13. Federal and State Regulatory Impact

After completion of the merger, the combined Citizens companies will maintain the existing federal Universal Service Administrative Company (USAC) study areas, Service Provider Identification Numbers (SPIN), and Operating Company Numbers (OCN). Accordingly, this transaction should have no impact on numbering resources, federal universal support, and /or federal or state public program claims/filings.

Frontier-Golden State, Frontier-Tuolumne and Frontier-Global Valley currently do not draw from the California High Cost Fund-A (CHCF-A). Therefore, this merger should have no impact on that program.

Frontier-California currently draws from the California High Cost Fund-B (CHCF-B). Once the merger is complete, Frontier-California anticipates that it would include the approximately 22,000 basic residential access lines served by Frontier-Golden State, Frontier-Tuolumne and Frontier-Global Valley in the calculations for support under the CHCF-B program. However, Frontier-California does not currently anticipate that all of these lines will qualify as high cost, since the benchmark rate will likely be raised by mid-2009. Since the CHCF-B program is under review and changes in process and qualification are likely in the months to come, it is not known what impact these additional lines would have on the overall program. However, Frontier-California anticipates that the impact on the CHCF-B fund overall would be insignificant.

Joint Applicants do not anticipate that the proposed merger would have any impact on the other Commission public purpose programs, such as the Universal Lifeline Telephone Service, California Relay Service, or California Teleconnect Fund. Similarly, Joint Applicants anticipate that the proposed merger would not impact the Commission User Fee or amounts collected in connection with the 911 program.