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

Similar documents
VIA HAND DELIVERY. Re: Joshua S. Foster v. Appalachian Power Company P.S.C. Case No E-C. Dear Ms. Ferrell: July 17,2015

GIANOLA, BARNUM & WIGAL, L.C. Attorneys At Law

Leslie J. Anderson Supervising Attorney Public Service Commission of West Virginia 201 Brooks St. PO Box 812 Charleston, WV Dear Ms.

SAMPLE. This document is presented for guidance only and does not completely state either Oklahoma law or OCC regulations.

February 17, Dan Gilleon 1320 Columbia St. 200 San Diego, California 92101

1300 MOUNT KEMBLE AVENUE P.O. BOX 2075 MORRISTOWN, NEVJ JERSEY (973) FACSIMILE (973)

Case 3:14-cv PK Document 53 Filed 04/23/15 Page 1 of 7

IN THE SUPREME COURT OF FLORIDA. No. SC VERIFIED MOTION FOR DAN K. WEBB TO APPEAR PRO HAC VICE

IN THE SUPREME COURT OF FLORIDA. No. SC VERIFIED MOTION FOR STUART ALTSCHULER TO APPEAR PRO HAC VICE

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION. Plaintiff, Case No:

PUBLIC SERVICE COMMISSION OF WEST VIRGINIA CHARLESTON

BEFORE THE OIL AND GAS CONSERVATION COMMISSION OF THE STATE OF COLORADO ) ) ) ) ) ) ) ) ) APPLICATION

FILED: NEW YORK COUNTY CLERK 12/02/2013 INDEX NO /2012 NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 12/02/2013

Pre stonlgateslellis & RouvelaslMeeds LLP

ANSWER WITH AFFIRMATIVE DEFENSES

September 21, Docket No. ER

FILED: NEW YORK COUNTY CLERK 02/09/ :08 PM INDEX NO /2016 NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 02/09/2018

BEFORE THE OIL AND GAS CONSERVATION COMMISSION OF THE STATE OF COLORADO ) ) ) ) ) ) ) ) ) ) ) ) ) ) AMENDED APPLICATION

March 17, Very truly yours, PLUNKETT COONEY A T T O R N E Y S & C O U N S E L O R S A T L A W

SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ORANGE. Sam Sloan. Petitioner INDEX No against-

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C FORM SD SPECIALIZED DISCLOSURE REPORT FACEBOOK, INC.

FILED: NEW YORK COUNTY CLERK 11/04/ :38 PM INDEX NO /2016 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 11/04/2016

August 6, Ms. Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, NE Washington, DC 20426

KATZ, KANTOR 8c PERKING, PLLC

Case 1:12-cv JD Document 37 Filed 07/16/13 Page 1 of 6 UNITED STATES DISTRICT COURT DISTRICT OF NEW HAMPSHIRE

2200 Noll Drive Lancaster, PA Latitude: N 40º (NAD 83) Longitude: W 76º (NAD 83) 362 AMSL

IN THE VANDERBURGH CIRCUIT COURT

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO EASTERN DIVISION ) ) ) ) ) ) ) ) ) ) ) ) )

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION. Plaintiff, Case No:

ELECTROMAGNETIC FIELD (EMF) STRENGTH MEASUREMENTS SITE: ROHRERSTOWN ELEMENTARY SCHOOL OCTOBER 16, 2017

THE MATTER : BEFORE THE SCHOOL

FILED: NEW YORK COUNTY CLERK 09/30/ /16/ :04 02:25 PM INDEX NO /2014 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 09/30/2014

FILED: NEW YORK COUNTY CLERK 06/21/ :49 PM INDEX NO /2016 NYSCEF DOC. NO. 117 RECEIVED NYSCEF: 06/21/2017

NEW YORK STOCK EXCHANGE LLC OFFICE OF HEARING OFFICERS

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

FILED: NEW YORK COUNTY CLERK 09/26/ :02 PM INDEX NO /2017 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 09/26/2017

March 13, Certain Wireless Consumer Electronics Devices and Components Thereof, Inv. No. 337-TA-853

1. STANDARD OPERATING PROCEDURES 1.1 MISSION STATEMENT

BEFORE THE OIL AND GAS CONSERVATION COMMISSION OF THE STATE OF COLORADO ) ) ) ) ) ) ) ) ) ) ) ) ) ) AMENDED APPLICATION

TOWNSHIP OF MAHWAH BOARD OF HEALTH MINUTES January 12, 2016

BEFORE THE CORPORATION COMMISSION OF THE STATE OF OKLAHOMA. Contempt, Fines and Compliance with Commission Rules

THIS IS AN ASBESTOS LITIGATION CASE FILED UNDER N.Y.C.A.L.

BEFORE THE SCHOOL IN THE MATTER OF

SHARED TENANT SERVICE (STS) ARRANGEMENTS

BEFORE THE OIL AND GAS CONSERVATION COMMISSION OF THE STATE OF COLORADO APPLICATION

THIS IS AN ASBESTOS LITIGATION CASE FILED UNDER N.Y.C.A.L.

IN THE CIRCUIT COURT FOR THE STATE OF OREGON FOR THE COUNTY OF MULTNOMAH. Case No. COMPLAINT

Case 3:02-cv EBB Document 34 Filed 01/20/2004 Page 1 of 13 UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT. Plaintiff,

Case 2:12-cv RJS-DBP Document 184 Filed 08/26/15 Page 1 of 12 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF UTAH CENTRAL DIVISION

Case 1:11-cv JSR Document 33 Filed 01/20/12 Page 1 of 9

Petition for Reconsideration by Lake Benton Power Partners, LLC Docket No. E002/M

FILED: NEW YORK COUNTY CLERK 02/24/2014 INDEX NO /2013 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 02/24/2014. Exhibit 1

Fraser Trebilcock Davis & Dunlap, P.C.

FILED: NEW YORK COUNTY CLERK 04/22/2013 INDEX NO /2013 NYSCEF DOC. NO. 18 RECEIVED NYSCEF: 04/22/2013

WHITE & CLYBUrn Law Offices phone: (304) faxz(304) Sixth Street Moundsville, WV Secretary

STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION COUNTY OF IREDELL FILE NO. 07 CRS 61136,

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA ) ) ) ) ) ) ) ) )

Case 5:10-cv MWB Document 62-2 Filed 07/01/11 Page 1 of 6 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF IOWA WESTERN DIVISION

FILED: NEW YORK COUNTY CLERK 09/15/ :25 PM INDEX NO /2016 NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 09/15/2016

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. ) ) ) ) )

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

REPLY OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) TO PROTESTS AND REQUESTS FOR HEARINGS

Re: Ruby Pipeline Project; Docket No. CP ; Response to Comments from Mr. Randy Largent, Landman for Newmont Mining Corporation

Mika Meyers Beckett & Jones PLC

BEFORE THE ARKANSAS WORKERS COMPENSATION COMMISSION CLAIM NO. G STEVEN BROWNING, EMPLOYEE CENTRAL ADJUSTMENT COMPANY, INC.

Fiscal 2007 Environmental Technology Verification Pilot Program Implementation Guidelines

Your SBIR Data Rights and How to Protect Them

Section 12 Original Contents Sheet 1. B. Conditions and Limitations. C. Regulations. 1. Concurrence 2. Exceptions. D. Specific Company Services

UNITED STATES DEPARTMENT OF AGRICULTURE BEFORE THE SECRETARY OF AGRICULTURE

JEFFERSON LAB TECHNICAL ENGINEERING & DEVELOPMENT FACILITY (TEDF ONE) Newport News, Virginia

am- Harrahs CHESTER CASINO & RACETRACK RECEIVED IRRC 2BIFEB (U A <*3<* February 7,2011

SUPREME COURT OF FLORIDA CASE NO. SC AMENDED VERIFIED MOTION FOR ADMISSION PRO HAC VICE

TRAFFIC ENGINEERING DIVISION

VOLUSIA COUNTY SHERIFF'S OFFICE INTERNAL AFFAIRS

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C

Pennsylvania Public Utility Commission v. PECO Energy Company Docket R , C , C

IN THE JUSTICE COURT/CITY COURT IN AND FOR THE COUNTY OF GALLATIN, MONTANA ************************************************ Cause No.17<11~3t.

July 11, If you have any questions or concerns with the enclosed, please do not hesitate to contact. Very truly yours,

VIA ELECTRONIC FILING SYSTEM AND ELECTRONIC MAIL

McDowell Rackner & Gibson PC

)(

Product Guide Verizon Delaware LLC. Section 31 Delaware LLC Original Sheet 1. Connection With Certain Facilities of Others

University of West Georgia Summary Report Investigation of Allegations Made Against the Vice President of University Advancement April 8, 2011

FILED: NEW YORK COUNTY CLERK 04/20/ :23 PM INDEX NO /2017 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/20/2017

Thursday, November 2, 2017

STANDARD SPECIFICATIONS SECTION SUBMITTAL PROCEDURES

BEFORE THE OIL AND GAS CONSERVATION COMMISSION OF THE STATE OF COLORADO CAUSE NO: DOCKET NO: APPLICATION

Advice No Rule 8 Metering and Schedule 300 Charges as Defined by Rules and Regulations

FILED: SUFFOLK COUNTY CLERK 07/14/ :47 PM INDEX NO /2015 NYSCEF DOC. NO. 193 RECEIVED NYSCEF: 07/14/2017

APPLICATION TO AMEND CERTIFICATE OF DEATH

SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA CLARA. Cross-Complainant Western National Construction ("Western") in this action.

Case 4:14-cv BRW Document 58 Filed 12/04/15 Page 1 of 13

UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION

THIRD SCHEDULE Form of Application For A Revised Disability Access Certificate Article 20E(2)

Voluntary Paternity Acknowledgment. Angie Saleeby Vital Records Operations Manager PHSIS

Truckee Fire Protection District Board of Directors

SITE PLAN Application Packet (Required For All Non-Residential Development Projects)

FILED: NEW YORK COUNTY CLERK 05/22/ :14 PM INDEX NO /2013 NYSCEF DOC. NO. 180 RECEIVED NYSCEF: 05/22/2015

December 5, Dear Ms. Kale:

Please sign the signature page of the report and keep it in your files as proof that the product has been tested.

Transcription:

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 25396 (304) 344-7644 JoseDh.Starsick@FTR.com Via Hand Delivery Ingrid Ferrell Executive Secretary Public Service Commission 201 Brooks Street Charleston, West Virginia 25323 Re: 18-1545-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

PUBLIC SERVICE COMMISSION OF WEST VIRGINIA CHARLESTON CASE NO. 18-1545-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

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

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

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 25314 (304) 344-6303 Joseph.Starsick@F'I'R.com Joshua.Johnson @FTR.com Attorneys for Frontier West Virginia Inc. 4

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. 18-1545-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, 201 9. hf NOTARYP LIC

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 9 1 1 Mineral County 9 1 1 Center 392 Pine Swamp Road Keyser, WV 26726 Complainant Joseph J. Starsick, Jr. (WV State Bar #3576)