20250306ZWL to Staff 33-35.pdf

RECEIVED
March 6, 2025
Idaho Public
Utilities Commission
Ziply Fiber •
135 Lake Street South,Suite 155,Kirkland,WA 98033 I
M.[phone] 1:)l
[e-mail]
fiber
March 6, 2025
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 Second 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 Second Production Request of
the Commission Staff.
If you have any questions regarding this filing, you may contact me at [phone].
Sincerely,
qq4____
Jessica Epley
VP - Regulatory & External Affairs
Ziply
ziplyfiber.com

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,D/B/A ZIPLY FIBER'S APPLICATION ) CASE NO. ZWL-T-24-02
FOR DESIGNATION AS AN ELIGIBLE )
I I TELECOMMUNICATIONS CARRIER IN ) RESPONSE TO SECOND
THE STATE OF IDAHO TO RECEIVE ) PRODUCTION REQUEST
12 FEDERAL LIFELIFE SUPPORT ) OF THE COMMISSION
STAFF TO ZIPLY WIRELESS,
13 ) LLC,D/B/A ZIPLY FIBER
14
15
REQUEST NO.33: Regarding the Company's response to Request No.
16 10 to Staffs Production Request No. 1, please provide:
17 a. A sample copy of the marketing material that the Company
18 intends to use to advertise Lifeline-including the specific
19 products.
20 ANSWER: Please see Exhibit A and Exhibit B.
21 Bill Message:
22 Ziply Fiber is committed to helping qualified low-income individuals obtain discounted
23 phone or internet service under a government assistance program called Lifeline. Lifeline
24 provides a monthly non-transferable discount($9.25) on internet service or($5.25) on
RESPONSE TO SECOND PRODUCTION REQUEST - 1

I voice service. Lifeline is limited to one discount per household for qualified customers.
2 To receive the Lifeline discount each month, you must receive benefits from one of these
programs: Medicaid; Supplemental Security Income (SSI); Supplemental Nutrition
3 Assistance Program (SNAP) formerly Food Stamps;Federal Public Housing Assistance
4 (Section 8);VA Veterans Pension(Supplemental Income for Wartime Veterans); or VA
5 Survivors Pension. You may also qualify if your yearly household income is at or below
135% of the Federal Poverty Guidelines. Residents living on federally recognized Tribal
6 Lands who participate in one of the programs above or one of the following federal
7 assistance programs shall also qualify for an additional monthly credit of up to $25.00
8 with Enhanced Tribal Lifeline and up to $100.00 toward installation fees with Tribal
Link-Up Assistance: Bureau of Indian Affairs General Assistance; Tribally Administered
9 Temporary Assistance for Needy Families (Tribal TANF); Head Start (Income Based); o
10 Food Distribution Program on Indian Reservations (FDPIR). For more information or to
11 apply,please visit www.lifelinesupport.org or call the Universal Service Administration
Company at(800) 234-9473.
12
13 Link to website:
14 https:Hziplyfiber.com/resources/discount-pro rg am-types/low-income-assistance-
15
programs
16
17 Ziply Fiber does not offer any specific Lifeline plans. The Lifeline discount is available
18 on any available products.
19
20
21 REQUEST NO.34: Regarding the Company's response to Request No.29
22 to Staffs Production Request No. 1, please provide the following supporting
documents to demonstrate that the Company can remain functional in
23
emergencies:
24
RESPONSE TO SECOND PRODUCTION REQUEST - 2

I a. For the circuit auditing, please provide a copy of a quarterly review of
2 Public Safety Answering Points diversity that was conducted;
b. For the backup power, please provide any document supporting (fully or
3
partially) the explanation that was previously provided in Production
4 Request No. 1, answer 29 (2); and
5 c. For network monitoring,please provide a copy of the certified
6 annual Network Reliability Certification that was filed with the
Federal Communications Commission.
7
8 ANSWER: There are no records maintained for quarterly circuit auditing. Ziply Fiber is
9 not required to do the audit more often than annually for the purposes of the annual E911
Network Reliability report.
10
11 There is no documentation of our critical power supply other than what we provide to the
12 FCC, which is the narrative from the E911 Network Reliability Report. The report itself
is not a prepared document- it is provided via the FCC portal as answers to individual
13 questions, so we have no "report" to provide. Ziply Fiber provides the following
14 narrative (as previously provided) to clarify what we provide as far as Backup power:
15 • All Ziply Central Offices hosting a Selective Router or directly serving a PSAP,provide
for emergency power distribution via direct current battery strings sized at minimum to
16 hold for PUC defined time in Amp hours. The DC power rectification systems are
17 supported by on-site generators that are started automatically upon voltage drop detection
18 and load is transferred once generator is operating. Most sites maintain on-site reserves to
run for 72 hours prior to refueling. Sites that do not have stationary generators are
19 provided trailer mounted portable generators and fuel to run for a minimum of 24 hours.
20 • Many of our locations are serviced and maintained by vendors.
21 • Local Central Office Technicians do the monthly and weekly tests.
• Local Central Office Technicians also do a monthly Planned Maintenance Program of
22 the generator which includes a run and functional check of the ATS. These are
23 documented and logged electronically in the PMP system.
24
RESPONSE TO SECOND PRODUCTION REQUEST - 3

I • The generators and transfer switches are maintained every 18 months except the
2 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 units). • All Ziply
3 Central Offices hosting a Selective Router or directly serving a PSAP, that have a
4 stationary generator are controlled via an automatic transfer switch as well as a roll up
5 "pin& sleeve" connection and manual transfer switch as well to accommodate a
secondary trailer mounted roll up generator if needed.
6 • All multi-gen configurations are either designed for use via manual tie breaker or
7 paralleling systems that start generators independently and phase balance before load
8 transfer.
9 REQUEST NO. 35:
10 ANSWER: Ziply Fiber objects to Staff Data Request Number 35 on the
11 grounds that the Data Request is redundant, unduly repetitive and has been
previously answered four times in the course of this
12 proceeding. Notwithstanding and without waiving that objection, Ziply
13 Fiber states that its application for designation as an ETC in the State of
14 Idaho, signed by its Vice President, Regulatory &External Affairs, and
verified as true and correct by its General Counsel and Secretary, contains
15 the following language in paragraph 2: "ZF is a facilities based
16 competitive local exchange carrier with a fully constructed fiber-optic
17 network over which it currently offers a full suite of communications
services to customers in Idaho." Additionally, the application states in
18 Paragraph 13 that: "ZF certifies it offers the services that are supported by
19 the federal universal service support mechanisms in the state of Idaho using
20 its own facilities." Paragraph 16 of the application also states that: "Under
Section 214(e)(1)(A) of the Act, an ETC must offer the services supported
21 by federal universal service support mechanisms throughout its designated
22 service area `either using its own facilities or a combination of its own
facilities and resale of another carrier's services.' Facilities are the ETC' s
23
"own" if the ETC has exclusive right to use the facilities to provide the
24
RESPONSE TO SECOND PRODUCTION REQUEST - 4

I supported services or when service is provided by any affiliate within the
2 holding company structure. ZF certifies that it provides service through
facilities owned and operated by itself or its affiliates." Finally, Ziply
3 Fiber provided this earlier Response to Staff Data Request Number
4 30: "As stated in paragraphs 13 and 16 of the application, Ziply Fiber
5 offers services through facilities owned and operated by itself or its
affiliates. Since Ziply Fiber complies with the "own-facilities"
6 requirement, an FCC compliance plan is not required."In sum, Ziply Fiber
7 has submitted a formal pleading (application) to the Commission, verified
8 by an Officer of the Company, that recites in three places that the Company
will provide services via its own facilities, and has repeated that assertion
9 both in its response to Staff Data Request 30, also signed by its Vice
10 President—Regulatory &External Affairs, and again in this response to
11 Staff Data Request 35.
12
Respectfully submitted on this 6th day of March 2025.
13
14 �(4--
15
16 Jessica Epley
VP—Regulatory & External Affairs
17 135 Lake Steet South, Suite 155
Kirkland, WA 98033
18 503.431.0458
19 [e-mail]
20
21
22
23
24
RESPONSE TO SECOND PRODUCTION REQUEST - 5

Exhibit A
3/4/25, 12:58 PM lifeline.html
z py
I fi ber
You may qualify for discounts
Ziply Fiber is committed to helping you receive internet service at an
affordable price. We're excited to announce that in your area, we now
participate in the Lifeline Program which can lower the cost of your monthly
internet bill.
What is Lifeline?
Lifeline is a government assistance program offering a monthly discount of
$9.25 on internet service or $5.25 on phone service for eligible customers.
Those living on Tribal lands can receive an additional $25 discount each
month. Please note that Lifeline is limited to one discount per household
and is non-transferable from one person to another.
� w
Do I qualify? '
You may qualify for the Lifeline '
i
discount based on your income,
current enrollment in SNAP,
Medicaid, or other government
programs, or if you're a survivor.
Apply to find out if you qualify.
Apply now
file:///C:/Users/emb9953/AppData/Local/M icrosoft/windows/I NetCache/Content.Outlook/373SNYZQ/lifeline.html 1/2

3/4/25, 12:58 PM lifeline.html
Once you're approved, call us and we'll apply your Lifeline benefit to your
internet service. For questions or if you're already approved, call [insert
TFN]. We're here to help!
Thanks for choosing Ziply Fiber.
ziplyfiber
Need more help? Learn more at the help center.
Let's stay connected
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Exhibit B
•
Y
fiber
December 12, 2024
Ms. Jennifer Porter, Chair
Kootenai Tribe of Idaho
100 Circle Drive
Bonners Ferry, ID 83805
Honorable Chair Porter,
Ziply Fiber is the Incumbent Local Exchange Carrier(aka the telephone company)within the Kootenai
Reservation. We are reaching out to better understand the connectivity needs of Tribal communities
within our service areas across Idaho, Montana, Oregon, and Washington.
We are interested in collaborating to bring fiber optic infrastructure to Tribal facilities and residences. We
want to learn about each tribes rights-of-way processes, land use permitting, facilities siting,
environmental and cultural preservation review process, and business and licensing requirements.
Working together will help support the Tribes planning for growth and/or modernization.
Ziply Fiber is an Eligible Telecommunications Carrier(ETC), which enables us to provide access for
qualifying households to the Lifeline program administered by the Federal Communication Commission.
The Lifeline program provides qualifying households on Tribal lands with discounts of up to$34.25 per
month for local voice and broadband service. In addition, the Tribal Link Up program provides qualified
households up to $100 off the customary installation charges at the customer's household location. How
might we increase awareness amongst your membership about these programs?
On Reservation lands both tribal and non-tribal households can apply. Only households determined
eligible may enroll in the program. To determine eligibility and sign up, interested households can go to
https://www.lifelinesupport.org/additional-support-for-tribal-lands/or call 1.800.234.9473. Lifeline is non-
transferable and is limited to one discount per household.
To schedule a meeting, please contact our Local Partnership Manager/Tribal Liaison, Chris St Germaine
at 208-400-0602 or chris.stgermaine(a)zi ply.com or myself at [phone] or iessica.epley(a)ziply.com .
We look forward to developing a positive relationship that results in meaningful efforts to meet the
telecommunications needs of the Tribe and its communities.
Sincerely,
qq4___
Jessica Epley
VP- Regulatory and External Affairs
ziplyfiber.com