20090619Comments.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 6864
REGEl D
2009 JUN , 9 Pl1~: 06
IDAHO rusue
UTILITIES COMMISSION
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
CTC TELECOM, INC. FOR DESIGNATION AS )
AN ELIGIBLE TELECOMMUNICATIONS )CARRER )
)
)
CASE NO. CTL-T-09-1
COMMENTS OF THE
COMMISSION STAFF
The Staff of the Idaho Public Utilties Commission, by and through its Attorney of
Record, Neil Price, Deputy Attorney General, in response to the Notice of Application and
Notice of Modified Procedure, issued on May 29,2009, Order No. 30824, submits the following
comments.
BACKGROUND
On April 23, 2009, CTC Telecom, Inc. ("CTC" or "Company") fied an Application,
pursuant to Section 214(e)(l)-(2) of the Telecommunications Act of 1934, Sections 54.201 of the
rules of the Federal Communications Commission ("FCC") and the rules and regulations of the
Idaho Public Utilties Commission, for designation as an Eligible Telecommunications Carer
("ETC") for the purpose of receiving support from the Universal Service Fund ("USF").
CTC is a Commercial Mobile Radio Services ("CMRS") carier marketing and sellng its
mobile wireless services under the brand name Snake River PCS. The Company is licensed to
STAFF COMMENTS 1 JUE 19, 2009
provide telecommunications services in Basic Trading Area ("BT A") 050 in Idaho that includes
the following Idaho counties: Adams, Boise, Gem, and northern Washington.
The Company's proposed ETC wireless service area in Idaho includes both non-rual
and rual wire centers served by four ILECs: Qwest Communications ("Qwest"), Cambridge
Telephone Company ("Cambridge"), Citizens Communications/Frontier Communications
("Citizens") and Midvale Telephone Company ("Midvale").
STAFF ANALYSIS
CTC is an Idaho corporation, and it is a wholly-owned subsidiar of Cambridge
Telephone Company. CTC was granted a Certificate of Public Convenience and Necessity on
August 19, 1998, to provide basic local exchange service to an area known as Hidden Springs in
Ada County, Idaho. See Order No. 27673. On June 8, 1999, this Certificate was amended to
expand CTC's potential service area to include US WEST Communications, Inc's southern
Idaho territory. See Order No. 28059.
Staff has reviewed CTC's Application and has conducted an analysis of the Company's
fulfillment of the federal Telecommunications Act of 1996 ("the Act") and of Commission Order
No. 29841. In addition, Staffhas analyzed the merits of awarding ETC designation separately
under the two wire center classifications of non-rural and rual wire center service areas.
Non-rural Wire Centers
CTC identifies the non-rual wire centers, Emmett and Idao City, in the Qwest service
territory. Application, Exhibit B 1.
The Act treats rual and non-rual service areas differently for the puroses of ETC
designation. When a carier meets the service requirements set forth in 47 U.S.C. § 214(e)(l)
and requests designation in a non-rual area served by an incumbent local exchange carrier
(ILEC), the statute provides that the Commission shall designate more than one common carer
as an ETC. 47 U.S.C. § 214(e)(2).
Designating more than one ETC in a non-rural area is consistent with past Commission
decisions in which the Commission granted ETC status to Clear Talk, a wireless company, in the
non-rual Qwest wire centers in eastern Idaho and the Magic Valley (Case No. GNR-T-03-8).
See Order No. 29261. The Commission granted ETC designation to Western Wireless in the
non-rual wire centers of Emmett, New Plymouth, and Weiser (Case No. WST-T-05-1). See
STAFF COMMENTS 2 JUE 19,2009
Order No. 29791. Inland Cellular was granted ETC status in the non-rual Verizon and Qwest
wire centers in northern Idaho (Case No. INC- T -06-2). See Order No. 30212. Edge Wireless
Company was granted ETC designation in the non-rual Qwest wire centers in southern Idaho
(Case No. EDG-T-07-1). See Order No. 30360. Finally, on August 28,2008, the Commission
granted ETC status to Syringa Wireless LLC (Case No. SRY-T-08-1). See Order No. 30629.
Staff believes CTC meets all the statutory ETC requirements of Commission Order
No. 29841 as it relates to non-rual wire centers. Designating CTC as an ETC in the non-rural
service areas is consistent with the "public interest, convenience, and necessity" pursuant to
47 U.S.C. § 214(e)(2). Staff also believes granting ETC designation in the non-rual areas is in
the public interest and wil benefit the recipients of the Idaho Telecommunications Service
Assistace Program ("ITSAP").
Based upon past Commission decisions, and consistent with the requirements of Section
214 of the Act, Staff recommends approval ofCTC's request for ETC designation in the non-
rual wire centers set forth in Exhibit B 1 of the Application.
Rural Wire Centers
CTC's Application, includes nine rual wire centers in central and southern Idaho. These
rual wire centers are: Cambridge, Council/Cuprum, Indian Valley and Lowman wire centers
served by Cambridge Telephone Company; Garden Valley, Horseshoe Bend, New Meadows and
Sweet served by Citizens Communications, and Midvale wire center served by Midvale
Telephone. Application, Exhibit B 1.
As noted above, the Act treats rual service areas differently for the puroses of ETC
designation. When a carier meets the statutory ETC requirements and requests designation in a
rual area served by an ILEC, the Act gives the State Commission more discretion, stating that
the State commission may grant ETC designation to the additional carier provided that ETC
designation of the additional carier is in the public interest. 47 U.S.C. § 214(e)(2).
Under the Act and Order No. 29841, greater emphasis is place on scrutinizing the public
interest issues for ETC Applications in rual service areas. Rural wire centers often have widely
disparate population densities, and therefore, higWy disparate cost characteristics. In the Matter
of the Federal-State Joint Board on Universal Services, CC Docket No. 96-45 (reI. March 17,
2005) 2005 WL 646635 at 21-22 (the "FCC Order"). As such, Staff believes the public interest
analysis plays a more importt role when reviewing ETC designation in rural service areas.
STAFF COMMENTS 3 JUE 19, 2009
Public Interest Analysis
Under Section 214 of the Act, the State commission must determine that an ETC
designation is consistent with the public interest, convenience and necessity. 47 U.S.C. §
214( e)(2). In accordance with the Act, and the ETC requirements of the FCC rules, the
Commission has stated:
(i)n adopting the FCC's proposed public interest analysis, this
Commission adopts an analytical framework for making a public interest
determination. This framework necessarily involves the consideration of
certin enumerated factors, such as the benefits to consumer choice, the
unique advantages and disadvantages of the applicant's service offering,
and, where applicable, consideration of creamskimming. However, the
Commission may consider other relevant public interest determinations in
its public interest determination." Order No. 29841 at 15-16.
This Commission has consistently applied the public interest analysis in previous decisions. The
Commission denied the ETC Applications of thee wireless cariers, IAT Communications, Inc.
dba NTCH-Idaho, Inc., NPCR, Inc dba Nextel Parners (Case No. GNR- T-03-8) and, most
recently, Inland Cellular Telephone Company (Case No. INC- T -06-2), because the applicants
failed to car out their burden of demonstrating that their Applications for areas served by rual
companies were in the public interest. See Order Nos. 29541 and 30212. These Applications
failed the public interest test by placing too much emphasis on competition and relying on
approved state and federal applications in very different service areas rather than explaining how
the paricular applicant's ETC designation would benefit all the customers in a service area. The
term service area means a geographic area established by a State commission for the purose of
determining universal service obligations and support mechanisms. In the case of a rual
telephone company, service area means such company's study area unless and until the FCC and
the State Commission, after taking into account recommendations of a Federal-State Joint Board
instituted under section 41 O( c), establish a different definition of service area for such company.
47 U.S.C. § 214(e)(5).
Applicants have the burden of proof to demonstrate that the public interest is served by
designating them as an ETC in these rual areas. Order No. 29541 at 6 (citing Virginia Cellular,
LLC Petition/or Designation as an ETC, 19 F.C.C.R. 1563 (2004)). CTC's Application makes
four primar public interest arguments.
STAFF COMMENTS 4 JUE 19, 2009
"
1. Cost-Benefit Analysis
CTC asserts its universal service offering not only increases competition in the rual
areas, but also provides greater consumer choice for the rual consumer. Application at 13.
CTC states the increased competitive choice and quality service will benefit the rual Idaho
consumers and wil also "speed the delivery of advanced wireless services to rual Idaho
citizens." ¡d. The Company fuher states that, "(w)ithout CTC's wireless service, many
consumers in areas surounding Indian Valley, Idaho would have to rely solely on traditional
wire line services." ¡d. CTC claims mobilty will offer "increased flexibility, public safety, and
service options.. .by offering the benefits of mobilty, CTC's wireless universal offering wil
provide unique and essential services to consumers in Lowman, Montour, Idaho City, Garden
Valley and Emmett, Idaho." Application at 14. The Application states that an additional benefit
wil be offered to low-income consumers who are eligible for federal Lifeline benefits. Id.
Finally, CTC claims it provides several advantages: Mobilty, access to E911, voicemail, three-
way callng, call waiting, call forwarding, expanded callng scopes and several callng plans. ¡d..
CTC concludes its Cost-Benefit Analysis by describing how the federal high cost support would
be used to improve its infrastructure in rual areas and how these improvements would positively
impact the residents, travelers, and recreators (sic) in remote areas. Application at 15.
Staff does not advocate one technology over another, but instead recognizes that each has
unique advantages and disadvantages depending upon the geography, demographics, and
technological needs of the community. CTC states its wireless service wil provide greater
benefits and high-quality service to its consumers, but does not provide any data or facts to
substatiate these claims. CTC's list of advantages is not necessarily unique to nor exclusively
associated with wireless technology and, as such, Staff is not convinced that a positive cost
benefit analysis exists for wireless service that cannot also be claimed by the ILECs. Staff
acknowledges that mobilty is unique to wireless service, but Staff also understads the unique
disadvantages and service quality challenges a mountainous terrain poses for wireless service
providers. Furher, the Company's presumptive disadvantage associated with a consumer having
to "rely solely on traditional wireline service," is not a compellng argument to satisfy the public
interest requirement.
2. Potential for Cream Skimming.
CTC states that it is not tageting low cost areas or avoiding high cost areas, but instead
wil serve all customers where it is able to provide wireless service to varied population
STAFF COMMENTS 5 JUE 19, 2009
densities. Application at 16. CTC is not seeking ETC designation in partial wire centers and is
proposing to serve some of the most sparsely populated and costliest to serve study areas in
Idaho. Application at 18. This statement is supported by a wire center population density chart.
Confidential, Exhibit C-2.
Staff notes that the list of wire centers in the Application includes the entire service area
of Cambridge. CTC's Application, however, includes parial service areas of Citizens and
Midvale. These two rual ILECs serve non-contiguous service areas in Idaho.
Staff agrees that Applications for ETC designation that include an entire service area
avoid the specter of cream skimming. The opposite is true when an Application seeks ETC
designation that does not include all the wire centers that make up a service area. Edge Wireless,
in its ETC designation Application, understood that the Commission would not grant ETC status
for parial service areas without first receiving FCC approval of a petition to redefine a service
area down to the wire center. For this reason, Edge Wireless chose to eliminate a wire center
that represented parial service areas. See Case No. EDG-T-07-1, Edge Wireless, LLC's
ERRTA to Application and Exhibits.
The parial service area for Citizens is unique and must be analyzed separately. In the
Rural Task Force (RTF) Order (FCC 01-157, released May 23,2001), all rural ILECs were
required to select one of three available disaggregation paths and to notify USAC of its
selections. The path selected by an ILEC affects the support provided to competitive cariers.
Citizens elected to disaggregate its service area at the exchange leveL. This decision changed the
high cost support from an averaged cost across all lines served by a carier in a service or
"study" area to average line cost at each wire center. For this reason, Staff makes an exception
to the parial service area test for the wire centers served by Citizens.
Staff believes that CTC parially meets the cream skimming test. Staff agrees that CTC
avoids the appearance of cream skimming in those areas where CTC proposes to serve an entire
study area, but not for those areas that represent a parial service area.
3. Impact on the Fund.
CTC asserts that receipt of high cost fuds wil have a nominal impact on the federal
USF fud if calculated using the FCC's curent "identical support" rule. CTC conducted a study
using customer zip codes from its billng system to identify the location of its customers relative
to the exchange area boundaries of the ILEC with whom CTC competes for wireless service
customers. CTC's calculation of total per-line support (using USAC data from September 2008)
STAFF COMMENTS 6 JUE 19,2009
that each competing ILEC curently receives, including high cost, local switching, interstate
common line, and long-term support when multiplied by the individual ILEC per-line support
amount with the number of CTC wireless consumers shows CTC would receive an estimated
$171,288.59 per year in USF support. Application at 17. Based upon CTC's calculations,
"(t)his represents less than 0.0041 percent of the high-cost portion of the federal USF, assuming
$4.2 bilion in high cost support disbursement in a single year. Accordingly, grant(ing) of CTC's
ETC request will have minimal impact on the USF." ¡d. CTC goes on to state, "(t)he benefits of
designating CTC as an ETC outweigh any potential har to the sustainabilty of the fud."
Application at 18.
As stated earlier, CTC Telecom markets and sells wireless service under the brand name
Snake River PCS. Application at 2. Staff notes that CTC Telecom is a Competitive Local
Exchange Carrier ("CLEC") and a subsidiar of Cambridge Telephone Company. Cambridge is
a Title 61 company and is price-regulated by the Idaho PUC. In addition to the federal high-cost
fuds it receives, Cambridge also receives approximately $167,000 anually from the Idaho USF
fud.
Staff notes that most of CTC' s wireless emergency operation features are identical to the
features stated in the Syringa Wireless ETC designation Applications (Case No. SYR-T-08-1).
Application at 8.
Syringa Wireless is owned by a consortium (Member Parners) of the following ILECs:
Albion Telephone Company, Project Mutual, Direct Communications, Filer Mutual Telephone
Co., and Silver Star. See Syrnga Wireless website, http://ww.syringawireless.com/. Albion
Telephone Company, Direct Communications, and Silver Sta are price-regulated Title 61
companies. Project Mutual and Filer Mutual Telephone Co. are Cooperative
Telecommunications Companies that are not regulated by the Commission. All five members of
the Syringa Wireless Board of Directors are employees of the Member Parners. ¡d. Thee of
the ILECs, Albion Telephone Company, Direct Communications, and Silver Star/Teton also
receive a combined Idaho USF funding of over $900,000 anually or 47% of the total Idaho USF
fud disbursement. With the inclusion of CTC, the Idaho USF fuds provide to the four
affiliated ILECs totals over $1,070,000 anually or more than 50% of the total Idaho USF fud
disbursement. These companies also receive federal USF money.
STAFF COMMENTS 7 JUE 19, 2009
CTC's assertion of minimal impact to the federal USF fud may be correct, but parly
because of recent action taken by the FCC. This topic is examined in greater detail in the High-
Cost Federal Funding discussion.
4. State and Federal Precedent.
CTC notes that designation of CTC wireless services as an ETC is consistent with ETC
decisions across the country, demonstrated by numerous cases at the state and federal level,
including this Commission's recent designations of Edge Wireless, LLC and Syringa Wireless
LLC as Idaho's first wireless rual ETCs. Application at 18.
As noted in previous decisions, the Commission does not rely upon past decisions in
determining whether a current Application should be approved or denied. Each Application
must stand on its own merit in determining if it meets the state and federal ETC designation
requirements as outlined in Commission Order No. 29841. The Commission stated in Case
No. INC-T-06-2, "(it canot be presumed that benefits associated with different companies in
different states are applicable to the Company or the customers in its requested service area."
Order No. 30212 at 6.
Public Interest Summary
In evaluating the public interest portion of an ETC Application, the Commission weighs
whether the potential benefits of ETC designation outweigh the potential hars. One
consideration is whether the Applicant is committed to providing universal service throughout
the rural areas or, if not, whether the potential for cream skimming exists. Staff believes the
Company avoids the problem of cream skimming where the Application includes all wire centers
in a designated service area. Staff notes the CTC Application includes a detailed network plan
(Application, Confidential Exhibit C) for a nyu-year period, with wire center specific plans to
enhance the network. This provides support for the Applicant's claim that it will continue to use
high cost fuds to upgrade the network. In sum, the Application presents one unpersuasive
argument (Cost-Benefit), one parially compellng (Potential for Cream Skimming) and two
arguments (Impact on the Fund and State and Federal Precedent) as supporting the public
interest analysis. However, if the wire centers that represent parial service areas are removed,
the appearance of cream skimming is eliminated. Staff believes CTC's Application in total
presents a somewhat acceptable argument to support the Company's public interest position.
STAFF COMMENTS 8 JUNE 19, 2009
Network improvement Plan
The two-year network improvement plan must describe with specificity proposed
improvements or upgrades to the applicant's network on a wire center-by-wire center basis
throughout its proposed designated service area. Order No. 29841 at 18.
As mentioned earlier, CTC's Application provides detailed information outlining its
network improvement plan for the years 2009, 2010 and 2011. Application, Confidential at 15
and Confidential Exhibit C. The plan includes details such as affected wire centers, expenditures
and a narrative description of the planed improvements for each year.
Staff believes CTC provides a reasonable improvement plan, and if CTC is granted ETC
designation, the anual submission of the Two-Year Network Improvement Plan and Progress
Report will hold the Company accountable for making a reasonable effort to implement the
network improvement plan. See Appendix Reporting Requirement, Order No. 29841.
Abilty to Remain Functional in Emergencies
The Commission explains in Order No. 29841 that it "understands different cariers in
different industries and geographic areas will have different technological challenges and
opportunities to meet these fuctional requirements, especially in an emergency." Order No.
29841 at 10. To demonstrate the abilty to remain functional in emergencies, the ETC applicant
must show that it has a "reasonable amount of back-up power to ensure fuctionality without an
external power source, is able to re-route traffc around damaged facilties, and is capable of
managing different traffc spikes resulting from emergency situations."
In the Application, CTC describes the components that make up its fault-tolerant
network. Application at 7-9. These components include a Mobile Switching Center located in
Roosevelt, Uta with 12 hours of backup battery and a natual gas generator plumbed to public
utilty supply; Self-Healing Alternative Route Protection Service for Fiber Facilties
interconnection with automated 7X24 remote monitoring; Cell sites with 8 hours battery backup
and standby generator to accommodate extended power outages; Network Operating Center in
Roosevelt, Utah, and CTC's 7X24 on-call staff who wil be called or contacted via text message
when the monitoring system detects a problem. Application at 8-9.
Staff believes the fault-tolerant network, as described in the Application, provides
adequate support to demonstrate the Company's abilty to remain functional in an emergency.
STAFF COMMENTS 9 JUE 19, 2009
Other ETC Designation Requirements
Additional requirements for ETC designation, not previously discussed, are detailed in
the Appendix 1 of Order No. 29841. These are discussed below.
1. Common Carier Status. CTC Telecom is a Commercial Mobile Radio Services
(CMRS) carier providing "mobile service" as defined in 47 U.S.C. § 153(27). Application at 2.
2. Provide the Universal Services. CTC offers the federally designated services listed at
47 U.S.C. § 54.1O(a). ¡d. at 5.
3. Advertising. CTC plans to advertise the availability of each of the supported services
as detailed in the Application, throughout its licensed service area. ¡d. at 11.
4. The Commitment and Ability to Provide Supported Services. CTC is committed to
answering all reasonable requests for service within its proposed ETC service area. ¡d. at 19.
5. A Commitment to Consumer Protection and Service. CTC wil comply with all
applicable protection stadards established by the CTIA Consumer Code. ¡d. at 12.
6. Description of the local Usage Plan. CTC submits its rate plan brochures as Exhibit
E. ¡d. at 6.
7. Tribal Notification. CTC is not seeking ETC designation for any portion of tribal
lands. ¡d. at 12.
Staff believes CTC meets the above seven ETC designation requirements.
HIGH-COST FEDERAL FUNDING
The original goal of the federal Universal Service Fund, under the Telecommunications
Act of 1934, was to provide at least one access line for basic telephone service to every
household in the U.S., and at a reasonable, subsidized cost. Staff does not believe the USF was
ever intended to provide equal fuding for both the ILEC and an ILEC affliate operating in the
same service area as would be the case with Cambridge Telephone Company, CTC Telecom,
LLC and its wireless brand name Snake River PCS.
Staff is aware of the high-cost federal fuding issues for rual areas. Staff recognizes and
is concerned about the growth of high-cost fuds, paricularly as it relates to Competitive ETCs
("CETC"). The escalating high-cost fud is an ongoing concern that is being addressed at the
federal leveL. On April 29, 2008, the FCC adopted the Federal-State Joint Board on Universal
Service's recommendation to impose an interim emergency cap on the amount of high-cost
support that CETCs may receive. See FCC 08-122. Specifically, effective May 1,2008, total
STAFF COMMENTS 10 JUE 19,2009
anual CETC support for each state wil be capped at the level of support that CETCs in that
state were eligible to receive during March 2008 on an anualized basis. All newly designated
and existing CETCs in Idaho wil share the high-cost USF support in the amount that was
distributed to Idaho CETCs in March 2008. The only exception to this interim cap is if a CETC:
(l) Files cost data demonstrating that its costs meet the support threshold in the same maner as
the ILEC; or (2) Serves tribal lands or Alaska Native regions. The interim cap will remain in
place until the FCC adopts comprehensive reform measures. ¡d.
The Commission is not in a position to alter public policy regarding the federal USF
draw, but must follow rules and regulation even if troubled by the outcome. In the meantime,
Staff does not feel it should recommend denial of an ETC Application that reasonably meets all
of the statutory requirements for an ETC designation. Denial of an ETC Application also denies
the rual consumers the benefit of Idaho Telephone Service Assistance Program (ITSAP), federal
Lifeline and Linkup support as well as other potential technological and safety benefits that may
be offered by the CETC. Staff wishes to note, however, that these benefits are available to the
consumers through the ILECs.
SUMMARY
Of the requirements for ETC designation, it is Staffs opinion that the public interest
analysis, the two-year network improvement plan, and the abilty to remain fuctional in an
emergency are essential to the Idaho consumers in the rual wire centers. Consequently, Staff
carefully considers these categories to determine if the Applicant has provided compellng
evidence that it meets these requirements.
Based on the information presented in the Application, Staff sees no indication that CTC
would not provide comparable service to that curently provided by the ILECs. Staff believes
the Company exhibits an understanding of the federal and state customer service requirements
for ETC designation. Staff believes CTC meets all federal and state requirements to be granted
ETC designation in the two non-rual wire centers served by Qwest. Staff fuher believes CTC
meets all federal and state ETC requirements as to the eight rural wire centers served by
Cambridge Telephone Company and Citizens Communications. CTC's Application includes the
entire Cambridge service area and the less populated wire centers in the Citizens service area.
Staff does not believe CTC meets the ETC requirements for the one rural wire center served by
STAFF COMMENTS 11 JUE 19, 2009
Midvale Telephone Company as this wire center represents the most densely populated wire
center in the Midvale designated service area and, therefore, the least costly wire center to serve.
STAFF RECOMMENDATION
Staff is satisfied that the Application meets the minimal requirements of an ETC and
recommends that the Commission approve the Application as to the non-rual wire centers of
Emmett and Idaho City in the Qwest service area. Staff recommends approval of the Application
in the four rural wire centers that make up the entire designated service area served by
Cambridge Telephone Company. Staff also recommends Commission approval of the four rual
wire centers, Garden Valley, Horseshoe Bend, New Meadows and Sweet, in the Citizens
Communications service area. Finally, Staff recommends that the Commission deny the
Application for the one rual wire center, Midvale, in the Midvale Telecom service area.
Respectfully submitted this h~ay of June 2009.
~.~price
Deputy Attorney General
Techncal Staff: Grace Seaman
i:umisc:commentsctlt09.l npgs comments
STAFF COMMENTS 12 JUE 19, 2009
CERTIFICATE OF SERVICE
..
I HEREBY CERTIFY THAT I HAVE THIS 19TH DAY OF JUE 2009,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. CTL-T-09-01, BY MAILING A COpy THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
MOLLY O'LEARY
RICHARDSON & O'LEARY
PO BOX 7218
BOISE ID 83707
E-MAIL: molly(frichardsonandolear.com
SECRETARY
~.~
CERTIFICATE OF SERVICE