20220721Qwest Amendment with Quantum Shift-UNE Resale.pdf

luly 21,2022
Via Email Submission
s e c re taryt@t u e ida h o. go v
Ms. Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Ste. 201-A
Boise, D 83714
Re: Case No.: -
Application for Approval of Amendment to Interconnection Agreement
Dear Ms. Noriyuki:
Attached for filing are an Application for Approval of Amendment to Interconnection
Agreement along with the Unbundled Network Elements (UNEs) - Resale Forbearance
Amendment to the lntercoonection Agreement between Qwest Corporation dba CenturyLink QC
('CenturyLink") and Quantum Shift Communications, Inc. dba vCom Solutions for the State of
Idaho. CenturyLink respectfully requests that this matter be placed on the Commission Decision
Meeting Agenda for expedited approval.
Please feel free to contact me with any questions regarding this submission. Thank you
for your assistance in this matter.
Sincerely
LUMEN'
t)
L)4l"lrfft
Josie Addington -
Legal Assistant
Attachments
cc: Service List
1600 7t' Avenue, Floor't5
Seattle, Washington 981 91
206-806-7339
[e-mail]
William E. Hendricks, III (WSBA#29786)
Lumen
902 Wasco Street
Hood River, OR 97031
541-387-9439
Tre.hendricks@lumen. com
ArplrclrroN oF Qwnsr ConponauoN DBA
CnxrunvlrNK QC FonAppnovAl oFAN
A*rcxoprnNT To IxrBncoxxECTIoN
Acnrnurnxr wITH Quauruu Srur,
Corr*rumcATroNs, Ixc. pra vCoM
Sorurroxs Punsuaxr ro47 U.S.C. $252(e)
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO.: Nt o E-T- LT t C
APPLICATION FOR APPROVAL OF
AMENDMENT TO INTERCONNECTION
AGREEMENT
Qwest Corporation dba CenturyLink QC ("CenturyLink") hereby files this Application
for Approval of Amendment to the lnterconnection Agreement. The lnterconnection Agreement
was approved by the Idaho Public Utilities Commission on December 3, 2008 under Order
No. 30696 (the "Agreement"). The Unbundled Network Elements (UNEs) - Resale Forbearance
Amendment to the lnterconnection Agreement ("Amendment") between CenfuryLink and
Quantum Shift Communications, Inc. dba vCom Solutions ("vCom Solutions") is submitted
herewith.
This Amendment 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").
Section 252(e)(2) of the Act directs that a state Commission may reject an amendment
reached through voluntary negotiations only if the Commission finds that: the amendment (or
portion(s) thereof) discriminates against a telecommunications ca:rier not a party to this
AppucenoN ron AppRovRL on AuBxor"rENT To INrsncoxxectoN
AcnrnurNr [Queruruu SHFI ose vCou SolurrcNs] - Page I
agreement; or the implementation of such an amendment (or portion) is not consistent with the
public interest, convenience and necessity
CenturyLink respectfully submits this Amendment provides no basis for either of these
findings, and, therefore requests that the Commission approve this Amendment expeditiously.
This Amendment is consistent with the public interest as identified in the pro-competitive
policies of the State of Idaho, the Commission, the United States Congress, and the Federal
Communications Commission. Expeditious approval of this Amendment will enable vCom
Solutions to interconnect with CenturyLink facilities and to provide customers with increased
choices among local telecommunications services.
CenturyLink further requests that the Commission approve this Amendment without a
hearing. Because this Amendment was reached through voluntary negotiations, it does not raise
issues requiring a hearing and does not concern other parties not a party to the negotiations.
Expeditious approval would further the public interest.
Respectfully submitted this 2l't day of July,2022.
CENTURYLINK
William E. Hendricks, III
Attorney for Qwest Corporation dba
CenturyLink QC
APPIICAnON FOR APPROVAL oF AMENDMENT To INTERCoNNECTIoN
AcRsrusNr [QuANruM SHFI ose vCorvr Sorurrows] - Page 2
CERTIFICATE OF SERYICE
I hereby certiff that on this 21$ day of July,2022,I served the foregoing
APPLICATION FOR APPROVAL OF AMENDMENT TO TIIE INTERCONI\TECTION
AGREEMENT upon all parties of record in this matter as follows:
JanNoriyuki, Secretary
Idaho Public Utilities Commission
Jenna Brown, Sr. Dir. Parbrer & Compliance Mgt.
Quantum Shift Communications, Inc. dba vCom
Solutions
Via Email:
[e-mail]. sov
Via Email:
ibrown@vcomsolutions. com
(Jz',r /"Aflt
losie l(ddinlton /
Appltcerrcu ron Appnovar oF AMENDMET{T ro IvrrRcoNNEcrIoN
AcnseMENT [QuANruM SHnr osa vcou SoruuoNs] - Page 3
Unbundled Network Elements (UNEs) - Resale Forbearance Amendment
to the lnterconnection Agreement between
Qwest Corporation dba CenturyLink QC
and
Quantum Shift Communications, lnc. dba vCom Solutions
for the State of Idaho
This is an Amendment ("Amendment") to the lnterconnection Agreement between Qwest
Corporation dba CenturyLink QC ("CenturyLink"), a Colorado corporation, and Quantum Shift
Communications, !nc. dba vCom Solutions ('CLEC'). CenturyLink and CLEC shall be known
jointly as the "Parties'.
RECITALS
WHEREAS, the Parties entered into an lnterconnection Agreement ("Agreement") for service in
the state of ldaho which was approved by the Commission on December 3, 2008; and
WHEREAS, on July 12, 2019, the Federal Communications Commission (the, "FCC' or
"Commission") released Order FCC 19-66, a Report and Order on Remand and Memorandum
Opinion and Order in WC Docket Nos. 18-141, et a! (the "UNE Transport Order"), which became
effective upon release; and
WHEREAS, on August 2, 2019, the FCC released Order FCC 19-72, a Memorandum Opinion
and Order in WC Docket 18-141 (the "UNE Analog Loop and Resale Forbearance Order"),
which became effective upon release (together, with the UNE Transport Order, collectively
referred to as the'Forbearance Orders"); and
WHEREAS, the Parties agree that the Forbearance Orders are changes in Applicable Law that,
pursuant to the terms of the Agreement, must be incorporated through an amendment to the
Agreement; and
WHEREAS, in order to implement the terms of the Forbearance Orders and consistent with the
terms of the Agreement regarding changes in Applicable Law, the Parties desire to amend the
Agreement further under the terms and conditions contained herein.
AGREEMENT
NOW THEREFORE, in consideration of the mutual terms, covenants and conditions contained
in this Amendment and other good and valuable consideration, the receipt and sufficiency of
which is hereby acknowledged, the Parties agree as follows:
Amendment Terms
The Agreement is hereby amended by adding terms and conditions for Unbundled Network
Elements (UNEs) and Resale as set forth in attachments and Exhibit A to this Amendment,
attached hereto and incorporated herein by this reference. Any capitalized terms not defined
specifically in this Amendment are as defined in the Agreement.
Effective Date
This Amendment shall be deemed effective upon approval by the Commission, or by being
permitted to go into effect by operation of law; however, the Parties may agree to implement the
June 4, 2020/kjc/UNE-Resale Forbearance Amd/Quantum Shift/lD I
Q Ame ndment to C DS-08082&0004 (v.01 .22.2020-3)
provisaons of this Amendment upon execution. To accommodate this need, CLEC must
generate, if necessary, an updated Customer Questionnaire. The Parties agree that so long as
CenturyLink implements the billing changes and the true-up as set forth below, the CLEC's bills
shall be deemed accurate and adjusted without error.
Further Amendments
Except as modified herein, the provisions of the Agreement shall remain in full force and effect.
The provisions of this Amendment, including the provisions of this sentence, may not be
amended, modified or supplemented, and waivers or consents to departures from the provisions
of this Amendment may not be given without the written consent thereto by both Parties'
authorized representative. No waiver by any Party of any default, misrepresentation, or breach
of warranty or covenant hereunder, whether intentional or not, will be deemed to extend to any
prior or subsequent default, misrepresentation, or breach of wananty or covenant hereunder or
affect in any way any rights arising by virtue of any prior or subsequent such occurrence.
Entlre Asreement
The Agreement as amended (including the documents referred to herein) constitutes the ful!
and entire understanding and agreement between the Parties with regard to the subjects of the
Agreement as amended and supersedes any prior understandings, agreements, or
representations by or between the Parties, written or oral, to the extent they relate in any way to
the subjects of the Agreement as amended.
The Parties intending to be legally bound have executed this Amendment as of the dates set
forth below, in multiple counterparts, each of which is deemed an original, but al! of which sha!!
constitute one and the same instrument.
Quantum Shift Communications, lnc.
dba vcom Solutions
Qwest Corporatlon dba CenturyLink QG
,(tubetlq 't ?ott7k
Kimberly J. Povirl(Jun 7. 2021 ll:08 CDT)Brown (May 25, 2021 12:05 PDT)
Signature
Jenna Brown
Signature
Kimberlv J. Povirk
Name Printedffyped
Sr. Dir. - Partner & Compliance Manaoement
Title
May25,2O2L
Date Date
J une 4, 2020/kic/U N E-Resale Forbearance Amd/Quantum Shifl/lD
Q Amendment to CDS-08082&.0004 (v.01.22.2020-3)
Name Printed/Typed
Sr. Dir. Bus. Oos Wholesale Sales
Title
Jun 7,2021
2
ATTACHMENT 1
ATTACHMENT I
1. Resale Provisions - Pursuant to the Forbearance Orders, CLEC's ability to order new
services and retain existing services from CenturyLink for resale pursuant to Sections 6,
including Directory Listings and Directory Assistance that pertain to Resale, of the
Agreement are altered as follows:
a. Effective Date to February 2, 2020 - During the time period from the Effective
Date of this Amendment until February 2, 2020, CLEC may order any services
for resale pursuant to the applicable terms and conditions of the Agreement. ln
addition, CLEC may make changes in existing resold services, also pursuant to
the applicable terms of the Agreement, until February 2,2020.
b. February 2,2020 to August 2,2022 - After February 2,2020, CLEC cannot
order any services for resale from CenturyLink pursuant to the applicable
provisions of the Agreement. Any orders for new services for resale will be
pursuant solely to the terms of the applicable Tariff for the service including any
lCB agreements entered into under the applicable Tariffs.
i. For any services procured for resale under the terms of the Agreement
("Existing Resale Services") on February 2,2020 or prior, CenturyLink will
continue to provide such Existing Resale Services pursuant to the terms
of the Agreement, including any discounts delineated in Exhibit A of the
Agreement.
ii. CLEC cannot make any changes to such Existing Resale Services, as
they will be treated in a "grandfathered" status, with continued receipt or
disconnection of the Existing Resale Services the only options under the
Agreement available to CLEC. lf CLEC issues an order to change such
services, it will be treated as new services for resale and will be provided
solely under the Tariffs, rather than under the Agreement.
iii. CLEC agrees that it will no longer submit any orders for resale services
under the Agreement from CenturyLink after February 2,2020. CLEC
agrees that it is the CLEC's responsibility to ensure that no further orders
for resold services under the Agreement are submitted after February 2,
2020. lf resold services are ordered after February 2,2020 CLEC agrees
that the Agreement is no longer in effect and resold services are being
ordered per the applicable tariff at the full rates in the tariff.
1. ln order to ensure compliance with these provisions, the Parties
agree that CenturyLink, on no more than quarterly basis, may
conduct an audit of CLEC's order activity after February 2,2020,
in order to identify any mistaken instances of attempting to order
resold services under the terms of the Agreement.
2. Should such instances occur, the Parties further agree that
CenturyLink may issue a bill using the effective date of the
changes that the applicable service was originally ordered
("Resale True-Up Bill') removing the discount for such services
and billing under the Tariffs at full tariffed prices. CLEC agrees
June 4, 2020/kjc/UNE-Resale Forbearance Amd/Quantum Shifl/lD
Q Amendment to cDS-08082&0004 (v.O1.22.2020-31
3
ATTACHMENT 1
not to contest such Resale True-Up Bills unless such billing is not
consistent with the applicable Tariff.
c. After August2,2O22 - The Parties agree that CenturyLink wil! no longer provide
any Existing Resold Services under the terms of the Agreement after August 2,
2022. CLEC is solely responsible for either disconnecting such Existing Resold
Services prior to August 2, 2022 or ordering them as new services under the
applicable Tariffs.
2. UNE Analog Loops - Pursuant to the terms of the Forbearance Orders, the terms and
conditions under which CLEC may order and maintain Analog Unbundled Loops, as
defined in Section 9.2.2 provided in the Agreement and Two-Wire/Four-Wire Unbundled
Distribution Loop, as provided in Section 9.3.2.1.1 of the Agreement (together, referred
to as "Analog Unbundled Loops") are altered as follows:
a. Effective Date to February 2, 2020 - During the time period from the Effective
Date of this Amendment until February 2, 2020, CLEC may order Analog
Unbundled Loops pursuant to the applicable terms and conditions of the
Agreement. !n addition, CLEC may make changes in existing Analog Unbundled
Loop arrangements, also pursuant to the applicable terms of the Agreement.
b. February 2,2O2O to August 2,2022 - After February 2,2020, CLEC cannot
order any Analog Unbundled Loops from CenturyLink pursuant to the applicable
provisions of the Agreement.
i. For any Unbundled Analog Loops procured under the terms of the
Agreement ('Existing Analog Loops") on February 2, 2O2O or prior,
CenturyLink willcontinue to provide such Existing Analog Loops pursuant
to the terms of the agreement, including the applicable rates delineated in
Exhibit A of the Agreement.
ii. CLEC cannot make any changes to such Existing Analog Loops, as they
will be treated in a "grandfathered" status, with continued receipt or
disconnection of the Existing Analog Loops the only options under the
Agreement available to CLEC. lf CLEC issues an order to change such
services, it will be treated as a conversion to Special Access services
being provided solely under the Tariffs, rather than under the Agreement.
iii. CLEC agrees that it will no longer submit any orders for Unbundled
Analog Loops under the Agreement from CenturyLink after February 2,
2020. CLEC agrees that it is the responsibility of the CLEC to ensure that
no further orders for such Analog Unbundled Loops under the Agreement
are submitted after February 2,2020.
1. ln order to ensure compliance with these provisions, the Parties
agree that CenturyLink, on a no more than quarterly basis, may
conduct an audit of CLEC's order activity after February 2,2020,
in order to identify any mistaken instances of attempting to order
Analog Unbundled Loops under the terms of the Agreement.
2. Should such instances occur, the Parties further agree that
CenturyLink wil! request CLEC to disconnect such services and
order them as new by ordering the Special Access service under
June 4, 2020/kjc/UNE-Resale Forbearance Amd/Quantum Shifl/lD
Q Amendment to CDS-08082&.0004 (v.01.22.2020-3)
4
ATTACHMENT 1
the applicable Tariff, changing the applicable rate charged, and
CenturyLink may issue a bi!! using the effective date of the
changes that the applicable Unbundled Analog Loop was
originally ordered ("Analog Loop True-Up Bill"). CLEC agrees not
to contest such Analog Loop TrueUp Bills unless such billing is
not consistent with the applicable Tariff.
iv. CLEC agrees that any provisions in the Agreement that provide for Line
Splitting or Loop Splitting are also removed and may no Ionger be
ordered, as they all involve an order of an Unbundled Analog Loop. Any
existing arrangements will be maintained during the time period of this
section.
c. After August2,2022 - The Parties agree that CenturyLink will no longer provide
any Unbundled Analog Loops under the terms of the Agreement after August 2,
2022, including any arrangements for Line Splitting or Loop Splitting. CLEC is
solely responsible for either disconnecting such Analog Unbundled Loops prior to
August 2,2022 or converting them to a service under the applicable Tariffs. For
any Analog Unbundled Loops in place as of August2,2022, CLEC agrees that
CenturyLink wil! convert any such Analog Unbundled Loops to the appropriate
SpecialAccess service under the applicable Tarffi, and CLEC is then responsible
for such services under that Tariff. ln addition, should any charges be necessary
as part of that conversion, CLEC agrees that it is responsible for payment of such
charges and will not dispute application of such charges necessary for the
conversion. As Line Splitting and Loop Splitting are not available service under
CenturyLink's Tariffs, CLEC must convert to alternative arrangements that meet
its needs, as such arrangements will otherwise be terminated after August 2,
2022.
d. Alternative Analog Unbundled Loops Gommercial Arrangements - The
Parties understand and agree that the Forbearance Orders specifically permit
alternative commercial arrangements for the provision of UNEs that are impacted
by the Forbearance Orders. Nothing in this Amendment either requires
CenturyLink to enter into such alternative arrangements or prohibits the Parties
from reaching an agreement on terms and conditions of such alternative
arrangements. The Parties agree that nothing in such alternative arrangement
would ever be intended to change any of the obligations under this Agreement,
rather to be in parallel to the terms and conditions of the Agreement.
e. UNE Gombinations - Any UNE Combinations provided under the Agreement
that might include UNE Analog Loop are also treated as UNE Analog Loops
under this Agreement.
3. UNE Transport - Pursuant to the terms of the Forbearance Orders, the terms and
conditions under which CLEC may order and maintain Unbundled Dedicated lnteroffice
Transport ("UD|T"), as provided in Section 9.6.1.1 of the Agreement and Enhanced
Extended Loop ("EEL"), as provided in Section 9.23.3.7 of the Agreement (together,
referred to as "UNE Transport') are altered as follows:
a. Effective Date to January 12,2020 - During the time period from the Effective
Date of this Amendment unti! January 12,2020, CLEC may order UNE Transport
pursuant to the applicable terms and conditions of the Agreement. ln addition,
June 4, 2020/kjc/UNE-Resale Forbearance Amd/Quantum Shifl/lD
Q Amendment to C DS-08082&0004 (v.O'| .22.2020-31
5
ATTACHMENT 1
CLEC may make changes in existing UNE Transport arrangements, also
pursuant to the applicable terms of the Agreement.
b. January 12, 2O2Oto July 12, 2022- After January 12, 2020, CLEC cannot order
any UNE Transport from CenturyLink pursuant to the applicable provisions of the
Agreement that has each endpoint in one of the Serving Wire Centers listed on
the Wholesale website: http://www.centurvlink.com/wholesale/clecs/nta.html#UNE-F
to this Amendment ("Forbearance UNE Transport"). For any UNE Transport that
does not meet the definition of Forbearance UNE Transport, such UNE Transport
will continue to be available and provided under the terms of the Agreement,
including the terms underwhich it may be wtthdrawn.
i. For any Forbearance UNE Transport procured under the terms of the
Agreement ('Existing Forbearance UNE Transport') on January 12,2020
or prior, CenturyLink will continue to provide such Existing Forbearance
UNE Transport pursuant to the terms of the Agreement, including the
applicable rates delineated in Exhibit A of the Agreement.
ii. CLEC cannot make any changes to such Existing UNE Transport, as they
will be treated in a 'grandfathered' status, with continued receipt or
disconnection of the Existing UNE Transport the only options under the
Agreement available to CLEC. lf CLEC issues an order to change such
services, it will be treated as a conversion to Special Access services
being provided solely under the Tariffs, rather than under the Agreement.
iii. CLEC agrees that it will no longer submit any orders for Forbearance
UNE Transport under the Agreement fiom CenturyLink after January 12,
2020. CLEC agrees that it is the CLEC's responsibility to ensure that no
further orders for such Forbearance UNE Transport under the Agreement
are submitted after January 12,2020.
1. ln order to ensure compliance with these provisions, the Parties
agree that CenturyLink, on a no more than quarterly basis, may
conduct an audit of CLEC's order activity after January 12,2020,
in order to identify any mistaken instances of attempting to order
Forbearance UNE Transport under the terms of the Agreement.
2. Should such instances occur, the Parties further agree that
CenturyLink will convert such services to the Special Access
service under the applicable Tariff, changing the applicable rate
charged as needed, and issue a bill to make the effective date of
the charges be the date the applicable Forbearance UNE
Transport was originally ordered ("UNE Transport True-Up Bill").
CLEC agrees not to contest such UNE Transport True-Up Bills
unless such billing is not consistent with the applicable Tariff.
c. After July 12,2022 - The Parties agree that CenturyLink will no longer provide
any Forbearance UNE Transport under the terms of the Agreement after July 12,
2022. CLEC is solely responsible for either disconnecting such Forbearance
UNE Transport prior to July 12, 2022 or converting to Special Access service
under the applicable Tariffs. For any Forbearance UNE Transport in place as of
July 12, 2022, CLEC agrees that CenturyLink will convert any such Forbearance
J une 4, 2020/kjc/U N E-Resale Forbearance Amd/Quantum Shift/l D
Q Amendment to CDS48082&0004 (v.01.22.2020-3)
o
ATTACHMENT 1
UNE Transport to the appropriate Special Access service under the applicable
Tariff, and CLEC is then responsible for such services under that Tariff. ln
addition, should any charges be necessary as part of that conversion, CLEC
agrees that it is responsible for payment of such charges and will not dispute
application of such charges necessary for the conversion.
d. Alternative UNE Transport Commercial Arrangements The Parties
understand and agree that the Forbearance Orders specifically permit alternative
commercial arrangements for the provision of UNEs that are impacted by the
Forbearance Orders. Nothing in this Amendment either requires CenturyLink to
enter into such alternative arrangements or prohibits the parties from reaching an
agreement on terms and conditions of such alternative arrangements. The
Parties agree that nothing in such alternative arrangement would ever be
intended to change any of the obligations under this Agreement, rather to be in
paralle! to the terms and conditions of the Agreement.
J u ne 4, 2020/kjc/U N E-Resale For.bea rance Amd/Quantum Sh ift/lD
Q Amendment to CDS-08082&0004 (v.01.22.2020-3)
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o)??.tFFt 2-ire I od6 lnilallation
1 $245.1 I DFI
sla2-97 D. E. ,I
1 1
tt5-65 D. E. t5
s23 76
340.50 D. E. t5
s.23.2.2
1't lFiRt 321Afi DEI
Addilional $182.97 D.E.I
1 330 7(l
M6.63 D. E. 15
379 47 DF15
FFI I ooD DSIq) ra IFFI D I I mn lnstdlrtlm
s300.49
l1 2 lFe.ii Addition.l 3225-39 D. E. ,I
mtes in
?2 1 lTone 1 386.4a D. E.'t5
2 tE6..16
sgs-06 D. E_ l5
02326 EEL Reamnoemont
$130.83 o. E. 12
rnrailv 31a8 50 DE12
FFI trrultlDleinoq)arA 3263 86 s216.92 B-D.E D.E.I
*ana D *ri6 0,PNFq)ar9
I Low st3 lo RDF
Lw 37.47 RDF
g-26
,51
9.25.1.1
$225.67
\d.lilimd 3148_96 D- E.1
E2512 2-Wire Anelm LmD (see ratas in 9.2-1.1)
sl5-65 D. E, 15
s73 76 DF15
340.50 D. E. 15
s.25-2
92521
1225.67 D.E.1
31aA C6 DF1
crar)
1 330 DE15
346.63 n F t5
Page 2 of 3
E hibit A
ldeho
19.25.2.2.3 lzone 3 i79_17 D. E. l5
't0.3.2 R€mlum / PrlvEcy Lislings Gen6rd
Edrange
Tedf Rate,
Le3s
Wholesale
Dbmnl
G€nerd
E)drange
f8rilI Rato,
Le3s
Wholesale
Diswnl
O,E D.E
6.1 nd
Ihe Fode.al Communlcslions Comri$ion (the, "FCC' ot'Comr$sion') rBleased Order FCC 1966, a Report {|d Order on Rsm$d and Memorandum
Oplnlon and Odsr in WC Docket Nos. 1&141, et al (th6 'UNE Transport Ordel"), end on Argu3t 2, 2019, r€l€as€d Ord€r FCC 1$72, a Meflrorsndum
Oplnion and Order in WC Docket 1&141 (the 'UNE Analog Loop and Resale Forioarance Order) whlch dtor€d C€nturyLlnk's oblioetions to provldo cortain
unbundled n€twork elements. As a result, any rate Wth this footnoto attach6d to it only appli€s lo UNES and Resold soMces according to tho terms of the
UNE/Resale Fotteardrce Arnendment of the Agreement. Any rate with this toohdo ls no longer applicable ln any way a'nor Argust 2, 2022, agaln
E fhe rate3 in this tablo apply solely to leMca3 ordeted for UNE/Relde on or b€ilore Februsy 2, 2020. Any n€w seMces for UtE/R$de inconoctly ordered
after February 2, 2020 will nd hav€ tho discounts or rales applicaDle in this lebl€, but instesd will be subrocn to the applicable tdff, prie lBt or catdog
I,t S€md VoluntaN Rale Reductim- Dod(ct USW-T-dl3- o{factire 6nlo2- Reduclions mlleded in the 71do2 Errlbil A
rELRIC rel$ proposed ln Cost Oocket OWE-1-01-11 testimony fil€d on Novomb€r '12, 2003, The cas€ rya8 bffurcated and ths rates ushg thb foolnote are
dhnored in Phr.a 2 .tf lhe 6rl dod.l
12
t5
Page 3 of 3