20181212Supplemental to Petition.pdf

MARASHLIAN
& DONAHUE,pu-c
lHE COMMLAW GROUP
December t2,20L8
VIA Overnioht Courier
Diane Hanian
Secretary
Idaho Public Utilities Commission
472 W. Washington Street
Boise, lD 83702
Viasat Carrier Seruices, Inc.; Case No. VCS-T-1801 - Supplement to Petition
for Designation as an Eligible Telecommuniations Carrier
Dear Ms. Hanian:
On behalf of Viasat Carrier Seruices, Inc. ('Viasast'), transmitted herewith is one (1) original
and seven (7) copies of Viasat's Supplement to Petition for Designation as an Eligible
Telecommunications Carrier in Idaho f'PetitionJ.
Please date-stamp the duplicate of this filing and return it in the self-addressed, postage-
prepaid envelope. Should you have any questions regarding the contents of this letter, please do not
hesitate to contact the undersigned.
Respectfu I ly su bm itted,
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Enclosures
Michael P. Donahue
Counsel for Viasat Carier Seruices, Inc.
P 703.71 4.1 300
t703.563.6222
cc:Daniel Klein, Telecom Analyst
Telecomm u nications Section, Ida ho Public Uti I ities Com mission
via e-mail to [e-mail]
secreta ry@ p uc. ida ho. gov
1420 Spring Hill Road, Suite 401
Mclean, Virginia 22102
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STATE OF IDAHO
BEFORE THE IDAHO PUBLIC UTITMES COMMISSION
EI)
tntJ JJ
In the Matter of
Petition of Viasat Carrier Seruices, Inc.
for Designation as an Eligible Telecommunications
Carrier to Receive Connect America Fund Phase II
Auction (Auction 903) Support for Voice and
Broadband Seruices
)
)
)
)
)
)
)
Case No. VCS-T-1801
SUPPLEMENT TO PETMON OF
vrAsAT CARRTER SER\IrCES, rNC. FOR LTMTTED DESIGNATION AS AN ELTGTBLE
TELECOMMUNICATIONS CARRIER TO RECEIVE CONNECT AMERICA FUND PHASE II
AUCTTON (AUCTTON 903) SUPPORT FORVOTCE AND BROADBAND SERVTCES AND
REOUEST FOR EVPEDITED CONSIDERATION
Viasat Carrier Services, Inc. ('Viasat" or the "CompanyJ respectfully submits this Supplement
to its Petitionl for designation as an Eligible Telecommunications Carrier C'ETC') to the Idaho Public
Utilities Commission f'CommissionJ pursuant to section 21a(e)(2) of the Communications Act of
1934, as amended (the "ActJ,2 Sections 54.20L and 54.2023 of the rules and regulations of the
FederalCommunications Commission ('FCC'), and in accordance with the Commission's requirements
as set forth in Order No. 29841 ('ffC Ordef)l The Supplement provides additional information
related to the Petition as requested by Staff.
Specifically, Viasat supplements the Petition with the following information:
(1) the status of Viasat's notifications to Tribal Authorities residing in the Idaho Census
Blocks for which Viasat submitted winning bids in the CAF II Auction (the "Idaho
Census Blocks') that it filed its Petition;
l Viasat's Petition was submitted to the Commission on September 27,2078. The Supplement is submitted
pursuant to Commission Rule of Procedure 66, which provides petitioners the opportunity to amend petitions
submitted to the Commission. See IDAPA 31.01.01.066.
2 47 U.s.c. $ 214(e)(2).
3 47 C,F.R. 55 54.201 and 54.202.
4 In the Matter of the Appliation of WWC Holding Co., Inc. d/b/a Cellularone Seeking Designation as an
Eligible Telecommunications Carrier that may Receive Federal Universal Seruice Support, Order No. 29841
(August 4,2005) ('ETC Order").
1
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(2) pricing for Viasat's local usage plans; and
(3) the status of Viasat's request for qualification to operate as a business in Idaho.
In shoft, Viasat notified all of the applicable Tribal Authorities, can clarifu the pricing of its local usage
plans and, is qualified to operate in the State of Idaho. These matters are expounded upon below.
I. STATUSOFTRIBALAUTHORITYNOTIFICATIONS
Viasat notified all of the Tribal Authorities located in the Idaho Census Blocks that it was able
to determine required notification under the FCC's Rules. Viasat identified approximately L27 census
blocks as located on land governed by a Tribal Authority within Idaho of the 1392 Idaho Census
Blocks for which Viasat was awarded CAF II funding.
Specifically, Viasat was awarded funding for Idaho Census Blocks within land governed by
the Coeur d'Alene Tribe, within The Duck Valley Indian Reseruation under the authority of the
Shoshone-Paiute Tribes, within the Foft Hall Reservation under the authority of the Shoshone-
Bannock Tribes, and on land under the authority of the Nez Perce Tribe. Viasat notified the Coeur
d'Alene Tribe on October 9, 2018; the Shoshone-Paiute Tribes within the Duck Valley Indian
Reservation on October 72,20L8; the Shoshone-Bannock Tribes within the Foft Hall Reseruation on
October 10, 2018; and the Nez Perce Tribe on October L2, 20L8. Copies of the notifications are
attached hereto as Exhibit A.
The notification Viasat sent to the Coeur DAlene Tribes via overnight courier was accepted
and signed for on October 11, 2018. The confirmation of receipt for this notification is included in
Exhibit A.
2
The three other Tribal Authorities indicated they received the notifications by sending
"Stamped & Received" copies of the Petition back to Viasat (the Shoshone-Paiute Tribes within The
Duck Valley Indian Reservation (notification stamped as received on November 1, 2018); the
Shoshone-Bannock Tribes within the Foft Hall Reseruation (notification stamped as received on
October 15, 2018) and the Nez Perce Tribe (notification stamped as received on December 11,
2018)). Copies of these receipt notifications are also included in Exhibit A.
Viasat will keep the Commission apprised of discussions with the Tribe Authorities as they
develop.
II. PRICING OF LOCAT USAGE PLANS
Viasat is currently conducting market research to determine what mix of seruices potential
customers would prefer and the terms upon which the seruices are offered. Viasat will make seruices
available based on customer demand in each market. As a result, Viasat has not yet determined
specific details of its rates and seruices to be offered under the CAF II program. However, customers
in Idaho who order standalone voice seruice will receive a VolP-enabled voice service that provides
unlimited calling within the U.S. and Canada for a fixed monthly price. Viasat will update the
Commission and supplement its Petition as soon as its seruice offerings are more fully formulated.
To provide the Commission with an outline of what Viasat's local usage plans may look like,
Viasat respectfully directs the Commission's attention to the FCC's Urban Rate Survey benchmarK.s
For CAF Il-supported services, Viasat's rates and seruices must be consistent with these benchmarks.
For example, the FCC's 2018 average urban monthly rate floor for voice seruices is $25.20/month
and the reasonable comparability benchmar( two standard deviations above the urban average, is
$45.38.6
s Please see https://www.fcc,gov/general/urban-rate-suryey-data-resources for additional information about
these requirements.
6 Furthermore, the FCC's Urban Rate Suruey benchmark for broadband seruices depends upon the speed
and usage allowance, For a broadband service that provides 25 Mbps downstream and 3 Mbps upstream
and offers a minimum usage allowance of 250 GB per month, the benchmark is $94.01.
3
Because of the different service requirements of the CAF II Auction, Viasat has not determined
whether its service offerings under that program will be the same as those currently offered by its
parent company, Viasat, Inc, Nonetheless, for comparison, Viasat, Inc.'s current pricing for voice
seruice is $19.99/month (in addition to any charges for broadband Internet access seruice) for 6
months and $29,99/month thereafter.
ur. sTATus oF coRPoRATE QUALTFTCATTON
Viasat received its Ceftificate of Registration to transact business in the State of Idaho from
the Secretary of State on September 26,2018. A copy of the Ceftificate of Registration is attached
hereto as Exhibit B.
ry. CONCLUSION
As in the Petition, Viasat again respectfully requests that the Commission designate Viasat as
an ETC in the State of Idaho for the Idaho Census Blocks on an expedited basis and order such other
relief as may be appropriate.
Respectfu I ly su bm itted,
Viasat Carrier Services, Inc.
l\J"{OL
By:
Michael P. Donahue
Nathaniel J. Hardy
Marashlian & Donahue, PLLC
1420 Spring Hill Road, Suite 401
Tysons, VA22L02
Tel: 703-7L4-1319
Fax: [phone]
E-Mail : [e-mail]
[e-mail]
4
Dated: December 72, 2018.
LIST OF EXHIBITS
Exhibit A - Tribal Authority Notifications.
Exhibit B - Corporate Qualification
a II
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ililil MARASHLIAN
& DONAHUE,pT-uc
THECOMMLAW GROUP .l
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October 9, 2018
The Honorable Chief James Allan, Tribal Chairman
Coeur DAlene Tribe
850 A. Street
Plummer, Idaho 83851
Viasat Carrier Seruices, Inc.
Notice of Pendino Elioible Telecommunications Carrier Aoolication
Dear Tribal Chairman Allan:
On behalf of Viasat Carrier Services, Inc., ('Viasat" or the "Company), transmitted herewith is
Viasat's Application for Limited Designation as an Eligible Telecommunications Carrier C'ilC") in the State
of Idaho ('StateJ. This letter is designed to provide the Coeur DAlene Tribe with notice of the filing of
the application(s).
For your convenience, this packet includes copies of the application(s) that Viasat filed with the
State.
The Communications Act of 1934, as amended, provides that"only an eligible telecommunications
carrier designated under section 214(e) shall be eligible to receive specific federal universal service
support," 47 U.5.C.254(e). Viasat has filed its application(s) for ETC status in order to receive federal
universal service support already awarded to Viasat by the Federal Communications Commission ("FCC').
The funding will be used to expand telecommunications service offerings in un-/underserued census
blocks on the Coeur D Alene Tribe, as detailed in the enclosed application(s). Viasat seeks ETC status
for the census block locations stated in the exhibit to the enclosed application(s). This includes 3 Census
Block Groups on the Coeur DAlene Tribe.
Please acknowledge receipt of this notice by date-stamping the extra copy of this notice, and
returning it to me in the self-addressed, stamped envelope for that purpose. Any questions regarding
this notice should be directed to the undersigned. Viasat stands ready to cooperate with the Coeur
DAlene Tribe regarding any applicable regulatory requirements.
RE
1420 Spring Hill Road, Suite 401
MrLean,Virginia 22102
P 703.i'I4.1300
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Respectfu I ly submitted,
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Michael P. Donahue
Marashlian & Donahue, PLLC
1420 Spring Hill Road, Suite 401
McLean, VA22t02
Tel: 703-714-t3L9
Fax: [phone]
Email : [e-mail]
Counsel for Viasat Carrier Seruices, Inc.
Enclosures
5l!,r lie I COMMLAWGROUP.COM
L IIr,rr:*-
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The Honorable Chief James Allan, Tr
PLUMMER, ID US 83851
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ilil MARASHLIAN
& DONAHUE,pul-c
THE CA&'I"'LAW GROUP ;
October 12,2018
The Honorable Theodore "Ted" Howard, TribalChairman
Shoshone-Paiute Tribes of The Duck Valley Indian Reseryation
1036Idaho State Highway 51
Owyhee County, Idaho 83604
SIAMP & RETIJRN
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Viasat Carrier Services, Inc.
Notice of Pendino Elioible Telecommunications Carrier Aoolication
Dear Tribal Chairman Howard:
On behalf of Viasat Carrier Services, Inc., ("Viasat" or the "Company"), transmitted herewith is
Viasat's Application for Limited Designation as an Eligible Telecommunications Carrier C'EIC] in the State
of Idaho C'State'J. This letter is designed to provide the Shoshone-Paiute Tribes of The Duck Valley
Indian Reservation with notice of the filing of the application(s).
For your convenience, this packet includes copies of the application(s) that Viasat filed with the
State.
The Communications Act of 1934, as amended, provides that "only an eligible telecommunications
carrier designated under section 214(e) shall be eligible to receive specific federal universal service
support." 47 U.S.C. 254(e). Viasat has filed its application(s) for ETC status in order to receive federal
universal service support already awarded to Viasat by the Federal Communications Commission |'FCC").
The funding will be used to expand telecommunications service offerings in un-/underserved census
blocks on the Shoshone-Paiute Tribes of The Duck Valley Indian Reservation, as detailed in the enclosed
application(s). Viasat seek ETC status for the census block locations stated in the exhibit to the enclosed
application(s). This includes 3 Census Block Groups on the Shoshone-Paiute Tribes of The Duck Valley
Indian Reseryation.
Please acknowledge receipt of this notice by date-stamping the extra copy of this notice, and
returning it to me in the self-addressed, stamped envelope for that purpose. Any questions regarding
this notice should be directed to the undersigned. Viasat stands ready to cooperate with the Shoshone-
Paiute Tribes of The Duck Valley Indian Reseruation regarding any applicable regulatory requirements.
RE
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Enclosures
Respectfully subm itted,
tl,k,f,jil"
Michael P. Donahue
Marashlian & Donahue, PLLC
1420 Spring Hill Road, Suite 401
Mclean, VA22L02
Tel: [phone]
Fax: [phone]
Email: mod@commlawq rouo,com
Counsel for Viasat Carrier Services, Inc.
COMhILAWGROUP.COM
ilil MARASHLIAN
& DONAHUE,plt-c
THECOMMLAW GROUP
October 10, 2018
The Honorable Nathan Small, Chairman
Shoshone-Bannock Tribes of the Foft Hall Reseruation
Post Office Box 306
Fort Hall, Idaho 83203-0306
STAMP & RETIJRT\
I
RE:Viasat Carrier Services, Inc.
Notice of Pending Elioible Telecommunications Carrier Aoolication
Dear Chairman Small:
On behalf of Viasat Carrier Seruices, Inc., ("Viasat" or the "Company'), transmitted herewith is
Viasat's Application for Limiteci Designation as an Eligible Telecommunications Carrier 0FfC1 in tiie State
of Idaho ('State'). This letter is designed to provide the Shoshone-Bannock Tribes of the Foft Hall
Reservation with notice of the filing of the application(s).
For your convenience, this packet includes copies of the application(s) that Viasat filed with the
State.
The Communications Act of 1934, as amended, provides that "only an eligible telecommunications
carrier designated under section 214(e) shall be eligible to receive speciflc federal universal service
support." 47 U.S.C. 254(e). Viasat has filed its application(s) for ETC status in order to receive federal
universal service support already awarded to Viasat by the Federal Communications Commission ('FCCJ.
The funding will be used to expand telecommunications seruice offerings in un-/underserued census
blocks on the Shoshone-Bannock Tribes of the Foft Hall Reservation, as detailed in the enclosed
application(s). Viasat seeks ETC status for the census block locations stated in the exhibit to the enclosed
application(s). This includes zl4 Census Block Groups on the Shoshone-Bannock Tribes of the Fort Hall
Reservation.
Please acknowledge receipt of this notice by date-stamping the extra copy of this notice, and
returning it to me in the self-addressed, stamped envelope for that purpose. Any questions regarding
this notice should be directed to the undersigned, Viasat stands ready to cooperate with the Shoshone-
Bannock Tribes of the Fort Hall Reseruation regarding any applicable regulatory requirements.
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Enclosures
Respectfu lly submitted,
MichaelP. Donahue
Marashlian & Donahue, PLLC
1420 Spring Hill Road, Suite 401
Mclean, VA22102
Tel: 703-7L4-1319
Fax: [phone]
Email : [e-mail]
Counsel for Viasat Carrier Services, Inc.
COMMLAWGROUP.COM l---_
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October 12, 2018
The Honorable Shanon F. Wheeler, Chairman
Nez Perce Tribe
Post Office Box 305
Lapwai, Idaho 83540-0305
RE: Viasat Carrier Seruices, Inc.
Notice of Pendino Elioible Telecommunications Carrier Apolication
Dear Chairman Wheeler:
On behalf of Viasat Carrier Services, Inc., ('Viasat" or the "C.ompany"), transmitted herewith is
Viasat's Application for Limited Designation as an Eligible Telecommunications Carrier C'E[C) in the State
of Idaho ('State). This letter is designed to provide the Nez Perce Tribe with notice of the filing of the
application(s).
For your convenience, this packet includes copies of the application(s) that Viasat filed with the
State.
The Communications Act of 1934, as amended, provides that"only an eligible telecommunications
carrier designated under section 214(e) shall be eligible to receive specific federal universal service
support." 47 U.S.C. 254(e). Viasat has filed its application(s) for ETC status in order to receive federal
universal seruice support already awarded to Viasat by the Federal Communications Commission ['FCC").
The funding will be used to expand telecommunications seruice offerings in un-/underserued census
blocks on the Nez Perce Tribe, as detailed in the enclosed application(s). Viasat seeks ETC status for the
census block locations stated in the exhibit to the enclosed application(s). This includes 68 Census Block
Groups on the Nez Perce Tribe.
Please acknowledge receipt of this notice by date-stamping the extra copy of this notice, and
returning it to me in the self-addressed, stamped envelope for that purpose. Any questions regarding
this notice should be directed to the undersigned. Viasat stands ready to cooperate with the Nez Perce
Tribe regarding any applicable regulatory requirements.
Wcloel
[,EC I I 2018
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1420 Spring Hill Road, Suite 401
Mcl"ean, Virginia 22102
p 703.714.1300
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Enclosures
Respectfully submitted,
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Michael P. Donahue
Marashlian & Donahue, PLLC
1420 Spring Hlll Road, Suite 401
Mclean, VA22702
Tel: [phone]
Faxz 703-563-6222
Email : [e-mail]
Counsel for Viasat C-arrier Services, Inc.
COMMLAWGNOUP.COM
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State of ldaho
CERTIFICATE OF REGISTRATION
OF
VIASAT CARRIER SERVICES, ING.
File Number C 2'19406
l, LAWERENCE DENNEY, Secretary of State of the State of ldaho, hereby
certrfy that an application for Foreign Registration Statement, duly executed pursuant to
the provisions of the ldaho Uniform Business Organization Code, has been received in
this office and is found to conform to law.
ACCORDINGLY and by virtue of the authority vested in me by law, I issue this
Certificate of Registration to transact business in this State and attach hereto a
duplicate of the application for such cefiificate.
Dated: September 26, 2018
r
Office of the Secretary of State
-t
By
SECRETARY OF STATE
FOREIGN REGISTRATION STATEMENT
Tltle 30, Chaptor2l, ldaho Code
Fillng fee: $100 typed, $120 not typed
Complete and submitthe form in duolicate.
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1. The nanp of the antity ts:Viasat Canier Sewices, lnc,
2, The narne which lt shall use in ldaho is:
3, Select the typ€ of entity you wish to regi
E Business corporstion
EI Nonprofrt Corpo ration
E Limited Liabillty Partnership
EI Llmlted Liabllity Company
(Enlera nrm€ hera only ;f yot' are requi|.ed io adopl an rliehal€ nama)istsr:
E General Partnership
E Goneral Goopexative Association
E LimiteO Partnership (lnoluding a llmited tiability limited partnership
E Statutorytrusl, Business Trust, or Common-lal Buslness Trust
E other:(Us€ "Orher' only ir you' brEign lype is tis'leC abJve. afi,l €ntar lhe typo here.)
4, Jurisdlotion of formallon:Delaware
{Frcviae rhe donresilc llnEdtcilon lyher€ th! Bolity was termld)5. The address of its principal office ls:
6155 El Camino
349 lnvemess Drlve South. Englewood, CO 80112
([,lail!ng Adirese if diiferent)
6. The address of lts dornestlc prlncipal offioe (lf requlrad by the lgws of lhe JurFdlctlon of formstlon) ls:
(Street AdCressl
(Mailing AdCress. it Cifteiofir)
7. The mailing address to whlch conespondence should be addressad. if difierent from ltem 5, is:
(Address)
B. The name ot lhe regblered agent and street address of registered agant in ldaho:
Corporation Sarvice Company, 12550 W. Explorer Drive, Suite 100, Bolse, l0 83713(rarn{f (Ad.lress)
9. The name. capac,ty, and mailing address of at lesst one gorr€mor:
Robert Blair Pras/sec 61sg El camino Real, carlsbad cA s2009
(Na,rai
Shawn Duffy
(CapadU')
VPlTreas
(AcCre$s)
6155 El Camino Real, Carlsbad CA 92009
(Capa:ityl
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