20040123Motion to Take Judicial Notice Nextel.pdf

ORIGINAL
McDEVITT & MILLER, LLP
Dean J. Miller (ISB No. 1968)
420 West Bannock Street
O. Box 2564-83701
Boise, Idaho 83702
Phone [phone]
Facsimile [phone]
j oe~mcdevitt -miller .com
BRIGGS AND MORGAN, P.
Philip R. Schenkenberg (MN #260551)
2200 First National Bank Building
332 Minnesota Street
Saint Paul, Minnesota 55101
Phone [phone]
Facsimile [phone]
psch enken berg~ bri ggs. co m
Attorneys For NPCR, Inc. d/b/a Nextel Partners
RECEIVED
L. E 0
fiJ
2ilD~ JJ N 23 P~1 3:
, '
UTiLI liES COr"Ji'"lISSiON
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
In the Matter of the Petition of IA T
Communications, Inc. d/b/a NTCH-Idaho, Inc.
or Clear Talk for Designation as an Eligible
Telecommunications Carrier.
In the Matter of the Application of NPCR, INc.
d/b/a NEXTEL PARTNERS Seeking Designation
as an Eligible Telecommunications Carrier that may
receive Federal Universal Service Support.
) Case Nos. GNR-03-8 & GNR-03-
MOTION TO TAKE
) JUDICIAL NOTICE
Pursuant to IPUCRP 263 , Nextel Partners requests that the Commission take judicial
notice ofthe attached Order (Nextel Partners Arkansas Order) issued by the Arkansas Public
Service Commission (Docket No. 03-141-, Order No.4) and in support thereof respectfully
shows as follows:
MOTION TO TAKE JUDICIAL NOTICE-
1. Pursuant to IPUCRP 263.01(a)(2) the Commission may take judicial notice of the orders
of "any other regulatory agency, state or federal."
2. Evidentiary hearings in this matter concluded on December 11 , 2003 and the Nextel
Partners Arkansas Order was issued on December 22 2003 , after the close of the Idaho evidentiary
record.
3. The Nextel Partners Arkansas Order is relevant to the Commission s deliberations
because it considers and discusses a number of the issues raised in this proceeding.
4. No party will be prejudiced by the granting of this motion.
WHEREFORE, Nextel Partners respectfully requests that the Commission enter its Order:
1. Takingjudicial notice of the Nextel Partners Arkansas Order;
2. Directing that the Nextel Partners Arkansas Order be marked as Exhibit No. 111 and
included in the record as a late-file exhibit.
Oral argument is not requested on this Motion.
Respectfully submitted, January , 2004
llitXTEL
PARTNERS, IN
McDEVITT & MILLER, LLP
Dean J. Miller
420 West Bannock Street
O. Box 2564-83701
Boise, Idaho 83702
Phone [phone]
Facsimile [phone]
BRIGGS AND MORGAN, P.
Philip R. Schenkenberg (MN #260551)
Matthew Slaven (MN #288226)
2200 First National Bank Building
332 Minnesota Street
Saint Paul, Minnesota 55101
Phone [phone]
Facsimile [phone]
COUNSEL FOR APPLICANT
NPCR, INC d/b/a NEXTEL PARTNERS
MOTION TO TAKE JUDICIAL NOTICE-
ARr: : '-, ,.
:":0'
;;j.
ARKANSAS PUBLIC SERVICE COMMISSit)iJL 2 11 PH '
~.- 11 ,
~: ~\
\' '-'.0-
IN THE MATTER OF THE APPLICATION OF
NPCR, lNc. D/B/A NEXTEL PARTNERS FOR
DESIGNATION AS AN ELIGIBLE
TELECOMMUNICATIONS CARRIER
PURSUANT TO SECTION 214(e)(2) OF THE
COMMUNICA nONS ACT OF 1934, AS AMENDED
DOCKET NO. 03-141-
ORDER NO.
ORDER
On August 28, 2003, NPCR, Inc. d/b/a Nextel Partners ("Nextel") initiated this docket by
filing a petition for designation as an eligible telecommunications carrier ("ETC") pursuant to
section 214(e)(2) of the Federal Communications Act of 1934 as amended
, ("
the Federal Act"
Nextel's petition asserts that the Arkansas Public Service Commission ("APSC" or "this
Commission ) has established procedures for designation as an ETC2 and that Nexte1 has
complied with those procedures.
Nextel states that it is a commercial mobile radio service common carrier3 and seeks
designation as an ETC for certain specified wire centers in a Southwestern Bell Telephone
Company study area.Nextel asserts that, pursuant to 9 214(e)(2) of the Federal Act and
consistent with this Commission s Order in Docket No. 97-326-U, the Commission must
designate more than one common carrier as an ETC in non-rural service areas as long as each
carrier requesting ETC status meets the requirements of g 214(e)(2) of the Federal Act.
In support of its petition, Nextel offers the affidavit of Donald J. Manning, Vice President
and General Counsel for Nextel. Mr. Manning s affidavit asserts that Nextel is able to offer all
47 U.C 9 214 (e)(2).
2 See in the Matter of Determining Eligible Telecommunications Carriers in Arkansas, Order No. I , Docket 97-326-
u (August IS , 1997).3 Also referred to as a wireless or cellular carrier.
4 See attachment I , exhibit A to Nextel's petiton.
Case Nos. GNR-T-03-8 &. GNR-T-03-16
Exhibit No. 111, page 1 of 10
NPCR, Inc. d/b/a Nextel Partners
DOCKET NO. 03-141-
PAGE 2 OF 10
servIces and functionality required by 47 CFR 9 54.101(a) to its customers usmg its own
facilities in the Southwestern Bell wire center areas. Specifically, Nextel states that it is able to
offer voice grade access to the public switched network, local usage, dual tone multi-frequency
signaling or its functional equivalent, single-party service or its functional equivalent, access to
emergency service, access to operator services, access to interexchange service, access to
directory assistance, and toll limitation for qualifying low-income consumers. The affidavit
states that Lifeline and Linkup programs, which can only be offered by ETCs, and toll blocking
for Lifeline subscribers, will be made available when Nextel receives an ETC designation.
Three sets of comments were filed on September 29, 2003 by three groups of incumbent
local exchange carriers ("ILECs The rural ILECs argue that wireless carriers are essentially
unregulated in Arkansas and do not provide their customers with the protections provided in the
APSC's Telecommunications Provider Rules because wireless carriers are not subject to those
rules. The rural ILECs argue that, because wireless carriers are not subject to the APSC's
Telecommunications Provider Rules, it may not be in the public interest to approve Nextel'
ETC request.
The rural ILECs also argue that ifNextel takes a customer from an ILEC, the rural ILECs
would lose terminating access charges which would have been paid to rural ILECs for
terminating the toll calls of the customer taken by Nextel. The rural ILECs acknowledge that
Nextel would pay terminating access charges to rural ILECs for termination of toll calls from
The commenting parties are three groups of ILECS which will be referred to as (I) "the rural ILECS", which
consist of Arkansas Telephone Company, Inc.; Central Arkansas Telephone Cooperative, Inc.; Madison County
Telephone Company; Magazine Telephone Company; Northern Arkansas Telephone Co.; Pinnacle
Communications; Prairie Grove Telephone Company; Rice Belt Telephone Company; South Arkansas Telephone
Company, Inc.; Southwest Arkansas Telephone Cooperative, Inc.; Walnut Hill Telephone Company; and Yell
County Telephone Company (2) "the Ritter companies , which consist of Ritter Communications Holdings, Inc. on
behalf of its whol1y owned subsidiaries Ritter Telephone Company and Tri-County Telephone Company, along with
Ye1cot Telephone Company and Mountain View Telephone Company and (3) "the CenturyTel companies" which
consist of CenturyTel of Central Arkansas, LLC; CenturyTel of Northwest Arkansas, LLC; CenturyTel of Arkansas
Inc.; CenturyTel of Mountain Home, Inc.; CenturyTel of Redfield, Inc.; CenturyTel of South Arkansas, Inc.
Cleveland County Telephone Company, Inc.; and Decatur Telephone Company,lnc.
Case Nos. GNR-T-03-8 & GNR-T-03-
Exhibit No. 111, page 2 of 10
NPCR, Inc. d/b/a Nextel Partners
DOCKET NO. 03-141-
PAGE 3 OF 10
Nextel customers, however, the rural ILECs assert that the terminating access rates paid by
wireless carriers are substantially less than those paid by other ILECs, such as Southwestern
Bell, and the resulting reduction in access charges paid to the rural ILECs could affect their
profitability and lead to rate increases for the customers of the rural ILECS.
The Ritter companies argue that ACA ~ 23-17-405(b) (5) provides that Nextel may not be
designated as an ETC unless "it is determined by the Commission that the designation is in the
public interest" and that Nextel is not entitled to an automatic grant of ETC status. The Ritter
companies state that Nextel has failed to demonstrate that ETC designation for Nextel is in the
public interest and that Nextel has not shown that competition will be materially increased or that
new or advanced services will be delivered sooner as a result of Nextel receiving ETC
designation. The Ritter companies assert that granting ETC status to Nextel could detrimentally
effect the Federal Universal Service Fund
, ("
USF"), because the USF is funded by assessments
on telecommunications providers ' interstate revenue and as the size of the USF grows, as a result
of commercial mobile radio service providers receiving ETC status, the customers of the Ritter
companies will be charged increasing amounts to fund the USF and will receive no demonstrable
benefit.
The Ritter companies also argue that CMRS providers are not subject to the same quality
of service standards as ILECs and are not required to act as a provider of last resort. The Ritter
companies assert that the lack of these protections for Nextel's customers leads to the conclusion
that Nextel's designation as an ETC is not in the public interest.
The Ritter companies ' comments also point out the continuing activity by the Federal-
State Joint Board on Universal Service ("Joint Board") and the United States House of
Representatives Energy and Commerce Committee which are reviewing the operations of the
USF.The Ritter companies suggest that this Commission wait until the Joint Board and
Case Nos. GNR-T-03-8 & GNR-T-03-16
Exhibit No. 111, page 3 of 10
NPCR, Inc. d/b/a Nextel Partners
DOCKET NO. 03-l41-
PAGE 4 OF 10
Congress have completed their reviews of the USF and made any necessary changes before
granting ETC status to Nextel.
The CenturyTel companies also raise many of the issues that are currently under review
by the Joint Board, arguing that the availability of affordable high quality telephone services to
consumers is at risk because of the ever-increasing demands on the USF from new carriers being
granted ETC status. The CenturyTel companies request that the APSC deny the ETC request
and initiate a generic proceeding to examine the policy and factual issues presented by the
application or delay any decision until the Joint Board reports its findings regarding the USF to
the Federal Communications Commission ("FCC"). The CenturyTel companies refer to the
spiraling" demands on the USF caused by the influx of ETC applications asserting that Nextel
does not need USF support to be competitive and that granting ETC status to carriers that do not
need USF support places the USF at risk. The CenturyTel companies note that the Federal
Universal Service charge has increased from 6.8 % to 9.3 % on interstate revenue over the past
two years and note that this issue is currently under review by the Joint Board.
The CenturyTel companies also argue that, when a carrier like Nextel receives an ETC
designation, it can increase its revenues through USF support funds regardless of whether it adds
any additional customers or obtains any customers from the ILEC serving the same area.
CenturyTel suggests that this ability to artificially inflate revenues through Federal USF support
when it cannot be shown that the revenues are needed is contrary to the public interest.
The CenturyTel companies claim that Nextel has not shown that it is able to provide
service in the entire study area, i., the geographical area for which Nextel seeks ETC status
and argue that the FCC rules which require wireless ETCs to use the customer billing address for
the purpose of identifying the service location provides an opportunity for customers to misuse
the service by obtaining service using a billing address within the ETC designated area, but using
Case Nos. GNR-T-03-8 & GNR-T-03-16
Exhibit No. 111, page 4 of 10
NPCR, Inc. d/b/a Nextel Partners
DOCKET NO. 03-141-
PAGE 5 OF 10
the service primarily within the service area of a rural ILEc. The CenturyTel companies argue
that the Commission should hold all pending ETC applications in abeyance until the FCC has an
opportunity to consider the Joint Board recommendations on the issues raised by the CenturyTel
companies in their comments.
The CenturyTel companies ' comments also reiterate the arguments previously made
asserting that when a wireless ETC captures a customer from an existing ILEC, the amount of
access revenues received by ILECs tenninating calls for the wireless ETC is less than the amount
of tenninating access which the ILEC would have received if it had tenninated the call from
another ILEC customer, thereby reducing the amount of access revenues available to the ILECs.
The CenturyTel companies also argue that Nextel is not required to serve as a carrier of last
resort and is not subject to the APSC's Telecommunications Provider Rules. The CenturyTel
companies assert that because the Telecommunications Provider Rules are not applicable to
Nextel, Nextel customers would not be able to file formal complaints and that the Commission
could not require credits or refunds for service interruptions, billing errors or failure to provide
service. The CenturyTel companies state that Nextel's rates are not subject to investigation by
this Commission and that Nextel's customers deserve the protections of the Commission
Telecommunications Provider Rules. The CenturyTe1 companies assert that because Nextel is
currently providing service in the area in which it seeks ETC designation, this Commission
should conclude that adequate competition exists in the area and that it is not in the public
interest to designate Nextel as an ETC since such designation would not further promote
competition.
Nextel's response to the comments filed by the ILECs asserts that it has met all of the
criteria set forth in the Federal Act and this Commission s previous orders regarding ETC
designation. Nextel emphasizes that it is not seeking ETC designation in any area served by a
Case Nos. GNR-T-03-S &. GNR-T-03-16
Exhibit No. 111, page 5 of 10
NPCR, Inc. d/b/a Nextel Partners
DOCKET NO. 03-141-
PAGE 6 OF 10
rural telecommunications company,Nexte1 argues that the Federal Act requires this
Commission to provide Nextel with an ETC designation if it meets the qualifications set forth in
47 USC ~ 214(e)(l) and 47 CFR 9 54.201(d). Nextel asserts that it has met those requirements
and this Commission must, therefore, provide an ETC designation to Nextel. Nextel argues that
FCC precedent holds that designation of an ETC in non-rural territory per se satisfies the public
interest requirement, citing In the Matter of Federal-State Joint Board on Universal Service;
Farmer s Cellular Telephone, Inc. Petition for a Designation as an Eligible Telecommunication
Carrier 18 FCC Rcd 3848 (released March 12 2003).
Although the comments raise significant public policy issues, those issues are properly
being addressed at the Congressional level and at the Federal Communications Commission. To
the extent comments raise public policy issues such as the potential expansion of the Federal
Universal Service Fund, these matters of public policy should be addressed at the Federal level
and should not effect this Commission s decision in this case for two reasons. First, this
Commission has no jurisdiction to make changes in the Federal USF or the laws under which the
Federal USF is established, and, second, this Commission is obliged to follow the requirements
of Arkansas law which require this Commission to act consistently with the Federal Act.
ACA 23-17-405 provides that the Commission may designate other
telecommunications providers to be eligible for high-cost support consistent with 47 USC 9
214(e) (2). This grant of authority to the Commission is conditioned on the telecommunications
provider accepting responsibility to provide service to all customers in the ILEC's local
exchange area through its own facilities or a combination of facilities, and the support will not
begin until the telecommunications provider has the facilities in place to serve the area. The
telecommunications provider may only receive funding for the portion of its facilities that it
owns and maintains the telecommunications provider must advertise the availability and
Case Nos. GNR- T -03-8 &. GNR- T -03-
Exhibit No. 111, page 6 of 10
NPCR, Inc. d/b/a Nextel Partners
DOCKET NO. 03-141-
PAGE 7 OF 10
charges for its services, and the Commission must determine that the designation is in the public
interest.
47 USC 9 214(e)(2) states that:
A State Commission shall upon its own motion or upon request
designate a common carrier that meets the requirements of
paragraph (I) as an eligible telecommunications carrier for
service area designated by the State Commission. Upon request
and consistent with the public interest, convenience, and necessity,
the State Commission may in the case of an area served by a rural
telephone company, and shall, in the case of all other areas
designate more than one common carrier as an eligible
telecommunications carrier for a service area designated by the
State Commission, so long as each additional requesting carrier
meets the requirements of paragraph (1). Before designating an
additional eligible telecommunications carrier for an area served
by a rural telephone company, the State Commission shall find that
the designation is in the public interest.
(Emphasis added).
Nextel seeks ETC designation in an area served by a non-rural telephone company.
Section 214(e)(2) clearly directs the Commission to designate more than one common carrier as
an ETC if the requirements of paragraph (1) are met. Sections 214 (e)(I)(A) and (B) require that
the carrier seeking ETC status must "offer the services that are supported by Federal Universal
Service support mech~isms under 9 254(c) of this title, either using its own facilities or a
combination of its Own facilities and resale of another carrier s services (including the services
offered by another eligible telecommunications carrier); and advertise the availability of such
services and the charges therefore using media of general distribution.) The affidavit submitted
by Nextel clearly indicates that Nextel has, or upon receiving ETC designation will, offer the
services required and advertise the availability of those services in compliance with 9 214(e)(1)
and 9 254(c) thereby meeting the requirements of 9 214(e)(2) ofthe Federal Act.
ACA g 23-17-405 requires this Commission to act in a manner which is "consistent with
~ 214(e)(2) of the Federal Act. . ." The fact that Nextel has agreed to comply with ~ 214(e) in
Case Nos. GNR- T -03-8 & GNR- T -03-16
Exhibit No. 111, page 7 of 10
NPCR, Inc. d/b/a Nextel Partners
DOCKET NO. 03-141-
PAGE 8 OF 10
obtaining ETC designation in an area served by a non-rural carrier is sufficient to determine that
granting ETC status is consistent per se with the public interest. In the Matter of Federal-State
Joint Board on Universal Service; Farmer s Cellular Telephone, lnc, Petitionfor Designation as
an Eligible Telecommunications Carrier 18 FCC Rcd 3848 (released March 12 , 2003); Cellco
Partnership d/b/a Bell Atlantic Mobile Petitioned for Designation as an Eligible
Telecommunications Carrier 16 FCC Rcd 39, ~ 14 (2000); Pine Belt Cellular and Pine Belt
PCS, Inc. Petition for Designation as an Eligible Telecommunications Carrier 17 Rcd 9589
, ~
13 (2002).
In adopting the Telecommunications Regulatory Reform Act of 1997(ACA g 23-17-401
et seq.
),
the General Assembly stated that its intent was to provide for a system of regulation
consistent with the Federal Act, that assists in implementing the national policy of opening the
telecommunications market to competition on fair and equal terms. Many of the objections
made to the granting of ETC status by the commenting parties suggest that the granting of ETC
status could affect the profitability of those companies and possibly result in rate increases to
their customers. They therefore argue that it is not in the public interest and is inconsistent with
Arkansas law to approve the ETC request.This argument ignores the statutory intent to
implement competition, which will obviously have an affect on the profitability of some
companies, but will also provide competitive alternatives to customers. If the ILECs receive
reduced terminating access charges from the contracts they have negotiated with wireless
carriers, they should receive the benefit of paying reduced access charges for terminating their
calls to the wireless networks. Additionally, the tenninating access rates paid between ILECs and
wireless carriers are negotiated rates which the ILECs have agreed to pay. The contracts
between the ILECs and wireless carriers should not, therefore, provide a basis to deny ETC
status to a wireless carrier.
Case Nos. GNR-T-O3-8 &. GNR-T-O3-
Exhibit No. 111, page 8 of 10
NPCR, Inc. d/b/a Nextel Partners
DOCKET NO. 03-141-
PAGE 9 OF 10
The suggestion by the ILECs that granting ETC status could affect their profits and their
customers ' rates does not suggest that granting ETC status is not in the public interest. The
granting of ETC status to Nextel will provide a competitive alternative for customers in the
Southwestern Bell area in which Nextel seeks to provide service. The effect on the ILECs in
Arkansas, resulting from the funding of the USF through assessments on all carriers' interstate
services, is essentially the same regardless of whether an ETC request is granted in Arkansas or
by another state commission. There wi1l be some effect on amounts paid by Arkansas ILECs
since all carriers' interstate revenues are assessed to support the USF; however, denying the
request would prohibit a group of Arkansas consumers from having the competitive alternatives
available to customers in other states even though those Arkansas consumers would be indirectly
paying fOT the benefits to customers in other states through payments for interstate services
which originate or terminate in Arkansas.
To the extent that the commenting parties have suggested that the Commission delay its
decision pending resolution of some of the issues raised in the comments and currently pending
or under consideration in United States Congressional committees or before the FCC's Joint
Board, the request to delay would be inconsistent with the requirements of 47 USC 9 214 (e)(2)
which states that the Commission "shall" grant the ETC request if the requirements of the statute
are met. Additionally, the issues raised by the commenting parties are best dealt with in the
appropriate forums which have the jurisdiction to effect any changes which might be deemed
necessary.
The commenting parties also argue that the ETC designation, if granted, should be
conditioned on Nextel's agreement to submit to this Commission s jurisdiction for enforcement
of the Commission s Telecommunications Provider Rules. This recommendation appears to be
inconsistent with the requirements of ACA g 23-17-411 (g), which substantially limits the
Case Nos. GNR-T-03-8 &. GNR-T-03-16
Exhibit No. 111, page 9 of 10
NPCR, Inc. d/b/a Nextel Partners
DOCKET NO. 03-141-
PAGE 10 OF 10
Commission s jurisdiction over commercial mobile radio services. The recommendation also
lacks support under g 214( e) which requires the Commission to grant ETC status if the
conditions set forth in the statute are met.
In view of the foregoing, the request by NPCR, Inc.d/b/a Nextel Partners for ETC status
in the exchanges of Southwestern Bell Telephone Company-Arkansas (study area code 405211)
is hereby granted.
BY ORDER OF THE PRESIDING OFFICER PURSUANT TO DELEGATION.
This ~.1 JJ.day of December, 2003.
~~L l~~iana K. Wilson
..... -
Secretary of the Commission
fj I/-Mli/L
Arthur H Stuenkel
Presiding Officer
I hereby certify that the following order issued by the
Arkansas Public Service Commission has been served
on all parties of record this date by the U.S, mail with
postage prepaid. using the address of each party as
indicated in the official docket file,
Secretary of the Commission
Date I ;J..-J.3--tko
Case Nos. GNR-T-03-8 & GNR-T-03-
Exhibit No. 111, page 10 of 10
NPCR, Inc. d/b/a Nextel Partners
CERTIFICATE OF SERVICE
I hereby certify that onJanuary 2004 I caused to be served true and correct copies of the foregoing
document, Nextel Partners' Motion to Take Judicial Notice by the methode s) indicated, upon:
Glenn Ishihara, President
rAT COMMUNICATIONS, INc.
703 Pier Avenue, Suite B; PMB 813
Hermosa Beach, California 90254
Molly O'Leary
RICHARDSON Cst O'LEARY
99 East State Street, Suite 200
O. Box 1849
Eagle, Idaho 83616
molly(fYrichardsonandoleary. com
Attorney for IA Communications, Inc.
Conley E. Ward, Jr.
GIVENS PURSLEY, LLP
227 North 6th Street, Suite 200
O. Box 2720
Boise, Idaho 83701-2720
cew(iYgi venspursley. com
Attorney for Idaho Telephone Association
Clay Sturgis, Senior Manager
Moss ADAMS LLP
601 Riverside, Suite 1800
Spokane, Washington 99201-0063
clays(iYmossadams.com
Attorney for Idaho Telephone Association
Morgan W. Richards
MOFFAT THOMAS BARREIT ROCK &: FIELDS
101 So, Capitol Blvd., 10th Floor
O. Box 829
Boise, Idaho 83701
mwr(iYmoffatt.com
Attorneys for Citizens Telecommunications of Idaho
Lance A. T ade, Manager
State Government Affairs
CITIZENS TELECOMMUNICATIONS OF IDAHO
4 Triad Center, Suite 200
Salt Lake City, Utah 84180
Itade(iYczn, com
Attorney for Citizens Telecommunications of Idaho
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Mary S. Hobson
STOEL RIVES LLP
101 So. Capitol Blvd., Suite 1900
0 Boise, Idaho 83702
mshobson(iYstoel.com
Attorneys for ~west Corporation
Robert M. Nielsen
ATTORNEY AT LAw
0 P.O. Box 706
0 Rupert, Idaho 83350
f6' Attorney for Project Mutual Telephone
Cooperative Association nc.
Charles H. Creason, Jr.
President Cst General Manager
PROJECT MUTUAL TELEPHONE Coop,
507 G Street
~ P.O. Box 366
Rupert, Idaho 83350
ccreason(iYpmt.coop
John Hammond, Deputy AG
ID PUBLIC UTILITIES COMMISSION
472 West Washington Street
0 P.O. Box 83720
~ Boise, Idaho 83720-0074
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