20030908Curry Direct for Clear Talk.pdf

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF
IAT COMMUNICATIONS, INc., d.
NTCH-IDAHO, INc. OR CLEAR TALK
FOR DESIGNATION AS AN ELIGIBLE
TELECOMMUNICATIONS CARRIER
IN THE MATTER OF THE APPLICATION
OFNPCR, INc. d.a. NEXTEL PARTNERS
SEEKING DESIGNATION AS AN
ELIGIBLE TELECOMMUNICATIONS
CARRIER
Case No. GNR-O3-
Case No. GNR-O3-
DIRECT TESTIMONY OF LARRY CURRY ON BEHALF OF
!AT COMMUNICATIONS, INC. DBA CLEAR TALK
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TABLE OF CONTENTS
IDENTIFICATION OF WITNESS, FACTUAL BACKGROUND, AND
PURPOSE 0 F TESTIMONY ............................................................................................ 3
ESCRIPTI ON OF CLEAR TALK'S SERVICE ...........................................................
ADVERTISING OF CLEAR TALK'S SERVICE .........................................................
SERVICE AREAS IN WHICH CLEAR TALK SEEKS ETC
DESIGNATION, .................................................................................................................
PUB LI C INTEREST............... ............................................................................................ 13
AFFIDAVIT (1 PAGE)
EXHIBIT A (1 PAGE)
Curry --
Clear Talk
DIRECT TESTIMONY OF LARRY CURRY
IDENTIFICATION OF WITNESS, FACTUAL BACKGROUND, AND
PURPOSE OF TESTIMONY
PLEASE STATE YOUR NAME, PLACE OF EMPLOYMENT, AND
BUSINESS ADDRESS.
My name is Larry Curry. I am a director ofIAT Communications, Inc., a
Delaware corporation, and the president and general manager ofNTCH-
Idaho, Inc., an Idaho corporation, collectively doing business as Clear Talk
Clear Talk"). Clear Talk's offices are located at 233 N. Main Street
Pocatello, Idaho, 83204. I live and work in Pocatello, Idaho.
WHAT ARE YOUR RESONSIBILITIES WITHIN CLEAR TALK?
My primary responsibilities are to oversee Clear Talk's operations in Idaho. I
was responsible for the design and buildout of Clear Talk's wireless network
in Idaho. I have also supervised the design and buildout of wireless networks
in several other states. In my capacity as president and general manager of
NTCH-Idaho, I have substantial knowledge about the products and services
offered by Clear Talk, as well as Clear Talk's network and business
operations. I have substantial knowledge about the service offerings Clear
Talk offers in Idaho, including their features, pricing, and services.
PLEASE DESCRIBE YOUR WORK EXPERIENCE.
I have been employed by NTCH-Idaho, Inc. since 2000 when I was hired as
general manager. Prior to my present employment I was Pre-Development
Manager for NTCH, Inc. in Eureka, California. Prior to that, I was a
commercial construction project manager for an excavation company and a
construction superintendent for a construction company. I have also been
licensed in Oregon as a general contractor and was self-employed in that
capacity for eleven years.
DOES CLEAR TALK CURRENTLY PROVIDE
TELECOMMUNICA TIONS SERVICE IN IDAHO?
Clear Talk currently provides mobile wireless service (also known as
Commercial Mobile Radio Service
" "
CMRS
" "
Personal Communication
Services" or "PCS") in Idaho, as shown on the maps submitted with its
Petition for ETC Designation (the "Application
TURNING TO THE MATTER OF UNIVERSAL SERVICE, DOES
CLEAR TALK CURRENTLY CONTRIBUTE TO THE FUNDING
FOR UNIVERSAL SERVICE?
Yes. Clear Talk submits quarterly reports to the Universal Service
Administration Company. Clear Talk also contributes to the Idaho
Telecommunications Service Assistance Program ("ITSAP") on a quarterly
basis.
IS THE COMPANY PRESENTLY ABLE TO DRAW FROM THE
FEDERAL UNIVERSAL SERVICE FUND FOR THE PROVISION
OF THE SUPPORTED SERVICES IN IDAHO?
No. Until Clear Talk is designated as an ETC in the requested service areas
within Clear Talk's FCC-licensed boundaries, Clear Talk is not able to draw
from the federal universal service fund for those areas. Without access to
universal service funding, a competitive carrier like Clear Talk can be limited
in its ability to provide a competitive telecommunications service to
consumers, especially in high-cost areas such as those served by rural
telephone companies in Idaho.
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Clear Talk
DID CLEAR TALK FILE AN APPLICATION FOR DESIGNATION
AS AN ETC IN THE STATE OF IDAHO?
Yes. Clear Talk's Application in this proceeding was filed with the Idaho
Public Utilities Commission on February 3 , 2003.
HAS CLEAR TALK PREVIOUSLY BEEN DESIGNATED AS AN ETC
IN IDAHO?
This Application is Clear Talk's first application for ETC designation in
Idaho. In connection with this Application, Clear Talk has already been
designated as an ETC in certain exchange areas in Idaho.
WHAT IS THE PURPOSE OF YOUR TESTIMONY?
The purpose of my testimony is to describe how Clear Talk provides the
supported services in Idaho, to identify Clear Talk's plans for providing
universal service offerings within the state of Idaho in compliance with the
statutory ETC criteria, and to show how the designation of Clear Talk as an
ETC in the proposed exchange areas and/or wirecenters is in the public
interest.
WHY IS CLEAR TALK SEEKING DESIGNATION AS AN ETC?
Clear Talk is hot eligible for universal service support unless and until it is
designated as an ETC by the Commission. Clear Talk wants to continue to
expand and enhance its service in Idaho and to try to bring high-quality
telecommunications services atthe lowest possible prices to Idaho
consumers.
IS IT CLEAR TALK'S INTENT TO OBTAIN UNIVERSAL SERVICE
SUPPORT FOR THE PROVISION OF TELECOMMUNICATIONS
SERVICES TO THE PUBLIC?
I Idaho Public Utilities Commission, Order No. 29261, dated June 10 2003 , Docket No. GNR-
03-
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Clear Talk
Yes.
II.DESCRIPTION OF CLEAR TALK'S SERVICE
IN WHAT AREAS IS CLEAR TALK SEEKING DESIGNATION AS
AN ETC?
Clear Talk is seeking designation as an ETC in certain exchange areas and/or
wirecenters within the FCC-defined Basic Trading Areas Nos. 451 (Twin
Falls), 202 (Idaho Falls), and 353 (pocatello), which cover a substantial
portion of southeast Idaho and for which Clear Talk has been granted a
license in Idaho.. A list of Clear Talk's proposed designated service areas is
attached as Exhibit A to this testimony.
UNDER THE TELECOMMUNICATIONS ACT OF 1996, WHAT ARE
THE PREREQUISITES FOR DESIGNATION AS AN ETC?
I am informed that a telecommunications carrier, including wireless carriers
such as Clear Talk, are eligible for ETC designation if the carrier is: (1) is a
cOlmnon carrier; (2) will offer the supported services; (3) will advertise the
availability of the supported services; and (4) will make the supported
services available throughout a designated service area.
WHAT ARE THE SUPPORTED SERVICES THAT MUST BE .
OFFERED BY CLEAR TALK IN CONNECTION WITH ETC
DESIGNATION?
I am informed that Clear Talk must offer the following services as a condition
of any ETC designation:
1. voice-grade access to the public switched network;
2. local usage;
3. dual tone multi-frequency signaling or its functional equivalent;
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Clear Talk
4. single-party service or its functional equivalent;
5. access to emergency services;
6. access to operator services;
7. access to inter exchange services;
8. access to directory assistance; and
9. toll limitation for qualifying low-income consumers.
47 C.R. ~ 54.101(a).
COULD YOU EXPLAIN EACH OF THE SUPPORTED SERVICES
AND HOW CLEAR TALK PROVIDES THESE SERVICES?
Yes. Clear Talk currently offers and is able to provide its Idaho customers
those services and functionalities within its designated service areas.
Voice-grade access to the public switched telephone network.Clear
Talk meets this requirement of providing voice-grade access to the public
switched network. Through its interconnection arrangement Qwest, all
customers of Clear Talk are able to make and receive calls on the public
switched network within the specified bandwidth.
Local usage.Clear Talk will comply with any and all minimum local
usage requirements adopted by the FCC, and any applicable minimum local
usage requirements adopted by the Commission.
Dual-tone. multi-frequency ("DTMF") signaling. or its functional
equivalent.Clear Talk currently uses out-of-band digital signaling and in-
band multi-frequency ("MF") signaling that is functionally equivalent to
DTMF signaling. Clear Talk therefore meets the requirement to provide
DTMF signaling or its functional equivalent.
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Clear Talk
Single-party service or its functional equivalent.Single-party
service" means that only one party will be served by a subscriber loop or
access line, in contrast to a multi-party line. Clear Talk meets this
requirement by providing a dedicated message path for the length of all
customer calls.
Access to emergency services. Clear Talk presently provides E911
service to its subscribers and is currently working with PSAPs within its
designated universal service areas to make Phase 11 E911 service available.
Access to operator services.Clear Talk meets this requirement by
providing all of its customers with access to operator services provided by
either Clear Talk or other entities (e.g. LECs, IXCs, etc.
Access to interexchange service. Clear Talk presently meets this
requirement by providing all of its customers with the ability to make and
receive interexchange or toll calls through direct interconnection
arrangements Clear Talk has with several interexchange carriers (IXCs).
Additionally, customers are able to reach their IXC of choice by dialing the
appropriate access code.
Access to directory assistance. Clear Talk meets this requirement by
providing all of its customers with access to directory assistance by dialing
411" or "555-1212.
Toll limitation for qualifying low-income consumers.Upon
designation an ETC, Clear Talk will participate in Lifeline and other lower-
income programs, as required, and will provide toll blocking in satisfaction of
federal requirements. Clear Talk currently provides toll-blocking services, at
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Clear Talk
no charge, for international calls and customer selected toll calls. Clear Talk
can and will utilize the same toll blocking technology to provide this service
to its Lifeline and other lower-income customers, at no charge, as part of its
universal service offerings once designated as an ETc.
HOW WILL CLEAR TALK COMBINE THE SUPPORTED
SERVICES INTO A UNIVERSAL SERVICE OFFERING?
Clear Talk will deliver the supported services to consumers using the same
antennae, cell sites, towers, trunk lines, mobile switching center, and
interconnection facilities used for its existing PCS service. Clear Talk also
regularly deploys additional cell sites, as necessary, to maximize signal
coverage and service availability. In order to meet service requests
throughout of the entirety of designated exchange areas and/or wirecenters
Clear Talk may contract, as needed, to use the facilities of other facilities-
based carriers, as allowed by federal law.
Clear Talk intends to offer the supported services to universal service
customers in a basic universal service offering, using Clear Talk's PCS
network in conjunction with fixed wireless local loop equipment. Clear
Talk's BUS can ,be offered and provided without any changes to Clear Talk'
existing network.
WHAT IS WIRELESS LOCAL LOOP SERVICE?
A wireless local loop involves the use of a wireless access unit at a
customer s location to transmit the signal to the nearest cell site. The wireless
access unit is a piece of equipment that serves as the interface to the Clear
Talk network over the CMRS spectrum in the same manner as a conventional
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Clear Talk
PCS handset. A wireless access unit is typically a desk unit that is more
powerful than a conventional handset and simulates dial-tone.
HOW IS WIRELESS LOCAL LOOP SERVICE DIFFERENT FROM
CONVENTIONAL PCS SERVICE?
The network cannot distinguish wireless local loop equipment and mobile
handset equipment. The only difference is in the capabilities of the
customer s transmitter/receiver, and the wireless local loop provides stronger
transmitting/receiving capabilities than a mobile handset. However, although
wireless local loop technology is identical to conventional PCS service, it is
generally marketed more as a residence-based service that competes with
landline service offerings. Clear Talk's advertising materials and customer
service agreement would reflect this difference accordingly.
HOW DOES WIRELESS LOCAL LOOP SERVICE GIVE CLEAR
TALK AN ADVANTAGE AS IT PROVIDES UNIVERSAL
SERVICES?
There are spots within Clear Talk's coverage area where a conventional PCS
customer may not have strong signal coverage. In those areas, the wireless
local loop technology offering might be more appropriate for the customer
because the wireless access unit is typically more powerful than a
conventional handset and reception is greatly improved. This offering gives
Clear Talk another option as it seeks to meet requests for universal services
within its designated ETC service areas. At the same time, Clear Talk is able
to provide all of its customers with a larger "local" calling area than a
landline carrier, so that a Clear Talk universal service customer will likely
incur fewer toll calls.
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Clear Talk
WHAT OTHER MEANS CAN CLEAR TALK EMPLOY TO MEET
REQUESTS FOR SERVICE?
I am informed that the FCC has determined that an ETC must be given an
opportunity to expand its network, over time, to meet reasonable requests for
service. Clear Talk accepts that obligation, and fully expects that as its
network expands over time, it will be able to meet all such requests. If Clear
Talk receives a request for service in an area outside its existing PCS signal
coverage, there are numerous ways for Clear Talk to provide service. A
technician can install a high-gain antenna at the location, or the power at an
existing cell site can be turned up or redirected, or antennae can be adjusted
(e., azimuth and downtilt), or microwave equipment can be installed, or
new cell sites can be built, or Clear Talk can, if necessary, contract for the use
of another carrier s facilities. Through one or more of these options, Clear
Talk will be able to meet requests for service throughout the entirety of its
designated ETC service areas, either using its own facilities or through
combination of its own facilities and resale of another carrier s facilities.
III.ADVERTISING OF CLEAR TALK SERVICE
WILL CLEAR TALK ADVERTISE THE AVAILABILITY OF THE
SUPPORTED SERVICES?
Clear Talk currently advertises its wireless services through several different
media, including newspaper, television, radio, and billboard advertising.
Clear Talk also maintains various retail store locations throughout its
authorized service areas, which provide an additional source of advertising.
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Clear Talk
Clear Talk's current advertising includes publications targeted to the general
residential market. Clear Talk will use the same media of general distribution
that it currently employs to advertise its universal service offerings
throughout the service areas designated by the Commission. Clear Talk will
also comply with all form and content requirements that apply to ETCs.
IV.SERVICE AREAS IN WHICH CLEAR TALK SEEKS ETC
DESIGNATION
FOR WHAT SERVICE AREAS IS CLEAR TALK SEEKING ETC
DESIGNA TION?
At this time, Clear Talk seeks designation as an ETC in certain
exchange areas and/or wirecenters (as set forth in Exhibit A) that fall within
the boundaries of Clear Talk's FCC licenses. Exhibit A is a listing of the
specific exchange areas and/or wirecenters in which Clear Talk is seeking
ETC designation. Clear Talk is committed to making the supported services
available to consumers within its designated service areas, using its own
facilities and/or a combination of its own facilities and those of other
facilities-based carriers, as necessary.
IS CLEAR TALK SEEKING ETC DESIGNATION IN EACH
AREA CONTAINED WITHIN ITS AUTHORIZED PCS LICENSED
AREA?
Yes. Clear Talk has reviewed and analyzed its PCS license areas and its
existing signal coverage. Using publicly available mapping software and
Clear Talk's own radio frequency signal propagation information (i.
coverage), Clear Talk determined the extent to which each exchange and/or
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Clear Talk
wire center within its PCS-licensed area is currently covered, and where
coverage could be extended if necessary to respond to a request for service.
WHERE CLEAR TALK'S FCC-LICENSED BOUNDARIES DO NOT
APPEAR TO EXTEND OVER AN ENTIRE WIRECENTER, DOES
THE COMPANY REQUEST DESIGNATION AS AN ETC IN ONLY
PART OF THE WIRECENTER?
Yes. Clear Talk requests that the Commission designate Clear Talk as an
ETC throughout the entirety of Clear Talk's FCC-licensed boundaries in
Idaho, including any partial wirecenters, insofar as Clear Talk is committed to
responding to service requests throughout any service areas in which Clear
Talk obtains ETC designation.
PUBLIC INTEREST
IS THE DESIGNATION OF CLEAR TALK AS AN ADDITIONAL
ETC IN THE PUBLIC INTEREST?
Yes. Designating Clear Talk as an ETC in Idaho will bring competition to
rural, high-cost areas, and competition is in the pubic interest. One of the
underlying purposes of the Telecommunications regulations is to promote
competition and reduce regulation in order to secure lower prices and higher
quality services for telecommunications consumers and encourage the rapid
deployment of new telecommunications technologies." I am informed that the
applicable statutory public interest standards emphasize competition and
consumer benefits-- not incumbent protection.
Failure to designate Clear Talk as an ETC would deprive consumers
of the benefits of competition, including increased choices, higher quality
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Clear Talk
service, and lower rates. Rural consumers should be allowed to choose
services from a carrier that best meets the consumer s communications needs.
Absent a choice of service providers, the consumer is unable to make a
selection based upon service quality, service availability, or service rates.
The incumbent provider has little or no incentive to introduce new, innovative
or advanced service offerings. Competition promises to bring new and
beneficial services to rural consumers in Idaho, at competitive prices.
Clear Talk will offer universal services to rural consumers, as well as
services not currently provided by the landline LEe. For example, Clear Talk
may provide an expanded local calling area, which will benefit rural
consumers who currently pay toll charges to reach family, friends
government offices, health care providers, and businesses located outside of a
landline s restricted local calling area.
In addition to increased choices, Idaho rural consumers may also
experience lower rates. When compared side-by-side with other ETCs
universal offerings, the rates for Clear Talk's BUS will be comparable to, if
not less than, the local service rates charged by the incumbent LEC, and Clear
Talk will provide equivalent - or better - services and features. Otherwise
Clear Talk will not likely attract any customers. Likewise, Clear Talk'
service quality will need to meet or exceed the quality of services provided by
the incumbent LEC in order for Clear Talk to obtain - and retain --
customers. Designating Clear Talk as an ETC will also further the
deployment of Clear Talk's facilities-based network in Idaho.
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Clear Talk
If the Commission establishes a competitive universal service system
rural consumers will be better able to keep pace with, and quite possibly
outpace, urban consumers in terms of the availability - and price --
telecommunications services. Clear Talk stands ready, willing and able to
bring competition to consumers in Idaho, which will result in better consumer
pricing, better service quality, immediate service availability, and better
customer service. The increased choices for rural consumers will advance
universal service.
DOES THIS CONCLUDE YOUR TESTIMONY?
Yes.
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Clear Talk
, ~Er-~l-l~~J (T~E)H :lJ LlEAR TAlK WIRElE~~(fAX) l~~ lJJ ol~~r. ~~U~~l
BEFORE THE IDAHO PUBLIC rn"lUTIES COMMISSION
IN THE MATTER OF THE PETITION' 0
IAT COMMUNICATIONS, INC., d.
NTCI-I-IDAHO, INC. OR CLEAR TALK
FORDESIGNATlON AS ANELI(JlBLE
TELECOMMUNICA nONS CARRIER
IN TIlE MATTER OF 11.IE APPLICATION
OF NPCR. INC. d.a. NEXTEL PARTNERS
SEEKING DESIGNA nON AS AN
ELIGIBLE TELECOMMUNICA nONS
CARRIER
CaseiNo. GNR-T-Q3..08
Case No. GNR-O3-
AFFIDA VI1' OF LARRY CURRY
I HAVE READ the foregoing DIRECT TESTIMONY OF LARRY CURRY ON
BEHALF OF IA T COMMUNlCATIONS; INC. DBA CLEAR TALK and T :,wcar under
penalty of perjury 1illder the taws of1he Stare of Idaho and the United States of Americathat the statements contained therein are true and correct to the best afmy knowledgeillfonnation and bclie1:
~-'-'-----.-. - -
CLEAR TALK COVERAGE AREA -- Idaho Exchanges and Wire Centers
Idaho PUC Docket No. GNR-T -03-8
EXHIBIT 1 TO CLEAR TALK DIRECT TESTIMONY
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Page 1 of 1
Submitted by IAT Communications, Inc.
9/2/2003
CERTIFICA TE OF SERVICE
I HEREBY CERTIFY that on this 2nd day of September, 2003, I caused a true and
correct copy of the foregoing DIRECT TESTIMONY OF LARRY CURRY ON BEHALF
OF CLEAR TALK to be served by the method indicated below, and addressed to the following:
Jean Jewell
Idaho Public Utilities Commission
472 West Washington Street
Post Office Box 83720
Boise, Idaho 83720-0074
(X) US. Mail, Postage Prepaid
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( ) Electronic Mail
Dean J. Miller, Esq.
420 West Bannock
Post Office Box 2564-83701
Boise, Idaho 83702
[phone] (Fax)
j oe(0mcdevitt - mill er. com
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Philip R. Schenkenberg, Esq.
2200 First National Bank Building
332 Minnesota Street
St. Paul, Minnesota 55101
pschenkenberg(0briggs. com
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Conley Ward
Givens Pursley LLP
277 North 6th Street, Suite 200
Post Office Box 2720
Boise, Idaho 83701
[phone] (Fax)
ill lilt Q.:~~ W jfggiy ~!1~ p-.l.!r.~l ~Y-,.~ gJTI,
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Lance A. Tade, Manager
State Government Affairs
Citizens Telecommunications Company of
Idaho
4 Triad Center, Suite 200
Salt Lake City, UT 84180
tld~~cZn&91n
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CLEAR TALK
CERTIFICATE OF SERVICE - 1
Charles H. Creason, Jr.
President and General Manager
Project Mutual Telephone Cooperative
Association, Inc.
507 G Street
Post Office Box 366
Rupert, Idaho 83350
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John Hammond, Deputy AG
Idaho Public Utilities Commission
Washington Street
Boise, Idaho 83720-0074
[phone] (Fax)
ihammon~,puc.state.id.
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Clay Sturgis, Senior Manager
MOSS ADAMS LLP
601 Riverside, Suite 1800
Spokane, W A 99201-0063
clays~mossadams. com
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Morgan W. Richards, Esq.
Moffatt, Thomas, Barrett, Rock & Fields
101 S. Capitol Blvd, loth Floor
P. O. Box 829
Boise, Idaho 83701-0829
[phone] (Fax)
mwr~moffatt. com
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Mary S. Hobson
Stoel Rives LLP
101 S. Capitol Blvd, Suite 1900
Boise, Idaho 83702-5958
[phone] (Fax)
mshobson~stoel.com
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CLEAR TALK
CERTIFICATE OF SERVICE - 2
Robert M. Nielsen
548 E Street
Post Office Box 706
Rupert, Idaho 83350
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Signed:
Sean P. Farrell
Clear Talk
CLEAR TALK
CERTIFICATE OF SERVICE - 3