20131015Application.pdf

Lance J.M. Steinhart, P.C.
Attomeys At Law
1725 Windward Concourse
Suite 150
Alpharett4 Georgia 3 0005
Also Admitted inNew York
Email : [e-mail]
October 10,2013
VIA OYERMGHT DELTVERY
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472West Washington
Boise,Idaho 83702
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Re: Global Connection Inc. of America dba STAND UP WIRELESS Application for' Limited Designation as an Eligible Telecommunications Carrier
Dear Ms. Jewell:
Enclosed please frnd for filing an original and seven (7) copies of Global Connection [nc. of
America dba STAND UP MRELESS's Application for Limited Designation as an Eligible
Telecommunications Carrier in the State of Idaho.
I have also enclosed an extra copy of this letter to be date stamped and retumed to me in the
enclosed, self-addressed, postage prepaid envelope.
If you have any questions or if I may provide you with additional information, please do not
hesitate to contact me. Thank you.
submitted,
Lance
Global Connection lnc. of America dba
STAND UP MRELESS
Enclosurescc: Bill Moran
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
In the Matter of the Application of
GLOBAL COI\NECTION INC. OF AMERICA
DBA STAND UP WIRELESS FOR LIMITED
DESIGNATION AS AN ELIGIBLE
TELECOMMUNICATIONS CARRIER
cASENo. & t0-T -13-ol
APPLICATION OF GLOBAL COI\NECTION INC. OF AMERICA DBA
STAIID T]P WIRELESS FOR LIMITED DESIGNATION AS AN
ELIGIBLE TELECOMMUNICATIONS CARRIER
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Lance J.M. Steinhart
Lance J.M. Steinhart, P.C.
Attorneys at Law
1725 Windward Concourse, Suite 150
Alpharetta, Georgia 30005
[phone] (Phone)
[phone] (Fax)
E-Mail: [e-mail]
Attorneys for Global Connection Inc. of
America dba STAND UP WIRELESS
October 10,2013
ru.
IV.
A.
B.
C.
D.
A.
B.
C.
Company Overview .......2
Proposed Lifeline Offering ..............4
Plan Enrollment .............8
Prevention of Waste, Fraud and Abuse ..............9
THE COMMISSION HAS ruzuSDICTION TO DESIGNATE WIRELESSETCS....... ...............10
A. The ETC Designation Request Is Consistent with Recent CommissionPrecedent.. ....................1 I
STAND UP WIRELESS SATISFIES THE REQUIREMENTS FOR
DESIGNATION AS AN ETC.......... .........12
Stand Up Wireless Will Provide Service Consistent With the FCC's
Grant of Forbearance from Section 214's Facilities Requirements.......................12
Stand Up Wireless Is a Common Carrier. .........13
Stand Up Wireless Will Provide All Required Supported Services.......................13
l. Voice Grade Access to the Public Switched Telephone
Network.... ........13
2. Minutes of Use for Local Service ........14
3. Access to Emergency Services ........-.-.14
4. Toll Limitation for Qualified Low-Income Customers. ............................14
5. Other Services. ...................15
Stand Up Wireless Will Advertise the Availability of Supported
Services ......15
Stand Up Wireless Requests Designation Throughout its Service Area
in Idaho ......16
Service Commitment Throughout the Proposed Designated Service
Area.......... ....................I7
Five-Year Network Improvement Plan...... ......17
Ability to Remain Functional in Emergency Situations.............. ........17
Commitment to Consumer Protection and Service Quality...... ...........17
Local Usage Requirement.............. ..................18
Equal Access Requirement.............. ................18
Financial and Technical Capability............. ......................19
D.
E.
F.
G.
H.
I.
J.
K.
L.
M. Stand Up Wireless Will Comply with Certification and Verification
Requirements ............ .....................19
N. Stand Up Wireless Will Comply With All Regulations Imposed By TheCommission............... ....................20
V. DESIGNATION OF STAND UP WIRELESS AS AN ETC WOULD
PROMOTE THE PUBLIC INTEREST............. ..........20
A. Advantages of Stand Up Wireless' Service Offering.... ......21
B. The Benefits of Competitive Choice.............. ....................23
C. Impact on the Universal Service Fund......... ......................23
VI. ANTI-DRUG ABUSE CERTIFICATION ..................24
vlr. CoNCLUSION.......... ..............25
TABLE OF DGIIBITS
Certification of Dave Skogen, Chief Executive Officer of Global Connection Inc.
of America dba STAND UP WIRELESS ............ .........................1
Proposed Lifeline Offering ......................2
StandUp Wireless' FCC-Approved Compliance Plan .................3
2011 Lifeline Participation Rates by State..... ............4
Wire Centers............... ...........5
Key Management Bios.......... ...................6
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
In the Matter of the Application of
GLOBAL COI\NECTION INC. OF AMERICA
DBA STAND UP WIRELESS FOR LIMITED
DESIGNATION AS AN ELIGIBLE
TELECOMMTII\ICATIONS CARRIER
CASE NO.
APPLICATION OT GLOBAL CONII"ECTION INC. OF AMERICA DBA
STAND UP WIRELESS FOR LIMITED DESIGNATION AS AN
ELIGIBLE TELECOMMT]NICATIONS CARRIER
I. INTRODUCTION
Global Connection Inc. of America dba STAND UP MRELESS ("Stand Up Wireless" or
the "Compmy"), by its undersigned counsel, and pursuant to Section 2la@)Q) of the
Communications Act of 1934, as amended (the "Act")l, Sections 54.101 through 54.207 of the
Rules of the Federal Communications Commission ("FCC"),2 and the Idaho Public Utilities
Commission's ("Commission") rules and regulations,3 hereby submits this Application for
Designation as an Eligible Telecommunications Carrier ("ETC") in the State of Idaho. Stand Up
Wireless seeks ETC designation solely to provide Lifeline service to quali$ing Idaho
consumers; it will not seek access to funds from the federal Universal Service Fund ("USF") for
the purpose of participating in the Link-Up program or providing service to high cost areas.a As
' 4z u.s.c. g 2ra(eX2)
' 47 c.F.R. gg 54.lol-54.207.
3 See In the Matter of the Application of WWC Holding Co., Inc. d/b/a Cetlular-one Seeking Designation as an
Eligible Telecommunications Carrier that may Receive Federal Universol Service Support, Order No. 29841
(August 4, 2005) ("Commission Order No. 29841").
o Given that Stand Up Wireless only seeks support from the low-income program and does not seek any high-cost
support, ETC certification requirements for the high-cost program are not applicable to the Company.
demonstrated herein, and as certified in Exhibit I to this Application, Stand Up Wireless meets
all the statutory and regulatory requirements for designation as an ETC in the State of Idaho,
including the new requirements outlined in the FCC's Lifeline and Link Up Reform Order.s
Rapid grant of Stand Up Wireless' request, moreover, would advance the public interest because
it would enable the Company to commence much needed Lifeline service to low-income Idaho
residents as soon as possible. Accordingly, the Company respectfully requests that the
Commission expeditiously approve this Application for ETC designation.
All correspondence, communications, pleadings, notices, orders and decisions relating to
this Application should be addressed to:
Lance J.M. Steinhart
Lance J.M. Steinhart, P.C.
Attorney for Global Connection Inc. of America dba STAND UP WIRELESS
1725 Windward Concourse, Suite 150
Alpharetta, Georgia 30005
[phone] (Phone)
[phone] (Fax)
E-Mail: [e-mail]
II. BACKGROUND
A. Company Overview
Global Connection tnc. of America ("Global Connection") is a Georgia Corporation.6 Its
principal office is located at 5555 Oakbrook Parkway, Suite 620, Norcross, Georgia 30093.
Global Connection provides local exchange telecommunications services throughout the United
States and is designated as an ETC on a wireline basis in Alabama, Arkansas, Georgia,
s In the Matter of Lifeline and Link tJp Reform and Modernization, Lifeline and Link Up, Federal-Stqte Joint Board
on Universal Service, Advancing Broadband Availability Through Digital Literaqt Training, WC Docket No. l1-42,
WC Docket No. 03-109, CC Docket No. 96-45, WC Docket No. 12-23, Report and Order and Further Notice of
Proposed Rulemaking, FCC l2-11 (rel. Feb. 6,2012) ("Lifeline and Link Up Reform Ordey'').
u Global Connection was incorporated in the State of Georgia on June l, 1998. Global Connection Inc. of America's
corporate and trade names, identifiers, and its holding company, operating companies and affiliates are: Stand Up
Wireless (dba), and Global Connection Holdings Corporation (holding company).
Louisiana, Michigan, and North Carolina. Global Connection provides commercial mobile radio
service ("CMRS") throughout the United States under its dlbla, Stand Up Wireless. Stand Up
Wireless provides prepaid wireless telecommunications services to consumers by using the Sprint
PCS and Verizon Wireless ("Sprint/Veizon") networks on a wholesale basis. Stand Up Wireless
obtains from Sprint/Veizon, via an agreement with Boomerang Wireless, LLC d/b/a Ready Mobile
("Ready Mobile"), the network infrastructure and wireless transmission facilities to allow the
Company to operate as a Mobile Virtual Network Operator ("M\INO"), similar to TracFone
Wireless, Inc. ("TracFone") and Virgin Mobile USA, L.P. ("Virgin Mobile"), who have been
granted ETC status by the Commission.T Stand Up Wireless has been designated as an ETC in
Arkansas, Aizon4 Colorado, Georgia, Iow4 Kansas, Kentucky, Louisian4 Maryland,
Massachusetts, Michigan, Missouri, Nebrask4 Ohio, Pennsylvani4 Puerto Rico, South Carolina"
Texas, Wisconsin and West Virginia and currently has applications for ETC designation pending
with California, Minnesota, Mississippi, New Jersey, Rhode Island, Utah and the FCC; no such
petitions have been denied.
Stand Up Wireless' prepaid wireless services are affordable, easy to use, and attractive to
low-income consumers, providing them with access to emergency services and a reliable means of
communication that can be used both at home and while traveling to remain in touch with friends
and family, as well as for contacting prospective employers. Stand Up Wireless offers consumers a
variety of simple and affordable prepaid calling plans, easy-to-use handsets, and high-quality
customer service. Given its pricing and marketing strategy and the demographics of other, similar
MVNOs' customers, Stand Up Wireless anticipates that many of its customers will be from low-
1 See In the Matter of the Amended Application of TracFone Wireless, Inc. for Designation as an Eligible
Telecommunications Carrier in the State of ldaho for the Limited Purposes of Offering Lifeline Service to Qualified
Households. Case No. TFW-T-09-01. Order No. 32586 (June 29, 2012) ("TracFone ETC Order"); In the Matter of
the Petition of Virgin Mobile USA for Limited Designation as an Eligible Telecommunications Carrier. Case No.
VMU-T-I1-01. Final Order No. 32645 (Sept. 19,2012) ("Virgin Mobile ETC Order").
income backgrounds and will not previously have enjoyed access to wireless service because of
economic constraints, poor credit history, or sporadic employment. Stand Up Wireless does not
conduct credit checks or require customers to enter into long-term service contracts as a
prerequisite to obtaining wireless service.
By providing aflordable wireless plans and quality customer service to consumers who are
otherwise unable to afford them, or were previously ignored by traditional ca:riers, Stand Up
Wireless will expand the availability of wireless services to many more consumers, which is the
principal reason that Congress created the universal service program.
B. Proposed Lifeline Offering
Stand Up Wireless has the ability to provide all services and functionalities supported by
the universal service program, as detailed in Section 5a.101(a) of the FCC's Rules (47 C.F.R. $
5a.101(a)) throughout Idaho. Stand Up Wireless intends to be a leader in the prepaid
marketplace by offering consumers exceptional value and competitive amounts of voice usage at
all price points. The Company's Lifeline service offering will provide customers with the same
features and functionalities enjoyed by all other Stand Up Wireless prepaid customers, with one
notable exception: prepaid Lifeline services will not require payment of an out-of-pocket fee by
subscribers, but instead, Stand Up Wireless will receive support from the Lifeline program as
compensation for providing those services.
Stand Up Wireless' free Lifeline plan (StandUp 100) includes separate pools of both
voice minutes and text minutes. Competing Lifeline wireless providers typically deplete voice
minutes when text is used, reducing the available voice minutes available to customers and
thereby reducing the provider's per customer cost because text messaging costs are typically
much lower than voice minute costs. According to Pew Research Center, in May 2010, seventy-
two percent (72%) of adults reported sending or receiving a text message.s Since text messages
draw from their own pool, Stand Up does not deplete the pool of voice minutes available for use
of text messages and vice versa. Separate pools for both voice minutes and text messages are in
the consumers' best interest as it preserves critical voice minutes for consumers who utilize text
messaging.
Under the Company's Wireless Lifeline Plan, Stand Up Wireless customers will have
several options to choose from. In addition to Standup 100, customers will also be permitted to
select one of Stand Up Wireless' alternative plans, which offer customers the opportunity to
receive more text units and voice units. Such alternative plans will be offered to Lifeline
customers at a subsidized rate. Where Stand Up Wireless customers select an alternative plan,
Stand Up Wireless will apply a discount of $12.75 per month, which includes the federal Lifeline
subsidy (currently 59.25), to the retail rate of the altemative plan. Competing Lifeline wireless
providers typically offer only a base package with required retail top up to add more voice
minutes and/or texts. The initial plans offered by Stand Up Wireless are as follows:
StandUp 100. Stand Up Wireless will provide qualified Lifeline customers with a
monthly allotment of 100 free anytime local and long distance minutes and 100 free SMS text
messages, and all applicable taxes and fees will be included. Thus, Stand Up Wireless will use
all Lifeline support to allow the Company to provide the service with no monthly recurring
charge, ensuring that the consumer receives 100% of all universal service support funding for
which the Company will seek reimbursement. Unused minutes and unused SMS text messages
will rollover from month to month.
8 Amanda Lenhart, Adutts, Cell Phones and Texting,Pew Research Center Publications, September 2,2010.
StandUp 250. Stand Up Wireless will provide qualified Lifeline customers with a
monthly allotment of 250 free anytime local and long distance minutes, and all applicable taxes
and fees will be included. Unused minutes do not rollover from month to month.
StandUp 500. Stand Up Wireless expects to provide qualified Lifeline customers
with a monthly allotment of 500 anytime local and long distance minutes and 500 SMS text
messages at a cost of $14.95 per month, excluding applicable taxes and fees. Unused minutes
and unused SMS text messages do not rollover from month to month in this plan.
StandUp 1000. Stand Up Wireless expects to provide qualified Lifeline
customers with a monthly allotment of 1000 anytime local and long distance minutes and 1000
SMS text messages at a cost of $29.95 per month, excluding applicable taxes and fees. Unused
minutes and unused SMS text messages do not rollover from month to month in this plan.
StandUp Unlimited. Stand Up Wireless expects to provide qualified Lifeline
customers with unlimited voice minutes and 1000 SMS text messages for $34.95 per month,
excluding applicable taxes and fees. Unused minutes and unused SMS text messages do not
rollover from month to month in this plan.
New Stand Up Wireless customers must choose a plan upon enrollment. If the customer
selects a non-FREE plan, payment must be made directly to Stand Up Wireless or one of its
designated payment agent locations prior to activation of service. Existing Stand Up Wireless
customers who wish to switch plans may do so at www.StandUpWireless.com or by calling a toll
free number. Stand Up Wireless customers who select one of the three (3) non-FREE plans must
make payment for their upcoming service period five (5) days prior service period end date.
Customers who fail to make payment prior to the deadline will be automatically changed to the
6
free StandUp 100 plan with 100 free airtime minutes and 100 free SMS text messages for the
subsequent service period.
Calls made to Stand Up Wireless customer service made by customers via their Stand Up
Wireless handset will not deplete the customer's available airtime. Stand Up customers can
contact Stand Up Wireless customer service by dialing a short code (e.g. *611) from their Stand
Up Wireless phone to address billing, service and general account issues with all voice minutes
used in association with such calls being credited to the customer's account. Customers whose
balance of voice minutes has been exhausted will still be able to make outbound calls to Stand
Up Wireless customer service as long as their service is active. Calls to 911 emergency services
are always free, regardless of service activation or availability of minutes.
In the event that all airtime subscribed to has been used, Lifeline customers will have the
ability to purchase additional time. At this time additional credits may be purchased at the rate
of $5.00 for40 credits; $10.00 for 100 credit; $20.00 for250 credits, $30.00 for 500 credits; and
$50.00 for 1000 credits by calling our toll free number or at www.StandUpWireless.com.
Credits may also be purchased at any authorized Stand Up Wireless payment center. Each credit
provides one (1) minute of airtime or one (l) SMS text message.
All Lifeline plans will also include a free handset and the following Custom Calling
features at no charge:
(1) Caller ID;
(2) Call Waiting;
(3) 3-Way Calling(4) Voicemail.
Upon certification of the customer for Lifeline, wireless handsets will be delivered, at no
charge, and the requisite number of minutes will be added upon service activation. Stand Up
Wireless will not seek reimbursement from the USF for new subscribers until they have
personally activated the service, either by initiation and/or actual use of the service.
Attached hereto as Exhibit 2 is a summary table of the Company's proposed Lifeline
offering.e As Exhibit 2 demonstrates, the Company's Lifeline offerings will not only allow
feature-rich mobile connectivity for qualiffing subscribers at no cost to the subscriber, but also
will bring a variety of rate plans into the reach of eligible customers that are comparable in
minutes and features to those available to post-paid wireless subscribers - but at low Lifeline
rates and without a the burden of credit checks or service contracts. Stand Up Wireless' prepaid
offering will be an attractive altemative for consumers who need the mobility, security, and
convenience of a wireless phone, but who are concerned about usage charges or long-term
contracts.
C. Plan Enrollment
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 detailed description of the program
and state-specific eligibility criteria. Customers may then request that an enrollment form be
mailed to them, or they can download a form from the internet or retrieve a form in person at a
Company event. The certification forms, a sample of which is attached as Exhibit A of Exhibit
3, the Company's FCC Compliance Plan, will explain in clear, easily understandable language
that:
(i) Lifeline is a federal benefit;
(ii) Lifeline service is available for only one line per household;
(iii) a household is defined, for purposes of the Lifeline program, as any individual or
group of individuals who live together at the same address and share income and
'The Company's Lifeline terms and conditions can be found at www.standUpWireless.com.
8
expenses;
(iv) households are not permitted to receive benefits from multiple providers;
(v) that violation of the one-per-household requirement would constitute a violation of
the FCC's rules and would result in the consumer's de-enrollment from the program, and
potentially, prosecution by the United States government; and
(vi) a Lifeline subscriber may not transfer his or her service to any other individual,
including another eligible low-income consumer.
Stand Up Wireless' certification form will also require all consumers, at sign up and
annually thereafter, to provide the information and certifications, under penalty of perjury,
required by revised CFR $ 54.410(d).10 S". Exhibit 3 for more detailed enrollment information.
Stand Up Wireless will annually re-certifr the continued eligibility of all of its subscribers.
D. Prevention of Waste, Fraud and Abuse
Stand Up Wireless recognizes the importance of safeguarding the USF. Therefore, the
Company has implemented the following 60-day non-usage policy in an effort to avoid waste,
fraud, and abuse of the program. After 60 days of nonuse, the Company will provide notice to
the subscriber that failure to use the Lifeline service within a 30-day notice period will result in
de-enrollment.ll Subscribers can "use" the service by: (l) completing an outbound call; (2)
purchasing minutes from the Company to add to the subscriber's plan; (3) answering an
incoming call from a party other than the Company; or (4) responding to a direct contact from
the Company and confirming that the subscriber wants to continue receiving the service.l' If the
subscriber does not respond to the notice, the subscriber will be de-enrolled and the Company will
not request further Lifeline reimbursement for the subscriber.
To further protect the integrity of the USF, Stand Up Wireless has contracted with CGM,
LLC of Roswell, Georgia, a lifeline service bureau, to edit all subsidy request data. CGM will
to See Lifeline and Link Up Reform Order page 227 -29.
tt See Lifeline and Link Up Reform Order atl257.
t2 See Lifeline and Link Up Reform Order atl261.
process and validate the Company's subsidy data to prevent: (1) Duplicate Same-Month Lifeline
Subsidies (Double Dip): any name/address that is already receiving a lifeline subsidy from the
Company will be automatically prevented from receiving a second lifeline subsidy in that same
month; and (2) Inactive lines receiving subsidy: CGM's systems compare all subsidy requests to
underlying network status to ensure that subsidies are requested only for active lines. Through
the processes described above, Stand Up Wireless ensures that it does not over-request from
support funds.
III. THE COMMISSION HAS JURISDICTION TO DESIGNATE WIRELESS ETCS
Section zla@)Q) of the Act (47 U.S.C. $ 2la(eX2)) provides state public utility
commissions with the "primary responsibility" for the designation of ETCs. Although Section
332(c)(3)(A) of the Act prohibits states from regulating the entry of or the rates charged by any
provider of commercial mobile service or any private mobile service, this prohibition does not
allow states to deny wireless carriers ETC status.l3 Therefore, the Commission has the authority
to designate Stand Up Wireless as an ETC. Pursuant to this authority, the Commission has
designated numerous carriers as ETCs in the State of Idaho, including many wireless carriers.la
Under the Act, a state public utility commission with jurisdictional authority over ETC
designations must designate a common carrier as an ETC if the carrier satisfies the requirements
of Section 2la(e)(l). Stand Up Wireless recognizes that Section 2la(eXl)(A) of the Act states
that ETCs shall offer services, at least in part, over their own facilities and that Section 5a.201(i)
of the FCC's Rules (47 C.F.R. $ 54.201(i)) prohibits state commissions from designating as an
ETC a telecommunications carrier that offers services exclusively through the resale of another
t3 See Federal-State Joint Bosrd on (Jniversal Service, First Report ond Order, 12 FCC Rcd 8776, 8858-59, fl 145
(1997) ("USF Order").
'o 5"" e.g., TracFone ETC Order and Virgin Mobile ETC Order.
l0
carrier's services. However, the FCC recently granted forbearance from enforcement of this
facilities requirement to carriers seeking Lifeline-only ETC designation.ls Section 10(e) of the
Act (47 U.S.C. $ 160(e)) provides: "[a] State commission may not continue to apply or enforce
any provision of this chapter that the [Federal Communications] Commission has determined to
forbear from applying under subsection (a) of this section." As such, the Commission is required
by Section 10(e) to act in accordance with the FCC's grant of forbearance, and therefore, may
not apply the facilities-based requirement to Stand Up Wireless. Therefore, the Commission has
the authority to act under Section 21a@)Q) of the Act and to grant Stand Up Wireless' request
for designation as an ETC throughout the State of Idaho.
A. The ETC Designation Request Is Consistent with Rebent Commission
Precedent
Stand Up Wireless' request for ETC designation to participate in the Lifeline program is
consistent with the Commission's recent decision designating TracFone and Virgin Mobile as
ETCs.l6 In its decisions, the Commission determined that designation of a prepaid wireless
provider as an ETC would serve the public interest. Stand Up Wireless requests that the
Commission expeditiously process its ETC Application so that it can quickly corrmence
providing qualiffing low-income Idaho customers with affordable USF-supported wireless
services during these challenging economic times for all state residents. Designation of Stand Up
Wireless as an ETC would further competition for wireless Lifeline services and would offer
eligible consumers an additional choice of providers for accessing telecommunications services,
representing a significant step towards ensuring that all low-income consumers share in the many
benefits associated with access to wireless services.
ls See Lifeline and Link Up Reform Order at\368.
16 See TracFone ETC Order; see also Virgin Mobile ETC Order
l1
ry.STAI\D UP WIRELESS
DESIGNATION AS AN ETC
SATISFIES THE REQUIREMENTS FOR
Section 25a@) of the Act provides that o'only an eligible telecommunications carrier
designated under section 2I4(e) shall be eligible to receive specific federal universal service
support." Section zla@)Q) of the Act authorizes state commissions, such as the Commission, to
designate ETC status for federal universal service purposes and authorizes the Commission to
designate wireless ETCs.rT Section 2la(eXl) of the Act and Section 54.201(d) of the FCC's
rules provide that applicants for ETC designation must be common carriers that will offer all of
the services supported by universal service, either using their own facilities or a combination of
their own facilities and the resale of another carrier's services, except where the FCC has
forborne from the "o\ m facilities" requirement. Applicants also must commit to advertise the
availability and rates of such services.l8 As detailed below, Stand Up Wireless satisfies each of
the above-listed requirements.
A. Stand Up Wireless Will Provide Service Consistent with the FCC's Grant of
Forbearance from Section 214's Facilities Requirements
Although Section 214 requires ETCs to provide services using their facilities, at least in
part, the FCC has forborne from that requirement with respect to carriers such as Stand Up
Wireless. In the Lifeline and Link Up Reform Order, the FCC granted forbearance from the "own-
facilities" requirement contained in Section 21a(e)(1)(A) for carriers that are, or seek to become,
Lifeline-only ETCs, subject to the following conditions:re
(1) the carrier must comply with certain 9ll requirements [(a) providing is Lifeline
subscribers with 911 and E9l1 access, regardless of activation status and availability of
minutes; (b) providing its Lifeline subscribers with E9ll-compliant handsets and replacing,
at no additional charge to the subscriber, noncompliant handsets of Lifeline-eligible
t7 See USF Order, at 8858-59, fl 145.
t8 See47 U.S.C. $ 2la(eX1) and47 C.F.R. $ s4.2}l(d)(2).
te See Lifeline and Link Up Reform Order attTfl 368, 373 and,379.
I2
subscribers who obtain Lifeline-supported services; and (c) complying with conditions (a)
and (b) starting on the effective date of this Order]; and
(2) the carrier must file, and the Bureau must approve, a compliance plan providing specific
information regarding the carrier's seryice offerings and outlining the measures the
carrier will take to implement the obligations contained in this Order as well as further
safeguards against waste, fraud and abuse the Bureau may deem necessary."
Stand Up Wireless will avail itself of the FCC's grant of blanket forbearance. In accordance with
the Lifeline and Link Up Reform Order, Stand Up Wireless filed its Compliance Plan which the
FCC approved on May 25,2012. A copy of its approved Compliance Plan is attached hereto as
Exhibit 3. Stand Up Wireless commits to providing Lifeline service in Idaho in accordance with
the Compliance Plan.
B. Stand Up Wireless Is a Common Carrier
CMRS providers like Stand Up Wireless are treated as common carriers.2o
C. Stand Up Wireless Will Provide AII Required Supported Services
Through its wholesale arrangements with Sprint/Verizon through Ready Mobile, Stand
Up Wireless is able to provide all of the services and functionalities required by Section
54.101(a) and Section 54.202(a) of the FCC's Rules (47 C.F.R. $ 5a.101(a) ard 47 C.F.R.
$ 5a.202(a)), including the following:
1. Voice Grade Access to the Public Switched Telephone Network
Stand Up Wireless provides voice grade access to the public switched telephone network
("PSTN") through the purchase of wholesale CMRS services from Sprint/Verizon.
20 Implementation of Sections 3(n) and 332 of the Communications Act, Regulatory Treatment of Mobile Services,
GN Docket No. 93-252, Second Report and Order, 9 FCC Rcd 1411,1425 n37,1454-55 fl 102 (1994) (wireless
resellers are included in the statutory "mobile seryices" category, and providers of cellular service are common
carriers and CMRS providers); 47 U.S.C. $ 332(c)(l)(A) ("mobile services" providers are common carriers); see
also PCIA Petitionfor Forbearancefor Broadband PCS, WT Docket No. 98-100, Memorandum Opinion and Order
and Notice of Proposed Rulemaking, 13 FCC Rcd 16857, 169ll fl lll (1998) ("We concluded [in the Second
Report and Orderf that CMRS also includes the following common carrier services: cellular service, ... all mobile
telephone services and resellers ofsuch services.")
l3
2. Minutes of Use for Local Service
As part of the voice grade access to the PSTN, an ETC must provide minutes of use for
local service at no additional charge to end-users. The FCC has not specified a minimum
amount of local usage that an ETC must offer.2l Stand Up Wireless offers a variety of rate plans
that provide its customers with minutes of use for local service at no additional charge.
3. Access to Emergency Services
Stand Up Wireless provides 911 and 8911 access for all of its customers to the extent the
local government in its service area has implemented 911 or E911 systems. Stand Up Wireless
also complies with the FCC's regulations governing the deployment and availability of E911
compatible handsets.
4. Toll Limitation for Qualified Low-Income Customers
In its Lifeline and Link Up Reform Order, the FCC stated that toll limitation would no
longer be deemed a supported service.22 "ETCs are not required to offer toll limitation service to
low-income consumers if the Lifeline offering provides a set amount of minutes that do not
distinguish between toll and non-toll calls."23 Nonetheless, Stand Up Wireless' offerings
inherently allow Lifeline subscribers to control their usage, as its wireless service is offered on a
prepaid, or pay-as-you-go, basis. Stand Up Wireless' service, moreover, is not offered on a
distance-sensitive basis and local and domestic long distance minutes are treated the same. Stand
Up Wireless will not seek reimbursement for toll limitation service.
" Se" ".g., In the Matter of Federal-State Joinl Board on (Jniversal Semice, Recommended Decision l5 FCC Rcd
7331 (2002).
22 See Lifeline and Link up Reform Order atl367.
23 See Lifeline and Link L)p Reform Order all49.
t4
5.Other Services
While no longer required by 47 C.F.R. $ 54.101(a), Stand Up Wireless provides dual tone
multi-frequency ("DTMF") signaling to expedite the transmission of call set up and call detail
information throughout the network, single party service for the duration of each telephone call
and not multi-party (or 'party-line") services, access to operator services, the ability to make
interexchange, or long distance, telephone calls, and access to directory assistance services by
dialing u411" from the provided wireless handsets.
D. Stand Up Wireless Will Advertise the Availability of Supported Services
Stand Up Wireless will advertise the availability and rates for the services described
above using media of general distribution as required by 47 C.F.R. $ 54.201(d)(2) of the FCC's
regulations. Stand Up Wireless' advertising will comply with the requirements set forth in the
Lifeline and Link Up Reform Order, as outlined in the Company's Compliance Plan2a The
Company will advertise its services in a manner reasonably designed to reach those likely to
qualiff for Lifeline service, using mediums for outreach such as mass media, outreach events,
and community and charitable involvement. The Company will engage in advertising campaigns
specifically targeted to reach those likely to qualifu fo. Lifeline service, promoting the
availability of cost-effective wireless services to this neglected consumer segment. Stand Up
Wireless may also promote the availability of its Lifeline offering by distributing brochures at
various state and local social service agencies, and may partner with nonprofit assistance
organizations in order to inform customers of the availability of its Lifeline service. In addition,
Stand Up Wireless intends to utilize its network of retail partners to help promote the availability
of its Lifeline plans, especially those retail outlets that are frequented by low income consumers;
2a See Exhibit 3, section I.F. See also Lifeline and Link (tp Reform Order at Section VII.F.
l5
examples include all Western Union and MoneyGram locations, independent operators including
insurance providers, check cashing locations and select discount retailers. Stand Up Wireless
will provide retail vendors with signage to be displayed where Company products are sold, and
with printed materials describing the Company's Lifeline prog.am.2s
Statistics suggest there are many eligible customers who are not yet aware of the
programs. According to the best data available to the Company, as of December 31,2011, only
between 10-20% of consumers eligible for Lifeline Services in the State of Idaho were being
provided such services.26 Stand Up Wireless believes that its advertising and outreach efforts
detailed above will inform consumers of the availability of Lifeline service in a manner that will
result in higher participation by qualified consumers than has been the case in the past.
E. Stand Up Wireless Requests Designation Throughout lts Service Area in
Idaho
Stand Up Wireless is not a rural telephone company as defined in Section 153(37) of the
Act (47 U.S.C. $ 153(37)). Accordingly, the Company is required to describe the geographic
area(s) within which it requests designation as an ETC. Stand Up Wireless requests designation
as an ETC that is statewide in scope, subject to the existence of its underlying carrier's facilities
and corresponding coverage.zT Stand Up Wireless understands that its service area may overlap
with rural carriers in Idaho, but maintains that the public interest factors described below justify
its designation in these carriers' service areas, especially because it seeks ETC designation solely
to utilize USF funding to provide Lifeline service to qualified low-income consumers. It does
" See Exhibit B of attached Exhibit 3, the Company's Compliance Plan, for a sample advertisement.
26 See attached Exhibit 4,2}ll Lifeline Participation Rates by State, which was obtained from the Universal Service
Administrative Company ("USAC"), an independent not-for-profit corporation designated as the administrator of
the federal Universal Service Fund by the FCC. USAC administers Universal Service Fund (USF) programs for
high cost companies serving rural areas, low-income consumers, rural health care providers, and schools and
libraries.
" A list of wire centers in which the Company requests ETC designation is attached hereto as Exhibit 5.
16
not seek and will not accept Link-Up or high cost support.
F. Service Commitment Throughout the Proposed Designated Service Area
Stand Up Wireless provides service in Idaho by reselling service which it obtains from its
underlying facilities-based provider. The provider's network is operational and largely built out.
Thus, Stand Up Wireless will be able to commence offering its Lifeline service to all locations
served by its underlying ca:rier very soon after receiving approval from the Commission. Stand
Up Wireless commits to comply with the service requirements applicable to the support that it
receives.28
G. Five-Year Network Improvement Plan
As set forth in the Lifetine and Link Up Reform Order, 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.2e
H. Ability to Remain Functional in Emergency Situations
In accordance with 47 CFR $5a.202(a)(2), Stand Up Wireless has the ability to remain
functional in emergency situations. Through its agreement with its underlying carriers, Stand Up
Wireless provides to its customers the same ability to remain functional in emergency situations
as currently provided by the ILECs to their own customers, including access to a reasonable
amount of back-up power to ensure functionality without an external power source, the ability to
reroute traffic around damaged facilities, and the capability of managing traffic spikes resulting
from emergency situations.
I. Commitment to Consumer Protection and Service Quality
Under FCC guidelines, an ETC applicant must demonstrate that it will satisfu applicable
28 See Lifeline and Link Up Reform Order atpage 208, revised $ 54.202(a)(l)(i).
2e See Lifeline and Link Up Reform Order atl386.
t7
consumer protection and service quality standards.3o The Company commits to satisfuing all
such applicable state and federal requirements related to consumer protection and service quality
standards. Specifically, Stand Up Wireless commits to comply with the Cellular
Telecommunications and Internet Association's (CTIA) Consumer Code for Wireless Service.
J. Local Usage Requirement
An applicant for ETC designation is no longer required to demonstrate that it offers a
local usage plan that is "comparable" to the plan offered by the ILEC in the relevant service
territory.3l Nevertheless, not only will the Company's offering be comparable to the underlying
ILEC plans, but it also will exceed them in several respects. Stand Up Wireless will offer
customers a certain amount of service free of charge. In contrast to the ILEC plans, which
contain relatively small local calling areas, Stand Up Wireless customers can use these free
minutes to place calls statewide (and even nationwide) because Stand Up Wireless does not
constrict customers' use by imposing a local calling area requirement. Stand Up Wireless will
also provide Lifeline customers with E911 capabilities and access to voice mail, caller I.D., 3-
way calling and call waiting services at no cost. The very nature of the wireless phone, i.e.
mobility, has a tremendous benefit to many consumers, a benefit to which a monetary value
cannot be easily assigned.
K. Equal Access Requirement
FCC Rules no longer require an applicant for ETC status to provide a certification that it
acknowledges that the FCC may require it to provide equal access to long distance carriers in the
event that no other ETC is providing equal access within the service ur"u.3'
to 5""47 C.F.R. $ 5a.202(a)(3).
3t See Lifeline and Link Up Reform Order atpage 208, revised $ 5a.202(a).
32 See id.
18
L. Stand Up Wireless is Financially and Technically Capable
Stand Up Wireless is financially and technically capable of providing Lifeline-supported
services.33 Global Connection has been offering non-Lifeline and Lifeline wireline service since
1998 and began providing non-Lifeline and Lifeline-supported wireless service in April 2011.
The Company generates substantial revenues from non-Lifeline services and has access to capital
from its investors. The majority owner of Global Connection is Milestone Partners, a
Pennsylvania private equity firm. Consequently, Global Connection has not relied, and will not be
relying exclusively on Lifeline reimbursement for the Company's operating revenues. The
Company has not been subject to enforcement sanctions or ETC revocation proceedings in any
state. Furthermore, the senior management of Stand Up Wireless has great depth in the
telecommunications industry and offers extensive telecommunications business technical and
managerial expertise to the Company.3o Stand Up Wireless will be providing resold wireless
service, and therefore will also rely upon the managerial and technical expertise of its underlying
carrier.
Stand Up Wireless Will Comply with Certification and Verification
Requirements
Section 54.410 of the FCC's Rules requires ETCs to certiff and veriff a Lifeline
customer's initial and continued eligibility. Stand Up Wireless will certifu and verify consumer
eligibility in accordance with the FCC's requirements and in accordance with its Compliance
Plan, which outlines how the Company will comply with the requirements set forth in the
Lifetine and Link Up Reform Order, and with Commission Order No. 29841.3s
33 See Lifeline qnd Link Up Reform Order atl387.
3a See Exhibit 6 for key management bios.
3s See Commission Order No. 29841 at Appendix, Section D.
M.
19
N. Stand Up Wireless Will Comply With All Regulations Imposed By The
Commission
By this Application, Stand Up Wireless hereby asserts its willingness and ability 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, to the extent such provisions
apply to a prepaid wireless provider. Upon Commission request, the Company is prepared to
answer questions or present additional testimony or other evidence about its services within the
state. Stand Up Wireless commits that 100% of federal universal service funds will flow through
directly to Lifeline customers. The Company commits to comply with the reporting
requirements adopted by the Commission.36
As the Company is not seeking high-cost support for its wireless service, it hereby
requests a waiver of the following Commission Rules: Commission Order No. 29841 Section B.1
(two-year network improvement and maintenance plan based on high-cost support) and
Commission Order No. 29841 Section C.1 (annual report of certain information based on high-
cost support). Because the Company is not seeking high-cost support, these rules are not
applicable and, therefore, should be waived.
V. DESIGNATION OF STAI\D UP WIRELESS AS AN ETC WOULD PROMOTE
THE PUBLIC INTEREST
One of the principal goals of the Act, as amended by the Telecommunications Act of
1996, is "to secure lower prices and higher quality services for American telecommunications
consumers and encourage the rapid deployment of new telecommunications technologies" to all
citizens, regardless of geographic location or income.37 Designation of Stand Up Wireless as an
ETC in Idaho will further the public interest by providing Idaho consumers, especially low-
36 See Commission Order No. 29841at Appendix, Section C.
31 -t'' 'l'elecommunications Act of 1996, Pub. L. No. 104-104, I l0 Stat. 56.
20
income consumers, with low prices and high quality services. Many low-income customers in
Idaho have yet to reap the full benefits of the intensely competitive wireless market. Whether
because of financial constraints, poor credit history or intermittent employment, these consumers
often lack the countless choices available to most consumers.
The instant request for ETC designation must be examined in light of the Act's goal of
providing low-income consumers with access to telecommunications services. The primary
purpose of universal service is to ensure that consumers-particularly low-income consumers-
receive affordable and comparable telecommunications services. Given this context, designating
Stand Up Wireless as an ETC would significantly benefit low-income consumers eligible for
Lifeline service in the State of Idaho - the intended beneficiaries of universal service.
A. Advantages of Stand Up Wireless' Service Offering
The public interest benefits of the Company's wireless service include larger local calling
areas (as compared to traditional wireline carriers), the convenience and security afforded by
mobile telephone service, the opportunity for customers to control cost by receiving a preset
amount of monthly airtime at no charge, the ability to purchase additional usage at flexible and
affordable amounts in the event that included usage has been exhausted, 911 service and, where
available, E91l service in accordance with current FCC requirements. The Company's Lifeline
customers will receive the same high-quality wireless services and exceptional customer service
provided to all Company customers. Stand Up Wireless' Lifeline rate plans will not only allow
feature-rich mobile connectivity for qualifying subscribers at no cost to the subscriber, but also
will bring a variety of rate plans into the reach of Lifeline customers that are comparable in
minutes and features to those available to post-paid wireless subscribers - but at low Lifeline
rates and without the burden of credit checks or contracts.
2t
Stand Up Wireless' Lifeline program will provide low-income Idaho residents with the
convenience and security offered by wireless services----even if their financial position deteriorates.
The economic circumstances indicate that low-income individuals, now more than ever, can
greatly benefit from the advantages offered by the Company's Lifeline service, thus allowing
those adversely impacted by the failing economy or job loss to have access to a free wireless
service to assist in emergency situations, facilitate job search efforts, and to maintain contact
with family members.
It is also a commonly accepted fact that in today's market all consumers, including
qualified Lifeline customers, view the portability and convenience of wireless service not as a
luxury, but as a necessity. Mobile service allows children to reach their parents, wherever they
may be, allows a person seeking employment the ability to be contacted by potential employers,
and provides end users with the ability to contact emergency service providers, regardless of
location. Providing Stand Up Wireless with the authority necessary to offer discounted Lifeline
service to those most in danger of losing wireless service altogether undoubtedly promotes the
public interest.
Moreover, grant of Stand Up Wireless' Application will serve the public interest in
increasing the number of ETCs in Idaho. By granting ETC status to Stand Up Wireless, the
Commission will enable Stand Up Wireless to increase the number of Idaho residents receiving
Lifeline support, thereby increasing the amount of USF money flowing into Idaho. In sum, ETC
designation in the State of Idaho would enable Stand Up Wireless to provide all of the public
benefits cited by the FCC in its analysis in the Virgin Mobile Order. Namely, Stand Up Wireless
22
would provide "increased consumer choice, high-quality service offerings, and mobility,"38 as well
as the safety and security of effective 911 and E911 services.3e
B. The Benefits of Competitive Choice
The benefits to consumers of being able to choose from among a variety of
telecommunications service providers have been acknowledged by the FCC for more than three
decades.a0 Designation of Stand Up Wireless as an ETC will promote competition and
innovation, ffid spur other carriers to target low-income consumers with service offerings
tailored to their needs and to improve their existing networks to remain competitive, resulting in
improved services to consumers. Designation of Stand Up Wireless as an ETC will help assure
that quality services are available at'Just, reasonable, and affordable rates" as envisioned in the
Act.ar Introducing Stand Up Wireless into the market as an additional wireless ETC provider will
afford low-income Idaho residents a wider choice of providers and available services while
enhancing a competitive marketplace as ETCs compete for a finite number of Lifeline-eligible
customers. Increasing the competitive marketplace of providers has the potential to effectively
increase the penetration rate and reduce the number of individuals not connected to the PSTN.
C. Impact on the Universal Service Fund
With Lifeline, ETCs only receive support for customers they obtain. The amount of
support available to an eligible subscriber is exactly the same whether the support is given
through a company such as Stand Up Wireless or the Incumbent LEC operating in the same
service area. Stand Up Wireless will only increase the amount of USF Lifeline funding in
situations where it obtains Lifeline customers not enrolled in another ETC's Lifeline program.
38 See Virgin Mobile Order,24FCC Rcd at 3395 fl 33.
3e See Id. at339l 1123.
oo Se", e.g., Specialized Common Carrier Services,29 FCC Rcd 870 (1971).
at See 47 U.S.C. S 254(bXl).
23
By implementing the safeguards set forth in the Lifeline and Link-up Reform Order, Stand Up
Wireless will minimize the likelihood that its customers are not eligible or are receiving
duplicative support either individually or within their household. Significantly, the Company's
designation as an ETC will not increase the number of persons eligible for Lifeline support.
Starid Up Wireless' ability to increase the Lifeline participation rate of qualified low-income
individuals will further the goal of Congress to provide all individuals with affordable access to
telecommunications service, and thus any incremental increases in Lifeline expenditures are far
outweighed by the significant public interest benefits of expanding the availability of affordable
wireless services to low-income consumers. According to the FCC, "the additional choice and
service options of another wireless reseller offering a service for low-income consumers
represents a significant benefit for consumers and is in the public interest," and "A new entrant
should incent existing wireless reseller ETCs to offer better service and terms to their customers,
which provides additional evidence that forbearance in the context of the Lifeline program
outweighs the potential costs."42
VI. ANTI.DRUG ABUSE CERTIFICATION
Stand Up Wireless certifies that no party to this Application is subject to denial of federal
benefits, including FCC benefits, pursuant to Section 5301 of the Anti-Drug Abuse Act of 1988.
o' Se" Petition of i-wireless, LLCfor Forbearancefrom 47 U.S.C$ 2|a@)Q)@), Order, FCC l0-117 (rel. June 25,
2010) at tf 19.
24
VII. CONCLUSION
Based on the foregoing, designation of Stand Up Wireless as an ETC in the State of
Idaho accords with the requirements of Section 2la@)Q) of the Act and is in the public interest.
WHEREFORE, Stand Up Wireless respectfully requests that the Commission promptly
designate Stand Up Wireless as an ETC in the State of ldaho.
1725 Windward Concourse, Suite 150
Alpharett4 Georgia 30005
[phone] (Phone)
[phone] (Fax)
E-Mail: [e-mail]
Attorneys for Global Connection Inc. of
America dba STAND UP WIRELESS
October 10,2013
ly submitted,
25
EXHIBIT 1
Certilication of l)ave Skogen, Chief Executive Officerof Global Connection Inc. of America
dba STAITID UP WIRELESS
State of Georgia
County of Gwinnett
Certification
Personally appeared before the undersigned, an officer duly authorized to administer oaths, Dave
Skogen, who frst being duly sworn, deposes and states that he is the Chief Executive Officer of
Global Connection Inc. of America dba STAND UP WIRELESS, Applicant in this application,
and has read the same and knows the contents thereof, and confirms that the statements made
herein are true to the best of his knowledge and belief.
Subscribed and swom to before me thi*I34 ay ot 'V(a</ zotl.T-
(Notary Seal)
lvly Comrnission Expires:
)
)
)
Skogen, Chief Executive Officer
StandUP Wireless
Rate Plans
As of 7 /71/72
Subsidized Rate Plans
Non-Subsidized Rate Plans
Plan Name
lroice
Vlinutes
tncluded
n Plan
;MS
Vlessages
tncluded
in Plan
Unused
Vlinutes
RoIIover
Unused
iMS
RoIIover
[oicemail
Caller ID
Call Waiting
lncluded
\lationwide
Long
Distance
tncluded
)ost per
I,tonth
StandUP 100 t00 t00 fes fes (es Ies lREE
$tandUP 250 250 Units 1 {o tlo (es Ies rREE
$tandUP 500 ;00 ;00 tlo tlo Ies fes t14.es
ItandUP1000 t 000 [000 tlo tlo (es Ies 129.95
ItandUP Unlimited Jnlimited t 000 tlo tlo (es fes t34.e5
rone unit equals one voice minute or one SMS
Plan Name
tIolce
Vlinutes
lncluded
n PIan
;MS
Vtessager
Included
n Plan
Unused
Minutes
Rollover
Unused
sMs
RoIIover
Voicemail
Caller ID
Call Waiting
Included
\lationwide
Long
Distance
Included
Jost per
tlonth
ItandUP 100 t00 t00 les (es fes (es 1L2.75
itandUP 250 250 Units 1 No No Yes (es 172.75
itandUP 500 ;00 ;00 No No Yes Yes 127.70
StandUP1000 1000 t 000 No No Yes Yes 142.70
ItandUP Unlimited Jnlimited 1000 No No Yes fes i47.70
rone unit equals one voice minute or one SMS
EXHIBIT 3
Stand Up Wireless' FCC-Approved Compliance Plan
ln the Matter of
I
Telecommunications Carriers Eligible to I *a Docket No. 09-197
Receive Universal Service Support
LifelineandLinkUpReformandModernization I WCDocketNo. 11-42
Global Connection Inc. of America
BEFORE THE
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554
Gr,on.lr, CoNNBcrroN INc. orAurmc,l CorrrpnnNcp Pr,eN
Global Connection Inc. of America ( "Global Connection" or the "Company''),l
through its undersigned counsel, hereby respectfully submits and requests expeditious
approval of its Compliance Plan outlining the measures it will take to implement the
conditions imposed by the Commission in its Lifetine Reform Order.z
The Company commends the Commission's commitment to a nationwide
communications system that promotes the safety and welfare of all Americans, including
The Company hereby also reports its corporate and trade names, identifiers, and
its holding company, operating companies and affiliates as: Stand Up Wireless
(dba), and Global Connection Holdings Corporation (holding company). This
Compliance Plan applies only to Global Connection's wireless Lifeline service
offerings.
See Lifeline and Link Up Reform and Modernization, Lifeline and Link Up,
Federal-State Joint Boord on Universal Service, Advancing Broadband
Availability Through Digital Literacy Training, WC Docket No. ll-42, WC
Docket No. 03-109, CC Docket No. 96-45, WC Docket No. 12-23, Report And
Order and Further Notice Of Proposed Rulemaking, FCC 12-11 (Feb. 6, 2012)
("Lifeline Reform Order"). The Company herein submits the information
required by the Compliance Plan Public Notice. See Wireline Competition
Bureau Provides Guidance for the Submission of Compliance Plans Pursuant to
the Lifeline Reform Order, WC Docket Nos. 09-197, 11.-42, Public Notice, DA
12-314 (rel. Feb. 29,2012).
Lifeline customers. Global Connection will comply with 911 requirements as described
below and it is submitting this Compliance Plan in order to qualify for blanket
forbearance from the facilities requirement of section 2la(e)(l)(A) of the
Communications Act and participate as an eligible telecommunications carrier ("ETC")
in the Lifeline program.3
Global Connection will comply fully with all conditions set forth in the Lifeline
Reform Order, as well as with the Commission's Lifeline rules and policies more
generally.a This Compliance Plan describes the specific measures that the Company
intends to implement to achieve these objectives. Specifically, this Compliance Plan: (l)
describes the specific measures that the Global Connection will take to implement the
obligations contained in the Lifeline R"for* Order, including the procedures the
Company follows in enrolling a subscriber in Lifeline and submitting for reimbursement
foi that subscriber from the low income fund, materials related to initial and ongoing
certifications and sample marketing materials; and (2) provides a detailed description of
how Global Connection offers Lifeline services, the geographic areas in which it offers
services, and a detailed description of the Company's Lifeline service plan offerings.
See Lifeline Reform Order, fl 368. Although Global Connection qualifies for and
seeks to avail itself of the Commission's grant of forbearance from the facilities
requirement of section 21a(e)(1)(A) for purposes of the federal Lifeline program,
the Company reserves the right to demonstrate to a state public utilities
commission that it provides service using its own facilities in a state for purposes
of state universal service funding under state program rules and requirements.
In addition, this Compliance Plan is consistent with the compliance plan filed by
Cricket Communications, Inc. See Notice of Ex Parte Communication of Cricket
Communications, Inc., WC Docket No. 09-197 (Sept. 23,201.1) ("Cricket
Compliance Plan"). The Wireline Competition Bureau approved the Cricket
Compliance Plan on February 7,2012. See Telecommunications Carriers Eligible
for Universal Service Support, Cricket Communications, Inc. Petitionfor
Forbearance,WC Docket No. 09-197, Order, DA 12-158 (Feb. 7, 2012).
Pursuant to the Lifeline Reform Order, forbearance is conditioned upon the
Company: (l) providing its Lifeline subscribers with 911 and E911 access, regardless of
activation status and availability of minutes; and (2) providing its Lifeline subscribers
with E91l-compliant handsets and replacing, at no additional charge to the subscriber,
noncompliant handsets of Lifeline-eligible subscribers who obtain Lifeline-supported
services.6 The Company will comply with these conditions starting on the effective date
of the Lifeline Reform Order.
The Company will provide its Lifeline customers with access to 911 and E911
services immediately upon activation of service. The Commission and consumers are
hereby assured that all Company customers will have available access to emergency
calling services at the time that Lifeline service is initiated, and that such 911 and E91l
access will be available from Company handsets, even if the account associated with the
handset has no minutes remaining.
Global Connection's existing practices currently provide access to 911 and E911
services for all customers. The Company uses Sprint and Verizon Wireless as its
underlying network provider/carrier. Sprint and Verizon Wireless route 9l l calls from
the Company's customers in the same manner as 9l I calls from their own retail
customers. To the extent that Sprint or Verizon Wireless is certified in a given PSAP
territory, this 911 capability will function the same for the Company. Global Connection
also currently enables 911 emergency calling services for all properly activated handsets
regardless of whether the account associated with the handset is active or suspended.
t 5"" Compliance Plan Public Notice at 3.u 5"" Lifetine Reform Order,n373 .
Finally, Global Connection transmits all 911 calls initiated from any of its handsets even
if the account associated with the handset has no remaining minutes.
E91l-Compliant Handsets. Global Connection will ensure that all
handsets used in connection with the Lifeline service offering are E911-
compliant. In point of fact, the Company's phones have always been and will
continue to be 911 and E91l-compliant. The Company uses phones from BDI
Logistics LLC that have been through a stringent certification process, which
ensures that the handset models used meet all 911 and E911 requirements. As a
result, any existing customer that qualifies for and elects Lifeline service will
already have a glllEgtl-compliant handset, which will be confirmed at the time
of enrollment in the Lifeline program. Any new customer that qualifies for and
enrolls in the Lifeline program is assured of receiving a9lllB9ll-compliant
handset as well, free of charge.
Coupr,raNcp Pr,nN
I. Pnocrounrs To ENRor,r, A SusscRrBER rx Lrrrr,nvBT
A.Policy
Global Connection will comply with the uniform eligibility criteria established in
new section 54.409 of the Commission's rules (when it becomes effective on June 1,
2012), as well as any additional certification and verification requirements for Lifeline
eligibility in states where the Company is designated as an ETC.
Therefore, all subscribers will be required to demonstrate eligibility based at least
on: (l) household income at or below 135% of the Federal Poverty Guidelines for a
.See Compliance Plan Public Notice at 3.
household of that size; or (2) the household's participation in one of the federal assistance
programs listed in new sections 54.409(a)(2) or 5a.a09(a)(3) of the Commission's rules.
ln addition, through the certification requirements described below, the Company will
confirm that the subscriber is not already receiving a Lifeline service and no one else in
the subscriber's household is subscribed to a Lifeline service.
B. Eligibility Determination
If Global Connection cannot determine a prospective subscriber's eligibility for
Lifeline by accessing income databases or program eligibility databases, the Company's
employees or agents ("Company personnel") will review documentation establishing
eligibility pursuant to the Lifeline rules.8 All personnel who interact with current or
prospective customers will be trained to assist Lifeline applicants in determining whether
they are eligible to participate based on the federal and state-specific income-based
and/or program-based criteria. These personnel will be trained to answer questions about
Lifeline eligibility, and will review required documentation to determine whether it
satisfies the Lifeline Reform Order and state-specific eligibility requirements using state-
specific checklists.e
Proof of Eligibiliqv. Company personnel will be trained on acceptable
documentation required to establish income-based and program-based eligibility. l0
Acceptable documentation of program eligibility includes: (1) the current or prior year's
statement of benefits from a qualifuing state, federal or Tribal program; (2) a notice letter
See Lifeline Reform Order, fl 100; section 54.410(bXlXiXB), 54.a10(c)(1Xi)(B);
Cricket Compliance Plan at 4.
^lee Cricket Compliance Plan at 6.
See Lifeline Reform Order, fl 101.
9
10
of participation in a qualifuing state, federal or Tribal program; (3) program participation
documents (e.g.,the consumer's Supplemental Nutrition Assistance Program (SNAP)
electronic benefit transfer card or Medicaid participation card (or copy thereof)); or (4)
another official document evidencing the consumer's participation in a qualifuing state,
federal or Tribal program.ll
Acceptable documentation of income eligibility includes the prior year's state,
federal, or Tribal tax return; current income statement from an employer or paycheck
stub; a Social Security statement of benefits; a Veterans Administration statement of
benefits; a retirement/pension statement of benefits; an Unemployment/Workmen's
Compensation statement of benefits; federal or Tribal notice letter of participation in
General Assistance; or a divorce decree, child support award, or other official document
containing income information for at least three months time.l2
Company personnel will examine this documentation for each Lifeline applicant,
and will record the type of documentation used to satisfu the income- or program-based
criteria.13 The Company will not retain a copy of this documentation.la Where the
Company personnel conclude that proffered documentation is insufficient to establish
such eligibility, Global Connection will deny the associated application and inform the
applicant of the reason for such rejection.ls In the event that Company personnel cannot
t1
t2
13
14
15
Id. and section 5a.al0(c)(lXiXB).
See Lifeline Reform Order, fl101; section 54.410.(bXlXiXB).
See Lifeline Reform Order, fl101; sections 54.41O(bXlXiii), 5a.a10(c)(1)(iii).
See Lifeline Reform Order,fll0l; sections 54.410(b)(lXii), 5a.a10(c)(1)(ii).
See Cicket Compliance Plan at 6.
ascertain whether documentation of a specific type is sufficient to establish an applicant's
eligibility, the matter will be escalated to supervisory personnel.16
De-Enrollment for Inelieibility. If Global Connection has a reasonable basis to
believe that one of its Lifeline subscribers no longer meets the eligibility criteria, the
Company will notifu the subscriber of impending termination in writing and in
compliance with any state dispute resolution procedures applicable to Lifeline
termination, and give the subscriber 30 days to demonstrate continued eligibitity.lT A
demonstration of eligibility must comply with the annual verification procedures below
and found in new rule section 54.410(0, including the submission of a certification form.
C.Subscriber Certifications for Enrollment
Global Connection will implement certification policies and procedures that
enable consumers to demonstrate their eligibility for Lifeline assistance to Company
personnel as detailed inthe Lifeline Reform Order, together with any additional state
certification requirements.18 The Company shares the Commission's concern about
abuse of the Lifeline program and is thus committed to the safeguards stated herein, with
the belief that these procedures will prevent the Company's customers from engaging in
such abuse of the program, inadvertently or intentionally.le Every applicant will be
required to complete an application/certification form containing disclosures, and
collecting certain information and certifications as discussed below.20 Applicants that do
t6
t7
18
19
20
See id.
See Lifeline Reform Order, ![ 143; section 5a.a05(e)(1).
Lifeline Reform Order, !J61; section 54.410(a).
See Cicket Compliance Plan at 3.
See Model Applicatior/Certification Form, included as Exhibit A. See
Compliance Plan Public Notice at 3.
not complete the form in person will be required to return the signed
application/certification to the Company by mail, facsimile, electronic mail or other
electronic transmission. In addition, Company personnel will verbally explain the
certifications to consumers when they are enrolling in person or over the phone.2l
Disclosures. The Company's application and certification forms will include the
following disclosures: (l) Lifeline is a federal benefit and willfully making false
statements to obtain the benefit can result in fines, imprisonment, de-enrollment or being
barred from the program; (2) only one Lifeline service is available per household; (3) a
household is defined, for purposes of the Lifeline program, as any individual or group of
individuals who live together at the same address and share income and expenses; (4) a
household is not permitted to receive Lifeline benefits from multiple providers; (5)
violation of the one-per-household limitation constitutes a violation of the Commission's
rules and will result in the applicant's de-enrollment from the program; and (6) Lifeline is
a non-transferable benefit and the applicant may not transfer his or her benefit to any
other person.22
Applications and certification forms will also state that: (1) the service is a
Lifeline service, (2) Lifeline is a government assistance program, and (3) only eligible
consumers may enroll in the program.23
In addition, the Company will noti$r the applicant that the prepaid service must be
personally activated by the subscriber and the service will be deactivated and the
subscriber de-enrolled if the subscriber does not use the service for 60 days.2a
2t
23
See Lifeline Reform Order,nl23.
See id.,n 1.2.L; section 54.410(d)(1).
See section 54.405(c).
Information Collection. The Company will also collect the following information
from the applicant in the application/certification form: (1) the applicant's full name;"
(2) the applicant's full residential address (P.O. Box is not sufficient26); (3) whether the
applicant's residential address is permanent or temporary; (4) the applicant's billing
address, ifdifferent from the applicant's residential address; (5) the applicant's date of
birth; (6) the last four digits of the applicant's Social Security number (or the applicant's
Tribal identification number, if the subscriber is a member of a Tribal nation and does not
have a Social Security number); (7) if the applicant is seeking to qualify for Lifeline
under the program-based criteria, the name of the qualifuing assistance program from
which the applicant, his or her dependents, or his or her household receives benefits;27
and (8) if the applicant is seeking to qualify for Lifeline under the income-based criterion,
the number of individuals in his or her household.28
Applicant Certification. Consistent with new rule section 54.410(d)(3), the
Company will require the applicant to certify, under penalty of perjury, in writing or by
electronic signature or interactive voice response recording,2e the following: (l) the
applicant meets the income-based or program-based eligibility criteria for receiving
Lifeline; (2) the applicant will notify the Company within 30 days if for any reason he or
she no longer satisfies the criteria for receiving Lifeline including, as relevant, if the
applicant no longer meets the income-based or program-based criteria for receiving
24
25
26
27
28
29
See Lifeline Reform Order, fl 114.
See Cricket Compliance Plan at 4.
See Lifeline Reform Order,fl87.
See Cricket Compliance Planat4.
See section 54.4I0(d)(2). See Cricket Compliance Plan at 4.
See Lifeline Reform Order. flfl 168-69; section 54.419.
Lifeline support, the applicant is receiving more than one Lifeline benefit, or another
member of the applicant's household is receiving a Lifeline benefit; (3) if the applicant is
seeking to qualify for Lifeline as an eligible resident of Tribal lands, he or she lives on
Tribal lands; (4) if the applicant moves to a new address, he or she will provide that new
address to the Company within 30 days; (5) if the applicant provided a temporary
residential address to the Company, the applicant will be required to verify his or her
temporary residential address every 90 days; (6) the applicant's household will receive
only one Lifeline service and, to the best of the applicant's knowledge, the applicant's
household is not already receiving a Lifeline service;3o (7) the information contained in
the applicant's certification form is true and correct to the best of the applicant's
knowledge;31 (8) the applicant acknowledges that providing false or fraudulent
information to receive Lifeline benefits is punishable by law; and (9) the applicant
acknowledges that the applicant may be required to re-certify his or her continued
eligibility for Lifeline at any time, and the applicant's failure to re-certify as to the
applicant' s continued eligibility will result in de-enrollment and the termination of the
applicant's Lifeline benefits pursuant to the de-enrollment policy included below and in
the Commission's rules.
ln addition, the applicant will be required to authorize Global Connection to
access any records required to verify the applicant's statements on the
application/certification form and to confirm the applicant's eligibility for the Company
Lifeline credit.32 The applicant must also authorize the Company to release any records
30
31
32
See Cricket Compliance Plan at 4.
See id. at 5.
See id.
r0
required for the administration of the Company Lifeline credit program, including to
USAC to be used in a Lifeline program database.33
D.Annual Verification Procedures
Global Connection will annually re-certify all subscribers by querying the
appropriate eligibility databases or obtaining a signed certification from each subscriber
consistent with the certification requirements above and new section 54.410(d) of the
Commission's rules. This certification will include a confirmation that the applicant's
household will receive only one Lifeline service and, to the best of the subscriber's
knowledge, the subscriber's household is receiving no more than one Lifeline service.3a
Further, the verification materials will inform the subscriber that he or she is being
contacted to re-certify his or her continuing eligibility for Lifeline and if the subscriber
fails to respond, he or she will be de-enrolled in the program.3s
2012 Verification. Global Connection will re-certifu the eligibility of each of its
existingsubscribersasofJune 1,2012 onarollingbasisbytheend of2012 andreport
the results to USAC by January 31,2013.36 The Company will contact its subscribers via
text message to their Lifeline supported telephone, or by mail, phone, email or other
Intemet communication. The notice will explain the actions the customer must take to
34
35
16
See Section 54.404(b)(9). The application/certification form will also describe the
information that will be transmitted, that the information is being transmitted to
USAC to ensure the proper administration of the Lifeline program and that failure
to provide consent will result in the applicant being denied the Lifeline service.
See id. See also Cricket Compliance Plan at 5.
See Lifeline Reform Order, fl 120 and Cricket Compliance Plan at 8.
See Lifeline Reform Order, fl 145.
See id, '11 130.
t1
retain Lifeline benefits, when Lifeline benefits may be terminated, and how to contact the
Company.
Verification De-Enrollment. Global Connection will de-enroll subscribers that do
not respond to the annual verification or fail to provide the required certification." The
Company will give subscribers 30 days to respond to the annual verification inquiry. If
the subscriber does not respond, the Company will send a separate written notice
explaining that failure to respond within 30 days will result in the subscriber's de-
enrollment from the Lifeline program. If the subscriber does not respond within 30 days,
the Company will de-enroll the subscriber within five business days.
E. Activation and Non-Usage
Global Connection will not consider a prepaid subscriber activated, and will not
seek reimbursement for Lifeline for that subscriber, until the subscriber activates the
Company's prepaid service by dialing a specified dedicated number from their Global
Connection-issued handset.3s ln addition, after service activation, the Company will
provide a de-enrollment notice to subscribers that have not used their service for 60 days.
After 60 days of non-use, the Company will provide notice to the subscriber that failure
to use the Lifeline service within a 30-day notice period will result in de-enrollment.3e
Subscribers can "use" the service by: (1) completing an outbound call; (2) purchasing
minutes from the Company to add to the subscriber's plan; (3) answering an incoming
37
38
39
See Lifeline Reform Order,nA2; section 54.5a.a05@)@).
See Lifeline Reform Order,l257; section 5a.a07(c)(1).
See Lifeline Reform Order,\257; section 54.405(e)(3). See Cricket Compliance
Plan at 2 (stating that it did not need to implement a non-usage policy because it
offered only plans with unlimited local and long distance calling).
t2
call from a party other than the Company; or (4) responding to a direct contact from the
Company and confirming that the subscriber wants to continue receiving the service.a0
If the subscriber does not respond to the notice, the subscriber will be de-enrolled
and the Company will not request further Lifeline reimbursement for the subscriber.
Global Connectino will report annually to the Commission the number of subscribers de-
enrolled for non-usage by month.al
F. Additional Measures to Prevent Waste, Fraud and Abuse
To supplement its verification and certification procedures, and to better ensure
that customers understand the Lifeline service restrictions with respect to duplicates,
Global Connection will implement measures and procedures to prevent duplicate Lifeline
benefits being awarded to the same household. These measures entail additional
emphasis in written disclosures as well as live due diligence.a2
In addition to checking the database when it becomes available, Company
personnel will emphasize the "one Lifeline phone per household" restriction in their
direct sales contacts with potential customers.43 Training materials will include a
discussion of the limitation to one Lifeline phone per household, and the need to ensure
that the customer is informed of this restriction.aa All customer-facing employees and
agents must demonstrate understanding of the Commission's and Global Connection's
40
41
42
43
44
See Lifeline Reform Order,n26l; section
See Lifeline Reform Order,n257; section
See Cicket Compliance Plan at 9.
See id. at 6,9.
See id.
sa.a07@)(2).
sa.a0s(e)(3).
t3
rules and policies by completing the Company's Lifeline training and passing a Company
issued exam. The training will be updated as needed, but at least every 90 days.
Database. When the National Lifeline Accountability Database ("National
Database") becomes available, the Company will comply with the requirements of new
rule section 54.404. The Company will query the National Database to determine
whether a prospective subscriber is currently receiving a Lifeline service from another
ETC and whether anyone else living at the prospective subscriber's residential address is
currently receiving Lifeline service.as
One-Per-Household. Global Connection will implement the requirements of the
Lifetine Reform Order to ensure that it provides only one Lifeline benefit per householda6
through the use of its application and certification forms discussed above, internal
database checks and its marketing materials discussed below. Upon receiving an
application for the Company's Lifeline service, the Company will search its own internal
records to ensure that it does not already provide Lifeline-supported service to someone
at the same residential address.aT If so, and the applicant lives at an address with multiple
See Lifeline Reform Order,nZ03. Company will also transmit to the National
Database the information required for each new and existing Lifeline subscriber.
See id., flfl 189-195; section 54.404(bX6). Further, Company will update each
subscriber's information in the National Database within ten business days of any
change, except for de-enrollment, which will be transmitted within one business
day. See section 54.404(bX8),(10).
A "household" is any individual or group of individuals who are living together at
the same address as one economic unit. A household may include related and
unrelated persons. An "economic unit" consists of all adult individuals
contributing to and sharing in the income and expenses of a household. An adult
is any person eighteen years or older. If an adult has no or minimal income, and
lives with someone who provides financial support to him/her, both people shall
be considered part of the same household. Children under the age of eighteen
living with their parents or guardians are considered to be part of the same
household as their parents or guardians. See Lifeline Reform Order, fl 74; section
s4.400(h).
See Lifeline Reform Order, fl 78 and Cricket Compliance PlanatT.
45
t4
households, the Company will require the applicant to complete and submit a written
USAC document containing the following: (l) an explanation of the Commission's one-
per-household rule; (2) a check box that an applicant can mark to indicate that he or she
lives at an address occupied by multiple households; (3) a space for the applicant to
certifu that he or she shares an address with other adults who do not contribute income to
the applicant's household and share in the household's expenses or benefit from the
applicant's income, pursuant to the Commission's definition; and (4) the penalty for a
consumer's failure to make the required one-per-household certification (i.e., de-
enrollment).48 Further, if a subscriber provides a temporary address on his or her
application/certification form collected as described above, Global Connection will verify
with the subscriber every 90 days that the subscriber continues to rely on that address.ae
Finally, Company personnel will inform each Lifeline applicant that he or she
may be receiving Lifeline support under another name, and facilitate the applicant's
understanding of what constitutes "Lifeline-supported services," and ability to determine
whether he or she is already benefiting from Lifeline support, by informing the consumer
that not all Lifeline services are currently marketed under the name Lifeline.
Marketins Materials. Within the deadline provided inthe Lifeline Reform Order,
the Company will include the following information regarding its Lifeline service on all
marketing materials describing the service: (1) it is a Lifeline service,so (2) Lifeline is a
government assistance program, (3) the service is non-transferable, (4) only eligible
consumers may enroll in the program, (5) the program is limited to one discount per
48
49
50
Id.
See Lifeline Reform Order,fl89.
See Cricket Compliance Plan at 4.
15
household; (6) what documentation is necessary for enrollment; (7) Global Connection's
name (the ETC); and (8) consumers who willfully make a false statement in order to
obtain the Lifeline benefit can be punished by fine or imprisonment or can be barred from
the program.sl These statements will be included in all print, audio video and web
materials (including social networking media) used to describe or enroll customers in the
Company's Lifeline service offering, as well as the Company's application forms and
certification forms.s2 This specifically includes the Company's website
(www.StandUpWireless.com) and outdoor signage.s3 A sample of the Company's
marketing materials is included as Exhibit B.
G.Company Reimbursements From the Fund
To ensure that the Global Connection does not seek reimbursement from the Fund
without a subscriber's consent, the Company will certify, as part of each reimbursement
request, that it is in compliance with all of the Commission's Lifeline rules and, to the
extent required, has obtained valid certification and verification forms from each of the
subscribers for whom it is seeking reimbursement.sa Further, the Company will transition
the submission of its FCC Forms 497 to the eighth day of each month in order to be
reimbursed the same month, and inform USAC, to the extent it deems necessary, to
transition its reimbursement process to actual claims rather than projected claims over the
5l
52
53
54
See Lifeline Reform Order,n275; section 5a.a05(c).
Id.
rd.
See Lifeline Reform Order, t[ 128; section 54.407(d).
16
course of more than one month.ss In addition, the Company will keep accurate records as
directed by USACS6 and as required by new section 54.417 of the Commission's rules.
H. Annual Company Certifications
The Company will submit an annual certification to USAC, signed by a Global
Connection officer under penalty of perjury, that the Company: (1) has policies and
procedures in place to review consumers' documentation of income- and program-based
eligibility and ensure that its Lifeline subscribers are eligible to receive Lifeline
services;s7 (2) is in compliance with all federal Lifeline certification procedures;s8 and (3)
has obtained a valid certification form for each subscriber for whom the carrier seeks
Lifeline reimbursement.se
In addition, the Company will provide the results of its annual re-
certifications/verifications on an annual basis to the Commission, USAC, the applicable
state commission and the relevant Tribal goverrments (for subscribers residing on Tribal
lands).60 Further, as discussed above, Global Connection will report annually to the
Commission the number of subscribers de-enrolled for non-usage by month.6l
The Company will also annually report to the Commission, USAC, and relevant
state commissions and the relevant authority in a U.S. territory or Tribal govemment as
55
56
57
58
s9
60
61
See Lifeline Reform Order,lJfl 302-306.
See section 54.407(e).
See Lifeline Reform Order,nD6; section 5a. l6(a)(l).
See Lifeline Reform Order,nl2T; section 5a.al6@)(2).
See section 5a.a1 6(a)(3).
See Lifeline Reform Order, fllJ 132,148; section 54.416(b).
See Lifeline Reform Order,n257; section 5a.405(e)(3).
t7
appropriate,62 the company name, names of the company's holding company, operating
companies and affiliates, and any branding (such as a "dba" or brand designation) as well
as relevant universal service identifiers for each entity by Study Area Code.63 The
Company will report annually information regarding the terms and conditions of its
Lifeline plans for voice telephony service offered specifically for low income consumers
during the previous year, including the number of minutes provided and whether there are
additional charges to the consumer for service, including minutes of use and/or toll
cal1s.6a Finally, Gtobal Connection will annually provide detailed information regarding
service outages in the previous year, the number of complaints received and certification
of compliance with applicable service quality standards and consumer protection rules, as
well as a certification that the Company is able to function in emergency situations.6s
I. Cooperation with State and Federal Regulators
Global Connection has cooperated and will continue to cooperate with federal and
state regulators to prevent waste, fraud and abuse. More specifically, the Company will:
Make available state-specific subscriber data, including the names and
addresses of Lifeline subscribers, to USAC and to each state public
utilities commission where the Company operates for the purpose of
determining whether an existing Lifeline subscriber receives Lifeline
service from another carrier;66
Assist the Commission, USAC, state commissions, and other ETCs in
resolving instances of duplicative enrollment by Lifeline subscribers,
including by providing to USAC and/or any state commission, upon
62
63
@
65
66
See section 54.422(c).
See Lifeline Reform Order,fln296,390; section 54.422(a).
See Lifeline Reform Order, 'l|T390; section 54.422(b)(5).
Se e Lifel i ne Reform O r der, lJ 3 89 ; section 5 4.422(b)(I)-(4).
The Company anticipates that the need to provide such information will sunset
following the implementation of the national duplicates database.
18
request, the necessary information to detect and resolve duplicative
Lifeline claims;
. Promptly investigate any notification that it receives from the
Commission, USAC, or a state commission to the effect that one of its
customers already receives Lifeline services from another carrier; and
. Immediately de-enroll any subscriber whom the Company has a
reasonable basis to believe6T is receiving Lifeline-supported service from
another ETC or is no longer eligible - whether or not such information is
provided by the Commission, USAC, or a state commission.68
II. Description of Lifeline Service Offerings6e
Global Connection will offer its wireless Lifeline service in the states where it is
designated as an ETC70 and throughout the coverage area of its underlying provider(s)
Sprint and Verizon Wireless. The Company's Lifeline offering will provide customers
with 100 anytime prepaid minutes per month, plus 100 anytime text messages, with
rollover, at no charge. Additionally, the Company will offer a250 anytime talk and text
plan without rollover (one minute of talk time for each text). Lifeline customers can
purchase additional bundles of minutes in denominations of $5 (40 minutes), $10 (100
minutes), S20 (250 minutes), $30 (500 minutes) and $50 (1000 minutes). Airtime "top-
up" minutes are available for purchase at the Company's retail locations, through
customer service and on its website. Text messaging is available at the rate of one
minute of talk time per text message. Additional information regarding the Company's
plans, rates and services can be found on its website www.StandUpWireless.com.
67 See section 5a.405(e)(1).68 See CricketCompliance Plan at 10.6e See Compliance Plan Public Notice at 3.70 Global Connection is currently designated as an ETC in Arkansas, Louisiana,
Maryland, Missouri and West Virginia.
19
In addition to free voice services, Global Connection's Lifeline plan will include a
free handset and custom calling features at no charge, including Caller ID, Call Waiting,
and Voicemail. All plans include domestic long-distance at no extra per minute charge.
Calls to 91 1 emergency services are always free, regardless of service activation or
availability of minutes.
III. Demonstration of Financial and Technical Capabilities and Certifications
Required for ETC DesignationTl
Financial and Technical Capabilities. Revised Commission rule 54.202(a)(4),47
C.F.R. 5a.202(a)$), requires carriers petitioning for ETC designation to demonstrate
financial and technical capability to comply with the Commission's Lifeline service
requirements.T2 The Compliance Plan Public Notice requires that carriers' compliance
plan include this demonstration. Among the factors the Commission will consider are: a
carrier's prior offering of service to non-Lifeline subscribers, the length of time the
carrier has been in business, whether the carrier relies exclusively on Lifeline
reimbursement to operate; whether the carrier receives revenues from other sources and
whether the carrier has been the subject of an enforcement action or ETC revocation
proceeding in any state.
Global Connection has been offering non-Lifeline and Lifeline wireline service
since 1998 and began providing non-Lifeline and Lifeline-supported wireless service in
April, 201 1. The Company generates substantial revenues from non-Lifeline services
and has access to capital from its investors. The majority owner of Global Connection is
Milestone Partners, a Pennsylvania private equity firm. Consequently, Global
See Compliance Plan Public Notice at 3.
See Lifeline Reform Order, fl!|387-388 (revising Commission rule 5a.202(a)(g).
7t
72
20
Connection has not relied, and will not be relying exclusively on Lifeline reimbursement
for the Company's operating revenues. The Company has not been subject to
enforcement sanctions or ETC revocation proceedings in any state.
Service Reuirements Applicable to the Companv's Supoort. The Compliance
Plan Public Notice requires carriers to include "certifications required under newly
amended section 54.202 of the Commission's rules."7' Global Connection certifies that it
will comply with the service requirements applicable to the support the Company
receives.T4 The Company provides all of the telecommunications service supported by
the Lifeline program and will make the services available to all qualified consumers
throughout the states in which it is designated as an ETC. The Company's services
include voice telephony services that provide voice grade access to the public switched
network or its functional equivalent. Further, the Company's service offerings provide its
customers with a set number of minutes of use for local service at no charge to the
customer. The Company's current Lifeline offerings include packages in Section II
supra that can be used for local and domestic toll service.
The Company also will provide access to emergency services provided by local
government or public safety officials, including 911 and E9l I where available and will
comply with any Commission requirements regarding E91l-compatible handsets. As
discussed above, the Company will comply with the Commission's forbearance grant
conditions relating to the provision of 911 and E911 services and handsets.
Finally, Global Connection will not provide toll limitation service ("TLS"), which
allows low income consumers to avoid unexpected toll charges. However, since the
Compliance Plan Public Notice at 3.
47 C.F.R. $ sa.202(aX1).
73
74
21
Company is a prepaid service provider, customers cannot be disconnected for failure to
pay toll charges, nor are there additional charges for exceeding their minutes. Further,
the Company, like most wireless carriers, does not differentiate domestic long distance
toll usage from local usage and all usage is paid for in advance. Pursuant to the Lifeline
Reform Order, subscribers to such services are not considered to have voluntarily elected
to receive TLS.75
IV. Conclusion
Global Connection submits that its Compliance Plan fully satisfies the conditions
set forth in the Commission's Lifeline Reform Order, the Compliance Plan Public Notice
and the Lifeline rules. Accordingly, the Company respectfully requests that the
Commission expeditiously approve its Compliance Plan.
Respectfully submitted,
q$t*S++**."--...-.
John J. Heitmann
Joshua T. Guyan
Kelley Drye & Warren, LLP
3050 K Street, NW
Suite 400
Washington, D.C. 20007
(202) 342-8s44
Counsel to Global Connection Inc. of
America
March 8,2012
See Lifeline Reform Order,nn0.
22
EXHIBIT A
standilil
WIRELESSH"
Global Connection !nc. of America
Customer eligibility certification: I hereby certify that I
(check one):
tr Supplemental Nutrition Assistance Program (SNAP)
o Section 8 Federal Public Housing Assistance (FPHA)
tr Medicaid (noi Medicare)
tr Supplemental Security lncome (SSl)
Global Connection lnc. of America D/B/A StandUP Wireless
State Wireless Lifeline Service Application and Certification
Mail or fax form completed and signed form to:
Fax [phone] / Customer Service: 1.800.544.4447
participate in at least one of the following programs
o TemporaryAssistance for Needy Families (TANF)
tr Low lncome Home Energy Assistance Program (LIHEAP)
tr National School Lunch Program's free lunch program
tr lncome at or below t35% of Federal Poverty Guidelines
A complete and signed Lifeline Service Application and Certification ("Certification") is required to enroll you in Global
Connection lnc. of America D/B/A StandUP Wireless ("the Company's") Lifeline service program in your state. This
Certification is only for the purpose of verifying your eligibility for Lifeline service and will not be used for any other
purpose. Service requests will not be processed until this Form has been received and verified by Company.
One Lifeline service per household disclosures: Lifeline is a government assistance program and willfully making false
statements to obtain a Lifeline benefit can result in fines, imprisonment, de-enrollment or being barred from the program.
Lifeline benefits are limited to a single line of service per household. A household is defined, for purposes of the Lifeline
program, as any individual or group of individuals who live together at the same address and share income and expenses. A
household may not receive multiple Lifeline discounts. You may apply your Lifeline discount to either one landline or
one wireless number, but you cannot have the discount on both and you cannot receive Lifeline benefits from multiple
providers. Note that not all Lifeline services are currently marketed under the name Lifeline. Lifeline is a non-
transferable benefit and you may not transfer your benefit to any other person, including another eligible low-income
consumer. Violation of the one-per-household limitation constitutes a violation of the Federal Communications Commission's
rules and will result in your de-enrollment from the program, and potentially prosecution by the United States Government.
o I hereby certify that I have read and understood the disclosures listed above and that, to the best of my
knowledge, my household is not already receiving a Lifeline service benefit.
Additional certifications: I hereby certify, under penalty of perjury, that (Check the box next to each line):
o I meet the income-based or program-based eligibility criteria for receiving Lifeline service and have provided documentation
of eligibility if required
o I will notify the Company within 30 days if for any reason I no longer satisfy the criteria for receiving Lifeline including, as
relevant, if I no longer meet the income-based or program-based eligibility criteria, I begin receiving more than one Lifeline
benefit, or another member of my household is receiving a Lifeline benefit. I understand that I may be subject to penalties if I
fail to follow this requirement
o I am not listed as a dependent on another person's tax return (unless over the age of 6O)
o The address listed below is my primary residence, not a second home or business
o lf I move to a new address, I will provide that new address to the Company within 30 days
o lf I provided a temporary residential address to the Company, I will verify my temporary residential address every 90 days
o I acknowledge that providing false or fraudulent information to receive Lifeline benefits is punishable by law
o I acknowledge that I may be required to re-certify my continued eligibility for Lifeline at any time, and my failure to re-certify
as to my continued eligibility within 30 days will result in de-enrollment and the termination of my Lifeline benefits
o The information contained in this certification form is true and correct to the best of my knowledge
Multiple households sharing and address:
o I hereby certify that I reside at an address occupied
contribute income to my household and/or share in my
additional form.
by multiple households, including adults who do not
household's expenses, and lwill complete a separate
Activation and usage requirement disclosures: This service is a prepaid service and you must personally activate it by
calling 1.877.283.3890. To keep your account active, you must use your Lifeline service at least once during any 60 day period by
completing an outbound call, purchasing additional minutes from Company, answering an in-bound call from someone other
than Company, or by responding to a direct contact from Company confirming that you want to continue receiving Lifeline
service from Company. lf your service goes unused for 60 days, you will no longer be eligible for Lifeline benefits and your
service will be suspended (allowing only 911 calls and calls to the Company's customer care center) subject to a 30 day cure
period during which you may use the service (as described above) or contact the Company to confirm that you want to continue
receiving Lifeline service from Company.
o I hereby certify that I have read and understood the disclosures listed above regarding activation and usage
requirements.
Authorizations:
o I hereby authorize the Company to access any records required to verify my statements on this form and to confirm my
eligibility for the Lifeline program. I also authorize the Company to release any records required for the administration of the
Lifeline program (e.g., name, telephone number and address), including to the Universal Service Administrative Company, to
be used in a Lifeline database and to ensure the proper administration of the Lifeline Program. Failure to consent will result in
denial of service.
Customer Application lnformation:
First Name:Middle Name:Last Name:
Date of Birth: Month: _ Day: _ Year: Last Four Digits of Social Security Number:
lf Qualifying for Lifeline by lncome, number of lndividuals in Household:
Home Telephone Number (if available):
Residential Address (P.O. Box NOT sufficient)
Number:Apt: _ Street
State: _ Zip Code:
Address is (choose one):Permanent. Temporary
City
Billing Address (if different
Number: _ Apt
State:Zip Code:
from Residential Address) (P.O. Box
: Street
lS sufficient)
City
Applicant's Signature:Date:
For Agent Use Only (check only 1 eligibility category and only 1
Docum ents Acceptable Proof for lncome-Eligibility:
! the prior year/s state, federal, or Tribal tax return,
! Current income statement from an employer or paycheck stub,
I e Social Security statement of benefits,
I A Veterans Administration statement of benefits,
E A retirement/pension statement of benefits,
f] en Unemployment/Workmen's Compensation statement of benefits,
! Federal or Tribal notice letter of participation in General fusistance, or
I A divorce decree, child support award, or other official document
containing income information for at least three months time.
box under that category; do not copy or retain documentation):
Documents Acceptable Proof for Program-Eligibility:
I The current or prior year's statement of benefits from a qualifying state, federal
or Tribal program;
n A notice letter of participation in a qualifying state, federal or Tribal program;
I Program participation documents (e.g., the consume/s Supplemental Nutrition
Assistance Program {SNAP} electronic benefit transfer card or Medicaid
participation card (or copy thereof)); or
I Another official document evidencing the consume/s participatlon in a
qualifying state, federal or Tribal program
Applicant Account Number Agent/Dealer Number
EXHIBIT B
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EXIIIBIT 4
2011 Lifeline Participation Rates by State
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BLFTIDMA
BLSSIDMA
BNCRIDMA
BOISIDMA
BOISIDNW
BOISIDSW
BOISIDWE
BRLYIDMA
BUHLIDMA
CLWLIDMA
CSFRIDMA
DECLIDMA
DWNYIDMA
DYTNIDMA
EAGLIDNM
EDHZIDMA
EMMTIDMA
FKLNIDMA
FRTHIDMA
GAVLIDOl
GDNGIDMA
GLFYIDMA
GRACIDMA
HALYIDMA
HGMNIDMA
IDCYIDMA
IDFLIDMA
INKMIDMA
JERMIDNM
KMBRIDMA
KTCHIDMA
KUNAIDMA
LAPWIDOl
LHSPIDMA
LSMNIDMA
LSTNIDSH
MCCMIDMA
MDTNIDMA
MELBIDMA
MRDNIDMA
MRTGIDMA
MTHOIDMA
MTHOIDSO
MTPLIDMA
NMPAIDMA
WIRE CENTER
POCATELLO
BLACKFOOT
TWIN FALLS
POCATELLO
BOISE
BOISE
BOISE
BOISE
BURLEY
TWIN FALLS
CALDWELL
TWIN FALLS
BURLEY
POCATELLO
POCATELLO
BOISE
TWIN FALLS
EMMETT
POCATELLO
IDAHOFALLS
GRANGEVL
TWIN FALLS
MT HOME
POCATELLO
KETCHUM
TWIN FALLS
BOISE
IDAHOFALLS
POCATELLO
TWIN FALLS
TWIN FALLS
KETCHUM
BOISE
LAPWAI
POCATELLO
RIGBY
LEWISTON
POCATELLO
BOISE
MELBA
BOISE
MURTAUGH
MT HOME
MT HOME
POCATELLO
NAMPA
ILEC
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
CLLI
NPMOIDMA
PCTLIDMA
PCTLIDNO
PSTNIDMA
PYTTIDMA
RBRTIDMA
RGBYIDMA
RIRIIDMA
RVSDIDMA
RXBGIDMA
SDSPIDMA
SHLYIDMA
SHSHIDMA
STARIDNM
THTCIDMA
TWFLIDMA
WESRIDMA
WNDLIDMA
MLCYIDXC
LEDRIDXC
NFRKIDXC
SLMNIDXC
ABRDIDXC
CSCDIDXC
DNLYIDXC
HMDLIDXC
HRBNIDXC
MCCLTDXC
MRNGIDXC
NWMDIDXC
PARMIDXC
WLDRIDXC
EKBNIDXC
FRLDIDXX
FILRIDAA
HLSTIDXC
STATIDMA
CRALIDXX
GENSIDXX
HYLKIDXX
KLLGIDXX
MSCWIDXX
ORFNIDXC
PNHRIDXA
PSFLIDXX
RTHDIDXX
WIRE CENTER
NEW PLYMTH
POCATELLO
POCATELLO
POCATELLO
PAYETTE
RIGBY
RIGBY
IDAHOFALLS
BLACKFOOT
IDAHOFALLS
POCATELLO
IDAHOFALLS
TWIN FALLS
BOISE
POCATELLO
TWIN FALLS
WEISER
TWIN FALLS
MALAD
LEADORE
SALMON
SALMON
ABERDEEN
CASCADE
DONNELLY
HOMEDALE
HORSEHBEND
MCCALL
MARSING
NEWMEADOWS
PARMA
WILDER
ELK BEND
FRUITLAND
FI LER
HOLLISTER
ST ANTHONY
COERDALENE
GENESEE
HAYDENLAKE
KELLOGG
MOSCOW
OROFINO
KELLOGG
POST FALLS
RATHDRUM
ILEC
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
ALBION TELEPHONE CO. DBA ATC COMMUNICATIONS
CENTURYTEL OF IDAHO, INC. DBA CENTURYLINK
CENTURYTEL OF IDAHO, INC. DBA CENTURYLINK
CENTURYTEL OF IDAHO, INC. DBA CENTURYLINK
CITIZENS TELECOM IDAHO-FRONTIER COMM OF IDAHO
CITIZENS TELECOM IDAHO-FRONTIER COMM OF IDAHO
CITIZENS TELECOM IDAHO-FRONTIER COMM OF IDAHO
CITIZENS TELECOM IDAHO-FRONTIER COMM OF IDAHO
CITIZENS TELECOM IDAHO-FRONTIER COMM OF IDAHO
CITIZENS TELECOM IDAHO-FRONTIER COMM OF IDAHO
CITIZENS TELECOM IDAHO-FRONTIER COMM OF IDAHO
CITIZENS TELECOM IDAHO.FRONTIER COMM OF IDAHO
CITIZENS TELECOM IDAHO-FRONTIER COMM OF IDAHO
CITIZENS TELECOM IDAHO-FRONTIER COMM OF IDAHO
CUSTER TELEPHONE COOPERATIVE, INC.
FARMERS MUTUAL TELEPHONE CO.
FILER MUTUAL TELEPHONE CO.
FILER MUTUAL TELEPHONE CO.
FREMONTTELCOM CO
FRONTIER COMMUNICATIONS NORTHWEST, INC. - ID
FRONTTER COMMUNTCATTONS NORTHWESI rNC. - rD
FRONTIER COMMUNICATIONS NORTHWEST, INC. . ID
FRONTIER COMMUNICATIONS NORTHWEST, INC. .ID
FRONTIER COMMUNICATIONS NORTHWEST, INC. - ID
FRONTIER COMMUNICATIONS NORTHWESI INC. - ID
FRONTTER COMMUNTCATTONS NORTHWESI rNC. - rD
FRONTIER COMMUNICATIONS NORTHWEST, INC. - ID
FRONTIER COMMUNICATIONS NORTHWEST, INC. - ID
CLL!
SNPNIDXX
STMRIDXX
WRLKIDXC
MNDKIDXC
PAULIDXC
RPRTIDXC
GLFYIDCO
GLFYIDCO
IRWNIDXC
WIRE CENTER
SANDPOINT
ST MARIES
WARM LAKE
MINIDOKA
PAUL
RUPERT
PRAIRIE
TIPANUK
IRWIN
ILEC
FRONTIER COMMUNICATIONS NORTHWEST, INC. - ID
FRONTIER COMMUNICATIONS NORTHWEST, !NC. - 1D
MIDVALE TELEPHONE EXCHANGE, INC.
PROJECT MUTUAL TELEPHONE COOP. ASSOCIATION, INC.
PROJECT MUTUAL TELEPHONE COOP. ASSOCIATION, INC.
PROJECT MUTUAL TELEPHONE COOP. ASSOCIATION, INC.
RURAL TELEPHONE CO.
RURALTELEPHONE CO.
SILVER STAR TELEPHONE CO., INC.
Officer Biographv for Global Connection lnc.
David Skoeen, CEO
David, a twenty year Telecommunications veteran, joined Global Connection as COO in October of 2009
and was promoted to CEO is January 2010. Prior to joining Global Connection, Dave was Director and
General Manager for Verizon Prepaid. ln that role, he led the SfOOfU+ business unit and was
responsible for all functions including Sales, Marketing, Finance and Operations. Before being named
General Manager, Dave was Director of Marketing and Operations for MCI Prepaid.
ln addition to his responsibilities with the Prepaid organization, Dave held many other positions during
his twenty year career with MCI/Verizon including Access Cost Management auditor, Senior Manager of
Small Business Operations and Director of Business Development for Small Business and Call Center
Services.
Dave graduated with a BBA - Finance, with distinction, from the Henry B. Tippie College of Business at
the University of lowa in 1989.