UM 1177, TESTIMONY & EXHIBITS, 7/15/2005 - State of Oregon

Docket UM 1177Staff/1Marinos/1112345678910111213141516EDGE HAS SATISFIED THE REQUIREMENTS FOR ETC STATUS 1Q. DOES EDGE SATISFY THE BASIC REQUIREMENTS FOR DESIGNATIONAS AN ETC?A. Yes. In its Second Amended Application, Edge demonstrates that it meets thebasic statutory conditions for eligibility. Edge is a common carrier under theAct. Edge currently offers all but one of the nine supported services required tocomply with FCC rules in 47 C.F.R. § 54.101(a). Edge commits to provide thatsupported service, toll limitation for qualifying low income consumers, once it isdesignated as an ETC and is able to participate in the Lifeline low incomeprogram. Edge provides the required supported services throughout itslicensed service area utilizing its own facilities – including its own antennas,towers and mobile switching offices. In addition, Edge has committed tooffering Lifeline low-income assistance programs upon designation, as requiredby 47 C.F.R. § 54.405. Edge is technically unable to offer Link Up service, thefederal program for discounts on connection charges, because Edge does notcharge for activation of wireless services. However, Edge will advertise that it1 Based on its experience in previous ETC dockets, Staff proposed only two issuesat the December 2004 prehearing conference for Edge’s application in the ruralareas in UM 1177. They were: 1) “Is it in the public interest to grant federal ETCstatus to Applicant in rural service areas?”, and 2) “Do the commercial mobile radioservices of Applicant comply with the requirements of 47 CFR § 54.101(a)?” Staffidentified no issues in UM 1176 (non-rural areas) because there was no prehearingconference for that docket before it was combined with UM 1177. As FCC decisionsand recommendations, as well as Edge’s applications, have changed substantiallysince the issues were first identified at the December 2004 prehearing conference inUM 1177, Staff believes that the initial issues now appear too limited and do notencompass all concerns related to Edge’s Second Amended Combined Application.The initial two issues are, however, covered in the course of addressing all therequirements met by Edge’s application.