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l!Jlla.sllington, m<ir 20515 
Chairman Tom Wheeler 
Federal Communications Commission 
445 lih Street SW 
Washington, DC 20554 
September 25, 2015 
RE: Preliminary Determination of Rate-of-Return Study Areas 100 Percent Overlapped 
By Unsubsidized Competitors WC Docket No. 10-90 
Dear Chairman Wheeler: 
We note that four of the companies preliminarily determined to have 100 percent overlap 
by an unsubsidized competitor or combination of competitors in the proceeding noted above are 
located in Oregon. Without commenting on the merits of the docket itself, with this 
correspondence we make known our concerns with the methodology used to make the 
determination and strongly urge the Federal Communications Commission (FCC) Wireline 
Competition Bureau to re-consider the determination and methodology. 
Gervais Telephone Company, Mt Angel Telephone Company, St Paul Cooperative 
Telephone Association and Monitor Cooperative Telephone (referred to throughout as the 
Carriers) serve rural areas in Oregon. The FCC used data from Form 477 to detennine that 
McMinnville Access and WaveDivision (referred to throughout as the competitors) have 100 
percent or 99 percent coverage of the Carriers service areas and on that basis made the 
preliminary determination to eliminate all federal universal high-cost support from these areas. 
As we understand the situation, the Carriers have filed comments with the FCC 
effectively refuting the determination by the FCC. Without re-stating all the Carriers comments 
to the FCC we do point out one aspect of the comments we find compelling: one of the 
competitors McMinnville Access, has signed an affidavit explicitly stating they do not serve all 
the census blocks in the Carriers service territory and do not intend to make any attempt to do so. 
This points to the serious flaw in relying solely on the Form 477 data to determine that all federal 
universal high-cost support should be withheld from the Carriers service areas. 
In addition to the foregoing, we also understand that each of the Carriers did a physical 
review of the census blocks in their service areas and could find no evidence of either cable 
facilities or fixed wireless antenna that would substantiate a complete, 100 percent or 99 percent 
overlap of all locations in all census blocks within their service areas by a facilities based 
competitor. 
Withholding all federal universal high-cost support from rural Oregon would have 
serious negative impacts on the people living there. Access to modern telecommunications 
systems is essential to participating in today' s economy, education and healthcare systems and, 
interaction with government agencies. This action should not be taken lightly or be done based 
on flawed data collection methods. 
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In summary, based on the information in this correspondence, the rest of the information 
contained in the Carriers comments to the FCC and our understanding of the situation, we feel 
the methodology used to determine that 100 percent or 99 percent overlap in the Carriers service 
areas is flawed. 
With this correspondence we collectively request that the FCC remove Gervais 
Telephone Company, Mt Angel Telephone Company, St Paul Cooperative Telephone 
Association and Monitor Cooperative Telephone from the list set out in DA 15-868 as either 100 
percent or 99 percent overlapped. 
Thank you for your attention to this matter. 
Sincerely, 
~r RONWYDE 
U.S. Senator U.S. Senator Member of Congress