20240709Application Supplement.pdf

RECEIVED
Tuesday, July 9, 2024 10:23:28 AM
IDAHO PUBLIC
UTILITIES COMMISSION
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
TruConnect Communications, Inc. )
Docket No. TCC-T-24-01
Application for Designation as an )
Eligible Telecommunications Carrier )
SUPPLEMENT TO APPLICATION OF TRUCONNECT
COMMUNCIATIONS,INC. FOR DESIGNATION AS AN ELIGIBLE
TELECOMMUNICATIONS CARRIER IN THE STATE OF IDAHO
TruConnect Communications, Inc. ("TruConnect" or the "Company"), hereby files this
Supplement to its Application for Designation as an Eligible Telecommunications Carrier in the
State of Idaho ("Application") filed in this docket on March 4, 2024. By this Supplement,
TruConnect provides additional information regarding the Company and its affiliate, Sage
Telecom Communications, LLC ("Sage Telecom"), and updates the Commission regarding other
states in which the Company has been designated as an eligible telecommunications carrier
("ETC").
In the ETC Application, TruConnect explained that the Company is a subsidiary of TSC
Acquisition Corporation("TSC") and that TSC also owns Sage Telecom. In 2019, the Idaho
Public Utilities Commission ("Commission") designated Sage Telecom as an ETC.' Sage
Telecom and TruConnect, as wireless resellers, each have a Lifeline compliance plan approved
by the Federal Communications Commission(FCC). However, Sage Telecom and TruConnect
1 See In the Matter of the Application of Sage Telecom Communications, LLC for Designation as
an Eligible Telecommunications Carrier, Case No. SAG-T-19-01, Order No. 34314 (April 17,
2019).

have different ETC designation footprints. To date,both Sage Telecom and TruConnect have
used the "TruConnect"brand to market their Lifeline service offers. The pending TruConnect
ETC application is part of a broader multi-state effort to establish an as broad as possible ETC
designation footprint for TruConnect. Once that ETC designation expansion process has been
completed for TruConnect, TSC intends for the existing Lifeline business to utilize the
TruConnect ETC designations and the TruConnect brand, while the Sage ETC designations
would be used to support a distinct Lifeline brand with differentiated service offerings for
consumers and potentially additional investment resulting in differentiated ownership. Because
the "prepaid"wireless marketplace is dynamic, TSC cannot settle on a brand and market strategy
for Sage Telecom until the multi-state project to expand TruConnect's ETC footprint has been
completed. Regardless, grant of TruConnect's ETC Application will serve the public interest as
it will allow TSC to utilize the Sage Telecom ETC designations in Idaho and elsewhere to
develop and support a new Lifeline brand with differentiated service offerings and marketing
strategies that will provide low-income consumers with more competitive choices.
TruConnect further informs the Commission that it has been designated as an ETC in the
following states where Sage Telecom is also an ETC: Colorado, Hawaii, Iowa, Kentucky,
Maryland, Michigan, Minnesota, Mississippi, Missouri,New York, South Carolina, Utah,West
Virginia,Wisconsin and Wyoming. Each of the relevant public utility commissions in those
states found that designation of TruConnect as an ETC was in the public interest.
For the reasons stated in the ETC Application and in this Supplement, TruConnect
respectfully requests that the Commission promptly designate TruConnect as an ETC in the State
of Idaho for the purpose of participating in the Lifeline program.

Respectfully submitted,
Debra McGuire Mercer
Nelson Mullins Riley& Scarborough LLP
101 Constitution Avenue,NW
Suite 900
Washington, DC 20001
[phone]
debra.mercer&nelsonmullins.com
Counsel for TruConnect Communications, Inc.
July 9, 2024