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HomeMy WebLinkAbout20140630MTE Communications FCC Form 481.pdfffi,M,AM MTE 2205 Keithley Creek Road P.O. Box 7 R r c E lt"li lt Midvale, lD 83645 208.355.2211 z0lq JUN 30 hl{ g: 27 Fax 208'355'2222COMMUNICATIONS REDACTED.TORPUBLIC INSPECTION iilT\i 1] i}I,.11,.; t.lT !LlTlL:5 riLii,l l,i l;.,;: ; i., i Jure24,2014 VIA OVERNIGHT DELIVERY Marlene H. Dortctr, Secretary Federal Communications Commission Office of the Secretary 445lzth Sfeet, S.W. Washington, DC 20554 RE: Confidential Financial Information Subiect to Protective Order in WC Docket Nos. 10-90. 07-135. 05-337. 03-109. CC Docket Nos. 0l-92. 96-45. GN Docket No.09-51. WT Docket No. 10-208. Before the Federal Communications Commission Dear Ms. Dortch: Midvale Telephone Exchange, Inc. ("MTE"), a privately-held rate-of-return carrier receiving high cost support, has electronically submiued FCC Form 481 to the Commission with redacted financial data in compliance wfih 47 C.F.R. $$ 54.313 and 54.422. As specified in the Protective Order issued on November 16, 20l2by the Commission, two copies of the redacted confidential information are being filed simultaneously with the non- redacted confidential information. The redacted information for this filing and each page of the file where confidential information has been omitted is marked "REDACTED - FOR PUBLIC INSPECTION''. Please feel free to contact me with any questions regarding this particular matter. Sincerely, ', t. i \-:\f. i; -\:j'..... rJdHi'sdft" ) -----.? CEO Midvale Telephone Exchange, [nc. Enclosures .cc Mr. Charles Tyler, FCC Telecommunications Access Policy Division Idaho Public Utilities' Arizona Corporation Commission "Employe Owned, Community Focused Customer Centered" MTE Communications is an equal opportunity provider and employer & ru R,-r-t4.ul ^dffi. lt-F ^#^lYI I tr, CO]I,IMUNICATIONS CONFIDENTIAL FILING Jvrc24,2014 VIA OVERNIGHT DELIYERY Marlene H. Dortch, Secretary Federal Communications Commission Office of the Secretary 445120o Sfieet, S.W. Washington,Dc 20554 2205 Keithley Creek Road P.O. Box 7 Midvale, lD 83645 208.355.2211 Fax 208.355.2222 RE: Confidential Financial Information Subiect to Protective Order in WC Docket Nos. 10-90.07-135.05-337.03-109. CC Docket Nos. 01-92.9645. GN Docket No. 09-51. WT Docket No. 10-208. Before the Federal Communications Commission Dear Ms. Dortch: Midvale Telephone Exchange, Inc. (*MTE"), a privately-held rate-of-return carrier receiving high cost support, has electonically submitted FCC Fomr 481 to the Commission with redacted Line 3005 financial data and five-year build out plan in Line 100. MTE respectfully provides the Commission with its confidential financial data so that all its reporting obligations are satisfied. MTE, by its authorized representative, respectfully submits confidential information in compliance with 47 C.F.R. $$ 54.313 and54.422, under seal, as specified with the Protective Ordered adopted onNovember 16, 2012 ("Protective Order") and also in conjunction with47 C.F.R. $$ 0.457 and 0.459. Further justification for this confidential filing is identified below in accordance with 47 C.F.R $0.4590). MTE requests confidential teatment of certain information submitted with its annual reporting requirements as a privately-held rate of return carrier and high-cost recipient in Docket No. l0- 90. The confidential information is required by 47 C.F.R. $ 54.313(0(2) and includes detailed financial information that is competitively sensitive. Disclosure of this confidential inforrration would have a substantial negative impact on MTE. Such information would not normally be made available to the public for inspection because of the financial infomration and should be afforded confidential treatment under both 4 7 C.F.R. $$ 0.457 and 0.459. 47 C.F.R. g 0a9O): Information provided by MTE includes specific information related to financial data and is subject to protection for the following reasons: 47 C.F.R. $ 0459OXl) Identification of the specific inforrration for which confidential treaftrent is sought: MTE requests that all financial dat4 loop/subscriber counts and route mile data be treated on a confidential basis under Exemption 4 of the Freedom of Information Act. MTE maintains this information is confidential, competitively sensitive data not normally made available to the public. Release of this information would have a substantial negative competitive impact on MTE. The non-redacted version of the cover letter for MTE's submission and each page of the file containing confidential information is marke4'CONFIDENTIAL FINANCIAL INFORMATION SUBJECT TO PROTECTTVE ORDER IN WC DOCKET NOS. 10-90, 07-135,05-337,03-109, CC DOCKET NOS. 01-92,96- 45, GN DOCKET NO. 09.5I, WT DOCKET NO. IO.2O8, BEFORE THE FEDERAL COMMUNICATIONS COMMISSION." 47 C.F.R. $ 0459OX2) Identification of the Commission proceeding in which the inforrration was submitted: The information is being submitted in compliance with 4 7 C.F.R. $ 54.313(0(2) and is to be filed in WC DocketNo. 10-90. Privately held rate of retum carriers that receive high-cost support must complete the FCC Form 481 to include a full and complete annual support of the company's financial condition and operations as of the end of the preceding fiscal year (sections of which MTE is requesting be afforded confi dential treatnent). 47 C.F.R. $ 0459OX3) Explanation of the degee to which the information is commercial or financial or contains a trade secret or is privileged: The infomration designated as confidential is detailed financial information including a balance sheet, income statement cash flow statement that is competitively sensitive information not normally released to the public. Release of any of this commercial or financial information would have a substantial negative competitive impact on MTE. 47 C.F.R. $ 04590)(,4)&(fl Explanation of the degree to which the information concerns a service that is subject to competition and how disclosure of the information could result in substantial competitive harm: This type of commercial and financial information is generally not subject to routine public inspection under the Commission's rules (47 C.F.R. $ 0.457(d), demonsfiating that the Commission already anticipates that the release of this type of inforrration likely would produce competitive harm. Release of the information designated as confidential would allow competitors to become aware of sensitive proprietary information regarding the operation of MTE's business and would cause MTE substantial competitive harm. 47 C.F.R. $ 0459ftXO&(7) Identification of measures taken b], the Company to prevent unauthorized disclosure: availabilitv of the information to the public and extent of any previous disclosure of the information to third parties: MTE treats and has treated the non-public information included in this Submission as confidential and has protected it from disclosure to parties outside the Company. Any financial information required to be submitted to a state regulatory authority has been "Employx Ownd, Community Focud, Customer Centeted" MTE Communiations is an equal opportunity provider and employer filed as confidential information, not available to the public, in accordance with state rules and/or statutes. 47 C.F.R. I 0459(bX8) Justification of the period dtrine which the Company asserts that material should not be available for public disclosure: MTE cannot determine any date on which this information should not be considered confidential. However MTE does believe that this information should be treated confidential for a minimum of l0 years. 47 C.F.R. I 0459(bX8) Other information the Company believes may be usefrrl in assessing whether its request for confidentialitv be sranted: Under applicable Commission rules and court rulings, the information designated by the Company as confidential should be withheld from public disclosure. Exemption 4 of the Freedom of Information Act protects information that is commercial or financial in nature; obtained from a person outside government; and privileged or confidential. As specified in the Protective Order, two copies of the redacted confidential information are being filed simultaneously with the non-redacted confidential information. The redacted information for this filing and each page of the file where confidential information has been omitted is marked *REDACTED - FOR PUBLIC INSPECTION" Please feel free to contact me with any questions regarding this particular matter. Sincerely, Midvale Telephone Exchange, [nc. Enclosures Mr. Charles Tyler, FCC Telecommunications Access Policy Division Idaho Public Utilities Arizona Corporation Commission "Employe Ownd, Community Focused, Customer Centeted" MTE Communications is an equal opportunity provider and employer CEO UNE 100 REDACTEI) FOR PI]BLIC INSPECTION ldaho Service Quality Standards and Consumer Protection Rules Compliance Midvale Telephone understands and complies with the ldaho Public Utilities Commission's Telephone Customer Relotions Rules, IDAPA 3t.4t.07, adopted under the general legal authority of the Public Utilities Law, Chapters l through 7, Title 61, ldaho Code, and the Telecommunications Act of 1988, Chapter 6, Title 52, ldaho Code, with regards to service. These telephone customer relations rules provide a set of fair, just, reasonable, and non-discriminatory rules regarding deposits, guarantees, billing, application for service, denial of service, termination of service, complaints to telephone companies, billing for interrupted service, and provisions of certain information about customer to authorities. Functionality in Emergency Situations Pursuant to 47 C.F.R. 5 5a.313(aX5) and/or 47 C.F.R S 54.422(bX4) as set forth in 47 C.F.R. 54.202 (aX2). Midvale Telephone meets the requirements to remain functional in emergency situations and has the following capabilities: Back-up power is provided to Midvale Telephone's central and or remote office(s) by use of fixed generator and batteries that provide it with a minimum of 24 hours of emergency power service. ln addition, Midvale Telephone's field electronics have a minimum of 24 hours of back-up power by use of fixed/mobile generators and batteries. Midvale Telephone also has SONET technology in its network that allows for self-healing network should a fiber cut occur in its core network and will automatically reroute traffic. Midvale Telephone also has 2 redundant paths within its network to provide for the capability to reroute traffic. Midvale Telephone has equipped its remote offices with Emergency Stand Alone technology that will provide for call completion and access to 911 in emergency situations. Midvale Telephone is capable of managing traffic spikes resulting from emergency situations. Response to Line 1000 MTE Communications StudyArea 472226 Voice Services Comparability Report Pursuant to 47 C.F.R. S 54.313 (a) (10 ) MTE Communications (MTE) is in compliance with the requirement that voice services is no more than two standard deviations above the national average urban rate for voice service of Sa5.95 as specified in Public Notice DA 14-384 issued on March 20,2OL4. MTE's current total local end-user ratel of 525.75 is not above the standard deviation as specified in the USF/ICC Transformation Order. 2 1 Local End User Rate as defined in USF/ICC Transformation Order 26 FCC Rcd at 17751, Para. 238 'USf/tCCtransformation Order,26 FCC Rcd aLt7694, Para. 84 (footnote included) "The standard deviation is a measure of dispersion. The sample standard deviation is the square root of the sample variance. The sample variance is calculated as the sum of the squared deviations of the individual observations in the sample of data from the sample average divided by the total number of observations in the sample minus one. ln a normal distribution, about 58 percent of the observations lie within one standard deviation above and below the average and about 95 percent of the observations lie within two standard deviations above and below the average." IINE 7OO REDACTEI) FOR PTIBLIC INSPBCTION TINE 7IA REDACTEI) FORPUBLIC INSPECTION IDAHO PUBLIC UNLMES Midvale Telephone company - App-T'^I^ Customer Service Contacl (bOqqeZnSZ3 Aug. 13, 2012 Aug.tl,2012 Jean D. Jewel! Secretary Idaho Fublic Utilitie.s Commission TariffNumber4 Odginal SheetNumbefi 62 tV. LIFELII\IE GENERAL A federal progmm applicable to qualifying low-income subscribers to single party residential service of the Company. RATES 1. Baseline Lifeline is a reduction or credit in the local service charges normally paid by qualifying low-income consumers. The reduction to tle normal residential one-party rates are as establishedby the Federal Communications Commission (FCC). C. These reductions or credits are from the normal residential one-party semrice subscribed to by the consumer. In addition to the Federal Service Discount, the State may provide an additional discormt for eligible consumsrs, pnrsuant to Idaho code Title 56, C:hapter 9. In no case will the discount exceed the rate charged for the service zubscribed to by each individual. ELIGIBILITY REQIJIREMENT S To qualiff for Lifeline Senrice, an applicant must meet all of the requirements established by the FCC. a. The consumer must be a head of household whose gross income is at or below one hundred and thirty-five percent (135%) of the Federal Poverty Limit. b. The customer must be recertified aonually by the appropriate state agenry. c. The premises at which the residential service is requested is the applicant's principle place of residence. l. Issucd July 27, 20 I 2 Effective Augu st 27 , 2012 Issued by Midvale Telepholre Company : SteDhen G. Child Title: CEO A. B. IDAHO PUBLIC UflLMES MidvaleTelephonecompany - o'p-1"1*^ Customer Service Contact 1too7+az-+sz3 Aug' 13, 2012 Aug'27,2o12 Jean D. Jewell Secrctary Idaho Public Utilities Commission TariffNumber4 Original SheetNumber: 63 rv. LTFELINE (CONTTNITED) C. ELIGIBILITY REQIJIREMENTS, (CONTINUED) d. Only one telephone line (wireline or rtrireless) per househotd is eligible for the credit. A "household" is any individual or group of individuals, related and unrelate{ who are living together at the same address as one economic udt. An "economic unif'consists of all adult individuals contibuting to and sharing in the income and expenses of a household. E. REGI.JLATIONS 1. The regular service connection charge, move and change charge, and regulations applicable to the service offerings specified in the tariffwill apply. The service connectioo charge and move and change charge to change to or from this program due to eligibility status wiII be waived. 2. The Company will offer Lifeline assistance only drning such periods as reimbursement of the discormt is available to the Company from Federal and/or State revenue sources. V. IDAHOTELECOMMT]NICATIONSSERVICEASSISTAI\TCEPROGRAM (IrsAP) A. A state program applicable to qualifring low-income residential zubscribers ITSAP provides eligfrle recipients with a reduction in costs of residential basic local exchange telephone senrice. B. SURCHARGERATES The monthly surcharge is set at the amount ordered by the Idaho Public Utilities Commission. Issr.redJuly 27,20t2 EffectiveAugustn,20l2 Issued by Midvale Telephone Company : SteDhenG.Child Titler CEO IDAHO PUBLIC UILMES MidvaleTelephoueCompauy - App-T|{-- Customer Service Conact $Oq CAZCSZ3 Aug. 13' 2O12 Aug. t7, 2O12 Jean D. Jewell Secrctary Idaho Public Utilities Commission TariffNumber4 Original SheetNumber: 64 rv. rTsAP (coNTrNrrED) C. CONDMIONS 1. A surcharge assessed on all access lines to contribute toward funding for the Idaho Telecommmications Serrice Assistance Program (ITSAP). The ITSAP suxchaxge will not be assessed on ITSAP-eligible zubscribers' bills 2. The surcharge rate will remain in effect until otherwise modified, cancele4 or changed by the Commission. VI. IDAHO UNIVERSAL SERYICE T'UND SI'RCHARGE A. RATES The monthly surcharge is set at the amor:nt ordered by the Idaho Public Utilities Commission. B. CONDITIONS A surcharge assessed on all access lines to contibute toward funding for an Idaho Universal Service Fund. The surcharge rate will remain in effect until othenvise modifie4 canceled" or changed by the Commission. YI[. CONCURRENCES Midvale Telephone Company concurs in the filed tariffs of the Mountain States Telephone and Telegraph Company dba CenturyLinlq together with amendments and successive issues thereof, for the purpo$e of providing message toll telephone service between its points when no other telephone company jointly provides the message toll service with the Company. IssuedJuly27,2012 Effective Atgnst77,2ol2 I*sued by Midvale Telephone Company : Steohen G. Child Title: CEO LINE 3OO5 REDACTED F'ORPUBLIC INSPECTION