20131015Staff 1-13 to QLW.pdf

NEIL PRICE .'
-]-
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION 1'I :'. |}iI i ; .' ' !I : L t:
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 6864
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
oF Q LrNK WTRELESS LLC FOR ) CASE NO. QLW-T-13-01LIMITED DESIGNATION AS AN )ELIGIBLE TELECOMMUNICATIONS )CARRIER ) rrRSr pRODUCTTON REeUEST) or rHE coMMrssroN srAFF To) q LINK wIRELESS LLC
)
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Neil Price, Deputy Attorney General, requests that Q LINK Wireless LLC (Company; Q LINK)
provide the following documents and information as soon as possible, but no later than
TUESDAY, NOVEMBER 5, 2013.
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 Q LINK 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.
FIRST PRODUCTION REQUEST
TO Q LINK WIRELESS OCTOBER T5,2OI3
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 identiff 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. 1: Based on the Secretary of State documents, Q LINK's Certificate of
Authority to conduct business in Idaho was approved on December 28,2011. Please indicate if
the Company has current customers in Idaho.
REQUEST NO.2: All wireless carriers, including mobile network virtual operators
(MNVO) are required to remit fees associated with the Idaho Telephone Assistance Program
(ITSAP) and E91ll91l. Please confirm that Q LINK understands and will comply with the
remittance of ITSAP, E-911 and other applicable fees.
REQUEST NO.3: On page 5 of the Application, Q LINK states that "customers can
purchase additional bundles of minute in denominations as low as $10, $20, $35, $50, and $60."
Please explain the minutes of talk time or text messages associated with each denomination.
How do these denominations correlate with the Q LINK cards described in Exhibit F Terms and
Conditions?
REQUEST NO. 4: On page 5 of the Application, Q LINK indicates that it blocks
roaming; please verify that 911 calls will be allowed while roaming.
REQUEST NO. 5: On page 17 of the Application, Q LINK states that it "intends to
launch its retail and Lifeline wireless service simultaneously." Does Q LINK provide retail
services not tied to Lifeline? If yes, please explain.
REQUEST NO. 6: Exhibit C Confidential Financial information is redacted. Please
provide a copy of the financial information without the redaction. If you wish to keep this
FIRST PRODUCTION REQUEST
TO Q LINK WIRELESS ocToBER t5,2013
information from public review, please follow Rule 67 of the Commission's Rules of Procedure.
See IDAPA 31.01.01 Rule 67.
REQUEST NO. 7: On page 2l of the Third Amended Compliance Plan, dated July 20,
2012 (Exhibit 4), the Company states that it does not currently provide service in any state.
Please submit a current list of states where Q LINK is providing Lifeline service.
REQUEST NO. 8: On the Q LINK website,
https://qlinkwireless.com/reeister/default.aspx, the Company displays a matrix with the
headings: Free Plan Feature, Q Link Wireless, and Others. This matrix states that Q LINK offers
all the features listed such as National Long Distance, Free Minutes Every Month, Local Calls,
etc. It appears that the "Others" heading does not offer any of the features on the matrix. Please
explain.
REQUEST NO.9: On the Q LINK website, and under How Q Link's Lifeline Program
Worles, one of the bullet items states "250 FREE Minutes Every Month." The ETC Application
lists four Lifeline plans and only one of the plans includes 250 minutes. The ETC Application
Exhibit B (Q LINK WIRELESSTM Lifeline Terms and Conditions of Service) lists three plans
and only one includes 250 minutes. Please explain the inconsistencies and verify which
information source is correct for Idaho.
REQUEST NO. 10: On the Q LINK website under the About Us link, the Company
claims it is known for "superior customer support." On the Dania, Florida BBB Business
Review website: http://www.bbb.ors/south-east-florida/business-reviews/telephone-equipment-
and-systems-repair-service/q-link-wireless-in-dania-fl-90052553 the Company received a failing
grade due to the number of complaints received (70), the number of failures to respond to
complaints (18) and the number of unresolved complaints (6). Please explain.
REQUEST NO. 11: On June 25,2013, the FCC released Enforcement Advisory DA
l3-1435 and DA 13-1441. Please acknowledge that the Company has reviewed these Orders and
will comply.
FIRST PRODUCTION REQUEST
TO Q LINK WIRELESS ocToBER 15,2013
REQUEST NO. 12: The Idaho PUC understands that Puerto Rico initially denied Q
LINK's ETC Application due to negative working capital. Q LINK filed a Motion for
Reconsideration. Please provide a status on that case.
REQUEST NO. 13: Effective September 30,2013, all wireless carriers are required to
send an automatic "bounce-back" message to any consumer who tries to send a text message to a
911 center where this service is not yet available. Please verify that Q LINK and its underlying
carrier will continue complying with this requirement.
Neil Price
Deputy Attorney General
DATED atBoise,Idaho, this | fr^rof October 2[ll.
Technical Staff: Grace Seaman
i:umisc:prodreq/ncitl L Inpgs prod reqI
FIRST PRODUCTION REQUEST
TO Q LINK WIRELESS ocToBER 15,2013
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 15TH DAY oF oCToBER 2013,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
CoMMISSTON STAFF TO Q LrNK WIRELESS LLC, rN CASE NO. QLW-T-13-01,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
LANCE JM STEINHART
LANCE JM STEINHART P.C.
I 725 WINDWARD CONCOURSE
STE I5O
ALPHARETTA GA 3OOO5
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE