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HomeMy WebLinkAbout19991105Comments 2.docBRAD PURDY DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0357 IDAHO BAR NO. 3472 Street Address for Express Mail: 472 W. WASHINGTON BOISE, IDAHO 83702-5983 Attorney for the Commission Staff BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE JOINT APPLICATION OF CENTURYTEL OF IDAHO, INC. AND CENTURYTEL OF THE GEM STATE, INC. TO REDUCE ACCESS RATES AND REBALANCE OTHER RATES FOR TELECOMMUNICATIONS SERVICE. ) ) ) ) ) ) ) CASE NO. CEN-T-99-3 CGS-T-99-4 COMMENTS OF THE COMMISSION STAFF COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its attorney of record, Brad Purdy, Deputy Attorney General, and in response to the Notice of Application and Notice of Modified Procedure, Order No. 28171 issued on October 20, 1999, submits the following comments. BACKGROUND On September 27, 1999, CenturyTel of the Gem State (CGS), which provides local exchange service in the Richfield, Bruneau, Grand View and Grasmere/Riddle exchanges, filed a Joint Application to reduce access rates and to rebalance other rates for telecommunications services (CGS-T-99-4). A similar Application (CEN-T-99-3) was filed at the same time for CenturyTel of Idaho, which shares the same parent company, for its exchanges in the Salmon area. These Applications were filed after consultation with Staff in order to address the requirements of Idaho Code § 62-623, which calls for the Commission to identify and quantify the implicit subsidies within the rates of incumbent telephone corporations in Idaho, and goes on to specifically identify access charges paid by intrastate interexchange carriers as one of the implicit subsidies that is to be reduced. Subsection (2) of the statute directs the Commission to “determine a mechanism for the removal of subsidies from the rates of incumbent telephone corporations.” The reduction in access charges contained in the Joint Application is intended to address this requirement. Under the Company’s proposal, access charges would be reduced from CGS’s current composite rate of $0.13650 to $0.06, a reduction of more than 50%. CenturyTel proposes to restructure its access rates in a manner that conforms to the federal goal of identifying and separating traffic-sensitive and nontraffic-sensitive costs and revenues. The Company establishes per-minute switching and termination rates and per-mile per-minute transport rates. This rate structure provides more flexibility for carriers who will benefit from a choice of dedicated (direct) or switched (common) transport facilities. Non-traffic sensitive costs are assumed to be included in the carrier common line charges that are residually set to achieve CenturyTel’s target of $0.06 per minute. When fully implemented these changes will bring the rates much closer to the statewide average rate in Idaho and will move intrastate access rates toward interstate rates; a move consistent with the requirements of the federal Telecommunications Act of 1996. A portion of the revenues lost due to these reductions in access rates will be made up by increases in other charges, primarily the rates for basic local exchange service. These rates will increase significantly. Residential rates in all 4 exchanges will be increased to $21.28 per line per month, with business customer rates increasing to $39.77 per line per month. These rates are the current threshold rates for companies receiving funds from Idaho’s Universal Service Fund (USF), which is 125% of the statewide average rate. In addition, a rural additive of $3.00 for residential customers and $6.00 for business customers will be added to these rates for all customers located outside the base rate area. This results in rural customers paying monthly rates of $24.28, and $42.77 for residential and business service. The rural residential customers in the Grasmere/Riddle exchange who currently pay $4.75 per line for party line service will now receive one-party service at $24.28, an increase of over 500%. Residential customers in the other 3 exchanges will see rates increase from $9.40 per month to $24.28 for rural customers or $21.28 for those located in the base rate area. As over 70% of the residential customers live outside the base rate area, the majority of the customers will see an increase of over 250%. Business rates increase from the current rates of $17.40 ($7.75 in Grasmere) to $45.77 for rural business and $39.77 for business located in the base rate area (approximately 40% of businesses). CGS proposes to introduce these rate changes in 2 steps - an initial transitional step in which these rates will increase to $12.76 for residential ($15.76 with rural additive) and $23.84 for business ($29.84 with rural additive), followed by full implementation in one year. The reductions in access rates would also be accomplished in 2 steps. The initial step reduces the composite rate by one half of the target amount to a composite rate of $0.09860 for CGS. The second step is a further reduction of carrier common line rates to bring the composite rate to $0.06 per minute. Implementation of this rate reduction in 2 steps allows the Company to reduce the “rate shock” to its local customers. In addition, the Application proposes to address Extended Area Service (EAS) issues raised in 2 existing cases, GNR-T-97-4, which was initiated in response to petitions for EAS filed by customers in the Richfield exchange, and GNR-T-99-2, which was initiated in response to petitions for EAS from customers in the Bruneau and Grand View exchanges. In both of these cases the customers have petitioned for EAS to the regional local calling areas that border these exchanges. The proposal includes extending the local calling area of Richfield customers to include the entire Magic Valley calling area. The proposal includes expanding the local calling area of Bruneau, Grand View and Grasmere/Riddle exchanges to include the exchanges of Mountain Home and Melba, but not the entire Treasure Valley Region. STAFF ANALYSIS Richfield EAS The Commission assigned Case No. GNR-T-97-4 to consider the reasonableness of establishing EAS routes between the communities of Richfield and the communities of the U S WEST Communications, Inc.’s (U S WEST) Magic Valley EAS region. Staff witness Wayne Hart’s testimony in that case was prefiled on February 19, 1998. However, the technical hearing in that case was postponed indefinitely and that testimony was not officially placed into the record. Staff has included that testimony as an attachment to these comments. In that testimony, Staff indicated that a strong community of interest exists between the community of Richfield and the other communities in U S WEST’s Magic Valley calling area. Strong ties exist with the hub of the region, Twin Falls, and also with the communities of Shoshone and Gooding, with significant ties into the community of Jerome as well. Nearly all of the community of interest factors as set forth in Commission Order No. 26311, which established guidelines and factors to be followed when evaluating EAS petitions in addition to the calling data, support extending the calling area. However, Staff did not recommend EAS to the entire region at that time because the cost of providing the requested EAS, on a revenue neutral basis, was higher than the savings a typical Richfield customer would have received. In addition, the Idaho Legislature had directed the Commission to address the subsidies hidden in the access charges of companies such as CenturyTel, which could have a significant impact on the cost of providing EAS. It was hoped that the EAS issue could be addressed in the restructuring of the Company’s rates. Staff also examined the feasibility of providing EAS over a single route, such as to Shoshone or Twin Falls, but the calling patterns were so distributed among the different routes that no single route was believed to adequately meet the customers’ needs. The Company’s current proposal addresses the same EAS routes identified in Case No. GNR-T-97-4, and would provide extended area service to Richfield customers that includes local, seven digit access to all the exchanges currently within the U S WEST Magic Valley calling region. Staff believes EAS to the entire Magic Valley region is the appropriate solution. The calling patterns of Richfield customers were spread relatively evenly among Shoshone, Twin Falls, Gooding and Jerome. This indicates a significant community of interest between Richfield and each of these communities. The relatively few calls placed to any of the other exchanges results in an incremental cost of providing the entire region, instead of just these 4 exchanges, that is relatively small. The value of providing the entire region, in terms of less customer confusion, easier administration and enhanced regional economy, far outweighs the incremental costs of serving the exchanges that did not share a strong community of interest with Richfield. The access charge reductions included in this proposal have significantly reduced the revenue impact of EAS over these routes, and the revenue impacts are now more reasonable. In addition, as the Company’s proposal is not revenue neutral and these EAS routes will be provided at less than full recovery of lost revenues, the actual cost to the customer appears quite reasonable. Therefore, including these EAS routes in this proposal provides the customers with a very valuable service at a reasonable price. Bruneau/Grand View/Riddle EAS Issues In response to signatures submitted on November 17, 1998 from approximately 250 customers from the Bruneau and Grand View area requesting EAS to Mountain Home, Boise, and the Treasure Valley calling region, the Commission opened Case No. GNR-T-99-2. Staff requested and received calling data from the Company. However, discussions regarding the Company’s rate restructuring proposal were initiated about this same time so no proceedings were scheduled and no testimony has been prepared for that case. COMMUNITY OF INTEREST STANDARDS According to Order No. 26311, calling volume and calling distribution are among many primary and secondary factors to be used when evaluating EAS calling areas. To determine whether a community of interest exists to support EAS, the primary factors in addition to the calling data are as follows: 1. Geographic proximity (distance between exchanges); 2. The presence of geographic or other physical barriers (mountains, rivers, valleys) between exchanges; 3. County seat relationship (are both exchanges in the same county); 4. The relationship to school districts (do both exchanges share the same school district); 5. The proximity to medical facilities and services; 6. The willingness of customers to pay increased rates. In general, the calling data indicates that customers from the Bruneau, Grand View and Grasmere/Riddle exchanges place approximately one third of their calls into the region to the Mountain Home exchange, one third to the Boise Exchange, and the rest to the remaining communities in the U S WEST region. The average number of calls to the region per line per month is over 16 for residential users, and nearly 22 for businesses for a combined average of 17.5 calls per line. Residential callers from all 3 exchanges made an average of just over 7 calls per line to Mountain Home, while business lines averaged almost 8 calls per month with the combined average just under 7.5 calls per line per month. The average residential line made over 4 calls per month to Boise, with business lines averaging more than 6.5 calls per month, for a combined average of just under 5 calls to Boise per line per month. The average number of calls to all the other exchanges in the region for residential lines was just under 5, with the average for business at a little over 7 calls per month, for a combined average of nearly 5.5 calls per line per month. The data only allows for an analysis of call distribution on an individual exchange basis, so Staff was not able to determine the distribution patterns on a regional basis. However, more than 52% of the customers in these 3 exchanges made 2 or more calls each month to the Mountain Home exchange, and more than 42% made an average of 2 or more calls to the Boise exchange. 21% of the customers made 2 or more calls to Nampa, 13% made 2 or more calls to Meridian, 12% made 2 or more calls to Glenns Ferry, and 11% made 2 or more calls to Caldwell. Less than 10% of the customers in these 3 exchanges made 2 or more calls to any other exchange. This information indicates that, based upon current calling patterns, the majority of customers are likely to benefit from an EAS route to Mountain Home as they make more than 2 calls to that exchange now. However, just over 40% of customers made 2 or more calls to Boise and are considered likely to benefit from an EAS route to Boise. According to the Company’s data, more than 44% of the customers did not make a single call to Boise in an average month. The calling distribution for any of the other individual exchanges in the Treasure Valley region would be even worse, with only a minority of the customers making calls to any specific exchange. The Company provided proprietary data on the revenue impact of the proposed EAS routes, as well as the impact of including Boise or the entire region in the local calling area of these exchanges. Based upon this information, Staff estimates that rates would need to be increased considerably more than $8.00 more per line per month in order to recover these costs, which are estimated to be in excess of $100,000 per year. The resulting rates, with the rural additive included in this proposal, would be between $32 and $33 per month for rural residential customers, and over $53 per month for a rural business line. Expanding the proposed calling area to include only Boise (in addition to Mountain Home and Melba) would require just under half of that total, or slightly more than $50,000 per year, or an increment of approximately $4 per line per month. The Grand View and Bruneau exchanges both share part of their border with the Mountain Home exchange. The community of Bruneau is approximately 16 miles from Mountain Home, while the Grand View community is about 23 miles from Mountain Home. The Grand View exchange also shares part of its northern border with the Melba exchange. The Grasmere/Riddle exchange borders the Bruneau exchange on the south. All 3 of these exchanges are, for the most part, located south of the Snake River while the other exchanges in the Treasure Valley calling area are located north of the Snake River. Bridges to the north are located at the towns of Bruneau and Grand View with a third bridge located east of the Grand View exchange, south of the town of Melba. The highway access to the Treasure Valley exchanges for most customers is through Mountain Home, with the customers on the west end of the Grand View exchange using the highway through Melba. Most of the customers in these 3 exchanges live in Owyhee County, of which Murphy is the County seat. Murphy is located in the Melba exchange. Both the Bruneau and Grand View exchanges extend into Elmore County, and the County seat for those customers is Mountain Home. The Grand View exchange also extends into the southern end of Ada County. However, most of this area is either within the Birds of Prey Natural Area or National Guard Maneuver area, so it contains few if any customers. The Staff report in the Comprehensive Statewide EAS study (Case No. GNR-93-13) indicates the Bruneau-Grand View School District reported a significant number of its students and teachers lived in the Mountain Home exchange. Proximity to medical facilities and services is one of the reasons for EAS specifically identified on the petitions, and one of the most frequently mentioned reasons cited by individuals calling the Commission with comments in this case. The only medical facility in these 3 exchanges is the Grand View Clinic, which is staffed by mid-level providers. There are no doctors or dentists in these exchanges. The nearest hospital for most residents is in Mountain Home, which also has a number of general practice doctors, as well as dentists. Most medical specialists would only be available in Boise, Nampa or Caldwell. For those on the west end of the Grand View exchange, the nearest hospital would be in Nampa. Only a few other businesses and services are available with a local call. There is 1 local bank, a couple of farm/ranch supply stores, a few grocery/mercantile stores and a few convenience stores. Many of the services a household or business uses during its normal everyday activities require a long distance call. These are farming and ranching communities and most of the parts and services that farmers may need to keep their equipment in good operating condition also require a long distance call. Most of these services would be available in Mountain Home. Bruneau and Grand View customers can access the Internet without a toll call, but this is a relatively recent change, and only through a single provider. Staff understands the local dial-up access is only available through a cooperative venture with the schools. It required a substantial local investment to establish, and may require a continuing local contribution by the school system for its continuation. Additional local dial-up access would be available from Mountain Home, but most of the national providers would only be available through Boise. The only evidence available to indicate the willingness of customers to pay for the increased cost of EAS is the data from the petitions. Of the 240 customers who signed the petitions requesting EAS to the entire U S WEST Treasure Valley region, 223 also checked a box for the amount they would be willing to pay. Of those, 20% indicated a willingness to pay more than $10 extra per month, 41% indicated they would pay between $5 and $10 more per month, 29% indicated between $3 and $5, with the remainder indicating less than $3 per month. These responses indicate a greater willingness to pay than typically seen in other EAS cases. In summary, customers in these exchanges have a strong community of interest with Mountain Home, which provides most of the basic services they use on a day-to-day basis but are not currently available without a toll call. The Melba exchange would provide toll free access to their County seat. The community of interest with Boise is not as strong, but these communities are part of the greater Treasure Valley economy and these customers must call Boise for many of the medical specialists or other specialty needs that are only available from metropolitan sources. The community of interest between these CGS exchanges and the remaining exchanges of the Treasure Valley region is considerably weaker. ACCESS CHARGE REFORM The Company’s access charges are among the highest in the state and clearly priced well above actual cost. In that regard they could be viewed as a form of subsidy. In accordance with the wishes of the Idaho Legislature, as expressed in Idaho Code § 62-623, these subsidies are to be reduced. By bringing the composite rate for its access charges down to levels approaching the statewide average, the Company’s proposal accomplishes much of what is required by § 62-623. Staff believes this reduction to be sufficient at this time. As the Commission indicated in the Telecommunications Report to the Governor and The Idaho Legislature in January 1998, the Commission intends to use a “cost model” and company-by-company rate cases as the appropriate mechanism for removal of subsidies. The Federal Communications Commission has only recently reached its decision on the appropriate cost model for nonrural companies, and has only begun the process of looking into the appropriate models for rural companies such as CenturyTel’s Idaho exchanges. Until the appropriate tools for further analysis are available, this reduction should be sufficient. Even if these access charges are still above costs, Staff does not necessarily believe they should be reduced further. Again, quoting from the Commission’s 1998 Report, The Commission does not necessarily recommend that all subsidies be made explicit; instead it argues that a competitive business must recover all of its costs while at the same time have the freedom to set rates for its services as it sees fit in order to remain competitive. Any business that produces multiple products and services necessarily incurs joint and common costs that should, in theory, be incorporated to some degree in all prices. But there is no objectively correct method for allocating joint and common costs to multiple products. Furthermore, even if an allocation method is deemed to be correct, businesses often knowingly price goods or services at less than fully allocated costs in order to maximize overall revenues. RESIDENTIAL AND BUSINESS BASIC SERVICE RATES The proposed rates for basic local exchange access for both residential and business customers are at or just below the Universal Service Fund’s threshold rate, which is set at 125% of the statewide average. As they are essentially based upon the rates of other utilities, most of which have recently been revised to levels approved by this Commission, Staff believes these rates to be appropriate. RURAL RATE ADDITIVE The Company is proposing a flat, rural additive charge of $3.00 per month per line for rural residential customers, and $6.00 per month for business lines. Averaged or sometimes called “postage stamp” rates, where a customer pays the same amount for basic service, regardless of whether he/she is an urban customer next door to the central office or a rural customer miles away, have long been one of the guiding principles of ratemaking in order to encourage universal service. As the value of the phone system to all users increases if nearly everyone has a phone, all users benefit from policies that keep the cost of basic service reasonable in rural and high cost areas. Averaging the costs of providing service in rural or high cost areas with the costs in urban areas has historically been considered an acceptable method of keeping rates reasonable for all, and encouraging universal service. This Commission has eliminated additional rural charges in the rate structures of other companies. However, there is little question that rural lines cost the Company more to provide than do urban lines. In addition, the Federal Communications Commission has called for de-averaging of the wholesale rates charged to competitors, and it will be hard to maintain averaged retail rates if competitors can purchase wholesale at de-averaged rates. In addition, the proposed charges can be viewed as being consistent with the requirements of Idaho Code § 62-623, which calls for the removal of implicit subsidies from rates. The recent increase in the explicit subsidies available to individual users from the Idaho Telephone Subscriber Assistance Program will mitigate some of the impact of the higher rural rates. MEASURED SERVICE RATES The measured rate option proposed by the Company provides some customers with a reasonable alternative to this higher cost for flat rate service, especially when viewed in light of the wider local calling area. Measured service will provide a savings of $8 per month over flat rate service and includes 90 minutes of outgoing local calling per month without additional charge, with additional minutes over the 90-minute allotment priced at 3 cents each. These rates are very similar to those implemented by other independent telephone companies with basic service rates at or above the levels in this proposal. The Company has projected less than 10% of the customers would choose the measured service option, which is well within the range Staff would expect with this big of an increase in basic service rates. Since this is a new option for CGS customers, Staff believes that the availability of this option needs to be specifically identified in the notices of these changes the Company provides to its customers. Information should be provided to customers that clarifies and addresses common questions customers may have, including how the measured option will work and guidelines as to how a customer should evaluate their own calling in order to determine whether they might save by choosing the measured option, To facilitate customers moving from flat rate to measured local service, and to provide them with time to try this new option without a penalty, Staff recommends the Company be directed to waive any nonrecurring charges associated with such moves for a period of no less than 90 days. This should allow customers to move in either direction as they find the option that best fits their calling patterns. The information filed with the Application did not indicate whether call detail would be provided on the bills of customers who elect the measured option. Staff believes customers should be provided with at least an option to obtain billing detail, if it is not provided in the monthly bill. If a charge is to be imposed for providing this information, it should reasonable, and needs to be identified in the tariff. Staff also recommends that the Company’s tariffs be revised to clarify that a single customer may not mix flat and measured services. IDAHO TELEPHONE SERVICE ASSISTANCE PROGRAM The proposed rates may create difficulties for certain CGS customers who are on low incomes. The recent revisions to the Idaho Telephone Service Assistance Program (ITSAP) have increased the amount of assistance provided and the number of customers who will be eligible for assistance. Eligible ITSAP customers will now receive credits to their monthly charges for local service that can total up to $10.50 per month. Customers qualifying for this program would be able to obtain measured rate services for example, for less than $7.00 a month plus the cost of their local calls at $0.03 per minute. Staff believes that ITSAP can provide the necessary relief to those customers who would otherwise be hurt by the proposed increases. Current participation levels in the ITSAP program indicate that a significant percentage of households that are believed to be eligible for this discount have not yet applied for it. Staff believes the availability of this program also needs to be identified in the notices the Company provides to its customers. The information should include contact information for the Department of Health and Welfare and the appropriate community action agency. The Company should also work with the community action agencies to alert them of these increases, and to explore opportunities for jointly promoting the availability of this program. RATES FOR CUSTOM CALLING AND ADVANCED FEATURES Staff compared the proposed rates for the other services contained in the proposal with the rates charged by other Idaho companies for these services. In general, the rates were typically within the same price range as the other Idaho companies. None of these rates appeared to be unreasonably low or high. PHASE IN OF RATE CHANGES These rate increases are substantial, but partially because these customers are starting from such a low point. During the first year of the phase-in customers will see more than a 50% increase, but their rates will still be lower even with the rural additive than the rates paid by their neighbors who are U S WEST customers. At full implementation, the impact of the remaining rate increase will be softened by the increase in calling area. REASONABLENESS OF OVERALL PROPOSAL The basic service and other rates included in this proposal are generally considerably higher than current rates. However, when one looks at the overall revenue impact of this proposal, Staff believes these increases are not unwarranted. The Company projects a revenue deficiency associated with the CenturyTel of the Gem State proposal of over $100,000 per year and when combined with CenturyTel of Idaho, approximately half a million per year. While Staff has not conducted the rigorous level of audit typically associated with a rate case, it has examined the Company’s financial records. After considering the revenue deficiency associated with this proposal, Staff does not believe CenturyTel of the Gem State would be significantly overearning to warrant proposing different rates. Staff understands that the Company is willing to accept a revenue deficiency at this time because of other priorities within the Company. In addition, with rates set at the threshold for Universal Service Fund support, the Company would be eligible in the next rate case to request funds for any additional revenue requirement above the then current threshold revenues from Idaho’s Universal Service Fund (USF), rather than raising additional revenues from customers. However, the Company is also electing not to make such a request, at least at this point in time. As the USF surcharge will not need to be increased to cover the potential draw for CenturyTel, ratepayers throughout the state are the actual beneficiaries of the Company’s willingness to incur its calculated revenue deficiency with its proposal. CUSTOMER SERVICE The Consumer Assistance Division of the Commission received a total of 36 complaints, comments and inquiries from customers of CGS from January 1, 1996 through September 30, 1999. Fifteen of those were investigated by Staff, and the other 21 were general questions or inquiries. Twelve customers wanted their local calling region expanded: 1 customer asked that Richfield be included in the Magic Valley calling region, 2 in Bruneau asked to at least be able to call Mountain Home toll free, 1 customer from Grand View wanted to call Mountain Home or Nampa, and one customer near Murphy called to see if there was any possibility to expand his calling area to Nampa or Melba. Staff is pleased to note there was only one held order for service and 4 billing complaints. It is apparent from the relatively few Commission complaints that CenturyTel of the Gem State is providing excellent customer service. Due to a misunderstanding of its obligations, CenturyTel did not file a copy of the news release announcing its Application as required by Commission rule nor had a news release been sent out. Soon after Staff brought this matter to the attention of CenturyTel, the Company issued a news release to all appropriate media. In addition to that notice, CenturyTel agreed to individually notify customers of the Application and the public meetings to be held in November. RECOMMENDATIONS In general, Staff supports the Company’s proposal. Staff believes the proposal is a reasonable compromise that: 1) accomplishes the reduction in access charges required by Idaho Code § 62-623, 2) provides reasonable local telephone access to the services customers need on a regular basis, 3) provides rates at or below a level that could have been proposed, which minimizes the rate impact of these actions on the customers, and 4) does not include any request for funds from the Idaho Universal Service Fund. Staff recommends the proposal be approved. Staff supports the phase-in of the changes to access and local exchange service rates as a way to ease into the full impact of this rebalancing. Staff recommends the Company provide each customer with a reminder notice at least 30 days prior to the effective date of the first, as well as the second, phase. Staff assumes that new customers coming on service will pay the same rate as existing customers during the phase-in period, and not the ultimate rates. To facilitate customers moving from flat rate to measured local service, Staff recommends the Company be directed to waive any nonrecurring charges associated with such moves for a period of no less than 90 days. This should allow customers to move in either direction as they find the option that best fits their calling patterns. Staff recommends the Company provide specific notice to customers regarding the measured rate option and the availability of the ITSAP program. The Company should also work with the appropriate community action agencies to increase awareness of the ITSAP program among eligible households. Staff also recommends that the tariff include language that prohibits the use of both measured and flat rate service at a single location. In addition, the Company should provide customers a means to obtain call detail. If call detail will not be provided in the normal billing to customers choosing measured service, the procedures and any applicable charges for obtaining call details should be identified in the tariff. Respectfully submitted this day of November 1999. ___________________ Brad Purdy Deputy Attorney General Technical Staff: Wayne Hart Carol Cooper BP:WH:gdk:i/umisc/comments/cent993_cgst994.bpwh STAFF COMMENTS 15 NOVEMBER 5, 1999