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LAW OFFICES ROBERT R.RODECKER BB&T SQUARE

300 SUMMERS STREET, SUITE 1230

POST OFFICE BOX 3713

ROBERT R. RODECXER CHARLESTON,WEST VIRGINIA25337 AREA CODE 304 [email protected] 343-1054 _. - JAMES V. XELSH September 3, 2008 FACSIMILE OF COUNSEL 343- 1057 kelshlaw@yahoo. corn

Ms. Sandra Squire Executive Secretary Public Service Commission

201 Brooks Street i Charleston, West Virginia 25301 hs

RE: CASE NO. 08-0618-T-GI General Investigation Regarding Certification of Federal Universal Service Funding for Eligible Carriers in West Virginia

Dear Ms. Squire:

Enclosed herein please find thirteen (13) copies of the “Annual Lifeline Certification & Verification” filed by AT&T Mobility with the Federal Communications Commission (“FCC”) on August 29, 2008, as required by FCC Public Notice DA07- 3088. The filing includes information regarding American Cellular Corporation, Easterbrooke Cellular Corporation and Highland Cellular, LLC, whose West Virginia ETC authorities were transferred by this Commission to New Cingular , PCS, LLC dba AT&T Mobility by Recommended Decision entered August 20, 2008, final as of August 30, 2008, in Case No. 08-0620-T-PC.

While this Commission has not entered an order in this instant proceeding requiring the filing of a copy of the FCC document, in its Final Joint Staff Memorandum filed on August 15, 2008, Staff recommended that each ETC file a copy of the filing with the PSC simultaneously with its filing with the FCC.

Should you have any questions regarding this filing, please do not hesitate to contact me.

Sincerely,

-Robert R. Rodeckef - WV State Bar No. 3145

enclosures e-mail cc: Cindy Manheim *

t AT&T Mobility' Annual Lifeline Certification & Verification2

1. Ix] Eligible Telecommunications Carrier (ETC) serving Federal Default State (See table below.)

I certify that the companies listed below have procedures in place to verify the continued eligibility ofa statistically random sample of Lifeline ~ustomers.~Results are provided in the first chart below. I certify that the companies listed below have procedures in place to review income documentation and that, to the best of my knowledge, the companies were presented with documentation of the consumer's household income. I am an officer of the companies named below. I am authorized to make this certification for the Study Area(s) listed below.

2. Eligible Telecommunications Carrier (ETC) serving Non-Federal Default State (See table below.)

I certify that to the best of my knowledge the companies listed below are in compliance with the Lifeline and Link-up verification procedures in place in the state@ listed below. If any Lifeline customers of the companies listed below qualify based on income, I certify that to the best of my knowledge the companies listed below are in compliance with state Lifeline income certification procedures and that, to the best of my knowledge, documentation of income was presented. I am an officer of the companies named below. I am authorized to make this certification for the Study Area(s) listed below.

3. I certify that my company has not claimed federal Low Income support for any Lifeline customers in 2008 (insert current year). (See table below.)

A B C D E SAC (6 State Customers Customers Company Name digit Surveyed or Found to be

' ATCGT Mobility has iistcd in this cenification/verificalion thosc entity iiarncs as shown on rhe USAC'a website. ' For administrative CISC, AT&T Mobility has included each ofthe three categories on this single form. ' AT&T Mobility surveyed all ofits Lifeline custonien in the federal default mtc.

I SAC (6 digt State Customers Customers Company Name number) Surveyed or Found to be Verified Ineligible" Dobson Cellular Systems of Alaska, 619004 Alaska LLC4 Edge Wireless, LLC5 479006 Idaho American Cellular Corporationb 269905 Kentucky American Cellular Corporation 319012 Michigan Dobson Cellular Systems, Inc7 319912 Michigan New Cingular Wireless PCS,LLC 289912 Mississippi American Cellular Corporation' 439010 Dobson Cellular Systems 439005 Oklahoma Cingular Wireless (OR) 539006 Oregon Edge Wireless, LLC 539004 Oregon Cingular Wireless 639005 Puerto Rico Dobson Cellular Systems 449022 Texas Highland Cellular, LLC' 199002 Virginia American Cellular Corporation 339920 Wisconsin American Cellular Corporation 20901 I West Virginia Easterbrooke Cellular Corporation" 209006 West Virginia Highland Cellular, LLC 209003 West Virginia Cingular Wireless, LLC d/b/a 529910 Washington AT&T Wireless (WA)

States AT&T Mobility has not claimed federal Low Income support for in 2008'

~~ On November 15,2007, Dobson Communications Corporation became a wholly-owned subsidiary of AT&T Inc. Dobson Cellular Systems of Alaska, LLC remained a subsidiary of Dobson Communications Corporation following the merger and is managed by AT&T Mobility Corporation. Edge Wireless, LLC was acquired by AT&T Mobility 11 LLC on April 18,2008 and is managed by AT&T Mobility Corporation. On November 15,2007, Dobson Communications Corporation became a wholly-owned subsidiary of AT&T Inc. American Cellular Corporation remnined a subsidiary of Dobson Communications Corporation following the merger, but was converted to a limited liability company and is managed by AT&T Mobility Corporation. ' On Novembcr 15,2007, Dobson Communications Corporation became a wholly-owned subsidiary of AT&T Inc. Dobson Cellular Systems, Inc. remained a subsidiary of Dobson Communications Corporation following the merger, but was converted to a limited liability company and is managed by AT&T Mobility Corporation. ' Dobson Cellular Systems and American Cellular have a petition pending before the Oklahoma Corporation Commission to relinquish its ETC designation in the state. Also, earlier this year the Minnesota Public Utilities Commission granted American Cellular's request to relinquish its ETC designation in the state. In October 2006 Highland Ccllular was purchased by American Cellular Corporation a wholly-owned subsidiary of Dobson Communications Corporation. On November 15,2007, Dobson Communications Corporation became a wholly-owncd subsidiary of AT&T Inc. Highland Cellular remained a subsidiary of Dobson Communications Corporation following the merger with AT&T, but was converted to a limited liability company and is now managed by AT&T Mobility Corporation. loOn January 2,2008, an AT&T Mobility subsidiary purchased the assets of Easterbrooke, AT&T Mobility Corporation is the manager of this entity and hns assumcd Easterbrooke's ETC obligations. I' ATgLT Mobility reccntly received approval for its ETC designation In Alabama, Yew York and Virginia effective on August 1. 2008, and therefore these SACS wcrc not included in the verification process. Further, AT&T Mobility (f'kla Clngular Wireless) has :in application pending beforc thc Arkansas Public Service Commission for designation as an ETC.

2 A B C D E SAC (6 State Customers Customers Company Name digit Surveyed or Found to be number) Verified Ineligible* AT&T Wireless (AL) 259908 Alabama NIA N/A Cingular Wireless (AR) 409004 Arkansas NIA N/A American Cellular Corporation 159910 New York N/A N/A Dobson Cellular Systems 159910 New York NIA NIA Cingular Wireless (VA) 199009 Virginia NIA NIA

Signed,

William E. How (Printed Name of Officer)

President - Network Services (Title of Officer)

Tricia McKinley (Person Completing this Sample Letter)

(425) 580-8920 (Contact Phone Number)

1633 1 NE 72"d Way. Redmond, WA 98052 (Company Address)

22 &7l/bf 2M (Date)

Submit to WAC using only ONE method:

Fax to: (202) 776-0080 Email to: I.iVeiifications(rr,u~ac.or~ Mail to: Low Income Program 2000 L Street, NW, Suite 200 Washington, DC 20036

DeadIine: August 3Ist

3 CERTIFICATE OF SERVICE

I, Robert R. Rodecker, counsel for New Cingular Wireless, PCS, LLC dba AT&T

Mobility, do hereby certify that copies of the foregoing document were served upon the following parties of record on this 2"d day of September, 2008, in the manner so

indicated:

VIA HAND DELIVERY:

Carrie DeHaven, Esquire Legal Division Public Service Commission 201 Brooks Street Charleston, West Virginia 25301

VIA FIRST CLASS U.S. MAIL, POSTAGE PREPAID:

Patrick W. Pearlman, Esquire Consumer Advocate Division 700 Union Building 700 Kanawha Boulevard East Charleston, West Virginia 25301

- RdBEf?? R. RODECKER