Ben Johnson Associates, Inc.

6070 West Hill Rd. 2252 Killearn Center Blvd Boise, Idaho 83703 Tallahassee, Florida 32309 Phone: (208) 342-1700 Phone: (850) 893-3600 Fax: (208) 384-1511 Fax: (850) 668-2731

RESPONSE TO REQUEST FOR INFORMATION: IDAHO LEGISLATIVE COUNCIL INTERIM COMMITTEE ON ENERGY, ENVIRONMENT AND TECHNOLOGY Re: INTEGRATED STATE ENERGY PLAN

To: Paige Alan Parker Legislative Services Office P.O. Box 83720 Boise, ID 83720-0054 (208) 334-4857 (208) 334-2125 (fax) [email protected] • Introduction This is a response to the Request For Information (RFI) issued by The Idaho Legislative Council Interim Committee on Energy, Environment and Technology on April 4, 2006, for a consultant to aid in the creation of a integrated state energy plan. The following proposal will address electricity and natural gas issues including electric transmission and natural gas pipelines. Transportation issues are not part of this bid. This response is organized around the specific items outlined in the RFI.

This proposal suggests a two-stage process for completing the integrated energy plan for Idaho. The first stage would be to complete a current profile of the state’s energy situation for natural gas and electricity. It would also include forecasts of energy needs along with estimates of the costs of various energy options. It would also include the transmission of electric power and the transportation of natural gas. The first stage would be completed in a three month period to give the Committee a base document to use in the development of energy polices produced during the second stage of the process. The energy profile and forecasts will be based on existing energy studies and plans available from utilities, regional and national organizations, and governments.

On a parallel track during stage one we would assist the Committee in designing the planing process that will occur during stage two. This will include defining the goals, expectations, scope, and the process that will occur in stage two. It will be to ‘plan the plan’. This would also include robust stakeholder engagements and discussions with relevant agencies. By completing the basic data and planning process in tandem will allow the Committee the time and tools to grapple with the policy directions it will need to be clarified in stage two.

Once the basic energy document is produced the Committee can use it as a basis to form policy recommendations. We will be available to work with the Committee – and subcommittees – in the formulation of recommendations for state energy policy. Our major function at this stage will to be to suggest various energy policy directions – such as tax incentives, portfolio standards, conservation options, etc. – along with estimated costs and benefits of each approach. At the end of the second stage an integrated energy plan can be produced that will include the base data and forecasts produced in stage one along with the policy recommendations developed in stage two. • An explanation of the There are a variety of approaches that could be undertaken by the Committee. alternative approaches These range from hiring a consultant to produce a ‘turn-key’ energy plan that that the Consultant feels would include recommendations and policy recommendation to be undertaken could be taken to frame a by the state. On the other end of the spectrum would be the Committee along state energy plan. with Legislative Staff actively producing its own energy plan while using a consultants to provide specific aspects necessary to complete the task outlined in House Concurrent Resolution No. 62. This proposal advocates a middle ground between these two approaches. This approach is described more fully below.

• A description of the The first order of business should be the collection and synthesis of energy steps that the Interim studies and plans currently in existence as they relate to Idaho. The existence Committee should take of these other energy plans is a major difference between today and when the during the next eight (8) last state energy plan was produced in 1982. At that time the basic data needed months toward to produce the energy plan needed to be created. Currently, for example, each developing a state energy investor owned utility produces an Integrated Resource Plan (IRP). In addition, plan. there are numerous national and regional plans that can be melded to be state specific. An energy document will be produced at the end of this first stage that will form the basis of discussions of the Committee leading to the development of policies that will give the plan meaning.

This is not a trivial undertaking. Each plan or study covers a unique geographical scope and encompass a variety of energy specifics (i.e. generation, transmission, conservation, etc.). Some of these plans contain forecasts of demographics and energy demand that vary and thus will need to be rationalized. The estimated costs of various generation resources vary among the plans because of both the scope of the study and the different assumptions used to develop the costs and benefit.

The melding of the various studies and plans tailored to the state should be undertaken first and completed in the shortest time frame reasonable because the data will be the foundation of state plan and will be needed for policy development. It is proposed that this stage be completed within 3 months of the letting of the contract.

Also during stage one we would assist the Committee in designing the planing process that will occur during stage two. This will include defining the goals, expectations, scope, and the formulation of policies process that will occur in stage two. In essence this would entail a ‘planning of the plan’. This would also include discussions with stakeholders and governmental and non- governmental agencies. Completing the basic data and planning the process in tandem will allow the Committee the time and the tools to grapple with a variety of the policy directions it will need to clarify during the remaining study period. • A detailed statement of In addition during this first stage the Committee can hear from energy stake the Consultant’s holders (utilities, government agencies, non-governmental organizations, etc.). approach to this specific The Committee would organize itself during this first stage. The Committee, project, including a for example, may want to form subcommittees focused on specific energy breakdown of specific aspects and form advisory groups. services the Consultant proposes to offer the With the basic data in hand the Committee can spend the remaining months Interim Committee. developing recommended policies. Too often state energy plans are produced then put on the shelf and ignored. This is what happened to the last state plan. In order to give the document meaning specific policies need to be implemented so that the Committee’s recommendations can be followed. These polices could include both specific legislation and the creation of mechanisms to monitor the plan on an ongoing basis.

During the second stage we will assist the Committee in the development of specific policies. These policies can only be fully defined once the data is gathered. It is difficult at this point to define the number of hours needed (and thus the cost) for this stage. As outlined below the bid will be for a specific amount for stage one, and a not-to-exceed amount for stage two.

The following studies and plans will be examined in detail in stage one and tailored to Idaho. This is no doubt not a complete list and an investigation will be undertaken during this stage to completed the list.

1. IOU Integrated Resource Plans A. Idaho Power Company B. Avista C. PacifiCorp 2. Public Power Loads, Forecasts, and Resources 3. Idaho Public Utilities Commission (IPUC) Annual Reports, utility filed documents, Commission Staff documents 4. Northwest Power and Conservation Council’s Fifth Power Plan (and related documents and updates) 5. Bonneville Power Administration (BPA) A. Annual Reports B. White Books (Loads and Resource Studies) C. Rate Case Publications (Power and Transmission) D. Strategic Direction Documents E. Miscellaneous Planning Documents 6. Pacific Northwest Utilities Conference Committee (PNUCC) Northwest Regional Forecast 7. Coordinating Council (WECC) Reliability Center Strategic Planning Initiative Task Force Report (and related documents) 8. Western Governors’ Association’s Clean and Diversified Energy Advisory Committee (CDEAC) Task Force Reports 9. Northwest Energy Coalition Citizens Energy Plan 10. Idaho National Laboratory (INL) Idaho’s Energy Options 11. National Energy Policy Development Group, Reliable, Affordable and Environmentally Sound Energy for Americas Future 12. Western Resource Advocates, Balanced Energy Plan 13. U.S. Department of Energy (DOE) Annual Energy Outlook, Annual Energy Review, National Energy Policy Report 14. Federal Energy Regulatory Commission, Winter Energy Outlooks, State of the Markets Report, Summer Energy Market Assessments, Energy Policy Act (EPAct) documents 15. National Commission on Energy Policy, Ending The Energy Stalemate

Stage One:

• A cost estimate broken We estimate the following hours by position for the performance of tasks during down by each discrete Stage One: segments of proposals of the Consultant’s Collection of various energy studies and plans: proposed services. Don Reading 130 Bill Eastlake 20 Bob Anderson 20 Research Associates 60

Synthesis and melding of energy studies and plans: Don Reading 250 Bill Eastlake 35 Bob Anderson 30 Research Associates 120

Planning the Plan Don Reading 25 Bill Eastlake 20 Bob Anderson 120

We charge for our services on the basis of the time devoted to a project, in accordance with the following hourly rates: Don Reading, Bill Eastlake, Bob Anderson ...... $ 150.00

Research Associates ...... $75.00

To assist in evaluating our proposal, setting priorities, and determining the overall scope of our engagement, we have broken down our estimated fees by activity, as set forth below:

Collection of various energy studies and plans: Don Reading $19,500 Bill Eastlake $3,000 Bob Anderson $3,000 Research Associates $4,500

Synthesis and melding of energy studies and plans: Don Reading $37,500 Bill Eastlake $5,250 Bob Anderson $4,500 Research Associates $9,000

Planning the Plan Don Reading $3,750 Bill Eastlake $3,000 Bob Anderson $18,000

Accordingly, we propose to perform all of the work during stage one for an amount not to exceed $116,000 including consulting fees associated with the stage one. There may be some travel expenses necessary during the collection of the various energy studies and plans. This travel, for example would be to utility headquarters, BPA, or the Power Council, to obtain and review documents not available by other means. Travel expenses will be billed on an actual expense basis and are included in the not to exceed amount.

We bill only for the actual time expended on a project, in accordance with the above schedule of rates. If you do not require as intensive a level of effort as we have assumed in our proposal, or if you decide to narrow the scope of our involvement, the actual cost would be correspondingly less. We would be happy to work with you in matching our effort to your actual needs, and can work within budgetary constraints that may apply.

Stage Two

Stage Two will be billed on an hourly basis at the rates listed above and for an amount not to exceed $100,000. It is expected this study will take on a life of its own. The process for stage two will not become clearly defined until the end of stage one. Therefore there is uncertainty at this point as to the number of hours needed and potential travel expenses in assisting the Committee with its deliberations in establishing energy policy recommendations. It would probably make sense to renegotiate our involvement at this point in time. The Committee should have a better idea of the direction it wishes to take in establishing specific policy recommendations at the end of stage one. Once the Committee decides the direction it wishes to take our involvement can be defined.

Please feel free to contact us if you have any questions, or would like us to prepare alternative cost estimates based upon a more limited scope, or different assumptions than those set forth above.

Ben Johnson Associates, Inc. is an economic research and consulting firm that • Basic data relative to primarily works for government agencies involved in public utility regulation. the Consultant’s However, we also work for many other types of clients, including law firms, organizational structure, corporations, and non-profit organizations. Although much of our work is history, personnel, focused on the electric and telecom industries, it has also encompassed natural special expertise and gas, water, and waste water utilities, as well as various unregulated firms. general credits. Individual resumes, Our research efforts have historically covered a very wide range. For instance, awards, associations, one recent study examined the effect of restored salmon runs on the price of etc., may be included. power in the Pacific Northwest, while another focused on the economic cost of Office brochures should local exchange telephone service. On another recent occasion we were asked to be submitted separately analyze a Big 5 accounting firm's assessment of damages in litigation arising as supplemental data. out of a contract dispute.

We were recently asked to analyze key economic factors affecting the valuation of certain property for tax purposes, while another client has asked us to analyze the potential impact of global warming on the future output of a major hydroelectric facility. Although our work typically culminates in expert testimony, we also produce cost studies, economic and environmental impact studies, opinion surveys, and a variety of other research reports.

For a Corporate Profile see attached. Individual resumes can be found on our web sites; http://www.benjohnsonassociates.com/ http://www.utilityregulation.com/

The lead researcher and project leader will be Don Reading. His office is in • List of the individuals Boise and he will be available throughout the study time period. He will expected to accomplish devote at least two-thirds time during stage one. During stage two he will be this work, including available on an as needed basis to help the Committee complete it policy anticipated consultants. reviews and recommendations. Two other principal researchers involved will Describe who will be Bill Eastlake and Bob Anderson. perform the various tasks, the amount of their Mr. Anderson will participate in all stages. However his main focus will be involvement and focused on ‘planning the plan’. Mr. Anderson's experience with energy responsibilities, and their planning dates from the 1970s when he headed Montana's state energy agency, qualifications. which was responsible for developing a state energy plan. Plans from that era, while analytically good, seldom predicted the future well or changed it much.

In recent years, states have tended to delegate planning responsibilities to the private sector, especially the utilities.

Anderson chaired NARUC's Committee on Energy Resources and Environment, which, beginning in the 1980s, invented Integrated Resource Planning (then called Least Cost Planning, now often called Portfolio Management), then refined and evolved its principles and methods. As a state utility regulator, he oversaw IRPs by Montana Power Company and its successor NorthWestern Energy. He led the development of Montana's resource procurement guidelines.

Mr. Eastlake will also participate in all stages of the process. Given his extensive experience one important role will be that as an advisor. His value is his experience and institutional memory having participated in the first energy plan in 1982. In addition to his experience as a Policy Strategist for the IPUC he was an Energy Policy Analyst for the Washington State Energy Office and held the same title at the Northwest Power Planning Council. He also worked as the Geothermal Program Manger for the Idaho Office of Energy.(principals resumes are attached)

In addition the Ben Johnson Associates staff in Tallahassee will be used for what ever support is needed and is included in the bid below.

• A list of the For Ben Johnson Associates clients see Corporate Profile see attached. Consultant’s clients over Bob Anderson clients: the past five (5) years. National Renewable Energy Laboratory, Wind Powering America Power Procurement Group Center for Resource Solutions National Rural Electric Cooperative Association Golden State Power Cooperative Plumas-Sierra REC Regulatory Assistance Project Western Energy Generation Information System (WREGIS) American Wind Energy Association Lawrence Berkeley Laboratories GridWest American Ecology • A description of all Capital City Development Corporation Idaho projects in which City of Eagle the Consultant has been Glimbia involved and all projects Idaho Center on Budget and Tax Policy with Idaho-based clients. Idaho Fish and Wildlife Foundation Idaho Ground Pumpers Idaho Rivers United Idaho State Attorney Generals Office Idaho State Tax Commission Industrial Customers of Idaho Power Jerome Cheese Mediator for Riley Creek Lumber/Northern Lights, Inc Midvale Telephone Company Minidoka Irrigation District Schwendimen Wind Settlers and Farmers Irrigation Districts The J.R. Simplot Company

• Provide a list of at least 1. Midvale Telephone Company, prepared a general rate case in five (5) projects, with Arizona. brief descriptions, 2. Participated in producing Idaho’s first energy plan in 1982. including the entity for 3. American Ecology, an economic impact study showing the which the Consultant impact of the Company on a three county region and the state. performed the services, 4. Idaho Fish and Wildlife Foundation/Idaho Rivers United, which shows the ability studies on the economic impact of Salmon and Steelhead fishing of the Consultant to for river communities and the state. complete projects of 5. Minidoka Irrigation District, a study of the value of similar scope. hydroelectric benefits of the Minidoka Project. 6. University of Washington Climate Impact Group, a study of the impact of climate change on Idaho ski areas and the economics of artificial snow making.

• Examples of state energy plans the Participated in producing Idaho’s first energy plan in 1982. Consultant has prepared or helped to prepare Corporate Profile

General Business Information

Ben Johnson Associates, Inc.®, (“BJA”) is a private, economic analysis and research consulting firm which specializes in issues surrounding public utility regulation. Its officers are Ben Johnson, Ph.D., President, and Don Reading, Ph.D., Vice President. The firm was incorporated on July 11, 1979, in the state of Florida, and has remained in business to the current date. The address of BJA’s home office is:

Ben Johnson Associates, Inc. 2252 Killearn Center Blvd. Suite 2D Tallahassee, Florida 32309

Telephone: (850) 893-8600 FAX: (850) 668-2731 Corporate Website: www.benjohnsonassociates.com Industry Website: www.utilityregulation.com

The address of BJA’s branch office is:

6070 West Hill Road Boise, Idaho 83703 Telephone: (208) 342-1700 FAX: 208-384-1511

BJA employs 2 Consulting Economists, 1 Senior Research Consultant, 1 Senior Research Assistant, and 2 Research Assistants. Devoted Employees

We expect that all BJA employees will, in some fashion, be engaged in tasks directly related to the project. Key BJA team members are Consulting Economists Ben Johnson and Don Reading, and Senior Research Consultant John Nesmith. Supporting BJA team members are Senior Research Assistant Elizabeth Birdwell and Research Assistants Cameron Potter and Ashley Scheuermann. The extent to which each BJA employee is involved in this project is detailed in Section II of this proposal.

Relevant Experience

In the cover letter to this proposal, we outlined some specific examples of our relevant experience working on projects similar to this work. However, our breadth of experience is much wider. We are well acquainted with the full range of issues involved in analyzing barriers to entry and other competitive market conditions, which is at the center of this proceeding.

For instance, we assisted your office with development of rules governing the introduction of competition into local telephone markets, in Docket No. 95-845-TP-COI. We also assisted your office with a state-specific impairment during the Commission’s Triennial Review Proceeding. Similarly, we served as consultants and advisors to the commissioners in Alaska concerning implementation of the 1996 Telecom Act, and we have extensive experience in numerous different jurisdictions analyzing various issues relating to local competition, and many other policy issues that are closely related to the issues that are involved in this proceeding.

Although we have not attempted to detail every issue and sub-issue for which we are qualified to provide expert assistance, the following list gives an indication of the depth and breadth of our expertise. Feel free to contact us to discuss our experience with issues which may not be covered by the following list.

Competitive Entry Cost of Capital Deregulation Economies of Scale Economic Depreciation Embedded Costs Forward Looking Costs Implementation of the 1996 Telecom Act Industry Restructuring Market Share Analysis Mergers and Acquisitions Network Modernization Network Unbundling Operations Support Systems Price Cap Regulation Quality of Service Unbundled Network Element Pricing Universal Service Support Mechanisms

The remainder of this section of our proposal will provide further information regarding jurisdictions in which we have appeared, our clients, our areas of expertise, and the companies we have analyzed.

Members of the firm have presented or currently have pending testimony before the following utility regulatory commissions or administrative bodies:

Alaska Public Utilities Commission Alberta Public Utilities Board Arizona Corporation Commission Arkansas Public Service Commission California Public Utilities Commission Colorado Public Utilities Commission Connecticut Department of Public Utility Control District of Columbia Public Service Commission Federal Communications Commission Fifth Jud icial District Court for Cou nty of Twin Falls Florida Public Service Commission Georgia Public Service Commission Hawaii Public Utilities Commission Idaho Public Utilities Commission Indiana Utility Regulatory Commission Interstate Commerce Commission Iowa State Utilities Board Kansas State Corporation Commission Public Service Commission Public Service Commission Maine Public Utilities Commission Maryland Public Service Commission Michigan Public Service Commission Minnesota Department of Public Service Minnesota Public Utilities Commission Public Service Commission Missouri Public Service Commission National Association of Security Dealers Nebraska Public Service Commission Nevada Public Service Commission New Hampshire Public Utilities Commission New Mexico State Corporation Commission North Carolina Utilities Commission Ohio Public Utilities Commission Oklahoma Corporation Commission Ontario Ministry of Culture and Communications Pennsylvania Public Utility Commission South Carolina Public Service Commission Public Service Commission Texas Public Utilities Commission Texas Railroad Commission United States Bankruptcy Court Utah Public Service Commission Virginia State Corporation Commission Washington Utilities and Transportation Commission West Virginia Public Service Commission Wisconsin Public Service Commission In most proceedings, we have worked for regulatory commissions, consumers' counsels, attorneys general, and public counsels. However, we have also gained experience through assisting various private firms and non-profit organizations.

Regulatory Commission Clients

Alabama Public Service Com mission - Public Staff for Utility Consumer Protection Alaska Public Utilities Comm ission Staff Arizona Corporation Commission Arkansas Public Service Commission Connecticut Department of Public Utility Control District of Columbia Public Service Commission Idaho Public Utilities Commission Idaho State Tax Commission Kansas State Corporation Commission Maine Public Utilities Commission Minnesota Department of Public Service Missouri Public Service Commission Nevada Public Service Commission New Hampshire Public Utilities Commission New Mexico State Corporation Commission North Carolina Utilities Commission - Public Staff Oklahoma Corporation Commission Ontario Ministry of Culture and Communications Staff of the Nevada Public Service Commission Texas Public Utilities Commission Virginia State Corporation Commission Washington Utilities and Transportation Commission Wisconsin Public Service Commission

Public Counsel and Attorney General Clients

Arizona Residential Utility Consumer Office Arkansas Attorney General Colorado Office of Consumer Counsel Connecticut Consumer Counsel District of Columbia Office of the People's Counsel Florida Attorney General - Antitrust Division Florida Public Counsel Georgia Consumers' Utility Counsel Hawaii Division of Consumer Advocacy Idaho Office of Attorney General Illinois Small Business Utility Advocate Office Indiana Office of Utility Consumer Counselor Iowa Consumer Advocate Kentucky Attorney General Maryland Office of the People's Counsel Michigan Attorney General Minnesota Attorney General Minnesota Office of Consumer Services Missouri Public Counsel Nevada Attorney General's Office of Advocate for Custom ers of Public Utilities New Hampshire Consumer Counsel New Jersey Ratepayer Advocate Ohio Consumer Counsel Pennsylvania Office of Consum er Advocate South Carolina Attorney General Utah Departm ent of Business Regulation - Com mittee of Consumer Services Virginia Attorney General Washington Attorney General

Other Government Agency Clients

Hillsborough County Property Appraiser United States Bureau of Mines United States Department of Health, Education, and Welfare United States Department of Justice - Antitrust Division United States Environmental Protection Agency Canada Department of Communications National Association of State Utility Consumer Advocates Austin, TX Corpus Christi, TX Dallas, TX El Paso, TX Fort Worth, TX Galveston, TX Henrico, VA Houston, TX Lubbock, TX Phoenix, AZ Richmond, VA San Antonio, TX Suffolk, VA Tucson, AZ York, VA Florida Department of General Services Provincial Governments of Canada Utah Department of Business Regulation

Private Organization Clients

Alabama Power Company Americall Ardmore Telephone Company Arizona Center for Law in the Public Interest Arkansas Telephone Company, Inc. ATX Telecommunications, Inc. BCRail Black United Fund of New Jersey, Inc. Blountsville Telephone Company Business Telecom, Inc. Casco Bank and Trust Center for Law in the Public Interest Central Arkansas Telephone Cooperative Cignal Communications Corporation Citizens' U tility Board of Wisconsin Cleveland County Telephone Company Colorado Energy Advocacy Office Combined Network, Inc. CommuniGroup Companies, Inc. Comptel Depositors Bank and Trust Discount Long Distance Discount WATS Lines, Inc. East Maine Medical Center East Ritter Telephone Company Eastern Security Corporation First National Bank, Capital City Group Florida Association of Concerned Telephone Companies Florida Telcom Long Distance Company Franklin Memorial Hospital Georgia Legal Services Program Hannaford Brothers Harris Corporation Independent Energy Producers of Idaho Industrial Customers of Idaho Power Interstate Securities Corporation Iowa Farm Bureau Federation J.R. Simplot Company Jarvis Long Distance LDDS Lavaca Telephone Company Lee Management Corporation Legal Aid Society of Metro Denver Liberty Telephone and Communications Long Distance Savers Louisiana/Mississippi Association of Resellers Madison County Telephone Company Magazine Telephone Company Maine Bankers Association Maine Telephone Users Association Merrill Trust Company Metro Media Long Distance Mid Maine Medical Center Midvale Telephone Exchange Mississippi Association of Resellers Mountain Home Telephone Company Mountain View Telephone Company National Telephone System Network I, Inc. Nevada Power Company NEXTLINK Pennsylvania, Inc. North American Telephone Company Ohio Ad vocates for Basic Equality Pan-Alberta Gas, Ltd. PenBay Memorial Hospital Perco Telephone Company Phone America of Carolina, Inc. Portland Press Herald Prairie Grove Telephone Company PW Ventures Redfield Telephone Company RDO Foods Company Rice Belt Telephone Company St. George Island Utility Company Skokomish Indian Tribe South Arkansas Telephone Company South Carolina Long Distance Association Stanton Telephone Company Starnet Corporation Statewide Credit Bureau State Farm Insurance Company Tel America Tel/Man, Inc. Teleconnect Company Telemarketing Com munications of Charlotte Telem arketing Communications of C olumb ia Telemarketing Communications of Eastern North Carolina Telem arketing Communications of F ayetteville Telemarketing Communications of The Piedmont Telemarketing of Greater New Orleans/Baton Rouge Telemarketing of Jackson Telemarketing of Lafayette Telemarketing of Louisiana, Inc. Teltec Savings Communications, Inc. Tennessee Resellers Association TMC of Tampa Bay Transcall America Tri-County Telephone Company USA Telecom Valueline of Alexandria Westel World Center for Birds of Prey Yelcot Telephone Company Yell County Telephone Company

BJA has analyzed issues concerning more than 300 telephone companies and telecommunications holding companies, as indicated below. On numerous occasions, there has been recurrent involvement.

Alascom, Inc. Allied Telephone Company ALLTEL, Florida, Inc. ALLTEL, Kentucky, Inc. ALLTEL, Missouri, Inc. ALLTEL, Pennsylvania, Inc. Alma Telephone Company Ameritech - Indiana Arizona Telephone Company Asotin Telephone Company AT&T Communications of the Midwest, Inc. AT&T Communications of Nevada AT&T Communications of the South Central States AT&T Communications of the Southern States - Florida AT&T Communications of the Southwest, Inc. - Texas AT& T Com munications of W isconsin Ballard Rural Telephone Coop. Corp., Inc. Bell Atlantic - District of Columbia Bell Atlantic - Maryland Bell Atlantic - New Jersey Bell Atlantic - Pennsylvania Bell Atlantic - Virginia BellSouth - North Carolina of Nevada Big Bend Telephone Company Blountsville Telephone Company BPS Telephone Company Brandenburg Telephone Company Brazoria Telephone Company Brazos Telephone Co-op, Inc. Breezewood Telephone Company Byers-Petrolia Telephone Company Call U.S. of Kentucky, Inc. Cambridge Telephone Company, Inc. Cass County Telephone Company Centel Communications Company Central Telephone Company of Florida Central Telephone Company-Midstate Central Telephone Company of Minnesota Central Telephone Company of M issouri Central Telephone Company of Nevada Central Telephone Company of North Carolina Central Telephone Company of Texas Central Texas Telephone Co-op, Inc. Century Telephone Enterprises, Inc. Century Telephone of Idaho Century Telephone of Missouri Chariton Valley Telephone Company Chesapeake and Po tomac Telephone Company - District of Columbia Chesapeake and Po tomac Telephone Company - Virginia Chesapeake and Po tomac Telephone Company - We st Virginia Choctaw Telephone Company Churchill County Telephone and Telegraph System Telephone Company Citizens Utilities Company Citizens Utilities Rural Company Citizens Telephone Company - Missouri Colorado Valley Telephone Co-op, Inc. Comanche County Telephone Co-op, Inc. Commonwealth Telephone Company Community Telephone Company, Inc. Continental Telecom, Inc. Continental Telephone Company of Colorado Continental Telephone Company of Florida Continental Telephone Company of Indiana Continental Telephone Company of Kentucky Continental Telephone Company of Minnesota Continental Telephone C ompany of M issouri Continental Telephone Company of Nevada Continental Telephone Company of the South - Florida Continental Telephone Company of Texas Continental Telephone Com pany of Virginia Continental Telephone Company of Washington Continental Telephone C ompany of the W est Cox Arizona Telecom CP National Corporation Craw - Kan Telephone Cooperative, Inc. Duo County Telephone Coop. Corp., Inc. Eastern New Mexico Rural Telephone Co-op, Inc. Eastex Telephone Co-op, Inc. Ellington Telephone Company Farber Telephone Company Farmers Mutual Telephone Company, Ltd. Fidelity Telephone Company Five Area Telephone Co-op, Inc. Florala Telephone Company Florida Telephone Corporation Foothills Rural Telephone Co-op, Inc. General States Utilities Corporation General Telephone Company of Florida General Telephone Company of Indiana General Telephone Company of Kentucky General Telephone Company of the Midwest - Missouri General Telephone Company of Minnesota General Telephone Company of the Northwest - Idaho General Telephone Company of the Southwest General Telephone Company of Virginia General Telephone Company of Washington General Telep hone C ompany of W isconsin Goodman Telephone Company Granby Telephone Company Grand River Mutual Telephone Corp. Great Southwest Telephone Corp. Green Hills Telephone Corp. GTE/Contel of New Mexico GTE Gulf Telephone Company Harold Telephone Company Highland Telephone Co-op., Inc. Hill Country Telephone Co-op, Inc. Hood Canal Telephone Company Hopper Telecommunications Corp. Iamo Telephone Company Telephone Company, Inc. Telephone Company, Inc. Inland Telephone Company Kalamara Telephone Company Kerrville Telephone Company Kingdom Telephone Company Lake Dallas Telephone Company, Inc. Lathrop Telephone Company Le-ru Telephone Company Lewisport Telephone Company, Inc. Lincoln County Telephone System, Inc. Logan Telephone Co-op., Inc. MCI Telecommunications Corp. Mcdonald County Telephone Company Mt. Rural Telephone Co-op, Inc. Mark Twain Rural Telephone Company Mid-Missouri Telephone Company Mid-Plains Rural Telephone Co-op, Inc. Telephone Company Miller Telephone Company Moapa Valley Telephone Company Mokan Dial Inc Mountain States Telephone and Telegraph Company - Arizona Mountain States Telephone and Telegraph Company - Colorado Mountain States Telephone and Telegraph Company - Idaho Mountain States Telephone and Telegraph Company - Utah Muenster Telephone Corporation of Texas New England Telephone and Telegraph Company - Maine Nevada Telephone - Telegraph Company Telephone Company New Florence Telephone Company New London Telephone Company North American Telephone Company - Florida North Central Telephone Co-op., Inc. North Florida Telephone Company Northeast Florida Telephone Company Northeast Missouri Rural Telephone Company Telephone Company - Minnesota Nynex Corporation Telephone Company Orchard Farm Telephone Company Oregon Farmers Mutual Telephone Company Ozark Telephone Company Telephone Company - Washington Pacific Telesis Group Panhandle Telephone Cooperative, Inc. Peace Valley Telephone Company Peoples Rural Telephone Coop. Corp., Inc. Peninsula Communications, Ltd. Peoples Telephone Co-op, Inc. Quaker State Telephone Company Quincy Telephone Company Communications International, Inc. Riviera Telephone Company, Inc. Rochester Telephone Corporation Rockland Telephone Company Rock Port Telephone Company St. John Telephone Company St. Joseph Telephone and Telegraph Company Seneca Telephone Company Telephone Company - Kentucky South Central Bell Telephone Company - Mississippi South Central Rural Telephone Co-op. Corp., Inc. Telephone Company - Florida Southern Bell Telephone Company - Georgia Southern Bell Telephone Company - North Carolina Southern New England Telecommunications Corporation Southern New England Telephone Company - Connecticut Southern Pacific Communications Company Southland Telephone Company, Inc. South Plains Telephone Co-op, Inc. Southwest Arkansas Telephone Co-op, Inc. Telephone Company - Kansas Southwestern Bell Telephone Company - Missouri Southwestern Bell Telephone Company - Oklahoma Southwestern Bell Telephone Company - Texas Southwest Texas Telephone Company Sprint Communications Corp. Stanton Telephone Company Steelville Telephone Exchange, Inc. Stoutland Telephone Company Telemarketing Communications Texas-Midland Telephone Company Thacker & Grigsby Telephone Company Toledo Telephone Company Tri-County Telephone Company, Inc. Trinity Valley Telephone Company U.S. Telephone, Inc. US WEST Communications, Inc. - Arizona US WEST Communications, Inc. - Iowa United Telephone Company of Florida United Telephone Company of Minnesota United Telephone Company of Missouri United Telephone Company of Texas United Telephone Company of Washington Universal Telephone Company of the Southwest Verizon North, Inc. Verizon South, Inc. Vista-United Telecommunications West Kentucky Rural Telephone Co-op. Corp., Inc. West Texas Rural Telephone Co-op, Inc. Wes-Tex Telephone Co-op, Inc. Winter Park Telephone Company , Inc. XIT Rural Telephone Co-op, Inc. Yelm Telephone Company