20251017Application.pdf

Docusign Envelope ID: EF64CABE-6C77-4EA3-A2A6-73441A1E6D5A RECEIVED
OCTOBER 17, 2025
IDAHO PUBLIC
Public Sector Pension Investment Board UTILITIES COMMISSION
1250 Rene-Levesque Blvd. West, Suite 1400
Montr6al, Qu6bec H3B 5E9
T: +1 514.937.2772
www.investpsp.com
October 14, 2025
To Whom It May Concern
Re: Verification Letter for Network FiberCo, LLC, NFC Northwest, LLC and NFC Management,
LLC
This letter is provided in support of Network FiberCo, LLC ("Network FiberCo") and its ability to fund its
operations.
1. We hereby confirm that PSPIB Quadratic Blocker LLC, a wholly owned subsidiary of the Public
Sector Pension Investment Board ("PSP"), holds a 51% interest in Network FiberCo. PSP's most
recent annual report can be found at Investment performance reports I PSP Investments.
2. We confirm that NFC Northwest, LLC ("Northwest") is a wholly-owned subsidiary of NFC
Management, LLC ("Management')which, in turn, is a wholly-owned subsidiary of Network FiberCo.
3. We confirm that,it is the intention of PSP to ensure that Network FiberCo,Northwest and Management
at all times remain viable and going concerns and are able to meet their respective financial and regulatory
obligations as they become due.
4. We have entered into binding agreements with Northwest Fiber, LLC dba Ziply Fiber("Ziply Fiber")
to form and fund operations for Network FiberCo and its subsidiaries. With respect to these agreements, PSP
has agreed to a potential commitment in excess of US$1.5 billion over time to fund these activities.
5 We will also vote our interests in Network FiberCo to have it and its subsidiaries honor all
contractual and regulatory obligations.
6. Nothing expressly or implied in this letter is intended to create a legal obligation between us.
Sincerely,
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I
BEFORE THE PUBLIC UTILITY COMMISSION OF IDAHO
2
3 In the Matter of )
4 NFC NORTHWEST, LLC )
APPLICATION FOR CERTIFICATION)
5 -COMPETITIVE LOCAL EXCHANGE )
CARRIER )
6 )
7
I. Proposed Services.
8
The Applicant,NFC Northwest, LLC, ("Applicant") is an infrastructure-focused
9
telecommunications entity that builds, owns, and maintains fiber-optic network facilities from a
10
centralized point of presence throughout public rights-of-way and other authorized public areas
11
to network endpoints serving homes, businesses, community institutions, and anchor facilities.
12
NFC Northwest does not provide retail internet access service to end users. Rather, its role is the
13
long-term ownership and stewardship of the local fiber distribution and access network. Pursuant
14
to a strategic partnership, Ziply Fiber Pacific, LLC serves as the exclusive retail internet service
15
provider over NFC Northwest's facilities, owns and operates the single backhaul fiber
16
connecting the local point of presence to the broader internet, and is responsible for day-to-day
17
operations, maintenance, customer activation, billing, network monitoring, and emergency
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response. In practical terms, this arrangement ensures that the Applicant provides the underlying
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fiber transport infrastructure, while retail broadband services to residents and businesses are
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provided by Ziply Fiber Pacific using that infrastructure.
21
II. Geographic area and market to be served.
22
The Applicant intends to develop, own, and maintain fiber facilities within selected Idaho
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municipalities and unincorporated communities, subject to local permitting and right-of-way
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NFC NORTHWEST, LLC'S APPLICATION FOR CERTIFICATION - COMPETITIVE
LOCAL CARRIER EXCHANGE

I approvals. The network is designed to reach residential neighborhoods, multi-dwelling units,
2 small and medium-sized businesses, enterprise and public-sector locations, community
3 institutions, and critical infrastructure sites. The deployment approach is locality-specific, with
4 construction plans sequenced to align with municipal coordination and market demand. Within
5 each locality,NFC Northwest will construct the fiber distribution and access network from the
6 central point of presence out to premises and community endpoints; Ziply Fiber Pacific will
7 interconnect that local network to the internet via its separately owned backhaul facility and will
8 deliver retail broadband services across the NFC Northwest infrastructure.
9 III. Facilities-based status and resale activity.
10 The Applicant is a facilities-based provider with respect to the local fiber distribution and access
11 network located in public rights-of-way and other authorized public areas. The Applicant does
12 not provide retail services and does not act as a reseller of telecommunications or broadband
13 services to end users. Ziply Fiber Pacific, as the exclusive retail provider on the Applicant's
14 network, provides internet access services over the Applicant's facilities and owns the single
15 fiber backhaul linking the local point of presence to the wider internet.
16 IV. Plans to build facilities.
17 The Applicant's core business plan is to invest in, construct, own, and maintain fiber-to-the-
18 premises infrastructure and related passive facilities over a multi-year horizon. The Applicant
19 will: design the local fiber network; undertake civil construction and restoration in compliance
20 with municipal standards; place distribution and access fiber to serve homes,businesses, and
21 institutions; and ensure long-term reliability through asset stewardship, inspection, and
22 maintenance programs. The Applicant's facilities plan is predicated on durable, carrier-grade
23 infrastructure capable of supporting current and next-generation broadband services, with
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NFC NORTHWEST, LLC'S APPLICATION FOR CERTIFICATION - COMPETITIVE
LOCAL CARRIER EXCHANGE

I sufficient capacity and resiliency to meet long-term community needs. Ziply Fiber Pacific will
2 operate and maintain these facilities on the Applicant's behalf and provide the retail customer
3 interface.
4 V. Target markets and go-to-market approach.
5 The Applicant's infrastructure is intended to support retail broadband offerings that appeal to a
6 broad spectrum of users, including residential consumers seeking high-speed, symmetrical fiber
7 connectivity; small and medium-sized businesses requiring reliable access and service-level
8 assurances; enterprises and public-sector entities that need robust connectivity for mission-
9 critical applications; and community institutions such as schools, healthcare facilities, and public
10 safety agencies. Because the Applicant is not a retail provider, end-user marketing, sales, and
11 customer acquisition are handled by Ziply Fiber Pacific through its established channels,
12 including digital and field marketing, sales representatives, and customer service operations. This
13 single-provider retail approach over the Applicant's facilities ensures a unified customer
14 experience while the Applicant focuses on infrastructure quality and availability.
15 VI. Prior and current services in Idaho.
16 The Applicant is a newly formed infrastructure owner and does not have a prior history of
17 providing retail telecommunications services in Idaho. Retail broadband services delivered over
18 the Applicant's facilities will be provided by Ziply Fiber Pacific, which has an established
19 operational presence and brand recognition in Idaho and the broader Northwest region. Ziply
20 Fiber Pacific will be the municipality-facing operator for day-to-day activities related to
21 construction coordination, permitting, inspections, maintenance, and emergency response on the
22 Applicant's facilities.
23
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NFC NORTHWEST, LLC'S APPLICATION FOR CERTIFICATION - COMPETITIVE
LOCAL CARRIER EXCHANGE

I VII. Corporate family structure.
2 The Applicant,NFC Northwest, LLC, is a wholly owned subsidiary of NFC Management, LLC,
3 which is a wholly owned subsidiary of Network FiberCo, LLC, formed through a strategic
4 partnership between BCE Inc., through Northwest Fiber, LLC (dba Ziply Fiber), and the Public
5 Sector Pension Investment Board("PSP Investments"). Within this structure,Network FiberCo
6 provides the capital framework and governance for long-term fiber infrastructure investment,
7 while NFC Northwest serves as the operating subsidiary responsible for building, owning, and
8 maintaining the local fiber distribution and access network in authorized geographies. Ziply
9 Fiber Pacific, LLC is an operational partner to the Applicant: it owns the single backhaul fiber
10 connecting each local network to the broader internet; it is the exclusive retail internet service
11 provider on the Applicant's facilities; and it is engaged to operate and maintain the Applicant's
12 network facilities on the Applicant's behalf. This delineation preserves clear lines of ownership,
13 responsibility, and accountability: NFC Northwest as the owner of local fiber assets in public
14 areas, and Ziply Fiber Pacific as the day-to-day operator and exclusive retail service provider
15 interfacing with end users and municipal stakeholders.
16
In Idaho, the Applicant will act as a facilities-based owner of local fiber network infrastructure,
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constructing and maintaining distribution and access fiber to serve residential, business, and
18
institutional locations. Retail broadband services will be delivered exclusively by Ziply Fiber
19
Pacific over the Applicant's facilities, with Ziply Fiber Pacific also owning the single backhaul
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connection from the local point of presence to the internet and managing operations,
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maintenance, and customer-facing functions. The Applicant's deployment plan targets selected
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Idaho communities, subject to local approvals, with a focus on resilient, long-lived infrastructure
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that supports high-quality broadband services across residential, commercial, and public-sector
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NFC NORTHWEST, LLC'S APPLICATION FOR CERTIFICATION - COMPETITIVE
LOCAL CARRIER EXCHANGE

I markets. The Applicant has no prior retail operations in Idaho, while its operational partner,
2 Ziply Fiber Pacific,has an established presence in the state.
3
VIII. Name,Address, and Form of Business.
4
1. A short statement of the character of public service in which it may engage,
5
Answer: Telecommunications services
6
2. The entity's name (including any assumed business name) and the name of the
7
state in which it is incorporated, or organized,
8
Answer: NFC Northwest, LLC, a Delaware limited liability company
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3. The street address of the entity's principal, office and of its principal office in
10
Idaho, and email address (if available);
11
Answer:
12
135 Lake Street South, Suite 155
13
Kirkland, WA 98033
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4. A certified copy of the entity's articles of incorporation or certificate of
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organization if an LLC; and
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Answer: [x]
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S. The names, titles, and addresses of the entity's officers and directors if the entity
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is a corporation, or of at least one (1)governor if the entity is an LLC(i.e. a
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manager of a manager-managed LLC or a member of a member-managed LLC);
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Answer: Byron Springer Jr., Authorized Person
21
135 Lake Street South, Suite 155
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Kirkland, WA 98033
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6. Names and addresses of subsidiaries the entity owns or controls.
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NFC NORTHWEST, LLC'S APPLICATION FOR CERTIFICATION - COMPETITIVE
LOCAL CARRIER EXCHANGE

I Answer: N/A
2 IX. Service and Territory.
3 1. A description of customer classes and customer services that the applicant
4 proposes to offer to the public. The application shall indicate the date on which
5 the applicant proposes to begin construction or anticipates it will begin to provide
6 service in Idaho.
7 Answer: Residential, business and enterprise customers will be offered data
8 services/internet access.
9 2. A description sufficient to determine whether service to be offered in a particular
10 location and the names of incumbent local exchange corporations (ILECs) with
11 whom the proposed utility is likely to compete. The application shall also describe
12 the intended manner of service, e.g. resold services or facilities-based services;
13 and a general description of the property owned or controlled by its applicant.
14 Answer: Facilities-based services will be offered in selected Idaho municipalities
15 and unincorporated communities, subject to local permitting and right-of-way
16 approvals. Service area may encompass the ILEC services of all ILEC's in Idaho
17 primarily focusing on the ILEC service area of CenturyLink/Lumen. The
18 Applicant will hold legal title to the local fiber distribution and access network
19 that it constructs within Idaho public rights-of-way and other authorized public
20 areas. This ownership encompasses feeder, distribution, and access fiber cables;
21 associated passive network elements such as handholes, vaults, cabinets, splice
22 cases, and splitters; and related supporting structures placed in the public domain
23 under applicable permits and franchises. The Applicant's ownership extends from
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NFC NORTHWEST, LLC'S APPLICATION FOR CERTIFICATION - COMPETITIVE
LOCAL CARRIER EXCHANGE

I the local point of presence to network endpoints situated in public areas,
2 consistent with municipal approvals and right-of-way authorizations. The single
3 backhaul fiber that connects the local point of presence to the broader internet is
4 not owned by the Applicant; it is owned by Ziply Fiber Pacific. While Ziply Fiber
5 Pacific is engaged to operate and maintain the Applicant's facilities on the
6 Applicant's behalf, such engagement does not transfer ownership. The Applicant
7 remains responsible for long-term asset stewardship, compliance with right-of-
8 way obligations applicable to its owned facilities, and capital renewal and
9 replacement of those assets.
10 3. A reasonably sized and detailed map showing where the applicant proposes to
11 provide service including exchanges (if different from existing exchanges), rural
12 zones, and local calling areas. If the service area is identical to an incumbent
13 LEC's service area, then applicant may refer to the incumbent's service area.
14 Answer: See the service area of all ILEC's in Idaho,primarily focusing on the
15 service area of CenturyLink/Lumen.
16 X. Financial Information.
17 1. The current detailed balance sheets, including detailed income and profit and loss
18 statements of applicant reflecting current and prior year balance for the twelve
19 (12) months ending as of the date of the balance sheet, or if not readily available,
20 for the period since the close of the preceding calendar year. If a balance sheet
21 and income statement are not available, the applicant shall submit financial data
22 sufficient to establish it possesses adequate financial resources to provide the
23 proposed services.
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NFC NORTHWEST, LLC'S APPLICATION FOR CERTIFICATION - COMPETITIVE
LOCAL CARRIER EXCHANGE

I Answer: The Applicant is a recently formed entity and, therefore, does not have
2 financial statements. To demonstrate its financial integrity, the Applicant is
3 submitting Financial Comfort Letters from each of PSP and Bell Canada,
4 Northwest Fiber's ultimate parent company. See attached.. These letters
5 demonstrate the commitment of Bell Canada and PSP Investments to fully fund
6 the Applicant and to vote their interests to have the Applicant comply with all
7 legal and regulatory obligations. These letters also incorporate by reference the
8 financial statements of each of Bell Canada and PSP Investments to document the
9 substantial financial resources that the Applicant will have available to it.
10 2. The latest annual report, if any.
11 Answer: See above.
12 XI. Tariffs and Price Lists.
13 Proposed initial tariffs or price sheets setting forth rates, rules, terms, and
14 regulations applicable to the contemplated service. Initial tariffs and price lists
15 filings shall be in an electronic form as well as paper. The tariffs and pricelists in
16 electronic format will be in computer searchable Adobe Acrobat(PDF) or submitted
17 on a CD-ROM or other format as prescribed by the Commission Secretary.
18 Answer: As the Applicant will not be offering end-user services, no such initial
19 tariffs or price sheets are required.
20 XIL Tariffs and Customer contacts.
21 The name, address, and telephone number for those persons responsible for tariff an
22 price list questions, as well as customer complaints and inquiries. The application
23 shall state the toll free telephone number for customer inquiries and complaints.
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NFC NORTHWEST, LLC'S APPLICATION FOR CERTIFICATION - COMPETITIVE
LOCAL CARRIER EXCHANGE

I Answer: Jessica Epley or Elizabeth Brayman
2 135 Lake Street South, Suite 155
3 Kirkland, WA 98033
4 [phone] (Jessica)
5 Customer service - [phone]
6 XIII. Interconnection Agreements.
7 1. Whether the applicant has initiated interconnection negotiations and, if so, when
8 and with whom. Include copies of any interconnection contracts which have been
9 completed for the provision of telecommunication services.
10 Answer: The Applicant has undertaken no such negotiations, nor does it need any
11 such agreements given its relationship with Ziply Fiber Pacific.
12 XIV. Compliance with Commission Rules.
13 1. A written statement that the applicant has reviewed the Commission's rules and
14 will comply, or request for waiver of those rules believed to be inapplicable, or
15 both.
16 Answer: The Applicant has reviewed the Commission's rules and will comply.
17 XV. Conservation of Telephone Numbers.
18 An acknowledgment that non paging telecommunications carriers with
19 telephone numbering resources in Idaho shall be subject to numbering
20 conservation measures including mandatory one thousand(1,000) block
21 pooling. See Commission Order No. 30425. All CLECs shall evaluate their
22 numbering resources and donate to the numbering resource pool unused one
23 thousand(1,000) number blocks and one thousand(1,000) number blocks that
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NFC NORTHWEST, LLC'S APPLICATION FOR CERTIFICATION - COMPETITIVE
LOCAL CARRIER EXCHANGE

I have fewer than ten percent (10%) of the telephone numbers assigned.
2 Applicable carriers shall also file the necessary utilization reports with
3 NeuStar and semi-annual report their number resource utilization/forecast
4 (NRUF) data at the one thousand(1,000) block level for each rate center
5 within their service territory. The Federal Communications Commission has
6 appointed NeuStar to manage the assignment and conservation of telephone
7 area codes and telephone numbers in North America
8 Answer: Acknowledged.
9
DATED at Portland, Oregon, this 16th day of October, 2025.
10 lq4t�
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Jessica Epley
12 Vice President, Regulatory &
External Affairs
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NFC NORTHWEST, LLC'S APPLICATION FOR CERTIFICATION - COMPETITIVE
LOCAL CARRIER EXCHANGE

1
CERTIFICATE OF SERVICE
2
I hereby certify that on October 16, 2025, I caused a true and correct copy of the foregoing
3
Application for Competitive Local Carrier Exchange to be served upon the following:
4
Via electronic filing
5
Public Utility Commission of Idaho—[e-mail].
6
DATED at Portland, Oregon, this 16th day of October, 2025.
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qq,40--
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Jessica Epley
10 Vice President, Regulatory &
External Affairs
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NFC NORTHWEST, LLC'S APPLICATION FOR CERTIFICATION - COMPETITIVE
LOCAL CARRIER EXCHANGE

114r
October 14, 2025
To Whom It May Concern
Re: Verification Letter for Network FiberCo,LLC,NFC Northwest,LLC and NFC Management
LLC
This letter is in support of Network FiberCo, LLC ("Network FiberCo") and its ability to perform its
obligations.
1. We hereby confirm that Northwest Fiber, LLC dba Ziply Fiber, a wholly owned subsidiary of Bell
Canada, holds a 49%interest in Network FiberCo. Bell Canada, in turn, is a wholly owned subsidiary
of BCE Inc. ("BCE"). A copy of BCE's current annual report can be found at Latest Annual report I
BCE Inc.
2. We confirm that NFC Northwest, LLC ("Northwest") is a wholly-owned subsidiary of NFC
Management,LLC("Management")which,in turn,is a wholly-owned subsidiary of Network FiberCo.
3. We confirm that, it is the intention of BCE to ensure that Network FiberCo, Northwest and
Management at all times remains viable and going concerns and are able to meet their respective
financial and regulatory obligations as they become due.
4. We have entered into binding agreements with PSPIB Quadratic Blocker LLC (the majority Member
of Network FiberCo) to form and fund operations for Network FiberCo and its subsidiaries.
5. We will also vote our interests in Network FiberCo to have it and its subsidiaries honor all contractual
and regulatory obligations.
6. Nothing express or implied in this letter is intended to create a legal obligation between us.
Sincerely,
BCE INC.
By: /A e�97
Name: Martin Cossette
Title: SVP—Corporate Strategy
EW1

Delaware Page 1
The First State
I, CHARUNI PATIBANDA—SANCHEZ, SECRETARY OF STATE OF THE
STATE OF DELAWARE, DO HEREBY CERTIFY THE ATTACHED IS A TRUE AND
CORRECT COPY OF THE CERTIFICATE OF FORMATION OF "NFC NORTHWEST,
LLC", FILED IN THIS OFFICE ON THE THIRTIETH DAY OF SEPTEMBER,
A.D. 2025, AT 11 :30 O'CLOCK A.M.
y 0. A F
0
Che run i Patibenda-Sanchez,Secretary of State
10348297 8100 Authentication: 204901866
SR# 20254127126 Date: 09-30-25
You may verify this certificate online at corp.delaware.gov/authver.shtml

State of Idaho
Office of the Secretary of State
CERTIFICATE OF REGISTRATION
OF
NFC NORTHWEST, LLC
Filing Number: 6462952
I, PHIL McGRANE, Secretary of State of the State of Idaho, hereby certify that
an application for Foreign Registration Statement, duly executed pursuant to the
provisions of the Idaho Uniform Business Organization Code, has been received in
this office and is found to conform to law.
ACCORDINGLY, by virtue of the authority vested in me by law, I issue this
Certificate of Registration to transact business in this State and attach hereto a
duplicate of the application for such certificate.
Dated: 17 October 2025
H Phil McGrane
Secretary of State
Processed by: Business Division
LkEEO

CERTIFICATE OF FORMATION
OF
NFC NORTHWEST,LLC
The undersigned authorized person, desiring to form a limited liability company pursuant
to the Limited Liability Company Act of the State of Delaware hereby certifies as follows:
1. The name of the limited liability company is:
NFC Northwest,LLC
2. The registered office of the limited liability company in the State of Delaware is
located at 251 Little Falls Drive, in the city of Wilmington, County of New Castle, Delaware
19808. The name of the registered agent at such address upon whom process against this limited
liability company may be served is Corporation Service Company.
IN WITNESS WHEREOF,the undersigned has executed this Certificate of Formation of
NFC Northwest,LLC this 30d'day of September,2025.
By:
Name: Ana Castro
Title: Authorized Person
State of Delaware
Secretary of State
Division of Corporations
Delivered 11:30 AM 09/30/2025
FUID 11:30 AM 09/30/2025
SR 20254127126 - File Number 10348297