Via Hand Delivery T-C Mineral County 911 v. Frontier West Virginia Inc. co M MU N I c AT I o N s

Transcription

1 co M MU N I c AT I o N s JOSEPH J. STARSICK, JR. Associate General Counsel Frontier Communications 1500 MacCorkle Ave., S.E. Charleston, West Virginia (304) JoseDh.Starsick@FTR.com Via Hand Delivery Ingrid Ferrell Executive Secretary Public Service Commission 201 Brooks Street Charleston, West Virginia Re: T-C Mineral County 911 v. Frontier West Virginia Inc. Dear Ms. Ferrell: Y Please find enclosed for filing in the original plus 12 copies of the Answer of Frontier West Virginia Inc. in the above-referenced matter. Thank you for your attention to this matter. Sincerely, /$y@/&&s=h os h J. arsick, Jr. (State Bar No. 3576) JJSjr/sc Enclosure cc: Luke McKenzie, Complainant Mineral County 911 Angie McCall Frontier

2 PUBLIC SERVICE COMMISSION OF WEST VIRGINIA CHARLESTON CASE NO T-C MINERAL COUNTY 911, Complainant, V. FRONTIER WEST VIRGINIA INC. a public utility, Defendant. ANSWER OF FRONTIER WEST VIRGINIA INC. Defendant, Frontier West Virginia Inc. ( Frontier ), for its Answer to the Complaint filed in this proceeding, says: 1. In response to Paragraph 1 of the Complaint, Frontier admits it is a public utility subject to the provisions of Chapter 24 of the West Virginia Code. 2. In response to Paragraph 2 of the Complaint, Frontier says: a. Frontier is and was in full compliance with all applicable standards and rules regarding 911. Frontier takes and has taken the Complaint and the underlying situation with extreme seriousness. b. Upon information and belief, including information supplied to Frontier from Mineral County 91 I, Frontier s understanding of the incident that caused the 911 outage is as follows. In the early morning hours of November 21, 2018, a hit-and-run driver struck and damaged a pole along Jersey Mountain Road, north of US Route 50 near Romney, West

3 Virginia. The responding ambulance apparently struck the low-hanging facilities resulting from the accident, damaging an additional three poles. At some point, first responders purposely cut the facilities, based on their professional judgment at the scene. The facilities cut or otherwise damaged included 911 circuits, thus unfortunately causing the outage. c. These 911 circuits were interoffice facilities ( IOF ) in Frontier s network serving Mineral County. Although the circuits were redundant, they were not route-redundant - meaning that the primary and redundant IOF 911 circuits did not run along different physical paths. In addition, the local 911 circuits within the wire center, connecting the 911 center to Frontier s central office, were not route-redundant. However, Mineral County 911 is responsible for any such local route redundancy, and has elected not to obtain it. d. No state or federal rules or industry standards mandate that either IOF or local 911 circuits must be route-redundant. Frontier reports all IOF 911 circuits that are not route-redundant to the Federal Communications Commission ( FCC ) on an annual basis. e. The 911 databases and selective routers in its Frontier s 911 Network serving West Virginia are completely redundant. f. In addition, Frontier s IOF circuits serving Mineral County previously had been route-redundant. The end-office equipment necessary for the route redundancy was part of the 911 network transferred to Frontier by Verizon. Consistent with the plan for the transfer, the redundant circuit path traversed facilities in Verizon s Maryland network, which mated the equipment in Verizon s network with the equipment in Frontier s network. g. The mated equipment was appropriately designed for this purpose, but support for the particular model in service in West Virginia was subsequently discontinued by the manufacturer. 2

4 h. Prior to the automobile accident, the network on this redundant path had begun experiencing data errors. As a result, Frontier s equipment had to be taken out of service shortly before the accident, and a new solution, if economically feasible and otherwise appropriate, found for route redundancy. i. In October 2018, Frontier appropriately and timely reported the loss of route-redundancy for Mineral County in its annual 9 11 filing to the FCC. j. After taking the equipment out of service, Frontier immediately began an engineering analysis of possible solutions, including any solution that might allow it to avoid depending on Verizon s portion of the network. k. Frontier diligently continues its study of whether there might be a solution that is not infeasible or otherwise undesirable. It is possible that an alternative solution might require traversing Verizon s Maryland network in a different manner, which would require the cooperation of Verizon. Frontier as of yet has no definite alternative to propose, but continues to work on the matter with a sense of urgency. At the present time, Frontier has no reason to believe that Verizon will not cooperate if a proposed solution is otherwise feasible. 3. Frontier has generally enjoyed a long and healthy relationship with the state s 911 centers. As noted, Frontier takes this matter with the utmost seriousness, as we know the 911 centers do. Frontier, Mineral County 911, and other affected 911 centers already have scheduled an initial meeting to discuss the issues the same day this Answer is due. We have no reason to believe that the parties will not be able to reach an acceptable resolution. 3

5 4. Pending final resolution and dismissal of this matter, Frontier respectfully reserves all defenses and objections, including without limitation the right to demand strict proof of each and every allegation of the Complaint not expressly admitted in this Answer. FRONTER WEST VIRGINIA INC. Affiant d-sd W ' J. Starsick, Jr. (WV State Bar #3576) Joshua A. Johnson (WV State Bar #12247) Frontier Communications 1500 MacCorkle Avenue, S.E. Charleston, West Virginia (304) Joseph.Starsick@F'I'R.com Attorneys for Frontier West Virginia Inc. 4

6 VERIFICATION STATE OF WEST VIRGINIA COUNTY OF MERCER I, Angela C. McCall, after first being duly sworn, state that I am State Government Affairs Manager of Frontier West Virginia Inc., and that, as State Government Affairs Manager, I am authorized to verify the Statement in Case No T-C and I state that said Verified Statement is true and correct to the best of my knowledge, information and belief. FRONTIER WEST VIRGINIA INC. Taken, sworn to and subscribed before me this 4* day of January, hf NOTARYP LIC

7 CERTIFICATE OF SERVICE I, Joseph J. Starsick, Jr., Counsel for Defendant Frontier West Virginia Inc., do hereby certify that I have served the foregoing Answer of Frontier West Virginia Inc. upon the parties of record by depositing a true copy thereof in an envelope in the United States mail, return receipt requested, this 4'h day of January 2019, addressed as follows: Luke McKenzie, Director Mineral County Mineral County Center 392 Pine Swamp Road Keyser, WV Complainant Joseph J. Starsick, Jr. (WV State Bar #3576)