The State of the Department Paul Grannis, Sept. 14, 2004 grannis/dept.html.
WG WILTSHIRE GRANNIS LLPWG Ex Parte WILTSHIRE &GRANNIS LLP May 10,2011 Ms. Marlene H. Dortch...
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WG Ex Parte WILTSHIRE & GRANNIS LLP May 10,2011 Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 12 th Street, SW Washington, DC 20554 Re: High-Cost Universal Service Support, WC Docket 05-337; Rural Health Care Universal Service Support Mechanism, WC Docket No. 02-60; Universal Service Reform Mobility Fund, WT Docket No. 10-208; Connect America Fund, WC Docket No. 10-90; A National Broadband Planfor Our Future, GN Docket No. 09-51; Establishing Just and Reasonable Ratesfor Local Exchange Carriers, WC Docket No. 07-135; Developing a Unified Intercarrier Compensation Regime, CC Docket No. 01-92; Federal-State Joint Board on Universal Service, CC Docket No. 96-45; Lifeline and Link-Up, WC Docket No. 03-109 Dear Ms. Dortch: On May 9, 2011, Megan Delany, Vice President, Federal Governmental Affairs & Counsel, Christopher Nierman, Director, Federal Regulatory Affairs, both of General Communication Inc. ("GCI") and I, on behalf of GCI, met separately with Christine Kurth, Policy Director and Wireline Counsel for Commissioner McDowell, and Angela Kronenberg, Wireline Legal Advisor to Commissioner Clyburn to discuss the above-captioned proceedings. On May 10, 2011, Gregory Chapados, Senior Vice President of GCI, Christopher Nierman, Megan Delany, and I met with Zac Katz, Wireline Legal Advisor to Chairman Genachowski, Sharon Gillett, Chief, Wireline Competition Bureau, Carol Mattey, Deputy Chief, Wireline Competition Bureau, Theodore Burmeister, Rebekah Goodheart, Patrick Halley, and Michael Steffen, all of the Wireline Competition Bureau to discuss the aforementioned proceedings. Attached, is a copy of the material presented during those meetings. We discussed Alaska's extreme need for assistance in completing the buildout of 20 th Century telecommunications services, as well as 21 st Century services. With the universal service support and substantial private investment, GCI is bringing modem wireless services to many communities in Alaska that never before had such service. This is a major improvement in communications services and provides real public safety benefits, as residents can now easily summon assistance when away from home - such as when a snowmachine breaks down on the tundra between villages. With USF support, in addition to a RUS Distance LeamingiTelemedicine grant/loan and a BIP grant/loan, GCI and its affiliates have and are constructing a microwave/fiber middle-mile transport facility to connect southwestern Alaska and Anchorage. This middle-mile network is already allowing GCI to deliver high bandwidth, low-latency connections for critical telemedicine applications such as telepsychiatry. 1200 18TH STREET, NW I SUITE 1200 I WASHINGTON, OC 20036 I TEL 202-730-1300 I FAX 202-730-1301 I WILTSHIREGRANNIS.COM
Transcript of WG WILTSHIRE GRANNIS LLPWG Ex Parte WILTSHIRE &GRANNIS LLP May 10,2011 Ms. Marlene H. Dortch...
WGEx Parte
WILTSHIRE& GRANNIS LLP
May 10,2011
Ms. Marlene H. DortchSecretaryFederal Communications Commission445 12th Street, SWWashington, DC 20554
Re: High-Cost Universal Service Support, WC Docket 05-337; Rural Health Care UniversalService Support Mechanism, WC Docket No. 02-60; Universal Service Reform MobilityFund, WT Docket No. 10-208; Connect America Fund, WC Docket No. 10-90; ANational Broadband Planfor Our Future, GN Docket No. 09-51; Establishing Just andReasonable Ratesfor Local Exchange Carriers, WC Docket No. 07-135; Developing aUnified Intercarrier Compensation Regime, CC Docket No. 01-92; Federal-State JointBoard on Universal Service, CC Docket No. 96-45; Lifeline and Link-Up, WC DocketNo. 03-109
Dear Ms. Dortch:
On May 9, 2011, Megan Delany, Vice President, Federal Governmental Affairs &Counsel, Christopher Nierman, Director, Federal Regulatory Affairs, both of GeneralCommunication Inc. ("GCI") and I, on behalf of GCI, met separately with Christine Kurth,Policy Director and Wireline Counsel for Commissioner McDowell, and Angela Kronenberg,Wireline Legal Advisor to Commissioner Clyburn to discuss the above-captioned proceedings.On May 10, 2011, Gregory Chapados, Senior Vice President of GCI, Christopher Nierman,Megan Delany, and I met with Zac Katz, Wireline Legal Advisor to Chairman Genachowski,Sharon Gillett, Chief, Wireline Competition Bureau, Carol Mattey, Deputy Chief, WirelineCompetition Bureau, Theodore Burmeister, Rebekah Goodheart, Patrick Halley, and MichaelSteffen, all of the Wireline Competition Bureau to discuss the aforementioned proceedings.Attached, is a copy of the material presented during those meetings.
We discussed Alaska's extreme need for assistance in completing the buildout of 20th
Century telecommunications services, as well as 21 st Century services. With the universalservice support and substantial private investment, GCI is bringing modem wireless services tomany communities in Alaska that never before had such service. This is a major improvementin communications services and provides real public safety benefits, as residents can now easilysummon assistance when away from home - such as when a snowmachine breaks down on thetundra between villages. With USF support, in addition to a RUS DistanceLeamingiTelemedicine grant/loan and a BIP grant/loan, GCI and its affiliates have and areconstructing a microwave/fiber middle-mile transport facility to connect southwestern Alaskaand Anchorage. This middle-mile network is already allowing GCI to deliver high bandwidth,low-latency connections for critical telemedicine applications such as telepsychiatry.
1200 18TH STREET, NW I SUITE 1200 I WASHINGTON, OC 20036 I TEL 202-730-1300 I FAX 202-730-1301 I WILTSHIREGRANNIS.COM
Ms. Marlene H. DortchMay 10,2011Page 2 of2
It will be extremely costly to construct the middle-mile facilities necessary to delivermodem broadband services to anchor institutions and the mass market in Alaska. As anexample, GCI submitted a Round 2 BIP application for $150 million in loan/grant funding tosupport a second middle-mile segment. In addition to large upfront construction costs, thesenetworks - as well as the last-mile networks - cost millions to operate every year. Many factorscontribute to Alaska's high operating costs, not the least of which are its topography, climate,and high power costs, which typically are 5 to 10 times higher than the national average. AndAlaska has a population that is far too small to support the costs of these networks on their own.
Accordingly, it makes little sense to phase down high-cost support in Alaska to fund anationwide Phase 1 Connect America Fund that, as proposed, is unlikely to provide any benefitto Alaska. A better transitional path would be to extend the Commission's tribal landsmechanism to all forms of high cost support and all ETCs serving tribal lands, and then todetermine the best long-term approach to support both the deployment and operation oflastmile and middle-mile networks in Alaska.
We also discussed that, with respect to Lifeline services, a one per qualifying adult rulebetter recognizes the reality of wireless-only households, and the need to ensure that lowincome consumers have the ability to place 911 calls in an emergency, no matter where they arelocated.
A copy of this letter is being filed in the above-referenced docket.
SincerelY,~
~~taCounsel to General Communication Inc.
cc:Zac KatzChristine KurthAngela KronenbergSharon GillettTheodore BurmeisterRebekah GoodheartPatrick HalleyCarol MatteyMichael Steffen
Attachment
Alaska and Universal ServiceReform
General Communication, Inc.
May 2011
Alaska is Unique
• Enormous- 570/627 Square Miles, roughly 1/5 the size of the lower 48
• Limited road system - Over 200 communities are "off-road JJ
• Sparse Population- 710/231 residents- Approximately 1.2 persons per square mile, compared to 103.8
persons per square mile in the lower 48
• Rough Terrain and Climate- Mountains, islands, rivers, and lack of roads- Short construction season (May to October)
• Rural areas rely on satellite middle mile
Alaska TelecommunicationsChallenges and Benefits
..
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Alaska/s Limited Road & Pipeline
System
--------------------------~
Alaska's Fiber "Backbone"
Actual Alaa8:a Flbsr
- Fr:tnGCI~~
o Census 'CouIt1Ies'
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•
Alaska's ILEC Exchanges
Alaska ILEe Exchanges
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ARC'I1C8LCI'E TEL • 012'TEL COOPERA:IlIIE
EETTU:8 tEL co INC .. 6ULNITtEL6 'TEL-M
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Alaska's Wireless Coverage (2009)
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Gel - Bringing Wireless to Rural Alaska
111:1
Gel Wireless Availability
• Current - Voice. Text and Data
• 2011 (Planned): 11 Communities
• 2012 (Planned): 52 Communities
SuttPauI •5alnt George •
Adak*.,J, • AIlca
Build •Ing the Middle Mile - The Key to
o 100 200 Miles..I-....- .....~-...-+I-.........- ...- ...- ..I
(~..
Hooper Bay ._~•._"-""'
- New Fiber-Optic Network
- New Microwave Network
- Upgraded Gel Fiber-Optic Network
- Upgraded Microwave Network
- Leased Facilnies
- Existing Gel Fiber-Optic Network
TERRA-SW Served Community
• TERRA-SW Microwave Repeater
Rural Broadband
,
An Illustrative Vision of a 21st CenturyAlaska Broadband Network
TERRA Project
-1&
-TERRA-SW
-TERRA-NW
-TERRA-NS
Kobuk-Pipeline Ring Closure
- Existing Gel FIber
TERRA-SW
• TERRA-NW
• TERRA-NS
• Kobuk-Pipeline Ring Closure
• Repeater
o 100 200 Miles• • • • I .... • •
Illustrative only - unconstructed routes subject to change.
