20261007Staff Comments.pdf

RECEIVED
October 07, 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.
On February 5, 2026, the Commission issued a Notice of Application and Notice of
Modified Procedure,establishing deadlines for public comments and for the Company to file reply
comments. Order No. 36920. No public comments were received.
STAFF COMMENTS 1 OCTOBER 7, 2026

On April 2, 2026, the Commission issued Order No. 36986, conditionally denying the
Company's Application and directing the Company to submit all outstanding information and
documentation within 21 days of service of the Order. The Company submitted a Compliance
Filing on April 3, 2026, and a Supplemental Response to Order No. 36986 on July 17, 2026.
STAFF ANALYSIS
Staff reviewed the Company's Application, compliance filing, supplemental response to
Interlocutory Order No. 36986 and Staffs prior comments filed in this case. Additionally, Staff
reviewed the Commission's Rules of Procedure, Rule 114 ("Rule 114") which provides the
information required to be included in a CPCN application. Staff previously verified that the
Company's application met all the requirements listed in Rule 114 except for item number two
which addresses services and territory. The Application was missing incumbent local exchange
corporations ("ILEC") and a detailed map showing the proposed service area.
IDAPA3 L01.01.114.2(b-c).
In response to Order No. 36986, the Company submitted a compliance filing. In the
compliance filing, the Company included several ILECs and also included an out-of-date map of
Idaho Telephone Exchange and Company Areas. The map was more than ten years old, included
several companies who are no longer providing services in Idaho, and the service areas have
changed since it was created. Compliance Filing at 2. Staff worked with the Company to identify
a specific service area and suggested filing a new map to satisfy the Rule 114 requirement. The
Company submitted a Compliance filing on July 17,2026,which included the information needed
to verify Rule 114 (2 b-c). Through the compliance filing and Staffs prior comments filed in this
case, Staff was able to determine that the Company has met all the requirements listed in Rule 114,
for a CPCN.
Additionally, Staff believes that the Commission should require the Company to
demonstrate progress toward providing the services identified in the Application in the form of
compliance filings updating the number of customers, interconnection agreements and status of
infrastructure construction at various points in the near future.
STAFF COMMENTS 2 OCTOBER 7, 2026

STAFF RECOMMENDATION
Staff recommends approval of the Company's Application for a CPCN to provide resold
and facilities-based local exchange telecommunications services in the State of Idaho subject to
the following conditions:
1. The Company shall comply with the number pooling and reporting requirements of the
North American Numbering Plan Administrator, as outlined in Commission Order
30425.
2. The Company shall provide the necessary reports and contributions to the Idaho
Universal Service Fund, Idaho Telecommunications Relay Services, and Idaho
Telecommunications Service Assistance Program and comply with all future reporting
requirements deemed appropriate by the Commission for competitive
telecommunications providers.
3. Prior to the issuance of the CPCN certificate, the Company shall file a final price list
and/or tariff outlining all its rates, terms and conditions with the Commission.
4. Prior to the issuance of the CPCN certificate, the Company shall file three reports
indicating the number of customers connected and its progress on the construction of
the infrastructure needed to provide service. These reports shall be due as follows:
a. December 31, 2026;
b. March 15, 2027; and
c. May 31, 2027.
If the Company fails to provide the three reports, the Company shall relinquish its
CPCN certificate and all telephone numbers it has been assigned or the Commission
will by its order revoke the Company's CPCN certificate.
5. The Company shall relinquish its certificate and any telephone numbers if it is not
doing business within one year of its issuance of its CPCN.
Respectfully submitted this 7th day of October 2026.
61 �(AAA/'710-
Melanson
Deputy Attorney General
Technical Staff. Allison Moore
L•\Utility\UMISC\COMMENTS\EFI-T-25-01 Comments.docx
STAFF COMMENTS 3 OCTOBER 7, 2026

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 7th DAY OF OCTOBER 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