20141106Comments.pdf

DAPHNE HUANG RECER’
DEPUTY ATTORNEY GENERAL -
IDAHO PUBLIC UTILITIES COMMISSION rflj fl\!Q 5
P0 BOX $3720
BOISE,IDAHO 83720-0074
[phone] -
IDAHO BAR NO.8370
Street Address for Express Mail:
472 W.WASHINGTON
BOISE,IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
MOBILITIE,LLC TO REGISTER AS A )CASE NO.MOB-T-14-O1
WHOLESALE TELECOMMUNICATIONS )
PROVIDER IN IDAHO.)COMMENTS OF THE
)COMMISSION STAFF
____________________________________________________________________________________)
The Staff of the Idaho Public Utilities Commission,by and through its Attorney of Record,
Daphne Huang,Deputy Attorney General,in response to the Notice of Application and Notice of
Modified Procedure,issued on October 16,2014,Order No.33153,submits the following
comments.
BACKGROUND
On September 26,2014,Mobilitie,LLC (“Mobilitie”or “Company”)applied for a
registrationlcertification as a wholesale provider of telecommunications service in the State of Idaho
pursuant to Procedural Order No.32277,IDAPA 31.01.01.114,and Title 62 of the Idaho Code.
Application at 1.
STAFF ANALYSIS
Mobilitie is a Nevada limited liability company and lists its principal place of business as
Newport Beach,California.Id.at 2.Mobilitie does not maintain a place of business in Idaho but
lists CT Corporation System,921 5.Orchard Street,Suite G,Boise,Idaho 83705,as its registered
STAFF COMMENTS 1 NOVEMBER 6,2014
agent in Idaho.Id In June 2014,Idaho’s Secretary of State certified that Mobilitie’s authorization
to transact business in Idaho,issued upon its August 2010 request,was still active.Id at Exh.2.
Mobilitie states it has not yet initiated interconnection negotiations but intends to do so as
necessary and upon being granted authority by the Commission.The Company represents that it
will seek Commission approval of any ensuing interconnection agreements.Id.at 3.
Mobilitie agrees to comply with all Idaho laws and Commission rules and regulations and is
committed to numbering conservation measures including mandatory one thousand (1,000)block
pooling.Id.
STAFF RECOMMENDATION
Staff has reviewed Mobilitie’s Application for registration as a wholesale provider of
telecommunications services in Idaho for compliance with applicable legal requirements and
believes the Company understands Commission Rule of Procedure 114 and Commission Order No.
32277.Staff believes that Mobilitie possesses the requisite financial,managerial,and technical
qualifications necessary to operate as a provider of telecommunications services.Staff,therefore,
recommends that the Commission approve Mobilitie as a registered wholesale communications
provider subject to the following conditions:
1.Mobilitie shall comply with number pooling and requirements of the North American
Numbering Plan Administrator,as set forth in Commission Order No.30425;
2.Mobilitie shall provide necessary reports,and contribute as appropriate to the Idaho
Universal Service Fund,Idaho Telecommunications Relay System,and Idaho
Telecommunications Service Assistance Program;and
3.Mobilitie shall comply with all future reporting requirements deemed appropriate by the
Commission for competitive telecommunications providers.
Respectfully submitted this day of November 2014.
Deputy Attorney General
Technical Staff:Grace Seaman
i:umisc:comments/mobtl4.1 djhgs comments
STAFF COMMENTS 2 NOVEMBER 6,2014
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 6TH DAY OF NOVEMBER 2014,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF,IN
CASE NO.MOB-T-14-01,BY MAILING A COPY THEREOF,POSTAGE PREPAID,
TO THE FOLLOWING:
VINEETHA PILLAI ETHAN ROGERS
MARASHLIAN &DONAHUE LLC GENERAL COUNSEL
1420 SPRING HILL RD MOBILITIE LLC
STE 401 2220 UNIVERSITY DR
McLEAN VA 22102 NEWPORT BEACH CA 92660
E-MAIL:vmp(comm1awgroup.corn E-MAIL:[e-mail]
*)/Z(
SECRETAY
CERTIFICATE OF SERVICE