20050929_1339.pdf

DECISION MEMORANDUM
TO:CO MMISSI 0 NER KJELLAND ER
COMMISSIONER SMITH
COMMISSIONER HANSEN
COMMISSION SECRETARY
LEGAL
WORKING FILE
FROM:CAROL COOPER
DATE:SEPTEMBER 27, 2005
RE:COMPLAINT OF TOM BROOKS, POLLOCK, IDAHO, AGAINST
FRONTIER COMMUNICATIONS.
BACKGROUND
On August 5, 2005, Tom Brooks filed a complaint regarding a telephone outage due to a
fiber optic line being cut - the second outage in less than a year. The Commission Staff received
a written letter with additional details on August 9, 2005 (attached). Mr. Brooks maintains that
when the fiber optic line is cut, the customers have no ability to reach law enforcement, fire and
medical emergency services by calling 911. It prohibits calling long distance, including 800
services. Mr. Brooks blames Frontier Communications for being irresponsible and negligent.
He is asking for a secondary system such as microwave to give them continued service.
I sent Mr. Brooks a written response on August 18 2005 (attached) acknowledging that a
contractor had cut the fiber optic cable between McCall and New Meadows, and service was out
for approximately 3 hours on August 2, 2005. I also summarized the results of my investigation
which confirmed that Idaho County has not subscribed to dedicated trunks for the routing of
emergency services at Pollock, and instead uses the regular telephone lines. However, when the
fiber optic cable is cut, customers in Pollock do have local calling within the 628 prefix. When
Frontier is made aware of an outage such as this, the local Sheriff is notified by radio and the
local emergency numbers (all with a 628 prefix) are manned for the duration of the outage.
explained that Frontier Communications had no order for dedicated trunks from the County, and
urged Mr. Brooks to contact the Idaho County Commissioners regarding their decision to use
regular telephone lines instead of dedicated trunks for 911 services.
DECISION MEMORANDUM SEPTEMBER 27 2005
A second letter was received from Mr. Brooks on August 25, 2005 (attached) stating that
he was "amazed that since this matter involves life-and-death communications deficiencies of
Frontier/Citizens Communications..., that your Public Utilities Commission treated my earlier
letter as 'informal'" He is asking that his complaint be considered a "formal" complaint. He
contends that the fiber optic trunk between Riggins and McCall exchanges has been very poorly
engineered and placed by Frontier, and
, "
The inability to call out of the Riggins exchange during
these cable cuts is truly a life-and-death emergency situation for over 500 Frontier telephone
customers in the Little Salmon River Valley." There are no other service providers in his area
and no cellular services. He states "Frontier holds the ultimate accountability to assure
communications during emergencies for their customers.
. . "
Listed below are the reasons given in his letter asking for a formal investigation:
There is no landline, microwave or satellite redundancy provided by Frontier to
protect their customers.
We were unable to call doctors or the hospital in McCall, prefix "634"
We were unable to dial Boise for Life Flight medical emergencies.
Our 24/7, monitored fire and burglary alarms were ineffective, because they are
programmed to call long distance to remote monitoring centers.
We were unable to dial Grangeville for residential fire emergencies, or to report forest
fires.
. We were unable to call Grangeville for law enforcement services.
Frontier Communications confirmed that contractors have cut the fiber optic cable twice
in the past 12 months. These cuts were not related or in the same vicinity.
September 13 2004 service was out for five hours and on August 2 2005 for two hours and 57
minutes. There have been no reported local service outages on Mr. Brooks' line. The monthly
cost of dedicated 911 trunks between Pollock and Grangeville is estimated at $3290. In addition
installation costs may be prohibitive, as facilities over White Bird hill do not exist. The current
911 services are routed over the public switched network, and the Company has no pending
order for dedicated trunks at this time.
DECISION MEMORANDUM SEPTEMBER 27, 2005
ST AFF ANALYSIS AND RECOMMENDATION
Staff understands Mr. Brooks' concerns , and agrees that 911 emergency service is a vital
service. However, Staff finds no basis for the Commission to initiate a formal investigation into
this dispute. Frontier Communications provides service as requested by its customers, which in
the case of 911 service, is Idaho County. Frontier Communications has not failed to fulfill
service orders in the Pollock exchange or otherwise failed to serve its customers. The current
911 services are routed over the public switched network, as they are in several other Idaho
communities. County Commissioners chose between no 911 service and 911 service over the
public network when dedicated lines are economically prohibited. Frontier cannot guarantee
continuity of service 100% of the time, due to factors beyond its control for either toll or local
services. The Company is not required to provide redundancy without compensation so that
service will never be interrupted. Therefore, Staff does not recommend this complaint be
considered as a formal complaint.
COMMISSION DECISION
Does the Commission agree that there is no basis for initiating a formal complaint against
Frontier Communications?
Does the Commission wish to accept this as a formal complaint and assign a case number
for investigation?
Attachments
i:dmemos/dmemo.brooks
DECISION MEMORANDUM SEPTEMBER 27, 2005
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Formal Complaint against Frontier/Citizen Communications 8~4 i:
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August 5 2005
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Ms C. 1. Young, Consumer Compliance Investigator
Idaho State Public Utilities Commission - [phone]
PO Box 83720
Boise, ill 83720
RE: Life-Endan2erin~ Out!!ges of 1" Emer2ence S~rvice Telephone Access
Dear Ms. Young:
We live in Pollock, Idaho. We have telephone service through Frontier, from the Riggins
Central Office and Riggins Exchange. Our telephone number is [phone].
This week, on Tuesday, for the second time in less than a year, our ability to reach law
enforcement, fire and medical emergency services was not available for over Y2 day!
This happened as recently as September of last year, as documented in the enclosure.
The last time this happened we were told that the cable between Riggins and McCall was
severed; that there was no redundancy in the 9-1 Emergency Services circuit!
It seems that Frontier has done absolutely nothing to remedy this egregious oversight
since the last OCCUITence.
We were informed on both occasions that every telephone customer in the Riggins
Exchange was adversely affected by these outages. Not only were we unable to dial out
of the "628" prefix to adjacent communities, we were unable to call long distance or to
reach a Frontier operator for any manner of dialing assistance.
In short, hundreds of customers were without access to any emergency services. This
shortcoming is only one of many with the Frontier telephone service. This situation
created by Frontier is not only unacceptable, it is irresponsible, negligent and perhaps
criminal as well.
We hope this formal complaint is sufficient for the Idaho Public Utilities Commission to
take action against Frontier to remedy this very serious matter quickly, once-and-for-all.
Sincerely,i/jTom Brooks
PO Box 244
Pollock, ill 83547
Enclosures: Letters of 4/16/04 and 9/14/04 to Frontier Communications
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Preliminary Complaint Pending Formal Complaint - [phone]
September 14 2004
Mike Giles, Plant Service Center Manager
Frontier/Citizens Communications
9260 E Stockton BI
Elk Grove, CA 95624
Dear Mr. Giles:
Yesterday, once again customers in our prefix in the Riggins exchange of Idaho were
unable to dial out except to other Frontier Communications customers in the (208) "628"
prefix of the Riggins exchange.
This meant that a call to our closest tandem switching center, prefix "634" in McCall
Idaho was not possible.
In fact, calls to any prefix other than our own, even to other local calling area prefixes
were not possible.
Long distance calls out of our area code were not possible. Therefore, a timely trouble
report to your 800 area code could not be placed and logged. In fact, all calls out of prefix
628" were blocked with "All Circuits Busy" recordings. This went on ITom about
8:30am to 2:45pm! As I indicated earlier, this was not the first occurrence of this
dangerous situation.
Inconvenience is not the main issue or problem. The real problem is that in this rural
mountainous area, our only link to emergency services for medical and wildfire
situations is by your Frontier telephone service, to This critical emer1!enCV
service access was also not available for the e~tire time cited above! Moreover. even i(
!!1!vone in our 628" Jvould have tried to call Life FliJfht in either Boise. Idaho
or Missoula. Montana. ofl out of area code ca(ls were b~ocked wifh four "All Circuits
Busv " recordin1!s!
I will be filing a copy of this preliminary complaint with our Grangeville, Idaho "
call center, as well as with our local people at the Salmon River Rural Fire District and
with the State of Idaho Emergency Services office.
I am hereby requesting a written, signed response as to the cause of my 9/14/04AM
trouble report, its solution and your business plan as to preventing these global "All
Circuits Busy" occurrences in the future.
I1#.Tom Brooks
PO Box 244
Pollock, ill 83547
CCs:
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Service Complaint - 208-628-4160
Frontier
Citizens " Communications" Company
PO Box 3 609
Kingman, AZ 86402-3609
April 16, 2004
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To Whom It May Concern:
We have had a series of "no dial tone" occurrences of recent. We are over 1/8 mile ftom
our nearest neighbor. We are in an area that is at least 4-1/2 miles and 25 minutes down a
rural, mountain road ftom the nearest coin telephone. It is not feasible to run to the
nearest working telephone service to even report the outages. Without telephone service
we are not only isolated and unable to conduct affairs, but our safety and security are
compromised. There is no access to fire services, emergency medical services or law
enforcement agencies.
Yesterday, April 15, we were without dial tone, unable to make or receive calls for the
second time in a month. The period of outage yesterday was all day long. Yesterday I was
unable make or receive numerous business-related calls, schedule medical and dental
appointments, or to handle multiple family matters for my 88 year old mother. Of course
I could not receive calls as well.
This morning when I got up early to attempt to begin to make up for yesterday, once
again we have no dial tone. It is now 6:30am.
Be advised that:
* This morning we must make anothyr wasted, time-consuming trip to the closest
neighbor to attempt to get the service corrected.
* We will travel the time and distance necessary to mail this formal complaint.
We have no other choices.
* We will file this complaint with the Idaho Public Utilities Commission.
* While "bypass" will not ever be a likely alternative to us in this rural area
cellular service will eventually be available. At such time we will leave Frontier
for the fITst 21 st Century solution that becomes available.
* We expect billing adjustments, along with a letter explaining your methods for
correcting the service outages that we continue to experience.
Sincerely
CtfoJ4Y
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Tom Brooks - PO Box 244, 77 Chukar Run, Whitewater Wilderness, Pollock, ill 83547
IDAHO
PUBLIC UTIL.ITIES
com miSSion
Dirk Kempthorne, Governor
o. Box 83720, Boise, Idaho 83720-0074
August 18, 2005
Paul Kjellander, President
Marsha H. Smith, Commissioner
Dennis S. Hansen, Commissioner
T om Brooks
P. O. Box 244
Pollock, ill 83547
Dear Mr. Brooks:
. I. have confirmed with Frontier Communications that on Tuesday, August 2, 2005 , the fibet -optic
cable running between McCall andNew-Meadowswascutby acoptractbr at 12:25 p.m. and
restoredby3:22 p.m.
. -
You are con-ect that the current routing of emergency services such as 911 have no dedicated
trunks at this time. The decision to use the regular telephone system for 911 calls was made by
the County Sheriff and County Commissioners. Frontier Communications is required to serve
customers with two-way voice communication. Additional services such as dedicated trunks
would have to be ordered and paid for by the party requesting that service. I would guess that
the county has probably looked into the cost of the dedicated lines and determined the cost to beprohibitive.
There is a process in place for when telephone outages occur. Frontier contacts the County
Sheriff and advises them of the outage and that only local exchange dialing is available in that
area. The local Sheriff's office is then notified via radio, and the local emergency service
numbers are manned for the Sheriff (628-3738), Fire 628-3792), and Ambulance (628-3394).
I have learned that Frontier is working on alternative trunk routing to avoid the 911 services
drop-off, but this does not mean that a fiber cut would not block the alternative SS7 trunk routing
as well.
If you have additional questions regarding the reasons for not using dedicated trunks, you need to
ask the Idaho County Commissioners.
Sincerely,
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C. J. Cooper
Utilities Compliance Investigator
cc: Frontier Communications
Located at 472 West Washington Street , Boise, Idaho 83702
Telephone: [phone] Facsimile: [phone]
Second Formal Complaint against Frontier/Citizen Communications
August 24, 2005
Ms C. 1. Cooper, Consumer Compliance Investigator
Idaho State Public Utilities Commission [phone]
PO Box 83720
Boise ID 83720
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RE: Life-Endan2erin2 Outa2es ofF.S. Telephone Access
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We talked on Monday by telephone. I now have your written reply to the earlier
complaint. Your letter, however, only addresses the faulty "1" services.
Dear Ms. Cooper:
First, allow me to apologize for the name mistake on my earlier letter.
I was told your last name was "Young" when I originally called.
Frankly, I am amazed that since this matter involves life-and-death communications
deficiencies of Frontier/Citizens Communications in the Little Salmon River V alley, that
your Public Utilities Commis-sion treated my earlier letter as "informal"
THE FACTS REMAIN:
There have been two cable cuts in less than 6 months which have caused our inability to
call out of the Riggins exchange. Last September when this happened we were without
capabilities to dial out of our valley for a much longer period of time.
It appears that the fiber optic trunk between the Riggins and McCall exchanges has very
likely been very poorly engineered and placed by Frontier.
The inability to call out of the Riggins exchange during these cable cuts is truly a life-
and-death emergency situation for over 500 Frontier telephone customers in the Little
Salmon River Valley.
There is no land line, microwave or satellite redundancy provided by Frontier
protect their customers.
We were unable to call doctors or the hospital in McCall, prefIX 634"
We were unable to dial Boise for Life Flight medical emergencies.
Our 24/7 monitored fire and burglary alarms were ineffective, because they are
programmed iocailiong distance to remote monitoring centers.
We were unable to dial Grangeville for residential fire emergencies, or to report
forest fires.
We were unable to call Grangeville for law enforcement services.
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August 24, 2005 Letter to C. 1. Young, Idaho Public Utilities Commission
We have no other choices for our telephone communications. We have no cellular
services available. There are no other telephone companies allowed to compete against
Frontier for their miserable service in the Little Salmon River Valley.
If Frontier is allowed to continue serving the telecommunications needs of customers in
the Little Salmon River Valley, the buck stops at Frontier. They possess no credible
excuses. There must be no divided responsibility for the solutions. Frontier holds the
ultimate accountability to assure communications during emergencies for their customers
here as well as elsewhere in their operating territories.
The ftreservices in our area are staffed on a volunteer basis. Full time fire personnel from
the U. S. Forest Service and from Grangeville are only available to average citizens by
telephone. The same situation applies to our law enforcement services.
The Riggins Sheriff Station is also staffed only on a part-time basis, so calling them is no
solution to our inability to call out of the Riggins exchange during cable cut situations.
All of these facts are in addition to the serious truths that "1 Emergency" services
were not available during these trunk cable outages.
The above facts do not even contemplate increased telecommunications requirements to
reach cri~is services for any terrorist activities, or biological or nuclear catastrophes.
In addition, our area is within the fallout patterns of both the Eastern Washington and
Eastern Idaho nuclear facilities, should radiation emergencies occur there.
The Idaho County Commissioners have no concern for assuring that our P.O. T . S.
functions efficiently to serve our emergency telecommunications needs in the Little
Salmon River Valley. They are unproductive, ineffective part-time entities who appear
content to serve only as lackeys for farmers and developers.
The Idaho Public Utilities Commission should not regard this matter as frivolous or
subordinate to other issues before them. We need your help in this grave matter.
I will await a case number in your written reply for this second formal complaint.
~~rely,
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Tom Brooks - [phone]
PO Box 244
Pollock, ill 83547
CCs: President, Whitewater Wilderness Homeowner s Association;
Chief, Salmon River Rural Fire Department; Mayor, City of Riggins