20210315Application.pdf

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March 15, 2021

Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission (PUC) of Idaho
11331 W. Chinden Blvd. Building 8, Suite 201-A
Boise, ID 83714

RE: Torch Wireless Application for Designation as an Eligible Telecommunications Carrier

Ms. Noriyuki:

Enclosed please find the application of Torch Wireless for Designation as an Eligible
Telecommunications Carrier in the State of Idaho.

If there are any questions on the documents, please feel free to contact me. Thank you.
Respectfully submitted,

Jorge E. Perea
Chief Executive Officer, Torch Wireless
[e-mail]
904.720.4505

RECEIVED
2021March 15, PM 3:52
IDAHO PUBLIC
UTILITIES COMMISSION
2

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

In the matter of the application of Torch Wireless for
Designation as an Eligible Telecommunications Carrier.
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APPLICATION OF TORCH WIRELESS
FOR DESIGNATION AS AN ELIGIBLE TELECOMMUNICATIONS CARRIER

Torch Wireless (“Torch” or the “Company”), pursuant to Section 214(e)(2) of the
Communications Act of 1934, as amended (the “Act”)1, 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 entire State of Idaho (including Tribal Lands) for local
exchange services in the designated service area, for the purpose of receiving federal universal service
supported. The Company is seeking only low-income support to provide Lifeline services to qualifying
consumers in the state of Idaho. The Company is not seeking nor requesting high-cost support.4 Torch
requests that its designation as an ETC include the authority to participate and receive reimbursement
from the Idaho Telephone Service Assistance Program (ITSAP). As demonstrated herein, and as
certified in this Application, Torch satisfies all the statutory and regulatory requirements for designation
as an ETC in the Designated Service Area, including the requirements outlined in the FCC’s Lifeline

1 47 U.S.C. § 214(e)(2).
2 47 C.F.R. §§ 54.101-54.207.
3 See In the Matter of the Application of Sage Telecom Communications, LLC dba TruConnect Seeking Designation
as an Eligible Telecommunications Carrier that may receive Federal Universal Service Support, Commission Order
No. 34266 (March, 7, 2019).
4 Given that Torch only seeks support from the low-income program and does not seek any high-cost support, ETC
certification requirements for the high-cost program are not applicable to the Company.

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and Link Up Reform Order5 and Lifeline Modernization Order.6 Furthermore, designation of the
Company in the Designated Service Area will serve the public interest as it would enable the Company
to commence Lifeline service to low-income Idaho residents. Accordingly, Torch respectfully requests
that the Commission grant this application.
All correspondence, including but not limited to, notices and decisions related to this
Application, as well as communications for the Company, should be addressed to:

Torch Wireless
Regulatory Department
4320 Deerwood Lake Parkway, Suite 101-158
Jacksonville, FL 32216
Office: 904-574-4130
Fax: [phone]
[e-mail]

5 In the Matter of Lifeline and Link Up Reform and Modernization, Lifeline and Link Up, Federal-State Joint Board
on Universal Service, Advancing Broadband Availability Through Digital Literacy Training, WC Docket No. 11-42,
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 12-11 (rel. Feb. 6, 2012) (hereafter “Lifeline and Link Up Reform Order”).
6 In the Matter of Lifeline and Link Up Reform and Modernization, Telecommunications Carriers Eligible for
Universal Service Support, Connect America Fund, WC Docket No. 11-42, WC Docket No. 09-197, WC Docket No.
10-90, Third Report and Order, Further Report and Order, and Order on Reconsideration, FCC 16-38 (rel. Apr. 27,
2016) (hereafter “Lifeline Modernization Order”).
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I. INTRODUCTION
Torch Wireless is incorporated in the state of Wyoming and is authorized to conduct business as a
foreign corporation in the state of Idaho. A copy of the authorization to do business is attached as
Exhibit A, “Certificate of Registration”. Its corporate address is 4320 Deerwood Lake Parkway, Suite
101-158, Jacksonville, Florida, 32216. Torch is a facilities-based Competitive Local Exchange Carrier
(CLEC), Inter-Exchange Carrier (IXC), Commercial Radio Mobile Services (CMRS) provider, and an
Eligible Telecommunications Company (ETC) in the state of Wisconsin. The Company was granted a
Facilities Based Alternative Telecommunication Utility via Wisconsin docket 18015-NC-100 dated
August 9, 2017, attached as Exhibit B, “Alternative Local Exchange Carrier Other Certification”. The
Company will provide services in the designated service area using their own facilities or a combination
of their own facilities and the resale of another carrier’s services.
Torch currently provides prepaid and Lifeline wireless telecommunications services and its network is
integrated with Sprint Spectrum, L.P. (“Sprint”), Verizon Wireless (“Verizon”), and T-Mobile US, Inc.
(“T-Mobile”), in order to provide network and transport services. This includes, but is not limited to, a
series of local loops that interconnect to the Torch Wireless network and switching facilities. Torch
Wireless may also obtain additional commercial agreements for end-to-end switching and delivery of
calls purchased from other ILECs servicing Idaho, if needed.
A. Torch’s Lifeline Offering
Lifeline is a component of one of the four separate federal universal service fund mechanisms
known as the “low-income support mechanism” and is defined in 47 C.F.R § 54.401 as “a retail
local service offering” available only to qualified low-income consumers for which qualifying low-
income consumers pay reduced charges as a result of application of the Lifeline support amount
that includes the services or functionalities enumerated in 54.401(a)(1) through (a)(9), which the
Company will use to “make Lifeline services available to qualifying low-income consumers.” In its
Lifeline Modernization Order, the FCC created minimum service standards for wireless ETC
carriers with requirements as of December 1, 2020 set at 1000 minutes per month. Further, the
Lifeline Modernization Order requires that Lifeline-supported broadband plans provide at least 4.5
GB monthly as of December 1, 2020. Torch will comply with the current and future minimum
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service requirements set out in the Lifeline Modernization Order, with several plans already in
compliance. The Company’s Rate Plans are attached as Exhibit C, “Torch Wireless Rate Plans”.
B. Plan Enrollment
Consumers interested in obtaining information on the Lifeline program will be able to contact Torch
via a toll-free number or the Company’s website, where information regarding the Company’s
Lifeline service plans will be provided, along with a description of the Lifeline program and eligibility
criteria. To obtain service, consumers will apply in-person for Lifeline through the National Verifier
service provider portal, or on their own through the National Verifier consumer portal. They may
also submit a paper application utilizing the standardized Lifeline Program Application Form,
attached as Exhibit D, “USAC Lifeline Consumer Forms”, as required by FCC rules, complying
with the disclosure and information collection requirements in 47 C.F.R. § 54.410(d).7 Upon
approval, Torch will assist consumers in completing their enrollment in their Lifeline qualified plan
of choice and ensure Consumers understand continuing eligibility requirements to maintain
service.
C. Prevention of Waste, Fraud, and Abuse
Torch recognizes the importance of safeguarding the Universal Service Fund from potential waste,
fraud, and abuse. Torch relies on the National Verifier8 for the initial and ongoing determination of
a subscriber’s eligibility to qualify for Lifeline through the income-based eligibility criteria or
program-based criteria set forth in C.F.R § 54.410. Further, Torch complies with the requirements
of the National Lifeline Accountability Database (“NLAD”) and section 54.404 of the FCC rules.
Through these processes, Torch can ensure applicants adhere to the “One Lifeline Benefit per
Household” requirement.

7 FCC Wireline Competition Bureau Provides Guidance on Universal Forms for 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, Forms, Lifeline Application https://www.usac.org/lifeline/additional-requirements/forms/).
8 See Lifeline and Link Up Reform and Modernization, Telecommunications Carriers Eligible for Universal Service
Support, Connect America Fund, WC Docket No. 11-42, WC Docket No. 09-197, WC Docket No. 10-90, Third
Report and Order, Further Report and Order, and Order on Reconsideration, FCC 16-38 (rel. Apr. 27, 2016) (hereafter
“Lifeline Modernization Order”), section III.C.
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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. § 54.407(c)(2). An account will be considered active if the authorized
subscriber establishes usage, as "usage" is defined by 47 C.F.R. § 54.407(c)(2), during the
specified timeframe, currently a period of thirty (30) days, or during the notice period (“cure 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. § 54.405(c)(3), Torch 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. Consumers 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, Torch contracts with a third-party Lifeline service firm
to verify and audit all subsidy request data, prior to request for support funds.
II. TORCH MEETS THE STATUTORY AND REGULATORY REQUIREMENTS FOR ETC
DESIGNATION
Torch Satisfies the Requirements for Designation as an ETC. Section 254(e) of the Act provides that
“only an eligible telecommunications carrier designated under section 214(e) shall be eligible to receive
specific federal universal service support.” Section 214(e)(2) 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.9 Section 214(e)(1) 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. Applicants also must

9 See Federal-State Joint Board on Universal Service, First Report and Order, 12 FCC Rcd. 8776, 8858-59, ¶ 145
(1997) (“USF Order”).

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commit to advertise the availability and rates of such services.10 As detailed below, Torch Wireless
satisfies each of the above-listed requirements.
A. Torch Is a Common Carrier as defined in the Act. The Company will provide supported services
in the state of Idaho, pursuant to Section 214(e)(1).
B. Torch will provide Universal Services using a combination of its own facilities and resale.
Section 214(e)(1)(A) requires that a carrier must use its own facilities or a combination of its own
facilities and resale of another carrier’s facilities in order to provide universal service supported
services. Torch’s network supports the provision of wireless voice telephony, utilizing a
combination of elements provided by a national wireless carrier and Torch’s own facilities. The
network details are confidential and proprietary and included in Confidential Exhibit H, “Torch
Wireless Network Description.”
C. The services that are supported by the Federal Universal support mechanisms under section
254(c) are:
a. Voice Telephony Service
i. Voice Grade Access to the Public Switched Telephone Network – The ability to
transmit and receive communications with a minimum bandwidth of 300 to 3,500 Hertz
(47 C.F.R § 54.101(a)(1)). Torch meets this requirement through its provision of voice
communications service and interconnection to the public switched telephone network.
ii. Local Usage – An amount of minutes of use provided free of charge to end users (47
C.F.R. § 54.101(a)(2)).
iii. Access to Emergency Services – Access to emergency services includes
both access to 911 and E911 services to the extent the local government
has implemented such services (47 C.F.R. § 54.101(a)(5)). Torch meets this
requirement by providing access to 911 services and meeting all requests for access
to E911 services through local public service answering points ("PSAPs").
b. Broadband Internet Access Services

10 See 47 U.S.C. § 214(e)(1) and 47 C.F.R. § 54.201(d)(2).
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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 Internet access service."11 Torch
provides BIAS to low-income consumers combination of their own facilities and the
resale of another carrier’s services.
D. Torch Will Advertise the Availability and Rates for Its Services. Upon certification as an ETC,
Torch will participate in, and offer Lifeline services to qualifying low-income consumers and
publicize the availability of the lifeline services in a manner reasonably designed to reach those
likely to qualify for those services, as required by FCC Rules. A sample advertisement of state-
specific advertisement is attached as Exhibit E.
Torch will advertise the availability of the above-referenced services and the charges for those
services in the Designated Service Area using media of general distribution, as required by FCC
Rules. The current zip code coverage footprint in attached as Exhibit F.
E. Commitment to Consumer Protection and Service Quality Standards. 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.12 Torch hereby commits to comply with the CTIA Consumer Code for
Wireless Service.
F. Inapplicability of Five-Year Network Improvement Plan
As set forth in 47 C.F.R. § 54.202(a)(1)(i), 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.

11 See 47 C.F.R. § 8.2(a).
12 See 47 C.F.R. § 54.202(a)(3).
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G. Ability to Remain Functional in Emergency Situations
In accordance with 47 C.F.R. § 54.202(a)(2), through its underlying carrier agreements, Torch has
the ability to remain functional in emergency situations. The Company and its underlying carriers’
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. These underlying carriers have
repeatedly certified to the FCC that their networks function in emergency situations.13 The
underlying carriers provide the same functionality to Torch and its Consumers as these carriers
provide to themselves and their own Consumers.
H. Financially and Technically Capable
In accordance with 47 C.F.R. § 54.202(a)(4), Torch is financially and technically
capable of providing Lifeline-supported services. The Company has been offering
telecommunications services since 2016, including the provision of wire-line transport services to
telecommunications carriers, strategic partners, and vendors. In January 2018, Torch began
providing Lifeline and non-Lifeline wireless services. As such, Torch dos not offer exclusively
Lifeline supported service only, and therefore is not exclusively dependent on a regulatory
governing body for its revenue. Torch has not been subject to enforcement actions or license
revocation proceedings in any state. The Company is financially sound and assuredly capable of
honoring its service obligations to Consumers and also its regulatory obligations to the FCC and
State of Idaho regulators.
Furthermore, the senior management of Torch has extensive business and managerial expertise,
with an established record in the operations, marketing, and delivery of telecommunications
services, including wireless.

13 See, e.g., Sprint Nextel Corporation Verified Filing in Compliance with 47 C.F.R.§ 54.209, CC Docket No. 96-45,
at 6 (filed Sept. 30, 20ll); In the Matter of Telecommunications Carriers Eligible for Universal Service 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).
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I. Compliance with All Regulations Imposed by The Commission
By this Application, Torch hereby makes known its ability and also its willingness to fully comply
with all the rules and regulations that the Commission lawfully imposes upon the provision of
service as stated and detailed within this Application. Torch 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. Torch 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 non-applicable Commission Rules, Commission Order No. 29841 Section B.1 (two-year
network improvement and maintenance plan based on high-cost support).
III. DESIGNATION OF TORCH AS AN ETC WOULD PROMOTE THE PUBLIC INTEREST
One of the primary objectives dictated by the Telecommunications Act of 1996, as amended; 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.14
Designation of Torch as an ETC in Idaho will further the public interest by providing Idaho consumers,
especially low-income consumers, with low prices and high-quality services. Many low-income
Consumers have yet to reap the full benefits of the intensely competitive wireless market, whether
because of economic or financial constraints, employment impacts, or poor credit history.
The benefit given to a consumer having the ability to make a conscious choice and to choose from
multiple providers has been recognized by the FCC for decades.15 Designation of Torch as an Eligible
Telecommunications Carrier will promote competition and encourage other carriers to seek to engage
low-income consumers. The presence of additional providers results in diversity of options, greater
innovation for consumers, competitive pricing, and enhanced service experiences. Both the new
entrant and existing providers in a communications market are incented to offer consumers more

14 Telecommunications Act of 1996, Pub. L. No. 104-104, 110 Stat. 56.
15 See Virgin Mobile Order, 24 FCC Red at 3395 38.
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attractive service and more favorable terms. Introducing Torch into the market as a wireless ETC
provider will afford low-income residents a wider and more broad choice of providers and available
services thus creating a more competitive marketplace as ETC's compete for a specific number of
Lifeline-eligible Consumers. By overall increasing the competitive marketplace and number of
providers within the market, the Commission has the ability to significantly increase the number of
consumers consumption of wireless service and decrease the overall number of peoples who have no
connection to the Public Switched Telephone Network
A. Impact on the Universal Service Fund
Torch’s request for designation as an ETC solely for the purposes of participating in the Lifeline
program would not unduly burden the USF or otherwise reduce the amount of funding available to
other ETCs, as with Lifeline, they only receive support for Consumers they obtain with Lifeline. The
amount of support available to any potential consumer is the same whether the Lifeline support is
given through Torch, any other ETC, and/or an ILEC operating in the same service area(s).
Torch will therefore only increase the amount of USF Lifeline funding in situations where it obtains
Lifeline Consumers that are not presently enrolled in another ETC's Lifeline program. By
implementing all the mandates, requirements, and parameters as set forth in the Lifeline and Link-
Up Reform Order, and utilizing National Verifier and NLAD, Torch will decrease the possibility that
its consumers are not eligible or are presently receiving support either individually or within their
household. In accordance, Torch’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. Any incremental increases in Lifeline expenditures far outweigh the
significant public interest benefits of expanding the availability of affordable wireless services to
low-income consumers.
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IV. CONCLUSION
Torch respectfully requests designation as an ETC for the Designated Service Area for the purpose of
receiving federal low-income universal service support.

Respectfully submitted,

Torch Wireless
Jorge E. Perea, Chief Executive Officer

Dated ___________________

EXHIBIT A
CERTIFICATE OF REGISTRATION

EXHIBIT B
ALTERNATIVE LOCAL EXCHANGE CARRIER OTHER CERTIFICATION

PUBLIC SERVICE COMMISSION OF WISCONSIN

Application of Torch Wireless for Certification as a Competitive Local
Exchange Carrier and Alternative Telecommunications Utility
18015-NC-100

FINAL DECISION GRANTING CERTIFICATION
AS A COMPETITIVE LOCAL EXCHANGE CARRIER
Introduction
On July 19, 2017, Torch Wireless (Torch) filed an application to be certified as a
competitive local exchange carrier (CLEC). (PSC REF#: 328370.) Torch, pursuant to Wis. Stat.
§ 196.203, seeks certification as an alternative telecommunications utility under the “other”
category (ATU-other), defined in Wis. Stat. § 196.01(1d)(f), to provide intrastate intraLATA and
interLATA toll and local exchange services. A list of persons interested in this proceeding may
be found in Appendix A.
Background
On September 21, 2016, Torch Wireless registered with the Public Service Commission
of Wisconsin (Commission) as a Voice over Internet Protocol (VoIP) provider. Torch is now
seeking certification as a CLEC.
2011 Wisconsin Act 22 (Act 22), also known as the Telecommunications Modernization
Act, became effective on June 9, 2011. Act 22 significantly modified Wis. Stat. ch. 196 relating
to the regulation of telecommunications utilities and telecommunications services in Wisconsin.
Act 22 implements a clear intention to level the regulatory playing field among competitors by
imposing similar regulations on competing entities.
PSC REF#:329480
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Docket 18015-NC-100

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In a Final Decision1 issued July 12, 2011, the Commission granted a recertification to
Wisconsin Bell, Inc., d/b/a AT&T Wisconsin that addressed many issues related to the
new recertification process arising from Act 22. Since the AT&T Wisconsin recertification in
docket 6720-NC-100 was also as an ATU, the Final Decision in that case addressed the
application of the “parity provision” in Wis. Stat. § 196.203(3) (“If the commission imposes a
provision of this chapter specified in sub. (4m)(a) on an [ATU] under this subsection, the
commission shall impose the same provision at the same level of regulation on all other
alternative telecommunications utilities.”). Following on its determinations in
docket 6720-NC-100, the Commission also recertified numerous entities, specifically affiliates of
CenturyTel, Frontier, and TDS Telecom.2 Due to the enactment of Act 22 and the above-cited
decisions, the Commission will grant this application with a reduced level of regulation subject
to the parity provision.
The Commission delegated the issuance of this type of Final Decision to the Division
Administrator of the Division of Water, Telecommunications and Consumer Affairs based on the
guidance provided in previous dockets involving recertification pursuant to the provisions of
Act 22.
Findings of Fact
1. Torch is qualified by the Wisconsin Department of Financial Institutions to do
business in Wisconsin.

1 See “Final Decision Granting Recertification as an Alternative Telecommunications Utility, Notice of Wisconsin
Bell, Inc., d/b/a AT&T Wisconsin to Terminate Certificate Under Wis. Stat. § 196.50 and Become Certified as an
Alternative Telecommunications Utility Under Wis. Stat. § 196.203, Docket No. 6720-NC-100 (July 12, 2011).
2 CenturyTel affiliates were recertified ATUs under Wis. Stat. § 196.50(2)(j)1.a., similar to AT&T Wisconsin.
Frontier and TDS Telecom affiliates were granted recertification as “telecommunications utilities” pursuant to Wis.
Stat. § 196.50(2)(j)1.b.
Docket 18015-NC-100

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2. Torch represents that it has the financial resources, managerial ability, and
technical expertise to adequately provide its proposed telecommunications services.
No information to the contrary has come to the Commission’s attention.
3. It is consistent with Wis. Stat. § 196.203(2)(b) to reflect Torch’s certification as
statewide in geographical scope.
4. The following statutes must be applied to Torch: Wis. Stat. §§ 196.01, 196.016,
196.025(6), 196.191, 196.206, and 196.212.
5. The Commission may apply to Torch’s certification a number of statutes: Wis.
Stat. §§ 196.02(1), (4), and (5); 196.04; 196.135; 196.14; 196.197(1), (2), and (4); 196.199;
196.207; 196.208; 196.209; 196.218; 196.219(1), (2)(b), (c), and (d); (2r); (3)(a), (d), (j), (m), (n)
and (o); 196.25; 196.26; 196.39; 196.395; 196.40; 196.41; 196.43; 196.44; 196.65; 196.66;
196.81; 196.85; 196.858 and 196.859.
6. The Commission finds it in the public interest to impose certain statutes with
respect to Torch’s intrastate switched access services, specifically Wis. Stat. §§ 196.03(1)
and (6), 196.37 and 196.212; and, with respect to Torch’s wholesale telecommunications
services only, Wis. Stat. §§ 196.03(1) and (6), 196.219(4), 196.28, and 196.37.
7. It is not necessary in this Final Decision to determine the application of the parity
provisions of Wis. Stat. § 196.203(3) to different types of ATUs.
8. It is not necessary in this Final Decision to interpret the meaning of
"switched access service" in Wis. Stat. § 196.01(8e) as that definition relates to Extended Area
Service (EAS) and Extended Community Calling (ECC).
Docket 18015-NC-100

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9. It is not necessary to address in this Final Decision the potential that historical,
informal arrangements with other providers may be changed in light of Act 22.
10. It is reasonable to continue to apply any previous orders, rules, or Commission
determinations that are not inconsistent with Act 22.
Conclusions of Law
1. The Commission concludes it has jurisdiction pursuant to Wis. Stat. §§ 196.02(1),
196.395, and 196.203 to certify Torch as a competitive local exchange carrier in the ATU-other
category. This certification under Wis. Stat. § 196.203(3) and (4m), with the imposition of
statutes described above in Findings of Fact Nos. 4, 5, and 6, is in the public interest and
complies with applicable law.
2. The Commission has authority under Wis. Stat. § 15.02(4) to delegate to the
Administrator of the Division of Water, Telecommunications and Consumer Affairs those
functions vested by law as enumerated above.
3. It is consistent with Wis. Stat. § 196.203(2)(b) in this certification to reflect
Torch’s certification as statewide in geographical scope.
4. It is reasonable, in the public interest, and consistent with the Commission’s prior
decision in docket 6720-NC-100 as applicable here, to act, or refrain from acting, as set forth
herein in certifying Torch under Wis. Stat. § 196.203(2)(a).
Opinion
The Commission concludes that the public interest is best served by imposing on Torch
the same statutes imposed on AT&T Wisconsin in docket 6720-NC-100.
Docket 18015-NC-100

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The public interest supports the imposition of the statutes listed in Findings of Fact
Nos. 4, 5 and 6. Those statutes contribute to leveling regulation among competitors in the
telecommunications service market in this state, thereby removing potentially distorting effects
of differential regulation and maximizing competition consistent with Wis. Stat. §§ 133.01
and 196.03(6)(a). This reduced, “levelized” regulation, when combined with the statewide
certification for ATUs effected by Wis. Stat. § 196.203(2)(b), also contributes to the public
interest by promoting consumer choice, deployment of telecommunications infrastructure, and
efficiency and productivity. See Wis. Stat. § 196.03(1) and (6)(b), (e), and (f). Other public
interest factors listed in Wis. Stat. § 196.03(6) are either not relevant or outweighed by the
foregoing cited factors.
Torch’s request for certification does not alter some issues identified in
docket 6720-NC-100. Specifically, this decision does not resolve the “carry over” issues, or
allow for differing treatments, as to the following: (1) the meaning of “switched access service”
in Wis. Stat. § 196.01(8e); (2) any changes in treatment or status of historical, informal
arrangements between providers in light of Act 22; (3) any application to, or effect on, rights,
duties or privileges that Torch may have under federal law; (4) reservation of a right to seek
certificate modifications to continue parity of regulatory treatment; and (5) intended continued
application of previous orders, rules or Commission determinations that are not inconsistent with
Act 22. See Final Decision, docket 6720-NC-100, at 4-5, and 10-11.
The Commission’s issuance of this certification for Torch is consistent with Wis. Stat.
§ 196.203, the precedential guidance of the Final Decision in docket 6720-NC-100, and the
public interest as framed by Wis. Stat. § 196.03(1) and (6).
Docket 18015-NC-100

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Order
1. This Final Decision shall be effective one day after the date of service.
2. Torch is granted certification as an alternative telecommunications utility as set
forth in the certificate below.
3. In the event that future Commission action implicates the parity provisions of
Wis. Stat. § 196.203(3) and impacts Torch’s certificate, Torch shall provide notice to the
Commission that it desires to be issued a new certificate reflecting the change in regulation.
4, The Commission retains jurisdiction.
Certificate
Torch Wireless, as of the effective date of this Final Decision, is a telecommunications
utility per Wis. Stat. § 196.01(10), an ATU per Wis. Stat. § 196.01(1d)(f), certified per Wis. Stat.
§§ 196.203(2)(a), and authorized throughout Wisconsin to offer facilities-based and resold
intrastate telecommunications services, access services, and all other telecommunications
services available for certification.
Torch Wireless, shall be subject to the following statutory provisions: Wis. Stat.
§§ 196.01; 196.02 (1), (4), and (5); 196.04; 196.016; 196.025(6); 196.135; 196.14; 196.191;
196.197(1), (2) and (4); 196.199; 196.206; 196.207; 196.208; 196.209; 196.212; 196.218;
196.219(1), (2)(b), (c), and (d), (2r), and (3)(a), (d), (j), (m), (n), and (o); 196.25; 196.26; 196.39;
196.395; 196.40; 196.41; 196.43; 196.44; 196.65; 196.66; 196.81; 196.85; 196.858; and 196.859.
With respect to wholesale telecommunications services only, Torch Wireless shall be
subject to the following additional provisions of Wis. Stat. ch. 196: Wis. Stat. §§ 196.03(1) and
(6), 196.219(4), 196.28, and 196.37.
Docket 18015-NC-100

7

With respect to its intrastate switched access services only, Torch Wireless shall be
subject to the following additional provisions of Wis. Stat. ch. 196: Wis. Stat. §§ 196.03(1) and
(6), and 196.37.
To the extent the Commission later chooses not to impose a provision listed in section
Wis. Stat. § 196.203(4m)(a) on any ATU, pursuant to Wis. Stat. § 196.203(3), Torch Wireless
shall be provided the same regulatory relief and shall provide notice to the Commission that it
desires to be issued a new certificate reflecting that change in regulation.
All regulatory requirements related to Torch Wireless’ certification that are not
inconsistent with 2011 Wisconsin Act 22 or this certificate, apply to Torch Wireless.

Dated at Madison, Wisconsin, August 8, 2017.

For the Commission:

Steven A. Knudson
Administrator
Division of Water, Telecommunications, and Consumer Affairs

SAK:KN:PRJ: DL:01557300

See attached Notice of Rights

Docket 18015-NC-100

8

PUBLIC SERVICE COMMISSION OF WISCONSIN
610 North Whitney Way
P.O. Box 7854
Madison, Wisconsin 53707-7854

NOTICE OF RIGHTS FOR REHEARING OR JUDICIAL REVIEW, THE
TIMES ALLOWED FOR EACH, AND THE IDENTIFICATION OF THE
PARTY TO BE NAMED AS RESPONDENT

The following notice is served on you as part of the Commission's written decision. This general
notice is for the purpose of ensuring compliance with Wis. Stat. § 227.48(2), and does not
constitute a conclusion or admission that any particular party or person is necessarily aggrieved or
that any particular decision or order is final or judicially reviewable.

PETITION FOR REHEARING
If this decision is an order following a contested case proceeding as defined in Wis. Stat.
§ 227.01(3), a person aggrieved by the decision has a right to petition the Commission for
rehearing within 20 days of the date of service of this decision, as provided in Wis. Stat. § 227.49.
The date of service is shown on the first page. If there is no date on the first page, the date of
service is shown immediately above the signature line. The petition for rehearing must be filed
with the Public Service Commission of Wisconsin and served on the parties. An appeal of this
decision may also be taken directly to circuit court through the filing of a petition for judicial
review. It is not necessary to first petition for rehearing.

PETITION FOR JUDICIAL REVIEW
A person aggrieved by this decision has a right to petition for judicial review as provided in Wis.
Stat. § 227.53. In a contested case, the petition must be filed in circuit court and served upon the
Public Service Commission of Wisconsin within 30 days of the date of service of this decision if
there has been no petition for rehearing. If a timely petition for rehearing has been filed, the
petition for judicial review must be filed within 30 days of the date of service of the order finally
disposing of the petition for rehearing, or within 30 days after the final disposition of the petition
for rehearing by operation of law pursuant to Wis. Stat. § 227.49(5), whichever is sooner. If an
untimely petition for rehearing is filed, the 30-day period to petition for judicial review commences
the date the Commission serves its original decision.3 The Public Service Commission of
Wisconsin must be named as respondent in the petition for judicial review.

If this decision is an order denying rehearing, a person aggrieved who wishes to appeal must seek
judicial review rather than rehearing. A second petition for rehearing is not permitted.

Revised: March 27, 2013

3 See Currier v. Wisconsin Dep’t of Revenue, 2006 WI App 12, 288 Wis. 2d 693, 709 N.W.2d 520.
Docket 18015-NC-100

9

APPENDIX A

This docket proceeding is not a contested case under Wis. Stat. ch. 227, therefore there
are no parties as defined in Wis. Stat. § 227.01(8), to be listed or certified under Wis. Stat.
§ 227.47. However, the persons listed below are defined by Wis. Admin. Code
§ PSC 2.02(7), (10), and (12) as parties in the docket and participated therein.

Public Service Commission of Wisconsin
(Not a party but must be served)
610 North Whitney Way
P.O. Box 7854
Madison, WI 53707-7854

Torch Wireless
Jorge E. Perea, Managing Partner
4320 Deerwood Lake Parkway, Suite 101-158
Jacksonville, FL 32216
904-701-8424
[e-mail]

EXHIBIT C
TORCH WIRELESS RATE PLANS

2021

IDAHO SERVICE PLANS

TOP UP PLANS PLAN DETAIL

Essentials Essentials 1GB Essentials 4.5GB Unlimited 1 GB Unlimited 4.5GB

Tribal Lifeline Cost - - No charge No charge $30.00/mo.
Non-Tribal Lifeline Cost No Charge $10.00/mo. $30.00/mo. $30.00/mo. $60.00/mo.
Non-Lifeline Cost $10.00/mo. $20.00/mo. $40.00/mo. $40.00/mo. $70.00/mo.

Data - 1 GB 4.5GB 1 GB 4.5 GB
Voice Minutes 1000 1000 1000 Unlimited Unlimited
SMS Text Messages 1000 1000 1000 Unlimited Unlimited
Service Protection1 Included Included Included Included Included
Free Smartphone - - Included Included Included
Voice Text Data

Add 100 $3.00 $1.00 $3.00
Add 250 $6.00 $3.00 $6.00
Add 500 $10.00 $6.00 $10.00
Add 1000 $15.00 $10.00 $15.00
Include

• Nationwide Calling • Caller ID
• Call Waiting • Call Forwarding
• 3-Way Calling • Voicemail

• Plan, pricing, and features offered, where coverage is available.
• Plan features refresh every 30 days.
• Bring Your Own Device (BYOD) service available.
• No Contracts, Deposits, or Credit Check required.

Service Protection1 – Optional; Applies to Paid Plans Only. If service is not used for 45 consecutive days, the account will move to a service protection plan, reducing the monthly cost to $1.00/mo. Once on
the protection service plan, any usage (call, text, or data) will revert the service back to the original plan and pricing.

Top Ups are valid for 90 days from the date of purchase.
Values are assigned in the respective units.

EXHIBIT D
USAC LIFELINE CONSUMER FORMS

OMB APPROVAL EDITION 3060-0819
Lifeline Program Application Form
Page 1 of 8 Universal Service Administrative Company | www.lifelinesupport.org
Need help? Call the Lifeline Support Center at 1-800-234-9473
FCC FORM 5629
1.
About
Lifeline
Lifeline is a federal
benefit that lowers the
monthly cost of phone
or internet service.
Rules
If you qualify, your household can get Lifeline for phone or internet service, but not both.
• If you get Lifeline for phone service, you can get the benefit for one mobile phone or one home
phone, but not both.
• If you get Lifeline for internet service, you can get the benefit for your mobile phone or your home
connection, but not both.
• If you get Lifeline for bundled phone and internet service, you can get the benefit for your mobile
phone bundled service or your home bundled service, but not both.
Your household cannot get Lifeline from more than one phone or internet company.
You are only allowed to get one Lifeline benefit per household, not per person. If more than one person in
your household gets Lifeline, you are breaking the FCC’s rules and will lose your benefit.
What is a household?
A household is a group of people who live together and share income and expenses (even if they are not
related to each other).
Do not give your benefit to another person
Lifeline is non-transferable. You cannot give your Lifeline benefit to another person, even if they qualify.
Be honest on this form
You must give accurate and true information on this form and on all Lifeline-related forms or questionnaires. If
you give false or fraudulent information, you will lose your Lifeline benefit (i.e., de-enrollment or being barred
from the program) and the United States government can take legal actions against you. This may include (but
is not limited to) fines or imprisonment.
You may need to show other documents
If the Lifeline Program Administrator is not able to validate that you or someone in your household qualify
using this form and electronic databases, you may need to provide an official document from one of the
government qualifying programs or documentation that proves your annual income. You can submit copies
of your official documents with this application or wait until the Lifeline Program Administrator asks you for
them. To add them now, include the documents in option 1 or option 2 below
1. If you qualify through a government program, provide a copy of a document such as an approval
letter or benefit letter with the name of the person in your household who qualifies, name of the
program, and issue date within the past 12 months or future expiration date.
2. If you qualify through your income, provide a copy of the prior year’s state, federal, or Tribal
tax return or a current income statement from an employer or paycheck stub for 3 consecutive
months (or other accepted documents).
Visit lifelinesupport.org to see all acceptable document guidelines.
Apply
To apply for a Lifeline benefit, fill out the required
sections of this form, initial every agreement
statement, and sign on page 6.
Mail the form to this address
USAC
Lifeline Support Center
P.O. Box 7081
London, KY 40742
OMB APPROVAL EDITION 3060-0819
Lifeline Program Application Form
Page 2 of 8 Universal Service Administrative Company | www.lifelinesupport.org
Need help? Call the Lifeline Support Center at 1-800-234-9473
FCC FORM 5629
What is your full legal name?
The name you use on official documents, like your Social Security Card or State ID. Not a nickname.
What is your phone number (if you have one)?

First
2a.
Your
Information
All fields are required
unless indicated. Use only
CAPITALIZED LETTERS
and black ink to fill out
this form.
What is your date of birth?

Month Day Year
What is your email address (if you have one)?
What are the last 4 numbers of your Social Security Number (SSN)?
If you do not have a SSN, what is your Tribal Identification Number?
Middle (optional)Suffix (optional)
Last
What is the best way to reach you?
email phone* text message* mail
*If I selected the phone or text option, I consent to let USAC contact me at my Lifeline phone
number for important reminders and updates to my Lifeline service.
If I selected the text message option, message and data rates may apply.
Text STOP to end messages.
OMB APPROVAL EDITION 3060-0819
Lifeline Program Application Form
Page 3 of 8 Universal Service Administrative Company | www.lifelinesupport.org
Need help? Call the Lifeline Support Center at 1-800-234-9473
FCC FORM 5629
2b.
Your
Information
(continued)
* Tribal lands include any federally recognized
Indian tribe’s reservation, pueblo, or colony,
including former reservations in Oklahoma
Alaska Native regions established pursuant to
the Alaska Native Claims Settlement Act (85
Stat. 688) Indian allotments Hawaiian Home
Lands—areas held in trust for Native Hawaiians
by the state of Hawaii, pursuant to the Hawaiian
Homes Commission Act, 1920 July 9, 1921, 42
Stat. 108, et. seq., as amended and any land
designated as such by the FCC for purposes
of this subpart pursuant to the designation
process in the FCC’s Lifeline rules.
What is your home address? (The address where you will get service. Do not use a P.O. Box)
Street Number and Name
City
Zip CodeState
Apt., Unit, etc.
Is this a temporary address? Yes No Check if you live on Tribal lands*
What is your mailing address? (Only fill this out if it is not the same as your home address.)
Street Number and Name
City
Zip CodeState
Apt., Unit, etc.
OMB APPROVAL EDITION 3060-0819
Lifeline Program Application Form
Page 4 of 8 Universal Service Administrative Company | www.lifelinesupport.org
Need help? Call the Lifeline Support Center at 1-800-234-9473
FCC FORM 5629
2c.
Your
Information
(continued)
Check if you are qualifying through a child or dependent in your household. If so, answer the following questions:
What is their full legal name?
Only fill this section
out if you are applying
through a child or
dependent.
First
What is their date of birth?

Month Day Year
What are the last 4 numbers of their Social Security Number (SSN)?
If they do not have a SSN, what is their Tribal Identification Number?
Middle (optional)Suffix (optional)
Last
OMB APPROVAL EDITION 3060-0819
Lifeline Program Application Form
Page 5 of 8 Universal Service Administrative Company | www.lifelinesupport.org
Need help? Call the Lifeline Support Center at 1-800-234-9473
FCC FORM 5629
Check all programs that you or someone in your household have:
Supplemental Nutrition Assistance Program (SNAP) (Food Stamps)
Supplemental Security Income (SSI)
Medicaid
Federal Public Housing Assistance (FPHA)
Veterans Pension or Survivors Benefit Programs
Tribal Specific Programs
Bureau of Indian Affairs (BIA) General Assistance
Tribal Temporary Assistance for Needy Families (Tribal TANF)
Food Distribution Program on Indian Reservations (FDPIR)
Tribal Head Start (only households that meet the income qualifying standard)
Qualify through a government program:
Or
Qualify through your income:
(Only fill this out if you do not qualify through a government program.)
3.
Qualify for
Lifeline
Fill out this section to
show that you, your
dependent, or someone
in your household
qualifies for Lifeline.
You can qualify through
some government
assistance programs or
through your income (you
do not need to qualify
through both).
Including you, how
many people live in your
household? (check one)
Is your income the same or less than the amount listed for your
state and household size?
(only check yes or no next to your household size)
All 48 States, DC,and Territories
(not Alaska and Hawaii)Alaska Hawaii
1 $17,388 $21,722 $20,007 Yes No
2 $23,517 $29,390 $27,054 Yes No
3 $29,646 $37,058 $34,101 Yes No
4 $35,775 $44,726 $41,148 Yes No
5 $41,904 $52,394 $48,195 Yes No
6 $48,033 $60,062 $55,242 Yes No
7 $54,162 $67,730 $62,289 Yes No
8 $60,291 $75,398 $69,336 Yes No
If more than 8, add this
amount for each extra person Add $6,129 Add $7,668 Add $7,047 Yes No
135% of the 2021 Federal Poverty Guidelines
*The Federal Poverty Guidelines are typically updated at the end of January.
OMB APPROVAL EDITION 3060-0819
Lifeline Program Application Form
Page 6 of 8 Universal Service Administrative Company | www.lifelinesupport.org
Need help? Call the Lifeline Support Center at 1-800-234-9473
FCC FORM 5629
Signature Today’s Date
4.
Agreement
I agree, under
penalty of perjury,
to the following
statements:
You must initial next to each statement.
Initial
I (or my dependent or other person in my household) currently get benefits from the government
program(s) listed on this form or my annual household income is 135% or less than the Federal
Poverty Guidelines (the amount listed in the Federal Poverty Guidelines table on this form).
Initial
I agree that if I move I will give my service provider my new address within 30 days.
Initial
I understand that I have to tell my service provider within 30 days if I do not qualify for Lifeline
anymore, including
1) I, or the person in my household that qualifies, do not qualify through a government
program or income anymore.
2) Either I or someone in my household gets more than one Lifeline benefit (including more
than one Lifeline broadband internet service, more than one Lifeline telephone service, or
both Lifeline telephone and Lifeline broadband internet services).
Initial
I know that my household can only get one Lifeline benefit and, to the best of my knowledge,
my household is not getting more than one Lifeline benefit.
Initial
I agree that all of the information I provide on this form may be collected, used, shared, and retained
for the purposes of applying for and/or receiving the Lifeline Program benefit. I understand that
if this information is not provided to the Lifeline Program Administrator, I will not be able to get
Lifeline benefits. If the laws of my state or Tribal government require it, I agree that the state or Tribal
government may share information about my benefits for a qualifying program with the Lifeline
Program Administrator. The information shared by the state or Tribal government will be used only
to help find out if I can get a Lifeline Program benefit.
Initial
All the answers and agreements that I provided on this form are true and correct to the best
of my knowledge.
Initial
I know that willingly giving false or fraudulent information to get Lifeline Program benefits is
punishable by law and can result in fines, jail time, de-enrollment, or being barred from the
program.
Initial
My service provider may have to check whether I still qualify at any time. If I need to recertify
(renew) my Lifeline benefit, I understand that I have to respond by the deadline or I will be
removed from the Lifeline Program and my Lifeline benefit will stop.
Initial
I was truthful about whether or not I am a resident of Tribal lands, as defined in section 2 of
this form.
OMB APPROVAL EDITION 3060-0819
Lifeline Program Application Form
Page 7 of 8 Universal Service Administrative Company | www.lifelinesupport.org
Need help? Call the Lifeline Support Center at 1-800-234-9473
FCC FORM 5629
5.
Agent
Information
Answer only if a sales
person submits this form.
What is the agent’s full legal name?
The name you use on official documents, like your Social Security Card or State ID. Not a nickname.
What is the agent’s ID number?

First
What is the agent’s date of birth?

Month Day Year
Middle (optional)Suffix (optional)
Last
OMB APPROVAL EDITION 3060-0819
Lifeline Program Application Form
Page 8 of 8 Universal Service Administrative Company | www.lifelinesupport.org
Need help? Call the Lifeline Support Center at 1-800-234-9473
FCC FORM 5629
Notice
PAPERWORK REDUCTION ACT NOTICE: Section 54.410 of the Federal Communications Commission’s rules requires all Lifeline
subscribers to demonstrate their eligibility to receive Lifeline services. This collection of information stems from the FCC’s
authority under Section 254 of the Communications Act of 1934, as amended, 47 U.S.C. §254. Using this authority, the FCC has
designated USAC as the permanent Lifeline Administrator. The FCC has published rules detailing how consumers can qualify
for Lifeline services and what Lifeline services they may receive (47 CFR §54.400 et seq.). The data provided in response to this
information collection will be used by USAC to verify the applicant’s eligibility for Lifeline services.
We have estimated that each response to this collection of information will take, on average, between 0.25 and 0.75 hours. Our
estimate includes the time to read the questions, look through existing records, gather the required data, and actually complete
and review the form or response. If you have any comments on this estimate, or how we can improve the collection and reduce
the burden it causes you, please write to the Federal Communications Commission, OMD-PERM, Paperwork Reduction Project
(3060-0819), Washington, D.C. 20554. We also will accept your comments via the Internet if you send them to [e-mail]. Please
DO NOT SEND COMPLETED DATA COLLECTION FORMS TO THIS ADDRESS.
Remember – You are not required to respond to a collection of information sponsored by the Federal government, and the
government may not conduct or sponsor this collection, unless it displays a currently valid Office of Management and Budget
(OMB) control number. This collection has been assigned an OMB control number of 3060-0819.
The Commission is authorized under the Communications Act of 1934, as amended, to collect the information we request on
this form. If we believe there may be a violation or potential violation of a statute or a Commission regulation, rule, or order,
your response may be referred to the Federal, state, or local agency responsible for investigating, prosecuting, enforcing, or
implementing the statute, rule, regulation, or order.
If you do not provide the information we request on this form, you will not be eligible to receive Lifeline services under the Lifeline
Program rules, 47 C.F.R. §§ 54.400-54.423.
The foregoing Notice is required by the Paperwork Reduction Act of 1995, P.L. No. 104-13, 44 U.S.C. § 3501, et seq.
PRIVACY ACT STATEMENT: The Privacy Act is a law that requires the Federal Communications Commission (FCC) and the
Universal Service Administrative Company (USAC) to explain why we are asking individuals for personal information and what we
are going to do with this information after we collect it.
Authority: Section 254 of the Communications Act (47 U.S.C. § 254), as amended, 47 U.S.C. §254, authorizes the FCC to operate
the Lifeline Program. Using this authority, the FCC has designated USAC as the permanent Lifeline Administrator. The FCC has
published rules detailing how consumers can qualify for Lifeline services and what Lifeline services they may receive (47 CFR
§54.400 et seq.).
Purpose: We are collecting this personal information so we can verify that you qualify for the Lifeline Program and so we can
efficiently provide Lifeline services to you. We access, maintain and use your personal information in the manner described in the
Lifeline System of Records Notice (SORN), FCC/WCB-1, which we have published in 82 Fed. Reg. 38686 (Aug. 15, 2017).
Routine Uses: We may share the personal information you enter into this form with other parties for specific purposes, such
as with contractors that help us operate the Lifeline Program with other federal and state government agencies that help
us determine your Lifeline eligibility with the telecommunications companies that provide you Lifeline service and with law
enforcement and other officials investigating potential violations of Lifeline rules.
A complete listing of the ways we may use your information is published in the Lifeline SORN described in the “Purpose”
paragraph of this statement.
Disclosure: You are not required to provide the information we are requesting, but if you do not, you will not be eligible to receive
Lifeline services under the Lifeline Program rules, 47 C.F.R. §§ 54.400-54.423.
OMB APPROVAL EDITION 3060-0819
Lifeline Program
Household Worksheet
Universal Service Administrative Company | www.lifelinesupport.orgPage 1 of 4
Need help? Call the Lifeline Support Center at 1-800-234-9473
FCC FORM 5631
What this worksheet is for
Use this worksheet if someone else at your address gets Lifeline. The answers to these questions will
help you find out if there is more than one household at your address.
What is a household?
A household is a group of people who live together and share income and expenses (even if they are
not related to each other).
Examples of one household:
• A married couple who live together are one household. They must share one Lifeline
benefit.
• A parent/guardian and child who live together are one household. They must share one
Lifeline benefit.
• An adult who lives with friends or family who financially support him/her are one
household. They must share one Lifeline benefit.
Examples of more than one household:
• 4 roommates who live together but do not share money are 4 households. They can have
one Lifeline benefit each, 4 total.
• 30 seniors who live in an assisted-living home are 30 households. They can have one
Lifeline benefit each, 30 total.
Household expenses
A household shares expenses. Household expenses include, but are not limited to, food, healthcare
expenses, and the cost of renting or paying a mortgage on your place of residence and utilities.
Income
Households share income. Income includes salary, public assistance benefits, social security
payments, pensions, unemployment compensation, veteran’s benefits, inheritances, alimony, child
support payments, worker’s compensation benefits, gi!s, and lottery winnings.
About
Lifeline
Lifeline is a benefit that
lowers the monthly cost
of phone or internet
service (not both). You
are only allowed to get
one Lifeline benefit
per household, not per
person.
OMB APPROVAL EDITION 3060-0819
Lifeline Program
Household Worksheet
Universal Service Administrative Company | www.lifelinesupport.orgPage 2 of 4
Need help? Call the Lifeline Support Center at 1-800-234-9473
FCC FORM 5631
What is your full legal name?
The name you use on o!icial documents, like your Social Security Card or State ID. Not a nickname.
First
Middle (optional)Su!ix (optional)
Last
What is your home address? (The address where you will get service. Do not use a P.O. Box)
Street Number and Name
City
Zip CodeState
Apt., Unit, etc.
Your
Information
All fields are required
unless indicated. Use only
CAPITALIZED LETTERS
and black ink to fill out
this form.
OMB APPROVAL EDITION 3060-0819
Lifeline Program
Household Worksheet
Universal Service Administrative Company | www.lifelinesupport.orgPage 3 of 4
Need help? Call the Lifeline Support Center at 1-800-234-9473
FCC FORM 5631
You do not qualify for Lifeline because someone in your household
already gets the benefit. You are only allowed to get one Lifeline
discount per household, not per person.
Check this box
You can apply for
Lifeline. You live in a
household that does
not get Lifeline yet.
Please initial line B on
page 4, and sign and
date the worksheet.
Check this box
Can you
apply?
Follow this decision tree
to confirm if you qualify
for the Lifeline Program.
You can apply for
Lifeline. You live at an
address with more than
one household and
your household does
not get Lifeline yet.
Please initial lines
A and B on page 4,
and sign and date the
worksheet.
Check this box
2. Do they get Lifeline?
Yes No
1. Do you live with another adult?
Adults are people who are 18 years old or older, or who are emancipated
minors. This can include a spouse, domestic partner, parent, adult son or
daughter, adult in your family, adult roommate, etc.
Yes No
3. Do you share money (income and expenses)
with them?
This can be the cost of bills, food, etc., and income. If you are married,
you should check yes for this question.
Yes No
If yes, answer
question 3
If yes, answer
question 2
OMB APPROVAL EDITION 3060-0819
Lifeline Program
Household Worksheet
Universal Service Administrative Company | www.lifelinesupport.orgPage 4 of 4
Need help? Call the Lifeline Support Center at 1-800-234-9473
FCC FORM 5631
Notice
NOTICE: Section 54.410 of the Federal Communications Commission’s rules requires all Lifeline subscribers to demonstrate their
eligibility to receive Lifeline services. If more than one person at the same address is applying for Lifeline service, all applicants
must submit a Household Worksheet. This collection of information stems from the Commission’s authority under Section 254 of
the Communications Act of 1934, as amended, 47 U.S.C. §254. Using this authority, the FCC has designated USAC as the permanent
Lifeline Administrator. The FCC has published rules detailing how consumers can qualify for Lifeline services and what Lifeline
services they may receive (47 CFR §54.400 et seq.). The data provided in response to this information collection will be used by USAC
to verify the applicant’s eligibility for Lifeline services.
We have estimated that each response to this collection of information will take, on average, 0.25 hours. Our estimate includes the
time to read and complete the form and review the form or response. If you have any comments on this estimate, or how we can
improve the collection and reduce the burden it causes you, please write to the Federal Communications Commission, OMD-PERM,
Paperwork Reduction Project (3060-0819), Washington, D.C. 20554. We also will accept your comments via the Internet if you send
them to [e-mail]. Please DO NOT SEND COMPLETED DATA COLLECTION FORMS TO THIS ADDRESS.
Remember – You are not required to respond to a collection of information sponsored by the Federal government, and the
government may not conduct or sponsor this collection, unless it displays a currently valid O!ice of Management and Budget (OMB)
control number. This collection has been assigned an OMB control number of 3060-0819.
The Commission is authorized under the Communications Act of 1934, as amended, to collect the information we request in this
form. We will use the information that you provide to determine your eligibility for Lifeline services. If we believe there may be a
violation or potential violation of a statute or a Commission regulation, rule, or order, your form may be referred to the Federal,
state, or local agency responsible for investigating, prosecuting, enforcing, or implementing the statute, rule, regulation, or order. In
certain cases, the information in your form may be disclosed to the Department of Justice, court, or other adjudicative body when
(a) the Commission; (b) any employee of the Commission; or (c) the United States government, is a party to a proceeding before the
body or has an interest in the proceeding.
If you do not provide the information we request on this form, you will not be eligible to receive Lifeline services under the Lifeline
Program rules, 47 C.F.R. §§ 54.400-54.423.
The foregoing Notice is required by the Paperwork Reduction Act of 1995, P.L. No. 104-13, 44 U.S.C. § 3501, et seq.
PRIVACY ACT STATEMENT: The Privacy Act is a law that requires the Federal Communications Commission (FCC) and the Universal
Service Administrative Company (USAC) to explain why we are asking individuals for personal information and what we are going to
do with this information a"er we collect it.
Authority: Section 254 of the Communications Act (47 U.S.C. § 254), as amended, 47 U.S.C. §254, authorizes the FCC to operate the
Lifeline program. Using this authority, the FCC has designated USAC as the permanent Lifeline Administrator. The FCC has published
rules detailing how consumers can qualify for Lifeline services and what Lifeline services they may receive (47 CFR §54.400 et seq.).
Purpose: We are collecting this personal information so we can verify that you qualify for the Lifeline program and so we can
e!iciently provide Lifeline services to you. We access, maintain and use your personal information in the manner described in the
Lifeline System of Records Notice (SORN), FCC/WCB-1, which we have published in 82 Fed. Reg. 38686 (Aug. 15, 2017).
Routine Uses: We may share the personal information you enter into this form with other parties for specific purposes, such as: with
contractors that help us operate the Lifeline program; with other federal and state government agencies that help us determine your
Lifeline eligibility; with the telecommunications companies that provide you Lifeline service; and with law enforcement and other
o!icials investigating potential violations of Lifeline rules.
A complete listing of the ways we may use your information is published in the Lifeline SORN described in the “Purpose” paragraph
of this statement.
Disclosure: You are not required to provide the information we are requesting, but if you do not, you will not be eligible to receive
Lifeline services under the Lifeline Program rules, 47 C.F.R. §§ 54.400-54.423.
Initial
A I live at an address with more than one household.
Initial
B I understand that the one-per-household limit is a Federal Communications Commission
(FCC) rule and I will lose my Lifeline benefit if I break this rule.
Agreement
Please initial the
agreement below and
sign and date this
worksheet. Submit this
worksheet to your
service provider with
your Lifeline Program
Application Form.
Signature Today’s Date
I consent to let USAC contact me at my Lifeline
phone number for important reminders and
updates to my Lifeline service. Message and data
rates may apply. Text STOP to end messages.

EXHIBIT E
TORCH WIRELESS SAMPLE ADVERTISING

EXHIBIT F
COVERAGE ZIP CODES

83201 83271 83352 83467 83630 83711 83844
83202 83272 83353 83468 83631 83712 83845
83203 83274 83354 83501 83632 83713 83846
83204 83276 83355 83520 83633 83714 83847
83205 83277 83401 83522 83634 83715 83849
83206 83281 83402 83523 83635 83716 83850
83209 83283 83403 83524 83636 83717 83851
83210 83285 83404 83526 83638 83719 83852
83211 83286 83405 83530 83639 83720 83854
83212 83287 83406 83531 83641 83722 83855
83213 83301 83415 83533 83642 83724 83856
83214 83302 83420 83535 83643 83725 83857
83215 83303 83421 83536 83644 83726 83858
83217 83311 83422 83537 83645 83728 83860
83218 83313 83423 83540 83646 83729 83864
83220 83314 83424 83541 83647 83731 83865
83221 83316 83425 83543 83648 83732 83867
83223 83318 83427 83545 83650 83735 83868
83226 83320 83428 83548 83651 83756 83869
83228 83321 83429 83552 83652 83799 83870
83230 83322 83431 83553 83653 83801 83871
83232 83323 83433 83554 83654 83803 83872
83233 83324 83434 83555 83655 83804 83876
83234 83325 83435 83601 83656 83805 83877
83235 83327 83436 83602 83657 83809 00056
83236 83328 83438 83604 83660 83810
83237 83330 83440 83605 83661 83811
83239 83332 83441 83606 83669 83813
83241 83333 83442 83607 83670 83814
83243 83334 83443 83610 83672 83815
83244 83335 83444 83611 83676 83816
83245 83336 83445 83612 83680 83822
83246 83337 83446 83615 83686 83824
83250 83338 83448 83616 83687 83825
83251 83340 83449 83617 83701 83832
83252 83341 83450 83619 83702 83833
83254 83342 83451 83622 83703 83835
83255 83343 83452 83623 83704 83836
83256 83344 83454 83624 83705 83839
83261 83346 83455 83626 83706 83840
83262 83347 83460 83627 83707 83841
83263 83348 83462 83628 83708 83842
83349 83350 83464 83629 83709 83843
Torch Wireless - Idaho Current Zip Code Coverage

EXHIBIT G
TORCH WIRELESS EXECUTIVE BIOGRAPHIES

Executive Biography

Jorge E. Perea | Chief Executive Officer
Jacksonville, FL
Jorge E. Perea is the Chief Executive Officer for Torch Wireless, with overall responsibility of the corporate
direction, strategy, and governance.
With over 25 years of experience in senior corporate and multiple small business roles, Mr. Perea has been
responsible for the successful execution of strategic decisions of new businesses and products, with strong
expertise in operations management, regulatory adherence, performance management, and communications.
Prior to assuming the Chief Operating Officer role for Torch Wireless, Mr. Perea served as a Management
Executive for a fortune 50 financial institution and has been a partner with an independent servicing firm,
focused on telecom regulatory and service strategy.
A first-generation Colombian-American, Mr. Perea understands the impact of underserved, low-income
communities and has sought an opportunity to help support and enable communities in need of basic
services. In 2016 he co-founded Torch Wireless as an opportunity to align his work and experience in ways
that could help support this principle.
Mr. Perea holds a Bachelors of Business Administration from the University of North Florida and is a certified
Six Sigma Greenbelt and trained Blackbelt. He has served on multiple boards within the community and
currently serves as President of the Board of Directors for a mixed-use property association. He remains active
in the community and is a member of several organizations including the Jacksonville Community Council, Inc.
(JCCI) and the Jacksonville Regional Chamber of Commerce.

Executive Biography

Anatoliy Budnik | Chief Operating Officer
Jacksonville, FL

Anatoliy Budnik is the Chief Operating Officer for Torch Wireless, with overall responsibility for oversight and
execution of the corporation’s operations.
Having established business in the automotive industry for the past two decades, Anatoliy Budnik founded
Breitling Autoworks in 2008, where he served as president since it’s formation. At Breitling, Mr. Budnik was
responsible for the operational and strategic direction, including product development of company operations
in the United States. Breitling Autoworks provides custom modifications and work for exotic, and luxury
vehicles, specializing in makes such as Lamborghini, Ferrari, and Bentley, as well as collision repair for
consumers, vehicle manufactures, and distribution centers. In addition to his experience at Breitling
Autoworks, Mr. Budnik was instrumental in funding and establishing the foundation for a successful home
remodeling and new construction firm in 2003.
Through established relationships in the community, Mr. Budnik has had the opportunity to engage in events
focused on underprivileged families and children in low income communities, leading him to establish an ETC
investment program in 2015. This program focuses on providing funds to ETC companies seeking capital for the
acquisition of handsets for the underserved lifeline market. After understanding the value and opportunity to
improve the how families stay connected within the lifeline community, Mr. Budnik co-founded Torch Wireless
in 2016.

EXHIBIT H – CONFIDENTIAL
TORCH WIRELESS NETWORK DESCRIPTION

(submitted confidentially to Idaho PUC)

Proprietary | Confidential | Do Not Distribute
Torch Wireless Network Map
Signaling
Call Path
Sprint
MPLS / IMS
SBC
Sprint Wireless Network
PSTN
Voicemail
G/W
Soft SwitchTorch Wireless Network