20130214Staff 1-4 to TCM.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
P0 BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 6864
21 FEB i 2:50
C WV
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 TOTAL CALL MOBILE, INC. FOR ) CASE NO. TCM-T-12-01
LIMITED DESIGNATION AS AN )
ELIGIBLE TELECOMMUNICATIONS )
CARRIER. ) FIRST PRODUCTION REQUEST
) OF THE COMMISSION STAFF TO
) TOTAL CALL MOBILE, INC.
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Neil Price, Deputy Attorney General, requests that Total Call Mobile, Inc. (Company; Total Call
Mobile; TCM) provide the following documents and information as soon as possible, but no later
than THURSDAY, MARCH 7, 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 Total Call Mobile 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 TOTAL CALL MOBILE 1 FEBRUARY 14, 2013
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 files on CD with formulas activated.
REQUEST NO. 1: Ability to Remain Functional in Emergency Situations. This is a
requirement for designation as an ETC as described in revised Rule 54.202(a)(2). Total Call
Mobile, Inc. ("TCM" or "Company") addresses this requirement on page 17 of the Application
by stating that this requirement is not applicable because the Company is a reseller of its
underlying wireless network carrier and that TCM will provide its customers with the same
ability to remain functional in emergency situations as is currently provided by the ILECs to
their own customers."
TCM's underlying carrier is not an ETC in Idaho, and therefore, the Commission Staff
does not have any information or assurances regarding the company's ability to remain
functional in emergency situations. Because TCM is the entity applying for ETC designation,
please explain whether TCM or its underlying carrier has the ability to meet the following
requirements: 1) has reasonable amount of back-up to ensure functionality without external
power sources; 2) is able to reroute traffic around damaged facilities; and 3) is capable of
managing traffic spikes resulting from emergency situations.
REQUEST NO. 2: TCM addresses the Equal Access Requirement as follows:
"While Total Call is no longer required to acknowledge that it may be required to provide equal
access to long distance carriers in the event that no other ETC is providing equal access within
the service area under revised FCC Rule 54.202(a)..." This statement is confusing, because it
does not correspond with the referenced FCC Rule. Please correct or provide further
explanation.
REQUEST NO. 3: In the Application, no mention is made of how TCM intends to
participate in or remit fees to the Idaho Telephone Service Assistance Program (ITSAP) and
Idaho Emergency Communications Act (IECA or 911/E911) funds. See Idaho Code § 56-901, et
FIRST PRODUCTION REQUEST
TO TOTAL CALL MOBILE 2 FEBRUARY 14, 2013
seq. (ITSAP), Idaho Code § 31-4801, et seq. and Case No. TFW-T-09-0 1. Please provide a
statement that TCM intends to remit the required fees for all Idaho postpaid and prepaid wireless
(including Lifeline) customers.
REQUEST NO. 4: On page 4 and 5 and in Exhibit 2, TCM explains the five proposed
service plans that will be available to Lifeline-eligible customers. The Company also explains
some activities that will not deplete plan minutes (i.e. calls to customer service). Please explain
how TCM will handle other charges such as fees, taxes, and surcharges with respect to plan
minutes.
p
DATED at Boise, Idaho, this li "i day of February 2013.
Neil rice
Deputy Attorney General
Technical Staff: Grace Seamanl1-4
i:umisc:prodreq/tcmt12. lnpgs prod req I
FIRST PRODUCTION REQUEST
TO TOTAL CALL MOBILE 3 FEBRUARY 14, 2013
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 14TH DAY OF FEBRUARY 2013,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO TOTAL CALL MOBILE, INC., IN CASE NO.
TCM-T-12-01, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
ROBERT YAP
CHIEF LEGAL/ADMIN. OFFICER
TOTAL CALL MOBILE INC
1411W 190TH ST STE 700
GARDENA CA 90248
E-MAIL: [e-mail]
SECRETARY
CERTIFICATE OF SERVICE