20200821Application.pdf

Lance J.M. Steinhart, P.C.
Attomeys At Law
I 725 Windward Concourse
Suite 150
Alpharetta, Georgia 30005
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Also Admitted in New York
Email: [e-mail]
Telephone: (77 0\ 232-9200
Facsimile: [phone]
August 21,2020
VIA EMAIL DELI\MRY
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472West Washin$on
Boise,Idaho 83702 &-uud-T- eo-o,
Re:Q LINK WIRELESS LLC
Application to Expand ETC Service Area
Dear Ms. Hanian:
Attached please find for filing Q LINK WIRELESS LLC's Application to Expand its
Eligible Telecommunications Carrier Service Area in the State of Idaho.
If you have any questions or if I may provide you with additional information, please do not
hesitate to contact me at770-232-7805 or [e-mail]. Thank you.
Respectfu lly submitted,
s/ Heather Kirby
Heather Kirby
Regulatory Specialist
Lance J.M. Steinhart, P.C
Attorneysfor Q LINKWIRELESS LLC
Attachments
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
In the Matter of the Application of
Q LINK WIRELESS LLC to Expand its
Eligible Telecommunications Carrier
Service Area
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Case No.
APPLICATION Or Q LINK WTRELESS TO EXPAND ITS
ELIGIBLE TELECOMMUNICATIONS CARRIER SERVICE AREA
I. INTRODUCTION
Q LINK WIRELESS LLC ("Q LINK" orthe "Company"), by its undersigned counsel, and
pursuant to Section 2la@)Q) of the Communications Act of 1934, as amended (the "Act"),r
Sections 54.101 through 54.207 of the Rules of the Federal Communications Commission
("FCC"),2 and the ldaho Public Utilities Commission's ("Commission") rules and regulations,
hereby files this application to expand Q LINK's Eligible Telecommunications Carrier ("ETC")
service area in the State of Idaho ("Application"). Q LINK was designated as a Lifeline-only ETC
by the Commission by Order No. 32995 dated March 13,2014 in Case No. QLW-T-13-01 ("ETC
Designation Order"). Q LINK requests to expand its ETC service area solely to provide Lifeline
service to additional qualiffing tdaho households through participation in the federal Universal
Service Fund's ("USF") low-income program and the Idaho Telephone Service Assistance
Program ("ITSAP"). The Company does not seek access to USF support for the purpose of
providing service to high-cost areas.3
' 47 U.S.C. $ 2la(eX2)
2 47 C.F.R. $$ 54.101-54.207.
3 Given that Q LINK 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 Q LINK.
1
As demonstrated herein, and as certified by Exhibit I affached hereto, Q LINK continues
to meet all statutory and regulatory requirements for designation as an ETC, including the
requirements outlined in the FCC's Lifeline Modernization Order.a Rapid grant of Q LINK's
request would advance the public interest by enabling the Company to expand the availability of
Lifeline service to many more low-income consumers in Idaho, especially in light of the current
national state of emergency. Accordingly, Q LINK respectfully requests that the Commission
expeditiously approve this Application.
All correspondence, communications, pleadings, notices, orders and decisions relating to
this Application should be addressed to:
Lance J.M. Steinhart
Managing Attorney
Lance J.M. Steinhart, P.C.
Attorneys for Q LINKWIRELESS, LLC
1725 Windward Concourse, Suite 150
Alpharetta, Georgia 30005
[phone] (Phone)
[phone] (Fax)
E-Mail: [e-mail]
II. DESIGNATED SERYICE AREA
ln the ETC Designation Order, the Commission designated Q LINK as an ETC within the
wire centers listed in Exhibit 6 of the Company's application for designation as an ETC filed in
Case No. QLW-T-13-01 ("ETC Application"). Q LfNK provides wireless Lifeline service to
eligible Idaho Lifeline customers utilizing the Sprint Spectrum L.P. ("Sprinf') and/or T-Mobile USA,
Inc. ("T-Mobile") wireless networks. Through its agreement with these underlying carriers, Q
LINK customers benefit from Sprint and T-Mobile's ability to remain functional in emergency
a In the Matter of Lifeline and Link Up Reform and Modernization, Telecommunications Caniers Eligible for
Universal Service Support, Connect America Fund, WC Docket Nos. ll-42,00-197, 10-90, Third Report and Order,
Further Report and Order, and Order on Reconsideration, FCC 16-38 (rel. Apr.27,2016) (hereinafter,"Third Report
and Order" or "Lifeline Modernization Order").
2
situations, 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.
Q LINK seeks to revise its ETC designated service area as described in attached Exhibit 2
to include additional areas where Sprint and T-Mobile have wireless coverage.s Pursuant to 199 IAC
39.2(3)d, Q LINK adopts the exchange area maps on file with the Commission for the exchange
areas listed in Exhibit 2.
III. Q LINK MEETS APPLICABLE REQUIREMENTS
FCC rules, 47 C.F.R. $$ 54.201-54.202 (the "FCC ETC Rules"), set forth the information
that must be contained in an application for designation as an ETC. In its ETC Application,
incorporated herein by reference, Q LINK provided all of the information required by FCC ETC
Rules in effect at the time, including those set forth in the FCC's Lifeline Reform Order.6 The
Commission found in its ETC Designation Order that Q LINK met the requirements for
designation as an ETC. Q LINK has complied with the conditions of its ETC designation and will
continue to do so. In accordance with 47 C.F.R. $ 5a.202(a)(l)(i) and by the attached certification,
Q LINK certifies that it will comply with the service requirements applicable to the support that it
receives. Q LINK hereby also provides additional and updated information as a result ofthe FCC's
Lifeline Modernization Order, which was issued after the Company's ETC Designation Order.
5 For convenience, Exhibit 2 contains the wire centers originally approved and the new proposed wire centers which
are labeled accordingly.
6 In the Matter of Lifeline qnd 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 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 l2-l I (rel. Feb. 6,2012) ("Lifeline Reform Order").
aJ
A. Provision of Supported Services
Q LINK is able to provide all services supported by the universal service program, as
detailed in Section 5a.l0l(a) ofthe FCC's Rules (47 C.F.R. $ 5a.l0l(a)), throughout its requested
service area in the State ofldaho, including broadband Internet access service, a supported service
as of December 2,2016. Q LINK commits that its Lifeline-supported services will continue to
meet or exceed the minimum service standards set forth in 47 C.F.R. $ 54.408, including as they
change going forward. The Company's current Lifeline offering is attached hereto as Exhibit 3.7
Q LINK currently offers these Lifeline wireless plans throughout its existing service area in Idaho.
B. Eligibility Verification
Q LINK determines eligibility of Lifeline subscribers in accordance with 47 C.F.R.
$ 54.410, utilizing the streamlined eligibility criteria implemented by the Lifeline Modernization
Order (see 47 C.F.R. $ 54.409). The FCC has taken steps to curb abuse in the Lifeline program
by establishing the National Lifeline Eligibility Verifier ("National Verifier") which transfers the
responsibility of eligibility determination away from Lifeline providers.s Q LINK will rely on the
National Verifier to determine initial and ongoing eligibility of ldaho Lifeline subscribers. The
National Verifier queries the National Lifeline Accountability Database ('NLAD") for every
enrollment to determine whether a prospective subscriber is currently receiving a Lifeline service
from Q LINK or any other ETC, and whether anyone else living at the prospective subscriber's
residential address is currently receiving Lifeline service. As such, Q LINK complies with the
requirements of 47 C.F.R. $54.404.
7 The Company's terms and conditions can be found at www.glinkwireless.com.
8 See Lifeline Modernizqtion Order, section III.C.
4
C. Non-Usage Policy
Q LINK has updated its non-usage policy in compliance with changes in federal
regulations. Q LINK will not seek reimbursement from the USF for inactive subscribers and will
de-enroll any subscriber that has not used the Company's Lifeline service as set forth in 47 C.F.R.
$ 5a.a07(c)(2). An account will be considered active if the authorized subscriber establishes
usage, as "usage" is defined by 47 C.F.R. $ 5a.a07(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. $ 5a.a05(e)(3), Q LINK will
provide the subscriber advanced notice, using clear, easily understood language, that the
subscriber's failure to use the Lifeline service within the notice period will result in service
termination for non-usage.
ry. EXPAI\SION OF Q LINK'S ETC SERYICE AREA WOULD PROMOTE THE
PUBLIC INTEREST
In its ETC Designation Order, the Commission found that designation of Q LINK as an
ETC would serve the public interest. Expansion of Q LINK's ETC service area will increase the
number of low-income individuals that can benefit from the advantages offered by the Company's
Lifeline service, ensuring they have access to wholly-supported or discounted wireless voice and
broadband service, and will thus further the public interest by providing more low-income Idaho
consumers with low-priced and high-quality services. Q LINK's prepaid wireless plans enable
consumers to enjoy the benefits of wireless telecommunication and mobile broadband access without
being subject to extensive credit reviews and long-term service commitments, which historically
have prevented many low-income Americans, including many ldaho residents, from reaping the full
benefits of the intensely competitive wireless market.
5
Q LINK offers a unique, easy to use, competitive, and highly affordable wireless
telecommunications service, which benefits qualified consumers who either have no other service
alternatives or who choose a wireless prepaid solution in lieu of more traditional service.
Q LINK's Lifeline offerings compare favorably withthose of other competitive ETCs, and provide
Lifeline customers with voice minutes, unlimited text messages, and a data allotment (with current
plan options meeting the voice andbroadband minimum service standards), at no net cost to the
customer after application of Lifeline and ITSAP support. In today's market, 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 greater ability to be contacted by potential
employers, and provides end users with the ability to contact emergency service providers
regardless of location. Mobile service often also serves as a key bridge in closing the homework
gap for students who live in rural areas with limited access to broadband.
Q LINK employs a state-of-the-art proprietary fraud prevention system and does not utilize
agents or third-party representatives for Lifeline enrollment, and does not pay any commissions or
sales incentives on Lifeline sign-ups. This model, which Q LINK has employed for almost the
entirety of its Lifeline operations, was recently endorsed by the FCC which adopted an order to
prevent Lifeline ETCs from paying commissions to agents.e This direct-to-customer model
utilizes technology to protect against waste, fraud and abuse. Q LINK recognized the value of this
approach early and has a detailed, proven methodology that has and will continue to give it a
competitive advantage over its competitors, demonstrating Q LINK's commitment to being a
e See In the Matter of Bridging the Digital Divide for Low-Income Consumers, Lifeline and Link (Ip Reform and
Modernization, Telecommunications Carriers Eligible for Universal Seryice Support, WC Docket Nos. 17-287, I l-
42, 00-197 , Fifth Report and Order, Memorandum Opinion and Order and Order on Reconsideration, FCC 19- l I I ,
(rel. Nov. 14,2019) (*Ftfth Report and Order"),1168.
6
trusted steward with public resources. Q LINK's business model is unique in that the Company is
able to reach unserved and underserved Lifeline-eligible consumers, including in less dense areas
that have not been a focus of other Lifeline providers; in fact, on average, eighty percent (80%) of
Q LINK's customers are new and have not previously participated in the Lifeline program.
With the comprehensive strength and experience of Q LINK's management team, the
Company's proven technology-based business model, and Q LINK's solid history as a Lifeline
provider, Q LINK is uniquely-positioned to meet the needs of Lifeline customers, utilizing the
Company's innovative outreach and high integrity enrollment process, and Q LINK remains
committed to careful stewardship of the Lifeline program. Without question, prepaid wireless
services have become essential for low-income customers, providing them with value for their
money, access to emergency services on wireless devices, and a reliable means of contact for
prospective employers, social service agencies or dependents. Providing Q LINK with the
authority necessary to offer discounted Lifeline services to eligible residents in additional areas of
Idaho undoubtedly promotes the public interest.
V. CONCLUSION
Q LINK submits that the information contained herein, together with the information in
the Company's ETC Application, incorporated herein by reference, demonstrates that Q LINK
continues to meet the requirements for ETC designation and that expansion of Q LINK's ETC
service area would promote the public interest.
7
WHEREFORE, Q LINK respectfully requests that the Commission promptly grant this
Application and expand Q LINK's Lifeline-only ETC service anea as requested herein.
Respectfu lly submitted,
s/ Lance J.M. Steinhort
Lance J.M. Steinhart
Maneging Attorney
Lance J.M. Steinhart, P.C.
Attomeys atlaw
1725 Windward Concourse, Suite 150
Alpharetta, Georgia 30005
[phone] @hone)
[phone] (Fax)
E-Mail: [e-mail]
Attorrcysfor Q LINKWIRELESS, LLC
August 21,2020
8
EXHIBIT 1
CERTIFICATION
CERTIFICATION
I, Issa Asad, hereby depose and state that I am the Chief Executive Officer ("CEO") of
Q LINK WIRELESS LLC ("Q LINK"); that I have read the Application of Q LINK to expand
its Eligible Telecommunications Carrier Service Area and know the contents thereof; and that
the contents are true and correct to the best of my knowledge and belief. I further certiff that Q
LINK will comply with the service requirements applicable to the low-income universal service
support that it receives.
Q LINK WIRELESS LLC
By
Issa Asad, CEO
EXTIIBIT 2
Proposed Service Area
STATE cLU ItEC NAME RATE CENTER NEW (N)
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ID ARCOIDXC ALBION TELEPHONE CO. DBA ATC COMMUNICATIONS ARCO
ID ELBAIDXC ALBION TELEPHONE CO. DBA ATC COMMUNICATIONS ELBA N
ID HLBKIDXC ALBION TELEPHONE CO. DBA ATC COMMUNICATIONS HOLBROOK N
ID HOWEIDXC ALBION TELEPHONE CO. DBA ATC COMMUNICATTONS ARCO
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ID CMBRIDXC CAMBRIDGE TELEPHONE COMPANY COUNCIL N
ID CMBRIDXC CAMBRI DGE TELEPHON E COMPANY INDIAN VLY N
ID LWMNIDXC CAMBRIDGE TELEPHONE COMPANY LOWMAN N
ID BRUNIDXC CENTURYTEL GEM STATE INC-ID DBA CENTURYLINK - ID BRUNEAU
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ID RCFDIDXC CENTURYTEL GEM STATE INC-ID DBA CENTURYLINK - ID RICHFIELD
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ID FRFDIDXC CITIZENS TELECOM IDAHO.FRONTIER COMM OF IDAHO FAIRFIELD N
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ID RGNSIDXC CITIZENS TELECOM IDAHO-FRONTIER COMM OF IDAHO RIGGINS N
ID SPFDIDXC CITIZENS TELECOM IDAHO-FRONTIER COMM OF IDAHO SPRINGFLD
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IIIIIIII
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ID RVSDIDMA QWEST CORPORATION BLACKFOOT
ID RXBGIDMA QWEST CORPORATION IDAHOFALLS
ID SDSPIDMA QWEST CORPORATION POCATELLO N
ID SHLYIDMA QWEST CORPORATION IDAHOFALLS
ID SHSHIDMA QWEST CORPORATION TWIN FALLS
ID STARIDNM QWEST CORPORATION BOISE
ID THTCIDMA QWEST CORPORATION POCATELLO N
ID TWFLIDMA QWEST CORPORATION TWIN FALLS
ID WESRIDMA QWEST CORPORATION WEISER
ID WNDLIDMA QWEST CORPORATION TWIN FALLS
ID GLFYIDCO RURAL TELEPHONE CO.ATLANTA
ID GLFYIDCO RURAL TELEPHONE CO.PRAIRIE
ID GLFYIDCO RURAL TELEPHONE CO.TIPANUK
ID SHOPIDXC RURAL TELEPHONE CO.SHOUP N
ID FRDMWYXC SILVER STAR TELEPHONE CO., INC ALPINE N
ID IRWNIDXC SILVER STAR TELEPHONE CO., INC.IRWIN N
ID WAYNIDXC SILVER STAR TELEPHONE CO., INC WAYAN N
EXHIBIT 3
Current Lifeline Offering
Q LrNK WTRELESS LTFELINE OFFERTNG EFFECTIyE lznnog
LIFELINE NON.TRIBAL:
1000 Minutes & 3 GB Data (O LINK ALWAYS ON)
1000 anytime minutes per month
Unlimited text and picture messaging
3 GB data per month
Minutes & data do not rollover
Net cost to Lifeline customer: $0
LIFELINE TRIBAL:
Unlimited Talk & Text & 3 GB Data (O LINK ALWAYS ON TRIBAL)
Unlimited anytime voice minutes per month
Unlimited text and picture messaging
3 GB data per month (no rollover)
Net cost to Tribal Lifeline customer: $0
ADDITIONAL AIRTIME
Available for purchase at https://qlinkwireless.com/members/carilquickpurchase.aspx
AII packages include:
. Free Wi-Fi enabled Smartphone, or data-capable tablet/hotspot device for qualified
applicants. Free calls to Q LINK Customer Service. Free calls to 9l I emergency services. Free access to Voicemail, Caller-ID, and Call Waiting features
' Voice minutes may be used for Domestic Long Distance at no extra cost