Attachment Narrative Statement

This document pretains to ITC-T/C-INTR2018-05242 for Transfer of Control on a International Telecommunications filing.

IBFS_ITCTCINTR201805242_1501431

September 24, 2018

FILED VIA IBFS

International Bureau
Federal Communications Commission
Washington, DC 20554

Re:    Illinois Valley Cellular RSA 2-I Partnership
       File No. ITC-T/C-20180829-00168

Dear Sir/Madam:

       Illinois Valley Cellular RSA 2-I Partnership (“IVC RSA 2-I”) hereby files, by counsel, a
Revised Narrative Statement to the above-referenced application. The Revised Narrative
Statement deletes all references to nunc pro tunc approval.

       Please do not hesitate to contact the undersigned if you have any questions.

                                                           Sincerely,

                                                           Robert S. Koppel
                                                           Counsel to IVC RSA 2-I

Attachment


Attachment 1
FCC Form 214
Transfer of Control of IVC RSA 2-I
Page 1



                       REVISED DESCRIPTION OF TRANSACTION
                         AND PUBLIC INTEREST STATEMENT

        In this application, Illinois Valley Cellular RSA 2-I Partnership (“IVC RSA 2-I”) seeks
consent from the Commission to transfer control of the Section 214 authorization for global
resale, File No. ITC-214-20010507-00291 of IVC RSA 2-I (with no single owner holding more
than a 40% interest) to MTCO Corporation (“MTCO”).

         Prior to January 1, 2017, the ownership of IVC RSA 2-I consisted of the following: (1)
Tonica Cellular, Inc. (“Tonica”) held an 11.11 percent general partnership interest in IVC RSA
2-I; (2) Leonore Cellular, Inc. (“Leonore”) held a 14.51 percent general partnership interest in
IVC RSA 2-I; (3) Cencomm, Inc. (“Cencomm”) held a 37.19 percent general partnership interest
in IVC RSA 2-I; and (4) Marseilles Cellular, Inc. (“Marseilles”), which is 100% owned by
MTCO, held a 37.19 percent general partnership interest in IVC RSA 2-I.

        On January 1, 2017, the general partnership interests held by Leonore (14.51 percent) and
Cencomm (37.19 percent) were distributed to Marseilles and Tonica. As a result, MTCO’s
indirect general partnership interest in IVC RSA 2-I increased from 37.19 percent to 77 percent
and Tonica’s general partnership interest in IVC RSA 2-II increased from 11.11 percent to 23
percent.

        The Parties respectfully submit that Commission approval of the transfer of control will
serve the public interest, convenience, and necessity. IVC RSA 2-I is a longstanding FCC
licensee, operating state of the art digital wireless networks in eight counties running from the
Indiana State line to south of Chicago, to near Peoria, Illinois and then on towards the Iowa state
line. Unlike other wireless providers, it has concentrated on building towers that serve the needs
of the local communities and the rural farming community. IVC RSA 2-I holds several licenses
in good standing and provides commercial mobile wireless service in furtherance of the public
interest. Finally, the transaction that triggered the transfer of control did not impact the
operations of IVC RSA 2-I, including its customers, as there was no change in the operations of
the partnership.

        The Commission has determined that applications that demonstrate on their face that a
transaction will yield affirmative competitive public interest benefits and will neither violate the
Act or Commission rules, nor frustrate or undermine policies and enforcement of the Act by
reducing competition or otherwise, do not require extensive review or expenditure of
considerable resources by the Commission. This transaction meets this standard and should thus
be granted promptly.

       By separate application, Special Temporary Authority (“STA”) is requested to allow for
continued operation and continued service to customers by IVC RSA 2-I while this application is
considered by the International Bureau.


Attachment 1
FCC Form 214
Transfer of Control of IVC RSA 2-I
Page 2



ANSWER TO QUESTION 10

Information for Transferor, Section 214 Holder, and Transferee

Section 214 Holder & Transferor: IVC RSA 2-I

Contact point:
Glenn Rauh
Illinois Valley Cellular
200 Riverfront Drive
Marseilles, IL 61341
815-795-3200

Transferee: MTCO Corporation

Contact point:
Ann E. Dickerson
MTCO Corporation
220 N. Menard Street
Metamora, IL 61548
309-366-6120

Regulatory Counsel to Section 214 holder, Transferor and Transferee

Pamela Gist
Todd Slamowitz
Robert S. Koppel
Lukas, LaFuria, Gutierrez & Sachs, LLP
8300 Greensboro Drive, Suite 1200
Tyson, VA 22102
703-584-8669
bkoppel@fcclaw.com


ANSWER TO QUESTION 11

Direct and Indirect Ownership of Transferee

        Rauh Enterprises, L.P. directly owns 36.53 percent of MTCO Corporation. Its business
address is 220 North Menard Street, Metamora, IL 61548. It is organized in the United States,
and its principal business is investments.



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Document Created: 2018-08-20 13:09:14
Document Modified: 2018-08-20 13:09:14

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