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1 Before the Federal Communications Commission Washington, DC In the Matter of Federal-State Joint Board on Universal Service i-wireless, LLC Petition for Limited Designation as an Eligible Telecommunications Carrier in the States of Alabama, Connecticut, Delaware, Florida, New Hampshire, North Carolina, New York, Tennessee, the Commonwealth of Virginia, and the District of Columbia WC Docket No REQUEST TO AMEND DESIGNATED SERVICE AREA IN THE STATE OF FLORIDA February 18, 2013 Lance J.M. Steinhart Lance J.M. Steinhart, P.C Windward Concourse, Suite 150 Alpharetta, Georgia ( (Phone ( (Fax Attorneys for i-wireless, LLC
2 TABLE OF CONTENTS I. INTRODUCTION... 1 II. BACKGROUND... 2 III. PUBLIC INTEREST DETERMINATION... 3 IV. CONCLUSION... 3 APPENDIX A I-WIRELESS ETC SERVICE AREA
3 BEFORE THE FEDERAL COMMUNICATIONS COMMISSION WASHINGTON, DC In the Matter of Federal-State Joint Board on Universal Service i-wireless, LLC Petition for Limited Designation as an Eligible Telecommunications Carrier in the States of Alabama, Connecticut, Delaware, Florida, New Hampshire, North Carolina, New York, Tennessee, the Commonwealth of Virginia, and the District of Columbia WC Docket No REQUEST TO AMEND DESIGNATED SERVICE AREA IN THE STATE OF FLORIDA I. INTRODUCTION i-wireless, LLC ( i-wireless or the Company, pursuant to Section 214(e(6 of the Communications Act of 1934, as amended ( Communications Act, and Section of the rules of the Federal Communications Commission ( FCC or Commission, hereby requests that the Commission amend the Company s designation as an eligible telecommunications carrier ( ETC in the State of Florida to include the additional non-rural service territories of Bellsouth Telecommunications, LLC d/b/a AT&T Florida ( AT&T. Grant of i-wireless request will promote the public interest by providing customers in AT&T Florida service territories with low prices and high quality wireless services. 1
4 II. BACKGROUND i-wireless provides prepaid wireless services on a common carrier basis, offering customers wireless voice, messaging, and data plans without a fixed-term contract or a credit check. i- wireless also offers a Lifeline program under its brand name "Access Wireless." i-wireless has received Compliance Plan approval, 1 and has been authorized as a Lifeline ETC by this Commission 2 and by the state public service commissions in 20 states. In its ETC Petition filed with this Commission, i-wireless requested ETC designation for its entire service area in Alabama, Connecticut, Delaware, District of Columbia, Florida, New Hampshire, North Carolina, New York, Tennessee and Virginia (i.e., the area served by the facilities-based carriers from whom it obtains wholesale service, but excluding any Tribal Areas. However, AT&T was inadvertently omitted from the list of approved service areas in Florida. 1 2 See i-wireless LLC s Revised Compliance Plan, CC Docket No , WC Docket No (filed Sept. 9, 2011 ( Compliance Plan ; i-wireless, LLC Petition for Forbearance from 47 USC. 214(e(1(A, CC Docket No , WC Docket No , DA , 2011 WL (rel. Oct. 21, 2011( Compliance Plan Order. See In the Matter of Federal-State Joint Board on Universal Service, i-wireless, LLC Petition for Limited Designation as an Eligible Telecommunications Carrier in the States of Alabama, Connecticut, Delaware, Florida, New Hampshire, North Carolina, New York, Tennessee, the Commonwealth of Virginia, and the District of Columbia ( ETC Petition, WC Docket No , Order, DA (rel. June 13, 2012 ( ETC Order. 2
5 III. PUBLIC INTEREST DETERMINATION The Commission has already found that the services that i-wireless offers as a Lifeline carrier fulfill the public interest for the State of Florida. 3 There should be no public interest concern about correcting i-wireless list of approved service areas to include AT&T territories in the State of Florida, especially in light of the safeguards already contained in i-wireless approved Compliance Plan and its existing ETC designation which covers all other service areas in the State of Florida. 4 IV. CONCLUSION For the foregoing reasons, i-wireless respectfully requests that the Commission amend i- wireless ETC designation to include the AT&T service area in the State of Florida. February 18, 2013 Respectfully submitted, /s/ Lance J.M. Steinhart Lance J.M. Steinhart Lance J.M. Steinhart, P.C Windward Concourse, Suite 150 Alpharetta, Georgia ( (Phone ( (Fax lsteinhart@telecomcounsel.com Attorneys for i-wireless, LLC 3 4 See ETC Order at For the Commission s convenience, i-wireless has attached as Appendix A an updated list of the Company's ETC service areas; the only change between the attached list and the service area list provided in Appendix B and C of i-wireless ETC Order is the addition of AT&T Florida to the non-rural telephone company study areas. 3
6 APPENDIX A I-WIRELESS ETC SERVICE AREA Non-Rural Telephone Company Study Areas for Inclusion in i-wireless' ETC Service Area Alabama South Central Bell - AL CenturyTel-AL-South CenturyTel-AL-North Connecticut Southern New England d/b/a AT&T Connecticut Delaware Verizon Delaware, Inc. District of Columbia Verizon Washington, D.C., Inc. Florida Bellsouth Telecommunications, LLC d/b/a AT&T Florida Verizon Florida New Hampshire Northern New England Telephone Operations LLC d/b/a Fairpoint New York Verizon New York, Inc. Frontier-Rochester North Carolina Bellsouth Telecommunications Inc. d/b/a Southern Bell Tel. Frontier Communications of the Carolinas, Inc. Verizon South Inc. d/b/a North Carolina Tennessee Bellsouth Telecommunications Inc. d/b/a South Central Bell Tel. Virginia Verizon Virginia, Inc. Verizon South Inc. - VA (Contel
7 Rural Telephone Company Study Areas for Inclusion in i-wireless' ETC Service Area Alabama Blountsville Tel. Company Brindlee Mountain Butler Tel Co. Castleberry Tel Co. National Of Alabama Farmers Telcom Coop Graceba Total Comm Gulf Tel Co - AL HayneVille Tel Co. Hopper Telecomm. Co. Frontier-Lamar CNTY Windstream AL Millry Tel Co. Mon-CRE Tel Coop Frontier Comm - AL Moundville Tel Co. New Hope Tel Coop. Oakman Tel Co. (TDS Otelco Telephone LLC Peoples Tel. Co. Pine Belt Tel. Com Ragland Tel Co. Roanoke Tel. Co. Frontier Comm-South Union Springs Tel Co. Connecticut The Woodbury Tel Co. Florida GTC, Inc. Frontier Comm-South Smart City Tel LLC ITS Telecomm. Sys. Northeast Florida Windstream Florida Quincy Tel Co-Fl Div. Embarq Florida Inc. New Hampshire Bretton Woods Tel Co. Granite State Tel Dixville Tel Co. Dunbarton Tel Co. Kearsarge Tel Co. Merrimack County Tel. Union Tel. Co. Wilton Tel Co-NH MCTA, Inc.
8 New York Armstrong Tel Co-NY Frontier Ausable Val Berkshire Tel Corp. Cassadaga Tel Corp. Champlain Tel Co. Chautauqua & Erie Chazy & Westport Citizens Hammond NY Taconic Tel Corp. Crown Point Tel Corp. Delhi Tel Co. Deposit Tel Co. Dunkirk & Fredonia Edwards Tel Co. Empire Tel Corp. Fishers Island Tel. Germantown Tel Co. Hancock Tel Co. Frontier Comm of NY Margaretville Tel Co. Middleburgh Tel Co. Windstream NY-Fulton Newport Tel Co. Nicholville Tel Co. Winstream-Jamestown Odgen Tel DBA Frontier Oneida County Rural Ontario Tel Co, Inc. Winstream Red Jacket Oriskany Falls Tel. Pattersonville Tel. Port Byron Tel Co. Frontier-Rochester Frontier Communications of Seneca Gorham, Inc. State Tel Co. Frontier-Sylvan Lake Township Tel Co. Trumansburg Tel Co. Vernon Tel Co. Warwick Valley-NY Citizens-Frontier-NY North Carolina Atlantic Membership Barnardsville Tel Co. Citizens Tel Co. Concord Tel Co. Ellerbre Tel Co. LexCom Telephone Co. Carolina Tel and Tel Co., LLC d/b/a Centurylink Centel of NC
9 Mebtel, Inc. d/b/a Centurylink N St. DBA N. St. Comm. Piedmont Membership Pineville Telephone Co. Randolph Tel Co. Randolph Membership Saluda Mountain Tel. Service Tel Co. Skyline Membership Star Membership Corp. Surry Membership Tri County Tel Membership Wilkes Membership Yadkin Valley Telephone Membership Corp. Windstream NC Tennessee Ardmore Tel Co. CenturyTel-Adamsville Ben Lomand Rural Telephone Cooperative, Inc. Bledsoe Tel Coop. Century-Claiborne Concord Telephone Exchange, Inc. d/b/a TDS Telecom Crockett Tel Co. DeKalb Telephone Cooperative Highland Telephone Cooperative, Inc. - TN Humphrey's County United Inter-MT-TN Loretto Tel Co. Millington Telephone Co. North Central Coop. CenturyTel-Ooltewah Tennessee Telephone Co. d/b/a TDS Telecom Peoples Tel Co. Tellico Tel Co. Twin Lakes Tel Coop. Citizens Telecom Vol St. LLC d/b/a Frontier Vol State UTC of TN West Tennessee Tel. Yorkville Tel Coop. West Kentucky Rural Telephone Citizens-Frontier-TN Virginia Buggs Island Coop Burke's Garden Tel Citizens Tel Coop Ntelos, Inc. Highland Tel Coop. MGW Tel. Co. Inc. New Hope Tel Coop.
10 Pembroke Tel Coop. Peoples Mutual Tel. Scott County Coop Roanoke & Botetourt Shenandoah Tel Co. Virginia Tel Co. Centel of Virginia Verizon South-VA New Castle Tel. Co. Shenandoah Telephone Company- NR United Inter-MT-VA
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