viasat” or the “company”), transmitted herewith for company’s … · communications...
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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]
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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
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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)).
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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]
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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.
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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.
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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
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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
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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.
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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).
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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:
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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));
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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).
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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
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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
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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
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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.
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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
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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.
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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
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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
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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
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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
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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
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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]
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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).
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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.
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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.
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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
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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
410659708002227
410319601002233
410110011001082
410639602001007
410599400002124
410019501001959
410333601002144
410139504002736
410639602001229
410333616003057
410639603004027
410359702001865
410139504002526
410079512003040
410019503003047
410319601002044
410639603002042
410170005001031
410259602002227
410639602002385
410192100001593
410639601001953
410192100004056
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
410639601001845
410619703001014
410239602001833
410379602001967
410670321101054
410379601001985
410110010007037
410499702003029
410599514002091
410659708003415
410192100004474
410019503002272
410619703001149
410639602002706
410099705004005
410359704001193
410319601002225
410419518002145
410159501001499
410639603001086
410290026002522
410019505001118
-
410333601002143
410239601001621
410319601002019
410670334002050
410110011002284
410390004022026
410599501003283
410259602001186
410659708001118
410379601001355
410259602002824
410190100001322
410359701001096
410619701001499
410099711001005
410599505003221
410699601001243
410699601002543
410359701001786
410019503002585
410359710002019
410639603004147
410430303001040
410290023001034
410259602001883
410279501003034
410619703002001
410099711002075
410599514002307
410259602001862
410699601002668
410670334002084
410259602002529
410019506003498
410139504002217
410319400002128
410259601001593
410379601001664
410239601001126
410619706002538
410379601002256
410110011007138
410359702001157
410319400001016
410619702003933
410359701001259
410619702003086
410379601001437
410099711003076
410639602001004
410379602001810
410599501003227
410319601002116
410379601002864
410099711001100
410659707001067
410359702002155
410619703001003
410139504002807
410239602001805
410190100001169
410379601002812
410379601001657
410110010007162
410619706002218
410599400001090
410319601001197
410170001001048
410639602001193
410599400001041
410379601001978
410050232022054
410139504002731
410219601001202
410499702002008
410619702003143
410459709003023
410239601001146
410619701004132
410019506003540
410619701004102
410639601001379
410639603004118
410192100004472
410639601001179
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