Docket Number	Docket Name	Company
UP 433	QWEST TRANSFER OF PROPERTY UNDER ORS 759.375	QWEST CORPORATION

Created Date	Comment Type	First Name	Last Name	Comment
4/15/2025 10:04:03 AM	Oppose Docket	Ashutosh	Patra	Dear Members of the Oregon Public Utility Commission, My name is Ashutosh Patra and I grew up in Portland, Oregon where our broadband options were CenturyLink or Comcast. I wanted to write to you today with objections I have to the proposed transaction in Docket Number “UP 433” called QWEST TRANSFER OF PROPERTY UNDER ORS 759.375. I believe this transaction is against the public interest as it will 1) materially increase the risk of bankruptcy of Qwest Corporation’s regulated ILEC business and 2) will reduce the already limited competition between Internet Service Providers. In particular, I disagree with the responses to questions (g) and (i) in Section II of the “INITIAL (APPLICATION, COMPLAINT, PETITION)” filed in the case. Please see below for the issues I have with the proposed transaction. I am happy to answer any questions you may have. Best, Ashutosh Patra Objection to Response in Section II(g) I believe this is incorrect and that this transaction materially impairs the ability of Qwest Corporation to fulfill its ILEC obligations and service its debt. While it is technically true that the internal reorganization does not affect the consolidated financials or debt obligations of Qwest Corporation, the newly created subsidiary, “49 Percent Qwest Sub 1, LLC”, recently gave a guarantee to ~$6.5 billion of debt that is owed to creditors by Lumen Corporation. This guarantee effectively allows Lumen Corporation creditors to recover value from the assets being transferred to the subsidiary ahead of preexisting creditors of Qwest Corporation. In other words, if the guarantee is called upon, the transferred assets will be used to pay off Lumen Corporation's creditors leaving fewer assets to support Qwest Corporation’s ILEC service and debt obligations which could lead to bankruptcy, service disruptions and/or reduced broadband investment. The guarantee could be called upon if either 1) the highly indebted Lumen were to file for bankruptcy or 2) Lumen were to sell the newly created subsidiary. This risk is no longer hypothetical as Bloomberg News reported that Lumen Corporation is in talks to sell their Consumer Fiber Business to AT&T on March 25th, 2025. The assets that Qwest Corporation is proposing to transfer to the new subsidiary appear to be the same assets they are discussing selling to AT&T. If the PUC were to allow the asset transfer to 49 Percent Qwest Sub 1, LLC, any proceeds from the sale to AT&T would first go to paying off creditors of Lumen Corporation effectively leaving Qwest Corporation with fewer assets and cash flows to support its ongoing ILEC and debt service obligations. In addition, Chris Stansbury, the CFO of Lumen recently spoke at a NewStreet Research Conference and told participants that selling the Consumer Fiber business “would mean that we walk away from a continued investment of a billion dollars a year in the consumer business" indicating the Company plans to stop investing in the ILEC after receiving approval for this transaction and selling the subsidiary. Objection to Response in Section II(l) As discussed above, I believe this transaction is against the public interest as it weakens the ability of Qwest Corporation to fulfill its ILEC and debt obligations as the transferred assets will be used to satisfy the obligations of Lumen Corporation (rather than Qwest Corporation). In addition, the only argument presented in favor of the proposed asset transfer is that the TSA Refinancing Transaction completed in March 2024 was beneficial to the public interest and that to gain creditors approval Lumen was required to “use its reasonable best efforts to cause Qwest to transfer 49% of its assets to Qwest Sub”. This was beneficial for Lumen Corporation but it was negative for Qwest Corporation which holds the regulated ILEC business that the Oregon PUC oversees as evidenced by Qwest Corporation’s bond prices collapsing upon rumors of the TSA (specifically on rumors of transferring assets out of Qwest). Regardless, the TSA only requires that Qwest Corp attempts to transfer 49% of its assets to the newly formed subsidiary, not that they ultimately receive approval from the PUC. There are no negative repercussions to Lumen or Qwest from not receiving regulatory approval of the proposed transfer therefore it is not in the public interest to approve the transfer. Particularly when such asset transfer will likely result in the assets being sold and Qwest Corp no longer investing in upgrading its copper footprint to fiber which is much needed across Oregon to close the digital divide.