20241202ZFP to Staff 1-32.pdf

Ziply Fiber •
135 Lake Street South,Suite 155, Kirkland,WA 98033 I
M.[phone] pi
[e-mail]
fiber
RECEIVED
Monday, December 2, 2024
December 2, 2024 IDAHO PUBLIC
UTILITIES COMMISSION
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: Case No. ZFP-T-24-02 First Production Request of the Commission Staff to Ziply Fiber
Pacific, LLC dba Ziply Fiber
Dear Ms. Barrios-Sanchez:
Please find Ziply Fiber Pacific, LLC dba Ziply Fiber's response to the First Production Request of
the Commission Staff.
If you have any questions regarding this filing, you may contact me at [phone].
Sincerely,
qqlt�
Jessica Epley
VP - Regulatory & External Affairs
zip y-
ziplyfiber.com fiber

I ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL
2 IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
3 BOISE, IDAHO 83720-0074
(208) 334- 0318
4 IDAHO BAR NO. 10221
5 Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
6 BOISE, ID 83714
7 Attorney for the Commission Staff
8 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
9
IN THE MATTER OF ZIPLY FIBER PACIFIC, )
10 LLC, D/B/A ZIPLY FIBER'S APPLICATION ) CASE NO. ZFP-T-24-02
FOR DESIGNATION AS AN ELIGIBLE )
11 TELECOMMUNICATIONS CARRIER IN ) RESPONSE TO FIRST
THE STATE OF IDAHO TO RECEIVE ) PRODUCTION REQUEST
12 FEDERAL LIFELIFE SUPPORT ) OF THE COMMISSION
STAFF TO ZIPLY FIBER
13 ) PACIFIC, LLC DBA ZIPLY
FIBER
14
15
REQUEST NO. 1: Please provide the Company's proposed designated
16 service area, i.e., a map or zip codes in an Excel spreadsheet along with the city
17 and county to which each zip code corresponds.
18 ANSWER: Ziply Fiber Pacific seeks a state-wide designation as an Eligible
19 Telecommunications Carrier in Idaho.
20
REQUEST NO.2: Please provide the following Eligible
21 Telecommunications carriers ("ETC") statuses:
22 a. The status of the Company's ETC Applications before the Federal
23 Communications Commission("FCC") and/or any other jurisdictions;
b. The ETC status of Ziply Fiber Northwest, LLC,parent company
24
RESPONSE TO FIRST PRODUCTION REQUEST - 1

I ("Parent"),before the FCC and/or any other jurisdictions;
2 c. The ETC status of Ziply Fiber of Idaho,LLC, sister company("Sister
1"),before the FCC and/or any other jurisdictions; and
3 d. The ETC status of Ziply Wireless, LLC, sister company("Sister 2"),
4 before the FCC and/or any other jurisdictions.
5 ANSWER: Ziply Fiber Pacific objects to this data request on the grounds
that the FCC does not normally or routinely grant ETC status to carriers,
6 states are charged with the process of granting ETC status to individual
7 carriers. Additionally, Ziply Fiber Pacific objects that this information is
8 publicly and equally available to staff on commission websites in Oregon,
Washington, and Montana. Finally, Ziply Fiber Pacific objects that the
9 information sought falls outside the jurisdiction of the Idaho Public Utilities
10 Commission and therefore is irrelevant and not calculated to lead to the
11 discovery of admissible evidence in this proceeding. Notwithstanding and
without waiving these objections, Ziply Fiber Pacific provides the following
12 data. As stated in paragraph 3 of the petition, state commissions generally
13 have the authority to designate a carrier as an ETC, and such designations
14 are not usually the province of the FCC. Our response below identifies our
ETC status with the appropriate state commissions. Please note that Ziply
15 Fiber Northwest, LLC is identified as an affiliate of Ziply Fiber Pacific in
16 paragraph 20 of the petition and is not the parent company of Ziply Fiber
17 Pacific.
Ziply Fiber Pacific has pending petitions for designation as an ETC in the
18 states of Idaho, Montana, Oregon and Washington.
19 Ziply Fiber Northwest is designated as an ETC in the states of Idaho, Oregon
20 and Washington.
Ziply Fiber of Idaho is designated as an ETC in Idaho.
21 Ziply Wireless is designated as an ETC in Washington and has pending
22 petitions for designation in the states of Idaho, Montana and Oregon.
23
24 REQUEST NO. 3: Has the Company,Parent, or Sister 1 been subjected to
RESPONSE TO FIRST PRODUCTION REQUEST - 2

I any FCC or Universal Service Administrative Company("USAC")audits? If yes,
2 please describe the nature of the audit, describe the current status, and provide a copy
of the resulting audit report for each audit.
3 ANSWER: No
4
5 REQUEST NO. 4: Please describe any pending investigations of the
6 Company,Parent,or Sister 1 by USAC,the FCC,or any state commission with
respect to a state or federal Lifeline program, of which the Company is aware.
7 Please describe the nature and status of the investigation in the Company's
8 response.
9 ANSWER: None
10
REQUEST NO. 5: Has the Company, Parent, or Sister 1 received any data
11 or information requests from the FCC related to the Lifeline program, including but
12 not limited to requests from the Office of Inspector General, Enforcement Bureau,
13 etc. If so,please identify the requestor, and provide a copy of the data or
information requests and any responses provided by the Company.
14 ANSWER: No
15
16 REQUEST NO. 6: Has the Company,Parent,or Sister 1 ever
returned,remitted, or repaid federal or state Lifeline funds that it had
17
received? If so,please identify each instance and the specific reasons for each
18 action.
19 ANSWER: No
20
REQUEST NO. 7: Please explain in detail how Wi-Fi secures data
21 transfers once a customer connects a phone with the Company,Parent, Sister
22 1,or Sister 2 to public Wi-Fi and provide any supporting documentation that
establishes the transfers are secure.
23
ANSWER: Ziply Fiber Pacific objects to this data request on the grounds
24
RESPONSE TO FIRST PRODUCTION REQUEST - 3

I that it demonstrates a fundamental misunderstanding of fixed wireless
2 technology and assumes that telephone sets that work with Ziply Fiber
Pacific technology are akin to mobile/cellular telephones and utilize public
3 Wi-Fi. Instead, Ziply Fiber Pacific telephone sets are in fixed locations in
4 the home/business and are not mobile. Notwithstanding and without
5 waiving these objections, Ziply Fiber Pacific provides the following data.
Ziply Fiber Pacific service is dependent on customer premise equipment
6 and will not operate outside the home/business where the service is
7 provided. Ziply Fiber Pacific does not sell or provide phones for fixed
8 wireless services.
9 REQUEST NO. 8: Please provide the following financial documents for
10 the Company or Parent:
11 a. FCC Form 499 filed in 2024, 2023, and 2022; and
b. Financial statements (including balance sheets, income statements,
12 and cash flow statements)for the last three years and accompanying
13 audit reports, if any.
14 ANSWER: Ziply Fiber Pacific objects to this data request on the grounds
that it requests confidential,proprietary, and competitively sensitive
15 information without a protective order form the Commission in place.
16 Ziply Fiber Pacific will respond with relevant information once a standard
17 protective order is in place in this proceeding.
18 REQUEST NO. 9: How many Lifeline and how many non-Lifeline
19 customers did the Company have nationally on October 31, 2024?
20 ANSWER: Ziply Fiber Pacific objects to this data request on the grounds that it
requests information on Ziply Fiber Pacific customers outside the Commission's
21 jurisdiction, and therefore is not reasonably designed to lead to relevant and admissible
22 evidence. Notwithstanding and without waiving that objection, Ziply Fiber Pacific
23 provides the following data.
24
RESPONSE TO FIRST PRODUCTION REQUEST - 4

I As of 10/31/2024 Ziply Fiber Pacific did not have any Federal Lifeline customers and
2 had 30,341 non-Federal Lifeline customers across its operating area of Idaho, Montana,
Oregon and Washington.
3
4 REQUEST NO. 10: Please describe the Company's plans to advertise the
5 availability of Lifeline services using media of general distribution to reach the
target low-income population in Idaho. In the Company's response:
6 a. Please specifically identify the types of general distribution media
7 that will be employed;
8 b. Please provide sample copies of marketing material the Company
either currently uses to advertise Lifeline or intends to use in Idaho,
9 including the specific products and the charges thereof; and
10 c. Please provide an estimate of the Company's budget for advertising that
11 targets the low-income population in Idaho for the first twelve months of
12 operation in the event the Company is designated in Idaho.
ANSWER: Upon designation as an ETC in Idaho, Ziply Fiber Pacific will launch an
13 email campaign to customers announcing participation in the Federal Lifeline program.
14 Federal Lifeline information is available on our website, though regular customer bill
15 messages and through our Customer Care and sales agents. Additionally, we conduct
annual tribal outreach within our service area describing Federal Lifeline benefits.
16
17
REQUEST NO. 11: In response to the coronavirus pandemic,how many
18 additional free voice minutes and free gigabytes of data did the Company offer to
19 Lifeline customers in each state where it has ETC designation? Please indicate the
20 date the additional minutes and data became available and, if no longer available,
the date that it was no longer available.
21 ANSWER: Ziply Fiber Pacific objects to this data request on the grounds
22 that it assumes incorrect facts and demonstrates a misunderstanding of how
23 fixed wireless services are provided and incorrectly assumes that fixed
wireless services are sold and invoiced with per-minute charges and come
24
RESPONSE TO FIRST PRODUCTION REQUEST - 5

I with data limits/caps similar to mobile phone offerings. Notwithstanding
2 and without waiving these objections, Ziply Fiber Pacific provides the
following data. Ziply Fiber Pacific offers voice service through Voice over
3 Internet Protocol and does not provide mobile telephone services.
4
5 REQUEST NO. 12: Please provide a detailed narrative with
supporting data and other available sources to support the Company's statement
6 on page 5 of its application for designation as an ETC that the Company offers
7 "high-quality services."
8 ANSWER: Ziply Fiber Pacific will provide the supported services both through Ziply
Fiber Pacific owned and operated fiber-optic infrastructure XGS-PON (50 Gigabit
9 Symmetrical Passive Optical Network) and"last-mile" equipment representing the
10 latest in fixed wireless telecommunications technology. In addition, Ziply Fiber Pacific
11 provides voice service through two carrier grade Class 5 integrated soft switches
capable of delivering supported services in a single site deployment for up to 100,000
12 subscribers operated by its affiliate, Ziply Fiber Northwest. These switches are rated to
13 provide 99.999%uptime delivering reliability and redundancy which will ensure high
14 quality service to the company's customers. These switches also allow for easy repairs
and upgrades.
15
16 REQUEST NO. 13: How long,on average,does a customer subscribe to the
17 Company's Lifeline service offering?
ANSWER: Ziply Fiber Pacific objects to this data request on the grounds
18 that to answer it would require a special study or analysis because it
19 requests data that does not currently reside in a Ziply Fiber Pacific system
20 of records, and because the data requested is not required to be tracked or
reported by Commission rule. Notwithstanding and without waiving these
21 objections, Ziply Fiber Pacific provides the following data. Ziply Fiber
22 Pacific does not track this data and has no responsive records.
23
REQUEST NO. 14: Please describe the Company's customer complaint
24
RESPONSE TO FIRST PRODUCTION REQUEST - 6

I process, beginning with how a customer may complain and ending with how
2 complaints are resolved. Include a description of all the categories or types of
customer complaints that the Company tracks in the Company's response.
3 ANSWER: Customers can notify Ziply Fiber Pacific of a complaint through an online
4 chat or by placing a phone call to customer service. Agents will attempt to resolve the
5 issue or will forward the information to the appropriate group to take action via a
trouble ticket. Issues and complaints brought up to customer service representatives are
6 recorded in customer account notes.
7
8 REQUEST NO. 15: Please explain the Company's customer service and
compliance training process.
9 ANSWER: Ziply Fiber Pacific provides the highest level of customer
10 service training in our call centers by requiring all new agents to undergo
11 and complete a rigorous training program. After they complete training,
agents work directly with the Ziply Fiber Pacific coaching and training
12 team for an additional two weeks to ensure they perform as outlined in
13 training. Prior to handling customer inquiries/calls, each agent is certified
14 by our quality assurance and training teams to ensure they meet our quality
and technical standards. Our compliance training is coordinated with and
15 reviewed by our legal and regulatory team to ensure customer and payment
16 information is being handled in accordance with CPNI requirements.
17
REQUEST NO. 16: Does the Company utilize an Interactive Voice
18 Response automated system that lists all menu options available to the
19 customer? If yes,please explain how a customer can request de-enrollment or
20 report their phone as lost, stolen, or defective.
ANSWER: Ziply Fiber Pacific uses an Interactive Voice Response automated system to
21 list menu options. A customer merely needs to select any option to speak to an agent to
22 request de-enrollment from the Federal Lifeline program. Ziply Fiber Pacific provides
23 voice and data service, it does not sell or provide phones. Customers would not report
phones as lost, stolen or defective to Ziply Fiber Pacific.
24
RESPONSE TO FIRST PRODUCTION REQUEST - 7

I
REQUEST NO. 17: Please identify the locations,business days, and hours
2 of call centers that the Company uses to serve its customers.
3
4 ANSWER:
IBEX (South Carolina and the Philippines): Monday through Friday Sam- 7pm PST,
5 Saturday/Sunday Sam - 6pm PST; Technical support is available 24 hours a day, 7 days
6 a week; Payment and Collections teams are available Monday through Friday Sam-
7 5pm PST, closed weekends
Foundever(Philippines): Monday through Friday Sam - 7pm PST, Saturday Sam- 6pm
8 PST
9 Ziply Fiber(Everett): Monday through Friday Sam - 6pm PST, closed weekends
10
11
REQUEST NO. 18: For the past twelve(12)months,please provide
12 call center system-generated documentation that shows the following:
13 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
14
Idaho;
15 b. Average handling time for inbound calls;
16 c. Abandoned rate for inbound calls;
d. Average speed of answer; and
17
e. Average email response time.
18
ANSWER: Ziply Fiber Pacific objects to this data request to the extent
19 that it does not and/or is not required to track these metrics by Commission
20 rule, and that to provide the requested data would require a special study or
analysis. Notwithstanding and without waiving these objections, Ziply
21
Fiber Pacific provides the following data. Ziply Fiber Pacific does not
22 have call information specific to Ziply Fiber Pacific customers in Idaho.
23 The average handling time over the last 12 months for inbound calls across
Idaho, Oregon, Montana and Washington from all Ziply companies is 9:26.
24
RESPONSE TO FIRST PRODUCTION REQUEST - 8

I The average abandon rate over the last 12 months for inbound calls across
2 Idaho, Oregon, Montana and Washington from all Ziply companies is
3.9%.
3
4
REQUEST NO. 19: Please identify all means by which a customer can submit a
5 Lifeline application to the Company.
6
7 Ziply Fiber Pacific customer submit Federal Lifeline applications to through the
National Verifier. Ziply Fiber Pacific does not accept applications for the Federal
8 Lifeline program directly from customers in accordance with program rules.
9
10 REQUEST NO. 20: Please describe the process by which an
Idaho Lifeline customer brings or purchases their own compatible handset
11 for use with the Company's Lifeline service. In the Company's response,
12 please answer the following:
13 a. Please describe all methods available to the customer to verify
the handset's compatibility with the Company's Lifeline
14
service.
15 b. Please describe any and all limitations of the Company's
16 "bring your phone"program.
c. Of all Lifeline customers that the Company serves, what
17 percentage brought their own phone as opposed to those who
18 bought a phone from the Company?
19 d. Indicate whether the Parent Company employs a different process.
20 ANSWER: Ziply Fiber Pacific objects to this data request to the extent it
21 reflects misunderstandings regarding the Company's fixed wireless service
and presumes that the service includes a mobile component.
22 Notwithstanding and without waiving that objection, Ziply Fiber Pacific
23 provides the following data. Ziply Fiber Pacific does not sell or offer
24 handsets or phones for use with our voice products and does not have a
RESPONSE TO FIRST PRODUCTION REQUEST - 9

I "bring your phone"program. Additionally, Ziply Fiber Pacific only offers
2 Voice over Internet Protocol and does not have an obligation to ensure
phone set compatibility with our product.
3
4 REQUEST NO. 21: Does the Company use automated calls with a recorded
5 message, for any Lifeline-related purpose? If so,please explain the purpose for which
6 such calls are used and provide details on each instance within the past year when
such calls were placed to customers or potential customers.
7 ANSWER: No
8
9 REQUEST NO. 22: Does the Company use live representatives for
customer web chats? If not,please describe the Company's practice.
10 ANSWER: Yes
11
12 REQUEST NO.23: Please provide a numerical forecast of Lifeline
13 customers that the Company anticipates serving during each month of its first
year of operation in Idaho.
14
ANSWER: Ziply Fiber Pacific objects to this data request to the extent it
15 presumes any requirement for the Company to track or forecast the
16 requested data. Notwithstanding and without waiving that objection, Ziply
Fiber Pacific provides the following data. Ziply Fiber Pacific does not track
17
or forecast this information.
18
19 REQUEST NO. 24: Please explain how the Company monitors and
complies with the FCC regulation governing customer usage. Please provide a
20
sample Customer Data Record report that the Company uses. Customer
21 personal identifying information may be redacted from the response.
22 ANSWER: Ziply Fiber Pacific objects to this data request to the extent it
reflects misunderstandings regarding the Company's fixed wireless service
23
and presumes that the service includes a mobile component.
24
RESPONSE TO FIRST PRODUCTION REQUEST - 10

I Notwithstanding and without waiving that objection, Ziply Fiber Pacific
2 provides the following data. Ziply Fiber Pacific has no plans that do not
require a subscriber contribution. Federal Lifeline customers subscribing
3 to any of the Ziply Fiber Pacific plans will not be subject to the FCC's
4 usage rules.
5
REQUEST NO. 25: Please describe all of the Company's methods for
6 contacting the customer to determine if they are still using the Lifeline service in
7 accordance with the FCC's usage rules. In the Company's response, please
8 indicate:
a. Whether or not the Company tracks the number of customers
9 who choose to discontinue Lifeline service with the Company;
p Y;
10 and
11 b. Describe the process, if any,by which customers can opt out of
receiving such contact from the Company.
12
ANSWER: Ziply Fiber Pacific objects to this data request to the extent it
13 reflects misunderstandings regarding the Company's fixed wireless service
14 and presumes that the service includes a mobile component.
15 Notwithstanding and without waiving that objection, Ziply Fiber Pacific
provides the following data. Ziply Fiber Pacific has no plans that do not
16 require a subscriber contribution. Federal Lifeline customers subscribing to
17 any of the Ziply Fiber Pacific plans will not be subject to the FCC's usage
18 rules.
19 REQUEST NO. 26: Barring FCC action,the federal mobile broadband
20 minimum service standard for Lifeline may increase three-fold on December 1,
21 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
22 estimated cost the customer will incur to subscribe to the Company's offerings as
23 shown in Exhibit 4 of the Application and 12-gigabyte data plan.
24 ANSWER: Ziply Fiber Pacific objects to this data request to the extent it
RESPONSE TO FIRST PRODUCTION REQUEST - 11

I reflects misunderstandings regarding the Company's service and presumes
2 that the service includes a mobile component. Notwithstanding and
without waiving that objection, Ziply Fiber Pacific provides the following
3 data. Ziply Fiber Pacific does not offer mobile broadband. Pricing for each of the
4 plans offered by the company may vary by address. Pricing and service plan
5 details can be found on www.zipllyfiber.com by searching for a specific address.
6 REQUEST NO. 27: Please provide a list of the healthcare
7 organizations or any other organization with which the Company partners to
promote the availability of Lifeline service. Please indicate whether the
8 Company has or intends to have any such partnerships in Idaho.
9 ANSWER: Currently Ziply Fiber Pacific does not have any partnerships
10 with outside organizations to promote the availability of the Lifeline program.
11
REQUEST NO. 28: Please provide the following information regarding the
12
Company's auditing process:
13 a. Provide narrative to elaborate on the Company's Death Master process;
14 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
15 records.
16 ANSWER: Ziply Fiber Pacific objects to this data request to the extent it
17 reflects misunderstandings regarding the Company's fixed wireless service
and presumes that the service includes a mobile component.
18
Notwithstanding and without waiving that objection, Ziply Fiber Pacific
19 provides the following data. Ziply Fiber Pacific uses the National Lifeline
20 Accountability Database exclusively to determine a customer's eligibility
status for the Lifeline program.
21
22
REQUEST NO.29: Please provide supporting documents demonstrating
23
that the Company can remain functional in emergency situations. For example:
24
RESPONSE TO FIRST PRODUCTION REQUEST - 12

I disaster recovery contingency plans,backup power plans, and copies of contracts
2 with other companies for reliance on their support in case of emergency.
3 ANSWER: Ziply Fiber Pacific' internal standard for backup power is a
minimum of 48 hours of critical power system supply for central offices and
4 remote terminals with onsite generators. All of our central office locations
5 host onsite generators with either underground fuel tanks or above ground
6 concrete encased fuel tanks. The standard fuel capacity across our footprint
is five days. In remote terminal locations where we do not have a generator
7 onsite, we have strategically staged generators on trailers that can be
g deployed in under four hours. We maintain a supply of trailer mounted
9 generators at several locations throughout our operating area which can be
expeditiously deployed when necessary due to commercial power outages.
10
Ziply Fiber Pacific also takes measures to provide reliable service through
11 the following:
12 (1) Circuit auditing
• Ziply Fiber Pacific conducts quarterly reviews of PSAPS diversity, semiannual
13
reviews of end offices diversity, and at installation or modification of any E911
14 circuit.
15 • Ziply Fiber Pacific tags all circuits in our internal tracking software.
16 • Ziply Fiber Pacific continues to work to resolve areas where we are single
homed with no diversity.
17
18 (2) Backup power:
•19 All Ziply Central Offices hosting a Selective Router or directly serving a PSAP,
provide for emergency power distribution via direct current battery strings sized
20 at minimum to hold for PUC defined time in Amp hours. The DC power
21 rectification systems are supported by on-site generators that are started
22 automatically upon voltage drop detection and load is transferred once generator
is operating. Most sites maintain on-site reserves to run for 72 hours prior to
23 refueling. Sites that do not have stationary generators are provided trailer
24 mounted portable generators and fuel to run for a minimum of 24 hours.
RESPONSE TO FIRST PRODUCTION REQUEST - 13

1 • Many of our locations are serviced and maintained by vendors.
2 • Local Central Office Technicians do the monthly and weekly tests.
• Local Central Office Technicians also do a monthly Planned Maintenance
3
Program of the generator which includes a run and functional check of the ATS.
4 These are documented and logged electronically in the PMP system.
5 • The generators and transfer switches are maintained every 18 months except the
6 mountain tops which are done on a yearly basis. There is a generator PM log
kept either in the control panel (portable generators) or in the ATS's (stationary
7 units).
g • All Ziply Central Offices hosting a Selective Router or directly serving a PSAP,
9 that have a stationary generator are controlled via an automatic transfer switch
as well as a roll up "pin& sleeve" connection and manual transfer switch as well
10 to accommodate a secondary trailer mounted roll up generator if needed.
11 • All multi-gen configurations are either designed for use via manual tie breaker
12 or paralleling systems that start generators independently and phase balance
before load transfer.
13
14 (3)Network monitoring:
15
• Daily reporting on all aggregation devices carrying E911 circuits that exhibit
issues or stop reporting through our third-party network monitoring vendor
16 (IBM Netcool)
17 • Monitoring links will report as down notifications are sent to a separate third-
18 party monitoring vendor(TruSight) for triage and repair
• Where we have diversity, 24/7 monitoring is managed by the Ziply Fiber
19
Network Operation Center
20 • As diverse circuits are added, monitoring is transitioned to the Ziply Fiber
21 Network Operations Center
22 This information is certified annually through the FCC's E911 Network
Reliability Certification.
23
24
RESPONSE TO FIRST PRODUCTION REQUEST - 14

I
REQUEST NO. 30: Please provide the following:
2 a. A copy of the FCC Compliance Plan;
3 b. If you do not have one,please state why and provide supportive
4 documents showing that the Company does not need to comply with the
"own-facilities" requirement contained in Section 214(e)(1)(A) for
5 carriers that are, or seek to become, Lifeline- only; and
6 c. The supportive documents in Part b,which could be documents
7 showing that the Company owns the facilities it uses to provide the
lifeline services.
8 ANSWER: Ziply Fiber Pacific objects to this data request on the grounds
9 that it presumes that the Company is required to maintain the referenced
10 Compliance Plan. Notwithstanding and without waiving that objection,
Ziply Fiber Pacific provides the following data. As stated in paragraphs 13
11 and 16 of the application, Ziply Fiber Pacific offers services through
12 facilities owned and operated by itself or its affiliates. Since Ziply Fiber
13 Pacific complies with the "own-facilities"requirement, an FCC compliance
plan is not required.
14
15
16 REQUEST NO. 31: Please provide an organizational chart(s) for all four
Ziply companies,namely: Ziply Fiber Pacific, LLC; Ziply Fiber Northwest,LLC;
17 Ziply Fiber of Idaho, LLC; and Ziply Fiber Pacific, LLC.
18 a. Please specifically identify and show the leadership and how all four
19 companies relate to each other.
20 ANSWER:A complete organizational chart is attached. Ziply Fiber Pacific,
LLC; Ziply Fiber Northwest, LLC; Ziply Fiber of Idaho, LLC and Ziply
21 Fiber Pacific, LLC are all affiliate companies. The leadership for all Ziply
22 Fiber companies is detailed in Exhibit 3 of the application.
23
24
RESPONSE TO FIRST PRODUCTION REQUEST - 15

I REQUEST NO.32: Please provide documents and data that support the
2 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;
3 b. How the promotion of economic growth will take place following Part a; and
4 c. Given the demise of the ACP,what are additional supports that the
5 Company will provide to Idahoans that are not already being given?
ANSWER: Ziply Fiber Pacific objects to this data request to the extent that
6 it presumes that the Company is required to have a finalized plan for
7 investment and deployment in Idaho,and to the extent it requires speculation
8 about future plans and investments which are dependent on a variety of
factors, including factors yet to be known including the amount and timing
9
of federal and state grants and support programs. Ziply Fiber Pacific also
10 objects to the assumption that it is or may be required to provide unspecified
11 "additional supports" now that ACP has ended, or that such ambiguous
support is required to designate the Company as an ETC. Notwithstanding
12
and without waiving those objections, Ziply Fiber Pacific provides the
13 following data. Ziply Fiber Pacific is in the planning stages of increasing
14 the footprint of its network and will only finalize its investment and
deployment planning when the commission grants ETC designation. Ziply
15 Fiber Pacific' planned investment and deployment in the state of Idaho will
16 further the goals of the Commission and the FCC by expanding the
17 reach of digital connectivity to promote economic growth in rural areas and
ensure quality communications services are available at competitive rates.
18
Designation of competitive ETCs promotes competition and benefits
19 consumers by increasing customer choice, innovative services, and new
20 technologies.
21
22
23
24
RESPONSE TO FIRST PRODUCTION REQUEST - 16

I Respectfully submitted on this 2nd day of December 2024.
2
3
4
Jessica Epley
5 VP—Regulatory& External Affairs
135 Lake Steet South, Suite 155
6 Kirkland, WA 98033
503.431.0458
7 [e-mail]
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RESPONSE TO FIRST PRODUCTION REQUEST - 17