20240730Decision Memo.pdf

DECISION MEMORANDUM
TO: COMMISSIONER ANDERSON
COMMISSIONER HAMMOND
COMMISSIONER LODGE
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL
FROM: MICHAEL DUVAL
DEPUTY ATTORNEY GENERAL
DATE: JULY 30, 2024
SUBJECT: IN THE MATTER OF TRUCONNECT COMMUNICATIONS, INC.'S
APPLICATION FOR DESIGNATION AS AN ELIGIBLE
TELECOMMUNICATIONS CARRIER; CASE NO. TCC-T-24-01.
On March 4, 2024, TruConnect Communications, Inc. ("Company") applied to the Idaho
Public Utilities Commission ("Commission") for designation as an Eligible Telecommunications
Carrier("ETC") in the State of Idaho. The Company requested designation as an ETC for the sole
purpose of providing Lifeline services. The Company asked that it be allowed to participate and
receive reimbursement from the Idaho Telephone Service Assistance Program accordingly.
On June 20, 2024, the Commission issued a Notice of Application and set deadlines for
public comments and the Company's reply. Order No. 36227.
The Company submitted materials supplementing its Application on July 9, 2024.
Staff submitted comments on July 11, 2024. Staff s Comments argued that the Company's
request for ETC status should be denied.Among other things, Staff argued that the Company failed
to meet the necessary requirements for an ETC to remain functional in an emergency and promote
the public interest.
The Company submitted Reply Comments on July 18,2024. The Company argued that the
items of non-compliance referred to by Staff were not actually requirements for obtaining ETC
status. Therefore, the Company argued it should not be denied ETC status for not abiding by these
non-mandatory items.
Staff has reviewed the Company's Reply Comments. While Staff believes that its
recommendation was appropriate, Staff believes that adding additional documentation and
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analysis to the record would place the Commission in the best position to make a fully informed
decision.
STAFF RECOMMENDATION
Staff recommends the Commission issue a Notice of Supplemental Comment and Reply
Deadlines establishing an August 16, 2024, Staff supplemental comment deadline and an August
30, 2024, Company supplemental reply comment deadline.
COMMISSION DECISION
Does the Commission wish to issue a Notice of Supplemental Comment Deadlines
establishing an August 16, 2024, Staff supplemental comment deadline and an August 30, 2024,
Company supplemental reply comment deadline?
Michael Duval
Deputy Attorney General
I:\Legal\TELECOWTCCT2401\TCCT2401_dec2_md.docx
DECISION MEMORANDUM 2