20030808Discovery Requests to Nextel from Citizens.pdf

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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: [phone]
Facsimile: [phone]
mwr(fYmoffattcom
15-881.19
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Attorneys for Citizens Telecommunications
Company of Idaho
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF
IAT COMMUNICATIONS, INC., d.
NTCH-IDAHO, INe. OR CLEAR TALK
FOR DESIGNATION AS AN ELIGIBLE
TELECOMMUNICATIONS CARRIER
Case No. GNR-03-
IN THE MATTER OF THE APPLICATION
OF NPCR, INC. d.a. NEXTEL PARTNERS
SEEKING DESIGNATION AS AN
ELIGIBLE TELECOMMUNICATIONS
CARRIER
Case No. GNR-03-
DISCOVERY REQUESTS TO NEXTEL
PARTNERS
YOU WILL PLEASE TAKE NOTICE that Citizens Telecommunications
Company of Idaho hereby requests that Nextel Partners ("Nextel") 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 ofNextel to any discovery requests
of all other parties in this proceeding. This request is ongoing.
DISCOVERY REQUESTS TO NEXTEL PARTNERS - 1 BOI MT2:519723,
Identify the number of current Nextel customers that have a billing
address in each respective wire center served by Citizens in the area in which Nextel is seeking
ETC status.
Identify the number, including zero as appropriate, of current Nextel
customers that have a billing address in each respective wire center served by Citizens in the area
in which Nextel is not seeking ETC status.
Identify the NP A-NXXs currently assigned to Nextel that will be used to
serve customers in the area in which Nextel 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 Nextel is seeking ETC status.
Identify the location by street address of all towers/ antenna used to serve
Nextel customers in each respective wire center served by Citizens in the area in which Nextel is
seeking ETC status.
Identify the number and address of all new cell site tower/antenna placed
in service in Idaho by Nextel, 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 of the government consent, permit or approval for each cell site tower/antenna.
DISCOVERY REQUESTS TO NEXTEL PARTNERS - 2 BOI MT2:519723,
10.Identify the number and addresses in Idaho where Nextel 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.1 0
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 Nextel currently has in place in Idaho with
ILECs in the area in which Nextel is seeking ETC status.
15.Describe any supplemental equipment (e.g. yagi antennas) Nextel plans to
deploy to increase its coverage area and/or enhance service to customers in the area in which
Nextel 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 Nextel
customer requesting one; and
DISCOVERY REQUESTS TO NEXTEL PARTNERS - 3 BOI MT2:519723,
What will customers be charged for the equipment?
16.Will 3-watt phones be made available to all Nextel customers requesting a
3-watt phone? What will customers be charged for the 3-watt phone?
17.Will Nextel provide service to all requesting customers in each respective
wire center served by Citizens in the area in which Nextel is seeking ETC status?
18.Are there any blind spots in Nextel's service area in Idaho that would
prevent Nextel from providing those services it must provide to be designated anETC?
19.Does Nextel need additional interconnection agreements to provide
universal services throughout the areas in which Nextel is seeking ETC status? Please describe
in detail.
20.Please describe in detail how Nextel 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 of the areas ofldaho currently served or
covered by Nextel's service, depicting maximum range boundaries and terrain limitations.
22.
23.
What percentage ofNextel's service offerings will be provided through:
resale of wire line services; and
purchase of unbundled network elements form wireline
telecommunications providers?
What services will Nextel provided to its customers as an ETC that it does
not currently provide in the areas it is seeking ETC status?
24.Is N extel requesting that the Commission redesignate service areas in
Idaho? If yes, please explain the details of the request.
25.Please describe the fax service N extel provides to customers.
DISCOVERY REQUESTS TO NEXTEL PARTNERS - 4 BOI MT2:519723,
26.At what transmission speed does Nextel's network allow for the
transmission of fax and data services?
27.Can broadcast fax transmissions be sent over Nextel's network in Idaho?
28.Do Nextel customers require additional equipment to send/receive a fax
over Nextel's network?
29.Can Nextel customers access the Internet via the Nextel Network? If so
what are the average connect speeds for Internet calls?
30.Will Nextel follow the Idaho Public Utilities Commission s service quality
rules?
31.Does Nextel plan to open customer service centers in communities
throughout its designated service area?
32.Does Nextel 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 Nextel seeks ETC status, could, and how would, Nextel substitute for the
ILEC in the provision of service to all customers?
Respectfully submitted this day of August, 2003.
MOFFATT, THOMAS, BARRETT, ROCK &
FIELDS, CHARTERED
By ~ f':ri c.J
Morgan W. 'chards, Jr. - Ofth FIrm
Attorneys for Citizens
Telecommunications Company of Idaho
DISCOVERY REQUESTS TO NEXTEL PARTNERS - 5 BOI MT2:519723,
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this
g\fh day of August, 2003 , I caused a true and
correct copy of the foregoing DISCOVERY REQUESTS TO NEXTEL PARTNERS 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
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( ~Overnight Mail
(v') Facsimile
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Hand Delivered
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Sean P. Farrell, Esq.
!AT Communications, Inc.
NTCH-Idaho Inc., dba Nextel
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
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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
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Lance A. Tade, Manager
State Government Affairs
Citizens Telecommunications Company of
Idaho
4 Triad Center, Suite 200
Salt Lake City, UT 84180
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Facsimile
DISCOVERY REQUESTS TO NEXTEL PARTNERS - 6 BOI MT2:519723,
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
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Morgan . Richards, Jr.
DISCOVERY REQUESTS TO NEXTEL PARTNERS - 7 BOI MT2:519723,