20230713Application.pdf

Lance J.M. Steinhart, P.C.
Attorneys At Law 1725 Windward Concourse Suite 150 Alpharetta, Georgia 30005

Also Admitted in New York Telephone: [phone]
Email: [e-mail] Facsimile: [phone] July 13, 2023
VIA EMAIL DELIVERY TO [e-mail]
Jan Noriyuki Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd. Building 8, Suite 201-A Boise, ID 83714 [phone]
Re: TERRACOM INC. d/b/a Maxsip Tel
Application for Designation as an Eligible Telecommunications Carrier for the Limited Purpose of Offering Lifeline Service to Qualified Households Dear Ms. Noriyuki:
Please find for filing TERRACOM INC. d/b/a Maxsip Tel’s Application for Designation as an Eligible Telecommunications Carrier for the Limited Purpose of Offering Lifeline Service to Qualified Households in the State of Idaho.
Please note that Exhibit 7 is marked “CONFIDENTIAL” and contains confidential and proprietary information. Applicant hereby respectfully requests confidential treatment of such information. If you have any questions, or if I may provide you with additional information, please do not hesitate to contact me at [e-mail] or by phone at 770-232-9200. Respectfully submitted,
Lance J.M. Steinhart, Esq.
Managing Attorney Lance J.M. Steinhart, P.C. Attorneys for TERRACOM INC. d/b/a Maxsip Tel
Attachments
RECEIVED
Thursday, July 13, 2023 2:42:16 PM
IDAHO PUBLIC
UTILITIES COMMISSION
CASE NO. TRA-T-23-01
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
TERRACOM INC.
d/b/a Maxsip Tel Application for Designation as an Eligible Telecommunications Carrier for the Limited Purpose of Offering Lifeline Service to Qualified Households ____________________________________
) )))))))
Case No. ____
APPLICATION

Lance J.M. Steinhart, Esq. 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 TERRACOM INC. d/b/a Maxsip Tel
July 13, 2023
TABLE OF CONTENTS I. INTRODUCTION ...............................................................................................................1
II. COMPANY OVERVIEW ...................................................................................................3
III. THE COMMISSION HAS JURISDICTION OVER DESIGNATION OF WIRELESS ETCS ...............................................................................................................6
IV. TERRACOM SATISFIES THE REQUIREMENTS FOR DESIGNATION AS AN ETC UNDER 47 C.F.R. § 54.201 ...........................................................................7
V. TERRACOM SATISFIES THE ADDITIONAL REQUIREMENTS FOR
ETC DESIGNATION UNDER 47 C.F.R. § 54.202(a) .....................................................13
VI. DESIGNATION OF TERRACOM AS AN ETC WOULD PROMOTE THE PUBLIC INTEREST .........................................................................................................20
VII. CONCLUSION ..................................................................................................................24

TABLE OF EXHIBITS
Exhibit
Certification ...............................................................................................................1 FCC-Approved Compliance Plan and FCC-5TH Revised Compliance Plan ................2

Coverage Area ...........................................................................................................3 Sample Advertisement ...............................................................................................4
Key Management Bios ...............................................................................................5
Proposed Lifeline Offering ........................................................................................6 Financial Statements ..................................................................................................7

Certificate of Service .................................................................................................8

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
TERRACOM INC.
d/b/a Maxsip Tel Application for Designation as an Eligible Telecommunications Carrier for the Limited Purpose of Offering Lifeline Service to Qualified Households ____________________________________
) )))))))
Case No. ____
APPLICATION

I. INTRODUCTION
TERRACOM INC. d/b/a Maxsip Tel (“TERRACOM” or the “Company”), by its
undersigned counsel, and 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 (the “Commission”), including the Idaho Telecommunications Act of 1988, hereby
submits this Application for Designation as an Eligible Telecommunications Carrier (“ETC”) in
the State of Idaho (this “Application”).

1 47 U.S.C. § 214(e)(2)
2 47 C.F.R. §§ 54.101-54.207.
2
TERRACOM 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 high cost
program.3 TERRACOM 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 1 attached hereto, TERRACOM meets
all the statutory and regulatory requirements for designation as an ETC in the State of Idaho,
including the requirements outlined in the FCC’s Lifeline and Link Up Reform Order,4 Lifeline
Modernization Order,5 and Fifth Report and Order.6 Furthermore, TERRACOM is positioned to
reach unserved and underserved Lifeline-eligible consumers. Rapid grant of TERRACOM’s
request, therefore, would advance the public interest because it would enable the Company to
commence much needed Lifeline services to a wide array of low-income Idaho residents as soon
as possible. Accordingly, the Company respectfully requests that the Commission expeditiously
approve this Application.

3 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.
4 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) (“Lifeline and Link Up Reform Order”).
5 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) (hereinafter, “Third Report and Order” or “Lifeline Modernization Order”).
6 In the Matter of Bridging the Digital Divide for Low-Income Consumers, Lifeline and Link Up Reform and
Modernization, Telecommunications Carriers Eligible for Universal Service Support, WC Docket No. 17-287, WC Docket No. 11-42, WC Docket No. 09-197, Fifth Report and Order, Memorandum Opinion and Order and Order on Reconsideration, and Further Notice of Proposed Rulemaking, FCC 19-111 (rel. Nov. 14, 2019) (hereinafter, “Fifth Report and Order”).
3
All correspondence, communications, pleadings, notices, orders and decisions relating to
this Application should be addressed to:
Lance J.M. Steinhart, Esq. Managing Attorney Lance J.M. Steinhart, P.C.
Attorneys for TERRACOM INC.
d/b/a Maxsip Tel 1725 Windward Concourse, Suite 150 Alpharetta, Georgia 30005 [phone] (Phone)
[phone] (Fax)
E-Mail: [e-mail]
II. COMPANY OVERVIEW
TERRACOM is an Oklahoma corporation organized on April 10, 2003, with principal
offices located at 6650 East Brainerd Road, Suite 200-C, Chattanooga, Tennessee 37421.
TERRACOM is owned Fifty One percent (51%) by Global Reconnect, LLC, a Delaware limited
liability company; and Forty Nine percent (49%) by MAXSIP TEL LLC, a New York limited
liability company (“Maxsip”).7 TERRACOM also owns One hundred percent (100%) of Yourtel
America, Inc., a Missouri corporation (“YourTel”).
TERRACOM is a provider of commercial mobile radio service (“CMRS”) and provides
prepaid wireless telecommunications services to consumers by using the underlying wireless
networks of Tier 1 carriers, currently T-Mobile USA, Inc. (“T-Mobile”) and/or AT&T (collectively,
“Underlying Carriers”) on a wholesale basis. TERRACOM obtains from its Underlying Carriers the
network infrastructure and wireless transmission facilities to allow the Company to operate as a
Mobile Virtual Network Operator (“MVNO”). The Underlying Carrier is selected based on best
coverage available at the service address.

7 On April 3, 2023, MAXSIP TELECOM CORPORATION reorganized from a New York corporation to a New York limited liability company.
4
TERRACOM is designated as an ETC to provide Lifeline services to low-income
consumers on a wireless basis in Arizona, Arkansas, Colorado, Indiana, Iowa, Louisiana,
Maryland, Minnesota, Nebraska, Nevada, Oklahoma, Texas, West Virginia and Wisconsin. As of
2015, TERRACOM directly holds 100% of the ownership interest in YourTel, which is designated
an ETC to provide Lifeline services on a wireless basis in Illinois, Kansas, Maine, Missouri,
Pennsylvania, Rhode Island, and Washington. TERRACOM commenced providing Lifeline
services in 2004.
Pursuant to the terms of a Stock Purchase Agreement by and among TERRACOM; Global
Reconnect, LLC, a Delaware limited liability company (“Seller”); and Maxsip, Maxsip will
purchase one hundred percent (100%) of the issued and outstanding common stock of
TERRACOM including its wholly owned subsidiary, YourTel from Seller (the “Transaction”). In
step one of the Transaction, Maxsip acquired forty nine percent (49%) of the issued and
outstanding common stock of TERRACOM; step two of the Transaction is the purchase of the
remaining fifty-one percent (51%) of the stock of TERRACOM which will close upon obtaining
any required regulatory approvals for the Transaction, including its 5th Revised Compliance Plan
which was filed with the FCC on March 1, 2023, a copy of which is attached hereto as Exhibit 2.
Maxsip was formed in 2008 and then commenced offering competitive local exchange and
resold long distance service. On August 28, 2008, the FCC International Bureau granted Maxsip
Section 214 international authority to provide facilities-based service in accordance with section
63.18(e)(1) of the FCC’s rules, and also to provide resale service in accordance with section
63.18(e)(2) of the FCC’s rules. Maxsip’s principal offices are located at 708 Central Avenue,
Woodmere, New York 11598. Maxsip has established considerable financial resources that will
be available, as needed, to support TERRACOM in its operations and continuing growth. Maxsip
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is wholly owned by Israel Max, a United States citizen. Maxsip provides competitive local
exchange services in New York and New Jersey, as well as landline Lifeline services in New York.
Maxsip is authorized to provide commercial mobile radio services throughout the United States and
Puerto Rico, is authorized to provide VoIP services throughout the United States, and has been
authorized to provide services by the FCC and USAC under the Affordable Connectivity Program
(“ACP”) (and previously the Emergency Broadband Benefit “EBB” program) in said jurisdictions.
TERRACOM will provide affordable prepaid mobile phone service, including calling, text
messaging, and broadband access, along with user-friendly handsets, and high quality customer
service. The Company will not require service contracts from its customers and it will always
ensure competitively low pricing for its services and products. TERRACOM will manage all
aspects of the customer experience, including setting service pricing, handset selection, marketing
materials, and live customer service. The Company’s prepaid, budget-friendly pricing will give
many low-income consumers the option of having mobile phone service and broadband access
without the burden of hidden costs, varying monthly charges, or contractual commitments.
Customers will be able to customize their TERRACOM service to suit their needs with
TERRACOM’s available bundles of minutes, broadband data, and text packages to supplement
their monthly plan.
TERRACOM’s Lifeline customers will depend on, and benefit greatly from,
TERRACOM’s inexpensive and flexible pricing plans. TERRACOM will not impose credit
checks nor will it require any deposits or contractual commitments. Many Lifeline customers turn
to carriers like TERRACOM because they cannot afford the postpaid services provided by
traditional wireless carriers. TERRACOM will affirmatively reach out to the low-income sector
of the consumer base to offer attractive and affordable communications options. As such,
6
TERRACOM will contribute to the expansion of mobile wireless and broadband services for low-
income consumers in Idaho.
III. THE COMMISSION HAS JURISDICTION OVER DESIGNATION OF WIRELESS ETCS
Section 214(e)(2) of the Act provides state public utility commissions with the “primary
responsibility” for the designation of ETCs.8 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.9 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 214(e)(1).
TERRACOM recognizes that Section 214(e)(1)(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.10 Section 10(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 subsection
(a) of this section.” As such, the Commission is required by Section 10(e) to act in accordance
with the FCC’s grant of forbearance, and therefore, may not apply the facilities-based requirement

8 47 U.S.C. § 214(e)(2).
9 USF Order, at 8858–59, ¶ 145.
10 See Lifeline and Link Up Reform Order at ¶ 368.
7
to TERRACOM. Therefore, the Commission has the authority under Section 214(e)(2) of the Act
to grant TERRACOM’s request for designation as an ETC throughout the State of Idaho.
IV. TERRACOM SATISFIES THE REQUIREMENTS FOR DESIGNATION AS AN ETC UNDER 47 C.F.R. § 54.201
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.11 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 shall, throughout the
designated service area, 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.12 As detailed below, TERRACOM
satisfies each of the above-listed requirements.

11 See Federal-State Joint Board on Universal Service, First Report and Order, 12 FCC Rcd 8776, 8858-59, ¶ 145 (1997) (“USF Order”).
12 See 47 U.S.C. § 214(e)(1) and 47 C.F.R. § 54.201(d)(2).
8
A. TERRACOM Will 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 TERRACOM.
In the Lifeline and Link Up Reform Order, the FCC granted forbearance from the “own-facilities”
requirement contained in Section 214(e)(1)(A) for carriers that are, or seek to become, Lifeline-only
ETCs, subject to the following conditions:13
(1) the carrier must comply with certain 911 requirements [(a) providing its Lifeline
subscribers with 911 and E911 access, regardless of activation status and availability of minutes; (b) providing its Lifeline subscribers with E911-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, TERRACOM filed a
Compliance Plan with the FCC, which the FCC approved on May 25, 2012.14 TERRACOM filed
its Fourth Revised Compliance Plan on October 3, 2016, which the FCC approved on November
8, 2016,15 identifying a transfer of control and making revisions to comply with rule changes since
the 2012 Lifeline Reform Order. TERRACOM filed its 5th Revised Compliance Plan, which

13 See Lifeline and Link Up Reform Order at ¶¶ 368, 373, and 379.
14 Wireline Competition Bureau Approves the Compliance Plans of American Broadband & Telecommunications, Budget Prepay, Consumer Cellular, Global Connection, TerraCom and Total Call, Public Notice, 27 FCC Rcd 5776 (WCB rel. May 25, 2012); In Re Telecommunications Carriers Eligible for Universal Service Support, et al., Third
Revised Compliance Plan of TerraCom, Inc. (filed June 19, 2012) (providing minor updates requested by Bureau staff).
15 Wireline Competition Bureau Approves the Amended Compliance Plan of TerraCom, Public Notice, DA 16-1264 (rel. Nov. 8, 2016); In Re Telecommunications Carriers Eligible for Universal Service Support, et al., Fourth Revised Compliance Plan of TerraCom, Inc. (filed Oct. 3, 2016), a copy of which can be found at https://www.fcc.gov/ecfs/document/1003273824499/1.
9
remains pending, on March 1, 2023. TERRACOM commits to providing Lifeline service in Idaho
in accordance with its approved Compliance Plan, as revised, and in compliance with applicable
state and federal regulations, to the extent amendments thereto may supersede commitments made
in the Compliance Plan.
B. TERRACOM Is a Common Carrier
CMRS providers like TERRACOM are treated as common carriers.16
C. TERRACOM Will Provide All Supported Services
Through its Underlying Carriers, TERRACOM is able to provide all of the supported
services required by Section 54.101(a) of the FCC’s Rules (47 C.F.R. § 54.101(a)) as follows:
1. Voice Telephony Service
As set forth in 47 C.F.R. § 54.101(a)(1), eligible Voice Telephony Services must provide
the following:
Voice Grade Access to the Public Switched Telephone Network. TERRACOM
provides voice grade access to the public switched telephone network (“PSTN”) through the
purchase of wholesale CMRS services from its Underlying Carriers.
Local Usage At No Additional Charge. TERRACOM offers rate plans that provide its
customers with minutes of use for local service at no additional charge.
Access to Emergency Services. TERRACOM provides 911 and E911 access for all of its
customers to the extent the local government in its service area has implemented 911 or E911

16 Implementation of Sections 3(n) and 332 of the Communications Act, Regulatory Treatment of Mobile Services, GN Docket No. 93-252, Second Report and Order, 9 FCC Rcd 1411, 1425 ¶ 37, 1454-55 ¶ 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)(1)(A) (“mobile services” providers are common carriers); see also PCIA
Petition for Forbearance for Broadband PCS, WT Docket No. 98-100, (Memorandum Opinion and Order and Notice of Proposed Rulemaking, 13 FCC Rcd 16857, 16911 ¶ 111 (1998) ("We concluded [in the Second Report and Order] that CMRS also includes the following common carrier services: cellular service, … all mobile telephone services and resellers of such services.") (emphasis added).
10
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. TERRACOM also complies with
the FCC’s regulations governing the deployment and availability of E911 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.17 “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.”18 Nonetheless, TERRACOM’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. TERRACOM’s service, moreover, is not offered
on a distance-sensitive basis and local and domestic long distance minutes are treated the same.
2. Broadband Internet Access Services
The FCC has stated that broadband Internet access service (“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.”19 TERRACOM provides
BIAS to low-income consumers via resale of its Underlying Carriers’ mobile services.

17 See Lifeline and Link Up Reform Order at ¶ 367.
18 See id. at ¶ 49.
19 See 47 C.F.R. § 8.2(a).
11
D. TERRACOM Requests Designation Throughout Its Service Area
TERRACOM is not a rural telephone company as defined in Section 153(37) of the Act
(47 U.S.C. § 153(37)). Accordingly, TERRACOM is required to describe the geographic area(s)
within which it requests designation as an ETC. TERRACOM requests ETC designation that is
statewide in scope to allow the Company to provide Lifeline service wherever its underlying,
facilities-based provider(s) have wireless coverage, including federally recognized tribal
(“Tribal”) lands,20 including as it may change going forward. Current coverage maps are attached
hereto as Exhibit 3. TERRACOM understands that its service area overlaps with rural carriers
in Idaho, 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. TERRACOM is not
eligible for and does not seek Link-Up or high-cost support.
Therefore, designation of TERRACOM 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,
and new technologies.”21 While federal rules (47 U.S.C. §§ 160, 214(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 “service area conformance” requirement), the
FCC’s Lifeline and Link Up Reform Memorandum Opinion and Order (FCC 13-44 released April

20 In accordance with Commission requirements, a copy of this Application is being sent concurrent with this filing to the tribes identified on the attached Certificate of Service.
21 See Western Wireless Corporation Petition for Designation as an Eligible Telecommunications Carrier in the State of Wyoming, Memorandum Opinion and Order, 16 FCC Rcd 48, 55 (2000).
12
15, 2013) authorized forbearance from the service area conformance requirements with respect to
carriers seeking to provide Lifeline-only service.22 In light of this forbearance, the Commission
has the authority to designate ETCs such as TERRACOM in rural areas without concern for the
service area conformance requirement.23
E. TERRACOM Will Advertise the Availability of Supported Services
TERRACOM 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). TERRACOM will
comply with the FCC’s rules regarding information to be included in marketing materials,
including FCC rule section 54.405(c). Specifically, TERRACOM’s marketing materials will state,
in easily understood language, that: (i) the service is a Lifeline service; (ii) Lifeline is a government
assistance program; (iii) the service may not be transferred to someone else; (iv) consumers must
meet certain eligibility requirements before enrolling in the Lifeline program; (v) the Lifeline
program permits only one Lifeline discount per household; (vi) documentation is necessary for
enrollment; and (vii) TERRACOM is the provider of the services. Moreover, the Lifeline
application/certification form will state that Lifeline is a federal benefit and that consumers who
willfully make a false statement in order to obtain the Lifeline benefit can be punished by fine or
imprisonment or can be barred from the program.
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 internet, radio, television,
print advertising, and direct mailing.24 Moreover, TERRACOM will expand its advertising efforts

22 See In the Matter of Telecommunications Carriers Eligible for Support, Lifeline and Link Up Reform, WC Docket
No. 09-197, WC Docket No. 11-42, Memorandum Opinion and Order, FCC 13-44 (rel. April 15, 2013).
23 See 47 C.F.R. § 54.207(c).
24 See attached Exhibit 4 for a sample advertisement. The advertisement will be updated if necessary to comply with any state specific requirements.
13
as necessary to ensure that Lifeline-eligible customers are aware of the Company’s service
offerings.
V. TERRACOM SATISFIES THE ADDITIONAL REQUIREMENTS FOR ETC DESIGNATION UNDER 47 C.F.R. § 54.202(a)
TERRACOM hereby provides the additional information and certifications required for
carriers seeking ETC designation as set forth in 47 C.F.R. § 54.202(a).
A. Service Commitment Throughout the Proposed Designated Service Area
TERRACOM will provide service in Idaho by reselling service which it obtains from its
Underlying Carriers whose networks are operational and largely built out. Thus, TERRACOM
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 certification attached in Exhibit 1,
TERRACOM commits to comply with the service requirements applicable to the low-income
support that it receives. Pursuant to 47 C.F.R. § 54.202(a)(1)(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.
B. Ability to Remain Functional in Emergency Situations
In accordance with 47 C.F.R. § 54.202(a)(2), TERRACOM has the ability to remain
functional in emergency situations. As discussed, TERRACOM will utilize the extensive and
well-established network and facilities of Tier 1 carriers to provide its Lifeline services. The
Company understands that 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. Through access to the Underlying Carriers’ networks, TERRACOM and
14
its customers benefit from this functionality.
C. Commitment to Consumer Protection and Service Quality
In accordance with 47 C.F.R. § 54.202(a)(3), 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. TERRACOM hereby
commits to comply with the CTIA Consumer Code for Wireless Service.
D. TERRACOM is Financially and Technically Capable
In accordance with 47 C.F.R. § 54.202(a)(4), TERRACOM is financially and technically
capable of providing Lifeline-supported services. Maxsip brings to TERRACOM not only
financial stability, but also managerial and technical resources available to Maxsip which has been
providing telecommunications service since 2008 including wireline Lifeline service, and wireless
service under the EBB and ACP. Maxsip receives revenue from a number of sources which are
independent from the revenue it receives in the form of Lifeline reimbursements, such as non-
Lifeline wireless income from the sale of prepaid wireless services to non-Lifeline consumers as
well as the sale of replenishment airtime minutes and data to Lifeline consumers, the sale of various
other ancillary services, and CLEC and VoIP services. Maxsip will similarly move forward with
TERRACOM operations such that TERRACOM provides non-Lifeline services wholly separate
from and/or complementary to its Lifeline services. TERRACOM has provided non-Lifeline
telecommunications services since 2004 and will continue to do so after the closing of the
Transaction. Consequently, TERRACOM never has and will not be relying exclusively on
Lifeline reimbursement for its operating revenues. Maxsip has not been subject to enforcement
15
sanctions related to the Low Income Fund or ETC revocation proceedings in any state.25 Neither
TERRACOM nor any of its affiliates have any pending investigations before the FCC.
In addition, TERRACOM’s and Maxsip’s financial and technical capabilities to provide
service are demonstrated by its performance over 20 years. The senior management of
TERRACOM and Maxsip has great depth in the telecommunications industry and offers extensive
telecommunications business technical and managerial expertise to TERRACOM.26 TERRACOM
will be providing resold wireless service, and therefore will also rely upon the managerial and
technical expertise of its Underlying Carriers.
E. Terms and Conditions of Proposed Lifeline Offering
TERRACOM has the ability to provide all services supported by the universal service
program, as detailed in 47 C.F.R. § 54.101(a), throughout Idaho. TERRACOM 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. TERRACOM’S
Lifeline-supported broadband services will also meet the minimum service standards set forth in
47 C.F.R. § 54.408 for mobile broadband internet access services, including for service speed and
data usage allowance, as such standards are updated going forward. To the extent TERRACOM
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 TERRACOM will not impose an
additional or separate tethering charge for mobile data usage below the minimum standard.

25 Neither Maxsip nor TerraCom have been subject to any ETC revocation proceedings. TerraCom has resolved all FCC enforcement proceedings. In Re TerraCom, Inc., and YourTel America, Inc. File Nos.: EB-TCD-13- 00009175,
EB-IHD-13-00010677, Order, 30 FCC Rcd 7,075 (EB rel. July 9, 2015).
26 See Exhibit 5 for key management bios.
16
Attached hereto as Exhibit 6 is a summary table of the Company’s proposed Lifeline service
offerings, showing that Lifeline customers will receive 1,000 voice minutes, 1,000 text messages,
and 4.5 gigabytes (GB) of data per month (Tribal Lifeline customers will receive unlimited talk
and text with 10 GB data) at a net cost of $0.00 after application of Lifeline and ITSAP support.27
Lifeline customers that also elect to receive ACP benefits from TERRACOM will receive
unlimited talk and text with 15 GB data (unlimited for Tribal residents) after application of
Lifeline/ITSAP and ACP support. Customers will be able to purchase additional minutes or data
as needed. In addition to wholly-supported or discounted wireless services, prepaid Lifeline
customers will receive access to voicemail, caller ID and call waiting features at no additional
charge. All plans will include nationwide domestic long-distance at no extra per-minute charge,
and TERRACOM will not assess any usage for access to its free customer services (611).
Emergency (911) calls will be free, regardless of service activation or availability of minutes, and
will not count against the customer’s airtime. The Company’s Lifeline offering will provide
feature-rich mobile connectivity for qualifying subscribers without the burden of credit checks or
service contracts. TERRACOM’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.
TERRACOM’s customer service representatives are located at the Company’s principal
place of business in Chattanooga, Tennessee and the toll-free telephone number is 888-716-8880.
Customer service is available Monday through Friday from 10:00AM to 7:00PM EDT via phone
or online chat. Subscribers can also initiate support tickets 24 hours a day 7 days a week via an

27 This plan meets the requirements to receive full Lifeline support of $9.25 based upon current FCC minimum service standards (“MSS”) and may change based on future MSS.
17
online chat and customer service representatives respond during the above-mentioned support
hours. TERRACOM will cooperate fully with the Commission to resolve all consumer
complaints. At this time, the company does not plan to have physical locations and employees in
Idaho.
F. TERRACOM Will Comply with the Lifeline Certification and Verification Requirements
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 must then apply directly through the National Lifeline
Eligibility Verifier (“National Verifier”), which they may do online or by submitting all required
documentation to the National Verifier by mail. Customers may download a copy of the
application form from the Internet (either from the National Verifier’s or Company’s website) or
request that a copy be mailed to them. TERRACOM utilizes the standard Lifeline application
forms as required by FCC rules, and thus complies with the disclosure and information collection
requirements in 47 C.F.R. § 54.410(d).28 TERRACOM will certify and verify initial and continued
consumer eligibility in accordance with 47 C.F.R. § 54.410, and 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. TERRACOM further confirms that it will not provide a consumer
with an activated device and will not activate a Lifeline service unless or until it has confirmed
that the consumer is a qualifying low-income household pursuant to 47 C.F.R. § 54.409, and

28 FCC Wireline Competition Bureau Provides Guidance on Universal Forms for the Lifeline Program, WC Docket No. 11-42, Public Notice, “Wireline Competition Bureau Provides Guidance on Universal Forms for the Lifeline Program,” DA 18-161 (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).
18
completed the required eligibility determination and certification requirements of 47 C.F.R. §§
54.410, 54.404-54.405. Processing of consumers’ applications and determination of eligibility will
be performed by the National Verifier.
G. Prevention of Waste, Fraud and Abuse

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 away from Lifeline
providers. TERRACOM will rely on the National Verifier to determine initial and ongoing
eligibility of Idaho Lifeline subscribers. The National Verifier queries the National Lifeline
Accountability Database (“NLAD”) for every enrollment to determine whether a prospective
subscriber is currently receiving a Lifeline service from TERRACOM or any other ETC, and
whether anyone else living at the prospective subscriber’s residential address is currently receiving
Lifeline service. TERRACOM thus complies with the requirements of section 54.404 of the
FCC’s rules. In addition, Company personnel emphasize the “one Lifeline service per household”
restriction in their direct sales contacts with potential customers.
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 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(e)(3), TERRACOM will provide the subscriber advanced notice, using clear, easily
understood language, that the subscriber’s failure to use the Lifeline service within the notice
19
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.
H. TERRACOM Will Comply With Reporting Requirements
TERRACOM will provide the Commission a copy of its annual certifications and Lifeline
recertification results pursuant to 47 C.F.R. § 54.416 (i.e., FCC Form 555), as well as a copy of its
annual report filed pursuant to 47 C.F.R. § 54.422 (i.e., FCC Form 481), and will comply with
applicable Commission reporting requirements for Lifeline ETCs.
I. TERRACOM Will Comply With Regulations Imposed By The Commission
By this Application, TERRACOM 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. TERRACOM 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.
TERRACOM further commits to remit required ITSAP funds to the ITSAP Administrator. Upon
Commission request, TERRACOM is prepared to answer questions or present additional
testimony or other evidence about its services within the state.
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.1 (two-year network
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.
TERRACOM commits that 100% of federal universal service funds will flow through
directly to Lifeline customers.
20
VI. DESIGNATION OF TERRACOM AS AN ETC WOULD PROMOTE THE PUBLIC INTEREST
One of the principal goals 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.29 Designation of TERRACOM 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. The FCC has in recent years
expanded the Lifeline program to cover broadband services, noting that “Only half of all
households in the lowest income tier subscribe to a broadband service and 43 percent say the
biggest reason for not subscribing is the cost of the service,” and “Of the low income consumers
who have subscribed to mobile broadband, over 40 percent have to cancel or suspend their service
due to financial constraints.”30 Given this context, designating TERRACOM as an ETC would
significantly benefit low-income consumers eligible for Lifeline services in Idaho—the intended
beneficiaries of universal service.

29 Telecommunications Act of 1996, Pub. L. No. 104-104, 110 Stat. 56.
30 See Lifeline Modernization Order ¶ 2.
21
A. Advantages of TERRACOM’s Service Offering
TERRACOM offers an easy to use, competitive, and highly affordable wireless
telecommunications service, which benefits qualified consumers who either have no other service
alternatives or who choose a wireless prepaid solution in lieu of more traditional service. The
public interest benefits of TERRACOM’s wireless service include larger calling areas (as
compared to traditional wireline carriers), the convenience and security afforded by mobile
service, and a generous amount of voice and broadband access included without cost (after
application of Lifeline and ITSAP support), as well as free access to caller ID, call waiting, and
Voicemail features, and access to 911 services regardless of the number of voice minutes
remaining on the Lifeline consumer’s plan. These no cost to consumer services and low-cost
minutes are an invaluable resource for cash-strapped consumers, and the prepaid nature of the
service also provides an alternative for “unbanked” consumers. TERRACOM’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.
In today’s market, consumers, including qualified Lifeline customers, view the portability
and convenience of wireless service not as a luxury, but as a necessity. Mobile service allows
children to reach their parents wherever they may be, allows a person seeking employment greater
ability to be contacted by potential employers, and provides end users with the ability to contact
emergency service providers regardless of location. Mobile service often also serves as a key
bridge in closing the homework gap for students who live in rural areas with limited access to
broadband.
22
With the comprehensive strength and experience of TERRACOM’s and Maxsip’s
management team, and their solid history as a Lifeline provider, TERRACOM is positioned to
meet the needs of Lifeline customers and remains committed to careful stewardship of the Lifeline
program. Without question, prepaid wireless services have become essential for low-income
customers, providing them with value for their money, access to emergency services on wireless
devices, and a reliable means of contact for prospective employers, social service agencies or
dependents. Providing TERRACOM with the authority necessary to offer discounted Lifeline
service to those without wireless service—or most in danger of losing service altogether—
undoubtedly promotes the public interest.
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.31 Increasing
customer choice promotes promote competition and innovation, thus spurring other carriers to
target low-income consumers with service offerings tailored to their needs, ultimately resulting in
improved services to consumers. Designation of TERRACOM as an ETC will help ensure that
quality services are available at “just, reasonable, and affordable rates” as envisioned in the Act.32
Introducing TERRACOM 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.

31 See, e.g., Specialized Common Carrier Services, 29 FCC Rcd 870 (1971).
32 See 47 U.S.C. § 254(b)(1).
23
C. Impact on the Universal Service Fund
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 TERRACOM or the Incumbent LEC operating in the same service area. The
number of persons eligible for Lifeline support is the same regardless of the number of ETCs; thus,
TERRACOM 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 in the Lifeline and Link Up Reform Order and utilizing the NLAD and National
Verifier, the likelihood that TERRACOM’s customers are not eligible or are receiving duplicative
support either individually or within their household is greatly minimized. TERRACOM’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.

24
VII. CONCLUSION
Based on the foregoing, designation of TERRACOM as an ETC in the State of Idaho
accords with the requirements of Section 214(e)(2) of the Act and is in the public interest.
WHEREFORE, TERRACOM respectfully requests that the Commission promptly
designate TERRACOM as an ETC in the State of Idaho for the purpose of participating in the
Lifeline and ITSAP programs.
Respectfully Submitted,
/s/ Lance J.M. Steinhart ________________________ Lance J.M. Steinhart, Esq.
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 TERRACOM INC.
d/b/a Maxsip Tel
July 13, 2023

EXHIBIT 2
FCC-Approved Compliance Plan and FCC-5TH Revised Compliance Plan

Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554

)
In the Matter of )
)
Telecommunications Carriers Eligible for ) WC Docket No. 09-197
Universal Service Support )
)
Lifeline and Link Up Reform and Modernization ) WC Docket No. 11-42
)
TerraCom, Inc. Blanket Forbearance )
Compliance Plan )
)
Petition of TerraCom, Inc. for Limited Designation )
as an Eligible Telecommunications Carrier for )
Purposes of Receiving Low Income Support Only )
)

COMPLIANCE PLAN OF TERACOM, INC.

TERRACOM, INC.

Jonathan D. Lee
J.D. Lee Consulting, LLC
1776 I Street, N.W.
Suite 900
Washington, DC 20006
[phone]

Its Attorney

March 2, 2012

TABLE OF CONTENTS
SUMMARY ........................................................................................................................................ i

I. INTRODUCTION ..........................................................................................................................1

II. TERRACOM BACKGROUND .......................................................................................................3

III. OBLIGATIONS IMPOSED ON ETCS BY THE LIFELINE REFORM ORDER ..................................5

A. Customers of TerraCom Lifeline-supported Services Will Have Access to
911/E911 Compatible Handsets ........................................................................................8

B. Description of TerraCom’s Lifeline Service Offerings.............................................9

C. TerraCom’s Plans To Implement New Lifeline Service Offerings........................12

1. Enrollment.........................................................................................................12

2. De-Enrollment...................................................................................................20

3. Recordkeeping Requirements ...........................................................................23

i. Individual Account Records ..........................................................................24
ii. Company-wide Records................................................................................26

4. Reimbursement from USAC.............................................................................28

5. Marketing Materials..........................................................................................28

6. Financial and Technical Capability to Provide Service ....................................29

i

SUMMARY

TerraCom, Inc. (“TerraCom”) submits the instant Compliance Plan in order to
demonstrate how it plans to comply with the new obligations imposed on Lifeline-only ETCs as
part of the Commission’s recently released Lifeline Reform Order. In submitting this
Compliance Plan, TerraCom seeks to benefit from the Commission’s grant of “blanket
forbearance” from Section 214(e)(1)(A) of the Communications Act of 1934, as amended (the
“Act”), to all telecommunications carriers seeking limited ETC designation to offer Lifeline
services, regardless of the facilities used to provide the services. Accordingly, TerraCom also
seeks the Commission’s approval of its Petition for ETC Designation, as amended, for the states
of Alabama, Connecticut, Delaware, Florida, New Hampshire, New York, North Carolina,
Tennessee, the Commonwealth of Virginia, and the District of Columbia.
In this submission, TerraCom explains that in many instances, it is already operating
largely in compliance with the Commission’s new rules. Nonetheless, TerraCom will describe
(for all the major rule changes the Commission adopted in this Order) how it plans to comply
with the Commission’s new rules.
TerraCom has considerable experience operating as both a wireline and wireless Lifeline-
only ETC. It is currently in compliance with all federal and state rules in the states of Arkansas,
Indiana, Iowa, Louisiana, Maryland, Nevada, Oklahoma, Texas, West Virginia, Wisconsin, and
the Commonwealth of Puerto Rico, where it has been designated an ETC by the state or territory
commissions. As a Lifeline-only ETC, operating successfully within the Commission’s existing
rules, TerraCom has given considerable thought towards how it will comply with the
Commission’s recently-adopted new rules for Lifeline-only ETCs.

ii

In its Lifeline Reform Order, the FCC imposed a number of changes to its existing rules
in order to ensure that Lifeline consumers receive all the same public safety benefits that are
available to other telecommunications services consumers, and to ensure that carriers operate in a
manner that facilitates prudent Fund administration by the USAC. Among other obligations
imposed, the Commission explicitly requires all Lifeline-only ETCs to 1) provide 911/E911-
compliant handsets to all their customers, 2) describe their service offerings and the areas in
which these services are available, and 3) explain how the ETC plans to comply with the other
major rule changes adopted in this Order.
TerraCom believes that it is already in compliance with the 911/E911 handset obligations
imposed by the Order, and it will continue to comply with these obligations. Moreover,
TerraCom also describes its company-wide, and state-specific, Lifeline service offerings in this
document.
The most significant information provided in this Compliance Plan explains how
TerraCom will implement the many major rule changes in this Order. Among these rule
changes, one of the largest involves how TerraCom enrolls customers, specifically how it plans
to obtain customer information, customer consent to use this information pre-enrollment for the
purposes of determining that the customer’s household does not already receive any other
Lifeline-supported services, and to verify whether the customer is eligible for Lifeline enrollment
under either a supported program, or by virtue of income qualification.
To this end, TerraCom has adopted a new customer certification form, a copy of which is
attached as Exhibit 1. This new customer certification form will be the focus of all initial
customer contact, regardless of how the customer chooses to initiate contact with TerraCom—
whether through a TerraCom retail store, online, or over the phone. Additionally, TerraCom has

iii

adopted a new eligibility certification practice in order to comply with the Commission’s new
rules designed to protect the integrity of the Fund. TerraCom will, as the Commission’s new
rules require, first check the National Lifeline Accountability Database to determine that the
customer’s household is not already receiving a Lifeline-supported service. TerraCom will then
continue to use (where available) state eligibility databases or employee verification of the
customer’s program/income-based eligibility.
For successfully enrolled customers, and for all its existing customers, TerraCom has
adopted new procedures to ensure that a customer re-certifies eligibility as required (either every
90 days for customers enrolling using a temporary address, after 60 consecutive days of non-
usage, or annually), by contacting TerraCom through a number of convenient channels (in-
person, over the phone, via return text, email, or online, using TerraCom’s website.
Correspondingly, TerraCom has also developed procedures to promptly de-enroll Lifeline
customers when notified by the Administrator that the customer’s household is receiving
duplicative supported services, or when a customer fails to timely recertify ongoing eligibility.
TerraCom is also modifying its internal data collection/customer account databases in
order to be able to comply with the many new record keeping requirements imposed by the
Commission’s Order. The Commission has specified a number of new requirements that will
better facilitate an ETC’s ability to respond to an audit request, or to conduct its own internal
audits periodically. TerraCom is also modifying its customer-specific, and company-wide,
databases so as to facilitate quicker and easier retrieval of the information necessary to comply
with the Commission’s new reporting requirements.
The Commission’s new rules also impose several other “new” requirements on ETCs,
which TerraCom is already in compliance with, or with which TerraCom can easily comply.

iv

These new requirements include providing additional information on Lifeline eligibility and
terms of receiving the federal assistance on all new advertising materials. To demonstrate
compliance with this new obligation, TerraCom has included a sample of the information it will
include on all new marketing materials.
The Commission, in its Order and new rules, also changed and standardized the Lifeline
reimbursement procedures for all ETCs. Under the new rules, all carriers must limit requests for
reimbursement to those customers that they actually served in the past month—also known as
“actual” reimbursement (vs. the previously-acceptable scheme of allowing carriers to receive
advance reimbursement for “projected” customers). TerraCom will move to operating on an
“actual” reimbursement schedule in accordance with the process set forth in the Order.
Finally, the Commission also imposes a requirement that service providers seeking to
receive Lifeline subsidies be able to demonstrate that they are technically and financially capable
of providing Lifeline-supported service. TerraCom has been providing service to, primarily, low
income customers since first being designated an ETC in 2004. TerraCom is a profitable firm, is
in good standing with all its vendors so as to ensure its ability to provide customers with safe and
reliable service, and has been providing telecommunications services to its customers, in
compliance with applicable federal and state regulations for 8 years.
Accordingly, upon the demonstrated intent and ability to comply with the Commission’s
newly-adopted Lifeline obligations described in the foregoing Compliance Plan, TerraCom asks
that the Commission promptly approve this Plan and allow TerraCom to operate as a beneficiary
of the “blanket forbearance” grant extended to all qualifying providers under the Lifeline Reform
Order. Upon approval of this Compliance Plan, TerraCom also asks that the Commission grant
its pending Petition for Limited ETC Designation.

1 

Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554

)
In the Matter of )
)
Telecommunications Carriers Eligible for ) WC Docket No. 09-197
Universal Service Support )
)
Lifeline and Link Up Reform and Modernization ) WC Docket No. 11-42
)
TerraCom, Inc. Blanket Forbearance )
Compliance Plan )
)
Petition of TerraCom, Inc. for Limited Designation )
as an Eligible Telecommunications Carrier for )
Purposes of Receiving Low Income Support Only )
)

COMPLIANCE PLAN OF TERRACOM, INC.

I. INTRODUCTION

TerraCom, Inc. (“TerraCom”), by its undersigned counsel, hereby submits this plan to
comply with the new legal obligations imposed on telecommunications carriers by the Federal
Communications Commission (“FCC” or the “Commission”) in its Order reforming and
modernizing the Lifeline and Link Up programs of the Universal Service Fund (“USF”).1 In its
Lifeline Reform Order, the Commission granted “blanket forbearance” from Section
214(e)(1)(A) of the Communications Act of 1934, as amended (the “Act”), to all
                                                            1 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, Report and Order and Further Notice of Proposed Rulemaking,
Docket Nos. 96-45, 03-109, 11-42, and 12-23, January 31, 2012 [rel. February 6, 2012].
(“Lifeline Reform Order” or “Order”).

2 

telecommunications carriers seeking limited ETC designation to offer Lifeline services.2
TerraCom has a Petition for Limited ETC Designation pending at the Commission, and requests
that, concordant with Commission grant of this Compliance Plan, the Commission also approve
its Pending ETC Petition.3 The extension of blanket forbearance not only covers carriers
operating as mobile virtual network operators (“MVNOs”) using the facilities of other carriers,
but to carriers that would not obviously need Commission forbearance, such as carriers providing
service using their own facilities, or a combination of their own facilities and those of other
carriers.4
All telecommunications carriers are eligible to receive blanket forbearance on the
condition that the carriers seeking the blanket forbearance agree to submit a compliance plan,

2 See, Lifeline Reform Order, ¶¶ 368-391.
 3 See, Petition of TerraCom, Inc. for Limited Designation as an Eligible Telecommunications
Carrier in the States of Alabama, Connecticut, Delaware, New Hampshire, New York, North
Carolina, Tennessee, the Commonwealth of Virginia, and the District of Columbia, WC Docket
No. 09-197, filed June 13, 20011. This Petition was subsequently amended on June 28, 2011 to
include the State of Florida. While TerraCom’s Petition for Limited ETC Designation originally
sought Link Up support, in addition to Lifeline support, this portion of its request has been
rendered moot by the Lifeline Reform Order, and is hereby withdrawn. Thus, TerraCom still
seeks Lifeline-only designation in the above-mentioned jurisdictions for which the Commission
has the authority to perform such designation.
4 In this instance, the term “forbearance” (as discussed in the Order) is actually somewhat
confusing. In the Order, the Commission has forbidden all carriers, regardless of how they
provide service, from obtaining “Lifeline-only” eligible telecommunications carrier (“ETC”)
status in any “new” states unless, or until, these carriers have submitted compliance plans
explaining how they will comply with all of the Commission’s rule changes. Similarly, states
are forbidden to grant new “Lifeline-only” ETC petitions until the Commission has approved the
requesting carrier’s compliance plan. See, Lifeline Reform Order, ¶ 380 (“No designations shall
be granted for any pending or new Lifeline-only ETC applications filed with the states or the
Commission after December 29, 2011, and carriers shall not receive reimbursement from the
program, until the Bureau approves their compliance plans.”) (emphasis added) On the other
hand, the restrictions discussed in the Order do not appear in the new rules that are included in
Appendix A of the Order. But see, new 47 C.F.R. § 54,401(d) (states can certify carriers as
ETCs, including Lifeline-only, as long as they obtain prices, terms, and conditions of service.)

3 

subject to the approval of the Wireline Competition Bureau (“the Bureau”), describing how they
intend to comply with the Commission’s new requirements for participating in the Lifeline
program.5 As explained below, TerraCom will fully comply with the conditions imposed in the
Lifeline Reform Order to ensure that the Commission’s concerns regarding consumer safety and
the fiscal integrity of the Universal Service Fund (“the Fund”) are completely satisfied.
Accordingly, and because TerraCom has several state Lifeline-only ETC applications pending
(and which are now dependent on the Commission’s approval of TerraCom’s Compliance
Plan6), it is TerraCom’s sincere desire that the Commission act expeditiously to approve its
Compliance Plan.
II. TERRACOM BACKGROUND
TerraCom began providing retail landline telecommunications service in 2004. With
TerraCom’s years of experience focusing on providing high quality telecommunications services
to low income consumers, TerraCom became one of the first competitive ETCs in 2004. Today,
TerraCom provides both landline and wireless service to well over 200,000 customers as an ETC
in Arkansas, Indiana, Maryland, Nevada, Oklahoma, Texas, West Virginia, Iowa, Louisiana,
Puerto Rico and Wisconsin. While TerraCom specializes in providing superior service at
affordable rates to low income consumers, and is a “Lifeline-only” ETC, its customers are not
exclusively Lifeline-supported. In most states, TerraCom’s service territory is limited to the area
served by the large incumbent LECs (which are required under the Act to lease pieces of their
networks to competitive carriers at cost-based rates).

5 See, Lifeline Reform Order, ¶¶ 368-391.
6 Id. at ¶ 380.

4 

TerraCom prefers direct contact with consumers and will use outreach events, direct
sales, neighborhood agents, and TerraCom branded or authorized retail outlets. TerraCom’s
specialty is in identifying underserved customers through serving communities by local outreach,
and by becoming part of the communities it serves. To this end, TerraCom does not offer its
services through “chain” stores, but rather through its own store, and locally-owned stores
familiar with the underserved consumers in the communities TerraCom serves. TerraCom sells
the remainder of its service through Internet sales/inbound telemarketing (where a customer is
seeking to initiate service with TerraCom).
Consistent with Commission and industry trend data, TerraCom has found that
consumers—including low income consumers—are migrating away from wireline
telecommunications service and towards mobile wireless services. In its existing service
territories, TerraCom offers wireless service to consumers by using a combination of its own
facilities (offering more than just operator services or directory assistance), leased wireline
facilities, and the wholesale wireless services of Sprint Spectrum, LLC and Cellco Partnership
d/b/a Verizon Wireless.
As an ETC, and provider of telecommunications services to its customers, TerraCom has
an impeccable reputation. It has never been subject to sanctions by a state or the FCC, and—
while no carrier is without its mistakes or errors—TerraCom has auditing systems in place, has
been diligent in performing its obligations as an ETC, and has caught its few errors before they
were ever submitted to USAC for reimbursement. This information, coupled with certain other

5 

detailed demonstrations made, infra, helps to establish TerraCom’s financial and technical
capability to provide the supported service.7
Moreover, as part of the overall carrier certifications required by the Order and its rules,
TerraCom commits to comply with the Cellular Telecommunications and Internet Industry
Association’s Code for Wireless Service.8 Thus, TerraCom has the intention and demonstrated
ability to fastidiously comply with the Commission’s new requirements for Lifeline-only ETCs.
III. OBLIGATIONS IMPOSED ON ETCS BY THE LIFELINE REFORM ORDER

In order to continue to offer low income service and qualify for state and/or federal
Lifeline-only ETC designations, TerraCom—like any facilities-based or non-facilities-based
wireless telecommunications provider—must take advantage of the Commission’s blanket
forbearance and obtain approval of its Compliance Plan.9 In its Lifeline Reform Order, the
Commission explains that carriers seeking Lifeline-only ETC designation must, as part of their
Compliance Plans, describe how they intend to implement certain conditions specified in the
Order, as well as explain how the carrier plans to comply with the new rules, generally. The
conditions (both broadly and specifically) established by the Commission tend to focus on
ensuring that consumers are protected, and that carriers will do their best to ensure that they (and
their customers) cooperate fully in assisting with prudent, efficient administration of the Low
Income Fund by the Universal Service Administrative Company.

7 See, e.g., Lifeline Reform Order, ¶388 (whether a carrier has been the subject of an
enforcement action is relevant to financial/technical capability to provide Lifeline service under
new rule §54.202(a)(4).)
8 See, Lifeline Reform Order, Appendix A, §54.202(a)(3)
. 9 See n. 4, supra. The Commission’s Order, but not its rule changes, prohibits the states and the
Commission from designating any new Lifeline-only ETCs unless or until the Commission
approves a satisfactory Compliance Plan.

6 

In paragraphs 368 through 391, the FCC sets forth the conditions that carriers must
satisfy in order to receive approval of their Compliance Plans, and the corresponding blanket
forbearance allowing them to be granted Lifeline-only ETC designation by the states or the
Commission. The conditions established by the Commission range from the very specific, such
as requiring carriers to provide all customers receiving Lifeline-supported service with access to
911 and E911 service (regardless of activation status or available minutes) as well as E911-
compliant handsets10, to the ubiquitously general (requiring compliance plans to describe “the
measures the carrier will take to implement the obligations contained in this Order”).11
In this Compliance Plan, TerraCom will describe in detail how it plans to comply with
the rule changes made in the Lifeline Reform Order. Specifically, TerraCom will address the
Commission’s concerns regarding how it intends to comply with: 1) the Commission’s
911/E911 service requirements12, 2) providing a detailed description of its Lifeline-supported
service offerings13, and 3) outlining the measures it will take to implement the more significant
changes in the Order.14 The large majority of changes imposed by the Order, and the
Commission’s new rules implementing the Order, are addressed in this Compliance Plan, which
will describe the way TerraCom plans to: a.) enroll customers, including a description of how
TerraCom will: i) initially qualify customers’ eligibility to prevent duplicate subsidies being
awarded to the same household, ii) initially qualify customers’ eligibility to make sure that only

10 See, e.g., Lifeline Reform Order, ¶ 373.

11 Id. at ¶ 379.
12 Id. at ¶ 373.
13 Id. at ¶368.
14 Id.

7 

program, or income, eligible customers are able to receive service; iii) how TerraCom intends to
annually certify its customers continued eligibility, including procedures for annual re-
certification15, b) TerraCom’s procedures to de-enroll customers who no longer meet the
eligibility requirements to receive Lifeline service, customers who have failed to use a free
service within a continuous 60 day period, and customers who have failed to re-certify their
continued Lifeline eligibility as part of an annual (or 90 day, for customers initially enrolling
with temporary addresses) re-certification process16, c) the records that TerraCom will keep to
facilitate efficient audits of TerraCom’s customer base17, as well as the customer data TerraCom
will collect to satisfy its reporting requirements to USAC (and to allow it to further cooperate
with USAC should additional information be needed); d) TerraCom’s proposed procedures for
submitting and collecting reimbursements from USAC; e) providing copies of its marketing
materials that describe the customer eligibility requirements for Lifeline (both income and one
per household), the continued obligation of customers to notify TerraCom of changes in their
address, changes effecting eligibility, the customer’s obligation to initially certify eligibility and
to annually re-certify eligibility under penalty of perjury; and f) TerraCom’s technical and
financial capability to provide Lifeline-supported services to low income customers.18

15 Lifeline Reform Order at ¶¶379, 383, n.1004. TerraCom will, of course, also re-certify those
customers that enrolled using temporary addresses every 90 days.
16 See, Id., Appendix A, § 54.405(e)
17 Lifeline Reform Order at ¶379.
18 Id. at ¶¶379. 383, and 390.

8 

A. Customers of TerraCom Lifeline-Supported Services Will Have Access to
911/E911 Service and Will Receive E911 Compatible Handsets

In its Lifeline Reform Order, the Commission (as it has in all of its previous forbearance
grants) requires carriers seeking “blanket forbearance” to provide—as a condition to the
forbearance grant—911 and (where available) E911 service to customers regardless of the
activation status of their service plans.19 Thus, regardless of whether the customer has any
remaining minutes on their monthly service plan, the customer must be able to use emergency
services.
TerraCom supports the Commission’s reasoning in requiring this condition, and, is aware
that this requirement—that customers always have access to the technologically-mandated
emergency access on all active mobile phones—is a current obligation the Commission imposes
on all wireless providers for their customers.20 TerraCom understands that mobile wireless
service is much less valuable to its customers if the customer cannot rely on their TerraCom
mobile service for emergency situations, and TerraCom already complies with this obligation.
Another public safety-related condition, routinely required by the Commission, is for
carriers receiving forbearance to ensure that all Lifeline-only customers have access to E911-
capable handsets.21 This is another condition that is already a TerraCom policy, and comes with
all TerraCom mobile wireless services (both Lifeline-supported, and non-Lifeline-supported).
TerraCom currently complies with this condition and automatically provides each new customer
with an E911-capable handset. In fact, TerraCom has no non-E911-compliant handsets in its
                                                            19 Lifeline Reform Order, at ¶373.
20 See, generally, 47 C.F.R. § 20.18.
21 Lifeline Reform Order at ¶373.

9 

inventory. Nonetheless, if TerraCom discovers any Lifeline-supported customers that do not
have a handset that is E911-capable, TerraCom will promptly replace that handset with a
compliant handset. Similarly, if TerraCom has any non-Lifeline-supported customers that are
eligible for, and wish to convert their service to, mobile wireless Lifeline service, TerraCom will
provide these customers with E911-capable handsets.
Finally, the Commission requires Lifeline-supported carriers to comply with both of these
conditions as of the effective date of the Order. TerraCom is currently in compliance with both
911/E911-related conditions, and will still be in compliance when the Order becomes effective.
B. Description of TerraCom’s Lifeline Service Offerings
The Commission requires that every carrier seeking blanket forbearance, submit a
Compliance Plan containing detailed information regarding its Lifeline-supported service
offerings, including terms of service and the geographic areas where the services are available 22
TerraCom offers all supported services, throughout the Sprint Wireless Service Area footprint
and that of Verizon Wireless, in Arkansas, Indiana, Iowa, Louisiana, Maryland, Nevada,
Oklahoma, Texas, Puerto Rico, West Virginia, and Wisconsin. All 611 and 911 calls are free,
and do not count against the customer’s airtime. Directory assistance calls (411) are “free”;
however, applicable airtime charges are assessed as minutes of usage.
TerraCom offers three basic Lifeline service packages throughout all of its service
territories, except Oklahoma. In addition, TerraCom offers two plans that are only available to
Oklahoma residents. TerraCom’s basic Lifeline programs are listed below. These plans are
taken directly from the TerraCom Wireless website.23

22 Lifeline Reform Order, at ¶368.
23 www.terracomwireless.com/plans/lifeline-free-plans/

10 

Lifeline Free Plan 68
Each month you will receive 68 free voice minutes. Text messaging will be assessed at a rate of
0.3 minutes per text message for sending and 0.3 minutes per text message for receiving text
messages. Unused minutes will rollover from month to month, see terms and conditions for
more information. This plan is not available to new subscribers and existing subscribers may
change to any plan they choose.
Lifeline Free Plan 125
Each month you will receive 125 free voice minutes. Text messaging will be assessed at a rate
of 1 minute per text message for sending and 1 minute per text message for receiving text
messages. Unused minutes will rollover from month to month, see terms and conditions for
more information. This plan is not available to new subscribers and existing subscribers may
change to any plan they choose.
Lifeline Free Plan 250
Each month you will receive 250 free voice minutes. Text messaging will be assessed at a rate
of 1 minute per text message for sending and 1 minute per text message for receiving text
messages. There are no rollover minutes with this plan. Unused minutes will expire each month
on the service expiration date. This plan is available in all states where TerraCom Wireless offers
service except in tribal areas of Oklahoma.
Oklahoma Lifeline Unlimited Plan
Each month you will receive unlimited voice minutes for $6.20 per month plus fees and taxes.
Text messaging will not be available with the unlimited talk plan. There are no rollover minutes

11 

with this plan. Unused minutes will expire each month on the service expiration date. This plan
is only available to Oklahoma residents.
Oklahoma Lifeline 1000 Plan
Each month you will receive 1000 voice minutes or 1000 text messages for $1.00 per month plus
fees and taxes. Text messaging will be assessed at a rate of 1 minute per text message for
sending and 1 minute per text message for receiving text messages. There are no rollover
minutes with this plan. Unused minutes will expire each month on the service expiration date.
This plan is only available to Oklahoma residents.

With all TerraCom Lifeline service plans, additional minutes are available for as low as
$.05/minute. This low per minute rate does not require the customer to purchase an
unreasonably large amount of minute, but can be obtained with a purchase of only 200 additional
minutes for $10.00. The lowest incremental purchase of minutes is 60 minutes for $5.00.
Moreover, each TerraCom subscriber can select a phone—either a free phone (choices
include refurbished phones, as well as refurbished smartphones such as the Blackberry Curve®
and in the future new phones), or purchase an upgraded phone from a wide inventory. For those
customers choosing the smartphone, data can be added to any phone plan starting at
$1.25/megabyte—a price that can be reduced on a “per/megabyte” basis when the customer
purchases multiple megabytes of data.
Thus, TerraCom has demonstrated that it offers a number of “no contract” plans for
Lifeline users that provide for flexibility based on the particular consumer’s usage pattern.
TerraCom also allows low income customers to add affordable data usage to these free voice/text

12 

minutes—facilitating greater smartphone utilization, consistent with the Commission’s goal of
promoting broadband access to all Americans.
C. TerraCom’s Plans To Implement New Lifeline Provider Obligations
As previously noted, one of the Commission’s requirements for all Compliance Plans it
requires to be submitted in order to benefit from the grant of “blanket forbearance” in the Order
is for the carrier to describe how it will comply with the remainder of the new obligations
imposed on Lifeline participants in the Order. In this section, TerraCom will explain how it
plans to implement the new obligations in the Order, and incorporate those obligations into
TerraCom’s existing processes for enrollment, de-enrollment, record keeping/re-certification,
seeking reimbursement from USAC, and marketing service to eligible consumers. TerraCom
will also demonstrate that it is technically and financially capable of providing Lifeline service to
consumers.
1. Enrollment
By way of background, the Order requires each prospective customer to apply for
Lifeline service. The Commission has changed its procedures for how carriers must qualify
customers for enrollment in the Lifeline program, and how customers must certify their
eligibility. The Commission, for the first time, has established uniform eligibility and
application criteria for enrolling low-income customers in the Lifeline program. In the Lifeline
Reform Order, the FCC integrated and standardized the eligibility and certification criteria
through the establishment of what may be called a uniform application process. Each new
prospective customer will have to provide certain information and eligibility certifications as part
of an overall application to receive benefits under the Lifeline program.

13 

However, before submitting an application to receive Lifeline-supported service under
the Commission’s new rules, the ETC providing the Lifeline service must obtain consent from
each of its new and existing subscribers to transmit the subscriber’s information to the program
Administrator. The carrier must explain in clear, and easy-to-understand, language the
information that the carrier will have to transmit to the Administrator.24 If the subscriber refuses
to grant the carrier permission to transmit this information to the Administrator, the subscriber
will not be eligible to receive Lifeline service.
The application will require each prospective customer to provide all of the information
required in revised rule 47 C.F.R. § 54.410(d)(2): the subscriber’s full name; the subscriber’s
residential address; whether the subscriber’s residential address is permanent or temporary; the
subscriber’s billing address (if different from the residential address); the subscriber’s date of
birth; the last four digits of the subscriber’s social security number, or the subscriber’s tribal
identification number in lieu of a social security number; whether the subscriber is seeking to
demonstrate eligibility to receive Lifeline service under the program-based criteria, or based on
income.
Moreover, as part of the application (and pursuant to revised rule 47 C.F.R. § 410(d)(3))
the prospective subscriber will have to certify under penalty of perjury that: the subscriber meets
the income-based or program-based eligibility criteria for receiving Lifeline, explained in §
54.409; the subscriber will notify the carrier within 30 days if for any reason the subscriber no
longer satisfies the eligibility criteria, or if the subscriber no longer satisfies the “one subsidy per
household” qualification; if the subscriber is seeking to qualify for Lifeline as an eligible resident
of Tribal lands, that they actually live on Tribal lands; if the subscriber moves to a new address,
                                                            24 See Lifeline Reform Order, Appendix A, §54.404(b)(9).

14 

they will notify the carrier of their address change within 30 days; if the subscriber provided a
temporary address upon sign-up, the subscriber will verify their correct address every 90 days or
face de-enrollment; the subscriber’s household will receive only one Lifeline service and, to the
best of the subscriber’s knowledge, their household is not already receiving a Lifeline service;
the subscriber’s information on their application is true and accurate to the best of their
knowledge; the subscriber understands that providing false information to obtain Lifeline
benefits is punishable by law; and the subscriber acknowledges that they may be required to re-
certify continued eligibility for Lifeline at any time, and that the subscriber’s failure to re-certify
will result in de-enrollment and termination of the subscriber’s Lifeline benefits pursuant to §
54.405(e)(4).
TerraCom-Specific Enrollment
As an initial matter, in those few states that have a state administrator, TerraCom will
fully cooperate with the state Lifeline administrators to ensure that it does everything necessary
to ensure it is in compliance with both state and federal enrollment, verification, and re-
certification procedures. For all states that do not have a Lifeline administrator, TerraCom will
perform the same first step in the process of enrollment. Regardless of how the customer
applies—whether in a retail store, online, or over the phone, each customer will end up supplying
the same information via TerraCom’s standard customer certification form. (Attached as
Exhibit 1.) This form contains all relevant information required by the Commission’s new rules,
and requires the customer to certify, under penalty of perjury, that to the best of the customer’s
knowledge all of the information supplied is correct. The customer will also agree to contact
TerraCom in the event any information regarding the customer’s ongoing eligibility, or
household information, should change.

15 

TerraCom enrolls Lifeline customers through several different marketing channels: 1) in
person, through company-owned and affiliated retail stores, 2) in person, through company
employees that are retail sales representatives, and 3) through customer-initiated contact, either
through inbound telemarketing or (more frequently) through online sales over the Internet. The
large majority of TerraCom’s sales are through its “in person” channels.
What is significant is that all of TerraCom’s retail sales are the result of direct contact
with the potential Lifeline consumer. The manner in which the sales will be made will be
slightly different, but the obligations imposed by the new rules will be addressed directly by
TerraCom. Before examining each new enrollment obligation, it will be helpful to explain how
TerraCom will interact directly with its customers through each sales channel.
Retail Store. These sales are the most “direct” and easiest to explain how TerraCom will
comply with the Commission’s new Lifeline obligations. The prospective customer comes into
the store, and is asked the basis for his or her claim to Lifeline eligibility; participation in a
qualifying program, or earning household income below 135% of the Federal Poverty
Guidelines. The store employee can verify the customer’s program, or income, based eligibility
in person. TerraCom provides excellent training/reference materials to its employees—an
example of which is attached as Exhibit 2—which allows the employees to verify the most
common forms of proof for each eligible program and/or income verification (based on the
Commission’s definition of “income” in §54.400(f)). The store employee will then ask the
prospective customer for additional documentation proving identity, and/or address verification.
The final program/income eligibility-specific step is for the customer to provide the required
information and make the certifications required by new rule §54.410(d)(3).

16 

If the customer appears to be eligible, the employee will explain the Commission’s
definition of “household”, defined in new rule §54.400(h), as an “economic unit” where related
or unrelated people share income and expenses. In the case of multiple applicants at the same
mailing address, the customer will then make the “one per household” certification required by
§54.410(d)(1). Finally, TerraCom will collect the necessary customer-specific information
required by new rule §54.401(d)(2) so that TerraCom can report the information to USAC to be
used to populate the National Lifeline Accountability Database (“duplicates database”), defined
in §54.400(i) of the Commission’s new rules.
The retail store employee then enters the customer’s information into TerraCom’s OSS
systems, where the information is checked against available databases (the duplicates database,
and TerraCom’s own list of existing customers). The retail store rep quickly determines whether
the customer is eligible to receive Lifeline service. In cases where a state program eligibility
database exists, the retail store personnel will contact TerraCom’s internal group dedicated to
verifying eligibility who will query the state database and either approve or deny the applicant.
Where proof of eligibility is needed, the retail personnel, who are trained on what is eligible
documentation will witness the documentation and sign the application demonstrating they have
witnessed the documentation.
Upon successful completion of the certification process, the customer is allowed to
choose a service plan, and, as mentioned earlier, select a phone—either a free phone (choices
include refurbished phones, as well as refurbished smartphones such as the Blackberry Curve®
and in the future new phones), or purchase an upgraded phone from a wide inventory. The

17 

customer then receives their phone right at the store, upon payment of a TerraCom’s customary
activation fee. The customer’s account is activated upon completion of an outbound call.25
Field Representatives. Frequently, TerraCom will dispatch employees as “field
representatives” to underserved communities, where the “field rep” focuses on traditionally
underserved low income customers. Opportunities for field reps to reach those customers not on
the network range from educational sessions at low income housing, or nursing homes, to
sponsoring booths at community events.
The protocol for signing up customers in the field is similar to that of signing up
customers in a store, in the sense that the field rep can personally see whether the customer is
eligible based on program participation or income qualification. The customer can also provide
the requisite information, and sign the required eligibility verifications, from the field. Should a
customer in the field be determined to be ineligible but feels that the determination is incorrect;
the order can be submitted to TerraCom for review and investigation. In such a case the phone
would be mailed to the customers upon approval and the customer can personally activate their
service – as in the manner of all TerraCom phones – by completing an outbound call.
Inbound Channel Marketing. Prospective customers can also apply for, and obtain, Lifeline
service from TerraCom either over the phone or through the Internet. Customers choosing to
obtain service through inbound channels must either fill out an application online, or provide the
relevant information to the customer sales rep over the telephone. In these cases, TerraCom will
verify eligibility via a state database, state administrator, or by reviewing documentation of
eligibility submitted by the applicant in advance of receiving service.
                                                            25 See, Lifeline Reform Order, Appendix A, §54.407(c)(2)(i).

18 

Online Sales. To apply for TerraCom Lifeline service online, a customer will fill out an
application, provide the necessary information that all prospective Lifeline customers must
provide, and be taken through successive screens, which clearly explain all relevant legal
eligibility requirements. If the customer is seeking to qualify for Lifeline service based on their
participation in a particular program (or income level), the prospective customer may be able to
be qualified by an inbound sales rep who inputs the prospective customer’s information into an
eligibility database (if available for the relevant state). However, in most cases, the prospective
customer will fill out the relevant eligibility forms on the computer, and then send in copies of
the records needed by TerraCom to verify the customer’s eligibility to participate in Lifeline.
Once the prospective customer is successfully verified by TerraCom, the customer can be
enrolled in the service plan they have chosen, and then mailed their handset.
Assuming the customer has successfully completed the online application process,
TerraCom will have all the information it needs to verify the customer is only receiving one
Lifeline subsidy for their household, to verify eligibility, to satisfy its record-keeping obligations,
and to send to USAC in order to populate the duplicates database. The requisite certifications
needed by TerraCom to establish service with the prospective customer can be obtained as
electronic signatures.26
TerraCom’s proposed method of accepting electronic signatures—on all of its online
certifications and re-certifications—is to allow the customer to create a unique electronic
signature by typing their name, and providing their date of birth and their social security number.
The customer’s name, combined with their date of birth and their social security number, is
sufficiently unique to satisfy the Commission’s new rules for accepting electronic signatures.
                                                            26 See, Lifeline Reform Order, Appendix A, §54.419.

19 

Inbound Telemarketing. To obtain TerraCom Lifeline service, a customer can call TerraCom to
initiate service. The process is very similar to online enrollment, except that instead of being
taken through successive screens, the customer is asked a series of qualifying questions by a
customer service representative. The questions will all be designed to elicit true and accurate
information that is necessary for TerraCom to obtain a complete standard certification form. See
Exhibit 1. If, at any time during the conversation, it becomes apparent to the customer service
rep that the prospective customer is unlikely to qualify for TerraCom Lifeline service, the
customer service rep will explain the issue to the customer and offer to allow the customer to
sign up for one of TerraCom’s non-Lifeline service plans.
On the other hand, if the customer provides information indicating that the customer
would be eligible to obtain Lifeline service, the customer service rep will take the customer as
far as possible in trying to qualify the customer. For example, if there are no other Lifeline
subscribers in the customer’s household, and the customer participates in a Lifeline-eligible
program (or is income-qualified), the customer service rep will try to verify the customer’s
information through a state database (if available). If the customer seems to qualify (through a
database query), then the customer service rep will open a file for the customer, take the
customer’s information that is required to be collected from each customer, send the customer
the requisite certification forms for verification of eligibility (or allow the customer to certify
eligibility through an IVR recorded and associated with the customer’s account), and request
copies of the evidence that would prove eligibility in cases where a state database is not
available.
As always, if the prospective customer fails to qualify for Lifeline service, TerraCom will
explain to the customer why the request was rejected. On the other hand, if the prospective

20 

customer sends in sufficient evidence to qualify for Lifeline eligibility, and adequately certifies
eligibility, TerraCom will notify the customer, and enroll the customer in their requested service
plan, and send the customer the phone they have requested/purchased (if the customer has
expressed a handset preference).
2. De-Enrollment
In order to most efficiently use funds set aside for Lifeline customers, the FCC has
adopted rules to ensure that only customers eligible to participate in the Lifeline program receive
the benefit of the Lifeline subsidy. These rules require that Lifeline ETCs “de-enroll” customers
who are no longer eligible to receive Lifeline benefits from the carrier’s list of customers for
whom Lifeline reimbursement is sought from USAC.27
The Commission’s new rule requires carriers to “de-enroll” customers from Lifeline
enrollment for several reasons: the carrier has reason to believe that the customer no longer
participates in a Lifeline-eligible program, or no longer meets the income-based criteria for
Lifeline eligibility, and the customer fails to prove eligibility within 30 days28; the Fund
Administrator notifies the ETC that either the customer is receiving Lifeline support from more
than one carrier, or that more than one person in the customer’s household is receiving a Lifeline
subsidy29, the customer has failed to “use” a free service for more than 60 consecutive days30; or,
the customer has either failed to perform their required annual recertification of continued
eligibility, the annual re-certification that the customer is not in violation of the one-per-

27 See, Lifeline Reform Order, Appendix A, §54.405(e)(1)-(4).
28 Id., §54.405(e)(1).
29 Id. at (e)(2).
30 Id. at (e)(3).

21 

household rule, or (for customers who provided a temporary address upon enrollment) the
customer has failed to re-certify their temporary address within the 90 day window (or failed to
provide the carrier with a permanent address within the same time period).31
With the exception of the situation where an ETC is notified by the Administrator that a
customer/customer’s household is receiving duplicate support, each basis for de-enrollment
requires the carrier to notify the customer that their support is in jeopardy, and provide the
customer with 30 days to either refute or cure their apparent ineligibility to receive Lifeline
support.32 When an ETC is notified that they are receiving duplicative support for a customer
that has been confirmed to be ineligible by the Administrator, the ETC has 5 days to remove the
ineligible Lifeline recipient from its reimbursement list.
Customers receiving duplicative subsidies not only present a risk to the Fund, but they
present a financial risk to TerraCom if customers not eligible for reimbursement are allowed to
continue to use their phones, and thereby raise TerraCom’s unrecoverable costs. Because it is in
TerraCom’s self-interest to immediately remove from its Lifeline roles those customers
identified by the Administrator as disqualified from receiving Lifeline service, TerraCom will
further explain how it will comply with this new obligation.33

31 Lifeline Reform Order, Appendix A, §54.405(e)(4).
32 Id. at §54.405(e)(1).
33 TerraCom recently encountered such a situation in Wisconsin when it agreed to assume the
service for another company that was failing and was close to disconnecting customer service.
In this situation, after TerraCom was designated an ETC by the Wisconsin Public Service
Commission, and assumed service for those customers in jeopardy of losing service, TerraCom
immediately de-enrolled more than half of the customers served by the previous carrier.
TerraCom has also had to continue service to the remaining customers at its own cost, and has
only been able to re-certify a fraction of the customers whose service was assumed. TerraCom
nonetheless must pay its own vendors for services consumed by uncertified customers until it can
get a valid certification and obtain USAC reimbursement.

22 

Putting aside those subscribers recovering duplicative support, every qualifying Lifeline
subscriber is subject to de-enrollment for reasons both completely outside the ETC’s control (e.g,
customers failing to use service and customers no longer qualifying for the subsidy), and for
reasons that can be avoided if the customer has sufficient notice to comply with the rules. For
this reason, TerraCom has adopted procedures to help deserving customers to avoid undeserved
de-enrollment, and procedures for quickly removing subscribers that the Administrator has
determined to be wasting Lifeline funds.
When TerraCom establishes a customer account, it also places a Lifeline start date on the
account, based on the potential vulnerabilities of the customer to undeserved de-enrollment. For
example, every Lifeline account is subject to recertification on an annual basis that: the
subscriber still meets the criteria to be considered a qualifying low-income customer under
§54.409, and that the subscriber’s household is not receiving more than one Lifeline subsidy.
Thus, every Lifeline subscriber should receive (through multiple channels) an advance reminder
that they must re-certify annually, along with an explanation of the many convenient ways that
TerraCom offers customers to re-certify. TerraCom allows customers to re-certify via dialing a
toll free number (IVR), return text, email, regular mail, and online through TerraCom’s website.
Moreover, once the duplicate database is up and working, TerraCom will be able to
perform certifications for its customers that have qualified through a database query. Regardless,
though, it is clear that TerraCom, and many other Lifeline-only ETCs, will be sending out annual
re-certification requests on a daily basis.
Annual re-certifications are required for all customers, but TerraCom also creates an
advance reminder for customers that have established their accounts using a temporary address.

23 

Customers establishing service with a temporary address are potentially difficult to remain in
contact with, so TerraCom sends out text notifications to these customers on a monthly basis.
Similarly, since many—if not most—of TerraCom’s Lifeline customers do not pay a
regular monthly bill, TerraCom has tracking software to notify the customer if the customer has
not used their service for more than 60 consecutive days . These notifications are not only
helpful to ensure that the customer does not risk losing their phone by failing to use their phone,
but the notifications also help the customer become more aware of their own usage patterns,
which might cause the customer to choose a different plan (for example, a plan with less monthly
minutes, but minutes that “rollover” to the next month). After notification, if the customer fails
to use the phone, it is automatically disconnected by the system.
3. Recordkeeping Requirements
In adopting the Lifeline Reform Order the Commission, to paraphrase Commissioner
McDowell’s separate statement, takes the large step of imposing accountability on a government
entitlement program. In its directives for what should be included in a carrier’s Compliance
Plan, as described in Paragraphs 368-391, the Commission frequently states that it would like
carriers to explain and describe how they will comply with the rule changes in the Order. If
accountability equals recordkeeping, then this section is perhaps the most challenging and
comprehensive of this entire Compliance Plan.
While only one section of the new rules, §54.417 is specifically entitled “record
keeping”, most of the rule changes either create new records and/or create new recordkeeping
requirements. For purposes of organizing TerraCom’s explanation of how it intends to comply
with the new recordkeeping obligations imposed under the Order, TerraCom will divide records
into “individual account records” and “company-wide records”. The theory behind this

24 

organization of TerraCom’s explanation of how it will meet the Order’s recordkeeping
requirements is that, for reporting purposes, TerraCom is required to report on both individual
account compliance (on a company-wide basis), company wholesale compliance, and company-
wide performance compliance.
i. Individual Account Records
For each individual Lifeline account, TerraCom will keep customer records for the entire
length of time the customer remains in the Lifeline program, and for certain records within the
individual accounts, TerraCom will keep customer records for 10 years following customer de-
enrollment from the Lifeline program.34 TerraCom will keep the following records for each
subscriber’s individual Lifeline account:
--date that TerraCom queried the duplicates database35;

--date and information that TerraCom transmitted to Database36;

--date of transmission of updated customer information to Database37;

--date of transmission of customer de-enrollment to Database38;

--date of customer service activation and method of activation39;

--certification and re-certification forms for each subscriber40;

34 See generally, Lifeline Reform Order, Appendix A, §54.417, and Appendix B, proposed rule
§54.417.
35 Id., Appendix A, §54.404(b)(1).
36 Id., §54.404(b)(6).
37 Id., §54.404(b)(8).
38 Id., §54.404(b)(10).

39 See generally, Id., §54.407(c).
40 Id., §54.407(d).

25 

--per customer records of revenues forgone by providing Lifeline services in the form
requested by the Administrator for periodic reporting to the Administrator upon
request41;

--date and database upon which the ETC determined income-based eligibility42;

--date and documentation/data source used to determine income-based eligibility when no
database was available to determine subscriber eligibility43 which include the following
forms of acceptable documentation:

o prior year’s state, federal, or Tribal tax return
o current income statement from an employer or paycheck stub
o a Social Security statement of benefits
o a Veterans Administration statement of benefits
o a retirement/pension statement of benefits
o an Unemployment/Workers’ Compensation statement of benefit
o federal or Tribal notice letter of participation in General Assistance
o a divorce decree
o child support award
o other official document containing income information;

--state Lifeline administrator documentation of customer eligibility, and subscriber’s
certification of eligibility44;

--date, database, and program on which ETC determined subscriber eligibility45;

--keep and maintain accurate records detailing data source a carrier used to determine a
subscriber’s program-based eligibility or the documentation a subscriber provided to
demonstrate Lifeline eligibility46;

41 Lifeline Reform Order, Appendix A, §54.407(e).
42 Id., §54.410(b)(1)(A).

43 Id. at §54.410(b)(1)(B)(iii).
44 Id. at §54.410(b)(2).
45 Id. at §54.410(c)(1)(A).
46 Id. at §54.410(c)(1)(iii).

26 

--notice of program-certification and customer self-certification, when performed by a
state agency or state Lifeline administrator47;

--prospective subscriber certification, where subscriber acknowledges 1) Lifeline
qualifications in terms of one benefit per household and the requirement that a violation
of the rules could result in de-enrollment, 2) require each prospective subscriber to
provide certain information with which to populate the duplicates database, 3) require
each prospective subscriber to certify, under penalty of perjury, that the subscriber meets
the income-based, program-based, or Tribal Lands criteria for receiving Lifeline, and the
subscriber knows the Lifeline program rules, and will notify the carrier if the subscriber
ceases to qualify48;

--maintain records re-certifying all subscribers remain Lifeline eligible under a qualifying
program or income eligibility, and re-certification by the subscriber that they can confirm
their original certification under §54.410(d), except those subscribers that are required to
be re-certified by state agencies or administrators49;

--where a state administrator or agency is responsible for re-certification, the carrier has
to: 1) maintain re-certification results from the state, 2) maintain the results of each state
administrator’s certification efforts for each subscriber in that state, and 3) where a state
has been unable to re-certify a subscriber, the ETC must keep the record and comply with
the relevant de-enrollment procedures50;

--maintain a record of each subscriber’s re-certification (or failure to re-certify) a
temporary address every 90 days51;

ii. Company-wide Records
The Commission requires ETCs to maintain some “company” records, but it also requires
the ETC to make annual reports, certified by an officer of the company, to the Commission. The
company reporting obligations require company officers to certify company procedures for

47 Lifeline Reform Order, Appendix A, §54.410(c)(2).

48 Id. at §54.410(d).
49 Id. at §54.410(f)(1)-(2).
50 Id. at §54.410(f)(3)-(5).
51 Id. at §54.410(g).

27 

maintaining compliance with the rules regarding ETCs participating in the Lifeline program.
The records, on an aggregate basis, that companies have to collect are primarily required to be
collected for reporting purposes. TerraCom will collect the following data, and report it to the
requisite authorities.
--provide, on an annual basis, the results of the ETC’s annual re-certification efforts to
the Commission and the Administrator. For states where the TerraCom has been granted
state ETC designation, it must report the results of its annual re-certification efforts to the
proper state regulators, and, for Tribal Lands52, the ETC must collect and report the
results of its Tribal re-certification process to the appropriate tribal government
officials53;

--if the ETC provides Lifeline discounted services to a reseller, it must obtain a
certification from the reseller that it is complying with all relevant Lifeline rules54;

--collect certain outage information for areas in which the carrier owns facilities, the
failure of which, results in an outage lasting greater than 30 minutes in any calendar year
and which affects critical services55;

--collect data on the number of complaints per 1,000 connections in the prior calendar
year56;

--certification of compliance with applicable service quality standards and consumer
protection rules57;

--certification that the carrier is able to function in emergency situations58;
                                                            52 TerraCom will report to the appropriate governing body with respect to Tribal Lands re-
certification efforts/results. In some states, like Oklahoma, the type of tribal government
officials (which would regulate service providers) do not exist. In these states TerraCom will file
its results with the proper local regulator such as the state commission.
53 Lifeline Reform Order.Appendix A, §54.416(b).
54 Id. at §54.417(b).
55 Id. at §54.422(b)(1).
56 Id. at §54.422(b)(2).

57 Id. at §54.422(b)(3).
58 Id. at §54.422(b)(4).

28 

--information regarding the terms and conditions of any service plans, and the terms and
conditions of any non-Lifeline plans available to the public59.

4. Reimbursement from USAC
In the Lifeline Reform Order, the FCC eliminated Lifeline reimbursement based on
“projected” lines for which the carrier expects to be compensated based on past growth. Instead,
in the Order, the Commission changed the method of Lifeline reimbursements to “actual” lines
served.60 To the degree it has not already done so, TerraCom will modify its reimbursement
requests to comply with the Commission’s new reimbursement scheme, based on actual lines
served.
5. Marketing Materials
In its Lifeline Reform Order, the FCC imposed certain obligations on ETCs to clearly
disclose on all of their marketing and advertising materials that the service they are offering is a
Lifeline service, that Lifeline is a government assistance program, that it is only available to
qualifying eligible customers, it is not transferable, and the program is limited to one discount
per household.61 Moreover, all materials describing the service must disclose the name of the
ETC providing the service.
TerraCom will include all of this required information on all of its ads describing its
service. TerraCom is in the process of changing its marketing materials to comply with the new
rules. Since TerraCom will not change its existing advertisements until it is sure it is in

59 Lifeline Reform Order, Appendix A, at §54.422(b)(5).
60 Id. at §54.407.
61 Id. at §54.405(a)-(d).

29 

compliance with the Commission’s rules, it has supplied proposed advertising copy. See
Exhibit 3, attached.
6. Financial and Technical Capability to Provide Service
In its Order, the FCC includes a new qualification for carriers seeking to become ETCs:
that they demonstrate they are financially and technically capable of providing the supported
Lifeline service in compliance with the Commission’s rules.62 Because TerraCom is seeking to
have its pending ETC Petition, as amended, granted in tandem with the Commission’s grant of
this Compliance Plan, TerraCom will demonstrate that it is financially, and technically, able to
completely comply with all of the new Commission rules governing Lifeline ETCs.
TerraCom can demonstrate that it is financially and technically capable of providing both
wireless and wireline Lifeline service, because it is already successfully providing both services
as a designated Lifeline ETC in nine states and one Commonwealth, serving over 200,000 lines.
TerraCom is not only capable of providing Lifeline-supported service, it is successfully
providing Lifeline-supported services in the states where it is designated an ETC. In these states,
TerraCom is growing its customer base, has no disproportionate consumer complaints, and offers
high quality service at affordable rates to all its customers.
Nonetheless, TerraCom will demonstrate, through Exhibit 4 (Declaration of Dale
Schmick) that it is financially capable of providing Lifeline-only service. TerraCom’s business
model is to serve low-income customers, who may, or may not, be eligible to receive Lifeline-
supported service. So, TerraCom does not, and does not intend to, offer exclusively Lifeline-
supported services—and is therefore not exclusively dependent on USAC for its revenue.
TerraCom will also explain that it is on good terms with all of its wholesale vendors, and can
                                                            62 Lifeline Reform Order, Appendix A, at §54.201(h), and §54.202(a)(4).

30 

afford to keep a customer’s service active without depending upon immediate reimbursement
from USAC in order to continue to provide service to its customers.63 Thus, it is clear that
TerraCom—with its years as a Lifeline-only service provider in good standing since first being
designated an ETC in 2004—has only become a more capable and qualified provider of Lifeline-
supported services.
* * *
As required by the Lifeline Reform Order, in order to take advantage of the
Commission’s conditional grant of blanket forbearance, TerraCom has hereby submitted a
Compliance Plan that effectively outlines the measures it will take to address each specific
concern elaborated by the Commission, and every significant rule change to the Lifeline program
addressed in its Order. The Commission should find that this Compliance Plan addresses all of
its concerns and grant TerraCom the conditional “blanket forbearance” from Section
214(e)(1)(A) of the Act by approving the instant Compliance Plan, as well as TerraCom’s
pending Petition for Limited ETC Designation in the subject states.64 Accordingly, the public
interest is best served by the Commission’s expeditious approval of this Compliance Plan and
TerraCom’s pending Petition for Limited ETC Designation. For these reasons, TerraCom
respectfully requests that the FCC approve this Compliance Plan, and at the same time grant its
pending Petition for Limited ETC Designation in the subject states of Alabama, Connecticut,
Delaware, Florida, New Hampshire, New York, North Carolina, Tennessee, the Commonwealth
of Virginia, and the District of Columbia.

63 See, Lifeline Reform Order, at ¶388.
64 See, n.3, supra.

31 

Respectfully submitted,

TERRACOM, INC.

___________________________
Jonathan D. Lee

JD Lee Consulting, LLC
1776 I Street, NW
Suite 900
Washington, DC 20006
[phone]

Its Attorney

March 2, 2012
Lance J.M. Steinhart, P.C. Attorneys At Law 1725 Windward Concourse Suite 150
Alpharetta, Georgia 30005

Also Admitted in New York Telephone: [phone]
Email: [e-mail] Facsimile: [phone]
March 1, 2023
VIA ECFS
Marlene H. Dortch, Secretary Federal Communications Commission 45 L Street NE
Washington, DC 20554

Re: TerraCom, Inc. Revised Compliance Plan, WC Docket Nos. 09-197 and 11-42
Dear Ms. Dortch:
TerraCom, Inc.’s (“TerraCom” or the “Company”) Compliance Plan, outlining the
measures the Company would take to implement the conditions imposed by the Federal
Communications Commission (“FCC” or the “Commission”) in its 2012 Lifeline Reform Order,1 was originally approved by the Wireline Competition Bureau (“Bureau”) on May 25, 2012.2 TerraCom filed its Fourth Revised Compliance Plan on October 3, 2016, which the Bureau approved on November 8, 2016,3 identifying a transfer of control and making revisions to comply
with rule changes since the 2012 Lifeline Reform Order.

1 See 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 (Feb. 6, 2012) (“2012 Lifeline Reform Order”).
2 Wireline Competition Bureau Approves the Compliance Plans of American Broadband & Telecommunications, Budget Prepay, Consumer Cellular, Global Connection, TerraCom and Total Call, Public Notice, 27 FCC Rcd 5776 (WCB rel. May 25, 2012); In Re
Telecommunications Carriers Eligible for Universal Service Support, et al., Third Revised Compliance Plan of TerraCom, Inc. (filed June 19, 2012) (providing minor updates requested by Bureau staff).
3 Wireline Competition Bureau Approves the Amended Compliance Plan of TerraCom, Public Notice, DA 16-1264 (rel. Nov. 8, 2016); In Re Telecommunications Carriers Eligible for
Universal Service Support, et al., Fourth Revised Compliance Plan of TerraCom, Inc. (filed Oct. 3, 2016).
Marlene H. Dortch March 1, 2023 Page 2
TerraCom now seeks expedited approval of the enclosed 5th Revised Compliance Plan,
which has been revised to: (1) reflect a proposed change in ownership of the Company; and (2)
update the information provided in the Company’s approved Compliance Plan due to the
passage of time.
Change in Ownership
Pursuant to the terms of an Agreement by and among TerraCom, Inc., an Oklahoma
corporation; Global Reconnect, LLC, a Delaware limited liability company (“Seller”); and
Maxsip Telecom Corporation, a New York corporation (“Buyer” or “Maxsip”), Buyer will
purchase one hundred percent (100%) of the issued and outstanding common stock of TerraCom
including its wholly owned subsidiary, YourTel America, Inc. (the “Transaction”). In step one
of the Transaction, MaxSip is acquiring forty nine percent (49%) of the issued and outstanding
common stock of TerraCom; step two of the Transaction is the purchase of the remaining fifty-
one percent (51%) of the stock of TerraCom upon obtaining any required regulatory approvals
for the Transaction, including this 5th Revised Compliance Plan. Following the proposed
change in ownership, the Company's corporate and trade names and identifiers will remain
unchanged. The Transaction will not result in any loss or impairment of service for any
customer, and customers will continue to receive their existing services at the same or better
rates, terms, and conditions currently in effect.
Updates Due to Rule Changes and Passage of Time
TerraCom also files this 5th Revised Compliance Plan to update its policies and practices
to account for changes in the Commission's Lifeline rules, orders, and guidance and due to the
passage of time. This includes, without limitation, full implementation of the Lifeline National
Eligibility Verifier and new requirements for Lifeline enrollment representatives.
Respectfully submitted,
s/ Lance Steinhart
Lance J.M. Steinhart, Esq.
Managing Attorney Lance J.M. Steinhart, P.C. Legal and Regulatory Counsel
Enclosures
BEFORE THE FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554

In the Matter of Telecommunications Carriers Eligible to Receive Universal Service Support

Lifeline and Link Up Reform and Modernization TERRACOM, INC.
WC Docket No. 09-197

WC Docket No. 11-42

TERRACOM, INC. 5TH REVISED COMPLIANCE PLAN
TerraCom, Inc. (“TerraCom” or the “Company”),1 through its undersigned counsel,
hereby respectfully submits and requests expeditious approval of these revisions to its approved
Compliance Plan (this “Revised Compliance Plan”) outlining the measures it will take to comply
with the Federal Communications Commission’s (“Commission” or “FCC”) 2012 Lifeline
Reform Order, 2015 Lifeline Second Report and Order,2 and Third Report and Order.3
1 Changes in the Company’s affiliates following a proposed change in ownership are discussed
in Section III herein; upon consummation, the Company’s names and identifiers will remain the same.
2 See 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 (Feb. 6, 2012) (“2012 Lifeline Reform Order”). See Lifeline and Link Up Reform and Modernization, Telecommunications Carriers Eligible for Universal Service Support, Connect America Fund, WC Docket Nos. 11-42, 09-197, 10-90, Second Further Notice of Proposed Rulemaking, Order on Reconsideration, Second Report and Order, and Memorandum Opinion and Order, FCC 15-71, ¶ 249 (rel. June 22, 2015) (Order on Reconsideration). The Company herein submits the information required by the Compliance Plan Public Notice. See Wireline Competition Bureau Provides Guidance for the Submission of Compliance Plans Pursuant to the Lifeline Reform Order, WC Docket Nos. 09-197, 11-42, Public Notice, DA 12-314 (rel. Feb. 29, 2012) (Compliance Plan Public Notice).
2
TerraCom’s Compliance Plan was originally approved by the Wireline Competition Bureau
(“Bureau”) on May 25, 2012.4 TerraCom filed its Fourth Revised Compliance Plan on October
3, 2016, which the Bureau approved on November 8, 2016,5 identifying a transfer of control and
making revisions to comply with rule changes since the 2012 Lifeline Reform Order. TerraCom
is designated as an eligible telecommunications carrier (“ETC”) to provide Lifeline services to
low-income consumers on a wireless basis in Arizona, Arkansas, Colorado, Indiana, Iowa,
Louisiana, Maryland, Minnesota, Nebraska, Nevada, Oklahoma, Texas, West Virginia and
Wisconsin. As of 2015, TerraCom directly holds 100 percent (100%) of the ownership interest
in YourTel America, Inc. (“YourTel”), a Missouri corporation. YourTel is designated an ETC to
provide Lifeline services on a wireless basis in Illinois, Kansas, Maine, Missouri, Pennsylvania,
Rhode Island, and Washington.
TerraCom files this 5th Revised Compliance Plan to update the information provided
due to the passage of time and to reflect a proposed change in ownership described in Section III
below.
3 See 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. 00-197, WC Docket No. 10-90, Third Report and Order, Further Report and Order, and Order on Reconsideration, FCC 16-38 (rel. Apr. 27, 2016) (“Third Report and Order”).
4 Wireline Competition Bureau Approves the Compliance Plans of American Broadband & Telecommunications, Budget Prepay, Consumer Cellular, Global Connection, TerraCom and Total Call, Public Notice, 27 FCC Rcd 5776 (WCB rel. May 25, 2012); In Re
Telecommunications Carriers Eligible for Universal Service Support, et al., Third Revised Compliance Plan of TerraCom, Inc. (filed June 19, 2012) (providing minor updates requested by Bureau staff).
5 Wireline Competition Bureau Approves the Amended Compliance Plan of TerraCom, Public Notice, DA 16-1264 (rel. Nov. 8, 2016); In Re Telecommunications Carriers Eligible for
Universal Service Support, et al., Fourth Revised Compliance Plan of TerraCom, Inc. (filed Oct. 3, 2016).
3
TerraCom commends the Commission’s commitment to a nationwide communications
system that promotes the safety and welfare of all Americans, including Lifeline customers.
TerraCom complies with 911 requirements as described below and qualifies for blanket
forbearance from the facilities requirement of section 214(e)(1)(A) of the Communications Act
to participate as an ETC in the Lifeline program.6
TerraCom complies fully with all conditions set forth in the 2012 Lifeline Reform Order
and Third Report and Order, as well as with the Commission’s Lifeline rules and policies more
generally.7 This 5th Revised Compliance Plan describes the specific measures that the Company
has implemented to achieve these objectives. Specifically, this 5th Revised Compliance Plan: (1)
describes in detail the measures that TerraCom takes to implement the obligations contained in
the 2012 Lifeline Reform Order and Third Report and Order, including (a) the procedures the
Company follows in enrolling a subscriber in Lifeline and submitting for reimbursement for that
subscriber from the Low Income Fund and (b) materials related to initial and ongoing
certifications and marketing materials; and (2) provides a detailed description of how TerraCom
offers Lifeline services, the geographic areas in which it offers services, and a detailed
description of the Company’s Lifeline service plan offerings.
6 See 2012 Lifeline Reform Order ¶ 368. Although TerraCom qualifies for and seeks to avail itself of the Commission’s grant of forbearance from the facilities requirement of section 214(e)(1)(A) for purposes of the federal Lifeline program, the Company reserves the right to demonstrate to a state public utilities commission that it provides service using its own facilities in a state for purposes of state universal service funding under state program rules and requirements. TerraCom will follow the requirements of the Commission’s Lifeline rules and this Compliance Plan in all states in which it provides Lifeline service and receives reimbursements from the federal Low-Income fund, including in any state where the public utilities commission determines that TerraCom provides service using its own facilities for purposes of a state universal service program.
7 TerraCom will update its associated Lifeline program forms and advertising, whenever necessary, to reflect Commission changes to the applicable Lifeline program rules.
4
ACCESS TO 911 AND E911 SERVICES8
Pursuant to the 2012 Lifeline Reform Order, forbearance is conditioned upon the
Company: (1) providing its Lifeline subscribers with 911 and E911 access, regardless of
activation status and availability of minutes; and (2) providing its wireless Lifeline subscribers
with E911-compliant handsets and replacing, at no additional charge to the subscriber,
noncompliant handsets of wireless Lifeline-eligible subscribers who obtain Lifeline-supported
services.9 The Company will provide its wireless Lifeline customers with access to 911 and
E911 services immediately upon activation of service. The Commission and consumers are
hereby assured that all TerraCom customers will have available access to emergency calling
services at the time that Lifeline voice telephony service is initiated, and that such 911 and E911
access will be available from Company handsets, even if the account associated with the handset
has no minutes remaining.
TerraCom’s existing practices currently provide access to 911 and E911 services for all
customers. TerraCom currently uses T-Mobile as its underlying wireless network
provider/carrier (“Underlying Carrier”). The Underlying Carrier routes 911 calls from the
Company’s customers in the same manner as 911 calls from their own retail customers. To the
extent that TerraCom’s Underlying Carrier is certified in a given PSAP territory, this 911
capability will function the same for the Company. TerraCom also currently enables 911
emergency calling services for all properly activated handsets regardless of whether the account
associated with the handset is active or suspended or has any remaining minutes.
8 See Compliance Plan Public Notice at 3.
9 See 2012 Lifeline Reform Order ¶ 373.
5
E911-Compliant Handsets. TerraCom’s handsets used in connection with the wireless
Lifeline service offering have always been and will continue to be 911 and E911-compliant. As
a result, any existing TerraCom wireless customer that qualifies for and elects Lifeline service
will already have a 911/E911-compliant handset, which will be confirmed at the time of
enrollment in the Lifeline program. To the extent TerraCom offers handsets for use with its
Lifeline service, any new customer that qualifies for and enrolls in TerraCom’s Lifeline voice
telephony service is assured of receiving a 911/E911-compliant handset.
To further obtain the benefits of a modernized Lifeline program, the Commission’s Third
Report and Order also set forth the requirement that Lifeline providers providing both mobile
broadband services and devices to their consumers provide handset devices that are Wi-Fi
enabled.10 The Commission further requires such providers to offer the choice to Lifeline
customers of devices that are equipped with hotspot functionality.11 To the extent TerraCom offers
devices for use with its Lifeline-supported broadband service, it commits to provide devices that
meet the equipment requirements set forth in 47 C.F.R. § 54.408(f).

COMPLIANCE PLAN
I. PROCEDURES TO ENROLL A SUBSCRIBER IN LIFELINE12
A. Policy
TerraCom will comply with the uniform eligibility criteria established in section 54.409
of the Commission’s rules, as amended by and through the Third Report and Order. Therefore,
10 See Third Report and Order at ¶ 366.
11 See id. The Third Report and Order clarifies that the requirement to provide Wi-Fi-enabled handsets does not apply to devices provided prior to the effective date of the rule (December 2, 2016).
12 See Compliance Plan Public Notice at 3.
6
all subscribers will be required to demonstrate eligibility, as determined by the National Lifeline
Eligibility Verifier (“National Verifier”),13 based on: (1) household income at or below one
hundred-thirty five percent (135%) of the Federal Poverty Guidelines for a household of that
size; or (2) the household’s participation in one of the federal assistance programs listed in
sections 54.409 of the Commission’s rules. In addition, through the certification requirements
described below and the use of the National Lifeline Accountability Database (“NLAD”), the
Company confirms that the subscriber is not already receiving a Lifeline service and no one else
in the subscriber’s household is subscribed to a Lifeline service.
B. Eligibility Determination
TerraCom relies on the National Verifier and NLAD (in conjunction with the state
administrator in NLAD Opt-out states such as Texas; hereafter, use of “National Verifier” is
inclusive of any state administrator in NLAD Opt-out states) to determine an applicant's
eligibility for Lifeline service. Eligible customers can enroll in TerraCom’s Lifeline service in-
person with field representatives, TerraCom retail locations, apply electronically on the
Company’s website, or through live agents at the company’s call center. Customers may also
apply directly with the National Verifier online or by mail. Regardless of enrollment method,
TerraCom relies upon the National Verifier for determination of consumer eligibility for
Lifeline.
TerraCom uses a web-based electronic Lifeline enrollment application (“ECP”) for all
Lifeline customer enrollments. Applications are processed using a third party platform which
13 The National Verifier is fully operational, except in NLAD Opt-out states where it is undergoing a modified launch (see Wireline Competition Bureau Announces the Next National Lifeline Eligibility Verifier Launch in Three States, WC Docket No. 11-42, Public Notice, DA 19-1290 (Released Dec. 18, 2019). In these states, TerraCom will rely upon the National Verifier in conjunction with the state administrator (together, the “National Verifier”) for eligibility determination.
7
works in conjunction with the National Verifier and NLAD. The ECP works on a tablet or
computer in tandem with the National Verifier Service Provider portal to provide the required
disclosures and collect applicant information, identity documentation, and proof of eligibility, all
of which is uploaded to the National Verifier for eligibility determination and NLAD duplicate
check. Each prospective customer is checked against the NLAD to ensure that the applicant does
not already receive Lifeline service before the customer is enrolled.14 Upon approval in a state,
TerraCom provides an approved Zip Code list to load into the ECP to ensure all prospective
subscribers reside within TerraCom’s approved service area as designated by the state
commission or the FCC.
When in person, TerraCom requires all prospective customers to provide a copy of their
valid government-issued identification.15 Customers that enroll electronically will use the
National Verifier consumer portal to submit their Lifeline application, eligibility proof and copy
of government-issued identification directly to the National Verifier, or customers may submit
such documentation directly to the National Verifier by mail. TerraCom does not collect,
review, or maintain eligibility documentation, other than in NLAD-opt out states (such as
Texas).
As discussed in further detail in Section I.F. below, all employees or representatives
(“Representatives”) who interact with current or prospective customers are trained regarding all
applicable eligibility and certification requirements, including the one-per-household
requirement, and told to inform potential customers of those requirements.
14 See infra Section I.F. regarding use of the NLAD.
15 Any identification documentation collected, including documentation used in NLAD processes to verify identity are now retained pursuant to the Order on Reconsideration. See Order on Reconsideration ¶ 224.
8
Further, TerraCom will not enroll customers at retail locations where TerraCom does not
have an agency agreement with the retailer. TerraCom will require a retailer to have any
employees involved in the enrollment process go through the standard TerraCom training
process, just as it would for any other Company Representative. By establishing contractual
relationships with all of its Representatives, including future retail outlets, TerraCom meets the
“deal directly” requirement adopted in the TracFone Forbearance Order.16
The Commission determined in the 2012 Lifeline Reform Order that ETCs may permit
representatives to assist with the Lifeline application process because “the Commission has
consistently found that ‘[l]icensees and other Commission regulatees are responsible for the acts
and omissions of their employees and independent contractors.’”17 TerraCom acknowledges it is
responsible for the actions of all of its Representatives, and further commits to comply with the
Commission’s Fifth Report and Order which set forth reforms to strengthen the Lifeline
program’s enrollment, recertification, and reimbursement processes including involvement of
representatives.18
All Representatives are instructed that the company has zero tolerance for waste, fraud or
abuse, and that they should notify the compliance team if they suspect that anyone might be
providing false information or attempting to obtain a duplicate Lifeline benefit. In addition, if
personnel have any questions or concerns regarding eligibility and enrollment, the Company
16 See Petition of TracFone Wireless, Inc. for Forbearance from 47 U.S.C. § 214(e)(1)(A) and 47 C.F.R. § 54.201(i), CC Docket No. 96-45, Order, FCC 05-165, ¶ 19 (2005).
17 2012 Lifeline Reform Order ¶ 110.
18 In the Matter of Bridging the Digital Divide for Low-Income Consumers, Lifeline and Link Up Reform and Modernization, Telecommunications Carriers Eligible for Universal Service Support, WC Docket No. 17-287, WC Docket No. 11-42, WC Docket No. 09-197, Fifth Report
and Order, Memorandum Opinion and Order and Order on Reconsideration, and Further Notice of Proposed Rulemaking, FCC 19-111 (rel. Nov. 14, 2019) (“Fifth Report and Order”).
9
strongly encourages them to bring such questions and concerns to the TerraCom compliance
team so that they can be researched and resolved in accordance with the Commission's Lifeline
rules and regulations. TerraCom provides personnel with refresher training, including to inform
them of changes to Lifeline program rules and regulations, including eligibility requirements.
Personnel will be disciplined, up to and including termination, for failing to comply with Lifeline
rules and regulations. TerraCom also provides comprehensive training to its internal compliance
personnel.
De-Enrollment for Ineligibility. If TerraCom has a reasonable basis to believe that one of
its Lifeline subscribers no longer meets the eligibility criteria, the Company will notify the
subscriber of impending termination in writing, will comply with any state dispute resolution
procedures applicable to Lifeline termination, and will give the subscriber thirty (30) days to
demonstrate continued eligibility.19 A demonstration of eligibility must comply with the annual
certification procedures in 47 C.F.R. §54.410(f). After the expiration of the subscriber’s time to
respond, TerraCom will de-enroll any subscriber who fails to demonstrate eligibility within five
(5) business days. If TerraCom is notified by the Administrator that a subscriber is receiving
duplicative support, TerraCom will de-enroll the subscriber within five (5) business days
pursuant to 47 C.F.R. §54.405(e)(2).
As required by the Commission’s rules, if a customer contacts the Company and states
that he or she is not eligible for Lifeline or wishes to de-enroll for any reason, the Company will
de-enroll the customer within two (2) business days.20 Live customer service and bilingual
operators can currently be reached for Lifeline service support from 8 AM to 11 PM Eastern, 7
days a week, with 24/7 access to assistance via phone and email.
19 See 2012 Lifeline Reform Order ¶ 143; 47 C.F.R. § 54.405(e)(1).
20 See 47 C.F.R. § 54.405(e)(5).
10
C. Subscriber Certifications for Enrollment
TerraCom has implemented certification policies and procedures that enable consumers
to demonstrate their eligibility for Lifeline assistance in compliance with 47 C.F.R. § 54.410(a).
The Company shares the Commission’s concern about abuse of the Lifeline program and is thus
committed to the safeguards stated herein, with the belief that these procedures will prevent the
Company’s customers from engaging in such abuse of the program, inadvertently or
intentionally. Every applicant will be required to complete the universal or National Verifier
Lifeline application forms required by FCC rules (“Universal Forms”), and thus TerraCom
complies with the disclosure and information collection requirements in 47 C.F.R. § 54.410(d).21
The Universal Forms, whether online or paper format, indicate qualifying programs as well as a
breakdown of income eligibility based upon the Federal Poverty Guidelines by household size.
When enrolling with TerraCom’s assistance via the service provider portal, Company personnel
will orally explain the certifications to consumers.22
Disclosures. The Universal Forms include the following disclosures, which the Company
also includes on its website or electronic application platform: (1) Lifeline is a federal benefit
and willfully making false statements to obtain the benefit can result in fines, imprisonment, de-
enrollment or being barred from the program; (2) only one Lifeline service is available per
household; (3) 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; (4) a
household is not permitted to receive Lifeline benefits from multiple providers; (5) violation of
21 See FCC Wireline Competition Bureau Provides Guidance on Universal Forms for the Lifeline Program, WC Docket No. 11-42, Public Notice, DA 18-161 (rel. Feb. 20, 2018). The standard application/certification forms are available on USAC’s website (See USAC, Lifeline Forms, https://www.usac.org/lifeline/additional-requirements/forms/). See Compliance Plan Public Notice at 3.
22 See 2012 Lifeline Reform Order ¶ 123.
11
the one-per-household limitation constitutes a violation of the Commission’s rules and will result
in the applicant’s de-enrollment from the program; and (6) Lifeline is a non-transferable benefit
and the applicant may not transfer his or her benefit to any other person.23 The Universal Forms
further collect the information and certifications required by 47 C.F.R. §§ 54.410(d)(2)-(3), and
require the applicant to consent to transmission of the subscriber’s information to the
Administrator to ensure the proper administration of the Lifeline program.24
D. Annual Re-Certification Procedures
TerraCom relies upon the National Verifier to annually re-certify all subscribers in
compliance with section 54.410(f)(3) of the Commission’s rules (the Company follows
prescribed modified processes in NLAD opt-out states such as Texas). The National Verifier is
responsible to annually confirm a subscriber's current eligibility to receive Lifeline by querying
the appropriate income or eligibility databases, or contacting subscribers as needed to obtain a
signed certification from the subscriber on a form that meets the certification requirements in
section 54.410(d). The National Verifier is responsible for sending notice to the subscriber
explaining that failure to respond to the re-certification request within sixty (60) days will result
in the subscriber’s de-enrollment from the Lifeline program. If TerraCom is notified by the
National Verifier that it is unable to re-certify a subscriber, TerraCom will comply with the de-
enrollment requirements provided for in §54.405(e)(4).25
23 See id. ¶ 121; 47 C.F.R. § 54.410(d)(1).
24 See 47 C.F.R. § 54.404(b)(9). The application/certification form will also describe the information that will be transmitted, that the information is being transmitted to USAC to ensure the proper administration of the Lifeline program and that failure to provide consent will result in the applicant being denied the Lifeline service. See 47 C.F.R. § 54.404(b)(9).
25 TerraCom may send messages to its customers, as permitted by National Verifier recertification processes, to educate them regarding the annual recertification process and requirement, as contemplated by the 2012 Lifeline Reform Order. This type of educational recertification message is consistent with the 2012 Lifeline Reform Order, which states that
12
E. Activation and Non-Usage
To the extent TerraCom offers Lifeline service that does not require the Company to
assess and collect a monthly fee from its subscribers, TerraCom will not consider a subscriber
activated, and will not seek Lifeline reimbursement for that subscriber, until the subscriber
activates the Company’s service by qualified use of the service as defined in 47 C.F.R. §
54.407(c)(2).26
After service activation, TerraCom will not seek reimbursement from the USF for and will
de-enroll any subscriber that has not used TerraCom’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 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(e)(3), TerraCom 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. TerraCom will update the NLAD within
one (1) business day of de-enrolling a subscriber for non-use and will submit a non-usage de-
enrollment report annually to USAC.27

“ETCs and states may also choose to notify subscribers about the re-certification requirements in their Lifeline outreach materials. By taking these actions, ETCs and states will ensure that consumers are aware of the importance of responding to re-certification efforts, and that they are not inadvertently disconnected due to a lack of understanding of program rules.” 2012 Lifeline Reform Order ¶ 145.
26 See 2012 Lifeline Reform Order ¶ 257; 47 C.F.R. § 54.407(c)(1).
27 See 2012 Lifeline Reform Order at ¶ 257; see also 47 C.F.R. §§ 54.404(b)(10) and 54.405(e)(3), respectively.
13
F. Additional Measures to Prevent Waste, Fraud and Abuse
To supplement its verification and certification procedures, and to better ensure that
customers understand the Lifeline service restrictions with respect to duplicates, TerraCom has
implemented measures and procedures to prevent duplicate Lifeline benefits being awarded to
the same household. These measures entail additional emphasis in written disclosures as well as
live due diligence.
Database. The Company complies with the requirements of the NLAD and section
54.404 of the Commission’s rules. Through use of the National Verifier, the Company queries
the NLAD for every enrollment28 to determine whether a prospective subscriber is currently
receiving a Lifeline service from another ETC and whether anyone else living at the prospective
subscriber’s residential address is currently receiving Lifeline service.29
In addition to checking the NLAD, Company personnel emphasize the “one Lifeline
phone per household” restriction in their direct sales contacts with potential customers. Training
materials include a discussion of the limitation to one Lifeline phone per household, and the need
to ensure that the customer is informed of this restriction. All Company personnel interacting
with existing and potential Lifeline customers undergo training regarding eligibility and
certification requirements. Representatives must acknowledge completion of the training and
agree to follow the procedures outlined therein. Further, Representatives assisting with National
Verifier or NLAD transactions will be required to participate in the Representative
28 With the limited exception of states that have opted out of the NLAD. In those states, TerraCom will follow the duplicates detection process required by the state.
29 See 2012 Lifeline Reform Order ¶ 203. The Company transmits to the NLAD the information required for each new Lifeline subscriber. See id., ¶¶ 189-195; 47 C.F.R. § 54.404(b)(6). Further, the Company updates each subscriber’s information in the NLAD within ten (10) business days of any change, except for de-enrollment, which will be transmitted within one business day. See 47 C.F.R. § 54.404(b)(8),(10). These statements may not be applicable in states that have opted out of the NLAD.
14
Accountability Database (RAD) in accordance with FCC rules. All Representatives are given a
toll-free hotline and an email address that can be used for any issues or questions regarding
Lifeline services.
One-Per-Household Certification. TerraCom has implemented the requirements of the
2012 Lifeline Reform Order to ensure that it provides only one Lifeline benefit per household30
through the use of Universal Forms discussed above, National Verifier and NLAD database
checks, and its marketing materials discussed below. Upon receiving an application for the
Company’s Lifeline service, TerraCom will search its own internal records to ensure that it does
not already provide Lifeline-supported service to someone at the same residential address.31 If
an applicant shares an address with one or more existing Lifeline subscribers according to the
NLAD or National Verifier, the prospective subscriber may complete a form certifying
compliance with the one-per-household rule in accordance with 47 C.F.R. § 54.410(g).32
If an applicant is determined to have an existing Lifeline service, TerraCom will explain
that a subscriber cannot have multiple Lifeline Program benefits with the same or different
service providers, and will obtain consent from the subscriber that the subscriber wishes to
transfer their existing Lifeline service to TerraCom (and acknowledges doing so will result in
loss of the Lifeline benefit with their former Lifeline service provider) prior to initiating a benefit
transfer.
30 A “household” is any individual or group of individuals who are living together at the same address as one economic unit. A household may include related and unrelated persons. An “economic unit” consists of all adult individuals contributing to and sharing in the income and expenses of a household. An adult is any person eighteen years or older. If an adult has no or minimal income, and lives with someone who provides financial support to him/her, both people shall be considered part of the same household. Children under the age of eighteen living with their parents or guardians are considered to be part of the same household as their parents or guardians. See 2012 Lifeline Reform Order ¶ 74; section 54.400(h).
31 See 2012 Lifeline Reform Order ¶ 78.
32 The Household Worksheet is available at https://www.usac.org/lifeline/additional-requirements/forms/.
15
Marketing Materials. The Company includes the following information regarding its
Lifeline service on all marketing materials describing the service: (1) it is a Lifeline service, (2)
Lifeline is a government assistance program, (3) the service is non-transferable, (4) only eligible
consumers may enroll in the program, (5) the program is limited to one discount per household;
and (6) the name of the ETC (TerraCom).33 These statements are included in all print, audio,
video and web materials (including social networking media) used to describe or enroll
customers in the Company’s Lifeline service offering.34 This specifically includes the
Company’s website as well as outdoor signage.35 In addition, the application forms state that
consumers who willfully make a false statement in order to obtain the Lifeline benefit can be
punished by fine or imprisonment or can be barred from the program.
G. Company Reimbursements from the Fund
To ensure that TerraCom does not seek reimbursement from the Fund without a
subscriber’s consent, the Company certifies, as part of each reimbursement request, that it is in
compliance with all of the Commission’s Lifeline rules and, to the extent required, has obtained
valid certification and re-certification forms from each of the subscribers for whom it is seeking
reimbursement.36 Further, the Company will comply with the Commission’s requirement to use
a first day of the month uniform snapshot date to request reimbursement from USAC for the
33 See 2012 Lifeline Reform Order ¶ 275; 47 C.F.R. § 54.405(c).
34 See 2012 Lifeline Reform Order ¶ 275; 47 C.F.R. § 54.405(c).
35 See 2012 Lifeline Reform Order ¶ 275; 47 C.F.R. § 54.405(c).
36 See 2012 Lifeline Reform Order ¶ 128; 47 C.F.R. § 54.407(d).
16
provision of Lifeline support.37 In addition, the Company will keep accurate records as directed
by USAC38 and as required by section 54.417 of the Commission’s rules.
H. Annual Company Certifications
The Company submits an annual FCC Form 481 filing to the Commission by July 1st of
each year, providing the Company’s business and affiliate information, terms and conditions of
any voice telephony plans offered to Lifeline subscribers, and all other required information and
certifications.39 The Company also submits an annual Form 555 filing to the Commission
certifying, under penalty of perjury, that the Company: (1) has policies and procedures in place
to ensure that its Lifeline subscribers are eligible to receive Lifeline services; (2) that the
Company is in compliance with all federal Lifeline certification procedures; and (3) that the
Company is in compliance with the minimum service levels set forth in 47 C.F.R. §54.408.40
The Company provides the results of re-certification efforts, performed pursuant to section
54.410(f) of the Commission’s rules, as amended, annually by January 31st, for re-certification
efforts of the previous year.41
37 See 47 C.F.R. § 54.407(a).
38 See 47 C.F.R. § 54.407(e).
39 See 47 C.F.R. § 54.422.
40 See 47 C.F.R. § 54.416(a).
41 See 47 C.F.R. § 54.416(b).
17
II. Description of Lifeline Service Offerings42
TerraCom will offer its Lifeline service in the service areas in the states where it is
designated as an ETC and throughout the coverage area of its respective underlying provider(s),
currently T-Mobile. TerraCom’s Lifeline-supported services will meet or exceed the minimum
service standards set forth in 47 C.F.R. § 54.408.
TerraCom’s current wireless Lifeline offering based upon minimum service standards
effective December 1, 2022 consists of the following plan option(s): Kansas KS Voice Base Plan 1840 MOU: This plan includes 1,840 voice minutes and 1,000 SMS text along with 1 MB data each month, at no cost after application of Lifeline support. Unused minutes and data do not roll over.
KS Broadband Base Plan 920 MOU and 4.5GB: This plan includes 920 voice minutes, 1,000 SMS text, and 4.5GB of data each month, at no cost after application of Lifeline support. Unused minutes and data do not roll over. This plan is only available to subscribers with data capable handsets.
Nebraska NE Voice Base Plan 1350 MOU: This plan includes 1,350 voice minutes and 1,000 SMS text along with 1 MB data each month, at no cost after application of Lifeline support. Unused
minutes and data do not roll over. NE Broadband Base Plan 690 MOU and 4.5GB: This plan includes 690 voice minutes, 1,000 SMS text, and 4.5GB of data each month, at no cost after application of Lifeline support. Unused minutes and data do not roll over. This plan is only available to subscribers with data capable
handsets. All Other States Tribal Broadband Base Plan 2,000 MOU and 4.5GB: This plan includes 2,000 voice minutes of
local calling and 1,000 SMS text messaging plus 4.5GB of data each month, at no cost after application of Lifeline support. Unused minutes and data do not roll over. This plan is only available to residents of federally recognized tribal lands.
42 See Compliance Plan Public Notice at 3.
18
Non-Tribal Voice Base Plan 1000 MOU: This plan includes 1000 voice minutes and 1,000 SMS text along with 1 MB data each month, at no cost after application of Lifeline support. Unused
minutes and data do not roll over. Non-Tribal Broadband Base Plan 500 MOU and 4.5GB: This plan includes 1,000 voice minutes, 1,000 SMS text, and 4.5GB of data each month, at no cost after application of Lifeline support. Unused minutes and data do not roll over. This plan is only available to subscribers with
data capable handsets.
In addition to allotments of voice, text and broadband services, TerraCom’s current
wireless Lifeline offering includes a free SIM card and access to custom calling features at no
charge, including Caller ID, Call Waiting, and Voicemail. All wireless Lifeline plans include
domestic long-distance at no extra per minute charge. Calls to 911 emergency services are
always free, regardless of service activation or availability of minutes. Lifeline customers can
purchase additional minutes or data through customer service, the Company’s website, Point of
Sale locations, and through IVR. Additional information regarding the Company’s wireless
Lifeline plans, rates and services can be found on its website
(https://www.terracomwireless.com/).
III. Demonstration of Financial and Technical Capabilities and Certifications Required for ETC Designation43
Financial and Technical Capabilities. Section 54.202(a)(4)44 requires carriers petitioning
for ETC designation to demonstrate financial and technical capability to comply with the
Commission’s Lifeline service requirements,45 and the Compliance Plan Public Notice requires
that carriers' compliance plan include this demonstration. Among the factors the Commission
43 See Compliance Plan Public Notice at 3.
44 See 47 C.F.R. § 54.202(a)(4).
45 See 2012 Lifeline Reform Order ¶¶ 387-388 (revising Commission rule 54.202(a)(4)).
19
will consider are the following: a carrier’s prior offering of service to non-Lifeline subscribers,
the length of time the carrier has been in business, whether the carrier relies exclusively on
Lifeline reimbursement to operate; whether the carrier receives revenues from other sources and
whether the carrier has been the subject of an enforcement action or ETC revocation proceeding
in any state.
Pursuant to the terms of an Agreement by and among TerraCom, Inc., an Oklahoma
corporation; Global Reconnect, LLC, a Delaware limited liability company (hereafter the
“Seller”); and Maxsip Telecom Corporation, a New York corporation (hereinafter the “Buyer” or
“Maxsip”), Buyer will purchase one hundred percent (100%) of the issued and outstanding
common stock of TerraCom including its wholly owned subsidiary, YourTel America, Inc. (the
“Transaction”). In step one of the Transaction, MaxSip is acquiring forty nine percent (49%) of
the issued and outstanding common stock of TerraCom; step two of the Transaction is the
purchase of the remaining fifty-one percent (51%) of the stock of TerraCom upon obtaining any
required regulatory approvals for the Transaction, including this 5th Revised Compliance Plan.
Maxsip was incorporated in 2008 and then commenced offering competitive local
exchange and resold long distance service. On August 28, 2008, the FCC International Bureau
granted Maxsip Section 214 international authority to provide facilities-based service in
accordance with section 63.18(e)(1) of the Commission’s rules, and also to provide resale service
in accordance with section 63.18(e)(2) of the Commission’s rules. Maxsip’s principal offices are
located at 708 Central Avenue, Woodmere, New York 11598. Maxsip has established
considerable financial resources that will be available, as needed, to support TerraCom in its
operations and continuing growth. Maxsip is wholly owned by Israel Max, a United States
citizen and resident of the State of New York. Maxsip provides competitive local exchange
20
services in New Jersey and New York, as well as landline Lifeline services in New York. Maxsip
is authorized to provide commercial mobile radio services throughout the United States and Puerto,
is authorized to provide VoIP services throughout the United States except Arizona in which it is
pending approval, and has been authorized to provide services by the FCC and USAC under the
Affordable Connectivity Program (“ACP”) (and previously the Emergency Broadband Benefit
“EBB” program) in said jurisdictions. Maxsip does not have foreign ownership and, like
TerraCom, is not a foreign carrier or affiliated with foreign carriers in any market.
Maxsip brings to TerraCom not only financial stability, but also managerial and technical
resources available to Maxsip which has been providing telecommunications service since 2008
including wireline Lifeline service, and wireless service under the EBB and ACP. Maxsip
receives revenue from a number of sources which are independent from the revenue it receives in
the form of Lifeline reimbursements, such as non-Lifeline wireless income from the sale of
prepaid wireless services to non-Lifeline consumers as well as the sale of replenishment airtime
minutes and data to Lifeline consumers, the sale of various other ancillary services, and CLEC
and VoIP services. Maxsip will similarly move forward with TerraCom operations such that
TerraCom provides non-Lifeline services wholly separate from and/or complementary to its
Lifeline services. TerraCom has provided non-Lifeline telecommunications services since 2004
and will continue to do so after the closing of the Transaction. Consequently, TerraCom never
has and will not be relying exclusively on Lifeline reimbursement for its operating revenues.
Maxsip has not been subject to enforcement sanctions related to the Low Income Fund or ETC
revocation proceedings in any state.46
46 Neither has TerraCom been subject to any ETC revocation proceedings. TerraCom has resolved all Commission enforcement proceedings. In Re TerraCom, Inc., and YourTel America,
21
With respect to technical expertise, both TerraCom and Maxsip have considerable
experience complying with the requirements of the federal Lifeline program as well as the ACP.
In addition, key members of TerraCom’s current operations team will remain with the Company
post-Transaction, continuing to work on day-to-day operations. As a result, the Transaction will
bring together TerraCom’s current valued personnel, and the full strength of Maxsip’s proven
telecommunications capabilities and business expertise, particularly with respect to compliance
and marketing in the low-income consumer sector. As a result, Maxsip’s ownership will enable
TerraCom to achieve measurable growth at the same time as it develops improved operating
efficiencies, both necessary components for the Company to thrive. In addition, the Transaction
will not result in any loss or impairment of service for any customer, and customers will continue
to receive their existing services at the same or better rates, terms, and conditions currently in
effect.
Service Requirements Applicable to the Company’s Support. The Compliance Plan
Public Notice requires carriers to include “certifications required under newly amended section
54.202 of the Commission’s rules.”47 TerraCom certifies that it will comply with the service
requirements applicable to the support the Company receives.48 TerraCom’s Lifeline supported
voice services will meet the minimum service standards set forth in 47 C.F.R. § 54.408.
TerraCom’s Lifeline supported broadband services will meet the minimum service standards set
forth in 47 C.F.R. § 54.408 for mobile broadband internet access services, including for service
speed and data usage allowance, as such standards are updated on an annual basis. To the extent

Inc. File Nos.: EB-TCD-13- 00009175, EB-IHD-13-00010677, Order, 30 FCC Rcd 7,075 (EB rel. July 9, 2015).
47 Compliance Plan Public Notice at 3.
48 See 47 C.F.R. § 54.202(a)(1).
22
TerraCom 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 TerraCom will not
impose an additional or separate tethering charge for mobile data usage below the minimum
standard.
The Company provides all of the telecommunications services supported by the Lifeline
program and will make the services available to all qualified consumers throughout the states in
which it is designated as an ETC. The Company’s services include broadband Internet access
service (“BIAS”) as well as voice telephony services that provide voice grade access to the public
switched network or its functional equivalent. Further, the Company’s wireless service offerings
included in Section II supra provide its customers with a set number of minutes of use at no
additional charge to the customer beyond the monthly plan rate, and can be used for local and
domestic toll service.
The Company also will provide access to emergency services provided by local
government or public safety officials, including 911 and E911 where available, and will comply
with any Commission requirements regarding E911-compliant handsets. As discussed above,
the Company will comply with the Commission’s applicable forbearance grant conditions
relating to the provision of 911 and E911 services and handsets (when applicable).
Finally, TerraCom will not provide toll limitation service (“TLS”), which allows low-
income consumers to avoid unexpected toll charges. However, since TerraCom is a prepaid
service provider, customers cannot be disconnected for failure to pay toll charges and they are
unable to exceed their preset minutes without purchasing more in advance. The Company, like
most wireless carriers, does not differentiate domestic long-distance toll usage from local usage
23
and all usage is paid for in advance. Pursuant to the 2012 Lifeline Reform Order, subscribers to
such services are not considered to have voluntarily elected to receive TLS.49
IV. Conclusion
TerraCom submits that its 5th Revised Compliance Plan fully satisfies the conditions set
forth in the Commission’s 2012 Lifeline Reform Order, the Compliance Plan Public Notice and
the Lifeline rules. Timely approval of this 5th Revised Compliance Plan is essential to allow
TerraCom to consummate the ownership change as described herein and demonstrably
strengthen the Company’s operating capabilities to the direct benefit of its Lifeline customers.
Accordingly, the Company respectfully requests that the Commission expeditiously approve the
revisions to its Compliance Plan.
Respectfully submitted, /s/ Lance J.M. Steinhart
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]

Legal and Regulatory Counsel March 1, 2023
49 See 2012 Lifeline Reform Order ¶ 230.

EXHIBIT 3
Coverage Area
AT&T

T-Mobile

EXHIBIT 4
Sample Advertisement
Office: [phone] Call Center: [phone] Fax: [phone]
PO Box 13006
Oklahoma City, OK 73113
Friday, May 12, 2023
Eligible Telecommunications Carrier (“ETC”) Only Information
Advertising
The attached national advertising post card is sent annually to various service agencies
within the 22 states TerraCom serves.
Facebook Marketing
Marketing is done by outreach via Facebook boost ads on a regular basis.
https://www.facebook.com/TerracomUSA
Mailers:
We will also mail the attached brochure upon request.

You may be eligible for discounted wireless phone service through the LIFELINE
assistance program if you, or a member of your household, are currently receiving low
income benefits under certain government assisted programs such as:
●SNAP ●SSI ●Medicaid
or other government programs
Lifeline is a government benefit program limited to
one benefit per household. Only eligible
consumers may enroll in Lifeline. Lifeline service is
non-transferable and limited to one benefit per
household. Qualifications for the Lifeline program
vary by state. Proper documentation of income or
program participation is required for enrollment.
Consumers who willfully make false statements in
order to obtain the benefit may be punished by
fine or imprisonment, or barred from the program.
Call 1-888-716-8880 or
visit
www.terracomwireless.com

P. O. Box 13006
Oklahoma City, OK 73113

PRESORTED
POSTAGE
USPS
PERMIT NO. XX
Social Services Center
123 Drive
Suite 456
Somewhere, US xxxxx-xxxx
Please post this on your
outreach board so that
community members may
benefit from Lifeline provided
service.
For more information call
888-716-8880 or e-mail
[e-mail]

Facebook post
How to enroll in the Lifeline Program
All subscribers must first qualify through the
National Verifier. The Lifeline National
Eligibility Verifier (National Verifier) is a
centralized system that determines whether
subscribers are eligible for Lifeline. USAC
manages the National Verifier and its customer
service department, the Lifeline Support Center.
Qualify for Lifeline here:
https://nationalverifier.servicenowservices.
com/lifeline
After approval from the National Verifier
you can enroll with TerraCom here:
www.terracomwireless.com
TerraCom will ship you your free phone
after approval. Your phone will arrive
between 5 – 7 business days.
Who We Are
About Us
Throughout its long history TerraCom has been
the Lifeline company cut from a different cloth.
We have a wide variety of subscribers – both
lifeline and non-lifeline, both wireless and
wireline. We have learned in our 25 years that
customers and co-workers come first.
TerraCom was founded to help low-income
consumers get the communications services they
deserve. TerraCom prides itself on helping
people save money and providing top notch
customer service. TerraCom uses its expertise to
run an efficient operation with the customer in
mind, so we can always provide low cost, high
quality service.
We know you, our customer, and we
work hard to reach out and bring you
the benefits of Lifeline service, so you
are not left behind.
Contact Us
Phone: [phone]
Email: [e-mail]
TerraCom
P.O. Box 13006
Oklahoma City, OK 73113
TerraCom
Visit
www.terracomwireless.com/terms
for complete terms and conditions.
Any free cell phone offering is that of
TerraCom and not the Lifeline program.
This is a Lifeline service provided by
TerraCom Wireless. Lifeline is a
government benefit program. Only
eligible consumers may enroll in
Lifeline. Lifeline service is non-
transferable and limited to one benefit
per household. Qualifications for the
Lifeline program vary by state. Proper
documentation of income or program
participation is required for enrollment.
Consumers who willfully make false
statements in order to obtain the benefit
may be punished by fine or
imprisonment or barred from the
program. Smart phone model, activation
fee and phone pricing may vary by state.
Additional terms and other restrictions
apply. MMS not available on all devices.
Our Products and Services
TerraCom has a variety of plan offerings. The
following are the most commonly used but you
can find other plan offerings on our website at
www.terracomwireles.com/plans.php
“TerraCom Customer Service
is always a joy to work with.
They provide fast and friendly
service.”
Non-Lifeline Plans
If you do not qualify for the Lifeline program, we
have non-lifeline voice or data plans available for
$39.99 per month and purchase of mobile device
or tablet.
Unlimited Talk and Text
Each month you will receive unlimited voice
and text message with purchase of mobile
device.
Unlimited Data
Each month you will receive unlimited data with
purchase of tablet.
.
TerraCom provides Lifeline home phone service
in OK and wireless service in AR, AZ, CO, IA, IL,
IN, KS, LA, MD, ME, MN, MO, NE, NV, OK, PA,
RI, TX, WA, WI and WV.
If you reside on federally recognized tribal lands
in Oklahoma and Washington, you qualify for the
following:
2000 Minute of Use
4.5 GB of Data
Unlimited Text Messaging
Kansas customers qualify for the following:
920 Minutes of Use
4.5 GB of Data
Unlimited Text Messaging
Nebraska customers qualify for the following:
690 Minutes of Use
4.5 GB of Data
Unlimited Text Messaging
All other states and non-tribal areas of Oklahoma
and Washington qualify for the following:
500 Minutes of Use
4.5 GB of Data
Unlimited Text Messaging

EXHIBIT 5
Key Management Bios

Israel Max
708 Central Ave Woodmere NY 11598
[phone] · [e-mail]

Dynamic and visionary Owner/CEO of Maxsip Telecom with an impressive 35-year tenure in the
industry. A highly experienced professional, adept at leveraging expertise in telecommunications
systems, sales, and installation to drive business success. Committed to delivering unparalleled
service and cultivating a customer-centric approach within the organization. A strategic leader with a
proven track record of achieving exceptional results, maximizing profitability, and fostering long­
term business relationships. Dedicated to continuously innovating and adapting to the evolving
landscape of the telecommunications industry, while consistently contributing to the growth and
success of the organization.

PROFESSIONAL EXPERIENCE Maxsip Telecom: CEO (Valley Stream, NY) 2008-Present
• Provide visionary leadership and strategic direction with a focus on mobile, broadband, and digital services.
• Develop and implement innovative business strategies to drive revenue growth and market expansion.
• Forge strategic partnerships and alliances to enhance the company's product and service offerings.
• Successfully participated in government programs, such as the Emergency Broadband Benefit (EBB) Program, by offering eligible consumers a discount of up to $50 per month for broadband services, ensuring affordability and accessibility.
• Provided enhanced support to consumers residing on qualifying Tribal lands through the EBB
program, offering up to $75 per month toward broadband services, promoting digital inclusion for
underserved communities.
• Facilitated the acquisition of essential devices through the EBB program, offering a one-time discount of up to $100 for laptops, desktop computers, or tablets purchased from approved providers, improving access to connected devices.
• Effectively transitioned from the temporary Emergency Broadband Benefit to the long-term Affordable Connectivity Program (ACP) on December 31, 2021, ensuring continuous support and affordability for eligible households.
• Demonstrated compliance with regulations and government directives by adopting final rules for
the ACP on January 14, 2022, in accordance with the Infrastructure Investment and Jobs Act.
• Successfully conducted outreach activities as part of the Affordable Connectivity Outreach Grant Program and the Your Home, Your Internet Pilot Program, increasing awareness of the ACP
among recipients of federal housing assistance.
• Participated in the Affordable Connectivity Pilot Programs, including the Affordable Connectivity Program Navigator Pilot Program, further increase awareness and facilitate enrollment in the ACP, ensuring maximum program utilization.
• Proven ability to navigate regulatory frameworks, adapt to evolving program requirements, and
effectively communicate program benefits to target audiences, resulting in increased
participation and positive community impact.
Maxsip: Owner/CEO (Woodmere,NY)
• Specialize in delivering custom-designed, full-featured, easily managed, and endlessly scalable Internet-based communications solutions.
• Provide a complete range of VOiP (Voice Over IP) systems to extend existing infrastructure and integrate VOiP with current PBX (Private Branch Exchange).
• Certified CLEC (Competitive Local Exchange Carrier) offering carrier-grade voice service.
• Skilled technicians handle internal wiring and ensure a smooth transition without interruption to business flow.
• Build IP-based communications solutions on top of our family of VOiP solutions.
• Future-proof communications infrastructure to address immediate needs and allow seamless and
cost-effective scalability as the business grows and needs change. Expert Communications: Owner/CEO (Brooklyn, NY) 1985-1999
• Accomplished CEO with a track record of driving growth and profitability in the PBX and low voltage wiring industry.
• Strategic leader who has successfully developed and executed business plans to achieve organizational objectives.
• Demonstrated expertise in overseeing the design, implementation, and maintenance of PBX systems and low voltage wiring solutions.
• Proven ability to build and manage high-performing teams, fostering a culture of collaboration, innovation, and customer focus.
• Strong business acumen with a deep understanding of market dynamics, customer needs, and industry trends in the telecommunications and low voltage sectors. Quality Security and Communications: Owner/CEO (Brooklyn, NY) 1985-1997
• Owner and Founder of a successful alarm systems company catering to both commercial and residential markets.
• Built and led a high-performing team, fostering a culture of innovation, excellence, and customer
satisfaction.
• Established strategic partnerships with suppliers and manufacturers, ensuring the availability of cutting-edge technologies and products.
• Oversaw the design and installation of alarm systems, ensuring compliance with industry standards
and meeting customer requirements.
• Successfully managed operations, including inventory management, procurement, and logistics, to optimize efficiency and reduce costs.
• Maintained strong relationships with clients, providing exceptional customer service and ensuring
their security needs were met.
• Stayed up-to-date with industry trends and advancements, continuously enhancing the company's offerings and staying ahead of the competition.
• Achieved consistent revenue growth and profitability, contributing to the long-term sustainability
and success of the company.
• Received accolades and positive feedback from clients for delivering reliable and top-quality alarm systems and services.

SKILLS
PBX, Telecom, Low Voltage Wiring, Data, Networking, Microsoft Office Suite EDUCATION
Yeshiva Torah Vodaath, Brooklyn, NY 1991
ADDITIONAL PERSONAL INFORMATION
• EMT (Emergency Medical Technician) - 1989-Present, Hatzalah ember
• Fire Commissioner - Woodmere Fire District
• Class A Firefighter - Woodmere Fire Department
Noah Isaacs
11-04 Upton Place Fair Lawn, NJ 07410
[phone] · [e-mail]

Experienced Senior Financial Executive with a proven track record of optimizing financial operations for
multibillion-dollar, multinational corporations. Skilled in driving complex strategic initiatives, M&A
activities, and financial operations, while motivating large-scale teams to achieve organizational growth and
stability. Integrates scalable strategies to align global financial operations with corporate vision, partners
with cross-functional teams to drive enterprise-wide financial technology integrations and mitigates risk
through scalable solutions. Areas of expertise include strategic planning and execution, financial operations
management, mergers and acquisitions, financial planning and analysis, risk mitigation, SOX and regulatory
compliance, process design and improvement, and budgeting and forecasting.

PROFESSIONAL EXPERIENCE
Maxsip Telecom: CFO (Valley Stream, NY) Dec. 2022-Present
• Successfully implement streamlined Accounts Payable and Accounts Receivable processes,
reducing errors and increasing efficiency in financial operations.
• Lead the valuation and purchase of two companies, with a total value of $14 million, utilizing
sound financial analysis to achieve significant cost savings.
• Oversee all financial operations, including the preparation of financial statements and ensuring
compliance with regulatory requirements, resulting in accurate reporting and financial stability.
• Continuously evaluate all marketing campaigns, identifying areas for improvement and optimizing
ROI for the company.
• Manage and mentor a team of over 10 finance professionals, driving professional growth and
fostering a collaborative and supportive work environment.
• Develop and implement financial strategies that support business objectives, resulting in
sustainable growth and improved profitability.
• Maintain strong relationships with key stakeholders, including investors and lenders, ensuring
ongoing financial support and stability for the company.
• Proactively identify and mitigate financial risks, utilizing sound financial analysis and forecasting
to inform strategic decision-making.

Astral Energy LLC: CIO (Montvale, NJ) Feb. 2018-Nov. 2022
• Directed and managed a team of 4 professionals responsible for overseeing the financial operations
of the organization.
• Provided accurate financial statement reporting and supervised the annual third-party audit to
ensure compliance with regulatory requirements.
• Led due diligence and assessed the value of prospective M&A targets ranging from 1mm-80mm
TEV.
• Successfully acquired a company for $800k in 2019 and increased its value by 80%.
• Formulated and implemented the general hedging strategy for all commodities to mitigate risks
and optimize profitability.
• Prepared compelling pitch decks and financial materials for prospective equity investors,
effectively communicating the organization's financial performance and growth potential.
• Strategized and executed pricing policies for all prospective customers, identifying fixed prices
and savings opportunities to maximize revenue.
• Conducted thorough underwriting analysis of new commodity products for all markets, ensuring
risk management and profitability.
• Negotiated a preferred service agreement with financial backers Mitsubishi Industries, optimizing
financing and partnership opportunities.

Astral Energy LLC: Financial Analyst (Englewood Cliffs, NJ) Sep. 2014-Jan. 2018
• Generated monthly reports on customer and market margins to identify areas for improvement and
optimize profitability.
• Collaborated with in-house development team to optimize processes and pricing models, resulting
in increased efficiency and revenue growth.
• Designed and implemented customized rate classes and customer groups to better meet the needs
of diverse customer segments, resulting in improved satisfaction and retention rates.
• Conducted extensive data analysis on sales production, customer retention, and overall market
trends, providing valuable insights to guide strategic decision-making and improve business
performance.

ENTREPRENEURIAL EXPERIENCE
ZivugTech: National Director (Lakewood, NJ) Nov 2020-Present
• Consult and steer startup company by employing advanced entrepreneurial mindset to achieve
business objectives.
• Formulate pitch decks to successfully secure $300K in funding and benefits while onboarding new
partners across the industry.
• Promote community engagement through software technologies while onboarding new users
during product demonstrations.
• Improve functionality and contribute towards software development process in coordination with
software engineers.
• Conceptualize new features with in-house development team while overseeing marketing efforts to
acquire new users.
• Raise funds for ongoing product development while regularly updating products to grow user base
and outreach.
• Devise, direct, and implement strategic plans to promote and achieve the organization’s mission,
vision, and long-term goals.
• Forge and maintain mutually beneficial relationships with shareholders, partners, and external
authorities.
•
TECHINAL SKILLS
Microsoft Office Suite: Word, PowerPoint, Advance Microsoft Excel (Spreadsheets, Macros, VBA)

EDUCATION
Yeshiva University, Sy Syms School of Business, New York, NY May 2016
Bachelor of Science in Accounting, Graduated Magna Cum Laude GPA: 3.76

ADDITIONAL COURSES/CERTIFICATIONS
• M&A Modeling
• Real Estate Underwriting
• Life Insurance Broker
• Chaveirim of Bergen County
Stanley J. McCright - Bio Stan McCright is the founder of McCright & Associates, LLC (a company specializing in providing HUD-mandated inspections for public housing residential units), having been involved in different aspects of public housing since 1974. In that time, he developed a sound knowledge and understanding of the changing needs of the public and leased housing industry. Particularly in today’s environment, communications and information access needs are increasingly significant to the underserved and low-income populations not only in public housing but also in most other areas of the country. Stan founded McCright & Associates in 1988 and since then has focused that firm on providing services in the areas of HQS inspections, physical inventory, fixed asset tracking and reporting programs, organizational structuring, market comparability studies and rent reasonableness surveys. Stan has performed work for various housing authorities throughout the United States ranging in size from 50 to 40,000 conventional units. He has incorporated resident initiative programs into the performance of his contracts by screening, hiring, training and supervising residents to work on various projects. While serving as the Chief Financial Officer for White Consolidated Industries, Inc. (White-Westinghouse, Frigidaire), a Fortune 500 corporation, Stan directed the financial turnaround of the range division. Under Stan’s leadership, within one year, the division went from a $4 million loss to a $1.5 million profit. Stan accomplished this turnaround in a union environment during a period when sales increased only by 10%. Stan achieved these improvements in profitability through internal reorganization and the implementation of cost control measures. Later Stan directed the company into government contracting with HUD and GSA through the consolidated supply contracts that resulted in annual sales in excess of $15 million. Within three years, the range division became the number one profit entity for the corporation. While Director of Finance at M&M Mars Corporation, Stan was selected to develop and lead “CITI” (“Constant Improvement Through Involvement) a pilot program that involved all levels of employees of the corporation from top executives to janitorial staff. Stan facilitated this group’s development of policies and procedures through a participatory management program to enhance the productivity of the corporation. Due to the efforts of this initiative, the corporation netted an increase of $500 million in sales with only a 25% increase in labor and operating expenses. Stan’s expertise in UPCS and HQS are recognized nationally. He was a presenter at the National Association of Housing and Redevelopment Officials’ (“NAHRO”) 2002 National Conference in Seattle, Washington. He has since then presented information on HQS and/or UPCS standards numerous times at several Regional NAHRO conferences, State NAHRO Meetings, State Association meetings, and at various Housing Authorities. Stan is training REAC inspections standards throughout the industry. In early 2017, Stan acquired TerraCom, Inc., an ETC providing, at that time, primarily telecommunications services to qualified individuals under the FCC’s Lifeline program. Stan’s experience with serving low-income residents of public housing was directly applicable to providing Lifeline services to its intended markets. Since 2017, Stan has guided TerraCom through the many program changes made by the FCC in its attempts to better serve qualified program participants. TerraCom is approved for providing Lifeline services in 21 states. In April 2021 TerraCom was approved to provide services under the FCC’s Affordable Connectivity Program in those same 21 states. Stan is a graduate of the University of South Dakota, holding a Bachelor of Science Degree in Business Administration and Accounting. He is a REAC 2.3 Certified Inspector. Stan’s HUD REAC Certification Identification Number is M98549.

EXHIBIT 6
Proposed Lifeline Offering TERRACOM WIRELESS LIFELINE OFFERING
1000 Minutes & 4.5 GB Data 1000 anytime minutes per month 1000 texts
4.5 GB data per month
Minutes & data do not rollover Net cost to Lifeline customer: $0

Tribal Plan Unlimited talk
Unlimited text
10 GB data per month
Data does not rollover Net cost to Lifeline customer: $0

ADDITIONAL AIRTIME
Available for purchase at https://terracomwireless.com

All packages include:
• Free calls to TERRACOM Customer Service
• Free calls to 911 emergency services
• Free access to Voicemail, Caller-ID, and Call Waiting features
• Voice minutes may be used for Domestic Long Distance at no extra cost

EXHIBIT 7
PUBLIC DISCLOSURE DOCUMENT Financial Statements
CONFIDENTIAL IN ENTIRETY

EXHIBIT 7
TRADE SECRET Financial Statements

EXHIBIT 8
CERTIFICATE OF SERVICE I HEREBY CERTIFY that I caused a true and correct copy of TERRACOM INC. d/b/a
Maxsip Tel’s Application for Designation as an Eligible Telecommunications Carrier for the
Limited Purpose of Offering Lifeline Service to Qualified Households to be mailed, by USPS
Tracking, to the Tribes listed below:

Coeur d’ Alene Tribe 850 A Street Plummer, ID 83851
Kootenai Tribe of Idaho 142 County Road 38A, Bonners Ferry, ID 83805
Nez Perce Tribe of Idaho 120 Bever Grade Rd, Lapwai, ID 83540 Shoshone-BannockTribe of Idaho
Mission Rd, Fort Hall, ID 83203 DATED THIS _13th_ day of July 2023.

____________________________
Lance J.M. Steinhart, Esq.
Lance J.M. Steinhart, P.C. Attorneys at Law 1725 Windward Concourse, Ste. 150 Alpharetta, GA 30005 [phone] (Phone)
[phone] (Facsimile) [e-mail] (Email) Attorneys for TERRACOM INC. d/b/a
Maxsip Tel