Federal Communications Commission FCC 08-122 Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of High-Cost Universal Service Support Federal-State Joint Board on Universal Service Alltel Communications, Inc., et al. Petitions for Designation as Eligible Telecommunications Carriers RCC Minnesota, Inc. and RCC Atlantic, Inc. New Hampshire ETC Designation Amendment ) ) ) ) ) ) ) ) ) ) ) ) WC Docket No. 05-337 CC Docket No. 96-45 ORDER Adopted: April 29, 2008 Released: May 1, 2008 By the Commission: Chairman Martin and Commissioners Tate and McDowell issuing separate statements; Commissioners Copps and Adelstein dissenting and issuing separate statements. I. INTRODUCTION 1. In this Order, we take action to rein in the explosive growth in high-cost universal service support disbursements. As recommended by the Federal-State Joint Board on Universal Service (Joint Board), we adopt an interim, emergency cap on the amount of high-cost support that competitive eligible telecommunications carriers (ETCs) may receive.1 Specifically, as of the effective date of this Order, total annual competitive ETC support for each state will be capped at the level of support that competitive ETCs in that state were eligible to receive during March 2008 on an annualized basis. We also adopt two limited exceptions from the specific application of the interim cap. First, a competitive ETC will not be subject to the interim cap to the extent it files cost data demonstrating that its costs meet the support threshold in the same manner as the incumbent local exchange carrier (LEC). Second, we adopt a limited exception for competitive ETCs serving tribal lands or Alaska Native regions. The interim cap will remain in place only until the Commission adopts comprehensive high-cost universal service reform.2 The Commission plans to move forward on adopting comprehensive reform measures in an expeditious manner. The Commission commits to completing a final order on comprehensive reform as quickly as feasible after the comment cycle is completed on the pending Commission Notices regarding 1 See High-Cost Universal Service Support; Federal-State Joint Board on Universal Service, WC Docket No. 05- 337, CC Docket No. 96-45, Recommended Decision, 22 FCC Rcd 8998 (Fed.-State Jt. Bd. 2007) (Recommended Decision). 2 The Commission is required by statute to act within one year after receiving a recommendation from the Joint Board. 47 U.S.C. § 254(a)(2). Federal Communications Commission FCC 08-122 2 comprehensive reform.3 Finally, we resolve most of the petitions for ETC designation currently pending before the Commission.4 II. BACKGROUND 2. For the past several years, the Joint Board has been exploring recommending modifications to the Commission’s high-cost universal service support rules. In 2002, the Commission asked the Joint Board to review certain of the Commission’s rules related to the high-cost universal service support mechanisms.5 Among other things, the Commission asked the Joint Board to review the Commission’s rules relating to high-cost universal service support in study areas in which a competitive ETC provides service.6 In response, the Joint Board made a number of recommendations concerning the designation of ETCs in high-cost areas, but declined to recommend that the Commission modify the basis of support (i.e., the methodology used to calculate support) in study areas with multiple ETCs.7 Instead, the Joint Board recommended that it and the Commission continue to consider possible modifications to the basis of support for competitive ETCs as part of an overall review of the high-cost support mechanisms for rural and non-rural carriers.8 3. In 2004, the Commission asked the Joint Board to review the Commission’s rules relating to the high-cost universal service support mechanisms for rural carriers and to determine the appropriate rural mechanism to succeed the plan adopted in the Rural Task Force Order.9 In August 2004, the Joint Board sought comment on issues the Commission referred to it related to the high-cost universal service support mechanisms for rural carriers.10 The Joint Board also specifically sought comment on the methodology for calculating support for ETCs in competitive study areas.11 Since that time, the Joint Board has sought comment on a variety of specific proposals for addressing the issues of universal service support for rural carriers and the basis of support for competitive ETCs, including proposals developed by 3 See infra para. 4. 4 See infra para. 39, App. B. 5 See Federal-State Joint Board on Universal Service, CC Docket No. 96-45, Order, 17 FCC Rcd 22642 (2002). 6 Id. 7 See Federal-State Joint Board on Universal Service, CC Docket No. 96-45, Recommended Decision, 19 FCC Rcd 4257 (Fed.-State Jt. Bd. 2004) (2004 Recommended Decision). 8 Id. at 4294, para. 88. 9 See Federal-State Joint Board on Universal Service, CC Docket No. 96-45, Order, 19 FCC Rcd 11538, para. 1 (2004) (Rural Referral Order); Federal-State Joint Board on Universal Service; Multi-Association Group (MAG) Plan for Regulation of Interstate Services of Non-Price Cap Incumbent Local Exchange Carriers and Interexchange Carriers, Fourteenth Report and Order, Twenty-Second Order on Reconsideration, and Further Notice of Proposed Rulemaking in CC Docket No. 96-45, and Report and Order in CC Docket No. 00-256, 16 FCC Rcd 11244, 11268- 70 (2001) (Rural Task Force Order); see also Federal-State Joint Board on Universal Service; High-Cost Universal Service Support, CC Docket No. 96-45, WC Docket No. 05-337, Order, 21 FCC Rcd 5514 (2006) (extending the Rural Task Force Order plan). 10 See Federal-State Joint Board on Universal Service Seeks Comment on Certain of the Commission’s Rules Relating to High-Cost Universal Service Support, CC Docket No. 96-45, Public Notice, 19 FCC Rcd 16083 (Fed.- State Jt. Bd. 2004). 11 See id. at 16094, paras. 36-37. Federal Communications Commission FCC 08-122 3 members and staff of the Joint Board, as well as the use of reverse auctions (competitive bidding) to determine high-cost universal service funding to ETCs.12 4. On May 1, 2007, the Joint Board recommended that the Commission adopt an interim cap on high-cost universal service support for competitive ETCs while the Joint Board considered proposals for comprehensive reform.13 Specifically, the Joint Board recommended that the Commission cap competitive ETC support at the amount of support received by competitive ETCs in 2006.14 The Joint Board recommended that the cap on competitive ETC support be applied at the state level.15 Finally, the Joint Board recommended that the interim cap apply until one year from the date that the Joint Board makes its recommendation regarding high-cost universal service reform.16 On May 14, 2007, the Commission released a Notice of Proposed Rulemaking, seeking comment on the Joint Board’s recommendation.17 On November 19, 2007, the Joint Board submitted to the Commission recommendations for comprehensive reform of high-cost universal service support.18 On January 29, 2008, the Commission released three notices of proposed rulemaking addressing proposals for comprehensive reform of the high-cost universal service support program.19 Comments on the Reform Notices were due by April 17, 2008 and reply comments are due by May 19, 2008.20 12 See Federal State Joint Board on Universal Service Seeks Comment on Proposals to Modify the Commission’s Rules Relating to High-Cost Universal Service Support, CC Docket No. 96-45, Public Notice, 20 FCC Rcd 14267 (Fed.-State Jt. Bd. 2005); Federal-State Joint Board on Universal Service Seeks Comment on the Merits of Using Auctions to Determine High-Cost Universal Service Support, WC Docket No. 05-337, CC Docket No. 96-45, Public Notice, 21 FCC Rcd 9292 (Fed.-State Jt. Bd. 2006). In February 2007, the Joint Board held an en banc hearing to discuss high-cost universal service support in rural areas, including the use of reverse auctions and geographic information systems to determine support for ETCs. See Federal-State Joint Board on Universal Service to Hold En Banc Hearing on High-Cost Universal Service Support in Areas Served by Rural Carriers, WC Docket No. 05-337, Public Notice, 22 FCC Rcd 2545 (Wireline Comp. Bur. 2007). 13 See Recommended Decision, 22 FCC Rcd at 8999-9001, paras. 4-7. The Joint Board committed to making recommendations on comprehensive reform within six months (i.e., by November 1, 2007), and sought comment on comprehensive reform in a public notice released on the same day as the Recommended Decision. See id. at 8; Federal-State Joint Board on Universal Service Seeks Comment on Long Term Comprehensive High-Cost Universal Service Reform, WC Docket No. 05-337, CC Docket No. 96-45, Public Notice, 22 FCC Rcd 9023 (Fed.-State Jt. Bd. 2007) (Joint Board 2007 Public Notice). 14 Recommended Decision, 22 FCC Rcd at 9003, para. 13. 15 Id. at 9002-03, paras. 9-12. 16 Id. at 9002, para. 8. 17 High-Cost Universal Service Support; Federal-State Joint Board on Universal Service, WC Docket No. 05-337, CC Docket No. 96-45, Notice of Proposed Rulemaking, 22 FCC Rcd 9705 (2007) (Notice). 18 High-Cost Universal Service Support; Federal-State Joint Board on Universal Service, WC Docket No. 05-337, CC Docket No. 96-45, Recommended Decision, 22 FCC Rcd 20477 (2007) (Comprehensive Reform Recommended Decision). 19 High-Cost Universal Service Support; Federal-State Joint Board on Universal Service, WC Docket No. 05-337, CC Docket No. 96-45, Notice of Proposed Rulemaking, 23 FCC Rcd 1467 (2008) (Identical Support Rule NPRM); High-Cost Universal Service Support; Federal-State Joint Board on Universal Service, WC Docket No. 05-337, CC Docket No. 96-45, Notice of Proposed Rulemaking, 23 FCC Rcd 1495 (2008) (Reverse Auctions NPRM); High-Cost Universal Service Support; Federal-State Joint Board on Universal Service, WC Docket No. 05-337, CC Docket No. 96-45, Notice of Proposed Rulemaking, 23 FCC Rcd 1531 (2008) (Joint Board Comprehensive Reform NPRM) (collectively Reform Notices). 20 High-Cost Universal Service Support; Federal-State Joint Board on Universal Service, CC Docket No. 96-45; WC Docket No. 05-337, Order, DA 08-674 (rel. Mar. 24, 2008) (extending comment and reply comment dates). Federal Communications Commission FCC 08-122 4 III. DISCUSSION 5. We adopt, with limited modifications, the Joint Board’s recommendation for an emergency, interim cap on high-cost support for competitive ETCs.21 This action is necessary to halt the rapid growth of high-cost support that threatens the sustainability of the universal service fund. As described below, annual support for competitive ETCs in each state will be capped at the level of support that competitive ETCs in that state were eligible to receive during March 2008, on an annualized basis. As further discussed below, we also create a limited exception to the cap to allow competitive ETCs that serve tribal lands or Alaska Native regions to continue to receive support at uncapped levels.22 A. Need for a Cap on Competitive ETC Support 1. A Cap on Competitive ETC Support is Required to Preserve the Sustainability and Sufficiency of Universal Service 6. We agree with the Joint Board’s assessment that the rapid growth in high-cost support places the federal universal service fund in dire jeopardy. In 2007, the universal service fund provided approximately $4.3 billion per year in high-cost support.23 In contrast, in 2001, high-cost universal service support totaled approximately $2.6 billion.24 In recent years, this growth has been due to increased support provided to competitive ETCs, which receive high-cost support based on the per-line support that the incumbent LECs receive, rather than on the competitive ETCs’ own costs. While support to incumbent LECs has been flat since 2003,25 competitive ETC support, in the seven years from 2001 21 The interim cap adopted in this Order supersedes the interim caps on high-cost, competitive ETC support adopted in the ALLTEL-Atlantis Order and the AT&T-Dobson Order. See Applications of ALLTEL Corporation, Transferor, and Atlantis Holdings LLC, Transferee For Consent to Transfer Control of Licenses, Leases and Authorizations, WT Docket No. 07-185, Memorandum Opinion and Order, 22 FCC Rcd 19517 (2007) (ALLTEL-Atlantis Order); Applications of AT&T Inc. and Dobson Communications For Consent to Transfer Control of Licenses and Authorizations File Nos. 003092368 et al., WT Docket No. 07-153, Memorandum Opinion and Order, 22 FCC Rcd 20295 (2007) (AT&T-Dobson Order). 22 See Letter from Tina Pidgeon, Vice President, Federal Regulatory Affairs, General Communications Inc. (GCI), to Marlene H. Dortch, Secretary, Federal Communications Commission, WC Docket No. 05-337, CC Docket No. 96-45, at 2 (filed May 31, 2007) (GCI May 31 Ex Parte Letter). 23 Universal Service Administrative Company, 2007 Annual Report 43 (2007), available at http://www.usac.org/_res/documents/about/pdf/usac-annual-report-2007.pdf (USAC 2007 Annual Report). 24 See Universal Service Monitoring Report, CC Docket No. 98-202, Prepared by the Federal and State Staff for the Federal-State Joint Board on Universal Service in CC Docket No. 96-45, Table 3.2 (2007) (Universal Service Monitoring Report). 25 Incumbent LECs received $3.136 billion in high-cost support in 2003; $3.153 billion in 2004; $3.169 billion in 2005; $3.116 billion in 2006; and $3.108 billion in 2007. Universal Service Monitoring Report, Table 3.2 (for 2003, 2004, 2005, and 2006 data); USAC 2007 Annual Report at 41 (for 2007 data). In 2001, much of the growth in high- cost support was attributable to removing implicit subsidies from access charges and the inclusion of these amounts in explicit universal service mechanisms adopted in the CALLS Order and the MAG Plan Order. See Access Charge Reform, Price Cap Performance Review for Local Exchange Carriers; Low-Volume Long-Distance Users; Federal- State Joint Board on Universal Service, Sixth Report and Order in CC Docket Nos. 96-262 and 94-1, Report and Order in CC Docket No. 99-249, Eleventh Report and Order in CC Docket No. 96-45, 15 FCC Rcd 12962 (2000) (CALLS Order); Multi-Association Group (MAG) Plan for Regulation of Interstate Services of Non-Price Cap Incumbent Local Exchange Carriers and Interexchange Carriers; Federal-State Joint Board on Universal Service; Access Charge Reform for Incumbent Local Exchange Carriers Subject to Rate-of-Return Regulation; Prescribing the Authorized Rate of Return From Interstate Services of Local Exchange Carriers, Second Report and Order and Further Notice of Proposed Rulemaking in CC Docket No. 00-256, Fifteenth Report and Order in CC Docket No. (continued....) Federal Communications Commission FCC 08-122 5 through 2007, has grown from under $17 million to $1.18 billion – an average annual growth rate of over 100 percent.26 We find that the continued growth of the fund at this rate is not sustainable and would require excessive (and ever growing) contributions from consumers to pay for this fund growth. 27 7. We conclude that immediate action must be taken to stem the dramatic growth in high- cost support. Therefore, as recommended by the Joint Board, we immediately impose an interim cap on high-cost support provided to competitive ETCs until fundamental comprehensive reforms are adopted to address issues related to the distribution of support and to ensure that the universal service fund will be sustainable for future years. 28 The interim cap that we adopt herein limits the annual amount of high-cost support that competitive ETCs can receive in the interim period for each state to the amount competitive ETCs were eligible to receive in that state during March 2008, on an annualized basis. (...continued from previous page) 96-45, and Report and Order in CC Docket Nos. 98-77 and 98-166, 16 FCC Rcd 19613 (2001) (MAG Plan Order), recon. pending. 26 Universal Service Monitoring Report, Table 3.2; USAC 2007 Annual Report at 45. 27 Support for the fund derives from assessments paid by providers of interstate telecommunications services and certain other providers of interstate telecommunications. See 47 C.F.R. § 54.706. Fund contributors are permitted to, and almost always do, pass those contribution assessments though to their end-user customers. See 47 C.F.R. § 54.712. Fund assessments paid by contributors are determined by applying the quarterly contribution factor to the contributors’ contribution base revenues. In the second quarter of 2007, the contribution factor reached 11.7 percent, which is the highest level since its inception. See Proposed Second Quarter 2007 Universal Service Contribution Factor, CC Docket No. 96-45, Public Notice, 22 FCC Rcd 5074 (Off. of Man. Dir. 2007). The contribution factor has since declined slightly to 11.3 percent in the second quarter of 2008. Proposed Second Quarter 2008 Universal Service Contribution Factor, CC Docket No. 96-45, Public Notice, 23 FCC Rcd 4087 (Off. of Man. Dir. 2008). 28 The interim cap received widespread support from commenters. See ATA Comments; Alexicon Comments; AT&T Comments; CenturyTel Comments; Blackfoot Comments; Comcast Comments; Embarq Comments; Fred Williamson & Associates Comments; Frontier Comments; GVNW Comments; ITTA Comments; Iowa Telecommunications Ass’n Comments; Iowa Utilities Board Comments; Minnesota Independent Coalition Comments; Montana Telecommunications Ass’n Comments; NASUCA Comments; NECA Comments; NTCA Comments; Nebraska Rural Independent Cos and South Dakota Telecommunications Ass’n Comments; New Jersey Board of Public Utilities Comments; New York Department of Public Service Comments; OPASTCO Comments; Rural Iowa Independent Telephone Ass’n Comments; Rural Telecommunications Group Comments; Small Company Committee of the Louisiana Telecommunications Ass’n Comments; State Independent Telephone Ass’n of Kansas and Independent Telecommunications Group; TCA Comments; TDS Comments; Telephone Ass’n of Maine Comments; Tennessee Telecommunications Ass’n; Texas Statewide Telephone Cooperative, Inc. Comments; Totah Communications, Inc. et al. Comments; USTelecom Comments; Valley Telephone Cooperative Comments; Verizon and Verizon Wireless Comments; Western Telecommunications Alliance Comments; Windstream Comments; Wisconsin State Telecommunications Ass’n Comments. Other commenters, however, opposed the cap. See Alltel Comments; Centennial Comments; Chinook Wireless Comments; ComspanUSA Comments; COMPTEL Comments; CTIA Comments; DialToneServices Comments; Dobson Comments; GCI Comments; Kansas State Corporation Comm'n Comments; Rural Cellular Ass'n and Alliance of Rural CMRS Carriers Comments; South Carolina Office of Regulatory Staff Comments; SourthernLINC Comments; Sprint Nextel Comments; Surewest Comments; US Cellular and Rural Cellular Corp. Comments. In addition many individuals and public safety officials filed brief comments or ex parte letters, both in favor and in opposition to the interim cap. See, e.g., Letter from Senator J. Brian Bingman, Oklahoma State Senate, to Chairman Martin, Federal Communications Commission, WC Docket No. 05-337 (filed June 22, 2007) (urging the quick adoption of an interim cap); Letter from Lt. S.C. O’Dwyer, Commander of Communications, Office of the Sheriff of Effingham County, Georgia, to Kevin J. Martin, Chairman, Michael J. Copps, Commissioner, Jonathon S. Adelstein, Commissioner, Deborah Taylor Tate, Commissioner, and Robert M. McDowell, Commissioner, Federal Communications Commission, WC Docket No. 05-337 (filed July 11, 2007) (opposing the adoption of the interim cap). Appendix A contains a list of all commenters in this proceeding. Federal Communications Commission FCC 08-122 6 8. We find that adopting an interim cap is consistent with the requirement of section 254 of the Communications Act of 1934, as amended (the Act), that support be “sufficient” to meet the Act’s universal service purposes.29 The Commission previously has concluded that the statutory principle of “sufficiency” proscribes support in excess of that necessary to achieve the Act’s universal service goals.30 Notably, the Commission has previously adopted cost controls, including adopting an indexed cap on the high-cost loop support mechanism, which the U.S. Court of Appeals for the Fifth Circuit held to be consistent with the Act’s universal service mandate.31 9. Similarly, our action today applies interim cost controls to the aspect that most directly threatens the specificity, predictability, and sustainability of the fund: the rapid growth of competitive ETC support.32 A primary consequence of the existing competitive ETC support rules has been to promote the sale of multiple supported wireless handsets in given households.33 We do not today make a final determination regarding the level of support to competitive ETCs that is sufficient, but not excessive, for achieving the Act’s universal service goals because we expect to take further action to enact fundamental reform.34 Instead, today we take the reasonable, interim step of capping annual competitive ETC support for each state at the amount competitive ETCs in that state were eligible to receive during March 2008 on an annualized basis. Doing so will provide a necessary constraint on the growth of support until comprehensive reform is adopted. 10. We do not find it necessary to adopt additional caps on support provided to incumbent LECs at this time because, as the Joint Board noted in its Recommended Decision, high-cost support to incumbent LECs has been flat and is therefore exerting less pressure on the universal service fund.35 Moreover, incumbent LEC high-cost loop support is already capped, and incumbent LEC interstate access support is subject to a targeted limit.36 Incumbent LEC disbursements from other support mechanisms, 29 Telecommunications Act of 1996, Pub. L. No. 104-104, 110 Stat. 56 (1996) (the Act). The 1996 Act amended the Communications Act of 1934. 47 U.S.C. §§ 151, et seq. 47 U.S.C. § 254(b)(5) (“There should be specific, predictable and sufficient Federal and State mechanisms to preserve and advance universal service.”), (e) (“any such [universal service] support should be predictable and sufficient to achieve the purposes of this section”). 30 MAG Plan Order, 16 FCC Rcd at 19669-70, paras. 131-32; Rural Task Force Order, 16 FCC Rcd at 11257-58, para. 27; Federal-State Joint Board on Universal Service, CC Docket No. 96-45, Order on Remand, Further Notice of Proposed Rulemaking, and Memorandum Opinion and Order, 18 FCC Rcd 22559, 22581-82, paras. 36-37 (2003), remanded, Qwest Corp. v. FCC, 398 F.3d 1222 (10th Cir. 2005); 47 U.S.C. § 254(b). 31 Alenco Communications, Inc. v. FCC, 201 F.3d 608, 620-21 (5th Cir. 2000) (“[t]he agency’s broad discretion to provide sufficient universal service funding includes the decision to impose cost controls to avoid excessive expenditures that will detract from universal service”). 32 See 47 U.S.C. § 254(b)(5). 33 See Petition of Qwest Communications International Inc. for Forbearance from Enforcement of the Commission’s Dominant Carrier Rules As They Apply After Section 272 Sunsets, WC Docket No. 05-333, Memorandum Opinion and Order, 22 FCC Rcd 5207, 5218, para. 17 (2007) (stating that a majority of presubscribed interexchange customers also subscribe to mobile wireless service); Implementation of Section 6002(b) of the Omnibus Budget Reconciliation Act of 1993, Annual Report and Analysis of Competitive Market Conditions with Respect to Commercial Mobile Services, WT Docket No. 07-71, Twelfth Report, 23 FCC Rcd 2241, 2340-41, para. 246 (2008) (citing survey reporting that only approximately 11.8 percent of U.S. households relied exclusively on wireless phones in 2006) (2007 Commercial Mobile Services Report). 34 See Alenco, 201 F.3d at 619 (“excessive funding may itself violate the sufficiency requirements of the Act”). 35 Recommended Decision, 22 FCC Rcd at 9001, para. 5; see also supra para. 6. 36 See 47 C.F.R. §§ 36.603, 54.801(a). We are unconvinced by Alltel’s arguments that the existing caps on incumbent LEC support also effectively cap competitive ETC support. Alltel Comments at 10-11. Competitive ETC support has grown rapidly while, during the same period, incumbent LEC support has not grown significantly. (continued....) Federal Communications Commission FCC 08-122 7 like local switching support and interstate common line support, have been stable in recent years.37 Further, although high-cost model support has no actual cap, it does have built-in restraints on growth, which derive from the fact that support is based on stable statewide average estimated costs. Accordingly, we limit the interim cap we adopt today to high-cost support provided to competitive ETCs. 11. Some parties argue that inefficiencies in high-cost support for incumbent LECs are the root cause of the high-cost support growth, and that the Commission must address these inefficiencies to stabilize the fund.38 Although addressing inefficiencies in incumbent LEC support may be necessary for comprehensive reform, we disagree that such review of incumbent LEC support is necessary immediately to rein in the growth of high-cost support for an interim period. First, as we have noted, total incumbent LEC support has not grown in recent years and does not have the same potential for rapid explosive growth competitive ETC support does. Second, although increases in incumbent LEC high-cost support may contribute indirectly to growth in high-cost support for competitive ETCs, the interim cap on competitive ETC support we adopt today will eliminate that growth potential.39 To the extent that there may be inefficiencies in incumbent LEC high-cost support, we anticipate addressing those in the context of comprehensive universal service reform. 2. An Interim Cap on Competitive ETC Support Is Consistent With the Act 12. We disagree with arguments that capping support for competitive ETCs violates the Act. As a general matter, the Commission’s discretion to establish caps on high-cost support has been upheld.40 Moreover, as we discuss further below, we find no merit in the arguments raised by commenters in this proceeding that this particular cap violates the Act. 13. We disagree with comments that this cap violates the Act’s statutory principles. CTIA argues that the cap would violate the Act’s requirements that rates in rural areas should be reasonably comparable to those in urban areas.41 CTIA, however, fails to provide any data demonstrating that, or analysis explaining why the cap would result in rural rates that are not comparable with those in urban areas. Instead, it merely asserts that “[t]he proposed cap will deny customers access to reasonably (...continued from previous page) See supra para. 6. To the extent there are exceptions to the incumbent LEC caps (e.g., an index on high-cost loop support and the availability of the safety net additive), these exceptions are warranted due to the additional regulatory burdens faced by incumbent LECs. Competitive ETCs are able to raise their rates when necessary to recover their increased expenses, while many incumbent LECs are subject to rate regulation and cannot do so. Furthermore, we note that we are adopting a limited exception to the competitive ETC cap for carriers that serve tribal lands or Alaska Native regions. See infra paras. 31-34. 37 Local switching support for incumbent LECs ranged between $363 million and $379 million annually from 2003 through 2007. Interstate common line support (including its predecessor, Long Term Support) for incumbent LECs ranged between $877 million and $985 million annually from 2003 through 2007. See Universal Service Monitoring Report, Table 3.2 (2007 support based on actual and projected data). 38 See CTIA Comments at 5-6; Centennial Comments at 4-5. 39 Because competitive ETCs receive the same per-line support as the incumbent LEC, any increase in the incumbent LEC’s cost per loop, whether due to inefficiencies or line loss, could contribute to competitive ETC support growth rates. For example, if the underlying incumbent LEC per-line (but not total) support increases year over year (due to line loss, for example), the competitive ETC will receive both more per-line support and more total support, even in a service area where a competitive ETC’s lines remain constant year over year. 40 See Alenco, 201 F.3d at 620. 41 CTIA Comments at 21-22. Federal Communications Commission FCC 08-122 8 equivalent rates, and to reasonably equivalent services.”42 There simply is no support in the record for this contention. To the contrary, many wireless carriers that do not receive high-cost support compete against wireless competitive ETCs that do receive support, and many wireless competitive ETCs served high-cost territories before they were designated as eligible to receive support. 14. CTIA, along with Dobson, also contends that the cap violates the universal service principle of sufficiency.43 Neither commenter, however, provides any support for its contentions. To the contrary, as we explain above, we believe that the statutory principle of sufficiency is not inconsistent with the interim “cost controls” we adopt herein.44 We find that the interim cap we adopt is consistent with the principle of sufficiency as defined by the court in Alenco because it seeks to eliminate support in excess of that necessary to ensure the Act’s universal service goals.45 Further, because competitive ETC support is based on the incumbent LEC’s costs, rather than on the competitive ETC’s own costs, there is no reason to believe – and no record data showing – that support subject to an interim cap would necessarily result in insufficient support levels.46 Dobson also argues that the cap will violate the universal service principle of predictability because the effects of the cap “will be driven by factors that are not at all ‘predictable’.”47 Adoption of the interim cap, however, makes competitive ETC support more predictable, in that it sets an upper, definitive bound on the amount of support available in a state. Moreover, Dobson ignores the fact that, as the court concluded in Alenco, the Act’s requirement of predictability requires only that the rules governing distribution, not the resulting funding amounts, must be predictable.48 15. We are not persuaded by CTIA’s argument, citing Alenco, that the Act requires the promotion of competition in high-cost areas through the provision of equal per-line support amounts to all carriers.49 Rather than requiring the use of universal service support to subsidize competition, the court in Alenco was concerned with the sustainability of universal service in a competitive environment. Specifically, the court found that “[t]he Commission therefore is responsible for making the changes necessary to its universal service program to ensure that it survives in the new world of competition.”50 The court stated that the Commission “must see to it that both universal service and competition are 42 Id. 43 CTIA Comments at 22, Dobson Comments at 4-5. 44 See supra para. 8 (discussing the Alenco court’s conclusion that the Commission may adopt universal service cost controls). 45 See Alenco, 201 F.3d at 619. 46 See id. at 620 (“The Act only promises universal service, and that is a goal that requires sufficient funding of customers, not providers.”). 47 Dobson Comments at 5. 48 Alenco, 201 F.3d at 623. Further, we note that Dobson’s criticism is equally applicable to the cap on high-cost loop support, which was affirmed by the court in Alenco. Id. at 620. 49 CTIA Comments at 19. 50 Alenco, 201 F.3d at 615 (citing Federal-State Joint Board on Universal Service, CC Docket No. 96-45, Report and Order, 12 FCC Rcd 8776, 8780-82, paras. 1-4, 8788, para. 20 (1997) (Universal Service First Report and Order) (stating that the Commission, through its work with the Joint Board, “ensure[s] that this system is sustainable in a competitive marketplace, thus ensuring that universal service is available at rates that are ‘just, unreasonable [sic], and affordable’ for all Americans”)). Federal Communications Commission FCC 08-122 9 realized; one cannot be sacrificed in favor of the other.”51 We therefore find that our action today is not only consistent with, but is supported by, the court’s holding in Alenco. 16. Similarly, we are not persuaded by Alltel’s argument that competitive ETCs and incumbent LECs must receive the same amount of support on a per-line basis.52 Although Alltel correctly notes that, in upholding the cap on high-cost loop support, the court in Alenco “rejected the premise that [incumbent LEC] revenue flows must be protected at all costs, and thus that any reductions in disbursements needed to prevent undue fund growth must be borne by [competitive ETCs] rather than [incumbent LECs],”53 Alltel fails to explain why the court’s holding requires equal per-line support for all competitors. Put simply, while the court rejected the idea that any reductions in disbursements necessary to curtail fund growth had to be borne by competitive ETCs and not incumbent LECs, the court did not prohibit the Commission from imposing reductions or limits on competitive ETC disbursements.54 17. CTIA argues that adoption of the interim cap would not comport with the court’s statement in Alenco that “the program must treat all market participants equally . . . so that the market, and not local or federal government regulators, determines who shall compete for and deliver service to customers.”55 The cited language, however, does not require the Commission to continue to provide identical levels of support to all carriers. It merely requires that all ETCs must be eligible to receive support, an unremarkable conclusion given the plain text of the statute.56 18. Alltel and CTIA both ignore key aspects of Alenco, in which the court expressly found that the Commission must ensure that all customers be able to receive affordable basic telecommunications services. Competition necessarily brings the risk that some telephone service providers will be unable to compete. The Act only promises universal service, and that is a goal that requires sufficient funding of customers, not providers. So long as there is sufficient and competitively-neutral funding to enable all customers to receive basic telecommunications services, the FCC has satisfied the Act and is not further required to ensure sufficient funding of every local telephone provider as well. Moreover, excessive funding may itself violate the sufficiency requirements of the Act.57 Nowhere in the court’s decision did it require that all providers must receive equal per-line support amounts. 51 See Alenco, 201 F.3d at 615. 52 Alltel Comments at 15-18. 53 Id. at 15. 54 Alltel also relies the court’s decision in TOPUC to support its argument that high-cost support must be portable on a per-line basis. Id. at 15-16 (citing Texas Office of Public Utility Counsel v. FCC, 183 F.3d 393, 417-18 (5th Cir. 1999) (TOPUC)). Alltel, however, only cites TOPUC’s requirement that implicit subsidies be replaced with explicit universal service subsidies. Id. That requirement, however, does not require that universal service support continue on a per-line basis under the identical support rule. 55 CTIA Comments at 20 (quoting Alenco, 201 F.3d at 616). 56 The quotation that CTIA relies on specifically cites section 214(e)(1) of the Act, which requires that all “eligible telecommunications carriers . . . shall be eligible to receive universal service support.” 47 U.S.C. § 214(e)(1). See also infra para. 29. 57 Alenco, 201 F.3d at 620. Federal Communications Commission FCC 08-122 10 19. In arguing that the interim cap would not comport with the identical support rule because it would disburse unequal support per line, Alltel also cites various Commission precedents related to the establishment and implementation of the identical support rule, which, at the time, the Commission found to be consistent with its principle of competitive neutrality.58 In justifying this portability requirement, both the Joint Board and Commission made clear that they envisioned that competitive ETCs would compete directly against incumbent LECs and try to take existing customers from them. 59 The predictions of the Joint Board and the Commission have proven inaccurate, however. 20. First, they did not foresee that competitive ETCs might offer supported services that were not viewed by consumers as substitutes for the incumbent LEC’s supported service.60 Second, wireless carriers, rather than wireline competitive LECs, have received a majority of competitive ETC designations, serve a majority of competitive ETC lines, and have received a majority of competitive ETC support.61 These wireless competitive ETCs do not capture lines from the incumbent LEC to become a customer’s sole service provider, except in a small portion of households.62 Thus, rather than providing a complete substitute for traditional wireline service, these wireless competitive ETCs largely provide mobile wireless telephony service in addition to a customer’s existing wireline service.63 58 Alltel Comments at 16-17 (citing Federal-State Joint Board on Universal Service, Ninth Report and Order, 14 FCC Rcd 20432, 20480, para. 90 (1999)). 59 See Universal Service First Report and Order, 12 FCC Rcd at 8932, para. 287, 8944, para. 311; Federal-State Joint Board on Universal Service, Recommended Decision, 12 FCC Rcd 87, 238, para. 296 (Fed-State Jt. Bd. 1996). 60 SouthernLINC argues that “consumers in rural, insular and high-cost areas should also have access to competitive wireless services at reasonable rates in order to complement their wireline service.” SouthernLINC Comments at 7- 11. Essentially, SouthernLINC is arguing that mobility should be added to the list of supported services. We find that issue beyond the scope of the current proceeding. 61 See Letter from Jeffrey A. Eisenach, Chairman, Criterion Economics, LLC, to Marlene H. Dortch, Secretary, Federal Communications Commission, CC Docket No. 96-45, WC Docket No. 05-337, Attach. The Effects of Providing Universal Service Subsidies to Wireless Carriers at 16-18, App. B (filed June 13, 2007) (Criterion Report) (claiming that, in 2006, 68 percent – 192 out of 281 – of all competitive ETC service areas were wireless service areas, and that 94 percent – $770.5 million out of $820.5 million – of all competitive ETC support went to wireless competitive ETCs). 62 See 2007 Commercial Mobile Services Report, 23 FCC Rcd at 2340-41, para. 246 (citing survey reporting that only approximately 11.8 percent of U.S. households relied exclusively on wireless phones in 2006). Even the data on which CTIA relies show that less than 13 percent of households have replaced wireline with wireless service. CTIA Comments at 10. 63 CTIA’s reliance on a survey showing that less than 13 percent of households have replaced wireline with wireless service fails to demonstrate that wireless ETCs are a complete substitute for wireline ETCs. See CTIA Comments at 10. Nor does CTIA’s second cited survey – in which respondents were asked to identify the single service, wireline or wireless, that they would retain if they could only retain one (a fictitious assumption) – demonstrate complete substitutability. See id. at 10-11. In 2004, the Joint Board tried to address these developments by recommending that support be limited to “a single connection to the public telephone network.” 2004 Recommended Decision, 19 FCC Rcd at 4282, para. 62. Congress, however, has prohibited the Commission from implementing this recommendation. On December 8, 2004, Congress passed the 2005 Consolidated Appropriations Act, which prohibits the Commission from utilizing appropriated funds to “modify, amend, or change its rules or regulations for Universal Service support payments to implement the February 27, 2004 recommendations of the Federal-State Joint Board on Universal Service regarding single connection or primary line restrictions on universal service payments.” Consolidated Appropriations Act, 2005, Pub. L. No. 108-447, § 634, 118 Stat. 2809 (2004) (2005 Consolidated Appropriations Act); Science, State, Justice, Commerce and Related Agencies Appropriations Act 2006, Pub. L. No. 109-108, § 622, 119 Stat. 2342 (2005) (extending prohibition until September 30, 2006); Revised Continuing Appropriations Resolution 2007, Pub. (continued....) Federal Communications Commission FCC 08-122 11 21. This has created a number of serious problems for the high-cost fund, and calls into question the rationale for the identical support rule. Instead of competitive ETCs competing against the incumbent LECs for a relatively fixed number of subscriber lines, the certification of wireless competitive ETCs has led to significant increases in the total number of supported lines.64 Because the majority of households do not view wireline and wireless services to be direct substitutes,65 many households subscribe to both services and receive support for multiple lines, which has led to a rapid increase in the size of the fund.66 In addition, the identical support rule fails to create efficient investment incentives for competitive ETCs. Because a competitive ETC’s per-line support is based solely on the per-line support received by the incumbent LEC, rather than its own network investments in an area, the competitive ETC has little incentive to invest in, or expand, its own facilities in areas with low population densities, thereby contravening the Act’s universal service goal of improving the access to telecommunications services in rural, insular and high-cost areas.67 Instead, competitive ETCs have a greater incentive to expand the number of subscribers, particularly those located in the lower-cost parts of high-cost areas, rather than to expand the geographic scope of their network. The Commission is currently considering eliminating the identical support rule.68 22. We also find that the Commission’s universal service principle of competitive neutrality does not preclude us from adopting an interim, limited cap under existing circumstances.69 As discussed above, high-cost support has increased by $1.7 billion – more than 65 percent – from 2001 to 2007.70 Continued growth at this rate would render the amount of high-cost support unsustainable and could (...continued from previous page) L. No. 110-5, § 105, 121 Stat. 9 (2007) (extending prohibition until September 30, 2007); Consolidated Appropriations Act, 2008, Pub. L. No. 110-161, § 511, 121 Stat. 1998 (2007) (extending prohibition until September 30, 2008). 64 Between November 1, 2002, and February 1, 2008, the total number of lines served by all ETCs receiving interstate common line support or interstate access support, including competitive ETCs and incumbent LECs, increased by approximately 35.7 million. Competitive ETC line counts, which grew by approximately 31.7 million during that period, drove the increase. See Universal Service Administrative Company, Federal Universal Service Support Mechanisms Fund Size Projections for the Second Quarter 2008, App. HC09, HC12 (filed Feb. 1, 2008); Universal Service Administrative Company, Federal Universal Service Support Mechanisms Fund Size Projections for the First Quarter 2003, App. HC08, HC14 (filed Nov. 1, 2002). 65 See Petition of Qwest Communications International Inc. for Forbearance from Enforcement of the Commission’s Dominant Carrier Rules As They Apply After Section 272 Sunsets, WC Docket No. 05-333, Memorandum Opinion and Order, 22 FCC Rcd 5207, 5218, para. 17 (2007) (stating that a majority of presubscribed interexchange customers also subscribe to mobile wireless service); 2007 Commercial Mobile Services Report, 23 FCC Rcd at 2340-41, para. 246 (citing survey reporting that approximately 11.8 percent of U.S. households relied exclusively on wireless phones in 2006). 66 See Congressional Budget Office, Factors that May Increase Future Spending from the Universal Service Fund at 12 (2006) (“The fact that wireless entrants are providing additional telephone service rather than replacement service in many cases is part of the reason that total spending for support grows when wireless carriers enter a market covered by the USF.”). 67 See 47 U.S.C. § 254(b)(3). 68 Identical Support Rule NPRM, 23 FCC Rcd 1467. 69 Universal Service First Report and Order, 12 FCC Rcd at 8801-03, paras. 46-52 (subsequent history omitted) (“[W]e define this principle, in the context of determining universal service support, as: COMPETITIVE NEUTRALITY – Universal service support mechanisms and rules should be competitively neutral. In this context, competitive neutrality means that universal service support mechanisms and rules neither unfairly advantage nor disadvantage one provider over another, and neither unfairly favor nor disfavor one technology over another.”). 70 See supra para. 6. Federal Communications Commission FCC 08-122 12 cripple the universal service fund. To avert this crisis, it is necessary to place some temporary restraints on the fastest-growing portion of high-cost support, i.e., competitive ETC support. Moreover, as discussed above, it is not clear that identical support has, in reality, resulted in competitive neutrality. We therefore find that, rather than departing from the principle of competitive neutrality, as a matter of policy, we instead are temporarily prioritizing the immediate need to stabilize high-cost universal service support and ensure a specific, predictable, and sufficient fund.71 23. Finally, we reject arguments that the cap should not be adopted because it will not be truly interim in nature.72 The interim cap will remain in place only until the Commission adopts comprehensive, high-cost universal service reform.73 Thus, we are satisfied that the interim cap’s life will be of limited duration. 3. Cap on Competitive ETC Support Would Not Inhibit Broadband Deployment in Rural America 24. Several commenters argue that the interim cap on competitive ETC support will inhibit the deployment of broadband services.74 With the exception of GCI, these commenters provide only anecdotal evidence of the possible effect of the interim cap on particular deployments, and do not systematically analyze the effect of the interim cap on broadband deployment.75 Moreover, although high-cost support for rural incumbent LECs has been capped for many years, that does not appear to have inhibited the deployment of broadband service to areas served by rural incumbent LECs.76 Indeed, high- cost universal service support may be used to invest in facilities to provide broadband service if those facilities are also necessary to provide voice grade access.77 25. In light of the foregoing, we decline to adopt specific requirements for competitive ETCs regarding the provision of broadband Internet access services. Rather, we find that the role of high-cost support mechanisms in promoting broadband deployment is better addressed in a rulemaking of general applicability. In fact, the Commission currently is considering proposals to provide high-cost support for broadband service.78 71 See 47 U.S.C. § 254(b)(5), (d). Moreover, as we explain below, the statute does not mandate that ETCs receive support, but rather that ETCs be eligible to receive support. See infra para. 29. 72 Alltel Comments at 7-9; CTIA Comments at 23. 73 The Commission is required by statute to act within a year after receiving a recommendation by the Joint Board. 47 U.S.C. § 254(a)(2); see also Recommended Decision, 22 FCC Rcd at 8998, para. 1; Joint Board 2007 Public Notice, 22 FCC Rcd at 9023, para. 1. 74 See, e.g., CTIA Comments at 6-9; ComspanUSA Comments at 9-11; MidRivers Comments at 7; SouthernLINC Comments at 16-17. 75 See GCI May 31 Ex Parte Letter at 2. 76 See NTCA 2007 Broadband/Internet Availability Survey Report, National Telecommunications Cooperative Association, 3 (Sept. 2007) (survey of NTCA member companies that serve primarily rural areas showed that 99 percent of 2007 respondents offer broadband to some parts of their customer base, compared with only 58 percent of respondents in 2000). 77 See Rural Task Force Order, 16 FCC Rcd at 11321-23, paras. 199-201. 78 See supra note 19. Federal Communications Commission FCC 08-122 13 B. Design and Implementation of the Cap 1. Operation of the Cap 26. We adopt a cap on competitive ETC support for each state, as recommended by the Joint Board, subject to two limited exceptions described below.79 A competitive ETC cap applied at a state level will effectively curb growth, but, given a state’s role in designating ETCs, will allow a state the flexibility to direct competitive ETC support to the areas in the state that it determines are most in need of such support.80 An interim, state-based cap on competitive ETC support also will avoid creating an incentive for each state to designate as many new ETCs as possible for the sole purpose of increasing support to that state at the expense of other states, which could occur had we adopted a single, nationwide cap. A state-based cap will require newly-designated competitive ETCs to share funding with other competitive ETCs within the state. 27. Under the state-based cap, support will be calculated using a two-step approach. First, on a quarterly basis, the Universal Service Administrative Company (USAC) will calculate the support each competitive ETC would have received under the existing (uncapped) per-line identical support rule,81 and sum these amounts by state. Second, USAC will calculate a state reduction factor to reduce this amount to the competitive ETC cap amount. Specifically, USAC will compare the total amount of uncapped support to the cap amount for each state. Where the total state uncapped support is greater than the available state cap support amount, USAC will divide the state cap support amount by the total state uncapped amount to yield the state reduction factor. USAC will then apply the state-specific reduction factor to the uncapped amount for each competitive ETC within the state to arrive at the capped level of high-cost support. Where the state uncapped support is less than the available state capped support amount, no reduction will be required. 28. For example, if, in State A, the capped amount is $90 million, and the total uncapped support is $130 million, the reduction factor would be 69.2 percent ($90/$130). In State A, each competitive ETC’s uncapped support would be multiplied by 69.2 percent to reduce support to the capped amount. If, in State B, however, the capped amount is $100 million, and the total uncapped support is $95 million, there would be no reduction factor because the uncapped amount is less than the capped amount. Finally, if, in State C the base period capped amount is $0 (i.e., there were no competitive ETCs eligible to receive support in State C in March 2008), then no competitive ETCs would be eligible to receive support in that state during the interim cap. Each quarter, for the duration of the cap, a new reduction factor would be calculated for each state. 79 See infra paras. 31-34. 80 In addition to capping competitive ETC support by state, the Joint Board considered, but declined to recommend, capping competitive ETC support nationwide or by study area. The Joint Board felt that a nationwide cap would provide an incentive for states to designate additional competitive ETCs to increase their share of competitive ETC capped support and would result in competitive ETC support shifting to those states that aggressively designate competitive ETCs during the period of the interim cap. The Joint Board found that capping support at the study area level would foreclose the possibility of support for the duration of the cap for those study areas that currently have no competitive ETCs and would be administratively burdensome. The Joint Board noted that establishing the cap by any particular geographic area would not change the total amount of competitive ETC support available for all competitive ETCs in the nation, but the scope of the geographic territory for the cap affects the distribution of capped support and the administrative complexity of computing capped support. See Recommended Decision, 22 FCC Rcd at 9002, para. 9 n. 24. We agree with this analysis by the Joint Board. 81 See 47 C.F.R. § 54.307. Federal Communications Commission FCC 08-122 14 29. Some commenters argue that, in states where there currently are no competitive ETCs designated, subsequently designated competitive ETCs will receive no high-cost support while the interim cap remains in place.82 The Act does not, however, require that all ETCs must receive support, but rather only that carriers meeting certain requirements be eligible for support.83 Section 214(e)(1) of the Act states, “A common carrier designated as an eligible telecommunications carrier . . . shall be eligible to receive universal service support in accordance with section 254[.]”84 Likewise, section 254(e) of the Act states, “[O]nly an eligible telecommunications carrier designated under section 214(e) shall be eligible to receive specific Federal universal service support.”85 This language indicates that designation as an ETC does not automatically entitle a carrier to receive universal service support.86 Moreover, in section 254 of the Act, Congress distinguished between those who are merely “eligible” to receive support and those who are “entitled” to receive benefits.87 We find that Congress’s careful delineation demonstrates an intention to ascribe different statutory rights. Accordingly, even if imposition of the interim cap results in no support for some competitive ETCs, this result is not inconsistent with the Act.88 30. Moreover, there are advantages to obtaining and maintaining an ETC designation regardless of whether a competitive ETC receives high-cost support. In particular, the ability of competitive ETCs to receive low-income universal service support shows value in obtaining and maintaining ETC designation separate and apart from high-cost support. Indeed, TracFone Wireless, Inc. (TracFone) sought forbearance from section 214(e)(1) of the Act so that it could seek designation as an ETC eligible only to receive universal service Lifeline support.89 TracFone took this step because “offering prepaid plans which make wireless service available to low income users . . . has been a critical component of TracFone’s business strategy since the company’s inception.”90 Other ETCs may have 82 See, e.g., Alltel Comments at 17-18; Rural Cellular Ass’n Comments at 27; SC Off. of Reg. Staff Comments at 2. 83 47 U.S.C. §§ 214(e)(1); 254(e) (emphasis added). 84 47 U.S.C. § 214(e)(1) (emphasis added). 85 47 U.S.C. § 254(e) (emphasis added). 86 See Universal Service First Report and Order, 12 FCC Rcd at 8853, para. 137 (“Indeed, the language of section 254(e), which states that ‘only an eligible telecommunications carrier designated under section 214(e) shall be eligible to receive’ universal service support, suggests that a carrier is not automatically entitled to receive universal service support once designated as eligible.”); Alenco, 201 F.3d at 620 (“The Act only promises universal service, and that is a goal that requires sufficient funding of customers, not providers.”). 87 Compare 47 U.S.C. § 254(e) with 47 U.S.C. § 254(h)(1)(A) (providing that carriers offering certain services to rural health care providers “shall be entitled” to have the difference between the rates charged to health care providers and those charged to other customers in comparable rural areas treated as an offset to any universal service contribution obligation); see also Transbrasil S.A. Linhas Aereas v. Dep’t of Transp., 791 F.2d 202, 205 (D.C. Cir. 1986) (“[W]here different terms are used in a single piece of legislation, the Court must presume that Congress intended the terms have different meanings.”). 88 Some of the Commission’s current rules, including sections 54.307(a) and 54.309(a), provide that ETCs “shall receive” universal service support if certain conditions are met. See, e.g., 47 C.F.R. § 54.307(a), 54.309(a). But see 47 C.F.R. § 54.201(d) (“A common carrier designated as an eligible telecommunications carrier . . . shall be eligible to receive universal service support in accordance with section 254[.]”) (emphasis added). These rules, which were never intended to mandate support to all ETCs, unduly narrow the Commission’s discretion under the statute, which states merely that ETCs “shall be eligible” to receive such support. 47 U.S.C. § 214(e)(1). 89 See TracFone Wireless, Inc. Petition for Forbearance, CC Docket No. 96-45 (filed June 8, 2004). Forbearance was granted in 2005. Petition of TracFone Wireless, Inc. for Forbearance from 47 U.S.C. § 214(e)(1)(A) and 47 C.F.R. § 54.201(i), CC Docket No. 96-45, Order, 20 FCC Rcd 15095 (2005) 90 TracFone Wireless, Inc. Petition for Designation as an Eligible Telecommunications Carrier in the State of Tennessee, CC Docket No. 96-45, 3 (filed Nov. 9, 2004) (Tennessee Petition). This petition was granted in an order (continued....) Federal Communications Commission FCC 08-122 15 similar business strategies. Further, by offering Lifeline and Link Up service, a competitive ETC may attract new subscribers that may not otherwise have taken telephone service.91 This would increase a competitive ETC’s base of subscribers and, consequently, lower its average cost of serving all of its subscribers. Moreover, competitive ETCs may be eligible for separate universal service support at the state level.92 31. We adopt two limited exceptions to the operation of the interim cap.93 First, consistent with the ALLTEL-Atlantis Order and the AT&T-Dobson Order, we find it in the public interest to adopt a limited exception to the interim cap if a competitive ETC submits its own costs.94 Specifically, a competitive ETC will not be subject to the interim cap to the extent that it files cost data demonstrating that its costs meet the support threshold in the same manner as the incumbent LEC. 32. Second, we also adopt a limited exception to the interim cap for competitive ETCs that serve tribal lands or Alaska Native regions (the Covered Locations).95 We permit competitive ETCs serving Covered Locations to continue to receive uncapped high-cost support for lines served in those Covered Locations. Because many tribal lands have low penetration rates for basic telephone service, we do not believe that competitive ETCs are merely providing complementary services in most tribal lands, as they do generally.96 33. Participation in this limited exception to the interim cap is voluntary and will be elected by the competitive ETC on a study area by study area basis. Therefore, any competitive ETC that does not or cannot opt into the limited exception, or that does not or cannot opt into the limited exception for a particular Covered Location, will remain subject to the interim cap as described herein. Support for competitive ETCs that do opt into the limited exception will continue to be provided pursuant to section (...continued from previous page) released on April 11, 2008. Federal-State Joint Board on Universal Service, TracFone Wireless, Inc. Petition for Designation as an Eligible Telecommunications Carrier in the State of New York et al., CC Docket No. 96-45, Order, FCC 08-100 (rel. April 11, 2008) (granting petitions for designation as an eligible telecommunication carrier for the purpose of low-income universal service support in 11 states and the District of Columbia). 91 See id. at 15. 92 See, e.g., KAN. STAT. ANN. § 66-2008 (2006) (providing for the creation of a Kansas universal service fund (KUSF) and requiring that carriers be designated as an ETC pursuant to section 214(e)(1) of the Act to receive support from the KUSF). 93 Alaska Telephone Association (ATA) criticized proposals for a limited exception to the interim cap largely because ATA opposed the continued operation of the identical support rule. ATA Reply Comments at 3-4. This issue is better addressed in a rulemaking of general applicability. 94 See ALLTEL-Atlantis Order, 22 FCC Rcd at 19521, paras 9-10; AT&T-Dobson Order, 22 FCC Rcd at 20329-30, paras. 70-72. 95 Specifically, Covered Locations are tribal lands or Alaska Native regions as those terms are defined in section 54.400(e) of the Commission’s rules. See 47 C.F.R. 54.400(e) (tribal lands or Alaska Native regions are “any federally recognized Indian tribe's reservation, pueblo, or colony, including former reservations in Oklahoma, Alaska Native regions established pursuant to the Alaska Native Claims Settlement Act (85 Stat. 688), and Indian allotments.”); see also 47 C.F.R. §§ 54.403(a)(4), 54.409(c) (providing for additional Lifeline and Link Up support for eligible residents living in tribal lands or Alaska Native regions). 96 See Federal-State Joint Board on Universal Service; Promoting Deployment and Subscribership in Unserved and Underserved Areas, Including Tribal and Insular Areas, CC Docket No. 96-45, Twelfth Report and Order, Memorandum Report and Order, and Further Notice of Proposed Rulemaking, 15 FCC Rcd 12208, 12211-12, para. 2 (2000) (concluding that “existing universal service support mechanisms are not adequate to sustain telephone subscribership on tribal lands.”). Federal Communications Commission FCC 08-122 16 54.307 of the Commission’s rules, except that the uncapped per line support is limited to one payment per each residential account.97 If a competitive ETC serves lines in both Covered Locations and non-Covered Locations (or only Covered Locations), the universal service administrator shall determine the amount of additional support – after application of the interim cap – necessary to ensure that a competitive ETC receives the same per-line support amount as the incumbent LEC for the lines qualifying for the exception.98 34. Finally compliance with the terms of this limited exception will be verified through certification and reporting requirements.99 Specifically, a competitive ETC seeking to receive high-cost support pursuant to this limited exception must certify the number of lines that meet the limited exception requirements.100 The competitive ETC also must provide a specific description of how it confirmed that it had met the certification threshold.101 35. Even with the total amount of support provided to competitive ETCs being capped, continued growth in competitive ETC lines would have the effect of reducing the amount of interstate access support (IAS) received by incumbent LECs, due to the operation of the formula for calculating IAS.102 To prevent the implementation of the interim cap on competitive ETC support from having this unintended consequence on incumbent LEC support, we find it necessary to adjust the calculation of IAS for both incumbent LECs and competitive ETCs. Accordingly, we divide IAS into separate pools for incumbent LECs and competitive ETCs and separately cap the amount of IAS support for both types of carriers.103 The annual amount of IAS available for incumbent LECs shall be set at the amount of IAS that incumbent LECs were eligible to receive in March 2008 on an annual basis.104 This amount shall be indexed annually for line growth or loss by price cap incumbent LECs.105 The annual amount of IAS available for competitive ETCs shall be set at the amount of IAS that competitive ETCs were eligible to receive in March 2008 on an annual basis.106 Subject to these constraints, we direct USAC to calculate and distribute IAS for each pool to eligible carriers consistent with the existing IAS rules.107 97 47 C.F.R. § 54.307. 98 For example, if the uncapped per-line support amount in a competitive ETC’s service area is $10 per line, but the application of the interim cap reduces the per-line support amount to $8 per line, the competitive ETC would receive an additional $2 for each qualifying line in a Covered Location. 99 See GCI May 31 Ex Parte Letter at 3. 100 In order to qualify for the exception, the competitive ETC must certify the number of qualifying lines each time it files line count data with the universal service administrator. 101 Competitive ETCs must also comply with the document retention requirements for any such documentation. Comprehensive Review of the Universal Service Fund Management, Administration, and Oversight, WC Docket No. 05-195, Report and Order, 22 FCC Rcd 16372, 16383-84, para. 24. (2007). 102 See 47 C.F.R. §§ 54.800-54.808; see also Letter from David B. Cohen, Vice-President, Policy, USTelecom, to Marlene H. Dortch, Secretary, Federal Communications Commission, WC Docket No. 05-337, CC Docket No. 96- 45 (filed November 21, 2007) (USTelecom IAS Letter). 103 See USTelecom IAS Letter at 1-2. 104 See infra section III.B.3 (Base Period for the Cap). 105 See USTelecom IAS Letter at 2. 106 See infra section III.B.3 (Base Period for the Cap). 107 Nothing in this order is intended, or shall be construed by USAC, to alter the annual IAS targeted cap amount of $650 million. See 47 C.F.R. § 54.801(a). Federal Communications Commission FCC 08-122 17 2. Length of Time 36. In light of the harm to the sustainability of the universal service fund posed by the dramatic growth of support to competitive ETCs, we find that the cap we adopt today should become effective as soon as possible.108 The cap will, therefore, commence as of the effective date of this Order. 37. We emphasize that the cap on competitive ETC support that we adopt here is only an interim measure to slow the current explosion of high-cost universal service support while the Commission considers further reform. We remain committed to comprehensive reform of the high-cost universal service support mechanisms. The Commission has three outstanding rulemaking proceedings that consider comprehensive reform of high-cost universal service support.109 The Commission plans to move forward on adopting comprehensive reform measures in an expeditious manner. The Commission commits to completing a final order on comprehensive reform as quickly as feasible after the comment cycle is completed on the pending Reform Notices.110 We therefore do not believe that a fixed sunset date, as proposed by some commenters, is necessary or provides additional benefit.111 3. Base Period for the Cap 38. Although we adopt the Joint Board’s recommendation that the cap on competitive ETC support be set at the level of competitive ETC support actually distributed in each state, rather than set such a cap at the level of support actually distributed in 2006, we find it is more appropriate to set such a cap at the level of support competitive ETCs were eligible to receive during March 2008 on an annualized basis. Specifically, for each state, the annual interim cap shall be set at twelve times the level of support that all competitive ETCs were eligible to receive in that state for the month of March 2008. Using March 2008 data allows use of more recent actual support amounts than 2006. Use of March 2008 as the base period, moreover, will ensure that funding levels will not undermine the expectations underlying competitive ETC investment decisions or result in immediate funding reductions.112 Further, consistent with our decision to cap competitive ETC support on an interim basis, we find it inappropriate and counterproductive to index the cap to a growth factor. 39. Although the interim cap that we adopt today applies only to the amount of support available to competitive ETCs, it does not restrict the number of competitive ETCs that may receive support. In fact, as part of this Order, we grant, to the extent described in Appendix B, numerous applications for ETC designation currently pending before the Commission. As described in more detail in Appendix B, we find that the applicants have met the Commission’s requirements for designation. We also amend an ETC designation as described in Appendix C. These designations, however, do not affect the amount of support available to competitive ETCs, which is limited by the interim cap we adopt in this Order. 108 Because the limited exception that we adopt herein will trigger additional Paperwork Reduction Act requirements, the limited exception will not become effective until the relevant reporting and recording requirements are approved by the Office of Management and Budget. 109 See infra note 19. 110 See infra para. 4. 111 See Alltel Comments at 21-23. 112 See Dobson Comments at 14 (“The Commission should not disturb competitive ETCs’ expectations by picking a point in the past as the base period for the cap.”); see also Alltel Comments at 20-21; CTIA Comments at 28-29. Federal Communications Commission FCC 08-122 18 IV. PROCEDURAL MATTERS A. Final Regulatory Flexibility Analysis 40. As required by the Regulatory Flexibility Act of 1980, the Commission has prepared a Final Regulatory Flexibility Analysis (“FRFA”) of the possible significant economic impact on small entities of the policies and rules addressed in this Order.113 The FRFA is set forth in Appendix D. B. Paperwork Reduction Act Analysis 41. This document contains new information collection requirements subject to the Paperwork Reduction Act of 1995 (PRA).114 It will be submitted to the Office of Management and Budget (OMB) for review under section 3507(d) of the PRA. OMB, the general public, and other federal agencies are invited to comment on the new information collection requirements contained in this proceeding. In addition, we note that, pursuant to the Small Business Paperwork Relief Act of 2002, we previously sought specific comment on how the Commission might “further reduce the information collection burden for small business concerns with fewer than 25 employees.”115 42. In this present document, we have assessed the effects of demonstrating compliance with the exception to the interim cap, and find that there may be an increased administrative burden on businesses with fewer than 25 employees. We have taken steps to minimize the information collection burden for small business concerns, including those with fewer than 25 employees. First, we note that compliance with the exception is voluntary – small business concerns are not required to comply with the information collection. In addition, compliance with the exception will be elected by carriers on a study area by study area basis. Carriers need only provide additional information on the study areas for which they elect to rely on the exception to the interim cap. C. Congressional Review Act 43. The Commission will send a copy of this Order in a report to be sent to Congress and the Government Accountability Office pursuant to the Congressional Review Act.116 V. ORDERING CLAUSES 44. Accordingly, IT IS ORDERED, pursuant to the authority contained in sections 1-4, 201- 205, 214, 218-220, 254, 303(r), 403, 405, and 410 of the Communications Act of 1934, as amended, 47 U.S.C. §§ 151-154, 201-205, 214, 218-220, 254, 303(r), 403, 405, and 410, that this Order in CC Docket No. 96-45 and WC Docket No. 05-337 IS ADOPTED. 45. IT IS FURTHER ORDERED that, pursuant to the authority contained in section 214(e)(6) of the Communications Act, 47 U.S.C. § 214(e)(6), the petitions for eligible telecommunications carrier designation as set forth in Appendix B ARE GRANTED, DENIED, OR DISMISSED WITHOUT PREJUDICE to the extent described therein and, pursuant to section 1.103(a) of the Commission’s rules, 47 C.F.R. § 1.103(a), SHALL BE effective thirty days after publication in the 113 See 5 U.S.C. § 604. 114 Paperwork Reduction Act of 1995, Pub. L. No. 104-13, 109 Stat. 163 (1995). 115 Small Business Paperwork Relief Act of 2002, Pub. L. No. 107-198, 116 Stat. 729 (2002); 44 U.S.C. § 3506(c)(4). 116 See 5 U.S.C. § 801(a)(1)(A). Federal Communications Commission FCC 08-122 19 Federal Register, except where redefined service areas require the agreement of a state commission as described therein. 46. IT IS FURTHER ORDERED that, pursuant to the authority contained in section 214(e)(5) of the Communications Act, 47 U.S.C. § 214(e)(5), and sections 54.207(d) and (e) of the Commission’s rules, 47 C.F.R. §§ 54.207(d) and (e), the requests to redefine the service areas of the rural telephone companies described in Appendix B, ARE GRANTED, DENIED, or GRANTED IN PART AND DENIED IN PART to the extent described therein and SUBJECT TO the agreement of the relevant state commissions with the Commission’s redefinition of the relevant service areas, if not previously redefined as described therein. 47. IT IS FURTHER ORDERED that a copy of this order SHALL BE transmitted by the Office of the Secretary to the relevant state commissions and the Universal Service Administrative Company. 48. IT IS FURTHER ORDERED that the petitioners set forth in Appendix B SHALL SUBMIT additional information pursuant to sections 54.202(a) of the Commission’s rules, 47 C.F.R.§§ 54.202(a). 49. IT IS FURTHER ORDERED that NEP Cellcorp, Inc.’s Motion to Strike IS DISMISSED AS MOOT as described in Appendix B. 50. IT IS FURTHER ORDERED that, pursuant to the authority contained in section 214(e)(6) of the Communications Act, 47 U.S.C. § 214(e)(6), RCC Minnesota, Inc. and RCC Atlantic, Inc.’s ETC designation in New Hampshire is amended as set forth in Appendix C. 51. IT IS FURTHER ORDERED that the Commission’s Consumer and Governmental Affairs Bureau, Reference Information Center, SHALL SEND a copy of this Order, including the Final Regulatory Flexibility Analysis, to the Chief Counsel for Advocacy of the Small Business Administration. 52. IT IS FURTHER ORDERED, that this Order SHALL BE EFFECTIVE thirty days after publication in the Federal Register. FEDERAL COMMUNICATIONS COMMISSION Marlene H. Dortch Secretary Federal Communications Commission FCC 08-122 20 APPENDIX A List of Commenters Initial Comments Commenter Abbreviation Alaska Telephone Association ATA Alexicon Telecommunications Consulting Alexicon Alltel Communications, Inc. Alltel AT&T Inc. AT&T Blackfoot Telecommunications Group Blackfoot California Public Utilities Commission CPUC Centennial Communications Corp. Centennial CenturyTel, Inc. CenturyTel Chinook Wireless MTPCS, LLC d/b/a Chinook Chinook Wireless Comcast Corporation Comcast COMPTEL COMPTEL ComspanUSA ComspanUSA Corporation Commission of the State of Kansas KCC Corr Wireless Communications, LLC Corr CTIA – The Wireless Association® CTIA DialToneServices, L.P. DialToneServices Dobson Cellular Systems, Inc. Dobson Embarq Corporation Embarq ETS Telephone Company, Inc. f/k/a Kingsgate Telephone, Inc. ETS Fred Williamson and Associates Fred Williamson & Associates Frontier Communications Frontier General Communication, Inc. GCI GVNW Consulting, Inc. GVNW Idaho Public Utilities Commission IPUC Independent Telephone and Telecommunications Alliance ITTA Iowa Telecommunications Association Iowa Telecommunications Ass’n Iowa Utilities Board IUB Corporation Commission of the State of Kansas Kansas State Corporation Comm'n Maine Public Utilities Commission MPUC Midcontinent Communications Midcontinent Mid-Rivers Telephone Cooperative, Inc. MRTC Minnesota Independent Coalition MIC Montana Public Service Commission MTPSC Montana Telecommunications Association MTA National Association of State Utility Consumer Advocates NASUCA National Exchange Carrier Association, Inc. NECA National Telecommunications Cooperative Association NTCA Navajo Nation Telecommunications Regulatory Commission NNTRC Nebraska Public Service Commission NPSC Nebraska Rural Independent Telephone Companies Federal Communications Commission FCC 08-122 21 and South Dakota Telecommunications Association Nebraska Rural Independent Cos and South Dakota Telecommunications Ass’n New Jersey Board of Public Utilities New Jersey Board of Public Utilities New York State Department of Public Service New York Department of Public Service Organization for the Promotion and Advancement of Small Telecommunications Companies OPASTCO Public Utilities Commission of Ohio Ohio Commission Rural Cellular Association and the Alliance of Rural CMRS Carriers Rural Cellular Ass'n and Alliance of Rural CMRS Carriers Rural Independent Competitive Alliance RICA Rural Iowa Independent Telephone Association Rural Iowa Independent Telephone Ass’n Rural Telecommunications Group, Inc. Rural Telecommunications Group Small Company Committee of the Louisiana Telecommunications Association (Louisiana Rural Telephone Companies) Small Company Committee of the Louisiana Telecommunications Ass’n South Carolina Office of Regulatory Staff South Carolina Office of Regulatory Staff Southern Communications Services, Inc. d/b/a SouthernLINC Wireless SouthernLINC Sprint Nextel Corporation Sprint Nextel State Independent Telephone Association of Kansas and Independent Telecommunications Group State Independent Telephone Ass’n of Kansas and Independent Telecommunications Group SureWest Communications SureWest TCA, Inc. – Telcom Consulting Associates TCA TDS Telecommunications Corp. TDS Telecommunications Association of Michigan TAMI Telephone Association of Maine Telephone Ass’n of Maine Tennessee Telecommunications Association Tennessee Telecommunications Ass’n Texas Statewide Telephone Cooperative, Inc. Texas Statewide Telephone Cooperative, Inc. Totah Communications, Inc. FairPoint Communications (formerly Chouteau Telephone Company) Pine Telephone Company, Inc. Pine Cellular Phones, Inc. Grand Telephone Company, Inc. Totah Communications, Inc. et al. TracFone Wireless, Inc. TracFone Unicom, Inc. Unicom United States Cellular Corporation and Rural Cellular Corporation US Cellular and Rural Cellular Corp. United States Telecom Association USTelecom Valley Telephone Cooperative, Inc. Valley Telephone Cooperative Verizon and Verizon Wireless Verizon and Verizon Wireless Western Telecommunications Alliance Western Telecommunications Alliance Windstream Communications, Inc. Windstream Federal Communications Commission FCC 08-122 22 Wisconsin State Telecommunications Association Wisconsin State Telecommunications Ass’n Reply Comments Commenter Abbreviation Alaska Telephone Association ATA Alltel Communications, Inc. Alltel Arizona Corporation Commission Arizona Commission CTIA – The Wireless Association CTIA DialToneServices, L.P. DialToneServices Dobson Cellular Systems, Inc. Dobson Embarq Corporation Embarq Five State Members of the Mid-Atlantic Conference of Regulatory Utility Commissioners Five MACRUC States Florida Public Service Commission FPSC Fred Williamson and Associates, Inc. Fred Williamson & Associates General Communication, Inc. GCI Golden West Telecommunications Cooperative, Inc. Golden West GVNW Consulting, Inc. GVNW Independent Telephone and Telecommunications Alliance ITTA Missouri RSA No. 5 Partnership d/b/a Chariton Valley Wireless Services and Panhandle Telecommunication Systems, Inc. Chariton Montana Telecommunications Association MTA National Association of State Utility Consumer Advocates NASUCA National Telecommunications Cooperative Association NTCA Nebraska Rural Independent Telephone Companies and South Dakota Telecommunications Association Nebraska Rural Independent Cos and South Dakota Telecommunications Ass’n New Jersey Division of Rate Counsel NJ Rate Counsel New York State Telecommunications Association, Inc. NYSTA Ohio Telecom Association OTA Oregon Telecommunications Association Small Company Committee and Washington Independent Telephone Association WITA Organization for the Promotion and Advancement of Small Telecommunications Companies OPASTCO Pennsylvania Public Utility Commission PaPUC Qwest Communications International Inc. Qwest Rural Cellular Association and the Alliance of Rural CMRS Carriers Rural Cellular Ass'n and Alliance of Rural CMRS Carriers Rural Iowa Independent Telephone Association Rural Iowa Independent Telephone Ass’n Scott Wallsten, Sr. Fellow and Director of Communications Policy Studies at the Progress & Freedom Foundation Wallsten Small Company Committee of the Louisiana Telecommunications Association Federal Communications Commission FCC 08-122 23 (Louisiana Rural Telephone Companies) Small Company Committee of the Louisiana Telecommunications Ass’n South Carolina Telephone Coalition SCTC Southern Communications Services, Inc. d/b/a SouthernLINC Wireless SouthernLINC Sprint Nextel Corporation Sprint Nextel State Independent Telephone Association of Kansas and Independent Telecommunications Group State Independent Telephone Ass’n of Kansas and Independent Telecommunications Group SureWest Communications SureWest TDS Telecommunications Corp. TDS Texas Statewide Telephone Cooperative, Inc. Texas Statewide Telephone Cooperative, Inc. T-Mobile U.S.A., Inc. T-Mobile Totah Communications, Inc. FairPoint Communications (formerly Chouteau Telephone Company) Pine Telephone Company, Inc. Pine Cellular Phones, Inc. Grand Telephone Company, Inc. Totah Communications, Inc. et al. TracFone Wireless, Inc. TracFone United States Cellular Corporation and Rural Cellular Corporation US Cellular and Rural Cellular Corp. Verizon and Verizon Wireless Verizon and Verizon Wireless Western Telecommunications Alliance Western Telecommunications Alliance Federal Communications Commission FCC 08-122 24 APPENDIX B Alltel Communications, Inc., et al. Petitions for Designation as Eligible Telecommunications Carriers I. INTRODUCTION 1. As stated in paragraph 44 of this Order, we grant, deny, or dismiss without prejudice as discussed below 22 petitions for designation as eligible telecommunications carriers (ETCs) filed by 14 entities pursuant to section 214(e)(6) of the Communications Act of 1934, as amended (the Act) (collectively, Petitions).1 We also redefine the service areas of certain rural telephone companies to the extent described herein. II. BACKGROUND A. The Act 2. Section 254(e) of the Act provides that “only an eligible telecommunications carrier designated under section 214(e) shall be eligible to receive specific Federal universal service support.”2 Pursuant to section 214(e)(1) of the Act, a common carrier designated as an ETC must offer and advertise the services supported by the federal universal service mechanisms throughout the designated service area.3 3. Section 214(e)(2) of the Act gives state commissions the primary responsibility for performing ETC designations.4 Section 214(e)(6) directs the Commission, upon request, to designate as an ETC “a common carrier providing telephone exchange service and exchange access that is not subject 1 47 U.S.C. § 214(e)(1). A list of the Petitions is set forth in Exhibit 1. We note that many of the Petitioners filed amendments and/or supplements to their petitions. The term Petitions, as used herein, includes any such amendments and supplemental filings. Exhibit 1 also provides abbreviations for the entities, petitions, amendments, and supplemental filings cited in this Order. We note that AT&T Wireless Services, Inc. (AWS) initially filed a petition for designation as an ETC in the state of Alabama for itself and on behalf of AirCom PCS, Inc., Tritel C/F Holding Corp., Tritel A/B Holding Corp, AT&T Wireless PCS, LLC, and QuinComm, Inc. See generally AWS Alabama Petition. After its merger with AWS, Cingular Wireless LLC filed amendments to the petition to reflect the merger, remove all rural study areas, and amend the non-rural areas for which it requests designation. See Cingular Alabama Amendment. Cingular Wireless LLC now wholly owns or controls all of the licensees at issue in the instant matter: New Cingular Wireless PCS, LLC, Blue Licenses Holding, LLC, and Orange Licenses Holding, LLC. See id. at 2 and Exhibit D. We refer to Cingular Wireless LLC and any of the associated entities holding the licenses at issue herein collectively as Cingular. Based on Cingular’s representations, we evaluate the AWS petition and the Cingular amendments as unified pleadings. We further note that U.S. Cellular acquired control of Tennessee RSA No. 3 Limited Partnership d/b/a Eloqui (Eloqui) after Eloqui filed its petition for designation as an ETC in the state of Tennessee. See U.S. Cellular Tennessee Amended Petition at 2. We evaluate the Eloqui Petition and the U.S. Cellular amendments thereto as unified pleadings. 2 47 U.S.C. § 254(e). 3 47 U.S.C. § 214(e)(1); see also 47 C.F.R. § 54.201(d). 4 47 U.S.C. § 214(e)(2); see Promoting Deployment and Subscribership in Unserved Areas, Including Tribal and Insular Areas, CC Docket No. 96-45, Twelfth Report and Order, Memorandum Opinion and Order, and Further Notice of Proposed Rulemaking, 15 FCC Rcd 12208, 12255, para. 93 (2000) (Twelfth Report and Order). Federal Communications Commission FCC 08-122 25 to the jurisdiction of a State commission.”5 Under section 214(e)(6), the Commission may, with respect to an area served by a rural telephone company, and shall, in all other cases, designate more than one common carrier as an ETC for a designated service area, consistent with the public interest, convenience, and necessity, so long as the requesting carrier meets the requirements of section 214(e)(1).6 Before designating an additional ETC for an area served by a rural telephone company, the Commission must determine that the designation is in the public interest.7 B. Commission Requirements for ETC Designation 4. An ETC petition must contain the following: (1) a certification and brief statement of supporting facts demonstrating that the petitioner is not subject to the jurisdiction of a state commission; (2) a certification that the petitioner offers or intends to offer all services designated for support by the Commission pursuant to section 254(c) of the Act; (3) a certification that the petitioner offers or intends to offer the supported services “either using its own facilities or a combination of its own facilities and resale of another carrier’s services;” (4) a description of how the petitioner “advertise[s] the availability of the [supported] services and the charges therefor using media of general distribution;” and (5) if the petitioner meets the definition of a “rural telephone company” under section 3(37) of the Act, the identity of its study area, or, if the petitioner is not a “rural telephone company,” a detailed description of the geographic service area for which it requests an ETC designation from the Commission.8 5. In the ETC Designation Order, the Commission adopted additional requirements for ETC designation proceedings in which the Commission acts pursuant to section 214(e)(6) of the Act.9 Specifically, consistent with the recommendation of the Federal-State Joint Board on Universal Service (Joint Board), the Commission found that an ETC applicant must demonstrate: (1) a commitment and ability to provide services, including providing service to all customers within its proposed service area; (2) how it will remain functional in emergency situations; (3) that it will satisfy consumer protection and service quality standards; (4) that it offers local usage comparable to that offered by the incumbent LEC; and (5) an understanding that it may be required to provide equal access if all other ETCs in the designated service area relinquish their designations pursuant to section 214(e)(4) of the Act.10 These additional requirements are mandatory for all ETCs designated by the Commission.11 ETCs already 5 47 U.S.C. § 214(e)(6). 6 Id. 7 Id. 8 See Procedures for FCC Designation of Eligible Telecommunications Carriers Pursuant to Section 214(e)(6) of the Communications Act, CC Docket No. 96-45, Public Notice, 12 FCC Rcd 22947, 22948 (1997) (Section 214(e)(6) Public Notice); see also Virginia Cellular, LLC Petition for Designation as an Eligible Telecommunications Carrier for the Commonwealth of Virginia, CC Docket No. 96-45, Memorandum Opinion and Order, 19 FCC Rcd 1563, 1564, 1565, 1575-76, 1584-85, paras. 1, 4, 27, 28, 46 (2004) (Virginia Cellular Order); Highland Cellular, Inc. Petition for Designation as an Eligible Telecommunications Carrier for the Commonwealth of Virginia, CC Docket No. 96-45, Memorandum Opinion and Order, 19 FCC Rcd 6422, 6438, paras. 1, 33 (2004) (Highland Cellular Order). 9 See Federal-State Joint Board on Universal Service, CC Docket No. 96-45, Report and Order, 20 FCC Rcd 6371 (2005) (ETC Designation Order). 10 See ETC Designation Order, 20 FCC Rcd at 6380, para. 20 (citing Federal-State Joint Board on Universal Service, CC Docket No. 96-45, Recommended Decision, 19 FCC Rcd 4259, 4261, para. 5 (Fed-State Jt. Bd. 2004)). 11 47 C.F.R. § 54.202(a). Federal Communications Commission FCC 08-122 26 designated by the Commission or ETC applicants that submitted applications prior to the effective date of the ETC Designation Order must make such showings in their annual certification filings.12 6. In addition, prior to designating an ETC pursuant to section 214(e)(6) of the Act, the Commission determines whether such designation is in the public interest.13 In the ETC Designation Order, the Commission adopted one set of criteria for evaluating the public interest for ETC designations for both rural and non-rural areas.14 Specifically, in determining the public interest, the benefits of increased consumer choice and the unique advantages and disadvantages of the applicant’s service offering are considered.15 As the Commission noted in the ETC Designation Order, however, the same factors may be analyzed differently or may warrant a different outcome depending on the specifics of the proposed service area and whether it is rural or non-rural.16 In particular, the creamskimming analysis is limited to designations in rural service areas.17 Thus, when an ETC applicant seeks designation below the study area level of a rural telephone company, the Commission conducts a creamskimming analysis to compare the population density of the wire centers in which the ETC applicant seeks designation against that of the wire centers in the study area in which the ETC applicant does not seek designation.18 C. Requirements for Redefining Rural Telephone Company Service Areas 7. To designate ETCs in service areas that differ from the affected rural telephone companies’ study areas, we must redefine the service areas of the rural telephone companies in accordance with section 214(e)(5) of the Act.19 Under section 214(e)(5), “[i]n the case of an area served by a rural telephone company, ‘service area’ means such company’s ‘study area’ unless and until the Commission and the States, after taking into account recommendations of a Federal-State Joint Board instituted under section 410(c), establish a different definition of service area for such company.”20 Under section 54.207(d)(1) of the Commission’s rules, the Commission must petition a state commission with the proposed definition according to that state commission’s procedures.21 In that petition, the Commission must provide its proposal for redefining the service area and its decision presenting reasons for adopting the new definition, including an analysis that takes into account the recommendations of the Joint Board.22 When the Joint Board recommended that the Commission retain the current study areas of 12 47 C.F.R. § 54.202(b). 13 47 U.S.C. § 214(e)(6); 47 C.F.R. § 54.202(c); see also ETC Designation Order, 20 FCC Rcd at 6388-96, paras. 40-57; Virginia Cellular Order, 19 FCC Rcd at 1575, para. 27; Highland Cellular Order, 19 FCC Rcd at 6431-32, para. 21. The Commission places the burden on the ETC applicant to demonstrate that the public interest is served. ETC Designation Order, 20 FCC Rcd at 6390, para. 44. 14 Id. at 6389-90, paras. 42-43. 15 47 C.F.R. § 54.202(c). 16 ETC Designation Order, 20 FCC Rcd at 6390, para. 43. 17 Id. at 6389-90, paras. 42-43. A carrier “creamskims” when it serves only the least expensive customers, thereby undermining the ability of the incumbent local exchange carrier (LEC) to provide service to the entire study area. See Federal-State Joint Board on Universal Service, Report and Order, CC Docket No. 96-45, 12 FCC Rcd 8776, 8881-82, para. 189 (1997) (subsequent history omitted). 18 ETC Designation Order, 20 FCC Rcd at 6392-95, paras. 48-53. 19 47 U.S.C. § 214(e)(5). 20 Id. 21 47 C.F.R. § 54.207(d)(1). 22 Id. Federal Communications Commission FCC 08-122 27 rural telephone companies as the service areas for the rural telephone companies, the Joint Board made the following observations: (1) the potential for creamskimming is minimized by retaining study areas because competitors, as a condition of eligibility, must provide services throughout the rural telephone company's study area; (2) the Act, in many respects, places rural telephone companies on a different competitive footing from other local telephone companies; and (3) there would be an administrative burden imposed on rural telephone companies by requiring them to calculate costs at something other than the study area level.23 III. DISCUSSION A. Commission Authority to Perform ETC Designations 8. Petitioners have demonstrated that, except for the Florida Public Service Commission, the Georgia Public Service Commission, and the U.S. Virgin Islands Public Services Commission, the relevant state commissions lack authority to perform the requested ETC designations and the Commission has authority to consider the Petitions under section 214(e)(6) of the Act.24 9. In April 2007, the Florida Public Service Commission found that, due to a change in Florida state law, it “now ha[s] jurisdiction to consider CMRS applications for ETC designation.”25 The Georgia Public Service Commission found in October 2007 that it has the authority to designate wireless carriers as ETCs.26 Further, the U.S. Virgin Islands in February 2008 granted its Public Services Commission the authority to grant requests for ETC designation by wireless carriers.27 In light of these developments, and because section 214(e)(2) of the Act gives state commissions the primary responsibility for performing ETC designations,28 we dismiss without prejudice the petitions filed by SouthernLINC seeking designation as an ETC in Florida and Georgia and the petition filed by Choice seeking designation as an ETC in the U.S. Virgin Islands (the Dismissed Petitions). SouthernLINC may re-file its petitions with the Florida Public Service Commission and the Georgia Public Service Commission, respectively, and Choice may re-file its petition with the U.S. Virgin Islands Public Services Commission. 23 See Federal-State Joint Board on Universal Service, CC Docket No. 96-45, Recommended Decision, 12 FCC Rcd 87, 179-80, paras. 172-74 (1996) (1996 Recommended Decision). 24 47 U.S.C. § 214(e)(6). 25 Petition of Alltel Communications, Inc. for Designation as Eligible Telecommunications Carrier (ETC) in Certain Rural Telephone Company Study Areas Located Partially in Alltel's Licensed Area and for Redefinition of those Study Areas, PSC-07-0288-PAA-TP, Notice of Proposed Agency Action Order Finding Authority to Consider Applications By CMRS Providers For ETC Designation, 2007 WL 1029436 (Fla. P.S.C. Apr. 3, 2007). This order was a proposed agency action, which was made final by a consummating order on June 7, 2007. See Petition of Alltel Communications, Inc. for Designation as Eligible Telecommunications Carrier (ETC) in Certain Rural Telephone Company Study Areas Located Partially in Alltel's Licensed Area and for Redefinition of those Study Areas, PSC-07-0481A-CO-TP, Amendatory Order, 2007 WL 1774614 (Fla. P.S.C. June 7, 2007). 26 See Ga. Code Ann. § 46-5-222 (2007); Application of Alltel Communications, Inc. for Designation as an Eligible Telecommunications Carrier in the State of Georgia, 10396-U, Order Granting ETC Status, 2007 WL 3119444 (Ga. P.S.C. Oct. 15, 2007). 27 See 2007 V.I. Sess. Laws 6977; Letter from Joseph B. Boschulte, Chairman, U.S.Virgin Islands Public Services Commission, to Marlene H. Dortch, Secretary, FCC, WC Docket No. 05-337, CC Docket No. 96-45 (dated Feb. 11, 2008). 28 See 47 U.S.C. § 214(e)(2). Federal Communications Commission FCC 08-122 28 10. Each of the remaining Petitions includes an affirmative statement from the relevant state commission providing that ETC designation should be sought from the Commission.29 Accordingly, we find that the relevant state commissions lack jurisdiction to designate Petitioners as ETCs and that this Commission therefore has authority to perform the requested ETC designations under section 214(e)(6).30 B. Analysis of the Eligibility Requirements 11. Offering the Services Designated for Support. Petitioners have demonstrated through the required certifications and related filings that they now offer, or will offer upon designation as ETCs, the services supported by the federal universal service mechanisms.31 12. Offering the Supported Services Using a Carrier’s Own Facilities. Petitioners have demonstrated that they offer, or will offer upon designation as ETCs, the supported services using either their own facilities or a combination of their own facilities and resale of another carrier’s services.32 29 See generally Petitions. The term Petitions shall hereinafter be interpreted to exclude the Dismissed Petitions and the term Petitioners to exclude Choice and, with respect to its Florida and Georgia petitions, SouthernLINC. 30 47 U.S.C. § 214(e)(6). We note that the Pennsylvania Public Utility Commission (Pennsylvania Commission) filed reply comments opposing NEP’s petition. See Petitions of NEP Cellcorp, Inc. for Designation as an Eligible Telecommunications Carrier in the Commonwealth of Pennsylvania and Corr Wireless Communications, LLC for Designation as an Eligible Telecommunications Carrier in the State of Alabama, CC Docket No. 96-45, Reply Comments of the Pennsylvania Public Utilities Commission (filed Sept. 5, 2007). The Pennsylvania Commission also, however, stated in a letter to NEP that the Pennsylvania Commission did not intend to exercise jurisdiction to consider NEP’s petition, and that NEP should seek ETC designation at the federal level. See NEP Petition at Exh. B. We find that NEP has provided sufficient evidence to support the conclusion that we have jurisdiction to perform NEP’s requested ETC designation under section 214(e)(6). 47 U.S.C. § 214(e)(6). NEP filed a motion to strike the Pennsylvania Commission’s reply comments from the record. See NEP Cellcorp, Inc. Application for Designation as an Eligible Telecommunications Carrier in the Commonwealth of Pennsylvania, CC Docket No. 96-45, Motion to Strike (filed Oct. 10, 2007). Because we grant NEP’s petition here, we dismiss NEP’s motion as moot. The Commission previously has stated that “the Commission’s authority to perform [an ETC designation under section 214(e)(6)] is no greater than that of the state that would have otherwise made the designation.” Petition for Reconsideration of Western Wireless Corporation’s Designation as an Eligible Telecommunications Carrier in the State of Wyoming, CC Docket No. 96-45, Order on Reconsideration, 16 FCC Rcd 19144, 19147, para. 8 (2001) (Western Wireless 2001 Order), affirming Western Wireless Corporation Petition for Designation as an Eligible Telecommunications Carrier in the State of Wyoming, CC Docket No. 96-45, Memorandum Opinion and Order, 16 FCC Rcd 48 (Com. Carrier Bur. 2000) (Western Wireless 2000 Order). With respect to U.S. Cellular’s New Hampshire petition, the Commission stands in the place of the New Hampshire Public Utilities Commission (New Hampshire Commission). U.S. Cellular requested, however, designation for certain wire centers located in Vermont, which are served by Verizon New England, a non-rural incumbent LEC, and two wire centers located in Maine, which are served by Northland Telephone of Maine Inc., a rural incumbent LEC. U.S. Cellular New Hampshire Petition, Exhibits B and C. U.S. Cellular has not demonstrated that the Maine and Vermont Commissions do not have the authority to designate U.S. Cellular as an ETC in their states. As the New Hampshire Commission would not have the authority to perform an ETC designation for wire centers in Maine or Vermont, we exclude from our determination the wire centers of Verizon New England in Vermont and Northland Telephone of Maine Inc. in Maine. The Verizon New England wire centers in Vermont which we exclude are: Barnet, Bellows Falls, Brattleboro, Bradford, Fairlee, Newbury, Windsor, and White River Junction. The Northland Telephone of Maine Inc. wire centers in Maine which we exclude are Fryeburg and North Fryeburg. 31 47 C.F.R. § 214(e)(1)(A); 47 C.F.R. § 54.201(d)(1); 47 C.F.R. § 54.101(a) (listing the services supported by the federal universal service mechanisms); see generally Petitions. 32 47 C.F.R. § 214(e)(1)(A); 47 C.F.R. § 54.201(d)(1); see generally Petitions. Federal Communications Commission FCC 08-122 29 13. Advertising Supported Services. Petitioners have committed to advertise the availability of the supported services and the related charges using media of general distribution.33 In addition, Petitioners have committed to advertising the availability of Lifeline and Link-Up services in a manner reasonably designed to reach those likely to qualify for those services.34 14. Additional Eligibility Requirements. Petitioners also satisfy the eligibility requirements set forth in the ETC Designation Order, described above,35 or must make such showings in their first annual reports under section 54.209 of the Commission’s rules.36 C. Public Interest Analysis 15. Cost-Benefit Analysis. We find that Petitioners’ universal service offerings will provide a variety of benefits to consumers, including increased consumer choice, high-quality service offerings,37 and mobility.38 In addition, universal service support will enable Petitioners to construct facilities or accelerate planned construction.39 This should improve quality of service and will, in some cases, extend telephone service to people who do not have access to a wireline telephone or do not have a choice of telephone providers.40 On balance, and subject to our creamskimming analysis for rural study areas below, we find that the advantages of designating Petitioners as ETCs to the extent described herein outweigh any disadvantages.41 33 47 U.S.C. § 214(e)(1)(B); 47 C.F.R. § 54.201(d)(2); see generally Petitions. 34 47 C.F.R. §§ 54.405, 54.411. 35 See supra para. 5. 36 ETC Designation Order, 20 FCC Rcd at 6380, para. 20; 47 C.F.R. §§ 54.202(a), 54.209; see generally Petitions. 37 For example, Petitioners have committed to comply with the Consumer Code for Wireless Service of the Cellular Telecommunications Industry Association (CTIA). See generally Petitions. 38 See generally Petitions. As noted in the PSC Alabama Order, the mobility of telecommunications assists consumers in rural areas who often must drive significant distances to places of employment, stores, schools, and other locations. Public Service Cellular, Inc. Petition for Designation as an Eligible Telecommunications Carrier in the States of Georgia and Alabama, CC Docket No. 96-45, Order, 20 FCC Rcd 6854, 6861, para. 25 (Wireline Comp. Bur. 2005) (PSC Alabama Order). Moreover, the availability of a wireless universal service offering also provides access to emergency services that can mitigate the unique risks of geographic isolation associated with living in rural communities. Id. 39 See generally Petitions. 40 See, e.g., Dobson First Petition at 17. 41 Although there may be disadvantages to designating Petitioners as ETCs, such as dropped calls or poor coverage in certain portions of these areas, our concerns about potential disadvantages are allayed by Petitioners’ commitments to build out their facilities and to make service quality improvements. We note that Petitioners are required to report on service quality improvements and any problems associated with their coverage on October 1st of each year. 47 C.F.R. § 54.209. See also ETC Designation Order, 20 FCC Rcd at 6400-6402, paras. 68-69. We also note that all ETCs must report annually on the progress of their five-year network improvement plans. See 47 C.F.R. § 54.209. In addition, some commenters argued that designation of multiple new ETCs may undermine the sustainability of the universal service fund (Fund). See, e.g., Cingular Wireless Petition for Designation as an Eligible Telecommunications Carrier in the Commonwealth of Virginia, CC Docket No. 96-45, Opposition of Verizon, at 4 (filed Dec. 4, 2006). The interim cap on high-cost universal service support disbursements adopted in this order is sufficient to ensure the sustainability of the Fund. Further, the ETC Designation Order found that any impact on the Fund must be balanced against other objectives, such as providing access to services comparable to services offered (continued....) Federal Communications Commission FCC 08-122 30 16. Creamskimming Analysis. Because Petitioners request ETC status in the entire study area of each of the rural telephone companies listed in Exhibits 2, 4-9, 11-13, 15-16, and 18-28, we are not concerned about the potential for creamskimming with regard to these companies.42 For this reason and for the reasons set forth in paragraph 15, we find that designation of Petitioners as ETCs in the areas stated in Exhibits 2, 4-9, 11-13, 15-16, and 18-28 is in the public interest. 17. Petitioners’ service areas differ from the study areas of the rural telephone companies identified in Exhibits 3, 10, 14, 17 and 29. We therefore performed a creamskimming analysis for those service areas. Except as noted below, our analysis of the population density of each of the affected wire centers revealed that Petitioners will not be serving only low-cost areas to the exclusion of high-cost areas. Although there are other factors that define high-cost areas, a lower population density generally indicates a higher-cost area.43 Therefore, except as noted below, we find that, for the reasons stated in paragraph 15 and because designating Petitioners below the study area level of the relevant rural telephone companies will not have the effect of creamskimming, such designations are in the public interest. 18. For the following study areas, we find designating Petitioners below the study area level raises creamskimming concerns based on analysis of population densities and therefore is not in the public interest. 19. Alltel. We find that designating Alltel as an ETC in the Butler Telephone Co., Inc. and Frontier Communications of the South study areas in Alabama, the Alltel Carolina-North Inc. and Sprint Mid Atlantic study areas in North Carolina, and the Central Telephone Co.-Virginia, NTELOS Telephone Inc., United Inter-Mountain Telephone, and Verizon South Inc.-VA study areas of Virginia would not be in the public interest. 20. Dobson. We find that designating Dobson as an ETC in the Citizens Telecom-NY and State Tel. Co. study areas would not be in the public interest. Designation of Dobson as an ETC in the Empire Tel. Corp. study area does not create creamskimming concerns because, consistent with Dobson’s filing, we remove the East Pembroke wire center from the proposed service area.44 We therefore designate Dobson as an ETC only in the Pulteney wire center in the Empire Tel. Corp. service area. 21. U.S. Cellular. We find that designating U.S. Cellular as an ETC in the Citizens Communications Company Tennessee d/b/a Frontier Communications of Tennessee, LLC, Tennessee Telephone Co., and Twin Lakes Telephone Cooperative Corp. study areas would not be in the public interest. We note that U.S. Cellular did not provide sufficient data for us to perform a creamskimming analysis with respect to Tennessee Telephone Co. (...continued from previous page) in urban areas and competitive neutrality. See ETC Designation Order, 20 FCC Rcd at 6395-96, para. 56. We find that any impact on the Fund is outweighed by the benefits described above. 42 ETC Designation Order, 20 FCC Rcd at 6392, para. 49; Virginia Cellular Order, 19 FCC Rcd at 1578, para. 32; Highland Cellular Order, 19 FCC Rcd at 6434-35, para. 26. As noted above, the creamskimming analysis is limited to designations in rural service areas. See supra para. 6. 43 Advantage Cellular Systems Inc. Petition for Designation as an Eligible Telecommunications Carrier in the State of Tennessee, CC Docket No. 96-45, Order, 19 FCC Rcd 20994, n.67 (Wireline Comp. Bur. 2004). 44 Dobson stated “in the event the Commission finds that the present disparity in population density between the served and unserved wire centers of the study area of Empire Telephone Corporation (SAC 150093) (Empire) is large enough to present cream skimming concerns, Dobson would withdraw from its proposed designated area the East Pembroke wire center (EPMBNYXA) to equalize the balance in population density.” Dobson Second Amendment at 2. Federal Communications Commission FCC 08-122 31 22. Partial Wire Centers. In the ETC Designation Order and Highland Cellular Order, the Commission concluded that making designations for a portion of a rural telephone company’s wire center would be inconsistent with the public interest. 45 Therefore, we find that designating NEP as an ETC in the North-Eastern Pennsylvania Telephone Co. study area in Pennsylvania would not be in the public interest because NEP only provides partial coverage in the wire centers of Clifford and Forest City. In addition, we find that designating NEP as an ETC in the Springville wire center in the Frontier study area in Pennsylvania would not be in the public interest because NEP only provides partial coverage in this wire center.46 D. Redefinition Analysis 23. Consistent with prior rural service area redefinitions and with the recommendations of the Joint Board described above,47 we redefine certain service areas as follows. 24. Alltel. We note that we previously redefined the service areas of Alltel Alabama Inc. and Millry Telephone Company in Alabama48 and Central Telephone Co. and Surry Telephone Membership in North Carolina.49 25. Dobson. We redefine the services areas of Citizens Tel. Co. of NY, Taconic Tel. Corp., and Middleburgh Tel. Co at the wire center level. We also redefine the revised Empire service area at the wire center level.50 26. NEP. We redefine the requested wire centers in the study area of Frontier and Verizon North at the wire center level.51 27. NY RSA 2. We redefine the requested wire centers in the study area of Citizens Telecommunications of New York d/b/a Frontier Communications as a separate service area. 28. U.S. Cellular. We redefine the requested wire centers in the study area of North Central Telephone Cooperative, Inc. as a separate service area. We also redefine the requested wire centers in the study areas of NTELOS Telephone Inc., Peoples Mutual Telephone Co., Central Telephone Co.-VA and Verizon South Inc.-VA in Virginia as a separate service area. We also redefine the requested wire centers in the study areas of Alltel Carolina-North, Inc., Central Telephone Company-North Carolina, Randolph Telephone Membership Corporation, Skyline Telephone Membership Corporation, Sprint Mid-Atlantic, and Yadkin Valley Telephone Membership Corporation in North Carolina as a separate service area. 45 ETC Designation Order, 20 FCC Rcd at 6378, para. 15; Highland Cellular Order, 19 FCC Rcd at 6438, para. 33. 46 We note that NEP sought redefinition of the Frontier study area. See infra para. 26. 47 See supra para. 7. 48 RCC Holdings, Inc. Petition for Designation as an Eligible Telecommunications Carrier Throughout its Licensed Service Area in the State of Alabama, CC Docket No. 96-45, Memorandum Opinion and Order, 17 FCC Rcd 23532, 23547, para. 38 (Wireline Comp. Bur. 2002). 49 North Carolina RSA 3 Cellular Telephone Company Petition for Designation as an Eligible Telecommunications Carrier in the State of North Carolina, CC Docket No. 96-45, Order, 21 FCC Rcd 9151, 9159, para. 26 (Wireline Comp. Bur. 2006). 50 See supra para. 20. 51 See supra para. 22 (declining to designate NEP in the Springville wire center). We note that NEP did not request redefinition of the Verizon Pennsylvania study area, and therefore decline to designate NEP in the Lake Como wire center. See infra para. 36. Federal Communications Commission FCC 08-122 32 Finally, we note that we previously redefined Granite State Telephone Inc.’s service area in New Hampshire52 and United Inter-Mountain Telephone Company’s service area in Virginia.53 29. Except where noted above, our redefinition proposals are subject to the agreement of the relevant state commissions. We therefore submit our redefinition proposals to the relevant state commissions and request that they examine such proposals based on their unique familiarity with the rural areas in question. If, after its review, a state commission determines that it does not agree with a redefinition proposal herein, we intend to reexamine the relevant petition with regard to redefining the service area. E. Designated Service Areas 30. Based on the foregoing, we hereby designate Petitioners as ETCs as follows. 31. Alltel. We designate Alltel as an ETC for the entire study areas served by the rural telephone companies in Alabama, North Carolina, and Virginia listed in Exhibit 2. Subject to the agreement of the Alabama Public Service Commission, North Carolina Utilities Commission and Virginia Corporation Commission on our proposed redefinition of service areas, if not previously redefined,54 we also designate Alltel as an ETC in the wire centers listed in Exhibit 3. 32. Cingular. We designate Cingular as an ETC in the requested areas served by the non- rural telephone companies in Alabama and Virginia listed in Exhibit 4. We designate Cingular as an ETC for the entire study areas served by the rural telephone companies in Virginia listed in Exhibit 5. 33. Corr. We designate Corr as an ETC in the entire study area served by the non-rural telephone company in Alabama listed in Exhibit 6. We designate Corr as an ETC in the entire study areas served by the rural telephone companies in Alabama listed in Exhibit 7.55 34. Dobson. We designate Dobson as an ETC in the requested study areas in New York served by non-rural telephone companies, as listed in Exhibit 8. We designate Dobson as an ETC in the entire study areas served by the rural telephone companies in New York, as listed in Exhibit 9. Subject to the New York Department of Public Service’s agreement on our proposed redefinition of service areas, we also designate Dobson as an ETC for the wire centers in Exhibit 10. 52 RCC Minnesota Inc., and RCC Atlantic, Inc. Petition for Designation as an Eligible Telecommunications Carrier in New Hampshire, CC Docket No. 96-45, Order, 20 FCC Rcd 15833, 15841, para. 25 (Wireline Comp. Bur. 2005) (RCC Order). 53 Highland Cellular Order, 19 FCC Rcd at 6439, paras. 37-38. 54 See supra para. 24. 55 Corr requested designation for one study area, Ardmore Telephone Co., which extends beyond the state boundary of Alabama into Tennessee. The Commission previously has stated that “the Commission’s authority to perform [an ETC designation under section 214(e)(6)] is no greater than that of the state that would have otherwise made the designation.” Western Wireless 2001 Order, 16 FCC Rcd at 19147, para. 8. Corr did not seek ETC designation in Tennessee. Therefore, we designate Corr as an ETC only in the portion of Ardmore Telephone Co.’s study area that is contained within the boundaries of the state of Alabama. See id. at 19147-49, paras. 8-13, affirming Western Wireless 2000 Order, 16 FCC Rcd at 57-59, paras. 23-24 (designating Western Wireless as an ETC only in the study areas of telephone companies that are located in the state (Wyoming) that was the subject of Western Wireless’ ETC petitions). Federal Communications Commission FCC 08-122 33 35. Farmers. We designate Farmers as an ETC in the requested areas served by the non-rural telephone companies in Alabama listed in Exhibit 11. We designate Farmers as an ETC for the entire study areas served by the rural telephone companies in Alabama listed in Exhibit 12. 36. NEP. We designate NEP as an ETC for the entire study areas served by the rural telephone companies in Pennsylvania listed in Exhibit 13. Subject to the Pennsylvania Public Utility Commission’s agreement on our proposed redefinition of service areas, we also designate NEP as an ETC in the wire centers listed in Exhibit 14. 37. NY RSA 2. We designate NY RSA 2 as an ETC in the requested areas served by the non-rural telephone companies in New York listed in Exhibit 15. We designate NY RSA 2 as an ETC for the entire study areas served by the rural telephone companies in New York listed in Exhibit 16. Subject to the New York Department of Public Service’s agreement on our proposed redefinition of service areas, we also designate NY RSA 2 as an ETC for the wire centers listed in Exhibit 17. 38. Pine Belt. We designate Pine Belt as an ETC for the entire study areas served by the rural telephone companies in Alabama listed in Exhibit 18. 39. RCC. We designate RCC as an ETC in the requested areas served by the non-rural telephone companies in Alabama listed in Exhibit 19. We designate RCC as an ETC for the entire study areas served by the rural telephone companies in Alabama listed in Exhibit 20. 40. SouthernLINC. We designate SouthernLINC as an ETC in the requested service areas in Alabama served by the non-rural telephone companies listed in Exhibit 21. We designate SouthernLINC as an ETC in the entire study areas served by the rural telephone companies in Alabama listed in Exhibit 22.56 41. St. Lawrence Seaway. We designate St. Lawrence Seaway as an ETC in the requested areas served by the non-rural telephone companies in New York listed in Exhibit 23. We designate St. Lawrence Seaway as an ETC for the entire study areas served by the rural telephone companies in New York listed in Exhibit 24. 42. SunCom. We designate SunCom as an ETC in the requested areas served by the non- rural telephone companies in North Carolina, Tennessee, and Virginia listed in Exhibit 25. We designate SunCom as an ETC for the entire study areas served by the rural telephone companies in North Carolina, Tennessee, and Virginia listed in Exhibit 26. 43. U.S. Cellular. We designate U.S. Cellular as an ETC in the requested areas served by the non-rural telephone companies in North Carolina, New Hampshire, Tennessee, and Virginia listed in Exhibit 27.57 We designate U.S. Cellular as an ETC for the entire study areas served by the rural telephone companies in North Carolina, New Hampshire, Tennessee, and Virginia listed in Exhibit 28.58 56 SouthernLINC requested designation for one wire center, West Point, which extends beyond the state boundary of Alabama into Georgia. See SouthernLINC December 29 Alabama Supplement at Ex. 1. As discussed above, the Commission does not have the authority to consider the SouthernLINC Georgia Petition. See infra para. 9. Therefore, we designate SouthernLINC in the West Point wire center only to the extent that the wire center is contained within the boundaries of the state of Alabama. See Western Wireless 2001 Order, 16 FCC Rcd at 19147- 49, paras. 8-13, affirming Western Wireless 2000 Order, 16 FCC Rcd at 57-59, paras. 23-24. 57 As noted above, we exclude the wire centers of the non-rural incumbent LEC Verizon New England in Vermont for purposes of U.S. Cellular’s ETC designation. See supra note 30. 58 As noted above, we exclude the wire centers of rural incumbent LEC Northland Telephone of Maine Inc. in Maine for purposes of U.S. Cellular’s ETC designation. See supra note 30. Federal Communications Commission FCC 08-122 34 Subject to the agreement of the New Hampshire Public Utilities Commission, North Carolina Utilities Commission, Tennessee Regulatory Authority, and Virginia Corporation Commission on our proposed redefinition of service areas, if not previously redefined,59 we also designate U.S. Cellular as an ETC for the wire centers listed in Exhibit 29. 44. Petitioners’ ETC designations are effective thirty days after publication of this Order in the Federal Register, except where redefined service areas require the agreement of a state commission. Where redefined service areas require the agreement of a state commission, Petitioners’ ETC designations are effective upon the effective date of the agreement of the relevant state commission with our redefinition of the service area, but in no event prior to the effective date of this order. We also note that a newly designated ETC shall be eligible to receive support as of the effective date of its designation as an ETC provided it submits the data required by sections 54.307, 54.313, and 54.314, as applicable, of our rules within 60 days of the effective date.60 Therefore, if Petitioners file the required data within the 60- day period, they will receive support as of the effective date of their designations. F. Regulatory Oversight 45. Petitioners are required under section 254(e) of the Act to use high-cost support “only for the provision, maintenance, and upgrading of facilities and services for which the support is intended” and must, under sections 54.313 and 54.314 of the Commission’s rules, certify annually that they are in compliance with this requirement.61 In addition, Petitioners must report certain information to the Commission and the Universal Service Administrative Company (USAC) for the areas in which they are designated as ETCs pursuant to section 54.209 of our rules.62 46. We find that reliance on Petitioners’ commitments to meet these requirements is reasonable and consistent with the public interest, the Act, and the Fifth Circuit decision in Texas Office of Public Utility Counsel v. FCC.63 We conclude that these additional certification and reporting requirements will further the Commission’s goal of ensuring that Petitioners satisfy their obligation under section 214(e) of the Act to provide supported services throughout their designated service areas. 47. We note that the Commission may institute an inquiry on its own motion to examine any ETC’s records and documentation to ensure that the high-cost support it receives is being used “only for the provision, maintenance, and upgrading of facilities and services” in the areas where it is designated as 59 See supra para. 28. 60 See 47 C.F.R. §§ 54.307, 54.313, 54.314; ETC Designation Order, 20 FCC Rcd at 6411, para. 92. 61 47 U.S.C. § 254(e); 47 C.F.R. §§ 54.313, 54.314. 62 See 47 C.F.R. § 54.209(a) (specifying the information to be included in the annual reports submitted by ETCs); ETC Designation Order, 20 FCC Rcd at 6400-6402, paras. 68-69. See also Virginia Cellular Order, 19 FCC Rcd at 1584, para. 46 & n.140 (anticipating that annual submissions will encompass only the ETC’s designated service areas). We note that SouthernLINC requested that, if the Commission were to grant its petition prior to October 1, 2006, it be granted a waiver of the October 1, 2006 filing deadline. See Letter from Todd Daubert, Counsel for SouthernLINC, to Marlene H. Dortch, Secretary, FCC, CC Docket No. 96-45 (filed Aug. 15, 2006). Given the passage of time, we find that SouthernLINC’s waiver request is moot. 63 See generally Petitions. In TOPUC, the Fifth Circuit held that that nothing in section 214(e)(2) of the Act prohibits states from imposing additional eligibility conditions on ETCs as part of their designation process. See Texas Office of Public Utility Counsel v. FCC, 183 F.3d 393, 417-18 (5th Cir. 1999) (TOPUC). Consistent with this holding, we find that nothing in section 214(e)(6) prohibits the Commission from imposing additional conditions on ETCs when such designations fall under our jurisdiction. Federal Communications Commission FCC 08-122 35 an ETC.64 Petitioners will be required to provide such records and documentation to the Commission and USAC upon request. We further emphasize that if a Petitioner fails to fulfill the requirements of the statute, our rules, or the terms of this Order after it begins receiving universal service support, the Commission has authority to revoke its ETC designation.65 The Commission also may assess forfeitures for violations of Commission rules and orders.66 IV. ANTI-DRUG ABUSE ACT CERTIFICATION 48. Pursuant to section 5301 of the Anti-Drug Abuse Act of 1988, no applicant is eligible for any new, modified, or renewed instrument of authorization from the Commission, including authorizations issued pursuant to section 214 of the Act, unless the applicant certifies that neither it, nor any party to its application, is subject to a denial of federal benefits, including Commission benefits.67 Petitioners have provided a certification consistent with the requirements of the Anti-Drug Abuse Act of 1988.68 We find that Petitioners have satisfied the requirements of the Anti-Drug Abuse Act of 1988, as codified in sections 1.2001-1.2003 of the Commission’s rules.69 64 47 U.S.C. §§ 220, 403. 65 See Federal-State Joint Board on Universal Service, Western Wireless Corporation Petition for Preemption of an Order of the South Dakota Public Utilities Commission, CC Docket No. 96-45, Declaratory Ruling, 15 FCC Rcd, 15168, 15174, para. 15 (2000) (subsequent history omitted). See also 47 U.S.C. § 254(e). 66 See 47 U.S.C. § 503(b). 67 21 U.S.C. § 862; 47 C.F.R. § 1.2002(a)-(b). Section 1.2002(b) provides that a “party to the application” shall include: “(1) If the applicant is an individual, that individual; (2) If the applicant is a corporation or unincorporated association, all officers, directors, or persons holding 5% or more of the outstanding stock or shares (voting and/or nonvoting) of the petitioner; and (3) If the application is a partnership, all non-limited partners and any limited partners holding a 5% or more interest in the partnership.” 47 C.F.R. § 1.2002(b). See Section 214(e)(6) Public Notice, 12 FCC Rcd at 22949. 68 See generally Petitions. 69 47 C.F.R. §§ 1.2001-1.2003. Federal Communications Commission FCC 08-122 36 EXHIBIT 1 PENDING ETC DESIGNATION PETITIONS Alltel Communications, Inc. Alabama Petition Alltel Communications, Inc. Petition for Designation as an Eligible Telecommunications Carrier in the State of Alabama, CC Docket No. 96-45 (filed Oct.13, 2005) (Alltel Alabama Petition) (redacted). Alltel Communications, Inc. North Carolina Petition Alltel Communications, Inc. Petition for Designation as an Eligible Telecommunications Carrier in the State of North Carolina, CC Docket No. 96-45 (filed Oct. 13, 2005) (Alltel North Carolina Petition) (redacted). Alltel Communications, Inc. Virginia Petition Alltel Communications, Inc. Petition for Designation as an Eligible Telecommunications Carrier in the Commonwealth of Virginia, CC Docket No. 96-45 (filed Oct. 13, 2005) (Alltel Virginia Petition) (redacted). Choice Communications LLC U.S. Virgin Islands Petition Choice Communications LLC, Petition for Designation as an Eligible Telecommunications Carrier in the United States Virgin Islands, CC Docket No. 96-45 (filed Jan. 13, 2005) (Choice Petition) (redacted). Letter from Jennifer M. Kashatus, Counsel for Choice, to Marlene H. Dortch, Secretary, Federal Communications Commission, CC Docket No. 96-45 (filed Feb. 9, 2005) (Choice Supplement) (submitting additional information in support of its petition). Letter from Jennifer M. Kashatus, Counsel for Choice, to Marlene H. Dortch, Secretary, Federal Communications Commission, CC Docket No. 96-45 (filed Mar. 16, 2005) (Choice Second Supplement) (submitting maps of Choice’s coverage area) (redacted). Letter from Jennifer M. Kashatus, Counsel for Choice, to Marlene Dortch, Secretary, Federal Communications Commission, CC Docket No. 96-45 (filed May 15, 2007) (Choice Third Supplement) (submitting a list of Choice’s MMDS licenses and maps of its service area) (redacted). Letter from Jennifer M. Kashatus, Counsel for Choice, to Marlene Dortch, Secretary, Federal Communications Commission, CC Docket No. 96-45 (filed Sept. 24, 2007) (Choice Fourth Supplement) (submitting additional information on Choice’s service offerings). Cingular Alabama Petition Petition of AT&T Wireless Services, Inc. for Designation as an Eligible Telecommunications Carrier Pursuant to Section 214(e)(6) of the Communications Act, Petition of AT&T Wireless Services, Inc. for Designation as an Eligible Telecommunications Carrier in the State of Alabama, CC Docket No. 96-45 (filed Dec. 31, 2003) (AWS Alabama Petition) (redacted). Federal Communications Commission FCC 08-122 37 Supplement to the Petition of AT&T Wireless Services, Inc. for Designation as an Eligible Telecommunications Carrier Pursuant to Section 214(e)(6) of the Communications Act, Petition of AT&T Wireless Services, Inc. for Designation as an Eligible Telecommunications Carrier in the state of Alabama, CC Docket No. 96-45 (filed May 11, 2004) (AWS Alabama Supplement). Amendment to the Petition of AT&T Wireless Services, Inc. for Designation as an Eligible Telecommunications Carrier in the State of Alabama, CC Docket No. 96-45 (filed Feb. 23, 2006) (Cingular Alabama Amendment) (redacted). Minor Further Amendment to ETC Petition: Cingular Wireless LLC (f/k/a AT&T Wireless Services, Inc.), CC Docket No. 96-45 (filed April 28, 2006) (explaining that the request includes the Livingston wire center in the BellSouth SAC (255181) with whichever CLLI Code is applicable, noting that currently the Local Exchange Routing Guide and the Universal Service Administrative Company use different CLLI codes – LVTNALMA and LVTNALLA). Cingular Virginia Petition Cingular Wireless, LLC Petition for Designation as an Eligible Telecommunications Carrier in the Commonwealth of Virginia, CC Docket No. 96-45 (filed Nov. 7, 2006) (Cingular Virginia Petition) (redacted). Letter from Russell P. Hanser, Counsel for Cingular, to Marlene H. Dortch, Secretary, Federal Communications Commission, CC Docket No. 96-45 (filed Sept. 4, 2007) (submitting maps of Cingular’s coverage area) (redacted). Corr Wireless Communications, LLC Alabama Petition Corr Wireless Communications, LLC Petition for Designation as an Eligible Telecommunications Carrier in the State of Alabama, CC Docket No. 96-45 (filed June 14, 2007) (Corr Petition). Dobson Cellular Systems, Inc. New York Petition Dobson Cellular Systems, Inc. and American Cellular Corp. (Dobson) Joint Petition for Designation as Eligible Telecommunications Carriers in the State of New York (No Rural Redefinition Requested), CC Docket No. 96-45 (filed May 3, 2004) (Dobson First Petition). Dobson Cellular Systems, Inc. and American Cellular Corp. Joint Petition for Designation as Eligible Telecommunications Carriers in the State of New York (Rural Redefinition Requested), CC Docket No. 96-45 (filed May 10, 2004) (Dobson Redefinition Petition). Amendment of ETC Petition – Dobson Cellular Systems Inc. and American Cellular Corporation, New York, CC Docket No. 96-45 (filed Sept. 16, 2005) (Dobson Exhibit E (revised)) (correcting a wire center study area code). Second Amendment of ETC Petition – Dobson, New York, CC Docket No. 96-45 (filed Oct. 11, 2005) (Dobson Second Amendment) (filing a revised list of rural wire centers that corrects some slight errors in population data and makes alternative proposals about service area boundaries). Federal Communications Commission FCC 08-122 38 Farmers Cellular Alabama Petition Farmers Cellular Petition to Amend the Designated Service Area of Farmers Cellular Telephone, Inc., CC Docket No. 96-45 (filed Dec. 1, 2005) (seeking to amend its designated area to include additional wire centers in the state of Alabama) (Farmers Petition). Letter from Gary Kirk, General Manager for Farmers, to Marlene H. Dortch, Secretary, Federal Communications Commission, CC Docket No. 96-45 (filed Dec. 2, 2005) (submitting a chart and maps in support of Farmers’ five-year plan) (redacted). Supplement to Farmers Cellular Petition to Amend the Designated Service Area of Farmers Cellular Telephone, Inc., CC Docket No. 96-45 (filed Feb. 2, 2007) (Farmers February 2 Supplement). NEP Cellcorp, Inc. Pennsylvania Petition Petition of NEP Cellcorp, Inc. to be Designated as an Eligible Telecommunications Carrier in the Commonwealth of Pennsylvania, CC Docket No. 96-45 (filed June 7, 2007) (NEP Petition). New York RSA 2 Cellular Partnership New York Petition New York RSA 2 Cellular Partnership Petition for Designation as an Eligible Telecommunications Carrier in the State of New York, CC Docket No. 96-45 (filed June 23, 2005) (NY RSA 2 Petition). New York RSA 2 Cellular Partnership, Supplement for Designation as an Eligible Telecommunications Carrier in the State of New York, CC Docket No. 96-45 (filed July 19, 2005) (NY RSA 2 July 19 Supplement). Pine Belt Cellular, Inc. Alabama Petition Pine Belt Cellular, Inc. Petition for Designation as an Eligible Telecommunications Carrier in the State of Alabama, CC Docket No. 96-45 (filed Mar. 2, 2006) (Pine Belt Petition) (redacted). RCC Minnesota, Inc. Alabama Petition RCC Holdings, Inc. Petition for Designation as an Eligible Telecommunications Carrier in Additional Portions of the State of Alabama, CC Docket No. 96-45 (filed June 23, 2005) (RCC Petition) (seeking to extend its ETC designation in Alabama to include newly acquired portions of its service area). Letter from B. Lynn F. Ratnavale, Counsel for RCC Minnesota, Inc., to Marlene H. Dortch, Secretary, Federal Communications Commission, CC Docket No. 96-45 (filed Mar. 2, 2007) (notice of name change from RCC Holdings, Inc. to RCC Minnesota, Inc., and supplemental maps and licensing information). SouthernLINC Alabama Petitions Petition of Southern Communications Services, Inc. d/b/a SouthernLINC Wireless for Designation as an Eligible Telecommunications Carrier in Alabama, CC Docket No. 96-45 (filed Sep. 14, 2004) (SouthernLINC Non-Rural Alabama Petition). Petition of Southern Communications Services, Inc. d/b/a SouthernLINC for Designation as an Eligible Telecommunications Carrier in Alabama, CC Docket No. 96-45 (filed Sep. 14, 2004) (SouthernLINC Rural Alabama Petition). Federal Communications Commission FCC 08-122 39 Letter from Erin W. Emmott, Counsel for SouthernLINC, to Marlene H. Dortch, Secretary, Federal Communications Commission, CC Docket No. 96-45 (filed Jan. 12, 2005) (January 12 Non-rural Alabama Supplement). Letter from Erin W. Emmott, Counsel for SouthernLINC, to Marlene H. Dortch, Secretary, Federal Communications Commission, CC Docket No. 96-45 (filed Jan. 12, 2005) (January 12 Rural Alabama Supplement). Letter from Erin W. Emmott, Counsel for SouthernLINC, to Marlene H. Dortch, Secretary, Federal Communications Commission, CC Docket No. 96-45 (filed Jan. 21, 2005) (January 21 Non-Rural Alabama Supplement). Letter from Erin W. Emmott, Counsel for SouthernLINC, to Marlene H. Dortch, Secretary, Federal Communications Commission, CC Docket No. 96-45 (filed Jan. 21, 2005) (January 21 Rural Alabama Supplement). Letter from Erin W. Emmott, Counsel for SouthernLINC Wireless, to Marlene H. Dortch, Secretary, Federal Communications Commission, CC Docket No. 96-45 (filed Mar. 2, 2005) (March 2 Alabama Supplement). Letter from Erin W. Emmott, Counsel for SouthernLINC Wireless, to Marlene H. Dortch, Secretary, Federal Communications Commission, CC Docket No. 96-45 (filed Nov. 16, 2005) (November 16 Supplement) (replacing January 21 Rural Alabama Supplement and March 2 Alabama Supplement) (noting also that the company had changed its name to “SouthernLINC Wireless”). Letter from Erin W. Emmott, Counsel for SouthernLINC Wireless, to Marlene H. Dortch, Secretary, Federal Communications Commission, CC Docket No. 96-45 (filed Dec. 29, 2005) (December 29 Alabama Supplement). Letter from Robert G. Dawson, SouthernLINC Wireless, to Kevin J. Martin, Chairman, Federal Communications Commission, CC Docket No. 96-45 (filed June 29, 2006) (June 29 Supplement). SouthernLINC Florida Petition Petition of Southern Communications Services, Inc. d/b/a SouthernLINC for Designation as an Eligible Telecommunications Carrier Pursuant to Section 214(e)(6) of the Communications Act, CC Docket No. 96-45 (filed Sep. 14, 2004) (SouthernLINC Florida Petition). Letter from Erin W. Emmett, Counsel for SouthernLINC, to Marlene H. Dortch, Secretary, Federal Communications Commission, CC Docket No. 96-45 (filed Jan. 12, 2005) (January 12 Florida Supplement). Letter from Erin W. Emmett, Counsel for SouthernLINC, to Marlene H. Dortch, Secretary, Federal Communications Commission, CC Docket No. 96-45 (filed Jan. 21, 2005) (January 21 Florida Supplement). Letter from Erin W. Emmett, Counsel for SouthernLINC, to Marlene H. Dortch, Secretary, Federal Communications Commission, CC Docket No. 96-45 (filed Feb. 22, 2005) (February Florida Supplement). Federal Communications Commission FCC 08-122 40 Letter from Erin W. Emmett, Counsel for SouthernLINC Wireless, to Marlene H. Dortch, Secretary, Federal Communications Commission, CC Docket No. 96-45 (filed Nov. 16, 2005) (November Florida Supplement) (noting that the company had changed its name to “SouthernLINC Wireless”). Letter from Erin W. Emmett, Counsel for SouthernLINC Wireless, to Marlene H. Dortch, Secretary, Federal Communications Commission, CC Docket No. 96-45 (filed Dec. 29, 2005) (December Florida Supplement). Letter from Robert G. Dawson, SouthernLINC Wireless, to Kevin J. Martin, Chairman, Federal Communications Commission, CC Docket No. 96-45 (filed June 29, 2006) (June 29 Supplement). SouthernLINC Georgia Petitions Petition of Southern Communications Services, Inc. d/b/a SouthernLINC for Designation as an Eligible Telecommunications Carrier Pursuant to Section 214(e)(6) of the Communications Act, CC Docket No. 96-45 (filed Sep. 14, 2004) (SouthernLINC Non-Rural Georgia Petition). Petition of Southern Communications Services, Inc. d/b/a SouthernLINC for Designation as an Eligible Telecommunications Carrier Pursuant to Section 214(e)(6) of the Communications Act, CC Docket No. 96-45 (filed Sep. 14, 2004) (SouthernLINC Rural Georgia Petition). Letter from Erin W. Emmott, Counsel for SouthernLINC, to Marlene H. Dortch, Secretary, Federal Communications Commission, CC Docket No. 96-45 (filed Jan. 12, 2005) (January 12 Non-Rural Georgia Supplement). Letter from Erin W. Emmott, Counsel for SouthernLINC, to Marlene H. Dortch, Secretary, Federal Communications Commission Petition, CC Docket No. 96-45 (filed Jan.12, 2005) (January 12 Rural Georgia Supplement). Letter from Erin W. Emmott, Counsel for SouthernLINC, to Marlene H. Dortch, Secretary, Federal Communications Commission, CC Docket No. 96-45 (filed Jan. 21, 2005) (January 21 Georgia Supplement). Letter from Erin W. Emmott, Counsel for SouthernLINC, to Marlene H. Dortch, Secretary, Federal Communications Commission, CC Docket No. 96-45 (filed Mar. 2, 2005) (March 2 Georgia Supplement). Letter from Erin W. Emmott, Counsel for SouthernLINC, to Marlene H. Dortch, Secretary, Federal Communications Commission, CC Docket No. 96-45 (filed Nov. 16, 2005) (November Georgia Supplement) (noting that the company had changed its name to “SouthernLINC Wireless”). Letter from Erin W. Emmott, Counsel for SouthernLINC, to Marlene H. Dortch, Secretary, Federal Communications Commission, CC Docket No. 96-45 (filed Dec. 29, 2005) (December 29 Georgia Supplement). Letter from Robert G. Dawson, SouthernLINC Wireless, to Kevin J. Martin, Chairman, Federal Communications Commission, CC Docket No. 96-45 (filed June 29, 2006) (June 29 Supplement). Federal Communications Commission FCC 08-122 41 St. Lawrence Seaway Cellular Partnership New York Petition St. Lawrence Seaway Cellular Partnership Petition for Designation as an Eligible Telecommunications Carrier in the State of New York, CC Docket No. 96-45 (filed June 23, 2005) (St. Lawrence Seaway Petition). Supplement to Petition for Designation as an Eligible Telecommunications Carrier in the State of New York, CC Docket No. 96-45 (filed July 19, 2005) (St. Lawrence Seaway July 19 Supplement). SunCom Wireless, Inc. Petition SunCom Wireless, Inc. Petition for Designation as an Eligible Telecommunications Carrier in Georgia, North Carolina, Tennessee and Virginia, CC Docket No. 96-45 (filed June 23, 2005) (SunCom Petition). Letter from David L. Sieradzki, Counsel for SunCom, to Marlene Dortch, Secretary, Federal Communications Commission. CC Docket No. 96-45 (filed May 4, 2007) (submitting call signs and maps of its license area). Letter from David L. Sieradzki, Counsel for SunCom, to Marlene Dortch, Secretary, Federal Communications Commission, CC Docket No. 96-45 (filed Nov. 2, 2007) (submitting a list of wire centers and CLLI codes for which SunCom is seeking designation). Letter from David L. Sieradzki, Counsel for SunCom, to Marlene Dortch, Secretary, Federal Communications Commission, CC Docket No. 96-45 (filed Dec. 14, 2007) (withdrawing SunCom’s petition for ETC designation in Georgia and withdrawing requests for designation in two study areas). Letter from David L. Sieradzki, Counsel to SunCom, to Marlene H. Dortch, Secretary, Federal Communications Commission, CC Docket No. 96-45 (filed Jan. 2, 2008) (clarifying the CLLI code for the Hartford wire center in North Carolina). U.S. Cellular New Hampshire Petition U.S. Cellular Petition for Designation as an Eligible Telecommunications Carrier in the State of New Hampshire, CC Docket No. 96-45 (filed April 13, 2004) (U.S. Cellular New Hampshire Petition). Letter from David A. LaFuria, Counsel for U.S. Cellular, to Marlene H. Dortch, Secretary, Federal Communications Commission, CC Docket No. 96-45 (filed Nov. 4, 2005) (U.S. Cellular New Hampshire Amendment) (amending its New Hampshire petition to demonstrate compliance with the Virginia Cellular Order and the Highland Cellular Order). U.S. Cellular New Hampshire Amendment Erratum, CC Docket No. 96-45 (filed Nov. 7, 2005) (correcting a footnote). U.S. Cellular North Carolina Petition U.S. Cellular Petition for Designation as an Eligible Telecommunications Carrier in the State of North Carolina, CC Docket No. 96-45 (filed Oct. 14, 2004) (U.S. Cellular North Carolina Petition). Letter from David A. LaFuria, Counsel for U.S. Cellular, to Marlene H. Dortch, Secretary, Federal Communications Commission, CC Docket No. 96-45 (filed Nov. 4, 2005) (U.S. Cellular North Carolina Amendment) (amending its North Carolina petition to demonstrate compliance with the Virginia Cellular Order and the Highland Cellular Order, and, for each partial wire center listed in the original North Federal Communications Commission FCC 08-122 42 Carolina Petition, either withdrawing the request or committing to serve the entire wire center through a combination of its own facilities and resale or roaming). U.S. Cellular North Carolina Amendment Erratum, CC Docket No. 96-45 (filed Nov. 7, 2005) (correcting a footnote and the signature block). U.S. Cellular North Carolina Amendment Second Erratum, CC Docket No. 96-45 (filed Nov. 15, 2005) (correcting certain discrepancies between the list of requested wire centers and the population density analysis in the revised Exhibits D and I (hereinafter “Corrected Revised Exhibit D” and “Corrected Revised Exhibit I”)). U.S. Cellular Tennessee Petition Tennessee RSA No. 3 Limited Partnership d/b/a Eloqui Wireless, Petition for Designation as an Eligible Telecommunications Carrier in the State of Tennessee, CC Docket No. 96-45 (filed June 23, 2005) (Eloqui Petition). U.S. Cellular Corp. Amended Petition for Designation as an Eligible Telecommunications Carrier in Additional Areas in the State of Tennessee, CC Docket No. 96-45 (filed Sept. 7, 2007) (noting that U.S. Cellular now controls Eloqui, and extending its proposed ETC service area to include additional territory within U.S. Cellular’s FCC-licensed service area in Tennessee) (U.S. Cellular Tennessee Amended Petition). U.S. Cellular Corp. Supplement to Amended Petition for Designation as an Eligible Telecommunications Carrier in Areas in the State of Tennessee, CC Docket No. 96-45 (filed Nov. 6, 2007) (submitting maps of combined licensed service areas of U.S. Cellular in Tennessee). U.S. Cellular Virginia Petition U.S. Cellular Petition for Designation as an Eligible Telecommunications Carrier in the Commonwealth of Virginia, CC Docket No. 96-45 (filed April 9, 2004) (U.S. Cellular Virginia Petition). Letter from David A. LaFuria, Counsel for U.S. Cellular, to Marlene H. Dortch, Secretary, Federal Communications Commission, CC Docket No. 96-45 (filed Nov. 4, 2005) (U.S. Cellular Virginia Amendment) (amending its Virginia petition to demonstrate compliance with the Virginia Cellular Order and the Highland Cellular Order). Letter from David LaFuria, Counsel for U.S. Cellular, to Marlene H. Dortch, Secretary, Federal Communications Commission, CC Docket No. 96-45 (filed June 14, 2006) (U.S. Cellular Virginia Second Amendment) (amending its Virginia petition to withdraw certain wire centers from the proposed ETC service area in the Central Telephone Co.-VA and Verizon South-VA study areas; in the alternative, removal of certain wire centers in the Verizon South-VA study area and removal of the Collinsville (COLLINSVL) wire center in the Central Telephone Co.-VA study area). Letter from David LaFuria, Counsel for U.S. Cellular, to Marlene H. Dortch, Secretary, Federal Communications Commission, CC Docket No. 96-45, (filed July 28, 2006) (U.S. Cellular Virginia Third Amendment) (amending its Virginia petition to withdraw the Alta Vista (ALTVVAXA) and Buena Vista (BNVSVAXA) wire centers and to include the Brownsburg (BRBGVAXA) and Virgilina (VRGLVAXA) wire centers in its proposed service area for Central Telephone Co.-VA). Federal Communications Commission FCC 08-122 43 EXHIBIT 2 Rural Wire Centers for Inclusion in Alltel’s ETC Service Area Alabama: LEC NAME WIRE CENTER CLLI Castleberry Telephone Co. Inc. CASTLEBERRY CSTLALXA Frontier Communications of AL BEATRICE BTRCALXA Frontier Communications of AL MONROEVILLE EXCLALXA Frontier Communications of AL FINCHBERG FNBGALXA Frontier Communications of AL FRISCO CITY FRCYALXA Frontier Communications of AL GOSPORT GSPTALXA Frontier Communications of AL MONROEVILLE MOVLALXA Frontier Communications of AL PINE APPLE PNAPALXA Frontier Communications of AL PETERMAN PTMNALXA Frontier Communications of AL REPTON RPTNALXA Frontier Communications of AL URIAH URIHALXA Gulf Telephone Co. BON SECOUR BNSCALXA Gulf Telephone Co. ELBERTA ELBTALXA Gulf Telephone Co. ELBERTA ELBTALXB Gulf Telephone Co. FOLEY FOLYALXA Gulf Telephone Co. FOLEY FOLYALXB Gulf Telephone Co. FORT MORGAN FTMRALXA Gulf Telephone Co. GULF SHORES GLSHALXA Gulf Telephone Co. GULF SHRS GLSHALXB Gulf Telephone Co. LILLIAN LLLNALXA Gulf Telephone Co. ELBERTA LLLNALXB Gulf Telephone Co. LOXLEY LXLYALXA Gulf Telephone Co. LOXLEY LXLYALXB Gulf Telephone Co. FOLEY MGSPALXA Gulf Telephone Co. SUMMERDALE MRLWALXA Gulf Telephone Co. ORANGE BEACH ORBHALXA Gulf Telephone Co. ORANGE BCH ORBHALXC Gulf Telephone Co. ROBERTSDALE RBDLALXA Gulf Telephone Co. SILVERHILL RBDLALXB Gulf Telephone Co. SEMINOLE SMNLALXA Gulf Telephone Co. ROBERTSDALE SMNLALXB Gulf Telephone Co. SUMMERDALE SRDLALXA Hayneville Telephone Co. Inc. GORDONSVILLE GOVLALXA Hayneville Telephone Co. Inc. HAYNEVILLE HYVLALXA Hayneville Telephone Co. Inc. LOWNDESBORO LWBOALXA Mon – Cre Telephone Cooperative RAMER RAMRALXA Union Springs Telephone Co. Inc. FORT DAVIS FTDVALXA Union Springs Telephone Co. Inc. MIDWAY MDWYALXA Union Springs Telephone Co. Inc. PEROTE PROTALXA Union Springs Telephone Co. Inc. UN SPGS UNSPALXA Federal Communications Commission FCC 08-122 44 North Carolina: LEC NAME WIRE CENTER CLLI CODE Atlantic Telephone Membership Co BOLIVIA BOLVNCXA Atlantic Telephone Membership Co BOILING SPRING LAKES BSLKNCXA Atlantic Telephone Membership Co SUPPLY HLBHNCXB Atlantic Telephone Membership Co LONGWOOD LGWDNCXA Atlantic Telephone Membership Co OCEAN IS BEACH SESDNCXB Atlantic Telephone Membership Co SHALLOTTE SHLTNCXA Concord Telephone Co. ALBEMARLE ALBMNCXA Concord Telephone Co. BADIN BADNNCXA Concord Telephone Co. CHINA GROVE CHGVNCXA Concord Telephone Co. CONCORD CNCRNCXA Concord Telephone Co. HARRISBURG HRBGNCXA Concord Telephone Co. KANNAPOLIS KNPLNCXA Concord Telephone Co. MT PLEASANT MNPLNCXA Concord Telephone Co. NEW LONDON NWLNNCXA Concord Telephone Co. OAKBORO OKBONCXA Ellerbe Telephone Co. Inc. ELLERBE ELRBNCXA Lexcom Telephone Company LEXINGTON LXTNNCXA Lexcom Telephone Company LEXINGTON LXTNNCXB Lexcom Telephone Company LEXINGTON LXTNNCXC Lexcom Telephone Company LEXINGTON LXTNNCXD Lexcom Telephone Company LEXINGTON LXTNNCXE Lexcom Telephone Company SOUTHMONT SMNTNCXA Lexcom Telephone Company WELCOME WLCMNCXA Mebtel Inc. MEBANE MEBNNCXA Piedmont Telephone Membership Co CHURCHLAND CHLDNCXA Piedmont Telephone Membership Co LEXINGTON REDSNCXA Pineville Telephone Co. PINEVILLE PIVLNCXB Randolph Telephone Co. LIBERTY LBRTNCXA Randolph Telephone Membership Co. BADIN LAKE BDLKNCXA Randolph Telephone Membership Co. BENNETT BNNTNCXA Randolph Telephone Membership Co. COLERIDGE CLRGNCXA Randolph Telephone Membership Co. FARMER FRMRNCXA Randolph Telephone Membership Co. HIGHFALLS HGHFNCXA Randolph Telephone Membership Co. JACKSON CREEK JKCKNCXA Randolph Telephone Membership Co. ASHEBORO PSGHNCXA Service Telephone Co. FAIR BLUFF FRBLNCXA Star Telephone Membership Corp. BLADENBORO ABBGNCXA Star Telephone Membership Corp. DUNN COHRNCXA Star Telephone Membership Corp. GARLAND CYCKNCXA Star Telephone Membership Corp. HARRELLS HRLSNCXA Star Telephone Membership Corp. CLINTON HRNGNCXA Star Telephone Membership Corp. KELLY KLLYNCXA Star Telephone Membership Corp. LISBON LSBNNCXA Star Telephone Membership Corp. ROSEBORO SORVNCXA Star Telephone Membership Corp. TURKEY SXRNNCXA Federal Communications Commission FCC 08-122 45 LEC NAME WIRE CENTER CLLI CODE Star Telephone Membership Corp. WHITE OAK WHOKNCXA Tri-County Telephone Membership PANTEGO PKRDNCXA Tri-County Telephone Membership PINETOWN PNTWNCXA Tri-County Telephone Membership BATH SDNYNCXA Yadkin Valley Telephone Membership ADVANCE ADVNNCXA Yadkin Valley Telephone Membership HAMPTONVILLE BRKSNCXA Yadkin Valley Telephone Membership COOLEEMEE COLMNCXA Yadkin Valley Telephone Membership YADKINVILLE CRTYNCXA Yadkin Valley Telephone Membership EAST BEND EBNDNCXA Yadkin Valley Telephone Membership FORBUSH FRBSNCXB Yadkin Valley Telephone Membership HARMONY HRMYNCXA Yadkin Valley Telephone Membership MOCKSVILLE IJAMNCXA Yadkin Valley Telephone Membership UNION GROVE UNGVNCXB Yadkin Valley Telephone Membership NEW HOPE NWHPNCXA Virginia: LEC NAME WIRE CENTER CLLI CODE Buggs Island Telephone Coop LA CROSSE BCRGVAXA Buggs Island Telephone Coop BAKERVILLE BCWDVAXA Burkes Garden Telephone Co. Inc BURKES GARDEN BRGRVAXA New Hope Telephone Co. FT DEFIANCE NWHPVAXA Peoples Mutual Telephone Co. GRETNA GRETVAXA Peoples Mutual Telephone Co. HURT HURTVAXA Peoples Mutual Telephone Co. RENAN RENNVAXA Peoples Mutual Telephone Co. SANDY LEVEL SNLVVAXA Scott County Telephone Coop CLINCHPORT CLPTVAXA Scott County Telephone Coop DUFFIELD DFFDVAXA Scott County Telephone Coop DUNGANNON DNGNVAXA Scott County Telephone Coop FORT BLACKMORE FTBCVAXA Scott County Telephone Coop NICKELSVILLE NCVLVAXA Scott County Telephone Coop WILLIAMS MILL WLMLVAXA EXHIBIT 3 Rural Service Areas Previously Reclassified Along Wire Center Boundaries For Inclusion In Alltel’s ETC Service Area Alabama: LEC NAME WIRE CENTER CLLI Alltel Alabama Inc. ECLECTIC ECLCALXA Alltel Alabama Inc. ECLECTIC KWLGALXA Millry Telephone Co. CHATOM CHTMALXA Federal Communications Commission FCC 08-122 46 North Carolina: LEC NAME WIRE CENTER CLLI Central Telephone Co. – North Carolina ASHEBORO ASBONCXA Central Telephone Co. – North Carolina ASHEBORO ASBONCXB Central Telephone Co. – North Carolina HICKORY BHLHNCXA Central Telephone Co. – North Carolina BISCOE BISCNCXA Central Telephone Co. – North Carolina BOONVILLE BNVLNCXA Central Telephone Co. – North Carolina CANDOR CNDRNCXA Central Telephone Co. – North Carolina CATAWBA CTWBNCXA Central Telephone Co. – North Carolina EDEN EDENNCXA Central Telephone Co. – North Carolina EDEN EDENNCXB Central Telephone Co. – North Carolina ELKIN ELKNNCXA Central Telephone Co. – North Carolina GRANITE FALLS GRFLNCXA Central Telephone Co. – North Carolina HICKORY HCKRNCXA Central Telephone Co. – North Carolina HICKORY HCKRNCXB Central Telephone Co. – North Carolina HILLSBOROUGH HLBONCXB Central Telephone Co. – North Carolina HILDEBRAN HLDBNCXB Central Telephone Co. – North Carolina MADISON MDSNNCXA Central Telephone Co. – North Carolina MOCKSVILLE MKVLNCXA Central Telephone Co. – North Carolina MT GILEAD MTGLNCXA Central Telephone Co. – North Carolina HICKORY MTVWNCXA Central Telephone Co. – North Carolina PILOT MT PLMTNCXA Central Telephone Co. – North Carolina PROSPECT HILL PRHLNCXA Central Telephone Co. – North Carolina WALNUT COVE QKGPNCXA Central Telephone Co. – North Carolina RAMSEUR RMSRNCXA Central Telephone Co. – North Carolina ROXBORO RXBONCXA Central Telephone Co. – North Carolina SEAGROVE SEGVNCXA Central Telephone Co. – North Carolina SHERRILLS FORD SHFRNCXA Central Telephone Co. – North Carolina STONEVILLE STVLNCXA Central Telephone Co. – North Carolina ROUGEMONT TMLKNCXA Central Telephone Co. – North Carolina TROY TROYNCXA Central Telephone Co. – North Carolina VALDESE VLDSNCXA Central Telephone Co. – North Carolina W END WENDNCXB Central Telephone Co. – North Carolina WALKERTOWN WKTWNCXA Central Telephone Co. – North Carolina WALNUT COVE WLCVNCXA Central Telephone Co. – North Carolina YANCEYVILLE YCVLNCXA Central Telephone Co. – North Carolina YADKINVILLE YDVLNCXA Surry Telephone Membership Corp. SHOALS SHLSNCXA Federal Communications Commission FCC 08-122 47 EXHIBIT 4 Non-Rural Wire Centers for Inclusion in Cingular’s ETC Service Area Alabama: LEC NAME WIRE CENTER CLLI BellSouth (Study Area Code 255181) ALBERTVILLE-MAIN ALVLALMA BellSouth ANNISTON-LENLOCK ANTNALLE BellSouth ATHENS-ELK RIVER ATHNALER BellSouth ATHENS-MAIN ATHNALMA BellSouth ATTALLA-MAIN ATTLALNM BellSouth BELLE FONTAINE BLFNALMA BellSouth BOAZ-MAIN BOAZALMA BellSouth BREWTON BRTOALMA BellSouth BESSEMER-BUCKSVILLE BSMRALBU BellSouth BAY MINETTE BYMNALMA BellSouth CALERA CALRALMA BellSouth CHELSEA CHLSALMA BellSouth COLUMBIANA CLMBALMA BellSouth CULLMAN-JONES CHAPEL CLMNALJC BellSouth CORDOVA CRDVALMA BellSouth CARBON HILL CRHLALNM BellSouth COURTLAND CRLDALMA BellSouth DORA DORAALMA BellSouth EUTAW-BOLIGEE EUTWALBO BellSouth EVERGREEN EVRGALMA BellSouth FORT DEPOSIT FTDPALMA BellSouth FORT PAYNE-MAIN FTPYALMA BellSouth GADSDEN-HILLSIDE GDSDALHS BellSouth GADSDEN-RAINBOW DRIVE GDSDALRD BellSouth GARDENDALE GRDLALNM BellSouth GURLEY-MAIN GRLYALMA BellSouth GUNTERSVILLE-MAIN GTVLALNM BellSouth GRAYSVILLE GYVLALNM BellSouth HUNTSVILLE-REDSTONE ARSEN, HNVIALRA BellSouth HANCEVILLE-BREMEN HNVLALBR BellSouth HARTSELLE-MAIN HRTSALNM BellSouth HARTSELLE-PENCE HRTSALPE BellSouth HAZEL GREEN-MAIN HZGRALMA BellSouth JACKSON JCSNALNM BellSouth JACKSONVILLE-MAIN JCVLALMA BellSouth JASPER JSPRALMT BellSouth KILLEN KLLNALMA BellSouth LEIGHTON LGTNALMA BellSouth LIVINGSTON LVTNALMA BellSouth MONTEVALLO MNTVALNM Federal Communications Commission FCC 08-122 48 LEC NAME WIRE CENTER CLLI BellSouth MOBILE-SARALAND MOBLALSA BellSouth MOBILE-SEMMES MOBLALSE BellSouth MOBILE-THEODORE MOBLALTH BellSouth MOULTON MOLTALNM BellSouth MONTGOMERY-MILLBROOK MTGMALMB BellSouth MONTGOMERY-NORMANDALE MTGMALNO BellSouth MT VERNON MTVRALMA BellSouth OHATCHEE-MAIN OHTCALMA BellSouth PIEDMONT-MAIN PDMTALMA BellSouth PINSON PNSNALMA BellSouth PARRISH PRSHALNM BellSouth PRATTVILLE PRVLALMA BellSouth RED BAY RDBAALMA BellSouth RUSSELLVILLE RLVLALMA BellSouth ROGERSVILLE RRVLALMA BellSouth SELMA SELMALMT BellSouth STEVENSON-MAIN STSNALMA BellSouth SYLACAUGA SYLCALMT BellSouth THOMASVILLE THVLALMA BellSouth TALLADEGA-MAIN TLDGALMA BellSouth TUSCALOOSA-NORTHPORT TSCLALNO BellSouth TUSKEGEE TSKGALMA BellSouth TOWN CREEK TWCKALMA BellSouth UNIONTOWN UNTWALNM BellSouth VINCENT VNCNALMA BellSouth WARRIOR WRRRALNM BellSouth WETUMPKA WTMPALMA CenturyTel (Northern) (Study Area Code 259789) BAYOU LA BATRE BLBTALXA CenturyTel (Northern) BRILLIANT BRILALXA CenturyTel (Northern) BERRY BRRYALXA CenturyTel (Northern) CHULAFINNEE CHLFALXA CenturyTel (Northern) CARROLLTON CRTNALXA CenturyTel (Northern) DOUBLE SPRINGS DBSPALXA CenturyTel (Northern) DELTA DELTALXA CenturyTel (Northern) ETHELSVILLE ETVLALXA CenturyTel (Northern) FOWL RIVER FWRVALXA CenturyTel (Northern) GRAND BAY GDBAALXA CenturyTel (Northern) GORDO GORDALXA CenturyTel (Northern) HACKLEBURG HCBGALXA CenturyTel (Northern) HEFLIN HFLNALXA CenturyTel (Northern) HALEYVILLE HLVLALXA CenturyTel (Northern) HAMILTON HMTNALXA CenturyTel (Northern) IRVINGTON IRSEALXA CenturyTel (Northern) LECTA LECTALXA CenturyTel (Northern) LINCOLN LNCLALXA CenturyTel (Northern) MORRISONS XRDC12 MRCRALXA CenturyTel (Northern) PHIL CAMPBELL PHBLALXA CenturyTel (Northern) PELL CITY PLCYALXA Federal Communications Commission FCC 08-122 49 LEC NAME WIRE CENTER CLLI CenturyTel (Northern) THORSBY THRSALXA CenturyTel (Northern) VERNON VERNALXA CenturyTel (Northern) VALLEY HEAD VYHDALXA CenturyTel (Northern) WEDOWEE WEDWALXA CenturyTel (Southern) (Study Area Code 259788) BRUNDIDGE BRNDALXA CenturyTel (Southern) GEORGIANA GRGNALXA CenturyTel (Southern) MIDLAND CITY MLCYALXA CenturyTel (Southern) SCOTTSBORO SCBOALXA CenturyTel (Southern) WICKSBURG WCBGALXA Virginia: LEC NAME WIRE CENTER CLLI Verizon South Inc.-VA (Contel) INDEPENDENT HILL INHLVAXA Verizon South Inc.-VA (Contel) DALE CITY DLCYVAXA Verizon South Inc.-VA (Contel) BOWLING GREEN BWLGVAXA Verizon South Inc.-VA (Contel) COLONIAL BEACH CLBHVAXA Verizon South Inc.-VA (Contel) DAWN DAWNVAXA Verizon South Inc.-VA (Contel) KING GEORGE KGGRVAXA Verizon South Inc.-VA (Contel) KING WILLIAM KGWLVAXA Verizon South Inc.-VA (Contel) LORTON LRTNVAXA Verizon South Inc.-VA (Contel) MANASSAS MNSSVAXA Verizon South Inc.-VA (Contel) OCCOQUAN OCQNVAXA Verizon South Inc.-VA (Contel) TAPPAHANNOCK TPHNVAXA Verizon South Inc.-VA (Contel) WARSAW WRSWVAXA Verizon South Inc.-VA (Contel) BROADWAY BRWYVAXA Verizon South Inc.-VA (Contel) ELKTON EKTNVAXA Verizon South Inc.-VA (Contel) GREAT BRIDGE GRBRVAXA Verizon South Inc.-VA (Contel) BATTLEFIELD GRBRVAXB Verizon South Inc.-VA (Contel) HICKORY HCKRVAXA Verizon South Inc.-VA (Contel) HARRISONBURG HRBGVAXA Verizon South Inc.-VA (Contel) MCGAHEYSVILLE MGVLVAXA Verizon South Inc.-VA (Contel) PRINCESS ANNE PRANVAXA Verizon South Inc.-VA (Contel) PUNGO PUNGVAXA Verizon South Inc.-VA (Contel) SMITHFIELD SMFDVAXA Verizon Virginia Inc. ASHBURN ASBNVAAS Verizon Virginia Inc. STEPHENS CITY STCYVASC Verizon Virginia Inc. HARTWOOD HRWDVAHW Verizon Virginia Inc. BERRYVILLE BEVLVABV Verizon Virginia Inc. CAPE CHARLES CPCHVACC Verizon Virginia Inc. CULPEPER CLPPVACU Verizon Virginia Inc. GORDONSVILLE GOVLVAGV Verizon Virginia Inc. LIGNUM CLPPVALI Verizon Virginia Inc. LOUISA LOUSVALU Verizon Virginia Inc. MARSHALL MRSHVAMA Verizon Virginia Inc. ONANCOCK ONNCVAON Verizon Virginia Inc. ORANGE ORNGVAOR Federal Communications Commission FCC 08-122 50 LEC NAME WIRE CENTER CLLI Verizon Virginia Inc. PARKSLEY PRKSVAPK Verizon Virginia Inc. REVA CLPPVARV Verizon Virginia Inc. SPERRYVILLE SRVLVASP Verizon Virginia Inc. SPOTSYLVANIA SPTSVASP Verizon Virginia Inc. TEMPERANCEVILLE TMVLVATV Verizon Virginia Inc. WARRENTOWN WRTNVAWR Verizon Virginia Inc. EXMORE EXMRVAEX Verizon Virginia Inc. BEDFORD BDFRVABD Verizon Virginia Inc. BETHIA BTHIVABT Verizon Virginia Inc. NEW LONDON ROAD LYBGVANL Verizon Virginia Inc. POWHATAN PWHTVAPW Verizon Virginia Inc. BONSACK RONKVABS Verizon Virginia Inc. STEWARTSVILLE SWVLVASV Federal Communications Commission FCC 08-122 51 EXHIBIT 5 Rural Wire Centers for Inclusion in Cingular’s ETC Service Area Virginia: LEC NAME WIRE CENTER CLLI Amelia Tel. Corp. AMELIA COURT HOUSE AMELVAXA Citizens Tel. Coop.-VA ALUM RIDGE ALRGVAXA Citizens Tel. Coop.-VA BALLARD BLLRVAXA Citizens Tel. Coop.-VA FLOYD FLYDVAXA Citizens Tel. Coop.-VA LOCUST GRV LCGVVAXA Citizens Tel. Coop.-VA WILLIS WILSVAXA NTELOS, Inc. CLIFTON FORGE CFFRVAXA NTELOS, Inc. COVINGTON CVTNVAXA NTELOS, Inc. POTTSCREEK PTCKVAXA NTELOS, Inc. WAYNESBORO WYBOVAXA Pembroke Tel. Coop. NEWPORT,VA NWPTVAXA Pembroke Tel. Coop. PEMBROKE PMBRVAXA Peoples Mutual Tel. Co.-VA GRETNA GRETVAXA Peoples Mutual Tel. Co.-VA HURT HURTVAXA Peoples Mutual Tel. Co.-VA RENAN RENNVAXA Peoples Mutual Tel. Co.-VA SANDYLEVEL SNLVVAXA Roanoke & Botetourt Tel. Co. EAGLE ROCK EGRKVAXA Roanoke & Botetourt Tel. Co. FINCASTLE FNCSVAXA Roanoke & Botetourt Tel. Co. ORISKANY ORSKVAXA Roanoke & Botetourt Tel. Co. TROUTVILLE TRVLVAXA Central Tel. Co. of VA ALTAVISTA ALTVVAXA Central Tel. Co. of VA ARARAT ARRTVAXA Central Tel. Co. of VA ARVONIA ARVNVAXA Central Tel. Co. of VA AXTON AXTNVAXA Central Tel. Co. of VA BACHESHALL BCHLVAXA Central Tel. Co. of VA BUCKINGHAM BCHMVAXA Central Tel. Co. of VA BLACKSTONE BLCSVAXA Central Tel. Co. of VA BOONESMILL BNMLVAXA Central Tel. Co. of VA BUENAVISTA BNVSVAXA Central Tel. Co. of VA BROWNSBURG BRBGVAXA Central Tel. Co. of VA BRODNAX BRDNVAXA Central Tel. Co. of VA BROOKNEAL BRKNVAXA Central Tel. Co. of VA BURKEVILLE BRVLVAXA Central Tel. Co. of VA BASSETT BSSTVAXA Central Tel. Co. of VA BURNTCHMNY BTCHVAXA Central Tel. Co. of VA BEAVERDAM BVRDVAXA Central Tel. Co. of VA CHARLOTSVL CHVLVAXA Central Tel. Co. of VA CHARLOTSVL CHVLVAXB Central Tel. Co. of VA COLLINSVL COVLVAXA Central Tel. Co. of VA CREWE CREWVAXA Central Tel. Co. of VA CROZET CRZTVAXA Central Tel. Co. of VA DILLWYN DLWYVAXA Federal Communications Commission FCC 08-122 52 LEC NAME WIRE CENTER CLLI Central Tel. Co. of VA FORK UNION FKUNVAXA Central Tel. Co. of VA FIELDALE FLDLVAXA Central Tel. Co. of VA FERRUM FRRMVAXA Central Tel. Co. of VA FRONTROYAL FRRYVAXA Central Tel. Co. of VA FARMVILLE FRVLVAXA Central Tel. Co. of VA GLADYS GLDYVAXA Central Tel. Co. of VA GLASGOW GLSGVAXA Central Tel. Co. of VA GUM TREE GMTRVAXA Central Tel. Co. of VA HALIFAX HLFXVAXA Central Tel. Co. of VA HAMPDESDNY HMSYVAXA Central Tel. Co. of VA KENBRIDGE KNBRVAXA Central Tel. Co. of VA LA CROSSE LACRVAXA Central Tel. Co. of VA LURAY LURYVAXA Central Tel. Co. of VA LEXINGTON LXTNVAXA Central Tel. Co. of VA MEADOWSDAN MDDNVAXA Central Tel. Co. of VA MONTPELIER MTPLVAXA Central Tel. Co. of VA BOONESMILL MTVIVAXA Central Tel. Co. of VA NATURALBDG NTBRVAXA Central Tel. Co. of VA PALMYRA PLMYVAXA Central Tel. Co. of VA PROSPECT PRSPVAXA Central Tel. Co. of VA ROCKYMOUNT RCMTVAXA Central Tel. Co. of VA RIDGEWAY RDWYVAXA Central Tel. Co. of VA RUSTBURG RSBGVAXA Central Tel. Co. of VA SO BOSTON SBTNVAXA Central Tel. Co. of VA SCHUYLER SCHLVAXA Central Tel. Co. of VA SCOTTSVL SCVLVAXA Central Tel. Co. of VA STANARDSVL SDVLVAXA Central Tel. Co. of VA SHENANDOAH SHNDVAXA Central Tel. Co. of VA SPENCER SPNCVAXA Central Tel. Co. of VA SOUTH HILL STHLVAXA Central Tel. Co. of VA STANLEY STNLVAXA Central Tel. Co. of VA STUART STRTVAXA Central Tel. Co. of VA TURBEVILLE TBVLVAXA Central Tel. Co. of VA UNION HALL UNHLVAXA Central Tel. Co. of VA VICTORIA VCTAVAXA Central Tel. Co. of VA VOLENS VLNSVAXA Central Tel. Co. of VA VIRGILINA VRGLVAXA Central Tel. Co. of VA WASHINGTON WASHVAXA Central Tel. Co. of VA WHITMELL WHTMVAXA Central Tel. Co. of VA WOOLWINE WLWNVAXA United Inter-Mountain Tel. Co.-VA ABINGDON ABNGVAXA United Inter-Mountain Tel. Co.-VA AUSTINVL ATVLVAXA United Inter-Mountain Tel. Co.-VA BLAND BLNDVAXA United Inter-Mountain Tel. Co.-VA BRISTOL BRSTVAXA United Inter-Mountain Tel. Co.-VA CANA CANAVAXA United Inter-Mountain Tel. Co.-VA CERES CERSVAXA United Inter-Mountain Tel. Co.-VA CHILHOWIE CHLHVAXA United Inter-Mountain Tel. Co.-VA CMSRKELCRK CMRKVAXA Federal Communications Commission FCC 08-122 53 LEC NAME WIRE CENTER CLLI United Inter-Mountain Tel. Co.-VA CRIPPLECRK CRCKVAXA United Inter-Mountain Tel. Co.-VA DAMASCUS DMSCVAXA United Inter-Mountain Tel. Co.-VA FRIES FRISVAXA United Inter-Mountain Tel. Co.-VA GALAX GALXVAXA United Inter-Mountain Tel. Co.-VA GLADE SPG GDSPVAXA United Inter-Mountain Tel. Co.-VA GATE CITY GTCYVAXA United Inter-Mountain Tel. Co.-VA HILLSVILLE HLVLVAXA United Inter-Mountain Tel. Co.-VA INDEPNDNCE INDPVAXA United Inter-Mountain Tel. Co.-VA KONNAROCK KNRKVAXA United Inter-Mountain Tel. Co.-VA LAURELFORK LRFKVAXA United Inter-Mountain Tel. Co.-VA MARION MARNVAXA United Inter-Mountain Tel. Co.-VA MEADOWVIEW MDVWVAXA United Inter-Mountain Tel. Co.-VA MOUTHWILSN MTWLVAXA United Inter-Mountain Tel. Co.-VA MAXMEADOWS MXMDVAXA United Inter-Mountain Tel. Co.-VA RICHVALLEY RCVYVAXA United Inter-Mountain Tel. Co.-VA RURALRTRET RRRTVAXA United Inter-Mountain Tel. Co.-VA SUGARGROVE SGGVVAXA United Inter-Mountain Tel. Co.-VA SALTVILLE SLVLVAXA United Inter-Mountain Tel. Co.-VA SYLVATUS SYLVVAXA United Inter-Mountain Tel. Co.-VA WYTHEVILLE WYVLVAXA Federal Communications Commission FCC 08-122 54 EXHIBIT 6 Non-Rural Wire Centers for Inclusion in Corr’s Alabama ETC Service Area LEC NAME WIRE CENTER CLLI BellSouth Telecommunications, Inc. d/b/a South Central Bell ANNISTON- LENLOCK ANTNALLE BellSouth Telecommunications, Inc. d/b/a South Central Bell ANNISTON-MAIN ANTNALMT BellSouth Telecommunications, Inc. d/b/a South Central Bell ANNISTON- OXFORD ANTNALOX BellSouth Telecommunications, Inc. d/b/a South Central Bell BOWDEN BWDNGAMA BellSouth Telecommunications, Inc. d/b/a South Central Bell BRIDGEPORT- MAIN BRPTALMA BellSouth Telecommunications, Inc. d/b/a South Central Bell COURTLAND CRLDALMA BellSouth Telecommunications, Inc. d/b/a South Central Bell FORT PAYNE- MAIN FTPYALMA BellSouth Telecommunications, Inc. d/b/a South Central Bell GADSDEN- HILLSIDE GDSDALHS BellSouth Telecommunications, Inc. d/b/a South Central Bell GOODWATER GDWRALMA BellSouth Telecommunications, Inc. d/b/a South Central Bell GURLEY-MAIN GRLYALMA BellSouth Telecommunications, Inc. d/b/a South Central Bell JACKSONVILLE- MAIN JCVLALMA BellSouth Telecommunications, Inc. d/b/a South Central Bell MOULTON MOLTALNM BellSouth Telecommunications, Inc. d/b/a South Central Bell OHATCHEE-MAIN OHTCALMA BellSouth Telecommunications, Inc. d/b/a South Central Bell PIEDMONT-MAIN PDMTALMA BellSouth Telecommunications, Inc. d/b/a South Central Bell STEVENSON- MAIN STSNALMA BellSouth Telecommunications, Inc. d/b/a South Central Bell TALLAPOSSA TLLPGAES BellSouth Telecommunications, Inc. d/b/a South Central Bell TOWN CREEK TWCKALMA EXHIBIT 7 Rural Wire Centers for Inclusion in Corr’s Alabama ETC Service Area LEC NAME WIRE CENTER CLLI Roanoke Telephone Co., Inc. ROANOKE RONKALXA Roanoke Telephone Co., Inc. ROCK MILLS RCMLALXA Ardmore Telephone Co. ARDMORE ARMRALXA Ardmore Telephone Co. ELKMONT ELMTALXA Ardmore Telephone Co. NEW MARKET NWMRALXA Federal Communications Commission FCC 08-122 55 EXHIBIT 8 Non-Rural Wire Centers for Inclusion in Dobson’s New York ETC Service Area LEC NAME WIRE CENTER CLLI Frontier Telephone of Rochester (Study Area Code 150121) COHOCTON CHCNNYXA Frontier Telephone of Rochester CASTILE CSTLNYXA Frontier Telephone of Rochester LEROY LROYNYXA Frontier Telephone of Rochester PAVILION PVLNNYXA Frontier Telephone of Rochester WARSAW WRSWNYXA Frontier Telephone of Rochester WYOMING WYNGNYXA Verizon - New York Inc. (Study Area Code 155130) AMENIA AMENNYAN Verizon - New York Inc. ANGELICA ANGENYAG Verizon - New York Inc. ARKPORT ARPTNYAR Verizon - New York Inc. ATTICA ATTCNYAT Verizon - New York Inc. AVON AVOCNYXA Verizon - New York Inc. BOOTH BATHNYBH Verizon - New York Inc. BATAVIA BATVNYBT Verizon - New York Inc. BEACON BECNNYBE Verizon - New York Inc. BELFAST BLFSNYBZ Verizon - New York Inc. BELMONT BLMTNYBM Verizon - New York Inc. BLISS BLSSNYBS Verizon - New York Inc. BOLIVAR BLVRNYBX Verizon - New York Inc. CAIRO CAIRNYCA Verizon - New York Inc. CANAAN CANSNYXA Verizon - New York Inc. CHERRY CREEK CHCKNYCE Verizon - New York Inc. CHERRY VALLEY CHVYNYZV Verizon - New York Inc. CALLICOON CLCNNYCN Verizon - New York Inc. CLINTON CORNERS CLCRNYCC Verizon - New York Inc. CLAVERACK CLVRNYCV Verizon - New York Inc. CAMPBELL CMPBNYCP Verizon - New York Inc. CAMERON CMRNNYCF Verizon - New York Inc. CLINTONDALE CNDLNYCL Verizon - New York Inc. COOPERSTOWN CPTWNYZW Verizon - New York Inc. CORNWALL CRNWNYCW Verizon - New York Inc. CATON CTONNYZN Verizon - New York Inc. CATTARAUGUS CTRGNYSO Verizon - New York Inc. CATSKILL CTSKNYCT Verizon - New York Inc. CUBA CUBANYEM Verizon - New York Inc. DUNKIRK DNKRNYDK Verizon - New York Inc. DOVER PLAINS DVPLNYDP Verizon - New York Inc. DAVENPORT DVPTNYDT Verizon - New York Inc. EDMESTON EDTNNYET Verizon - New York Inc. ELLICOTTVILLE ELCVNYEV Verizon - New York Inc. ELLENVILLE ELVLNYEL Verizon - New York Inc. FRANKLINVILLE FKVLNYFK Verizon - New York Inc. FALLSBURG FLBGNYFB Federal Communications Commission FCC 08-122 56 LEC NAME WIRE CENTER CLLI Verizon - New York Inc. FLEISCHMANNS FLSCNYFM Verizon - New York Inc. FREEHOLD FRHDNYFH Verizon - New York Inc. FRIENDSHIP FRSHNYFS Verizon - New York Inc. FORESTVILLE FSVLNYFL Verizon - New York Inc. GRAHAMSVILLE GHVLNYGH Verizon - New York Inc. GRAND GORG GRGRNYGG Verizon - New York Inc. GREENWOOD LAKE GRLKNYGL Verizon - New York Inc. HOBART HBRTNYHZ Verizon - New York Inc. HUDSON HDSNNYHD Verizon - New York Inc. HIGHLAND HGLDNYHG Verizon - New York Inc. HIGHLAND FALLS HHFLNYHF Verizon - New York Inc. HIGH FALLS HIFLNYHF Verizon - New York Inc. HINSDALE HNDLNYHI Verizon - New York Inc. HUNTER HNTRNYHN Verizon - New York Inc. HORNELL HRNLNYHL Verizon - New York Inc. HARTWICK HRWKNYHW Verizon - New York Inc. HYDE PARK HYPKNYHK Verizon - New York Inc. JEFFERSONVILLE JFVLNYJF Verizon - New York Inc. KINGSTON KGTNNYKG Verizon - New York Inc. KERHONKSON KRHNNYKR Verizon - New York Inc. LIBERTY LBRTNYLB Verizon - New York Inc. LAKE HUNTINGTON LKHNNYLH Verizon - New York Inc. LAKE KATRINE LKKTNYLK Verizon - New York Inc. LIMESTONE LMSTNYLM Verizon - New York Inc. LINDLEY LNDYNYLN Verizon - New York Inc. LITTLE VALLEY LTVYNYLI Verizon - New York Inc. LIVINGSTON MANOR LVMNNYLV Verizon - New York Inc. LEXINGTON LXTNNYLX Verizon - New York Inc. MACHIAS MCHSNYMA Verizon - New York Inc. MILLBROOK MLBKNYML Verizon - New York Inc. MILFORD MLFRNYMU Verizon - New York Inc. MILTON MLTNNYMN Verizon - New York Inc. MONTICELLO MNTINYMT Verizon - New York Inc. MARLBORO MRBONYMB Verizon - New York Inc. NORTH CLOVE NCLVNYNC Verizon - New York Inc. NEWBURGH NWBRNYNW Verizon - New York Inc. NEWBURGH WEST NWBRNYWT Verizon - New York Inc. NEW PALTZ NWPLNYNP Verizon - New York Inc. NEW WINDSOR NWWNNYNW Verizon - New York Inc. OLEAN OLENNYHA Verizon - New York Inc. ONEONTA ONNTNYOA Verizon - New York Inc. OTEGO OTEGNYOT Verizon - New York Inc. POUGHKEEPSIE- SOUTH HAMILTON PGHKNYSH Verizon - New York Inc. POUGHKEEPSIE- SPACKENKILL PGHKNYSP Verizon - New York Inc. PHILMONT PHMTNYPM Verizon - New York Inc. PHOENICIA PHNCNYPH Federal Communications Commission FCC 08-122 57 LEC NAME WIRE CENTER CLLI Verizon - New York Inc. PALENVILLE PLVLNYPL Verizon - New York Inc. PORTVILLE PRTVNYPV Verizon - New York Inc. PRATTSVILLE PRVINYPR Verizon - New York Inc. PLEASANT VALLEY PVYDNYPD Verizon - New York Inc. PAWLING PWNGNYSS Verizon - New York Inc. RICHMONDVILLE RCVLNYRH Verizon - New York Inc. ROSENDALE RODLNYRD Verizon - New York Inc. RUSHFORD RSFRNYRF Verizon - New York Inc. ROXBURY RXBYNYRX Verizon - New York Inc. SCHENEVUS SCHVNYQN Verizon - New York Inc. SOUTH DAYTON SDTNNYPI Verizon - New York Inc. SAUGERTIES SGRTNYSG Verizon - New York Inc. SHOKAN SHKNNYSK Verizon - New York Inc. SHARON SPRINGS SHSPNYQS Verizon - New York Inc. SALAMANCA SLMNNYWW Verizon - New York Inc. STAMFORD SMFRNYQM Verizon - New York Inc. STANFORDVILLE STNVNYST Verizon - New York Inc. TANNERSVILLE TNVLNYTN Verizon - New York Inc. TUXEDO TUXDNYTX Verizon - New York Inc. VARYSBURG VRBGNYVB Verizon - New York Inc. WOODSTOCK WDSTNYWS Verizon - New York Inc. WHITE LAKE WHLKNYWH Verizon - New York Inc. WELLSVILLE WLVLNYNM Verizon - New York Inc. WINGDALE WNDLNYWD Verizon - New York Inc. WINDHAM WNHMNYWM Verizon - New York Inc. WAPPINGERS FALLS WPFLNYWF Verizon - New York Inc. WORCESTER WRCSNYUC EXHIBIT 9 Rural Study Areas for Inclusion in Dobson’s New York ETC Service Area Armstrong Tel. Co. – NY (Study Area Code 150071) Berkshire Tel. Co. (Study Area Code 150073) Cassadaga Tel. Corp. (Study Area Code 150076) Chautauqua & Erie Tel. Corp. (Study Area Code 150078) Citizens-Red Hook (Study Area Code 154533) Delhi Tel. Co. (Study Area Code 150088) Dunkirk & Fredonia Tel. Co. (Study Area Code 150091) FC of New York, Inc. (Study Area Code 150100) FC of Sylvan Lake, Inc. (Study Area Code 150128) Germantown Tel. Co., Inc. (Study Area Code 150097) Hancock Tel. Co. NY (Study Area Code 150099) Jamestown Tel. Co. (Study Area Code 150109) Margaretville Tel. Co., Inc. (Study Area Code 150104) Warwick Valley – NY (Study Area Code 150135) Federal Communications Commission FCC 08-122 58 EXHIBIT 10 Rural Service Areas Requiring Reclassification Along Wire Center Boundaries for Inclusion In Dobson’s New York ETC Service Area LEC NAME WIRE CENTER CLLI Citizens Tel. Co. of NY (Study Area Code 154534) CORFO CORFNYXA Citizens Tel. Co. of NY DARIEN DARNNYXA Citizens Tel. Co. of NY DOWNSVILLE DSVLNYXA Citizens Tel. Co. of NY NARROWSBURG NRBGNYXB Citizens Tel. Co. of NY ROSCOE ROSCNYXA Citizens Tel. Co. of NY WALTON WLTNNYXA Empire Tel. Corp. (Study Area Code 150093) PULTENEY PLTNNYXA Taconic Tel. Corp. (Study Area Code 150084) CANAAN CANNNYXA Taconic Tel. Corp. CHATHAM CHHMNYXA Taconic Tel. Corp. COPAKE COPKNYXA Taconic Tel. Corp. HILLSDALE HLDLNYXA Taconic Tel. Corp. MILLERTON MLLTNYXA Taconic Tel. Corp. PINE PLAINS PNPLNYXA Taconic Tel. Corp. WEST LEBANON WLBNNYXA The Middleburgh Telephone Company (Study Area Code 150105) BRAMANVILLE BRMVNYXA The Middleburgh Telephone Company SUMMIT SMMTNYXA Federal Communications Commission FCC 08-122 59 EXHIBIT 11 Non-Rural Wire Centers for Inclusion in Farmers’ Alabama ETC Service Area LEC NAME WIRE CENTER CLLI BellSouth Telecommunications, Inc. ALBERTVILLE ALVLALMA BellSouth Telecommunications, Inc. BOAZ BOAZALMA BellSouth Telecommunications, Inc. GUNTERSVILLE GTVLALNM BellSouth Telecommunications, Inc. GURLEY GRLYALMA CenturyTel of Alabama, L.L.C. MENTONE MENTALXA CenturyTel of Alabama, L.L.C. SCOTTSBORO SCBOALXA CenturyTel of Alabama, L.L.C. SECTION SECTALXA CenturyTel of Alabama, L.L.C. SKYLINE SKLNALXA CenturyTel of Alabama, L.L.C. VALLEY HEAD VYHDALXA EXHIBIT 12 Rural Wire Centers for Inclusion in Farmers’ Alabama ETC Service Area LEC NAME WIRE CENTER CLLI Farmers Telecommunications Coop. Inc. BRYANT BRYNALXA Farmers Telecommunications Coop. Inc. FLAT ROCK FLRKALXA Farmers Telecommunications Coop. Inc. FYFFE FYFFALXA Farmers Telecommunications Coop. Inc. GERALDINE GLDNALXA Farmers Telecommunications Coop. Inc. HENAGAR HNGRALXA Farmers Telecommunications Coop. Inc. PISGAH PSGHALXA Farmers Telecommunications Coop. Inc. RAINSVILLE RNVLALXA Federal Communications Commission FCC 08-122 60 EXHIBIT 13 Rural Wire Centers for Inclusion in NEP’s Pennsylvania ETC Service Area LEC NAME WIRE CENTER CLLI Deposit Telephone Co. Inc. SHERMAN DPSTNYXA Hancock Telephone Co. NY WINTERDALE HNCCNYXA EXHIBIT 14 Service Areas Requiring Reclassification Along Wire Center Boundaries for Inclusion In NEP’s Pennsylvania ETC Service Area LEC NAME WIRE CENTER CLLI Citizens Telecommunications Co. of NY d/b/a Frontier Communications of NY BROOKLYN BRKLPAXB Citizens Telecommunications Co. of NY d/b/a Frontier Communications of NY HALLSTEAD HLSTPAXH Citizens Telecommunications Co. of NY d/b/a Frontier Communications of NY LAWSVILLE LYCNPAXL Citizens Telecommunications Co. of NY d/b/a Frontier Communications of NY LITTLE MEADOWS-PA LTMDPAXL Citizens Telecommunications Co. of NY d/b/a Frontier Communications of NY MONTROSE MTRSPAXM Citizens Telecommunications Co. of NY d/b/a Frontier Communications of NY QUAKER LAKE-PA QKLKPAXQ Citizens Telecommunications Co. of NY d/b/a Frontier Communications of NY RUSH RUSHPAXR Citizens Telecommunications Co. of NY d/b/a Frontier Communications of NY ST JOSEPH STJSPAXS Citizens Telecommunications Co. of NY d/b/a Frontier Communications of NY SUSQUEHANNA SSQHPAXS Verizon North Inc.- Quaker State GALILEE GALLPAXG Federal Communications Commission FCC 08-122 61 EXHIBIT 15 Non-Rural Service Area for Inclusion in NY RSA 2’s New York ETC Service Area Verizon New York, Inc. (Study Area Code 155130) EXHIBIT 16 Rural Service Areas for Inclusion in NY RSA 2’s New York ETC Service Area Champlain Telephone Company (Study Area Code 150077) Chazy & Westport Telephone Corp. (Study Area Code 150079) Crown Point Telephone Corp. (Study Area Code 150085) Frontier Communications of Ausable Valley (Study Area Code 150072) EXHIBIT 17 Service Areas Requiring Reclassification Along Wire Center Boundaries for Inclusion In NY RSA 2’s New York ETC Service Area LEC NAME WIRE CENTER CLLI Citizens Telecommunications Co. of NY d/b/a Frontier Communications ADAMS ADMSNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications ADAMS CENTER ADCTNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications ALFRED ALFENYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications ALMOND ALMDNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications ANDOVER ANDVNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications APALACHIN APLCNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications BAINBRIDGE BNBRNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications BARRYVILLE BYVLNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications BELLEVILLE BLVLNYXA Citizens Telecommunications Co. of NY d/b/a BERKSHIRE BRKSNYXA Federal Communications Commission FCC 08-122 62 LEC NAME WIRE CENTER CLLI Frontier Communications Citizens Telecommunications Co. of NY d/b/a Frontier Communications BLOOMINGBURG BMBGNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications BLUE MOUNTAIN LAKE BMLKNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications BOONVILLE BNVLNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications BRANCHPORT BNPTNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications BROADALBIN BRDBNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications BROOKFIELD BRFDNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications CANAJOHARIE CNJHNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications CANDOR CNDRNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications CAROGA LAKE CGLKNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications CATO CATONYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications CHEMUNG CHMGNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications CHENANGO BRIDGE CHBRNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications CHESTERTOWN CHRTNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications CINCINNATUS CNCNNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications CLAYVILLE CYVLNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications CONSTABLEVILLE CSTVNYXB Citizens Telecommunications Co. of NY d/b/a Frontier Communications CORFU CORFNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications CORINTH CRNTNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications CROGHAN CRGHNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications DALTON DLTNNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications DARIEN DARNNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications DE RUYTER DRTRNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications DENTON DNTNNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications DOWNSVILLE DSVLNYXA Federal Communications Commission FCC 08-122 63 LEC NAME WIRE CENTER CLLI Citizens Telecommunications Co. of NY d/b/a Frontier Communications DRYDEN DRYDNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications DUNDEE DUNDNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications EAGLE BAY EGBANYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications EARLVILLE ERVLNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications ELIZAVILLE EZVLNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications ETNA ETNANYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications FAIR HAVEN (CAYUGA) FHNCNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications FONDA FONDNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications FORESTPORT FOPTNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications FORT PLAIN FTPLNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications FRANKLIN FKLNNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications GEORGETOWN GRTWNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications GILBERTSVILLE GBVLNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications GLEN GLENNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications GLOVERSVILLE GLVNNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications GREENE GRNENYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications GREENWOOD GNWDNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications GUILFORD GUFDNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications HAMMONDSPORT HMPTNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications HANNIBAL HNBLNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications HAWLEYTON HWTNNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications HENDERSON HNSNNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications INDIAN LAKE INLKNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications JASPER JSPRNYXA Citizens Telecommunications Co. of NY d/b/a JOHNSTOWN JHTWNYXA Federal Communications Commission FCC 08-122 64 LEC NAME WIRE CENTER CLLI Frontier Communications Citizens Telecommunications Co. of NY d/b/a Frontier Communications LUZERNE LZRNNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications LAKE PLEASANT LKPLNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications LEONARDSVILLE LNRVNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications LOCKWOOD LCWDNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications LONG LAKE (HAMILTON) LLKHNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications LOWVILLE LOWVNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications LYONS FALLS LYFLNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications LYSANDER LYSNNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications MADISON MDSNNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications MANNSVILLE MNVLNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications MARATHON MRTHNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications MASONVILLE MSVLNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications MAYFIELD MYFDNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications MCDONOUGH MCDNNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications MIDDLETOWN MDTWNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications MORRIS MRRSNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications MORRISVILLE MRVLNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications MOUNT UPTON MTUPNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications NARROWSBURG NRBGNYXB Citizens Telecommunications Co. of NY d/b/a Frontier Communications NEW BERLIN NWBLNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications NEW WOODSTOCK NWWDNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications NEWARK VALLEY NWVYNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications NEWCOMB NWCMNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications NORTH BROOKFIELD NBFDNYXA Federal Communications Commission FCC 08-122 65 LEC NAME WIRE CENTER CLLI Citizens Telecommunications Co. of NY d/b/a Frontier Communications NORTH CREEK NRCKNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications NORTHVILLE NRVLNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications NORWICH NRWCNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications OLD FORGE OLDFNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications OTISVILLE OTVLNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications OXFORD OXFRNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications PORT JERVIS PTJRNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications PULASKI PLSKNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications RAQUETTE LAKE RQLKNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications RED HOOK RDHKNYXB Citizens Telecommunications Co. of NY d/b/a Frontier Communications REMSEN REMSNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications RHINEBECK RHNBNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications ROSCOE ROSCNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications SANBORN SNBRNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications SANDY CREEK SNCKNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications SCOTCHTOWN SCTWNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications SHERBURNE SHBNNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications SIDNEY SDNYNYXB Citizens Telecommunications Co. of NY d/b/a Frontier Communications SLATE HILL SLHLNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications SLATERVILLE SPRINGS SLSPNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications SMYRNA SMYRNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications SOUTH NEW BERLIN SNBLNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications SOUTH OTSELIC SOTSNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications SPENCER SPNCNYXA Citizens Telecommunications Co. of NY d/b/a ST JOHNSVILLE STJNNYXA Federal Communications Commission FCC 08-122 66 LEC NAME WIRE CENTER CLLI Frontier Communications Citizens Telecommunications Co. of NY d/b/a Frontier Communications STAATSBURG STATNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications TIVOLI TIVONYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications TRIBES HILL TRHLNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications TRUXTON TXTNNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications UNADILLA UNADNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications UNIONVILLE (ORANGE) UVLONYXF Citizens Telecommunications Co. of NY d/b/a Frontier Communications VIRGIL VRGLNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications WALTON WLTNNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications WATERVILLE WTVLNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications WAYNE WAYNNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications WELLS WLLSNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications WEST VALLEY WSVYNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications WHITNEY POINT WHPNNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications WILLIAMSTOWN WLTWNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications WURTSBORO WRBONYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications FILLMORE FLMRNYXA Citizens Telecommunications Co. of NY d/b/a Frontier Communications CIRCLEVILLE CRVLNYXA Federal Communications Commission FCC 08-122 67 EXHIBIT 18 Rural Wire Centers for Inclusion in Pine Belt’s Alabama ETC Service Area LEC NAME WIRE CENTER CLLI Butler Telephone Co. Inc. (Study Area Code 250284) BUTLER BTLRALXADS0 Butler Telephone Co. Inc. LISMAN LSMNALXADS0 Butler Telephone Co. Inc. NEEDHAM NDHMALXARS0 Butler Telephone Co. Inc. PENNINGTON PNTNALXARS0 Frontier CM – Alabama (Study Area Code 250306) PINE APPLE PNAPALXARS0 Frontier CM SO – AL (Study Area Code 250318) CAMDEN CMDNALXADS0 Frontier CM SO – AL CATHERINE CTHRALXARS0 Frontier CM SO – AL THOMASTON THMTALXARS0 Frontier CM SO – AL VREDENBG VRBGALXARS0 Millary Telephone (Study Area Code 250304) GILBERTOWN GLTWALXADS0 Millary Telephone SILAS MLRYALXADS0 Millary Telephone FRANKVILLE MLRYALXADS0 Pine Belt Telephone Co. Inc. (Study Area Code 250315) ARLINGTON ARTNALXARS0 Pine Belt Telephone Co. Inc. DIXONS MILLS DXMALXADS0 Pine Belt Telephone Co. Inc. NANAFALIA NNFLALXARS0 Pine Belt Telephone Co. Inc. SWEETWATER SWWRALXARS0 Federal Communications Commission FCC 08-122 68 EXHIBIT 19 Non-Rural Wire Centers for Inclusion in RCC’s Alabama ETC Service Area LEC NAME WIRE CENTER CLLI BellSouth Telecom. Inc. d/b/a Central Bell Tel. AUBURN AUBNALUA BellSouth Telecom. Inc. d/b/a Central Bell Tel. CLANTON CLANALMA BellSouth Telecom. Inc. d/b/a Central Bell Tel. GEORGETOWN EUFLALMA BellSouth Telecom. Inc. d/b/a Central Bell Tel. HURTSBORO HRBOALOM BellSouth Telecom. Inc. d/b/a Central Bell Tel. OPELIKA OPLKALMT BellSouth Telecom. Inc. d/b/a Central Bell Tel. PHENIXCITY (PHCYALFM) PHCYALFM BellSouth Telecom. Inc. d/b/a Central Bell Tel. PHENIXCITY (PHCYALMA) PHCYALMA BellSouth Telecom. Inc. d/b/a Central Bell Tel. TROY TROYALMA Century Telephone of Alabama, LLC ABBEVILLE ABVLALXA Century Telephone of Alabama, LLC ARITON ARITALXA Century Telephone of Alabama, LLC CLIO CLIOALXA Century Telephone of Alabama, LLC COLUMBIA CLMAALXA Century Telephone of Alabama, LLC DALEVILLE DLVLALXA Century Telephone of Alabama, LLC DOTHAN DTHNALXA Century Telephone of Alabama, LLC ECHO ECHOALXA Century Telephone of Alabama, LLC HEADLAND HDLDALXA Century Telephone of Alabama, LLC LOUISVILLE LSVLALXA Century Telephone of Alabama, LLC MIDLAND CY MLCYALXA Century Telephone of Alabama, LLC NEWTON NWTNALXA Century Telephone of Alabama, LLC NEWVILLE NWVIALXA Century Telephone of Alabama, LLC OZARK OZRKALXA Century Telephone of Alabama, LLC WICKSBURG WCBGALXA EXHIBIT 20 Rural Wire Centers for Inclusion in RCC’s Alabama ETC Service Area LEC NAME WIRE CENTER CLLI Graceba Total Communications GORDON GRDNALXA Valley Telephone Co., Inc. LANGDALE LNDLALXA Federal Communications Commission FCC 08-122 69 EXHIBIT 21 Non-Rural Service Areas for Inclusion in SouthernLINC’s Alabama ETC Service Area BellSouth Telecommunications (Study Area Code 255181) EXHIBIT 22 Rural Study Areas for Inclusion in SouthernLINC’s Alabama ETC Service Area LEC NAME WIRE CENTER CLLI Alltel Alabama, Inc. ASHVILLE AHVLALXA Alltel Alabama, Inc. CAMP HILL CMPHALXA Alltel Alabama, Inc. ECLECTIC ECLCALXA Alltel Alabama, Inc. KOWALIGA KWLGALXA Alltel Alabama, Inc. LEEDS LEDSALXA Alltel Alabama, Inc. LEEDS LEDSALXB Alltel Alabama, Inc. ODENVILLE ODVLALXA Alltel Alabama, Inc. SPRINGVL SPVLALXA Blountsville Telephone Company, Inc. BLOUNTSVL BUVLALXA Blountsville Telephone Company, Inc. NECTAR NCTRALXA Brindlee Mountain Telephone Company ARAB ARABALXA Brindlee Mountain Telephone Company MORGANCITY MRCYALXA Brindlee Mountain Telephone Company UNIONGROVE UNGVALXA Butler Telephone Company, Inc. BUTLER BTLRALXA Butler Telephone Company, Inc. GOSHEN GSHNALXA Butler Telephone Company, Inc. GROVE HILL GVHLALXA Butler Telephone Company, Inc. LISMAN LSMNALXA Butler Telephone Company, Inc. NEEDHAM NDHMALXA Butler Telephone Company, Inc. PENNINGTON PNTNALXA Castleberry Telephone Company, Inc. CASTLEBRY CSTLALXA CenturyTel of Alabama, LLC ABBEVILLE ABVLALXA CenturyTel of Alabama, LLC ALBERTA ALBRALXA CenturyTel of Alabama, LLC ALICEVILLE ACVLALXA CenturyTel of Alabama, LLC ANDALUSIA ANDSALXA CenturyTel of Alabama, LLC ARITON ARITALXA CenturyTel of Alabama, LLC ASHLAND ASLDALXA CenturyTel of Alabama, LLC BANKS BNKSALXA CenturyTel of Alabama, LLC BAYOUBATRE BLBTALXA CenturyTel of Alabama, LLC BERRY BRRYALXA CenturyTel of Alabama, LLC BRANTLEY BTLYALXA CenturyTel of Alabama, LLC BRILLIANT BRILALXA CenturyTel of Alabama, LLC BRUNDIDGE BRNDALXA CenturyTel of Alabama, LLC CARROLLTON CRTNALXA CenturyTel of Alabama, LLC CHULAFINNE CHLFALXA CenturyTel of Alabama, LLC CLIO CLIOALXA CenturyTel of Alabama, LLC COFFEEVL CFVLALXA CenturyTel of Alabama, LLC COLUMBIA CLMAALXA Federal Communications Commission FCC 08-122 70 LEC NAME WIRE CENTER CLLI CenturyTel of Alabama, LLC DALEVILLE DLVLALXA CenturyTel of Alabama, LLC DAUPHIN IS DPISALXA CenturyTel of Alabama, LLC DELTA DELTALXA CenturyTel of Alabama, LLC DETROIT DTRTALXA CenturyTel of Alabama, LLC DOTHAN DTHNALXA CenturyTel of Alabama, LLC DOUBLE SPG DBSPALXA CenturyTel of Alabama, LLC DOZIER DOZRALXA CenturyTel of Alabama, LLC ECHO ECHOALXA CenturyTel of Alabama, LLC ELBA ELBAALXA CenturyTel of Alabama, LLC ENTERPRISE ENTRALXA CenturyTel of Alabama, LLC ETHELSVL ETVLALXA CenturyTel of Alabama, LLC FALKVILLE FLVLALXA CenturyTel of Alabama, LLC FAYETTE FYTTALXA CenturyTel of Alabama, LLC FORESTHOME FRHMALXA CenturyTel of Alabama, LLC FOWL RIVER FWRVALXA CenturyTel of Alabama, LLC GANTT GNTTALXA CenturyTel of Alabama, LLC GENEVA GENVALXA CenturyTel of Alabama, LLC GEORGIANA GRGNALXA CenturyTel of Alabama, LLC GORDO GORDALXA CenturyTel of Alabama, LLC GRAND BAY GDBAALXA CenturyTel of Alabama, LLC GREENVILLE GNVLALXA CenturyTel of Alabama, LLC GUIN GUINALXA CenturyTel of Alabama, LLC HACKLEBURG HCBGALXA CenturyTel of Alabama, LLC HALEYVILLE HLVLALXA CenturyTel of Alabama, LLC HAMILTON HMTNALXA CenturyTel of Alabama, LLC HARTFORD HRFRALXA CenturyTel of Alabama, LLC HEADLAND HDLDALXA CenturyTel of Alabama, LLC HEFLIN HFLNALXA CenturyTel of Alabama, LLC IRNGTNSTEL IRSEALXA CenturyTel of Alabama, LLC JEMISON JMSNALXA CenturyTel of Alabama, LLC KINSTON KSTNALXA CenturyTel of Alabama, LLC LECTA LECTALXA CenturyTel of Alabama, LLC LINCOLN LNCLALXA CenturyTel of Alabama, LLC LINEVILLE LNVLALXA CenturyTel of Alabama, LLC LOUISEVILLE LSVLALXA CenturyTel of Alabama, LLC LUVERNE LVRNALXA CenturyTel of Alabama, LLC MASSEY MSSYALXA CenturyTel of Alabama, LLC MCKENZIE MCKNALXA CenturyTel of Alabama, LLC MENTONE MENTALXA CenturyTel of Alabama, LLC MIDLAND CY MLCYALXA CenturyTel of Alabama, LLC MRNSCRSRDS MRCRALXA CenturyTel of Alabama, LLC NEWBROCKTN NWBCALXA CenturyTel of Alabama, LLC NEWTON NWTNALXA CenturyTel of Alabama, LLC NEWVILLE NWVIALXA CenturyTel of Alabama, LLC NOTASULGA NTSLALXA CenturyTel of Alabama, LLC ODEN RIDGE ODRGALXA CenturyTel of Alabama, LLC OPP OPPALXA CenturyTel of Alabama, LLC ORRIVLLE ORVLALXA Federal Communications Commission FCC 08-122 71 LEC NAME WIRE CENTER CLLI CenturyTel of Alabama, LLC OZARK OZRKALXA CenturyTel of Alabama, LLC PANOLA PANLALXA CenturyTel of Alabama, LLC PELL CITY PLCYALXA CenturyTel of Alabama, LLC PHILCMPBLL PHBLALXA CenturyTel of Alabama, LLC PINE HILL PNHLALXA CenturyTel of Alabama, LLC RED LEVEL RDLVALXA CenturyTel of Alabama, LLC REFORM RFRMALXA CenturyTel of Alabama, LLC ROCKFORD RCFRALXA CenturyTel of Alabama, LLC SAMSON SMSNALXA CenturyTel of Alabama, LLC SCOTTSBORO SCBOALXA CenturyTel of Alabama, LLC SECTION SECTALXA CenturyTel of Alabama, LLC SKYLINE SKLNALXA CenturyTel of Alabama, LLC SLOCOMB SLCMALXA CenturyTel of Alabama, LLC SULLIGENT SLGNALXA CenturyTel of Alabama, LLC SURFSIDE PLCYALXA CenturyTel of Alabama, LLC TALLASSEE TLLSALXA CenturyTel of Alabama, LLC THORSBY THRSALXA CenturyTel of Alabama, LLC TRUSSVILLE TSVLALXA CenturyTel of Alabama, LLC VALLEYHEAD VYHDALXA CenturyTel of Alabama, LLC VERNON VERNALXA CenturyTel of Alabama, LLC WADLEY WDLYALXA CenturyTel of Alabama, LLC WEDOWEE WEDWALXA CenturyTel of Alabama, LLC WICKSBURG WCBGALXA CenturyTel of Alabama, LLC WINFIELD WNFDALXA CenturyTel of Alabama, LLC WOODLAND WDLDALXA Farmers Telephone Cooperative, Inc. BRYANT BRYNALXA Farmers Telephone Cooperative, Inc. FLAT ROCK FLRKALXA Farmers Telephone Cooperative, Inc. FYFFE FYFFALXA Farmers Telephone Cooperative, Inc. GERALDINE GLDNALXA Farmers Telephone Cooperative, Inc. HENAGAR HNGRALXA Farmers Telephone Cooperative, Inc. PISGAH PSGHALXA Farmers Telephone Cooperative, Inc. RAINSVILLE RNVLALXA Frontier Communications of Alabama, Inc. BEATRICE BTRCALXA Frontier Communications of Alabama, Inc. EXCEL EXCLALXA Frontier Communications of Alabama, Inc. FINCHBURG FNBGALXA Frontier Communications of Alabama, Inc. FRISCOCITY FRCYALXA Frontier Communications of Alabama, Inc. GOSPORT GSPTALXA Frontier Communications of Alabama, Inc. MONROEVL MOVLALXA Frontier Communications of Alabama, Inc. PETERMAN PTMNALXA Frontier Communications of Alabama, Inc. PINE APPLE PNAPALXA Frontier Communications of Alabama, Inc. REPTON RPTNALXA Frontier Communications of Alabama, Inc. URIAH URIHALXA Frontier Communications of Lamar County, Inc. KENNEDY KNDYALXA Frontier Communications of Lamar County, Inc. MILLPORT MLPTALXA Frontier Communications of the South, Inc. – AL ATMORE ATMRALXA Frontier Communications of the South, Inc. – AL CAMDEN CMDNALXA Frontier Communications of the South, Inc. – AL CATHERINE CTHRALXA Frontier Communications of the South, Inc. – AL HUXFORD HXFRALXA Federal Communications Commission FCC 08-122 72 LEC NAME WIRE CENTER CLLI Frontier Communications of the South, Inc. – AL MCCULLOUGH MCCLALXA Frontier Communications of the South, Inc. – AL THOMASTON THMTALXA Frontier Communications of the South, Inc. – AL VREDENBG VRBGALXA Graceba Total Communications, Inc. ASHFORD ASFRALXA Graceba Total Communications, Inc. COTTONWOOD CTWDALXA Graceba Total Communications, Inc. GORDON GRDNALXA GTC, Inc. FLORALA FLRLALXA Gulf Telephone Company BON SECOUR BNSCALXA Gulf Telephone Company ELBERTA ELBTALXA Gulf Telephone Company ELBERTA ELBTALXB Gulf Telephone Company FOLEY FOLYALXA Gulf Telephone Company FOLEY FOLYALXB Gulf Telephone Company FOLEY MRLWALXA Gulf Telephone Company FORTMORGAN FTMRALXA Gulf Telephone Company FORTMORGAN FTMRALXB Gulf Telephone Company GULFSHORES GLSHALXA Gulf Telephone Company GULFSHORES GLSHALXB Gulf Telephone Company LILLIAN LLLNALXA Gulf Telephone Company LILLIAN LLLNALXB Gulf Telephone Company LOXLEY LXLYALXA Gulf Telephone Company LOXLEY LXLYALXB Gulf Telephone Company MAGNOLISPG MGSPALXA Gulf Telephone Company ORANGE BCH ORBHALXA Gulf Telephone Company ORANGE BCH ORBHALXC Gulf Telephone Company ORANGE BCH ORBHALXD Gulf Telephone Company ROBERTSDL RBDLALXA Gulf Telephone Company ROBERTSDL RBDLALXB Gulf Telephone Company SEMINOLE SMNLALXA Gulf Telephone Company SEMINOLE SMNLALXB Gulf Telephone Company SUMMERDALE SRDLALXA Hayneville Telephone Company, Inc. GORDONSVL GOVLALXA Hayneville Telephone Company, Inc. HAYNEVILLE HYVLALXA Hayneville Telephone Company, Inc. LOWNDESBO LWBOALXA Hopper Telecommunications Company SNEAD SNEDALXA Hopper Telecommunications Company WALNUT GRV WLGVALXA Interstate Telephone Company FREDONIA FRDNALXA Interstate Telephone Company HUGULEY HGLYALXA Interstate Telephone Company SHAWMUT SHWMALXA Interstate Telephone Company WEST POINT1 WSPNGAXA1 Millry Telephone Company, Inc. CHATAM CHTMALXA Millry Telephone Company, Inc. GILBERTOWN GLTWALXA Millry Telephone Company, Inc. MILLRY MLRYALXA Mon-Cre Telephone Cooperative, Inc. RAMER RAMRALXA Moundville Telephone Company MOUNDVILLE MNVLALXA National Telephone Company of Alabama, Inc. BART BARTALXA 1 As discussed above, designated only to the extent that the wire center is contained within Alabama. Federal Communications Commission FCC 08-122 73 LEC NAME WIRE CENTER CLLI National Telephone Company of Alabama, Inc. CHEROKEE CHRKALXA National Telephone Company of Alabama, Inc. MONTGOMERY MGRMALXA New Hope Telephone Cooperative, Inc. GRANT GRNTALXA New Hope Telephone Cooperative, Inc. NEW HOPE NWHPALXA New Hope Telephone Cooperative, Inc. OWNSCRSRDS OCRDALXA Oakman Telephone Company FLATWOOD FLWDALXA Oakman Telephone Company LYNN LYNNALXA Oakman Telephone Company NAUVOO NAUVALXA Oakman Telephone Company OAKMAN OKMNALXA Otelco Telephone LLC ONEONTA ONNTALXA Peoples Telephone Company ARONEY ARNYALXA Peoples Telephone Company CEDARBLUFF CDRBALXA Peoples Telephone Company CENTRE CNTRALXE Peoples Telephone Company COLLINSVL COVLALXA Peoples Telephone Company CROSSVILLE CSVLALXA Peoples Telephone Company GAYLESVL GLVLALXA Peoples Telephone Company GRAYSON GYSNALXA Peoples Telephone Company LEESBURG LSBGALXA Peoples Telephone Company RINEHART RNHRALXA Peoples Telephone Company SAND ROCK SNRCALXA Peoples Telephone Company WHORTON WHTNALXA Pine Belt Telephone Company, Inc. ARLINGTON ARTNALXA Pine Belt Telephone Company, Inc. DIXONS ML DXMLALXA Pine Belt Telephone Company, Inc. NANAFALIA NNFLALXA Pine Belt Telephone Company, Inc. SWEETWATER SWWRALXA Ragland Telephone Company, Inc. RAGLAND RGLDALXA Union Springs Telephone Company, Inc. FORT DAVIS FTDVALXA Union Springs Telephone Company, Inc. MIDWAY MDWYALXA Union Springs Telephone Company, Inc. PEROTE PROTALXA Union Springs Telephone Company, Inc. UNION SPG UNSPALXA Valley Telephone Company LLC LANGDALE LNDLALXA Federal Communications Commission FCC 08-122 74 EXHIBIT 23 Non-Rural Service Area for Inclusion in St. Lawrence Seaway’s New York ETC Service Area Verizon New York, Inc. (Study Area Code 155130) EXHIBIT 24 Rural Service Areas for Inclusion in St. Lawrence’s New York ETC Service Area Citizens Telecommunications of Hammond, Inc. (Study Area Code 150081) Edwards Telephone Co. (Study Area Code 150092) Nicholville Telephone Co., Inc. (Study Area Code 150108) Township Telephone Co., Inc. (Study Area Code 150129) Federal Communications Commission FCC 08-122 75 EXHIBIT 25 Non-Rural Wire Centers for Inclusion in SunCom’s ETC Service Area North Carolina: LEC NAME WIRE CENTER CLLI BELLSOUTH - NC ACME ACMENCMA BELLSOUTH - NC ALTAN ALTNNCXA BELLSOUTH - NC APEX APEXNCCE BELLSOUTH - NC ARDEN AHVLNCOH BELLSOUTH - NC ARDEN ARDNNCCE BELLSOUTH - NC ASHEVILLE AHVLNCBI BELLSOUTH - NC ASHEVILLE AHVLNCOT BELLSOUTH - NC ATKINSON ATSNNCMA BELLSOUTH - NC BELMONT BLMTNCCE BELLSOUTH - NC BESSEMER CITY BSCYNCMA BELLSOUTH - NC BLACK MOUNTAIN BCMTNCCE BELLSOUTH - NC BLOWING ROCK BLRKNCCE BELLSOUTH - NC BOONE BOONNCKI BELLSOUTH - NC BURGAW BRGWNCMA BELLSOUTH - NC BURLINGTON BURLNCDA BELLSOUTH - NC BURLINGTON BURLNCEL BELLSOUTH - NC BURLINGTON BRVLNCXA BELLSOUTH - NC CANTON CNTNNCMA BELLSOUTH - NC CAROLEEN CRLNNCMA BELLSOUTH - NC CAROLINA BEACH CRBHNCCE BELLSOUTH - NC CARY CARYNCWS BELLSOUTH - NC CARY MRVLNCCN BELLSOUTH - NC CASTLE HAYNE CSHYNCMA BELLSOUTH - NC CHAPEL HILL CPHLNCRO BELLSOUTH - NC CHAPEL HILL RLGHNCMO BELLSOUTH - NC CHARLOTTE CHRLNCBO BELLSOUTH - NC CHARLOTTE CHRLNCCE BELLSOUTH - NC CHARLOTTE CHRLNCCR BELLSOUTH - NC CHARLOTTE CHRLNCDE BELLSOUTH - NC CHARLOTTE CHRLNCER BELLSOUTH - NC CHARLOTTE CHRLNCLP BELLSOUTH - NC CHARLOTTE CHRLNCMI BELLSOUTH - NC CHARLOTTE CHRLNCOD BELLSOUTH - NC CHARLOTTE CHRLNCRE BELLSOUTH - NC CHARLOTTE CHRLNCSH BELLSOUTH - NC CHARLOTTE CHRLNCTH BELLSOUTH - NC CHARLOTTE CHRLNCUN BELLSOUTH - NC CHARLOTTE PIVLNCXB BELLSOUTH - NC CHARLOTTE SLBRNCMA BELLSOUTH - NC CHERRYVILLE CHVLNCCE BELLSOUTH - NC CLAREMONT CLMTNCMA BELLSOUTH - NC CLEVELAND CLEVNCMA BELLSOUTH - NC CLYDE CLYDNCMA Federal Communications Commission FCC 08-122 76 LEC NAME WIRE CENTER CLLI BELLSOUTH - NC DAVIDSON CHRLNCCA BELLSOUTH - NC DAVIDSON DVSNNCPO BELLSOUTH - NC DENVER DNVRNCMA BELLSOUTH - NC DURHAM DRHMNCXH BELLSOUTH - NC ELLENBORO ELBONCMA BELLSOUTH - NC ENKA-CANDLER ENKANCMA BELLSOUTH - NC FAIRMONT FAMTNCMA BELLSOUTH - NC FAIRVIEW FRVWNCMA BELLSOUTH - NC FOREST CITY FRCYNCCE BELLSOUTH - NC GASTONIA GSTANCDA BELLSOUTH - NC GASTONIA GSTANCSO BELLSOUTH - NC GIBSONNC GBSNNCMA BELLSOUTH - NC GOLDSBORO GLBONCAD BELLSOUTH - NC GOLDSBORO GLBONCMA BELLSOUTH - NC GRANTHAM GNHMNCMA BELLSOUTH - NC GREENSBORO GNBONCAP BELLSOUTH - NC GREENSBORO GNBONCAS BELLSOUTH - NC GREENSBORO GNBONCHO BELLSOUTH - NC GREENSBORO GNBONCLA BELLSOUTH - NC GREENSBORO GNBONCMC BELLSOUTH - NC GREENSBORO GNBONCPG BELLSOUTH - NC HAMLET HMLTNCMA BELLSOUTH - NC HARTFORD HRFRTNMA BELLSOUTH - NC HENDERSNVILLE HNVLNCCH BELLSOUTH - NC HENDERSNVILLE HNVLNCED BELLSOUTH - NC HENDERSNVILLE HNVLNCMI BELLSOUTH - NC HUNTERSVILLE HSVLNCCE BELLSOUTH - NC JULIAN GNBONCEU BELLSOUTH - NC JULIAN JULNNCMA BELLSOUTH - NC KINGS MT KGMTNCMA BELLSOUTH - NC KNIGHTDALE KNDLNCCE BELLSOUTH - NC LAKE LURE LKLRNCCE BELLSOUTH - NC LATTIMORE LTMRNCCE BELLSOUTH - NC LAURINBURG LRBGNCMA BELLSOUTH - NC LAWNDALE LWDLNCCE BELLSOUTH - NC LEICESTER LCSRNCMA BELLSOUTH - NC LENOIR LENRNCHA BELLSOUTH - NC LENOIR LENRNCHU BELLSOUTH - NC LINCOLNTON LNTNNCMA BELLSOUTH - NC LINCOLNTONB LNTNNCVA BELLSOUTH - NC LOCUST LCSTNCMA BELLSOUTH - NC LONG BEACH LNBHNCMA BELLSOUTH - NC LOWELL LWLLNCMA BELLSOUTH - NC LUMBERTON LMTNNCMA BELLSOUTH - NC MAGGIE VALLEY MGVANCCE BELLSOUTH - NC MAIDEN MADNNCCE BELLSOUTH - NC MONTICELLO MNTINCMA BELLSOUTH - NC MORGANTON MGTNNCGL Federal Communications Commission FCC 08-122 77 LEC NAME WIRE CENTER CLLI BELLSOUTH - NC MORGANTON MGTNNCGR BELLSOUTH - NC MOUNT HOLLY MTHLNCMA BELLSOUTH - NC MOUNT OLIVE MTOLNCCE BELLSOUTH - NC NEWLAND NWLDNCCE BELLSOUTH - NC NEWTON NWTNNCMA BELLSOUTH - NC PEMBROKE PMBRNCCE BELLSOUTH - NC RALEIGH RLGHNCGA BELLSOUTH - NC RALEIGH RLGHNCGL BELLSOUTH - NC RALEIGH RLGHNCHO BELLSOUTH - NC RALEIGH RLGHNCJO BELLSOUTH - NC RALEIGH RLGHNCSB BELLSOUTH - NC RALEIGH RLGHNCSI BELLSOUTH - NC REIDSVILLE RDVLNCMA BELLSOUTH - NC REIDSVILLE RDVLNCSI BELLSOUTH - NC ROCKINGHAM RCHMNCMA BELLSOUTH - NC ROWLANDNC RWLDNCMA BELLSOUTH - NC RUFFIN RFFNNCMA BELLSOUTH - NC RUTHERFORDTON RTTNNCCE BELLSOUTH - NC SAXAPAHAW SXPHNCMA BELLSOUTH - NC SCOTTS HILL1 SCHLNCHA BELLSOUTH - NC SCOTTS HILL2 SCHLNCMA BELLSOUTH - NC SELMA SELMNCMA BELLSOUTH - NC SHELBY SHLBNCMA BELLSOUTH - NC SOUTHPORT SOPTNCCE BELLSOUTH - NC SPRUCE PINE SPPNNCMA BELLSOUTH - NC STANLEY STNLNCCE BELLSOUTH - NC STATESVILLE SSVLNCJE BELLSOUTH - NC STATESVILLE SSVLNCMA BELLSOUTH - NC STONY POINT STPNNCMA BELLSOUTH - NC SUMMERFIELD SRFDNCCE BELLSOUTH - NC SWANNANOA SWNNNCMA BELLSOUTH - NC TAYLORSVILLE TYVLNCMA BELLSOUTH - NC TROUTMAN TRMNNCMA BELLSOUTH - NC WAYNESVILLE WYVLNCMA BELLSOUTH - NC WENDELL WNDLNCPI BELLSOUTH - NC WILMINGTON WLMGNCFO BELLSOUTH - NC WILMINGTON WLMGNCLE BELLSOUTH - NC WILMINGTON WLMGNCWI BELLSOUTH - NC WINSTON SALEM WNSLNCAR BELLSOUTH - NC WINSTON SALEM WNSLNCCL BELLSOUTH - NC WINSTON SALEM WNSLNCFI BELLSOUTH - NC WINSTON SALEM WNSLNCGL BELLSOUTH - NC WINSTON SALEM WNSLNCLE BELLSOUTH - NC WINSTON SALEM WNSLNCVI BELLSOUTH - NC WINSTON SALEM WNSLNCWA BELLSOUTH - NC WINSTON SALEM WNSLNCWH BELLSOUTH - NC WRIGHTSVILLE BEACH WGVLNCMA BELLSOUTH - NC ZEBULON ZBLNNCCE Federal Communications Commission FCC 08-122 78 LEC NAME WIRE CENTER CLLI North State Telephone Company HIGH POINT HGPNNCXA North State Telephone Company HIGH POINT HGPNNCXB North State Telephone Company HIGH POINT HGPNNCXC North State Telephone Company HIGH POINT HGPNNCXD North State Telephone Company HIGH POINT HGPNNCXE North State Telephone Company HIGH POINT HGPNNCXF North State Telephone Company RANDLEMAN RNMNNCXA North State Telephone Company THOMASVILLE THVLNCXA VERIZON SOUTH INC - NC (CONTEL) ANDREWS ANDRNCXA VERIZON SOUTH INC - NC (CONTEL) BAKERSVILLE BAVLNCXA VERIZON SOUTH INC - NC (CONTEL) BRYSON CITY BRCYNCXA VERIZON SOUTH INC - NC (CONTEL) BURNSVILLE BRVLNCXA VERIZON SOUTH INC - NC (CONTEL) CASHIERS CSHRNCXA VERIZON SOUTH INC - NC (CONTEL) CHEROKEE CHRKNCXB VERIZON SOUTH INC - NC (CONTEL) FONTANA FNVLNCXA VERIZON SOUTH INC - NC (CONTEL) FRANKLIN FKLNNCXA VERIZON SOUTH INC - NC (CONTEL) GARDEN CITY GRCYNCXA VERIZON SOUTH INC - NC (CONTEL) GLENWOOD- PROVIDENCE GWPRNCXA VERIZON SOUTH INC - NC (CONTEL) GUNTERTOWN GTTWNCXA VERIZON SOUTH INC - NC (CONTEL) HAYESVILLE HYVLNCXA VERIZON SOUTH INC - NC (CONTEL) HIGHLANDS HGLNNCXA VERIZON SOUTH INC - NC (CONTEL) HIGHLANDS SYLVNCXA VERIZON SOUTH INC - NC (CONTEL) HOT SPRINGS HTSPNCXA VERIZON SOUTH INC - NC (CONTEL) MARION MARNNCXB VERIZON SOUTH INC - NC (CONTEL) MARS HILL MRHLNCXA VERIZON SOUTH INC - NC (CONTEL) MARS HILL WVVLNCXA VERIZON SOUTH INC - NC (CONTEL) MARSHALL MRSHNCXA VERIZON SOUTH INC - NC (CONTEL) MICAVILLE MIVLNCXA Federal Communications Commission FCC 08-122 79 LEC NAME WIRE CENTER CLLI VERIZON SOUTH INC - NC (CONTEL) MURPHY MRPHNCXB VERIZON SOUTH INC - NC (CONTEL) OLD FORT OLFTNCXA VERIZON SOUTH INC - NC (CONTEL) ROBBINSVILLE ROVLNCXA VERIZON SOUTH INC - NC (CONTEL) SEVIER SEVRNCXA VERIZON SOUTH INC - NC (CONTEL) SUIT SUITNCXA VERIZON SOUTH INC – NC (CONTEL) CULLOWHEE CLWHNCXA VERIZON SOUTH INC. - NC DURHAM DRHMNCXB VERIZON SOUTH INC. - NC DURHAM DRHMNCXT VERIZON SOUTH INC. - NC MONROE MONRNCXA VERIZON SOUTH INC. – NC CREEDMOOR CRDMNCXA VERIZON SOUTH INC. – NC CREEDMOOR CRDMNCXM VERIZON SOUTH INC. – NC DURHAM DRHMNCXA VERIZON SOUTH INC. – NC DURHAM DRHMNCXC VERIZON SOUTH INC. – NC DURHAM DRHMNCXD VERIZON SOUTH INC. – NC DURHAM DRHMNCXE VERIZON SOUTH INC. – NC DURHAM DRHMNCXG VERIZON SOUTH INC. – NC DURHAM DRHMNCXM VERIZON SOUTH INC. – NC GOOSECREEK GSCKNCXA Tennessee: LEC NAME WIRE CENTER CLLI BELLSOUTH - TN ROGERSVILLE RRVLTNMA BELLSOUTH - TN SURGOINSVILLE SRVLTNMA Virginia: LEC NAME WIRE CENTER CLLI VERIZON-VIRGINIA, INC. APPALACHIA APLCVAAP VERIZON-VIRGINIA, INC. BIG STONE GAP BSGPVABG VERIZON-VIRGINIA, INC. CLINCHCO CLNCVACL VERIZON-VIRGINIA, INC. CLINTWOOD CLWDVACW VERIZON-VIRGINIA, INC. COEBURN COBNVACB VERIZON-VIRGINIA, INC. COEBURN NRTNVANO VERIZON-VIRGINIA, INC. CUMBERLAND GAP RSHLVALE VERIZON-VIRGINIA, INC. DANTE DANTVADA VERIZON-VIRGINIA, INC. HAYSI HYSIVAHY VERIZON-VIRGINIA, INC. HONAKER HNKRVAHK VERIZON-VIRGINIA, INC. HONAKER SWCKVASC VERIZON-VIRGINIA, INC. JONESVILLE JNVLVAJV VERIZON-VIRGINIA, INC. LEBANON DCVLVADV VERIZON-VIRGINIA, INC. LEBANON LBNNVALB VERIZON-VIRGINIA, INC. LEBANON LBNNVARD Federal Communications Commission FCC 08-122 80 LEC NAME WIRE CENTER CLLI VERIZON-VIRGINIA, INC. PENNINGTON GAP PNGPVAPG VERIZON-VIRGINIA, INC. POUND PONDVAPO VERIZON-VIRGINIA, INC. ST CHARLES STCHVASC VERIZON-VIRGINIA, INC. ST PAUL STPLVASP VERIZON-VIRGINIA, INC. WISE WISEVAWI Federal Communications Commission FCC 08-122 81 EXHIBIT 26 Rural Wire Centers for Inclusion in SunCom’s ETC Service Area North Carolina: LEC NAME WIRE CENTER CLLI ALLTEL CAROLINA INC. - NORTH ABERDEEN ABRDNCXA ALLTEL CAROLINA INC. - NORTH ANSONVILLE ASVLNCXA ALLTEL CAROLINA INC. - NORTH BROADWAY BRWYNCXA ALLTEL CAROLINA INC. - NORTH COLUMBUS CLMBNCXA ALLTEL CAROLINA INC. - NORTH DENTON DNTNNCXA ALLTEL CAROLINA INC. - NORTH GREENCREEK GRCKNCXA ALLTEL CAROLINA INC. - NORTH HEMBY BRIDGE HMBRNCXA ALLTEL CAROLINA INC. - NORTH INDIAN TRAIL INTRNCXA ALLTEL CAROLINA INC. - NORTH KINGNC KINGNCXA ALLTEL CAROLINA INC. - NORTH LAUREL HILL LRHLNCXA ALLTEL CAROLINA INC. - NORTH LEWISVILLE LWVLNCXA ALLTEL CAROLINA INC. - NORTH LILESVILLE LLVLNCXA ALLTEL CAROLINA INC. - NORTH MARSHVILLE MHVLNCXA ALLTEL CAROLINA INC. - NORTH MATTHEWS MTHWNCXB ALLTEL CAROLINA INC. - NORTH MORVEN MRVNNCXA ALLTEL CAROLINA INC. - NORTH NEW SALEM NWSLNCXA ALLTEL CAROLINA INC. - NORTH NORWOOD NRWDNCXA ALLTEL CAROLINA INC. - NORTH OLDTOWN OLTWNCXA ALLTEL CAROLINA INC. - NORTH OLIVIA OLIVNCXA ALLTEL CAROLINA INC. - NORTH PEACHLAND POLKTON PCLDNCXA ALLTEL CAROLINA INC. - NORTH PINEBLUFF PNBLNCXA ALLTEL CAROLINA INC. - NORTH RURAL HALL RRHLNCXA ALLTEL CAROLINA INC. - NORTH SANFORD SNFRNCXA ALLTEL CAROLINA INC. - NORTH STANLEYVILLE SLVLNCXA ALLTEL CAROLINA INC. - NORTH TRYON TRYNNCXA ALLTEL CAROLINA INC. - NORTH WADESBORO MRVINCXA ALLTEL CAROLINA INC. - NORTH WAGRAM WGRMNCXA ALLTEL CAROLINA INC. - NORTH WAXHAW WXHWNCXA ALLTEL CAROLINA INC. - NORTH WINGATE WNGTNCXA ALLTEL CAROLINA INC. – NORTH GRANITE QUARRY- ROCKWELL GRQYNCXA ALLTEL CAROLINA INC. – NORTH WADESBORO WDBONCXA ATLANTIC TEL. MEMBERSHIP CORP. BLNGSPGLKS BSLKNCXA ATLANTIC TEL. MEMBERSHIP CORP. BOLIVIA BOLVNCXA ATLANTIC TEL. MEMBERSHIP CORP. HOLDEN BEACH HLBHNCXB ATLANTIC TEL. MEMBERSHIP CORP. LONGWOOD LGWDNCXA ATLANTIC TEL. MEMBERSHIP CORP. SEASIDE SESDNCXB ATLANTIC TEL. MEMBERSHIP CORP. SHALLOTTE SHLTNCXA BARNARDSVILLE TEL. CO. D/B/A TDS TELECOM BARNARDSVL BDVLNCXA CAROLINA TELEPHONE & TELEGRAPH CO. NEW BERN NWBRNCXA Federal Communications Commission FCC 08-122 82 LEC NAME WIRE CENTER CLLI CENTRAL TELEPHONE COMPANY - NC ASHEBORO ASBONCXA CENTRAL TELEPHONE COMPANY - NC BETHLEHEM BHLHNCXA CENTRAL TELEPHONE COMPANY - NC BISCOE BISCNCXA CENTRAL TELEPHONE COMPANY - NC BOONVILLE BNVLNCXA CENTRAL TELEPHONE COMPANY - NC CANDOR CNDRNCXA CENTRAL TELEPHONE COMPANY - NC CATAWBA CTWBNCXA CENTRAL TELEPHONE COMPANY - NC DANBURY DNBRNCXA CENTRAL TELEPHONE COMPANY - NC DOBSON DBSNNCXB CENTRAL TELEPHONE COMPANY - NC EDENNC EDENNCXA CENTRAL TELEPHONE COMPANY - NC ELKIN ELKNNCXA CENTRAL TELEPHONE COMPANY - NC GRANITE FALLS GRFLNCXA CENTRAL TELEPHONE COMPANY - NC HAYS HAYSNCXA CENTRAL TELEPHONE COMPANY - NC HICKORY HCKRNCXA CENTRAL TELEPHONE COMPANY - NC HILDEBRAN HLDBNCXA CENTRAL TELEPHONE COMPANY - NC HILLSBOROUGH HLBONCXB CENTRAL TELEPHONE COMPANY - NC MADISON MDSNNCXA CENTRAL TELEPHONE COMPANY - NC MOUNT AIRY MTARNCXA CENTRAL TELEPHONE COMPANY - NC MOUNT GILEAD MTGLNCXA CENTRAL TELEPHONE COMPANY - NC MOUNTAIN VIEW MTVWNCXA CENTRAL TELEPHONE COMPANY - NC MULBERRY MLBYNCXB CENTRAL TELEPHONE COMPANY - NC NORTH WILKESBORO NWBONCXA CENTRAL TELEPHONE COMPANY - NC PILOT MOUNTAIN PLMTNCXA CENTRAL TELEPHONE COMPANY - NC QUAKER GAP QKGPNCXA CENTRAL TELEPHONE COMPANY - NC RAMSEUR RMSRNCXA CENTRAL TELEPHONE COMPANY - NC ROARING GAP RNRPNXCA CENTRAL TELEPHONE COMPANY - NC SANDY RIDGE SNRGNCXA CENTRAL TELEPHONE COMPANY - NC SEAGROVE SEGVNCXA CENTRAL TELEPHONE COMPANY - NC SHERRILLS FORD SHFRNCXA CENTRAL TELEPHONE COMPANY - NC STATE ROAD STRDNCXA CENTRAL TELEPHONE COMPANY - NC STONEVILLE STVLNCXA CENTRAL TELEPHONE COMPANY - NC TIMBERLAKE TMLKNCXA CENTRAL TELEPHONE COMPANY - NC TROY TROYNCXA CENTRAL TELEPHONE COMPANY - NC VALDESE VLDSNCXA CENTRAL TELEPHONE COMPANY - NC WALKERTOWN WKTWNCXA CENTRAL TELEPHONE COMPANY - NC WALNUT COVE WLCVNCXA CENTRAL TELEPHONE COMPANY - NC WEST END WENDNCXB CENTRAL TELEPHONE COMPANY - NC WEST JEFFERSON WJSNNCXA CENTRAL TELEPHONE COMPANY - NC YADKINVILLE CRTYNCXA CENTRAL TELEPHONE COMPANY – NC ASHEBORO ASBONCXB CENTRAL TELEPHONE COMPANY – NC EDENNC EDENNCXB CENTRAL TELEPHONE COMPANY – NC HICKORY HCKRNCXB CENTRAL TELEPHONE COMPANY – NC YADKINVILLE YDVLNCXA CENTRAL TELEPHONE COMPANY NC MOCKSVILLE MKVLNCXA CITIZENS TEL. CO. BREVARD BRVRNCXA ELLERBE TELEPHONE COMPANY ELLERBE ELRBNCXA LEXCOM TELEPHONE CO. LEXINGTON LXTNNCXA LEXCOM TELEPHONE CO. LEXINGTON LXTNNCXB LEXCOM TELEPHONE CO. LEXINGTON LXTNNCXC Federal Communications Commission FCC 08-122 83 LEC NAME WIRE CENTER CLLI LEXCOM TELEPHONE CO. LEXINGTON LXTNNCXD LEXCOM TELEPHONE CO. LEXINGTON LXTNNCXE LEXCOM TELEPHONE CO. SOUTHMONT SMNTNCXA LEXCOM TELEPHONE CO. WELCOME WLCMNCXA MEBTEL, INC. MEBANE MEBNNCXA PIEDMONT TELEPHONE MEMBERSHIP CORP. CHURCHLAND CHLDNCXA PIEDMONT TELEPHONE MEMBERSHIP CORP. REEDS REDSNCXA RANDOLPH TEL. CO. LIBERTY LBRTNCXA RANDOLPH TEL. MEMBERSHIP CORP. BADIN LAKE BDLKNCXA RANDOLPH TEL. MEMBERSHIP CORP. BENNETT BNNTNCXA RANDOLPH TEL. MEMBERSHIP CORP. COLERIDGE CLRGNCXA RANDOLPH TEL. MEMBERSHIP CORP. FARMER FRMRNCXA RANDOLPH TEL. MEMBERSHIP CORP. HIGHFALLS HGHFNCXA RANDOLPH TEL. MEMBERSHIP CORP. JACKSON CREEK JKCKNCXA RANDOLPH TEL. MEMBERSHIP CORP. PISGAH PSGHNCXA SALUDA MOUNTAIN TEL. CO. D/B/A TDS TELECOM SALUDA SALDNCXA SERVICE TEL. CO. D/B/A TDS TELECOM FAIR BLUFF FRBLNCXA SKYLINE TEL. MEMBERSHIP CORP. BALDWIN BLDWNCXA SKYLINE TEL. MEMBERSHIP CORP. BANNER ELK BNELNCXA SKYLINE TEL. MEMBERSHIP CORP. BEECH MOUNTAIN BEMTNCXA SKYLINE TEL. MEMBERSHIP CORP. CRESTON CETNNCXA SKYLINE TEL. MEMBERSHIP CORP. GLADECREEK GLCKNCXA SKYLINE TEL. MEMBERSHIP CORP. LANSING LNNGNCXA SKYLINE TEL. MEMBERSHIP CORP. NATHANSCRK NTCKNCXA SKYLINE TEL. MEMBERSHIP CORP. SCOTTVILLE SCVLNCXA SKYLINE TEL. MEMBERSHIP CORP. SPARTA SPRTNCXA SKYLINE TEL. MEMBERSHIP CORP. SUGAR GROVE SGGVNCXA SKYLINE TEL. MEMBERSHIP CORP. WATAUGA WATGNCXA STAR TEL. MEMBERSHIP CORP. ABBOTTSBG ABBGNCXA STAR TEL. MEMBERSHIP CORP. COHARIE COHRNCXA STAR TEL. MEMBERSHIP CORP. CYPRESSCRK CYCKNCXA STAR TEL. MEMBERSHIP CORP. HARRELLS HRLSNCXA STAR TEL. MEMBERSHIP CORP. HERRING HRNGNCXA STAR TEL. MEMBERSHIP CORP. KELLY KLLYNCXA STAR TEL. MEMBERSHIP CORP. LISBON LSBNNCXA STAR TEL. MEMBERSHIP CORP. SIX RUN SXRNNXCA STAR TEL. MEMBERSHIP CORP. SOUTHRIVER SORVNCXA STAR TEL. MEMBERSHIP CORP. WHITE OAK WHOKNCXA SURRY TEL. MEMBERSHIP CORP. BEULAH BELHNCXA SURRY TEL. MEMBERSHIP CORP. LEVELCROSS LVCRNCXA SURRY TEL. MEMBERSHIP CORP. RED BRUSH RDBSNCXA SURRY TEL. MEMBERSHIP CORP. SHOALS SHLSNCXA SURRY TEL. MEMBERSHIP CORP. WESTFIELD WSFDNCXA SURRY TEL. MEMBERSHIP CORP. ZEPHYR ZPHYNCXA THE CONCORD TELEPHONE COMPANY, INC. ALBEMARLE ALBMNCXA THE CONCORD TELEPHONE COMPANY, INC. BADIN BADNNCXA Federal Communications Commission FCC 08-122 84 LEC NAME WIRE CENTER CLLI THE CONCORD TELEPHONE COMPANY, INC. CHINA GROVE- LANDIS CHGVNCXA THE CONCORD TELEPHONE COMPANY, INC. CONCORD CNCRNCXA THE CONCORD TELEPHONE COMPANY, INC. HARRISBURG HRBGNCXA THE CONCORD TELEPHONE COMPANY, INC. KANNAPOLIS KNPLNCXA THE CONCORD TELEPHONE COMPANY, INC. NEW LONDON NWLNNCXA THE CONCORD TELEPHONE COMPANY, INC. OAKBORO OKBONCXA TRI-COUNTY TEL. MEMBERSHIP CORP. PIKE ROAD PKRDNCXA TRI-COUNTY TEL. MEMBERSHIP CORP. PINETOWN PNTWNCXA TRI-COUNTY TEL. MEMBERSHIP CORP. SIDNEY SDNYNCXA WILKES TELEPHONE MEMBERSHIP CORPORATION BOOMER BOMRNXCA WILKES TELEPHONE MEMBERSHIP CORPORATION CHAMPION CHMPNCXA WILKES TELEPHONE MEMBERSHIP CORPORATION CLINGMAN CLNGNCXA WILKES TELEPHONE MEMBERSHIP CORPORATION LOMAX LOMXNCXA YADKIN VALLEY TEL. MEMBERSHIP CORP. ADVANCE ADVNNCXB YADKIN VALLEY TEL. MEMBERSHIP CORP. BROOKS BRKSNCXA YADKIN VALLEY TEL. MEMBERSHIP CORP. COOLEEMEE COLMNCXA YADKIN VALLEY TEL. MEMBERSHIP CORP. EAST BEND EBNDNCXA YADKIN VALLEY TEL. MEMBERSHIP CORP. FORBUSH FRBSNCXB YADKIN VALLEY TEL. MEMBERSHIP CORP. HARMONY HRMYNCXA YADKIN VALLEY TEL. MEMBERSHIP CORP. IJAMES IJAMNCXA YADKIN VALLEY TEL. MEMBERSHIP CORP. NEW HOPE NWHPNCXA YADKIN VALLEY TEL. MEMBERSHIP CORP. UNIONGROVE UNGVNCXB Tennessee: LEC NAME WIRE CENTER CLLI UNITED TELEPHONE INTER-MOUNTAIN - TN BAILEYTON BLTNTNXA UNITED TELEPHONE INTER-MOUNTAIN - TN BLOUNTVILLE BUVLTNXA UNITED TELEPHONE INTER-MOUNTAIN - TN BLUFF CITY- PINEY FLATS BLCYTNXA UNITED TELEPHONE INTER-MOUNTAIN - TN BRISTOL, TN BRSTTNXA UNITED TELEPHONE INTER-MOUNTAIN - TN BRISTOL, TN BRSTTNXB UNITED TELEPHONE INTER-MOUNTAIN - TN BUTLER BTLRTNXA UNITED TELEPHONE INTER-MOUNTAIN - TN CHURCHHILL-MT CARMEL CHHLTNXA UNITED TELEPHONE INTER-MOUNTAIN - TN ELIZABETHTON ELTNTNXA UNITED TELEPHONE INTER-MOUNTAIN - TN ERWIN ERWNTNXA UNITED TELEPHONE INTER-MOUNTAIN - TN FALL BRANCH FLBRTNXA UNITED TELEPHONE INTER-MOUNTAIN - TN GREENEVILLE GRVLTNXA UNITED TELEPHONE INTER-MOUNTAIN - TN HAMPTON HMPNTNXA UNITED TELEPHONE INTER-MOUNTAIN - TN JONESBORO- SULPHUR SPR JNBOTNXA UNITED TELEPHONE INTER-MOUNTAIN - TN KINGSPORT KGPTTNXA UNITED TELEPHONE INTER-MOUNTAIN - TN KINGSPORT KGPTTNXC Federal Communications Commission FCC 08-122 85 LEC NAME WIRE CENTER CLLI UNITED TELEPHONE INTER-MOUNTAIN - TN LIMESTONE LMSTTNXA UNITED TELEPHONE INTER-MOUNTAIN - TN MIDWAY (WASHINGTON CO) MDWYTNXA UNITED TELEPHONE INTER-MOUNTAIN - TN MOSHEIM MOSHTNXA UNITED TELEPHONE INTER-MOUNTAIN - TN MOUNTAIN CITY MTCYTNXA UNITED TELEPHONE INTER-MOUNTAIN - TN ROAN MOUNTAIN RNMTTNXA UNITED TELEPHONE INTER-MOUNTAIN - TN STONEY CREEK STCKTNXA UNITED TELEPHONE INTER-MOUNTAIN - TN SULLIVAN GARDENS SLGRTNXA Virginia: LEC NAME WIRE CENTER CLLI SCOTT COUNTY TEL. COOP. DUFFIELD DFFDVAXA SCOTT COUNTY TEL. COOP. DUNGANNON DNGNVAXA SCOTT COUNTY TEL. COOP. FT BLACKMR FTBCVAXA SCOTT COUNTY TEL. COOP. NICKELSVL NCVLVAXA SCOTT COUNTY TEL. COOP. WILLIAMSML WLMLVAXA Federal Communications Commission FCC 08-122 86 EXHIBIT 27 Non-Rural Wire Centers for Inclusion in U.S. Cellular’s ETC Service Area New Hampshire: LEC NAME WIRE CENTER CLLI Verizon New England Inc. ALSTEAD ALSTNHLIRS1 Verizon New England Inc. ASHLAND ASLDNHHIRS1 Verizon New England Inc. ATKINSON ATSNNHMARS1 Verizon New England Inc. BEDFORD BDFRNHAMRS1 Verizon New England Inc. BETHLEHEM BHLHNHCRRS1 Verizon New England Inc. BELMONT BLMTNHMARS1 Verizon New England Inc. BARRINGTON BNTONHPRRS1 Verizon New England Inc. BERLIN BRLNNHHERS1 Verizon New England Inc. BRISTOL BRSTNHSPRS1 Verizon New England Inc. BARTLETT BRTLNHGERS1 Verizon New England Inc. CANDIA CANDNHDERS1 Verizon New England Inc. CANAAN CANNNHYARS1 Verizon New England Inc. CHARLESTOWN CHTWNHBRRS1 Verizon New England Inc. COLEBROOK CLBKNHMARS1 Verizon New England Inc. CLAREMONT CLMTNHBRRS1 Verizon New England Inc. CAMPTON CMTNNHOWRS1 Verizon New England Inc. CONCORD CNCRNHSODS1 Verizon New England Inc. CENTER HARBOR CNHRNHPLRS1 Verizon New England Inc. CENTER OSSIPEE CNOSNHFORS1 Verizon New England Inc. CTR SANDWICH CNSWNHSLRS1 Verizon New England Inc. CANTERBURY CNTRNHSHRS1 Verizon New England Inc. N CONWAY CNWYNHYARS1 Verizon New England Inc. DUBLIN DBLNNHMORS1 Verizon New England Inc. DANBURY DNBRNHDBRS1 Verizon New England Inc. DEERFIELD DRFDNHCCRS1 Verizon New England Inc. DERRY DRRYNHEBDS1 Verizon New England Inc. ENFIELD ENFDNHNMRS1 Verizon New England Inc. EPPING EPNGNHMARS1 Verizon New England Inc. EPSOM EPSMNHBHRS1 Verizon New England Inc. ERROL ERRLNHYARS1 Verizon New England Inc. FRANKLIN FKLNNHFRRS1 Verizon New England Inc. FRANCONIA FRNCNHWHRS1 Verizon New England Inc. FARMINGTON FRTNNHMGRS1 Verizon New England Inc. FITZWILLIAM FTZWNHUTRS1 Verizon New England Inc. GOFFSTOWN GFTWNHWHRS1 Verizon New England Inc. GLENDALE GLDLNHABRS1 Verizon New England Inc. GREENFIELD GNFDNHMARS1 Verizon New England Inc. GREENVILLE GNVLNHADRS1 Verizon New England Inc. GORHAM GRHMNHLARS1 Verizon New England Inc. GROVETON GVTNNHSTRS1 Verizon New England Inc. HAMPSTEAD HMPSNHMARS1 Verizon New England Inc. HANCOCK HNCCNHSCRS1 Verizon New England Inc. HINSDALE HNDLNHMARS1 Federal Communications Commission FCC 08-122 87 LEC NAME WIRE CENTER CLLI Verizon New England Inc. HANOVER HNVRNHSCDS0 Verizon New England Inc. HARRISVILLE HRVLNHMARS1 Verizon New England Inc. JACKSON JCSNNHTHRS1 Verizon New England Inc. JAFFREY JFRYNHRIRS1 Verizon New England Inc. JEFFERSON JFSNNHYARS1 Verizon New England Inc. KEENE KEENNHWADS0 Verizon New England Inc. LACONIA LACNNHNMDS0 Verizon New England Inc. LEBANON LBNNNHBARS1 Verizon New England Inc. LANCASTER LNCSNHHIRS1 Verizon New England Inc. LISBON LSBNNHMARS1 Verizon New England Inc. LITTLETON LTTNNHPLDS0 Verizon New England Inc. LYME LYMENHYARS1 Verizon New England Inc. MADISON MDSNNHYARS1 Verizon New England Inc. MILAN MILNNHPLRS1 Verizon New England Inc. MOULTONBORO MLBONHYARS1 Verizon New England Inc. MILFORD MLFRNHSODS0 Verizon New England Inc. MILTON MLTNNHSIRS1 Verizon New England Inc. MANCHESTER MNCHNHCODS2 Verizon New England Inc. MARLBORO MRBONHYARS1 Verizon New England Inc. MEREDITH MRDTNHWARS1 Verizon New England Inc. MARLOW MRLWNHYARS1 Verizon New England Inc. MERRIMACK MRMCNHYADS1 Verizon New England Inc. MILTON MILLS MTMLNHWERS1 Verizon New England Inc. NASHUA NASHNHGRRS1 Verizon New England Inc. NASHUA NASHNHWPDS1 Verizon New England Inc. NEW BOSTON NBTNNHHPRS1 Verizon New England Inc. NORTH CONWAY NCWYNHKERS1 Verizon New England Inc. NORTH STRATFORD NSFRNHMARS1 Verizon New England Inc. N WOODSTOCK NWDSNHMARS1 Verizon New England Inc. NORTHWOOD NWODNHYARS1 Verizon New England Inc. NEWPORT NWPTNHMADS0 Verizon New England Inc. PIKE PIKENHPIRS1 Verizon New England Inc. PELHAM PLHMNHBRDS0 Verizon New England Inc. PLYMOUTH PLMONHLHRS1 Verizon New England Inc. PLAISTOW PLSTNHMADS0 Verizon New England Inc. CONCORD PNCKNHCHRS1 Verizon New England Inc. PITTSFIELD PTFDNHBRRS1 Verizon New England Inc. PETERBOROUGH PTRBNHCORS1 Verizon New England Inc. RUMNEY RMNYNHSLRS1 Verizon New England Inc. RINDGE RNDGNHCERS1 Verizon New England Inc. ROCHESTER ROCHNHWEDS0 Verizon New England Inc. RAYMOND RYMNNHFLDS0 Verizon New England Inc. SALEM SALMNHNBDS1 Verizon New England Inc. SANBORNVILLE SBVLNHCSRS1 Verizon New England Inc. SULLIVAN SLLVNHYARS1 Verizon New England Inc. SUNCOOK SNCKNHPARS1 Verizon New England Inc. SPOFFORD SPFRNHMSRS1 Verizon New England Inc. SUNAPEE SUNPNHMCRS1 Federal Communications Commission FCC 08-122 88 LEC NAME WIRE CENTER CLLI Verizon New England Inc. TILTON TLTNNHPRRS1 Verizon New England Inc. TAMWORTH TMWONHWHRS1 Verizon New England Inc. TROY TROYNHPRRS1 Verizon New England Inc. TWIN MOUNTAIN TWMTNHYARS1 Verizon New England Inc. WOODSVILLE WDVLNHJLRS1 Verizon New England Inc. WEIRS WERSNHSTRS1 Verizon New England Inc. WHITEFIELD WHFDNHPLRS1 Verizon New England Inc. WOLFEBORO WLBONHGSRS1 Verizon New England Inc. WALPOLE WLPLNHWPRS1 Verizon New England Inc. WESTMORELAND WMLDNHWERS1 Verizon New England Inc. WINCHESTER WNCHNHMIRS1 Verizon New England Inc. WARREN WRRNNHMARS1 Verizon New England Inc. WATERVILLE VALLEY WVVYNHMRRS1 North Carolina: LEC NAME WIRE CENTER CLLI Central Telephone Co. - Virginia Virgilina VRGLVAXA Verizon South, Inc. - NC Durham DRHMNCXB Verizon South, Inc. - NC Durham DRHMNCXE Verizon South, Inc. - NC Durham DRHMNCXM Verizon South, Inc. - NC Durham DRHMNCXC Verizon South, Inc. - NC Durham DRHMNCXT Verizon South, Inc. - NC Durham DRHMNCXD Verizon South, Inc. - NC Butner CRDMNCXA Verizon South, Inc. - NC Creedmoor CRDMNCXM Verizon South, Inc. - NC (Contel) Hot Springs HTSPNCXA Verizon South, Inc. - NC (Contel) Guntertown GTTWNCXA Verizon South, Inc. - NC (Contel) Marshall MRSHNCXA Verizon South, Inc. - NC (Contel) Mars Hill MRHLNCXA Verizon South, Inc. - NC (Contel) Weaverville WVVLNCXA Verizon South, Inc. - NC (Contel) Burnsville BRVLNCXA Verizon South, Inc. - NC (Contel) Burnsville MIVLNCXA Verizon South, Inc. - NC (Contel) Bakersville BAVLNCXA Verizon South, Inc. - NC (Contel) Old Fort OLFTNCXA Verizon South, Inc. - NC (Contel) Marion GWPRNCXA Verizon South, Inc. - NC (Contel) Marion GRCYNCXA Verizon South, Inc. - NC (Contel) Sevier SEVRNCXA Verizon South, Inc. - NC (Contel) Marion MARNNCXA Bell South Telecomm, Inc. d/b/a Southern Bell Tel Clyde CLYDNCMA Bell South Telecomm, Inc. d/b/a Southern Bell Tel Canton CNTNNCMA Bell South Telecomm, Inc. d/b/a Southern Bell Tel Candler ENKANCMA Bell South Telecomm, Inc. d/b/a Southern Bell Tel Horseshoe HNVLNCMI Bell South Telecomm, Inc. d/b/a Southern Bell Tel Hendersonville HNVLNCCH Bell South Telecomm, Inc. d/b/a Southern Bell Tel Leichester LCSRNCMA Bell South Telecomm, Inc. d/b/a Southern Bell Tel Asheville AHVLNCOH Bell South Telecomm, Inc. d/b/a Southern Bell Tel Asheville AHVLNCOT Federal Communications Commission FCC 08-122 89 LEC NAME WIRE CENTER CLLI Bell South Telecomm, Inc. d/b/a Southern Bell Tel Asheville AHVLNCBI Bell South Telecomm, Inc. d/b/a Southern Bell Tel Hendersonville HNVLNCED Bell South Telecomm, Inc. d/b/a Southern Bell Tel Fairview FRVWNCMA Bell South Telecomm, Inc. d/b/a Southern Bell Tel Arden ARDNNCCE Bell South Telecomm, Inc. d/b/a Southern Bell Tel Swannanoa SWNNNCMA Bell South Telecomm, Inc. d/b/a Southern Bell Tel Black Mount BCMTNCCE Bell South Telecomm, Inc. d/b/a Southern Bell Tel Lake Lure LKLRNCCE Bell South Telecomm, Inc. d/b/a Southern Bell Tel Spruce Pine SPPNNCMA Bell South Telecomm, Inc. d/b/a Southern Bell Tel Rutherfordton RTTNNCCE Bell South Telecomm, Inc. d/b/a Southern Bell Tel Newland NWLDNCCE Bell South Telecomm, Inc. d/b/a Southern Bell Tel Morganton MGTNNCGL Bell South Telecomm, Inc. d/b/a Southern Bell Tel Morganton MGTNNCGR Bell South Telecomm, Inc. d/b/a Southern Bell Tel Boone BOONNCYI Bell South Telecomm, Inc. d/b/a Southern Bell Tel Lenoir LENRNCHA Bell South Telecomm, Inc. d/b/a Southern Bell Tel First City FRCYNCCE Bell South Telecomm, Inc. d/b/a Southern Bell Tel Ellenboro ELBONCMA Bell South Telecomm, Inc. d/b/a Southern Bell Tel Caroleen CRLNNCMA Bell South Telecomm, Inc. d/b/a Southern Bell Tel Lattimore LTMRNCCE Bell South Telecomm, Inc. d/b/a Southern Bell Tel Shelby SHLBNCMA Bell South Telecomm, Inc. d/b/a Southern Bell Tel Lawndale LWDLNCCE Bell South Telecomm, Inc. d/b/a Southern Bell Tel Grover GRVRNCMA Bell South Telecomm, Inc. d/b/a Southern Bell Tel Cherryville CHVLNCCE Bell South Telecomm, Inc. d/b/a Southern Bell Tel Vale LNNNNCVA Bell South Telecomm, Inc. d/b/a Southern Bell Tel Newton NWTNNCMA Bell South Telecomm, Inc. d/b/a Southern Bell Tel Taylorsville TYVLNCMA Bell South Telecomm, Inc. d/b/a Southern Bell Tel Hamlet HMLTNCMA Bell South Telecomm, Inc. d/b/a Southern Bell Tel Laurenburg LRBGNCMA Bell South Telecomm, Inc. d/b/a Southern Bell Tel Rowland RWLDNCMA Bell South Telecomm, Inc. d/b/a Southern Bell Tel Pembroke PMBRNCCE Bell South Telecomm, Inc. d/b/a Southern Bell Tel Fairmont FAMTNCMA Bell South Telecomm, Inc. d/b/a Southern Bell Tel Lumberton LMTNNCMA Bell South Telecomm, Inc. d/b/a Southern Bell Tel Acme ACMENCMA Bell South Telecomm, Inc. d/b/a Southern Bell Tel Atkinson ATSNNCMA Bell South Telecomm, Inc. d/b/a Southern Bell Tel Wilmington WLMGNCLE Bell South Telecomm, Inc. d/b/a Southern Bell Tel South Point SOPTNCCE Bell South Telecomm, Inc. d/b/a Southern Bell Tel Long Beach LNBHNCMS Bell South Telecomm, Inc. d/b/a Southern Bell Tel Carolina Beach CRBHNCCE Bell South Telecomm, Inc. d/b/a Southern Bell Tel Wilmington WGVLNCMA Bell South Telecomm, Inc. d/b/a Southern Bell Tel Wilmington WLMGNCFO Bell South Telecomm, Inc. d/b/a Southern Bell Tel Wilmington WLMGNCCE Bell South Telecomm, Inc. d/b/a Southern Bell Tel Castle Hane CSHYNCMA Bell South Telecomm, Inc. d/b/a Southern Bell Tel Burgaw BRGWNCMA Bell South Telecomm, Inc. d/b/a Southern Bell Tel Hampsted SCHLNCHA Bell South Telecomm, Inc. d/b/a Southern Bell Tel Goldsboro GNHMNCMA Bell South Telecomm, Inc. d/b/a Southern Bell Tel Mount Olive MTOLNCCE Bell South Telecomm, Inc. d/b/a Southern Bell Tel Goldsboro GLBONCMA Bell South Telecomm, Inc. d/b/a Southern Bell Tel Goldsboro GLBONCAD Bell South Telecomm, Inc. d/b/a Southern Bell Tel Selma SELMNCMA Federal Communications Commission FCC 08-122 90 LEC NAME WIRE CENTER CLLI Bell South Telecomm, Inc. d/b/a Southern Bell Tel Garner RLGHNCGA Bell South Telecomm, Inc. d/b/a Southern Bell Tel Apex APEXNCCE Bell South Telecomm, Inc. d/b/a Southern Bell Tel Raleigh RLGHNC Bell South Telecomm, Inc. d/b/a Southern Bell Tel Raleigh RLGHNCAB Bell South Telecomm, Inc. d/b/a Southern Bell Tel Knight Dale KNDLNCCE Bell South Telecomm, Inc. d/b/a Southern Bell Tel Wendell WNDLNCPI Bell South Telecomm, Inc. d/b/a Southern Bell Tel Zebulon ZBLNNCCE Bell South Telecomm, Inc. d/b/a Southern Bell Tel Cary CARYNCCE Bell South Telecomm, Inc. d/b/a Southern Bell Tel Chapel Hill CPHLNCRO Bell South Telecomm, Inc. d/b/a Southern Bell Tel Graham SXPHNCMA Bell South Telecomm, Inc. d/b/a Southern Bell Tel Raleigh RLGHNCSI Bell South Telecomm, Inc. d/b/a Southern Bell Tel Burlington BURLNCDA Bell South Telecomm, Inc. d/b/a Southern Bell Tel Burlington BURLNCHA Bell South Telecomm, Inc. d/b/a Southern Bell Tel Gibsonville GBVLNCXA Bell South Telecomm, Inc. d/b/a Southern Bell Tel Elon College BURLNCEL Bell South Telecomm, Inc. d/b/a Southern Bell Tel Greensboro GNBONCLA Bell South Telecomm, Inc. d/b/a Southern Bell Tel Greensboro GNBONCMC Bell South Telecomm, Inc. d/b/a Southern Bell Tel Monticello MNTINCMA Bell South Telecomm, Inc. d/b/a Southern Bell Tel Summerfield SRFDNCCE Bell South Telecomm, Inc. d/b/a Southern Bell Tel Reidsville RDVLNCMA Bell South Telecomm, Inc. d/b/a Southern Bell Tel Reidsville RDVLNCSI Bell South Telecomm, Inc. d/b/a Southern Bell Tel Ruffin RFFNNCMA Bell South Telecomm, Inc. d/b/a Southern Bell Tel Anderson ARSNNCMA Bell South Telecomm, Inc. d/b/a Southern Bell Tel Gatewood GTWDNCMA Bell South Telecomm, Inc. d/b/a Southern Bell Tel Milton MLTNNCMA Tennessee: LEC NAME WIRE CENTER CLLI BellSouth Telecomm Inc d/b/a South Central Bell Tel ATHENS ATHNTNMA BellSouth Telecomm Inc d/b/a South Central Bell Tel BULLS GAP BLGPTNMA BellSouth Telecomm Inc d/b/a South Central Bell Tel BENTON BNTNTNMT BellSouth Telecomm Inc d/b/a South Central Bell Tel CHARLESTON CHTNTNMT BellSouth Telecomm Inc d/b/a South Central Bell Tel CLINTON CLTNTNMA BellSouth Telecomm Inc d/b/a South Central Bell Tel COPPERBSIN CRHLTNCB BellSouth Telecomm Inc d/b/a South Central Bell Tel CUMBERLDGP CLDGTNMA BellSouth Telecomm Inc d/b/a South Central Bell Tel DANDRIDGE DNRGTNMA BellSouth Telecomm Inc d/b/a South Central Bell Tel DAYTON DYTNTNMA BellSouth Telecomm Inc d/b/a South Central Bell Tel DECATUR DCTRTNMT Federal Communications Commission FCC 08-122 91 LEC NAME WIRE CENTER CLLI BellSouth Telecomm Inc d/b/a South Central Bell Tel ETOWAH ETWHTNMT BellSouth Telecomm Inc d/b/a South Central Bell Tel FRIENDSVL FIVLTNMA BellSouth Telecomm Inc d/b/a South Central Bell Tel GATLINBURG GTBGTNMT BellSouth Telecomm Inc d/b/a South Central Bell Tel GEORGETOWN CLEVTNMA BellSouth Telecomm Inc d/b/a South Central Bell Tel GREENBACK GRNBTNMA BellSouth Telecomm Inc d/b/a South Central Bell Tel HARRIMAN HIMNTNMA BellSouth Telecomm Inc d/b/a South Central Bell Tel HARTFORD HRFRTNMA BellSouth Telecomm Inc d/b/a South Central Bell Tel HARTSVILLE HTVLTNMA BellSouth Telecomm Inc d/b/a South Central Bell Tel JEFFERSNCY JFCYTNMA BellSouth Telecomm Inc d/b/a South Central Bell Tel JELLICO JLLCTNMA BellSouth Telecomm Inc d/b/a South Central Bell Tel KINGSTON KGTNTNMT BellSouth Telecomm Inc d/b/a South Central Bell Tel KNOXVILLE KNVLTNBE BellSouth Telecomm Inc d/b/a South Central Bell Tel KNOXVILLE KNVLTNFC BellSouth Telecomm Inc d/b/a South Central Bell Tel KNOXVILLE KNVLTNMA BellSouth Telecomm Inc d/b/a South Central Bell Tel KNOXVILLE KNVLTNWH BellSouth Telecomm Inc d/b/a South Central Bell Tel KNOXVILLE KNVLTNYH BellSouth Telecomm Inc d/b/a South Central Bell Tel LAFOLLETTE LFLTTNMA BellSouth Telecomm Inc d/b/a South Central Bell Tel LAKE CITY LKCYTNMA BellSouth Telecomm Inc d/b/a South Central Bell Tel LENOIRCITY LNCYTNMA BellSouth Telecomm Inc d/b/a South Central Bell Tel LOUDON LODNTNMA BellSouth Telecomm Inc d/b/a South Central Bell Tel MARYVILLE MAVLTNMA BellSouth Telecomm Inc d/b/a South Central Bell Tel MADISONVL MDVITNMT BellSouth Telecomm Inc d/b/a South Central Bell Tel MORRISTOWN MRTWTNMA BellSouth Telecomm Inc d/b/a South Central Bell Tel MASCOT MSCTTNMT Federal Communications Commission FCC 08-122 92 LEC NAME WIRE CENTER CLLI BellSouth Telecomm Inc d/b/a South Central Bell Tel MAYNARDVL MYVLTNMA BellSouth Telecomm Inc d/b/a South Central Bell Tel NORRIS NRRSTNMA BellSouth Telecomm Inc d/b/a South Central Bell Tel NEWPORT NWPTTNMT BellSouth Telecomm Inc d/b/a South Central Bell Tel OAK RIDGE OKRGTNMT BellSouth Telecomm Inc d/b/a South Central Bell Tel OLIVER SPG OLSPTNMA BellSouth Telecomm Inc d/b/a South Central Bell Tel ROCKWOOD RKWDTNMA BellSouth Telecomm Inc d/b/a South Central Bell Tel ROGERSVL RRVLTNMA BellSouth Telecomm Inc d/b/a South Central Bell Tel SNEEDVILLE SNVLTNMA BellSouth Telecomm Inc d/b/a South Central Bell Tel SPRINGCITY SPCYTNMT BellSouth Telecomm Inc d/b/a South Central Bell Tel SEVIERVL SVVLTNMT BellSouth Telecomm Inc d/b/a South Central Bell Tel SWEETWATER SWTSTNMT BellSouth Telecomm Inc d/b/a South Central Bell Tel TOWNSEND TWNSTNMA BellSouth Telecomm Inc d/b/a South Central Bell Tel WHITE PINE WHPITNMA Virginia: LEC NAME WIRE CENTER CLLI Verizon South Inc. – VA (Contel) ALLWOOD ALWDVAXA Verizon South Inc. – VA (Contel) AMHERST AMHRVAXA Verizon South Inc. – VA (Contel) APPOMATTOX APMTVAXA Verizon South Inc. – VA (Contel) BARNESVL BRVIVAXA Verizon South Inc. – VA (Contel) CLARKSVL CLVLVAXA Verizon South Inc. – VA (Contel) CHASE CITY CSCYVAXA Verizon South Inc. – VA (Contel) DRAKESBRCH DRBRVAXA Verizon South Inc. – VA (Contel) ELKTON EKTNVAXA Verizon South Inc. – VA (Contel) GLADSTONE GLDSVAXA Verizon South Inc. – VA (Contel) GROTTOES GRTSVAXA Verizon South Inc. – VA (Contel) KEYSVILLE KYVLVAXA Verizon South Inc. – VA (Contel) RAPHINE RPHNVAXA Verizon Virginia, Inc. BUCHANAN BCHNVABH Verizon Virginia BEDFORD BDFRVABD Verizon Virginia BIG ISLAND BGISVABI Verizon Virginia BLACKSBURG BLBGVABB Verizon Virginia CRIGLERSVL CGVLVACL Verizon Virginia CHATHAM CHHMVACH Federal Communications Commission FCC 08-122 93 LEC NAME WIRE CENTER CLLI Verizon Virginia MADISON CLPPVARV Verizon Virginia CLOVER CLVRVACL Verizon Virginia CUMBERLAND CMLDVACU Verizon Virginia CHRISTISBG CRBGVACB Verizon Virginia CRAIGSVL CRVIVACV Verizon Virginia CARTERSVL CRVLVACV Verizon Virginia DANVILLE DAVLVADA Verizon Virginia DANVILLE DAVLVAFP Verizon Virginia RINGGOLD DAVLVAWE Verizon Virginia DUBLIN DBLNVADU Verizon Virginia FIFE FIFEVAFI Verizon Virginia GREENWOOD GNWDVAGW Verizon Virginia GORDONSVL GOVLVAGV Verizon Virginia HONAKER HNKRVAHK Verizon Virginia W LEBANON LBNNVALB Verizon Virginia LEBANON LBNNVARD Verizon Virginia LOUISA LOUSVALU Verizon Virginia LOVINGSTON LVTNVALN Verizon Virginia LYNCHBURG LYBGVACH Verizon Virginia LYNCHBURG LYBGVACV Verizon Virginia LYNCHBURG LYBGVAMH Verizon Virginia LYNCHBURG LYBGVANL Verizon Virginia LYNCHBURG LYBGVAOF Verizon Virginia LYNCHBURG LYBGVATM Verizon Virginia LYNCHBURG LYBGVAYB Verizon Virginia MADISON MDSNVAMA Verizon Virginia NELLYSFORD NLFRVANF Verizon Virginia NARROWS NRWSVANA Verizon Virginia ORANGE ORNGVAOR Verizon Virginia PULASKI PLSKVAPU Verizon Virginia PINEYRIVER PNRVVAPR Verizon Virginia PEARISBURG PRBGVAPB Verizon Virginia POWHATAN PWHTVAPW Verizon Virginia RADFORD RDFRVARA Verizon Virginia ROANOKE RONKVABK Verizon Virginia ROANOKE RONKVABS Verizon Virginia ROANOKE RONKVACS Verizon Virginia ROANOKE RONKVACV Verizon Virginia ROANOKE RONKVAGC Verizon Virginia ROANOKE RONKVALK Verizon Virginia SALEM SALMVAFL Verizon Virginia SALEM SALMVAMC Verizon Virginia SALEM SALMVASA Verizon Virginia SHAWSVILLE SHVLVASW Verizon Virginia STONE MT SNMTVASM Verizon Virginia STAUNTON STTNVAST Federal Communications Commission FCC 08-122 94 LEC NAME WIRE CENTER CLLI Verizon Virginia SWORDS CRK SWCKVASC Verizon Virginia ROANOKE SWVLVASV Verizon Virginia LOVINGSTON WNTRVAWG EXHIBIT 28 Rural Wire Centers for Inclusion in U.S. Cellular’s ETC Service Area New Hampshire: LEC NAME WIRE CENTER CLLI Bretton Woods Telephone Co. BRETTON WOODS BTWDNHXADS0 Dunbarton Telephone Co. DUNBARTON DNTNNHXADS0 Hollis Telephone Company Inc. HOLLIS HLLSNHXADS0 Kearsage Telephone Co. ANDOVER ANDVNHXARS1 Kearsage Telephone Co. CONCORD BSCWNHXARS1 Kearsage Telephone Co. CHICHESTER CHCHNHXADS1 Kearsage Telephone Co. MERIDEN MRDNNHXADS1 Kearsage Telephone Co. NEW LONDON NWLNNHXADS0 Kearsage Telephone Co. SALISBURY SLBRNHXARS1 Merrimack County Telephone Co. d/b/a Contoocook Valley ANTRIM ANTRNHXARS3 Merrimack County Telephone Co. d/b/a Contoocook Valley HILLSBORO HLBONHXADS0 Merrimack County Telephone Co. d/b/a Contoocook Valley HENNIKER HNKRNHXARS2 Merrimack County Telephone Co. d/b/a Contoocook Valley MOULTONBOR OUGH MLVGNHXADS0 Merrimack County Telephone Co. BRADFORD BRFRNHXARS2 Merrimack County Telephone Co. CONTOOCOOK CNTCNHXADS1 Merrimack County Telephone Co. NEWBURY STTNNHXARS2 Merrimack County Telephone Co. WARNER WRNRNHXARS2 Union Telephone Co. – New Hampshire ALTON ALTNNHXADS0 Union Telephone Co. – New Hampshire BARNSTEAD BRNSNHXADS0 Union Telephone Co. – New Hampshire CENTER BARNSTEAD CNBNNHXADS0 Union Telephone Co. – New Hampshire CTR SANDWICH GLTNNHXADS0 Union Telephone Co. – New Hampshire NEW DURHAM NWDRNHXADS0 Wilton Telephone Co. WILTON WLTONHXADS0 North Carolina: LEC NAME WIRE CENTER CLLI Tri -County Telephone Membership Corporation Pine Town PNTWNCXA Federal Communications Commission FCC 08-122 95 LEC NAME WIRE CENTER CLLI Tri -County Telephone Membership Corporation Pantego PKRDNCXA Tri -County Telephone Membership Corporation Bath SDNYNCXA Atlantic Telephone Membership Corporation Longwood LGWDNCXA Atlantic Telephone Membership Corporation Ocean Island Beach SESDNCXA Atlantic Telephone Membership Corporation Shallotte SHLTNCXA Atlantic Telephone Membership Corporation Bolivia BOLVNCXA Atlantic Telephone Membership Corporation Supply HLBHNCXA Atlantic Telephone Membership Corporation Boiling Spring Lake BSLKMOXA Barnardsville Telephone Company Barnardsville BDVLNCXA Saluda Mountain Telephone Company Saluda SALDNCXA Star Telephone Membership Corporation Bladenboro ABBGNCXA Star Telephone Membership Corporation Lisbon LSBNNCXA Star Telephone Membership Corporation Kelly KLLYNCXA Star Telephone Membership Corporation Harrells HRLSNCXA Star Telephone Membership Corporation Cypress Creek CYCKNCXA Star Telephone Membership Corporation White Oak WHOKNCXA Star Telephone Membership Corporation Herring HRNGNCXA Star Telephone Membership Corporation Turkey SXRNNCXA Star Telephone Membership Corporation Dunn COHRNCXA Star Telephone Membership Corporation Roseboro SORVNCXA Star Telephone Membership Corporation South River SORYNCXA Service Telephone Company Fair Bluff FRBLNCXA Surry Telephone Membership Corporation Beulah BELHNCXA Surry Telephone Membership Corporation Dobson DBSNNCXA Surry Telephone Membership Corporation Level Cross LVCRNCXA Surry Telephone Membership Corporation Red Brush RDBSNCXA Surry Telephone Membership Corporation Shoals SHLSNCXA Surry Telephone Membership Corporation Westfield WSFDNCXA Surry Telephone Membership Corporation Zephyr ZPHYNCXA Wilkes Telephone Membership Corp. Boomer BOMRNCXA Wilkes Telephone Membership Corp. Ferguson CHMPNCXA Wilkes Telephone Membership Corp. Clingman CLNGNCXA Wilkes Telephone Membership Corp. No. Wilkesboro HAYSNCXA Wilkes Telephone Membership Corp. Lomax LOMXNCXA Wilkes Telephone Membership Corp. No. Wilkesboro MLBYNCXA Wilkes Telephone Membership Corp. No. Wilkesboro NWBONCXA Tennessee: LEC NAME WIRE CENTER CLLI CenturyTel of Clairborne, Inc. NEWTAZWELL NWTZTNXA CenturyTel of Clairborne, Inc. SHARPSCHPL SHCPTNXA Citizens Telecom – Vol St DBA Frontier Vol. State CLAXTON CXTNTNXA Citizens Telecom – Vol St DBA Frontier Vol. State POWELL POWLTNXA Citizens Telecom – Vol St DBA Frontier Vol. State RUTLEDGE RTLGTNXA Citizens Telecom – Vol St DBA Frontier Vol. State TATE SPG TTSPTNXA Citizens Telecom – Vol St DBA Frontier Vol. State WASHBURN WSBNTNXA Concord Telephone Exchange, Inc. CONCORD CNCRTNXA Highland Telephone Coop., Inc. – TN DEER LODGE DRLDTNXA Federal Communications Commission FCC 08-122 96 LEC NAME WIRE CENTER CLLI Highland Telephone Coop., Inc. – TN HUNTSVILLE HNVITNXA Highland Telephone Coop., Inc. – TN OAKDALE OKDLTNXA Highland Telephone Coop., Inc. – TN ONEIDA ONEDTNXA Highland Telephone Coop., Inc. – TN PETROS PTRSTNXA Highland Telephone Coop., Inc. – TN ROBBINS RBNSTNXA Highland Telephone Coop., Inc. – TN SUNBRIGHT SNBRTNXA Highland Telephone Coop., Inc. – TN WARTBURG WABGTNXA Tellico Telephone Co., Inc. BALL PLAY BLPLTNXA Tellico Telephone Co., Inc. COKERCREEK CKCKTNXA Tellico Telephone Co., Inc. ENGLEWOOD ENWDTNXA Tellico Telephone Co., Inc. NIOTA NIOTTNXA Tellico Telephone Co., Inc. RICEVILLE RCVLTNXA Tellico Telephone Co., Inc. TELLICO PL TLPLTNXA Tellico Telephone Co., Inc. VONORE VONRTNXA Virginia: LEC NAME WIRE CENTER CLLI Burke’s Garden Telephone Co., Inc. BURKESGRDN BRGRVAXA Citizens Telephone Cooperative ALUM RIDGE ALRGVAXA Citizens Telephone Cooperative BALLARD BLLRVAXA Citizens Telephone Cooperative FLOYD FLYDVAXA Citizens Telephone Cooperative LOCUST GRV LCGVVAXA Citizens Telephone Cooperative WILLIS WILSVAXA New Castle Telephone Co. NEW CASTLE NWCSVAXA New Castle Telephone Co. PAINT BANK PNBNVAXA Pembroke Telephone Cooperative NEWPORT NWPTVAXA Pembroke Telephone Cooperative PEMBROKE PMBRVAXA Roanoke & Botetourt Telephone Co. EAGLE ROCK EGRKVAXA Roanoke & Botetourt Telephone Co. FINCASTLE FNCSVAXA Roanoke & Botetourt Telephone Co. ORISKANY ORSKVAXA Roanoke & Botetourt Telephone Co. TROUTVILLE TRVLVAXA EXHIBIT 29 Rural Service Areas Requiring Reclassification Along Wire Center Boundaries For Inclusion In U.S. Cellular’s ETC Service Area New Hampshire:2 LEC NAME WIRE CENTER CLLI Granite State Telephone Inc. Hillsboro Upper Village HUVGNHXADS0 2 Previously redefined, as discussed above. Federal Communications Commission FCC 08-122 97 Granite State Telephone Inc. Washington WASHNHXADS0 Granite State Telephone Inc. Weare WEARNHXADS0 Federal Communications Commission FCC 08-122 98 North Carolina: LEC NAME WIRE CENTER CLLI Alltel Carolina - North, Inc. Aberdeen ABRDNCXA Alltel Carolina - North, Inc. Broadway BRWYNCXA Alltel Carolina - North, Inc. Columbus CLMBNCXA Alltel Carolina - North, Inc. Green Creek GRCKNCXA Alltel Carolina - North, Inc. King KINGNCXA Alltel Carolina - North, Inc. Olivia OLIVNCXA Alltel Carolina - North, Inc. Pine Bluff PNBLNCXA Alltel Carolina - North, Inc. Sanford SNFRNCXA Alltel Carolina - North, Inc. Tryon TRYNNCXA Alltel Carolina - North, Inc. Wagram WGRNNCXA Central Telephone Co. - North Carolina Boonville BNVLNCXA Central Telephone Co. - North Carolina Dobson DBSNNCXB Central Telephone Co. - North Carolina Danbury DNBRNCXA Central Telephone Co. - North Carolina Eden 1 EDENNCXA Central Telephone Co. - North Carolina Eden 2 EDENNCXB Central Telephone Co. - North Carolina Elkin ELKNNCXA Central Telephone Co. - North Carolina Madison MDSNNCXA Central Telephone Co. - North Carolina Mount Airy MTARNCXA Central Telephone Co. - North Carolina Pilot Mt PLMTNCXA Central Telephone Co. - North Carolina Prospect Hill PRHLNCXA Central Telephone Co. - North Carolina Roaring Gap RRGPNCXA Central Telephone Co. - North Carolina Roxboro RXBONCXA Central Telephone Co. - North Carolina State Road STRDNCXA Central Telephone Co. - North Carolina Stoneville STVLNCXA Central Telephone Co. - North Carolina Rougemont TMLKNCXA Central Telephone Co. - North Carolina Wend WENDNCXA Central Telephone Co. - North Carolina W. Jefferson WJSNNCXA Central Telephone Co. - North Carolina Walnut Cove 1 QKGPNCXA Central Telephone Co. - North Carolina Walnut Cove 2 WLCVNCXA Central Telephone Co. - North Carolina Yanceyville YCVLNCXA Central Telephone Co. - North Carolina Yadkinville YDVLNCXA Randolph Telephone Membership Corp. Bennett BNNTNCXA Randolph Telephone Membership Corp. High Falls HGHFNCXA Skyline Telephone Membership Corporation West Jefferson BLDWNCXA Skyline Telephone Membership Corporation Creston CETNNCXA Skyline Telephone Membership Corporation Glade Creek GLCKNCXA Skyline Telephone Membership Corporation Lansing LNNGNCXA Skyline Telephone Membership Corporation Nathans Creek NTCKNCXA Skyline Telephone Membership Corporation Laurel Springs SCVLNCXA Skyline Telephone Membership Corporation Sparta SPRTNCXA Sprint Mid-Atlantic Ahoskie AHSKNCXA Sprint Mid-Atlantic Aulander ALNDNCXA Sprint Mid-Atlantic Angier ANGRNCXA Sprint Mid-Atlantic Atlantic ATLTNCXA Sprint Mid-Atlantic Aurora AURRNCXA Sprint Mid-Atlantic Ayden AYDNNCXA Sprint Mid-Atlantic Bailey BALYNCXA Federal Communications Commission FCC 08-122 99 LEC NAME WIRE CENTER CLLI Sprint Mid-Atlantic Bath BATHNCXA Sprint Mid-Atlantic Bethel BETHNCXA Sprint Mid-Atlantic Beulaville BEVLNCXA Sprint Mid-Atlantic Bladenboro BLBONCXA Sprint Mid-Atlantic Belhaven BLHNNCXA Sprint Mid-Atlantic Benson BNSNNCXA Sprint Mid-Atlantic Bonlee BONLNCXA Sprint Mid-Atlantic Beaufort BUFTNCXA Sprint Mid-Atlantic Buxton 1 BXTNNCXA Sprint Mid-Atlantic Buxton 2 BXTNNCXB Sprint Mid-Atlantic Bayboro BYBONCXA Sprint Mid-Atlantic Camden/Shiloh SHLHNCXA Sprint Mid-Atlantic Chadbourn CHDBNCXA Sprint Mid-Atlantic Clarkton CKTNNCXA Sprint Mid-Atlantic Coinjock CNJCNCXA Sprint Mid-Atlantic Columbia CLMANCXA Sprint Mid-Atlantic Colerain CLRNNCXA Sprint Mid-Atlantic Conway CNWYNCXA Sprint Mid-Atlantic Carthage CRTHNCXA Sprint Mid-Atlantic Creswell CRWLNCXA Sprint Mid-Atlantic Clayton CYTNNCXA Sprint Mid-Atlantic Dunn DUNNNCXA Sprint Mid-Atlantic Erwin/Dunn DUNNNCXB Sprint Mid-Atlantic Edenton EDTNNCXA Sprint Mid-Atlantic Elizabeth City ELCYNCXA Sprint Mid-Atlantic Enfield ENFDNCXA Sprint Mid-Atlantic Engelhard ENGLNCXA Sprint Mid-Atlantic Elizabethtown EZTWNCXA Sprint Mid-Atlantic Faison FASNNCXA Sprint Mid-Atlantic Fayetteville 1 FYVLNCXA Sprint Mid-Atlantic Fayetteville 2 FYVLNCXB Sprint Mid-Atlantic Fayetteville 3 FYCLNCXF Sprint Mid-Atlantic Fayetteville 4 FYVLNCXG Sprint Mid-Atlantic Franklinton FKTNNCXA Sprint Mid-Atlantic Fountain FONTNCXA Sprint Mid-Atlantic Fuquay Varina FQVRNCXA Sprint Mid-Atlantic Fremont FRMTNCXA Sprint Mid-Atlantic Four Oaks FROKNCXA Sprint Mid-Atlantic Farmville FRVLNCXA Sprint Mid-Atlantic Ft. Bragg FYVLNCXD Sprint Mid-Atlantic Grifton GFTNNCXA Sprint Mid-Atlantic Goldston GLDSNCXA Sprint Mid-Atlantic Greenville 1 GNVLNCXA Sprint Mid-Atlantic Greenville 2 GNVLNCXB Sprint Mid-Atlantic Eure/Gatesville GTVLNCXA Sprint Mid-Atlantic Halifax HLFXNCXA Sprint Mid-Atlantic Hamilton HMTNNCXA Sprint Mid-Atlantic Harbinger/Mamie MAMINCXA Federal Communications Commission FCC 08-122 100 LEC NAME WIRE CENTER CLLI Sprint Mid-Atlantic Henderson HNSNNCXA Sprint Mid-Atlantic Hertford HRFRNCXA Sprint Mid-Atlantic Havelock HVLCNCXA Sprint Mid-Atlantic Holly Ridge HLRGNCXA Sprint Mid-Atlantic Jackson JCSNNCXA Sprint Mid-Atlantic Jacksonville 1 JCVLNCXA Sprint Mid-Atlantic Kill Devil Hills KDHLNCXA Sprint Mid-Atlantic Kitty Hawk KDHLNCXB Sprint Mid-Atlantic Kenly KNLYNCXA Sprint Mid-Atlantic Kenansville KNVLNCXA Sprint Mid-Atlantic Kinston KSTNNCXA Sprint Mid-Atlantic La Grange LGRNNCXA Sprint Mid-Atlantic Lake Waccamaw LKWCNCXA Sprint Mid-Atlantic Lillington LLTNNCXA Sprint Mid-Atlantic Louisburg LSBGNCXA Sprint Mid-Atlantic Louisburg LSBGNCXB Sprint Mid-Atlantic Lewiston/Woodville LSTNNCXA Sprint Mid-Atlantic Littleton LTTNNCXA Sprint Mid-Atlantic Lucama LUCANCXA Sprint Mid-Atlantic Manteo MANTNCXA Sprint Mid-Atlantic Moyock MOYCNCXA Sprint Mid-Atlantic Moyock/Sligo MOYCNCXB Sprint Mid-Atlantic Stacy/Marshallbg MRBGNCXA Sprint Mid-Atlantic Murfreesboro MRBONCXA Sprint Mid-Atlantic Morehead City MRCYNCXA Sprint Mid-Atlantic Deep Run/Moss Hill MSHLNCXA Sprint Mid-Atlantic Maxton MSTNNCXA Sprint Mid-Atlantic Maysville MYVLNCXA Sprint Mid-Atlantic Norlina NRLNNCXA Sprint Mid-Atlantic Nashville NSVLNCXA Sprint Mid-Atlantic New Bern NWBRNCXA Sprint Mid-Atlantic Newton Grove NWGVNCXA Sprint Mid-Atlantic Newport NWPTNCXA Sprint Mid-Atlantic Orcracoke OCRCNCXA Sprint Mid-Atlantic Oriental ORNTNCXA Sprint Mid-Atlantic Oxford OXFRNCXA Sprint Mid-Atlantic Pollocksville PCVLNCXA Sprint Mid-Atlantic Pink Hill PKHLNCXA Sprint Mid-Atlantic Parkton PKTNNCXA Sprint Mid-Atlantic Plymouth PLMONCXA Sprint Mid-Atlantic PineHurst PNHRNCXA Sprint Mid-Atlantic Pinetops PNTNNCXA Sprint Mid-Atlantic Princeton PRTNNCXA Sprint Mid-Atlantic Pittsboro PTBONCXA Sprint Mid-Atlantic Belvidere/Piney Wds PYWDNCXA Sprint Mid-Atlantic Raeford RAFDNCXA Sprint Mid-Atlantic Robbins RBNXNCXA Sprint Mid-Atlantic Robersonville RBVLNCXA Federal Communications Commission FCC 08-122 101 LEC NAME WIRE CENTER CLLI Sprint Mid-Atlantic Richlands RCLDNCXA Sprint Mid-Atlantic Rocky Mt 1 RCMTNCXA Sprint Mid-Atlantic Rich Square RCSQNCXA Sprint Mid-Atlantic Red Springs RDSPNCXA Sprint Mid-Atlantic Roanoke Rapids RNRPNCXA Sprint Mid-Atlantic Roseboro RSBONCXA Sprint Mid-Atlantic Rose Hill RSHLNCXA Sprint Mid-Atlantic Roxobel RXBLNCXA Sprint Mid-Atlantic Seaboard SBRDNCXA Sprint Mid-Atlantic Scotland Neck SCNKNCXA Sprint Mid-Atlantic Siler City SLCYNCXA Sprint Mid-Atlantic Smithfield SMFDNCXA Sprint Mid-Atlantic Sunbury SNBYNCXA Sprint Mid-Atlantic Sneads Ferry SNFYNCXA Sprint Mid-Atlantic Snow Hill SNHLNCXA Sprint Mid-Atlantic Southern Pines SPNSNCXA Sprint Mid-Atlantic Spring Hope SPRHNCXA Sprint Mid-Atlantic Stantonsburg STBGNCXA Sprint Mid-Atlantic South Mills STMLNCXA Sprint Mid-Atlantic St. Pauls STPLNCXA Sprint Mid-Atlantic Swan Quarter SWNQNCXA Sprint Mid-Atlantic Emerald Isle SWNSNCXA Sprint Mid-Atlantic Swanboro SWNSNCXA Sprint Mid-Atlantic Tabor City TBCYNCXA Sprint Mid-Atlantic Sneads/Top Sail TPISNCXA Sprint Mid-Atlantic Tarboro TRBONCXA Sprint Mid-Atlantic Trenton TRENNCXA Sprint Mid-Atlantic Vass VASSNCXA Sprint Mid-Atlantic Vanceboro VNBONCXA Sprint Mid-Atlantic Washington WASHNCXA Sprint Mid-Atlantic Waves WAVENCXA Sprint Mid-Atlantic Woodland WDLDNCXA Sprint Mid-Atlantic Woodville WDVLNCXA Sprint Mid-Atlantic Carthage/Whispepins WHPNNCXA Sprint Mid-Atlantic Whitakers WHTKNCXA Sprint Mid-Atlantic Whiteville WHVLNCXA Sprint Mid-Atlantic Winton WITNNCXA Sprint Mid-Atlantic Wake Forest WKFSNCXA Sprint Mid-Atlantic Weeksville WKVLNCXA Sprint Mid-Atlantic Tyner/Welch WLCHNCXA Sprint Mid-Atlantic Weldon WLDNNCXA Sprint Mid-Atlantic Wallace WLLCNCXA Sprint Mid-Atlantic Wilson WLSNNCXA Sprint Mid-Atlantic Williamston WMTNNCXA Sprint Mid-Atlantic Warsaw WRSWNCXA Sprint Mid-Atlantic Warrenton WRTNNCXA Yadkin Valley Telephone Membership Corp. Hamptonville BRKSNCXA Yadkin Valley Telephone Membership Corp. East Bend EBNDNCXA Federal Communications Commission FCC 08-122 102 LEC NAME WIRE CENTER CLLI Yadkin Valley Telephone Membership Corp. Forbush FRBSNCXA Tennessee: LEC NAME WIRE CENTER CLLI North Central Telephone Coop., Inc. – TN BETHPAGE BTHPTNXA North Central Telephone Coop., Inc. – TN DEFEATED DFTDTNXA North Central Telephone Coop., Inc. – TN GREENGROVE GNGVTNXA North Central Telephone Coop., Inc. – TN HILLSDALE HLDLTNXA North Central Telephone Coop., Inc. – TN LAFAYETTE LFYTTNXA North Central Telephone Coop., Inc. – TN OAK GROVE OKGVTNXA North Central Telephone Coop., Inc. – TN PLEASASHAD PLSHTNXA North Central Telephone Coop., Inc. – TN RDBOLNGSPG RBSPTNXA North Central Telephone Coop., Inc. – TN WESTMORELD WMLDTNXA Virginia:3 LEC NAME WIRE CENTER CLLI NTELOS Telephone Inc. CLIFTNFORG CFFRVAXA NTELOS Telephone Inc. POTTSCREEK PTCKVAXA Peoples Mutual Telephone Co. SANDYLEVEL SNLVVAXA Central Telephone Co. - Virginia ARARAT ARRTVAXA Central Telephone Co. ARVONIA ARVNVAXA Central Telephone Co. AXTON AXTNVAXA Central Telephone Co. BUCKINGHAM BCHMVAXA Central Telephone Co. BOONESMILL BNMLVAXA Central Telephone Co. BROWNSBURG BRBGVAXA Central Telephone Co. BROOKNEAL BRKNVAXA Central Telephone Co. BASSETT BSSTVAXA Central Telephone Co. BURNTCHMNY BTCHVAXA Central Telephone Co. CHARLOTSVL CHVLVAXA Central Telephone Co. CROZET CRZTVAXA Central Telephone Co. DILLWYN DLWYVAXA Central Telephone Co. FORK UNION FKUNVAXA Central Telephone Co. FIELDALE FLDLVAXA Central Telephone Co. FERRUM FRRMVAXA Central Telephone Co. FARMVILLE FRVLVAXA Central Telephone Co. GLADYS GLDYVAXA Central Telephone Co. GLASGOW GLSGVAXA Central Telephone Co. HALIFAX HLFXVAXA Central Telephone Co. HAMPDESDNY HMSYVAXA Central Telephone Co. LEXINGTON LXTNVAXA Central Telephone Co. MEADOWSDAN MDDNVAXA Central Telephone Co. MARTINSVL MTVIVAXA Central Telephone Co. NATURALBDG NTBRVAXA Central Telephone Co. PALMYRA PLMYVAXA 3 United Inter-Mountain Telephone’s study area has been previously redefined, as discussed above. Federal Communications Commission FCC 08-122 103 Central Telephone Co. PROSPECT PRSPVAXA Central Telephone Co. ROCKYMOUNT RCMTVAXA Central Telephone Co. RIDGEWAY RDWYVAXA Central Telephone Co. RUSTBURG RSBGVAXA Central Telephone Co. SO BOSTON SBTNVAXA Central Telephone Co. SCHUYLER SCHLVAXA Central Telephone Co. SCOTTSVL SCVLVAXA Central Telephone Co. STANARDSVL SDVLVAXA Central Telephone Co. SPENCER SPNCVAXA Central Telephone Co. TURBEVILLE TBVLVAXA Central Telephone Co. UNION HALL UNHLVAXA Central Telephone Co. VOLENS VLNSVAXA Central Telephone Co. VIRGILINA VRGLVAXA Central Telephone Co. WOOLWINE WLWNVAXA Verizon South Inc. – VA BLUEFIELD BLFDVAXA Verizon South Inc. – VA ROCKY GAP RCGPVAXA United Inter-Mountain Telephone AUSTINVL ATVLVAXA United Inter-Mountain Telephone BLAND BLNDVAXA United Inter-Mountain Telephone CANA CANAVAXA United Inter-Mountain Telephone CERES CERSVAXA United Inter-Mountain Telephone CHILHOWIE CHLHVAXA United Inter-Mountain Telephone CMSRKELCRK CMRKVAXA United Inter-Mountain Telephone CRIPPLECRK CRCKVAXA United Inter-Mountain Telephone FRIES FRISVAXA United Inter-Mountain Telephone GALAX GALXVAXA United Inter-Mountain Telephone GLADE SPG GDSPVAXA United Inter-Mountain Telephone HILLSVILLE HLVLVAXA United Inter-Mountain Telephone INDEPNDNCE INDPVAXA United Inter-Mountain Telephone KONNAROCK KNRKVAXA United Inter-Mountain Telephone LAURELFORK LRFKVAXA United Inter-Mountain Telephone MARION MARNVAXA United Inter-Mountain Telephone MOUTHWILSN MTWLVAXA United Inter-Mountain Telephone MAXMEADOWS MXMDVAXA United Inter-Mountain Telephone RICHVALLEY RCVYVAXA United Inter-Mountain Telephone RURALRTRET RRRTVAXA United Inter-Mountain Telephone SUGARGROVE SGGVVAXA United Inter-Mountain Telephone SALTVILLE SLVLVAXA United Inter-Mountain Telephone SYLVATUS SYLVVAXA United Inter-Mountain Telephone WYTHEVILLE WYVLVAXA Federal Communications Commission FCC 08-122 103 APPENDIX C RCC Minnesota, Inc. and RCC Atlantic, Inc. New Hampshire ETC Designation Amendment 1. On October 7, 2005, the Wireline Competition Bureau (Bureau) released an order granting a petition of RCC Minnesota, Inc. and RCC Atlantic, Inc. (RCC) to be designated as an ETC in portions of its licensed service areas in the state of New Hampshire.1 In its petition, RCC requested ETC designation in the entirety of the Kearsarge Telephone Company study area. However, RCC failed to include one wire center in the Kearsarge Telephone Company study area, the Meridian wire center, in the list of wire centers attached to its petition. Because RCC did not identify the Meridian wire center in the list of Kearsarge Telephone Company wire centers in its Petition, Appendix B of the RCC Order similarly did not include this wire center.2 RCC has notified the Commission of this omission.3 Inclusion of this wire center would not have changed the Bureau’s analysis because RCC requested, and the Bureau granted, designation in the entire Kearsarge Telephone Company study area. Therefore, we amend Appendix B of the RCC Order by inserting “Meridian MRDNNHXA” in the list of Kearsarge Telephone Company service areas, following “Chichester CHCHNHXA.” 1 Federal-State Joint Board on Universal Service, RCC Minnesota, Inc. and RCC Atlantic, Inc. Petition for Designation as an Eligible Telecommunications Carrier in the State of New Hampshire, CC Docket No. 96-45, Order, 20 FCC Rcd 15833 (Wireline Comp. Bur. 2005) (RCC Order). 2 See RCC Minnesota, Inc. and RCC Atlantic, Inc., Petition for Designation as an Eligible Telecommunications Carrier in the State of New Hampshire, CC Docket No. 96-45, Supplemental Filing, at Exhibit C (filed Aug. 26, 2005). 3 See Letter from David A. LaFuria and B. Lynn F. Ratnavale, Lukas, Nace, Gutierrez, and Sachs, to Marlene H. Dortch, Secretary, FCC, CC Docket No. 96-45 (filed Dec. 13, 2005). Federal Communications Commission FCC 08-122 104 APPENDIX D Final Regulatory Flexibility Analysis 1. As required by the Regulatory Flexibility Act of 1980, as amended (RFA),1 an Initial Regulatory Flexibility Analysis (IRFA) was incorporated in the Notice.2 The Commission sought written public comment on the proposals in the Notice, including comment on the IRFA.3 This Final Regulatory Flexibility Analysis (FRFA) conforms to the RFA.4 A. Need for, and Objectives of, the Proposed Rules 2. On May 1, 2007, the Joint Board recommended that the Commission adopt an interim cap on high-cost universal service support for competitive ETCs to rein in the explosive growth in universal service.5 We agree with the Joint Board’s assessment that the rapid growth in high-cost support places the federal universal service fund in dire jeopardy. In 2006, the universal service fund provided approximately $4.1 billion per year in high-cost support.6 In contrast, in 2001, high-cost universal service support totaled approximately $2.6 billion.7 In recent years, this growth has been due to increased support provided to competitive ETCs, which receive high-cost support based on the per-line support that the incumbent LECs receive, rather than on the competitive ETCs’ own costs. While support to incumbent LECs has been flat, or has even declined since 2003,8 competitive ETC support, in the six years from 2001 through 2006, has grown from under $17 million to $980 million – an average annual 1 See 5 U.S.C. § 603. The RFA, see 5 U.S.C. § 601-12., has been amended by the Small Business Regulatory Enforcement Fairness Act of 1996, Pub. L. No. 104-121, Title II, 110 Stat. 847 (1996). 2 Federal-State Joint Board on Universal Service, WC Docket No. 05-337, CC Docket No. 96-45, Notice of Proposed Rulemaking, 22 FCC Rcd 9705, 9737-42 (2007) (Notice). 3 Id. at 9737. 4 See 5 U.S.C. § 604. 5 Federal-State Joint Board on Universal Service, WC Docket No. 05-337, CC Docket No. 96-45, Recommended Decision, FCC 07J-1 (Fed.-State Jt. Bd., rel. May 1, 2007) (Recommended Decision) (Appendix A). 6 Universal Service Administrative Company 2006 Annual Report, 39 (2006), available at http://www.usac.org/_res/documents/about/pdf/usac-annual-report-2006.pdf (USAC 2006 Annual Report). 7 See Universal Service Monitoring Report, CC Docket No. 98-202, Prepared by the Federal and State Staff for the Federal-State Joint Board on Universal Service in CC Docket No. 96-45, Table 3.2 (2006) (Universal Service Monitoring Report). 8 Incumbent LECs received $3.129 billion in high-cost support in 2003; $3.153 billion in 2004; $3.186 billion in 2005; and $3.116 billion in 2006. Universal Service Monitoring Report, at Table 3.2 (for 2003, 2004, and 2005 data); USAC 2006 Annual Report at 41 (for 2006 data). In 2001, much of the growth in high-cost support was attributable to removing implicit subsidies from access charges and the inclusion of these amounts in explicit universal service mechanisms adopted in the CALLS Order and the MAG Plan Order. See Access Charge Reform, Price Cap Performance Review for Local Exchange Carriers; Low-Volume Long-Distance Users; Federal-State Joint Board on Universal Service, Sixth Report and Order in CC Docket Nos. 96-262 and 94-1, Report and Order in CC Docket No. 99-249, Eleventh Report and Order in CC Docket No. 96-45, 15 FCC Rcd 12962 (2000) (CALLS Order); Multi-Association Group (MAG) Plan for Regulation of Interstate Services of Non-Price Cap Incumbent Local Exchange Carriers and Interexchange Carriers; Federal-State Joint Board on Universal Service; Access Charge Reform for Incumbent Local Exchange Carriers Subject to Rate-of-Return Regulation; Prescribing the Authorized Rate of Return From Interstate Services of Local Exchange Carriers, Second Report and Order and Further Notice of Proposed Rulemaking in CC Docket No. 00-256, Fifteenth Report and Order in CC Docket No. 96-45, and Report and Order in CC Docket Nos. 98-77 and 98-166, 16 FCC Rcd 19613 (2001) (MAG Plan Order), recon. pending. Federal Communications Commission FCC 08-122 105 growth rate of over 100 percent.9 Competitive ETCs received $557 million in high-cost support in the first six months of 2007.10 Annualizing this amount projects that they will receive approximately $1.11 billion in 2007. We find that the continued growth of the fund at this rate is not sustainable and would require excessive (and ever growing) contributions from consumers to pay for this fund growth. 11 3. We conclude that immediate action must be taken to stem the dramatic growth in high- cost support. Therefore, we immediately impose an interim cap on high-cost support provided to competitive ETCs until fundamental comprehensive reforms are adopted to address issues related to the distribution of support and to ensure that the universal service fund will be sustainable for future years. The interim cap that we adopt herein limits the amount of high-cost support that competitive ETCs can receive in the interim period to the amount they were eligible to receive in March 2008 on an annualized basis. B. Summary of Significant Issues Raised by Public Comments in Response to the IRFA 4. None C. Description and Estimate of the Number of Small Entities to Which Rules Will Apply 5. The RFA directs agencies to provide a description of, and, where feasible, an estimate of the number of small entities that may be affected by the rules, if adopted.12 The RFA generally defines the term “small entity”13 as having the same meaning as the terms “small business,”14 “small organization,” 15 and “small governmental jurisdiction.”16 In addition, the term “small business” has the same meaning as the term “small business concern” under the Small Business Act, unless the Commission has developed one or more definitions that are appropriate to its activities.17 Under the 9 Universal Service Monitoring Report, at Table 3.2; USAC 2006 Annual Report at 41. 10 See Universal Service Administrative Company, Universal Service Fund Facts – High Cost Quarterly Program Statistics; High Cost Program Support Distribution By CETCs & ILECs 1998 Through 2Q2007, http://www.universalservice.org/_res/documents/about/pdf/fund-facts/HC%20CETC-ILEC%20Distribution.pdf (July 23, 2007). 11 Support for the fund derives from assessments paid by providers of interstate telecommunications services and certain other providers of interstate telecommunications. See 47 C.F.R. § 54.706. Fund contributors are permitted to, and almost always do, pass those contribution assessments though to their end-user customers. See 47 C.F.R. § 54.712. Fund assessments paid by contributors are determined by applying the quarterly contribution factor to the contributors’ contribution base revenues. In the second quarter of 2007, the contribution factor reached 11.7 percent, which is the highest level since its inception. See Proposed Second Quarter 2007 Universal Service Contribution Factor, CC Docket No. 96-45, Public Notice, 22 FCC Rcd 5074 (Off. of Man. Dir. 2007). The contribution factor has since declined slightly to 11.0 percent in the fourth quarter of 2007. Proposed Fourth Quarter 2007 Universal Service Contribution Factor, CC Docket No. 96-45, Public Notice, DA 07-3928 (Off. of Man. Dir. 2007). 12 5 U.S.C. § 604(a)(3). 13 5 U.S.C. § 601(6). 14 5 U.S.C. § 601(3). 15 5 U.S.C. § 601(4). 16 5 U.S.C. § 601(5). 17 5 U.S.C. § 601(3) (incorporating by reference the definition of “small business concern” in 5 U.S.C. § 632). Pursuant to 5 U.S.C. § 601(3), the statutory definition of a small business applies “unless an agency after consultation with the Office of Advocacy of the Small Business Administration and after opportunity for public (continued....) Federal Communications Commission FCC 08-122 106 Small Business Act, a “small business concern” is one that: (1) is independently owned and operated; (2) is not dominant in its field of operation; and (3) meets any additional criteria established by the Small Business Administration (SBA).18 Nationwide, there are a total of approximately 22.4 million small businesses, according to SBA data.19 A small organization is generally “any not-for-profit enterprise which is independently owned and operated and is not dominant in its field.”20 Nationwide, as of 2002, there were approximately 1.6 million small organizations.21 6. The most reliable source of information regarding the total numbers of certain common carrier and related providers nationwide, as well as the number of commercial wireless entities, is the data that the Commission publishes in its Trends in Telephone Service report.22 The SBA has developed small business size standards for wireline and wireless small businesses within the three commercial census categories of Wired Telecommunications Carriers,23 Paging,24 and Cellular and Other Wireless Telecommunications.25 Under these categories, a business is small if it has 1,500 or fewer employees. Below, using the above size standards and others, we discuss the total estimated numbers of small businesses that might be affected by our actions. 1. Wireline Carriers and Service Providers 7. We have included small incumbent local exchange carriers (LECs) in this present RFA analysis. As noted above, a “small business” under the RFA is one that, inter alia, meets the pertinent small business size standard (e.g., a telephone communications business having 1,500 or fewer employees), and “is not dominant in its field of operation.”26 The SBA’s Office of Advocacy contends that, for RFA purposes, small incumbent LECs are not dominant in their field of operation because any such dominance is not “national” in scope.27 We have therefore included small incumbent LECs in this RFA analysis, although we emphasize that this RFA action has no effect on Commission analyses and determinations in other, non-RFA contexts. (...continued from previous page) comment, establishes one or more definitions of such term which are appropriate to the activities of the agency and publishes such definition in the Federal Register.” 5 U.S.C. § 601(3). 18 15 U.S.C. § 632. 19 See SBA, Programs and Services, SBA Pamphlet No. CO-0028, at 40 (July 2002). 20 5 U.S.C. § 601(4). 21 Independent Sector, The New Nonprofit Almanac & Desk Reference (2002). 22 FCC, Wireline Competition Bureau, Industry Analysis and Technology Division, Trends in Telephone Service, Table 5.3, page 5-5 (February 2007) (Trends in Telephone Service). This source uses data collected as of October 20, 2005. 23 13 C.F.R. § 121.201, North American Industry Classification System (NAICS) code 517110. 24 Id. § 121.201, NAICS code 517211 (This category will be changed for purposes of the 2007 Census to “Wireless Telecommunications Carriers (except Satellite),” NAICS code 517210.). 25 Id. § 121.201, NAICS code 517212 (This category will be changed for purposes of the 2007 Census to “Wireless Telecommunications Carriers (except Satellite),” NAICS code 517210.). 26 15 U.S.C. § 632. 27 See Letter from Jere W. Glover, Chief Counsel for Advocacy, SBA, to Chairman William E. Kennard, Federal Communications Commission (May 27, 1999). The Small Business Act contains a definition of “small business concern,” which the RFA incorporates into its own definition of “small business.” See 15 U.S.C. § 632(a) (Small Business Act); 5 U.S.C. § 601(3) (RFA). SBA regulations interpret “small business concern” to include the concept of dominance on a national basis. 13 C.F.R. § 121.102(b). Federal Communications Commission FCC 08-122 107 8. Incumbent LECs. Neither the Commission nor the SBA has developed a size standard for small businesses specifically applicable to incumbent LECs. The closest applicable size standard under SBA rules is for “Wired Telecommunications Carriers.” Under that size standard, such a business is small if it has 1,500 or fewer employees.28 According to Commission data,29 1,307 carriers reported that they were engaged in the provision of local exchange services. Of these 1,307 carriers, an estimated 1,019 have 1,500 or fewer employees, and 288 have more than 1,500 employees. Consequently, the Commission estimates that most providers of incumbent local exchange service are small businesses that may be affected by our action. 9. Competitive LECs, Competitive Access Providers (CAPs), “Shared-Tenant Service Providers,” and “Other Local Service Providers.” Neither the Commission nor the SBA has developed a small business size standard specifically for these service providers. The appropriate size standard under SBA rules is for the category “Wired Telecommunications Carriers.” Under that size standard, such a business is small if it has 1,500 or fewer employees.30 According to Commission data,31 859 carriers reported that they were engaged in the provision of either competitive LEC or CAP services. Of these 859 carriers, an estimated 741 have 1,500 or fewer employees, and 118 have more than 1,500 employees.32 In addition, 16 carriers have reported that they are “Shared-Tenant Service Providers,” and all 16 are estimated to have 1,500 or fewer employees. In addition, 44 carriers have reported that they are “Other Local Service Providers.” Of the 44, an estimated 43 have 1,500 or fewer employees, and one has more than 1,500 employees. Consequently, the Commission estimates that most competitive LECs, CAPs, “Shared-Tenant Service Providers,” and “Other Local Service Providers” are small entities that may be affected by our action. 2. Wireless Carriers and Service Providers 10. Wireless Service Providers. The appropriate size standard for wireless service providers is the category of “Wireless Telecommunications Carriers (except Satellite).” Under that standard, the SBA deems a wireless business to be small if it has 1,500 or fewer employees.33 The data necessary to estimate the number of entities in this category has not been gathered since it was adopted in November 2007. Therefore, we will use the earlier, now-superceded categories – “Paging” and “Cellular and Other Wireless Telecommunications” – to estimate the number of entities. For the census category of “Paging,” Census Bureau data for 2002 show that there were 807 firms in this category that operated for the entire year.34 Of this total, 804 firms had employment of 999 or fewer employees, and three firms had employment of 1,000 employees or more.35 Thus, under this category and associated small business size standard, the majority of firms can be considered small. For the census category of “Cellular and Other Wireless Telecommunications,” Census Bureau data for 2002 show that there were 1,397 firms in this 28 13 C.F.R. § 121.201, NAICS code 517110. 29 Trends in Telephone Service at Table 5.3. 30 13 C.F.R. § 121.201, NAICS code 517210. 31 Trends in Telephone Service at Table 5.3. 32 Id. 33 13 C.F.R. § 121.201, NAICS Code 517210. 34 U.S. Census Bureau, 2002 Economic Census, Subject Series: “Information,” Table 5, Employment Size of Firms for the United States: 2002, NAICS code 517211 (issued Nov. 2005). 35 Id. The census data do not provide a more precise estimate of the number of firms that have employment of 1,500 or fewer employees; the largest category provided is for firms with “1000 employees or more.” Federal Communications Commission FCC 08-122 108 category that operated for the entire year.36 Of this total, 1,378 firms had employment of 999 or fewer employees, and 19 firms had employment of 1,000 employees or more.37 Thus, under this second category and size standard, the majority of firms can, again, be considered small. 11. Wireless Telephony. Wireless telephony includes cellular, personal communications services (PCS), and specialized mobile radio (SMR) telephony carriers. As noted earlier, the SBA has developed a small business size standard for “Wireless Telecommunications Carriers (except Satellite).” Under that SBA small business size standard, a business is small if it has 1,500 or fewer employees.38 The data necessary to estimate the number of entities in this category has not been gathered since it was adopted in November 2007. Therefore, we will use the earlier, now-superceded categories of “Cellular and Other Wireless Telecommunications” to estimate the number of entities. According to Commission data, 432 carriers reported that they were engaged in the provision of wireless telephony.39 We have estimated that 221 of these are small under the SBA small business size standard. 3. Satellite Service Providers 12. Satellite Telecommunications and Other Telecommunications. There is no small business size standard developed specifically for providers of international service. The appropriate size standards under SBA rules are for the two broad census categories of “Satellite Telecommunications” and “All Other Telecommunications.” 13. The first category of “Satellite Telecommunications” “comprises establishments primarily engaged in providing point-to-point telecommunications services to other establishments in the telecommunications and broadcasting industries by forwarding and receiving communications signals via a system of satellites or reselling satellite telecommunications.”40 Under this category, the SBA size standard is $13.5 million or less in aveage annual receipts.41For this category, Census Bureau data for 2002 show that there were a total of 371 firms that operated for the entire year.42 Of this total, 307 firms had annual receipts of under $10 million, and 26 firms had receipts of $10 million to $24,999,999.43 Consequently, we estimate that the majority of Satellite Telecommunications firms are small entities that might be affected by our action. 14. The second category of “All Other Telecommunications” “comprises establishments primarily engaged in (1) providing specialized telecommunications applications, such as satellite tracking, communications telemetry, and radar station operations; or (2) providing satellite terminal stations and associated facilities operationally connected with one or more terrestrial communications systems and 36 U.S. Census Bureau, 2002 Economic Census, Subject Series: “Information,” Table 5, Employment Size of Firms for the United States: 2002, NAICS code 517212 (issued Nov. 2005). 37 Id. The census data do not provide a more precise estimate of the number of firms that have employment of 1,500 or fewer employees; the largest category provided is for firms with “1000 employees or more.” 38 13 C.F.R. § 121.201, NAICS Code 517110. 39 Trends in Telephone Service at Table 5.3. 40 U.S. Census Bureau, 2002 NAICS Definitions, “517410 Satellite Telecommunications”; http://www.census.gov/epcd/naics02/def/NDEF517.HTM. 41 13 C.F.R. § 121.201, NAICS codes 517410. 42 U.S. Census Bureau, 2002 Economic Census, Subject Series: Information, “Establishment and Firm Size (Including Legal Form of Organization),” Table 4, NAICS code 517410 (issued Nov. 2005). 43 Id. An additional 38 firms had annual receipts of $25 million or more. Federal Communications Commission FCC 08-122 109 capable of transmitting telecommunications to or receiving telecommunications from satellite systems.”44 The SBA size standard for “All Other Telecommunications” is $23.0 million or less in average annual revenues. 45 For this category, Census Bureau data for 2002 show that there were a total of 332 firms that operated for the entire year.46 Of this total, 259 firms had annual receipts of under $10 million and 15 firms had annual receipts of $10 million to $24,999,999.47 Consequently, we estimate that the majority of Other Telecommunications firms are small entities that might be affected by our action. D. Description of Projected Reporting, Recordkeeping, and Other Compliance Requirements 15. In order to qualify for the exception to the interim cap, some small carriers serving tribal lands or Native Alaskan regions will be required to file certifications that they qualify for the exception. Other small carriers may qualify for an exception if they file data reporting their costs of serving high- cost areas for which they seek the exception to be applied. E. Steps Taken to Minimize Significant Economic Impact on Small Entities, and Significant Alternatives Considered 16. The RFA requires an agency to describe any significant alternatives that it has considered in reaching its proposed approach, which may include the following four alternatives (among others): (1) the establishment of differing compliance and reporting requirements or timetables that take into account the resources available to small entities; (2) the clarification, consolidation, or simplification of compliance or reporting requirements under the rule for small entities; (3) the use of performance, rather than design, standards; and (4) an exemption from coverage of the rule, or part thereof, for small entities.48 17. In adopting the interim cap, the Commission considered several alternatives to minimize the cap’s effect on small entites. We adopt an exception to the rule for carriers providing services to tribal lands. We also note that the Commission is examining ways to comprehensively reform federal high-cost universal service. The interim cap that the Commission adopts today is an interim measure that will be replaced by comprehensive reforms which will be developed in the future and which will minimize any economically adverse effect of the cap on small businesses. F. Report to Congress 18. The Commission will send a copy of the Order, including this FRFA, in a report to be sent to Congress pursuant to the SBREFA.49 In addition, the Commission will send a copy of the Order, 44 U.S. Census Bureau, 2002 NAICS Definitions, “517910 Other Telecommunications”; http://www.census.gov/epcd/naics02/def/NDEF517.HTM. 45 The SBA size standard for “All Other Telecommunications is $23.0 million or less in average annual revenues. See 13 C.F.R. § 121.201, NAICS Code 517919. 46 U.S. Census Bureau, 2002 Economic Census, Subject Series: Information, “Establishment and Firm Size (Including Legal Form of Organization),” Table 4, NAICS code 517910 (issued Nov. 2005). 47 Id. An additional 14 firms had annual receipts of $25 million or more. 48 See 5 U.S.C. § 603(c). 49 See 5 U.S.C. § 801(a)(1)(A). Federal Communications Commission FCC 08-122 110 including the FRFA, to the Chief Counsel for Advocacy of the SBA. A copy of the Order and the FRFA (or summaries thereof) will also be published in the Federal Register.50 50 See 5 U.S.C. § 604(b). Federal Communications Commission FCC 08-122 111 STATEMENT OF CHAIRMAN KEVIN J. MARTIN Re: High-Cost Universal Service Support, Federal-State Joint Board on Universal Service, Alltel Communications, Inc., et al. Petitions for Designation as Eligible Telecommunications Carriers, RCC Minnesota, Inc. and RCC Atlantic, Inc. New Hampshire ETC Designation Amendment, WC Docket No. 05-337, CC Docket No. 96-45. Today, we act to stem the explosive growth of the Universal Service Fund (Fund) by capping total annual high-cost universal service support for competitive eligible telecommunications carriers (ETCs) at the level of support that they were eligible to receive in each state during March 2008. This action is essential to preserve and advance the benefits of the universal service program while we consider comprehensive reform. The United States and the Commission have a long history and tradition of ensuring that rural areas of the country are connected and have similar opportunities for communications as other areas. Our universal service program must continue to promote investment in rural America’s infrastructure and ensure access to telecommunications services that are comparable to those available in urban areas today, as well as provide a platform for delivery of advanced services. Changes in technology and increases in the number of carriers that receive universal service support, however, have placed significant pressure on the stability of the Fund. A large and rapidly growing portion of the high-cost support program is now devoted to supporting multiple competitors to serve areas in which costs are prohibitively expensive for even one carrier. These competitive ETCs don’t receive support based on their own costs, but rather on the costs of the incumbent provider, even if their costs of providing service are lower. Indeed, growth in required contributions to the Fund is largely attributable to these competitive ETCs. High-cost support to competitive ETCs has grown from approximately $1.5 million in 2000 to well over $1 billion in 2007. Left unchecked, this staggering growth threatens the sustainability of the Fund. A year ago, the Federal-State Joint Board on Universal Service recommended capping competitive ETC funding to address the escalating impact of this problem. I supported that recommendation, and six months ago, I proposed the cap we adopt today. Today’s decision is not an end in itself, but a step on the path towards comprehensive reform. I continue to believe the long-term answer for comprehensive reform of high-cost universal service support is to move to a reverse auction methodology and to require that high-cost support be based on a carrier’s own costs. I’m supportive of these measures to contain the growth of universal service in order to preserve and advance the benefits of the Fund and protect the ability of people in rural areas to continue to be connected. I look forward to working with my colleagues as we consider comprehensive reform. Federal Communications Commission FCC 08-122 112 DISSENTING STATEMENT OF COMMISSIONER MICHAEL J. COPPS Re: High-Cost Universal Service Support, Federal-State Joint Board on Universal Service, Alltel Communications, Inc., et al. Petitions for Designation as Eligible Telecommunications Carriers, RCC Minnesota, Inc. and RCC Atlantic, Inc. New Hampshire ETC Designation Amendment, WC Docket No. 05-337, CC Docket No. 96-45. I dissent from today’s decision to cap high-cost support for competitive eligible telecommunications carriers (CETC) because it falls woefully short of the fundamental, comprehensive reforms needed to meet the overarching telecommunications challenge of the Twenty-first century. That challenge, both by statute and by necessity, is to encourage the deployment of basic and advanced telecommunications to all of our citizens and to ensure that the Universal Service system, which accomplished so much in the 20th Century, can do so again now. Today’s decision does nothing meaningful to meet that challenge; indeed, it only deflects us from the goal. The outcome is an illusory band-aid that is supposed to contain costs but, in reality, imposes the much heavier cost of lost opportunity to reform Universal Service and put America back in the vanguard of advanced telecommunications. As a result of today’s vote, real reform is on the back-burner. What a pity! The need for reform is patently obvious. As this country continues to lag in so many international broadband rankings and as consumers and competitors around the world are receiving high-speed and high-value services, Americans in urban and rural areas and on tribal lands are falling further behind. One critical element of turning this ship around is re-tooling the Universal Service system with broadband deployment as its mission. And while my colleagues on the Federal-State Universal Service Joint Board unanimously agreed to make broadband part of the system, today’s Order has the effect of putting this off to another day. So too does it put off the many other difficult questions regarding sustainability of the Fund that the Joint Board wrestled with and put in its recommendations six months ago. Comprehensive reform is not painless and may require shared sacrifice from all stakeholders. Yet, today’s piecemeal approach has the unfortunate consequence of pushing interested parties apart rather than bringing them all to the table to develop workable solutions. Just consider that 365 days ago the Joint Board recommended an interim, emergency high-cost cap. Since then Commission and stakeholder attention has been largely focused on the merits and demerits of such a cap. Today’s Order ends up picking winners and losers when it comes to future Universal Service support and increases the risk that no one will return to the table to discuss real reform any time soon. Had all interested parties spent the same time and energy over the last year focused on comprehensive reform, we might “be there” already. The Commission seems to forget that we do not have the luxury of time here. Why is it slamming on the brakes when it comes to reform? The Joint Board gave us more, and it is those proposals we should be considering in a more comprehensive fashion. While I disagreed with some of the Joint Board’s recommendations, at a minimum they put us on the road to real reform. The majority’s response today, while they will attempt to bill it as an “interim, emergency cap”, has no sunset period and commits only to completing comprehensive reform “as soon as feasible.” Remember that old song “The Twelfth of Never”? While I strongly disagree with the overall decision taken today, I am encouraged the majority added to their CETC cap two caveats that I have long deemed important. The Order excludes from the cap high cost support for CETCs serving tribal lands or Native Alaskan Regions. These areas are among the most underserved when it comes to telecommunications—both basic phone service and broadband. The Commission must continue to focus on ways to bring affordable services to these areas as their residents are equally deserving of the benefits that technology affords. Second, a CETC will not be Federal Communications Commission FCC 08-122 113 subject to the cap to the extent it provides cost data documenting its actual costs for providing competitive service. I continue to believe that the elimination of the Identical Support rule should be part of any comprehensive solution and this step is consistent with that approach. I, for one, will continue to beat the drums for comprehensive Universal Service reform. It’s what Congress wants, what the statute commands, and what consumers deserve. So I pledge today to do everything I can to encourage all stakeholders to come to the table and take on the unfinished business of empowering all our citizens through the awesome new tools of communications technology. Federal Communications Commission FCC 08-122 114 DISSENTING STATEMENT OF COMMISSIONER JONATHAN S. ADELSTEIN Re: High-Cost Universal Service Support, Federal-State Joint Board on Universal Service, Alltel Communications, Inc., et al. Petitions for Designation as Eligible Telecommunications Carriers, RCC Minnesota, Inc. and RCC Atlantic, Inc. New Hampshire ETC Designation Amendment, WC Docket No. 05-337, CC Docket No. 96-45. Universal service has long been at the heart of telecommunications policy. The resulting benefits – economic and social, in health care and education – accrue to us all, no matter where we live. So I take seriously our directive under the Act to ensure the continued vitality of universal service and am extremely grateful to the members of the Federal-State Joint Board on Universal Service for their multiple recommendations. Despite the importance and magnitude of the challenge of developing meaningful long-term improvements to our universal service policies, the Commission focuses today solely on the narrow question of whether to cap support for competitive eligible telecommunications carriers (CETCs). After careful deliberation, I dissent from this Order, which, I conclude, amounts to a step backwards in universal service policy rather than a step toward the future. While I am deeply skeptical about the imposition of artificial caps on universal service, I have long been concerned about fund growth and the need to manage scarce resources responsibly. One apparent obstacle to that goal is the current designation process, which gives State commissions strong incentives to designate additional universal service recipients but places no corresponding financial responsibility for those designations. Going back to my days on the Joint Board, I have urged both our Commission and our State commission colleagues to exercise caution in granting CETC designations. Yet, the cap mechanism adopted by the Commission today suffers from a major flaw because it penalizes most harshly the very States that heeded calls for discretion in the designation process. I would have preferred that the Commission take more meaningful measures to address growth of the fund, such as eliminating the Commission’s so-called identical support rule, tightening the designation process and improving the Commission’s audit processes. In this respect, I appreciate the majority’s efforts to address a number of my concerns with this revised cap mechanism, such as creating an exception for CETCs that document their own costs. I am also pleased that the Commission recognizes the unique nature of Tribal lands and Alaskan Native Regions, many of which face devastatingly low telephone penetration rates and high barriers to deploying advanced communications. A limited exemption should help maintain incentives for carriers to bring services to these hard-to-serve areas. As technology and the marketplace rapidly reshape the communications landscape, we face difficult questions about how our universal service policies should keep pace. Our larger challenge is preserving and advancing universal service amidst these changes. At the same time, we remain ever mindful that it is consumers who ultimately fund universal service contributions. This means that universal service must evolve, as Congress intended. In particular, universal service can and must be an integral part of meeting our nation’s broadband challenge. We also must craft our universal service policies with an eye towards their impact on providers of last resort, the deployment of spectrum-based services, the competitive marketplace, and the role of the states. The time is now to tackle these issues in earnest, lest time and technology render our policies obsolete. I share the concern expressed by so many commenters and Members of Congress that this decision to impose a cap, while labeled “interim,” may be used as an excuse for foot dragging. Our choices regarding long-term universal service reform will require hard work and the input of a wide range of providers, state commissions, and consumer interests. Rightly so, for our decisions will have a dramatic effect on the ability of communities and consumers in Rural America to thrive and grow with Federal Communications Commission FCC 08-122 115 the rest of the country. Yet, today, we do not meaningfully advance those discussions. Rather, the entire debate over the cap has, in fact, been a distraction from tackling the underlying issues. With the question of a cap now decided, the Commission must now turn its attention back to developing long-term solutions for universal service. I would like to again thank the Members of the Joint Board for their considerable efforts to deliver recommendations for comprehensive reform. The Commission has now sought comment on no less than three reform proposals. While I am not without reservations about some of them, it is time for the Commission to rededicate itself to ensuring that universal service continues to meet our communications challenges and stays vibrant in a broadband age. I look forward to the coming dialogue with Members of Congress, our state commission colleagues, consumers, providers, and the many others with a stake in the future of universal service. Federal Communications Commission FCC 08-122 116 STATEMENT OF COMMISSIONER DEBORAH TAYLOR TATE Re: High-Cost Universal Service Support, Federal-State Joint Board on Universal Service, Alltel Communications, Inc., et al. Petitions for Designation as Eligible Telecommunications Carriers, RCC Minnesota, Inc. and RCC Atlantic, Inc. New Hampshire ETC Designation Amendment, WC Docket No. 05-337, CC Docket No. 96-45. Today we take an important and historic step down the necessary road to real reform of universal service. Specifically, the Commission takes appropriate action to rein in the explosive growth in high- cost universal service support disbursements to competitive eligible telecommunications carriers. In both my role at the Commission and as Federal Chair of the Federal-State Joint Board on Universal Service (Joint Board), I have been clear about my commitment to the key tenets of universal service: to promote the availability of quality services at just, reasonable and affordable rates, to increase access to advanced telecommunications services throughout the Nation, and to advance the availability of such services to all consumers in the U.S., no matter where they live. At the same time, we all recognize that the system is outdated as competition and ever-changing technologies have caused inefficiencies in the current system. I look forward to examining market-oriented solutions such as reverse auctions that can provide appropriate incentives for investment and efficiencies, and closely scrutinizing whether it make economic sense to provide ongoing support for multiple providers who ultimately compete for the same customers. As we examine comprehensive reform our focus should be on encouraging efficiencies, as well as reviewing affordability and creating a level playing field. Most importantly, we must ensure that support from the fund is being utilized as it was intended: to provide services to those in truly high cost areas. And we must do so in a way that is efficient, targeted and fiscally responsible. As stewards of public funds, we must remain mindful that it is consumers who ultimately pay universal service contributions. It has been almost one year since the Joint Board made its recommendation and I would like to reiterate my appreciation for my Co-Chair, Commissioner Ray Baum of the Oregon Public Utility Commission and all of the Joint Board members. Each made valuable contributions to the process and set aside their individual state interests to work toward a unified, national recommendation. In addition, I would like to recognize the dedication and years of committed work of Billy Jack Gregg, former Consumer Advocate of West Virginia, and other public interest stakeholders. Their important input was crucial to bringing us to this point in the process. They should all take pride in the fact that their interim recommendation was adopted today by the Commission and will immediately begin to curb the unsustainable growth-at least regarding the high cost fund. I want to commend members of Congress who have drafted universal service reform proposals- the most recent from Congressman Barton whose draft is renewing discussion on fresh and innovative ideas. I look forward to working with members of Congress as we progress toward comprehensive reform and hope we may all come together to address the issues for the good of the program. Now, the difficult work must begin again toward lasting and full reform to insure the viability of our universal service fund in this new digital age. I humbly ask all of the providers/companies, scholars, economists, professors, and consumer advocates and others with unique knowledge to help us balance the varied and various interests and to work toward a consensus which will continue to insure the fund will remain for future generations. Federal Communications Commission FCC 08-122 117 STATEMENT OF COMMISSIONER ROBERT M. McDOWELL Re: High-Cost Universal Service Support, Federal-State Joint Board on Universal Service, Alltel Communications, Inc., et al. Petitions for Designation as Eligible Telecommunications Carriers, RCC Minnesota, Inc. and RCC Atlantic, Inc. New Hampshire ETC Designation Amendment, WC Docket No. 05-337, CC Docket No. 96-45. I support this Order imposing an interim cap on the Universal Service High Cost Fund. Since becoming a commissioner, I have maintained that controlling the growth of the fund should be the Commission’s first priority. Like an unabated fever, expenditures from this fund continue to spike out of control. Ultimately, it is consumers who pay for these unbridled escalations. While the Commission works toward broader and permanent reform, it is our duty to enact a temporary measure to instill fiscal discipline. For a time, it appeared as though the runaway growth of the fund was slowing. After a spike in the contribution factor to 11.7 percent for the second quarter of 2007, the factor declined steadily to 10.2 percent for the first quarter of 2008. However, the contribution factor is on the increase again, to 11.3 percent for the second quarter of 2008, as announced by the Commission’s Office of Managing Director on March 14. Funding for competitive eligible telecommunications carriers (CETCs) is increasing at a rate of roughly $150 million per year, and some estimate that the CETC funding level could reach as high as $1.4 billion by 2009, if left unchecked. Moreover, this estimate does not even take into account the additional potential increase in demand for CETC funding to build out AWS and 700 MHz spectrum when services on those frequencies come on line. As a result of our order, the fund is frozen at March 2008 levels. Additionally, I support an exception for all of the providers serving tribal lands across the country, and Alaska Native lands – some of the most under-served parts of America. This limited exception will ensure that companies operating in these remote areas will continue to receive high-cost support to provide their services while we move toward a permanent solution. Furthermore, these terms do not favor any specific provider. I look forward to pursuing comprehensive reform of the Universal Service system as quickly as possible. The Commission has a rare opportunity to enact permanent reform this year, and I am encouraged by the Chairman’s pledge to forge ahead. As always, I will work closely with my colleagues, Congress, industry, and consumers toward this end.