20201109Comments.pdf

MATT HUNTER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. 10655
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Street Address for Express Mail:
I I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF Q LINK WIRELESS,
LLC'S APPLICATION TO EXPAND ITS
ELIGIBLE TELECOMMUNICATIONS
CARRIER SERVICE AREA
CASE NO. QLW-T-20-01
COMMENTS OF THE
COMMISSION STAF'F
STAFF OF the Idaho Public Utilities Commission, by and through its Attorney of
record, Matt Hunter, Deputy Attomey General, submits the following comments.
BACKGROUND
On August 21,2020, Q LINK WIRELESS, LLC ("Q LINK" or o'Company") applied to
expand its Eligible Telecommunications Carrier ("ETC") service area to provide Lifeline service
to additional qualifring Idaho households. Q LINK also requests to participate in the Idaho
Telecommunications Service Assistance Program ("ITSAP"). The Lifeline program is intended
to provide more affordable telecommunications service benefits to eligible low-income
customers through the federal Universal Service Fund ("USF") and ITSAP. Idaho participates in
the residential Lifeline program pursuant to ldaho Code $ 56-90 I . See Order No. 2 1 71 3.
The Application
Q LINK is a Delaware limited liability company with its principal place of business in
Dania, Florida. The Company provides wireless Lifeline service to eligible Idaho Lifeline
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1STAFF COMMENTS NOVEMBER9,2O2O
customers utilizing the Sprint Spectrum L.P. (Sprint") and T-Mobile USA, Inc. ("T-Mobile")
wireless networks.
Q LINK was designated a Lifeline-only ETC by the Commission in Order No. 32995,
dated March 13,2014. See Case No. QLW-T-13-01. In that Order, Q LINK was restricted to
providing federal Lifeline service to the wire centers listed in Exhibit 6 of the Company's
Application.
In this Application, the Company seeks to expand its ETC designated service area as
described in Exhibit 2 of the Application. Sprint and T-Mobile provide wireless coverage in the
proposed service area. The Company also requests authority to participate in the State's ITSAP
progftlm which the Company did not seek in its previous ETC designation application.
Q LINK's Lifeline Service Offerings
The Company offers two Lifeline plans for qualified customers. One Non-Tribal Lifeline
Service Plan and one Lifeline Tribal plan. Exhibit 3. Q LINK allows customers to purchase
additional minutes on-line. Q LINK's plans include a free handset and domestic long-distance
service. A detailed description of the Company's Lifeline plans is attached to the Application as
Exhibit 3.
STAFF ANALYSIS
Staff has reviewed Q LINK's Application and recommends Commission approval. Staff
has conducted an analysis of the Company's compliance with the federal Telecommunications
Act of 1996, FCC regulations and orders, and Commission Order No. 29841.
Public Interest Considerations
Staff typically focuses on two considerations when analyzingwhether a common
carrier's ETC Application is in the public interest. First, Staff determines whether the Company
contributes to Idaho funds. Second, Staff analyzes whether the Company's Application raises
"cream skimming" concerns.I
I ooCream skimming" occurs when a telecommunications carrier seeks ETC designation for only part of a rural
telephone company's study area, leaving less profitable customers without service.
STAFF COMMENTS 2 NOVEMBER 9,2020
In the Company's Application, Q LINK confirmed that it has complied with the
conditions of its ETC designation and will continue to do so. Application at 3. Since the
Company was approved as an ETC in Idaho, the Company has paid into the appropriate Idaho
programs, specifically the ITSAP and the 9-l-1 program, and asserts it will comply with any
future reporting requirements deemed appropriate for competitive telecommunications providers.
Application at3-4. The Comprury requests ETC designation everywhere that its underlying
carrier provides service. Therefore, there is no risk of "cream skimming." Staff believes
Q LINK satisfies the public interest considerations.
STAFF RECOMMENDATION
Based on its review of the Company's Application, Staff believes that the Application
demonstrates the Company's commitment to fulfill the obligations of a Lifeline-only ETC in
Idaho. The Company will provide all universal services supported by the federal USF
throughout its service territory, and the Company's Application does not raise public interest
concerns. The Commission has designated several other companies statewide ETC status since
originally granting Q LINK's ETC designation. See Case Nos. SAG-T-19-01 and GLO-T-18-01.
Therefore, Staff does not see an issue with expanding the Company's ETC designation to the
wire centers listed in Exhibit 2. Currently, the Commission has granted six wireless ETCs access
to participate in the State's ITSAP program, so Staff supports allowirg Q LINK to participate in
the ITSAP program. Staff believes Q LNK's Application to expand its ETC service area is in
the public interest and should be approved for the new wire centers listed in Exhibit 2. Staff also
supports Q Link's request to participate in the ITSAP.
Respectfully submitted this q.4 day of Nov ember 2020I
Matt Hunter
Deputy Attorney General
Technical Staff: Daniel Klein
i :umisc/comments/sagt I 9. I ejdk comments
STAFF COMMENTS NOVEMBER9,2O2O3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 9TH DAY OF NOVEMBER 2020,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. QLW-T-20-0L, By E-MAILING A COpy THEREOF, TO THE
FOLLOWING:
LANCE JM STEINHART
LANCE JM STEINHART PC
1 725 WINDWARD CONSOURSE
STE 150
ALPHARETTA GA 3OOO5
E-MAIL : Isteinhar:t(#)tel ecomco unsel.corr
SECRET
CERTIFICATE OF SERVICE