20241112Staff 1-32 to ZFP.pdf

RECEIVED
Tuesday, November 12, 2024 4:05:34 PM
IDAHO PUBLIC
UTILITIES COMMISSION
MICHAEL DUVAL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 11714
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ZIPLY FIBER )
PACIFIC,LLC,DB/A ZIPLY FIBER'S ) CASE NO. ZFP-T-24-02
APPLICATION FOR DESIGNATION AS AN )
ELIGIBLE TELECOMMUNICATIONS ) FIRST PRODUCTION
CARRIER IN THE STATE OF IDAHO TO ) REQUEST OF THE
RECEIVE FEDERAL LIFELINE SUPPORT ) COMMISSION STAFF
TO ZIPLY FIBER PACIFIC,
DB/A ZIPLY FIBER
Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Michael Duval, Deputy Attorney General, requests that Ziply Fiber Pacific, LLC, D/B/A Ziply
Fiber("Company")provide the following documents and information as soon as possible, but no
later than TUESDAY, DECEMBER 3, 2024.
This Production Request is to be considered as continuing, and the Company is requested
to provide,by way of supplementary responses, additional documents that it, or any person
acting on its behalf, may later obtain that will augment the documents or information produced.
Please provide answers to each question, supporting work papers that provide details or
are the source of information used in calculations, and the name,job title, and telephone number
of the person preparing the documents. Please also identify the name,job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO ZIPLY PACIFIC 1 NOVEMBER 12, 2024

In addition to the written copies provided in response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUEST NO. 1: Please provide the Company's proposed designated service area,
i.e., a map or zip codes in an Excel spreadsheet along with the city and county to which each
zip code corresponds.
REQUEST NO. 2: Please provide the following Eligible Telecommunications Carrier
("ETC") statuses:
a. The status of the Company's ETC Applications before the Federal Communications
Commission("FCC") and/or any other jurisdictions;
b. The ETC status of Ziply Fiber Northwest, LLC, parent company("Parent"), before
the FCC and/or any other jurisdictions;
c. The ETC status of Ziply Fiber of Idaho, LLC, sister company ("Sister I"), before the
FCC and/or any other jurisdictions; and
d. The ETC status of Ziply Wireless, LLC, sister company ("Sister 2"),before the FCC
and/or any other jurisdictions.
REQUEST NO. 3: Has the Company,Parent, or Sister I been subjected to any FCC or
Universal Service Administrative Company("USAC") audits? If yes,please describe the nature
of the audit, describe the current status, and provide a copy of the resulting audit report for each
audit.
REQUEST NO. 4: Please describe any pending investigations of the Company,
Parent, or Sister I by USAC, the FCC, or any state commission with respect to a state or
federal Lifeline program, of which the Company is aware. Please describe the nature and
status of the investigation in the Company's response.
FIRST PRODUCTION REQUEST
TO ZIPLY PACIFIC 2 NOVEMBER 12, 2024

REQUEST NO. 5: Has the Company, Parent, or Sister 1 received any data or
information requests from the FCC related to the Lifeline program, including but not limited to
requests from the Office of Inspector General, Enforcement Bureau, etc.? If so,please
identify the requestor, and provide a copy of the data or information requests and any
responses provided by the Company.
REQUEST NO. 6: Has the Company,Parent, or Sister I ever returned, remitted,
or repaid federal or state Lifeline funds that it had received? If so, please identify each
instance and the specific reasons for each action.
REQUEST NO. 7: Please explain in detail how Wi-Fi secures data transfers
once a customer connects a phone with the Company, Parent, Sister 1, or Sister 2 to public
Wi-Fi and provide any supporting documentation that establishes the transfers are secure.
REQUEST NO. 8: Please provide the following financial documents for the Company
or Parent:
a. FCC Form 499 filed in 2024, 2023, and 2022; and
b. Financial statements(including balance sheets, income statements, and cash
flow statements) for the last three years and accompanying audit reports, if any.
REQUEST NO. 9: How many Lifeline and how many non-Lifeline customers did
the Company have nationally on October 31, 2024?
REQUEST NO. 10: Please describe the Company's plans to advertise the availability
of Lifeline services using media of general distribution to reach the target low-income
population in Idaho. In the Company's response:
a. Please specifically identify the types of general distribution media that will be
employed;
b. Please provide sample copies of marketing material the company either currently
uses to advertise Lifeline or intends to use in Idaho, including the specific
products and the charges thereof; and
FIRST PRODUCTION REQUEST
TO ZIPLY PACIFIC 3 NOVEMBER 12, 2024

c. Please provide an estimate of the Company's budget for advertising that targets the
low-income population in Idaho for the first twelve months of operation in the event
the Company is designated in Idaho.
REQUEST NO. 11: In response to the coronavirus pandemic,how many additional
free voice minutes and free gigabytes of data did the Company offer to Lifeline customers in
each state where it has ETC designation? Please indicate the date the additional minutes and
data became available and, if no longer available, the date that it was no longer available.
REQUEST NO. 12: Please provide a detailed narrative with supporting data and
other available sources to support the Company's statement on page 5 of its Application for
designation as an ETC that the company offers "high-quality services."
REQUEST NO. 13: How long, on average, does a customer subscribe to the Company's
Lifeline service offering?
REQUEST NO. 14: Please describe the Company's customer complaint process,
beginning with how a customer may complain and ending with how complaints are resolved.
Include a description of all the categories or types of customer complaints that the Company
tracks in the company's response.
REQUEST NO. 15: Please explain the Company's customer service and compliance
training process.
REQUEST NO. 16: Does the Company utilize an Interactive Voice Response
automated system that lists all menu options available to the customer? If yes, please
explain how a customer can request de-enrollment or report their phone as lost, stolen, or
defective.
REQUEST NO. 17: Please identify the locations,business days, and hours of call
centers that the Company uses to serve its customers.
FIRST PRODUCTION REQUEST
TO ZIPLY PACIFIC 4 NOVEMBER 12, 2024

REQUEST NO. 18: For the past twelve (12) months,please provide call center
system-generated documentation that shows the following:
a. Average wait time for a customer to reach a service representative on the phone for
each call center that will be used to serve customers in Idaho;
b. Average handling time for inbound calls;
c. Abandoned rate for inbound calls;
d. Average speed of answer; and
e. Average email response time.
REQUEST NO. 19: Please identify all means by which a customer can submit a Lifeline
application to the Company.
REQUEST NO. 20: Please describe the process by which an Idaho Lifeline
customer brings or purchases their own compatible handset for use with the Company's
Lifeline service. In the company's response, please answer the following:
a. Please describe all methods available to the customer to verify the handset's
compatibility with the company's Lifeline service.
b. Please describe any and all limitations of the company's"bring your phone"
program.
c. Of all Lifeline customers that the Company serves, what percentage
brought their own phone as opposed to those who bought a phone from the
Company?
d. Indicate whether the Parent Company employs a different process.
REQUEST NO. 21: Does the Company use automated calls with a recorded message,
for any Lifeline-related purpose? If so, please explain the purpose for which such calls are used
and provide details on each instance within the past year when such calls were placed to
customers or potential customers.
REQUEST NO. 22: Does the Company use live representatives for customer web
chats?If not,please describe the Company's practice.
FIRST PRODUCTION REQUEST
TO ZIPLY PACIFIC 5 NOVEMBER 12, 2024

REQUEST NO. 23: Please provide a numerical forecast of Lifeline customers
that the Company anticipates serving during each month of its first year of operation in
Idaho.
REQUEST NO. 24: Please explain how the Company monitors and complies with
the FCC regulation governing customer usage. Please provide a sample Customer Data
Record report that the Company uses. Customer personal identifying information may be
redacted from the response.
REQUEST NO. 25: Please describe all of the Company's methods for contacting the
customer to determine if they are still using the Lifeline service in accordance with the FCC's
usage rules. In the company's response, please indicate:
a. Whether or not the Company tracks the number of customers who choose to
discontinue Lifeline service with the Company; and
b. Describe the process, if any,by which customers can opt out of receiving such
contact from the Company.
REQUEST NO. 26: Barring FCC action, the federal mobile broadband minimum
service standard for Lifeline may increase three-fold on December 1, 2025, to 12 gigabytes.
Please indicate whether the Company will be able to meet that minimum standard for its free
service offerings. If not, please provide the estimated cost the customer will incur to subscribe
to the Company's offerings as shown in Exhibit 4 of the Application and 12-gigabyte data plan.
REQUEST NO. 27: Please provide a list of the healthcare organizations or any
other organization with which the Company partners to promote the availability of Lifeline
service. Please indicate whether the Company has or intends to have any such partnerships
in Idaho.
FIRST PRODUCTION REQUEST
TO ZIPLY PACIFIC 6 NOVEMBER 12, 2024

REQUEST NO. 28: Please provide the following information regarding the Company
or its auditing process:
a. Provide narrative to elaborate on the Company's Death Master process;
b. Identify the entity from which the Company receives decedent data; and
c. Explain how often the Company applies the Death Master search to customer records.
REQUEST NO. 29: Please provide supporting documents demonstrating that the
Company can remain functional in emergency situations. For example: disaster recovery
contingency plans,backup power plans, and copies of contracts with other companies for
reliance on their support in case of emergency.
REQUEST NO. 30: Please provide the following:
a. A copy of the FCC Compliance Plan;
b. If you do not have one,please state why and provide supportive documents showing
that the Company does not need to comply with the "own-facilities" requirement
contained in Section 214(e)(1)(A) for carriers that are, or seek to become, Lifeline-
only; and
c. The supportive documents in Part b, which could be documents showing that the
Company owns the facilities it uses to provide the lifeline services.
REQUEST NO. 31: Please provide an organizational chart(s) for all four Ziply
companies, namely: Ziply Wireless, LLC; Ziply Fiber Northwest, LLC; Ziply Fiber of Idaho,
LLC; and Ziply Wireless, LLC.
a. Please specifically identify and show the leadership and how all four companies relate
to each other.
REQUEST NO. 32: Please provide documents and data that support the statements that
the Company provided in its Application,under item 8 on pages 4-5:
a. The planned investment and deployment in the State of Idaho;
b. How the promotion of economic growth will take place following Part a; and
FIRST PRODUCTION REQUEST
TO ZIPLY PACIFIC 7 NOVEMBER 12, 2024

c. Given the demise of the ACP, what are the additional supports that the Company will
provide to Idahoans that are not already being given?
DATED at Boise, Idaho, this 12th day of November, 2024.
Michael val
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\ZFP-T-24-02 PR#l.docx
FIRST PRODUCTION REQUEST
TO ZIPLY PACIFIC 8 NOVEMBER 12, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS ' DAY OF NOVEMBER 2024,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO ZIPLY FIBER PACIFIC, D/B/A ZIPLY FIBER, IN CASE NO. ZFP-T-24-
02, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
JESSICA EPLEY
ZIPLY FIBER PACIFIC LLC
135 LAKE ST S STE 155
KIRKLAND WA 98033
E-MAIL: jessica.gpley�ziply.com
PA RICIA JORDA , SECRETARY
CERTIFICATE OF SERVICE