Attachment Attachment 1

This document pretains to ITC-STA-20150720-00173 for Special Temporal Authority on a International Telecommunications filing.

IBFS_ITCSTA2015072000173_1096111

Attachment 1 Response to Item 10: Special Temporary Authority (“STA”) is hereby requested for Sierra Telephone Long Distance (“STLD”) to continue uninterrupted service to the public while an application for Section 214 authorization for a transfer of control of Sierra Telephone Company, Inc. (“STC”) and STLD (jointly, the “214 Holders”) from Harry H. Baker, Jr. to John H. Baker is processed by the Commission (the “214 Application”).1 As explained in more detail in the attached request for Domestic Section 214 STA,2 a transfer of control of STC and STLD occurred on January 12, 2015 when John H. Baker became successor and sole trustee for each of the two trusts that hold a combined 98% of the voting stock of Sierra Tel Communications Group (“STCG”), the sole stockholder of each of the 214 Holders. John H. Baker is familiar with operations of the operating companies, having served as an officer of STC since 1981, and STLD since 1998. The 214 Holders remain the carriers of record to customers. Grant of the requested STA will serve the public interest, convenience and necessity because it will permit the continued provision of service by STLD without interruption to customers while the Commission considers the 214 Application. Customers rely upon STLD for telecommunications service and would be adversely impacted if there was a disruption of service while the 214 Application is processed. This STA request and the 214 Application demonstrate the qualifications of John H. Baker to control STLD, and that the past transfer of control of STLD does not present any eligibility or anticompetitive concerns under applicable Commission rules and policies. 1 STC, STLD and John H. Baker are parties to a Joint Application for Transfer of Control of Domestic and International Section 214 authorizations filed contemporaneously herewith. 2 See Attachment 3 of this application.

As the international Section 214 authorization holder, STLD acknowledges that grant of this STA request will not prejudice any action the Commission may take on the 214 Application. The parties further acknowledge that STA may be revoked by the Commission upon its own motion without a hearing. The parties acknowledge that grant of the STA request and the 214 Application will not preclude enforcement action for the unauthorized transfer of control. Response to Item 16: With reference to Section 63.18(d) of the Commission’s rules, STLD holds the following international Section 214 authorization which is the subject of this STA request: File No. ITC- 214-19960718-00321 (Old File No. ITC-96-391), granted September 9, 1996. That authorization is for Global Resale Service. In response to Section 63.18(e)(3) of the Commission’s rules, STLD hereby certifies that it will comply with the terms and conditions contained in Section 63.22 of the Commission’s rules. (Section 63.21 which concerns facilities-based international carriers is inapplicable to this STA request.) Section 63.18(g) of the Commission’s rules is not applicable because STLD does not seek facilities-based authority. 2


Document Created: 2015-07-15 09:15:37
Document Modified: 2015-07-15 09:15:37
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