[1]Public Utility Commission Memorandum from Bob Reilley, Director of Operations Review to Jim Crouch, Executive Director, April 8, 1991.

[2]National Association of Regulatory Utility Commissioners, 1989 Annual Report on Utility Carrier Regulation, (Washington, D.C., September 1990), pp. 414-5.

[3]Ibid, pp. 629-30.

[4]Public Utility Commission Memorandum, April 8, 1991.