BEFORE THE NEW MEXICO PUBLIC REGULATION COMMISSION
IN THE MATTER OF THE PETITION OF CENTURYLINK )QC TO INITIATE A RULEMAKING TO IMPLEMENT )SENATE BILL 53 AND TO ADOPT EMERGENCY RULES)
Case No. 17-00186-UT
THE ATTORNEY GENERAL OF NEW MEXICO’S RESPONSE TO CENTURYLINKQC’S PETITION FOR RULEMAKING TO IMPLEMENT SENATE BILL 53 AND TO
ADOPT EMERGENCY RULE
Introduction
The Office of the Attorney General of the State of New Mexico ("OAG"), by and through
undersigned counsel hereby provides its response to CenturyLink QC’s Petition for Rulemaking
to Implement Senate Bill 53 and to Adopt Emergency Rule, which was submitted to the New
Mexico Public Regulation Commission ("the Commission") on July 25, 2017. As explained
below, OAG supports CenturyLink QC’s request that the Commission open a rulemaking
proceeding as soon as possible for the purpose of adopting rules to regulate carriers serving 50,000
or more access lines in New Mexico~ in compliance with recently-passed Senate Bill 53 ("SB 53").
That rulemaking should address not only retail pricing, but service quality and consumer protection
as well. CenturyLink QC remains the largest wireline carrier in the state by far and is too important
to the citizens and economy of New Mexico to be left in regulatory limbo. However, OAG also
believes that CenturyLink QC’s proposal that it be regulated on an emergency interim basis (until
final rules are established) by application of 17.11.9 NMAC is seriously incomplete and would fail
to offer adequate regulatory protections to CenturyLink QC’s customers during that interim period.
Instead, OAG recommends that the Commission exercise its emergency powers pursuant to
1 AGO note in passing that the Petition characterizes the sought-after rule as applying to "carriers that serve morethan 50,000 access lines" but in reality the post-SB 53 NMTA applies to "incumbent local exchange carriers thatserve fifty thousand or more access lines within the state" (see, e.g. 63-gA-5-B).
ATTORNEY GENERAL’S RESPONSE TO CENTURYLINK QC PETITIONUTILITY CASE NO. 17-00186-UT 1
NMSA 1978, Sec. 8.8.15.C to: (1) impose a temporary moratorium on retail local exchange rate
increases by CenturyLink QC until final rules compliant with SB 53 have been adopted, and (2)
apply the retail service quality and consumer protection rules contained in 17.11.24 and 17.11.25
NMAC, respectively, to CenturyLink during that interim period. These recommendations are
explained in more depth below.
CenturyLink QC’s Petition Fails to Address the Critical Need to Maintain Quality ofService Standards and Consumer Protections During the Transition to the Post-SB 53Regulatory Regime.
Prior to the statutory revisions to the NMTA brought by Senate Bill 53, mid-size carders
including CenturyLink QC have been subject to three Commission rules, governing three distinct
aspects of their conduct:
¯ Retail pricing: 17.11.23 NMAC (Retail Pricing for Mid-Size Carders);
¯ Service quali _ty: 17.11.24 NMAC (Quality of Service Standards Applicable to Mid-Size
Carriers); and
¯ Consumer protection: 17.11.25 NMAC (Consumer Protection Standards Applicable to
Mid-Size Carriers.
In its Petition, CenturyLink QC has suggested that 17.11.9 NMAC, which currently applies
only to the class of incumbent rural telecommunications carders (serving less than 50,000 access
lines), could serve as an interim replacement to "to fill the regulatory gap created by the
replacement of the regulatory construct formerly applicable to mid-size carriers... ,,2
However, 17.11.9 NMAC addresses only retail rates, terms, and conditions, as explained in its
subsection .6:
2 CenturyLink QC Petition, at para. 4.
ATTORNEY GENERAL’S RESPONSE TO CENTURYLINK QC PETITIONUTILITY CASE NO. 17-00186-UT 2
17.11.9.6 OBJECTIVE: The purpose of this rule is to implement NMSA 1978,Section 63-9H-7 by providing procedures for filing rates for new services andchanges in rates for existing services, and for protesting rate increases forresidential local exchange service.
Consequently, at best, 17.11.9 NMAC could replace only the first of the mid-size carrier
rules listed above, the retail pricing rule 17.11.23 NMAC. CenturyLink QC’s Petition fails to
suggest any replacements for the other two mid-size cartier rules, and in fact never even mentions
the key issues of service quality or consumer protection, other than alleging that all three mid-size
carrier rules "are no longer operative.’’3
The Attorney General believes this is a critical omission in CenturyLink QC’s proposal,
which leaves unfilled two-thirds of the "regulatory gap" that the company itself points to.
Commission oversight in the areas of service quality and consumer protection were key statutory
elements of the mid-size cartier regulatory regime4 formerly applying to CenturyLink QC since it
was reclassified as a mid-size cartier in April 2015,5 and the Commission retains its authority over
retail service quality and consumer protection issues in the post-SB 53 version of the NMTA.6
For many years, retail service quality standards and reporting requirements have been an
essential tool for ensuring that the CenturyLink QC’s services continue to have an acceptable
quality of service for those hundreds of thousands of residential and business customers across the
state who rely on them.7 When it was reclassified as a mid-size carder, CenturyLink QC accepted
3 CenturyLink QC Petition at para. 1. The Attorney General is not taking a position on the current legal status of the
Commission’s mid-size carrier rules (17.11.23, .24, and .25 NMAC) but does recommend that the Commissionclarify that status when opening the SB 53 compliance rulemaking.4 See NMSA 1978, Sec. 63-9A-5.1 as was effective until June 16, 2017, particularly subsections C(1)(d), F(1) and
F(3).5 NMPRC Case No. 14-00068-UT, Order Partially Adopting Recommended Decision, issued April 8, 2015.6 NMSA 1978, Sec. 63-9A-5.B(3) and 63-9A-5.B(4).7 See, e.g. NMPRC Case No. 09-00094-UT, Recommended Decision of Hearing Examiner, issued October 22,2009, at page 93 ("Quality of service rules and requirements have been a part ofQwest AFORssince the very beginning.") and pages 147-149; and Final Order issued April 8, 2015 (adopting AFOR III includingservice quality plan).
ATTORNEY GENERAL’S RESPONSE TO CENTURYLINK QC PETITIONUTILITY CASE NO. 17-00186-UT 3
the mid-size cartier service quality rule 17,11.24 NMAC without modification,8 and for over two
years it has filed service quality reports as prescribed by that rule.
In fact, that rule has continued to reveal substandard performance in certain areas -- notably
customer service representative responsiveness, during the eleven month span from May 2015
through March 2016, and as recently as April and May 2017.9 The chronic nature of CenturyLink
QC’s sub-par performance in that area1° makes it clear that competitive pressures alone are
insufficient to incent the company to correct these deficiencies. This strongly suggests that more,
not less, regulatory oversight of its retail service quality should be occurring, including
enforcement actions and tangible remediation steps in such circumstances. While those issues can
and should be taken up during the SB 53 compliance rulemaking, the Attorney General strongly
recommends continuation (or re-application, if found legally necessary) of the service quality
requirements contained in the 17.11.24 NMAC rule to CenturyLink QC on an emergency and
interim basis, until the rulemaking is concluded. ~
Another important consideration for their retention is that the post-SB 53 version of the
NMTA now requires the Commission to conduct triennial reviews of key issues including service
quality:
8 NMPRC Case 15-00054-UT, CenturyLink QC Petition for Rulemaking, May 26, 2015, at para. 4 ("For different
reasons, CenturyLink QC does not propose changes to the mid-size carrier rules regarding quality of service(17.11.24 NMAC) or consumer protection (17.11.25 NMAC) at this time. In order to simplify the transition fromAFOR regulation to mid-size cartier regulation, CenturyLink QC is proposing only minimal changes to the mid-sizecarrier rules, and thus proposes that the existing quality of service and consumer protection rules remain intact fornow.").9 See Attachment A to this Response, for the Access Monitoring Reports filed by CenturyLink QC pursuant to the
Commission’ s rule 17.11.24.13.B, for the months with substandard performance between May 2015 and May 2017.Source: NMPRC InfoShare 2000 website.10 The Attorney General is unable to comment on CenturyLink QC’s recent service quality performance in other
areas because its latest annual report pursuant to 17.11.24.8 NMAC, for year 2016, has not been posted publically onthe Commission’s InfoShare 2000 website. (We note that Windstream’s 2016 service quality report pursuant to17.11.24.8 NMAC is posted, with a receipt date of 2/3/17).~ The OAG is not taking a position in this Response concerning what final service quality and consumer protectionrules should be adopted in response to SB 53.
ATTORNEY GENERAL’S RESPONSE TO CENTURYLINK QC PETITIONUTILITY CASE NO. 17-00186-UT 4
Commission Review of Impacts: The commission shall review the impact ofprovisions of the New Mexico Telecommunications Act on residential andbusiness consumers in urban and rural areas of the state every three years, the firstreview to be completed by July 31, 2019, and shall report its findings to thelegislature. The review shall investigate the impact on rates, service quality,incumbent local exchange carrier employment, investment in telecommunicationsinfrastructure and the availability and deployment of high speed data services.~2
The Commission must continue its legacy service quality reporting requirements, including those
that have been applied to CenturyLink QC, in order to have the factual basis to conduct these
reviews.
In like measure, the Commission should not let consumer protection for CenturyLink QC’s
customers fall by the wayside, as the company’s proposal would do. Given that CenturyLink QC
has been operating under consumer protection regulations for many years, and the specific mid-
size carrier consumer protection rule, 17.11.25 NMAC, for over two years, it could not impose
any undue burden on the company to extend the latter’s application on an interim basis until the
SB 53-compliance rulemaking is concluded, which CenturyLink QC characterizes as a matter of
several months.13 Consequently, OAG also recommends that the Commission exercise its
emergency powers pursuant to NMSA 1978, Sec. 8.8.15.C to extend (or re-apply, if found legally
necessary) the consumer protection rules contained in 17.11.25 NMAC to CenturyLink QC on an
emergency and interim basis, until the SB 53-compliance rulemaking is concluded.
The Commission Should Impose a Temporary Moratorium on Retail Local Exchange PriceIncreases by CenturyLink QC on an Emergency Basis Until Final Rules Compliant withSenate Bill 53 Have Been Adopted.
As described earlier in this Response, CenturyLink QC has petitioned the Commission to
apply 17.11.9 NMAC to CenturyLink QC on an interim basis for purposes of regulating the
12 NMSA 1978, Sec. 63-9A (un-numbered material).13 Petition at para. 2.
ATTORNEY GENERAL’S RESPONSE TO CENTURYLINK QC PETITIONUTILITY CASE NO. 17-00186-UT 5
company’s retail pricing (including rates, terms and conditions).14 OAG believes that proposal is
too extreme, absent further limitations, because it would essentially pre-judge the outcome of the
rulemaking with respect to retail pricing. As soon as 17.11.9 NMAC was applied to CenturyLink
QC’ the company could immediately raise retail rates for any or all retail services other than
residential local exchange service, without limitation, on ten days’ notice.~5 For example, the
company could immediately increase its business local exchange rates, applying to New Mexico
businesses small and large, by $10 per month throughout its service territory, with no recourse by
the Commission or those customers, before the Commission even began the process of devising
an appropriate retail pricing rule compliant with SB 53. Residential local exchange customers
receive scant additional protections from unlimited rate increases as well under that rule. 16 Rather
than expose New Mexico consumers to potentially extreme rate increases before a final rule has
been adopted, OAG urges the Commission to establish a temporary moratorium on retail local
exchange rate increases by CenturyLink QC, pursuant to NMSA 1978, See. 8.8.15.C, until the SB
53-compliance rulemaking has concluded with the adoption of a finalized retail pricing rule.
Conclusion
For all of the reasons set forth above, OAG recommends that the Commission accept
CenturyLink QC’s request to open a rulemaking to devise rules to regulate carriers serving 50,000
or more access lines in New Mexico in compliance with recently-passed Senate Bill 53. However,
the Commission should specify that the rulemaking will address not only retail pricing, but service
quality and consumer protection as well. Second, the Commission should supplement
~4 Petition at paras. 4-7.~5 17.11.9.8.A N-MAC.16See 17.11.9.9 and 17.11.9.10 NMAC. OAG also notes that the standard for affected residential local exchangecustomers to file a protest of a noticed rate increase is not consistent with the standard established by the post-SB 53version of the NMTA (compare 17.11.9.B(4) vs. NMSA 1978, Sec. 63-9A-8.1.F).
ATTORNEY GENERAL’S RESPONSE TO CENTURYLINK QC PETITIONUTILITY CASE NO. 17-00186-UT 6
CenturyLink QC’s request for emergency, interim rules by taking the following steps, exercising
its emergency powers pursuant to NMSA 1978, Sec. 8.8.15.C:
(1) Impose a temporary moratorium on retail local exchange rate increases byCenturyLink QC until final rules compliant with SB 53 have been adopted;
(2) Apply the retail service quality and consumer protection rules contained in17.11.24 and 17.11.25 NMAC, respectively, to CenturyLink during that interimperiod.
OAG believes these steps will best protect the interests of New Mexico’s residential and small
business consumers during this crucial period of regulatory transition for CenturyLink QC, and
not impose any significant burden on the company.
Respectfully submitted,
OFFICE OF THE NEW MEXICO ATTORNEY GENERAL
DATED this 28th day of August, 2017.
ATTORNEY GENERAL’S RESPONSE TO CENTURYLINK QC PETITIONUTILITY CASE NO. 17-00186-UT 7
ATTACHMENT A
CenturyLink-
Johnny MontoyaState Government Relations Director400 Tijeras Ave NW5th FloorAlbuquerque, NM 87102Tel: 505-767-8510
November 25, 2015 ~n
New Mexico Public Regulation CommissionAttn: Records1120 Paseo De PeraltaSanta Fe, New Mexico 87504
RE: Rule 17.11.24.13.B. Timely Response by O~omer Service Representst_~ve~
Enclosed for filing are the orional and 5 copies of Qwest Corporation d/b/a CenturyLink QCAccess Monitoring Report for May - October 2015, filed pursuant to the Commission’s rule17.11.24.13.B. An electronic filing is also enclosed. CenturyLink Call Centers and ITdepartments are working on creating a report for the new metric of 95% in 15 seconds. Anelectronic filing is also enclosed.
Please call me if you have questions regarding this information at 505-767-8510.
Respectfully yours,
Q
II
CenturyLink-
Johnny MontoyaState Government Relations Director400 Tijeras Ave NW5th FloorAlbuquerque, NM 87102Tel: 505-767-8510
January 6, 2016
New Mexico Public Regulation CommissionAttn: Records1120 Paseo De PeraltaSanta Fe, New Mexico 87504
RE: Rule 17.11.24.13.B. Timely Response by Customer Service Representatives
Enclosed for filing are the original and 5 copies of Qwest Corporation d/b/a CenturyLink QCAccess Monitoring Report for November 2016, filed pursuant to the Commission’s rule17.11.24.13.B. An electronic filing is also enclosed. CenturyLink Call Centers and ITdepartments are working on creating a report for the new metric of 95% in 15 seconds. Anelectronic filing is also enclosed.
Please call me if you have questions regarding this information at 505-767-8510.
Respectfully yours,
z
f_.
Z
Z
--+ ~+
CenturyLink
Johnny MontoyaState Government Relations Director400 Tijeras Ave NW5th FloorAlbuquerque, NM 87102Tel: 505-767-8510
January 29, 2016
New Mexico Public Regulation CommissionAttn: Records1120 Paseo De PeraltaSanta Fe, New Mexico 87504
RE: Rule 17.11.24.13.B. Timely Response by Customer Service Representafive.s
Enclosed for filing are the original and 5 copies of Qwest Corporation d/b/a CenturyLink QCAccess Monitoring Report for December 2015, filed pursuant to the Commission’s rule17.11.24.13.B. An electronic filing is also enclosed. CenturyLink Call Centers andITdepartments axe working on creating a report for the new metric of 95%in 15 seconds. Anelectronic filing is also enclosed.
Please call me if you have questions regarding this information at 505-767-8510.
Respectfully yours,
z
Z
CenturyLink-
Johnny MontoyaState Government Relations Director400 Tijeras Ave NW5t~ FloorAlbuquerque, NM 87102Tel: 505-767-8510
March 7, 2016
New Mexico Public Regulation CommissionAttn: Records1120 Paseo De PeraltaSanta Fe, New Mexico 87504
RE: Rule 17.11.24.13.B. Timely Respor~e by Customer Service Representatives
Enclosed for filing are the original and 5 copies of Qwest Corporation d/b/a CenturyLinkQCAccess Monitoring Report for January 2016, filed pursuant to the Commission’s rule17.11.24.13.B. An electronic filing is also enclosed. CenturyLink Call Centers and ITdepartments are working on creating a report for the new metric of 95% in 15 seconds. Anelectronic filing is also enclosed.
Please call me if you have questions regarding this information at 505-767-8510.
Respectfully yours,
I
CenturyLink-
Johnny MontoyaState Government Relations Director400 Tijeras Ave NW5m FloorAlbuquerque, NM 87102Tel: 505-767-8510
’16141%R 22 PM1:44
March 22, 2016
New Mexico Public Regulation CommissionAttn: Records1120 Paseo De PeraltaSanta Fe, New Mexico 87504
RE: Rule 17.11.24.13.B: Timely Response by Customer Service Representatives
Enclosed for filing are the original and 5 copies of Qwest Corporation d/b/a CenturyLink QCAccess Monitoring Report for February 2016, filed pursuant to the Commission’s rule17. I 1.24.13.B. CenturyLink Call Centers and IT departments are working on creating a reportfor the new metric of 95% in 15 seconds. An electronic filing is also enclosed.
Please call me if you have questions regarding this information at 505-767-8510.
Respectfully yours,
m
CenturyLink-
Johnny MontoyaState Government Relations Director400 Tijeras Ave NW5th FloorAlbuquerque, NM 87102Tel: 505-767-8510
April 20, 2016
New Mexico Public Regulation CommissionAttn: Records1120 Paseo De PeraltaSanta Fe, New Mexico 87504
RE: Rule 17.11.24.13.B. Timely Response by Customer Service Representatives
Enclosed for filing are the original and 5 copies of Qwest Corporation d/b/a CenturyLink QCAccess Monitoring Report for March 2016, filed pursuant to the Commission’s rule17.11.24.13.B. CenturyLink Call Centers and IT departments are working on creating a reportfor the new metre of 95% in 15 seconds. An electronic filing is also enclosed.
Please call me if you have questions regarding this information at 505-767-8510.
Respectfully yours,
. Montoya
Z
CenturyLink-
Johnny MontoyaState Government Relations Director400 Tijeras Ave NW5th FloorAlbuquerque, NM 87 t 02Tel: 505-767-8510
May 10, 2017
New Mexico Public Regulation CommissionAttn: Records1120 Paseo De PeraltaSanta Fe, New Mexico 87504
RE: Rule 17.11.24.13.B. Timely Response by Customer Service Representatives
Enclosed for filing are the original and 5 copies of Qwest Corporation d/b/a CenturyLink QCAccess Monitoring Report for April and May 2017, filed pursuant to the Commission’s rule17.11.24.13.B.
Please call me if you have questions regarding this information at 505-767-8510.
Respectfully yours,
Jl~rectorLs~~ nt Relations
NEW MEXICO RULE ].7.11.22.20.B TIMELY RESPONSE BY CUSTOMER SERVICE REPRESENTATIVES - MARCH 20:L7
METRIC DESCRIPTION
MARCH 2017
REMEDIAL ACTIONRESULT STANDARD REASON FOR FAILURE TAKEN
KNOWN RESULTS OF THEREMEDIAL ACTION
Average Wait Time. RES
Average Wait Time ÷ BUS
55.21 35
76.18 35
¯ Staffing continues to be achallenge. Some centers have ¯ A strong focus on handlingseen increased handling times times in retention, staffing
with their new hire classes levels and continued classescoming online. Call handling based on call volumes and
times missing goal primarily due attrition. Mandatory overtimeto the new tenure of Retention being scheduled on Mondays
agents. Monday volumes and voluntary overtime beingcontinue to impact the overall offered as needed.
monthly result.
¯ For Consumer, April continues tobe a struggle. Smali Business, from4/1 - 4/21, is meeting the objective
at a 20 second ASA.
Average Wait Time - REPAIR 4.3 35
Blanks in the report indicate no activity for the measure. I of 1
NEW MEXICO RULE 17.11.22.20.B TIMELY RESPONSE BY CUSTOMER SERVICE REPRESENTATIVES - APRIL 2017
METRIC DESCRIPTION
Average Wait Time - RES
APRIL 2017
REMEI~AL ACTIONRESULT STANDARD REASON FOR FAILURE TAKEN
~0.02 35
.... ¯ Strong focus on staffing levels¯ ~onsumer expenennao system and continued classes basedimpacts in Apdl some of which on call volumes and attrition.
ocour~d on Mondays.Mondays, due to volumes being25% higher than any other dayof the week, continue to impact
the overall monthly result.Towards the end of the month,
an WR change wssimplemented significantly
impacting call volumes in thecustomer Care group.
Several Retention teams wereconve~tad to Care poet IVRdeployment. Additional Carestaffing adjustments will bemade based on ongoing calldata analysis. Mandatory
overtime is being scheduled onMondays in addition to
additional votantary offers onMondays.
KNOWN RESULTS OF THEREMEDIAL ACTION
¯ Consumer ASA at the beginningof the month is not meeting the
standard primarily due to theongoing systems issues.
Average Wait Time - BUS 34.83 35
Average Wait Time - REPAIR 4.4 35
Blanks in the report indicate no activity for the measure. I of I
BEFORE THE NEW MEXICO PUBLIC REGULATION COMMISSION
IN THE MATTER OF THE PETITION OFCENTURYLINK QC TO INITIATE ARULEMAKING TO IMPLEMENT SENATEBILL 53 AND TO ADOPT EMERGENCYRULES
) FILED IN OFFICE OF) /~UG 2 8 2017) CaseNo. 17-00186-UT) N.X,1 PLBLI£ REGULATION COMM)
RECORD5 ’ ~ ~NA6E~IENT BURE-~U
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of The Attorney General of New
Mexico’s Response to Centurylink QC’s Petition for Rulemaking to Implement Senate Bill 53
and to Adopt Emergency Rule, was sent via email and first-class mail on August 28, 2017, to the
following parties:
Marco E. GonzalesMitchell F. BrecherDebra McGuire- MercerCarol CliffordJohn BadalPatricia S-IvesDavid LafuriaTimothy ShafferyJeffrey AlbrightBrimey LloydBobbie J. CollinsRohan RanarajaAmanda EdwardsLoretta BacaCarla BondRichard ZarateJean SnopkowskiAlan P. MorelAnthony SmithCecile ArchibequeDale LamanLourdes VifiasMarcy GuillenMark CostlowMary Beth CicalaMatthew HooverMichael LeybaLynn E. MostollerKirk LeeSharma PurcellDonna DanielleLinda Dallaero
[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];j [email protected];[email protected];[email protected];[email protected];[email protected]@twncorp.com;[email protected];[email protected];[email protected];[email protected];mj [email protected];[email protected];[email protected];[email protected];[email protected];[email protected];
Cheryl C. PowersGary RodhamPatrick D. CrockerMichael BagleyDave ComaCurtis HopfingerMaria GrahamDavid BaileyLance SteinhartPeggy BrieshLeo BacaDanielle FrappierLisa TatldrSusan CockerhamJohn JenningsKate DuttonKeith NussbaumJohnny MontoyaJerma BrownJennifer KeenKelly HebbardLakisha TaylorKaren KilgoreN. BurslemR. HannaMelanie O’ReillyMichelle AustinKasey C. ChowGayle GoukerWarren FischerScott Lnndquist-nmagRussell Sarazen
[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];peggybvtonly@bacavalle¥.com;[email protected];[email protected];Dave. coma@t-mobile, corn;[email protected];jj [email protected];[email protected];[email protected];Johnnv.Montoya@centur~link.com;[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];
Mary HopePaula FoleyCarol ValdezHerve AndrieuJerry NussbaumWilliam CabralDarneshia SmithMarsha PokornyAnnabelle PachecoDanny GrayTeri OhtaGene DeJordyGeorge ClarkGerald F. ZollarsGodfrey EnjadyJace ColbertJack PestanerJenica L. JacobiJane YeeJeremy SmucklerJessica MatushekJohn ClarkJon BrintonJules CoffmanKelley WellsKevin BartleyNick KyriakidesRalph DichyJerome BlockLuther EakinsLeon NailScott KlopackSharon ThomasJane HillZianetJessica RennekerDan WheelerAlan HermanDavid RobinsonSteve GattoMark A. OzanickCourtney SpearsGil ArvisoKelly FaulAmy GrossR. GavidiaTom OlsonArt HullSharon MullinShawn HansonSherry BoydSonia MendozaScott KlopackBrian GilbertStanley SmithSteven Chernoff
[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];j [email protected];[email protected];ion [email protected];[email protected];[email protected];[email protected];[email protected];rdich¥@mettel.net;j [email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];kell¥[email protected];[email protected];[email protected];[email protected];arthull 1 @gmail.com;[email protected];[email protected];[email protected];[email protected];[email protected];[email protected]@j oneswalker.com;[email protected];
Kenneth SchifmanSandra SkogenBrian GilbertKyle J. SmithTim GoodwinEdwin ReeseBill TemplemanDavid ZieglerJudith A. RileyCatherine HannanEddie MishanJoan M. EnglerD. JamesG. CookmanKen DawsonM. GruenhutGeorge ThomsonTrudy LongneckerRaymond CowleySonya BlackwellBrian GilbertCatherine NicolaouSharon PorterRichard MontoTroy JuddVictoria WilliamsWilliam E HuntJanice BadalDonna DanieleKitty J. CraemerVirgil BarnardJohn FrancisJennifer DwanJean ParkerMatthew FordLeo GarzaLauna WallerJames Boyd EvansJanice OnoJuan SaenzMark LammertCharles FerrellWayne GibsonMaria SanchezAllison BloomDale SniderChristopher CollinsJavier RodriguezSteven D. MettsJoan Ellis-PRCEugene Evans-PRCRussell Fisk-PRCKen Smith-PRCMark Cessarich-PRCMike Ripperger-PRCGeorgette Ramie-PRC
[email protected];[email protected];[email protected];[email protected];[email protected]@verizonbusiness.com;[email protected];[email protected];[email protected];[email protected];[email protected];j [email protected];dj ames4485 @cybermesa.com;[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];j cbadal@sacred-windocom;dg [email protected];[email protected];[email protected];[email protected];[email protected];[email protected]:[email protected];[email protected];[email protected];[email protected];[email protected];[email protected];[email protected]@gmail.com;[email protected];[email protected];abloom@ldxx:com;[email protected];[email protected];jrl [email protected];[email protected];[email protected];[email protected];[email protected];Ken.Smithl @state.am.us;[email protected];[email protected];[email protected];
2
Tim KeeferJoseph YarAlicia Armijo
[email protected];[email protected];[email protected];
Hank AdairRichard MatzkeBrad EllsworthEd Sema
[email protected];[email protected];[email protected];[email protected];
VIA FIRST-CLASS MAIL
Navajo Tribal Utility AuthorityWalter W. HaasePost Office Box 170Ft. Defiance, Arizona 86504
DATED this 28th day of August, 2017.
NEW M~XICO ~-~~ENERAL
Elaine G. Heltman, par/degal ~