Frontier West Virginia Inc. Case No, 12-0284-E-T-C

FRONTIER WEST VIRGINIA INC. CASE NO, 12-0284-E-T-C

Response to First Set of Interrogatories, Data Request or Requests for Information by the Staff of the Public Service Commission of West Virginia from Frontier West Virginia Inc.

Request No. 1, Dated May 24, 2013

Name and Title of the Person who prepared the Response: Jim Corwin, Manager - Operations

Name(s) of the Person(s) who could testify regarding the Response: Jim Corwin, Manager - Operations

Date the Response was Prepared: June 24, 2013

1.10. For each state in which a Frontier affiliated ILEC operates and for which the state utility commission does not determine pole attachment rates for joint use between an electric distribution utility and an Incumbent Local Exchange Carrier:

A. Provide the current pole attachment rate being charged by the Frontier affiliated ILEC to an electric distribution utility in each applicable state.

B. Provide the current pole attachment rate being charged to the Frontier affiliated ILEC by an electric distribution utility in each applicable state.

C. Is the pole attachment rate provided in response to 1.10.A. and/or 1.10,B. determined by a joint use agreement between the Frontier affiliate and the electric distribution utility?

D. For each pole attachment rate provided in response to 1.10.A. (i.e., rates assessed by Frontier), please provide the formula or complete description of the method by which the Frontier pole attachment rate is determined including the definition of each term to include the following if applicable: space occupied, usable space, carrying charge rate, unusable space, pole height, and applicable rate of return.

E. For each pole attachment rate provided in response to 1.10.B. (i.e., rates paid by Frontier), please provide the formula or complete description of the method by which the Frontier pole attachment rate is determined including the definition of each term to include the following if applicable: space occupied, usable space, carrying charge rate, unusable space, pole height, and applicable rate of return. RESPONSE 1.10:

Without waiving any objection, Frontier responds as follows:

Frontier-affiliated ILECs have approximately 478 joint use agreements with electric companies in 27 states. Some of these agreements were entered into as long as 50 years ago or more. These agreements are located in multiple offices spread across the country. Many of these agreements were entered into by predecessor entities that have been merged or consolidated out of existence, further complicating any attempt to respond to this Request. Frontier has consulted with Staff about narrowing this Request to make answering it more manageable. Based upon discussions with Staff, Frontier is gathering the most recent and readily available non-confidential rate data, and will forward it to Staff as soon as it is available. FRONTIER WEST VIRGINIA INC. CASE NO. 12-0284-E-T-C

Response to First Set of Interrogatories, Data Request or Requests for Information by the Staff of the Public Service Commission of West Virginia from Frontier West Virginia Inc.

Request No. 1, Dated May 24, 2013

Name and Title of the Person who prepared the Response: John Blake, Supervisor - Engineering

Name(s) of the Person(s) who could testify regarding the Response: John Blake, Supervisor - Engineering

Date the Response was Prepared: June 24, 2013

1.11. For Frontier-WV, please provide the following information for each year 2007 to most recent available data:

A. The total annual amount charged by Frontier-WV to all Cable TV Providers for any such charges resulting from a pole joint use agreement or pole rental agreement and a breakdown by general class of such charges such as "make ready" charges, pole rental rates, etc., and by name of the Cable TV provider.

B. The total annual revenue received by Frontier-WV to all Cable TV Providers for any such charges resulting from a pole joint use agreement and a breakdown by general class of such charges such as "make ready" charges, pole rental rates, etc., and by name of the Cable TV provider. Please include information as to which utility accounts and sub-accounts each of such revenues would be recorded.

RESPONSE 1.11:

Without waiving any objection, Frontier responds as follows:

This information is proprietary and confidential, and some of the agreements expressly prohibit the disclosure of agreement terms. In an effort to provide data that the Staff has requested while preserving the confidentiality of that data and not violating the terms of agreements to which Frontier is a party, Frontier is providing a spreadsheet including amounts charged to CATVs, identifying the general class of such charges as pole rent, make ready, or pre-license survey for each year 2007 through 2012. The available information responsive to Request No. 1.11 is set forth in the attached spreadsheet entitled "Response 1- 1.11." These revenues are recorded to the following accounts: Revenue Type Revenue Accounts Pole Rents 5240-100-000-131 Make Ready - Capital 2411.100.000.423 Make Ready - Expense 6411.000.253.345 Pre-License Surveys 5240-100-000-131 12-0284-E-T-C Frontier WV Response to Staff Data Request No. 1, Dated May, 24, 2013, Request 1.11 Response 1 - 1.11

2012 2007 2008 2009 2010 2011 CAW Pre-License Pre•License Pre-License Pre-License Pre-License Pre•License Contract Pole Rent Make-Ready Survey Fees Pole Rent " Make-Ready Survey Fees Pole Rent ** Make-Ready Survey Fees Pole Rent " Make-Ready Survey Fees Pole Rent 4* Make-Ready Survey Fees Pole Rent" Make-Ready Survey Fees

Invoiced $ 12,789.40 $ 29.00 5 12,801.75 $ 27.00 $ 12,802.70 $ 44,662.89 5 425.00 27.00 $ 44,662.89 5 425.00 1 Received 1$ 29.00 5 35.00 $26,318.64 Invoiced $ 12,353.06 $ 11,413.32 5 12,359.70 5 5,512.28 $ 265.00 5 25,514.45 $ 1,341.22 27.00 $ 26,772.64 $ 8,584.00 5 35.00 26,318.64 2 Received 5 5,512.28 $ 265.00 $ 1,341.22 27.00 5 13,613.07 $ 8,584.00 $ 830.00 $ 8,319.31 Invoiced 5 3,924.98 $ 3,924.98 $ 3,924.98 r $ 160.00 $ 11,398.40 $ 4,806.56 $ 53,134.25 5 830.00 $ 4,206.50 3 Received $ 160.00 3,924.98 $ 38,834.35 $ 11,763.82 $ 1,561.00 5 11,455.98 5 225.00 Invoiced 5 11,327.51 $ 35.00 S 11,358.26 $ 11,354.09 11,373.23 $ 11,367.38 $ 11,763.82 5 1,561.00 $ 11,367.38 $ 225.00 4 Received $ 35.00 $ 11,367.38

Invoiced $ 6,633.93 5 Received 26.58 invoiced 5 53.16 5 53.16 5 53.15 53.16 $ 53.16 $ 6 Received $ 2,848.00 $5,457.76 Invoiced $ 5,395.74 5 5,395.74 $ 5,395.74 51,308.96 $ 697.00 $ 5,457.76 $ 5,457.76 2,848.00 5,457,76 7 Received 5 1,308.96 5 697.00 $ 5,457.76 $ 5

Invoiced $ 2,857.35 -- 5 2,593.77 5 2,330.18 $ 2,330.09 8 Received

Invoiced $ 655.64 5 655.64 5 655.64 $ 655.64 9 Received

Invoiced 5 691.08 Received 10 . .I i $ 400.00 $3,499.70 r Invoiced 5 3,397.81 $ 175.00 5 3,429.69 $75.00 $ 3,428.82 $ 3,428.82 $ 3,428.82 400.00 $ 3,464.26 11 Received $ 175.00 $ 75.00 $ 3,428.82 5

$14,871.52 Invoiced $ 14,849.36 $ 20,336.86 $4,082.95 $ 14,849.36 S 7,435.76 $ 10,079.51 12 Received $ 4,082.95 5 84,351.64 Invoiced 81,631.61 $ 51,556.72 $ 415.00 $ 85,403.72 $ 83,190.98 $ 83,195.77 5 83,775.74 $ 53,875.95 13 Received $ 47,558.72 $ 415.00 83775.74

Invoiced $ 128,473.57 $ 33.00 14 Received 5 33.00 ,-- $ $ 2,090.96 $2,090.96 Invoiced 5 2,030.96 $ 2,588.46 $ 2,090.96 2,090,95 $ 2,090.96 is Received $ 1,28430 Invoiced $ 1,284.70 $ 1,284.70 $ 1,284.70 $ 1,284.70 $ 1,284.70 1,284.70 16 Received $ 1,284.70 $

Invoiced $ 553.75 5 553.76 $ 553.75 $ 553,76

17 Received _ $2,746.60 Invoiced $ 2,219.42 $ 2,356.75 $ 2,746.60 5 2,746,60 S 2,746.60 2,746.60 18 Received $ 63,025.62 ' $ 7,413.98 $ 185.00 Invoiced $ 62,033.29 5 25,877.00 $ 65,899.77 5 7,622.61 $ 27.00 $ 62,698.94 $ 9,733.36 $ 1,853.00 5 62,839.55 $ 1,586.51 60.00 $ 62,945,88 5 63,025.62 $ 5 185.00 19 Received 5 25,877.00 $ 1,141.61 27.00 $ 7,879.74 $ 1,853.00 60,00 $ 62,945.88 $ 42,997.59 $ 33,712.43 $ 667.00 Invoiced 5 37,418.00 $ 2,076.75 $ 38,316.84 $ 16,329.46 93.00 $ 38,275.20 $ 14,571.02 404.00 5 42,044.32 $ 53,315.09 5 2,008.00 $ 42,752.27 $ 135,725.44 $ 2,707.00 $ $ 11,019.15 404,00 $ 25,995.43 $ 2,008.00 $ 329,289.89 $ 2,707.00 $ 42,139.96 5 17,134.48 $ 657.00 20 Received $ 2,076,75 $ 16,329.46 93.00 S 1 Invoiced $ 101.89 21 Received

Invoiced $ 1,222.68 $ 1,222.68 $ 1,222.68 $ 1,222.68 22 Received Invoiced $ 106,32 106.32 106.32 106.32 23 Received J. Invoiced $ 3,796.51 $ 3,796.52 $ 3,796.51 24 Received 40,445.90 $ 6,357.32 $ 908,00 Invoiced 5 32,755.42 5 26,464.82 $ 38,565.65 $ 5,130.00 5 26,558.30 $ 39,207.72 $ 1,438.38 288.00 $ 39,834.56 96.00 $ 96,00 $ 40,445.90 $ 2,922.50 $ 908.00 25 Received $ 34,673.38 5 5,130.00 S 288.00 ' Invoiced $ 32,750.99 $ 13,235.37 $ 1,968.00 5 39,185.28 39,199.19 26 Received $ 3,161.95 $ 1,968.00

Invoiced $ 55,857.87 27 Received - Invoiced $ 2,002.36 $ 2,002.36 $ 2,002.36 75.32 28 Received

Invoiced $ 2,883.93 29 Received

Invoiced $ 55.38 30 Received

Invoiced S 5,919.66 31 Received

Invoiced S 9,883.33 32 Received ] 1 $ 240,017.94 $ 6,918.00 Invoiced $ 152,080.52 6,918.00 33 Received 1 $ $ 522.74 Invoiced $ 522.74 522.74 $ 522.74 522.74 522.74 $ 522.74 34 Received $

Invoiced $ 10,476.95 $ 34,803.65 $ 10,842.01 $ 10,742.75 S 10,742.76 35/ Received $ 5,699.76 1 1 146.20 1 Invoiced $ 110.2$ 123.30 313.00 114.61 $ 147.29 146.20 $ 36 Received $ 313.00 $ 146.20

Invoiced $ 190.45 190.48 190.49 37 Received 1 i

Invoiced 5 141.76 141.75 141.76 5 141.76 141.76 $ 141.76 38 Received $ 141.76 i

invoiced 5 4,833.13 $ 4,833.12 $ 4,833.12 39 Received Invoiced $ 1,258.12 $ 1,258.12 $ 5,258.12 $ 1,258.12 40 Received $ 26.58 Invoiced $ 26.58 $ 26.581 $ 26,58 $ 26.58 26.58 41 Received

Invoiced 5 115.18 $ 115.18 1 $ 115.18 42 Received H

Invoiced $ 40,326.29 $ 43,619.65 $ 44,362.02 43 Received iii Invoiced 5 766.39 $ 766.40 $ 766.39 $ 383.20 44 Received $ 8,268.60 $ 54,221.63 $ 3,163.00 invoiced $ 180,568.97 5 102,455.00 $ 4,913.86 $ 14,176.11 $ 145,228.58 $ 27,429.00 $ 139,860.05 $ 27,429.00 $ 8,268.60 $ 5,294.63 $ 3,163.00 45 Received $ 180,568.97 $ 102,456.00 $ 30,509.00 Invoiced $ 17,827.75 5 72,807.16 $ 30,420.00 $ 30,509.00 $ 26,816.22 $ 30,509.00 46 Received $ 58,191.16 $ 30,420.00 $ 275,260.19 S 23,002.00 Invoiced 5 275,260.19 $ 23,002.00 47 Received 1 $ 1,114.00 $ 196,012.82 $ 61,978.16 $ 20,120.00 Invoiced 5 214,714.38 $ 197,105.00 $ 15,400.82 $ 1,584.00 $ 199,326.95 $ 10,755.17 $ 317.00 $ 197,156.36 $ 16,203.55 $ 196,012.82 $ 37,724.06 $ 20,120.00 48 Received $ 1,584.00 $ 10,755.17 $ 317.00 $ 197,156.36 $ 13,079.02 5 1,114.00

Invoiced $ 212.64 $ 212.64 49 Received

Invoiced $ 979-03 $ 979.04 $ 42,861.70 $ 300,00 $ 979.03 so Received 5 42,024.00 $ 300.00

Invoiced $ 4,713.52 $ 4,713.52 $ 4,713.52 $ 4,713.52 51 Received

Invoiced S 447.431 $ 447.44 $ 447.43 52 Received I 37,020.00 542,520.20 $ 678,961.65 $ 55,188.00 Total Invoiced $ 604,091.65 5 127,549.49 $ 2,655.00 $ 624,238.87 $ 109,775.38 $ 5,652.00 $ 597,144.60 $ 271,758.30 $ 107,844.00 $ 535,583.73 $ 141,243.53 $ 33,332.64 $ 537,431.54 $ 370,640.64 $ $ 409,770.91 $ 343,411.13 $ 37,020.00 $ 502,704.85 $ 490,416.38 $ 55,188.00 Total Received $ • $ 84,374.13 $ 2,655.00 $ - 98,564.20 $ 5,652.00 $ - $ 250,951-99 5 107,844.00 $ - 5 96,282.98 $ 33,120.00

#. Frontier cannot access amounts received for pole rental FRONTIER WEST VIRGINIA INC. CASE NO. 12-0284-E-T-C

Response to First Set of Interrogatories, Data Request or Requests for Information by the Staff of the Public Service Commission of West Virginia from Frontier West Virginia Inc.

Request No. 1, Dated May 24, 2013

Name and Title of the Person who prepared the Response: John Blake, Supervisor - Engineering

Name(s) of the Person(s) who could testify regarding the Response: John Blake, Supervisor - Engineering

Date the Response was Prepared: June 24, 2013

1.12. For Frontier-WV, please provide the following information, for each year 2007 to most recent available data:

A. The total annual amount charged by Frontier-WV to all Competitive Local Exchange Carriers (CLECs) for any such charges resulting from a pole joint use agreement and a breakdown by general class of such charges such as "make ready" charges, pole rental rates, etc., and by name of the CLEC.

B. The total annual revenue received by Frontier-WV from all Competitive Local Exchange Carriers for any such charges resulting from a pole joint use agreement and a breakdown by general class of such charges such as "make ready" charges, pole rental rates, etc., and by name of the CLEC. Please include information as to which utility accounts and sub-accounts each of such revenues would be recorded.

RESPONSE 1.12:

Without waiving any objection, Frontier responds as follows:

This information is proprietary and confidential, and some of the agreements expressly prohibit the disclosure of agreement terms. In an effort to provide data that the Staff has requested while preserving the confidentiality of that data and not violating the terms of agreements to which Frontier is a party, Frontier is providing a spreadsheet including amounts charged to CLECs, identifying the general class of such charges as pole rent, make ready, or pre-license survey for each year 2007 through 2012. The available information responsive to Request No. 1.12 is set forth in the attached spreadsheet entitled "Response 1- 1.12." These revenues are recorded to the following accounts: Revenue Type Revenue Accounts Pole Rents 5240-100-000-131 Make Ready - Capital 2411.100.000.423 Make Ready - Expense 6411.000.253.345 Pie-License Surveys 5240-100-000-131

12.0284-E•T-C Frontier WV Response to Staff Data Request No. 1, Dated May 24,2013, Request 1,12 Response 1 - 1.12 --, 2009 2010 2011 2012 CLEC 2007 2008 Pre-License Pre.License Pre-License Pre•License Pre-License Pre-License Contract Survey fees Make-Ready Survey Fees Pole Rent " Make-Ready Survey Fees Pole Rent's Make-Ready Survey Fees Pole Rent " Make-Ready Survey Fees Pole Rent " Make-Ready Survey Fees Pole Rent Make-Ready 163.92 Invoiced $163.90 MOM $ 181.53 $ 163.91 $ 163.92 $ 163.92 $ 1 Received

Invoked $ 3,535.14 .1111MMIIIIIIM 3,875.92 $ 3,504.13 $ 925,00 $ 3,504.14 $ 3,504.14 $ 3,504.14 3,504.14 Received 111111MMIIIM 5 925.00 $ IIIIIIIII IIIM 496.16 Invoiced $ 496'36 Mill.=.1111 $ 549.59 MI S. 496.16 $ 496.16 $ 496.16 $ Received $ 496.16 I MINE { 1.11111 Invoiced Mr= $ 908.45 $ 350.00 5 1,447.34 $ 86,835.18 5 2,609.00 $ 1,306.85 5 12,709.69 $ 3,049.00 $ 1,581.52 $ 23,084.92 $ 1,609.00 $ 1,723.28 $ 91,717.91 $ 5,163.00 $ 2,755.46 $ 135,063.42 ' $ 13,506.00 5 82,24441 $ 13,605.00 4 Received MIN= 5 908.45 $ 350.00 $ 86,835.18 I $ 2,600.00 $ 648.09 5 3,049.00 $ 23,084.92 $ 1,609.00 $ 91,717.91 $ 5,15300 $ 2,043.40

Invoiced $ 6,022.59 $ 59,093.10 $ 34,932.00 $ 7,118.93 $ 324,195.01 $ 178,395A5 $ 9,697.21 $ 698,044.51 $ 72,566.00 $ 12,946 68 $ 128,165.62 $ 1,166.00 $ 15,109.95 $ 349,274.30 5 10,305.00 5 Received .111111.11 $ 20,545.59 $ 34,932.00 $ 130,728.00 $ 178,395.45 $ 154,582.08 5 72,566,00 $ 57,982.49 $ 1,166.00 $ 346,130 20 $ 10,305.00

Invoked $ 416.42 allIMMINIM $ 461.19 $ 2184.66 $ 3,844.00 $ 540.46 $ 540.46 $ 549.46 $ 540.46 6 Received M.11.11111MIEM $ 3,844.00 .11.111111. invoiced $ 53.16 $ 162,247.65 $ 8,454.00 MI 0 146.19 $ 225.00 $ 1,550.60 e om.Received N=5 8,454.00 5 225.00 Invoiced IIIII =11.11 $ 79.85 $ 75.32 NI Received =M11111.1111MBNIM 11.1111.1 III IIII IIIIM 4.44 Invoked 1.1 .IIIIIII $ 4.71 $ 111.11.11.11 4.44 9 Received =MENEM 1.11=111111=1111=111 $

111. 1111 .11. -1 --. $ 1,027,005.88 $ 123,428.01 Invoiced =.111111=MI $ 801,255.40 $ 123,428.01 EZ=.1 =MEE= MIME 1111 1111 .. Invoiced $ 834.73 $ 22,740.49 $ 3,477.00 1,349.21 $ 1,045,861.31 $ 141,496.00 $ 1,532.78 $ 197,793.43 $ 17,732.00 5 2,848.50 $ 58,550.25 $ 5,561.00 $ 5,136.59 $ 710,502.52 $ 111,530.00 5,561.00 $ 615,460.76 $ 111,533.00 11 WE= 5 22,740,49 $ 3,477.00 5 1,045,861.31 $ 141,496.00 $ 197,793.43 $ 17,732.00 $ 58,550.25 $

Invoiced 5 146.20 $ 513,436.55 - $ 73,863.00 $ 1,317.93 $ 5,656,357.55 $ 744,945.00 $ 744,945.90 12 Received $ 513,436.85i $ 23,863.00 5 796.25 $ 5,465,601.22 150,861.00 $ 8,857.83 $ 6,818,426.85 $ 881,979.01 Total Invoked 5 12,811.55 $ 244,989.69 $ 47,213.00 $ 15,145.53 $ 1,459,076.16 5 326,335.45 $ 17,381.75 $ 908,547.63 5 94,497.00 $ 23,631.98 $ 209,800.79 5 8,336.00 $ 26,935.26 $ 1,664,931.58 5 6,844.39 $ 6,349,300.73 $ 881,979.01 Total Received 5 206,442.18 5 47,213,00 $ 1,263,424.49 $ 326,335.45 $ 353,023.51 $ 94,497.09 $ 139,617.66 $ 8,336,00 $ 1,566,745.72 $ 150,861.00 $

" Frontier cannot access amounts received for pole rental FRONTIER WEST VIRGINIA INC. CASE NO. 12-0284-E-T-C

Response to First Set of Interrogatories, Data Request or Requests for Information by the Staff of the Public Service Commission of West Virginia from Frontier West Virginia Inc.

Request No. 1, Dated May 24, 2013

Name and Title of the Person who prepared the Response: Jim Corwin, Manager - Engineering

Name(s) of the Person(s) who could testify regarding the Response: Jim Corwin, Manager - Engineering

Date the Response was Prepared: June 24, 2013

1.13. For Frontier-WV, please provide the following information, for each year 2007 to most recent available data:

A. The total annual amount charged by Frontier-WV to an electric distribution utility for any such charges resulting from a pole joint use agreement and a breakdown by general class of such charges such as "make ready" charges, pole rental rates, etc., and by name of the electric utility.

B. The total annual revenue received by Frontier-WV from any electric distribution utility for any such charges resulting from a pole joint use agreement and a breakdown by general class of such charges such as "make ready" charges, pole rental rates, etc., and by name of the electric utility. Please include information as to which utility accounts and sub-accounts each of such revenues would be recorded.

C. For responses to 1.13.A. and 1.13.B., please provide the specific applicable responses for AEP-WV, Monongahela Power Company, and the Potomac Edison Company-WA/ separately.

RESPONSE 1.13:

Without waiving any objection, Frontier responds as follows:

A. This information is proprietary and confidential, and some of the agreements expressly prohibit the disclosure of agreement terms. In an effort to provide data that the Staff has requested while preserving the confidentiality of that data and not violating the terms of agreements to which Frontier is a party, Frontier is providing a spreadsheet including amounts charged to electric distribution utilities, identifying the general class of such charges as pole rent, make ready, or pre-license survey for each year 2007 through 2012. The available information responsive to Request No. 1.13 is set forth in the attached spreadsheet entitled "Response 1- 1.13."

For pole rents, the amount "charged by" Frontier is the amount included in the invoice sent by the electric utility. In nearly all circumstances, Frontier's rental payments to the electric utility exceed the electric utility's rental payments to Frontier, with Frontier making a net payment to the electric utility. So, the electric utilities prepare the invoices showing separate line items for the gross revenue to Frontier and the gross expense to Frontier.

B. In most circumstances, the amount received by Frontier from the electric utility is the same as the amount invoiced. An exception would apply when an electric utility's pole rent invoice is adjusted, in which case, the amount "received" by Frontier is likewise adjusted. These revenues are recorded to the following accounts:

Revenue Type Revenue Accounts Pole Rents 5240-100-000-131 Make Ready — Capital 2411.100.000.423 Make Ready — Expense 6411.000.253.345 Pre-License Surveys 5240-100-000-131

C. For Monongahela Power Company and the Potomac Edison Company-WV, please see the response to Request 1.3. Response 1 -1.13 12-0284-E-T-C Frontier WV Response to Staff Data Request No. 1, Dated May 24, 2013 Request 1.13

2011 2012 2007 2008 2009 2010 ELCO Pre-License Pre-License Pre-License Pre-License Pre-License Pre-License Contract Survey Fees Pole Rent Make-Ready Survey Fees Pole Rent Make-Ready Survey Fees Pole Rent Make-Ready Survey Fees Pole Rent Make-Ready Survey Fees Pole Rent Make-Ready Survey Fees Pole Rent Make-Ready Invoiced 1* Received 5 1,005.00 967.50 Invoiced $ 420.00 $ 420.00 $ 420.00 $ 420.00 420.00 $ 1,005.00 967.50 2 Received $ 420.00 $ 420.00 $ 420.00 $ Invoiced 5 52.50 $ 52.50 $ 52.50 $ 52.50 3 Received $ 5230 $ 5230 $ 52.50 $ 52.50

Invoiced $ .. 575.00 $ _ .. . 62230 $ 547.50 5 547.50 $ 547.50 4 Received $ 525.00 $ 622.50 5 54730 $ 135,601.09 $ 122,748.12 $ 116,955.12 Invoiced $ 134,107.07 $ 98A74.24 5** Received +++ $ 138,060.23 $ 3,136.53 $ 137,978.61 Invoiced $ 135,978.92 $ 140,631.26 $ 140,712.88 $ 138,060.23 $ 41,112.96^ 6 Received $ 135,978.92 $ 140,631.26 $ 140,712.88 $ 148.20 177.84 Invoiced $ 108.84 $ 113.92 $ 141.70 $ 148.20 $ 148.20 177.84 7 Received $ 108.84 $ 113.92 $ 141.70 $ 148.20

Invoiced 88 Received 1 I 1 i 17,380.11 $ 50,680.52 $ 608,773.42 Invoiced 5 1,203,576.66 $ $ 430,296.38^ #4. + $ 47,836.63 9 Received 1... ■ $ 82,967.47 Invoked 5 138,118.00 4-1. $ 120,837.96 A 10 Received 4.. *** + No tic° attachments on Frontier poles ** No rentals exchanged - Joint Ownership Agreement *** The 2008 Settlement Agreement established a lump sump settlement for all calendar years through 2008 + The 2008 Settlement Agreements established a confidential net payment rent amount for the 2009 and 2010 rental years ++ The First Amendment to the Settlement Agreement, the parties extended the confidential settlement net payment amount Into the 2011 rental year ++4 2010 Invoice Missing

A Invoice adjusted for payment FRONTIER WEST VIRGINIA INC. CASE NO. 12-0284-E-T-C

Response to First Set of Interrogatories, Data Request or Requests for Information by the Staff of the Public Service Commission of West Virginia from Frontier West Virginia Inc,

Request No. 1, Dated May 24, 2013

Name and Title of the Person who prepared the Response: John Blake, Supervisor - Engineering

Name(s) of the Person(s) who could testify regarding the Response: John Blake, Supervisor - Engineering

Date the Response was Prepared: June 24, 2013

1.14. For Frontier-WV, please provide the following information, for each year 2007 to most recent available data:

A. The total annual amount charged by Frontier-WV to any other "attaching party" including AEP affiliates for any such charges resulting from a pole joint use agreement and a breakdown by general class of such charges such as "make ready" charges, pole rental rates, etc. Please identify any such "other attaching" party which is not a CATV provider, CLEC, or ILEC.

B. The total annual revenue received by Frontier-WV from any other "attaching party" including AEP affiliates for any such charges resulting from a pole joint use agreement and a breakdown by general class of such charges such as "make ready" charges, pole rental rates, etc. Please include information as to which utility accounts and sub-accounts each of such revenues would be recorded. Please identify any such "other attaching" party which is not a CATV provider, CLEC, or ILEC.

RESPONSE 1.14:

Without waiving any objection, Frontier responds as follows:

This information is proprietary and confidential, and some of the agreements expressly prohibit the disclosure of agreement terms, In an effort to provide data that the Staff has requested while preserving the confidentiality of that data and not violating the terms of agreements to which Frontier is a party, Frontier is providing a spreadsheet including amounts charged to any other "attaching party," identifying the general class of such charges as pole rent, make ready, or pre-license survey for each year 2007 through 2012. The available information responsive to Request No. 1.14 is set forth in the attached spreadsheet entitled "Response 1- 1.14." These revenues are recorded to the following accounts:

Revenue Type Revenue Accounts Pole Rents 5240-100-000-131 Make Ready - Capital 2411.100.000.423 Make Ready - Expense 6411.000.253.345 Pre-License Surveys 5240-100-000-131 12-0284--T-C Frontier WV Response to Staff Data Request No. 1, Dated May 24, 2013, Request 1.14 Response 1 - t14

2007 2008 2009 2010 2011 2012 Other Attathers Contract Prelicense Pre-License Pre-License Pre-License Pre-License Pre-License Pole Rent ** Make-Ready Survey Fees Pole Rent ** Make-Ready Survey Fees Pole Rent ** Make-Ready Survey Fees Pole Rent " Make-Ready Survey Fees Pole Rent ** Make-Ready Survey Fees Pole Rent Make-Ready Survey Fees Invoiced $ 979,03 1 979.03 979.03 993.66 $ 1,255.05 $ 1,344.51 Received

Invoiced $ 35.44 2 53.16 Received Invoiced 3 70.88 Received Invoiced 4 Received Invoiced 5 Received r Invoiced 6 145.19 146.19 39.87 39.87 Received $ 39.87 invoked 7 Received

invoiced 13.28 i a $ 13.28 13.29 13.30 13.30 S 13.20 R ceived e r€ 13.20 Invoiced 9 Received [ Invoiced 10 Received f I invoiced S ils.is 115.18 11 115.18 $ 115.18 115,18 115.18 Received 57.59 Invoiced 12 Received invoiced 13 Received Invoiced $ 380.98 14 416.42 416.42 $ 416.42 Received

Invoiced $ 1,16932 15 $ 1,169.52 $ 1,169.52 $ 1,169.52 $ 1,169.52 $ 1,169.52 Received $ 1,169.52 Invoked 16 5 912.58 912.58 Received invoiced 17 Received

Invoiced $ 70.88 18 70.88 5 119.61 119.62 119.62 119.62 Received 119.62 Invoiced 19 Received Invoiced 20 Received invoiced 21 Received Invoiced 22 Received 8.86 4.43 Invoked $ 8.86 $ 8.86 8.86 $ 8.86 23 Received Invoiced 88.60 24 Received , 44.30 invoked $ 88.60 88.60 88.60 88.60 25 Received

Invoked $ 15.50 26 Received Invoiced 27 Received Invoiced 28 I Received Invoiced 29 Received Invoiced 30 Received 53.16 53.16 Invoiced $ 53.16 53,16 53.16 53.16 31 Received Invoiced 321 Received 13.30 Invoiced $ 13.28 13.28 5 13.28 13.30 13.30 33 13.30 Received Invoiced 34 Received 13.30 invoked $ 13.28 13.28 13.28 5 13.30 13.30 35 13.30 Received 39.88 Invoiced $ 39,86 39.86 39.87 39.88 34.88 36 Received Invoiced 37 Received 22.16 Invoiced $ 22.25 22.15 22.15 22.16 22.16 38 22.16 Received Invoiced 39 Received Invoiced 40 Received Invoked 41 Received Invoked 42 Received 43 Invoiced I Received Invoiced 44 Received 1,330.00 159.48 $ 318.96 Invoked 159.48 159.48 $ 159.48 $ 15,556.95 S 45 Received $ 15,556.95 $ 1,330.00 13.30 13.39 Invoked 5 13.28 13.28 13.28 13.30 46 $ 13.30 Received $ 1,984.57 $ 108.00 Invoiced 47 $ 1,984.57 $ 108.00 Received 101.33 39.88 invoiced 48 39.88 I Received 17.72 $ 8.86 Invoiced $ 17.72 17.72 17.72 17.72 49 Received SO Invoiced Received Invoiced 51 Received Invoked 52 Received Invoiced 53 Received invoked 313.00 54 Received $ 313.00

Invoked $ 75.31 75.31 75.31 75.32 55 Received Invoiced 56 Received invoiced $ 172.76 172.76 172.76 57 Received Invoiced 58 Received Invoiced 59 Received Invoiced 60 Received 13.30 13.30 Invoiced $ 13.28 13.28 1128 13.30 61 13.30 Received 62 Invoked $ 70.88 $ 70.88 $ 70.88 $ 70.88 $ 70.88 Received

Invoked 63 Received

Invoiced 64 Received

Invoiced $ 84.16 84.16 84.16 84.18 84.18 $ 84.18 65 Received 84.18

invoiced 66 Received $ 20,167.75 $ 6,690.00 Invoiced $ 636,65 923.79 775.25 868,29 $ 425.00 $ 1,027.76 $ 22,930 00 $ 4,280.00 653.43 67 Received $ 425.00 $ 22,930.00 $ 4,280.00 653.43 $ 20,167.75 $ 6,680.00

Invoiced 68 Received

Invoiced $ 13.28 13,28 13.28 13.30 13.30 13.30 69 Received 13.30

Invoiced 70 Received

Invoiced 71 Received

Invoiced 72 Received

Invoiced $ 6.86 8.86 8.86 8.86 8.86 5 8.86 73I Received 8.86

Invoiced 74 Received

Invoiced $ 7,495.00 4.44 4.44 4.44 75 I Received 5 7,495.00 Invoked 76 Received

Invoiced $ 39.87 39.87 39.87 77 Received I Invoiced 78 Received

- Invoiced 79 Received

Invoiced 80 Received

invoiced 81 Received

Invoiced 82 Received Invoiced $ 217.07 83 $ 237.07 $ 217.07 $ 217.03 217.08 $ 217.08 Received 108.54

Invoiced 5 39.86 39.86 4 39.86 59.88 39.88 39.88 Received 19.94 Invoiced 85 Received

invoiced 86 Received

Invoiced 87 Received

Invoiced $ 863.85 899.29 88 $ 1,422.03 $ 1,457.47 $ 1,456.00 80.00 $ 1,488.48 $ 1,488.48 Received 80.00

invoiced $ 88.60 88.60 89 89.60 88.60 88.60 83.60 Received 88.60 Invoiced 90 Received

Invoiced S 13.28 13.28 i $ 13.28 $ 13.30 13.39 13.30 Received

Invoiced 5 531.60 2 1 Received

Total 3avoiced 5,969.31 $ $ - $ $ 6,820.01 $ 7,808.00 $ 6,423.41 $ $ 7,342.01 $ 17,012.95 $ 1,835.09 $ 6,315.69 $ 22,930.00 $ 4,280.00 $ 5,998.28 $ 22,152.32 $ 6,788.00 Total Received S - $ - $ S 7,808.00 $ - $ $ - $ 15,556.95 $ 1,835.00 $ 22,930.00 $ 4,280.00 $ 2,491,89 $ 22,152.32 $ 6,788.00

No data for Invoiced pole rents Indicates alternate Willing cycle (2 yr, 5 yr or 10 yr) t Frontier cannot access amounts received for pole rental FRONTIER WEST VIRGINIA INC. CASE NO. 12-0284-E-T-C

Response to First Set of Interrogatories, Data Request or Requests for Information by the Staff of the Public Service Commission of West Virginia from Frontier West Virginia Inc.

Request No, 1, Dated May 24, 2013

Name and Title of the Person who prepared the Response: Susan Knowles, Director - Engineering

Name(s) of the Person(s) who could testify regarding the Response: Susan Knowles, Director - Engineering

Date the Response was Prepared: June 24, 2013

1.15, For Frontier-WV and for a typical or average pole height:

A. What pole height does Frontier-WV consider appropriate for use in a pole attachment rate formula and why? Does Frontier-WV support a pole attachment rate based upon an average pole height in service or a pole attachment rate applicable to different pole heights in service?

B. With respect to the answer to 1.15.A., please define "usable space", and "unusable space" and citations to any safety code or utility regulation upon which this answer depends?

C. Is there a current dispute between Frontier-WV and AEP-WV regarding the appropriate definitions for "usable space", and "unusable space" and/or the space Frontier-WV believes to be allocated to Frontier-WV by AEP-WV. If yes, please explain Frontier-WV's position in detail.

D. To what extent, if at all, have Frontier-WV and AEP-WV been able to resolve the disputes in 1.15.C. through the pole survey results provided by the Davey Resources Group?

RESPONSE 1.15:

Without waiving any objection, Frontier responds as follows:

A. The default assumption under the FCC's rate methodology is a 37.5 foot pole. In Frontier's experience, the average pole height in the field is typically closer to 40 feet, A 40-foot wood pole is commonly deployed by ILECs and power companies in joint use and non-joint use environments. Indeed, the parties' 1986 joint use agreements assumed that the great majority of joint use poles would be 40-foot poles. Further, a 40-foot pole is of sufficient height and strength to accommodate the attachments of three parties, which AEP reports is the average number of attackers on its joint use poles in West Virginia.9 Where, as here, the parties have undertaken a recent field inventory that has identified the average height of the joint use poles, the average actual pole height should be used in the FCC rate formula instead of the default value. Frontier believes the correct actual pole height from the inventory results is 41.25 feet.

Frontier supports a pole attachment rate based upon an average pole height in service. Applying different rates to different pole heights would be administratively burdensome and would increase the costs for managing pole records and billings.

B. Frontier defuses "usable space" as space on a pole that is available for attachments. Once in the ground, 24 feet of the pole is not available for attachments and is therefore considered "unusable" — the 6 feet of pole that is buried as required by Frontier and industry-wide construction practices, and the first 18 feet of pole that is above ground as measured from the ground line, which is required by National Electric Safety Code ("NESC") clearance standards. The remaining 16 feet are usable.

C. Yes. As explained in response to Request 1.15.B., the uppermost 16 feet of a 40 foot pole is considered "usable" space. The remaining 24 feet is considered "unusable" because it consists of the 6 foot below ground portion of the pole and the required 18 feet of clearance above ground for clearance. AEP's 2012 invoices reflected rates that were derived from the rate methodology contained in the parties' 1986 joint use agreements, which was long-ago abandoned and superseded by the parties. In using that methodology, AEP considers only 9.5 feet as useable space on a 40 foot pole because that is the only space "allocated" to Frontier and AEP in the 1986 agreements. AEP treats the remaining 6.5 feet of space above the 18 foot required clearance as "unusable." AEP then divides the "unusable" space equally between AEP and Frontier with each responsible for 50%.

Frontier believes that the 6.5 feet of space that AEP deems "unusuable" is "usable" and should be allocated as follows: First, the 40-inch safety zone is defined by the National Electrical Safety Code ("NESC") as the space that is required to separate electric supply cables from communications cables. This space is necessary only if electric facilities exist on a pole, and the FCC considers

9 Implementation of Section 224 of the Act; Amendment of the Commission 's Rules and Policies Governing Pole Attachments, WC Docket No. 07-245, RM-11293, RM-11303, Comments of American Electric Power Service Corporation, et al., at 21 (2008). this space as usable and used by the electric utility. ]° AEP has refused to consider that space as usable or its responsibility. Second, the remaining 3 feet, 2 inches of the 6.5 feet is not "unusable" as AEP maintains, but rather is "usable" and is most likely being used by a combination of AEP, as it has expanded its own space requirements over the years, or by a third party such as a CATV, CLEC or other attaching entity, or a combination of any or all of those additional attaching entities. This space is not being used by Frontier and therefore Frontier should not be asked to share in the burden of the cost for that portion of space.

AEP's methodology allocates to itself 55.625% of costs for 7 feet of usable space, and allocates to Frontier 44.375% of costs for 2.5 feet of usable space. These usable space percentages do not proportionately or equitably allocate the space occupied by the parties. They ignore the actual amount of space occupied by the parties — under allocating space to AEP and significantly over allocating space to Frontier. Further, these percentages ignore the fact that other attachers are also on the poles in the space allocated to Frontier, but paying rents to AEP. The joint inventory established that there were other companies using the pole in the communications space including AEP.

During discussions between the parties in June 2011 about the average space used by Frontier, AEP stated that it considers the amount of vertical space occupied by Frontier in the usable space on the pole to include the lowest sag point of Frontier's lines mid-span between the poles. Frontier disagrees. First, the Settlement Agreement specifically refers to the space on the pole: "the amount of vertical space occupied by each party in the usable space on the pole." (Emphasis added.) Second, the inventory contractor did not measure attachments at mid- span, so any additional space added to Frontier's space occupied would be speculation.

D. Paragraph 4 of the 2008 Settlement Agreement requires the parties, on a statistically significant sampling basis, to jointly determine the average usage of poles by each party based upon mutually agreeable field data and criteria, which the WVPSC Staff and Consumer• Advocate Division recommend should include three items: a) the amount of vertical space occupied by each party in the usable space on the pole; b) the pole's height; and c) the ground clearance at the pole. The parties have not jointly determined any of these amounts.

The pole inventory measurement data provides for an average pole height of 41.25 feet, with an average space occupied of 8.16 feet for AEP and of 1.07 feet for Frontier. For the ground clearance at the pole, the average lowest attachment on the pole was 19.95 feet.

10 Consolidated Partial Order on Reconsideration, In the Matter of Amendment of Commission's Rules and Policies Governing Pole Attachments, 16 FCC Red 12103, 12122 (¶ 51) (2001) ("Reconsideration Order"); Report and Order, Amendment of Rules and Policies Governing Pole Attachments, 15 FCC Red 6453, 6467 (I( 22) (2000) ("Fee Order"). FRONTIER WEST VIRGINIA INC. CASE NO. 12-0284-E-T-C

Response to First Set of Interrogatories, Data Request or Requests for Information by the Staff of the Public Service Commission of West Virginia from Frontier West Virginia Inc.

Request No. 1, Dated May 24, 2013

Name and Title of the Person who prepared the Response: John Blake, Supervisor - Engineering

Name(s) of the Person(s) who could testify regarding the Response: John Blake, Supervisor - Engineering

Date the Response was Prepared: June 24, 2013

1.16. In a situation in which a currently Frontier-WV owned pole, and to which AEP-WV facilities are attached, is damaged and requires replacement:

A. Does Frontier-WV or AEP-WV replace or contract to have the pole replaced?

B. If the pole is replaced by AEP-WV does AEP-WV charge Frontier-WV the cost of a new pole and associated installation costs? If yes, please provide a recent example of such charges to Frontier-WV.

C. If the response to 1.16.B. is yes, please explain including whether or not Frontier- WV retains ownership of the pole in this type of situation.

D. What is the current cost of a new pole purchased by Frontier-WV for varying heights as typically used for distribution facilities?

RESPONSE 1.16:

Without waiving any objection, Frontier responds as follows:

A. Frontier currently uses both employees and contractors to maintain its pole infrastructure. When a pole needs to be replaced it is typically handled by the first available crew.

B. The cost of pole replacements by either party is outlined in Article 8 — Division of Costs of the Joint Use Agreements between AEP-WV and Frontier-WV (attached in response to Request 1.7 as "Response 1 — 1.7 — 1" and "Response 1 — 1.7 — 2"). If AEP must replace a Frontier-owned pole under emergency conditions, Section 8.05 specifies that Frontier will pay for the costs incurred in replacing the pole and of removing the old pole, if applicable. Invoices for recent examples of such charges to Frontier are attached as "Response 1 — 1.16."

C. Except for poles 50 feet or taller, Frontier retains ownership of all poles in all circumstances in which AEP replaces a Frontier-owned pole. Section 8.01 expressly provides, "Any such new pole shall be the property of Owner regardless of any payments by Licensee toward the cost of such new pole and Licensee shall acquire no right, title or interest in and to such pole." Under Section 8.02, AEP shall own all new poles having a length of 50 feet or more. Section 8.05 expressly provides that where Licensee replaces an Owner's pole under emergency circumstances, "Title to the pole will remain with the Owner."

D. The table below shows the current material costs for new poles of different heights. Frontier has no recent orders for any 45 foot Class I or 50-foot Class 1 poles.

Height (in feet) Class Price 35 4 $ 178.11 35 5 $ 165.00 40 4 $ 226.86 40 5 $ 222.22 45 1 NA 45 2 $ 350.24 45 3 $ 328.00 50 1 NA 50 2 $ 405.96

Response 1 — 1.16

21 10 1 5 7 3? 0 0 0 0 1 5 60 8000 0 0 00 0 0 0 140 2 0 ? 7 754 30 0 0 000 0 0 0 0 0 0 6

AMERICEW ELE-Crizta POWER TOT4L„1., y60417 -3604-13ati'q

Amount Enclosed

Make Check Payable and Send To: - 11111111 11if II 1 it 1 1 1 I 1 1 1 I I I American Electric Power • Frontier Communications PO Box 24424 1500 McCorkle Ave Canton OH 44701-4424 Room 320 Charleston WV 25396 it11.1111 1E111 tf En If 1111111 E![11 I it l lE[1 1

Invoice: 140-20779754 3 Invoice Date: January 31, 2013

Invoice: 140-20779754 INVOICE AMERICANt ELEcrRic: Invoice Date: January 31, 2013 POWER Payment Terms: Net 30 brie Date: March 02, 2013 Page: 1 Contract No: Customer No: 11015737 Purchase Order: DAP0203552

Line- Description Quantity UOM Unit Amt Net Arnounti 1 POLE-REPLACMENT 1.00 LO 1,56.0.80 1,550.80 Billing for replacing one Frontier 40c2 pole due to a vehicle accident: AEP Pole # 454-108: Located@ Court St & Hight SL Fort Gay WV Work Completed 04/21/2012 Pole Coordinates: 38.117795 .82.594129 Frontier Pole #: N/A WO# DAP0208552 WR #44687051 $ 1055,98 12 Hrs Labor 503.82 Cost of Pole (40c2)

1560.80 TOTAL COST PaYment in full is expected upon receipt of this invoice. Any payment received in an amount less than the full amount billed will be applied as a partial payment on the full debt and will not be accepted as settlement of AEP's claim. Please be sure to return the invoice stub and inclOde your Customer ID # and Invoice # on your check. All payments should be-sent to AEP Accounting Services in Canton, OH. If you have any questions, pleaSe call the number below. Thank you. Subtotal: 1,560.80

301-00902901-BKT "S TOTAL AMOUNT DUE: LISD i,\Jukk - g 3

Please ffrefACH Funds To: Appalachian Power Co - Dist Citibank, N,A. New York ABA/Routing 021000089 Account #: 00021741

For bilthg questions, please call: Original 800-566-5499 ti

2 1 1 01 5 7 37 0 0 0 0 2 2 8 WIL[1E] 0 0 0 0 0 0 11-102 0 7 7 1 lt4 0 0 00 0 0 0 0 0 OD 0

AMERICA MccrRic .

Amount Enclosed

Make Check Payable and Send To: American Electric Power Frontier Communications PO Box 24424 1500 McCorkle Ave Canton OH 44701-4424 Room 320 Charleston WV 25396 II l il t 111111111111111111111111111111i 1 111 !II Ill Ei ll Invoice: 140-20778711 4 Invoice Date: January 24, 2013

Please tear on dotted line and return top portion with pour payment.

Invoice: 140-20778711 INVOICE l_La AMel MV.Are ELEcrRIC: Invoice Date: January 24, 2013 POWER Payment Terms: Net 30 Due Date: February 23, 2013 Page: 1 Contract No: Customer No: 11015737 Purchase Order: W/R46145374

Line Description Quantity WM.' Unit Amt Net Amount 1 POLE-REPLACMENT 1.00 LO 2,288.46 2,288.46 Billing for one 45'2 Pole and labor. Work completed —08/212012 LOCATION —Dry Hilt Rd Beckley WV Pole 488810799D10289 Lat#37.799280 Long# -81.224376 K670.33 Labor and equipment 618,13 1 Pole 45'2 $2,288.46 Total Service Request Payment in full is expected upon receipt of this invoice. Any payment received in an amount loss than the full amount billed will be applied as a partial payment on the full debt and will not be accepted as settlement of AEP's claim. Please be sure to'return the lriVOICe stub and include your Customer ID # and invoice n on your check. All payments should he sent to „EP Accounting Services in Canton , OH, If you have any questions, please call the number below, Thank you. Subtotal: 2,288.46

301-00902901-BKT 0/2,, TOTAL AMOUNT DUE: 13

Please Wire/ACH Funds To: Appalachian Power Co - Dist Citibank, N.A. New York ABA/Routing g: 021000089 Account #: 00021741

For billing questions, please cal!: 800-566-5499 Original

21 10 1.57 3 HO OD 92 7E4000 0 0 CI 0 0 CI it] 29 7 78 3LI 4 DO CIO 00 0 0 0 0 0 5

MI AMERICAN' ri,Ecnur, POWER 1-9-ZAIA%ct4,914617:11[: JE a r{ 24, Amount Enclosedt$

Make Check Payable and Send To; American Electric Power Frontier Communications PO Box 24424 1500 McCorkle Ave Canton OH 44701-4424 Room 320 Charleston WV 25396 if 1 I i ll ifillf 1 II hu ff ill I t i11111111r1 111 I I ri

Invoice; 140-20778834 4 Invoice Date: January 25, 2013

Please tear on clotted line and return top portion with your payment.

Invoice: 140-20778834 INVOICE ,..M.„..45i f AMERICAN' invoice Date: January 25, 2013 PO11C Payment Terms: Net 30 Due Date: February 24, 2013 Page: 1 Contract No: Customer No: 11015737 Purchase Order: W/R46998919

Line Description Quantity UOM Unit Arnt Net Amount POLE-REPLA.OMENT 1.00 LO 027.84 027.84 Billing for one 4005 Pole and labor. Work completed —10/23/2012 LOCATION —2176 Rt 75 Kenova WV Pole #38830157800139 Lat#38.358229 Long* -82.563923 $554.24 • Labor and equipment $373.60 1 Pole 4005 Pole $227.84 Total Service Request Payment in full is expected upon receipt of this invoice. Any payment received in an amount less than the full amount billed will be applied as a partial payment on the full debt and.will not be accepted as settlement of AEP's claim. Please be sure to return the invoice stub and include your Customer ID # and Invoice # on your check. All payments should be sent toAEP AcCountinO-Services In Canton, 01-1. If you have any questions, please calf the number below. Thank you. Subtotal: 927.84

301-00902901-8KT Ary

TOTAL AMOUNT DUE: 927.84 • SD

. lease WireIACH Funds To: Appalachian Power Co - Dist Citibank, NA. New York ABA/Routing #: 021000089 Account: 00021741

For billing questions, please calf: 800-566-5499 Original FRONTIER WEST VIRGINIA INC. CASE NO. 12-0284-E-T-C

Response to First Set of Interrogatories, Data Request or Requests for Information by the Staff of the Public Service Commission of West Virginia from Frontier West Virginia Inc.

Request No. 1, Dated May 24, 2013

Name and Title of the Person who prepared the Response: Susan Knowles, Director - Engineering

Name(s) of the Person(s) who could testify regarding the Response: Susan Knowles, Director - Engineering

Date the Response was Prepared: June 24, 2013

1.17. Does Frontier-WV believe that a pole attachment rate difference should exist for fiber- optic cable attachments compared to coaxial or copper cable wire attachments? If yes, please explain the basis for such difference and how the difference in pole attachment rates would be calculated.

RESPONSE 1.17:

Without waiving any objection, Frontier responds as follows:

In the interest of competitive neutrality, Frontier agrees with the FCC that a single rate should apply to fiber optic cable, coaxial cable, and copper cable attachments. To more effectively promote competition and the advancement of broadband and other advanced services, providers of these services should be able to compete with each other on an equal footing. Accordingly, the annual pole attachment rate should not be predicated on the facility used to provide service. Moreover, a two-tier or three-tier rate structure would create significant administrative burdens because it would require the parties to track each type of attachment that is made on each pole. Different rates would increase the costs for managing pole records and billings. FRONTIER WEST VIRGINIA INC, CASE NO. 12-0284-E-T-C

Response to First Set of Interrogatories, Data Request or Requests for Information by the Staff of the Public Service Commission of West Virginia from Frontier West Virginia Inc.

Request No. 1, Dated May 24, 2013

Name and Title of the Person who prepared the Response: John Blake, Supervisor - Engineering

Name(s) of the Person(s) who could testify regarding the Response: John Blake, Supervisor - Engineering

Date the Response was Prepared: June 24, 2013

1.18. For Frontier-WV please provide the following information for the years 1986 to present: (Please provide your response both in writing and by an Excel spreadsheet.)

A. The total number of Frontier-WV poles in service during each year.

B. The number of Frontier-WV poles placed into service during the year.

C. The number of Frontier-WV poles in service during each year in joint use with AEP-WV.

D. The number of Frontier-WV poles in service during each year in joint use with any other electric distribution companies other than AEP-WV.

E. The number of Frontier-WV poles in service during each year in joint use with a Cable TV provider.

F. The number of Frontier-WV poles in service during each year in joint use with a Competitive Local Exchange Carrier.

G. The number of Frontier-WV poles in service during each year in joint use with any other "attaching party" not listed in items 1.17. C. through 1.17. F. Please include the identity of such other "attaching parties" in your response. RESPONSE 1.18:

Without waiving any objection, Frontier responds as follows:

This request for years 1986 to present may have been an unintentional oversight. All other requests for information in this First Request go back to year 2007. Also, the parallel request for information sent to AEP (Request 1.17) seeks information "for the years 2007 to present."

A. The attached spreadsheet entitled "Response 1 — 1.18 — 1" sets forth the number• of Frontier poles in service from 1986 to 2012.

B. The available data for the number of Frontier poles placed into service from 1986 to 2012 is shown on the attached spreadsheet entitled "Response 1 —1.18 — 1." Frontier was unable to retrieve data for all years except 2011 and is continuing its search for year 2012 and will forward it to Staff as soon as it is available.

C. The attached spreadsheet identifies the number of joint use poles Frontier had with AEP that were in service during each year in joint use with AEP-WV from 1986 to 2012, other than 1989. Frontier was unable to locate the requested data for that year.

D, Frontier was only able to locate data from 2002 to 2007 identifying the number of poles in service during each year in joint use with any other electric distribution company other than AEP, which is set forth in the attached spreadsheet entitled "Response 1 — 1.18 — 1."

E. The attached spreadsheet entitled "Response 1 — 1.18 — 1" includes data from 1998 to 2012 identifying the number of Frontier poles in service during each year in joint use with a Cable TV provider. Frontier was not able to locate data from 1986 to 1997.

F. The attached spreadsheet entitled "Response 1 — 1.18 — 1" includes data from 1998 to 2012 identifying the number of Frontier poles in service during each year in joint use with a Competitive Local Exchange Carrier. Frontier was not able to locate data from 1986 to 1997.

G. The attached spreadsheet entitled "Response 1 — 1.18 — 1" includes data from 1998 to 2012 identifying the number of Frontier poles hi service during each year in joint use with any other "attaching party" not listed in items 1.17.C. through 1.17,F. Frontier was not able to locate data from 1986 to 1997. A list identifying the "other attachers" is included in the attached spreadsheet entitled "Response 1 — 1.18 — 2." nep JC42u!qpieas igs 391`I 886 VN VN VN VN VN VN VN VN VN VN VN VN (08VT) (00-2 'DnD 'AIVD 443V Inu) s.aaqaelIV-IDL110 Aq PtiDelle salod ,I.Ld 40 # 0 0 VN VN VN VN VN VN VN VN VN VN VN VN wt.-0 D3-0 Aq papeue salad tl1d }o # b8S`SZI 1710'SZ1 VN VN VN VN VN VN VN VN VN VN VN VN (38t1) AiVO Aq paLipelle salad Ad j.o # VN VN VN VN VN VN VN VN VN VN VN vN VN VN (02I1) salad n1d3V-uou Jo # LLB SZ.Ct• ESC ESL 17 ESL'17 VN VN VN VN VN VN VN VN VN (DSII) salod 111 dAA 10 # 60V517 60E'Sb 60E`St 60VSt 60E'Sb 217L'Et 817Z:£17 8be£17 abL`Str 8174'Et VN 69v0r 69£'017 69E'Ot (J8T7) salad nr clv 0 # ■ VN VN VN VN VN VN VN VN VN VN VN VN VN VN (gsrt) aoyvas u pantd salad pp # 60S'ESE 0S9'TEE 309`6ZE 99t,VE Zinn L6eSZE 08VEZE SOVIZE 80V6TE ZEC4tE 60t/64Z 09s`9a 06Z"bLZ 666'ELZ (VST-T) aovuas ul salad 3a # 6661 8661 L661 966T 5661 D661 8661 Z661 1661 0661 6861 8861 L861 9861 - 81'1 - T asuocisa8 13111.sanipall tIOZ-VZ-S palea T 'oN lsanbal; ea.ea 4.1els o3 asuodsali v Jap.uoid D-1-3-r8zo-zt elep Jo} SuNaJeas ilizs 9ZO'Z 1766'T VLSI 048'1 EZtT 6L1/T Z917'T LECI ITT'T OLO'T 17ZZ'T EZE't SSE1 (98tI) (0D13 `TO 'AM 'cl3V iou) slopeuv Jati10 Aq pagoeue saiod did 413 # L3L'ET 6TS'9 EIZ'S SZS'E LSO't 1766'Z ZOSt ST61 1709'T 89E'T NV' STE OZ (arc) 0317 Aq payaeue saiod w_d 10 4 0317`9E1 TZL'SET 8013'6ET anti 1Z8'6E1 SI756ET EZnET LLZAET TEDr9ET LVZ'SET L6CEET L917'6ZT SEVLZI (wri) Aiyo Aq PoPe1-12 sloci Ad P 4 ZZ8'1/ Ett't VN 'IN VN VN VN VN VN VN VN VN VN (asi.t) salad nr daV-uou 40 # 98Z'S 98Z'S 98Z'S 98Z'S 98Z'S 00E'S TOE'S TOE'S 00E'S 66Z'S E6L'17 8LL'17 8/1'17 (D8I-E) saiod III dm jo # ELL'Zb ELL'Zb ELL`Z17 ELL'ZI7 ELL'Zb 65e9v 6Se9t7 6St9t 6SL'917 6SLA4 6SLAV 6Se917 60E'Sb (JWTI) salod nr day po # 550'E VN VN VN VN VN VN VN VN VN VN VN (28I'1) aovuos ui paoeid saiod 4o # TZ6'E9E EOODSE SET'LtrE VN VN 8T0'917E ZTO'SVE Z96'EtrE t7013'ZtE StiO'ZtE E8V0bE 098'4EZ 6SL'LEE (vgv-i) aalNas u! saiod Jo # ZIOZ ITOZ OTOZ 600Z 8002 400Z 900Z SOOZ 1700Z SOOZ ZOOZ 1002 000Z 12-0284-E-T-C Frontier WV Response to Staff Data Request No. 1, Dated May 24, 2013, Request 1.18(G) Response 1 - 1.18 - 2 "Other Attachers" to Frontier West Virgina Poles 1986- Company 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 1st Community National Bank x x x x x x x Ames True Temper x x x

April Trent le x x b

la x x x Armstrong Telephone Company-ND i x x x x x ATTIX x x x x ' x x x Ava Basco Electronics, Inc. t x x

Basco Electronics MATV No x x x x x x x x x x ta Bayer Cropscience x x x x x Da

Berkeley Glass Properties 00 x x x Bethany College 20 x x x x x x Betty Parsons x x

Bluefield State College 1986 - x x x x x Bob Shulter x x Brooke County Sheriffs Dept. x x x x x x Bureau of the Public Debt x x x x x C&S West, LLC x x x x x Cabell Huntington Hospital x x x x x x x x x x x x Camden-Clark Memorial x x x x x x x Catholic Diocese of Wheeling x x x x x x x Charleston Area Medical Center, Inc. x x x x x. x x x x x x x

Charleston Authority of the City of Charleston, WV x x x x x Chenoweth Ford, Inc. x x x x x x x Citizens Communications x x x x x x City of Philippi Building Commission x x x x x x x x x x x x Claywood Park PSD x x CNG Transmission Corp. x x x x x x x x x x x x Columbia Gas Transmission Corp. x x x x x Columbia Gas Transmission Corp. - 421 x x Columbia Gas Transmission Corp. - 425 x x County Commission of Berkely County x x x x x x x x x x Crompton Crp/GE Specialty Chemicals x x x Davis Memorial Hospital x x x x x x x Day Surgery Center x x x x x Department of Agriculture x x x x x Digital Medical Corporation x x x Doddridge County BOE x x x Dominion Appalachian Dvlpmt, Inc. x x x x x x x x x x x x Eastern American Energy Corporation x x x x x x x Eastern Associated Coal Corp. x x x x x x x x x x x x Eimco Coal Machinery, Inc. x x x x x x x EQT Corp/formerly Eastern States Oil & Gas x x x x x Fairmont State College x x x x x Ferguson Brothers Company x x x x x First State Bank x x x x x Frank R. Ferguson x x GE Specialty Chemicals x x x x x x x x x Glennville State College x x x x x Gritt's Midway Greenhouse x x x x x x x x x x x x GTE South Inc. x x Hancock County Board of Education x x x x x x Hardy Telephone Company, Inc. x x x x x x x x x x x x Harriet J. Evans x x HMS Technologies, Inc. x x x x x x x Holzer Clinic Inc. x x x x x 1ndustronics/Bocco Cable x x James A. O'Brien x x Joe Holland Chevrolet, Inc. x x x x x x x x x x x x Kanawha River Terminals x x x x x Ken Linsay x x Leavitt Funeral Home, Inc. x x x x x Lewis County Commission x x Louis Thomas Suburau, Inc. x x x x x x x Lucas Tire, Inc. x x x x x x x Mabscott Supply x x x x x x x Marshall County Cable, Inc. x Marshall University x x x x x x x x x x x x Martinsburg IRS Facility LP x x Matheny Motor Tuck Company x x x x x x x x x x x x McClinton Cheverolet Co. x x x x x Mid State Automotive Inc. x x x Midway T&C, Inc. x x x x x x x x x x x x Monogalia County Health Dept. x x x x x x x Montgomery General Hosptial x x x x x x x Mountain State University x x x x x x Mylan Pharmaceuticals, Inc. x x x x x Nedpower Mountstorm LLC x x x x x Nicholas County Board of Education x x x x x x x Nursing Care Home Health Agency, Inc. x x x x x x x O. Ames Company x x x x x x Pendleton County Board of Education x x x x x Peoples Telephone Company x x x x x x Potomac State College x Raleigh County Memorial Airport x x x x x x x x x x x x Rhone-Poulenc Agency Company x x x x x x x Saint Nicholas Limited Liability Company x x x x x x Saint Vincent DePaul School x x x x x Salem-Teikyo University x x x x x x x x x x x x Service Wire Company x x x x x Shenandoah Network Company x x x x x x x x x x x x Shutler Machine and Fabrication x x x x x Sister Ann Fay x x Snodgrass Funeral Home x x x x x x x x x x x x Southern West Virginia Asphalt x x x x x St. Mary's Hospital x x x x x x x x Starvaggi Industries, Inc. x x x x x Sturm, Inc. x x x x x x x Sturm Pars Manufacturing Center, Inc. x x x x x Syscan Corporation x x x x x TCG America Inc./TCG Virginia, Inc. x x x The Senior Center x x x x x x x TKC Communications x x x TMC Technologies, Inc. x x x x x Tri-County Health Clinic, Inc. x x x x x Ultimate Health Services, Inc. x x x x x x United National Bank x x x x x x x Valley Welding Supply Company x x x x x x x Weirton Steel Corp. x x x x x x x x x x x x Wesbanco / American Bancdata Corp. x x x x x x x West Liberty State College x x x x x x x x x x x x West Virginia American Water Company x x x x x x West Virginia University at Parkersburg x x x x x West Virginia University of Technology x x x x x West Virginia University Research Corporation x x x x x Wheeling Jesuit University x x x x x x x x x x x x Wheeling -Nisshin, Inc. x x x x x William R. Sharpe, Inc. x x x x x x x x x x x x WVU Telecommunications x x x x x x x Wyoming County Board of Education x x x x x x x Zelma D. Boggess x x

TOTALS 36 35 34 36 41 63 66 84 84 86 86 87 FRONTIER WEST VIRGINIA INC. CASE NO. 12-0284-E-T-C

Response to First Set of Interrogatories, Data Request or Requests for Information by the Staff of the Public Service Commission of West Virginia from Frontier West Virginia Inc.

Request No, 1, Dated May 24, 2013

Name and Title of the Person who prepared the Response: Randy Brockman, Manager, Regulatory-Economic Costing

Name(s) of the Person(s) who could testify regarding the Response: Randy Brockman, Manager, Regulatory-Economic Costing

Date the Response was Prepared: June 24, 2013

1.19. The FCC's "Cable Formula" and "Telecom Formula" for determining the maximum pole attachment rate for use of LEC utility poles uses specific FCC ARMIS Accounts. For example, the FCC formulas define Net Pole Investment as equal to Gross pole Investment (Account 2411) minus Accumulated Depreciation (Account 3100) minus Accumulated Deferred Income Taxes (Account 4100+4340).

A. Please provide the historical data for the following accounts for December 31 of 2011 and 2012.

1. Gross pole Investment (Account 2411)

2. Accumulated Depreciation (Account 3100)(Poles)

3. Accumulated Deferred Income Taxes (Account 4100 + 4340)(Poles)

4. Total Administrative and General Expenses (Accounts 6170 & 6720)

5. Gross Plant Investment (Account 2001)

6. Maintenance Expenses (Account 6411)

7. Rental Expenses (Poles)

8. Accumulated Depreciation (Account 3100)(Plant)

9. Accumulated Deferred Income Taxes (Account 4100 + 4340)(Plant)

10. Depreciation Rate for• Gross Pole Investment 11. Operating Taxes (Account 7200)

12. Applicable rate of return element used annually to calculate applicable carrying charge rate.

B. For the calculation of a pole rental rate to be charged by Frontier-WV to AEP- WV does Frontier-WV believe an "Appurtenance Reduction Factor" is appropriate? If yes, please state the factor and explain how it is determined.

C. For the calculation of a pole rental rate to be charged to Frontier-WV by AEP- WV does Frontier-WV believe an "Appurtenance Reduction Factor" is appropriate? If yes, please state the factor and explain how it is determined.

RESPONSE 1.19:

Without waiving any objection, Frontier responds as follows:

A. Please see the attached spreadsheet entitled "Response 1 — 1.19" which includes the historical data for the above-requested accounts for December 31 of 2011 and 2012. This spreadsheet includes all of the data needed to calculate the rates for these two years.

B. Frontier believes that an "Appurtenance Reduction Factor•" is appropriate. An adjustment to a utility's net pole investment is necessary to eliminate the investment in crossanns and other non-pole related items. The FCC has analyzed the appurtenance factor and has concluded that a 15% factor should be applied to determine the net bare pole cost of electric utility poles."

For the rates that Frontier charges to AEP for AEP's use of Frontier-owned poles, under the guidance provided by the FCC, Frontier should charge AEP the same proportionate rate according to the space occupied by AEP on the poles. The FCC stated that "a just and reasonable rate in such circumstances would be the same proportionate rate charged the electric utility, given the incumbent LEC's relative usage of the pole (such as the same rate per foot of occupied space)."12 The 15% appurtenance factor is built into that proportionate rate calculation and should not be changed. Moreover, leaving the appurtenance factor intact instead of reducing it to the 5% appurtenance factor that the FCC applies to ILEC poles results in a lower rate for AEP and is to AEP's advantage.

C. Please see the response to Request 1.19.B. above.

11 Reconsideration Order, 16 FCC Red 12103, 12122 (II 32); Fee Order, 15 FCC Red 6453, 6472-73 (II 31). 12 Pole Attachment Order, 26 FCC Rcd 5337 (¶218 n. 662).

Lunlaj 40 azej pazpoillny linejaa/pannoliv ryogz. -a;eJ aZieua 2u4le.) aiqefidde aleinaie3 olAllenuue pasn luatuala uJniaJ apeauddv ZT elea 19 Lunlul4u I (AM-3d) ZTOZ at520"8Z (00ZLlunoaDv) saxei 2u1;aladC) TT aley Dnd pleas va0z-9 luaLL4sanui clod ssw 9 a0} uope Loaidaq OT elea 19 waiu0111 (AM-3d) ZTOZ SV8'9'vn6 (;ueLd)(017E17+ 00t4;unoaav) saxes aLuopui paiJapa palepuinoov 6 elea 19 wnluipl {AM-3d) ZTOZ LZVTLeSTZ"Z $ (weld)(00TE aunoaav) uonepaidao paleinwnoav ele0 19 wniuu.ul {Am-3.1) ZTOZ TOS"SEC9 (solo d) szsuadx3ieluold L elea 79 wriEuP1 (AAA-3d) ZTOZ 93StL56 (uct79 auncow) sasuadxs aDueua1u eifq 9 awl:: 79 wrquijul (MA-DJ) ZTOZ 089'9IL"655"Z $ (TOOZIuncoov)luau4sanui lueld sscu9 elea 19 u.imulju (AM-3d) ZTOZ TLO'LS5'517 (OZ49 8 OTZ,9 slunonv) sasuadx3 leJauaD pue anLleilsLuPPVIe;01 (saxeiaLuopui paliapc Lunaav x (Isamilueid sso.J9/1saAuraiOd sso.19) TEE'866'S {saiodWVEtr + 00tb .unooDv) saxei a =au' pailalaa pazeinwnaDV E 4teC 79 turl!u!PI(AM-D) ZTOZ 680'bI78"EZ.I (saiod)(tIvElunonov) uollepa.idaa pa1einuanaaV Z eleG 79 tumuy.ul (AM-3d) ZTOZ 9TVIZE'L9I (TIVZ zunonv) ;uaLulsanulaiod sso..0 DO.MOS s u d sa 6-E-T uo!pas Jo; suopsano ZTOZ J.0 tg.saquia.3aG JO} slum:tan 2uyvkollo4 alp Je9. ezep ie)poIsp-I pup-..reaA

Lurnaj alga pazpouzny wiejaa/pamoliv Vog plea a2JeLp 21.0.1JeD aigeDwide aleinoLeo olAllenuue pasn luaLuap Lumal p ale.: a icleaLiddv zT elea 79 wn!ul3ui (Am-Od) TTOZ S6V9tv't9 $ {00ZLI.unonv) saxei Sui4ead0 IT aley 3fld ale: s °A0Z'S luaL.=anui plod ssoi9 JO} aa2buopepaJdaa CI elea 79 Lun!ul}ul (AM-3d) TTOZ StV9t,n6 (lueld)(OVEV + 00TV luncoov) saxeiawmul pale[nwnaDV 6 nea 79 unIu[Jul (AM-3d) TTOZ UtETT'LlirZ 5 (lueld)(00TE lunonv) uo!z.etaaJdaa pale[nwnoov g eleq 79 umlu[Jul (AM-3d) TTOZ 117Z`EZ9'9 (salad) sasuadx3 ielua):1 L Cm 19 wno.itjui (AM-3d) TTOZ 90-CS9V0-: (ittgzuncwv) sasuadxs aaueualuelAi 9 MO 19 wniu!}u (AM-3d) TTOZ z8SIVEr9z1/Z $ (TOOZ lunaapv)4uau4sanui 1.ueld ssai 9 5 eec:119 wnEugul (AM-3d) TTOZ ClEtttetZtZ {OZL9 9 OIL9 slunoopv) sasuadxs ieJaua9 pue aA1.4eAsiu!wpvieloi (saxes aLumui paualap tunaav x (Isanuj luew sso.9/IsaAul clod ss0J9) z59'EE0'9 (solod)(0t/Et7+ oott auntoow) saxej_ a =au! pal-la}ao paleinLunDaV E e4ec 79 uanEugui (MA-DJ) TTOZ L9L'S6t/99T (saiod)(TIbglunonv) uoq.epaJdac pal.einwnDoV Z e4ec 79 wn!ullul (AM-3d) TTOZ VSO'SEL'09I (TTbz1UnOmV)I.uau4sanul plod ssw9 T asuodsa)j 611 uogoas Jo; suogsant) TTOZ 3o TE Jaqwana sw no= auvisoliolaqz JO} ezep ieopozsp.1 pup-JeaA 6-E-1

ielluaNjuop pue ioe-w■Adald (Aao;eln2ab) 2u,aso3 D!Luotaooa - Ny :Aq pwedaid Jamod Dypai3 UleDJZUN eqp ip.oq 'Aueclulop larnod SunaagArt pue AuedwoD aamod ueNDeLeddv D-1-3-178ZO-ZT "ON aseD 61 - T asuodsaa etup.m 4sam }o uo!sspanuoD aDirwas ouqnd of asuodsau FRONTIER WEST VIRGINIA INC. CASE NO, 12-0284-E-T-C

Response to First Set of Interrogatories, Data Request or Requests for Information by the Staff of the Public Service Commission of West Virginia from Frontier West Virginia Inc.

Request No. 1, Dated May 24, 2013

Name and Title of the Person who prepared the Response: Jim Corwin, Manager - Engineering

Name(s) of the Person(s) who could testify regarding the Response: Jim Corwin, Manager - Engineering

Date the Response was Prepared: June 24, 2013

1.20. Please provide an update on the status of the Davey Resources Group pole inventory.

A. What is the format of the inventory data, e.g,, Excel spreadsheet?

B. Have the parties resolved the question of how to draw a statistically significant sample from the survey data?

C. Please provide a brief description of the types of pole characteristics surveyed.

RESPONSE 1.20:

Without waiving any objection, Frontier responds as follows:

On May 31, 2013, AEP filed a closed entry of the inventory of facilities performed for Frontier and AEP. Frontier's response to that closed entry is due on July 1, 2013.

A, The inventory data was delivered in Excel spreadsheet formats — one for each of the 76 wire centers that were inventoried. Per AEP's cover letter and Certificate of Service filed with the PSC on May 31, 2013, copies of the inventory were provided to the PSC. Although AEP's Certificate of Service claimed that a copy of the inventory was served on Frontier on May 31, 2013, Frontier did not receive a copy. After request from Frontier, AEP delivered a copy of the inventory to Frontier on June 10, 2013. The copy delivered to Frontier states that there are 77 files, but one wire center, Apple Grove, was counted twice. The original delivery on July 30, 2012 was rejected because of errors and replaced by the re-delivery on October 17, 2012.

B. Paragraph 4 of the 2008 Settlement Agreement requires the parties, on a statistically significant sampling basis, to jointly determine the average usage of poles by each party based upon mutually agreeable field data and criteria, which the WVPSC Staff and Consumer• Advocate Division recommend should include three items: a) the amount of vertical space occupied by each party in the usable space on the pole; b) the pole's height; and c) the ground clearance at the pole. The parties have not jointly determined any of these amounts.

The parties agreed that each of their company's contracts with Davey Resources Group would include (and Frontier's contract did include) a requirement for DRG to work with Kent State to recommend to AEP and Frontier what would constitute a statistically significant sampling for their mutual consideration and decision. To Frontier's knowledge, no recommendation was submitted.

C. The types of pole characteristics surveyed are identified as a "database structure" and shown in Table 1 (pages 1-2) of the Manual — Joint Use Survey Procedures prepared by Davey Resources Group (attached as "Response 1 — 1.20"). REDACTED

Response 1-1.20 FRONTIER WEST VIRGINIA INC. CASE NO. 12-0284-E-T-C

Response to First Set of Interrogatories, Data Request or Requests for Information by the Staff of the Public Service Commission of West Virginia from Frontier West Virginia Inc.

Request No, I, Dated May 24, 2013

Name and Title of the Person who prepared the Response: Joan Huffine, Senior Business Consultant — Network Engineering

Name(s) of the Person(s) who could testify regarding the Response: Joan Huffine, Senior Business Consultant — Network Engineering

Date the Response was Prepared: June 24, 2013

1.21. The Federal Communications Commission Rule 1.1402(b) defines pole attachment as "...any attachment by a cable television system or provider of telecommunications service to a pole, duct, conduit, or right-of-way owned or controlled by a utility."

A. To what extent do the "pole attachment" issues in this case also involve disputed rates or charges applicable to ducts and/or conduits in joint use by AEP-WV and FTR-WV? Please explain the dispute if applicable.

B. If rates or charges applicable to ducts and/or conduits in joint use by AEP-WV and FTR-WV are not in dispute please describe how such rates or charges are currently determined.

RESPONSE 1.21:

Without waiving any objection, Frontier responds as follows:

A. No ducts and/or conduits are in joint use by AEP-WV and FTR-WV. Accordingly, no issues in this case involve disputed rates or charges applicable to ducts and/or conduits.

B. No ducts and/or conduits are in joint use by AEP-WV and FTR-WV. Accordingly, no rates or charges applicable to ducts and/or conduits are determined.