20131015Virgin Mobile USA ETC and FCC 481.pdf

Kristin L. Jacobson, Regulatory Counsel
201 Mission Street, Suite 1500
San Francisco, CA S{105
Tel: [phone] Fax: [phone]
Email: [e-mail]
Ii!'r rra? | --;.;,i;-j i: i,, tl: ll
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i:Sprint
October 15,2013
Ms. Jean Jewell, Commission Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, lD 83720-0074
RE: Case No. GNR-T-13-01
Virgin Mobile USA, L.P.'s 2013 Federal ETC Filing (FCC Form 481)
Dear Ms. Jewell:
Enclosed for filing with this Commission is Virgin Mobile USA, L.P.'s 2012 Annual Carrier Report
(Form 481) filed with the FCC. Please note that the funding year tor this report is 2014.
lf you have any questions regarding this report, please feel free to contact me. My contact
information is shown above.
Very truly yours,
fii*-,Lk**^fr,^Kristin L. Jacobson
CaY No AruR-T t3'ot
4? 9 015
Page 1
<010> Study Area Code
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CTIA
Tha Wireless Association F x,t;tl;i 111s the Vi re ess Froni er
Steve Largent
.. ,. ,..,,,,,1,; ,
August 16,2012
Mr. Dan Hesse
President and Chief Executive Officer
Sprint Nextel Corporation
6200 Spri nt Parkway, Mai lstop: KSOPHF04 1 0 -4 A42l
Overland Park, KS 66251
Dear Dan:
Congratulations! This letter is to notift you that Sprint Nextel Corporation ("Sprint")
and the Sprint Prepaid Group (Virgin Mobile USA, Boost Mobile, and Assurance Wireless) have
completed the recertification process for the CTIA Consumer Code for Wireless Service
("Voluntary Consumer Code") for the period January 1,2012 - December 31,2012, and are
deemed compliant with the principles, disclosures and practices set forth in the Voluntary
Consumer Code. Accordingly, Sprint, Virgin Mobile USA, Boost Mobile and Assurance
Wireless are authorized to use and display the CTIA Seal of Wireless Quality/Consumer
Information, subject to the terms and conditions set forth in the attached License Agreement.
Please ensure that the relevant employees of Sprint, Virgin Mobile USA, Boost Mobile
and Assurance V/ireless review the License Agreement before using the Seal. Use of the Seal
constitutes acceptance of these terms and conditions. Upon request, CTIA will provide two
specimens (color and blacldwhite) of the Seal for use on Sprint's, Virgin Mobile USA's, Boost
Mobile's and Assurance Wireless' respective websites and in their respective collateral
materials. If you should have any questions concerning the recertification process or use of the
Seal, please contact Michael Altschul, CTIA's Senior Vice President & General Counsel, ar
(202) 7 3 6-3248 or maltsc [e-mail]..
CTLA commends Sprint for its ongoing leadership and participation in the CTIA
Voluntary Consumer Code, and we look fonrard to continuing to work with Sprint on this
important industry initiative.
A+{,fi^l,fin \
Steve Largent
Attachment
Charles McKee
Vice President, Govemment Affairs - Federal & State Regulatory
@
Sincerely.
,:n'
,,.t.t :il\,.i)!, ...L.:
CTIA
The Wireless Associrtion'
u<' I r*,i'./
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Sprint'
Sprint Business Conti nuity
Program Overview
This document may not be duplicated, modified, used by, disclosed or fonivarded to a third party without the prior
express written consent of Sprint Nextel Corporation.
Sprint
Disclaimer
This document may not be duplicated, modified, used by, disc/osed or forwarded to a third party without the
prior express written consent af Sprint Nextel Corporation.
Purpose
The purpose of this document is to provide approved information that can be shared with interested parties in
order to illustrate that Sprint is committed to an efficient and effective corporate approach with respect to
Business Continuity Planning, lncident Management and Disaster Recovery. This document will explain the
core components of the Sprint Business Continuity Program and the structure by which it is implemented.
Business Continuity Program Mission
Assure the continuation of Sprint's mission critical business operations and services. Minimize financial
damage and damage to Sprint's brand, its employees and customers, following significant business
disruptions.
Program lntroduction
As businesses, government agencies, and individual consumers become more and more reliant on wireline
and wireless communications, as well as remote access to information, the concept of Business Continuity
has never been more important. Sprint takes Business Continuity to the next level by ensuring that it is part of
the corporation's business philosophy This philosophy promotes utilizing business continuity principles,
guidelines, and standards by all company employees in their day to day business operations.
Sprint's Business Continuity (BC) Program is based on industry accepted principles. Sprint has adapted key
principles from the Disaster Recovery lnstitute lnternational (DRll), ASIS Organizational Resilience Standard,
Federal Emergency Management Agency (FEMA), Business Continuity lnstitute (BCl), American National
Standards lnstitute (ANSI), NFPA 1600, and several Military Specifications (Mil-Spec) standards, into 3 BC
Program Elements: Program Governance, lncident Management, and Continuity Analysis & Planning, as
defined below:
Program Governance
Prooram Governance Structure- Program structure, mandate and executive sponsorship is required to
ensure a comprehensive Business Continuity Program.
Prooram Manaqement & Continuous lmorovement - Overall program management and continuous
improvement includes all of the documentation and efforts designed to ensure a well-defined BC
program that seeks to continually mature performance and processes.
lncident Management
lncident Manaqement & Crisis Communications - Enterprise lncident Management Team (EIMT) and
lncident Management Team (lMT) documentation, training, exercises and continuous improvement are
required for those teams that have roles and responsibilities before, during or after an incident that
significantly affects Sprint's employees, customers and/or shareholders.
Continuitv Analvsis & Planninq
Criticalitv Analysis & Risk Manaqement - Criticality Rating is necessary for prioritizing tasks and
recovery. Risks that threaten the company's critical functions, vendors, sites, systems and network
elements, require due diligence that result in decisions to mitigate or accept the risks.
Mitioation Strateqies & Plan Development - After determining criticality and risks, the next steps include
devising the appropriate mitigation strategies and recovery capabilities. BC plan development is
formalized using on-line tools.
This document may not be duplicated, modified, used by, disclosed or forwarded to a third party without the prior
express wrilten consent of Sprint Nextel Corporation.
5print'
Program Governance Structure Overview
Overall BC Program governance requires executive sponsorship, a structure for decision making, and a
means to direct and manage incremental changes towards goals and objectives. Sprint's program
governance structure achieves each of these requirements and accomplishes them through inclusion and
diversity of thought and viewpoint. The following describes the program governance structure that begins
with the highest levels of the company and leverages management and expertise for optimal effectiveness.
Executive Command Team (ECT) - The ECT consists of Sprint's highest level executives, representing
all critical Sprint functions. The ECT provides executive sponsorship of the overall Business Continuity
Program and is briefed on issues and status of prolects that require senior executive attention.
Business Continuity Office (BCO) - The BCO is the program office responsible for establishing the
policy, structure, and methodology for developing, maintaining, and testing enterprise-wide BC and
Disaster Recovery Plans. During an incident, the BCO is responsible for coordinating cross functional
incident management activities of the Enterprise lncident Management Team (EIMT).
Business Continuity Gommittee (BCC) - The BCC is comprised of Business Continuity Teams
(BCTs). The BCC is responsible for assuring business continuity policies, guidelines, standards and
tools are implemented consistently across the company and acts as a forum for business continuity
discussions. BCTs have overall responsibility for the implementation of business continuity initiatives
within their individual business units and act as business unit lncident Management Teams (lMT) for their
business units when disasters occur. The BCC has various sub-committees that focus on proactive
planning, incident management, tools and training, awareness, pandemic planning and other issues that
require attention,
P rogra m G ove rn a n ce Stru ctu re
This document may not be duplicated, modified, used by, disclosed or forwarded to a third party without the prior
express written consent of Sprint Nextel Corporation.
Business Co ntin uity Com mittee
All of Sprint Corporation
Sprint
Program Management & Continuous lmprovement
The concepts of Program Management and Continuous lmprovement are the overarching control elements
that bookend all other aspects of the BC Program. For each of the other Program Elements, Program
Management efforts will provide definition of what the Program Element should accomplish and the methods
used to achieve objectives. The Continuous lmprovement efforts provide a means to keep the Program
Elements evergreen, current, and striving for maturity.
Proqram Manaqement:
r Awareness & Communications - Employees and management are informed of current Business
Continuity efforts or awareness campaigns through internal communication methods that often target
allemployees in the company.
o Process, Standards & Documentation- Common terminology, methodologies and formal
documentation on standards and procedures help our large company stay consistent and current. All
program documents are to be reviewed annually, at a minimum, with all key stakeholders.
. Reporting - Each year, the Business Continuity Office formally reports to Sprint's Executive
Management on the efforts and status of the Business Continuity Program and partners with
Corporate Audit on reporting risk information to the Board of Directors.
r Maintenance - Frequent reviews of plan details and processes are updated in a timely manner,
following changes to contacts, suppliers, processes, organizational structures, etc.
Continuous lmorovement:
o Training - Annual training cycles are followed to ensure familiarity with systems, processes and peer
organizations. Ad-hoc training is also conducted for new team members or procedure changes.
o Exercises - Exercises are used to evaluate plans, educate personnel, and test functions and
operational capability of Sprint's response organizations. lnformation related to these exercises is
proprie$ to Sprint. Additionally, as part of the nation's critical infrastructure, Sprint participates in
coordinated situation drills with FEMA, the Department of Homeland Security (DHS), and state
emergency management agencies to ensure coordinated preparedness and response during a
disaster. The most common types of exercises conducted are: Tabletop, Walk-through, Functional
drills, and Full-scale.
Tabletoo Exercises - ln a round-table setting, members of the response team meet to discuss
their responsibilities and describe how they would react as a team to an emergency scenario.
This document may not be duplicated, modified, used by, disclosed or foruvarded to a third party without the prior
express written consent of Sprint Nextel Corporation.
Program
Management
Continuous
lmprovement
lncident Management
& Crisis Communications
Structure
Reporting
Awareness &
Communication
Process & Standards
Documentation
Maintenance
. Training. Exercises. After Action Reviews. Maturity Model
Assessments
Criticality Analysis
& Risk Management
Mitigation Strategies
& Plan Development
Sprint
They identify areas of overlap and confusion in a cost-effective and efficient manner before
conducting a more demanding exercise.
Walk-Throuoh Drills - Both management and the response team perform their emergency
functions within the emergency response location.
Functional Drills - Tests designed to target specific functional processes within the recoveryplan such as notification, response, communications, documentation, and team
cohesiveness. ln most cases, these functions should be tested separately to help identify
improvement areas and to eliminate confusion. Observers are often used to evaluate these
exercises.
Full-scale Exercises - Exercises simulated to be as close as possible to a real-life disaster.
They may involve a combination of response teams, management, field operations, and
outside agencies. During the simulated exercise, team members are expected to actually
perform their disaster responsibilities.
After Action Reviews (MRs) - Following an incident or an exercise, an AAR is conducted to ask
participants to identify areas of success and improvement. These are documented as Lessons
Learned and tracked to satisfactory completion.
Maturity - Sprint uses an internally developed Maturity Model for benchmarking Business Continuity
Program success and progress. The model is based on the Capability Maturity Model as developed
by Carnegie Mellon University.
lncident Management & Crisis Communicationg
Knowing that unexpected events occur, Sprint's lncident Management and Crisis Communications teams are
highly trained and tested. As with the overall program governance structure, full executive support and
authority is integrated into the incident management structure. Sprint's seasoned professionals, across
multiple fields of expertise, have responded to all major disasters impacting the United States in the last 13
years.
Executive Command Team (ECT) - During a disaster, the ECT is kept apprised of all activitles and
status. lf the incident requires chief executive involvement, the ECT members engage to provide
guidance and approval to make necessary response and recovery decisions. The Chief Executive
Ofiicer (CEO) is the Chairperson of the ECT,
Enterprise lncident Management Team (EIMT) - The Enterprise lncident Management Team (EIMT)
convenes quickly as a way of sharing impact, status and critical decision-making during an incident. This
team is flexible and scalable and built on the premise of an all-hazards response approach.
lncident Management Teams (lMTs) - An IMT consists of members of a single business unit and is
designed to meet the needs of the company, customers and employees at the time of an incident.
Examples of lMTs include lT, Network, Human Resources, Customer Care, Corporate Security and
others. ln all, there are more than 20 lMTs, each of varying size and complexity, capable of responding
quickly and effectively to a wide array ol issues. Each IMT have a designated chairperson that
represents their organization on the EIMT callwhen the incident requires an EIMT response posture.
This document may not be duplicated, modified, used by, disclosed or forwarded to a third party without the pnor
express written consent of Sprint Nextel Corporation.
Sprint'
Continuity Analysis & Planning
Sprint formally analyzes risks and criticality of all parts of the business that could cause impacts or
disruptions, if not properly mitigated and planned. These elements of the program ensure the proper priority
and attention is applied to mitigation and plan development efforts.
CriticalitY Analvsis:
Through various forms of analysis, such as Business lmpact Analysis (BlA), criticality of business
processes, applications, vendors, sites, network elements and other business aspects are determined.
The criticality defines the appropriate level of mitigation and planning that is necessary. Critical business
processes require a comparable criticality assigned to the applications they use, the suppliers they need
and other dependencies.
Risk Manaqement:
Sprint considers resiliency and Business Continuity risks to be a matter that requires tight management
and controls. Potential risks are evaluated using an internal algorithm, to determine appropriate
mitigation and Business Continuity planning efforts.
Mitiqation Strateoies & Plan Development:
Upon identification of potentially significant risks, Sprint makes every attempt to mitigate and plan for any
eventuality that could affect Sprint's customers and employees. ln most cases, the risks are
marginalized or eliminated due to mitigation efforts. ln some cases, the risks are highly improbable, but
still require alternative planning, in the event that it should occur.
The remainder of this document describes specific Business Continuity Plan details that are of
interest to customers and potential customers of Sprint
Workforce Resiliency Overuiew
Pandemic Plannino Overview
Sprint has implemented a pandemic plan that targets a safe and productive work environment for all
employees and takes into consideration that absenteeism may be excessive for a period of time.
Sprint's plan allows for flexibility and scalability to adjust to changing events. The plan also incorporates
a wide range of strategies that may be implemented by business units while ensuring communication
and information sharing on status and success.
A separate plan document is available upon request for Sprint's Pandemic Plan.
Alternate Site and Remote Access Overview
Sprint utilizes information obtained through business impact analysis and risk reduction strategies in
order to preserve business functions that are required in the face of a disaster. Depending on the size
and scale of the event, Sprint has strategies in place to provide added capacity, alternative work
locations and remote access if necessary to retain operations.
Business functions that require alternate sites, geographic redundancy and remote access capabilities
are identified proactively and plans are periodically reviewed and revised as necessary in anticipation of
any event.
This document may not be duplicated, modified, used by, disclosed or forwarded to a third party without the prior
express written consent of Sprint Nextel Corporation.
Sprint
Network Resiliency Overview
As a Mobile Telecommunications Leader, the resiliency of Sprint's network is of paramount interest to
our customers.
Network lncident Manaoement Team
Network Services' implementation of the lncident Command System (lCS), stays true to the core
principles of lCS. This enables Sprint to leverage this best practice in wide-scale responses, using
common terminology and standard organizational structures, to communicate efficiently internally and
with customers such as Public Safety agencies as many of these agencies utilize ICS as well. Teams
train on and deploy in standard ICS Sections, branches, units and strike teams, and emphasize span of
control, comprehensive resource management, and other ICS principles.
Network teams leverage Sprint tools such as Direct Talk units, (off-network unit-to-unit communications)
GPS hand held units, camera phones, laptop wireless cards, and smart phones to aid in response
communication, situation assessment and resource tracking. The teams also maintain a pool of Satellite
phones as a contingency plan to use in restoration. Teams continue to create innovative response tools,
such as the unique Satellite backhaul SaICOLTS (Cell on Light Truck) that enable restoration of service
when a traditionalTl circuit is not available.
The Network IMT receives notification of an actual or potential situation that requires activation
(hurricane, earthquake, regional power outage, other event where business as usual would not resolve
the situation), establishes the Emergency Operations Center (EOC), performs an initial overall
assessment, establishes monitoring bridge(s), coordinates between agencies impacted by the event,
assigns tasks, gathers status information, and performs executive notifications at prescribed times.
Cell Site Disaster Planninq
Sprint's priority site restoration plan focuses resources and speeds recovery partly by making sure that
existing infrastructure is operating properly under normal circumstances and by having a reaction plan
for abnormal circumstances. To accomplish this, Sprint has implemented a detailed preventative
maintenance program on site hardware to insure all systems and redundant equipment are in proper
working order. Sprint sites are equipped with battery backup. Some sites have fixed generators or fuel
cells for additional back-up power. . Sprint maintains a fleet of mobile generator sets, which can be
deployed to Sprint service areas.
Cellular Network Disaster Plannino
The Sprint wireless networks consist of multiple circuits on various combinations of copper, fiber, and
microwave radio syslems. Most Sprint hub locations are placed on their SONET bi-directional fiber
rings. These rings significantly reduce the chance of network failure due to third party fiber damage,
equipment failures, or other potential causes of service interruptions. Sprint's radio network provides
significant overlapping coverage areas, which often allow cell sites to fully or partially compensate for a
neighboring cell site. Also in an effort to minimize service impact when a site is down, Sprint maintains a
fleet of 'Cell On Wheels" (COWs), which are portable self-contained cell sites. COWs can be deployed to
restore coverage from a damaged site or provide additional capacity in the immediate vicinity of an
incident.
Switch Locations Disaster Planninq
Sprint has implemented a distributed architecture for interconnection redundancy utilizing dual fiber
facilities at all of our switch locations. These main switch locations currently have battery backup as well
as permanent generators. In addition, site recovery plans have been developed for all major switch
locations, prioritizing available options for relocation, and ensuring agility when faced with disaster
This document may not be duplicated, modified, used by, disclosed or fonararded to a third party without the prior
express written consent of Sprint Nextel Corporation.
Sprint"
recovery issues. Most switches also have tap boxes to readily connect the output of a portable
generator in the event of primary generator issues.
Overal I Network Performance Manaqement Efforts
The performance of Sprint's networks is monitored 24 hours a day,7 days per week, 365 days a year by
the Network Monitoring Centers (NMCs). ln addition, local switching offices staffed by trained
technicians and management coordinate with these larger operations centers, to ensure that Sprint's
networks are properly maintained and network performance is at expected levels.
Network Restoration Prioritiz{llon
Sprint's Business Continuity Management Team works as a customer advocate when large network
outages occur. The team works closely with network recovery response teams to establish customer
prioritization once the backbone, TSP (Telecommunications Service Priority) and Critical Life Circuits are
re-established. Sprint has an established service restoration priority and process.
Special Event Plannino
Special events have the potential to adversely impact the customer experience due to the greatly
increased traffic demand they place on communications networks. Sprint has a formal mature special
events process with dedicated project management personnel and a cross-functional management tool.
Teams archive records of recurring special events for future planning, and proactively search for one-
time special events and leverage capacity planning teams in implementing enhancements to optimize
the customer experience. Sprint has leveraged its experience in managing very large temporary users at
NASCAR events in managing specialevents.
As a specialized type of special event, Sprint also interfaces with the NCS (National Communications
System) in managing capacity needs at National Security Special Events, NSSES.
This document may not be duplicated, modified, used by, disclosed or forwarded to a third party without the prior
express written consent of Sprint Nextel Corporation.
Sprint
lnformation Technology Resiliency Overview
lnformation Technoloqv lncident Manaoement Team
The lT lncident Management Team (lT IMT) provides timely decision making processes in the
declaration of a disaster to ensure the proper decisions are made and communicated across the
enterprise. The lT IMT team structure will minimize the disaster declaration time and potentially minimize
the length of the event by quickly reacting to the event. The lT IMT is also responsible for maintaining
and facilitating the execution of the recovery plans in conjunction with Resource & Priority Management
(RPM).
lnformation Technoloqv lncident Gommand Genters
The lT IMT Command Center serves as a centralized arena to manage disaster related operations.
Recovery personnel execute defined processes and procedures, communicate and provide resources to
effectively assess and manage disaster events. The lncident Command Centers are geographically
redundant.
Data Center and Svstem Resiliencv Planninq
The lT IMT is a proactive planning group that works in partnership with peer IMT organizations. The
collective team is responsible for the accuracy and integrity of current information in their particular area
of responsibility, including internal procedures, available systems, resources, call trees and points of
contact. The lT IMT provides personnel with the necessary resources to assist with the restoration
process. Sprint-Data Genters are held to exceptionally high and stringent industry, but more importantly,
self-imposed standards of structural design, engineering, technology, redundancy, security, maintenance
and 24x7 operations. Data Centers are geographically diverse and have the capability to execute an
internally developed disaster recovery methodology of lnternal Business Recovery (lBR) where on Data
Center functions as the recovery site for another Data Center.
lT Network Restoration Prioritization
Critical Applications supporting the internal and external client community have been prioritized based on
application impact analysis in order to expedite and control the recovery process. Data required for
recovery of operating systems, production libraries, and application systems are backed up regularly and
placed in otf-site storage.
This document may not be duplicated, modified, used by, disclosed or forwarded to a third party without the prior
express written consent of Sprint Nexlel Corporation.
Sprint
Emergency Responee Team (ERTI
Who is the ERT?
Sprint's ERT is an experienced cross functional group which consists of a national team of full time,
dedicated personnel as well as over a thousand of ERT Reservists across the country, that provides
wireless telecommunications equipment, infrastructure and personnel operations support to federal, state
and local public safety, law enforcement, military agencies and private Sector Organizations during
declared emergencies, field training exercises, agency specilic short term communication needs and
National Special Security Events.
Suoport for Uroent Grisis Needs
The ERT designs and implements the internal policies and procedures necessary to enable timely and
effective deployments of Sprint's products and services. The ERT fully supports high volume, short
notice voice and data communication needs of emergency and disaster personnel with its SaICOLTS
(Satellite Cell on Light Truck), Satellite lP Equipment, satellite earth station, and inventory of over twenty
five thousand handsets and aircards which can be rapidly deployed to support short term
communications.
ERT in the EOCs
During a number of recent disasters, reservists staffed State and Local Emergency Operations Centers
(EOC) to relay first-hand information back to agencies that rely on critical communications. Having
reservist representation at EOC's is valuable for a number of reasons: Reservists provide real time
information and status updates to the EOC's on the progress of our network recovery efforts ; Allows
State EOC's to provide direction on priority areas for Network restoration; Coordinate information from
other critical infrastructure functions, such as Energy/Power and Transportation; and obtain location of
FEMA and other emergency responder command posts using Sprint handsets to help plan for influx of
capacity needs. The EOC initiative is an example of Sprint's proactive approach during an incident,
through partnership, involvement and communications support. Partnering with Emergency Management
agencies in cities and counties throughout the United States provides befter coordination of Sprint and
ERT support resources for Disaster Preparation and Response. Trained ERT Reservists are more
actively involved in providing their communities with critical volunteer support. Agencies are able to have
a direct channel into Sprint approved support organizations with more expedited response times and
capabilities, providing critical communications support when it's needed the most.
ERT has deployed in support of over 4800 deployments supporting federal, state and local public safety,
law enforcement, military and enterprise organizations; including 36 Presidential declared disasters since
2002.
Contact us
For more information on Sprint's Emergency Response Team, please visit us at www sprint.com/ert,
become a fan on Facebook at www.facebook com/SorintEmeroencvResoonseTeam email us at
ERTReouests@sorint com or for emergency communications support, contact ovr 24x7x365 ERT Hotline
at't-888€39-0020 or for GETS users 254-295-2220.
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express written consent of Sprint Nextel Corporation.
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