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  • September 25, 2018

    Via Electronic Filing and Overnight Delivery Public Utility Commission of Oregon 201 High Street SE, Suite 100 Salem, Oregon 97301-3398

    RE: Viasat Carrier Services. Inc. Petition for Designation as an Eligible Telecommunications Carrier/ Request for Confidential Treatment

    Dear Sir/Madam:

    On behalf of Viasat Carrier Services. Inc., (“Viasat” or the “Company”), transmitted herewith for filing is a redacted version of the Company’s Petition for Designation as an Eligible Telecommunications Carrier (“ETC”) in the State of Oregon. A CONFIDENTIAL version of the Petition is being provided to the Commission via overnight delivery.

    Please acknowledge receipt of the overnight delivery of the CONFIDENTIAL filing by date-stamping the extra copy of this cover letter, and returning it to me in the self-addressed, stamped envelope for that purpose.

    Any questions regarding this filing should be directed to the undersigned.

    Respectfully submitted,

    Michael P. Donahue Marashlian & Donahue, PLLC

    1420 Spring Hill Road, Suite 401 McLean, VA 22102 Tel: 703-714-1319 Fax: 703-563-6222 Email: [email protected]

    Enclosures

    mailto:[email protected]

  • 1

    BEFORE THE

    PUBLIC UTILITY COMMISSION OF OREGON

    In the Matter of

    Application of Viasat Carrier Services, Inc. for Designation as an Eligible Telecommunications Carrier to Receive Connect America Fund Phase II Auction (Auction 903) Support for Voice and Broadband Services

    Docket No. ___________

    APLICATION OF VIASAT CARRIER SERVCIES, INC. FOR DESIGNATION AS AN ELIGIBLE ELECOMMUNICATIONS CARRIER TO RECEIVE CONNECT AMERICA FUND PHASE II AUCTION (AUCTION 903) SUPPORT FOR VOICE AND BROADBAND SERVICES AND REQUEST FOR EXPEDITED CONSIDERATION

    APPLICATION OF VIASAT CARRIER SERVICES, INC. FOR LIMITED DESIGNATION AS AN ELIGIBLE TELECOMMUNICATIONS CARRIER TO RECEIVE CONNECT AMERICA FUND

    PHASE II AUCTION (AUCTION 903) SUPPORT FOR VOICE AND BROADBAND SERVICES AND

    REQUEST FOR EXPEDITED CONSIDERATION

    Viasat Carrier Services, Inc. (“Viasat” or the “Company”) pursuant to section 214(e)(2) of the

    Communications Act of 1934, as amended (the “Act”),1 Sections 54.201 and 54.2022 of the rules and

    regulations of the Federal Communications Commission ("FCC"), and in accordance with the Public

    Utility Commission of Oregon’s (“Commission”) requirements as set forth in Order No. 15-382 in

    Docket UM 1648,3 hereby submits this Application for Designation as an Eligible Telecommunications

    Carrier ("ETC"). Viasat’s parent company, Viasat, Inc. (“VSI”), was selected as a winning bidder for

    291 Census Block Groups in Oregon4 under the FCC's Connect America Fund Phase II Auction

    (Auction 903) (the “CAF II Auction”).5 However, Viasat’s receipt of CAF II Auction funding is

    1 47 U.S.C. § 214(e)(2), 2 47 C.F.R §§ 54.201 and 54.202. 3 Public Utility Commission of Oregon Staff Investigation into Eligible Communications Carrier Requirements, Docket UM 1648, Order No. 15-382 (Dec. 1, 2015) ("Oregon ETC Order"). 4 Connect America Fund Phase II Auction (Auction 903) Closes Winning Bidder Announced FCC Form 683

    Due October 15, 2018, AU Docket No. 17-182, WC Docket No. 10-90, Public Notice, DA 18-887, (rel. Aug.

    28, 2018) (“Auction 903 Results Notice”), Attachment A at 10; see also

    https://auctiondata.fcc.gov/public/projects/auction903/reports/all_assigned_census_blocks (listing winning

    bidders). 5 See Connect America Fund Phase II Auction Scheduled for July 24, 2018; Notice and Filing Requirements and Other Procedures for Auction 903, Public Notice, FCC 18-6, 33 FCC Rcd 1428 (2018) (“Auction 903

    https://auctiondata.fcc.gov/public/projects/auction903/reports/all_assigned_census_blocks

  • 2

    conditioned upon ViaSat obtaining designation as an ETC in the eligible Census Blocks by February

    25, 2019.6 Accordingly, Viasat seeks designation only in the Census Blocks for which it was awarded

    funding from the CAF II Auction, as identified in Exhibit A.

    Section 214(e)(2) of the Act authorizes the Commission to designate a company that meets

    the requirements of 47 U.S.C. § 214(e)(1), such as Viasat, as an ETC. In the Oregon ETC Order,

    the Commission adopted updated guidelines for companies seeking ETC designation in Oregon “to

    enable the Commission to acquire the data it needs to fulfill its oversight role and protect the

    public interest, while addressing the burdens of compliance on service providers."7 As

    demonstrated in this Application, Viasat meets all state and federal requirements for ETC designation,

    and, as shown by the description herein of Viasat’s planned voice and broadband deployment

    projects, designating Viasat as an ETC in the proposed areas would advance the goals of universal

    service and is in the public interest.

    In support of this Application, Viasat states as follows: I. BACKGROUND

    Viasat is a Delaware corporation headquartered at 6155 El Camino Real, Carlsbad, California

    92009. Viasat is filing a registration with the Oregon Secretary of State to qualify to do business in

    Oregon as a foreign corporation and will provide a copy of its Certificate of Authority as a soon as it

    is available. Viasat is a wholly-owned subsidiary of VSI, a Delaware corporation also headquartered

    at 6155 El Camino Real, Carlsbad, California 92009. Viasat will outsource technical, billing,

    installation, and customer service matters to VSI as doing so is more efficient and cost-effective than

    creating duplicative functions. Viasat will also rely on the significant managerial and technical

    expertise of VSI.

    Procedures Public Notice”). 6 Auction 903 Results Notice fn. 11. 7 Oregon ETC Order, at 6 (quoting Order No. 14-198 at 6 (Jun 5, 2014)).

  • 3

    Viasat’s parent company, VSI, is an innovator in broadband technologies and services. VSI’s

    end-to-end platform of high-capacity Ka-band satellites, ground infrastructure and user terminals enables

    VSI to provide cost-effective, high-speed, high-quality broadband solutions to enterprises, consumers

    and government users around the globe. In addition, VSI develops and provides advanced wireless

    communications systems, secure networking systems and cybersecurity and information assurance

    products and services. VSI’s satellite networks support broadband Internet access, video streaming, and

    voice over IP (“VoIP”), among other applications. VSI provides broadband and VoIP services to

    customers in all fifty states and the District of Columbia. VSI has previously deployed several consumer

    broadband networks, starting with the WildBlue-1 network, which was deployed in 2005 and has

    operated continuously since that time. In 2011, VSI deployed the ViaSat-1 satellite network, which VSI

    has used to provide high-speed, high-quality broadband services to consumers and other end users. In

    2017, VSI deployed the ViaSat-2 satellite network, which commenced service in April 2018. In addition,

    VSI has a new satellite under construction and ready for launch in the 2020 timeframe, ViaSat-3, which

    will allow Viasat to offer even higher speeds of broadband service and more capacity than ViaSat-2.

    VSI’s satellite networks utilize geostationary-satellite orbit (“GSO”) satellite technologies. Last-

    mile connectivity is provided to end users through GSO user terminals that communicate directly with

    VSI’s satellites. VSI’s satellites also connect to satellite access nodes (“SANs”) that are located on the

    ground and interconnect with the Internet, PSTN, and other terrestrial networks using leased fiber.

    II. COMMUNICATIONS AND CORRESPONDENCE

    Pleadings, orders, notices, or other correspondence and communications regarding this

    Application should be provided to:

    Jason Sophinos Associate General Counsel ViaSat, Inc. 349 Inverness Drive South Englewood, CO 80112 Tel: 720-493-6365 Email: [email protected]

    mailto:[email protected]

  • 4

    With a copy to:

    Michael P. Donahue Linda G. McReynolds Marashlian & Donahue, PLLC 1420 Spring Hill Road, Suite 401 Tysons, VA 22102 Tel: 703-714-1319 Fax: 703-563-6222 E-Mail: [email protected] [email protected]

    III. VIASAT’S PROPOSED PARTICIPATION IN THE FCC'S CAF II AUCTION

    A. Background on the CAF II Auction

    On January 31, 2018, the FCC issued an Order on Reconsideration concerning its Connect

    America Fund initiative, which enabled the FCC to move forward with the CAF II Auction, in which

    service providers competed to receive up to $1.98 billion to offer voice and broadband service in

    unserved high-cost areas.8 That Order followed a series of orders establishing the details of the CAF

    II Auction.9 Under this program the FCC will disburse up to $198 million annually for providers—

    including competitive providers such as competitive local exchange carriers, cable operators, fixed

    wireless ISPs, satellite broadband, or alternative providers such as electric utilities and governmental

    entities— to deploy broadband networks in high-cost, unserved price cap areas.

    B. Visat’s Selection as a Winning Bidder

    The FCC’s August 28, 2018 Auction 903 Results Notice announced that VSI was among the

    winners of the recently-concluded CAF II Auction.10 Specifically, the FCC designated VSI as a winning

    bidder in 291 Census Block Groups in Oregon. In accordance with the FCC’s procedures,11 VSI

    assigned its winning bid to Viasat. In order for Viasat to receive the CAF II Auction support that it has

    8 Connect America Fund, et al., Order on Reconsideration, 33 FCC Rcd 1380 (2018). 9 See, e.g., Connect America Fund et al., Report and Order and Further Notice of Proposed Rulemaking, 31 FCC Rcd 5949 (2016) (“Phase II Auction Order”); Connect America Fund, et al., Report and Order and Order on Reconsideration, 32 FCC Rcd 1624 (2017) (“Phase II Auction FNPRM Order”); Connect America Fund et al., Report and Order and Further Notice of Proposed Rulemaking, 26 FCC Rcd 17663 (2011) (“USF/ICC Transformation Order”). 10 Auction 903 Results Notice, Attachment A at 10. 11 See Auction 903 Procedures Public Notice, para. 37.

    mailto:[email protected]:[email protected]

  • 5

    been awarded, it must demonstrate to the FCC that it has been designated as an ETC in the areas

    where it was the winning bidder. The FCC’s deadline for submitting proof of the ETC designation is

    February 25, 2019.12

    C. Need for Expedited ETC Designation

    The FCC did not require that CAF II Auction participants be designated ETCs at the time they

    filed their applications. However, winning bidders must, within 180 days of being announced as

    winning bidders, obtain ETC designation in any areas for which they are awarded support and submit

    appropriate documentation of such ETC status to the FCC.13 As noted, Viasat has been selected as a

    winning bidder in the CAF II Auction for 291 Census Block Groups in Oregon. Because the timeframe

    for Viasat to obtain ETC designation is short and the consequences of failure to do so are severe,

    Viasat respectfully requests that the Commission review this Application promptly and grant Viasat

    ETC designation in the Census Blocks identified in this Application on an expedited basis.

    IV. VIASAT AND ITS TECHNICAL QUALIFICATIONS

    A. ViaSat’s Expertise and Experience

    Viasat’s parent company, VSI, is a leading provider of communications solutions across a wide

    variety of technologies (both terrestrial and satellite), and has played a significant role in expanding

    the availability of broadband services across the country. Among other things, VSI has revolutionized

    the satellite industry by reducing the “cost per bit” of delivering broadband service. As a result, VSI

    now provides high-quality broadband service to end users, and affords millions of Americans—

    including in rural and “high-cost” areas—an effective competitive alternative to wired and wireless

    terrestrial services, which rely on infrastructure that is often less cost-effective.

    12 Auction 903 Results Notice, para. 15, n. 11 (“By February 25, 2019, the long-form applicant must obtain from all the relevant states or the Commission a high-cost ETC designation(s) that cover its winning bid areas and upload the required documentation and a certification letter to its FCC Form 683.”). 13 See 47 CFR §§ 54.310(e)(1), 54.315(b)(5); see also Auction 903 Procedures Public Notice, 33 FCC Rcd 1428, 1473 (“the [FCC] decided that an applicant need not be an ETC as of the initial short-form application

    filing deadline for Auction 903, but that it must obtain a high-cost ETC designation for the areas covered by

    its winning bids within 180 days after being announced as a winning bidder”); Auction 903 Results Notice, DA 18-887, para. 34.

  • 6

    Viasat is qualified to meet applicable CAF II obligations given VSI’s proven track record of

    technical and commercial success operating as a provider of satellite broadband services and

    associated equipment. VSI’s technical qualifications have been reviewed by the FCC on numerous

    occasions, and the favorable results of such reviews are reflected in the multiple FCC licenses and

    authorizations granted to the company. VSI also holds a number of patents with respect to satellite

    technology, which cover, among other things, user terminals and networking and demonstrate the

    company’s commitment to the development of innovative network solutions. Viasat is proud to have

    at its disposal VSI’s extensive staff of experienced engineers with expertise in the fields of

    communications technology, hardware design, software development, data analytics, and

    networking. This expertise made it possible for Viasat to confidently participate in the CAF II auction

    with the certainty that the company will be able to fulfill its obligations.

    Today, VSI serves customers in all fifty states, as well as the District of Columbia. These

    customers include almost 600,000 residential customers. In addition, VSI connects millions of

    personal electronic devices per month on aircraft that rely on satellite broadband for connectivity to

    the Internet. VSI also has extensive experience managing the technical and customer service-related

    issues associated with the provision of consumer broadband services. Notably, VSI monitors network

    performance on a 24/7 basis and has implemented procedures to leverage its extensive engineering

    resources quickly and effectively.

    B. Viasat’s Network Architecture

    VSI will use GSO network architectures and technologies to provide CAF II-supported

    services. The same supported services will be provided in all supported areas. As such, the network

    description provided herein to each state in which supported service will be provided.

    VSI currently provides GSO services using the ViaSat-1 and ViaSat-2 networks. VSI has also

    been authorized to provide service to the United States using two additional GSO networks at the

    79º W.L. and 88.9º W.L. orbital locations. The ability to operate satellites at either or both of those

    locations, along with associated ground equipment, will allow Viasat to scale available capacity over

  • 7

    time in order to accommodate the demand for CAF II- supported services.

    Each of Viasat’s satellite networks is comprised of three principal segments: (i) a space

    segment consisting of communications links between Viasat’s satellites and associated ground

    facilities (which in turn connect to Viasat’s terrestrial network); (ii) a terrestrial network consisting of

    terrestrial data, management and control functions, and interconnection to the Internet; and (iii) a

    user segment, consisting of links between Viasat’s satellites and the end user equipment.

    1. Space Segment

    The space segment consists of the communication links between VSI’s GSO satellites located

    in space and gateway earth stations or SANs located on the ground. As noted above, VSI currently

    provides consumer broadband service over two GSO satellites—ViaSat-1 and ViaSat-2. Together,

    these satellites will allow Viasat to provide service to all supported areas. These satellites utilize Ka-

    band spectrum, and will provide capacity to facilitate the provision of supported services.

    ViaSat-1 is a “bent-pipe” Ka-band satellite, which uses relatively small “spot beams”

    that allow the efficient reuse of available spectrum resources. ViaSat-1 provides at

    least 140 Gbit/s of total capacity. ViaSat-1 currently communicates with 17 gateway

    earth stations. In addition to an antenna and associated radiofrequency (“RF”) and

    baseband equipment, each gateway contains a fiber link back to a core node, where

    data is further processed before connecting to the internet (as part of the terrestrial

    network segment, described below).

    ViaSat-2 is a newer satellite design than ViaSat-1. ViaSat-2 has a maximum potential

    capacity of approximately 260 Gbit/s. ViaSat-2 has a unique design which allows

  • 8

    ViaSat to allocate capacity among spot beams based on demand. ViaSat-2 currently

    communicates with 46 SANs. SANs are similar to gateway earth stations, except that

    in the case of SANs certain equipment (and related functions) are essentially relocated

    to the core node to increase operational efficiency.

    As noted above, VSI has been authorized to provide service to the United States using two

    additional GSO networks at the 79º W.L. and 88.9º W.L. orbital locations. Satellites operating at

    these locations will allow Viasat to scale available capacity over time to accommodate additional

    subscribers.

    2. Terrestrial Network

    The terrestrial network segment performs the transport, data processing, control, and

    management functions for VSI’s GSO networks. The terrestrial network segment is physically

    implemented using core nodes, fiber optic transport links, and public cloud computing centers.

    The transport network physically connects each gateway and SAN with its

    associated core node, and also connects the core nodes together to provide

    redundant data paths. The transport network is based on leased fiber wavelengths

    terminated into commercial off-the-shelf (“COTS”) switching and routing equipment.

    Viasat maintains several core nodes across the country, which: (i) serve as

    aggregation points for data traffic routed through gateways and SANs; and (ii)

    interconnect with the Internet, the PSTN, and other terrestrial networks through

    leased fiber. The core nodes essentially operate as private data centers and use a

    combination of proprietary and COTS applications.

    Control and management functions (e.g., provisioning, accounting, billing, network

    monitoring, and configuration management) are hosted in the public cloud. These functions utilize

    a combination of proprietary software and customized COTS software products. Hosting these

    functions in the public cloud allows them to be highly available and easily expandable.

  • 9

    CONFIDENTIAL Figure 1 shows the topology of the VSI’s terrestrial fiber backbone network.

    CONFIDENTIAL

    1Figure 1: Viasat Fiber Back Bone Network

    CONFIDENTIAL

    3. User Segment

    The user segment refers to the portion of the network that connects each individual user to

    one or more of VSI’s GSO satellites and, therefore, the larger satellite network. It is the rough analog

    of the “last mile” in terrestrial wireline networks. Relevant equipment (other than the satellite itself)

    includes the following:

    The user terminal is the ground-based equipment employed by an individual user to

    access the Viasat satellite network. The user terminal consists of an indoor unit (IDU),

    outdoor unit (ODU), inter-facility link (IFL), and power supply (which are depicted in

    the figure below).

  • 10

    Figure: Viasat User Terminals

    The indoor unit (or IDU) performs client-side functions related to Internet access

    (e.g., those related to use of transmission control protocol (TCP) and hypertext

    transfer protocol (HTTP)), as well as certain signal conversion, modulation, and

    amplification functions. The IDU also incorporates a WiFi router that can be accessed

    by end users (and their communications devices) in the same manner as other WiFi

    routers. The IDU interfaces with the ODU through the inter-facility link (described

    below).

    The outdoor unit (or ODU) performs certain signal conversion, modulation, and

    amplification functions, and transmits signals to and receives signals from the

    satellite. The ODU is typically mounted on a roof or a pole and interfaces with the

    IDU through the inter-facility link (described below).

    The inter-facility link (or IFL) is a 75 Ohm coaxial cable that carries the

    communications signal and electrical power between the IDU and ODU.

    V. VIASAT MEETS THE STATE AND FEDERAL STATUTORY AND REGULATORY REQUIREMENTS FOR ETC DESIGNATION

    Viasat meets all applicable federal and state requirements for designation as an ETC in

    Oregon, including, 47 U.S.C. § 214(e) and 47 C.F.R. § 54.201, et seq., and the Oregon ETC Order.

    A. Viasat Meets All Federal Requirements For ETC Designation

    Viasat meets all criteria for designation as an ETC under federal law. Specifically:

  • 11

    1) For purposes of this designation, Viasat will provide service on a common carrier

    basis. Viasat currently provides broadband Internet access service and VoIP service. As to customers

    and locations where Viasat is awarded CAF II Auction support, Viasat will provide its voice service on

    a common carrier basis. As such, Viasat is a common carrier. (47 U.S.C. § 214(e)(1); 47 C.F.R. §

    54.201(d));

    2) VSI is a facilities-based satellite provider with its own fleet of satellites, earth stations,

    gateways, switching facilities, and other associated facilities and, therefore, Viasat will offer the

    supported services using its own facilities or a combination of its own facilities and resale of another

    carrier's services (47 U.S.C. § 214(e)(1)(A); 47 C.F.R. § 54.201(d)(1)).

    3) As required by 47 C.F.R. § 54.101, Viasat will offer the voice telephony and broadband

    services supported by federal universal service support mechanisms, including the following

    capabilities:

    Voice Grade Access To The Public Switched Telephone Network – Viasat meets this

    requirement through its provision of an interconnected VoIP service that includes minutes of

    use for local service provided at no charge to end users (i.e., plans are generally unlimited

    usage within the U.S.) and access to emergency services via 911 or E-911, wherever available

    from local government or public safety organizations. Viasat will also provide toll limitation

    services to qualifying low-income consumers as provided in the Commission’s Rules (47 C.F.R.

    § 54.101(a)(1)).

    Broadband Internet Access Services – Viasat’s broadband Internet access service provides

    the capability to transmit data to and receive data by wire or radio from all or substantially

    all Internet endpoints, including any capabilities that are incidental to and enable the

    operation of the communications service (47 C.F.R. § 54.101(a)(2)).

    Viasat commits to provide these services consistent with applicable high-cost universal service

    support rules (47 C.F.R. § 54.101(c)). Viasat will also offer Lifeline service as required by the FCC’s

    rules at all locations where it has been awarded support (47 C.F.R. § 54.101(d));

  • 12

    4) Viasat will offer voice telephony as a standalone service and at rates that are

    reasonably comparable to urban rates;14

    5) Viasat will advertise the availability of its universal service offerings and charges for

    such offerings using media of general distribution (47 U.S.C. § 214(e)(1)(B); 47 C.F.R. §

    54.201(d)(2)), namely through a combination of digital and traditional media, such as the Internet,

    outbound Email, advertising via radio, newspapers, magazines or other print advertisements, outdoor

    advertising, or direct marketing, and will also publicize the availability of Lifeline service in a manner

    reasonably designed to reach those likely to qualify for the service (47 C.F.R. § 54.405(b));

    6) Viasat will provide the supported services throughout the designated service area (47

    U.S.C. § 214(e)(1); 47 C.F.R. § 54.201(d));

    7) Viasat certifies that, in accordance with 47 U.S.C. § 254(e), it will use federal universal

    service support only for the provision, maintenance, and upgrading of facilities and services for which

    the support is intended.

    8) Viasat further certifies that it meets all of the applicable requirements for designation

    as an ETC15 under 47 C.F.R. § 54.202 as follows:

    Compliance With Applicable Service Requirements. Viasat certifies that it will comply with the

    service requirements applicable to the support that it receives,16 including the requirements

    of the CAF II Auction.

    Ability to Remain Functional in Emergency Situations. VSI has been providing high speed

    internet service to customers on 24 hours x 365 days a year mode for more than thirteen

    years. As part of providing this commercial service, it is necessary to have in place

    14 USF/ICC Transformation Order, 26 FCC Rcd at 17693, paras. 80-81; see also 47 C.F.R. § 54.101(b). 15 The FCC waived the requirement for a winning bidder to file a five-year plan (47 C.F.R. § 54.202(a)(1)(ii)) as part of the ETC designation process and to demonstrate that it will satisfy applicable consumer protection

    and service quality standings (47 C.F.R. § 54.202(a)(3)). WCB Reminds Connect America Fund Phase II Applicants of the Process for Obtaining Federal Designation as an Eligible Telecommunications Carrier, WC Docket Nos. 09-197, 10-90, Public Notice, DA 18-714, at 4-5 (rel. July 10, 2018) (“FCC ETC Procedures Notice”). 16 47 C.F.R. § 54.202(a)(1)(i).

  • 13

    contingency plans for credible emergency situations for each of the major network facilities

    that are geographically distributed across the United States. These plans contain activation,

    required staffing, escalation, and communication procedures to deal with such

    emergencies. Additionally, all the ground-based facilities are equipped with independent

    power generators and sufficient fuel to operate for several days so as to mitigate power

    outages. The design of these facilities contains multiple levels of redundancy and autonomy

    that also mitigate the need for dedicated human interaction. Viasat plans to apply this

    successful model for its CAF II Action services and customers.

    B. Viasat Meets All State Requirements For ETC Designation

    The Oregon ETC Order established guidelines for entities seeking ETC status in Oregon,

    including a “checklist” of Initial Designation Requirements in Appendix A. As explained below, Viasat

    meets all the Initial Designation Requirements as follows:

    1. Information regarding applicant and its common carrier status

    1.1. Name of entity requesting designation and corporate affiliation.

    The entity requesting ETC designation is Viasat Carrier Services, Inc. Viasat is a Delaware

    corporation and a wholly-owned subsidiary of ViaSat, Inc.

    1.2. Demonstration of the applicant’s common carrier status.

    Viasat is a newly-formed entity established for purposes of providing CAF II Auction supported

    services to consumers in eligible Census Blocks in 20 states, including Oregon. For purposes of this

    designation, Viasat will provide service on a common carrier basis. Viasat currently provides broadband

    Internet access service and VoIP service. As to customers and locations where Viasat is awarded CAF

    II Auction support, Viasat will provide its voice service on a common carrier basis. As such, Viasat is a

    common carrier.

    1.3. Description of the general types of services and geographic area for which the applicant is authorized in the state of Oregon.

    See Section IV.A. Viasat seeks designation as an ETC to provide voice telephony (VoIP) and

  • 14

    broadband services in the locations identified in Exhibit A.

    1.4. Demonstration that applicant is financially and technically capable of providing the supported services in compliance with FCC and Commission rules. Relevant considerations include whether applicant previously offered services to non-Lifeline customers, how long the applicant has been in business, whether the applicant intends to rely exclusively on universal service fund (USF) disbursements to operate, whether the applicant receives or will receive revenue from non-USF sources, and whether the applicant has been subject to enforcement action or ETC revocation proceedings in any other jurisdiction.

    See Sections I, II, and IV. Viasat’s parent, VSI, provides broadband and VoIP services to

    customers in all fifty states and the District of Columbia. VSI has previously deployed several consumer

    broadband networks, starting with the WildBlue-1 network, which was deployed in 2005 and has operated

    continuously since that time. In 2011, VSI deployed the ViaSat-1 satellite network, which VSI has used to

    provide high-speed, high-quality broadband services to consumers and other end users. In 2017, VSI

    deployed the ViaSat-2 satellite network, which commenced service in April 2018. In addition, VSI has a

    new satellite under construction and ready for launch in the 2020 timeframe, ViaSat-3, which will allow

    Viasat to offer even higher speeds of broadband service and more capacity than ViaSat-2.

    The FCC required VSI to demonstrate that it has sufficient financial qualifications in order for VSI

    to qualify as a bidder in the CAF II Auction.17 VSI is a publicly-traded company with more than $1.5 billion

    in revenue for the year ending March 31, 2018. VSI’s most recent SEC Form 10-K is available here

    http://investors.viasat.com/static-files/e75b82fb-e7df-4273-8212-984c1fd332fb.

    VSI will provide necessary funding to Viasat in addition to any CAF II Auction funding to facilitate

    Viasat’s achievement of its service obligation milestones and ongoing operations. Accordingly, Viasat will

    not rely exclusively on USF disbursement for its operations in Oregon or elsewhere and will have sufficient

    financial capabilities to provide voice and broadband Internet access services throughout the territories in

    which it seeks designation.

    Neither VSI nor Viasat have been the subject of enforcement action or ETC revocation.

    2. Type of federal universal service support for which designation is requested

    17 Auction 903 Procedures Public Notice, 33 FCC Rcd 1428, para. 46.

    http://investors.viasat.com/static-files/e75b82fb-e7df-4273-8212-984c1fd332fb

  • 15

    2.1. For applicants awarded federal USF support conditional upon grant of ETC status: copies of relevant FCC documentation.

    A copy of the Auction 903 Results Notice, including Attachment A identifying VSI as a winning

    bidder for Census Block Groups in Oregon, is available here https://www.fcc.gov/document/connect-

    america-auction-expand-broadband-713176-rural-locations. In accordance with the FCC’s

    procedures,18 VSI assigned its winning bid to Viasat.

    3. Commitment and ability to provide all supported services

    3.1. Statement of commitment to offer supported Voice Telephony services and description of each element required in 47 CFR §54.101(a) (voice grade access to the public switched network or its functional equivalent, local usage, access to emergency services, and toll limitation services to qualifying low-income consumers if the applicant's proposed Lifeline service distinguishes between toll and non-toll calls in the pricing of the service). See Sections V.A.3. 3.2. Identification of any required supported Voice Telephony services that are not currently offered, and an explanation of when and how such services will be made available.

    As described in Section V.A.3, Viasat will offer all required supported Voice Telephony services.

    3.3. Identification and description of each of applicant's voice telephony local service offerings (the name the plan is marketed under, the number of minutes and included calling area, and the price) within the proposed designated service area.

    Viasat is currently developing the pricing and structure of its voice telephony plans based on

    its winning bids. As stated in Section V.A.3., Viasat’s voice telephony plan(s) will be based on its

    interconnected VoIP service that, in general, includes unlimited local and interstate calling within the

    US. The rates for this service will be reasonably comparable to urban rates for similar services.

    3.4 Description of broadband services to be offered, if such services must be provided as a condition for receiving USF support. See Section IV.A and V. 4. Identification and definition of proposed designated service area 4.1. Explicit identification of the proposed designated service area through:

    18 See Auction 903 Procedures Public Notice, para. 37.

    https://www.fcc.gov/document/connect-america-auction-expand-broadband-713176-rural-locationshttps://www.fcc.gov/document/connect-america-auction-expand-broadband-713176-rural-locations

  • 16

    4.1.1. Map showing boundaries of applicant's federally-licensed or state-certificated area within Oregon, or an explanation why such boundaries do not exist, and the boundaries of the requested designated service area. The map must also show the boundaries of the area for each geographic unit, e.g., wire center, census block, zip code, that will comprise the designated service area;

    As a facilities-based satellite service provider, Viasat’s service area includes all of Oregon. The

    Census Block in which Viasat seeks designation are identified in Exhibit A. Maps of Viasat’s requested

    designated service area in Oregon are attached hereto as Exhibit C and CONFIDENTIAL Exhibit D.

    4.1.2. Rationale for selection of the type of geographic unit to define the proposed designated service area;

    The CAF II Auction identified specific Census Block Groups for which qualified bidders could bid

    to obtain funding and provide service.19 The FCC awarded VSI funding as the winning bidder in 261

    Census Block Groups in Oregon. These Census Blocks are identified in Exhibit A. Accordingly, Viasat

    seeks ETC designation in the eligible census blocks within these Census Block Groups.

    4.1.3. Listing of each and every specific geographic unit, e.g., ILEC wire center (by ILEC name, wire center name and code), census block (by ID number), or zip code (by number), etc., that will be included in the designated service area, with identification of any units for which service will not be provided throughout;

    See Exhibit A.

    4.1.4. Identification of specific Tribal Lands (as defined in 47 C.F.R. § 54.5 or 47 C.F.R. § 54.400(e) as appropriate) included in proposed designated service area, if any.

    See Exhibit B.

    4.2. Commitment and ability to offer supported services throughout the proposed service area and to provide service to all requesting customers. See Section V.A.6. 4.2.1. Statement indicating whether all requesting customers in the proposed service area will be provided services for which USF support is to be received, e.g., voice and/or broadband, upon initial designation.

    Viasat will provide the supported services throughout the CAF II Auction awarded service areas.

    Viasat plans to offer multiple tiers of voice and broadband service in the eligible census blocks, including

    19 See Auction 903 Procedures Public Notice, 33 FCC Rcd 1428, paras. 18-19.

  • 17

    tiers that are eligible for USF support. Thus, Viasat will, consistent with the CAF II requirements, offer

    supported service tiers to customers in the eligible census blocks. However, not every customer may

    desire or require a supported service and may, instead, wish to purchase a different service tier.

    4.2.2. If applicant is unable to serve all customers in the proposed service area upon initial designation: 4.2.2.1. For each geographic unit in the proposed designated service area with less than full coverage, a description of the extent of coverage and percent of the population that applicant has the present ability to serve, and a public interest rationale for partial coverage.

    The FCC requires full coverage by the year 6 milestone, with a possible exception of 5% of

    locations uncovered by state. Viasat does not anticipate any inability to cover the census blocks to

    which Viasat committed to cover in the CAF II Auction process. Over the course of the 10 year

    commitment period Viasat will add capacity through new satellites to keep up with capacity

    requirements.

    4.2.2.2. Description of process that applicant will use to determine whether service can be provided to an individual when he/she inquires or makes a request for service. When a customer makes an inquiry or request for service, Viasat will request that the customer provides Viasat with his or her exact physical address. Viasat will create a tool that will allow Viasat to determine what services are available for customers in that particular service area. The Viasat sales agent can then use this information to advise the customer of what services are available in her or her service area. 4.2.2.3. For Lifeline-only ETCs: Commitment to report to the Commission Staff the number of requests for service from potential eligible customers within the designated service area that could not be fulfilled due to lack of adequate service availability. The report must include each such customer's address and must be submitted on a semi-annual basis for the first two calendar years following ETC designation. Network facility owners must also report how they attempted to provide service to each potential customer.

    Because Viasat is not seeking Lifeline-only ETC designation, this request is not applicable.

    4.2.3. For wireless carriers only, commitment to make available coverage maps in accordance with CTIA-The Wireless Association's Consumer Code for Wireless Service at the point of sale and on the applicant's website upon designation.

    Because Viasat is not a wireless carrier, this request is not applicable. 5. Types of facilities used to offer supported services

  • 18

    5.1. Description of types of network facilities currently used to provide service.

    See Section IV.B. 5.2. If applicant resells network facilities of other carriers in the provision of supported services: 5.2.1. A general description of such facilities and the company that owns the facilities.

    Viasat will utilize the facilities of its parent company, VSI. See Sections I, IV, and V.A.2. 5.2.2. Commitment to file notice to Commission in designation docket at least thirty days before adding or eliminating an underlying carrier.

    Viasat agrees to provide notice to the Commission in the designation docket at least thirty days

    prior to adding or eliminating an underlying carrier.

    5.2.3. Statement of whether the applicant qualifies for FCC forbearance as a reseller for Lifeline-only designation. If so, a copy of the FCC-approved compliance plan and the FCC order approving the compliance plan should be included in the application.

    Viasat is not seeking Lifeline-only designation. In addition, VSI is a facilities-based satellite

    provider with its own fleet of satellites, earth stations, gateways, switching facilities, and other

    associated facilities and, therefore, Viasat will offer the supported services using its own facilities or a

    combination of its own facilities and resale of another carrier's services. As a result, Viasat does not

    require FCC forbearance as a reseller.

    5.3. Map showing extent of current coverage and, explanation of the basis for depiction of coverage.

    See Exhibit C and CONFIDENTIAL Exhibit D. 5.4. Identification of service providers with which applicant has current and relevant resale or interconnection agreements.

    Viasat does not require or utilize resale or interconnection agreements with any other provider. 6. Commitment to use support funds in accordance with FCC and Commission rules

    Viasat certifies that, in accordance with 47 U.S.C. § 254(e), it will use federal universal service

    support only for the provision, maintenance, and upgrading of facilities and services for which the

    support is intended. Viasat commits to provide supported services consistent with applicable high-cost

    universal service support rules.

  • 19

    6.1. Affidavit, signed by responsible corporate officer, certifying that universal service support funds received will be used only for the intended purposes. See attached Affidavit/Certification.

    6.2. Certification that applicant will comply with the service requirements applicable to the support it receives, along with identification of such requirements by reference to specific FCC rules and relevant Orders.

    Viasat commits to comply with applicable high-cost and CAF II universal service support rules

    as provided in the FCC rules (47 C.F.R. §§ 54.301-54.321) and CAF II Auction orders (Connect America

    Fund Phase II Auction Scheduled for July 24, 2018; Notice and Filing Requirements and Other

    Procedures for Auction 903, Public Notice, FCC 18-6, 33 FCC Rcd 1428 (2018); Connect America Fund,

    et al., Order on Reconsideration, 33 FCC Rcd 1380 (2018); Connect America Fund et al., Report and

    Order and Further Notice of Proposed Rulemaking, 31 FCC Rcd 5949 (2016); Connect America Fund,

    et al., Report and Order and Order on Reconsideration, 32 FCC Rcd 1624 (2017); Connect America

    Fund et al., Report and Order and Further Notice of Proposed Rulemaking, 26 FCC Rcd 17663 (2011).

    6.3. A five-year plan that describes with specificity proposed improvements or upgrades to applicant's network throughout its proposed service area, including estimates of the area and population that will be served as a result of the improvements. An applicant seeking designation only for the purposes of offering Lifeline services to low-income consumers is not required to submit such a five-year plan.

    The FCC waived the requirement for a winning bidder to file a five-year plan as part of the ETC

    designation process. See WCB Reminds Connect America Fund Phase II Applicants of the Process for

    Obtaining Federal Designation as an Eligible Telecommunications Carrier, WC Docket Nos. 09-197, 10-

    90, Public Notice, DA 18-714, at 4-5 (rel. July 10, 2018) (“FCC ETC Procedures Notice”).

    7. Commitment to advertise high-cost non-Lifeline supported services throughout the service area 7.1. Statement of commitment to advertise supported services throughout the service area.

    Viasat will advertise the availability of its universal service offerings and charges for such

    offerings using media of general distribution, namely through a combination of digital and traditional

    media, such as the Internet, outbound mail, advertising via radio, newspapers, magazines or other

  • 20

    print advertisements, outdoor advertising, or direct marketing, and will also publicize the availability of

    Lifeline service in a manner reasonably designed to reach those likely to qualify for the service.

    7.2. Brief description of advertising plans for supported services (excluding low-income service offerings).

    See above response to Question 7.1.

    8. Commitment to offer and advertise Lifeline and OTAP services 8.1. Commitment to offer and advertise Lifeline and OTAP services throughout the designated service area.

    Viasat will offer Lifeline service as required by the FCC’s rules at all locations where it has been

    awarded support. As stated in response to Question 7.1, Viasat will also publicize the availability of

    Lifeline service in a manner reasonably designed to reach those likely to qualify for the service.

    8.2. Identification and description of specific service offerings that applicant will provide to qualifying Lifeline and OTAP customers (both on Tribal Lands and on non-Tribal Lands), including associated terms and conditions, applicable rates and charges, and the number of minutes provided in each plan.

    Viasat has not yet developed the terms and conditions for its VoIP and broadband Internet

    access service offers. Viasat will offer its services under the terms and conditions of the CAF II Auction.

    As stated in Section V.A.3., Viasat’s voice telephony plan(s) will be based on its interconnected VoIP

    service that, in general, includes unlimited local and interstate calling within the US. The rates for this

    service will be reasonably comparable to urban rates for similar services.

    8.2.1. For Lifeline services provided at no charge to the customer, applicant’s commitment to submit any proposed reductions in minutes, units or other material terms of Lifeline service offerings to the Commission at least 90 days prior to the proposed effective date. Proposed increases in minutes, units or other material terms of Lifeline service offerings must be submitted at least ten days before changes become effective. Once changes become effective, the revised service offerings must be filed in the designation docket within ten days.

    For Lifeline services provided at no charge to the customers, Viasat commits to submit any

    proposed reductions to the Commission at least 90 days prior to the proposed effective date.

    8.2.2. For Lifeline services provided at no charge to the customer, applicant's commitment to notify existing customers within ten days following an increase in the minutes, units, or other material terms of Lifeline service offerings and to permit existing customers to immediately subscribe to the increased service offering if the customer

  • 21

    does not automatically receive the benefit.

    For Lifeline services provided at no charge to the customer, Viasat commits to notify existing

    customers within ten days following an increase in the minutes, units, or other material terms of Lifeline

    service offerings and to permit existing customers to immediately subscribe to the increased service

    offering if the customer does not automatically receive the benefit

    8.3. Description of advertising plans designed to reach the target low-income population that applicant will implement after designation.

    See response to Question 7.1. 8.4. Request for designation as an Eligible Telecommunications Provider (ETP) to participate in the OTAP, and commitment to follow all OTAP and RSPF requirements.

    The funding Viasat may receive as a winning bidder will come solely from the Federal Universal

    Service Fund. Viasat does not have current plans to participate in the OTAP. However, at such time as

    Viasat does participate in OTAP, Viasat commits to follow all OTAP and RSPF requirements.

    8.5. Documentation showing the applicant's policies and procedures related to the training of third-party representatives and employees on Lifeline and/or OTAP requirements, as well as documentation showing internal quality control measures for actual applications received by the applicant.

    Viasat has no current plans to utilize third-party representatives in connection with the CAF II

    Auction services, including Lifeline services. Viasat will implement processes and procedures to ensure

    compliance with applicable Lifeline requirements.

    8.6. Applicants will file all necessary information with the FCC to fulfill any and all requirements of the Commission under 47 C.F.R. § 54.401(d) after ETC designation is granted by the Commission.

    Viasat will comply with the requirements of 47 C.F.R. § 54.401(d) after ETC designation is

    granted by the Commission.

    9. Ability to remain functional in emergencies 9.1. Demonstration of ability to remain functional in emergencies specifically addressing: 9.1.1. Amount of backup power available.

    VSI has been providing high-speed internet service to customers on 24 hours x 365 days a year

  • 22

    mode for more than thirteen years. As part of providing this commercial service, it is necessary to

    have in place contingency plans for credible emergency situations for each of the major network

    facilities that are geographically distributed across the United States. These plans contain activation,

    required staffing, escalation, and communication procedures to deal with such

    emergencies. Additionally, all the ground-based facilities are equipped with independent power

    generators and sufficient fuel to operate for several days so as to mitigate power outages. The design

    of these facilities contains multiple levels of redundancy and autonomy that also mitigate the need for

    dedicated human interaction. Viasat plans to apply this successful model for its CAF II Action services

    and customers.

    9.1.2. Ability to reroute traffic around damaged facilities.

    See response to Question 9.1.1. 9.1.3. Ability to manage traffic spikes during emergency periods.

    See response to Question 9.1.1 9.2. Description of current status of E911 deployment and compliance; if full deployment has not been attained, describe plans to achieve full deployment

    Viasat will rely on VSI’s existing 911 capabilities. VSI provides 911 services to all of its United

    States based voice customers. This is accomplished by routing 911 calls to a PSAP (public-safety

    answering point) based upon a customer’s ANI (automated number identification) and transported

    through a wireline 911 network. The PSAP, designated state default answering point, or emergency

    authority is able to identify the voice caller’s primary registered location through an ALI (automated

    location information) database.

    VSI obtains physical location from each customer as part of the voice ordering process. During

    order entry, customer care agents ask the customer to provide their 911 address, making the distinction

    between service address, specifically asking customers in the event of an emergency which address is

    associated with their voice number for emergency services to respond to. Customers are also provided

    contact information at the time of installation to understand how they can update address information.

    As part of order entry, an automated real time verification of the address is performed by a third party

  • 23

    against the MSAG (master street address guide). Within 2 business days a final detailed verification is

    performed by another third party agency, Intrado, to ensure service addresses are valid for emergency

    services to respond to. At any point where a discrepancy is found, customers are contacted to update

    street address information for 911 services.

    9.3. Commitment to comply with Oregon's 9-1-1 emergency reporting system tax requirements, currently ORS 403.200 to ORS 403.230.

    Viasat commits to comply with Oregon’s 9-1-1 emergency reporting system tax requirements

    as set forth in ORS 403.200 to ORS 403.230.

    10. Commitment to meet service quality and consumer protection standards

    The FCC waived the requirement for a winning bidder to demonstrate that it will satisfy

    applicable consumer protection and service quality standings. See FCC ETC Procedures Notice, DA 18-

    714, at 4-5; see also Connect America Fund, et al., ETCs Annual Reports and Certifications, WC Docket

    Nos. 10-90, 14-58, Report and Order, 32 FCC Rcd 5944, 5944-5948, paras. 3-14 (2017). Specifically,

    the FCC found that because ETCs “have an independent obligation to comply with all applicable service

    quality standards and consumer protection rules,” certification of compliance is not necessary.

    Nonetheless, Viasat commits to comply with applicable high-cost and CAF II Auction rules.

    10.1. Commitment to specific, objective measures for service quality and consumer protection, e.g., the CTIA Consumer Code for wireless carriers or the applicable Commission rules for wireline carriers.

    See response to Question 10. 10.2. Commitment to resolve complaints received by PUC, and designation of specific contact person to work with PUC s Consumer Services Division for complaint resolution.

    Viasat commits to resolve complaints received by the PUC. Viasat’s designated contact for

    resolution of complaints is:

    Jason Sophinos Associate General Counsel ViaSat, Inc. 349 Inverness Drive South Englewood, CO 80112

  • 24

    Tel: 720-493-6365 Email: [email protected]

    11. Designation on Tribal Lands Applicants requesting designation on Tribal Lands must notify and engage appropriate Tribal authorities in the proposed designated service area. Evidence of such notification and engagement must be provided in the application or in a supplemental filing, and include the information required in 11.1, 11.2 and 11.3 below. If the applicant does not submit such information for the relevant Tribal Lands prior to initial designation as an ETC, the applicant may submit a subsequent filing to request expansion of the designated service area to include Tribal Lands or additional Tribal Lands. 11.1. Copy of notice to appropriate Tribal government or regulatory entity of filing of ETC application, and identification of specific method and date of delivery. This should include the name of person to whom notice was sent.

    Viasat has not yet initiated discussions with Tribal authorities in Oregon. Viasat will provide a

    copy of this Application to affected Tribal authorities and will comply with the FCC, Commission and,

    as applicable, Tribal requirements for seeking ETC designation in census blocks that overlap Tribal

    lands. Viasat will supplement this Application with the information requested in Questions 11.1 through

    11.3 as it moves forward with efforts to engage applicable Tribal authorities.

    11.2. Summary of Tribal engagement efforts, e.g., dates and topics of meetings, participants, information shared, etc. and an explanation as to how the applicant addressed the following areas (as applicable): 1. Needs assessment and deployment planning with a focus on Tribal community anchor institutions; 2. Feasibility and sustainability planning; 3. Marketing services in a culturally sensitive manner; 4. Rights of way processes, land use permitting, facilities siting, environmental and cultural preservation review processes; and 5. Compliance with Tribal business and licensing requirements. Tribal business and licensing requirements are as described in 47 CFR 54.313(a)(9)(v).

    See response to Question 11.1

    11.3. Results of Tribal engagement efforts with evidence that the appropriate Tribal government or regulatory entity either supports or does not oppose applicant’s designation as an ETC on the relevant Tribal Lands.

    See response to Question 11.1.

    12. Public interest showing 12.1. Demonstration that designation would be in the public interest; this must address;

    mailto:[email protected]

  • 25

    12.1.1. Specific ways in which consumer choices will be increased. 12.1.2. Specific advantages and disadvantages of applicant's service offerings. 12.1.3. Any other specific criteria determined by the Commission.

    See Section VI.

    13. Commitment to provide reports as required 13.1. Annual ETC reports as required by the Commission.

    Viasat commits to provide annual reports required by the Commission. 13.2. Special weekly, monthly, or quarterly reports that Commission Staff finds necessary based on program requirements and the circumstances of each applicant and which the applicant, in good faith, commits to provide to the Commission.

    Viasat commits to file weekly, monthly, or quarterly reports deemed by Commission Staff to be

    necessary based on program requirements or the circumstances of Viasat’s Application.

    VI. DESIGNATION OF VIASAT AS AN ETC IS IN THE PUBLIC INTEREST

    In the FCC’s recent Order on Reconsideration concerning the Connect America Fund program,

    the FCC described holding the Auction as a step to “the goal of closing the digital divide for all

    Americans, including those in rural areas of our country.”20 As a winning bidder in the CAF II Auction,

    Viasat is eligible to receive approximately $10 million over the next ten years to bring high-quality,

    innovative voice and broadband services to consumers in underserved portions of Oregon. By selecting

    Viasat as a recipient of CAF II Auction funds, the FCC has recognized that the voice and broadband

    services Viasat proposes to deploy with the funds would advance the goal of the CAF II Auction, and

    thereby advance the goals of universal service.

    Granting Viasat’s Application will serve the public interest through the deployment of broadband

    and voice services to unserved and underserved high-cost areas in Oregon, support investment in

    facilities and equipment, and expand the number of competitive providers serving rural areas in

    Oregon. Designating Viasat as an ETC will permit the company to receive CAF II Auction funds

    designated for Oregon, directly advancing the goals of the FCC’s Connect America Fund and the

    20 Connect America Fund, et al., Order on Reconsideration, 33 FCC Rcd 1380, para. 1 (2018).

  • 26

    Auction. Viasat’s resulting deployments will bring expanded voice and broadband connectivity to rural

    areas in Oregon, helping to close the digital divide for residents of Oregon, and expanding economic

    opportunity for communities that will benefit from increased connectivity. Designating Viasat as an ETC

    will also help promote economic and job growth in Oregon through the employment of Viasat’s network

    of independent installers and dealers. Because granting Viasat’s Application will allow it to use the CAF

    II funds as intended to expand voice and broadband service in Oregon, designating Viasat as an ETC

    is in the public interest.

  • 27

    VII. CONCLUSION

    For the reasons stated herein, Viasat respectfully requests that the Commission designate

    Viasat as an ETC in the eligible census blocks in which it was awarded CAF II funding on an expedited

    basis and order such other relief as may be appropriate.

    Respectfully submitted,

    Viasat Carrier Services, Inc.

    By:

    Robert Blair President Viasat Carrier Services, Inc. 349 Inverness Drive South Englewood, CO 80112

    Michael P. Donahue Linda G. McReynolds Marashlian & Donahue, PLLC 1420 Spring Hill Road, Suite 401 Tysons, VA 22102 Tel: 703-714-1319 Fax: 703-563-6222 E-Mail: [email protected] [email protected]

    Dated: September 25, 2018.

    mailto:[email protected]:[email protected]

  • LIST OF EXHIBITS

    Exhibit A – List of Census Blocks Where Viasat Carrier Services, Inc. Awarded CAF II Auction

    Support

    Exhibit B – List of Census Blocks in Tribal Areas

    Exhibit C - Map of Census Blocks Where Viasat Carrier Services, Inc. Awarded CAF II Auction

    Support Covered by Viasat-1

    CONFIDENTIAL Exhibit D – Map of Census Blocks Where Viasat Carrier Services, Inc. Awarded

    CAF II Auction Support Covered by Viasat-2

  • EXHIBIT A

    List of Census Blocks Where Viasat Carrier Services, Inc. Awarded CAF II Auction Support

  • 410390031024035

    410619701001238

    410619706002210

    410239602001807

    410290030014028

    410699601002213

    410459709003802

    410259602002913

    410430303003139

    410359703001174

    410170001001057

    410333601001158

    410459706002017

    410599400002082

    410619706002924

    410192100004549

    410599514002051

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    410319601002233

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    410639602001007

    410599400002124

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    410333601002144

    410139504002736

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    410333616003057

    410639603004027

    410359702001865

    410139504002526

    410079512003040

    410019503003047

    410319601002044

    410639603002042

    410170005001031

    410259602002227

    410639602002385

    410192100001593

    410639601001953

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    410170001001985

    410379601002163

    410699601001443

    410259602001509

    410619702003074

    410239601001358

    410579607001468

    410579607001257

    410659708003323

    410510002001008

    410159503012028

    410659708003349

    410659708002077

    410710304001076

    410579607003039

    410290029001123

    410619708004104

    410619701001398

    410110011001268

    410379601001852

    410159502001191

    410619701004128

    410419518002143

    410639602002479

    410619703002163

    410599514002751

    410459709001026

    410379601002789

    410019506003822

    410659708003406

    410333616004252

    410419508002026

    410639603004005

    410459709001028

    410019506003547

    410379601001845

    410579602003004

    410139504002711

    410670321101017

    410019503003260

    410470108014056

    410639601001152

    410619702003887

    410139504002806

    410599514002114

    410079512003624

    410670334002056

    410359703001221

    410279502005047

    410639601001159

    410390015001446

    410619705003127

    410599514001138

    410139501001368

    410139504002838

    410619702003940

    410499702006154

    410659708003407

    410290028002061

    410699601001222

    410239601002693

    410050243042103

    410359705001476

    410219601001356

  • 410079512003310

    410192100005334

    410139504002430

    410659708003141

    410499702002099

    410219601001361

    410290025002330

    410239601001178

    410619702003089

    410459706002003

    410379601002183

    410359705002849

    410170005001866

    410599505003165

    410190300001215

    410499702006243

    410639602002711

    410699601002214

    410139504002597

    410639601001534

    410659708001076

    410159503011323

    410110011001291

    410619702003823

    410359701001547

    410619703001151

    410170003002000

    410359702002123

    410333609001001

    410619703001133

    410359702001802

    410379601001647

    410239601001720

    410290029002014

    410259602002662

    410190300001180

    410639601001002

    410699601002263

    410599505003275

    410599400001019

    410619703001064

    410599501003320

    410459709003968

    410259602001876

    410599514002534

    410191000003384

    410259602002652

    410110011001283

    410239601001376

    410259602002608

    410639602001213

    410290029001058

    410619701001243

    410579608002112

    410619703002011

    410599505003383

    410099702001029

    410110011002032

    410619704001027

    410619702003139

    410599504002015

    410670327001037

    410419506013057

    410379601001848

    410319603023050

    410599400001053

    410139502001039

    410379601001705

    410390007082002

    410599514001339

    410170002003070

    410619703002162

    410499702005160

    410110011001261

    410239601001194

    410239601002073

    410639602002456

    410159503011351

    410459709003012

    410639603004032

    410019501001228

    410599501003313

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    410239602001833

    410379602001967

    410670321101054

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    410110010007037

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    410659708003415

    410192100004474

    410019503002272

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    410359704001193

    410319601002225

    410419518002145

    410159501001499

    410639603001086

    410290026002522

    410019505001118

  • 410333601002143

    410239601001621

    410319601002019

    410670334002050

    410110011002284

    410390004022026

    410599501003283

    410259602001186

    410659708001118

    410379601001355

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    410190100001322

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    410619701001499

    410099711001005

    410599505003221

    410699601001243

    410699601002543

    410359701001786

    410019503002585

    410359710002019

    410639603004147

    410430303001040

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    410619703002001

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    410670334002084

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    410019506003498

    410139504002217

    410319400002128

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    410379601001664

    410239601001126

    410619706002538

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    410110011007138

    410359702001157

    410319400001016

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    410099711003076

    410639602001004

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    410099711001100

    410659707001067

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    410619703001003

    410139504002807

    410239602001805

    410190100001169

    410379601002812

    410379601001657

    410110010007162

    410619706002218

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    410170001001048

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    410599400001041

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    410050232022054

    410139504002731

    410219601001202

    410499702002008

    410619702003143

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    410619701004132

    410019506003540

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    410192100004472

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    410379602001268

    410619703002035

    410191700002300

    410359705002767

    410139504002896

    410290028002055

    410110011001275

    410259602002184

    410170005001654

    410050234031074

    410639602002142

    410619703002022

    410190100001055

    410190300003343

    410470106001435

    410599400001014

    410019506003814

    410019503002489

    410333615001010

  • 410239601001336

    410019506003913

    410459709002226

    410510046012019

    410259602002229

    410699601002149

    410019503003420

    410019505001211

    410290026002387

    410639601001199

    410319601002072

    410379601001575

    410670334002025

    410192100001465

    410379601001725

    410333615001034

    410139504002833

    410239601001587

    410639602002773

    410333616004198

    410110011002022

    410379601001635

    410219601001288

    410333616004138

    410192100001650

    410099705004046

    410110010007194

    410379601001223

    410699601002346

    410319601002156

    410359707002046

    410019503002163

    410319603011024

    410259602001807

    410359701003255

    410639603002002

    410050222081009

    410359701001816

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    410019501001170

    410639601001854

    410390005002079

    410239601001222

    410599505003425

    410259602001898

    410639603001052

    410170001001017

    410159503011315

    410159501001372

    410290025002196

    410639602002330

    410499702005308

    410192100005517

    410359701001913

    410619706002153

    410499702001039

    410259602002206

    410019506003948

    410239602001172

    410333614002136

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    410290028002057

    410259601001660

    410659708002216

    410319601001206

    410259602002858

    410639601001010

    410079512003408

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    410639601001498

    410319400002042

    410599514002861

    410599505003402

    410659708003444

    410639602002742

    410079512001067

    410099705002022

    410659708003006

    410599514001282

    410319400001200

    410699601002482

    410019505001389

    410659707001094

    410019505001073

    410319602021007

    410390004021089

    410710304002020

    410499702005287

    410499702005096

    410619702003308

    410579607001529

    410159501001378

    410290029002023

    410239602001020

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    410499702006275

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    410699601002564

    410319603023010

    410139501001222

    410619702003972

    410219601001376

    410019501003122

    410359705002462

  • 410599504002081

    410379601001653

    410239602003139

    410239601001391

    410359701001271

    410239601003380

    410599501003066

    410390007081316

    410290025002458

    410510023032064

    410319601001505

    410639603004035

    410239601001211

    410139504002146

    410619702003526

    410619703001073

    410599400001143

    410239602001446

    410459709003778

    410259602001900

    410599504002082

    410639602002774

    410559501001084

    410599501003236

    410659708003327

    410499702005167

    410190100001059

    410259602001840

    410259602001385

    410699601002441

    410333601001140

    410699601002163

    410110001003136

    410319603023016

    410159501001480

    410319603024022

    410619703002137

    410459706002084

    410110011007023

    410290023001054

    410159503011340

    410239601001579

    410239601002643

    410139504001143

    410499702006127

    410191700002269

    410419506013012

    410619703002015

    410170002003118

    410099711001003

    410259602002543

    410170003002028

    410239601003458

    410619701001483

    410110011007139

    410459709003807

    410530204003566

    410110010007106

    410599514001407

    410619705003049

    410710304001001

    410619701001016

    410359705002404

    410619708004056

    410219601001325

    410379601002854

    410499702002147

    410359702001785

    410710304001247

    410259602001744

    410239601001007

    410430302003054

    410499702001175

    410359710002012

    410379601001991

    410379601001468

    410379601001497

    410599505003319

    410259602002152

    410390001005152

    410319400002035

    410579608003242

    410110011007034

    410333614002021

    410619708004111

    410659707001076

    410619702003381

    410333601001144

    410379601001241

    410499702006250

    410619702003509

    410170001001377

    410619705003014

    410599501003059

    410110011002172

    410019501001153

    410019501001001

    410239601001773

    410359702001801

    410459709003046

    410319601002207

    410599501003012

    410170005001100

    410499702005070

  • 410639602002737

    410239601002930

    410290027004083

    410019503002005

    410191000003284

    410699601001058

    410239601003498

    410379601001781

    410639602002557

    410619703002150

    410239601001553

    410710304001065

    410359701001889

    410259602001267

    410319603021256

    410359702003099

    410459709003958

    410530204004086

    410219601001197

    410192100001242

    410359702002340

    410019501001085

    410359705002892

    410359702001788

    410379602001975

    410639603004145

    410599400001042

    410459709003319

    410019501003117

    410019503003267

    410239602001526

    410239601001227

    410259602002269

    410599501003026

    410319400002152

    410259602001511

    410639601001508

    410019503003210

    410459709002253

    410359702001175

    410099711002015

    410333614002134

    410359705001268

    410290026002692

    410290025002481

    410510077001037

    410599514001377

    410359705002844

    410359702002219

    410619703002171

    410459709003356

    410079511002278

    410159503011362

    410139504001056

    410359702001369

    410239601002689

    410290023001089

    410599514002556

    410110001003153

    410259602002307

    410359706001015

    410139504002306

    410259602001804

    410639602002768

    410259601003013

    410419506013112

    410390007081241

    410639603004003

    410079512003387

    410499701005178

    410619703002007

    410239601001563

    410079512003175

    410290025002173

    410359702001206

    410619706002925

    410219601001368

    410659708002217

    410333609001007

    410139504002290

    410390002004005

    410419508001047

    410219601001375

    410619703002019

    410619708004053

    410191000003370

    410619703001123

    410419518002215

    410619706002902

    410290027004054

    410599503002034

    410159503013023

    410639602001284

    410499702003074

    410559501001017

    410639602002736

    410159503011179

    410619703001136

    410239601003235

    410239602001293

    410499702002140

    410619701004117

    410430303003141

    410599514001122

  • 410259602002205

    410219601001218

    410259602001887

    410259602002981

    410639602001035

    410639602002415

    410379601001755

    410333601001107

    410319400002029

    410639601001829

    410499702002112

    410170002001232

    410319603011008

    410239601001327

    410290029002037

    410333615001012

    410239601001543

    410290025002505

    410139504002825

    410259602002893

    410333601001084

    410139504002288

    410139504002989

    410639602002704

    410290023001020

    410192100004417

    410110011007035

    410333616007074

    410259602001718

    410359702001161

    410290027004231

    410359701001332

    410499701005202

    410559501001066

    410319601002018

    410239601001577

    410239601002911

    410019503003003

    410333601001060

    410110011001181

    410670327001038

    410259601001243

    410190100001159

    410110011002033

    410579607001524

    410390014002228

    410139504002484

    410619706002155

    410159503012009

    410599514002085

    410192100001208

    410599504001158

    410699601001145

    410579604006066

    410359702002037

    410430303003001

    410019506003100

    410290026002590

    410019506003520

    410192100001656

    410333615001102

    410619701001333

    410710304001064

    410359702001831

    410239601001267

    410599400001124

    410170006004007

    410019506003503

    410319601002176

    410619702003099

    410639603001035

    410239602001667

    410190300001048

    410290023001053

    410192100001517

    410619701001392

    410579607001242

    410599514001394

    410239602001704

    410290025002480

    410699601002483

    410599400001199

    410159503011002

    410319601002132

    410019506003099

    410333601001066

    410699601001076

    410139501001257

    410390001004083

    410019506003818

    410619704001053

    410239601001250

    410639602001045

    410379601001092

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    410319601002105

    410159502001205

    410619702003427

    410259602001762

    410390007081231

    410259601001911

    410599514002540

    410699601001225

    410390007021199

  • 410159501001358

    410170002003124

    410359703001507

    410333601002155

    410239602001637

    410219601001040

    410559501002270

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    410239602001490

    410639603001120

    410290026001508

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    410290006011006

    410333601002142

    410599400001148

    410139504002303

    410159503011386

    410619706002110

    410239602001039

    410599514001275

    410359702002046

    410710304002021

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    410259602002782

    410192100001467

    410710304001034

    410019501001970

    410619703001156

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    410619702003920

    410139501001099

    410110011001086

    410110010007033

    410619702003540

    410499702002098

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    410599501003286

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    410190300001209

    410499702006224

    410192100004109

    410639601001338

    410379602001339

    410599505003334

    410599504001135

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    410359702002071

    410319601001491

    410619706002126

    410079504002189

    410639602002743

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    410659708002050

    410599504002068

    410670335001157

    410459707001022

    410619702003395

    410190100001032

    410459706002007

    410019503003013

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    410099711003121

    410459705001074

    410390013011006

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    410639602002770

    410139504002542

    410290029001158

    410333601002004

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    410259602001551

    410239601001079

    410390007081288

    410619703001019

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    410619702003372

    410499702006081

    410019503002286

    410239601001234

    410599514002559

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    410670335001103

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    410319603021843

    410019503002359

    410499702004030

    410259602002920

    410619702003878

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    410379601001820

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    410599514002113

  • 410359701003356

    410699601001342

    410639603001090

    410430303003476

    410192100001580

    410259602002007

    410259602001364

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    410659706001112

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    410159501001000

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    410430303003041

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    410139504002422

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    410259602001925

    410579604001006

    410290028002039

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    410619701004168

    410510041014012

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    410190700002332

    410259602002240

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    410170001001174

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    410599505003314

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    410019506003121

    410379602001876

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    410619701004149

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    410579607001036

    410670334001007

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    410110011007132

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    410139504002390

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    410079506001135

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    410499702005294

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    410079506001095

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    410191000003713

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    410379601002867

    410099705002066

    410359702002014

  • 410499702005026

    410239601001182

    410659708003287

    410333615001008

    410670334002010

    410333609002091

    410110011001438

    410430303003472

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    410390009021094

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    410639603001145

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    410510073001121

    410639602001257

    410191000003610

    410359702004417

    410319603021756

    410659708003342

    410359703001686

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    410619703002159

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    410599505003173

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    410390016004343

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    410619703001235

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    410110011001231

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    410459709002981

    410110005022171

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    410170001001185

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    410639603004040

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    410079506001134

    410139504002375

    410619703002004

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    410670335001140

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    410170006004008

    410110011007383

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    410079512003626

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    410139504002342

    410390003001037

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    410710305021356

    410499702006207

    410670335001070

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    410639602001011

    410599504002016

    410192100001821

    410499702005284

    410639603004008

    410659707001090

    410319601002007

    410430303001002

    410110010007092

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    410499702005259

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    410319603021899

    410019503003263

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    410239601001361

  • 410499702003082

    410170002003067

    410099702003049

    410639602002780

    410390011011060

    410599505003023

    410290025002114

    410319400001197

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    410192100001503

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    410110010007040

    410190100001146

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    410659708003292

    410110001003000

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    410110011007386

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    410239601001445

    410710305011023

    410619706002124

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    410170001001397

    410639602001254

    410639601001931

    410259601001830

    410290028002010

    410659707001147

    410599505003325

    410319400001019

    410259602002827

    410139501001172

    410110001003127

    410390002001047

    410599501003284

    410290029001093

    410333614002046

    410319601002045

    410239602001644

    410110011007048

    410319601001516

    410170002001067

    410379601001084

    410379601001501

    410379601001491

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