20250926Staff Comments.pdf

JEFFREY R. LOLL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 11675
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ASSURANCE )
WIRELESS USA,L.P.'S APPLICATION TO ) CASE NO. VMU-T-25-01
EXPAND ITS ELIGIBLE )
TELECOMMUNICATIONS CARRIER )
SERVICE AREA ) COMMENTS OF THE
COMMISSION STAFF
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission
("Commission"), by and through its attorney of record, Jeffrey R. Loll, Deputy Attorney
General, submits the following comments.
BACKGROUND
On June 24, 2025, Assurance Wireless USA, L.P. ("Company"), formerly known as
Virgin Mobile USA, L.P. (Order No. 34618), applied to the Commission requesting approval to
expand its Eligible Telecommunications Carrier("ETC") service area to provide Lifeline only
services in the state of Idaho.
With this Order, the Commission provides notice of the Company's Application and
orders that the Application be processed under Modified Procedure.
STAFF COMMENTS 1 SEPTEMBER 26, 2025

Under the Federal Communications Act of 1934, as amended, a telecommunications
carrier is eligible to receive federal support from the Universal Service Fund("USF") throughout
the service area for which an ETC designation is granted. 47 U.S.C. § 214(e). Lifeline is a
program supported by the USF that provides monthly discounts to eligible low-income
subscribers to maintain access to communications networks. Lifeline and Link Up Reform Order,
27 F.C.C.R. 6656 at 6662-63. The Commission has the authority to grant ETC designations
within Idaho. 47 U.S.C. § 214(e)(2). To qualify as an ETC, an applicant must satisfy several
requirements of federal and state law. See 47 U.S.C. § 214(e); Order No. 29841.
In 2012, the Commission designated the Company a wireless ETC for specified
geographic areas. Order No. 32645.
The Company states that it is a wholly owned subsidiary of T-Mobile USA, Inc.
Application at 2.
The Company seeks to expand its ETC service area to encompass statewide authority
where the Company has wireless coverage for the sole purpose of providing Lifeline service to
additional qualifying Idaho households, including customers on Tribal lands, through
participation in the federal USF low-income program. Id. at 1-2.
The Company represents that it does not seek access to funds from the federal USF for
the purpose of providing service to high-cost areas. Id. at 1.
The Company represents that approval of its ETC designated service area expansion
request would serve the public interest by allowing the Company to provide Lifeline services to
qualifying low-income households anywhere the Company has wireless coverage in Idaho. Id. at
2.
The Company asserts that it meets all federal and state requirements for designation as an
ETC in its proposed expanded service area. Id. at 3.
The Company represents that it has complied with previous Commission orders regarding
ETC designation, including all service requirements applicable to recipients of Lifeline support.
Id. at 4.
STAFF RECOMMENDATION
Staff has been unable to verify that the Company meets each of the ETC eligibility and
reporting requirements established by the Commission in Order No. 29841 for the proposed
STAFF COMMENTS 2 SEPTEMBER 26, 2025

expanded service area. Staff continues to work with the Company to acquire the information and
documentation needed for such verification. Accordingly, Staff requests that the Commission
allow Staff to supplement its comments at a later date.
Respectfully submitted this 26th day of September 2025.
Jeffrey R. Loll
Deputy Attorney General
Technical Staff. Jon Kruck
I:\Utility\UMISC\COMMENTS\VMU-T-25-01 Comments.docx
STAFF COMMENTS 3 SEPTEMBER 26, 2025

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 26th DAY OF SEPTEMBER 2025,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE
NO. VMU-T-25-01, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
MARK P. TRINCHERO
HEATHER MOELTER
DAVIS WRIGHT TREMAINE, LLP
560 SW LOTH AVE, SUITE 700
PORTLAND, OR 97205
E-MAIL:
mark trincheror&dwt.com
heathennoelter a)du-t.com
TERI OHTA
DIRECTOR, STATE REGULATORY
AFFAIRS
T-MOBILE
12920 SE 38TH STREET
BELLEVUE, WA 98006
E-MAIL:
Teri.Ohta(a-�T-M obi le.com
PATRICIA JORDAN, ECRETARY
CERTIFICATE OF SERVICE