Supplemental Information In Support of Joint Appli SUPPLEMENT by Ace Telephone Company of Michigan Inc ITC-T/C-20150922-00227 Supplemental Informa

Supplemental Informa

SUPPLEMENT submitted by Ace Telephone Company of Michigan Inc

Supplemental Information In Support of Joint Appli

2015-12-03

This document pretains to ITC-T/C-20150922-00227 for Transfer of Control on a International Telecommunications filing.

IBFS_ITCTC2015092200227_1117196

Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554

In the Matter of the Joint Application of )
)
Great Lakes Comnet, Inc., )
)
Transferor )
)
and ) WC Docket No. 15-224
)
Ace Telephone Association and ) IB File No. ITC-T/C-20150922-00226
Ace Telephone Company of Michigan, Inc. )
) IB File No. ITC-T/C-20150922-00227
Transferees. )
)
Pursuant to Section 214 of the )
Communications Act of 1934, as Amended, for )
Approval of the Transfer of Control of )
Great Lakes Comnet, Inc., )
Clinton County Telephone Company, )
Westphalia Telephone Company, )
Westphalia Broadband, Inc., and )
Comlink, LLC )
to Ace Telephone Company of Michigan, Inc. and )
Ace Telephone Association )
)

SUPPLEMENTAL INFORMATION IN SUPPORT OF
JOINT APPLICATION

In support of their Joint Application in this matter, Great Lakes Comnet, Inc. (“GLC”),

Clinton County Telephone Company (“CCTC”), Westphalia Telephone Company (“WTC”),

Westphalia Broadband, Inc. (“WBI”), Comlink, LLC (“Comlink”), Ace Telephone Association

(“ATA”) and Ace Telephone Company of Michigan, Inc. (“Ace Michigan”), collectively “Joint

Applicants,” hereby respectfully provide the supplemental information contained herein. The

purpose of this supplemental filing is to describe the geographic territories in which the Joint

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Applicants either provide service or have network facilities, as well as to identify over-lapping or

adjacent geographic territories in which the transferee and transferor entities have customers.

I. Geographic Territories of ATA, Ace Michigan, and Ace Link.

ATA is a telephone cooperative headquartered in Houston, Minnesota. ATA provides

local exchange service as an incumbent local exchange carrier (“ILEC”), long distance,

broadband Internet services, video service, and a variety of other services in small towns and

rural areas located in: (i) the Castalia, Clermont, Dorchester, Fort Atkinson, Highlandville,

Harpers Ferry, New Albin, Ossian, and Waterville exchanges located in Iowa; and (ii) the

Brownsville, Canton, Dakota, Eitzen, Granger, Hokah, Houston, La Crescent, Lanesboro,

Ostrander, Peterson, Rushford exchanges located in Minnesota. Maps showing the general

locations of the Iowa and Minnesota exchanges in which ATA provides service are contained in

Attachment A.

Ace Link Telecommunications, Inc. (“Ace Link”) is a wholly-owned subsidiary of ATA

that provides local exchange service as a competitive local exchange carrier (“CLEC”), exchange

access, and broadband Internet services in the Caledonia exchange located in Minnesota. The

general location of the Caledonia exchange is shown in Attachment A.

Ace Michigan, a wholly-owned subsidiary of ATA, is an ILEC licensed by the Michigan

Public Service Commission (“MPSC”)1 that provides local exchange service, exchange access,

domestic long distance service, broadband Internet service, and video services to the Allendale,

Buckley, Copemish-Thompsonville, Drenthe, Hoxeyville, Mesick, Old Mission and South

Boardman exchanges located in Michigan. Additionally, Ace Michigan, as a CLEC, provides

1
August 14, 1992 Order in MPSC Case No. U-10054; 136 PUR 4th 93; 1992 WL 230483; December 21, 2010
Order in MPSC Case No. U-16468; August 13, 2013 Order in MPSC Case No. U-17262.

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local exchange service, toll, broadband Internet, and video services to the Coopersville, Holland,

and Zeeland exchanges located in Michigan. See the telephone exchange map attached hereto as

Attachment B for the location of the Michigan exchanges in which Ace Michigan provides

service.

II. Geographic Territories of GLC and Its Subsidiaries.

GLC is a broadband network and switching infrastructure company that is registered as a

competitive access provider (“CAP”) in Michigan. As a CAP, GLC is a “carriers’ carrier” that

does not have any end-user customers and does not serve the general public in any state. GLC’s

network facilities provide tandem switching, long-haul Internet connectivity, video and other

transport, toll resale, wholesale Ethernet, Signaling System 7 (SS7), and point-to-point services

to telecommunication providers. GLC’s facilities are used by ILECs, CLECs, toll service

providers that are homed to its tandem, and data and video providers. GLC’s tandem switch is

located in Westphalia, Michigan, and GLC’s transport facilities are located throughout Michigan,

as well as in portions of Ohio, Indiana, and Illinois. GLC has network facilities, but no carrier

customers, in Minnesota and Wisconsin. See Attachment C.

GLC’s wholly-owned subsidiary, Comlink, provides local exchange service as a CLEC,2

and also provides exchange access, broadband Internet service, point-to-point private line

services, domestic and international toll services,3 and cloud computing and data center services.

Comlink provides services in numerous exchanges throughout Michigan. While most of

Comlink’s end user customers are located in Michigan, it also has some end user customers in

Ohio, Indiana, Illinois, and Wisconsin.

2
Comlink was licensed by the MPSC’s June 3, 2004 Order in Case No. U-14041.
3
Comlink provides resold international toll service pursuant to GLC’s international § 214 authority. See
correspondence dated February 17, 2011 filed with the International Bureau in GLC’s international license file.

3

WTC is an ILEC, and is licensed by the MPSC4 to serve an area known as the Westphalia

exchange in Michigan. A map of the Westphalia exchange is appended as Attachment D. WTC

provides local exchange service, exchange access, broadband Internet service, video, private line,

transport, and other telecommunications services to business and residential customers in the

Westphalia exchange.

WBI, d/b/a Comlink, is a CLEC licensed by the MPSC.5 WBI provides local exchange

service, exchange access, broadband Internet service, private line, transport and video service in

the following areas: (1) the DeWitt exchange, (2) the St. Johns exchange, and (3) the Fowler

exchange (a/k/a the Fowler-Pewamo exchange). WBI also provides video service in the Lansing

exchange. Maps of the DeWitt, St. Johns, Lansing and Fowler exchanges can be found at

Attachment E.

CCTC is a holding company that does not itself offer any telecommunications services.

WTC and WBI are wholly-owned subsidiaries of CCTC.

III. Overlapping and Adjacent Geographic Territories.

With respect to exchanges served by transferees ATA, Ace Michigan and Ace Link, or

exchanges that are adjacent to their ILEC exchanges, the tables below describe where Comlink,

WBI, and WTC provide service, and where GLC has network facilities. For purposes of this

Section III, “Transferor Entity” refers collectively to GLC, Comlink, CCTC, WTC and WBI, and

“Transferee Entity” refers collectively to Ace Michigan, ATA, and Ace Link. The term “CLEC

Operations” refers to the operations as a CLEC of an entity itself or via a separately-incorporated

4
August 14, 1992 Order in MPSC Case No. U-10054; 136 PUR 4th 93; 1992 WL 230483.
5
July 22, 2004 Order in MPSC Case No. U-14119; 2004 WL 1746427.

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affiliated entity. As shown in the maps appended to this supplemental information and in the

tables below:

 None of the ILEC Exchanges of the Transferor Entities or Transferee Entities
Overlap or are Adjacent to Each Other: The ILEC exchanges of the ILECs
involved in the transaction—Ace Michigan, ATA, and WTC—are geographically
separated from each other, and therefore: (i) do not overlap; and (ii) are not
adjacent to each other.

 No CLEC Operations of a Transferor Entity or Transferee Entity Provide Service
in any Transferor Entity or Transferee Entity ILEC Exchange: No CLEC
Operations of the Transferor Entities provide any service to end users in any
ILEC exchange of the Transferee Entities (i.e., Ace Michigan, Ace Link, or
ATA), and no CLEC Operations of the Transferee Entities provide any service to
end users in any ILEC exchange of a Transferor Entity (i.e., WTC).

 CLEC Operations in Exchanges Adjacent to ILEC Exchanges: Comlink, a
CLEC, has 5 or fewer end user customers in 7 exchanges that are adjacent to Ace
Michigan ILEC exchanges (the Traverse City, Cadillac, Ravenna, Fruitport,
Hudsonville, Ravenna, and Hamilton exchanges).

 Limited Overlap of CLEC Service Territories: Comlink, a CLEC, has 5 or fewer
end user customers in the Coopersville, Holland, and Zeeland exchanges, where
Ace Michigan has CLEC Operations.

 GLC does not serve end user customers, but has fiber facilities located in the Ace
Michigan ILEC exchanges that are used by Ace Michigan for traffic transport.

Exchanges Served Transferor Entities
By Transferee Entity:
ATA

Iowa exchanges: Castalia, Comlink, WTC, and WBI do not serve any end-user customers, the general public, or
Clermont, Dorchester, Fort any carrier customers in Iowa or Minnesota.
Atkinson, Highlandville,
Harpers Ferry, New Albin, GLC does not provide service to any end-user, the general public, or carrier customer
Ossian, and Waterville. in Iowa.
Minnesota GLC does not provide service to any end-user, the general public, or carrier customer
exchanges: Brownsville,
in Minnesota.
Canton, Dakota, Eitzen,
Granger, Hokah, Houston,
La Crescent, Lanesboro, GLC has fiber facilities located in Duluth, Minnesota, which is not in, or adjacent to,
Ostrander, Peterson, and any exchange served by ATA, and those facilities are not currently in use.
Rushford exchanges.

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Exchanges Served Adjacent Transferor Entities
By Transferee Exchanges
Entity:
Ace Michigan
Allendale Exchanges adjacent to GLC does not provide any service to any end-user customer
Allendale: Grand Haven, or to the general public in Michigan. GLC has network
Marne, Hudsonville, facilities (but no end user customers) throughout Michigan,
Borculo and Jamestown including in the Ace Michigan exchanges and some adjacent
exchanges.
Exchanges adjacent to
Drenthe Drenthe: Hudsonville, Comlink has five or fewer end-user customers in each of the
Jamestown, and Hamilton following exchanges that are served by, or adjacent to, Ace
Michigan:
Exchanges adjacent to Traverse City
Copemish-Thompsonville, Cadillac
Copemish-Thompsonville, Buckley and Mesick: Ravenna
Buckley and Mesick Harietta, Kaleva, Bear Fruitport
Lake, Beulah, Lake Ann, Coopersville
Kingsley, Manton, and Hudsonville
Cadillac Holland
Ravenna
Exchanges adjacent to Zeeland
Hoxeyville : Harietta, Hamilton
Brethren, Kaleva, Wellston,
Hoxeyville Dublin, Irons, Luther,
Tustin, and Cadillac

South Boardman Exchanges adjacent to
South Boardman: Fife WTC does not provide any service in any exchange served
Lake, Kingsley, Traverse by, or adjacent to, Ace Michigan.
City, Williamburg,
Kalkaska, Manistee River, WBI does not provide any service in any exchange served by,
Moorestown and Lake City or adjacent to, Ace Michigan.

Old Mission Exchanges adjacent to Old
Mission: Traverse City

Coopersville exchange located Exchanges adjacent to
Michigan Coopersville: Grand Haven,
Fruitport, Ravenna, Conklin,
and Marne

Holland, and Zeeland Exchanges adjacent to Holland
exchanges located in Michigan. and Zeeland: Grand Haven,
Borculo, Hudsonville,
Jamestown, Hamilton, and
Saugatuck

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Document Created: 2015-12-03 17:55:06
Document Modified: 2015-12-03 17:55:06

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