20121016Staff 1-11 to Budget.pdf

DONALD L. HOWELL, II
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
P0 BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 3366
ir- It NI 2: L8
( dLS
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
BUDGET PREPAY, INC. D/B/A BUDGET )
MOBILE FOR DESIGNATION AS AN )
ELIGIBLE TELECOMMUNICATIONS )
CARRIER PURSUANT TO 47 U.S.C. § 214(e)(2). )
)
)
CASE NO. BPP-T-12-01
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
BUDGET PREPAY, INC.
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Donald L. Howell, II, Deputy Attorney General, requests that Budget Prepay, Inc. d/b/a Budget
Mobile (Company; Budget) provide the following documents and information as soon as
possible, but no later than TUESDAY, NOVEMBER 6, 2012.
This Production Request is to be considered as continuing, and the Company is requested
to provide, by way of supplementary responses, additional documents that it or any person acting
on its behalf may later obtain that will augment the documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title and telephone number of
the person preparing the documents. Please identify the name, job title, location and telephone
number of the record holder.
FIRST PRODUCTION REQUEST
TO BUDGET PREPAY 1 OCTOBER 16, 2012
In addition to the written copies provided as response to the requests, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Based on the Idaho Secretary of State's Certificate of Authority,
Budget Prepay Inc. (Budget) has been authorized to do business in Idaho since 2007. Please
indicate the number of current customers in Idaho.
REQUEST NO. 2: Exhibit 3 of the Application explains the Company's federal Lifeline
Offering. Please confirm whether it is Budget's intent in this Application to seek a limited ETC
designation as a Lifeline-only company?
REQUEST NO. 3: On page 22 of the Application, the Company indicates it remits the
ITSAP and 911 /E91 1 fees. Which Idaho counties currently receive the emergency remittances?
When did the Company begin remitting the ITSAP fees?
REQUEST NO. 4: Please provide a summary of the formal complaint by Verizon
against Budget Prepay that is currently before the FCC.
REQUEST NO. 5: Please indicate if any other formal complaints are under review by
the FCC, a court, or any state Commissions.
REQUEST NO. 6: On page 3 of the Compliance Plan, Budget lists three affiliates:
Silver Creek Long Distance, Inc., MyMinutes.com , Inc., and Bluebird Wireless, Inc. Is this a
current list of affiliates?
REQUEST NO. 7: On page 13 of the Application, Budget states that it has COWs and
SatCOLTS that are available to deploy in an emergency situation. Please indicate if these are
owned by Budget and if any are located in Idaho.
FIRST PRODUCTION REQUEST
TO BUDGET PREPAY 2 OCTOBER 16, 2012
REQUEST NO. 8: On page 12 of the Application, Budget describes its customer
service network and the N+1 network. Please explain if Budget will have any company-owned
network facilities in Idaho.
REQUEST NO. 9: On page 12 and 13 of the Application, Budget describes its call
centers and the availability of technical support. Where are the customer service and the
technical support centers located?
REQUEST NO. 10: On page 14 of the Application, Budget states that it will use "resold
services and its own facilities." Please describe the facilities that will be used in Idaho.
REQUEST NO. 11: On page 12 and 13 of the Compliance Plan, Budget describes its
Retail Stores and Retail Agents. Please explain if the Company will have any stores or agents in
Idaho and their location(s) if applicable.
il
DATED at Boise, Idaho, this 1(0
/1./
day of October 2012.
iii-rog I Donald L. H ell, II
Deputy Attorney General
Technical Staff: Grace Seaman
i:umisc:prodreq/bppt12. I dhgs prod req I
FIRST PRODUCTION REQUEST
TO BUDGET PREPAY 3 OCTOBER 16, 2012
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 16TH DAY OF OCTOBER 2012,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO BUDGET PREPAY, INC., IN CASE NO. BPP-T-12-01,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
PAMELA S HOWLAND
HOLLAND & HART LLP
P0 BOX 2527
BOISE ID 83701-2527
E-MAIL: [e-mail]
THORVALD A NELSON
SARA KERKHOFF RUNDELL
HOLLAND & HART LLP
6380 S FIDDLERS GREEN CIRCLE
STE 500
GREENWOOD VILLAGE CO 80111
E-MAIL: [e-mail]
[e-mail]
TODD B LANTOR
LUKAS NACE GURIERREZ & SACHAS
STE 1200
8300 GREENSBORO DR
McLEAN VA 22102
E-MAIL: [e-mail]
SECRETAR
CERTIFICATE OF SERVICE