HomeMy WebLinkAbout20100608Application.pdfRECEIVED~.QJLis~pu
Molly O'Leary
2tUO JU -8 AM 1:- 59
iDAHO PU BLl c, _ ,
UTILITIES COMMISSION
ATTORNEYS AT LAW
Tel: 208-938-7900 Fax: 208-938-7904
mol i y~ rich ard. 0 n a ndol eary. com
P.O. Box 7218 Boi.e. 1D 83707 - 515 N. 27th St. Boi.e. ID 83702
7 june 2010
Ms. jean jewell
Commission Secretary
Idaho Public Utilties Commission
POBox 83720
Boise ID 83720-0074
&OL -(-to -al Hand Delivered
Dear Ms. jewell:
I am enclosing an original and seven (7 copies of GOLD STAR COMMUNICATIONS, LLC's
APPLICATION FOR DESIGNATION AS AN ELIGIBLE TELECOMMUNICATIONS CARRIER.
Also enclosed is a copy to be date stamped and returned for our fies.
Please note the enclosed Application contains confidential trade secret information that is exempt
from public disclosure pursuant to Section 9-340D(1), Idaho Code. Pursuant to Rule 67 of the
Rules of Procedure of the Idaho Public Utilties Commission, the enclosed trade secret
information has been submitted on yellow paper and has been separated from the non-
confidential portion of the Application.
PLLC
MOLLY O'LEARY (ISB # 4996)
Richardson & O'Leary PLLC
515 North 27th Street
P.O. Box 7218
Boise, Idaho 83707
Telephone: 208.938.7900
Fax: 208.938.7904
E-mail: molly(?richardsonandoleary.com
RECEIVED
20ID JUN -8 AI1 7: 59
IDAHO PUB! ,..
UTIUTiÉS COMlflšSION
Attorneys for Gold Star Communications, LLC
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF)
GOLD STAR COMMUNICATIONS, LLC FOR) CASE NO. GOL-T-10-01
DESIGNATION AS AN ELIGIBLE )
TELECOMMUNICATIONS CARRIER )PURSUANT TO THE )
TELECOMMUNICATIONS ACT OF 1996 )
)
APPLICATION OF GOLD STAR COMMUNICATIONS, LLC FOR
DESIGNATION AS AN ELIGIBLE TELECOMMUNICATIONS CARRIER
Gold Star Communications, LLC ("Gold Star"), by and through its undersigned
attorney, hereby submits this Application for Designation as an Eligible Telecommunications
Carrier e'ETC") pursuant to Sections 214(e)(1) - (2) of the Telecommunications Act of 1934,
as amended ('he Act'), 476 U.S.c. §214(e)(1)-(2), and Section 54.201 of the Federal
Communications Commission's ("FCC") rules, 47 C.F.R. § 54.201, and this Commission's ETC
Designation Requirements ("IPUC ETC Requirements'1.1 Gold Star requests that it be
i See In the Matter of the Application of WWC Holding Co.; Inc dba CellularOne Seeking
Designation as an Eligible Telecommunications Carrier That May Receive Federal Universal
Service Support Order No. 29841, Appendix pp. 1-3 (lPUC Case No. WST-T-05-1, served
August 4, 2005) (hereinafter, ill PUC ETC Requirements Order").
GOLD STAR COMMUNICATIONS, LLC ETC APPLICATION - 1
designated as eligible to receive all available support from the federal Universal Service Fund
("USF'1 including, but not limited to, support for rural, insular, high cost areas and low
income customers in geographic areas specified in this Application, and that it be approved
to participate in the Lifeline program. In support of this Application, Gold Star provides the
following information:
i. APPLICANT
Gold Star is a Commercial Mobile Radio Services e'CMRS") carrier providing "mobile
service" as defined in 47 U.s'c. § 153(27) doing business as "Silver Star Wireless". Gold Star
provides such CMRS and "mobile service" on a pre-paid and post-paid basis. Gold Star's pre-
paid customers purchase a specific amount of local callng minutes in advance and do not
sign a contract. In certain plans, pre-paid customers also have the abilty to purchase specific
amounts of long distance and roaming minutes. Gold Star's post-paid customers sign a
contract for a specific amount of monthly user-minutes and are biled for their usage.
Gold Star provides interstate telecommunications services as defined in 47 U.s.c. §
153(22) and 47 C.F.R. § 54.706. Through its cellular authorizations, Gold Star is licensed to
serve the following Basic Trading Area(s) ("BTAs") in Idaho: BTA 202 (Idaho Falls)¡ BTA 353
(Pocatello). In addition, Gold Star has entered into a lease agreement with Syringa Wireless,
LLC for use of its wireless spectrum (BT A 353) in the Wayan area and that of the Smoky
Canyon Mine owned by the J.R. Simplot Company. Pursuant to these authorizations, Gold
Star is authorized to provide wireless service in the following Idaho counties: Bonnevile,
Teton, Madison, Bingham, Butte, Custer, Lemhi, Jefferson, and Clark. Nevertheless, Gold
Star is currently seeking ETC designation only in Teton County, eastern and northern
Caribou County, and eastern Bonnevile County.2
2 CONFIDENTIAL Exhibit A, attched, is a map showing Gold Star's current wireless
coverage superimposed over a map of the counties for which it seeks ETC designation.
GOLD STAR COMMUNICATIONS, LLC ETCAPPLICATION - 2
II. ELIGIBILITY AND IDENTIFICATION OF THE SERVICE AREA
Under Sections 214(e) and 254 of the Act, the Idaho Public Utilties Commission
npUC" or "Commission'1 is authorized to designate Gold Star as an ETC. Section 214(e) of
the Act requires state commissions to designate as an ETC, throughout the service area for
which ETC status is sought, any common carrier that: (i) offers services that are supported
by federal universal support mechanisms¡ and (ii) advertises the availabilty of such services.
In its First Report and Order implementing Sections 214(e) and 254 of the Act, the FCC
designated the specific features a carrier must provide or agree to provide to be designated
as an ETC.3 The FCC also recognized that wireless telecommunications providers are eligible
to be designated as ETCs.4
Gold Star is a telecommunications carrier as defined in 47 U.s.c. § 153(44) and 47
C.F.R. § 51.5(a), and is a telecommunications carrier for the purposes of Part 54 of the FCC's
rules. 47 U.S.c. § 54.1 et seq. Gold Star, therefore, is considered a common carrier under
the Act.
Section 214(e)(2) of the Act provides that ETC designations shall be made for a
"service area" designated by the state commission. Section 214(e)(5) of the Act provides that
the "service area" shall be a geographic area established by the state commission. In areas
served by a rural telephone company, the FCC's rules generally define a competitive ETC's
service area to mean the local exchange carrier's ("LEC") study area.s Attached hereto as
Exhibit B is a map depicting Gold Star's proposed ETC service area in Idaho superimposed
over the rurallLEC exchanges fallng within Gold Star's proposed ETC service area.
Attched as Exhibit C-1 is a list of rurallLEC wire centers that fall within Gold Star's BTA
3 Federal-State Joint Board on Universal Service; First Report and Order; 12 FCC Rcd 8776,
8909-25 (1997) ("First Report and Order").
4 Id at 8858-59.
S See; 47 C.F.R. §S4.207(b).
GOLD STAR COMMUNICATIONS, LLC ETC APPLICATION - 3
licensed service areas for which it is seeking ETC designation.6 Also attched is
CONFIDENTIAL Exhibit C-2, which shows the population densities of the relevant ILEC wire
centers, including the specific wire center areas for which Gold Star seeks ETC designation.
III. LEGAL STANDARD FOR GRANTING ETC STATUS
Gold Star satisfies each of the statutory and regulatory prerequisites set forth in the
Act, the FCC Rules7 and this Commission's ETC Requirements.8 On .March 17, 2005, the
FCC released its FCC ETC Requirements Order establishing additional requirements for
carriers seeking ETC designation before the FCC. These additional requirements, however,
are not binding on state commissions. This Commission subsequently considered whether to
adopt all or some portion of the rules promulgated by the FCC and, as previously noted,
issued a set of ETC designation requirements in Commission Order No. 29841.
Gold Star may be designated as an ETC in ruralILEC areas upon a finding that: (1) it
offers the supported universal services¡ (2) it advertises the availabilty of those services using
media of general distribution in its service area¡ and (3) such a designation would serve the
public interest,tO
To comply with the specific requirements set forth in the FCC ETC Requirements
Order and the IPUC ETC Requirements Order, Gold Star includes in this Application the
following:
6 Because some ILEC exchanges include more than one ILEC wire center, there is some
variation between the list of ILEC centers on Exhibit C-1 and the ILEC exchanges shown on
Exhibit B.
7 47 U.S.c. § 214(e)(1)-(2), and 47 C.F.R. § 54.201.
8 See IPUC Order No. 29841.
9 In the Matter of Federal-State Joint Board on Universal Service, Report and Order, 20 FCC
Rcd 6371 (2005) ("FCC ETC Requirements Order'1.
10 See, 47 C.F.R. § 54.207(c).
GOLD STAR COMMUNICATIONS, LLC ETC APPLICATION - 4
. Demonstration of its commitment and abilty to provide supported services, including
a two-year, wire center-specific network improvement plan, attched hereto as
CONFIDENTIAL Exhibit D¡
. Demonstration of its abilty to remain functional in emergency situations¡
. Its commitment to comply with all applicable service quality standards and consumer
protection rules, and an agreement to comply with Cellular Telecommunications and
Internet Association's Consumer Code for Wireless Service ("CTIA Code")¡ and
. A description of Gold Star's local rate plans and the local usage plans for the ILECs
A. UNIVERSAL SERVICES PROVIDED BY GOLD STAR
Gold Star wil offer the federally designated services listed at 47 C.F.R. § 54.1 01 (a).
The services which are supported by the federal USF program are: (1) voice grade access to
the public switched telephone network¡ (2) local usage¡ (3) dual tone multi-frequency
signaling or its functional equivalent¡ (4) single-part service or its functional equivalent¡ (5)
access to emergency services¡ (6) access to operator services¡ (7 access to interexchange
service¡ (8) access to directory assistance¡ and (9) toll limitation for qualifying low-income
consumers.11 Gold Star is a full-service wireless carrier that offers all of these services, as
described in detail below, throughout its licensed service area utilzing its own wireless
network infrastructure (antenna, cell-sites, towers, trunking, mobile switching, and
interconnection).
1. Voice Grade Access to the Public Switched Telephone Network.
As previously noted, FCC Rule Section 54.101(a)(t) requires voice-grade access to the
public switched telephone network. The FCC defines this as:
the abilty of a user of telecommunications services to transmit voice
communications, including signaling the network that the caller wishes to place
11 47.C.F.R. 54.101(a).
GOLD STAR COMMUNICATIONS, LLC ETC APPLICATION - 5
a call, and to receive voice communications, including receiving a signal
indicating there is an incoming calL. For the purposes of this part, bandwidth
for voice grade access should be, at a minimum, 300 to 3,000 Hertz.12
Gold Star provides voice grade access to the public switched telephone network through
interconnection arrangements with local telephone companies. Gold Star offers its
subscribers this service at a bandwidth between no less than 300 to 3,000 Hz, thereby
providing voice grade access consistent with the FCC's definition.
2. Local Usage.
Gold Star rate plans provide local usage consistent with Section 54.101(a)(2) of the
FCC's Rules. In the First Report and Order, the FCC deferred a determination on the
amount of local usage that a carrier would be required to provideP Any minimum local
usage requirement established by the FCC wil be applicable to all designated ETCs. Gold
Star meets the local usage requirements by including local usage in its rate plans and Gold
Star wil comply with any and all minimum local usage requirements adopted by the FCC.
Consistent with the IPUC ETC Requirements Order; Appendix p.3, Gold Star submits
its rate plan brochures as Exhibit E. The relevant ILEC local usage rate plans are on file with
the Commission at: http://ww.puc.state.id.us/tarriff/approved/title61/approved.htm. A
comparison of Gold Star's local callng rates with other carriers in Gold Star's service area is
attched as Exhibit F. The Commission has expressly rejected the FCC's requirement that
the applicant's usage plan be comparable to that of the ILEC, stating: "we find it is suffcient
for the ETC applicant to simply describe its local usage plans and those of the ILEC."t4 The
t2 47 C.F.R. § 54.101(a)(t).
13 Id at 8814
14 IPUC ETC Requirements Order; p.12¡ see also; In the Matter of the Petition of Inland
GOLD STAR COMMUNICATIONS, LLC ETC APPLICATION - 6
Commission aptly noted that the FCC's comparabilty analysis could potentially discourage
carriers from offering diverse services, and that, with competition, consumers should have
the option to obtain the type of service offering they would Iike.ls
One of the distinct advantages to the Gold Star rate plans is that Gold Star provides
signifcantly wide local callng areas. Whereas the relevant ILEC local callng areas are
primarily limited to their local exchange boundaries and extended service area boundaries,
Gold Star's local callng area for its basic "Valleys Plan" includes local callng areas in parts of
Utah, Eastern Oregon and North Western Colorado. See Exhibit G, attched hereto. In
addition, Gold Star offers additional"local" network coverage via switching partners Syringa
Wireless, LLC and RINA Switching.
Second, Gold Star provides unlimited, toll-free service for 911 emergency calls and for
611 customer care. Gold Star also provides toll-free 511 road reports to the Idaho
Department of Transporttion.
Finally, all of Gold Star's nationwide and eight-state callng plans priced at $49.95 per
month and higher include unlimited nationwide long distance at no additional charge,
unlimited night and weekend callng, and unlimited mobile-to-mobile callng.16
Cellular Telephone Company for Designation as an Eligible Telecommunications Carrier
Under 47 u.S.C §2/4(e)(2l Order No. 30212, p.11 (IPUC Case No. INC-T-06-:Q2, served Dec.
28,2006).
tS Id
t6 See Exhibit E (Gold Star's rate plan brochure).
GOLD STAR COMMUNICATIONS, LLC ETC APPLICATION - 7
3. Dual-Tone, Multi-Frequency Signaling or its Functional Equivalent.
Pursuant to Section 54.101(a)(3) of the FCC's Rules, an ETC must provide dual tone
multi-frequency ("DTMF") signaling to facilitate the transportation of signaling throughout
its network. Gold Star currently provides DTMF signaling consistent with the FCC's Rules.
4. Single-Party Service or its Functional Equivalent.
"Single-part service" means that only one part wil be served by a subscriber loop
or access line in contrast to a multi-party line.17 Gold Star provides single-party service, as
required by 47 C.F.R. §54.101(a)(4).
5. Access to Emergency Services and Abilty to Remain
Functional in Emergency Situations.
The abilty to reach a public emergency service provider by dialing 911 is a required
service in any universal service offering. Gold Star currently provides all of its customers
with access to emergency service by dialing 911 in satisfaction of this requirement. Phase i
E911, which includes the capabilty of providing both automatic numbering information
(" ANI") and automatic location information (" ALI"), is only required if a public emergency
service provider makes arrangements with the local provider for the delivery of such
information.18 In addition to providing Phase 0 E911, Gold Star provides Phase I and II
wireless E911 to Public Safety Answering Points e'PSAP") when they request this improved
service and are ready to receive the Phase I or II call information. To date, Gold Star has
deployed requests for E911 Phase II in Bonnevile County. Gold Star has not received
requests in any other counties in its current service area.
17 First Report and Order at 8810.
18 See Id; at 8815-17.
GOLD STAR COMMUNICATIONS, LLC ETC APPLICATION - 8
Phase I and II wireless E911 service provides valuable location-based information to the
PSAP which allows emergency personnel to determine the cell site serving the caller and the
geographic location of the phone placing the calL. Additional cell site coverage in rural areas
wil greatly improve access to wireless E911 services and greater accuracy of the location
based information received by the PSAP. Gold Star hopes to improve its cell site coverage
with the use of USF support. See, CONFIDENTIAL Exhibit D.
Consistent with the IPUC ETC Requirements. Order at Appendix p. 3, Gold Star also
has the abilty to remain functional in emergency situations. Gold Star has designed a fault-
tolerant network that employs the following features:
· Nortel MTX switch with fully redundant fault-tolerant processors
· 12 hours of back-up battery
· 250 KW generator with the fuel supply connected to the public natural gas
utilty
· Complete complement of spare circuit boards
· Self-Healing Alternate Route Protection Service for Fiber Facilties
interconnection
· Multiple alternate trunk routes for PSTN interconnection trunks
· Redundant Microwave radio links where used
· Automated 7x24 network monitoring cell sites
· Overlapping cell site coverage with retry for blocked calls
· Backhaul network engineered with surplus back-bone capacity
· Ready access to growth channel element module stock for all field technicians
GOLD STAR COMMUNICATIONS, LLC ETC APPLICATION - 9
· 8 hours battery back-up for all cell sites
· Compact generator system stored in Freedom, Wyoming
· Remote monitoring 7x24 of all sites
· Ongoing monitoring of all Network and Outage Resolution procedures
· A network operating center ("NOC"), in Roosevelt, Utah
· All switches and cell sites are remotely monitored 7x24, with critical and
major alarms escalated to the next level of management every 20 minutes
· Gold Star's 7x24 on-call staff is sent a text message or called immediately when
the monitoring system detects system problems
· The Gold Star's team consists of 6 people strategically located within West
Central Wyoming and Southeastern Idaho in the following locations: 3 in Star
Valley, 2 in Teton Valley, and 1 in Jackson, Wyoming
· Gold Star staff is well-trained and equipped to respond quickly in the event of
outages, alarms or emergencies
· Complete inventory of alternate-ccess equipment, including:
o All field staff are equipped with 4-wheel drive pickups¡ a Snow Cat is
stored at Freedom, Wyoming¡ snowmobiles are stored at Freedom,
Wyoming and Driggs, Idaho facilities (1 each)¡ and Polaris 4-wheeler
ATVs are located in Freedom, Wyoming and Driggs, Idaho (1 each)
o All field staff are trained in operation for all alternative site-ccess
equipment
· Tower crews are on standby for emergency tower and antenna repairs
· Technicians are equipped with a complete complement of spares for cell site
· Microwave and DACs equipment is available to insure quick recovery
In addition to the foregoing, Gold Star is currently upgrading its MTX Switch to a
version MTX 16.
GOLD STAR COMMUNICATIONS, LLC ETC APPLICATION - 10
Through all of these efforts, Gold Star has demonstrated that it not only provides
customers with needed emergency services, but that it can also remain fully functional in
emergencies.
6. Access to Operator Services.
Access to operator services is defined as any automatic or live assistance provided to
a consumer to arrange for the biling or completion, or both, of a telephone call.19 Gold
Star provides customer access to operator services. Customers can reach operator services
in the traditional manner by dialing "0", in compliance with Section 54.101(a)(6) of the
Federal Rules.
7. Access to Interexchange Service.
A universal service provider must offer consumers access to interexchange service to
make and receive toll or interexchange calls. Equal access, however, is not required. liThe
FCC do(es) not include equal access to interexchange service among the services supported
by universal services mechanisms."20 Gold Star presently meets this requirement by
providing all of its customers with the abilty to make and receive interexchange or toll calls
through direct interconnection arrangements Gold Star has with several interexchange
carriers ("IXCs'1.
8. Access to Directory Assistance.
The abilty to place a call to directory assistance is a required service offering.21
19 Id; at 8817-18
20 Id; at 8819.
21 Id; at 8821.
GOLD STAR COMMUNICATIONS, LLC ETC APPLICATION - 11
Subscribers to Gold Star's services are able to dial"411" to reach directory assistance from
their mobile phones.
9. Toll Limitation for Qualifying Low Income Consumers.
An ETC must offer either "toll control" or "toll blocking" services to qualifying
Lifeline customers at no charge. The FCC no longer requires an ETC to provide both
services as part of the toll limitation service required under 47 C.F.R. § 54.101(a)(9).22 In
particular, all ETCs must provide toll blocking which allows customers to block the
completion of outgoing toll calls.23 Gold Star currently has no Lifeline customers in Idaho
because only carriers designated as an ETC can participate in Lifeline. See 46 c.F.R. §§
54.400-415. Once designated as an ETC, Gold Star wil participate in Lifeline, as required.
Gold Star has the capabilty and if requested provides toll blocking.
In addition, once it receives its ETC designation, Gold Star wil promote its Lifeline
Services through traditional media avenues such as newsprint, radio advertisements and media
flyers. In addition to these methods, Gold Star wil develop an information sheet that
explains the program and directs interested parties to the proper agencies to assist with the
program qualification process.
In addition to unlimited long distance callng at no extra charge, Gold Star's
customers wil have the abilty to block roaming and international dialing, all of which wil
allow customers to avoid unexpected charges.
22 See Universal Service Fourth Order on Reconsideration in CC Docket No. 96-45; Report
and Order in CC Docket Nos. 96-45; 96-262; 94-1; 9/-2/3; 95-72; 13 FCC Rcd 5318 (1997).
23 First Report and Order; at 8821-22.
GOLD STAR COMMUNICATIONS, LLC ETC APPLICATION - 12
B. ADVERTISING AVAILABILITY OF UNIVERSAL SERVICE
Pursuant to Section 54.201 of the FCC's rules, 47 C.F.R. Section 54.201, Gold Star
plans to advertise the availabilty of each of the supported services detailed above,
throughout its licensed service area, by media of general distribution. The methods of
advertising utilzed may include newspaper, magazine, radio, direct mailngs, public exhibits
and displays, bil inserts, and telephone directory advertising. Print media of general
distribution in Gold Star's service area include: The Post-Register in Idaho Falls, Teton Valley
News in Driggs, and the Caribou Sun which covers the Wayan area.
C. COMMITMENT TO CONSUMER PROTECTION
Consistent with the IPUC ETC Requirements Order at Appendix A, p.3, Gold Star
wil comply with all applicable service. quality standards and consumer protection rules, and
wil abide by the consumer protection standards established by the CTIA Consumer Code.24
D. TRIBAL NOTIFICATION
The IPUC ETC Requirements order at Appendix A p. 2, requires an ETC applicant
seeking ETC designation for any part of tribal lands to provide a copy of its application to
the affected tribal government or tribal regulatory authority, as applicable, at the time it fies
its application with Commission. There are no tribal lands in Gold Star's proposed ETC
service area.
IV. GRANT OF THIS PETITION SERVES THE PUBLIC INTEREST
Gold Star's petition meets the stringent public interest standards established by the
FCC. In its ETC Order, the FCC clarified its public analysis of ETC applications and
24 See Exhibit H, attched.
GOLD STAR COMMUNICATIONS, LLC ETC APPLICATION - 13
suggested that states follow suit.25 Pursuant to Section 214 of the Act, the FCC and states
must determine that an ETC designation is consistent with the public interest, convenience
and necessity.26 The FCC and states must also consider whether an ETC designation serves
the public interest consistent with Section 254 of the Act.2 Further, the FCC has noted
that it wil analyze the public interest benefits of an ETC applicant in a manner that is
consistent with the purposes of the Act, including the fundamental goals of preserving and
advancing universal service, ensuring the availabilty of quality telecommunications services at
just, reasonable, and affordable rates, and promoting the deployment of advanced
telecommunications and information services to all regions of the nation, including rural and
high-cost areas.28 Specifically, the FCC considers three specific items when analyzing the
public interest benefits of an ETC application: (1) the unique advantages and disadvantages of
the competitor's service offering through a cost-benefit analysis¡ (2) the potential for "cream
skimming"¡ and (3) the potential impact on the federal universal service fund (USF).29
A. COST-BENEFIT ANALYSIS
In evaluating ETC applications, the FCC and states consider the benefits of increased
consumer choice, and the unique advantages and disadvantages of the competitor's service
offerings. Gold Star's universal service offering wil provide consumers in rural eastern Idaho
25 In re Federal-State Joint Board on Universal Service, CC Docket No. 96-45, Report and
Order, FCC 05-46 (March 17, 2005) ("ETC Ordel). The Idaho Public Utilties Commission
has outlined its ETC procedures in its IPUC ETC Requirements Order.
2647 U.s'c. § 214(e)(2).
2747 U.S.c. § 254(b)(7).
28 ETC Order'r 40.
29 Id ,r 41.
GOLD STAR COMMUNICATIONS, LLC ETC APPLICATION - 14
with the benefits of increased competitive choice and quality service. Gold Star's universal
service offering wil speed the delivery of advanced wireless services to citizens in these
remote communities, including high-speed data transmission capabilties. Gold Stats
universal service offering wil not only increase competition in the area, but wil also provide
greater consumer choice. Gold Star wil provide consumers in the Palisades Lake area, as well
as the communities of Irwin in eastern Bonnevile County and Clementsvile in northern
+9Teton County with improved cell phone coverage that is equal to or better than other
providers in the area?O Without Gold Star, consumers in BEGIN REDACTED INFORM-
ATION END OF REDACTED INFORMATION would have to rely solely
on traditional wireline services.
As a locally based company, Gold Star is focused on the specific needs of its rural
customers, who are its one and only priority. In addition, Gold Star is the only wireless
carrier who is able to port landline numbers to its wireless customers' cell phones.
Further, unlike traditional wireline services, Gold Star's mobile service affords
customers increased flexibilty, public safety, and service options. The FCC has noted that
mobilty of telecommunications assists consumers in rural areas who must drive significant
distances to their jobs, schools, and critical community locations.3! By offering the benefits
of mobilty, Gold Star's universal service offering wil provide unique and essential services to
consumers in rural southeastern Idaho.
As an ETC, Gold Star wil also offer a basic universal service package to subscribers
30 See Exhibit I, attched ("A look at cell phone coverage in Teton Valleý', Teton Valley
News, August 27, 2009).
3t Virginia Cellular Order! 29.
GOLD STAR COMMUNICATIONS, LLC ETC APPLICATION - 15
who are eligible for Lifeline support. As stated earlier, Gold Star wil offer the "core" or
designated services that are supported by federal universal service support mechanisms.32 In
addition to the core services, designating Gold Star as an ETC wil allow customers in rural
southeastern Idaho to choose service based on pricing, service quality, customer service, and
service availabilty. Gold Star's universal service offering provides several advantages
including mobilty, access to E911, voicemail, three-way callng, call waiting, call forwarding,
expanded callng scopes and several callng plans to allow customers to purchase plans that fit
their telecommunications needs. Gold Star expects that its service offering wil be
competitive with those of the incumbent wireline carriers within its service area.
Upon designation as an ETC, Gold Star wil use the high cost support it receives to
improve its infrastructure in BEGIN REDACTED INFORMATION
_ END OF REDACTED INFORMATION. Gold Star has evaluated its projected levels
of support, along with identifying areas where Gold Star's coverage needs improvement and
demand for services coincide.33 In fact, in 2005, Gold Star built out some previously
underserved or un-served areas in rural southeastern Idaho. This network construction
included areas such as Irwin, Palisades and around Palisades Lake. BEGIN REDACTED
INFORMATION
END OF REDACTED
INFORMATION. Designation as an ETC and high cost support wil allow Gold Star to
32 See 47 U.s.c. § 254(c)¡ 47 C.F.R. § 54.101.
33 See Gold Star's Two-Year Network Improvement Plan (CONFIDENTIAL Exhibit D).
GOLD STAR COMMUNICATIONS, LLC ETC APPLICATION - 16
expand upon its substantial build-out and coverage plans.
With the receipt of high cost support, Gold Star BEGIN REDAGED INFORM-
ATION
END OF REDAGED
INFORMATION. Gold Star's expanded presence wil give consumers a choice in accessing
vital telecommunications services. Gold Star's designation as an ETC is crucial to its plans to
provide service in the currently unserved areas of BEGIN REDAGED INFORMATION
END OF REDAGED INFORMATION and improve coverage and
data transmission options in eastern Bonnevile and northern Teton counties, and is in the
public interest.
B. POTENTIAL FOR CREAM SKIMMING
Gold Star is seeking to serve ETC territories where Gold Star provides coverage and
is not targeting low cost areas, or avoiding high cost areas, in order to "cream skim" high
cost support. The FCC conducts a cream skimming analysis that compares the population
density of each wire center in which the ETC applicant seeks designation against that of the
wire centers in the study area in which the ETC applicant does not seek designation.34 "Rural
cream skimming occurs when competitors serve only the low-cost high revenue customers in
a rural telephone companýs study area."3S Gold Star has chosen to serve all customers
34 ETC Order' 48.
3S Highland Cellular Order' 26.
GOLD STAR COMMUNICATIONS, LLC ETC APPLICATION - 17
where it is able to provide wireless service regardless of the population densities. Consistent
with the FCC's Highland Cellular Order;36 Gold Star is not seeking ETC designation in partial
wire centers. Further, Gold Star is proposing to serve some of the least densely populated37
and costliest to serve study areas in Idaho, including BEGIN REDACTED INFORMATION
~ END OF REDACTED INFORMATION Therefore, Gold Star is not
engaging in any sort of customer targeting or cream skimming.
C. IMPACT ON THE FUND
Gold Star's receipt of high cost support wil have a nominal impact on the federal
fund if calculated using the FCC's current "identical support" rule. Gold Star conducted a
study using customer zip codes from its biling system to identify the location of its
customers relative to the exchange area boundaries of the incumbent LECs (lLEC) with
whom Gold Star competes. Gold Star calculated the total per-line support that each
competing ILEC currently receives, including high cost, local switching, interstate common
line, and long-term support. The individuallLEC per-line support amount was then
multiplied by the approximate number of Gold Star consumers residing within the
competing ILEC's particular exchange and ultimately totaled. Based upon this analysis, Gold
Star estimates that it wil receive approximately $648,000.00 per year in USF support. This
represents less than .015% percent of the high-cost portion of the federal USF, assuming
$4.321 bilion in high cost support disbursements in a single year. Accordingly, grant of
361d
37 See CONFIDENTIAL Exhibit C-2, supra.
38 See Exhibit J, Universal Service Administrative Company High Cost Support Projections
Second Quarter 2010 - Idaho
GOLD STAR COMMUNICATIONS, LLC ETC APPLICATION - 18
Gold Star's ETC request wil have minimal impact on the USF. The benefits of designating
Gold Star as an ETC outweigh any potential harm to the sustainabilty of the fund.39
D. STATE AND FEDERAL PRECEDENT
Designation of Gold Star as an ETC is consistent with ETC decisions across the
country. There are now numerous cases at the state and federal level, including this
Commission's recent designation of CTC Telecom, LLC, Syringa Wireless, LLC and Edge
Wireless, LLC as wireless rural ETCs40, where designation of a wireless carrier as an ETC in a
rural area was found to be in the public interest. In addition to this Commission, numerous
state commissions and the FCC have repeatedly found that designating wireless carriers as
ETCs wil promote competition, advance universal service and further the deployment of
advanced services. For example, in its decision to designate Rural Cellular Corp. ("RCC") as
an ETC, the Washington Utilties and Transportation Commission stated: "Granting ETC
designation to RCC.. .wil facilitate the telecommunications choices available to rural citizens,
support the growth of new technologies and services, preserve and advance universal service,
39 See Virginia Cellular Order 1 31 (holding that 0.105% of total high-cost support
does not dramatically burden the USF)¡ see also Highland Cellular Order 1 25
(holding that 0.04% of total high-cost support does not dramatically burden the
USFJ¡ see also Federal-State Joint Board on Universal Service; Advantage Cellular
System; Inc; Petition for Designation as an Eligible Telecommunications Carrier in the
state of Tennessee, Memorandum Opinion and Order, CC Docket. 96-45, FCC 04-
3357125 (October 22, 2004) (holding that 0.419% of total high-cost support does
not dramatically burden the USF).
40 In the Matter of the Application of CTC Telecom; LLC for Designation as an Eligible
Telecommunications Carrier Under 47 u.S.C §214(e) (2l Order No. 30867 (IPUC Case No.
CTL-T-09-01, Service Date July 24, 2009)¡ In the Matter of the Application of Syringa
ilreles5j LLC for Designation as an Eligible Telecommunications Carrier Under 47 u.S.C
§214(e) (2l Order No. 30629 (lPUC Case No. SYR-T-08-01, Service Date August 28, 2008¡
In the Matter of the Petition of Edge ilreles5j LLC forDesignation as an Eligible
Telecommunications Carrier Under 47 u.S.C §214(e) (2l Order No. 30360 (lPUC Case No.
EDG-T-07-01, Service Date June 29, 2007).
GOLD STAR COMMUNICATIONS, LLC ETC APPLICATION - 19
and promote competition and the benefits it brings."41 In designating Midwest Wireless
Communications, LLC as an ETC in Minnesota, the Minnesota Public Utilties Commission
held that, "(c)ompetition would benefit consumers in southern Minnesota by increasing
customer choice (from no choice in most areas to more than one) and providing new
services made possible by wireless technologies. . . ."42 Similarly, in its decision designating
Western Wireless as an ETC in the State of Wyoming, the FCC held: "Designation of
competitive ETCs promotes competition and benefits consumers in rural and high-cost areas
by increasing customer choice, innovative services and new technologies."43
For all the above reasons, the public interest would be served by the designation of
Gold Star as a competitive ETC throughout its requested ETC service area.
iV. COMMITMENT TO SERVE REQUESTING CUSTOMERS.
Consistent with the IPUC ETC Requirements Order; Appendix p. 2, Gold Star is
committed to answering all reasonable requests for service within its proposed ETC service
area. Gold Star wants to use high-cost support prudently, to improve service to as many
people as possible, while also extending service to as many requesting customers as possible.
Gold Star wil use the following, six-point checklist in answering requests from
residents within its proposed ETC area, but outside its existing network coverage: (1)
determine whether the customer's equipment can be modified or replaced to provide
41 RCC Minnesota; Inc; d/b/a Cellular One, Order Granting Petition for Designation as an
Eligible Telecommunications Carrier, WUTC Docket No. UT-023033) Aug. 24. 2002), 'r68.
42 Midwest Wireless Communications; LLe, OAH Docket No. 3-2500-14980-2, Minn. PUC
Docket No. PT6153/ AM-02-686, adopted Feb. 13,2003 (order pending), adopting ALj's
Findings of Fact, Conclusions of Law, and Recommendation (ALF Dec. 31, 2002), 'r37.
43 Western Wireless Corporation Petition for Designation as an Eligible Telecommunications
Carrier in the State of Wyomin~ Memorandum Opinion and Order; 16 FCC Rcd 48, 55
(2000).
GOLD STAR COMMUNICATIONS, LLC ETC APPLICATION - 20
acceptable service¡ (2) determine whether a roof-mounted antenna or other network
equipment can be deployed at the premises to provide service¡ (3) determine whether
adjustments at the nearest cell site can be made to provide service¡ (4) determine whether
there are any other adjustments to network or customer facilities that can be made to
provide service¡ (5) explore the possibilty of offering resold service¡ and (6) determine
whether an additional cell site, a cell-extender, or repeater can be employed or constructed
to provide service.
V. LEGAL AUTHORITY
The Commission has the legal authority to grant the relief requested by Applicant
pursuant to 47 U.s.c. § 214(e)(2)¡ 47 C.F.R. § 54.201¡ see also; IPUC ETC Requirements
Order.
VI. RELIEF REQUESTED
For the reasons set forth above, and pursuant to Section 214(e)(2) of the Act, Gold
Star requests that the Commission enter an Order designating Gold Star as an ETC for the
areas described herein and that the Commission process this Application under Modified
Procedure and enter its Order at the earliest possible date.
RESPECTFULLY SUBMITTED this 3rd day of June, 2010.
RICHARDSON & O'LEARY, PLLC
By:
RY
Attorn ys for Gold Star Communications, LLC
GOLD STAR COMMUNICATIONS, LLC ETC APPLICATION - 21
HIBIT A
CONFIDENTIAL
THIS EXH'B:tT AllEGEDt y
CONT \ INS TRADE SECRETS
4'
OR CQr rflDENTIAl MATERIAL
ANDIS SEPARA TEL Y FilED
GOLD STAR COMMUNICATIONS, LLC ETC APPLICATION
"
EXHIBIT B
GOLD STAR COMMUNICATIONS, LLC ETC APPLICATION
~TA wireless
CO-ÒPS
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GOLD STAR COMMUNICATIONS, LLC ETC APPLICATION
ILEC WIRE CENTERS
SILVER STAR TELEPHONE CO.1 INC.
FREEDOM
IRWIN
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THIS EXHIBIT ALLEGEDLY
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GOLD STAR COMMUNICA TiONS, LLC ETC APPLICATION
EXHIBIT D
CONFIDENTIAL
THIS EXHIBIT AllEGEDLY
CONTAINS TRADE SECRETS
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GOLD STAR COMMUNICATIONS, LLC ETC APPLICATION
XHIBIT E
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