20241202ZWL 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. ZWL-T-24-02 First Production Request of the Commission Staff to Ziply
Wireless, LLC dba Ziply Fiber
Dear Ms. Barrios-Sanchez:
Please find Ziply Wireless, 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 WIRELESS, )
10 LLC, DB/A ZIPLY FIBER'S APPLICATION ) CASE NO. ZWL-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 WIRELESS,
13 ) LLC, DB/A 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 Wireless seeks a state-wide designation as an Eligible Telecommunications
19 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 Fiber Pacific, LLC, sister company("Sister
4 2"),before the FCC and/or any other jurisdictions.
5 ANSWER: Ziply Wireless objects to this data request on the grounds that
the FCC does not normally or routinely grant ETC status to carriers, states
6 are charged with the process of granting ETC status to individual carriers.
7 Additionally, Ziply Wireless objects that this information is publicly and
8 equally available to staff on commission websites in Oregon, Washington,
and Montana. Finally, Ziply Wireless objects that the information sought
9 falls outside the jurisdiction of the Idaho Public Utilities Commission and
10 therefore is irrelevant and not calculated to lead to the discovery of
11 admissible evidence in this proceeding. Notwithstanding and without
waiving these objections, Ziply Wireless provides the following data. As
12 stated in paragraph 3 of the petition, state commissions generally have the
13 authority to designate a carrier as an ETC, and such designations are not
14 usually the province of the FCC. Our response below identifies our ETC
status with the appropriate state commissions. Please note that Ziply Fiber
15 Northwest, LLC is identified as an affiliate of Ziply Wireless in paragraph
16 20 of the petition and is not the parent company of Ziply Wireless.
17 Ziply Wireless is designated as an ETC in Washington and has pending
petitions for designation in the states of Idaho, Montana and Oregon.
18 Ziply Fiber Northwest is designated as an ETC in the states of Idaho, Oregon
19 and Washington.
20 Ziply Fiber of Idaho is designated as an ETC in Idaho.
Ziply Fiber Pacific has pending petitions for designation as an ETC in the
21 states of Idaho, Montana, Oregon and Washington.
22
23 REQUEST NO. 3: Has the Company,Parent, or Sister 1 been subjected to
24 any FCC or Universal Service Administrative Company("USAC") audits? If yes,
RESPONSE TO FIRST PRODUCTION REQUEST - 2

I please describe the nature of the audit, describe the current status, and provide a copy
2 of the resulting audit report for each audit.
ANSWER: No
3
4 REQUEST NO. 4: Please describe any pending investigations of the
5 Company,Parent,or Sister 1 by USAC,the FCC,or any state commission with
6 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
7
response.
8 ANSWER: None
9
10 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
11 not limited to requests from the Office of Inspector General, Enforcement Bureau,
12 etc. If so, please identify the requestor, and provide a copy of the data or
13 information requests and any responses provided by the Company.
ANSWER: No
14
15 REQUEST NO. 6: Has the Company,Parent,or Sister 1 ever
16 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
17
action.
18 ANSWER: No
19
REQUEST NO. 7: Please explain in detail how Wi-Fi secures data
20
transfers once a customer connects a phone with the Company,Parent, Sister
21 1, or Sister 2 to public Wi-Fi and provide any supporting documentation that
22 establishes the transfers are secure.
ANSWER: Ziply Wireless objects to this data request on the grounds that
23
it demonstrates a fundamental misunderstanding of fixed wireless
24
RESPONSE TO FIRST PRODUCTION REQUEST - 3

I technology and assumes that telephone sets that work with Ziply Wireless
2 technology are akin to mobile/cellular telephones and utilize public Wi-Fi.
Instead, Ziply Wireless telephone sets are in fixed locations in the
3 home/business and are not mobile. Notwithstanding and without waiving
4 these objections, Ziply Wireless provides the following data. Ziply
5 Wireless service is dependent on customer premise equipment and will not
operate outside the home/business where the service is provided. Ziply
6 Wireless does not sell or provide phones for fixed wireless services.
7
8 REQUEST NO. 8: Please provide the following financial documents for
the Company or Parent:
9 a. FCC Form 499 filed in 2024, 2023, and 2022; and
10 b. Financial statements (including balance sheets, income statements,
11 and cash flow statements) for the last three years and accompanying
audit reports, if any.
12 ANSWER: Ziply Wireless objects to this data request on the grounds that
13 it requests confidential,proprietary, and competitively sensitive
14 information without a protective order form the Commission in place.
Ziply Wireless will respond with relevant information once a standard
15 protective order is in place in this proceeding.
16
17 REQUEST NO. 9: How many Lifeline and how many non-Lifeline
customers did the Company have nationally on October 31, 2024?
18 ANSWER: Ziply Wireless objects to this data request on the grounds that it requests
19 information on Ziply Wireless customers outside the Commission's jurisdiction, and
20 therefore is not reasonably designed to lead to relevant and admissible evidence.
Notwithstanding and without waiving that objection, Ziply Wireless provides the
21 following data.
22 As of 10/31/2024 Ziply Wireless did not have any Federal Lifeline customers and had
23 5,002 non-Federal Lifeline customers across it's operating area of Idaho, Montana,
Oregon and Washington.
24
RESPONSE TO FIRST PRODUCTION REQUEST -4

1
2 REQUEST NO. 10: Please describe the Company's plans to advertise the
availability of Lifeline services using media of general distribution to reach the
3 target low-income population in Idaho. In the Company's response:
4 a. Please specifically identify the types of general distribution media
5 that will be employed;
b. Please provide sample copies of marketing material the Company
6 either currently uses to advertise Lifeline or intends to use in Idaho,
7 including the specific products and the charges thereof; and
g c. Please provide an estimate of the Company's budget for advertising that
9 targets the low-income population in Idaho for the first twelve months of
operation in the event the Company is designated in Idaho.
10 ANSWER: Upon designation as an ETC in Idaho, Ziply Wireless will launch an email
11 campaign to customers announcing participation in the Federal Lifeline program.
12 Federal Lifeline information is available on our website, though regular customer bill
messages and through our Customer Care and sales agents. Additionally, we conduct
13 annual tribal outreach within our service area describing Federal Lifeline benefits.
14
15 REQUEST NO. 11: In response to the coronavirus pandemic,how many
16 additional free voice minutes and free gigabytes of data did the Company offer to
17 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,
18 the date that it was no longer available.
19 ANSWER: Ziply Wireless objects to this data request on the grounds that
20 it assumes incorrect facts and demonstrates a misunderstanding of how
fixed wireless services are provided and incorrectly assumes that fixed
21 wireless services are sold and invoiced with per-minute charges and come
22 with data limits/caps similar to mobile phone offerings. Notwithstanding
23 and without waiving these objections, Ziply Wireless provides the
following data. Ziply Wireless offers voice service through Voice over
24
RESPONSE TO FIRST PRODUCTION REQUEST - 5

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

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

1
2 ANSWER:
IBEX (South Carolina and the Philippines): Monday through Friday Sam- 7pm PST,
3 Saturday/Sunday Sam - 6pm PST; Technical support is available 24 hours a day, 7 days
4 a week; Payment and Collections teams are available Monday through Friday Sam-
5 5pm PST, closed weekends
Foundever(Philippines): Monday through Friday Sam - 7pm PST, Saturday Sam - 6pm
6 PST
7 Ziply Fiber(Everett): Monday through Friday Sam - 6pm PST, closed weekends
8
9
REQUEST NO. 18: For the past twelve(12)months,please provide
10 call center system-generated documentation that shows the following:
11 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
12
Idaho;
13 b. Average handling time for inbound calls;
14 c. Abandoned rate for inbound calls;
d. Average speed of answer; and
15
e. Average email response time.
16
ANSWER: Ziply Wireless objects to this data request to the extent that it
17 does not and/or is not required to track these metrics by Commission rule,
18 and that to provide the requested data would require a special study or
analysis. Notwithstanding and without waiving these objections, Ziply
19
Wireless provides the following data. Ziply Wireless does not have call
20 information specific to Ziply Wireless customers in Idaho. The average
21 handling time over the last 12 months for inbound calls across Idaho,
Oregon, Montana and Washington from all Ziply companies is 9:26. The
22
average abandon rate over the last 12 months for inbound calls across
23 Idaho, Oregon, Montana and Washington from all Ziply companies is
24 3.9%.
RESPONSE TO FIRST PRODUCTION REQUEST - 8

1
2 REQUEST NO. 19: Please identify all means by which a customer can submit a
3 Lifeline application to the Company.
4
Ziply Wireless customer submit Federal Lifeline applications to through the National
5 Verifier. Ziply Wireless does not accept applications for the Federal Lifeline program
6 directly from customers in accordance with program rules.
7
REQUEST NO. 20: Please describe the process by which an
8 Idaho Lifeline customer brings or purchases their own compatible handset
9 for use with the Company's Lifeline service. In the Company's response,
10 please answer the following:
a. Please describe all methods available to the customer to verify
11 the handset's compatibility with the Company's Lifeline
12 service.
13 b. Please describe any and all limitations of the Company's
"bring your phone"program.
14 c. Of all Lifeline customers that the Company serves, what
15 percentage brought their own phone as opposed to those who
16 bought a phone from the Company?
d. Indicate whether the Parent Company employs a different process.
17
18 ANSWER: Ziply Wireless objects to this data request to the extent it
reflects misunderstandings regarding the Company's fixed wireless service
19 and presumes that the service includes a mobile component.
20 Notwithstanding and without waiving that objection, Ziply Wireless
21 provides the following data. Ziply Wireless does not sell or offer handsets
or phones for use with our voice products and does not have a"bring your
22 phone"program. Additionally, Ziply Wireless only offers Voice over
23 Internet Protocol and does not have an obligation to ensure phone set
24 compatibility with our product.
RESPONSE TO FIRST PRODUCTION REQUEST - 9

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

I
REQUEST NO. 25: Please describe all of the Company's methods for
2 contacting the customer to determine if they are still using the Lifeline service in
3 accordance with the FCC's usage rules. In the Company's response, please
4 indicate:
a. Whether or not the Company tracks the number of customers
5 who choose to discontinue Lifeline service with the Company;
p Y;
6 and
7 b. Describe the process, if any,by which customers can opt out of
receiving such contact from the Company.
8
ANSWER: Ziply Wireless objects to this data request to the extent it reflects
9 misunderstandings regarding the Company's fixed wireless service and
10 presumes that the service includes a mobile component. Notwithstanding
11 and without waiving that objection, Ziply Wireless provides the following
data. Ziply Wireless has no plans that do not require a subscriber
12 contribution. Federal Lifeline customers subscribing to any of the Ziply
13 Wireless plans will not be subject to the FCC's usage rules.
14
REQUEST NO. 26: Barring FCC action, the federal mobile broadband
15 minimum service standard for Lifeline may increase three-fold on December 1,
16 2025, to 12 gigabytes. Please indicate whether the Company will be able to meet
17 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
18 shown in Exhibit 4 of the Application and 12-gigabyte data plan.
19 ANSWER: Ziply Wireless objects to this data request to the extent it
20 reflects misunderstandings regarding the Company's fixed wireless service
and presumes that the service includes a mobile component.
21 Notwithstanding and without waiving that objection, Ziply Wireless
22 provides the following data. Ziply Wireless does not offer mobile broadband.
Additionally,there is no Exhibit 4 of the application.
23
24
RESPONSE TO FIRST PRODUCTION REQUEST - 11

I REQUEST NO. 27: Please provide a list of the healthcare
2 organizations or any other organization with which the Company partners to
promote the availability of Lifeline service. Please indicate whether the
3 Company has or intends to have any such partnerships in Idaho.
4 ANSWER: Currently Ziply Wireless does not have any partnerships with
5 outside organizations to promote the availability of the Lifeline program.
6
REQUEST NO. 28: Please provide the following information regarding the
7
Company's auditing process:
8 a. Provide narrative to elaborate on the Company's Death Master process;
9 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
10 records.
11 ANSWER: Ziply Wireless objects to this data request to the extent it
12 reflects misunderstandings regarding the Company's fixed wireless service
and presumes that the service includes a mobile component.
13
Notwithstanding and without waiving that objection, Ziply Wireless
14 provides the following data. Ziply Wireless uses the National Lifeline
15 Accountability Database exclusively to determine a customer's eligibility
status for the Lifeline program.
16
17
REQUEST NO. 29: Please provide supporting documents demonstrating
18
that the Company can remain functional in emergency situations. For example:
19 disaster recovery contingency plans, backup power plans, and copies of contracts
20 with other companies for reliance on their support in case of emergency.
21 ANSWER: Ziply Wireless' internal standard for backup power is a
minimum of 48 hours of critical power system supply for central offices and
22 remote terminals with onsite generators. All of our central office locations
23 host onsite generators with either underground fuel tanks or above ground
24 concrete encased fuel tanks. The standard fuel capacity across our footprint
RESPONSE TO FIRST PRODUCTION REQUEST - 12

I is five days. In remote terminal locations where we do not have a generator
2 onsite, we have strategically staged generators on trailers that can be
deployed in under four hours. We maintain a supply of trailer mounted
3 generators at several locations throughout our operating area which can be
4 expeditiously deployed when necessary due to commercial power outages.
5 Ziply Wireless also takes measures to provide reliable service through the
6 following:
(1) Circuit auditing
7 • Ziply Wireless conducts quarterly reviews of PSAPS diversity, semiannual
g reviews of end offices diversity, and at installation or modification of any E911
circuit.
9
• Ziply Wireless tags all circuits in our internal tracking software.
10 • Ziply Wireless continues to work to resolve areas where we are single homed
11 with no diversity.
12
(2) Backup power:
13 • All Ziply Central Offices hosting a Selective Router or directly serving a PSAP,
14 provide for emergency power distribution via direct current battery strings sized
15 at minimum to hold for PUC defined time in Amp hours. The DC power
rectification systems are supported by on-site generators that are started
16 automatically upon voltage drop detection and load is transferred once generator
17 is operating. Most sites maintain on-site reserves to run for 72 hours prior to
18 refueling. Sites that do not have stationary generators are provided trailer
mounted portable generators and fuel to run for a minimum of 24 hours.
19 • Many of our locations are serviced and maintained by vendors.
20 • Local Central Office Technicians do the monthly and weekly tests.
21 • Local Central Office Technicians also do a monthly Planned Maintenance
Program of the generator which includes a run and functional check of the ATS.
22
These are documented and logged electronically in the PMP system.
23 • The generators and transfer switches are maintained every 18 months except the
24 mountain tops which are done on a yearly basis. There is a generator PM log
RESPONSE TO FIRST PRODUCTION REQUEST - 13

I kept either in the control panel (portable generators) or in the ATS's(stationary
2 units).
• All Ziply Central Offices hosting a Selective Router or directly serving a PSAP,
3 that have a stationary generator are controlled via an automatic transfer switch
4 as well as a roll up "pin& sleeve" connection and manual transfer switch as well
5 to accommodate a secondary trailer mounted roll up generator if needed.
• All multi-gen configurations are either designed for use via manual tie breaker
6
or paralleling systems that start generators independently and phase balance
7 before load transfer.
8
(3) Network monitoring:
9
• Daily reporting on all aggregation devices carrying E911 circuits that exhibit
10 issues or stop reporting through our third-party network monitoring vendor
11 (IBM Netcool)
12
• Monitoring links will report as down notifications are sent to a separate third-
party monitoring vendor(TruSight) for triage and repair
13 • Where we have diversity, 24/7 monitoring is managed by the Ziply Fiber
14 Network Operation Center
15 • As diverse circuits are added, monitoring is transitioned to the Ziply Fiber
Network Operations Center
16
This information is certified annually through the FCC's E911 Network
17 Reliability Certification.
18
19
REQUEST NO. 30: Please provide the following:
20 a. A copy of the FCC Compliance Plan;
21 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
22
"own-facilities" requirement contained in Section 214(e)(1)(A) for
23 carriers that are, or seek to become, Lifeline- only; and
24 c. The supportive documents in Part b, which could be documents
RESPONSE TO FIRST PRODUCTION REQUEST - 14

I showing that the Company owns the facilities it uses to provide the
2 lifeline services.
ANSWER: Ziply Wireless objects to this data request on the grounds that
3 it presumes that the Company is required to maintain the referenced
4 Compliance Plan. Notwithstanding and without waiving that objection,
5 Ziply Wireless provides the following data. As stated in paragraphs 13 and
16 of the application, Ziply Wireless offers services through facilities
6 owned and operated by itself or its affiliates. Since Ziply Wireless
7 complies with the "own-facilities"requirement, an FCC compliance plan is
8 not required.
9
10 REQUEST NO. 31: Please provide an organizational chart(s) for all four
11 Ziply companies, namely: Ziply Wireless, LLC; Ziply Fiber Northwest, LLC; Ziply
Fiber of Idaho, LLC; and Ziply Fiber Pacific, LLC.
12 a. Please specifically identify and show the leadership and how all four
13 companies relate to each other.
14 ANSWER: A complete organizational chart is attached. Ziply Wireless,
15 LLC; Ziply Fiber Northwest, LLC; Ziply Fiber of Idaho, LLC and Ziply
Fiber Pacific, LLC are all affiliate companies. The leadership for all Ziply
16 Fiber companies is detailed in Exhibit 3 of the application.
17
18
REQUEST NO. 32: Please provide documents and data that support the
19 statements that the Company provided in its Application, under item 8 on pages 4-5:
20 a. The planned investment and deployment in the State of Idaho;
21 b. How the promotion of economic growth will take place following Part a; and
c. Given the demise of the ACP,what are additional supports that the
22 Company will provide to Idahoans that are not already being given?
23 ANSWER: Ziply Wireless objects to this data request to the extent that it
24 presumes that the Company is required to have a finalized plan for
RESPONSE TO FIRST PRODUCTION REQUEST - 15

I investment and deployment in Idaho,and to the extent it requires speculation
2 about future plans and investments which are dependent on a variety of
factors, including factors yet to be known including the amount and timing
3 of federal and state grants and support programs. Ziply Wireless also objects
4 to the assumption that it is or may be required to provide unspecified
5 "additional supports" now that ACP has ended, or that such ambiguous
support is required to designate the Company as an ETC. Notwithstanding
6 and without waiving those objections,Ziply Wireless provides the following
7 data. Ziply Wireless is in the planning stages of increasing the footprint of
8 its network and will only finalize its investment and deployment planning
when the commission grants ETC designation. Ziply Wireless' planned
9 investment and deployment in the state of Idaho will further the goals of
10 the Commission and the FCC by expanding the reach of digital
11 connectivity to promote economic growth in rural areas and ensure quality
communications services are available at competitive rates. Designation of
12 competitive ETCs promotes competition and benefits consumers by
13 increasing customer choice, innovative services, and new technologies.
14
Respectfully submitted on this 2nd day of December 2024.
15
16
qq4--
17
18
Jessica Epley
19 VP—Regulatory& External Affairs
135 Lake Steet South, Suite 155
20 Kirkland, WA 98033
503.431.0458
21 [e-mail]
22
23
24
RESPONSE TO FIRST PRODUCTION REQUEST - 16