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HomeMy WebLinkAbout02._Application 07, S.Rafferty Page 41 of 95 `,.CENTRAL SAN APPLICATION FOR POSITION AS BOARDMEMB. REPRESENTING DIVISION 3 , ads` 114,11 PLEASE TYPE OR PRINT IN INK. Completed applications must be submitted to the Secretary of the District at !� 5019 Imhoff Place, Martinez, CA 94553 or via email, kyoung@centralsan.org by 5.00 p.m. on Monday, March 27,2023.Applications submitted after the deadline will not be considered. Responses to all items are required for application to be considered complete. Applicant Name: Scott J. Rafferty Address: — Walnut Creek CA 94596 Phone Number: Email Address: 1. Are you a resident of Division 3*7 Yes T No *Verification can be obtained clicking the interactive map on the District website at https://www.centralsan.oWelections Or by calling the Secretary of the District at 925-229-7303. 2. Are you currently a registered voter? Yes No_ 3. Have you ever been convicted of a felony? Yes �, No 4. Attach resume and/or list your education, current employer and work experience: I graduated summa cum laude from Princeton with a degree in public affairs. I have a Ph.D. in social studies (regulatory economics)from Oxford,where I was a Rhodes Scholar. I have a J.D.from Yale Law School. I served as counsel to the House Telecom Subcomittee during the AT&T divestiture,worked for telecom and electric utilities while at McKinsey&Co.,and consulted to ten state agencies in connection with utility ratecases and other regulatory proceedings. I was research director for the Administrative Conference of the US during the Obtama Admnistration 1 March 30, 2023 Special Board Meeting Agenda Packet- Page 47 of 101 Page 42 of 95 ' CENTRAL SAN x.. r . 5. Describe any other relevant current or past experience that would qualify you for this position, including the dates of service and the length of time of the experience, specifically: a. Current or previous elected positions or experience with elected boards: see also attached letter and resume I have testified as staff witness before elected utility commissions, such as the Arizona Corporations Commission. I have worked with Dolores Huerta Foundation and other minority organizations to attain fair electoral divisions on school boards, cities, and special districts. I have volunteered to assist Central San and other special districts who have recieved CVRA demand letters from other attorneys. b. Volunteer services or community participation: see also attached letter and resume class leader, Rhodes Scholarship former member, National Convention Rules Committee, Platform Committee, Credentials Committee of major political party former board member, Meals on Wheels various political party positions former president, St. Sophia Greek Orthodox Church volunteer usher, Lesher Center c. Other roupeen�ber�� and affiliations: see also c eaa er and resume Princeton Club of Northern California (former president) Yale Club of San Francisco Knights of Columbus, St. John Vianney Oxford-Cambridge Boat Race Dinner Committee (former chair) McKinsey Alumni Association O'Melveny & Myers Alumni Association 2 March 30, 2023 Special Board Meeting Agenda Packet- Page 48 of 101 Page 43 of 95 CENTRAL SAN ��`_,r� `i`•,�.��;rZ.:�;575x-fa.'s� _ 6. Do you have a familial or financial relationship with an employee or Board Member at Central San? If Yes, please identify the nature of the relationship: no 7. Do you have any financial relationships with the District such as grants, contracts, or other economic relationships?If Yes, please identify the nature of the relationship: no 8. State your reason for interest in this position and explain why you would be the best candidate for this seat in 500 words or less. (You may use this form or attach a separate document for your response.) I would bring the expertise and perspective of an attorney to the board, especially since I specialize in administrative and public utility law. I also have extensive experience as an expert witness in utility ratecases and reorganization proceedings. At Princeton, Yale, and Oxford, I engaged in quantitative analyses focused on racial equity in housing, government programs, and voting rights. I was counsel to two national party reform commissions focused on implementing affirmative action. I have a longstanding commitment to the California environment and involvement in water policy, going back to advocacy for roadless designations in the Sierras and for flood control alternatives to the proposed Auburn Dam in the 199Os. My wife, two daughters and I have lived in Contra Costa County for 12 years. 3 March 30, 2023 Special Board Meeting Agenda Packet- Page 49 of 101 Page 44 of 95 �)yCENTRAL SAN 9. Any additional information you would like to provide for consideration. (You may use this form or attach a separate document for your response.) _see attached resume and letter Thank you for your interest in the Central San Signed: Aat Aof_ 3/26/23 4 March 30, 2023 Special Board Meeting Agenda Packet- Page 50 of 101 Page 45 of 95 SCOTT' J. IZAFFERT- �TTOR EY' AT r.a VV SAI. =CHF-=CA 94596 March 26, 2023 President Barbara Hockett and Members of the Board of Directors c/o Secretary Katie Young Central Contra Costa Sanitary District 5019 Imhoff Place Martinez CA 94553 Dear President Hockett and Board Members: I write to ask that the Board entrust me to represent all the residents of Division 3, including communities that have not traditionally influenced this District and other elected bodies,until the voters have an opportunity to elect a successor to the late David Williams at the next general election. As an alumnus of Central San Academy, I have a strong understanding of the role of the district and an appreciation of the issues that it faces. My background as an attorney, regulatory economist, and management consultant will add strength and diversity to the current board. The Board operates as a team, coordinating closely with the general manager and staff. I have already assisted the Board on a volunteer basis during its implementation of area elections. If appointed, I will work as full member of Central San's leadership team, bringing additional perspectives grounded in my professional training and career experiences. Much of my career as an attorney has involved public and administrative law, which will provide an important perspective to the Board especially if opportunities to work with other public entities emerge. During the Obama Administration, I served as research director for the Administrative Conference of the U.S., a federal agency tasked with developing best practices that improve the fairness and efficiency of government procedures. I also have experience in employment discrimination and whistleblower law, so I can be a resource to the district counsel in these areas. As the Board selects a successor to Mr. Alm, I would add perspectives to the Board's specification and review of candidate qualifications. I have worked with ten state governments as a regulatory economist, testifying in rate cases and other proceedings before utility commissions, usually on behalf of the March 30, 2023 Special Board Meeting Agenda Packet- Page 51 of 101 Page 46 of 95 Rafferty to Board of Directors, District 3 Vacancy,page 2 official advocate for consumer interests.' Although the ratemaking process conducted by sanitary districts differs in important respects, I am well qualified to assist the Board in evaluating the technical merits of cost-of-service studies. My experience could also help the Board enhance its evaluation of the impact of its decisions on the users of its services and their likely reactions. As a management consultant at McKinsey&Co., I focused on organizational effectiveness, including corporate structure and staff efficiency. The clients were very different, but some skills that I developed in this practice are relevant to Central San. Employee development is especially critical to public entities, which can be limited in their ability to implement either positive financial incentives or termination procedures. Mentoring employees and increasing job satisfaction are critical to retaining and improving high-quality management and increasing the efficiency of line operations. I can support and enhance Central San's efforts to invest in enhancing the quality and job satisfaction of its employees. I will not come to the Board with any agenda for immediate change. As an Academy alumnus, I understand the limits placed on the scope and scale of its operation, and its successes that it has achieved within its assigned domain. I know that the management is trying very hard to collaborate with related agencies. Reforms that we all know would be environmentally desirable are so prohibitively expensive and politically complex that any action affecting Central San appears impossible in the short term. Yet, we also know that the current regime of water rights and the system for distributing, managing, and recycling water in California is not sustainable in the long run. The district must always be prepared for change. Fundamental transformation may not be imminent, but when it does happen, the timing and pace of reform will likely be unanticipated. The diversity of education, skills, experience, and vision that I offer will be especially valuable to the Board in this environment of hidden uncertainty. The Board should work as a team to mentor advocates in communities whose needs have not historically been fully understood or addressed by elected officials. The Academy was a pioneering step toward that engagement. Our county's move to district elections can also provide minority and immigrant neighborhoods have greater influence. But these reforms will not fully succeed until these communities actually 11 was responsible for significant innovations in telecom ratemaking,including improved cost allocation methodology, appropriate amortization of post-employment benefits,and cost-of-capital adjustments to reflect the risk of diversified operations. I also served as Maryland's director of communications. March 30, 2023 Special Board Meeting Agenda Packet- Page 52 of 101 Page 47 of 95 Rafferty to Board of Directors, District 3 Vacancy,page 3 recruit and support a new generation of advocates. I have represented minority voters in this county. Elsewhere in the state, I have worked to create district elections in jurisdictions where elected officials had acutely neglected minority neighborhoods. If appointed, I will strengthen the Board's capacity to ensure that all communities of interest that Central San serves have a truly equal and informed opportunity to promote their own candidates of choice for the next election. I appreciate the Board's consideration and am pleased to provide additional information that you may require. Sincerely, A 4*4t A e9A Scott J. Rafferty cc: Application form and eligibility checklist Resume March 30, 2023 Special Board Meeting Agenda Packet- Page 53 of 101 Page 48 of 95 Scott J. Rafferty Walnut Creek CA 94596 PROFILE: *Extensive experience as a management consultant, attorney and regulatory economist *Pioneered use of disclosure, market-based incentives, and statistical surveillance to improve regulatory enforcement and increase government transparency •Proven leader and manager of interdisciplinary teams in the public and private sectors EDUCATION. Oxford University(Balliol College) Rhodes Scholar(1977);D.Phil. (1986) "Legislative Reform of the Telecommunications Industry: United States and Great Britain" Concentration: Regulatory economics Yale Law School J.D. (1979) Concentration: Civil rights,regulation and labor law Princeton University,Woodrow Wilson School A.B.(1976) Summa cum Laude, Phi Beta Kappa, Wilson School Thesis Prize Thesis: "Building the Consensus: The Civil Rights Division in the Kennedy Administration" 50 trimester-hours graduate credit to M.P.A. degree in Urban Economics PROFESSIONAL EXPERIENCE: Principal,Law Offices of Scott Rafferty Washington DC,Mountain View,Walnut Creek CA(2002— present,except 2010-12) Practice specializing in Voting Rights,Information Technology,Regulation,and Public Advocacy Accomplishments • As Executive Director of Neighborhood Elections Now, represented minority voters to promote the creation of electoral districts in jurisdictions where at-large voting diluted minority influence. o Prevailed in all 25 engagements,usually through pre-litigation collaboration. o Jurisdictions include Santa Clarita(largest city in America without districts), Ontario, Victorville,West Sacramento, and other cities in which minority neighborhoods had been unrepresented and neglected. o Obtained additional remedies to promote minority participation in school board governance,increasing the board size for San Juan USD and creating the first independent redistricting commission for a school district in the nation(West Contra Costa USD). • On behalf of Collaborative Approaches to Utility Safety Enforcement(CAUSE),successfully achieved implementation of international management system standards at PG&E o Advocated for safety-based undergrounding of distribution facilities(prior to North Bay fire) o Obtained modification of system of executive compensation that reflected safety metrics o Excluded$300,000 from rate recovery on the basis that PG&E had not adequately documented safety benefits of these claimed expenses o Obtained audit of undergrounding expenses • As Director of Litigation for Citizens for Responsibility and Ethics in Washington,refocused litigation strategy to extend federal recordkeeping and FOIA/Privacy Act requirements to electronic documents o Briefed successful litigation to preserve and disclose White House visitor records; o Developed techniques to scan large FOIA requests for key content, facilitating web publication; March 30, 2023 Special Board Meeting Agenda Packet- Page 54 of 101 Page 49 of 95 Rafferty resume,page 2 o Achieved declassification of Kennedy-era civil rights records at the National Archives and their release for digitization. • As Executive Director for Peninsula Ratepayers Association, represented utility consumers before the California Public Service Commission o Prevented Pacific Gas&Electric from using bankruptcy to preempt state regulation, avoiding substantial rate increases; o Built coalition with environmental groups to negotiate transfer of PG&E watershed lands from bankruptcy estate to nonprofit conservation entities; o Persuaded regulators to allow Voice Over Internet(VOID),advocating disclosure as the primary means to enforce service quality. • Enforced voting rights by working with state election officials and through litigation o Succeeded in challenging state legislation requiring soldiers to waive ballot secrecy if they participated in electronic ballot transmission program run by Dol)contractor; o Challenged Veterans Administration policies that interfered with voter registration at homeless shelters,nursing homes,and recreational areas where veterans live; o Directed voter protection in Montana 2006 election which ultimately resulted in change in control of U.S. Senate; o Strengthened California recall requirements through federal injunction action. Deputy Director for Research and Policy,Administrative Conference of the United States(federal agency), Washington DC (2010-2012) • Managed consultants and attorney-advisers who conduct work in connection with the Conference's research and policy projects. • Supported the Conference Committee on Administration and Management,keeping its chair and members informed on current research. • Organized project into E-FOIA and electronic publication of federal legal materials,including the use of copyrighted materials in rules and guidance • Digitized 1200 historic ACUS studies into best practices in administrative procedure at no cost to government. • Served as Designated Federal Officer at Conference Plenary Session and committee meetings, advising on compliance with Federal Advisory Committee Act • Performed research into collaborative regulatory enforcement,including self-regulatory organizations and privately funded inspections • Managed project into third-party certification • Organized conference on e-Rulemaking with Brookings,identifying innovations at state and federal agencies • Organized interagency workshops on online dispute resolution, case management,and immigration adjudication. • Recovered and organized 400,000 pages of archival materials Senior Director,Business Development,SiRF Technology,San Jose, CA (10/2000-2/2002) Built business and regulatory alliances for SiRF, which made leading-edge GPS chipsets for mobile telephones and consumer products Accomplishments • Successfully defended federal regulation mandating 911 location technologies in all new mobile phones; • Created competitive advantage with proactive corporate commitment to user security and privacy by preventing abuse of location data; • Built technology-sharing alliance with chipset customer; • Performed economic analysis of GPS deployment, showing effect of delay in E-911 mandate; March 30, 2023 Special Board Meeting Agenda Packet- Page 55 of 101 Page 50 of 95 Rafferty resume,page 3 • Developed cross-licensing framework to protect against potential patent and antitrust claims while negotiating access to critical software. Director,Aerie Group, Washington DC Accomplishments • Managed UN project to prepare state enterprises in Vietnam for privatization; • As economic consultant to twelve states,designed regulations to introduce telecom competition, and promote broadband penetration,privacy, security,universal service, and service quality; • Performed statistical analysis to show that the cable industry was not yet subject to effective competition,leading the incoming Clinton-Gore Administration to revise deregulatory rules; • Created nationwide database(by zip code and telephone exchange)of consumer economic and demand variables and penetration of broadband and wireless services to enable members of telephone company trade association to target broadband deployment and cross-selling initiatives; • Conducted or managed utility audits using quantitative statistical techniques to assess procurement practices and service quality; • Implemented franchise auction for provider-of-last-resort obligation in rural Hawaii; • Designed cost allocation accounting methodologies for utilities,which state commissions adopted and federal legislation incorporated; • Advised national political committee on internet strategy; • Testified before state legislatures and regulatory commissions in rulemaking and adjudicatory proceedings; • Built internal skills of state agencies to research and testify in regulatory hearings;managed teams of economists and lawyers in complex regulatory proceedings;taught continuing profes- sional education to regulatory CPAs Director of Telecommunications,Maryland Public Service Commission,Baltimore MD(9/1990-5/1992) As agency's first director,build and led staff to regulate telephone carriers Accomplishments: • Designed Maryland broadband plan, evaluating opportunities for telemedicine, distance education, and content delivery; • Managed statistical audit of affiliate transactions,using electronic discovery tools; • Served as state representative to federal-state joint board on accounting separations; • Enforced compliance with consumer safeguards,including privacy and service quality; • Launched self-regulation of payphones that improved enforcement and saved state costs. Principal,Rafferty Consulting, Washington DC (1987-90) Accomplishments • Achieved$965 million reduction in NY Tel rates,as well as"bubble up"compliance system and corporate restructuring to promote efficiency and ethical contracting; • Consultant on privatization to first industry minister in post-communist Poland; • Developed telecom job creation program for Irish Development Agency • Performed economic evaluation of pioneering Prodigy electronic service;proposed modifications to business plan; • Created security accounting tools to identify waste and fraud for telecommunications firms. NYNEX-TELCO Research, Washington DC(511986-111987) Managing Director and Senior Vice President Accomplishments March 30, 2023 Special Board Meeting Agenda Packet- Page 56 of 101 Page 51 of 95 Rafferty resume,page 4 • Managing director of 120-employee software development firm; ensured employees were appropriately appraised and rewarded; • Led team of 15 engineering and economic consultants who performed network planning and optimization and analyzed telecom markets for equipment and service suppliers; • Restored consulting practice to profitability in less than 6 months,at which point legal restrictions forced NYNEX to leave this line of business. Senior Associate,McKinsey& Company, Washington DC and London, UK (1983-86) Accomplishments • Created plan for Dutch government to open telecom market to competition; • Achieved$85 million in cost reductions while maintaining technical synergies and positive management culture for telecommunications client;restructured major regional electrical utility company to enhance business accountability; • Saved over 500 jobs and improved commercialization of research through Bell Labs re- organization; • Specialized in organizational change to support changing business strategies; • Led client teams to quantify post-merger staff needs; • Created separate subsidiary structure for electric utility to enter competitive telecommunications and power management businesses,providing regulatory transparency and business synergies; • Designed and implemented job development program for Republic of Ireland; • Helped create exploration and development strategy for major European energy firm; • Performed financial valuations of telecommunications companies. Counsel,House Subcommittee on Telecommunications,Energy and Commerce Committee Washington DC (1981-1983) Accomplishments • Represented committee members in U.S. v. AT&T,achieving 13 modifications to consent decree; • Developed and prepared policy for increasing competition in U.S.telecommunications markets; • Drafted AT&T divestiture bill and other laws relating to the telecommunications industry, including the Telecommunications for the Disabled Act; • Co-authored detailed statistical analysis of competition and market penetration for each telecom market("Technology in Transition"); • Organized numerous hearings into telecom competition,privacy,and data protection. Associate, O'Melveny and Myers,AC., Washington DC and Los Angeles CA (5/1979-81) • Specialized in antitrust and securities litigation, including all phases of discovery and trial, including depositions and motion practice. • Managed regulatory compliance in a major telecom merger; • Developed regulatory strategies for Fortune 100 corporations; • Handled all aspects of condemnation appeals before the General Accounting Office; • Successfully defended auto manufacturer in recall proceeding; • Represented airline industry in proceedings to reduce operations at National Airport. BAR ADMISSIONS Admitted to practice in California and District of Columbia; federal Northern District of California, and Second,Fifth,Ninth,Eleventh,D.C., and Federal Circuit Courts of Appeal. March 30, 2023 Special Board Meeting Agenda Packet- Page 57 of 101 Page 52 of 95 Rafferty resume,page 5 PROFESSIONAL ACTIVITIES President,Princeton Club of Northern California,2002-2005 Co-Chair, Oxford-Cambridge Committee of Northern California,2002-2005 Program Chair, Tshwane(South Africa)-Washington DC Sister City Committee Parish Council President, St. George Greek Orthodox Church,Bethesda MD, 1997-1999 UNITED STATES CITIZEN,SSN********** PUBLICATIONS AND REPORTS "Legislative Reform of the Telecommunications Industry in the United States and Great Britain,"Ph.D. dissertation,Oxford University 1986. The American Experience: The Dilemma of Telecommunications in the United States,"Libra Press (U.K.), 1983. Telecommunications in Transition:The Status of Competition in the Telecommunications Industry, Report by the Majority Staff of the Subcommittee on Telecommunications and Consumer Protection and Finance,U.S.House of Representatives Energy and Commerce Committee, Committee Print 97-V (GPO 86-058)November 1981. (I am the principal author of the introduction and pp. 55-2834 and co- author of pp. 29-54). "Realizing Congress's Promise of Effective Rate Regulation for Cable TV Consumers," September 28, 1983 (The Wall Street Journal commissioned this report,which resulted in a front page article and the substantial changes to FCC regulations) "Southern Republicanism,"Annals of the American Academy of Political and Social Sciences(1975) (citation pending)(a statistical analysis of the impact of the Voting Rights Act). "Proceedings of the Fifth Annual Homeland Security Law Institute,"35 Administrative&Regulatory Law News 29(2010). "Proceedings of the Fourth Annual Homeland Security Law Institute,"34 Administrative&Regulatory Law News 28 (2009). "Building the Consensus: Civil Rights and the Department of Justice 1961- 1963,"senior thesis, Woodrow Wilson School,Woodrow Wilson School Thesis Prize,Aaron Austin Godfrey Thesis Prize. "Analyzing New York Telephone Company's Request for Relief from the Rate Moratorium,"New York Public Service Commission No. 28961,January,l 1, 1990. "Transactions Between New York Telephone Company and Unregulated Affiliates of NYNEX Corporation,"New York State Department of Law,New York Public Service Commission No. 90-C- 0912, June 1990. "The Impact of Transactions with Unregulated Affiliates on the Regulated Rates of New York Telephone Company,"New York State Department of Law,New York Public Service Commission No. 90-C-0912,July 1990. (This report was the focus of a front-page story by the Wall Street Journal on July 12, 1990). March 30, 2023 Special Board Meeting Agenda Packet- Page 58 of 101 Page 53 of 95 Rafferty resume,page 6 "State Regulatory Jurisdiction over Voice-Over-Internet Telephony,"California Public Service Commission I-0402007,June 7, 2006. "Protecting Ratepayers During the Bankruptcy of PG&E,"California Public Service Commission I- 0204026,December 11,2003. "Opening Report for the Workshop on Competition in Telecommunications,"Arizona Corporations Commission,January 14, 1994. "Comments on Competition in Telecommunications,"Arizona Corporations Commission(Residential Utilities Consumer Office),July 21, 1994. "Incremental Cost and Telephone Calling Area Design,"Arizona Corporations Commission E-1051-93- 183 (Residential Utilities Consumer Office),May 26, 1994. "Rate Design for US West,"Arizona Corporations Commission E-1051-93-183 (Residential Utilities Consumer Office),March 14, 1994. "Reforming the Universal Service Fund,"Arizona Corporations Commission(Residential Utilities Consumer Office),October 26, 1994. "Making Retroactive Adjustments to Rates,"Arizona Corporations Commission E-1051-93-183 (Residential Utilities Consumer Office),October 26, 1994; additional comments filed July 3, 1996. "Designing Alternative Regulation in Telecommunications,"Public Advocate,Delaware Public Service Commission Case No. 33,May 26, 1992; further comments filed June 22, 1993. "Cost Methodology for Alternative Dialing Plans,Public Advocate,Delaware Public Service Commission Case No. 92-47,February 15, 1993. "Competition in Long-Distance Telephony,"Public Advocate,Delaware Public Service Commission Case No. 42,November 2, 1994. "Revenue Requirement and Reform in Rate Design to Reflect Competition, Public Advocate,Delaware Public Service Commission Case No. 92-47,January 15, 1993. "Reforming the Structure of Regulated Telecommunications Utilities,"Florida Public Service Commission No. 920255-TL,June 1, 1992. "Planning for the Entry of Competition,"Hawaii Department of Business,Economic Development& Tourism,Hawaii Public Service Commission No. 7702,March 24, 1995. "Using Auction Mechanisms to Reallocate Utility Franchises,"Hawaii Department of Business, Economic Development&Tourism,Hawaii Public Service Commission No. 7702,April 5, 1995. "Managing Competitive Entry,"Hawaii Department of Business,Economic Development&Tourism, Hawaii Public Service Commission No. 7702,May 12, 1995. "Maintaining the Quality of Rural Telephone Service,"Hawaii Department of Business,Economic Development&Tourism,Hawaii Public Service Commission No. 94-0346,June 28, 1994. March 30, 2023 Special Board Meeting Agenda Packet- Page 59 of 101 Page 54 of 95 Rafferty resume,page 7 "Regulating New Operator Service Providers,"Hawaii Department of Business, Economic Development & Tourism,Hawaii Public Service Commission No. 94-0144, June 5, 1995, further comments,January 16, 1996. "Calculating the Cost of Capital and Revenue Requirement for Hawaiian Telephone Company,"Hawaii Department of Business,Economic Development&Tourism,Hawaii Public Service Commission "Criteria for Awarding a Certificate of Public Convenience and Necessity,"Hawaii Department of Business,Economic Development&Tourism,Hawaii Public Service Commission No. 94-0093, November 14, 1994. "Regulatory Reform Proposals Before the Illinois Legislature,"Conference Committee of the Illinois Legislature,May 3, 1992. "Compensation for `Dial-Around Calls' from Payphones,"Maryland Public Service Commission, Case No. 8585,April 19, 1993. "Designing a Cost Allocation System for Regulated Telecommunications Utilities,"Maryland Public Service Commission,Case No. 8333,April 21, 1991. "Implementing a Cost Allocation System for Regulated Telecommunications Utilities,"Maryland Public Service Commission, Case No. 8333,May 10, 1991; further comments,May 17, 1991. "Toward a More Competitive Telecommunications Infrastructure for the State of Maryland,"Maryland Public Service Commission, Case No. 8388,November 7, 1991. "Setting Payphone Rates in a Competitive Environment,"Michigan Public Service Commission U- 10282,December 15, 1993. "Evaluating Price Caps as a Form of Alternative Regulation,"New Jersey Division of Ratepayer Advocate,New Jersey Board of Public Utilities No. T09030358, Sept.21, 1992. "Analyzing the Impact of Price Cap Regulation on Regulated Service-Quality,"New York Public Service Commission No. 92-C-0665,August 10, 1994. "Proposing Alternatives to Rate-of-Return Regulation for the Western Reserve Telephone Company," Ohio Consumers' Counsel,Public Utility Commission of Ohio No. 93-230-TP-ALT,November 8, 1993. "Proposing Alternatives to Rate-of-Return Regulation for the Cincinnati Bell Telephone Company," Ohio Consumers' Counsel,Public Utility Commission of Ohio No. 93-432-TP-ALT,March 3, 1994. "Evaluating the Reasonableness of a Rate Settlement Proposed for the Western Reserve Telephone Company,"Ohio Consumers' Counsel,Public Utility Commission of Ohio No.92-1525-TP-CSS, January 28, 1994. "Reforming the System of Cost Allocation and Jurisdictional Separations in the Face of Competitive Entry,"Ohio Consumers' Counsel,Public Utility Commission of Ohio No. 92-1525-TP-CSS,August 25, 1993. "Setting Rules for Competitive Entry,"Utah Department of Commerce,Utah Public Service Commission No. 94-2202-01,December 1, 1995. March 30, 2023 Special Board Meeting Agenda Packet- Page 60 of 101 Page 55 of 95 Rafferty resume,page 8 "Is Regulation of Rates and Quality of Service Appropriate for Residential ISDN,"Utah Department of Commerce,Utah Public Service Commission,July 15, 1996. "Developing a System of Cost Allocation for Regulated Utilities,"West Virginia Public Service Commission No. 90-424-T-PC, September 1992. "Implementing West Virginia's New Cost Allocation Methodology,"West Virginia Public Service Commission No. 90-424-T-PC,January 14, 1992. "Setting Rates for Payphones in a Competitive Environment,"Wisconsin Public Service Commission No. 2180-TR-103, October 6, 1992. I March 30, 2023 Special Board Meeting Agenda Packet- Page 61 of 101