1. The Three Rs: The Need for Reliable, Redundant and Resilient Telecommunications in the New Age Presentation for the National Association of State Utility Consumer Advocates State Utility Consumer Advocates Austin, Texas November 9, 2015 Susan M. Baldwin

2. November 9, 2015 Susan M. Baldwin NASUCA Annual Meeting “By eight-thirty, his home phone was ringing. His home phone never rang. It was a holdover from another time. His mother had told him that it was essential, a matter of safety – for hurricanes, or blackouts, or terrorist attacks. You never knew what could happen until it happened. She had insisted on paying the bill so that Usl would keep the landline.” [“Usl at the Stadium,” Rivka Galchen, New Yorker, October 12, 2015]

3. November 9, 2015 Susan M. Baldwin NASUCA Annual Meeting

4. Resiliency has many facets Multi-state 911 outage demonstrates we have insufficient resiliency Resiliency depends on rural call completion Resiliency depends on network maintenance Resiliency should not be degraded as we transition to new platforms

5. November 9, 2015 Susan M. Baldwin NASUCA Annual Meeting So Why Are Telephone Cables Pressurized? “….biggest threat to telephone wires (conductor pairs) is moisture”

6. November 9, 2015 Susan M. Baldwin NASUCA Annual Meeting “Consistent with these system-wide measures of performance, the Commission heard directly from numerous residents of the outlying areas of the Verizon service territory, particularly areas served by microwave middle-mile infrastructure, that lost dial tones and inability to complete calls were a significant and frequently recurring problem. Lack of redundancy (i.e., of alternate means of call completion when the primary means of transport is OOS for any reason) is most serious in the remote areas and poses a significant threat to health and safety.” CPUC Proposed Decision, at 64 (emphasis added)

7. November 9, 2015 Susan M. Baldwin NASUCA Annual Meeting Copper networks are not obsolescent... but the ILECs’ incentive is to hasten the transition When consumers have the choice between FiOS and copper, many want to stick with copper Although customers wanted copper-based broadband, Verizon deployed 4G LTE wireless broadband to fulfill PA Chapter 30 requirement

8. November 9, 2015 Susan M. Baldwin NASUCA Annual Meeting Until new platforms are as resilient as old ones Ensure consumer option for copper -No strong-arming in rural areas to Voice Link -No strong-arming in urban areas to FiOS -No bait-and-switch from wireline to wireless broadband Copper networks should be repaired in a timely manner

9. November 9, 2015 Susan M. Baldwin NASUCA Annual Meeting Copper networks are not obsolescent... demand for TDM-based special access is in the billions “Despite the growth of newer technologies,... revenues from such TDM services continue to make up in the range of sixty percent of the roughly $40 billion annual special access market.” “... DS1 and DS3 channel termination sales actually increased from 2010 to 2013.” It is estimated “use of legacy business services will remain stable at least through 2017.” In the Matter of Investigation of Certain Price Cap Local Exchange Carrier Business Data Services Tariff Pricing Plans, WC Docket No. 15-247, Order Initiating Investigation and Designating Issues for Investigation, released October 16, 2015, DA 15- 1194, paras. 2 and 3 emphasis added)

10. Resiliency depends on timely repair... but economic incentives are lacking California – Verizon performance declined from 72% of OOS repairs completed within 24 hours in 2010 to 68% in 2014 (PD, 64); - AT&T was 67% in 2013 (Staff Report, at 14) (CPUC standard is 90%) Massachusetts (as of August 2015) – % of residential troubles cleared within 24 hours is 40% (and only 34% (!) in the Mass Bay region). Rolling statewide average - 52% and the trend since September 2014 has been steadily down. (DTC standard is 60%)

11. November 9, 2015 Susan M. Baldwin NASUCA Annual Meeting CONCLUSION Many different pieces go into resiliency, reliability and redundancy and often economic incentives are lacking to create the situations that are essential to public safety and welfare.

12. November 9, 2015 Susan M. Baldwin NASUCA Annual Meeting Susan M. Baldwin 17 Arlington Street ▪ Newburyport, MA 01950 (978) 255-2344 smbaldwin@comcast.net www.smbaldwinconsulting.com