20240411Application.pdf

RECEIVED
Thursday,April 11,2024 11:46:27 AM
IDAHO PUBLIC
Ziply Fiber UTILITIES COMMISSION
135 Lake Street South,Suite 155, Kirkland,WA 98033 •
M.[phone] [e-mail]
fiber
ZFP-T-24-01
April 11, 2024
Sent via electronic mail to [e-mail]
Ms. Monica Barrios-Sanchez
Commission Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83720
Re: Ziply Fiber Pacific, LLC dba Ziply Fiber Application for Designation as an Eligible
Telecommunications Carrier for the Limited Purpose of Offering Lifeline Service to Qualified
Households.
Dear Ms. Barrios-Sanchez:
Please find for filing Ziply Fiber Pacific, LLC dba Ziply Fiber's Application for Designation as an
Eligible Telecommunications Carrier for the limited purpose of offering Lifeline service to qualified
households in the state of Idaho.
If you have any questions regarding this filing, you may contact me at [phone].
Sincerely,
Jessica Epley
VP - Regulatory & External Affairs
Ziply
ziplyfiber.com fiber

Before the
IDAHO PUBLIC UTILITIES COMMISSION
In the Matter of Case No. ZFP-T-24-01
Application of Ziply Fiber Pacific, LLC for APPLICATION
Designation as an Eligible
Telecommunications Carrier in the State
of Idaho to Receive Federal Lifeline
Support
APPLICATION FOR DESIGNATION AS AN
ELIGIBLE TELECOMMUNICATIONS CARRIER IN THE STATE OF IDAHO
TO RECEIVE FEDERAL LIFELINE SUPPORT
Ziply Fiber Pacific, LLC, dba Ziply Fiber ("ZFP" or the "Company"), pursuant to Section §
214(e)(2)' of the Federal Communications Act of 1934, as amended (the "1996 Act"), the rules
and regulations of the Federal Communications Commission ("FCC") related to Universal
Service,z Idaho statutes,3 and the requirements set forth in Idaho Public Utilities Commission
("Commission") Order No. 29841,4 respectfully submits this Application for Designation as an
Eligible Telecommunications Carrier ("ETC"). ZFP seeks ETC designation in order to receive
Lifeline support in the state of Idaho and authorization to participate in and receive reimbursement
from the Idaho Telecommunications Service Assistance Program ("ITSAP") (collectively, the
' 47 U.S.C. § 214(e)(2).
2 47 C.F.R. §§ 54.201, 54.202; see also 47 C.F.R. §§ 54.101 through 54.207 (the "FCC Rules") and AU
Docket No. 20-34, et al., Rural Digital Opportunity Fund Phase I Auction (Auction 904) Closes; Winning
Bidders Announced; FCC Form 683 Due January 29, 2021; DA 20-1422 (rel. Dec. 7, 2020) ("Public Notice");
Lifeline and Link Up Reform and Modernization; et al., 27 FCC Rcd 6656 (2012) ("Lifeline Reform Order").
3 Idaho Stat. § 62-610D.
4 Case No. WST-T-05-1, The Application of WWC Holding Co., Inc. dba Cellular-One Seekinq Designation
as an Eligible Telecommunications Carrier that may Receive Federal Universal Service Support, Order No.
29841 (Aug. 4, 2005) ("ETC Order").
1

"Designated Service Area". Specifically, ZFP seeks to be designated as an ETC throughout
the area defined by its physical network footprint in Idaho, as that footprint expands from time
to time (e.g., as a result of buildout or acquisition of physical plant). The public-facing FCC
broadband map at httl)s://broadbandmap.fcc.gov/home depicts ZFP's network in Idaho. This
representation is validated twice a year by the FCC' and is subject to a challenge process,'
allowing both the Commission and Idaho consumers to assess the geographic availability of
ZFP's service offerings and corresponding Designated Service Area.
As demonstrated herein, the Company meets all the statutory and regulatory requirements
for designation as an ETC in the State of Idaho. Accordingly, the Company respectfully requests
the Commission grant it ETC status in the Designated Service Area on an expedited basis to
enable ZFP to begin providing Lifeline service in addition to ITSAP support to eligible customers
at the earliest practical time.
In support of this Application, the Company states as follows:
BACKGROUND
1. ZFP is a Delaware limited liability company with its headquarters at 135 Lake
Street S., Suite 155, Kirkland, Washington 98033. The Company is registered with the Idaho
Secretary of State to conduct business in the state as shown in Exhibit 1. The Company will
operate under the DBA name of "Ziply Fiber" in Idaho, which also has been registered with the
Idaho Secretary of State as reflected in Exhibit 2. Attached as Exhibit 3 is a current list of the
Company's officers, along with relevant biographical information.
2. ZFP is a common carrier with a fully constructed fiber-optic network over
which it currently offers a full suite of communications services to customers in Idaho. The
Company has never been denied ETC designation by any state commission or by the FCC.
a 47 U.S.C. §§ 642(a)(1)(A), (a)(2).
6 47 U.S.C. §§ 642(a)(1)(B)(iii), (b)(5).
2

3. The FCC has adopted a number of cost recovery policies and mechanisms
designed to promote and maintain universal service. One aspect of universal service is
the availability of subsidies from the federal Universal Service Fund ("USF"), created by
the Act. The USF was created, in part, to provide support to qualifying low-income
communications end-users. Mechanisms were also established to moderate the amount
of costs to be recovered through basic, recurring charges to low-income users, thereby
assisting efforts to maintain reasonable basic rate levels for those users. Under 47 U.S.C.
§ 214(e), only common carriers designated as an ETC may receive subsidies from the
federal USF. Section 214(e)(2) of the Act provides that:
A State commission shall upon its own motion or upon request designate a
common carrier that meets the requirements of paragraph (1) as an eligible
telecommunications carrier for a service area designated by the State
commission. Upon request and consistent with the public interest,
convenience, and necessity, the State commission may, in the case of an area
served by a rural telephone company, and shall, in the case of all other areas,
designate more than one common carrier and an eligible telecommunications
carrier for a service area designated by the State commission, so long as each
additional requesting carrier meets the requirements of paragraph (1). Before
designating an additional eligible telecommunications carrier for an area
served by a rural telephone company, the State commission shall find that the
designation is in the public interest.
Section 214(e)(1) of the Act provides:
A common carrier designated as an eligible telecommunications carrier under
paragraph (2), (3), or (6) shall be eligible to receive universal service support
in accordance with Section 254 of this title and shall, throughout the service
area for which the designation is received -
(A) offer the services that are supported by Federal universal service support
mechanisms under Section 254(c) of this title, either using its own facilities or
a combination of its own facilities and resale of another carrier's services
(including the services offered by another eligible telecommunications carrier);
and
(B) advertise the availability of such services and the charges therefor using
media of general distribution.
4. Pleadings, orders, notices and other correspondence filed in this matter
should be served upon:
3

Jessica Epley
Ziply Fiber
135 Lake Street South, Suite
155
Kirkland, WA 98033
Telephone: [phone]
Email: messica.epley(@ziply.com
The above-referenced individual agrees to receive all Commission notices and orders
regarding this proceeding via electronic mail.
INFORMATION REQUIRED UNDER FCC RULES AND IDAHO LAW
5. Section 214(e)(1) of the federal Act, the FCC's rules, Idaho Code § 62-
610D(3)(a), and the Commission's ETC Order set forth certain requirements for ETC
designation in Idaho.7 As demonstrated below, the Company meets each of these
requirements. The requested designation of ZFP as an ETC in the Designated Service Area
will provide better service and increased consumer choice in the state of Idaho.
6. FCC Rule 54.201(c): FCC Rule 54.202(b); ETC Order, Appendix Section A.4. An
ETC applicant must demonstrate the ETC designation is consistent with the public interest,
convenience, and necessity, and in the case of an area served by a rural telephone company,
demonstrate the public interest will be met by an additional designation. In evaluating the public
interest element, the Commission generally has considered two factors: (1) whether the entity
contributes to state assistance programs; and (2) whether the designation is sought for only part
of a rural telephone company's study area, thus leaving some (perhaps less profitable)customers
without service (i.e., cream skimming).$
7. Designation of the Company as an ETC will serve the public interest,
convenience, and necessity. Upon designation as an ETC, ZFP will make Lifeline service
available to qualifying customers in the Designated Service Area pursuant to the guidelines
47 U.S.C. §214(e)(1);47 C.F.R. §§ 54.201, 54.202; Idaho Code§ 62-610D(3)(a); ETC Order, Appendix.
8 See, e.g., Order No. 33002 at 2-3; Order No. 33226 at 3.
4

and requirements of the universal service program and 47 C.F.R. § 54.202.
8. This planned investment and deployment in the Designated Service Area will
further the goals of the Commission and the FCC by expanding the reach of digital
connectivity to promote economic growth in rural areas and ensure quality communications
services are available at "just, reasonable, and affordable rates."9 As the FCC has observed,
"an important goal of the [federal] Act is to open local telecommunications markets to
competition. Designation of competitive ETCs promotes competition and benefits consumers
in rural and high-cost areas by increasing customer choice, innovative services, and new
technologies."10. Because the funding for ACP has expired, ZFP is particularly motivated to
obtain federal funding through Lifeline programs in order to ensure it can continue providing
support to low-income customers. However, Lifeline funding ultimately requires that ZFP obtain
an ETC designation.11
9. Grant of the instant petition ensures that ZFP will be best positioned to offer
supportive services by the time funding is in place. ZFP anticipates being able to provide higher-
quality services, including the ability to offer faster broadband speeds to a greater proportion of
its customers in rural areas. ZFP's fiber-based voice service offerings provide a high-quality
product for rural customers, and its broadband services provide speeds of up to approximately 1
Gbps. to customers.
10. The Company commits to participate in applicable Idaho assistance programs
upon approval and commencement of its business operations in Idaho. The Company's
participation in such Idaho programs also advances the public interest.
11. Finally, the Company is not engaged in "cream skimming."While federal rules (47
U.S.C. §§ 160, 214(e)(5) and 47 C.F.R. § 54.207(b)) require that the service area of an ETC
9 47 U.S.C. § 254(b)(1).
10 Federal-State Joint Board on Universal Service, 16 FCC Rcd 48, 117 (2000).
11 Rural Digital Opportunity Fund, Connect America Fund, Report and Order, 35 FCC Rcd 686, 723, para. 81
(2020).
5

conform to the service area of any rural telephone company serving the same area (the "service
area conformance" requirement), the FCC's Lifeline and Link Up Reform Memorandum Opinion
and Order (FCC 13-44 released April 15, 2013) authorized forbearance from the service area
conformance requirements with respect to carriers seeking to provide Lifeline-only service.12 In
light of this forbearance, the Commission has the authority to designate ETCs such as ZFP in
rural areas without concern for the service area conformance requirement.13
12. FCC Rule 54.201(d); ETC Order, Appendix Section A.1. An ETC applicant
must be a "common carrier" as defined by federal law."The Company will provide broadband
Internet access service and voice service in the Designated Service Area. The Company will
provide voice grade access to the public switched network or its functional equivalent and
minutes of use for local service at no additional charge to end users. The Company will provide
its voice service on a common carrier basis to customers.
13. FCC Rule 54.201(d)(1); FCC Rule 54.2010); ETC Order, Appendix Section A.2.
An ETC applicant must demonstrate that it is capable of providing and will continuously provide
the supported services throughout the service area either by using its own facilities or a
combination of its own facilities and the resale of another carrier's services. ZFP certifies it will
offer the services that are supported by the federal universal service support mechanisms in the
Designated Service Area either using its own facilities or a combination of its own facilities and
the resale of another carrier's services.14 Under current FCC rules, the two services are supported
by the federal universal service support mechanisms: (1) voice telephony services; and (2)
broadband Internet access services.15 Eligible voice telephony services must provide voice grade
access to the public switched telephone network ("PSTN") or its functional equivalent, minutes of
2 See In the Matter of Telecommunications Carriers Eligible for Support,Lifeline and Link Up Reform,WC Docket
No. 09-197,WC Docket No. 11-42,Memorandum Opinion and Order,FCC 13-44(rel.April 15,2013).
13 See 47 C.F.R. § 54.207(c)
14 47 C.F.R. § 54.101(a); see also ETC Order, Appendix Section A.2.
15 47 C.F.R. § 54.101(a).
6

use for local service provided at no additional charge, access to emergency 911 and enhanced
911 service in locations where implemented, and for qualifying low-income consumers, toll
limitation service.16 Eligible broadband Internet access services must provide the capability to
transmit data to and receive data by wire or radio from all or substantially all Internet endpoints,
including any capabilities that are incidental to and enable the operation of the communications
service, but excluding dial-up service.17
14. ZFP certifies that it will offer voice and broadband services in the Designated
Service Area that comply with the FCC's requirements. Section 214(e)(1)(A) of the Act18 requires
an ETC to offer the services that are supported by federal universal service support mechanisms
under Section 254(c). Effective December 29, 2011, pursuant to the USF/ICC Transformation
Order19 as further clarified by the USF/ICC Order on Reconsideration, the FCC eliminated its
former list of nine supported services and amended Section 54.101(a) of its rules to specify that
"voice telephony service" is supported by the federal universal service mechanisms. ZFP's voice
offering will provide voice grade access to the PSTN, and will include unlimited local calling. In
addition, the Company's voice offering will provide consumers with access to 911 and enhanced
911 to the extent local governments have implemented such services. With respect to toll
limitation service, the FCC eliminated the requirement to provide toll limitation services if the
Lifeline offering provides a set amount of minutes that do not distinguish between toll and non-
toll calls.20 As explained below, the Company plans to offer unlimited voice calling within the
United States for a fixed monthly price in the Designated Service Area, and thus the Company is
16 47 C.F.R. § 54.101(a)(1).
17 47 C.F.R. § 54.101(a)(2).
1147 U.S.C. §214(e)(1).
19 Connect America Fund;A National Broadband Plan for Our Future; Establishinq Just and Reasonable Rates
for Local Exchange Carriers; High-Cost Universal Service Support; Developing an Unified Intercarrier
Compensation Regime; Federal-State Joint Board on Universal Service; Lifeline and Link-Up; Universal
Service Reform—Mobility Fund, Report and Order and Further Notice of Proposed Rulemaking, 26 FCC Rcd
17663 (2011) ("USF/ICC Transformation Order").
20 Lifeline Reform Order 149.
7

not required to provide toll limitation service in connection with its Lifeline service offering.
15. Similarly, the Company's broadband Internet access service offering will provide
consumers with the capability to transmit data to and receive data from all or substantially all
Internet endpoints.
16. ZFP will provide service through facilities owned and operated by itself or its
affiliates. Under Section 214(e)(1)(A) of the Act, an ETC must offer the services supported by
federal universal service support mechanisms throughout its designated service area "either
using its own facilities or a combination of its own facilities and resale of another carrier's
services.i21 Facilities are the ETC' s "own" if the ETC has exclusive right to use the facilities to
provide the supported services or when service is provided by any affiliate within the holding
company structure.22
17. FCC Rule 54.201(d)(2); FCC Rule 54.405(b)-(d); ETC Order, Appendix Section
A_3. An ETC applicant must demonstrate that it will advertise the availability of its offering and the
charges therefore using media of general distribution. The Company will publicize the availability
of its voice and broadband service offerings throughout the Designated Service Area using media
of general distribution.23 ZFP will use a combination of digital and traditional media, such as
advertising via television, radio, newspapers, magazines or other print advertisements, outdoor
advertising, direct marketing, the Company website, and/or the Internet. It also will rely on the
marketing practices and advertising expertise of Ziply Fiber to advertise the availability of its
service offerings in the Designated Service Area.
18. In addition, ZFP will publicize the availability of Lifeline service in a manner
reasonably designed to reach those likely to qualify for the service.24 Using easily understood
21 47 U.S.C. §214(e)(1)(a).
22 See, e.g., WCB Reminds Connect America Fund Phase H Auction Applicants of the Process for Obtaining
a Federal Designation as an Eligible Telecommunications Carrier, 33 FCC Rcd 6696, nn. 23-24 (2018).
23 47 C.F.R. § 54.201(d)(2).
24 47 C.F.R. § 54.405(b).
8

language, ZFP will indicate on all materials describing its Lifeline service that: (1) it is a Lifeline
service; Lifeline is a government assistance program; (3) the service is nontransferable; (4) only
eligible consumers may enroll in the program: and (5) the program is limited to one discount per
household.25 ZFP also will disclose its name or its DBA name on all materials describing the
Lifeline service.26
19. FCC Rule 54.201(h); FCC Rule 54.2O2(a)(4).An ETC applicant seeking to provide
Lifeline services must demonstrate it is financially and technically capable of providing Lifeline
service in compliance with the FCC's rules. The FCC has stated that the "relevant considerations"
for satisfying this requirement would be whether the applicant previously offered services to non-
Lifeline consumers, how long the applicant has been in business, whether the applicant intends
to rely exclusively on universal service fund disbursements to operate, whether the applicant
receives funds from other sources, and whether the applicant has been subject to enforcement
action or ETC revocation proceedings in other states.27
20. The Company is financially and technically capable of offering Lifeline services in
the Designated Service Area. Currently, ZFP operates as a common carrier and provides a full
suite of communications services to non-Lifeline customers in Idaho over. Because it generates
and will continue to receive revenue from non-USF sources, the Company does not intend to
rely exclusively on Lifeline reimbursement for operating revenues. ZFP's affiliates Ziply Fiber
Northwest and Ziply Fiber of Idaho also can provide the Company with additional financial and
technical support as needed, and the Company will utilize the same management and day-to-day
operational personnel. Finally, the Company has not been subject to enforcement action or ETC
revocation proceedings in any state.
25 47 C.F.R. § 54.405(c). For these purposes, the term "materials describing the service" includes all print,
audio, video, and web materials used to describe or enroll in the Lifeline service offering, including
application and certification forms. See id.
26 47 C.F.R. § 54.405(d).
27 47 C.F.R. § 54.405(d).
9

21. ETC Order,Appendix Section A.5. The Commission's ETC Order requires an ETC
applicant seeking designation for "any part of tribal lands" to provide a copy of its application to
the affected tribal government or tribal regulatory authority, as applicable. However, ZFP's
Designated Service Area excludes Tribal Lands until such time, if any, that ZFP begins
discussions with the relevant Tribal authorities, and therefore ZFP is not currently required to
provide a copy of its application to any tribal government at the present time.
22. FCC Rule 54.202(a)(1); ETC Order,Appendix Section B.1.An ETC applicant must
demonstrate its commitment and ability to provide the supported services. ZFP certifies that it will
comply with the service requirements applicable to Lifeline support as well as ITSAP support in
the Designated Service Area. ZFP also certifies that it will: (a) provide service on a timely basis
to requesting customers within the Designated Service Area; and (b) provide service within a
reasonable period of time if the potential customer is within the Designated Service Area, but
outside the Company's existing network coverage if service can be provided at a reasonable cost.
23. An ETC applicant also must submit network improvement plans at designated
intervals. However, a five-year network improvement plan is no longer necessary for entities
seeking Lifeline-only designation.28 The Commission chose to adopt a similar approach in the
ETC Order to require ETCs to submit a two-year network improvement plan.29 ZFP respectfully
requests the Commission waive its two-year network improvement plan requirement as it has
done for other ETC applicants.30
24. In addition to offering the supported services in its current footprint, ZFP also
28 Lifeline Reform Order 11386.
29 ETC Order at 8.
31 See, e.g., Order No. 35126 ("The FCC waived the requirement for a winning bidder to file a five-year plan
as part of the ETC designation process, citing its heightened oversight of auction winners. ... Considering
the FCC's heightened oversight, we waive in this proceeding our requirement that the Company's ETC
Application include a two-year network improvement plan); Order No. 34254 ("Staff determined that . . . a
two-year network improvement and progress report is not required due to the FCC's waiver of the five-year
plan as part of its ETC designation process. . . . We agree with Staff. Because the FCC waived the
requirement for a winning bidder to file a five-year plan as part of the ETC designation process, a network
improvement plan is not required under Intermax's Application."); Order No. 34253 (same).
10

envisions expanding its operations into new areas as well. Because the funding for ACP has
expired, ZFP is doubly committed to ensuring it can continue providing support to low-income
customers by obtaining Lifeline support. However, that funding ultimately requires that ZFP obtain
an ETC designation.
25 . FCC Rule 54.202(a)(2); ETC Order,Appendix Section B.2.An ETC applicant must
demonstrate that it can remain functional in emergency situations. The Company certifies it will
have the ability to remain functional in emergency situations in the Designated Service Area.
Separate FCC rules also require the Company to implement certain back-up power
requirements.31 ZFP has a reasonable amount of back-up power to ensure functionality without
an external power source, is able to re-route traffic around damaged facilities, and is capable of
managing traffic spikes resulting from emergency situations. To guard against service
interruptions, such as those caused by natural or man-made events, ZFP has sufficient excess
capacity and/or redundancy and has designed its network so that its critical systems and service
locations use diverse fiber routes which have failover capabilities, ensuring its network and
services remain available to customers. In addition, ZFP will be able to rely on Ziply Fiber
Northwest's disaster recovery contingency plans such as the use of diverse/alternate routing,
electronics redundancy, redundant data centers, geographically separated operations, and
environmental controls for data and switching centers to remain functional in an emergency
situation.
26. FCC Rule 54.202(a)(3); ETC Order,Appendix Section B.3. An ETC applicant must
certify that it will comply with all applicable service quality standards and consumer protection
rules. ZFP certifies that it will comply with service quality standards and consumer protection rules
applicable to its provision of service in the Designated Service Area.
27. FCC Rule 54.202(a)(5); FCC Rule 54.202(a)(6); ETC Order, Appendix Section
31 47 C.F.R. § 9.20.
ll

B_4. The ETC Order requires an ETC applicant to provide a description of its local usage plans
and a description of the local usage plans of the incumbent local exchange carrier ("ILEC"). FCC
rules also require Lifeline-only ETC applicants to provide information describing the terms and
conditions of voice telephony service and broadband Internet access service plans to be offered
to Lifeline subscribers. For Lifeline services, the FCC has determined that providers may satisfy
the obligation to provide local usage via service offerings that bundle local and long distance
minutes.32
28. At this time, ZFP plans to offer service plans that include high-speed Internet
access service and unlimited voice calling within the United States for a fixed monthly price in the
Designated Service Area. The Company also will offer standalone voice services. ZFP has not
yet determined the specific details of its service offerings and associated rates to be offered in
the Designated Service Area, and will make services available based on customer demand in
each market. Further, ZFP's pricing will be reasonably comparable to the price of similar services
in urban areas. ZFP will offer calling plans comparable to those offered by ILECs in the
Designated Service Area.
29. ETC Order, Appendix Section C. All ETCs requesting high-cost support must
provide certain information to the Commission on an annual basis. ZFP certifies that it will comply
with all applicable annual reporting requirements of the Commission, including the requirement
to report information concerning: (1) outages; (2) unfulfilled service requests; (3) complaints; (4)
consumer protection and service quality standards; and (4)the Company's local usage plans and
ILEC local usage plans. As set forth above, the Company seeks waiver of the two-year network
improvement plan and progress report consistent with the Commission's rulings for similarly
situated applicants.
30. ETC Order, Appendix Section D. All ETCs must certify on an annual basis all
32 Lifeline Reform Order 149.
12

federal high-cost support provided to the ETC will be used only for the provision, maintenance,
and upgrading of facilities and services for which the support was intended. ZFP certifies that, in
accordance with 47 U.S.C. §254(e), it will use the high-cost support it receives for the Designated
Service Area only for the provision, maintenance, and upgrading of facilities and services for
which the support is intended.
31. FCC Rule 54.405(a). An ETC providing Lifeline services must make Lifeline
service available to qualifying low-income consumers. ZFP certifies that its Lifeline service
offering will conform to the definition of"Lifeline" in the FCC's rules.33
32. FCC Rule 54.405(e). An ETC providing Lifeline services must implement certain
de-enrollment procedures for Lifeline customers. ZFP certifies it will comply with the FCC's de-
enrollment procedures and will have general de-enrollment procedures in place for Lifeline
services. In accordance with FCC requirements, ZFP will de-enroll Lifeline customers for no
longer qualifying for Lifeline service, for duplicative support, for non-usage, for failure to re-certify,
and when requested by the Lifeline customer.
33. FCC Rule 54.409: FCC Rule 54.410. ZFP certifies that it will verify the eligibility of
its Lifeline subscriber base in accordance with FCC rules. ZFP also will establish processes for
ensuring Lifeline services are provided only to eligible customers, including procedures for
confirming consumer eligibility, enrolling eligible customers, recertifying eligibility at regular
intervals, and recordkeeping.
CONCLUSION
For the reasons stated herein, Ziply Fiber Pacific, LLC respectfully requests that the
Commission expeditiously designate it as an ETC for the provision of voice and broadband
services in the Designated Service Area.
33 47 C.F.R. § 54.401(a).
13

RESPECTFULLY SUBMITTED this 11th day of April, 2024
Ziply Fiber Pacific, LLC d/b/a Ziply Fiber
Name of Party
qq4---
Signature on Behalf of Party
Jessica Epley
Name of Signer
VP — Regulatory & External Affairs
Title of Signer
135 Lake Street South, Suite 155
Kirkland, Washington 98033
Address of Signer
503.431.0458
Telephone Number for Signer
jessica.epley(a)zi ply.com
Designated Email for Party
14

VERIFICATION
I, the undersigned, Byron E. Springer, Jr., hereby state that I am General
Counsel of Ziply Fiber Pacific, LLC dba Ziply Fiber ("ZFP"); that I am authorized
to make this Verification on behalf of the Company; that the foregoing Application
was prepared under my direction and supervision: and that the contents of the
foregoing Application are true and correct to the best of my knowledge,
information, and belief.
Executed this 19th day of March 2024.
yron Springer, Jr.
Gener .Counsel
Ziply Fiber Pacific, LLC
15

Exhibit I
Office of the Secretary
Service Date
December 8,2022
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ZIPLY FIBER ) CASE NO. ZFP-T-22-01
PACIFIC, LLC'S APPLICATION FOR )
COMPETITIVE LOCAL EXCHANGE ) ORDER NO. 35618
CARRIER(CLEC) IN THE STATE OF )
IDAHO )
On August 23,2022,Ziply Fiber Pacific,LLC, d/b/a Ziply Fiber("Company")' applied for
designation as a competitive local exchange carrier ("CLEC") in Idaho. Application at 1. The
Company plans to provide fiber-based telecommunications services, including internet access,
data transport, and voice over IP services in several Idaho cities.Id. at 2-3.
On October 31, 2022, the Commission issued a Notice of Application and Notice of
Modified Procedure, setting public comment and Company reply deadlines. Order No. 35572.
Commission Staff filed the only comments to which the Company did not reply.
With this Order, we approve the Company's Application and grant it designation as a
CLEC in Idaho.
APPLICATION
The Company plans to provide fiber-based telecommunications services—internet access,
data transport, and voice over IP—over its owned facilities in the following areas: Boise, Idaho
Falls, Lewiston, Meridian, Nampa, Pocatello, Rexburg, and Twin Falls. Id. The Company
anticipates it will begin construction in 2023 and states it may expand its service areas in the future.
Id.
The Company asserts that while it is a new entrant to the Idaho telecommunications market,
the Company is a registered CLEC in Oregon and Washington, and the Company is affiliated with
Ziply Fiber Northwest, LLC, and Ziply Fiber of Idaho, LLC, both Incumbent Local Exchange
Carriers which provide telecommunications services in Idaho.Id.
STAFF COMMENTS
Staff reviewed and analyzed the Company's Application and supplemental filings for
compliance with IDAPA 31.01.01.114 and Order No. 26665.
'The Company is a Delaware registered LLC,and provided a Foreign Registration Statement with the Idaho Secretary
of State with its Application.The Company's assumed business name"Ziply Fiber"is associated with Ziply Wireless,
LLC,as documented in Idaho Secretary of State File#0004859680.
ORDER NO. 35618 1

Staff believed the Company understands the Commission's rules and requirements related
to the provision of telecommunication services in Idaho. Staff also believed that the Company
possesses the requisite financial, managerial, and technical qualifications necessary to operate as
a provider of telecommunications services in Idaho.
Staff recommended approval of the Company's Application for authorization to operate in
the State of Idaho as a CLEC, and recommends that a certificate of public convenience and
necessity ("CPCN") should be issued, subject to the following conditions: (1) the Company
complies with the number pooling and reporting requirements of the North American Numbering
Plan Administrator, as set forth in Commission Order No. 30425; (2) the Company's agreement
to provide necessary reports and contributions as appropriate to the Idaho Universal Service Fund,
Idaho Telecommunications Relay Services, the Idaho Telecommunications Service Assistance
Program, and comply with all future reporting requirements deemed appropriate by the
Commission for competitive telecommunications providers; (3) the Company files a final price
list outlining all its rates,terms,and conditions with the Commission before issuance of the CPCN;
and (4) the Company provides three reports to the Commission with the number of basic local
exchange customers and the services being offered on the following dates of March 20,2023; July
17, 2023; and November 20, 2023. Staff further recommended the Commission revoke the
Company's CPCN if the Company fails to provide the three reports or if the Company is not
providing basic local exchange services by November 20, 2023.
COMMISSION FINDINGS AND DECISION
The Commission has jurisdiction over this matter under Idaho Code § 62-615 (the
Commission's authority to implement the Telecommunications Act of 1996) and Idaho Code §
62-605(5)(b) (the Commission's continuing, noneconomic authority over Title 62 telephone
corporations); see also 47 U.S.C. 252(e)(1).
Based on our review of the record in this case, including the comments of Staff, the
Commission finds it fair,just, and reasonable to grant the Company's Application for designation
as a CLEC in Idaho. The Company has provided all necessary information in its Application and
has the financial, managerial, and technical qualifications needed to provide fiber-based
telecommunications services in Boise, Idaho Falls, Lewiston, Meridian, Nampa, Pocatello,
Rexburg,and Twin Falls. The Company has also reviewed and agreed to comply with Commission
rules.
ORDER NO. 35618 2

The Company's Application for designation as a CLEC is approved, subject to these
conditions:
(1) The Company must comply with the number pooling and reporting
requirements of the North American Numbering Plan Administrator, as set forth in
Commission Order No. 30425;
(2) The Company must provide necessary reports and contributions as
appropriate to the Idaho Universal Service Fund,Idaho Telecommunications Relay
Services, the Idaho Telecommunications Service Assistance Program, and comply
with all future reporting requirements deemed appropriate by the Commission for
competitive telecommunications providers;
(3) The Company must file a final price list outlining all its rates, terms, and
conditions with the Commission before issuance of the CPCN;
(4) The Company must provide three reports to the Commission with the
number of basic local exchange customers and the services being offered on the
following dates:
a. March 20, 2023;
b. July 17, 2023;
c. November 20, 2023; and
(5) If the Company fails to provide the three reports or if the Company is not
providing basic local exchange services by November 20, 2023, the Commission
will revoke the Company's CPCN.
sasD
The Company must meet the foregoing conditions or its CPCN may be revoked at a future
proceeding.
ORDER
IT IS HEREBY ORDERED that the Company's Application for Designation as a CLEC
is approved, subject to the conditions described in this Order.
IT IS FURTHER ORDERED that the Company's Application for a CPCN is granted
subject to the conditions outlined above.
THIS IS A FINAL ORDER. Any person interested in this Order may petition for
reconsideration within twenty-one (21) days of the service date of this Order. Within seven (7)
days after any person has petitioned for reconsideration, any other person may cross-petition for
reconsideration.Idaho Code § 61-626.
ORDER NO. 35618 3

DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this Bch day of
December 2022.
ERIC ANDERSON, PRESIDENT
JOHN CHATBURN, COMMISSIONER
(57 R. HAMMOND JR., COMMISSIONER
ATTEST:
an Nori
Commission Secretary
I:\Legal\TELECOM\ZFP-T-22-01\ZFPT2201_final_cs.docx
ORDER NO. 35618 4

Exhibit 2
BATS STATE OF IDAHO
y o Lawerence Denney I Secretary of State
Business Office
450 North 4th Street
PO Box 83720
Boise, ID 83720
Ziply Fiber August 12, 2022
LEGAL
STE 155
135 LAKE ST S
KIRKLAND, WA 98033-6488
Filing Acknowledgment
Please review the filing information below and notify our office immediately of any discrepancies.
File#: 4859680
Filing Type: Assumed Business Name Expiration Date:
Filing Date: 08/12/2022 10:46 AM Image# : B0733-2531
Status: Active-Current Receipt#: 000700414
Congratulations on the successful filing of your Certificate of Assumed Business Name for Ziply Fiber in the State
of Idaho on the date shown above.
Mailing Address
LEGAL
STE 155
135 LAKE ST S
KIRKLAND, WA 98033-6488
When corresponding with this office or submitting documents for filing, please refer to the file number given above.
Lawer nce Denney
Idaho Secretary of State
Processed By: Business Division
Phone: [phone] * Email: [e-mail] * Website: sosbiz.idaho.gov

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Boise, ID 83720-0080 N
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Entity name Ziply Fiber
Type of Business
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business name is: (D
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ZIPLY FIBER OF IDAHO, LLC LEGAL
Foreign Limited Liability Company 135 LAKE ST S C!�
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KIRKLAND, WA 98033-6488 n
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Ziply Fiber Pacific, LLC LEGAL N
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Pagel of 1 Page 1 of 1

Exhibit 3
Ziply Fiber Leadership Team
The Ziply Fiber leadership team has extensive experience; each of our Leadership Team
members has over 20 years' experience in executive roles. Executive Chairman Steve Weed is
an industry leader who has focused on broadband services and technology for more than 25
years. His passion and experience is second to none. Prior to Ziply Fiber, Steve founded Wave
Broadband, serving as its Chief Executive Officer from 2002 through its sale in 2018. He has
served as head of Summit Communications, President of Millennium Digital Media, Chairman of
Xplornet Communications, and as a board member of both Metronet and Hargray
Communications. Steve assembled a leadership team for Ziply Fiber with decades of executive
level experience.
Chief Executive Officer Harold Zeitz has more than 30 years of experience in technology and
innovation. Prior to joining Ziply Fiber, Harold served as President and Chief Operating Officer of
Wave Broadband. Prior to joining Wave Broadband, Harold served in executive and leadership
roles at Classmates.com, International Game Technology, RealNetworks, Sharebuilder,AT&T
Wireless and McCaw Cellular. Chief Financial Officer Ryan Hjorten has more than ten years of
experience in executive financial and accounting roles. Prior to joining Ziply Fiber, Ryan served
as Controller and Chief Financial Officer at INRIX, Inc; and had managed financial operations at
Market Leader and at TelantWise. Chief Technology Officer Bambang "Bam" Liem is a
telecommunications industry veteran with 35 years of experience in engineering, operations and
system development for mobile, cable and telephone companies around the world. Barn was
the Executive Vice President of Central Technology, Operations &Systems at Wave Broadband,
where he oversaw deployment and management of Wave Broadband's Fiber& IP network
technology. Chief Operations Officer Chris Denzin has over 30 years of telecommunications
industry experience. Chris spent 26 years with CenturyLink in Arizona, Colorado, Oregon and
Washington prior to joining Ziply Fiber. Our Chief of Design and Construction, Rob Griffith has
over 20 years' experience in leading and managing teams responsible for design, engineering,
and construction of Outside Plant, Inside Plant and Core Network infrastructure to support voice
and data Internet Protocol, Metro Optical Ethernet, fiber to the Premise, Gigabit Passive optic
Network and Fiber to the Node services. Chief Marketing Officer Mike Doherty has over 22 years
of executive marketing experience. Mike served as President of Cole &Weber, one of Seattle's
premiere advertising agencies for 19 years. General Counsel Byron Springer has over 25 years
handling legal affairs for technology businesses. Prior to joining Ziply Fiber, he was the Executive
Vice President of Legal Affairs at Wave Broadband where he was responsible for a broad range
of legal and regulatory matters relating to the broadband, cable, and telecommunications
industry.