20110701Allied 1-24 to TMW.pdf

Dean J. Miler (ISB No. 1968)
Chas. F. McDevitt (lSB No. 835)
McDEVITT & MILLER LLP
420 West Banock Street
P.O. BOX 2564-83701
Boise, Idaho 83702
Tel: [phone]
Fax: [phone]
joeWimcdevitt-miler .com
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ORIGINAL
Brooks H. Harlow
Todd B. Lantor
LUKAS, NACE, GUTIERRZ & SACHS, LLP
8300 Greensboro Drive, Suite 1200
McLean, Virgiia 22102
Tel: [phone]
Fax: [phone]
bharlowWifcclaw.com
Attorneys for Alled Wireless Communications Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APPLICATION OF T-MOBILE WEST
CORPORATION FOR DESIGNATION
AS AN ELIGIBLE
TELECOMMUNICATIONS CARRER
PURSUANT TO 47 U.S.C. §214(e)(2)
Case No. TMW-T-IO-Ol
FIRST PRODUCTION REQUEST OF
ALLIED WIRELESS
COMMUNICATIONS
CORPORATION TO T-MOBILE
WEST CORPORATION
Alled Wireless Communications Corporation ("Alled Wireless"), by and
though its attorney of record, Dean J. Miler of McDevitt & Miler, LLP, requests that T-
Mobile West Corporation (T -Mobile) provide the following documents and information.
This Production Request is to be considered as continuing and T-Mobile (also
referred to herein as "you" or "your") is requested to provide, by way of supplementar
FIRST PRODUCTION REQUEST OF ALLIED WILESS COMMUNICATIONS
CORPORATION TO T-MOBILE WEST CORPORATION-l
responses, additional documents that it or any person acting on its behalf may later obtain
that wil augment the documents produced.
For each item, please indicate the name of the person(s) preparing the answers,
along with the job title of such persons) and the witness who can sponsor the answer.
Please provide answers to each question, supporting workpapers that provide
detail or are the source of information used in calculations. T-Mobile is reminded that
responses pursuant to Commssion Rules of Procedure must include the name and phone
number of the person preparng the document, and the name, location and phone number
of the record holder and if different the witness who can sponsor the answer at hearg, if
necessar.
REQUEST NO.1: Please provide copies of all documents fied in this case with
the Commssion which included a request for confidential designation or treatment.
REQUEST NO.2: Please provide copies of all documents provided or shown to
the Commssion staff in relation to ths case.
REQUEST NQ. 3: To the extent not included in your responses to Request Nos.
1 or 2, for each of first two years of ETC designation, please provide a detailed formal
network improvement plan demonstrating how applicant wil use support fuds (all
federal support tyes except low-income support); together with all drafts and
workpapers leading to such plan. Any information in table format should also be
provided in native electronic format, preferably ExceL.
FIRST PRODUCTION REQUEST OF ALLIED WILESS COMMUNICATIONS
CORPORATION TO T-MOBILE WEST CORPORATION-2
REQUEST NO.4: By quarer, for the end of each quaer from the first quarer
of 2009 though the second quarer of2011, please provide T-Mobile's counts of eligible
lines/handsets in service in each ILEC wire center included in your application in this
case, with dis aggregated per-line support, and in each ILEC study area where support is
averaged, by residence, single-line business, and multi-line business categories. If any
ILEC has dis aggregated its support below the wire center level, the counts should also be
provided by zone. The response should be provided in native electronic formats,
preferably ExceL.
REQUEST NO.5: Please provide T-Mobile's forecast of support amount, by
type other than low-income, and by ILEC service area, that the applicant expects to
receive in the fist two years of designation, as well as an explanation of how the forecast
was derived; together with all workpapers and calculations showing how the estimates
were prepared. The response should be provided in native electronic formats, preferably
ExceL.
REQUEST NO.6: Please provide detailed information for each T-Mobile
project that wil use unversal serice support fuds, including:
A. The descrption and purpose of the project, its physical location, the ILEC
sering that area, and whether the project is a collocation site.
B. The star date and completion data (by quarer).
C. The amount of support money allocated to the project, in total and broken
down by investment and expense tyes.
FIRST PRODUCTION REQUEST OF ALLIED WILESS COMMUNICATIONS
CORPORATION TO T-MOBILE WEST CORPORATION-3
D. The amount of company's own fuds that wil be used for each supported
project
E. A brief explanation of why the carer would not make these
improvements without the availability of support fuding.
F. Quantification of resulting servce improvements by type (increased
coverage, signal strengt, capacity, etc.), population benefited, and
geographic area benefited (shown onmap(s)).
REQUEST NO.7: Please provide electronic copies in native formats maps of
T-Mobile's curent coverage in Idaho. Without limitation, each map should include
separately all layers. If multiple formats are available, please provide in all available
formats.
REQUEST NO.8: Please provide electronic copies in native formats of T-
Mobile's coverage maps showing the projected coverage upon conclusion of the USF-
fuded projects identified in your responses. Without limitation, each map should
include separately all layers. If multiple formats are available please provide in all
available formats.
REQUEST NO.9: Please provide a table of the latitudes and longitudes of each
proposed new cell site identified in T -Mobile's Network Improvement Plans. If available,
in addition to a paper copy, please provide the table in Excel (or Word) format with the
site name and degrees, minutes, and seconds for both latitude and longitude in separate
columns.
FIRST PRODUCTION REQUEST OF ALLIED WILESS COMMUNICATIONS
CORPORATION TO T-MOBILE WEST CORPORATION-4
REQUEST NO. 10: Please provide a table of the Jatitudes and longitudes of
each existing cell site ofT-Mobile or any cell site curently under constrction in Idaho.
For cell sites added within the last five years, please include the in-service or acquisition
date. For cell sites added since 2009, please include the star of constrction date and the
in-service date. For cell sites under constrction, please provide the star of constrction
date. If available, in addition to a paper copy, please provide the table in Excel (or Word)
format with the site name and degrees, minutes, and seconds for both latitude and
longitude in separate colums.
REQUEST NO. 11: For all Idaho T -Mobile cell sites completed since July 1,
2010, or curently under constrction, or in any stages of planing (including any
planing that may be contingent on any occurence, such as ETC designation), please
state by site whether any site acquisition or prelimiar engineering work has been
planed, authorized, or done for the site. If so, please produce all documents reflecting
such work, authorization, or planng.
REQUEST NO. 12: Does T -Mobile have any maps or lists of current AT&T,
Cingular, or Edge cell sites in Idaho? If so, please provide the most precise information
available, such as a table of the latitudes and longitudes or maps in native electronic
format. If available, in addition to a paper copy, please provide the table in Excel (or
Word) format with the site name and degrees, minutes, and seconds for both latitude and
longitude in separate colums.
FIRST PRODUCTION REQUEST OF ALLIED WILESS COMMUNICATIONS
CORPORATION TO T-MOBILE WEST CORPORATION-5
REQUEST NO. 13: Does T -Mobile have any maps detailing the coverage of
AT&T, Cingular, or Edge cell sites in Idaho? If so, please provide the most precise
coverage information available, such as maps in native electronic formats.
REQUEST NO. 14: Please produce copies of any reports, memos,
correspondence, or other documents relating to T-Mobile's ETC applications and
provided to aT-Mobile Board or board commttee, T -Mobile officers, or T -Mobile's
parent or affiliate corporations; including, without limiting the foregoing, any discussion
of possible relinquishment of support in relation to the proposed merger with AT&T.
REQUEST NO. 15: Please provide copies of all T -Mobile capital expenditue
budgets for Idaho prepared since 2009.
REQUEST NO. 16: Has T -Mobile prepared alternative capital expenditue
budgets for Idaho that are contingent on receipt of Federal Universal Service fuding? If
so please provide them.
REQUEST NO. 17: With regard to states where T-Mobile has been designated
an ETC:
a. When was T-Mobile's ETC designation effective?
b. How many Lifeline subscrbers does T -Mobile have?
FIRST PRODUCTION REQUEST OF ALLIED WILESS COMMUNICATIONS
CORPORATION TO T-MOBILE WEST CORPORATION-6
REQUEST NO. 18: Why did T -Mobile relinquish its ETC designations in
Tennessee and Virginia?
REQUEST NO. 19: Please admit that Philipp Hum, CEO T-Mobile USA, Inc.,
gave the following testimony before a Subcommttee of the Senate Judiciar Commttee
in May, 2011: "As data usage continues to explode, spectrm is becoming a constraint to
our,business, with T-Mobile facing spectr exhaust over the next couple of years in a
number of signficant markets. Moreover, our spectrm holdings wil not allow us to
launch LTE. T-Mobile also lacks the low band spectrm that would enable it to offer
nationwide deep in-building coverage, paricularly to reach homes in suburbs and in rual
areas."
REQUEST NO. 20: With regard to your "Response" fied with the Commission
on June 23,2011, on page 2, that "T-Mobile wil remain the designated ETC legal entity"
following the merger, please describe in detail the post-merger corporate strctue,
provide and organization char, detail all changes in control (direct or indirect) of "T-
Mobile" that mayor wil occur after the merger as a result of changed ownership or
corporate strctue, and provide copies of relevant documents, including merger
agreements.
REQUEST NO. 21: With regard to your "Response" fied with the Commssion
on June 23,2011, at page 6, that Protesters are motivated by their "financial interests"
and "profits," please state whether or not T -Mobile is motivated by financial interests and
FIRST PRODUCTION REQUEST OF ALLIED WIRLESS COMMUNICATIONS
CORPORATION TO T-MOBILE WEST CORPORATION-'
profits and explain your answers. Additionally, please provide all documents relating to
financial analyses of the impacts of grant or denial ofT-Mobile's ETC application in
Idaho.
REQUEST NO. 22: With regard to your "Response" filed with the Commssion
on June 23, 2011, beginning at page 9, regarding Idaho's possible loss of relinquished
support resulting from the AT&T merger and "T -Mobile's plans," please detail all facts
or knowledge you possess regarding AT&T's plans for ETC status and Federal USF
support after or in relation to the proposed merger. Please provide all documents that
support or relate to your answer.
REQUEST NO. 23: With regard to your "Response" filed with the Commssion
on June 23, 2011, and the discussion of the Texas case beginning on page 11, please
provide unedacted copies of all motions and briefs filed by any par in the Texas PUC
case.
REQUEST NO. 24: With regard to your "Response" filed with the Commission
on June 23,2011, and the discussion of Mr. Stephenson's Congressional testimony
beginning at page 14, please explain in detail whether and, if so, how AT&T could or
would complete the L TE build out under discussion without concurently making voice
coverage available to same areas as the LTE coverage. Please provide all documents
supporting or relating to your answer.
FIRST PRODUCTION REQUEST OF ALLIED WIRELESS COMMUNICATIONS
CORPORATION TO T-MOBILE WEST CORPORATION-8
DATED this 1 8t day of July, 2011.
MCDEVITT & MILLER, LLP
BYÙlWL
Dean J. Miler
Attorney for Alled Wireless
Communications
FIRST PRODUCTION REQUEST OF ALLIED WILESS COMMUNICATIONS
CORPORATION TO T-MOBILE WEST CORPORATION-9
CERTIFICATE OF SERVICE
I hereby certify that on the Ì- day of July, 2011, I caused to be served, via the
methodes) indicated below, tre and correct copies of the foregoing document, upon:
Jean Jewell, Secretary
Idaho Public Utilities Commssion
472 West Washington Street
P.O. Box 83720
Boise, ID 83720-0074
jj ewell§puc.state.id. us
Hand Delivered
U.S. Mail
Fax
Fed. Express
Email
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DavidDaggett, Esq.
DAVIS WRIGHT TREMANE, LLP
1202 Third Ave., Suite 2200
Seattle, WA 98101-3045
daviddaggettØldwt.com
Hand Delivered ~I.
U.S. Mail ~I.
Fax ~I.
Fed. Express ~I.
Email .t
Cynthia A. Melilo, Esq.
Givens Pursley LLP
601 N. Banock Street
P.O. Box 2720
Boise, ID 83701
camØlgivenspursley.com
Hand Delivered ~I.
U.S. Mail ~I.
Fax ~I.
Fed. Express ~I.
Email p
Hand Delivered ~I.
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Fax ~I.
Fed. Express ~I.
Email ~
Hand Delivered ~I.
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Fax ~I.
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Email J4
Mark P. Trinchero, Esq.
DAVIS WRIGHT TREMANE, LLP
1300 SW Fift Ave., Suite 2300
Portland, OR 97201
marktrinchero Cidwt. com
Teri Ohta, Esq.
Senior Corporate Counsel
T-Mobile USA, Inc.
12920 SE 38th Street
Bellevue, W A 98006
teriotaØltmobile.com
BY: J1x
McDEV ~ & ~ILLER LLP
FIRT PRODUCTION REQUEST OF ALLIED WILESS COMMUNICATIONS
CORPORATION TO T-MOBILE WEST CORPORATION.IO