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
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' 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
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CENTRAL SAN
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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
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�)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
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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
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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.
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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
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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;
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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;
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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
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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.
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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).
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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.
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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.
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"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
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