20241216Application.pdf

RECEIVED
Monday, December 16, 2024
Ronald L. Williams, ISB #3034 IDAHO PUBLIC
HAWLEY TROXELL UTILITIES COMMISSION
877 W. Main Street, #200
Boise, ID 83702
208-344-6633 (telephone)
208-954-5253 (facsimile)
[e-mail]
Angela F. Collins
CAHILL GORDON&REINDEL LLP
1990 K Street,N.W., Suite 950
Washington, D.C. 20006
202-862-8930 (telephone)
212-269-5420 (facsimile)
[e-mail]
Before the
IDAHO PUBLIC UTILITIES COMMISSION
In the Matter of )
Cable One VOIP LLC d/b/a Sparklight ) Case No. CAB-T- 24-01
Request to Relinquish Designation as an )
Eligible Telecommunications Carrier )
REQUEST TO RELINQUISH ETC DESIGNATION
In accordance with 47 U.S.C. § 214(e)(4), Federal Communications Commission
("FCC") Rule 54.205, and Idaho statutes,' Cable One VoIP LLC d/b/a Sparklight (the
"Company"), by its attorneys, respectfully submits this request to the Idaho Public Utilities
Commission (the "Commission") to relinquish the Company's eligible telecommunications
carrier("ETC") designation in Idaho. In support of this request, the Company states:
1. The Company is a Delaware limited liability company with a principal place of
business located at 210 E. Earll Drive, Phoenix, Arizona 85012. The Company is a wholly
owned subsidiary of Cable One, Inc. ("Cable One"), a publicly traded Delaware corporation
1 Idaho Stat. § 62-6101)(4).
1

(NYSE: CABO). Cable One and its wholly owned subsidiaries provide cable/video, Internet
access, broadband, and voice services in 23 states, including Idaho.
2. In January 2020, the FCC adopted the framework and rules for Phase I of the
Rural Digital Opportunity Fund ("RDOF") auction (Auction 904) to connect millions of rural
homes and small businesses to fixed high-speed broadband networks.2 The Company's parent
Cable One participated in Auction 904 as a member of the Wisper-CABO 904 Consortium (the
"Consortium"). On December 7, 2020, the FCC announced the results of Auction 904, and the
Consortium was a winning bidder in numerous states, including Idaho. Pursuant to the FCC's
process for distributing winning bids among related entities, the Consortium assigned the
Company as the entity to receive RDOF support for certain winning bids in the state of Idaho.
3. The FCC required the Company (and other RDOF winning bidders) to obtain
high-cost ETC designation in a state as a condition for receiving RDOF funding in that state. On
April 19, 2021, in Case No. CAB-T-21-01, the Commission designated the Company as an ETC
in 57 census block groups in which the Company was deemed the winning bidder in Auction 904
as well as additional geographic areas in which the Company requested to be designated as an
ETC for the provision of federal Lifeline services.
4. On July 26, 2021, the FCC provided the Company (and numerous other RDOF
winning bidders) with a list of census blocks covered by the Company's winning RDOF bids in
which "concerns" had been raised that those areas "are already served by one or more service
providers that offer 25/3 Mbps broadband service or otherwise raise significant concerns about
wasteful spending, such as parking lots and international airports."3 The FCC Letter asked the
2 Rural Digital Opportunity Fund, et al., 35 FCC Rcd 686(2020) ("RDOF Order").
3 Letter from Michael Janson, FCC, to Cable One VoIP LLC (July 26, 2021) ("FCC Letter"),
https://us-fcc.app.box.com/s/lg4igpj t8ukal4wve6hbrkbs 5473 kpcw/file/83 863 8500240.
2

Company and other RDOF winning bidders to review their bids based on "significant concerns
about the best use of[the public's] limited universal service funds."4
5. In response to the FCC Letter, on August 16, 2021, the Company informed the
FCC that it would no longer pursue RDOF support for certain census blocks identified in the
FCC Letter based on the Company's determination that those census blocks either contained no
serviceable locations or already received broadband service at 25/3 Mbps or better. The
Company also indicated it would further review its other RDOF winning bids to determine if the
public interest would be served by relinquishing RDOF support for any of the Company's other
winning bids.
6. On August 24, 2021, the Company informed the FCC that it would no longer seek
RDOF support in several additional census blocks, including some of those for which it received
ETC designation in Idaho.5 In January and May 2022, the FCC acknowledged those Idaho
census blocks the Company would no longer serve.6
7. On August 1, 2022 (as amended January 13, 2023), the Company filed a request
with the Commission in Case No. CAB-T-22-01 to partially relinquish its ETC designation for
certain RDOF areas and to relinquish the additional Lifeline ETC designation it received for non-
RDOF areas. The Commission granted the Company's request in Order No. 35688 dated
February 24, 2023.
4 FCC Letter at n.4.
5 FCC AU Docket No. 20-34, et al., Petition for Waiver (filed Aug. 24, 2021),
https://www.fcc.gov/ecfs/search/search-filings/filing/108240356730305; FCC AU Docket No. 20-34, et
al., Amended Petition for Waiver (filed May 12, 2022), https://www.fcc.gov/ecfs/search/search-
filings/filing/1051115 80221676.
6 Rural Digital Opportunity Fund Support for 5,254 Winning Bids Ready to Be Authorized; Bid
Defaults Announced, 37 FCC Rcd 724 (2022); Rural Digital Opportunity Fund Support for 2,061
Winning Bids Ready to Be Authorized;Bid Defaults Announced, 37 FCC Red 5748 (2022).
3

S. On October 17, 2024, the Company notified the FCC that it was withdrawing
from the RDOF program for the state of Idaho.7 The Company explained that its parent Cable
One had made significant investment to deploy broadband in new geographic areas and to
increase broadband speeds in existing areas, but the planned RDOF deployment in Idaho was no
longer viable due to unforeseeable costs that increased dramatically since the conclusion of the
RDOF auction. On November 27, 2024, the FCC issued a Public Notice acknowledging the
Company's withdrawal from the RDOF program for the state of Idaho.8
9. Accordingly, the Company files the instant request to fully relinquish its ETC
designation in the state of Idaho.
10. Federal law provides an objective standard for ETC relinquishment: a state
commission "shall permit" an ETC to relinquish its ETC designation "in any area" so long as
that area is served by more than one ETC.9 FCC Rule 54.205 requires an ETC to "give advance
notice to the state commission of such relinquishment."10 Idaho law similarly states the
Commission "shall permit" an ETC to relinquish its ETC designation for an area served by more
than one ETC upon no less than 30 days' notice to the Commission." The Company meets the
established standard for ETC relinquishment.
https://www.fcc.gov/ecfs/document/1017216511117/1.
8 FCC AU Docket No. 20-34, et al., Wireline Competition Bureau Announces Mercury Wireless
Indiana, LLC; Mercury Wireless Kansas, LLC; PVT Networks, Inc.; Cable One, VoIP LLC d/b/a
Sparklight; and Fidelity Cablevision, LLC Defaults on Certain RDOF Census Block Groups in Idaho,
Illinois, Indiana, Kansas, Michigan, Missouri, and New Mexico, Public Notice, DA 24-1199 (rel. Nov.
27, 2024), https://www.fcc.gov/document/wcb-announces-mercury-pvt-cable-one-and-fidelity-rdof-
defaults.
9 47 U.S.C. § 214(e)(4); 47 C.F.R. § 54.205.
10 47 C.F.R. § 54.205(a).
11 Idaho Stat. § 62-6101)(4).
4

11. To the Company's knowledge, there are numerous other ETCs operating in the
geographic areas the Company is relinquishing, including wireless ETCs and incumbent local
exchange carriers ("ILECs"), as shown in Exhibit 1.
12. No consumer will be impacted by the Company's request to relinquish its ETC
designation in Idaho because the Company does not serve any customers pursuant to its ETC
designation. Thus, no customer notice is required in connection with the relinquishment.
13. Finally, there will be no discontinuance of service associated with the
relinquishment of the Company's ETC designation because the Company does not currently
serve any customers in Idaho.
14. Commission rules require an ETC applicant seeking designation for "any part of
tribal lands" to provide a copy of its application to the affected tribal government or tribal
regulatory authority, as applicable.12 A portion of one census block group in the Company's
RDOF area (census block group 160059400001 in Bannock County) overlaps with the Fort Hall
Reservation on which the Shoshone-Bannock Tribes are located. The Company provided a copy
of its original application for ETC designation to the Shoshone-Bannock Tribal Attorney's
Office, as well as its request for partial relinquishment approved in Order No. 35688, and will
provide a copy of the instant request to the Shoshone-Bannock Tribal Attorney's Office via
electronic mail and U.S. Mail within one (1) business day of this request being filed with the
Commission.
12 Case No. WST-T-05-1, The Application of WWC Holding Co., Inc. dba Cellular-One Seeking
Designation as an Eligible Telecommunications Carrier that may Receive Federal Universal Service
Support,Order No. 29841 (Aug. 4, 2005) ("ETC Order").
5

CONCLUSION
WHEREFORE, for the foregoing reasons, the Company respectfully requests that the
Commission issue an order confirming the Company's relinquishment of its ETC designation in
its entirety.
Dated: December 16, 2024 Respectfully submitted,
CABLE ONE VOIP LLC
D/B/A SPARKLIGHT
/s/Rom,,gld L. Willign s
Ronald L. Williams, ISB #3034
Hawley Troxell
877 W. Main Street, #200
Boise, ID 83702
208-344-6633 (telephone)
208-954-5253 (facsimile)
[e-mail]
Angela F. Collins
Cahill Gordon&Reindel LLP
1990 K Street,N.W., Suite 950
Washington, D.C. 20006
202-862-8930 (telephone)
212-269-5420 (facsimile)
[e-mail]
Its Attorneys
6

EXHIBIT 1
The Company seeks to relinquish ETC designation in the following areas, which are the
census block groups for which it received RDOF authorization. Other known ETCs in the area
also are listed, which were determined using the "Companies Near Me" search function available
on the Universal Service Administrative Company(USAC)website.
County RDOF Census Located Other ETCs
Block Group Near
Ada 160010102011 Star, Eagle CenturyLink; SafeLink/Straight Talk/Tracfone;
TruConnect; Gen Mobile; Assurance Wireless;
Access Wireless; AirTalk Wireless
Ada 160010105011 Boise CenturyLink; Gen Mobile; TruConnect;
SafeLink/Straight Talk/Tracfone; Assurance
Wireless; AirTalk Wireless; Access Wireless
Ada 160010105031 Boise CenturyLink; Gen Mobile; TruConnect;
SafeLink/Straight Talk/Tracfone; Assurance
Wireless; AirTalk Wireless; Access Wireless
Bannock 160050002001 Chubbuck, CenturyLink; AT&T Mobility; SafeLink/Straight
Alameda Talk/Tracfone; Syringa Wireless; Assurance
Wireless; Access Wireless; Gen Mobile; AirTalk
Wireless; TruConnect
Bannock 160050002003 Inkom CenturyLink; SafeLink/Straight Talk/Tracfone;
Syringa Wireless; AirTalk Wireless; Assurance
Wireless; Access Wireless; Gen Mobile;
TruConnect
Bannock 160050005001 Pocatello CenturyLink; AT&T Mobility; Access Wireless;
TruConnect; Assurance Wireless; AirTalk
Wireless; Gen Mobile; Syringa Wireless;
SafeLink/Straight Talk/Tracfone
Bannock 160050006002 Pocatello CenturyLink; AT&T Mobility; Access Wireless;
TruConnect; Assurance Wireless; AirTalk
Wireless; Gen Mobile; Syringa Wireless;
SafeLink/Straight Talk/Tracfone
1

Bannock 160050015005 Pocatello CenturyLink; AT&T Mobility; Access Wireless;
TruConnect; Assurance Wireless; AirTalk
Wireless; Gen Mobile; Syringa Wireless;
SafeLink/Straight Talk/Tracfone
Bannock 160059400001 Chubbuck CenturyLink; Assurance Wireless; TruConnect;
SafeLink/Straight Talk/Tracfone; AirTalk
Wireless; Syringa Wireless; Gen Mobile; Access
Wireless
Bonneville 160199701002 Ammon CenturyLink; Gen Mobile; Syringa Wireless;
SafeLink/Straight Talk/Tracfone; TruConnect;
AirTalk Wireless; Access Wireless; Assurance
Wireless
Bonneville 160199715001 Idaho Falls CenturyLink; AT&T Mobility; SafeLink/Straight
Talk/Tracfone; AirTalk Wireless; Gen Mobile;
Assurance Wireless; Access Wireless;
TruConnect; Syringa Wireless
Bonneville 160199715002 Idaho Falls CenturyLink; AT&T Mobility; SafeLink/Straight
Talk/Tracfone; AirTalk Wireless; Gen Mobile;
Assurance Wireless; Access Wireless;
TruConnect; Syringa Wireless
Canyon 160270219032 Middleton CenturyLink; SafeLink/Straight Talk/Tracfone;
AirTalk Wireless; Assurance Wireless; Gen
Mobile; TruConnect; Access Wireless
Canyon 160270223002 Warrens, CenturyLink; AirTalk Wireless; Access Wireless;
Hutson Gen Mobile; TruConnect; SafeLink/Straight
Talk/Tracfone; Assurance Wireless
Jefferson 160519604001 Idaho Falls CenturyLink; AT&T Mobility; SafeLink/Straight
Talk/Tracfone; AirTalk Wireless; Gen Mobile;
Assurance Wireless; Access Wireless;
TruConnect; Syringa Wireless
Nez Perce 160699603002 Lewiston CenturyLink; SafeLink/Straight Talk/Tracfone;
Inland Cellular; AirTalk Wireless; TruConnect;
Gen Mobile; Access Wireless
Nez Perce 160699608002 Lewiston CenturyLink; SafeLink/Straight Talk/Tracfone;
Inland Cellular; AirTalk Wireless; TruConnect;
Gen Mobile; Access Wireless
2

Nez Perce 160699608003 Lewiston CenturyLink; SafeLink/Straight Talk/Tracfone;
Inland Cellular; AirTalk Wireless; TruConnect;
Gen Mobile; Access Wireless
Nez Perce 160699610001 Lewiston CenturyLink; SafeLink/Straight Talk/Tracfone;
Inland Cellular; AirTalk Wireless; TruConnect;
Gen Mobile; Access Wireless
Payette 160759601003 Payette CenturyLink; AirTalk Wireless; TruConnect;
Assurance Wireless; Access Wireless;
SafeLink/Straight Talk/Tracfone; Gen Mobile
Payette 160759602003 New CenturyLink; Gen Mobile; SafeLink/Straight
Plymouth Talk/Tracfone; AirTalk Wireless; Farmers Mutual
Telephone Company; Assurance Wireless; Access
Wireless; TruConnect
Payette 160759604001 New CenturyLink; Gen Mobile; SafeLink/Straight
Plymouth Talk/Tracfone; AirTalk Wireless; Farmers Mutual
Telephone Company; Assurance Wireless; Access
Wireless; TruConnect
Twin Falls 160830006001 Twin Falls CenturyLink; AT&T Mobility; TruConnect;
SafeLink/Straight Talk/Tracfone; Filer Mutual
Telephone Company; Syringa Wireless; Assurance
Wireless; AirTalk Wireless; Access Wireless; Gen
Mobile
Valley 160859702002 McCall Ziply Fiber; SafeLink/Straight Talk/Tracfone;
AirTalk Wireless; Gen Mobile; Assurance
Wireless; TruConnect
Valley 160859703001 McCall Ziply Fiber; SafeLink/Straight Talk/Tracfone;
AirTalk Wireless; Gen Mobile; Assurance
Wireless; TruConnect
3