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Home My WebLink About20110222Joint ITA-CTC 1-50 to TFW.pdfCynthia A. Melilo (ISB No. 5819) GIVENS PURSLEY LLP 601 West Banr'iock Street P.O. Box 2720 Boise, 10 83701 Telephone: (208) 388..1200 Facsimile: (208) 388-1300 E-Mail: cam(ggivenspursley.com Attorneys for Idaho Telecom Allance Idaho Public Utilties Commission Office of the SecretaryRECEIVED FEB 1 8 2011 Boise, Idaho Molly O'Leary (lSB No. 4996) Richardson & O'Leary PLLC 515 Nort 27th Street P.O. Box 7218 Boise, 10 83707 Telephone: (208) 938-7900 Facsimile: (208) 938-7904 E-Mail: molly(gnchardSönandolear:.com Attorneys for CTC Telecom, Inc. BEFORE THE IDAHO PUBLIC SERVICE COMMISSION IN THE MATTR OF THE APPLICATION OF APPLICANT TRACFONE WIRELESS, INC. FOR DESIGNATION AS AN ELIGIBLE TELECOMMUNICATIONS CARRIER CASE NO.: TFW-T-09-1 FIRST JOINT PRODUCTION REQUEST OF THE IDAHO TELECOM ALLIANCE AND CTC TELECOM, INC., DBA eTC WIRELESS, TO TRACFONE WIRELESS, INC. The Idaho Telecom Allance, by and through its attorney of record, Givens Pursley LLP, and CTC Telecom, Inc., dba CTC Wireless (formerly dba Snake River PCS), by and .through its attorney of record, Richardson & O'Leary, PLLC, jointl request that TracFone Wireless, Inc. ("TracFòne") provide the following documents and information as soon as possible, but no later than twenty-one (21) days from the date of service hereof, in accrdance with IDAPA 31.01.01.225.03. FIRST JOINT PRODUCTION REQUEST OF THE IDAHO TELECOM ALLIANCE AND CTC TELECOM. INC.. DBA CTC WIRELESS. TO TRACFONE WIRELESS, INC.-1 TFW-T -01 This Production Request is to be considere continuing, and TracFone 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. 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. Please provide a list of all partial exchanges and/or study areas in Idaho where TracFone intends to offer Lifeline service. REQUEST NO.2. Please provide financial statements and related footnotes for the years ending 2010,2009 and 2008 (audited if available). REQUEST NO.3. Please provide total TracFone and Idaho-specific revenues by type or source for the years 2010,2009 and 200. REQUEST NO.4. Please provide the total amounts of Federal low income support received for the years 2010,2009 and 2008. REQUEST NO.5. Please provide the total amounts of state low income support received for the years 2010, 2009 and 2008. REQUEST NO.6. Please provide total TracFone and Idaho-specific operating expenses by type of expenditure for the years 2010, 2009 and 2008. REQUEST NO.7. Please provide any business plans, budgets or forecasts completed in the past three years. Please provide any margin analysis or related studies showing profitabilty by product or service. FIRST JOINT PRODUCTION REQUEST OF THE IDAHO TELECOM ALLIANCE AND CTC TELECOM, INC., DBA CTC WIRELESS. TO TRACFONE WIRELESS, INC. - 2 TFW-T-09-01 REQUEST NO.8. Please describe TracFone's dividend policy. REQUEST NO.9. Please provide a list of the amount of dividends paid to the top ten (10) shareholders of TracFone the previous three (3) calendar years. REQUEST NO. 10. Please provide the average cost of the handsets TracFone provides for free to Lifeline customers. REQUEST NO. 11. Please provide the total number TracFone employees. REQUEST NO. 12. Please provide the total number of TracFone employees located in Idaho. REQUEST NO. 13. Please provide the forecasted number of TracFone employees to be located in Idaho if ETC status is obtained. REQUEST NO. 14. Please provide the copies of the reseller's agreements or contracts with T-Mobile and Verizon Wireless. REQUEST NO. 15. Please provide the total amounts paid to the above-referenced carriers for services provided in 2010, 2009 and 2008. REQUEST NO. 16. Does TracFone provide or receive services from any affliated interests, including its parent company or other subsidianes? If so, disclose the nature of those services and their related costs. Please provide a copy of any management services agreements. REQUEST NO. 17. How many customers did TracFone serve in Idaho at the end of 2010? What was the average revenue per customer per month? REQUEST NO. 18. At the end of 2010, how many total customers did TracFone serve? What was the average revenue per customer per month? FIRST JOINT PRODUCTION REQUEST OF THE IDAHO TELECOM ALLIANCE AND CTC TELECOM, INC., DBA CTC WIRELESS, TO TRACFONE WIRELESS, INC. - 3 TFW-T-09-01 REQUEST NO. 19. At the end of 2010, how many SafeUnk customers did TracFone serve? What was the amount of average low income support per customer, per month? What was the average revenue per customer per month, excluding low income support? REQUEST NO. 20. What percentage of SafeUnk customers purchase additional minutes and services and in what volumes? REQUEST NO. 21. If TracFone were granted ETC status in Idaho, how many eligible low income customers does TracFone forecast it wil obtain in the first three (3) years of service? REQUEST NO. 22. What is TracFone's customer churn rate in total and for SafeUnk customers? REQUEST NO. 23. What states have denied TracFone's request for ETC status as it relates to low income support? REQUEST NO. 24. What measures does TracFone use to monitor quality of service? Provide copies of any internal management reports showing this information for the past three (3) years. REQUEST NO. 25. Where is TracFone's customer service center located? How many people are employed at this location( s)? REQUEST NO. 26. How many SafeLink applications have been denied following venfication of eligibilty over the past three (3) years? REQUEST NO. 27. How many applications are verified against state records for eligibilty? REQUEST NO. 28. Please provide copies of all enrollment forms currently in use by TracFone for each state in which TracFone provides Lifeline subsidized cell phone service. FIRST JOINT PRODUCTION REQUEST OF THE IDAHO TELECOM ALLIANCE AND CTC TELECOM, INC., DBA CTC WIRELESS, TO TRACFONE WIRELESS. INC. - 4 TFW-T -09-01 REQUEST NO. 29. Please state, with specificity, what the current Lifeline enrollment eligibilty criteria is for Idaho. REQUEST NO. 30. Please state, with specificity, how TracFone intends to verify eligibilty in Idaho. REQUEST NO. 31. Please identify how many TracFone customers have been prosecuted for providing false information on a Lifeline enrollment form since TracFone began offering Lifeline subsidized cell phone service. For each such customer, please identify: a. in what state the customer resided at the time of their enrollment b. what the nature of their perjury was c. by whom they were prosecuted, and d. what penalty was imposed. REQUEST NO. 32. Please identify the specific type of proof TracFone Lifeline customers must provide of their income eligibilty. If such proof varies from state-to-state, please identify the type of proof required for each state. REQUEST NO. 33. Please explain TracFone's internal procedures for verifying the data provided on its customers' enrollment forms and please provide all related procedural documents. REQUEST NO. 34. To the extent TracFone uses third-party vendors to perform all or any portion of its enrollment form verification, please identify any such third-party vendors and please provide documentation detailng the number of applications that have been rejected as a result of this verification process for each calendar year that TracFone has been offering Lifeline subsidized cell phone service. FIRST JOINT PRODUCTION REQUEST OF THE IDAHO TELECOM ALLIANCE AND CTC TELECOM, INC., DBA CTC WIRELESS, TO TRACFONE WIRELESS, INC. - 5 TFW-T-09-01 REQUEST NO. 35. Please explain TracFone's internal procedures for verifying that any third-party vendors it uses for enrollment verification are accurately verifying enrollment data and please provide all related procedural documents. REQUEST NO. 36. Please describe what type of proof a TracFone applicant must provide regarding the address at which they claim to reside. REQUEST NO. 37. Please describe the procedures TracFone uses to verify that addresses provided by applicants on TracFone's enrollment forms are, in fact, residential addresses. REQUEST NO. 38. If the same address is used by more than one TracFone applicant for Lifeline subsidized "free" cell phone service, and the new applicant provides proof that the applicant is residing at the address in question, does TracFone terminate the servce of the "current subscriber" using such address? If not, why not? REQUEST NO. 39. Under what circumstances might TracFone provide Lifeline subsidized "free" cell phone service to more than one person at the same address? REQUEST NO. 40. Please explain what procedures TracFone has in place to ensure that its Lifeline customers update their eligibilty status on a regular basis. REQUEST NO. 41. Please explain what procedures TracFone has in place to verify its Lifeline customers' updated eligibilty status information. REQUEST NO. 42. Please identif all jurisdictions in which TracFone customers are not required to use their Lifeline subsidized "free" airtime minutes for calls to customer service and/or technical support. FIRST JOINT PRODUCTION REQUEST OF THE IDAHO TELECOM ALLIANCE AND CTC TELECOM, INC., DBA CTC WIRELESS, TO TRACFONE WIRELESS, INC. - 6 TFW.T-09-01 REQUEST NO. 43. Please explain what role underlying carriers have in determining whether TracFone customers in Idaho would be required to use their Lifeline subsidized "free" airtime for calls to customer service and/or technical support. REQUEST NO. 44. Please identify and explain what other factors, if any, wil determine whether TracFone customers in Idaho would be required to use their Lifeline subsidized "free" airtime for calls to customer service and/or technical support. REQUEST NO. 45. Please identify all usage that is considered usage under TracFone's "non-usage policy." REQUEST NO. 46. Are there any states other than South Carolina and Washington that do not pay $0.20 per minute for additional airtime minutes? If so, please provide documentation of what TracFone customers in such states pay. REQUEST NO. 47. Please explain how TracFone will determine the "effectiveness" of its $0.10 per additional airtime minutes offerings in South Carolina and Washington (and any other state where such a program is offered) prior to deciding whether to make that offering to its Lifeline customers in all states. REQUEST NO. 48. Customer Communications: a. Please identify all methods of communication used by TracFone to communicate with its Lifeline customers regarding rates and fees, and please identify whether all forms of communication are used for each customer communication. b. To the extent all forms of communication are not used for each customer communication from TracFone, please explain what forms are typically used and the order of priority for each such communication format. FIRST JOINT PRODUCTION REQUEST OF THE IDAHO TELECOM ALLIANCE AND CTC TELECOM, INC., DBA CTC WIRELESS, TO TRACFONE WIRELESS, INC. - 7 TFW-T-09-01 c. Please explain what determines which forme s) of communication are used in each instance. REQUEST NO. 49. Please explain, in detail, any revisions to your responses to the First Production Request of Commission Staff that are necessitated by TracFone's decision to offer an expanded Lifeline service offering in Idaho, as outlned in its August 13, 2010 Notice of Expanded Lifeline Offering. Please provide your response to this Production Request on a question-by-question basis for each Production Request set forth in the Commission Staff's First Production Requests. REQUEST NO. 50. Please provide copies of all communications (whether oral, written or otherwise) with the Idaho Public Utilties Commission that have not otherwise been published on the Commission's website. A request for the description of oral communications shall be deemed to include a request for the folloing information with respect to each of said oral communications: 1. The date and place of such communication. 2. Whether said communication was in person or by telephone. 3. A description of each persn who participated in or heard of said communication. 4. The substanc of what was said by each persn who participated in said communication. 5. A chronological description of all documents or recordings, summarizing, confirming or in any manner referring to said communication. FIRST JOINT PRODUCTION REQUEST OF THE IDAHO TELECOM ALLIANCE AND CTC TELECOM. INC., DBA CTC WIRELESS. TO TRACFONE WIRELESS, INC. - 8 TFW-T-09-01 DATED this 18th day of February 2011. GIVENS PURSLEY LLP ~lffL,Cy. A. MeUlo Attorneys for Idaho Telecm Alliance RICHARDSON & O'LEARY, PLLC FIRST JOINT PRODUCTON REQUEST OF THE IDAHO TELECOM AlIANCE AND CTC TELECOM, INC., DBA CTC WIRELESS. TO TRCFONE WIRELESS, INC.-9TF.T..9-1 CERTIFICATE OF SERVICE WE HEREBY CERTIFY that on the 18th day of February 2011, I caused to be served a true and correct copy of the foregoing by the method indicated below, and addressed to the following: Jean Jewell Idaho Public Utilties Commission 412 West Washington Street Boise, 1083702 jean.jewell(gpuc.ldaho.gov Mitchell F. Brecher Debra McGuire Mercr GREENBERG TRAURIG, LLP 2101 L Street, NW, Suite 1000 Washington, DC 20037 brecherm(§law.com memerdm(§law.com Dean J. Miler McDEVITT & MILLER LLP 420 West Bannock Street Boise, 10 83702 joe(gmcdevitt-miller.com D U.S. Mail D Overnight Mall D Hand Delivery DFax ~ Electrnic Mail D U.S. Mail D Overnight Mail D Hand Delivery DFax ~ Electronic Mail DU.S.Mail D Overnight Mail D Hand Delivery DFax ~ Electnic Mail FIRST JOINT PROOUCTION REQUEST OF THE IDAHO TELECOM ALLIANCE AND CTC TELECOM, INC., OBA CTC WIRELESS, TO TRACFONE WIRELESS, INC. -10 TFW-T .(9-1