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HomeMy WebLinkAbout20030808Discovery Requests to IAT from Citizens.pdf!, ::: c r~ l V E 0 Morgan W. Richards, ISB No. 1913 MOFFATT, THOMAS, BARRETT, ROCK & FIELDS, CHARTERED 101 S. Capitol Boulevard, 10th Floor Post Office Box 829 Boise, Idaho 83701 Telephone: (208) 345-2000 Facsimile: (208) 385-5384 mwr~moffatt.com 15-881.19 , I i- , , ,-.---- p:1,r'!r"' ~4 "'0l;.JJI-.. )!)- O 1..)0(. ; .- . UTIli i i:.~; COill,i~S:CN Attorneys for Citizens Telecommunications Company of Idaho BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE PETITION OF IA T COMMUNICATIONS , INC., d. NTCH-IDAHO, INC. OR CLEAR TALK FOR DESIGNATION AS AN ELIGIBLE TELECOMMUNICATIONS CARRIER Case No. GNR-03- IN THE MATTER OF THE APPLICATION OFNPCR, INe. d.a. NEXTELPARTNERS SEEKING DESIGNATION AS AN ELIGIBLE TELECOMMUNICATIONS CARRIER Case No. GNR-03- DISCOVERY REQUESTS TO IAT COMMUNICATIONS, INc. ("CLEAR TALK" YOU WILL PLEASE TAKE NOTICE that Citizens Telecommunications Company ofldaho hereby requests that IAT Communications, Inc. ("Clear Talk") answer, under oath, the following discovery requests within twenty-eight (28) days from the date of service hereof. Please provide a copy of the responses of Clear Talk to any discovery requests of all other parties in this proceeding. This request is ongoing. DISCOVERY REQUESTS TO IAT COMMUNICATIONS, INC. ("CLEAR TALK"BOLMT2:519714. Identify the number of current Clear Talk customers that have a billing address in each respective wire center served by Citizens in the area in which Clear Talk is seeking ETC status. Identify the number, including zero as appropriate, of current Clear Talk customers that have a billing address in each respective wire center served by Citizens in the area in which Clear Talk is not seeking ETC status. Identify the NPA-NXXs currently assigned to Clear Talk that will be used to serve customers in the area in which Clear Talk is seeking ETC status. Identify which NP A-NXXs are currently assigned to customers in each respective wire center served by Citizens in the area in which Clear Talk is seeking ETC status. Identify the location by street address of all towers/ antenna used to serve Clear Talk customers in each respective wire center served by Citizens in the area in which Clear Talk is seeking ETC status. Identify the number and address of all new cell site tower/antenna placed in service in Idaho by Clear Talk, respectively, in 2002 and 2003. For each cell site tower/antenna identified in response to Request No. identify the time frame in weeks, from the identification of a need for a cell site tower/antenna to the completion and turn up of the tower/antenna. For each cell site tower/antenna identified in response to Request No. identify any government consent, permit or approval that was required to construct or place facilities on or to the tower from federal, state or local government or regulatory authorities. Identify the time frame in weeks, from the identification of a need for a cell site tower/antenna to the receipt ofthe government consent, permit or approval for each cell site tower/antenna. DISCOVERY REQUESTS TO IAT COMMUNICATIONS, INC. ("CLEAR TALK"- 2 BOI MT2:519714. 10.Identify the number and addresses in Idaho where Clear Talk plans to build cell site tower/antenna in 2003 2004, and 2005. Differentiate the towers that would be constructed without universal service funding and with universal service funding assuming ETC designation was obtained. 11.For each cell site tower/antenna identified in response to Request No.1 0 identify the estimated time frame in weeks to complete construction and turn up of the tower/antenna for each cell site tower/antenna. 12.For each cell site tower/antenna identified in response to Request No. 10 identify any government consent, permit or approval that will be required to construct or place facilities on the tower from federal, state or local government or regulatory authorities. Estimate the time frame in weeks to obtain the government consent, permit or approval for each cell site tower/antenna. 13.For each cell site tower/antenna identified in response to Request Nos. 7 and 10, provide the capacity limits and the number of lines each is able to serve. 14.Identify any resale agreements Clear Talk currently has in place in Idaho with ILECs in the area in which Clear Talk is seeking ETC status. 15.Describe any supplemental equipment (e.g. yagi antennas) Clear Talk plans to deploy to increase its coverage area and/or enhance service to customers in the area in which Clear Talk is seeking ETC status; What is the cost to deploy; How long does it take to deploy; Will the supplemental equipment be made available to every Clear Talk customer requesting one; and DISCOVERY REQUESTS TO IAT COMMUNICATIONS, INc. ("CLEAR TALK") - 3 BOI MT2:519714. What will customers be charged for the equipment? 16.Will 3-watt phones be made available to all Clear Talk customers requesting a 3-watt phone? What will customers be charged for the 3-watt phone? 17.Will Clear Talk provide service to all requesting customers in each respective wire center served by Citizens in the area in which Clear Talk is seeking ETC status? 18.Are there any blind spots in Clear Talk's service area in Idaho that would prevent Clear Talk from providing those services it must provide to be designated an ETC? 19.Does Clear Talk need additional interconnection agreements to provide universal services throughout the areas in which Clear Talk is seeking ETC status? Please describe in detail. 20.Please describe in detail how Clear Talk terminates calls to Citizens where no interconnection agreement is in place? How is Citizens compensated for terminating this traffic? 21.Please provide a map or a chart ofthe areas ofldaho currently served or covered by Clear Talk's service, depicting maximum range boundaries and terrain limitations. 22. through: 23. What percentage of Clear Talk's service offerings will be provided resale of wireline services; and purchase of unbundled network elements form wireline telecommunications providers? What services will Clear Talk provided to its customers as an ETC that it does not currently provide in the areas it is seeking ETC status? DISCOVERY REQUESTS TO IAT COMMUNICATIONS, INc. ("CLEAR TALK") - 4 BOI MT2:519714. 24.Is Clear Talk requesting that the Commission redesignate service areas in Idaho? If yes, please explain the details of the request. 25. 26. Please describe the fax service Clear Talk provides to customers. At what transmission speed does Clear Talk's network allow for the transmission of fax and data services? 27. Idaho? 28. Can broadcast fax transmissions be sent over Clear Talk's network in Do Clear Talk customers require additional equipment to send/receive a fax over Clear Talk's network? 29.Can Clear Talk customers access the Internet via the Clear Talk Network? If so, what are the average connect speeds for Internet calls? 30. quality rules? 31. Will Clear Talk follow the Idaho Public Utilities Commission s service Does Clear Talk plan to open customer service centers in communities throughout its designated service area? 32.Does Clear Talk plan to comply with the Commission s Customer Relations Rules, including the Commission s resolution process for complaints escalated to the Commission? 33.If Citizens or another ILEC were to relinquish its designation as an ETC in any exchange in which Clear Talk seeks ETC status, could, and how would, Clear Talk substitute for the ILEC in the provision of service to all customers? DISCOVERY REQUESTS TO IAT COMMUNICATIONS, INC. ("CLEAR TALK"- 5 BOI MT2:519714. Respectfully submitted this..L:.... day of August, 2003. MOFFATT, THOMAS, BARRETT, ROCK & FIELDS, CHARTERED B Y '-J ' f2skJ, d-::.Mor an W. chards, Jr. - Of the FIrm Attorneys for Citizens Telecommunications Company of Idaho DISCOVERY REQUESTS TO IAT COMMUNICATIONS, INC. ("CLEAR TALK"- 6 BOI MT2:519714. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this gth day of August, 2003, I caused a true and correct copy of the foregoing DISCOVERY REQUESTS TO IAT COMMUNICATIONS, INc. ("CLEAR TALK") to be served by the method indicated below, and addressed to the following: Jean Jewell Idaho Public Utilities Commission 472 West Washington Street Post Office Box 83720 Boise, Idaho 83720-0074 ( ))J.S. Mail, Postage Prepaid (0 Hand Delivered ( ) Overnight Mail ( ) Facsimile Molly O'Leary, Esq. Richardson & O'Leary, PLLC 99 East State Street, Suite 200 Eagle, Idaho 83616 ( ) U.S. Mail, Postage Prepaid ( ) Hand Delivered ( ) pvernight Mail (oJ Facsimile (/u.S. Mail, Postage Prepaid ( ) Hand Delivered ( ) Overnight Mail ( ) Facsimile Sean P. Farrell, Esq. IA T Communications, Inc. NTCH-Idaho Inc., dba Clear Talk 703 Pier Avenue, Suite B, PMB 813 Hermosa Beach, California 90254 Dean J. Miller, Esq. 420 West Bannock Post Office Box 2564-83701 Boise, Idaho 83702 ( ) u.S. Mail, Postage Prepaid ( ) Hand Delivered ( ) ,.overnight Mail (v) Facsimile /u.S. Mail, Postage Prepaid ( ) Hand Delivered ( ) Overnight Mail ( ) Facsimile Philip R. Schenkenberg, Esq. 2200 First National Bank Building 332 Minnesota Street St. Paul, Minnesota 55101 Conley Ward Givens Pursley LLP 277 North 6th Street, Suite 200 Post Office Box 2720 Boise, Idaho 83701 ( ) u.S. Mail, Postage Prepaid ( ) Hand Delivered ( ) 9vernight Mail ( 0'Facsimile Lance A. Tade, Manager State Government Affairs Citizens Telecommunications Company of Idaho 4 Triad Center, Suite 200 Salt Lake City, UT 84180 (/u.S. Mail, Postage Prepaid ( ) Hand Delivered ( ) Overnight Mail ( ) Facsimile DISCOVERY REQUESTS TO IAT COMMUNICATIONS, INc. ("CLEAR TALK") - 7 BOLMT2:519714. Robert M. Nielsen 548 E Street Post Office Box 706 Rupert, Idaho 83350 Charles H. Creason, Jr. President and General Manager Project Mutual Telephone Cooperative Association, Inc. 507 G Street Post Office Box 366 Rupert, Idaho 83350 ,u.s. Mail, Postage Prepaid ( ) Hand Delivered ( ) Overnight Mail ( ) ,csimile (0U.S. Mail, Postage Prepaid ( ) Hand Delivered ( ) Overnight Mail ( ) Facsimile tjZ~~ '-.). ~(. Morgan . Richards, Jr. DISCOVERY REQUESTS TO IAT COMMUNICATIONS, INC. ("CLEAR TALK"- 8 BOI MT2:519714.