20230420Response.pdf

135 Lake Street South, Suite 155
Kirkland, WA 98033
M. [phone]
[e-mail]

ziplyfiber.com
April 20, 2023
Sent via electronic mail to [e-mail]
Ms. Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd, Bldg 8
Suite 201-A
Boise, Idaho 83714

Re: IPUC Case No. VZN-T-23-01, Frederic Quinto vs. Ziply Fiber Northwest, LLC
Dear Idaho Public Utilities Commission:
Thank you for the opportunity to respond to Mr. Quinto’s formal complaint. Ziply Fiber believes
that Mr. Quinto is confused regarding the responsibility of the customer for inside wire facilities
on the customer side of the Standard Network Interface (SNI).
Ziply Fiber has reconfirmed through its local manager, Chris Vickery, that permanent repairs
have been made to the pedestal serving Mr. Quinto’s residence, and the drop wire to the SNI on
the residence is buried, which reduces the likelihood of damage from the elements or
human/animal activity. These are permanent facilities improvements paid for by Ziply Fiber.
Ziply Fiber submits that there are no temporary facilities on Ziply Fiber’s side of the SNI. Mr.
Quinto’s service is subject to Ziply Fiber’s price list terms: (https://wholesale.ziplyfiber.com/-
/media/Wholesale/Files/doc/id-price-list-no1-network-access-service-zfn.pdf) and the
Residential Service terms and conditions found at the following link:
(https://ziplyfiber.com/corporate/terms-conditions/resi-services-terms). The Price List language
pinpoints the main issue here: “Installation and Maintenance of CPIW is the responsibility of the
customer.”
Ziply Fiber field and central office technicians have tested Mr. Quinto’s line to the SNI multiple
times over the last several months and have reported clear dialtone to the Company side of the
device. Ziply Fiber has minimal information on the condition of the inside wire on Mr. Quinto’s
side on the SNI. Mr. Quinto does not subscribe to an inside wire maintenance plan, under
which the Company would repair or replace any inside wire components that may be affecting
service quality at no cost. Ziply Fiber technicians strongly suspect that there is recurring
damage to Mr. Quinto’s inside wire that is affecting service. However, Ziply Fiber employees or
contract technicians will not enter Mr. Quinto’s residence until he cures the unsafe working
conditions therein.
RECEIVED
2023 April 20, 1:39PM
IDAHO PUBLIC
UTILITIES COMMISSION

ziplyfiber.com 2
Based on the facts and arguments set out above, Ziply Fiber respectfully requests that this
formal complaint be dismissed. Ziply Fiber will continue to respond to Mr. Quinto insofar as any
issues with the Company’s service to the SNI.
Sincerely,

Jessica Epley
VP - Regulatory & External Affairs