20250530Notice of Filing Certification.pdf

RECEIVED
May 30, 2025
IDAHO PUBLIC
BEFORE THE UTILITIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION
TruConnect Communications, Inc. )
Docket No. TCC-T-24-01
Application for Designation as an )
Eligible Telecommunications Carrier )
NOTICE OF FILING CERTIFICATION
TruConnect Communications, Inc. ("TruConnect" or the "Company"), hereby files the
attached certification from Sage Telecom Communications, LLC ("Sage Telecom") in support of
the Company's Application for Designation as an Eligible Telecommunications Carrier in the
State of Idaho ("ETC Application"). TruConnect is a subsidiary of TSC Acquisition Corporation
("TSC"), a company that also owns Sage Telecom. In 2019, the Idaho Public Utilities
Commission ("Commission") designated Sage Telecom as an ETC.' To date, both Sage Telecom
and TruConnect have used the "TruConnect"brand to market their Lifeline service offers.
The certification from Sage Telecom is being filed to address Commission Staff's
concerns about two affiliates offering Lifeline service under the same brand name in Idaho. In
the certification, Sage Telecom agrees to comply with certain conditions upon the Commission's
grant of TruConnect's ETC Application. The conditions ensure that Sage Telecom and
TruConnect's concurrent use of the TruConnect brand name for their Lifeline services will be a
temporary situation. As explained in the Supplement to the ETC Application, filed on July 9,
2024, the pending TruConnect ETC Application is part of a broader multi-state effort to establish
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).

a broad 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. TruConnect submits that Sage Telecom's representations set forth in the certification
address Commission Staff's concerns while providing Sage Telecom sufficient time to develop
new branding or materially change its ownership.
For the reasons stated in the ETC Application, as supplemented by the Company's filings
in this matter, 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,
,Be.P&-A6)y4j t/i w4j
Debra McGuire Mercer
Nelson Mullins Riley & Scarborough LLP
101 Constitution Avenue,NW
Suite 900
Washington, DC 20001
[phone]
debra.mercer(anelsonmullins.com
Counsel for TruConnect Communications, Inc.
May 30, 2025

Docusign Envelope ID: 1C6E0630-9A29-4D83-B8BB-A7DB1B36EEE8
CERTIFICATION
Danielle Perry, on behalf of Sage Telecom Communications,LLC ("Sage Telecom") states as
follows:
1. I am the Chief Compliance Officer of Sage Telecom. In my capacity as Chief Compliance
Officer of Sage Telecom, I am an authorized officer of Sage Telecom. I am providing this
Declaration in support of TruConnect Communications, Inc.'s("TruConnect")Application
for Designation as an Eligible Telecommunications Carrier("ETC"),filed with the Idaho
Public Utilities Commission("Commission") in Docket No. TCC-T-24-01.
2. In 2019,the Commission designated Sage Telecom as an ETC in the State of Idaho. Sage
Telecom and TruConnect are both subsidiaries of TSC Acquisition Corporation. Sage
Telecom and TruConnect both use the"TruConnect"brand name to market Lifeline services.
3. Sage Telecom understands that TruConnect's ETC Application filed with the Commission is
part of a broader multi-state effort to establish a broad ETC designation footprint for
TruConnect. Once that ETC designation expansion process has been completed in all states
where Sage Telecom is designated as an ETC, Sage Telecom will work with the Federal
Communications Commission on a process to transfer its current Lifeline customers to
TruConnect. As of the date of this certification,TruConnect has ETC applications pending
before three state commission that have also designated Sage Telecom as an ETC: this
Commission,the Kansas Corporation Commission, and the Pennsylvania Public Utility
Commission.
4. Within one year of the effective date a Commission order designating TruConnect as an ETC,
Sage Telecom will do one of the following:
a. offer Lifeline service to eligible low-income Idaho consumers under a brand name
other than"TruConnect"and that includes at least one plan that differs from the
standard Lifeline plan offered by TruConnect;
b. enter into an agreement with a third party to be acquired or to materially change
ownership; or
c. relinquish Sage Telecom's ETC status without prejudice.
5. Sage Telecom will informally advise the Staff via email on a quarterly basis regarding its
progress in transferring customers to TruConnect and its plans for brand and Lifeline plan
differentiation or for a material change in ownership.
I declare under penalty of perjury that the foregoing is true and correct.
Signed by:
Dated: 5/30/2025
Danielle Perry
Chief Compliance Officer
Sage Telecom Communications, LLC