20260319APPLICATION.pdf

CTB-T-26-01 Cynthia A. Melillo PLLC
CUS-T-26-01 8385 W. Emerald Street RECEIVED
Boise, Idaho 83704 March 19, 2026
IDAHO PUBLIC
(208)-577-5747 UTILITIES COMMISSION
cam(a�camlawidaho.com
March 19, 2026
VIA Electronic Mail
Monica Barrios-Sanchez, Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd. Building 8, Suite 201-A
Boise, ID 83714
P.O. Box 83720
Boise, ID 83720-0074
Re: Custer Telephone Cooperative, Inc. and Custer Telephone
Broadband Services LLC - Joint Application for Approval of Merger
Dear Ms. Barrios-Sanchez:
Enclosed for filing, please find a copy of Custer Telephone Cooperative, Inc. and
Custer Telephone Broadband Services LLC's Joint Application for Approval of Merger,
Consolidation of Certificates of Public Convenience and Necessity and Eligible
Telecommunications Carriers. I have not sent a hard copy so please let me know if you
will require that prior to opening the case.
If you have any questions or need any additional information, please feel free to
contact me.
Sincerely,
��� *t
Cynthia A. Melillo
CAM/
Enclosure
Cc: JD Bennetts (via electronic mail)
Shelly Helm (via electronic mail)

CYNTHIA A. MELILLO (ISB # 5819)
Cynthia A. Melillo PLLC
8385 W. Emerald Street
Boise, Idaho 83704
Telephone: [phone]
Fax: [phone]
E-mail: cam a(D.camlawidaho.com
Attorney for Custer Telephone Broadband Services LLC and
Custer Telephone Cooperative, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION,
JOINT APPLICATION OF CUSTER )
TELEPHONE BROADBAND SERVICES )
LLC AND CUSTER TELEPHONE ) Case No.
COOPERATIVE, INC. FOR APPROVAL )
OF MERGER, CONSOLIDATION OF )
CERTIFICATES OF PUBLIC )
CONVENIENCE AND NECESSITY AND )
ELIGIBLE TELECOMMUNICATIONS )
CARRIERS
JOINT APPLICATION OF CUSTER TELEPHONE BROADBAND SERVICES LLC AND
CUSTER TELEPHONE COOPERATIVE, INC. FOR APPROVAL OF MERGER,
CONSOLIDATION OF CERTIFICATES OF PUBLIC CONVENIENCE AND NECESSITY
AND ELIGIBLE TELECOMMUNICATIONS CARRIERS
Custer Telephone Broadband Services LLC("CTBS")and Custer Telephone Cooperative,
Inc. ("CTCI" and collectively with CTBS, "Applicant"), by and through their undersigned
attorney, hereby submits to the Idaho Public Utilities Commission (the "Commission")
this Joint Application for Approval of Merger, Consolidation of Certificates of Public Convenience
and Necessity and Eligible Telecommunications Carriers ("Merger") pursuant to IDAPA
31.01.01.111 through 114..
All correspondence, communications, pleadings, notices, orders and decisions relating to
CTBS CTCI Joint Application for Approval of Merger- 1

this Application should be addressed as follows:
Cynthia A. Melillo
Cynthia A. Melillo PLLC
8385 W. Emerald Street
Boise, Idaho 83704
Telephone: [phone]
Email: 3mlawidaho.com
JD Bennetts
Custer Telephone Cooperative, Inc.
P.O. Box 324
Challis, ID 83226
Telephone: [phone]
Email: Id.bennettsO-custertel.com
I. BACKGROUND
A. Company Overview
CTCI is a mutual, non-profit telephone corporation organized under the laws of the State
of Idaho and exempt from most regulations of the Commission. CTCI's principle place of business
is located at 1101 E. Main Avenue, Challis, Idaho 83226, and it maintains central offices in Challis,
May, Elk Bend and Clayton, Idaho. CTCI provides basic local exchange telecommunications
services, MTS, WATS, access services to inter-exchange carriers, special access services,
broadband and other telecommunications services that its customers may from time-to-time
request or require. On May 16, 1989,the Commission issued Order No.22519,grantingCTCI's
application for a certificate for an exclusive service area for telecommunications service
pursuant to Idaho Code 62-615 (since amended), and simultaneously issued CTCI
Certificate No. 308, as amended. The Commission has also designated CTCI as an Eligible
Telecommunications Carrier for low-income support.
CTBS is an Idaho limited liability company, with a principal place of business located at
1101 E. Main Avenue, Challis, Idaho 83226. CTBS is a full-service wireline carrier that provides
facilities-based, locate exchange services and broadband services. The Commission issued a
Certificate of Public Convenience and Necessity(Certificate No. 501)authorizing CTBS to provide
local exchange and interexchange services within the State of Idaho in Case No. CTB-T-11-01,
Order No. 32383, dated April 1, 2014. The Commission further designated CTBS as an Eligible
Telecommunications Carrier for low-income support in Case No. CTB-T-14-01, Order No. 33002,
CTBS CTCI Joint Application for Approval of Merger—2

in the Salmon, Idaho exchange area.
CTBS was initially formed as a wholly owned subsidiary of CTCI to purchase cable
TV franchises in the Salmon, Idaho area. As this was outside the primary purposes of CTCI
to provide voice services, the board of directors of CTCI felt it best to form a separate entity
for regulatory purposes. Over time, CTBS began to provide voice and data services and
stopped providing cable TV services. In addition, as the industry evolved, CTCI began to
provide data services. At this time, CTCI and CTBS provide the same or similar services to
customers in adjacent territories. The original rationale for operating CTBS as a separate
subsidiary is no longer a concern to CTCI, and CTCI desires to merge CTBS into CTCI with
CTCI as the surviving entity. CTCI and CTBS assert that combining the two entities will result
in some cost savings from the elimination of duplicative functions such as separate books
and records. Second, the merger will eliminate "the regulatory cost" associated with
allocating joint and common costs between the two companies. Finally, the customers of
CTBS will become customers of CTCI and as such will benefit by becoming members of the
cooperative eligible for patronage. Operation and control of the two companies will not
change because the officers of both entities are identical.
B. CTBS and CTCI Approval of the Merger
The members of CTCI, at a meeting duly held on the 26th day of March 2025, approved
the merger of CTBS into CTCI with CTCI as the surviving company. The sole member and
managers of CTBS, at a meeting duly held on the 26th day of March 2025, approved the merger
of CTBS into CTCI with CTCI as the surviving company.
II. THE MERGER.
The merger of the two entities meets all statutory requirements under Idaho law for the
merger of a limited liability company into a corporation. Upon the effective date of the merger,
CTBS will cease to exist as a separate entity. The governing documents of CTCI shall govern
the merged entities. The customers of CTBS will become customers of CTCI and as such will
become non-voting members of CTCI, eligible to receive patronage from CTCI in the same
manner as the current members of CTCI. The merger will become effective upon filing Articles
of Merger with the Idaho Secretary of State. The Articles of Merger will be filed after receiving
final approval of this Commission, and upon transfer of CTBS's FCC radio licenses for Call
Sign/Lease IDs WRLL640, WRLL641 and WRLL642, and upon any approvals required by the
CTBS CTCI Joint Application for Approval of Merger—3

Rural Utilities Service and CoBank, ACB, lenders of CTCI.
III. CONSOLIDATION OF CTBS'S CERTIFICATE OF PUBLIC CONVENIENCE AND
NECESSITY WITH CTCI'S CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY
CTCI intends to continue to provide local exchange services throughout the service area
of CTBS as set forth in CTBS's Certificate of Public Convenience and Necessity (Certificate No.
501). As such, CTCI respectfully requests that such Certificate be transferred to CTCI or a new
certificate issued to consolidate CTCI's current service territory under Certificate No. 308. As
amended, with the service territory of CTBS under Certificate No. 501. CTCI will continue to offer
the services in the service area at the rates set forth in CTBS's price list on file with the
Commission.
Because CTCI currently holds a CPCN from the Commission, the Commission has all
information regarding CTCI required for the issuance of a CPCN. A current certificate of good
standing is attached hereto as Exhibit A.
The current officers and directors of CTCI are as follows:
Name Address Position
William C. Ebberts PO Box 324 President
Challis, ID 83226-0324
Kenneth Crisp PO Box 324 Secretary
Challis, ID 83226-0324
Gary Ingram PO Box 324 Vice President
Challis, ID 83226-0324
Hubert Miller PO Box 324 Director
Challis, ID 83226-0324
Jim Martiny PO Box 324 Director
Challis, ID 83226-0324
Monte Severe PO Box 324 Director
Challis, ID 83226-0324
Bruce Brunp PO Box 324 Director
Challis, ID 83226-0324
CTBS CTCI Joint Application for Approval of Merger—4

IV. CONSOLIDATION OF CTBS'S ELIGIBLE TELECOMMUNICATIONS CARRIER
DESIGNATION WITH CTCPS ELIGIBLE TELECOMMUNICATIONS CARRIER DESIGNATION.
CTCI intends to continue to provide all supported services throughout the Salmon, Idaho
exchange area as set forth in Order No. 33002, granting ETC status to CTBS. As such, CTCI
respectfully requests that CTCI's ETC service area be extended to include the Salmon, Idaho
exchange.
Because CTCI has been designated an ETC by the Commission, the Commission has all
information regarding CTCI required for the Commission to designate CTCI an Eligible
Telecommunications Carrier. CTCI has previously provided evidence to the Commission that
CTCI (i) is a common carrier,' (ii) offers services that are supported by federal universal support
mechanisms;2 (iii) will use its own facilities, in whole or in part, to provide the
supported services;3 (iv) will provide the supported services throughout its
Designated Service Area;4 (v) will advertise the availability of such services using media of
general distribution;5 (vi)will make Lifeline service available to qualifying low-income consumers;6
(vii) will certify that it will comply with the service requirements applicable to the support that it
receives;'(viii)will remain functional in emergency situations;$ (ix)will satisfy consumer protection
and service quality standards;'(x)will provide local usage plans comparable to the ILECs already
operating in the proposed Designated Service Areas;10(xi)will provide notice to any affected tribal
governments or tribal regulatory authorities;" (xii) will comply with all applicable reporting
requirements;12 and (xiii) will take steps to limit fraud, waste and abuse of the federal USF.13
147 U.S.C.§214(e)(1);47 C.F.R.§54.201(d).
2 47 U.S.C.§214(e)(1)(A);47 C.F.R.§§54.201(d)(1)and 54.405.
3 47 U.S.C. §214(e)(1)(A);47 C.F.R.§54.201(d)(1).
4 47 U.S.C. §214(e)(1);47 C.F.R.§54.201(d).
5 47 U.S.C.§214(e)(1)(13);47 C.F.R.§54.201(d)(2).
6 47 C.F.R.§54.405;see also In the Matter of Lifeline and Link Up Reform and Modernization,Report and Order and
Further Notice of Proposed Rulemaking,WC Docket No. 11-42, FCC 12-11, released February 6,2012("Lifeline
Reform Order").
47 C.F.R.§54.202(a)(1)(i).
8 47 C.F.R.§54.202(a)(2);and IPUC ETC Requirements Order,App.,at 3.
9 47 C.F.R.§54.202(a)(3);and IPUC ETC Requirements Order,App.,at 3.
11 IPUC ETC Requirements Order, App., at 3.
11 Id.at 2.
12 See IPUC ETC Requirements Order, App., at 3-4.
13 See Lifeline Reform Order.
CTBS CTCI Joint Application for Approval of Merger—5

V. RELIEF REQUESTED
For the reasons set forth above, CTBS and CTCI request the following:
A. That the Commission enter an Order approving the merger of CTBS into CTCI with
CTCI as the surviving entity;
B. That the Commission issue an Amended Certificate of Public Convenience and
Necessity for CTCI to reflect the merger and transfer of CTBS's CPCN Certificate No.
501 to CTCI; and
C. That the Commission amend the service territory for which CTCI is designated an
Eligible Telecommunications Carrier to reflect the merger and transfer of CTBS's
designated service areas granted in Case No. CTB-T-14-01, Order No. 33002.
Applicant does not believe that the public interest requires a hearing on this matter and,
therefore, requests that the Commission approve the Application by Minute Order or under
Modified Procedure. In the event the Commission determines that further proceedings are
necessary, Applicant stands ready for immediate hearings.
RESPECTFULLY SUBMITTED this 19th day of March 2026.
Cynthia A. Melillo PLLC
BY: L� z"'L-- , CI
Cynthia A. Melill
Attorney for Custer Telephone Cooperative,
Inc. and Custer Telephone Broadband Services
LLC
CTBS CTCI Joint Application for Approval of Merger—6

CERTIFICATE OF SERVICE
HEREBY CERTIFY that on this 19th day of March 2026, 1 caused to be served a true and
correct copy of the foregoing by the method indicated below, and addressed to the following:
Monica Barrios-Sanchez, Commission ❑ U.S. Mail
Secretary
Idaho Public Utilities Commission F1 Hand Delivered
11331 W. Chinden Blvd. Building 8, Suite
201-A ❑ Overnight Mail
Boise, ID 83714
❑ Facsimile
P.O. Box 83720
Boise, ID 83720-0074 Electronic Mail
Cynthia A. Melillo(
CTBS CTCI Joint Application for Approval of Merger—7

Exhibit A
Certificate of Existence
[attached]
Exhibit A

B STATE OF IDAHO
y c Phil McGrane I Secretary of State
Business Office
450 North 4th Street
PO Box 83720
Boise, ID 83702
March 18, 2026
Request Type: Certificate of Existence/Filing Issuance Date: 03/18/2026
Request#: 0006716285 Copies Requested: 0
Receipt#: 001296678
Regarding: CUSTER TELEPHONE COOPERATIVE, INC.
Filing Type: Non-Profit Corporation (D) File# 96042
Formation/Qualification Date: 01/31/1955 Delayed Effective Date:
Status: Active-Good Standing Formation Locale: IDAHO
Duration Term: Perpetual Inactive Date:
Certificate of Existence
I, Phil McGrane, Secretary of State of the State of Idaho, do hereby certify that effective as of the
issuance date noted above
CUSTER TELEPHONE COOPERATIVE, INC.
is a Corporation duly incorporated under the law of this State with a date of incorporation and
duration as given above.
Phil McGrane
Idaho Secretary of State
Processed By: Business Division Verification#: 038953943
Phone: [phone] * Website: sosbiz.idaho.gov