20261007Staff Comments.pdf

RECEIVED
October 07, 2026
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 LTS )
TELECOMMUNICATIONS SERVICES (USA) ) CASE NO. LTS-T-25-01
INC.'S APPLICATION FOR CERTIFICATE )
OF AUTHORITY TO OFFER )
TELECOMMUNICATIONS SERVICES ) 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 December 3, 2025, LTS Telecommunications Services Inc. ("Company") applied to
the Commission requesting authority to offer non-switched local exchange and interexchange
telecommunications services (non-voice) in Idaho ("Application"). 1
The Company requests statewide authority to provide resold and facilities-based local
exchange and interexchange telecommunications services. Application at 2. The Company states
that it primarily aims to serve large enterprise customers through rates established by individual
1 The Company indicated several times in its Application that it is seeking a Certificate of Authority to Offer
Telecommunication Services,which is not offered in Idaho.On page four of the Application the Company stated it is
seeking a Certificate of Public Convenience and Necessity. Staff confirmed with the Company that it is seeking to
avail itself of the framework created in Commission Order No. 32277 for gaining Commission acknowledgement as
a registered wholesale provider of telecommunication services.
STAFF COMMENTS 1 OCTOBER 7, 2026

contracts. Id. The Company intends to construct its own fiber-optic facilities and anticipates
providing key route and service maintenance on all its constructed fiber facilities. Id. Consistent
with Commission rules, the Company states that it has not initiated interconnection negotiations
with any carriers in the state. Id. at 3.
The Company is a Delaware corporation,headquartered in California and authorized to do
business in the State of Idaho. Id. at 1,Exhibits A—C. The Company is a wholly owned subsidiary
of 13107 Delaware LLC. Id. at Exhibit E. The Company provided its financial information and
proposed tariffs and price lists as part of the Application. Id. Exhibits F—G.
STAFF ANALYSIS
For its analysis, Staff reviewed the Company's Application, IDAPA 31.01.01.114 ("Rule
114"), and Order No. 32277. Rule 114 prescribes the information required to be included in a
Certificate of Public Convenience and Necessity ("CPCN") application. Companies that do not
provide basic local exchange services are not required to provide information for sections two,
three and four of Rule 114. Order No. 32277 at 8. The Company indicated that it is seeking
Commission acknowledgement as a registered wholesale provider of telecommunication services
under Order No. 32277. Application at 3.
Rule 114 requires the Company to provide detailed information regarding its business
structure—including name, address, and entity type—with tailored requirements depending on
whether the applicant is a sole proprietor, partnership, corporation, or limited liability company.
Rule 114(1)(a-c). The Application provided evidence that certifies that the Company is a limited
liability company organized under the laws of the State of Delaware. Application at 2. In Exhibit
C of the Application, the Company provided its Certificate of Registration from the State of
Idaho's Office of the Secretary of State, Filing Number 6531340, and Staff was able to verify this
information through the Idaho Secretary of State's Office. The Company has met this requirement.
Because the Company is not requesting authorization to provide basic local exchange
service, it was not required to provide information pursuant to Rule 114(2)—(4). Nevertheless, the
Company's Application and accompanying exhibits provided a description of its proposed services
and territory; confidential financial information;and its proposed tariffs,which would satisfy these
requirements. To comply with Rule 114 (5), the Company is required to provide contact
information for the individual(s) who can answer any questions regarding the tariff and customer
STAFF COMMENTS 2 OCTOBER 7, 2026

service. Additionally, Rule 114(6) requires the Company to provide information regarding any
interconnection agreement negotiations. Rule 114(7)—(8) require statements acknowledging
ongoing compliance with relevant Commission's rules, including numbering conservation
measures detailed in Order No. 30425. Through information provided in the Application, the
Company has met all of the requirements stated above.
Additionally, Staff believes that the Commission should require the Company to
demonstrate progress toward providing the services identified in the Application in the form of
compliance filings updating the number of interconnections and status of infrastructure
construction at various points in the near future.
STAFF RECOMMENDATION
Staff recommends that the Commission approve the Company's Application to provide
resold and facilities-based local exchange telecommunications services and acknowledge its
registration as a wholesale telecommunications provider in the State of Idaho subject to the
following conditions:
1. The Company shall comply with the number pooling and reporting requirements of the
North American Numbering Plan Administrator, as outlined in Commission Order
30425.
2. As implicitly acknowledged in its statement of compliance with Commission rules,the
Company shall provide any and all necessary reports and contributions to the Idaho
Universal Service Fund, Idaho Telecommunications Relay Services and Idaho
Telecommunications Service Assistance Program and comply with all future reporting
requirements deemed appropriate by the Commission for competitive
telecommunications providers.
3. The Company shall file three reports as compliance filings indicating the number of
customers connected and its progress on the construction of the infrastructure needed
to provide service. These reports shall be due as follows:
a. December 31, 2026;
b. March 15, 2027; and
c. May 31, 2027.
STAFF COMMENTS 3 OCTOBER 7, 2026

If the Company fails to provide the three reports, the Company shall relinquish its
wholesale communications provider registration and all telephone numbers it has been
assigned, or the Commission will by its order revoke the Company's registration.
4. The Company shall relinquish its certificate and any telephone numbers if it is not
doing business within one year of the Commission's acknowledgement.
Respectfully submitted this 7th day of October 2026.
Jeffrey R. Loll
Deputy Attorney General
Technical Staff. Allison Moore
I:\Utility\UMISC\COMMENTS\LTS-T-25-01 Comments.doex
STAFF COMMENTS 4 OCTOBER 7, 2026

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 7ch DAY OF OCTOBER 2026,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF IN CASE
NO. LTS-T-25-01, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
LTS Telecommunications Services (USA) Inc.
Victor M. Noriega
Counsel for LTS Telecommunications Services (USA) Inc.
Troutman Pepper Locke LLP
600 Peachtree Street NE, Suite 3000
Atlanta, GA 30308
EMAIL: victor.noriegagtroutman.com
PATRICIA JORD N, SECRETARY
CERTIFICATE OF SERVICE