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Home My WebLink About20070323Reply comments.pdfRE' ::':: , inir 1':~"i) :SlLU'~ 'IL". IDJ\i'iC: iJ ".:, :.L!C RJLf;I1IARJ11SQNr&0JJJ:.RMlY , '",,,.-. ""' " '881U !!..Iilt:.);.. ").:,,,.-...,' ATTORNEYS AT tAW Molly O'Leary Tel: 208-938-7900 fa,.: 208-938-7904 mollyfi!'richa rdsonandolca ry.com 1'.0. Box 7218 Boise !D. 83707 - 515 N. 27th Sf. Boise, 10.83702 22 March 2007 Ms. Jean Jewell Commission Secretary Idaho Public Utilities Commission POBox 83720 Boise ID 83720-0074 Hand Delivered RE:EDG- T -07 -, Edge Wireless, LLC Application for ETC Designation Dear Ms. Jewell: I am enclosing an original and seven (7) copies of Edge Wireless, LLC' REPLY COMMENTS. Also enclosed is a copy to be date stamped and returned for our files. , PLLC Molly O'Leary (ISB # 4996) Richardson & O'Leary, PoLLCo O. Box 7218 Boise, ID 83707 Tel: 208-938-7900 Fax: 208-938-7904 molly~richardsonandoleary .com ::C, ZQi.\l r" 1", I. C, r! I II' ,JOL-. 1\j/i~) \~("/"\\\ II,jinlu';:)I~' \ ,- ' t.- ' ,.,., IJ ~ " Mark P. Trinchero , OSB #88322 1300 SoW. 5th Avenue, Suite 2300 Portland, Oregon 9720 I Tel: 503- 778-5318 Fax: 503-778-5299 marktrinchero~dwt.com BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF EDGE WIRELESS, LLC FOR DESIGNATION AS AN ELIGIBLE TELECOMMUNICATIONS CARRIER PURSUANT TO THE TELECOMMUNICATIONS ACT OF 1996 (RURAL AND NON-RURAL AREAS) Case No. EDG-O7- REPLY COMMENTS OF EDGE WIRELESS, LLC Applicant Edge Wireless, LLC ("Edge ), by and through its attorneys of record Davis Wright Tremaine LLP and Richardson & O'Leary, P.LLC., files these Reply Comments in response to the Protest and Comments filed by the Idaho Telephone Association ("ITA") on March 13 , 2007 ("ITA Comments ) and to the Comments filed by Commission Staff ("Staff' on March 13 2007 ("Staffs Comments ). For the reasons set forth below, Edge respectfully requests that the Commission reject ITA's request to dismiss Edge s Application and to deny ITA's eleventh hour request for a hearing. Edge also respectfully requests that the Commission consider additional information, attached hereto, in response to Staff s assertion that it had EDGE WIRELESS REPLY COMMENTS Page 1 of7 PDX 1624045v3 0054189-000049 insufficient information to verify Edge s claims that eligible telecommunications carrier ("ETC" designation increased consumer choice and service quality in its Oregon service area. REPLY TO ITA COMMENTS ITA's arguments in support of its request to dismiss Edge s Application are based on a misreading of the application and a misstatement of the relevant lawo First, ITA quotes a single sentence from the Application to imply that Edge has somehow ignored the "public interest" standard with respect to ETC designation in the territories of rural incumbent local exchange carriers ("ILECs ). This is a gross mischaracterization of the Application, an entire section of which is devoted to establishing that Edge satisfies the public interest test with respect to its request for ETC designation in rural ILEC study areas. 1 In fact, Staff's Comments include a detailed four page discussion of its review of Edge s public interest showing? ITA's argument is disingenuous and should be rejected. IT A also appears to argue that the Application states that the Commission must grant Edge ETC status throughout Edge s service areao This is also a gross mischaracterization of the Application, which specifically seeks ETC designation for an area that is smaller than Edge licensed service territoryo For example, Edge has specifically excluded from its proposed ETC service area five rural ILEC wire centers that fall within Edge s licensed service area.3 In addition, Edge excluded the Boise River and Three Creek wire centers from its request because its license area covers only a portion of each of those two wire centerso4 The Application also expressly states that: Section 214(e)(2) of the Act provides that ETC designations shall be made for a service area" designated by the state commission. Section 214(e)(5) of the Act See g., Application, Section V. "PUBLIC INTEREST FACTORS" See Staff Comments, pp. 4-3 Application, footnote 9.4 Application, Exhibit B. EDGE WIRELESS REPLY COMMENTS Page 2 of7 PDX 1624045v3 0054189-000049 provides that service area" shall be a geographic area established by the state commission. In areas served by a rural telephone company, the FCC's rules generally define a competitive ETC's "service area" to mean the LEC study areao Once again, ITA's selective reading ofthe Application is misleading and disingenuous, at best. IT A also claims that it "can find nothing" in the Application that "even alleges" that Edge will offer service to customers throughout the relevant rural ILEC study areas.6 Once again IT A's claim suggests it did not read the entire Application, which includes a section devoted entirely to discussion of Edge s commitment to provide service to requesting customers.? This section of the Application provides the Commission with the requisite commitment from Edge to provide service upon reasonable request, including the six-point check list for responding to requests from residents within its proposed ETC area, but outside its existing network coverage. This is consistent with the Commission s requirements, which are, in turn, based on the Federal Communications Commission s ("FCC") rules.9 In addition, Edge submitted a detailed two-year network improvement plan the "thoroughness and attention to details" of which "indicates to Staffthat Edge has made an effort to understand the rural wire centers ' deficiencies and has determined how they plan to improve these wire centers.10 Edge s Application is, thus, replete with information sufficient for the Commission to make the requisite determinations, and ITA' bald assertions to the contrary mischaracterize the Application and should be rejected. 5 Application, p. 3.6 ITA Comments, p. 3. See Application, Section V. "Commitment to Serve Requesting Customers Id. See In the Matter of the Application of WWC Holding Co., Inc. dba CellularOne Seeking Designation as an Eligible Telecommunications Carrier That May Receive Federal Universal Service Support Order No. 29841 Appendix p. 2 (IPUC Case No. WST-05-, served August 4, 2005)(hereinafter IPUC ETC Requirements Order ); see also, In the matter of the Federal-State Joint Board on Universal Service CC Docket No. 96-, 20 R. 637; see also 47 C.R. 9 54.202(a).10 Staff Comments, p. 8. EDGE WIRELESS REPLY COMMENTS Page 3 of 7 PDX 1624045v3 0054189-000049 Finally, ITA argues that modified procedure is inappropriate because ITA has not had an opportunity to review Edge s confidential two-year network improvement plan. ITA also questions whether Edge s confidentiality claim is warrantedo The Commission should reject IT A's eleventh hour request for a hearingo The Application was filed on January 22, 2007 and this Commission issued its notice that modified procedure would be used on February 14 2007011 Yet ITA has never requested of Edge a copy of any of the confidential exhibits to the Application. Nor does Edge have reason to believe that ITA has made a request of the Commission for a copy of any of the confidential exhibits to the Application. This Commission has procedures for providing limited access to confidential information to selected individuals in pending dockets, including Protective Orders.12 In addition, telecommunications carriers frequently enter into non-disclosure agreements in order to share confidential information (e. cost and network data relevant to interconnection negotiations)o ITA's counsel is undoubtedly aware of these mechanisms and the fact that he could have gained protected access to the confidential exhibits upon request. IT A made no such request, opting instead to wait until the final day of the comment period to raise this issue. The Commission should not condone such obvious delay tactics. Furthermore, ITA's suggestion that Edge s claim of confidentiality is somehow unwarranted is specious. A number of ITA's members are part of a consortium that has formed a company called Syringa Wireless, LLC that provides wireless service in Idaho in direct competition with Edge. Syringa s web site describes Syringa as follows: Syringa Wireless is a consortium of long standing, local Idaho telecommunication companies who banded together to form a new cellular company called Syringa Wireless, LLC. The member partners include Albion Telecommunication Company (A TC), Direct Communications of Rockland, Filer Mutual Telephone 11 See Order No. 30240.12 Rule 67.04 of the Rules of Procedure of the Idaho Public Utilities Commission. IDAP A 31.01.01.067.04. EDGE WIRELESS REPLY COMMENTS Page 4 of 7 PDX 1624045v3 0054189-000049 Silver Star Communications based in Freedom, Wyoming and serving the Driggs Victor Idaho areas, and Project Mutual Telephone (PMT) of Rupert. Silver Star Communications also operates a wireless carrier in eastern Idaho called Silver Star PCS.14 These companies are undoubtedly well aware that wireless companies consider network plans that describe locations for new cell sites as highly sensitive proprietary information and take every precaution to maintain the confidentiality of such information. Nor is it uncommon for competitive wireless carriers to "swoop in" on a potential site if it finds out that another carrier is in negotiations with a land-owner. Thus, IT A's argument is insincere and hypocritical. Edge clearly expected that ITA members would be interested in its application and obviously needs to ensure that access to this information is limited, especially in light of the fact that ITA members are also part of a competing wireless carrier. The Commission should reject ITA's last minute request for a hearing. It is "sandbagging" plain and simple and should not be tolerated. REPLY TO STAFF COMMENTS Edge commends Staffs thorough review of Edge s Application and welcomes Staff recommendation that Edge s Application be approved. This Reply to Staffs Comments is limited to the following Staff observation: Staff does not have sufficient information to verify the Company s anecdotal claims that ETC designation increased consumer choice and service quality in its Oregon service area. In addition, the Application provides no documentation to support the Company s claim that its network improvement was specifically a result of ETC designation in Oregon. Edge is proud of its accomplishments in improving network coverage and service quality in its Oregon service area and, therefore, wishes to respond to Staff s desire for more information. Attached hereto is a copy of Oregon Public Utility Commission s ("OPUC") latest annual recertification decision, Order No. 06-537, in OPUC Docket UM 1217, entered September 19 13 See http://syringawireless.com/abouthtm. 14 See http://www.silverstar.com/co - abouthtm. EDGE WIRELESS REPL Y COMMENTS Page 5 of 7 PDX 1624045v3 0054189-000049 2006. The Order describes in detail the findings of OPUC Staff as a result of its comprehensive review of competitive wireless ETC ("CETC") network improvement plans, including the network improvement plan submitted by Edge in Oregon. 15 The Order finds that Edge had in fact used its 2005 high cost funds to further the goals of universal service in Oregono 16 The Order also states: Edge Wireless had submitted a 5-year plan as part of its application for designation last yearo Edge did a superb job of retaining much of that plan and carrying through elements of it for implementation in 2006 and 2007, as their recertification for last year required a plan for only 2005 support spending. While some projects that were not completed from their 2005 plan were carried over into their 2006 plans, much of the 2006 and 2007 plans were new this year. Clearly, ETC designation in Oregon has allowed Edge to invest in infrastructure that has promoted the goals of universal service. Granting Edge ETC designation in Idaho will help bring similar benefits to the consumers in this State. 15 See OPUC Order No. 06-537 Appendix A, pp. 4- 16 Id.App. A, p. 5. EDGE WIRELESS REPLY COMMENTS Page 6 of? PDX 1624045v3 0054189-000049 CONCLUSION For the foregoing reasons, Edge respectfully request that the Commission reject ITA' request to dismiss the Application, reject IT A's request for a hearing, and adopt Staffs recommendation to grant Edge s Application for designation as an ETC in Idahoo /)):, Dated this:2Z day of March, 20070 Respectfully submitted, DA VIS WRIGHT TREMAINE, LLP By: jJ~ Mark p,/rrinchero, OSB #88322 EDGE WIRELESS REPL Y COMMENTS POX 1624045v3 0054189-000049 RICHARDSON & O'LEARY, PLLC Page 7 of 7 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 22nd day of March, 2007 a true and correct copy of the within and foregoing REPLY COMMENTS OF EDGE WIRELESS, LLC was filed with the Idaho Public Utilities Commission and served on the parties as indicated below: Ms. Jean Jewell Commission Secretary Idaho Public Utilities Commission POBox 83720 Boise ID 83720-0074 X- Hand Delivery u.So Mail, postage pre-paid Facsimile Electronic Mail Cece Gassner Deputy Attorney General Idaho Public Utilities Commission POBox 83720 Boise ID 83720-0074 Cece. Gassner~puc.idaho. gov - Hand Delivery - U.S. Mail, postage pre-paid Facsimile Electronic Mail Dean J. Miller McDEVITT & MILLER LLP O. Box 2564 Boise, Idaho 83701 Fax: 208.336.6912 Email: ioe~mcdevitt-miller.com - Hand Delivery S. Mail, postage pre-paid Facsimile Electronic Mail Nathan Glazier Regional Manager, State Affairs Alltel Communications, Inc 4805 Thistle Landing Dr. Phoenix, AZ 85044 Fax: 480.403.7231 Email: Nathan. glazier~alltel.com ~ Hand Delivery S. Mail, postage pre-paid Facsimile Electronic Mail Conley E. Ward Michael C. Creamer GIVENS PURSLEY LLP O. Box 2720 Boise, ID 83701-2720 Fax: 2080388.1201 Email: cew~givenspursley.com Email: mcc~givenspursley.com - Hand Delivery X-U.S. Mail, postage pre-paid Facsimile Electronic Mail CERTIFICATE OF SERVICE - I Molly Steckel Executive Director Idaho Telephone Association O. Box 1638 Boise, Idaho 83701- 1638 Fax: 208.229.0482 Email: mollysteckel~msn.com - Hand Delivery x..u.So Mail, postage pre-paid Facsimile Electronic Mail CERTIFICATE OF SERVICE - 2 Edge Reply Comments Attachment Page 1 of1S ORDER NO. 06-537 ENTERED 09/19/06 BEFORE THE PUBLIC UTILITY COMMISSION OF OREGON UM 1217 In the Matter of Annual certification for continued eligibility to receive federal universal service fund high cost support pursuant to 47 CFR ~54.314; and annual certification of non-rural ILEC basic service rates pursuant to 47 CFR ~54.316. ELIGIBLE TELECOMMUNICATIONS CARRIERS ORDER DISPOSITION: ELIGIBLE TELECOMMUNICATIONS CARRIERS CERTIFIED TO RECEIVE FEDERAL UNNERSAL SERVICE IllGH COST FUND SUPPORT; BASIC SERVICE RATES CHARGED BY NON- RURAL LOCAL EXCHANGE CARRIERS IN RURAL AREAS CERTIFIED TO BE COMPARABLE TO A NATIONAL URBAN BENCHMARK.; W ANERS GRANTED; AND ANNUAL RECERTIFICATION FILINGS ACCEPTED ELIGIBLE TELECOMMUNICATIONS CARRIERS Section 214 (e)(2) of the Communications Act of 1934, as amended by the Telecommunications Act of 1996 (the Act), provides that a state commission shall designate those common carriers eligible to receive universal service support (USF) in accordance with Section 254 of the Act. Section 254 (e) of the Act provides, in part as follows: (e) Universal Service Support.After the date on which Commission regulations implementing this section take effect, only an eligible telecommunications carrier designated under section 214(e) shall be eligible to receive specific Federal universal service support. The Public Utility Commission of Oregon (Commission) fITst exercised this authority in December 2, 1997, when it designated 34 local exchange carriers Edge Reply Comments Attachment Page 2 of 18 ORDER NOo 06-537 (ILECs) as eligible for federal USF supporto See Order Noo 97-481. On June 24, 2004 the Commission designated two Commercial Mobile Radio Service (CMRS) carriers RCC Minnesota, Inc., and United States Cellular Corporation (US Cellular), as authorized to receive federal USF supporto See Orders No. 04-355 and 04-3560 On August 29 2005, the Commission designated a third CMRS carrier, Edge Wireless, LLC as a carrier authorized to receive federal USF support. See Order No. 05-965. The Commission also designated two other carriers, VCl Company and Wantel, as eligible to receive federal USF support, but only in non-ruralll..,EC areaso See Order No. 03-749 and Order Noo 05-856. Pursuant to 47 CFR ~54.314, a state that desires eligible telecommunications carriers within its jurisdiction to receive federal universal service support in rural areas must file an annual Certification with the USF Administrator and the Federal Communications Commission (FCC) "stating that all federal high-cost support provided to such carriers within the state will be used only for the provision maintenance, and upgrading of facilities and services for which the support is intendedo 47 CFR ~54.314, subsection (c), sets the requirements for the format of the Certification. In compliap.ce with those federal requirements, the Commission certified the eligibility of Oregon s designated telecommunications carriers at public meetings in 2001 (OrderNoo 01-819),2002 (Order No. 02-605), 2003 (Order No. 03-551),2004 (Order No. 04-532), and 2005 (Order Noo 05-1049). This Order addresses eligibility certification for 2006. In prior certifications, the Commission relied on affidavits provided by corporate officers of the eligible telecommunications carriers (ETCs) that attested to their use of federal USF high cost funds. While such affidavits were required for recertification this year as well, the Commission recently adopted additional requirements in Order Noo 06-292. This is the first annual certification that employs the new requirements. All ETCs submitted the required filings, including affidavits attesting to the use of support funds for the intended purposes. Based on this information, andbecause the continued receipt of federal USF high cost support is vital to maintaining reasonable basic service rates in these rural service areas, Staff recommends the Commission certify that the ETCs are authorized to receive federal USF high cost support pursuant to 47 Co R. ~54.314. We certify RCC Minnesota, Inc. with the understanding that the company will cooperate with Staff in developing a revised networking improvement plan consistent with the goals of the USF program. Staff also requested that the trouble report requirement of Order Noo 06-292 be waived this year for S1. Paul Cooperative Telephone Company, Pine Telephone Company, and Roome Telecommunications. Staff explains that these companies were not able to provide such information for 2005 because they had not been collecting such data during that period. Staff adds that these carriers have agreed to start tracking the data that will enable them to file this information next year. Staff also Edge Reply Comments Attachment Page 3 of 18 - - ORDER NOo 06-537 recommends that the Commission accept the 2006 annual recertification filings submitted by all ETCs, rural and non-rural, in compliance with Order No. 06-292. The Commission adopted Staff's recommendations at its Public Meeting on September 19,2006. The Staff Report, which includes a list of the 35 carriers certified to be eligible to receive federal high cost support pursuant to 47 C.R. 9 54.314is attached to this Order as Appendix A and incorporated by reference. RURAL TO URBAN BASIC SERVICE RATE COMPARABILITY 47 CFR ~54.316 requires each state to annually review the comparability of residential rates in rural areas served by non-rural incumbent local exchange carners (ILECs) to urban rates nationwide, and to certify to the USF Administrator and the FCC as to whether the rates are reasonably comparable. This detennination is made by comparing basic service rates charged by non-rural ILECs in their rural service areas to a national average benchmark for urban basic service rates detennined by the FCc. In compliance with this federal requirement, Staff conducted an analysis of the basic service rates charged by Oregon s non-rural ILECs, Qwest and Verizon, in their rural service territories. Staffs analysis indicates that in many rural exchanges Qwest and Verizon charge basic service rates below the current national average urban benchmark of $24.74 as calculated by the FCCo In all cases, basic service rates charged by Qwest and Verizon in rural exchanges are significantly below the FCC's current "safeharbor" rate of $34.58 per line per montho We addressed the rural to urban basic service rate comparability matter at our Public Meeting on September 19 2006, and adopted Staffs recommendation to certify that the basic service rates charged by Oregon s non-rural ILECs in their rural service areas are comparable to basic service rates charged in urban areaso A summary of basic service rates charged by Qwest and Verizon in each rural Oregon county where they provide service is set forth in Exhibit C to Appendix A. Detailed information regarding the analysis of basic service rates, as discussed in Staff's Report, appears in Exhibits D and Eo CONCLUSIONS The telecommunications carners, listed in Exhibit A of the Staff Report are qualified for annual certification as telecommunications carners eligible to receive federal universal service high cost support. The basic service rates charged by non-rural ILECs in their rural service areas are certified to be comparable to urban rates. The waivers of Order No. 06-292 trouble report requirements are granted for this year, and the 2006 annual recertification filings of all ETCs are accepted. IT IS ORDERED that: Edge Reply Comments Attachment Page 4 of 18 ORDER NOo 06-537 ORDER The rural telecommunications carriers listed in Exhibit A to the Staff Report are certified as telecommunications carriers eligible to receive federal universal service support pursuant to 47 CFR g54.314; We certify that the basic service rates charged by non-rural ILECs in their rural service areas, as summarized in Exhibit C of the Staff Report, are reasonably comparable to urban basic service rates nationWide pursuant to 47 CFR g54.316; and We grant waivers for good cause of the trouble report requirement of Order Noo 06-292 for this year for Sto Paul Cooperative, Pine Telephone, and Roome Telecommunications; and accept the 2006 annual recertification filings of all eligible telecommunications carrIers. Made, entered, and effective SEP 1 '2006 A party may request rehearing or reconsideration of this order pursuant to ORS 756.5610 A requestfor rehe~ing or reconsideration must be filed with the Commission within 60 days of the date of service of this ordero The request must comply with the requirements in OAR 860-014-00950 Acopy of any such request must also be served on each party to the proceeding as provided by OAR 860-013-0070(2). A party may appeal this order by filing a petition for review with the Court of Appeals in.compliance with ORS 183.480-183.4840 REGULAR DATE: TO: FROM: THROUGH: SUBJECT: 0__, moo,Edge Reply Comments Attachment Page 5 of 18 ORDER NO. 06-537 ITEM NO. PUBLIC UTILITY COMMISSION OF OREGON STAFF REPORT PUBLIC MEETING DATE: September 19, 2005 CONSENT EFFECTIVE DATE N/A September 12, 2006 Public Utility Commission KI1 ay anno~Lv. Lee Sparling, Phil Nyegaa (i a d Dave Booth OREGON PUBLIC UTILITY COMMISSION STAFF: (DocketNo. UM 1217) Annual certification for continued eligibility to receive federal universal service fund high cost support pursuant to 47 C.R. 954.314; annual certification of non-rurallLEC basic service rates pursuant to 47 C.R. 9 54.316; and review of 2006 annual recertification reports. STAFF RECOMMENDATION: Staff recommends that the Commission: 1. Certify that the rural incumbent local exchange carriers (ruraIILECs) and the competitive eligible telecommunications carriers (CETCs), listed in Exhibit A to this report, are authorized to receive federal Universal Service Fund (USF) high cost support pursuant to 47 Co R. 9 54.314; 2. Certify that the basic service rates charged by non-rurallLECs in their rural service areas, as summarized in Exhibit C to this report, are reasonably comparable to urban basic service rates nationwide pursuant to 47 C.R. 9 54.316; and 3. Grant waivers for good cause of the trouble report requirement of Order No. 06-292 for this year for S1. Paul Cooperative Telephone Company, Pine Telephone, and Roome Telecommunications; and accept the 2006 annual recertification filings of all ETCs, with the understanding that RCC has committed to work with Staff to file a revised network improvement plan before the end of this year. APPENDIX PAGE --'- OF l.:!...- Edge Reply CommentS Attachment Page 6 of18 ORDER NO. 06-537 Docket UM 1217 September 12, 2006 Page 2 DISCUSSION: A. Certification of RurailLECs and CETCs Section 214(e)(2) of the Telecommunications Act of 1996 (Act) authorizes state public utility commissions to designate telecommunications carriers eligible to receive federal USF high cost support. The Commission first exercised this authority in December 1997 when it designated Oregon s ILECs as eligible telecommunications carriers (ETCs).1 In June of 2004 the Commission designated two wireless carriers operating in the service areas of rurallLECs as CETCs authorized to receive federal USF high cost support.2 In August of 2005 the Commission designated a third wireless carrier operating in the service areas of rurallLECs as a CETC.3 The Commission has also designated two non-ILEC wireline carriers as CETCs in the service areas of Owest Corporation (Owest), a non-rural carrier. Section 54.314 of the FCC rules requires state public utility commissions to annually certify that rurallLECs, and CETCs operating in the service areas of rurallLECs, are using their federal USF support in compliance with Section 254( e) of the Act. That section of the Act requires that federal USF high cost support be used only for the provision, maintenance and upgrading of facilities and services for which the support is intended. The Commission must provide this annual certification to the Federal Communications Commission (FCC) and the Universal Service Administrative Company (USAC) by October 1 st of eachyear in order for the rural ETCs to continue receiving high cost support. Since 2001, this annual certification has been achieved by requiring the corporate officers of rurallLECs and CETCs to provide a sworn affidavit attestingto their use of federal USF high cost funds.See Sample affidavit included asExhibit B. While such affidavits are required for recertffication this year as well, See Order Noo 97-481, Docket UM 873. See Order No. 04-355 in Docket UM 1083 designating RCC Minnesota. Inc., and Order No. 04-356 in Docket UM 1084 designating US Cellular Corporation. See Order No. 05-965 in Docket UM 1177 designating Edge Wireless, LLC. See Order No. 03-749 in Docket UM 1107 designating Stan Efferding, dba VCI Company, and Order No. 05-856 in Docket UM 1202 designating Wantellnc., dba ComspanUSA. See PUG Orders 01-819 02-605 03-551 04-532, and 05-1049 in Docket UM 873. APPENDIX p AGE OF LL. Edge Reply Comments" Attachment Page 7 of18 -- - . - ORDER NO. 06-537 Docket UM 1217 September 12, 2006 Page 3 additional requirements for recertification were recently adopted by the Commission in Docket UM 1217 Order No. 06-292 (Order), entered on June 13 of this year. This is the first annual certification that employs the new requirements adopted in the order. To meet the new ETC annual certification requirements, each ETC must formally file specific information designed to demonstrate that the ETC: offers the supported services; will provide, and advertise, the supported services throughout its designated service area; offers and advertises low-incomeservices (Lifeline, Link Up, and OT AP); is able to remain functional in emergencies; is committed to service quality and consumer protection; and uses support funds for their intended purposes. The required reports are generally comparable for all ETCs, with one significant exception. CETCs that receive high cost universal service support must submit a network improvement plan explaining how they" used support funds in the previous year and how they will use support funds in the coming two years. For reasons explained in the Order ILEC ETCs are not required to submit such plans. To implement the new reporting system in a standardized format and to aid the ETGs in filing the information required by the order, Staff developed and distributed a set of prototype report formats for all the ETGs to follow. The time frame for Staff to convey the new requirements to ETCs and for the ETGs to file the new reports by the July 15 ordered deadline was quite short - barely a month - during this initial implementation year. Because of the short time frame, several challenges were presented which Staff believes will not affect next year's reporting. Staff addresses specific areas of difficulties faced by different types of ETGs. First, the rurallLECs, particularly the smallest ones ,. experienced some filing hurdles. All rurallLECs but one submitted their reports by the deadline, although some initial reports were incomplete or inaccurate. Nehalem Telecommunications submitted its filing three days after the deadline. ,HoweverNehalem had alerted Staff that it was experiencing personnel and scheduling problems and worked with Staff to enable as timely a filing as possible. The requirements to file electronically presented a challenge for severalsmalilLECs who had never before made an electronic filing and did not have scanning equipment available. After receiving electronic and hard copy filings from the ILECs, Staff reviewed each one for completeness and accuracy and contacted each ILEC to file missing reports or re-file inaccurate or incomplete reports. All rurallLECs were cooperative and acted in good faith to re-file in'a timely manneroThree smalllLECs -- St. Paul Cooperative Telephone Company, Pine Telephone, and Roome Telecommunications -- were unable to provide reports APPENDIX 4- PAGE~ OF 1'/ J!.age .KeplY ~umllu:ul.II ' Attachment Page 8 of 18 ., . ,-,. nI-_I_- "' ----- ORDER NOo 06-537 Docket UM 1217 September 12 , 2006 Page 4 on the number of trouble reports received for 2005 because they had not been collecting such data during that period. These carriers have agreed to start tracking the data that will enable them to file this information next year. Staff therefore recommends that the Commission grant these ETCs a waiver of the trouble report requirements for this year only. Staff has now received complete electronic.and hard copy versions of the required filings from all rurailLEC ETCs. Based on the information contained in the filed reports, including signed affidavits attesting to the use of s!Jpport funds for the intended purposes, and because the continued receipt of federal USF high cost support is vital to maintaining reasonable basic service rates in the service areas of rurailLECs 6 Staff recommends that the Commission certify that the rurallLECs listed in Exhibit A to this report are authorized to receive federal USF high cost support' pursuant to 47 C.R. ~ 54.314. . The second group of ETCs is comprised of the three CETCs designated in rural ILEG service areas - Edge Wireless (Edge), US Cellular Corporation (USCG)and RCG Minnesota (RCG). All three of these CETCs submitted their reports on time, including their network improvement plans. The detailed requirements of the network improvement plans were set out in Appendix A of the Order. Staff prepared a prototype reporting format for the network improvement plans to aid CETCs in filing and Staff in reviewing the required plans. While the format aided considerably, Staff and the CETCs agree that some improvements can be made and will discuss changes for next year's filing. The new requirements and the very short .time frame presented challenges for the CETGs and Staff relative to the network improvement plans. The plans address how the CETCs spent support money they received in 2005 and how they intend to spend support money they expect to receive in 2006 and 2007. Staff first reviewed the portion of each CETC's plan that identified the specific projects for which the CETG actually used support funds in 2005, and comparedthe actual spending with the projected plans that the GETGs submitted to the Commission last year. While the CETCs did not implement all the 2005 projectsthat they had included in their previous plans, they did substitute other projects which they believed met the intended purposes of support funds. Based on review of the plans submitted and responses to several questions Staff put to 6 Oregon s rurallLECs will receive approximately $50 million from federal USF high cost support programs in 20060 Federal USF high cost support programs are: high cost loop support; local switching support; long-term support; interstate access support; and interstate common line support. APPENDIX PAGE OF /'-1 Edge Reply Comments Attachment Page 9 0118 ORDER NO. 06-537 Docket UM 1217 September 12, 2006 Page 5 each of the CETCs, Staff concludes that each of the three CETCs did indeed use their 2005 high cost support funds to further the goals of universal service in Oregon. The second part of each CETC's network improvement plan addresses how the GETC proposes to use the support funds it expects to receive in 2006 and 2007. Edge Wireless had submitted a 5-year plan as part of its application for designation last year. Edge did a superb job of retaining much of that plan and carrying through elements of it for implementation in 2006 and 2007. USCG and RCG, however, had no previous plans on file for 2006 and 2007, as their recertification last year required a plan for only 2005 support spending. While some projects that were not completed from their 2005 plans were carried over into their 2006 plans, much of the 2006 and 2007 plans were new this year. Staff requested further information from USCG and RCC regarding their planned projects and each responded promptly. Staff expressed concerns to USCG and RCC that their proposed plans did not sufficiently focus support funds on projects to increase coverage and bring wireless service to rural areas that do not currently have service. "In-addition, Staff wanted to ensure that the carriers did not plan to use support funds to subsidize normally profitable business endeavors in high-density areas. USCG agreed to make several modifications to its plan to address Staffs concerns and to formally file a revised plan. Although RCG agreed to some specific changes to its plan, Staff and RCC were unable to come to total agreement on a revised plan prior to this meeting, due largely to time constraints. However, RCC has committed to work with Staff to develop, and file, a revised plan before the end of this year. Based on the information included in the annual reports of Edge, USCG and RCG, including the demonstrated appropriate use of 2005 support funds, the carrier's plans for 2006-2007 support, and signed affidavits to use support funds for the intended purposes, Staff recommends the Commission certify that Edge USCG, and RCC are authorized to receive federal universal service high cost support pursuant to 47 C.R. ~ 54.314. This recommendation is made with the understanding that RCC wtll continue to work with Staff to file a revised plan before the end of this year. The complete list of ETCs to be certified by October 1, 2006, to the FCC and USAC is included as Exhibit A to this memo. APPENDIX PAGE 5'"OF !.L Edge Reply Comments Attachment Page 10 of 18 ORDER NO. 06-537 Docket UM 1217 September 12 2006 Page 6 B. Certification of Non-RuraiILEC Rates in Rural Service Areas In October 2003 the FCC issued Order No. 03-249, which added Section 54.316to the FCC rules.? This section requires state public utility commissions to certify that the basic service rates charged by non-rural lLECs in their rural serviceareas are reasonably comparable to urban rates nationwide. This determination is made by comparing the basic service rates charged by non-rurallLECs in their rural service areas to a national average benchmark for urban basic service rates as calculated by the FCC. For purposes of this comparison, the FCC has " specified a safe harbor" mechanism which allows non-rural bas.ic service rates to be presumed reasonable if they are Jess than two standard deviations above the ,national average urban benchmark. For example, the FCC's most recentlycalculated national average rate for basic service in urban areas is $24.74.8 The rate two standard deviations above this benchmark is $34.58. States with non- rurallLEC rates below $34.58 in their rural service areas are presumed to have basic service rates reasonably comparable to those charged in urban areas. States with non-rurallLEC rates that equal or exceed $34.58 in rural areas mustexplain to the FCC why such rural and urban rate differentials are reasonable. Failure to provide this annual certification to the FCC and USAC by October 1 st of each year will prevent non-rural ETCs "in Oregon from receiving federal forward-looking high cost fund support. Owest Corporation (Owest) and Verizon Northwest Inc. (Verizon) are the only two non-rurallLECs in the state of Oregon. However, as is the case with non-rural/LECs in 40 of the 50 states , neitherOwest nor Verizon receives federal USF forward-looking high cost fund supportdespite the fact that they both provide service in high cost rural areas. The lack of federal support for these carriers emphasizes the importance of the Oregon Universal Service Fund (OUSF), which wa$ designed to achieve the comfarability between rural and urban rates mandated by Section 254(b) of the Act. Because no federal USF high cost fund support is available to Owest and See In the Matter of Federal-State Joint Board on Universal Service, Order on Remand,FNPRM, and MO&O, CC Docket 96-45 (released Oct. 27, 2003)0 8 The FCC annually calculates this national average benchmark in a publication entitled Reference Book of Rates, Price Indices, and Household Expenditures for Telephone Serviceo The rates for this year are taken from Table 1.13 of the 2006 edition. 9 The FCC's regulations concerning whether an ILEC is considered to be "rural" or "non-rural" aresomewhat arcane. Basically, an ILEC is considered to be a rural company if it serves less than , 00 000 access lines in a single study area. By default, Qwest and Verizon are the only non-rural ILECs in Oregono APPENDJX PAGE OF Edge Reply l.:omments Attachment Page 11 of 18 -- - - - ORDER NO. 06-537 Docket UM 1217 September 12, 2006 Page 7 Verizon , the OUSF currently distributes approximately $3.5 million per month tosubsidize the basic service rates of these carriers in their high cost rural service territories. Although neither Owest nor Verizon receive federar non-rural forward-lookinghigh cost support in Oregon, submitting the required demonstration will help the FCC to insure that federal and state universal service funding mechanisms are sufficient to meet the objectives of Section 254(b) of the Act, which provides that consumers in rural, irysular and high cost areas should have access totelecommunications services at rates that are "reasonably comparable" to ratescharged for similar services in urban areas. This is the third year the rate comparison , required by Section 54.316 of the 'FCCrules, is being submitted to the FCC. This year's comparison utilizes the same methodology as in past years. Exhibit C to this report summarizes the basic service rates charged b~ Owestand Verizon in each rural Oregon county where they provide service. 0 Exhibits 0 and E to this report provide a detail of the individual rate elements summarized in Exhibit C. Consistent with the methodology used by the FCC to calculate the national urban benchmark of $24., the basic service rates calculated for Owest and Verizon for this analysis include charges for the following: flat rate service, extended area service, federal Subscriber Line Charge, Oregon ResidentialService Protection Fund surcharge, E911 surcharge, city and county franchise fees, miscellaneous taxes, Oregon PUC fee assessment, Oregon Universal Service Fund surcharge, federal excise tax, and federal Universal Service Fundsurcharge. Pursuant to section 54.316(d) of the FCC rules, the basic service rates are those for July 1 , 2006. As illustrated in Exhibit C, Owest's basic service rates in rural Oregon counties range from $24.19 to $27.50 per month. Verizon s basic service rates in rural Oregon counties range from $22.07 to $28.67. All of these basic service ratesare significantly below the safe harbor threshold of $34.58 set by the FCC, andmany are below the national average urban benchmark of $24.740 Thereforepursuant to Section 54.316 of the FCC rules, they are presumed reasonably 10 The FCC requires state commissions to follow guidelines issued by the federal Office of Management and Budget (OMB) which publishes, and routinely updates, a list of metropolitanstatistical areas in the United States. Pursuant to the OMB's methodology, any county whichdoes not include a metropolitan statistical area is considered to be. rural. Under this definitiononly 10 of Oregon s 36 counties are considered to be non-rural. APPENIllX PAGE 1- OF l.f.... Edge Reply CommeRu Attachment Page 12 of 18 ORDER NO. 06-537 Docket UM 1217 September 12, 2006 Page 8 comparable to urban basic service rates nationwide and the Commission is not required to provide any additional explanations or analysis to the FCC or USAC. C. Review of 2006 Annual Recertification Reports In Section A. of this memo, Staff discussed the annual recertification reports of the rural ILECs and CETCs designated in rurailLEC service areas, as evidence that those ETCs met the annual reporting requirements adopted in Order No. 06~ 292, and therefore, should be recertified to the FCC to continue receiving federal high cost universal service support. Order No. 06-292 also required, for the first time, the submission of annual reports from the non-rurallLECs - Owest and Verizon - and CETCs designated only in non-rurallLEC service areas - Wantel and VCI Company (VCI). The Commission is not required to recertify these ETCs to the FCC each year because these ETCs do not receive rural'high cost supporto awest, Verizon, and Wantel receive only Interstate Access Support (IAS) and low-income support, for which they recertify directly to the FCC and USAC each year. VCI receives only low-income support. Although these ETCs certify directly to the FCC each year without Commission action, Order No. 06-292 requires these ETCs to submit annual reports to the Commission in order to provide evidence that they are fulfilling their universal service obligations. If the Commission finds that any ETC is not fulfilling all its universal service obligations, the Commission may revoke that ETC' certification, thereby prohibiting it from receiving any kind of federal universal service support. Based on review otthe information that Owest, Verizon, Wantel and VCI have submitted in their annual reports, Staff sees no reason for the Commission to consider revocation of any of these carriers' ETC status at this time. However, Staff will continue to monitor the performance of all ETCs and reserves the right to bring any concerns it may have to the Commission at a later date. PROPOSED COMMISSION MOTION: An order be issued in Docket UM 1217: 1. Certifying that the rurallLECs and CETCs listed in Exhibit A are authorized to receive federal universal service high cost support pursuant to 47 C.R. ~ 54.314; APPENDIX PAGE LOFlL Edge Reply Comments Attachment Page 13 of 18 ORDER NO. 06-537 Docket UM 1217 September 12, 2006 Page 9 2. Certifying that the basic service rates charged by Oregon s non-rurallLECs in their rural service areas are reasonably comparable to urban basic service rates nationwide pursuant to 47 Co R. ~ 54.316; and 3. Granting waivers for good cause of the trouble report requirement of Order No. 06-292 for this year for St. Paul Cooperative, Pine Telephone, and Roome Telecommunications; and accepting the 2006 annual recertification filings of all ETCs, with the understanding that RCG has committed to work with Staff to file a revised network improvement plan before the end of this year. Exhibits A through E follow. UM 1217 Annual Certificationodoc APPENDIX .4 PAGE OF ft. Edge Reply Comments - Attachment Page 14 of 18 ORDER NO. 06-537 Docket UM 1217 September 12, 2006 Page 10 Exhibit A Eligible Telecommunications Carriers (Oregon RurailLECs and CETCs) Certified to Receive Federal Universal Service Fund High Cost Support Company USAC Study Area Code Asotin Telephone Company Beaver Creek Cooperative Telephone Co. Canby Telephone Association Cascade Utilities, Inc. CenturyTel of Oregon, Inco CenturyTel of Eastern Oregon, Inc. Citizens Telephone Co. of Oregon, loco Clear Creek Mutual Telephone Company Colton Telephone Company10 Eagle Telephone System, Inc.11 Gervais Telephone Co. 12 Helix Telephone Company13 Home Telephone Company14 Malheur Home Telephone Company15 Midvale Telephone.Exchange Inco16 Molalla Communications Company17 Monitor Cooperative Telephone Company18 Monroe Telephone Company19 Mt. Angel Telephone Company20 Nehalem Telecommunications, Inc.21 North-State Telephone Company 22 Oregon-Idaho Utilities, Inc.23 Oregon Telephone Corporation 24 People s Telephone Company25 Pine Telephone System, Inco26 Pioneer Telephone Cooperative 27. Roome Telecommunications, Inc.28 Scio Mutual Telephone Association29 Stayton Cooperative Telephone Company30 United Telephone Co. of the Northwest31 St. Paul Cooperative Telephone Association 32 Trans-Cascades Telephone Company 33 RCC Minnesota Inco34 United States Cellular Corporation35 Edge Wireless, LLC 532404 532359 532362 532371 532361 532361 533401 532363 532364 532369 532373 532376 532377 532456 532226 532383 532384 532385 532386 532387 532388 532390 532389 532391 532392 532393 532375 532397 5323. 532400 532396 532378 539001 539002 539004 APPENDIX PAGE.L1L OF Iff. rOo , being of lawful age and duly sworn , on my oath (an officer) of Company") and that I am authorized to execute this Affidavit on behalf of the Company, and the facts set forth in this Affidavit are true to the best of my knowledge, information and belief. Docket UM 1217 September 12 2006 Page 11 Exhibit B AFFIDAVIT CERTIFYING USE OF UNIVERSAL SERVICE FUNDS I, state that I am the Edge Reply c..;omments Attachment Page 15 of 18 ORDER NO. 06-537 Pursuant to the rules of the Federal Communications Commission, 47 C.R. 954.314there must be an annual certification that funds received under the federal Universal Service Fund programs will be used only for the provision, maintenance and upgrading of facilities and services for which the support is intended. The Company hereby certifies to the Public Utility Commission of Oregon that pursuant to 47 Co R. 954. and for purposes of the certification required under 47 C.R. S 540314, the Company will use all federal high-cost support provided to it only for the provision, maintenance and upgrading of facilities and services for which the support is intended, consistent with the principles of universal service set forth in 47 U.S. Co 254. This includes, but is not limited to, trying to meet the goal of the provision of services that are properly supported by the high-cost funds at rates that are reasonably comparable to rates charged for similar services in urban areas. DATED this day of 20060 By: (Company) (Name) Its:(Title) SUBSCRIBED AND SWORN to before me this _day of 20060 Notary Public in and for the State of Oregon My Commission Expires: APPENDIX PAGE OF !.L Edge Reply Comments ' Attachment Page 16 oUS ORDER NO. 06-537 Docket UM 1217 September 12, 2006 Page 12 Exhibit C Summary of Non-RuraiILEC Basic Service Rates in Rural Oregon Counties Qwest Rural Monthly Verizon Rural MonthlyExchangeCountyRateExchangeCountyRate Baker City Baker $ 24.Bandon Coos $ 280SumpterBaker$ 24.Coos Bay"'N. Bend Coos $ 24.Astoria Clatsop $ 24.Coquille Coos $ 28. Cannon Beach.Clatsop $ 25.Lakeside Coos $ 28.Seaside Clatsop $ 24.Myrtle Point Coos $ 28.Warrenton Clatsop $ 24.Powers Coos $ 28.Westport Clatsop $ 26.45 Brookings Curry $ 22.Prineville Crook $ 26.Gold Beach Curry $ 22.45Oakland-Sutherlin Douglas $ 25.Langlois Curry $ 230RoseburgDouglas$ 25.Port Orford Curry $ 23.Camp Sherman Jefferson $ 27.Reeds port Douglas $ 23.Culver Jefferson $ 26.Murphy-Provolt Josephine $ 28.Madras Jefferson $ 26.Mill City Linn $ 28.Grants Pass Josephine $ 25.Cove Union $ 24.Klamath Falls Klamath $ 24.Elgin Union $ 24.48NewportLincoln$ 24.Imbler Union $ 24.Siletz Lincoln $ 26.La Grande Union $ 23.Toledo Lincoln $ 25.Union Union $ 24.Albany Linn $ 25.Enterprise Wallowa $ 23.Harrisburg Linn $ 26.Joseph Wallowa $ 23.Athena-Weston Umatilla $ 26.Lostine Wallowa $ 23.Hermiston Umatilla $ 24.Wallowa Wallowa $ 23. Milton Freewater Umatilla $ 25. Pendleton UmatilIa $ 24. Stanfield Umatilla $ 25. Umatilla Umatilla $ 25. Walla Walla Umatilla $ 25. APPENDIX If PAGE L~F 'd i ! d Do c k e t U M 1 2 1 7 Se p t e m b e r 1 2 , 2 0 0 6 Pa g e 1 3 0'1 \# . ) -.. J Ex h i b i t D De t a i l o f Q w e s t B a s i c S e r v i c e R a t e s i n R u r a l O r e g o n C o u n t i e s Fr a n c h i s e Fe d Fe d Qw e s t Ru r a l Ra t e EA S Ba s e EA S Fe d Fe d Fe e s & PU G OU S F Ex c i s e T a x US F (i y Ex c h a n g e Co u n t y Gr D . Ba n d Ra t e Ch r a . SL C LN P RS P F E9 1 1 M. T a x e s Fe e ai) 7 . 12 % (Q ! 3 % 10 . To t a l Ba k e r C i t y Ba k e r 12 . 0. 4 2 24 . Su m D t e r Ba k e r 12 . 0. 4 2 24 0 As t o r i a Cl a t s o p 12 . 80 ' 1 . 0. 4 2 24 . Ca n n o n B e a c h Cl a t s o p 13 . 0. 4 5 25 . Se a s i d e Cl a t s o p 12 . 24 . Wa r r e n t o n Cl a t s o D 12 . 0. 4 2 24 . We s t p o r t Cl a t s o p 14 . 0. 4 8 26 . 4 5 Pr l n e v i l l e Cr o o k 13 . 0. 4 8 26 . Oa k l a n d - Su t h e r l i n Do u a l a s 13 . 0. 4 5 25 . Ro s e b u r g Do u a l a s 13 . 0. 4 5 25 . Ca m p S h e r m a n Je f f e r s o n 14 . 27 . Cu l v e r Je f f e r s o n 13 . 0. 4 8 26 , Ma d r a s Je f f e r s o n 13 . 0. 4 8 26 . Gr a n t s P a s s Jo s e p h i n e 12 . 0. 4 2 25 . Kl a m a t h F a l l s Kl a m a t h 12 . 0. 4 5 24 . Ne w p o r t Li n c o l n 12 . 0. 4 3 24 . Si l e t z Li n c o l n 14 . 26 . To l e d o Li n c o l n 13 . 0. 4 5 25 . Al b a n y Li n n 12 . 0. 4 5 25 . Ha r r i s b u r g Li n n 13 . 0. 4 8 26 . At h e n a - We s t o n Um a t i l l a 14 . 0. 4 8 26 . 4 5 He r m i s t o n Um a t i l l a 12 . 0. 4 2 24 . Mi l t o n F r e e w a t e r Um a t i l l a 13 , 0. 4 5 25 . Pe n d l e t o n Um a t i l l a ' 12 . 0. 4 2 24 . St a n f i e l d Um a t i l l a 13 . 25 . Um a t i l l a Um a t i l l a 13 . 0. 4 5 25 . Wa l l a W a l l a Um a t i l l a 13 . 25 . :~ ~ IJ Q E i I J Q t' ) ~ OM : : r 1- . . 1 a Q ~ '1 : 1 "" : : 1 OM . . . . -. . : OI l (') ::I .. . . fI ) -' - ' - - - - _ _ _ 0 _ _ _ - _ _ - - - - - - - - - . - - . . . . - . - , - . - - - . - - . . - - - - - - - - - - - - ' - " - - " " " - - - " " " _ _ _ _ d_ _ ' - - - - , . - . -- , . - , . . . , n Do c k e t U M 1 2 1 7 Se p t e m b e r 1 2 , 2 0 0 6 Pa g e 1 4 -- . . ) Ex h i b i t E De t a i l o f V e r i z o n R a t e s i n R u r a l O r e g o n C o u n t i e s Fr a n c h i s e Fe d Fe d Ve r i z o n Ru r a l EA S Ba s e EA S . Fe d Fe d Fe e s & PU C OU S F Ex c i s e T a x US F ~ Ex c h a n a e Co u n t y Ba n d Ra t e Ch r a . SL C LN P RS P F E9 1 1 M. T a x e s Fe e lf f i 12 % lf f i 10 . 5% . To t a l Ba n d o n Co o s II I 12 . 28 . Co o s B a v ~ N. B e n d Co o s 12 . 0. 4 4 24 . Co q u i l l e Co o s II I 12 . 28 . La k e s i d e Co o s II I 12 . 59 , 28 . My r t l e P o i n t Co o s II I 12 . 28 . Po w e r s Co o s /I I 12 . 5; 5 0 28 . Br o o k i n a s Cu r r y N/ A 12 . 22 . Go l d B e a c h Cu r r y N/ A 12 . 22 . 4 5 La n g l o i s Cu r r Y 12 . 23 . Po r t O r f o r d Cu r r Y 12 . 23 . Re e d s p o r t Do u Q l a s 12 . 23 . Mu r c h v - Pr o v o l t Jo s e o h i n e II I 12 . 28 . Mi l l C i t v Un n 12 . 28 . Co v e Un i o n 12 . 0. 4 4 24 . El a i n Un i o n 12 . 24 . 4 8 Im b l e r Un i o n 12 . 24 . 4 8 La G r a n d e Un i o n 12 . 23 . Un i o n Un i o n 12 . 0. 4 4 24 . En t e r p r i s e Wa l l o w a 12 . 23 . Jo s e p h Wa l l o w a 12 . 0. 4 1 23 . Lo s t i n e Wa l l o w a 12 . 0~ 8 3 '0 . 23 . 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