California. Eligibility:

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1 California Eligibility: California LifeLine eligibility is determined by an applicant s participation in one of the following programs or based on income. Income eligibility is based on California s statespecific limits: 1. Medicaid/Medi-Cal 2. Low Income Home Energy Assistance (LIHEAP) 3. Supplemental Security Income (SSI) 4. Federal Public Housing Assistance or Section 8 5. CalFresh, Food Stamps or Supplemental Nutrition Assistance Program 6. Women, Infants, and Children Program (WIC) 7. National School Lunch Program (NSLP) 8. Temporary Assistance for Needy Families (TANF) California Work Opportunity and Responsibility to Kids (CalWORKs) Stanislaus County Work Opportunity and Responsibility to Kids (StanWORKs) Welfare-to-Work (WTW) Greater Avenues for Independence (GAIN) 9. Tribal TANF 10. Bureau of Indian Affairs General Assistance 11. Head Start Income Eligible (Tribal Only) 12. Food Distribution Program on Indian Reservations Income Eligibility (Effective from June 1, 2015 to May 31, 2016): Household Size Annual Income Limits 1-2 members $25,700 3 $29,900 4 $36, 300 For each additional member Add $6,300 Income Eligibility (Effective from June 1, 2016 to May 31, 2017): Household Size Annual Income Limits 1-2 members $25,900 3 $30,100 4 $36, 500 For each additional member Add $6,400

2 California LifeLine in-person Enrollment Process 1. Telrite In-Person Subscriber Enrollment a. Telrite will ask the subscriber if he/she is currently enrolled in California LifeLine with another provider. i. If yes, then Telrite will contact California LifeLine Administrator California Lifeline Administrator to validate the customer s approved status. i. If approved status is confirmed, then Telrite will notify the customer once it determines whether or not the customer is currently or within the last 30 days has been enrolled in California LifeLine. ii. If approval is not confirmed, Telrite will proceed to the next step. ii. If no, Telrite will proceed to the next step. b. Telrite informs the applicant of California LifeLine eligibility requirements i. Telrite checks for program-based qualification. i. Telrite asks if the applicant is enrolled in a qualifying means-tested programs listed in Section of General Order 153. a. If yes, Telrite will ask whether the applicant is able to demonstrate participation in the program at this time through enrollment in a qualifying program. i. If yes, Telrite will request supporting documentation from the applicant. 1. If provided, Telrite will capture scan/picture of documents and proceed with pre-screening, below. 2. If not provided, Telrite will proceed to check income-based qualification ii. If no, Telrite will proceed to check income-based qualification. b. If no, Telrite will proceed to check income-based qualification. ii. Telrite checks for income-based qualification (if needed) i. If program-based qualification was not established, Telrite will ask the customer about his/her household size and read the corresponding California LifeLine income limit information outlined in Section of General Order 153 that the applicant must meet to qualify for California LifeLine. a. If the customer indicates that he/she meets the income limits, Telrite will inform the customer that he/she must also provide income document(s) substantiating the household income, and will request supporting documentation from the applicant. i. If provided, Telrite will capture scan/picture of documents. ii. If not, Telrite will end the application process. b. If customer indicates that he/she is not eligible based on program or income, end application process. c. Telrite pre-screens the applicant

3 i. A Telrite employee will complete a pre-screening review of the customer submitted documentation. Telrite utilizes LexisNexis to validate name, date of birth, and last four digits of Social Security Number and Melissa data for address validation. In addition, every applicant is required to provide documentation proof of identity and program eligibility. Telrite employees review 100% of the applicants. i. If applicant is an internal duplicate (already a Telrite customer) then Telrite will not allow the order to proceed. ii. If not eligible, end application process. iii. If eligible, continue. d. Telrite will offer the applicant a promotional wireless service (i.e., free handset with 250 talk/text until LifeLine eligibility determination is issued by the California LifeLine Administrator). Telrite will inform the applicants that he/she will be able to use the handset with the promotional minutes until approval of their California LifeLine Application Form (and can purchase additional minutes if necessary). e. Telrite will submit the applicant to the California LifeLine Administrator via DAP API service (with Dummy Phone Number ) and retrieve California LifeLine Administrator generated LifeLine Certification Form. f. Telrite will make available to customer upon request their completed Application and provide via US mail if requested and inform the customer that no deposit is required. The customer will also be provided at enrollment the opportunity to review the completed Application. Also, Telrite will inform customer about options for Braille or large print application, and for a TTY-enabled phone, and if a TTY-enabled phone is required, inform the customer that he/she must provide proof for the need of a TTYenabled phone as outlined in Section of General Order 153. g. After successful submission of the application with the California LifeLine Administrator, Telrite will create the customer account in its billing system, charge all subscribers in accordance with CPUC requirements, and distribute a handset to the customer, including the following steps: i. Informing the subscriber of the activation process ii. Picking a handset from inventory iii. Activating the handset iv. Assigning a phone number v. Assigning promotional minutes h. Telrite submits to California LifeLine Administrator completed Certification Form and Supporting Documentation. i. The subscriber completes the activation process by making first call into Telrite s IVR within 60 days, and an activation fee is assessed on his/her account. j. Upon return of status code 53 from the California LifeLine Administrator and a successful activation call by the subscriber, an update record is issued to the California LifeLine Administrator to update the dummy phone number to the actual phone number assigned to the customer. 2. California LifeLine Administrator Review a. The California LifeLine Administrator reviews application and returns the subscriber s eligibility status. i. If the California LifeLine Administrator sends a Status Code 53: i. Telrite will send California LifeLine Administrator an update record with the telephone number and service start date.

4 ii. Upon receipt of confirmation from the California LifeLine Administrator that the phone number has been updated and that the subscriber has been approved: a. Telrite will send the subscriber notification of approval, via no charge text message, that the LifeLine benefit has been approved and applied to the subscribers account. b. The California LifeLine Administrator will notify the subscriber via U.S. Mail that the LifeLine benefit has been approved. c. Telrite will update the account in its billing system, in accordance with CPUC requirements. d. Telrite will credit the customer for the activation fee ii. If the California LifeLine Administrator sends a Correctable Denial notification via the daily return file: i. Telrite will send a text message to subscriber providing notification of correctable denial status and advises customer to respond to Pink Envelope from the California LifeLine Administrator. ii. The California LifeLine Administrator will notify the subscriber via U.S. Mail about the correctable denial with instructions on how to correct the enrollment. iii. If the California LifeLine Administrator sends a Firm Denial notification via the daily return file: i. Telrite will send a text message to the subscriber informing him/her of the firm denial status. Subscribers will be moved from the promotional plan to a pre-paid offering. ii. California LifeLine Administrator will notify the subscriber via U.S. Mail about the denial with instructions on how to appeal the denial. iii. Telrite will update account in their billing system, in accordance with CPUC requirements.

5 California LifeLine Customer Service Enrollment Process 1. Telrite Subscriber Customer Service Enrollment a. Customer calls Life Wireless Toll Free Number and selects option for New Service. Telrite Customer Service collects the necessary information from the customer (information necessary to begin the mail process with California LifeLine Administrator), and informs customer of process. b. Telrite submits the customer s information to California LifeLine Administrator for processing via the California LifeLine Administrator mailing process. i. California LifeLine Administrator will mail application to the applicant ii. The applicant will complete the necessary forms and gather necessary documentation. iii. The applicant will mail the completed forms and necessary documentation to California LifeLine Administrator. c. Applicant either is successful or fails to complete, sign, and submit the required documents to the California LifeLine Administrator. 2. California LifeLine Administrator Review a. The California LifeLine Administrator reviews application and returns the subscriber s eligibility status. i. If the California LifeLine Administrator sends a Customer Prequalification Status Code 53: 1. Telrite will immediately ship a handset to the customer. 2. Upon receipt of the handset, the customer will contact Telrite Customer Service in order to activate the handset and receive their phone number. 3. After successful activation of the handset, Telrite will submit to the California LifeLine Administrator an update record in the daily upload file with the actual telephone number assigned to the customer and the service start date. 4. Upon receipt of confirmation in the daily return file from the California LifeLine Administrator that the phone number has been updated and that the subscriber has been approved: a. Telrite will send the subscriber notification of approval, via text message, that the LifeLine benefit has been approved and applied to the subscribers account. b. The California LifeLine Administrator will notify the subscriber via U.S. Mail that the LifeLine benefit has been approved. c. Telrite will update the account in its billing system, in accordance with CPUC requirements. d. Telrite will credit the customer for the activation fee ii. If the California LifeLine Administrator sends a Correctable Denial notification via the daily return file: 1. Telrite will notify the subscriber via U.S. Mail providing notification of correctable denial status and advises customer to respond to Pink Envelope from CPUC/California LifeLine Administrator. 2. The California LifeLine Administrator will notify the subscriber via U.S. Mail about the correctable denial with instructions on how to correct the enrollment.

6 iii. If the California LifeLine Administrator sends a Firm Denial notification via the daily response file: 1. Telrite will notify the subscriber via U.S. Mail informing him/her of the firm denial status. 2. California LifeLine Administrator will notify the subscriber via U.S. Mail about the denial with instructions on how to appeal the denial. 3. Telrite will update account in their billing system, in accordance with CPUC requirements. California LifeLine Web Enrollment Process 1. Telrite Subscriber Web Enrollment a. The customer visits and selects Sign-Up Today. The customer selects California from the Option 1 drop down box. The customer enters the necessary information to begin the mail process with California LifeLine Administrator (Xerox), and informs the customer of the process. b. Telrite submits the customer s information to California LifeLine Administrator (Xerox) for processing via the California LifeLine Administrator (Xerox) mailing process. i. California LifeLine Administrator (Xerox) will mail application to the applicant ii. The applicant will complete the necessary forms and gather necessary documentation. iii. The applicant will mail the completed forms and necessary documentation to California LifeLine Administrator (Xerox). c. Once California LifeLine Administrator (Xerox) receives the completed customer information back from the end user and validates it, California LifeLine Administrator (Xerox) will notify Telrite of acceptance via an issuance of status code 53 in the daily response files for the customer. d. After successful submission of the enrollment with the California LifeLine Administrator, and acceptance from California LifeLine Administrator (Xerox), Telrite will create account in their Billing System, charge all subscribers in accordance with CPUC requirements, and mail a handset to the customer. e. Upon receipt of the phone, the customer will contact Telrite to activate their service. Upon completion of activation, Telrite will charge the activation fee to the customer and credit the account for the activation fee, and will issue an update to California LifeLine Administrator (Xerox) with the actual phone number assigned to the customer. 2. California LifeLine Administrator Approval a. The California LifeLine Administrator reviews application and returns subscriber s eligibility status. i. If the California LifeLine Administrator sends an Approval notification via the daily response file (Status Code 53): 1. Telrite will send the subscriber notification of approval, via text message that the LifeLine benefit has been approved and applied to the subscribers account. 2. The California LifeLine Administrator will notify the subscriber via U.S. Mail that the LifeLine benefit has been approved. 3. Telrite will update the account in its billing system, in accordance with CPUC requirements.

7 4. Telrite will send California LifeLine Administrator (Xerox) an update record with the telephone number and service start date. 5. Telrite will credit the customer for the activation fee. ii. If the California LifeLine Administrator sends a Correctable Denial notification via the daily response file: 1. Telrite will send a text message to subscriber providing notification of correctable denial status and advises customer to respond to Pink Envelope from CPUC/California LifeLine Administrator (Xerox). 2. The California LifeLine Administrator will notify the subscriber via U.S. Mail about the correctable denial with instructions on how to correct the enrollment. iii. If the California LifeLine Administrator sends a Firm Denial notification via the daily response file: 1. Telrite will send text message to subscriber informing them of the hard denial status. Subscribers will be moved from the promotional plan to a pre-paid offering. a. If the subscriber wants specific reasons for the denial they will be directed to the California LifeLine Administrators Call Center. 2. California LifeLine Administrator (Xerox) will notify the subscriber via U.S. Mail about the denial with instructions on how to appeal the denial. 3. Telrite will update the account in its billing system, in accordance with CPUC requirements.

8 Rate plans: The Unlimited Plan which includes a FREE phone plus Unlimited FREE voice minutes and Unlimited FREE texts each month. The other choices is the California 1250 Plan which offers 1250 voice minutes and texts assessed at 3 per each voice minute and 250 MBs of data and 250 MMSs of data. Minutes do not roll over. Additional minutes are available for purchase. Unused purchased airtime is banked for your use for as long as you remain a Life Wireless subscriber. Additional time purchased as unlimited for a set timeframe expires at the end of the timeframe. CA data will not roll over. The 400MB recharge ($9.95) will rollover. Each California LifeLine rate plan is subject to a one-time $39 activation fee or service conversion fee. The one-time $39 fee will be charged to the customer s account at activation; however, once the customer is approved for LifeLine service by the California LifeLine Administrator, Life Wireless will credit the $39 back to the customer s account.. Telrite Corporation shall clearly label its offerings as federal Lifeline service to minimize customer confusion between the California LifeLine and federal Lifeline programs, shall include adequate information about the potential coverage and service quality issues, and shall provide copies of all marketing materials including, but not limited to, customer service representative scripts, internet marketing, and posters and brochures for Communications Division s California LifeLine staff review and approval prior to distribution of marketing publications. In California, if an ETC s service area includes tribal land, the carrier can offer their approved plan to customers living on tribal lands. However, it cannot receive the $25 enhanced tribal subsidy unless and until it gets an enhanced tribal plan approved and meets all other enhanced tribal prerequisites. Database dip?: California has opted out of NLAD. All enrollments into the Lifeline program in California are managed by the third party administrator California LifeLine Administrator (Xerox). Historically, the enrollment process was completed through what was known as the California Pink Envelope System. To complete a Lifeline enrollment through the Pink Envelope System, once an application was completed, California LifeLine Administrator (Xerox) would send the end user, via USPS, a pink envelope which contained a LifeLine Certification form and, if needed, a one per household worksheet. Applicants were instructed to either (1) complete the paper Certification form and return it to California LifeLine Administrator (Xerox) along with documentation verifying their Lifeline eligibility, or (2) complete an electronic Certification form online, using a pin number assigned to the specific customer (provided within the pink envelope), and send California LifeLine Administrator (Xerox) documentation verifying their Lifeline eligibility.

9 California LifeLine Administrator (Xerox) has up to 7 business days from receipt to review the application and supporting documentation, and provide a final approval to the ETC. CGM has built a real-time enrollment process for California through its existing ECP application. CGM s ECP application allows an ETC s representative to (1) perform a realtime duplicate validation into California LifeLine Administrator (Xerox) s duplicate database, (2) electronically receive, from California LifeLine Administrator (Xerox), a customer specific PDF of the required California Lifeline Certification form, and (3) complete a real-time enrollment on the California LifeLine website, which is embedded into the CGM ECP, using the associated pin number on the customer specific PDF Certification form. Once the enrollment is complete, the CGM ECP forwards California LifeLine Administrator (Xerox) all required program eligibility documentation for California LifeLine Administrator (Xerox) to perform its final review and eligibility determination. All California LifeLine Administrator (Xerox) approvals, denials, and conditional approvals are automatically reconciled within the ECP review queue which allows ETCs instant access to each order and any updates so ETCs can take appropriate action(s). Departmental Impacts Training To ensure all hired representatives of the company are trained in all aspects of the California LifeLine program, all employees or representatives that conduct in-person enrollments are on-boarded and trained regarding both federal and state eligibility and certification requirements using a California-specific online Learning Management System. This comprehensive on-boarding and training includes, but is not limited to: mandatory background checks agreeing (by signature) to an Ethical Conduct Addendum assignment of unique representative log-in which tracks all movements and keystrokes 24/7 online Compliance Wiki explaining eligibility guidelines in the State of California. attesting at the start of every work day that: I will not submit a Life Wireless order on behalf of any customer that I have sufficient reason to believe is currently receiving a Lifeline phone/service from Life Wireless or another provider or who does not qualify for service under the FCC rules and requirements specific to the state in which I am working. I understand that failure to adhere to these policies may result in the immediate suspension/termination of my privileges as a Life Wireless representative, and that serious breaches of these policies could result in criminal and/or civil action against me.

10 daily auditing of representatives required signage, materials, and appearance. mandatory training and passing grade for every new representative in the State of California. Includes lessons on: -what makes an individual eligible for California LifeLine, -what proof of eligibility and identification is required, -what the one-per-household rule is, -what information provided by the applicant needs to be recorded and in what form, -what information needs to be communicated to the applicant about eligibility and the program, and -the consequences of not following Life Wireless s procedures to ensure full compliance with California LifeLine requirements mandatory training/lessons, distributed real-time through Learning Management System with agreement of understanding or passing grade confirmation, required for any new regulation, policy, or procedure Production California LifeLine handsets will be prepared and packaged separately from regular LifeLine handsets. A few Production Department associates will be designated as concentrating on solely Califormia Lifeline preparation and packaging. The packaging will also include marketing information and inserts specific to California LifeLine. Included with each phone shipment: CA X1 (25 per box) CA 4x6 bag insert Hearing Aid / Customer Handset Replacement CA Fact Sheet Field Support (Marketing Materials) California-specific marketing materials must be used: 6-2x4 banner CA wmap.pdf 6-3x8 banner CA wmap.pdf 6 - Full page handout 8.5x11 CA.p 6 - Half Page Handout CA.pdf 6 - Life Wireless 4x6 Insert CA.pdf Field Support (Field Representative CA LifeLine Enrollments) Field representatives will assist applicants with enrolling to tentatively receive California LifeLine Service pending approval of their eligibility by the California LifeLine Administrator (California LifeLine Administrator (Xerox)). The applicant s information will be entered and they must provide acceptable identity and subsidy proofs. The Subsidy Approvals Center (SAC) will review the proofs provided by the customer and if acceptable, the customer will receive a handset with 250 prepaid minutes. Their

11 application will be submitted to California LifeLine Administrator (Xerox), and once approved, they will begin receiving California LifeLine service. Equipment Shipped to each Field Representative: CA FCC Sign CA Table Documents CA State LifeLine Form Packet Customer Certification Document (Legal size yellow border) CA Application Information Document (4 steps) Compliance (Site Materials) The following materials are required at every California tent site: 6-24x36 compliance CA.pdf CA LL Fed Form 1.2.pdf CA State LL Form Packet.pdf CA Application Information Sheet.p Retailer sites: 6 - RETAIL POSTER RETAIL POSTER 2 - LW 11x17 poster re- LW 11x17 poster re Compliance (Field Representative Order Monitoring) Compliance is to monitor the fail rate of all orders from California LifeLine Administrator (Xerox) file to achieve a company average. Compliance will take action on any rep that exceeds the company average. Other state specifics: 1. Although the federal definition of adult for USF purposes is only those individuals over age 18, California makes allowance for emancipated minors who can qualify for Lifeline. 2. File all federally required annual reports (e.g., Form 481, Form 555, etc.) and compliance reports with the FCC and the CPUC. This requirement includes the obligation of ETCs to notify all subscribers of Lifeline program and eligibility requirements each year. 3. File the required service plan(s) information pursuant to 47 C.F.R (d) with the Universal Service Administrative Company (USAC). USAC will review the service plan(s) to ensure they meet the federal Lifeline requirements. Once the USAC review and approval are finalized, copies of the documentation provided to USAC and a copy of USAC s approval shall be provided to the Director of the California Communications Division (CD) within 30 days of receipt from USAC.

12 This requirement is satisfied by completing the USAC Study Area Code request and approval process. CGM completes this task for all clients and provides all necessary documentation for the ETC to forward to CPUC staff. 4. Provide marketing materials to the CPUC California LifeLine staff for review prior to distribution and marketing. ETCs must clearly label wireless offerings as a federal Lifeline service to minimize customer confusion between the California LifeLine and federal Lifeline programs, and include adequate information about potential coverage and service quality issues. All marketing materials must contain the following disclosures: This [company/dba] offering is a California LifeLine [federal Lifeline]- supported service. Only eligible consumers may enroll in the program and proof of eligibility documentation is necessary for enrollment. The program is limited to one benefit per household, consisting of either wireline or wireless service. LifeLine service is non-transferable. Coverage limitations such as weather, signal strength, and service outages may affect wireless mobile phone service, quality, or access to E-911 and/or 911 in the event of an emergency. By removing your wireless cell phone from a residence that does not have other phone services, residents may not have a way to make 911 calls during an emergency. 5. Comply with CPUC User Fee and Public Purpose Program surcharge requirements. 6. File an updated data list of nine digit zip codes (ZIP+4) with Director of the California CD and the California LifeLine Administrator, California LifeLine Administrator (Xerox). Once an ETC is approved, the CPUC will provide a list of small ILEC ZIP+4 service area data. The ETC will then provide a ZIP+4 service area listing excluding the small ILEC service area. 7. Post safety concerns about wireless telephone service coverage limitations and how they may effect wireless mobile service, including E911/911 emergency calls, in clear statements, on all distributed materials and its website. 8. Comply with the California LifeLine requirement to provide access to two residential telephone lines if a low income household with a disabled person requires both lines to access California LifeLine. 9. LifeLine Related Forms and Notices For Carriers: ublic+program.htm 10. ETC Approval: CA resolution.pdf

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20 Compliance with GO 153, Appendix A-2 Service Elements of California Wireless LifeLine No. Service Element of Appendix A-2 Complies? Comments 1 The provider must offer participants the ability to place and receive voice-grade calls over all distances utilizing the public switched telephone network or successor network. a) The provider must, at a minimum, enable calls to be sent and received within a local exchange or over an equivalent or larger sized local calling area. b) The provider must provide a voice-grade connection to the public switched telephone network or successor network. c) The provider must disclose to each participant before activating service that they are entitled to a voice-grade connection and the conditions under which the participant may terminate service without penalty if one cannot be provided. d) If at any time, a participant fails to receive a voice-grade connection and notifies the provider, the provider is required to (1) promptly restore the voice grade connection, or if not possible (2) provide telephone service to that participant using a different technology if offered by the provider and if the participant agrees; or (3) allow the participant to discontinue service within 14 days of service activation without incurring early termination fees, if applicable. The provider shall also refund in full any applicable service connection charges and deposits if a participant terminates service within three days of service activation, excluding national holidays. These rules also do not preclude the participant from terminating service for any reason within 14 days of service activation without incurring early termination fees. Nothing in these rules alters or modifies the service obligation of a COLR to ensure continuity and functionality of basic service within the residence. Yes Telrite will meet all of the requirements set forth: a) Telrite s wireless service includes nationwide long-distance calling as part of all of its service offerings. b) Telrite offers its customers the ability to send and receive voice-grade calls within a nationwide coverage area, currently using the AT&T Wireless network. The Company does not differentiate domestic long distance telephone usage from local usage; customers utilize their minutes of use at the same rate for each type of call. c) Telrite will disclose to each participant before activating service that they are entitled to a voice-grade connection and the conditions under which the participant may terminate service without penalty if a voicegrade connection cannot be provided. Telrite does not require participants to enter into a service contract, so Telrite customers are free to discontinue service at any time without penalty. d) If, at any time, a participant fails to receive a voice-grade connection and notifies Telrite, the Company will (1) promptly restore the voice-grade connection, or if not possible, (2) provide telephone service to that participant using different technology if offered by Telrite and if the participant agrees; or (3) allow the participant to discontinue service within 14 days of service activation without incurring early termination fees. Telrite does not require

21 No. Service Element of Appendix A-2 Complies? Comments participants to enter into a service contract, so Telrite customers are free to discontinue service at any time without penalty. 2 The provider must provide free, unlimited access to 911 emergency services, in compliance with current state and federal laws and regulations. a)each provider must provide its potential and existing customers information regarding its 911 emergency services, in compliance with current state and federal laws and regulations. Yes Telrite does not charge its customers for calls placed to 911/E-911, nor do 911/E-911 calls utilize available minutes. In addition, 911/E-911 service is available for all activated handsets is available for all handsets with sufficient battery charge, regardless of whether there are minutes available for use under the plan. a) Telrite will provide its potential and existing customers information regarding its 911 emergency services, in compliance with current state and federal regulations. 3 The provider shall offer a choice of a California LifeLine plan with 1,000 or more voice minutes, and may include domestic messaging or of a California LifeLine plan with 501 to 999 voice minutes, and may include domestic messaging. 4 The provider must abide by certain additional billing provisions. a)the provider must offer at least one California LifeLine plan that meets or exceeds the California LifeLine service elements, and is not bundled with any video or data services. The provider may offer added features and/or enhanced service elements without additional charge(s). b) The provider shall apply the applicable California LifeLine discount to the participant's selected plan. c) The California LifeLine eligible plans may be offered on a pre-paid or post-paid basis. d) The provider must offer California LifeLine discounted services on a nondiscriminatory basis to any customer residing within the service territory where the provider offers retail wireless telephone services. The provider must only provide California LifeLine discounts to participants Yes Telrite will offer a California LifeLine Plan with 1,000 or more voice minutes, and may include domestic messaging,. Yes Telrite will abide by the following additional billing provisions: a) Telrite will offer at least one California LifeLine plan that meets or exceeds the California LifeLine service elements and is not bundled with any video or data services. Telrite understands that it may offer added features and/or enhanced service elements without additional charge(s). b) Telrite will apply the applicable California LifeLine discount to each participant s selected plan c) Telrite will offer its California LifeLine eligible plan on a pre-paid

22 No. Service Element of Appendix A-2 Complies? Comments that are approved by the California LifeLine Administrator. e) The provider shall not require contracts lasting more than two years for participants; and the terms must be comparable to the provider's retail customers for the same service and/or device, except as needed to comply with California LifeLine rules. f)the provider may add features and/or enhanced services as part of its California LifeLine offerings if they meet or exceed the California LifeLine minimum standards set by the CPUC. Nothing in these rules alter or modify the obligation of the provider to offer at least one plan that meets or exceeds the minimum service elements, and is not bundled with any video or data services. g) The provider must allow participants to purchase additional voice minutes at the lowest rate that is offered to its retail customers for comparable plans with similar services and/or features. h) The provider may offer plans that cease phone operation when all of the allotted minutes are used. The provider shall provide participants an option to purchase additional minutes. The provider must prominently disclose the charges, terms, and conditions associated with the purchase of additional minutes. i) The provider shall not assess a fee to participants for paying their bills in person by cash, check or other form of payment. j) The provider shall not assess a restocking fee to participants for devices returned within three days of service activation. basis. d) Telrite will offer California LifeLine discounted services on a nondiscriminatory basis to any customer residing within the service territory where it offers retail wireless telephone services. Telrite will only provide California LifeLine discounts to participants that are approved by the California LifeLine Administrator. e) Telrite will not require contracts lasting more than two years for participants. Telrite offers service on a pre-paid basis, and currently does not require its customers to enter into a service contract. Any required contract terms will be comparable to those offered to Telrite s retail customers for the same service and/or device, except as needed to comply with California LifeLine rules f) If Telrite adds features and/or enhanced services as a part of its California LifeLine offerings, the offerings will meet or exceed minimum standards set by the CPUC. Telrite offers a California LifeLine plan that meets or exceeds the minimum service elements and is not bundled with any video or data services. g) Telrite will allow participants to purchase additional voice minutes at the lowest rate that is offered to its retail customers for comparable plans with similar services and/or features. h) Telrite meets this requirement by providing customers options to purchase additional minutes or an

23 No. Service Element of Appendix A-2 Complies? Comments unlimited voice minute plan. i) Telrite will not assess a fee to participants for paying their bills in person by cash, check or other form of payment. j) Telrite will not assess a restocking fee to participants for devices returned within three days of service activation. 5 All handsets shall be available to participants on the same basis as the provider's retail customers. Yes Telrite will offer all handsets to participants on the same basis as its retail customers. Telrite provides a free phone to eligible consumers. The equipment is new. See Terms and Conditions for replacement and warranty information 6 The provider must offer access to California Relay Service pursuant to Public Utilities Code 2881 for deaf or hearing-impaired persons or individuals with speech disabilities. 7 The provider must provide participants free blocking for 900/976 information services and a one-time free billing adjustment for 900/976 information services related charges inadvertently or mistakenly incurred, or without authorization. Yes Yes Through its underlying carrier, Telrite will provide access to California Relay Service for deaf or hearing-impaired persons or persons with speech disabilities. Telrite will provide participants free blocking for 900/976 information services and a one-time free billing adjustment for 900/976 information services related charges inadvertently or mistakenly incurred, or without authorization. 8 The provider must provide access to operator services commensurate to its retail customers. The provider must disclose any charges or fees associated with using operator services. Yes Telrite provides access to operator services for its LifeLine customers commensurate to its retail customers. Calls to operator service are free 9 The provider shall prominently disclose and disseminate terms and conditions, including their rates and fees, the charges, terms, and conditions associated with purchasing additional minutes, 911 emergency services location accuracy and reliability standards, as required in basic service element number Yes Telrite will prominently disclose and disseminate all of the required disclosures set forth in Element 9 of Appendix A-2.

24 No. Service Element of Appendix A-2 Complies? Comments I.2.(d) in Appendix A of Decision , potential service coverage and service quality issues, safety related considerations when handsets are removed from the home and when there is poor mobile reception, any charges associated with calling 800 or 800- like toll-free services, and the device's condition if refurbished, the device's applicability on other provider's wireless networks if the participant switches providers, and power back-up requirements for the system that supports California LifeLine wireless service including limitations due to power for equipment on towers or other facilities, e.g. that wireless telephone service may not work if the tower the wireless handset is trying to reach loses commercial or backup power. Additional disclosures must include the entitlement to a voice grade connection, the conditions under which the participant may terminate service without penalty, the charges or fees associated with using operator services, and the impact of terminating wireless service for contracts lasting more than one year, e.g., the consumer will be subject to the retail rates charged by the service provider and any applicable early termination fees. 10 The provider must provide access to local directory assistance. Yes Telrite provides directory assistance to all its customers free of charge. Although no charge is assessed for directory assistance calls made by its customers, such calls use the minutes of the customer making the directory assistance call. 11 The provider shall offer and file a schedule of California LifeLine service rates and charges. 12 The provider must provide access to 800 or 800-like toll-free services and provide a full disclosure to the participant concerning how charges for 800 or 800-like toll-free services would apply if the participant does not subscribe to unlimited voice service. Yes Yes Telrite submits Exhibit C as its schedule of rates and charges. Telrite provides its customers with access to 800 or 800-like toll-free services. Under Telrite s business model, there is no toll charge for these calls. Although there is free access to 800 or 800-like toll-free services, such calls are treated the same as regular outgoing calls with respect to minute usage.

25 No. Service Element of Appendix A-2 Complies? Comments 13 The provider must provide free, unlimited access to customer service for information about California LifeLine, service activation, service termination, service repair, and bill inquiries. Calls to the provider's customer service shall not count against the participant's allotted voice minutes or number of calls. Yes Telrite s California LifeLine customers are provided free, unlimited access to customer service either by dialing 611 or by dialing the toll-free Telrite customer service number. Calls to Telrite customer service do not count against the California LifeLine customer s allotted voice minutes or number of calls. 14 The provider must provide free, unlimited access to customer service representatives fluent in the same language (English and non-english) in which California LifeLine was originally sold or marketed. Calls to the provider's customer service shall not count against the participant's allotted voice minutes or number of calls. 15 The provider must provide free access to Toll-Blocking Service. 16 The provider must provide free access to Toll-Control Service, but only if (i) the California LifeLine Service Provider is capable of offering Toll-Control Service, and (ii) the California LifeLine subscriber has no unpaid bill for toll service. Yes Yes Yes At this time, Telrite only intends to market and sell California LifeLine service in English and Spanish. Telrite will therefore provide both English and Spanish speaking customer service operators through its customer service department, which may be accessed as described in Number 13, above. Telrite is a prepaid service provider, which means that customers pay for their service in advance and can use only the amount of service for which they have already paid. Furthermore, Telrite provides uniform pricing for both local and domestic longdistance telephone calls. Therefore, the prepaid nature of the service, along with the fact that voice calls are not distance sensitive, acts in effect as a toll-blocking service. See Number 15, above. The prepaid nature of the service, along with the fact that voice calls are not distance sensitive, acts in effect as a toll-control service. 17 The provider must provide access to two California LifeLine discounted telephone lines to Deaf and Disabled Telecommunications Program participants or teletypewriter users. Yes Telrite will provide access to two California LifeLine discounted telephone lines to Deaf and Disabled Telecommunications Program

26 No. Service Element of Appendix A-2 Complies? Comments participants or teletypewriter users. 18 The provider must provide free access to the California Relay Service via the 711 abbreviated dialing code. Yes Telrite will provide free access to California Relay Service through the 711 abbreviated dialing code. 19 The provider must provision access to public safety N11s (211, 311, 511, 711, 811 and 911). The provider must provide free, unlimited access to public safety N11s (211, 311, 511, 711, and 811) for California LifeLine eligible plans with 1,000 or more voice minutes. Calls to these special service N11s shall not count against the participant's allotted voice minutes or number of calls. Only the call to the 711 relay service is required to be free and not counted against minutes, not the associated call made using the 711 relay service. Wireless providers may meet this obligation by offering these features on plans with 1,000 or more minutes, or by offering at least one plan with unlimited voice minutes that conform to this Decision, and which may include text, but not video or data. 20 The provider must provide free, unlimited access to 611 for service provider billing and repair services. Calls to 611 shall not count against the participant's allotted voice minutes or number of calls. Yes Telrite meets the N11 requirement by offering free, unlimited access to public safety N11s (211, 311, 511, 711, and 811) for its California LifeLine eligible plan with 1,000 or more voice minutes. Yes Telrite will provide free, unlimited access to 611 for service provider billing and repair services. For all Telrite LifeLine customers, calls to 611 are free and do not use plan minutes. 21 The provider must provide access to 411, and disclose charges and conditions associated with 411 access and information. Yes Telrite provides access to 411 and discloses the charges and conditions associated with 411 access and information.

27 CALIFORNIA LIFELINE PLAN COMPARISON CHART California LifeLine 1250 Unit plan California LifeLine Unlimited plan Regular Rate $22.40 $29.95 Federal Lifeline Discount $9.25 $9.25 California LifeLine Discount $12.65 $12.65 Additional Company Discount $0.50 $8.05 Monthly Discounted Rate $0.00 $0.00 Number of Minutes 1,250 1 Unlimited Domestic Messages Yes, including 250 MMS 1 Unlimited Data 250 MB No Applicable Taxes, Fees, and $0.00 $0.00 Surcharges California LifeLine Taxes, Fees, $0.00 $0.00 and Surcharges Exemption Per Minute/Message Fee for Additional Minutes/Messages $5.00 denomination 60 minutes ($0.083 per minute) of use 2 ; $10.00 denomination 130 minutes ($0.077 per minute) of use 2 ; $4.95 denomination 1 day Unlimited Talk and Text; $7.95 denomination - 3 day Unlimited Talk and Text; $12.95 denomination 1 week Unlimited Talk and Text; $19.95 denomination 2 week Unlimited Talk and Text; $29.95 denomination 1 month Unlimited Talk and Text Fee for Additional Data $ MB of data $ MB of data

28 California LifeLine 1250 Unit plan California LifeLine Unlimited plan Fee for Calling N11 Special $0.00 $0.00 Service Numbers Fee for Calling 411 / Directory No fees. Decrements units. No fees. Decrements units. Assistance Fee for Calling 611 Fee for Calling 611 / Operator $0.00 $0.00 Services Regular Activation Fee $39.00 $39.00 Discounted Activation Fee $0.00 $0.00 Cell Phone Fee $0.00 $0.00 Restocking Fee $0.00 $0.00 Deposit $0.00 $0.00 Early Termination Fee $0.00 $0.00 Nationwide Domestic Long Included Included Distance Caller ID Included Included Call Waiting Included Included Call Forwarding Included Included Voic Included Included 3-way Calling Included Included Rollover Unused Minutes/Text No No Option Contract Needed No No Credit Check Needed No No Fee for Changing Plans $ $ Units are depleted at the rate of one (1) unit per voice minute and one (1) unit per three (3) SMS text messages sent or received. SMS sent to or from Life Wireless do not decrement units. The allocation of 250 MMS messages is separate from the 1250 units. Sending/receiving MMS messages does not deplete units, and sending/receiving SMS messages does not deplete the allocation of MMS messages. SMS messages sent to or from Life Wireless do not decrement units. 2 Bundles of additional minutes in the $5.00 and $10.00 denomination do not expire. 3 Customers can always change plans for no charge. Any MMS or data previously allocated to the customer can be used until the customer s next recharge date.

29 SCHEDULE OF RATES AND CHARGES FEATURES AVAILABLE TO TELRITE S PREPAID WIRELESS PLANS Service/Feature Name Caller ID Call Waiting Call Forwarding Voic 3- Way Calling Toll Blocking International Long Distance (ILD) Blocking 900 / 976 Call Block Service/Feature Definition A feature that alerts you to an incoming call and allows you to see the number from which the call is A feature that alerts you to an incoming call while you're on a call and allows you A feature whereby all calls to your mobile phone number redirect A feature that lets a caller to leave a message or access other available options A feature that allows you to merge three separate line calls into one call. A feature to limit toll spending thresholds A feature where outbound calls are blocked to international destinations. A feature where outbound calls are blocked to 900 and 976 numbers. Regular Service / Feature Rate and $0.00 None $0.00 None $0.00 None $0.00 None $0.00 None Service/Feature Restrictions $0.00 Note: once toll limits have been N/A $0.00 reached, only calls to 611 and Note: Telrite does not offer ILD as a part of the federal Lifeline or California LifeLine benefit. However because outgoing International Calls are blocked unless the customer purchases a special International Long None Local Calls Any call, text message or other connection made to a location in your local calling area. $0.00 None

30 Service/Feature Name Long Distance International Texts Roaming 211 Information and referral service Service/Feature Definition Any call, text message or other connection made to a location outside your local calling area. Any text message made to international destinations. Calls made outside of the provider s network region. Regular Service / Feature Rate and * Long Distance will be charged at one (1) unit per voice minute and one third (1/3) unit per text N/A N/A Service/Feature Restrictions None Information and referral service. $0.00 None Telrite does not offer International Texts as a part of the federal Lifeline or California LifeLine benefit. Telrite does not charge for roaming. Customers can roam at no additional charge where roaming Government Information Directory Services Transportation Information Non-emergency government service information. 411 gives you access to telephone numbers and addresses of business, Non-emergency government service information. $0.00 None $0.00 No fees. Decrements units. $0.00 None Customer and Repair Service TRS Relay Access Call Before You Customer service and repair information. $0.00 FCC adopted use of the 711 dialing code for access to Telecommunications Relay Services (TRS). $0.00 None CBUD information to protect pipes. $0.00 None Note: Only the call to the 711 relay service is not counted against Dig (CBUD) Emergency Services Emergency call number based on location information available. $0.00 None