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

aarmijo@nmag.gov

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

MEG@modrall.com;brecherm@gtlaw.com;mercerdm@gtlaw.com;carol@thejonesfirm.com;jbadal@sacred-wind.com;pives@cuddvrnccarthy.com;DLaFuria@fcclaw.com;tshaffery@cellularoneaz.com;JAlbright@lrrc.com;Bllovd@atni.com;BCollins@lrrc.com;Rranaraja@atni.com;AEdwards@lrrc.com;LBaca@lrrc.com;CBond@lrrc.com;rzarate@solixinc.com;j snopko@solixinc.com;apmpa@valomet.com;anthony@zianet.com;cecile@yuccatelecom.com;dalel@pvt.comlvinas@twncorp.com;mguillen@dellcity.com;help@swcp.com;mbc@tbtc.net;mhoover@kitcarson.net;mj leyba@lajicarita.com;lem@sutinfirm.com;Kirk.lee@ftr.com;sharma.purcell@vtc.net;Dgl612@att.com;Ldellaero@matrixbt.com;

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

verizonlongdistance@verizon.com;grodham@diversifiedconsulting.net;contact@nationwideregulatorycompliance.com;michael.baglev1@verizonwireless.com;regulatorycomplaints@broadviewnet.com;chopfinger@securustechnologies.com;maria_graham-baptist@cable.comcast.com;dbailey@bullseyetelecom.com;lsteinhart@telecomcounsel.com;peggybvtonly@bacavalle¥.com;Leo.baca@centurvlink.com;DanielleFrappier@dwt.com;Dave. coma@t-mobile, corn;scockerham@fastekteam.com;jj ennings@bigrivertelephone.com;regulatoryaffairs@accesspointinc.com;keith@preferredlongdistance.com;Johnnv.Montoya@centur~link.com;jbrown@vcomsolutions.com;support@cedarnetworks.com;khebbard@fasttrackcomm.net;lakishat@budgetprepav.com;kkilgore@cuddgmccarthy.com;ninaburslem@imagitel.com;hannalaw@windstream.net;mporeilly@matinetworks.net;maustin@cellularoneaz.com;kchow@telecomcounsel.com;ggouker@cellularoneaz.com;wfischer@qsiconsulting.com;Slundquist@qsiconsulting.com;russell.sarazen@t-mobile.com;

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

regulatorv@matrixbt.com;legal.request@elnk.com;cvaldez@montand.com;taxes@telna.com;preferred@aol.com;bcs@los-alamos.net;dsmith@acninc.com;m.pokorny@ildmail.com;apacheco@lajicarita.com;dgray@lajicarita.com;Teri.Ohta@t-mobile.com;gene@dakelvn.com;george.clarke@state.nm.us;jzollars@fastmail.fm;gen_iadv@matinetworks.net;accounts@cvbermesa.com;accounts@cvbermesa.com;jjacobi@CABQ.gov;jyee@CABQ.gov;jsmuckle@acninc.com;j essica.matushek@ftr.com;jclark@GMSSR.com;ion brinton@mitel.com;jcoffman@pngmail.com;kelleT.wells@ptci.net;kbartley@pvt.com;nick@nettalk.com;rdich¥@mettel.net;j eromedblock@msn.com;luther@yucca.net;leonn@vuccatelecom.com;sklopack@matrixbt.com;sthomas@tminc.com;jhill@cvbermesa.com;anthony@zianet.com;jrenneker@nos.com;danw@ntscom.com;alanh@plateautel.com;davidr@plateautel.com;sgatto@gvnw.com;mozanick@gvnw.com;cspears@gvnw.com;gil_arviso@yahoo.com;kell¥.faul@xo.com;agross@tminc.com;rgavidia@wcs.com;tolson@montand.com;arthull 1 @gmail.com;sm3162@att.com;shawn.hanson@ptci.net;sboyd@ioneswalker.com;smendoza@leaco.org;sklopack@matrixbt.com;bgilbert@cellularoneaz.comssmith@j oneswalker.com;schernoff@fcclaw.com;

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

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2

Tim KeeferJoseph YarAlicia Armijo

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Hank AdairRichard MatzkeBrad EllsworthEd Sema

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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

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