20210216_mh1.pdf

DECISION MEMORANDUM 1
DECISION MEMORANDUM

TO: COMMISSIONER KJELLANDER
COMMISSIONER RAPER
COMMISSIONER ANDERSON
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL

FROM: MATT HUNTER
DEPUTY ATTORNEY GENERAL

DATE: FEBRUARY 12, 2021

SUBJECT: IN THE MATTER OF CUSTER TELEPHONE BROADBAND SERVICES
LLC’S PETITION FOR EXPANSION OF ITS ELIGIBLE
TELECOMMUNICATIONS CARRIER DESIGNATED SERVICE AREA;
CASE NO. CTB-T-21-01

On January 29, 2021, Custer Telephone Broadband Services LLC (“CTBS”) petitioned
to expand its designated service area as an Eligible Telecommunications Carrier (“ETC”).
BACKGROUND
CTBS is a wholly owned subsidiary of Custer Telephone Cooperative, Inc., which was
a winning bidder in the Rural Digital Opportunity Fund (“RDOF”) Auction 904 to provide
broadband service in specific Idaho census blocks. Application at 1. Custer Telephone
Cooperative, Inc. assigned its winning bids to CTBS on December 22, 2020. Id. CTBS asserts that
it is required under the rules of the RDOF auction to seek and receive designation as an ETC in all
census blocks in which it was awarded RDOF support. Id. at 2.
In 2014, CTBS sought designation as an ETC for the limited purpose of participating
in Lifeline and receiving universal service fund, low-income support in the Salmon, Idaho
exchange area. See Case No. CTB-T-14-01, Order No. 32989. In Order No. 33002, the
Commission designated CTBS a Lifeline-only ETC.
THE APPLICATION
CTBS seeks Commission approval “to expand its low-income/Lifeline-only ETC
designation for purposes of receiving high cost RDOF support in those areas located within its
[existing service area] and to expand its [existing service area] to include those areas…for which
it has been awarded RDOF support via Auction 904.” Application at 2. CTBS asserts it meets the
DECISION MEMORANDUM 2
federal and state requirements for designation as an ETC, and argues that designating CTBS as an
ETC is in the public interest. Id. at 3-5. CTBS asks that the Commission issue a final order on its
petition prior to June 7, 2021. Id. at 5.
STAFF RECOMMENDATION
Staff recommends the Commission issue a Notice of Application and Notice of
Modified Procedure, setting an April 1, 2021 comment deadline and an April 15, 2021 reply
comment deadline.
COMMISSION DECISION
Does the Commission wish to issue a Notice of Application and Notice of Modified
Procedure, setting an April 1, 2021 comment deadline and an April 15, 2021 reply comment
deadline?

__________________________
Matt Hunter
Deputy Attorney General

I:\Legal\TELEPHONE\CTB-T-21-01\CTBT2101_dec memo_mh.docx