20140204Idaho Telecom Alliance Comments.pdf

Idaho Telecom Alliance 2Th FE3 -*
Post Office Box 1638 •Boise,D 83701
208 229 1482 Fax [phone] www idahotelecomelliance org
Idaho Public Utilities Commission
472 W.Washington Street
P.O.Box 83720
Boise,Idaho 83720-0074
RE:Comments regarding Application of Q-Link Wireless LLC for Designation
as an Eligible Telecommunications Carrier
Case No.QLW-T-13-01
Dear Commissioners:
The Idaho Telecom Alliance (“ITA”)submits these comments with regard to the above
referenced matter.As you know,the hA vigorously opposed the application of TracFone
Wireless for designation as an eligible telecommunications carrier.The opposition to that
application revolved around TracFone’s refusal to contribute to the Emergency Communications
Fee in support of Idaho counties’9-1-1 systems or the Idaho Telephone Service Assistance
Fund (“ITSAP”).
Since that time,the majority of applicants for ETC status,whether facilities based or
non-facilities based,and whether or not such carriers provide pre-paid service plans,have
agreed to pay into such funds.The ITA further acknowledges that the payment process for
prepaid wireless services was changed by an amendment to the Emergency Communications
Act requiring collection of the fees at the point of sale.Nevertheless,nowhere in Q-Link
Wireless’application does Q-Link Wireless commit to paying into either fund.
Unless and until Q-Link Wireless commits to paying both the Emergency
Communications Fee and the ITSAP fees,the ITA objects to the granting of ETC status to Q
Link Wireless.Granting such status without the commitment to pay into the funds provides Q
Link Wireless a competitive business advantage over the companies represented by the ITA.
These companies simply ask that all carriers asking for ETC designation in Idaho be subject to
the same rules that the Idaho carriers are subject.
Accordingly,the ITA respectfully requests that the Commission deny the application
unless Q-Link Wireless agrees to be bound by the same rules as other ETC’s in the state of
Idaho.The ITA appreciates the Commission’s consideration of our members’concerns.
Sincerely,
Kate Creswell
Executive Director
Idaho Telecom Alliance