March 17, Very truly yours, PLUNKETT COONEY A T T O R N E Y S & C O U N S E L O R S A T L A W

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1 March 17, 2017 Ms. Mary Jo Kunkle Executive Secretary Michigan Public Service Commission 7109 W. Saginaw Highway Lansing, MI Re: Talk America, LLC Case No: U Dear Ms. Kunkle: Enclosed for filing in the above matter, please find Exhibits E to the Application of Talk America, LLC for a Temporary and Permanent License in the above matter. Please contact me if you have questions. Very truly yours, PLUNKETT COONEY PDC/llr Enclosure Peter D. Cronk Direct Dial: pcronk@plunkettcooney.com Open A T T O R N E Y S & C O U N S E L O R S A T L A W 325 E. Grand River Avenue, Suite 250 East Lansing, MI T: (517) F: (517) plunkettcooney.com

2 BEFORE THE PUBLIC SERVICE COMMISSION OF MICHIGAN ) Application of ) ) TALK AMERICA, LLC ) Case No. U ) For A Temporary and Permanent ) License to Provide ) Basic Local Exchange Services in the ) State of Michigan ) ) SUBMISSION OF EXHIBIT E TO APPLICATION OF TALK AMERICA, LLC FOR A TEMPORARY AND PERMANENT LICENSE Peter Cronk Elaine M. Pohl Plunkett Cooney 325 E. Grand River Ave., Suite 250 East Lansing, Michigan Tel: (517) Fax: (517) pcronk@plunkettcooney.com epohl@plunkettcooney.com Counsel for Talk America, LLC Dated: March 22, 2017

3 EXHIBIT F Q. PLEASE STATE YOUR NAME, TITLE, BUSINESS ADDRESS AND TELEPHONE NUMBER. A. My name is Dan Deem. I am Senior Vice President Customer Care Operations of Talk America, LLC ( TA ). My business address is 4001 N. Rodney Parham Rd., Little Rock, AR I can be reached by telephone at (501) Q. PLEASE DESCRIBE YOUR EDUCATIONAL BACKGROUND AND PROFESSIONAL EXPERIENCE. A. I have a degree in management from the Malone College out of Canton, Ohio. I have over 30 years of telecommunications experience starting out in the finance organization of Alltel Wireline during my career I have held a number of finance roles, process improvements and procures and a variety of call center management responsibilities. After working in the wireless industry for a number of years I returned to Windstream and have been an employee of Windstream Holdings, Inc. for a year and half. My current responsibilities involve managing over 700 employees in our customer care centers, financial services, back office center, and call center support organization. Q. WHAT IS THE PURPOSE OF YOUR TESTIMONY IN THIS PROCEEDING? A. The purpose of my testimony is to describe the basic local exchange services that TA proposes to offer in Michigan and to review issues related to its request for a license and authority to provide such services. My testimony specifically relates to TA s managerial, financial, and technical competence to provide the

4 telecommunications services for which authority is requested, and its compliance with the rules and policies of this commission. Q. PLEASE DESCRIBE THE AUTHORITY THAT PETITIONER SEEKS FROM THE COMMISSION. A. Applicant requests the granting of a temporary and permanent license to provide basic local exchange service throughout the State of Michigan pursuant to Section 301(2) of the MTA. MCL (2). Section 301(2) states, pending the determination of an application for a license the Commission without notice and hearing may issue a temporary license for a period not to exceed one year. Q. HAS PETITIONER BEEN AUTHORIZED TO PROVIDE SUCH SERVICE IN ANY OTHER JURISDICTIONS? A. TA is currently certificated or is registered to provider telecommunications services in Alabama, Arizona, Colorado, Connecticut, Delaware, Florida, Georgia, Hawaii, Illinois, Indiana, Kentucky, Louisiana, Minnesota, Missouri, Montana, Nevada, New Hampshire, North Carolina, Oregon, Pennsylvania, South Carolina, Tennessee, Texas, Washington, and Wisconsin, to provide intrastate and interstate telecommunications services. Q. PLEASE DESCRIBE THE CORPORATE STRUCTURE OF PETITIONER. A. TA is a Delaware limited liability company formed on January 31, 2015, and is an indirect subsidiary of Windstream Holdings, Inc. A copy of TA s incorporation documents were provided to the Commission with the Application as Exhibit A. Q. IS PETITIONER LEGALLY AUTHORIZED TO DO BUSINESS IN MICHIGAN? A. Yes. TA is authorized to transact business in the State of Michigan.

5 Q. PLEASE ADDRESS PETITIONER S MANAGERIAL AND TECHNICAL QUALIFICATIONS. A. Applicant has the technical and financial ability to provide the proposed services. Applicant will be managed and operated by capable, experienced executives and employees who possess extensive managerial, financial, and technical experience in the telecommunications industry. Resumes of the key personnel that will be managing Applicant were provided to the Commission with the Application as Exhibit C. The officers and directors of TA are Anthony W. Thomas, President and Chief Executive Officer, Bob Gunderman, Chief Financial Officer, and Jeffery W. Small, Executive Vice President of Engineering. These individuals have both highly effective management skills and considerable telecommunications expertise. The biographies of these key executives are submitted as evidence that Applicant possesses the managerial qualifications required for the provision of telecommunications services on behalf of Applicant. Q. PLEASE DESCRIBE PETITIONER S FINANCIAL QUALIFICATIONS. A. TA has included as Exhibit D with its Applications the financial statements of its public parent company Windstream Holdings, Inc. As shown in the information provided, TA is financially qualified to operate within Michigan. Q. PLEASE DESCRIBE THE TYPES OF SERVICES THAT PETITIONER WILL OFFER IN MICHIGAN A. TA proposes to provide wireline local telecommunications service specifically, local exchange service (including, among other things, access to emergency services, access to operator services, alternative operator services, access to service, access to

6 directory assistance, toll limitation for qualifying low-income consumers, and any other ancillary functionalities that TA must provide pursuant to applicable statutes and regulations). TA s network will consist of leased facilities provided by other carriers. Under the requested authority, TA will not engage in any construction of buildings, towers, conduits, poles, or trenches. TA will focus on service packages, marketing strategies and designing customers service standards catered to the residential, small business, and enterprise CLEC customer segment. Q. WHAT FACILITIES WILL PETITIONER USE TO PROVIDE ITS PROPOSED LOCAL EXCHANGE SERVICES? A. TA plans on using the existing local exchange boundaries and established local calling scope of the incumbent local exchange in the Michigan service territories of AT&T Michigan, Frontier North, and Frontier Midstate. Q. DOES PETITIONER AGREE TO ABIDE BY ALL RULES, REGULATIONS, POLICIES AND ORDERS OF THIS COMMISSION, AND THE LAWS OF THE STATE OF MICHIGAN, IN ITS PROVISION OF TELECOMMUNICATIONS SERVICE? A. Yes. TA agrees to abide by all rules and regulations that are deemed to be applicable to TA. Q. HOW ARE CUSTOMER INQUIRIES/DISPUTES HANDLED? A. Customers with billing questions or complaints may also reach TA at its toll free number (800) In the event of a billing dispute, TA will perform a review of the disputed billing amount and promptly attempt to reach a settlement to the mutual satisfaction of all parties. Following a full investigation to determine

7 whether or not the charges may have been fraudulent or improper, TA may adjust the disputed bill. Q. PLEASE PROVIDE THE CONTACT TO THE CUSTOMER SERVICE DIVISION FOR COMPLAINT RESOLUTION. A. TA s contact to the customer service division for complaint resolution is Andrea Curtis, who may be reached in writing at 1720 Galleria Boulevard, Charlotte, NC 28270, by phone at (877) or via at windstream.executive.complaints@windstream.com. Q. HOW WILL TA BILL FOR ITS SERVICES? A. TA will bill its customers directly. Q. HOW WILL TA GUARD AGAINST SLAMMING? A. TA will prevent unauthorized switching of customers by obtaining a signed letter of authorization ( LOA ) or similar authorization from all new customers. TA will comply with Michigan law and Federal Communications Commission ( FCC ) regulations regarding how carriers may change a customer s Primary Interexchange Carrier. Q. PLEASE DESCRIBE THE PUBLIC INTEREST BENEFITS ASSOCIATED WITH PETITIONER S PROPOSED OFFERING OF TELECOMMUNICATIONS SERVICES IN MICHIGAN. A. The granting of this Application will promote the public interest, TA s operations will be overseen by a well-qualified management team with substantial telecommunications experience and technical expertise. The entry of TA into the Michigan telecommunications market will enhance competition in the provision of

8 telecommunications services within the State of Michigan. By enhancing competition, TA will bring significant benefits to telecommunications users within the State of Michigan by providing: (a) lower-priced and better-quality service; (b) innovative telecommunications services; (c) efficient use of existing communications resources; and (d) increased diversification in the supply of communications services. TA s proposed intrastate services are designed to meet the telephone needs of subscribers and permit subscribers to realize cost savings in communications services. Accordingly, TA anticipates that its proposed service will provide its subscribers with better quality services and will increase consumer choice through innovative, diversified, and reliable service and equipment offerings. Q. DOES THIS CONCLUDE YOUR TESTIMONY? A. Yes.

9 Respectfully submitted, Elaine M. Pohl Peter Cronk Plunkett Cooney Woodward Ave., Ste 2000 Bloomfield Hills, MI Tel: (248) Fax: (248) Counsel for Talk America, LLC Dated: March 17, 2017 Open