20190301Decision Memo.pdf

DECISION MEMORAI{DUM
TO:COMMISSIONER KJELLANDER
COMMISSIONER RAPER
COMMISSIONER ANDERSON
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL
FROM:EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
DATE: FEBRUARY 27,2019
SUBJECT:APPLICATION OF SAGE TELECOM COMMUNICATIONS, LLC FOR
DESIGNATION AS AN ELIGIBLE TELECOMMUNICATIONS
CARRIER; CASE NO. SAG-T-19-01
On January 24, 2019, Sage Telecom Communications, LLC dba TruConnect
("TruConnect" or "Company") applied to the Commission for an Order designating it as an
eligible telecommunications carrier ("ETC") in the State of Idaho. The Company seeks ETC
designation solely to provide Lifeline service to qualifying Idaho consumers. Application at 1.
The Company states that it will not 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. Id. The Company requests its designation as an ETC include the authority to
participate in and receive reimbursement from the Idaho Telephone Service Assistance Program
("ITSAP"). Id. at2.
THE APPLICATION
TruConnect provides prepaid wireless telecommunications services to consumers by
using the underlying wireless networks of Sprint Spectrum, Verizon Wireless, andlor T-Mobile.
Id. at 3. The Company operates as a Mobile Virtual Network Operator ("M\TIO"). Id The
Company states that it is eligible for a forbearance from the Federal Communication
Commission's "own facilities" requirement because it seeks to provide Lifeline-only services.
Id. at l0-11. The Company is currently a designated ETC in 24 states and Puerto Rico. 1d at 3-
4. The Company states that it has the ability to provide all services supported by the universal
service program throughout Idaho. Id. at 4. The Company states that its Lifeline-supported
DECISION MEMORANDUM I
voice and broadband services will meet or exceed the applicable minimum service standards set
forth in 47 C.F.R. $ 54.408. Id. at 5. The Company's proposed Lifeline offerings will include
1,000 voice minutes, unlimited text messages, and 2 gigabytes of data per month at a net cost of
$0.00 per month after application of Lifeline support, with additional voice minutes and data for
purchase. 1d
STAFF RECOMMENDATION
Staff recommends that the Commission process TruConnect's Application under
Modified Procedure with a 21 day comment period and a seven day reply period.
COMMISSION DECISION
Does the Commission wish to process TruConnect's Application under Modified
Procedure with a 2l day comment period and a seven day reply period?
Edward J
Deputy General
I:\LegaIYI ELEPHONE\SAC-T- I 9-0 l\SAcT I 901 _dec memo_ej.doc
2DECISION MEMORANDUM