20151020Exhibit 7 CA ETC Approval 9.11.14.PDF

Resolution T- 17449 Date of Issuance: 09/12/2014
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107222695

PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

R E S O L U T I O N

Resolution T-17449. This Resolution conditionally grants the request of i-wireless,
LLC to be designated as an Eligible Telecommunications Carrier to provide only
federal Lifeline wireless service in specified areas of California.

Summary

By this Resolution, the California Public Utilities Commission (CPUC or Commission)
conditionally grants the request of i-wireless, LLC (i-wireless) (U-4372-C), a wireless
carrier under the brand designation “Access Wireless,” to be designated as an Eligible
Telecommunications Carrier (ETC) to provide only federal Lifeline wireless service to
qualifying customers in California in the service areas of the Uniform Regulatory
Framework (URF) carriers1 excluding the Small Local Exchange Carriers (Small LECs)2
service areas.3 i-wireless seeks federal Lifeline support only and does not seek California
LifeLine fund support. The request is consistent with the Federal Communications
Commission’s (FCC) ETC and Lifeline requirements and the Commission’s ETC,
LifeLine and operating requirements. We find that i-wireless’ ETC request is reasonable
and consistent with the public interest and should be conditionally granted to the extent
allowed by this Resolution.

1 The URF carriers are AT&T California, Verizon California, Surewest Telephone, Frontier Communications of
California, and Frontier of the South West. 2 The Small LECs group is composed of Calaveras Telephone Co. (U-1004-C), Cal-Ore Telephone Co. (U-1006-C),
Ducor Telephone Co. (U-1007-C), Foresthill Telephone Co. (U-1009-C), Happy Valley Telephone Co. (U-1010-C),
Hornitos Telephone Co. (U-1011-C), Kerman Telephone Co. (U-1012-C), Pinnacles Telephone Co. (U-1013-C),
Ponderosa Telephone Co. (U-1014-C), Sierra Telephone Co. (U-1016-C), Siskiyou Telephone Co. (U-1017-C),
Volcano Telephone Co. (U-1019-C), Winterhaven Telephone Co. (U-1021-C), and Frontier Communications West
Coast (U-1020-C). These telephone companies generally operate in rural areas and have regulated rates. 3 See i-wireless, LLC’s Advice Letter 2 (filed July 30, 2012), Advice Letter 2A (October 17, 2012), Advice Letter 2B
(February 20, 2013), and Advice Letter 2C (July 24, 2014).
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Background

Congress directed the FCC to establish universal service support mechanisms to ensure
that “[q]uality services [are] available at just, reasonable, and affordable rates” for
consumers throughout the nation.4 The FCC’s and the CPUC’s Lifeline programs further
this goal by providing discounts on monthly telephone services to eligible low-income
consumers.

Section 254(e) of the Communications Act, as amended (the Act), states that “only an
eligible telecommunications carrier under section 214(e) shall be eligible to receive
specific federal universal service support.”5 Under section 214(e)(1)(A) and (b), a
common carrier designated as an ETC must:

 offer services supported by the federal Universal Service Fund (USF) either by
using its own facilities, resale, or both, and
 advertise the services and the related charges using advertising media of general
distribution.6

Under section 214(e)(2), state commissions are given the primary responsibility of
designating ETCs in their states. Once designated an ETC, the FCC then authorizes the
ETC to receive federal USF support for providing those services supported by the USF
(e.g. local telephone service) in high-cost areas and to low-income customers.

47 C.F.R. § 54 contains the FCC’s Universal Service rules issued to implement § 254 of
the Telecommunications Act regarding universal service. Sections 54.400 – 54.422
address federal Lifeline service. Section 54.401 defines Lifeline as a non-transferrable
retail service offering for which qualifying low-income consumers pay a reduced charge
for voice telephony service after applying the federal Lifeline support amount.7

FCC Orders
The following provides a brief summary of some of the relevant aspects of the FCC
orders that address ETC matters:

FCC 11-161 (November 18, 2011), the federal USF and Intercarrier Compensation
(ICC) Transformation Order, modified the definition of the services that are
supported by the Federal USF by eliminating the FCC’s former list of nine
supported services and adopting a definition that is technology neutral, now
focusing on service functionality instead of the technologies used and allowing
services to be provided over any platform.8
4 47 U.S.C. § 254(b)(1). 5 47 U.S.C. § 254(e). 6 47 U.S.C. § 254(e)(1)(A), (b).
7 47 C.F.R. § 54.403. 8 In the Matter of Connect America Fund, A National Broadband Plan for Our Future, Establishing Just and
Reasonable Rates for Local Exchange Carriers, High-Cost Universal Service Support, Developing an Unified
Intercarrier Compensation Regime, Federal-State Joint Board on Universal Service, Lifeline and Link-Up, Universal
Service Reform – Mobility Fund, WC Docket No. 10-90, GN Docket No. 09-51, WC Docket No. 07-135, WC Docket
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In addition, the Order reformed the framework for ETC oversight by the FCC, state
commissions, Tribal governments, and the Universal Service Administrative
Company (USAC).9 The Order established uniform national standards of
accountability related to reporting requirements and annual § 254(e) certifications10;
imposed consequences of non-compliance with rules; described the USAC
oversight process, access to cost & revenue data; and, updated the federal USF/ICC
systems including revisions to the information required of common carriers when
seeking ETC designation and annual reporting requirements. ETCs must meet
public interest obligations and apply new certifications related to the public
interest.

FCC 11-189 (December 23, 2011), the Sua Sponte Order on Reconsideration,
clarified the attributes of “voice telephony service” by amending the definition of
services supported by the federal USF in order to establish a more technologically
neutral approach to functionality over any platform, not just based on technology.
With the amendment of § 54.101, voice telephony services must, by definition
provide a) voice grade access to the public switched network or its functional
equivalent, b) minutes of use for local service provided at no additional charge to
end users, c) access to emergency services provided by local government or other
public safety organizations (e.g. 911 or E-911), and d) toll limitation for qualifying
low-income consumers.11 Additionally, the Order affirmed that Lifeline-only ETCs
do not meet the “own facilities” requirement if their facilities no longer support the
“voice telephony service” under the amended section. To be in compliance with
rules, Lifeline-only carriers seeking ETC designation must use their own facilities,
in whole or in part, to provide the supported services or obtain forbearance from
the FCC.12

FCC 12-11 (February 6, 2012), the Lifeline Reform Order, revised the definition of
Lifeline service to include technological-neutral terms of service and adopted a rule
to permit ETCs to allow qualifying consumers to apply Lifeline discounts to all
residential service plans that provide voice telephony service including bundled
service packages of voice and broadband or packages with optional calling features.
ETCs can apply the Lifeline discount to any retail service offering, not just to
offerings specifically designed for low-income consumers.13

No. 05-337, CC Docket No. 01-92, CC Docket No. 96-45, WC Docket No. 03-109, WT Docket No. 10-208, Report
and Order and Further Notice of Proposed Rulemaking (FCC 11-161) (rel. Nov. 18, 2011) (USF/ICC Transformation
Order) ¶ 77.
9 Id. at § VIII. 10 47 U.S.C. § 254(e) requires ETCs to use federal support funds only for the provision, maintenance, and upgrading
facilities and services. 11 Connect America Fund et al., WC Docket 10-90 et al., Order on Reconsideration, 26 FCC Rcd 17633 (2011)(First
Order on Reconsideration) ¶ 3. 12 Id. at ¶ 4.
13 In the Matter of Lifeline and Link Up Reform and Modernization, Lifeline and Link Up, Federal-State Joint Board
on Universal Service, Advancing Broadband Availability Through Digital Literacy Training, WC Dkt. 11-42, WC
Dkt. 03-109, CC Dkt. 96-45, WC Dkt. 12-23 (FCC 12-11) rel. Feb 6, 2012 (Lifeline Reform Order) ¶¶ 315-316.
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The Order updated the definition of Lifeline to be consistent with the new
definition of the supported services (e.g. voice telephony service) adopted in FCC
11-161, the Transformation Order, and removed the “local” qualifier because many
providers no longer distinguish between local and long distance usage since service
offerings bundle minutes of use. Prior to the adoption of FCC 12-11, an ETC had to
demonstrate that it offered a local usage plan comparable to one offered by the
incumbent LEC in the service area(s) for which the ETC applicant sought
designation. The FCC never adopted a specific local usage threshold leaving it up
to a fact specific case-by-case analysis that took into consideration different local
calling areas than those of the incumbent LEC, a specified number of free local
minutes, or the offering of an unlimited calling plan that bundles local and long
distance minutes.14 In FCC 12-11, however, the FCC noted that many providers do
not distinguish between local and long distance usage and concluded that carriers
may satisfy the obligation to provide local usage via service offerings which bundle
local and long distance minutes15 and concluded that this finding was applicable
also to Lifeline service. The FCC, therefore, determined it appropriate to remove
the qualifier “local” from Lifeline comparable local usage requirements and
determined that prescribing a minimum amount of local minutes was not necessary
at this time.

The Order updated its ETC rules16 for all ETCs by: a) modifying the definition of
ETC to include ETC’s designated by the FCC as well as by the states; b) requiring
all carriers requesting ETC designation to demonstrate financial and technical
capability to provide Lifeline services; and, c) streamlining annual reporting
requirements, including service outages, into a new section 47 C.F.R. § 54.422. By
adopting these program revisions, the FCC expects to strengthen protections
against waste, fraud, and abuse and improved program administration,
accountability, and consumer protections.

47 U.S.C. § 214(e)(1)(A) required an ETC to provide the supported services through
the use of its own facilities or a combination of its own facilities and resale. The
Order concluded that forbearance from the facilities requirement would be in the
public interest because it will increase connection among providers of
telecommunications services. As a condition of granting forbearance from the
“own-facilities” rule, resellers must have an FCC-approved Compliance Plan.
Section 214(e)(1)(A) limits ETC designation to common carriers providing service
with their own facilities. The FCC granted forbearance to this requirement to those
common carriers that do not meet the “own facilities” requirement, subject to the
conditions that17: a) the carrier must comply with certain 911 requirements
including, but not limited to, the procedures the ETC follows in enrolling a
subscriber in Lifeline and submitting for reimbursement for that subscriber from

14 In the Matter of Federal-State Joint Board on Universal Service, Report and Order, CC Dkt. 96-45 (FCC 05-46),
rel. Mar 17, 2005. ¶¶ 32-33.
15 Lifeline Reform Order at ¶ 49. 16 Id. at ¶¶ 384-391. 17 Id. at ¶ 379.
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the fund, materials related to initial and ongoing certifications and sample
marketing materials, as well as further safeguards against waste, fraud, and abuse
the FCC may deem necessary and b) the carrier must file, and the FCC must
approve, a compliance plan that provides specific information regarding the
carrier’s service offerings and outlines the measures the carrier will take to
implement the obligations set forth in FCC 12-11. This includes a detailed
description of how the carrier offers service, the geographic areas in which it offers
service, and a description of the carrier’s various Lifeline service plan offerings
including subscriber rates, number of minutes included, and the types of plans
available.

The FCC declined to prescribe minimum monthly minute standards, finding that it
was not necessary because the communications market place should make this
determination, citing examples of competitive forces driving up the number of
minutes offered to Lifeline customers.18 While the FCC has not prescribed
minimum minutes of use for Lifeline plans, Communications Division (CD) staff
reviews an ETC applicant’s proposed plans to determine if they are based on retail
offerings of the ETC applicant that are available to its non-Lifeline customers or if
the plans are offered only to Lifeline customers. For those Lifeline plans that are
not based on retail plans available to all prospective customers, CD staff evaluates
the Lifeline customer-only plans in its public interest analysis of each ETC request.

FCC 12-52 (May 14, 2012), the Third Order on Reconsideration, extended annual
reporting requirements to all recipients of federal high-cost/Connect America Fund
(CAF) support, including state-designated ETCs, and clarified that the FCC will not
preempt states from imposing state-specific reporting requirements as long as those
additional reporting requirements do not create burdens that thwart achievement
of the universal service reforms adopted by the FCC.

California Public Utilities Commission ETC Designation Requirements
The following are the CPUC requirements that a carrier seeking an ETC must also
comply with:

In Resolution T-17002 (May 25, 2006), the CPUC adopted The Comprehensive
Procedures and Guidelines for ETC Designation and Requirements for ETCs that are
consistent with FCC Order 97-157 regarding designation of a telephone carrier as a
qualified ETC. Pursuant to this Resolution, applicants seeking ETC designation in
California are required to provide the following: a description of the proposed
service offerings and attached service area maps; description of the advertising
plan(s); commitment to provide service; submission of the 2-year service quality
improvement plan; ability to remain functional; commitment to consumer

18 Id. at ¶ 50.
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protection; demonstration that a carrier’s usage plan is comparable to that of the
incumbent LEC in the proposed service area; and, public interest determination.

In addition, the CPUC’s rules require that, in order to be designated as an ETC, an
applicant must comply with General Order 153 (GO 153) which implements the
Moore Universal Telephone Service Act and contains California LifeLine service
requirements. Applicants must offer all 22 Lifeline service elements unless it has
obtained a waiver19 and comply with all other applicable provisions in GO 153.
User Fees and Surcharges are obligations which CPUC-approved carriers must
fulfill. The Public Utilities Commission (PUC) User Fee is levied on all
telecommunications carriers providing services directly to customers or subscribers
and the amount of fees is a percentage calculation based on all intrastate customer
billings for telecommunications services. In addition, all telecommunications
carriers that provide basic telephone service are required to collect and remit Public
Purpose Program (PPP) surcharges from end-users that fund the Commission’s
universal service program. When reviewing ETC designation requests, CD staff
reviews carrier compliance with these state regulatory requirements for telephone
corporations operating in California including, but not limited to, reporting and
paying PUC User Fees, PPP surcharges, and submitting required reports.

Notice/Protests

The advice letter filing was served via email to all parties on the ETC service list and
appeared in the Commission’s Daily Calendar on August 3, 2012.

On August 16, 2012, the Division of Ratepayer Advocates (DRA)20 filed a protest to this
advice letter with two concerns: the proposed Lifeline discount amount of $15 needed
clarification and the proposed plans did not offer sufficient minutes of use. On August
22, 2012, i-wireless responded to the protest explaining that the $15 discount includes the
maximum federal support amount of $9.25 added to a $5.75 company credit. Also, in
addressing the insufficient minutes, i-wireless responded that the 200 and 250 Minute
plans serve as choices for individuals who want a plan with some minutes at a budget-
saving low-cost. i-wireless, also, pointed out that there are currently available plans
with similar minutes and features.

19 See Attachment B for list of GO 153 service elements. 20 DRA is now known as the Office of Ratepayer Advocates.
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Discussion

Company Overview and Proposed Lifeline Rate Plans
i-wireless, LLC (i-wireless), under the brand designation “Access Wireless,” is a prepaid
wireless service provider with principal offices at 1 Levee Way, Suite 3104, Newport,
Kentucky, 41071. Using the Sprint Spectrum, L.P. network on a wholesale basis, i-
wireless obtains the network infrastructure and wireless transmission facilities to allow
it to operate as a mobile virtual network operator. On May 21, 2007, the Commission
issued i-wireless its Wireless Identification Registration number U-4372-C allowing it to
operate as a commercial mobile radio service (CMRS) provider in California. i-wireless
has complied with the regulatory requirements for telephone corporations operating in
California including, but not limited to, reporting and payment of PUC User Fees and
Public Purpose Programs (PPP) surcharges and submitting required reports.

On July 30, 2012, i-wireless filed Tier III Advice Letter (AL) 2 requesting ETC designation
to receive federal support to provide only federal Lifeline prepaid wireless service to
eligible customers under the brand “Access Wireless.” In partnership with The Kroger
Company (Kroger), the nation’s largest grocery retail chain and second largest retailer
overall, i-wireless customers would accumulate free minutes for dollars spent at
participating Kroger or “Ralphs” grocery store locations that participate in the Free
Minutes Loyalty Program (approximately 137 cities across the state at the time of the AL
filing).

i-wireless seeks approval of the following five rate plans,21 two rate plans that are only
available to eligible Lifeline customers and three rate plans that are available to both
eligible Lifeline and regular/non-Lifeline customers: :
 550 Minutes of talk and text, a Lifeline-only offering for $5.75 per month.
 1,000 Minutes of talk and text with 200 MB data, a Lifeline-only offering for $12.65
per month.
 Unlimited Talk Plan with unlimited text and 500 MB data for $25.75 per month,
retail value of $35.22
 Unlimited Talk Plan with unlimited text and 2 GB data for $40.75 per month, retail
value of $50.23
 Unlimited Talk Plan with unlimited text and 3 GB data for $65.75 per month, retail
value of $75.24
Lifeline-only customers can purchase additional airtime minutes in denominations of $5
for 100 minutes ($0.05 per minute), $10 for 200 minutes ($0.05 per minute), and $25 for
300 minutes ($0.083 per minute).

21 i-wireless initially requested approval of four Lifeline rate plans in AL 2. Subsequent thereto, i-wireless modified
its rate plans in AL 2A, 2B, and 2C and is now seeking approval of five Lifeline rate plans.
22 A regular/non-Lifeline customer would pay the applicable retail rate ($35, $50 or $75) and an eligible Lifeline
customer would pay the applicable Lifeline rate ($25.75, $40.75 or $65.75), which reflects a deduction of federal
Lifeline discount of $9.25 from the retail rate. 23 Id. 24 Id.
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Compliance with Federal Rules
Federal ETC Requirements:
A carrier must satisfy all FCC ETC requirements in order to receive an ETC designation.
i-wireless has met the following federal ETC requirements:

Demonstrate that the services intended to be offered comply with the voice
telephony definition - Pursuant to 47 U.S.C. § 214(e)(1) and (6), i-wireless submits
that it is a common carrier and is able to provide telephone exchange and exchange
access through its wholesale arrangements with its underlying facilities-based
provider, Sprint.

Advertise using media of general distribution – i-wireless demonstrates that its
Lifeline services meet the definition of voice telephony and commits to advertise in
a manner reasonably designed to reach those likely to qualify for Lifeline using any
California-specific advertising requirements such as media of general distribution
which may include advertisements via printed advertisements, billboards, and
public transit signage. i-wireless states that it may also promote the availability of
its Lifeline offerings by distributing brochures at various state and local social
service agencies and may partner with non-profit organizations in order to inform
customers of the availability of its Lifeline services. i-wireless also states that it
plans to engage in a collaborative advertising strategy with Kroger to increase
consumer awareness of the Lifeline program through store customer education.
For example, when a customer pays with a government-subsidized form of
payment, a secondary cash register receipt automatically will generate information
about the customer’s eligibility for Lifeline program benefits and how to obtain
more information. Kroger in-store radio, printed advertisements, and signage will
be used. Another benefit for Kroger customers is participation in the Free Minutes
Loyalty Program which allows customers with an i-wireless Lifeline account to earn
additional minutes in a month. i-wireless expects that its advertising and outreach
efforts will result in increased participation in the Lifeline program by eligible low-
income consumers.

Commit to provide service throughout the designated service area – i-wireless
commits to provide service in the areas that it is designated an ETC, based on the
build-out of the facilities and availability of service of its underlying facilities based
carrier, Sprint. i-wireless will expand its service area accordingly as Sprint
continues to develop additional facilities from it operational and largely built out
network. i-wireless’s agreement with Sprint allows the company to provide to its
customers the same ability to remain functional in emergency situations as
currently provided by Sprint to its own customers, including access to a reasonable
amount of back-up power to ensure functionality without an external power
source, the ability to reroute traffic around damaged facilities, and the capability of
managing traffic spikes resulting from emergency situations. Sprint has
redundancies, back-up generator power and an extensive disaster recovery
program. Sprint has built its network from the ground up which means that its
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network is consistent across the entire network so that it is easy to monitor and to
troubleshoot should any outage or disruption occur.

Resellers submit FCC-approved compliance plan – i-wireless submitted a revised
compliance plan approved by the FCC on October 21, 2011.

Demonstrate financial and technical capability – i-wireless is financially and
technically capable of providing Lifeline services. i-wireless is 50% owned by
Kroger, the nation’s largest grocery retail chain and the second largest retailer
overall. i-wireless has been in business for six years and has successfully provided
wireless service in states around the nation. i-wireless possesses ETC designations
in 26 states and the District of Columbia and has petitions pending in four states. i-
wireless is financially able to provide Lifeline services as it does not intend to offer
exclusively Lifeline services and therefore not exclusively dependent on universal
service support for its revenue. Its senior management has many years’ experience
in the telecommunications industry and offers extensive telecommunications
business, technical, and managerial expertise to the company. i-wireless will
provide resold wireless service and therefore will rely upon the managerial and
technical expertise of its underlying carrier, Sprint.

Meet public interest requirements for the proposed service areas – i-wireless
asserts that it meets the FCC public interest criteria because it will provide
consumers, especially low-income consumers, with low prices and high quality
communications services. i-wireless would provide increased consumer choice,
service offerings, and mobility as well as the safety and security of effective 911 and
E911 services through its portable and convenient wireless service. i-wireless’ entry
into the market will promote competition which will spur competitors to improve
their existing networks to remain competitive while giving low income residents a
wider choice of providers and available services.

Commit to satisfy all applicable consumer protection and service quality
standards – i-wireless agrees to abide by all applicable state and federal consumer
protection and service quality standard requirements and commits to comply with
the Cellular Telecommunications and Internet Association’s (CTIA) Consumer Code
for Wireless Service.

Agree to apply the Lifeline support discount to residential retail plans – i-
wireless states that it will apply the $9.25 federal Lifeline support amount to all of
its proposed plans.

CD staff finds that i-wireless has not complied with the following three federal ETC
requirements and makes these recommendations:
1) i-wireless did not address its commitment to file federal compliance reports (e.g.,
Form 481, etc.) annually. CD staff recommends that the Commission direct i-
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wireless to file federal compliance reports with the FCC and this Commission, as
directed.
2) FCC 12-11 Paragraphs (¶) 384-391 changed some of the ETC designation and
annual compliance reporting requirements in Part 54 in order to centralize and
streamline certification and reporting requirements for carriers. These changes
were effected by deleting 47 C.F.R. § 54.202 and establishing 47 C.F.R. § 54.422. i-
wireless should include the following data and information in its annual reports:25
 ¶ 385 - Definition of ETC in 47 C.F.R. § 54.5 as modified includes ETCs
designated by the FCC
 ¶ 386 – Lifeline-only ETCs exempted from filing 5-year network
improvement plans
 ¶ 387-388 - Explicit requirement that ETC applicants must demonstrate
financial and technical capability to provide Lifeline service including:
 Previous experience offering service to non-Lifeline customers
 Length of time in business
 Whether applicant will rely exclusively on Lifeline revenues to
operate
 Whether applicant will receive revenue from other sources
 Previous enforcement action against applicant or ETC revocation
proceedings in other states
 ¶ 389 – Reporting requirements within 47 C.F.R. § 54.422
 Service outage information
 Number of complaints received per 1,000 connections
 Compliance with service quality standards and consumer protection
rules
 Certify that the carrier can operate in emergency situations
 ¶ 390 – Other reporting requirements
 Names and identifiers used by the ETC, its holding company,
operating companies and affiliates
 General information of terms and conditions of Lifeline voice
telephony plans offered to Lifeline customers including number of
minutes provided, additional charges for toll calls, and rates for
each plan.

3) 47 C.F.R. § 54.401(d) requires that when a state commission designates a carrier an
ETC status, the state commission shall file or require the ETC to file information
with USAC that demonstrates that the ETC’s Lifeline plan meets the universal
service support criteria for low-income consumers including the terms and

25 Wireline Competition Bureau Announces Filing Deadline of October 15, 2013 for Eligible Telecommunications
Carriers to File High-Cost and Low-Income Annual Reports, and Announces Filing Deadline of December 16, 2013
for States and ETCs to File Annual Use Certifications, Public Notice, WC Dkt.1090 and 11-42, DA 13-1707 (August
6, 2013)
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conditions of voice telephony service plans and the plan details.26 To comply
with § 54.401(d), CD recommends that the Commission direct i-wireless to file the
applicable information directly with USAC. USAC will review the service plans
to ensure they meet the federal Lifeline requirements. Once USAC approves the
service plans, i-wireless shall provide to the Communications Division Director a
copy of the information submitted to USAC and a copy of i-wireless’s certification
of approval from the USAC within 30 days of receipt from USAC.
With the three recommendations covered above, CD staff believes i-wireless is compliant
with FCC ETC requirements.

Compliance with CPUC Rules
GO 153 Basic Service Elements Compliance:
GO 153 requires carriers that seek an ETC designation to comply with 22 basic service
elements of California LifeLine. (See Attachment B of this resolution for a complete list of
California LifeLine basic service requirements.)27 i-wireless requested a waiver of the
following California LifeLine basic service elements: (4) the ability to receive free
incoming calls, (11) free provision of one directory listing per year, (12) availability of
free white pages telephone directory, (15) free access to 800 and 800-like toll-free
numbers, (19) free access to toll-blocking service, (20) free access to toll-control service,
and (21) access to two residential lines if a low income household with a disabled person
requires both lines to access Lifeline.28

CD staff recommends granting waivers from elements (4), (11), (12), and (15) because
they do not apply to wireless service providers but to providers of wireline services; the
Commission has granted such waivers in the past. Likewise, CD staff recommends
granting waivers from elements (19) and (20) since there is no distinction between the
local and long distance usage of minutes offered in i-wireless’s proposed plans and
therefore do not apply. However, CD staff denies i-wireless’ request for a waiver of
element (21) because other federal Lifeline wireless providers comply with this service
element currently and because D.14-01-032 maintains this element as a requirement in
the California LifeLine rules for wireless carriers.29 Since all wireless carriers are
required to provide access to two lines for a household with a disabled person, CD staff
does not recommend granting a waiver to requested element (21).

26 USAC requires a copy of a new ETC’s designation order issued by its state utility regulator,
http://usac.org/li/telecom-carriers/step03/default.aspx. Site last visited May 15, 2014. 27 Current GO 153 continues to be used to evaluate ETC designation request by wireless carriers including federal
Lifeline applications and renewals until the Commission revises GO 153 and determines the extent to which revised
GO 153 rules and revised California LifeLine service elements should apply to federal Lifeline wireless offerings in
Rulemaking 11-03-013. 28 D.10-11-033 (November 19, 2010). 29 D.14-01-032 (January 16, 2014), Attachment D, Appendix A-2, service element 17 (revised).
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LifeLine Third Party Administrator:
GO 153, § 4.2 related to California LifeLine enrollment procedures provides a reasonable
means for wireless carriers to determine if a prospective low-income customer is eligible
for federal Lifeline wireless service. In California, the California LifeLine Administrator
(CLA) performs enrollment application and renewal functions.30 i-wireless agrees to
comply with GO 153 requirements, including consumer enrollment, prequalification,
certification, eligibility verification and annual renewal, and working with the CLA.
Once eligibility is established and approval information is sent by the CLA, i-wireless
will then send a phone and welcome package to an approved customer.

CD staff recommends that the Commission require i-wireless to label clearly its wireless
offerings as “federal Lifeline service”. Doing so would minimize customer confusion
between the California LifeLine and federal Lifeline programs, disseminate adequate
information about potential coverage and service quality issues, and provide copies of
all marketing materials including, but not limited to, customer service representative
scripts, internet marketing, and posters and brochures to CPUC California LifeLine staff
for review and approval prior to publication and distribution.

Resolution T-17002 Compliance:
i-wireless has satisfied the applicable requirements set forth in Resolution T-17002
including, but not limited to: providing Lifeline-only services within the proposed
service area; providing the designated services; and, complying with advertising rules as
required by the FCC such as using printed advertisements, billboards, public transit
signage, and brochures, all of which will state clearly that the Lifeline support is from
the federal Lifeline program only.

At the time of review, i-wireless was current with payment of the annual PUC User Fees
and public purpose program surcharges. As a condition of its Commission authority
and its ETC designation, i-wireless must continue to remain current with its payments.
The Commission may revoke i-wireless’s ETC designation and/or operating authority if
the company does not remit timely fees and surcharges and the Commission will notify
the USAC and the FCC of the revocation.

i-wireless states it has the ability to remain functional in emergency situations by
working with its underlying carrier, Sprint. i-wireless commits to satisfy all applicable
state and federal requirements related to consumer protection and service quality
standards.

Providing Federal Lifeline Wireless Service to Customers in Small LEC Service Areas:
i-wireless does not seek ETC designation in the service areas of the Small LECs.
Consistent with the policy adopted in Resolution T-17284, i-wireless commits to
coordinate with the Small LECs using their list of the ZIP+4 codes31 associated with the

30 GO 153, § 4.2.1. The current California LifeLine Administrator is Xerox.
31 ZIP+4 code is the standard ZIP code with a four digit add-on code. This add-on code identifies a smaller
geographic region within the main code, such as a city block, office building, etc. In Resolution T-17284, Virgin
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Small LECs service areas. i-wireless will use that data to ensure that no federal Lifeline
wireless service is offered to customers residing in the Small LECs’ service areas.

CD staff recommends that the Commission require the Small LECs to provide to i-
wireless, as they do for all current ETCs, an updated ZIP+4 code data list of the Small
LECs’ service areas32 within 30 days of the effective date of this Resolution, as
appropriate for the carrier and the service area. The Small LECs should also be required
to provide to i-wireless any update to the ZIP+4 code data, as needed. i-wireless should
file a copy of any updated ZIP+4 code data list with the Communications Division
Director and the CLA. The ZIP+4 code data shall be provided in an MS Excel file (.xls)
format via email to the CD Director. The Small LECs also shall provide the CLA the
ZIP+4 code data in a format specified by the CLA.

Public Interest Determination:
Before recommending designation of a carrier as an ETC, CD staff must determine that
doing so would be in the public interest for California consumers.33 In the Lifeline
Order, the FCC clearly states the importance of promoting universal service principles34
and in that context that the Lifeline program includes a public interest determination
particularly for Lifeline-only ETCs where forbearance of the facilities-based requirement
exists.35 Since the federal Lifeline program adopted a technology-neutral definition for
supported service, i-wireless proposes to give consumers a choice of prepaid wireless
rate plans that provide larger local calling areas than traditional wireless service through
its mobile connectivity. In addition, i-wireless service provides convenience and
security, the opportunity for customers to control cost by receiving a preset amount of
monthly airtime at low cost (e. g. the 550 Minute Plan), the ability to purchase additional
usage at flexible and affordable amounts, 911 service and, where available, E911 service.
i-wireless states that its Lifeline customers will receive the same high-quality wireless
service and exceptional customer service provided to all its customers. i-wireless
emphasizes that its Lifeline rate plans will allow feature-rich mobile connectivity for
qualifying subscribers at minimal cost through a choice of rate plans that are comparable
in minutes and features to those available to post-paid wireless subscribers. The current
choices of low-cost, low minutes to discounted monthly cost for unlimited talk and text
with data allow a customer who can contribute more out-of-pocket to subscribe to a
higher bucket of minutes if it suits his/her needs and budget.

Upon review, CD staff finds that i-wireless meets the FCC criteria for public interest
determination including providing the benefits of increased competitive choice,

Mobile was required to screen prospective Lifeline customers to ensure they do not reside in the Small LECs’
territories. The screening can be accomplished by using the list of ZIP+4 codes for the Small LEC service areas.
32 On July 5, 2011, the Small LECs filed with the CPUC the ZIP+4 code data pursuant to Resolution T-17284. On
July 6, 2011, Frontier Communications West Coast, Inc. filed the ZIP+4 code data for its service areas pursuant to
T-17284. 33 In the Matter of Federal-State Joint Board on Universal Service, Report and Order, CC Dkt 96-45 (FCC 05-46),
released Mar 17, 2005 ¶ 40 and CPUC Resolution T-17002, Appendix A, Section II-G: Public Interest Determination. 34 47 U.S.C. § 254(b)(c)(e)(2). 35 Lifeline Reform Order at ¶¶ 219, 378, 362, and fn 968.
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convenience, security with mobility, ability to purchase additional usage, and the ability
to use supported service to send and receive text messages in a prepaid plan.

Price Analysis
When analyzing Lifeline plan pricing, CD staff considers non-Lifeline retail plan prices,
relying on competitive forces to determine what plans are reasonable, as well as
currently available federal Lifeline retail plans. In addition, CD staff evaluated i-
wireless’s proposed offerings using the expected monthly cost to a low-income
consumer based on average minutes of use36 compared to similar incumbent local
exchange carrier (ILEC) Lifeline plans and other wireless ETC Lifeline plans.

As proposed, i-wireless’ 550 Minutes, 1,000 Minutes, and the Unlimited Talk Plans with
unlimited text and 500 MB and 2 GB data have equal or better value for low-income
customers when compared to other prepaid wireless Lifeline packages. The Unlimited
Talk Plan with unlimited text and 3 GB data, a $75 retail plan, would cost a Lifeline
customer $65.75 per month after applying the $9.25 federal support amount. Compared
to other currently available unlimited wireless Lifeline plans on the market, i-wireless’s
Unlimited Talk Plan with unlimited text and 3 GB data would cost more than i-wireless’
plan with unlimited talk, text, and data priced at $39.99. See Chart 1 for comparison
details.

36 In the Matter of Implementation of Section 6002(b) of the Omnibus Budget Reconciliation Act of 1993 Annual
Report and Analysis of Competitive Market Conditions With Respect to Mobile Wireless, Including Commercial
Mobile Services, WT Dkt. No. 11-186 (FCC 13-34) (Sixteenth Report on Mobile Competition). The FCC annually
issues a mobile competition report which reflects analysis of 2011 data submitted by carriers. CD staff analysis uses
the 615 average minutes of use (MOU) for wireless voice as a base to evaluate Lifeline plan offerings (Table 38).
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Chart 1 -- Comparison of Proposed Federal Lifeline Wireless Plans to Other Prepaid Federal Lifeline
Wireless Plans in Service Area (Assuming Average Wireless MOU)

Prepaid Wireless Lifeline Plans
Budget Mobile
500
i-wireless 550
Minutes
Virgin Mobile
500
i-wireless 1000
Minutes & 200
MB Data
Total Call 1000
Talk & 1000
Text
Telscape 1100 Virgin Mobile
1000 Nexus 1000 Budget Mobile
1000
TAG Mobile
Plan 1000
Avg. MOU*615 615 615 615 615 615 615 615 615 615
Basic Plan Minutes
(allowance)500 550 500 1000 1000 1100 1000 1000 1000 1000
Texts included 100 1 txt = 1 min 500 1 txt = 1 min 1000 1 txt = 1 min 1000 -250 1000
Data included ---200 MB ------
Avg. Excess MOUs 115 65 115 0 ------
Cost per Min in excess of
allowance **$0.033 $0.050 $0.100 $0.050 ------
Cost of excess minutes**$3.80 $3.25 $11.50 -------
Min. Lifeline Plan Cost
(per D.10-11-033) or Cost
per Plan
$5.00 $5.75 $5.00 $12.65 $19.99 $20.00 $20.00 $20.00 $20.00 $20.00
Total GO 153 Cost to
Customers $8.80 $9.00 $16.50 $12.65 $19.99 $20.00 $20.00 $20.00 $20.00 $20.00
Caller ID $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00
Long Distance $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00
Voicemail $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00
Federal Excise Tax $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00
Total Additional costs of
vertical features $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00
Total Cost to Lifeline
Customers with 615 MOU
and additional costs of
vertical features
$8.80 $9.00 $16.50 $12.65 $19.99 $20.00 $20.00 $20.00 $20.00 $20.00

Prepaid Wireless Lifeline Plans
Cricket
Unlimited
i-wireless
Unlimited
Talk, Text, &
500 MB Data
Total Call
Unlimited
Talk & Text
Virgin Mobile
Unlimited
TAG Mobile
Plan
Unlimited
Budget
PrePay
Unlimited
Talk/Text
Total Call
Unlimited
Talk,Text, &
Data
i-wireless
Unlimited
Talk, Text, &
2 GB Data
i-wireless
Unlimited Talk,
Text, & 3 GB Data
Avg. MOU*615 615 615 615 615 615 615 615 615
Basic Plan Minutes
(allowance)Unlimited Unlimited Unlimited Unlimited Unlimited Unlimited Unlimited Unlimited Unlimited
Texts included -Unlimited Unlimited Unlimited Unlimited Unlimited Unlimited Unlimited Unlimited
Data included -500 MB ----Unlimited 2 GB 3 GB
Avg. Excess MOUs ---------
Cost per Min in excess of
allowance **-$0 -----$0 $0
Cost of excess minutes**-$0 -----$0 $0
Min. Lifeline Plan Cost (per
D.10-11-033) or Cost per
Plan
$21.50 $25.75 $29.99 $30.00 $30.00 $32.00 $39.99 $40.75 $65.75
Total GO 153 Cost to
Customers $21.50 $25.75 $29.99 $30.00 $30.00 $32.00 $39.99 $40.75 $65.75
Caller ID $0.00 -$0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00
Long Distance $0.00 -$0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00
Voicemail $0.00 -$0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00
Federal Excise Tax $0.00 -$0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00
Total Additional costs of
vertical features $0.00 -$0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00
Total Cost to Lifeline
Customers with 615 MOU
and additional costs of
vertical features
$21.50 $25.75 $29.99 $30.00 $30.00 $32.00 $39.99 $40.75 $65.75
Plan choices based on AL Supplement 2C filed July 24, 2014.
** Requires purchase of $5 airtime card for 100 additional minutes
* Average Minutes of Use based on FCC 13-34 16th Mobile Wireless Competition Report issued March 19, 2013, Table 38. Avg MOU
615, Year 2011.

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Comparable Local Usage and Equal Access
To demonstrate that its proposed federal Lifeline wireless plans are reasonable, i-
wireless provided a summary comparing its federal Lifeline wireless plans to other retail
and federal Lifeline offerings made by wireless and wireline local exchange carriers.
CD, however, updated Chart 2 using the companies’ websites to reflect accurately
current offerings and retail prices.

Chart 2 -- Comparison of Proposed Federal Lifeline Wireless Plans to California ILEC Federal Lifeline
Wireless Measured Rate Plans and Prepaid Wireless Plans (Assuming Average Wireless MOU)

i-wireless 550 Minutes
i-wireless 1000 Minutes & 200 MB Data
i-wireless Unlimited Talk, Text, &
500 MB Data
i-wireless Unlimited Talk, Text, & 2 GB
Data
i-wireless Unlimited Talk, Text, & 3 GB
Data
AT&T Lifeline MR (minimum)
AT&T Lifeline MR (maximum)
Verizon Lifeline MR (minimum)
Verizon Lifeline MR (maximum)
Virgin Mobile PayLo 1500
Nexus Reach Out Simple Plan
1000
Metro PCS Unlimited
AT&T Go Phone Unlimited Talk
& Text
Sprint Basic Plus Verizon Talk & Text 450
Avg. MOU*615 615 615 615 615 615 615 615 615 615 615 615 615 615 615
Basic Plan Minutes (allowance)550 1000 Unlimited Unlimited Unlimited 146 146 146 146 1500 1000 Unlimited Unlimited Unlimited 450
Texts included 1 txt = 1
min 1 txt = 1 min Unlimited Unlimited Unlimited ----1500 -Unlimited Unlimited Unlimited Unlimited
Data included -200 MB 500 MB 2 GB 3 GB ----30 MB -Unlimited Unlimited Unlimited -
Avg. Excess MOUs 65 ----469 469 469 469 -----165
Cost per Min in excess of
allowance $0.050 $0 $0 $0 $0 $0.033 $0.033 $0.033 $0.033 $0 $0 $0 $0 $0 $0.45
Cost of excess minutes $3.25 $0 $0 $0 $0 $15.48 $15.48 $15.48 $15.48 $0 $0 $0 $0 $0 $74.25
Min. Lifeline Plan Cost (per
D.10-11-033) or Cost per Plan $5.75 $12.65 $25.75 $40.75 $65.75 $2.50 $3.66 $2.50 $3.66 $30.00 $20.00 $40.00 $45.00 $50.00 $59.99
Total GO 153 Cost to
Customers $9.00 $12.65 $25.75 $40.75 $65.75 $17.98 $19.14 $17.98 $19.14 $30.00 $20.00 $40.00 $45.00 $50.00 $134.24
Caller ID -----$9.99 $9.99 $7.95 $7.95 ------
Long Distance -----$6.99*$6.99*$15.99 $15.99 ------
Voicemail -----N/A N/A $7.45 $7.45 ------
Federal Excise Tax -----$0.08 $0.11 $0.08 $0.11 ------
Total Additional costs of
vertical features -----$17.06 $17.09 $31.47 $31.50 ------
Total Cost to Lifeline
Customers with 615 MOU and
additional costs of vertical
features
$9.00 $12.65 $25.75 $40.75 $65.75 $35.04 $36.23 $49.45 $50.64 $30.00 $20.00 $40.00 $45.00 $50.00 $134.24
Plan choices based on AL Supplement 2C filed July 24, 2014.
** Requires purchase of $5 airtime card for 100 additional minutes
Prepaid Wireless Retail PlansILEC MR Lifeline Plansi-wireless, LLC branded as Access Wireless
* Average Minutes of Use based on FCC 13-34 16th Mobile Wireless Competition Report issued March 19, 2013, Table 38. Avg MOU 615,

CD staff notes that in the Chart 2, listing current prepaid wireless retail plans, Metro
PCS, AT&T Wireless, and Sprint (i-wireless’s underlying carrier) charge less for their off-
the-shelf unlimited talk, text, and data plans, respectively $40, $45, and $50. A low-
income customer could sign up directly with those companies and save monthly $25.75,
$20.75, or $15.75, respectively, over i-wireless’ Lifeline Unlimited Plan with 3 GB data
plan costing $65.75. CD staff does not find it in the public interest to approve a package
that would cost a Lifeline customer more than a similar or better off-the-shelf retail
offering and recommends that the Commission reject i-wireless’s Unlimited Talk Plan
with unlimited text and 3 GB data plan. CD staff found the 550 Minutes, 1,000 Minutes,
the Unlimited Plan with 500 MB, and the Unlimited Plan with 2 GB data plans to be
acceptable as they offer better value to a Lifeline customer with choices to fit individual
needs and budget.

Due Diligence Review:
An integral part of CD’s processing of an ETC designation request is a due diligence
review of the requesting carrier as a supplement to the public interest analysis to
determine if the carrier has engaged in behavior that may call into question its fitness to
be granted ETC designation to serve California consumers. The due diligence review
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includes, but is not limited to, confirming that a company is current with payment of
CPUC Reimbursement Fees (referred to as PUC User Fees)37 and surcharges38 as
required to maintain its operating authority. In addition, CD conducts independent
research about a carrier to provide the Commission with background information that
may be pertinent in deciding whether or not to grant the ETC designation request.
Typical research methods are performing Lexis/Nexis legal resource searches, Google
Internet searches, reviewing industry and trade publications, querying other
governmental agencies (e.g. California Secretary of State for business registration),
contacting the FCC and USAC, reviewing a company’s history of operations, and
contacting the Commission’s Safety and Enforcement Division and Consumer Affairs
Branch.

To continue its commitment to protect against waste, fraud, and abuse of the Lifeline
program, CD staff considered the FCC’s Notice of Apparent Liability for Forfeiture (NAL)
issued November 1, 2013, to i-wireless.39 The NAL alleges that the company willfully
violated 47 C.F.R. §§ 54.407, 54.409, and 54.410 by requesting and receiving
reimbursement payments from the Universal Service Fund for intra-company duplicate
Lifeline enrollments. The basis for the NAL resulted from USAC’s in-depth validation
review in specified months of 2012 and 2013 in eight states to identify intra-company
and inter-company duplicates. Of 259,459 subscribers reported, USAC identified 1,684
intra-company duplicates, an error rate of only 0.65%.

The FCC has not adopted a threshold for an acceptable level of duplicates. To assess i-
wireless’ error rate, CD staff relied upon the Federal Improper Payments Elimination and
Recovery Act of 2010 (IPERA)40 as a guideline for an acceptable level of error for duplicate
enrollments. IPERA requires that all federal programs and activities that may be
susceptible to significant improper payments be identified, which aids in the prevention
of the loss of taxpayer dollars through wrongful payments to individuals, organizations,
and contractors by defining standards and setting limits to reduce improper payments.
The IPERA asserts that “significant” risk exists when improper program payments
exceed $10,000,000 of all payments made in a fiscal year or 1.5% of a fiscal year’s
program outlay. Absent an FCC threshold, CD staff finds that the 1.5% provides a
reasonable guideline for an acceptable level of duplication and based on this benchmark,
CD finds that i-wireless’ 0.65% duplicate rate does not rise to the level of a “significant”
risk that justifies a denial of their ETC designation request.

As an additional safeguard against waste, fraud, and abuse, in April 2014, USAC
launched the National Lifeline Accountability Database (NLAD) where all carriers must
upload Lifeline subscriber information. When a carrier initiates a new enrollment, the
carrier must directly access NLAD to verify the individual’s eligibility before enrolling
the person in the program. USAC’s NLAD process prohibits companies from entering
37 PU Code §§ 401, 405, and 431.
38 PU Code §§ 275-279. 39 FCC 13-148 (November 1, 2013). 40 31 U.S.C.3321 note, July 22, 2010.
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the same name twice by blocking duplicate enrollment attempts via live Internet
connections. For April and May 2014, i-wireless reports it had no intra-company or
inter-company duplicates in NLAD.

In addition to NLAD, the CPUC has its own database of California LifeLine customers
that provides essentially the same safeguards as the federal NLAD where California’s
LifeLine third party administrator verifies a new subscriber’s eligibility at the front-end
of the sign-up process to ensure that only eligible California households will receive
California and federal Lifeline benefits from i-wireless.

CD’s due diligence review of i-wireless did not uncover any fitness issues to deny
approval of i-wireless’s ETC request. We, therefore, find i-wireless’s ETC request
consistent with the public interest but if substantive issues emerge after this ETC is
approved which raises public interest questions about i-wireless’s operations, the
Commission may pursue an enforcement action against the company which may include
fines, penalties, and the revocation of ETC designation and/or wireless identification
registration authority.

Safety Concerns:
Although wireless phone service offers great mobility for consumers, CD staff notes
safety concerns related to wireless mobile phone service and E-911 and/or 911
connection limitations. Where there is a lack of coverage, poor signal strength, or
atmospheric or terrain conditions that affect connections, emergency calls may not be
completed. In rural areas, for example, with spotty connectivity or interference (e.g. due
to geographic or structural obstacles), wireless mobile resellers of wholesale facilities
service cannot guarantee full, accessible emergency connections for their own direct
customers. An incomplete emergency call can have devastating results. Given that E-911
and/or 911 safety is a common concern for all of California’s wireless customers, CD
staff recommends that i-wireless be required to fully and clearly inform prospective
federal Lifeline wireless customers that coverage limitations may affect wireless mobile
phone service access to E-911 and/or 911 in the event of an emergency. Such disclosures
include, but are not limited to, clear statements on marketing materials and conspicuous
placement on the public website in the form of information content on webpages,
footnotes, and/or listings on a frequently asked questions (FAQ) webpage.

Changes to Federal Lifeline Wireless Plans:
Regarding changes to federal Lifeline wireless plan offerings, CD recommends as
follows:
1. For changes to i-wireless’ two Lifeline-only plans which are not based on retail
plans currently available to all prospective customers at the time of filing, the
company must file a Tier II Advice Letter to request for approval of any
changes.41 Such request shall demonstrate that the change complies with
Resolution T-17002, i.e. Appendix A-Sections II-E: Local Usage and II-G. Public
41 Resolution T-17339 Ordering Paragraph 3.
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Interest Determination, all applicable GO 153 rules, and pricing rules pursuant
to D.10-11-033 or as modified and/or updated by subsequent Decisions
and/or Resolutions effective at the time of the request; and

2. For changes to i-wireless’s Unlimited Plans that are based on retail service
offerings available to all prospective customers and not just to Lifeline
customers, changes from one retail plan to another retail plan should be
handled via an Information-Only filing, consistent and in compliance with
General Order 96-B General Rules 3.9, 6.1, and 6.2, and Telecommunications
Industry Rule 2. Since i-wireless offers both retail and Lifeline plans, any
future changes to i-wireless’s California federal Lifeline plans that are based
on retail plans shall be noticed via an Information-Only filing.

Final Conclusions and Staff Recommendations:
CD staff recommends conditional approval of i-wireless’ request for an ETC designation
for the purpose of offering federal Lifeline wireless service in California in the service
areas of the URF carriers, excluding the Small LEC service areas. CD staff specifically
recommends conditional approval for i-wireless to offer these four plans:
 550 Minutes of talk and text, a Lifeline-only offering for $5.75 per month.
 1,000 Minutes of talk and text with 200 MB data, a Lifeline-only offering for $12.65
per month.
 Unlimited Talk Plan with unlimited text and 500 MB data for $25.75 per month,
retail value of $35.
 Unlimited Talk Plan with unlimited text and 2 GB data for $40.75 per month, retail
value of $50.

CD staff does not recommend approval of i-wireless’s Plan 4, Unlimited Talk & Text with
3 GB data costing $65.75, because it would be more expensive than any other federal
Lifeline wireless offering currently available to California low-income customers as well
as off-the-shelf retail wireless plans.

Before commencing its federal Lifeline wireless operations in California, i-wireless must
perform with all of the following:

 i-wireless will file required annual reports and compliance reports with the FCC
and the Commission, as directed;
 i-wireless will comply with 47 C.F.R. § 54.401(d) by filing the required
information directly with USAC to certify that its federal Lifeline wireless plan
meets federal requirements under the USAC administration. i-wireless is
obligated to report within 30 days of receipt from USAC that compliance has been
achieved via a letter to the Director of CD including a copy of the information
submitted to USAC and a copy of i-wireless’s certification of approval from the
USAC;

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 i-wireless will provide marketing materials to the CPUC California LifeLine staff
for review prior to distribution and advertising;
 i-wireless will comply with CPUC User Fee and Public Purpose Program
surcharge requirements. Failure to comply with fee and surcharge remittance
requirements may lead to enforcement action including, but not limited to,
revocation of i-wireless’s ETC designation and/or wireless identification
registration authority;
 i-wireless will file a copy of updated ZIP+4 code data list with the Director of CD
and the California LifeLine Administrator; and,
 i-wireless will post safety-concerns about wireless telephone service coverage
limitations on distributed materials and on its company website.

COMMENTS

In compliance with P.U. Code § 311(g), the Commission emailed a notice letter on
August 12, 2014, informing all parties on the eligible telecommunications carrier service
list of the availability of this resolution for public comments at the Commission’s website
www.cpuc.ca.gov. The notice letter also informed parties that the final conformed
resolution adopted by the Commission will be posted and available at this same website.

CD did not receive comments on this resolution.

FINDINGS AND CONCLUSIONS

1. i-wireless, LLC is a prepaid wireless service provider that uses the Sprint
Spectrum, L.P. network on a wholesale basis under the brand designation “Access
Wireless.” Its principal offices are at 1 Levee Way, Suite 3104, Newport, Kentucky,
41071.

2. On May 21, 2007, the Commission issued i-wireless, LLC., its Wireless
Identification Registration number U-4372-C allowing it to operate as a
commercial mobile radio service (CMRS) provider to the public in California.

3. On July 30, 2012, i-wireless, LLC filed Tier III Advice Letter (AL) 2 requesting ETC
designation to offer only federal Lifeline prepaid wireless service to eligible
customers under the brand “Access Wireless.” i-wireless, LLC proposed four
plans, one a Lifeline-only offering for $3 per month and choice of three retail
plans, that apply a $15 discount of $9.25 federal support amount plus $5.75
company credit.

4. i-wireless, LLC only seeks federal Lifeline support and does not seek California
LifeLine fund support.

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5. On August 16, 2012, the Division of Ratepayer Advocates filed a protest stating
the proposed Lifeline discount amount of $15 needed clarification and the
proposed plans did not offer sufficient minutes of use.

6. On August 22, 2012, i-wireless responded to the Division of Ratepayer Advocates
protest explaining that the $15 discount includes the maximum federal support
amount of $9.25 added to a $5.75 company credit and giving support for the low-
minute plans.

7. i-wireless, LLC shall file all federal annual reports (e.g., Form 481, etc.) and
compliance reports with the Federal Communications Commission and, as
directed, with this Commission.

8. i-wireless, LLC shall file the required service plan information pursuant to 47
C.F.R. § 54.401(d) with the Universal Service Administrative Company (USAC).
USAC will review the service plans to ensure they meet the federal Lifeline
requirements. Once accepted, a copy of the information submitted to USAC and a
copy of i-wireless, LLC’s certification of approval from the USAC shall be
provided to the Communications Division Director within 30 days of receipt from
USAC.

9. i-wireless, LLC meets the Federal Communications Commission’s Eligible
Telecommunications Carrier requirements.

10. i-wireless, LLC requested waivers of California LifeLine service elements: (4) the
ability to receive free incoming calls, (11) free provision of one directory listing
per year, (12) availability of free white pages telephone directory, (15) free access
to 800 and 800-like toll-free numbers, (19) free access to toll-blocking service, (20)
free access to toll-control service, and (21) access to two residential telephone lines
if a low-income household with a disabled person requires both lines to access
California LifeLine.

11. It is reasonable to grant waivers for California LifeLine elements (4), (11), (12), and
(15) because they do not apply to wireless service providers and the Commission
has granted such waivers in the past to other federal Lifeline wireless service
providers.

12. It is reasonable to grant waivers to California LifeLine elements (19) and (20)
because they do not apply to i-wireless, LLC’s proposed service plans since there
is no distinction between local and long distance calling.

13. It is reasonable to deny i-wireless’ request for a waiver to California LifeLine
element (21) because other federal Lifeline wireless providers comply with this
service element currently and because Decision 14-01-032 maintains this element

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as a requirement in the California LifeLine rules for wireless carriers (Attachment
D, Appendix A-2, service element (17)).

14. i-wireless, LLC commits to comply with all General Order 153 rules including the
Lifeline enrollment process, working with California’s Third Party Administrator
(TPA) to establish customer eligibility, and to cooperate with the California
LifeLine team in the review and approval of its federal Lifeline advertisement
materials.

15. i-wireless, LCC commits to comply with General Order 153’s application,
verification, and renewal processes to establish customer eligibility with the
California LifeLine Administrator and will not offer federal Lifeline wireless plans
to customers until the California LifeLine Administrator approves their Lifeline
eligibility.

16. i-wireless, LLC will label clearly its wireless offerings as federal Lifeline service to
minimize customer confusion between the California LifeLine and federal Lifeline
programs, to include adequate information about the potential coverage and
service quality issues, and to provide copies to Communications Division of all
marketing materials including, but not limited to, customer service representative
scripts, internet marketing, and posters and brochures, for CPUC California
LifeLine staff to review and approval prior to publication and distribution. We
find this recommendation reasonable and adopt it.

17. i-wireless, LLC commits to comply with CPUC User Fee and Public Purpose
Program surcharge requirements. Failure to comply with fee and surcharge
remittance requirements may lead to enforcement action including, but not
limited to, revocation of i-wireless, LLC’s Eligible Telecommunications Carrier
designation and/or wireless identification registration authority.

18. i-wireless, LLC will utilize the ZIP+4 code data of the Small LECs’ service areas to
ensure that current customers of the Small LECs are not accepted as its federal
Lifeline customers. We find this recommendation reasonable and adopt it.

19. i-wireless, LLC shall be authorized to receive from the Small LECs an updated
ZIP+4 code data in their corresponding service areas within 30 days of the
effective date of this Resolution. i-wireless shall also be authorized to receive
from the Small LECs, on an as-needed basis, any update to the ZIP+4 code data to
i-wireless, LLC, as with all other wireless designated ETCs in California. i-
wireless, LLC shall file a copy of any updated ZIP+4 code data with the
Communications Division Director and the California LifeLine Administrator
(CLA). The ZIP+4 code data shall be provided in an MS Excel file (xls) format via
email to the CD director and to the CLA in a format specified by the CLA.

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20. Communications Division finds that i-wireless, LLC’s proposed federal Lifeline
wireless plans meet federal ETC criteria for public interest determination with
increased competitive choice, convenience, security with mobility, ability to
purchase additional usage, and ability to send and receive text messages in a
prepaid plan.

21. Communications Division finds these i-wireless, LLC’s federal Lifeline wireless
plans to have equal or better value in its Lifeline plan pricing for low-income
customers:
 550 Minutes of talk and text, a Lifeline-only offering for $5.75 per month.
 1,000 Minutes of talk and text with 200 MB data, a Lifeline-only offering for
$12.65 per month.
 Unlimited Talk Plan with unlimited text and 500 MB data for $25.75 per month,
retail value of $35.
 Unlimited Talk Plan with unlimited text and 2 GB data for $40.75 per month,
retail value of $50.

22. Communications Division finds i-wireless’ Unlimited Talk Plan with unlimited text
and 3 GB data for $65.75 per month (a retail value of $75 less the $9.25 federal
support) to be too expensive when compared to other currently available federal
Lifeline wireless and off-the-shelf retail wireless plans and therefore does not
recommend approval.

23. Communications Division’s recommendation to use the Improper Payments
Elimination and Recovery Act of 2010 (IPERA) 1.5% as a guideline for allowable
duplicates is reasonable until some other guideline is adopted by the FCC or the
CPUC.

24. Communications Division conducted due diligence review to determine i-
wireless, LLC’s fitness as it relates to business practice behavior and customer
protection that may call into question its fitness to be granted ETC designation to
serve California consumers. Communications Division found no fitness issues.

25. The Commission may pursue an enforcement action which may include fines,
penalties, and the revocation of ETC designation and/or wireless identification
registration authority should substantive issues emerge after this ETC is
approved which raises public interest questions about i-wireless, LLC’s
operations.

26. For public safety reasons, i-wireless, LLC shall clearly inform Lifeline customers
that coverage limitations may affect wireless mobile service including E-911/911
emergency calls. Disclosures shall include, but are not limited to, clear statements
on all marketing materials and the company website.

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27. Communications Division recommends that the Commission’s Eligible
Telecommunications Carrier rule requiring filing of a Tier II Advice Letter to
request approval for any future changes to the federal Lifeline wireless plans
approved in this Resolution be applied only to i-wireless, LLC’s 500 Minutes and
1,000 Minutes plans that are not based on a retail plan currently available to all
prospective customers at the time of filing. Such request shall demonstrate that
the changes comply with Resolution T-17002, i.e. Appendix A-Sections II-E: Local
Usage and II-G. Public Interest Determination, all applicable General Order 153
rules, and pricing rules pursuant to Decision 10-11-033 or as modified and/or
updated by subsequent Decisions and/or Resolutions effective at the time of the
request. We find Communications Division’s recommendation reasonable and
adopt it.

28. For changes to i-wireless, LLC’s two Unlimited Lifeline plans that are based on
retail service offerings available to all prospective customers, not just Lifeline
customers, changes from one retail plan to another retail plan should be handled
via an Information-Only filing, consistent and in compliance with General Order
96-B General Rules 3.9, 6.1, and 6.2, and Telecommunications Industry Rule 2.

29. On August 12, 2014, the Commission emailed a draft of this resolution to the
eligible telecommunications carrier service list for public comments.

30. Communications Division did not receive comments on this resolution.

THEREFORE, IT IS ORDERED that:

1. The Commission conditionally approves i-wireless, LLC’s (U-4451-C), under the
brand designation “Access Wireless,” request for an eligible telecommunications
carrier (ETC) designation to provide federal Lifeline prepaid wireless service
throughout California in the service areas of the uniform regulatory framework
carriers, excluding the small local exchange carrier (Small LECs) service areas.

2. i-wireless, LLC’s ETC designation approval shall be contingent upon the
following: 1) i-wireless, LLC shall file required annual reports and compliance
reports with the Federal Communications Commission and this Commission, as
directed; 2) i-wireless, LLC shall submit to the Communications Division Director
a copy of the information submitted to Universal Service Administrative
Company and a copy of i-wireless, LLC’s certification of approval from the USAC
within 30 days of receipt from USAC of its compliance with 47 C.F.R. § 54.401(d)
related to its federal Lifeline wireless plan; 3) i-wireless, LLC shall submit its
marketing materials to the CPUC California LifeLine staff for approval prior to
distribution and publication; and, 4) i-wireless, LLC shall clearly identify its
wireless mobility safety content on all distributed federal Lifeline materials and
on the company website.

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3. i-wireless, LLC shall offer these four federal Lifeline wireless service plans under
the brand designation “Access Wireless”:
 550 Minutes of talk and text, a Lifeline-only offering for $5.75 per month.
 1,000 Minutes of talk and text with 200 MB data, a Lifeline-only offering for
$12.65 per month.
 Unlimited Talk Plan with unlimited text and 500 MB data for $25.75 per month,
retail value of $35.
 Unlimited Talk Plan with unlimited text and 2 GB data for $40.75 per month,
retail value of $50.
Lifeline-only customers can purchase additional airtime minutes in
denominations of $5 for 100 minutes ($0.05 per minute), $10 for 200 minutes
($0.05 per minute), and $25 for 300 minutes ($0.083 per minute).

4. i-wireless, LLC shall use a Tier II Advice Letter to request approval for any future
changes to its federal Lifeline 500 Minutes and 1,000 Minutes plans that are not
based on a retail plan. Such request shall demonstrate that the changes comply
with Resolution T-17002, i.e. Appendix A-Sections II-E: Local Usage and II-G. Public
Interest Determination, all applicable General Order 153 rules, and pricing rules
pursuant to Decision 10-11-033 or as modified and/or updated by subsequent
Decisions and/or Resolutions effective at the time of the request.

5. i-wireless, LLC shall file an Information-Only filing, consistent and in compliance
with General Order 96-B General Rules 3.9, 6.1, and 6.2, and Telecommunications
Industry Rule 2, for changes to its two Unlimited Lifeline plans because they are
based on retail service offerings available to all prospective customers.

6. i-wireless, LLC shall comply with General Order 153’s enrollment application,
verification, and renewal processes under the review of the California LifeLine
Administrator which establishes customer eligibility.

7. i-wireless, LLC shall be authorized waivers for these six requested service
elements of California LifeLine: (4) the ability to receive free incoming calls; (11)
free provision of one directory listing per year, (12) availability of free white
pages telephone directory, (15) free access to 800 and 800-like toll-free numbers,
(19) free access to toll-blocking service, and (20) free access to toll-control service.

8. i-wireless, LLC shall clearly label its offerings as federal Lifeline service to minimize
customer confusion between the California LifeLine and federal Lifeline
programs, shall include adequate information about the potential coverage and
service quality issues, and shall provide copies of all marketing materials
including, but not limited to, customer service representative scripts, internet
marketing, and posters and brochures for Communications Division’s California
LifeLine staff review and approval prior to distribution of marketing publications.

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9. i-wireless, LLC shall implement the ZIP+4 codes to screen customers and ensure
that current customers of the Small LECs are not accepted as federal Lifeline
wireless customers with i-wireless, LLC.

10. i-wireless, LLC shall be authorized to receive from the Small LECs an updated list
of the ZIP+4 code data in their service areas within 30 days of the effective date of
this Resolution. i-wireless shall also be authorized to receive from the Small LECs
on an as-needed basis any update to the ZIP+4 code data to i-wireless, LLC, the
same as with all other active wireless designated ETCs in California. A copy of
any updated ZIP+4 code data shall be filed with the Communications Division
Director and the California LifeLine Administrator. The ZIP+4 code data shall be
provided in an MS Excel file (.xls) format via email to the Communications
Division Director and to the CLA in a format specified by the CLA.

11. i-wireless, LLC shall comply with all applicable Commission rules and
regulations including the reporting and payment of Public Utilities Commission
User Fees and Public Purpose Program surcharges. Failure to do so may result in
the revocation of its ETC designation and wireless identification registration
authority to operate in California.

This Resolution is effective today.

I certify that the foregoing resolution was duly introduced, passed, and adopted at a
conference of the Public Utilities Commission of the State of California held on
September 11, 2014, the following Commissioners voting favorably thereon:

MICHAEL R. PEEVEY
President
MICHEL PETER FLORIO
CATHERINE J.K. SANDOVAL
CARLA J. PETERMAN
MICHAEL PICKER
Commissioners

Resolution T- 17449
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APPENDIX A
Resolution T-17449

Resolution T- 17449
CD/ABA

A-1

Attachment A
Resolution T-17449
i-wireless, LLC branded as Access Wireless

Proposed Service Area for Federal Lifeline Wireless
ETC Service in California

Resolution T- 17449
CD/ABA

A-2

Attachment B
Resolution T-17449
i-wireless, LLC

General Order 153 – Service Elements of California LifeLine

California LifeLine is composed of the service elements set forth below. All California LifeLine subscribers
are entitled to receive every one of the service elements of California LifeLine, and every California
LifeLine Service Provider is required to offer all of the service elements of California LifeLine to each of its
subscribers. The service elements of California LifeLine are as follows:

1 Access to (a) single party local exchange service or (b) service that is equivalent, in all substantial
respects, to single party local exchange service.
2 Access to all interexchange carriers offering service in the California LifeLine subscriber’s local
exchange.
3 Ability to place calls.
4 Ability to receive free unlimited incoming calls.
5 Free touch-tone dialing.
6 Free unlimited access to 911/E-911.
7 Access to local directory assistance (DA). Each California LifeLine Service Provider shall offer to its
subscribers the same number of free DA calls that the California LifeLine Service Provider provides to
its non-California LifeLine residential customers.
8 Access to foreign Numbering Plan Areas.
9 California LifeLine rates and charges.
10 Customer choice of local Flat-Rate Service or Measured-Rate Service. The 14 small ILECs identified in
D. 96-10-066 do not have to offer subscribers the choice of local Flat or Measured-Rate Service, unless
the small ILEC offers this option to its non- California LifeLine residential customers.
11 Free provision of one directory listing per year as provided for in D. 96-02-072.
12 Free white pages telephone directory.
13 Access to operator service.
14 Voice grade connection to the public switched telephone network.
15 Free access to 800 or 800-like toll-free services.
16 Access to telephone relay services as provided for in Public Utilities Code §2881 et seq.
17 Toll-free access to customer service for information about California LifeLine, service activation,
service termination, service repair, and bill inquiries.
18 Toll-free access to customer service representatives fluent in the same language (English and non-
English) in which California LifeLine was originally sold.
19 Free access to Toll-Blocking Service.
20 Free access to Toll-Control Service but only if (i) the California LifeLine Service Provider is capable of
offering Toll-Control Service and (ii) the California LifeLine subscriber has no unpaid bill for toll
service.
21 Access to two residential telephone lines if a low-income household with a disabled person requires
both lines to access California LifeLine.
22 Free access to the California Relay Service via the 711 abbreviated dialing code.

GO 153 (Effective December 1, 2011 – D.10-11-033, Resolution T-17321)

(END OF APPENDIX A)