20170518Staff 1-5 to NNI.pdf

DAPHNE HUANG
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 8372Q-0074
[phone]
IDAHO BAR NO. 8370
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Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702.59I8
Attomey for the Commission Staff
BEFORE THE IDAIIO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
NATIVE NETWORK,INC. TO PROVIDE
FACILITIES.BASED WHOLESALE LOCAL
TELECOMMUNICATIONS SERVICE
THROUGHOUT IDAHO
CASE NO. NNI.T-I7-OI
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
NATIVE NETWORK,INC.
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Daphne Huang, Deputy Attorney General, request that Native Network (Company; Native
Network) provide the following documents and information as soon as possible, but no later than
THURSDAY, JUNE 8,2017.
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 sponsor the
answer at hearing if need be. Reference IDAPA 31.01.01.228.
This Production Request is to be considered as continuing, and Native Network is
requested to provide, by way of supplementary responses, additional documents that it or any
person acting on its behalf may later obtain that will augment the documents produced.
Please provide answers to each question, supporting work papers that provide detail or
are the source of information used in calculations, and the name, job title and telephone number
FIRST PRODUCTION REQUEST
TO NATIVE NETWORK
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of the person preparing the documents. Please identifu the name, job title, location and telephone
number of the record holder.
Please provide all Excel and electronic files on CD with formulas activated.
REQUEST NO. l: In an e-mail response to Staff inquiry regarding Native Network's
status in Oregon and Washington, the response from Carey Roesel was, "[t]he Company is
pursuing registration in OR and WA." Please provide additional details regarding the status of
the registration process in these two states, including docket numbers, if applicable.
REQUEST NO. 2: On the website of Native Network Inc. (nativenetwork.com), the
Company profiles three case studies involving Spokane Tribes, Tulalip Tribes, and Forest
County Potawatomi. All three cases appear to describe the implementation of tribally-owned
networks. Please explain if these case studies reflect the Native Network's business plan in
Idaho. If not, how will the Idaho business plan be different?
REQUEST NO. 3: In the cases mentioned in Request No. 2, who currently owns the
infrastructure? And, does Native Network have any responsibility for service quality and
customer complaints?
REQUEST NO. 4: The federal Communications Act of 1934, as amended requires that
the FCC establish mechanisms to fund certain programs such as the universal fund and
telecommunications relay service. To accomplish this the FCC requires telecommunications
carriers and certain other providers of telecommunications (including VoIP service providers) to
report each year to file FCC Form 499. Wholesale providers are also required to file the FCC
Form 499A Annual Reseller Certifications. Generally speaking, "resellers" incorporate
wholesale services into their own offerings and are expected to contribute to the federal universal
support mechanism. See FCC 12-134. On the Company website under "We Can Help" and
"What We Do," it appears Native Network more closely resembles a contractor that builds
infrastructure for its clients. Once the infrastructure is in place and the entity/reseller begins
selling services, who will be responsible for the completion and filing of the federal Form 499?
FIRST PRODUCTION REQUEST
TO NATIVE NETWORK 2 MAY 18,2017
REQUEST NO.5: Who will be responsible for remitting payments to the Idatro
Universal Service Fund, Telephone Relay Service, Idaho Telecommunications Service
Assistance Program, and 9l I programs?
Dated at Boise, Idalro, this l#uurofMay 20t7.
Deputy Attorney General
Technical Staff: Grace Seaman
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FIRST PRODUCTION REQUEST
TO NATIVE NETWORK 3 MAY t8,2017
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 18TH DAY OF MAY 2017,
SERVED THE FOREGQING FIRST PRODUCTION REQUEST OF THE
CoMMISSION STAFF TO NATM NETWORK, INC., IN CASE NO. NNI-T-17-01,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
CAREY ROESEL CONSULTANT
TECHNOLOGIES MGMNT INC
SUITE 3OO
2600 MAITLAND CTR PKWY
MAITLAND FL 32751
E-MAIL: [e-mail]
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CERTIFICATE OF SERVICE