20190125Application.pdf

AIso Admitted in New York
Email : [e-mail]
January 24,2019
VIA OVERNIG HT DELIVERY
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472West Washington
Boise,ldaho 83702
Dear Ms. Hanian
Enclosed please find for filing an original and
Communications, LLC dba TruConnect's Application
Telecommunications Carrier in the State of Idaho.
Re
SAg-T- tQ-o t
Sage Telecom Communications, LLC dba TruConnect
Application for Designation as an Eligible Telecommunications Carrier
Lance J.M. Steinhart, P.C.
Attorneys At Law
I 725 Windward Concourse
Suite 150
Alpharetta, Georgia 30005
:'l Jl 1- 1- 11/tr. f)-t l LLt
i:i:Ji;i 25 Pii 3:t0
Telephone: [phone]
Facsimile: [phone]
two (2) copies of Sage Telecom
for Designation as an Eligible
I have also enclosed an extra copy of this letter to be date stamped and retumed to me in the
enclosed, self-addressed, postage prepaid envelope.
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.
Respectfully submitted,
illrtr*
Heather Kirby
Regulatory Specialist
Lance J.M. Steinhart, P.C.
Attorneys for Sage Telecom Communications, LLC
dba TruConnect
Enclosures
cc: Nathan Johnson
.::,riili5SlCN
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
In the Matter of the Application of CASENO. sKC"- T- t?-o/
SAGE TELECOM COMMUNICATIONS, LLC
DBA TRUCONNECT FOR DESIGNATION AS
AN ELIGIBLE TELECOMMUNICATIONS
CARRIER
Attorneys for Sage Te le com Communicat io ns, LLC
dbo TruConnect
January 24,2019
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APPLICATION OF SAGE TELECOM COMMUNICATIONS, LLC DBA
TRUCONNECT FOR DESIGNATION AS AN
ELIGIBLE TELECOMMUNICATIONS CARRIER
Lance J.M. Steinhart
Managing Attorney
Lance J.M. Steinhart, P.C.
1725 Windward Concourse, Suite 150
Alpharetta, Georgia 30005
[phone] (Phone)
[phone] (Fax)
E-Mail: [e-mail]
II
TABLE OF CONTENTS
INTRODUCTION
BACKGROUND .........
A. Company Overview
B. Proposed Lifeline Offering.
C. Plan EnrolIment..................
D. Prevention of Waste, Fraud and Abuse
E. The Commission Has Jurisdiction to Designate Wireless ETCs
TRUCONNECT SATISFIES THE REQUIREMENTS FOR DESIGNATION
AS AN ETC..........
A. TruConnect Will Provide Service Consistent With the FCC's Grant of
Forbearance from Section 214's Facilities Requirements..
B. TruConnect Is a Common Carrier..
C. TruConnect Will Provide All Supported Services..............
I . Voice Telephony Service.........
2. Broadband Internet Access Services.....
D. TruConnect Requests Designation Throughout its Service Area.............
E. TruConnect Will Advertise the Availability of Supported Services........
F. Service Commitment Throughout the Proposed Designated Service
Area.........-
Ability to Remain Functional in Emergency Situations.....
Commitment to Consumer Protection and Service Quality
Financial and Technical Capability ........
TruConnect Will Comply with the
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J.Lifeline Certification and
Verification Requirements ...............
K. TruConnect Will Comply With All Regulations Imposed By The
Commission.....
IV. DESIGNATION OF TRUCONNECT AS AN ETC WOULD PROMOTE
THE PUBLIC TNTEREST
A. Advantages of TruConnect's Service Offering..
B. The Benefits of Competitive Choice.......
C. lmpact on the Universal Service Fund..........
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.L)V.CONCLUSION..........
TABLE OF EXHIBITS
Exhibit
Certification..I
Proposed Lifeline Offering .2
FCC-Approved Compliance Plan....J
Coverage Area ..........
Sample Advertisement.............
Key Management Bios...........
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
In the Matter of the Application of CASE NO
SAGE TELECOM COMMUNICATIONS, LLC
DBA TRUCONNECT FOR DESIGNATION AS
AN ELIGIBLE TELECOMMUNICATIONS
CARRIER
APPLICATION OF SAGE TELECOM COMMUNICATIONS, LLC DBA
TRUCONNECT FOR DESIGNATION AS AN
ELIGIBLE TELECOMMUNICATIONS CARRIER
I. INTRODUCTION
Sage Telecom Communications, LLC dba TruConnect ("TruConnect", or the "Company"),
by its undersigned counsel, and pursuant to Section Ta@)Q) of the Communications Act of 1934,
as amended (the "Act"),l Sections 54.101 through 54.207 of the Rules of the Federal
Communications Commission ("FCC"),2 and the rules and regulations of the Idaho Public Utilities
Commission ("Commission"),3 hereby submits this Application for Designation as an Eligible
Telecommunications Carrier ("ETC") in the State of Idaho. TruConnect seeks ETC designation
solely to provide Lifeline service to qualifying Idaho consumers; it will not (and is not eligible to)
seek access to funds from the federal Universal Service Fund ("USF") for the purpose of
participating in the Link-Up program or providing service to high cost areas.4
| 47 U.S.C. $ 2la(e)(2)
'? 47 C.F.R. S$ 54.101-54.207
1 See In the Mqtter of the Application of WWC Holding Co., Inc. d/b/a Cellular-one Seeking Designation as an Eligible
Telecommunications Caruier that may Receive F-ederal (lniversal Semice Supporl, OrderNo.2984l (August4,2005)
("Commission Order No. 29841").
a Given that the Company only seeks Lifeline 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 the Company.
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TruConnect requests that its designation as an ETC include the authority to participate in
and receive reimbursement from the Idaho Telephone Service Assistance Program (ITSAP).
As demonstrated herein, and as certified in Exhibit I to this Application, TruConnect meets all the
statutory and regulatory requirements for designation as an ETC in the State of ldaho, including
the requirements outlined in the FCC's Lifeline and Link Up Reform Orders and Lifeline
Modernization Order.6 Rapid grant of TruConnect's request, 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 Commission expeditiously approve this Application for ETC designation.
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 Sage Telecom Communications, LLC dba TruConnect
1725 Windward Concourse, Suite 150
Alpharetta, Georgia 30005
[phone] (Phone)
[phone] (Fax)
E-Mail: [e-mail]
5 In the Matter of Lifeline and Link (/p Reform and Modernization, Lifeline and Link Up, F-ederal-Stale Joint Board
on Universal Service, Advancing Broadband Availabilily Through Digital Literacy Training, WC Docket No. I I -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 l2-11 (rel. Feb. 6,2012) ("Lifeline and Link Up Reform Order").
6 In the Matter of Lifeline and Link Up Reform and Modernizalion, Telecommunication.s Carciers Eligible for
Universal Service Supporl, Connect America Fund, WC Docket No. 1l-42, WC Docket No. 00-197, WC Docket No.
10-90, Third Report and Order, Further Report and Order, and Order on Reconsideration, FCC l6-38 (rel. Apr.27,
2016) (herein afte1"I'hird Report and Order" or "Lifeline Modernization Order").
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II. BACKGROUND
A. Company Overview
TruConnect is a Texas Limited Liability Company,T with its principal office located at ll49
S. Hill Street, Suite H-400, Los Angeles, California 90015. Sage Telecom Communications, LLC
is a subsidiary of TSC Acquisition Corporation ("TSC") and was formerly known as Sage
Telecom, Inc. before a corporate restructuring in 2012. TSC also owns TruConnect
Communications, Inc., formerly Telscape Communications, lnc., and the owners of TSC
separately own TruConnect Mobile, LLC, which sells mobile hotspot devices and low-cost
monthly data plans, as well as TruConnect Technologies, LLC, a mobile data analytics company
that develops data intelligence products and services for wireless carriers, cable operators, content
providers, and application developers.
TruConnect provides prepaid wireless telecommunications services to consumers by using
the underlying wireless networks of Sprint Spectrum, L.P. ("Sprint"), Verizon Wireless ("Verizon"),
and/or T-Mobile USA, Inc. ("T-Mobile") (collectively, "Underlying Carriers") on a wholesale basis
to offer nationwide service. TruConnect obtains from its Underlying Carriers the network
infrastructure and wireless transmission facilities to allow the Company to operate as a Mobile
Virtual Network Operator ("M\rNO"), similar to TracFone Wireless, Inc. ("TracFone") and Virgin
Mobile USA, L.P. ("Virgin Mobile"), who have been granted ETC status by the Commission.8
TruConnect is currently designated as a wireless ETC in Arizona, Arkansas, California, Colorado,
Georgia, Indiana, lowa, Kansas, Kentucky, Louisiana, Maryland, Michigan, Minnesota, Missouri,
7 TruConnect was organized in the State of Texas on December 5,2012.
8 See In the Matter of the Amended Application of TracFone Ll/ireless, Inc. for Designation as an Eligible
Telecommunicalions Carrier in the State of ldaho for the Limited Purposes of Offering Lifeline Service to Qualified
Ilouseholds. Case No. TFW-T-09-01. Order No. 32586 (June 29, 2012) ("TracF'one ETC Order"); In the Matter of
the Pelilion of Virgin Mobile USA for Limited Designation as an Eligible Telecommunications Carrier. Case No.
VMU-T-11-01. Final Order No. 32645 (Sept. 19,2012) ("Virgin Mobile ETC Order").
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Nebraska, Nevada, Ohio, Oklahoma, Pennsylvania, Puerto Rico, South Carolina, Texas, Utah, West
Virginia and Wisconsin. TruConnect has applications for ETC designation pending with the FCC
and in Illinois.
TruConnect's prepaid wireless services are affordable, easy to use, and attractive to low-
income and lower-volume consumers, providing them with access to emergency services and a
reliable means of communication that can be used both at home and while traveling to remain in
touch with friends and family and for contacting prospective employers. TruConnect offers
consumers simple and affordable prepaid calling plans, a variety of prepaid service plans, easy-to-
use handsets and high-quality customer service. Given its pricing and marketing strategy and the
demographics of its customers in other states, TruConnect anticipates that many of its customers will
be from low-income backgrounds and will not previously have enjoyed access to wireless service
because of economic constraints, poor credit history, or sporadic employment. TruConnect does not
conduct credit checks or require customers to enter into long-term service contracts as a prerequisite
to obtaining wireless service.
By providing affordable wireless plans and quality customer service to consumers who are
otherwise unable to afford them, or who were previously ignored by traditional carriers, TruConnect
will expand the availability of wireless services to many more consumers, which is the principal
reason that Congress created the universal service program.
B. Proposed Lifeline Offering
TruConnect has the ability to provide all services supported by the universal service
program, as detailed in Section 5a.l0l(a) of the FCC's Rules (47 C.F.R. $ 5a.l0l(a)) throughout
Idaho. TruConnect intends to be a leader in the prepaid marketplace by offering consumers
exceptional value and competitive amounts of voice and broadband usage. The Company's
Lifeline service offering will provide customers with the same features and functionalities enjoyed
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by all other TruConnect prepaid customers, with one notable exception: TruConnect's prepaid
Lifeline services will not require payment of an out-of-pocket foe by subscribers, but instead,
TruConnect will receive support from the Lifeline program as compensation for providing those
services.
TruConnect commits 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. TruConnect's Lifeline-supported broadband services will also meet the minimum
service standards set forth in 47 C.F.R. $ 54.408 for mobile broadband intemet access services,
including for service speed and data usage allowance, as such standards are updated going forward.
To the extent TruConnect 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
TruConnect 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'sproposed Lifeline service
offerings, showing that Lifeline customers can receive 1,000 voice minutes, unlimited text
messages, and 2 gigabytes (GB) of data per month at a net cost of $0.00 after application of Lifeline
support, or choose a discounted retail plan option with unlimited voice minutes and higher
allotment of data. 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
receive a free handset or SIM card, 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
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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.
As Exhibit 2 demonstrates, the Company's Lifeline offering will not only allow feature-
rich mobile connectivity for qualifring subscribers at no cost to the subscriber, but also will bring
a variety of rate plans into the reach of eligible customers that are comparable in minutes and
features to those available to post-paid wireless subscribers - but at low Lifeline rates and without
a the burden of credit checks or service contracts. TruConnect's prepaid offering will be an
attractive alternative for consumers who need the mobility, security, and convenience of a wireless
phone, but who are concerned about usage charges or long-term contracts.
C. Plan Enrollment
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. Customers may then request that an enrollment form (hereinafter also
referred to as application or certification form) be mailed to them, complete the online application,
download a form from the Intemet or retrieve a form in person at a Company event (or apply
directly through the National Lifeline Eligibility Verifier ("National Verifier"), once implemented
in ldaho). TruConnect utilizes the standard Lifeline application/certification forms as required by
FCC rules, and thus complies with the disclosure and information collection requirements in 47
C.F.R. $ 54.410(d).e Processing of consumers' applications, including review of all application
forms and relevant documentation, will be performed underthe Company's supervision by managers
e FCC lryireline Competition Bureau Provides Guidance on Universal Formsfor the Lifeline Program, WC Docket
No. 1l-42, Public Notice, "Wireline Competition Bureau Provides Guidance on Universal Forms for the Lifeline
Program," DA l8-l6l (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).
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experienced in the administration of the Lifeline program.
In addition, 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. TruConnect will annually re-certify the continued eligibility of all of its Lifeline subscribers
in accordance with federal and Commission regulations. See Exhibit 3 for additional enrollment
information.
D. Prevention of Waste, Fraud and Abuse
TruConnect recognizes the importance of safeguarding the USF. TruConnect has
implemented measures and procedures to prevent duplicate Lifeline benefits being awarded to the
same household. TruConnect complies with the requirements of the National Lifeline
Accountability Database ("NLAD") and section 54.404 of the FCC's rules. As such the Company
(or Eligibility Administrator or National Verifier, where applicable) queries the NLAD for every
enrollmentl0 to determine whether a prospective subscriber is currently receiving a Lifeline service
from TruConnect or any other ETC, and whether anyone else living at the prospective subscriber's
residential address is currently receiving Lifeline service.rl In addition, Company personnel
emphasize the "one Lifeline service per household" restriction in their direct sales contacts with
potential customers.
Moreover, the FCC has taken steps to further curb abuse in the Lifeline program by
establishing the National Verifier, which transfers the responsibility of eligibility determination
'0 With the limited exception of states that have opted out of the NLAD. In those states, the Company will query the
state duplicates database.
tt See Lifeline and Link Up Reform Order\203.
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away from Lifeline providers.12 TruConnect will rely on the National Verifier, once in place, to
determine initial and ongoing eligibility of Idaho Lifeline subscribers.
Consistent with federal regulations, the Company will not seek USF reimbursement for
new subscribers until they have personally 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 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), TruConnect 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. Customers that have been deactivated may
participate in the Company's Lifeline service in the future by reapplying and re-establishing
eligibility.
To further protect the integrity of the USF, TruConnect contracts with a third party Lifeline
service bureau, currently CGM, LLC, to edit all subsidy request data. CGM will process and
validate the Company's subsidy data to prevent: (1) Duplicate Same-Month Lifeline Subsidies
(Double Dip): any name/address that is already receiving a lifeline subsidy from the Company will
be automatically prevented from receiving a second lifeline subsidy in that same month; and (2)
Inactive lines receiving subsidy: CGM's systems compare all subsidy requests to underlying
network status to ensure that subsidies are requested only for active lines. Moreover, TruConnect
has implemented an intemal auditing process to review NLAD and CGM findings as a final layer of
t2 See Lifeline Modernization Order, section III.C
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fraud prevention. Through the processes described above, TruConnect ensures that it does not over-
request from support funds.
E. The Commission Has Jurisdiction to Designate Wireless ETCs.
Section zla@)Q) of the Act provides state public utility commissions with the "primary
responsibility" for the designation of ETCs.r3 Although Section 332(c)(3)(A) of the Act prohibits
states from regulating the entry of or the rates charged by any provider of commercial mobile
service or any private mobile service, this prohibition does not allow states to deny wireless carriers
ETC status.la Therefore, the Commission has the authority to designate TruConnect as an ETC.
Pursuant to this authority, the Commission has designated numerous carriers as ETCs in the State
of Idaho, including wireless carriers.15 Under the Act, a state public utility commission with
jurisdictional authority over ETC designations must designate a common carrier as an ETC if the
carrier satisfies the requirements of Section 2la(e)(l). TruConnect recognizes that Section
2la(e)(l)(A) of the Act states that ETCs shall offer services, at least in part, over their own
facilities and that Section 54.201(i) of the FCC's Rules (47 C.F.R. $ 54.201(i)) prohibits state
commissions from designating as an ETC a telecommunications carrier that offers services
exclusively through the resale of another carrier's services.
However, the FCC has granted forbearance from enforcement of this facilities requirement
to carriers seeking Lifeline-only ETC designation.r6 Section l0(e) of the Act(47 U.S.C. $ 160(e))
provides: "[a] State commission may not continue to apply or enforce any provision of this chapter
that the [Federal Communications] Commission has determined to forbear from applying under
rr 47 U.S.C. $ 2la(e)(2).
t4 USF Order, at 8858-59, fl 145.
ts See e.g., TracFone ETC Order and Virgin Mobile ETC Order
t6 See Lifeline and Link Up Reform Order atl368.
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subsection (a) of this section." As such, the Commission is required by Section l0(e) to act in
accordance with the FCC's grant of forbearance, and therefore, may not apply the facilities-based
requirement to TruConnect. Therefore, the Commission has the authority under Section 2la@)Q)
of the Act to grant TruConnect's request for designation as an ETC throughout the State of Idaho.
III. TRUCONNECT SATISFIES THE REQUIREMENTS FOR DESIGNATION AS AN
ETC
Section 25a@) of the Act provides that, "only an eligible telecommunications carrier
designated under section 2la@) shall be eligible to receive specific federal universal service
support." Section zla@)Q) of the Act authorizes state commissions, such as the Commission, to
designate ETC status for federal universal service purposes and authorizes the Commission to
designate wireless ETCs.rT Section 2la(e)(l) of the Act and Section 54.201(d) of the FCC's rules
provide that applicants for ETC designation must be common carriers that will offer all of the
services supported by universal service, either using their own facilities or a combination of their
own facilities and the resale of another carrier's services, except where the FCC has forborne from
the "own facilities" requirement. Applicants also must commit to advertise the availability and
rates of such services,l8 and provide additional information set forth in 47 C.F.R. $ 54.202(a). As
detailed below, TruConnect satisfies each of the above-listed requirements.
A. TruConnect Wiil Provide Service Consistent with the FCC's Grant of
Forbearance from Section 214's Facilities Requirements
Although Section 214 requires ETCs to provide services using their facilities, at least in
part, the FCC has forborne from that requirement with respect to carriers such as TruConnect. In
the Lifeline and Link Up Reform Order, the FCC granted forbearance from the "own-facilities"
t7 See Federal-Slate Joint Board on Universal Service, First Report and Order, 12 FCC Rcd 8776, 8858-59, fl 145
(1997) (*USF Order").
t8 See 47 U.S.C. $ 2la(e)(1) and 47 C.F.R. S s4.201(dX2).
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requirement contained in Section 2la(e)(l)(A) for carriers that are, or seek to become, Lifeline-only
ETCs, subject to the following conditions:le
(l) the carrier must comply with certain 911 requirements [(a) providing its Lifeline
subscribers with 9ll and E9l1 access, regardless of activation status and availability of
minutes; (b) providing its Lifeline subscribers with E9l l-compliant handsets and replacing,
at no additional charge to the subscriber, noncompliant handsets of Lifeline-eligible
subscribers who obtain Lifeline-supported services; and (c) complying with conditions (a) and
(b) starting on the effective date of this Order]; and
(2) the carrier must file, and the Bureau must approve, a compliance plan providing specific
information regarding the carrier's service offerings and outlining the measures the carrier
will take to implement the obligations contained in this Order as well as further safeguards
against waste, fraud and abuse the Bureau may deem necessary.
In accordance with the Lifeline and Link Up Reform Order, TruConnect filed a Compliance
Plan with the FCC, which the FCC approved on December 26,2012.20 A copy of its FCC-
Approved Compliance Plan is attached hereto as Exhibit 3. TruConnect commits to providing
Lifeline service in Idaho in accordance with its FCC-approved Compliance Plan and in compliance
with applicable state and federal regulations, to the extent amendments thereto may supersede
commitments made in the Compliance Plan.
B. TruConnect Is a Common Carrier
CMRS providers like TruConnect are treated as common carriers.2l
C. TruConnect Will Provide All Supported Services
Through its Underlying Carriers, TruConnect is able to provide all of the supported services
te See Lifeline and Link Up Reform Order at flfl 368, 373, and379.
20 See FCC Public Notice DA 12-2063, https://apps.fcc.gov/edocsJrublic/attachmatch/DA-12-
2063A1 Rcd.pdf.
2t Implementation of Seclions 3(n) and 332 of the Communicalions /cl, Regulatory T'reatment of Mobile Servrces, GN
Docket No. 93-252, Second Report and Order, 9 FCC Rcd 1411 , 1425 n 37 , 1454-55 n 102 (1994) (wireless resellers
are included in the statutory "mobile services" category, and providers of cellular service are common carriers and
CMRS providers);47 U.S.C. $ 332(c)(l)(A) ("mobile services" providers are common carriers); see also PCIA
I'etitionfor F'orbearancefor Broadband PCE WT Docket No. 98-100, (Memorandum Opinion and Order and Notice
of Proposed Rulemaking, 13 FCC Rcd 16857, 169l I fl 1l I (1998) ("We concluded [in the Second Report and Orderf
that CMRS also includes the following common carrier services: cellular service, ... all mobile telephone sewices and
resellers of such services.") (emphasis added).
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required by Section 54.101(a) of the FCC's Rules (47 C.F.R. $ 5a.101(a)) as follows:
1. Voice Telephony Service
As set forth in 47 C.F.R. $ 54.l0l(a)(l), eligible Voice Telephony Services must provide
the following:
Voiqe Grade Access to the Public Switched Tqlephone Network. TruConnect provides
voice grade access to the public switched telephone network ("PSTN") through the purchase of
wholesale CMRS services from its facilities-based underlying carriers.
Local Usage At No Additional Charee. TruConnect offers rate plans that provide its
customers with minutes of use for local service at no additionalcharge.
Access to Emerqency Services. TruConnect provides 9l I and E9l I access for all of its
customers to the extent the local government in its service area has implemented 9ll or E91l
systems. As noted, calls to 911 emergency services will always be free and will be available
regardless of service activation status or availability of minutes. TruConnect also complies with
the FCC's regulations governing the deployment and availability of E9l I compatible handsets.
Toll Limitation. In its Lifeline and Link Up Reform Order, the FCC provided that toll
limitation would no longer be deemed a supported service.22 "ETCs are not required to offer toll
limitation service to low-income consumers if the Lifeline offering provides a set amount of
minutes that do not distinguish between toll and non-toll calls."23 Nonetheless, TruConnect's
offerings inherently allow Lifeline subscribers to control their usage, as its wireless service is
offered on a prepaid, or pay-as-you-go, basis. TruConnect's service, moreover, is not offered on
a distance-sensitive basis and local and domestic long distance minutes are treated the same.
22 See Lifeline and Link Up Reform Order atl367
23 See id. atl49.
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2. Broadband Internet Access Services
Broadband Internet access service ("BIAS") is a supported service as of December 2,2016.
The FCC has stated that BIAS consists of the ability for a user to receive "the capability to transmit
data to and receive data from all or substantially all Internet endpoints, including any capabilities
that are incidental to and enable the operation of the communications service, but excluding dial-
up Intemet access service."24 TruConnect provides BIAS to low-income consumers via resale of
its underlying carriers' mobile services.
D. TruConnect Requests Designation Throughout Its Service Area
TruConnect is not a rural telephone company as defined in Section 153(37) of the Act (47
U.S.C. $ 153(37)). Accordingly, TruConnect is required to describe the geographic area(s) within
which it requests designation as an ETC. TruConnect requests ETC designation that is statewide
in scope (excluding tribal lands), to allow the Company to provide Lifeline service wherever its
underlying, facilities-based providers have wireless coverage. The current zip code coverage
footprint is attached hereto as Exhibit 4. TruConnect understands that its service area overlaps
with rural carriers in ldaho, but maintains that the public interest factors described below justify
its designation in these carriers' service areas, especially because it seeks ETC designation solely
to utilize USF funding to provide Lifeline service to qualified low-income consumers. TruConnect
is not eligible for and does not seek Link-Up or high-cost support.
Therefore, designation of TruConnect as an ETC will cause no growth in the high-cost
portions of the USF and will not erode high-cost support from any rural telephone company. In
fact, the FCC has determined that "[d]esignation of competitive ETCs promotes competition and
benefits consumers in rural and high-cost areas by increasing customer choice, innovative services,
2a See 47 C.F.R. $ 8.2(a).
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and new technologies."25 While federal rules (47 U.S.C. $$ 160, 2la(e)(5) and 47 C.F.R. $
54.207(b)) require that the service area of an ETC conform to the service area of any rural
telephone company serving the same area (the 'oservice area conformance" requirement), the
FCC's Lifeline and Link Up Reform Memorandum Opinion and Order (FCC 13-44 released April
I 5, 2013) authorized forbearance from the service area conformance requirements with respect to
carriers seeking to provide Lifeline-only service.26 In light of this forbearance, the Commission
has the authority to designate ETCs such as TruConnect in rural areas without concern for the
service area conformance requirement.2T
E. TruConnect Will Advertise the Availability of Supported Services
TruConnect will advertise the availability and rates for the services described above using
media of general distribution as required by 47 C.F.R. $ 54.201(d)(2) and the rules adopted by this
Commission. TruConnect's advertising will comply with the requirements set forth in the
Lifeline and Link Up Reform Order, as outlined in TruConnect's Compliance Plan.28 The
Company will advertise its services in a manner reasonably designed to reach those likely to
qualify for Lifeline service, using mediums for outreach such as print advertisements, direct
marketing, social media and the Internet. TruConnect will engage in advertising campaigns
specifically targeted to reach those likely to qualifu for Lifeline service, promoting the availability
of cost-effective wireless services to this neglected consumer segment. TruConnect may also
promote the availability of its Lifeline offering by distributing brochures at various state and local
25 See Western Llireless Corporation Petitionfor Designcttion as an Eligible Telecommunicalions Carrier in the Stale
of Wyoming, Memorandum Opinion and Order, l6 FCC Rcd 48, 55 (2000).
26 See In the Matter of Telecommunications Carriers Eligiblefor Support, Lifeline and Link (/p Reform, WC Docket
No.09-197, WC DocketNo. ll-42, Memorandum Opinion and Order, FCC 13-44 (rel. April 15,2013).
27 See 47 C.F.R. $ 54.207(c).
28 See Exhibit 3, section (4). See also Lifeline and Link Up Reform Order at Section VII.F.
l4
social service agencies, and may partner with nonprofit assistance organizations in order to inform
customers of the availability of its Lifeline service. In addition, TruConnect intends to utilize its
network of retail partners (once established) to help promote the availability of its Lifeline plans,
especially retail outlets that are frequented by low-income consumers. TruConnectwill provide
retail vendors with signage to be displayed where Company products are sold, and with printed
materials describing the Company's Lifeline program.2e
TruConnect will explain in clear, easily understood language the following disclosures in
all marketing materials related to the supported service: (a) that the service is a Lifeline-supported
service; (b) that only eligible consumers may enroll in the program; (c) what documentation is
necessary for enrollment; and (d) that the benefit is limited to one per household consisting of
either wireline or wireless service and is non-transferrable. TruConnect will also explain that
Lifeline is a government benefit program and willfully making false statements to obtain Lifeline
benefits may be punished by fine or imprisonment or result in being barred from the program.
Additionally, TruConnect will disclose the company name under which it does business and the
details of its Lifeline service offerings in any Lifeline-related marketing and advertising.
F. Service Commitment Throughout the Proposed Designated Service Area
TruConnect will provide service in Idaho by reselling service which it obtains from its
underlying carriers. These providers' networks are operational and largely built out. Thus,
TruConnect will be able to commence offering its Lifeline service to all locations served by its
underlying carriers very soon after receiving approval from the Commission.
In accordance with 47 C.F.R. $ 54.202(a)(1)(i), and by the attached certification, TruConnect
commits to comply with the service requirements applicable to the low-income support that it
2e See attached Exhibit 5 for a sample advertisement.
l5
receives. Pursuant to 47 C.F.R. S 54.202(a)(l)(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.30
G. Ability to Remain Functional in Emergency Situations
In accordance with 47 C.F.R. $ 5a.202(a)(2), TruConnect has the ability to remain
functional in emergency situations. As discussed, TruConnect will utilize the extensive and well-
established Verizon, Sprint, and/or T-Mobile networks and facilities to provide its Lifeline
services. The Company understands that the Underlying Carrier networks have access to a
reasonable amount of back-up power to ensure functionality without an external power source, are
able to reroute traffic around damaged facilities, and are capable of managing traffic spikes
resulting from emergency situations. lndeed, these Underlying Carriers have repeatedly certified
to the FCC that their networks function in emergency situations.3l l'he Underlying Carriers
provide the same functionality to TruConnect and its customers as these carriers provide to
themselves and their own customers.
H. Commitment to Consumer Protection and Service Quality
Under FCC guidelines, an ETC applicant must demonstrate that it will satisfy applicable
consumer protection and service quality standards, and wireless applicants may satisfy this
requirement with a commitment to comply with the Cellular Telecommunications and Internet
Association's ("CTIA") Consumer Code for Wireless Service.32 TruConnect hereby commits to
30 See also Lifeline and Link (lp Reform Order atl386.
3t See, e.g., Sprint Nextel Corporation Verified Filing in Compliance with 17 C.F.R. S 54.209, CC Docket No. 96-45,
at 6 (filed Sept. 30, 20ll); In the Matter of T'elecommunications Carriers Eligible for Universal Seryice Support,
Petition of T-Mobile USA, Inc. for Designation as a Low-lncome Eligible Telecommunications Carrier, et al., WC
Docket No. 09- I 97, at 20 (released Aug. 16,2012).
32 See 47 C.F.R. $ 5a.202(a)(3).
l6
comply with the CTIA Consumer Code for Wireless Service.
I. TruConnect is Financially and Technically Capable
In accordance with 47 C.F.R. $ 5a.202(a)(4), TruConnect is financially and technically
capable of providing Lifeline-supported services. The Company has been offering
telecommunications service since 1998 and began providing non-Lifeline wireless service in
October 2012 and Lifeline-supported wireless service in May 2013. TruConnect already
successfully provides wireless services nationwide, including Lifeline services in seventeen (17)
states.33 TruConnect has not been subject to enforcement actions, and has not been subject to ETC
revocation proceedings except as explained in the footnote below.3a The Company has operated as a
telecommunications carrier for twenty years and has never had to file for bankrupcy protection, and
is supported by the resources of its parent, TSC Acquisition Colporation ("TSC"). TruConnect does
not, and does not intend to, offer exclusively Lifeline-supported services-and is therefore not
exclusively dependent on USAC for its revenue. The result of TruConnect's efforts is that it is a
33 TruConnect is in the process of launching its wireless Lifeline service in the remaining states in which it has been
designated as an ETC.
3a In a Memorandum dated October 18,2017 in Docket No. 3005-TI-102, Wisconsin Commission ("WI PSC") Staff
noted concerns that the Company was not providing Lifeline service in Wisconsin and may have failed to inform the
WI PSC of changes to contact numbers and web sites. TruConnect acknowledges that the Company should have
informed the WI PSC of changes to contact numbers and web sites, a process which was overlooked due to internal
restructuring and employee turnover in 2016 and 2017. TruConnect has put measures in place to ensure consistent,
timely compliance going forward by contracting with the following independent third-party compliance vendors: FAS
Tek Compliance Solutions, Inc. for ongoing regulatory compliance and reporting; Expert Telecom Compliance, Inc.
for ETC-specific compliance, Telecom Professionals, Inc. for ongoing sales and use tax and E-91 1 compliance; and
Lance J.M. Steinhart, P.C. for legal and regulatory services, including maintaining current contact information with
regulatory entities, as well as legal advice regarding operations, marketing and compliance, rate changes and service
area expansions, advice regarding state and federal ETC Lifeline rulemakings and rule changes, and general
monitoring of Lifeline notices and proceedings that could potentially affect TruConnect. These third-party vendors
will provide industry expertise and add a layer of accountability and protection regardless of unforeseen intemal
personnel changes, although in addition, the Company has dedicated staff to work with these aforementioned
compliance providers. Regrettably, as a result of TruConnect not updating its address with the WI PSC, the Company
did not receive notice ofthe proceeding and proposed revocation ofits ETC designation, and therefore the Company's
Wisconsin ETC designation was revoked effective December 19,2017 without input from TruConnect. However,
TruConnect re-filed for ETC designation in Wisconsin on March 26,2018 which the WI PSC conditionally granted
effective August 28, 2018.
l7
profitable, liquid company, fully capable of honoring all its service obligations to customers and
regulatory obligations to state and federal regulators. Furthermore, the senior management of
TruConnect has great depth in the telecommunications industry and offers extensive
telecommunications business technical and managerial expertise to the Company.3s TruConnect
will be providing resold wireless service, and therefore will also rely upon the managerial and
technical expertise of its underlying carriers.
J. TruConnect Will Comply with the Lifeline Certification and Verification
Requirements
Section 54.410 of the FCC's Rules requires ETCs to certify and verify a Lifeline
customer's initial and continued eligibility. TruConnect will certifo and verify consumer
eligibility 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), and will annually
re-certifu the continued eligibility of all of its subscribers.
K. TruConnect Will Comply With All Regulations Imposed By The Commission
By this Application, TruConnect hereby asserts its willingness and ability to comply with
all the rules and regulations that the Commission may lawfully impose upon the Company's
provision of service contemplated by this Application. TruConnect commits to comply with
applicable ITSAP regulations, including but not limited to required monthly reporting, as well as
execution of a Memorandum of Understanding with the Department of Health and Welfare.
TruConnect further commits to remit required ITSAP funds to the ITSAP Administrator.
As the Company is not seeking high-cost support for its wireless service, it hereby requests
a waiver of the Commission Rules, Commission Order No. 29841 Section B.l (two-year network
35 See Exhibit 6 for key management bios.
18
improvement and maintenance plan based on high-cost support). Because the Company is not
seeking high-cost support, this rule is not applicable and therefore should be waived.
IV. DESIGNATION OF TRUCONNECT AS AN ETC WOULD PROMOTE THE
PUBLIC INTEREST
One of the principalgoals of the Act, as amended by the Telecommunications Act of 1996,
is "to secure lower prices and higher quality services for American telecommunications consumers
and encourage the rapid deployment of new telecommunications technologies" to all citizens,
regardless of geographic location or income.36 Designation of TruConnect as an ETC in Idaho
will further that public interest. Whether because of financial constraints, poor credit history, or
intermittent employment, many low-income consumers often lack the countless choices available
to most consumers and thus have yet to reap the full benefits of the intensely competitive wireless
market-
The instant request for ETC designation must be examined in light of the Act's goal of
providing low-income consumers with access to telecommunications services. The primary
purpose of universal service is to ensure that consumers-particularly low-income consumers-
receive affordable and comparable telecommunications services. Given this context, designating
TruConnect as an ETC would significantly benefit low-income consumers eligible for Lifeline
services in ldaho-the intended beneficiaries of universal service.
A. Advantages of TruConnect's Service Offering
The public interest benefits of TruConnect's wireless service include larger local calling
areas (as compared to traditional wireline carriers); the convenience, portability and security
afforded by mobile telephone service; the opportunity for customers to control cost by receiving a
16 Telecommunications Act of 1996, Pub. L. No. 104-104, I I0 Stat.56.
l9
preset amount of monthly airtime at no charge; the opportunity for customers to receive both the
minimum service standards for voice andbroadband usage within the same rate plan; the ability
of users to use the supported service to send and receive "SMS" or text messages; the ability for
customers to purchase additional usage at flexible and affordable amounts in the event that
included usage has been exhausted (and the courtesy of free low-balance alerts); the option to
purchase international calling at affordable rates; the opportunity for customers to receive service
without going through a credit check or deposit requirement, or committing to a long-term service
contract; and access to 9l I and E9l I (where available) service in accordance with current FCC
requirements.
Low-income individuals can greatly benefit from the advantages offered by the Company's
Lifeline service, which provides access to wholly-supported wireless service to assist in emergency
situations, facilitate job search efforts, and to maintain contact with family members. It is a
commonly accepted fact that in today's market all 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 the ability to be contacted by potential employers, and provides end
users with the ability to contact emergency service providers, regardless of location. TruConnect's
prepaid wireless service is likely to be an especially attractive option for low-income consumers
because it alleviates customer concerns regarding hidden costs, varying monthly charges and long-
term contract issues. Providing TruConnect with the authority necessary to offer discounted
Lifeline service to those most in danger of losing wireless service altogether undoubtedly promotes
the public interest.
20
Finally, grant of TruConnect's Application will serve the public interest in increasing the
number of ETCs in Idaho. By granting ETC status to TruConnect, the Commission will enable
TruConnect to increase the number of Idaho residents receiving Lifeline support, thereby increasing
the amount of USF money flowing into Idaho. In sum, ETC designation in the State of Idaho would
enable TruConnect to provide all of the public benefits cited by the FCC in its analysis in the Virgin
Mobile Order. Namely, TruConnect would provide "increased consumer choice, high-quality
service offerings, and mobility,"37 as well as the safety and security of effective 9l I and E9l I
services.3S
B. The Benefits of Competitive Choice
The FCC has acknowledged the benefits to consumers of being able to choose from among
a variety of telecommunications service providers for more than three decades.3e Designation of
TruConnect as an ETC will promote competition and innovation, spurring other carriers to target
low-income consumers with service offerings tailored to their needs, ultimately resulting in
improved services to consumers. Designation of TruConnect as an ETC will help ensure that
quality services are available at'Just, reasonable, and affordable rates" as envisioned in the Act.ao
Introducing TruConnect into the market as an additional wireless ETC provider will afford low-
income Idaho residents a wider choice of providers and available services while creating a
competitive marketplace as ETCs compete for a finite number of Lifeline-eligible customers.
Increasing the competitive marketplace of providers has the potential to effectively increase the
penetration rate and reduce the number of individuals not connected to the PSTN.
37 See Virgin Mobile Order,24 FCC Rcd at 3395 !l 38.
38 See Id. at3391 123.
3e See, e.g., Specialized Common Carrier Services,29FCC Rcd 870 (1971).
ao See 47 U.S.C. $ 254(bxl).
21
C. Impact on the Universal Service Fund
TruConnect's request for designation as an ETC solely for purposes of participating in the
Lifeline program would not unduly burden the USF or otherwise reduce the amount of funding
available to other ETCs. With Lifeline, ETCs only receive support for customers they obtain. The
amount of support available to an eligible subscriber is exactly the same whether the support is
given through a company such as TruConnect or the Incumbent LEC operating in the same service
area. The number of persons eligible for Lifeline support is the same the Company's designation
as an ETC; TruConnect will only increase the amount of USF Lifeline funding in situations where
it obtains Lifeline customers not already enrolled in another ETC's Lifeline program. By
implementing the safeguards set forth inthe Lifeline and Link Up Reform Order and utilizing the
NLAD and National Verifier (once in place), the likelihood that TruConnect's customers are not
eligible or are receiving duplicative support either individually or within their household is greatly
minimized. TruConnect's ability to increase the Lifeline participation rate of qualified low-income
individuals will further the goal of Congress to provide all individuals with affordable access to
telecommunications service, and thus any incremental increases in Lifeline expenditures are far
outweighed by the significant public interest benefits of expanding the availability of affordable
wireless services to low-income consumers.
22
V. CONCLUSION
Based on the foregoing, designation of TruConnect as an ETC in the State of Idaho accords
with the requirements of Section2la@)Q) of the Act and is in the public interest.
WHEREFORE, TruConnect respectfully requests that the Commission promptly designate
TruConnect as an ETC in the State of Idaho for the purpose of participating in the Lifeline program.
Respectfully submitted,
Lance J.M. Steinhart
Managing Attorney
Lance J.M. Steinhart, P.C.
1725 Windward Concourse, Suite 150
Alpharetta, Georgia 30005
[phone] (Phone)
[phone] (Fax)
E-Mail: [e-mail]
Attorneys for Sage Telecom Communications, LLC
d/b/a TruConnect
January 24,2019
23
EXHIBIT I
Certification
STATE OF CALIFORNIA )
)
)COUNTY OF LOS AI\GELES
I, Nathan Johnson, the Co-CEO (Co-Chief Executive Officer) of Sage Telecom Communications,
LLC dlb/a TruConnect, hereby depose and state that I have read the foregoing Application and
knows the contents thereof, and confirm that the statements made therein are true to the best of my
knowledge and belief.
Co-CEO
EXHIBIT 2
Proposed Lifeline Offering
Sage Telecom Communications, LLC dlbla TruConnect
Lifeline Offering
Terms & Conditions maintained at www.truconnect.com
* unl i m ite d I hr ot t le d dat a t he re afte r
Plans Include
o Free data-capable device or SIM card
. Free calls to Company Customer Service
. Free calls to 91 I emergency services
o Free access to Voicemail, Caller-ID, Call Waiting, Call Forwarding, and 3-Way Calling
. Free Domestic Long Distance
o Data at 3G speeds or higher
Additional airtime available toruufchase
Voice, Data, and International Talk refill options are maintained on the Company's website:
https ://www.truconnect.com/intemati onal
Plan Minutes Text Data Net Cost
to Lifeline
Customer
Basic Lifeline PIan 1,000 Unlimited 2.0 GB s 0.00
Bundled Plan I Unlimited Unlimited 4.0 GB*$35.00
Before the
FEDERAL COMMT]MCATIONS COMNdISSION
Washington, D.C. 20554
In the Matter of
Federal-State Joint Board on
Universal Service
WC Docket No. 09-197
Lifeline and LinkUp Reform Modemization WCDocketNo, ll42
RE\TSED COMPLIANCE PLAN OF SAGE TELECOM,INC.
Sage Telecom, Inc. ("Sage"), by its attorneys, respectfirlly submits this Compliance Plan
('?lan") for the purposes of seeking federal Lifeline support for wireless service under the
Universal Service Fund's Low lncome Program.
In the Ltfeline Reform Order,l the Commission adopted rules and procedures through
which it instituted *blanket forbearance" from the applications of the facilities requirement to all
telecommunications carriers seeking a limited ETC designation to provide wireless Lifeline
services. In order to qualify for this blanket forbearance, the Commission requires carriers to
comply with certain 911 requirements and file and receive approval of a compliance plan
providing specific information about its service offerings and procedures to safeguard against
waste, fraud and abuse.
Therefore, Sage respectfully submits this Plan in accordance with the Lifeline Reform
Order and instructions set forth in the Wireline Competition Bureau Public Notice issued on
' In the Motter of Lifeline qnd Link Up Reform snd Modernbation Lfeline and Link llp, Federal-State Joint
Board on Universal Selvice, Advancing Broadband Availability Through Digital Literacy Training, WC Docket No.
1142, WC Docket No. 03-109, CC Docket No.9645, WC Docket No.12-23, Report and Order and FurtherNotice
of Proposed Rulemaking, FCC I l-12,',|[ 172 (rel. Feb. 6, 2012) ("Lifeline Reform Ordet").-l-
)
)
)
)
)
)
)
)
N75233916.2
February 29,2012.2 Sage seeks approval of this compliance plan only for the provision of
Lifeline support to provide wireless services nationwide, as the company offers wireline service
as a facilities-based carrier under the approval of state commissions. This Plan sets forth Sage's
service offerings and the procedures and measures it will use to safeguard against waste, fraud
and abuse. In support of this request Sage provides the following information:
(l) Information about the carrier and the Lifeline plans it intends to offer:
(a) names and identiliers used by the carrier, its holding company, operating
company and all affiliates;
Sage is a Texas corporation with offices located at 10440 N Central Expressway, Suite
700, Dallas,TX7523l.3 The company began operations as a competitive local exchange carrier
("CLEC") providing traditional wireline service in 1998. Sage is authorized as a CLEC in 25
additional states and as an interexchange carrier in Colorado,o *d provides service in Arkansas,
Califomi4 Connecticut,Illinois, Kansas, Michigan, Missouri, Ohio, Oklahoma, Texas and
Wisconsin. Sage was authorized as an ETC in Texas in2002, and Sage also a provider of high
speed Intemet services. Sage has also been designated as an ETC in a number of other states for
the provisions of wireline seryice Lifeline service and currently has wireline Lifeline customers
in five states for which it is reimbursed through state and/or federal programs, depending upon
the state and the customer. Specifically, in California, Sage receives support only from the
CPUC's Low Income Programs. Sage also receives support from state programs in Kansas,
Texas and Wisconsin. Less than}0o/o of Sage's customers receive a subsidy from a low income
2 Public Notice, Wireline Competition Bureau Provides Guidance for the Submissisn of
Compliance Plans Pursuant to the Lifeline Reform Order, DA 12-314, (Rel. Feb. 29.2012).
3 Due to a planned move of corporate oftices, this address is effective after October 26,2012.a Technically, the services provided by Sage in Texas are under the corporate entity Sage Telecom of Texas,
LP, and services in all other states are provided by Sage Telecom, Inc. However, services are all offered to
consumers under the trade name "Sage Telecom, Inc."
-Z_
N752339t6.2
program. The company is planning to launch wireless service on a non-Lifeline basis, primarily
in Texas, through an MVNO arrangement with Sprint. As the company would like to expand
this offering to Lifeline customers, Sage seeks approval of a compliance plan to offer Lifeline
service using this resold service.
Sage is wholly-owned by TSC Acquisition Corporation ("TSC"). TSC also owns
Telscape Communications, Inc., A CLEC based in Califomia that primarily serves customers in
that state on both a wireline and wireless basis. Sage, through its common ownership with
Telscape, has collective access to a broader market and combined subscriber growth. Sage is
also affiliated with TruConnect Mobile, LLC ("TruConnect"), through partial common
ownership. TruConnectis 40yo owned by TSC, Sage's parent company as described above.
TruConnect provides mobile broadband data services and does not provide any services
supported by the low income program.
(b) detailed information demonstrating the carrier is financially and technicalty
capable of providing the supported Lifeline services in compliance with the Commission's
rules;
As a long-time provider of wireline services, particularly in Texas, Sage has a proven
record of technical and financial qualifications. The company provides facilities-based wireline
service in numerous states and has sophisticated back-office, operational and support systems,
which allows it to operate at lower costs and pass those savings on to its subscribers. As a carrier
who has provided service for nearly 14 years, Sage possesses the financial viability, as well as
the expertise to continue to provide affordable and quality service to customers and has the
proven experience to maintain its compliance with all applicable federal and state regulatory
guidelines. Sage derives the majority of its revenue from the telecommunications services it
provides to its customers. Sage does not and will not rely exclusively on the Universal Service
-3-
N75233916.7
Fund ("USF") disbursements to operate, but rather relies on revenues it receives from providing
non-Lifeline wireline (and soon wireless) service, the payment for service by Lifeline
customers,s as well as high-speed Internet services. [n addition, Sage has not been subject to any
type of enforcement action or ETC revocation proceeding by the FCC or any state utility
regulatory commission.
Sage is working with Sprint Spectrum to resell Sprint's wireless services to non-Lifeline
customers in Texas and elsewhere. As a Lifeline service provider, Sage would continue to work
with Sprint, who provides the necessary network infrastructure and wireless facilities nec€ssary
for the operation of Sage's services as a Mobile Virtual Network Operator ("MVNO'). As the
Commission is aware, Sprint is a large, nationwide carrier who provides similar service to other
wireless Lifeline providers operating as MVNOs. Sage's agreement and parErership with Sprint
further demonstrates its financial and technical capability to provide these seniices.
(c) detailed information, including geographic locations, of the carrierts current
service offerings if the carrier currently offers serwice;
u
As detailed in response to Question l(a) above, Sage currently provides local and
interstate wireline and is planning to provide wireless services in numerous states, with a
particular emphasis on Texas.
(d) the terms and conditions of each Lifeline service plan offering, including
rates, the number of minutes provided and additional charges, if any, for toll calls;
At this time, Sage plans to offer the following wireless Lifeline plans and services,
subject to state specific requirements or requests from state PUCs. These plans are offered to
both Lifeline and non-Lifeline subscribers, with a discount applied to the Lifeline customer.
Seryices will be offered on a prepaid basis, and potentially also on a postpaid basis. All services
5 All of Sage's Lifeline wireline customers currently pay a monthly fee for the discounted service.
-4-
N7s231916.2
will norrrally have an activation fee and will likely require a monthly payment from the
customer. The prices listed below show the basic, non-Lifeline price and the price to the
consumer with the $9.25 Lifeline credit applied. AII plans will likely require a monthly payment
by the customer. Sage commits to providing a minimum of 250 minutes per month for the $9.25
subsidy.
Sage is still determining the exact plans it will offer (reiterating the condition that plans
will provide a minimum of 250 minutes for the $9.25 subsidy), but a sample plan would be as
follows:
ValuMobile PIus Price: $24.25 monthllifeline Price: $ I 5.00
Activation Fee: $25.00
Additional Minutes: For all service plans the customer can purchase additional voice, data,
MMS, text minutes for $0.05 per minute with aminimum purchase of $5.00. For example, 100
additional minutes will cost 55.00. The customer will have the ability to purchase 100 minutes
($5.00); 200 minutes ($10.00); 300 minutes ($15.00) and 500 minutes ($25.00). For Unlirnited
service plans the customer will not need additional voice or text but will need to purchase
additional minutes for data and MMS. MMS is priced at $0.15 per minute and Data is $0.05 per
MB.
Text Messages: The service plans include text messaging; text messaging rates are assessed at I
minute per text message sent and I minute per text message received.
Other: Plans do not permit rollover minutes. Top Ups are available for a 30 day period as long
as the customer renews the service at the normal plan rate. Plans do not allow roaming. The
$25.00 Activation Fee includes selection of a basic handset which is activated and provided
ready for use. Customers are allowed to call internationally but will be assessed the intemational
rates. International text rates are $0.20 per minute for messages sent or received. Special
Promotional offer: 10 MB data FREE for 3 months with the selsction of a data capable phone.
CostFeatures
500 minutes Voice/Text Included
Call Waiting Included
Included3 Way Calling
Caller ID Included
IncludedVoiceMail
Free9il
611 (Customer Service)Free
$1.50Directory Assistance
l./752339t6.2
-5-
(e) all other certilications required under newly amended section 54.202 of the
Commission's rules.
Section 54.202 requires ETCs to (1) certifr that it will comply with the applicable service
requirements; (2) file a five-year plan detailing proposed improvements or upgrades in the
network unless the ETC is receiving only Lifeline support; (3) demonstrate that it will continue
to function in emergency situations including reasonable back-up backup power and emergency
haffic management; (4) demonstrate that the carrier will comply with applicable consumer
protection and service quality standards; (5) demonstrate that it is financially and technical
qualified to provide Lifeline services that comply with the applicable rules; and (6) provide
information concerning the terms and conditions of the service plans offered to Lifeline
customers.
In response to item (1), Sage certifies that it will comply with applicable service
requirements and regulations for Lifeline support.
ln response to item (2), Sage is not required to submit a five year plan since it is seeking
to obtain only Lifeline support for its eligible customers.
In response to item (3), as a CLEC provider in multiple states for over 14 years, Sage has
significant experience with emergency preparedness. Sage has detailed Emergency Action and
Disaster Recovery Plans in place to respond to emergencies. In addition, Sage's agreement with
Sprint provides for the continuation of services during emergencies and sets forth obligations for
the service to remain functioning during disasters and similar emergency situations. [n addition,
as a nationwide carrier and provider of wireless service, Sprint also remains subject to the
Commission's authority and must, and does, comply with federal outage reporting requirements.
N75233916.2
-6-
In response to item (4), Sage certifies that it will comply with the applicable consumer
protection and service quality standards. As an operating CLEC in many states, Sage is already
subject to states consumer protection and service quality requirements. Sage's wireless Lifeline
customers will also receive the same quality service and protections.
Sage's response to items (5) and (6) are provided above and in the provided exhibits
@ A detailed explanation of how the carrier will comply with the Commission's new
rules relating to determinations of subscriber eligibility for Lifeline services, including all
consumer eligibility, consumer enrollment and ro-certifiication procedures as required by
Section VI and Appendix C of the Lifeline Reform Order, and a copy of the carrier's
certification form;
Under the Lifeline Reform Order, ETCs must comply with eligibility rules for Lifeline
services, including initial eligibility, certification, and annual re-certification procedures. [n
addition to the Commission's rules, Sage must also comply with all certification and verification
requirements for Lifeline eligibility established by states where Sage is designated as an ETC.
For states that do not have a Lifeline administrator or state agency responsible for determining
eligibility and initial certifications and annual certifications, Sage certifies it will comply with the
Commission's certification and verification requirements and will follow the procedures outlined
below until such time as the Commission implements its planned National Lifeline
Accountabil ity Database.
N75D3916.2
-7-
Procedures for Initial Elieibilitv Determination and Certificafion of Lifeline Subscribers.
With respect to determining eligibility certification procedures, the rules provide that an
ETC must determine a Lifeline applicant's eligibility and provide and receive certification forms
with proper documentation from Lifeline subscribers, except where there is a state Lifeline
administrator or a state agency responsible for eligibility verification.
In states where there is a third party entity acting as the Lifeline administator (also
refered to as the "Low Income Discount Administrator" or *LIDA" in Texas) who is responsible
for determining the eligibility of consumers seeking to subscribe to Lifeline service, sending out
certification forms, reviewing documentation and providing ETCs with the appropriate approval
of a potential subscriber's eligibility for Lifeline, Sage will comply with the prograrn rules
established in those states and will cooperate fully with any state Lifeline administrator.
Based on Sage's history of providing Lifeline and non-Lifeline customers in wireline
products, Sage's primary source of signing up Lifeline customers will be via telephone, although
some customers may be signed up in person at temporary locations staffed by Sage employees.
Visitors to Sage's website will be given information about the program but are required to
contact Sage directly via telephone to complete the sign-up process. These callers speak to Sage
employees who are specially trained on the Lifeline programs. Sage's customer services
representatives will review incomer and program-based requirements with applicants via
telephone contact. During the initial sign up for service, Sage will (a) require the applicant to
confirm that he or she is not already receiving a Lifeline service and that no one else in the
applicant's household is subscribed to a Lifeline service in order to avoid providing duplicate
services; and (b) inform the applicant of both the income- and program-based eligibility
requirements to determine initial eligibility and any state-specific requirements.
-8-
N752339t6.2
Customers are offered the choice to either sign up for service as a non-Lifeline customer
pending confirmation of eligibility, or to have their application for service held pending
confirmation of eligibilrty. In the event the customer chooses to proceed, they are processed as a
new non-Lifeline customer and the verification process continues as described below. The
customer would only be given the Lifeline discount when they have satisfied the verification
process, either through the state administrator or Sage's internal process. If the customer is
eventually deemed ineligible, they receive no credit. Where the customer chooses to wait for
confirmation of eligibility before starting service, the employee will take down the relevant
information from the consumer, including payment information, but the order is then held
pending verification of eligibility. Only if the customer is determined to be eligible is the order
processed.
The Verification process varies by state, in states with a Lifeline administrator, if a new
applicant indicates that he or she is eligible for Lifeline service, Sage will provide the applicant's
relevant information to the adminishator in conformance with any state or Lifeline administator
specific mles. The Lifeline administator will provide the requisite forms and will be responsible
for processing those forms when returned and ensuring the documentation is satisfactory as set
forth in state regulations. Sage will not provide Lifeline service or seek reimbursement for
providing services to such applicant until it receives a certification of eligibility from the Lifeline
administrator.
In states where there is no Lifeline administrator or state agency responsible for
determining initial eligibility and certiffing Lifeline applicants, Sage will require all applicants
to demonstrate either: (1) the applicant's household income is at or below 135% of the Federal
Poverty Guidelines based on the income-eligibility criteria set forth in Sections 54.409(a)(l) or
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N?5233916.2
(aX3) or (2) the applicant participates in Medicaid, Food Stamps, Supplemental Security Income,
Federal Public Housing Assistance, Low-Income Home Energy Assistance Program, National
School Lunch Program or Temporary Assistance for Needy Families. As required to prevent
suspected duplications, Sage will also require the customer to complete the Lifeline Household
Worksheet issued by USAC to ensure that duplicate support is not provided to any household.
Sage will inform the applicant that any information provided will be submitted to USAC as
necessary under the Commission's rules to verify the household is not receiving duplicate
Lifeline support.
After confirming initial eligibility either in person or over the phone, Sage will provide
the individual with an application via mail requiring him or her to provide certain information
and certify that they meet either the income-based eligibility requirements or the program-based
requirements, make certain certifications and submit documentation. Specifically, Sage's
Lifeline application form will collect the following information from the potential Lifeline
customers: (i) the subscriber's full name; (ii) the subscriber's full residential street address (P.O.
Boxes will not be acceptable); (iii) whether the residential address is permanent or temporary;
(iv) the subscriber's billing address, if different; (v) the subscriber's date of birth; (vi) the last
four digits of the subscriber's Social Security number (or Tribal identification number if the
subscriber is a member of a Tribal nation and does not have a Social Security number); (vii) if
the subscriber is seeking to qualiff for Lifeline under the program-based criteria, the name of the
quali$ing assistance program from which the zubscriber, or his or her dependents, or his or her
household receives benefits; and (viii) if the subscriber is seeking to qualiff for Lifeline under
the income-based criterion, the number of individuals in his or her household.
-10-
N75233916.2
In addition, as part of the Lifeline application, Sage will require all Lifeline applicants to
certifr, under penalty of perjury, that:
the applicant meets the income-based or progftrm-based eligibility criteria for receiving
Lifeline either because the household receives benefits from a state or federal assistance
program (and list the name of the program) or has income at or below 135Yo of the
Federal Poverty Guidelines;
the applicant has provided documentation to Sage that correctly and accurately confirms
the subscriber's household income or participation in the aboveJisted program(s);
the applicant will notify its carrier within thirry (30) days if, for any reason, he or she no
longer satisfies the criteria for receiving Lifeline including, as relevant, if the applicant no
longer meets the income-based or program-based criteria for receiving Lifeline support,
the applicant is receiving more than one Lifeline benefit, or anottrer member of the
subscriber's household is receiving a Lifeline benefit. The applicant will also certifl that
they understand this requirement and may be subject to penalties if they fail to notiff
Sug";
if the applicant moves to a new address, he or she will provide that new address to the
eligible telecommunications carrier within thirty (30) days;
if the applicant provided a temporary residential address to the eligible
telecommunications carrier, he or she will be required to veriff his or her temporary
residential address every ninety (90) days;
the applicant acknowledges that the subscriber will be required to re-certifr his or her
continued eligibility for Lifeline at any time, and the applicant's failure to re-certifu as to
his or her continued eligibility will result in de-enrollment and the termination of the
applicant's Lifeline benefi ts;
the applicant's household will receive only one Lifeline service and, to the best of his or
her knowledge, the subscriber's household is not already receiving a Lifeline service;
the information contained in the applicant's certification form is true and correct to the
best of his or her knowledge, that providing false or fraudulent documentation or
information in order to receive assistance if punishable by fines, imprisonment, de-
enrollment or being barred from the program;
That a violation of the one-per-household rule constitutes a violation of FCC rules and
will result in their de-enrollment from the Lifeline progam
the applicant understands that Lifeline is a non-transferable benefit and the service may
not be transfers to anyone else; and
the applicant understands their information, including name, telephone number and
address, will be given to the Universal Service Administrative Company ([JSAC) and/or
its agents for the purpose of verifuing the applicant and the applicant's household do not
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N75233916.2
receive more than one Lifeline benefit and consenting to the inclusion of that information
into a Lifeline database.
A sample Sage application is attached hereto as Exhibit A.
This application is mailed by Sage to the customer for completion and is retumed to Sage
for review and certification. All applications are reviewed by Sage employees. Should Sage
engage sales agents to assist in signing up customers, those applications will also be reviewed by
Sage employees to ensure the applicant's eligibility.6 This review includes a review to determine
eligibility as well as a duplicate review process described below. Sage will make itself available
as a direct point of contact with all Lifeline applicants. In addition, all Sage ernployees who
have contact with potential Lifeline customers will be fully trained on the state and Commission
Lifeline eligibility rules.
If Sage cannot determine a prospective subscriber's eligibility through a review of an
appropriate federal or state database, Sage personnel will require the submission of appropriate
documentation required to establish income-based and program-based eligibility and will review
each subscriber's documentation for compliance with the eligibility criteria- If documentation is
not sufficient or if the application is incomplete, then Sage will deny the application and inform
the applicant of the reason for such rejection. For applicants submitting proof of income-
eligibility or program-based eligibility, Sage will not retain copies of such documentation but
will maintain accurate records detailing how the customer demonstrated his or her eligibility.T In
addition, if the subscriber provides Sage with a temporary address, it will veriry with the
subscriber every 90 days that this address remains valid. If the subscriber fails to respond to the
Sage within 30 days, the subscriber will be de-enrolled from the Lifeline program.
u In states with a Lifeline Administrator, this process would be handled pursuant to the procedures of the
Administrator.
47 C.F.R. $ $ s4.4 I 0(bX I Xiixiii) and 54.4 I 0(c)( I XiD-Gii).-12-
7
N757339t6.2
Procedures for Annual Re-Certification. Similar to the initial certification process, an
ETC must annually certifr all subscribers, unless there is a Lifeline administrator that is
responsible for re-certification. [n states where a Lifeline administrator is responsible for
completing annual re-certifications, Sage will rely on such administrator completing the annual
certification. If the Lifeline administrator provides notice to Sage that a current subscriber did
not re-certifu, then Sage will comply with the de-enrollment requirements required by the FCC's
rules. Sage will cooperate fully with any Lifeline administrator and take any necessary steps to
ensure it is in compliance with both state and federal re-certification procedures.
ln states where there is not a Lifeline administator, Sage will require its Lifeline
subscriber to annually re-certiff their eligibility as set forth in Rules 54.410(DQ) and (f)(5) and
5a.a05(e)(a). Sage may complete the re-certification process on a rolling basis throughout the
year. If Sage cannot determine on-going eligibility by accessing a qualifying database, Sage will
re-certiff the continued eligibility of its subscribers by contacting them in person, in writing (by
mail), by phone, by text message, by email or otherwise through the Internet.s Alternatively,
beginning in 2013, Sage may elect to have the USAC administer the annual self-certification
process.9
As part of the re-certification process, Sage will inform its Lifeline subscribers that they
must confirm eligibility to retain Lifeline benefits, when Lifeline benefits will be terminated if
confirmation of eligibility is not provided and how to contact Sage for more information or
assistance. If a Lifeline subscriber does not respond to the notice within 30 days, Sage will send
Lifeline Reforn Order,\ 130.
[d.,1t33.
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l/752339t6.2
8
9
a notice of impending termination. Subscribers who do not respond to the impending
termination notice will be de-enrolled from the Lifeline program within five business days.r0
(3) A detailed explanation of how the carrier will comply with the forbearance
conditions relating to public safety and 911/E-911 access;
The Commission conditioned its grant of forbearance on an ETC (a) providing its
Lifeline subscribers with 911 and E911 access, regardless of activation status and availability of
minutes; (b) providing its Lifeline subscribers with E91l-compliant handsets and replacing, at no
additional charge to the subscriber, noncompliant handsets of Lifeline-eligible subscribers who
obtain Lifeline-supported services-ll Sage's wireless service currently complies with these
requirements and will continue to comply with these conditions.
Specifically, Sage provides its wireless subscribers with 9l l/E911 access at the time their
service is initiate4 regardless of activation status and availability of minutes and provides its
subscribers with E9ll-compliant handsets. It is the company's practice to provide access to
9l l/E9l I to the extent these services are available from the underlying carrier, Sprint. Sage also
enables 911 emergency calling from all properly activated handsets regardless of whether the
account associated with the handset is active, suspended to terminated. Sage will transmit all
911 calls initiated from any of its handsets even if the associated account has no remaining
minutes.
In addition, all phones provided by Sage are 911/E9l I compliant. Sage uses phones from
Sprint that, based on representations made to Sage by Sprint, have been through the applicable
certification process in the company's labs. In the event that a customer does not have an E911-
complaint handset, Sage will replace it with a compliant handset at no charge. All new
47 C.F.R. $ sa.a0s(e[a).
Lifel i ne Refor m Order, \ 37 3.
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N'l52139t6.2
t0
ll
customers who qualifi for Lifeline services with Sage will receive a9lllE9ll-compliant
handset free ofcharge.
(4) A detailed explanation of how the carrier will comply with the Commission's
marketing and disclosure requirements for participation in the Lifeline program;
Sage has experience in providing clear, concise and consistent marketing and disclosure
information to its wireline Lifeline to its customers. With respect to its wireless services, Sage
will emphasize in clear, easily understood language: (a) that the service is a Lifeline-supported
service; (b) that only eligible consumers may enroll in the program; (c) what documentation is
necessary for enrollment; and (d) that the benefit is limited to one per household consisting of
either wireline or wireless service and is non-transfenable. Sage will also explain that Lifeline is
a govemment benefit progarn and willfully making false statements to obtain Lifeline benefits
may be punished by fine or imprisonment or result in being barred from the program. Sage has
and will continue to clearly disclose its name (Sage or Sage Wireless) on all marketing materials.
A sample advertisement to be used as a model for creation of state-specific advertisements is
attached hereto as Exhibit B. Please note that the two pages of the exhibit represents the front
and back of single page document.
(5) A detailed explanation of the carrier's procedures and efforts to prevent wastg
fraud and abuse in connection with Lifeline funds, including but not limited to, procedures
the carrier has in place to prevent duplicate Lifeline subsidies within its own subscriber
base, procedures the carrier undertakes to de-enroll subscribers receiving more than one
Lifeline subsidy per household, information regarding the carrier's toll limitation service,
if applicable, and the carrier's non-usage policy, if applicable.
Sage fully understands and shares the Commission's commitment to minimize waste,
fraud and abuse with respect to the Lifeline program. Sage derives less than a quarter of its
revenue from Low lncome service, and does offer a wireline low income service in a number of
states both with and without and administrator. Nonetheless, Sage has focused its operations in a
_15_
N75233916.2
few states, with a goal of focused growth, to be offered initially in Texas, and then into other
states in which Sage is already a wireline ETC. This approach has allowed Sage to refine its
business practices and to implement policies consistent with the Commission's goal of
minimizing waste, fraud and abuse before launching its service nationwide at some time in the
future.
Prevention of Duplicates In Saee's Subscriber Base. At time of initial sign up of a new
subscriber, the subscriber's service address is validated for accuracy against the USPS ("United
States Postal Service') database and saved in the USPS-approved format which permits the Sage
subscriber database to more accurately prevent duplicates by preventing variations of the same
address from appearing multiple times in the database. Once the address is validated for accuracy
and format, Sage can check it in available databases or provide it to the Lifeline administrator,
where applicable, to be checked against addresses for all Lifeline customer addresses for the
entire state.
In addition, while it is anticipated that Sage and its affrliate, Telscape will only operate in
different states, to the extent that they have Lifeline customers in the same state, customers can
be checked against each company's records to further avoid duplication.
Activation and Non-Usage Policy. Sage will not consider a wireless subscriber activated
until the customer has chosen a non-Lifeline service plan, activates their service by paying the
activation fee, and then applies for and is approved for a Lifeline service plan. Adhering to this
"prequalification guideline" prevents waste, fraud and abuse by requiring customers to first sign
up for service at regular rates and then only provide discounted service once the customer's
eligibility has been confirmed through verification or a Lifeline adminisfrator. As such, Sage
will not seek reimbursement for any wireless subscriber until the subscriber activates service and
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N752339t6.?
is approved by the Lifeline administator or by Sage, in states without a third parfy Lifeline
administrator. Customers who wish to be confirmed as an eligible Lifeline subscriber prior to
commencing service can place a non-Lifeline order and have the order held pending verification
of eligibility as described above. Because customers do not receive their handset and service
until they have an order processed and the activation fee is paid, customers receive activated
handsets. Thus, there is no possibility of Sage receiving reimbursement for a customer who does
not have an active handset. After the order is processed, Sage personnel activate, configure and
test the handsets before they are sent to the consumer. Thus all customers receive an activated
handset.
As required by the Lifeline Reform Order, Sage has implemented a non-usage policy
under which it will de-enroll Lifeline customers that have not used the Sage's Lifeline service for
60 consecutive days. When consumers sign-up for Sage's service, Sage will inform them about
the usage requirement. If a Sage Lifeline customer's accotrnt does not reflect any usage during
any consecutive 60-day period, Sage will deactivate the customer's Lifeline service. Accounts
will be deemed active if the Lifeline subscriber: (a) completes an outbound call; (b) purchases
minutes or an additional month of service to add to the subscriber's Lifeline service plan; (c)
answers an incoming call from a party other than Sage, its agent or representative; or (d)
responds to a direct contact from Sage and confirms that he or she wants to continue receiving
the Lifeline service. I 2
For Lifeline subscribers failing to use their Lifeline service for a 60-day corsecutive
period as described above, Sage will provide a clear, easily understood notice that the
subscriber's failure to use the Lifeline service within the 30-day notice period will result in
t2 See Lifeline Rdorm Order,\261;47 C.F.R. $ 54.!07(c)(2).
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N752339t6.2
service termination for non-usage. Sage will not terminate service to Lifeline subscribers that
use their Lifeline service within 30 days of Sage providing said notice.13
Cooperate with Federal and State Regulators and Lifeline Administrators. Sage will
cooperate with the Commission and has and will continue to cooperate with state regulators and
Lifeline administrators to prevent waste, fraud and abuse. Sage will, for example:
As applicable, participate in industry working groups conducted by or in coordination
with state commissions and Lifeline administators;
Respond to requests from the Commission, USAC or state commissions concerning
consumers' eligibility to be enrolled in Lifeline service, among other matters;
Upon having a reasonable basis and/or upon any notification from federal or state
commissions and/or Lifeline administators, timely investigate iszues concerning a Sage
Lifeline customer receiving service from another carrier or customers receiving more
than one Lifeline subsidy per household;
As applicable and when available, access the National Lifeline Accountability Database
to determine if an applicant is currently receiving Lifeline service from another carrier or
if another person residing at the applicant's residential address is receiving Lifeline
service; and
Comply with federal and state audit requirements.
ll 47 C.F.R. $ sa.a05(eX3).
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CONCLUSION
Sage respectfully submits that the foregoing Compliance Plan fully satisfies the
conditions set forth in the Lifeline Reform Order. Accordingly, Sage respectfully requests
approval of this Compliance Plan so that Sage can provide essential Lifeline wireless service to
eligible low-income customers nationwide.
Respectfrrlly submitted,
/s/ electronically signed
Douglas D. Orvis II
Kimberly A. Lacey
Bingham McCutchen LLP
2020K Sreet, N.W.
Washington, DC 20006
Date: December 19,2012
,.r152339t6.2
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E}GIIBIT A
CERTIFICATION TORMS
FEDERAL LIFELINE CERTIFICATION FORM
Lifeline Informationo Lifeline is a federal benefit and that willfully making false statements to obtain the benefit can result in fines,
imprisonment de-enrollment or being barred from the program-
o Only one Lifeline service is available per household.
o A household is defined, for purposes of the Lifeline program, as any individual or group of individuals who
live together at the same address and share income and expenses.o A household is not permitted to receive Lifeline benefits from multiple providers.o You must use your phone every 60 days to maintain service. Usage includes making an outbound call,
answering an incoming call. Usage can also include the purchase of additional minutes or payment of your
monthly bill. Ifthere is no usage on your account for 60 days you will be de-enrolled from the program.
o Lifeline is a non-hansferable benefit and the subscriber may not transfer his or her benefit to any other person.
Lifeline Qertifi cation Instructions
Step l. Fill out the Customer Information Section. You must provide the last four digis of your Social Security
Number and Date of Birth.
Step 2- Indicate How You Ouali8 for Lifeline. Choose whether you participate in a oualifoing program or if you
household income falls within the guidelines. You MUST send photocopies demonstrating that you participate in
the qualiffing program or if you quali$ based on your household income, you must provide docurnentation of
income that covers one full year. Documentation that does not cover a full year, such as paystubs, the customer
must present the same type of documentation covering Three Consecutive Months within the previous twelve
months.
Step 3. Determine If You Oualifu for Tribal Land. Not all customers will be eligible for the Tribal Land benefit.
To be eligible for Tribal Lands a customer must reside on Tribal Lands and participate in one of the following
prognrms: Tribally Administered Frce School Lunch Program, Tribally Administcrcd Tcmporary Assistancc for Necdy
Pamilies, Food Distribution Program on Indian Rcservations, Hcad Start (those mecting incomc standard), and Burcau of Indian
Affairs General Assistancc.
Stcp 4. Certito Customer Elieibility. Each customer r.rust certifu, under penalty of perjury, for receiving Lifeline
support, by initialing ALL areas under this section.
Step 5. Sien Cedification Form. You must print your name and sign the certification form indicating that you are
complying with the Lifeline rules.
Step 6. Supportins Documentation. Don't forget that you must include supporting documentation which can
include a copy of an award letter or card in the qualifying prognm based. Income documentation could include the
prior year's state or federal tax return, paycheck stubs for the most recent 3 months, social security statement of
benefits, child support document, retiremenUpension statement of benefits, unemploymenUworkmen's compensation
statement of benefits, Federal notice letter of participation in General Assistance, and other official document.
Step 7. Send the Certification Form. When completed, you may mail the form to:
Sage Teleconl lnc.
I 0440 N Central Expressway
Suite 700
Dallas, TX7523l-222E
AK t2lq20t2
Saqe
FEDERAL LIFELINE CERTIFICATION FORM
Step 1. Customer Information Section
Name of Applicant:
Account Number:
Applicant's Service Address (May NOT be a P.O. BOX):
o Pleasc check this box ifthe abovc is a Temporary Addrcss.
Telephone Number:
Date of Birth:
Last Four Digits of SSN:
Qfatp.zip:
Billing Address (if different from Service Address):
Step 2. Determine How You Oualifv For Lifeline (Choose either #l or #2)
Ifthe person who receives the benefit is not the Sage account holder, then please provide the name ofthe person in
your household who is receiving the benefits:
(#l).IqualifrforLifelineunder@becauseIparticipateinthefolIowingprogram.
Check only ONE box below:
o Mcdicaid (not Medicare)
u Low-Income Home Energy Assistance Program (LIHEAP)
o National School Lunch Program (Free Lunch Program)
o Supplemental Nutrition Assistance Program (SNAP)
o Supplemental Security Income (SSI)
o Tcrnporary Assistance forNeedy Families OANF)
c Federal Public Housing Assistance (Section 8)
(#2). I qualify for Lifeline under the Income'Based Criteria because my annual household income is at or below
135Y" of the federal poverty level guidelines. The number of individuals in my residential household is:
(Numbcr in houschold)
Annual Income 135% of Federal Poverty Level Thresholds Based on Household Size
I 2 J 4 5 For each additional person
$15,080 s20,426 $2s,772 $31,1l8 s36,464 +S5,346 per person
Step 3. Determine If You Oualify for Tribal Lands (If Applicable, Choose either#l or#2)
My Tribal ID Number:Check ONE box below:
(#1) o I qualify for Tribal Lifeline service as an eligible resident on federally recognized tribal land.
(#2) I participate in the following tribally administered program.
o Tribally Administered Free School Lunch Program o Tribally Administered Temporary Assistance for Need Families
o Food Distribution Program on Indian Reservations o Head Start (those mecting income standard)
o Bureau of Indian Attar-rs General Assistance
AK l2t 0l2
Saqe
StCp 4. CERTItr"Y APPLICAI\T'S ELIGIBILITY
Please @f or Initial AII the statements below to certifr your eligibility.
I certify, under penalqt of perjury, thtt:
--:
I meet the income-based or program-based eligibility criteria-
_: I must notifr Sage within 30 days if for any reason I no longer satisfu the criteria for receiving Lifeline
including, as relevant, if I no longer meet the income-based or program-based criteria for receiving Lifeline
support, I am receiving more than one Lifeline benefit or another member of my household is receiving a
Lifeline benefit. I understand this requirement to notiS Sage if my eligibility changes and that I may be
subject to penahies if I fail to follow this notification requirement-
_: When I move to a new address. I must provide that my new address to Sage within 30 days.
_; I acknowledge that a household is eligible to receive only one Lifeline service and, to the best of my
knowledge, no other member in my household is currently receiving wireline or wireless Lifeline service.
_: The information contained in this Lifeline certification form is true and correct to the best of my knowledge.
_: I acknowledge that providing false or fraudulent information on this certification form, to receive Lifeline
benefits, is punishable by law.
_: I acknowledge that I may be required to recerti$ my eligibility for Lifeline at any time, and failure to
recertiff as to my continued eligibility will result in the de-enrollment and termination of my Lifeline
benefits pursuant to the Code ofFederal Regulation Section 5a.a05(eXa).
_: I understand that if violation of the one-per-household rule constitutes a violation of FCC rules and will result
in my de-enrollment from the Lifeline program.
_: If I provided a temporary address, I will be required to verifo my temporaq/ address every 90 days.
==-: I authorize Sage to release information concerning my service necessary to administer the Lifeline program
(such as name, address, telephone number) to the Universal Service Administrative Company. I give consent
to Sage to veri$ with the National Lifeline Accountability Database my eligibility in certain low-income
assistance programs or verifu my income to qualifo me for Lifeline service. Sage shall maintain the
information in this form and any information received about me from the National Lifeline Accountability
Database as confidential customer account information. Failure to provide consent will result in being
denied the Lifeline service.
Step 5. Sien Certification Form. You must print yow name and sigrr the certification form indicating that
you are complying with the Lifeline rules.
Signaure Printcd Namc Date
You may mail the completed Lifeline form to:Sage Telecom, Inc.
10440 N Cenhal Expressway
Suite 700
Dallas, TX7523l-2228
AK r2r920t:
For Srge Telccom, Ioc.'s Usc Only!
Lifeline Ccrtificarion Approval / Denial Service Order Provisioned By _ Date
Supporting Documcntation Provided
FEDERAL LIFELINE RECERTIFICATION FORM
Lifeline Information
o All Lifeline subscribers must annually recerti$ their continued eligibility in the Lifeline program.
o Lifeline is a Federal bencfit and willfully making false statcmcnts to obtain the benefit can result in fines, imprisonmcn!
de-enrollmsnt or being barred from the program.
o Only one Lifeline service is available per houschold- A household is define4 for purposes ofthe Lifeline progrsrn, as any
individual or group of individuals who live together at thc same address and share income and expenses.
o A household is not permined to receive Lifclinc benefits from multiple providers (wireline or wircless).o You must use your phonc cvery 60 days to maintain servicc. Usagc includcs making an outbound call, answering an
incoming call. Usage can also include thc purchase of additional minutes or payment of your monthly bill. If there is no
usage on your account for 60 days you will be de-enrolled from the program.
o Lifclinc is a non-transferable benefit and the subscriber may not transfer his or her bcnefit to any other person.
o Failure to rccertiry will result in being de-enrolled from the program and loss of the Lifeline credits.
Instructions for Completins the Attached Lifeline Recertification Form
Step l. Fill out the Customer Information Section. You must provide the last four digits of your Social
Security Number and date of birth.
Step 2. lndicate How You Continue to Oualify for Lifeline. Choose whether you continue to
participate in a qualiffing proeram or if your annual household income remains at or below the income guidelines.
Please choose Proeram-Based or IncomeBased elisibilitv. but not both.
Step 3. Determine If You Continue to Oualifr for Tribal Lifeline. (If Applicabte) Not all customers
will be eligible for the Tribal l,and benefit. To be eligible for Tnbal Lifeline seryice, the applicant must reside on
Federally reco gnized Tribal tand.
Step 4. Certifu Customer Eligibilitv. Each applicant must certiff, under penalty of perjury, to receive
Lifeline service, by initialine or checting ALL items under this section.
Step 5. Sim Certification Form. You must print your name and sigrr the certification form indicating that
you are complying with the Lifeline rules.
Step 6. Send in the Certification Form. Upon completion, please mail the completed form to:
Sage Teleconr, Inc.
10440 N Central Expressway
Suite 700
Dallas, TX7523l-222E
All steps a.re required except Step 3 above for processing of your recertification form.
Please send the completed Lifeline Recertification Form to Sage within 30 days upon receipt.
AK t2l 0l2
Saqe
Saqe
FEDERAL LIFELINE RECERTIFICATION FORM
Step 1. Customer Information Section
Name of Applicant:Number:
Account Number:Date of Birth:
Applicant's Service Address (May NOT be a P.O. BOX):
o Please check this box ifthe above address is a temporary address. last Four Digits of
Crty:Zip
Billing Address (if different from Service Address):
Step 2. Indicate How You Oualifv For Lifeline (Choose either #1- or #2)
If the person who receives the benefit is not the Sage account holder, then please provide the name of the person in
your household receiving the benefits:
(#l). I qualifu for Lifeline under the Prosram-Based Criteria because I participate in the following program(s):
Check only ONE box below:
o Medicaid (not Medicare) o Supplemeirtal Nutrition Assistance Program (SNAP)
o Supplemental Securiry Income (SSI) o Federal Public Housing Assistance (Section 8)
o Low Incomc Heat Energy Assistance Program (LIHEAP) o Temporary Assistance for Needy Families ([ANF)
o National School Lunch Program (Free Lunch Program)
(n). I qualifi for Lifeline under the [ncome-Based Criteria because my annual household income is at or below
135% of the federal pov€rty level guidelines. The number of individuals in my residential household is:
(Numbcr in household)
Annual Income 135% of Federal Poverly Level Thresholds Based on Household Size
I 2 3 4 5 For each additional person
$15,080 s20,426 $2s,772 $31,1 t8 $36,464 +$5,346 per p€rson
Step 3. Determine If You Oualifv for Tribal Lif-eline (If Applicable, Choose either #1 or#2)
My Tribal ID Number is:Check ONE box below:
(#l) o I qualiff for Tribal Lifeline service as an eligible resident on federally recogrrized tribal land.
(#2) I qualiff for Tribal Lifeline service as I participate in the following tribally administered program.
o Tribally Admin Free School Lunch Program o Tribally administered Ternporary Assistance for Needy Families
o Head Start (thosc meeting income standards) tr Bureau of Indian Affairs General Assistance
o Food Distribution Program on Indian Reservations (FDPIR)
AK 12t92012
Qrata.
Step 4. CERTIFY APPLICANT,S ELIGIBILITY
Please Check or Initial AII the statements below to certifu your continued eligibility.
I certify, under penallt of perju4t, that:
_: I continue to meet either the income-based or prograrn-based eligibility criteria.
_: I must notify Sage within 30 days if, for any reason, I no longer satisfu the criteria for receiving Lifeline
including, as applicable, if I no longer meet the income-based or program-based criteri4 I am receiving more
than one Lifeline service, or another member of my household is receiving a Lifeline service. I understand
this requirement to notiff Sage if my eligibility changes and that I may be subject to penalties if I fail to
follow this notifi cation requirement.
_: When I move to a new address. I must provide my new address to Sage within 30 days.
_: I knowledge that my household is eligible to receive only one Lifeline service and to the best of my
knowledge, no other member in my household is currently receiving wireline or wireless Lifeline service.
_: The information contained in this Lifeline certification form is true and correct to the best of my knowledge.
_: I acknowledge that providing false or fraudulent information on this certiflrcation form, to receive Lifeline
service, is punishable by law.
_: I understand that I may be required to recertiff my eligibilify for Lifeline at any time, and failure to recerti$
my continued eligibility will result in the de-enrollment and termination of my Lifeline service, pursuant to
the Code of Federal Regulation 47 Section 5a.a05(eXa).
_: I understand that if violation ofthe one-per-household rule constitutes a violation of FCC rules and will result
in my de-enrollment from the Lifeline program.
_: If I provided temporary address, I will be required to veriff my temporary address every 90 days.
_: I authorize Sage to release information concerning my service necessary to administer the Lifeline progrirm
(such as name, address, telephone number) to the Universal Service Administrative Company. I give my
consent for Sage to veriff with the National Lifeline Accountability Database whether I participate in certain
low-income assistance progmms or veriff my income to qualiff me for Lifeline service. Sage shall maintain
the information in this form and any information received about me from the National Lifeline
Accountability Database as confidential customer account information. Failure to provide consent will result
in being denied the Lifeline service.
Step 5. Sien Certification Form
You must print your name and sign the certification form indicating you are compllng with the Lifeline rules.
Signature Printed Name Dale
You may mail the completed Lifeline form to:Sage Telecom, Inc-
10440 N Central Expressway
Suite 700
Dallas, 'fX75231-2228
AK t21920r2
For Srge Telecom, Inc.'s Use Only!
Lifelinc Recertification Approval. / Denial
Lifeline Participaring Program / Income B"s.d C.it".ia
Servicc Order hovisioned By _ Date
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83201
83202
83203
83204
8320s
83205
83209
83210
83211
83212
83213
832L4
83215
832L1
83218
83220
8322L
83223
83226
83228
83230
83232
83233
83234
83236
83237
83238
83239
8324L
83243
83244
8324s
83246
83250
83251
83252
83254
83255
83256
83261
83262
83253
8327L
83272
83274
83276
83277
83278
83281
83283
8328s
83285
83287
83301
83302
83303
83311
833L2
83313
83314
83316
83318
83320
8332r,
83322
83323
83324
8332s
83327
83328
83330
83332
83333
83334
83335
83336
83337
83338
83340
83341
83342
83344
83345
83347
83348
83349
83350
833s2
83355
83401
83402
83403
83404
83405
83405
83414
83415
83420
83421
83422
83423
83424
83425
83427
83428
83429
83431
83433
83434
83435
83435
83438
83440
83441
83442
83443
83444
83445
83446
83448
83449
83450
83451
83452
83454
83455
83450
83464
83501
83522
83523
83524
83535
83537
83540
83541
83544
83555
83602
83604
8360s
83606
83607
83610
83611
83612
8351s
83616
83617
83619
83622
83623
83624
83626
83627
83628
83629
83630
83531
83532
83633
83534
83635
83537
83539
8364L
83642
83643
83644
83545
83545
83647
83648
836s0
83551
83552
83653
83654
83655
836s6
83557
83650
83561_
83555
83669
83670
83672
83676
83680
83686
83587
8370r.
83102
83703
83104
8370s
83705
83707
83708
83709
837tt
837t2
83713
837t4
837L5
837L6
83717
837t9
83120
83722
83724
83725
83726
83128
83729
8373L
83732
83735
83755
83799
83801
83803
83804
83805
83805
83809
83810
83811
83813
83814
838L5
83816
83821
83822
83823
83824
83825
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83827
83832
83833
83834
83835
83835
83837
83839
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83850
83851
83852
838s3
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83855
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83859
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Sage Telecom Communications, LLC dlbla TruConnect
Executive Bios
Nathan R. Johnson, Co-Chief Executive Officer
Nathan R. Johnson is Executive Chairman of the Board and an investor in Sage Telecom Communications,
LLC dlb/a TruConnect, where he oversees the strategic vision and effective governance of the
organization. Mr. Johnson is also a Managing Partner of Gemini Partners, a middle market investment
bank, where he has financed, sold, and advised several small and middle market telecommunications
companies including Telemac, Distributive Networks, and Pulse Entertainment among others. Prior to
Gemini Partners, Mr. Johnson served as Vice President in investment banking at Deutsche Bank, where
he advised several Latin American companies including Telefonos de Peru and a Venezuelan phone
company in their efforts to take the companies private. Mr. Johnson received his MBA from the Wharton
School at the University of Pennsylvania with a concentration in Finance and Multinational Management.
He also received his MA from the University of Pennsylvania with concentrations in Latin America and
Spanish.
Matthew H. Johnson, Co-Chief Executive Officer
Matthew Johnson is Managing Partner of Gemini Partners and a Board Member and investor of Sage
Telecom Communications, LLC d/b/aTruConnect. At Gemini Partners, a middle market investment bank,
Mr. Johnson has financed, sold, and advised several small and middle market telecommunications
companies including Telemac, Distributive Networks and Pulse Entertainment, among others. Previously,
Mr. Johnson was a Vice President in lnvestment banking at Credit Suisse First Boston where he financed
numerous telecommunications companies specifically located in Latin America, including Bestel
Communications, a company that operated fiber loops stretching from the US to Mexico, and Globopar a
telecommunications and media conglomerate based in Brazil. Mr. Johnson holds an MBA from
Northwestern University's Kellogg School of Management.
David Wilder, Chief Financial Officer
David Wilder is a CPA with over 30 years of broad industry experience that has included extensive
financial as well as operational responsibilities. David has held positions as President/CFO/Controller
with a variety of public and privately held companies in varying industries. They included both US and
international assignments.
David's initial professional experience out of college was as a CPA with Deloitte & Touche, 5 years, and
Arthur Andersen, 2 years. David left Deloitte & Touche in December of 1988 as a Manager working in
the Emerging Business Group. David graduated from the University of Southern California with a degree
in Business Administration.
Lucy Sung, General Manager, Global Operations
Ms. Sung is the General Manager of Global Operations for of Sage Telecom Communications, LLC d/b/a
TruConnect and leads the Legal, Compliance, Customer Care, Sales Operations, Human Resources, and
Billing Operations teams. She has over 30 years of experience in the wireless carrier industry, and has 15
years of experience managing the operations and expansion of wireless ETCs. She has held senior
management positions in companies that include AT&T, among others. Ms. Sung holds a Bachelor of
Science Degree in Business Administration.
Aleksandr Gudkov, Chief Technology Officer
Mr. Gudkov istheChief TechnologyOfficerforSageTelecom Communications, LLC dlblaTruConnectand
leads all Business lntelligence, data warehouse, and technology related initiatives. Mr. Gudkov has over
18 years of experience in information technology supporting private, state and local governments. He has
managed several large-scale integration and migration initiatives forthe California Lifeline program, CEL
child care eligibility system, and Arizona APS energy income eligibility program. Mr. Gudkov holds a
Master of Science degree in Nuclear Engineering from National Research Nuclear University, Moscow
Russia.
Danielle Perry, Chief lnformation Officer
Danielle Perry is the Chief lnformation Officer for Sage Telecom Communications, LLC d/b/a TruConnect
and is responsible for leading all technology related aspects of the business; from software development
to data analytics. Ms. Perry has over 20 years of experience in the telecommunications field, with 8 of
those years being focused on Lifeline. ln her previous position she was the Chief lnformation Officer at
Blue Jay Wireless.