During the transition to competition, PUC will be responsible for providing traditional regulation in areas without effective competition, primarily bysetting rates. For telecommunications, continued rate regulation is likely tobe needed in rural and isolated areas for several years at least. Competitionin the electric industry has been authorized at the wholesale level, but notfor retail. Even with retail competition, local distribution systems that bringelectricity into homes and businesses are likely to remain monopolies, witheither PUC or a local municipality or cooperative continuing to set rates.
Competition will reduce the agency's need to set rates and therefore its ratecaseload. Rate regulation should eventually cease entirely in thetelecommunications industry; in the electric industry, which is opening tocompetition more slowly, rate cases ultimately will be limited largely totransmission and distribution.
TPR's examination of PUC's current regulatory process found it to be generallyeffective and consistent with those of other states. Of concern, however, isthe significant time and expense devoted to the entire contested case process.TPR found that Florida uses a process that resolves a significant percentage ofcontested cases without formal legal hearings. TPR proposes that PUC beauthorized to adopt a similar process to streamline its contested case process.
In addition, TPR found that PUC sometimes uses its preliminary order process,which is intended to streamline contested cases, to expand rather thannarrow the scope of issues for a hearing. TPR recommends that PUC develop rulesto correct this situation and ensure that preliminary orders are used to limitcases.
Another area of concern related to the contested case process involves the significant amount of staff time devoted to answering discovery requests. TPR found that other Texas regulatory agencies and utility regulatory agencies in other states have more efficient ways of using their staff resources in contested cases, and recommends that PUC be authorized to adopt a process similar to that of Ohio's agency. This would substitute staff reports for the traditional public interest case, and would ease the PUC staff's responsibilities regarding discovery.
TPR also found that, while PUC has made significant progress towards implementing the recent legislative changes, its rules do not yet contain a quantifiable definition of competition or procedures for regularly monitoring the effects of expanded competition. TPR recommends that such rules be developed to ensure that the agency has the information needed to manage what will basically be a two-track regulatory system during the transition to competitive markets.
PUC should streamline its process for handling contested cases.
Texas' Administrative Procedure Act (APA) outlines the basic processesstate agencies must use to establish policies and resolve issues and questionsbrought before them. In general, agency policies are established through arulemaking process, while specific issues and questions are resolved through a"contested case" process. The contested case process gives interestedindividuals and companies the opportunity to present information concerning aspecific question or issue to the agency in a hearing.
Each agency can add its own, more detailed procedures to the basic APArequirements.[ 1 ] In addition, some agencies' enabling statutes add furtherrequirements. For instance, PUC must follow APA as well as specific provisionsin the Public Utility Regulatory Act (PURA) when conducting contested cases.PURA requires PUC to follow APA for all proceedings unless PURA specifiesanother process.[ 2 ]
A large share of PUC's regulatory duties are carried out through the contestedcase process. For example, PUC sets rates that utilities may charge theircustomers; determines the boundaries of each utility's service area; authorizesthe building of additional power plants; and verifies the fuel costs a utilitypasses on to its customers.
Each year a large number of contested cases are filed with PUC--672 in fiscal1995 and 806 in fiscal 1996.[ 3 ] Each request must be filed in writing at PUC; theLegal Administration Division then assigns each case a tracking or "docket"number. A case may be filed by a utility, one of its competitors, or aratepayer. Generally, those affected will be a utility, customers whose ratesor services will be affected by the case, or any of the utility's competitorsor potential competitors.[ 4 ] Under PUC rules, these individuals and companiesthat will be affected by the case can tell PUC that they wish toparticipate or "intervene" in the case; participants are called parties to thecase.[ 5 ]
Types of cases
PUC cases fall into three different groups; PUC uses a different approach to process each group. The first group consists of cases requesting PUC approval of a proposed action by a utility that is unopposed by any party. For example, to better serve additional customers in its service area, a utility may request authority to extend a transmission line. If no one objects to the line, the Legal Administration Division, relying on recommendations filed by the Office of Regulatory Affairs, will review the case for compliance with agency rules and prepare a proposed order for the commissioners to adopt in an open meeting. Such cases make up about 85 percent of all contested cases filed with PUC. If an objection is raised, however--if property owners object to the extension of a transmission line across their land, for example--the case is set for hearing by the State Office of Administrative Hearings (SOAH).
The second group, about 5 percent of all cases, consists of those that do not involve disputed facts and may be resolved on legal grounds without a hearing. For example, questioning whether PUC's authority extends to a particular provider or service. Parties to such cases file briefs outlining their positions with Legal Administration, or with the commissioners if they decide to consider the case directly themselves.
If the Legal Administration Division conducts the case, it reviews the briefs and prepares a recommendation for the commissioners that also is sent to all parties to the case. The parties may file exceptions outlining their areas of disagreement with the recommendation. The commissioners then consider the recommendation and exceptions in an open meeting and issue a final order. If the commissioners consider the case directly themselves, the parties simply file their briefs and await consideration of the matter in open meeting and issuance of the final order. After this action, any parties not satisfied with the outcome may file a motion for rehearing of any issues in the case. The commissioners may grant a rehearing or let the motion die without action. Parties may file an appeal in state district court.
The third group of cases involve disputes over facts that require a judge to establish the truth. A case is classified as "protested" if PUC believes a hearing will be needed to introduce and evaluate evidence on the facts.[ 6 ] Protested cases can involve issues such as whether a utility has prudently managed a facility, or paid a reasonable price for its fuel. All major cases fall into this group. PUC transfers protested cases to SOAH unless its commissioners choose to hear them personally.[ 7 ] Protested cases make up only about 10 percent of PUC's caseload, but take the majority of available staff time to litigate and resolve.
Protested cases: the process
In transferring a case to SOAH, Legal Administration asks that an administrative law judge be assigned to the case.[ 8 ] Parties to the case then seek additional information or clarification from the other parties involved, in a process known as "discovery." The judge hearing the case sets deadlines for questions and responses in line with PURA requirements. For example, rate cases must be concluded within 185 days after being filed, although this deadline may be extended if the actual hearing time exceeds 15 days.[ 9 ] The hearing at which deadlines are set generally occurs within 15 days of the case being transferred to SOAH.
Once a case is filed, PUC's commissioners may issue a preliminary order outlining the issues to be addressed by the parties to the case. These orders are drafted by the agency's Office of Policy Development (OPD) after case review and private consultations with the commissioners individually. The order also may state PUC's position on legal or policy issues.[ 10 ] These orders are prepared while discovery is being conducted and are issued within the first six weeks of the case's transfer to SOAH.
After discovery is completed, SOAH hears evidence on the disputed issues. Major rate hearings usually begin about 100 days after a case is filed.[ 11 ] At the end of the hearing, SOAH prepares a proposal for decision and submits it to PUC and the other parties to the case. The parties may file exceptions with PUC; PUC's commissioners can adopt the judge's recommendations or reach an alternative decision. Any party not satisfied with the commissioners' decision may file a motion for rehearing of any issues in the case. The commissioners may grant a rehearing or let the motion die without action. Parties can appeal to state district court.
PUC streamlining efforts
PUC's existing efforts to streamline its contested case process have focused on reducing the number of issues in dispute and limiting the time allowed for certain phases of the process. PUC's preliminary orders, for instance, are designed to streamline contested cases by limiting the issues early in the case that may be addressed, which in turn can reduce the amount of discovery needed and the hearing's overall length.
Issues also can be limited through a prehearing conference conducted by the Legal Administration Division. A prehearing conference sets out the issues in a case and weighs the possibility for a settlement. The hearing process can be limited or avoided if case issues can be settled in advance. However, PUC walks a fine line in determining if a settlement is possible. If a case requires a hearing and PUC delays sending it to SOAH to encourage settlement, the amount of time left available to complete remaining steps is reduced in order to meet statutory deadlines.
PURA gives PUC limited authority to streamline the hearing process. PURA allows PUC to limit discovery and the amount of time parties have to present their case, and to limit cross-examination of witnesses.[ 12 ]
Problems with the process
Protested cases can require many months of hearings; one recent case, for instance (Central Power and Light, Docket No. 14965), required more than 6 months of hearings.[ 13 ] On average, major cases take about 50-60 days of hearing time; medium-length cases require two to three weeks. One factor contributing to the length of hearings is the number of parties to a case. The Central Power and Light (CP&L) case cited above involved 24 parties.[ 14 ]
The complexity of issues in contested cases also contributes to the length of time needed to complete them. PUC's commissioners may, for instance, be called upon to determine whether a utility has made prudent investments, which can have a profound effect upon rates for many years. In addition to such complex issues, many large utilities have portions of their business that are not regulated by PUC. To ensure that utility customers do not subsidize unregulated portions of the utilities' business, PUC must allocate shared costs to the appropriate service.[ 15 ]
Furthermore, contested cases are expensive, with substantial costs for attorneys and expert witnesses. CP&L has asked PUC to approve almost $13 million for its expenses associated with its recent case.[ 16 ] All expenses approved by PUC will be passed along to CP&L ratepayers. In addition, state law allows cities to recover their costs associated with participating in cases before PUC from the appropriate utility. Cities that intervened in the most recent CP&L case may recover about $1 million from CP&L, which in turn will pass on that cost to its ratepayers.[ 17 ]
It should be noted that PUC sometimes uses its ability to issue preliminary orders to expand rather than narrow the scope of issues for a hearing. For example, in the recent CP&L case, the preliminary order expanded the scope of the hearing to include competitive issues such as performance-based regulation and a plan for stranded investments. At the time, PUC was conducting a study on such competitive issues in electric markets and collecting information from many utilities. Opinions differ on the extent of PUC's authority to act on these issues and whether it was appropriate for PUC to include these issues in the case.
Even so, this expansion of the scope required all parties to the case, including PUC, to commit additional resources. CP&L indicated that the expanded scope added three weeks to the hearing as well as more than $3 million in expenses to the utility alone.[ 18 ] CP&L will pass these costs along to its ratepayers.
The timing of a preliminary order also may cause problems. Generally it is issued after discovery is already under way, and if new issues arise as a result of the order, the parties may not have enough time before the hearing to fully investigate them.[ 19 ]
Other states' efforts
TPR surveyed 11 other state utility agencies and interviewed the staff members of the National Regulatory Research Institute to identify additional ways to streamline the contested case process. TPR's research identified a process used by the State of Florida that resolves a significant percentage of cases similar to PUC's protested cases without a hearing.
Since 1979, Florida law has allowed its Public Service Commission (PSC) to use a proposed agency action (PAA) process. Once a case is filed, PSC's staff makes an informal determination as to whether the case is appropriate for this process. PAAs generally are not used with controversial and complex cases.
If a case is deemed appropriate for a PAA, PSC's technical staff begins reviewing the case documents. The PAA, a staff-proposed decision, is completed well in advance of legal deadlines; for example, certain telephone tariff matters must be concluded within 60 days. Therefore the PAA would be completed within 30 days after the case is submitted.
After PSC staff completes a PAA, it is posted as an agenda item for future commission action. Affected parties have 21 days to object to any part of the PAA and request a hearing; otherwise, the PAA is adopted unless PSC's commissioners disagree with it. Any subsequent hearing is limited to specific issues in the PAA to which a party objects.
The PAA process has successfully limited the number of cases going to hearing. Prior to the use of PAAs, most cases went to hearing; now only about one-fourth do. Only about 5 percent of those cases in which a PAA is issued ultimately result in a hearing.[ 20 ]
A. State law should authorize PUC to use proposed agency actions in protested cases.
PUC should develop rules defining when a PAA process should be used and establishing applicable timelines. The rules also should specify that parties to the case would have 21 days to object to any of a PAA's findings and recommendations. If they do not object, the PAA would become final upon commission approval and no other hearing would be necessary.
B. PUC should amend its rules to specify that preliminary orders are to be used to limit cases to those issues absolutely necessary to a fair resolution, and to specify the timing for issuing preliminary orders.
Preliminary orders should be used only to streamline the cases classified as protested, by limiting issues to be addressed to those that are absolutely relevant to a fair resolution of the case.
The timing of preliminary orders should be established early enough to allow the discovery period adequate time to address all issues in the case. PUC and SOAH should work together to develop timelines that allow both agencies to effectively carry out their duties.
State law required the State Office of Administrative Hearings (SOAH) to conduct PUC's contested case hearings beginning in fiscal 1996. PUC's fiscal 1996 contract with SOAH totalled $1,034,284 that included several one-time costs. To complete the hearings, SOAH logged 12,224 hours. A review of SOAH's hours found that 34 percent was allocated to cases that could be resolved using the PAA process. In addition, Proposal 16 in this report requires the use of alternative dispute resolution (ADR) and assumes that ADR would be successful in half of the cases in which it is used. Those cases that are not resolved with ADR would also be added to the pool of cases that could be resolved using the PAA process, accounting for 21 percent of SOAH's hours.
The State of Florida avoided 75 percent of its hearings using the PAA process.[ 21 ] Assuming PUC resolved 50 percent of its eligible cases with a similar process, PUC would have saved $284,400. The fiscal 1997 contract with SOAH is $707,000. Assuming that SOAH's hours would be allocated in the same percentages, PUC would save $194,500. This savings would be available to fund other recommendations in this report.
PUC should also realize a productivity savings of more than 9,000 hours of staff time, slightly more than four full-time equivalent employees. This productivity savings is associated with the amount of time that is no longer allocated to preparing and participating in hearings.
PUC should modify its staff participation in contested cases.
As noted in the previous issue, PUC's contested case process does not limit the number of parties who may participate in a case. PUC employees act as parties in contested cases that go to a hearing; in such instances, the agency's Office of Regulatory Affairs is responsible for preparing and presenting evidence.[ 22 ] In acting as party to a case, PUC is required to represent the public interest, balancing the special interests of all the other parties involved to create the maximum benefit to society.[ 23 ] (In contrast, the Office of Public Utility Counsel has a legislative mandate to act as an advocate for the interests of residential and small business consumers.)
The issues addressed in PUC's contested cases often are highly complex, including rate-setting, plant-building decisions, and judgments concerning utilities' economic performance and prudence. To deal with such issues, PUC employs engineers, economists, accountants, financial analysts, attorneys and other policy experts. These specialists review documents filed by parties to a case; participate in discovery, requesting information and responding to other parties' requests as needed; and present testimony and examine witnesses at hearings. Because these PUC employees are a party to the case, they cannot discuss the case with the administrative law judge or PUC's commissioners unless all other parties have been given notice and an opportunity to be present.[ 24 ]
Practices at other state agencies
Contested case practices vary at Texas' other three major regulatory agencies, the Texas Railroad Commission (RRC), Texas Natural Resource Conservation Commission (TNRCC), and Texas Department of Insurance (TDI). RRC's procedures are similar to PUC's. TNRCC, however, does not always choose to participate as a party to a hearing; instead, the agency's executive director may simply comment on the order proposed by an administrative law judge.[ 25 ] TDI no longer acts as a party to contested cases involving insurance rates, focusing instead on an advisory and informational role.[ 26 ]
TPR found that the Ohio Public Utilities Commission uses a potentially useful approach to treating contested cases. Until recently, this approach was limited to rate cases and cases authorizing new electric generation and transmission facilities; in the past few years, however, the process has been expanded to other types of cases.
When a case is filed, agency staff begin preparing a staff report that is a proposal for decision. While the report is being prepared, other parties to the case participate in the discovery process. In contrast to PUC's situation, Ohio staff members may request information and receive copies of all the other parties' requests and responses, but are not required to respond to requests from other parties. Once the staff report is issued, the parties have 30 days before the commissioners take action on the case. Commission action can include accepting the staff report, accepting a partial or complete settlement, or referring issues to a hearing. Typically, during these 30 days, the parties review the staff report and negotiate a partial or complete settlement. If any issues in the case are referred to a hearing, the commission staff presents its case, as outlined in the staff report.[ 27 ]
This process has helped Ohio's agency make better use of its staff resources by allowing employees to focus on their analysis of the case rather than discovery procedures. Moreover, the staff report, rather than the utility's initial request, serves as the key document to which all parties have to respond. All parties retain the right to be heard on issues in dispute, and decisions are based upon a public record.
A. State law should be amended to authorize PUC to employ staff reports rather than its traditional public interest cases.
To implement the statute, PUC should establish rules that should specify the types of cases eligible for this process and general timelines for filing staff reports. This date would be set on a case-by-case basis by the commissioners or the administrative law judge hearing the case. Following issuance of the staff report, the rules should specify that other parties in the case would have at least 14 days to respond. Only those parts of the report disputed by the parties would be subject to a hearing. PUC would become subject to discovery actions after filing its report. PUC's commissioners could reject any settlement they find unfair to the public.
Using staff reports, like using the protested agency action process described in the previous issue, are additional tools for PUC to use to streamline and possibly avoid hearings. PUC would retain the ability to determine which process is most appropriate to resolve each case.
B. Section 1.(b)(2) of the Public Utility Regulatory Act should be amended to exempt PUC staff from responding to discovery requests until it completes a staff report for the case.
This recommendation would allow PUC to focus its initial efforts on analyzing the issues presented in the contested case instead of answering discovery requests, while allowing its staff to collect information needed to prepare the report.
Changing its role in the protested case process would allow PUC to accrue savings in staff time that cannot be estimated. Any productivity savings could be redirected to carry out new tasks associated with overseeing the transition to competition.
PUC should establish a system for identifying and monitoring competition in telecommunications markets.
The 1995 Texas Legislature amended the state's Public Utility Regulatory Act (PURA) to encourage fair competition among local telephone service providers.[ 28 ]
As competition emerges, PUC will be forced to significantly modify its current approach to regulation. This will involve a switch from traditional economic regulation (rate setting and restrictions on market entry) to a broader oversight intended to ensure quality service for consumers and a level playing field for new competitors. This shift will not happen overnight, and will occur more rapidly in major urban areas due to the greater economic opportunities available there. Some rural areas will continue to operate without competition for some time.[ 29 ]
During the transition to competition, PUC will continue to be responsible for traditional regulation, including rate-setting, in areas without effective competition. This will ensure that consumers in rural and isolated areas continue to receive adequate services at a reasonable rate.
To make this two-track approach to regulation work, PUC must be able to decide when a local market is in fact competitive. Effective competition exists when, as one analyst put it, "buyers [have] real alternatives sufficient to enable them, by shifting their purchases from one seller to another, substantially to influence quality, service, and price." In other words, buyers have genuine alternatives that give them "substantial protection against exploitation by sellers."[ 30 ]
Quantitative measures can be applied to determine whether such "effective" competition exists. For example, the U.S. Department of Justice uses economic modeling to determine whether competition exists in various markets.[ 31 ] PUC is examining similar models for use in Texas.
One of the major difficulties in defining and measuring competition is that it can occur in different ways and at different rates, varying widely among services, geographic locations, and types of customers. Commercial and industrial services may become competitive well before residential services. Certain services, such as special fiber loops or cellular services, may become competitive in a given area while most services remain essentially noncompetitive. Alternatively, competition may exist for all services in some parts of an area but not others. PURA does not require new service providers to serve all of an existing local telephone service area. These factors may result in a crazy quilt of emerging competitive markets and services, depending on how competition is defined and measured.
The existence of competition, as a legal or philosophical question, could be debated endlessly. As a practical matter, however, PUC must develop a workable definition if its post-deregulation role is to be successful. Public utility commissioners, at a national summit in 1995, "expressed widespread agreement that, in the face of emerging competition and in segments of utility markets where all customers did not uniformly benefit from competition, commissions have a role in protecting certain customers." Identifying those customers and ensuring appropriate oversight for the services provided them was seen as a key mission of utility agencies during the transition to deregulation.[ 32 ]
While the agency has made significant progress towards implementing the recent legislative changes, PUC rules do not yet contain a workable, quantifiable definition of competition. Moreover, while PUC collects information on competition to prepare its biennial report to the Legislature, the agency does not have a regular process for monitoring the effects of deregulation on an ongoing basis.
One factor needing careful attention in the transition to competition is the existence of inappropriate "cross-subsidies." Cross-subsidies are funds from one part of a company's business that are used to lower prices in another, particularly between regulated and unregulated parts of the business.[ 33 ] PURA directs the PUC to ensure that prices for competitive services not be subsidized either directly or indirectly by noncompetitive services.[ 34 ]
In the patchwork world of the transition, telecommunications companies may provide some services that are competitive and others that are not, and some that are regulated and others that are not. A clear definition of competition will facilitate PUC's efforts to ensure that companies do not inappropriately cross-subsidize services.
A. The PUC should develop formal rules for determining when a telecommunications market or service is "competitive."
The rules should focus on a workable, quantifiable definition of competition that will aid the agency in tracking the evolving patchwork of competitive services and markets across an expanding number of telecommunications service providers. The definition should support the agency's ongoing efforts to prevent inappropriate cross-subsidization of services between regulated and unregulated parts of a business.
Significant public input should be obtained as part of the formal rulemaking process and the rules should reflect and comply with evolving federal telecommunications law and requirements. Placing such a definition in rules will give PUC the flexibility to adjust the definition as needed to an ever-changing telecommunications environment.
B. PUC should develop a standard mechanism for periodically gathering information from providers to enable the agency to monitor the ongoing effects of competition and changes in the market caused by deregulation.
This change would ensure that PUC remains informed in a rapidly changing environment by ensuring that the agency collects this data on an ongoing basis, not simply biennially for its report to the legislature.
PUC should be able to implement these recommendations within its existing resources.
[ 1 ] V.T.C.A., Government Code SS2001. and SS2001.(c).
[ 2 ] Vernon's Ann. Civ. St. art. 1446c-O, SS1..
[ 3 ] Memorandum from Paula Mueller, director, Legal Administration Division, Public Utilities Commission of Texas, Austin, Texas, December 2, 1996.
[ 4 ] Vernon's Ann. Civ. St. art. 1446c-O, SS1.(1).
[ 5 ] 16 T.A.C. SS22..
[ 6 ] State Bar of Texas, "Practice Tips Before the State Office of Administrative Hearings," 1996 Advanced Administrative Law Course, by J. Kay Trostle, director, Utility Division, State Office of Administrative Hearings (Austin, Texas, September 1996), p. I-35.
[ 7 ] Vernon's Ann. Civ St. art. 1446c-O, SS1.(e).
[ 8 ] Interview with Paula Mueller, director, Legal Administration Division, Public Utility Commission of Texas, Austin, Texas, October 17, 1996.
[ 9 ] Vernon's Ann. Civ. St. art. 1446c-O, SS2.(d).
[ 10 ] State Bar of Texas, "Practice Tips Before the State Office of Administrative Hearings," p. I-36.
[ 11 ] Interview with Paula Mueller, director, Legal Administration Division, Public Utility Commission of Texas, Austin, Texas, December 11, 1996.
[ 12 ] Vernon's Ann. Civ. St. Art. 1446c-O, SS1.(b)(3).
[ 13 ] Interview with Phil Ricketts, Bracewell & Patterson, Austin, Texas, December 6, 1996.
[ 14 ] Interview with Phil Ricketts.
[ 15 ] Interview with Jim Boyle, Law Offices of Jim Boyle, Austin, Texas, November 5, 1996.
[ 16 ] Interview with Phil Ricketts.
[ 17 ] Vernon's Ann. Civ. St. art. 1446c-O, SS2..
[ 18 ] Interview with Phil Ricketts.
[ 19 ] Interview with Suzi Ray McClellan, public counsel, Office of Public Utility Counsel, Austin, Texas, October 18, 1996.
[ 20 ] Interview with David Smith, director, Appeals Division, Florida Public Service Commission, Tallahassee, Florida, November 26, 1996.
[ 21 ] Interview with David Smith.
[ 22 ] Interview with Carole Vogel, Office of Regulatory Affairs, Public Utility Commission of Texas, Austin, Texas, October 17, 1996.
[ 23 ] Vernon's Ann. Civ. St. art. 1446c-O, SS1.(d)(7).
[ 24 ] V.T.C.A., Government Code SS2001.(a).
[ 25 ] Interview with Greg Cooke, attorney, Austin, Texas, December 19, 1996.
[ 26 ] Interview with Caroline Scott, general counsel, Texas Department of Insurance, Austin, Texas, November 14, 1996.
[ 27 ] Interview with Lou Pompi, chief of forecasting, Ohio Public Utilities Commission, Columbus, Ohio, January 6, 1997.
[ 28 ] Vernon's Ann. Civ. St. art. 1446c-O,SS3..
[ 29 ] Public Utility Commission of Texas, 1997 Report to the Legislature on the Scope of Competition in Telecommunications Markets (Austin, Texas, November 18, 1996), Chapter 11. (Draft report.)
[ 30 ] Clair Wilcox quoted in Public Utility Commission of Texas, 1997 Report to the Legislature on the Scope of Competition in Telecommunications Markets, pp. 15-16.
[ 31 ] Interview with Rowland Curry, Office of Policy Development, Public Utility Commission of Texas, Austin, Texas, December 9, 1996.
[ 32 ] The National Regulatory Research Institute, Missions, Strategies, and Implementation Steps for State Public Utility Commissions in the Year 2001: Proceedings of the NARUC/NRRI Commissioners Summit (Columbus, Ohio, May 1995), p. 8.
[ 33 ] Frederick Williams, The New Telecommunications: Infrastructure for the Information Age (New York, The Free Press, 1991), p. 222.
[ 34 ] Vernon's Ann. Civ. St. art. 1446c-O, SS3.(b)2(B).
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