Pillsbury Winthrop Shaw Pittman LLP 2300 N Street, NW Washington, DC tel fax

Transcription

1 Pillsbury Winthrop Shaw Pittman LLP 2300 N Street, NW Washington, DC tel fax October 28, 2013 VIA ELECTRONIC DELIVERY Ms. Susana Woolcock, Manager Telecommunications Division Michigan Public Service Commission 4300 W. Saginaw Highway Lansing, MI Glenn S. Richards Phone: glenn.richards@pillsburylaw.com RE: Airvoice Wireless, LLC Eligible Telecommunications Carrier Recertification in Michigan SAC , U Dear Ms. Woolcock: On behalf of Airvoice Wireless, LLC ( AVW ), this letter is submitted in response to your letter, dated October 21, 2013, seeking additional information associated with the FCC Form 481 and AVW s recertification before the Michigan Public Service Commission ( PSC ). As the PSC is aware, AVW timely filed its FCC Form 481 with the Federal Communications Commission ( FCC ) on October 4, Since AVW has not yet received FCC designation as an eligible telecommunications carrier ( ETC ), it is only required to respond to Sections 800 (affiliates) and 1200 (terms and conditions) of the FCC Form 481. As indicated on its FCC Form 481, Section 800, AVW does not have any affiliates. Additionally, and in response to Section 1200, copies of AVW s terms and conditions were provided as an attachment to the form. As part of the PSC recertification process, AVW has been asked to provide additional information that FCC designated ETCs would normally include on their FCC Form 481, including Section 200 (outage reporting), Section 400 ( number of complaints), Section 500 (service quality standards and consumer protection rules compliance) and Section 600 (functionality in emergency situations). In response, AVW provides the following: Section 200 (outage reporting) AVW has no outages to report. Section 400 (number of complaints) AVW, a mobile provider, has 0 complaints.

2 October 28, 2013 Page 2 Section 500 (service quality standards and consumer protection rules compliance) AVW certifies its service quality standards and consumer protection rules compliance. Section 600 (functionality in emergency situations) - AVW certifies its functionality in emergency situations. Additionally, as a reseller, the AVW relies upon its underlying facilities-based carrier for functionality in emergency situations. Through AVW s agreement with its underlying carrier, AT&T, it has the ability to remain functional in emergency situations. The AT&T wireless network has reasonable amounts of back-up power and the ability to re-route traffic around damaged facilities and manage traffic spikes resulting from emergency situations. Each cell site in the AT&T network is equipped with two to four hours of battery back-up power. Many cell sites in the AT&T network provide overlapping coverage for neighboring areas, ensuring that coverage continues in the event of damage to a particular facility. These neighboring cell sites can be adjusted to provide coverage to a wider service area in the event of an emergency. As a mobile virtual network operator of AT&T, these capabilities benefit AVW customers. Section 800 (affiliates) As indicated on its FCC Form 481, AVW does not have any affiliates. Section 1200 (terms and conditions) AVW has updated its marketing materials for Michigan consumers. Additionally, AVW has updated its website to clearly indicate that, for Michigan consumers, the maximum income threshold is 150% of the federal poverty guidelines. The direct link, provided in red, is included in the attachment. Copies of the new materials are enclosed as Attachment A. Please direct any communications regarding this matter to the undersigned. Respectfully submitted, /s/ Glenn S. Richards Christine A. Reilly Counsel for Airvoice Wireless, LLC Enclosure v1

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