STATE OF ) ) BEFORE THE (Caption of Case) ) PUBLIC SERVICE COMMISSION IN RE: ) OF SOUTH CAROLINA Proceeding to Establish Guidelines for an Intrastate ) Universal Service Fund (USF) ) COVER SHEET ) ) ) DOCKET ) NUMBER: 1997 - 239 - C ) ) )

(Please type or print) Submitted by: C. Jo Anne Wessinger Hill SC Bar Number: 15025 Address: P.O. Drawer 7788 Telephone: 803-771-4400 (1900 Barnwell Street, 29201 Fax: 803-779-0016 Columbia, SC 29202 Other: 803-576-3714 Email: 'hill a,richardson lowden.corn NOTE; The cover sheet and information contained herein neither replaces nor supplements the filing and service of pleadings or other papers as required by law. This form is required for use by the Public Service Commission of South Carolina for the purpose of docketing and must be filled out completely. DOCKETING INFORMATION (Check all that apply) Emergency Relief demanded in petition Request for item to be placed on Commission's Agenda expeditiously

Other:

NATURF. OF ACTION (Check all that apply)

Electric Affidavit I.atter Request Electric/Gas Agrecmcnt Memorandum Rcqucst for Certificatio Electric/Telecommunications Answer Motion Request for Investigation Electric/Water Appellate Review Objection Resale Agreement Electric/Water/Telecom. Application Pctiiion Resale Amendment Electric/Water/Sewer Brief Petition for Reconsideration Reservation Letter Gas Certificate Petition for Rulemaking Response Railroad Comments Petition for Itule to Show Cause Response to Discovery Sewer Complaint H Petition to Intervene Return to Petition H Telecommunications Consent Order Petition to Intervene Out of Time Stipulation Transponation Discovery Prefiled Testimony Subpoena Water F.xhibit Promotion Tariff Water/Sewer Expedited Consideration Proposed Order Other: Administrative Matter Interconnection Agreement Protest Other. Interconnection Amendment Publisher's Affidavit Late-I'iled Exhibit Report BEFORE THE

PUBLIC SERVICE COMMISSION OF

SOUTH CAROLINA

Docket No. 1997-239-C

IN RE: ) OF THE CAROLINAS, LLC PETITION TO INTERVENE Proceeding to Establish ) AND PARTICIPATE AS A PARTY OF Guidelines for an Intrastate ) RECORD ) Universal Service Fund (USF) )

Petitioner Frontier Communications of the Carolinas, LLC (" Frontier" ), an incumbent local exchange provider, contributor, and recipient of State USF, hereby petitions the South Carolina

(" Public Service Commission Commission" ) pursuant to Rule 103-82S of the Commission's

Rules, for an order allowing Frontier to intervene in the above-referenced Docket with full rights to participate as a party of record. In support of its Petition, Frontier submits the following to the Commission:

l. As of October 29, 2009, Frontier is a facilities-based incumbent local exchange provider, contributor, and recipient of the State Universal Service Fund ("USF") in South

Carolina. See Orders No. 2009-769 and Order No. 2010-742, Docket No. 2009-220-C.

Frontier seeks to intervene in this proceeding with full rights to participate as a party of record to represent its interests in this matter as it would have not needed to be part of the original docket when opened on May 27, 1997.

2. On June 27, 2016, the South Carolina Office of Regulatory Staff ("ORS") filed a Petition for Commission approval to take certain actions to implement provisions of Commission Order No. 2016-22 and 2016 S.C. Act No. 181 (State

Telecom Equity in Funding Act).

3. Frontier's request to intervene is timely made and filed as the Commission

established a deadline of August 15, 2016 for any interested party to this matter to file and

make such petition to intervene.

4. Frontier participates in the state universal service fund ("State USF") in compliance with the Orders the Commission has entered in this Docket.

5, Frontier also participated and was aware of the discussion and efforts that lead to the enactment of the State Telecom Equity Funding Act, 2016 S.C. Act No. 181.

6. Frontier supports the relief sought by ORS in its Petition.

However, Frontier reserves the right to provide input and to take specific

position with respect to any issues that may arise in the proceeding.

7. The issues raised by the ORS in its Petition concerning the USF and related

matters in the context of this docket will affect Frontier; therefore, Frontier has a direct and

substantial interest in the subject matter of the Petition before the Commission.

8. Frontier believes that its participation in this proceeding is essential to

protect its interests and ensure a full and fair consideration of the issues raised in this

proceeding.

9. Permitting Frontier as a party will not cause any undue delay, and it will not

prejudice any party to this proceeding.

10. Correspondence and communications to Frontier with respect to this proceeding should be directed to undersigned counsel and Frontier regulatory contact:

C. Jo Anne Wessinger Hill, Esquire Steven W. Hamm, Esquire Richardson, Plowden 5 Robinson, P.A. P.O. Drawer 7788 (1900 Barnwell Street, 29201) Columbia, South Carolina 29202 803-77 1-4400 803-771-0016 facsimile Email; jhill@richardsonplowden,corn [email protected]

Susan A. Miller Frontier Communications 2600 Meridian Parkway Durham, NC 27713 E-Mail: Telephone: (919) 941-3411 Facsimile: (919) 544-0963

11. Frontier is informed and believes that its request to be made a party of record

in this docket is in the interest of the public, is consistent with the policies of the Commission

for public participation in the matters before it, and is necessary for the development of a

full and complete record.

WHEREFORE, based upon the foregoing, Frontier respectfully requests that the

following relief:

(1) That the Commission grant this Petition to Intervene as a formal party of

record by this Commission's granting its Petition to Intervene to permit

Frontier's intervention to protect its interests and to allow Frontier to take

such positions as it deems advisable;

(2) That the Commission direct any and all parties of record to provide F ro n t i e r with a copy of any pleadings, testimony and exhibits or any other

filings made in this proceeding; and

(3) That the Commission grant all such other r li/ef at it deems just and proper.

Respectfully submitted, this day of August, 2016.

By:

Columbia, South Carolina 29202 803-771-4400 803-771-0016 facsimile Email: [email protected] swhammgrichardsonplowden.corn Attorneys for Frontier Communications of the Caroiinas, LLC

August 2016

Columbia, South Carolina. BEFORE THE

PUBLIC SERVICE COMMISSION OF

SOUTH CAROLINA

Docket No. 1997-239-C

IN RE: Proceeding to Establish CERTIFICATE OF SERVICE Guidelines for an Intrastate Universal Service Fund (USF)

This is to certify that I, C. Jo Anne Wessinger Hill, an attorney with the law firm of Richardson

Plowden & Robinson, PA, have on August 15, 2016, served one (1) copy of the foregoing document, filed on behalf of Frontier Communications of the Carolinas, inc. in the above-referenced matter to the person(s) named below by causing said copy to be deposited in the United States Postal Service (unless otherwise specified), first class postage prepaid and affixed thereto, and addressed as follows:

VIA U.S. MAIL VIA U.S. MAIL M. John Bowen, Jr., Esquire Nannette S. Ewards, Esquire Margaret M. Fox, Esquire Jeffrey M. Nelson, Esquire South Carolina Telecommunications and Office of Regulatory Staff Broadband Association (South Carolina 1401 Main Street, Suite 900 Telephone Association) Columbia, South Carolina 29201 McNair Law Firm, PA Post Office Box 11390 Columbia, South Carolina 29211

VIA U.S. MAIL VIA U.S. MAIL The Honorable Jocelyn G. Boyd, Esquire Robert E. Tyson, Jr, Esquire Chief Clerk &. Administrator ITC DeltaCom Communications The Public Service Commission of South Carolina Sowell Gray Stepp & Laffitte, LLC 101 Executive Center Drive (29210) PO Box 11449 Post Office Drawer 11649 Columbia, South Carolina 29211 Columbia, South Carolina 29210 VIA U.S. MAIL VIA U.S. MAIL Benjamin P. Mustian, Esquire Anthony Mastando Celico Partnership d/b/a Verizon Wireless ITC DeltaCom Communications Willoughby & Hoefer, P.A. 7037 Old Madison Pike, Suite 400 Post Office Box 8416 Huntsville, AL 35806 Columbia, SC 29202 VIA U.S. MAIL VIA U.S. MAIL Scott Elliott, Esquire Burnet R. Maybank, III, Esquire United Telephone Company of the Carolinas, LLC Windstream South Carolina, LLC, d/b/a Century Link and Windstream Nuvox, LLC ELLIOTT &. ELLIOTT, P.A. 1230 Main Street, Suite 700 1508 Lady Street Columbia, South Carolina 29201 Columbia, South Carolina 29201

VIA U.S. MAIL VIA U.S. MAIL Frank R. Ellerbe, III, Esquire Jeanne W. Stockman, Esquire South Carolina Cable Television Association CenturyLink Post Office Box 944 14111 Capital Blvd.— NCWKFR0313 Columbia, South Carolina 29202 Wake Forest, 27587

VIA U.S. MAIL VIA U.S. MAIL Craig K. Davis, Esquire Faye A. Flowers, Counsel SC Office of Information Resources Budget & LCI International, Inc. Control Board Parker Poe Adams 8 Bernstein, LLP Davis Law Firm Post Office 1509 1524 Buck Hill Landing Road Columbia, SC 29202 Ridgeway, SC 29130

VIA U.S. MAIL VIA U.S. MAIL Bonnie D. Shealy, Esquire John F. Beach, Esquire TW Telecom of South Carolina, LLC & Competitive South Carolina Public Communications Carriers of the South, Inc. Association Post Office Box 944 Adams and Reese, LLP Columbia, South Carolina 29202 Post Office Box 2285 Columbia, South Carolina 29202

VIA U.S. MAIL VIA U.S. MAIL John J. Pringle, Jr., Esquire John M.S. Hoefer, Esquire NuVox Communications, Inc, & Sprint Nextel , Inc. Corporation Willoughby & Hoefer, P.A, Adams and Reese, LLP Post Office Box 8416 1501 Main St., 5th Floor Columbia, South Carolina 29202-8416 Columbia, SC 29201

VIA U.S. MAIL VIA U.S. MAIL Patrick W. Turner, Esquire Sonia Daniels, Esquire BellSouth Telecommunications, Inc. d/b/a AT&T AT&T Corp (f/k/a AT&T Communications of the South Carolina & AT&T Communications of the Southern States) Southern States 1230 Peachtree, 4'loor 1600 Williams Street, Suite 5200 Atlanta, GA 30309 Columbia, South Carolina 29201 VIA U.S. MAIL VIA U.S. MAIL Stan Bugner Susan B. Berkowitz, Esquire Verizon South, Inc. Women's Shelter — SC Appleseed Legal Justice 1301 Gervais Street, Suite 825 Center Columbia, South Carolina 29201 P.O. Box 7187 Columbia, South Carolina 29202

VIA U.S. MAIL William R.L. Atkinson, Esquire Nextel Corporation 233 Peachtree Street. N.E., Suite 2200 Atlanta, GA 30303

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