20060120Application.pdf

103 S. 2nd St.
O. Box 688
Roslyn, WA 98941
Telephone: [phone]
Fax: [phone]
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INLAND CELLULAR TELEPHONE COMPANY
Corporate Offices
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January 18 , 2006
Via Federal Express overniGht deliveru
Ms. Jean Jewel, Executive Secretary
Idaho Public Utilities Commission
472 W. Washington Street
O. Box 83720
Boise , ID 83720-0074
[phone]
Dear Ms. Washburn:
Enclosed please find one original and seven (7) copies of the Petition ofInland Cellular for Designation as Eligible Telecommunications Carrier
Petition ). Inland Cellular Telephone Company ("ICTC") is the sole general
partner of Washington RSA No.8 Limited Partnership (dba Inland Cellular).
ICTC is submitting the Petition on behalf of the partnership.
If there are any questions concerning the foregoing, please contact me at
[phone]. Thank you for your consideration of this Petition.
Sincerely,
ames K. Brooks
Controller
Enclosurescc: Joe Cusik (IPUC Staff)
:EI'./ED
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Before the
Idaho Public Utilities Commission ;:~O Ci:
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Inland Cellular
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i iLJ l~Urii"ii~~ hIn the Matter of the Petition of
Case No.1:/VC t - 0 "-0
For Designation as Eligible
Telecommunications Carriers
Under 47 U.C. ~ 214(e)(2)
PETITION OF INLAND CELLULAR
FOR DESIGNATION AS ELIGIBLE
TELECOMMUNICATIONS CARRIERS
Inland Cellular Telephone Company ("ICTC"), on behalf of Washington RSA No.
Limited Partnership d/b/a Inland Cellular (hereinafter referred to as "Inland Cellular" or the
Partnership ), submits this Petition to the Idaho Public Utilities Commission ("IPUC") for
Designation of Inland Cellular as an Eligible Telecommunications Carrier ("ETC") pursuant to
Section 214(e)(2) of the Telecommunications Act of 1934, as amended ("Act"), 47 U.c. ~
214(e)(2), and Section 54.201 of the Federal Communications Commission s ("FCC") rules, 47
R. ~ 54.201. To benefit the State, further competition, and to provide lifeline service, ICTC
requests that Inland Cellular be designated as eligible to receive all available support from the
federal Universal Service Fund ("USF") including, but not limited to, support for rural, insular
and high-cost areas and low-income customers. In support of this Petition, the following is
respectfully shown:
Name and Address of Petitioner
The name and address of Petitioner is Inland Cellular Telephone Company, 103
South 2nd Street, P.O. Box 688, Roslyn, Washington 98941. James K. Brooks shall be the
designated representative with the same mailing address as Petitioner. Official documents to be
sent electronically, are to be sent to jbrooks~inlandnet.com.
II.Applicable Statutes and Rules
The statutes and rules implicated by the instant Petition are as follows: 47 U.
~~ 153(27), 153(44), 214(e), 253(b) and 254(d); 47 C.R. ~~ 51.5, 54., 54.101 , 54.201 , 54.207
54.307 54.313 , and 54.314.
III.Authorization and Service Area
Inland Cellular is a telecommunications carrier as defined in 47 US.C. ~ 153(44)
and 47 C.R. ~ 51., and for the purposes of Part 54 of the FCC's rules.1 Inland Cellular is
therefore considered a common carrier under the Act.
Inland Cellular is authorized by the FCC as the "B Band" cellular carrier in the
northern section (within Idaho County) ofIdaho 2 (B-2) Rural Service Area ("RSA"). Inland
Cellular is licensed by the FCC as the "B Band" cellular carrier and has the authority to serve the
southern section (Clearwater, Latah, Lewis, and Nez Perce Counties) ofIdaho 1 (B-2) RSA
through a Rural Service Area Service Agreement and Option, dated as of January 12 1994, held
by Inland Telephone Company. A map of Inland Cellular s proposed service area with current
service contours is attached hereto as Exhibit A. Inland Cellular is a commercial mobile radio
service ("CMRS") provider pursuant to the definition of "mobile service" provided in 47 U.
~ 153(27). Inland Cellular provides interstate telecommunications services as defined in 47
US.C. ~ 254(d) and 47 C.R. ~ 54.
A telecommunications carrier may be designated as an ETC and receive universal
service support throughout its designated service area ifit agrees to: (i) offer services that are
47 U.C. ~ 54.et seq.
2 The operating entity for both South Idaho 1 RSA and North Idaho 2 RSA is Washington RSA
No.8 Limited Partnership d/b/a Inland Cellular. ICTC is the sole managing and general partner.
supported by federal universal service support mechanisms, and (ii) advertise the availability of
such services.3 In its
First Report and Order implementing Sections 214(e) and 254, the FCC set
forth the services a carrier must provide to be designated as an ETC in order to receive federal
universal service support.
Section 214(e)(2) of the Act provides that ETC designations shall be made for a
service area" designated by the state commission. In areas served by a non-rural company, the
state commission may establish an ETC service area for a competitor without federal
concurrence.5 Accordingly, Inland Cellular requests designation for its service area in the
non-rural wire centers listed in Exhibit B, attached hereto. Where Inland Cellular serves only a
portion of a wire center listed, it requests that it be designated as an ETC in that portion of the
wire center where it is authorized to serve.
In areas served by a rural telephone company, "service area" means the local
exchange carrier ("LEC") study area unless and until the FCC and the states, taking into account
recommendations of the Federal-State Joint Board on Universal Service, establish a different
definition of service area for such company.
See 47 U.C. ~ 214(e)(1).
Federal-State Joint Board on Universal Service, Report and Order 12 FCC Rcd 8776, 8809-
(1997) First Report and Order
See 47 Us.e. ~ 214(e)(5).
6 Those wire centers that Inland Cellular partially serves are indicated on Exhibit B with the
word "partial."
See 47 c.F.R. ~ 54.207(b).
Inland Cellular serves the entire study areas ofthe rural LECs listed in Exhibit C and therefore
disagregation is not an issue. Accordingly, with respect to the rural LECs wire centers8 within
the Partnership s service territories, the IPUC may designate the Partnership as an ETC without
the need to redefine the LEC service areas.
10.There are rural LEC wire centers that the Partnership does not cover entirely,
generally because the Partnership is not licensed by the FCC strictly along LEC boundaries.9 In
order to accommodate CMRS carriers who have authorized service areas that do not match LEC
wire centers, the FCC permits the state to designate the competitive ETC's service area along
boundaries that are not identical with LEC wire center boundaries. To do otherwise would
effectively exclude wireless carriers as a class from receiving universal service support and, as
discussed in Section VI infra would be contrary to the pro-competition policies articulated by
the FCc. Accordingly, pursuant to 47 C.R. ~ 54.207, for the LEC wire centers that are only
partially covered by the Partnership s authorized service areas, the Partnership requests that the
IPUC designate the portion of the wire centers where the Partnership is authorized to provide
servIce.
IV.The Partnership Offers the Supported Services to Qualify for Federal USF Support
11.Section 214(e)(I) of the Act and Section 54.201(d) of the FCC's rules provide
that carriers designated as ETCs shall, throughout their service area, (1) offer the services that
are supported by federal universal service support mechanisms either using their own facilities or
a combination of their own facilities and resale of another carrier s services, and (2) advertise the
availability of such services and the charges therefore using media of general distribution. 47
8 With the exception of certain non-rural areas, wire centers are generally synonymous with
exchanges.9 These wire centers are identified in Exhibit D by the word "partial."
US.c. ~ 214(e)(I); 47 C.R. ~ 54.201(d). The services which are supported by the federal USF
are:
1) voice grade access to the public switched network;
2) local usage;
3) dual tone multi-frequency signaling or its functional equivalent;
4) single-party 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.
47 C.R. ~ 54.101(a).
12.The Partnership is a full-service wireless carrier, which offers all of these
services, as described in detail below, throughout its service areas. The Partnership therefore
satisfies the requirements of Section 214( e)(1) of the Act.
13.Voice Grade Access. The Partnership provides voice grade access to the public
switched network through interconnection arrangements with local telephone companies. The
Partnership offers its subscribers this service at bandwidth between 300 and 000 hertz as
required by 47 c.F.R. 54.101(a)(I), thereby providing voice grade access.
14.Local Usage. The Partnership has a variety of rate plans that provide local usage
consistent with 47 c.F.R. 9 54.101(a)(2). To date, the FCC has not quantified a minimum
amount of local usage required to be included in a universal service offering, but has initiated a
separate proceeding to address this issue.10 As it relates to local usage
, the October 1998 NPRM
sought comment on a definition of the public service package that must be offered by all ETCs.
Specifically, the FCC sought comment on how much, if any, local usage should be required to be
10 See Guam Cellular and Paging, Inc.CC Docket No. 96-, DA 02-174 at para. 11 (C.
reI. Jan. 25 , 2002) Guamcell"); Federal-State Joint Board on Universal Service, Memorandum
Opinion and Order and Further Notice of Proposed Rulemaking, 13 FCC Red 21252 (1998)
October 1998 NPRM"
provided to customers as part of a universal service offering. 11 In the First Report and Order the
FCC deferred a determination on the amount of local usage that a carrier would be required to
provide.12 Any minimum local usage requirement established by the FCC will be applicable to
all designated ETCs, and the Partnership will comply with any and all minimum local usage
requirements adopted by the FCC or the IPUC.
15.DTMF Signaling. The Partnership provides dual tone multi-frequency ("DTMF"
signaling to facilitate the transportation of signaling throughout its network. The Partnership
currently uses out-of-band digital signaling and in-band multi-frequency ("MF") signaling that is
functionally equivalent to DTMF signaling.
16.Single Party Service.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. 13 The Partnership
provides single party service, as that term is defined in Section 54.101 of the FCC's rules. See
R. ~ 54.101.
17.Access to Emergency Services. The Partnership currently provides 911 access to
emergency services throughout its service area.
18.Access to Operator Services. The Partnership provides customer access to
operator services. Customers can reach operator services in the traditional manner by dialing "
19.Access to Interexchange Services . ICTC has signed interconnection agreements
with interexchange carriers on behalf of the Partnership. These arrangements enable the
Partnership to provide their customers access to interexchange services.
11
See October 1998 NPRM, 13 FCC Rcd at 21277-21281.
12 See First Report and Order 12 FCC Rcd at 8813.
13
See id. At 8810.
20.Access to Directory Assistance.Subscribers to the Partnership s services are able
to dial "555-1212" with the appropriate area code to reach directory assistance or "411" from
their mobile phones.
21.Toll Limitation. The Partnership has toll blocking capabilities which will enable
the Partnership to provide toll blocking service for Lifeline customers once the Partnership is
designated an ETC.
22.Pursuant to Section 54.201 of the FCC's rules, 47 c.F.R. ~ 54.201 , the
Partnership will advertise the availability of each of the supported services detailed above
throughout its licensed service area, by media of general distribution. The methods of advertising
utilized may include television, radio, newspaper, magazine, direct mailings, public exhibits and
displays, bill inserts, and telephone directory advertising. ETC designation will also enable
Inland Cellular the ability to offer and advertise the availability of Lifeline and Link-
Assistance Programs.
FCC ETC Designation
23.In addition to Section 214(e)(I) of the Act and Section 54.201(d) of the FCC's
rules, the FCC adopted additional requirements for a telecommunications carrier to be designated
as an eligible telecommunications carrier (ETC) by the FCc. 14 The FCC'
ETC Order effectively
states that an ETC Applicant must now: (1) provide a five-year plan demonstrating how high-
cost universal service support will be used to improve coverage, service quality or capacity
throughout the service area for which it seeks designation; (2) demonstrate its ability to remain
functional in emergency situations; (3) demonstrate that it will satisfy consumer protection and
service quality standards; (4) offer local usage plans comparable to those offered by the
14 See In re Federal-State Joint Board On Universal Service CC Docket No. 96-, Report and
Order, FCC 05-06 (March 17 2005)(ETC Order).
incumbent local exchange carrier (LEC) in the areas for which it seeks designation; and (5)
acknowledge that it may be required to provide equal access if all other ETCs in the designated
service area relinquish their designations. Inland Cellular believes that it could comply with
these additional requirements should the IPUC choose to adopt them for State certification
however, prior to adoption, we would ask the IPUC to consider the following: (1) is a five year
plan required of all providers that receive Universal Service Support; (2) for extension of
facilities to accommodate a subscriber or subscribers, doesn t the wireline provider charge the
subscriber(s) for all or a portion of the extension; (3) does the IPUC order all wireline carriers to
serve all subscribers within their designated service areas (e.g. Qwest-Soldiers Meadows)
without compensation; (4) would the IPUC require Inland Cellular to confine its customers to the
wireline service area, since today an Inland Cellular subscriber in Grangeville, ill, can talk to
another Inland Cellular subscriber in Lewiston, ill, (or any other Inland Cellular subscriber
within our entire coverage area, cell-to-cell) for 5 000 minutes a month on our U.A. calling
plans without additional charges; how is "comparable" local usage defined; (5) if a "local usage
plan comparable to those offered by the incumbent local exchange carrier (LEC) in the areas for
which it seeks designation" means unlimited local calling within the exchange (cell-to-wireline),
will facilities be available from the LEC's at reasonable rates?
VI.Statement of Need
24.Many residents ofIdaho live in rural areas where it is cost-prohibitive for a
competitive wireline telecommunications company to offer service. As a result, consumers
generally have only one service provider from which to choose. The Partnership seeks to offer
citizens of Idaho in its service area an alternative to traditional wireline service. In order for the
Partnership s network to expand into underserved areas, federal high-cost funding must be
provided so that needed infrastructure can be fully deployed and competitive service can be
delivered.
25.By granting ETC status to the Partnership, this Commission will expedite the
provision of competitive telephone service to the people living in remote areas and provide a
meaningful choice for many subscribers who have access to only one service provider.
VII.Grant oflCTC's Application Would Serve the Public Interest
26.In areas served by non-rural LECs, the Commission can designate Inland Cellular
as an ETC upon finding that the company meets the nine-point checklist and that it agrees to
advertise the supported services.15 In areas served by a rural telephone company, the
Commission must also determine whether granting ETC status to a competitor would serve the
public interest.16 In numerous cases decided by the FCC and state commissions, the answer has
been in the affirmative.
27.Designation of the Partnership as an ETC will promote competition and facilitate
the provision of advanced communications services to the residents of rural Idaho. Residents in
many rural areas have long trailed urban areas in receiving competitive local exchange service
and advanced telecommunications services. In many rural areas, no meaningful choice of local
exchange carrier exists.
15 See Cellular South Licenses, Inc.Docket No. 01-UA-0451 (Dec. 18 2001) (Mississippi).
16
See 47 U.C. ~ 214(e)(2).
17 See, e., Western Wireless Corporation Petition for Designation as an Eligible
Telecommunications Carrier in the State of Wyoming, 16 FCC Rcd 48 55 (2000) Western
Wireless ), aff'24 CR 1216 (Oct. 19 2001) Western Wireless Recon. Order ); Smith
Bagley, Inc., Final Order Utility Case No. 3026 (Feb. 19 2002) (New Mexico).
28.To date, a number of wireless carriers have been designated as ETCs in multiple
states.18 Recognizing the advantages wireless carriers can bring to the universal service program
the FCC has found that "imposing additional burdens on wireless entrants would be particularly
harmful to competition in rural areas, where wireless carriers could potentially offer service at
much lower costs than traditional wireline service.,,19 One of the principal goals of the
Telecommunications Act of 1996 was to "promote competition and reduce regulation in order to
secure lower prices and high-quality services for American telecommunications consumers and
encourage the rapid deployment of new telecommunications technologies.20 Competition in
rural areas increases facilities and spurs development of advanced communications as carriers
vie for a consumer s business.
29.The FCC recognized that rural customers will benefit from the increased
availability of wireless service in its initial decision designating Western Wireless as an ETC in
the State of Wyoming, observing: "Designation of competitive ETCs promotes competition and
benefits consumers in rural and high-cost areas by increasing customer choice, innovative
services, and new technologies.21 Similarly, in designating the cellular carrier Smith Bagley,
Inc. as an ETC in Arizona, the state commission found competitive entry to provide additional
consumer choice and a potential solution to "health and safety risks associated with geographic
18 See, e., Yelm Telephone Company et aI., Order Designation Eligible Telecommunications
Carriers Docket Nos. UT-970333 et al. (Dec. 23 , 1997) (Washington); Guamcell, supra;
Cellular South Licenses, Inc., supra; NE. Colorado Cellular, Inc.Docket No. 00A-315T (Dec.
2001) (Colorado); Minnesota Cellular Corporation s Petition for Designation as an Eligible
Telecommunications Carrier Docket No. P5695/M-98-1285 (Oct. 27, 1999) (Minnesota).
19 First Report and Order 12 FCC Rcd at 8881-82.
20 Telecommunications Act of 1996, Public Law, 104-104, 100 Stat. 56 (1996).
21 Western Wireless Corporation; supra 16 FCC Rcd at 55.
isolation.22 By designating a wireless carrier as an ETC, the IPUC will foster competition and
provide a meaningful choice of services and service providers to the residents of Idaho.
30.The public interest standard under Section 214(e)(2) for designating ETCs in
territories served by rural telephone companies emphasizes competition and consumer benefit
not incumbent protection. In considering the impact that Western Wireless' ETC designation in
Wyoming would have on rural telephone companies, the FCC said:
We do not believe that it is self-evident that rural telephone
companies cannot survive competition from wireless providers.
Specifically, we find no merit to the contention that designation of
an additional ETC in areas served by rural telephone companies
will necessarily create incentives to reduce investment in
infrastructure, raise rates, or reduce service quality to consumers in
rural areas. To the contrary, we believe that competition may
provide incentives to the incumbent to implement new operating
efficiencies, lower prices, and offer better service to its
customers.
Further, Congress has mandated that universal service provisions be "competitively neutral" and
necessary to preserve and advance universal service.See 47 U.C. ~ 253(b). The Partnership
will provide consumers with wider local calling areas, mobile communications, a variety of
service offerings, high-quality service, and competitive rates. By offering customers new
choices, the incumbent LECs will have an incentive to introduce new, innovative, or advanced
service offerings.
31.In most rural areas, wireless telephone service is today a convenience, but it will
not emerge as a potential alternative to wireline service unless high-cost support is made
available to drive infrastructure investment. Indeed, without the high-cost program it is doubtful
22 Smith Bagley, Inc., Order Decision No. 63269, Docket No. T-02556A-99-0207, at p. 12 (Dec.
2000) (Arizona).
23 Western Wireless, supra 16 FCC Rcd at 57.
that many rural areas would have wireline telephone service even today. Provision of high-cost
support to Inland Cellular will begin to level the playing field with the incumbent LECs and
make available for the first time a potential competitor for primary telephone service in remote
areas ofIdaho in the Idaho 1 (B-2) RSA and the Idaho 2 (B-2) RSA.
32.The consumer benefits of designating a competitive ETC are already becoming
evident. In South Dakota, shortly after WWC License, LLC entered the market as a competitive
carrier, the incumbent LEC lowered its prices and upgraded its switch. Competitive carriers in
Arizona and Mississippi have earmarked high-cost support funds for additional channel capacity,
new cell sites, and expedited upgrading of facilities from analog to digital.
33.With high-cost support, Inland Cellular will have an opportunity to create a
network that is capable of convincing customers to rely on wireless service as their primary
phone.
VIII.High-Cost Certification
34.Under FCC Rule Sections 54.313 and 54.314, carriers wishing to obtain
high-cost support must either be certified by the appropriate state commission or, where the state
commission does not exercise jurisdiction, self-certify with the FCC and the Universal Service
Administrative Corporation ("USAC") their compliance with Section 254(e) of the Federal
Telecommunications Act of 1996.47 c.F.R. ~~ 54.313, 54.314. ICTC attaches its high-cost
certification letter as Exhibit E hereto. ICTC respectfully requests that the IPUC issue a finding
that the Partnership has met the high-cost certification requirement and that the Partnership is
therefore, entitled to begin receiving high-cost support as of the date it receives a grant of ETC
status in order that funding will not be delayed.
24 See, e.g. Guam Cellular and Paging, Inc. Petition for Waiver of FCC Rule Section 54.314, CC
Docket 96-45 (filed Feb. 6 2002).
WHEREFORE, pursuant to Section 214(e)(2) of the Act, ICTC respectfully requests that
the Commission, (1) enter an Order designating the Partnership as an ETC for its requested ETC
service area as shown on Exhibit A hereto, and (2) certify to the FCC that the Partnership will
use the support for its intended purpose.
Respectfully submitted
Inland Cellular Telephone Company
As General Partner for
Washington RSA No.8 Limited Partnership
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Gregory A. Maras
Secretary
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Exhibit B
NON-RURAL LEC WIRE CENTERS
LEC: Verizon Northwest, Inc. - ill - SAC 472416
Wire Center:
LEC: Owest Corp. - ill
Wire Centers:
Bovil
Deary
Genesee
Moscow
Orofino
Peck
Pierce
Potlatch (GTE)
Weippe
Cottonwood
Craigmont
Grangeville
Kamiah
Kooskia
Lapwai
Lewiston
Nez Perce
Exhibit C
RURAL LEC WIRE CENTERS
LEC: Inland Telephone Company- SAC 472423
Wire Centers:Leon
Lenore
LEC: Potlatch Telephone Company, Inc. SAC 472230
Wire Centers: Juliaetta
Kendrick
Troy
Exhibit D
RURAL LEC WIRE CENTERS
LEC: Citizens Telephone Co. ofID DBA Frontier Communications ofIdaho - SAC 474427
Wire Centers:Elk City (partial)
White Bird (partial)
INLAND CELLULAR TELEPHONE COMPANY
Corporate Offices
lllflt" 103 S. 2nd St.
O. Box 688
Roslyn, WA 98941
Telephone: [phone]
Fax: [phone]
January 18, 2006
Idaho Public Utilities Commission
472 W. Washington Street
O. Box 83720
Boise , ID 83720-0074
Re: High-Cost Certification of Inland Cellular
To the Commission:
Inland Cellular Telephone Company ("ICTC") has submitted a Petition for
Eligible Telecommunications Carrier ("ETC") designation in the State of Idaho
for Washington RSA No.8 Limited Partnership (dba Inland Cellular)("Inland
Cellular" hereafter). As required by Sections 54.313(b) and 54.314(b) of the
Federal Communications Commission s rules, 47 C.R. SS 54.314(a), (c) and
(d), ICTC hereby submits the certification below in order to begin receiving
high-cost support in Inland Cellular s designated ETC areas.
Accordingly, as Secretary of ICTC , I hereby certify on behalf of Inland
Cellular and under penalty of perjury that all high-cost support provided to
Inland Cellular will be used only for the provision, maintenance and upgrading
of facilities and services for which the support is intended, pursuant to Section
254(e) of the Telecommunications Act of 1996, 47 U.C. S 254(e). I also certify
that I am authorized to make this certification on Inland Cellular s behalf.
~~
tJ.
/ Gre Dry . Maras
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Date
SUBSCRIBED, SWORN TO AND ACKNOWLEDGED before me this ~day
January, 2006.
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NOTARY PUBLIC
My Commission Expires:
BEFORE THE IDAHO PUBLIC UTILITES COMMISSION
CERTIFICATE OF SERVICE
, James K. Brooks, hereby certify that I have, on this /8Pday of January, 2006, served
the foregoing PETITION FOR INLAND CELLULAR FOR DESIGNATION AS AN
ELIGIBLE TELECOMMUNICATIONS CARRIER upon all parties believed to be of interest in
this proceeding. A copy of the foregoing PETITION FOR INLAND CELLULAR FOR
DESIGNATION AS AN ELIGIBLE TELECOMMUNICATIONS CARRIER filed today was
placed in the United States mail, first-class postage pre-paid, to the following:
Citizens Telecommunications CompanyofID
DBA Frontier Communications of ID
Ingo Henningson, Manager, Regulatory
4 triad Center, Suite 200
Salt Lake City, Utah 84180
Qwest Corporation
Theresa Jensen, Director-Regulatory
1600 - 71 st Avenue
Room 1806
Seattle, Washington 98191
Inland Telephone Company
John P. Coonan, Treasurer
Post Office Box 171
Roslyn, Washington 98941
Verizon Northwest, Inc.
David Valdez, Vice President
1800 41 st Street
Post Office Box 1003
Everett, Washington 98206
Potlatch Telephone Company, Inc.
TDS Telecom
Gail Long, Regulatory Contact
Post Office Box 1566
Oregon City, Oregon 97045
Conley Ward, Esq, ITA Legal Counsel
Givens Pursley LLP
O. Box 2720
Boise, Idaho 83701