Examination of the Local Telecommunications Networks and Related Policies and Practices of AT&T California and Frontier California, 2010 – 2017 (Network Exam)

Network Exam - Definition 

Examination of the telecommunications networks and related policies and practices of AT&T
California (AT&T CA) and Frontier California as ordered by Decision (D.) 13-02-023.

Relevant Proceedings

(R.) 11-12-001“Order Instituting Rulemaking to Evaluate Telecommunications Corporations Service Quality Performance and Consider Modification to Service Quality Rules.”
(D.) 13-02-023“Decision Affirming Provisions of the Scoping Memo and Ruling.”
(D.) 15-08-041 – “Decision Affirming Commission Direction to Conduct the Network Evaluation Study”

Purpose of Study

Per (D.) 13-02-023, “the performance of Pacific Bell Telephone Company dba AT&T California (AT&T) and Verizon California Inc. (Verizon) [currently Frontier California] has consistently failed to meet existing service quality metrics.” The goal of the Network Examination is to evaluate the condition of the carriers’ network infrastructure for wireline telecommunications services to ensure that facilities and company practices support a level of service consistent with public safety and customer needs.


Evaluation of Service Quality data, review of documents related to the companies' policies, procedures, practices, and work rules/job duties

  • Current condition of the wireline networks;
  • Adequacy of each company's practices and policies regarding network maintenance, repair, replacement, and capital budgeting;
  • Carriers' capital budgets for network modifications or improvements;
  • Physical inspection of sample of carrier facilities; and
  • Recommendations for changes.

Data Sources

  • Carriers’ quarterly service quality data provided to California Public Utilities Commission (CPUC);
  • Public information (media coverage, annual reports, census data);
  • Financial Reports (both confidential and public);
  • Data requests (specific information supplied by both carriers); and
  • Complaint information from CPUC Consumer Affairs Branch.

Key Findings from the Study:  

1. Service Quality has deteriorated - Both carriers exhibited a higher relative number of outages and longer time required to restore service for outages lasting more than 24 hours.

2. Demonstrated lack of resiliency - AT&T and Frontier are not maintaining networks to withstand environmental and weather-related conditions.  Networks are not robust, both Incumbent Local Exchange Carriers (ILECs) have cut back on preventative maintenance expenditures.  

3. Disinvestment in Plain Old Telephone Service (POTS) - AT&T and Frontier are putting very little investment into infrastructure that supports only Time Division Multiplexing (TDM) service.  Both ILECs are relying on price increases and customer inertia to maintain revenue stream. 

4. Increased investment in broadband improves POTS service quality - AT&T and Frontier areas with higher broadband investment have a higher level of POTS service quality and better performance on all General Order 133-D metrics.

5. AT&T is focusing on higher income communities - AT&T wire centers serving areas with the lowest household incomes exhibit higher trouble report rates and longer out-of-service durations than areas in higher income communities.

6. Direct relationship between amount of competition and service quality results - Areas with limited or no competition experience lower service quality results.  Both AT&T and Frontier put more investment and attention in areas with higher rates of competitive offerings.  

The Network Exam Report is based on information submitted by AT&T California and Verizon California/Frontier with claims of confidentiality made pursuant to Pub. Util. Code section 583 and General Order 66-D. The Commission’s Communications Division has redacted certain information in the Report based on these claims. The Communications Division anticipates that a public, redacted version of each chapter in this report will be released in due course, upon review of all confidentiality claims. The validity of the companies’ confidentiality claims are subject to Commission review. 

New: Decision (D.) D.20-12-021, Decision Addressing Carriers' Confidentiality Claims Related to Network Study Ordered in Decision 13-02-023, as Affirmed in Decision 15-08-041, is now available at: https://docs.cpuc.ca.gov/SearchRes.aspx?docformat=ALL&docid=356209718.

Decision 20-12-021 addresses the confidentiality claims of AT&T California and Frontier California in relation to the Network Exam. The Decision orders a majority of the Network Exam Report to be made public. The Commission directs staff to make limited redactions to information that, if revealed, could pose a security risk. The Commission orders Chapters 1, 2, 4 (including 4A, and 4F), and 11 of the report and the Table of Contents to be made available in their entirety on the Commission's website within 30 days of the effective date of this Decision. The Commission also orders Chapters 3, 5, 6, 7, 8, 9, 10 and 12 to be redacted consistent with the orders in the Decision and to be made available within 30 days of the Decision's effective date. Decision (D.) 20-12-021, Ordering Paragraphs 1 and 2, requires staff to redact Chapters 3, 5, 6, 7, 8, 9, 10, and 12 consistent with the conclusions in the decision. Accordingly, no redactions were made to Chapters 5, 6, 7, and 8. Please see below, for the complete report. 

Table of Contents 
Chapter 1 - Executive Summary and Overview of this Report
Chapter 2 – Introduction and Background for this Study
Chapter 3 - California ILEC Network Overview (Redacted)
Chapter 4 - ILEC Responses to Service Outages
Chapter 4A - Service Quality Analysis: AT&T California
Chapter 4F - Service Quality Analysis: Verizon/Frontier
Chapter 5 - Infrastructure Policies and Procedures: AT&T
Chapter 6 - Infrastructure Policies and Procedures: Frontier
Chapter 7 - AT&T Corporate and California ILEC Investment Policies
Chapter 8 - Verizon/Frontier Corporate and California ILEC Investment Policies
Chapter 9 - Assessment of safety, redundancy and resiliency of network(s): AT&T (Redacted)
Chapter 10 - Assessment of safety, redundancy and resiliency of network(s): Frontier (Redacted)
Chapter 11 – Conclusions and Recommendations
Chapter 12 - Communications Division Staff Site Visits (Redacted)

Network Exam Report (April 2019)_Complete Report_PUBLIC per D.20-12-012 (Redacted)

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