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WESTERN PRESENTS ITS SUBSIDY MODEL FOR UNIVERSAL-SERVICE PROGRAM

WASHINGTON-A computer model by Western Wireless Corp. to determine the amount of subsidy
each customer in a rural, high-cost or low-income area could help wireless carriers in the universal-service debate even
if it is not used by the Federal Communications Commission.

Western Wireless presented the model to the FCC late
last month, although the company originally unveiled its plan in July. FCC staff is working on its own model, culling
information from three competing models.

The delay in presenting the model to the FCC could put Western
Wireless’ plan at a disadvantage since FCC plans to have its model finished by April for full implementation July
1.

The FCC is devising a cost proxy model for universal-service support payments for carriers serving non-rural
areas. The cost proxy models are supposed to determine how much it would cost to build a telephone system from
scratch.

Western Wireless thinks its model still has merit, said Michele Farquhar, Western’s outside Washington
counsel. FCC staff “have continued to encourage [the wireless cost model] on a separate track … It has a much
broader use [than simply in the model debate]. It is beneficial on the Hill and in other lobbying venues,” Farquhar
said.

The model is expected to show that wireless service is more cost effective than wireline service in some cases,
a notion many states have rejected, Farquhar said. Western Wireless has 13 proceedings underway to obtain eligible
telecommunications carrier status so it can obtain universal-service support subsidies.

Western Wireless is at the
forefront of offering competitive local exchange service to rural areas, and this model could be used to determine
support for these areas when the FCC takes up the issue in 2001.

Western Wireless gave the FCC its blueprints for
subsidy payouts right after the wireless carrier had a run-in with Consolidated Telephone Cooperative in Regent, N.D.,
population 268.

CTC, the rural wireline phone company in Regent, disconnected telephone numbers Western
Wireless was using to offer wireless local loop service. CTC claims Western should have negotiated a competitive
interconnection agreement with the phone company since Western is offering residential phone service. Western has
filed a complaint with the North Dakota Public Service Commission and a lawsuit in district court. Western is offering
competitive rates and a calling area larger than CTC’s.

Service was restored last week to Western Wireless after
Western filed a complaint with the FCC.

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