STATEMENT OF FCC CPNI RULE COMPLIANCE This statement serves to explain how Valley Cable TV, Inc.

(the Company), FCC Form 4 Filer I! "#$ $, is complyin% with Fe&eral Comm'nications Commission (FCC) r'les relate& to the privacy o( c'stomer in(ormation. The type o( in(ormation (or which c'stomer privacy is protecte& by the FCC)s r'les is calle& c'stomer proprietary networ* in(ormation (C+,I). The FCC)s r'les restrictin% telecomm'nications company 'se o( C+,I are containe& at +art -4, .'bpart / o( the FCC)s r'les (4$ C.F.0. 1 -4.#2223#244). 1. Duty to Protect CPNI

5e reco%ni6e o'r &'ty to protect c'stomer C+,I. 5e may not &isclose C+,I to 'na'thori6e& persons, nor may we 'se C+,I in certain ways witho't consent (rom o'r c'stomers. 7e(ore we can provi&e c'stomers with their own C+,I, we m'st a'thenticate the c'stomer. 5e reco%ni6e that there are a (ew cases in which we can &isclose C+,I witho't (irst obtainin% c'stomer approval8 4) 9&ministrative 'se8 5e may 'se C+,I to initiate, ren&er, bill an& collect (or comm'nications services. #) +rotection o( carrier an& thir& parties8 5e may 'se C+,I to protect the interests o( o'r company, s'ch as to prevent (ra'& or ille%al 'se o( o'r systems an& networ*. :mployees are noti(ie& o( the steps to ta*e, i( any, in these sorts o( sit'ations. ;) 9s re<'ire& by law8 5e may &isclose C+,I i( we are re<'ire& to by law, s'ch as thro'%h le%al process (s'bpoenas) or in response to re<'ests by law en(orcement. :mployees are noti(ie& o( any steps they m'st ta*e in these sit'ations. 2. Our Use of CPNI in Mar etin!

The Company &oes not 'se C+,I (or mar*etin% p'rposes except in the (ollowin% circ'mstances8 4) to mar*et services to o'r existin% c'stomers within the cate%ories o( service to which the c'stomer alrea&y s'bscribes= #) to mar*et a&>'nct3to3basic services= an& ;) to provi&e C+: an& call answerin%, voice mail or messa%in%, voice stora%e an& retrieval services, (ax store an& (orwar&, an& protocol conversion. For mar*etin% p'rposes (or which 'se o( C+,I wo'l& otherwise re<'ire permission (rom the C'stomers, the Company 'ses only C'stomer billin% name an& a&&ress an&?or telephone n'mber witho't any se%re%ation or re(inement base& on C+,I. @n inbo'n& an& a&ministrative calls, however, the Company may 'tili6e C+,I in its sales an& mar*etin% e((orts by (irst re<'estin% permission to &o so p'rs'ant to 1-4.#22"((). In 4

those cases, the Company reco%ni6es that permission to 'se C+,I en&s when the call terminates an& the C'stomer is ('lly in(orme& that he may re('se the permission. 5e re%'larly review o'r mar*etin% practices to &etermine when, how an& i( C+,I is 'se& within the Company to ins're that we remain in compliance with the FCC)s C+,I re%'lations an& with o'r policy as &escribe& here in. In the 'nli*ely event that Company &eci&es to mo&i(y its policies (or 'se o( C+,I, it will ins're that its new policy ('lly complies with FCC C+,I r'les incl'&in%, b't not limite& to, trac*in% an& C'stomer notice provisions containe& in 1-4.#22"3#22 . ". Aut#entication Prior to Disc$osure of CPNI

5e 'n&erstan& that we are re<'ire& to &etermine that any re<'est (or C+,I will not be release& witho't a'thenticatin% the a'thority o( the re<'estor to receive s'ch in(ormation. 5e 'n&erstan& that when a c'stomer calls, we may not release C+,I 'ntil we have a'thenticate& the release o( the in(ormation to the re<'estor in one o( the (ollowin% ways8 4) 7y callin% the c'stomer bac* at the telephone n'mber associate& with the comm'nications service= #) 7y mailin% the in(ormation to the a&&ress o( recor&= ;) 7y releasin% it in person (ollowin% a'thentication via a vali& %overnment3 iss'e& photo i&enti(ication at o'r o((ice= 4) For those c'stomers who have chosen to &o so, over the phone (ollowin% the &isclos're o( a passwor&. %. E&'$oyee Issues

9ll o( o'r employees were traine& re%ar&in% the company)s C+,I policies prior to the e((ective &ate o( the most recent C+,I re%'lations, !ecember ", #22$. To maintain compliance with FCC r'les a(ter !ecember ", #22$, the Company establishe& proce&'res an& traine& employees havin% access to, or occasion to 'se c'stomer &ata, to i&enti(y what c'stomer in(ormation is C+,I consistent with the &e(inition o( C+,I 'n&er the FCC)s revise& C+,I r'les. The Company has implemente& a trainin% proce&'re (or all new hires an& contractors re%ar&in% the Company)s practices re%ar&in% C+,I. In a&&ition, the Company has in place an express &isciplinary process to a&&ress any 'na'thori6e& 'se o( C+,I where the circ'mstances in&icate a'thori6ation is re<'ire& 'n&er the FCC)s C+,I r'les.

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Notifications to Custo&ers

5e provi&e a C+,I privacy policy to all c'stomers ann'ally. This policy incl'&es o'r &'ty to protect their C+,I an& a statement that we &o not &isclose C+,I to any thir& parties or 'se C+,I witho't their express permission to &o so. 5e also in(orm them o( o'r re<'irements (or a'thenticatin% them prior to &isclosin% C+,I to them in any way. 5e noti(y c'stomers when chan%es have been ma&e to passwor&s, c'stomer responses to bac*3'p means o( a'thentication (i( implemente&), a&&resses o( recor& an& a'thori6e& 'sers by mailin% a noti(ication to the acco'nt a&&ress o( recor&. The notice &oes not contain in(ormation re%ar&in% the chan%es. ). Recor*+,ee'in! 5e maintain the (ollowin% recor&s in o'r (iles (or at least two years8 4) 0ecor&s relatin% to the ann'al mailin% o( the c'stomer C+,I privacy policy= #) :mployee &isciplinary recor&s, i( applicable= an& ;) I( applicable8 i) recor&s o( &iscovere& C+,I breaches= ii) noti(ications to law en(orcement re%ar&in% breaches= an& iii) any responses (rom law en(orcement re%ar&in% those breaches. -. Unaut#ori.e* Disc$osure Of CPNI

5e 'n&erstan& that we m'st report C+,I breaches to law en(orcement no later than seven ($) b'siness &ays a(ter &eterminin% the breach has occ'rre&, by sen&in% electronic noti(ication thro'%h the lin* at http8??www.(cc.%ov?eb?C+,I? to the central reportin% (acility, which will then noti(y the /nite& .tates .ecret .ervice (/...) an& the Fe&eral 7'rea' o( Investi%ation (F7I). 5e 'n&erstan& that we may not noti(y c'stomers or the p'blic o( the breach earlier than seven ($) &ays a(ter we have noti(ie& law en(orcement thro'%h the central reportin% (acility. I( we wish to noti(y c'stomers or the p'blic imme&iately, where we (eel that there is an extraor&inarily 'r%ent nee& to noti(y to avoi& imme&iate an& irreparable harm, we in(orm law en(orcement o( o'r &esire to noti(y an& comply with law en(orcement)s &irections. !'rin% the co'rse o( the year, we compile in(ormation re%ar&in% pretexter attempts to %ain improper access to C+,I, incl'&in% any breaches or attempte& breaches. 5e incl'&e this in(ormation in o'r ann'al C+,I compliance certi(ication (ile& with the FCC.