Thomas Walsh
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Exhibit No.: 1.0 Issue: Application for Designation as an Eligible Telecommunications Carrier Witness: Thomas Walsh Sponsoring Party: Illinois Valley Cellular RSA 2-I Partnership Type of Exhibit: Pre-filed Direct Testimony Docket No.: 04-0454 Date Testimony Prepared: October 27, 2004 ILLINOIS VALLEY CELLULAR RSA 2-I PARTNERSHIP ICC DOCKET NO. 04-0454 PRE-FILED DIRECT TESTIMONY OF THOMAS WALSH October 27, 2004 1 PRE-FILED DIRECT TESTIMONY 2 OF 3 THOMAS WALSH 4 APPLICATION OF ILLINOIS VALLEY CELLULAR RSA 2-I 5 PARTNERSHIP 6 7 DOCKET NO. 04-0454 8 9 Q. Please state your name and business address. 10 A. Thomas Walsh. 200 Riverfront Drive, Marseilles, Illinois 61341. 11 Q. By whom are you employed and in what capacity? 12 A. Since September of 1992, I have been employed as the General Manager of 13 Marseilles Cellular, Inc., the Network and Operating Partner for Illinois Valley 14 Cellular RSA 2-I Partnership (“IVC”). Under the terms of the Agreement 15 Establishing Illinois Valley Cellular RSA 2-I Partnership (“Partnership 16 Agreement”), one of the Partners is designated as the Network Partner with 17 responsibilities for the construction and operation of the Network and one of the 18 Partners is designated as the Operating Partner for purposes of conducting the day 19 to day operations of the Partnership. A copy of the Partnership Agreement is 20 appended hereto as Exhibit 1.1. Marseilles Cellular, Inc. has been designated as 21 both the Network and the Operating Partner for IVC since 1991. In my capacity 22 as General Manager for Marseilles Cellular, Inc., I am responsible for the overall 23 management of the IVC wireless service. 24 Q. Please describe your education. Direct Testimony of IVC RSA 2-I Exhibit 1.0 Thomas Walsh 25 A. I have a Bachelors of Science degree in Business from Northern Illinois 26 University, Dekalb, IL. 27 Q. In your capacity as General Manager for IVC, are you involved with any 28 professional associations? 29 A. Yes. IVC is a member of the Cellular Telecommunications and Internet 30 Association (“CTIA”) and the Rural Cellular Association (“RCA”). I serve on the 31 RCA Board of Directors as that Association’s Secretary and Treasurer. I also 32 chair the RCA Government and Regulatory Committee which is involved with 33 legislative and regulatory issues as they relate to the rural wireless industry. In 34 that capacity I regularly visit with members of Congress and Federal 35 Communications Commission (“FCC”) Officials to discuss the impact of 36 telecommunications legislative and regulatory initiatives on rural wireless carriers 37 and the rural communities they serve. 38 Q. What is the purpose of your testimony in this proceeding? 39 A. I am testifying in support of IVC’s Application For Designation As An Eligible 40 Telecommunications Carrier for Purposes of Receiving Federal Universal Service 41 Support Pursuant To §214(e)(2) of The Telecommunications Act of 1996 42 (“Application”) in this docket. My testimony will address four aspects of the 43 Application: (a) the IVC service offerings; (b) rate and service plans offered by 44 IVC to subscribers; (c) the requirements imposed upon ETC by Section 45 54.201(d)(2) of the FCC’s Rules to advertise, using media of general distribution, 46 the availability of and charges for the core services that are supported by federal 2 Direct Testimony of IVC RSA 2-I Exhibit 1.0 Thomas Walsh 47 universal service mechanisms, as set forth in Section 54.101(a) of the FCC’s Rules; 48 and (d) public interest considerations. 49 Q. Is IVC a certificated Telecommunications Carrier in the state of Illinois? 50 A. Yes. IVC holds a Certificate of Service Authority from the Illinois Commerce 51 Commission which was issued on September 11, 1990 in ICC Docket 90-0285. 52 Q. What type of telecommunications service does IVC provide and where? 53 A. IVC is licensed by the FCC to provide Commercial Mobile Radio Service 54 (“CMRS”) to the public as a wireless cellular service provider in a portion of 55 Illinois RSA No. 2. A copy of the IVC FCC license is appended hereto as Exhibit 56 1.2. IVC has submitted Pre-filed Direct testimony of Michael K. Kurtis which I 57 have reviewed. Mr. Kurtis has provided testimony providing some background 58 information on the formation of IVC as well as describing IVC’s FCC-licensed 59 service area. 60 Q. Do you recall that Mr. Kurtis testified as to the services that are supported by 61 Federal universal service support mechanisms under Section 54.101(a) of the 62 FCC=s Rules? 63 A. Yes. 64 Q. I am going to ask you to explain IVC’s service offerings as they relate to each 65 of the requirements identified by Mr. Kurtis. First, does IVC offer Voice- 66 Grade Access to the Public Switched Network? 67 A. Yes. As an existing cellular service provider in Illinois, IVC provides voice-grade 68 access to the public switched network. Through interconnection with incumbent 69 local exchange carriers, IVC is able to originate and terminate telephone service for 3 Direct Testimony of IVC RSA 2-I Exhibit 1.0 Thomas Walsh 70 all of its subscribers. All customers of IVC are able to make and receive calls on 71 the public switched network within the specified bandwidth identified by Mr. 72 Kurtis. 73 Q. Does IVC offer Local Usage? 74 A. IVC=s service includes local usage that allows customers to originate and terminate 75 calls within the local calling area without incurring toll charges. The service allows 76 for a bundle of local calling minutes for a flat-rated monthly charge. IVC currently 77 offers several service options that include varying amounts of local usage in 78 monthly service plans. As Mr. Kurtis has testified, to date the FCC has not 79 quantified any minimum amount of local usage required to be included in a 80 universal service offering, but has initiated a separate proceeding to address this 81 issue. IVC will comply with any and all minimum local usage requirements 82 adopted by the FCC. 83 Q. Does IVC offer the Functional Equivalent of Touch-Tone (ADTMF@) Signaling? 84 A. IVC currently uses out-of-band digital signaling and in-band multi-frequency 85 signaling that is functionally equivalent to DTMF signaling. 86 Q. Does IVC offer Single Party Service? 87 A. Yes, IVC provides a dedicated message path for the length of all customer calls. 88 Q. Does IVC offer Access to Emergency Service? 89 A. Yes. IVC customers can reach an emergency dispatch, or public safety answering 90 point (APSAP@), by dialing A911.@ IVC then routes the call to the appropriate PSAP. 91 Enhanced 911 (AE911@), which includes the capability of providing both automatic 92 numbering information (AANI@) and automatic location information (AALI@), is 4 Direct Testimony of IVC RSA 2-I Exhibit 1.0 Thomas Walsh 93 required only if a public emergency service provider makes arrangements with the 94 local provider for delivery of such information. In the wireless context, provision 95 of location information is broken down into two phases; Phase I involves providing 96 the PSAP with the location of the cell from which the 911 call originated and Phase 97 II provides the location of the originating subscriber phone to within an FCC- 98 specified accuracy. IVC’s network is capable of providing Phase I and Phase II 99 E911 services, as a function of the capabilities of each PSAP throughout the IVC 100 service area. 101 Q. Does IVC offer Access to Operator Services? 102 A. Yes. IVC currently offers its subscribers access to operator services for the 103 placement and billing of telephone calls, including collect calls, calling card calls, 104 credit card calls, person-to-person calls, and third party calls, as well as obtaining 105 related information, throughout its designated ETC service area. 106 Q. Does IVC offer Access to interexchange service? 107 A. IVC has direct interconnection to multiple access tandems for delivering traffic to 108 all offices subtending those tandems as well as direct interconnection to local 109 exchange carrier end offices where traffic levels so justify. In addition, IVC 110 provides indirect access to one or more interexchange carriers (AIXC@), for access to 111 any other exchanges. 112 Q. Does IVC offer Access to Directory Assistance? 113 A. Yes. IVC provides all of its customers with access to information contained in 114 directory listings by dialing A411@ or A555-1212.@ 115 Q. Does IVC offer Toll Limitation for Qualifying Low-Income Customers? 5 Direct Testimony of IVC RSA 2-I Exhibit 1.0 Thomas Walsh 116 A. IVC does not currently offer Lifeline or Link Up services. However, the IVC 117 network is capable of providing Toll Blocking services. Currently, IVC provides 118 Toll Blocking services for international calls. IVC will utilize the same Toll 119 Blocking technology to provide toll limitation for qualifying low-income 120 customers, at no charge, as part of its universal service offerings for Lifeline and 121 Link Up customers. 122 Q. How will IVC advertise that it is offering the core services that are supported 123 by federal universal service mechanisms as set forth in Section 54.101(a) of 124 the FCC’s Rules? 125 A. Upon grant of its Application, IVC will advertise to the public in its ETC 126 designated area that it is offering the core universal support services and the charges 127 for those services. IVC already advertises its rates and services in several media of 128 general distribution throughout its FCC-licensed service area.