Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C ) ) ) ) ) CENSUS BLOCK CHALLENGE OF BLUEGRASS CELLULAR, INC.

Transcription

1 Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C In the Matter of Connect America Fund ) ) ) ) ) WC Docket No CENSUS BLOCK CHALLENGE OF BLUEGRASS CELLULAR, INC. Bluegrass Cellular, Inc. ( Bluegrass or the Company ), by counsel and pursuant to the Commission s Public Notice, DA , hereby files its Census Block Challenge ( Challenge ) in the above-captioned proceeding. 1 In the CAF Phase I Round 2 Public Notice, the Commission invited parties to challenge the list of potentially eligible census blocks submitted by price cap carriers as being unserved and thus eligible for the Connect America Fund ("CAF") Phase I second round of funding. 2 This Challenge is being filed to provide the Commission with a list of census blocks, along with supporting evidence, where Bluegrass is currently offering and providing a fixed wireless broadband service at or above the requisite broadband speed of 3 Mbps downlink and 768 kbps uplink. Accordingly, the census blocks identified in this Challenge should be removed from eligibility from the CAF Phase I second round of funding. 3 1 See Wireline Competition Bureau Publishes Census Blocks, And Commences Challenge Process, For Second Round of Connect America Phase I, Public Notice, DA (rel. Aug. 28, 2013) ("CAF Phase I Round 2 Public Notice"). 2 Id. at 1 ("Interested parties have 30 days from the release of this public notice to challenge price cap carriers' Phase I deployment plans by demonstrating that a block in question is already served by fixed Internet access with the requisite speeds."). 3 See Connect America Fund, Report and Order, FCC at 33 (rel. May 22, 2013) ("CAF Phase I Round 2 Order") ("Where the Bureau finds it more likely than not that the status of a census block should be treated differently than the status shown on the National Broadband Map, the Bureau will deem that census block as served or unserved, as appropriate, for the purposes of Connect America Phase I.").

2 I. INTRODUCTION Bluegrass is a provider of commercial wireless fixed and mobile service in Kentucky. Affiliates of Bluegrass are licensed in the cellular and PCS bands and have a longstanding record of serving rural communities in Kentucky. 4 Bluegrass currently offers a fixed Internet access to subscribing customers. This fixed wireless service provides customers with access to an Internet broadband service in their home with speeds at, or in excess, of 3 Mbps downlink and 768 kbps uplink. With the wireless router offered by Bluegrass as part of the fixed wireless service, customers can establish a wide-area network ("WAN") at home through the use of the router's Ethernet port or built-in WiFi that then provides customers with high-speed broadband access for computers and other devices in the home. 5 We have provided in Attachment A to this Challenge sample advertisements used by the Company for its fixed Internet wireless service and the speeds that it offers consumers. 6 II. BLUEGRASS CURRENTLY PROVIDES FIXED INTERNET ACCESS TO NUMEROUS CENSUS BLOCKS IN KENTUCKY THAT CERTAIN PRICE CAP CARRIERS ARE LISTING AS BEING ELIGIBLE FOR CAF PHASE I SECOND ROUND SUPPORT When electing to receive Phase I second round support, price cap carriers were required to provide a list of those census blocks unserved by 3 Mbps/768 kbps Internet access in which 4 Bluegrass markets wireless services that are provided under authority of licenses held by its affiliates including Kentucky RSA #3 Cellular General Partnership, Kentucky RSA 4 Cellular General Partnership, Cumberland Cellular Partnership and Bluegrass Wireless LLC. 5 See 6 See Attachment A. Some Bluegrass Cellular customers receive fixed Internet access at or above 3 Mbps (down) / 768 kbps (up) under the GetSetGo name, as opposed to the Bluegrass Cellular name. Sample advertisements for GetSetGo are also included in Attachment A.

3 they intend to deploy to meet their buildout obligations. 7 At the same time, the Commission invited interested parties to challenge this list by demonstrating that a census block is in fact served by fixed Internet access with speeds of 3 Mbps/768 kbps or higher. 8 With respect to wireless services, the Commission has previously determined that service is being provided to a census block when service is provided at the centroid point. 9 Bluegrass has reviewed the price cap carrier's list of potentially unserved census blocks in Kentucky. After careful analysis, Bluegrass has determined that it already provides, over its 4G LTE network, a qualified fixed Internet access service (i.e., 3 Mbps/768 kbps) at the centroid point of numerous census blocks on the price cap carrier's list. A list of those census blocks where Bluegrass already provides this coverage is attached hereto as Attachment B. In addition, a map showing the census blocks in Kentucky that price cap carriers have preliminarily designated as unserved, but where Bluegrass provides coverage, is attached hereto as Attachment C. 10 In developing Attachments B and C, Bluegrass enlisted the consulting services of Ms. Leila Rezanavaz, an electrical engineer specializing in the design of wireless networks, including those using 4G LTE technology. An engineering declaration, including a description of Ms. 7 See CAF Phase I Round 2 Order at 31. As set forth by the Commission, parties may contend that a census block is completely unserved (i.e., lacks speeds of 768 kbps/200 kbps and thus is eligible for $775 in funding), is unserved by 3 Mbps/768 kbps but served by 768 kbps/200 kbps (thus is eligible for $550 in funding), or is served by 3 Mbps/768 kbps (and thus is eligible for no support). Id. 8 Id. at 32. See also CAF Phase I Round 2 Public Notice at 1. 9 See, e.g., Mobility Fund Phase I Auction Scheduled for September 27, 2012, Comment Sought on Competitive Bidding Procedures for Auction 901 and Certain Program Requirements, DA at 16 (rel. Feb. 2, 2012); see also Mobility Fund Phase I Auction, Limited Extension of Deadlines for Comments and Reply Comments of Census Block Eligibility Challenges, DA (Feb. 16, 2012) (extending the comment deadline for filing comments and reply comments on census block eligibility challenges to March 16 and March 26 respectively.). 10 If requested, Bluegrass can provide Commission staff with enlarged copies of the coverage map included in Attachment C.

4 Rezanavaz s qualifications, is attached hereto as Attachment D. 11 In sum, Ms. Rezanavaz mapped the centroid point for each unserved census block listed by the Commission for the state of Kentucky. She then performed a coverage analysis of each Bluegrass cell site that uses 4G LTE, using Optimi xwizard ver. 8.2, a highly specialized propagation tool used by engineers to predict and model coverage to ensure appropriate coverage when designing wireless networks. Wizard software is widely accepted by engineers designing commercial mobile wireless networks and it is an essential tool for selecting, among other things, site locations, antenna height, antenna type, and power levels. Ms. Rezanavaz then overlaid the Bluegrass coverage map onto the eligible census block map, and performed an analysis of each census block to determine whether a tower operated by Bluegrass and offering the fixed Internet access provides coverage at the centroid point. Those census blocks that have such coverage are listed in Attachment B and the coverage map is included as Attachment C. 12 In addition, set forth at Attachment E is a signed declaration from Mr. Ronald Smith, President & CEO of Bluegrass, declaring that he has read this pleading and that Bluegrass offers 3 Mbps/768 kbps fixed wireless Internet service to customers in the census blocks identified in Attachment B. 13 Further, in accordance with the CAF Phase I Round 2 Order, accompanying this declaration are samples of customer billing records (redacted to preserve customer privacy) further demonstrating that Bluegrass is in fact providing its fixed wireless Internet service in 11 See Attachment D. 12 See CAF Phase I Round 2 Order at 33 ("All filings in the challenge process, whether from a price cap carrier or another provider, must be supported by some form of documented evidence."). 13 See CAF Phase I Round 2 Order at 33 ("In cases where another provider contests the price cap carrier's intention to serve, the Bureau may consider such evidence as a signed certification from an officer of the provider under penalty of perjury that it offers 3 Mbps/768 kbps Internet service to customers in that particular census block.").

5 these areas. 14 Bluegrass includes in its Declaration a certification that the company is in fact offering and advertising its service in the census blocks identified in Attachment B and depicted in the map in Attachment C, and has customers taking service in these areas. The evidence provided herein is sufficient to enable the Commission to determine that the census blocks listed in Attachment B already are served by a fixed Internet access service operating at, or in excess, of 3 Mbps/768 kbps, and as a result, these census blocks should be made ineligible for CAF Phase I second round funding. Respectfully submitted, September 27, 2013 Todd B. Lantor Marc A. Paul Lukas, Nace, Gutierrez & Sachs, LLP 8300 Greensboro Drive, Suite 1200 McLean, Virginia Phone: (703) Counsel for Bluegrass Cellular, Inc. 14 Id. ("Such [an officer] certification could be accompanied by current customer billing records, appropriately redacted to preserve customer privacy."). As noted earlier, and as reflected in some of the sample customer bills provided in Attachment E, some Bluegrass Cellular customers receive fixed Internet access service at or above 3 Mbps (down) / 768 kbps (up) from the Company under the GetSetGo name, as opposed to the Bluegrass Cellular name.

6 ATTACHMENT A Advertisements for Bluegrass Fixed Wireless Internet Service

7 CONNECT TO MORE. INSTANTLY. With Bluegrass Cellular s fast wireless Internet. Turn your house into a powerful 4G Internet hotspot to start connecting online with the people that matter the most almost instantly. You ll be amazed how much you ll save by adding this service to your voice plan. Come put our wireless services to the test today, and you ll also receive $20.00 off your monthly fee. BANDLUXE ROUTER ONLY $ * NOW *with a 2-year agreement. Retail: $ Just plug it in for fast 4G Wifi Internet Connect multiple devices Enhanced security features YOUR COMMUNITY, EXPANDED. bluegrasscellular.com Shop anytime, sign up for community news and special offers or find a career at bluegrasscellular.com. Sale dates August 4 August 24. Requires purchase of router and new or renewed two-year broadband service plan, which is subject to plan Terms and Conditions (including activation fee and early termination fees). Offer limited to one per eligible service plan. Does not apply to previous purchases, and cannot be combined with any other offer. Limited-time offer, available only while supplies last. Available brand, model and technical specifications of router may vary. Broadband service plan may not be available for all monthly data amounts, devices or geographical areas. 3G and 4G hi-speed data service requires a compatible device and service plan, is subject to performance limitations and may not be available in all areas. 4G is available on select devices only. Certain applications and features may not be available. Other restrictions may apply. Call CELL or visit your nearest Bluegrass Cellular location for details Bluegrass Cellular, Inc. All rights reserved.

8 Step one. Plug in. Installation complete. Get running faster with GetSetGo. Plug it in, turn it on and without any wires or installation, you ve got a high-speed 4G connection to the World Wide Web. Whether you live in an area that s not served by other providers or you re just fed up with the hassles of the service you already have, GetSetGo offers a faster, easier alternative to traditional DSL or Broadband Internet. Plans start at just $20/month. For more information or to order, call or visit us online at MyGetSetGo.com. Requires purchase of one-year service plan. Advertised price does not include sales tax or activation fee. Limited-time offer. Does not apply to previous purchases and cannot be combined with any other offer. Valid only on select service plans. Additional restrictions may apply. Call , log on to MyGetSetGo.com, or visit your nearest GetSetGo location for details GetSetGo. All rights reserved.

9 Direct Mailer Front Get there faster. 11

10 Direct Mailer Back Introducing GetSetGo wireless Internet. GetSetGo is simple. Plug it in, turn it on and without any wires or installation, you ve got a high-speed 4G connection to the World Wide Web. The BandLuxe R529 router/modem allows you to access the speed and simplicity of GetSetGo wireless service at home. Features include LTE/EVDO VoIP Supports WAN/LAN Ethernet port Dual embedded cellular antenna Upload up to 5 Mbps, download up to 12 Mbps For more information, visit us online at MyGetSetGo.com, call or stop by your nearest GetSetGo location. Limited promotional pricing available. Some restrictions apply. 12

11 ATTACHMENT B List of Census Blocks Where Bluegrass Already Provides Fixed Internet Access Service at 3 Mpbs (downlink)/768 kbps (uplink)

12 Details Regarding Unserved Census Blocks Being Challenged by Bluegrass Cellular Census Block ID LAT_centroid LON_Centroid State Carrier Centroid Covered KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y Page 1 of 11 September 27, 2013

13 Details Regarding Unserved Census Blocks Being Challenged by Bluegrass Cellular Census Block ID LAT_centroid LON_Centroid State Carrier Centroid Covered KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY AT&T Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY AT&T Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y Page 2 of 11 September 27, 2013

14 Details Regarding Unserved Census Blocks Being Challenged by Bluegrass Cellular Census Block ID LAT_centroid LON_Centroid State Carrier Centroid Covered KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y Page 3 of 11 September 27, 2013

15 Details Regarding Unserved Census Blocks Being Challenged by Bluegrass Cellular Census Block ID LAT_centroid LON_Centroid State Carrier Centroid Covered KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY AT&T Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y Page 4 of 11 September 27, 2013

16 Details Regarding Unserved Census Blocks Being Challenged by Bluegrass Cellular Census Block ID LAT_centroid LON_Centroid State Carrier Centroid Covered KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y Page 5 of 11 September 27, 2013

17 Details Regarding Unserved Census Blocks Being Challenged by Bluegrass Cellular Census Block ID LAT_centroid LON_Centroid State Carrier Centroid Covered KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y Page 6 of 11 September 27, 2013

18 Details Regarding Unserved Census Blocks Being Challenged by Bluegrass Cellular Census Block ID LAT_centroid LON_Centroid State Carrier Centroid Covered KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y Page 7 of 11 September 27, 2013

19 Details Regarding Unserved Census Blocks Being Challenged by Bluegrass Cellular Census Block ID LAT_centroid LON_Centroid State Carrier Centroid Covered KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y Page 8 of 11 September 27, 2013

20 Details Regarding Unserved Census Blocks Being Challenged by Bluegrass Cellular Census Block ID LAT_centroid LON_Centroid State Carrier Centroid Covered KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y Page 9 of 11 September 27, 2013

21 Details Regarding Unserved Census Blocks Being Challenged by Bluegrass Cellular Census Block ID LAT_centroid LON_Centroid State Carrier Centroid Covered KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y Page 10 of 11 September 27, 2013

22 Details Regarding Unserved Census Blocks Being Challenged by Bluegrass Cellular Census Block ID LAT_centroid LON_Centroid State Carrier Centroid Covered KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y KY Windstream Y Page 11 of 11 September 27, 2013

23 ATTACHMENT C Map of Bluegrass 4G LTE Coverage in Kentucky (Coverage Map Represents LTE Reference Signal Threshold of -85 dbm)

24 !" # $ % & ' ( ) *+, ' ' - ' ( ) ( # * # ) * $ %% ' * # % ' ' % $ '! % ' " + & & ' ' & ( & $ ( ) ' &! " & & ' & ' % ) ' & ' * '!, -,& *,",,,,,,,,,,*,./0,.123

25 ATTACHMENT D Declaration of Leila Rezanavaz Senior Consulting Engineer

26 Declaration of Leila Rezanavaz Senior Consulting Engineer 1. My name is Leila Rezanavaz and I am an RF Consulting Engineer with Lukas, Nace, Gutierrez, and Sachs, LLP in McLean, Virginia. I graduated from George Mason University in Fairfax, Virginia in 1989 with a Bachelor of Science degree in Electrical Engineering. 2. I worked with RMS Technologies at the Goddard Space Flight Center in Greenbelt, Maryland as an Associate Engineer for one year after my graduation. Since October of 1990, I have been working as a Consulting Engineer in the wireless industry. 3. I was employed by LCC Incorporated from 1990 until 1994, where I was involved in the design and implementation of several analog and digital Cellular and PCS systems using TMDA, GSM, and CDMA technologies in several European and South American countries. I also performed and supervised the RF design and system planning for several Cellular markets in the United States. I attended several training programs at Cellular Institute within LCC. The training included the Principles of RF Propagation; Traffic Analysis; The Principles of North American TDMA, Pan European GSM, and Qualcomm CDMA technologies; GSM and CDMA RF design, frequency planning, capacity planning, and system optimization and expansion. 4. I have been employed by Lukas, Nace, Gutierrez, and Sachs, LLP since 1994, where I have provided many Cellular and PCS operators with RF engineering consulting services. My responsibilities include FAA and FCC filings and compliance, cell site design, site candidate evaluation and recommendation, system traffic study and capacity planning, frequency planning and coordination, system drive test evaluation and recommendation, interference study and analysis, cell site optimization, and system expansion, PCS microwave incumbent analysis and relocation. Since 1995, I have helped many of my clients migrate their systems from analog to various digital technologies and move on to overlay 3G and 4G networks. I have also been involved in the design and evaluation of the private radio, paging, and other types of wireless systems. 5. I am familiar with the FCC rules for the Commercial Fixed and Mobile Services. 6. For purposes of the preparing the material set forth in Attachments B and C to the foregoing Census Block Challenge, I mapped the centroid point for each unserved census block listed by the price cap carriers and the Commission for the state of Kentucky as part of the Commission's Public Notice for the Connect America Fund Phase I Round 2 funding. See Wireline Competition Bureau Publishes Census Blocks, And Commences Challenge Process, For Second Round of Connect America Phase I, Public Notice, DA (rel. Aug. 28, 2013) ("CAF Phase I Round 2 Public Notice"). I then performed a coverage analysis of each Bluegrass cell site that uses 4G LTE with Reference Signal values equal or greater than -85 dbm RSSI using Optimi xwizard ver. 8.2, a highly specialized propagation tool used by engineers to predict and model coverage to ensure appropriate coverage when designing wireless networks. Wizard software is widely accepted by engineers designing commercial