STATE OF NEW YORK PUBLIC SERVICE COMMISSION

At a session of the Public Service Commission held in the City of

Albany on March 14, 2013 COMMISSIONERS PRESENT: Garry A. Brown, Chairman Patricia L. Acampora Maureen F. Harris James L. Larocca Gregg C. Sayre CASE 12-C-0510 - Petition of Time Warner Cable Information

Services (New York), LLC for Modification of Its Existing Eligible Telecommunications Carrier Designation.

ORDER APPROVING DESIGNATION AS A LIFELINE-ONLY ELIGIBLE TELECOMMUNICATIONS CARRIER

(Issued and Effective March 18, 2013)

BY THE COMMISSION:

INTRODUCTION

By petition dated November 13, 2012, pursuant to Section

214 of 47 U.S.C., Time Warner Cable Information Services (New

York), LLC (TWCIS(NY)), or the Company) seeks Commission

designation as an eligible telecommunications carrier (ETC) in

order to receive federal universal service support for offering

Lifeline Service.1

The company’s requested ETC-designated service

area includes nearly all of its network footprint, including

portions of rural local exchange carriers’ territories.

1 In its petition TWCIS(NY) says that it holds “dormant” ETC

designations originally granted to some of its predecessor entities and requests “modification of its existing ETC designation.” For the sake of clarity, we will treat TWCIS(NY)’s petition as an initial request for ETC designation.

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Section 214 of 47 U.S.C. requires state commissions to

designate ETCs for the purpose of determining universal service

obligations and eligibility to receive federal universal service

funding after determining that certain criteria have been met. In

cases in which an ETC applicant petitions for designation in a

rural service area already served by an ETC, the state commission

is required to find that such designation is in the public

interest.

BACKGROUND

TWCIS(NY)’s petition represents the first request to the

Commission for ETC designation from an entity providing service

using fixed Voice over Internet Protocol (VoIP) technology.

Although the Federal Communications Commission (FCC) has not yet

determined the overall classification of interconnected VoIP, it

recently recognized that a VoIP provider with a state commission

issued Certificate of Public Convenience and Necessity (CPCN) that

has also filed a tariff offering intrastate telecommunications

service, is functioning as a telecommunications provider.2

TWCIS(NY) has a Commission-issued CPCN3 and had tariffs in effect

offering intrastate services. The company subsequently filed a

replacement tariff, effective February 23, 2013, offering Home

Phone and Business Class Phone service on a fully regulated basis.4

2 Telecommunications carrier status is required by federal law as

a condition for obtaining an ETC designation.

TWCIS(NY)’s Lifeline tariff, effective March 15, 2013, will offer

reduced rates to low income, Lifeline-eligible customers for the

following services: (i) local-only, unlimited in-state and

3 Case 98-C-0593, Time Warner Communications Holdings, Inc., et al. Certificates of Public Convenience and Necessity, Untitled Order (issued April 23, 1998).

4 Matter No. 13-00199, Time Warner Cable Information Services (New York), LLC – New Tariff Schedule No. 3, filed January 24, 2013.

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unlimited nationwide calling; and (ii) “double play” and “triple

play” bundles. Both tariff offerings will increase consumer access

to voice services as well as high-speed data and video services.

In comments submitted in response to a Notice Inviting

Comments issued December 11, 2012, the New York State

Telecommunications Association, Inc. (NYSTA) objected to granting

ETC designation to TWCIS(NY), claiming that TWCIS(NY): 1) did not

qualify as a telecommunications carrier; 2) had not satisfied FCC

requirements; and 3) lacked commitment to universal service

programs. As discussed in this Order, we find that TWCIS(NY) meets

the requisite criteria for Lifeline-only ETC designation and that

such designation is in the public interest.

TWCIS(NY)’s PETITION

TWCIS(NY) seeks Commission designation as an ETC in order

to become a “Lifeline-only” ETC. Lifeline-only ETCs, eligible to

receive federal support for providing Lifeline service, are

ineligible for other universal service funding support . In

addition to the federal funding that it will receive for offering

Lifeline service, TWCIS(NY) will seek reimbursement from the

state’s Targeted Accessibility Fund of New York, Inc. (TAF).

According to the TAF Operational Procedures and Advisory Board

Manual, reimbursement will be limited to the difference between the

applicable non-Lifeline and Lifeline rates of the incumbent local

exchange carrier (ILEC) serving the territory (Manual at page 16).

TWCIS(NY) notes that its proposed ETC-designated service

area in New York includes portions of the rural study areas of many

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of the rural ILECs.5 TWCIS(NY) explains that it qualifies as an

ETC because it satisfies each of the federal statutory and

regulatory requirements for designation. Specifically, the Company

states that it provides the following services:6

a) Voice grade access to the public switched network;

b) Local Usage;

c) Access to emergency services, including access to 911 or E911;

d) Lifeline and free toll limitation services for qualifying low-income customers; and,

e) Voice Telephony Service.

TWCIS(NY) asserts that it will advertise the availability

and charges for such services in media of general distribution, as

required by §214(e)(1)(B). The Company states that it will offer

Lifeline services only under its parent company Time Warner Cable’s

(TWC) brand names and not through an unidentified affiliate. To

the extent that Lifeline service is provided by any affiliate in

5 The specific ILECs are: Armstrong Telephone Company, Berkshire

Telephone Company, Cassadaga Telephone Corporation, Champlain Telephone Company, Chautauqua & Erie Telephone Company, Chazy & Westport Telephone Company, Crown Point Telephone Corporation, Delhi Telephone Company, Deposit Telephone Company Inc., Dunkirk & Fredonia Telephone Company, Edwards Telephone Company Inc., Empire Telephone Corporation, Middleburgh Telephone Company, Newport Telephone Company Inc., Nicholville Telephone Company, Oneida County Rural Telephone Company, Oriskany Falls Telephone Company, Pattersonville Telephone Company, Port Byron Telephone Company, Taconic Telephone Corporation, Township Telephone Company, Inc., Trumansburg Telephone Company, Vernon Telephone Company Inc., Citizens Telecommunications Company of New York, Inc., Frontier Communications of Ausable Valley, Inc., Frontier Communications of New York, Inc., Frontier Telephone of Rochester, Inc., Frontier Communications of Seneca-Gorham, Inc., Ogden Telephone Company and Windstream New York, Inc. (Fulton, Jamestown and Red Jacket study areas).

6 These requirements are set forth in 47 CFR 54.101.

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the future, TWCIS(NY) will disclose such information pursuant to

federal reporting requirements.

The Company represents that it has the financial

capabilities and technical expertise to provide Lifeline service.

It also states that it will satisfy other ETC requirements adopted

by this Commission and the FCC, including:

a) Ability to Remain Functional in an Emergency - TWCIS(NY) says that it maintains a reasonable amount of back-up power to ensure the functionality of its service without an external power source; is able to reroute traffic around damaged facilities; and is capable of managing traffic spikes resulting from emergency situations. In accordance with Commission rules, TWCIS(NY) filed an updated Emergency Plan with the Commission detailing its practices in the event of an emergency.

b) Satisfaction of Applicable Consumer Protection and Service Quality Standards - TWCIS(NY) says that it will comply with all applicable state and federal consumer protection and service quality standards, including Commission procedures for resolution of complaints.

c) Service Initiation Deposits - TWCIS(NY) will not

collect a service deposit for Lifeline plans that do not charge additional fees for toll calls, or for which a subscriber has elected toll limitation service.

d) Number-Portability Charges - TWCIS(NY) will not charge

Lifeline account holders a monthly number-portability charge.

e) Lifeline Certification and Verification - TWCIS(NY)

will certify and verify consumer eligibility to participate in the Lifeline program in accordance with the rules of the FCC. TWCIS(NY) states that it will adhere to the provisions of any compliance plan to which it is subject.

f) Regulatory Fees - TWCIS(NY) says that it pays and will continue to pay, in a timely manner, all applicable federal, state, and local regulatory fees, including, but not limited to, universal service and E-911 fees.

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The petition states that TWCIS(NY) will offer several

service plans to Lifeline subscribers. These will include: (i)

separate plans offering local-only, unlimited in-state and

unlimited nationwide calling; and (ii) “double play” and “triple

play” bundles, which will facilitate consumer access to voice

services as well as high-speed data and video services. For each

service, TWCIS(NY) will apply the Lifeline discount only to the

voice component of the bundle.

TWCIS(NY)’s ETC-designated service area will consist of

nearly all of the company’s franchise areas, which includes

portions of Verizon New York’s service area as well as portions of

the state’s small local exchange carriers serving New York State.

A list of the company's franchise service areas covered by the

petition is shown in Attachment A to this Order.

Finally, the petition states that granting a Lifeline-

only ETC designation to TWCIS(NY) will serve the public interest by

expanding choice regarding discounted basic service for New York

State’s low-income customers and concomitantly ensuring that more

of the state’s residents are connected to the telephone network.

Though TWCIS(NY) already provides voice services in New York, some

low-income individuals may be unable to take advantage of

TWCIS(NY)’s services unless offered in connection with a discounted

service such as Lifeline. According to TWICS(NY), designating it

as an ETC able to offer discounted basic service will give New

York’s Lifeline-eligible consumers an opportunity to obtain service

from TWCIS(NY).

COMMENTS AND REPLY COMMENTS

A Notice Inviting Comments (Notice) regarding TWCIS(NY)’s

petition, issued December 11, 2012, requested submission of

initial comments by January 10, 2013 and reply comments by

January 24, 2013. Only one party, the New York State

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Telecommunications Association, Inc. (NYSTA), filed initial

comments in response to the Notice. TWCIS(NY) filed reply comments

in response.7

NYSTA argued that the Commission should either deny

TWCIS(NY)’s petition or, alternatively, “undertake a fact-

intensive, rigorous analysis of the assertions contained in the

petition.” According to NYSTA, such analysis must be based on

TWCIS(NY)’s inability to qualify as a “telecommunications carrier”

offering or proposing to offer “telecommunications services,” as

those terms are defined in the Act. NYSTA argues that TWCIS(NY)

does not meet all of the eligibility requirements set forth by the

FCC and Section 214(e) of the Act.

In addition, a State Administrative Procedures Act

(SAPA) Notice of Proposed Rule Making on TWCIS(NY)’s petition was

published in the State Register on December 26, 2012; no comments

were filed in response.

NYSTA states that Section 214(e) of the Act requires

telecommunications carrier status as a prerequisite for ETC

designation. NYSTA contends that TWCIS(NY)’s federal status as a

VoIP provider does not meet Section 214(e) requirements.

TWCIS(NY)replies that this argument is meritless, explaining that

the FCC has allowed VoIP-based providers to qualify as

telecommunications carriers under certain circumstances.

NYSTA further questions whether TWCIS(NY) fully commits

to participating in all universal service programs in the State of

New York, including Lifeline, E911, Relay Service and the funding

of the State Universal Service Fund (SUSF). In response, TWCIS(NY)

noted that TWC, through its various affiliates, in connection with

its Home Phone and Business Class Phone services, has historically

7 NYSTA submitted late-filed comments in regard to TWCIS(NY)’s

proposed Lifeline tariff. Although the comments were not timely filed, they raised no objection that would preclude granting the company's petition.

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paid into the TAF, which supports the Commission’s universal

service goals, including Lifeline, E911 and the Relay Service. In

addition, TWCIS(NY) confirmed its commitment to fund the

Commission’s newly created State Universal Service Fund,

notwithstanding the exemption of VoIP providers as contributors to

the fund.

NYSTA urges us to reject the petition on the basis that

granting the requested Lifeline-only ETC designation is not in the

public interest. TWCIS(NY) replies that the petition “documents

the strong public interest benefits associated with its planned

participation in the Lifeline program.” Further, TWCIS(NY) says

its petition explains that extending Lifeline discounts to

qualified low-income customers will make TWCIS(NY)’s facilities-

based voice services more affordable and accessible.

DISCUSSION

NYSTA objections are centered on 1) TWCIS(NY)’s

telecommunications carrier status; 2) satisfaction of FCC

requirements; and 3) commitment to universal service programs.

TWCIS(NY)’s Status as a Telecommunications Carrier

TWCIS(NY)’s petition represents the first time in New

York State that a VoIP provider has requested ETC designation.

NYSTA questions whether TWCIS(NY) possesses the required status

under 47 U.S.C. Section 214(e) as a telecommunications carrier.

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Section 214(e) of 47 U.S.C. requires telecommunications

carrier status8

The FCC recognizes a VoIP provider that has obtained a

certificate from a state commission and filed a tariff offering

intrastate telecommunications service as a telecommunications

provider.

for any telecommunications provider seeking

designation as an ETC. TWCIS(NY) claims such status by virtue of

its CPCN and filed tariffs. NYSTA, however, claims that TWCIS(NY)

is seeking a telecommunications service designation for TWCIS(NY)’s

retail interconnected VoIP service and that self-declarations are

not sufficient to confer the required telecommunications carrier

status. NYSTA states that TWCIS(NY)’s previous classification of

its VoIP service as unregulated requires justification for the

basis of such service’s transformation to telecommunications

service status.

9

8 47 U.S.C 153(44) defines telecommunications carrier as “any

provider of telecommunications services . . .” specifying that a telecommunications carrier “shall be treated as a common carrier” . . . to the extent that “it is engaged in providing telecommunications services.” Telecommunications service is defined as “the offering of telecommunications for a fee directly to the public . . . regardless of the facilities used” (47 U.S.C. 153(46)). Telecommunications is defined as transmitting “between or among points specified by the user, of information of the user’s choosing, without change in the form or content of the information as send and received” (47 U.S.C. §153(43)).

Although the FCC has not determined interconnected VoIP

service’s overall classification, it has stated that, “if a

provider of interconnected VoIP holds itself out as a

telecommunications carrier and complies with appropriate federal

and state requirements,” it may be treated as a telecommunications

9 Fiber Technologies Network, LLC v. North Pittsburgh Telephone

Company, 22 FCC Rcd 3392 (2007).

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carrier.10 TWCIS(NY) holds a CPCN issued by this Commission, and

had tariffs in effect offering intrastate services. The company

subsequently filed a replacement tariff effective February 23, 2013

offering Home Phone and commercial Business Class Phone services on

a fully regulated basis.11

TWCIS(NY) holds itself out to New York

State consumers as a telecommunications provider and, therefore,

has met the FCC standard for operating as a telecommunications

carrier for the purpose of this ETC designation.

TWCIS(NY)’s Satisfaction of FCC Requirements to Become an ETC

NYSTA urges us to perform a rigorous fact-based analysis

of TWCIS(NY)’s petition to determine that the company meets the

FCC’s requirements to become an ETC. Staff independently reviewed

the petition and TWCIS(NY)’s PSC No. 3 – Telephone tariff and

confirmed that the company satisfies the requirements for

designation as an ETC for the purpose of receiving federal

universal service support for low income programs pursuant to

Sections 214(e)(2) and 214(e)(6) of the Act and Section 54.101

through Section 54.207 of 47 CFR.

TWCIS(NY) intends to offer its proposed Lifeline-only

service in nearly all of its franchise areas which will include

portions of rural study areas. Section 214(e)(5) requires both

state and federal approval to designate an ETC service area that

10 IP-Enabled Services; E911 Requirement for IP-Enabled Service

Providers, 20 FCC Rcd 10245, ¶38, n. 128 (2007).

11 “TWCIS(NY) . . . confirm[s] that its Home Phone and Business Class Phone services generally, for all Lifeline and non-Lifeline subscribers alike, will be offered pursuant to TWCIS(NY)’s CPCN on a fully regulated basis (TWCIS(NY) Reply, p 7).

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does not conform to the study area of a rural telephone company.12

Because the TWCIS(NY) study areas may not conform, TWCIS(NY)

submitted a petition to the FCC seeking forbearance from the

boundary modification provision of Section 214(e)(5),should such

relief prove necessary. Although boundary modification statutorily

requires both state and federal approval to designate a

nonconforming ETC service area, the FCC previously granted

forbearance from this requirement to two facilities-based

Lifeline-only ETCs.13

TWCIS(NY)’s Commitment to Universal Service Programs

In its comments, NYSTA questions TWCIS(NY)’s commitment

to participate in universal service programs. However, in both

TWCIS(NY)’s petition and reply comments, it stated that TWCIS(NY)

is fully committed to supporting all New York State universal

service programs. In addition, TWCIS(NY) made a commitment to full

Commission regulation; and, we will regulate TWCIS(NY) as we

regulate any other competitive local exchange carrier (CLEC). This

obligation includes payment of all fees, including mandatory

payment into the State’s USF and TAF. In addition, the company

will be subject to service quality regulation. Finally, the level

of TAF reimbursement for TWCIS(NY) will be the same as for other

CLECs, as provided for in the TAF Manual.

12 Section 214(e)(5) of the Act defines the term “service area” as

“a geographic area established by a State commission for the purpose of determining universal service obligations and support mechanisms. In the case of an area served by a rural telephone company, “service area” means such company’s “study area” unless and until the Commission and the States, after taking into account recommendations of a Federal-State Joint Board instituted under section 410(c), establish a different definition of service area for such company.”

13 See NTCH, Inc. and Cricket Communications, Inc. Petitions for Forbearance, Order, 26 FCC Rcd 13723 (2011).

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PUBLIC INTEREST

We find that TWCIS(NY) will provide the requisite

telephone services and satisfies all of the FCC’s requirements for

designation as an ETC for the purpose of receiving federal

universal service support for Lifeline service. We find that

granting a Lifeline-only ETC designation to TWCIS(NY) will serve

the public interest. As an ETC, TWCIS(NY) will be able to offer

discounted basic service, thereby meeting the needs of New York’s

Lifeline-eligible consumers and allowing the company to serve more

New York low-income individuals. By giving low income individuals

another choice for discounted basic service, in conjunction with

the company’s cable television and broadband services, many

Lifeline-eligible customers will have the opportunity to receive

more advanced and various telecommunications services than they

receive from some of the currently designated ETCs.

CONCLUSION

TWCIS(NY) qualifies as an eligible telecommunications

carrier for purposes of participating in federal universal service

low income support programs. We find that the designation of

TWCIS(NY) as a Lifeline-only ETC is in the public interest.

The Commission orders:

1. The petition of Time Warner Cable Information

Services (New York), LLC for designation as a Lifeline-only

eligible telecommunications carrier is approved.

2. The case is closed.

By the Commission, (SIGNED) JEFFREY C. COHEN Acting Secretary

Attachment A

TWCIS (NY) ETC Designated Service Area List of Included Franchises

MUNICIPALITY TYPE COUNTY

Brooklyn, Borough of (Western - NYC) Borough Kings Manhattan, Borough of (Northern - NYC) Borough New York Manhattan, Borough of (Southern - NYC) Borough New York Mount Vernon, City of City Westchester Queens, Borough of (Eastern & Southern NYC) Borough Queens Queens, Borough of (Western - NYC) Borough Queens Staten Island, Borough of (NYC) Borough Richmond Adams, Town of Town Jefferson Adams, Village of Village Jefferson Addison, Town of Town Steuben Addison, Village of Village Steuben Afton, Town of Town Chenango Afton, Village of Village Chenango Akron, Village of Village Erie Alabama, Town of Town Genesee Albany, City of City Albany Albion, Town of Town Orleans Albion, Town of Town Oswego Albion, Village of Village Orleans Alden, Town of Town Erie Alden, Village of Village Erie Alexander, Town of Town Genesee Alexander, Village of Village Genesee Alexandria, Town of Town Jefferson Alfred, Town of Town Allegany Alfred, Village of Village Allegany Alma, Town of Town Allegany Almond, Town of Town Allegany Almond, Village of Village Allegany Altamont, Village of Village Albany Altmar, Village of Village Oswego Altona, Town of Town Clinton Amboy, Town of Town Oswego Ames, Village of Village Montgomery Amsterdam, City of City Montgomery Amsterdam, Town of Town Montgomery Angelica, Town of Town Allegany Angelica, Village of Village Allegany Annsville, Town of Town Oneida Antwerp, Town of Town Jefferson Antwerp, Village of Village Jefferson Arcadia, Town of Town Wayne Argyle, Town of Town Washington Argyle, Village of Village Washington Arkport, Village of Village Steuben Ashland, Town of Town Chemung

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Attica, Town of Town Wyoming Attica, Village of Village Wyoming Auburn, City of City Cayuga Augusta, Town of Town Oneida Aurelius, Town of Town Cayuga Aurora, Village of Village Cayuga Ava, Town of Town Oneida Avoca, Town of Town Steuben Avoca, Village of Village Steuben Avon, Town of Town Livingston Avon, Village of Village Livingston Bainbridge, Town of Town Chenango Bainbridge, Village of Village Chenango Baldwinsville, Village of Village Onondaga Ballston Spa, Village of Village Saratoga Ballston, Town of Town Saratoga Bangor, Town of Town Franklin Barker, Town of Town Broome Barneveld, Village of Village Oneida Barre, Town of Town Orleans Barton, Town of Town Tioga Batavia, City of City Genesee Batavia, Town of Town Genesee Bath, Town of Town Steuben Bath, Village of Village Steuben Belfast, Town of Town Allegany Bemus Point, Village of Village Chautauqua Bennington, Town of Town Wyoming Bergen, Town of Town Genesee Bergen, Village of Village Genesee Berne, Town of Town Albany Bethany, Town of Town Genesee Bethel, Town of Town Sullivan Bethlehem, Town of Town Albany Big Flats, Town of Town Chemung Binghamton, City of City Broome Binghamton, Town of Town Broome Black River, Village of Village Jefferson Bleecker, Town of Town Fulton Bloomfield, Village of Village Ontario Blooming Grove, Town of Town Orange Bloomingburg, Village of Village Sullivan Bolivar, Town of Town Allegany Bolivar, Village of Village Allegany Bolton, Town of Town Warren Bombay, Town of Town Franklin Boonville, Town of Town Oneida Boonville, Village of Village Oneida Brasher, Town of Town St. Lawrence Bridgewater, Town of Town Oneida Bridgewater, Village of Village Oneida

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Brighton, Town of Town Monroe Brighton, Town of Town Franklin Bristol, Town of Town Ontario Broadalbin, Town of Town Fulton Broadalbin, Village of Village Fulton Brockport, Village of Village Monroe Brocton, Village of Village Chautauqua Brookfield, Town of Town Madison Brownville, Town of Town Jefferson Brownville, Town of Town Jefferson Brownville, Village of Village Jefferson Brunswick, Town of Town Rensselaer Brushton, Village of Village Franklin Brutus, Town of Town Cayuga Burke, Town of Town Franklin Burke, Village of Village Franklin Burlington, Town of Town Otsego Burns, Town of Town Allegany Busti, Town of Town Chautauqua Butler, Town of Town Wayne Butternuts, Town of Town Otsego Byron, Town of Town Genesee Caledonia, Town of Town Livingston Caledonia, Village of Village Livingston Callicoon, Town of Town Sullivan Cambridge, Town of Town Washington Cambridge, Village of Village Washington Camden, Town of Town Oneida Camden, Village of Village Oneida Camillus, Town of Town Onondaga Camillus, Village of Village Onondaga Campbell, Town of Town Steuben Canadice, Town of Town Ontario Canajoharie, Town of Town Montgomery Canajoharie, Village of Village Montgomery Canandaigua, City of City Ontario Canandaigua, Town of Town Ontario Canaseraga, Village of Village Allegany Canastota, Village of Village Madison Candor, Town of Town Tioga Candor, Town of Town Tioga Candor, Village of Village Tioga Caneadea, Town of Town Allegany Canisteo, Town of Town Steuben Canisteo, Village of Village Steuben Canton, Town of Town St. Lawrence Canton, Village of Village St. Lawrence Cape Vincent, Town of Town Jefferson Cape Vincent, Village of Village Jefferson Carlton, Town of Town Orleans Caroga, Town of Town Fulton

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Caroline, Town of Town Tompkins Carroll, Town of Town Chautauqua Carthage, Village of Village Jefferson Cassadaga, Village of Village Chautauqua Castile, Town of Town Wyoming Castile, Village of Village Wyoming Castleton-on-Hudson, Village of Village Rensselaer Castorland, Village of Village Lewis Catlin, Town of Town Chemung Catlin, Town of Town Chemung Cato, Town of Town Cayuga Cato, Village of Village Cayuga Caton, Town of Town Steuben Catskill, Town of Town Greene Cayuga Heights, Village of Village Tompkins Cayuga, Village of Village Cayuga Cazenovia, Town of Town Madison Cazenovia, Village of Village Madison Celoron, Village of Village Chautauqua Central Square, Village of Village Oswego Champion, Town of Town Jefferson Champlain, Town of Town Clinton Champlain, Village of Village Clinton Charlton, Town of Town Saratoga Chateaugay, Town of Town Franklin Chateaugay, Village of Village Franklin Chaumont, Village of Village Jefferson Chazy, Town of Town Clinton Chemung, Town of Town Chemung Chenango, Town of Town Broome Cherry Creek, Village of Village Chautauqua Cherry Valley, Town of Town Otsego Cherry Valley, Village of Village Otsego Chester, Town of Town Warren Chester, Village of Village Orange Chili, Town of Town Monroe Chittenango, Village of Village Madison Churchville, Village of Village Monroe Cicero, Town of Town Onondaga Cincinnatus, Town of Town Cortland Clarendon, Town of Town Orleans Clarkson, Town of Town Monroe Clarksville, Town of Town Allegany Clay, Town of Town Onondaga Clayton, Town of Town Jefferson Clayton, Village of Village Jefferson Clayville, Village of Village Oneida Cleveland, Village of Village Oswego Clifton Park, Town of Town Saratoga Clifton Springs, Village of Village Ontario Clinton, Village of Village Oneida

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Clyde, Village of Village Wayne Clymer, Town of Town Chautauqua Cobleskill, Town of Town Schoharie Cobleskill, Village of Village Schoharie Cochecton, Town of Town Sullivan Coeymans, Town of Town Albany Cohocton, Town of Town Steuben Cohocton, Village of Village Steuben Cohoes, City of City Albany Colchester, Town of Town Delaware Cold Brook, Village of Village Herkimer Colonie, Town of Town Albany Colonie, Village of Village Albany Colton, Town of Town St. Lawrence Columbia, Town of Town Herkimer Columbus, Town of Town Chenango Conesus, Town of Town Livingston Conklin, Town of Town Broome Constable, Town of Town Franklin Constableville, Village of Village Lewis Constantia, Town of Town Oswego Cooperstown, Village of Village Otsego Copenhagen, Village of Village Lewis Corfu, Village of Village Genesee Corinth, Town of Town Saratoga Corinth, Village of Village Saratoga Corning, City of City Steuben Corning, Town of Town Steuben Cornwall, Town of Town Orange Cornwall-on-Hudson, Village of Village Orange Cortland, City of City Cortland Cortlandville, Town of Town Cortland Coventry, Town of Town Chenango Covert, Town of Town Seneca Covert, Town of Town Seneca Covington, Town of Town Wyoming Crawford, Town of Town Orange Croghan, Town of Town Lewis Croghan, Village of Village Lewis Crown Point, Town of Town Essex Cuyler, Town of Town Cortland Danby, Town of Town Tompkins Dansville, Town of Town Steuben Dansville, Village of Village Livingston Danube, Town of Town Herkimer Darien, Town of Town Genesee Davenport, Town of Town Delaware Day, Town of Town Saratoga De Kalb, Town of Town St. Lawrence De Witt, Town of Town Onondaga Decatur, Town of Town Otsego

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Deerfield, Town of Town Oneida Deerpark, Town of Town Orange Deferiet, Village of Village Jefferson Delanson, Village of Village Schenectady Delaware, Town of Town Sullivan Delhi, Town of Town Delaware Delhi, Village of Village Delaware Denmark, Town of Town Lewis Denning, Town of Town Ulster DeRuyter, Town of Town Madison DeRuyter, Village of Village Madison Dexter, Village of Village Jefferson Diana, Town of Town Lewis Dickinson, Town of Town Broome Dix, Town of Town Schuyler Dolgeville, Village of Village Herkimer Dresden, Village of Village Yates Dryden, Town of Town Tompkins Dryden, Village of Village Tompkins Duanesburg, Town of Town Schenectady Dundee, Village of Village Yates Eagle, Town of Town Wyoming Earlville, Village of Village Chenango Earlville, Village of Village Madison East Bloomfield, Town of Town Ontario East Greenbush, Town of Town Rensselaer East Rochester, Village of Village Monroe East Syracuse, Village of Village Onondaga Easton, Town of Town Washington Eaton, Town of Town Madison Edinburg, Town of Town Saratoga Edmeston, Town of Town Otsego Elba, Town of Town Genesee Elba, Village of Village Genesee Elbridge, Town of Town Onondaga Elbridge, Village of Village Onondaga Ellenburg, Town of Town Clinton Ellenville, Village of Village Ulster Ellery, Town of Town Chautauqua Ellicott, Town of Town Chautauqua Ellington, Town of Town Chautauqua Ellisburg, Town of Town Jefferson Ellisburg, Village of Village Jefferson Elmira Heights, Village of Village Chemung Elmira, City of City Chemung Elmira, Town of Town Chemung Endicott, Village of Village Broome Erin, Town of Town Chemung Erwin, Town of Town Steuben Esopus, Town of Town Ulster Esperance, Town of Town Schoharie

CASE 12-C-0510

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Esperance, Village of Village Schoharie Evans Mills, Village of Village Jefferson Exeter, Town of Town Otsego Exeter, Town of Town Otsego Fabius, Town of Town Onondaga Fabius, Village of Village Onondaga Fair Haven, Village of Village Cayuga Fairfield, Town of Town Herkimer Fairport, Village of Village Monroe Falconer, Village of Village Chautauqua Fallsburg, Town of Town Sullivan Farmington, Town of Town Ontario Fayette, Town of Town Seneca Fayetteville, Village of Village Onondaga Fenner, Town of Town Madison Fenner, Town of Town Madison Fenton, Town of Town Broome Fleming, Town of Town Cayuga Florida, Town of Town Montgomery Floyd, Town of Town Oneida Fonda, Village of Village Montgomery Forestburgh, Town of Town Sullivan Forestport, Town of Town Oneida Fort Ann, Town of Town Washington Fort Ann, Town of Town Washington Fort Ann, Village of Village Washington Fort Covington, Town of Town Franklin Fort Drum Base Jefferson Fort Edward, Town of Town Washington Fort Edward, Village of Village Washington Fort Johnson, Village of Village Montgomery Fort Plain, Village of Village Montgomery Fowler, Town of Town St. Lawrence Frankfort, Town of Town Herkimer Frankfort, Town of Town Herkimer Frankfort, Village of Village Herkimer Franklin, Town of Town Delaware Franklin, Town of Town Franklin Franklin, Village of Village Delaware Fredonia, Village of Village Chautauqua Freeville, Village of Village Tompkins Fremont, Town of Town Sullivan Fremont, Town of Town Steuben French Creek, Town of Town Chautauqua Friendship, Town of Town Allegany Fulton, City of City Oswego Fultonville, Village of Village Montgomery Gaines, Town of Town Orleans Gainesville, Town of Town Wyoming Gainesville, Village of Village Wyoming Galen, Town of Town Wayne

CASE 12-C-0510

-8-

Galway, Town of Town Saratoga Galway, Village of Village Saratoga Gardiner, Town of Town Ulster Gates, Town of Town Monroe Geddes, Town of Town Onondaga Genesee Falls, Town of Town Wyoming Genesee, Town of Town Allegany Geneseo, Town of Town Livingston Geneseo, Village of Village Livingston Geneva, City of City Ontario Geneva, Town of Town Ontario Georgetown, Town of Town Madison German Flats, Town of Town Herkimer Gerry, Town of Town Chautauqua Gilbertsville, Village of Village Otsego Glen Park, Village of Village Jefferson Glen, Town of Town Montgomery Glens Falls, City of City Warren Glenville, Town of Town Schenectady Gloversville, City of City Fulton Goshen, Town of Town Orange Goshen, Village of Village Orange Gouverneur, Town of Town St. Lawrence Gouverneur, Village of Village St. Lawrence Granby, Town of Town Oswego Granville, Town of Town Washington Granville, Village of Village Washington Greece, Town of Town Monroe Green Island, Village of Village Albany Greene, Town of Town Chenango Greene, Village of Village Chenango Greenfield, Town of Town Saratoga Greenwich, Town of Town Washington Greenwich, Town of Town Washington Greenwich, Village of Village Washington Greig, Town of Town Lewis Groton, Town of Town Tompkins Groton, Village of Village Tompkins Groveland, Town of Town Livingston Groveland, Town of Town Livingston Guilderland, Town of Town Albany Guilford, Town of Town Chenango Hadley, Town of Town Saratoga Hagaman, Village of Village Montgomery Hague, Town of Town Warren Halfmoon, Town of Town Saratoga Hamden, Town of Town Delaware Hamilton, Town of Town Madison Hamilton, Village of Village Madison Hamlin, Town of Town Monroe Hamptonburgh, Town of Town Orange

CASE 12-C-0510

-9-

Hannibal, Town of Town Oswego Hannibal, Village of Village Oswego Hardenburgh, Town of Town Ulster Harmony, Town of Town Chautauqua Harpersfield, Town of Town Delaware Harrietstown, Town of Town Franklin Harrisville, Village of Village Lewis Hartford, Town of Town Washington Hartland, Town of Town Niagara Hartsville, Town of Town Steuben Hartwick, Town of Town Otsego Hastings, Town of Town Oswego Henderson, Town of Town Jefferson Henrietta, Town of Town Monroe Herkimer, Town of Town Herkimer Herkimer, Village of Village Herkimer Hermon, Town of Town St. Lawrence Hermon, Village of Village St. Lawrence Herrings, Village of Village Jefferson Heuvelton, Village of Village St. Lawrence Highland Falls, Village of Village Orange Highland, Town of Town Sullivan Highlands, Town of Town Orange Hilton, Village of Village Monroe Hobart, Village of Village Delaware Holland Patent, Village of Village Oneida Holley Village, Village of Village Orleans Homer, Town of Town Cortland Homer, Village of Village Cortland Honeoye Falls, Village of Village Monroe Hoosick Falls, Village of Village Rensselaer Hoosick, Town of Town Rensselaer Hopewell, Town of Town Ontario Hopkinton, Town of Town St. Lawrence Horicon, Town of Town Warren Hornby, Town of Town Steuben Hornell, City of City Steuben Hornellsville, Town of Town Steuben Horseheads, Town of Town Chemung Horseheads, Village of Village Chemung Hounsfield, Town of Town Jefferson Howard, Town of Town Steuben Hudson Falls, Village of Village Washington Hume, Town of Town Allegany Hunter, Town of Town Greene Hunter, Village of Village Greene Hurley, Town of Town Ulster Huron, Town of Town Wayne Ilion, Village of Village Herkimer Inlet, Town of Town Hamilton Interlaken, Village of Village Seneca

CASE 12-C-0510

-10-

Ira, Town of Town Cayuga Irondequoit, Town of Town Monroe Ithaca, City of City Tompkins Ithaca, Town of Town Tompkins Jamestown, City of City Chautauqua Jasper, Town of Town Steuben Java, Town of Town Wyoming Jefferson, Town of Town Schoharie Jeffersonville, Village of Village Sullivan Jewett, Town of Town Greene Johnson City, Village of Village Broome Johnstown, City of City Fulton Johnstown, Town of Town Fulton Jordan, Village of Village Onondaga Junius, Town of Town Seneca Kendall, Town of Town Orleans Kiantone, Town of Town Chautauqua Kinderhook, Town of Town Columbia Kinderhook, Village of Village Columbia Kingsbury, Town of Town Washington Kingston, City of City Ulster Kingston, Town of Town Ulster Kirkland, Town of Town Oneida Kirkland, Town of Town Oneida Kirkwood, Town of Town Broome Knox, Town of Town Albany Kortright, Town of Town Delaware Lacona, Village of Village Oswego LaFayette, Town of Town Onondaga LaGrange, Town of Town Dutchess Lake George, Town of Town Warren Lake George, Village of Village Warren Lake Luzerne, Town of Town Warren Lake Placid, Village of Village Essex Lakewood, Village of Village Chautauqua Lansing, Town of Town Tompkins Lansing, Village of Village Tompkins Laurens, Town of Town Otsego Laurens, Village of Village Otsego Lawrence, Town of Town St. Lawrence Le Ray, Town of Town Jefferson Le Ray, Town of Town Jefferson Le Roy, Town of Town Genesee Le Roy, Village of Village Genesee Lebanon, Town of Town Madison Ledyard, Town of Town Cayuga Lee, Town of Town Oneida Leicester, Town of Town Livingston Leicester, Village of Village Livingston Lenox, Town of Town Madison Lewis, Town of Town Lewis

CASE 12-C-0510

-11-

Leyden, Town of Town Lewis Liberty, Town of Town Sullivan Liberty, Village of Village Sullivan Lima, Town of Town Livingston Lima, Village of Village Livingston Lincoln, Town of Town Madison Lindley, Town of Town Steuben Lisbon, Town of Town St. Lawrence Lisle, Town of Town Broome Lisle, Village of Village Broome Litchfield, Town of Town Herkimer Litchfield, Town of Town Herkimer Little Falls, City of City Herkimer Little Falls, Town of Town Herkimer Liverpool, Village of Village Onondaga Livonia, Town of Town Livingston Livonia, Village of Village Livingston Lloyd, Town of Town Ulster Lodi, Town of Town Seneca Lodi, Village of Village Seneca Lorraine, Town of Town Jefferson Louisville, Town of Town St. Lawrence Lowville, Town of Town Lewis Lowville, Village of Village Lewis Lumberland, Town of Town Sullivan Lyme, Town of Town Jefferson Lyndonville, Village of Village Orleans Lyons Falls, Village of Village Lewis Lyons, Town of Town Wayne Lyons, Village of Village Wayne Lyonsdale, Town of Town Lewis Lysander, Town of Town Onondaga Macedon, Town of Town Wayne Macedon, Village of Village Wayne Madison, Town of Town Madison Madison, Village of Village Madison Madrid, Town of Town St. Lawrence Maine, Town of Town Broome Malone, Town of Town Franklin Malone, Village of Village Franklin Malta, Town of Town Saratoga Mamakating, Town of Town Sullivan Manchester (Canand), Town of Town Ontario Manchester, Village of Village Ontario Manheim, Town of Town Herkimer Manlius, Town of Town Onondaga Manlius, Village of Village Onondaga Mannsville, Village of Village Jefferson Marathon, Town of Town Cortland Marathon, Village of Village Cortland Marbletown, Town of Town Ulster

CASE 12-C-0510

-12-

Marcellus, Town of Town Onondaga Marcellus, Village of Village Onondaga Marcy, Town of Town Oneida Marcy, Town of Town Oneida Marilla, Town of Town Erie Marion, Town of Town Wayne Marlborough, Town of Town Ulster Marshall, Town of Town Oneida Martinsburg, Town of Town Lewis Maryland, Town of Town Otsego Masonville, Town of Town Delaware Massena, Town of Town St. Lawrence Massena, Village of Village St. Lawrence Maybrook, Village of Village Orange Mayfield, Town of (Gloversville and Schnectady) Town Fulton Mayfield, Village of Village Fulton McGraw, Village of Village Cortland Mechanicville, City of City Saratoga Medina, Village of Village Orleans Menands, Village of Village Albany Mendon, Town of Town Monroe Mentz, Town of Town Cayuga Meredith, Town of Town Delaware Meridian, Village of Village Cayuga Mexico, Town of Town Oswego Mexico, Village of Village Oswego Middleburgh, Town of Town Schoharie Middleburgh, Village of Village Schoharie Middlebury, Town of Town Wyoming Middlefield, Town of Town Otsego Middleport, Village of Village Niagara Middletown, City of City Orange Middleville, Village of Village Herkimer Milford, Town of Town Otsego Milford, Village of Village Otsego Millport, Village of Village Chemung Milton, Town of Town Saratoga Mina, Town of Town Chautauqua Minden, Town of Town Montgomery Minetto, Town of Town Oswego Minoa, Village of Village Onondaga Mohawk, Town of Town Montgomery Mohawk, Village of Village Herkimer Moira, Town of Town Franklin Montgomery, Town of Town Orange Montgomery, Village of Village Orange Monticello, Village of Village Sullivan Montour Falls, Village of Village Schuyler Montour, Town of Town Schuyler Mooers, Town of Town Clinton

CASE 12-C-0510

-13-

Moreau, Town of Town Saratoga Moriah, Town of Town Essex Morris, Town of Town Otsego Morris, Village of Village Otsego Morristown, Town of Town St. Lawrence Morristown, Village of Village St. Lawrence Morrisville, Village of Village Madison Mount Hope, Town of Town Orange Mount Morris, Town of Town Livingston Mount Morris, Village of Village Livingston Munnsville, Village of Village Madison Murray, Town of Town Orleans Nanticoke, Town of Town Broome Naples, Town of Town Ontario Naples, Village of Village Ontario Nassau, Town of Town Rensselaer Nassau, Village of Village Rensselaer Nelliston, Village of Village Montgomery Nelson, Town of Town Madison Neversink, Town of Town Sullivan New Berlin, Town of Town Chenango New Berlin, Village of Village Chenango New Bremen, Town of Town Lewis New Hartford, Town of Town Oneida New Hartford, Village of Village Oneida New Haven, Town of Town Oswego New Lisbon, Town of Town Otsego New Paltz, Town of Town Ulster New Paltz, Village of Village Ulster New Scotland, Town of Town Albany New Windsor, Town of Town Orange New York Mills, Village of Village Oneida Newark Valley, Town of Town Tioga Newark Valley, Village of Village Tioga Newark, Village of Village Wayne Newburgh, City of City Orange Newburgh, Town of Town Orange Newfield, Town of Town Tompkins Newport, Town of Town Herkimer Newport, Village of Village Herkimer Newstead, Town of Town Erie Nichols, Town of Town Tioga Nichols, Village of Village Tioga Niles, Town of Town Cayuga Niles, Town of Town Cayuga Niskayuna, Town of Town Schenectady Norfolk, Town of Town St. Lawrence North Dansville, Town of Town Livingston North Elba, Town of Town Essex North Greenbush, Town of Town Rensselaer North Harmony, Town of Town Chautauqua

CASE 12-C-0510

-14-

North Hornell, Village of Village Steuben North Norwich, Town of Town Chenango North Syracuse, Village of Village Onondaga Northampton, Town of Town Fulton Northumberland, Town of Town Saratoga Northville, Village of Village Fulton Norwich, City of City Chenango Norwich, Town of Town Chenango Norwich, Town of Town Chenango Norwood, Village of Village St. Lawrence Nunda, Town of Town Livingston Nunda, Village of Village Livingston Oakfield, Town of Town Genesee Oakfield, Village of Village Genesee Odessa, Village of Village Schuyler Ogden, Town of Town Monroe Ogdensburg, City of City St. Lawrence Olive, Town of Town Ulster Oneida Castle, Village of Village Oneida Oneida, City of City Madison Oneonta, City of City Otsego Oneonta, Town of Town Otsego Onondaga, Town of Town Onondaga Ontario, Town of Town Wayne Orangeville, Town of Town Wyoming Oriskany Falls, Village of Village Oneida Oriskany, Village of Village Oneida Orleans, Town of Town Jefferson Orwell, Town of Town Oswego Oswegatchie, Town of Town St. Lawrence Oswego, City of City Oswego Oswego, Town of Town Oswego Otego, Town of Town Otsego Otego, Village of Village Otsego Otisco, Town of Town Onondaga Otisville, Village of Village Orange Otsego, Town of Town Otsego Otselic, Town of Town Chenango Ovid, Town of Town Seneca Ovid, Village of Village Seneca Owasco, Town of Town Cayuga Owego, Town of Town Tioga Owego, Village of Village Tioga Oxford, Town of Town Chenango Oxford, Village of Village Chenango Painted Post, Village of Village Steuben Palatine Bridge, Village of Village Montgomery Palatine, Town of Town Montgomery Palermo, Town of Town Oswego Palmyra, Town of Town Wayne Palmyra, Village of Village Wayne

CASE 12-C-0510

-15-

Pamelia, Town of Town Jefferson Panama, Village of Village Chautauqua Paris, Town of Town Oneida Parish, Town of Town Oswego Parish, Village of Village Oswego Parishville, Town of Town St. Lawrence Parma, Town of Town Monroe Pavilion, Town of Town Genesee Pembroke, Town of Town Genesee Penfield, Town of Town Monroe Perinton, Town of Town Monroe Perry, Town of Town Wyoming Perry, Village of Village Wyoming Perth, Town of Town Fulton Pharsalia, Town of Town Chenango Phelps, Town of Town Ontario Phelps, Village of Village Ontario Philadelphia, Town of Town Jefferson Philadelphia, Village of Village Jefferson Phoenix, Village of Village Oswego Pierrepont, Town of Town St. Lawrence Pike, Town of (fka Village of Pike) Town Wyoming Pitcairn, Town of Town St. Lawrence Pitcher, Town of Town Chenango Pittsfield, Town of Town Otsego Pittsford, Town of Town Monroe Pittsford, Village of Village Monroe Pittstown, Town of Town Rensselaer Plainfield, Town of Town Otsego Plattekill, Town of Town Ulster Pleasant Valley, Town of Town Dutchess Plymouth, Town of Town Chenango Poestenkill, Town of Town Rensselaer Poland, Town of Town Chautauqua Poland, Village of Village Herkimer Pomfret, Town of Town Chautauqua Pompey, Town of Town Onondaga Port Byron, Village of Village Cayuga Port Dickinson, Village of Village Broome Port Henry, Village of Village Essex Port Jervis, City of City Orange Port Leyden, Village of Village Lewis Portage, Town of Town Livingston Portland, Town of Town Chautauqua Potsdam, Town of Town St. Lawrence Potsdam, Village of Village St. Lawrence Poughkeepsie, City of City Dutchess Poughkeepsie, Town of Town Dutchess Preble, Town of Town Cortland Preble, Town of Town Cortland Prospect, Village of Village Oneida

CASE 12-C-0510

-16-

Providence, Town of Town Saratoga Pulaski, Village of Village Oswego Putnam, Town of Town Washington Queensbury, Town of Town Warren Reading, Town of Town Schuyler Red Creek, Village of Village Wayne Red Hook, Town of Town Dutchess Red Hook, Village of Village Dutchess Remsen, Town of Town Oneida Remsen, Village of Village Oneida Rensselaer Falls, Village of Village St. Lawrence Rensselaer, City of City Rensselaer Rhinebeck, Town of Town Dutchess Rhinebeck, Village of Village Dutchess Richburg, Village of Village Allegany Richfield Springs, Village of Village Otsego Richfield, Town of Town Otsego Richland, Town of Town Oswego Richmond, Town of Town Ontario Richmondville, Town of Town Schoharie Richmondville, Village of Village Schoharie Richville, Village of Village St. Lawrence Ridgeway, Town of Town Orleans Riga, Town of Town Monroe Riverside, Village of Village Steuben Rochester, City of City Monroe Rochester, Town of Town Ulster Rockland, Town of Town Sullivan Rodman, Town of Town Jefferson Rome, City of City Oneida Romulus, Town of Town Seneca Root, Town of Town Montgomery Root, Town of Town Montgomery Rose, Town of Town Wayne Rosendale, Town of Town Ulster Rotterdam, Town of Town Schenectady Round Lake, Village of Village Saratoga Rouses Point, Village of Village Clinton Royalton, Town of Town Niagara Rush, Town of Town Monroe Russell, Town of Town St. Lawrence Russia, Town of Town Herkimer Rutland, Town of Town Jefferson Sackets Harbor, Village of Village Jefferson Salem, Town of Town Washington Salem, Village of Village Washington Salina, Town of Town Onondaga Salisbury, Town of Town Herkimer Sand Lake, Town of Town Rensselaer Sandy Creek, Town of Town Oswego Sandy Creek, Village of Village Oswego

CASE 12-C-0510

-17-

Sangerfield, Town of Town Oneida Santa Clara, Town of Town Franklin Saranac Lake, Village of Village Franklin Saratoga Springs, City of City Saratoga Saratoga, Town of Town Saratoga Saugerties, Town of Town Ulster Saugerties, Village of Village Ulster Savannah, Town of Town Wayne Savona, Village of Village Steuben Schaghticoke, Town of Town Rensselaer Schaghticoke, Village of Village Rensselaer Schenectady, City of City Schenectady Schodack, Town of Town Rensselaer Schoharie, Town of Town Schoharie Schoharie, Village of Village Schoharie Schroeppel, Town of Town Oswego Schroon, Town of Town Essex Schuyler, Town of Town Herkimer Schuylerville, Village of Village Saratoga Scio, Town of Town Allegany Scotia, Village of Village Schenectady Scott, Town of Town Cortland Scottsville, Village of Village Monroe Scriba, Town of Town Oswego Seneca Falls, Town of Town Seneca Seneca Falls, Village of Village Seneca Seneca, Town of Town Ontario Sennett, Town of Town Cayuga Seward, Town of Town Schoharie Shandaken, Town of Town Ulster Sharon Springs, Village of Village Schoharie Sharon, Town of Town Schoharie Shawangunk, Town of Town Ulster Shelby, Town of Town Orleans Sheldon, Town of Town Wyoming Sherburne, Town of Town Chenango Sherburne, Village of Village Chenango Sherill, City of City Oneida Shortsville, Village of Village Ontario Sidney, Town of Town Delaware Sidney, Village of Village Delaware Silver Springs, Village of Village Wyoming Sinclairville, Village of Village Chautauqua Skaneateles, Town of Town Onondaga Skaneateles, Town of Town Onondaga Skaneateles, Village of Village Onondaga Smithfield, Town of Town Madison Smyrna, Town of Town Chenango Smyrna, Village of Village Chenango Sodus Point, Village of Village Wayne Sodus, Town of Town Wayne

CASE 12-C-0510

-18-

Sodus, Village of Village Wayne Solvay, Village of Village Onondaga South Bristol, Town of Town Ontario South Corning, Village of Village Steuben South Dayton, Village of Village Cattaraugus South Glens Falls, Village of Village Saratoga Southport, Town of Town Chemung Spafford, Town of Town Onondaga Sparta, Town of Town Livingston Spencerport, Village of Village Monroe Springfield, Town of Town Otsego Springport, Town of Town Cayuga Springwater, Town of Town Livingston St. Armand, Town of Town Essex St. Johnsville, Town of Town Montgomery St. Johnsville, Village of Village Montgomery Stafford, Town of Town Genesee Stamford, Town of Town Delaware Stamford, Village of Village Delaware Starkey, Town of Town Yates Sterling, Town of Town Cayuga Stillwater, Town of Town Saratoga Stillwater, Village of Village Saratoga Stockbridge, Town of Town Madison Stockholm, Town of Town St. Lawrence Stockton, Town of Town Chautauqua Stuyvesant, Town of Town Columbia Sullivan, Town of Town Madison Summit, Town of Town Schoharie Sweden, Town of Town Monroe Sylvan Beach, Village of Village Oneida Syracuse, City of City Onondaga Tannersville, Village of Village Greene Taylor, Town of Town Cortland Theresa, Town of Town Jefferson Theresa, Village of Village Jefferson Thompson, Town of Town Sullivan Throop, Town of Town Cayuga Thurston, Town of Town Steuben Ticonderoga, Town of Town Essex Tioga, Town of Town Tioga Tivoli, Village of Village Dutchess Torrey, Town of Town Yates Trenton, Town of Town Oneida Trenton, Town of Town Oneida Triangle, Town of Town Broome Troupsburg, Town of Town Steuben Troy, City of City Rensselaer Trumansburg, Village of Village Tompkins Truxton, Town of Town Cortland Tully, Town of Town Onondaga

CASE 12-C-0510

-19-

Tully, Village of Village Onondaga Tupper Lake, Town of (f/k/a Altamont) Town Franklin Tupper Lake, Village of Village Franklin Turin, Town of Town Lewis Turin, Village of Village Lewis Tuscarora, Town of Town Steuben Tusten, Town of Town Sullivan Ulster, Town of Town Ulster Ulysses, Town of Town Tompkins Unadilla, Town of Town Otsego Unadilla, Village of Village Otsego Union Springs, Village of Village Cayuga Union, Town of Town Broome Utica, City of City Oneida Valatie, Village of Village Columbia Valley Falls, Village of Village Rensselaer Van Buren, Town of Town Onondaga Varick, Town of Town Seneca Vernon, Town of Town Oneida Vernon, Village of Village Oneida Verona, Town of Town Oneida Vestal, Town of Town Broome Veteran, Town of Town Chemung Victor, Town of Town Ontario Victor, Village of Village Ontario Victory, Village of Village Saratoga Vienna, Town of Town Oneida Villenova, Town of Town Chautauqua Volney, Town of Town Oswego Voorheesville, Village of Village Albany Waddington, Town of Town St. Lawrence Waddington, Village of Village St. Lawrence Walden, Village of Village Orange Wallkill, Town of Town Orange Walton, Town of Town Delaware Walton, Village of Village Delaware Walworth, Town of Town Wayne Wampsville, Village of Village Madison Warrensburg, Town of Town Warren Warsaw, Town of Town Wyoming Warsaw, Village of Village Wyoming Washingtonville, Village of Village Orange Waterford, Town of Town Saratoga Waterford, Village of Village Saratoga Waterloo, Town of Town Seneca Waterloo, Village of Village Seneca Watertown, City of City Jefferson Watertown, Town of Town Jefferson Waterville, Village of Village Oneida Watervliet, City of City Albany Watkins Glen, Village of Village Schuyler

CASE 12-C-0510

-20-

Watson, Town of Town Lewis Waverly, Town of Town Franklin Waverly, Village of Village Tioga Wawarsing, Town of Town Ulster Wawayanda, Town of Town Orange Wayland, Town of Town Steuben Wayland, Village of Village Steuben Webb, Town of (a/k/a Old Forge) Town Herkimer Webster, Town of Town Monroe Webster, Village of Village Monroe Weedsport, Village of Village Cayuga Wellsburg, Village of Village Chemung West Bloomfield, Town of Town Ontario West Carthage, Village of Village Jefferson West Monroe, Town of Town Oswego West Point U.S. Military Academy Base Orange West Sparta, Town of Town Livingston West Turin, Town of Town Lewis West Winfield, Village of Village Herkimer Western, Town of Town Oneida Westmoreland, Town of Town Oneida Westmoreland, Town of Town Oneida Westville, Town of Town Franklin Wheatland, Town of (Mumford) Town Monroe Wheeler, Town of Town Steuben Whitehall, Town of Town Washington Whitehall, Village of Village Washington Whitesboro, Village of Village Oneida Whitestown, Town of Town Oneida Whitestown, Town of Town Oneida Whitney Point, Village of Village Broome Willet, Town of Town Cortland Williamson, Town of Town Wayne Wilna, Town of Town Jefferson Wilton, Town of Town Saratoga Winfield, Town of Town Herkimer Wirt, Town of Town Allegany Wolcott, Town of Town Wayne Wolcott, Town of Town Wayne Wolcott, Village of Village Wayne Woodhull, Town of Town Steuben Woodridge, Village of Village Sullivan Woodstock, Town of Town Ulster Worcester, Town of Town Otsego Wright, Town of Town Schoharie Wurtsboro, Village of Village Sullivan Wyoming, Village of Village Wyoming Yates, Town of Town Orleans York, Town of Town Livingston Yorkville, Village of Village Oneida Allegany, Town of Town Cattaraugus

CASE 12-C-0510

-21-

Allegany, Village of Village Cattaraugus Amherst, Town of Town Erie Amity, Town of Town Allegany Andover, Town of Town Allegany Andover, Village of Village Allegany Angola, Village of Village Erie Arcade, Town of Town Wyoming Arcade, Village of Village Wyoming Aurora, Town of Town Erie Barker, Village of Village Niagara Barrington, Town of Town Yates Belmont, Village of Village Allegany Benton, Town of Town Yates Blasdell, Village of Village Erie Boston, Town of Town Erie Brant, Town of Town Erie Buffalo, City of City Erie Cambria, Town of Town Niagara Cattaraugus, Village of Village Cattaraugus Chautauqua, Town of Town Chautauqua Cheektowaga, Town of Town Erie Clarence, Town of Town Erie Colden, Town of Town Erie Coldspring, Town of Town Cattaraugus Collins, Town of Town Erie Concord, Town of Town Erie Conewango, Town of Town Cattaraugus Cuba, Town of Town Allegany Cuba, Village of Village Allegany Delevan, Village of Village Cattaraugus Depew, Village of Village Erie Dunkirk, City of City Chautauqua Dunkirk, Town of Town Chautauqua East Aurora, Village of Village Erie East Randolph, Village of Village Cattaraugus Eden, Town of Town Erie Ellicottville, Town of Town Cattaraugus Ellicottville, Village of Village Cattaraugus Elma, Town of Town Erie Evans, Town of Town Erie Farnham, Village of Village Erie Forestville, Village of Village Chautauqua Franklinville, Town of Town Cattaraugus Franklinville, Village of Village Cattaraugus Freedom, Town of Town Cattaraugus Gorham, Town of Town Ontario Gowanda, Village of Village Cattaraugus Gowanda, Village of Village Erie Grand Island, Town of Town Erie Great Valley, Town of Town Cattaraugus Hamburg, Town of Town Erie

CASE 12-C-0510

-22-

Hamburg, Village of Village Erie Hammondsport, Village of Village Steuben Hanover, Town of Town Chautauqua Hinsdale, Town of Town Cattaraugus Holland, Town of Town Erie Ischua, Town of Town Cattaraugus Italy, Town of Town Yates Jerusalem, Town of Town Yates Kenmore, Village of Village Erie Lackawanna, City of City Erie Lancaster, Town of Town Erie Lancaster, Village of Village Erie Lewiston, Town of Town Niagara Lewiston, Village of Village Niagara Lockport, City of City Niagara Lockport, Town of Town Niagara Machias, Town of Town Cattaraugus Mansfield, Town of Town Cattaraugus Mayville, Village of Village Chautauqua Middlesex, Town of Town Yates Milo, Town of Town Yates New Albion, Town of Town Cattaraugus Newfane, Town of Town Niagara Niagara Falls, City of City Niagara Niagara, Town of Town Niagara North Collins, Town of Town Erie North Collins, Village of Village Erie North Harmony, Town of Town Chautauqua North Tonawanda, City of City Niagara Olean, City of City Cattaraugus Olean, Town of Town Cattaraugus Orchard Park, Town of Town Erie Orchard Park, Village of Village Erie Pendleton, Town of Town Niagara Penn Yan, Village of Village Yates Perrysburg, Town of Town Cattaraugus Perrysburg, Village of Village Cattaraugus Persia, Town of Town Cattaraugus Pomfret, Town of Town Chautauqua Porter, Town of Town Niagara Portland, Town of Town Chautauqua Portville, Town of Town Cattaraugus Portville, Village of Village Cattaraugus Prattsburg, Town of Town Steuben Pulteney, Town of Town Steuben Randolph, Town of Town Cattaraugus Randolph, Village of Village Cattaraugus Ripley, Town of Town Chautauqua Rushville, Village of Village Yates Rushville, Village of Village Ontario Sardinia, Town of Town Erie

CASE 12-C-0510

-23-

Scio, Town of Town Allegany Sheridan, Town of Town Chautauqua Sherman, Town of Town Chautauqua Sherman, Village of Village Chautauqua Silver Creek, Village of Village Chautauqua Sloan, Village of Village Erie Somerset, Town of Town Niagara Springville, Village of Village Erie Tonawanda, City of City Erie Tonawanda, Town of Town Erie Tyrone, Town of Town Schuyler Urbana, Town of Town Steuben Wales, Town of Town Erie Wayne, Town of Town Steuben Wellsville, Town of Town Allegany Wellsville, Village of Village Allegany West Seneca, Town of Town Erie Westfield, Town of Town Chautauqua Westfield, Village of Village Chautauqua Wheatfield, Town of Town Niagara Wheeler, Town of Town Steuben Williamsville, Village of Village Erie Willing, Town of Town Allegany Wilson, Town of Town Niagara Wilson, Village of Village Niagara Yorkshire, Town of Town Cattaraugus Youngstown, Village of Village Niagara Rathbone, Town of Town Stuben Cameron, Town of Town Stuben