Financial Considerations in the New World!! GTA Annual Meeting Hilton Head, SC June 19, 2012 Leo Staurulakis – Executive Vice President

Discussion Topics Rate Base Regulation The Impact of the Order Are we still really rate of return carriers? Price Cap Carrier discussion Comparative profiles Structural Changes and Share Resources The importance of proper planning and execution in our evolution 2

Rate Base Regulation A regulatory process meant for capital intensive monopolistic utilities Over a prescribed period of time, recover your investment in the regulated plant Earn a Regulated Return on your Regulated Rate Base annually Recover specific expense activity related to your Regulated Rate Base 3

Benefits of Rate Base Regulation Provides stable environment to attract investors and incent capital investment Provides financial predictability and stability Helps to ensure the offering and delivery of communications services Limits financial effects of competition in rural markets 4

Top Seven Rate-Of-Return USF Reforms 5

Top seven rate-of-return USF Reforms Limit Reimbursements Broadband Overlap Service HCLS Benchmark Phase out of SNA Corporate Operations Overall Support Cap Move LSS to CAF-RM 6

ICC Policy Reforms 7

FCC Abandons Access Policy We reject the notion that only the calling party benefits from a call and therefore should bear the entire cost of originating, transporting, and terminating a call. As a result, we now abandon the calling-party-network-pays model that dominated ICC regimes of the last century. Although we adopt bill-and-keep as a national framework, governing both inter- and intrastate traffic, states will have a key role in determining the scope of each carrier’s financial responsibility for purposes of bill-and-keep. 8

What Does This Imply? 9

Are We Really RoR Carriers If: If we are limited on how much of our rate base we can recover on due to caps If we have an obligation to serve but are not allowed to recover on our investment or expenses if there is competition If key programs that are meant to get us our authorized return levels are capped or eliminated 10

Are We Really RoR Carriers Or are we forced to become more like Price Cap Carriers? While maintaining what we can from Rate of Return Regulation 11

Price Cap Form of Regulation 12

What Is Price Cap Regulation? Method adopted by the FCC in 1990 for regulating the interstate access rates of larger ILECs that focused on prices rather than earnings to maintain just and reasonable interstate access rates RBOCs & former GTE operating companies considered “mandatory” price cap filers Other ILECs can opt for price caps on an “elective” or voluntary basis 13

Expected Benefits of Price Caps “Price cap regulation encourages incumbent LECs to improve their efficiency by harnessing profit- making incentives to reduce costs, invest efficiently in new plant and facilities, and develop and deploy innovative service offerings, while setting price ceilings at reasonable levels. Individual companies retain an incentive to cut costs and to produce efficiently, because in the short run their behavior has no effect on the prices they are permitted to charge, and they are able to keep any additional profits resulting from reduced costs.” 14

Performance Comparisons Public Price Cap Companies versus Public and Private Rate or Return Carriers Focused on wireline voice activities only ILEC ROR company information from the JSI Peer Group of 150+ co’s 15

Price Cap versus ROR Monthly Total Regulated Voice Revenue Per Line Public Price CapPublic RORILEC ROR $53.58$57.42$

Price Cap versus ROR Monthly Regulated Local Revenue Per Line Public Price CapPublic RORILEC ROR NA$28.95$

Price Cap versus ROR Monthly Access/USF Revenue Per Line Public Price CapPublic RORILEC ROR NA$32.18$

Price Cap Versus ROR Monthly Cash Expense Per Line Public Price CapPublic RORILEC ROR $44.68$41.13$

Price Cap Versus ROR Annual Operating Margin/Amount Per Line Public Price CapPublic RORILEC ROR 20.25% $ % $ % $.10 20

Price Cap Versus ROR Monthly Cash Flow Per Line Public Price CapPublic RORILEC ROR $25.19$27.06$

Price Cap Versus ROR Cash Flow Margin Public Price CapPublic RORILEC ROR 36.60%40.27%34% 22

Price Cap Versus ROR CAPX Margins Public Price CapPublic RORILEC ROR 15.26%17.49%30.30% 23

Price Cap Versus ROR Monthly CAPX Per Voice Line Public Price CapPublic RORILEC ROR $10.27$12.24$

Price Cap Versus ROR Gross PPE per Line Public Price CapPublic RORILEC ROR $2,643$2,577$6,810 25

Why we do not Operate Under Price Caps (Historically) Lumpy investment Lack of true control of expenses Less predictable demand Lack of size, market density and diversification Need for higher regulated support 26

How Do We Change Change our Mind Set!! Carefully assess future capital investments Determine return expectations for every new product, service, and investment Become a sales driven company Continued to lessen reliance on regulated revenues 27

How Do We Change (cont’d) Be prepared to create “Haves and Have Not’s” Create realistic and viable business plans and follow them (update as required) Form Partnerships for operations and business development Evaluate mergers, acquisitions and consolidations 28

Organic growth Merger, consolidation and/or federation Acquire commercial and cooperative companies Vertical acquisitions Operational consolidations MERGERS, ACQUISITIONS, CONSOLIDATIONS AND PARTNERSHIPS - How Can You Achieve Scale 29

The Reality Many companies will never be able to transition to the performance levels of the current price cap structured companies, alone or as a larger group Some improvements can, and should, be made regardless Some level or regulated support will always be needed The goal is to Survive? Thrive? 30

Transition - Reasons for Success or Failure Take advantage of opportunities Use realistic expectations and assumptions in planning Ability to execute to plan Proper staffing and other resources Proper structure and capital resources Proper market and competitive analysis 31

Questions that Need to be Answered What actions can we take over the next 3-5 years to help ensure our survival? How do we meet the service expectations of our customers? How do we avoid being “the carrier of last resort”? 32

THANK YOU Leo Staurulakis