CALIFORNIA ILEC NETWORK OVERVIEW

3

Principal observations and takeaways

! AT&T California’s decision to retain its decades-old central office switches in service may

be a practical strategy in light of the formidable economic, technology and regulatory

challenges to any wholesale involuntary migration of its legacy voice service customers to

current packet switched VoIP technology.

! Most of AT&T’s recent central office plant additions have been for packet switches that are

not used to provide legacy POTS services.

! Frontier’s central office switches were all acquired before Frontier’s 2016 purchase of

Verizon, with the majority pre-dating the 2000 merger of Bell Atlantic and GTE. Many of

the switches that are still in service were installed more than three decades ago.

! As of the April 2016 date when Frontier took over the company, FTTP plant deployed by

Verizon was available to roughly 1.44-million – or about 38.4% – of the population in areas

Verizon served. Since the acquisition, Frontier has added 59 wire centers serving areas

with another 2.32-million people to its FTTP network and, by the end of 2017, FTTP was

available to slightly more than two-thirds of all people living in Frontier-served areas.

! AT&T has never committed to deploying FTTP on a large scale, although the company

has constructed FTTP at a small number of customer locations in the state. Overall, only

1.8% of homes passed by AT&T California have been upgraded with FTTP.

! Broadband upgrades provide service quality benefits to basic POTS customers, but a

carrier’s decision to invest in broadband is driven mainly by factors that have little direct

bearing upon improving service to legacy POTS customers. California ILECs are under no

legal obligation to invest in broadband, but fines imposed pursuant to GO 133-D, if scaled

correctly with respect to the extent of the shortcoming, have the potential to provide the

necessary incentives to encourage such investments.

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CALIFORNIA ILEC NETWORK OVERVIEW

TABLE OF CONTENTS

The relationships between the two largest California ILECs and their respective corporate

parents: A brief history. 65

AT&T California 65

Frontier California 66

The ILECs' service areas in California 68

AT&T California 71

Frontier California 75

Central Office Switch Technology 77

AT&T California 77

Frontier California 80

Outside Plant Distribution Area Technology 81

OSP Architecture in general 81

Frontier California 84

AT&T California 94

Summary and conclusions 102

Tables and Figures

Table 3.1: AT&T California Technical Field Services Districts 71

Table 3.2: AT&T California Construction & Engineering (C&E) Districts 72

Table 3.3: Frontier California Geographic Operating Areas 75

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Table 3.4: AT&T California Central Office Switches and Capacities 77

Table 3.5: Frontier California Central Office Switches and Capacities 81

Table 3.6: Frontier California Population at Locations Where FiOS- Capable

FTTP Plant has been Deployed 86

Table 3.7: Frontier California Types of Broadband Services at Each Central Office 87

Table 3.8: AT&T California Households at Which Some Form of

"Broadband" Service is Currently Available 94

Table 3.9: AT&T California Availability of Broadband by Technology Category 96

Table 3.10: Fiber-Equipped and Low-Speed DSL Availability – ILEC

Central Offices and Lines in Service as of December 2017 103

Figure 3.1: AT&T California ILEC service areas 69

Figure 3.2: Frontier California ILEC service areas 70

Figure 3.3: AT&T Technical Field Services (“TFS”) Districts 73

Figure 3.4: AT&T Construction & Engineering (“C&E”) Districts 74

Figure 3.5: Frontier California Operating Areas (“OPAs”) 76

Figure 3.6: Principal components of an ILEC local distribution network 82

Figure 3.7: Frontier Distribution Area Technology – Long Beach wire centers 93

Figure 3.8: Relationship between the maximum download datarate and the

length of the copper distribution segment of a subscriber line

between the Central Office or Node and the end user. 95

Figure 3.9: AT&T Distribution Area Technology Maps

a. Map Legend 97 b. Mountain View 98

c. San Carlos 99 d. San Diego 100

e. Bakersfield 100 f. Los Angeles area 101

g. Oakland / East Bay 101 h. San Francisco 102

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The relationships between the two largest California ILECs and their respective corporate

parents: A brief history.

Each of the two ILECs that are the subject of this Study are wholly-owned subsidiaries of

parent corporations with extensive multi-state operations. While the nature and identities of both

corporate parents have changed several times over the past four decades, AT&T’s California

ILEC – Pacific Bell d/b/a AT&T California – has seen fewer disruptions to its corporate struc-

ture and ownership in recent years than what is now Frontier California. The parent company

AT&T Inc. has diversified its overall business activities beyond local telephone company ILEC

operations and AT&T’s ILECs have become an increasingly smaller component of AT&T’s

overall business.

Verizon’s corporate evolution has been similar. This has not, however, been the case with

Frontier Communications, Inc., which acquired Verizon’s California ILEC business in 2016.

Unlike AT&T and Verizon, Frontier’s business is primarily that of operating incumbent local

exchange carrier (ILEC) affiliates. Unlike AT&T and Verizon, Frontier does not have any

consequential interest in any mobile wireless, video content, Internet content, long distance, or

video distribution businesses except, in the case of video distribution, as an adjunct to its ILEC

operations. From the perspective of the ILEC and its customers, the 2016 transaction brought

the third parent company owner of the company in less than two decades – from GTE to Verizon

in 2000, and from Verizon to Frontier in 2016.

AT&T California

AT&T California and Frontier California are the two largest ILECs in the state. As of

December 31, 2017, AT&T operated 615

28

wire centers across 51 of the state’s 58 counties, and

served approximately 2,245,171 residential and small business legacy circuit-switched (POTS)

access lines. AT&T California is a wholly-owned subsidiary of AT&T Inc., a company that was

formed in 2005 as a result of acquisition of AT&T Corp. by SBC Communications.

29

The parent

AT&T Inc. is headquartered in Dallas, Texas. AT&T California also provides several types of

broadband digital services to the residential and small business market, including high-speed

Internet access, video services, and VoIP-based digital residential telephone service, under the

U-verse brand name (offered individually and in bundles). AT&T also offers wireless

Commercial Mobile Radio Services (CMRS) through its AT&T Mobility affiliate, satellite

28. AT&T furnished several tabulations of its California wire centers, with differing numbers of wire centers,

over the course of the study (615 in its response to DR-01A,Data Request 3, Attachment 4; 624 in response to

DR-03A, Data Requests 1,2, and 6 , Corrected Attachment 1; 622 in DR-03A, Corrected Attachment 2; 626 in DR-

03A, Corrected Attachment 2, DR-03A, Corrected Attachment 4 ). The GO 133-C/D service quality data covers

only 612 wire centers.

29. In the Matter of SBC Communications Inc. and AT&T Corp. Applications for Approval of Transfer of

Control, WC Docket No. 05-65, 20 FCC Rcd 18290, 2005 FCC LEXIS 6385, 37 Comm. Reg. (P & F) 321,

November 17, 2005.

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television service through its DirecTV affiliate acquired in 2015, and a range of video content

through its recent (2018) acquisition of Time Warner. AT&T Inc.’s consolidated gross revenues

for 2017 were $165.5-billion.

30

Total revenues derived from all of its “legacy voice and data

services” were $17.85-billion, of which only about $3.92-billion came from legacy residential

and small business POTS-type services.

31

Only about 10.8% of all AT&T Inc. 2017 revenues

were derived from the services that are the principal focus of this study.

Frontier California

As of December 31, 2017, Frontier California operated 270 wire centers across 35 of the

state’s 58 counties, and served 857,467 residential and small business legacy circuit-switched

(POTS) access lines. The Company was acquired by Frontier Communications Inc. as part of a

three-state purchase that also included Verizon ILEC operations in Texas and Florida.

32

All of

these ILEC operations had been owned by GTE prior to its 2000 merger with Bell Atlantic to

form Verizon. Frontier had its genesis as Rochester Telephone Corporation

33

(“RTC”), an ILEC

whose service area consisted of the Rochester, New York metropolitan area. RTC was at the

time the largest Independent telephone company not affiliated with any other ILEC system or

holding company.

34

30. AT&T Inc. 2017 Annual Report, Selected Financial and Operating Data, at 14.

31. Id., at 18, 20. AT&T Inc. breaks down its operations into several business segments. The “Business

Solutions Segment” provides services to business customers; the “Entertainment Group Segment” provides services

to consumers. Business Segment “Legacy Voice and Data Services” revenues for 2017 were $13.93-billion; the

Entertainment Group Segment “Legacy Voice and Data Services” revenues for 2017 were $3.92-billion.

32. Two other Frontier ILEC affiliates, Frontier Citizens Telecommunications Company (U-1024-C) and Frontier

Communications of the South West (U-1026-C), operate 50 and 6 wire centers, respectfully, in 16 California

counties and served approximately 82,047 access lines as of the end of 2017. Both of these Frontier ILECs’

existence pre-dates the parent company’s 2016 acquisition of Verizon California, and is not included within the

scope of this Study.

33. Frontier Corporation 8-K filing, April 2, 1996, at 1.

34. As far back as 1993, RTC had proposed an innovative restructuring arrangement to accommodate the then-

emerging competition in the local exchange market. It proposed to split itself into separate "retail" and a "whole-

sale" entities, with the latter providing underlying network services to RTC's retail operation as well as to competing

local carriers. The retail entity would compete with other potential providers, buying service in bulk and as a reseller

would not be subjected to full regulatory oversight as would the wholesale entity. Rochester Telephone Corporation,

Form 8-K, November 18, 1994, at 2. Although the specific RTC plan was never implemented as envisioned, it is

noteworthy that the wholesale/retail structure ultimately adopted by the UK Office of Communications ("Ofcom")

for British Telecom bears a striking resemblance to the original RTC plan. "[British] Telecom splits retail and

wholesale," http://www.nbr.co.nz/article/telecom-splits-retail-and-wholesale [accessed on July 15, 2015]

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With the GTE acquisition, Bell Atlantic (Verizon) expanded its ILEC footprint across 28

states,

35

from Maine to Hawaii. Within a few years following the merger, Verizon initiated the

process of shedding large portions of its wireline operations. Although most of these divestitures

were of former-GTE operating companies, Verizon also sold off four legacy Bell territories in

Maine, New Hampshire, Vermont and West Virginia. The bulk of the GTE divestitures were

sold to Frontier. Nearly all of Frontier’s investments over the past 20 years have been in

wireline operations, which have included the acquisition of a number of former-GTE territories

from Verizon. In 1993 RTC acquired half a million access lines from pre-Verizon GTE. Just six

years later, the company made a series of acquisitions from pre-Verizon GTE in Arizona,

California, Minnesota, Nebraska, and Illinois that amounted to 361,000 additional access lines.

36

In 2007, the company acquired nearly half a million access lines in Pennsylvania from

Commonwealth Telephone Enterprises, Inc. In that same year, Frontier acquired small ILEC

properties in California from Global Valley Networks, Inc. Frontier’s largest acquisition was in

2010 when it acquired roughly half of the former GTE ILEC properties from Verizon. Frontier’s

most recent acquisition was from AT&T, adding nearly one million access lines in Connecticut.

Its most recent major acquisition was the California/Texas/Florida deal with Verizon. As of the

April 1, 2016 date when that 3-state deal closed, Frontier served 5.77-million voice access lines

in 29 states nationwide.

37

Frontier is today the nation’s fourth largest ILEC with roughly 4.9-

million residential and business customers across 29 states.

38

The transition of the three states acquired in 2016 from Verizon to Frontier experienced

complications. There were numerous service interruptions and protracted technical and

operational issues.

39

Frontier hemorrhaged access lines from the outset. Between April 1, 2016

and December 31, 2017, the Company’s California access lines dropped by 29.4%, from 1.25-

million to 883,000. On the date that Frontier announced its deal with Verizon (February 5,

2015), Frontier common stock closed at $7.71, which was equivalent to a post- 1-for-15 share

reverse split price of) 115.65.

40

By the end of 2017, the equivalent post-reverse split share price

35. GTE Corporation, 1999 Form 10-K, March 30, 2000, at 2.

36. Application, at 33, fn. 55.

37. “Frontier Communications Completes Acquisition of Verizon Wireline Operations in

California, Texas and Florida,” Press Release, April 1, 2016

http://investor.frontier.com/static-files/ce1429d7-39d8-4e7f-aae3-63f5a24eb1e1 [accessed on October 3, 2018].

38. Frontier, 2018 Form 10-K, March 1, 2018, at 2.

39. Frontier Communications, Inc. Forms 10-Q, Second Quarter 2016. See also Table 8.1 infra.

40. On

July 10, 2017, Frontier announced a 1-for-15 “reverse split” of its common stock – i.e., shareholders

would receive one 1 new share for each 15 shares owned. The pre-reverse split shares closed at $7.71 on February

5, 2015.

“Frontier Communications to Implement Reverse Stock Split on July 10, 2017” Press Release, July 7, 2017

http://investor.frontier.com/news-releases/news-release-details/frontier-communications-implement-reverse-stock-sp

lit-july-10 [accessed on October 9, 2018].

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had dropped by 94.02%, to 6.92. As of January 14, 2019, Frontier (post reverse-split) stock

closed at 2.58, down 97.8% from its February 2015 level. To put all of this in context, Frontier

paid Verizon a total of $10.54-billion in cash for the California/Texas/Florida ILEC operations,

and financed that purchase through a combination of $2.75-, $1.5- and $6.6-billion in new debt.

41

Based upon its January 14, 2019 closing stock price, Frontier market cap is currently about

$271-million.

Unlike AT&T, where legacy wireline operations represent a tiny fraction of the Company’s

total business, for Frontier, legacy ILEC operations are its principal business. Although Frontier

does provide video services under the “Vantage TV by Frontier” and FiOS brands using the

same types of digital transport facilities that also provide high-speed Internet access, the

Company has no wireless affiliate, no content affiliate, and no cable TV affiliate.

42

Just ILECs.

With the 2016 Verizon deal, Frontier acquired approximately 1.26-million revenue-producing

access lines. Frontier California facilities passed some 2.63-million households within the

former Verizon California operating footprint. Approximately 1.52-million of these were passed

by fiber-to-the-premises (“FTTP“) facilities, capable of providing broadband digital voice,

Internet access, and TV under the FiOS brand name.

43

The three-state Verizon acquisition

enabled Frontier to offer high-speed Internet access and video in these markets, and perhaps to

use this as a springboard for a wider broadband buildout. But its financial collapse subsequent to

that 2016 purchase has made any major expansion not financially viable.

Prior to its Verizon California acquisition, Frontier had already acquired two other small

ILECs in California – Frontier Citizens Telecommunications Company (U-1024-C) and Frontier

Communications of the South West (U-1026-C).

44

This study is limited solely to those Frontier

exchanges that were acquired from Verizon (U-1002-C).

The ILECs’ service areas in California

Figures 3.1 and 3.2 provide maps of the areas served by AT&T California and Frontier

California, respectively. The two companies together serve approximately 95.7% of all ILEC

access lines in California; including CLECs, they serve

51.77% of all voice access lines in the

41. Frontier, 2016 Form 10-K, February 25, 2016, at 2.

42. Frontier Communications Corporation, 2017 Form 10-K, March 30, 2000, at 3.

43. Data derived from CPUC Broadband Availability Database. See Reply Testimony of Lee L. Selwyn

(redacted) on behalf of ORA, A.15-03-005, July 28, 2015, at 53.

44. CPUC Total Number of Working Telephone Lines from 27 Carriers Reporting Under General Order 133-D,

as of June 2017. available at (accessed 10/3/18):

ftp://ftp.cpuc.ca.gov/Telco/ServiceQualityReports/2017/CARRIER%20LINE%20COUNTS%20FOR%20JUNE%20

30%202017.pdf

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Figure 3.1. AT&T California ILEC service areas.

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Figure 3.2. Frontier California ILEC service areas.

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state. Two other Frontier operating affiliates, not included within the scope of this study, bring

the total for both AT&T and Frontier to 56.99%. Most of the other legacy voice service access

lines are provided by CLECS (41.8%), with a small number (0.83%) furnished by small, non-

URF ILECs.

45

AT&T California

AT&T California maintains extensive operations across all portions of the state. It is the

largest ILEC both statewide and in all major metropolitan centers. The Company has 615

exchanges spread across 51 of the state’s 58 counties. It serves all of the state principal

metropolitan centers – Los Angeles, San Francisco/East Bay, San Jose, San Diego and

Sacramento – and most of their suburbs. The AT&T California ILEC also provides service

(under the AT&T Nevada brand) to northern Nevada, mainly in the Reno/Tahoe/Carson City

area.

AT&T California is organized into five “Technical Field Services” (“TFS”) districts for

purposes of network maintenance, and five “Construction & Engineering” (“C&E”) districts that

are responsible for plant upgrades and expansions. TFS projects are generally booked as

maintenance expenses, whereas C&E projects are recorded as gross plant additions. The TFS

districts are summarized on Table 3.1, and the C&E districts are summarized in Table 3.2,

below. Figure 3.3 and 3.4 provide maps indicating the geographic responsibilities of the TFS and

C&E districts, respectively.

Table 3.1

AT&T CALIFORNIA

TECHNICAL FIELD SERVICES DISTRICTS

TFS District

No. of Wire

Centers

Bay / Central Coast 126

Greater LA / Bakersfield 85

Northern CA / Central Valley / NV 286

San Gabriel 13

Southern CA 105

TOTAL 615

Source: AT&T California response to CD Data Request 01A.

45. Id.

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Table 3.2

AT&T CALIFORNIA

CONSTRUCTION & ENGINEERING (C&E)

DISTRICTS

C&E District

No. of Wire

Centers

Bay 81

LA 98

North / NV 234

South 105

Valley 97

TOTAL 615

Source: AT&T California response to CD Data Request 01A.

Table 4A.12 identifies the TFS districts associated with each AT&T wire center.

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Figure 3.3. AT&T California Technical Field Services (“TFS”) Districts.

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Figure 3.4. AT&T California Construction & Engineering (“C&E”) Districts.

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Frontier California

Frontier California’s footprint embraces large areas of the state, including a number of rural

areas in addition to its presence in several major metropolitan markets. The company has

exchanges in 35 of the state’s 58 counties. Frontier’s largest concentration is in southern

California, and covers large portions of Los Angeles County, where its territory includes Santa

Monica, parts of West LA, and portions of the San Fernando Valley. Some 41% of Frontier

California’s customers are in Los Angeles County. Frontier also serves large portions of

Ventura, Orange, Riverside and San Bernardino Counties. The Company’s presence in northern

California is more limited, serving several isolated Bay Area exchanges in Marin and Santa

Clara Counties. The remainder of Frontier California’s operations are mainly in low-density

rural areas; its largest market outside of southern California and the Bay Area is in Fresno.

Frontier has organized its operations into six geographic areas, as follows:

Table 3.3

FRONTIER CALIFORNIA

GEOGRAPHIC OPERATING AREAS

Operating Area

No. of Wire

Centers

Beach Cities 31

Coastal 31

Desert 58

Gateway 64

Inland 23

Northern 66

TOTAL 273

Source: Frontier California response to CD Data Request 01F.

Figure 3.5 provides a map indicating the geographic regions that are the responsibility of each

of Frontier’s six Operating Areas, respectively. Table 4F.12 identifies the Operating Area

associated with each Frontier wire center.

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Figure 3.5. Frontier California Operating Areas (“OPAs”).

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Central Office Switch Technology

AT&T California

AT&T has a total of 615 central offices, some of which have more than one switching entity

in the building. AT&T’s CO switch entities cover a broad mix of switch types. In total, these

entities have a combined capacity of 18.8 -million voice dial connections. Many of the switches

still in service were initially acquired and installed more than three decades ago – some as early

as 1983 – and most even pre-date the 1997 merger of Pacific Telesis Group and SBC Communi-

cations; all but one switch acquisition pre-date the 2006 AT&T Corp./SBC merger.

46

These

machines are, for the most part, second generation stored program digital electronic switches

built in the mid-1980s and 1990s utilizing computer technology extant at that time. In almost

any other communications application, this type of vintage hardware would have been replaced

years or even decades ago. The most recent switch acquisition identified by AT&T occurred in

2008.

47

Table 3.4 below summarizes the number of entities and total capacity of each type of

switch.

Table 3.4

AT&T CALIFORNIA

CENTRAL OFFICE SWITCHES AND CAPACITIES

Switch type Description

Installation

dates

No. of

switches

Total capacity

(access lines)

5ESS No. 5 ESS digital host 1983-2002 161 6,300,891

NT DMS 100 (all

types)

Northern Telecom DMS 100 host

switch 1984-2000 163 7,371,963

DRSCS

Dual Remote Switching Center -

SONET 1990-1997 14 141,952

TSCS Remote Switching Center - SONET 1988-1999 24 164,144

Remotes (other

types)

Includes remote switch modules, line

multiplexers/concentrators 1985-2002 215 2,674,968

COs with multiple

switches

Multiple host switches, combination

of host and remote switches

(individual capacities not provided) 1984-1993 35 2,114,159

Misc (other types)

MG9000-ABI VoIP Gateway, NT

DMS 100/200 1985-2008 3 20,608

TOTALS 615 18,788,685

Source: AT&T response to DR 01-A.

46. AT&T Response to DR-01-A, “05 - Attachment 4 - Network Evaluation DR 1 - Question 3.xlsx”

47. Id.

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Table 3.5

FRONTIER CALIFORNIA

CENTRAL OFFICE SWITCHES AND CAPACITIES

Switch type Description

Installation

dates

No. of

switches

Total capacity

(access lines)

5ESS No. 5 ESS digital host 1986-1999 33 617,268

5ESSRSM No. 5 ESS Remote Service Module 1991-1995 13 46,402

GTD5 EAX GTE (AE) No. 5 digital host switch 1982-1997 104 2,124,852

AE RSU GTE (AE) No. 5 Remote Service

Unit

1983-1991 31 73,112

NT DMS 10,

DMS10 SSO

Northern Telecom DMS 10 (all

types)

1991-1993 14 34162

NT DMS 100 (all

types)

Northern Telecom DMS 100 host

switch

1985-2000 24 250,057

NT DMS

Remotes (all

types)

Northern Telecom DMS 100 Remote

Service Units (various types)

1983-2001 54 77,841

NT SLOA Northern Telecom 2007 2 39,888

NT AAL1S 2007 3 37,006

TOTALS 278 3,300,588

Source: Frontier response to DR 01-F.

As with AT&T, the combined capacities of Frontier’s central office switch inventory – 3.3-

million legacy circuit-switched voice (POTS) telephone lines – grossly exceeds – by a factor of

nearly four times – Frontier’s current demand which, as of the end of 2017, was under 900,000

POTS lines. As long as these switches remain serviceable and functionally viable for their

current uses, Frontier’s (and its predecessors’) policy of keeping these switches in active service

may well be the most prudent strategy.

Outside Plant Distribution Area Technology

OSP Architecture in general

Local telephone service is typically furnished by means of a hierarchical distribution network

with the serving wire center at its center. The principal components of an ILEC local

distribution network are illustrated in Figure 3.6 below. These consist of the following elements:

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Figure 3.6. Principal components of an ILEC local distribution network.

(1) Wire Center A building where central office switches, feeder cables, and interoffice trunks

to other wire centers terminate and interconnect to one another.

(2) Interoffice Trunks. High capacity digitally multiplexed transmission cables that connect

the wire center with other locations on the public switched network.

(3) Feeder plant. These are typically high-capacity facilities connecting the wire center to the

“Distribution Area.” The feeder cables are cross-connected at a “Service Area Interface”

(“SAI”) through a Feeder/Distribution Interface or “cross-box”) to distribution facilities

that run along individual streets and roads so as to pass directly in front of individual

customer premises. In the past, feeder cables would consist of large capacity sheaths of

twisted-pair copper cables, usually in the range of 300 to 1200 pairs, sometimes less,

sometimes more, depending upon the service demands of the area served. In urban

centers, feeder plant is typically carried in underground conduit pipes. However, in

suburban and rural areas, feeder plant is usually carried on pole lines, making them more

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vulnerable to adverse weather and other environmental conditions. Where large

concentrations of customers are to be served (e.g., in a large office complex or a large

multi-unit residential building), feeder cable might be deployed directly to that location.

As technology developed over time, these large, heavy copper cables were replaced by

fiber optic cables connecting the wire center to the various remote terminals. Such fiber

facilities support many multiples of the capacity typical of copper cables. They carry

voice and data signals in digital form. For traditional voice (POTS) services, these digital

signals have to be converted back to analog for transport over the twisted-pair copper

distribution facilities to individual customers.

(4) Remote Terminal. Remote Terminals are the point of intersection of the high-capacity

feeder plant and relatively low-capacity distribution plant. Where feeder cables utilize

fiber optic technology, so-called “optronic” equipment at the Remote Terminal converts

the optical signals carried on the fiber into electronic form for transmission over the copper

distribution facilities to the end user. Multiple distribution routes are typically served out

of a single Remote Terminal. Where required, e.g., for relatively long distribution

segments, pair-gain equipment is also housed within the Remote Terminal to provide

signal amplification. Pair-gain can extend the distance range for voice signals, but cannot

generally be used for DSL type data signals.

(5) Distribution cables. These typically consist of relatively low-capacity twisted-pair copper

sheaths that are run along individual streets, most commonly on telephone poles but in

some cases buried underground. Where the serving area of a wire center involves large

distances, such as in rural exchanges, signal amplification is sometimes required where

distances are particularly long. The introduction of Internet access services in the mid-

1990s brought with it an additional challenge for distribution network architecture. The

data transmission rate (bits per second or “bps”) of Digital Subscriber Line (DSL) drops

off precipitously as the length of the copper connection between the customer and the

central office increases. The use of DSL is not even feasible where the route distance of

the copper segment exceeds about 18,000 feet,

51

which translates roughly into about three

miles from the central office. The use of fiber optic feeder facilities reduces this effect,

because the relevant distance for this purpose is limited to the copper segment – i.e., the

portion that is between the customer and the Remote Terminal where the copper pair is

cross-connected to the fiber-fed equipment. By extending fiber optic feeder runs more

deeply into local neighborhoods, the ability to provide DSL across larger areas is

increased. This combination of fiber optic feeder and copper distribution is known as

“Fiber-to-the-Node” (“FTTN”) architecture. The closer that the carrier can bring fiber to

51. Goleniewski, Lillian, Telecommunications Essentials, Second Edition: The Complete Global Source,

Addison-Wesley, 2007, at 49-50.

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its customers, the higher the data rate (“bandwidth”) that it can offer its customers.

52

A

variant of FTTN is referred to as “fiber-to-the-curb” (“FTTC”). In an FTTC architecture,

fiber cable is extended much closer to the end user – generally within 1000 feet – and is

then connected by twisted-pair copper (in the case of ILECs) or coaxial cable (in the case

of cable TV infrastructure).

(6) Drop wire. The “drop wire” is the final connection between the telco distribution network

and the customer’s premises. It typically connects the customer’s premises to a twisted

pair assigned to the customer at a telephone pole in close proximity to the customer’s

location. In the case of fiber-to-the-premises (“FTTP”) distribution architectures

(sometimes referred to as “Fiber-to-the-Home” (“FTTH”)), the drop is also fiber optic

cable.

“Fiber-to-the-Node” (“FTTN”) vs. “Fiber-to-the-Premises” (“FTTP”). DSL technology can be

supported entirely over copper facilities, but at relatively slow data rates. Where fiber feeder

plant is available, DSL is provided utilizing a hybrid of those fiber optic cables connected to

copper distribution cables at a Remote Terminal (a “Node”). FTTP extends fiber all the way to

the customer’s premises. Under Verizon’s FiOS architecture, for example, a fiber cable pair

capable of serving up to 32 customers is extended into a neighborhood, where individual fiber

drop facilities are then connected to individual customer locations. In general, when Verizon

selected a wire center for FiOS deployment, it built-out virtually all of the serving area,

providing near-ubiquitous FiOS availability to all customers served from that wire center.

The outside plant distribution infrastructures of both AT&T California and Frontier California

employ a mix of distribution technologies, ranging from legacy twisted pair copper to fiber-to-

the-home. However, the deployment strategies of the two companies have been dramatically

different.

Frontier California

In 2006, Verizon Communications, the parent company, announced plans for an ambitious

investment program to deploy FTTP broadband to 18-million of its (then) 25.1-million residential

wireline subscribers.

53

By 2010, Verizon had deployed its FiOS-branded FTTP distribution

facilities to some 15.2-million homes. But then, in March of that year, Verizon announced that it

was suspending further deployment of FiOS plant, committing only to complete construction in

52. Cable TV distribution confronts a similar issue. The longer the coaxial cable segment, the slower the data

rate available to end user customers. Like ILECs, cable MSOs have also been extending their fiber runs deeper in

individual neighborhoods and closer to customers so as to provide the highest possible bandwidth.

53. Verizon Communications Inc. 2010 Annual Report, at 2.

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locations where FiOS deployment was already underway.

54

While the bulk of Verizon’s FiOS

investment was directed at its legacy Bell Atlantic markets in the northeast, certain former GTE-

served areas, including portions of the former GTE California, Texas, Florida and Washington

State markets, had also been upgraded with FTTP distribution facilities. As of the April 1, 2016

date when Frontier acquired Verizon California, FTTP plant deployed by Verizon was available

in 55 wire centers

55

serving areas with a population of roughly 1.44-million – or about 38.4% – of

the total population in areas served by the company. Since the acquisition, Frontier has added 59

wire centers, serving areas with another 2.32-million people to its FTTP network and, by the end

of 2017, some 68.4% of the population in Frontier California exchanges were capable of being

served via FTTP distribution facilities; in the non-FTTP portions of Frontier’s operating territory,

about 900,000 people (23.8%) live in areas where Frontier offers some form of (relatively slow

data rate) broadband, and the remaining roughly 300,000, have no broadband service available at

all.

The CPUC’s approval of the transfer of Verizon’s California ILEC to Frontier included the

Commission’s acceptance of a “partial settlement” between Frontier and several protesting parties

under which Frontier had make certain commitments to expand the availability of broadband

services within its operating footprint beyond those wire centers in which Verizon had built out

FTTP plant.

56

And, since acquiring the ILEC, Frontier California has expanded its broadband

footprint. In a tabulation provided to the Communications Division dated January 24, 2018,

Frontier identified a total of 229 “Broadband Equipped Central Offices,”

57

seemingly indicating

that 180 additional central offices beyond the initial 55 were now capable of offering broadband

service. In its response to CD Data Request 02-F, Frontier provided a total of 270 detailed maps

showing, for each of its wire centers, the distribution area technology at each geographic location

within the wire center serving area.

58

Frontier also provided the total population within the areas

served by each of its wire centers. Based upon ETI’s examination of these maps, it appears that,

in wire centers where FTTP has been deployed, FTTP is provided almost ubiquitously throughout

54. “Verizon to End Rollout of FiOS,” The Wall Street Journal, March 30, 2010.

http://www.wsj.com/articles/SB10001424052702303410404575151773432729614 [accessed on July 16, 2015].

55. CPUC Communications Division Staff.

56. A.15-03-005, D.15-12-005 (December 3, 2015

), 2015 Cal. PUC LEXIS 762, 326 P.U.R.4th 367 (Cal. P.U.C.

December 3, 2015), slip. op. at 57-59 (§3.2.4. The Joint Protesters Settlement; 71 (Conclusion 10); 77-78 (COL 5, 6,

7); and Appendix F (Joint Motion of Frontier Communications Corporation, Frontier Communications of America,

inc., the Utility Reform Net\ryork, the Office of Ratepayer Advocates and the Center for Accessible Technology for

Approval of Partial Settlement).

57. Frontier Response to DR-01F, “Frontier COs and equipment - added reconciliation to wirecenters on go 133d

final.xlsx”

58. Frontier Response to DR-05F, Attachment 4.

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Where some type of “broadband” service is available, there is considerable variation in its

capability and functionality. Table 3.7 identifies, for each Frontier California wire center, the

type of broadband service (or no broadband service) available to customers served. We

distinguish between “FTTP” and “non-FTTP” broadband. “FTTP” (Fiber-to-the-Premises)

provides very high data rates (download and upload speeds) potentially reaching and exceeding 1

Gbps. Frontier’s FTTP service was originally deployed by Verizon and marketed under

Verizon’s FiOS brand, which Frontier has retained under the 2016 acquisition. “Non-FTTP”

broadband is furnished primarily via Digital Subscriber Line (DSL) service over copper or by a

hybrid fiber/copper architecture (“Fiber-to-the-Node” (“FTTN”)). Depending upon the specific

technology available, data rates are considerably slower than with FTTP/FiOS.

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Table 3.7 (page 1 of 6)

FRONTIER CALIFORNIA

TYPES OF BROADBAND SERVICES

AT EACH CENTRAL OFFICE

CLLI Wire Center Population

No

Broadband

Non-FTTP

Broadband FTTP / FiOS

ADLNCAXF ADELANTO 10,725 X

ALPGCAXF ALPAUGH 208 X

ALPNCAXF ALDERPOINT 113 X

ANZACAXF ANZA 2,935 X

APVYCAXF APPLE VALLEY 26,192 X

ARHDCAXF ARROWHEAD 9,196 X

ARTSCAXF ARTESIA 27,827 X

AZUSCAXF AZUSA 18,274 X

BBCYCAXF BIG BEAR CITY 6,152 X

BBLKCAXF BIG BEAR LAKE 11,670 X

BDGRCAXF BADGER 206 X

BELRCAXF BEL AIR 16,626 X

BGPICAXF BIG PINE 465 X

BLFLCAXF BELLFLOWER 37,266 X

BLGRCAXF FLORENCE 18,873 X

BLPKCAXF BALDWIN PARK 38,085 X

BNNGCAXF BANNING 10,795 X

BNTNCAXF BENTON 186 X

BORNCAXF BORON 1,472 X

BRDNCAXF WASHINGTON STREET 29,840 X

BRMSCAXF BERRENDA MESA 79 X

BRPTCAXF BRIDGEPORT 533 X

BRSWCAXH BARSTOW 7,843 X

BRSWCAXJ SOUTH BARSTOW 5,706 X

BSHPCAXG BISHOP 7,937 X

BTNWCAXF BUTTONWILLOW 789 X

BUMTCAXF BEAUMONT 24,427 X

CCHLCAXF COACHELLA 11,863 X

CCMNCAXF CUCAMONGA 58,692 X

CFCYCAXF CALIFORNIA CITY 5,736 X

CHLKCAXF CHINA LAKE 3,719 X

CHNOCAXF CHINO 40,629 X

CHSPCAXF CALIF HOT SPRINGS 167 X

CLCYCAXG MAR VISTA 34,681 X

CLEMCAXF CLEMENTS 273 X

CLFXCAXF COLFAX 2,749 X

CLMSCAXF CALIMESA 9,646 X

CLMTCAXF CLAREMONT 32,564 X

CMRLCAXF CAMARILLO 36,879 X

CNCKCAXF CANTUA CREEK 235 X

COVNCAXF COVINA 42,731 X

CRCRCAXF CORCORAN 4,839 X

CRLKCAXF CROWLEY LAKE 7,868 X

CRLNCAXF CRESTLINE 10,590 X

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Table 3.7 (page 2 of 6)

CLLI Wire Center Population

No

Broadband

Non-FTTP

Broadband FTTP / FiOS

CRPRCAXF CARPINTERIA 8,805 X

CUYMCAXF CUYAMA 392 X

CVELCAXF COVELO 826 X

CZDRCAXG CAZADERO 635 X

DHSPCAXF DESERT HOT SPRINGS 23,615 X

DMBRCAXF DIAMOND BAR 16,627 X

DNLPCAXF DUNLAP 1,294 X

DSCTCAXG DESERT CENTER 308 X

DSHGCAXF DESERT HEIGHTS 1,038 X

DSKNCAXF DESERT KNOLLS 9,428 X

DSPLCAXF DOS PALOS 3,796 X

DSSHCAXF DESERT SHORES 1,106 X

DWNYCAXF DOWNEY 30,672 X

DWNYCAXG IMPERIAL 2,982 X

EDMTCAXF EDGEMONT 20,288 X

ELMGCAXF EL MIRAGE 337 X

ELRICAXF EL RIO 29,000 X

ELSNCAXF ELSINORE MAIN 24,156 X

ELSNCAXG ELSINORE GRAND 13,618 X

ELWDCAXF ELLWOOD 14,698 X

ETWNCAXF ETIWANDA 18,749 X

EXTRCAXF EXETER 5,678 X

FLWSCAXF FELLOWS 196 X

FRTNCAXF FARMINGTON 586 X

FRVLCAXF FARMERSVILLE 1,123 X

FTIRCAXF FORT IRWIN 2,822 X

FWLRCAXF FOWLER 4,599 X

GDLPCAXG GUADALUPE 4,096 X

GGVGCAXF GRANT GROVE 215 X

GLNDCAXF GLENDORA 22,086 X

GLRYCAXF GILROY 22,696 X

GLVLCAXF GLENNVILLE 311 X

GOLTCAXF GOLETA 21,315 X

GRHLCAXF GRANADA HILLS 33,232 X

GRVLCAXF GARBERVILLE 1,758 X

HEMTCAXF HEMET 48,442 X

HMLDCAXF HOMELAND 16,345 X

HMVYCAXF HOMESTEAD VALLEY 2,403 X

HNBHCAXF SLATER 29,143 X

HNBHCAXG HUNTINGTON BEACH 24,242 X

HNBHCAXH BUSHARD 32,362 X

HNBHCAXL WARNER 18,830 X

HNDLCAXF SILVER LAKES 1,422 X

HOPACAXF HOOPA 252 X

HRBHCAXA REDONDO 40,699 X

HSPRCAXF HESPERIA 47,103 X

HYFKCAXF HAYFORK 909 X

IDYLCAXF IDYLLWILD 3,917 X

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Table 3.7 (page 3 of 6)

CLLI Wire Center Population

No

Broadband

Non-FTTP

Broadband FTTP / FiOS

INDICAXG INDIO 31,667 X

INDPCAXF INDEPENDENCE 308 X

INYKCAXF INYOKERN 2,050 X

JNLKCAXF JUNE LAKE 454 X

JSTRCAXF JOSHUA TREE 4,951 X

KNLDCAXF KNIGHTS LANDING 316 X

KNWDCAXF KENWOOD 879 X

KRVLCAXF KERNVILLE 2,004 X

LAHBCAXF LA HABRA 23,777 X

LAPNCAXF ROWLAND 32,596 X

LAPNCAXG LA PUENTE 37,939 X

LAPNCAXL MAPLEGROVE 14,612 X

LAQNCAXG LA QUINTA 22,501 X

LCVYCAXF LUCERNE VALLEY 2,166 X

LGBHCAXF LAGUNA BEACH 17,750 X

LGGTCAXF LEGGETT 231 X

LKHGCAXF LAKE HUGHES 1,659 X

LKISCAXF LAKE ISABELLA 3,356 X

LMCVCAXF LEMON COVE 191 X

LMLNCAXF LOMA LINDA 14,821 X

LMPCCAXF LOMPOC 18,805 X

LMPCCAXG MESA 4,128 X

LNBHCAXF LONG BEACH MAIN 41,854 X

LNBHCAXG UPTOWN 30,129 X

LNBHCAXH MARKET 29,793 X

LNBHCAXL MARTIN L KING 18,053 X

LNBHCAXM CLARK 21,344 X

LNBHCAXS STADIUM 27,902 X

LNBHCAXT TERMINO 37,405 X

LNCSCAXF ANTELOPE 7,161 X

LNCSCAXG LANCASTER 42,848 X

LNDNCAXF LINDEN 1,273 X

LNDSCAXF LINDSAY 5,523 X

LNPNCAXF LONE PINE 584 X

LNWDCAXF LENWOOD 2,748 X

LSALCAXF LOS ALAMOS 22 X

LSGTCAXA BLOSSOM HILL 8,980 X

LSGTCAXF MONTEBELLO 11,291 X

LSGTCAXG MOUNTAIN 3,508 X

LSHLCAXF LOST HILLS 608 X

LSSRCAXF LOS SERRANOS 23,484 X

LTHPCAXF LATHROP 5,471 X

LVNGCAXF LEE VINING 71 X

LVRNCAXF LA VERNE 18,183 X

LYVLCAXF LAYTONVILLE 955 X

MALBCAXF ZUMA 5,728 X

MALBCAXG MALIBU 5,207 X

MCFACAXF MCFARLAND 3,576 X

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Table 3.7 (page 4 of 6)

CLLI Wire Center Population

No

Broadband

Non-FTTP

Broadband FTTP / FiOS

MCKTCAXF MCKITTRICK 79 X

MDRVCAXF MAD RIVER 356 X

MECCCAXF MECCA 2,117 X

MENTCAXF MENTONE 9,366 X

MMLKCAXF MAMMOTH LAKES 135 X

MNBHCAXF MANHATTAN 11,734 X

MNRVCAXG MONROVIA 30,834 X

MNTCCAXG MANTECA 30,620 X

MNTTCAXF MONTECITO 8,559 X

MRCPCAXF MARICOPA 446 X

MRHLCAXF MORGAN HILL 19,639 X

MRMNCAXF MIRAMONTE 259 X

MRVYCAXF MORONGO VALLEY 1,624 X

MSCYCAXF MUSCOY 16,457 X

MUGUCAXF MUGU 14,238 X

MURTCAXF MURRIETA 45,384 X

NEDWCAXF NORTH EDWARDS 684 X

NOVTCAXF NOVATO 20,223 X

NRWLCAXF NORWALK 29,864 X

NRWLCAXG ALONDRA 16,526 X

NSHRCAXF NORTH SHORE 758 X

NWBRCAXF NEWBERRY 1,069 X

NWPKCAXF NEWBURY PARK 18,253 X

OASSCAXF OASIS 2,391 X

OLNCCAXF OLANCHA 63 X

ONTRCAXF ONTARIO MAIN 38,545 X

ONTRCAXG ONTARIO SOUTH 16,449 X

ONTRCAXM ONTARIO AIRPORT 2,180 X

ORCTCAXG BRADLEY 17,592 X

ORLNCAXF ORLEANS 125 X

ORMACAXF ORO LOMA 211 X

OXNRCAXF OXNARD 27,038 X

OXNRCAXG MANTILLA 16,918 X

PACMCAXF PACOIMA 27,210 X

PCPLCAXF PACIFIC PALISADES 13,438 X

PCRVCAXF RIO HONDO 14,200 X

PDRYCAXF DEL REY 46,233 X

PERSCAXF PERRIS 33,166 X

PHLNCAXF PHELAN 10,257 X

PIRCCAXF PIERCY 45 X

PLDSCAXF PALM DESERT 46,087 X

PLSPCAXG PALM SPRINGS EAST 47,458 X

PNCKCAXF PINECREEK 614 X

PNYNCAXF PINYON 622 X

POMNCAXF POMONA 36,470 X

PRFDCAXF PARKFIELD 131 X

PSDNCAXF

SIERRA MADRE

HASTINGS 2,590 X

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Table 3.7 (page 5 of 6)

CLLI Wire Center Population

No

Broadband

Non-FTTP

Broadband FTTP / FiOS

QUVYCAXF QUAIL VALLEY 10,160 X

QZHLCAXF QUARTZ HILL 22,388 X

RBNSCAXG ROBBINS 66 X

RDBHCAXF EL NIDO 26,369 X

RDGCCAXG RIDGECREST 11,362 X

RDLDCAXF REDLANDS 32,943 X

RDLYCAXF REEDLEY 10,182 X

RIPNCAXF RIPON 7,730 X

RLHLCAXF ROLLING HILLS 20,390 X

RNBGCAXF RANDSBURG 101 X

RNCACAXF RANCHO CALIFORNIA 33,946 X

RNMGCAXF RANCHO MIRAGE 38,552 X

RNSPCAXF RUNNING SPRINGS 4,003 X

SERNCAXG SEA RANCH 1,495 X

SLBHCAXF ALAMITOS 39,806 X

SLCYCAXF SALTON CITY 1,707 X

SLGBCAXF ALISO 3,711 X

SLVNCAXG SANTA YNEZ 12,044 X

SMVYCAXF SUMMIT VALLEY 183 X

SNBBCAXF SANTA BARBARA 30,180 X

SNBBCAXG LAS POSITAS 21,061 X

SNBRCAXH MARSHALL 29,375 X

SNBRCAXK SAN BERNARDINO 34,814 X

SNBRCAXL WATERMAN 2,209 X

SNBRCAXN Norton 113 X

SNCYCAXF SUN CITY 35,544 X

SNDMCAXF SAN DIMAS 17,912 X

SNFNCAXG SAN FERNANDO 15,921 X

SNGRCAXF SANGER 9,951 X

SNJCCAXG SAN JACINTO 18,680 X

SNJQCAXF SAN JOAQUIN 812 X

SNLDCAXF SUNLAND/TUJUNGA 21,076 X

SNMGCAXF SAN MIGUEL 1,318 X

SNMNCAXG SANTA MONICA 30,981 X

SNMNCAXJ SUNSET 30,720 X

SNNGCAXG SNELLING 300 X

SNPLCAXF SANTA PAULA 12,047 X

SNTMCAXF SANTA MARIA 31,422 X

SNYMCAXF SUNNYMEAD 48,402 X

SPLVCAXF SEPULVEDA 40,630 X

SRMDCAXF SIERRA MADRE 8,109 X

STMRCAXF STRATHMORE 1,524 X

SURFCAXF SURF 2,270 X

SVYFCAXF SQUAW VALLEY 660 X

SYLMCAXF SYLMAR 22,045 X

TAFTCAXF TAFT 6,868 X

THOKCAXF THOUSAND OAKS 2 29,061 X

THOKCAXH CONEJO 12,806 X

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Table 3.7 (page 6 of 6)

CLLI Wire Center Population

No

Broadband

Non-FTTP

Broadband FTTP / FiOS

THPLCAXF THOUSAND PALMS 4,723 X

THRMCAXF THERMAL 1,348 X

TMCLCAXG TEMECULA 1,448 X

TMCLCAXH REDHAWK 14,540 X

TMCVCAXH TIMBER COVE 305 X

TPNGCAXF TOPANGA 3,056 X

TRNCCAXF DEL AMO 16,180 X

TRNCCAXG PALOS VERDES 21,011 X

TRNQCAXF TRANQUILITY 322 X

TRONCAXF TRONA 1,448 X

TVVYCAXF TIVY VALLEY 1,495 X

TWPLCAXF TWENTYNINE PALMS 8,692 X

TWPLCAXG MARINE PALMS 1,504 X

UPLDCAXF UPLAND 40,853 X

VLVSCAXF VALLE VISTA 8,652 X

VTVLCAXA VICTORVILLE 50,221 X

WEMRCAXF WEIMAR 1,247 X

WHTNCAXF WHITEHORN 767 X

WHTRCAXF WHITTIER SOUTH 28,951 X

WHTRCAXG WHITWOOD 16,834 X

WHTRCAXH VALLEY VIEW 20,859 X

WHTRCAXJ PICO 21,309 X

WLANCAXF WEST LOS ANGELES 30,523 X

WLANCAXG WESTWOOD 19,101 X

WLANCAXH BUNDY WLA 28,845 X

WLANCAXJ UNIVERSITY 9,224 X

WLDNCAXF WELDON 1,434 X

WLNTCAXF WALNUT 21,539 X

WMNSCAXF WESTMINSTER 59,132 X

WRWDCAXF WRIGHTWOOD 2,893 X

WVVLCAXG WEAVERVILLE 2,031 X

WWCKCAXF WILLOW CREEK 888 X

YCVYCAXG YUCCA VALLEY 12,566 X

YERMCAXF YERMO 929 X

YUCPCAXF YUCAIPA 17,317 X

Source: Frontier Responses to DR-02F, DR-05F

For most of the 114 Frontier wire centers that have been substantially upgraded to FTTP, the

FTTP deployment generally covers all, or nearly all, of the area served by each wire center.

Figure 3.7 provides an example of this approach for the Long Beach exchange, which consists of

seven (7) wire centers. Only one of these – LNBHCAXF (Long Beach Main) was included

among the 55 Verizon wire centers identified as having been equipped to provide FiOS.

Therefore, it would appear that the other six Long Beach wire centers have been upgraded in the

2-1/2 years following the Frontier takeover of the company.

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Long Beach –

Figure 3.7. Frontier Distribution Area Technology – Long Beach wire centers

Long Beach –

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AT&T California

Unlike Verizon, AT&T has never committed to a massive FTTP deployment, although some

FTTP plant has been constructed in limited portions of a small number of AT&T California wire

centers. “Broadband Availability” data compiled by the CPUC’s Communications Division

indicates the extent to which each category of broadband technology is available to households

served by AT&T, as summarized in Table 3.8 below:

Table 3.8

AT&T CALIFORNIA

HOUSEHOLDS AT WHICH SOME FORM OF “BROADBAND” SERVICE

IS CURRENTLY AVAILABLE

Technology