HomeMy WebLinkAbout20042666.tiff RESOLUTION
RE: APPROVE PUBLIC UTILITIES COMMISSION, PARTIAL STIPULATION AND PARTIAL
SETTLEMENT AGREEMENT OF THE PARTIES RE: JOINT APPLICATION TO
EXPAND LOCAL CALLING AREA IN NORTHERN COLORADO AND AUTHORIZE
CHAIR TO SIGN
WHEREAS, the Board of County Commissioners of Weld County, Colorado, pursuant to
Colorado statute and the Weld County Home Rule Charter, is vested with the authority of
administering the affairs of Weld County, Colorado, and
WHEREAS,the Board has been presented with a Partial Stipulation and Partial Settlement
Agreement of the Parties regarding a Joint Application to Expand Local Calling Area in Northern
Colorado between the County of Weld, State of Colorado, by and through the Board of County
Commissioners of Weld County, and the Colorado Public Utilities Commission, with terms and
conditions being as stated in said agreement, and
WHEREAS,after review,the Board deems it advisable to approve said agreement, a copy
of which is attached hereto and incorporated herein by reference.
NOW,THEREFORE, BE IT RESOLVED by the Board of County Commissioners of Weld
County, Colorado, that the Partial Stipulation and Partial Settlement Agreement of the Parties
regarding a JointApplication to Expand Local Calling Area in Northern Colorado between the County
of Weld, State of Colorado, by and through the Board of County Commissioners of Weld County,
and the Colorado Public Utilities Commission be, and hereby is, approved.
BE IT FURTHER RESOLVED by the Board that the Chair be, and hereby is, authorized to
sign said agreement.
The above and foregoing Resolution was,on motion duly made and seconded, adopted by
the following vote on the 8th day of September, A.D., 2004.
BOARD OF COUNTY COMMISSIONERS
f\\ E LA WEk;D COUNTY, COLORADO
861t ' S '
Robert D. Masden, Chair
tf). yyr• Clerk to the Board
�A � /
A r William H. e, Pro-Tem
Deputy Clerk to the Board
Geile
APBROV AS- RM:
Da . Long
ounty Attorne
Glenn Vaa
Date of signature: qfrAay
2004-2666
BC0034
fir!
BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF COLORADO
Docket No. 03A-496T
IN THE MATTER OF THE JOINT APPLICATION TO EXPAND THE LOCAL CALLING
AREA IN NORTHERN COLORADO
PARTIAL STIPULATION AND PARTIAL SETTLEMENT AGREEMENT OF THE PARTIES
Nunn Telephone Company ("Nunn"), the Staff of the Public Utilities Commission of the
State of Colorado ("Staff'), the Office of Consumer Counsel ("OCC"), and Larimer County,
Colorado; Weld County, Colorado; City of Loveland, Colorado; Loveland Chamber of Commerce;
City of Greeley, Colorado; Town of Windsor, Colorado; Windsor Chamber of Commerce; City of
Fort Collins, Colorado; Fort Collins Chamber of Commerce; Town of Ault, Colorado; Town of
Timnath, Colorado; Town of LaSalle, Colorado; Town of Kersey, Colorado; Town of Mead,
Colorado; Town of Nunn, Colorado; City of Evans, Colorado; Town of Eaton, Colorado; Town of
Estes Park, Colorado; Town of Milliken, Colorado; Town of Platteville, Colorado; Town of
Berthoud, Colorado; and Town of Johnstown, Colorado (collectively, the "Applicants"), each
individually a "Party" and collectively "the Parties," by and through their respective counsel,
submit this Partial Stipulation and Partial Settlement Agreement ("Partial Stipulation") as more
fully described herein. The Parties respectfully submit this Partial Stipulation for approval by the
Commission pursuant to Rule 723-1-83(a) (2000) of the Commission's Rules of Practice and
Procedure.
PROCEDURAL BACKGROUND
On or about November 14, 2003, the Applicants filed a Joint Application to Expand the
Local Calling Area in Northern Colorado ("Joint Application"). The Commission published its
Notice of Application Filed on or about November 19, 2003. By Decision No. C03-1350, Qwest
and Nunn were made indispensable parties to the Docket. Qwest and Nunn filed a joint Notice of
Intervention, Entry of Appearance, and Request for Extension of Time on December 15, 2003. In
the motion, Qwest and Nunn requested an extension of time to and including January 30, 2004 to
perform and submit "all necessary analyses to quantify calling volumes per customer ... and all
necessary revenue and cost analyses to quantify the rate increment per customer." The motion was
granted on December 17, 2003. OCC filed its Notice of Intervention on December 19, 2003. On or
about December 30, 2003, Staff intervened in the Joint Application.
Also on December 30, 2003, the Commission on its own motion entered an order waiving
the requirement that the Commission mail its decision on the status of the Joint Application by
January 5, 2004. See Decision No. C03-1465 and 4 C.C.R. 723-2-17.3.5. In that order, the
Commission enlarged the time in which the Joint Application would automatically be deemed
complete without Commission action and extended the date by which it must determine the
completeness of the Joint Application to and including February 19, 2004.
During the months of December of 2003 and January and February of 2004, non-disclosure
agreements were filed on behalf of the OCC, Staff, Qwest, and various Applicants pursuant to Rule
723-16.
On January 30, 2004, in accordance with Decision No. C03-1350, Nunn filed the results of
its analyses to quantify the calling volumes per customer in the exchanges affected by the Joint
Application as well as all necessary revenue and cost analyses to quantify the rate increment per
customer. The revenue and cost analyses demonstrated that expanding the local calling area would
equate to a gross annual rate increment of an additional $43,565 to be recovered from Nunn's
customers.
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On January 30, 2004, in accordance with Decision No. C03-1350, Qwest filed the results of
its analyses to quantify the calling volumes per customer in the exchanges affected by the Joint
Application as well as all necessary revenue and cost analyses to quantify the rate increment per
customer. The revenue and cost analyses demonstrated that expanding the local calling area would
equate to a rate increment of an additional $.06 per access line per month that could be added to all
of Qwest's residential and business local phone service rates for all customers in its Colorado
service territory.
On March 29, 2004, the Parties held a meeting at which Nunn informed the Parties that it
would not participate in the local calling area expansion; instead, Nunn stated that it would offer its
customers an optional plan to the larger calling area and measured local service to those who do not
choose the optional plan. At that time, Nunn did not identify what the rates would be for the
optional or measured minutes of use. Staff requested that Qwest revise its cost study to reflect
known changes in the switched access carrier common line rates and the capital investment
associated with the calling area expansion.
On or about April 23, 2004, Staff filed its Unopposed Motion for Enlargement of Time to
File a Report in Response to Qwest Corporation's Cost Study, and Request for Waiver of Response
Time. That request was granted pursuant to Decision No. R04-0454-I.
On April 9, 2004, Qwest filed revised analyses to quantify known changes in the switched
access carrier common line rates and the capital investment associated with such expansion.
Further, Qwest updated the study to reflect the 2003 factors, which became available prior to that
filing. Based upon the revised revenue and cost analysis of June 2003 though August 2003, the
costs and lost revenues to Qwest from expanding the local calling area would equate to a rate
3
increment of an additional $.06 per access line per month to Qwest's residential and business local
phone service rates for all customers in its Colorado service territory.
On May 13, 2004, Staff filed its Report Pursuant to 4 C.C.R. 723-2-17.3.5. Staff confirmed
that Nunn elected to offer an optional local calling area plan while Northern Colorado Qwest
customers would receive a non-optional local calling area expansion that would include the Nunn
exchange as part of the approval of the Joint Application. Staff submitted a copy of Nunn's
correspondence confirming its intentions, a copy of which is attached as Attachment A. Staff
further identified the revisions Qwest incorporated into its revised analyses filed with the
Commission on August 9, 2004 that addressed Staff's concerns. Staff reported the revised study
was complete for purposes of this docket and recommended the study be accepted without further
modification.
On May 21, 2004, the Administrative Law Judge issued an order accepting Qwest's revised
cost study filed on or about April 9, 2004 and ordering Qwest to proceed with the customer survey
using the survey form approved in the order. See Decision No. R04-0515-I.
On June 30, 2004, Qwest filed its Notice of Survey Results. Qwest reported that it mailed
1,600 surveys to a random selection of its residential customers throughout the exchange areas
being considered for calling area expansion. Of the 1,600 surveys mailed, 488 surveys (30.5%)
were returned. Of those surveys that were returned, 387 responded yes (79%) and 101 responded
no (21%).
THE AGREEMENT
The Parties agree and stipulate as follows:
1. Summary of Agreement. In an attempt to narrow the disputed issues in this docket
and to promote administrative efficiency, the Parties are entering into this Partial Stipulation to
4
resolve specific factual and legal issues described herein. All remaining issues are reserved and
will be determined by the Commission.
2. Requested Expansion of Local Calling Area. The Applicants propose that the local
calling area expansion occur between the following exchanges:
From Qwest
Exchange: To Exchange:
Berthoud La Salle, Nunn Exchange
Eaton-Ault Estes Park, Ft. Collins, Loveland, Mead
Estes Park Eaton-Ault, Gilcrest, Greeley, Johnstown-Milliken, La Salle, Mead,
Platteville, Windsor, Nunn Exchange
Fort Collins Eaton-Ault, Gilcrest, Greeley, Johnstown-Milliken, La Salle, Mead,
Platteville
Gilcrest Estes Park, Ft. Collins, Loveland, Nunn Exchange
Greeley(Evans Estes Park, Ft. Collins, Loveland
&Kersey)
Johnstown- Estes Park, Ft. Collins, Nunn Exchange
Milliken
La Salle Berthoud, Estes Park, Ft. Collins, Loveland, Nunn Exchange
Loveland Eaton-Ault, Gilcrest, Greeley, La Salle, Platteville, Windsor, Nunn
Exchange
Mead Eaton-Ault, Estes Park, Ft. Collins, Windsor, Nunn Exchange
Platteville Estes Park, Ft. Collins, Loveland, Nunn Exchange
Windsor Estes Park, Loveland, Mead, Nunn Exchange
3. Community of Interest Standard. The Applicants seek approval of the local calling
expansion pursuant to the alternative criteria standard set forth in Rule 723-2-17.3.3.2. Rule 723-2-
17.3.3.2 provides that, when evaluating such a request, "the Commission shall consider community
of interest issues dictated by urban growth patterns, and the present and future availability of
essential services in rural areas." 4 C.C.R 723-2-17.3.3.2. In making its determination, the
Commission shall consider the following criteria: (a) the local calling area principles of Rule 723-
2-17.3.1; (b) customer calling patterns; (c) the location of serving transportation centers; (d)
demographic profiles of the residents of the exchange(s); and (e) the location of primary centers of
5
business activity and employment centers, and the location of employee residences. See 4 C.C.R
723-2-17.3.3.2. In addition, "[t]he Commission may consider other pertinent factors such as the
availability and feasibility of optional calling plans, and the local and long distance competition." 4
C.C.R. 723-2-17-3.3.2. The Parties note that Rule 723-2-17.3.1 provides that, in general and to the
extent possible, each local calling area should: (a) allow customers to place and receive calls
without payment of a toll charge to 9-1-1, their county seat, municipal government, elementary and
secondary school districts, libraries, primary centers of business activity, police and fire
departments, and essential medical and emergency services; (b) be provided in both directions
between the two exchange areas; and (c) not exhibit any discontinuities. See 4 C.C.R. 723-2-
17.3.1.
4. Conformity with Alternate Criteria Standard. Relying upon the information
contained in the Joint Application, Nunn, Staff, and the OCC stipulate with the Applicants to the
facts contained therein. The Parties agree that the stipulated facts constitute clear and convincing
evidence of a community of interest under the alternative criteria standard. A copy of the Joint
Application, excluding exhibits, is attached hereto as Attachment B and is incorporated herein by
reference.
5. Purpose of this Agreement. This Partial Stipulation is a partial settlement of specific
disputed issues of fact and law, and is made for settlement purposes only. All other issues remain
in dispute. Except for settlement purposes in this docket, no Party concedes the validity or
correctness of any regulatory principle or methodology directly or indirectly incorporated in this
Partial Stipulation. Furthermore, this Partial Stipulation does not constitute an agreement, by any
Party, that any principle or methodology contained within this Partial Stipulation may be applied to
any situation other than the above-captioned docket. No precedential effect or other significance,
6
except as may be necessary to enforce this Partial Stipulation or a Commission order concerning
this Partial Stipulation, shall attach to any principle or methodology contained in this Partial
Stipulation.
6. Support by Parties. Except as provided herein, the Parties agree to support all
aspects of the stipulations and agreements embodied in this Partial Stipulation in any hearing or
proceeding conducted to determine whether the Commission should approve this Partial
Stipulation, including, but not limited to, any pleadings, comments filed, or testimony given in such
a proceeding, or in any appeal of the decision. Each Party also agrees that it will take no action in
any administrative or judicial proceeding, or otherwise, which would have the effect, directly or
indirectly, of contravening the provisions or purposes of this Partial Stipulation. Furthermore, each
Party represents that, except as expressly provided in this Partial Stipulation, in any proceeding in
which this Partial Stipulation or its subject matter may be raised by a non-party, it will support the
continued effectiveness of this Partial Stipulation. Without prejudice to the foregoing, the Parties
and each of them expressly reserve the right to advocate positions different from those stated in this
Partial Stipulation in any proceeding other than one necessary to enforce or obtain approval of this
Partial Stipulation or a Commission order concerning this Partial Stipulation. Nothing in this
Partial Stipulation shall constitute a waiver by the Parties or any of them with respect to any matter
not specifically addressed in this Partial Stipulation.
7. Final Commission Order. This Partial Stipulation shall not become effective and
shall be of no force and effect until the issuance of a final Commission order approving this Partial
Stipulation and not containing any material modification of this Partial Stipulation that is deemed
unacceptable by any of the Parties. In the event the Commission modifies this Partial Stipulation in
a manner unacceptable to any Party, that Party may withdraw from this Partial Stipulation and shall
7
so notify the Commission and the other Parties in writing within ten (10) days of the date of the
Commission order. In the event a Party exercises its right to withdraw from this Partial Stipulation,
this Partial Stipulation shall be null and void and of no effect in these or any other proceedings, and
the above-captioned docket shall be set for hearing and a procedural schedule established.
8. Inadmissibility. In the event this Partial Stipulation becomes null and void, or in the
event the Commission does not approve this Partial Stipulation, this Partial Stipulation, as well as
the negotiations and discussions undertaken in conjunction with this Partial Stipulation, shall not be
admissible into evidence in these or any other proceedings.
9. Public Interest. The Parties stipulate that they have reached this Partial Stipulation
by means of a negotiated process in the public interest and that the results reflected herein are just,
reasonable, and in the public interest. The Parties agree that approval by the Commission of this
Partial Stipulation shall constitute a Commission determination that the stipulations and agreements
contained herein are a just, equitable, and reasonable resolution of the issues described herein. The
Parties agree to the specific waiver of any Commission rule identified in this Partial Stipulation,
and the waiver of any such additional Commission rule(s), to the extent necessary to implement or
effectuate this Partial Stipulation.
10. Construction and Enforcement. This Partial Stipulation shall be construed,
interpreted, and enforced in accordance with the laws of the State of Colorado.
11. Integrated and Binding Agreement. This Partial Stipulation is an integrated
agreement that may not be altered by the unilateral determination of any Party and which shall be
binding on and shall inure to the benefit of the Parties hereto and their successors and assigns.
12. Counterparts. This Partial Stipulation may be executed in separate counterparts, and
the counterparts taken together shall constitute the whole of this Stipulation.
8
13. Facsimile Execution and Signature Authority. This Partial Stipulation may be
executed by facsimile transmission. Signatures obtained through facsimile transmission shall be
valid and binding as if they were original signatures. Attorneys and other representatives and
agents signing on behalf of the Parties represent and warrant that each has the authority to bind the
Party to the terms of this Partial Stipulation.
9
JAN-07-2005 FRI 01:31 PM FAX NO. P. 02
BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF COLORADO
Docket No.03A-496T
IN THE MATTER OF THE JOINT APPLICATION TO EXPAND THE LOCAL
CALLING AREA IN NORTHERN COLORADO
MOTION TO SUBMIT ADDITIONAL APPLICANT SIGNATURES TO THE
PARTIAL STIPULATION AND PARTIAL SETTLEMENT AGREEMENT
The City of Loveland, Colorado, through its undersigned attorney, respectfully
requests that the Public Utilities Commission accept the attached signatures to the Partial
Stipulation and Partial Settlement Agreement filed on August 30, 2004 (`Partial
Stipulation") from the following Applicants: Latimer County, Colorado; Weld County,
Colorado; City of Fort Collins, Colorado; Town of Windsor, Colorado; City of Greeley,
Colorado; Town of Ault, Colorado; Town of LaSalle, Colorado; Town of Mead,
Colorado; Town of Kersey, Colorado; City of Evans, Colorado; Town of Eaton,
Colorado; Town of Milliken, Colorado; Town of Estes Park, Colorado; and Town of
Berthoud, Colorado. Those signatures are submitted in accordance with the discussion
and schedule established at the Preheating Conference and aro intended to be a part of the
Partial Stipulation as if filed contemporaneously therewith.
Respectfully submitted this 2001 day of October, 2004.
CITY OF LOVELAND,COLORADO
By:
Sharon L. Citino, #32800
Loveland City Attorney's Office
500 East Third Street
Loveland, CO 80537
(970) 962-2540
citins@ci.loveland.co.us
JAN-07-2005 FRI 01:31 PM FAX NO. P. 03
ATTORNEYS FOR THE
CITY OF LOVELAND, COLORADO
STIPULATED AND AGREED UPON this 30`h day of August, 2004.
Staff of the Commission: Office of Consumer Counsel:
Geraldine G. Santos-Rach Patricia A. Parker
Chief of Fixed Utilities Rate/Financial Analyst
1580 Logan St., OL1 1580 Logan St., OL7
Denver, CO 80203 Denver, CO 80203
303.894.2537 /3y' / 303.894.2126
Approved as to Form: Approved as to Form:
Anne K. Botterud G. Harris Adams
Reg. No. 20726 Reg. No. 19668
Office of the Attorney General Office of the Attorney General
1525 Sherman Street, 7`h Floor 1525 Sherman St., 5th Floor
Denver, CO 80203 Denver, CO 80203
303.866.3867 303.866.5441
r
Nunn Telephone Company: Qwest Corporation:
Name: Paul R. McDaniel
Title: Assistant Vice President for Regulatory Affairs
P.O. Box 249 Denver, CO 80202
Nunn, CO 80648-0249 303.896.4552
Approved as to form: Approved as to Form:
Barry L. Hjort David W. McGann
Reg. No. 19551 Reg. No. 34521
P.O. Box 300 1005 17th St., Suite 200
Littleton, Co. 80160 Denver, CO 80202
303.795.8080 303.896.3892
10
STIPULATED AND AGREED UPON this 30th day of August, 2004.
Staff of the Commission: Office of Consumer Counsel:
Geri Santos-Rach Kenneth V. Reif, Director
Chief of Fixed Utilities Office of Consumer Counsel
1580 Logan St., OL2 1580 Logan St., OL7
Denver, CO 80203 Denver, CO 80203
303.894.2533 303.894 121
Approved as to Form: Approved as to Form:
Anne K. Botterud G. Harris Adams
Reg. No. 20726 Reg. No. 19668
Office of the Attorney General Office of the Attorney General
1525 Sherman Street, 7th Floor 1525 Sherman St., 5`h Floor
Denver, CO 80203 Denver, CO 80203
303.866.3867 303.866.5441
Nunn Telephone Company:
Name:
Title:
P.O. Box 249
Nunn, CO 80648-0249
Approved as to form:
Barry L. Hjort
Reg. No. 19551
P.O. Box 300
Littleton, CO 80160
303.795.8080
10
08/30/04 MON 11:55 FAX e 00
EIS/.'O/?O04 1^_: 54 370^97^7^7
iIUf N TELEPHONE CO
PAGE 0./0^
STIPULATED AND AGREED UPON this 30th day of August, 2004
Staff of the Commission: Office of Consumer Counsel:
Geri Santos-Rath Patricia A. Parker
Chief of Fixed Utilities Rate/Financial Analyst
1580 Logan St., OL 2 1580 Logan St., OL7
Denver, CO 80203 Denver, CO 80203
303.894.2533 303.894.2126
Approved as to Form:
Approved as to Form:
Anne K. Botterrd G. Harris Adams
Reg. No. 20726 Reg. No. 19668
Office of the Attorney General Office of the Attorney General
1525 Sherman Street, 7th Floor 1525 Sherman St., 5t'Floor
Denver, CO 80203 Denver, CO 80203
303.8663867 303.866.544
7 i
Nunn TeJeph .cetiipat >
a _
Title: -
P.O. Box 249
Nunn, CO 80648-0249
t7-.- e
Approved issioftrnir
Barry L. Iijort
Reg. No. 19551
P.O. Box 300
Littleton, CO 80160
303.795.8080
Jo
AUG-30-2004 M0N 10:35 AM FAX NO, F. 03
Lorimer County, Colorado: Weld County, Colorado:
Name: Ncune: Robert D. Masden _
Title: - Title: Chairs Board of County Commissioners
Address; Address: 91 1gth Street
Greeley, Colorado 806.22
Telephone: T ephone: 970-356-4000 x 4200
SEP 0 R 7004
Signature 5ignatui��
Approved as to Fonn: Approved as t on. 7 4.447-
ATTEST:
ATTEST: ,�
Name:
Title: WELD COUNTY CLER. TOTH BO
Reg, No.; % c "'1/4?�1
Address; '"DEPUTY CLE TO THE BOAR
915 10th St. Greeley, CO %r. ` W _q
Telephone: Telephone: (970)356-4000 X4200U N'S
Signature . •
City of Loveland, Colorado: Loveland Chamber of Commerce: '
Name: DON F. WILLIAMS Name: (��'-�=
Title: CITY MANAGER Title:
Address: 500 EAST THIRD ST. Address:
LOVELAND, CO 80537
Telephone: 570-962-2306 Telephone: M� _
rr—
J "i VLJ_XJ� bwtti
Signature Signature
Approved as to Form: Approved as to Form:
Name; SHARON CITINO Name:
Title: ASSISTANT CITY ATTORNEY Title:
Reg. No.: 32800 Reg. No.:
Address; 500_.EA5T_SHLRD.ST Address; — }
LOVELAND, CO 80537
Telephone; _570-562-2542 Telephone^ `�
eTt
tobe
Signature Signature
11 cRCL')5/---Q6G
JAN-07-2005 FRI 01:31 PM FAX NO. P. 04
' OCT-15-2004 FRI 11:08 AM FM NO. P. 02
Lorimer County,Colorado: W d County,Colorado:
Name: N e:
Title: �' T; .
Add s• A reels•
QL O I l
Telephone:7r' - 4/9 '— J Ted i bone:
gnature Signature
Approved as to Form: A lied as to Form:
Name: N e'
Title: Ti e:
Reg.No.: a rSl° _ R No.:
Address; 915 t : a41 q 4 f7• A :
1,(f (n VS;2.
Telephone: q 4 7 O T epbene:
Signature Signature
City of Loveland,Colorado: L land Chamber of Commerce:
Name: N ha;
Title: Ti e:'
Address: I — A dross:
Telephone: T Cpl one:
Signature • I Signature
Approved as to Form: A proved as to Form;
Name: N
Title: T 1e:c
Reg.No.: R g.No.:
Address: A dress:
Telephone: T fephone:
Signature Signature
tt
JAN-07-2005 FRI 01 :31 PM FAX NO. P. 06
OCT-07-2004 THU 02:31 PM FT COLLINS CITY ATTORNEY FAX NO. 9702216327 P. 02
City of Greeley,Colorado: Town of Windsor,Colorado:
Name Name:
Tills: Title:
Address: Address:
Telephone; Telephone:
Signature -Signature
Approved as to Form: Approved As to Form;
Name: Name: _
Title: Title;
Reg,No,: Reg.No,: ---
Address: Address:
Telephone: Telephone:
• Signature Signature
Windsor Chamber of Commerce: City of Fort Collins,Colorado:
Name: Name; Darin A. Attebury
Title: Title: City Mana9ar
Address: A resg Dfl Porte"!YC enuc
_ Fort Collins, olora 080521
Telephone: 'telephone: 970 221 05
0..r
Signature Signature
Approved as to Fenn: Approved as to Form:
None: Name: Kral a F.cton
Title: Title: Assistant City Attorney
Reg.No.: Reg.No.: 20706
Address: Address: 900 LaPorte Avenue
__. Part'CotXIni';'22f"87352]
Telephone: Telephone: _.._
--_w Signature FP Signature
12
JAN-07-2005 FRI 01:31 PM FAX N0. P, 07
09/14/2804 15:42 9784991210 FI044 PAGE 92/02
01/14/2004 10'50 FAA win eA$ ?IRO loin OF IINDIOR
City of Greeley.Coloradot Ten of Windsor,Colorado:
Name: Nano: sotda�ed L
Title: Tide: MA4e
Address: Address: _ 3D/ t 4uAres—.Sr
Telephone: Telephone: 9
41a 12�o
Signature
Approved as to Fenn: Approved as to Fenn: r
Name: J 0 Id M `I7- rR 4-
Name: a a.
Title: r-' 1
Reg.No.: Reg.No.: OO
Address: 3l t Colas aP
Address: Foitr ate-bus, Cu 29(4 4 /
r
Telephone: Td�pbyge: 6
Signature /!/�/"JJ Sl
Wtndaor Chamber of Commerce; City ofFert Collins,Colorado;
Name: Name
Tide: Title;MINIP
Address: Address:
Telephone: Telephone:
Syaa Sipatme
Approved as to Fenn: Approved as to Fonn:
Names_ Name:Title; Title:
Rey,.No.: Reg,No.:_
Address: Address:
Telephone: Telephone
Signature Signature
12
JAN-07-2005 FRI 01:32 PM FAX NO, P. 08
09/20/2004 YON 12:59 FAX ItiO2/003
City of Greeley,Colorado: Town of Windsor,Colorado:
Name: • Name:
Titlo: Title;
Address: Address:
Telephone: —+ Telephone:
c-. ;teal LnA Coley of Greeley
attestant paiignature Signature
Approved as to Form: Approved as to Form:
Name: Name:
,Title: Title:
Reg.No.: Reg.No.:
Address: Address:
Telephone: Telephone:
Signature Signature
Windsor Chamber of Commerce: City of Fort Collins,Colorado:
Name; Name;
Title: • Title:
Address: Address:
Telephone: Telephone: •
Signature Signature
Approved as to Form: Approved as to Form:
Name: Name: _
Titles Title:
Reg.No.: Reg.No.:
Address: Address:
Telephone: Telephone:
Signature Signature
12
JAN-07-2005 FRI 01:32 PM FAX NO. P. 09
In the Matter of the Joint Application to Expand the Local Calling Area in Northern Colorado
City of Greeley,Colorado Signature Page
IN WITNESS WHEREOF, the parties hereto have executed this Partial Stipulation and
Partial Settlement Agreement the day and year first hereinabove written.
ATTEST: THE CITY OF GREELEY,COLORADO
By: es t n-,c,c- L
City ClcrktN Mayor
APPROVED AS TO SUBSTANCE: APPROVED AS TO I, . FORM:
/V /
By:
City Manager City A m
AVAILABILITY OF FUNDS:
By:
tractor of Fina
JAN-07-2005 FRI 01:32 PM FAX NO. P. 10
'1-°m-Seo.15. 2004 2:26PM Town of Ault No.9811 P. 2
alga A
Docket No.01Ad967
ONadaa Na a04-10704
Sepat &I,21104
Pate IS OM
Fort Collins Chamber of Commerce: Town of Anit,Colorado:
Name: Name: vaFtla..4 rid,
Title: Title: /1tMdV
Address- Address: lts f t,-c+.
Telephoner Telephone 97O IA/ 2I '
i
•
Signature Signature i
.i
Approved as to Form: Approved as to Form:
Name: _ Name: R . Gel:Ari/ A",Erb, '
Title: _ Title: T.,,,,,, AillerNe
ReE.Add Nio Reg,No.: Se 73. Y I:
. Address: Ai 40s ,3314 SS
Telephone: Tel hone: n..i4.7 „. e. .Fe613
(0701 333— KSc8
i
/�
Signature 1
• _ 1'
Town ofTimnath,Colorado: Town of LaSalle,Colorado:
Name: Name:
Title: —_ Title:
Addresc- • Address:
Telephone- _ • Telephone: l
Signature Signature i
Approved as to Form: Approved as to Form:
4
Name: y
N21218;
Title: (j
Title: ,
Reg.No.: Reg.No.: l._
Address: iI
Address: r'
•
Telephone: Telephone. •
•
Signature Signature
i
13 i
JAN-07-2005 FRI 01 :32 PM FAX NO. P. 11
ne/Soo.28:, 2004348:39AMe3526sa7
W H & H LLC No.2881 PM= 02/82
Fort Collins Chamber of Commerce Town of Ault,Colorado:
Name: Name:
Tide: Titir.
Address: Address:
Telephone: Telephone:
Signature Signature
Approved as to Form: Approved as to Form:
Names Name:
Title: Title; _
Bog.No.: _ Reg,No,:
Address: Address:
Telephone: Telephone:
•
Signature Signature
Ton of Timnath,Colorado: Town of LaSalle,Colorado:
Name: Name: - ' t 1►Z E ✓A
Title: Title: rri A r d rt..
Address: Address: I d t alp a -sr
Telephone: Telephone; n) a S!-,tr 9'?/
T /�J 11
Signature Signature
Approved as to Fong: Approved as to Foim:
Name: Name: l C
Title: Title: o
Reg,No.: Reg.No.: 1 f
Address: Address: t i(of
U.
Telephone: Telephone; "•7 e• 3S f
Signature SiBosduc
13
JAN-07-2005 FRI 01 :32 PM FAX NO. P. 12
09/29/2004 15:36 9705350031 TOWN OF MEAD PAGE 52
SEP-29-2004 NED 01:10 PM FAX NO. P. 02
1 • It:Aio�,
I
ae f paport,leg 1AOM 070,
Peso MOM
I
Town of Kersey,Colorado: TowA of Mead,Colorado:
Name: Name:/' L 0, Flow...;
Title: Title: Yount: /t,
Address: Address: P. O. t h 6
Juetc o ras'E2
Telephone: Telephone: 970 cat- V4077
Signature Signature
Approved as to Form: Approved as to Perm: .
Natno: Name: h/a
Title: T Title:
Reg.No.: Rog.No.:
Address: • Address:
—
Telephone: _ Telephone:
Signature Signature
Town of Nano,Colorado: City of Evans,Colorado:
Name:— Name:
Tale: Title:
Address: Address:.
Telephone: Telephone: •
Signature Signature
Approved as to Form: Approved as to Form:
Name: Nemo:
Title; Title:
Reg,No Rot No.:
Address: Addross:
Telephone: „ Telephone:
•
Signature Signature•
14
JAN-07-2005 FRI 01 :33 PM FAX Na P. 13
' Sop 30 04 03:02p TOWN OF KERSEY (9701352-2197 p_ 1
SEP-30-04 THU 1426 WILth N K SWTHARD, ATV ml '"' ^'^ 7t7 tine P 111
Pos��t4r Fax Note 7671 0aI cegac/pc/ Imo► / -
T°!p eye &Attlee F"°'" Lrnnede.oo.sc000- Q°106 PP•
Phmet }PMn.WO'--35d-/GP/
T wa of Kaxey)(Vandal To, ru r9�v 9� a9oD "� "
Nam:Sey M Name:
Tide: Title: -
Address: Address;.
Tdcphonec DJ • Telephone;
Signature
proved sii to Porro � (/ Approved is to Form:
„,..S.Name: _Uon F ,6 Name
Title; d etkeyTille:
tee.No.; Ref No.:
Mesas: ,i ON 6.3E4 Address:
Or-t--‘0." (o go 3+ . _
'Telephone: .912±714 c C.- (.1 4.7? Telephone:
Sienat}uc Siietgnue
Town er Nan,Colorado; cloy or Event,Colorado: .
Name: �_ . — Nsmc: . _
Title; Title:
Address: _._— Address:.
Telephone; - _ Teephone: —
Slgesiere Siptanra
Approved as to Ponw Approved as to Form;
Name: Name:
Tittc: _ Title:
Reg.No:- Reg.He.:
Address: Addreu:
Telephone: Telephone:
--.._ ^Sigutore IL Signature
14
2.4 1.612-ccetottl1 A3Stl9M d0 r1R01 d5pIxn Do ea dot;
JAN-07-2005 FRI 01 :33 PM FAX NO. P. 14
Town of Kersey, Colorado: Town of Mead,Colorado:
Name: Name: _ T
Title: Title:
Address: Address:
Telephone: _ Telephone:
Signature Signature
Approved as to Form: Approved as to Form:
Name: • Name:
Title: Title:
Rcg.No.: Reg. No.:
Address: _.. .._.,.._ Address:
Telephone: Telephone:
Signature Signature
Town of Nunn,Colorado: City of Evans,Colorado:
Name: Name: fA I- ,valt:1 tt1t sb<✓r�,
Title: _ Title: i1\Ckp
Address: Address: o 31 St
u n 5 CO t&X,do
Telephone: - - 1' one: _ -ii
Signature Signature P4(441._
Approved as to Form: Approved as to Form:
Name: Name; _ m
Title: Title: o, t
Reg.No.: Reg.No.:err)
._...
Address: Address: O s jt,irj5
_ e e Ic& Co %U,',''
Telephone: --. Telephone: • 10• 53-S5o`3
Signature Signature
14
_JAN-07-2005 FRI 01:33 PM FAX NO. P. 15
08/31/2004 10:06 970-454-3339 TOWN OF EATON PAGE 02/02
Rug 31 2004 6: 14A0 HP LASERJET 3330 p.2
Town of Eaton,Colorado: Town of Etas Park,Colorado:
Name: Cat y Cars re n, Name:
Title: Irv-., ria....e aft
Address: 7 Z 3 1 rr S7r..a r Addren:
F4T0., Co nets
' ° ster Telephone:
Signature Signature
Approved as to Form: Approved as to Porn
Name: R. anssalj Anson Name:
Title: Town Attorney Title:
Reg.No.: 5672 Reg.No.:
Address: P. 0. Box 336155 Address;
Sreeley. Cp_80633
Telephone; 970-3 3-5506 Telephone:
Town of MilUken,Colorado: Town of Platteville,Colorado:
Name: Name:
Title: Title: -
Address: mss: - •
Telephone: Telephone:
Signature Signature
Approved as to Form: Approved as to Form:
Name: Name:
Thle: Title:
Reg,No.: R.eg,No,:
Address: Address:
Telephone: •
Telephone:
Signature Signature
Is
JAN-07-2005 FRI 01 :33 PM FAX NO. P. 16
09/27/2004 14:31 9705872678 MILLIKEN PAGE 01
Town of Eaton,Colorado; Town of Estes Park,Colorado:
Name:
Title: Name:
Address:
Address:
Telephone:
Telephone:
Signature Signature
Approved as to Form Approved as to Form:
Name: Name:
Title: Title:
• Reg,No,: Reg.No.:
Address; Address:
Telephone: Telephone:
Signature Signature
Town of Million, Colorado: Town of Platteville,Colorado;
Name: ` 4�S1n4A Mune:
Title: Title:
Address; a Address:
Telephone, Telephone:
Signature Signature
Approved as to Form;
Approved as to Form:
Name: Name:
Title: Title:
Reg,No.:
Red.No::
Address:
Address:
Telephone: Telephone:
Signature Signature
rs
Aug 30 04 01 : 50p Gregory A White 9706672527 p. 2
Aug 30 2004 H_40AM HP LASERJET FAX p. 1
Town of Eaton,Colorado: 'Town of Estes Park, Colorado:
Name: Name: jayN B,ovot--4
Title: Title: #lAYo/C.
Address: Address: ,4o lint /100
flies Aserri th Fos'/7
Telephone: Telephone: 970--577 -37o4
Signature Signature
Approved as to Form: Approved as to Fong:
Name: Name: (..T-
Title: Title: Thuu... IA- t1-e vv, t�
Reg.No.: Reg. No.: r3 Ll D
Address: • Address: 1 { L2 W, 2- et .11"-
Le..LU u... t �aLA 11- (r
Telephone: Telephone: 0
Signature Signature
Town of Milliken,Colorado: Town of Platteville, Colorado:
Name: Name:
Title: Title:
Address: Address:
Telephone: Telephone:
Signature Signature
Approved as to Form: Approved as to Form:
Name: Name:
Title: Title:
Reg.No.: Reg.No.:
Address:- Address:
Telephone: Telephone:
Signature Signature
15
JAN-07-2005 FRI 01 :34 PM FAX NO. P. 18
Town of Berthoud,Colorado: Town of Johnstown, Colorado:
Naane: 'hLag. kW-speck Name:
_ _.
Title: _Mayor o r r Title:
Address: =, La MassaeNorc:v 4 ye_. Address: .
Po 3.x Izty BcwrIevyti. Co
Telephone: (et 7o)S3a-24 Sc3 goS/3 Telephone:
SignattuIee Signature
Approved as to Form: Approved as to Fomv
Name: ) ) ���e_ Name:
I� r
Title: .J{.:.:i.:iw? ,t Y Title:
Reg. No.: Ce S,_ Reg.No.:
Address: et C J IS 017T, Address:
T )≥ 17ne'url CC' Res 3 _.
elephone: 9'7 6 •-.54,4Z Telephone:
c
Signature Signature
16
JAN-07-2005 FRI 01:34 PM FAX NO. P. 19
CERTIFICATE OF SERVICE,:
This is to certify that I have duly served the within MOTION TO SUBMIT
ADDITIONAL APPLICANT SIGNATURES TO TI1E PARTIAL STIPULATION
AND PARTIA L SETTLEMENT AGREEMENT upon all parties herein by depositing
copies of the same in the United States mail, first class postage prepaid, at Loveland,
Colorado this 20th day of October,2004,addressed as follows:
Andrew 13. Claus,Esq.
Winslow B. Waxier, Esq. G.Harris Adams
David W. McGann, Esq. Assistant Attorney General
Qwest Corporation Office of the Attorney General
1005 17°i Street, Suite#200 1525 Sherman Street, 5th Floor
Denver, CO 80202 Denver, CO 80203
Nunn Telephone Company Pat Parker
P.O.Box 249 Office of Consumer Council
Nunn, CO 80648 1580 Logan Street, Suite 740
Denver,CO 80203
Barry L. Mort, Esq.
P.O. Box 300 P.B. Schechter
Littleton, CO 80160 Office of Consumer Council
1580 Logan Street, Suite 740
David P, Ayraud, Esq. Denver, CO 80203
Assistant County Attorney
P.O. Box 1606 Anne K. Botterud
Fort Collins, CO 80522 Assistant Attorney General
Office of the Attorney General
County of I arimer 1525 Sherman Street, 5th Floor
Torn Bender,Commission Chair Denver,CO 80203
P.O. Box 1190
Fort Collins, CO 80522 Gary Klug
Public Utilities Commission
City of Evans 1580 Logan Street,OL-2
1100 37th Street Denver,CO 80203
Evans, CO 80620
Sharon Podein
City of Fort Collins Public Utilities Commission
300 Laporte Avenue, Floor 2 1580 Logan Street, OL-2
Fort Collins, CO 80522 Denver, CO 80203
City of Greeley Becky Quintana
1000 10th Street Advisory Staff
Greeley, CO 80631 Public Utilities Commission
1580 Logan Street, OL-2
Denver,CO 80203
JAN-07-2005 FRI 01 :34 PM FAX NO. P. 20
County of Weld Mike Zimmerman
David E. Long, Commission Chair Advisory Staff
915 10th Street Public Utilities Commission
Greeley,CO 80632 1580 Logan Street, OIr2
Denver, CO 80203
Town of Ault
Sharon Sullivan,Town Clerk/Treasurer Town of Eaton
201 First Street Gary Carsten, Town Administrator
Ault, CO 80610 223 First Street
Eaton, CO 80615
Town of Berthoud
P.O. Box 1129 Town of Gilcrest
Berthoud, CO 80513-2229 Paul Chacon,Mayor
204 8`h Street,Box 128
Town of Estes Park Gilcrest, CO 80623
Join Baudck, Mayor
P.O. 13ox 1200 Town of Kersey
Estes Park,CO 80517 Timothy J.Phippard,Mayor
332 Third Street
Town of Johnstown Kersey, CO 80644
Troy Mellon,Mayor
Box 609 Town of Mead
Johnstown, CO 80534 Richard E. Kraemer,Mayor
441 Third Street
Town of LaSalle Mead, CO 80542
Tim Evans,Mayor
128 North Second Street Town of Nunn
LaSalle, CO 80645 Duane Bayne, Mayor
185 Lincoln Avenue
Town of Milliken Nunn, CO 80648
P.O. Box 290
Milliken, CO 80543 Town of Timnath
Annalee Foster,Mayor
Town of Platteville 4100 Main Street
Nicholas J.Meier,Town Administrator Timnath,CO 80547
400 Grand Avenue
Platteville, CO 80651
Town of Windsor
Board of Trustees
301 Walnut Street
Windsor, CO 80550
JAN.07'2005 13:04 #1951 K.002/006
boelcuN0.0JM96T
hake No.W(-10701
•
hoes 42004
Are 100f09
STIPULATED AND AGREED UPON•this 30th day of August,2004.
•
Staff of the Commission: Office of Consumer Counsel:
Geraldine G.Santos-Rath Patricia A.Parker
Chief of Fixed Utilities Rate Financial Analyst
1580 Logan St,OLi 1580 Logan St;OL7
Denver,CO 80203 Denver,CO 80203
303.894.2533 303.894.2126 •
Approved as to En Approved aai to Penn:
Anne K.Bottom! G.Harris Adams
Reg.No:20726 Reg.No. 19668
Office of the Attorney General Office of the Attornv General
1525 Sherman Street,7m Floor • 1525 Sherman St,5 Floor
Denver,CO 80203 Denver,CO 80203
303.866.38676..33867 3032663441
03a
Nunn Telephone Company: Qwest Corporation; •
•
Name: Paul R.McDaniel •
Tide: Assistant Vice President for Regulatory Affairs
P.O.Box 249 Denver,CO 80202
Nunn,CO 80648-0249 303.896.4552
Approved as to form: Approved as to Form:
Barry L.Hjort David W.McGann
Reg.No. 19551 Reg.No.34521
P.O.Box 300 100517th St, Suite 200
Littleton,Co. 80160 Denver,CO 80202
. • 303.795.8080 303296.3892
•
•
•
20
JAN.07'2005 13:04 #1857 P.003/006
stitS A
• Docket No.03M96T
• Decedem Nw R0r-1070.1
•
September I,2004
• Pagel'Of39
STIPULATE)AND AGREED UPON this 30i°day of August,2004.
•
Staff of the Commission: Office of Consumer Counsel:
. God Santos-Rack Kenneth V.Reif,Director
Chief of Fixed Utilities Office of Consumer Counsel
1580 Logan St.,O12 1580 Logan St.,OL7
Denver,CO 80203 Denver,CO 80203
303.8942533 303. 12� •
•
•
Approved as to Form: Approved as to Form:
Anne X.Botterud O.Harris Adams
Reg.No.20126 Reg.No: 19668
Office of the Attorney General, Office of the Attorney General
1525 Sherman Street,7e°Floor 1525 Sherman St.,56 Floor
Denver,CO 80203 Denver, CO 80203
303.8663867 303.866.5441
Nana Telephone Company:,
Name:
True:
P.O.Box 249
Nunn,CO 80648-0249
•
Approved as to form:
Barry L.Hjort
Reg. No. 19551
P.O.Box 300
. Littleton,CO 80160 - .
303.795.8080
•
•
19
JAN.0712005 13:04 #1857 P.004/006
$/30/_tla i 12t 54 9TOB97272T NUM 1E1E3'!�E CO Decision1 200$.070-1
• Ot3 •
•
•
STIPULATE)AND AGREED UPONthis 306 day of August,2004.
Staff of tlri Centeinton- • Office crCensamer Counsel:
Geri Samos-Ram Patricia A.Parker
Chief of.Fused UtiiiOies
1580 Lope St,O .a 1 Logan Sl Analyst
Denver.CO 80203 1580 CO 8O2 3
• 301894.2533 Dotter, 80203
303.894.2126
•
Approved as to Fenn: . Approved as to Penn:
Anne K Boated ' ' G Fes:Adams
Reg.No.20726 Rey.No.19668 •
Office ed'the Attorney General Office of the Auorn
g General
]525 Sherman Stmt,76 Floor 1525 Sherman St., rThor
Denver,CO 80203 Darvcr, CO 80203
303.866.3867 3O3.866.5414
Nunn Tdeph Po -
•
•
•
Side• .
P.O.Hot 249
Nunn,CO 80648.0249 •
:17
A.pprtrear fig
Bury L.*ft
Reg No. 19551
P.O.Bolt 300
Littleton.CO 80160
303.795.8080
•
10
JAN.07'2005 13:04 #1857 P.005/006
AUG-30-2004 NON 10:35 AN FAX NO. Bah A
Docket ,03k,
967
t+.e61oals au.-io7at
spnma.;moe
• Page noes
Latimer County,Colorado Weld County,Colorado:
Namo: - Nemo:
Title: Title: •
Address: Address:
• Telephone: — Telephone: •
I .
Signature Signature
Approved as to Irons: Approved as to Perm:
Name: _ Name:
Title:' • Title:
Reg.No.: Reg.No.:
Address: Address:
Telephone: Telephone:
Signature Signature
City of Loveland,Colorado: Loveland Chamber of Commerce:
Name: DON F. .4ILLIA$S Name: . •
Title; city NAJ1AGER —T Title: •
Address: 50D EAST THIRD ST. Address:
LOVELAND. CO 80531
Telephone: 970-962-230¢__, Telephone:
•
Signature Signature
Approved as to Form: Approved as to Poem:
Name: _%MO c IT Name:
Title: ASSISTANT CITY ATTORNEY Title:
• Reg.No.: 32800 Reg.No.:
Address: sgp_Edst_tiito sr Address: •
_ LOVELAND, Co 80537
Telephone; rJ0-962;3.542 Telephone:
Signature Signature •
JAN.07'2005 13:04 #1857 P.006/006
EkkiWt A
Flug 30 04 D1s50, Gregory Fl White 9709672527 Dal 144.0JAd96T
• DecaiaNa R04.14704
Rug 30 2004 9:4pnM HP IRSERJET FR% Sep,Nnbere,2004
•• Pass 17 er19 •
•
Town of Satoa,Cnkrado: Town oflatw Park,Colorado:
Nemec • Na4 a ig_aeraten
Tide: Tide ati
: a Address: Act Cole /moo
EAf_.4e i to "S17
Telephone: • Talepboun lat.-sr, -Tha_d' •/at• Signature
•
Approved as to Paint Approved es to For •
•
• Nssne Neon Cr-.,, c
Tlas Title: 44 rw t3/4)
Reg.No.: • Rag No.: r^3 't n J
• Address: Addresi:, i q irs? r✓- 19
•
Telephone: _ •• Telephone;
. S12netoro *alma
•
L• •
Town of Colorado: Town of Platteville,Colendo
Name: • Nome:
Title: Title '
Address: Addicts
•
Telephone: Telephone:
Signature Sigaetmt
' Approved as to Poe= .Approved as to Pont:
- Nome ' Nan
Title • Title:• .
Rog.Na: Ref,No.:
Adelman. • Address:
•
Telephone: Telephone:
•
`. . Sipaaue Signature•
. •e.
•
A
BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF COLORADO
Docket No. 03A-496T
IN THE MATTER OF THE JOINT APPLICATION TO EXPAND THE LOCAL
CALLING AREA IN NORTHERN COLORADO
UNOPPOSED JOINT MOTION TO APPROVE PARTIAL STIPULATION AND
PARTIAL SETTLEMENT AGREEMENT OF THE PARTIES AND REQUEST FOR
WAIVER OF RESPONSE TIME
Pursuant to Rule 22 of the Commission's Rules of Practice and Procedure,
Nunn Telephone Company ("Nunn"), the Staff of the Public Utilities Commission of
the State of Colorado ("Staff'), the Office of Consumer Counsel ("OCC"), and the
City of Loveland, Colorado ("Loveland"), (collectively referred to as "Joint
Movants"), through their undersigned attorneys, respectfully request that the
Commission issue an order approving the "Partial Stipulation and Partial Settlement
Agreement of the Parties" ("Partial Stipulation"), filed contemporaneously herewith
in this docket, which resolves specific issues in this proceeding.
In general, the Joint Movants have resolved the issue in this docket as to
whether the Applicants have demonstrated clear and convincing evidence of a
community of interest under the alternative criteria for the community of interest
standard set forth in 4 C.C.R. 723-2-17.3.3.2. However, all other issues not
specifically addressed in the Partial Stipulation are reserved and will be addressed at
hearing.
By this Partial Stipulation, the Joint Movants are attempting to streamline the
hearing by avoiding presentation of testimony from as many as twenty-two applicants
on an undisputed issue. Thus, Joint Movants request the Commission's approval of
the Partial Stipulation to give all parties certainty in preparing pre-filed testimony.
Qwest, though not a party to the Partial Stipulation, participated in the drafting
and negotiation of the stipulation entered into by the Joint Movants. The undersigned
counsel for Joint Movants are authorized to represent that Qwest does not object to
the Commission's approval of the Partial Stipulation. Accordingly, as no party
opposes this Motion, it is appropriate that response time hereto be waived so that the
Commission may consider this request at its earliest convenience.
Counsel for Staff has reviewed this motion and has authorized the undersigned
counsel for the OCC to execute it on Staffs behalf.
WHEREAS, for good cause shown, the Joint Movants respectfully request that
the Commission issue an order approving the Stipulation filed contemporaneously
herewith. As no party opposes this Joint Motion, the Joint Movants further request
r IIVV JV LVVT IIVII LV'JJ 1111 I llll "Vi Ii VL
that response time hereto be waived.
Respectfully submitted this 30'h day of August, 2004.
KEN SALAZAR KEN SALAZAR,
ATTORNEY GENERAL ATTORNEY GENERAL
Nc
is dams, No. 19668 ....__._.." BY: C (�J`S �
BY: ,J
G. IfarrAnne K. Botterud, 20726* tea
Assistant Attorney General Assistant Attorney General
Office of the Attorney General Business and Licensing Section
1525 Sherman Street, 5th Floor 1525 Sherman Street, 7th Floor
Denver, Colorado 80203 Denver, Colorado 80203
(303) 86G-5441 Telephone: (303) 866-3867
(303) 866.5342 (Fax) Facsimile: (303) 866-5395
anne.botterucl@state.co.0 s
ATTORNEYS FOR THE COLORADO COUNSEL FOR STAFF OF THE
OFFICE OF CONSUMER COUNSEL PUBLIC UTILITIES COMMISSION
*Counsel of Record
NUNN TELEPHONE COMPANY: CITY OF LOVELAND, COLORADO
BY: _ BY: Qt4fiaLl• elCGfil
Barry L. Hjort, #19551 Sharon L. Citino, #32800
P.O. Box 300 City Attorney's Office
Littleton, CO 80160 500 East Third Street
303-795-8080 Loveland, CO 80537
rollsroyal@aol.com 970.962.2540
CitinS@ci.loveland.co.us
ATTORNEY FOR NUNN ATTORNEY FOR THE
TELE3PIION.E COMPANY CITY OF LOVELAND, COLORADO
that response time hereto be waived.
Respectfully submitted this 30th day of August, 2004.
KEN SALAZAR KEN SALAZAR,
ATTORNEY GENERAL ATTORNEY GENERAL
BY: BY:
G. Harris Adams, No. 19668 Anne K. Botterud, 20726*
Assistant Attorney General Assistant Attorney General
Office of the Attorney General Business and Licensing Section
1525 Sherman Street, 5th Floor 1525 Sherman Street, 7th Floor
Denver, Colorado 80203 Denver, Colorado 80203
(303) 866-5441 Telephone: (303) 866-3867
(303) 866-5342 (Fax) Facsimile: (303) 866-5395
anne.botterud@state.co.us
ATTORNEYS FOR THE COLORADO COUNSEL FOR STAFF OF THE
OFFICE OF CONSUMER COUNSEL PUBLIC UTILITIES COMMISSION
*Counsel of Record
NUNN TELEPHONE COMPANY: CITY OF LOVELAND, COLORADO
B • BY:
Barry L. Hjort 9551 Sharon L. Citino, #32800
P.O. Box 300 City Attorney's Office
Littleton, CO 80160 500 East Third Street
303-795-8080 Loveland, CO 80537
rollsroyal@aol_com 970.962.2540
CitinS@ci.loveland.co.us
ATTORNEY FOR NUNN ATTORNEY FOR THE
TELEPHONE COMPANY CITY OF LOVELAND, COLORADO
Attachment A
- t -lip
ciColorado s , �`�''
Telecommunications . , ,f r4
Association
"Companies Connecting Colorado"
May 12, 2004
G. Harris Adams, J.D., C.P.A
Assistant Attorney General
Office of the Attorney General
1525 Sherman Street, 5th Floor
Denver, CO 80203
Anne K. Botterud, Esq.
Assistant Attorney General
Office of the Attorney General
1525 Sherman Street, 5th Floor
Denver, CO 80203
Re: Docket No. 03A-496T: Nunn
Dear Harris& Anne:
As I indicated I would do in our recent meeting concerning several of the pending
issues involved in the proposed Northern Colorado Calling Area expansion
docket, I am providing the following information concerning Nunn Telephone
Company's intentions with respect to the calling plan(s) it intends to offer in the
event that the COPUC approves the proposed expansion. You will recall that our
discussion in this regard focused on your requests for specific information as to
Nunn's intentions and Nunn's request that the Staff Report to the Commission
incorporate a proposed waiver of Commission Rule 723-2-17.3.6 which requires
that a statistically valid survey be conducted by each local exchange provider
whose customers will be affected by any proposed expansion.
If the proposed calling area expansion affecting Nunn is approved, Nunn intends
to offer its customers the option to elect an unlimited, flat rate calling plan for
local calling into the expanded calling area for a flat rate of$11.25 per month.
which amount will be in addition to the Nunn current basic residential service rate
of$20.56 per month or in addition to the current basic business service rate of
$30.8o per monti-,. The current residential and business basic service rates wil.
not change for those customers who do not elect to take the optional calling nth.:
EXHIB'-
-, ' : _^_at- -^_an. .S 4. ._
30. : ..r•^.rn • 30: 791..1:4;f3 (Far_ • 30' 55u 4771. („eI?) 1 {
- r t n,': `@ ao?.c',r^ .CO1,- i L_CC'
For those Nunn customers who do not take the optional calling plan, calling by
such customers who make calls into the expanded local calling area will be billed
at the rate of$.11 per minute. Nunn is also considering making a concurrent tariff
filing that would provide its customers who do not elect the optional calling plan
with a blocking option that would permit its customers to avoid the imposition of
toll charges for calls which they might otherwise believe to be local into the
expanded calling area. (This proposal would likely be very similar to the
blocking option that Strasburg Telephone Company has provided to its
customers.)
Nunn is aware that the Commission's rules require that expanded calling be
established on a"two-way" basis. Thus once C0PUC approval is granted for the
calling area expansion, calls made by subscribers located outside the Nunn service
area, but inside the expanded local calling area to Nunn's customers will be made
as local, toll-free calls.
I have not included detail here concerning the access charge loss and other costs
that Nunn will incur as a consequence of the proposed calling area expansion. If
you have questions in that regard, or require additional detail —I suggest that you
contact Nunn's consultant: Kevin Kelly at 719.266.4334.
It is my understanding that the above information meets your needs, and that as a
result Staff will recommend waiver of the customer survey requirement for Nunn
in its Report to the COPUC. If you have additional questions, please contact me.
Very truly yours,
!/ Barry L. Ff
cc Greg Grablander, Nunn Telephone
Kevin Kelly, TCA
Gary Klug, COPUC
Pat Parker, 0CC
Attachment B
APPLICATION TO THE PUBLIC UTILITIES COMMISSION FOR THE
PURPOSE OF EXPANDING THE LOCAL CALLING AREA
xecutive Summary
This application is a joint Northern Colorado filing for expansion of the local calling
area. We would like two-way calling between each of the communities listed in the
current calling area and the proposed calling area listed in the attached exhibit (Exhibit
Table to Clarify Calling Area Expansion Request). The application is based on the
alternate criteria standards for the community of interest. The communities in support of
the application have attached letters. The letters indicate that there is substantial support
for this effort. The county letters have a majority of the county commissioner signatures,
as required.
The current calling area for Loveland includes the following exchange areas: Fort
Collins, Estes Park, Loveland, Berthoud, and Johnstown-Milliken. This application is a
request to add the following exchange areas: Windsor; Eaton-Ault; Greeley; Lasalle;
Evans; Platteville; and northern exchange area dissected by Highway 85 (area bordered
by the northern state line, the Fort Collins exchange area on the west, the Eaton-Ault
exchange area on the east and the Windsor exchange area on the south). A map has been
included in the attached material.
Residents and businesses in Northern Colorado truly support a regional economy in every
aspect of their lives. Evidence of the interdependence of the business centers in the
Northern Colorado region has been found to exist in every segment of the economy.
> Growth management areas for Northern Colorado communities are
contiguous.
• There is substantial travel between r '
h} _j
three main business centers for U 111- Regional Travel Patterns
both employment and shopping. ' -
1
> Short distances, short travel times, '1 Ilr w�
accessible roadways, and moderate
'll .aii»n.travel traffic volumes between
business centers in Northern • = ^ =<. tvFB�
Colorado are factors that +__f ° ., ', �_
perpetuate interdependence.
Source:Nor-th Front Range Metropolitan Planning Organization
> Businesses are buying local. 45% inputs used by primary employers to
generate goods and services are purchased from local businesses in the
region.
> The regional North Front Range Transportation & Air Quality Planning
Council exists due to regional cooperation of the communities in Northern
Summary - 1
xecunve Summar-
oiorado, particularly related to transportation initiatives.
Regional economic development organizations exist because of the
salability of the regional concept for recruiting businesses.
> Utility providers have a dependence upon resources and customers
throughout the region.
> Two major hospital systems (locations in Greeley, Loveland, and Fort
Collins)provide services for patients throughout the region and are major
employers in the region.
> Educational entities serve overlapping county areas for kindergarten
through 12`h grade. Windsor residents that attend Thompson Valley
(Loveland) schools.
> Universities and community colleges serve the entire region. These
institutions are serving a role in continuing education for the businesses in
the area and are amongst the largest employers in the region.
• > Non-profit agencies, Larimer and Weld counties work together to address
human service needs of the region, as well as support the strong
agricultural business segment of the region through extension services.
> Regional leisure destinations attract users from the entire region providing
a well-rounded, higher quality of life.
It is understood that there could be an incremental increase to the monthly bill for each
customer throughout the calling area based on infrastructure costs to make the expansion
possible. It is our hope that given the number of customers included in the proposed area
each customer's proportional share would be very small. We believe the elimination of
monthly cost of long distance between the exchanges included in the application and the
cost of service alternatives to avoid long distance calls would substantially reduce
monthly financial obligations of businesses and residents in our region. It is our hope
that the Public Utilities Commission will see the value of the body of evidence that has
been submitted to establish a community of interest.
Summary- 2
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�x;affair Table to Clarify calling Area Expansion Request - Exhibit
::change Current Calling Areas Proposed Calling Areas (Extension)
3er.;roud !Eaton-Ault, Estes, Ft. Collins, La Salle. Nunn Tele.
Gilcrest, Greeley, Johnstown-
Milliken, Longmont, Loveland,
Mead, Platteville, Windsor
Eaton-Ault Berthoud, Gilcrest, Greeley, Estes Park, Ft. Collins, Loveland
Johnstown-Milliken, LaSalle,
Platteville, Windsor, Nunn wire
center, Briggsdale & Grover wire
centers of Wiggins.
Estes Park Allenspark, Berthoud, Ft. Collins, Eaton-Ault, Gilcrest, Greeley, Johnstown-
Loveland, Lyons Milliken, La Salle, Platteville, Windsor,
Nunn Tele.
Fort Collins Berthoud, Estes Park, Loveland, Eaton-Ault, Gilcrest, Greeley, Johnstown-
(Harmony& Windsor,Nunn wire center(Nunn Milliken, La Salle, Platteville,
Wellington) Tele.), Red Feathers &Walden
wire centers (CenturyTel)
Gilcrest Berthoud, Eaton-Ault, Greeley, Estes Park, Ft. Collins, Loveland, Nunn
Johnstown-Milliken, La Salle, Tele.
Mead, Platteville, Windsor
Greeley(Evans) Berthoud, Eaton-Ault, Gilcrest, Estes Park, Ft. Collins, Loveland
Hudson,Johnstown-Milliken,
Keenesburg,La Salle, Mead,
Platteville,Weldona, Windsor,
Roggen wire center, Nunn wire
center, Briggsdale, Grover, Hoyt,
New Raymer&Wiggins wire
centers of Wiggins, Stoneham wire
center.
Johnstown- Berthoud, Eaton-Ault, Gilcrest, Estes Park, Ft. Collins, Nunn Tele.
Milliken Greeley, LaSalle, Loveland, Mead,
Platteville, Windsor
La Salle Eaton-Ault, Gilcrest, Greeley, Berthoud, Estes Park, Ft. Collins, Loveland,
Hudson, Johnstown-Milliken, Nunn Tele.
Keenesburg,Mead, Platteville,
Windsor
Loveland Berthoud, Estes Park, Ft. Collins, Eaton-Ault, Gilcrest, Greeley, La Salle,
Johnstown-Milliken, Mead Platteville, Windsor, Nunn Tele.
Exhibit 1 -Page 1 of 2
Ex-;;ibis Table to U'larify Calling Area Expansion Request - Exhibit I
Exchanue Current Calling Areas Proposed Calling Areas (Extension)
!Platteville Berthoud. Eaton-Ault, Ft. Lupton. Estes Park, Ft. Collins. Loveland. Nunn
Gilcrest, Greeiey, Johnstown- Tele.
Milliken, La Salle, Longmont,
Mead, Windsor
Windsor Berthoud, Eaton-Ault, Ft. Collins, Estes Park, Loveland, Nunn Tele.
Gilcrest, Greeley, Johnstown-
Milliken, La Salle, Platteville
Nunn Tele. of At least to Greeley, Eaton-Ault, Ft. Berthoud, Estes Park, Gilcrest, Johnstown-
CenturyTel Collins Milliken, La Sale, Loveland, Platteville,
Windsor
•
•
Exhibit 1 -Page 2 of 2
APPLICATION TO THE PUBLIC UTILITIES COMMISSION FOR THE
PURPOSE OF EXPANDING THE LOCAL CALLING AREA
'his application is a joint filing for expansion of the local calling area in Northern
Colorado. The current calling area includes the following exchanges: Fort Collins, Estes
Park, Loveland, Berthoud, and Johnstown-Milliken. This expansion application is to add
the following exchanges: northern exchange area around Highway 85 (area bordered by
the northern state line, the Fort Collins exchange area on the west, the Eaton-Ault
exchange area on the east and the Windsor exchange area on the south); Windsor; Eaton-
Ault; Greeley; Lasalle; Evans; and Platteville. We are requesting two-way calling
between all communities in the current and proposed exchange areas as indicated in the
map below.
AIb.nY L.r....
l _ Telephone
,:.::.' ,-41)-::-;7.i ..'/ Exchanges
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Letters of support are intended to be "signatures" for the application. Several
communities are participating in this joint application as indicated by the "Exhibit Table
to Clarify Calling Area Expansion Request-Exhibit 1 ". Letters of support have been
signed by a majority of the county commissioners in both Weld and Larimer Counties.
We believe the evidence presented in this application meets the alternate criteria standard
for a community of interest. Northern Colorado is a regional economy with local calling
area needs.
1
REGIONAL ECONOMY
interdependence of Business Centers
The Northern Colorado area is a regional economy. Its interdependence is much like the
Denver Metro area.
Urban Growth Areas, Growth Management Areas, City Limits The North Front Range
Transportation &Air
2 Quality Planning Council
staff collected information
YT .5 ,. — about growth areas. These
"n' c I areas are called Urban
ti� �,,� Growth areas in some
^� r I Cveschn communities and Growth
®. :
�; 7 ova. Management Areas in
�".'�. � —' others. The map to the left
40'4.-;l4,1 rid indicates plans for the
.. ,; .,
^t ---14. I-_-2--� communities to annex and
_ - .:: i •
~° I tarn / incorporate the areas into
Z-4- • their city limits. It clearly
�" — -� indicates that the
communities are forming a
geographic regional relationship. The next graphic indicates that the regional economy
already exists. It is the commuter patterns and tells the tale well.
According to the 2001
Regional Household Travel •
III"I
Survey Overview, a North Front Rs r• - Regional Travel Patterns
Range Metropolitan Planning t - d'i ,
Organization (NFRMPO) ' "• ua
study:
1!!1 ••. 1 r, I
+t ' ��es�wwwxVA ten.__
• 30% of Greeley's •
�' tit I y�' m�ti
workforce commutes t ■ il� ��•
outside Greeley ,i�5 • 9r� �` •.n d
• 45% of Loveland's ` '` A'
workforce commutes : ,,. _< ..n.,
r .
outside of Loveland �, L `-s_• er4illiffi li
U t 4 �. `. t AM�m r Y� '
• 17/o of Fort Collins' d •l9n�n� v. w F in I s
y+
workforce commutes a ° � ;"
outside of Fort Collins °w ' 4if •
2
Regionalism relates to the close proximity of the business centers. If Fort Collins were
used as the point of origination the following chart indicates the short distances in miles
and times for communities in the region.
Chi Hiles Minutes
Loveland 8 • • .-.
Greeley 29
Windsor 10
According to the NFRMPO, "many residents in Northern Colorado are spending much of
their time driving. If the average number of household trips per day is 6.25 trips and the
average trip length is 18.64 minutes, each resident in Northern Colorado is spending an
average of 116.5 minutes or almost two hours traveling in one day." The point is that
residents in Northern Colorado are accustom to driving and think very little of driving for
their needs and desires throughout Northern Colorado.
The Northern Colorado Economic Development Council produced and distributed a
report in June, 2003, Northern Colorado Primary Employers Research Project. The
purpose of the project is to determine existing businesses' ability to do business in
Northern Colorado and to identify the strengths and weaknesses of business activity in
Northern Colorado from the perspective of the firms themselves. The project was based
on an interview approach with thirty-eight primary employers. Primary employers are
defined by their products-goods or services that are exported out of the region and that
result in net"new" dollars returning to the region. There were several findings with
regard to regional business issues. Two of the most important as it pertains to the need to
communicate between counties are workforce commuters and supplier relationships for
business in the region.
Larimer County Residents Who Work in The report provided information about
Other Counties the Larimer County workforce that
supports regionalism. 21,206
employees or 16% of the total Larimer
Adams
Other
s i County workforce lives in Larimer
19%�* •
County and works in other counties.
Boulder 6,290 or 30% of them commute to
We 36% Weld County.
30% Denver
to% The Smart Trips program reports that
there are approximately 1,500
participants in the Smart Trips
commuter program. The study indicated that on the average commuters travel in excess
20 miles one way to work.
3
The NCEDC Primary
Employers report also International
found that "45% of the ��� it
National
inputs used by local
business included in the Regional(between 50-250 mi.) r
research are purchased
Local(within 50 mi.)
from businesses within , ,t
the region and almost o 10 20 30 40 50 60
40% of the goods Source of Supplies by Percentage
produced from those
inputs are sold with
Northern Colorado. This, indeed, shows the interconnectivity of Northern Colorado's
economy."
There were several findings in the report that suggest the regional economy will continue
to thrive.
• According to the report 16%rated the local business climate better today than five
years ago.
• 80% felt that the local business climate five years form today will be better than it
is at the present
• 42% have been increasing investment in the facility, while almost 40% have had a
steady rate of investment
• Job growth is anticipated, primarily in the manufacturing sector
• 39% of the employers stated that there would be come expansion in the
employment base and nearly 53% said they would remain at the same level of
employment
• 80% of the primary employers are predicting at least some growth in sales
Since a little less than 3% of the essential ss a older I I
workforce is described as near retirement
the trends are expected to continue. 35-55 yrs
, R I I
or less
0 20 40 60 80
Percentage of Workforce
4
,)11;:. 'I iorauo Luc'.
The Center for Business and Economic Development and the State Demographer indicate
nat job growth in Northern Colorado will be above the state and national levels over the
-text 20 years further supporting the notion that the current patterns will continue into the
suture.
North Front Range is the modeling area for the regional transportation study. The study
that was commissioned indicated that there will be a 70%job growth in Larimer County
by 2030. Weld County will see a job growth of 95% over the same time period.
Regional Transportation Planning
The North Front Range Transportation& Air Quality Planning Council is an association
of local governments was formed in 1987 to address transportation and air quality
planning issues in Colorado's North Front Range. It is responsible for transportation
planning in the region that consists of the most populous parts of Larimer and Weld
Counties, including the cities of Fort Collins, Greeley, Loveland, Evans and the towns of
Berthoud, Garden City, Johnstown, LaSalle, Timnath and Windsor. This council has
developed a$606.3 million transportation plan based on the regional interdependence
founded in employment, shopping and entertainment. The plans focus on regionally
significant corridors. These corridors are defined as a corridor that serves as an important
link between major communities and destinations within or outside the North Front
Range. Corridors are identified as far north as Wellington, east to Kersey, south to
Gilcrest and across to the Boulder County line south of Berthoud, and west into the
Poudre and Thompson Canyons. It includes highway projects, transit projects,bike and
pedestrian projects, rail projects, Transportation Demand Management projects and
Transportation System Management projects spread throughout the region. The
organization is working on the means to finance the plan that requires significant
coordination efforts between member communities in both Larimer and Weld Counties.
There is currently an effort to develop support for a funding mechanism and a North
Front Range Transportation Authority to manage funds made up of Berthoud, Evan, Fort
Collins, Garden City, Greeley, Johnstown, Loveland, Milliken, Timnath, Windsor and the
unincorporated areas of Weld and Larimer Counties.
Regional Economic Development
The Northern Colorado Economic Development Corporation(NCEDC) is a 501(c) 6
designated, public/private, not-for-profit corporation serving Northern Colorado. Funded
by investments from regional businesses and government entities, the focus of the
NCEDC is to leverage public and private funds to strengthen existing employers, support
expansion projects, provide critical research for decision-making, and recruit new
employers who create primary jobs, invest capital, and add vitality to the economy. The
organization has many investors from various sectors of the community and is served by
a 27-member Board of Directors, CEO, and staff that work closely with local resources
and business service providers.
5
•
_,.._:.'1[ •rc: itsan
They strive to enhance the region's future by supporting existing businesses and
recruiting new businesses to our vibrant communities. They are focused on increasing the
number of primaryjobs in our region, which will ultimately create exported goods and
services that, in return, will draw new business and industry into our area.
Another economic development effort that crosses the county lines and therefore the
calling area lines is the Weld/Larimer Revolving Loan Fund program. The loan fund was
established to assist with the financial needs of the companies expanding or locating to
the rural areas of Weld or Larimer County. The program is funded through the State of
Colorado Community Development Block Grant (CDBG) allocation and is administered
by the Greeley/Weld Economic Development (EDAP) agency. Larimer County has an
intergovernmental agreement with Weld County for the CDBG Loan Fund. A copy of
that agreement has been attached (Exhibit 2).
Economic development of the Northern Colorado region involves a considerable amount
of communication for the benefit of the regional economy.
Utilities
By law Platte River Power Authority can only provide service to Estes Park, Fort Collins,
Longmont and Loveland. However there are operational dependencies on Weld County.
• 13% of the Platte River Authority workforce lives in Weld County and works in
facilities in Larimer County.
• Over the last two years, Platte River has done business with 58 Weld County
vendors.
Northern Colorado Water Conservancy District is a public agency created in 1937. It
provides water for agricultural, municipal, domestic and industrial uses in northeastern
Colorado. NCWCD encompasses 1.5 million acres in portions of Boulder, Larimer,
Weld, Broomfield,Morgan, Logan, Washington, and Sedgwick counties. Most of the 95
full time positions work in Loveland and will move to Berthoud once that facility is
complete.
The Little Thompson Water District has a 300 square mile service area generally bound
by the City of Loveland on the north, Longs Peak Water District on the south, the City of
Greeley, the South Platte River and the St. Vrain River on the east, and the foothills on
the west. It also now includes the former Arkins Association and the Town of Mead.
They provide treated water to about 6,500 homes and businesses in Northern Colorado.
The organization is a user-owned, not for profit public utility with customers in Larimer,
Weld, and Boulder counties.
Healthcare Providers
The major hospital systems in the area serve the entire Northern Colorado region as well
as southern Wyoming and southwestern Nebraska. They have provided information
6
about their patients and their workforce that indicates that Northern Colorado
communication is important.
Pouare Valley Hospital in Fort Collins
i Larimer County Facility Patient Care(Overnight Employees
stays in 2001)
Portion from Weld 1045 257— 10% of
County workforce; 101
367 from the greater of them from
Greeley area and 678 from Windsor
Windsor/Johnstown/Milliken
Poudre Valley Health Systems Health Systems of Fort Collins, Colorado and Regional
West Medical Center of Scottsbluff, Nebraska are joining efforts to build a$200 million
regional hospital immediately south of the Fort Collins Loveland airport. Service
provisions will be specialized: heart care and surgery,neurosurgery, and trauma. It will
be a 115-bed facility with 500 employees. Its service area is expected to be northern
Colorado, southern Wyoming and southwestern Nebraska.
Banner Health Care System in Larimer and Weld Counties
Facility Patient Care Employees (work in
one county and live in the
other)
McKee Medical 400 or 6% inpatient 100 or 10% of
Center-Loveland, 1255 or 6% emergency workforce
Larimer County 2600 or 5% outpatient
Northern 730 or 5% inpatient 263 or 5% of
Colorado Medical 640 or 2% emergency workforce
Center— Greeley, 1811 or 2% outpatient
Weld County
Banner Health Care System has announced plans for a two-phase $70 million expansion.
The expansion will include a new Intensive Care/Telemetry unit, expand birthing suites
in the obstetrics department, add two additional surgical suites and enlarge the Peri
Auesthesia Care Unit.
Both hospital systems have made a substantial commitment to the Northern Colorado
region. They provide excellent patient care and are amongst the largest employers in the
area. Communications within the region are particularly important in this industry.
7
Primary Education (K- 12)
The map to the right
illustrates the issue with 'I '" v Telephone
uL Exchanges
overlapping boundaries. m
The brown line is the z C i?
easterly border of the , ' ` rx
Thompson Valley ; I
School District. There ""
are several Windsor ,
students in the proposed t:41
calling area expansion i A
(light green) that attend -
Thompson Valley
�_ ---
Schools. It is a long
distance school to "—
contact the school or for
the students to call home.
Sports conferences have been set up by the schools districts, one designated for the
football league and one for all other sports. The Tri-Valley 3A Football Conference
includes: Berthoud, Fort Lupton, Fort Morgan, Mountain View (Loveland), Northridge
(Greeley), Silver Creek (Longmont), Sterling and Windsor. District 4 sports conference
for all other sports includes several Northern Colorado teams. This conference includes:
Berthoud, Fort Lupton, Fort Morgan, Greeley Central, Greeley West, Longmont, Niwot,
Skyline(Longmont), Sterling, and Windsor. Communication amongst Northern
Colorado schools becomes critically important as these teams schedule games,juggle
facility availability and set up coaches meetings for a variety of other administrative
tasks. Communication between parents, coaches and athletes because important
throughout the year as well.
Secondary Education
Colorado State University
Colorado State University is a land-grant institution and a Carnegie Doctoral/Research
University-Extensive. 24,000 students from every state and 95 foreign countries. 150
programs of study are offered within eight colleges.
• 163 employees that live in Weld County
• 69 students (generally first year students that still claim parents address)
• 12 active Colorado alumni chapters
• Extension Offices in 59 of 64 Colorado Counties, including Weld and Larimer
Counties
8
Jrt): rn 1...torcao Lu,.:f jaLi nw...">..
• Events in the athletic, music, theater &dance departments draw audiences
primarily from the enure Northern Colorado region
o Rams field teams in 15 intercollegiate sports
o Hughes Stadium with capacity for 30,000 fans
o Moby Arena with capacity for 9,000 fans
o 300+performances, exhibits, and other arts events annually
University of Northern Colorado
• Single campus in Greeley, Colorado
• 11,000 students from 47 states and 52 nations
• 40 undergraduate degree programs with 103 emphasis areas and 52 graduate
degree programs with 90 emphasis areas
• 1,035 Larimer County residents were enrolled as students in 2002.
• UNC does business with 400-450 Larimer County commercial vendors annually
• 123 of their 1,382 employees live in Larimer County(9%)
• 794 undergraduate and 241 graduate students attend UNC and live in Larimer
County
Front Range Community College
• Front Range Community College has campuses in Boulder, Boulder County, Brighton,
Larimer(Fort Collins), Estes Park, Longmont, and Westminster. The Larimer Campus in
Fort Collins provides education and is an employer in Larimer County that draws from
the entire Northern Colorado region. There are 4,698 students enrolled at the Larimer
Campus and the enrollment has tripled in 10 years. 146 of those students live in Weld
County and commute to Fort Collins to attend classes.
FRCC-Larimer has strong partnerships with Colorado State University and the three
public school districts in the county - Park, Poudre, and Thompson. FRCC's Veterinary
Technology program is a partner with the Program of Excellence at CSU's College of
Veterinary Medicine and Biomedical Science.
It provides continuing education for several major area employers: CSU, Hewlett-
Packard, Poudre School District, Eastman Kodak, Poudre Valley Hospital, Woodward
Governor, the City of Fort Collins, Larimer County, Teledyne Water Pik, LSI Logic and
Anheuser-Busch. Eastman Kodak located in Windsor is currently a long distance call.
Aims Community College
Aims Community College is one of the largest and most comprehensive two-year
colleges in Colorado. The main campus is located in Greeley, Colorado. Since 1967
Aims has established three campuses— Greeley, Fort Lupton, and Loveland. Today
14,000 students who annually attend the college choose from 60 degree and certificate
programs. In addition, Aims helps businesses and industry assess employee job skills
and improve work productivity. The Aims student body is, on the average, older than
9
,racto .,
most community colleges. The average Aims student is age 34, is female, works part-
::me and has a family. This particular demographic has special, low-cost, communication
needs. Aims teaches recent high school graduates, senior corporate officials, first graders
nn the summer college for Kids program, and instructs 90-year-oids on how to keep
number in Senior Shape-Up classes. Aims Community College is truly a college for the
community.
Student Database Information
• 529 of the 1,029 (51%) students that reside in Larimer County commute to either
the Greeley or Fort Lupton campuses
• 121 of 4,679 (3%) of the students that reside in Weld County commute to the
Loveland campus
Workforce Database Information
• 68 of 125 (54%) employees reside in Larimer County and commute to the
Greeley or Fort Lupton campuses to work
• 18 of 529 (3%) employees reside in Weld County and commute to the Loveland
campus to work
Non-Profit Agency Coordination of Service Delivery
Many of the United Way agencies that provide service in Larimer County have
administrative offices in Greeley. Catholic Charities Northern, Consumer Credit
Counseling Services, Hope Counseling Center, Lutheran Family Services, and RVNA
Home Care Services all operated from both counties. Additionally, United Way Offices
collaborate on many dual county projects such as the Funders Fair on July 315t. This
event brings together well over 200 nonprofit agencies from Larimer and Weld Counties
to meet with funders from across the state to explore new funding opportunities.
The Loveland Community Health Center is a non-profit organization that serves the
uninsured and underinsured members of communities throughout the Northern Colorado
Region. Over the last year(2002) 304 of 6,934 of their patients were from Weld County.
This is fairly substantial since it is a Larimer County service entity sponsored by the
McKee Medical Foundation.
Island Grove Regional Treatment Center, Inc. is the only substance abuse treatment
center for the Weld and Larimer County area. The Larimer County contract is attached
for your review (Exhibit 3). The Island Grove Treatment Center provides fro non-
hospital based substance abuse detoxification services to Larimer and Weld County
residents through the appropriate governmental agencies (Le., Loveland Police
Department, Larimer County Health and Human Services, Greeley Police Department).
Local Calling Area communication to provide timely assistance for individuals in need
and coordinating the transportation to the treatment center is critical.
10
County Relationships
There are intergovernmental relationships between Larimer and Weld Counties. Two
good examples are: 4-H programs, and extension service horticulture education.
There is a common perception that 4-H group membership is aligned with the county of
residence. However, Larimer County indicates that there are 68 Weld County families
involved in the Larimer County 4-H program, which represents 97 members and 42 adult
leaders. The reverse is true as well. The only stipulation is that residents of either county
can only belong to one 4-H program.
Larimer County has four master gardeners in the horticulture education program who live
in Weld County. The professionals in the extension services for Larimer and Weld
counties have different areas of expertise and commonly refer questions from residents
"across county lines". Larimer County indicates that they get 10-15 calls per week from
people who identify themselves as Weld County residents.
Since public health and environmental issues generally do not align themselves with
county borders, they require a collaborative effort. Funding available to address these
concerns is always a scarcity. The cost of necessary communication is a concern.
Regional Leisure Destinations
The Northern Colorado region is rich with leisure destinations that enhance the quality of
life. Because the relative travel time within the region is manageable, each destination
serves the entire area.
The Ranch
Larimer County completed construction on a 7,200-seat events center September 2003
directly across Interstate 25 from the airport. It is already substantially"booked" for the
year. Colorado's professional hockey team, the Avalanche, have already agreed to play
exhibition games as this facility. A minor league hockey team and women's professional
basketball team have committed to play home games at the facility. Events that have
already been announced include: Bill Cosby(comedy), Scott Hamilton and Friends (ice
skating), Kenny Rogers (singer), Motocross on Ice, Disney on Ice, Harlem Globetrotters,
Sesame Street Live, and Lipizzaner Stallions. The facility will host concerts,
professional rodeos, and many other events that will attract performers from around the
nation and attract fans from the entire region, possibly the state.
There are several other venues that attract visitors from around the region. Events that
call these venues home are related to animal best-in-breed competitions, product shows,
sports activities and arts activities. Island Grove Regional Park, Colorado Marketplace,
and a facility at CSU hold animal and product shows (i.e. animal competitions, boat
shows, RV shows, and the like).
11
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everal sports complexes and golf courses (too numerous to mention) in the region serve
is the location for tournament play with participants at all age groups that reside
nroughout Northern Colorado.
The Union Colony Civic Center (Greeley), Lincoln Center(Fort Collins) and the Rialto
Theater(Loveland)bring the arts to the Northern Colorado region. They provide a
nationally acclaimed entertainment for a variety of tastes and preferences. Some of the
performers/performances included in the 2003-2004 seasons include: Natalie Cole, B.B.
King,Bob Newhart, Seussical, the Musical, Michael Flatley's Lord of the Dance, and
Kiss Me Kate. Just to name a few.
Conclusion
Residents and businesses in Northern Colorado truly support a regional economy in every
aspect of their lives. It is our hope that the Public Utilities Commission will see the value
of the body of evidence that has been submitted to establish a "community of interest".
Evidence of the interdependence of the business centers in the Northern Colorado region
has been found to exist in every segment of the economy.
> Growth management areas for Northern Colorado communities are
contiguous.
> There is substantial travel between three main business centers for both
employment and shopping.
> Short distances, short travel times, accessible roadways, and moderate
travel traffic volumes between business centers in Northern Colorado are
factors that perpetuate interdependence.
> Businesses are buying local. 45% inputs used by primary employers to
generate goods and services are purchased from local businesses in the
region.
> The regional North Front Range Transportation & Air Quality Planning
Council exists due to regional cooperation of the communities in Northern
Colorado, particularly related to transportation initiatives.
> Regional economic development organizations exist because of the
salability of the regional concept for recruiting businesses.
> Utility providers have a dependence upon resources and customers
throughout the region.
> Two major hospital systems (locations in Greeley, Loveland, and Fort
Collins) provide services for patients throughout the region and are major
employers in the region.
12
Educational entities serve overlapping county areas for kindergarten
through 12'h grade. Windsor residents that attend Thompson Valley
(Loveland) schools.
Universities and community colleges serve the entire region. These
institutions are serving a role in continuing education for the businesses in
the area and are amongst the largest employers in the region.
Non-profit agencies, Larimer and Weld counties work together to address
human service needs of the region, as well as support the strong
agricultural business segment of the region through extension services.
➢ Regional leisure destinations attract users from the entire region providing
a well-rounded, higher quality of life.
The Northern Colorado region is a regional economy. We understand that there could be
an incremental increase to the monthly bill for each customer throughout the calling area
based on infrastructure costs to make the expansion possible. It is our hope that given the
number of customers included in the proposed area each customer's proportional share
would be very small. We believe the monthly cost of long distance between the
exchanges included in the application and the cost of service alternatives to avoid long
distance calls would substantially reduce monthly financial obligations of businesses and
residents in our region.
13
Sources of Information Contained in this Report:
. Exchange Area maps were provided by Edie Ortega, Public Affairs Manager,
Qwest 331 Eastbrook Drive, Fort Collins, Colorado 80525
2. Urban Growth Areas/Growth Management Areas/City Limits map provided by
Margie Joy, Public Participation and Outreach Manager, North Front Range
Metropolitan Planning Organization.
3. Regional Travel Patterns graphic provided by Margie Joy, Public Participation
and Outreach Manager, North Front Range Metropolitan Planning Organization.
4. 2001 Regional Household Travel Survey Overview, conducted for The North
Front Range Metropolitan Planning Organization prepared by ETC Institute,
Olthe, KS and Bucher, Willis &Ratliff, January 2002.
5. Northern Colorado Primary Employers Research Project, Final Analysis Report,
prepared by the Northern Colorado Economic Development Corporation,
Loveland, Colorado, June, 2003.
The consolidated Telephone Exchanges map was prepared by Steve Holmes, Land
Records Manager, City of Loveland.
Web sites were "consulted" for basic descriptive and statistical information about the
organizations.
• North Front Range Metropolitan Planning Organization
http://www.nfrmpo.org/
• Platte River Authority http://www.prpa.org/
• Northern Colorado Water Conservancy District http://www.ncwcd.ora/
• Little Thompson Water District http://www.ltwd.org/
• Northern Colorado Economic Development Council
http://www.ncedc.com
• Colorado State University http://welcome.colostate.edu/
• University of Northern Colorado http://www.unco.edu/
• Front Range Community College http://frcc.cc.co.us/
• Aims Community College http://www.aims.edu/
All other information was made available by organizations mentioned in the document
based on an interview process performed via e-mail, in person, or over the telephone.
Interviews were conducted by Renee Wheeler, Assistant to the City Manager, City of
Loveland.
14
e
CERTIFICATE OF SERVICE
I hereby certify that on this 30th day of August, 2004,the original and 5 copies of the
foregoing UNOPPOSED JOINT MOTION TO APPROVE PARTIAL STIPULATION AND
PARTIAL SETTLEMENT AGREEMENT OF THE PARTIES AND REQUEST FOR WAIVER
OF RESPONSE TIME and PARTIAL STIPULATION AND PARTIAL SETTLEMENT
AGREEMENT OF THE PARTIES were hand-delivered to:
Bruce Smith,Director
Colorado Public Utilities Commission
1580 Logan, OL2
Denver, CO 80203
and a copy was faxed, hand-delivered or placed in the United States mail, postage prepaid, and
addressed to:
Renee Wheeler Pat Parker
Assistant to the City Manager Rate/Financial Analyst
City of Loveland Office of Consumer Counsel
500 E. 3rd St. 1580 Logan Street, Suite 740
Loveland, CO 80537 Denver, CO 80203
David P. Ayraud, Esq. Andrew B. Clauss, Esq.
Assistant County Attorney Winslow B. Waxter, Esq.
Larimer County Board of County David W. McGann, Esq.
Commissioners Qwest Corporation
P.O. Box 1606 1005 17th St., Suite 200
Fort Collins, CO 80522 Denver, CO 80202
P.B. Schechter Anne K. Botterud, Esq.
Rate/Financial Analyst Assistant Attorney General
Office of Consumer Counsel Business & Licensing Section
1580 Logan Street, Suite740 Office of the Attorney General
Denver, CO 80203 1525 Sherman St. 5th Floor
Denver, CO 80203
Sharon Podein Gary Klug
Testimonial Staff Testimonial Staff
Public Utilities Commission Public Utilities Commission
1580 Logan St., OL2 1580 Logan St., OL2
Denver, CO 80203 Denver, CO 80203
Becky Quintana Michael Zimmerman
Advisory Staff Advisory Staff
Public Utilities Commission Public Utilities Commission
1580 Logan St., OL2 1580 Logan St., OL2
Denver, CO 80203 Denver, CO 80203
Anthony Marquez, Esq. Barry L. Hjort
Assistant Attorney General Hjort Law Firm
State Services Section P.O. Box 461288
Office of the Attorney General Glendale, CO 80246
1525 Sherman St., 5th Floor
Denver, CO 80203
City of Evans City of Fort Collins
1100 37th Street 300 Laporte Ave.,Floor 2
Evans, CO 80620 Fort Collins, CO 80522
City of Greeley Larimer County
1000 10th St. Tom Bender, Commission Chair
Greeley, CO 80631 P.O. Box 1190
Fort Collins, CO 80522
Weld County Nunn Telephone Company
David E. Long, Commission Chair P.O. Box 249
915 10th St. Nunn, CO 80648
Greeley, CO 80632
Town of Ault Town of Berthoud
Sharon Sullivan, Town Clerk/Treasurer P.O. Box 1229
201 First Street Berthoud, CO 80513-2229
Ault, CO 80610
Town of Eaton Town of Estes Park
Gary Carsten, Town Administrator John Baudek, Mayor
223 First Street P.O. Box 1200
Eaton, CO 80615 Estes Park, CO 80517
Town of Gilcrist Town of Johnstown
Paul Chacon, Mayor Troy Mellon, Mayor
204 8th St., Box 128 Box 609
Gilcrest, CO 80623 Johnstown, CO 80534
Town of Kersey Town of LaSalle
Timothy J. Phippard,Mayor Tim Evans,Mayor
332 Third St. 128 No. Second St.
Kersey, CO 80644 LaSalle, CO 80645
Town of Mead Town of Milliken
Richard E. Kraemer, Mayor P.O. Box 290
441 Third St. Milliken, CO 80543
Mead, CO 80542
Town of Nunn Town of Platteville
Duane Bayne,Mayor Nicholas J. Meier, Town Administrator
185 Lincoln Ave. 400 Grand Avenue
Nunn, CO 80648 Platteville, CO 80651
Town of Timnath Town of Windsor
Annalee Foster,Mayor Board of Trustees
4100 Main Street 301 Walnut Street
Timnath, CO 80547 Windsor, CO 80550
Don F. Williams Sharon Citino
City Manager Assistant City Attorney
City of Loveland 500 East Third St.
500 East Third St. Loveland, CO 80537
Loveland, CO 80537
Greg White
Town Attorney
1423 W. 29th St.
Loveland, CO 80538
Page 1 of 1
Carol Harding
To: Janet Reichert
Subject: RE: Release of liens - Local Improvement Districts
Thanks.
From: Janet Reichert
Sent: Tuesday, January 04, 2005 2:21 PM
To: Carol Harding
Subject: RE: Release of liens - Local Improvement Districts
I will be sending them to you next week after the Treasurer sends me December reports.
From: Carol Harding
Sent: Tuesday, January 04, 2005 12:21 PM
To: Janet Reichert
Subject: Release of liens - Local Improvement Districts
It's that time of year again, when we release the liens on Local Improvement Districts which were paid off in
2004. I can't remember if you send them without prompting, or if we need to request them. Could you please
send me a list of them so we can process the Resolutions? Thanks.
Carol
1/4/2005
Page 1 of 3
Carol Harding
From: Bruce Barker
Sent: Monday, August 30, 2004 1:54 PM
To: Carol Harding
Subject: FW: Final Stipulation Agreement-Quick Action Needed
See the attached. For backup to the stipulation I gave to Debra for the Board's agenda on Wednesday
(9/1).
From: Renee Wheeler [mailto:wheelr@ci.loveland.co.us]
Sent: Monday, August 30, 2004 12:00 PM
To: Bruce Barker
Subject: RE: Final Stipulation Agreement-Quick Action Needed
Hello Bruce! Thanks for you message.
The application has graphics that cause it to be of substantial size and our system won't let me send it.
I would be happy to send you a hard copy. Vickie Sprague has a hard copy as well if that is an easier
route. Just let me know which regular mail address you would like me to use.
Attachment A is referenced on page 4 of the agreement. We don't have a copy of Nunn's
correspondence confirming its intentions. Harris Adams Assistant Attorney General would have a
copy. 303-866-5441 or Harris Adams [harris.adams@state.co.us].
Have a great day./
Renee Wheeler
Assistant to the City Manager
970-962-2704
wheelr@clloveland.co.us
From: Bruce Barker [mailto:bbarker@co.weld.co.us]
Sent: Monday, August 30, 2004 11:25 AM
To: Renee Wheeler
9/1/2004
Page 2 of 3
Subject: RE: Final Stipulation Agreement-Quick Action Needed
Thanks. I will be placing the Stipulation on the agenda for the Board of County Commissioners
approval for this Wednesday (9/1). The Board may ask about what facts are being stipulated to. I see
that the facts are contained in the application, which is Attachment B. I hate to ask for a copy, but I
probably should. Also, is there an Attachment A?
From: Renee Wheeler [mailto:wheelr@ci.loveland.co.us]
Sent: Monday, August 30, 2004 7:43 AM
To: Bruce Barker; Bruce Eisenhauer; Carl Harvey; David Ayraud; David May; Don Williams; Donald
Cadwallader; Frank Lancaster; Gaye Stockman; Jim White; Joe Racine; JR Schnelzer; Michael Friesen; Myles
Jensen; Nick Meier; Richard Widmer; Rod Wensing; Roy Lauricello; Roy Otto; Sharon Sullivan; Tom Vosburg;
Town of Nunn; Trudy Peterson; Vicky Sprague
Cc: Sharon Citino; John Duval
Subject: Final Stipulation Agreement-Quick Action Needed
Hello all!
The attached document is the stipulation agreement we are asking you sign. It has been reduced in
scope.
The single purpose of the stipulation at this point is to agree that the community of interest standard
has been met and won't be challenged during the proceedings that follow. You will notice that Qwest
is not included. After a lengthy meeting on Thursday, Qwest decided they would not sign a
stipulation agreement. Instead they gave Sharon Citino and other parties' attorneys' authorization to
include in the motion for approval of the agreement that they would not oppose approval of the
stipulation.
Please review the stipulation agreement with your attorney. We will need both signatures
(mayor/manager and attorney). For those of you that are authorized to sign on behalf of your
organization (either because you have already reviewed the previous draft with your councils/boards
or do not need to take it to your council/board), we really need the signature page faxed to Harris
Adams at (303)866-5342 by Today, 8/30/04, 2:00 pm. He is the Assistant Attorney General that has
been representing the Office of Consumer Counsel and is coordinating the physical logistics of filing
of the motion to approve the stipulation and the stipulation. Please send me an e-mail indicating that
you sent a signature page to Harris so that I know which signatures we still need. Sharon Citino is
available to address any questions about the agreement at 970-962-2540.
Those of you who need to take the agreement to a council/board meeting or study session, please do
so as soon as possible and fax the signature page to me at (970)962-2900. Once we have all the
additional organizations that could not get signed for the original filing, Sharon Citino will take care
of generating a cover pleading supplementing signatures to the stipulation for filing. I know that some
of you indicated it would be 9/14/04 before you could get approval. We need all parties' signature
sheets no later than September 24, 2004.
9/1/2004
Page 3 of 3
•
Thanks so much in advance for addressing this as quickly as possible.
Have a great day./
Renee Wheeler
Assistant to the City Manager
970-962-2704
wheelr@cilovelandco.us
9/1/2004
Hello