20220111Reply Comments.pdf

Ziply Fiber
1800 41"t Street, Everett, WA 98203
Shannon Lipp
[phone]
[e-mail]
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January 11,2022
VIA UPS OVERNIGHT
ldaho Public Utilities Commission
11331 WChinden Blvd. Bldg.8, Ste.2O1-A
Boise, lD 83714
Re: Docket No. GNR-T-21-10 - ln the Matter of the Public Util$ Commission's lnquiry into
the Review of Applications to Determine Whether Brcadband Equipment Meetsthe
Higibility Requircments for lnvestment Tax Crcdits
Reply Comments
Dear Stafi,
Please find the following origina! and seven (7) copies of the enclosed for filing
Ziply Fiber Northwest, LLC and Ziply Fiber of ldaho, LLC's Reply Commentsa
Please contact us if you have any questions regarding this filing. Thank you.
Sincerely,
8t--*'l-
Shannon Lipp
LegalAssistant
Enclosurescc: Service List
ziplyfiber.com
January 11,2022
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PUBLIC
UTILITY COMn[rSSrON',S INQUIRY INTO
THE REYIEW OF APPLICATIONS TO
DETERMINE WTIETHER BROADBAIII)
EQUIPMENT MEETS TIIE ELIGIBILITY
REQUIREMENTS FOR INYESTMENT TAX
CREDITS
CASE NO. GNR.T-?I.IO
ztPLY FIBER NORTHWEST,
LLC AI\D ZIPLY FIBER IDAHO,
LLC'S REPLY COMMENTS
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Below are Ziply Fiber's reply comments, 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 $ 63-30291(3)(bxi). [n addition, Ziply Fiber is
investing millions to expand its ability to provide fiber broadband services throughout its Idaho
service territory.
ln terms of substantive comments, Ziply Fiber states that it concurs with Staffs
recommendation to delete ltem 7 of the original requirements established by Commission Order
No. 28784. Ziply Fiber also does not oppose Staff s recommendations regarding ltems l, 2,3, 4
6, 8 and 9.
With regard to StafPs recommendations regarding ltem 5, Ziply Fiber believes that
reporting the listed items would force a carrier to publicly reveal competitively sensitive and
trade secret information that could be useful to a competitor planning to deploy and/or market its
network in the same or adjacent geography in Idaho. Ziply Fiber urges the Commission to find
that, taken as a whole, the list required by rewritten Item 5 constitutes confidential information
and should be available only to Staff, and where appropriate, admitted parties in any future
docket (or other proceeding) who sign a standard protective order.
WHEREFORE, Ziply Fiber rcspccffirlly rquasts that ttre Commission revicw its
reply commcnts ss a party to &is proccoding, adjust the language in Order 2878y'- appropriately,
and gnnt whatcver oilher relMthe Commission dcems apprcpriat€ under the circumstances.
Respectfully Submitte4
fe
Georgo Bakcr Thomson, Jr.
Associatc General Cormsel, Ziply Fiber
ATTN: Legal
lSol 4ld sL, N-100
Everett, WA 98203
[e-mail]
CERTIFICATE OF SERVICE
Docket No. GNR-T-21-10
I hereby certiff that on January 11,2022,1 have electronically filed a true copy of the ZIPLY FIBER
NORTHWEST, LLC AND ZIPLY FIBER OF IDAHO, LLC'S REPLY COMMENTS. On January 11,
2022 a have sent the original via overnight courier to the ldaho Public Service Commission. Additionally,
this document was served upon the following,
Emailing a true and conect copy
Commission Staff
Riley Newton, rilev. newton@puc. idaho.qov
Lipp,Assistant
Ziply Fiber
1800 41't Street, N-100
Everett, WA 98203
shannon. [e-mail]
425-261-1023