Rising Concerns Over Telecommunication Service Quality Issues
The National Association of State Utility Consumer Advocates discussed the resurgence of telecommunication service quality issues at their annual meeting. Topics included state regulatory proceedings, advocacy for service quality, and the impact of ILECs' premature abandonment of copper networks. Consumers are seeking functioning dial tone lines and timely repairs, prompting regulatory attention through complaints and legislative actions. Concerns also arise from sales and mergers affecting service quality and network maintenance.
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Presentation Transcript
NATIONAL ASSOCIATION OF STATE UTILITY CONSUMER ADVOCATES Telecom Committee Panel: Like the Phoenix, Telecommunication Service Quality Issues are Rising Again Susan Baldwin November 19, 2019
Topics Discussion of state regulatory proceedings Roadmap for service quality advocacy Why it matters -- 35 million ILEC-provided retail residential and business local exchange lines depend on copper networks Views expressed are my own! Susan Baldwin | NASUCA Annual Meeting November 19, 2019 2
Subpar Service Quality Nationwide Premature abandonment by ILECs of copper networks Premature abandonment by PUCs of SQ oversight Now circling back The Commission concluded that the seeming failure of Verizon s wireline telephone service to meet long-standing Commission service quality objectives, despite the existence of competition, necessitated such an inquiry. November 19, 2019 Susan Baldwin | NASUCA Annual Meeting 3
Eyes on the Prize Consumers Want: Functioning dial tone lines Timely repair of non-functioning dial tone lines Broadband (but that s another story) November 19, 2019 Susan Baldwin | NASUCA Annual Meeting 4
When and How to Gain Regulators Attention Consumers complain loudly, leading to an SQ investigation Consumers get fed up with long waits to have their dial tone lines fixed (e.g., Maryland, Minnesota, New Jersey, Wyoming and more) Consumers file complaints (e.g., Maryland - 1,000 complaints) Consumers find a sympathetic ear at the State Legislature (e.g., Vermont) November 19, 2019 Susan Baldwin | NASUCA Annual Meeting 5
When and How to Gain Regulators Attention Sales/mergers: e.g., CA past sale of Verizon to Frontier; ID, OR, MT, WA pending sale of Frontier to Northwest Did the selling company neglect the network? Does the buying company know what it is buying? Will the buying company cut costs (have fewer outside plant technicians, not bother to replace/fix defective plant; focus on urban and high-revenue areas to the neglect of other areas)? November 19, 2019 Susan Baldwin | NASUCA Annual Meeting 6
When and How to Gain Regulators Attention Legislators speak up Constituent conveys to Vermont legislator that the constituent s line had been out six days. Legislator points out how dangerous this could have been for an elderly shut in who needed help on day 2 (or 3 or 4 or 5). CWA supports consumer advocate or petitions for SQ investigations New York The network is aging, breaking down and will get dramatically worse unless Verizon is required to reinvest in equipment and personnel. Pennsylvania, New Mexico November 19, 2019 Susan Baldwin | NASUCA Annual Meeting 7
Remedies Continuing oversight and wire center level data reporting (Maryland) Outside plant remediation (New Jersey, New York, Pennsylvania) (in PA: repair and replace bad cable, defective equipment, and faulty back-up batteries, and take down 15,000 double telephone poles) Network Audit (California) Escrow Funds (West Virginia) November 19, 2019 Susan Baldwin | NASUCA Annual Meeting 8
Remedies (contd) SQ standards, reporting and more (Minnesota) Satellite-based VoIP substitute (Wyoming) Rules (SQ rulemaking in New Mexico) Pending investigation ( negative performance trends re % OOS cleared; consumer complaints - Vermont) Penalties/Incentives (California) November 19, 2019 Susan Baldwin | NASUCA Annual Meeting 9
Remedies (contd): California Network Audit Redacted executive summary details service quality deterioration and demonstrated lack of resiliency. The CPUC s web site lists six findings: service quality deterioration, lack of network resiliency, disinvestment in basic local exchange service, broadband investment leads to higher quality basic local exchange service, AT&T provides worse service quality in low-income communities than in high income communities, and areas with little or no competition experience lower service quality. November 19, 2019 Susan Baldwin | NASUCA Annual Meeting 10
NM Recent Win The Commission notes the disturbing indications in the record that CenturyLink may be neglecting portions of its infrastructure used to provide telecommunications service, particularly in rural and low- income areas. CenturyLink does not explain how lower levels of quality of service regulation will remedy such deficiencies. The Commission finds that robust quality of service regulation is more likely to encourage CenturyLink to maintain and repair its wireline infrastructure October 31, 2019 November 19, 2019 Susan Baldwin | NASUCA Annual Meeting 11
Metrics: analyze at the wire center level Network trouble report rate (out-of-service and service-affecting) Repeat trouble report rate (indicator of band-aid repair): [J]erry- rigged cable repairs also undermine the viability of the air pressure system. For example, if temporary plastic enclosures are placed on damaged cables, air pressure leaks at that point. Average repair interval and % of troubles cleared within 24 (or 48) hours (measures of timeliness of repair) Installation interval or % of appointments kept (consumers continue to order basic lx from telcos) November 19, 2019 Susan Baldwin | NASUCA Annual Meeting 12
Outside plant metrics Numbers/locations of requests from outside plant technicians regarding areas where copper plant needs to be repaired or replaced (e.g., NY, PA) Age of plant (New York, PA) Are batteries in remote terminals being replaced? (various states) Are transducers going into alarm mode (when rain/moisture enters outside plant)? (NY, PA) Audit (California, West Virginia) Detailed report: slow repair times, failure to maintain and repair equipment, lack of investment in its infrastructure, lengthy customer service wait times, and slower repair services in rural areas compared to more populated areas (Minnesota) Other important metrics: consumer complaints and public hearings November 19, 2019 Susan Baldwin | NASUCA Annual Meeting 13
Who Cares? Potential partners for state consumer advocates include: First responders AARP (persons over 65 disproportionately rely on landlines) Rural areas, non-FiOS, non-U-verse areas; rural organizations; rural consumers Municipalities Legislators CWA, IBEW November 19, 2019 Susan Baldwin | NASUCA Annual Meeting 14
Questions to Ask When did the telco last replace the batteries in its remote terminals? How often do the transducers go into alarm mode? How old is the copper plant in the various wire center areas? How many pending requests have outside plant technicians made to fix or replace defective outside plant? What is the repeat trouble report rate at the wire center level? How quickly is the telco repairing out-of-service troubles? What are consumers saying? Why exactly should the SQ data be considered confidential? November 19, 2019 Susan Baldwin | NASUCA Annual Meeting 15
Long Term Vision for Telco SQ: Who continues to rely on telcos copper networks? Those who haven t cut the cord Older persons -Three out of four over 65 have not cut the cord Rural areas: - Cell phone service spotty in rural areas - Rural areas less likely to cut the cord than metro areas Those lacking the broadband that provides typical platform for VoIP alternative Older persons less likely to adopt broadband Broadband is less available in rural areas November 19, 2019 Susan Baldwin | NASUCA Annual Meeting 16
Takeaways: 1. Oversight of ILEC service quality to ensure reliable, adequate, safe dial tone lines continues to be essential 2. Consumer advocates have key role November 19, 2019 Susan Baldwin | NASUCA Annual Meeting 17
The ILECs Story Money argument: It s not profitable to maintain copper networks We re facing financial straits and so can t afford to fix outside plant Thanks to all those mergers we re big and powerful: Strong resistance to regulatory oversight November 19, 2019 Susan Baldwin | NASUCA Annual Meeting 18
The ILECs Story We want a level playing field: Why regulate our SQ when you re not regulating our competitors SQ? Competition cures all: If consumers are unhappy, they can go to the cable company and to the cell phone company Migrate to fixed wireless (e.g., Voice Link): Deploy fixed wireless rather than roll out trucks to fix defective plant Less regulation leads to more broadband: [NM] Commission is also not persuaded by CenturyLink s assertion that lowering quality of service and consumer protection standards for telecommunications services will result in expanded broadband internet access. November 19, 2019 Susan Baldwin | NASUCA Annual Meeting 19
Susan M. Baldwin smbaldwinconsulting@gmail.com www.smbaldwinconsulting.com (617) 388-4068 Ms. Baldwin s views today are based in part on her experience in the following recent proceedings California: In the Matter of the Joint Application of Frontier Communications Corporation, Frontier Communications of America, Inc. (U 5429 C), Verizon California Inc. (U 1002 C), Verizon Long Distance, LLC (U 5732), and Newco WestHoldings LLC for Approval of Transfer of Control Over Verizon California Inc. and Related Approval of Transfer of Assets and Certifications (Filed March 18, 2015), Application 15-03-005, reply and supplemental testimony on behalf of the Utility Reform Network (TURN), July 28, 2015 and September 11, 2015. Pennsylvania: Public Utility Commission Docket No. P-2015-2509336, Petition of Communications Workers of America for a Public, On-the-Record Commission Investigation of the Safety, Adequacy, and Reasonableness of Service Provided by Verizon Pennsylvania, LLC, direct testimony on behalf of Communications Workers of America, September 29, 2016. Maryland: Petition of the Maryland Office of People s Counsel for an Investigation into Verizon Maryland s Provision of Basic Local Phone Service Over Copper or Fiber Networks, affidavit on behalf of the Maryland Office of People s Counsel, January 13, 2017. Report on behalf of Maryland Office of People s Counsel, February 8, 2019. New York: New York Public Service Commission Case 16-C-0122, Proceeding on Motion of the Commission to Consider the Adequacy of Verizon New York Inc. s Retail Service Quality Processes and Programs, testimony on behalf of the Communications Workers of America, March 24, 2017. Wyoming: Public Service Commission Docket No. 700000-1644-TA-17, In the Matter of the Application of Qwest Corporation d/b/a CenturyLink QC for Determination that Basic Residential and Business Services Are Competitive Throughout All of CenturyLink QC s Zone 2 and Zone 3 Service Areas, testimony on behalf of AARP, November 15, 2017 New Mexico: Public Regulation Commission Case No. 18-00295-UT, In the Matter of the Petition of CenturyLink CQ Regarding Effective Competition for Retail Residential Services, testimony on behalf of CWA, April 15, 2019. New Jersey: Investigation of the Service Quality Standards and Reporting by Incumbent Local Exchange Carriers Service Quality Proceeding, BPU Docket No. TX18131301,on behalf of New Jersey Division of Rate Counsel (pending) Washington: UTC Docket UT-190574, In the Matter of the Joint Application of Northwest Fiber, LLC, Frontier Communications Corporation, and Frontier Communications ILEC Holdings LLC for an Order Declining to Assert Jurisdiction Over, or, in the Alternative, Approving the Transfer of Control of Frontier Communications Northwest Inc. to Northwest Fiber, LLC, on behalf of Public Counsel (pending) November 19, 2019 Susan Baldwin | NASUCA Annual Meeting 20
