20260630Final_Order_No_37083.pdf

Office of the Secretary
Service Date
June 30,2026
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AT&T MOBILITY II ) CASE NO. GNR-T-25-09
LLC'S APPLICATION FOR THE 2024 )
BROADBAND EQUIPMENT TAX CREDIT )
ORDER NO. 37083
On September 22, 2025, AT&T Mobility II LLC ("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 § 63-3029I
(Income tax credit for investment in broadband equipment) ("Application").
On May 8, 2026, the Commission issued a Notice of Application and Notice of Modified
Procedure establishing written comment deadlines. Order No. 37035. Commission Staff("Staff')
filed comments. The Commission received no public comments or Company reply comments.
Based on our review of the record, the Commission now issues this Final Order denying
the 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-
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 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 apply for and obtain an order from the
Commission confirming that the installed equipment meets the statutory definition of qualified
broadband equipment. Idaho Code § 63-3029I(4). Prior to making such a determination, the
ORDER NO. 37083 1

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. 3 5297,Attachment A. 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
The Company represented that it offers mobile broadband technologies over its wireless
broadband network, including voice and data services, messaging, location-based services, over-
the-air downloadable applications, video on demand, and push-to-talk. Application at 2. The
Company states that through FirstNet services, it also provides a nationwide wireless broadband
network dedicated to public safety.Id. The Company stated that it has implemented the Distributed
Radio Access Network architecture at its cell tower locations throughout Idaho.Id. The Company
represents that the components it installed at its cell tower locations include: the tower or other
supporting structure;antennas;coaxial cables;remote radio heads or remote radio units;fiber optic
cables and power cables; and a shelter containing power supply components, baseband units
(signal processing), and a smart integrated access device (Interface to the backhaul network). Id.
at 3.
According to the Company, it offers broadband services to its customers at minimum
transmission rates of 48.75 megabits per second ("Mbps") and for downloads and 2.84 Mbps for
uploads. Id. The Company stated that its network is available to 98.6 percent of Idaho residents.
Id. According to the Company, it currently services 302,727 subscribers. Id. The Company
reported investing $5,931,601 in qualifying broadband equipment during 2024. Application,
Appendix A at 14.
STAFF COMMENTS
Staff audited the Company's equipment list and could not verify that each entry in the list
identified a valid brand, manufacturer, and model number. Staff Comments at 3. Staff requested
the missing information through a set of production requests that were served on December 5,
2025. Id. at 3. As of May 26, 2026, Staff had yet to receive any substantive response to its
production requests.Id.
ORDER NO. 37083 2

Staff attached to its comments as Attachment A a spreadsheet of the Company's equipment
list with the items Staff believed should be disallowed and a brief explanation as to why it could
not verify each item. Id. Because Staff could not confirm the majority of the Company's list were
qualified broadband equipment, it recommended that the Commission conditionally deny the
Company's Application with leave to amend for a period of 30 days.
COMMISSION FINDINGS AND DECISION
Having reviewed the record, the Commission is unable to find that the items included in
the list attached to the Company's Application are qualified broadband equipment eligible for the
broadband tax credit under Idaho Code § 63-3029I. Accordingly, we deny the Company's
Application.
ORDER
IT IS HEREBY ORDERED that the Application is denied.
THIS IS A FINAL ORDER. Any person interested in this Order may petition for
reconsideration within 21 days of the service date of this Order regarding any matter decided in
this Order.Within seven days after any person has petitioned for reconsideration, any other person
may cross-petition for reconsideration.Idaho Code §§ 61-626 and 62-619.
1H
ORDER NO. 37083 3

DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 30th day of
June 2026.
G
EDWARD LODGE, PR_ IDENT
J R. HAMMOND JR., COMMISSIONER
DAYN HA IE, COMMISSIONER
ATTEST:
Monica I3af'ri Sanchez
Commission Secretary
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