20250929Decision Memo.pdf

DECISION MEMORANDUM
TO: COMMISSIONER LODGE
COMMISSIONER HAMMOND
COMMISSIONER HARDIE
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL
FROM: JON KRUCK,COMMISSION STAFF MEMBER
JEFF LOLL, DEPUTY ATTORNEY GENERAL
DATE: SEPTEMBER 29, 2025
RE: IN THE MATTER OF FATBEAM HOLDINGS LLC's APPLICATION
FOR THE 2024 BROADBAND EQUIPMENT TAX CREDIT;
CASE NO.FZ4-T-25-01.
On July 23, 2025, Cable One, Inc. ("Company") applied to the Idaho Public Utilities
Commission ("Commission") for an order confirming that equipment the Company installed during
2024 is "qualified broadband equipment" under Idaho Code § 63-30291 (Income tax credit for
investment in broadband equipment) ("Application").
BACKGROUND
In 2001, House Bill 377 was enacted, authorizing income tax credit for the installation of
qualifying broadband infrastructure in Idaho. Idaho Code § 63- 3029B(3)(a)(ii). Idaho Code § 63-
30291 allows a taxpayer to receive an investment tax credit for eligible broadband equipment
installed during a calendar year.
Qualified broadband equipment is defined as equipment "capable of transmitting signals at a
rate of at least two hundred thousand (200,000) bits per second to a subscriber and at least one
hundred twenty-five thousand (125,000) bits per second from a subscriber." Idaho Code 63-
3029I(3)(b). If the equipment is installed by a telecommunications carrier, it must also be "necessary
to the provision of broadband services and an integral part of a broadband network." Idaho Code §
63- 30291(3)(b)(i). The equipment must be primarily used to provide services to subscribers in Idaho
to qualify for the credit. Idaho Code § 63-30291(3)(b)(vii).
To be eligible for the tax credit, the taxpayer must obtain from the Idaho Public Utilities
Commission ("Commission") an order confirming that the installed equipment meets the statutory
definition of qualified broadband equipment. Commission Order No. 35297 and Idaho Code § 63-
DECISION MEMORANDUM - I -

30291(4). Once the Commission has determined that the installed equipment is eligible for the
broadband equipment tax credit, an order along with the original Application is forwarded to the
Idaho Tax Commission.
THE APPLICATION
In the Application, the Company stated that all its customers in Idaho have access to
broadband services. Application at 3. The Company indicated that the broadband services offered
include a 100G backbone network' that feeds the broadband equipment throughout the state of Idaho
and customers via direct access fiber, fiber to the home, fixed microwave or broadband radio setups.
Id. The offerings include fixed wireless at speeds up to 3gbps symmetrical, wireless broadband
services with speeds from 5Mbps to 30Mbps download and up to 5Mbps upload and Fiber To The
Home (FTTH) with speeds up to 1Gbps symmetrical. Id.
The Company indicates that the equipment identified in its Broadband Equipment List,
attached to the Application,was necessary to the provision of broadband services and an integral
part of a broadband network. Id.
The Company reports investing $3,864,590.13 in qualifying broadband equipment in
2024,which resulted in a 3% broadband tax credit of$115,937.70. Id.
STAFF REVIEW AND RECOMMENDATION
Staff reviewed the list of proposed broadband equipment. Upon Staff s initial review of the
Application, Staff determined that one piece of equipment claimed as qualified equipment was not listed
in the manufacturer's online catalog. Staff sent a Production Request to clarify the correct equipment
number and to confirm the claimed equipment is primarily used to provide services to subscribers in Idaho.
The Company sent a response on September 8, 2025, that provided the manufacturer's data sheet for the
equipment in question and information confirming the equipment claimed in the Company's Application
is primarily used to service Idaho customers. Following the Company's clarification, Staff believe the
identified equipment qualifies for the investment tax credit pursuant to Commission Order No. 35297 and
Idaho Code § 63-30291(3)(b). Staff recommend that the Commission issue an order confirming that the
equipment is qualified broadband equipment and forward the approving order, along with a copy of the
original Application, to the Idaho Tax Commission.
'A backbone network is a high-speed central connection or network that serves as the main route for data transmission
between different networks or devices.It uses high-speed cables,routers, switches,and other hardware components to relay
data between its user's computers,supporting the transfer of data,voice,and video information in a large area or vast
geographic region.
DECISION MEMORANDUM -2 -

COMMISSION DECISION
Does the Commission wish to issue an order confirming the broadband equipment
identified in Case No. FZ4-T-25-01 is qualified broadband equipment as defined in Idaho Code
§ 63-30291(3)(b), and forward the order and Application to the Idaho Tax Commission?
Anything else?
Jon Kruck
Commission Staff
I:\Uti1ity\UDMEM0S\FZ4-T-25-01 Decision Memo.docx
DECISION MEMORANDUM - 3 -