HomeMy WebLinkAbout20030731Application.pdf4 Triad Center, Suite 200
Salt Lake City, UT 84180
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July 30, 2003
Mrs. Jean Jewell
Commission Secretary
IDAHO PUBLIC UTILITIES COMMISSION
472 West Washington Street
Boise, ID 83720 OIC- r--dJ~(Jr
RE:Interconnection and Traffic Interchange Agreement between Citizens Telecommunications
Company ofIdaho and Edge Wireless, LLC
Dear Mrs. Jewell:
Citizens Telecommunications Company ofIdaho ("CTC-Idaho ) hereby submits for approval by
the Idaho Public Utilities Commission ("Commission ) the enclosed "Interconnection and
Traffic Interchange Agreement for Cellular and Other 2- Way Mobile Radio Services" dated May
2003 (the "Agreement"), which provides for Edge Wireless, LLC to interconnect with CTC-
Idaho. This Agreement was reached through voluntary negotiations without resort to mediation
or arbitration and is submitted for approval pursuant to Section 252 (e) of the Communications
Act of 1934, as amended by the Telecommunications Act of 1996 ("the Act") and the
requirements ofIdaho Administrative Code, 31.42., Rule 408.
Section 252(e)(2) of the Act directs that a state Commission may reject an agreement reached
through voluntary negotiations only if the commission finds that
(1)the agreement (or portion thereof) discriminates against a telecommunications
carrier not a party to the agreement; or
the implementation of such agreement or portion is not consistent with the public
interest, convenience and necessity.
(2)
CTC-Idaho respectfully submits that the Agreement provides no basis for either of these findings
and, thus, requests that the Commission approve the Agreement expeditiously. First, the
Agreement does not discriminate against any other telecommunications carrier because CTC-
Idaho has made the terms of the Agreement available to other carriers. Second, the Agreement is
consistent with the public interest as identified in the pro-competitive policies of the State of
Idaho, the Commission, the U.S. Congress and the Federal Communications Commission. The
Agreement will enable Edge Wireless, LLC to provide service to, and interconnect with, a
greater number of telecommunications customers in Idaho. Expeditious approval of this
Agreement will facilitate immediate competition in the telecommunications market.
Page 1 of 2
CTC-Idaho further requests that the Commission approve this Agreement without a hearing and
without allowing the intervention of other parties. Because this Agreement was reached through
voluntary negotiations, it does not raise issues requiring a hearing and does not concern other
parties not a part of the negotiations. Expeditious approval would further the public interest.
Enclosed are an original and seven copies ofthis filing. Also included is a copy of this letter.
Please return the copy of this letter, date-stamped in the enclosed postage-paid envelope.
If you have any questions regarding this matter, please contact me at 801-924-6357 (voice), 801-
924-6363 (fax) or ltadeCfYczn.com (e-mail).
Sincerely,
'-:/--
Lance A. Tade
Manager - State Government Affairs
Frontier, A Citizens Communications Company
4 Triad Center, Suite 200
Salt Lake City, UT 84180
cc:Jenny Smith, w/o Attachments
Page 2 of2
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Agreement Number: 00-EWID-
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INTERCONNECTION AND TRAFFIC*INTERCHANGE AGREEMENT
FOR CELLULAR AND OTHER 2-WAY MOBILE RADIO SERVICES
Between
Citizens Telecommunications Company
of Idaho
and
Edge Wireless , LLC
DATED: May 27,2003
Edge Wireless 10 final 052803,doc
Version: 2-
Page i
Agreement Number: 00-EWID-
INTERCONNECTION AND TRAFFIC INTERCHANGE AGREEMENT
CELLULAR AND OTHER 2-WAY MOBILE RADIO SERVICES
TABLE OF CONTENTS
SECTION 1,
SECTION 2,
SECTION 3,
SECTION 4.
SECTION 5,
SECTION 6.
SECTION 7.
SECTION 8.
SECTION 9,
SECTION 10,
SECTION 11.
SECTION 12,
SECTION 13,
SECTION 14.
SECTION 15,
SECTION 16,
SECTION 17.
SECTION 18,
SECTION 19,
SECTION 20,
SECTION 21,
SECTION 22.
SECTION 23,
SECTION 24.
SECTION 25,
SECTION 26
SECTION 27,
SECTION 28
SECTION 29
DEFINITIONS
INTERCONNECTION
USE OF FACILITIES AND SERVICES
CHARGES FOR FACILITIES AND ARRANGEMENTS
ALLOWANCE FOR INTERRUPTIONS
AUDIT
TERM AND TERMINATION OF AGREEMENT
CONFIDENTIALITY AND PUBLICITY
LIABILITY AND INDEMNITY
INTELLECTUAL PROPERTY
DISCLAIMER OF WARRANTIES
RECORD RETENTION
AMENDMENTS; WAIVERS
NOTICES AND DEMANDS
ASSIGNMENT
ESCALATION DISPUTE RESOLUTION AND MEDIATION
ENTIRE AGREEMENT
GOVERNING LAW
EXECUTED IN COUNTERPARTS
HEADINGS
FORCE MAJEURE
REGULATORY APPROVALS
SEVERABILITY
CONDITIONS TO INDEMNIFICATION
NO JOINT VENTURE
REMEDIES
TIME OF ESSENCE
PRONOUNS
FURTHER ASSURANCES
ATTACHMENT 1 - CONTACT LIST
SERVICE ATTACHMENT - INDIRECT
Paqe
Agreement Number: 00-EWID-
INTERCONNECTION AND TRAFFIC INTERCHANGE AGREEMENT
CELLULAR AND OTHER 2-WAY MOBILE RADIO SERVICES
THIS AGREEMENT is made this 27th day of May, 2003 by and between Citizens Telecommunications
Company of Idaho, a Delaware corporation, with offices at 180 S. Clinton , Rochester, NY 14646 (referred
to as "Citizens ), and Edge Wireless , LLC , a Oregon limited liability company, (as defined hereunder) with
its office at 600 S,W, Columbia, Suite 7200, Bend , OR 97702, collectively referred to as the "Carrier
Carrier and Citizens may also be referred to herein collectively as the "Parties" and singularly as a "Party".
WITNESSETH:
Citizens is an authorized telecommunications carrier engaged in providing 2-way telecommunications
service in the state identified in the Attachment(s); and
Carrier is an authorized telecommunications carrier by radio engaged in providing mobile radio
telecommunications service in the state identified in the Attachment(s); and
Citizens and Carrier desire to interconnect their facilities and interchange traffic for the provision of
telecommunications service pursuant to 47 U.C. Section 251 (a) (2);
In consideration of their mutual agreements , Citizens and Carrier agree as follows:
SECTION 1. DEFINITIONS
For purposes of this Agreement, the following definitions will apply:
ACCESS TANDEM -- Citizens' switching system that provides a traffic concentration and distribution
function for traffic originating from or terminating to end offices in the access area,
AUTOMATIC NUMBER IDENTIFICATION ("ANI") -- The automatic identification of the calling station,
AUTHORIZED SERVICES -- Those mobile radio services which the Carrier now or hereafter provides to
its end users on an interconnected basis.
CARRIER'S PREMISES -- A location designated by the Carrier for the purposes of originating or
terminating services provided by Citizens.
CARRIER'S SYSTEM -- The communications system of Carrier used to furnish public mobile services,
CENTRAL OFFICE PREFIX (NXX Code) -- The first three digits of the seven-digit directory number and
associated block of 10 000 numbers for use in accordance with the North American Dialing Plan,
CITIZENS' SYSTEM -- The communications network of Citizens.
CONNECTING FACILITY -- A means for providing access between Citizens' end office or tandem and the
Carrier's Point Of Connection (POC),
DEDICATED NXX -- An NXX the Carrier has obtained from the number administrator for dedication to its
exclusive use and sole administration.
END OFFICE -- The Citizens central office trunking/switching entity where telephone loops are terminated
for purposes of interconnection to each other and to the network.
Edge Wireless 10 final 052803,doc
Version: 2-Page 1
Agreement Number: OO-EWID-
LOCAL CALLING AREA -- (1) The applicable Major Trading Area ("MTA") will be used to define the local
calling area for all telecommunications traffic originated on the system of Carrier and interchanged with
Citizens for delivery in Citizens' exchange areas in the same MTA. (2) Citizens' local calling areas , as
defined by state regulatory authorities will be used to define the local calling area for all
telecommunications traffic originated on the system of Citizens and interchanged with Carrier. These
definitions of "local calling area" will not be deemed to affect the right of either Party to bill its own end-
users its own charges for any such call, nor its right to reciprocal compensation, as defined in Section
51,701 of the FCC's Rules,
MAJOR TRADING AREA -- The Major Trading Area ("MTA") is defined as the local calling scope for
interconnection and is based on the Rand McNally 1992 Commercial Atlas & Marketing Guide, 123rd
Edition, at pages 38-, with the exceptions contained in Section 24.202(a) of the Rules of the Federal
Communications Commission,
MOBILE SWITCHING OFFICE (MSO) -- The Mobile Switching Office used by Carrier in performing
originating and terminating functions for calls interchanged between Carrier s customer and the public
switched network.
LAND-TO-MOBILE DIRECTION -- Calls from land line customers to Carrier s system. Also referred to as
land-to-mobile.
POINT OF INTERCONNECTION (POI) -- Point of Interconnection means the physicallocation(s) at which
the Parties' networks meet for the purpose of establishing interconnection.
SERVICE AREA -- Service Area is defined as the geographic area in which Carrier is authorized by the
FCC to provide services.
MOBILE-TO-LAND DIRECTION -- Calls from Carrier s premises to land line customers. Also referred to
as mobile-to-Iand,
TOLL BILLING EXCEPTION (TBE) -- A service which restricts operator assisted (0-, 0+) land-to-mobile
calls from being sent on a collect (charged to mobile line) basis.
TYPE 2A INTERCONNECTION -- The connection between Carrier s System and a Citizens access
tandem switch, Type 2A interconnection provides connectivity to all Citizens' end offices subtending the
tandem,
TYPE 2B INTERCONNECTION -- A high-usage connection between Carrier s system and a Citizens' end
office subtending a Citizens' tandem, A Type 2B interconnection is an interconnection between the
Wireless MTSO and the ILEC's End Office only, Citizens will not complete any call to customers not
served by the specified Citizens End Office in the attached Service Attachment for Type 2B and will not
originate any calls from customers not served by the Citizens End Office.
WIRELESS PROVIDER -- Telecommunications common carrier authorized by the Federal
Communications Commission (FCC) under FCC rules Part 22 (47 CFR Part 22), Part 24 (47 CFR Part
24), and Part 90 (47 CFR Part 90) which utilizes radio as the principal means of connecting its end-user
subscribers with the Public Switched Telephone Network,
SECTION 2. INTERCONNECTION
Subject to the applicable interconnection rules and regulations, Citizens will provide to Carrier
upon request, those facilities and arrangements described herein and in the Attachments hereto to
establish the physical interconnection and interchange of traffic provided for herein and such other
facilities Carrier may require and request for operation of its system.
Agreement Number: 00-EWID-
All interchanged traffic will be handled only over interconnecting facilities as described herein.
The type of interconnections offered under this Agreement are designated as Type 2A, and Type 2B, as
defined in Section 1,
Local Traffic may be indirectly exchanged and routed through one or more intermediaries for
interconnection with the other Party s system and , transit a Tandem switch before reaching Citizens ' End
Office or Edge Wireless s MSC, Indirect traffic will be subject to Reciprocal Compensation pursuant to this
Agreement.
In the event indirect traffic volumes exceed a DS1 level (512 centum call seconds or
CCS) when measured at the busy hour at least 15 times per month over a three (3) month period
the Parties will establish one or more of the direct interconnections pursuant to this Section 2,
If Carrier provides service using an NPA-NXX assigned solely to a rate center where
Citizens provides EAS or a Commission approved optional calling plan and Carrier
chooses to indirectly interconnect by using the Tandem switching facilities of a third party,
each Party shall reciprocally terminate on its network Local Traffic originating from the
other Party s network, provided that the Parties have agreed on measurement and/or
compensation arrangements.
2.4 Carrier may request activation/addition of new locations under the terms and conditions of this
Agreement at any time during the term by submitting a request for interconnection to Citizens
Interconnection organization. Citizens will provide an amended Service Attachment to reflect activation or
addition of new locations. The Service Attachment will be signed by Citizens' authorized representative
and Carrier s authorized representative, affixed to this Agreement, and thereby being made a wholly part
and subject to this Agreement. To the extent that any of the Service Attachments may be inconsistent
with or in conflict with this Agreement, the Agreement will prevail.
Signaling Systems and Administration
The Parties will , where Citizens has the capability, interconnect their networks using SS7
signaling associated with all interconnection trunk groups as defined in Telcordia GR-246 "Bell
Communications Research Specification of Signaling Systems 7 (SS7) and GR-905
, "
Common Channel
Signaling Network Interface Specification (CCSNIS) Supporting Interconnection , Message Transfer Part
(MTP), and Integrated Services Digital Network (ISDN) User Part (ISUP) "including ISDN User Part
ISUP") for trunk signaling and Transaction Capabilities Application Part ("TCAP") for CCS-based
features in the interconnection of their networks. For glare resolution , Citizens will have priority on odd
trunk group member circuit identification codes, and carrier will have priority on even trunk group member
circuit identification codes, unless otherwise mutually agreed.
The terms and conditions of this Agreement will prevail over and supersede any other conflicting
rates, terms and conditions contained on Carrier s purchase order for services provided under this
Agreement.
At Carrier s request, Citizens and Carrier will physically interconnect their facilities at Citizens
office or another mutually agreed to POI, and interchange traffic originating and/or terminating on Carrier
System in connection with Carrier s Authorized Services; such interconnection will be in accordance with
the service, operating and facility arrangements set forth hereinafter.
Sizing and Structure of Interconnection Facilities
The Parties will mutually agree on the appropriate sizing for facilities based on the
standards set forth below, The capacity of interconnection facilities provided by each Party will be based
on mutual forecasts and sound engineering practice, as mutually agreed to by the Parties.
Agreement Number: 00-EWID-
The electrical interface at Points of Interconnections (POls) will be DS1 or DS3 as
mutually agreed to by the Parties. When a DS3 interface is agreed to by the Parties, Citizens will provide
any multiplexing required for DS1 facilities or trunking at their end and Carrier will provide any DS1
multiplexing required for facilities or trunking at their end. Citizens will charge DS3/DS1 multiplexing
charges according to Citizens FCC #1 Tariff.
Citizens and Carrier will engineer all Traffic Exchange Trunks using a network loss plan
conforming to ANSI T1,508-1998 and ANSI T1.508-1998 Supplement A.
9. Where additional equipment is required, such equipment would be obtained, engineered, and
installed on the same basis and with the same intervals as any similar growth job for Carriers, or Citizens
internal customer demand.
Trunk Forecasting
10.1 The Parties will work towards the development of joint forecasting responsibilities for
traffic utilization over interconnection trunk groups covered in this contract. Orders for trunks that exceed
forecasted quantities for forecasted locations will be accommodated as faCIlities and/or equipment
becomes available. Parties will make all reasonable efforts and cooperate in good faith to develop
alternative solutions to accommodate orders when facilities are not available, Intercompany forecast
information must be provided by the Parties to each other upon reasonable request. Citizens' preference
is a semi-annual forecast covering the following 24-month period,
Grade of Service
11.1 Each Party will provision their network to provide a P .01 grade of service,
11.2 The characteristics and methods of operation of any circuits, facilities or equipment of
either Party connected with the services, facilities or equipment of the other Party pursuant to this
Agreement shall not interfere with or impair service over any facilities of the other Party, its affiliated
companies, or its connecting and concurring carriers involved in its services, cause damage to their plant
violate any applicable law or regulation regarding the invasion of privacy of any communications carried
over the Party s facilities or create hazards to the employees of either Party or to the public (each
hereinafter referred to as an "Impairment of Service
11.Each Party will advise the other of any critical nature of the interoperative facilities
service, and arrangements and any need for expedited clearance of trouble. In cases where a Party has
indicated the essential or critical need for restoration of the facilities, services or arrangements, the other
Party will use its best efforts to expedite the clearance of trouble,
SECTION 3. USE OF FACILITIES AND SERVICES
The interconnecting facilities will be used only for the handling of interchanged traffic originating or
terminating on Carrier s System in connection with Carrier s Authorized Services. Such facilities may,
however, be used for any lawful use. This Agreement is applicable only to Citizens' Local serving areas
within Carrier s MTA, Citizens will not be responsible for interconnections or contracts relating to Carrier
interconnection with any other LEC.
Connecting circuits , facilities and arrangements provided pursuant to this Agreement will not be
used , switched or otherwise connected together by Carrier for the provision of through calling from a
land line telephone to another land line telephone or from a landline telephone to an Internet Service
Provider. The only exception is when Carrier s end-user "call forwards" to a land line telephone,
Connecting circuits, facilities and arrangements provided to Carrier by Citizens will not be used
knowingly for any purpose or in any manner, directly or indirectly, in violation of law or in aid of any
unlawful act or undertaking,
Agreement Number: 00-EWID-
3.4 When needed and upon request by Carrier, special construction will be undertaken in accordance
with the applicable Citizens tariff or as mutually negotiated by the Parties.
Any other provision of this Agreement notwithstanding, Citizens will recognize, deliver traffic to
accept traffic from, and otherwise honor the validity of any NXX assigned to Carrier by a third party in
accordance with 47 USC Section 251 (e) (or related FCC or state number administration rules),
Network Harm
Neither Party will use any service related to or use any of the services provided in this
Agreement in any manner that interferes with third parties in the use of their service, prevents third parties
from using their service, impairs the quality of service to other carriers or to either Party s Customers;
causes electrical hazards to either Party s personnel, damage to either Party's equipment or malfunction
of either Party s billing equipment (individually and collectively, "Network Harm ), If a Network Harm will
occur or if a Party reasonably determines that a Network Harm is imminent, such Party will, where
practicable, notify the other Party that temporary discontinuance or refusal of service may be required;
provided , however, wherever prior notice is not practicable, such Party may temporarily discontinue or
refuse service forthwith, if such action is reasonable under the circumstances. In case of such temporary
discontinuance or refusal , such Party will:
(a)
(b)
Promptly notify the other Party of such temporary discontinuance or refusal;
Afford the other Party the opportunity to correct the situation which gave rise to
such temporary discontinuance or refusal; and
(c)Inform the other Party of its right to bring a complaint to the Commission or FCC.
Citizens and Carrier each may make reasonable tests and inspections of its facilities and may,
upon notice and coordination with the other, temporarily interrupt the facilities being tested or inspected
so long as impairment or restriction of the operation of facilities is minimized, When cooperative testing is
requested by either Party, such testing will be done in accordance with this Section 3,
The characteristics and methods of operation of any circuits, facilities or equipment of either Party
connected with the services , facilities or equipment of the other Party pursuant to this Agreement will not
interfere with or impair service over any facilities of either Party, its Affiliates, or its connecting and
concurring carriers involved in its services, cause damage to their plant, invade the privacy of any
communications carried over either Party's facilities or create hazards to the employees of any of them or
to the public.
Carrier will be solely responsible, at its expense, for the overall design of its services and for any
redesigning or rearrangement of its services which may be required because of changes in facilities
operations or procedures of Citizens , minimum network protection criteria, operating or maintenance
characteristics of the facilities,
10 Mobile customers of Carrier will be instructed to report all cases of trouble to Carrier. In order to
facilitate trouble reporting and to coordinate the repair of service provided to Carrier by Citizens under this
Agreement
, "
Citizens 24-Hour Repair Center" will provide 24-hour trouble reporting for Carrier.
10,1 Where new facilities, services and arrangements are installed , Citizens, via the NOC, will
ensure that continuity has been established and that appropriate transmission measurements have been
made before advising Carrier that the new circuit is ready for service.
10.Citizens will furnish a trouble reporting telephone number for the designated NOC. See
Attachment 1. This number will give Carrier access to the location where its facility records are normally
located and where current status reports on any trouble reports are readily available, Alternative out-of-
Agreement Number: 00-EWID-
hours procedures will be established to ensure access by Carrier to a location which is staffed and has the
authority to initiate corrective action,
10,Before Carrier reports a trouble condition , it will use its commercially reasonable efforts to
isolate the trouble to Citizens' facilities.
10.4 In cases where a trouble condition adversely affects Carrier s service, Citizens will give
Carrier the same priority extended to other telephone companies.
10.Citizens and Carrier will cooperate in isolating the trouble.
SECTION 4. CHARGES FOR FACILITIES AND ARRANGEMENTS
Reciprocal Termination Charqes This form of reciprocal termination charging is a usage-
sensitive in which each party assesses the other usage-sensitive charges for the termination of
traffic on each other s system. The Service Attachment to this Agreement reflects the selection
by the Parties,
Reciprocal Transport Charqes. Each Party is solely responsible for the provision of transport
facilities necessary for the carriage of interchanged traffic between the Point of Interconnection
and points within its own network and for all costs of delivering traffic to the Point of
Interconnection; provided, however, that Citizens shall have no responsibility for delivering traffic
to a Point of Interconnection located at any point outside of a Citizens local exchange area or
beyond the boundary.
Reciprocal Termination Charqes,Reciprocal Termination Charges are assessed on a per minute
basis,
4.4 Each Party agrees to pay the other Party all undisputed charges specified on the Service
Attachment within thirty (30) calendar days of the bill date as printed on the face of the bill offset by
reciprocal compensation charges owed to it by said other Party. If the entire amount billed (excluding any
amount disputed by a Party) is not received by the other Party in immediately available funds within thirty
(30) calendar days of the bill date (as printed on the face of the bill), a late payment charge will be applied
to the unpaid balance, The charge is applied to a total unpaid amount carried forward and is included in
the total amount due on the bill. The rate for the late payment charge will be the same as found in
Citizens FCC #1 Tariff,
Each Party will charge and collect from the other Party appropriate federal, state and local taxes,
Where a Party notifies the other Party and provides appropriate documentation that such Party qualifies
for partial or full exemption , then the billing Party will not collect such taxes from the other Party.
In the absence of an agreement between Carrier, Citizens and other local exchange carriers in the
MTA in which Carrier s System is located , Citizens has no obligation to deliver calls in the MOBILE-TO-
LAND DIRECTION to points in the MTA in which Carrier's System is located that are beyond Citizens
local exchange areas, at rates set forth in the Service Attachment(s) to this Agreement.
Billing by either Party for calls to be terminated on its own network will begin at trunk seizure and
will end at time of call disconnect.
Minutes of use, or fractions thereof, are accumulated over the billing period. Fractions of minutes
are rounded up monthly to the nearest whole minute for total minutes for each end office for billing
purposes,
For the purpose of this Agreement, the Parties , when the necessary facilities are deployed, agree
Agreement Number: 00-EWID-
to utilize industry standard technical arrangements enabling each Party to provide the other Party with all
electronic signaling data necessary to bill terminating traffic, including but not limited to ANI.
When the Parties have directly interconnected their facilities , or when traffic between the Parties is
terminated indirectly, either Party may utilize its own systems or the records from a third party,
including Edge Wireless, to calculate traffic terminated to its network. In the event either Party is
unable to determine the amount of mobile-to-Iand or land-to-mobile traffic terminated in a specific
End Office(s) or Tandem , the Parties agree to apply a traffic factor to the volume of land-to-mobile
traffic Edge Wireless terminates from Citizens to calculate the mobile-to-Iand traffic Citizens
terminates from Edge Wireless.
10.1 Edge Wireless shall assume 70% ownership of the traffic exchanged between the Parties
and Citizens shall assume 30% ownership of the traffic exchanged between the Parties as
referenced in , and adjusted pursuant to, Section 4 of the Service Attachment to this agreement.
SECTION 5. ALLOWANCE FOR INTERRUPTIONS
When use of the facilities furnished by either Party to the other Party in accordance with this
Agreement is interrupted due to trouble in such facilities and such interruption is not caused by the
interrupted Party, any contractor or supplier of the interrupted Party or its customer, the interrupted Party
will , upon request, be allowed a credit as follows:
The amount of credit to Carrier will be an amount equal to the pro rata monthly charge for the
period during which the facility affected by the interruption is out of service,
Claims for reimbursement will be made in writing within sixty (60) calendar days of the
occurrence, All credit for interruption will begin from the time of actual notice by the interrupted Party to
the other Party, in accordance with Section 14 following, that an interruption of use has occurred. No
credit will be allowed for an amount of less than five dollars ($5),
5.4 A credit will not be applicable for any period during which the interrupted Party fails to afford
access to the facilities furnished by the other Party for the purpose of investigating and clearing troubles.
SECTION 6. AUDIT
Either Party may, upon written notice to the other Party, conduct an audit, during normal business hours
only on the source data/documents as they may contain information bearing upon the services being
provided under the terms and conditions of this Agreement. An audit may be conducted no more
frequently than once per 12-month period, and only to verify the other Party s compliance with provisions
of this Agreement. The notice requesting an audit must identify the date upon which it is requested to
commence, the estimated duration, the materials to be reviewed, and the number of individuals who will
be performing the audit. Each audit will be conducted expeditiously. Any audit is to be performed as
follows: (i) following at least 45 days prior written notice to the audited Party; (ii) subject to the reasonable
scheduling requirements, during ordinary business hours , and limitations of the audited Party; (iii) at the
auditing Party s sole cost and expense; (iv) of a reasonable scope and duration; (v) in a manner so as not
to interfere with the audited Party s business operations, Any other provision of this Section 6
notwithstanding, each Party shall have the right to audit only such data and records as are available in (or
reproducible on) paper or other tangible (non-electronic) medium , and neither Party may have access to
the other Party s electronic records without the other s prior written consent.
SECTION 7. TERM AND TERMINATION OF AGREEMENT
This Agreement will become effective upon the first business day following the date this
Agreement has been approved by the applicable regulatory authority or authorities and will continue for a
Agreement Number: 00-EWID-
period of one (1) year unless terminated earlier under the conditions set forth in this Section. This
Agreement will be automatically renewed for successive periods of one (1) year after the initial term
unless either Party provides the other Party with no less than ninety (90) day s prior, written notification of
in the case of Citizens, its intent to ,terminate this Agreement, or, in the case of either Party, its desire to
renegotiate at the end of the initial or any successive period. During any such renegotiation, the rates
terms and conditions of this Agreement will remain in effect until the effective date of the renegotiated
agreement.
The date when the facilities and arrangements furnished under this Agreement will be placed into
service will be mutually agreed upon by the Parties , subject to applicable state regulatory approvals. If
service is not established by such date, or in the event Carrier ceases to engage in the business of
providing public land mobile radio service, either Party may terminate this Agreement on thirty (30)
calendar days notice subject, however, to payment for facilities or arrangements provided or for costs
incurred. Citizens will consult with Carrier prior to termination by Citizens.
This Agreement will immediately terminate upon the suspension , revocation or termination by
other means of either Party's authority to provide communications services over its System.
7.4 This Agreement may be terminated at any time by either Party upon not less than thirty (30)
calendar days notice, providing an opportunity to cure, to the other Party as set forth in Section 14
following, for material breach or failure to pay the other Party all undisputed charges on the dates or at the
times specified in the applicable invoice for the facilities and services fumished pursuant to this
Agreement.
If a dispute arises between the Parties as to the proper charges for the facilities or arrangements
furnished, or any other financial arrangements, the failure to pay an amount in dispute will not constitute
cause for termination of this Agreement provided that a bond or escrow account (or other security
arrangement reasonably acceptable to both Parties) is made for the security of the amount in dispute.
The continuation of such dispute will not be deemed cause for Citizens to refuse to furnish additional
facilities or arrangements upon reasonable request of Carrier or otherwise relieve the Parties of their
obligation to fully comply with the provisions hereof as to which no dispute exists, provided financial
security for payment of the amount in dispute has been made as stated above, Any dispute arising as to
the security arrangement under this Section 7,5 will be subject to the dispute resolution provisions of
Section 16 below.
Notwithstanding any other provisions of this Agreement, this Agreement may be terminated at any
time as mutually agreed by the Parties.
SECTION 8. CONFIDENTIALITY AND PUBLICITY
All proprietary or confidential information ("Proprietary Information ) disclosed by either Party
during the negotiations and the term of this Agreement will be protected by both Parties in accordance
with the terms of this Section 8.
As used in this Agreement, the term "Proprietary Information" will mean written , recorded
machine readable or other information provided in tangible form to one Party by the other Party regarding
the above referenced subject matter and which is marked proprietary or confidential with the appropriate
owner corporation name, e,
g" "
Citizens Proprietary", Information disclosed orally will not be considered
proprietary unless such information is reduced to writing by the disclosing Party and a copy is delivered to
the other Party within thirty (30) business days after such oral disclosure, The writing will also state the
place , date and person(s) to whom disclosure was made.
Each Party agrees that it will not disclose any Proprietary Information of the other Party in whole
or in part, including derivations, to any third party for a period of three (3) years from the date of disclosure
unless the Parties agree to modify this Agreement to provide for a different nondisclosure period for
specific materials, Neither Party will be liable for inadvertent or accidental disclosure of Proprietary
Agreement Number: 00-EWID-
Information of the other Party provided that:
(i) each Party uses at least the same degree of care in safeguarding such Proprietary
Information as it uses for its own proprietary information of like importance and such degree of
care will be reasonably calculated to prevent such inadvertent disclosure;
(ii) it limits access to such Proprietary Information to its employees, attorneys and agents
who are directly involved in the consideration of the Proprietary Information and informs its
employees and agents who have access to such Proprietary Information of its duty not to
disclose; and
(iii) upon discovery of any such inadvertent disclosure of Proprietary Information, it will
endeavor to prevent any further inadvertent disclosure.
8.4 Information will not be deemed proprietary and the receiving Party will have no obligation with
respect to any such information which:
(i) is or becomes publicly known through no wrongful act, fault or negligence of the receiving
Party; or
(ii) was known by the receiving Party or by any other affiliate or subsidiary of the receiving
Party prior to disclosure, or is at any time developed by the receiving Party independently of any
such disclosure; or
(iii) was disclosed to the receiving Party by a third party who was free of obligations of
confidentiality to the disclosing Party; or
(iv) is disclosed or used by the receiving Party, not less than three (3) years following its initial
disclosure or such other nondisclosure period as may be agreed in writing by the Parties; or is
approved for release by written authorization of the disclosing Party; or
(v) is disclosed pursuant to a requirement or request of a governmental agency or disclosure
is required by operation of law.
Since either Party may choose not to use or announce any services, products or marketing
techniques relating to these discussions or information gained or exchanged during the discussions, both
Parties acknowledge that one is not responsible or liable for any business decisions made by the other in
reliance upon any disclosures made during any meeting between the Parties or in reliance on any results
of the discussions. The furnishing of Proprietary Information to one Party by the other Party will not
obligate either Party to enter into any further agreement or negotiation with the other.
Nothing contained in this Agreement will be construed as granting to one Party a license, either
express or implied , under any patent, copyright or trademark, now or hereafter owned, obtained
controlled, or which is or may be licensable by the other Party.
Except for public filings, litigation , or other administrative or judicial proceedings arising from or
related to the Agreement, all publicity regarding this Agreement and its Attachments is subject to the
Parties' prior written consent.
Unless otherwise agreed upon, neither Party will publish or use the other Party s name, language
pictures, or symbols from which the other Party s name may be reasonably inferred or implied in any
advertising, promotion , or any other publicity matter relating directly or indirectly to this Agreement.
SECTION 9. LIABILITY AND INDEMNITY
Agreement Number: 00-EWID-
Neither Party will be liable for any act or omission of the other Party in the furnishing of that Party'
service to its customers.
To the extent not prohibited by law or tariff and except as otherwise provided in the Agreement
each Party will indemnify, defend and hold harmless the other Party from any loss, cost, claim, injury or
liability brought by a person not a Party under this Agreement which is proximately caused by the negligent
acts or omissions or willful misconduct of the indemnifying Party or its employees, agents or contractors in
connection with the performance of this Agreement. Such indemnity only extends to the comparative
degree of negligence attributable to the indemnifying Party, as determined by state law negligence
standards.
To the extent not prohibited by law or tariff, Citizens will reimburse Carrier for damages to
premises or equipment of Carrier resulting from the installation or removal of facilities, services or
arrangements by Citizens and/or its employees or agents on such premises if predominately caused by
the sole or comparative negligence or willful misconduct of Citizens, its employees or agents.
9.4 Carrier will reimburse Citizens for damages to facilities of Citizens provided under this Agreement
if caused by the negligence or willful act of Carrier or due to malfunction of any facilities or equipment
provided to Carrier by an entity, other than Citizens. Citizens will cooperate with Carrier in prosecuting a
claim against the person causing such damage and Carrier will be subrogated to Citzens right to recover
for the damages to the extent of such payment.
Each Party will reimburse the other Party for any loss through theft of facilities provided under this
Agreement on such Party s premises attributable to the reimbursing Party s actions (or to that of its agents
or employees), except to the extent that such loss is due to the other Party s comparative negligence,
The Parties will cooperate with each other in the defense of any suit, claim or demand by third
persons against either or both of them arising out of the connection arrangements and interchange of
traffic including, without limitation , Workers Compensation claims, actions for infringement of copyright
and/or unauthorized use of program material, libel and slander actions based on the content of
communications.
Neither Party will be required to reimburse the other for any claim or loss pursuant to this Section
9 arising out of a single incident, where the amount in controversy is less than one hundred dollars
($100,00).
SECTION 10. INTELLECTUAL PROPERTY
10.Citizens and Carrier will each defend, indemnify, hold harmless the other Party and/or acquire any
license or right for the benefit of the other Party, arising from any claim demand or proceeding
(hereinafter "Claim ) by any third party alleging or asserting that the use of any circuit, apparatus, or
system, or other facilities, or the use of any software, or the performance of any service or method, or the
provision or use of any facilities by either Citizens or Carrier under this Agreement constitutes direct or
contributory infringement, or misuse or misappropriation of any patent, copyright, trademark, trade secret
or any other proprietary or intellectual property right of any third party, Each Party s indemnification
obligation will be to the extent of infringement by the indemnifying Party
10,Nothing in this Agreement will be construed as the grant of a license by, or the creation of an
estoppel against, Citizens, either express or implied , with respect to any patent, copyright, trademark
trade secret or any other proprietary or intellectual property right now or hereafter owned, controlled or
licensable by Citizens, except to the extent necessary for Carrier to use any facilities or equipment
(including software) or to receive any service provided by Citizens under this Agreement.
SECTION 11. DISCLAIMER OF WARRANTIES
11,NOTWITHSTANDING ANY OTHER PROVISION OF THIS AGREEMENT (INCLUDING
Agreement Number: 00-EWID-
WITHOUT LIMITATION THE PARTIES' RESPECTIVE INDEMNIFICATION OBLIGATIONS), THE
PARTIES AGREE THAT CITIZENS HAS NOT MADE, AND THAT THERE EXISTS, NO WARRANTY
EXPRESS OR IMPLIED, THAT THE USE BY CARRIER OF FACILITIES, ARRANGEMENTS, OR
SERVICES PROVIDED BY CITIZENS UNDER THIS AGREEMENT WILL NOT GIVE RISE TO A CLAIM
BY ANY THIRD PARTY OF INFRINGEMENT, MISUSE, OR MISAPPROPRIATION OF ANY
INTELLECTUAL PROPERTY RIGHT OF SUCH THIRD PARTY.
11.CITIZENS WILL PROVIDE INTERCONNECTION TO CARRIER OF A QUALITY AND IN A
DILIGENT MANNER CONSISTENT WITH SERVICE CITIZENS PROVIDES TO ITS CUSTOMERS AND
OTHER INTERCONNECTORS, IN ACCORDANCE WITH APPLICABLE TECHNICAL STANDARDS FOR
INTERCONNECTION SERVICES ESTABLISHED IN THE TELECOMMUNICATIONS INDUSTRY,
CITIZENS MAKES NO OTHER WARRANTY, EXPRESS OR IMPLIED, WITH RESPECT
TRANSMISSION, EQUIPMENT OR SERVICE PROVIDED HEREUNDER, AND EXPRESSLY
DISCLAIMS ANY WARRANTY OF MERCHANTIBILITY OR FITNESS FOR ANY PARTICULAR
PURPOSE.
11.It is the express intent of the Parties that each Party be solely responsible for all claims of its end-
users , including, without limitation , any credits or adjustments that may be issued or required to be issued
to its end-users, except to the extent such claims are found to be caused by the other Party s gross
negligence or willful misconduct.
11 .4 Except for allowance of interruptions as set forth in Section 5, in no event will either Party be liable
to the other Party for incidental, special , or consequential damages, loss of goodwill, anticipated profit, or
other claims for indirect or special damages in any manner related to this Agreement or the services even
if such Party was advised of the possibility of such damages, and whether or not such damages were
foreseeable or not at the time this Agreement was executed.
SECTION 12. RECORD RETENTION
12,All data associated with the provision and receipt of Service(s) pursuant to this Agreement will be
maintained for the greater of:
(i)the retention time required by law for maintaining Federal, State, and Local tax
information;
(ii)the retention time required by law or regulation in order to substantiate or reconstruct an
End-User invoice; and
(iii)the retention time currently used by Citizens for its billing information or Carrier for its own
billing information, in compliance with legal or regulatory requirements; or
(iv)the retention time as agreed to by both Parties in writing,
12.Either Party will , upon reasonable request, furnish copies or otherwise make available to the other
Party its licenses and other federal and, if applicable , state regulatory authorizations.
SECTION 13. AMENDMENTS; WAIVERS
13.This Agreement may be amended only by written agreement signed by authorized representatives
of both Parties,
13,No waiver of any provisions of this Agreement and no consent to any default under this
Agreement will be effective unless the same is in writing and signed by or on behalf of the Party against
whom such waiver or consent is claimed.
Agreement Number: 00-EWID-
13.No course of dealing or failure of either Party to strictly enforce any term, covenant or condition of
this Agreement in anyone or more instances will be construed as a waiver or relinquishment of any such
terms, covenants or conditions, but the same will be and will remain in full force and effect.
SECTION 14. NOTICES AND DEMANDS
14,All notices, demands or requests which may be given by any Party to the other Party under this
Agreement (other than Trouble reports and Notice of Interruption pursuant to Sections 3 and 5) are to be
in writing (or made electronically, followed by written confirmation thereof) and will be deemed to have
been duly delivered on the date delivered in person or on the date received in writing if sent via telex
telefax, e-mail or cable, or three (3) business days after the date deposited, postage prepaid, in the United
States Mail via certified mail return receipt requested , or the day after delivery to an overnight courier and
addressed as follows:
For Carrier.
Edge Wireless, LLC
Attn: Angel Hawman
600 S,W. Columbia , Suite 7200
Bend , OR 97702
Telephone: (541) 312-5405
Fax: (541) 312-5870
and to Citizens , addressed as follows:
Citizens Communications
Attn: Director - Carrier Services
180 S, Clinton
Rochester, NY 14646
Telephone: (585) 777-7124
Fax: (585)424-1196
With copy to:
Kevin Keillor, General Counsel
600 S.W. Columbia, Suite 7200
Bend , OR 97702
Telephone: (541) 312-5430
Fax: (541) 312-5868
Any Invoices should be sent to:
Citizens Communications
Attn: Access Validation
14450 Burnsville Drive
Burnsville, MN 55306
14.If personal delivery is selected as the method of giving notice under this Section, a receipt of such
delivery will be obtained,
14,The address to which such notices, demands, requests, elections or other communications may
be given by either Party may be changed by written notice given by such Party to other Party pursuant to
this Section.
SECTION 15. ASSIGNMENT
Any assignment by either Party of any right, obligation or duty, in whole or in part, or of any other interest
without the written consent of the other Party will be void, except either Party may assign all or part of its
rights and obligations to any legal entity which is a subsidiary or Affiliate of that Party without consent, but
with written notification. For purposes of this Agreement, an "Affiliate" of a Party is any entity directly or
indirectly controlling, controlled by, or under common control with said Party, and "control" means the
ownership of, or the power to vote the equity securities or comparable interests of, forty percent (40%) or
more the controlled entity, Such written consent to assignment to all other entities will not be
unreasonably withheld or delayed. All obligations and duties of any Party under this Agreement will be
binding on all successors in interest and assigns of such Party and such assignment will not waive any
right or remedy available to either Party under law, regulation or this Agreement, including without
limitation the right of set-off, Each Party, upon written notice to the other, may from time to time and
without additional consideration add any of its future Affiliates as parties to this Agreement and the other
Party shall reasonably cooperate in amending this Agreement to effect such an addition; provided,
however, such addition is subject to the condition that any such added Affiliate of Citizens be an
incumbent local exchange carrier and any such added Affiliate of Carrier be a Wireless Carrier.
SECTION 16. DISPUTE RESOLUTION
Agreement Number: 00-EWID-
Any controversy or claim arising out of or relating to this Agreement, or the breach thereof, will be resolved
by both Parties according to the procedures set forth below.
The Parties agree that in the event of a default or any other dispute arising hereunder or in connection
herewith, the aggrieved Party shall first discuss the default or dispute with the other Party and seek
resolution prior to taking any action before any court or regulator or before authorizing any public
statement about or disclosure of the nature of the dispute to any third party, Such conferences shall if
necessary be escalated to the vice presidential level for each Party. In the event that the Parties shall be
unable to resolve a default or other dispute, the Parties shall then submit the matter to the PSC for non-
binding mediation. If mediation by the PSC is unsuccessful , recourse may be had by either Party to the
PSC , if it has jurisdiction over the breach or dispute or to an appropriate court having jurisdiction over the
Parties, Each Party shall bear the cost of preparing and presenting its case through all phases of thedispute resolution procedure herein described.
SECTION 17. ENTIRE AGREEMENT
This Agreement, including the preamble and all Attachments hereto , constitutes the entire agreement
between the Parties and supersedes all prior or contemporaneous oral or written agreements,
representations, statements, negotiations , understandings , proposals and undertakings with respect to the
subject matter hereof. Except as otherwise expressly provided in this Agreement, neither Party is to be
bound by any pre-printed terms appearing in the other Party's form documents , tariffs, purchase orders
quotations, acknowledgments, invoices, or other instruments. All exhibits referred to in this Agreement are
incorporated herein by reference,
SECTION 18. GOVERNING LAW
This Agreement will be deemed to be a contract made under and will be construed, interpreted and
enforced in accordance with the Communications Act of 1934, as amended, and, to the extent federal law
is inapplicable, to the laws of the State of interconnection and will be subject to the concurrent jurisdiction
of the Federal Communications Commission and the courts, public service commission , and other
agencies in that state.
SECTION 19. EXECUTED IN COUNTERPARTS
This Agreement may be executed in counterparts, each of which is to be an original, but such
counterparts will together constitute but one and the same document.
SECTION 20. HEADINGS
The headings and numbering of Sections and paragraphs in this Agreement are for convenience only and
will not be construed to define or limit any of the terms herein or affect the meaning or interpretation of this
Agreement.
SECTION 21. FORCE MAJEURE
Neither Party will be held liable for any delay or failure in performance of any part of this Agreement from
any cause reasonably beyond its control and without its fault or negligence, including, but not limited to,
acts of God , acts of civil or military authority, government regulations or orders, embargoes, epidemics
war, terrorist acts, riots, insurrections , fires, explosions, earthquakes , nuclear accidents , floods , labor
difficulties or strikes, power blackouts , unusually severe weather conditions, inability to secure products or
services or other persons or transportation facilities, or acts or omissions of transportation common
Agreement Number: 00-EWID-
carriers (collectively referred to as "Force Majeure" conditions), The Party whose performance is impaired
by such Force Majeure condition will exercise commercially reasonable efforts to mitigate the effects
thereof; and neither Party has any obligation to pay for any services disrupted or not provided during the
period of such Force Majeure.
SECTION 22. REGULATORY APPROVALS
22,Although this Agreement may be executed by both Parties, to the extent that any federal or state
statute, order, rule or regulation or any state regulatory agency having competent jurisdiction over one or
both Parties to this Agreement will require that this Agreement be approved by such regulatory agency
before this Agreement may be effective, this Agreement will not be effective in such state notwithstanding
the Parties' signature until the first business day after such approval has been obtained,
22,Each Party agrees to cooperate with each other and with any regulatory agency so that any
approval necessary to provide the Service(s) under this Agreement is obtained. During the term of this
Agreement, each Party agrees to continue to cooperate with each other and with any regulatory agency so
that the benefits of this Agreement may be achieved.
SECTION 23. SEVERABILITY
In the event that anyone or more of the provisions contained herein , is, for any reason, held to be
unenforceable in any respect under law or regulation, the remainder of this Agreement will not be affected
thereby and will continue in full force and effect, unless removal of that provision results in a material
change to this Agreement. In such a case, the Parties will negotiate in good faith for replacement
language. If replacement language cannot be agreed upon , either Party may invoke the dispute resolution
procedures of Section 16 foregoing,
SECTION 24. CONDITIONS TO INDEMNIFICATION
Upon a request for indemnification owed by either party (the "indemnifying Party") to the other (the
indemnified Party") under this Agreement, the indemnified Party shall promptly notify the indemnifying
Party of any and all threats, written claims, or demands for which indemnification is sought under this
Agreement. Each Party shall cooperate fully with the other, and the indemnifying Party shall control such
defense and the right to litigate, settle, appeal (provided it pays the cost of any required appeal bond),
compromise or otherwise deal with any such claim or resulting judgment; provided further that such
settlement, compromise or other resolution of such claim does not result in any liability to the indemnified
Party, The indemnified Party shall have the right to retain to undertake its own defense or settlement of any
such threat, claim or demand upon written notice to the indemnifying Party, whereupon the indemnifying
Party's indemnification obligations with respect to such threat, claim or demand (but not with respect to any
other) shall automatically be excused,
SECTION 25. NO JOINT VENTURE
Nothing herein contained shall be construed as creating a partnership or joint venture by or between the
Parties.
SECTION 26. REMEDIES
Unless stated otherwise, all remedies provided for in this Agreement shall be cumulative, nonexclusive and in
addition to, but not in lieu of, any other remedies available to either Party at law, in equity, or otherwise,
SECTION 27. TIME OF ESSENCE
Time is of the essence of this Agreement.
SECTION 28. PRONOUNS
Agreement Number: 00-EWID-
Pronouns used herein are to be construed as masculine, feminine, or neuter, and both singular and plural, as
the context may require; the term "person" includes an individual , corporation, association, partnership,
limited liability company, limited liability partnership, trust, and any other organization; and the term "includes
is to be construed as without limitation.
SECTION 29. FURTHER ASSURANCES
From and after the date of this Agreement, each of the Parties shall, from time to time, at the request of the
other Party and without further consideration, do, execute and deliver, cause to be done, executed and
delivered , all such further acts , things and instruments as may be reasonably requested or required more
effectively to evidence and give effect to the transactions contemplated by this Agreement.
The Parties thereto have caused this Interconnection and Traffic Interchange Agreement for Cellular and
Other 2-Way Mobile Radio Services to be executed in their behalf on the dates set forth below:
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ATTACHMENT 1
CONTACT LIST
24-HOUR REPAIR CENTER - 1-800-565-1619
Edge Wireless 10 final 052803,doc
Version: 2-
Agreement Number: 00-EWID-
Page 1
Agreement Number: 00-EWID-
SERVICE ATTACHMENT -INDIRECT
Section 1 - Description
Carrier OCN:3874
Legal Entities: Edge Wireless, LLC
Section 2 - Usage Sensitive Charges
Charges for Reciprocal Transport and Termination of Local Traffic Interchanged Between The Parties:
NPAINXX: 208-705, 208-317, 208-709, and 208-313
The land-to-mobile originating rate is limited in application to Land-to-Mobile (Originating) calls that originate in
the Citizens Local Calling Area at the Point of Interconnection. The mobile-to-Iand terminating rate is limited in
application to Mobile-to-Land (Terminating) calls that terminate at a point within a Citizens Exchange Area in
Carrier s Service Area. All other traffic is subject to access rates.
2.2 Mobile-to-Land (Terminating) per minute
Land-to-Mobile (Customer charges Citizens) per minute
Non-MT A **
Indirect Traffic
0112
0112
Access rates apply
$0.0112
limited in application to calls originating on Carrier s system within the MTA and terminating at a
point in a Citizens exchange area within the MTA
applicable to mobile-to-Iand (terminating) calls terminating at a point in a
Citizens exchange area but which did not originate on Carrier s system
within the MTA.
The rates in this Section 2 constitute compensation to the Parties for both the transport and
termination of local telecommunications traffic, as defined in Section 51.701 of the FCC's Rules
interchanged between them,
Section 3 - Network Facilities
This Agreement relates to the exchange of Local Traffic between the respective networks of Carrier and
Citizens, which uses the tandem switching facilities of a third party for the point of interconnection and where
there is no direct connection between Carrier and Citizens, Unless a direct connection is separately negotiated
no network facilities between the Parties will be used,
It is anticipated that direct interconnection facilities, if established pursuant to Section 2,1 of
this Agreement, will be arranged for 2-way operations and will be used to transport both mobile-to-Iand and land-
to-mobile traffic, and the cost of that transport will be apportioned between Citizens and the Carrier based on
their relative use of the facility. During the first 12 months of this Agreement, Citizens and the Carrier will bill
each other based on the Traffic Factors in Section 4 of this Service Attachment. The parties agree to review
traffic volumes at a mutually agreeable time and adjust the billing percentages according to the then relative
usage,
Agreement Number: 00-EWID-
Section 4 - Traffic Factors
Mobile-to-Land Traffic Factor
Land-to-Mobile Traffic Factor
70%
30%
During the first 12 months of this Agreement, Citizens and the Carrier will bill each other based on the Traffic
Factors in this Section 4. The parties agree to review traffic volumes at a mutually agreeable time and adjust the
billing percentages according to the then relative usage.