20250219Staff 33-35 to ZFP.pdf

RECEIVED
Wednesday, February 19, 2025 10:33:24 AM
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 ) SECOND PRODUCTION
CARRIER IN THE STATE OF IDAHO TO ) REQUEST OF THE
RECEIVE FEDERAL LIFELINE SUPPORT ) COMMISSION STAFF
TO ZIPLY FIBER PACIFIC
LLC,DB/A ZIPLY FIBER
Staff of the Idaho Public Utilities Commission("Staff'),by and through its attorney of
record, Michael Duval, Deputy Attorney General, requests that Ziply Fiber Pacific, LLC, DB/A
Ziply Fiber("Company")provide the following documents and information as soon as possible,
but no later than WEDNESDAY,MARCH 12, 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 FIBER PACIFIC 1 FEBRUARY 19, 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: Regarding the Company's response to Request No. 10 to Staffs
Production Request No. 1, please provide:
a. A sample copy of the marketing material that the Company intends to use to
advertise Lifeline—including the specific products.
REQUEST NO. 34: Regarding the Company's response to Request No. 29 to Staffs
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 Public Safety
Answering Points 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 Federal Communications
Commission.
REQUEST NO. 35: Regarding the Company's response to Request No. 30 to Staffs
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 19th day of February 2025.
l
Michael Duval
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\ZFP-T-24-02 PR#2.docx
SECOND PRODUCTION REQUEST
TO ZIPLY FIBER PACIFIC 2 FEBRUARY 19, 2025

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS �DAY OF FEBRUARY 2025,
SERVED THE FOREGOING SECOND 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.epleygzipl .com
bix
PA RICIA JORDA , SECRETARY
CERTIFICATE OF SERVICE