REDACTED—FOR PUBLIC INSPECTION February 3, 2021 VIA ECFS Marlene H. Dortch, Secretary Federal Communications Commission 45 L Street, NE Washington, DC 20554 Re: Petition of Certain Members of CCA for Waiver or, In the Alternative, Declaratory Ruling, CG Docket No. 16-145 and GN Docket No. 15-178 Dear Ms. Dortch: Southern Communications Services, Inc. d/b/a Southern Linc (“Southern Linc”) hereby submits its response to requests from the Consumer and Governmental Affairs Bureau for further information as it considers the request for waiver in the above-captioned dockets.1 Some portions of Southern Linc’s response are confidential. Under separate cover, Southern Linc has submitted the unredacted version consistent with 47 C.F.R. §§ 0.457 and 0.459 and the current procedures described in Public Notice DA 20-361. Respectfully submitted, /s/ Michael D. Rosenthal Michael D. Rosenthal Director of Legal & External Affairs Southern Linc Attach. cc: Suzy Rosen Singleton William D. Wallace 1 See Letter from Suzy Rosen Singleton, Chief, Disability Rights Office, Consumer and Governmental Affairs Bureau, FCC, to Michael Rosenthal, Southern Linc (Dec. 21, 2020). While Ms. Singleton’s letter set an initial 30-day deadline for responses, that deadline was extended to February 3, 2021. See Letter from Suzy Rosen Singleton, Chief, Disability Rights Office, Consumer and Governmental Affairs Bureau, FCC, to Alexi Maltas, Competitive Carriers Association (Feb. 2, 2021). REDACTED - FOR PUBLIC INSPECTION Response of Southern Communications Services, Inc., d/b/a Southern Linc, to December 21, 2020 Letter from Consumer and Governmental Affairs Bureau 1. Describe the IP-based voice services (e.g., VoLTE, VoWi-Fi, etc.) that the Company offers. Southern Linc’s Long-Term Evolution (“LTE”) network utilizes Internet Protocol (“IP”)-based technologies across our footprint and is a 100% greenfield LTE network deployment with no 3G fallback capabilities (for voice services or otherwise). Southern Linc offers VoLTE and VoWi-Fi as well as Push to Talk (“PTT”) services. Southern Linc’s LTE network also provides mission critical data services that serve public safety and critical infrastructure customers with many critical use cases (i.e., active monitoring and execution of Southern Company’s electric companies’ bulk power and distribution systems). Because of its expansive rural coverage and history of reliability, Southern Linc’s service is widely used by state and local public safety agencies, school districts, rural local governments, public utilities, and other emergency responders. It is also used by other commercial entities in both urban and rural areas. Southern Linc’s customer base is primarily business-to-business given its mission critical data services and PTT application. 2. In what geographic areas are the Company’s IP-based voice calling services currently available, and to how many subscribers? Southern Linc provides these services over a 127,000 square mile territory covering Georgia, Alabama, southeastern Mississippi, and the panhandle of Florida. Southern Linc offers comprehensive geographic coverage, serving the extensive rural territory within its footprint as well as major metropolitan areas and highway corridors. As of December 31, 2020, Southern Linc had ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** customers throughout its service territory, with approximately ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** of those being consumer accounts. 1 REDACTED - FOR PUBLIC INSPECTION 3. When did the Company first make IP-based voice calling services available for customers? Southern Linc's LTE network was commercially launched in September 2018 throughout its regional service territory. a. Provide a copy of any notice that the Company provided to consumers regarding the availability and limitations of IP-based voice calling services. Please see the following attachments: Attachment 1: Screenshot of Southern Linc 911 and Text to 911 Website Attachment 2: Screenshot of Southern Linc RTT FAQs Website. 4. Are the Company’s legacy networks (e.g., 2G, 3G, TDMA, GSM, CDMA, iDEN, etc.) still in use? No. Southern Linc previously used an iDEN network but it is no longer in use. Once the manufacturer stopped supporting iDEN, it was not possible for Southern Linc to continue to maintain its iDEN network. a. If no, when were the legacy networks retired in each geographic area served by the Company? Southern Linc's legacy iDEN network was commercially shut down in Alabama, Florida, and Mississippi in March 2019. Commercial services in Georgia were turned down the following month in April 2019. A very small number of legacy iDEN sites continued to 2 REDACTED - FOR PUBLIC INSPECTION operate through March 2020 for Southern Linc's electric operating company affiliates to continue to use PTT services only. b. If yes, describe what services are available on the legacy networks and whether and how customers know which network they are using. Not Applicable. c. Does the Company have plans to retire any existing legacy networks? If yes, what is that schedule? Not Applicable. d. Has the Company notified customers of the schedule for retirement of the legacy networks? If yes, provide a copy of the notice. Not Applicable. 5. Does the Company currently support TTY calling? No. However, Southern Linc supports 711 calling to Telephone Relay Service as well as Text-to- 911 for 131 PSAPs out of the 309 PSAPs within Southern Linc's footprint (as of 1/20/2021). a. Identify the geographic areas where TTY calling is supported and any limitations on such support. Not Applicable. b. What has the Company done to evaluate the effectiveness of TTY calls on its networks? Not Applicable. c. To the extent that the Company currently supports TTY calls, explain how customers know TTY is an available option. Provide copies of any notices to customers regarding TTY calling. Not Applicable. d. To the extent that the Company currently supports TTY calling, describe how a TTY call would be routed in areas where the primary network is IP-based. If TTY 911 calls are routed differently from other TTY calls, describe the difference. Not Applicable. 3 REDACTED - FOR PUBLIC INSPECTION e. Provide copies of any notices to customers regarding TTY calling, including any notices re 911 calling that address the use of TTYs. Southern Linc has maintained consumer-oriented webpages with information about 911 and RTT limitations. Please see Attachments 1 and 2 for the current versions. 6. Has the Company entered into a contract with a network vendor to deploy RTT, as defined by Part 67 of the Commission’s rules? Yes. a. If yes, identify the vendor, the date of the contract, and the projected RTT-ready date(s) specified in the contract and in any subsequent contract amendments. Provide documentation supporting your response. The Master Agreement with ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** was executed on December 10, 2019 (executed on behalf of Southern Linc by its affiliate, Southern Company Services, Inc.). Southern Linc issued purchase orders for the ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** project (“Replacement Project”) on February 24, 2020, which was supplemented by purchase orders for RTT/TTY transcoding on April 7, 2020 pursuant to a quote dated March 4, 2020. The purchase orders do not provide a projected ready date, but ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** submission in response to Southern Linc’s Request for Proposals for the Replacement Project included a ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** “representative project schedule” for the project. See Attachment 3: Master Software License Agreement 2019. b. If yes, describe the progress toward RTT deployment in the Company’s network, and provide both the vendor’s and the Company’s project status reports. Detail what elements of your network require modification to implement RTT and projected dates for completing each of those modifications. Southern Linc has made good progress toward RTT deployment in the network. There are five main categories of network changes to implement RTT on Southern Linc’s network. • First, to enable RTT-to-RTT capability within Southern Linc’s network, Southern Linc’s ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** infrastructure had to be configured, devices provisioned with development loads, and tested within the lab. Once lab validation was completed, the production network had to be configured. This work was completed around the end of June 2020. 4 REDACTED - FOR PUBLIC INSPECTION fully until early November even though it was originally expected to be complete within a few months. System Change Freezes: Due to a combination of the COVID-19 pandemic and a series of fall storms, Southern Company ***BEGIN CONFIDENTIAL*** *** END CONFIDENTIAL***. During a normal year, change freezes ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL***. With the start of the COVID-19 pandemic, Southern Company ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL***, which was extended to ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL***, so then system maintenance and changes that had been delayed since ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL***. However, there was an additional conservative mode of operation during most of ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** that required additional timing, planning, and scrutiny of any changes. See generally Attachment 6. Fall storm season resulted in a change freeze for Hurricane Sally that struck the Gulf Coast and Southeastern United States resulted in a change