20070205_1832.pdf

DECISION MEMORANDUM
TO:COMMISSIONER KJELLANDER
COMMISSIONER SMITH
COMMISSIONER HANSEN
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL
WORKING FILE
FROM:CAROLEE HALL
DATE:FEBRUARY 7, 2007
RE:RURAL TELEPHONE COMPANY ("RURAL") REVISING ITS
OFF-PREMISE EXTENSION SERVICE TARIFF. TARIFF ADVICE
NUMBER 07-01.
BACKGROUND
On January 12, 2007, Rural Telephone filed its Tariff Advice Letter 07-01 seeking
Commission approval to revise its Off -Premise Extension Service Tariff. The new tariff adds
language to the conditions of continuous property that states
, "
the E-911 address will identify the
address of the main access line and not the location of the additional access point"
The Company also eliminates language under the conditions of the Off-Premise
Extension Service that provided for non-continuous property and the treatment of such service as
a line termination along ,with installation charges and monthly rates. Off-premise extension
service, according to the tariff, is where the extension is located in a different building on the
same continuous property as the main access line termination. Continuous property extensions
are defined as those where the drop to the additional access point comes directly from the
premises of the main access line termination and does not come out of the distribution cable.
When off-premise extension service is provided on Non-Continuous property, each location is
treated as an access line termination and the applicable access line rates apply at each location.
With this filing, the Company wishes to remove from its tariff its Non-Continuous
property extension service. According to the Company there currently there are no customers
subscribing to this service.
DECISION MEMORANDUM - 1 -FEBRUARY 7, 2007
The Company is proposing new language regarding Enhanced 911 (E-911) service. In its
letter the Company stresses that the additional language to its off-premise extension service now
provided a statement that the E-911 address will identify the address of the main access line and
not the location of the additional access point. This new language specifically states that
, "
The
property must be continuous and have the same E-911 address regardless of property
dimension! size
STAFF DISCUSSION
Staff contacted the Company s Consultant to inquire about the Company s ability to
provide E-911 service. Rural currently uses a Red Com Central Office Switch that does not have
the capability to provide Enhanced 911 ("91 I ") service. Enhanced 911 is an advanced form of
911 service where the telephone number of the caller is transmitted to the Public Safety
Answering Point ("PSAP") and it is cross-referenced with an address database to determine the
caller s location. That information is displayed on a video-monitor for the emergency dispatcher
to direct public safety personnel responding to the emergency. This enables police, fire
departments and ambulances to find callers who cannot orally provide their precise location.
The Company s consultant confirmed that the Company cannot provide E-911 and is
only providing Basic 911 service. Therefore, Staff asked the Company to remove references of
911 service offerings from its tariff filing and replace it with the actual 911 service that the
Company currently offers. The Company complied with this request and resubmitted its filing
on January 30 2007.
STAFF RECOMMENDATION
Because there are no customers currently subscribing to the Non-Continuous Property
service and there will be no revenue impact, Staff recommends approval of Rural's request to
remove that service from its tariff. With respect to the additional language addressing 911 , Staff
recommends approval, and strongly suggests that the Company begin investigating an upgrade to
its switch so that it can soon provide Enhanced 911 service. Given the rural service area served
by Rural Telephone, it would certainly be in the customer s safety and interest to have this
servIce.
Staff recommends approval of Rural Telephone s Advice Letter 07-01 with the revised
effective date of February 12 2007.
DECISION MEMORANDUM - 2 -FEBRUARY 7 2007
COMMISSION DECISION
Does the Commission wish to approve Rural Telephone s Tariff Advice Number 07-01 to
become effective on February 12, 2007?
chall/u/decision memo/Rural Telephone 07-01 Off-Prem Extension service and 911
DECISION MEMORANDUM - 3 -FEBRUARY 7, 2007