STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION

Transcription

1 STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION In the Matter of the Application of ) MIDWEST ENERGY COOPERATIVE d/b/a ) MIDWEST ENERGY & COMMUNICATIONS for ) Case No. U Expansion of Its Designation As an Eligible ) Telecommunications Carrier in the State of Michigan ) APPLICATION OF MIDWEST ENERGY COOPERATIVE D/B/A MIDWEST ENERGY & COMMUNICATIONS FOR EXPANSION OF ITS ETC STATUS IN THE STATE OF MICHIGAN Shannon M. Heim (P82718) Moss & Barnett, P.A. 150 South Fifth Street, Suite 1200 Minneapolis, MN Telephone: (612) shannon.heim@lawmoss.com kelly.mcginty@lawmoss.com Attorneys for Midwest Energy Cooperative

2 I. INTRODUCTION. Midwest Energy Cooperative d/b/a Midwest Energy & Communications 1 ( Midwest ), by its undersigned counsel, and pursuant to Section 214(e)(2) of the Communications Act of 1934, as amended by the Telecommunications Act of 1996 (the Act ), Sections through of the Code of Federal Regulations promulgated by the Federal Communications Commission ( FCC ), and the Rules and Regulations of the Michigan Public Service Commission ( Commission ), hereby submits this Application for Expansion of its Designation as an Eligible Telecommunications Carrier ( ETC ) in the State of Michigan. 1 Midwest seeks expansion of its ETC designation to fulfill the requirements of the federal Connect America Fund Phase II Reverse Auction ( CAF Auction ). Midwest successfully competed in the auction and prevailed in acquiring additional funding over the next ten years. 2 Midwest applied for and was granted ETC status in a portion of its service territory in Midwest sought only high cost support at that time. Midwest fulfilled all federal obligations and also offered Lifeline service throughout its service area as required by the Michigan Telecom Act and related regulations. Midwest s successful provision of broadband led it to make substantial investments in broadband. Midwest participated in the CAF Auction to leverage its investment with federal funds to accelerate its deployment. 1 Midwest Energy Cooperative created a new Doing Business As to better reflect its communications business. It has no legal bearing on this Application. 2 Five Michigan carriers were awarded more than $33M over the next 10 years to provide broadband service to more than 21,000 locations. See 3 Midwest applied for ETC status for the census blocks covered by its award in the Rural Broadband Experiment Award. See U

3 As discussed herein, Midwest meets all of the statutory and regulatory requirements for an expansion of its designation as an ETC in Michigan. Midwest seeks to expand its geographic footprint and to include Lifeline to its ETC designation. The expansion and Lifeline designation advances the public interest because it will enable Midwest to receive federal funding to build critical broadband infrastructure in Michigan. For these reasons, Midwest respectfully requests that the Commission approve this Application for expansion of its ETC designation. The contact information for Midwest is: David H. Allen Midwest Energy & Communications Decatur Road Cassopolis, MI Telephone: (269) All correspondence, pleadings, notices, orders, and decisions relating to this Application should be addressed to: Shannon M. Heim Moss & Barnett, P.A. 150 South Fifth Street, Suite 1200 Minneapolis, MN Telephone: (612) II. OVERVIEW OF MIDWEST S TELECOMMUNICATIONS BUSINESS. On March 18, 2014, the Commission granted Midwest a license to offer local exchange service in Midwest s then existing service area. 4 Midwest will request an 4 Midwest originally sought authority to provide basic local exchange services in the Watervliet, Coloma, Kalamazoo, Benton Harbor, Niles, Vicksburg, and Eau Claire exchanges served by AT&T Michigan; the Bloomingdale exchange served by Bloomingdale Telephone Company, Inc.; the Sturgis, Cassopolis, Three Rivers, Mattawan, Lawton, Bangor, Hartford, Edwardsburg, Decatur, Sister Lakes, Constantine, Dowagiac, Vandalia, White Pigeon, Mendon, Union, 3

4 expansion of its CLEC certificate under separate application. Midwest seeks an ETC designation for the entirety of its service area as described more fully in Exhibit 1. 5 The benefit of its years of providing service makes it more comfortable in seeking a wider designation than it though was prudent or appropriate in 2014 or Midwest is not seeking ETC designation in any census block that includes Tribal land at this time. Midwest plans to offer facilities-based and resold local exchange services to residential and business customers in its expanded area. Midwest won federal CAF Auction support and is obligated to expand its ETC designation in those areas. Midwest seeks to expand this obligation throughout its entire service area. 6 Midwest will also offer unregulated information services in the form of broadband service. Facilities-based basic local exchange service will be provided via fiber facilities built by Midwest in conjunction with Midwest s Voice over Internet Protocol ( VoIP ) 7 telephone partner, Alianza. 8 This service meets the federal definition of providing telecommunications service. Exhibit 2 contains information about Alianza and the network configuration used by Midwest to provide telecommunication services. Midwest s exemplary conduct and commitment to consumers demonstrates its long term intention to provide basic Marcellus, Paw Paw, Schoolcraft, Gobles, Covert, and Centreville exchanges served by Frontier North Inc.; and the Lawrence exchange served by Frontier Midstates Inc. 5 Exhibit 1 includes a list and a map of the census blocks from its Rural Broadband Experiment award and its CAF Auction award. It also includes a list of exchanges and the ILECs who serve them. 6 Midwest s expanded service area is depicted in the maps and table attached as Exhibit 1. 7 Third party provider of VoIP service has become increasingly common since Midwest s initial ETC Application in Midwest stands ready to provide additional information about the voice application that rides on Midwest s fiber network, but Midwest would respectfully assert that this arrangement has worked quite well in Michigan and across the nation over recent years. 8 Midwest has transitioned to a new telecommunications partner. Alianza has proven to be a reliable and effective provider of VoIP telephone service. See There was no gap in service when Midwest transitioned between its previous provider and Alianza. 4

5 and enhanced services with its own fiber networks with reliance on resale where necessary and prudent. 9 III. MIDWEST MEETS THE STATUTORY AND REGULATORY REQUIREMENTS FOR ETC DESIGNATION. Midwest meets all of the statutory and regulatory requirements for designation as an ETC and its application to extend that territory should be granted as expeditiously as possible to meet the parameters of the CAF Auction. The Michigan Telecommunications Act encourages the introduction of new services, the entry of new providers, the development of new technologies, and increase investment in the telecommunication infrastructure. Mich. Comp. Laws (2)(c). Midwest has proven itself a worthy telecommunications partner in Michigan. Midwest reviewed the ETC Applicant Checklist published by the Commission and this Application complies with all requirements contained therein. See Mich. PSC Case No. U et al. Section 254(e) of the Act provides that only an eligible telecommunications carrier designated under section 214(e) shall be eligible to receive specific federal universal service support. 47 U.S.C. 254(e). Section 214(e)(2) provides that state commissions have the authority to designate ETC status for federal universal service purposes. Midwest reviewed the applicable federal rules and the Commission s ETC Applicant checklist. See 47 C.F.R As described herein, Midwest has met its obligations in existing areas and satisfies all of the necessary state and federal requirements for additional designation. 9 Midwest discussed the network configuration and the FCC s consideration of that service as compliant with federal law and regulations. There is no substantive difference in the service being proposed in this application and the service previously approved by the Commission. See Exhibit 2 for VoIP information. 5

6 A. Midwest Will Offer the Services Supported By Federal Universal Service Support Mechanisms. Midwest certifies that it will use any federal high cost support it receives only for the provision, construction, maintenance and upgrading of facilities and provision of supported services in the service area for which such support is intended. Midwest is committed to extending broadband service, including a voice application, to its customers, but the pace of deployment will be dependent on the availability of federal and private funds to support the project. Midwest has committed to meet its federal broadband deployment obligations. Midwest has provided Lifeline services since it was designated an ETC in Exhibit 4 contains Midwest s Lifeline Application and Advertisement. It has fulfilled all of its state obligations. Although it has not sought or received state or federal support, it has advertised and provided low cost serviced to qualifying customers. 10 Midwest has developed its internal offering to comply with federal requirements for Lifeline so it respectfully requests the Commission designate it an ETC for both high cost support (CAF Phase II) and Lifeline. B. Midwest is an ETC and a Common Carrier. On June 3, 2015, the Commission approved Midwest s ETC designation for purposes of high-cost support only. 11 Midwest is also a licensed CLEC in the service 10 See Midwest s Application and related information In the matter of the application Midwest Energy Cooperative, d/b/a Midwest Connections, for designation as an eligible telecommunications carrier in the state of Michigan, Case No. U , Order (June 3, 2015). 6

7 area where it received its ETC designation. 12 Midwest is regulated as a common carrier, subject to all applicable regulations, and therefore meets the ETC requirement of being a common carrier. C. Midwest Will Fulfill Lifeline Eligibility Requirements. Midwest has provided Lifeline service as required under Michigan regulations since its ETC status was granted in Midwest is financially and technically capable of providing Lifeline services to low-income members in its CLEC service area as required by 47 C.F.R (a)(4). The FCC requires minimum broadband speed of 18/2 Mbps as of December 1, Midwest currently provides a Lifeline broadband offering of 25/25 Mbps with no data cap. The FCC requires Lifeline providers to offer a telephone package. Midwest does fulfill the requirement. Midwest is currently advertising for its Lifeline service on its website. It has not applied for reimbursement of the discount provided to its customers. Midwest vetted the eligibility of customers on its own. This process was appropriate as long as no reimbursement was requested. As Midwest now requests a formal Lifeline designation, it will comply with the federal obligations regarding Lifeline Eligibility. 14 Both new and reapplying customers will be required to complete the federal application. Any customer who does not meet the federal eligibility requirements will not be eligible for the discount. During a reasonable transition period, Midwest will not terminate service for customers who qualified for the discount under Midwest s internal process. 12 See Docket U finding Midwest s provision of local exchange service to be in the public interest. 13 Midwest currently advertises its Lifeline services on its website. See 14 Midwest will add Lifeline to its exhibit Tariff. The excerpt pages are included in Exhibit 4. 7

8 D. Midwest Will Provide All Required Services and Functionalities. In accordance with 47 C.F.R (a) and (a), Midwest certifies that it will provide all of the services and functionalities required under federal law. 1. Voice Grade Access to the Public Switched Telephone Network. Midwest will provide voice grade access to the public switched telephone network ( PSTN ) in part through the purchase of service from Alianza and in part over its own fiber network. 2. Local Usage. Midwest has the ability to offer local usage plans comparable to the ILEC in areas where designations are sought but currently focuses on the areas where it has constructed its own network as described more fully in Exhibit Midwest has the financial ability to offer and is currently offering local usage plans comparable to the ILEC, Frontier Communications, through its relationship with Alianza Telephone in conjunction with its existing network infrastructure. 16 Midwest offers an unlimited local service. Midwest also offers unregulated broadband plans to meet the broadband needs of its customers who do not wish to purchase voice service. 3. Equal Access. Midwest acknowledges it may be required to provide equal access to long distance carriers to the extent that no other ETC is providing equal access within the Midwest service area. Midwest does not expect this to be an issue as it offers unlimited 15 See Exhibit

9 nationwide calling with its local service. No customer has requested equal access in Midwest s existing service area. 4. Access to Emergency Services. Midwest provides access to emergency services via traditional 911 or E911 as requested by the appropriate local government or Public Safety Answering Point ( PSAP ). Midwest currently leverages the experience of its telecommunications partner, Alianza, to fulfill its emergency obligations. This arrangement works well and Midwest will implement it in its new service areas as well. E. Midwest Will Advertise the Availability of Its Services and the Charges. Midwest broadly advertises the availability and rates for the above-described services using its website, which is how it primarily advertises to all of its customers. 47 C.F.R (d)(2). It will continue to do so in the same manner for its new service areas. Midwest will investigate additional mechanisms to reach target Lifeline customers and educate them on the availability of a discount for telephone or broadband services. F. Midwest Requests Designation Within Its Service Area. Because Midwest is not a rural telephone company under 47 U.S.C. 153(37), it is required to describe the geographic area(s) within which it requests designation as an ETC. Midwest proposes to offer service in the ILEC serving areas identified in the maps and the table in Exhibit 1. The exchanges requested by Midwest include the census blocks from the Rural Broadband Experiment and the census blocks from the CAF Phase II Auction. Midwest s request is consistent with its existing CLEC area plus the expanded CLEC request it submitted in Case No. U Exhibit 1 includes several 9

10 maps demonstrating census blocks and the requested ETC area sought by Midwest as well as a tabular representation of the ILEC exchanges and the ILECs who serve them. 17 G. Midwest Has the Ability to Remain Functional in Emergency Situations. Midwest exceeds traditional expectations in emergency situations. Midwest has been certified as a Tier 2 data center with full battery and generator backup services. All network assets have adequate backup power generation or backup generation service to provide functionality without an external power source. 47 CFR (a)(2). Midwest has a long history of providing utility service in emergency situations. It is well able to restore service in the shortest amount of time possible when an outage does occur. Midwest will comply with the obligations to provide service and have emergency backup power as required in Section 305(c) of the MTA, as amended by HB4314, MCL c. Midwest s network is engineered to provide maximum capacity to handle excess traffic resulting in spikes during emergency situations. The fiber configuration is designed to handle an enormous amount of data and voice traffic. The current and projected usage of the Midwest system is relatively low in the near term and there is virtually no chance that excess traffic spikes could overwhelm the ability of the network to respond. Midwest s network also has multiple backup power supplies to provide continued service in the event of an emergency. The network uses a redundant uninterruptable 17 Midwest discussed providing a list of the census blocks with staff, but the document was several hundred pages and inconsistent with how ETC designations are typically granted or administered. 10

11 power supply to support electric service to its data center. The data center also has an emergency generator and battery backup to continue operation for up to 24 hours before requiring refueling. Additionally, the cabinet at each customer location contains a battery backup capable of providing 10 hours of backup power. H. Midwest Will Satisfy Applicable Consumer Protection and Service Quality Standards. Midwest satisfies all applicable state and federal requirements related to consumer protection and service quality standards, as required by 47 C.F.R (a)(3). 18 Midwest has a long history of providing its utility customers with a high level of consumer protection and service quality, whether they purchase telephone, broadband or a package that includes both. Midwest will be responsible, managerially and legally, for handling and responding to any customer issues. Midwest annually files an Officer s Compliance Certificate that outlines the provisions of Midwest s CPNI Operating Procedures with the FCC. Chief Executive Officer Robert L. Hance s Affidavit certifies that Midwest will comply with applicable service requirements. IV. EXPANSION OF MIDWEST S ETC DESIGNATION WILL PROMOTE THE PUBLIC INTEREST. Prior to designating an ETC pursuant to Section 214(e), the Commission must determine that such designation is in the public interest. 47 CFR (b). The FCC determined that access to robust broadband is an essential element of universal service. See Transformation Order, 26 FCC Rcd (2011). Americans turn to advanced telecommunications capability for every facet of daily life, using both fixed and mobile broadband services to communicate and to access the Internet. FCC See Exhibit 2 for a list of Midwest s residential rates and service charges. 11

12 Broadband Deployment Report, GN Docket No (Feb. 2, 2018). Many individuals and businesses in the area to be served by Midwest lack access to robust broadband. They are clamoring for access to the same level of broadband access as urban Americans. The FCC s award of funding to Midwest in the CAF Auctions demonstrates the FCC s belief that Midwest s service area still requires improved access to robust broadband. 19 The network already implemented and the future expansion planned by Midwest includes fiber to the premise. A fiber network represents a significant advancement in available infrastructure in the area. It allows Midwest to deliver broadband to individuals and businesses in the area at speeds that simply are not possible today. V. REQUEST FOR EX PARTE TREATMENT. This Application may be approved without a hearing. Neither the MTA nor federal law requires a hearing. The MPSC has previously concluded that it need not solicit comment on an ETC designation. Therefore, Midwest respectfully requests approval on an ex parte basis. VI. CONCLUSION. As detailed herein, Midwest satisfies all statutory and regulatory requirements to expand its ETC designation in the State of Michigan. WHEREFORE, Midwest Energy Cooperative d/b/a Midwest Energy & Communications respectfully requests that the Commission: 19 The incumbent provider declined support to provide service in these areas thus opening the opportunity for Midwest to compete for the funding. 12

13 A. Issue an order expanding Midwest s designation as an ETC in its CLEC service area, described herein, for the purposes of receiving high cost federal universal service and Lifeline support; and B. Issue an order, minute action, or other action by the MPSC which sets forth the appropriate ETC certification to the FCC so that Midwest may receive additional federal universal service support, including high cost support and Lifeline support in the requested service area. C. Issue an order granting such other relief as may be necessary or appropriate. Respectfully submitted, Dated: December 14, 2018 Shannon M. Heim (P82718) Moss & Barnett, P.A. 150 South Fifth Street, Suite 1200 Minneapolis, MN Telephone: (612) shannon.heim@lawmoss.com Attorneys for Midwest Energy Cooperative 13

14 STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION In the Matter of the Application of ) MIDWEST ENERGY COOPERATIVE d/b/a ) MIDWEST ENERGY & COMMUNICATIONS for ) Case No. U Expansion of Its Designation As An Eligible ) Telecommunications Carrier in the State of Michigan ) EXHIBIT 1: CENSUS BLOCKS WHERE MIDWEST WAS AWARDED CAF AUCTION FUNDING AND WHERE MIDWEST SEEKS FOR EXPANSION OF ITS ETC STATUS IN THE STATE OF MICHIGAN

15 EXHIBIT 1 CONTENTS Page 1: Page 2: Page 3: Page 4: Page 5: Page 6: Pages 7-8: Page 9: Pages 10-18: RBE & CAFF Phase II Michigan: RBE in Blue; CAF in Green RBE & CAF Phase II West Michigan CAF Phase II Census Blocks ETC Territory ETC East Michigan ETC West Michigan ILECs Serving Midwest s Proposed ILEC Territory by Exchange RBE Census Blocks CAP Census Blocks

16 Exhibit 1: Page 1

17 Exhibit 1: Page 2

18 Exhibit 1: Page 3

19 Exhibit 1: Page 4

20 Exhibit 1: Page 5

21 Exhibit 1: Page 6

22 Exhibit 1: Page 7 Exhibit 1: ILECs Serving Midwest s Proposed ILEC Territory Exchange Cassopolis White Pigeon Three Rivers Constantine Lawton Paw Paw Decatur Dowagiac Niles Edwardsburg Union Vandalia Eau Claire Marcellus Schoolcraft Vicksburg Fulton Kalamazoo Mattawan Scotts Gobles Bloomingdale Covert Coloma Watervilet Hartford Lawrence Sturgis ILEC AT&T Michigan AT&T Michigan AT&T Michigan AT&T Michigan AT&T Michigan AT&T Michigan Bloomingdale Telephone Company AT&T Michigan AT&T Michigan Frontier Midstates Inc.

23 Exhibit 1: Page 8 Exchange Centreville Bangor Mendon Benton Harbor Adrian Tecumseh Blissfield Deerfield Lambertville Ogden Waldron Weston Morenci Clayton Hudson Onsted Addison Tipton Stockbridge Gregory Chelsea Clinton Sister Lakes ILEC AT&T Michigan Deerfield Farmers Telephone Company Frontier Midstates Inc. Ogden Telephone Company Waldron Telephone Company Sand Creek Telephone Company Frontier Midstates Inc. Communications Corporation of Michigan (TDS) Frontier Communications of Michigan, Inc. Frontier Midstates Inc. Frontier Midstates Inc. Frontier Midstates Inc. AT&T Michigan

24 FRN Winner State Census Block ID Midwest Energy Cooperative, Inc. Michigan Midwest Energy Cooperative, Inc. Michigan Midwest Energy Cooperative, Inc. Michigan Midwest Energy Cooperative, Inc. Michigan Midwest Energy Cooperative, Inc. Michigan Midwest Energy Cooperative, Inc. Michigan Midwest Energy Cooperative, Inc. Michigan Midwest Energy Cooperative, Inc. Michigan Midwest Energy Cooperative, Inc. Michigan Midwest Energy Cooperative, Inc. Michigan Midwest Energy Cooperative, Inc. Michigan Midwest Energy Cooperative, Inc. Michigan Midwest Energy Cooperative, Inc. Michigan Midwest Energy Cooperative, Inc. Michigan Midwest Energy Cooperative, Inc. Michigan Midwest Energy Cooperative, Inc. Michigan Midwest Energy Cooperative, Inc. Michigan Midwest Energy Cooperative, Inc. Michigan Midwest Energy Cooperative, Inc. Michigan Midwest Energy Cooperative, Inc. Michigan Midwest Energy Cooperative, Inc. Michigan Midwest Energy Cooperative, Inc. Michigan Midwest Energy Cooperative, Inc. Michigan Midwest Energy Cooperative, Inc. Michigan Midwest Energy Cooperative, Inc. Michigan Midwest Energy Cooperative, Inc. Michigan Midwest Energy Cooperative, Inc. Michigan Midwest Energy Cooperative, Inc. Michigan Midwest Energy Cooperative, Inc. Michigan Midwest Energy Cooperative, Inc. Michigan Exhibit 1: Page 9

25 Exhibit 1: Page 10 FRN Winner State County Census Block ID Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass

26 Exhibit 1: Page Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass

27 Exhibit 1: Page Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Cass Midwest Energy Cooperative, Inc. Michigan Kalamazoo Midwest Energy Cooperative, Inc. Michigan Kalamazoo Midwest Energy Cooperative, Inc. Michigan Kalamazoo Midwest Energy Cooperative, Inc. Michigan Kalamazoo Midwest Energy Cooperative, Inc. Michigan Kalamazoo Midwest Energy Cooperative, Inc. Michigan Kalamazoo Midwest Energy Cooperative, Inc. Michigan Kalamazoo Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee

28 Exhibit 1: Page Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee

29 Exhibit 1: Page Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee

30 Exhibit 1: Page Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee

31 Exhibit 1: Page Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan Lenawee Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph

32 Exhibit 1: Page Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph

33 Exhibit 1: Page Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan St. Joseph Midwest Energy Cooperative, Inc. Michigan Van Buren Midwest Energy Cooperative, Inc. Michigan Van Buren Midwest Energy Cooperative, Inc. Michigan Van Buren Midwest Energy Cooperative, Inc. Michigan Van Buren Midwest Energy Cooperative, Inc. Michigan Van Buren Midwest Energy Cooperative, Inc. Michigan Van Buren Midwest Energy Cooperative, Inc. Michigan Van Buren Midwest Energy Cooperative, Inc. Michigan Van Buren Midwest Energy Cooperative, Inc. Michigan Van Buren Midwest Energy Cooperative, Inc. Michigan Van Buren Midwest Energy Cooperative, Inc. Michigan Van Buren Midwest Energy Cooperative, Inc. Michigan Van Buren Midwest Energy Cooperative, Inc. Michigan Van Buren Midwest Energy Cooperative, Inc. Michigan Van Buren Midwest Energy Cooperative, Inc. Michigan Van Buren Midwest Energy Cooperative, Inc. Michigan Van Buren Midwest Energy Cooperative, Inc. Michigan Van Buren Midwest Energy Cooperative, Inc. Michigan Van Buren Midwest Energy Cooperative, Inc. Michigan Van Buren

34 STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION In the Matter of the Application of ) MIDWEST ENERGY COOPERATIVE d/b/a ) MIDWEST ENERGY & COMMUNICATIONS for ) Case No. U Expansion of Its Designation As an Eligible ) Telecommunications Carrier in the State of Michigan ) EXHIBIT 2: MIDWEST S VOICE OVER INTERNET PROTOCOL ( VoIP )

35 VOICE NETWORK Exhibit 2: Page 1 Voice over Internet Protocol (VoIP) service originates from Alianza Softswitches. Voice traffic traverses the Internet via multiple diverse route GRE Secured Tunnels to MEC customers via Everstream Internet Service and Hurricane Internet Service. MEC delivers VoIP service to customers?home outlets through a fiber connection via devices called Optical Line Terminals (OLT) and Optical Network Terminals (ONT). MIDWEST COMMUNICATIONS ALIANZA CLOUD NETWORK 3 Physical Servers with vsphere 6.5 and High Availability Operating Systems for Calix CMS, Internet DHCP, DNS, Syslog, Video, Network Hurricane Internet Service Anaheim Data Center Everstream Internet Service Sacramento Data Center Internet/VoIP VLAN Traffic 10 Gbps Redundant Transport around Ring SUBSTATION Secured VPN VoIP Traffic MSAG Data WEST SAFETY SERVICES NETWORK PUBLIC SAFETY AUTHORITY Emergency Services Gateway Emergency Services Gateway Session Border Controller GPON PSAP Serving ALI Dynamic ALI Positioning Text Server West Provisioning System GPON Data & Voice

36 Exhibit 2: Page 2 Consumer Guide Voice over Internet Protocol (VoIP) Voice over Internet Protocol (VoIP) is a technology for communicating using "Internet protocol" instead of traditional analog systems. Some VoIP services need only a regular phone connection, while others allow you to make telephone calls using an Internet connection instead. Some VoIP services may allow you only to call other people using the same service, but others may allow you to call any telephone number - including local, long distance, wireless and international numbers. How VoIP works VoIP converts the voice signal from your telephone into a digital signal that can travel over the Internet. If you are calling a regular telephone number, the signal is then converted back at the other end. VoIP calls can be made from a computer, a special VoIP phone, a traditional phone with or without an adapter, or using a wireless phone, depending on the type of VoIP service you subscribe to. Here is one example of how VoIP service works: What equipment do I need? Depending on the VoIP service you purchase, you may need a computer, a special VoIP telephone or a regular telephone with an adapter. If you are calling a regular telephone number, the person you are calling does not need any special equipment: just a telephone. Are there special considerations for using VoIP? If you re considering replacing your traditional telephone service with VoIP, be aware that: Some VoIP service providers may have limitations to their 911 service. For more information on VoIP and 911 services, see the FCC s guide at Some VoIP services don t work during power outages and the service provider may not offer backup power. VoIP providers may or may not offer directory assistance/white page listings. Always check with potential VoIP service providers to confirm any limitations to their service, including 911 service. 1 Federal Communications Commission Consumer and Governmental Affairs Bureau th St. SW. Washington, DC CALL-FCC ( ) TTY: TELL-FCC ( )

37 Exhibit 2: Page 3 With VoIP, is there a difference between making a local and a long distance call? Some VoIP providers do not charge for calls to other subscribers to the service. Some VoIP providers charge for a long distance call to a number outside your calling area. Other VoIP providers permit you to call anywhere at a flat rate for a fixed number of minutes. Your VoIP provider may permit you to select an area code for your VoIP service that is different from the area code in which you live. How does the FCC regulate VoIP? 911 Services: Providers of "interconnected" VoIP services which allow users generally to make calls to and receive calls from the regular telephone network do have 911 service obligations; however, 911 calls using VoIP are handled differently than 911 calls using your regular telephone service. Portability: The FCC requires interconnected VoIP providers and telephone companies to comply with Local Number Portability (LNP) rules. (See our guide on Portability Calling Records: The FCC limits interconnected VoIP providers' use of customer proprietary network information such as your telephone calling records, and requires interconnected VoIP providers to protect it from disclosure. Universal Service: The FCC requires interconnected VoIP providers to contribute to the Universal Service Fund, which supports communications services in high-cost areas and for income-eligible telephone subscribers. Accessibility: Interconnected VoIP providers must contribute to the Telecommunications Relay Services Fund used to support the provision of telecommunications services to persons with speech or hearing disabilities and offer 711 abbreviated dialing for access to relay services. Providers and equipment manufacturers also must ensure their services are available to and usable by individuals with disabilities, if such access is achievable. (See our guide about TRS Filing a complaint If you have concerns about an interconnected VoIP provider's handling of your 911 calls or telephone calling records, making services available to and usable by individuals with disabilities, or porting your telephone number, first try to resolve the matter with your service provider. If you can't resolve the matter directly, you have multiple options for filing a complaint with the FCC: File a complaint online at By phone: CALL-FCC ( ); TTY: TELL-FCC ( ) ; ASL: By mail (please include your name, address, contact information and as much detail about your complaint as possible): Federal Communications Commission Consumer and Governmental Affairs Bureau Consumer Inquiries and Complaints Division th Street, S.W. Washington, DC Accessible formats To request this article in an accessible format - braille, large print, Word or text document or audio - write or call us at the address or phone number above, or send an to fcc504@fcc.gov. Last Reviewed: 1/27/17 2 Federal Communications Commission Consumer and Governmental Affairs Bureau th St. SW. Washington, DC CALL-FCC ( ) TTY: TELL-FCC ( )

38 Exhibit 2: Page 4 Alianza Key Products: Cloud-based VoIP platform Summary: Though early fiber-to-the-home deployers were mainly telephone companies, many of today s new entrants to the FTTH field have no history of providing voice services. For a broadband operator without telephone equipment or expertise, using a cloud-based system is the simplest, most economical way to add a voice offering typically a highmargin service. Alianza s Cloud Voice Platform, a web-scale voice over IP (VoIP) solution built for broadband providers, provides the functions required to deliver and support residential and business VoIP services. The platform does not require capital expenditure or equipment installation, and Alianza alleviates most operational and regulatory burdens associated with phone services. Since announcing a solution specifically for FTTH providers in February 2017, Alianza has made inroads with electric cooperatives, utilities and municipalities that deliver FTTH broadband to their communities. In the last year, Alianza has signed on more than 10 new FTTH ISPs to help them launch VoIP or replace outdated solutions and improve their phone services. The company has added more than 60 ISPs from the Cable MSO, Satellite, FTTH & Wireless segments on the platform with over 300,000 end-user subscribers under contract since being founded in Alianza is headquartered in Lindon, Utah, Alianza has more than 60 employees. Platform Overview: Alianza s Cloud Voice Platform is a web-scale, turnkey solution that enables service providers to rapidly customize, launch and profit from VoIP and UC services. Using a virtualized software core provides scale and agility while our SaaS model provides a success-based model that aligns our interests with our Service Provider customers. Built with our intellectual property and code, we have control over innovation and responsiveness to market changes and requirements. The Cloud Voice Platform features comprehensive back-office integration and webbased management tools that enable automation of administration and provisioning to significantly drive down time and costs related to customer care and support. Alianza s solution integrates with carrier services for telephone numbers, LNP, e911 and PSTN interconnection. Our solution includes Core platform with all of today s 100+ end-user features for residential, business lines, Hosted PBX and SIP trunking services APIs for back office integration to OSS/BSS applications Simple, all-in pricing model v1

39 Exhibit 2: Page 5 Maintenance and ongoing enhancements (operational and end-user enhancements) E911 Operational tools for support and NOC Fraud prevention Built-in troubleshooting tools Unmatched API integration with carrier services for porting, 911, CNAM, directory listing and DID management Launch management and training Go-to-market assistance Branded end-user portal Availability & Scalability: Redundancy and resiliency are key tenets in the architecture of the Alianza Cloud Voice Platform. The solution leverages geographically redundant data centers, best-of-breed security technologies and an active-active service architecture. Alianza defines cloud at a higher bar than others in the space. The Alianza elastic cloud architecture is built on OpenStack, in which all platform components are virtualized except SBC services. There are no individual servers or clusters. All components are built in redundant clusters which are designed for resiliency and zero downtime. The platform is both intra-site redundant and inter-site redundant, with automated failover in the event a service or site is responding in a less-than-optimal timeframe. Each Alianza service and site are in production and available in an active-active architecture. Meaning that at any given time, each end-user device can access either site. In the event of any connectivity issue to a specific site, the end-user device will switch sites. Device registration, call state and all account settings are replicated realtime between sites. Site Architecture: v1

40 v1 Exhibit 2: Page 6

41 STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION In the Matter of the Application of ) MIDWEST ENERGY COOPERATIVE d/b/a ) MIDWEST ENERGY & COMMUNICATIONS for ) Case No. U Expansion of Its Designation As an Eligible ) Telecommunications Carrier in the State of Michigan ) EXHIBIT 3: LOCAL USAGE PLANS

42 MONTHLY LOCAL SERVICE RATE BUSINESS $49.95/ month Unlimited Long Distance RESIDENTIAL $39.95/ month Unlimited Long Distance SERVICE CHARGES BUSINESS Activation Fee: $10.00 Reconnection Fee: $25.00 RESIDENTIAL Activation Fee: $10.00 Reconnection Fee: $25.00

43 STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION In the Matter of the Application of ) MIDWEST ENERGY COOPERATIVE d/b/a ) MIDWEST ENERGY & COMMUNICATIONS for ) Case No. U Expansion of Its Designation As an Eligible ) Telecommunications Carrier in the State of Michigan ) EXHIBIT 4: MIDWEST TARIFF EXCERPTS

44 Exhibit 4: Page 1 Midwest Energy Cooperative d/b/a Midwest Energy & Communications TariffM. P.S.C. No. I Section 4 - Original Page LIFELINE SERVICE A. DESCRIPTION SECTION 4 - RATES AND CHARGES, CONT'D. I. Lifeline applies discounts to monthly recurring rates for qualifying residential customers. These discounts are applied to existing rates and charges for residential telephone service. 2. In order to be eligible for Lifeline, a residential customer's annual household income must be at or below 150 percent of the poverty level, as determined by the U.S. Department of Health and as approved by the State Treasurer or the person must participate in one of the following programs: a. Medicaid b. Supplemental Nutrition Assistance Program (SNAP) - Food Stamps c. Supplemental Security Income (SSI) d. Federal Public Housing Assistance/Section 8 e. Low Income Home Energy Assistance Program (LIHEAP) f. National School Lunch Program's free lunch Program g. Temporary Assistance for Needy Families (TANF) aka Family Independence Program h. Veterans Pension i. Survivors Pension In addition to the criteria above, applicants residing on Tribal Lands [referenced in Title 25 Code of Federal Regulations, Section 20.1, paragraph (v)] may also qualify if they participate in one of the following federal assistance programs: a. Bureau of Indian Affairs general assistance b. Tribally administered Temporary Assistance for Needy Families (TANF) c. Head Start (must meet program's income qualifying standard) d. Food Distribution Program on Indian Reservations Applicants residing on tribal lands must sign under penalty of perjury that he/she resides on a reservation/as defined in Title 25 Code of Federal Regulations, Section 20.1, paragraph (v), and receives benefits from at least one of the programs referenced above. The Tribal Lands Applicant also must agree to notify the Company if they cease to participate in the program LIFELINE SERVICE (cont'd) Issued: Effective: _ Issued by: Robert L. Hance, Chief Executive Officer Decatur Road Cassopolis, Michigan Bob.Hance@teamm.idwest.com

45 Exhibit 4: Page 2 Midwest Energy Cooperative d/b/a Midwest Energy & Communications TariffM. P.S.C. No. I Section 4 - Original Page 13 A. DESCRIPTION (cont'd) 3. Other services can be provided with the Lifeline Service at applicable rates and charges. 4. Proof of eligibility will be required for all initial lifeline applicants and all lifeline recipients will be required to re-certify every year. B. REGULA TIO NS I. Regulations specified elsewhere in the Company's tariffs apply to Lifeline. 2. Lifeline is available only with residential services, excluding foreign exchange service. Lifeline is limited to a single subscription per household where household is defined to be any individual or group of individuals who are living together at the same address as one economic unit. For the purposes of this rule, an economic unit consists of all adult individuals contributing to and sharing in the income and expenses of a household. 3. A miscellaneous service charge does not apply where Lifeline is added or discontinued to existing service when that is the only work being done. 4. The Lifeline plan will apply after receipt and processing of a completed Lifeline application, including documentation indicating that the household income meets the eligibility standards established above. 5. Customers of Lifeline must notify the Company of any changes which would affect qualification. Recertification of eligibility will take place on an ongoing basis. When the customer is no longer eligible for Lifeline service, the Lifeline discount will be discontinued and regular rates and charges will apply. 6. As a participant in Lifeline, customers are eligible to receive toll blocking service at no charge. This service will only be provided at the customer's request. Toll blocking service is defined as a central office service that restricts access to the network. Toll blocking is provided where facilities permit and will not allow I+, O+, 0-, 101XXXX, 900, or interzone calls to be completed. Toll blocking does not restrict local calls, calls to intranpa directory assistance, telephone repair service, 911, or calls to 800 or 950 numbers. 7. Local service deposit requirements will be waived for customers who voluntarily receive Toll Blocking Service. 8. Participants in Lifeline shall not be disconnected from local service for nonpayment of toll charges. In addition, the Company will not deny re-establishment of local service to customers who are eligible for Lifeline and have previously been disconnected for nonpayment of toll charges LIFELINE SERVICE (cont'd) Issued: Effective: _ Issued by: Robert L. Hance, Chief Executive Officer Decatur Road Cassopolis, Michigan Bob.Hance@teammidwest.com

46 Exhibit 4: Page 3 Midwest Energy Cooperative d/b/a Midwest Energy & Communications TariffM. P.S.C. No. I Section 4 - Original Page 14 C. RATES AND CHARGES I. The discount on the monthly rate for residential exchange service for qualified Lifeline customers shall be $9.25 from the Federal discount program plus $2.00 from the State discount program for a total discount of$ Credits are applied to the end user's basic local exchange service. At no time shall the total Lifeline credit exceed the sum of the end user common line charge and the basic local exchange rate. The discount on the monthly rate for residential exchange service for qualified Lifeline customers 65 years of age or more shall $9.25 from the Federal discount program plus $3.10 from the State discount program for a total discount of $ Credits are applied to the end user's basic local exchange service. At no time shall the total Lifeline credit exceed the sum of the end-user common line charge and the basic local exchange rate. Qualified participants residing on tribal lands will receive, in addition to the discounts listed above, an additional federal approved reduction of up to $25.00 applied to the monthly local service rate. Issued: Effective: Issued by: Robert L. Hance, Chief Executive Officer Decatur Road Cassopolis, Michigan Bob.Hance@teammidwest.com