Attachment attch 2

This document pretains to ITC-STA-20130718-00196 for Special Temporal Authority on a International Telecommunications filing.

IBFS_ITCSTA2013071800196_1004573

                               REQUEST FOR SPECIAL TEMPORARY AUTHORITY


        Long Lines Wireless, LLC (the "Applicant"), is a Tier—3 CMRS provider operating primarily in rural
areas of northwestern lowa, but also in portions of Minnesota, Nebraska, and South Dakota. On July 2,
2013, Applicant applied for an authorization pursuant to 47 U.S.C. § 214 to provide telecommunications
services between the United States and international locations. (FCC File No. 1B2013001423.)

         As more fully set forth below, so as not to inconvenience Applicant‘s subscribers by terminating
their current international calling capability, Applicant now requests special temporary authority ("STA")
to continue originating and terminating international wireless services during the pendency of
Applicant‘s international 214 application. The STA would continue until the Commission resolves
Applicant‘s underlying international 214 application. In support of this request, Applicant states:

       1.    Applicant is a direct wholly—owned subsidiary of Long Lines Communications, LLC
("Communications").

        2.   Until February 2011, Applicant was a direct wholly—owned subsidiary of Long Lines, LLC
("Long Lines"), a provider of wireline voice video, and data services in roughly the same geographic area
as the Applicant. Long Lines is itself a direct wholly—owned subsidiary of Communications and,
therefore, until February 2011, Applicant was an indirect subsidiary of Communications. In February
2011, Applicant was moved from under Long Lines to become a direct subsidiary of Communications as
part of a process to separate the wireless and wireline operations of Communications and, ultimately, to
sell the wireless operation.

        3. Long Lines, and its predecessors, has held an international 214 authorization for many years.
While Applicant was a direct subsidiary of Long Lines, Applicant originated and terminated wireless calls
between the United States and international locations pursuant to the Long Lines authorization. When
Applicant ceased being a direct subsidiary of Long Lines in February 2011, Applicant‘s management
failed to apply for a separate international 214 authorization and, since that time, Applicant has
originated and terminated international wireless calls without proper authorization.

        4. On or about July 2, 2013, in connection with negotiation of a potential sale of the Applicant,
Communications discovered that the Applicant had failed to apply for an international 214 authorization
when it was moved for under Long Lines. An application for the international 214 authorization was
filed later that day. Communications is now monitoring the situation and will ensure that the Applicant
remains in compliance with the Commission‘s rules going forward.

        5.   The Applicant acknowledges that the grant of this STA will not prejudice any action the
Commission may take on the underlying international 214 application. Applicant further acknowledges
that this STA can be modified or revoked by the Commission upon its own motion without a hearing.




                                                 Respectfully submitted,

                                                 LONG LINES WIRELESS, LLC



Document Created: 2019-04-15 21:56:34
Document Modified: 2019-04-15 21:56:34

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