20250520Decision Memo.pdf

DECISION MEMORANDUM
TO: COMMISSIONER LODGE
COMMISSIONER HAMMOND
COMMISSIONER HARDIE
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL
FROM: ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL
DATE: MAY 20, 2025
SUBJECT: IN THE MATTER OF TRUCONNECT COMMUNICATIONS, INC.'S
APPLICATION FOR DESIGNATION AS AN ELIGIBLE
TELECOMMUNICATIONS CARRIER IN THE STATE OF IDAHO; CASE
NO. TCC-T-24-01.
On March 4, 2024, TruConnect Communications, Inc. ("Company" or"TCC") 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.
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.
On July 11, 2024, Staff submitted comments on the Application, arguing that the Company's
request for ETC status should be denied. Among other things, Staff asserted that the Company failed
to meet the necessary requirements for an ETC to remain functional in an emergency and promote
the public interest.
On July 18,2024,the Company submitted reply comments,arguing that the compliance issues
Staff identified 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. After
reviewing the reply comments, Staff recommended that the Commission issue a Notice of
Supplemental Comment and Reply Deadlines to allow the parties to submit additional documentation
and analysis for consideration by the Commission. The Commission adopted Staff s recommendation
and ordered a supplemental period accordingly. Order No. 36284.
DECISION MEMORANDUM 1

On August 15, 2024, the Company moved to stay this case for six months. The Company
explained that this would give its corporate parent time to decide on the future of TCC and Sage
Telecom Communications, LLC dba TruConnect ("Sage")—an affiliate telephone company
operating in Idaho. Staff did not oppose this request.
On August 16, 2024, Staff filed supplemental comments. In these comments, Staff explained
that they believed TCC's corporate parent did not intend for both TCC and Sage to provide the same
services in the same area while operating under separate ETC designations. Instead, the companies
were to have different owners or be sufficiently distinct to justify separate designations. Because the
Company had yet to decide which path to take, Staff recommended that the Commission stay the case
for up to six months so the Company could finalize its plan. The Commission directed Staff to
recommend the appropriate course of action once the six-month stay elapsed or TCC and Sage's
futures became clear.
Discussions between counsel for Staff and the Company have identified a path to conclude
this case. TCC's corporate parent plans to submit a certification stating that, within one year of TCC
obtaining ETC status in Idaho, it will either 1) enter an agreement to sell Sage; or 2) Sage will begin
offering at least one different service plan than TCC. Alternatively, if neither occurs, it will
voluntarily give up Sage's ETC status without prejudice. This will allow TCC's corporate parent to
complete a broader, multi-state initiative to align TCC's ETC service area with that of Sage. Once
this effort is complete, the corporate parent intends to coordinate with the Federal Communications
Commission to transfer Sage's customers to TCC.
STAFF RECOMMENDATION
Staff recommends that the Commission issue a Notice of Supplemental Comment and Reply
Deadlines, establishing a 14-day public comment deadline and a 21-day Company reply deadline.
This will give all parties an opportunity to address the impact of the certification submitted by TCC's
corporate parent on the Company's application for ETC designation.
COMMISSION DECISION
Does the Commission wish to issue a Notice of Supplemental Comment and Reply Deadlines,
establishing a 14-day public comment deadline and a 21-day Company reply deadline?
Adam Triplett
Deputy Attorney General
L\Legal\TELECOM\TCCT2401\memos\TCCT2401_dec4_at.docx
DECISION MEMORANDUM 2