20230302Application.pdf

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
DISH Wireless L.L.C. Application for Designation as an Eligible Telecommunications Carrier in the State of
Idaho for the Limited Purpose of Providing
Lifeline Service to Qualifying Customers
) )
)
) )
Case No. ________
APPLICATION OF DISH WIRELESS L.L.C. FOR DESIGNATION AS AN ELIGIBLE TELECOMMUNICATIONS CARRIER IN THE STATE OF IDAHO FOR THE LIMITED PURPOSE OF OFFERING LIFELINE SERVICE TO QUALIFIED HOUSEHOLDS
Thomas J. Lloyd III Elam & Burke, P.A. 251 East Front Street Ste. 300
Post Office Box 1539
Boise, ID 83701 [phone](208) 384-5844 (fax)[e-mail]
March 2, 2023
RECEIVED
2023 March 2, PM 1:09
IDAHO PUBLIC
UTILITIES COMMISSION
DWL-T-23-01
ii
TABLE OF CONTENTS
I.INTRODUCTION .............................................................................................................. 1
II.COMPANY OVERVIEW .................................................................................................. 2
III.THE COMMISSION HAS JURISDICTION OVER DESIGNATION OF WIRELESSETCS ................................................................................................................................... 4
IV.THE COMPANY MEETS THE REQUIREMENTS FOR ETC DESIGNATION ........... 5
A.DISH Wireless Is a Common Carrier ..................................................................... 6
B.DISH Wireless Will Offer the Services Supported by Federal Universal Service . 7
C.DISH Wireless Will Offer the Services Designated for Support Using aCombination of Its Own Facilities and Resale ....................................................... 7
D.DISH Wireless Will Provide Gen Mobile-Branded Service Throughout Its
Designated Service Area ......................................................................................... 8
E.The Company Will Advertise the Availability of Gen Mobile Services andCharges Using Media of General Distribution ....................................................... 9
F.DISH Wireless Will Comply with Service Requirements Applicable to theSupport It Receives ................................................................................................. 9
G.DISH Wireless Will Comply with Any Applicable Two-Year and Five-Year Plan
Requirements ........................................................................................................ 10
H.Consumer Protection and Service Quality Standards ........................................... 10
I.Ability to Remain Functional During Emergencies.............................................. 10
J.DISH Wireless Is Financially and Technically Capable....................................... 11
K.Terms and Conditions of Proposed Lifeline Offering .......................................... 12
L.Gen Mobile’s Offerings Will Comply with Lifeline Certification and Annual Re-certification Requirements .................................................................................... 13
M.DISH Wireless Will Comply With All Regulations Imposed by the Commission............................................................................................................................... 14
N.Prevention of Waste, Fraud and Abuse................................................................. 15
V. DESIGNATING DISH WIRELESS AS AN ETC WOULD PROMOTE THE PUBLICINTEREST ........................................................................................................................ 16
iii
A.Advantages of Gen Mobile Lifeline Plans ............................................................ 17
B.Benefits of Competitive Choice ............................................................................ 18
C.Commission Public Interest Standard ................................................................... 18
VI.ANTI-DRUG ABUSE CERTIFICATION ....................................................................... 19
VII.CONCLUSION ................................................................................................................. 19
LIST OF EXHIBITS:
Exhibit 1 – Certification
Exhibit 2 – Proposed Lifeline Plans
Exhibit 3 – Service Area
Exhibit 4 – Sample Advertising
Exhibit 5 – Financial Statements
Exhibit 6 – Key Personnel Bios
Before the IDAHO PUBLIC UTILITIES COMMISSION
DISH Wireless L.L.C. Application for Designation as an Eligible
Telecommunications Carrier in the State of
Idaho for the Limited Purpose of Providing Lifeline Service to Qualifying Customers
)
)
) ) )
Docket No. ________
I.INTRODUCTION
DISH Wireless L.L.C. dba Gen Mobile (“DISH Wireless” or the “Company”), by its
undersigned counsel, and pursuant to Section 214(e)(2) of the Communications Act of 1934, as
amended (the “Act”),1 Sections 54.101 through 54.2072 of the Rules of the Federal
Communications Commission (“FCC”),3 the Idaho Telecommunications Act of 1988,4 and the
orders of the Idaho Public Utilities Commission (the “Commission”),5 , hereby submits this
Application for Designation as an Eligible Telecommunications Carrier (“ETC”) in the State of
Idaho. The Company seeks ETC designation for the limited purpose of providing Lifeline
1 47 U.S.C. § 214(e)(2).
2 47 C.F.R. §§ 54.101-54.207.
3 DISH Wireless files this Application in accordance with the rules adopted by the FCC in the 2012 Lifeline Reform Order. See Lifeline and Link Up Reform and Modernization, Lifeline and Link Up, Federal-State Joint Board on Universal Service, Advancing Broadband Availability Through Digital Literacy Training, WC Docket Nos. 11-42 and 03-109, CC Docket No. 96-45, WC Docket No. 12-23, Report and Order and Further Notice of Proposed Rulemaking, FCC 12-11 (rel. Feb. 6, 2012) (“2012 Lifeline Reform Order”).
4 Idaho Code §§ 62-610(D)(1) and 62-615(1).
5 Application of WWC Holding Co., Inc. dba Cellular-One® Seeking Designation as an Eligible Telecommunications Carrier That May Receive Federal Universal Service Support, Case No. WST-T-05-1, Order No. 29841(Aug. 4, 2005) (attaching Appendix titled “Requirements for Eligible Telecommunications Carrier (“ETC”) Designation, Reporting, and Certification”) (“Order No. 29841”), as amended by Torch Wireless’s Application for Designation as an Eligible Telecommunications Carrier in Idaho, Case No. TOR-21-01, Order No. 35126 (Aug. 25, 2021) (removing requirement that the Commission (in addition to the applicant) provide notice of an ETC application to affected Tribes) (“Order No. 35126”).
2
service under the brand name “Gen Mobile” to qualifying Idaho consumers, including those on
federally recognized Tribal lands. DISH Wireless requests for its ETC designation to include the
authority to participate in and receive reimbursement from the Idaho Telephone Service
Assistance Program (“ITSAP”).6
As demonstrated herein, and as certified in Exhibit 1 to this Application, the Company
meets all the federal and state statutory and regulatory requirements for designation as an ETC in
Idaho. Grant of this Application, moreover, would advance the public interest because it would
enable the Company to commence much needed Lifeline services to low-income Idaho residents,
including those on Tribal lands, as soon as possible. Accordingly, the Company respectfully
requests that the Commission expeditiously approve this Application.
All correspondence, communications, pleadings, notices, orders and decisions relating to
this Application should be addressed to:
Thomas J. Lloyd III
Elam & Burke, P.A. 251 East Front Street Ste. 300 Post Office Box 1539 Boise, ID 83701
[phone]
[phone] (fax)[e-mail]
Alison Minea Vice President and Associate
General Counsel
DISH Wireless L.L.C. 1110 Vermont Ave NW Ste. 450 Washington, DC 20005 [phone]
[e-mail]
II.COMPANY OVERVIEW
DISH Wireless L.L.C. is a Colorado limited liability company with a principal address at
9601 S. Meridian Blvd, Englewood, CO 80112. DISH Wireless provides, among other things,
resold wireless telecommunications services operating in Idaho and other states, using the Gen
Mobile brand name and other brand names.
6 Idaho Code Ann. §§ 56-901, 56-902 (2013).
3
DISH Wireless’ parent company, DISH Network Corporation (“DISH Network”), is a
connectivity company headquartered in Colorado that has served as a disruptive force in the pay-
TV market since 1980. In 2020, DISH Wireless entered the retail wireless business by acquiring
the Boost Mobile brand and in 2021, acquiring the Gen Mobile brand as well as other brands and
customer assets. Now, using its own licensed wireless spectrum assets, DISH Wireless is
building the nation’s first virtualized, cloud-native, Open RAN-based 5G broadband network.
To facilitate the buildout, DISH Wireless has entered into multi-year agreements with over 30
partners, including Mavenir, Amazon, Dell, CISCO, VM Ware, IBM, Oracle, Nokia, Fujitsu,
MTI, Intel, Altiostar, Samsung, and Qualcomm. Because DISH Wireless is actively constructing
wireless facilities around the country, it is well positioned to identify opportunities to target
buildouts in underserved areas.
Even as the 5G network is under construction, DISH Wireless has already been
competing in the retail wireless space and is an approved provider in the Federal
Communications Commission’s Affordable Connectivity Program (“ACP”). Under the Gen
Mobile and other brand names, DISH Wireless currently uses AT&T and T-Mobile wireless
facilities to provide discounted mobile broadband service in all 50 states and the territories of
Washington D.C. and Puerto Rico, including plans bundling voice, text messaging, and
broadband services.7 Available Gen Mobile branded plans include talk, text, and data at various
data speeds under the ACP’s monthly $30 subsidy for eligible consumers. DISH Wireless has an
application for ETC designation pending with the FCC (for the states of Alabama, Connecticut,
Delaware, Florida, New Hampshire, North Carolina, and the District of Columbia, the “Non-
7 See 47 C.F.R. § 54.1602(b) (“a bundle of broadband internet access service along with fixed or mobile voice telephony service, text messaging service, or both” is an EBB-eligible plan).
4
Jurisdictional States”). DISH Wireless is currently designated as a wireless ETC in Colorado,
New York, and Oklahoma and authorized by the California Public Utilities Commission to
provide California LifeLine service and plans to file for ETC status in other states over time.
DISH Wireless now seeks an ETC designation in Idaho so that it can (i) serve low-
income Idaho customers, including those residing on Tribal lands, (ii) supplement the amount of
support available to its current ACP customers, and (iii) invite new, underserved customers to
benefit from Lifeline and other federal support programs. DISH Wireless’ Lifeline-supported
plans will be offered to prepaid customers under the Gen Mobile brand, a recognized and trusted
provider in this market segment. Gen Mobile prepaid wireless plans are affordable, easy to use,
and attractive to low-income consumers, providing them with connectivity that has become
indispensable to participating in 21st century society and opportunities. Gen Mobile customers
can choose from several affordable prepaid calling plans and handsets and have access to high-
quality, responsive customer service. Gen Mobile prepaid plans start as low as $10 per month
and can be refilled at an estimated 10,000 retail locations nationwide.
III. THE COMMISSION HAS JURISDICTION OVER DESIGNATION OF WIRELESS ETCS
Section 214(e)(2) of the Act provides state public utility commissions with the primary
responsibility for the designation of ETCs.8 Under the Act, a state public utility commission,
like the Commission, with jurisdictional authority over ETC designations must designate a
common carrier as an ETC if the carrier satisfies the requirements of Section 214(e)(1).
Therefore, the Commission has the authority to designate DISH Wireless as an ETC. As

8 47 U.S.C. § 214(e)(2).
5
demonstrated below, DISH Wireless fulfills the requirements to be designated as an ETC in
Idaho.
IV. THE COMPANY MEETS THE REQUIREMENTS FOR ETC DESIGNATION
An application for ETC designation in Idaho must meet specific federal statutory and
regulatory requirements and state requirements. As demonstrated below, DISH Wireless meets
the requirements for ETC designation by the FCC pursuant to Section 214(e)(2) of the
Communications Act and Order No. 29841.9 These include: (1) a certification that the applicant
offers or intends to offer all services designated for support by the FCC pursuant to section
254(c) of the Communications Act; (2) a certification that the applicant offers or intends to offer
the supported services on a common carrier basis either using its own facilities or a combination
of its own facilities and/or resale of another carrier’s services; (3) a description of how the
applicant advertises the availability of the supported services and the charges therefor using
media of general distribution; (4) a detailed description of the geographic service area for which
the applicant requests to be designated as an ETC; and (5) a certification that neither the
applicant, nor any party to the application, is subject to a denial of federal benefits pursuant to
the Anti-Drug Abuse Act of 1988.10
In addition, an applicant seeking designation as an ETC solely for the purpose of offering
Lifeline service must: (1) certify that it will comply with the service requirements applicable to
the support that it receives; (2) demonstrate its ability to remain functional in emergency
situations; (3) demonstrate its ability to satisfy applicable consumer protection and service

9 Order No. 29841 provides: “All ETC applicants must follow the federal statutory requirements for ETC Designation. See 47 U.S.C. § 214(e)(1).” Appendix, § A.
10 47 U.S.C. § 214(e)(1) and (5); 47 C.F.R § 54.201(d)(1) and (2); 47 C.F.R § 54.207(a).
6
quality standards; and (4) demonstrate that it is financially and technically capable of providing
Lifeline service.11
Finally, prior to designating a carrier as an ETC, the Commission must determine
whether such designation is in the public interest.12 When making a public interest
determination, the Commission considers the benefits of increased consumer choice and the
unique advantages and disadvantages of the applicant’s service offerings.13 The Commission
also considers (1) whether the applicant will contribute to appropriate Idaho funds, which include
funds that support the ITSAP and the Idaho Telecommunications Relay Services program,14 and
(2) whether the applicant is engaged in “cream-skimming” (i.e., when a an applicant seeks ETC
designation for only part of a rural telephone company’s study area, thus leaving some customers
(who are likely less-profitable) without service.15
A. DISH Wireless Is a Common Carrier
DISH Wireless provides, among other things, commercial mobile radio services (CMRS)
that are regulated pursuant to the common carrier requirements of the Communications Act.16
Accordingly, the Company meets the common carrier requirement for ETC designation pursuant
to Section 214(e)(1) of the Act and Section 54.201(d) of the FCC’s rules.
11 47 CFR § 54.202(a). Section 54.202(a)(ii) requires carriers seeking ETC designation that is not limited to Lifeline service to submit a five-year plan that describes proposed improvements to the carrier’s network throughout the proposed service area. Although DISH Wireless is not seeking high cost support in this Application, it is building out its 5G network in accordance with certain FCC-approved construction deadlines as described below.
12 47 U.S.C. §214(e)(6); 47 C.F.R. § 54.202(b).
13 See, e.g., Virgin Mobile ETC Designation Order in the States of Alabama, Connecticut, Delaware, New Hampshire and the District of Columbia, WC Docket 09-197, Order, 25 FCC Rcd 17797, 17799, ¶ 6 (WCB 2010).
14 See Idaho Code §§ 56-904, 61-1301; see, e.g.,
15 See, e.g., Order No. 35126, at 5.
16 See 47 U.S.C. § 153(11) (defining a common carrier as “any person engaged as a common carrier for hire, in interstate or foreign communications by wire or radio . . . .”; 47 U.S.C. §332 (c)(1)(A) (treating commercial mobile service providers as common carriers).
7
B. DISH Wireless Will Offer the Services Supported by Federal Universal Service
Pursuant to Section 54.101(a) of the FCC’s rules, DISH Wireless’ voice service provides
the following: (1) voice grade access to the public switched network or its functional equivalent;
(2) minutes of use for local service at no additional charge to end users; (3) access to the
emergency services provided by local government or other public safety organizations, such as
911 and enhanced 911, to the extent the local government in an eligible carrier’s service area has
implemented 911 or enhanced 911 systems; and (4) toll limitation services to qualifying low-
income consumers.17 As defined in Section 8.1(b) of the FCC’s rules, DISH Wireless also
provides broadband internet access service to consumers.18
C. DISH Wireless Will Offer the Services Designated for Support Using a Combination of Its Own Facilities and Resale
DISH Wireless, through the Gen Mobile brand, offers the supported services – voice
telephony service and broadband Internet access service – meeting the standards set in the FCC’s
rules.19 DISH Wireless is currently providing and will provide mobile voice, text messaging,
and broadband services to low-income consumers. The various Lifeline service plans that will
be available to qualifying low-income Idaho residents, including those on Tribal lands, are
described in Exhibit 2.
In general, Section 214 requires ETCs to provide services using their facilities, at least in
part. DISH Wireless is in a unique position to increase wireless competition and serve low-
incomer consumers. Gen Mobile service plans are currently supported by AT&T and T-
Mobile’s networks. This will allow DISH Wireless to immediately introduce new Lifeline

17 47 C.F.R. § 54.101(a); see also 47 U.S.C. § 214(e)(1)(A).
18 See 47 C.F.R. § 8.1(b).
19 See 47 C.F.R. § 54.101(a).
8
options for Idaho consumers as soon as the Commission approves this Application. At the same
time, DISH Wireless is building out an advanced nationwide 5G network of its own. The
Company recently launched 5G broadband service in over 130 cities (including in Idaho) and
currently offers service to more than 20 percent of the U.S. population.20 In areas of Idaho
where service on DISH Wireless’ own network is not yet available or where the Company does
not yet offer Lifeline products on its own network, DISH Wireless will provide service on a
resale basis on the networks of AT&T and/or T-Mobile. Accordingly, pursuant to 47 U.S.C. §
214(e)(1)(A) and 47 C.F.R. § 54.101(b), DISH Wireless will offer Gen Mobile-branded services
that are designated for federal universal support using a combination of its own facilities and/or
resale of another carrier’s services. A complete description of the Gen Mobile terms, conditions
and rates applicable for supported services can be found at https://www.genmobile.com.
Because DISH Wireless is deploying facilities-based wireless voice and broadband services in
Idaho and other states, there is no need for DISH Wireless to obtain an approved FCC
Compliance Plan in accordance with the 2012 Lifeline Reform Order.21
D. DISH Wireless Will Provide Gen Mobile-Branded Service Throughout Its Designated Service Area
Pursuant to 47 U.S.C. § 214(e)(1) and 47 C.F.R. § 54.201(d), as an ETC, DISH Wireless
will provide service in the same 50-state footprint where it currently offers ACP service – this
includes the entire geographic boundary of the State of Idaho subject to coverage limits of
underlying carriers and DISH Wireless’ own network. Further, pursuant to 47 C.F.R. §
54.202(a)(1)(i), the Company commits to provide service throughout its proposed service area on

20 See DISH Press Release, DISH’s Smart 5G™ Wireless Network is Now Available to Over 20 Percent of the U.S. Population, June 15, 2022. See also Applications of American H Block Wireless L.L.C., DBSD Corporation, Gamma Acquisition L.L.C., and Manifest Wireless L.L.C. for Extension of Time, Order of Modification and Extension of Time to Construct, DA 20-1072 WT Docket 18-197 (rel. Sept. 11, 2020).
21 See 2012 Lifeline Reform Order, ¶ 368.
9
a timely basis to all customers making a reasonable request for service where facilities are
available. DISH requests ETC designation that is statewide in scope, including on federally-
recognized Tribal lands, to allow the Company to provide Lifeline service wherever its
underlying, facilities-based providers have wireless coverage.22 The current Idaho coverage
footprint or service area by zip code is attached hereto as Exhibit 3.
E. The Company Will Advertise the Availability of Gen Mobile Services and Charges Using Media of General Distribution
Pursuant to 47 U.S.C. § 214(e)(1)(B) and 47 C.F.R. § 54.201(d)(2), the Company will
advertise the availability of Gen Mobile-branded voice, text messaging, and broadband services
through various marketing channels that may include direct mail, email, local and community
outreach events, and targeted online electronic advertising. In addition, the availability of Gen
Mobile Lifeline service will be publicized in ways that are reasonably designed to reach those
who will likely qualify for the service. The Company’s marketing efforts will be consistent with
and in compliance with the Commission’s rules. Samples of the Company’s Lifeline advertising
are attached hereto as Exhibit 4.
F. DISH Wireless Will Comply with Service Requirements Applicable to the Support It Receives
Pursuant to 47 C.F.R. § 54.202(a)(1)(i), DISH Wireless will comply with the service
requirements applicable to the supported services it will be offering in the identified service
areas. Gen Mobile plans will be offered in Idaho initially by reselling AT&T and/or T-Mobile
service, and in the future will also be supported by DISH’s own 5G network facilities when
feasible. These providers’ networks are operational and largely built out. Thus, the Company
22 In accordance with Order No. 29841, DISH Wireless is providing notice of this Application to all affected tribal governments and tribal regulatory authorities. A certificate of service listing the recipients is attached.
10
will be able to commence offering its Lifeline service to all locations served by its underlying
carriers very soon after receiving approval from the Commission.
G. DISH Wireless Will Comply with Any Applicable Two-Year and Five-Year Plan Requirements
Pursuant to 47 C.F.R. § 54.202(a)(1)(ii), a common carrier seeking designation as a
Lifeline-only ETC is not required to submit a five-year network improvement plan as part of its
application for designation as an ETC. DISH Wireless is in a unique position, however, because
it is constructing its own facilities-based 5G wireless network subject to FCC-approved buildout
milestones, including having already deployed its 5G broadband service to 20% of the U.S.
population on June 14, 2022 and scheduled to deploy in 70% of the U.S. population by June 14,
2023 and (using certain low-band spectrum) to 75% of the population of each Partial Economic
Area by June 14, 2025. DISH Wireless commits to providing service consistent with the
requirements of any other support mechanism pursuant to which it is authorized to receive
support in the future.
H. Consumer Protection and Service Quality Standards
The Company commits to comply with all applicable consumer protection and service
quality standards for universal service programs. As stated in 47 C.F.R. § 54.202(a)(3), a
wireless applicant’s commitment to comply with the Cellular Telecommunications and Internet
Association’s Consumer Code for Wireless Service (“CTIA Consumer Code”) will satisfy this
consumer protection and service quality requirement. DISH Wireless commits to fully
complying with the CTIA Consumer Code.
I. Ability to Remain Functional During Emergencies
The Company’s services are able to remain functional in emergency situations as
required by 47 C.F.R. Section 54.202(a)(2). DISH Wireless’ greenfield 5G network operates in
11
a cloud-native environment that is not encumbered by traditional technology and will be more
flexible and resilient in the event of service outages. In addition, DISH Wireless relies on mobile
virtual network operator (MVNO) partner networks that are designed to remain functional even
without external power sources, are able to re-route traffic around damaged facilities, and can
manage traffic spikes that may occur in emergency situations.
J. DISH Wireless Is Financially and Technically Capable
As part of the 2012 Lifeline Reform Order, the FCC amended its rules to require a carrier
seeking designation as a Lifeline-only ETC to demonstrate that it is financially and technically
capable of providing the supported Lifeline service in compliance with all of the low-income
program rules.23 DISH Wireless satisfies these criteria.
DISH Wireless is financially stable and capable of honoring its service obligations to
customers, as shown in Exhibit 5, a link to the Form 10-K of DISH Network Corporation, parent
company of DISH Wireless, as well as meeting its federal and state regulatory obligations. The
Company will not rely exclusively on revenues from the provision of Lifeline services for its
operating revenues. The Company also has access to additional capital resources from its parent
and affiliate companies. The Company’s financial resources position the Company to expand its
operations to serve currently unserved/underserved eligible low-income Idaho consumers,
including those residing on Tribal lands, and increase competition.
In addition, the proposed Lifeline offerings will be overseen by a team of personnel with
substantial industry experience with the requirements of the federal Lifeline program and
marketing to the low-income consumer sector. Attached as Exhibit 6 is a current list of the
Company’s key personnel responsible for Gen Mobile-branded Lifeline offerings, with

23 See 2012 Lifeline Reform Order, ¶ 387; see also 47 C.F.R. § 54.202(a)(4).
12
biographical information for each, showing that the Company has the expertise necessary to
provide the services detailed herein.
K. Terms and Conditions of Proposed Lifeline Offering
The Company has the ability to provide all services supported by the universal service
program, as detailed in 47 C.F.R. § 54.101(a), throughout Idaho. The Company further affirms
that its Lifeline-supported voice services will meet or exceed the minimum service standards set
forth in 47 C.F.R. § 54.408, including as such standards are updated going forward. Gen
Mobile-branded Lifeline-supported broadband services will also meet the minimum service
standards set forth in 47 C.F.R. § 54.408 for mobile broadband internet access services,
including for service speed and data usage allowance, as such standards are updated going
forward. To the extent DISH Wireless provides devices for use with Lifeline-supported
broadband service, such devices will meet the equipment requirements set forth in 47 C.F.R. §
54.408(f), and DISH Wireless will not impose an additional or separate tethering charge for
mobile data usage below the minimum standard.
Attached hereto as Exhibit 2 is a summary table of the Company’s proposed Lifeline
service offerings, showing that Lifeline customers can receive 1,000 voice minutes, 1,000 text
messages, and 4.5 gigabytes (GB) of data per month at a net cost of $0.00 after application of
Lifeline support and customers on Tribal lands can receive unlimited voice minutes and text
messages and 11 GB of data per month at a net cost of $0.00 after application of Lifeline Tribal
support . Customers will also be able to purchase additional minutes or data as needed. In
addition to wholly-supported or discounted wireless services, prepaid Lifeline customers will be
able to receive an upgraded handset at an additional charge or SIM card offer, as well as access
to voice mail, caller I.D., call forwarding, 3-way calling, and call waiting features at no
additional charge. Customers may use their minutes to place domestic long-distance calls at no
13
additional charge, and calls to the Company’s customer service are free with no deduction of
available minutes. Calls to 911 emergency services are always free, regardless of service
activation or availability of minutes.
L. Gen Mobile’s Offerings Will Comply with Lifeline Certification and Annual
Re-certification Requirements
Customers interested in obtaining information on the Lifeline program will be directed to
a toll-free telephone number and to the Company’s website, which will contain information
regarding the Company’s Lifeline service plans, including a description of the Lifeline program
and eligibility criteria. DISH Wireless will use multiple outreach methods including but not
limited to nonprofit partnerships, phone, online, and in person enrollments through Lifeline
events. Section 54.410 of the FCC’s rules requires ETCs to certify and verify a Lifeline
customer’s initial and continued eligibility. DISH Wireless will rely on the National Verifier and
the National Lifeline Accountability Database (“NLAD”), both administered by the Universal
Service Administrative Company (“USAC”), to determine an applicant’s eligibility for Lifeline
service. DISH Wireless will require all Gen Mobile’s Lifeline applicants to complete the
standard Lifeline application forms in the National Verifier environment. The standard Lifeline
application complies with the disclosure, certification, and information collection requirements
in 47 C.F.R. § 54.410(d).24
For applicants verified as being eligible by USAC’s National Verifier and NLAD, DISH
Wireless will complete enrollment by transmitting the required information into NLAD as
required by Section 54.404(b)(6) of the FCC’s rules. In addition, at the time of enrollment, the
24 FCC Wireline Competition Bureau Provides Guidance on Universal Forms for the Lifeline Program, WC Docket No. 11-42, Public Notice, “Wireline Competition Bureau Provides Guidance on Universal Forms for the Lifeline Program,” DA 18-161 (rel. Feb. 20, 2018). The standard application/certification forms are available on USAC’s website (see USAC, Lifeline Forms, http://www.usac.org/li/tools/forms/default.aspx).
14
Company will notify the applicant that the prepaid service must be personally activated by the
subscriber and the subscriber must use their service every thirty (30) days in order to maintain
their Lifeline benefit.
DISH Wireless will also comply with Sections 54.410(f) of the FCC’s rules governing
annual subscriber re-certification of eligibility and will coordinate with USAC’s National
Verifier and NLAD systems to manage additional de-enrollments related to USAC-administered
benefit transfers and failure to re-certify.25
M. DISH Wireless Will Comply With All Regulations Imposed by the Commission
By way of this Application, DISH Wireless hereby declares its ability and goal to comply
with all the rules and regulations that the Commission may lawfully impose upon the Company’s
provision of service contemplated by this Application, including any reporting requirements set
by the Commission. The Company will comply with any applicable ITSAP rules and
regulations, including but not limited to required monthly reporting, as well as execution of a
memorandum of understanding with the Department of Health and Welfare.26 DISH Wireless
commits to remitting the required ITSAP funds to the ITSAP Administrator. DISH Wireless will
answer any questions or present additional testimony and other evidence about its services within
the state upon the Commission’s request. In addition, DISH wireless promises to pass on all
support received from the federal Universal Service Fund (“USF”) to its qualified Lifeline
customers.

25 47 C.F.R. §§ 54.405(e), 54.410(f).
26 Idaho Code Ann. §§ 56-901, 56-902
15
N. Prevention of Waste, Fraud and Abuse
The Company recognizes the importance of safeguarding the USF, and has implemented
measures and procedures to prevent duplicate Lifeline benefits being awarded to the same
household. Gen Mobile Lifeline offerings will comply with the requirements of the NLAD and
section 54.404 of the FCC’s rules. As part of the application process, the National Verifier
queries the NLAD for every enrollment to determine whether a prospective subscriber is
currently receiving a Lifeline service from DISH Wireless or any other ETC, and whether
anyone else living at the prospective subscriber’s residential address is currently receiving
Lifeline service.
Consistent with federal regulations, the Company will not seek USF reimbursement for
new subscribers until they have activated the service, either by initiation and/or actual use of the
service, and will de-enroll any subscriber that has not used the Company’s Lifeline service as set
forth in 47 C.F.R. § 54.407(c)(2). An account will be considered active if the authorized
subscriber establishes usage, as “usage” is defined by 47 C.F.R. § 54.407(c)(2), during the
specified timeframe, currently a period of thirty (30) days, or during the notice period set forth in
47 C.F.R. § 54.405(e)(3), currently a period of fifteen (15) days. In accordance with 47 C.F.R.§
54.405(e)(3), DISH Wireless will provide the subscriber advance notice when a subscriber’s
failure to use the Lifeline service within the notice period will result in service termination for
non-usage. Customers that have been deactivated may participate in the Company’s Lifeline
service in the future by reapplying and re-establishing eligibility.
To further protect the integrity of the USF, DISH Wireless contracts with third party
vendors to backstop USAC’s own processes and procedures. First, the Company will use
Emerios Enterprise Services Inc. (“Emerios”) software to process Lifeline applications. Among
other things, Emerios uses third-party verification sources (including the Lexis Nexis LEXID
16
service) to validate a prospective customer’s identity. Emerios also validates the Company’s
subsidy data to prevent duplicate subsidies. In addition, the Company has established a back-
office real time review (“RTR”) process to be completed before a Lifeline application is passed
to the National Verifier to qualify a customer. This process involves specially trained operations
analysts (who have no financial stake in whether an application is successful) individually
confirming the information entered into the application and supporting documentation to, among
other things, confirm the identities of the sales agent and the customer by reviewing pictures of
them in real time during the application process and review the customer’s identification and
address for anomalies. DISH Wireless has hired experienced staff and a third party company to
provide RTR for the Company’s Lifeline enrollments. This third party company has substantial
experience running RTR for other Lifeline providers.
V. DESIGNATING DISH WIRELESS AS AN ETC WOULD PROMOTE THE PUBLIC INTEREST
The Commission will advance the public interest by designating the Company as an ETC
so that it can offer the Gen Mobile-branded Lifeline services. Americans increasingly need
greater access to voice and broadband services, and low-income Idaho consumers, including
those on Tribal lands, in particular are suffering from the lack of affordable and available access.
The Company is currently helping to close the gap by providing service under the ACP and
stands ready to expand consumer choice and continue offering discounted services as a Lifeline
ETC to customers who have come to rely on these benefits. In addition, because DISH Wireless
is deploying a new facilities-based wireless 5G network throughout the country over the next
several years, designating DISH Wireless as an ETC will improve its ability to apply for state
broadband funding grants, should ETC designation be required, to increase service in
underserved and unserved areas.
17
A. Advantages of Gen Mobile Lifeline Plans
Authorizing the Company as a Lifeline ETC in the State of Idaho will enable the
Company to provide eligible low-income consumers, including those residing on Tribal lands,
with access to high quality mobile voice, text, and data services. This will increase those
consumers’ choices in service providers and service options and make essential communications
services more affordable and accessible to these consumers. Mobile services are
overwhelmingly preferred by Lifeline-eligible consumers who may be able to afford only a
single connection, may frequently change residences or places of employment, and may need the
ability to communicate with prospective employers. Some of these individuals may be
experiencing homelessness and rely upon Lifeline service as their single reliable source of
connectivity. Lifeline services also ensure that consumers always have the ability to contact 911
emergency services should the need arise. The availability of a no-charge Lifeline service that
includes voice minutes, texts, and data is an invaluable resource for consumers in these
circumstances.
Gen Mobile Lifeline service plans provide meaningful options for low-income consumers
because they offer low-cost, reliable alternatives to traditional rate plans. Among the Gen
Mobile Lifeline offerings is a plan with 1,000 voice minutes, 1,000 texts, and 4.5 GB of data
available to all qualifying low-income Idaho consumers for no cost, and a plan with unlimited
voice minutes, unlimited texts and 11 GB of data available to residents of Tribal lands for no
cost. Qualified Idaho consumers will have the choice to apply their Lifeline discount to existing
Gen Mobile plans.
In addition, Gen Mobile Lifeline plans alleviate customer concerns regarding deposits,
hidden costs, varying monthly charges, and long-term contract issues. Gen Mobile prepaid plans
18
allow customers to subscribe to voice, text, and data services without the hurdle of a credit check
or the commitment of a contract.
B. Benefits of Competitive Choice
Designating the Company as an ETC also meets the FCC’s stated goals for promoting
competition and increasing customer choice. The FCC has recognized that in non-rural areas,
designation of multiple ETCs is “consistent per se with the public interest.”27 In rural and high-
cost areas, the FCC determined that “designation of competitive ETCs promotes competition and
benefits consumers . . . by increasing customer choice, innovative services, and new
technologies.”28 In the Lifeline context, the entry of additional providers increases competitive
choice for lower-income customers who may not be the focus of wireless carriers’ marketing
efforts. Launching Gen Mobile Lifeline options in Idaho will add affordable, innovative mobile
wireless choices to the marketplace, and could spur other ETCs to expand and improve their own
Lifeline service offerings. Granting ETC designation to DISH Wireless will promote
competition for the benefit of consumers and will have desirable effects upon the Idaho market
for Lifeline services by making these services more available and accessible, thereby supporting
the goals of universal service.
C. Commission Public Interest Standard
As noted above, when assessing whether designation of an ETC applicant as an ETC
would serve the public interest, the Commission considers whether the applicant will contribute
the relevant state funds. DISH Wireless currently contributes to the ITSAP and TRS programs

27 Federal-State Joint Board on Universal Service, Cellco Partnership d/b/a Bell Atlantic Mobile, Petition for Designation as an Eligible Telecommunications Carrier, Memorandum, Opinion and Order, CC Docket No. 96-45, DA 00-2895, ¶ 14 (rel. Dec. 26, 2000).
28 See Western Wireless Corporation Petition for Designation as an Eligible Telecommunications Carrier in the State of Wyoming, Memorandum Opinion and Order, CC Docket No. 96-45, DA 00-2896, ¶ 17 (rel. Dec. 26, 2000).
19
as requires by relevant state law, and will continue to do so after being designated as an ETC.
The Commission considers whether the applicant is engaged in “cream-skimming.” However,
because DISH is seeking ETC designation for the entire state, a cream-skimming analysis is not
required.29
VI. ANTI-DRUG ABUSE CERTIFICATION
In accordance with section 5301 of the Anti-Drug Abuse Act of 1988, DISH Wireless
certifies that no party to the Application is subject to denial of federal benefits, including FCC
benefits.
VII. CONCLUSION
Based on the foregoing, designation of DISH Wireless as an ETC in the State of Idaho
accords with the requirements of Section 214(e)(2) of the Act and is in the public interest.

29 See Order No. 35126, at 5.
20
WHEREFORE, DISH Wireless respectfully requests that the Commission designate
DISH Wireless as an ETC in the State of Idaho for the purpose of participating in the Lifeline
program.
Respectfully submitted,
___________________________
Thomas J. Lloyd III Elam & Burke, P.A.
22
EXHIBIT 2: PROPOSED LIFELINE PLANS

Subsidy
Amount
of data

23
EXHIBIT 3: IDAHO SERVICE AREA
83201
83202
83204
83209
83210
83211
83212
83213
83214
83215
83217
83218
83220
83221
83223
83226
83228
83229
83232
83233
83234
83236
83237
83238
83239
83241
83243
83244
83245
83246
83250
83251
83252
83254
83255
83256
83261
83262
83263
83271
83272
83274
83276
83277
83278
83281
83283
83285
83286
83287
83301
83302
83311
83312
83313
83314
83316
83318
83320
83321
83322
83323
83324
83325
83327
83328
83330
83332
83333
83334
83335
83336
83337
83338
83340
83341
83342
83344
83346
83347
83348
83349
83350
83352
83353
83354
83355
83401
83402
83404
83406
83420
83421
83422
83423
83424
83425
83427
83428
83429
83431
83433
83434
83435
83436
83438
83440
83442
83443
83444
83445
83446
83448
83449
83450
83451
83452
83454
83455
83460
83462
83464
83465
83466
83467
83468
83501
83520
83522
83523
83524
83526
83530
83531
83533
83535
83536
83537
83539
83540
83541
83542
83543
83544
83545
83547
83548
83549
83552
83553
24
83554
83555
83602
83604
83605
83607
83610
83611
83612
83615
83616
83617
83619
83622
83623
83624
83626
83627
83628
83629
83631
83632
83633
83634
83636
83638
83639
83641
83642
83643
83644
83645
83646
83647
83648
83650
83651
83654
83655
83656
83657
83660
83661
83666
83669
83670
83672
83676
83686
83687
83702
83703
83704
83705
83706
83709
83712
83713
83714
83716
83720
83724
83801
83802
83803
83804
83805
83806
83808
83809
83810
83811
83812
83813
83814
83815
83821
83822
83823
83824
83825
83827
83830
83832
83833
83834
83835
83836
83837
83839
83840
83841
83842
83843
83844
83845
83846
83847
83848
83849
83850
83851
83852
83854
83855
83856
83857
83858
83860
83861
83864
83866
83867
83868
83869
83870
83871
83872
83873
83874
83876

25
EXHIBIT 4: SAMPLE ADVERTISEMENT
Buckslips 3.5” by 9.5”

26
Banners 2’ by 5’

Webpage Copy

27
EXHIBIT 5: FINANCIAL STATEMENT (LINK TO 10-K)
Form 10-K of DISH Network Corporation, DISH Wireless’s parent company, https://ir.dish.com/sec-filings/sec-filing/10-k/0001558370-22-001816.
28
EXHIBIT 6: KEY PERSONNEL BIOS Robert Yap, VP of Gen Mobile, a DISH Wireless L.L.C. brand, has over 20 years of telecommunication experience. Mr. Yap was an executive at several telecommunications companies (wireless, CLEC, and calling cards), including at Gen Mobile, Inc. where he was a founder, and was a corporate attorney at McDermott, Will & Emory. From 2015 to 2017, he was
the President of TruConnect Communications, Inc., a nationwide wireless Lifeline Provider with
over 500,000 customers during his tenure. In 2018, Mr. Yap and his fellow executives founded Gen Mobile, Inc. (later acquired by DISH Wireless L.L.C.), to provide consumers affordable wireless service options and to help bridge the digital divide for the 30% of Americans that have limited access to the internet. He hopes to provide the same in the State of Idaho with Gen
Mobile as the head of the brand under DISH Wireless.
Mr. Yap also has served on several nonprofit boards including as chairman of the Asian Pacific Community Fund (“APCF”), a non-profit that has raised over $5,000,000 for distribution to non- profits that serve communities in Los Angeles, and as a current board member of Center for
Asian Americans United for Self-Empowerment (“CAUSE”), a non-profit dedicated to
politically empowering the Asian Pacific American community. He also held leadership positions at Project by Project and the National Asian Pacific American Bar Association, and served in AmeriCorps at Public Allies Chicago.
Mr. Yap received his B.A. in Economics from Northwestern University and his J.D., with
honors, from George Washington University School of Law. Anthony Lombardo, Director and Head of Finance for Gen Mobile, is an experienced Finance and M&A professional. Prior to joining Gen Mobile, he worked with various early stage
and venture backed start-ups as well as servicing private equity and strategic clients with buy-
side and sell-side transaction support. He has experience supporting clients with needs in the CFO suite and finance operations and started his career at PricewaterhouseCoopers where he spent 13 years in both the audit and transaction support groups. Mr. Lombardo served as CFO at Gen Mobile, Inc. and is now the head of finance for the Gen Mobile brand.

Mr. Lombardo received his Bachelor of Science in Economics from The Wharton School at the University of Pennsylvania and his Master of Business Administration from the UCLA Anderson School of Management. Mr. Lombardo is also a licensed CPA (inactive) in the state of California.
Jennifer Lin, Head of Marketing, Gen Mobile, is a marketing and market research professional. She previously worked in market research at Farmers Insurance and was part of the team that launched online health insurance broker, HealthInsurance.com. Mr. Lombardo served as CFO at Gen Mobile, Inc. and is now the head of finance for the Gen Mobile brand.

Ms. Lin received her Bachelor’s degree from the University of California, Los Angeles and her M.P.H. from Boston University.
29
Jose Andrade, Head of Operations, Gen Mobile, has over 15 years of operational management
experience at wireless telecommunications companies including from 2015-2018 as Director of
Operations at TruConnect, a wireless Lifeline Provider with over 500,000 customers and from 2018-2021 as Director of Operations at Gen Mobile, Inc. His experience includes PMO leadership, customer service management, business optimization, data analysis, and leadership development. Mr. Andrade is responsible for day-to-day operations at Gen Mobile.

Mr. Andrade received his Business degree from the California State University-Los Angeles. Sola Lee, Senior Corporate Counsel, Gen Mobile, has over 10 years of legal experience including as Counsel from 2015 to 2017 at TruConnect, a wireless Lifeline Provider with over
500,000 customers and from 2018-2021 at Gen Mobile, Inc. She was responsible for legal,
regulatory, and compliance functions at TruConnect and Gen Mobile. Ms. Lee is the lead counsel for the Gen Mobile brand. Ms. Lee graduated with a Bachelor’s degree from the University of California, Davis and with a
J.D. from the University of Oregon.
Vincent Buongiovanni, Head of Sales Operations – ACP/Lifeline, Gen Mobile, has over 10 years of experience in the wireless telecommunications industry, including managing the sales, operations, and compliance of Assurance Wireless’ Affordable Connectivity Program and
Lifeline Program nationwide, specifically managing the field agents used by the service provider.
He also served as interim Director of Wireless at Assurance during the acquisition of Sprint by T-Mobile and is part-time police officer in Hi-Nella, New Jersey. Mr. Buongiovanni is in charge of the sales operations for ACP and Lifeline program for the Gen Mobile brand at DISH Wireless.