20251222Staff Comments.pdf

RECEIVED
December 22, 2025
JEFFREY R. LOLL IDAHO PUBLIC
DEPUTY ATTORNEY GENERAL UTILITIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83702
[phone]
IDAHO BAR NO. 11675
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 ) SUPPLEMENTAL 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. The Company states that it is a wholly owned subsidiary of T-
Mobile USA, Inc. and was granted a wireless ETC for specified geographic areas by the
Commission in 2012. Order No. 32645. Application at 2.
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
SUPPLEMENTAL STAFF COMMENTS 1 DECEMBER 22, 2025

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.
STAFF ANALYSIS
Staff has reviewed the Company's application and the state ETC requirements from
Order No. 29841. 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. Additionally, 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.
Staff submitted comments on September 26, 2025. Staff stated that they have been able 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 expanded service area. On
October 8, 2025, Staff submitted a production request. Staff also continued to work with the
Company to acquire the information and documentation needed for verification. The Company
filed their responses to the production request on October 21, 2025.
It the application, 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. Additionally, 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.
After reviewing the application, documentation and production request responses, Staff
has determined that the Company has met the requirements for an expiration of the Company's
current ETC as defined in Order No. 29841.
SUPPLEMENTAL STAFF COMMENTS 2 DECEMBER 22, 2025

STAFF RECOMMENDATION
Staff recommends the Commission approve the Company's request to expand their
current wireless ETC to statewide.
Respectfully submitted this 22nd day of December 2025.
Jeffrey R- Loll
Deputy Attorney General
Technical Staff. Allison Moore
I:\Utility\UMISC\COMMENTS\VMU-T-25-01 Supplemental Comments.doex
SUPPLEMENTAL STAFF COMMENTS 3 DECEMBER 22, 2025

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 22nd DAY OF DECEMBER 2025,
SERVED THE FOREGOING SUPPLEMENTAL 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 IOTH AVE, SUITE 700
PORTLAND, OR 97205
E-MAIL:
marktrinchero gdwt.com
heathermoelter(&,,dwt.com
TERI OHTA
DIRECTOR, STATE REGULATORY
AFFAIRS
T-MOBILE
12920 SE 38TH STREET
BELLEVUE, WA 98006
E-MAIL:
Teri.Ohta&T-Mobile.com
PATRICIA JORD , SECRETARY
CERTIFICATE OF SERVICE