20220801Qwest Amendment with ACN Communications-UNE Resale.pdf

MEN"i':,i.'iDLU..*
.-,.i .,.=i- - , ili iil: l+9
August 1,2022
Via Email Submission
s e cre ta ry@1t u c. i da h o. gov
Ms. Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Ste. 201-A
Boise, D 837L4
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
Agree,ment along with the Unbundled Network Elements QNEs) - Resale Forbemance
Amendment to the lnterconnection Agreement between Qwest Corporation dba CenturyLink QC
("CenturyLink") and ACN Communication Services, LLC forthe 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
Re:
9ry/"*f/k
Josie Addine6n
Legal Assistant
Attachments
cc: Service List
1600 7r' Avenue, Floor 15
Seattle, Washington 98191
206-806-7339
[e-mail]
William E. Hendricks, Iil (WSBA#297 86)
Lumen
902 Wasco Street
Hood River, OR 97031
54t-387-9439
Tre.hendricks@lumen. com
Amr,rc.lrroN or Qwnsr CoRpon lrroN DBA
Cnrvrunvl,m< QC Fon ArpnovAl oF AI\
AupxoupNT To lxrnncoxxpcTloN
AcnnnprBnr wITIr ACN CoITIMUNICATIoN
Snnvrcns, LLC PunsuANT ro47 U.S.C.
$2s2(e)
BEFORE THE IDAIIO PTIBLIC UTILITIES COMIVtrSSION
CASE NO.:
APPLICATION FOR APPROVAL OF
AMENDMENT TO INTERCONNECTION
AGREEMENT
Qwest Corporation dba CenturyLink QC ("CenturyLink") hereby files this Application
for Approval of Amendment to the Interconnection Agreement. The Interconnection Agreement
was approved by the Idaho Public Utilities Commission on November L7,2003 under Order
No. 29380 (the "Agreement"). The Unbundled Network Elements (tINEs) - Resale Forbearance
Amendment ("Amendment") between CenturyLink and ACN Communication Services, LLC
("ACN Communication Services") 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 carrier not a party to this
AppLtcattoN FoR AppRovAr or AuruouENT To INTERCoNNECTIoN
AcRrs[,rrNr [ACN ComawtcArloN Srnvtcrs, LLC] - Page 1
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 ACN
Communication Services 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 1't day of August,2022.
CENTURYLINK
William E. Hendricks, III
Attorney for Qwest Corporation dba
CenturyLink QC
Appltcenou FoR AppRovAr- or AusNnvrENT To INTERCoT.INECTIoN
AcREEMENT [ACN CoMMr.rNrcArroN SERVrcEs, LLC] - Page 2
CERTIFICATE OF SERVICE
I hereby certiff that on this l't day of August,2022,I senred the foregoing
APPLICATION FOR APPROVAL OF AMEI\DMENT TO TIIE INTERCONI\IECTION
AGREEMENT upon all parties of record in this matter as follows:
JanNoriyuki, Secretary
Idalro Public Utilities Commission
Dave Stevanovski, President
ACN Communication Services, LLC
Via Email:
secretarv@puc. idaho. gov
Via Email:
[e-mail]
a"*r' A6{/k
losie,(<Hinlton /
Apprrcrc.rroN ron Appnover oF AMENDMENT To INTERCoNNECTIoN
AcRsrMENr [ACN CowtutttcArloN SERVIcrs, LLC] - Page 3
Unbundled Network Elements (UNEs) - Resale Forbearance Arnendment
to the lnterconnection Agmement between
Glwest Gorporation dba CenturyLink QG
And
ACN Communication Seruices, LLC
for the State of ldaho
This is an Amendment ('Amendment') to the lnterconnection Agreement between Qwest
Corporation dba GenturyLink QC ("CenturyLink'), a Colorado corporation, and ACN
Communication Services, LLC ("CLEC'). CenturyLink and GLEC shall be known jointly as the
"Parties'.
RECITALS
WHEREAS, the Parties entered into an lnterconnection Agreement ("Agreemenf) for service in
the state of ldaho which was approved by the Commission on November 17, 2fi)3; 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. 1&141, et al(the "UNE Transport Order'), which became
effective upon release; and
WHEREAS, on August 2,2019, the FCC released Order FCC 19-72, a Memorandum Oplnion
and Order in WC Doc*et '18-141 (the "UNE Analog Loop and Resale Forbeanance Ordef),
which became effective upon release (together, with the UNE Transport Order, collec,tively
refened 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 contiained 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 Attachment 1 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 shal! be deemed effec{ive upon approval by the Commission, or by being
permitted to go into effect by operation of law; horever, the Parties may agree to implement the
September 2, 2021lnap-alslNegotiated/UNE-Resale Forbeanance Amd/ACN Gommunications/lD
Q Amendment to CDS{31 022{005 (v.01.22.20204)
1
provisions of this Amendment upon execuffon.
FurtherAmendments
Except as modified herein, the provisions of the Agraement shall remain in full folpe and effect.
The povisions of this Amendment, induding the prwisions of this sentenoo, may not be
amended, modified or supplemented, ard waivers or consents to departures from the prwisions
of this Amendment may not be given without the written onsent thereto by both Parties'
authorized representrative. No waiver by any Party of any defauft, misrcpresentiation, or brcacfr
of wananty or @venant heleunder, whether intentional or not, will be deemed to extend to any
prior or subsequent default, misreprssentation, or breach of wananty or @\renant hereunder or
atrect in any wey any nghts arising by virtue of any prior or subsequent such o@ur€noe.
Entlro Aorcement
The Agreement as amended (including the documents refened to herein) constiMes the full
and entirc understanding and agreement betrreen the Parties with regard to the subjects of the
Agreement as amended and supercedes any prior underctandings, agreements, or
representaUons by or botween the Parties, written or oml, to the extent they rclate in any way to
the subjeds 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 rtfiich is deemed an odginal, but all of which shall
constihrte one and the same instument.
ACN Communlcatlon Serulcec, LLG Qrest Corporatlon dba CenturyLlnk QG
daas*etnrpusli trni*b t- Pot*idestmnoEli (SGp 7,2021rft{s EDT}Ki'nberlyTPoffi (5ep 29, 2021 06:05 CDT)
Signature
Dave Stevanovski
Signature
Kimberlv J. PoMrk
Name Printed/Typed
President
Name Prinbd/Typed
Sr. Dir. Bus. Oos Wholesale Sales
Ti0e
Sep 7,2021
Title
Sep 29,2021
Date Date
Sepbmber 2, 2021lnap-als/Negotiated/UNE-Reale Forbeanance Amd/ACN CommunbationsflD
Q Amendment to CDS{31 022{005 (v.01.2,.202041
2
ATTACHMENT 1
ATTACHTENT I
1. Resale Provislons - Pursuant to the Forbearance Orders, CLEC's ability to order new
services and retrain existing services ftom CenturylJnk for resale pursuant to Sec'tions 6,
induding Dircc'tory Listings and Directory Assistance that pertain to Resale, of the
Agreement are altered as follows:
a. Efiectlve Date to February 2,2020 - During the time period ftom 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 servi@s, also pursuant to
the applicable terms of the Agrcement, until February 2,2020.
b. February 2,2020 to Angust 2,207n - After February 2,2020, CLEC cannot
order any services for resale ftom CenturyLink pursuant to the applicable
provisions of the Agreement. Any oders for neur services br resale will be
pursuant solely to the terms of the applicable Tariff for the service including any
ICB agreemenE entered into underthe 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 wi!!
continue to provide such Existing Resale Services pursuant to the terms
of the Agreement, induding any discounb delineated in Exhibit A of the
Agreement.
ii. CLEC cannot make any changes to such Existing Resale SeMces, as
they will be treated in a'gnandfather€d' status, wtth continued receipt or
disconnec'tion of the Existing Resale Services the only options under the
Agreement available to CLEC. lf CLEC issues an order to change sudr
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 fiom CenturyLink after February 2,2020. CLEC
agrees that it is the CLEC's responsibility to ensure that no further orders
br resold services under the Agreement are submitted afier February 2,
2O2O. lf resold seMces are ordered after February 2,2020 CLEC agr€es
that the Agreement is no longer in effect and resold seMces are being
ordered per the applicable taffi 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
conduc't an audit of GLEC's order activity after February 2,2020,
in order to identify any mistraken instiances of attempting to order
resold services under the terms of the Agreement.
2. Should such instianoes o@ur, the Parties further agree that
CenturyLink may issue a bill using the effiective date of the
changes that the applicable service riras originally ordered
("Resale True-Up Bill") removing the dlscount for such services
and billing under the Tariffs at full tariffed pries. CLEC agrees
Sepbmber 2, 2021lnapals/D.legotiated/UNE-Resale Forbeanance Amd/ACN Cornmunbations/lD
Q Amendment to CDS{31 022{0OS 1v.01.22.2O2041
3
ATTACHMENT 1
not to contest such Resale True-Up Bills unless sucfr billing is not
consistent with the applicaUe Tariff.
c. After August2,2022- The Parties agree that CenturyLink will no longer provHe
any Existing Resold SeMces under the terms of the Agreement after August 2,
2022. CLEC is solely rcsponsible for either disonnecling 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 $,hich CLEC may order and maintiain Analog Unbundled Loops, as
defined in Sec'tion 9.2.2 provkled in the Agreement and TvruWire/Four-Wire Unbundled
Distribution L*p, as provided in Section 9.3.2.1.1 of the Agreement (together, refened
to as Analog Unbundled Loops') are altered as follows:
a. Effiactlve Date to February 2,2020 - During the time period from the Effedive
Date of this Amendment until February 2, 2020. CLEC may order Analog
Unbundled Loops pursuant to the applicable terms and conditions of the
Agreement. ln addition, CLEC may make changes in existing Analog Unbundled
Loop anangements, also pursuant to the applicable terms of the Agreement.
b. February 2, 2020 to Auguet 2,207n - Afier February 2,2020, CLEC cannot
order any Analog Unbundled Loops fiom 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 will continue to provide such Existing Analog Loops pursuant
to the terms of the agrcement, induding the applicable rate delineated in
Exhibit A of the Agreement.
ii. CLEC cannot make any cfianges to such Existing Analog L*pr, as they
will be treated in a 'grandfathered" stratus, 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 sucfr
services, it will be treated as a @nversion to Special Access services
being proMded solely under the Tartffs, nather than under the Agreement.
iil. CLEC agrees that it wil! no longer submit any orders for Unbundled
Analog Loops under the Agreement ftom CenturyLink after February 2,
2020. CLEC agrees that it is the responsibility of the CLEC to ensure that
no further orders for sucfr Analog Unbundled Loops under the Agreement
are submitted after February 2,2O2O.
1. ln order to ensure compliance with these provisions, the Parties
agree that GenturyLink, on a no more than quarterly basis, may
conduc't an audit of CLEC's order ac'tivity after February 2,2O2O,
in order to identify any mistaken instances of attempting to order
Analog Unbundled Loops under the terms of the Agreernent.
iv. Should such instranoes oocur, the Parties further agree that CenturyLink
will request CLEC to disconnec't such services and order them as new by
ordering the SpecialAccess service under the applicable Tariff, changing
Sepbmber 2, 2021/nap-als/tlegotiated/UNE-Resale Forbeanance Amd/ACN Communbatione/lD
Q Amendment to CDS{31022{005 (v.O1.22.202041
4
ATTACHMENT 1
the applicable rate charged, and CenturyLink may issue a bill using the
effec{ive date of the cfianges that the applicable Unbundled Analog Loop
was originally ordered ("Analog Loop True-Up Bill"). CLEC agrees not b
contest such Analog Loop TrueUp Bills unless sucfr billing is not
consistent with the applicable Taffi.
v. CLEC agrees that any provisions in the Agreement that provide for Line
Splitting or Loop Splitting are also removed and may no longer be
ordered, as they all involve an order of an Unbundled Analog Lmp. Any
existing arangoments will be maintrained durlng the time period of this
section.
c. After August2,2O22 - The Parties agree that CenturyLink will no longer provide
any Unbundled Analog Loops under the terms of the Agreement afrer August 2,
2022, induding any arangements for Line Spliftlng or Loop Splitting. CLEC is
solely rcsponsible for either disconnec{ing suctr Analog Unbundled Loops prior to
August 2,2022 or converting them to a service under the applicable Tariffs. For
anyAnalog Unbundled Loops in place as of August2,2022, CLEC agrees that
CenturyLink will convert any such Analog Unbundled Loops to the appropriate
Special Access service under the applicable Tariff, and CLEC is then responsible
for suc{r 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 sucfr
charges and will not dispute application of such charges neoessary for the
conversion. As Line Splitting and Loop Splitting are not available seMoe under
GenturylinKs Tarifts, CLEC must convert to alternative arangemenb that meet
its needs, as such arangements will otherwise be terminated after August 2,
2022.
d. Aternatlve Analog Unbundled Loops Commercial Arrangementr - The
Parties understrand and agree that the Forbeanance Orders specifically permit
altemative commercial anangemenb for the provision of UNEs that are impacted
by the Forbearance Orders. Nothing in this Amendment either rcquires
CenturyLink to enter into such altemative arangements or prohibits the Parties
ftrom reaching an agreement on terms and conditions of such altemative
anangements. The Parties agree that nothing in such altemative anangement
would ever be intended to change any of the obligations under this Agreement,
ratherto be in parallelto the terms and conditions of the Agreement.
e. UNE GombinaUons - Any UNE Combinations prcvided under the Agreement
that might indude 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 fuDlf), 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,
refened to as'UNE Transport') are altered as follows:
a. Effiectlve Date to January 12,2O2O - During the time period from the Etrective
Date of this Amendment until January 12,2020, CLEC may order UNE Transport
pursuant to the applicable terms and conditions of the Agreement. ln addition,
Sepbmber 2, 202'llnap-als/Negotiated/UNE-Resale Forbeanance Amd/ACN Communica$ons/lD
Q Amendment to CDS{3102-@05 (v.01.22.202041
5
ATTACHMENT 1
CLEC may make changes in existing UNE Transport amangementrs, also
pursuant to the applicable terms of the Agrcement.
b. January 12,2020 to July 12,2O7n - After January 12,2O2O, CLEC cannd 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 rvebsite: htto://www.centurylink.comArholesale/clecs/nta.hfnHUNE-F
to this Amendment ('Forbearance UNE Transporf). 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 Agrcement,
including the terms under $fiicfi it may be withdrawn.
i. For any Forbearanoe UNE Transport prccured 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, induding the
applicable rates delineated in Exhibit A of the Agreement.
ii. CLEC cannot make any changes to such Existing UNE Tnansport, as they
will be treated in a 'grandfathered" stiatus, wtth continued receipt or
disconnec*ion of the Existing UNE Transport the only options under the
Agreement available to CLEC. lf CLEC issues an order to cfiange sucfi
serui@s, it will be treated as a @n\rersion 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 br Forberanoe
UNE Transport under the Agreement from CenturyLink after January 12,
2020. CLEC agrees that it is the CLEC's rcsponslbility to ensure that no
further orders for such Forbearance UNE Transport under the Agrcement
are submitted afler January 12,2020.
1. ln order b ensure compliance with these prcvisions, the Parties
agree that CenturyLink, on a no more than quarterly basis, may
conduct an audit of CLEC's oder actMty after January 12,2O2O,
in order to identify any mistraken instiances of attempting to order
Forbearance UNE Transport under the terms of the Agrcement.
2. Should such instran@s o@ur, the Parties further agree that
CenturyLink will conwrt such services to the Speclal Access
service under the applicable Tariff, changing the applicable rate
charged as needed, and issue a bill to make the effec{ive date of
the charges be the date the applicable Forbearance UNE
Transport was originally ordered fUNE 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 12,2O7n - The Parties agree that CenturyLink will no longer provide
any Forbearanoe UNE Transport under the terms of the Agreement after July 12,
2022. CLEC is solely responsible for either disconnecting such Forbearane
UNE Transport prior to July 12, 2022 or converting to Special Amss service
under the applicable Tarift. For any Forbearane UNE Transport in place as of
July 12,2022, CLEC agrees that CenturyLink will convert any such Forbearance
Septembar 2, 2021lnap-alelNegotiated/UNE-Resale Forbeanance Amd/ACN Communications/lD
Q Amendment to CDS{31 022{D05 (v.01 .22.2020.4)
6
ATTACHMENT 1
UNE Transport to the appropriate Special Access service under the applicable
Tariff, and CLEC is then responsible for sudt services under that Tariff. ln
addition, should any charges be neesary as part of that conwrsion, CLEC
agrces that it is responsible for payment of such cfiarges and will not dispute
apflication of such charges neoessary for the conversion.
d. Aternatlve UNE Transport Gommerclal Arrangements The Parties
understiand and agree that fie Forbearance Orders specifically permit altemative
commercial anangements for the provision of UNEs that are impac'ted by the
Forbearance ffiers. Nothing in this Amendment either requires CenturyLink to
enter into such altemative anangements or prohibits the parties ftom reaching an
agreement on terms and conditbns of such altemative anangements. The
Parties agrce that nothing in such altemative arangement would ever be
intended to change any of the obligations under this Agreement, raffrer to be in
parallel to the terms and conditions of the Agreement.
Saptember 2, m21lnapals/tlegotiated/UNE-Reale Forbeanancs &nd/ACN Communbatims/lD
Q tunendment to CDS-031022{XD5 1v.01.22.20204)
7
ErhSltA
ld.ho
E lrl.ct Trrila
Ilrr trrD
'!aourilrg
Rmll'hg
P.r 5.ton
RGltrhe
-Ito =HaoI
-,o
t0 NTJ.Wffi
[Xrcqntturgf.e.
R.culrhgClm
Whdab
Oaodrthtilf.ee
ildra(ln*rgClIm
!.
B-l.t Sdrtsn lddb
tlt slLl lln tr ,5lr lr ,5rf
t_1-12 BarhUl.nm r.dn-r Lhai srba le.B*t825*B.D.E B-D.Eil_13 tE25*1E.5t
.1.1.4 dmrSo.d 1825*1e.a*
Ll-1.5 1A zflL ta 25*
tla t625!r 1e*
Lt^1.7 5ortb. S6da, Dhev Arhimd aClSrDA!18,25*l825rl B.D.E
I ta m-l*1.6#6.6SX B.D.E B.D.E
Lt-t-e o-tb*o-mtx B.D.E B.D.E
1.1_2 fimld,o
.1.2.1 imrb.te37r t037x B.D.E B.D.E
*1_22 t9 37t .t9
.1.2:'le-s,|r t93i7rx
t-1.LI le 3ilr ts3ru
126 Lilm CflFd lm t9.s1r 19374
.1-2-6 dr/!t l.lD lelrt*re37x B-D-E B.D.E
N1.7'{l dvL!to t7*IT 5,tI
.l.zE 6.eilf c-e7x B.D.E B^D-E
8.1-2-9 o IIt*o flt*
ut
21
2.1-1 MdilIl
l, 111 n 3tt
R' 1-1-2 E drAdb.dltx gtzt B.D^E
82.12
21rn ID 30,83 B.D.E
2-12-2 fi.12 B.D.E
a2-2 I
2)1 l!|&81 B.D.E
B2-22 Addlbml CIUIL rclaill^ .mCSR llis!
B-2-3 raa n,t
E2-t -grl2.1.1 -WIrVobe G[
D2-l -l-l zffi1 rl5
,11U h *ra-?I D.E *T
82.1_1-t Zd[ 3 tro.
c21.2 I
21.3 a"Whrv6bGr
D2t_3_l m lltll
,147 h t/l6.63 D.E. **
8.2-r3-3 Zon 3 araaT
92.1 l.oP ldeldon Cfiargot br 2 & +WL. An log boF tvhG onduonhg b noatulrrd.588.2.1 &
t2_2
D.E
s.2.4.1 n
1t24.1.1 311-m AD.E
a-2.a.1.2 E drAddillMl ra lt7
24,
92t2-1 FIrt j17_7
e2ta2 38S AD.E
.2.1.3 s2la,l 3141 47
,LA'S'a-m D.E^Jt2.1t Corffid lrd.Iddl 'iilrou Coop..drr T.drg , Pr1C.d C@fiffillfbLtldr
,-2aa,l s5e.81 D.E.*
.2.14-2 lEt32 D- E.I
,2.a5 Btb hrfeletdrrdhCffil
?l5a i112_10 D. E-*
9-2.4-6-2 Eedr ArHlfdrrl rga
c-3.1
.3.1-l Lrt lloT
r.3.12 Edr lddtord Srro nFle3t3
Frgp f of3
ErhlutA
ldaho
.1 lTj,!6 all m T!E S
s16.70 D.E. #j2t *t DEI
9I Blran.d I
0-a-1
4.2 LIno Sdltl I
9-1.2.1 to I:t3.78 o.E.tga3lroo sdltutg-tt-3-l E $r3.
9L.33-23 D.EI
e.a Unb[ndLd D.dlc.hd lnt E
.6.t t,SO UD]T lo FD€d & I'€'j2al ta B.D E
ta 1 1 chffoto8 Mlh c,L.a7 3iJ-m B.D.E B.D.E
t.6.12 6l t2a-60 fi.23 E.D.E B-D.E
e8l3 32.[.86 t0.15 B.D.E B.D.E
alL 6t t24_6S 3I)-05 B.D.E B,D.E
e.8.2 t2E/t.5i
8.6.2.1 ffOtoSMlh llla_43 33.2n B.D.E B.D.E
9.4.2-2 vler 117 r-3 EDE EDEeraChar25to5O Mllea iilo.12 31.81 B.D.E B.D.E
9-8.2-1 *17 7,t07 EDE BDE
0.8-3 'i,f,/.ait B.D.E
.6.3-t Dt68 Mlh 3238.81 33t.07 B.D.E B,D-E
D.6 3,2 tit12.B s18.7
8.6.3.3 EI s223-e0 t21.U B-D.E B.D.E
0-8-3-.1 Crver tit35.64 r14.E3 B.D.E RDF
a.a UXE Goilr
9.4.2.1
rthn11.t I FlEl t245.1 I D.E-'
1-Eedr,.ldltonal t{n 07
sls a5
zffi2 3i13.78 D. E.15
2a I m aao 5n D E.I5
g7-142 EELlm. OSOCWlnAmbd
||tFFl a-tElff rtbr
Flrst l2$.1'l
Eedr AddflbDl 3182-07 D.E,1
3!n_m D. E- t5
?2 I taa ait
Zone 3 379-11 D. E. l5
9.2t.2.1 ELL
11 3EnO-aS D.EI
EadrA.Hltoml 1225.33
I rne 'l sE6.rtEZN2388.46 D. E. t5
m tm DEIS
24, B EELREmrffit
3t30.83 o.E.12
ll116.5l
s.?3-2-a EEL M
$l8s.g24E..DEI
I?N.D
'iua-92
B.D.E D.EI
g-23.2-9 mhd
st3.t0 B.D.E)tDs{ ,lfl anmlt2rlkh
':r.t7
B.D.E
I
9.25_1
,51 .l LMC 2-WlE lBt lLdm
98 5.67 D.E.I
staa DEI
25.1.2
s.%.1.-1 lzoi,€'lts 65 D_ E- t5
szl.76
3 17,,'m Lo.50 D. E_ l5
,2E2 tmMrrGW|EAmbo
.2.1
tiri,s a7 D.E-'
t148.98
9.25.2_2 rm al* trh 3l
$m.702 lz.m 3/le-8ll D. E. 15
Pa0p 2 of 3
E rb[A
l(ED
195-)^t lrltt Jrttt D.E16
to.3.z ftsdun,ftlrryl.bfhg!griit
Edrf,rg!
IJilR.a.,L6lYhdr*
DLount
rrffl
Erdr.rE!
f.rl' Rd.,l-6
Whoar.h
OLcdrnt
o.E D.E
t:
rt llrt
D Ih. F.d..d Cofiilnlc.ton Coffitrlon (th.. .Fcg a lo.mlr.lorf) rda.d olld.r FCC lgao, . Reort and d.r m R.lllnd .nd Mrndrrdun
ophh fld (mr h YYC Doctrt ]{6. l&141, a d Or Uf{E Til.-po.r d..'I rnd o Aaurt t 2019, r*d ffir F@ llZ2, e tl..rundm
ophbn ttd Od.. h WC Dcld 1&l4f OE UIG An log Lo$ .ri Rrd. Foltrm dr') dfdl -.!d Ciilryllrlcr oile.0s! b Frvld. cf,i5n
mund.dn lwt.L.trnt. A..txdt..iyItattl[rtI3bdrfi.[drdblodySl..bUlEriR..ddrtlcc.coo.rllebfi.frtrl.dtlx
UtG,R-d. Fort .rurc. Arlndndrt d ttr Aommmt Any nte wm lhb botrotc b no E grr Slc.bL h .ny u,!y db. Augu.t Z 2A2, .e,fri
E Ih. rt h tt ffi .ppty .d.ty b .r.r,la (r'dGd h U]E/R.* cn a btbrt F.tnry e 20eI1. Any r.u tan lar h UtC/Rd hccrc[y odrrdtrbrF.bru.ry2,2mrlndbv!t,trd.drt orrttr.eplc.trlrh$btttlr,h,tl[bdx,lb.atF.lbt,I.Dpht5dt,prlc.Sorcrt&g
i.mrd lhItil, Rlb R.da{m- Dod(d USIIV-T&g- fr.{ri Mtftl- Rrddm rdEt d h tr. rrlorfil Eirllt A.
t IERICrlfaFugodhCdDod(rtQwEl{l.llffirooyt dqlNo\..tt r12,m. T|f,cr.nmr!.ldridtrltblJlhglhahotrfr]t
ffil LrF|lE)r{Atnl.Hd
.12 d-m
t5
P.gp 3 ot3