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Competitive Cable & VideoServices Act MinorityOwned BusinessParticipation Plan Reportfor 2016TENNESSEE PUBLIC UTILITY COMMISSIONAUGUST 2017

Table of ContentsBackgroundAnnual Review23AppendicesAppendix 1: AT&TAppendix 2: Charter CommunicationsAppendix 3: KnologyAppendix 4: Cable OneAppendix 5: Highland Telephone Cooperative, Inc.Appendix 6: ComcastAppendix 7: Electric Power Board of ChattanoogaAppendix 8: Twin Lakes Communications, Inc.Appendix 9: North Central Telephone CooperativeAppendix 10: TDS Telecom Service CorporationAppendix 11: Spring City Cable TV, Inc.Appendix 12: United CommunicationsAppendix 13: West Kentucky Rural Telephone CooperativeAppendix 14: Millington CATVAppendix 15: Community Television CompanyAppendix 16: InfoStructure Inc. d/b/a Click1.NetAppendix 17: Google FiberAppendix 18: Trenton TVAppendix 19: Crystal Clear Technologies

BackgroundPublic Chapter 932 of 2008, known as the Competitive Cable and Video Services Act,(“CCSVA”), became law on July 1, 2008 and is codified as Tenn. Code Ann. § 7-59-102through § 7-59-318. The CCSVA opened markets for cable and video services to competitionby allowing providers to receive state-issued certificates of franchise authority. Applicantsmust provide a plan to facilitate the participation of minority owned businesses whenestablishing, providing or expanding cable or video services and related support facilitiespursuant to § 7-59-313(c). 1 Tenn. Code Ann. § 7-59-313(a)(1) defines a minority ownedbusiness as: a business that is solely owned, or at least fifty-one percent (51%) of theassets or outstanding stock of which is owned, by an individual who personallymanages and controls the daily operations of the business and who is impededfrom normal entry into the economic mainstream because of:(A) Past practices of discrimination based on race, religion, ethnic backgroundor sex, including, but not limited to, women;(B) A disability as defined in § 4-26-102, including, but not limited to, disabledveterans; or(C) Past practices of racial discrimination against African-Americans.Tenn. Code Ann. § 7-59-313(a)(2) defines a minority owned business plan as: a business plan for actively soliciting bids from minority owned businesses andletting contracts to such businesses when establishing, providing or expandingcable or video services and related support facilities. The plan shall include thefollowing information:(A) A proposal for purchasing goods and services from minority ownedbusinesses;(B) Information on programs to provide technical assistance to such businesses;and(C) A statement of intent to follow its minority owned business participation plan.The goals of a minority owned business participation plan are “ to maximize participation ofminority owned businesses through both prime and second tier business contractingopportunities and shall strive to achieve a level of minority owned business participationrepresentative of the population demographics of this state.” 21Tenn. Code Ann. § 7-59-313(c) states, “Notwithstanding any provision of this part to the contrary, a state-issuedcertificate of franchise authority shall not be issued by the department to any applicant that fails to include aminority owned business participation plan in the applicant’s application. The department shall review eachapplication to confirm that the minority owned business participation plan includes all information requiredpursuant to this section.”2Tenn. Code Ann. § 7-59-313(b).2

Annual ReviewTenn. Code Ann. § 7-59-313(d) requires the Tennessee Public Utility Commission to conductan annual review of the plans:Notwithstanding any provision of this part to the contrary, the department shallannually review each holder of a state-issued certificate of franchise authority todetermine compliance with the holder's minority owned business participationplan. In conjunction with the review, by January 31 of each year, each holder of astate-issued certificate of franchise authority shall prepare and submit an annualreport to the department concerning the holder's minority owned businessparticipation plan and compliance with the plan. The department shall annuallyprepare a compliance report to be delivered to the governor and the clerks of thesenate and the house of representatives. The compliance report shall also beposted on the web site of the department. 3By the end of 2016, the Tennessee Public Utility Commission had granted nineteen stateissued certificates of franchise authority. Each franchise holder has submitted its reportconcerning its small and minority owned business participation plan. Below are somehighlights.1. BellSouth Telecommunications, Inc. d/b/a AT&T Tennessee provided a copy of its Smalland Minority Owned Business Plan.2. Charter Communications submitted a copy of its Minority Vendor outreach program,which includes a qualifying form sent to 439 vendors, 97 of which met Minority status.Charter also supplied a letter that it is sending to certified Minority vendors that wassupplied by the Tennessee Department of Economic & Community Development.3. Knology spent approximately 29,000 during 2015 with ten minority-owned Tennesseevendors.4. Cable One indicates that it spent a total of 10,225 with five minority-owned vendors inTennessee.5. Highland Telephone Cooperative provided a copy of its Minority Owned BusinessParticipation Plan and indicated that its plan continues in force and effect as a policy ofthe Cooperative.6. Comcast indicated that it continues to comply with its plan and notes that it spent 14.4%of its total supplier expenditures with diverse vendors.7. The Electric Power Board of Chattanooga (“EPB”) indicated that its Fiber Optics Divisionconducted business with eleven minority-owned Tennessee companies and spent inexcess of 1.5 million with these companies.8. Twin Lakes Communications, Inc. stated that it continues to comply with its MinorityOwned Telecommunications Business Participation Plan, a copy of which it submittedwith its response.9. North Central Telephone Cooperative stated that it continues to adhere to the MinorityOwned Business Participation Plan.3Tenn. Code Ann. § 7-59-313(d).3

10. TDS Telecom Service Corporation submitted a copy of the Minority-Owned BusinessParticipation Plan.11. Spring City Cable TV, Inc. submitted a copy of the Minority-Owned BusinessParticipation Plan.12. United Communications submitted a copy of its Minority-Owned Business ParticipationPlan and indicated that there were no changes to the plan in 2016.13. West Kentucky Rural Telephone Cooperative Corporation submitted a copy of itsMinority- Owned Business Participation Plan.14. Millington CATV (“MCATV”) indicated that it will continue to comply with its MinorityOwned Business Participation Plan and look for ways to increase its contacts andpartnerships with Minority- Owned suppliers. MCATV stated that is paid minority-ownedbusinesses approximately 30,000 in 2016.15. Community Television Company (“CTC”) stated that it implemented the Minority-OwnedBusiness Participation Plan included in its application for a state issued certificate offranchise authority. CTC stated that it is in compliance with the plan.16. InfoStructure Inc. supplied a letter that it is sending to certified Minority vendors that wassupplied by the Tennessee Department of Economic & Community Development.17. Google Fiber stated that it continues to comply with the Minority-Owned BusinessParticipation Plan.18. Trenton TV Cable Company stated that it continues to comply with its Minority-OwnedBusiness Participation Plan.19. Crystal Clear Technologies stated that its Minority-Owned Business Participation Plan isin effect as the policy of the company.4

Appendix 1AT&T2016 Minority Owned Business Participation Plan Report

Appendix 2Charter Communications2016 Minority Owned Business Participation Plan Report

Appendix 3Knology2016 Minority Owned Business Participation Plan Report

Appendix 4Cable One2016 Minority Owned Business Participation Plan Report

Appendix 5Highland Telephone Cooperative2016 Minority Owned Business Participation Plan Report

7840 Morgan County Hwy.P.O. Box 119Sunbright, TN [email protected] 423/628 2121423/663 3939606/376 5311Fax423/628 2409January 19, 2017Mr. Jerry KettlesTennessee Regulatory Authority502 Deaderick Street, Fourth FloorNashville, TN 37243RE:Response of Highland Telephone Cooperative, Inc.Minority Owned Business Participation PlanDear Mr. Kettles:Please find enclosed the Minority Owned Business Participation Plan previouslyestablished by Highland Telephone Cooperative, Inc. This Plan was enacted to conformto the requirements of Tennessee Code Annotated 7-59-301 through 7-59-318 in 2009and continues in force and effect as a policy of the Cooperative.If you have any questions, please do not hesitate to contact me.Sincerely,HIGHLAND TELEPHONE COOPERATIVE, INC.itm{ General ManagerGMP/sljEnclosureThis institution is an equal opportunity provider and employer.

EXHIBIT BHIGHLAND TELEPHONE COOPERATIVE, INC.MINORITY OWNED BUSINESS PARTICIPATION PLANPursuant to Section 313 of the Tennessee Competitive Cable and Video Services Act("Act"), Tenn. Code Ann. §7-59-313, Highland Telephone Cooperative, Inc. ("Highland")submits this Minority Owned Business Participation Plan ("Plan") as an exhibit to itsApplication for a State-Issued Certificate of Franchising Authority ("Application").I. OBJECTIVESHighland is committed to the objectives stated in Section 313 of the Act with respect tominority-owned business participation. Highland will endeavor to promote participation ofminority-owned businesses through business contracting opportunities. In addition, Highlandwill attempt to identify and inform minority-owned businesses that are qualified and capable ofproviding goods and services to Highland of such opportunities.II. DEFINITIONSFor the purposes of this Plan, the following terms shall have the following meanings:A. "Minority-Owned Business" means a business that is solely owned, or at least fiftyone percent (51 % ) of the assets or outstanding stock of which is owned, by anindividual who personally manages and controls the daily operations of such businessand who is impeded from normal entry into the economic mainstream because of:1. Past practices of discrimination based on race, religion, ethnic background, orsex including, but not limited to, women;2. A disability as defined in Tenn. Code Ann. §4-26-102 including, but notlimited to, disabled veterans; or3. Past practices ofracial discrimination against African-Americans.B. "Minority-Owned Business Participation Plan" means a business plan for activelysoliciting bids from minority-owned businesses and letting contracts to suchbusinesses when establishing, providing or expanding cable or video services andrelated support facilities. Such plan shall include the following information:1. A proposal for purchasing goods and services from ilesxp/High/Tennessee Regulatory Authority Minority Business Plan 2017 (00013139).doc- 1-

2. Information on programs to provide technical assistance to such businesses;and3. A statement of intent to follow its minority-owned business participation plan.III.ADMINISTRATIONThe Plan will be overseen by the individual named below, hereinafter referred to as theAdministrator. The Administrator of the Plan will be:G. Mark PattersonGeneral ManagerHighland Telephone Cooperative, Inc.7840 Morgan County HighwayP.O. Box119Sunbright, TN 37872The Administrator' s responsibilities will include:1. Maintaining and updating the Plan in full compliance with Section 313 of the Actand the rules and orders of the Tennessee Regulatory Authority ("TRA").2. Ensuring that policies and procedures necessary for the successful implementationof the Plan are in place.3. Preparing and submitting such forms as may be required by the TRA, includingthe filing of required annual updates.4. Serving as the primary liaison with the TRA, other applicable agencies of theState of Tennessee, and minority-owned businesses.5. Monitoring opportunities to use minority-owned businesses and encouragequalified minority-owned businesses to participate in and bid on contracts andsubcontracts.6. Managing a record keeping system to track qualified minority-owned businessesand efforts to engage such businesses.7. Overseeing informational and educational activities within and outside Highlandto identify, encourage and promote the use of minority-owned nnessee Regulatory Authority Minority Business Plan 2017 (00013139).doc-2-

In performance of such duties, the Administrator will utilize a number of resources,including, but not limited to, the following:Chambers of CommerceTennessee Department of Economics and Community DevelopmentTennessee Department of Labor and Workforce DevelopmentSmall Business Administration, Office of Women's Business OwnershipTennessee Minority Supplier Development CouncilNational Association of Minority Contractors, Memphis, TNNational Association of Women Business Owners, Nashville, TNHighland will maintain records of qualified minority-owned businesses and efforts to usethe goods and services of such businesses. In addition, Highland will maintain records ofinformational and educational activities with respect to minority-owned businesses. Highlandwill submit a report to the TRA by January 31 of each year concerning Highland's minorityowned business participation plan and its compliance with such plan. Highland will cooperatefully with any additional informational requests by the TRA. Finally, it is Highland' s intent tofollow the Plan as described herein.HIGHLAND TELEPHONE COOPERATIVE, INC.By:Jiai,!b - -a-g-erDate:/ -- f9-f )/Volumes/home/sandra/Sanfilesxp/High/Tennessee Regulatory Authority Minority Business Plan 2017 (00013139).doc-3-

Appendix 6Comcast2016 Minority Owned Business Participation Plan Report

Appendix 7Electric Power Board of Chattanooga2016 Minority Owned Business Participation Plan Report

2016 Annual ReportMinority Business Participation Plan ComplianceCompetitive Cable and Video Services ActP.O. Box 182255Chattanooga, TN 37422

EPB is proud to support minority and women owned companies within the Tennesseearea for many years. EPB’s purchasing policy is committed to supporting minority andwomen-owned businesses and has developed a Minority and Women Owned BusinessDevelopment Program (“MWOB”). This program has five (5) key objectives:1. Identify goods and services for which minority and women owned businesses havethe capability of becoming a source of supply;2. Seeking out minority and women owned businesses capable of supplying goodsand services for EPB’s operations;3. Using minority and women owned business whenever possible in order to increasethe volume of expenditures into the minority business community;4. Nurturing minority and women owned businesses and help them to becomecompetitive, viable and self-sustaining enterprises; and5. Foster relationships within the minority and women owned business community.EPB has designated Michael Jones, Senior Manager, to oversee its Minority and WomenOwned Business Development Program. Our MWOB Senior Manager works closely withthe Purchasing Department and members of leadership to ensure the continued successof the program.In 2016, EPB’s Fiber Optics Division conducted business with eleven (11) minority ownedcompanies in Tennessee and spent in excess of 1,525,815.53 with these companies.Additionally, EPB participated in outreach to continue developing and buildingrelationships with minority and women owned businesses. These outreach effortsincluded: Hosting a number of M&WOB networking events at EPB throughout 2016;Continued partnerships with CACC, AABD Board, City of Chattanooga Multi-CulturalDevelopment Department and Chattanooga Minority Connection Group toencourage minority and women-owned businesses to bid on EPB projects;Participation by EPB’s Minority Business Manager and Purchasing Manager indevelopment events hosted by the TVA, Erlanger, Volkswagen Expo and AABENational for vendors of M&WO businesses.As always, EPB Fiber Optics will continue to seek out qualified minority and women ownedbusinesses to supply products and services through EPB’s purchasing policy andcommitted to increase opportunities for minority and women owned businesses goingforward.

Appendix 8Twin Lakes Communications, Inc.2016 Minority Owned Business Participation Plan Report

January 10, 2017Tennessee Regulatory AuthorityAttn: Jerry Kettles-460 Jttffies Robertson Parkway 6-t!J2Nashville, Tennessee 37243J't{Ct (,.ft.,Dear Mr. Kettles:In Re: Minority Owned Business Plan Annual ReportAs required in the Competitive Cable & Video Services Act, Twin LakesCommunications provides this annual report concerning Twin Lakes Communications' MinorityOwned Business Plan and its compliance with that plan. The Plan, which was provided as part ofTwin Lakes Communications' franchise application is attached.Twin Lakes Communications continues to comply with the Minority OwnedBusiness Plan.If you have any questions or concerns, please do not hesitate to contact me.Very truly yours,TWIN LAKES COMMUNICATIONS, INC.a IJ t:: anWest,General Manager/CEOJW/efAttachment as stated931 -476-2151P.O. Box 696Gainesboro, TN 38562-0696www.twlakes.coop

SMALL AND MINORITY-OWNED TELECOMMUNICATIONSBUSINESS PARTICIPATION PLANPursuant to T.C.A. §65-5-112, as amended, Twin Lakes Communications, Inc. ("TwinLakes Communications;') submits this small and minority-owned Telecommunications businessparticipation plan (the ''Plan").I.PURPOSEThe purpose of §65·5-112 is to provide opportunities for small and minority-ownedbusinesses to provide goods and services to Telecommunications service providers. Twin LakesCommunications is committed to the goals of §65-5-112 and to taking steps to support theparticipationofsmallandTelecommunications sintheTwin Lakes Communications will endeavor to provideopportunities for small and minority-owned Telecommunications businesses to compete forcontracts and subcontracts for goods and services. As part of its procurement process, TwinLakes Communications will mal (e efforts to identify and inform minority-owned and smallbusinesses that are qualified and capable of providing goods and services to Twin LakesCommunications of such opportunities.Twin Lakes Communications' representatives havealready contacted the Department of Economic and Community Development and theadministrator of the Small and Minority-O'wned Telecommunications Assistance Program, toobtain a list of qualified vendors. Moreover, Twin Lakes Communications will seek to increaseawareness of such opportunities so that companies not otherwise identified will have sufficientinformation to participate in the procurement process.II.DEFINITIONSAs defined in §65-5-112.24327607v1

Minority-Owned Business. Minority-owned business shall mean a business which issolely owned, or at lease fifty-one percent (51 %) of the assets or outstanding stock of which isowned, by an individual who personally manages and controls daily operations of suchb iness,and who is impeded frotn nonna1 entry into the economic mainstream because of race, religion,sex or national origin and such business has annual gross receipts of less than four million dollars( 4,000,000).Small Business. Small Business shall mean a business with annual gross receipts of lessthan four million dollars ( 4,000,000).III.ADMINISTRATIONTwin Lakes Communications' Plan will be overseen and administered by the individualnamed below, hereinafter referred to as the Administrator, who will be responsible for carryingout and promoting Twin Lakes Communications' full efforts to provide equal opportunities forsmall and minority-owned businesses. The Administrator of the Plan will be:Jonathan WestTwin Lakes Communications, Inc.200 Telephone LaneGalnesboro, Tennessee 38562Telephone:(931) 268-2151Facsimile:(931) 268-2734The Administrator's responsibilities will in.:lude:(1)Maintaining an updated Plan in full compliance with §65-5-112 and the rules andorders of the Tennessee Regulatory Authority.(2)Establishing and developing policies and procedures necessary for the successfulimplementation of the Plan.224327607v1

The National Association of Minority ContractorsHistorically Black Colleges, Universities, and Minority InstitutionsThe efforts to promote and ensure equal opportunities for small and minority-owned businesses areprimarily spelled out in the Administrator' s duties above. Additional efforts to provide opportunities tosmall and minority-owned businesses will include offering, where appropriate and feasible, small andminority-owned businesses assistance with technical, insurance, bonding, licensing, production, anddeadline requirements.IV.RECORDS AND COMPLIANCE REPORTSTwin Lakes Communications will maintain records of qualified small and minority-ownedbusiness and efforts to use the goods and services of such businesses. In addition, Twin LakesCommunications will maintain records of educational and training activities conducted or attended and ofthe internal procurement procedures adopted to support this plan. Twin Lakes Communications willsubmit records and reports required by the Tennessee Regulatory Authority concerning the Plan .Moreover, Twin Lakes Communications will cooperate fully with any surveys and studies required by theTennessee Regulatory Authority.Twin Lakes Communications, Inc.Dated:,?// -/0- Jl424327830vl

Appendix 9North Central Telephone Cooperative2016 Minority Owned Business Participation Plan Report

Appendix 10TDS Telecom Service Corporation2016 Minority Owned Business Participation Plan Report

TDS Telecom Service Corporation – TennesseeJanuary 2017MINORITY-OWNEDBUSINESS PARTICIPATION PLAN1

MINORITY-OWNEDBUSINESS PARTICIPATION PLANTABLE OF CONTENTS1.0 PURPOSE2.0 DEFINITIONS3.0 PLAN RESPONSIBILITY4.0 PLAN PERIOD5.0 PLAN ADMINSTRATION6.0 PLAN TO ENSURE EQUITABLE OPPORTUNITY7.0 PLAN REPORTING2

MINORITY – OWNED BUSINESSPARTICPATION PLAN1.02.0PLAN1.1This Minority –Owned Business Participation Plan (“Plan”) is submitted by TDSTelecom (“TDS” as required by the Competitive Cable & Video Service Act of2008, codified as T.C.A 7-59-3131.2The Administration of this Plan is the responsibility of TDS. It is the policy ofTDS to provide an opportunity for Minority Owned Businesses to compete forsubcontracts awarded by TDS on a fair and equitable basis with certified suppliersand contractors.1.3This plan is a state of objectives and is not intended to create any legal obligationof TDS of any person or organization.DEFINITIONS2.13.0Minority Business – For the purpose of this Plan, “minority business” means abusiness that is solely owned, or at least fifty-one (51%) of the assets oroutstanding stock of which is owned by an individual who personally managesand controls the daily operations of such business, and who is impeded from nonentry into the economic mainstream per T.C.A 7-59-313(1)(A-C)PLAN RESPONSIBILITY AND POLICY STATEMENT3.1It is the policy of TDS to afford Minority –Owned Businesses an opportunity toparticipate in the performance of contracts in accordance with T.C.A 7-59-313(b).3.2As a purchaser of goods and services, it is TDS – responsibility to:-Identify and maintain a pool of qualified suppliers-Provide opportunities for Minority Owned Businesses to bid in those solicitations forproducts or services which they are capable of providing, and which meet RUS(Rural Utility Service) standards.3

4.0PLAN PERIOD OF EFFECTIVENESS4.1TDS is committed to providing affirmative access to contracting opportunities forMinority-Owned Businesses. TDS is proactive and will move toward inclusion of suchfirms in the supplier base. This plan represents an on-going commitment by theCompany, and has no fixed time period for effectiveness.5.0PLAN ADMINSTRATION5.1TDS Plan Administrator is:Mr. Jon FinsethManager – Procurement525 Junction RoadMadison, WI 53717Telephone: 608-664-4067FAX: 608-664-45195.2The Administrator manages the Plan as described below.5.3The Administrator’s specific job duties, as they related to this Plan are as follows:(a) Develops and maintains policies and procedures to ensure that Minority-OwnedBusinesses have an equitable opportunity to be awarded contracts.(b) Establishes and maintains policies and procedures to ensure that Minority-OwnedBusinesses have an equitable opportunity to be awarded contracts.(c) Ensures inclusion of Minority – Owned Businesses in those solicitations for productsor services which they are capable of providing, and which meet Unites StatesDepartment of Agriculture Rural Utility Service (RUS) standards.(d) Maintains Minority – Owned Businesses related correspondence and record keeping.(e) Coordinates activities during the conduct of any compliance review by the Tennesseestate agencies.(f) Attends or arranges for attendance by appropriate members of management at,Minority Business Enterprise Seminars, Trade Fairs, and Conventions.4

6.0PLAN TO ASSURE EQUITABLE OPPORTUNITY6.1The Administrator shall ensure that appropriate source listings and services areproperly utilized in support of the Plan. Sources / listings include, but are not limitedto the following:(a) The TDS approved Master Supplier list.(b) Information received from the Small Business Administration ProcurementAutomated Source System (PASS).(c) Information sources received from the TN Department of EconomicDevelopment’s Office of Minority Business Enterprise and Small BusinessOffice.(d) Information received from the local Chamber of Commerce.6.2Outreach efforts will be made as follows:(a) The Administrator shall cultivate and maintain relationships with Small Businesstrade associations and business development organizations in an effort to locateand qualify capable Minority – Owned Businesses for participation in contractingopportunities.(b) The Administrator shall ensure that TDS assists Minority – Owned Businesses byarranging solicitations, time for the preparation of bids, quantities, specifications,and delivery schedules so as to facilitate the participation by such concerns.(c) The Administrator shall ensure that TDS provides adequate and timelyconsideration of the potentialities of Minority – Owned Businesses in “make orbuy” decisions.(d) Appropriate members of management will attend seminars and trade fairs in orderto develop sources.5

7.0PLAN REPORTING7.1TDS will submit such periodic reports and cooperate in those studies or surveysas may be required to determine the extent of compliance with this Plan.7.2TDS will maintain, if required, the following types of records:(a) Source lists, guides, and other data that identify Minority-Owned Businesses.(b) Lists of organizations contacted in an attempt to locate sources that are Minority Owned Businesses.(c) Records of any outreach efforts to contact trade associations, business developmentorganizations, and conferences and trade fairs attended.7.3TDS’s Supplier Master List identifies Minority-Owned Businesses. The SupplierList shall be utilized in identifying potential contractors. A Summary Sheet shall bemaintained in each suppliers file and shall be reviewed and evaluated by the PlanAdministrator.6

TDS TelecomHumphreys County Telephone CompanySMALL AND MINORITY-OWNED TELECOMMUNICATIONSBUSINESS PARTICIPATION PLANSUBMITTED TO THETENNESSEE REGULATORY AUTHORITYJanuary 30, 20171

SMALL AND MINORITY-OWNED TELECOMMUNICATIONS BUSINESSPARTICIPATION PLANTABLE OF CONTENTS1.0 PURPOSE2.0 DEFINITIONS3.0 PLAN RESPONSIBILITY AND POLICY STATEMENT4.0 PLAN PERIOD5.0 PLAN ADMINISTRATION6.0 PLAN TO ENSURE EQUITABLE OPPORTUNITY7.0 PLAN REPORTING2

SMALL AND MINORITY-OWNED TELECOMMUNICATIONS BUSINESSPARTICIPATION PLAN1.0 PLAN1.1 This small and minority-owned telecommunications business participation plan (Plan) issubmitted by TDS Telecom as required by Section 16 of the Tennessee Telecommunications Actof 1995, now codified as T.C.A. § 65-5-212.1.2 The Administration of this Plan is the responsibility of TDS Telecom. It is the policy of TDSTelecom to provide an opportunity for Small Business, and Minority-Owned Businesses tocompete for subcontracts awarded by TDS Telecom on a fair and equitable basis with certifiedtelecommunications suppliers and contractors.1.3 This plan is a statement of objectives and is not intended to create any legal obligation ofTDS Telecom to any person or organization.2.0 DEFINITIONS2.1 Small Business - For the purpose of this Plan, "small business" means a business withannual gross receipts of less than four million dollars ( 4,000,000) per T.C.A. &65-5-212.2.2 Minority Business - For the purpose of this Plan, "minority business" means a businessthat is solely owned, or at least fifty-one (51%) of the assets or outstanding stock of which isowned by an individual who personally manages and controls the daily operations of suchbusiness, and who is impeded from non entry into the economic mainstream because of race,religion, sex or national origin and such business has annual gross receipts of less than fourmillion dollars ( 4,000,000) per T.C.A.&65-5-2123

3.0 PLAN RESPONSIBILITY AND POLICY STATEMENT3.1 It is the policy of TDS Telecom to afford Small and Minority-OwnedTelecommunications Businesses an opportunity to participate in the performance ofcontracts in accordance with T.C.A. 665- 5-212.3.2 As a purchaser of goods and services, it is TDS Telecom –responsibility to:-Identify and maintain a pool of qualified Telecommunications suppliers. -Provideopportunities for Small and Minority Owned Businesses to bid in thosesolicitations for telecommunications products or services which they are capableof providing, and which meet RUS

and Minority Owned Business Plan. 2. Charter Communications submitted a copy of its Minority Vendor outreach program, which includes a qualifying form sent to 439 vendors, 97 of which met Minority status.