Grafton Technologies, Inc.
Application for Eligible Telecommunications Carrier for Lifeline Support Only
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Docket No.
IIJ.INOIS COMMERCE COMMISSON CHIEF CLERK'S OFFICE
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GRAFTON TECHNOLOGIES, INC. APPLICATION FOR DESIGNATION AS AN ELIGIBLE TELECOMMUNICATIONS CARRIER FOR LIFELINE SUPPORT ONLY
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20-0824
TABLE OF CONTENTS
I. INTRODUCTION AND OVERVIEW OF GTI II. THE COMMISSION HAS JURISDICTION OVER GTl'S DESIGNATION
REQUEST III. GTI MEETS THE REQUIREMENTS FOR ETC DESIGNATION UNDER
SECTION 214(e) OF THE ACT AND SECTIONS 54.201(c) AND (d) OF THE FCC'S RULES A. GTI Will Provide Service as a Common Carrier B. GT! Will Offer the Services Supported by Federal Universal Service C. GTI Will Provide Service Using Its Own Facilities D. GTI Will Provide Service Throughout Its Designated Service Area E. GT! Will Advertise the Availability of the Supported Services and the Relevant
Charges Using Media of General Distribution IV. GTI MEETS THE ADDITIONAL REQUIREMENTS FOR ETC DESIGNATION
UNDER SECTION 54.202 OF THE FCC'S RULES A. GT! Will Comply with the Service Requirements Applicable to Lifeline Support B. GT! Will Remain Functional in Emergency Situations C. GTI Will Satisfy Applicable Consumer Protection and Service Quality Standards D. GTI is Financially and Technically Capable of Providing Lifeline Services in
Accordance with the FCC's Rules E. GTI Will Provide Supported Lifeline Service Plans to Eligible Consumers
V. DESIGNATION OF GTI AS A LIFELINE-ONLY ETC IS IN THE PUBLIC INTEREST
VI. ANTI-DRUG ABUSE CERTIFICATION VII. CONCLUSION
EXHIBITS
EXHIBIT A - MAP OF DESIGNATED SERVICE AREA IN WHICH GTI SEEKS ELIGILBLE TELECOMMUNICATIONS CARRIER DESIGNATION
EXHIBIT B - AFFIDAVIT
EXHIBIT C - FINANCIAL INFORMATION FOR GRAFTON TECHNOLOGIES, INC.
EXHIBIT D - VERIFICATION
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ST ATE OF ILLINOIS ILLINOIS COMMERCE COMMISSION
Grafton Technologies, Inc. ) )
IWNOISCOMMERCECOMMISSllN CHIEF ClERK'SOFFICE
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Docket No. Application for Eligible Telecommunications Carrier for Lifeline Support Only
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GRAFTON TECHNOLOGIES, INC. APPLICATION FOR DESIGNATION AS AN ELIGIBLE TELECOMMUNICATIONS CARRIER FOR LIFELINE SUPPORT ONLY
Grafton Technologies, Inc. ("GTI") respectfully submits this application to the Illinois
Commerce Commission ("Commission") for designation as an eligible telecommunications
carrier ("ETC") pursuant to Sections 2 I 4( e )( I )-(2) 1 of the Communications Act of I 934, as
amended (the "Act"), and Sections 54.201(c) and (d)2 of the rules and regulations of the Federal
Communications Commission ("FCC").3 GTI seeks ETC designation for Lifeline support only
to offer high-speed Internet access and traditional voice telephony services ("voice service") in
the Designated Service Area, as outlined in Exhibit A. GTI requests ETC designation for the
Designated Service Area so that it may begin serving customers as soon as possible.
All correspondence, communications, pleadings, notices, orders and decisions relating to
this Application should be addressed to:
Susan Hamilton Vice President
I 47 U.S.C. §§ 2J4(e)(l)-(2). 2 47 C.F.R. § 54.201(c)-(d). 3 GTI files this Petition in accordance with the rules adopted by the FCC on October 30, 2019 in WC Docket Nos. 11-42, 17-287 and 09-197, Lifeline and Link Up Refonn and Modernization, et al., FCC 19-111, Fifth Report, Memorandum Opinion and Order and Order on Reconsideration, and Further Notice of Proposed Rulemaking ("Lifeline Reform Order").
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Grafton Technologies, Inc. PO Box428 Jerseyville, IL 62052 (618)639-4841 sham i [email protected]
I. INTRODUCTION AND OVERVIEW OF GTI
Grafton Communications, Inc., through its wholly owned subsidiaries Grafton Telephone
Company, GTI and Grafton Long Distance, has been in the telecommunications service business
for 120 years. GTI is a competitive local exchange carrier ("CLEC") and currently serves I ,600
landline customers, I, 769 broadband customers and 665 video customers with 10 I miles of lines
within its CLEC service area. GTl's CLEC service area currently includes the communities of
Jerseyville and Chautauqua in Jersey County, Illinois, as well as a small portion of Macoupin
County, Illinois. GTl's CLEC service area will soon include the underserved communities of
Fieldon, Dow, Otterville, Nutwood and McClusky, also located in Jersey County, Illinois, upon
GTl's completion of its fiber optic network expansion through the Connect [llinois Broadband
Grant Program.4 GTI was the first Internet Service Provider (ISP) in Jersey County, Illinois and
has been providing residents with Internet since 1996. GTI is dedicated to supporting economic
development throughout the Designated Service Area and serving industries both large and
small. A portion of the Designated Service Area is an economically distressed area, and the
community of Fieldon, IL, specifically, is considered an Opportunity Zone5 according to the
Illinois Department of Commerce and Economic Opportunity ("DCEO"). Consequently, the
4 Public Act IO 1-0029 authorizes the Department of Commerce and Economic Opportunity ("DCEO") to award grants from the Build Illinois Fund to qualified applicants for expansion of broadband infrastructure in Illinois ("Connect Illinois Broadband Grant Program"). 5 Qualifying low-income census tracts were chosen to be eligible for consideration as an "Opportunity Zone" based on a three-phase approach. Phase one included Need-Based Indexing which examined an area's poverty rates, unemployment rates, total number of children in poverty, violent crime rate and population. The second phase included a geographical distribution method and the third phase included a review of suggestions from government and community entities throughout the state. h11ps ~/www21jU inois,gov/dceo/Pgges{011pZn.aspx.
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Designated Service Area requires long-term investment and job creation which may only be
achieved through better broadband.
In the spirit of continuing to support economic development and growth in the region and
communities it serves, GTI applied for and was awarded a grant through the Connect Illinois
Broadband Grant Program. GTI has chosen to construct and operate a new state-of-the-art fiber
optic network to provide high-speed broadband Internet access and voice services to residents in
the portions of the Designated Service Area, who currently lack access to such services. GTI
currently offers and will offer Internet service at the following bi-directional speeds and prices
with no contract required: 5/5 Mbps for $39.95/month, 10/IO Mbps for $50.95/month, 20/20
Mbps for $65.95/month, 30/30 Mbps for $75.95/month, 40/40 Mbps for $85.95/month, 50/50
Mbps for $95.95/month, 75/75 Mbps for $116.95/month, 100/100 Mbps for $130.95/month and
1 Gbps for $299.95/month. GTI already provides and will provide its customers with voice grade
access to the Public Switched Telephone Network ("PSTN") through its voice services for
approximately $25.00/month.
Today, GTI offers high-speed broadband Internet and voice services to non-Lifeline
customers in its CLEC service area in the Designated Service Area and will begin offering high
speed broadband Internet and voice services to all residents throughout the Designated Service
Area in the second quarter of 2021 . The Connect Illinois Broadband Grant Program will allow
GTI to expand its fiber optic network throughout the entire Designated Service Area. Through
the expansion and installation of its fiber optic network, GTI will be a facilities-based provider
that focuses on specific rural and remote areas within the territory where it is a CLEC. As
discussed in more detail below, the Commission has authority to grant GTl's ETC designation
status pursuant to Section 214( e) of the Act and GTI meets all of the statutory and
regulatory requirements for ETC designation. Designating GT( as an ETC to receive
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federal Lifeline support will serve the public interest by allowing GTI to operate a fiber optic
network that will not only provide voice and broadband services but also opportunities for
economic development to the underserved areas in GTl's Designated Service Area, as well
as subsidized voice and broadband services to qualified households in the Designated Service
Area.
II. THE COMMISSION HAS JURISDICTION OVER GTl'S DESIGNATION
REQUEST
The Commission has the authority to designate GTI as an ETC, pursuant to Section
214( e )(2) of the Act, for the Designated Service Area. Pursuant to Section 214( e )(2) of the Act,
a State commission shall, upon its own motion or upon request, designate a common carrier, who
meets the requirements of Section 214(e)(I), as an ETC for purposes of receiving universal
service support in a service area designated by the State commission.6 Sections 54.201(c) and
(d) of the FCC's rules reflect the provisions of Section 214{e) of the Act and provide that, "upon
request and consistent with the public interest, convenience, and necessity, the state commission
may, in the case of an area served by a rural telephone company, and shall, in the case of all
other areas, designate more than one common carrier as an eligible telecommunications carrier
for a service area designated by the state commission, so long as each additional requesting
carrier meets the requirements" of Section 54.20 I ( d) of the FCC' s rules. 7
The Commission has jurisdiction over GTI's designation request and has the authority to
designate GTI as an ETC for purposes of receiving universal service support in the Designated
Service Area. As shown below, GTI meets the requirements outlined in Section 214(e)(J) of the
Act and Section 54.201(d) of the FCC's rules, as well as the additional requirements for ETC
designation under Section 54.202 of the FCC's rules. Therefore, it is appropriate that the
6 47 U.S.C. §§ 214(e)(I )-(2). 7 47 C.F.R. § 54.20 l(c)-(d).
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Commission designate GT) as an ETC, pursuant to subsection (e)(2), for the Designated Service
Area.
III. GTI MEETS THE REQUIREMENTS FOR ETC DESIGNATION UNDER SECTION 214(e) OF THE ACT AND SECTION 54.201(d) OF THE FCC'S RULES
Under Section 2 I 4(e)( I) of the Act and Section 54.20 I (d) of the FCC's rules, a common
carrier may be designated as an ETC if it ( t) offers the services supported by federal universal
service as determined by the FCC, (2) offers such services using its own facilities or a
combination of its own facilities and resale of another carrier's services; and (3) advertises the
availability of such services and the relevant charges using media of general distribution. 8 As set
forth below, GTI meets these requirements.
A. GT/ Will Provide Service as a Common Carrier
GTI will be a common carrier by virtue of its provision of voice telephony services on a
common carrier basis. As such, GTI certifies that it is a common carrier under Sections 214( e )(I)
and (2) of the Act and Sections 54.201 (c) and (d) of the FCC's rules and regulations. 9
B. GT/ Will Offer !he Services Supported by Federal Universal Service
Pursuant to Section 54. 10 I (a) of the FCC's rules, carriers seeking ETC designation must
provide voice telephony services and broadband Internet access services. IO
Specifically, eligible Lifeline telephony services must provide voice grade access to the
public switched telephone network ("PSTN") or its functional equivalent, minutes of use for
local service provided at no additional charge to end users, access to emergency 91 t and
enhanced 911 service in locations where implemented, and toll limitation at no charge (subject
8 47 U.S.C. § 214(e)(l); 47 C.F.R. § 54.201(d). 9 See Exhibit B (Affidavit of Susan Hamilton, Vice President and Director of Operations, Grafton Communications, Inc.) ("Affidavit"). 10 47 C.F.R. § 54. I0l(a).
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to certain requirements and limitations). 11 GTI certifies that its provision of voice services
satisfies the FCC's definition of voice telephony service, and it will therefore provide all services
designated for support by the FCC.
GTI's supported Lifeline service offering will provide voice grade access to the PTSN
through its provision of voice services. This service will include minutes of use for local service
provided at no additional charge to eligible consumers (specifically, plans are generally
unlimited usage within the U.S.). In addition, as explained below, GTl's voice service offering
will provide consumers with access to 91 I and enhanced 91 I to the extent local governments
have implemented such services. With respect to toll limitation service, GTI will offer toll
blocking service at no charge and free calling of 800 numbers to its subscribers as part of its
Lifeline service offering. GTI offers monthly traditional phone service. Grafton Long Distance
is GTl's carrier for Long Distance service and fees, in addition to the per month or per billing
cycle price of service, do apply for toll calls. Therefore, GTI is required to provide toll limitation
services and certifies that it will offer toll blocking service at no charge to subscribers as part of
its Lifeline service offering. 12
Additionally, eligible Lifeline broadband Internet access services must provide 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, but excluding dial-up service. 13 GTI certifies that its provision of high
speed broadband Internet over its fiber-based facilities satisfies the FCC's definition of
broadband Internet access services and it will therefore provide all services designated for
support by the FCC.
11 47 C.F.R. §§ 54.400-54.423. 12 47 C.F.R. § 54.401(a)(2). 13 47 C.F.R. § 54.IOl(a)(2).
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GTI will offer Lifeline voice and broadband service to qualifying low-income consumers
pursuant to the FCC's Lifeline rules.
C. GT/ Satisfies the Requirements for Providing Service Using Its Own Facilities
Both the Act and the FCC's rules require a carrier seeking ETC designation to offer the
supported services using its own facilities or a combination of its own facilities and resale of
another carrier's services. 14 GTI certifies that it will be a facilities-based broadband Internet
access and voice service provider. GTI already offers Internet broadband services and voice
service, through its fiber-based network, throughout the portion of its Designated Service Area
where it is a CLEC. Furthermore, GTI was awarded a grant through the Connect Illinois
Broadband Grant Program specifically to build out its fiber-based network and has begun to
deploy its fiber-based network throughout the Jersey County portion of its Designated Service
Area.
D. GT! Will Provide Service Throughout Its Designated Service Area
Sections 214(e)(I) and (2) of the Act and Sections 54.201(c) and (d) of the FCC's rules
state that a common carrier designated as an ETC shall offer the services supported by Federal
universal service throughout the service area for which the designation is received. 15 GTI
commits to provide the supported Lifeline service offerings throughout its Designated Service
Area, consistent with all applicable requirements. GTI's requested ETC Designated Service Area
is solely limited to the areas identified in Exhibit A.
E. GTJ Will Advertise the Availability of the Supported Services and the Relevant
Charges Using Media of General Distribution
14 47 U.S.C. § 2l4(e)(I); 47 C.F.R. § 54.20l(d). 15 47 U.S.C. §§ 2l4(e)( I) and (2); 47 C.F.R. §§ 54.201 (c) and (d).
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Pursuant to Section 214( e )(I) of the Act, carriers seeking ETC designation must advertise
the availability of such services for which it receives universal service support and the charges
therefore using media of general distribution. 16 GTI will advertise the availability of, and
charges for, its supported Lifeline service offerings using media of general distribution and will
undertake outreach initiatives to increase consumer awareness consistent with all applicable
requirements. Specifically, GT( will utilize outreach materials and methods designed to reach
households that currently do not have telephone service and those likely to qualify for the service.
Additionally, GTI will coordinate its outreach efforts with relevant government agencies and
other local groups.
GTl's advertising strategy for its supported Lifeline service offerings will build on its
already successful marketing and communication plans and strategies. GTl's advertising will
include, but not be limited to, targeted direct mail, advertisements in daily and weekly print
periodicals, booths and promotional activities at local events, billboards and radio advertising.
GTI will also coordinate with relevant state agencies, community outreach organizations, and
non-profit organizations to make information regarding GTl's supported Lifeline service
offering available in their respective resource guides, other printed materials and offices. GTI
also has existing relationships and works closely with local organizations such as Partners in
Progress, Here's to Reading, Inc. and the University of Illinois Extension Community and
Economic Development Educator in connection with its efforts to support economic
development in the Designated Service Area. GTI will also advertise through online search
engines. GTI will use the appropriate media outlets to advertise its universal service offerings in
a manner consistent with applicable requirements.
16 47 U.S.C. § 214(e)(2). 10
IV. GTI MEETS THE ADDITIONAL REQUIREMENTS FOR ETC DESIGNATION UNDER SECTION 54.202 OF THE FCC'S RULES
Section 54.202 of the FCC's rules contains certain additional requirements for a common
carrier to be designated as an ETC.17 As set forth below, GT( satisfies each of those requirements.
A. GT! Will Comply with the Service Requirements Applicable to Lifeline Support
Section 54.202(a)(I) of the FCC's rules requires a common carrier seeking ETC
designation to ( 1) certify that it will comply with the service requirements applicable to the
support that it receives and (2) submit a five-year plan for proposed improvements or upgrades
to the applicant's network unless the applicant is seeking Lifeline support only. 18 GTI seeks ETC
designation for Lifeline support only. GTI hereby certifies that it will comply with the service
requirements applicable to Lifeline support. Given that GTI seeks designation for Lifeline
support only, a five-year network improvement plan is no longer necessary. 19
B. GT! Will Remain Functional in Emergency Situations
Section 54.202(a)(2) of the FCC's rules require a common carrier seeking ETC
designation to demonstrate its ability to remain functional in emergency situations, including a
demonstration that it has a reasonable amount of back-up power to ensure functionality without
an external power source, is able to reroute traffic around damaged facilities and is capable of
managing traffic spikes resulting from emergency situations.20 GTI certifies that its fiber optic
network has the ability to remain functional in emergency situations and fulfill the applicable
requirements. GTI also certifies that its fiber optic network supports telephone service and all
phone features, including 91 I services. GTI can modify network routing and weighting as
17 47 C.F.R. § 54.202. 18 47 C.F.R. § 54.202(a)( I). 19 47 C.F.R. § 54.202(a)( I). 20 47 C.F.R. § 54.202{a)(2).
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needed to reroute traffic around damaged facilities. Traffic management capabilities will also
allow GTI to manage traffic spikes throughout its network, as emergency situations require.
GTI has established reasonable provisions to meet emergencies resulting from failures of
lighting or power service, sudden and prolonged increases in traffic, illness of operators or from
fire, storm or acts of God, including provisions to offer subscribers the option to purchase
backup power as required by Section 9.20(b) of the FCC's rules. GTl's network facilities
will have off-grid backup power available, as well, from its backup generator system.
Therefore, GTl's on-site generator will give network facilities sufficient availability
of backup power. This system ensures functionality without an external power source. In
the case of damaged facilities, GTI is able to re-route traffic to circumvent such facilities by
utilizing its secondary connections. GTI also maintains adequate capacity to manage traffic
spikes from emergency situations.
GTI has informed employees as to procedures to be followed, including reasonable
rerouting of traffic around damaged facilities and the deployment of emergency power in the
event of emergency to prevent or mitigate interruption or impairment of telecommunications
service.
C. GT/ Will Satisfy Applicable Consumer Protection and Service Quality Standards
Section 54.202(a)(3) of the FCC's rules require a common carrier seeking ETC
designation to demonstrate that it will satisfy applicable consumer protection and service quality
standards.21 GTI is currently subject to and complies with all state and federal consumer
protection requirements and service quality standards applicable to its operations. GTI has not
been the subject of any serious consumer complaints or investigations. GTI certifies that it will
21 47 C.F.R. § 54.202(a)(3). 12
continue to prioritize complying with all applicable consumer protection and service quality
standards to satisfy this requirement.
D. GTJ is Financially and Technically Capable of Providing Lifeline Services in
Accordance with the FCC 's Rules
Section 54.202(a)(4) of the FCC's rules requires a common carrier seeking ETC
designation for Lifeline support to demonstrate it is financially and technically capable of
providing Lifeline service in compliance with the FCC's rules.22 The FCC stated that the
"relevant considerations" for satisfying this requirement would be whether the applicant
previously offered services to non-Lifeline consumers, how long the applicant has been in
business, whether the applicant intends to rely exclusively on universal service fund
disbursements to operate, whether the applicant receives funds from other sources, and whether
the applicant has been subject to enforcement action or ETC revocation proceedings in other
states.23
GTI has full financial capabilities to underwrite its share of construction and start-up
expenses to get its fiber optic network built and to begin operations as GTI in the Internet and
voice services business. Additionally, Grafton Communications, Inc. is financially viable and
able to support GTI as an ETC offering Lifeline support only, as indicated in Exhibit C. GTI,
together with its parent company, Grafton Communications, Inc., and affiliates, Grafton
Telephone Company and Grafton Long Distance, has been in the telecommunications service
business for 120 years. GTI has been successfully providing residents in its CLEC service area
with telecommunications services since 1996. Therefore, GTI does not, and will not, rely on
22 47 C.F.R. § 54.202(aX4). 23 See Report and Order and Further Notice of Proposed Rulemaking et al., WC Docket Nos. 11-42, 03-109, 12-23 and CC Docket No. 96-45, FCC 12-1 I (2012) para. 388.
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universal service fund disbursements to operate - the majority of GTl's funds to operate will
come from "non-Lifeline" services it provides throughout its Designated Service Area.
GTI currently offers high-speed broadband Internet and voice services to non-Lifeline
customers in the Designated Service Area. The Connect Illinois Broadband Grant Program will
allow GTI to expand its network and offer high-speed broadband Internet and voice service to
more residents in the Designated Service Area. By the second quarter of 2021, GTI will offer
high-speed broadband internet and voice service to both Lifeline and non-Lifeline customers
throughout the entire Designated Service Area. Finally, GTI has not been subject to any
enforcement proceedings or ETC revocation proceedings.
With respect to its supported Lifeline service offerings, GTI will offer high-speed
broadband Internet services and voice services. GTl's history of successfully providing
customers with non-Lifeline telecommunications service offerings further demonstrates GTI is
technically capable of providing supported Lifeline service.
GTI has substantial experience in building, maintaining and upgrading utility
infrastructure. Accordingly, GTJ is fully able to manage, build, maintain and repair infrastructure
for support of the proposed telecommunications services. GTI has trained technicians and
equipment dedicated to repair and restoration activities. Furthermore, GTI has a 24-hour calls
service to report emergencies. GTI technicians can be dispatched 24/7 if necessary. Customer
service representatives are available during normal business hours. GTI has qualified employees
to support the proposed telecommunications services.
E. GT! Will Provide Supported Lifeline Service Plans to Eligible Consumers
Sections 54.202(a)(5) and (6) of the FCC's rules require a common carrier seeking ETC
designation for Lifeline support to submit information describing (i) the terms and conditions of
the voice telephony plans offered to Lifeline subscribers, including details on the number of
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minutes provided as part of the plan, additional charges for toll calls (if any), and rates for each
such plan and (ii) the terms and conditions of any broadband Internet access service plans offered
to Lifeline subscribers, including details on the speeds offered, data usage allotments, additional
charges for particular uses, if any, and rates for each plan.24 GTI commits that its Lifeline
supported services will meet or exceed the minimum service standards set forth in Section 54.408
of the FCC's rules, including as they change going forward. 25 At this time, GTI plans to offer
the following supported Lifeline service plans with no contract and unlimited data:
Voice
- Voice telephony services for approx. $25.00
Broadband Internet
- 20/20 Mbps for $65.95/month - 30/30 Mbps for $75.95/month - 40/40 Mbps for $85.95/month - 50/50 Mbps for $95.95/month - 75175 Mbps for $116.95/month
100/100 Mbps for$ 130.95/month 1 Gbps for $299.95/month.
GTI's planned supported Lifeline service offerings are consistent with the Act's requirement that
consumers have access to quality services at "just, reasonable, and affordable rates."26
V. DESIGNATION OF GTI AS AN ETC SERVES THE PUBLIC INTEREST
Section 54.202(b) of the FCC's rules requires the Commission to make a public interest
finding prior to making an ETC designation.27 Designation ofGTI as an ETC for Lifeline support
serves the public interest by bringing high-speed broadband Internet and voice services to
underserved locations in the Designated Service Area, as well as subsidized voice and broadband
24 47 C.F.R. §§ 54.202(a)(4) and (6). 25 47 C.F.R. § 54.408. 26 47 U.S.C. § 254(b)(I). ~7 47 C.F.R. § 54.202(b).
15
services to those households that qualify for Lifeline benefits. GTl's ETC designation will bring
another competitive alternative to low-income consumers in the Designated Service Area. For
the last 120 years, GT!, through its parent company and affiliates, has been an active member in
its community and has been committed to supporting numerous efforts to help its region grow
and prosper. A portion of the Designated Service Area is an economically distressed area, with
the DCEO having specifically designated the community of Fieldon, IL an Opportunity Zone.
Consequently, the Designated Service Area requires long-term investment and job creation given
that it is a low-income area and people are leaving. The only way to attract such long-term
investment and create better jobs is through better broadband. GTI was inspired to apply for a
grant through the Connect Illinois Broadband Grant Program after receiving numerous letters of
support from residents stating that high speed broadband is necessary for bringing improved
economic, educational, healthcare and public safety opportunities to the Designated Service
Area. Better broadband would also support more sophisticated farm operations.
GTI is determined to make it easier for low-income consumers located within the
Designated Service Area to receive affordable telecommunications and high-speed broadband
Internet services that are comparable to those enjoyed by other customers. GTI understands that
access to voice services and high-speed broadband Internet services will attract more businesses
and residents to the area, creating better jobs and allowing families to enjoy a decent lifestyle.
GTl's ETC designation will serve the public interest by providing services to customers that may
not otherwise be able to obtain telecommunications services. Lifeline supported services also
offer customers convenience, control over their telecommunications and high-speed broadband
Internet spending without high monthly fees, and the ability to pay for only those services
needed. Finally, given the current COVID-19 crisis, it is now more important than ever that
residents within the Designated Service Area have access to high quality and affordable
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broadband and voice services. The goals of universal service mandated by Congress and the FCC
are therefore served by designating GTI as a Lifeline-only ETC.28
VI. ANTI-DRUG ABUSE CERTIFICATION
GTI certifies that, pursuant to Sections 1.200 I through 1.2003 of the FCC's rules, that
neither GTI nor its subsidiaries, affiliates, officers, directors, or persons holding 5% or more of
its outstanding stock, are subject to a denial offederal benefits, including FCC benefits, pursuant
to Section 5301 of the Anti-Drug Abuse Act of 1988.29
VII. CONCLUSION
For all of the foregoing reasons, GTI respectfully requests that the Commission designate
it as an ETC so that GTI will be eligible for Lifeline support only.
November f'l, 2020
~8 47 U.S.C. § 254.
Respectfully submitted,
Vice President Grafton Technologies, Inc. PO Box 428 Jerseyville, IL 62052 (618)639-4841 shami [email protected]
29 See Procedures for FCC Designation of Eligible Telecommunications Carriers Pursuant to Section 214(e)(6) of the Communications Act, 12 FCC Red 22947, 22948-949 ( 1997).
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EXHIBIT A
MAP OF DESIGNATED SERVICE AREA IN WHICH GTI SEEKS
ELIGILBLE TELECOMMUNICATIONS CARRIER DESIGNATION
STATE OF ILLINOIS
COUNTY OF JERSEY
EXffIBtTB
AFFIDAVIT OF SUSAN HAMIL TON
) ) )
ss.
Susan Hamilton, after being duly sworn, states the following:
I. I have personal knowledge of the facts and information set forth in this Affidavit and I am competent to testify to these facts if called as a witness.
2. I am the Vice President and Director of Operations of Grafton Communications, Inc. and its wholly-owned direct subsidiary, Grafton Technologies, Inc. ("GTI"). Acting on behalf of Grafton Communications, Inc. and GTI, I have read the Petition to which this Affidavit is attached. I have knowledge of the facts stated in the Petition and those facts are true to the best of my knowledge and my belief.
3. GTI certifies that it is a common carrier under Sections 214(e)(I) and 2l4(e)(6) of the Communications Act of 1934 ("Act").
4. GTI commits to provide the services and functionalities required for designation as an Eligible Telecommunications Carrier in the Designated Service Area described in the Petition.
5. GTI certifies that it will meet all of the Commission's requirements for designation as an ETC under Section 214(e)(6) of the Act, as specified in the Petition.
6. I am the corporate officer responsible for certifying GTl's use of federal low-income support funds. GTI is eligible to be designated as an Eligible Telecommunications Carrier within the meaning of Section 214( e) of the Act and is eligible to receive universal service support pursuant to Section 254(e) of the Act.
7. GTI certifies that no party to this Petition is subject to denial of federal benefits, including Commission benefits, pursuant to Section 5301 of the Anti-Drug Abuse Act of 1988.
Date: November 1'1 , 2020
Grafton Technologies, Inc. PO Box428 Jerseyville, IL 62052 ( 618)639-4841 [email protected]
EXHIBIT C
Financial Information for Grafton Technologies, Inc.
REDACTED VERSION FOR PUBLIC INSPECTION
EXHIBITC
Financial Information for Grafton Technologies, Inc.
The attached documents are confidential and proprietary. Pursuant to 83 Ill. Adm. Code Section 200.605, applicant does not make these documents publicly available. Documents have been submitted under seal.
EXHIBITD
VERIFICATION
Under penalties as provided by law pursuant to Section 1-109 of the Code of Civil Procedure, the undersigned certifies that the statements set forth in this instrument are true and correct, except as to matters therein stated to be on information and belief and as to such matters the undersigned certifies as aforesaid that he verily believes the same to be true.
November fl, 2020
Vice President Grafton Technologies, Inc. PO Box 428 Jerseyville, IL 62052 (618)639-4841 sham i [email protected]
