20260522Staff Comments.pdf

RECEIVED
May 22, 2026
JEFFREY R. LOLL IDAHO PUBLIC
DEPUTY ATTORNEY GENERAL UTILITIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83702
[phone]
IDAHO BAR NO. 11675
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF BLACKFOOT )
COMMUNICATIONS, INC.'S APPLICATION ) CASE NO. FRC-T-25-01
FOR THE 2024 BROADBAND EQUIPMENT )
TAX CREDIT )
COMMENTS OF THE
COMMISSION STAFF
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission
("Commission"),by and through its attorney of record, Jeffrey R. Loll, Deputy Attorney General,
submits the following comments.
BACKGROUND
On July 23, 2025, Blackfoot Communications, Inc. dba Fremont Communications, Inc.
("Company") applied to the Commission for an order confirming that equipment the Company
installed during 2024 is "qualified broadband equipment" under Idaho Code § 63-3029I (Income
tax credit for investment in broadband equipment) ("Application").
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-
3029I 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
STAFF COMMENTS I MAY 22, 2026

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 § 63-3029I(3)(b)(i). The equipment must be primarily used to
provide services to subscribers in Idaho to qualify for the credit. Idaho Code § 63-3029I(3)(b)(vii).
To be eligible for the tax credit, the taxpayer must obtain an order from the Commission
confirming that the installed equipment meets the statutory definition of qualified broadband
equipment. Idaho Code § 63-3029I(4) and Commission Order Nos. 35297 and 36970. Prior to
making such a determination, the Commission requires applicants to submit"a specific list of the
equipment or types of equipment that the applicant is requesting that the Commission determine
is `qualified broadband equipment' as defined in Idaho Code § 63-3029I(3)(b)," and to "[1]ist the
brand, manufacturer, model numbers of the installed equipment, number of items, and total cost."
Order No. 35297, Attachment A. The Commission has emphasized that its "role in applications
for broadband equipment tax credit is limited to `confirming that the installed equipment is
qualified broadband equipment"' and does not extend to approving costs for non-equipment
project expenditures for credit. Order No. 36970, quoting Idaho Code § 63-3029I(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 Company represents that it offers broadband services to its customers at transmission
rates of 256,000 bits per second ("bps") up to 1,000,000,000 bps from a subscriber and 768,000
bps up to 1,000,000,000 bps to a subscriber. Id. The Company represents that during 2024, it
offered broadband services to all 112 of its Idaho customers. Id.
The Company reported investing $118,266.46 in qualifying broadband equipment during
2022. Id. at 1.
STAFF ANALYSIS
Staff reviewed the Application and documentation submitted to the Commission. As
part of the review process, Staff audited the list of broadband equipment submitted by the
Company. During the review, Staff was unable to verify that all of the broadband equipment
listed complied with the requirements of Commission Order Nos. 35297and 36970, which
requires the Company to provide the brand, manufacturer, model numbers of the installed
equipment, number of items, and total cost of the listed broadband equipment. The Company
STAFF COMMENTS 2 MAY 22, 2026

did not provide a brand, manufacturer, or model number for many of the items included in its
original Application. In addition,the Company included line items for labor and other project
costs that are not qualified broadband equipment.
On October 20, 2025, Staff requested the missing information through production
requests. In the Company's response on October 28,2025,the Company provided an identical
list to the one that was originally submitted in the Application and did not include the missing
or required information. Company's Response to Staff Production Request No. 1. Staff was
unable to verify all items in the list as qualifying broadband equipment pursuant to Idaho
Code § 63-3029I(3)(b) and Commission Order Nos. 35297 and 36970. Subsequently, the
Company sent an amended spreadsheet on March 27, 2026, directly to Staff with labor and
other expenses removed. In the amended spreadsheet, attached to these comments as
Attachment A, the Company reported that it invested a total of $39,071.01 in qualifying
broadband equipment in 2024. Id. Staff reviewed the information and verified that the items
are in accordance with Commission Order Nos. 35297 and 36970.
STAFF RECOMMENDATION
Staff recommends that the Commission issue an order confirming that the
equipment identified in Attachment A is qualified broadband equipment and forward the
approving order, along with a copy of the original Application and the equipment list in
Attachment A, to the Idaho Tax Commission.
Respectfully submitted this 22nd day of May 2026.
Jeffrey R. Loll
Deputy Attorney General
Technical Staff. Jon Kruck, Allison Moore
I:\Utility\UMISC\COMMENTS\FRC-T-25-01 Comments.docx
STAFF COMMENTS 3 MAY 22, 2026

Idaho Broadband Equipment Tax Credit Application Details-amended
Tax year ending 1213112024
Company Information
1.Name of com an: Blackfoot Communications,Inc.dba Fremont Communications
2.Address: 1221 N Russell Street,Missoula,MT 59808
3.Type of com an: Telecommunication Carrier
4.Contact erson: Dan!Kinard,CPA [e-mail]
Date Asset Description Project ID ASSET ID Manufacturer Brand Model Location Item Cost Total Cost of
installed Project
7/31/2024 STAT-CO-NCSSSA2-2 BC12021691-02 BC1007578 Cisco Cisco GLC-T-C Fremont 1.00 52.00
7/31/2024 STAT-CO-NCS55A2-2 BC12021691-02 BC1007578 OptoSpan OptoSpan MTMT-KM408NXR20 Fremont 1.00 245.53
7/31/2024 STAT-CO-NCS55A2-2 BC12021691-02 BC1007578 Cisco Cisco QSFP-100G-SR4-S-C Fremont 2.00 637.00
7/31/2024 STAT-CO-NCS55A2-2 BC12021691-02 BC1007578 Prol-abs Prol-abs 1029-3600-C Fremont 2.00 637.00
7/31/2024 STAT-CO-NCS55A2-2 BC12021691-02 BC1007578 OptoSpan OptoSpan MTMT-KM408NXR20 Fremont 1.00 247.80
7/31/2024 STAT-CO-NCS55A2-2 BC12021691-02 BC1007578 Digicomm International Inc. Digicomm International Inc. 1015-6800 Fremont 1.00 3,854.45
7/31/2024 STAT-CO-NCSSSA2-2 BC12021691-04 BC1007578 Cisco Cisco NC55-MPA-4H-S Fremont 1.00 5,586.39 11,260.17
4/30/2024 KCD-CAA 1x64 SC/APC Splitter BC12022226 BC1007817 Clearfield Clearfield KCD-CAA Madison 2.00 3,639.98 3,639.98
5/31/2024 Fiber 48,BOC,SM/FIBER 144,BOC,SM BC12023452 BC1007834/BC1007835 Corning Corning 012EU4-T4700D20 Madison 980.00 357.35 357.35
7/31/2024 FIBER 144,BOC,SM BC12023376 BC1007843 Corning Corning 012EU4-T4700D20 Madison 2,128.00 2,078.63 2,078.63
10/31/2024 POIyCpm VVX 450 HPP Desk Phone BC12024305 BC1007875 Cisco Cisco MS120-24P Madison 2.00 3,864.93
10/31/2024 Polycom VVX 450 HPP Desk Phone BC12024305 BC1007875 Cisco Cisco Z3-HW Madison 1.00 240.13
10/31/2024 Polycom VVX 450 HPP Desk Phone BC12024305 BC1007875 Cisco Cisco LIC-MS120-24P-3YR Madison 2.00 386.36
10/31/2024 Polycom VVX 450 HPP Desk Phone BC12024305 BC1007875 Cisco Cisco LIC-Z3-ENT-3YR Madison 1.00 166.08
10/31/2024 Polycom VVX 450 HPP Desk Phone BC12024305 BC1007875 Polycom Polycom 2200-48840-001 Madison 38.00 5,604.09
10/31/2024 Polycom VVX 450 HPP Desk Phone BC12024305 BC1007875 Polycom Polycom 2200-86810-001 Madison 2.00 483.07
10/31/2024 Polycom VVX 450 HPP Desk Phone BC12024305 BC1007875 Polycom Polycom 2200-86820-001 Madison 2.00 331.34
10/31/2024 Polycom VVX 450 HPP Desk Phone BC12024305 BC1007875 Polycom Polycom 2200-48840-001 Madison 1.00 147.48
10/31/2024 Polycom VVX 450 HPP Desk Phone BC12024305 BC1007875 Polycom Polycom 220D-48840-001 Madison 2.00 294.95
10/31/2024 Polycom VVX 450 HPP Desk Phone BC12024305 BC1007875 Cisco Cisco MS120-48LP-HW Madison 1.00 2,553.03
10/31/2024 Polycom VVX 450 HPP Desk Phone BC12024305 BC1007875 Cisco Cisco LIC-MS120-48LP-3YR Madison 1.00 292.52 14,363.98
11/30/2024 C4110-4848 ION Fiber to Fiber BC12024403 BC1007900 Cisco Cisco SFP-JOG-LR-C Jefferson 2.00 116.00
11/30/2024 C4110-4848 ION Fiber to Fiber BC12024403 BC1007900 Cisco Cisco SFP-10G-ZR-1550-C Jefferson 2.00 1,040.00
11/30/2024 C4110-4848 ION Fiber to Fiber BC12024403 BC1007900 Cisco Cisco SFP-30G-ZR-1570-C Jefferson 2.00 1,040.00
11/30/2024 C41104848 ION Fiber to Fiber BC12024403 BC1007900 Lantronix Lantronix ION001-A Jefferson 1.00 75.15
11/30/2024 C4110-4848 ION Fiber to Fiber BC12024403 BC1007900 Lantronix Lantronix C4110-4848 Jefferson 3.00 2,457.87
11/30/2024 C4110-4848 ION Fiber to Fiber BC12024403 BC1007900 Lantronix Lantronix IONMM Jefferson 1.00 370.29
11/30/2024 C4110-4848 ION Fiber to Fiber BC12024403 BC1007900 Lantronix Lantronix ION219-A Jefferson 1.00 519.00 5,618.31
12/31/2024 Fiber 12 Universal Drop BC12022387 BC1007932 Corning Corning 012EU4-T4700D20 Madison 1,874.00 503.85
12/31/2024 Fiber 12 Universal Drop BC12022387 BC1007932 Comstock Comstock WRUX11CCO24BKO Madison 1.00 298.69
12/31/2024 Fiber 12 Universal Drop BC12022387 BC1007932 Lenovo Lenovo 11RUO11CA012BK3 Madison 1.00 332.59 1,135.13
12/31/2024 Fiber 2 Toneable Drop BC12022387 BC1007933 Corning Corning 012EU4-T4700D20 Madison 954.00 256.50 256.50
12/31/2024 Fiber 48,BOC,SM BC12024502 BC1007934 Corning Corning 012EU4-T4700D20 Madison 520.00 139.81 139.81
12/31/2024 Fieldsmart Cross Connect Cabin BC12024279 BC1007937 Corning Corning 444401G2133002M Madison 30.00 87.94
12/31/2024 Fieldsmart Cross Connect Cabin BC12024279 BC1007937 ComingCorning444401G2131003M Madison 30.00 90.85
12/31/2024 Fieldsmart Cross Connect Cabin BC12024279 BC1007937 Corning Corning 444401G2133002M Madison 15.00 42.36 221.15
TOTAL QUALIFYING BROADBAND COSTS PLACED IN SERVICE IN 2024 39,071.01
Attachment A
Case No. FRC-T-25-01
5/20/2026 Staff Comments 2024 details
May 22, 2026

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 22nd DAY OF MAY 2026, SERVED
THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE NO. FRC-
T-25-01, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
STACEY MUELLER, CPA
CHIEF FINANCIAL OFFICER
BLACKFOOT COMMUNICATIONS, INC.
1221 NORTH RUSSELL STREET
MISSOULA, MT 59808
E-MAIL: taxgblackfoot.com
PATRICIA JORD: , SECRETARY
CERTIFICATE OF SERVICE