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I n the Matter of the Petition of
VCI COMPANY for Designation as
an Eligible Telecommunications Carrier Docket No.
Providing Service to Customers under the
IDAHO Telephone Assistance Plan
tic t:(li/tJ/
Petition for Designation
As An Eligible Telecommunications Carrier
VCI Company ("Petitioner ), a registered IDAHO competitive
telecommunications provider providing wireline services primarily through the
leasing of Unbundled Network Elements (UNE's), petitions the IDAHO Public
Utilities Commission ("Commission ) for an Order designating it this Petition for
Designation as an Eligible Telecommunications Carrier ("Petition ) for purposes
of providing local exchange service to IDAHO residents qualifying for the IDAHO
Telephone Assistance Plan ("ITAP"). Petitioner provides the following
information in support of its Petition:
Petitioner s Service and Contact Information
The name and address of the Petitioner is VCI Company, 3875
Steilacoom Blvd SW #A, Lakewood, WA. 98499. Petitioner is a registered
competitive carrier in the State of IDAHO.
Petitioner s registration as a competitive local exchange carrier in
Washington was approved in Docket No. UT-021524 on December 10
2002. Petitioner s application for Eligible Telecommunications Carrier
Status in Washington was approved in Docket No. UT-033014 on April 23
2003. Also approved as an ETC in Wyoming and Oregon.
Services to be Provided
(a)Petitioner provides the following services supported by the
Universal Service Fund under 47 CFR 954.101 , as adopted by the
Federal Communications Commission ("FCC') on May 8, 1997, in
CC Docket 96-45:
(1 )Voice grade access to the public switched network;
(2)
(3)
(4)
(5)
(6)
(7)
(8)
Local usage;
Dual tone multi-frequency signaling or its functional
equivalent;
Single-party service or its functional equivalent;
Access to emergency services;
Access to operator services;
Access to interexchange service;
Access to directory assistance; and
Petitioner does not provide toll limitation for qualifying low-income
consumers as its underlying carrier and UNE-P provider, Qwest
Communications, does not have the technological capability for providing toll-
limitation service. Thus, Petitioner hereby applies for an exemption from the
requirement that it provide toll limitation to qualifying low-income customers, until
such time as its underlying carrier and UNE-P provider obtains the technical
ability to provide this service as allowed under 47 CFR 9 54.101(c). Petitioner
does provide toll-blocking service.
(b)Petitioner provides these services using its own facilities or a
combination of its own facilities and resale of another carrier
service.
Service Area
VCI Company will service all Qwest Corporation exchanges in IDAHO.
FCC Compliance
VCI Company is currently an ETC in the state of Washington, Oregon and
Wyoming and complies with all FCC rules including federal high cost
support and currently provides lifeline and linkup support t9 residents of
tribal lands in areas approved for ETC status in Washington , Oregon and
Wyoming. The following specific FCC rules and a detail of how VCI
Company intends to comply is described below:
47 CFR 54.5 - terms and conditions.
47 CFR 54.7 - Sec. 54.Intended use of federal universal service support.
A carrier that receives federal universal service support shall use
that support only for the provision, maintenance, and upgrading offacili ties and services for which the support is intended.
Should VCI Company receive any federal universal service support, those
monies would be used as intended by 47 CFR 54.
4 7 C FR 5 4 . 1 0 1
VCI Company currently complies with all requirements of 47 CFR 54.101
in the state of Washington, Oregon and Wyoming as described above and
was obliged to prove compliance in order to be approved as a CLEC in
the state of IDAHO.
4 7 C FR 5 4 . 2 0 1
VCI Company complies with the definition of an ETC as required by
CFR 54.201 d (1) by servicing customers through the use of unbundled
network elements. D (2) advertising in a media of general distribution
as described in detail in this petition under 'advertising of servicesprovided. '
47 CFR 54.203 - does not apply since VCI Company only services areas
that are served by Qwest Corporation and therefore cannot be unserved
areas.
47 CFR 54.205 - does not apply since VCI Company is not requesting torelinquish it's ETC designation in areas served by more than onecarrier.
47 CFR 54.207 - VCI Company will serVlce all areas serviceable by Qwest
Corporation Service Exchanges in IDAHO.
47 CFR 54.307 - Should VCI Company receive any high cost support from
USAC, Vilaire would submit requests for support as required by 47 CFR
54.307.
47 CFR 54.313 - does not apply since it is a requirement of the state,
not VCI Company.
47 CFR 54.400 - terms and definitions
47 CFR 54.401 - VCI Company already complies with these Federal Rules
for service currently being provided in Washington, Oregon and Wyoming
and will continue to do so in IDAHO. Specifically, VCI Company will
offer reduced charges to qualifying low income customers and provide
toll limitation service and not charge deposits
AdvertisinQ of Services Provided rOAR 860-003-005(I)(Q))
Petitioner advertises the availability of the above listed services
throughout its service area in Washington, Oregon and Wyoming using a
medium of general distribution and will do so in IDAHO upon ETC
approval.
Public Interest Statement
By granting ETC designation to Petitioner , this Commission will greatly
benefit the people of IDAHO who qualify by lowering their telephone bills
and allowing more money for other needs of these citizens and their
families.
Wherefore, Petitioner respectfully requests that the Commission enter an
Order designating Petitioner an Eligible Telecommunications Carrier for the State
of IDAHO for provision of local exchange service to Customers eligible for the
ITAP.
Dated this0- day of September, 2004,
Sta rding
VCI Company
3875 Steilacoom Blvd SW #A
Lakewood , W A. 98499
Telephone: 206-419-5948
Facsimile: 253-475-6328