20080811_2328.pdf

DECISION MEMORANDUM
TO:COMMISSIONER REDFORD
COMMISSIONER SMITH
COMMISSIONER KEMPTON
COMMISSION SECRETARY
COMMISSION STAFF
LEG AL
FROM:WELDON STUTZMAN
DEPUTY ATTORNEY GENERAL
DATE:JULY 31, 2008
SUBJECT:CASE NO. SYR-08-
APPLICATION OF SYRINGA WIRELESS FOR DESIGNATION AS AN
ELIGIBLE TELECOMMUNICATIONS CARRIER
On April 30, 2008 , Syringa Wireless LLC filed an Application requesting designation
as an eligible telecommunications carrier (ETC) pursuant to Sections 214(e)(1)-(2) of the
Telecommunications Act of 1934 as amended by the federal Telecommunications Act of 1996.
The Commission is authorized to designate carriers as ETCs, and set forth requirements for
designation in Order No. 29841 issued August 4, 2005 in Case No. WST-05-The
Application states that Syringa Wireless isa commercial mobile radio service carrier providing
mobile service as defined in the federal statute, and also provides intrastate telecommunications
services. See 47 U.C. ~ 153(27) and 47 US.C. ~ 153(22). Syringa provides service in 17
counties in south and east Idaho.
Syringa s Application states that it satisfies all of the statutory and regulatory
requirements for ETC designation. Syringa asserts that it will offer the services required for
carriers to be eligible for federal Universal Service Funds, including voice grade access to the
public switched telephone network, local calling, and access to emergency services and ability to
remain functional in emergency situations. Syringa requests that it be designated as eligible to
receive all available support from the federal Universal Service Fund including support for rural
insular and high-cost areas and low-income customers in geographic areas, and that it be
approved to participate in the Lifeline program. Syringa s Application asserts that its
designation as an ETC is consistent with the public interest, convenience and necessity, and that
it is consistent with the purposes and fundamental goals of preserving and advancing universal
DECISION MEMORANDUM
service, ensuring the availability of quality telecommunications services at just, reasonable and
affordable rates, and promoting the deployment of advanced telecommunications services to
rural and high-cost areas. Syringa asserts that it satisfies the items considered by the Federal
Communications Commission when analyzing the public interest benefits of an ETC application:
(1) unique advantages and disadvantages of the competitor s service offering through a cost-
benefit analysis, (2) potential for cream skimming, and (3) impact on the federal Universal
Service Fund.
Staff recommends that the Commission approve the Application as to the non-rural
WIfe centers listed in the Application.Satisfied that the Application meets the minimal
requirements, Staff recommends that the Commission approve the Application in the rural wire
centers served by Albion Telephone Company, CenturyTel of Idaho , Custer Communications
Direction Communications, Filer Mutual, Fremont Telecom Company, Mud Lake, Project
Mutual, Citizens Communications/Frontier Communication, Silver Star-Teton and Silver Star
Communications. Staff recommends that the Commission deny the Application for the non-rural
wire centers served by Midvale Telecom Company, and Rural Telephone Company, as these
wire centers represent partial service areas.
COMMISSION DECISION
Should the Application of Syringa Wireless LLC for designation as an eligible
telecommunications carrier be approved?
~t~~
Weldon B. Stutzman
Deputy Attorney General
bls/M:SYR-O8-01 ws2
DECISION MEMORANDUM