20240909Additional Comments.pdf

Additional Comments of the ITA In Response to 2024 Annual IUSF Report – 1

CYNTHIA A. MELILLO (ISB # 5819)
Cynthia A. Melillo PLLC
8385 W. Emerald Street
Boise, Idaho 83704
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]

Attorney for Idaho Telecom Alliance

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION.

ADDITIONAL COMMENTS OF THE
IDAHO TELECOM ALLIANCE IN
RESPONSE TO 2024 ANNUAL IDAHO
UNIVERSAL SERVICE FUND REPORT

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Case No. GNR – T – 24 - 05

COMMENTS OF THE IDAHO TELECOM ALLIANCE IN RESPONSE TO 2024 ANNUAL
IDAHO UNIVERSAL SERVICE FUND REPORT

Idaho Telecom Alliance (“ITA”), by and through its undersigned attorneys, hereby
submits to the Commission these additional comments in response to the
Administrator’s Addendum to the Administrator’s Report of the Idaho Universal
Service Fund (“IUSF”), filed September 4, 2024, and Commission Staff’s amended
Decision Memo in this matter, dated September 10, 2024, and filed September 6,
2024. The ITA is an advocacy group for 14 independent telecommunications
companies in Idaho. All recipients of the IUSF are members of the ITA, and thus the
ITA has a direct interest in the IUSF.
BACKGROUND
The ITA originally filed comments to the 2024 Annual Report of the
RECEIVED
Monday, September 09, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
Additional Comments of the ITA In Response to 2024 Annual IUSF Report – 2

Administrator of the Idaho Universal Service Fund on August 30, 2024. In the ITA’s
comments, the ITA proposed that the Public Utilities Commission require the
recipients of the IUSF to raise service rates to the Idaho statewide average. The ITA
also sugg ested raising surcharge rates to a level the Commission deemed
appropriate, and adjusting distributions to a level that still meets the recipient’s needs
while also allowing for survival of the IUSF.
Commission Staff in its Decision Memo filed on August 30, 2024, Staff
recommended that the Commission adopt Option 3 as set forth in the Administrator’s
report. Option 3 required raising rates to 125% of the statewide average, adjusted
surcharge rates and reducing disbursements from the IUSF by almost fifty percent
(50%).
At the Decision Meeting of the Commission on September 3, 2024, Commission
Staff and the ITA presented testimony.
The Commission voted to defer any decision on this matter until a date certain
allowing for additional information to be provided.
Following the Decision Meeting, Commission Staff and representatives of the
ITA worked through the issues and arrived at a n option each party believes to be in
the best interest of both the recipient companies and the IUSF.
ITA has reviewed the Adden dum and the revised Decision Memorandum of
Commission Staff and believes it accurately represents the agreement of the parties.
ITA’S RECOMMENDATION
ITA recommends that the Commission adopt the option presented in the Administrator’s
Addendum and Commission Staff’s revised Decision Memo.
In addition, the ITA again requests the Commission’s assistance in bringing stakeholders
together and promoting changes to the USF statutes to make the fund viable into the future.

Additional Comments of the ITA In Response to 2024 Annual IUSF Report – 3

RESPECTFULLY SUBMITTED this 9th day of September 2024.

Cynthia A. Melillo PLLC

By: /Cynthia A. Melillo/
Cynthia A. Melillo

Attorney for Idaho Telecom Alliance

Additional Comments of the ITA In Response to 2024 Annual IUSF Report – 4

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 9th day of September 2024, I caused to be served a true
and correct copy of the foregoing by the method indicated below, and addressed to the following:

Monica Barrios-Sanchez, Commission
Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd. Building 8, Suite
201-A
Boise, ID 83714

P.O. Box 83720
Boise, ID 83720-0074
U.S. Mail
Hand Delivered
Overnight Mail
Facsimile
Electronic Mail

/Cynthia A. Melillo/
Cynthia A. Melillo