20260903Decision Memo.pdf

DECISION MEMORANDUM
TO: COMMISSIONER LODGE
COMMISSIONER HAMMOND
COMMISSIONER HARDIE
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL
FROM: ERIKA K. MELANSON
DEPUTY ATTORNEY GENERAL
DATE: SEPTEMBER 3, 2026
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. ("TCC") applied to the Idaho Public
Utilities Commission("Commission") for designation as an Eligible Telecommunications Carrier
("ETC")in the State of Idaho ("Application"). The Company requested designation as an ETC for
the sole purpose of providing Lifeline services. Application at 1. The Company asked that it be
allowed to participate and receive reimbursement from the Idaho Telephone Service Assistance
Program("ITSAP") accordingly. Id.
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. The Company submitted materials
supplementing its Application on July 9, 2024.
On July 11, 2024, Staff submitted comments 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. Staff Comments at 10.
On July 18, 2024, the Company submitted reply comments, arguing that the items of non-
compliance referred to by Staff were not actually requirements for obtaining ETC status. TCC
Reply at 1. Therefore, the Company contended it should not be denied ETC status for not
submitting these non-mandatory items. Id. After reviewing the reply comments, Staff
recommended that the Commission issue a Notice of Supplemental Comment and Reply Deadlines
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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
comment and reply period accordingly. Order No. 36284.
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. Motion to Stay at 1. 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. Staff Supplemental Comments at 2. Instead,
the companies were to have different owners or be sufficiently distinct to justify separate
designations. Id. 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. Id.
at 3.
On October 4, 2024,the Commission stayed this case for six months to give the Company
time to determine its path forward. Order No. 36344.
On June 11, 2025,the Commission issued a Notice of Second Supplemental Comment and
Reply Deadlines, establishing deadlines for Staff and the Company to address the impact of a
certification Sage would file regarding its plans in relation to TCC's application for ETC
designation. Order No. 36634.
On May 30, 2025, prior to the issuance of Order No. 36634, a representative of TCC's
corporate parent filed a document certifying that, within one year of TCC obtaining ETC status in
Idaho, it would either 1) enter an agreement to sell Sage; or 2) Sage will begin offering at least one
different service plan than TCC. Certification at 1. Alternatively, if neither occurs, it would
voluntarily give up Sage's ETC status without prejudice. Id. at 2. Subsequently, Staff filed
supplemental comments to which the Company replied on June 25, 2025, and June 26, 2025,
respectively.
On August 22, 2025, the Commission issued Order No. 36738 granting TCC a limited
designation as an ETC in the State of Idaho and directing Sage to submit quarterly compliance
filings for the next 12 months detailing the status of the customer transfer and the plans for Sage.
TCC submitted compliance filings on April 24, 2026, and July 29, 2026. Order No. 36738 at 7.
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On August 18, 2026, TCC filed a Motion for Extension of Time ("Motion"),requesting an
additional 6-months, until February 22, 2027, for its parent company to take the actions directed
in Order No. 36738. Motion at 1. TCC explained that it was currently working with Federal
Communications Commission ("FCC") Staff in the Wireline Competition Bureau regarding
options to transfer Sage's Lifeline customers to TCC. Id. at 2. TCC also reported that the number
of Lifeline customers enrolled with Sage had declined in the last 12 months from over 700 to 358,
while the number of Lifeline customers enrolled with TCC had increased.Id. TCC believed that a
6-month extension would enable communications with the FCC to continue while not causing
harm to TCC or Sage customers.Id.
STAFF RECOMMENDATION
Commission Staff recommends the Commission issue an Order granting TCC a 6-month
extension and directing TCC to submit an additional compliance filing in 3 months updating Staff
and the Commission detailing the status of the customer transfer and the plans for Sage.
COMMISSION DECISION
Does the Commission wish to issue an Order granting TCC a 6-month extension and
directing TCC to submit an additional compliance filing in 3 months updating Staff and the
Commission detailing the status of the customer transfer and the plans for Sage?
M&�_
Erika K. Melanson
Deputy Attorney General
I:\Legal\TELECOM\TCC\TCCT2401\memos\TCCT2401_dec5_em.docx
DECISION MEMORANDUM 3