20230322Application.pdf

BEFORE THE STATE OF IDAHO
DEPARTMENT OF TELECOMMUNICATIONS AND CABLE
GO MD USA LLC
Petition for Designation as an Eligible
Telecommunications Carrier in THE STATE
OF IDAHO for the Limited Purpose of
Providing Lifeline Service to Qualifying
Customers
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) D.T.C. Docket No.
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PETITION OF GO MD USA LLC FOR DESIGNATION AS AN ELIGIBLE
TELECOMMUNICATIONS CARRIER IN THE STATE OF IDAHO FOR THE
LIMITED PURPOSE OF OFFERING LIFELINE SERVICE TO QUALIFIED
HOUSEHOLDS
Apollo Arcallana
Manager
GO MD USA LLC
3385 Airways Blvd STE 201
Memphis TN, 38116
[phone]
[e-mail]
March 18, 2023
RECEIVED
2023 March, 22 10:00AM
IDAHO PUBLIC
UTILITIES COMMISSION
GMD-T-23-01
TABLE OF CONTENTS
I.INTRODUCTION...............................................................................................................1
II.COMPANY OVERVIEW.....................................................................................................2
III.THE COMMISSION HAS JURISDICTION OVER DESIGNATION OF WIRELESS
ETCS....................................................................................................................................4
IV.THE COMPANY MEETS THE REQUIREMENTS FOR ETC DESIGNATION..................4
A.GO MD USA LLC Wireless Is a Common Carrier...................................................6
B.GO MD USA Will Offer the Services Supported by Federal Universal Service . 6
C.GO MD USA Will Offer the Services Designated for Support Using a
Combination of Its Own Facilities and Resale........................................................7
D.GO MD USA Will Provide GO MD USA Mobile-Branded Service Throughout
Its Designated Service Area.....................................................................................8
E.The Company Will Advertise the Availability of GO MD USA Mobile Services
and Charges Using Media of General Distribution.................................................8
F.GO MD USA Will Comply with Service Requirements Applicable to the Support
It Receives................................................................................................................9
G.GO MD USA Will Comply with Any Applicable Two-Year and Five-Year Plan
Requirements...........................................................................................................9
H.Consumer Protection and Service Quality Standards..............................................10
I.Ability to Remain Functional During Emergencies.................................................10
J.GO MD USA Is Financially and Technically Capable............................................10
K.Terms and Conditions of Proposed Lifeline Offering...............................................11
L.GO MD USA Mobile’s Offerings Will Comply with Lifeline Certification and
Annual Re- certification Requirements..................................................................12
M.Prevention of Waste, Fraud and Abuse...................................................................13
N.Department Lifeline Requirements.........................................................................15
V.DESIGNATING GO MD USA AS AN ETC WOULD PROMOTE THE PUBLIC
INTEREST.........................................................................................................................16
A.Advantages of GO MD USA Mobile Lifeline Plans..............................................17
B.Benefits of Competitive Choice..............................................................................18
VI.ANTI-DRUG ABUSE CERTIFICATION..........................................................................18
VII.CONCLUSION..................................................................................................................19
LIST OF EXHIBITS:
Exhibit 1 – Verification
Exhibit 2 - Proposed Lifeline Plans
Exhibit 3 - Service Area Zip Codes
Exhibit 4 - Sample Advertising
Exhibit 5 – Financial Statements
Before THE STATE OF
IDAHO
DEPARTMENT OF TELECOMMUNICATIONS AND CABLE
GO MD USA LLC
Petition for Designation as an Eligible
Telecommunications Carrier in THE STATE
OF IDAHO for the Limited Purpose of
Providing Lifeline Service to Qualifying
Customers
)
)
)
)D.T.C. Docket No.
)
)
)
I.INTRODUCTION
GO MD USA LLC dba GO MD USA (“GO MD USA” or the “Company”), by its
undersigned counsel, and pursuant to Section 214(e)(2) of the Communications Act of 1934, as
amended (the “Act”)1 and Sections 54.101 through 54.2072 of the Rules of the Federal
Communications Commission (“FCC”),3 and the rules of the IDAHO Department of
Telecommunications and Cable (the “Department”), including the filing requirements for
Lifeline service providers,4 hereby submits this Petition for Designation as an Eligible
Telecommunications Carrier (“ETC”) in THE STATE OF IDAHO. The Company seeks ETC
designation for the limited purpose of providing Lifeline service under the brand
1 47 U.S.C. § 214(e)(2).
2 47 C.F.R. §§ 54.101-54.207.
3 GO MD USA files this Petition in accordance with the rules adopted by the FCC in the 2012 Lifeline Reform
Order. See Lifeline and Link Up Reform and Modernization, Lifeline and Link Up, Federal-State Joint Board on
Universal Service, Advancing Broadband Availability Through Digital Literacy Training, WC Docket Nos. 11-42
and 03-109, CC Docket No. 96-45, WC Docket No. 12-23, Report and Order and Further Notice of Proposed
Rulemaking, FCC 12-11 (rel. Feb. 6, 2012) (“2012 Lifeline Reform Order”).
name “GO MD USA Mobile” to qualifying IDAHO consumers subject to the service areas
served by the Company’s underlying wireless carriers, AT&T and T-Mobile.
As demonstrated herein, and as certified in Exhibit 1 to this Petition, the Company meets
all the federal and Commonwealth statutory and regulatory requirements for designation as an
ETC in IDAHO. Grant of this Petition, moreover, would advance the public interest because it
would enable the Company to commence much needed Lifeline services to low- income IDAHO
residents as soon as possible. Accordingly, the Company respectfully requests that the IDAHO
Department expeditiously approve this Petition.
All correspondence, communications, pleadings, notices, orders and decisions relating to
this Petition should be addressed to:
II.COMPANY OVERVIEW
Apollo Arcallana
Manager
GO MD USA LLC
201 Airways Blvd STE 201
Memphis TN, 38116
(88) 818-9220
[e-mail]
GO MD USA LLC is a South Dakota limited liability company with a principal address at
3385 Airways BLVD STE 201, Memphis, TN 38116. GO MD USA LLC provides, among other
things, resold wireless telecommunications services operating in IDAHO and other states, using
the GO MD USA Mobile brand name and other brand names.
GO MD USA’ parent company, GO MD USA LLC (“GO MD USA”), is a connectivity
company headquartered in Tennesse that has served as a disruptive force in mobile teleheath
technologies. In 2023, GO MD USA entered the retail wireless business by creating GO MD USA
Mobile brand and in 2023, acquiring the GO MD USA Mobile brand as well as other brands and
customer assets. Now, using its subcontracted licensed wireless spectrum assets, GO MD USA is
building the nation’s first virtualized, cloud-native, Open Mobile Telehealth Mobile Network-
based 5G broadband network. To facilitate the buildout, GO MD USA will be entering into
multi-year agreements with multiple partners. Because GO MD USA is actively sub-
contracting wireless facilities around the country, it is well positioned to identify
opportunities to target build-outs in under-served areas.
Even as the 5G network partner relationship are expanding, GO MD USA will be
competing in the retail wireless space and is in the process of seeking to be an approved
provider in the Federal Communications Commission’s Affordable Connectivity Program
(“ACP”).
Under the GO MD USA Mobile, GO MD USA will use AT&T and T-Mobile wireless facilities
to provide discounted mobile broadband service in all 50 states and the territories of Washington
D.C. and Puerto Rico, including plans bundling voice, text messaging, and mobile broadband
services.5 Available GO MD USA Mobile branded plans include talk, text, and data at various
data speeds under the ACP’s monthly $30 subsidy for eligible consumers. GO MD USA will be
submitting an application for ETC designation pending with the FCC (for the states of Alabama,
Connecticut, Delaware, Florida, New Hampshire, North Carolina, and the District of Columbia,
the “Non- Jurisdictional States”). GO MD USA will be seeking designated as a wireless ETC in
IDAHO and other 46 state, and will seeking authorition by the California Public Utilities
Commission to provide California LifeLine service, and plans to file for ETC status in other
states over time.
GO MD USA now seeks an ETC designation in IDAHO so that it can (i) serve low-
income IDAHO customers, (ii) supplement the amount of support available to
5 See 47 C.F.R. § 54.1602(b) (“a bundle of broadband internet access service along with fixed or mobile voice
telephony service, text messaging service, or both” is an EBB-eligible plan).
ACP customers and (iii) invite new, underserved customers to benefit from Lifeline and other
federal support programs. GO MD USA’ Lifeline-supported plans will be offered to prepaid
customers under the GO MD USA Mobile brand, a recognized and trusted provider in this
market segment. GO MD USA Mobile prepaid wireless plans are affordable, easy to use, and
attractive to low- income consumers, providing them with connectivity that has become
indispensable to participating in 2023 and beyond society and opportunities. GO MD USA
Mobile customers can choose from several affordable prepaid calling plans and handsets and
have access to high-quality, responsive customer service. GO MD USA Mobile prepaid plans
start as low as $10 per month and can be refilled by contacting GO MD USA directly.
III.THE COMMISSION HAS JURISDICTION OVER DESIGNATION OF
WIRELESS ETCS
Section 214(e)(2) of the Act provides state public utility commissions with the primary
responsibility for the designation of ETCs.6 Under the Act, a state public utility commission,
like the Commission, with jurisdictional authority over ETC designations must designate a
common carrier as an ETC if the carrier satisfies the requirements of Section 214(e)(1).
Therefore, the Commission has the authority to designate GO MD USA as an ETC. As
demonstrated below, GO MD USA fulfills the requirements to be designated as an ETC in
IDAHO.
IV.THE COMPANY MEETS THE REQUIREMENTS FOR ETC DESIGNATION
A application for ETC designation in IDAHO must meet specific federal statutory and
regulatory requirements. As demonstrated below, GO MD USA meets the requirements for
ETC designation by the FCC pursuant to Section 214(e)(2) of the Communications Act. These
6 47 U.S.C. § 214(e)(2).
include: (1) a certification that the applicant offers or intends to offer all services
designated for support by the FCC pursuant to section 254(c) of the Communications Act; (2) a
certification that the applicant offers or intends to offer the supported services on a common
carrier basis either using its own facilities or a combination of its own facilities and/or resale of
another carrier’s services; (3) a description of how the applicant advertises the availability of
the supported services and the charges therefor using media of general distribution; (4) a
detailed description of the geographic service area for which the applicant requests to be
designated as an ETC; and (5) a certification that neither the applicant, nor any party to the
application, is subject to a denial of federal benefits pursuant to the Anti-Drug Abuse Act of
1988.7In addition, an applicant seeking designation as an ETC solely for the purpose of
offering Lifeline service must: (1) certify that it will comply with the service requirements
applicable to the support that it receives; (2) demonstrate its ability to remain functional in
emergency situations; (3) demonstrate its ability to satisfy applicable consumer protection and
service quality standards; and (4) demonstrate that it is financially and technically capable of
providing Lifeline service.
8Finally, prior to designating a carrier as an ETC, the Commission must determine
whether such designation is in the public interest.
9 When making a public interest determination,
7 47 U.S.C. § 214(e)(1) and (5); 47 C.F.R § 54.201(d)(1) and (2); 47 C.F.R § 54.207(a).
8 47 CFR § 54.202(a). Section 54.202(a)(ii) requires carriers seeking ETC designation that is not limited to Lifeline service to submit a five-year plan that describes proposed improvements to the carrier’s network throughout the
proposed service area. Although GO MD USA is not seeking high cost support in this Petition, it is expanding its
network through partner relationships and contracts 5G network in accordance with certain FCC-approved .
9 47 U.S.C. §214(e)(6); 47 C.F.R. § 54.202(b).
A.the Commission considers the benefits of increased consumer choice and the
unique advantages and disadvantages of the applicant’s service offerings.10GO MD
USA Is a Common Carrier
GO MD USA provides, among other things, commercial mobile radio services (CMRS)
that are regulated pursuant to the common carrier requirements of the Communications Act.
11 Accordingly, the Company meets the common carrier requirement for ETC designation pursuant to
Section 214(e)(1) of the Act and Section 54.201(d) of the FCC’s rules.
B.GO MD USA Will Offer the Services Supported by Federal Universal
Service
Pursuant to Section 54.101(a) of the FCC’s rules, GO MD USA’ voice service provides
the following: (1) voice grade access to the public switched network or its functional equivalent;
(2) minutes of use for local service at no additional charge to end users; (3) access to the
emergency services provided by local government or other public safety organizations, such as
911 and enhanced 911, to the extent the local government in an eligible carrier’s service area has
implemented 911 or enhanced 911 systems; and (4) toll limitation services to qualifying low-
income consumers.12 As defined in Section 8.1(b) of the FCC’s rules, GO MD USA also
provides mobile broadband internet access service to consumers.13
10 See, e.g., Virgin Mobile ETC Designation Order in the States of IDAHO, Connecticut, Delaware, New Hampshire and
the District of Columbia, WC Docket 09-197, Order, 25 FCC Rcd 17797, 17799, ¶ 6 (WCB 2010).
11 See 47 U.S.C. § 153(11) (defining a common carrier as “any person engaged as a common carrier for hire, in
interstate or foreign communications by wire or radio........”; 47 U.S.C. §332 (c)(1)(A) (treating commercial
mobile
service providers as common carriers).
12 47 C.F.R. § 54.101(a); see also 47 U.S.C. § 214(e)(1)(A).
13 See 47 C.F.R. § 8.1(b).
C.GO MD USA Will Offer the Services Designated for Support Using a
Combination of Its partners Facilities and Resale
GO MD USA, through the GO MD USA Mobile brand, offers the supported services -
voice telephony service and broadband Internet access service - meeting the standards set in the
FCC’s rules.14 GO MD USA will be providing and will provide mobile voice, text messaging,
and broadband services to low-income consumers. The various Lifeline service plans that will be
available to qualifying low-income IDAHO residents are described in Exhibit 2.
In general, Section 214 requires ETCs to provide services using their facilities, at least in
part. GO MD USA is in a unique position to increase wireless competition and serve low-
incomer consumers. GO MD USA Mobile service plans are will be supported by AT&T and
T-Mobile’s networks. This will allow GO MD USA to immediately introduce new Lifeline
options for IDAHO consumers as soon as the Department approves this Petition. At the same
time, GO MD USA is building additional partner relationship in advanced nationwide 5G
network serives. The Company will be launching 5G broadband service in over 80 cities
(including in IDAHO) 5 In areas of IDAHO where service on GO MD USA’ subcontracted
network is not yet available or where the Company does not yet offer Lifeline products on its
partner networks, GO MD USA will provide service on a resale basis on the networks of AT&T
and/or T-Mobile. Accordingly, pursuant to 47 U.S.C. § 214(e)(1)(A) and 47
C.F.R. § 54.101(b), GO MD USA will offer GO MD USA Mobile-branded services that are
designated for federal universal support using a combination of its own facilities and/or resale of
another carrier’s services.
14 See 47 C.F.R. § 54.101(a).
Because GO MD USA is deploying facilities-based wireless
D.voice and broadband services in IDAHO and other states, there is no
need for GO MD USA to obtain an approved FCC Compliance Plan
in accordance with the 2012 Lifeline Reform Order.16GO MD USA
Will Provide GO MD USA Mobile-Branded Service Throughout
Its Designated Service Area
Pursuant to 47 U.S.C. § 214(e)(1) and 47 C.F.R. § 54.201(d), as an ETC, GO MD USA
will provide service in the same 50-state footprint where it plans to offers ACP service – this
includes the entire geographic boundary of THE STATE OF IDAHO subject to coverage limits
of underlying carriers and GO MD USA’ partner networks. Further, pursuant to 47
C.F.R. § 54.202(a)(1)(i), the Company commits to provide service throughout its proposed
service area on a timely basis to all customers making a reasonable request for service where
facilities are available. GO MD USA requests ETC designation that is statewide in scope to
allow the Company to provide Lifeline service wherever its underlying, facilities-based
providers have wireless coverage. The current IDAHO coverage footprint by zip code is
attached hereto as Exhibit 3.
E.The Company Will Advertise the Availability of GO MD USA Mobile
Services and Charges Using Media of General Distribution
Pursuant to 47 U.S.C. § 214(e)(1)(B) and 47 C.F.R. § 54.201(d)(2), the Company will
advertise the availability of GO MD USA Mobile-branded voice, text messaging, and broadband
services through various marketing channels that may include direct mail, email, local and
community outreach events, and targeted online electronic advertising. In addition, the
availability of GO MD USA.
16 See 2012 Lifeline Reform Order, ¶ 368.
Mobile Lifeline service will be publicized in ways that are reasonably designed to reach those
who will likely qualify for the service. The Company’s marketing efforts will be consistent with
and in compliance with Department rules. Samples of the Company’s Lifeline advertising are
attached hereto as Exhibit 4.
F.GO MD USA Will Comply with Service Requirements Applicable to the
Support It Receives
Pursuant to 47 C.F.R. § 54.202(a)(1)(i), GO MD USA will comply with the service
requirements applicable to the supported services it will be offering in the identified service
areas. GO MD USA Mobile plans will be offered in IDAHO initially by reselling AT&T and/or
T-Mobile service, and in the future will also be supported by GO MD USA’s own 5G network
facilities when feasible. These providers’ networks are operational and largely built out. Thus,
the Company will be able to commence offering its Lifeline service to all locations served by its
underlying carriers very soon after receiving approval from the Department.
G.GO MD USA Will Comply with Any Applicable Two-Year and Five-Year Plan Requirements
Pursuant to 47 C.F.R. § 54.202(a)(1)(ii), a common carrier seeking designation as a
Lifeline-only ETC is not required to submit a five-year network improvement plan as part of its
application for designation as an ETC. GO MD USA is in a unique position, however, because it
is working on buidling its own facilities-based 5G wireless network through partnerships
we are in the process of deploying its 5G broadband service to 40% of the U.S. population
on September 1, 2023 and scheduled to deploy 70% of the U.S. population by December 15,
2023 and (using certain low-band spectrum) to 85% of the population of each Partial
Economic Area by July 1, 2024. GO MD USA commits to providing service consistent with
the requirements of any other support mechanism pursuant to which it is authorized to receive
support in the future.
H.Consumer Protection and Service Quality Standards
The Company commits to comply with all applicable consumer protection and service
quality standards for universal service programs. As stated in 47 C.F.R. § 54.202(a)(3), a
wireless applicant’s commitment to comply with the Cellular Telecommunications and Internet
Association’s Consumer Code for Wireless Service (“CTIA Consumer Code”) will satisfy this
consumer protection and service quality requirement. GO MD USA commits to fully
complying with the CTIA Consumer Code.
I.Ability to Remain Functional During Emergencies
The Company’s services are able to remain functional in emergency situations as
required by 47 C.F.R. Section 54.202(a)(2). GO MD USA’ partner 5G network operates in a
cloud- native environment that is not encumbered by traditional technology and will be more
flexible and resilient in the event of service outages. In addition, GO MD USA relies on mobile
virtual network operator (MVNO) partner networks that are designed to remain functional even
without external power sources, are able to re-route traffic around damaged facilities, and can
manage traffic spikes that may occur in emergency situations.
J.GO MD USA Is Financially and Technically Capable
As part of the 2012 Lifeline Reform Order, the FCC amended its rules to require a carrier
seeking designation as a Lifeline-only ETC to demonstrate that it is financially and technically
capable of providing the supported Lifeline service in compliance with all of the low-income
program rules.17 GO MD USA satisfies these criteria.
GO MD USA is financially stable and capable of honoring its service obligations to
customers, as shown in Exhibit 5, as well as meeting its federal and state regulatory obligations.
17 See 2012 Lifeline Reform Order, ¶ 387; see also 47 C.F.R. § 54.202(a)(4).
The Company will not rely exclusively on revenues from the provision of Lifeline services for
its operating revenues. The Company also has access to additional capital resources from its
parent and affiliate companies. The Company’s financial resources position the Company to
expand its operations to serve currently unserved/underserved eligible low-income IDAHO
consumers and increase competition.
In addition, the proposed Lifeline offerings will be overseen by a team of personnel with
substantial industry experience with the requirements of the federal Lifeline program and
marketing to the low-income consumer sector.
K.Terms and Conditions of Proposed Lifeline Offering
The Company has the ability to provide all services supported by the universal service
program, as detailed in 47 C.F.R. § 54.101(a), throughout IDAHO. The Company further
affirms that its Lifeline-supported voice services will meet or exceed the minimum service
standards set forth in 47 C.F.R. § 54.408, including as such standards are updated going
forward. GO MD USA Mobile-branded Lifeline-supported broadband services will also meet
the minimum service standards set forth in 47 C.F.R. § 54.408 for mobile broadband internet
access services, including for service speed and data usage allowance, as such standards are
updated going forward. To the extent GO MD USA provides devices for use with Lifeline-
supported broadband service, such devices will meet the equipment requirements set forth in 47
C.F.R. § 54.408(f), and GO MD USA will not impose an additional or separate tethering charge
for mobile data usage below the minimum standard.
Attached hereto as Exhibit 2 is a summary table of the Company’s proposed Lifeline
service offerings, showing that Lifeline customers can receive 1,000 voice minutes, 1,000 text
messages, and 4.5 gigabytes (GB) of data per month at a net cost of $0.00 after application of
Lifeline support. Customers will also be able to purchase additional minutes or data as needed.
In addition to wholly-supported or discounted wireless services, prepaid Lifeline customers will
be able to receive an upgraded handset at an additional charge or SIM card offer, as well as
access to voice mail, caller I.D., call forwarding, 3-way calling, and call waiting features at no
additional charge. Customers may use their minutes to place domestic long-distance calls at no
additional charge, and calls to the Company’s customer service are free with no deduction of
available minutes. Calls to 911 emergency services are always free, regardless of service
activation or availability of minutes.
L.GO MD USA Mobile’s Offerings Will Comply with Lifeline Certification
and Annual Re-certification Requirements
Customers interested in obtaining information on the Lifeline program will be directed to
a toll-free telephone number and to the Company’s website, which will contain information
regarding the Company’s Lifeline service plans, including a description of the Lifeline program
and eligibility criteria. GO MD USA will use multiple outreach methods including but not
limited to nonprofit partnerships, phone, online, and in person enrollments through Lifeline
events. Section 54.410 of the FCC’s rules requires ETCs to certify and verify a Lifeline
customer’s initial and continued eligibility. GO MD USA will rely on the National Verifier and
the National Lifeline Accountability Database (“NLAD”), both administered by the Universal
Service Administrative Company (“USAC”), to determine an applicant’s eligibility for Lifeline
service and ACP services. GO MD USA will require all GO MD USA Mobile’s Lifeline
applicants to complete the standard Lifeline and ACP application forms in the National Verifier
environment. The standard Lifeline and ACP
application complies with the disclosure, certification, and information collection
requirements in 47 C.F.R. § 54.410(d).18For applicants verified as being eligible by USAC’s
National Verifier and NLAD, GO MD USA will complete enrollment by transmitting the
required information into NLAD as required by Section 54.404(b)(6) of the FCC’s rules. In
addition, at the time of enrollment, the Company will notify the applicant that the prepaid
service must be personally activated by the subscriber and the subscriber must use their service
every thirty (30) days in order to maintain their Lifeline benefit and ACP benefits.
GO MD USA will also comply with Sections 54.410(f) of the FCC’s rules governing
annual subscriber re-certification of eligibility and will coordinate with USAC’s National
Verifier and NLAD systems to manage additional de-enrollments related to USAC-administered
benefit transfers and failure to re-certify.
M.19Prevention of Waste, Fraud and Abuse
The Company recognizes the importance of safeguarding the Universal Service Fund
(“USF”), and has implemented measures and procedures to prevent duplicate Lifeline and ACP
benefits being awarded to the same household. GO MD USA Mobile Lifeline offerings will
comply with the requirements of the NLAD and section 54.404 of the FCC’s rules. As part of
the application process, the National Verifier queries the NLAD for every enrollment to
determine whether a prospective subscriber is currently receiving a Lifeline service or ACP
Service from GO MD USA or any other
18 FCC Wireline Competition Bureau Provides Guidance on Universal Forms for the Lifeline Program, WC Docket No.
11-42, Public Notice, “Wireline Competition Bureau Provides Guidance on Universal Forms for the Lifeline Program,”
DA 18-161 (rel. Feb. 20, 2018). The standard application/certification forms are available on USAC’s website (see
USAC, Lifeline Forms, http://www.usac.org/li/tools/forms/default.aspx).19 47 C.F.R. §§ 54.405(e), 54.410(f).
ETC, and whether anyone else living at the prospective subscriber’s residential address is
currently receiving Lifeline service or ACP services..
Consistent with federal regulations, the Company will not seek USF reimbursement for
new subscribers until they have activated the service, either by initiation and/or actual use of the
service, and will de-enroll any subscriber that has not used the Company’s Lifeline service or
ACP services as set forth in 47 C.F.R. § 54.407(c)(2). An account will be considered active if
the authorized subscriber establishes usage, as “usage” is defined by 47 C.F.R. § 54.407(c)(2),
during the specified timeframe, currently a period of thirty (30) days, or during the notice period
set forth in 47 C.F.R. § 54.405(e)(3), currently a period of fifteen (15) days. In accordance with
47 C.F.R.§ 54.405(e)(3), GO MD USA will provide the subscriber advance notice when a
subscriber’s failure to use the Lifeline service or ACP services within the notice period will
result in service termination for non-usage. Customers that have been deactivated may
participate in the Company’s Lifeline service or ACP services in the future by reapplying and re-
establishing eligibility.
To further protect the integrity of the USF, GO MD USA contracts with third party
vendors to backstop USAC’s own processes and procedures. First, the Company will use
telgoo5.com . (telgoo5.com) software to process Lifeline applications and ACP applications.
Among other things, Emerios uses third-party verification sources (currently the Lexis Nexis
LEXID service) to validate a prospective customer’s identity. Emerios also validates the
Company’s subsidy data to prevent duplicate subsidies. In addition, the Company has
established a back- office real time review (“RTR”) process to be completed before a Lifeline
application is passed to the National Verifier to qualify a customer. This process involves
specially trained operations analysts (who have no financial stake in whether an application is
successful) individually confirming the information entered into the application and supporting
documentation to, among other things, confirm the identities of the sales agent and the customer
by reviewing pictures of them in real time during the application process and review the
customer’s identification and address for anomalies. GO MD USA has hired experienced staff
and a third party company to provide RTR for our Lifeline enrollments. This third party
company has substantial experience running RTR for other Lifeline providers.
N.Department Lifeline Requirements
GO MD USA represents that it will comply with the Department’s rules and orders that
are applicable to wireless ETCs. Specifically, GO MD USA will meet the reporting
requirements and consumer safeguards set forth in the Department Lifeline Requirements. As
such, within 60 days of designation as an ETC and prior to offering Lifeline service in IDAHO,
GO MD USA will submit the following information to the Department: (1) Lifeline application
form; (2) advertising and marketing materials that GO MD USA plans to use in IDAHO; (3)
rates, terms, and conditions of its Lifeline service offerings in IDAHO; (4) contact information
for the Company’s customer service designee; and (5) the Company’s proposed method and
timing of annual recertifications and a sample recertification notice.20 GO MD USA will comply
with the Department Lifeline Requirements regarding consumer safeguards, including working
with the Department staff to resolve Lifeline subscriber disputes, providing 60 days’ notice to
subscribers and the Department of a planned discontinuance of Lifeline service, and working
with the Department to facilitate a smooth transition of subscribers to an alternative ETC in the
event of a discontinuance of service. The Department Lifeline Requirements direct wireless
ETCs to include the Department’s Consumer
20 The annual recertification process is administered by the National Verifier. GO MD USA will advise customers
that they may need to recertify their eligibility annually if the National Verifier does not automatically do so, in
accordance with 47 C.F.R. § 54.410(f).
Division contact information on the ETC’s website, marketing materials, applications, and terms
and conditions and to advise that the Consumer Division is available to handle Lifeline
complaints on the ETC’s website and in the terms and conditions. GO MD USA will comply
with these requirements to the extent that they are in effect and not waived by the Department.
21GO MD USA also will submit the reports identified in the Department Lifeline Requirements
that are due annually by March 1 (FCC Form 555, report on marketing and promotional
activities, public safety answering point self-certification, and certification that all 911 fees have
been paid) and by July 1 (FCC Form 481, Lifeline terms and conditions, and complaints per
1,000 subscribers). The Company will submit 30-day notices of the events specified in the
Department Lifeline Requirements, will provide copies of final USAC audit reports, and provide
5-business day prior notice of material changes to rates, terms of conditions of Lifeline service.
V.DESIGNATING GO MD USA AS AN ETC WOULD PROMOTE THE
PUBLIC INTEREST
The Department will advance the public interest by designating the Company as an ETC
so that it can offer the GO MD USA Mobile-branded Lifeline services. Americans increasingly
need greater access to voice and broadband services, and low-income IDAHO consumers in
particular are suffering from the lack of affordable and available access. The Company is
currently helping to close the gap by seeking approval to providing service under the ACP and
stands ready to expand consumer choice and continue offering discounted services as a Lifeline
ETC to customers who have come to rely on these benefits. In addition, because GO MD USA is
is planing deploying a new facilities-based wireless 5G network throughout the country over the
next several years, designating GO MD USA as an
21
National Verifier).
ETC will improve its ability to apply for state broadband funding grants, should ETC designation
be required, to increase service in underserved and unserved areas.
A.Advantages of GO MD USA Mobile Lifeline Plans and ACP Plans
Authorizing the Company as a Lifeline ETC in THE STATE OF IDAHO will enable the
Company to provide eligible low-income consumers with access to high quality mobile voice,
text, and data services. This will increase those consumers’ choices in service providers and
service options and make essential communications services more affordable and accessible to
these consumers. Mobile services are overwhelmingly preferred by Lifeline- eligible consumers
who may be able to afford only a single connection, may frequently change residences or places
of employment, and may need the ability to communicate with prospective employers. Some of
these individuals may be experiencing homelessness and rely upon Lifeline service as their
single reliable source of connectivity. Lifeline services also ensure that consumers always have
the ability to contact 911 emergency services should the need arise. The availability of a no-
charge Lifeline service that includes voice minutes, texts, and data is an invaluable resource for
consumers in these circumstances.
GO MD USA Mobile Lifeline service plans provide meaningful options for low-income
consumers because they offer low-cost, reliable alternatives to traditional rate plans. Among the
GO MD USA Mobile Lifeline offerings is a plan with 1,000 voice minutes, 1,000 texts, and 4.5
GB of data available to all qualifying low-income IDAHO consumers for no cost, and a plan
with unlimited voice minutes, unlimited texts and 11 GB of data available to residents of Tribal
lands for no cost. Qualified IDAHO consumers will have the choice to apply their Lifeline
discount to existing GO MD USA Mobile plans.
In addition, GO MD USA Mobile Lifeline plans alleviate customer concerns regarding
deposits, hidden costs, varying monthly charges, and long-term contract issues. GO MD USA
Mobile prepaid plans allow customers to subscribe to voice, text, and data services without the
hurdle of a credit check or the commitment of a contract.
B.Benefits of Competitive Choice
Designating the Company as an ETC also meets the FCC’s stated goals for promoting
competition and increasing customer choice. The FCC has recognized that in non-rural areas,
designation of multiple ETCs is “consistent per se with the public interest.”22 In rural and high-
cost areas, the FCC determined that “designation of competitive ETCs promotes competition and
benefits consumers . . . by increasing customer choice, innovative services, and new
technologies.”23 In the Lifeline context, the entry of additional providers increases competitive
choice for lower-income customers who may not be the focus of wireless carriers’ marketing
efforts. Launching GO MD USA Mobile Lifeline options in IDAHO will add affordable,
innovative mobile wireless choices to the marketplace, and could spur other ETCs to expand and
improve their own Lifeline service offerings. Granting ETC designation to GO MD USA will
promote competition for the benefit of consumers and will have desirable effects upon the
IDAHO market for Lifeline services by making these services more available and accessible,
thereby supporting the goals of universal service.
VI.ANTI-DRUG ABUSE CERTIFICATION
In accordance with section 5301 of the Anti-Drug Abuse Act of 1988, GO MD USA
certifies that no party to the Petition is subject to denial of federal benefits, including FCC
benefits.
22 Federal-State Joint Board on Universal Service, Cellco Partnership d/b/a Bell Atlantic Mobile, Petition for
Designation as an Eligible Telecommunications Carrier, Memorandum, Opinion and Order, CC Docket No. 96-45,
DA 00-2895, ¶ 14 (rel. Dec. 26, 2000).
23 See Western Wireless Corporation Petition for Designation as an Eligible Telecommunications Carrier in the
State of Wyoming, Memorandum Opinion and Order, CC Docket No. 96-45, DA 00-2896, ¶ 17 (rel. Dec. 26, 2000).
VII.CONCLUSION
Based on the foregoing, designation of GO MD USA as an ETC in THE STATE OF
IDAHO accords with the requirements of Section 214(e)(2) of the Act and is in the public interest.
WHEREFORE, GO MD USA respectfully requests that the Department designate GO
MD USA as an ETC in THE STATE OF IDAHO for the purpose of participating in the
Lifeline program.
Respectfully submitted,
Apollo Arcallan
GO MD USA LLC
Manager
EXHIBIT 1: VERIFICATION
I, Apollo Arcallana, Manager of GO MD USA Mobile for GO MD USA LLC, have reviewed
and am familiar with the foregoing Petition for Designation as an Eligible Telecommunications
Carrier in THE STATE OF IDAHO. The statements in the foregoing document are true of my
own knowledge, except as to matters which are herein stated on information and belief, and as to
those matters, I believe them to be true.
GO MD USA Mobile & GO MD USA LLC
Apollo Arcallana
Manager
03/19/2023
EXHIBIT 2: PROPOSED LIFELINE PLANS
Subsidy
Amount
($)
Subsidy Type GO MD USA Mobile Lifeline Plan
Offering
9.25 Lifeline (Federal)1,000 minutes of talk/voice, 1,000 text, and 4.5 GB
of data
34.25 Lifeline (Federal and Tribal)Unlimited talk & text, 11 GB of data
iiii
i
21
9
2021
EXHIBIT 3: IDAHO COVERAGE AREA ZIP CODES
Zip Code Population
1 83646 71,501
2 83301 60,434
3 83709 56,541
4 83686 53,952
5 83642 51,088
6 83854 48,382
7 83440 47,535
8 83401 46,215
9 83704 40,580
10 83201 38,683
11 83605 38,420
12 83815 36,987
13 83501 36,308
14 83651 36,139
15 83687 35,266
16 83706 34,660
17 83634 34,507
18 83607 34,024
19 83616 32,605
20 83713 29,839
21 83705 29,021
22 83221 28,184
23 83402 27,238
24 83814 26,851
25 83843 25,951
26 83404 25,349
27 83714 25,050
28 83442 23,609
29 83702 22,966
30 83835 22,868
31 83202 22,609
32 83647 22,508
33 83338 21,402
34 83716 20,243
35 83406 19,297
36 83204 19,125
37 83318 18,821
38 83864 18,462
39 83703 17,963
40 83858 17,825
41 83617 16,551
42 83644 14,345
43 83669 12,957
44 83350 12,333
45 83333 11,220
46 83316 10,552
47 83661 10,321
48 83274 9,965
49 83263 9,666
50 83712 8,837
51 83805 8,609
52 83672 8,552
53 83341 8,215
54 83619 7,940
55 83445 7,704
56 83638 7,463
57 83860 7,398
58 83801 7,243
59 83856 7,005
60 83467 6,724
61 83861 6,685
62 83330 6,549
63 83544 6,395
64 83211 6,165
65 83336 6,083
66 83660 5,973
67 83328 5,827
68 83455 5,738
69 83530 5,511
70 83676 5,460
71 83355 5,393
72 83340 5,359
73 83869 5,317
74 83655 5,300
75 83628 4,875
76 83536 4,562
77 83252 4,482
78 83210 4,298
79 83313 4,127
80 83641 3,998
81 83276 3,817
82 83254 3,772
83 83422 3,553
84 83347 3,296
85 83352 3,264
86 83448 3,206
87 83837 3,203
88 83639 3,177
89 83648 2,863
90 83540 2,690
91 83334 2,633
92 83522 2,629
93 83332 2,541
94 83427 2,479
95 83611 2,452
96 83850 2,442
97 83245 2,417
98 83241 2,377
99 83420 2,353
100 83844 2,319
101 83871 2,286
102 83849 2,219
103 83236 2,195
104 83539 2,176
105 83822 2,146
106 83845 2,101
107 83452 2,093
108 83629 2,091
109 83622 2,083
110 83612 2,068
111 83250 1,982
112 83226 1,979
113 83851 1,940
114 83855 1,903
115 83832 1,842
116 83335 1,841
117 83434 1,812
118 83876 1,690
119 83873 1,689
120 83654 1,658
121 83810 1,635
122 83823 1,561
123 83624 1,554
124 83323 1,549
125 83833 1,547
126 83320 1,538
127 83804 1,488
128 83811 1,480
129 83251 1,464
130 83623 1,453
131 83346 1,441
132 83234 1,362
133 83342 1,352
134 83857 1,348
135 83615 1,342
136 83286 1,338
137 83213 1,320
138 83344 1,294
139 83237 1,287
140 83353 1,267
141 83349 1,257
142 83626 1,227
143 83847 1,209
144 83852 1,204
145 83631 1,144
146 83450 1,118
147 83228 1,095
148 83535 1,067
149 83537 1,050
150 83839 1,049
151 83610 1,044
152 83444 1,031
153 83541 1,026
154 83255 1,023
155 83553 1,010
156 83451 1,000

EXHIBIT 4: SAMPLE ADVERTISEMENT
AD Sample

EXHIBIT 5: FINANCIAL STATEMENT
GO MD USA LLC has obtained funding commitments
from various partners and believes that it will have
sufficient funding to support its business plans.
Moreover, the company is not reliant on ACP or Life Line
revenue, as these sources of income only pertain to a
small segment of GO MD USA's operations.