20260226Staff Comments.pdf

RECEIVED
February 26, 2026
ERIKA K. MELANSON IDAHO PUBLIC
DEPUTY ATTORNEY GENERAL UTILITIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83702
[phone]
IDAHO BAR NO. 11560
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF EATON FIBER IDAHO, )
LLC'S APPLICATION FOR A CERTIFICATE ) CASE NO. EFI-T-25-01
OF PUBLIC CONVENIENCE AND )
NECESSITY TO PROVIDE RESOLD AND )
FACILITIES-BASED EXCHANGE ) COMMENTS OF THE
TELECOMMUNICATIONS SERVICES ) COMMISSION STAFF
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission
("Commission"), by and through its attorney of record, Erika K. Melanson, Deputy Attorney
General, submits the following comments.
BACKGROUND
On November 19, 2025, Eaton Fiber Idaho, LLC ("Company") applied to the
Commission requesting a Certificate of Public Convenience and Necessity ("CPCN") to provide
resold and facilities-based local exchange telecommunications services in the State of Idaho
("Application"). The Company proposed providing point-to-point telecommunications services,
including dark fiber, ethernet, and broadband internet access services. Application at 1. The
Application requested authority to build and operate a fiber network throughout the entire state
of Idaho, with network construction beginning within 60-90 days of an order from the
Commission granting a CPCN. Id. at 2.
STAFF COMMENTS 1 FEBRUARY 26, 2026

STAFF ANALYSIS
Commission Rules of Procedure, Rule 114 ("Rule 114") requires the Company to provide
detailed information regarding its business structure—including name, address, and entity type—
with tailored requirements depending on whether the applicant is a sole proprietor,partnership,
corporation, or limited liability company. Rule 114(1)(a-c). The Company is a subsidiary of
Eaton Fiber, LLC. The Application provided evidence that certifies that it is a limited liability
company organized under the laws of the State of Delaware. Application at 2. In Exhibit A of
the Application, the Company provided its Certificate of Registration from the State of Idaho's
Office of the Secretary of State, Filing Number 64990467, and Staff was able to verify this
information through the Idaho Secretary of State's Office. Additionally, the Company stated that
it is headquartered at 152 West 57th Street, 34t1i FL,New York,NY 10019. Id. at 2. The
Company has met this requirement.
In accordance with Rule 114(2), the Company is required to submit a detailed description
of the services and competitive landscape, including a detailed narrative of proposed customer
classes and services to be offered to the public, identification of incumbent local exchange
carriers ("ILECs")that the Company anticipates competing with, and a sufficiently detailed
service-area map, illustrating intended exchanges, rural zones, and local calling areas where the
applicant proposes to operate. Rule 114(2). The Company provided a detailed description of its
proposed services and a draft of their tariff in the Application. However, Staff did not find
information or documentation that identified any ILECs or a detailed service area map that
included intended exchanges, rural zones and local calling areas where they are proposing to
operate. Rule 114(2)(b-c). The Company has not met this requirement.
Rule 114(3)requires the Company to submit financial information that includes "detailed
balance sheets, including detailed income and profit and loss statements applicant reflecting
current and prior year balance for the twelve months . . . if not available, the applicant shall
submit financial data sufficient to establish it possesses adequate financial resources to provide
the proposed services." In the Application, a confidential example of how they will be
capitalized financially was included to meet this requirement as a result of not currently being
operational in Idaho. Application at Exhibit B. Additionally, a copy of the Company's proposed
tariff and price list was included in the Application. Id. at Exhibit C. The Company has met this
requirement.
STAFF COMMENTS 2 FEBRUARY 26, 2026

In compliance with Rule 114(4)-(5), the Company is required to provide an initial
proposed tariff and services, along with the corresponding charges and contact information for
the individual(s)who are able to answer any questions regarding the tariff and customer service.
Additionally, Rule 114(6)requires the Company to provide information regarding any
interconnection agreements or if they have initiated interconnection negotiations with any other
companies. The remaining Rule 114(7)-(8) requirements for a CPCN have been provided by the
Company in the Application. The Company has met all of the requirements stated above.
STAFF RECOMMENDATION
Staff does not recommend approval of the Company's Application for a CPCN to provide
resold and facilities-based local exchange telecommunications services in the State of Idaho until
the Company has submitted the requirements outlined in Rule 114(2)(b-c). Staff recommends
the Commission deny the Application and provide the Company twenty-one (21) days to provide
the additional required information for Staff to review.
Respectfully submitted this 26th day of February 2026.
Erika K. Melanson
Deputy Attorney General
Technical Staff. Allison Moore
I:\Utility\UMISC\COMMENTS\EFI-T-25-01 Comments.docx
STAFF COMMENTS 3 FEBRUARY 26, 2026

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 26th DAY OF FEBRUARY 2026,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF , IN
CASE NO. EFI-T-25-01, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
SCOTTY AMOS
EISNER ADVISORY GROUP LLC
2640 YOUREE DRIVE, SUITE 100
SHREVEPORT, LA 71104
EMAIL: scott. .amoskeisneramper.com
PATRICIA JORDAN, ECRETARY
CERTIFICATE OF SERVICE