20190222final_order_no_34254.pdf

Office of the Secretary
Service Date
February 22,2019
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF NEWMAX,LLC DBA INTERMAX )CASE NO.NEW-T-18-01
NETWORKS FOR DESIGNATION AS AN )ELIGIBLE TELECOMMUNICATIONS )ORDER NO.34254
CARRIER )
On November 5,2018,Newmax,LLC dba Intermax Networks ("Intermax"or the
"Company")applied to the Commission for an Order designating the Company as an eligible
telecommunications carrier (ETC)in certain Idaho census blocks.The Company seeks ETC
designation so it can receive support it was provisionally awarded under the Federal
Communications Commission (FCC)Connect America Fund (CAF)Phase II Auction.'The
Commission issued a Notice of Application and Modified Procedure on December 19,2018.
Order No.34220.
On January 8,2019,Commission Staff filed comments recommending the
Commission approve the Application in the public interest.The Coeur D'Alene Tribe (the
"Tribe"),on the other hand,filed a Petition to Intervene,and a separate Protest and Comment
and Request for Hearing.On January 15,2018,the Company replied to the Tribe's filings by
asking the Commission to approve the Application and grant it ETC status without further
proceedings or a hearing.On January 22,2019,the Commission considered the above outlined
filings during its public decision meeting and granted the Tribe's intervention,denied its request
for a stay and for a technical hearing,and amended the Notice of Modified Procedure to extend
the comment deadlines.See Order No.34237 at 1.
Based on a thorough review of the record established in this case,the Commission
now approves the Company's Application.
BACKGROUND
A.The Connect America Fund
On January 31,2018,the FCC issued an Order on Reconsideration concerning its
Connect America Fund initiative,which enabled the FCC to move forward with the CAF II
Auction,in which service providers competed to receive up to $1.98 billion to offer voice and
'The Company filed a Supplemental Statement on Local Usage Plans with the Commission on December 3,2018.
ORDER NO.34254 1
broadband service in unserved high-cost areas.2 That Order followed a series of orders
establishing the details of the CAF II Auction.3 Under this program the FCC will disburse up to
$198 million annually for providers -including competitive providers such as competitive local
exchange carriers,cable operators,fixed wireless ISPs,satellite broadband,or alternative
providers such as electric utilities and governmental entities -to deploy broadband networks in
high-cost unserved price cap areas.
On August 28,2018,the FCC announced the Auction 903 results.The FCC
designated Intermax as a winning bidder in specific Census Block Groups in Idaho.Funding is
contingent on Intermax demonstrating that it meets the FCC's technical and financial
qualifications,includingobtaining ETC designation from the Idaho Public Utilities Commission
by February 25,2019,for the service area.ETC designation by this Commission is,therefore,a
prerequisite for Intermax's eligibilityfor funding.4
B.ETC Designation Requirements
Under the federal Telecommunications Act of 1996 (the "Federal Act"),a carrier
designated as an ETC is eligible to receive federal support from the federal Universal Service
Fund (USF)."47 U.S.C.§214(e).This Commission has the authority,under the Federal Act,to
grant ETC designations within Idaho.47 U.S.C.§214(e)(2).Authority for the Commission to
designate ETC status is also provided in Idaho law-the Idaho Telecommunications Act of 1988
(the "Idaho Act")-and expounded upon in prior Commission orders.See Idaho Code §§62-
610D(1),62-615(l);Order No.29841 ("ETC Requirements Order").Under this authority,this
Commission has granted ETC designations to numerous carriers in Idaho,including wireless
carriers.See e.g.Order Nos.32586,32645,and 34163.
2 Connect America Fund,et at,Order on Reconsideration,33 FCC Rcd 1380 (2018).
3 See,e.g.,Connect America Fund et al.,Report and Order and Further Notice of Proposed Rulemaking,31 FCC
Rcd 5949 (2016).
4 Auction 903 Results Notice,para.15,n.11.
6 The FCC established the federal USF with the intent to make adequate,efficient communications available
nationwide,at reasonable charges.In the Matter of Lifeline and Link Up Reform and Modernization,Lifeline and
Link Up,Federal-State Joint Board on Universal Service,AdvancingBroadband Availability Through Digital
Literacy Training("Lifeline and Link Up Reform Order")27 F.C.C.R.6656,at 6660-62 (Feb.6,2012);47 U.S.C.§254(b).Lifeline is a program supported by the USF that provides monthly discounts to eligible low-income
subscribers in order to maintain access to communications networks.Lifeline and Link Up Reform Order,27
F.C.C.R.6656 at 6662-63.High-cost support through the Connect America Fund,addresses initial connections for
services in high-cost areas.See In the Matter Connect America Fund,27 F.C.C.R.4040,17672-73 (Nov.18,2011)
(goals for high-cost support include ensuring and advancing the availability of communications services).Idaho has
an analogous state USF program,established in Idaho Code §§62-610 and 62-610A-610F,and a Lifeline program
knows as the Idaho Telecommunications Service Assistance Program (ITSAP).
ORDER NO.34254 2
To qualify as an ETC,an applicant must satisfy several requirements established in
federal and state law.47 U.S.C.§214(e);Order No.29841.The Federal Act requires the
applicant to be a "common carrier,"offering services supported under Section 254(c)of the
Federal Act "using its own facilities or a combination of its own facilities and resale of another
carrier's services,"unless otherwise granted FCC forbearance.47 U.S.C.§§153(10),
214(e)(1)(A),160(a)(3)(FCC has regulatory flexibility to forbear application where consistent
with public interest).The Federal Act also requires that the applicant "advertise the availability
of such services and the charges therefor using media of general distribution."47 U.S.C.§
214(e)(l)(B).
Under the Federal Act,state commissions are granted the authority to determine
whether ETC designation is "consistent with the public interest,convenience,and necessity."47
U.S.C.§214(e)(2).In evaluating this public interest element,this Commission has generally
considered two factors.See Order Nos.33002 at 2-3;and 33226 at 3.First,the Commission
evaluates whether the carrier contributes to state assistance programs such as ITSAP and the
Idaho Telecommunications Relay Services (TRS)program.Id;Idaho Code §61-1301.Second,
the Commission considers if the designation is sought for only part of a rural telephone
company's study area,thus leaving some (perhaps less profitable)customers without service.
See Order Nos.33002 at 2-3;and 33226 at 3.Such practice,known as "cream skimming,"has
been determined by this Commission to be contrary to the public interest.Id
Federal regulations include the following additional requirements,which the
Commission has adopted by reference,in evaluating applications for ETC designation:(1)
compliance with service requirements applicable to support received;(2)submission of a plan
for proposed improvements or upgrades to the network (where applicable);(3)demonstrated
ability to remain functional in emergencies without an external power source;(4)demonstrated
willingness to satisfy consumer protection and service quality standards;(5)financial and
technical capability to provide Lifeline service;and (6)notice to affected Tribes where
designation is sought for any part of Tribal lands.See 47 C.F.R.§54.202;"ETC Requirements
Order"No.29841 at 5 and 16.
For applicants seeking Lifeline-only ETCs,the FCC has waived the requirement to
submit a network improvement and upgrade plan,noting that such ETCs do not receive funds to
improve or extend their networks.Lifeline and Link Up Reform Order,27 F.C.C.R.6656,¶386.
ORDER NO.34254 3
This Commission-which requires a two-year network improvement plan and progress report
(Order No.29841 at 18)where applicable-has also waived the requirement where a Lifeline-
only ETC is requested.Order No.33002 at 3,citing Lifeline and Link Up Reform Order,27
F.C.C.R.6656,¶386.
THE APPLICATION
Newmax,LLC dba Intermax Networks is an Idaho LLC.Intermax stated it is a
facilities-based,locally-owned,independent Internet,voice,data,and IT Managed Services
provider.Application at 3.It provides a variety of "fixed terrestrial broadband services,
including fiber,cable Internet,and fixed point to multi-pointwireless broadband services,"and
Voice over Internet Protocol (VoIP)technology.Id.
Intermax participated in,and was provisionallyselected as,a recipient of funds from
the CAF II Auction.Intermax's receipt of the funds is contingent on it meeting the FCC's
technical and financial qualifications,which includes obtaining ETC designation in Idaho.Id.at
2.Intermax stated it must obtain designation as an Idaho ETC in specific eligible Census Block
Groups by February 25,2019,as set forth in Exhibit A to the Company's Application.Intermax
asserted that 47 U.S.C.§214(e)(2),47 C.F.R.§§54.201,et seq.,Idaho Commission Order No.
29841,and IDAPA 31.46.01 et seq.,govern its designation as an ETC.
Intermax claimed it satisfies all FCC and Commission rules and requirements for
ETC designation,claiming it:(1)is a common carrier that will offer high-speed Internet access
service and unlimited VoIP under local usage plans comparable to those offered by incumbent
local exchange carriers;(2)can provide continuous universal services outlined in 47 C.F.R.§
54.101(a);(3)will advertise the availability of its universal service offering through media of
general distribution;(4)will notify and engage Tribal governments according to 47 C.F.R.§
54.10046,7;(5)has demonstrated that ETC designation is consistent with the public interest,
convenience,and necessity;(6)is committed to providing supported service based on the criteria
6 In IDÍCTmaX's Supplemental Application,filed with the Commission on December 3,2018,Intermax included a
letter sent to the Tribe stating that it "would like to engage the Coeur d'Alene Tribe in discussions regarding ...
pursuant to 47 C.F.R.§54.1004:(i)A needs assessment and deployment planning with a focus on Tribal
community anchor institutions;(ii)Feasibility and sustainability planning;(iii)Marketing services in a culturally
sensitive manner;(iv)Rights of way processes,land use permitting,facilities siting,environmental and cultural
preservation review processes;and (v)Compliance with Tribal business and licensing requirements."
7 For clarification,47 C.F.R.§54.202-and our Order No.29841 (see pages 5 and 16)-govern tribal notification at
this stage.If and when the Company actually receives its provisionallygranted CAF award,47 C.F.R.§54.301 et
seq.will govern Tribal reporting and consultation.
ORDER NO.34254 4
in Order No.29841;(7)has a reasonable amount of back-up power to operate without an
external power source (with the ability to re-route traffic around damaged facilities or in
emergency);and (8)will comply with annual reporting requirements set forth in Order No.
29841.Id.at 5 and the Supplemental Statement on Local Usage Plans.
Intermax certified that "all federal high-cost support provided to [it]for service areas
in Idaho will be used for the provision,maintenance,and upgrading of facilities and services for
which the support was intended,consistent with Section 47 U.S.C.§254(c)."Id.at 9.
THE COMMENTS
A.Staff
Staff reviewed Intermax's Application and conducted an analysis of the Company's
fulfillment of the Federal Telecommunications Act of 1996,the Connect America Fund
requirements,and Commission Order No.29841.In addition,Staff analyzed the public interest
benefits of awarding the Company ETC designation.
Staff determined that Intermax either fulfilled or met waiver requirements of each
requirement to be an ETC in Idaho.Specifically,Staff determined that:(1)Intermax satisfied
the public interest considerations related to Idaho ETC designation;(2)a two-year network
improvement and progress report is not required due to the FCC's waiver of the five-year plan as
part of its ETC designation process;and (3)the Company has the ability to remain functional in
emergency situation,in accordance with Order No.29841 and 47 C.F.R.§54.202(a)(2).
Staff further determined the Company meets all other requirements of the
Commission,set forth at Appendix 1 of Order No.29841.Specifically,Intermax:(1)is a
common carrier as defined by 47 U.S.C.§214(e)(1);(2)committed to providing universal
services;(3)committed to advertise the availability of its service offerings;(4)committed to
describe local usage plans;(5)stated its Application is in the public interest;(6)committed to
maintaining the ability to provide supported services;(7)committed to remain functional in
emergencies;and (8)committed to maintain sufficient consumer protection and service.
Accordingly,Staff recommended the Commission approve the Company's Application.
B.Tribe's Protest and Comments
The Tribe submitted a Petition to Intervene,and a Protest and Comment and Request
for Hearing.The Tribe stated its interest arises because Intermax seeks ETC designation on four
Census Blocks on the Coeur d'Alene Reservation,over which the Tribe has sovereign
ORDER NO.34254 5
jurisdiction.See Tribe's Petition to Intervene,and a Protest and Comment and Request for
Hearing at 1.
The Tribe argued that Intermax failed to properly apply for ETC designation in Idaho
and on Tribal lands because Intermax:(a)did not commit to provide Lifeline services (including
whether it would provide Lifeline services through its own facilities,or through resold services);
(b)did not demonstrate it is authorized to do business on the reservation;(c)did not adequately
meet the Tribal consultation provisions of the FCC's regulations;and (d)filed an Application
that may not be in the public interest because the Tribe has applied for a competing ETC
designation with the FCC.Id.at 2-6.
The Tribe asked for an order:(1)allowing the Tribe to intervene as a party;(2)
holding the case in abeyance "until ...the Tribe certifies to the Commission that Intermax is
qualified to do business on the reservation";(2)determining whether sufficient notice was
provided to the Tribe;(3)determining whether Intermax would provide Lifeline services and,if
so,whether it would provide the services through its own facilities or through resold services;
and (4)determining whether Intermax has substantively engaged with the Tribe according to
federal regulation.See Id.at 2-5 and 47 C.F.R.54.1004(d).The Tribe requested a hearing under
Commission Rule 203.Id.at 6.
C.Company's Reply
The Company replied that the Tribe "does not present issues material to the
Commission's consideration of Intermax's application"for ETC designation,and,therefore,no
hearing or further proceedings are necessary."See Newmax,LLC DBA Intermax Reply
Comments at 1.
The Company argued that the Tribe's requests should be denied because:(1)the
Company committed to complying with federal and state law if granted ETC designation(but did
not have to state every legal requirement to which it is subject,including its participation in
Lifeline);(2)while federal law permits ETCs to offer services through their own facilities or a
combination of their facilities and the resale of another carrier's services,the Commission need
not decide exactly how the Company would provide the services-i.e.,whether only through its
own facilities,only through resold services,or througha combination of both-as a condition to
granting the Company ETC status;(3)the Company did not have to register to do business and
obtain a business license from the Tribe to become an ETC;rather,the Company would obtain
ORDER NO.34254 6
requisite Tribal permissions before doing business on the Tribe's lands;(4)the Tribe cited an
incorrect and irrelevant FCC regulation to argue that when the Company provides service to
Tribal lands,it is subject to consultation obligations as a condition to receiving ETC designation,
instead of annual reporting requirements related to Tribal service;and (5)approval of the
Company's Application should not be withheld simply because the Tribe has applied for ETC
designationwith the FCC,because only one recipient of support from the CAF Phase II Auction
will be in each census block.Id.at 2-4.
While the Company did not object to the Tribe intervening,it denied there was a need
for additional process or hearing.Instead,the Company recommended that the Commission
approve the Application,as it is in the public interest and all federal and state laws had been
complied with.Id.at 5.
D.Tribe's Supplemental Comments
The Tribe filed supplemental comments on February 7,2019,stating,in summary,
that:(1)the Digital Divide is causing a looming crisis in Indian Country because the Lifeline
Program is under attack by the FCC;(2)the D.C.Circuit remanded the FCC's Fourth Report and
Order because "traditional carriers have left the market for providing Lifeline services because
they find them unprofitable and the compliance costs too high"";(3)if Intermax chooses to
service the Tribal Census Blocks through resale of other facilities,members of the Tribe would
lose $25 per month in Tier 4 support,potentially leaving Tribal members unable to afford
Intermax's services;(4)while Intermax did state that it will provide Lifeline services,it did so
only in its Reply Comments and through an attorney for the Company who is not licensed to
practice law in Idaho or admitted pro hac vice ;(5)Intermax did not indicate or make a showing
of being able to obtain ETC designation for purposes of receiving Lifeline or Tribal Lifeline
funding support or offerings,or whether it had interfaced with any Tribes related to such
services;(6)the Tribe would like the answer of when Intermax will provide Lifeline services
answered prior to it being granted ETC designation;(7)the Commission should hold a hearing
related to Lifeline and the services the Company purports to provide,at least to those Census
Blocks on Tribal ground;and (8)the issue of whether Intermax will adequately serve the Coeur
*See Coeur d'Alene Tribe Supplemental Comments at 2.
The Commission found,in Order No.34220,that this docket should be processed through modified procedure.
IDAPA 31.01.01.043 states that written comments in modified procedure are an administrative function,which can
be handled by a either a non-attorney or licensed attorney.Rule 43 does not require pro hac vice admission if
written comments are filed by an attorney.
ORDER NO.34254 7
d'Alene Tribe is a question for the Idaho Commission and not,as alleged by the Company,the
FCC.Coeur d'Alene Tribe Supplemental Comments at 1-6.
E.Intermax Supplemental Reply Comments
The Company,on the other hand,replied,in summary,that:(1)the tribe is "sorely
mistaken"in suggesting the FCC rulemaking proceedings and the D.C.Circuit Court's remand
related to the FCC's Lifeline rules,because the rulemaking process related to the Lifeline rules is
not a consideration when determining Intermax's commitment to comply with the Idaho
Commission's rules,or to Lifeline services in the supported census blocks;(2)"[i]t is a
requirement of the FCC's Connect America Fund ('CAF')rules that Intermax offer Lifeline
services to its supported census blocks,and Intermax has committed to do that on two
occasions";(3)the Commission should reject the Tribe's attempts to impose a higher standard
for Intermax than is required by law;and (4)the commitments the Company makes at this point
in the process are what matter,including its commitment to service quality,FCC build-out
milestones,and FCC rules and enforcement and remediation procedures if it does not fulfill its
commitments.Newmax,LLC dba Intermax Networks Supplemental Reply Comments at 1-5.
DISCUSSION AND FINDINGS
The Commission has authority to grant ETC designation to a telecommunications
carrier under federal and state law.47 U.S.C.§214(e);and Idaho Code §§62-610D,62-615(l).
The Commission has reviewed and considered the record in this case,including Intermax's
Application and exhibits,Staff comments,and the reply and supplemental comments.We now
make the followingfindings in granting the Application.
A.Common Carrier,Own-Facilities,and Advertising
We first address requirements listed in §214(e)(l)of the federal Telecommunications
Act.That provision requires an applicant to be a "common carrier"offering services "using its
own facilities or a combination of its own facilities and resale of another carrier's services,"
unless otherwise granted FCC forbearance.47 U.S.C.§§153(10),214(e)(l)(A),160(a)(3).
Intermax stated that it "use a combination of its own network and facilities and resale of another
carrier's services to provide service."Application at 6.Therefore,we find that Intermax is a
facilities-based provider that will use its own facilities and resale of another carrier's services,
which is permissible under 47 U.S.C.§214(e)(l)(A).On the record before us,we find that
Intermax is also a "common carrier."See 47 U.S.C.§153(11);and Application at 5-6.An
ORDER NO.34254 8
applicant seeking ETC designation must also "advertise the availability of such services and the
charges therefor using media of general distribution."47 U.S.C.§214(e)(l)(B).Based on the
record and the Company's assurances,we find this requirement to also be satisfied.Application
at 7.
B.Public Interest and Related ETC Designation Requirements
Under the Federal Act,state commissions shall determine whether granting the
requested ETC designation is "consistent with the public interest,convenience,and necessity."
47 U.S.C.§214(e)(2).
First,Intermax certified that it is
capable of providing (a)voice grade access to the public switched telephone
network;(b)minutes of use for local service providers at no additional charge to
end users;(c)access to emergency services provided by local government or other
public safety organizations (such as 911 and enhanced 911)...and (d)toll-
limitation services for qualifying low-income consumers.Intermax's voice
services interconnect with,and provide voice-grade access to,the Public Switched
Telephone Network,and Intermax relies on local-exchange-carrier partners with
regard to physical interconnection,numbering resources,local number portability,
call termination,and other service.Intermax does not meter local calls and in fact
treats local and non-local calls as equivalents,thereby eliminating the need for
toll-limitation for low-income consumers.
Application at 6.Intermax also committed to offering Lifeline services,as required by FCC
rules.See 47 C.F.R.§54.101(d);Newmax,LLC dba Intermax Networks Reply Comments at 2;
and Newmax,LLC dba Intermax Networks SupplementalReply Comments at 2-3.
We find that the Company's offering of these services in the CAF II Auction awarded
service areas promotes the public interest because the provision of these services will enable
recipients to deploy CAF II Auction funds to high-cost areas of Idaho which are unserved or
underserved and provide investment in facilities and equipment in these areas.This deployment
also furthers the goals of this Commission,and of the FCC,of expanding the reach of digital
connectivity to promote economic growth in rural areas.Further,in pursuit of deployment
Intermax has made a commitment to satisfying all applicable state and federal requirements
related to consumer protection and service quality standards.Application at 8.
We also consider whether the Company would contribute to the appropriate Idaho
funds.Order Nos.33002 at 2-3,33226 at 3.Staff confirmed that Intermax,upon approval and
commencement of business operation in Idaho,will participate in the appropriate Idaho
ORDER NO.34254 9
programs,specifically the Idaho 9-1-1 program and any additional required reporting
requirements for completive telecommunications providers.Staff Comments at 3.We find that
the Company's commitment to participating in the appropriate Idaho programs advances the
public interest.
Next we consider whether the Company is engaged in "cream skimming,"which we
have found to be contrary to the public interest.Order Nos.33002 at 2-3,33226 at 3.We agree
with Staff,because the Company requested ETC designation for entire census blocks where price
cap carriers previouslydeclined support to serve,no cream skimming analysis is required.
We therefore find that granting Intermax ETC designation in the applied for Census
Block Groups satisfies state and federal public interest requirements.
C.RemainingRequirements
Finally,we address the six remaining requirements from federal regulations and our
"ETC Requirements Order."47 C.F.R.§54.202;"ETC Requirements Order"No.29841.
(1)Service Requirements for Support Received.We find that Intermax has
sufficiently committed to meeting these requirements.See Application at 7-8.
(2)Plan for Proposed Improvements or Upgrades to the Network.We agree with
Staff.Because the FCC waived the requirement for a winning bidder to file a five-year plan as
part of the ETC designation process,a network improvement plan is not required under
Intermax's Application.See Order Nos.29841;32501;and Connect America Fund et al.,Report
and Order and Further Notice of Proposed Rulemaking,WC Docket Nos.10-90,14-58,29
F.C.C.R.8769,8801,8095,para.77 (2014).
(3)Ability to Remain Functional in Emergencies.We find the Company has
demonstrated sufficient compliance with this requirement.Application at 8.
(4)Willingness to Satisfy Consumer Protection and Service Quality Standards.We
are satisfied with the Company's assurances as to this requirement.Id at 8.
(5)Financial and Technical Capability.Based on the Company's assurances and
description of its financial and technical qualifications,we also find this requirement to be
satisfied.Id at 3.
(6)Notice to Affected Tribes.For purposes of obtaining ETC designation by this
Commission we find the Company has sufficiently notified and engaged the Tribe according to
47 C.F.R.§54.202,and our Order No.29841 (at pages 5 and 16).Intermax's Application before
ORDER NO.34254 10
this Commission for ETC designation is but one part of its receipt (and continued maintenance)
of high cost USF CAF support and our role at this time is to determine whether Intermax may be
an ETC in Idaho,not determine how,when,and in what precise matter the Company will use
that eligibility in partnering with the Tribe.There are mechanisms both at the Tribal level,and
under the Federal Act for preventing improper practice of business on tribal lands,and for
malfeasance under regulations to the Federal Act,which are enforced by the FCC.See,e.g.,47
C.F.R.§
54.320.!°We would,however,encourage the Company and the Tribe,while
recognizing its sovereignty,to view their relationship as a partnership,and not in an adversarial
fashion,with an aim toward the common end goal of universal service in high-cost support areas,
includingon Tribal lands.
Based on the above findings,we conclude that Intermax has satisfied the federal and
state requirements for designation as an Idaho eligible telecommunications carrier,and we
therefore grant the Application for the Census Block Groups described in Exhibit 1 of the
Company's Application.
ORDER
IT IS HEREBY ORDERED that the Commission approves Intermax's Application
for designation as an eligible telecommunications carrier as discussed herein.
THIS IS A FINAL ORDER.Any person interested in this Order may petition for
reconsideration within twenty-one (21)days of the service date of this Order.Within seven (7)
days after any person has petitioned for reconsideration,any other person may cross-petition for
reconsideration.See Idaho Code §61-626.
io 47 C.F.R.§54.320 requires ETCs receiving universal service high-cost support to,among other things,be
audited,to retain records,to comply with public interest obligations,to meet build-out milestones,and to submit to
ongoing compliance reviews.Failure under the regulations may lead to enforcement proceedings by the FCC,
including penalties,reductions in support amounts,revocation of ETC designation,and suspension or debarment.
ORDER NO.34254 11
DONE by Order of the Idaho Public Utilities Commission at Boise,Idaho this 2
day of February 2019.
PAUL K LLAND ,PRESIDENT
K INE RAPER,COMMISSIONER
ERIC ANDERSON,COMMISSIONER
ATTEST:
Diane M.Hanian
Commission Secretary
I \Legal\TELEPHONE\NEW-T-18-01\NEWTl801FO_sc.doc
ORDER NO.34254 12