Industry Talks Down Rural Calling Problems, as CPUC Mulls Action

“In many rural areas of the state, wireless service is spotty, unreliable or nonexistent,” commented the center, a consumer group that advocates for people with disabilities. “In the same areas, the physical plant supporting wireline service is not well maintained. Outages are frequent and repairs are slow (and often limited in effectiveness). Broadband access is also limited in many locations, with few options and slow speeds." The reliability issues increase risk to rural residents during emergencies and burdens them in daily lives, it said. The center urged the CPUC to move forward with a pending network study "to obtain a better perspective of the extent of problems with network facilities, and then build a plan that evaluates and prioritizes appropriate action in response." The agency should reconsider a recent decision not to adopt increased reporting standards for rural outages, it said.

Some industry commenters said they don’t see a big problem. AT&T said an internal investigation found no complaints about call failures from customers, other carriers or regulatory agencies. The company also found no instance in which AT&T failed to complete a 211 nationwide help center call, a problem claimed by some consumers in the proceeding. Cox Communications said the examples of problems in the record, including the Frontier/Verizon California issues and a Verizon-Intrado outage, “do not reflect an industry-wide issue that could be considered in this proceeding.” The CPUC should close the proceeding, commented Cox. "There is no need for Commission action here, and waiting for future direction from the Legislature is the most appropriate and reasonable path forward.”

CTIA warned the state agency not to clash with work at its federal counterpart. “Consideration of rural outage reporting requirements, in addition to being outside the scope of the proceeding, would be ill-timed at best and unlawful at worst,” the group commented. "Not only did the Commission recently reject the imposition of state specific rural outage reporting requirements on wireless carriers, the FCC is actively considering rural network outage reporting standards designed to address the differing attributes of a rural area.” The FCC hasn’t finalized its rules, including reporting thresholds and a definition for rural areas, CTIA said. “Requiring wireless carriers serving rural areas to comply with differing reporting obligations in rural areas would, at minimum, impose unnecessary burdens and costs on wireless carriers seeking to serve rural areas in California. Any inconsistencies with federal requirements would also give rise to preemption concerns.” AT&T said it would be “duplicative and inefficient” for the CPUC to set up a reporting system for call completion failures because it can get the same information from the FCC Network Outage Reporting System.

LECs said they “share the Commission’s concern with rural call completion problems” and urged the CPUC to use enforcement, consumer education and coordination of carriers to resolve issues and disputes. Small LECs have experienced call completion problems and received complaints, but "do all they can to ensure that all calls to and from their subscribers complete promptly and without difficulty,” they wrote. They urged the CPUC to put intermediate companies under the lens, including-least cost routers that transport telephone traffic: "While some call completion failures might be traced to failures in the networks of local exchange carriers, because no network is perfect at all times such that it can be guaranteed to complete each and every call, the findings of the FCC and Congress seem to support the conclusion that the most significant rural call completion problems have involved issues with purposeful action by some intermediary carriers.”

Frontier continued to defend its handling of integration issues after migrating Verizon customers to its network April 1. The buyer said it "complied fully" with the CPUC decision that OK’d the Verizon acquisition. "Frontier will continue to meet all its commitments in that Decision, including its commitments to enhance service quality and improve network performance,” it said. "Frontier also has worked diligently to address and resolve customer issues in connection with the service cutover. ... Frontier has appeared at town halls, city and county meetings, legislative hearings, and at seven of the PPHs [public participation hearings] held thus far in this proceeding.”