II. Pacific's Compliance Filings

In compliance with D.02-09-049, Pacific submitted its recalculation of UNE rates on December 18, 2002. On January 21, 2003, AT&T Communications of California (AT&T) and WorldCom Inc. (WorldCom) (collectively "Joint Applicants") filed comments alleging that Pacific's filing was incomplete. They argued that the filing did not adequately comply with Ordering Paragraph 3 of D.02-09-049, which ordered Pacific to calculate "the net impact on all of its UNE prices of the markup and recurring cost changes ordered herein." Joint Applicants did not dispute the calculations contained in Pacific's compliance filing, only that it was incomplete because new rates were not calculated for all of Pacific's UNEs.

In a ruling dated February 25, 2003, the assigned ALJ directed Pacific to supplement its compliance filing with further rate recalculations for additional UNEs. Pacific submitted a supplemental compliance filing on March 21, 2003. On April 11, 2003, Joint Applicants, TRI-M Communications Inc., Anew Telecommunications Corporation and Sage Telecom, Inc. joined together to protest Pacific's supplemental filing as incomplete. These parties again claimed that Pacific failed to recalculate rates for all of its UNEs, particularly several adopted through negotiated interconnection agreements. Once again, the protest did not dispute the calculations for the rates contained in the supplemental filing, only the completeness of the filing.