20220104Comments.pdf

Ziply Fiber
1800 41st Street, Everett, WA 98203
Shannon Lipp
[phone]
[e-mail]
ziplyfiber.com
January 4, 2022
VIA UPS OVERNIGHT
Idaho Public Utilities Commission
11331 W Chinden Blvd. Bldg. 8, Ste. 201-A
Boise, ID 83714
Re: Docket No. GNR-T-21-10 - In the Matter of the Public Utility Commission’s Inquiry into
the Review of Applications to Determine Whether Broadband Equipment Meets the
Eligibility Requirements for Investment Tax Credits
Initial Comments
Dear Staff,
Please find the following original and seven (7) copies of the enclosed for filing:
Ziply Fiber Northwest, LLC and Ziply Fiber of Idaho, LLC’s Initial Comments
Please contact us if you have any questions regarding this filing. Thank you.
Sincerely,
Shannon Lipp
Legal Assistant
Enclosures
cc: Service List
RECEIVED
2022 JAN 04 AM 8:54
IDAHO PUBLIC
UTILITIES COMMISSION
January 4, 2022

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE PUBLIC
UTILITY COMMISSION’S INQUIRY INTO
THE REVIEW OF APPLICATIONS TO
DETERMINE WHETHER BROADBAND
EQUIPMENT MEETS THE ELIGIBILITY
REQUIREMENTS FOR INVESTMENT TAX
CREDITS
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CASE NO. GNR-T-21-10

ZIPLY FIBER NORTHWEST,
LLC AND ZIPLY FIBER OF
IDAHO, LLC’S INITIAL
COMMENTS

On December 21, 2021, The Idaho Public Utilities Commission (“PUC” or
“Commission”) issued Order 35264, which granted intervention as a party in this proceeding to
the named Ziply Fiber entities, which are two certificated Incumbent Local Exchange Carriers
operating in Idaho inside their respective PUC-assigned service territories. Below is Ziply
Fiber’s initial comment, submitted in accordance with the Notice of Modified Procedure issued
by the Commission in this docket on November 30, 2021.
The named Ziply Fiber operating entities both own and operate a substantial and
material amount of equipment “necessary to the provision of broadband services and an integral
part of a broadband network.” Idaho Code § 63-3029I(3)(b)(i). In addition, Ziply Fiber is
investing millions to expand its ability to provide fiber broadband services throughout its Idaho
service territory.
In terms of substantive comments, Ziply Fiber has only one at this point in the
proceedings. Should Staff make recommendations in addition to the Ziply Fiber comment below,
the Company will address those comments in subsequent reply filings.
Order No. 28784, in Case No. GNR-T-01-10, specified what information applicants
must submit to obtain an order that installed equipment is “qualified” broadband equipment. The
fourth information requirement in that Order asks applicants to:

“4. State the network transmission rate in bits per second at which
subscribers to the relevant broadband network can receive and send
(download and upload).”
Ziply Fiber believes the mention of a bits per second rate should be modified to
reflect a megabits per second rate for qualified broadband equipment to acknowledge the
development of new technology and the general increase in available speeds since 2001, when
the original Order was promulgated.
WHEREFORE, Ziply Fiber respectfully requests that the Commission review its
initial comments as a party to this proceeding, adjust the language in Order 28784, and grant
whatever other relief the Commission deems appropriate under the circumstances.
Respectfully Submitted,

George Baker Thomson, Jr.
Associate General Counsel, Ziply Fiber
ATTN: Legal
1801 41st St., N-100
Everett, WA 98203
[e-mail]

CERTIFICATE OF SERVICE
Docket No. GNR-T-21-10

I hereby certify that on January 4, 2022, I have electronically filed a true copy of the ZIPLY FIBER
NORTHWEST, LLC AND ZIPLY FIBER OF IDAHO, LLC’S INITIAL COMMENTS. On January 4,
2022 I have sent the original via overnight courier to the Idaho Public Service Commission. Additionally,
this document was served upon the following,

Emailing a true and correct copy:

Commission Staff
Riley Newton, [e-mail]

___________________________________
Shannon Lipp, Legal Assistant
Ziply Fiber
1800 41st Street, N-100
Everett, WA 98203
[e-mail]
425-261-1023