20070123Application.pdf

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Molly O'Leary
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molly~richardsonandoleary.com
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O. Box 7218 Boise, ID 83707 - 515 N. 27rh Sr. Boise, 10 83702
22 January 2007 E.i)G-l-C"O (
Ms. Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
POBox 83720
Boise ID 83720-0074
Hand Delivered
RE: Edge Wireless, LLC Application for ETC Designation
Dear Ms. Jewell:
I am enclosing an original and seven (7) copies of Edge Wireless, LLC'
APPLICATION FOR DESIGNATION AS AN ELIGIBLE
TELECO MMUNI CA TI 0 NS CARRIER.
Also enclosed is a copy to be date stamped and retumed for our files.
Please note the enclosed Application contains confidential trade secret
information that is exempt from public disclosure pursuant to Section 9-
340D(1), Idaho Code. Pursuant to Rule 67 of the Rules of Procedure of the
Idaho Public Utilities Commission , the enclosed trade secret information has
been submitted on yellow paper and has been separated from the non-
confidential portion of the Application.
Enclosures
Molly O'Leary (ISB # 4996)
Richardson & O'Leary, P.LLC.
O. Box 7218
Boise, ID 83707
Tel: [phone]
Fax: [phone]
mo 11 yCfYrichardsonando leary. com
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Mark P. Trinchero, OSB #88322
1300 S.W. 5th Avenue, Suite 2300
Portland, Oregon 97201
Tel: [phone]
Fax: [phone]
marktrinch ero CfYd wt. com
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF EDGE WIRELESS, LLC
FOR DESIGNATION AS AN ELIGIBLE
TELECO MMUNI CA TI 0 NS CARRIER
PURSU ANT TO THE
TELECOMMUNICATIONS ACT OF 1996
(RURAL AND NON-RURAL AREAS)
Case No. E:t)S..::-r-ory-o(
APPLICATION OF EDGE WIRELESS. LLC FOR DESIGNATION AS AN ELIGIBLE
TELECOMMUNICATIONS CARRIER (RURAL AND NON-RURAL AREAS)
Edge Wireless, LLC ("Edge ), by its attorneys, hereby submits this Application for
Designation as an Eligible Telecommunications Carrier ("ETC") pursuant to Sections 214(e)(1)-
(2) of the Telecommunications Act of1934, as amended ("Act"), 47 U.c. 9214(e)(1)-(2), and
Section 54.201 of the Federal Communications Commission s ("FCC") rules, 47 C.R. 9
54.201 , and this Commission s ETC Designation Requirements ("IPUC ETC Requirements ). 1
See In the Matter of the Application ofWWC Holding Co., Inc. dba CeliularOne Seeking
Designation as an Eligible Telecommunications Carrier That May Receive Federal Universal
Service Support, Order No. 29841 , Appendix pp. 1-3 (IPUC Case No. WST-05-, served
August 4, 2005)(hereinafter IPUC ETC Requirements Order
EDGE WIRELESS ETC. APPLICA nON
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Edge requests that it be designated as eligible to receive all available support from the federal
Universal Service Fund ("USF") including, but not limited to, support for rural, insular and high
cost areas and low income customers in the geographic areas specified in this Application and
that it be approved to participate in the Lifeline program. In support of this Application, the
following is respectfully shown:
APPLICANT
Edge is a Commercial Mobile Radio Service ("CMRS") carrier providing
mobileservice" as defined in 47 U.C. 9 153(27). Edge provides interstate telecommunications
services as defined in 47 U.C. 9 254(d) and 47 C.R. 9 54.703(a). Through its cellular
authorizations, Edge is licensed to serve the following Basic Trading Areas ("BT As ) in Idaho:
BTA 202 Idaho Falls, BTA 353 Pocatello, BTA 451 Twin Falls, and the portion ofBTA 258
Logan (Utah) covering Franklin County, Idaho.2 Pursuant to these authorizations, Edge provides
service to the following counties in Idaho: Bannock, Bear Lake, Blaine, Bingham, Bonneville
Butte, Camas, Caribou, Cassia, Clark, Custer, Franklin, Fremont, Gooding, Jefferson, Jerome
Lemhi, Lincoln, Madison, Minidoka, Oneida, Power, Teton, and Twin Falls.3 Outside ofIdaho
Edge operates in portions of northern California, southeastern Oregon, and northwestern
Wyoming. Edge has been operating as an ETC in the State of Oregon since August, 2005.
II.ELIGIBILITY AND IDENTIFICATION OF THE SERVICE AREA.
Under Sections 214(e) and 254 of the Act, the Idaho Public Utilities Commission
IPUC" or "Commission ) is authorized to designate Edge as an ETC. Section 214(e)(2) of the
Act requires state commissions to designate as an ETC, throughout the service area for which
2 Edge currently has 60 employees in Idaho. Upon opening its new call center in Idaho Falls in
March 2007 , Edge will have 74 employees in Idaho. Edge has over 350 total employees and is
headquartered in Bend, Oregon.3 Exhibit A is a map showing the counties encompassed within Edge s FCC licensed territory in
Idaho, superimposed over a map showing incumbent local exchange carrier ("ILEC") exchanges.
See In the Matter of Edge Wireless, LLC Application for Designation as an Eligible
Telecommunications Carrier Pursuant to the Telecommunications Act of 1996, Order No. 06-
965 (OPUC Docket No. UM 1177, August 29,2005).
EDGE WIRELESS ETC. APPLICA nON
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ETC status is sought, any common carrier that: (i) offers services that are supported by federal
universal service support mechanisms; and (ii) advertises the availability of such services. In its
First Report and Order implementing Sections 214( e) and 254, the FCC designated the specific
features a carrier must provide or agree to provide to be designated as an ETC.5 The FCC also
recognized that wireless telecommunications providers are eligible to be designated as ETCs.
Edge is a telecommunications carrier as defined in 47 US.c. 9 153(44) and 47 C.R. 9
51.5(a), and is a telecommunications carrier for the purposes of Part 54 of the FCC's rules. 47
C. 954.1 et seq. Edge is, therefore, considered a common carrier under the Act.
Section 214(e)(2) of the Act provides that ETC designations shall be made for a "service
area" designated by the state commission. Section 214(e)(5) of the Act provides that the "service
area" shall be a geographic area established by the state commission. In areas served by a rural
telephone company, the FCC's rules generally define a competitive ETC's "service area" to
mean the LEC studyarea.7 Attached hereto as Exhibit B is a map depicting Edge s proposed
ETC service area in Idaho superimposed over the rural ILEC ("ILEC") exchanges falling within
Edge s proposed ETC service area. Attached as Exhibit C is a list of non-rural ILEC and rural
ILEC wire centers that fall within Edge s BTAs.8 Edge does not seek to split any wire centers in
the non-rural ILEC areas. Edge serves all the wire centers in all of the rural ILEC study areas
listed in Exhibit C.
Federal-State Joint Board on Universal Service, First Report and Order 12 FCC Rcd 8776
8809-25 (1997) ("First Report and Order
Id.at 8858-59.
See 47 C.R. 954.207(b).8 Because some ILEC exchanges include more than one ILEC wire center, there is some
variation between the list of ILEC wire centers in Exhibit C and the ILEC exchanges shown on
Exhibit B.9 There are five rural ILEC wire centers, four in Citizens territory and one CenturyTel - Gem
State territory, that fall within Edge s BTA. Upon Commission Staffs recommendation, Edge
has excluded these wire centers from its proposed ETC area because including them would
require "redefinition" of the Citizens and CenturyTel - Gem State study areas. Had these wire
centers been included in the proposed ETC area, Edge planned to invest over a two year period
in excess of $500 000 of universal service support on infrastructure to benefit consumers within
EDGE WIRELESS ETC. APPLICA nON
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III.The Legal Standard for Granting ETC Status in Non-Rural and Rural Areas.
Edge satisfies each of the statutory and regulatory prerequisites set forth in the Act, the
FCC's Rules , and the IPUC's ETC Requirements.1I On March 17 2005 , the FCC released its
FCC ETC Requirements Order12 establishing additional requirements for carriers seeking ETC
designation before the FCC. These additional requirements, however, are not binding on state
commissions. This Commission subsequently considered whether to adopt all or some portion
of the rules promulgated by the FCC, and issued a set of ETC designation requirements in the
IPUC ETC Requirements Order.13 In this Application, Edge provides all of the information
required by the Commission pursuant to the IPUC ETC Requirements Order.
Edge may be designated as an ETC in non-rural ILEC areas upon a finding that: (1) Edge
offers the supported services; and (2) Edge will advertise the availability of such services using
media of general distribution.14 Edge may be designated as an ETC in rural ILEC areas upon a
finding that: (1) Edge offers the supported services; (2) Edge will advertise the availability of
such services using media of general distribution; and (3) such designation would serve the
public interest I
To comply with the additional requirements set forth in the FCC ErC Requirements
Order and the IPUC ETC Requirements Order Edge includes in this Application the following:
Demonstration of commitment and ability to provide supported services, including a
two-year wire center-specific network improvement plan, attached hereto as
Confidential Exhibit D.
the excluded area. Edge will continue to work with Commission Staff to determine the most
~~propriate time and procedure for obtaining ETC designation for these wire centers.
47 U.C. 9 214(e)(1)-(2), and 47 c.F.R. g54.201.
II See IPUC ETC Requirements Order.
12 In the Matter of Federal-State Joint Board on Universal Service Report and Order, 20 FCC
Rcd 6371 (2005) FCC ETC Requirements Order
13 IPUC ETC Requirements Order Appendix pp. 1-
14 See e.g., In the Matter of the Petition of IAT Communications, Inc. dba NTCH-Idaho, Inc. or
Clear Talk for Designation as an Eligible Telecommunications Carrier, Order No. 29261 (IPUC
Case No. GNR-03-, served June 11 2003).
15 See 47 C.R. g54.207(c).
EDGE WIRELESS ETC. APPLICA nON
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Demonstration of Edge s ability to remain functional in emergency situations.
Commitment to comply with all applicable service quality standards and consumer
protection rules and an agreement to comply with the Cellular Telecommunications
and Internet Association s Consumer Code for Wireless Service ("CTIA Code
Descriptions of Edge s local rate plans and the local usage plans of the ILECs.
SERVICES PROVIDED BY APPLICANT
Edge will offer the federally designated services listed at 47 C.R. 954.101(a). The
services which are supported by the federal USF program are: (1) voice grade access to the
public switched network, (2) local usage, (3) dual tone multi-frequency signaling or its
functional equivalent, (4) single-party service or its functional equivalent, (5) access to
emergency services, (6) access to operator services , (7) access to interexchange service, (8)
access to directory assistance, (9) toll limitation for qualifying low-income consumers.16 Edge is
a full service wireless carrier that offers all of these services, as described in detail below
throughout its licensed service area utilizing its own facilities - including its own antennas
towers and mobile switching offices.
Voice-Grade Access to the Public Switched Telephone Network.
FCC Rule Section 54.101(a)(I) requires voice grade access to the public switched
telephone network. The FCC defines this as:
the ability of a user of telecommunications services to transmit
voice communications, including signaling the network that the
caller wishes to place a call, and to receive voice communications
including receiving a signal indicating there is an incoming call.
For the purposes of this part, bandwidth for voice grade access
should be, at a minimum, 300 to 3 000 Hertz.
Edge provides voice grade access to the public switched network through interconnection
arrangements with local telephone companies. Edge offers its subscribers this service at a
47 C.R. 954.101(a).
47 c.F.R. 54.1O1(a)(I).
EDGE WIRELESS ETC. APPLICATION
PDX 1588359vl 0054189-000049
bandwidth between no less than 300 to 3 000 hertz, thereby providing voice grade access
consistent with the FCC's definition.
Local Usage.
Edge s rate plans provide local usage consistent with Section 54.1 01 (a)(2) of the FCC'
Rules. In the First Report and Order, the FCC deferred a determination on the amount of local
usage that a carrier would be required to provide. 18 Any minimum local usage requirement
established by the FCC will be applicable to all designated ETCs. Edge meets the local usage
requirements by including local usage in its rate plans and Edge will comply with any and all
minimum local usage requirements adopted by the FCC.
Consistent with the IPUC ETC Requirements Order Appendix p. 3 , Edge submits its
LocalEdge rate plan brochures as Exhibit E. The relevant ILEC local usage rate plans are on file
with the Commission at: http://www.puc.state.id.us/tariff/approved/title611approved.htm. A
copy of this web page is attached as Exhibit F. The Commission has expressly rejected the
FCC's requirement that the applicant's usage plan be comparable to that ofthe ILEC, stating:
we find it is sufficient for the ETC applicant to simply describe its local usage plans and those
of the ILEC.19 The Commission aptly noted that the FCC's comparability analysis could
potentially discourage carriers from offering diverse services, and that with competition
consumers should have the option to obtain the type of service offering they would like
One of the distinct advantages to the LocalEdge rate plans is that Edge provides
significantly wider local calling areas. Whereas the relevant ILEC local calling areas are
primarily limited to their local exchange boundaries and extended service area boundaries
Edge s local calling area includes most of Southeastern Idaho and a portion of Northwestern
18
Id. at 8814.
19 IPUC ETC Requirements Order p. 12; see also, In the Matter of the Petition of Inland
Cellular Telephone Companyfor Designation as an Eligible Telecommunications Carrier Under
47 USe. 9214(e)(2), Order No. 30212 , p. 11 (IPUC Case No. INC-06-, served Dec. 28
2006).
20 Id.
EDGE WIRELESS ETC. APPLICA nON
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Wyoming. In addition, Edge s local calling area includes its partner network coverage along the
84 corridor from the western boundary of Twin Falls to the Oregon border, including Boise and
the surrounding area, subject to the requirement that a majority of the subscribers minutes of use
be on the Edge Wireless Network.
Second, Edge provides unlimited, toll-free service for 911 emergency calls and for 611
customer care. Edge also provides toll-free 511 road reports to the Idaho Department of
Transportation, 711. calls to TRS/TTY operators and 211 calls to social service agencies.
Finally, all of Edge s local calling plans include unlimited nationwide long distance at no
additional charge?1 The LocalEdge calling plans priced at $44.99 and higher per month also
include unlimited night and weekend calling, and unlimited mobile to mobile calling.
Dual-Tone, Multi-Frequency Signaling or its Functional Equivalent.
Pursuant to Section 54.101(a)(3) of the FCC's Rules, an ETC must provide dual tone
multi-frequency ("DTMF") signaling to facilitate the transportation of signaling throughout its
network. Edge currently provides DTMF signaling consistent with the FCC's Rules.
Single-Party Service or its Functional Equivalent.
Single-party service" means that only one party will be served by a subscriber loop or
access line in contrast to a multi-party line?3 Edge provides single party service, as required by
47 C.R. 954.101(a)(4).
21 Local Carryover rate plans, which allow subscribers to carry unused minutes forward to the
next billing cycle, do not include unlimited nationwide long distance.
22
See Exhibit E (LocalEdge rate plan brochure).
23
First Report and Order at 8810.
EDGE WIRELESS ETC. APPLICATION
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Access to Emergency Services and Ability to Remain Functional in
Emergency Situations.
The ability to reach a public emergency service provider by dialing 911 is a required
service in any universal service offering. Edge currently provides all of its customers with
access to emergency service by dialing 911 in satisfaction of this requirement. Phase I E911
which includes the capability of providing both automatic numbering information ("ANI") and
automatic location information ("ALl"), is only required if a public emergency service provider
makes arrangements with the local provider for the delivery of such information?4 In addition to
Phase 0 E911 , Edge Wireless provides Phase I and Phase II wireless E911 to Public Safety
Answering Points ("PSAP") when they request this improved service and are ready to receive the
Phase 1 and Phase II call information. To date, Edge has received requests for E911 Phase I and
Phase II deployment in Blaine, Bingham, Bonneville, Caribou, Fremont and Lemhi Counties.
All Counties are deployed with the exception ofthe Fremont County, which is currently in the
deployment process (as of December 15 2006).
Phase I and Phase II wireless E911 service provides valuable location based information
to the PSAP which allows emergency personnel to determine the cell site serving the caller and
the geographic location of the phone placing the call. Additional cell site coverage in rural areas
will greatly improve access to wireless E911 services and greater accuracy of the location based
information received by the PSAP. Edge was able to use these enhanced capabilities recently
assist law enforcement rescue efforts in Oregon. When the James Kim family was lost in
Oregon, Edge was able to provide information gained from a rural cell site to Search and Rescue
personnel regarding the area in which the family s phone was last active. This information was
key to the survival of Mrs. Kim and her two young children. In addition Edge installed a cell on
wheels ("COW") which improved telephone communications for the rescue teams. Exhibit G is a
letter from the California Public Utilities Commission praising Edge s contribution to this
rescue.
24 See !d.at 8815-17.
EDGE WIRELESS ETC. APPLlCA nON
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Consistent with the IPUC ETC Requirements Order at Appendix p. 3 , Edge also has the
ability to remain functional in emergency situations. Edge has designed a fault tolerant network
that employs the following features:
Mobile Switching Center
Nortel DMS NSS 18- R4 switches with fully redundant fault tolerant processors;
12 hours of back up battery;
300 KW generator with 7days fuel supply;
complete complement of spare circuit boards;
0 Self-Healing Alternate Route Protection Service for Fiber Facilities
interconnection;
Redundant A TM interconnection to remote media gateway switches;
Multiple alternate trunk routes for PSTN interconnection trunks;
Redundant Microwave radio links; and
Automated 7x24 network monitoring.
Cell sites
Overlapping cell site coverage with directed retry for blocked calls;
Back haul network engineered with surplus back bone capacity;
- Field technicians are equipped with growth radio stock;
- In the event of a capacity spike that can not be absorbed by directed retry,
additional radios can be installed quickly;
All (4) major hub sites have 8 hours battery back up and standby generators;
Standby Generators and 8 hours battery back up at 12 minor hub sites;
85% of sites have minimum of 8 hours back up battery, remaining 15% have
hour;
Leased Fiber and redundant MW to major network hub locations;
All sites have quick connect plugs for portable generator;
EDGE WIRELESS ETC. APPLICA nON
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One (1) trailer mounted 20 kw trailer mounted generators stored in Twin Falls and
two (2) in Pocatello;
Compact generator system stored in Pocatello, Idaho for use with Snow Cat only
accessible sites; and
All sites remotely monitored 7x24.
Monitoring Network and Outage Resolution procedures
Edge Wireless has 2 network operating centers ("NOCs ), 1 in Medford, Oregon
and 1 in Pocatello, Idaho;
All Switches and cell sites are remotely monitored 7x24, with critical and major
alarms escalated to the next level of management every 20 minutes.
Staffing and Additional Equipment
The Idaho Technical Operations team consists of 11 people strategically located
within Southeastern Idaho in the following locations: 1 in Rigby, 1 in Idaho Falls
2 in Shelley, 5 in Pocatello, 1 in Kimberly and 1 in Filer;
Staff is very well trained and equipped to respond quickly in the event of outages
alarms or emergencies;
0 Two (2) cells on wheels, complete with temporary microwave systems, stored at
Pocatello, Idaho facility which can be used for emergency coverage, capacity and
back bone recovery;
Complete inventory of alternate access equipment, including:
- All field staff are equipped with 4 wheel drive pickups, (1) Tucker Terra Snow
Cat stored at Pocatello facility, (3) snow mobiles stored at Pocatello facility, (2)
Polaris 4 wheelers located in Pocatello;
All field staff trained in operation for all alternative site access equipment;
Tower crews on standby for emergency tower and antenna repairs; and
Technicians equipped with complete complement of spares for Cell site
Microwave and DACs equipment to insure quick recovery.
EDGE WIRELESS ETC. APPLICA nON
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Edge Wireless has proven its ability to respond quickly during emergency situations:
Installed cell on wheels, or COWs, to provide phone service for remote fire camps for
Tiller and Orleans complex fires;
Provided timely subscriber location information to help public safety officials locate
injured people in rural areas;
Increased network capacity on sites serving county fairs annually for the past 5 years
typically adding enough network capacity to handle a 100% increase in busy hour traffic
for sites serving the fair grounds; and
Installed on numerous occasions temporary microwave hops when ILEC-provided
circuits have sustained extended outages or due dates for new circuits have not been
achieved.
In 2006 alone, Edge Wireless has performed the following network upgrades for improved
reliability:
Installed redundant leased Tl facilities to our Preston, Soda Springs and Montpellier cell
sites, thereby providing an alternate route to the Edge microwave system that routes
through Sedgwick peak;
Installed leased DS3 circuits to Idaho Falls, Rexburg and Twin Falls to provide alternate
network back haul for Edge s existing microwave network; and
Installed high capacity Mobile Switching Center.
Through all of these efforts, Edge has ensured that it not only provides customers with needed
emergency services, but can also remain fully functional in emergencies. In addition, Edge has
planned the following 2007 reliability and technology upgrades:
Edge Wireless is currently building a regional call center in Idaho Falls with planned
opening in March of 2007. The new Idaho call center will provide additional redundancy
and improved capability to support Idaho customers with local employees.
25 Attached hereto as Exhibit H is a letter from the Cassia County 911 Coordinator.
EDGE WIRELESS ETC. APPLICATION
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Additional 3G sites to expand coverage area for advanced wireless service.
Access to Operator Services.
Access to operator services is defined as any automatic or live assistance provided to a
consumer to arrange for the billing or completion, or both, of a telephone cal1.26 Edge provides
customer access to operator services. Customers can reach operator services in the traditional
manner by dialing ", in compliance with Section 54.101 (a)(6) of the Federal Rules.
Access to Interexchange Service.
A universal service provider must offer consumers access to interexchange service to
make and receive toll or interexchange calls. Equal access, however, is not required. "The FCC
do(esJ not include equal access to interexchange service among the services supported by
universal service mechanisms.27 Edge presently meets this requirement by providing all of its
customers with the ability to make and receive interexchange or toll calls through direct
interconnection arrangements Edge has with several interexchange carriers ("IXCs
Access to Directory Assistance.
The ability to place a call to directory assistance is a required service offering.
Subscribers to Edge s services are able to dial "411" or "555-1212" to reach directory assistance
from their mobile phones.
Toll Limitation for Qualifying Low Income Consumers.
An ETC must offer either "toll control" or "toll blocking" services to qualifying Lifeline
customers at no charge. The FCC no longer requires an ETC to provide both services as part of
the toll limitation service required under 47 C.R. g54.101(a)(9)?9 In particular, all ETCs must
provide toll blocking which allows customers to block the completion of outgoing toll calls.
26 Id.ad 8817-18.
27 Id.at 8819.
28 Id.at 8821.
29
See Universal Service Fourth Order on Reconsideration in CC Docket No. 96-45, Report and
Order in CC Docket Nos. 96-, 96-262, 94-, 91-213, 95-, 13 FCC Rcd 5318 (1997).
30 First Report and Order at 8821-22.
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Edge currently has no Lifeline customers in Idaho because only carriers designated as an ETC
can participate in Lifeline. See 47 C.R. 99 54.400-415. Once designated as an ETC, Edge will
participate in Lifeline, as required. Though Edge s switch does not currently support toll
blocking per se as noted in Section B above, all of Edge s LocalEdge rate plans include
unlimited long distance at no additional charge, which is the functional equivalent of toll
blocking. Edge s Lifeline rate plans will have the same feature, as well as the ability to block
roaming and international dialing, all of which will allow customers to avoid unexpected
charges.
ADVERTISING AVAILABILITY OF UNIVERSAL SERVICE
Pursuant to Section 54.201 of the FCC's rules , 47 C.R. Section 54.201 , Edge plans to
advertise the availability of each of the supported services detailed above, throughout its licensed
service area, by media of general distribution. The methods of advertising utilized may include
newspaper, magazine, radio, direct mailings, public exhibits and displays, bill inserts, and
telephone directory advertising. See Confidential Exhibit J which provides data regarding
Edge s advertising expenditures in 2006. Edge expects to engage in similar, if not greater, levels
of advertising in 2007.
Edge also intends to offer advertising similar to its advertising in Oregon to promote
Lifeline service, primarily through print advertising and direct outreach by Edge s direct and
indirect sales staff to community health, welfare and employment offices as well as Indian tribes.
Edge will not be promoting Linkup service because Edge does not charge for activation of
wireless services. Edge will advertise the fact that it does not charge activation fees as a
functional equivalent of advertising Linkup. See Exhibit K which provides examples of Edge
Lifeline related advertising in Oregon.
31
See Exhibit I, which is a copy of Edge s Oregon Lifeline brochure.
EDGE WIRELESS ETC. APPLICA nON
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COMMITMENT TO CONSUMER PROTECTION
Consistent with the IPUC ETC Requirements Order at Appendix A p. 3 , Edge will
comply with all applicable service quality standards and consumer protection rules, and will
abide by the consumer protection standards established by the CTIA Consumer Code.
TRIBAL NOTIFICATION
The IPUC ETC Requirements Order at Appendix A p. 2 requires an ETC applicant
seeking ETC designation for any part of tribal lands to provide a copy of its application to the
affected tribal government or tribal regulatory authority, as applicable, at the time it files its
application with Commission. Edge is seeking ETC designation for a portion of the Fort Hall
Reservation. Consistent with this requirement, contemporaneous with the filing of the
Application with the Commission, Edge has provided a copy of its Application to:
Shoshone-Bannock Tribes of the Fort Hall Reservation of Idaho
Ms. Diana Yupe
Shoshone-Bannock Tribes of Fort Hall
Shoshone-Bannock Heritage Tribal Office
O. Box 306
Fort Hall, ID 83203
Edge currently provides service to portions of the Fort Hall Reservation. Upon designation as an
ETC, Edge will offer Tribal Lifeline service to qualified residents of the Fort Hall Reservation
for as little as one dollar per month.
EDGE WIRELESS ETC. APPLICATION
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IV.PUBLIC INTEREST FACTORS
In addition to finding that Edge meets the nine-point checklist, and that it agrees to offer
and advertise the supported services throughout the proposed ETC service area, and that it
satisfies the Commission s additional criterion, the Commission must also determine whether
such designation otherwise serves the public interest.
In determining whether designating Edge as an ETC in the rural ILEC wire centers listed
in Exhibit C, the Commission must follow the guidance provided by Congress in adopting the
Act, and by the FCC in its enabling orders.32 The overarching principles embodied in the Act are
to "promote competition and reduce regulation. . . secure lower prices and higher quality
services. . . and encourage the rapid deployment of new technologies.33 In its implementing
orders, the FCC ruled that the pro-competitive and deregulatory directives from Congress
required universal service support mechanisms to be competitively neutral and portable among
eligible carriers.34 This Commission has adopted the FCC's public interest analysis as set forth
in the FCC ETC Requirements Order stating:
Thus, in determining whether ETC designation is in the public
interest, this Commission shall consider the benefits of increased
consumer choice, and the unique advantages and disadvantages of
the applicant's service offering.
32 Pub. L No. 104-104, 110 Stat. 56 (1996); See also, First Report and Order, supra; Federal-
State Joint Board on Universal Service, Ninth Report and Order and Eighteenth Order on
Reconsideration 14 FCC Rcd 20432 Ninth Report and Order ); Federal-State Joint Board on
Universal Service, Multi-Association Group (MAG) Plan for Regulation of Interstate Services of
Non-Price Cap Incumbent Local Exchange Carriers and Interexchange Carriers, Fourteenth
Report and Order, Twenty-Second Order on Reconsideration, and Further Notice of Proposed
Rulemaking, 16 FCC Rcd 11244 (2001) Fourteenth Report and Order ); See also NAACP
FCC 425 U.S. 662 669 (1976); accord, e.g., Office of Communication of the United Church of
Christv. FCC 707 F. 2d 1413 1427 (D.c. Cir. 1983); Bilingual Bicultural Coalition on Mass
Media, Inc. v, FCC 595 F. 2d 621 628 & n. 22 (D.C. Cir. 1978).
33 See Act (preamble).
34 First Report and Order at 8861-62; Ninth Report and Order at 20480.
35 IPUC ETC Requirements Order p. 16.
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As shown herein, the public interest objectives set forth in the Act, the FCC's Orders, the
IPUC ETC Requirements Order and precedent established across the country, will be furthered
by the designation of Edge as an ETC in the rural ILEC wire centers listed in Exhibit C.
Increased Consumer Choice and Service Quality.
Designation of Edge as an ETC is in the public interest because such designation will
promote competition and thereby facilitate the provision of advanced communications services
and higher quality services to the residents of rural Idaho. A central tenet of federal universal
service policy is that consumers in rural areas are entitled to the same kind of choices of
telecommunications services as those in urban areas?6 In many rural areas, no meaningful
choice of local service providers exists. Designation of Edge as an ETC will provide rural
consumers with a choice among carriers and service features. Edge will provide wider local
calling areas, mobile communications, a variety of service offerings, high-quality service37 and
competitive rates. Wireless service provides consumers with numerous benefits not typically
available from wire line competitors. For example, mobility provides subscribers the ability to
communicate while commuting, working on farms or ranches, or otherwise away from homes
and offices. Mobility also makes emergency services more readily accessible in situations where
time is of the essence. In addition, wireless handsets offer increased functionality such as
contact lists, voice-activated dialing, conference calling capabilities, and access to multi-media
and data services. Thus, consumers will be able to choose those service features that best meet
their needs.
Upon receipt of ETC designation in Idaho, Edge will use the high-cost support it receives
to improve its infrastructure in rural areas. Edge has evaluated the projected levels of support
along with identifying areas where poor coverage and demand for service coincide.38 Edge
two-year network improvement plan shows projects that may not otherwise be constructed
36
See 47 U.C. 9254(b)(3).37 See Confidential Exhibit L, describing service quality metrics to which Edge adheres.38 See Confidential Exhibit D, Edge s two-year network improvement plan designating proposed
infrastructure investment in Edge s BTA should Edge receive ETC status.
EDGE WIRELESS ETC. APPLICATION
PDX 1588359vl 0054189-000049
without universal service support. This expansion and strengthening of network coverage
increases the number of competitive choices available for rural Idaho consumers where Edge
service would not otherwise extend without support. The improved service quality, reliability
and increased choices to rural Idaho will be significant. In addition, some rural Idaho consumers
may be able to obtain wireless service from Edge where landline service from the ILEC is cost
prohibitive. Since receiving ETC designation in the State of Oregon , Edge has been able to
invest in infrastructure that brings enhanced wireless services to parts of rural Oregon that would
not have otherwise received those services.
As Edge constructs additional cell sites in high-cost areas to improve the quality of its
radio frequency ("RF") signal, consumers will have a greater choice among service providers
and will receive more reliable service. Some will have the option to receive Edge s service for
the first time. Indeed, without the high-cost program, it is doubtful that many rural areas would
have wireline telephone service, even today. Edge has been successful in competing for second
lines. However, the rural ILECs serving the proposed ETC service area retain close to 100% of
the local exchange market primarily because it is impossible for any company to compete with a
monopoly that receives explicit subsidies from the government as well as substantial implicit
subsidies that are unavailable to competitors (even those designated as ETCs). If only wireline
providers receive universal service support, consumers will continue to have no service
alternatives, and will be left behind their urban counter-parts. The Washington Utilities and
Transportation Commission expressly recognized this fact when designating United States
Cellular as an ETC, stating:
The fact that its competitors receive universal service support puts
USCC at a disadvantage in its ability to make cellular technology
more widely available at competitive prices. Allowing USCC to
receive universal service support increases the likelihood that
39 See In the Matter of Edge Wireless, LLC Application for Designation as an Eligible
Telecommunications Carrier Pursuant to the Telecommunications Act of 1996, Order No. 05-
965 (OPUC Docket No. UM 1177, August 29 2005).
EDGE WIRELESS ETC. APPLICA nON
pox 1588359vl 0054189-000049
cellular technology will become available to more rural consumers
at an affordable price.
Designation of Edge as an ETC will begin to level the playing field among carriers
competing in the local exchange market - to the benefit of consumers.
In addition, consumers will benefit from access to advanced wireless data
communications. Historically, Edge has been on the forefront in offering advanced wireless
communications to rural areas. Edge was the first carrier to bring mobile wireless data
applications to many rural areas in Southeastern Idaho by launching its GPRS wireless packet
data system in 2003. This system offered wireless data rates of up to 40 kilobytes per second
kbs ). In 2004, Edge upgraded its GPRS packet data system to "EDGE" technology, which
increased the data rates up to 150kbs. In 2006, Edge installed 3G wireless core switching
equipment, and has installed 3G cell sites and has customer trials in progress in Twin Falls
County. The 3G cell sites support 3G handsets for advanced voice and data services. 3G devices
available today support wireless data rates of up to 3.6 megabits per second ("mbs ) upgrading to
7.2 mbs in 2008. Edge can now offer internet access in rural areas with very good data rates.
Moving forward the service will be advanced by:
Upgrading EDGE packet data core software and hardware to increase data through-put;
Installing additional 3G sites and core equipment for expanded 3G coverage;
Improving access to the network by adding additional rural Base Transceiver Systems
BTS"
Making antenna systems available for rural residences that boost signals between
wireless modems and BTS;
Providing access to upgraded wireless handsets as they become available for rural users
that enhance voice quality and data rates; and
40 See In the Matter of United States Cellular Third Supplemental Order Granting Petition for
Designation as Eligible Telecommunications Carrier, WUTC Docket No. UT-970345 (Jan. 27
2000), at ~43.
EDGE WIRELESS ETC. APPLICATION
POX I 588359v I 0054189-000049
Improving wireless feature sets by improving applications, such as picture messaging,
video messaging, video conferencing, text messaging, wireless internet access, wireless
security systems and wireless email.
Designating Edge as an ETC in Idaho will provide a framework for providing consumers
increased choice of service offerings consistent with the goals established by the Act, the FCC
and this Commission.
Health and Safety Benefits.
Designation of Edge will advance important health and safety goals. Edge s mobile
offering will allow rural consumers the flexibility to communicate while on the go and still retain
access to emergency services. In addition to being able to reach emergency services while in
their homes, wireless subscribers are able to reach emergency services while they are in route to
their homes, workplaces and commercial centers. Wireless phone service has become essential
to farming, mining, law enforcement, resource management and construction sectors.
In a recent ETC designation proceeding, the Oregon Public Utility Commission
concluded that "the 'unique advantages' of wireless telephones , which allow mobile
communications beneficial to safety, health and commerce, weigh in favor of the application.
Similarly, in designating the wireless carrier Smith Bagley, Inc. as an ETC in Arizona, the
Arizona Corporation Commission found that carrier s designation would provide a potential
solution 'to "health and safety risks associated with geographic isolation. ,,44 Designation of Edge
as an ETC in Idaho will provide similar benefits.
41 See e.g., In the Matter of the Petition ofVCI Company for Designation as an Eligible
Telecommunications Carrier Providing Service to Customers Under the Idaho
Telecommunications Service Assistance Program, Order No. 29686, Case No. VCI-04-, p. 3
(Jan. 13 , 2005)(finding ETC status in the public interest due in part to greater competition).
42
See Exhibit M, which is a description ofthe use of cell phones in rural areas by the Twin Falls
Division of the Bureau of Land Management.
43 In the Matter of RCC Minnesota, Inc. Applicationfor Designation as an Eligible
Telecommunications Carrier, Pursuant to the Telecommunications Act of 1996, Order No. 04-
355, OPUC Docket UM 1083 , p. 9 (June 24 2004).
44 Smith Bagley, Inc.Decision No. 63269, ACC Docket No. T-02556A-99-0207 , at p. 12 (Dec.
2000).
EDGE WIRELESS ETC. APPLICA nON
PDX 1588359vl 0054189-000049
Citizens in rural areas depend on mobile phones more and more to provide critical
communications needs. The provision of universal service support to Edge will enable it to
improve signal strength, thereby improving the reliability of service for health and safety
purposes. All wireless carriers are required to implement over the next several years Phase II E-
911 service, which permits a caller to be located and tracked. For every cell site Edge constructs
the reliability and performance of its E-911 service will improve. It would be difficult to
overstate the important public interest benefit that will be realized by supporting improvement to
critical wireless infrastructure.
As mentioned above, when the James Kim family became lost in Oregon over the past
Thanksgiving holiday, Edge was able to provide information gained from a rural cell site to
Search and Rescue personnel regarding the area in which the family s phone was last active.
This information was key to the survival of Mrs. Kim and her two young children. In addition
Edge installed a cell on wheels that improved telephone communications for the rescue teams.
In Idaho, over two dozen federal, state and local government agencies use Edge service.
These include several law enforcement agencies and first responders.
Having reliable wireless phone service provides a redundant form of communications
should the ILEC experience outages such as storm-related outside plant failures, fiber cuts or
widespread call processing failures. For example, when activation of the tsunami warning system
along rural sections of the Oregon and California coast generated high call volumes resulting in
failed ILEC call processing, residents were able to stay connected using the robust call capacity
provided by Edge s network. Edge has received the 2004 Excellent Network Award from Nortel
Networks acknowledging Edge s commitment to operating a very reliable network.46
Competitive Response.
By designating Edge as an ETC, competition will be increased in the proposed service
area. As a result, both Edge and the other carriers serving that area will be motivated to
45
See Exhibit G, CPUC letter commending Edge.
46
See Exhibit N.
EDGE WIRELESS ETC. APPLICA nON
PDX 1588359vl 0054189-000049
implement advanced communications services and continually improve service quality levels in
order to attract customers for their respective services. The public interest standard under
Section 214(e)(2) for designating ETCs in territories served by rural telephone companies
emphasizes competition and consumer benefit, not incumbent protection. There is no question
that, if Edge is designated as an ETC and is, therefore, better able to compete for local exchange
customers, it will spur a competitive response from affected ILECs: service quality and
customer service will improve; new investments in plant will be made; high speed data (e,
g.,
DSL) may be deployed more quickly to retain and attract customers; and wider local calling
areas, bundled service offerings, and lower prices overall will be introduced to compete with
Edge to retain and attract customers.
Another response will be increased investment in areas that are the ILEC's strengths. For
example, many ILECs advertise the advantage that wire line facilities offer in the area of high-
speed data or Internet access. The affected ILEC can be expected to use its advantage in this
area to cement and expand its customer base by investing in facilities needed to bring DSL and
other high-speed connectivity to a greater percentage of people living in rural areas. Those that
have constructed DS I-ready facilities may lower prices to attract customers. Rural consumers
will benefit from these types of investment and price competition, and Edge believes that the use
of high-cost support to develop competitive services in rural areas can be a powerful driver of
broadband development by ILECs, who will be forced to respond.
Edge s enhanced coverage will also help economic development in rural areas. One
the key components in a decision to locate a new business, or to move an existing business, is the
quality of overall telecommunications infrastructure in a particular area. More and more
wireless connectivity is an indispensable part ofthat equation. If telecommunications
infrastructure is substandard in a particular area, businesses that serve the community s needs
and create jobs may be compelled to leave. Preserving and expanding economic development in
rural areas is in the public interest and a grant of Edge s Application will further that objective.
EDGE WIRELESS ETC. APPLICA nON
PDX 1588359vl 0054189-000049
State and Federal Precedent.
Designation of Edge as an ETC is consistent with ETC decisions across the country.
There are now numerous cases at the state and federal level where designation of a wireless
carrier as an ETC in a rural area was found to be in the public interest. Numerous state
commissions and the FCC have repeatedly found that designating wireless carriers as ETCs will
promote competition, advance universal service, and further the deployment of advanced
services. For example, in its decision to designate Rural Cellular Corp. ("RCC") as an ETC, the
Washington Utilities and Transportation Commission stated: "Granting ETC designation to RCC
. . . will facilitate the telecommunications choices available to rural citizens, support the growth
of new technologies and services, preserve and advance universal service, and promote
competition and the benefits it brings.47 More recently, in designating Midwest Wireless
Communications, LLC as an ETC in Minnesota, the Minnesota Public Utilities Commission held
that
, "
( c )ompetition would benefit consumers in southern Minnesota by increasing customer
choice (from no choice in most areas to more than one) and providing new services made
possible by wireless technologies. . . .48 Similarly, in its decision designating Western Wireless
as an ETC in the State of Wyoming, the FCC held: "Designation of competitive ETCs promotes
competition and benefits consumers in rural and high-cost areas by increasing customer choice
innovative services and new technologies.
For all of the above reasons, the public interest would be served by the designation of
Edge as a competitive ETC throughout its requested service area.
Commitment to Serve Requesting Customers
Consistent with the IPUC ETC Requirements Order Appendix p. 2, Edge is committed
to answering all reasonable requests for service within its proposed ETC service area. Edge
47 RCC Minnesota, Inc., d/b/a Cellular One Order Granting Petition for Designation as an
Eligible Telecommunications Carrier, WUTC Docket No. UT-023033 (Aug. 2002), ~68.
48 Midwest Wireless Communications, LLC OAH Docket No. 3-2500-14980-, Minn. PUC
Docket No. PT6153/AM-02-686, adopted Feb. 13 2003 (order pending), adopting ALl's
Findings of Fact, Conclusions of Law, and Recommendation (ALl Dec. 31 , 2002), ~37.
49 Western Wireless Corporation Petition for Designation as an Eligible Telecommunications
Carrier in the State of Wyoming, Memorandum Opinion and Order 16 FCC Rcd 48 55 (2000).
EDGE WIRELESS ETC. APPLICA nON
PDX I 588359v I 0054189-000049
wants to use high-cost support prudently, to improve service to as many people as possible
whHe also extending service to as many requesting customers as possible.
Edge will use the following, six-point checklist in answering requests from residents
within its proposed ETC area, but outside its existing network coverage: (1) determine whether
the customer s equipment can be modified or replaced to provide acceptable service; (2)
determine whether a roof-mounted antenna or other network equipment can be deployed at the
premises to provide service; (3) determine whether adjustments at the nearest cell site can be
made to provide service; (4) determine whether there are any other adjustments to network or
customer facilities that can be made to provide service; (5) explore the possibility of offering
resold service; and (6) determine whether an additional cell site, a cell-extender, or repeater can
be employed or constructed to provide service.
VI.LEGAL AUTHORITY
The Commission has the legal authority to grant the relief requested by Applicant
pursuant to 47 U.C. 9 214(e)(2); 47 C.R. 9 54.201; see also, IPUC ETC Requirements Order.
EDGE WIRELESS ETC. APPLICA nON
pox 1588359vl 0054189-000049
VII.RELIEF REQUESTED
For the reasons set forth above, and pursuant to Section 214(e)(2) of the Act, Edge
requests that the Commission enter an Order designating Edge as an ETC for the areas described
herein and that the Commission enter its Order at the earliest possible date.
'11 .Dated the day of January, 2007.
Respectfully submitted,
DA VIS WRIGHT TREMAINE, LLP RICHARDSON & O'LEARY, PLLC
By:
Mark . Trinchero, OSB #88322
130 S.W. 5th Avenue, Suite 2300Po and, Oregon 97201
Tel: [phone]
Fax: [phone]
marktrinchero (g)dwtcom
EDGE WIRELESS ETc. APPLICATION
POX 1588359vl 0054189-000049
/011
EXHIBIT B
BONNERSFERRY Idaho Telephone Exchanges
and Company Areas
Regulated Companies
ATC
Cambridge
CenturyTel
CenturyTel - Gem State
Citizens
Direct
Fremont
Inland
CO-OPS Midvale
Blackfoot f~j Oregon -Idaho
Custer Pine
Farmers Mutual Owes!
II1II Filer Mutual
~~~
Rural
Mud Lake Silver Star
Project Mutual TDS
Teton
Verizon
Unclaimed
LATA Boundary
Miles
AUotO
IDAHO PUBUCtmJ7IES
""""""'""""""
RPS
EXHIBIT C
ILEC WIRE CENTERS WITHIN
EDGE WIRELESS PROPOSED ETC AREA
NON-RURAL ILEC WIRE CENTERS
Qwest Communications
AMFLIDMA (American Falls)
BLFTIDMA (Black Foot)
BLSIDMA (Bliss)
BN CRID MA (Bancroft)
BRL YIDMA (Burley)
BUHLIDMA (BOOl)
CSFRIDMA (Castleford)
DWNYIDMA (Downey)
EDHZIDMA (Eden-Hazelton)
GDNGIDMA (Gooding)
GRACIDMA (Grace)
HAL YIDMA (Hailey)
HGMNIDMA (Hagerman)
IDFLIDMA (Idaho Falls)
JERMIDNM (Jerome)
KMBRIDMA (Kimberly)
KTCHIDMA (Ketchum)
LHSPIDMA (Lava Hot Springs)
M CCMID MA (McCammon)
MRTGIDMA (Murlaugh)
MTPLIDMA (MontpelIer)
PCTLIDMA (Pocatello)
PSTNIDMA (Preston)
RBRTIDMA (Roberts)
RGBYIDMA (Rigby)
RIRIIDMA (Ririe)
RXBGIDMA (Rexburg)
SDSPIDMA (Soda Springs)
SHL YIDMA (Shelley)
SHSHIDMA (Shoshone-Dietrich)
AFTNWYMA (Tygee Valley)
TWFLIDMA (Twin Falls)
WINDLIDMA (Wendell)
PDX 1575371vl 0054189-000049
RURAL ILEC WIRE CENTERS
Albion Telephone Company
ALBNIDXC (Albion)
ALMOIDXC (Almo)
ARCOIDXC (Arco)
ELBAIDXC (Elba)
HLBKIDXC (Holbrook)
HOWEIDXC (Howe)
MSL TIDXC (Malta)
MCKYIDXC (Mackay)
MLCYIDXC (Malad)
MOORIDXC (Moore)
RFRVIDXC (Raft River)
CenturvTel of Idaho. Inc.
LEDRIDXC (Leadore)
NFRKIDXC (North Fork)
SLMNIDXC (Salmon)
Custer Communications
CHLSIDXC (Challis)
CYTNIDXC (Clayton)
EKBNIDXC (Elk Bend)
MA YIDXC (May)
STNLIDXC (Stanley)
Direct Communications
ARBNIDXC (Arbon)
PARSIDXC (Paris)
RKLDIDXC (Rockland)
Filer Mutual
FILRIDXC (Filer!)
FILRIDXC (Filer2)
HLSTIDXC (Hollisterl)
HLSTIDXC (Hollister2)
PDX 1575371vl 0054189-000049
Fremont Telecom Company
ASTNIDMA (Ashton)
STATIDMA (St. Anthony)
ISPKIDMA (Island Park)
Mud Lake
DUBSIDXC (Dubios)
HAMRIDXC (Hamer)
KLGRIDXC (Kilgore)
MNVWIDXC (Monteview)
TRTNIDXC (Terreton)
Project Mutual
MNDKIDXC (Minidoka)
NRLDIDXC (Norland)
OKL YIDXC (Oakley)
AULIDXC (Paul)
RPRTIDXC (Rupert)
Silver Star - Teton Telephone
DRGSIDMA (Driggs)
TTNIDMA (Tetonia)
VCTRIDMA (Victor)
Silver Star Communications
FRDMWYXC (Freedom)
IRWNIDXC (Irwin)
W A YNIDXC (Wayan)
PDX 1575371vl 0054189-000049
EXHIBIT D
THIS EXHIBIT ALLEGEDLY
CONTAINS TRADE SECRETS
OR CONFIDENTIAL MATERIAL
AND IS SEPARATELY FILED.
APPLICATION OF EDGE WIRELESS FOR ETC DESIGNATION
Edge Wireless:: LocalEdge Rate PIan
edg~~BE~~$
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Rate Plans & Coverage
Areas
Phones
Customer Services
Business Services
Store Locations
Ring Tones &
Games
Buy Service Online
EXHIBIT E
Ps2e J of 5
About u. I Careers I Pr... Room I Bill Pay I Send a Message " cingular'
-.....
LocalEdge
The LocalEdge Plan Is one of the most economical ways to enjoy all the
convenience and benefits of wireless. You won t have to pay any nationwide
long distance charges as long as you re calling within the U.
All plans also offer features like call waiting, voice mall, and call
forwarding.Edge Rate Plans
LocalEdge '"
Western Edge "
NationalEdge '"
Carryover ,.
meph()n~~ ,.
f-1obilei"ledla "
BlackBerry Devices ,.
Included Features
2-Way SMS**
Caller 10
Call Waiting
Call Forwarding
Enhanced Voice Mail
Detailed BIlling
, Conference Calling
Message Waiting Indicator
LocalEdge
Additional Options
InfoEdge" #555 - 754 plus airtime
(on the Edge Wireless Network)
Wireless 101 Classes.....Freel
SpeedBllls Online Bill Pay.....Free!
Handset Insurance Available
Roadside Assistance Available
- --"-'
INCL'NIGHT MOBII.NATIONWIDE ADDT'llPLANMONTHLYANYTII-IE WEEKEND TO-LONG ROAI.-JINGACCESSMINUTES"MINUTES*f-10BILE DISTANCE'MINUTESMINUTES"
--", '-,-,--"
LocalEdge 800 $34.BOO 1500 N/C 304
t.ocalEdge 1100 $44.1100 Unlimited Unlimited N/C 304:
LocalEdge 1500 $64.1500 Unlimited Unlimited N/C 30il:
LocalEdge 2000 $79.2000 Unlimited Unlimited N/C 304New to Edge?
LocalEdge 3000 $99.3000 Unlimited Unlimited N/C 304Try our service for 30 days.
If you don t like It,LocalEdge 3500 $149.3500 Unlimited Unlimited N/C 304walk away
with no cancellation fees.LocalEdge 6000 $299.6000 Unlimited Unlimited N/C 304Click here for details.
LocalEdge 10000 $499.10000 Unlimited Unlimited N/C 30il:
LocalEdge Share $14.Unlimited Unlimited N/C 304
Add multiple lines to any LocalEdge plan $44.99 and above and share minutes with the host plan.
At least 50% of your included Anytime Minutes and Night/Weekend Minutes must be on the Edge Wireless Network Ineach billmg cycle or we mov terminate your Service.
. Included Anytime Minutes and Night/Weekend Minutes are valId for voice calls made from or received in your Rate PI"n
http://www .edgewireless.comlratesllocalEdge. h tInl 12/21/2006
EXHIBIT C
ILEC WIRE CENTERS WITHIN
EDGE WIRELESS PROPOSED ETC AREA
NON-RURAL ILEC WIRE CENTERS
Owest Communications
AMFLIDMA (American Falls)
BLFTIDMA (Black Foot)
BLSIDMA (Bliss)
BNCRIDMA (Bancroft)
BRL YIDMA (Burley)
BUHLIDMA (Buhl)
CSFRIDMA (Castleford)
DWNYIDMA (Downey)
EDHZIDMA (Eden-Hazelton)
GDNGIDMA (Gooding)
GRACIDMA (Grace)
HAL YIDMA (Hailey)
HGMNIDMA (Hagerman)
IDFLIDMA (Idaho Falls)
JERMIDNM (Jerome)
KMBRIDMA (Kimberly)
KTCHIDMA (Ketchum)
LHSPIDMA (Lava Hot Springs)
MCCMIDMA (McCammon)
MRTGIDMA (Murlaugh)
MTPLIDMA (Montpeller)
PCTLIDMA (Pocatello)
PSTNIDMA (Preston)
RBRTIDMA (Roberts)
RGBYIDMA (Rigby)
RIRIIDMA (Ririe)
RXBGIDMA (Rexburg)
SDSPIDMA (Soda Springs)
SHL YIDMA (Shelley)
SHSHIDMA (Shoshone-Dietrich)
AFTNWYMA (Tygee Valley)
TWFLIDMA (Twin Falls)
WINDLIDMA (Wendell)
PDX 1575371vl 0054189-000049
RURAL ILEC WIRE CENTERS
Albion Telephone Company
ALBNIDXC (Albion)
ALMOIDXC (Almo)
ARCOIDXC (Arco)
ELBAIDXC (Elba)
HLBKIDXC (Holbrook)
HOWEIDXC (Howe)
MSL TIDXC (Malta)
MCKYIDXC (Mackay)
MLCYIDXC (Malad)
MOORIDXC (Moore)
RFRVIDXC (Raft River)
CenturvTel of Idaho. Inc.
LEDRIDXC (Leadore)
NFRKIDXC (North Fork)
SLMNIDXC (Salmon)
Custer Communications
CHLSIDXC (Challis)
CYTNIDXC (Clayton)
EKBNIDXC (Elk Bend)
MA YIDXC (May)
STNLIDXC (Stanley)
Direct Communications
ARBNIDXC (Arbon)
PARSIDXC (Paris)
RKLDIDXC (Rockland)
Filer Mutual
FILRIDXC (Filer!)
FILRIDXC (Filer2)
HLSTIDXC (Hollister 1)
HLSTIDXC (Hollister2)
POX 1575371vl 0054189-000049
Fremont Telecom Company
ASTNIDMA (Ashton)
STATIDMA (St. Anthony)
ISPKIDMA (Island Park)
Mud Lake
DUBSIDXC (Dubios)
HAMRIDXC (Hamer)
KLGRIDXC (Kilgore)
MNVWIDXC (Monteview)
TRTNIDXC (Terreton)
Project Mutual
MNDKIDXC (Minidoka)
NRLDIDXC (Norland)
OKL YIDXC (Oakley)
P AULIDXC (Paul)
RPRTIDXC (Rupert)
Silver Star - Teton Telephone
DRGSIDMA (Driggs)
TTNIDMA (Tetonia)
VCTRIDMA (Victor)
Silver Star Communications
FRDMWYXC (Freedom)
IRWNIDXC (Irwin)
W A YNIDXC (Wayan)
PDX 1575371vl 0054189-000049
EXHIBIT D
THIS EXHIBIT ALLEGEDLY
CONTAINS TRADE SECRETS
OR CONFIDENTIAL MATERIAL
AND IS SEPARATELY FILED.
APPLICATION OF EDGE WIRELESS FOR ETC DESIGNATION
Edge Wireless :: LocaIEdge Rate Plan EXHIBIT E
Page 2 of 5
' Area. All other usage Is roaming. Night/Weekend is 7:00 p.m. - 6:59 a.lll. M-, all day Saturday and Sunday. Unlimited
'lYIR
,._
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: Mobile'to-~'obile Minutes apply only to voice calls between Edge Wireless phones that are I;OCO::/1 rprp~vp(1 and
--,-----. --
completed e_j~.vP'6~J=fiM_~,tWtlr"'~i'hsWiV&J!i~ Distance feature " cln Ular'geswill 110t apply when calling from anywhere In the U.S. to anywhere in'thcr'l.r.s. Standard alrtlm
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Way SMS iflclllcJes ~,Olnconlin9, orout9.CJlIlgI11'~ssi3ge?, per 1119.l1t"" l(hj: per additio ijl '!Icssage
( ".~~-~~-~~~.~.,-,.-
2-Way SMS 250* $4.99/Month
2-Way SMS 1000** $9.99/Month
Way SMS Unlimited $14.99/Month
10~ per additional message I . "S(j: per additional message
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View LoC;lic(!~H! rate plan area,
Expldnatio.l of RiJle~; aile! Cha'~lcs (POF)
Terms of Use I Acceptable Use Policy I Privacy Policy I Contact Us I Subscriber Terms and Conditions I Prepaid Terms and
Conditions I Return Policy I Rebate Form
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All other trademarks are the property of their respective owners.
http://www .edgewireless. comJrates/localEdge.h tml 12/21/2006
Edge Wireless :: Coverage Areas
edg WIRELES
.......a
- ~... --... -. ..........
Rate Plans & Coverage
Areas
Phones
Customer Services
Business Services
Store Locations
Ring Tones &
Games
Buy Service Online
EXHIBIT E
Page 3 of S
About Us I Careers I Press Room I Bill Pay I Send a Message " cingular'
-.......
Coverage Areas
Edge Wireless LocalEdge Rate Plan areas.
. OR/CA HD/WY
,_,_..._..
L.___.,.,-,.,
Click map for detail
Click map for detail
Rete Plan Area
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+ These maps depict the Rate Plan Area, comprised of the Edge Wireless GSM Network and the Partner Network, TDf'-1J
coverage may vary. See an Edge Wireless representative tor coverage detail. Actual coverage depends on system availabilit)
and system capacity. system repairs and modifications, customer s equipment, terrain, signal strength, weather and otl1e
http://www . edgewireless .comlrates/coverageAreas. html 12121/2006
Edge Wireless:: Coverage Areas EXHIBIT E
Page 4 of 5
conditions. Future Coverage areas are based on current build-out plans and are subject to change. Pintner Network is based OJ
, ,
e WlB&lES~information proXW8Stlij.PfeYFg,r\n iP~. 'tiK6\i.s 1 iiW~~~tl !Wlhi'~eM~it~racy. Partner Ne
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without notice.
.......... .... ...........
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View I()G)lbl(:)(~ rate plan area.
View Wpst('rnEcI(j(' rate plan area.
View Ndlionalld9C rate plan area.
View r.lobilcMedla rate plan area.
View mephone rate plan area.
View BlackBerry rate plan area.
Terms of Use I Acceptable Use Policy I Privacy POliCY I Contact Us I Subscriber Terms and Conditions I Prepaid Terms and Condlti!
Return Policy I Rebate Form
Copyright ~ 2006 Edge Wireless, llC.
All other trademarks are the property of their respective owners.
http://www . edge wire less. co mI ratesl coverage Areas. html 12/21/2006
EXHIBIT E
Page 5 ofS
i ..Edg".,.,", I '1;.
explanation of Rates and Charges:
Activation is subject to credit approval; a deposit or valid major credit card may be required.
Usage limitations may apply. If Service Limit Monitoring is required for activation, you will be
limited to a maximum of two wireless calling plans on your account.
Call Waiting, Conference Calling, Call Forwarding and Voice Mail will incur applicable airtime,
roaming and wireless long distance charges. When using the Call Waiting and Conference
Calling features, you will be charged for the minutes of use for both lines which are being utilized
during the call. If a calling card or credit card is required to complete a call , different rates apply.
Due to delayed reporting between carriers, wireless usage may be billed in a subsequent month.
This usage will be charged as if used in the month billed.
When using your device outside the Edge Wireless Networ1c, some features may not work.
Coverage is not available in all areas of the United States.
If your Rate Plan includes a predetermined allotment of services (for example, a predetermined
amount of airtime or text messages), any unused allotment of services from one billing cycle will
not carry over to any other billing cycle.
Fees: Reconnection - $25 per line; Returned Check Charge - $20; InfoEdge - 751# per call (while
on the Edge Wireless Netwof'1() plus airtime, roaming and wireless long distance. If you have any
questions. please call 611, free of charge from your wireless device while on the Edge Wireless
Network, or call 1- 866-221-EDGE (3343),
Plan rates may not be available when using your phone outside the United States; International
wireless long distance not included. May not be combined with certain wireless offers and
promotions.
approved
EXHIBIT F
Page I of2
IDAHO PUBLIC UTILITIES COMMISSION
IDAHO 208-334-0300
APPROVED TITLE 61 TARIFFS - PRICE LISTS
'0
Albion Telephone Company, Incl dba ATC - Local Exchange Tariff
Cambridge Telephone Company, Inc. Local Exchange Tariff
CenturyTel ofIdaho, Inc./dba CenturyTel - Local Exchange Tariff
CenturyTel ofthe Gem State, Inc./ dba CenturyTel - Local Exchange Tariff
Citizens Telecommunications Company ofIdaho Local Exchange Tariff
Citizens Telecommunications Company ofIdaho Access Service Tariff
Direct Communications Local Exchange Tariff
Fremont Telecom Company Local Exchange Tariff
Idaho Rural Exchange Carriers Pages I - 203 1- Access Service Tariff
Idaho Rural Exchange Carriers Pages 204 - 406 Access Service Tariff
Inland Telephone Company - Local Exchange Tariff
Midvale Telephone Exchange, Inc. - Local Exchange Tariff
Midvale Telephone Exchange, Inc. - Access Service Tariff
Oregon-Idaho Utilities, Inc. - Local Exchange Tariff
Potlatch Telephone Company - Local Exchange Tariff
Sections 1 - 4
Sections 5 - 7
Sections 8 - 11
Rural Telephone Company - Local Exchange Tariff
Silver Star Communications - Local Exchange Tariff
http://www.puc.state.id.us/tariffiapprovediTitle61/approved.htm 12/21/2006
approved
EXHIBIT F
Page 2 of 2
Teton Telecom - Local Exchange Tariff
http://www.puc.state.id.us/tariff/approved/Title61/approved.htm 12/21/2006
EXHIBIT G
, '.,\; '
1~ i"'iIf'.
~.,~:;;, \;., ' '" ,
r;p
PUBLIC UTILITIES COMMISSION
STATE OF CALIFORNIA
505 VAN NESS AVENUE
SAN FRANCISCO, CALIFORNIA 94102
RACHEL!.E CHONG
COMMI$810Nltft December 7, 2006
TEL: 14 15) 70~-3700
FAX: [phone]
Donnie Castleman, President
Edge Wireless
650 SW Columbia
Suite 7200
Bend, OR 97702
Re: Edge s Assistance to Authorities in Locating the James Kim Family
Dear Mr. Castleman:
I wanted to commend your two employees, Eric Fuqua and Noah Pugsley, who
spent long hours assisting search and rescue teams to help locate the James Kim family of
San Francisco, eventually providing key information that Oregon authorities say helped
locate and rescue Kati Kim and her two young daughters. I praise your employees
dedication, determination and ingenuity in using wireless technology to help authorities
focus on a particularly geographic area where the family was likely to be. I also thank
Edge for making available a temporary cell-on-wheels and 30 wireless phones to search
and rescue teams, so they could communicate. While I am deeply saddened by the loss of
James Kim who died in a heroic attempt to seek help for his family, we cannot forget that
without the efforts of so many good-hearted people like your employees, Mr. Pugsley and
Mr. Fuqua, we may have lost Kati and the children.
Please extend my sincere thanks and congratulations on a job well done to both
them and to your company for your lifesaving assistance to the authorities.
cc:Eric Fuqua
Noah Pugsley
Steve Largent, CTIA CEO and President
Stan Sigman, Cingular CEO and President
EXlliBIT H
----
---0--
December 17, 2006
Jeff
Several months ago our 911 dispatch center received a call requesting
medical assistance for man who had fallen ITom a horse and had a broken his
leg. The location was described as in the Mount Independence area. The
area is somewhat remote and very large. We determined that the caller was
using an Edge Wireless phone. We contacted Edge Wireless, explained the
situation. Very soon they called use back informing us that three 911 calls
had hit a cell site in Twin Falls and one had been received at a cell site in, I
believe the Hansen area. They told us that the sectors that had received the
call would indicate the can came ITom southeast of Twin Falls. The
information helped us determine what side of the Mountain the injured man
was located and we were able to concentrate our search. Our emergency
workers located the man and he was air lifted to the hospital. The
information given by Edge was extremely valuable in finding the patient and
transporting him to advanced medical help.
Recently, a young man caned our 911 center threatening suicide. We
contacted Edge to find out what area he was caning ITom. However, before
we faxed our written request to Edge we located the young man. However
Edge was very willing to help us.
Thanks for your help,
Kent R. Searle
Cassia County 911 coordinator
Edge Wireless:: LocalEdge Rate Plan
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Rate Plans & Coverage
Areas
Phones
Customer Services
Business Services
Store Locations
Ring Tones &
Games
Buy Service Online
New to Edge?
Try our service for 30 days.
If you don t like it,
walk away
with no cancellation fees.
Clid; here for details.
EXHIBIT I
Page 1 of S
About Us I Careers I Pre.. Room I Bill Pay I Send a Message cingular'-_os
lifeline
For eligible Oregon residents, the UfeUne Plan is an economical way to
enjoy the convenience and utility of digital wireless service. You won
pay long distance charges as long as you re calling to anywhere In the
50 United States.
All plans also offer features like call waiting, voice mall, and call
forwarding,Edge Rate Plans
Loc.aIEdg'~ ,.
West:ernF.clqe ,.
NdtionalEdgc '"
Included Features
2-Way SMS**
Caller ID
. Call Waiting
Call Forwarding
Enhanced Voice Mall
Detailed Billing
Conference Calling
Message Waiting Indicator
LifeLine
Carryover '"
rneph(Hi". ,.
1'1obilei'leclia '"
BI?cU3.::rry Devices ,.
Additional Options
InfoEdge" #555 - 754 plus airtime
(on the Edge Wireless Network)
Wireless 101 Classes.....Free!
Speed Bills Online Bill Pay..,..Free!
Handset Insurance Available
Roadside Assistance Available
INCL'NIGHT!NOBIlE-NATIONWfDE ADDT'l/MONTHLY TO-PLAN ACCESS AN'fTIME WEEi(END MOBILE lONG ROAHING
MINUTES'MINUTES'MINUTES'OISTM~CE"j-7rNUTES
UfeUne 800 $21.49 800 1500 N/C 304
LifeLIne 1100 $31.49 1100 Unlimited Unlimited N/C 30q:
u. After $13.50 Lifeline subsidy.
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111;
Roaming and International calling are available subject to approved credit or with a
security deposit. Security deposit may be waived If you elect to block roaming and
international dialing. If you elect to block roaming, your phone will not work on the
Partner Network (see map below).
You are eligible to participate in the Edge Wireless LIfeLIne Rate Plan if you receive
assistance from one of the following programs:
" --,_..,--------,---,-, --. ---
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_..- -_.----..-
.Food Stamps ,Welfare Medical ID Card .Temporary Assistance for Needy Families
http://www edgewi reless .comlrates/lifeLine. html 12/22/2006
Edge Wireless:: LocalEdge Rate Plan
edg~WJ~EL~SS
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EXHIBIT I
Page 2 of 5
.Oregon Health Plan .Supplemental Security Income
About Us I Careers I Press Room I Bill Pay I Send a Message
::'
cingu ar'
-,- ----- '-'"---.,,-- - ---'------ ,-_. ----, --,---,._---------,-,-,..-_._._-,----"._-------".--!!!!~
It.
You must certify through the Oregon Telephone Assistance Program (OTAP) by calling
[phone]. or online at www.rc;pf,or9. lifeline subsidies may only be applied once
per household on either your land line or your wireless service. Lifeline subsidies
automatically terminate upon loss of eligibility, and monthly access rates will increase
by $13.50, Any reduction In the available lifeline subsidy will increase monthly access
rate by the same amount.
" Included Anytime Minutes and Night/Weekend Minutes are valid for voice calls made from or received in
your Rate Plan Area. All other usage is roaming. Night/Weekend is 7:00 p.m. - 6:59 a.m. M-F, all daySaturday and Sunday. Unlimited Moblle-to-Mobile Minutes apply only to voice calls between Edge Wirelessphones that are placed, received and completed entirely on your local Edge Wireless Network. WithNationwide Long Distance feature, long distance charges will not apply when calling to anywhere in the50 United States, Standard airtime and roaming charges apply. At least 50% of your Included Anytime
Minutes and Night/Weekend Minutes must be on the Edge Wireless Network In each billing cycle or we
may terminate your Service.
u 2 - Way SMS Includes 50 incoming or outgoing. messages per month
, ,
lOct_peradd"itional ITIe.ssa
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Code
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2-Way SMS 250* $4.99/Month
2-Way SMS 1000** $9.99/Month
2-Way SMS Unlimited $14.99/Month
104 per additional message I "SIt per addition,ll message
- .::-
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"'""'- ,;",,
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View LifeUnc rate plan area,
l.';q):Cln"UO!i 0f P",le5 dnd CrliJ"~if:" (f'Dr:i
Terms of Use I Acceptable Use Policy I Prillacy Policy I Contact Us I Subscriber Terms and Conditions I Prepaid Terms and
Conditions I Return Polley I Rebate Foml
Copyright If) 2006 Edge Wireless, LLc.
All other trademarks are the propelty of their respectille owners.
http://www .edgewireless.comlratesllifeLine. html 12/22/2006
Edge Wireless:: LocalEdge Rate Plan
edae WIRELESSe0---'--"-'-""'
-..oo.... ~... ",.......... w,...... ....wo..
Rate Plans & Coverage
Areas
Phones
Customer Services
Business Services
Store Locations
Ring Tones &
Games
Buy Service Online
New to Edge?
Try our service for 30 days.
If you don t like it,
walk away
with no cancellation fees.
Click here for details.
EXHIBIT I
Page 3 of 5
About Us I Careers I Press Room I Bill Pay I Send a Message
..
cingular'
-.....
lifeLine
For eligible Oregon residents, the lifeline Plan Is an economical way to
enjoy the convenience and utility of digital wireless service, You won
pay long distance charges as long as you re calling to 'anywhere in the
50 United States.
All plans also offer features like call waiting, voice mall, and call
forwarding.Edge Rate Plans
LocaIEdgl': ,.
WeSlernEdge ,.
~atimlaIEdge "
Carryover ,.
Included Features
2-Way SMS**
Caller 10
Call Waiting
Call Forwarding
Enhanced Voice Mall
Detailed BIlling
Conference Calling
Message Waiting Indicator
LifeLine
Additional Options
InfoEdge" #555 - 751t plus airtime
(on the Edge Wireless Network)
Wireless 101 Classes.....Freel
Speed Bills Online Bill Pay.....Free!
Handset Insurance Available
Roadside Assistance Available
mcphonrc
' ,.
Mobilei'h'dia ,.
BlackBerry Devices ,.
'.,ONTHL Y INCL'NIGHT /
PLAN ACCESS ANYTIME WEEKEND
MINUTES"MINUTES"
lifeline 800 $21.49 ,..800 1500
',10BILE.NATIONWIDE I\OD1"TO-LONG ROAf-lXNG!'IOBILE DISTANCE'MINUTESMINUTES'
N/C 301t
Unlimited N/C 304lifeline 1100 $31.49
... After $13,50 lifeline subsidy.
1100 Unlimited
,,-,,- -"'--",""", _..",-"""--"-,"""""""""""'-'-""'" "- "" "
- n_
"", ,..,-" ,-- "--,,-,,--""-" -",""""-,, -""----
Roaming and international calling are available subject to approved credit or with a
security deposit. Security deposit may be waived If you elect to block roaming and
international dialing, If you elect to block roaming, your phone will not work on the
Partner Network (see map below),
f~j You are eligible to participate in the Edge Wireless lifeline Rate Plan if you receive
assistance from one of the following programs:
'--, ",,-----,,--, "--"--"'-"
n""--,_"
"",--"-"-,,,,,-,-_..,,-,,,,,---,,--.."-""-""--,--,,-,,,,--,,--,--,,,"----"-- ,
"...,nmn"""",
Food Stamps .Welfare Medical ID Card .Temporary Assistance for Needy Families
http://www ed gewireless.comlrates/li feLine.html 12/22/2006
Edge Wireless:: LocalEdge Rate Plan
e.-dgeW'RE~E
........ .. "... e,........
-....... ...--..
EXHIBIT I
Page 4 of 5
.Oregon Health Plan .Supplemental Security Income About Us I Careers I Press Room I Bill Pay I Send a Musage clngu ar'
,----,-- ,-----------------,,--, ------"'------- -- --,---- ,---- -----,----------,-
You must certify through the Oregon Telephone Assistance Program (OTAP) by calling
[phone], or online at w\'/W,rspf,or9. lifeline subsidies may only be applied once
per household on either your landllne or your wireless service. Lifeline subsidies
automatically terminate upon loss of eligibility, and monthly access rates will Increase
by $13,50. Any reduction in the available Lifeline subsidy will increase monthly access
rate by the same amount.
* Included Anytime Minutes and Night/Weekend Minutes are valid for voice calls made from or received in
your Rate Plan Area. All other usage is roaming. Night/Weekend is 7:00 p.m. .. 6:59 a.m. M-F, all day
Saturday and Sunday. Unlimited Mobile-to-Mobile Minutes apply only to voice calls between Edge Wireless
phones that are placed, received and completed entirely on your local Edge Wireless Network. With
Nationwide Long Distance feature, long distance charges will not apply when calling to anywhere in the
50 United States. Standard airtime and roaming charges apply. At least 50% of your Included Anytime
. Minutes and Night/Weekend Minutes must be on the Edge Wireless Network In each billing cyde or we
may terminate your Service.
- ** 2:Way SMS inc:.ludesSOincol11ing ~routg,oing .rn.essa9~s per l1"I()n
/,_
cLRer_i3d.Q.lt!onal I11_~ssa.g.
---
meSSaGinG
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Code
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90.\Lt~"
Way SMS 250" $4.99/Month
Way SMS 1000** $9.99/Month
2-Way SMS Unlimited $14.99/Month
101t per additional message I .. Sit per additional message
-.-.: :':......: :._~' ""'-'" .;:.;.."""," '..,.,:---.-~\\:,~--
View LifeLine rate plan area,
l'xpL:rniJtlon of Rates and ChiW)CS (PDF)
Tenns of Use I Acceptable Use Policy I Privacy Policy I Contact Us I Subscriber Terms and Conditions I Prepaid Terms and
Conditions I Return Policy I Rebate Fonn
Copyright (f) 2006 Edge Wireless, LLC.
All other trademarks are the property of their respective owners.
http://www . edgewireless .comlratesllifeLine. html 12/22/2006
EXHIBIT I
Page 5 of 5
. ~
.1 e Ine
Explanation of Rates and Charges:
Activation is subject to credit approval; a deposit or valid major credit card may be required.
Call Waiting, Conference Calling, Call Forwarding and Voice Mail will Incur applicable airtime, roaming and
wireless long distance charges. When using the Call Waiting and Conference Calling features, you will becharged for the minutes of use or both lines which are being utilized during the call. If a calling card or
credit card is required to complete a call, different rates apply.
When using your device outside the Edge Wireless Network, some features may not work. Coverage Is notavailable in all areas of the United States.
If your Rate Plan Indudes a predetermined allotment of services (for example, a predetermined amount of
airtime or text messages), any unused allotment of services from one billing cycle will not carry over to any
other billing cycle.
Fees: Reconnectlon - $25 per line; Returned Check Charge - $20; InfoEdge - 75q: per call (while on the
Edge Wireless Network) plus airtime, roaming and wireless long distance. If you have any questions, please
call 611, free of charge, from your wireless device (while on the Edge Wireless Network) , or calll-
B66-350-EDGE (3343).
Plan rates may not be available when using your phone outside the United States; International wireless
long distance not Included. May not be combined with certain wireless offers and promotions.