20151020Applicationcontinued.pdf

BEFORE TTTE WASHINGTON
UTILITIES AI\D TRANSPORTATION COMIVtrSSION
ln the Matter of the Petition of
i-wireless, LLC
. Petitioner,
Fer an Exemption from WAC 480-
123-030(lXd), (f), and (g), and
Designation as an Eligible
Telecommunications Carrier
DOCKET UT-IOI640
ORDER 02
ORDER RENEWING ELIGTBLE
TELECOMMUNICATIONS CARRIER
DESTGNATION AND EXEMPTION
FROM RULE WITH AMENDED
CONDITIONS
BACKGROT]ND
On August 20,2013, i-wireless, LLC (i-wireless or Company) filed an application with
the Washington Utilities and Transportation Commission (Commission) to renew its
designation as an Eligible Telecommunications Carrier (ETC) under the Communications
Act of 1934' (Communications Act) and WAC 480-123.
The Commission originally designated i-wireless as an ETC on September 13,2012,
allowing the Company to provide qualified Washington consumers with Lifeline support,
which is part of the federal Universal Service Fund (USF) supported services and
subsidizes qualified low-income household monthly charges for basic telephone services
and non-recurring connection charges.2 In that order, the Commission granted the
Company exemptions from the provisions of WAC 480-123-030 (lxd), (0, and (g),
which require the company to file a substantive investment plan, digital map of wireless
facilities and coverage, and certification regarding back-up power requirements. The
Commission also imposed 2l conditions on i-wireless's ETC designation, including a
requirement that the Company seek renewal of its ETC status within one year.
In support of its application, i-wireless states that it satisfied the requirements of WAC
480-123-030 in its original petition and that, except for provisions for which a waiver
was granted, its operations remain otherwise unchanged. The Company further states
that it has complied with all 2l conditions the Commission imposed on the Company in
Order 01 and provides a summary explanation of its compliance for each individual
condition. Finally, i-wireless affirms that the circumstances underlying the
' +7 u.s.c. g 2la (e)(2) (2012).
'Order 01, Order Granting Exemption From Provisions of WAC 480-123-030(lxd), (f), and (g),
and Designation as an Eligible Telecommunications Carrier (September 13,2012).
DOCKET UT-101640
ORDER02
PAGE 2
Commission's grant of exemption from WAC 480-123-030(l)(d), (f), and (g) are
unchanged.
i-wireless states that its service continues to advance the purposes of universal service set
forth in 47 U.S.C. $ 254. i-wireless states that its designation as an ETC remains in the
public interest because ETC service benefits low-income household in Washington.3
Commission Staff(Staff) agrees that i-wireless complied with the terms and conditions of
Order 01 and also complied with the new rules implemented by the FCC's (Federal
Communication Commission) 2012 Lifeline and Link Up Reform Order,a primarily
strengthening eligibility check and one-Lifeline-per-household policy, enforcing
deactivation upon 60 consecutive days of non-usage, certifuing all its Lifeline customers
on an annual basis and providing results of annual recertification to the FCC and relevant
state commissions.
Staffsupports i-wireless's application with certain new or revised conditions that better
reflect rule changes at the federal level and the deletion of some previously imposed
conditions. Staff believes that monitoring and rule enforcement in the today's Lifeline
market obviates the need for the commission's one-year interim condition. The
Company agrees to these revised conditions on its ETC status, as enumerated in
Appendix A.
Staffnotes that the FCC issued a Notice of Apparent Liability For Forfeiture (NAL) to i-
wireless, LLC on November I,2013.5 The NAL alleges that between October 2012 and
April20l3, i-wireless was reimbursed for 1,684 alleged intra-company duplicate
customer enrollments totaling $24,358 in overpayments from the Universal Service
Administrative Company, none of which involved the Company's activities in the state of
Washington. The FCC proposed a forfeiture of over $8.8 million dollars. On January 10,
2014, i-wireless filed a response challenging the NAL findings and the matter is now
pending at the FCC.6 Staffsuggests that because there is no reasonable estimate as to
3 i-wireless Application to Renew at 7.
a In the Matter of Lifeline and Link Up Reform and Modernization, Lifeline and Link Up,
Federal-State Joint Board on Universal Service, Advancing Broodband Availability Through
Digital Literacy Training, WC Docket No. I l-42, WC Docket No. 03-109, CC Docket No. 96-
45, WC Docket No. 12-23, Report and Order and Further Notice of Proposed Rulemaking, FCC
l2-l l-.(rel. Feb 6,2012) ("Lifeline and Link Up Reform Order").
5In the Matter of i-wireless, ZIC., Notice of Apparent Liability for Forfeiture, File No.EB-IHD-
l3-00010656, FCC l3-148 (rel. November 1,2013).
6 i-wireless' response to the FCC states that even if every alleged duplicate turned out to be an
actual duplicate, i-wireless still would have been 99.74% effective in screening for duplicates. i-
wireless, LLC's Response to the Notice of Apparent Liabilityfor Forfeiture, Coruected Public
Vers ion, File No.EB-IHD- I 3 -000 I 0656 (January 10, 201 4), p. 25.
t0
il
DOCKET UT-101640
ORDER02
PAGE 3
when the FCC will resolve the NAL, the commission should not wait on the result of the
NAL to decide on i-wireless' ETC renewal. This issue does not change staff s evaluation
of i-wireless' ETC Renewal petition.
DISCUSSION
Common carriers receiving designation as ETCs under 47 U.S.C. $ 214 are eligible to
receive subsidies from the federal Universal Service Fund. State utility commissions are
responsible for designating common carriers as ETCs for the purpose of receiving such
funds, and may impose conditions on a common carrier so designated. The Commission
will approve applications from carriers requesting ETC designation if the application
meets the requirements of WAC 480-123-030, the designation will advance some or all
of the purposes of universal service found in 47 U.S.C. $ 254, and the designation is in
the public interest.'
The Commission agrees with Staffthat the Company has demonstrated that it continues
to meet the criteria for designation as an ETC set forth in Order 01, including offering all
services supported by the federal universal service support mechanisms set forth in 47
U.S.C. $ 254. i-wireless should also continue to be exempt from WAC 480-123-
030(1Xd),(0, and (g) because i-wireless is not a high cost fund recipient and because the
Company relies on other carrier facilities. i-wireless has also demonstrated compliance
with the 2l conditions set forth in Appendix B to Order 0l.
The Commission also agrees with Commission Saff that the amended conditions set
forth in Appendix A to this order are appropriate, given the FCC's recent order requiring
a forbearance compliance plan and adoption of more stringent requirements for the
federal Lifeline program.
The Commission concurs with Staffthat the Company's ETC renewal application should
not be delayed pending FCC resolution of the NAL. The Commission recognizes the
importance of accurate customer eligibility records and we are concerned that the
Company may have some issues with its current practices, although no such problems
have been identified in Washington. However, the Commission will consider i-wireless'
renewal petition on the record now before us. We may choose to revisit the Company's
ETC status once the FCC finalizes this matter.
The Commission agrees with Commission Staff that the Company may continue to be
designated as an ETC and is entitled to continued exemptions from WAC 480-123-
030(lXd),(|, and (g), subject to the amended conditions set forth in Appendix A to this
order.
l2
7 wAC 480-123-040.
(1)
(2)
t3
t4
DOCKET UT-101640
ORDER02
(4)
(s)
PAGE 4
FINDINGS AI\D CONCLUSIONS
The Commission has jurisdiction over ETCs in Washington and the subject matter
of this order under 47 U.S.C. $ 2la(e)(2),47 C.F.R. 54.201(b)-(c) and WAC 480-
123-040.
i-wireless is a telecommunications company doing business in the state of
Washington as an Eligible Telecommunications Carrier. i-wireless has
demonstrated that it continues to meet the requirements for designation as an
ETC, subject to the conditions set out in Appendix A to this Order.
i-wireless's continued designation as an ETC will advance the purpose of
universal service because the Company will offer voice telephony services, which
facilitate universal service.
i-wireless has also demonstrated that its designation as an ETC is in the public
interest because its services will benefit low-income customers.
This matter came before the Commission at its regularly scheduled meeting on
May 29,2014.
(3)15
16
t7
I8
ORDER
THE COMMISSION ORDERS:
(1) i-wireless, LLC's request for continued designation as an ETC in service areas
specified in Appendix B is hereby GRANTED, subject to the conditions set forth
in Appendix A.
i-wireless LLC's request for continued exemption from WAC 480-123-
030(lxd),(0 and (g) is hereby GRANTED, subject to the conditions set forth in
Appendix A.
The Commission retains jurisdiction over this matter for purposes of effectuating
this order.
(2)
(3)
DOCKET UT.1O164O
ORDER02
DATED at Olympia Washington, and effective May 29,2014.
PAGE 5
WASHINGTON UTTLITIES AND TRANSPORTATION COMMIS SION
DAVID W. DANNER, Chairman
JEFFREY D. GOLTZ, Commissioner
DOCKET UT-1OI64O
ORDER02
PAGE 6
APPEI\DIX A
Washington State Conditions on Designation of i-wireless, LLC
as an Eligible Telecommunications Carrier
i-wireless, LLC (i-wireless or Company) shall utilize federal default eligibility criteria
only, i.e., not utilizing Washington Telephone Assistance Program eligibility criteria
that are not on the federal list.
i-wireless shall file with the Commission any future changes to its rates, terms,
conditions or Lifeline customer application form at least one day prior to the effective
date ofthe change.
The information on i-wireless's rates, key terms and conditions, e.g., return policy,
usage definition, refill methods, annual recertification requirement, and customer
service contact, shall be provided in a package sent or given to Lifeline customers
after enrollment in i-wireless's Lifeline program, as well as at i-wireless's official
Lifeline website.
For the rate plans free of charge to customers, i-wireless must offer at least one plan
with a minimum of 250 minutes per month. The Company may invoke Condition No.
2 only for the purpose of increasing the number of minutes or enhancing the features
in the Lifeline plan, but not decreasing the number of minutes.
i-wireless shall deactivate a Lifeline account if the customer has no usage for 60
consecutive days pursuantto 47 C.F.R. $ 5a.a07(c)(2). No fewer than eight business
days before deactivation, i-wireless shall send the customer a written notice by mail
about the potential deactivation and ways to avoid unwanted deactivation. The
customer shall have a 30 day grace period from the deactivation date to reactivate the
Lifeline account by incurring otsage" as defined in 47 C.F.R. g 54.407(c)(2). When a
customer reactivates the account, i-wireless must deposit the minutes the customer is
entitled to for the grace period.
On a quarterly basis, i-wireless shall provide the number of Lifeline customers that it
enrolls each month. i-wireless shall also report the number of deactivated Lifeline
customers each month by service plan and the reasons for deactivation, e.g., no usage
for 60 consecutive days, annual verification unsuccessful, or voluntary exit. Quarterly
reports shall be filed with the Commission no later than 30 days after the end of each
quarter.
i-wireless shall respond within 30 days to Commission Staffs information requests
on i-wireless's Lifeline operations, including but not limited to Lifeline customers'
usage patterns and Lifeline customer records.
l.
J.
4.
5.
6.
7.
DOCKET UT.l01640
ORDER 02
PAGE 7
i-wireless shall cooperate with the commission and the Department of Social and
Health Services (DSHS) to work out a procedure to verifu i-wireless Lifeline
customers'eligibility. i-wireless shall maintain access to DSHS's online query
database to veriff the eligibility of Lifeline applicants who qualiff based on their
participation in Medicaid, Supplemental Nutrition Assistance Program, Supplemental
Security Income and Temporary Assistance for Needy Families. This condition shall
be required until the national Lifeline eligibility database is fully functional.
i-wireless must not deduct airtime minutes for calls to customer care made from the
customer's handset by dialing 611. i-wireless shall explicitly state the policy of free
611 calls in its Lifeline service agreements. i-wireless may require the customer to
call the toll-free customer care number from another phone if necessary to resolve
technical issues related to the handset or its programming.
i-wireless shall have DSHS audit its Washington Lifeline customers'eligibility
(including program eligibility and duplication with other Lifeline providers) at least
once a year. By January 3l of each year, i-wireless shall provide DSHS the complete
record of its Washington Lifeline customers who qualiff based on their participation
in Medicaid, Supplemental Nutrition Assistance Program, Supplemental Security
lncome and Temporary Assistance for Needy Families in the prior calendar year. The
records must have atl the necessary information and be in an electronic format
required by DSHS. After DSHS notifies i-wireless of the results of the review, i-
wireless must take appropriate measures to either correct the customer records or stop
providing services to ineligible customers and report the resolutions to the
commission and DSHS within 60 days of the DSHS notice. This condition shallbe
required until the national database for Lifeline customer eligibility is fully
functional.
i-wireless shall provide the commission a copy of its annual Lifeline Re-certification
results within 30 days it files with the Universal Service Administration Company
(USAC) each year.
i-wireless shall file with the commission, by March 3l of each year, a report on the
number of complaints, categorized by the different nature of complaints that it
received from Washington Lifeline customers during the prior calendar yetr, e.9.,
billing disputes and service quality complaints. This report shall include complaints
filed with i-wireless, the commission's Consumer Protection and Communications
Section, the Washington State Office of the Attorney General, and the Federal
Communications Commission (FCC). This report shall not include calls from
customers with regard to general inquiries such as account balance, additional
purchases, service availability or technical support. The Commission reserves the
8.
9.
10.
I l.
12.
DOCKET UT.1O164O
ORDER02
PAGE 8
right to revoke i-wireless's ETC designation if i-wireless fails to provide reasonable
quality of service.
i-wireless shall cooperate with the Washington State Enhanced 911 Program (E9ll)
and all Public Safety Answering Points on E911 issues and shall, upon request,
designate a representative to serve as a member or altemate member of the
Washinglon State E911 Advisory Committee or its Communications Sub-committee.
i-wireless shall comply with rules on cessation of business as specified in WAC 480-
120-083.
Prior to cessation of business, i-wireless shall make arrangements with its
underlying carriers to provide minutes already sold to customers under the
same terms and conditions it has with the customers, or provide refunds to the
existing customers.
i-wireless shall provide written notice to the following persons at least 30 days
in advance ofcessation ofservice:
The Commission;
The state 911 program;
Each of its customers;
The national number administrator.
c. The notice to the Commission and the state 9l I program must include the
same information required by WAC 480-120-083(3).
d. The notice to the customers must include the same information required by
wAC 480-120-083(4).
e. The notice to the national number administrator must include the same
information required by WAC 480-120-083(7).
f. i-wireless shall file with the Commission at least 30 days in advance of its
cessation of business and request the relinquishment of its ETC designation in
Washington.
i-wireless shall collect and maintain necessary records and documentation to ensure
its compliance with the applicable FCC and Commission requirements, including
existing requirements and any future modifications. The records and documentation
shall be provided to Commission Staffupon request.
b.
l.
ll.
lll.
iv.
15.
DOCKET UT-101540
ORDER02
PAGE 9
i-wireless shall cooperate with Commission Staffon phone number conservation
issues and shall comply with 47 C.F.R. $ 52.
i-wireless shall comply with all applicable federal and Washington state statutes and
regulations, including E9 I 1 tax contributions.
i-wireless shall file with the Commission ofthe results of any audits (including in-
depth data validations) or investigations on the Company's Lifeline operation in any
states or jurisdictions conducted by the FCC or USAC within 14 calendar days from
the receipt of results. The Company must also notiff the Commission of any ongoing
investigation that has resulted in monetary or administrative penalty (e.g., suspension
of Universal Service Fund reimbursement, suspension of Lifeline program operation)
within 14 calendar days of the occurrence of such events. To the extent the Company
deems the above information confidential, the Company may submit the notification
on a confidential basis consistent with Commission rules.
16.
17.
18.
i-wireless
Lifeline Assistance Program
lndependent Accountants' Report
on Applying Agreed-Upon Procedures
March 2,2015
.{.91 Clanr ScHaerrR HAcKETT
t}1f STRENGTH tN NUMBERS
$ Cuanr ScHRETER HACKETT
S TRINGl'H IN NUMBERS
INDEPENDENT ACCOUNTANTS' REPORT
ON APPLYING AGREED.UPON PROCEDURES
i-wireless, Federal Communications Commission, and
Universal Service Administrative Company
We have performed the procedures contained in the Lifeline BiennialAudit Plan, which were agreed to by i-
wireless ("Carrier'), Federal Communications Commission ("FCC"), and Universal Service Administrative
Company ('USAC') (the specified parties), solely to assist you with respect to determining compliance with the
Lifeline Assistance Program for the year ended December 31, 2013. i-wireless's management is responsible for
compliance with the Lifeline Assistance Program. This agreed-upon procedures engagement was conducted in
accordance with U.S. generally accepted government auditing standards as established by the Government
Accountability Office, which incorporate attestation standards established by the American lnstitute of Certified
Public Accountants. The sufficiency of these procedures is solely the responsibility of those parties specifled in
the report. Consequently, we make no representation regarding the sufficiency of the procedures described below
either for the purpose for which this report has been requested or for any other purpose.
Our procedures and findings are as follows:
1. Procedure: lnquired of management and obtained carrier policies and procedures for offering Lifeline
service to qualifying loririncome consumers. Examined the canier policies and procedures, and
compared management responses and carrier policies and procedures with the FCC's Lifeline rules set
forth in Appendix F of the Lifeline Biennial Audit Plan.
Results: No exceptions noted.
2. Procedure: lnspected 10 examples of carrier marketing materials describing the Lifeline service to
ensure they included the following:
The service is a Lifeline service, which is a government assistance program;
The service is non-transferable;
Only eligible subscribers may enroll;
Only one Lifeline discount is allowed per household; and
i-wireless's name or other brand names used to market the service.
Results: No exceptions noted.
one east fourth street, suite 1200
cincinnati, OH 45202
www.cshco.com
p. 513.241.3111
1.513.241.1212
northern kentucky I springfield I toledo
a.
b.
c.
d.
e.
cincinnati I cleveland I columbus I miami valley I
3.Procedure: Randomly selected 10 recorded calls servicing i-wireless's Lifeline subscribers out of the 50
recorded calls provided by i-wireless. Listened to the calls to note:
a. The telephone number(s) involve the use of interactive voice response (lVR) system;
b. A live customer care operator is available;
c. The time spent using the customer care telephone service; and
d. Whether the customer care telephone number(s) can be used by subscribers to notify i-wireless
of the subscriber's intent to cancel service or give notification that the subscriber is no longer
eligible to receive service.
Results: No exceptions noted.
Procedure: lnspected applicable policies and procedures regarding de-enrollment from the program,
including when i-wireless will de-enroll subscribers based on lack of eligibility, duplicative support, non-
usage, and failure to recertify, as further described below.
lnspected i-wireless's policy and procedures for de-enrollment where i-wireless has information indicating
that a Lifeline subscriber no longer meets the criteria to be considered a qualifying low-income consumer
under 47 C.F.R. 554.409. Noted whether the policy and procedures detail the process for
communications between the subscriber and i-wireless regarding de-enrollment, including, but not limited
to:a. Notifying subscribers of impending termination of service;
b. Allowing subscriber to demonstrate continued eligibility; and
c. Termination of service for failure to demonstrate eligibility.
lnspected i-wireless's policy and procedures for de-enrolling subscribers that are receiving Lifeline service
from another eligible telecommunications carrier or where more than one member of a subscriber's
household is receiving Lifeline service (duplicative support). Noted if the policy and procedures state that
i-wireless will de-enroll subscribers within five business days of receiving notification from USAC program
management that a subscriber or a subscriber's household is receiving duplicative Lifeline support, as
required by section 54.405(eX2) of the Commission's rules.
lnspected i-wireless's policy and procedures for de-enrolling subscribers for non-usage (i.e., where a
Lifeline subscriber fails to use Lifeline service for 60 consecutive days), including the process of how the
carrier monitors the identifies subscribers who are non-users of Lifeline service but enrolled in the
program. Using a list of subscribers provided by i-wireless:
a. For subscribers listed as de-enrolled or scheduled for de-enrollment, selected a sample of 10
accounts and requested copies of the non-usage termination notifications sent to the subscribers.
b. Examined the non-usage termination notifications to verify if the termination notifications explain
that the subscriber has 30 days following the date of the impending termination notification to use
the Lifeline service.
c. Attached a sample of non-usage termination notifications as Attachment 1 to this report.
Reviewed the carrier's policy and procedures for de-enrolling a Lifeline subscriber that does not respond
to the carrieds attempts to obtain recertification, as part of the annual eligibility recertification process.
Selected a random sample of 30 subscribers and requested copies of the notice of impending de-
enrollment letters and all other communications sent to the subscribers involving recertification and
performed the following:
a. lnspected the sampled notice of impending de-enrollment letters and any other communications
sent to the subscriber regarding re-certification to verify if the communications explain that the
subscriber has 30 days following the date of the notice of impending de-enrollment letter to
demonstrate continued eligibility or the carrier will terminate the subscriber's Lifeline service.
4.
b. Reviewed the de-enrollment letters, and other forms of communications, and the carrier's
responses to the background questionnaire and verified through observation that the de-
enrollment letters, if that form of communication was used, were sent by a method separate from
the subscriber's bill (if a customer receives a bill from the carrier).
c. Attached a random sample of 5 examples of the impending de-enrollment letters to this report as
Attachment 2.
Results: No exceptions noted.
5. Procedure: !nquired of management and obtained i-wireless policies and procedures for limiting Lifeline
support to a single subscription per household as provided by the carrier. Examined the policies and
procedures. Compared management responses and carrier policies and procedures with the FCC's
Lifeline rules set forth in 54.409(c).
Results: No exceptions noted.
6. Procedure: Reviewed procedures i-wireless has in place to ensure it has accurately completed the FCC
Form 497. Ensured the procedures or process included the following:
a. The position title of the person responsible for obtaining data for the FCC Form 497;
b. The process for determining which subscribers should be included monthly in the FCC Form 497.
Verified the procedures include cut-off and billing cycle dates, and only those subscribers active
as of the start or end of the month;
c. That a corporate officer signature is required for the FCC Form 497;
d. That a verification process exists to perform an independent review; that is, the person reviewing
or validating the form's data is different from the person completing the form;
e. Provides the billing system name used to generate completion of the form; and
f. lf applicable, describes the process for completing the Tribal Link Up portions of the FCC Form
497.
Results: No exceptions noted.
7. Procedure: Obtained the subscriber list and obtained i-wireless's FCC Form 497s for lllinois, Kentucky,
and Kansas. Examined the number of subscribers claimed on the Forms 497. Compared the number of
subscribers reported on the Form 497s to the number of subscribers contained on the subscriber list for
each study area.
Results: No exceptions noted.
8. Procedure: Used computer-assisted audit techniques to examine the subscriber list for duplicate
addresses with different subscribers. Created a list of subscribers with duplicate addresses.
Results: No exceptions noted.
9. Procedure: From the list created in Procedure #8, randomly selected 30 subscribers and requested
copies from i-wireless of the one-per-household certification form for each of the selected subscribers.
Verified that the selected subscribers certified to only receiving one Lifeline-supported service in his/her
household using the one-per-household worksheet.
Results: No exceptions noted.
10.Procedure: lnquired of management and obtained i-wireless policies and procedures for ensuring that its
Lifeline subscribers are eligible to receive Lifeline services as provided by the carrier. Examined the
policies and procedures. Compared management responses and i-wireless policies and procedures with
the FCC's Lifeline rules set forth in section 54.410.
lnspected i-wireless's policies and looked for evidence as to whether it includes a policy that i-wireless
does not retain copies of subscribers' proof of income or program based eligibility.
lnspected i-wireless's policies and looked for evidence as to whether it includes a policy or procedure that
i-wireless must fully verify the eligibility of each low-income consumer prior to providing Lifeline service to
that consumer, and that i-wireless or its agents may not provide the consumer with an activated device
intended to enable access to Lifeline service until that consumer's eligibility is fully verified and all other
necessary enrollment steps have been completed.
Results: No exceptions noted.
Procedure: Examined i-wireless's policies and procedures for training employees and agents for
ensuring that i-wireless's Lifeline subscribers are eligible to receive Lifeline services, including any
policies regarding how the company ensures employees and agents have completed the training.
Noted the following related to training:
i-wireless conducts a comprehensive training program for all employees, agents and/or third parties
acting on behalf of the company on the various processes and validation checkpoints designed to ensure
only eligible consumers enroll in the Lifeline program. Updates to training materials are incorporated on
an as-needed basis to reflect any changes or modifications to the Lifeline program rules, requirements or
enrollment process. Training materials include: NLAD lnformation and Data Exchange, CGM Enrollment
Compliance Platform for Tablets and WebBased devices, Real-Time-Review Queue Process, State
Eligibility Database Query Process, Kroger Event Best Practices and Call Center scripts for onboarding
new customers. All of these materials are included in the i-wireless Policies & Procedures Guidebook. ln
addition to these materials being provided to all employees and third party agents, new employees
receive hands on, on the job training and agents receive update webinars at least monthly.
Results: No exceptions noted.
12. Procedures: Randomly selected 50 subscribers from the subscriber list and performed the following tests:
Examined the subscriber certification and recertification forms, if any, to verify the forms contained the
following information:
a. Lifeline is a federal benefit and that willfully making false statements to obtain the benefit can
result in fines, imprisonment, de-enrollment or being barred from the program;
Only one Lifeline service is available per household;
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;
A household is not permitted to receive Lifeline benefits from multiple providers;
Violation of the one-per-household limitation constitutes a violation of the Commission's rules and
will result in the subscriber's de-enrollment from the program;
Lifeline is a non-transferable benefit and the subscriber may not transfer his or her benefit to any
other person;
Require each prospective subscriber to provide the following information:i. The subscriber's full name;
ii. The subscriber's full residential address;
11.
b.
c.
d.
A
t.
g.
Whether the subscriber's residential address is permanent or temporary;
The subscriber's billing address, if different from the subscriber's residential address;
The subscriber's date of birth;
The last four digits of the subscriber's social security number, or the subscribe/s Tribal
identification number, if the subscriber is a member of a Tribal nation and does not have
a social security number;
lf the subscriber is seeking to qualify for Lifeline under the program based criteria, as set
forth in 554.409, the name of the qualiffing assistance program from which the
subscriber, his or her dependents, or his or her household receives benefits; and
lf the subscriber is seeking to qualiff for Lifeline under the income based criterion, as set
forth in S 54.409, the number of individuals in his or her household.
Require each prospective subscriber to certif,, under penalty of perjury, that:
i. The subscriber meets the income based or program based eligibility criteria for receiving
Lifeline, provided in S 54.409;
ii. The subscriber will notiff i-wireless within 30 days if for any reason he or she no longer
satisfies the criteria for receiving Lifeline including, as relevant, if the subscriber no longer
meets the income based or program based criteria for receiving Lifeline service, the
subscriber is receiving more than on Lifeline benefit, or another member of the
subscriber's household is receiving a Lifeline benefit;
iii. lf the subscriber is seeking to qualifu for Lifeline as an eligible resident of Tribal lands, he
or she lives on Tribal lands, as defined in 54.400(e);
iv. lf the subscriber moves to a new address, he or she will provide that new address to i-
wireless within 30 days;
v. The subscriber's household will receive only one Lifeline service and, to the best of his or
her knowledge, the subscriber's household is not already receiving a Lifeline service;
vi. The information contained in the subscriber's certification form is true and correct to the
best of his or her knowledge;
vii. The subscriber acknowledges that providing false or fraudulent information to receive
Lifeline benefits is punishable by law; and
viii. The subscriber acknowledges that the subscriber may be required to recertify his or her
continued eligibility for Lifeline at any time, and the subscriber's failure to recertify as to
his or her continued eligibility will result in de-enrollment and the termination of the
subscriber's Lifeline benefits pursuant to $ 54.405(e)(4).
Compared i-wireless's subscriber eligibility criteria on the certification and recertification forms to
the federal eligibility criteria listed in 47 CFR S 54.409.
Verified the subscriber completed all the required elements, including signature and
initialing/checkbox requirements contained in the certification and recertification forms.
Examined the subscriber's initial certification form to verify the initial certification form is dated
prior to or on the same day as the Lifeline start date per the subscriber list.
lf applicable, verified subscribers who received Tribal Lifeline support certified to residing on
Triballands.
Reviewed the list of the data source or documentation i-wireless reviewed to confirm the subscriber's
eligibility. Verified the recorded data sources are eligible data sources per 47 CFR S 54.410, such as ('1)
income or program eligibility databases, (2) income or program eligibility documentation, or (3)
confirmation from a state administrator.
Results: Two out of 50 (4%) certification and recertification forms did not document whether the address
provided was permanent or temporary. No other exceptions noted.
iii.
iv.
v.
vi.
vii.
viii.
h.
13. Procedure: lnquired of management and obtained carrier policies and procedures for ensuring that the
carrier has made and submitted the annual certifications require under sections 54.416 and 54.422 otthe
FCC's rules. Examined the policies and procedures. Compared management responses and carrier
policies and procedures with the FCC's Lifeline rules set forth in sections 54.416 and 54.522.
Results: No exceptions noted.
14. Procedure: Examined i-wireless's FCC Form 555 that was filed the January following the audit period
(January 2014). Verified the carrier made all of the following certifications An officer of each eligible
telecommunications company must certiff that he or she understands the FCC's Lifeline rules and
requirements and that the carrier:
a. Has policies and procedures in place to ensure that its Lifeline subscribers are eligible to receive
Lifeline services;
b. ls in compliance with all federal Lifeline certification procedures; and
c. ln instances where i-wireless confirms consumer eligibility by relying on income or eligibility
databases, as defined in 47 CFR S 54.410 (bxlX|XA) or (c)(1)(i)(A), the representative must
attest annually as to what specific data sources the ETC used to conflrm eligibility.
Results: No exceptions noted.
15. Procedure: Examined i-wireless's organizational chart. Verified that the certifying officer on the FCC
Form 555 is an officer per the organizational chart or other publicly available documents.
Results: No exceptions noted.
16. Procedure: Verified that the subscriber count per the FCC Form 555 agrees with the total subscriber
count per the February Form 497.
Results: No exceptions noted.
17. Procedure: Reviewed the recertification results for lllinois, Kentucky and Kansas of individual subscribers
reported on the FCC Form 555 filed the January following the audit period. Verified the data reported on
the FCC Form 555 for those states agree with the detailed recertification results.
Results: lnformation reported in Column I on the Form 555 for lllinois, Kentucky and Kansas did not
agree to supporting schedules prepared by i-wireless. The amounts reported in Column I for lllinois,
Kentucky, and Kansas are 33,941, 12,007, and 1,151, respectively. However, the amountthat should
have been reported and the amount supported by i-wireless schedules is 0, for each of the states tested.
No other exceptions noted.
18. Procedure: Reviewed i-wireless's detailed non-usage results of the individual subscribers reported on the
FCC Form 555 during March, June, and October in lllinois, Kentucky and Kansas. Verified that the data
reported on the FCC Form 555 for the Non-Usage Sample agrees with the detailed non-usage results.
Results: No exceptions noted.
19. Procedure: Reviewed i-wireless's annual ETC certification. Verified that i-wireless reported allthe
information and made all the certifications required by 47 CFR S 5a.a22@)(b).
Results: No exceptions noted.
20. Procedure: Reviewed supporting schedules related to i-wireless's annual ETC certification. Verified that
the data reported on the annual ETC certification agrees with the supporting schedules.
Results: lnformation reported in Column I on the Form 555 for lllinois, Kentucky and Kansas did not
agree to supporting schedules prepared by i-wireless. The amounts reported in Column I for lllinois,
Kentucky,andKansasare33,941,12,007,and1,151,respectively. However,theamountthatshould
have been reported and the amount supported by i-wireless schedules is 0, for each of the states tested.
No other exceptions noted.
21. Procedure: lnquired of management and obtained i-wireless policies and procedures for maintaining
records that document compliance with the Lifeline program rules. Examined the policies and procedures.
Compared the management responses and carrier policies with recordkeeping rules set forth in 47 CFR S
54.417.
Results: No exceptions noted.
We were not engaged to, and did not, conduct an audit, the objective of which would be the expression of an
opinion on the accounting records. Accordingly, we do not express such an opinion. Had we performed additional
procedures, other matters might have come to our attention that would have been reported to you.
This report is intended solely for the information and use of i-wireless, FCC, and USAC and is not intended to be
and should not be used by anyone other than those specified parties. This report becomes a matter of public
record when the final report is filed with the FCC.
C/a,"( ek fr, #*hx & Co,
Cincinnati, Ohio
March 2,2015
ATTACHMENT 1
SAMPLE NON.USAGE TERMINATION NOTIFICATION
The following is a sample e-mail termination notification:
Dear AccBss Wireless Customer,
Our records indicate that you have not used lour Access t/Yirebss
phone in the past 60 days. In order to maintain your Lrfeline
bcncfrt, you MIIST 3hor,, activc rrnc on your account indicatng your
d€sire to continue receiving your free morthly allotrnert of
airtinE. Failure to use your phorc in the next 30 days will result
in thc tcrmination of your Lifclinc gervice and dc-enrollmcnt from
the Lifeline prooram for non-usaoe.
Afv or $!e followlng a(uvHes cdrstkutrE use or your ACtG8E
Wirele*s trhtrre and wBl a$ow you to ecntinue raceiving your frae
monthly Lifeline benefrt:
e Makean outbound ohone cal or daal 611r Add airtime to your a(counto AnsrvEr an incqring call frorn sorncone other thtn Access
Wirelecer Respond to dircct contacl from Acess Wireless confirmingyour desire to continLE rcceiving your rnonthly Ufehne
bcnsrit
If you have {uestlons regardng your lccess Wircle$ s€rvice,
pl6es{ csrtact Cu&torrior Caro by dialirq 611 frorn yourAccoae
Wir€less phtrre or by calling 1-866-594-3644 from any touch-lone
phon€.
Thank yor for chocing Access lllirdess.
Kind Rcgards,
Access Wirehss Lifeline AdministratDr
AfIegS YS€ES5 E a Satylg: p,0vl{N, IO( tne giirY€rnmefil-Iuaot{ Llterlne A5S6aA*lJ
PrBrirff, U&llneseftlEe I prsrlded D\, ]'wfieEss. LLc, dr!/a ,tccels wlEle$. whldl is ar
elldble telec}lnrnin&rflors €arPr. Lltelne leffl(€ It non.trdnrrer€ble. only one Lltelne
or$lunt mal b€ reEeueo p€r lousdflolc. A roll{*rolg t5 {rpnn6, tcr the p0rpot€s cr fia
Iltfllne ,m{rarn. a5 aoy IrdivMsa[ rr orsuD 0t lnd$id{als {ho lhB m{afiEf at me SarFe
address i nd sflarE lnom€ and €rpen:rer . A hous{holo l5 r{rt lltrmlmd b rElElve D€nellls
tror mrliiple 9(*rd€(5. vBlaDofl d $e onc-per.lsurenoB ruE aorsuBt€a i vldeuoll ot
rcC ru16, sr, wal ett t^ tie cu&mc/a ab.e@llffit Iror Llfsino. O^h ohgttc
cusomefls oay grrolr in $a ofcgBn. @Esure'! ufira wlltulty mala a EBestatamert tn
oraEr tooBtrlrl tle urEllne befleilt (.n E prnBhcrt by tlna or trnprEonEent, or G'n ba
bsGd tEm llr ,898F. curlom6 m!!t FfE4nt p,E Cr dGrneoleBon Mim.rg
ellgbllltl forure Uteltle 9ro{rErn. Yolrr tntormaton will br valdatd agBlnst puurc r€corG
aod any dlsorpafl(,e! c{h,{, rerult n ddafs n yatr ar9roral u releciolr ol tervfe.
8
CCCESSWIRELESS
--]
ATTACHMENT I
SAMPLE NON.USAGE TERMINATION NOTIFICATION
The following is a sample post card termination notification:
,'6t
OCCESSWIRE LESS.
Dear Access Wireless Custome[
Our records indicate that you have not used your Access Wreless phone in
the past60days.ln orderto maintain your Llfeline beneft,you MUSI show
actlve use on your account indicating your desire to continue receiving your
free monthlyallotmentdairtime. Failure to useyour phone in the next30days
will result in termination of your Lifeline seMce and deenrollment from the
Lifu line program for non-usage.
Any of the folbwing activities constitutes use of your AccessWreles phone
and will allory you to <ontlnue neMng your fioe montlily Llfellne bcnefit:
.Add airtime to your account by calling 61 1
.ltdake a phone call
lf you have questions regarding your AccessWrehss service, please contact
Customer Care by dialing 61 1 from your Access Wreles phone.
Kind regards,
kcess Wrclss Llfeline ldministrator :,Gs OCCESS
V/IRELESS.
nlu.Euf (b'udordho.Fft cddd if qrl:rrt*rff ilq adraEtnttoDns.rffiIL-rnrtl'h!ffi n!!rdtrrrFgrlr(m*EilrncHt r-ilhotEdirndErdroD.Frft !,tlra@n l,aobbdtmirFoFrrclEmmrF.rFFddt!.*rd{HrgdilofyHr.tmrFqre
A go\renrIlEnt{flded Ublne Asr8ttnce Plogfian.
ATTACHMENT 2
FIVE SAMPLE IMPENDING DE-ENROLLMENT NOTIFICATIONS
i-wireless sends the following text messages to notiff subscribers of impending de-enrollment regarding the
recertifi cation process:
1. "You must renew your eligibility for Lifeline service in the next 60 days. Call 611 now to keep Access
Wireless phone active.'2. "Renew your free Access Wireless service for another year by calling 611 to confirm your eligibility to
receive Lifeline assistance."3. "You must re-certify your eligibility to receive Lifeline assistance. Call 611 to keep your Access
Wireless phone active for another year."4. "Renew your Access Wireless service for 1 year by calling 611 and confirming your eligibility to
continue receiving Lifeline assistance."5. "Call 611 to keep your free Access Wireless service for another year by recertif,ing your eligibility to
receive Lifeline assistance."
10
Federal Communications Commission FCC 10-117
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Federal-State Joint Board on Universal Service
Telecommunications Carriers Eligible for
Universal Service Support
i-wireless, LLC Petition for Forbearance from 47
u.S.C. $ 2la(eXlXA)
CC Docket No. 9645
WC Docket No. 09-197
ORDER
Adopted: June22,2010
By the Commission:
Released: June 25,2010
I. INTRODUCTION
l. In this order, we grant in part and deny in part a petition for forbearance filed by i-
wireless, LLC (i-wireless), a prepaid wireless resale provider, requesting that the Commission forbear
from the requirement that a carier designated as an eligible telecommunications carrier (ETC) for
purposes of federal universal service support provide services, at least in part, over its own facilities.t As
a result, i-wireless may seek ETC desiglation to offer discounted service to qualified low-income
consumers through the universal service Lifeline program. i-wireless will be subject to the same
conditions that the Commission previously applied to prepaid wireless resellers TracFone Wireless, Inc.
and Virgin Mobile USA, L.P. in granting similar requests. The conditions will help to ensure that, if i-
wireless is granted ETC designation for the purpose of providing Lifeline service, its low-income
consumers have access to 911 and enhanced 9l I services and will help to protect the universal service
flrnd against waste, fraud and abuse. However, we deny i-wireless's petition for forbearance for the
purposes of participating in the Link Up program because the company has not demonstrated that
granting its request satisfies the three-prong statutory test for forbearance.2
il. BACKGROUND
Congress directed the Commission to establish the universal service fund to help ensure
that "[q]uality services [are] available at just, reasonable, and affordable rates" for consumers tlroughout
the nation, "including low-income consumers."' The Commission's Lifeline program furthers this goal
by reducing the price of monthly telephone service for low-income consumers, and the Commission's
I i-wireless, LLC Petition for Forbearance, CC Docket No. 96-45 (filed Apr. I, 2009) (Forbearance Petition). On
March 23, 20 I 0, pursuant to section I 0(c) of the Act, the Wire line Competition Bureau (Bureau) extended until June
30,2010, the date on which the Forbearance Petition shall be deerned granted in the absence of a Commission
decision that the petition fails to meet the standard for forbearance under section l0(a) ofthe AcL i-wireless, LLC
Petitionfor Forbearance, CC Docket No. 9645, Order, 25 FCC Rcd 2762 (Wireline Comp. Bur. 2010); 47 U.S.C.
$ 2la(e).
2 +z u.s.c. g l6o(a).
'+z u.s.c. g 2s4(b)(3).
Federal Communications Commission FCC 10-117
Link Up program furthers this goal by reducing the customary connection charge for commencing
telephone service at a low-income consumer's principal place of residence.a
3. The Communications Act of 1934, as amended (the Act), provides that only an entity
designated as an eligible telecommunications carrier shall be eligible for universal service high-cost and
low-income support.s To become an ETC, a corlmon carrier must offer the services supported by the
federal universal service support mechanisms "either using its own facilities or a combination of its own
facilities and resale ofanother carrier's services" to each customer in its designated service area.6
Carriers designated as ETCs generally must participate in the Lifeline and Link Upprograms and are
reimbursed for the revenues foregone through their participation in these programs.'
4. The Commission has granted two petitions for forbearance from the facilities requirement
for ETC designation in section 214(e) of the Act. In 2005, the Commission forbore from applying the
facilities requirement to TracFone Wireless, Inc. (TracFone), a wireless reseller, insofar as TracFone
sought ETC designation only for the purpose of receiving Lifeline support.s Similarly, in 2009, the
Commission forbore from applying the facilities requirement to another wireless reseller, Virgin Mobile
USA, L.P. (Virgin Mobile).e In both orders, the Commission conditioned forbearance on the carriers'
meeting certain obligations upon being designated as an ETC that are tailored to the concems arising from
each carrier's lack offacilities and proposed service offering.r0
a Through the Lifeline program, low-income consumers may receive discounts of up to $13.50 off the monthly cost
of telephone service, with the federal program reimbursing the ETC up to $10 each month. 47 C.F.R.
$ 5a.a0l (a)(2). ln tribal areas, the federal program reimburses ETCs up to an additional $25 each month. 47 C.F.R.
$ 5a.a05(a)(a). Through the Link Up program, low-income consumers may receive discounts of up to $30 off the
connection charge. 47 C.F.R. $ 54.41l(aX1). ln tribal areas, low-income consumers may receive up to an
additional $70 off the connection charge. 47 C.F.R. $ 54.41l(aX3).
'+Z U.S.C. g 25a(e). A canier need not be an ETC to participate in the schools and libraries or rural health care
universal service programs. 47 U.S.C. $ 254(hXlXA) and (B)(ii); see f'ederal-Stote Joinl Board on Universal
Service, CC Docket No. 96-45, Report and Order, I 2 FCC Rcd 8776, 901 5, para. 449 (1997) (Universal Service
First Report and Order) (subsequent history omitted); Federal-State Joint Board on Universal Service, CC Docket
No. 9646, Fourteenth Order on Reconsideration, l4 FCC Rcd 20106, 20114-15, para. l9 (1999) (Fourteenth Order
on Reconsideration).
6+ZU.S.C.g2la(eXl);47C.F.R.$54.201(dxl). BecauseacarrierneednotbeanETCtoparticipateinthe
schools and libraries or rural health care universal service programs, a carrier need not offer service over its own
facilities to receive support from those programs. See supra note 5.
7 See 47 C.F.R. $ 5a.a07@)'-(c). ETCs designated for the limited purpose of participating in the Lifeline program, in
contrast, may only receive Lifeline support.
r Petition of TracFone Wireless, lnc,for Forbearance.from 47 U.S.C. t 2la@(l)(A) and 47 C.f'.n. ss 54.201(r,CC
Docket No.96-45, Order,20 FCC Rcd 15095 (2005) (TracFone Forbearance Order).
e Virgin Mobile USA, L.P. Petition.for liorbearancefrom 47 U.S.C. S 2ta@(t)(A); Petition.for Designation as an
Eligible Telecommunications Carrier in the State o.f New York; Petition for Designation as an Eligible
Telecommunications Carrier in the Commonwealth of Virginia; Petition.for Limited Designation as an Eligible
Telecommunications Caruier in the State of North Carolina; Petilion for Limiled Designation as an Eligible
Telecommunications Caruier in the State of Tennessee, CC Docket No. 96-45, Order,24 FCC Rcd 3381 (2009)
(Virgin Mohile Forbearance Order).
r0 Specifically, each carrier must: (l) provide its Lifeline customers with 911 and enhanced 9l I (E9l l) access
regardless of activation status and availability of prepaid minutes; (2) provide its Lifeline customers with E9 I 1-
compliant handsets and replace, at no additional charge to the customer, noncompliant handsets ofexisting
customers who obtain Lifeline-supported service; (3) comply with conditions (l) and (2) as of the date it provides
Lifeline service; (4) obtain a certification from each public-safety answering point (PSAP) where the carrier
provides Lifeline service confirming that the carrier provides its customers with 91 I and E9 I I access or self-certif,
that it does so if certain conditions are met; (5) require each customer to self-certifu at time of service activation and
(continued . . .)
2
Federal Communications Commission FCC 10-117
5. i-wireless Forbearance Petition. Like Tracfone and Virgin Mobile, i-wireless is a non-
facilities-based commercial mobile radio service (CMRS) provider (i.e., a pure wireless reseller) that
provides prepaid wireless telecommunications services.rr On April l,2OO9, i-wireless filed a petition
seeking forbearance from the facilities requirement of section zla@) of the Act so that it may be
designated as an ETC and be eligible to receive Lifeline and Link Up low-income support.12 i-wireless
states that its request for forbearance satisfies the statutory requirements and is in the public interest.r3
Further, i-wireless agrees to abide by the conditions imposed on TracFone and Virgin Mobile as part of
the Commission's decisions granting those carriers' requests to forbear from the ETC facilities
requirement to allow them to receive Lifeline support only.la
III. DISCUSSION
6. The Act requires the Commission to forbear from applying any requirement of the Act or
of our regulations to a telecommunications carrier if and only if the Commission determines that:
(l) enforcement ofthe requirement is not necessary to ensure that the charges, practices, classifications,
or regulations by, for, or in connection with that telecommunications carrier are just and reasonable and
are not unjustly or unreasonably discriminatory; (2) enforcement of that requirement is not necessary for
(continued from previous page)
annually thereafter that he or she is the head ofhousehold and receives Lifeline-supported service only from that
carrier; (6) establish safeguards to prevent its customers from receiving multiple Lifeline subsidies from that carrier
at the same address; (7) deal directly with the customer to certifu and veri$ the customer's Lifeline eligibility; and
(8) submit to the Wireline Competition Bureau a compliance plan outlining the measures the carrier will take to
inrplenrent these conditions. ,See id. at3386-87,3392,parus. 12,26; TracFone Forbearunce Order,20 FCC Rcd at
15098-99, I 5l 04, paras. 6, 19; Federal-Slate Jctint Board on Universal Service; TracFone Wireless, Inc. Petition
for Designation as an Eligible Telecommunicalions Carcier in the State of New York; Petition for Designation as at1
Eligible Telecommunications Carcier in the Slate of Florida; Petition for Designation as an Eligible
Telecommunications Carrier in the Commonweahh of Virginia; Pelition for Designalion as an Eligible
Telecommunications Caruier in the State of Connecticut; Petition.for Designalion as an Eligible
Telecommunications Carrier in lhe Commonwealth of Massachusetts; Pelitionfor Designation as an Eligible
Telecommunications Carrier in the State of Alabama; Petilionfor Designation as an Eligible Telecomrnunications
Carrier in the State of North Carolina: Pelition for Designation as an Eligible Telecommunications Carrier in the
State of Tennessee; Petition for Designation as an Eligible Telecommunications Carcier in the State of Delaware for
the Limited Purpose of Offering Ldeline Service to Qualified Households; PetitionJbr Designation as an Eligible
Telecommunications Cttrrier in the State o.f New Hampshire.for the Limiled Purpose of Offering Lifeline Service lo
Qualified Households; Petition.for De.signalion as an Eligible Telecommunicalions Canier in the Commonwealth o/
Pennsylvania.for the Limited Purpose of Offering Lifeline Service to Qualified Households; Petitionfor Designation
as an Eligible Telecommunications Carrier in the Dislrict of Columbia for the Limited Purpose of Offering Lifeline
Seryice to Qualified Households, CC Docket No. 96-45, Order,24 FCC Rcd 3375 (2009) (TracFone Forbearance
ModiJication Order).
rlForbearance Petition at 2.
12 See Forbearance Petition. On June 5,2009, the Bureau issued a public notice seeking comment on the
Forbearance Petition. Commenl Sought on i-wireless, LLC Pelitionfor Forbearancefrom Eligible
Telecommunications Carrier Facilities Requirement, CC Docket No. 96-45, Public Notice , 24 FCC Rcd 7682
(Wireline Comp. Bur. 2009). Comments on the Forbearance Petition were filed by the National Association of State
Utility Consumer Advocates (NASUCA) and the National Emergency Number Association (NENA). Reply
comments were filed by NASUCA, i-wireless, and the Pennsylvania Public Utility Commission (Pennsylvania
Comrnission). We interpret i-wireless's petition to request forbearance not only from the statutory f'acilities
requirement, 47 U.S.C. S 2la(eX1)(A), but also from our parallel regulatory requirements, 47 C.F.R. $ 54.201(dXl),
(i). We have previously read these requirements to have the same scope and purpose as the statutory provision. ,See
Virgin Mobile Forbearance Order,24 FCC Rcd at 3386-87 n.4l .
rl Forbearance Petition at 8-13.
ra Forbearance Petition at 13; TracFone Forbearance Order,20 FCC Rcd at I 5098-99, l5l}4, paras. 6, 19; Virgin
Mo b ile F o rb earanc e Orde r, 24 FCC Rcd 3 3 86-87, 3392, paras. 12, 26.
tr'ederal Communications Commission FCC 10-117
the protection of consumers; and (3) forbearance from applying that requirement is consistent with the
public interest.rs As in the TracFone Forbearance Order andthe Virgin Mobile Forbearance Order,we
examine the facilities requirement from which i-wireless seeks forbearance in light of the statutory goal of
providing low-income consumers with access to telecommunications services and in light of the specific
programs in which i-wireless seeks to participate. Because our prior orders have laid the path for
examining forbearance requests in the context of the Lifeline program, we first evaluate i-wireless's
petition in that context. We then turn to the new issue of whether i-wireless has demonstrated that the
statutory requirements for forbearance are met in the context of the Link Up program.
A. Forbearance for Lifeline
7. In this section, we evaluate whether i-wireless has met the three-prong statutory test for
forbearance to receive Lifeline support. For the reasons provided below, we conditionally grant the
request of i-wireless for forbearance from the facilities requirement of section 214(e) for the purpose of
seeking ETC designation to provide Lifeline support only.
8. Just and Reasonable. As an initial matter, we note that a provision or regulation is
"necessary" if there is a strong connection between the requirement and regulatory goal.16 Section
l0(a)(l) of the Act requires that we consider whether enforcement of the facilities-based requirement of
section 214(e) for a pure wireless reseller that seeks ETC designation for Lifeline support only is
necessary to ensure that the charges, practices, classifications or regulations arejust and reasonable and
not unjustly or unreasonably discriminatory.' '
9. As the Commission found in the TracFone Forbearance Order and the Virgin Mobile
Forbearance Order, we conclude that the section 2la@) facilities requirement is not necessary to ensure
that i-wireless's charges, practices, and classifications arejust and reasonable and not unjustly or
unreasonably discriminatory where it is providing Lifeline service only.rs As a reseller, i-wireless is by
definition subject to competition. We expect that i-wireless's Lifeline offerings will compete, at a
minimum, with the Lifeline offerings of the incumbent wireline carrier in a given geographic area, and
potentially, depending on the states where i-wireless seeks ETC designation, with the offerings of
TracFone and Virgin Mobile.re We also expect that this competition will spur innovation amongst
carriers in their Lifeline offerings, expanding the choice of Lifeline products for eligible consumers. For
these reasons, we find that the first prong of section 10(a) is met. In the limited context of Lifeline
support, the facilities requirement is not necessary to ensure that i-wireless's charges, practices, and
classifi cations are just and reasonable.
10. Consumer Protection. Section l0(a)(2) requires that we consider whether enforcement of
the facilities-based requirement of section 214(e) for a pure wireless reseller that seeks ETC designation
only for Lifeline support is necessary for the protection of consumers. As in the cases of TracFone and
Virgin Mobile, we find that imposing the facilities requirement on i-wireless is not necessary for the
protection of consumers so long as the carrier complies with the obligations described below.
Specifically, we conclude that forbearance from this provision will benefit consumers. Indeed, if i-
wireless is ultimately granted limited ETC status, it would be offering Lifeline-eligible consumers an
additional choice of providers for accessing telecommunications services. The prepaid feature may be an
's 47 U.S.C. $ 160(a)-(b). ln making a public interest determination, section l0(b) requires the Commission to
consider whether forbearance will promote competitive market conditions.
16 See CTIA v. FCC,330 F.3d 502,512 (D.C. Cir. 2003).
'7 47 u.s.c. g r60(a)(1);47 u.s.c. g 21a(e).
tB See TracFone Forbearance Order,20 FCC Rcd at I 5 I 00, para. 12; Virgin Mobile Forbearance Order,24 FCC
Rcd at 3389, para.20.
te See 47 C.F.R. $ 54.405(a) (requiring ETCs to offer Lifeline service).
Federal Communications Commission FCC l0-117
attractive alternative for such consumers who need the mobility, security, and convenience of a wireless
phone, but who are concemed about usage charges or long-term contracts.
I L Given the importance of public safety and in light of the fact that a Lifeline ETC is
generally a low-income customer's only connection to the public switched telephone network, however,
we condition this grant of forbearance on i-wireless's compliance with certain obligations upon being
designated as an ETC, consistent with the public safety obligations previonsly imposed on TracFone and
Virgin Mobile.2o Specifically, our forbearance is conditioned on i-wireless:
( I ) providing its Lifeline customers with 9l I and enhanced 91 1 (E91 I ) access regardless of
activation status and availability of prepaid minutes;
(2) providing its Lifeline customers with E91l-cornpliant handsets and replacing, at no additional
charge to the customer, noncompliant handsets of existing customers who obtain Lifeline-
supported service;
(3) complying with conditions (l) and (2) as of the date it provides Lifeline service; and
(4) obtaining a certification from each PSAP where the carrier seeks to provide Lifeline service
confirming that the carrier provides its customers with 911 and E9l l access or self-certifying that
it does so if certain conditions are met.
12. The Commission has an obligation to promote "safety of life and property" and to
"encourage and facilitate the prompt deployment throughout the United States of a seamless, ubiquitous,
and reliable end-to-end infrastructure" for public safety.2r The provision of 91 I and E9l I services is
critical to our nation's ability to respond to a host of crises, and this Commission has a longstanding and
continuing commitment to a nationwide communications system that promotes the safety and welfare of
all Americans, including Lifeline customers.22 As we have held previously, we believe these obligations
are necessary to ensure that the Lifeline customers of these wireless resellers have meaningful access to
emergency services.?3
13. Consistent with the obligations we have placed on TracFone and Virgin Mobile, these
obligations apply in any state in which i-wireless becomes an ETC and plans to serve any customers
without using its own facilities. Additionally, i-wireless must furnish to the Commission upon request
copies of all certifications required by the fourth obligation.2a Furtherrnore, if i-wireless seeks to use the
self-certification option, it may do so only after complying with the following procedures. First, i-
wireless must request certification from the PSAP and notiff the PSAP that the carrier may self-certify
compliance if the PSAP has neither provided certification nor made an affirmative finding that the carrier
does not provide its customers with access to 911 and E9l I service within the PSAP's service area within
90 days of the request. This evaluation period commences upon proper notification.2s The evaluation
20 See TracFone Forbearance Order,20 FCC Rcd at 15101-02, paras. 15-16; Virgin Mobile Forbearance Order,
24FCC Rcd at 339G-91, paras. 21-23.
2t Applicalions of Nextel Communicalions, Inc. and Sprint Corporation For Consent to Transfer Control o./'Licenses
and Authorizations,WT Docket No. 05-63, Memorandum Opinion and Order, 20 FCC Rcd 13967, 14020, para. 144
(200s).
" rd.
23SeeTracFoneForbearanceOrder,20FCCRcdatl5l0l-{2,paras. 15-16;VirginMobileForbearonceOrder,
24FCC Rcd at 3390-9l,para.21-23.
2a See Virgin Mobile ETC Designation Order,24 FCC Rcd at 3390, para.22.
2s Id. at 3390-91, para.22. Consistent with the Virgin Mobile Forbearance Order, in providing notice that it may
self-certifu, i-wireless must provide a PSAP with all of the information and/or equipment requested by the PSAP in
analyzing i-wireless's ability to provide 9l I and E9l I to its customers.
Federal Communications Commission FCC 10-117
period is tolled whenever a PSAP reasonably requests information or equipment to evaluate the carrier's
ieqrest until the carrier responds with that information or equipment.26 If a PSAP determines that the
carrier will not offer its Lifeline customers appropriate access to emergency services or has concems
regarding the carrier's ability and if the PSAP notifies the carrier of its concerns during the evaluation
period, the evaluation period is extended by an additional 90 days and the carrier may not self+ertift
compliance until it has addressed the PSAP's concerns." Second,before self-certiffing, the carrier must
obtain from its underlying carrier in that area certification that the underlying carrier routes emergency
calls from the carrier's customers to the PSAP in the same manner that it routes emergency calls from its
own customers." Third,the carrier must provide the PSAP with a copy of the relevant self'certifications
at the time it is effective .2e Fourth, if a PSAP finds that i-wireless does not provide its customers with
9l I and E9l I access after the carrier has self-certified that it does, the carrier must notif, the Commission
of this finding upon receiving notice and must explain how it plans to meet the PSAP's concerns and
provide Lifeline customers with appropriate 9 t I and E9 I I access.30
14. Accordingly, we find that, subject to the 911 and E9l I conditions and the self-
certification and other conditions set out above, and consistent with the Commission's grant of
forbearance to TracFone and Virgin Mobile, the ETC facilities-based requirement is not necessary for
consumer protection with respect to i-wireless's receipt of Lifeline support only. We therefore conclude
that the second element of section 10(a) is satisfied.
15. Public Interesl. Section 10(aX3) requires that we consider whether enforcement of the
facilities-based requirement of section 214(e) for a pure wireless reseller that seeks ETC designation for
Lifeline support only is in the public interest. In evaluating whether forbearance is in the public interest,
we follow the path we laid out in the TracFone Forbearance Order andthe Virgin Mobile Forbearance
Order. We note first that the Commission's traditional concem with a carrier doubling its recovery by
reselling facilities that are already supported by the high-cost fund does not apply in the low-income
context.3r We also note that Lifeline support is designed to reduce the monthly cost of
telecommunications service for qualifying low-income consumers and is directly reflected in the price
that the low-income customer pays.32 Requiring a Lifeline provider to own the facilities it uses to offer
service does not necessarily further the statutory goal of the low-income program." In accordance with
our forbearance grants to TracFone and Virgin Mobile, we find that the public interest is served by
forbearing from the facilities requirement in section Zla@) to allow i-wireless to receive Lifeline
support.3a
'u ld. at339l,para.22.
" ld. at3390 n.67.
" ld. at 3391, para. 22. Like other certifications, the carrier is required to retain these underlying carrier
certifications and provide them to the Commission upon request.
'n rd.
30 Id.
3t See TracFone Forbearance Order,20 FCC Rcd at 15100-{1, para. 12; Virgin Mobile Forbearance Order,24
FCC Rcd at 3389, para. 18.
" 47 c.F.R. $g 54.40r, 54.504.
33 See TracFone Forbearance Order,20 FCC Rcd at 15104-05, para. 23; Virgin Mohile Forbearance Order,24
FCC Rcd at 3393, para. 29.
3a See Virgin Mobile Forbearance Order, 24 FCC Rcd at 3392-93 , para. 27 ("twle do not believe that similar
requests will have a detrimental impact on the fund. We note that to the extent any similarly situated prepaid
wireless reseller seeks forbearance from these requirements for the purpose of providing only Lifeline support, it
(continued . . .)
6
Federal Communications Commission FCC 10-117
16. Continued growth of the universal service fund has highlighted in recent years the
importance of the Commission's continued commitment to fight waste, fraud, and abuse. Accordingly, in
addition to the consumer protection conditions outlined above and consistent with obligations imposed on
TracFone and Virgin Mobile, we find that it is necessary to require i-wireless to assume additional
obligations designed to protect against waste, fraud, and abuse.3s Specifically, we condition our
forbearance from the facilities requirement on i-wireless:
(5) requiring each customer to self-certiff at time of seruice activation and annually thereafter
that he or she is the head ofhousehold and receives Lifeline-supported service only from that
carrier;
(6) establishing safeguards to prevent its customers from receiving multiple Lifeline subsidies
from that carrier at the same address;
(7) dealing directly with the customer to certify and veriff the customer's Lifeline eligibility; and
(8) submitting to the Wireline Competition Bureau a compliance plan outlining the measures the
carrier will take to implement the obligations contained in this order within 30 days of the
effective date ofthis order.
17. As we have held previously, we believe these obligations are necessary safeguards to
help deter waste, fraud, and abuse.36 These obligations apply in any state in which i-wireless becomes an
ETC and plans to serve any customers without using its own facilities. Consistent with the obligations we
have placed on TracFone and Virgin Mobile, we require i-wireless to clearly state the penalties for
perjury on the self-certification form it uses to comply with the fifth obligation and to monitor compliance
of its customers' self-certifications by retaining those self-certifications and providing them, as well as
documentation of how the carrier obtained the certification, to the Commission upon request.3?
18. We disagree with parties that argue that we should condition our forbearance on i-
wireless complying with additional obligations, such as offering a particular usage package or complying
with state-level 9l I and E9l I obligations.3s We believe it is appropriate to leave those assessments to
whichever commissions will rule on i-wireless's petitions for designation as an ETC. A state commission
is generally in a better position than we to assess whether a particular offering will benefit that state's
low-income consumers and to determine whether it is necessary to condition ETC designation on
compliance with state-level 9l 1 and E9l I obligations.3e We therefore encourage parties arguing for
(continued frorn previous page)
will be expected to comply with all the conditions we imposed upon TracFone, which Virgin Mobile has agreed to
do.").
35 See TracFone Forbearance Order,20 FCC Rcd at 15103-{4, 15105, paras. 18, 25; Virgin Mobile Forbearance
Order,24 FCC Rcd at3392,para.25.
'u These obligations are in addition to, and do not supplant, the certification and verification eligibility already
required by our rules for federal default states and any similar state rules for the non-federal default states. .tee, e.9.,
47 C.F.R. $ 54.410. On May 4,2010, the Cornmission asked the Federal-State Joint Board on Universal Service to
review the Commission's eligibility, verification, and outreach rules for the Lifeline and Link Up universal service
programs. See Federal-State Joint Board on Universal Service; Lifeline and Link Up, CC Docket No. 96-45, WC
Docket No. 03-109, Order, 25 FCC Rcd 5079 (2010).
31 See TracFone Forbearance Order,2O FCC Rcd at 15103-04, 15105, paras. 18, 25; Virgin Mobile Forbearance
Order,24 FCC Rcd at3392,para.25 &n.74.
3r Ser, e.g.,NASUCA Comments at 4-5 (arguing that forbearance is inappropriate unless i-wireless explains how it
will apply the Lifeline discount to its plans); NENA Comments at l-2 (arguing that carriers seeking forbearance
should commit to complyirrg with state-level 9l I and E91l obligations as a condition of forbearance).
t' Of course, if a state commission does not have jurisdiction to designate i-wireless as a limited-purpose ETC, we
will consider i-wireless's application as well as whether any additional obligations are necessary for that particular
designation to be in the public interest. See 47 U.S.C. $ 21a(eX6).
Federal Communications Commission FCC 10-117
additional obligations to redirect their arguments to ETC designation proceedings rather than this
proceeding.
19. Similarly, we are not persuaded by comments regarding the impact on the size of the
universal service fund and the associated contribution obligation if we grant the forbearance petition.ao
Granting forbearance here would allow i-wireless to compete with TracFone and Virgin Mobile (as well
as other ETCs) for the existing pool of low-income customers, and the size of that pool is determined by
Lifeline program eligibility requirements, not by the number of providers competing for those customers.
The additional choice and service options of another wireless reseller offering a service for low-income
consumers represents a significant benefit for consumers and is in the public interest. A new entrant
should incent existing wireless reseller ETCs to offer better service and terms to their customers, which
provides additional evidence that forbearance in the context of the Lifeline program outweighs the
potential costs.al
20. In conclusion, we find that conditionally granting i-wireless forbearance for purposes of
seeking ETC designation to participate in the Lifeline program only will ftirther the statutory goal of
providing low-income subscribers access to telecommunications and emergency services, while
protecting the universal service fund against waste, fraud, and abuse.a2 To the extent, however, that our
predictive judgment proves incorrect and these conditions prove to be inadequate safeguards, parties may
file appropriate petitions with the Commission and we have the option of reconsidering this forbearance
ruling.a3
B. Forbearance for Link Up
21. We decline to grant the request of i-wireless for forbearance from the facilities
requirement for the purpose of seeking ETC designation to receive Link Up support.aa Petitioners seeking
forbearance bear the burden of proof and must show that each of the statutory elements of forbearance is
met.as i-wireless has not done so in the context of the Link Up program. Specifically, i-wireless does not
a0 See Pennsylvania Commission Reply at 5*6.
ar For example, Virgin Mobile (the second wireless reseller to receive forbearance) has recently increased the
number of minutes it offers to low-income consumers through its Lifeline product to attract more customers.
Compare, e.g., Pennsylvania Commission Reply, CC Docket No. 96-45, at 6 n.l6 (filed July 20,2009) (noting that
Virgin Mobile planned to offer 120 free prepaid minutes to Lifeline customers), with Yirgin Mobile Petition for
Limited Designation as an Eligible Telecommunications Carrier in the State of Alabama, WC Docket No. 09-197, at
8(filedJan, 15,2010)(notingthatVirginMobileplanstooff'er200freeprepaidminutestoitsLifelinecustomers).
a2 i-wireless has committed to complying with all the obligations imposed on TracFone and Virgin Mobile as
conditions offorbearance. See Forbearance Petition at 13.
a3 See Petition.for Forbearance of the Verizon Telephone Companies Pursuant to 47 U.S.C. li t60(c), WC Docket
No.0l-338, Memorandum Opinion and Order, l9 FCC Rcd 21496,21508-09, para.26 & n.85 (200$;see also
Petilion ofSBC Communications lnc.for Forbearancefrom Structural Separalions Requirements of Section 272 of
the Communications Acl of 1934, As Amended, and Request.for Relief to Provide International Directory Assistance
Services, CC Docket No. 97- 172, Memorandum Opinion and Order, I 9 FCC Rcd 52 I l, 5?23-24, para. 19 & n.66
Q009; Cellnet Communications, Inc. v. FCC,l49 F.3d 429,442 (6th Cir. 1998).
a See Forbearance Petition at 8-14.
ot See, ",g., Petition to Establish Procedural Requiremenls to Govern Proceedings.for Forbearance under Section
l0 of the Communications Act of 1934, As Amended, WC Docket No. 07-267, Report and Order, 24 FCC Rcd 9543,
9554-55 , para. 20 (2009) ("We now state explicitly that the burden of proof is on forbearance petitioners at the
outset and throughout the proceeding."); Petitions of Qwest Corporation for Forbearance Pursuant to 47 U.S.C.
S 160(c) in the Denver, Minneapolis-St. Paul, Phoenix, and Sealtle Metropolitctn Stalistical Arerus, WC Docket No.
07-97, Memorandum Opinion and Order, 23 FCC Rcd I I 729, I I 750, I I 754-58, paras. 28, 36, 39 (2008) (noting
that Qwest had failed to meet its burden of persuasion regarding sufficiency of market share).
Federal Communications Commission FCC 10-117
address in its petition the differences between the Lifeline and Link Up programs, nor does the company
explain how the obligations conditional to Lifeline participation would apply in the context of Link Up.
Moreover, i-wireless does not explain how the public interest would be served by forbearing from the
facilities requirement in this context.a6 General references to the statutory goal of ensuring that low-
income consumers have access to telecommunications services do not suffice to replace a particularized
argument regarding the facts and policy sumounding the facilities requirement and the Link Up program.o'
We thus conclude that i-wireless has failed to meet its burden to show that forbearing from the facilities
requirement in the context of the Link Up program is in the public interest.a8
ry. ORDERING CLAUSES
22. Accordingly, IT IS ORDERED that, pursuant to the authority contained in sections 4(i),
4(i), 10, 214, and254 of the Communications Act of 1934, as amended, 47 U.S.C. $$ 154(i), fi44),214,
254, the petition for forbearance filed by i-wireless Telecom, LLC IS GRANTED IN PART to the extent
discussed herein and conditioned on fulfillment of the obligations set forth in this order and otherwise
DENIED.
23. IT IS FURTHER ORDERED that, pursuant to the authority contained in sections 4(i),
40), 10, 214, and254 of the Communications Act of 1934, as amended, 47 U.S.C. $$ 154(i), l54Q),214,
254,we forbear from applying sections 54.201(dXl) and 54.201(i) of the Commission's rules, 47 C.F.R.
$ 54.201(dXl), (i), to i-wireless Telecom, LLC to the extent discussed herein and conditioned on
fulfillment of the obligations set forth in this order.
24. IT IS FURTHER ORDERED that, pursuant to section 1.103(a) of the Commission's
rules, 47 C.F.R. $ L103(a), this order SHALL BE effective upon release.
FEDERAL COMMLTNICATIONS COMMISSION
Marlene H. Dortch
Secretary
a6 See Forbearance Petition at 8-14 (discussing Link Up only in the context of its discussion of Lifeline).
ai See Amendment of the Commission's Rules Concerning Maritime Communicatiors, PR Docket No. 92-257, Third
Report and Order and Memorandum Opinion and Order, l3 FCC Rcd 19853, 19879-80, para. 55 (1998)
("MariTEL's request cannot be granted because it is too vague, both as to the specific provisions from which we
should forbear from enforcing, and as to why forbearance would be in the public interest.").
o8 Because we find that i-wireless has not met its burden of proof on the third statutory element, we do not examine
whether it did so on the first or second elements.
EXHIBIT 1I
i-wireless' f,'CC-Approved Compliance Plan
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of the
Federal-State Joint Board on Universal Service
Telecommunications Carriers Eligible for
Universal Service Support
i-wireless, LLC Petition for Forbearance from 47
u.S.C. $ 2la(eXlXA)
)
)
) CC Docket No. 96-45
)
) WC Docket No. 09-197
)
)
)
)
I.WIRELESS. LLC'S REYISED COMPLIANCE PLAI\
i-wireless, LLC ("i-wireless" or the "Company"), by its attomey, hereby files its revised
plan outlining the measures it will take to implement the conditions imposed by the Federal
Communications Commission ( "Commission") in its recent Order, released June 25, 2010, in the
above-captioned maffer.r Given the severe economic environment that is forcing many lower-
income customers to forego wireless service, i-wireless respectfully requests expeditious approval
of this plan so that the Company, upon designation as an Eligible Telecommunications Carrier
("ETC"), may quickly deploy much-needed Lifeline services to many low-income customers. i-
wireless will provide Lifeline services under the brand name "Access Wireless."
BACKGROTII\D
The Commission's Order conditionally granted i-wireless'request for forbearance from the
Section 2la(e)(l)(A) requirement that a carrier designated as an ETC for purposes of federal
universal service support provide services, at least in part, over its own facilities, stating "i-wireless
may seek ETC designation to offer discounted services to qualified low-income consumers through
I See Federal-State Joint Board on (Jniversal Service; In the Matter of i-wireless, LLC Petition
for Forbearancefrom 47 U.S.C. $ 2la@(I)(A), Order, FCC l0-117, released June 25, 2010
("Order").
the universal service Lifeline program'."
The Commission found that a conditional grant of forbearance for i-wireless from the
facilities requirement of section Zla@) for the purpose of seeking ETC designation to provide
Lifeline support only "will further the statutory goal of providing low-income subscribers access to
telecommunications and emergency services, while protecting the universal service fund against
waste, fraud and abuse3." The Commission's grant of forbearance is subject to the following
conditions: (a) i-wireless providing its Lifeline customers with 9ll and Enhanced 9ll (Egll)
access regardless of activation status and availability of prepaid minutes; (b) i-wireless providing its
Lifeline customers with E9ll-compliant handsets and replacing, at no additional charge to the
customer, noncompliant handsets of existing customers who obtain Lifeline-supported service; (c) i-
wireless complying with conditions (a) and (b) as of the date it provides Lifeline service; and (d) i-
wireless obtaining a certification from each PSAP where the carrier seeks to provide Lifeline
service confirming that the carrier provides its customers with 9ll and E91l access or self-
certifying that it does so if certain conditions are met; (e) i-wireless requiring each customer to self-
certify at time of service activation and annually thereafter that he or she is the head of household
and receives Lifeline-supported service only from i-wireless; (f) i-wireless establishing safeguards
to prevent its customers from receiving multiple Lifeline subsidies from i-wireless at the same
address; and (g) i-wireless dealing directly with the customer to certif, and verifr the customer's
Lifeline eligibility.a The Commission required i-wireless to submit a plan describing the measures
it would take to implement each one of these conditions within thirty days of the release of the
Order.5 i-wireless is not seeking support for Link-up, as the Commission denied that portion of i-
2 Order at fl l.
' Order at fl 20.
a See Order at !f'tl I l, 16.
s See id.
wireless' request for forbearance.6
COMPLIANCE PLAII
i-wireless commends the Commission's commitment to a nationwide communications
system that promotes the safety and welfare of all Americans, including Lifeline customers.T i-
wireless will comply with all conditions set forth in the Order, the provision of this Compliance
Plan, all laws and regulations governing its provision of Lifeline-supported prepaid wireless service
to customers throughout the United States and in addition take the steps set forth herein.
I. Access to 911 and E9lL Services
In the Order, the Commission required i-wireless to provide its Lifeline customers with
access to 9l I and E91 1 services immediately upon activation of service, and stated that, in order to
demonstrate compliance with the condition, i-wireless must obtain certification from each PSAP
where it provides Lifeline service confirming that its customers receive 9l I and E91 I services. If
within 90 days of i-wireless' request, a PSAP has neither provided the certification nor made an
affirmative findingthatthe Company does notprovide its customers with 911 and E91l services
within the applicable service are4 the Order allowed i-wireless to self-certify that it meets the
requirements.s The Commission and consumers are hereby assured that all i-wireless customers
will have available access to emergency calling services at the time that Lifeline service is initiated,
and that such 9ll and E9ll access will be available from i-wireless handsets, even if the account
associated with the handset has no minutes remaining.
i-wireless can ensure the Commission that all Lifeline customers will have meaningful
access to emergency calling services at the time the customer activates Lifeline service, and that
such access will continue regardless of the customer's account status of the availability of prepaid
6 See Order at fl l.
7 See Order atn n.I See Order atfl 13.
minutes. The Company's existing practices currently provide access to 9l I and E91 I services to
the extent that these services have been deployed by its underlying carrier, Sprint Nextel (o'Sprint").
i-wireless also currently enables 9ll emergency calling services for all properly activated handsets
regardless of whether the account associated with the handset is active, suspended or terminated.
Finally, the Company transmits all 911 calls initiated from any of its handsets even if the account
associated with the handset has no remaining minutes.
To satisfr the conditions of the Order regarding 9l I and E9l l services, i-wireless will
implement the following measure prior to deploying Lifeline services in a given area. Initially, the
Company will confirm that its underlying carrier has deployed E9ll services in a specific PSAP
territory. i-wireless will obtain the requisite certification from each PSAP where it provides Lifeline
service confirming that its customers receive 9l I and E9l I services.' If within 90 days of receiving
the Company's request, a PSAP has neither provided such certification nor made an affrmative
finding that the Company does not provide its customers with 9ll and E9ll services within the
applicable service area, i-wireless will self-certiff that it meets the basic and E9l I requirements.
II. E9ll-CompliantHandsets
The Commission also conditioned its grant of forbearance determination on i-wireless
providing only E9l l-compliant handsets to its Lifeline customers.lo i-wireless will ensure that all
handsets used in connection with the Lifeline service offering will be E9ll-compliant. [n fact, i-
wireless' phones have always been and will continue to be 9l I and E9l l-compliant. i-wireless uses
phones from Sprint that have been through a stringent certification process in Sprint's handset
certification lab, which ensures that the handset models used meet all 911 and E91l requirements.
In i-wireless' five year history, only one handset model has failed the E9l1 process during the
'A form of this PSAP certification request is attached hereto as Exhibit A.
to See Order at fl I l.
handset lab certification, and that is a model the Company did not launch. As a result, any existing
customer that qualifies for and elects Lifeline service will already have a gll/Bgtl-compliant
handset, which will be confirmed at the time of enrollment in the Lifeline program. Furthermore, in
the event that an existing customer does not have an E9ll-compliant handset, the Company will
replace it with a new glltBgll-compliant handset at no charge to the customer. Any new customer
that qualifies for and enrolls in the Lifeline program is assured of receiving a9lllB9ll-compliant
handset as well, free of charge.
[I. CertificationoflifelineCustomers'Eligibility
To safeguard against misuse of the Lifeline service plan, the Order required i-wireless to
deal directly with the customer and require each customer to self-certify under penalty of perjury at
time of service activation and annually thereafter that they are the head of household and receive
Lifeline-supported service only from i-wireless.lr The Commission also required i-wireless to
establish safeguards to prohibit more than one supported i-wireless service at each residential
address.l2 Unless and until the Commission's issuance of new rules in its Lifeline rulemaking
proceeding that set forth different requirements, i-wireless proposes the following plan to implement
these certification and verification conditions (the plan would be modified to conform to any new
rules and orders, once issued and effective):
A. Policy
i-wireless will comply with all certification and verification requirements for Lifeline
eligibility established by states where it is designated as an ETC. In states where there are no state-
imposed requirements, i-wireless will comply with the certification and verification procedures in
effect in that state as reflected on the website of the Universal Service Administration Company.
" See Order at 16.t2-Jee m.
For any states which do not mandate Lifeline support and/or which do not have established rules of
procedure in place, i-wireless will certifr at the outset and will verify annually consumers' Lifeline
eligibility in accordance with the Commission's requirements.
B. Certification Procedures
i-wireless will implement certification procedures that enable consumers to demonstrate
their eligibility for Lifeline assistance by contacting i-wireless in person or via telephone, facsimile,
or the internet. At the point of sale, consumers will be provided with printed information describing
i-wireless' Lifeline program, including eligibility requirements, and with instructions for enrolling.
Consumers will be signed up in person or directed, via company literature, collateral or advertising,
to a toll-free telephone number and to i-wireless' website, which will contain a link to information
regarding the Company's Lifeline service plan, including a detailed description of the program and
state-specific eligibility criteria. i-wireless' application form for its Access Wireless service will
identifr that it is a "Lifeline" application. i-wireless understands and accepts the Commission's
requirement that the Company have direct contact with all customers applying for participation in
the Lifeline program.'' i-wireless will have direct contact with all customers applying for Lifeline
service, either in person through its employees or agents or via the telephone (including facsimile)
or mail. i-wireless will provide Lifeline-specific training to all personnel, whether employees or
agents, that interact with actual or prospective consumers with respect to obtaining, changing or
terminating its Lifeline services.
Consumers who do not complete the application process in person must return the signed
application and support documentation to the Company by mail, fax, email or other electronic
transmission. The Company will accept electronic signatures that meet the requirements of the
Electronic Signatures in Global and National Commerce Act, 15 USC 7001-7006, and any
13 See Order at\ 16.
applicable state laws. Processing of consumers' applications, including review of all application
forms and relevant documentation, will be performed under i-wireless' supervision by managers
experienced in the administration of the Lifeline program.
i-wireless will ensure that all required documentation is taken care of properly by using
state-specific compliance checklists. For states with program-based eligibility criteria, the form will
list each of the qualiffing programs, and the applicant will be required to identify the program(s) in
which they participate, and to fumish proof that they currently participate in such program(s),
regardless of whether such proof is required pursuant to state law. For states with income-based
eligibility criteria, the applicant will be required to certifr under penalty of perjury that their
household income does not exceed the relevant threshold (e.g., l35Yo of the Federal Poverty
Guidelines for federal default states) and will be required to provide proof of income-based
eligibility. Notwithstanding the foregoing with respect to program or income eligibility, for states
that require i-wireless to enroll subscribers identified by the state or as eligible in a state database, i-
wireless may continue to rely on the state identification or database. In addition, the Lifeline
application form will include a certification section where the applicant must attest and sign under
penalty of perjury that the applicant's representations are true and correct. Applicants will also be
required to certify under penalty of perjury that they are head of their household and receive
Lifeline-supported service only from i-wireless. Penalties for perjury will be clearly-stated on the
certification form, as required by the Order.ta i-wireless will use substantiatly the fotlowing form of
its certification, printed in at least l0 point font:rs
ta See Order at\ 17.
't Among other things, i-wireless may, at its option, periodically update or change the list of
Lifeline services identified in certification item no. 3 to reflect its judgment as to the most
common prepaid wireless Lifeline products offered in its service areas, taken together, under
names that are not readily identifiable as Lifeline services.
By signing below, I certifr under penalty of perjury - (additionally, please initial each
of the 5 statements below)
1. The information contained within this application is true and correct. I
acknowledge that providing false or fraudulent documentation in order to receive
assistance is punishable by law.
2. I understand that Lifeline is only available for one phone line per household,
whether landline or wireless. I am the head of household and will only receive
Lifeline from Access Wireless.
3. I am not currently receiving a Lifeline telephone service from any other landline or
wireless telephone company. (Some Lifeline services are not marketed under a
"Lifeline" name; these include Lifeline services sold under the names Life Wireless,
TAG Mobile, Reachout Wireless, Assurance Wireless and Safelink.) _
4. Furthermore, I certifr that I will only use this phone for my family's own use and
will not resell it.
5. I will notify Access Wireless immediately if I no longer qualifu for Lifeline, or if I
have a question as to whether I would still qualify.
Perjury and false statements are punishable by fines and/or imprisonment.
Signature (required) Date
Finally, the application forms will require each applicant to provide their name and primary
residential address. i-wireless will incorporate this information into its customer information
database. Prior to initiating service for a customer, the Company will check the address of each
Lifeline applicant against its database to determine whether or not it is associated with a customer
that already receives i-wireless Lifeline service, and will then review the application to ascertain
whether the applicant is attempting to receive Lifeline-supported service for more than one handset
associated with the address. i-wireless will deny the Lifeline application of any such individual and
advise the applicant of the basis for the denial. In addition, prior to requesting a subsidy, i-wireless
will process and validate i-wireless' subsidy data to prevent: (l) Duplicate Same-Month Lifeline
Subsidies ("Double Dip," i.e., any household that is already receiving a Lifeline subsidy from i-
wireless will be automatically prevented from receiving a second lifeline subsidy in that same
month); and (2) Inactive lines receiving subsidy (r.e., systems compare all subsidy requests to
underlying network status to ensure that subsidies are requested only for active lines).16 i-wireless
shares the Commission's concern about abuse of the Lifeline program and is thus committed to the
safeguards stated herein, with the belief that the procedures it will implement will prevent i-wireless
customers from engaging in such abuse ofthe program, inadvertently or intentionally.
C. Annual Verification Procedures
As required by the Commission's Order, i-wireless will require every consumer enrolled in
the Lifeline program to veriff on an annual basis that they are the head of their household and only
receive Lifeline service from i-wireless.rT i-wireless will notift each participating Lifeline
consumer prior to their service anniversary date that they must confirm their continued eligibility in
accordance with the applicable requirements. This notification will be mailed via the U.S. Postal
Service to the address the subscriber has on record with i-wireless. The notice will explain the
actions the customer must take to retain Lifeline benefits, when Lifeline benefits may be
terminated, and how to contact i-wireless. Customers will have 60 days to complete the form,
certifu under penalty of perjury that they are the head of household and receive Lifeline service
only from i-wireless, and return the form to i-wireless by mail. Anyone who does not respond to
the mailing and certiff their continued eligibility will be removed from the Lifeline program.
Currently, customers will be required to complete the verification process by mail;
however, i-wireless may offer additional options, such as web-based methods, in the future. Such
verification will be required in order for the consumer to continue to receive free Lifeline service or
16 See Usage Policy, below.
t7 See Order at\ 16.
to purchase prepaid airtime from i-wireless at the discounted rate only available to those customers
who are enrolled in its Lifeline program.
[V. Additional Measures to Prevent Waste, Fraud, and Abuse
A. Non-usage Policy
i-wireless will implement a non-usage policy whereby we will identiff Lifeline
customers that have not used the Company's Lifeline service for 60 days, and cease to claim
Lifeline reimbursements for such customers if they do not use their service within a 30-day grace
period following the initial 60-day non-usage period.r8 Specifically, if no usage appears on an i-
wireless Lifeline customer's account during any continuous 60-day period, i-wireless will
promptly notiff the customer that the customer is no longer eligible for i-wireless Lifeline
service subject to a 30-day grace period. During the 30-day grace period, the customer's account
will remain active, but i-wireless will engage in outreach efforts to determine whether the
customer desires to remain on the Company's Lifeline service. If the customer's account does
not show any customer-specific activity during the grace period (such as making or receiving a
voice cal[, sending a text message, downloading data or adding money to the account), i-wireless
will deactivate Lifeline services for that customer. In addition, i-wireless will not seek to recover
a federal Universal Service Fund subsidy for the minutes provided to the customer during the
grace period or thereafter report that customer on its USAC Form 497 unless the customer re-
initiates service.
r8 i-wireless will consult with the state commissions (PUCs) in the states where it provides
Lifeline services regarding implementation of the policy described above. i-wireless expects that
certain state PUCs or similar agencies may seek to incorporate state-specific variations to the
policy. Consequently, i-wireless may modiff the parameters of the inactivity policy described
herein after consultation with the respective state PUCs.
l0
B. Customer Education with Respect to Duplicates
To supplement its verification and certification procedures, and to better ensure that
customers understand the Lifeline service restrictions with respect to duplicates, i-wireless will
implement 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.
a) Call Center Scripts - i-wireless will emphasize the "one Lifeline phone per
household" restriction through its interaction with the potential customer at the call
center. The call center introduction script substantially in the form that i-wireless
would use is attached as Exhibit B.
b) Sales Scripts - i-wireless will also emphasize the "one Lifeline phone per household"
restriction through its direct sales contact with the potential customer. The sales
training materials will 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.
Affached as Exhibit C is a sample of training material that would meet the
requirements of this provision.
c) Marketing, Advertising and Website Content - i-wireless, in its marketing materials,
will reinforce the limitation of one Lifeline phone per household. The following
statement will appear in conspicuous place in bold font in an offseffing color,
minimum l0 point font, to ensure it is not overlooked.
Note: By law, the Lifeline program is only available for one phone per household
This statement will also appear on the company's website (www.accesswireless.com)
during the customer information/education cycle. At the point on its website when a
customer inputs his/her zip code to verify that Access Wireless/i-wireless offers
service in their area, i-wireless would display the above message in the section where
the website explains the service and rate plan options. The message would flash to
draw attention to it. In addition, i-wireless will include in its printed materials and
website substantially the following statement'Not all Lifeline supported programs
are identified as 'Lifeline' and may be marketed under other brand names."
D. Cooperation with state and federal regulators
i-wireless has and will continue to cooperate with federal and state regulators to prevent
waste, fraud and abuse, including:
. Providing state commissions (PUC), the FCC or USAC upon request with data
ll
that will enable that state, the FCC or USAC to determine whether some
consumers are enrolled in more than one Lifeline program. Specifically, i-
wireless agrees to make available state-specific customer data, including name
and address, upon request to each state PUC where it operates, the FCC or USAC
for the purpose of permitting the PUC, FCC or USAC to determine whether an
existing Lifeline customer receives Lifeline service from another carrier, and will
participate in such a duplicate resolution process, provided that costs for
participation are reasonable or defrayed through the universal service contribution
mechanisms;
Promptly investigate any notification that it receives from a state PUC, the FCC
or USAC that one of its customers already receives Lifeline service from another
carrier;
Immediately deactivate a customer's Lifeline service and no longer report that
customer on USAC Form 497 if i-wireless' investigation, a state, the FCC or
USAC concludes that the customer receives Lifeline services from another carrier
in violation of the Commission's regulations and that i-wireless' Lifeline service
should be discontinued such as a de-enrollment notification pursuant to the FCC's
June 17, 201I Report and Order (Section III, B.).
V. Included Usage
iwireless will offer at least one Lifeline plan that provides consumers with at least 250
included minutes-of-use per month at the lowest end user rate permitted under FCC rules. This
provision will expire 36 months from the date of approval of this Compliance Plan.
CONCLUSION
i-wireless submits that its Compliance Plan fully satisfies the conditions set forth in the
Commission's Order granting forbearance to the Company. Implementation of the procedures
described herein will promote public safety and should ensure that Lifeline customers have access
to 911 and E911 services while safeguarding against misuse of the Company's Lifeline services.
Accordingly, i-wireless respectfully requests that the Commission expeditiously approve its
Compliance Plan so that i-wireless may begin providing the benefits of much-needed Lifeline
service to qualifying low-income consumers as quickly as possible.
t2
Respectfu lly submitted,
I-WIRELESS, LLC
lsl
Lance J.M. Steinhart
Lance J.M. Steinhart, P.C.
1 725 Windward Concourse
Suite 150
Alpharetta, Georgia 30005
[phone]
Its Counsel
Dated September 9,20L1
13
EXHIBIT A
IDate]
Public Safety Answering Point Coordinator
Name
Address Line 1
Address Line?
[City], [state] [zip]
PSAP Certification for i-wireless Lifeline Program
Dear PSAP Coordinator,
This letter is being sent to inform you that i-wireless, LLC ("i-wireless") plans to
offer Lifeline service in your state in the near future, and we are seeking your
assistance with PSAP certification.
Lifeline provides affordable phone service for more than 7 million low-income
Americans. Eligible consumers receive approximately a $15 discount off of their
monthly telephone service charges. Presently, only about one-third of the Lifeline
eligible households subscribe to the program. i-wireless is pleased to be one of the
companies to offer Lifeline in your state.
Before we can offer this service in [state], the FCC requires that i-wireless receive
the following:
L. Forbearance from the facilities based services requirement of the
Communications Act of 1934
2. Eligible Telecommunications Carrier ["ETC") status for your state
3. Certification from Public Safety Answering Points ("PSAPs") in areas
where i-wireless will offer Lifeline, confirming that9Ll/E9L1 access will
be available to Lifeline customers regardless of activation status and
availability of prepaid minutes
On fune 22,20L0 the FederalCommunications Commission [FCC) granted i-wireless
forbearance from the facilities-based services requirement (see enclosed
Forbearance Order), and i-wireless is currently awaiting ETC status for the state of
Istate].
Although i-wireless is still awaiting ETC status for your state, we are moving
fbrward with the PSAP certification process in order to be prepared to launch
Lifeline in your area soon after ETC status in received. i-wireless is requesting your
certification based on the information you receive in this letter or any other
information you may request of us.
Please keep in mind that i-wireless provides prepaid wireless telecommunications
services to customers using the Sprint PCS network. Sprint Nextel is a nationwide
facilities-based carrier that provides wholesale capacity to resellers such as i-
wireless. All i-wireless 9 1 1/E91 1 calls are routed by Sprint to the appropriate PSAP,
the same way that Sprint routes its own 911/E911 calls.
Sprint has deployed the FCC required Phase II caller location functionality on their
CDMA network in your area, which enables Sprint and i-wireless to provide E91L
access. In addition, all i-wireless customers will be provided with E9L1 compliant
handsets.
Please review and sigtr the enclosed PSAP certification form and return it in the
postage-paid envelope provided. i-wireless will keep this form on file in case the
state or federal commissions request a review of this documentation. If i-wireless
does not receive your signed form (or documentation stating that i-wireless
does not provide 9LL/E9LL functionality in your area) within the next 90
days, i-wireless is permitted to and will self-certity 9Ll/8911 compliance for
your area.
If you have any questions relating to the certification process or you would like to
request a test handset, please contact [i-wireless contact] at i-wireless via email
[email address), regular mail or fax (fax numberJ. Please include your PSAP
jurisdiction along with your name on the attached form. Please call me [phone
number) should you have any questions or requests.
Thank you for your assistance in enabling i-wireless to offer Lifeline to low-income
households in your area.
Sincerely,
Ii-wireless contact]
i-wireless, LLC
To: [i-wireless contactl
i-wireless Lifeline Program
PSAP Certification Form
State of [state]
PSAP Name/f urisdiction:
PSAP Coordinator:
Business Address:
I am the PSAP Coordinator for the above listed Public Safefy Answering Point ("PSAP'] and I am
responsible for 971/E977 service in accordance to the rules and regulations ofthe Federal
Communication Commission (FCCJ.
i-wireless has informed me that on June 22,2070 the Federal Cornmunications Commission (FCC)
granted thern forbearance from the facilities-based services requirernent of the Communications Act
of 1934, and they are currently awaiting ETC status for the state of [state]. We understand that the i-
wireless designation as an ETC is subject to conditions including certification from PSAPs where they
will offer Lifeline service, confirming that Lifeline customers will have 9L1/8911 access regardless of
activation status and availability of prepaid miuutes.
i-wireless has also confirmed that they provide prepaid wireless telecommunications seryices to
customers using the Sprint PCS network and that Sprint Nextel is a nationwide facilities-based
carrier that provides wholesale capacity to resellers such as i-wireless. It is understood that i-
wireless 971/E9l1calls are routed by Sprint to the appropriate PSAP, the same way that Sprint
routes its own 911/E911calls.
Finally, i-wireless communicated that Sprint has deployed the FCC required Phase II caller location
functionality on their CDMA network in my area, which enables Sprint and i-wireless to provide E911
access, and that all i-wireless customers will be provided with E911 cornpliant handsets.
Based on all of the information provided by i-wireless and belie{, as PSAP Coordinator, I hereby
certify that i-wireless has provided sufficient proof that they will comply with the FCC requirement to
provide Lifeline customers with 911/ E911 service regardless of activation status and availability of
prepaid minutes.
Date Signature of PSAP Coordinator
EXHIBIT B
Access Wireless (i-wireless Lifeline) CaIl Center Script
Call Initiation * Pnrt I
Created February 4, 2011
Updated May 261 2011. for discussions with the FCC
Greeting: noThank you for calling Access Wireless. This is (Agent Name). May I please
have your last nanne and the state you are calliug from?"
** Agent - Perform customer search while asking cusiomer **
r "Are you calling for a new application or to check status?
r If status of application: "May I please have your address?"
. If new application: Validate that they are the head of household and that they are not
currelrtly receiving a Lifeline subsidized phone with the following line cf questioning:
a) "Do you currently have wireless or home phone service?" (if no, skip (b) - (e)
b) If yes: "Is that [wireless or home phone] service a subsidized seryice or do you pay
full price?"
c) If subsidized: "By law, thc Lifeline program is only available for one phone per
household. Do you know if your current phone is subsidized under the Lifeline
program?"
d) If they are unsure: "'Who is your provider for that service?" (Safelink, Assurance,
TSI / Nexus Communicatiotls, Smitir Bagley or DPI only offer Lifeline $o go to (e) -
if a more ambiguous provider. e.9., Verizon, Pacific Bell or lllinois Bell, try to
question further to determine if they have Lifeline).
e) If it is Lifeline: "We cannot provide you with a second Lifeline phone. If there is a
problem with that service or you want to be on our service, you must first discorurect
your service with your other provider and then call back to establish service with us."
tlf it is evident that they don't already have Lifeline servise then click on add new
customer and fill out appropriate information.
EXHIBIT C
Access Wireless (i-wireless Lifeline)
Sales Trainin g Materials
Updated May 26,2011 for discussions with the FCC
Refer to the state specific one page Sales Informatior shett for state specific, progrsm
information.
If custorner is int*rested in Lifeline service and is eligible undsr one of the programs or thr
income threshold listed in the "Who is cligibtc ta rceeive an Ascess \ilircless phone and Frec
Service?" section of the state specific information sheet, please complete the followlng
procedures:
l. Ask the following questions:
a) "Do you currently have wireless or trome phone service'I" (if no, skip (b) * (f)
b) If yes: "Is that [wireless or home phone] service a subsidized or no-charge
service, or do you pay full price'I"
If subsidlzed: "By law, the Lifelin* program is only available for one phone
per household. Do you know if your cuncnt phone is subsidized under the
Lifeline program?"
If they are unsure: "'Who is your provider for that service?" (Safelink,
Assurance, TSI / Nexus Communications, Smith Bagley or DPI only offer
Lifeline so go to (e) - if a more ambiguous provider, e.g., Verizon, Pacific
Bell or lllinois Bell, try to dig further to determine if they have Lifeline).
If it is Lifeline; "We cannot provide you with a second Lifeline phone. If
there is a problem with that service or you want to be on our service, you must
first disconnect your service with your other provider and then call back to
establish service with us."
If it is evident that they don't already have Lifelins servics, tlcn procced to 2.:
2. Click on "check cus(omer's address" to perform an address check to insure there isn't
already an Access Wireless phone registered to that address.
a) If there is an active Access Wireless phone registered at that address, then
thank customer for their interest, explain the situation and say "by law, the
Lifeline program is only available for one phone per household".
b) If there isn't an active Access Wireless phone registered at that adclress,
proceed to 3.
3. Assist cu$torner in filling out the state ;pecific application. Use the application
guidelchecklist to make sure it is filled out appropriately. Review the documentation
for program/income proof closely against the guidelines to make sure the
documentation meets the requirements.
c)
d)
e)
ffiI-ilffiS$ \VI R E LTSS
lVhat is Access Wireles by i-wireless?
Access Wireless from i-wireless is a part of the Lifeline Assistance program designed to ensure
that quality telecommunications services are available to low-income customers at reasonable and
affordable rates. Access provides program and income-eligible customers with a free wiretess
phone and free monthly service. The phone offers in-demand features: voicemail, text, three-way
calling, call waiting, caller ID and access to 9l l.
Who ls eligible to recrive on Access Wireless phone and Free Service?
Eligibility guidelines vary by state, but in lllinois, individuals qualify if they participate in a
public assistance program such as Food Stamps (SNAP), Medicaid, Low Income Home Energy
Assistance Program (LIHEAP), National Frce SchoolLunch, Federal Housing/Section 8
Assistance, Supplemenul Security Income (SSI; Not the same as Social Security Benefits) or
Temporary Assistance to Needy Families (TANF).
N{}tsr Lifeline is only aveilable to the head-of-household. Furthermore. there is a limit of
anly one Lifeline phone 1xr houschold. Please makt sure that the custom€r docs not
nlrendy receive a Lifeline suhsidy from aro(her provitler
How to Apply?
In lllinois, applicants must provide proof of program participation and complete an application
(attached). Program documents submitted must be "a valid, dated copy of a document issued by a
qualifying agency." It also needs to show the individual's name and addrcss. Typically this
needs to be a dated enrollment lener showing the name and address of the eligible individual.
Submission of a program card typically will not be sufficient because many of the enrollment
cards do not show the name, address, or date of eligibility. Many of the state issued cards (i.e.
food stamp) only display an ID number similar to the debit card look.
Y['hat's included with my Access phone service?
Access offers eligible customers a free wireless phone and free service. The minutes can be used
for local or domestic long distance calling. There are no bills, no long-term contracts, no
activation fees, and no recurring fees or surcharges for Access Wireless custorrcrs. Upon
verification, Access Wireless u.sers may renew their service on an annual basis.
Customers may choose betwom 3 plan optiore:
a. f50 FREE MINUTES: These minutes will be added on the first day of the monthly
service cycle, and may be used for making or receiving voice calls. All incoming text
messages and calls to Customer Care are FREE. Unused minutes will be carried over to
the next month.
b. 250 FREE MINI-ITES: These minutes will be added on the first day of the monthly
service cycle, and may be used for making or receiving voice calls. All incoming and
outbound text messages will be deducted at a rate of I minute per text. All calls made to
Customer Care &om the handset will be deducted from the monthly minute allocation.
All unused minutes expire at the end of the month. If you run out of minute.s within the
monthly service period and you have money on your account, each mirute of talk or text
nressage will cause a deduction of $0.10 from your account.
c. $15 Credit - Customers can apply a $I5 credit (free to the customer) to any retail plan of
their choice. In this way, Access Wireless customers can opt into the 200 minute,
unlimited text messaging and 200I\A of data plan for only $10 + tax (this plan is
normally $25 less the $15 credit).
Free Phone
+ Free Monthly Service Plan
op'oru 0
H i'ffi#fr]::I,*.,.,,* offeronv
oprtoN O 250 M in UteS/Ief,{g rveryvront,
You may qualifi for Lifeline service with Access Wkeless' if you participate
in public assistance programs such as SNAP/Food Stamp1 Medicaid or SSl.
Call 1-BBB-450-1 B3B.
G occess
\VIRELESS.
A government-funded Lifeline Assistance Program.
EXHIBIT 13
2011 Lifeline Participation Rates by State
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ALBNIDXC
ARCOTDXC
ELBAIDXC
HOWEIDXC
MALTIDXC
MLCYIDXC
MOORIDXC
CMBRIDXC
BRUNIDXC
GRVWIDXC
RCFDIDXC
ABRDIDXC
cscDrDxc
DNLYIDXC
HMDLIDXC
HRBNIDXC
MCCLIDXC
MRNGIDXC
NWMDIDXC
PARMIDXC
SWETIDXC
WLDRIDXC
DRGSIDMA
PARSIDXC
FRLDIDXX
FILRIDAA
HLSTIDXC
STATIDMA
FRFDWAXA
NWPTWAXX
BWWIDXX
CLFKIDXX
CRALIDXX
GENSIDXX
HOPEIDXX
HRSNIDXA
HYLKIDXX
MSCWIDXX
PLMRIDXX
PRLKIDXX
PRRVIDXX
PSFLIDXX
PTLTIDXX
RTHDIDXX
SNPNIDXX
SPLKIDXX
WIRE CENTER
ALBION
ARCO
ELBA
ARCO
MALTA
MALAD
ARCO
INDIAN VLY
BRUNEAU
GRAND VIEW
RICHFIELD
ABERDEEN
CASCADE
DONNELLY
HOMEDALE
HORSEHBEND
MCCALL
MARSING
NEWMEADOWS
PARMA
SWEET
WILDER
DRIGGS
PARIS
FRUITLAND
FILER
HOLLISTER
ST ANTHONY
ROCK CREEK
ALBENI
BAWIEW
CLARK FORK
COERDALENE
GENESEE
HOPE
HARRISON
HAYDENLAKE
MOSCOW
PLUMERWRLY
PRIESTLAKE
PRIEST RIV
POST FALLS
POTLATCH
RATHDRUM
SANDPOINT
SPIRITLAKE
ItEC
ALBION TELEPHONE CO. DBA ATC COMMUNICATIONS
ALBION TELEPHONE CO. DBA ATC COMMUNICATIONS
ALBION TELEPHONE CO. DBA ATC COMMUNICATIONS
ALBION TELEPHONE CO. DBA ATC COMMUNICATIONS
ALBION TELEPHONE CO. DBA ATC COMMUNICATIONS
ALBION TELEPHONE CO. DBA ATC COMMUNICATIONS
ALBION TELEPHONE CO. DBA ATC COMMUNICATIONS
CAMBRIDGE TELEPHONE COMPANY
CENTURYTEL GEM STATE INC-ID DBA CENTURYLINK. ID
CENTURYTEL GEM STATE INC-ID DBA CENTURYLINK. ID
CENTURYTEL GEM STATE INC.ID DBA CENTURYLINK - ID
CITIZENS TELECOM IDAHO-FRONTIER COMM OF IDAHO
CITIZENS TELECOM IDAHO-FRONTIER COMM OF IDAHO
CITIZENS TELECOM IDAHO-FRONTIER COMM OF IDAHO
CITIZENS TELECOM IDAHO-FRONTIER COMM OF IDAHO
CITIZENS TELECOM IDAHO-FRONTIER COMM OF IDAHO
CITIZENS TELECOM IDAHO-FRONTIER COMM OF IDAHO
CITIZENS TELECOM IDAHO-FRONTIER COMM OF IDAHO
CITIZENS TELECOM IDAHO.FRONTIER COMM OF IDAHO
CITIZENS TELECOM IDAHO.FRONTIER COMM OF IDAHO
CITIZENS TELECOM IDAHO.FRONTIER COMM OF IDAHO
CITIZENS TELECOM IDAHO-FRONTIER COMM OF IDAHO
COLUMBINE TELCO DBA SILVER STAR COMMUNICATIPMS
DIRECT COMMU NICATIONS ROCKLAND, INC.
FARMERS MUTUAL TELEPHONE CO.
FILER MUTUAL TELEPHONE CO.
FILER MUTUAL TELEPHONE CO.
FREMONTTELCOM CO
FRONTIER COMMUNICATIONS NORTHWEST INC. - WA
FRONTIER COMMUNICATIONS NORTHWEST INC. - WA
FRONTIER COMMUNICATIONS NORTHWEST, INC. . ID
FRONTIER COMMUNICATIONS NORTHWESI INC. - ID
FRONTIER COMMUNICATIONS NORTHWESI INC. - ID
FRONTTER COMMUNICATIONS NORTHWESI lNC. - lD
FRONTIER COMMUNICATIONS NORTHWESI INC. - ID
FRONTIER COMMUNICATIONS NORTHWEST, INC. . ID
FRONTIER COMMUNICATIONS NORTHWEST, INC. - ID
FRONTIER COMMUNICATIONS NORTHWEST, INC. - ID
FRONTIER COMMUNICATIONS NORTHWEST, INC. - ID
FRONTIER COMMUNICATIONS NORTHWESI INC. - ID
FRONTIER COMMUNICATIONS NORTHWEST, INC. - ID
FRONTIER COMMUNICATIONS NORTHWEST, INC. - ID
FRONTIER COMMUNICATIONS NORTHWEST, INC. - ID
FRONTIER COMMUNICATIONS NORTHWEST, INC. - ID
FRONTIER COMMUNICATIONS NORTHWEST, INC. - ID
FRONTIER COMMUNICATIONS NORTHWEST, INC. - ID
cLU
LENRIDXA
WRLKIDXC
HAMRIDXC
TRTNIDXC
JLTTIDXA
TROYIDXX
MNDKIDXC
OKLYIDXC
PAULIDXC
RPRTIDXC
AMFLIDMA
BLFTIDMA
BLSSIDMA
BNCRIDMA
BOISIDMA
BOISIDNW
BOISIDSW
BOISIDWE
BRLYIDMA
BUHLIDMA
CLWLIDMA
CSFRIDMA
DECLIDMA
DWNYIDMA
DYTNIDMA
EAGLIDNM
EDHZIDMA
EMMTIDMA
FKLNIDMA
FRTHIDMA
GDNGIDMA
GLFYIDMA
GRACIDMA
HALYIDMA
HGMNIDMA
IDCYIDMA
IDFLIDMA
INKMIDMA
JERMIDNM
KMBRIDMA
KTCHIDMA
KUNAIDMA
LAPWIDOl
LHSPIDMA
LSMNIDMA
LSTNIDSH
WIRE CENTER
LENORE
WARM LAKE
HAMER
TERRETON
JULIAETTA
TROY
MINIDOKA
OAKLEY
PAUL
RUPERT
POCATELLO
BLACKFOOT
TWIN FALLS
POCATELLO
BOISE
BOISE
BOISE
BOISE
BURLEY
TWIN FALLS
CALDWELL
TWIN FALLS
BURLEY
POCATELLO
POCATELLO
BOISE
TWIN FALLS
EMMETT
POCATELLO
IDAHOFALLS
TWIN FALLS
MT HOME
POCATELLO
KETCHUM
TWIN FALLS
BOISE
IDAHOFALLS
POCATELLO
TWIN FALLS
TWIN FALLS
KETCHUM
BOISE
LAPWAI
POCATELLO
RIGBY
LEWISTON
ItEC
INLAND TELEPHONE CO.
MIDVALE TELEPHONE EXCHANGE, INC.
MUD LAKE TELEPHONE COOPERATIVE ASSOICATION, INC.
MUD LAKE TELEPHONE COOPERATIVE ASSOICATION, INC.
POTLATCH TELEPHONE CO., INC.
POTLATCH TELEPHONE CO., INC.
PROJECT MUTUAL TELEPHONE COOP. ASSOCIATION, INC.
PROJECT MUTUAL TELEPHONE COOP. ASSOCIATION, INC.
PROJECT MUTUAL TELEPHONE COOP. ASSOCIATION, INC.
PROJECT MUTUAL TELEPHONE COOP. ASSOCIATION, INC.
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
CLtI
MCCMIDMA
MDTNIDMA
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MTHOIDMA
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MTPLIDMA
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PYfiIDMA
RBRTIDMA
RGBYIDMA
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RVSDIDMA
RxBGIDMA
SDSPIDMA
SHLYIDMA
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STARIDNM
THTCIDMA
TWFLIDMA
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WNDLIDMA
GLFYIDCO
FRDMWYXC
WIRE CENTER
POCATELLO
BOISE
MELBA
BOISE
MURTAUGH
MT HOME
MT HOME
POCATELLO
NAMPA
NEW PLYMTH
POCATELLO
POCATELLO
POCATELLO
PAYETTE
RIGBY
RIGBY
IDAHOFALLS
BLACKFOOT
IDAHOFALLS
POCATELLO
IDAHOFALLS
TWIN FALLS
BOISE
POCATELLO
TWIN FALLS
WEISER
TWIN FALLS
PRAIRIE
ALPINE
ILEC
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
qWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
RURAL TELEPHONE CO.
SILVER STAR TELEPHONE CO., INC.
PaulMcAleese
Paul McAleese, CEO and co-founder of i-wireless, LLC, has 20 years of experience in the wireless
telecommunications industry.
ln 2005, Mr. McAleese co-founded i-wireless LLC, a privately held company with 51-200 employees. i-
wireless is the private-label wireless service sold exclusively within the Kroger family of stores. As one of
the nation's largest grocery retail chains, Kroger operates over 2500 stores under two dozen local
banner names including: Kroger, Ralphs, Fred Meyer, Food4less, Fry's, King Soopers, Smith's, Dillons,
and QFC.
Unique among US wireless operators, i-wireless offers Kroger customers the ability to earn Free Minutes
loyalty rewards on their i-wireless phone when they use their Shopper's card on qualifying purchases,
potentially eliminating their cell phone bill altogether.
i-wireless is proud to count amongst its investors Spark Capital, Sprint, and the Kroger Company.
CEO and co-founder
i-wireless LLC
July 2005 - Present
Chief Marketing Officer
Cincinnati Bell
January 2OO4 - July 2005
General Manager, Consumer Markets
02 PLC, London
June 1998 - December 2003
Vice-President, Consumer Marketing & Sales Rogers Wireless August L992 - May 1998
John Willis
John Willis is Chief Operating Officer of i-wireless LLC, a privately held company with 51-200 employees.
i-wireless is the private-label wireless service sold exclusively within the Kroger family of stores. As one
ofthe nation's largest grocery retail chains, Kroger operates over 2500 stores under two dozen local
banner names including: Kroger, Ralphs, Fred Meyer, Food4less, Fry's, King Soopers, Smith's, Dillons,
and QFC.
Prior to his role as COO, Mr. Willis served as Vice President of Operations for i-wireless, LLC. Before
joining i-wireless, LLC in 2006, Mr. Willis served as Director at Cincinnati Bell and Manager at Verizon
Wireless.