Jeff -- here is a rough outline of the activities we will be doing in CA.  

ECI porposes to:

* provide managed virtual private line service using DWDM technology over our 
own proprietary network.  This is primarily an interstate service, but some 
segments may be marketed and sold between points in CA.

* acquire OC-48 capacity on other networks and "mux" them down into DS-3, 
OC-3 and OC-12 increments and then re-sold to other carriers and large 
enterprise users.  Some of this activity will be interstate and some 
intrastate but interLATA.  

* possibly buy,lease, or build local loop capacity to connect metro 
points-of-presence, probably in LA and San Jose.  These facilities would 
carry mostly interstate/international traffic, but add/drop within the city 
and LATA.

QUESTIONS:

- Do we need a CPUC Certificate for these activities?
- Is there more benefit to common carriage vs. private?
- Will ECI need to tariff services?

Thanks for your help and interest.