Douglas Denney Vice President, Costs & Policy Company Representative Electric Lightwave 18110 SE 34th St. Building One, Suite 100 Vancouver, WA 98683 360.558.4318 dkdenney@cls;,Q.triciightwave.cQm

BEFORE THE PUBLIC SERVICE COMMISSION OF

In the Matter oflntegra Telecom ofUtah, Docket No. 16-2299-01 Inc.'s Notice ofName Change to Electric Lightwave Holdings, Inc.

In the Matter of the Application of Integra Telecom of Utah, Inc. for a Certificate Docket No. 99-2299-01 Authorizing it to Provide Local Exchange Service as a Telecommunications Provider in the State of Utah

Request for Review of Commission Order

Integra Telecom of Utah, Inc. ("Integra") requests the Commission rescind its order issued on November 22, 2016.

Background

On August 4, 2016 Integra's parent company, Integra Telecom Holdings, Inc. announced an internal organizational change that included changing the name of the corporate holding

1 company from Integra Telecom Holdings, Inc. to Electric Lightwave Holdings, Inc. 1 In addition, the legal entity Integra Telecom Parent, Inc. was renamed to Electric Lightwave Parent, Inc. and

Integra Telecom, Inc. was renamed to Electric Lightwave Communications, Inc? The Company did not change the name of any state certified operating entity, including Integra Telecom of

Utah, Inc.

On October 19, 2016 Electric Lightwave Holdings, Inc. sent a letter from its accounts payable manager to all external entities to which payments are made, including the Utah Public

Service Commission. The intent of the letter was to inform entities that Integra Telecom

Holdings, Inc. changed its name to Electric Lightwave Holdings, Inc. and make sure that entities which receive payments from the company were aware of the name change along with accounts payable terms and conditions. Unfortunately, the letter was not clear and stated that "Integra

Telecom changed its name to Electric Lightwave Holdings, Inc."3

On November 22, 2016 the Commission issued an order approving the change in the name oflntegra Telecom of Utah, Inc. to Electric Lightwave Holdings, Inc.4

Request

Integra respectfully requests that the Commission rescind its November 22, 2016 order.

The Company did not change the name of its operating entities in Utah and did not intend its letter to be taken as a request for a name change. Integra Telecom of Utah, Inc. continues to

1 See http://www.electricligbtwave,\;_OJn/about-us/~:;legtric-lightwave-to-operaJ§:::f\.t>_~11:~tan4g1Ql1.£:JThQ.r-based­ network-services-corQQ_any/ 2 See the corporate organizational chart attached as Exhibit A. 3 Notice ofName Change, Docket No. 16-2299-01, October 28, 2016. 4 Order Acknowledging New Name and Amending Certificate of Public Convenience and Necessity, Docket No. 16-2299-01, November 22,2016.

2 operate in Utah under its current Certificate of Public Convenience and Necessity without change.

Integra appreciates the Commission's prompt attention to this matter and is happy to provide any additional information required by the Commission to correct this misunderstanding.

DATED: November 28, 2016

Douglas Denney

3 Electric Lighnvave Parent, Inc. (DE Corporation)

Electric Lightwave Communications, Inc. (OR Corporation)

Electric Lightwave Holdings, Inc. (OR Corporation)

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