HomeMy WebLinkAbout20060629Application.pdf103 S. 2nd St.
O. Box 688
Roslyn, WA 98941
Telephone: (509) 649-2500
Fax: (509) 649-3300
It:!8J
INLAND CELLULAR TELEPHONE COMPANY
Corporate Offices
, ,
- i
"'-~, '
~ I: ,: 0
' ,- ,
June 26, 2006 b-O
:tN L
.-,
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
(208) 375-7382
Dear Ms. Jewel:
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
(509) 649-2500. Thank you for your consideration of this Petition.
Enclosurescc: Joe Cusik (IPUC Staff)
Before the
Idaho Public Utilities Commission
In the Matter ofthe Petition of
Case No. j:/JG-.:::t' -6'b-O2---
Inland Cellular
For Designation as Eligible
Telecommunications Carriers
Under 47 u.c. 9214(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. 9
214(e)(2), and Section 54.201 of the Federal Communications Commission s ("FCC") rules, 47
c.F.R. 9 54.201. To benefit the residents and promote business growth within Inland Cellular
Idaho service area, 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.
99 153(27), 153(44), 214(e), 253(b) and 254(d); 47 c.F.R. 99 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. 9 153(44)
and 47 C.R. 9 51.5, and for the purposes of Part 54 of the FCC's rules.l 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 ETC 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
C. 9 153(27). Inland Cellular provides interstate telecommunications services as defined in
47 U.C. 9 254(d) and 47 C.R. 9 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 US.C. 954.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. 9214(e)(1).
Federal-State Joint Board on Universal Service, Report and Order 12 FCC Red 8776, 8809-
(1997) First Report and Order
See 47 USe. 9 214(e)(5).
6 Those wire centers that Inland Cellular partially serves are indicated on Exhibit B with the
word "partial."
See 47 C.R. 954.207(b).
Inland Cellular s service area encompasses the entire study areas of the 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. 9 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.Inland Cellular Offers the Supported Services to Qualify for Federal USF Support
11.Section 214(e)(1) 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."
C. 9 214(e)(1); 47 c.F.R. 9 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.F.R. 954.1O1(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 3 000 hertz as
required by 47 C.R. 54.101(a)(1), thereby providing voice grade access.
14.Local Usage. The Partnership has a variety of rate plans that provide local usage
consistent with 47 C.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.
rel. 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 ("MP") signaling that is
functionally equivalent to DTMP 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 ofthe FCC's rules. See
c.F.R. 954.101.
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 Red at 21277-21281.
12 See First Report and Order 12 FCC Red 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 ofthe FCC's rules, 47 C.R. 954.201 , 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)(1) 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 ETC by the FCC.14
The FCC's 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 incumbent local exchange carrier (LEC) in 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).
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.
VI.IPUC ETC Designation
24.On August 4th of2005, the IPUC, through Order No. 29841 , adopted additional
requirements to Section 214(e)(1) of the Act for a telecommunications carrier to be designated as
an ETC by the IPUc. These requirements are: (1) The Commitment and Ability to Provide
Supported Services (including a two-year network improvement plan); (2) The Ability to Remain
Functional in Emergencies; (3) A Commitment to Consumer Protection and Service; and. (4)
Description ofthe Local Usage Plans. Inland Cellular believes that it currently meets these
additional requirements.
25.The Commitment and Ability to Provide Supported Services (including a two-
year network improvement plan): The Partnership was formed in 1989 and turned up its first
analog cell site in 1991. Over the years, Inland Cellular has steadily grown and expanded its
coverage in order to provide increasingly better service. Changing to digital coverage and now
expanding into data and eventually offering broadband services. Today, Inland Cellular has
sixty-eight (68) sites; twenty-two (22) of which are in Idaho. Our customers, their respective
communities and community emergency management personnel generate much of our continued
expansion. Being a relatively small cellular carrier, Inland Cellular has learned that in order to
gain customer loyalty and respect, it must listen to those that it will serve.
26.As was stated in section IV above, Inland Cellular currently meets the basic
requirements of supported services. Its two-year plan, 2006 and 2007, involves an estimated
investment of$2 100 000 in Idaho; budgeted sites or site improvements at Genesee, Kamiah
15 In the Matter of the Application ofWWC Holding Co., Inc. DBA Cellular-One Seeking
Designation as an Eligible Telecommunications Carrier that may receive Federal Universal
Service Support Case No. WST-05-, Order No. 29841 (August 4 2005).
Nuxall (near Kooskie), Troy, Track (outside of Moscow), Highway 95 North and Highway 95
Summit. These sites will increase the availability of service for rural Idaho and although not
specifically addressed by the FCC or the IPUC, the majority of the Idaho sites should be data
capable (lXRTT platform) and then upgraded to broadband data capable (EVDO) in the near
future. Inland Cellular has budgeted for 19 sites to be upgraded to EVDO (approximately
500 000) in 2006-2007, but have not committed to which sites. This is in addition to the
aforementioned $2 100 000 in Idaho sites. In addition, traffic loads are constantly reviewed and
additional carrier investment is added when the need is determined.
27.The Ability to Remain Functional in Emergencies: Inland Cellular has battery
back-up and a standby generator at the central office, as well as at all cell sites. The generators
are checked regularly and are alarmed for failure. Inland Cellular maintains redundant routes to
connect to the outside world should one route be cut-off. Inland Cellular has technicians on call
should trouble develop at any time.
28.A Commitment to Consumer Protection and Service : Customer service is very
important to Inland Cellular. It is the one portion of our business that we believe distinguishes us
from our competition in a highly competitive business. Although it can be time consuming, we
like for our customers to have a face for them to talk to should questions arise. Pursuant to FCC
regulations, Inland Cellular must certify that it complies with the Consumer Proprietary Network
Information rules, set forth in 47 CFR 964.2001 through 64.2009, to protect consumer
information.
29.Description of the Local Usage Plans: Inland Cellular offers many calling plans
for consumers to choose from that should fit their calling needs. The post-pay plans range from
$29.95 for unlimited minutes of in-network calling (within the Inland Cellular calling area
network cell-to-cell) per month and 200 other minutes to $789.95 for 5 000 minutes of in-
network calling per month, 5 000 minutes of incoming calls per month and 8 000 minutes of
calling per month within the 50 United States for no additional charges (i.e. no toll or roaming
when on another carriers network). Exhibit E lists the various calling plans offered by Inland
Cellular and are posted on its website (www.inlandcellular.com) as well as the coverage areas
and other service offerings.
VI.Statement of Need
29.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.
30.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 of ICTC'Application Would Serve the Public Interest
31.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.16 In areas served by a rural telephone company, the
Commission must also determine whether granting ETC status to a competitor would serve the
16 See Cellular South Licenses, Inc.Docket No. 01-UA-0451 (Dec. 18 2001) (Mississippi).
public interest.17 In numerous cases decided by the FCC and state commissions, the answer has
been in the affirmative.
32.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.
33.To date, a number of wireless carriers have been designated as ETCs in multiple
states.19 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 wire line service.,,20 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.21 Competition in
17
See 47 U.c. 9214(e)(2).
18 See, e., Western Wireless Corporation Petition for Designation as an Eligible
Telecommunications Carrier in the State of Wyoming, 16 FCC Red 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).
19 See, e.g., Yelm Telephone Company et al., 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).
20 First Report and Order 12 FCC Red at 8881-82.
21 Telecommunications Act of 1996, Public Law, 104-104, 100 Stat. 56 (1996).
rural areas increases facilities and spurs development of advanced communications as carriers
vie for a consumer s business.
34.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.22 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
isolation.23 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.
35.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
22 Western Wireless Corporation; supra 16 FCC Red at 55.
23 Smith Bagley, Inc., Order Decision No. 63269, Docket No. T-02556A-99-0207, at p. 12 (Dec.
, 2000) (Arizona).
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 US.c. 9 253(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.
36.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
that many rural areas would have wireline telephone service even today; in fact there are areas
within Inland Cellular s service area where wireline service is not available 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.
37.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.
24 Western Wireless, supra 16 FCC Red at 57.
38.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
39.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. 99 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.
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.
25 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).
Respectfully submitted
Inland Cellular Telephone Company
As General Partner for
Washington RSA No.8 Limited Partnership
BY:
Gregory A. aras
Secretary
Sh
o
s
h
o
n
e
Co
u
n
t
y
ET
G
A
R
E
A
A
P
P
L
I
G
A
T
I
O
N
Wa
s
h
i
n
g
t
o
n
R
S
A
N
o
.
8
L
i
m
i
t
e
d
P
a
r
t
n
e
r
s
h
i
p
(1
0
R
S
A
21
CM
A
3
8
9
-
B2
1
C
a
l
l
S
i
g
n
K
N
K
R
2
7
7
)
No
r
t
h
I
D
2
R
S
A
S
e
r
v
i
c
e
A
r
e
a
67
7
S
q
.
M
i
l
e
s
Cl
e
a
r
w
a
t
e
r
Co
u
n
t
y
Wa
s
h
i
n
g
t
o
n
R
S
A
N
o
.
8
L
i
m
i
t
e
d
P
a
r
t
n
e
r
s
h
i
p
(1
0
R
S
A
1
CM
A
3
8
8
-
B2
Ca
l
l
S
i
g
n
K
N
K
Q
4
0
0
)
So
u
t
h
I
D
1
R
S
A
S
e
r
v
i
c
e
A
r
e
a
88
8
S
q
.
M
i
l
e
s
"
.
(
/
.
mi
l
e
s
ID
2
R
S
A
Exhibit B
NON-RURAL LEC WIRE CENTERS
LEC: Verizon Northwest, Inc. - ill - SAC 472416
Wire Center:
LEC: Qwest 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)
IN
L
A
N
D
C
E
L
L
U
L
A
R
CA
L
L
I
N
G
P
L
A
N
S
A
N
D
P
R
E
P
A
I
D
S
E
R
V
I
C
E
Mi
n
u
t
e
s
Mo
n
t
h
l
y
Ad
d
'
50
S
t
a
t
e
In
c
o
m
i
n
g
Ce
l
l
t
o
Lo
n
g
50
0
N
i
g
h
t
&
Vo
i
c
e
St
a
n
d
a
r
d
Ad
d
'
Fr
e
e
I
Pl
a
n
Li
n
e
s
We
e
k
e
n
d
Ad
d
'
In
c
l
u
d
e
d
Ra
t
e
Mi
n
s
Ro
a
m
i
n
g
Ca
l
l
s
Ce
l
l
*
*
Di
s
t
a
n
c
e
Ma
i
l
Ma
i
l
Li
n
e
s
Mi
n
s
Mi
n
s
Te
k
P
a
k
20
0
$
2
9
.
$
0
.
N/
A
Un
l
i
m
i
t
e
d
Un
l
i
m
i
t
e
d
Un
l
i
m
i
t
e
d
In
c
l
u
d
e
d
In
c
l
u
d
e
d
N/
A
N/
A
S.
A
.
3
5
0
*
35
0
$
3
9
.
$
0
.
In
c
l
u
d
e
d
50
0
0
50
0
0
In
c
l
u
d
e
d
In
c
l
u
d
e
d
N/
A
N/
A
A.
5
0
0
*
50
0
$
4
4
.
$
0
.
In
c
l
u
d
e
d
50
0
0
50
0
0
In
c
l
u
d
e
d
In
c
l
u
d
e
d
N/
A
N/
A
A.
7
5
0
*
75
0
$
6
4
.
$
0
.
In
c
l
u
d
e
d
50
0
0
50
0
0
In
c
l
u
d
e
d
In
c
l
u
d
e
d
N/
A
N/
A
A.
1
0
0
0
*
10
0
0
$
8
9
.
$
0
.
In
c
l
u
d
e
d
50
0
0
50
0
0
In
c
l
u
d
e
d
In
c
l
u
d
e
d
N/
A
N/
A
A.
1
2
5
0
*
12
5
0
$
1
1
4
.
$
0
.
In
c
l
u
d
e
d
50
0
0
50
0
0
In
c
l
u
d
e
d
In
c
l
u
d
e
d
$9
.
20
0
A.
1
5
0
0
*
15
0
0
$
1
3
9
.
$
0
.
In
c
l
u
d
e
d
50
0
0
50
0
0
In
c
l
u
d
e
d
In
c
l
u
d
e
d
$9
.
20
0
A.
3
0
0
0
*
30
0
0
$
2
8
9
.
$
0
.
In
c
l
u
d
e
d
50
0
0
50
0
0
In
c
l
u
d
e
d
In
c
l
u
d
e
d
$9
.
20
0
S.
A
.
4
5
0
0
*
45
0
0
$
4
3
9
.
$
0
.
In
c
l
u
d
e
d
50
0
0
50
0
0
In
c
l
u
d
e
d
In
c
l
u
d
e
d
$9
.
20
0
S.
A
.
6
0
0
0
*
60
0
0
$
5
8
9
.
$
0
.
In
c
l
u
d
e
d
50
0
0
50
0
0
In
c
l
u
d
e
d
In
c
l
u
d
e
d
$9
.
20
0
A.
8
0
0
0
*
80
0
0
$
7
8
9
.
$
0
.
In
c
l
u
d
e
d
50
0
0
50
0
0
In
c
l
u
d
e
d
In
c
l
u
d
e
d
$9
.
20
0
Tw
i
n
s
U
.
*
+
+
50
0
$
6
9
.
$
0
.
In
c
l
u
d
e
d
50
0
0
50
0
0
In
c
l
u
d
e
d
In
c
l
u
d
e
d
N/
A
N/
A
Tr
I
D
s
U
.
A.
*
+
+
10
0
0
$
9
9
.
$
0
.
In
c
l
u
d
e
d
50
0
0
50
0
0
In
c
l
u
d
e
d
In
c
l
u
d
e
d
N/
A
N/
A
Qu
a
d
U
.
A:
+
+
12
5
0
$
1
2
4
.
$
0
.
In
c
l
u
d
e
d
50
0
0
50
0
0
In
c
l
u
d
e
d
In
c
l
u
d
e
d
N/
A
N/
A
NO
T
E
:
A
l
l
a
p
p
l
i
c
a
b
l
e
F
e
d
e
r
a
l
,
S
t
a
t
e
,
a
n
d
l
o
c
a
l
t
a
x
e
s
,
s
u
r
c
h
a
r
g
e
s
,
a
n
d
f
e
e
s
w
i
l
l
a
p
p
l
y
.
NO
T
E
:
S
e
r
v
i
c
e
i
s
n
o
t
a
v
a
i
l
a
b
l
e
i
n
a
l
l
a
r
e
a
s
.
W
e
h
a
v
e
a
g
r
e
e
m
e
n
t
s
w
i
t
h
o
t
h
e
r
s
e
r
v
i
c
e
p
r
o
v
i
d
e
r
s
i
n
m
o
s
t
a
r
e
a
s
a
c
r
o
s
s
t
h
e
U
.
S.
S
e
r
v
i
c
e
i
n
t
h
o
s
e
a
r
e
a
s
i
s
p
r
o
v
i
d
e
d
b
y
a
di
f
f
e
r
e
n
t
c
a
r
r
i
e
r
a
n
d
I
n
l
a
n
d
C
e
l
l
u
l
a
r
d
o
e
s
n
o
t
g
u
a
r
a
n
t
e
e
t
h
e
i
r
s
e
r
v
i
c
e
.
To
g
e
t
s
e
r
v
i
c
e
o
n
a
U
.
A.
p
l
a
n
,
y
o
u
m
u
s
t
h
a
v
e
a
T
r
i
-
Mo
d
e
C
O
M
A
p
h
o
n
e
t
h
a
t
i
s
c
o
m
p
a
t
i
b
l
e
w
i
t
h
o
u
r
s
e
r
v
i
c
e
a
n
d
h
a
s
t
h
e
m
o
s
t
c
u
r
r
e
n
t
P
R
L
l
o
a
d
e
d
.
S
e
e
s
t
o
r
e
f
o
r
de
t
a
i
l
s
.
**
Ap
p
l
i
e
s
o
n
l
y
t
o
c
a
l
l
s
m
a
d
e
o
r
r
e
c
e
i
v
e
d
w
i
t
h
i
n
o
u
r
H
o
m
e
S
e
r
v
i
c
e
A
r
e
a
o
n
o
u
r
t
o
w
e
r
s
.
C
e
l
l
t
o
c
e
l
l
c
a
l
l
s
t
o
o
t
h
e
r
I
n
l
a
n
d
C
e
l
l
u
l
a
r
c
u
s
t
o
m
e
r
s
w
i
t
h
i
n
o
u
r
H
o
m
e
S
e
r
v
i
c
e
Ar
e
a
o
n
l
y
.
W
e
e
k
e
n
d
s
:
12
:
0
1
a
.
m.
S
a
t
u
r
d
a
y
t
o
m
i
d
n
i
g
h
t
o
n
S
u
n
d
a
y
.
N
i
g
h
t
:
7
:
0
1
p
.
m.
t
o
6
:
5
9
a
.
m.
M
o
n
d
a
y
-
Th
u
r
s
d
a
y
;
M
o
n
d
a
y
1
2
:
0
1
a
.
m.
t
o
6
:
5
9
a
.
;
F
r
i
d
a
y
7
:
0
1
m.
t
o
1
2
:
0
0
a
.
++
Sh
a
r
e
d
m
i
n
u
t
e
s
Mo
n
t
h
l
y
In
l
u
d
e
d
Lo
n
g
Ro
a
m
i
n
g
Mi
n
i
m
u
m
Pr
e
p
a
i
d
P
l
a
n
Se
t
u
p
F
e
e
Ac
c
e
s
s
Ad
d
'
i
M
i
n
s
Vo
i
c
e
M
a
i
l
Fe
e
Mi
n
u
t
e
s
Di
s
t
a
n
c
e
Ra
t
e
Re
p
l
e
n
i
s
h
Q
P
l
a
n
15
.
In
c
l
u
d
e
d
Q
1
5
0
$
1
9
.
15
0
15
.
In
c
l
u
d
e
d
Q
3
0
0
$
2
9
.
30
0
15
.
In
c
l
u
d
e
d
Q
5
0
0
$
3
9
.
50
0
15
.
In
c
l
u
d
e
d
NO
T
E
:
A
l
l
a
p
p
l
i
c
a
b
l
e
F
e
d
e
r
a
l
,
S
t
a
t
e
,
a
n
d
l
o
c
a
l
t
a
x
e
s
,
s
u
r
c
h
a
r
g
e
s
,
a
n
d
f
e
e
s
w
i
l
l
a
p
p
l
y
.
AL
L
C
A
L
L
I
N
G
P
L
A
N
S
I
N
C
L
U
D
E
C
A
L
L
W
A
I
T
I
N
G
,
C
O
N
F
E
R
E
N
C
E
C
A
L
L
I
N
G
,
A
N
D
C
A
L
L
F
O
R
W
A
R
D
I
N
G
.
Fi
l
e
n
a
m
e
:
S
E
R
V
I
C
E
R
A
T
E
S
.
xl
s
::
r
:
--
i
INLAND CELLULAR TELEPHONE COMPANY
Corporate Offices
It:fJ1103 S. 2nd St.
O. Box 688
Roslyn WA 98941
Telephone: (509) 649-2500
Fax: (509) 649,3300
June 26, 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. 99 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. 9254(e). I also certify
that I am authorized to make this certification on Inland Cellular s behalf.
~ M~~S
~- -~
-,z,f; -O/:,
Date
SUBSCRIBED, SWORN TO AND ACKNOWLEDGED before me this .:1 day of June,
2006.
:\\\\\,'UII""
'\;
A"\ f. HI'
$'
!t,-
..."
~J..~'"
i di..
-,'Ntt- .?;~~
-. -. .
':0.
~ ~...."-
~ i
~CP
--..-
:z=
-;,....' . ....--,..#,-.".
'" A
.- ...~,-..
"'U "\V f!1.;!:
~,,. "'.. ~ ;:;
" O
.....~~~
'1111 W"~~'!t.'
"'u,,"\\\\~
;(~
OTARY PUBLIC
My Commission EXPires:
~ .
;2. 8", z "'0
BEFORE THE IDAHO PUBLIC UTILITES COMMISSION
CERTIFICATE OF SERVICE
, James K. Brooks, hereby certify that I have, on this '), 11f!aay of June, 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:
Ms. Jean Jewel, Executive Secretary
Idaho Public Utilities Commission
472 W. Washington Street
Post Office Box 83720
Boise, Idaho 83702
Nez Perce Tribal Executive Committee
Rebecca Miles, Chairman
Post Office Box 305
Lapwai, Idaho 83540
Citizens Telecommunications Company ofID
DBA Frontier Communications of ID
Ingo Henningson, Manager, Regulatory
4 triad Center, Suite 200
Salt Lake City, Utah 84180
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
Post Office Box 2720
Boise, Idaho 83701
Qwest Corporation
Theresa Jensen, Director-Regulatory
1600 - 71 st Avenue
Room 1806
Seattle, Washington 98191
The Coeur d' Alene Tribe
Chief James Allen, Tribal Chairman
850 A Street
Post Office Box 408
Plummer, Idaho 83851
Verizon Northwest, Inc.
David Valdez, Vice President
1800 41 st Street
Post Office Box 1003
Everett, Washington 98206
Inland Telephone Company
Douglas Weis, President
Post Office Box 171
Roslyn, Washington 98941