20110701Staff 1-23 to NCI.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 6864
RECEIVED
2Uff JUl -, PM 2= 3'
IDAHO
UìlLlTlES
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION)
OF NEXUS COMMUNICATIONS, INC. ) CASE NO. NCI-T-11-01
FOR DESIGNATION AS AN ELIGIBLE )
TELECOMMUNICATIONS CARRER IN )
THE STATE OF IDAHO. ) FIRST PRODUCTION REQUEST
) OF THE COMMISSION STAFF TO
) NEXUS COMMUNICATIONS, INC.
)
)
The Staff of the Idaho Public Utilties Commission, by and through its attorney of record,
Neil Price, Deputy Attorney General, requests that Nexus Communications, Inc. (Company;
Nexus) provide the following documents and information as soon as possible, but no later than
FRIDAY, JULY 22, 2011.
The Company is reminded that responses pursuant to Commission Rules of Procedure
must include the name and phone number of the person preparing the document, and the name,
location and phone number of the record holder and if different the witness who can spònsor the
answer at hearing ifneed be. Reference IDAPA 31.01.01.228.
This Production Request is to be considered as continuing, and Nexus is requested to
provide, by way of supplementary responses, additional documents that it or any person acting
on its behalf may later obtain that wil augment the documents produced.
FIRST PRODUCTION REQUEST TO
NEXUS COMMUNICATIONS 1 JULY 1,2011
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.
Please provide all Excel and electronic fies on CD with formulas activated.
REQUEST NO.1: Based on the Secretary of State's document, Nexus has been
operating in Idaho since March 21, 2011. Please verify if the Company has any current Idaho
customers.
REQUEST NO.2: Please explain how Nexus collects from current customers and
remits fees for the Idaho Telephone Service Assistance Program (ITSAP) or plans to collect and
remit fees for the program when the customers are actually served.
REQUEST NO.3: On page 1 of the Application, Nexus states that it seeks ETC
designation exclusively for Lifeline/Link Up ("Low Income") support. Please verify that the
Company is referring to federal support of these programs.
REQUEST NO.4: On page 2 and 3 of the Application, the Company states it,
"proposes to serve consumers in the Designated Service Area through wireless technology."
Please identify the services (Lifeline, Link Up, or both) offered in each of the states noted in
footnote 4, page 2 of the Application where only wireless service is provided.
REQUEST NO.5: On page 4 of the Application, the Company states that it wil provide
the nine supported services through a combination of its own facilities and the resale of another
carrier's services. Please provide the name of the underlying carrier.
REQUEST NO.6: Please provide a detailed schematic of the Company's network in
Idaho. Clearly indentify the Company's portion of the network from the underlying carer's.
FIRST PRODUCTION REQUEST TO
NEXUS COMMUNICATIONS 2 JULY 1,2011
REQUEST NO.7: Please provide a copy of the underlying carrier's resale agreement
and coverage map.
REQUEST NO.8: On page 5 of the Application, Nexus states it wil provide access to
both 911 and E911 services to the extent the local governent has implemented such services.
Please explain how the Company intends to collect the fees from Lifeline customers to support
these services. Please include a description of how 911 and E911 funds are collected and paid to
the appropriate Idaho counties.
REQUEST NO.9: On page 7 of the Application, Nexus describes how it plans to
provide services throughout its proposed designated area. Please explain if Nexus or its
underlying carrier wil provide the six identified service improvement solutions.
REQUEST NO. 10: On page 8 of the Application, the Company states that it will
remain functional in emergencies. Please explain how this wil be accomplished. Include the
measures that wil be undertaken by Nexus and those that wil be taken by its underlying carrier.
REQUEST NO. 11: On page 8 of the Application, Nexus states that its President,
Steven Fenker, wil serve as the direct contact for all consumer complaints. Please provide more
detail, including hours that Mr. Fenker wil be available, consumer contact number, etc.
REQUEST NO. 12: On page 9 of the Application, Nexus asks for certain waiver of
ETC requirements. If Nexus is a facilities-based company in Idaho, please explain in more detail
why the Commission should exempt the Company from annual submission of its network
improvement and maintenance plan, regardless of high-cost support.
REQUEST NO. 13: On page 9 of the Application, Nexus states that it "will offer
service on a prepaid or pay-as-you-go basis." Please explain in more detaiL. Wil the service
include a handset? Wil monthly recurring costs be assessed? Wil a one-time set up fee be
assessed? Please identify all calling features that wil be included.
FIRST PRODUCTION REQUEST TO
NEXUS COMMUNICATIONS 3 JULY 1,2011
REQUEST NO. 14: Please explain how Lifeline customers wil establish service.
REQUEST NO. 15: If a one-time set up fee is planed, please identify the Company's
costs to establish new service and explain if non-Lifeline customers are assessed the same fee.
REQUEST NO. 16: If applicable, please explain how Nexus wil handle roaming
charges.
REQUEST NO. 17: Please explain in detail the Company's Lifeline monthly statement
procedures (reloading minutes, assessment of fees, etc.).
REQUEST NO. 18: Please provide a copy of the Lifeline customer service agreement.
REQUEST NO. 19: Please explain what safeguards Nexus wil establish to avoid
duplicate services.
REQUEST NO. 20: Please explain how Nexus monitors inactivity. For example, how
wil the Company know if a Lifeline customer is no longer using its service?
REQUEST NO. 21: Please provide a copy of the most curent financial statements that
are available for Nexus.
REQUEST NO. 22: Please provide a Nexus organizational char with names of key
management personnel.
REQUEST NO. 23: Please indicate if the Company has been the subject of any formal
or informal investigation by any state or federal agency or the Universal Service Administration
Company (USAC).
FIRST PRODUCTION REQUEST TO
NEXUS COMMUNICATIONS 4 JULY 1,2011
DATED at Boise, Idaho, this ttday of July 2011.
rs~
Neil Price
Deputy Attorney General
Technical Staff: Grace Seaman
i:umisc:prodreq/ncitl I.npgs prod reqI
FIRST PRODUCTION REQUEST TO
NEXUS COMMUNICATIONS 5 JULY 1,2011
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 1ST DAY OF JULY 2011, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
TO NEXUS COMMUNICATIONS, INC., IN CASE NO. NCI-T-II-0l, BY MAILING A
COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DANIELLE FRAPPIER
BRIAN A NIXON
DAVIS WRIGHT TREMAINE
1919 PENNSYLVANIA AVE NW
STE 800
WASHINGTON DC 20006
E-MAIL: daniellefrappier(fdwt.com
brianixon(fdwt.com
STEVEN FENKER, PRESIDENT
NEXUS COMMUNICATIONS INC
3629 CLEVELAND AVE
STEC
COLUMBUS OH 43224
E-MAIL: sfenkerl(fearthlink.net
)-(cc
SECRETARY
CERTIFICATE OF SERVICE