March 9, 2011 VIA ELECTRONIC FILING. Marlene H. Dortch, Secretary Federal Communications Commission th Street, S.W. Washington, DC

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1 Joshua M. Bobeck Direct Phone: Direct Fax: March 9, 2011 VIA ELECTRONIC FILING Marlene H. Dortch, Secretary Federal Communications Commission th Street, S.W. Washington, DC Re: Notice of Ex Parte Meeting Qwest Communications International, Inc. and CenturyTel, Inc. d/b/a CenturyLink, Application for Transfer of Control Under Section 214 of the Communications Act, as Amended, WC Docket No A National Broadband Plan for Our Future, GN Docket No Fixed and Mobile Services in the Mobile Satellite Service Bands at MHz and MHz, MHz MHz, and MHz and MHz, ET Docket No Dear Ms. Dortch: On March 8, 2011, Neil L. Brodsky, Senior Corporate Counsel, Granite Telecommunications, LLC and the undersigned, met with Commissioner Mignon Clyburn and her legal advisor, Louis Peraertz. Granite updated the attendees on its progress in serving the national multi location business market and addressed the following policy matters. Boston Hartford Hong Kong London Los Angeles New York Orange County San Francisco Santa Monica Silicon Valley Tokyo Washington Bingham McCutchenLLP 202o K Street NW Washington, DC 2ooo6-18o6 First, Granite expressed concern regarding the pending Qwest/CenturyLink transaction and the post-merger wholesale local services market in the regions that the combined company will serve. Granite currently has an agreement for Qwest' s wholesale local services and obtains such services at discounted rates. In contrast, CenturyLink has to date refused to provide similar wholesale services to Granite in the CenturyTel footprint. In its petition to deny the merger application, Granite specifically requested that the Commission require Qwest/CenturyLink, as a direct and specific condition to its pending merger, to offer wholesale local services not only in the Qwest region but also in the legacy CenturyLink territories as a condition of the merger. Second, Granite observed that Qwest continues to discriminate in the provision of wholesale services to Granite and other similarly situated CLECs by refusing to make available wholesale voice service at locations where Qwest has replaced its copper loops with fiber fed loops. Granite reiterated its belief that the merger would only be in the public interest if it were conditioned on, among others, a requirement that Qwest to offer T ooo F ooi bingham.com A/

2 Marlene H. Dortch, Secretary March 9, 2011 Page 2 its wholesale voice service at any location where a customer could purchase retail voice services from Qwest, regardless of the underlying technology Qwest chose to provide the loop. Third, Granite expressed concern that as its existing agreements with the Applicants expire, the Applicants will raise the prices pursuant to which Granite has been purchasing service and/or reduce retail prices below the price for their wholesale offerings. These concerns are exacerbated because there is no viable wholesale commercial alternative to the Applicants' last mile facilities and the potential for entry of another source of last mile access is unlikely for the foreseeable future. For these reasons, the Commission should require, as a condition of approval of the proposed merger, that the Applicants offer CLECs the option of continuing current commercial agreements in effect for the full duration of the merger conditions, and ensure that Qwest's OSS and billing systems remain in place for the duration of any such condition. Finally, Granite discussed its current ability to obtain DSL services for resale on a competitive basis from a number of ILECs with the notable exception of AT&T. While other ILECs allow competitors to provide their customers with DSL service over the same line they purchase for voice service, AT&T requires Granite and other requesting carriers to purchase a separate line, thereby artificially raising Granite's costs. Sincerely, /s/ electronically signed Joshua M. Bobeck cc (by ): Commissioner Mignon Clyburn Louis Peraertz A/

3 Granite Presentation to: Wireline Competition Bureau Carol Simpson, Alexis Johns, Bill Dever, Jennifer Prime Federal Communications Commission March 8, 2011 Presented by: Neil L. Brodsky

4 Granite Overview A. Granite Background B. Web Based Middleware/National Support I. North American Voice Management II. Structured Cabling and Systems III. Broadband Solutions IV. Security and Fire Alarm Systems C. References I. City II. Industry

5 Background Granite s 8 year history has seen explosive growth, 2010 revenues exceed $550 million. Headquartered in Boston, MA with offices throughout America, our debt free and profitable company, with no outside investors, is one of the fastest growing companies in the country, and employees 900 teammates. Recent Recognition Ernst & Young Entrepreneur of the Year (2010) BBJ Top 20 Charitable Contributor of the Year in Massachusetts (2009, 2010) Inc. 500/5000 Top 10 in Revenue/ Fastest Growing Private Companies (2007, 2008, 2009, 2010) BBJ Top 20 in Revenue with Private Companies in Massachusetts (2009, 2010) BBJ Top 20 Fastest Growing Private Companies in Massachusetts (2006, 2007, 2008, 2009, 2010)

6 National and Product Support National Billing: Single customized file, compatible with Oracle, JP Edwards, SAP, and countless others Support: Single National Account Team for entire country. Pricing: Single National Rate Product Voice: Local, Long distance, Analog, and Dedicated lines Broadband: DSL, Broadband, and T-1 Alarm Monitoring Service: Fire and Burglar Cabling Support: New Builds, Remodels, Roll Outs, and Voice Systems

7 Background Last 8 Years

8 2010 Quarterly Cabling Revenue Growth Million Million

9 *4.5 of America s Business lines

10 North American Voice Consolidation The nation s largest distributor of Bell company analog services. North American consolidation of support and savings. Over 1,000,000 analog business lines under management. ***Only competitor to ever have 1,000,000*** Customers include all 10 of America s 10 largest companies and 66 of the Fortune 100. Electronically bonded to 14 of the largest local carriers.

11 Structured Cabling and Systems Structured Cabling Installations: Design and installation of voice, data and video cabling for commercial and retail customers nationwide. Moves, adds, changes and repairs on existing cabling systems. Installation and maintenance of Avaya and Nortel phone systems. Rapid deployment of national rolls. Milestone - Online Project Management Tool. Partners - Avaya, Nortel, Samsung, Talk Switch, Leviton, Mohawk, Cisco, Shoretel, Systimax, and Novar.

12 Broadband Solutions Nationwide Broadband Service (30,000 lines installed) DSL, Cable, Wireless and Satellite One point of contact for ordering provisioning and management Scalable solutions 24/7/365 Broadband support Single consolidated invoice

13 Security & Fire Alarm Systems SECURITY ALARM MONITORING AND MAINTENANCE Burglar alarm system monitoring Back-up monitoring services utilizing cellular and long range radio service Web access to manage and track account data FIRE ALARM SYSTEM MONITORING AND MAINTENANCE Fire alarm service and monitoring Water-flow/sprinkler monitoring Fire extinguishers and suppression systems Special hazard/clean agent systems ACCESS CONTROL SYSTEM SERVICES Web-based, multi-site access control solutions PC-based, small to mid-sized solutions Biometric readers, eliminating the need for card management CCTV SYSTEMS Digital video recording and storage Remote video CCTV monitoring Security video CCTV cameras Product s and Associations: Honeywell, GE, UTC Fire & Security, DSC, NFPA, ESA, and CSAA

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