20100412Staff 1-31 to TFW.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 6864
HECC:'
2010 12 Pr1 2: (+9
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF TRACFONE WIRELESS, INC. FOR
DESIGNATION AS AN ELIGIBLE
TELECOMMUNICATIONS CARRER.
)
) CASE NO. TFW-T-09-01
)
)
) FIRST PRODUCTION
) REQUEST OF THE
) COMMISSION STAFF TO
) TRACFONE WIRELESS, INC.
)
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Neil Price, Deputy Attorney General, requests that TracFone Wireless, Inc. (Company; TracFone
Wireless) provide the following documents and information as soon as possible, but no later than
MONDAY, APRIL 26, 2010.
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 TracFone Wireless 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 TRACFONE WIRELESS 1 APRIL 12,2010
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: TracFone Wireless, Inc. submitted an initial Application for
Designation as an Eligible Telecommunications Carrier (Case No. TFW-T-09-01), on October
29,2009. On March 1,2010, in response to Commission Order No. 30996, TracFone submitted
a Petition for Reconsideration (withdrawn on March 11,2010) along with a First Amended
Application for Designation as an Eligible Telecommunications Carrier. Please confirm that the
Amended Application replaces the initial Application in its entirety.
REQUEST NO.2: On page 4 of the Amended Application, TracFone requests ETC
designation statewide in all exchanges to the extent that its underlying cariers (AT&T Mobilty,
T-Mobile, and Verizon Wireless) have facilities and coverage. Please provide coverage maps of
the three underlying wireless service carriers.
REQUEST NO.3: Please provide a list of complete exchanges in Idaho that TracFone
intends to offer Lifeline service.
REQUEST NO.4: On page 5 of the SafeLink Wireless™ Terms and Conditions of
Service (Exhibit 12, Amended Application), it states, "You may also purchase Safelink Wireless
airtime cards at selected retail stores." Please provide a list of all Idaho retail and wholesale
point of sale locations where an Idaho Lifeline customer can purchase, disconnect, reconnect,
pay for, receive customer support for or interact with the Company concerning Lifeline services.
Please include name of business and address.
REQUEST NO.5: Please provide any other agreements, forms, documentation in
addition to the Terms and Conditions of Service that wil be required of or provided to the
Lifeline customer. Please include any applicable information from the website.
FIRST PRODUCTION REQUEST
TO TRACFONE WIRELESS 2 APRIL 12,2010
REQUEST NO.6: On page 2 of the Amended Application, TracFone states it seeks
designation "solely for the purpose of providing Lifeline service, under the trade name
SafeLinkiI Wireless, to qualifying Idaho consumers." Please explain TracFone's definition of a
qualifying Idaho Lifeline consumer, including the standards that will be used to determine
qualification.
REQUEST NO.7: On page 5 of the Amended Application, TracFone states it has been
designated as an ETC in 24 jurisdictions and is curently providing Lifeline to nearly 3 milion
qualified low-income households in 21 jurisdictions. Please explain why the Company is not
providing Lifeline in the remaining 3 jurisdictions.
REQUEST NO.8: On page 12 of the Amended Application, TracFone states,
"TracFone's Lifeline customers wil receive as part of Lifeline service 67 minutes of free
wireless service." Please explain how TracFone determined free service would equate to 67
minutes.
REQUEST NO.9: On page 9 of the Amended Application, TracFone states, it is
establishing safeguards to prevent its customers from multiple TracFone Lifeline subsidies at the
same address. Please provide a detailed explanation of these safeguards.
REQUEST NO. 10: On page 10 of the Amended Application, TracFone states, "that it
wil verify annually that its Lifeline customers are stil heads of households and that they only
receive Lifeline from TracFone." Please advise if TracFone intends to agree to conditions
imposed in other states such as: Lifeline customers wil be monitored for inactivity (no
conversation minutes and no purchase of prepaid cards). Lifeline customers wil be contacted if
the Lifeline services remain inactive over two consecutive months.
REQUEST NO. 11: On page 13 of the Amended Application, TracFone states that it
has the abilty to remain functional in an emergency through the underlying carriers' state-of-the-
art network. Please provide the three underlying cariers' emergency plans to support this
statement.
FIRST PRODUCTION REQUEST
TO TRACFONE WIRELESS 3 APRIL 12,2010
REQUEST NO. 12: On page 14 of the Amended Application, TracFone states it
provides access to operator services. Please explain if these calls are deducted from the 67 free
minutes and provide any associated charges.
REQUEST NO. 13: On page 14 of the Amended Application, TiacFone states it
provides access to directory assistance. Please explain if these calls are deducted from the 67
free minutes and provide any associated charges.
REQUEST NO. 14: On page 15 of the Amended Application, TracFone states,
"Occasional dropped calls and inconsistent coverage depending on atmospheric conditions are a
fact of life in the wireless industry." Treatment of dropped calls is also mentioned several times
in the SafeLink Terms and Conditions of Service (Exhibit 12). Please explain in detail how
these calls wil be treated as it relates to the 67 free minutes and if credit wil be provided to the
end-users under any circumstances.
REQUEST NO. 15: On page 25 of the Amended Application, TracFone states that
Lifeline customers wil be allowed to purchase additional usage cards at $.20 per minute. Please
verify if this rate for additional usage cards is the same as in other TracFone jurisdictions.
REQUEST NO. 16: IfIdaho rates (amount of free monthly minutes and cost for
additional usage cards) are different from those in other states, please explain the pricing scheme
and rationale to support the difference.
REQUEST NO. 17: Please explain if TracFone wil begin paying into the Idaho USF,
Idaho Telephone Relay Service (TRS), and Idaho Telephone Service Assistace Program
(lTSAP) funds. If not, please explain rationale for non-payment.
REQUEST NO. 18: Please explain if TracFone has been certified by all of the Idaho
PSAPs.
FIRST PRODUCTION REQUEST
TO TRACFONE WIRELESS 4 APRIL 12,2010
REQUEST NO. 19: Please explain if TracFone intends to collect reimbursements from
the Idaho Telephone Service Assistance Program (lTSAP) or if reimbursements wil be restricted
to the federal Lifeline program.
REQUEST NO. 20: Please verify if Lifeline customer calls to the SafeLink customer
service (800 number) are charged for the airtime against the free minutes. Wil Lifeline
customers be able to call customer service if minutes are depleted?
REQUEST NO. 21: Please provide TracFone's average process time of a Lifeline call
into customer service, including wait time.
REQUEST NO. 22: Excluding the website, please explain how SafeLink Wireless
Lifeline service customers wil be notified of any rate changes or program changes.
REQUEST NO. 23: Please explain the rates paid by Safelink Lifeline customers
compared to other TracFone pre-paid wireless service customers in Idaho.
(
REQUEST NO. 24: Please explain if Straight Talk is offered in Idaho. If so, please
provide cost details of the plan, including initial and additional cost per minute.
REQUEST NO. 25: Please verify how 911 and E911 funds are collected and paid to the
appropriate Idaho counties.
REQUEST NO. 26: Please provide the national average revenue per SafeLink Lifeline
customer per month for the first quarer of2010 (January, February, and March) or for the most
recent 3-month period.
REQUEST NO. 27: Please provide the national average minutes of use per month for
all TracFone Lifeline customers for the first quarter of2010 (January, February, and March) or
for the most recent 3-month period.
FIRST PRODUCTION REQUEST
TO TRACFONE WIRELESS 5 APRIL 12,2010
REQUEST NO. 28: Please explain how TracFone handles biling of parial minutes of
usage. If rounding is used, please explain.
REQUEST NO. 29: Please explain if Lifeline customers are allowed to use other brands
of handsets not furnished by TracFone.
REQUEST NO. 30: Please provide TracFone's Idaho intrastate monthly revenues for
the first quarer of2010 (January, February, and March) or for the most recent 3-month period.
REQUEST NO. 31: Please provide copies ofreseller agreements with the three
underlying cariers referenced in Request NO.2.
DATED at Boise, Idaho, this J). qay of April 2010.
¡;~
Neil Price
Deputy Attorney General
Technical Staff: Grace Seaman
i:umisc:prodreq/tfwt09. 17npgs prod req i
FIRST PRODUCTION REQUEST
TO TRACFONE WIRELESS 6 APRIL 12,2010
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 12th DAY OF APRIL 2010,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO TRACFONE WIRELESS, INC., IN CASE NO.
TFW-T-09-01, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
MITCHELL F. BRECHER
DEBRA MCGUIRE MERCER
GREENBERG TRAURIG, LLP
2101 L STREET NW SUITE 1000
WASHINGTON DC 20037
E-mail: brecherm(fgtlaw.com
mercerdm(fgtlaw.com
RICHARD B. SALZMAN
TRACEFONE WIRELESS INC
9700 NW 11 TH AVENUE
MIAMI, FL 33178
E-mail: rsalzman(ftracfone.com
~~SECRE~
CERTIFICATE OF SERVICE