R.11!12!001 Public Roycroft Declaration 1-31-12

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA
Order Instituting Rulemaking to Evaluate Telecommunications Corporations Service Quality Performance and Consider Modification to Service Quality Rules
) ) ) )
R.11-12-001
Declaration of Trevor R. Roycroft, Ph.D.
On Behalf of The Utility Reform Network (TURN) Center for Accessible Technology National Consumer Law Center January 31, 2012 NON-CONFIDENTIAL VERSION Material Alleged to be Confidential has been Expurgated
Table of Contents
I. II. A. B. C. III. Statement of Qualifications................................................................................................................................... 1 Introduction and Overview ................................................................................................................................... 3 The Objectives of the OIR ........................................................................................................................... 3 Management Choices Regarding Investment and Service Quality .............................................................. 7 Issues Raised by the March 2011 Communications Division Report ........................................................ 11 Response to OIR Questions ............................................................................................................................ 14
D. Summary ........................................................................................................................................................... 14 Question 1: Are the adopted GO 133-C service quality standards appropriate and reasonable? If not, should new service quality standards be adopted or should existing standards be modified or eliminated? ............................. 14 Service Guarantees ............................................................................................................................................. 16 Major Service Outages........................................................................................................................................ 17 Consistent Reporting........................................................................................................................................... 18 Question 2: Should additional Out-of-Service standards be established for Out-of-Service events in excess of 24 hours?...................................................................................................................................................................... 19 Question 3: Why are many of the URF carriers consistently missing the service quality measurement standards for (a) Out-of-Service Repairs, and (b) Answer Times? ......................................................................................... 19 Management Decisions Favor Advanced Service Platforms .............................................................................. 19 Verizon ............................................................................................................................................................... 20 AT&T ................................................................................................................................................................. 23 SureWest ............................................................................................................................................................. 23 Summary ............................................................................................................................................................. 24 Question 4: The current service quality standards and measures focus on retail customers. Should standards be adopted for wholesale service? If so, what should these standards and measures be? ...........................................24 Question 5: Is it appropriate to implement a penalty mechanism when standards are not met? If so, what should it be? ....................................................................................................................................................................... 25 Benchmark Annual Penalty ................................................................................................................................ 27 Penalty Points ..................................................................................................................................................... 28 Annual Penalty Assessment ................................................................................................................................ 29 Application of the Penalty Mechanism ............................................................................................................... 30 Calculating the Penalty ....................................................................................................................................... 30 Offset Benchmark Penalty by Amount of OOS Service Guarantees .................................................................. 31 Forgiveness for Brief Periods of Substandard Performance ............................................................................... 31 Customer Rebates ............................................................................................................................................... 31 Evaluation of the Penalty Mechanism ................................................................................................................ 31 Question 6: Should exemptions be allowed for calculating reported service quality results for States of Emergency, Catastrophic Events and events beyond the control of the utility management? If so, should there be limitations on the geographic area(s) covered and/or the duration of the exemption? ............................................ 32 Question 7: Should carriers provide the Commission with additional service quality data in the aftermath of a catastrophic event? If so, what additional data is appropriate? .............................................................................. 33 Question 8: What other reporting requirements or measures are appropriate to evaluate quality of service? ....... 34
Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________
Question 9: Should the Commission hire a network consultant to: a) review and evaluate the service quality results; b) to evaluate and monitor telecommunications carriers infrastructure, investments and manpower to improve service quality; and c) to help the Commission determine best practices? If so how should they be funded and who should administer the contract(s)? ................................................................................................ 34 Question 10: Are competitive market forces sufficient to ensure service quality? What, if any, are the barriers to switching to other services and service providers if a customer is dissatisfied with the quality of wireline telephone service offered by their current provider? .............................................................................................. 36 Barriers to Switching .......................................................................................................................................... 37 Additional Barriers to Switching for Consumers with Disabilities ..................................................................... 42 Question 11: How do carriers prioritize repairs between classes of customers, (e.g., retail vs. wholesale and business vs. residential) types of technologies, and types of services? Should residential service be given top priority for repair due to public safety and universal service obligations associated with residential service? ......43 Question 12: Is the service quality information posted at the Commissions website sufficient to provide consumers with the relevant information to make informed communications service purchasing decisions? ....... 47 Question 13: Should the Commission adopt service quality reporting standards for Wireless carriers? ............... 50 Question 14. Are there cost-effective engineering and design standards available that would prevent or better mitigate the effects of outages due to storms and other disruptions? If so, what are they? ......................... 53 Question 15. Is the wireline network designed and maintained so as to minimize the duration of outages due to catastrophic events? If not, what should be done to rectify that? ................................................................ 53 Question 16. Is the wireline network being properly maintained to serve Californians and the California economy? Is wireline service in California comparable to service in other states that have penalties for failure to maintain service or incentive regulation for service quality?.................................................................................. 53 Question 17. Are there any economic, regulatory, physical, or other barriers or disincentives that stifle or discourage wireline maintenance? What are the consequences of poor wireline maintenance? What can and should be done to foster proper and timely wireline maintenance? ........................................................................ 54
Appendix 1: Generic Calculation of Penalty Mechanism55 Appendix 2: Appendix 2: AT&T and Cox 3rd Quarter 2011 Service Quality Reports..56 Attachment 1: Dr. Roycrofts Vitae
I.
Statement of Qualifications
1. My name is Trevor R. Roycroft. My business address is 51 Sea Meadow Lane, Brewster, MA, 02631. I am an independent consultant providing economic and policy analysis related to telecommunications, public utility, and information technology industries. With regard to my educational background, I hold three degrees. I received a Bachelor of Arts degree in Economics with a minor in Statistics from California State University, Sacramento. The degree was awarded with honors. I also received a Masters and Doctor of Philosophy in Economics from the University of California, Davis. My Ph.D. fields of specialization are Economic Theory, Industrial Organization, Public Sector Economics, and Economic History. 2. I have twenty years of experience in the public utility field. My experience began with my employment at the Indiana Office of Utility Consumer Counselor (OUCC) during the years 1991 to 1994. For most of my tenure at the OUCC, I was Chief Economist. My primary areas of analytical responsibility at the OUCC related to telecommunications regulation and policy. 3. I have been involved in higher education related to the telecommunications field. From 1994 to 2004, I was a professor in the J. Warren McClure School of Communication Systems Management at Ohio University. At Ohio University I was granted tenure and promoted to Associate Professor in the spring of 2000. My primary areas of teaching responsibility were graduate and undergraduate courses covering regulatory policy, the economics of the telecommunications industry, consumer issues with telecommunications markets, and telecommunications technology. I left Ohio University to pursue consulting on a full-time basis at the end of 2004. 4. I have published research in refereed journals including The Journal of Regulatory Economics, Contemporary Economic Policy, and Telecommunications Policy. I have contributed chapters that have been published in book volumes related to the telecommunications field. I have
provided referee service to various academic journals including: The Journal of Regulatory Economics, Telecommunications Policy, Social Science Computer Review, Utilities Policy, Journal of Economic Studies, and Communications of the Association for Information Systems. 5. I have provided analysis and testimony as an independent consultant since 1994. In my role as a consultant, I have addressed a wide variety of issues including: incentive regulation plans, costof-service studies, cost modeling, service quality, merger review, and competition. I have filed testimony, reports, and affidavits before state regulatory commissions, before the Federal Communications Commission (FCC), and before the Canadian Radio-Television and Telecommunications Commission. I have also provided expert services in class action lawsuits associated with the public utility field. 6. I have extensive experience with regard to the matters the Commission is considering in this Order Instituting Rulemaking (OIR). I have published research on telephone company service quality.1 I have provided expert testimony and/or analysis regarding service quality issues in cases involving CenturyLink, Frontier, Verizon, Embarq, Windstream, D&E Systems, SBC, and Ameritech. With regard to SBC and Ameritech, I presented testimony before the Indiana Utility Regulatory Commission regarding the service quality crisis experienced by Ameritech Indiana following SBCs acquisition of that company. Ultimately that case was settled, with one of the provisions being that SBC would pay for a management audit of its Indiana operations. On behalf of some of the settling parities, I worked with the management consulting firm that performed a management audit of SBC Indiana, and provided extensive review of the consultants work product on behalf of my clients.2 With regard to other matters raised in the OIR, I have prepared competition analysis in numerous proceedings. I have provided expert services in class action lawsuits related to the wireless industry. Working with AARP, I have
Trouble Reports as an Indicator of Service Quality: The Influence of Competition, Technology, and Regulation. Telecommunications Policy, Volume 24, No. 10, November, 2000. 2 My clients were AARP, Citizens Action Coalition of Indiana, and United Senior Action of Indiana.
1
drafted model consumer-protection legislation directed at wireless markets. A copy of my curriculum vitae is provided as Attachment 1 to this Affidavit. 7. I was asked by TURN, Center for Accessible Technology and National Consumer Law Center3 (Consumer Group) to evaluate service quality issues raised in the OIR, focusing on the URF carriersAT&T, Verizon, Frontier, and SureWest. To prepare this Declaration I reviewed the Commissions GO 133-C service quality rules, and the previous GO 133-B rules. In addition, I reviewed the service quality data available on the Commissions web site. I also reviewed service quality rules in other jurisdictions. 8. I prepared discovery, which was served by TURN on each of the URF carriers on January 3, 2012. As of the date of filing this Declaration, TURN has received only partial responses from AT&T, Verizon, and Frontier, with the bulk of Frontiers partial response, and much of Verizons response, arriving on January 30, 2012. SureWest has responded to all TURN data requests on a timely basis. 9. With regard to discovery issues, TURN has also been informed by AT&T that it will not respond to any data requests regarding AT&Ts U-Verse deployment, indicating that U-Verse is irrelevant and has no bearing on this proceeding.4 As will be discussed below in detail, information regarding AT&Ts U-Verse (and Verizons FiOS) is central to the issues before this Commission. II. Introduction and Overview A. The Objectives of the OIR 10. The OIR raises a number of important issues relating to the quality of telecommunications services in California. The OIR begins by addressing the key responsibilities of the Commission:
The National Consumer Law Center has not signed the Non-Disclosure Agreements. NCLC has not reviewed the confidential portions of this Declaration. 4 E-mail message from Ramiz Rafeedie to Bill Nusbaum, January 27, 2012.
3
The Commission has a statutory duty to ensure that telephone corporations provide customer service that includes reasonable statewide service quality standards including, but not limited to, standards regarding network technical quality, customer service, installation, repair and billing.5 With regard to the extent of its responsibilities, the Commission also makes clear that it considers wireless service quality to fall within the scope of this rulemaking.6 The OIR offers the following statement of purpose: This OIR is opened to review the performance of telecommunications corporations in meeting GO 133-C service quality performance standards in 2010-2011, and to assess whether service quality measures adopted in D. 09-07-019/GO 133-C: Meet the goals of the service quality measures (i.e., ensure that telecommunications carriers provide the level of service required by P.U. Code 451); Provide consumers with relevant information to make informed communications service purchase decisions; Are relevant to todays regulatory environment and market; Need additional measures and/or penalty mechanisms added; and Should be revised to cover wholesale interconnection services as well as retail. If so, what revisions should be made?7 The OIR also poses seventeen additional questions. This Declaration will address those questions in detail. Before turning to that discussion, a brief response to the OIRs statement of purpose is provided: The current service quality regime is not meeting the goals required by P.U. Code 451. The GO 133-C standards are not sufficient given the level of competition facing carriers, and this is borne out by data indicating that Californias two largest ILECs, AT&T and Verizon, are generally non-compliant with service quality metrics associated with GO 133-C. As will be discussed below, AT&T and Verizon have implemented a two-tier service performance and network investment regime, where customers served on their
5 6
OIR, p. 2. OIR, p. 14. 7 OIR, pp. 12-13.
advanced service platforms are given superior attention than those who do not purchase advanced services. With regard to the issue of information provided to consumers that might enable informed choices, the current approach is insufficient. With regard to wireline carriers, the information gathered through the GO 133-C reporting process is posted on the CPUC web site in a format that generally reflects the carriers data submission worksheets. The format of this information is not user friendly, limiting its usefulness to consumers. With regard to wireless carriers, the current GO 133-C standards require that carriers make coverage maps available, however, there are no standards regarding the accuracy of these maps, and consumers ability to make accurate side-by-side comparisons of carrier coverage is limited. Furthermore, on other important issues that affect wireless service qualitysuch as dropped calls, voice quality, and data throughputno reliable information is available to the public. The Commission should work with consumer groups and an information design specialist to develop an informative representation of service quality information for both wireline and wireless carriers. Distilling service quality information into a graphical presentation formatusing side-by-side comparisons with graphics and color that convey carrier performance provides a superior approach to the current presentation method. The OIR poses the question of whether service quality standards are relevant in todays environment. The risks and hardships suffered by California consumers during the extensive outages in late 2010 and early 2011 provide ample evidence that enforceable service quality standards continue to be relevant in todays market and regulatory environment. If competition were effective, consumers would simply switch providers when their carrier cannot deliver reliable service. The customer loyalty exhibited by
consumers who stood by their carrier during an extended outage is a strong indicator of the lack of customer choice. o Furthermore, while it is certainly true that alternative telecommunication platforms exist, consumers of wireless, over-the-top VoIP, and cable-based VoIP services are also harmed when ILEC customers experience outages. Voice telephone service is subject to network effects, i.e., the value of the service is greater with a larger number of consumers connected to the network. ILEC service outages decrease the network effects, and harm consumers on all communication platforms. o This Commission has an obligation to ensure that the vital telecommunication services provided over the PSTN perform at a high level of reliability. The health and safety of the public, as well as economic opportunities, depend on high quality telecommunications services provided over the PSTN. With regard to additional service quality measures and penalty mechanisms, as is discussed in more detail below, the Commission should enhance both the preparedness of telecommunications service providers during emergency situations, and hold regulated telecommunications service providers accountable for their performance during normal operating conditions. Penalty mechanisms should be re-imposed for the URF ILECs. Yes, wholesale service quality should also be addressed. At a minimum, existing wholesale service quality standards should be enforced. In addition, in the course of its investigation of the performance of telecommunications companies under G.O. 133-C service quality standards, the Commission must also address the incentives that ILECs have to maintain and invest in their legacy copper networks. Telephone service quality is affected by inadequate maintenance and investment. For example, in
summarizing the problems experienced by ILECs with regard to phantom 911 calls, the legislative analysis noted that Telephone corporations and the 911 County Coordinator Task Force reports that public service access points sometimes receive 911 calls that are triggered by damaged or aging lines, weather, or other causes.8 If lines are aging or damaged to the extent that phantom 911 calls are being triggered, this raises issues related to maintenance and investment. The Commission must assess these factors to determine whether the root cause of the general lack of compliance with service quality standards, as well as the extensive outages that occurred during late 2010 and early 2011, lies in a lack of sufficient resources being devoted to these carrier networks. B. Management Choices Regarding Investment and Service Quality 11. Table 1 summarizes the service quality performance of the URF ILECs for the first three quarters of 2011 with respect to the out-of-service restoration standard.
Table 1: Repair tickets restored 24 Hours, URF ILECsCPUC Standard, 90% (Shaded Cell Indicates Compliance with Commission Standard)
Jan SureWest Frontier Verizon AT&T 96.4% 75.6% 93.9% 56.3% Feb 86.7% 78.4% 62.0% 57.5% Mar 95.3% 81.7% 61.9% 57.7% Apr 96.9% 80.0% 74.1% 62.3% May 95.1% 85.1% 77.2% 70.1% Jun 93.6% 79.4% 75.9% 63.4% Jul 97.0% 83.1% 69.2% 72.7% Aug 91.9% 85.9% 74.2% 71.1% Sep 95.5% 86.4% 69.9% 74.5%
12. Table 1 shows that other than SureWest, the URF ILECs are missing this service quality measure month-after-month, and sometimes by a wide margin. AT&T and Frontiers performance shows some improvement over the course of the year, while Verizons show no discernible trend. What is clear from Table 1 is that the Commissions standard is achievable; SureWest shows high levels of service quality performance. It may be argued that SureWest can achieve its high level of service quality due to its relatively small size. However, evidence obtained through
8
Bill Analysis, SB 1375, June 28, 2010. Assembly Committee on Utilities and Commerce, Steven Bradford, Chair. http://www.leginfo.ca.gov/pub/09-10/bill/sen/sb_1351-1400/sb_1375_cfa_20100625_140146_asm_comm.html
discovery, discussed in detail below, instead points to SureWest maintaining a high degree of attention to the delivery of high quality services to all SureWest customers. As will be discussed in more detail below, evidence associated with AT&T and Verizons operations points to a segmented approach to network investment and service quality performance. AT&T and Verizon provide superior service quality to customers who purchase their advanced services. AT&T and Verizon have evolved to provide what amounts to two separate customer service experiencesone associated with triple-play services using advanced technology, where the carriers maintain a keen focus on customer service, and another for services using legacy technology, where customer service and plant investment has been allowed to degrade. 13. The Commission has increasingly relied on market forces to determine outcomes in California telecommunications markets,9 including the market for basic local telephone service. With regard to service quality issues the Commission has noted: One of the goals of increased competition was to ensure high quality service. A concern was expressed that competition might not be sufficient in all markets to foster high service quality for all consumers.10 The concern over whether market forces are sufficient to guarantee high quality service to all customers is well placed. Telecommunications markets continue to be highly segmented, and this market segmentation makes it more likely that service quality may deteriorate for certain customers. Geographic availability of services varies. The largest URF carriers AT&T and Verizon have deployed their advanced network services (U-Verse and FiOS) in some areas, while in other areas legacy copper plant remains the only ILEC service platform. 14. There is no question that carriers like AT&T and Verizon are making strategic decisions regarding resource allocation within their networks that reflect a new vision for service
The URF Phase I Decision [D.06-08-030], relaxed regulatory oversight of the four largest ILECs with regard to various issues, including pricing. 10 D.09-07-019, pp. 6-7.
16. Carriers like AT&T and Verizon make their capital investment decisions based on a broad view of their operations. AT&Ts Group President and Chief Strategy Officer, John Stankey, recently summarized AT&Ts perspective on investment priorities: So finally, where are we putting your money? How are we investing our capital? And I would tell you that the story for '12 is very much the story that we shared with you in '11. We continue to increase the percentage of our spend and to dedicate it to our Mobility business. We think that's prudent and appropriate. It tracks the revenues. It tracks to where the opportunities are. We expect that we will continue to do that in 2012. We don't expect the overall investment percentages as total revenue for AT&T to change. We still expect we'll be in the mid-teens as a percentage of revenue, but we do expect that we'll be shifting. And a lot of that shift is created by the benefit of the fact that we've largely completed our U-verse build at this point and monies that we are putting toward building that platform and getting this to robust capability in our consumers markets in the most attractive market is now complete.14 Thus AT&T indicates that its overall investment priorities are slanted toward wireless.15 The UVerse build, which covers about 60% of AT&Ts nationwide footprint16 has been halted, with the investment dollars freed up flowing to AT&Ts wireless operations. While it is natural for investments to follow revenues, this Commission must ensure that sufficient investment is made in facilities that continue to provide critical telecommunications services to large numbers of Californians. 17. Markets are also segmented by consumer preferences and income levels. While carriers promote the most comprehensive bundle that their technology is capable of delivering, not all consumers want or can afford high-end bundled services. If ILEC triple-play bundles are linked to service
AT&T's CEO Presents at Citi Global Entertainment, Media & Telecommunications Conference (Transcript), January 5, 2012, emphasis added. Seeking Alpha. http://seekingalpha.com/article/317986-at-t-s-ceo-presents-at-citiglobal-entertainment-media-telecommunications-conference-transcript 15 There is no question that Verizon also considers wireless operations a priority. Goldman Sachs has identified the divestiture of all Verizon wireline assets outside of the enterprise market as a possible path forward. See Verizon Fixed-Line Sale Would Enable Vodafone Combination, Goldman Says, Bloomberg, January 6, 2012. http://www.bloomberg.com/news/2012-01-06/vodafone-lifted-to-buy-at-goldman-sachs-on-verizon-strength.html 16 AT&T nears end of its U-verse service buildout, FierceTelecom, May 20, 2011. http://www.fiercetelecom.com/story/att-nears-end-its-u-verse-service-buildout/2011-05-20
14
10
platforms (like U-Verse and FiOS), then a consumers decision to decline the triple-play option may relegate them to a service platform that receives inferior service quality support.17 18. This outcome is unacceptable, and is inconsistent with 451 of the Public Utilities Code, which the OIR notes requires the provision of an adequate level of service. However, 451 also requires that rates be just and reasonable: All charges demanded or received by any public utility, or by any two or more public utilities, for any product or commodity furnished or to be furnished or any service rendered or to be rendered shall be just and reasonable. Every unjust or unreasonable charge demanded or received for such product or commodity or service is unlawful.18 Service quality standards are essential for the satisfaction of this provision of the Public Utilities Code. Given that consumers of the URF ILECs have experienced increasing basic rates at a time when service quality performance has been consistently substandard, the proposition that these rates are just and reasonable is difficult to support. C. Issues Raised by the March 2011 Communications Division Report 19. The OIR references the March 2011 Communications Division (CD) Report as an indicator of service quality problems facing California consumers. The CD Report points to two distinct sets of service quality issues(1) problems that occurred during the storms in late 2010 and early 2011, and (2) URF carriers consistently failing to meet the Commission G.O. 133-C service quality standards. 20. The CD Report addresses the service outages that occurred in Southern California in late 2010 and early 2011. These service outages affected large numbers of customers, with some experiencing out-of-service conditions for extended periods. While the service outages present a dramatic example of service quality problems, the ongoing failure of carriers to meet the
17
AT&T and Verizon do not migrate a customer onto their advanced service platform until the customer chooses to take the advanced services. This leads to some consumers residing in the same general area being served by either the legacy copper facilities or the advanced service platform. 18 Public Utilities Code, 451.
11
Commissions service quality objectives is equally troubling as the problems that emerged during the emergency conditions of late 2010 and early 2011. 21. The general problem is most pronounced among the URF ILECs, with the two largest URF carriersAT&T and Verizonleading the pack in poor service quality performance. Where data is available, some reporting CLECs show substandard performance. However, as illustrated in data presented in Telepacifics reports, customers of CLECs that rely on inputs from ILECs are harmed by poor ILEC service quality performance. While the GRC ILECs fail to meet some standards, their performance generally tends to be superior to the URF ILECs. 22. The ongoing failure to restore service in line with the Commissions requirements has been a chronic problem for the URF ILECs, even absent the emergency conditions that existed following the heavy rains. On an ongoing basis, thousands of California consumers are facing extended delays in service restoration. According to data filed with the Commission, during the first nine months of 2011, outside of any emergency conditions, over 190,000 customers of the URF ILECs, primarily AT&T customers, were out-of-service for a period greater than 24 hours. These customers who experienced out-of-service conditions during the first nine months of 2011 do not include any of the customers who were out-of-service due to the rain events that occurred during that period. 23. The CD Report also identifies several problems with the current service quality reporting framework: There are different interpretations regarding calculating out of service intervals and the treatment of excludable events in the calculation (e.g., count all repairs made 24 hours, even those made during excluded events, but exclude from the calculation the service restoration times > 24 hours made during an excluded event). There is a lack of specificity as to when a state of emergency ends, introducing subjectivity in calculating results.
12
There are differing interpretations on whether a state of emergency constitutes an exemption for reporting anything for the entire company for one or more months, i.e., should a state of emergency definition be similar to a catastrophic event (e.g., 3% of total company access lines). Some carriers like, Verizon, include non-voice grade results (data/video) with small business and residential trouble tickets as well as out of service repair tickets that are only supposed to include voice services. Not all carriers provided raw data. The details in raw data do not contain sufficient specificity for staff to replicate carrier calculations. AT&T did not provide complete raw data that corresponded to the total number of outage tickets reported. Some carriers did not report data for each service quality measure.19
These observations point to troubling issues associated with the Commissions service quality regime. For example, service quality reporting should be consistently implemented by all reporting carriers. The CD report indicates that different carriers report data based on alternative interpretations of the requirements. Inconsistency of reporting undermines the effectiveness of service quality standards. The CD report also indicates that different carriers interpret states of emergency differently, with subjective interpretations of the end of the emergency conditions. This ambiguity in carrier reporting, especially when it may be in the carriers self-interest to extend the reporting emergency beyond the existence of emergency conditions, is also a significant problem with the current service quality regime. Finally, carriers have different interpretations of the reporting requirements in 4(b)(i) of GO 133-C, which states: In cases where large numbers of customers are impacted or that are otherwise of great severity, a telephone report should be made promptly. AT&T maintains no records of this communication, while Verizon does.20
19 20
CD Report, pp. 12-13. AT&T Response to TURN Set 1, request 1-5. Verizon response to TURN Set 1, request 1-5.
13
24. The CD report also states that carriers are mixing voice and non-voice services in their service quality reports. The reporting regime should be corrected so that reports on voice services are not mixed with non-voice services. The CD report further points to incomplete filings and the failure to provide raw data. Carrier provision of raw data is essential for verification of carrier reports and a full assessment of carrier performance. Likewise, if carriers are simply not filing the required reports, then there is no possibility of monitoring carrier performance. For service quality reporting to serve its purpose, the metrics by which carriers are measured must be consistently applied by all firms subject to the requirements. As will be discussed in more detail below, the problems illustrated in the CD report require immediate remedy. D. Summary 25. The service quality problems experienced by AT&T and Verizon should be deeply concerning to the Commission. The legacy portions of these carriers networks continues to serve a vital function in California, providing access to critical health and safety services, and enabling CLEC competition that benefits California business users. The Commission must determine the impact of discriminatory practices with regard to network investment and service quality provision. The provisions of the Public Utility Code require that high quality services be provided to all ILEC customers, not only those who have the desire and wherewithal to purchase high-end services.
III.
Response to OIR Questions
Question 1: Are the adopted GO 133-C service quality standards appropriate and reasonable? If not, should new service quality standards be adopted or should existing standards be modified or eliminated? 26. Response to Question 1: In D.09-07-019 the Commission concluded:
14
Consistent with the general agreement of the parties that competitive environments act to apply a natural pressure for carriers to ensure adequate service quality, it is reasonable to simplify the existing reporting requirements.21 This assessment resulted in faith in market forces to deliver high quality services to all consumers. As discussed above, market forces have led the states two largest carriers to target their service quality efforts on customers being served on their advanced platforms, leaving customers on their legacy networks to experience substandard performance. While the GO 133C service quality standards for the URF carriers might provide a reasonable set of reporting requirements for companies that have a demonstrated commitment to providing good service quality, they are not sufficient for companies that are neither committed to providing high quality services, nor facing sufficient competitive pressure to do so. As a result, the Commission should retain the GO-133 C standards, and impose increased reporting and penalties. The following additions should be made to the current GO 133-C service quality standards: Trouble reportsService Affecting (SA), Out-of-Service (OOS), and repeat SA and OOS trouble reports should be separately reported. If any wire center exceeds the Commissions existing surveillance standard (which is based on the wire centers size), for more than two months in a twelve-month period, then a report should be filed with the Commission detailing remedial actions taken or planned. Answer Timethe current reporting arrangement requires that monthly data be collected quarterly and reported annually. This reporting structure is unreasonable. Monthly reporting should be required, with data published at least on a quarterly basis showing the performance during the months of the quarter. Customer complaintsthe number of customer complaints received by the carrier from customers should be reported monthly The URF Carriers are currently not required to file information regarding installation intervals and installation commitments met. The Commission should extend the GO 133C reporting requirements that currently apply to the GRC ILECs for installation intervals and installation commitments met to the URF ILECs. Customer appointments met. Standards should be set for customer appointments. When an appointment for a service visit is made with a customer for a specific appointment time, and the customers presence is required for establishing new service or repair, the
21
D.09-07-019, p. 2.
15
ILEC service representative will arrive at the agreed upon appointment within 30 minutes before or after the scheduled time. The ILEC will report data on the number of appointments met and the number of appointments missed. Baseline performance penalties. A point-based penalty structure should be imposed to provide compliance incentives to the carriers by imposing monetary penalties. This penalty structure will be discussed in more detail in response to Question 5. Service Guarantees. (1) OOS restoration, for customers that are out of service for more than 48 hours, the ILEC should credit the customer for one months service, measured at the basic service rate. (2) For customers who do not have basic service installed within the five-day period, a credit of $30 should be applied to the customers first monthly bill. (3) For customers with missed installation or repair appointments, a credit of $30 should apply to the customers monthly bill.22 Carriers should be required to file a California-specific emergency response plan. The Commission should issue more detailed instructions regarding overall service quality reporting, and verify that carriers are complying with the Commissions service quality reporting rules.
Additional discussion is provided below regarding service guarantees, the emergency response plan, and Commission instructions regarding service quality reporting. Other points are addressed in the response to other of the Commissions questions. Service Guarantees 27. With regard to service guarantees, recent testimony from Southern California Edison points to the positive impact on company performance provided by service guarantees: Meeting our pledge to our customers related to these guarantees has required a great deal of commitment from our employees and multiple changes to our existing processes. SG223 has
22
The following, where applicable, are exceptions to the ILECs service guarantees described above. (1) There is a Category 1, 2, or 3 Storm Condition. (2) There is a declared Emergency Event. (3) Access to the customers premise is not available or the customer is not ready for service. (4) The premise is not deemed safe. (5) Causes related to force majeure, which include but are not limited to injunction or any decree or order of any court or governmental agency having jurisdiction, strikes or other labor disputes such as lockouts, slowdowns or work stoppages, sabotage, riot, insurrection, acts of public enemy, fire, flood, explosion, earthquake or other acts of God, or accidental destruction of or damage to facilities. 23 SG2 is SCE's commitment to customers that they will restore service within 24 hours of when SCE first becomes aware of a power outage. SG3 promises to notify any affected customer of a planned outage at least three days before the outage occurs. SCE's Transmission and Distribution Business Unit (TDBU) tracks its performance on these two measures and pays customers $30 if SCE does not meet the conditions of the guarantee.
16
required our staff to develop new call-out processes with improved communication methods and better integration with after-hour contract resources. SG3 placed more focus on our endto-end scheduling process by requiring that customer outage notification become a much more formalized and consistent procedure. The service guarantee program encouraged TDBU (Transmission and Distribution Unit) to invest the time and resources to implement concrete fundamental process changes to benefit our customers. SG2 established a greater sense of urgency to the restoration of power during an unplanned interruption. This greater sense of urgency forced TDBU to think in new ways and challenge long held assumptions. For example, TDBU has always been committed to restoring power as quickly as possible, but never fully explored the routine use of contract resources in emergency conditions. It was long believed by many in the organization that during an unplanned outage, using contractors should be minimized as much as possible even if it would result in longer restoration times because it was believed that contractors not intimately familiar with our system would not perform efficiently under emergency conditions. However, we began working with several of our contractors and have been able to identify and develop several who are able to meet our standards. SG3 required full review of our work scheduling process that had been in place for decades. Never before was the impact of a planned outage to the customer so carefully considered and communicated to the operating personnel. What was once an informal process where CCMs made casual contact with customers to discuss power disruptions, became a formal procedure based activity that is now integrated into our everyday routine.24 This discussion points to the beneficial impact of service guarantees. Service guarantees will be discussed in more detail in response to Question 5. Major Service Outages 28. Additional measures should be imposed for major service disruptions that could occur in the carriers California operating territory. All carriers should be required to develop a Californiaspecific emergency response plan that should be submitted to the Commission, and put out for comment in a publicly noticed proceeding.25 Emergency response plans should be reviewed annually. Elements of the emergency response plan should include:
24
Before the Public Utilities Commission of the State of California, 2012 General Rate Case Transmission and Distribution Business Unit (TDBU) SCE-03, Vol. 04 Part 05 & 06, Ch. I-II Witnesses: J. Arencibia, E. Martinez, pp. 114-116. 25 AT&T and SureWest produced documents related to emergency response planning. These documents do not provide a satisfactory emergency response plan. Verizon or Frontier did not produce any documents. See AT&T
17
The development of an outage management system to quickly identify the location and scope of customer outages and schedule outage restoration based on that information. A plan to communicate outage information to the Commission, including protocols as to the appropriate contact individuals, information format, and record-keeping requirements (communication logs). A plan to communicate information to the Community. The carrier should have channels available (local media, local emergency response personnel, carrier outreach/public relations personnel) to provide relevant information before and during the restoration process to customers. The plan should include information on how the carrier will communicate with customers who are difficult to reach, including customers with limited-English proficiency and those who have difficulty using standard forms of communication due to a disability. The plan should detail measures that will be taken to ensure sufficient staffing and management of call centers so that customers receive prompt responses to inquiries. The plan should include measures to ensure ongoing and frequent communications with state and local officials about the extent of the outage and the plan for restoration. The plan should include procedures for supplementing the workforce in the affected area from work force in other areas of the state and/or other states. In addition, carriers should not be exempted from collecting and reporting data during emergency events. The Commission should have ongoing access to data regarding service quality performance. Data provided to the Commission under exempted conditions can be reviewed by the Commission, but withheld from use for compiling compliance statistics.
Consistent Reporting 29. As discussed earlier, the CD report indicates that statistics are not being consistently calculated, and that Carrier reports are not reproducible. It is imperative that service quality reporting be standardized. Action should be taken to ensure that the reporting carriers prepare service quality statistics using a uniform methodology that is applied in the same manner by each carrier. For example, the New York Department of Public Service, Office of Telecommunications, issues
response to TURN Set 1, question 1.2; SureWest response to TURN Set 1, question 1.2; and Verizon response to TURN Set 1, question 1.2.
18
detailed guidelines associated with service quality measurements.26 The GO-133 standards should be augmented to ensure uniform reporting occurs.
Question 2: Should additional Out-of-Service standards be established for Out-of-Service events in excess of 24 hours? 30. Response to Question 2: As discussed above, service guarantees and additional penalties should be added. However, consumers experiencing extended outages should also be provided with an alternative communication device (cell phone), or should be reimbursed for personal cell-phone usage. Communication protocols should be developed that enable reliable communication channels be established with the affected community, including those who have disabilities, who do not speak English, or are difficult to reach, so that consumers, businesses, and public safety personnel are aware of restoration efforts and targets.
Question 3: Why are many of the URF carriers consistently missing the service quality measurement standards for (a) Out-of-Service Repairs, and (b) Answer Times? 31. Response to Question 3: Management Decisions Favor Advanced Service Platforms 32. To answer this question it is necessary to examine business decisions that have affected the operations of the URF carriers. AT&T and Verizon have effectively divided the operations of their companies into advanced and legacy service platforms. AT&Ts advanced service platform is known as U-Verse. Verizons advanced service platform is known as FiOS. These
26
Telecommunications Service Quality Uniform Measurement Guidelines, New York Public Service Commission, Office of Telecommunications, January 27, 2011. http://www3.dps.ny.gov/W/PSCWeb.nsf/96f0fec0b45a3c6485257688006a701a/7f830c1ff90ab31285257687006f38 8d/$FILE/Revised%20Uniform%20Measurement%20Guidelines%20-%20January%2027,%202011%20%20Final%20.pdf
19
Verizon ultimately settled this case, agreeing to a survey of outside plant conditions, and to make timely repairs to plant that was found to be deficient.32 36. In 2008 Verizon responded to a complaint filed by the Florida Attorney Generals office regarding poor service quality by pointing to the benefits that arise due to Verizons fiber to the premises (FTTP) deployment. Verizon stated that it had been: improving its network reliability through the hundreds of millions of dollars invested in its FTTP network. That network improves maintenance and repair performance in part because of the physical properties of fiber, including for example its immunity to moisture, which make the new network less susceptible to outages than the old copper network. Moreover, when outages and troubles do occur on the fiber network, they are easier to diagnose and repair, which shortens the time to restore service and clear troubles. As Verizon continues to extend its FTTP network, and more customers take the FiOS services offered on the network, Verizon's already high network reliability will improve still further.33 37. However, the Florida Public Service Commission did not find Verizons argument to be persuasive. Writing in 2009, the Florida Commission stated: Verizon has indicated that the rate of service line troubles has dropped by almost 95% where the copper network was replaced by fiber. The company also indicated that the FTTP network, in significant part, has contributed to a 34% reduction in out-of-service and service-affecting trouble reports from the fourth quarter of 2005 through 2007. Despite the reduction in out-of-service and service-affecting trouble reports due to the FTTP network, Verizons overall service quality declined during the same timeframe. It is our view that an investment in the FTTP network is not a justifiable reason for Verizons failure to maintain and support its copper network, which currently serves the vast majority of Verizons customers.34 The experience in Florida appears to be very similar to conditions in Californiacustomers served on the FiOS platform experience OOS service quality improvements, while customers served on legacy plant experience a lower level of OOS service quality.
In re Verizon Service Quality in Western Massachusetts, D.T.C 09-1, Settlement Agreement. Response and Answer of Verizon Florida to Joint Petition, In re: Joint Petition for show cause proceedings against Verizon Florida LLC for apparent violation of Rule 24-4.070, FAC., service availability, and impose fines, by the Office of the Attorney General, Citizens of the State of Florida, and AARP, Docket No. 08027S-TL, filed June 9, 2008. http://www.psc.state.fl.us/library/FILINGS/08/04890-08/04890-08.pdf 34 In re: Joint petition for show cause proceedings against Verizon Florida LLC for apparent violation of Rule 254.070, F.A.C., Customer Trouble Reports, and impose fines, by the Office of the Attorney General, Citizens of the State of Florida, and AARP. Docket No. 080278-TL Order No. PSC-09-0015-SC-TL. Order to Show Cause, January 5, 2009, p. 6, emphasis added.
33 32
22
Summary 40. In conclusion on the Commissions question regarding the reason why URF carriers are missing key service quality standards, the answer boils down to management choices. AT&T and Verizon have given priority to customers who purchase their premium services. AT&T and Verizon believe that this is appropriate as they have the ability to challenge cable companies in the triple-play game in areas where they have upgraded their networks. AT&T and Verizon do not believe that they will face market penalties for providing lower quality service to the customers of their non-premium services. Absent penalties from market forces, it is the responsibility of the Commission to ensure that all voice service consumers, regardless of the platform on which they are served, receive high quality service.
Question 4: The current service quality standards and measures focus on retail customers. Should standards be adopted for wholesale service? If so, what should these standards and measures be? 41. Response to Question 4: The Commission established a performance incentive plan (PIP) related to wholesale service quality in D.02-09-050. The Commission later modified that decision in D.08-12-032. This 2008 modification to the PIP resulted in a streamlining of performance standards, and made the application of the PIP an opt in exercise for the CLEC i.e., the PIP must be specified as applying to the CLEC in an interconnection agreement.40 The amended PIP still includes specific non-performance penalties, capped at $15 million per month for all CLECs combined.41 I have been advised by counsel that these wholesale service quality standards are still in effect.
40 41
D.08-12-032, p. 5. D.08-12-032, Appendix, p. 6.
24
42. Service quality standards and reporting requirements for wholesale services continue to be important. Wholesale firms and their customers are adversely affected in the same manner as are the ILECs retail customers. However, the customers of CLECs have another layer of information to confrontis the problem associated with their CLEC provider or with the ILEC's network? Reliable information on the performance of ILEC wholesale offerings will assist retail customers in assessing the performance of their CLEC provider.
Question 5: Is it appropriate to implement a penalty mechanism when standards are not met? If so, what should it be? 43. Response to Question 5: A penalty mechanism, including a set of service guarantees, is appropriate. Service quality penalties provide a deterrent to service quality deterioration. The Commission has found it necessary to impose service quality penalties in the past.42 The experience under the GO 133-C regime, discussed above, indicates that the largest URF carriers are discriminating in their service quality practices. Penalties will redirect these carriers attention to delivering high quality services to all customers. 44. As discussed in the response to Question 1, one component of the penalty mechanism should be the creation of service guaranteesdirect payments made to consumers to compensate them for poor performance. With regard to service guarantees, the following should apply: (1) OOS restorationfor customers that are out of service for more than 48 hours, the ILEC should credit the customer for one months service, measured at the basic service rate plus subscriber line charge. (2) Installationfor customers who do not have service installed within the five-day period, a credit of $30 should be applied to the customers first monthly bill. (3) Missed
42
See, for example, Resolution T-17120, November 1, 2007.
25
installation or repair appointmentsfor customers with missed installation or repair appointments, a credit of $30 should apply to the customers monthly bill.43 45. In addition, a service performance penalty structure is appropriate. The URF carriers, especially AT&T and Verizon, have exhibited substandard performance in some categories of the Commissions standards for extended periods. The performance penalty mechanism recommended uses a service quality index (SQI) that assigns penalty points based on carrier deviation from the Commissions service quality standards. The SQI is based on how the carrier performs vis--vis the Commissions service quality standards. Monthly penalty points are assigned based on the difference between the Commissions standard and the carriers actual performance. For example, with regard to the OOS standard of 90% restored in 24 hours or less, monthly performance by a carrier of 85% restored would result in five (5) penalty points being assigned. 46. The SQI has the following components(1) a benchmark annual penalty; (2) penalty points that are assessed when the carrier is not in compliance with Commission standards; (3) a forgiveness provision for brief periods of non-compliance which are quickly remedied; (4) an OOS offset based on OOS service guarantee payments made; (5) a rebate to customers of the remaining balance of service quality penalties; and (6) an assessment of the impact of the penalty mechanism.
43
The following, where applicable, are exceptions to the utilitys service guarantees described above. (1) There is a Category 1, 2, or 3 Storm Condition. (2) There is a declared Emergency Event. (3) Access to the customers premise is not available or the customer is not ready for service. (4) The premise is not deemed safe. (5) Causes related to force majeure, which include but are not limited to injunction or any decree or order of any court or governmental agency having jurisdiction, strikes or other labor disputes such as lockouts, slowdowns or work stoppages, sabotage, riot, insurrection, acts of public enemy, fire, flood, explosion, earthquake or other acts of God, or accidental destruction of or damage to facilities.
26
Benchmark Annual Penalty 47. The service quality penalty benchmark for each URF carrier should be established at a level that represents a substantial penalty so that the carrier will be provided significant incentives to comply. As noted by the CPUC regarding the performance incentive plan associated with AT&T Californias (then Pacific Bells) performance incentive plan (PIP), service quality penalties should include a potential liability that provides a meaningful and significant incentive to comply with the designated performance standards.44 48. Because the URF carriers have different sizes, the benchmark penalty should be scaled for each carrier, while providing a meaningful and significant incentive to comply with the designated performance standards. Given that each carriers basic rates are known, and given that the service quality reports require access line reports, I believe that each carriers benchmark penalty should be set based on that data, using the following approach: Multiply the year-end access line count by the weighted-average annual basic rate in effect during the year. Then multiply that amount by 4.0% to determine the benchmark penalty. For example, as of the end of the third quarter of 2011, AT&Ts service quality report listed 6,249,528 access lines. For ease of illustration, I will assume that this number of access lines also represents AT&Ts year-end total, and that all customers are residential flat-rate customers, with a monthly rate of $19.95.45 Given these assumptions the annual benchmark penalty facing AT&T for 2011 would be about $60 million.46 While this penalty is substantial, it is proportionally smaller than other recent penalty mechanisms that have been imposed on ILECs. For example, on January 18, 2012, the Vermont Commission reduced FairPoints benchmark
44 45
D.02-09-050. G.O. 133 requires reporting for residential and small business customers. The weighted average annual rate should be based on the relative proportions of residential and small business customers at the end of the reporting year, and the residential and small business basic rates. 46 (Calculated as 4.0 percent of $19.95 x 6,249,528 x 12 = $59.8 million). Of course, in practice the actual year-end total access line count and weighted-average rate would be utilized.
27
annual penalty from $10.5 million to $1.65 million.47 FairPoint Vermont has about 130,000 access lines, i.e., FairPoint Vermont is about 2.4% the size of AT&T California. Thus FairPoints penalty, if scaled by AT&T California line count, would be equivalent to a $438 million penalty under the old Vermont regime, and $68.75 million under the new Vermont regime. Penalty Points 49. To calculate the penalty points the standard for each performance measurement category should be compared to the carriers actual performance, and the difference between the standard and the carriers actual performance should calculated. This difference will reflect the number of penalty points assessed. 50. Service quality performance points should be assessed on a monthly basis for trouble reports and OOS restoration. For answer time, the penalty assessment should be based on the quarterly data reported by the companies. Table 3 shows an example of how penalty points would be calculated. Table 3: Penalty Points and Reporting Period Evaluation Service Quality Category and Period Standard Month Trouble Reports (6 Percent for exchanges with 3,000 or more lines) Quarter Answer Time (80 Percent in Less Than 60 Seconds) Month Out-of-Service Restoration (90 Percent in 24 Hours or Less)
Carriers Reported Performance 2 percent 75 percent 80 percent
Penalty Points None 5 10
47
See, Vermont Public Service Board Docket No. 7724, Petition of Telephone Operating Company of Vermont LLC, d/b/a FairPoint Communications ("FairPoint"), for approval of a Successor Incentive Regulation Plan ("IRP"), pursuant to 30 V.S.A. 226b, January 18, 2012. http://psb.vermont.gov/sites/psb/files/orders/2012/7724%20OrderApprovingSuccessorIncentiveRegPlan.pdf
See also, Docket No. 6959, Investigation into a Successor Incentive Regulation Plan for Verizon New England Inc., d/b/a Verizon Vermont; Docket No. 7142, Investigation into Tariff Filing of Verizon New England Inc., d/b/a Verizon Vermont, in re: Compliance Filing in Docket, 6959, Order Entered April 27, 2006. http://psb.vermont.gov/sites/psb/files/orders/2006/6959_7142fnl.pdf
28
As shown in example in Table 3, if a carriers monthly trouble reports in exchanges with 3,000 or more access lines is 2 percent rather than 6 percent, the service level exceeds the standard, and no points are assigned for that month. If a carriers quarterly speed of answer was 75% in less than 60 seconds rather than the 80% standard, 5 penalty points should be assessed for the quarter. If a carriers monthly OOS restoration was 80%, rather than the 90% standard in a given month, the difference in percentage points should be tallied as penalty points for the monthten (10) in this example. Annual Penalty Assessment 51. The penalty assessment should be conducted on an annual basis, with penalty points calculated on either a monthly or quarterly basis totaled at the end of the yearly evaluation period to assess penalties. Table 4 shows an example using AT&Ts full-year 2010 service quality performance.
Table 4: Hypothetical Penalty Points Using AT&Ts 2010 Service Quality Data Jan 90 50.7 Feb 90 40.2 Mar 90 53.4 Apr 90 38.9 May 90 34.2 Jun 90 32.7 Jul 90 32 Aug 90 54 Sep 90 75.6 Oct 90 66.7 Nov 90 69.6 Dec 90 51.7 Annual Penalty Points
OOS Standard (Percent Restored) AT&T Actual Performance OOS Monthly Penalty Points Trouble Reports Standard 6% 8% 10% 6% Penalty Points 8% Penalty Points 10% Penalty Points Quarterly Answer Time Penalty Points Percent in 60 Seconds or Less Penalty Points
39.3
49.8
36.6
51.1
55.8
57.3
58
36
14.4
23.3
20.5
38.3
480.42
AT&Ts Actual Performance 2.38 3.93 4.85 0 0 0 2.17 3.23 3.97 0 0 0 1.79 2.71 3.27 0 0 0 1.45 2.13 2.79 0 0 0 1.33 1.77 2.14 0 0 0 1.33 1.9 2.25 0 0 0 1.36 1.91 2.76 0 0 0 1.43 1.82 2.26 0 0 0 1.32 1.56 2.1 0 0 0 1.74 2.45 2.92 0 0 0 1.68 2.67 3.47 0 0 0 2.29 3.52 3.83 0 0 0 0 0 0
Standard: 80% in Less than 60 Seconds AT&Ts Actual Performance 1st Quarter 72.8 7.2 2nd Quarter 85.4 0 3rd Quarter 85.7 0 4th Quarter 67.5 12.5 Total 19.7 500.12
29
Application of the Penalty Mechanism 52. I believe that it is reasonable to structure the penalty mechanism so that penalties escalate and generate proportionally higher penalties as service quality performance deteriorates. Table 5 shows the escalating penalty structure, using the $60 million benchmark penalty from the AT&T example. Table 5 shows that penalties are based on the number of points generated by the carrier, and that the dollars per penalty point increase as the carriers service quality deteriorates, as reflected by it earning more points. Appendix 1 shows the formula that result in the values shown in Table 5. Table 5: Example of Penalty Structure Using Data from AT&T to Establish the Benchmark Penalty Annual Points Accumulated Dollars per Point Benchmark Penalty Maximum 1 to 25 $60,000 $1,500,000 26 to 50 $120,000 $4,500,000 51 to 100 $210,000 $15,000,000 101 to 150 $240,000 $27,000,000 151 and Above (to Maximum) $330,000 $60,000,000
Calculating the Penalty 53. Continuing with the AT&T example, Table 4 shows that AT&T would have had accrued 500 penalty points during 2010 if the mechanism had been in place. Using the penalty structure shown in Table 5, the first 25 points would be assessed at $60,000 per point, the next 25 would be assessed at $120,000 per point, the next 50 at $210,000 per point, and the next one-hundred at $330,000 per point, for a total annual penalty of $60 million.48 On the other hand, if AT&T had incurred 50 penalty points during the year, its total penalty would be $4.5 million.49
48
If a carrier were to have much better performance than AT&T, its penalty points would not reach the progressively higher point assessments. 49 I.e., the first 25 points at $60,000 each, and the next 25 points at $125,000 each.
30
Offset Benchmark Penalty by Amount of OOS Service Guarantees 54. For each annual period the Commission may reduce the carriers calculated benchmark penalty by the amount of the service guarantee associated with OOS paid during that same period. The Commission should collect data on all service guarantee payments. Forgiveness for Brief Periods of Substandard Performance 55. It is also reasonable to include a substandard performance forgiveness provision. For trouble reports and out-of-service restoration, if any a carrier drops below the minimum performance standard for any single month, and returns to compliance the following month, and remains in compliance for the balance of the year, then the single-month substandard performance penalty should be forgiven.50 One exemption per service quality performance classification per year should be permitted under the plan. For example, during 2011, up through the third quarter reports, SureWest has satisfied the OOS restoration in all months except February, when it restored 87%, just shy of the 90% threshold. If SureWests performance for the last three months is above the 90% threshold, the February violation would be without penalty. Customer Rebates 56. The penalty dollars should be returned to all customers as an annual rebate, which should appear on customers monthly bill sometime in the first quarter of the year following the assessment. The Commission should require a line-item on the bill labeled Rebate for Substandard Service Quality during the Year 20XX. Evaluation of the Penalty Mechanism 57. If URF carriers do not come into compliance while facing the level of incentive associated with the method described, the Commission should revisit the penalty level in the future.
50
If December was the only month during the year where the carrier fell below the standard, January of the following year should be used to determine whether forgiveness will be allowed. The forgiveness provision does not apply to answer time, as answer time penalty points are assessed using quarterly averages, which gives the carrier a chance to earn forgiveness within the quarterly period.
31
Question 6: Should exemptions be allowed for calculating reported service quality results for States of Emergency, Catastrophic Events and events beyond the control of the utility management? If so, should there be limitations on the geographic area(s) covered and/or the duration of the exemption? 58. Response to Question 6: The exemptions should apply to the calculation of service quality performance metrics alonethe carriers should not be exempted from reporting service quality data for the period during the emergency. Duration should be consistent with the duration of the actual emergency conditions. 59. With regard to emergency situations, the CD report states that there are differing interpretations of what constitutes an emergency, and that there are differing interpretations on whether a state of emergency constitutes an exemption for reporting anything for the entire company for one or more months.51 This lack of consistency is a serious problem that was confirmed by the URF carriers in their responses to discovery. While AT&T, Verizon, and SureWest point to proclamations from the Governors office or other governmental entities as indicating the start of an emergency and its geographic scope, the companies have different interpretations of determining when an emergency is over. AT&T determines the timeframe associated with a declaration of emergency by utilizing supporting information such as rain data, blocked roads, facilities impacted such as cables/pairs, poles, manholes, and the number of opening tickets, daily ticket volumes, which exceed the norm.52 Declarations of emergency issued by the State of California specify the start of the emergency situation, but do not specify when an emergency situation has ended. Verizon determines the "declarations of emergency" to be ended when repair ticket volumes have returned to normal volume levels.53 SureWest believes that a declaration of emergency has ended when it has repaired all trouble related to the emergency and is operating back under normal conditions.54
51 52
CD Report, p. 12. AT&T response to TURN Set 1, question 1.9(c). 53 Verizon response to TURN Set 1, question 1.9(c). 54 SureWest response to TURN Set 1, Question 1.6(c).
32
These responses indicate that subjective criteria are being utilized to determine when an emergency situation ends. For example, this could be remedied by the Commission defining normal trouble ticket volumes to be based on the average monthly trouble ticket volumes experienced by the carrier during the previous twelve month period.
Question 7: Should carriers provide the Commission with additional service quality data in the aftermath of a catastrophic event? If so, what additional data is appropriate? 60. Response to Question 7: Yes. As discussed above, an emergency response plan should be required. Following the emergency, carriers should provide the Commission with a report, supported by appropriate data, regarding how the emergency response plan was implemented, and how the company performed under the emergency response plan. The Commission should develop a full understanding of how carriers performed during the emergency, and should compare and evaluate carrier performance in subsequent emergency situations in light of past emergency performance data. 61. In addition, the carrier should continue to provide the Commission with unadjusted raw data regarding performance vis--vis the standard performance metrics in the affected areas (and throughout the carriers service area) during the period of the emergency. It appears that GO 133C requires this type of reporting. (When reporting includes a delay for one or more months, the carrier shall provide supporting information as to why the month should be excluded and work papers that show the date(s) of the catastrophic event and/or widespread outage and how the adjusted figure was calculated.) 62. The carriers should provide the Commission information regarding the termination of the emergency period. This will require that the carriers internal tracking of the repair ticket volumes and normal repair ticket volume be shared with the Commission. 33
Question 8: What other reporting requirements or measures are appropriate to evaluate quality of service? 63. Response to Question 8: 64. See response to Questions 1 and 2. Question 9: Should the Commission hire a network consultant to: a) review and evaluate the service quality results; b) to evaluate and monitor telecommunications carriers infrastructure, investments and manpower to improve service quality; and c) to help the Commission determine best practices? If so how should they be funded and who should administer the contract(s)? 65. Response to Question 9: Yes, a network consultant should be retained. As discussed elsewhere in this Declaration, there is evidence that AT&T and Verizon have made management decisions to favor their advanced network services. The Commission must develop an understanding of the extent to which the legacy networks of these companies have been affected by the priority that has been given to the advanced services. If inadequate maintenance and investment has led to degradation of copper plant, the extent of the problem must be documented.55 Legacy copper networks continue to provide a vital function. Not only do such networks provide connections to the majority of California households, but copper also serves as a platform for CLECs, which has provided benefits to the business telecommunications market. Copper continues to provide avenues for CLEC broadband innovation, such as Ethernet over copper applications that can economically expand copper loop data carrying capacity.56 66. The network consultant should be charged by the Commission to conduct a thorough evaluation of maintenance and service restoration practices and priorities (both in normal and emergency
55
For example, the Bill Analysis of the Assembly Committee on Utilities and Commerce reported Telephone corporations and the 911 County Coordinator Task Force reports that public service access points sometimes receive 911 calls that are triggered by damaged or aging lines, weather, or other causes. As phantom 911 calls have been a widespread problem, the extent of plant degradation may also be widespread. http://www.leginfo.ca.gov/pub/09-10/bill/sen/sb_1351-1400/sb_1375_cfa_20100625_140146_asm_comm.html 56 See, for example, http://www.telepacific.com/offer/data-network/ethernet-broadband.asp
34
discrimination based on customer location, or the type of technology utilized by the ILEC to provision service. 71. This data also reinforces the fact that outside of those areas where the largest URF carriers have deployed advanced facilities, that other market alternatives to wireline telephone service are not viewed by the URF ILECs as bringing a level of competition that warrants high levels of service quality. Barriers to Switching 72. The OIR asks about barriers to switching to other services and service providers if a customer is dissatisfied with the quality of wireline telephone service. I analyzed California markets for local telephone services in 2009, with TURN publishing the results of the study in a report titled The Limits of Choice in Californias Residential Telecommunications Market.61 In this report I conducted a detailed evaluation of the availability of alternatives to ILEC services in nine California counties,62 with a focus on the CLEC sector, cable VoIP, wireless, and over-the-top VoIP. 73. With regard to the residential CLEC sector, the results of my study revealed a CLEC sector that had declined considerably, and this trend continuesboth the absolute number of CLEC lines and the share of CLEC lines continuing to decline.63 However, it is important to note that the CLEC sector will not contribute in any meaningful way to the market forces associated with important aspects of ILEC service quality performance. Because residential CLECs rely on legacy ILEC facilities to provide their services, they may lack control over key service quality elements, including the general quality of network facilities, and the restoration of services
61 62
Available at: http://turn.org/article.php?id=840 Alameda, Fresno, Humboldt, Los Angeles, Madera, Sacramento, San Bernardino, Santa Clara, and Shasta. Approximately 48 percent of Californias population resides in these counties. 63 Based on review of resale and UNE-based lines reported by the FCC at http://transition.fcc.gov/wcb/iatd/comp.html. See, Selected RBOC Local Telephone Data.
37
following service outages. As a result, the Commission cannot assume that the CLEC sector will deliver beneficial competitive pressure on the level of service quality provided by ILECs. 74. Cable VoIP services offer another alternative. I reevaluated cable VoIP service offerings in the same market areas that I used in the 2009 study, and found general conditions to be little changed.64 Most consumers continue to have a wireline voice alternative from their cable company, however, cable companies generally push bundled triple-play services, and only Cox (the cable provider serving a relatively small geographic footprint in the southern portion of the state), offers stand-alone voice services. Comcast, the cable provider that has the largest footprint in the state, does not offer stand-alone basic voice service. It is the triple-play capability of the cable operators that AT&T and Verizon have addressed with their advanced network service offerings. As mentioned above, it appears that the rivalry between cable and the advanced ILEC services in the triple-play market segment have provided incentives for targeted service quality priorities on the part of AT&T and Verizon. 75. Verizons recent announcement that it has entered into a joint marketing agreement with cable companies may have a significant impact on competition in service areas where Verizon operates. If Verizon and cable companies jointly market one anothers products, there will be little incentive for competition between these entities. 76. The remaining alternatives to ILEC-provided basic service are wireless mobility services and over-the-top VoIP services. Turning first to wireless mobility services, it is critical to understand that wireless service quality is based on a fundamentally different proposition than is wireline service quality, and there is little reason to expect that the presence of wireless services will pressure the URF ILECs to offer high quality voice services.
64
The most notable exception being the deployment of voice services by Charter Communications in Santa Clara County. In 2009 cable VoIP was unavailable in the Gilroy and Morgan Hill areas. Charter now offers VoIP services in these areas.
38
77. Under their current service offering format, wireless providers do not guarantee that wireless service will work in any specific location, including a customers residence. If wireless service presents out-of-service conditions due to terrain, foliage, structures, weather, being indoors, etc., it is incumbent upon the user to relocate to an area where a signal is available. There is no trouble ticket to be filed, no customer service representative to be contacted. It is the responsibility of the customer to remedy the problem. This approach to service quality performance is fundamentally different than that of wireline services. As a result, it is unreasonable to expect that wireless mobility services will provide pressure on URF ILECs to maintain high levels of service quality. The data from the largest URF ILECs, discussed above, shows that for services other than their triple-play-capable advanced platforms, these carriers do not set high priorities for service restoration, and consistently fail to meet service quality standardseven though wireless services are widely available. If the availability of wireless services provided a competitive check on wireline service quality, this outcome would not be expected. 78. Furthermore, wireless services tend to be used in a complementary fashion by the overwhelming majority of Californiansmost households continue to purchase both wireline and wireless services. The most recent data from the National Health Interview Survey shows that California has one of the lowest rates of cord cutting in the nationabout 18.2% of California households have cut the cord, as compared to the national average of 26.6%. Table 6 summarizes NHIS data for the 2009-2010 period, the most recent state-level data available.65
65
Wireless Substitution: State-level Estimates From the National Health Interview Survey, January 2007June 2010, Stephen J. Blumberg, Julian V. Luke, Nadarajasundaram Ganesh, Michael E. Davern, Michel H. Boudreaux, Karen Soderberg, April 20, 2011. http://www.cdc.gov/nchs/data/nhsr/nhsr039.pdf
39
Table 6: Wireless-Only Households in California Area July 2009June 2010 California (Statewide) 18.2 Alameda County 17.4 Fresno County 21.5 Los Angeles County 17.0 Northern Counties66 18.1 San Bernardino County 18.1 San Diego County 18.4 Santa Clara County 17.7 Rest of California 18.8
The data in Table 6 show a relatively tight clustering of cord-cutting across the California counties studied. Fresno County is the outlier, with cord-cutting rates in the range of four to five percentage points above the statewide average, but still below the national average. The data in Table 6 suggest that the overwhelming majority of California households do not find wireless service to be a reasonable substitute for wireline voice services. In Limits of Choice report I concluded that with regard to wireless services: (1) for a limited subset of the population, a wireless phone can replace wireline, (2) for a large segment of consumers, wireless is used in a complementary fashion with wirelineboth services are purchased, (3) for the overwhelming majority of households with any telephone service, the value of functions provided by a wireline telephone leads to the purchase of this service, and (4) the economic downturn may lead to more households abandoning wireline out of economic necessity. I believe that this continues to be a reasonable assessment of the impact of wireless services on competition, and that as a result there is little reason to believe that the presence of wireless services will lead to ILECs to deliver high quality services. 79. The CPUC Staff Report on Affordability of Telephone Service also emphasizes the continuing importance of wireline service. On a statewide basis, of the households subscribing to landline,
66
Includes Del Norte, Siskiyou, Modoc, Lassen, Shasta, Trinity, Humboldt, Mendocino, Tehama, Plumas, Butte, Glenn, Colusa, Lake, and Sierra.
40
24% of the households are landline only, and 76% subscribe to both landline and wireless. In CHCF-B areas only 13% of households rely solely on landline and 87% of households subscribe to both landline and wireless services. Similarly, statewide Lifeline subscribers rely upon landline-only service more so than those in CHCF-B areas. Of the statewide survey households subscribing to LifeLine, 49% have wireless, while 83% of the non-LifeLine customers have wireless.67 80. Over-the-top VoIP services are also a possible alternative for some consumers. Data indicate that the popularity of over-the-top VoIP has waned in recent years, as cable VoIP expanded its presence. For example, Vonage, the largest over-the-top VoIP provider, notes as follows regarding its main rivals: Cable companies and, in many cases incumbent phone companies, are also aggressively using their existing customer relationships to bundle services. For example, they bundle Internet access, cable television, and home phone service with an implied price for the phone service that may be significantly below ours.68 81. Vonage has seen its U.S. nationwide customer base shrink from about 2.47 million in 2008 to 2.25 million in 2010.69 Vonages business model depends on the willingness of the consumer to avoid the bundle. For some consumers this may be a desirable alternative, however, the evidence indicates that it is in the triple-play product space where URF ILECs are making significant investments, and targeting their service quality performance. 82. Given that over-the-top VoIP requires that consumers avoid a bundle that includes telephone service, it seems unlikely that this alternative technology is exerting much competitive pressure
67
Staff Report to the California Legislature Affordability of Basic Telephone Service Pursuant to Senate Bill 780 (Chapter 342, Statutes 2008; amending Public Utilities Code 739.3 and adding 275.6), introduced by Senator Wiggins and coauthored by Senators Cox and Kehoe, September 30th, 2010, p. 14, Table 12. 68 Vonage 10-K for the year ending December 31, 2010, p. 7. 69 Vonage form 10-Ks for the years ending December 31, 2008 and December 31, 2010, p. 2.
41
on the service quality of non-triple-play voice offerings of the URF ILECs.70 The evidence uncovered through discovery indicates that the largest URF ILECs are targeting higher levels of service quality at their triple-play offerings provided over their advanced network platforms. There is no evidence that over-the-top VoIP is a sufficient competitive threat to result in high quality ILEC services. 83. Finally, it also should be noted that the services that consumers purchase from URF ILECs may be under a term contract, with penalty for breach. Customers under contract are less likely to switch in response to service quality problems. Additional Barriers to Switching for Consumers with Disabilities 84. For certain demographic subgroups, such as consumers with disabilities, the limitations of competitive market forces as a mechanism for ensuring service quality are even more severe. When the Commission reviewed the state of competition in the telecommunications market as part of the URF proceeding, advocates representing customers with disabilities presented substantial uncontested evidence that providers did not compete for these customers.71 Specifically, Disability Rights Advocates (DisabRA) presented uncontested evidence that people with disabilities did not receive high quality services or support;72 at the same time, people with disabilities are particularly vulnerable in that they are disproportionately low income and reliant on telecommunication service to all them to live independently.73 Nevertheless, as demonstrated
It is difficult to assess the absolute level of service quality provided by over-the-top VoIP providers. However, the existence of web sites such as We Hate Vonage . com provide some indication that these carriers are less than perfect. http://www.wehatevonage.com/ 71 See generally Opening Brief of Disability Rights Advocates, filed in R.05-04-005 on March 3, 2006, the supporting testimony of Dmitri Belser and Stephanie Cox and the other materials provided by DisabRA in that proceeding. 72 See URF Opening Brief of Disability Rights Advocates at pp. 5-7 (describing problems with inadequate training for customer service representatives regarding the special needs of customers with disabilities and the lack of available information about disability-related services and products). 73 See URF Opening Brief of Disability Rights Advocates at pp. 7-9 (describing how people with disabilities rely on consistent access to telecommunication service to ensure their safety and well being, and to participate more fully in society).
70
42
by DisabRA, telecommunication service providers do not compete for disabled customers74 and service providers do not offer adequate accessible or disability-related services and products because they perceive the disability market to be unattractive.75 No service provider contested the showing by DisabRA that there was a crisis in California regarding the accessibility affordability and reliability of telecommunications services for people with disabilities and that specific regulatory protections were needed in response. In fact, at the time, AT&T Californias expert witness agreed that targeted regulations would be appropriate to meet the needs of customers with disabilities.76 85. As discussed above, wireless cord cutting may provide an alternative choice for some. For individuals with disabilities, such as people with cochlear implants, the ability to use new wireless telephone technologies may be limited.77 Thus, the ability to switch to (or even use) wireless telephony may also be limited. Wireless 911 services, while improved over earlier versions, are still less reliable than wireline 911 services. Doubts about the reliability of 911 may deter a disabled person from cutting the cord. The Commission should recognize the additional limits of choice facing the disabled community, and this communitys continuing dependence on reliable wireline services.
Question 11: How do carriers prioritize repairs between classes of customers, (e.g., retail vs. wholesale and business vs. residential) types of technologies, and types of services? Should
See URF Opening Brief of Disability Rights Advocates at pp. 12-14 (lack of intramodal competition since CLECs and smaller wireline service providers do not provide the same level of accessible service as ILECs, even while ILEC service have significant room for improvement); id. at pp. 14-20 (lack of intramodal competition due to multiple constraints on availability and accessibility of wireline and VoIP). 75 See URF Opening Brief of Disability Rights Advocates at pp. 20 (service providers view the disability market as unprofitable because customers are disproportionately low-income or more expensive to serve). 76 Harris Testimony, URF Hearing Transcript at 475:20-476:4, cited in URF Opening Brief of Disability Rights Advocates at p. 4. 77 J. Simpson, Inclusive Information and Communications Technologies for People with Disabilities, published in Disability Studies Quarterly, Winter 2009, available at http://dsq-sds.org/article/view/167/167 .
74
43
alternative service providers must have access to multiple software packages, capable of reading both Excel and PDF files. Once they open the file they are presented with a complex table that provides little context regarding what the standards are that a consumer might be interested in, or how to interpret the information. 94. I have attached Appendix 2, which contains print-outs of the reports for Cox and AT&T, two wireline facilities-based carriers that have overlapping service territories, thus enabling a consumer choice opportunity. A review of Appendix 2 shows tables that contain multiple rows of information for each service quality performance measure. Some of the rows are data, others contain the results of calculations based on the data, thus making it difficult for the consumer to discern which row contains the actual service quality metric. Furthermore, some of the service quality measures reported are likely to be more relevant to consumers than are others. For example, a carriers average out-of-service restoration time and the carriers performance with regard to the Commissions out-of-service restoration standard of 90% restored within 24 hours are likely to resonate much more with consumers than are the statistics on trouble reports. The current presentation does not provide an informative presentation. 95. A third concern with the Commissions service quality information is that it excludes information that would be relevant to a customers evaluation of alternative providers. As mentioned earlier, there is no easy way for a consumer to determine which alternatives are available in their geographic location. There is also no information regarding services provided by facilities-based VoIP providers who have opted out of the CPUCs jurisdiction. 96. Fourth, for those carriers that are listed, there is no information on customer complaints. Information regarding the number of customer complaints for a carrier would be a valuable data point.
48
97. Finally, as discussed elsewhere in this declaration, information on wireless carrier performance should also be presented on the Commissions web site. 98. A presentation method based on side-by-side graphics will generate a much more informative presentation of service quality data.83 For example, I created the charts below that compare AT&T and Coxs performance regarding the average duration of a service outage, and the carriers performance associated with the service restoration standard. The graphic presentation is offered with a brief explanation, but a more detailed and plain language discussion should also be provided. For example, the following text could accompany the charts: The California Public Utilities Commission has set a standard for restoring telephone service90% of out-of-service conditions within a 24-hour period. In addition, the CPUC collects data on the average length of telephone service outages. The performance of Cox and AT&T is compared in the two figures below:
Figure 1: AT&T and Cox Average Service Outage Interval (2011). Lower Numbers Indicate Better Performance.
Sep Aug Jul Jun May Apr Mar Feb Jan 0 10 20 30 40 50

Average Hours
AT&T Cox
83
The Commission should also work with representatives of the disability community to ensure that information can be accessed by individuals who rely on assistive technology such as screen readers.
49
Figure 2: AT&T and Cox Percent of Service Outages Restored in 24 Hours (2011). Higher numbers are better, Commission standard of 90% or greater.
Sep Aug Jul Jun May Apr Mar Feb Jan 0% 10% 20% 30% 40% 50% AT&T 60% Cox 70% 80% 90% 100%
Question 13: Should the Commission adopt service quality reporting standards for Wireless carriers? 99. Response to Question 13: Yes, the widespread adoption of wireless services has resulted in wireless service becoming a necessary component of modern life. Wireless carrier claims regarding call quality, data speeds, service reliability and coverage are difficult for consumers to evaluate, short of purchasing service from a carrier and testing the product in multiple locations. As a result, the Commission should adopt wireless service quality reporting standards. 100. The direct impact of wireless service quality standards will not benefit wireless mobility
customers alone. As discussed earlier, telecommunications services are subject to network effectsthe value of the service expands with the number of subscribers using the network. The interconnected nature of voice networks also leads to a service quality spillover. Consumers using the wireline network are affected by the service quality levels on wireless networks. If
50
wireless networks are characterized by dropped calls, poor voice transmission, and difficulty in establishing connections, all callers who are connected to the wireless portion of the PSTN (i.e., wireline and wireless) suffer the consequences. 101. In Comments filed in R.02-12-004 TURN referenced a set of service quality standards
based on those applied by the Singapore Infocomm Development Authority (IDA).84 These test areas and standards continue to provide a reasonable set of service quality metrics: Call success rate this refers to the number of successful calls established over the total number of mobile call attempts (target: over 95%). Service coverage (street level) this is based on signal strength and refers to the network's ability in achieving a signal strength of -100 dBm or better during the mobile call holding period (target: over 95%). Voice quality - this refers to the network's ability in achieving an acceptable level of voice quality using the Mean Opinion Score (MOS) measure and is a complementary indicator to the service coverage indicator (target: at least a 2 annoying but not objectionable on a 5 point scale). Call drop-out this refers to the unintended disconnection of mobile calls by the network during a 100-second call-holding period for each call (target: below 5%).85
102.
However, given the growing importance of data mobility services (and confusing carrier
claims regarding the performance of their data service offerings), adding standards and testing associated with data services also makes sense. Reporting information on the average data throughput speeds of wireless carriers would provide consumers with valuable information regarding the performance of wireless broadband mobility services. 103. To implement reporting, the Commission should require wireless carriers to submit their
own network test information. Wireless carriers produce test information as part of their normal course of business. Wireless carriers conduct frequent drive tests that utilize computer84
The Singapore IDA has since added additional data collection and reporting on text message and data transmission metrics, as well as customer complaints. See, http://www.ida.gov.sg/Policies%20and%20Regulation/20060424141236.aspx 85 TURN Comments in R. 02-12-004, April 1, 2003.
51
automated equipment that tests for signal strength, call completion, voice-call quality using MOS standards,86 dropped calls, and data network speeds. For example, AT&T describes its drive testing efforts as follows: AT&T technicians and other third-party vendors will drive nearly 30 million miles to test AT&Ts wireless network this year the equivalent of more than 50 round trips to the moon to ensure AT&T is delivering the best coverage and quality. Hundreds of technicians from third-party testing companies, infrastructure vendors and AT&T technicians will use specially designed vehicles to travel throughout the country and test the signal strength and coverage of AT&Ts ALLOVERTM Network. Along with drive-testing its own network, AT&T drive-tests competitors networks to ensure that its coverage and quality are equal to or better than other companies providing service in the area. The drive-test results help to prioritize where the company invests in new cell sites and equipment that enhances the network quality and coverage.87 While AT&T may travel the equivalent of 50 round trips to the moon while testing its network, wireless service quality data might as well be on the moon as far as consumers are concerned. The Commission should take steps to disseminate the service quality tests performed by carriers. 104. As noted by AT&T, wireless carriers conduct tests not only of their own networks, but of
their wireless rivals networks.88 Thus, the Commission, by obtaining data from a single wireless carrier could gain information regarding the performance of multiple wireless carriers. 105. If the Commission were to obtain test data from wireless carriers, there would be
relatively little additional cost in processing the information; the cost of gathering the information is part of the wireless carriers normal operating expenses. The Commission should work with wireless carriers to develop a data submission process, with the Commission organizing the data into a standardized format for generating reports. However, as was the case with the wireline service quality data discussed above, the format of the data reports is critical to
86
Mean opinion score (MOS) is a test used in telephony networks to obtain the human user's view of the quality of the network. MOS testing is now automated, and the MOS provides a numerical indication of the perceived quality of a call. 87 http://www.att.com/Common/merger/files/pdf/wirelessnetwork/network-glance.pdf 88 The testing of multiple networks during a Verizon drive test is summarized in a video at: http://www.youtube.com/watch?v=CxM9e2zGjdA
52
conveying usable information to consumers. Presenting comparative metrics in graphical format, and enabling side-by-side comparison of carrier performance by geography would be the preferred approach to summarizing performance statistics. 106. As recognized by the G.O. 133-C standards, another key element of consumer protection
associated with wireless service is the production of accurate coverage maps by wireless telecommunications providers in the state. However, the G.O. 133-C standards do not go far enough. The Commission should develop standardized maps that allow side-by-side comparisons among wireless carriers in the geographic areas that they operate. Using carriergenerated information on signal strength, the Commission could produce coverage maps that could be accessed through the Commission web site that would illustrate carrier performance.
Question 14. Are there cost-effective engineering and design standards available that would prevent or better mitigate the effects of outages due to storms and other disruptions? If so, what are they? 107. Response to Question 14: See response to question 9.
Question 15. Is the wireline network designed and maintained so as to minimize the duration of outages due to catastrophic events? If not, what should be done to rectify that? 108. Response to Question 15: See response to question 9.
Question 16. Is the wireline network being properly maintained to serve Californians and the California economy? Is wireline service in California comparable to service in other states that have penalties for failure to maintain service or incentive regulation for service quality? 109. Response to Question 16: See response to question 9.
53
Question 17. Are there any economic, regulatory, physical, or other barriers or disincentives that stifle or discourage wireline maintenance? What are the consequences of poor wireline maintenance? What can and should be done to foster proper and timely wireline maintenance? 110. Response to Question 17. See discussion above. Economic incentives have led carriers
to favor their advanced service platforms, while providing insufficient resources to ensure highquality services for their legacy services. Service quality penalties will provide incentives to foster proper and timely wireline maintenance.
54
Appendix 1: Generic Calculation of Penalty Mechanism The carriers maximum penalty is calculated by multiplying the weighted average basic rate for residential and small business customers by the number of access lines. This value is then annualized by multiplying by 12. The maximum penalty is then used in the penalty table. The table below shows the formula needed to populate the penalty table, with the maximum penalty that appears in the lower right cell being the only data needed to generate all values. Generic Penalty Structure Points Accumulated Dollars per Point 1 to 25 26 to 50 51 to 100 101 to 150 151 and Above (to Maximum) (e)/25 ((d) - (e))/25 ((c) - (d))/50 ((b) - (c))/50 ((a) - (b))/100
Benchmark Maximum Penalty (e) 2.5% of the Maximum Penalty (d) 7.5% of the Maximum Penalty (c) 25% of the Maximum Penalty (b) 45% of the Maximum Penalty (a) Maximum Penalty (Access Lines x Basic Rate)
55
Appendix 2: AT&T and Cox 3rd Quarter 2011 Service Quality Reports
56
California Public Utilities Commission Service Quality Standards Reporting General Order No. 133-C
Company Name: Reporting Unit Type:
Total Company
AT&T California
Exchange Wire Center
U#:
U-1001-C
Report Year: Total Company - Statewide
2011
Reporting Unit Name:
Measurement (Compile monthly, file quarterly)

Installation Interval Min. standard = 5 bus. days Installation Commitment Min. standard = 95% commitment met Customer Trouble Report Total # of working lines 6% (6 per 100 working lines for Total # of trouble reports units w/ 3,000 lines) % of trouble reports Total # of working lines 8% (8 per 100 working lines for Total # of trouble reports units w/ 1,001 - 2,999 lines) % of trouble reports Total # of working lines 10% (10 per 100 working lines Total # of trouble reports for units w/ 1,000 lines) % of trouble reports Total # of outage report tickets Total # of repair tickets restored in < 24hrs Out of Service Report % of repair tickets restored 24 Hours Min. standard = 90% within 24 hrs Sum of the duration of all outages (hh:mm) Avg. outage duration (hh:mm) Min. Standard Total # of business days Total # of service orders Avg. # of business days Total # of installation commitments Total # of installation commitment met Total # of installation commitment missed % of commitment met Jan N/A N/A N/A N/A N/A N/A N/A
Date filed (05/16/2011) 1st Quarter Feb N/A N/A N/A N/A N/A N/A N/A
Mar N/A N/A N/A N/A N/A N/A N/A
Apr N/A N/A N/A N/A N/A N/A N/A
Date filed (08/15/2011) 2nd Quarter May N/A N/A N/A N/A N/A N/A N/A
Jun N/A N/A N/A N/A N/A N/A N/A
Jul N/A N/A N/A N/A N/A N/A N/A
Date filed (11/15/2011) 3rd Quarter Aug N/A N/A N/A N/A N/A N/A N/A
Sep N/A N/A N/A N/A N/A N/A N/A
Oct N/A N/A N/A N/A N/A N/A N/A
Date filed (02/15/yy) 4th Quarter Nov N/A N/A N/A N/A N/A N/A N/A
Dec N/A N/A N/A N/A N/A N/A N/A
6,848,232 6,773,133 6,701,965 6,618,647 188,658 104,397 123,701 89,575 2.75 1.54 1.85 1.35 195,870 194,225 191,851 196,313 8,540 5,117 6,126 4,458 4.36 2.63 3.19 2.27 51,756 51,262 51,810 51,468 2,369 1,507 1,875 1,386 4.58 2.94 3.62 2.69 42,072 57,950 57,300 48,867 23,670 33,334 33,069 30,430 56.3% 57.5% 57.7% 62.3% 2,048,053 1,508,854 1,545,756 1,212,037 48.7 26.0 27.0 24.8
6,533,054 6,465,819 6,376,972 6,313,338 6,249,528 79,420 77,462 76,595 78,667 74,445 1.22 1.20 1.20 1.25 1.19 193,122 195,674 199,855 194,409 195,912 3,450 3,731 3,673 3,335 3,030 1.79 1.91 1.84 1.72 1.55 52,026 50,699 50,271 51,885 51,587 1,149 1,294 1,227 1,072 1,096 2.21 2.55 2.44 2.07 2.12 48,485 50,492 46,669 48,300 45,711 33,976 32,019 33,927 34,332 34,054 70.1% 63.4% 72.7% 71.1% 74.5% 981,537 1,144,330 882,405 961,263 850,169 20.2 22.7 18.9 19.9 18.6 1st Quarter Not due until 2012 Not due until 2012 Not due until 2012 2nd Quarter Not due until 2012 Not due until 2012 Not due until 2012 3rd Quarter Not due until 2012 Not due until 2012 Not due until 2012 4th Quarter Not due until 2012 Not due until 2012 Not due until 2012
Measurement (Compile quarterly, file annually on February 15) Total # of calls for TR, Billing & Non-Billing Answer Time (Trouble Reports "TR", Billing & Non-Billing) Total # of call seconds to reach live agent Min. standard = 80% of calls 60 seconds to reach live agent (w/ a menu option to % 60 seconds reach live agent)
Primary Utility Contact Information
Name: Adela Chan Date Adopted: 7/28/09 Date Revised: 12/08/09 (Corrects typographical errors) Date Revised: 05/04/10 (Added new lines and changed terms to reflect requirements of G.O.133-C)
Phone: 415-778-1470
Email: ac2517@att.com
California Public Utilities Commission Service Quality Standards Reporting General Order No. 133-C
Company Name: Reporting Unit Type: Cox California Telcom, L.L.C.
Total Company Exchange Wire Center
U#:
5684-C
Report Year: Cox California Telcom, L.L.C.
2011
Reporting Unit Name:
Measurement (Compile monthly, file quarterly)

Jan Installation Interval Min. standard = 5 bus. days Installation Commitment Min. standard = 95% commitment met Customer Trouble Report Total # of working lines Total # of trouble reports % of trouble reports Total # of working lines 8% (8 per 100 working lines Total # of trouble reports for units w/ 1,001 - 2,999 lines) % of trouble reports Total # of working lines 10% (10 per 100 working lines Total # of trouble reports for units w/ 1,000 lines) % of trouble reports Total # of outage report tickets Total # of repair tickets restored in < 24hrs Out of Service Report % of repair tickets restored 24 Hours Min. standard = 90% within 24 hrs Sum of the duration of all outages (hh:mm) Avg. outage duration (hh:mm) Min. Standard 6% (6 per 100 working lines for units w/ 3,000 lines) 676,882 12,972 1.9% Total # of business days Total # of service orders Avg. # of business days Total # of installation commitments Total # of installation commitment met Total # of installation commitment missed % of commitment met
Date filed (05/16/11) 1st Quarter Feb
Mar
Apr
Date filed (08/15/11) 2nd Quarter May
Jun
Jul
Date filed (11/15/11) 3rd Quarter Aug
Sep
Oct
Date filed (02/15/yy) 4th Quarter Nov
Dec
676,042 10,565 1.6%
673,552 12,524 1.9%
671,983 11,304 1.7%
668,730 12,088 1.8%
665,310 12,701 1.9%
662,931 12,728 1.9%
657,839 12,778 1.9%
653,481 13,182 2.0%
3127 2832 91% 25574:50 8:11
2515 2333 93% 19970:33 7:56
3090 2925 95% 21445:31 6:56
2872 2697 94% 18868:26 6:34
3442 3309 96% 18972:18 5:31
3528 3339 95% 20758:36 5:53
3644 3418 94% 24153:39 6:38
3474 3262 94% 20644:02 5:56
3600 3287 91% 25690:37 7:08 3rd Quarter 4th Quarter
Measurement (Compile quarterly, file annually on February 15) Total # of calls for TR, Billing & Non-Billing Answer Time (Trouble Reports "TR", Billing & Non-Billing) Min. standard = 80% of calls 60 seconds to reach live agent (w/ a menu option Total # of call seconds to reach live agent % 60 seconds to reach live agent)
1st Quarter
2nd Quarter
Primary Utility Contact Information
Name: Marcie Evans Date Adopted: 7/28/09 Date Revised: 12/08/09 (Corrects typographical errors) Date Revised: 05/04/10 (Added new lines and changed terms to reflect requirements of G.O.133-C)
Phone:
(858) 836-7313
Email: Marcie.Evans@cox.com
Verification
The statements in the foregoing document are true of my own knowledge, except as to matters which are therein stated on information or belief, and as to those matters I believe them to be true. I declare under penalty of perjury that the foregoing is true and correct. Executed on January 31, 2012 at Brewster, Massachusetts.
____________________________________
Attachment 1: Dr. Roycrofts Vitae
Trevor R. Roycroft
51 Sea Meadow Lane Brewster, MA 02631 508-896-0151 trevor@roycroftconsulting.org www.roycroftconsulting.org Education Ph.D., Economics, University of California, Davis, 1989. M.A., Economics, University of California, Davis, 1986. B.A., Economics, with honors, California State University, Sacramento, 1984. Ph.D. Fields of Specialization Industrial Organization and Regulation Public Finance Economic History Experience Independent Consultant, June 1994 to present. Provides economic and policy research and analysis for clients. Presents expert testimony in state and federal venues. Performs economic and statistical studies of market conditions. Evaluates economic and policy issues in public utility, telecommunications, and information technology industries. Develops economic and policy recommendations. Matters addressed include market structure analysis and competition, merger evaluation, low-income programs, broadband policy, pricing plans, alternative regulatory frameworks, productivity growth, service quality, automatic metering infrastructure, smart grid deployment, cost calculations, cost allocation, cost modeling, network unbundling, capital costs, wireless markets, and economic damages. Lecturer, Fall 2006. Telecommunication Systems Management program in the Graduate School of Engineering at Northeastern University, Boston, MA. Conduct graduate seminar titled Perspectives on Telecommunications Policy: Governments, Markets, and Technological Change. Associate Professor, J. Warren McClure School of Information and Telecommunication Systems, Ohio University, September 1994 to November 2004. Granted tenure, Spring 2000. Conducted graduate and undergraduate courses in regulatory policy and law, and the economics of the telecommunications industry, as well as general education courses covering telecommunications technology, markets, policy, and the social impact of communications technology. Conducted research with a focus on the telecommunications industry. Provided academic advising to graduate and undergraduate students within the school and across the university. Served on department, college, and university committees. Interim Director, J. Warren McClure School of Information and Telecommunication Systems, Ohio University, July 2000 to June 2002. Responsibilities included: program planning, evaluation, and assessment; recruiting faculty and staff; managing fiscal resources; administering the Schools curriculum; and establishing and maintaining relationships with internal and external constituencies of the school.
Experience (continued) Chief Economist/Acting Chief Economist/Assistant Chief Economist/ Principal Economist, Indiana Office of Utility Consumer Counselor, May 1991 to June 1994. Conducted research and prepared testimony, cross examination, and legal briefs to be presented before the Indiana Utility Regulatory Commission in major cases involving gas, water, electric, and telecommunications utilities. Prepared analysis and comments to be presented before the Federal Communications Commission. Advised Director of Utility Analysis and the Utility Consumer Counselor on policy issues; assisted in formulation of policy. Coordinated technical analysis in major cases. Presented agency policy positions to outside groups. Supervised Economics and Finance Staff of eight professionals. Reviewed and provided extensive analysis of Economics and Finance Staff testimony. Visiting Assistant Professor, Kenyon College, September, 1989 to May, 1991. Conducted courses in Introductory Economics (Macro and Micro), Economics of the Public Sector, Industrial Organization, and Economic Development in the Third World. Rendered college service on award and hiring committees. Lecturer, California State University, Sacramento, Fall 1987, academic year 1988. Conducted courses in Intermediate Microeconomic Theory, Introductory Macroeconomic and Microeconomic Theory. Teaching Assistant, University of California, Davis, 1985-1988. Assisted the professor in conducting courses in Introductory Macroeconomic Theory, Introductory Microeconomic Theory, and Public Finance. Publications Low-Income Reality Check, Evaluating the Impact of Dynamic Pricing, Public Utilities Fortnightly, March 2011, Volume 149, No. 3. E-Auctioning: The U.S. Federal Communications Commission and Spectrum Management. Electronic Government: Concepts, Methodologies, Tools, and Applications, Ari-Veikko Anttiroiko, ed. Information Science Reference, New York, 2008. Empirical Analysis of Entry in the Local Exchange Market: the Case of Pacific Bell. Contemporary Economic Policy, Vol. 23, No. 1, January 2005. Internet Access. Johnson, D. ed. Encyclopedia of International Media and Communications, Academic Press, April 2003. Internet Subscription in Africa: Policy for a Dual Digital Divide. (With Siriwan Anantho.) Telecommunications Policy, Vol. 27, Nos. 1-2, February/March 2003. The Impact of State and Federal Alternative Regulation Plans on the RBOCs--a State Level Analysis. in Telecommunications for the 21st Century. Special issue of The International Journal of Development Planning Literature. William Baumol and Victor Beker eds. Vol. 16, Nos. 1 & 2, January and April 2001. Trouble Reports as an Indicator of Service Quality: The Influence of Competition, Technology, and Regulation. (With Martha Garcia-Murrilo.) Telecommunications Policy, Volume 24, No. 10, November, 2000.
Publications, Continued The Telecommunications Act--Law of Unintended Consequences? Public Utilities Fortnightly, Volume 138, No. 3, February 1, 2000. Alternative Regulation and the Efficiency of Local Exchange Carriers--Evidence from the Ameritech States. Telecommunications Policy, Volume 23, No. 6, July, 1999. The Billy Goats Gruff. A Fairy Tale for the Third Anniversary of the Telecommunications Act of 1996. Info: The Journal of Policy, Regulation and Strategy for Telecommunications, Information and Media, Volume 1, No. 2, April, 1999. A Dynamic Model of Incumbent LEC Response to Entry Under the Terms of the Telecommunications Act of 1996. Journal of Regulatory Economics, Volume 14, November, 1998. Ma Bells Legacy: Time for a Second Divestiture? Public Utilities Fortnightly. Vol 136, No. 12, June 15, 1998. The Telecommunications Act of 1996: An Unfunded Mandate for the States. (With Phyllis Bernt.) Central Business Review, Volume XV, No. 2, Summer 1996. Reports and White Papers Review of the Structure Group Report on PG&Es Smart Meter Debacle, Prepared for The Utility Reform Network (TURN), April 8, 2011. The Impact of Dynamic Pricing on Low Income Consumers: Evaluation of the IEE Low Income Whitepaper, November 29, 2010. Available at: http://www.roycroftconsulting.org/Roycroft_Dynamic_Pricing_Low_Income_11-29-10.pdf The Limits of Choice in Californias Residential Telecommunications Markets: Why Competition is Failing to Protect Consumers, March 25, 2009. Available at: http://www.turn.org/article.php?id=839 Reverse Auctions for Universal Service Funding?, February 1, 2008. Available at http://www.roycroftconsulting.org/Roycroft_Consulting_Auction_White_Paper_2-1-08.pdf Evaluating Telecommunications Trends: Commission Responsibilities in Evolving Markets. Policy White Paper Prepared for the Public Counsel Section of the Washington State Office of Attorney General, September 5, 2007. Economic Analysis and Network Neutrality: Separating Empirical Facts from Theoretical Fiction, May 2006. Available at: http://www.freepress.net/docs/roycroft_study.pdf Network Neutrality, Product Differentiation, and Social Welfare. A Response to Phoenix Center Policy Paper No. 24. Roycroft Consulting Policy White Paper. May 3, 2006. Available at: http://www.roycroftconsulting.org/response_to_Ford.pdf
Reports and White Papers (Continued) Network DiversityA Misguided Policy. A Response to Christopher S. Yoos Promoting Broadband Through Network Diversity. Roycroft Consulting Policy White Paper. March 1, 2006. Available at: http://www.roycroftconsulting.org/response_to_Yoo.pdf Wireless Consumer Protection: A Model Bill for the States. AARP Research Center, September, 2003. The End of Telecommunications? An Epilogue to Tangled Web: The Internet and Broadband Open Access Policy. AARP Research Center, June, 2002. Available at: http://www.aarp.org/research/ppi/cons-prot/telecom/articles/aresearch-import-123-2002-10.html Tangled Web: The Internet and Broadband Open Access Policy. AARP Research Center, January, 2001. Available at: http://www.aarp.org/research/ppi/cons-prot/telecom/articles/tangled_web__the_internet_and_broadband _open_access_policy.html Conference Papers The Impact of State and Federal Alternative Regulation Plans on the RBOCs--a State Level Analysis, July 1999. Presented at the Western Economic Association International Annual Meeting, San Diego, California. The Billy Goats Gruff. A Fairy Tale for the Third Anniversary of the Telecommunications Act of 1996, June, 1999. Presented at the Academic Seminar at the 1999 National Cable Television Association Convention, Chicago, Illinois. Alternative Regulation and the Efficiency of Local Exchange Carriers--Evidence from the Ameritech States. November, 1998. Presented at the 68th Annual Conference of the Southern Economic Association, Baltimore, Maryland. A Dynamic Model of Incumbent LEC Response to Entry Under the Terms of the Telecommunications Act of 1996. July 1998. Presented at the Western Economic Association International Annual Meeting, Lake Tahoe, Nevada. Do We have the Bugs Out of Telephone Deregulation? April 1998. Presented at the Law and Policy Division of the Broadcast Education Association, Las Vegas, Nevada. The Telecommunications Act of 1996 and Imposed Costs in the Local Exchange Market: A Dynamic Model of Incumbent Behavior. September 1997. Presented at the Telecommunications Policy Research Conference, Arlington Virginia. Towards an Advanced Information Infrastructure, August 1995. Presented to the National Association of Regulatory Utility Commissions' Annual Regulatory Studies Program at Michigan State University. Sorting, Bonding, and Barriers to Entry: Strategies of the Entry Concerned Firm, July 1990. Presented at the Western Economic Association Meetings, San Diego, California. 4
Additional Presentations Dynamic Pricing: An Idea Whose Time has Come or a Ticking Time Bomb? National Energy and Utility Affordability Conference, June 2011. Fort Lauderdale, FL. Regulatory Response to Rising Residential Rates. Presented at the Mid-Year Meetings of the National Association of Utility Consumer Advocates. June 2009. Boston, MA. Overview of Technology Transformation in the PSTN. Presented at the 2008 Annual Meetings of the National Association of Utility Consumer Advocates. November 2008. New Orleans, LA. Economics and Network Neutrality. Presented at the 2006 Mid-year Meetings of the National Association of Utility Consumer Advocates. June 2006. Memphis, TN. Consumer Education and Telecommunications Competition. Presented at the 2006 Mid-year Meetings of the National Association of Utility Consumer Advocates. June 2006. Memphis, TN. Broadband Open Access. Presented to AARPs National Legislative Council. October, 2000. Washington, D.C. Telecommunications Policy, Markets, and RegulationWhos On First? Presented to the Maryland Office of Peoples Counsel and Maryland Public Service Commission. October, 2000. Baltimore, MD. Broadband Open AccessImplications for the Internet and Consumers. November 1999. Panelist at the National Association of Utility Consumer Advocates Annual Convention. San Antonio, Texas. Validation of Proxy Cost Models. January 1997. Panel discussant at the Federal Communications Commission workshops on proxy cost models (CC Docket 96-45). Impact of the Telecommunications Act of 1996 on Telecommunications Managers. December 1996. Presented to members of the Association of Telecommunications Professionals. Columbus Ohio. Caveat emptor! Local competition, possible effects on prices and the reality of choice. October 1995. Presented at the Public Information Session on Telephone Competition. Dayton, Ohio. Cost Allocation in Network Industries, August 1995. Presented to the National Association of Regulatory Utility Commissions' Annual Regulatory Studies Program at Michigan State University. Incremental Cost Methodology in Telecommunications, June 1995. Presented to the Ohio Office of Consumers' Counsel. Regulatory Issues Connected with the Implementation of the Clean Air Act Amendments of 1990, August 1993. Presented at the Indiana Bar Association's Utility Law Section Summer Meetings. Consumer Perspectives on the Ameritech Customer's First Plan, August 1993. Presented at the Ameritech Regional Regulatory Committee Ad Hoc Working Group Meeting. Consumer Perspectives on Universal Telecommunications Service, December 1992. Presented at the Indiana Utility Regulatory Commission Workshops on Regulatory Flexibility in Telecommunications.
Honors Competitive paper finalist. The Academic Seminar at the 1999 National Cable Television Association Convention, Chicago, Illinois. Paper title: The Billy Goats Gruff. A Fairy Tale for the Third Anniversary of the Telecommunications Act of 1996. Courses Taught Perspectives in Telecommunications Policy: Governments, Markets, and Technological Change Northeastern University Competition and Market Structure in Network Industries, Ohio University Communication Regulatory Policy, Ohio University Applications of Common Carrier Regulation, Ohio University Introduction to Common Carrier Regulation, Ohio University Introduction to Communication Systems Management, Ohio University Consumer Issues in Communication Systems Management, Ohio University Topical Seminar (New Technologies and Telecommunication Policy), Ohio University Topical Seminar (The Telecommunications Act of 1996), Ohio University Special Studies in Communication Systems Management, Ohio University Economics of the Public Sector, Kenyon College Industrial Organization, Kenyon College Economic Development in the Third World, Kenyon College Intermediate Microeconomics, California State University, Sacramento Microeconomic Principles, Kenyon College; California State University, Sacramento Macroeconomic Principles, Kenyon College; California State University, Sacramento College and University Service Faculty Advisor, University College, Ohio University, 1998-2004 Member, Baker Fund Committee, Ohio University, 2003-2004 Member, College of Communication Curriculum Committee, Ohio University, 2003-2004 Chair, College of Communication Deans Evaluation Committee, Ohio University, 2003-2004 Faculty Advisor, Communication Week, Ohio University, 1994-2002 Faculty Advisor, Students in Communication Systems Management, Ohio University, 1994-1996 Member, University General Education Review Committee, Ohio University, 1998-1999 Member, College of Communication Curriculum Committee, Ohio University, 1998-2000 Member, College of Communication Graduate Committee, Ohio University, 1997-2002 Member, University Calendar Review Task Force, Ohio University, 1996-1997 Member, Outstanding Civil Service Award Committee, Ohio University, 1995-1996 Member, Mathematics Department Search Committee, Kenyon College, 1990-1991 Member, Williams Memorial Award Committee, Kenyon College, 1989-1991 Professional Membership American Economic Association Institute of Electrical and Electronics Engineers
Ph.D. Dissertation Supervision The Examination of Strategic Interactions in One Local Access Telephone Market, the Effects on Expected Price for Access and Universal Access. Judith Ann Molka-Danielsen. School of Information Sciences, Telecommunications Program, University of Pittsburgh, 1998. Referee Service Journal of Regulatory Economics Journal of Economic Studies Telecommunications Policy Southern Economic Journal Social Science Computer Review Utilities Policy Communications of the Association for Information Systems Expert Testimony Presented California (On behalf of The Utility Reform Network [TURN]) CPUC Cause No. Investigation 11-06-009 (July 6, 2011) (August 29, 2011) Rulemaking 09-06-019 (March 19, 2010) Rulemaking 06-06-028 (June 24, 2008) Rulemaking 05-04-005 (March 30, 2007) Title Investigation of AT&Ts Proposed Acquisition of T-Mobile Topic Market definition, market concentration, spectrum management, merger impact.
Order Instituting Rulemaking into the Review of the California High Cost Fund B Program Order Instituting Rulemaking into the Review of the California High Cost Fund B Program Order Instituting Rulemaking to Assess and Revise Regulation of Telecommunications Utilities Review of the California California High Cost Fund B Program Review of Telecommunications Public Policy Programs Verizon/MCI Merger
Reverse auction evaluation. Alternative support mechanism.
Reverse auctions for universal service funding.
Post-deregulation monitoring.
Rulemaking 06-06-028 (October 16, 2006) Rulemaking 06-05-028 (September 15, 2006) Application: 05-04-020 (August 15, 2005)
Approach to Calculating High Cost Funding.
Affordability of Basic Service.
Market Structure and Market Power.
California (On behalf of The Utility Reform Network [TURN]) Continued. CPUC Cause No. Rulemaking 05-04-005 Direct Declaration (May 31, 2005) Reply Declaration (September 2, 2005) Applications: 01-02-024, 01-02-035 02-02-031, 02-02-032 02-02-034, 02-03-002 (February 7, 2003) Reply Declaration (March 12, 2003) Rebuttal Declaration Rulemaking 93-04-003 Investigation 93-04-002 (Phase II) (July, 2001) Rulemaking 93-04-003 Investigation 93-04-002 (Phase I) (June, 2001) Title Order Instituting Rulemaking to Assess and Revise Regulation of Telecommunications Utilities Topic Local exchange Competition and Policy.
Review of UNE Rates
TELRIC Compliance of UNE Rates. Progress of local exchange competition.
Permanent Line Sharing Phase II
Pricing and Cost Allocation for the High Frequency Portion of the Local Loop in the NGDLC Environment.
Permanent Line Sharing Phase I
Pricing and Cost Allocation for the High Frequency Portion of the Local Loop.
Canadian Radio-Television and Telecommunications Commission (On Behalf of Action Rseau Consommateur, et al.) CRTC Case No. Public Notice CRTC 2006-5 (July, 2006) Public Notice CRTC 2001-37 (August, 2001) Title Review of Price Cap Framework Price Cap Review and Related Issues Topic Price Cap Plan, Productivity and Advanced Services, Competition.
Price cap regulation and productivity growth. Accommodative entry policy.
Colorado (On behalf of AARP) CPUC Docket No. 04A-411T (February, 2005) Title In the Matter of Qwest Corporation Application Topic Analysis of local exchange market. For Service Reclassification and Deregulation.
Indiana (On behalf of the AARP and Citizens Action Coalition of Indiana) IURC Cause No. 42405 (October, 2003) Title SBC Indianas Request for Alternative Regulation Topic Analysis of local competition, Price Cap Regulation and Productivity. Service Quality Performance.
41911 (July, 2001)
Commissions Investigation of Ameritech Indiana Service Quality
40785-S1, 40849, 41058 (January, 2001) 41058 (August, 2000)
Approval of Settlement Agreement between Ameritech and other Parties Agreement between Ameritech And other Parties
Alternative Regulation, Advanced Services Deployment, Service quality. Cost of Service, Cost Modeling, Compliance with 254(k)of the Telecommunications Act of 1996. Economic Cost of Service/ Cost Allocation.
40785-S1 (September, 1999)
Commissions Investigation Ameritech Indianas Compliance With Section 254(k) of the Telecommunication Act
40849 (November, 1997)
Commissions Own Motion On Ameritech Indianas Request for Interim Relief Ameritech Indiana Request for Interim Relief
Interim and Permanent Alternative Regulation/Rate Design. Interim Alternative Regulation/Rate Design.
40849 (September, 1997)
Kansas (On behalf of the Citizens Utility Ratepayer Board [CURB]) KCC Docket No. 05-SWBT-997-PDR (May, 2005) Title In the Matter of SWBTs Application for Price Deregulation of Certain Residential and Business Services Topic Analysis of local exchange market.
Maryland (On behalf of the Maryland People's Counsel) MPSC Docket No. 8730 (Direct Testimony, October, 1996) (Rebuttal Testimony, November, 1996) 8715 (Direct Testimony, (March, 1996) (Rebuttal Testimony, April, 1996) Title Bell Atlantic ISDN Tariff Proposal Topic ISDN pricing and cost of service.
MCI Request for Alternative Regulation for Bell Atlantic Maryland
Price Cap Regulation, Cost Allocation and Loop Cost Recovery.
Ohio (On behalf of the Ohio Consumers Counsel) PUCO Case Nos. 10-2387-TP-COI (December, 2010) 09-454-TP-ACO (October, 2009) 07-829-GA-AIR et al. (June, 2008) 06-1013-TP-BLS (October, 2006) Title Investigation into Intrastate Access Reform Frontier/Verizon Merger Approval Dominion East Ohio Gas Rate Case AT&T Ohio Request for Alternative Regulation For Basic Local Exchange Cincinnati Bell Request for Alternative Regulation For Basic Local Exchange Service Topic Intrastate Access Charge Reform
Evaluation of Proposed Frontier/ Verizon Merger Automatic Meter Reading, Prudency of Investment. Competition for Basic Local Exchange Service.
06-1002-TP-BLS (September, 2006)
Competition for Basic Local Exchange Service.
10
Ohio (On behalf of the Ohio Consumers Counsel, continued.) PUCO Case Nos. 05-13050TP-ORD (December, 2005) (March, 2006) Title Implementation of H.B. 218 Concerning Alternative Regulation of Basic Local Exchange Service. SBC Ohios TELRIC Costs for Unbundled Network Elements SBC/Ameritech Request for Approval of Merger Topic Existence of entry barriers. Appropriate competitive test.
02-1280-TP-UNC (May, 2004)
TELRIC cost modeling, Local Competition.
98-1082-TP-AMT (December, 1998)
Sharing of cost saving. Total factor productivity growth.
96-899-TP-ALT (December, 1997)
Cincinnati Bell Alternative Regulation MFS INTELENET
Price Cap Regulation/ Rate Rebalancing/ Rate Design. Financial, Managerial, and Technical Ability to Provide Local Exchange Service. Incremental Costs/ Fully Distributed Costs/ Alternative Regulation.
94-2019-TP-ACE (May, 1995)
93-487-TP-ALT and 93-576-CSS (September, 1994)
Ohio Bell: Alternative Regulation
Pennsylvania (On behalf of the Pennsylvania Office of Consumer Advocate) PPUC Docket No. Docket No. P-2011-2218683 Direct Testimony March, 2011 Docket No. P-2011-2224781 Direct Testimony April, 2011 Docket No. A-2010-2176733 Direct Testimony (July, 2010) Surrebuttal Testimony (August, 2010) Title Petition of West Penn for Approval of TOU Rates Topic Electric Service Time-of-Use Rate Design
Petition of West Penn For Approval of Critical Peak Pricing Program Qwest Change of Control
Electric Service Critical Peak Rate Design
Evaluation of Proposed Qwest/ CenturyLink Merger
11
Pennsylvania (On behalf of the Pennsylvania Office of Consumer Advocate, Continued) PPUC Docket No. Docket Nos. A-2009-2109528, A-2009-2109530, A-2009-2109531, and A-2009-3109532 (September, 2009) A-2008-2076038 (February, 2009) Title Windstream/D&E Communications Topic Evaluation of Proposed Merger; Merger Approval
CenturyTel/Embarq
Evaluation of Proposed Merger; Merger Approval
Virginia (On behalf of Consumer Counsel Section of the Virginia Office of Attorney General) SCC Docket No. PUC-2007-00008 (June, 2007) Title Verizon Petition for Deregulation and Detariffing Topic Local Exchange Competition; Market Analysis.
Washington (On behalf of Public Counsel Section of the Washington Attorney General) WUTC Docket No. UT-09-0842 (October, 2009) UT-08-2119 (March, 2009) UT-050814 (September, 2005) Title Frontier/Verizon Merger Approval CenturyTel/Embarq Merger Approval Verizon/MCI Merger Topic Evaluation of Proposed Frontier/ Verizon Merger Evaluation of Proposed Merger; Merger Conditions Market Structure and Market Power. Merger Conditions.
West Virginia (On behalf of the Consumer Advocate Division of the West Virginia Public Service Commission) WVSPC Case No. 09-0871-T-PC (November, 2009) Title Frontier/Verizon Merger Approval Topic Evaluation of Proposed Frontier/ Verizon Merger
12
Indiana (On behalf of the Indiana Consumer Counselor). *Testimony prepared, but not filed due to case settlement. IURC Cause No. 40611 (June, 1997) Title Ameritech Indiana Approval of Statement of Generally Available Terms Teleport Communications Group of Indiana, Inc. Topic Analysis of TELRIC studies.
39853 (March, 1994)
Authority to provide intraLATA and interLATA Private Line Services. Alternative Regulation/ Competition/Infrastructure Deployment/Imputation. Imputation/separate subsidiary.
39705 (January, 1994)
Indiana Bell Telephone
39474 (May, 1994)
Indiana Payphone Association v. Indiana Bell Telephone
39755 (September, 1993)
GTE North Inc./GTE Intelligent Network Service Inc. Ameritech Advanced Data Services
Divestiture of Assets/Policy.
39718 (August, 1993)
Affiliate Relationships.
39475 (March, 1993) 38269-S4 (February, 1993) 39369 (February, 1993)
Indiana Payphone Association
Dial-Around Compensation.
IntraLATA Toll Compensation
Toll Rate Deaveraging.
IURC Investigation into Access Charge Parity
Access Charge Parity/Recovery of Non-Traffic-Sensitive Costs/Policy. Collocation Policy.
39618 (January, 1993) 39385 (October, 1992)
IURC Investigation into Special Access Collocation Indiana Bell Telephone: Competition and Pricing Flexibility
Evaluation of Competition in Dedicated Communications Market/Policy.
13
Indiana (On behalf of the Indiana Consumer Counselor, Continued). *Testimony prepared, but not filed due to case settlement. IURC Cause No. 39353* Title Indiana Gas Company Topic Temperature Normalization Tracker/Demand Side Management/Reproduction Cost of Rate Base/Capital Costs. Clean Air Act Amendments /Demand Side Management. Financial Viability.
39314 (September, 1992) 39221 (January, 1992) 39215 (January, 1992) 39166 (November, 1991) 39164/39165 (October, 1991)
Indiana Michigan Power Co.
American Telecommunications Corporation Indiana American Water Co.
Reproduction Cost of Rate Base/Capital Costs. Reproduction Cost of Rate Base/Capital Costs. Reproduction Cost of Rate Base/Capital Costs.
Indiana Cities Water Co.
Ohio Valley Gas Corp.
39017*
IURC Investigation into Indiana Bell Earning
Reproduction Cost of Rate Base/Capital Costs.
Comments Filed Federal Communications Commission (On Behalf of National Association of Utility Consumer Advocates, Maine Office of Public Advocate, New Jersey Division of Rate Counsel, and The Utility Reform Network) In the Matter of Connect America Fund, A National Broadband Plan for Our Future, Establishing Just and Reasonable Rates for Local Exchange Carriers, High-Cost Universal Service Support, Developing an Unified Intercarrier Compensation Regime, Federal-State Joint Board on Universal Service, Lifeline and Link-Up, Universal Service Reform Mobility Fund. WC Docket No. 10-90, GN Docket No. 09-51, WC Docket No. 07-135, WC Docket No. 05-337, CC Docket No. 01-92, CC Docket No. 96-45, WC Docket No. 03-109, WT Docket No. 10-208. Assisted with preparation of Comments. (January 18, 2012.)
14
Comments Filed (Continued) Federal Communications Commission (On Behalf of National Association of Utility Consumer Advocates) In the Matter of Connect America Fund, A National Broadband Plan for Our Future, Establishing Just and Reasonable Rates for Local Exchange Carriers, High-Cost Universal Service Support, Developing a Unified Intercarrier Compensation Regime, Federal-State Joint Board on Universal Service, Lifeline and Link Up. WC Docket No. 10-90, GN Docket No. 09-51 WC Docket No. 07-135 WC Docket No. 05-337 CC Docket No. 01-92 CC Docket No. 96-45 WC Docket No. 03-109. Assisted with preparation of Comments and Reply Comments. (April 18, 2011 and May 23, 2011.) Federal Communications Commission (On Behalf of the National Association of Utility Consumer Advocates, Maine Public Advocate Office, Ohio Consumers Counsel, TURN) In the Matter of Connect America Fund, A National Broadband Plan for Our Future, High-Cost Universal Service Support, WC Docket No. 10-90, GN Docket No. 09-51, WC Docket No. 05-337. Affidavit in support of NASUCAs Comments on universal service reform, use of high-cost model, and reverse auctions. (July 12, 2010.) Federal Communications Commission (On Behalf of AARP) In the Matter of High-Cost Universal Service Support Federal-State Joint Board on Universal Service, WC Docket No. 05-337; CC Docket No. 96-45 (Universal Service Reform and Reverse Auctions). Assisted AARP with preparation of Comments (Filed April 17, 2008), and Reply Comments (Filed June 2, 2008). California Public Utilities Commission (On Behalf of TURN) Order Instituting Rulemaking into the Review of The California High Cost Fund B Program. (Auctions for Universal Service Funding. With Regina Costa and Christine Mailloux. November 9, 2007.) Federal Communications Commission (On Behalf of Consumer Federation of America, Consumers Union, Free Press, US PIRG). In the Matter of Broadband Industry Practices. WC Docket No. 07-52. (Supporting documents attached to Comments. June 15, 2007.) Federal Communications Commission (On Behalf of Consumer Federation of America, Consumers Union, Free Press, US PIRG). In the Matter of AT&T Inc. and BellSouth Corporation Applications for Approval of Transfer Of Control, WC Docket No. 06-74. (June 6, 2006.) With Mark Cooper. Federal Communications Commission (On Behalf of National Association of Utility Consumer Advocates) In the Matter of Federal-State Joint Board on Universal Service, CC Docket 96-45. Affidavit addressing application of forward-looking economic cost methodology to rural ILECs with 100,000 or more access lines. (December 14, 2004.) 15
Comments Filed (Continued) Federal Communications Commission (On behalf of AARP) In the Matter of Inquiry into High-Speed Access to the Internet Over Cable and Other Facilities. GN Docket No. 00-185, FCC No. 00-355. Tangled Web: The Internet and Broadband Open Access Policy. (January 10, 2001). Indiana Utility Regulatory Commission (On behalf of the Indiana Consumer Counselor) A Comprehensive Approach to Local Exchange Competition in Indiana (October, 1995). Indiana Utility Regulatory Commission (On behalf of the Indiana Consumer Counselor) Comments of the Office of the Office of Utility Consumer Counselor to the Telecommunications Regulatory Flexibility Committee (1993). New York Public Service Commission (On behalf of Independent Telephone Companies [NYNEX and Rochester excluded]) Proceeding on Motion of the Commission to Examine Issues Related to the Continued Provision of Universal Service and to Develop a Regulatory Framework for the Transition to Competition in the Local Exchange Market: "Comments on Compensation Arrangements Related to Module 2" (April, 1995). Maine Public Service Commission (On behalf of Independent Telephone Companies [NYNEX excluded]) Inquiry Into the Provision of Competitive Telecommunications Services (Chapter 280), Docket 94-114: "Reply Comments to the `Preliminary Proposal for a Revision and Restructuring of the Access Charge Provision of Chapter 280'" (June, 1995). Federal Communications Commission (On behalf of the Indiana Consumer Counselor) Comments of the Indiana Office of Utility Consumer Counselor on the Ameritech Customers First Plan (1993). Reply Comments of the Indiana Office of Utility Consumer Counselor on the Ameritech Customers First Plan (1993). Civil Litigation Jason Bond and David Lear, individually and as class representatives of those similarly situated v. Veolia Water North America Operating Services, Inc.; Veolia Water North America Operating service, LLC; and Veolia Water Indianapolis, LLC. In the Marion County, Indiana, Superior Court. Analysis and litigation support. 2008; United States District Court, Southern District of Indiana, Indianapolis Division, Affidavit, June 16, 2008.
16
Civil Litigation (Continued) Baxter Air, Inc., and for all others similarly situated, Plaintiffs, v. NOS Communications, Inc., NOSVA Limited Partnership, Affinity Network, Inc., Robert A. Lichtenstein, and Joseph T. Koppy, Defendants. In the Superior Court of the State of Washington in and for the County of King. Declaration, July 2007. Brooke Randolph and John Girad, et al, Plaintiffs, v. AT&T Wireless Services Inc., et al. Superior Court of the State of California in and for the County of Alameda, Unlimited Jurisdiction. Declaration, February 12, 2007. Reply Declaration, April 25, 2007. Declaration, March 4, 2009. Christopher W. Hesse, Plaintiff v. Sprint Spectrum L.P., Defendant. Nathaniel Olson, Plaintiff v. Sprint Spectrum L.P., et al v. Sprint Spectrum L.P. et al. United States District Court Western District of Washington at Seattle. Declaration, April 30, 2007. Dawn M. Black, et al, Plaintiffs, v. Indiana Bell Telephone Company, Inc. d/b/a Ameriech Indiana. State of Indiana, Marion County Superior Court. Analysis and litigation support. 2006-2007. Robert Young, et al, Plaintiffs, v. United Telephone of Indiana, Inc. d/b/a Sprint. State of Indiana, Marion County Superior Court. Analysis and litigation support. 2003-2004. Mark Webber, et al, Plaintiffs, v. Indiana Bell Telephone Company, Inc. d/b/a Ameriech Indiana. State of Indiana, Marion County Superior Court. Analysis and litigation support. 2003-2004.
January 2012
17

R.11!12!001 Public Roycroft Declaration 1-31-12

Загружено:

Сведения о документе

Исходное описание:

Авторское право

Доступные форматы

Поделиться этим документом

Поделиться или встроить документ

Параметры публикации

Этот документ был вам полезен?

Это неприемлемый материал?

Авторское право:

Доступные форматы

R.11!12!001 Public Roycroft Declaration 1-31-12

Загружено:

Авторское право:

Доступные форматы

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Declaration of Trevor R. Roycroft, Ph.D.

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

OIR, p. 2. OIR, p. 14. 7 OIR, pp. 12-13.

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Response to OIR Questions

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

D.08-12-032, p. 5. D.08-12-032, Appendix, p. 6.

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

See, for example, Resolution T-17120, November 1, 2007.

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Carriers Reported Performance 2 percent 75 percent 80 percent

Penalty Points None 5 10

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Sep Aug Jul Jun May Apr Mar Feb Jan 0 10 20 30 40 50

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Declaration of Trevor R. Roycroft, Ph.D. On Behalf of TURN CPUC R.11-12-001 _________________________________________________________________________________________________________

Report Year: Total Company - Statewide

Reporting Unit Name:

Measurement (Compile monthly, file quarterly)

Mar N/A N/A N/A N/A N/A N/A N/A

Apr N/A N/A N/A N/A N/A N/A N/A

Jun N/A N/A N/A N/A N/A N/A N/A

Jul N/A N/A N/A N/A N/A N/A N/A