20120831Syringa Wireless LLC.pdf

Ell ED CYNTHIA A. MELILLO PLLC

8385 W. EmERALD STREET • BOISE, IDAHO 83704 212 AUG 31 M [phone] • [e-mail]
IDAHO
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August 31, 2012
VIA HAND DELIVERY
Ms. Jean Jewell
Commission Secretary /7
Idaho Public Utilities Commission P.O. Box 83720
Boise, Idaho
Re: Syringa Wireless LLC - ETC Annual Recertification
Dear Ms. Jewell:
I am enclosing one copy of the Eligible Telecommunication Carrier Annual Re-Certification
form for Syringa Wireless, LLC.
Please note the enclosed document 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 re-certification document.
Sincerely,
Cynthia A. Melillo
CAM
Enclosures
cc: Scott Dike (via electronic mail, w/encl.)
Jessica Pearson (via electronic mail, w/encl.)
4Ic11:TUtI4 l'i.Y1 ;11UYil1'LN1
Syringa Wireless, LLC August 31st2012
P0 Box 1117
233 North Main Street.
Pocatello. Idaho 83204
CONTENTS
Section 1: ETC Information
Section 2: Description of Carrier's Local Usage Plan
Section 3: Detailed Outage Information
Section 4: Unfulfilled Service Requests
Section 5: Customer Complaints
Section 6 Service Quality and Consumer Protection Certification
Section 7: Ability to Remain Functional in an Emergency
Section 8: Federal USF High-Cost Support Certification
Section 9: Two-Year Network Improvement Plan and Progress Report
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Section 1: Eligible Telecommunication Carrier Information
Date of ETC Annual Report: August 31 st 2012
Company Name: Syringa Wireless LLC
Address: P0 Box 1117
233 North Main Street.
Pocatello. Idaho 83204
Company Contact Person/Title: Scott Dike, General Manager
Telephone Number: .208-830-6996
Email Address: [e-mail]
Service Area Code (SAC): 479008, 479010
Number of Idaho Telephone Service Assistance Program (ITSAP) recipients:
(Use number from last report submitted to the ITSAP Administrator)
1105
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Section 2: Description of Carrier's Local Usage Plan--
Competitive Eligible Telecommunications Carrier (CETC) Only
ETC applicants must demonstrate that their usage plan is comparable to the ILEC(s) in the service areas for
which it seeks designation. C. FR. § 54.202(a) (4). Local Usage Plan may be a descriptive narrative of the carrier's
basic usage plan or it may be a copy of tariff sheets as filed with the Idaho Public Utilities Commission.
Description: Please see attached Exhibit A for Description of Local Usage Plans
Section 3: Detailed Outage Information §54209(a)(2)
Provide detailed information on any outage, as that term is defined in 47 C.F.R. § 4.5, of at least thirty (30)
minutes in duration for each service area in which an ETC is designated for any facilities it owns, operates, leases
or otherwise uses that potentially affect (a) at least ten percent of the end users served in a designated service
area; or (b) a 9-1-1 special facility, as defined in 47 C.F.R. § 4.5(e). Specifically, the annual report must include
information detailing: (a) the date and time of onset of the outage; (b) a brief description of the outage and its
resolution; (c) the steps taken to prevent a similar situation in the future; and (f) the number of customers affected.
Reporting period is January 1, 201 1—December 31, 2011. See Order No. 29841, page 18.
This information was previously filed as part of the Section § 54.313 report (as required by the
FCC)
Section 4: Unfulfilled Service Requests §54.202(a)(1)(A)
Provide the number of requests for service from potential customers within the ETC'S service area(s) that were
unfulfilled in the previous year (January 1, 2011—December 31, 2011). The ETC shall also detail how it
attempted to provide service to those potential customers. See Order No. 29841, page 19.
This information was previously filed as part of the Section § 54.313 report (as required by the
FCC)
Section 5: Customer Complaints §54.209(a)(4)
Provide the number of complaints per 1,000 handsets or lines for the previous year (January 1, 2011 - December
31, 2011).
This information was previously filed as part of the Section § 54.313 report (as required by the
FCC)
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Section 6: Service Quality and Consumer Protection Certification
§54.202(a)(3)
Provide certification that the carrier is complying with applicable service quality standards and consumer
protection rules.
Consistent with the IPUC ETC Requirements Order, Syringa Wireless continues to
comply with all applicable service quality standards and consumer protection rules, and
abides by the consumer protection standards established by the CTIA Consumer Code.
In addition Syringa Wireless has adopted and is using a CPNI and Red Flag Rules policy
consistent with FCC requirements.
NOTE: See attached Exhibit B, Affidavit of Business or Corporate Officer for the above
certification requirements.
Section 7: Ability to Remain Functional in Emergencies Certification
§54.201 (a)(2)
ETCs must demonstrate that it has a reasonable amount of back-up power to ensure functionality without an
external power source, is able to re-route traffic around damaged facilities, and is capable of managing traffic
spikes resulting from emergency situations.
Consistent with the IPUC ETC Requirements Order, Syringa Wireless has the ability
to remain functional in emergency situations. Syringa Wireless has designed a fault-
tolerant network that employs the following features:
1.Mobile Switching Center located in Roosevelt, Utah
o Nortel MTX switch with fully redundant fault-tolerant processors
o 24 hours of back-up battery
o 250 KW generator with the fuel supply connected directly to the public natural gas
utility
o Complete complement of spare circuit boards
2.Self-Healing Diverse Alternate Route Protection Service for Fiber Facilities
interconnection
o Multiple alternate trunk routes for PSTN interconnection trunks
o Redundant Microwave radio links where used
o Automated 7x24 network monitoring
3.Cell sites
o Overlapping cell site coverage with retry for blocked calls
o Backhaul network engineered with surplus back-bone capacity
o Ready access to growth radio stock for all field technicians
o 8 hours battery back-up for all cell sites
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o Four Standby Generators at 4 different locations ready for deployment when and
where needed.
o Leased fiber and copper facilities to major network T-1 aggregation to multiple
Syringa Networks Backhaul locations
o Quick-connect plugs for portable generator at all sites
o Compact generator system stored in Driggs, Idaho for use with Snow Cat-only
accessible sites
o Remote monitoring 7x24 of all sites
4.Monitoring Network and Outage Resolution procedures
o Syringa Wireless has a network operating center ("NOC"), in Roosevelt, Utah;
o All Switches and cell sites are remotely monitored 7x24, with critical and major
alarms escalated to the next level of management every 20 minutes
o Syringa Wireless' 7x24 on-call staff is sent a text message and called immediately
when the monitoring system detects system problems
5.Staffing and Additional Equipment
o The Syringa Wireless Technical Operations team consists of 5 people strategically
located within Southeastern Idaho in the following locations: 1 in Jerome, 1 in
Firth, 3 in Pocatello
o Syringa Wireless staff is well trained and equipped to respond quickly in the event
of outages, alarms or emergencies
o Complete inventory of alternate-access equipment, including:
> All field staff are equipped with 4 wheel drive pickups; (1) Tucker Snow
Cat is stored at Driggs, Idaho facility; (2) snowmobiles are located at
Pocatello, Idaho facility; and (2) Polaris 4-wheeler ATV's are located in
Pocatello, Idaho.
> All field staff are trained in operation for all alternative site-access
equipment
o Tower crew is ready for emergency tower and antenna repairs
o Technicians are equipped with complete complement of spares for cell site
o Microwave and DACs equipment is available to insure quick recovery
Syringa Wireless has consistently demonstrated that it not only can provide customers with
needed emergency services, but that it also can also remain fully functional in emergencies.
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Section 8: Federal USF High-Cost Support Certification §54.313, §54.314
Pursuant to FCC regulations, in order for ETCs to continue to receive federal USF, the Commission "must file an
annual certification with the USAC and the [FCC] stating that all federal high-cost support provided to such
carriers within that State will be used only for the provision, maintenance, and upgrading of facilities and services
for which the support is intended."
NOTE: See attached Exhibit B, "Affidavit of Business or Corporate Officer for the above
certification requirements.
Section 9: Two-Year Network Improvement Plan and Progress Report
The annual report must include a progress report on the carrier's two-year service quality improvement plan,
including maps detailing its progress toward meeting the plan targets, an explanation of how much universal
service support was received and how it was used to improve signal quality, coverage, or capacity, and an
explanation regarding any network improvement targets that have not been fulfilled. This information shall be
submitted at the wire center level, The annual report must also include an updated two-year network
improvement plan indicating plans for future investment.
Two-Year Network Improvement Plan Format
During the Fiscal Year of 2011, Syringa Wireless collected $1,499,266 in universal service
support. Please see attached spreadsheets and maps listed as Exhibit C for details of the
2011 build-out plan was accomplished with cost breakdowns specific to wire centers served.
Also, the attached spreadsheets and maps listed as Exhibit D detail the forward looking build
out plans by wire center for the fiscal years of 2012 and 2013.
Note: Syringa Wireless intends to submit the Two-Year Network Improvement Plan as
"confidential information."
Additional Information: Lifeline and Tribal Assistance Programs
Syringa Wireless continues to provide service to the Fort Hall Reservation.
As a designated ETC, Syringa Wireless offers Tribal Lifeline service to qualified
residents of the Fort Hall Reservation.
Syringa Wireless also provides ITSAP and Lifeline assistance to qualifying
subscribers throughout its designated ETC service territories.
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EXHIBIT A
SIGNATURE FEATURES
• Unlimited nights and weekends (7pm-7arn)
Unlimited Syringa Wireless mobile-to-mobile
• Unlimited incoming minutes
• Call waiting, caller ID, call forwarding,
25 text messages, and voicemail
SIGNATURE ADD-ONS
Text and Picture Messaging
74ssaging Plan Per Month
600 text messages (SMS) ........................... . ........................ $5/line
300 text/picture messages (SMS/MMS) ........................... $1 0/line
Unlimited text messages (SMS) ........$15/line
Unlimited text/picture messaging* (SMS/MMS) $20/line
Shared unlimited text/picture messaging*
(SMS/MMS) ....... ............... .. .............. .... . .............. ........... $40/account
*Only available on select handsets, handset programming required
P,
Data Services
Data Plan Per Month
Unlimited 3G in-network & unlimited 2G
nationwide roaming -.......................... $25/line
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PRIMARY SERVICE LINE
$70/mo - Signature Everything
Unlimited nationwide calling, messaging and data.
Add up to 4 additional lines,
choose from the plan options below.
__ADD-ON SHARED LINE
$45/mo - Signature Voice
Unlimited nationwide calling.
$55/mo - Signature Voice
& Messaging
Unlimited nationwide calling and messaging.
$65/mo - Signature Everything
Unlimited nationwide calling, messaging and data.
*Unlimited in-network 3G data service offering 2G roaming
1: I
.... AU service and feature charges will be billed at either a thirty day (30) or .. .
National Service Area weekyusagerateofsevendays(7)
.-. THERE ARE NO REFUNDS OR PARTIAL REFUNDS once a payment 00060
.
has been applied to the account. THERE ARE NO TRANSFERRING
. OF FUNDS from any type of service account we offer. All ROAMING yrinaa
..
and LONG DISTANCE calls will include a per-minute charges rounded
up to the next minute Usage charges start when the SEND button is
pressed. Usage charges will conclude when the call is completed or by

Y pressing the END button. Charges will not be assessed for busy signals

. . or incomplete calls. The Syringa Wireless Coverage Area and Roaming

c Service Areas are outlined in this plan guide. Fifty percent of service •.
. : usage is required to be within the Syringa Wireless Network. We retain the •: •
. right to terminate services for any account we feel is abusing or service
offerings and/or network. We do not guarantee depicted coverage areas •
will process calls. Long distance service areas are defined as within
• .: the contiguous United States and include Alaska, Hawaii, and the U.S. 3t
1/ territories Depicted coverage areas are approximate actual coverage
All . .— . may vary due to terrain, weather, signal strength, equipment and other
factors SYRINGA WIRELESS MAKES NO WARRANTY EXPRESS
OR IMPLIED, REGARDING ITS SERVICE OR ANY WIRELESS
PHONE OR DEVICE USED ON SYRINGA WIRELESS NETWORK
. OR ANY THIRD PARTY NETWORK, INCLUDING BUT NOT LIMITED : TO, ANY WARRANTY OF MERCHANTABILITY OR FITNESS FOR A

Unlimited Local Calling Area .,. PARTICULAR PURPOSE.
- .... . Services may not be available or limited due to equipment. Not all
handsets will support SMS, MMS, WAP, Video and other service
applications. It is the responsibility of the subscriber to purchase the
appropriate amount of airtime they need to make and receive calls,
SMS or MMS services as well as the ability to access the web. Syringe
Wireless assumes no responsibility financially or otherwise for any
dropped call or the inability to process a call or service. We have made
all attempts to block calls to fee based numbers (900). international
Bol.. ..• and illegally routed numbers. The subscriber is responsible to cover
_________ any additional fees incurred for any additional charges The subscriber
• '•1 agrees to use the service for legal transactions Only. If it is determined,
________________________________________________ by Syringa Wireless, a third party, roaming partner or legal authorities
that there is a violation of this clause; Syringe Wireless retains the right
to suspend and/or deactivate the service without refund Calls made to )t.)

______________________________________ 411 directory assistance will route to a third party provider that offers .. • free 411 services. If SMS or WAP is terminated by Syringa Wireless, for

Blue = Syringe Wireless Home Network (Make and receive calls) misuse or abuses as determined by us, there will be no refund or partial
'Yellow = Syringa Wireless Extended Calling Area refund granted. Pay Go and TEXTAND TALK service plans require that

(Make noun to anywhere within the yellow area from within the bkre area.) local calling is active to utilize any long distance, roaming, SMS, MMS,
and WAP services. "
Syringe Wireless reserves the right to terminate any of its services
to any customer at anytime. Syringe Wireless reserves the right
ra Long distance and roaming minutes are available in addition to your Pay Go service plan to cancel or change service plan offerings at anytime without
Syringe Wireless Unlimited Pay Go service must be active to use long distance services notification to subscriber.
Current coverage areas depicted in geographical representation shows approximate licensed 4( PAY GO accounts must be active within a 30 day period or the account coverage area of Syringe Wireless Actual coverage may vary due to terrain weather, signal will be suspended PAY GO Accounts will be terminated after thirty days strength, customer's equipment, location and other factors. Clarity and recephnn may be •Ji/ suspension.
diminished by obstructions such as buildings and foliage Services msy not be available or of
limited due to equipment Nut at) handsets will support SMS, MMS, Video and other oervice may be assigned to another user Syringe Wireless is committed to
applicatons No guarantee of coverage is available, protecting your privacy. In all matters relating to your personal and
call privacy you may refer to the Syringe Wireless Privacy Policy Long distance allows for calls to be mode throughout the con- Statement S rin a Wireless is fully compliant with all CALEA Policies tinental United States while within the Syringa Wireless network and Procedures and FCC regulations relating to Network Management
Practices see: www.syringawireless.com/networkpractices
Phone Guard 9E1

(See Phone Guard Guide)SY LESS.
ringa
Syrinoa Wireless is registered trademark of SyringaWireiess LLc, SOynnga Wireless LLC 2009 PG-11/11 I.: t
y
Included In All Pay Go Service Plans
Voice Mail • Caller ID • Call Waiting
I.' Additional Service Options
14 ; 30 200 Long Distance Minutes $5.00
30 days Unlimited Long Distance Minutes per thirty days plus tax $10.00
Unlimited Pay As You Go 30 days of Unlimited Data $15.00
Local Calling Service Seven days of Pay Go Calling Service $10.00
Seven days of Unlimited Text $10.00
•d Seven days of Unlimited Data $10.00
!UIPI 30 Day Rate
Unlimited Text
200 Minutes of Local Voice
!. Caller ID
$12°
• Weekly Rate
• Unlimited SMS
60 Minutes of Local Voice
Caller ID
Choose To Add:
Call Waiting / Voice Mail $5.00
200 Additional Local Minutes* $5.00
200 Long Distance Minutes $5.00
Unlimited Data: 7 days $10.00
Unlimited Data: 30 days $15.00
Add these features while in current cycle
State of Idaho ) CERTIFICATION BY ELIGIBLE TELECOMMUNICATIONS CARRIER
)ss OF COMPLIANCE WITH SERVICE QUALITY AND CUSTOMER
County of Ada ) PROTECTION, ABILITY TO REMAIN FUNCTIONAL IN
EMERGENCIES,AND USE OF FEDERAL HIGH-COST SUPPORT.
AFFIDAVIT OF BUSINESS OR CORPORATE OFFICER
The Idaho Public Utilities Commission Order No. 29841 requires Eligible Telecommunications Carriers to
certify that they are compliant with applicable service quality standards and consumer protection rules;
and ETCs must demonstrate the ability to remain functional in emergencies. In addition, the Commission
must file an annual certification with the USAC and the FCC that all federal high-cost support provided to
ETCs within the State of Idaho will be used only for the provision, maintenance, and upgrading of facilities
and services for which the support is intended. Accordingly, the undersigned states and verifies under
oath the following:
1.I am an officer of Syringa Wireless LLC, an eligible telecommunications carrier for receiving federal
universal service support under section 214(e) of the Telecommunications Act of 1996 in the state of
Idaho.
2.I am familiar with the Company's day-to-day operations in the state of Idaho and with the State's
service quality standards and consumer protection rules as set forth in Commission Order No. 29841.
3.Syringa Wireless LLC is complying with applicable service quality standards and consumer protection
rules of the Federal Communications Commission and the Idaho Public Utilities Commission.
4.I certify to the Commission that the Company is able to remain functional in emergencies as set forth in
Commission Order No. 29841 and in 47 C.F.R. § 54.201(a)(2).
5.I also certify that all federal universal service support funds received by Syringa Wireless LLC during
the current calendar year will be used in a manner consistent with section 254(e); that is, for the
provision, maintenance, and upgrading of facilities and services for which the support is intended. The
company will continue to comply for the period of January 1, 2012, through December 31, 2012, to be
eligible for federal universal service fund support.
6.This verification and affidavit is provided to be the Idaho Public Utilities Commission to enable the
IPUC to certify to the FCC that federal universal service support received by the eligible carriers in the
state will be used in a manner consistent with Section 254(e) of t lecommunications Act.
- Name/Title "
IdA %JAI/CfI.
RA. C,5'vcn-'9-/ {L (Z> . Date__________________
to before me this day 029 of August, 2012
5 rTesidingat 5& ~_ 4ale~
My Commission expires