20031110Response of Citizens to Nextel.pdf

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(0moffattcom
15-881.19
RECEIVED mFILED
2nU3 NOY 1m rM12: 33
~;
UUC
UTILITIES Cor-iHISSION
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, INc. 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-
CITIZENS TELECOMMUNICATIONS
COMPANY OF IDAHO'S RESPONSES
TO NEXTEL'S DATA REQUESTS
Citizens Telecommunications Company ofldaho hereby responds to Nextel'
Data Requests follows:
ReQuest No.Res onse1. On page 11, paragraph 4 of Mr. Tade s testimony, he refers to "the principle
of competitive parity." Identify where that principle is discussed, if at all, in the
Telecommunications Act, the FCC's Rules, or any FCC Order addressing universal service
matters.
Refer to Mr. Trampush's testimony, page 6, lines 10-13 regarding the principle of
competitive neutrality , which what was intended by use of the phrase
, "
competitive parity
CITIZENS TELECOMMUNICATIONS COMPANY OF IDAHO'
RESPONSES TO NEXTEL'S DATA REQUESTS - 1 BOI MT2:528658.
2. Provide all cost studies and other data relied on by Citizens to support its
request to disaggregate its federal universal service. Provide all filings with the FCC
requesting such disaggregation.
Objection filed. See also the attached filing that was made with the Idaho Public Utilities
Commission and USAC pursuant to FCC rules.3. Admit that the unlimited local usage is not a supported service that must be
offered by any ETC.
Admit that the FCC has not prescribed the amount of minutes of use of exchange service
(local usage) that must be provided free of charge to end users by ETCs.4. Admit that every rate plan attached to Mr. Peabody s testimony contains "
amount of local usage " as that phrase is used in 47 CFR ~ 54.101(a). If you do not admit
this, identify which rate plans you claim fail to contain "an amount of local usage" and
explain why you made such a claim.
This Request has been denied in part and admitted in part. Rate plans attached to
Mr. Peabody s testimony include various amounts of cellular minutes that are included as part of
the monthly fee for each plan. For most plans, cellular minutes include both local and long
distance usage. One reasonable outcome could be that 100% of the monthly cellular minutes are
utilized for long distance calls leaving zero minutes for free local calls.
5. Provide all supporting data for Mr. Trampush's statements on page 8, lines
19, and page 9, lines 5-11 of his testimony.
The following data is specific to Citizens ' operations in Idaho.
Citizens Telecommunications
of Idaho
Data as of 12/31/02
;...
Access Square AcLns / Sq SourceLines Miles
L.-L~I~gi!y_- -
~??
7 9 0 . 8
g~_
4?-L-.2' I Fairfield 600 68 0.87 :
~;-
BiggiQ~_
_-
902 ! 971.
~~-
4J -YYhit~t?iEq_
~~~!
~I~~?J
. .'--- - .
~.. J .....L~p~~Q_gfi~lc:I__?~J_?~4~?J _
~~_
, 6:' Sweet ,439 ! 258.3 j 1.70
'-------------;--
Newrvfeado-ws--
-----
T------------ 7 6~r
+-----
303~-i---------
---
1----
-----------------:--------
8T--
~-
C a rey---
-----------------------;----------
6 2
------------
9-:-9-
---------
3 .
'----------------: ....:g~~~~~~-
j;626- 35 .(J1_
Jg_QgQQ~lly...........
_--..- ..__?~---,-- .......?~:__-j_..... ....
4~-i-.._..._.._..
.._......._-_.__._....
' !Aberdeen 1 164; 215.5.411
OJ_- om
(!~
OJ
Ln #Exchange
CITIZENS TELECOMMUNICATIONS COMPANY OF IDAHO'
RESPONSES TO NEXTEL'S DATA REQUESTS - 2 BOI MT2:528658.
14 I ...OJ-
71 i
15.34 i
16.i_.__--22.46 i
??~..~?:
r-----
30.93 i
961
---.
12
...'....j..~...'
.I.......
14 i
1$1
i_--______1J?--17
---
Jfj9T~~~h9~~~Qc:I- 712
IQ9Ec:I~QY911~y .
...
1 , 3~9E~iQg- 1 201: McCall 5 100
. ------..-------_...._-.-.. . ------- --------
P a rI!!9______-----------------J._- 1 ,911ilder '061edale 2 190 iTotal 21 176!
; TIPS
.....
A~.Q!p~tA~~Q_-
............----.....-................--...
223.457
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! Note 2: I The only Citizens ' exchange identified in Clear Talk's petition for ETc, designation
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- ------------------------
8. Please provide to Nextel Partners copies of your answers and/or objections to
Data Requests submitted by Clear Talk dated October 20, 2003.
The information is being provided.
RESPECTFULLY SUBMITTED this 10th day of November, 2003.
MOFFATT, THOMAS, BARRETT, ROCK &
FIELDS, CHARTERED
By ~ W
6J;;'Morgan . Richards - Of the F"
Attorneys for Citizens
Telecommunications Company of Idaho
CITIZENS TELECOMMUNICATIONS COMPANY OF IDAHO'
RESPONSES TO NEXTEL'S DATA REQUESTS - 3 BOI MT2:528658.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 10th day of November, 2003, I caused a true and
correct copy ofthe foregoing CITIZENS TELECOMMUNICATIONS COMPANY OF
IDAHO'S RESPONSES TO NEXTEL'S DATA REQUESTS to be served by the method
indicated below, and addressed to the following:
Sean P. Farrell, Esq.
!AT COMMUNICATIONS, INC.
NTCH-IDAHO INC., DBA CLEAR TALK
703 Pier Avenue, Suite B, PMB 813
Hermosa Beach, California 90254
( ) U.S. Mail, Postage Prepaid
(~and Delivered
( ) Overnight Mail
( ) Facsimile
~Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
(01acsimile
(4.~. Mail, Postage Prepaid
( ) Hand Delivered
( )
Overnight Mail
( ) Facsimile
John Hammond, Deputy AG
IDAHO PUBLIC UTILITIES COMMISSION
472 West Washington Street
Post Office Box 83720
Boise, Idaho 83720-0074
Molly O'Leary, Esq.
RICHARDSON & O'LEARY, PLLC
99 East State Street, Suite 200
Eagle, Idaho 83616
Philip R. Schenkenberg, Esq.
BRIGGS AND MORGAN, P.
2200 First National Bank Building
332 Minnesota Street
St. Paul, Minnesota 55101
~ Mail, Postage Prepaid
( ) Hand Delivered
( ) Oyrnight Mail
( q-Facsimile
( ~
. Mail, Postage Prepaid
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Hand Delivered
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( )
Facsimile
Dean J. Miller, Esq.
420 West Bannock
Post Office Box 2564-83701
Boise, Idaho 83702
Conley Ward
GIVENS PURSLEY LLP
277 North 6th Street, Suite 200
Post Office Box 2720
Boise, Idaho 83701
(01J.S. Mail, Postage Prepaid
( )
Hand Delivered
( ) 9vernight Mail
(.,rFacsimile
CITIZENS TELECOMMUNICATIONS COMPANY OF IDAHO'
RESPONSES TO NEXTEL'S DATA REQUESTS - 4 BOI MT2:528658.
Lance A. Tade, Manager
State Government Affairs
CITIZENS TELECOMMUNICATIONS
COMPANY OF IDAHO
4 Triad Center, Suite 200
Salt Lake City, UT 84180
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
Mary S. Hobson
STOEL, RIVES, L.L.P.
101 South Capitol Boulevard, Suite 1900
Boise, Idaho 83702
~. Mail, Postage Prepaid
( ) Hand Delivered
( )
Overnight Mail
( ) Facsimile
~. Mail, Postage Prepaid
( )
Hand Delivered
( ) Overnight Mail
( ) Facsimile
~~ail, Postage Prepaid
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Hand Delivered
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Overnight Mail
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~S. Mail, Postage Prepaid
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Overnight Mail
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Facsimile
i\-\
Morgan W. chards
CITIZENS TELECOMMUNICATIONS COMPANY OF IDAHO'
RESPONSES TO NEXTEL'S DATA REQUESTS - 5 BOI MT2:528658.
EXHIBIT TO ANSWER NO.
RECEIVED NOV - 02003
ftt~!'.TI,
~!~
4 Triad Center, Suite 200
Salt Lake City, UT 84180
May 6, 2002
Mrs. Jean Jewell
Commission Secretary
IDAHO PUBLJC UTll.JTIES CUMMJSSJON
472 West Washington Street
Boise, ID 83720
Ref: Election of a Federal High-Cost Universal Service Support Disaggregation Plan
pursuant to the Federal Communication Commission s (FCC) Rules under Section
54.315
, "
Disaggregation and targeting of support by rural incumbent local exchange
carriers
" .
Dear Mrs. Jewell
In conformance with Section 54.315 of the FCC rules, this filing designates the
Company s election for the Path of Disaggregation for the fo11owing rural incumbent
local exchange company operating in the State ofIdaho.
Path 3: Self-Cenification for Disaggregation of Federal USF Support
Citizens Telecommunications Company ofIdaho
For the Company listed above, we have enclosed an affidavit titled "Certification of
Disaggregation Plan" which provides a statement declaring the selected path for
disaggregation the Company has selected, the name and address of the individual(s) to be
contacted concerning the plan being filed, the Study Area Code (SAC) assigned under the
Federal Universal Service Fund (USF) program, and the signature of an authorized
Corporate Officer.
In addition, we have enclosed a complete description of the rationale used to compute
and disaggregate the Federal USF support by category of support, the wire centers which
comprise each SUPPOI1 zone, the FederalUSF suppOI1 per line per wire center (Exhibit 1),
and exchange boundary maps which clearly identify the wire center boundaries of the .
designated disaggregation zones within the Company s study area.
Complete copies of this filing are also being sent to the Universal Service Administrative
Company (USAC) in accordance with the FCC rules.
An additional copy of this letter is also enclosed. Please stamp this copy received and
return it in the enclosed stamped, self-addressed envelope.
Should you have any questions on the information included in this filing, please contact
myself or the individuals listed on the enclosed "Certification of Disaggregation Plan
document.
Sincerely,
'-i~
-- ~-; -
Lance A. Tade
State Regulatory Manager
Frontier
A Citizens Communications Company
Enclosures
xc: Administrator-USAC
M. Shultz
R. Brockmann
ft,Q~!! ~f
Certification of Disaggregation PIan
The fol1owing incumbent local exchange carriers operating in the State ofIdaho, have
elected to fol1ow Path 3 , Self-Certification for Disaggregation of Federal USF Support
for the following Study Areas:
Company / Study Area Study Area Code
Citizens Telecommunications Company ofIdaho 474427
Name and Address oflndividuals to be contacted concerning this Plan:
Mr. Randall J. Brockmann
Manager - Economic Costing
Frontier Corporation
180 South Clinton Avenue
Rochester, NY 14646-0400
[phone]
Corporate Officer Signature:
Mr. Michael J. Shultz
Director - Federal Regulatory
Frontier Corporation
180 South Clinton Avenue
Rochester, NY 14646-0300
(58 777-5619
ftr~~TIs ~f'
USF Disaggregation Plan
Methodology Used for Path 2 and Path 3 Certifications
The following document describes the Disaggregation Plan and specific procedures used
by Frontier, a Citizen s Communications Company (the "Company ), to determine the
allocation of its ' Federal Universal Service Fund (USF) support per line , per Study Area.
The plan is based in part, on wire center costs as developed from forward-looking cost
proxy models.
The Company began by segregating wire centers within each Study Area into three
separate cost zones based on line cost estimates from two forward looking cost proxy
models - the Citizens Costmap Wireline Model and the HAl 5.0a model . For each of
the Company s Study Areas within the State, a forward-looking weighted average cost
per line was computed. Next, for each of the wire centers in a given Study Area, an
average cost per line, per wire center was computed. The average cost per line, per wire
center was then compared to the average cost per line for the entire Study Area. The wire
centers were then classified into three cost zones depending on the relationship between
the average cost per line for the wire center and the average cost per line for the study
area. Zone 1 includes all wire centers whose average cost per line were below 75% of the
study area average cost per line. Zone 2 includes those wire centers whose average cost
per line were between 75% and 125% ofthe study area average and Zone 3 includes all
wire centers greater than 125% of the study area average.
Next the Company calculated the estimated Federal Universal Support per line by
dividing its 2002 budgeted USF support by study area over the 12/31/2001 access line
counts. The Company disaggregated the USF support per study area between local
switching support (LSS), high cost fund (HCF), interstate access support (lAF) and long-
term support (LTS). The final a11ocation was to spread the aggregate USF support
dollars over all wire centers in the three cost zones.
I Estimated forward looking line costs for Citizen s wire centers were computed using the Company
Cost map Wireline Model, while estimated forward looking line costs for Frontier s wire centers were
compUted using results from the HAl Model , v5.0a.
The Company first anocated the LSS (assuming the Company receives this support in the
Study Area), equally by wire center over an lines in the study area. This is based on the
fact that LSS support is generally not influenced by factors such as distance and density,
both of whjch directly affect loop costs. The LSS cost per line was computed by dividing
the annual LSS expected by the total access hnes in the Study Area. The remainder
the Federal USF support (HCF, lAP & LTS) was added together for each Study Area and
anocated between cost Zones 2 and 3. These support dollars were anocated between'
Zones 2 and 3 on the basis of the ratio of the wire center s total cost per Zone to the total
combined cost of Zones 2 and 3. The wire center s total cost is equal to the average cost
per line, as computed by the cost proxy model, times the number of access lines in the
wire center. The total allocated costs to each wire center were then divided by the access
lines in that wire center to arrive at the total al1ocated USF per line, per wire center.
In summary, under the Company s plan, each wire center is classified into only one
distinct cost zone. Support on a per line basis is then based on the relationship of the
total cost of the specific wire center to the total cost of all wire centers included in that
cost zone.
Exhibit 1
Per Lin~
Per Line HCF, IAF -
Cilli Exchange Line~LSE LTS Per Line
GTG of Idaho
SAG Number: 474427
Zone 1
HMDLlDXCDSO Homedale 228
MCCLlDXCDSO McCall 209
MRNGIDXCRSO Marsing 234
WLDRIDXCRSO Wilder 123 27-
PARMIDXCDSO Parma 973
Total 11,767
Zone 2
GRVYIDXCRSO Garden Valley 282 22.27.
ABRDIDXCDSO Aberdeen 194 4.27 23.27.
CSCDIDXCDSO Cascade 666 31.35.
Total 142 26.30.
Zone 3
HRBNIDXCDSO HorseshOe Bend 721 41.45.48
RGNSIDXCDS1 Riggin~918 4.27 44.49.
DNL YIDXCDSO Donnelly 881 46.51.
FRFDIDXCDSO Fairfield 582 60.64.48
SPFDIDXCRSO Springfield 241 60.65.
CARYIDXCDS1 Carey 371 63.67.
NWMDIDXCRS1 New Meadows 786 64.68.41
SWETIDXCRS1 Sweet 428 73.77.
WHBRIDXXRS1 White Bird 367 120.124.
EKCYIDXADSO Elk City 371 237.241.
Total 666 70.74.
Total Lines 575
WASHINGTON
SPOKANE AREA
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EXCHANGE BOUNDRY. C11lZENS PROPERTY
EXCHANGE BOUNDRY. C11lZENS PROP'RTY
DWG.
SIZE
REVISION~
ISSUE WORK ORDER ENE; DRAFT
START CiTIZENS CO~~UNICATIONS
ESlABUSH DRAWlNE;.N/A N/A SLJ 6/9'
UPOATE PER IDAHO PUBUC U"J1LIrr CONNI55ION
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N/A NfA "'" 10/9
CITIZENS
communication!
DWGNAN'EXCHANGE BOUNDARY ~AP
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CW CODE
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DATE 6/99
ID-EXCHANG'
ISSUED
DATE
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