rozycki christopher direct staff 2015 regulatory of
TRANSCRIPT
THE OFFICE OF REGULATORY STAFF
DIRECT TESTIMONY 4 EXHIBITS
OF
CHRISTOPHER J. ROZYCKI
OCTOBER 13, 2015
DOCKET NO. 2015-290-C
Petition of the South Carolina Telephone Coalition for aDetermination that Wireless Carriers are Providing Radio-Based
Local Exchange Services in South Carolina that Compete withLocal Telecommunications Services Provided in the State
Direct Testimony of Christopher L RozyckiOctober 13, 2015
Docket No. 2015-290-C South Carolina Telephone CoalitionPage 1 of 7
10
DIRECT TESTIMONY OF
CHRISTOPHER J. ROZYCKI
ON BEHALF OF
THE SOUTH CAROLINA OFFICE OF REGULATORY STAFF
DOCKET NO. 2015-290-C
IN RE: PETITION OF THE SOUTH CAROLINA TELEPHONE COALITION
FOR A DETERMINATION THAT WIRELESS CARRIERS ARE
PROVIDING RADIO-BASED LOCAL EXCHANGE SERVICES IN SOUTH
CAROLINA THAT COMPETE WITH LOCAL TELECOMMUNICATIONS
SERVICES PROVIDED IN THE STATE
11
12 Q. PLEASE STATE YOUR NAME, BUSINESS ADDRESS AND OCCUPATION.
13 A. My name is Christopher J. Rozycki. My business address is 1401 Main Street,
14 Suite 900, Columbia, South Carolina 29201. I am employed by the State of South
15 Carolina as the Director of Telecommunications for the South Carolina Office of
16 Regulatory Staff ("ORS").
17 Q. PLEASE STATE YOUR EDUCATIONAL BACKGROUND AND EXPERIENCE.
18 A.
19
20
21
22
23
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I have over thirty (30) years of experience. I have more than twenty (20) years in
telecommunications business and regulation and nearly ten (10) years in the regulation of
energy industries.
My testimony and advocacy covered issues involving finance, economics, rate-of-
retum, competitive entry, intercarrier compensation and access. I have also been
involved with the startup, development, and funding of telecommunications companies.
I hold a master's degree in Economics from George Mason University in Fairfax,
THE OFFICE OF REGULATORY STAFF1401 Main Street, Suite 900
Columbia, SC 29201
Direct Testimony ofChristopher J. Rozycki Docket No. 2015-290-COctober 13, 2015
South Carolina Telephone CoalitionPage 2 of 7
1 Virginia and a bachelor's degree in Economics I'rom Georgetown University in
2 Washington, DC.
3 Q. HAVE YOU TESTIFIED PREVIOUSLY BEFORE THE PUBLIC SERVICE
4 COMMISSION OF SOUTH CAROLINA ("COMMISSION")?
5 A. Yes.
6 Q. HAVE YOU TESTIFIED PREVIOUSLY ON TELECOMMUNICATIONS
7 MATTERS BEFORE OTHER STATE PUBLIC SERVICE COMMISSIONS?
8 A. Yes. 1 have testified on a variety of telecommunications issues in Alabama,
9 Delaware, Florida, Georgia, Louisiana, Mississippi, New York, North Carolina,
10 Pennsylvania, Tennessee, Vermont, and Virginia.
11 Q. WHAT IS THE PURPOSE OF YOUR TESTIMONY IN THIS PROCEEDING?
12 A. The purpose of my testimony is to provide facts, data, and research that would be
13 helpful to the Commission in determining the existence of competition between the
14 services provided by wireless or cellular telephone companies and local wireline service
15 provided by South Carolina's incumbent Local Exchange Companies ("LECs").
16 Q. CAN YOU SUMMARIZE THE RESULTS OF ORS'S REVIEW?
17 A. Yes. Wireless/cellular service is readily available throughout South Carolina.
18 Many households in South Carolina have dropped their landline telephone service, and
19 have become wireless-only households.
20 Q. DOES ORS REPORT ON LOCAL COMPETITION IN SOUTH CAROLINA?
21 A. Yes. Each year, ORS reviews data published by the Federal Communications
22
23
Commission ("FCC") and produces a report entitled, "Annual Report: The Status of
Local Telephone Competition in South Carolina." The most recent report completed by
THE OFFICE OF REGULATORY STAFF1401 Main Street, Suite 900
Columbia, SC 29201
Direct Testimony of Christopher 1. Rozycki Docket No. 2015-290-COctober 13, 2015
South Carolina Telephone Coalition
Page 3 of 7
I ORS is attached as Exhibit CJR-I.
2 Q. EXHIBIT CJR-I, CONTAINS DATA FOR 2013. IS THIS THE MOST RECENT
3 DATA AVAILABLE FROM THE FCC?
4 A. Yes.
5 Q. HAS THERE BEEN WIRELESS/CELLULAR GROWTH IN SOUTH
6 CAROLINA?
7 A. Yes. Exhibit CJR-2 shows the annual number of cell phones or handsets in
8 operation in South Carolina Irom 2003 to 2013. As can be seen, wireless telephone
9 subscribers have more than doubled during this 11 year period. This is impressive
10 growth.
Exhibit CJR-3 shows a broader more dramatic view of wireless telephone growth.
12 In this exhibit we have overlaid the growth in wireless telephone handsets or "lines" and
13 compared that with the decline in tadrelines. In 2003 in South Carolina, ILEC wirelines
14 exceeded wireless lines by 102,000. In 2013, just 10 years later, wireless lines were 3.3
15 million lines greater than ILEC wirelines. That means that cell phones outnumber ILEC
16 wirelines in the state in 2013 by nearly 4 to l.
17 Q. DOES THE FCC TRACK MOBILE WIRELKSS COMPETITION?
Yes. In its "Mobile Wireless Competifion Report ("Report"), the FCC fulfills its
19 obligation, pursuant to Section 332(c)(1)(C) of the Communications Act, to report
20 annually to the Congress on the state of competition in mobileservices."'1
Q. CAN YOU BRIEFLY PROVIDE KEY HIGHLIGHTS FROM THE FCC'S MOST
22 RECENT MOBILE WIRELESS COMPETITION REPORT?
'mplementation ofSection 6002(b) ofthe Omnibus Budget Reconciliation Act ofl993; Annual Report and Analysisof Competitive Market Conditions With Respect to Mobile Wireless, Including Commercial Mobile Services, WTDocket No. 13-135, Seventeenth R ort, 29 FCC Rcd 15311, (2014 .
THE OFFICE OF REGULATORY STAFF1401 Main Street, Suite 900
Columbia, SC 29201
Direct Testimony of Christopher J. RozyckiOctober 13, 2015
Docket No. 2015-290-C South Carolina Telephone CoalitionPage 4 of 7
I A. Key highlights include the following:
2 ~ Paragraph 66 — "The nationwide penetranon rate based on NRUF data now exceeds
100 percent, meaning that the number of connected devices exceeds the population."
4 ~ Paragraph 86 — "We provide here the latest information &om the U.S. Department of
5 Health and Human Services, Centers for Disease Control ("CDC") National Health
6 Interview Survey on wireless-only households. Preliminary results Irom CDC's July
7 — December 2013 National Health Interview Survey indicate that the number of
8 American homes with only wireless telephones continues to grow...the percentage of
9 U.S. adults and children living in households with landlines, with or without wireless,
10
12
has fallen steadily over the past few years. The percentage of wireless-only
households has continued to increase for both groups, and the percentage of
households without phones has not changed significantly."
13 Q. HAS ORS REVIEWED THE CDC REPORT AND SURVEY REFERENCED IN
14 THE FCC'S SEVENTEENTH MOBILE WIRELESS COMPETITION REPORT?
15 A. Yes. The CDC, National Center for Health Statistics ("NCHS") has been tracking
16
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19
20
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estimates of telephone coverage for a number of years. The latest report is titled:
5'ireless Substitution: Early Release of Estimates Pom the 1Vational Health Interview
Survey, July-December 2014. "The survey also includes information about household
telephones and whether anyone in the household has a wireless telephone.
As part of the Wireless Mobile Competition Report, the FCC developed Chart
III.C.7, Percentage of U.S. Adults Living in Households with/without Wireless and
Id. at/ 66.Id. at/ 86.Blumberg SJ, Luke JV. Wireless substitution: Early release of estimates &om the National Health Interview
Survey, July- December 2014. National Center for Health Statistics, June 2015. Available 1'rom:h://www.cdc. ov/nchs/nhis.htm.
THE OFFICE OF REGULATORY STAFF1401 Main Street, Suite 900
Columbia, SC 29201
Direct Testimony ofChristopher J. Rozycki Docket No. 2015-290-COctober 13, 2015
South Carolina Telephone CoalitionPage 5 of 7
1 Landlines (2008 - 2013). ORS has taken the data &om that chart and the most recent
2 CDC Early Release, and created the attached Exhibit CJR-4.
3 Q. WHAT DOES THE DATA IN EXHIBIT CJR-4 REFLECT?
4 A. The data tells us some very interesting things. To start with, in 2008 nearly 80%
5 of adults lived in a household with a landline telephone. By the end of 2014, just six
6 years later, less than 53% of adults lived in a household with a landline phone, a drop of
7 approximately 27 percentage points. Conversely, adults living in wireless only
8 households rose &om 18.4% in 2008 to 44.1% in 2014, a rise of nearly 26 percentage
9 points, which translates to an increase of 140%.
10 Q. IS IT CORRECT THAT THE DATA GATHERED BY THE CDC AND
11 PRESENTED IN EXHIBIT CJR-4 ARE NATIONAL AND NOT SPECIFIC FOR
12 SOUTH CAROLINA?
13 A. Yes that is correct.
14 Q. HAS THE CDC PRODUCED SIMILAR DATA OR ESTIMATES FOR THE
15 STATE OF SOUTH CAROLINA?
16 A. They have. In the report entitled "Wireless Substitution: State-level Estimates
17 &om the National Health Interview Survey, 2012," the CDC's NCHS has modeled or
18 estimated the data 1 have shown in Exhibit CJR-4 for each state. The estimated
19 percentage of South Carolina adults living in wireless-only households for the period July
20 2011 — June 2012, was 37.0%, and for the period January — December 2012, it was
21 39.0%. These are just slightly higher than the national averages for the same category.
22 Q. HAS THE FCC BEEN TRACKING LOCAL TELEPHONE COMPETITION?
23 A. Yes. In its semi-annual reports entitled "Local Telephone Competition," the FCC
THE OFFICE OF REGULATORY STAFF1401 Main Street, Suite 900
Columbia, SC 29201
Direct Testimony of Christopher J. Rozycki Docket No. 2015-290-COctober 13, 2015
South Carolina Telephone CoalitionPage 6 of 7
1 has been reporting on the status of local telephone competition throughout the U.S. In
2 this report the FCC provides data on local service provided by traditional wireline
3 telephone companies, Voice over Internet Protocol ("Voip") providers, and Mobile
Telephony providers. Data from this report have been used by ORS to develop the
5 tables found in Exhibit CJR-2 and CJR-3.
6 Q. IS WIRELESS SERVICE PROVIDED BY WIRELESS CARRIERS
7 THROUGHOUT SOUTH CAROLINA?
8 A. Yes, wireless service offered by the four national carriers, (AT&T, Sprint, T-
9 Mobile, and Verizon Wireless) is available throughout South Carolina. Both Verizon
10 Wireless and AT&T Wireless provide maps on their websites that show or claim their
11 coverage or the availability of their service in South Carolina is complete. T-Mobile
12 claims "We cover 98% of Americans coast to coast where they live, work, and play."
13 Sprint's coverage is not as robust, but it does cover most of the populated areas of South
14 Carolina.
15 Q. DO WIRELESS CARRIERS ADVERTISE THAT THEY ARE COMPETING
16 DIRECTLY WITH LOCAL TELEPHONE SERVICE AND PROVIDERS IN
17 SOUTH CAROLINA?
19
20
Yes. For example the website for Verizon wireless provides the following quote:
"Rethink your Home Phone Service. Wireless Home Phone offers you a reliable,
portable, low-cost alternative to traditional home phone service using the Verizon
"Local Telephone Competition Status as of June 30, 2013." Issued by Industry Analysis and Technology Divisionof the FCC Wireline Competition Bureau, June 2014.
h .//ex lore t-mobile com/4 -Ite-networkvicid=WMD TM NTWRKEXTND IV4S 6AKY2996h://covers e.s rint.com/IMPACT.'s?INTNAV=LeilNav:More:Covera eMa ¹I/
THE OFFICE OF REGULATORY STAFF1401 Main Street, Suite 900
Columbia, SC 29201
Direct Testimony of Christopher J. Rozycki Docket No. 2015-290-COctober 13, 2015
South Carolina Telephone CoalitionPage 7 of 7
Wireless network all while you keeping your same number and home phone." The
2 AT&T website offers a similar type of service: "Now there's a low-cost alternative to
3 traditional home phone service. AT&T Wireless Home Phone service uses a mobile
device to give you home phone service at a better price."«9
5 Q. DOES THIS CONCLUDE YOUR TESTIMONY?
6 A. Yes, it does.
't //www verizonwireless com/home-office-solutions/wireless-home- hone/ht://www.att.com/cell bones/att/att-wireless-home- hone.html
THE OFFICE OF REGULATORY STAFF1401 Main Street, Suite 900
Columbia, SC 29201
EXHIBIT CJR-IPage 1 of 13
2013
EXHIBIT CJR-IPage 2 of13
Table of Contents
Introduction
Telecommunications Events of 2013
Local Telephone Competition
Incumbent Local Exchange Carriers
Competitive Local Exchange Carriers
VoIP Providers
Alternative Regulation
Lifeline — Eligible Telecommunications Carriers
Wireless Carriers
Broadband Deployment
Consumer Services
Conclusion
10
12
Tables
Table 1: Alternative Regulation 13
2013
EXHIBIT CJR-1Page 3 of 13
INTRODUCTION
The South Carolina Office of Regulatory Staff (ORS) is required to compile information
and monitor the status of local telephone competition in the State on an annual basis.'his
document reports the status of competition in the local telephone exchange market in South
Carolina, notes the effects of changes that occurred in the local telecommunications marketplace
in 2013, and monitors the emergence of broadband and wireless services within the competitive
local exchange market. The report also addresses other notable developments related to the
telecommunications industry, such as consumer complaints that ORS receives and resolves snd
new industry trends that may affect the delivery of and access to critical telecommunications
services in South Carolina.
Much of the data that appears in this report was provided to the Federal Communications
Commission (FCC) in FCC Form 477. According to the FCC, data was submitted by 17
Incumbent Local Exchange Companies (ILECs), 137 Competitive Local Exchange Companies
(CLECs), 108 Voice over Internet Protocol (VoIP) providers, and 12 Wireless carriers.
TELECOMMUNICATIONS EVENTS OF 2013
Traditional telephone users continue to migrate their voice communications use to
wireless and/or VoIP using their broadband connection.
LOCAL TELEPHONE COMPETITION
FCC Form 477 is used by the FCC to collect subscribership information from providers
of local telephone service - incumbent local exchange carriers (ILECs), competitive local
exchange carriers (CLECs), mobile telephone providers, and interconnected Voice over Internet
'his report contains both data generated by ORS and state data published in the PCC's Local Competition Report.
2013
EXHIBIT CJR-IPage 4 of 13
Protocol (interconnected VolP or IVoIP) service providers. Traditional wireline service is being
replaced by VoIP technology.
The local telephone market is defined as the delivery of voice telephone service to
residential and/or business customers over a wired or wireless communications path regardless of
the technology used. This market includes traditional wired telephone service, replacement VoIP
service, and wireless or cellular telephone service. Each of these services allows two or more
individuals to engage in a simultaneous, speaking conversation even though they are not all
located in the same place and are considered direct substitutes for each other. Local competition
is measured by counting the number of access lines, telephone lines, or wireless handsets sold or
controlled by each provider.
Local telephone services are provided by ILECs, CLECs, VoIP providers, and wireless or
cellular phone companies. ILECs are the traditional local telephone companies that existed prior
to the Federal Telecommunications Act of 1996.
The number of wired access lines in South Carolina peaked in 2002 and has gradually
declined since that time. This trend may be attributed to the increasing number of households
replacing their wireline telephone either with a cell phone or a phone that delivers its service via
Internet protocol, or VoIP service. VoIP is further defined as interconnected and non-
interconnected. Interconnected VoIP providers are required to con&bute to the Federal
Universal Service Fund (USF) and Federal Telecommunications Relay Services Fund (TRS),
and some, though not all, are contributing to South Carolina's USF and TRS funds. On the
federal level, interconnected VOIP providers are generally being treated in a number of respects
as traditional telecommunications carriers.
See, 47 C.F.R. f 9.3 and 47 C.F.R f 64.601(a).See 47 C.F.R. 0 64.604(c)(5)(iii)(A) for TRS and 47 C.F.R. 0 54.706 for USF.
2013
EXHIBIT CJR-IPage 5 of 13
Chart 1 illustrates the gradual decline in total wired access lines occurring since 2003.
Importantly, during that period ILEC lines declined by approximately 47% and have fallen by
50% since their peak in 2002.
Chart 1: Local Telephone Connections in South Carolina
laIaIa
ale
aalIJ
Ye
Source: Local Telephone Competition Status as of June 30, 2013, issued by IndustryAnalysis and Technology Division of the FCC Wireline Competition Bureau, June 2014
INCUMBENT LOCAL EXCHANGE CARRIERS
During 2013 the ILEC market share continued its steady decline in South Carolina, with
market share dropping to 62%. In 2013, 22 of the State's 25 ILECs were operating under the
Alternative Regulation provisions of the Code, Section 58-9-576(B) or (C). Three ILECs
remained rate-of-return regulated in 2013 (See Table 1, page 14), but two of them opted into
Alternative Regulation provisions in 2014.
2013
EXHIBIT CJR-IPage 6 of 13
COMPETITIVE LOCAL EXCHANGE CARRIERS
Chart 2 illustrates the growth in market share that South Carolina's CLECs have
experienced since 2003. Based on access lines reported to the FCC, CLEC market share grew
again in 2013, increasing &om 35% to 38% of the local telephone market.
VOIP PROVIDERS
In June of 2013, the FCC reported 108 VoIP providers serving subscribers in South
Carolina. Some of these VoIP providers are ILECs, some are CLECs, and some are
uncertificated providers of VoIP telephone service. In 2013, nearly 57% of CLEC Wireline
customers purchased their telephone service from a VoIP provider.
Local Telephone Competition: Status as of June 30, 2013, Industry Analysis and Technology Division, WirelineCompetition Bureau, June, 2014; Table 9.
20l3
EXHIBIT CJR-IPage 7 of 13
ALTERNATIVE REGULATION
Prior to the development of competition in the telecommunications market, each ILEC's
rates were regulated by the Public Service Commission of South Carolina (Commission) based
on the telephone utility's rate of return. With the passage of the federal Telecommunications Act
of 1996, and legislative changes in South Carolina, ILECs are regulated in a more flexible
manner. Section 58-9-576(C) provides local exchange companies the ability to offer nearly all
retail local service on a deregulated basis.
If an ILEC or a CLEC opts for alternative regulation pursuant to Section 58-9-576(C),
then its retail service offerings are deregulated — allowing them the ability to set price, terms,
and conditions without Commission review. Additionally, an ILEC choosing Act 7 deregulation
will be subject to a three-year phase-down of any state Universal Service Fund (USF) support or
Interim LEC Fund (ILF) support it receives, but will continue to contribute to the State USF and
ILF funds. The Commission retains authority over wholesale services like switched access and
services sold to other carriers as well as limited authority over stand-alone basic residential lines.
During 2013, two (2) telecommunications companies chose Act 7 (58-9-576(C)) deregulation.
LIFELINE - ELIGIBLE TELECOMMUNICATIONS CARRIERS
Beginning in 2007, South Carolina began accepting applications &om carriers requesting
permission to become Eligible Telecommunications Carriers (ETCs) offering Lifeline and Link-
up services to low-income households. In addition to the ILECs, South Carolina had sixteen (16)
Lifeline ETCs — fourteen (14) wireless and three wireline providers' offering Lifeline at the
end of2013.
'ne South Camlina Lifeline ETC is authorized to provide both wireline and wireless lifeline service.
2013
EXHIBIT CJR-1Page 8 of 13
WIRELESS CARRIERS
In 2011 and 2012 there were 16 facilities-based wireless carriers operating in South
Carolina, but in 2013 the number dropped to 12. As reflected on Chart 3, these wireless
companies reported 4.4 million wireless subscribers, a jump of nearly 14% over the previous
year. Chart 4 provides a comparison of total wireless and wireline access lines in South Carolina
from 2003 to 2013. Chart 5 shows the combination of wireline voice with broadband in
comparison to wireless lines.
FCC Local Telephone Competition Report: Status as of June 30, 2013.
2013
EXHIBIT CJR-IPage 9 of )3
Chart 4: Wireline and Wireless Access Lines500045004000350030002500200015001000500
0Year
Wireless (000)
Total Wireline (000)
ILEC Wireline (000)
2003
2042
2348
2144
2004 2005
2337 2607
2251 2189
2025 1897
2006 2007
3001 3340
2238 2215
1908 1866
2008 2009
3573 3374
2127 2058
1728 1561
2010
3848
2050
1429
2011 2012
3987 3907
1953 1890
1330 1236
2013
4438
1827
1136
Source: Local Telephone Competition Status as of June 30, 2013 issued by Industry Analysisand Technology Division of the FCC Wireline Competition Bureau, June 2014
Chart 5: Wireline Voice/Broadband and Wireless Access Lines
Source: Internet Access Services, Status as of June 30, 2013 issued by Industry Analysisand Technology Division of the FCC Wireless Competition Bureau, June, 2014
2013
EXHIBIT CJR-IPage 10 of 13
BROADBAND DEPLOYMENT
Broadband access has grown significantly in South Carolina. As illustrated in Chart 6, the
number of high-speed internet-access lines has increased from 25,229 in 1999 to nearly 3.5
million in 2013. In fact, overall broadband access has soared past expectations due to several
factors such as industry advances, the popularity of wireless broadband, and the expanding role
broadband is taking both in residential and business applications.
Chart 7 shows the growth of high-speed lines using DSL, coax, fiber, and wireless
technologies from 2003 to 2013. The FCC reports that in June 2013 South Carolina had 42,000
fiber connections.
2013 10
EXHIBIT CJR-IPage 11 of 13
Chart 7: High-Speed lines by Technology
Source: Internet Access Services, Status as of June 30, 2013 Industry Analysis andTechnology Division of the FCC Wireline Competition Bureau, June 2014
CONSUMER SERVICES
Each year the ORS assists South Carolina residential and business consumers to resolve
issues related to their telephone service; two of the largest telecommunications complaint areas
relate to service quality and billing. Service quality complaints accounted for 24% of
telecommunications complaints, non-regulated issues were second with 19%, and billing issues
were third at 13%. The ORS necks a wide range of consumer complaints related to regulated
and non-regulated telecommunications services. Chart 8 depicts a breakdown of complaint calls
received by the ORS during 2013.
2013
EXHIBIT CJR-IPage 12 of 13
CONCLUSION
Voice services are increasingly provided by wireless and VoIP providers using the
underlying telecommunications network built by South Carolina's telephone utilities. This
report provides data illustrating that wireless and VoIP service providers are gaining market
share, while traditional landline local exchange carrier market share has decreased. The local
telephone landscape continues to evolve.
2013 12
EXHIBIT CJR-IPage 13 of 13
Table I: Alternative Regulation: ILECs
Carrier
United Telephone Company ofCarolinas dba CenturyLink, fkaEmbarq, fka SprintBellSouth Telecommunications
Alt. Reg.I 58-9-576(B)
29-Sep-97
13-Aug-99
Alt. Reg.I 58-9-576(C)
Act 7
1-0ct.-0
Rate ofRetura
Regulation
Frontier fka Verfzon South, inc.
Windstream South CarolinaHorry Telephone Coop.PBT TelecomHome Telephone Co.
West Carolina Rural TeL Coop.
Piedmont Rural Telephone Coop.
Lockhart Telephone Co.
Farmers Telephone Coop.Btuffton Telephone Co.
Hargray Telephone Co.
McClellanville Telephone Co.
(TDS)Norway Telephone Co. (TDS)St. Stephen Telephone Co. (TDS)Williston Telephone Co. (TDS)Fort Mill Telephone Co. dbaComporiumLancaster Telephone Co. dbaComporiumRock Hill Telephone Co, dbaComporiumChester Telephone Co.
Ridgeway Telephone Co.Chesnee Telephone Co.
Palmetto Rural Telephone Coop.Sandhill Telephone Coop.
14-Oct-00
27-Sep-0230-Jan-0318-Feb-06
7-Apr-0616-Oct-06
12-Jan-07
9-Aug-071-May-08
4-Mar-054-Mar-05
30-May-05
30-May-0530-May-05
30-May-05
1-Aug-05
1-Aug-05
1-Aug-05
9-Aug-079-Aug-07
23-Aug-2014
1-May-2014
'ompany requested Alternative Regulation based on interconnection agreement.Company requested Alternative Regulation based on Section 58-9-576(C) which effectively deregulates retail service pricing.Company requested Alternative Regulation based on determination that at least two wireless providem have coverage generally
available in the LEC's service area.
2013 13
EXHIBIT CJR-2
EXHIBIT CJR-3
Chart 4: Wireline and Wireless Access Lines
CICI
lOeC
5000
4500
4000
3500
3000
2500
2000
1500
1000
500
0Year 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013Wireless 2042 2337 2607 3001 3340 3573 3374 3848 3987 3907 4438Total Wireline 2348
ILEC Wireline 2144
2251
2025
2189 2238
1897 1908
2215
1866
2127 2058 2050
1728 1561 1429
1953
1330
1890 1827
1236 1136
Source: Local Telephone Competition Status as of June 30, 2013 Issued by Industry Analysis and Technology Division of theFCC Wireline Competition Bureau, June 2014
EXHIBIT CJR 4
60.0%
ING IN HOUSEHOLDF U.S. ADULTS LIVIIRELESS & LANDLINESWITH/WITHOUT WIREL
Wireless Only~ Landline w/o Wireless~Landline w/wireless ~Lan i
62.5% 62.2%59 4% 58 8%
50.0%45.896
40.096
20.0%
4 6.9% 7.096 7 p% 7 1%10.9% 10 7% 9 p%
.4% 2.9%1 7% 1 7% 1.8% 1.8%1.7% 1.5%
~b ~b
o ~ .o o~ .~o o+ o~ + gv~v'