20250213Staff 33-35 to ZWL.pdf

RECEIVED
Thursday, February 13, 2025 12:58.55 PM
IDAHO PUBLIC
UTILITIES COMMISSION
ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10221
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 WIRELESS, )
LLC,DB/A ZIPLY FIBER'S APPLICATION ) CASE NO. ZWL-T-24-02
FOR DESIGNATION AS AN ELIGIBLE )
TELECOMMUNICATIONS CARRIER IN ) SECOND PRODUCTION
THE STATE OF IDAHO TO RECEIVE ) REQUEST OF THE
FEDERAL LIFELINE SUPPORT ) COMMISSION STAFF
TO ZIPLY WIRELESS, LLC,
DB/A ZIPLY FIBER
Staff of the Idaho Public Utilities Commission ("Staff'), by and through its attorney of
record, Adam Triplett, Deputy Attorney General, requests that Ziply Wireless, LLC, D/B/A
Ziply Fiber("Company") provide the following documents and information as soon as possible,
but no later than THURSDAY,MARCH 6, 2025.
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.
SECOND PRODUCTION REQUEST
TO ZIPLY WIRELESS 1 FEBRUARY 13, 2025

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. 33: Further to the Company's response to Request No. 10 to Staff s
Production Request No. 1, please provide:
a. A sample copy of the marketing material the Company intends to use to advertise
Lifeline, including the specific products.
REQUEST NO. 34: Further to the Company's response to Request No. 29 of Staff s
Production Request No. 1, please provide the following supporting documents to demonstrate
that the Company can remain functional in emergencies:
a. For the circuit auditing, please provide a copy of a quarterly review of PSAPS
diversity that was conducted;
b. For the backup power, please provide any document supporting(fully or partially) the
explanation that was previously provided in Production Request No. 1, answer 29 (2);
and
c. For network monitoring, please provide a copy of the certified annual Network
Reliability Certification that was filed with the FCC.
REQUEST NO. 35: Further to the Company's response to Request No. 30 to Staff s
Production Request No. 1, please provide the following:
a. Supporting document(s) showing that the Company owns and operates the facilities it
uses to provide lifeline services or the Company facilities that are owned and
operated by the Company's affiliates.
DATED at Boise, Idaho, this 13th day of February 2025.
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Adam Triplett Ile
Deputy Attorney General
1:\Utility\UMISC\PRDREQ\ZWL-T-24-02 PR#2.docx
SECOND PRODUCTION REQUEST
TO ZIPLY WIRELESS 2 FEBRUARY 13, 2025

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS lb-AY OF FEBRUARY 2025,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ZIPLY WIRELESS, LLC, D/B/A/ZIPLY FIBER , IN CASE
NO. ZWL-T-24-02, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
JESSICA EPLEY
ZIPLY WIRELESS LLC dba ZIPLY FIBER
125 LAKE ST S STE 155
KIRKLAND WA 98033
E-MAIL: jessica.epleygziply.com
PATRICIA JORDA , SECRETARY
CERTIFICATE OF SERVICE