20241003Application.pdf

ziplyfiber.com
Ziply Fiber
135 Lake Street South, Suite 155, Kirkland, WA 98033
M.[phone]
[e-mail]
October 3, 2024
Ms. Monica Barrios-Sanchez
Commission Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83720
Sent via electronic mail to [e-mail]
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
RECEIVED
Thursday, October 03, 2024
IDAHO PUBLIC
UTILITIES COMMISSION

Case No: ZFP-T-24-02
1
Before the
IDAHO PUBLIC UTILITIES COMMISSION
Case No.
APPLICATION
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)1 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,2 Idaho statutes,3 and the requirements set forth in Idaho Public Utilities Commission
("Commission") Order No. 35126,4 respectfully submits this Application for Designation as an
Eligible Telecommunications Carrier ("ETC"). ZFP seeks ETC designation for the entire state of
Idaho (including tribal lands) in the designated service area, for the purposes of receiving Lifeline
support in the state of Idaho and authorization to participate in the Idaho Telecommunications
Service Assistance Program (“ITSAP”). ZFP seeks ETC designation solely to provide Lifeline
service to qualifying Idaho consumers; it will not seek access to funds from the Universal Service
1 47 U.S.C. § 214(e)(2).
2 47 C.F.R. §§ 54.201, 54.202; 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.
4Case No. TOR-R-21-01, The Application of Torch Wirless Seeking Designation as an Eligible
Telecommunications Carrier, Order No. 35126 (Aug. 25, 2021) .
In the Matter of
Application of Ziply Fiber Pacific, LLC for
Designation as an Eligible
Telecommunications Carrier in the State
of Idaho to Receive Federal Lifeline
Support
ZFP-T-24-02
2
Fund (“USF”) for high-cost support. As demonstrated herein, ZFP meets all the statutory and
regulatory requirements for designation as an ETC in the State of Idaho. Accordingly, ZFP
respectfully requests the Commission grant it ETC status in the State of Idaho 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 facilities based competitive local exchange carrier with a fully
constructed fiber-optic network over which it currently offers a full suite of communications
services to customers in Idaho. ZFP was granted a Certificate for Public Convenience and
Necessity (CPCN), Certificate No. 540, by the Idaho Commission on December 8, 2022 for
the purposes of providing wholesale transport, retail broadband, Voice over Internet Protocol
(VoIP) and local exchange service in Idaho in Docket ZFP-T-22-01.
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.
3
§ 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:
Jessica Epley
Ziply Fiber
135 Lake Street South
Suite 155
Kirkland, WA 98033
Telephone: [phone]
Email: [e-mail]

The above-referenced individual agrees to receive all Commission notices and orders
regarding this proceeding via electronic mail.
4
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 Order No. 35126 set forth certain requirements for ETC
designation in Idaho.5 As demonstrated below, the Company meets each of these requirements.
The requested designation of ZFP as an ETC in the state of Idaho will provide better service
and increased consumer choice in the state of Idaho.
6. FCC Rule 54.201(c); FCC Rule 54.202(b); Order No. 35126, 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).6
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 support available on all
offered services to qualifying customers in the state of Idaho pursuant to the guidelines and
requirements of the universal service program and 47 C.F.R. § 54.202.
8. ZFP’s planned investment and deployment in the state of Idaho 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."7 Designation of competitive ETCs promotes
competition and benefits consumers in rural and high-cost areas by increasing customer choice,
innovative services, and new technologies.”8. Because the funding for ACP has expired, ZFP is

5 47 U.S.C. § 214(e)(1); 47 C.F.R. §§ 54.201, 54.202; Idaho Code § 62-610D(3)(a); Order No. 35126, Appendix.
6 See, e.g., Order No. 33002 at 2-3; Order No. 33226 at 3.
7 47 U.S.C. § 254(b)(1).
8 Federal-State Joint Board on Universal Service, 16 FCC Rcd 48, ¶ 17 (2000).
5
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.
9. Grant of the petition ensures that ZFP will be best positioned to offer supportive
services to existing and future customers. ZFP is able to provide high-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 or higher to customers.
10. The Company commits to participate in applicable Idaho assistance programs
upon approval. 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

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.9 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.10
12. FCC Rule 54.201(d); Order No. 35126, Appendix Section A.1. An ETC
applicant must be a "common carrier" as defined by federal law." ZFP provides broadband
Internet access service and voice service in the Designated Service Area. ZFP provides voice
grade access to the public switched network or its functional equivalent and minutes of use for

9 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).
10 See 47 C.F.R. § 54.207(c)

6
local service at no additional charge to end users. The Company provides its voice service on a
common carrier basis to customers.
13. FCC Rule 54.201(d)(1); FCC Rule 54.201(i); Order No. 35126, 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 offers
the services that are supported by the federal universal service support mechanisms in the state
of Idaho using its own facilities.11 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.12 Eligible voice telephony services must provide voice grade access to
the public switched telephone network ("PSTN") or its functional equivalent, minutes of 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.13
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.14
14. ZFP certifies that it offers voice and broadband services in the state of Idaho that
comply with the FCC's requirements. Section 214(e)(l)(A) of the Act 15 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
Order 16 as further clarified by the USF/ICC Order on Reconsideration, the FCC eliminated its

11 47 C.F.R. § 54.101(a); see also Order No. 35126, Appendix Section A.2.
12 47 C.F.R. § 54.101(a).
13 47 C.F.R. § 54.101(a)(1).
14 47 C.F.R. § 54.101(a)(2).
15 47 U.S.C. § 214(e)(l).
16 Connect America Fund; A National Broadband Plan for Our Future; Establishing 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;

7
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 provides voice grade access to the PSTN and will include unlimited local calling. In
addition, ZFP's voice offering provides 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 number of minutes that do not distinguish between toll and non-toll calls.17 As
explained below, the ZFP offers unlimited voice calling within the United States for a fixed monthly
price in its Service Area, and thus the ZFP is not required to provide toll limitation service in
connection with its Lifeline service offering.
15. Similarly, the ZFP's broadband Internet access service offering provides
consumers with the capability to transmit data to and receive data from all or substantially all
Internet endpoints. Exhibit 4 lists ZFP’s current service plans.
16. Under Section 214(e)(l)(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."18 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.19 ZFP certifies that it provides service through facilities owned and operated
by itself or its affiliates.
17. FCC Rule 54.201(d)(2); FCC Rule 54.405(b)-(d); Order No. 35126, 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 its service area using media of

17 Lifeline Reform Order ¶ 49.
18 47 U.S.C. § 214(e)(l)(a).
19 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).

8
general distribution.20 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.21 Using easily understood
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.22 ZFP also will disclose its name or its DBA name on all materials describing the
Lifeline service.23
19. FCC Rule 54.201(h); FCC Rule 54.202(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.24
20. ZFP 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. Because it generates and will

20 47 C.F.R. § 54.201(d)(2).
21 47 C.F.R. § 54.405(b).
22 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.
23 47 C.F.R. § 54.405(d).
24 47 C.F.R. § 54.405(d).
9
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.
21. Order No. 35126, Appendix Section A.5. The Commission's Order No. 35126
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 does not provide service on any Tribal Lands at this time and therefore is not
required to provide a copy of its application to any tribal governments. If ZFP’s expansion plan
includes any Tribal Lands, ZPF will begin discussions with the relevant Tribal authorities.
22. FCC Rule 54.202(a)(1); Order No. 35126, 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 its service area; and (b) provide service within a reasonable period
of time if the potential customer is within the 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.25 The Commission chose to adopt a similar approach in Order
No. 35126 to require ETCs to submit a two-year network improvement plan.26 ZFP respectfully
requests the Commission waive its two-year network improvement plan requirement as it has
done for other ETC applicants.27

25 Lifeline Reform Order 11386.
26 Order No. 35126 at 8.
27 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
10
24. In addition to offering the supported services in its current service area, ZFP
also anticipates expanding its operations into new areas as well. All of ZFP’s products will be
available for customers in any expanded area.
25. FCC Rule 54.202(a)(2); Order No. 35126, Appendix Section B.2. An ETC applicant
must demonstrate that it can remain functional in emergency situations. The Company certifies it
has 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.28 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); Order No. 35126, 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); Order No. 35126, Appendix

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).
28 47 C.F.R. § 9.20.B.4.
11
Section B.4. Order No. 35126 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 offers service plans that include high-speed Internet access
service and unlimited voice calling within the United States for a fixed monthly price. ZFP
provides voice over Internet Protocol (VoIP) and broadband services either bundled together or
as individual products. All products offered by ZFP are eligible to receive the Lifeline subsidy.
ZFP will offer calling plans comparable to those offered by ILECs in the Designated Service
Area. Details regarding ZFP’s offerings can be found at ziplyfiber.com or in Exhibit 4.
29. 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.29
30. 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.
31. 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 has established processes for
ensuring Lifeline services are provided only to eligible customers, including procedures for

29 47 C.F.R. § 54.401(a).
12
confirming consumer eligibility, enrolling eligible customers, recertifying eligibility at regular
intervals, and recordkeeping. ZFP recognizes the importance of safeguarding the Universal
Service Fund from potential waste, fraud, and abuse. ZFP relies on the National Verifier for the
initial and ongoing determination of a subscriber’s eligibility to qualify for Lifeline through the
income-based eligibility criteria or program-based criteria set forth in C.F.R § 54.410. Further,
ZFP complies with the requirements of the National Lifeline Accountability Database (“NLAD”)
and section 54.404 of the FCC rules. Through these processes, ZFP can ensure applicants
adhere to the “One Lifeline Benefit per Household” requirement.
Consistent with federal regulations, ZFP will not seek USF reimbursement for new
subscribers until they have personally activated the service, either by initiation and/or actual use
of the service and will de-enroll any subscriber that has not used ZFP’s Lifeline service
as set forth in 47 C.F.R. § 54.407(c)(2). An account will be considered active if the authorized
subscriber establishes usage, as "usage" is defined by 47 C.F.R. § 54.407(c)(2), during the
specified timeframe, currently a period of thirty (30) days, or during the notice period (“cure
period”) set forth in 47 C.F.R. § 54.405(e)(3), currently a period of fifteen (15) days.
In accordance with 47 C.F.R. § 54.405(c)(3), ZFP will provide the subscriber advanced notice,
using clear, easily understood language, that the subscriber's failure to use the Lifeline service
within the notice period will result in service termination for non-usage. Consumers that have been
deactivated may participate in ZFP's Lifeline service in the future by reapplying and re-
establishing eligibility.
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.

13
RESPECTFULLY SUBMITTED this 3rd day of October, 2024
Ziply Fiber Pacific, LLC d/b/a Ziply Fiber
Name of Party
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
[e-mail]
Designated Email for Party

 


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ORDER NO. 35618 1
Office of the Secretary
Service Date
December 8, 2022
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
On August 23, 2022, Ziply Fiber Pacific, LLC, d/b/a Ziply Fiber (“Company”)1 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.
1 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.
IN THE MATTER OF ZIPLY FIBER
PACIFIC, LLC’S APPLICATION FOR
COMPETITIVE LOCAL EXCHANGE
CARRIER (CLEC) IN THE STATE OF
IDAHO
)
)
)
)
)
)
CASE NO. ZFP-T-22-01
ORDER NO. 35618
Exhibit 1
ORDER NO. 35618 2

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 3

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.
O R D E R
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 4
DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 8
th day of
December 2022.
__________________________________________
ERIC ANDERSON, PRESIDENT
__________________________________________
JOHN CHATBURN, COMMISSIONER
__________________________________________
JOHN R. HAMMOND JR., COMMISSIONER
ATTEST:
___________________________________
Jan Noriyuki
Commission Secretary
I:\Legal\TELECOM\ZFP-T-22-01\ZFPT2201_final_cs.docx
__________________________________________________________________
ERIC ANDERSON
______________________________
__________________________________________________________________________________________________________________________________________________________________________________________________________________
JOJOJOOJOOOOOJOOOJOJOJOJOOOOJOJOJOOOJOOJOJOOOOOOJOOOJOJOJOJOJOOJOOOOJOJOJOJOOOOOOOOJOOOOOOOJOOOJOOOOOOJOOOOJOJOOOOOJOOOOOOOOOJOOOOOOOOJOOOOOOOOOOOOOOOJOOJOJOOOOOOOJOOJOOOOOOOOOOJOJJJOOOOOOJOOOJJJOOOOOOOOOOOOJJOJJJOOOOOOOJOOJJJJJJJJJOOOOOJJJJJOOOOJJJJJJJJJJOJOOJJJJJJJJOOJOJJJJJOOJJJJJOJJJOOOHNHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHH R. HAMMOND JR., COMMIS
__________________________________________________________________
JaJJJJJJn Noriyuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuukikikkkkkkikkikikkkkkkkkkkikikikkkkkkkikkkkkikkkkkikkkkkkikkkkikkkkkkkkkikiiiikkkkkkikiiiiii
STATE OF IDAHO
Lawerence Denney | Secretary of State
Business Office
450 North 4th Street
PO Box 83720
Boise, ID 83720
Status: Active-Current
08/12/2022 10:46 AM
Filing Type:
4859680
Filing Date:
Assumed Business Name
File #:
When corresponding with this office or submitting documents for filing, please refer to the file number given above.
Expiration Date:
B0733-2531Image # :
Processed By: Business Division
Receipt #: 000700414
Mailing Address
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.
KIRKLAND, WA 98033-6488
STE 155
LEGAL
135 LAKE ST S
Lawerence Denney
Idaho Secretary of State
Filing Acknowledgment
Please review the filing information below and notify our office immediately of any discrepancies.
August 12, 2022
KIRKLAND, WA 98033-6488
STE 155
LEGAL
135 LAKE ST S
Ziply Fiber
Phone: [phone] * Email: [e-mail] * Website: sosbiz.idaho.gov
Exhibit 2
Exhibit 3

Ziply Fiber Leadership Team

The Ziply Fiber leadership team has extensive experience; each of our Leadership Team
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an industry leader who has focused on broadband services and technology for more than 25
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ŝŶĚƵƐƚƌLJ͘

Exhibit 4

Fiber 100 Mbps Upload/Download
Fiber 300 Mbps Upload/Download
Fiber Gig Speed Upload/Download
2 Gig Fiber 2 Gig Speed Upload/Download
Phone Voice over Internet Protocol