20141222Application.pdf

r]-*-FiVs--Etb,Eilb'[-Ul'E[tFE
Eastside Marketplace
P.O. Box 9587
Moscow Idaho 83843
208-882-8869
December 19,2014
Ilia FedEx
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 W . Washington Street
Boise,Idaho 83702 tr5t-T-\4-ol
Re: First Step Internet, LLC
Application for Des ignation as an Eligible Telecommunications Caruier.
First Step Intemet, LLC ("FSI") files an original and seven (7) copies of the enclosed
"Application of First Step Intemet, LLC for Designation as an Eligible Telecommunications
Carier for the Purposes of Participating in the FCC's Rural Broadband Experiments and Request
for Expedited Consideration."
Please date-stamp the enclosed "Stamp and Return" copy and return it to our oftices via
the enclosed, prepaid envelope.
Please contact the undersigned if you have any questions regarding this submission.
Respectfully submitted,
First Step Internet, LLC
Title: President
w. {8fl? lir?'"oy%o"t5* I . . Gt+ s ervic e s @rsr. ne t www. rsr. net
CERTIFICATION
I certifr under penalty of perjury under the laws of the State of Washington that the
foregoing is tnre and correct.
December 19, 2014, Moscow Idaho
Kevin Owen
2
{00023594.DOCX.r}
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
In the Matter of Application of )
First Step Internet, LLC for )
Designation as an Eligible Telecommunications ) Docket:
Carrier for Purposes of Participating in the )
Federal Communications Commission's )
Rural Broadband Experiments
APPLICATION OF FIRST STEP INTERNET. LLC FOR
DESIGNATION AS AN ELIGIBLE TELECOMMUNICATIONS CARRIER
FOR THE PURPOSES OF PARTICIPATING IN THE
FCC'S RURAL BROADBAND EXPERIMENTS AND
REOUEST FOR DGEDITED CONSIDERATION
First Step Internet, LLC (*FSI"), prrsuort to 47 U.S.C. $ 2la(e)(2),47 C.F.R. $ 54.101,
Idaho PUC OrderNo. 29841 ("ETC Order")r and IDAPA 31.46.01 et seq. ("Commission Rules"),
applies to the Idaho Public Utilities Commission (the "Commission") for designation as an Eligible
Telecommtrnications Carrier (*ETC") to serve the service area set forth herein.2 On December 5,
2014, the Federal Communications Commission announced that FSI was provisionally selected
for funding under the agency's Rural Broadband Experiments ("RBEs"), which are "focused on
bringing robust, scalable broadband networks to residential and small business locations in rural
communities that are not served by an unsubsidized competitor that offers voice and Internet
access delivering at least 3 Mbps downstream/768 kbps upstream."3 Funding is contingent on FSI
demonstrating that it meets the FCC's technical and financial qualifications, including obtaining
ETC designation from this Commission by March 5,2015 for the Service Area.a
I Application of WWC HoldingCo., Inc. dbaCellular-On@ Seeking Designation as an Eligible
Telecommunications Carrier that May Receive Federal Universal Serttice Support, Case No. WST-T-05-1, Order
No. 29841 (rel. Aug. 4, 2005)('Idaho ETC Order").
2 See Exhibit 1.
3 Connect America Fund; ETC Annuol Reports and Certifications, Report and Order and Further Notice of hoposed
Rulemaking WC Docket Nos. 10-90, 14-58, FCC 14-98 (rel. Jul. 14, 2014) ("RBE R&O") at !p.a llireline Competition Bureau Announces Entities Prwisionally Selectedfor Rural Brosdband Experimentls; Sels
Deadlines for Submission of Additional Information, WC Docket No. 10-90; DA 14-1772 (rel. Dec. 5,2014). See
Exhibit 2.
ETC designation by this Commission is, therefore, a prerequisite for FSI's eligibility for
RBE funding. Specifically, the FCC states that'\ru'e expect entities to confirm their ETC status
within 90 days of the public notice announcing the winning bidders selected to receive funding."s
FSI therefore, must receive ETC designation before March s,2}ls,which is the 90tr day from the
date that the FCC issued its Public Notice announcing the provisionally selected bidders.6 In light
of the above timeline, FSI is seeking expedited appreval and requesting that the ETC designation
requested herein be made conditional and effective upon it being awarded the associated funds.
As demonstrated inthis Application, FSI satisfies all the ETC requirements ofthe FCC and
the State of Idaho and designation will be in the public interest.
1. Identification of the Companv
FSI is a facilities-based, regional Internet Service Provider that has been providing Internet
access services since 1994. FSI began offering dial-up Internet access with the idea of making
Internet access available to virtually everyone in FSI's service areas. FSI services have evolved
to include fixed broadband lnternet access services to customers in eastern Washington and in
north/central ldatro. FSI obtained Round I Broadband Technology Opportunities Program funding
for regional broadband network services in Latatu Clearwater, Nez Perce, Lewis and Idaho
counties. FSI provides a variety of fixed terrestrial broadband services, including dial up, DSL,
fiber, cable Internet and fixed wireless broadband services. FSI also offers voice services using
Voice over lnternet Protocol ('VoIP") technology. On January 22,2013, the Idaho PUC issued to
5 RBE R&O atfB2.
6 Because the order designating FSI as an ETC is a part ofthe FCC's RBE process, FSI needs to have such an order
in hand before March 5, 2015 (ideally before the end of February 2015), if at all possible.
FSI a registration .N a wholesale provider of local telecommunications services within ttre State of
Idaho and is a competitive wholesale provider.T
The contact information for FSI is as follows:
Kevin Owen, President
First Step Internet, LLC
1420 S. Blaine Sfteet
Moscow,Idaho 83843
208-882-8869
2. The Rural Broadband Exneriments
In connection with its adoption of comprehensive reform of the universal service system,
inNovember}}ll, the FCC createdthe ConnectAmericaFund.s Inthe USF/ICC Transformation
Order, the FCC adopted a firm annual budget of $4.5 billion over a five-year period to, among
other things, direct funds toward new advanced networks in rural and insular communities, to
phase out funding for legacy networks and to eliminate some redundant support in specific
locations. As adopted in the USF/ICC Transformation Order, CAF includes several different
mechanisms, including one for price cap territories, one for rate-of-return carriers, a Mobility Fund
that is designed to ensure availability of mobile broadband networks and a Remote Areas Fund
that is designed to direct frrnding to the most remote areas in the nation. In July 2014, the FCC
took further steps to implement the Connect America Fund by authorizing use, on a limited scale,
of Connect America funding for rural broadband experiments in price cap areas, and the FCC
opened a formal application process to seek this Federal support.
7 Application of First Step Internet, LLCfor Registration as a Wholesale Telecommunications Provider in ldaho,
Case No. FSI-T- 12-01, Order No. 32721 (rel. Jan. 22,2013').
8 Connect America Fund, WC Docket No. 10-90, A National Broadband Planfor Our Future, GN Docket No. 09-
51, Establishing Just and Reasonqble Ratesfor Local Fscchange Carriers, WC Docket No. 07-135, High-Cost
Universal Service Support, WC Docket No. 05-337, Developing an Unified Intercarrier Compensation Regime,CC
Docket No. 0 I -92, Federal State Joint Board on Universal Service, CC Docket No. 9645, Lifeline and Link-up, WC
Docket No. 03-109, Universal Service Reform - Mobility, WT Docket No. 10-208, Report and Order and Further
Notice of Proposed Rulemaking, FCC I l-161, rel. November 18, 201I ('USF/ICC Transformation Ordef')
3. This Commission Has the Authoritv to Desienate FSI as an ETC
Federal law allows states to exercise the authority to designate a qualified carier as an
ETC.e The state of Idaho has accepted the grant of authority and empowered this Commission to
designate qualified cariers as ETCs.ro Thus the Commission has the authority under state law to
designate a qualified carrier as an ETC.
4. FSI Is Oualified to be Designated as an ETC
Both the FCC and this Commission have adopted rules that specifr the requirements for
cariers to be designated an ETC. FSI satisfies or will within a reasonable time after designation,
satisff all the relevant requirements for designation as an ETC specified in federal lawll and those
under state law.12 In summary, FSI (i) is a common carrier with respect to the telecommunications
services that it offers, (ii) is capable of providing and will continuously provide throughout its
proposed service area the universal services set forth in 47 C.F.R. $5a.101(a) either by using its
own facilities or a combination of its own facilities and resale of another carrier's facilities, (iii)
will advertise the availability of its universal service offering and charges through media of general
distribution, (iv) demonstrates herein that the ETC designation is consistent with the public
interest, convenience, and necessity, (v) is not seeking ETC designation for any part of hibal lands,
(v) has the commitment and ability to provide supported services based on the criteria set forth in
Section B.l of the ldaho ETC Order, (vi) has a reasonable amount of back-up power to ensure
functionality without an external power source, is able to re-route tralfic around damaged facilities
and is capable of managing traffic spikes resulting from emergency situations, (vii) will comply
with the annual reporting requirements set forth in Section C of the ldaho ETC Order.
e 47 u.s.c. g 2la(e).
to ldaho ETC Order at2.tr 47 U.S.C. $ 2la(eXl).
t2 See, generally, Idaho ETC order.
Demonstration that FSI meets or exceeds each of the above requirements of federal and state
law is provided in the following corresponding sections:
Common Canier Status. FSI provides telecommunications services within its
coverage area on a nondiscriminatory basis and therefore for those services is regulated as
and subject to the requirements applicable to a common carrier. Accordingly, FSI meets
this requirement of ETC designation.
Commitment and Ability to Provide Supported Services. FSI operates in Idaho and
in Washington state and provides service in very rural areas. FSI clearly has the technical
qualifications and experience and upon receipt of RBE funding will have the further
financial ability to bring service to those census blocks identified by the FCC. As indicated
in this Application, FSI is a Federal Broadband Technology Opportunities Program award
recipient and was required in that program to demonstrate its technical and financial
capabilities.
FSI is a facilities-based service provider. FSI will use a combination of its own
network and facilities and resale of another carrier's services to provide selice, as
permitted by 47 U.S.C. $2la(e)(l)(A). FSI is capable of providing (a) voice grade access
to the public switched telephone network; (b) minutes of use for local service provide at
no additional charge to end users; (c) access to emergency services provided by local
government or other public safety organizations (such as 9ll and enhanced 911) to the
extent the local government in the eligible carrier's service area has implemented 911 or
enhanced 911 systems; and (d) toll-limitation services for qualifting low-income
consumers. FSI's voice services interconnect with, and provide voice-grade access to, the
Public Switched Telephone Network, and FSI relies on local-exchange-carier partners
with regard to physical interconnection, peering, numbering resources, local number
portability, call termination and other service. FSI does not meter local calls and in fact
treats local and non-local calls as equivalents, thereby eliminating the need for toll-
limitation for low-income consumers. FSI plans to offer Lifeline services for $15.75 per
month (after accounting for the $9.25 per subscriber support for qualiffing Lifeline
customers) for the residential voice service described herein, including trnmetered long
distance. Qualiffing Lifeline customers will be permiued to apply the Lifeline discount to
bundled voice and data services in lieu of a discounted broadband-only plan for low-
income consumers. In sum, these are the supported services that a carrier must provide
and that are supported by universal service funds. FSI, therefore, satisfies this requirement
for ETC designation.
Advertise the Avqilability of Supported Services FSI currently advertises the
availability of supported services through media of general distribution, consistent with 47
U.S.C. $21a(e)(l)(B). It utilizes newspapers, radio, its website, and other direct advertising
methods throughout its service area. FSI will expand upon these media, as necessary, to
ensure that consumers within its ETC designated area are fully informed of its universal
service offerings. FSI, therefore, will satisfr this requirement for ETC designation.
ETC Designation is Consistent with the Public Interest, Convenience and
Necessity. The FCC has taken steps to advance the public interest through the RBEs to
"advance the deployment of voice and broadband-capable networks in rural, high-cost
areas, including extremely high-cost areas, while ensuring that rural Americans benefit
from the historic technology transitions that are informing our nation's communications
services."l3 The ETC designation will allow rural areas that the FCC has deemed unserved
to become served with broadband and voice services that meet FCC-defined metrics.
Tribal NotiJicaffon. FSI is not seeking ETC designation for any part of Tribal lands
and does not propose to install any equipment within Tribal borders. The FCC's
designation of the census blocks identified in Exhibit I did not identift any as being on
Tribal lands.
Commitment and Ability to Provide Supported Services. Pursuant to the ldoho
ETC Order, ETC applicants are required to demonstate that they are capable of
providing and will continuously provide throughout the proposed service area the
services identified in 47 C.F.R. $sa.lOl(a), as FSI has demonstrated above.ra FSI
certifies that it will (a) provide service on a timely basis to requesting customers within
the applicant's service area where the applicant's network already passes the potential
customer s premises; and (b) provide service within a reasonable period of time, if the
potential customer is within the applicant's licensed service area but outside its existing
network coverage, if service can be provided at reasonable cost by (i) modiffing or
replacing the requesting customer s equipment; (ii) deploying roof-mounted antenna or
13 RBE R&o atlft.
14 At the time the Idatro ETC Order was issued, the supported services under 47 C.F.R. $5a.101(a) included Voice
grade access to the public switched network; Local calling; Touch tone signaling or its functional equivalent; Single-
party service or its functional equivalent; Access to 9l I emergency services where available; Access to operator
services; Access to long-distance service; Access to directory assistance; and Toll limitation service. Idaho ETC
Order at Appendix Page 1. lnthe USF/ICC Transformation Order in 201l, the FCC modified 47 C.F.R. $5a.l0l(a)
to speciff the following: "Voice Telephony services shall be supported by federal universal service support
mechanisms. Eligible voice telephony services must provide voice grade access to the public switched network or its
functional equivalent; minutes ofuse for local service provided at no additional charge to end users; access to the
emergency services provided by local government or other public safety organizations, such as 9l l and enhanced
9l l, to the extent the local government in an eligible carrier's service area has implemented 9l I or enhanced 911
systems; and toll limitation services to qualifying low-income consumers as provided in subpart E of this part."
other equipment; (iii) adjusting the nearest cell tower; (iv) adjusting network or customer
facilities; (v) reselling services from another carrier s facilities to provide service; or (vi)
employing, leasing or constructing an additional cell site, cell extender, repeater, or other
similar equipment. FSI will provide the required two-year network enhancement plan,
which will start initially withthe build-out of the new network that FSI intends to cover
based on the areas proposed in FSI's RBE filing.
Exhibit 3 contains a two-year network improvement plan that describes FSI's
proposed improvement or upgrades to FSI's network throughout its proposed designated
service area. The plan demonstrates how signal quality, coverage and capacity will
improve due to receipt of high-cost support project start dates and completion dates for
each improvement and the estimated amount of investment for each project that is funded
by high-cost support, specific geographic areas where improvements will be made and
the estimated population that will be served.
Ability to Function in Emergency Situations. FSI will have the ability to remain
functional in emergency situations as required by FCC rules and by the ldaho ETC
Order.rs Specifically, FSI will have adequate amounts of back-up power to ensure
functionality without an external power source, and FSI maintains a redundant middle-
mile/backbone network with redundant paths and network rings. Power outage protection
is available at all site either by means of significant battery backup or gas-powered
generators. FSI satisfies this requirement for ETC designation.
Consumer Protection Requiremenrs. FSI complies with applicable consumer
protection and service quality standards specified by the FCC. FSI's wireless services
'5 47 CFR. Ssa.202(a)(2)
are fixed wireless, rather than mobile wireless; therefore, FSI intends to comply with
those portions of the CTIA Consumer Code that are applicable to fixed-wireless services.
The FCC has determined that commitrnent to comply with the CTIA Consumer Code
satisfies this requirement for ETC designation.l6
Comparable Local Usage Plans. FSI is committed to offering local usage plans
comparable to those offered by the incumbent LECs in the service areas for which it
seeks ETC designation. FSI's residential voice plan is $25 per month for unmetered local
and non-local calling, and additional feafires are provided at no extra charge, such as
Caller ID with rurme and voicemail. FSI commits to continue offering a local usage plan
comparable to that offered by the incumbent LECs within its ETC designated area to the
extent still applicable in Idaho and, therefore, satisfies this requirement for ETC
designation if applicable.
5. Desirmation Is in the Public Interest
The FCC and this Commission have outlined various criteria relevant to the Public lnterest
determination. Most of these have been addressed in the above discussion, and others will be
addressed below. With respect to the RBEs, the FCC has outlined and imposed specific public
interest obligations on successful RBE recipients that if not fulfilled can result in revocation of
support. The FCC imposed, among others, the following: (i) requirements to comply with all
relevant universal service rules, (ii) build-out requirements, including deadlines and certification
requirements, for all recipients; (iii) annual reporting requirements under Section 54.313 of the
FCC's rules and annual certifications required under Section 54.314 of the FCC's rules, (iv)
requirements to meet FCC latency standards, (v) record retention requirements, and (vi)
9
16 47 CFR $5a.202(aX3).
compliance reviews and investigation. FSI will meet each of these requirements and thus advance
the public interest. The Application on its face is demonstrated to be in the public interest. As
described above, this Application is for conditional ETC designation specifically to enable FSI to
submit accept its RBE award. This award will provide ongoing support to immediately accelerate
deployment of networks for voice and broadband services in unserved areas. The FCC has already
determined the census blocks in Exhibit I qualifu for these funds, subject to the outcome of the
FCC's ongoing Connect America Fund Phase II challenge process. If any ofthe census blocks are
later deemed ineligible for funding as a result of that process, support will be adjusted
proportionally. FSI is therefore one of the few or only operators that is qualified and uniquely
positioned as a predominately rural wireless operator to accelerate deployment of networks for
voice and broadband services in these unserved census blocks. It is, therefore, clearly in the public
interest to approve this Application to assure a bidder is available and to condition it on FSI being
the successful bidder.
The overarching principles embodied in the Telecommunications Act of 1996 that continue
to guide the FCC's USF Transformation Order are the promotion of competition and the
deployment of higher quality services and the rapid deployment of new telecommunications
technologies. Conditional designation and successful bidding by FSI will increase customer choice
and service availability and will make available new service offerings, including wireless
broadband and Lifeline services as the areas where the funds are to be used are presently unserved.
Unserved will have service. This Application is clearly in the public interest, and approval of this
Application is requested on an expedited basis.
6. Certifications
FSI certifies that all federal high-cost support provided to FSI for service areas in Idatro
will be used only for the provision, maintenance and upgrading of facilities and services for which
the support was intende{ consistent with Section 25a@) of the Communications Act. No party to
this application is subjectto denial of federal benefits under Section 5301 of the Anti-Drug Abuse
Actof 1988. 17
REOT'EST FOR RELIEF
FSI respectfully requests the following: (i) that the Commission expeditiously designate
FSI as an ETC in the census blocks identified in Exhibit 1, determined by the FCC to be unserved,
conditioned on FSI actually receiving RBE funds; (iD that the Commission send prompt notice of
the designation to the FCC and the Universal Service Administative Company; and (iii) for such
other relief as may be appropriate.
Respectfully submitted,
Kevin Owen, President
First Step Internet, LLC
t7 2l usc $862.
ll
EXHIBIT 1- SERVICE AREA
150359701004629
1503s9701004679
1603s9701004580
1603s9701004684
150499502001020
160499602001040
160499602001041
160499602001050
150499602001052
160499602001061
160499602001062
160499602001075
160499602001076
160499602001088
160499602001089
150499602001091
150499602001095
160499602001106
160499502001108
160499602001109
150499602001112
150499502001115
160499502007LL7
160499602001120
16049960200LL22
16049960200LL23
160499602001125
150499602001132
160499502001133
150499502001134
150499602001137
160499602001146
160499502001150
160499602001169
160499602001195
150499602002000
160499502002001
160499602002002
150499502002023
160499502004065
L604996020o4074
160499602004077
160499602004L29
160499602004131
160499602004t32
160499602004134
160499602004136
160499602004204
150499602004787
150499602004288
160499502004294
16049960200s036
150499502005041
15049960200s045
160499602005046
150499602005049
16049960200s050
150499602005053
16049960200s0s4
16049950200505s
16049960200s0s8
16049960200sO74
1604996030022s2
160570051002003
150570051002004
1505700s1002015
1505700s1002018
160570051002022
150s7005200Lo22
160570052001048
160s70053006011
1605700s3006034
150570054002048
r60570055001251
150570055002055
150570055002133
150s700550021s0
16057005s003006
150570055003036
160s700s5003047
160s70055004020
1505700s6001182
l3
160s70056001186
1605700s6001191
160570056001204
160s7005600t274
16057005600L275
1605700s600L279
160s7005600t282
150s70056001283
160s70056001284
150s70056001285
160s70056002001
160570056002012
1605700s5002013
160s70056002021
160570056002027
160570056002074
1605700s6002106
150570057001062
150570057003025
150599603001089
150599603001098
150599603001160
160599603002LL9
160699507001001
160599607002010
160699607002011
150699607002039
Blocks by State
Washington
ldaho
I
T
EXHIBIT 2 - FCC PUBLIC NOTICE
DAt4-1772
Released: December 5, 2014
WIRELII\-E COMPETITION BUREAU AITNOT'NCES ENTITIES PROVISIONALLY
SELECTED FOR RI]RAL BROADBAI\ID EXPERIMENTS; SETS DEADLINES X.OR
SUBMISSION OT' ADDITIONAL INFORMATION
WC Docket No. 10-90
On November 7,2014, the Federal Communications Commission closed the application
window for the rural broadband experiments. By this date, applicants were required to complete
FCC Form 5610 and attach project bid forms, a descriptive data form listing all of their proposed
projects, and certain other project information.ls Subsequently, the FCC Auction System ranked
the submitted bids meeting requirements for the rural broadband experiments from the most cost-
effective to the least cost-effective within each funding category.
This Public Notice announces the bidders that have been provisionally selected for
funding in each category, subject to the post-selection review process. Each identified bidder
must complete certain steps in order to be authorized to receive Connect America Fund support
for its rural broadband experiment.
Attachment A provides sunmary information conceming the provisionally selected
bidders, including the number of project bids, the states in which these proposed projects are
located, the total amount of support requested for these projects, and the total number of census
blocks covered by these projects.le These bidders are seeking support to serve diverse
geographic areas with different cost characteristics. Collectively, they have bid on support to
cover 26,867 census blocks in 25 states and Puerto Rico2o:
o 19 entities seeking support to build networks that are capable of delivering 100 Mbps
downstream and25 Mbps upstream to all locations2r in the project census blocks in Arkansas,
tB Wireline Competition Bureau Announces Application Processfor Entities Interested in Participating in the Rursl
Broadband Experiments, WC Docket No. l0-90, Public Notice,29FCC Rcd 10016, 10020, 10028-29, paras. l6-17,
36 (Wireline Comp. Bur.2014).
19 Additional information about the proposals of the provisionally selected bidders will be released at a future date.
20 A number of the census blocks that provisionally selected bidders seek to serve are the subject of a pending
challenge in the Phase II challenge process. See id. at 10035-36, paras. 64-66. The Wireline Competition Bureau is
currently reviewing the challenges and responses received in the Phase II challenge process to determine whether a
census block or blocks that a selected bidder proposed to serve should be deemed ineligible for rural broadband
experiment funding. In the event that census blocks are deemed ineligible for rural broadband experiment funding,
support for any project selected for funding that includes such census blocks will be adjusted proportionally. See
Connect America Fund; ETC Annual Reports and Certi/ications, WC Docket Nos. 10-90, 14-58, Report and Order
and FurtherNotice of Proposed Rulemakng,Z9 FCC Rcd 8769, 8786-87,paru 5l (2014) (Rural Broadband
Experiments Order).
2r For purposes of this Public Notice and the associated atcachments, "all locations" refers to all price cap locations
in each census block.
{00023573.DOCX.2}
t7
Californiq Colorado, Delaware,Illinois,Indiana" Iowa, Kansas, Michigan, Minnesota,
Nebrask4 Nevada, New Mexico, North Dakota, Oklahomq Puerto Rico, and Texas.22o 12 entities seeking support to build networks capable of delivering l0 Mbps downstream and
I Mbps upstream to all locations in the project census blocks in Colorado, Idaho, Iow4
Kansas, Kenfucky, Michigan, North Carolina, Ohio, Tennessee, Texas, Virginia, and
Washington.o 9 entities seeking support to build networks capable of delivering 10 Mbps downstream and I
Mbps upstream to all locations in project census blocks that are extremely costly to serve in
California,Illinois, Maryland, Michigan, North Dakota, Kansas, South Dakota, and Texas.
With the release of this Public Notice, the post-selection review process for these bidders
now begins. The Bureau is required to determine whether each selected applicant has
demonstrated that it has the technical and financial qualifications to successfully complete the
proposed project within the required timeframes and is in compliance with all statutory and
regulatory requirements for the universal service support that the applicant seeks.23 We
emphasize that selected bidders are required to deliver the required minimum speeds to all
locations within the funded census blocks.2a
Attachment B provides instructions for these entities on how to complete FCC Form
5620 and upload their post-selection review attachments. The identified bidders are required,
within 10 business days of this Public Notice, to submit the most recent three consecutive years
of audited financial statements, including balance sheets, net income, and cash flow, and to
submit a description of the technology and system design used to deliver voice and broadband
service, including a network diagram, which must be certified by a professional engineer.2s
Entities proposing to use wireless technologies also must provide a description of spectrum
access in the areas for which the applicant seeks support.26 The bidders identified in Attachment
A are required to submit these materials by Friday, December 19,2014 at 11:59p.m. EST.
Failure to submit the requested materials by this deadline will constitute a default, and the bidder
will no longer be considered for the identified rural broadband experiment.
22 Bidders in this category must offFer at least one service plan that provides 25 Mbps downstream/S Mbps upstream
to all locations within the selected census blocks. See Rural Broadband Experiments Order,2g FCC Rcd at 8779-
80,para.26.
23 Id. at8787,para.52.
2a Under the Commission's rules, recipients of support are required annually to provide the results of network
performance tests pursuant to the methodolory and in the format determined by the Wireline Competition Bureaq
Wireless Telecommunications Bureaq and Office of Engineering and Technology. 47 C.F.R. $ 5a313(a)(l l). The
Wireline Competition Bureaq Wireless Telecommunications Bureau, and the Office of Engineering and
Technology (together, the Bureaus) recently sought comment to further develop the record on a proposed
methodology for high-cost recipients to measure and report speed and latency performance to fxed locations. The
Bureaus have proposed that recipients be required to perform tests at least once an hour during peak period over a
four-week period, withgsyo of the observations at or above the required minimum speed. See Wireline Competition
Bureau, Wireless Telecommunications Bureau, and the ffice of Engineering and Technologt SeekComment on
Proposed Methodologtfor Connect America High-Cost Universal Service Support Recipients to Measure and
Report Speed ond Latency Performance to Fixed Locatiozs, WC Docket No. l0-90, Public Notice, DA 14-1499 (rel.
Oct. 16,2Ol4).
25 See Rural Broadband Experiments Order,zg FCC Rcd at 8787-88, para. 54.
26 Id.
{00023573.DOCX.2\
Finally, we note that three bidders that initially appeared on the provisionally selected
bidders list for funding category one submitted project bids that were facially non-compliant
with the requirements for this category.21 Those three bidders were removed from consideration,
and the FCC Auction System produced the provisionally selected bidders shown on Attachment
A.
One of these bidders, ViaSat, Inc., sought a waiver of the Commission's 100 millisecond
(ms) latency standard for categories one and two. We deny ViaSat's waiver request for the rural
broadband experiments, without prejudice to ViaSat's submission of this request into the docket
for further consideration for the Phase II competitive bidding process that will occur to the extent
price cap carriers decline the offer of Phase II model-based support. We are not convinced that
ViaSat has demonstrated that special circumstances warrant a deviation of the rural broadband
experiment rules established for categories one and two, and that waiving the rules for categories
one and two would serve the public interest.2s ViaSat's petition raises issues that warrant further
consideration with public input for the Phase II competitive bidding process, which remains
pending, but we conclude that waiving one of the core requirements for one bidder in the rural
broadband experiments without public input after the close of the filing window would be
prejudicial to the integrity of the competitive bidding process.2e
For additional information on this proceeding, contact Ian Forbes ([e-mail])
of the Wireline Competition Bureau, Telecommunications Access Policy Division, (202) 418-
7400.
-FCC-
EXHIBIT 3 - TWO-YEAR PROJECT IMPROVEMENT
PLAN
First Step Internet, LLC ("FSI") proposes deployment of a 4G LTE-TD fixed Radio Access
Network (RAN) to provide lOMbps/lMbps Broadband Intemet access along with voice-over-IP
telephony service, to serve the census blocks identified in Exhibit l, which the FCC has
determined are currently'tnserved" for purposes of the Rural Broadband Experiments prograrn.
We will leverage the existing assets provided by our Broadband Technology Opportunities
Program (*BTOP") award, which include physical towers, microwave paths and other primarily
middle-mile assets, and use the RBE funding to support cost-effective deployment of last-mile
service to customers in the unserved census blocks.
Wireless Broodband
27 T*o of these bidders proposed to offer service not meeting the required speeds for category one.
28 See 47 C.F.R. g 1.3; Northeast Cellular Telephone Co. v. FCC,897 F.2d I164, I166 (D.C. Cir. 1990).
2e Because ViaSat submitted its waiver request in its FCC Form 5610 submitted into the FCC Auction System,
rather than separately in the docket, other bidders and the general public have not had the opportunity to provide
input on the request.
{00023s73.DOCX.2}
19
The Radio Access Network (*RAN") will be implemented using Telrad BreezeCompact
eNodeB base stations, at the tower sites described, operating initially in the 'lightly licensed'
3650-3700 MHz band; with the intention to expand into the newly designated 3550-3650 MHz
"Citizens Broadband Seryice" band, once the rules are finalized, the spectrum access systems
come on-line, and vendor upgrades are available. Each eNB base station will initially be able to
provide approximately 200Mbps of capacity per sector, easily expandable to 400Mbps, as
utilization increases. Future software upgrades are expected to expand that to 600Mbps per
sector, and additional sectors can be deployed as needed. Each sector will be able to service at
least 100 users, at a conservative 5:l over subscription ratio. Should actual utilization allow for a
higher ratio, we may be able to service considerably more users, and/or users with higher speed
packages.
Regarding spectrum availability at the access layer, we are currently a non-exclusive licensee of
the 3650-3700 MHz band, which sees little current use in our region. It is our belief that this
spectrum will provide suffrcient capacity for the initial RAN deployment. As utilization
increases, and the 3550-3650 MHz "CBS" band becomes available, we intend to take advantage
of the additional capacity and automated coordination offered to increase end-user throughput
beyond the initial lOMbps/lMbps plans offered. Thanks to the softwaredefined nature of the
Telrad solution, this upgrade will not involve new hardware.
The LTE core will be implemented using geo-redundant Telrad EPC units, placed in two of our
data center sites, located in Pullman, WA and Lewiston, ID. These data center sites enjoy
multiple path and provider diverse upstream Internet connectivity, and technologically diverse
connectivity to each other (via WDM fiber, and high-capacity licensed microwave). They also
provide multiple links into our MPLS middle-mile transport (backhaul) network. Between the
two data center sites, an aggregate of 3Gbps of Internet connectivity is currently provisioned,
with substantially move available as needed. Each of the EPC units is capable of servicing 2Gbps
of LTE traffic, easily scalable by adding additional parallel EPCs.
Connectivity between the eNB base stations at the tower sites and the EPC core units at the data
centers will be provided by our MPLS transport network, comprised of fiber and I l, 18, and 23
GHz licensed microwave paths. With the exception of the microwave portions in Washington
state and the fiber, all of the involved sites and paths were constructed under our BTOP award.
All sites involved have at least 200Mbps of transport capacity available through primary paths,
and at least l0OMbps available through altemate paths. The central sites between Moscow and
Lewiston have over lGbps available. In all cases, this capacity is scalable as demand warrants, in
many cases without any hardware upgrades. With the exception of the High Camp site, all sites
involved have multiple redundant paths available to the LTE core locations through the transport
network.
For the microwave portion of the transport layer, we will utilize existing I I , I 8, and 23 GHz
licensed links, with already provisioned capacities ranging from 200Mbps to l.4Gbps on all
primary path. In most cases, this capacity is scalable to a degree without additional hardware, or
alterations to licensing. In some cases, minor modifications to the licenses may be necessary.
Additional scalability can be achieved through hardware upgrades and/or major licensing
revisions, and through deployment of additional paths.
{00023s73.DOCX.2}
All sites involved have propane, natural gas, or diesel generators on site, to provide multiple days
of backup power in the event of a loss of utility power. They also have substantial battery
backup, both to bridge the gap between the loss of utility power and generator start up, and to
provide enough time (8+ hours) for technicians to reach the site with portable generators in the
event of stationary generator failure. Small, inexpensive UPS systems will be available for
customer purchase, to provide backup power for the Customer Premises Equipment ("CPE'), or
they can provide their own backup power solution.
CPE installation will be performed by our in-house outside plant crews, for optimal performance.
The CPE equipment will initially be Telrad dual-mode WiMNVLTE devices, although we will
not be making use of the WiMAX capabilities. In the future, we expect to switch to less
expensive LTE-only Telrad CPEs, as they become available. Third-party CPEs can be supported,
as long as they conform to LTE standards, and operate in the correct frequency bands. Due to the
non-line-of-sight performance of the Telrad solution, we expect that most CPEs deployed will be
small integrated units (see picture), directly attached to the subscriber's residence or business. In
the event that the building-attached integrated unit is unable to perform satisfactorily, a
connectorized CPE may be used, and/or the CPE may be mounted to a pole up to 300ft from the
structure.
Round Trip Time ("RTT") latency in the Telrad access layer (CPE, eNB, and EPC) is anticipated
to be below 40ms in the worst case (l6ms in the best case), with an additional measured 5ms
RTT latency in the transport layer's most distant case (Pullman data center to High Camp base
station). Beyond our borders, RTT latency varies between 12 and22ms to our upstream
providers first IP routers, located in Portland, OR and Seattle, WA. In total, this yields a worst
case latency of less than 70ms from CPE to upstream provider. In the typical case, actual latency
will be less than 40ms.
Initial propagation studies, for the purposes of census block selection, were performed in-house
using Link Technologies' ToweCoverage.com service. Final propagation studies and RF design
were performed by PCS Technologies, Inc., a Telrad systems integrator.
On the back-end, the LTE network will be managed and monitored primarily through Telrad's
STAR Suite NMS system; with additional external monitoring provided through Cacti (SNMP
monitoring), SmokePing (latency, jitter, and packet loss monitoring), and What's Up Pro
(connectivity monitoring and alarming), among others. Authentication and provisioning will be
provided by Telrad's AAA/Radius system, tied to our main customer database. Tier 1 and2
technical support and troubleshooting will be primarily provided by technicians in our in-house
call center during the hours of 8am to 7pm, seven days a week. Off-hours support and
troubleshooting will be provided by a third-party call center, specializing in wireless technical
support. Both the in-house technicians and the third party call center have access to our advanced
team of engineers, administrators, tower crews, and OSP technicians; at all hours, when
waranted.
Voice Telephony Services
{00023573.DOCX.2}
2l
On the voice side, FSI has a VoIP network based on standard SIP signaling and RTP audio that
is deployed and in active use that offers landline-grade service to end-users. We support both
"single-line" voice deployments (as would be common for residential users) as well as multi-
channel voice IP trunks. Business-class voice trunk service pricing varies based on the
customer's requirements. Our standard plan for residential customers is a single line and phone
number at $25 per month for unmetered inbound and outbound calling to the United States and
Canadq and which includes a local phone number, voicemail, Caller-ID with Name, call waiting,
and call forwarding. We will also honor USF-supported Lifeline subsidies and discounts applied
to this same plan for qualiffing households. We do not offer so-called 'toll-blocking" to our
customers nor do we restrict calling for Lifeline-supported account holders to traditionally-
defined local calling areas since we do not distinguish between local and long-distance
destinations on this plan, nor do we offer a plan that does. We do not offer international calling
to any customer at this time, so customers who need to make a call outside of the United States
or Canada would have to use a third-party calling card. (Calls originating internationally can be
received just fine).
We interoperate with most SlP-compliant gateways and PBXes in the trunking configuration,
and most SlP-compliant voice endpoints (including IP telephones, IP-to-analog telephone
adapters, and IP "softphones") in the singleJine configuration. Customers have the option of
supplying a SIP endpoint of their choosing ("BYOD') or of electing to use one of ours (sold
separately); for those that use ours, our system automatically provisions and configures the
device. For residential users, we currently supply standalone analog telephone adapter (ATA)
models that have been carefully tested and vetted by us in the areas of performance and
compatibility for a trouble-free experience; however, the Telrad-supplied CPEs for their LTE
solution include a SlP-compliant ATA built-in that we may decide to leverage for customers
installed to the LTE network, provided that the integrated ATA meets our requirements and
performance standards and passes our network interoperability testing. At this time, we only
support a single line per ATA on the ATAs that we supply; if more than one line of service is
required, additional ATAs will have to be purchased from us, or the customer can elect to supply
their own multi-line ATA or equivalent solution. (Each additional active line of service would
incur a separate $25lmonth recurring charge.)
Call flow and provisioning within our network are handled by a system developed in-house that
is largely based around the Asterisk telephony platform. At the edge/point of interconnection,
calls coming from or headed to a PSTN destination go through our session border controller
(SBC), which then hands the call to our SIP regishar and call feature server (CFS). Both operate
as back-to-back SIP user agents, and are also configured to proxy the RTP audio. Since Asterisk
is NAT-aware, having both of these features (B2BUA and RTP proxy) enabled on the CFS
solves the majority of problems common to SIP endpoints behind aNAT without requiring a
functional SIP ALG (NAT helper) on the customer side or requiring the support or configuration
of extemal session haversal helpers (STUN, TURN, ICE, and the like) in the SIP endpoints
themselves, making for a largely "plug-and-play" system that is able to cope with a diverse set of
environments.
Account provisioning is handled through RADIUS, and the back-end database that handles the
provisioning of our broadband internet customers is common to both voice and internet
{00023573.DOCX.2}
RrAnruS/A.lq.A. An active broadband account can have voice service turned up on it by
populating the voice-specific fields in that database record. We strive to keep a modest number
of telephone numbers (DIDs) in inventory across all of our supported rate centers, which allows
for instant tum-up of services.
For E9l l, we use the "dash Carrier Seryices" (now Bandwidth.com) platform to add our end-
users to the ALI database. The standalone ATAs we supply to our customers can connect to our
CFS from any intemet connection and supply the customer with dialtone if they take it out of the
house, and we do allow for customers to preconfigure up to three E9l l service addresses that
they can switch between in real-time using our customer self-service web portal.
The projected start date May 1,2015 and it is expected thatzsyo of the project build will be
completed by April 30,2016. The project providing coverage to 100% of the planned service
area will be completed within 2 years, April 30, 2017. The estimated amount of investnent to
provide services to the coverage area is $300,000. The estimated population that will be served
as a result of these improvements is 542 currently unserved locations.
{00023573.DOCX.2}
23
{00023573.DOCX.2}