Hadley, Ryan E **** This Is an EXTERNAL Email. Exercise Caution. DO NOT Open Attachments Or Click Links from Unknown Senders Or
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Hadley, Ryan E From: Liane Steffes <[email protected]> Sent: Friday, June 15, 2018 4:56 PM To: Comments, Urc; Heline, Beth E. Cc: Jeremy Fetty; [email protected] Subject: IUSF-Broadband Study - Comments of INECA Attachments: INECA - GAO 2018-3 - Comments of INECA with Attachments.PDF **** This is an EXTERNAL email. Exercise caution. DO NOT open attachments or click links from unknown senders or unexpected email. **** Good Afternoon: Attached please find the comments of INECA responsive to the study topics set forth in the Commission’s GAO 2018-3 (IUSF-Broadband Study). Kind regards, Liane K. Steffes 251 N. Illinois Street, Suite 1800 | Indianapolis, Indiana 46204 Phone: 317-269-2500 | www.parrlaw.com This email originated from the law firm Parr Richey Frandsen Patterson Kruse LLP. The information contained in this email may be privileged and confidential and is intended solely for the use of the addressee(s) indicated above. Anyone receiving this email in error should notify the sender by telephone and destroy the original. 1 COMMENTS ON BEHALF OF INDIANA EXCHANGE CARRIER ASSOCIATION, INC. TO THE INDIANA UTILITY REGULATORY COMMISSION REGARDING IUSF-BROADBAND STUDY Comments of Indiana Exchange Carrier Association, Inc. Page 1 of 12 COMMENTS ON BEHALF OF INDIANA EXCHANGE CARRIER ASSOCIATION, INC. TO THE INDIANA UTILITY REGULATORY COMMISSION REGARDING IUSF-BROADBAND STUDY The Indiana Exchange Carrier Association, Inc. (“INECA”) and its member companies are dedicated to the promotion of state-of-the-art telecommunications facilities and services throughout rural Indiana. The purpose of INECA is to advocate for its member companies on federal and state issues, to educate government leaders, as well as the public at large, on the importance of modern telecommunications to rural communities and to ensure that voice, broadband and video services comparable to those available in urban and suburban areas are available in the rural areas of Indiana at affordable prices. INECA consists of 33 local exchange companies1 that service thousands of telephone access lines throughout rural Indiana. In addition to providing quality telephone service, the companies and their affiliates also provide a broad array of telecommunications services. These include broadband Internet services, long-distance services, and in many cases, video, wireless, security, and information technology services. The INECA companies play a significant role in the economy and the well-being of the communities they serve. These companies make millions of dollars in infrastructure investments annually and employ hundreds of Hoosiers. 1 INECA’s membership includes: Bloomingdale Home Telephone Company, Inc.; Citizens Telephone Corporation; Clay County Rural Telephone Cooperative, Inc. d/b/a/ Endeavor Communications; Craigville Telephone Company Inc.; Daviess-Martin Rural Telephone Corporation d/b/a RTC Communications; Geetingsville Telephone Company Inc.; Hancock Rural Telephone Corporation d/b/a NineStar Connect; Ligonier Telephone Co., Inc.; Monon Telephone Company Inc.; Miles Communications, Inc. d/b/a Enhanced Telecommunications Corp.; Mulberry Cooperative Telephone Company, Incorporated d/b/a Mulberry Telephone Company; New Lisbon Telephone Company Inc.; New Paris Telephone Inc.; Northwestern Indiana Telephone Company Inc. d/b/a Nitco; Perry- Spencer Rural Telephone Cooperative Inc. d/b/a PSC; Pulaski White Communications, Inc. d/b/a Lightstream; Rochester Telephone Company Inc.; Southeastern Indiana Rural Telephone Cooperative Inc. d/b/a SEI Communications; Smithville Telephone Company, Incorporated d/b/a Smithville Communications; Swayzee Telephone Company, Inc. d/b/a Swayzee Communications Corp.; Sweetser Rural Telephone Company Inc.; TDS Telecom Companies (Camden Telephone Company Inc., Communications Corporation of Indiana, Communications Corporation of Southern Indiana, Home Telephone Company Inc., Home Telephone Company of Pittsboro Inc., Merchants and Farmers Telephone Company d/b/a TDS Telecom-Hillsboro., S & W Telephone Company, Inc., Tipton Telephone Company Inc., Tri-County Telephone Company Inc., West Point Telephone Company, Incorporated); Washington County Rural Electric Telephone Cooperative Inc. d/b/a Tele-Media Solutions; and Yeoman Telephone Company Inc. Comments of Indiana Exchange Carrier Association, Inc. Page 3 of 12 IUSF-Broadband Study In GAO 2018-3, the Indiana Utility Regulatory Commission (the “Commission”) invited service providers, customers, and interested stakeholders to provide written comments on the study topics set forth below. INECA hereby provides its comments to those study topics. Study Topic 1 -The types of service on which the Indiana Universal Service Funds (“IUSF”) surcharge is imposed. Response - The IUSF surcharge is imposed on intrastate retail communications services, examples of which include, but are not limited to, the following: • Local service • Service establishment charges • Custom calling services • Intrastate subscriber line charges • Intrastate long distance • Directory assistance • Non-published number fees • Paging The IUSF surcharge is not imposed on interstate or non-telecommunications services, such as: • Interstate long distance • Interstate subscriber line charges • Wholesale services • Voicemail • Directory advertising • Video services • Internet access or broadband services At this time, INECA supports maintaining the status quo regarding the types of service upon which the IUSF surcharge is imposed. Comments of Indiana Exchange Carrier Association, Inc. Page 4 of 12 Study Topic 2 - The types of service for which disbursements from the IUSF may be used. Response: Currently there is no limitation on what type of services for which IUSF disbursements can be used. INECA supports maintaining the status quo in this respect. Study Topic 3 - The eligibility requirements for service providers to receive disbursements from the IUSF. Response: The Commission’s March 17, 2004 Order in Cause No. 42144 approved a settlement agreement that created the IUSF (the “Settlement Agreement”). The eligibility requirements for service providers to receive disbursements from the IUSF, as set forth in the Settlement Agreement, are as follows: Disbursement Eligibility: a) Designation as an ETC (eligible telecommunications carrier); b) Offer the services and functionalities identified by the FCC’s rules described in 47 C.F.R. g 54.10 1(a) adopted by the IURC in its order in Cause No. 40785 dated October 28, 1998, which are: i. Voice grade access to the public switch network; ii. Local usage; iii. Dual multi-frequency signaling or its equivalent; iv. Single party service or its functional equivalent; v. Access to emergency services; vi. Access to operator services; vii. Access to interexchange service; viii. Access to directory assistance; and ix. Toll control services for qualifying low-income consumers. c) Benchmark Rates: RLECs (rural local exchange carriers) required to set rates at a minimum rate level for residential and single-line business basic local exchange service; and d) Qualification test: the passing of a “Qualification Test” required for disbursements from the IUSF absent special circumstances completed from Comments of Indiana Exchange Carrier Association, Inc. Page 5 of 12 information provided within the RLECs’ annual reports to the Commission or, with respect to those RLECs not within Commission jurisdiction, from their year-end “Part 32” financial statements prepared in compliance with FCC orders INECA supports maintaining the status quo with respect to current eligibility requirements to receive disbursements from the IUSF. Study Topic 4 - Broadband deployment (expansion and improvement of access to broadband services). Response: INECA membership has been at the forefront of broadband deployment in rural areas of Indiana, experiencing success in deploying broadband in and outside of their ILEC territories. However, the INECA members face significant challenges in broadband deployment, primarily from a financial perspective. See below for information from certain INECA members regarding broadband deployment projects and the costs thereof (please note, such projects are not necessarily inclusive of all of a member’s broadband projects), and see also the Indiana Broadband and Technology Association’s 2018 Indiana Report on Broadband Progress, attached hereto as Attachment C, and Vantage Point Solutions’ report on Deploying a Broadband Network – From Start to Finish (and Beyond), outlining procedures associated with deployment and upkeep of broadband-capable networks, attached hereto as Attachment D. NineStar Connect. NineStar Connect was born of a merger between Hancock Telecom Indiana Rural Telephone Company and Central Indiana Power, an Indiana rural electric membership corporation. NineStar Connect also provides sewer and water services. Currently, it has approximately 15,000 customers in its electric division, 12,000 customers in its communication division, and 600 customers in its water and sewer division. As of April 1, 2018, 5,500 of its electric members were also communications customers. By the end of 2018, 100% of NineStar’s customers will have access to fiber to the home technology. To the far east of NineStar territory, there are no competitors, and the area is very rural. To the far west, there are several providers that NineStar competes with, and the area is very suburban. Comments of Indiana Exchange Carrier Association, Inc. Page 6 of 12 NineStar believes that deploying fiber optics in