200309051st Response of Nextel to Citizens.pdf

ORIGINAL
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McDEVITT & MILLER, LLP
Dean 1. Miller (ISB No. 1968)
420 West Bannock Street
O. Box 2564-83701
Boise, Idaho 83702
Phone [phone]
Facsimile [phone]
joe(illmcdevitt -miller .com
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BRIGGS AND MORGAN, P.
Philip R. Schenkenberg (MN #260551)
2200 First National Bank Building
332 Minnesota Street
Saint Paul, Minnesota 55101
Phone [phone]
Facsimile [phone]
psc h en ken berg(ill bri ggs. co m
Attorneys For NPCR, Inc. d/b/a Nextel Partners
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
In the Matter of the Petition of IA T
Communications, Inc. d/b/a NTCH-Idaho, Inc., or )
Clear Talk for Designation as an Eligible
Telecommunications Carrier
Case No. GNR-O3-
In the Matter of the Application of NPCR, INC.
d/b/a NEXTEL PARTNERS Seeking
Designation as an Eligible Teltcommunications
Carrier that may receive Federal Universal Service
Support
Case No. GNR-O3-
NEXTEL PARTNERS' RESPONSE TO REQUESTS FROM CITIZENS
TELECOMMUNICATIONS COMPANY OF IDAHO
For its responses to requests to Citizens Telecommunications Company of Idaho
Citizens ), Nextel Partners states as follows:
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REQUEST NO.
Please provide a copy of the responses of Nextel to any discovery requests of all other
parties in this proceeding. This request is ongoing.
RESPONSE:
Copies will be provided.
Person able to answer questions at hearing: Scott Peabody
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REQUEST NO.
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.
RESPONSE:
Nextel Partners currently has the following NP A-NXX-Xs in Idaho:
NP A-NXX RATE CENTER AVAILABLE BLOCK RANGES
208-243 Idaho Falls All 10 Blocks (0-
208-280 Twin Falls Blocks 0-
208-300 Rupert Blocks 0
208-471 Ketchum Blocks 0
208-573 Boise Blocks 0-, 9
208-941 Boise All 10 Blocks (0-
Person able to answer questions at hearing: Scott Peabody
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REQUEST NO.
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.
RESPONSE:
See response to Request No.
Person able to answer questions at hearing: Scott Peabody
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REQUEST NO.
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.
RESPONSE:
Nextel Partners will provide this information only subject to a protective order that
prevents its confidential company information from being available to persons with business
responsibility within Citizens or any ITA company. Such information is confidential, privileged
and a Trade Secret.
Person able to answer questions at hearing: Scott Peabody
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REQUEST NO.
Identify the number and address of all new cell site tower/antenna placed in served in
Idaho by Nextel, respectively, in 2002 and 2003.
RESPONSE:
Nextel Partners will provide this information only subject to a protective order that
prevents its confidential company information from being available to persons with business
responsibility within Citizens or any ITA company. Such information is confidential, privileged
and a Trade Secret.
Person able to answer questions at hearing: Scott Peabody
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REQUEST NO.
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.
RESPONSE:
This process can take as few as 3 months and as many as 18 months. On average, this is
approximately an 8 month process.
Person able to answer questions at hearing: Scott Peabody
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REQUEST NO. 11
For each cell site tower/antenna identified in Request No. 10 , identify the estimated time
frame in weeks to complete construction and turn up of the tower/antenna for each cell site
tower/antenna.
RESPONSE:
See response to Request No.
Person able to answer questions at hearing: Scott Peabody
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REQUEST NO. 14
Identify any resale agreements Nextel currently has in place in Idaho with ILECs in the
area in which Nextel is seeking ETC status.
RESPONSE:
None.
Person able to answer questions at hearing: Scott Peabody
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REQUEST NO. 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
What will customers be charged for the equipment?
RESPONSE:
Nextel Partners does not intend to use such supplemental equipment in Idaho. Customers
or the Company may at a later time choose to use any technology available to it to provide
service.
Person able to answer questions at hearing: Scott Peabody
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REQUEST NO. 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?
RESPONSE:
Three watt phones will be available to those who request. Nextel Partners has not
determined the prices that will charged for 3-watt phones.
Person able to answer questions at hearing: Scott Peabody
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REQUEST NO. 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?
RESPONSE:
Nextel Partners will comply with its obligation as an ETC to extend its network over time
in response to reasonable requests for service.
Person able to answer questions at hearing: Scott Peabody
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REQUEST NO. 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 an ETC?
RESPONSE:
There are no limitations that would prevent Nextel Partners from meeting its obligations
as an ETC.
Person able to answer questions at hearing: Scott Peabody
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REQUEST NO. 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.
RESPONSE:
No. Nextel Partners currently provides its Idaho customers with access to the public
switched telephone network.
Person able to answer questions at hearing: Scott Peabody
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REQUEST NO. 21
Please provide a map or a chart of the areas of Idaho currently served or covered
Nextel's service, depicting maximum range boundaries and terrain limitations.
RESPONSE:
Maps responsive to this request are attached the Direct Testimony of Scott Peabody.
Person able to answer questions at hearing: Scott Peabody
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REQUEST NO. 22
What percentage ofNextel's service offerings will be provided through:
resale of wireline services; and
purchase of unbundled network elements from wire line telecommunications
providers?
RESPONSE:
Nextel Partners does not intend to provide wireline service, and does not intend to
purchase unbundled network elements.
Person able to answer questions at hearing: Scott Peabody
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REQUEST NO. 23
What services will Nextel provide to its customers as an ETC that it does not currently
provide in the areas it is seeking ETC status?
RESPONSE:
Nextel Partners does not know the answer to this question.
Person able to answer questions at hearing: Scott Peabody
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REQUEST NO. 24
Is Nextel requesting that the Commission redesignate service areas in Idaho? If yes
please explain the details of the request.
RESPONSE:
Nextel Partners seeks a Commission order redefining each Citizens exchange as its own
ETC service area. Such redefinition would require the Commission to seek approval for the
redefinition from the FCC under 47 C.R. ~ 54.207. This is described in more detail in the
Peabody and Wood testimony.
Person able to answer questions at hearing: Scott Peabody
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REQUEST NO. 25
Please describe the fax service Nextel provides to customers.
RESPONSE:
Nextel Partners' customers cannot use a facsimile machine with their Nextel service.
Such equipment requires an analog dial tone, which is not compatible with the Nextel Partners
network.
Person able to answer questions at hearing: Scott Peabody
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REQUEST NO. 26
At what transmission speed does Nextel's network allow for the transmission of fax and
data services?
RESPONSE:
Nextel Partners' customers cannot use a facsimile machine with their Nextel service.
Such equipment requires an analog dial tone, which is not compatible with the Nextel Partners
network. Data speeds on the Nextel Partners' network are up to 56 kbps , i., comparable to dial-
up modem speeds.
Person able to answer questions at hearing: Scott Peabody
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REQUEST NO. 27
Can broadcast fax transmissions be sent over Nextel's network in Idaho?
RESPONSE:
Nextel Partners' customers cannot use a facsimile machine with their Nextel service.
Such equipment requires an analog dial tone, which is not compatible with the Nextel Partners
network.
Person able to answer questions at hearing: Scott Peabody
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REQUEST NO. 28
Do Nextel customers require additional equipment to send/receive a fax over Nextel'
network?
RESPONSE:
Nextel Partners' customers cannot use a facsimile machine with their Nextel service.
Such equipment requires an analog dial tone, which is not compatible with the Nextel Partners
network.
Person able to answer questions at hearing: Scott Peabody
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REQUEST NO. 29
Can Nextel customers access the Internet via the Nextel Network? If so, what are the
average connect speeds for Internet calls?
RESPONSE:
Yes. Subscribers of Nextel Partners' data services can access the internet and their email
from their handsets. Data speeds are up to 56 kbps, comparable to dial-up modem speeds.
Person able to answer questions at hearing: Scott Peabody
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REQUEST NO. 30
Will Nextel follow the Idaho Public Utilities Commission s service quality rules?
RESPONSE:
The stated rules do not apply to Nextel Partners. Nextel Partners will comply with all
rules that apply to its services.
Person able to answer questions at hearing: Scott Peabody
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REQUEST NO. 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?
RESPONSE:
The stated rules do not apply to Nextel Partners. Nextel Partners will comply with all
rules that apply to its service.
Person able to answer questions at hearing: Scott Peabody
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REQUEST NO. 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?
RESPONSE:
Nextel Partners has no reason to believe that any ILEC in Idaho would relinquish its ETC
designation. Any response to this request would be highly speculative. In addition, such action
would require Commission action consistent with Idaho Code 62-612. If such an unlikely event
were to occur, and the Commission ordered Nextel Partners to provide service to all consumers
in the ILEC's area , Nextel Partners would work with the Commission so that facilities would be
purchased or built during the transition period so that all consumers would continue to be served.
Person able to answer questions at hearing: Scott Peabody
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Respectfully submitted
Dated: September , 2003 i\ INC. dJb/a ~L PARTNERS
BY:
~. \~-
McDEVITT & MILLER, LLP
Dean J. Miller
420 West Bannock Street
O. Box 2564-83701
Boise, Idaho 83702
Phone [phone]
Facsimile [phone]
BRIGGS AND MORGAN, P.
Philip R. Schenkenberg (MN #260551)
Matthew Slaven (MN #288226)
2200 First National Bank Building
332 Minnesota Street
Saint Paul, Minnesota 55101
Phone [phone]
Facsimile [phone]
COUNSEL FOR APPLICANT
NPCR, INc. d/b/a NEXTEL PARTNERS
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