Expert Telecom Compliance, Inc Windward Concourse Suite 150 Alpharetta, Georgia 30005

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1 Expert Telecom Compliance, Inc Windward Concourse Suite 150 Alpharetta, Georgia Telephone: (770) Facsimile: (770) June 30, 2017 VIA ELECTRONIC DELIVERY Michigan Public Service Commission Communications Division Director 7109 W. Saginaw Highway Lansing, MI Re: Docket No. U-18216, ETC Annual Report & Form 481 AmeriMex Communications Corp. d/b/a SafetyNet Wireless To Whom It May Concern: Attached please find for filing in the above-referenced docket a copy of AmeriMex Communications Corp. d/b/a SafetyNet Wireless Annual ETC Report, including copy of FCC Form 481. If you have any questions regarding this filing, please contact me at or etc@telecomcounsel.com. Attachments Respectfully submitted, s/ Victoria Martin, Regulatory Specialist Expert Telecom Compliance, Inc.

2 STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION * * * In the matter, on the Commission s Own Motion, on the Certification of Eligible Telecommunications Carriers ) ) ) ) ) Case No. U ELIGIBLE TELECOMMUNICATIONS CARRIER ANNUAL REPORT OF AMERIMEX COMMUNICATIONS CORP. D/B/A SAFETYNET WIRELESS AmeriMex Communications Corp. d/b/a SafetyNet Wireless ( SafetyNet or the Company ) hereby files with the Michigan Public Service Commission ( Commission ) this Annual Report ( Report ) of its compliance with the requirements to remain an eligible telecommunications carrier ( ETC ), along with a copy of its FCC Form 481. SafetyNet requests continued certification as an ETC for purpose of receiving universal service fund ( USF ) support in. In support of this Report, SafetyNet hereby states as follows: 1. Company name, names of the company s holding company, operating companies and affiliates, and any branding as well as relevant universal service identifiers for each such entity by Study Area Code. See Exhibit A, copy of FCC Form 481. The Company provides its Lifeline service under the d/b/a SafetyNet Wireless. The Company s Study Area Code ( SAC ) for Michigan is. 2. Outage Information Detailed information on any outage in the prior calendar year of at least 30 minutes in duration for each service area the ETC is designated for any facilities it owns, operates, leases, or otherwise utilizes that potentially affect:

3 Case No. U AmeriMex Communications Corp. d/b/a SafetyNet Wireless At least 10 percent of the end users served in a designated service area; or A 911 special facility Including: The date and time of onset outage A brief description of the outage and its resolution The particular services affected The geographic areas affected by the outage Steps taken to prevent a similar situation in the future The number of customers affected SafetyNet is unaware of any outages. 3. Number of complaints per 1,000 connections in the prior calendar year SafetyNet had 0 complaints per 1,000 connections in the prior calendar year. 4. Emergency Preparedness SafetyNet, through its underlying carriers, has the ability to remain functional in emergency situations. Because of the agreements SafetyNet has to resell the network services of Sprint and Verizon through Ready Wireless, LLC, SafetyNet is able to provide to its customers the same ability to remain functional in emergency situations as currently provided by the ILECs to their own customers. Sprint and Verizon have established a variety of internal programs, policies and teams dedicated to analyzing, assessing and responding to emergency situations. Sprint and Verizon have access to reasonable amounts of back-up power to ensure functionality without an external power source, have implemented reasonable practices to reroute traffic around damaged facilities and manage traffic spikes resulting from emergency situations, and each cell site in Sprint and Verizon s networks is equipped with battery back-up power. 5. Carrier Certifications Attached hereto as Exhibit B is an affidavit certifying the following on behalf of SafetyNet:

4 Case No. U AmeriMex Communications Corp. d/b/a SafetyNet Wireless The carrier is in compliance with applicable state and federal service quality standards and consumer protection rules, as well as the CTIA Consumer Code for Wireless Service; The carrier is able to function in emergency situations; The carrier has policies and procedures in place to ensure that its Lifeline subscribers are eligible to receive Lifeline services; and The carrier is in compliance with all federal Lifeline certification procedures. 6. Annual Recertification Effort SafetyNet previously filed in this docket the results of its most recent annual Lifeline recertification effort in Michigan (FCC Form 555). 7. Certification(s) from reseller(s) reseller. Not applicable; SafetyNet does not provide Lifeline discounted wholesale services to a 8. Commitment by wireless applicants to comply with the Cellular Telecommunications and Internet Association s Consumer Code for Wireless Service SafetyNet commits that it will continue to comply with the Cellular Telecommunications and Internet Association s Consumer Code for Wireless Service. 9. Information describing the terms and conditions of the Company s voice telephony service plan(s) offered to Lifeline subscribers, including details on the number of minutes provided as part of the plan, additional charges, if any, for toll calls, and rates for each such plan. See Exhibit A, copy of FCC Form 481.

5 Case No. U AmeriMex Communications Corp. d/b/a SafetyNet Wireless CONCLUSION Based on the information set forth above, SafetyNet has demonstrated that it satisfies the requirements for continued ETC designation. SafetyNet therefore respectfully requests that the Commission issue an appropriate certification to the FCC indicating that SafetyNet should be eligible for federal USF Lifeline support for the entire funding year. Respectfully submitted, /s/ Lance J.M. Steinhart Lance J.M. Steinhart Lance J.M. Steinhart, P.C Windward Concourse, Suite 150 Alpharetta, Georgia (770) (Phone) (770) (Fax) lsteinhart@telecomcounsel.com Attorneys for AmeriMex Communications Corp. d/b/a SafetyNet Wireless Dated: June 28, 2017

6 Case No. U AmeriMex Communications Corp. d/b/a SafetyNet Wireless Exhibit A FCC Form 481

7 Page 1 FCC Form 481 FCC Form Carrier Annual Reporting OMB Control No /OMB Control No Data Collection Form Page 1 <030> Contact Name: Person USAC should contact with questions about this data <035> Contact Telephone Number: Number of the person identified in data line <030> <039> Contact Address: of the person identified in data line <030> Form Type

8 Page 2 (200) Service Outage Reporting (Voice) FCC Form 481 <039> Contact Address - Address of person identified in data line <030> <210> For the prior calendar year, were there any reportable voice service outages? <220> <a> <b1> <b2> <b3> <b4> <c1> <c2> <d> <e> <f> <g> <h> NORS Reference Outage Start Outage Start Outage End Outage End Number of Number Date Time Date Time Customers Affected Total Number of Customers 911 Facilities Affected (Yes / No) Service Outage Description (Check all that apply) Did This Outage Affect Multiple Study Areas (Yes / No) Service Outage Resolution Preventative Procedures Page 2

9 Page 3 (300) Unfulfilled Service Request FCC Form 481 <039> Contact Address - Address of person identified in data line <030> <300> Unfulfilled service request (voice) <310> Detail on attempts (voice) Name of Attached Document <320> Unfulfilled service request (broadband) <330> Detail on attempts (broadband) Name of Attached Document Page 3

10 Page 4 (400) Number of Complaints per 1,000 customers FCC Form 481 <035> <039> Contact Telephone Number - Number of person identified in data line <030> Contact Address - Address of person identified in data line <030> <400> Select from the drop-down list to indicate how you would like to report voice complaints (zero or greater) for voice telephony service in the prior calendar year for each service area in which you are designated an ETC for any facilities you own, operate, lease, or otherwise utilize. <410> Complaints per 1000 customers for fixed voice <420> Complaints per 1000 customers for mobile voice <430> <440> <450> Select from the drop-down list to indicate how you would like to report end-user customer complaints (zero or greater) for broadband service in the prior calendar year for each service area in which you are designated an ETC for any facilities you own, operate, lease, or otherwise utilize. Complaints per 1000 customers for fixed broadband Complaints per 1000 customers for mobile broadband Page 4

11 Page 5 (500) Compliance With Service Quality Standards and Consumer Protection Rules FCC Form 481 <039> Contact Address - Address of person identified in data line <030> <500> Certify compliance with applicable service quality standards and consumer protection rules <510> Descriptive document for Service Quality Standards & Consumer Protection Rules Compliance <515> Certify compliance with applicable minimum service standards Page 5

12 Page 6 (600) Functionality in Emergency Situations FCC Form 481 <010> <015> <020> <030> <035> <039> Study Area Code Study Area Name Program Year Contact Name - Person USAC should contact regarding this data Contact Telephone Number - Number of person identified in data line <030> Contact Address - Address of person identified in data line <030> <600> Certify compliance regarding ability to function in emergency situations <610> Descriptive document for Functionality in Emergency Situations Page 6

13 Page 7 (700) Price Offerings including Voice Rate Data FCC Form 481 <010> <015> <020> <030> <035> <039> Study Area Code Study Area Name Program Year Contact Name - Person USAC should contact regarding this data Contact Telephone Number - Number of person identified in data line <030> Contact Address - Address of person identified in data line <030> <701> Residential Local Service Charge Effective Date <702> Single State-wide Residential Local Service Charge 1/1/2017 <703> <a1> <a2> <a3> <b1> <b2> Residential Local State Exchange (ILEC) SAC (CETC) Rate Type Service Rate <b3> State Subscriber Line Charge <b4> State Universal Service Fee <b5> Mandatory Extended Area Service Charge <c> Total per line Rates and Fees Page 7

14 Page 8 (710) Broadbrand Price Offerings FCC Form 481 <039> Contact Address - Address of person identified in data line <030> <711> <a1> <a2> <b1> <b2> <c> <d1> <d2> <d3> <d4> State Exchange (ILEC) Residential Rate State Regulated Fees Total Rate and Fees Broadband Service - Download Speed (Mbps) Broadband Service - Upload Speed (Mbps) Usage Allowance (GB) Usage Allowance Action Taken When Limit Reached {select } Page 8

15 Page 9 (800) Operating Companies FCC Form 481 <039> Contact Address - Address of person identified in data line <030> <810> Reporting Carrier <811> Holding Company <812> Operating Company Not Applicable Not Applicable <813> <a1> <a2> <a3> Affiliates SAC Doing Business As Company or Brand Designation -- See attached worksheet -- Page 9

16 Page 10 (900) Tribal Lands Reporting FCC Form 481 <039> Contact Address - Address of person identified in data line <030> <900> Does the filing entity offer tribal land services? (Y/N) <910> Tribal Land(s) on which ETC Serves <920> Tribal Government Engagement Obligation <921> <922> Feasibility and sustainability planning; <923> Marketing services in a culturally sensitive manner; <924> Compliance with Rights of way processes <925> Compliance with Land Use permitting requirements <926> Compliance with Facilities Siting rules <927> Compliance with Environmental Review processes <928> Compliance with Cultural Preservation review processes <929> Compliance with Tribal Business and Licensing requirements. Page 10

17 (1000) Voice and Broadband Service Rate Comparability FCC Form 481 Page 11 <039> Contact Address - Address of person identified in data line <030> <1000> Voice services rate comparability certification <1010> Attach detailed description for voice services rate comparability compliance Name of Attached Document <1020> Broadband comparability certification <1030> Attach detailed description for broadband comparability compliance Name of Attached Document Page 11

18 Page 12 (1100) No Terrestrial Backhaul Reporting FCC Form 481 <039> Contact Address - Address of person identified in data line <030> <1100> Certify whether terrestrial backhaul options exist (Y/N) <1130> Page 12

19 Page 13 (1200) Terms and Condition for Lifeline Customers FCC Form 481 Lifeline OMB Control No /OMB Control No Data Collection Form <039> Contact Address - Address of person identified in data line <030> AMX _2017.pdf <1210> Terms & Conditions of Voice Telephony Lifeline Plans <1220> Link to Public Website HTTP <1221> Information describing the terms and conditions of any voice telephony service plans offered to Lifeline subscribers, <1222> Details on the number of minutes provided as part of the plan, <1223> Additional charges for toll calls, and rates for each such plan. Page 13

20 Page 14 (2005) Price Cap Carrier Additional Documentation FCC Form 481 Data Collection Form OMB Control No /OMB Control No Including Rate-of-Return Carriers affiliated with Price Cap Local Exchange Carriers <039> Contact Address - Address of person identified in data line <030> Select the appropriate responses below (Yes, No, Not Applicable) to note compliance as a recipient of Incremental High Cost support, High Cost support to offset access charge reductions, and Connect America Phase II support as set forth in 47 CFR (b),(c),(d),(e). The information reported on this form and in the documents attached below is accurate. Incremental Connect America Phase I reporting <2011> 3rd Year Certification 47 CFR (b)(1)(ii) - Note that for the July 2017 certification, this applies to Round 2 recipients of Incremental Support. <2022> Recipient certifies, representing year three after filing a notice of acceptance of funding pursuant to (c), that the locations in question are not receiving support under the Broadband Initiatives Program or the Broadband Technology Opportunities Program for projects that will provide broadband with speeds of at least 4 Mbps/1Mbps (b)(2)(i). Round 2 recipients only. <2023> The attachment on line 2024 includes a statement of the total amount of capital funding expended in the previous year in meeting Connect America Phase I deployment obligations, accompanied by a list of census blocks indicating where funding was spent. This covers year three (b)(2)(ii). Round 2 recipients only. <2024A> Round 2 Recipient of Incremental Support? <2024B> <2025A> <2025B> Attach list of census blocks indicating where funding was spent in year three (b)(2)(ii). Round 2 recipients only. Round 2 Recipient of Incremental Support? Attach geocoded Information for Phase I milestone reports (Round 2 for year three) - Connect America Fund, WC Docket 10-90, Report and Order, FCC 13-73, paragraph 35 (May 22, 2013). Name of Attached Document Listing Required Information Name of Attached Document Listing Required Information <2015> 2016 and future Frozen Support Certification 47 CFR (c)(4) Page 14

21 Page 15 (2005) Price Cap Carrier Additional Documentation FCC Form 481 Data Collection Form OMB Control No /OMB Control No Including Rate-of-Return Carriers affiliated with Price Cap Local Exchange Carriers Price Cap Carrier Connect America ICC Support {47 CFR (d)} <2016> Certification support used to build broadband Connect America Phase II Reporting {47 CFR (e )} <2017A> Connect America Fund Phase II recipient? <2017C> Total amount of Phase II support, if any, the price cap carrier used for capital expenditures in <> Attach the number, names, and addresses of community anchor institutions to which the carrier newly began providing access to broadband service in the preceding calendar year (e)(1)(ii)(A) Name of Attached Document Listing Required Information <2019> Recipient certifies that it bid on category one telecommunications and Internet access services in response to all FCC Form 470 postings seeking broadband service that meets the connectivity targets for the schools and libraries universal service support program for eligible schools and libraries located within any area in a census block where the carrier is receiving Phase II model-based support, and that such bids were at rates reasonably comparable to rates charged to eligible schools and libraries in urban areas for comparable offerings (e)(1)(ii)(C) Page 15

22 Page 16 (3005) Rate Of Return Carrier Additional Documentation FCC Form 481 <039> Contact Address - Address of person identified in data line <030> Select from the drop down menu or check the boxes below to note compliance with (f)(1). Privately held carriers must ensure compliance with the financial reporting requirements set forth in 47 CFR (f)(2). I further certify that the information reported on this form and in the documents attached below is accurate. Progress Report on 5 Year Plan (3009) Carrier certifies to (f)(1)(iii) (3010A) (3010B) (3012A) (3012B) Certification of Public Interest Obligations {47 CFR (f)(1)(i)} Please Provide Attachment Community Anchor Institutions {47 CFR (f)(1)(ii)} Please Provide Attachment (3013) Is your company a Privately Held ROR Carrier {47 CFR (Yes/No) (f)(2)} (3014) If yes, does your company file the RUS annual report (Yes/No) Name of Attached Document Listing Required Information Name of Attached Document Listing Required Information Please check these boxes to confirm that the attached PDF, on line 3017, contains the required information pursuant to (f)(2) compliance requires: (3015) Electronic copy of their annual RUS reports (Operating Report for Telecommunications Borrowers) (3016) Document(s) with Balance Sheet, Income Statement and Statement of Cash Flows (3017) If the response is yes on line 3014, attach your company's RUS annual report and all required Name of Attached Document Listing Required Information documentation (3018) If the response is no on line 3014, is your company (Yes/No) audited? If the response is yes on line 3018, please check the boxes below to confirm your submission on line 3026 pursuant to (f)(2), contains: (3019) Either a copy of their audited financial statement; or (2) a financial report in a format comparable to RUS Operating Report for Telecommunications Borrowers (3020) Document(s) for Balance Sheet, Income Statement and Statement of Cash Flows (3021) Management letter and/or audit opinion issued by the independent certified public accountant that performed the company s financial audit. If the response is no on line 3018, please check the boxes below to confirm your submission on line 3026 pursuant to (f)(2), contains: (3022) Copy of their financial statement which has been subject to review by an independent certified public accountant; or 2) a financial report in a format comparable to RUS Operating Report for Telecommunications Borrowers (3023) Underlying information subjected to a review by an independent certified public accountant (3024) (3025) (3026) Underlying information subjected to an officer certification. Document(s) with Balance Sheet, Income Statement and Statement of Cash Flows Attach the worksheet listing required information Name of Attached Document Listing Required Information page 16

23 Page 17 (3005) Rate Of Return Carrier Additional Documentation (Continued) FCC Form 481 <039> Contact Address - Address of person identified in data line <030> Financial Data Summary (3027) Revenue (3028) Operating Expenses (3029) Net Income (3030) Telephone Plant In Service(TPIS) (3031) Total Assets (3032) Total Debt (3033) Total Equity (3034) Dividends Name of Attached Document Listing Required Information Page 17

24 Page 18 (4005) Rural Broadband Experiment Additional Documentation Data Collection Form FCC Form 481 OMB Control No /OMB Control No <039> Contact Address - Address of person identified in data line <030> 4005 Rural Broadband Experiment Authorized Rural Broadband Experiment (RBE) recipients must address the certification for public interest obligations, provide a list of newly served community anchor institutions, and provide a list of locations where broadband has been deployed. Public Interest Obligations FCC (paragraphs 26-29, 78) Please address Line 4001 regarding compliance with the Commission s public interest obligations. All RBE participants must provide a response to Line Recipient certifies that it is offering broadband to the identified locations meeting the requisite public interest obligations consistent with the category for which they were selected, including broadband speed, latency, usage capacity, and rates that are reasonably comparable to rates for comparable offerings in urban areas? Community Anchor Institutions FCC (paragraph 79) 4003a. RBE participants must provide the number, names, and addresses of community anchor institutions to which they newly deployed broadband service in the preceding calendar year. On this line, please respond (yes attach new community anchors, no no new anchors) to indicate whether this list will be provided. If yes to 4003A, please provide a response for 4003B. 4003b. Provide the number, names and addresses of community anchor institutions to which the recipient newly began providing access to broadband service in the preceding calendar year. Name of Attached Document Listing Required Information Broadband Deployment Locations FCC (paragraph 80) 4004a. Attach a list of geocoded locations to which broadband has been deployed as of the June 1st immediately preceding the July 1st filing deadline for the FCC Form b. Attach evidence demonstrating that the recipient is meeting the relevant public service obligations for the identified locations. Materials must at least detail the pricing, offered broadband speed and data usage allowances available in the relevant geographic area. Name of Attached Document Listing Required Information Name of Attached Document Listing Required Information page 18

25 Page 19 Certification - Reporting Carrier FCC Form 481 <039> Contact Address - Address of person identified in data line <030> TO BE COMPLETED BY THE REPORTING CARRIER, IF THE REPORTING CARRIER IS FILING ANNUAL REPORTING ON ITS OWN BEHALF: Name of Reporting Carrier: Certification of Officer as to the Accuracy of the Data Reported for the Annual Reporting for CAF or LI Recipients I certify that I am an officer of the reporting carrier; my responsibilities include ensuring the accuracy of the annual reporting requirements for universal service support recipients; and, to the best of my knowledge, the information reported on this form and in any attachments is accurate. Signature of Authorized Officer: Date Printed name of Authorized Officer: Title or position of Authorized Officer: Telephone number of Authorized Officer: Study Area Code of Reporting Carrier: Filing Due Date for this form: Persons willfully making false statements on this form can be punished by fine or forfeiture under the Communications Act of 1934, 47 U.S.C. 502, 503(b), or fine or imprisonment under Title 18 of the United States Code, 18 U.S.C Page 19

26 Page 20 Certification - Agent / Carrier FCC Form 481 <039> Contact Address - Address of person identified in data line <030> TO BE COMPLETED BY THE REPORTING CARRIER, IF AN AGENT IS FILING ANNUAL REPORTS ON THE CARRIER'S BEHALF: Certification of Officer to Authorize an Agent to File Annual Reports for CAF or LI Recipients on Behalf of Reporting Carrier I certify that (Name of Agent) Expert Telecom Compliance, Inc. is authorized to submit the information reported on behalf of the reporting carrier. I also certify that I am an officer of the reporting carrier; my responsibilities include ensuring the accuracy of the annual data reporting requirements provided to the authorized agent; and, to the best of my knowledge, the reports and data provided to the authorized agent is accurate. Name of Authorized Agent: Name of Reporting Carrier: Signature of Authorized Officer: CERTIFIED ONLINE Printed name of Authorized Officer: Title or position of Authorized Officer: Telephone number of Authorized Officer: Expert Telecom Compliance, Inc. Steve Klein President ext. Study Area Code of Reporting Carrier: Filing Due Date for this form: 07/03/2017 Persons willfully making false statements on this form can be punished by fine or forfeiture under the Communications Act of 1934, 47 U.S.C. 502, 503(b), or fine or imprisonment under Title 18 of the United States Code, 18 U.S.C Date: 06/28/2017 TO BE COMPLETED BY THE AUTHORIZED AGENT: Certification of Agent Authorized to File Annual Reports for CAF or LI Recipients on Behalf of Reporting Carrier I, as agent for the reporting carrier, certify that I am authorized to submit the annual reports for universal service support recipients on behalf of the reporting carrier; I have provided the data reported herein based on data provided by the reporting carrier; and, to the best of my knowledge, the information reported herein is accurate. Name of Reporting Carrier: Name of Authorized Agent Firm: Signature of Authorized Agent or Employee of Agent: Name of Authorized Agent Employee: Title or position of Authorized Agent or Employee of Agent Telephone number of Authorized Agent or Employee of Agent: Study Area Code of Reporting Carrier: Expert Telecom Compliance, Inc. CERTIFIED ONLINE Expert Telecom Compliance, Inc. Regulatory Specialist ext. Filing Due Date for this form: 07/03/2017 Persons willfully making false statements on this form can be punished by fine or forfeiture under the Communications Act of 1934, 47 U.S.C. 502, 503(b), or fine or imprisonment under Title 18 of the United States Code, 18 U.S.C Date: 06/26/2017 Page 20

27 Attachments

28 (800) Operating Companies FCC Form 481 <039> Contact Address - Address of person identified in data line <030> ext. <810> Reporting Carrier <811> Holding Company <812> Operating Company Not Applicable Not Applicable <813> <a1> <a2> <a3> N/A Affiliates SAC Doing Business As Company or Brand Designation SafetyNet Wireless

29 Form 481 section 1210 AmeriMex Communications Corp. d/b/a SafetyNet Wireless Lifeline Rates, Terms & Conditions Lifeline Price Free $1.00 $5.00 Free $5.00 $10.00 $19.99 $27.99 $37.99 Talk Unlimited Unlimited Unlimited Text Unlimited Unlimited Unlimited Unlimited Unlimited Data MB 500 MB 500 MB 500 MB 1 GB 2.5 GB Phone Free Free Free Cust. Pay* Cust. Pay* Cust. Pay* Cust. Pay* Cust. Pay* Cust. Pay* * For data plans, customer must purchase the data device, bring their own device (BYOD), or supplement the cost of the device Additional Airtime: Voice TopUps: Data TopUps: Direct from SafetyNet Airfare (Retail) Direct from SafetyNet 100 minutes $4.00 $ MB $ minutes $8.00 $ MB $9.99 Airfare (Retail) 400 minutes $ GB $13.99 $ minutes $ GB $25.99 $30.00 Complete program terms of use located at

30 Case No. U AmeriMex Communications Corp. d/b/a SafetyNet Wireless Exhibit B Affidavit

31 CERTIFICATION I, Stephen Klein, President of AmeriMex Communications Corp. d/b/a Safety Net Wireless ( the Company ), certify that the foregoing report and the following matters, facts and things set forth below are true and correct to the best of my knowledge and belief. The Company is in compliance with applicable state and federal service quality standards and consumer protection rules, as well as the CTIA Consumer Code for Wireless Service; The Company is able to function in emergency situations; The Company has policies and procedures in place to ensure that its Lifeline subscribers are eligible to receive Lifeline services; and The Company is in compliance with all federal Lifeline certification procedures. By Stephen Klein, Its President AmeriMex Communications Corp. d/b/a Safety Net Wireless