20130719Staff 1-7 to TRA.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
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 UTTLITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
oF TERRACOM rNC. FOR DESIGNATION ) CASE NO. TRA-T-13-01
AS AN ELIGIBLE TELECOMMUNICA- )
TIONS CARRIER IN THE STATE OF )
IDAHO.) r'msr PRoDUCTIoN REeUEST) or rHE coMMrssroN srAFF To) rnnnq.coM rNC.
)
)
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Neil Price, Deputy Attorney General, requests that TerraCom Inc. ("Company or TerraCom")
provide the following documents and information as soon as possible, but no later than
FRIDAY, AUGUST 9,2013.
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 the Company 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
TERRACOM INC.JULY 19,2OI3
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 identifu 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: On May 20,2013, Commission Staff received an email from
TerraCom that provided information regarding the Company's Scripps Howard security breach.
The Company stated that a toll-free number was established for Lifeline subscribers to call
TerraCom with questions. Please provide an update of this situation by answering the following
questions:
a. Are you aware of any issues with credit reporting or identity theft that may have
resulted from this security breach?
What, if any, action has law enforcement taken against Scripps Howard?
Do you have any additional information to report regarding your investigation into
this data breach?
REQUEST NO. 2: On June 25,2013, the FCC released Enforcement Advisory, DA
l3-1435, which reminds Eligible Telecommunications Carriers (ETCs) receiving federal
universal service support from the Lifeline program that they are liable for any conduct by their
agents, contractors, or representatives (acting within the scope of their employment) that violates
the FCC's Lifeline rules. Please verify that TerraCom understands and will comply with this
requirement and explain if the Company has made any changes to the Lifeline application
process as a result of this advisory.
REQUEST NO.3: The FCC's DA 13-1441, released on June 25,2013 states that
"despite the directives in the Lifeline Reform Order, some ETCs may be activating phones that
they represent enables use of the Lifeline-supported service for consumers prior to fully
verifying the eligibility of such consumers. ETCs must determine eligibility and may not
activate Lifeline service until completing the entire enrollment process." Please verify that
TerraCom understands and will comply with this requirement.
FIRST PRODUCTION REQUEST TO
TERRACOM INC.
b.
c.
JULY 19,2013
REQUEST NO. 4: In the above DA 1435, the FCC reiterated the Commission's rule
that Lifeline is a "non-transferable retail service offering." This is afact that must be disclosed
to the consumer and included on the certification form. Please confirm that the Company
understands this requirement and explain how the Company plans to comply.
REQUEST NO. 5: In a June 19,2013 article in the UK's Daily Mail, TerraCom was
identified as the subject of a "sting operation" regarding the misuse of the Lifeline program. The
article reports that a TerraCom spokesperson stated that "the behavior is not acceptable and swift
action will be taken to address this situation, including the employee's termination from
TerraCom." Please provide your Company's explanation of what took place and explain the
outcome of TerraCom's investigation. If TerraCom's investigation determined that the
employee was portrayed accurately, what measures are being taken to avoid such behavior in the
future?
REQUEST NO. 6: On page 9 of Exhibit D, TerraCom states that "all 611 and 911 calls
are free, and do not count against the customer's airtime." Please confirm that 611 calls are calls
made to the Company's customer service center.
REQUEST NO. 7: On page 17 of Exhibit D, the Company states, "[t]he customer's
account is activated upon completion of an outbound call. For purposes of enrollment in the
Lifeline program, TerraCom will use the date of this first completed outbound call from its call
records as the customer's effective start date." TerraCom must rely on the Lifeline customers
who sign up via Internet sales or the inbound telemarketing channels to self-initiate the activation
process. Please explain how long the service can remain inactive before the Company takes
action.
FIRST PRODUCTION REQUEST TO
TERRACOM INC.JULY I9,2OI3
DATED at Boise, Idaho, this lqh^yof July 2013.
Technical Staff: Grace Seaman
i:umisc:prodreq/tratl3.lnpgs prod reql
FIRST PRODUCTION REQUEST TO
TERRACOM INC.
il/ / //,-
Neil Price
Deputy Attomey General
fo.:
4 ruLY 19,2013
CERTIFICATE OF SERYICE
I HEREBY CERTIFY THAT I HAVE THIS 19TH DAY oF ruLY 2013,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO TERRACOM INC., IN CASE NO. TRA.T.l3.OI, BY
MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
MICHAEL C CREAMER
GIVENS PURSLEY LLP
601 W BANNOCK ST
BOISE ID 83702
E-MAIL: [e-mail]
mcon nol ly@you rtel.com.
CERTIFICATE OF SERVICE