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August 12,2009 Via Han
Sandra S. Squire Executive Secretary Public Service Commission 201 Brooks Street Charleston, West Virginia 25323
Re: Case No. 09-0871-T-PC
Dear Ms. Squire:
Please find enclosed for filing the original and one copy of the Responses to the Second Set of Interrogatories, Data Requests or Requests For Information Directed to Citizens Telecommunication Company of Wet Virginia, DBA Frontier Communications of West Virginia and Verizon West Virginia, Inc., by the Communications Workers of America, AFL-CIO in the referenced matter.
Thank you for your attention to this matter.
Very truly yours,
(State Bar I.D. #3576) JJSjrhc Enclosure
cc: Counsel of Record PUBLIC SERVICE COMMISSION OF WEST VIRGINIA Charleston
CASE NO. 09-0871-T-PC Joint Application of Frontier Communications Corporation and Verizon West Virginia Inc. and certain affiliates for approval of the transfer of Verizon’s local exchange and long distance business in West Virginia to companies to be owned and controlled by Frontier Communications Corporation.
RESPONSES TO THE SECOND SET OF INTERROGATORIES, DATA REQUESTS OR REQUESTS FOR INFORMATION DIRECTED TO CITIZENS TELECOMMUNICATION COMPANY OF WEST VIRGINIA, DBA FRONTIER COMMUNICATIONS OF WEST VIRGINIA AND VERIZON WEST VIRGINIA, INC. BY THE COMMUNICATIONS WORKERS OF AMERICA, AFL-CIO
Frontier Communications Corporation (“Frontier Communications” or “Frontier”), New
Communications Holdings, Inc. (“NCH”), New Communications ILEC Holdings, Inc.
(“NCIH”), New Communications Online and Long Distance, Inc. (“NewLD”), Verizon West
Virginia Inc. (“Verizon WV”), Verizon Long Distance, LLC (“VLD”) and Verizon Enterprise
Solutions, LLC (“VES”) (collectively, “Applicants”) hereby submit their responses to the
“Second Set of Interrogatories, Data Request or Requests for Information Directed to Citizens
Telecommunications Company of West Virginia, dba Frontier Communications of West Virginia and Verizon West Virginia, Inc.” served by the Communications Workers of America, AFL-CIO
(“CWA”) (“CWA Data Requests Set 2”), subject to the objections previously filed in this proceeding.b Applicants expressly reserve the right to supplement the responses set forth below.
Applicants note that these data requests were directed only to Citizens Telecommunications Company of West Virginia, dba Frontier Communications of West Virginia and Verizon West Virginia, Inc., not to CITIZENS TELECOMMUNICATIONS COMPANY OF WEST VIRGINIA DBA FRONTIER COMMUNICATIONS OF WEST VIRGINIA AND VERIZON WEST VIRGINIA, INC. WEST VIRGINIA PSC CASE NO. 09-0871-T-PC SECOND REQUEST FOR INFORMATION - CWA
Name of Person Preparing Response: Billy Jack Gregg Date of Response: August 12,2009
Request 1 Please provide a copy of each document provided to Mr. Gregg prior to his testimony by Frontier and/or Verizon as part of his work in this case.
Response 1 Because the response to this request involves materials which are confidential and proprietary, the materials will be provided upon the execution of an appropriate confidentiality agreement. Mr. Gregg understands that the CWA has executed such an agreement.
Applicants. However, Applicants have supplied answers as if the requests were properly directed to Applicants. CITIZENS TELECOMMUNICATIONS COMPANY OF WEST VIRGINIA DBA FRONTIER COMMUNICATIONS OF WEST VIRGINIA AND VERIZON WEST VIRGINIA, INC. WEST VIRGINIA PSC CASE NO. 09-0871-T-PC SECOND REQUEST FOR INFORMATION - CWA
Name of Person Preparing Response: Billy Jack Gregg Date of Response: August 12,2009
Request 2 Please provide a copy of each document provided to Mr. Gregg following his testimony by Frontier and/or Verizon as part of his work in this case.
Response 2 Because the response to this request involves materials which are confidential and proprietary, the materials will be provided upon the execution of an appropriate confidentiality agreement. Mr. Gregg understands that the CWA has executed such an agreement. CITIZENS TELECOMMUNICATIONS COMPANY OF WEST VIRGINIA DBA FRONTIER COMMUNICATIONS OF WEST VIRGINIA AND VERIZON WEST VIRGINIA, INC. WEST VIRGINIA PSC CASE NO. 09-0871-T-PC SECOND REQUEST FOR INFORMATION - CWA
Name of Person Preparing Response: Billy Jack Gregg Date of Response: August 12,2009
Request 3 Please produce a copy of Mr. Gregg’s contract with Frontier concerning this case.
Response 3 This document will be produced. CITIZENS TELECOMMUNICATIONS COMPANY OF WEST VIRGINIA DBA FRONTIER COMMUNICATIONS OF WEST VIRGINIA AND VERIZON WEST VIRGINIA, INC. WEST VIRGINIA PSC CASE NO. 09-0871-T-PC SECOND REQUEST FOR INFORMATION - CWA
Name of Person Preparing Response: Billy Jack Gregg Date of Response: August 12,2009
Request 4 Prior to his testimony, was Mr. Gregg given access to the internal financial statements of Verizon- West Virginia and/or of Frontier- West Virginia, prepared under Generally Accepted Accounting Principles (GAAP)? If yes, please provide.
Response 4 No. Prior to his testimony Mr. Gregg reviewed publicly available annual financial reports made to one or more of the SEC, FCC and West Virginia Public Service Commission by Verizon Communications, Frontier Communications, Verizon West Virginia and Frontier West Virginia. CITIZENS TELECOMMUNICATIONS COMPANY OF WEST VIRGINIA DBA FRONTIER COMMUNICATIONS OF WEST VIRGINIA AND VERIZON WEST VIRGINIA, INC. WEST VIRGINIA PSC CASE NO. 09-0871-T-PC SECOND REQUEST FOR INFORMATION - CWA
Name of Person Preparing Response: Billy Jack Gregg Date of Response: August 12,2009
Request 5 Subsequent to his testimony, was Mr. Gregg given access to the internal financial statements of Verizon-West Virginia and/or of Frontier-West Virginia, prepared under Generally Accepted Accounting Principles (GAAP)? If yes, please provide.
Response 5, No. CITIZENS TELECOMMUNICATIONS COMPANY OF WEST VIRGINIA DBA FRONTIER COMMUNICATIONS OF WEST VIRGINIA AND VERIZON WEST VIRGINIA, INC. WEST VIRGINIA PSC CASE NO. 09-0871-T-PC SECOND REQUEST FOR INFORMATION - CWA
Name of Person Preparing Response: Billy Jack Gregg Date of Response: August 12,2009
Request 6 What is Mr. Gregg’s understanding of the primary differences, if any, of financial data reported by Verizon and Frontier for the WV Annual Surveillance Reports and those prepared according to GAAP?
Response 6 There are differences between the financial reports made to the FCC and to the West Virginia Public Service Commission involving the amount of booked depreciation expense. Depreciation expense reported to the FCC must be based on prescribed depreciation rates of each plant account and subaccount. Depreciation expense reported to the West Virginia Public Service Commission must be consistent with GAAP. See paragraph 9 of the IRP with Frontier, WV PSC Case No. 05-0040-T-PC, and paragraph 11 of the MTP with Verizon, WV PSC Case No. 06- 1935-T-PC. CITIZENS TELECOMMUNICATIONS COMPANY OF WEST VIRGINIA DBA FRONTIER COMMUNICATIONS OF WEST VIRGINIA AND VERIZON WEST VIRGINIA, INC. WEST VIRGINIA PSC CASE NO. 09-0871-T-PC SECOND REQUEST FOR INFORMATION - CWA
Name of Person Preparing Response: Billy Jack Gregg Date of Response: August 12,2009
Request 7 Re: p. 2, lines 14- 16. The witness states that he believes the proposed transaction “can provide a benefit to consumers.” Concerning this: (a) By using the word “can,” does Mr. Gregg mean that there could (or might) be a benefit to consumers, or does he mean that there will necessarily be a benefit to consumers if the transaction occurs? If the former, please describe the circumstances under which Mr. Gregg believes that the proposed transaction might not “provide a benefit to consumers.” (b) Does Mr. Gregg believe that the Commission’s approval of the transaction should be conditioned in some way in order to increase the likelihood that consumers will benefit from the transaction? If so, please list those conditions and explain the reasons why Mr. Gregg believes each of them is necessary.
Response 7 (a) The use of the word “can” recognizes the fact that in spite of good plans, actual execution of those plans is necessary as well to obtain the desired benefits. The statement recognizes that Frontier’s plans will have to be carried out in a satisfactory manner in order to produce benefits for consumers. (b) The Commission has previously required an acquiring entity to fulfill commitments made to the Commission. However, any speculation about what conditions, if any, may be required is premature. At this time, Mr. Gregg has not identified conditions, beyond the fulfillment of specific commitments made by the Applicants to the Commission, that should be imposed to increase consumer benefits associated with the transaction. CITIZENS TELECOMMUNICATIONS COMPANY OF WEST VIRGINIA DBA FRONTIER COMMUNICATIONS OF WEST VIRGINIA AND VERIZON WEST VIRGINIA, INC. WEST VIRGINIA PSC CASE NO. 09-0871-T-PC SECOND REQUEST FOR INFORMATION - CWA
Name of Person Preparing Response: Billy Jack Gregg Date of Response: August 12,2009
Request 8 Re: p. 3, lines 13-14: (a) What is Mr. Gregg’s understanding of what happens to former MCI (now known as Verizon Business) customers in West Virginia as a result of the proposed transaction? (b) Has Mr. Gregg asked Verizon whether Verizon has undertaken, or will undertake, any actions to transfer any customers from Verizon West Virginia to Verizon Business? If so, what is Mr. Gregg’s understanding of Verizon’s undertakings in this regard. If he has not asked the question of Verizon, why not? (c) Is Mr. Gregg aware of any restrictions that are presently in place on Verizon’s ability to seek to transfer customers from Verizon West Virginia to Verizon Business? If so, please explain in detail those restrictions. If not, does Mr. Gregg believe it would be in the public interest for a substantial number of business customers to transfer from Verizon West Virginia to Verizon Business prior to closing of the transaction? (d) Is Mr. Gregg aware of any restrictions that would be placed on Verizon Business’s ability to compete for customers in West Virginia if the proposed transaction occurs? If so, please explain in detail those restrictions. If not, does Mr. Gregg believe it would be in the public interest for a substantial number of business customers to transfer from Verizon West Virginia to Verizon Business after closing of the transaction?
Response 8 (a) Mr. Gregg’s understanding is that, in general, enterprise customers will stay with Verizon Business. Residential and small business long distance customers will be transferred to Frontier. The transaction documents, however, will speak for themselves. (b) No. The accounts retained by Verizon and those that are being transferred to Frontier are based on the agreement between Frontier, Verizon and Spinco, and the transaction documents will speak for themselves. Mr. Gregg is not aware that Verizon has undertaken, or will undertake, any actions to transfer any customers from Verizon West Virginia to Verizon Business. (c) Yes. The list of accounts that are being retained by Verizon and those that are being transferred to Frontier is based on the agreement between Frontier, Verizon and Spinco. Pursuant to Section 7.2 of the Merger Agreement, Verizon has agreed to operate Verizon West Virginia in the ordinary course of business. It is Mr. Gregg’s understanding that this language limits the ability of Verizon to seek to transfer customers from Verizon West Virginia to Verizon Business. (d) Mr. Gregg is not aware of any restrictions on Verizon Business’ ability to compete in West Virginia after the closing of the transaction. As is the case today, all of Frontier’s customers will be free to choose to take service from other providers after the closing of the transaction, subject to individual contract limitations. CITIZENS TELECOMMUNICATIONS COMPANY OF WEST VIRGINIA DBA FRONTIER COMMUNICATIONS OF WEST VIRGINIA AND VERIZON WEST VIRGINIA, INC. WEST VIRGINIA PSC CASE NO. 09-0871-T-PC SECOND REQUEST FOR INFORMATION - CWA
Name of Person Preparing Response: Billy Jack Gregg Date of Response: August 12,2009
Request 9 Re: p. 4, lines 2-8. Concerning this paragraph: (a) As of what date did Verizon West Virginia have 617,036 access lines? (b) Please provide the documents on which Mr. Gregg relies for the number of access lines served by Verizon West Virginia. (c) Please define with specificity the term “access line” as the witness uses it. For example, is the figure for switched access lines or access line equivalents; does it include or exclude UNE-P; does it include or exclude enterprise (Verizon Business, or the former MCI) lines; etc.? (d) If the number of “access lines” is not defined the same way for the year 2000 figure and the current figure, please explain how the definitions differ and provide figures for both periods using the same definition. (e) Please explain in detail, and provide all documents relied upon, for the witness’s opinion concerning the reasons for the decline in the number of Verizon West Virginia’s access lines.
Response 9 (a) December 3 1,2008. (b) For the number of access lines in 2008 Mr. Gregg relied on representations contained in the petition for approval filed in this case on May 29,2009. For the number of access lines in 2000 Mr. Gregg relied on data reported in the National Exchange Carrier Association (NECA) USF Study Results for 2000 (http://wWw.fcc.gov/wcb/iatdlneca.html). (c) “Working loops” are defined in 47 CFR 536.61 1 as follows: “For universal service support purposes, working loops are defined as the number of working Exchange Line C&WF [cable and wire facilities] loops used jointly for exchange and message telecommunications service, including C&WF subscriber lines associated with pay telephones in CW&F Category 1, but excluding WATS closed end access and TWX [teletypewriter exchange] service.” For reporting purposes, the National Exchange Carrier Association (NECA) divides loops into Categories 1.1 (Intrastate private line and WATS); 1.2 (Interstate private line and WATS); and 1.3 (Message Telephone Service, or revenue producing loops or equivalent). Total loops are the sum of Categories 1.1, 1.2 & 1.3 loops. The term “access lines” as used by Mr. Gregg on the referenced page refers to total loops. Mr. Gregg’s understanding is that access lines include UNE-P and UNE-L, and include access line equivalents, e.g., for Centrex service. It is Mr. Gregg’s understanding that the difference between the 6 17,036 Verizon access lines referred to in the petition in this case, and the total loops shown on the attachment to data request 9(d) is caused by exclusion of category 1.1 and 1.2 lines, as well as “official lines.” (d) The term was defined the same way in 2000. The access line data for Verizon for 2000 was taken from the NECA USF Study Results for 2000, under the column “Total Loops.” The access line data for 2008 was taken from the petition filed in this case. A document showing the change in “Total Loops” and “USF Loops (Category 1.3)” for both Verizon WV and Frontier WV since 1999 will be produced, but since this document contains confidential and proprietary information for 2008, its production will be subject to an appropriate confidentiality agreement. (e) Mr. Gregg’s opinion concerning the decline in access lines is based on his experience with the telecommunications market and numerous articles and presentations. The advent of broadband has caused a decline in the number of access lines in two ways. First, during the period 1996 to 2002 there was substantial growth in second lines as residential and business customers accessed the Internet by means of dial-up service. See, for example, the attached financial analyses of the local telecom market from 1998 and 1999. As broadband became more available from cable companies and telephone companies, many consumers dropped these second lines when they subscribed to broadband. This loss of second lines because of the advent of broadband occurred irrespective of whether the broadband was provided by a competitor or by the incumbent landline company. For example, between 2002 (the first year non-primary lines were reported in West Virginia annual reports) and 2008, Verizon West Virginia’s non-primary residential lines dropped from 37,338 to 12,888. Second, the advent of broadband allowed many broadband-based services to compete with the incumbent telephone company to provide voice service to customers. These broadband-based services include voice service provided by cable companies. In addition to competition from broadband-based services, there is competition from wireless services. More and more households are giving up their landline service and becoming wireless-only. See, for example, the attached Centers for Disease Control and Prevention report on Wireless Substitution released in May 2009. Data Request 9(e>- 1 Exhibit No. BJG-3 Page 1 of4
Cyriitcd Statu -,I c!cco ni n: u nit2tiondScrvices
Investment Hi~hiichts:
.Fur;Caner:al Highlights:
4 Data Request 9(e)-1 Data Request 9(e)-1
. -.
Data Request 9(e)-1 Exhibit No. BJG- Page 1 of 3
Cnited States Telecom s Prlices- WireIi ne
Danirl Reingoid ices - I i) 212 449-56; I hoca km-rsingoid @ rnl.corn ~ 3Q9Y RBOCGTE Review: Another Robust Quarter! Julia Belladonna (Ii 212 44-19-6693 ~;i!c:_trIl~donr.~~:mi.corn Reason for Report: l!xia I nvestrnenl H ig hi ights; b Average refurring 3499 EPS growth for the group was a healthy 12.95'0, up from 2Q's 11.45 and slightly below our estimare of 13.1 5%. b Recurring revenue growth of i.35 accelerated by 40 basis points from 2Q's 6.9Tc anti was just shy of our forecst of 7.14%. The main revenue drivers in the quarter were dam (up 31% ylpl; wireless {up164 yiy) and continued di)uhle digit growth in verrical services reveme (12.3% y/p) - more than sufficient to offset local share iosses that acceierated to an annualized 3.176, up from SCc in 3Q and 2.25 a .ear ago. SVe corirjnw tn srr revnues shift from local soice to higher growth margin dam crnd wireless. Darn revenue growth was again robust. growing 31 70 dur*ng32 1's 2Q's 313%. Wireless revenue growth ncceierated nicely to If.; 70 from ZQ'S i1.3co. Data as a percent of total revenue grew to 10.9=c. up from 10.5% in 2Q, 9.icc a sear 3gO and only S.4% 15 months ago. St'ireiess as a percent of total revenue grew to 13.5%, up from 12.5% in 3Q and 12.1 5 a year ago. . 'r'erticnl senice revenues continued to grow in the double-aigirs, growing 12.3% in 3Q versus 15.1% in 3Q nnd 16.28 in 10. Additional line growth folioms a simiiar pattern - fQ growth was 14.3% versus 15.75 in 2Q and 15.ga-c in 1Q. e Reporred business access line growth of 3.75 wsdown from 4.3% in 2Q and 4.7% in 1Q. However. our measure of revenue bnsed access line equivalent growth was stronger than expected at 17.3%, up from 10.0% in 2Q and ahead of our esrirnare of 9.98. Data volume metria were also strong -- excluding SBC (which has not reported this data yet). high-speed line demand grew 29.9% for Tls, 54.4% for T3s and 63.1 70 for ISDNs. \Ye espect to see a second hpe of upward iine migration in corning quarters for residential second lines. As DSL subscribers grow, some consumers will cancel their second POTS phone line. However. the revenue derived from the DSL lines will be greater ttinn those of the traditional POTS lines - resulting in higher revenues to the RBOG. e LVe espect EPS growth for BEL/GTE. BLS and SEC/XTT to accelerate to 14-1592 from 2000 and believe that the group should trade up LO a 90% relative rnultipie (from 73'70 today) over the next 9-12 months. Catalysts which should spark this moye are: I) the Oct. S close of the SBC/XIT merger; 3) IHOO approval of the BEWGTE merger; 3) lnte lQ00 approval of BEL long-distance in NY; and 4)2300 approval of SBC long distance in 'Texas. Tile average upside for the group at a 90% relative multiple is 25%. Data Request 9(e)-1 Exhibit No. BJG- Page 3 of 3 j:~toS9;f@rCTEIcJTE,SiiIN. B-I-I-i)bcsed on z I .2Z exch3n:e ::ria applied !o otx S80 price objective for BEL shares; j! 5% IO S61 for ELS iSLS. 95.E-2-2-7'1 bsed on n urge: I006 relxive PEnultiple on our LOCO EPS esrimste of 52.23. We mainuin our .~.ccumuiate :i?[ing on BLS despite the significant upslee beczuse :ve believe that some investors are stiil srnming from BellSouth's bid for Sprm:, The close of the BEUGTE merger in : HrR. We expect 26% for @-2-l-:i b3sed on a heFCC to impose similar in-rrgion mergcr conditions to SSO BEL (BEL. 555. target 90% reiaiive ?E mitipie on our ZOO0 as it did to SBUAIT. However. we do not expecr the EPS estimtrr ofSj.20: FCC to require an out-of-region expxsion ?lm and we do expect some additions! cme-out provision :o handle 199 to 576 fur USW (CSb':.S6-l. B-1-223) bzsd on i: CjTE's long disnncz data business. conservative exchnngr rail0 or' I .?3 (the top of :he ~coilarito our 544 fair value estimate For (>,west ZHCO 27 I long distance qicprocai in T:i far Sac); iQWST. 556 7iB. D-:-2-3!, Ocr SA4 rsrinmd fair Fanhe: growtn in i~edati: sector -- :!:e Seils' .due for Q*.ccst i!9.:% ccsidc) is derivd by applying rnxhinp efians in 3SL i:nd specla! xcebi an industry zvz:qe 13.Tx EBITD.4 muitiple-to-growrh businesses i?re picking up momentum. xio io our S-;ar Qwesr EEITDX C.4C.R of 17% and (Tit pwhIn data-ie!airc i:t'Cnc,'s' :, 23 In (j~5i,*..3.. ,. ~ver3ae I .li:PE:;rowth i3:io to our Qwcst Beiis cwav from a dcprndrnc:< on voice produc:~. .'-yezr c3sh EPS C.A.c.2 of '8%. Vdnarion i7C.i. to559 io~StiC(SBC.551.B-2-l-7) basedon a :..&;e: I 35% rciarive P.Z mul:i?ie on ncr 2000 EPC eh:imxe ofS7.S.i. 3 Data Request 9(e)-1 Exhibit No. SJG--! Page 2 of 3 The P3OCs rcponcd n saiid 3 'quxer, wick, sr-ong revenue .Adjcstmcnrs m2de to reporrid resuits dcring !he qumer ;:o~~hd-i:w p+mlriiy by data. Ivirc!csd and vtnicni \vert prin:;uiiy for one timers dcc to ncquisirions. sa".'_. ,L~..LC .At the 2nd of this report is our imsi version of Exmipits are: RBOC \:id Sip!r, afhi:h detsi!s ihr key dnvrrs behind rhe .+,rnerirctch's acquisitions of C!ow 2nd Anixter. s:mnf ::venue and EPS groit'th. a SBC's acquisitions of Ctllu!~Cornrnunis~ions of Zr;i \vas ;i busy time for ths RBOC'GTE grx?. Rrcrnt Pueno F,ico and Corncast Cel!i:ia:, <.,en!> u.hich nak tnis q4;lr:c.:. \arid the ix;in:.,ing or' AQ! h1c;er expenses at Bel! ALImtic and SEC. iiiitque include: One rime expenses re!atcd to Hc.+cane Fioyd ;1t BEL. * BEL'S 27 applicntlon in S:C*.V';'ark >:CkbiCh L 0;~s .Aftti rtinking ceniin adjustments. avcragr EPS growth for endorsed by the nnd pointed to either a SY PCC [he CiOu? vvx a heaithr. i 2.95 driven by svong revenue conditional approval or a disapprovai by the DOJ. We growth oi7.35. Average EBITD.4 for rnt group grew ioniinuc to expect BEL to he Zranicd approvsi by the 82% and operating income ptv!0.3%. rnd of iQ00. Despite iosing an annualized 3. I5 of rnilrket share in the BEL entered into n pxmership tvitn !ccal mukat to competi:ors this put quart:r. the RBOC Vodaione/X'mouch tc combine their US ivireirss group continued to FOSC the strong res'er.ue and earnings propenirs. u'ich this pmership and ii5 merger with ;mn.ih numbers quokd above due to the ccntinued GTE. BEL wiil own 3 national fiber ne:u.ork. 2 xrengrh oithe foliowing key drivers: naaonai wireless network. 3 naciunai IS? 2nd I/: of :be nation's accm iines. Dmha grown as n percenr ofievcnaes from 7.7% IS monchs ago to 8.25,n ;ex ago ;o IO.%C in 3Q. 3Q's 1 SLS made 2 bid f~;Sprin:. ani ios: tu V;cridCorn. nt txpsion Iron ZQ bra: our estiir,ate of 1 3BC c!osed its rr.c:gcr with .kneritec3. xdreporml oint im?rwemen: to itj.L'.>, irgrzssive 1 qcxer oct results. Excluding SSC (Btherefare .A!T). high-speed !in.- 1;2)-J"'.- n;7i. xzh ss Ti s.TZ>and !SD.X PR!j. conrinurd .- me !st 1: months. subscribers for :>e group In !SP to be strong with \:oiumes growing '9.0%. 54.4% :nd hsve nor: rnnn uoucic.6 2nd DSL ~~3sir::brrshn\*e . G.15 rrspectivei'i in io. ;:own almost ZO-Foid ZC) 2~4.000.I\,'< e\;?zcr this e upwxd utnd to contirxe. Internct Service Provider ilSP) subscAbers for the group now total 2.2hi. tip from 2.O'vl in 2Q, I .3M a * 52C unveiled its accelerated DSL dqioymtnr strsteg:;. P:ojecr Pronto. through *.Lhiii ir *xiilrex5 SO% of its customers by 2CG'i by spendin: 566 in ! ?T,Win ?Q and are txpxrtd IOalrn~st doubie by the insre::ienrai capex uniie creating Sj.53 in ncw nnnti:l end of be yen- risins ta SOLO3in 42. 7% exciudes :evenu.es wirnin 5 yusand 51.53 in annusi cos1 indeccndenr ILECs ;in2 CLEZ, !Jniiii '.ire beiieve couid ,.. .. JJ .ings. tod mcditr i W.k% - I W.DO0 by yere.na. 9 CS Vv'EST continued ro snow ts;ec:ni!y smong DSL Domestic wire!ess ievtnur grswrh of 15.753 and ISP subscribe: growth -- DSi subs increased 6G5 acc-ierared from 2Q's lA.2% but was short of otir gia to S0,OGO and net adds acce!erateu over IGO% qiq forecast of 16.5%. 13 30,000. t'eriicai ser-Aces revenue grew I!.59. down from * GTE cornpieced the szie of its Government Systems 15.1% in ZQ and ndditionai lines grc?~I~.S?c. down business. bringxig it S : B (570Uhl post QX ;. In from 15.74 in I(?. :on.iunctior: ivith :he s:!es of iru urz! x:e !Wzc of L?. i .6M lines hzvz beer, sold) iv hzv: netted an sverage of S3.3OOiline - trmsiating inta 55.3 ~S3.75post lax; whcn the sales are cornpis:. in sum CTE wiii lie[ ti? to S1.J.U from iLs 3>\c.t aaies. ... .._. (e>- 1 ______Exhibit No. BJG- CREDIT I FRSI Page I of 3 U.S.Telecom Serdices Wirdirts SUISSE , 33s!ON Exhibit i'i Valuations of Data-Centric Companies s 4-i r- 1.10-5 - 39 - -A CREDlT i FiST Exhibit No.BJ( U.S. T~~CGITServices Wireline SUISSE 30S'iON Page 2 of3 I__ . ... ______...... - ...... - ...... - .... - ...... _..... ...... -...... ltil),%l 153,733 53,770 51,5115 9.5 '3.5 6.3 G.3 131,201 137,Dl 72,@51 74,122 ...... - .. Data Request 9(e)- 1 Exhibit No. BJG-3 Page 1 of4 I nveslmenl Hi 5 h li CJ h ts: .Fundaner?:~;I Highlights: Data Request 9(e)-I - ._ -. . Data Request 9(e)-1 Exhibit No. BJG-. Page 4 of 4 . - . . .. .- . . . Data Request 9(e)-1 Exhibit No. BJG- Page 1 of 3 L'nited States Telecom Seriices- Wireline 15 Novembrr 1999 Daniel Reingold ii)?12U9-563! Lm-rtinpld@ rnl.corn 31299 RBOUGTE Review: Another Robust Quarter! Julia Be!ladonna (I 1 2 I2 419-6693 , _I._.:,> ts!l3donr,aOml.ccm .- Kesison Cor Keport: I!I~LI<~~Cpd.ite 1 nvestment H ig hI ig hts: 8 Average recurring 3099 EPS gruwth for the group svx zi healthy 12.9%, up from 1Q's 11.J70 and siightly below our ejtimate of 13.1 '5, . Recurring revenue growth of 7.3% accelerated by 40 basis points from 7Q)s 0.95 and asju just shy of our forecst of 7.4%. The main revenue drivers in the quarter were data (up 31% p/y); wire1e.s (up 165y/y) and continued doui-~ledigit growth in vernal services revenze { 11.3% y/y) - more than sutRficient to offset local share losses that accelerated to an annualized 3.1%, lip from 235 in 2Q and 2.25 n !ear ago. 4 !C e conrinw tn srr rov'enues shift from iocal voice to higher growth margin dnta and \virde=. Dntn reyenue grol.5 th was again robust. growing 31 70 durn:: 3Q vs 2Q's 31.8%. Wireless revenue growth accelerated niceIy to If.: 7c from ZQ's ii.3%. 8 Data as TI percent of total revenue grew to 10.95. up from 10.5% in 2Q. 9.1 a :,ear ago and only SA% IS months ago. IFireless as a percent of tatd reyenue grew to 13.1%, up from 12.5% in 2Q and 12.1 5 a year ago. Vertical senice revenues contrnuea to grow in the double-digirs, growing 12.37~in 3Q versus 11.1% in 2Q and 16.2% in IQ. Xddirional line growth foliows a simiinr pattern - 3Q growth was 14.35 versus 15.7'-~ in 2@ and 16.9Tc in 1Q. 'D Reported business access line prowrfi of 3.75 wadown from 42%in 3Q and 4.75 in 1Q. However, our measure of revenue based access line equivalent growth was stronger than expected at 13.3%. up from 10.0% in 3@and anead or" our estimate of 9.3 5. Data volume metria were also strong .-escluding SBC (which hm not reported this data yet). high-speed line demand grew 29.9% for Tls, 544% for T3s and 63.1 Clc for ISDNs. . I\ e espoct to see a second t) pe of upward line migration in coming quarters for residential second lines. As DSL subscribers grow, some consumers will cancel their second POTS phone line. However. the revenue derived from the DSL lines will be greater than those of the traditional POTS lints - resulting in higher revenues to the RBOCs. 'eve espect EPS growth for BEL/GTE. BLS and SEC/AIT to accelerate to 14-15% from 2000 and believe that the group should trade up 10 a 90% relative multipie (from 7370 today) over the next 9-12 months. Cat3iysts which should spark this move are: 1) the Oct. S close of the S3CIXIT merger: 2) IHOO approval of the BEL/GTE merger; 3) inte lQO0 approval of BEL long-distance in NY; and 4) 2H00 approval or'SBC long distance in 'I'esas. The average upside for the group at 3 90% relative multiple is 25%. - ._ Data Request 9(e)- 1 Exhibit No. BJG-- Page 3 of3 Investment Conclusion: %. , )be bziieve that hex compnies xe puning up SVGn: pvi~hnumbers des?ice tic incriubie n~kttshe erosion from compzdtcrs 2nd we continue io recommend t'ne entire pcp. highlighting Bell .-?rl;inuc and GTE. Vv"v'hhi: succ:sshui close of :ne SEC mqe: and 3eil ,\iiLntic's 271 ' 3 1% to 561 for BLS IBLS. S45.5-2-2-71 bzed on i! r??clii.adon.. proctss %.veilunderaay. xve h~t.t rtnewec! relscivc PEmitipie on our ZOCO EPS ccnridrnce cix.~ovcrhw.!gs on hegrmp B Yduarion 3 - .. ..._ . . - -... Data Request 9(e)-I Exhibit No. BJG-1 Page 2 of? .Adjustmcnrs made to reported results dcrina the quarter v.x:: prinwi;y for one rirntrs dce 13 xquisitions. Exniples are: ,imeri[ech's scquisirions of C!over and Anixte:. 0 SBC'r acquiritioiis oiCriiulv Communications of Pucno Rico and Comc~stCeI!i!h:. hlcger expenses :t 6211 .AtI~nricand SBC. @ne time expens3 re!ated tG Hu.+cane Floyd at BEL. ,After nakin; cen-in adjustments, ave:ag:: EPS giowth for [he group ii'ils LI health!. 12.95 driven by szong :evenut growrh oi7.25. A.verage EB1TD.A for t'ne roup grew 8.2% 3nd opsracing income grew 10.3%. Deszire losing on annualized 2.15 of rniL-kec share in the !oca! rnxk:t to com~etirorsthis pas; Gum::. L$e RBOC group continued to post the swan: rz'ienu2 3nd emings zro\vih numbers quotd above due to the ccntinued .srengh ofthe following Le;; drivers: E& hu grown as a percent of ie':cnues from 7.7% IS months ago to 3.25, a ye&- ago :o li?.9Q in ;Q. 30's SO basis point cx?a.nsion from 1Q bmt nur tstimxe OF 9 31: basis poin: impobement to Ik:~-c Exc!uding SBC t& therefore .i!Tj.high-speed line , TZ2 and iSD?-' ?Rl.i. continued umes growing 29.98. 54.4% and G.!F,. rrspectivei:/ in 5Q. 1ntt:ner Sewice Provide: (ISP) subscsbers for the group now total 3.3:rl. up iron; 2.0M in 2Q, I3M 3 ye3r ago and less than 1.0?4 I8 nonths ago. rR29C'GTE DSL szbsi%crs ?:.la. to X4..3LY) from ! 27.ooO in 2Q mo &-e expxred io dmst doujie by t$e end of hie yez- - rising to S0,CCd in This excludes indeFcnienr ILECs yld CLEG. rvhizii 'XL: beiieve couid toi;ii mod1t: LCo.LI3 - i53.oOo 5:1 l;ez-+na. Domestic wire!rss revenue Zrowch of 15.7% ac:e!emied from 2Q's ld.2% but was shon ofour forecast or' 16.5%. C'eriicnl services reG;enue grew i2.2ci. down from 15.15 in 2Q and addicionai lines yrcii. i'.3&. down from 15.78 in 1Q. CREDIT I cIp Page I of 3 SUISSE =USTON Exhibit 13 Valuations of Data-Centric Companies 5 'n r: i:ICFs CREDIT I FFST Exhibit No. BJC U.S. TelecGm Services Wire!ine SUISSE j SOSTON Page 2 of 3 CIIEDIT ! I .,.?,T LJ. s . Tt?leco~n S c r'vices W i IC tin c SUlSSE \, I..,'r). 1.) 1r;t.i ...... - ...... - .- ...... ~ ...... E xliilii t 20 what .. ~f .. wc Vnl~tctl..... 111c 'frncliliorial ...... Voicc Dtisincss...... ns n 13cclinitq Pwp!li!ily (iiticl IlocorJtiizecl Ils I.i\igc Frcc Cash FIOW)? __ - ...... - - ...... - ...... - ..... - __...... (?W EdAllnrdic soc Cocnn 3UY" -3.0% 13I 1 ,Ll 7";:) 10.0 10.0 53,770 51,915 6.3 6.3 72,Gfjl 74,122 I i I i r" I - ..... - ...... - . i ... il I Data Request 9(e)-2 N u n Y - N n I 5: - wireiess su~mtunoqJuy-uecemoer LUU~(Keleasea ~ILUWY) rage I 01 6 CDCHome About CDC Press Room A-Zlndex Contact Us Department of Health and Human Services Centers for Disease C~ntroland Prevention Email this Rage Publications and Information Products Printer-friendly version PDF reader . PowerPoint viewer Wireless Substitution: Early Release of Estimates From the National Health Interview Survey, July-December 2008 by Stephen J. Elurnberg, Ph.D., and Juiien V. Luke, Division of Health Interview Statidis, National Center for Health Statistics PDF version 358 KB Page Content Overview NHIS Eadv Release Proaram Methods Questionnaire Chanaes in 2007 Telephone Status Demosra~hicDifferences Wireless-Mostly Households Selected Health Measures bv Household Telephone Status Conclusions For More Information Suqaested Citation Figures Tables Overview Preliminary results from the July-December 2008 National Health Interview-Survey (NHIS) indicate that the number of American homes with only wireless telephones continues to grow. More than one of every five American homes (20.2%) had only wireless telephones (also known as cellular telephones, cell phones, or mobile phones) during the second half of 2008, an increase of 2.7 percentage points since the first half of 2008. This is the largest &month increase observed since NHIS began collecting data on wireless-only households in 2003. In addition, one of every seven American homes (14.5%) received all or almost all calls on wireless telephones, despite having a landline telephone in the home. This report presents the most up-todate estimates available from the federal government concerning the size and characteristics of these populations. http ://www. cdc .gov/nchs/datainhis/ea~~~e~e~~/~~eless200905. htm 8/ 1112009 -. -- - Data Request 9(e)-2 N u H Y - N n t 5: - wireiess submtuaon, July-uecemDer LWL( (Keteasea ~.ILWUY) rage L or 6 NHlS Early Release Program This report is published as part of the NHfS Early Release Program. In May and December of each year, the Centers for Disease Control and Prevention's National Center for Health Statistics (NCHS) releases selected estimates of telephone coverage for the civilian, noninstitutionalited US. population based on data from NHIS, along with comparable estimates from NHlS for the previous 3 years. The estimates are based on in-person interviews that NHlS conducts continuously throughout the year to collect information on health status, health- related behaviors, and health care utilization. The survey also includes information about household telephones and whether anyone in the household has a wireless telephone. Two additional reports are published as part of the Early Release Program. Earlv Release of Selected Estimates Based on Data from the National Health Interview Survey is published quarterly and provides estimates of 15 selected measures of health. Health Insurance Coverane: Earlv Release of Estimates from the National Health interview Survey is also published quarterly and provides additional estimates of health insurance coverage. Methods For many years, NHlS has included questions on residential telephone numbers, to permit recontacting of survey participants. Starting in 2003, additional questions were asked, to determine whether the family's telephone number was a landline telephone. All survey respondents were also asked whether "you or anyone in your family has a working cellular telephone." A '!family" can be an individual or a group of two or more related persons living together in the same housing unit (a "household"). Thus, a family can consist of only one person, and more than one family can live in a household (including, for example, a household where there are multiple single-person families, as when unrelated roommates are living together). In this report, families are identified as '!wireless families" if anyone in the family had a working cellular telephone at the time of interview. This person (or persons) could be a civilian adult, a member of the military, or a child. Households are identified as "wireless-only" if they include at least one wireless family and if there are no working landline telephones inside the household. Persons are identified as wireless-only if they live in a wireless-only household. A similar approach is used to identify adults living in households with no telephone service (neither wireless nor landfine). Household telephone status (rather than family telephone status) is used in this report because most telephone surveys draw samples of households rather than families. From July through December 2008, information on household telephone status was obtained for 12,597 households that included at least one civilian adult or child. These households included 23,726 civilian adults aged 18 years and over and 8,635 children under age 18. Analyses of demographic characteristics are based on data from the NHIS Person and Household files. Demographic data for all civilian adults living in interviewed households were used in these analyses. Estimates stratified by poverty status are based on reported income only. Household income was unknown for nearly 18% of adults. Analyses of selected health measures are based on data from the NHlS Sample Adult file. Health-related data for one civilian adult randomly selected from each family were used in these analyses. From July through http: //m.cdc .gov/nchs/datafnhis/earl y re1 easeiwireless:! 0090 5.htm 81 1 1/2009 Data Request 9(e)-2 N L n 3 - D( n L 3 - wueiess xmxmmon, July-uecemPer LUU~(Keieasea YLUUY) rage 3 OT 6 December 2008, data on household telephone status and selected health measures were collected from 9,841 randomly selected adults. Because NHlS is conducted throughout the year and the sample is designed to yield a nationally representative sample each week, data can be analyzed quarterly. Weights are created for each calendar quarter of the NHlS sample. NHlS data weighting procedures are described in more detail in an NCHS published report (Series Report No. 2, Vol. 330).To provide access to the most recent information from NHIS, estimates using the July-December 2008 data are being released prior to final data editing and final weighting. These estimates should be considered preliminary and may differ slightly from estimates using the final data files. Point estimates and 95% confidence intervals were calculated using SUDAAN software, to account for the complex sample design of NHIS. Differences between percentages were evaluated by using two-sided significance tests at the 0.05 level. Terms such as "more likely" and "less likely" indicate a statistically significant difference. Lack of comment regarding the difference between any two estimates does not necessarily mean that the difference was tested and found to be not significant. Because of small sample sizes, estimates based on less than Iyear of data may have large variances, and caution should be used in interpreting these estimates. Questionnaire Changes in 2007 From 2003 to 2006, families were considered to have landline telephone service if the survey respondent provided a telephone number, identified it as "the family's phone number," and said that it was not a cellular telephone number. If the family's phone number was reported to be a cellular telephone number, the respondent was asked if there was "at least one phone inside your home that is currently working and is not a cell phone." In 2007, the questionnaire was changed so that the survey respondent for each family was asked if there was "at least one phone inside your home that is currently working and is not a cell phone," unless the respondent indicated not having any phone when asked for a telephone number. From 2003 to 2006, the questions about cellular telephones were asked at the end of the survey. Because of incomplete interviews, more than 10% of households were not asked about wireless telephones. In 2007, the questions were asked earlier in the survey, resulting in fewer families with unknown wireless telephone status. In 2007, a new question was added to the survey for persons living in families with both landline and cellular telephones. The respondent for the family was asked to consider all of the telephone calls that his or her family receives and to report whether "all or almost all calls are received on cell phones, some are received on cell phones and some on regular phones, or very few or none are received on cell phones." This new question permits the identification of persons living in 'Wireless-mostly" households, defined as households with both landline and cellular telephones in which all families receive all or almost all calls on cell phones. Finally, in 2007, the questionnaire was redesigned to improve the collection of income information. Initial evaluations suggest that the resulting poverty estimates are generally comparable with those from years 2006 and earlier. However, as a result of the changes, the poverty ratio variable has fewer missing values in 2007 and 2008 compared with prior years. http: //wccdc.gov/nchs/data/nhis/earlyreleasd~reless200905. htm 8/11/2009 -. Data Request 9(e)-2 N L H 3 - N n L 3 - wifeiess suasuamon, my-vecemPer LUU~~(Keieasea ~ILUVY) rage 4 or II Telephone Status In the last 6 months of 2008, more than one of every five households (20.2%) did not have a landline telephone but did have at least one wireless telephone (Table I).Approximately 18.4% of all adults-more than 41 million adults-lived in households with only wireless telephones; 18.7% of all children-nearly 14 million children--lived in households with only wireless telephones. The percentage of households that are wireless-only has been steadily increasing. In fact, the 2.7-percentage- point increase from the first 6 months of 2008 is the largest 6-month increase observed since NHlS began collecting data on wireless-only households in 2003. The percentage of adults living in wireless-only households has also been increasing steadily (see Fiaure 1). During the last 6 months of 2008, more than one of every six adults lived in wireless-only households. One year before that (that is, during the last 6 months of 2007), one of every seven adults lived in wireless-only households. And 2 years before that (that is, during the last 6 months of 2005), only 1 of every 13 adults lived in wireless-only households. The percentages of adults and children living without any telephone service have remained relatively unchanged over the past 3 years. Approximately 1.9% of households had no telephone service (neither wireless nor landline). Nearly 4 million adults (1.7%) and 2 million children (2.4%) lived in these households. Demographic Differences The percentage of U.S. civilian, noninstitutionalized adults living in wireless-only households is shown by selected demographic characteristics and by survey time period in Table 2. For the period July through December 2008, More than three in five adults living only with unrelated adult roommates (60.6%) were in households with only wireless telephones. This is the highest prevalence rate among the population subgroups examined. Nearly two in five adults renting their home (39.2%) had only wireless telephones. Adults renting their home were more likely than adults owning their home (9.9%) to be living in households with only wireless telephones. More than two in five adults aged 25-29 years (415%) lived in households with only wireless telephones. Approximately one-third (33.1 %) of adults aged 18-24 years lived in households with only wireless telephones. As age increased from 30 years, the percentage of adults living in households with only wireless telephones decreased: 21 6% for adults aged 3044 years; 1? 5%for adults aged 45-64 years; and 3.3% for adults aged 65 years and over. However, as shown in Table 2 and Fioure 2, the percentage of wireless-only adults within each age group has increased over time. Men (20.0%)were more likely than women (17.0%) to be living in households with only wireless telephones. Adults living in poverty (30.9%) and adults living near poverty (23.8%) were more likely than higher income adults (16.0%) to be living in households with only wireless telephones. Adults living in the South (21.3%) and Midwest (20.8%) were more likely than adults iiving in the Northeast (1 1.4%) or West (17.2%) to be living in households with only wireless telephones, Non-Hispanic white adults (16.6%) were less likely than Hispanic adults (25.0%) or non-Hispanic black adults (21.4%) to be living in households with only wireless telephones. http://www.cdc.gov/nchs/data/nhis/earlyrelease6wireless200905.htrn 8/11/2009 . .._ Data Request 9(e)-2 N L H s - N H L 3 - wiretess xmmtunon, July-uecemPer LWU~(Keieasea YLUUY) rage 3 or 6 Wireless-Mostly Households Among households with both landline and cellular telephones, 24.4% received all or almost all calls on the cellular telephones, based on data for the period July through December 2008. These wireless-mostly households make up 14.5% of all households. The percentage of adults living in wireless-mostly households has been increasing (see Table 3). During the last 6 months of 2008, approximately 35 million adults (15.4%) lived in wireless-mostly households. Although this prevalence estimate was not significantly different from the estimate for the first 6 months of 2008 (14.4%), it was significantly greater than the estimate for the first 6 months of 2007 (12.6%). Table 3 presents the percentage of adults living in wireless-mostly households by selected demographic characteristics and by survey time period. For the period July through December 2008, Adults with college degrees (18.0%) were more likely to be living in wireless-mostly households than were high school graduates (13.2%) or adults with less education (9.8%). Adults living with children (19.2%) were more likely than adults living alone (12.2%) or with only adult relatives (13.2%) to be living in wirelessmostly households. Adults living in poverty (9.5%) and adults living near poverty (II .3%) were less likely than higher income adults (18.2%) to be living in wireless-mostly households. Adults living in metropolitan areas (15.8%) were more likely to be living in wireless-mostly households than were adults living in more rural areas (13.4%). Selected Health Measures by Household Telephone Status Most major survey research organizations, including NCHS, do not include wireless telephone numbers when conducting randomdigit-dial telephone surveys. Therefore, the inability to reach households with only wireless telephones (or with no telephone service) has potential implications for results from health surveys, political polls, and other research conducted using randomdigitdial telephone surveys. Coverage bias may exist if there are differences between persons with and without landline telephones for the substantive variables of interest. The NHlS Early Release Program updates and releases estimates for 15 key adult health indicators every 3 months. Table 4 presents estimates by household telephone status (landline, wireless-only, or without any telephone service) for all but two of these measures. ("Pneumococcal vaccination" and "personal care needs" were not included because these indicators are limited to adults aged 65 years and over.) For the period July through December 2008, The prevalence of binge drinking (Le., having five or more alcoholic drinks in 1 day during the past year) among wireless-only adults (36.7%) was nearly twice as high as the prevalence among adults living in landline households (19.7%). Wtreless-only adults were also more likely to be current smokers than were adults living in landline households. Compared with adults living in landline households, wireless-only adults were more likely to report that their health status was excellent or very good, were more likely to engage in regular leisure-time physical activity, and were less likely to have ever been diagnosed with diabetes. The percentage without health insurance coverage at the time of the interview among wireless-only nonelderly adults (27.5%) was considerably higher than the percentage among nonelderly adults living in landline households (16.4%). Compared with adults living in landline households, wireless-only adults were more likely to have experienced financial barriers to obtaining needed health care, and they were less likely to have a usual place to go for medical care. Wtreless-only adults were also less likely to have received an influenza vaccination during the previous year. Wireless-only adults (47.0%) were more likely than adults living in landline households (37.1%) to have ever been tested for HIV, the virus that causes AIDS. 811 112009 Data Request 9(e)-2 N L n 3 - N H L 3 - wxeiess su~mmo~July-uecemoer LUU~(Keieeasea YLUUY) rage 0 01 6 Conclusions The potential for bias due to undercoverage remains a real and growing threat to surveys conducted only on landline telephones. For more information about the potential implications for health surveys that are based on landline telephone interviews, see Blumberg SJ, Luke JV. Coverage bias in traditional telephone surveys of low-income and young adults. Public Opin Q 71:734-49. 2007. Blumberg SJ, Luke JV, Cynamon ML. Telephone coverage and health survey estimates: Evaluating the need for concern about wireless substitution. Am J Public Health 96:926-31. 2006. Blumberg SJ, Luke JV, Cynamon ML, Frankel MR. Recent trends in household telephone coverage in the United States. In: Lepkowski JM et al., eds., Advances in telephone survey methodology. New York: John Wiley and Sons, 56-86.2008. The potential for bias may differ from one state to another because the prevalence of wireless-only households varies substantially across states. For more infomation about state-level prevalence estimates from the 2007 NHIS, see 9 Blumberg SJ,Luke JV, Davidson G, Davem ME, Yu T, Soderberg K. Wireless substitution: State-level estimates from the National Health Interview Survey, January-December 2007. National health statistics report; no 14. Hyattsville, MD: National Center for Health Statistics. 2009. For More Information For more information about the National Health Interview Survey or the NHIS Early Release program, or to find other Early Release reports, please see the following websites: National Health Interview Sorvev hornepaoe. National Health lnterview Survev - Earfv Releases of Selected Estimates Suggested Citation Blumberg SJ, Luke JV. Wireless substitution: Early release of estimates from the National Health Interview Survey, July-December 2008. National Center for Health Statistics. May 2009. Available from: http:llwww.cdc.aovlnchslnhi~.htm. http ://w. cdc.gov/nchs/data/nhis/earl~~release/wireless2OO9O 5.htm %/I1/2009 . .. Data Request 9(e)-2 N L n 3 - N n L 5 - w~~esswosumon, Jury-uecemDer LVU~(Releasea ~ILUWYJ rage I or 5 Figures Figure 1 Figure 2 http://mr.cdc.gov/nchs/data/nhis/earlyrelease/wireless2OO9O5. htm 8/11/2009 Data Request 9(e)-2 N L" H S - N H I S - Wireless Substrtuhon, July-December 2OU8 (Keleased XLUUY) rage 8 01 8 Tables View Tables Page Last Modified: June f7,2009 Content source: CDClNational Center for Health Statistics What's New Births, Mamages, Divorces, and Deaths: Provisional Data for 2008..more (7~9/2009) Vaccination Coverage Estimates from the National Health Interview Survey: United States, 2008..more (7Q2QOO9) Aging Differently: Physical Limitations Among Adults Aged 50 years and Over: United States, 2001- 2007..more (7moo9) Announcements Errata List tistservs Ordering Information Printed Publications Birth, Death, Marriaae, and Divorce Certificates Government Printincl Office Bookstore How to order from the National Technical Information Service National Center for Health Statistics 331 1 Toledo Road Hyattsville, MD 20782 Phone: 1-800-232-4636 [email protected] -Home Policies and Reautations Disclaimer e-Government -FOIA Contact Us FirstGov -- The US. Government's Official Web Portal Deaartment ob Health and Human Services Safer Healthier People Centers for Disease Control and Prevention, 1600 Clifton Rd, Atlanta, GA 30333, U.S.A Tel: (4M) 639-331 1 / Public Inquiries: (404) 639-3534 I (800) 31 1-3435 8/11/2009 CITIZENS TELECOMMUNICATIONS COMPANY OF WEST VIRGINIA DBA FRONTIER COMMUNICATIONS OF WEST VIRGINIA AND VERIZON WEST VIRGINIA, INC. WEST VIRGINIA PSC CASE NO. 09-0871-T-PC SECOND REQUEST FOR INFORMATION - CWA Name of Person Preparing Response: Billy Jack Gregg Date of Response: August 12,2009 Request 10 Re: p. 5, line 19 to p. 6, line 2. Concerning this paragraph: (a) As of what date did Frontier West Virginia have 143,982 access lines? (b) Please provide the documents on which Mr. Gregg relies for the number of access lines served by Frontier West Virginia. (c) Please define with specificity the term “access line” as the witness uses it. For example, is the figure for switched access lines or access line equivalents; does it include or exclude UNE-P; etc.? (d) If the number of “access lines” is not defined the same way for the year 2002 figure and the current figure, please explain how the definitions differ and provide figures for both periods using the same definition. (e) Please explain in detail, and provide all documents relied upon, for the witness’s opinion concerning the reasons for the decline in the number of Frontier West Virginia’s access lines. (f) If the definition of “access lines” used by the witness for Frontier West Virginia is not the same as his definition of “access lines” used for Verizon West Virginia, please explain why not and provide data for both companies using the same definition. Response 10 (a) December 3 1,2008. (b) For the number of access lines in 2008 Mr. Gregg relied on representations contained in the petition for approval filed in this case on May 29,2009. For the number of access lines in 2002 Mr. Gregg relied on data reported in the National Exchange Carrier Association (NECA) USF Study Results for 2002 (http://www. fcc.aov/wcb/i atd/neca.html). (c) See the answer to data request 9(c). It is Mr. Gregg’s understanding that the difference between the 143,982 Frontier access lines referred to in the petition in this case, and the total loops shown on the attachment to data request 9(d) is caused by exclusion of category 1.1 and 1.2 lines. (d) See the answer to data request 9(d). (e) See the answer to data request 9(e). The access line data for Frontier for 2002 was taken from the NECA USF Study Results for 2002, under the column “Total Loops.” (f) The definition is the same. See document produced in response to data request 9(d). CITIZENS TELECOMMUNICATIONS COMPANY OF WEST VIRGINIA DBA FRONTIER COMMUNICATIONS OF WEST VIRGINIA AND VERIZON WEST VIRGINIA, INC. WEST VIRGINIA PSC CASE NO. 09-0871-T-PC SECOND REQUEST FOR INFORMATION - CWA Name of Person Preparing Response: Billy Jack Gregg Date of Response: August 12,2009 Request 11 Re: p. 7, lines 3-5. Does Mr. Gregg expect the combined companies to serve 761,000 access lines in West Virginia at closing? If not, please provide the witness’s estimate of the number of access lines that would be served by the companies at closing, and provide all documents and workpapers used to derive the estimate. Response 11 No, Mr. Gregg does not expect the combined companies to serve 761,000 access lines at closing. The number of access lines that the companies would serve at closing would depend on the change in the number of lines before closing. Mr. Gregg does not currently express an opinion on a numerical estimate of the number of access lines that would be served by the companies at closing. CITIZENS TELECOMMUNICATIONS COMPANY OF WEST VIRGINIA DBA FRONTIER COMMUNICATIONS OF WEST VIRGINIA AND VERIZON WEST VIRGINIA, INC. WEST VIRGINIA PSC CASE NO. 09-0871-T-PC SECOND REQUEST FOR INFORMATION - CWA Name of Person Preparing Response: Billy Jack Gregg Date of Response: August 12,2009 Request 12 Re: p. 7, lines 11-13. Please list the four metropolitan areas larger than CharlestodHuntington that would be served by the new Frontier, including the number of access lines in each such area. Response 12 Please note that the testimony states that CharlestodHuntington is in the top 5 metropolitan areas, not that it is fifth. Set forth below are the top 5 metropolitan areas to be served by Frontier after closing. The access line totals are based on primary residential lines in each area. Seattle/Tacoma, WA CharlestodHuntington, WV Rochester, NY Portland, OR Ft Wayne, IN A proprietary/confidential document, containing the number of such access lines by area, will be produced to all parties who have executed an appropriate protective agreement. CITIZENS TELECOMMUNICATIONS COMPANY OF WEST VIRGINIA DBA FRONTIER COMMUNICATIONS OF WEST VIRGINIA AND VERIZON WEST VIRGINIA, INC. WEST VIRGINIA PSC CASE NO. 09-0871-T-PC SECOND REQUEST FOR INFORMATION - CWA Name of Person Preparing Response: Billy Jack Gregg Date of Response: August 12,2009 Request 13 Re: table onp. 8. (a) Please provide the source documents used by Mr. Gregg to create this table. (b) Are the “combined” figures simply the result of adding the figures for the two companies? (c) Does Frontier West Virginia currently receive any revenues from Verizon West Virginia or any other entity that would become owned by Frontier if the proposed transaction occurs? If so, please provide a detailed listing of the reasons for those receipts and explain how the elimination of those revenues (and corresponding expenses) are reflected in the table. If they are not reflected in the table, please explain why not and provide a corrected table if necessary. (d) Does Verizon West Virginia currently receive any revenues from Frontier West Virginia or any other Frontier entity? If so, please provide a detailed listing of the reasons for those receipts and explain how the elimination of those revenues (and corresponding expenses) are reflected in the table. If they are not reflected in the table, please explain why not and provide a corrected table if necessary. Response 13 (a) The source documents are the annual reports and annual surveillance reports to the West Virginia Public Service Commission. Copies of these reports will be produced. Attached are copies of corrected pages 8 and 9 of Mr. Gregg’s testimony. The corrections incorporate the impact of Frontier’s unregulated revenue and expenses which were not included in the annual surveillance report. (b) Yes. (c) Subject to any and all objections previously interposed, Frontier and Verizon are still investigating this request. Mr. Gregg reserves the right to supplement his responses. (d) Subject to any and all objections previously interposed, Frontier and Verizon are still investigating this request. Mr. Gregg reserves the right to supplement his responses. 1 service area. 2 3 Q. WHAT WILL THE FINANCES OF THE COMBINED COMPANY LOOK LIKE? 4 A. Set forth below is a table that shows the 2008 reported West Virginia revenues and 5 expenses for Verizon and Frontier, along with the combined total for each category. VERIZON WEST VIRGINIA & FRONTIER 2008 REVENUES & EXPENSES $ Millions VERIZON Revenues 557.1 Expenses: Plant Specific 104.0 General Plant 53.3 Customer Operations 65.3 Corporate Operations 57.5 Depreciation 154.8 Other Taxes 25.7 Federal Taxes 29.6 Total Expenses 490.2 Net Operating Income 66.9 Source: WV Annual Reports 6 7 As can be seen, the combined companies would have revenues of over $700 million and a net operating income of $94 million. Moreover, the combined companies would produce 9 internally-generated cash flow of over $276 million. 10 11 Q. HOW MUCH SUPPORT DOES EACH COMPANY CURRENTLY RECEIVE FROM 12 THE FEDERAL UNIVERSAL SERVICE FUND? 13 ' Net income of $82.6 million plus depreciation of $194.2 million. 8 Corrected 1 2 A. Verizon West Virginia has one non-rural “study area” within West Virginia and received 3 $28.2 million in high-cost model and interstate access support during 2008. Frontier has 4 three rural “study areas” in West Virginia and received $1 5 million in high-cost loop, 5 local switching and interstate access support. Thus, USF support, while substantial, 6 constitutes only 6.2% of the combined companies’ total revenue. 7 8 Q. WILL THIS USF SUPPORT CHANGE AS A RESULT OF THE TRANSACTION? 9 A. It shouldn’t. Under the FCC’s “parent trap” rule,2 a purchasing or successor carrier 10 receives only as much support as the previous carrier received. Accordingly, after the 11 transfer Frontier would continue to receive its own support and would also receive the 12 same amount of support Verizon would have been entitled to in the acquired study area. 13 14 Q. IN SUMMARY, WHAT IS YOUR VIEW OF THE COMBINED COMPANIES? 15 A. After the transfer the combined companies should have adequate scale and scope and 16 sufficient cash flow to cope with any emergency and meet any long-term challenge. The 17 combining of scattered service areas into a single company should also produce 18 substantial efficiencies over time. 19 20 Q. VERIZON IS A LARGE FORTUNE 500 COMPANY. AFTER THE TRANSACTION 21 CLOSES, FRONTIER - THE PARENT COMPANY - WILL NOT BE AS LARGE. 22 WILL ADEQUATE RESOURCES CONTINUE TO BE AVAILABLE TO WEST 47 CFR 654.305 9 Corrected CITIZENS TELECOMMUNICATIONS COMPANY OF WEST VIRGINIA DBA FRONTIER COMMUNICATIONS OF WEST VIRGINIA AND VERIZON WEST VIRGINIA, INC. WEST VIRGINIA PSC CASE NO. 09-0871-T-PC SECOND REQUEST FOR INFORMATION - CWA Name of Person Preparing Response: Billy Jack Gregg Date of Response: August 12,2009 Request 14 Re: p. 8, lines 8-9. Mr. Gregg states that “the combined companies would produce internally-generated cash flow of over $269 million.” Concerning this: (a) Does this figure take into account capital expenditures that may be required as a matter of course as well as those associated with the acquisition? If so, please elaborate. (b) Does this figure take into account any extraordinary expenses that may be associated with the acquisition? If so, please elaborate. (c) Has Mr. Gregg performed any analyses or projections of the cash flow the proposed combined companies will require over time? If so, please provide. (d) In each of the years 2010,201 1, and 2012, how much of a dividend does Mr. Gregg expect the combined West Virginia operation to have to pay to the Frontier parent company in order to support the parent company’s debt service and/or common stock dividend? Please provide the basis for Mr. Gregg’s expectation. (e) In Mr. Gregg’s opinion, would it be reasonable for the combined West Virginia company to pay more than 100% of its net operating income to the Frontier parent company as a dividend to support the parent company’s debt service and/or common stock dividend? Please explain the answer. (f) In Mr. Gregg’s opinion, would it be reasonable for the West Virginia Public Service Commission to impose a condition on the transaction that prohibits the combined West Virginia company from paying more than 100% (or some other percentage) of its net operating income to the Frontier parent company as a dividend? If so, why does he believe such a condition to be reasonable? If not, why not? (g) In Mr. Gregg’s opinion, what should be the maximum percentage of the combined West Virginia company’s “internally-generated cash flow” (as the term is used on page 8 of his testimony) that should be paid to the Frontier parent company as a dividend to support the parent company’s debt service and/or common stock dividend? Please explain the answer. (h) In Mr. Gregg’s opinion, would it be reasonable for the West Virginia Public Service Commission to impose a condition on the transaction that prohibits the combined West Virginia company from paying more than the maximum percentage (identified in response to (g)) of the combined West Virginia company’s “internally-generated cash flow” (as the term is used on page 8 of his testimony) to the Frontier parent company as a dividend? If so, why does he believe such a condition it to be reasonable? If not, why not? Response 14 (a) No. The internally-generated cash flow of $269 million (corrected amount $276 million) used in Mr. Gregg’s testimony is simply the sum of net income and depreciation for each company. These funds are net of payments for taxes and interest and would be available for capital expenditures and dividend payments. Different cash analyses, such as earnings before interest, taxes, depreciation and amortization (EBITDA), would produce higher cash figures than used by Mr. Gregg. (b) No. (c) No. (d) Mr. Gregg has not prepared any such analysis. However, the publicly available proforma financials of the “new” Frontier show approximately 989 million shares of stock after closing. Assuming a $0.75 per share annual dividend post-closing, the annual dividend requirement would be $742 million. If West Virginia is responsible for 1 1% of this dividend requirement, this would amount to $81.6 million. Theproforma also shows post-closing interest expense to be $653 million. If West Virginia is responsible for 11% of this interest expense, this would amount to $71.8 million. Based on these assumptions, the combined total annual payments to the parent, assuming constant dividend payments and interest rates and no change in the principal amount of outstanding debt, would be $1 53.4 million. (e) There may be times when it would be appropriate to pay more than 100% of net income to the parent as dividends. Dividend policy will depend on a number of factors. Generally speaking, a company’s financial flexibility should not be limited. (f) No. As stated in answer to 14(e) above, there may be times when a payment of more than 100% of net operating income is necessary. More importantly, the Commission should not generally impose conditions that limit the financial flexibility of companies under their jurisdiction. However, the Commission should continually monitor the financial condition and cash flow of companies they regulate. (g) Mr. Gregg has no “maximum” dividend pay-out percentage to recommend. The new company post-closing should retain maximum financial flexibility in meeting both Commission requirements and parent company requirements. (h) Not applicable. CITIZENS TELECOMMUNICATIONS COMPANY OF WEST VIRGINIA DBA FRONTIER COMMUNICATIONS OF WEST VIRGINIA AND VERIZON WEST VIRGINIA, INC. WEST VIRGINIA PSC CASE NO. 09-0871-T-PC SECOND REQUEST FOR INFORMATION - CWA Name of Person Preparing Response: Billy Jack Gregg Date of Response: August 12,2009 Request 15 Re: p. 9, lines 14-17. (a) Has Mr. Gregg performed any independent analyses to support these statements? If so, please provide. (b) Has Frontier provided him with any analyses, models, sensitivity runs or other evaluations of the adequacy of the proposed combined companies’ scale, scope, cash flow, and efficiencies? If so, please provide. Response 15 (a) Mr. Gregg’s opinion is based on the size and statewide scope of the combined companies, efficiencies that will be gained by combining the two companies into a single statewide company, and potentially lower corporate operation expenses allocated from the parent. (b) Mr. Gregg reviewed publicly available information on the transaction. CITIZENS TELECOMMUNICATIONS COMPANY OF WEST VIRGINIA DBA FRONTIER COMMUNICATIONS OF WEST VIRGINIA AND VERIZON WEST VIRGINIA, INC. WEST VIRGINIA PSC CASE NO. 09-0871-T-PC SECOND REQUEST FOR INFORMATION - CWA Name of Person Preparing Response: Billy Jack Gregg Date of Response: August 12,2009 Request 16 Re: pp. 10-18. (a) How does Mr. Gregg define “broadband” as used in this portion of his testimony? (b) To the best of Mr. Gregg’s knowledge, do Verizon and Frontier use this same definition of “broadband” when they present figures for broadband availability (or penetration) and broadband customers? If not, please explain Mr. Gregg’s understanding of the different definitions used by Verizon and/or Frontier. Response 16 (a) “Broadband” as used in the testimony is based on the FCC definition, which is a minimum transmission speed of 200 kilobits per second. See, High Speed Services for Internet Access: Status As Of June 30, 2008, FCC IATD (July 2009), page 2: “The terms ‘high-speed connections’ and ‘broadband connections’ are synonyms in this report. The reported connections terminate at end user locations and enable the end user to receive information from and/or send information to the Internet at information transfer rates exceeding 200 kbps in at least one direction.” (b) Yes, to the best of Mr. Gregg’s knowledge. CITIZENS TELECOMMUNICATIONS COMPANY OF WEST VIRGINIA DBA FRONTIER COMMUNICATIONS OF WEST VIRGINIA AND VERIZON WEST VIRGINIA, INC. WEST VIRGINIA PSC CASE NO. 09-0871-T-PC SECOND REQUEST FOR INFORMATION - CWA Name of Person Preparing Response: Billy Jack Gregg Date of Response: August 12,2009 Request 17 Re: p. 10, lines 19-21. (a) Has Mr. Gregg performed any specific, independent analyses of Frontier’s broadband plans in West Virginia post-transaction? If so, please provide. If not, please disclose the basis for Mr. Gregg’s conclusions regarding Frontier’s ability to expand broadband into the current Verizon-West Virginia areas. (b) Please describe specifically (e.g., improvements to outside plant, etc.) how as “Frontier drives broadband into all areas of West Virginia” the result will be that “the quality of basic service will be improved” and describe the aspects that will be improved (e.g., trouble reports, installation intervals, etc.). Response 17 (a) Mr. Gregg’s conclusions are based on his experience with Frontier in West Virginia and Frontier’s overall business plan of bringing broadband to rural areas. (b) Generally speaking, expansion of broadband will involve shortening copper loop lengths by means of installing Litespan or other digital loop carrier outside plant. The replacement of old copper trunks and older generation DLC should not only expand broadband availability but also improve the quality of voice service. This should result in fewer trouble reports and shorter installation intervals. CITIZENS TELECOMMUNICATIONS COMPANY OF WEST VIRGINIA DBA FRONTIER COMMUNICATIONS OF WEST VIRGINIA AND VERIZON WEST VIRGINIA, INC. WEST VIRGINIA PSC CASE NO. 09-0871-T-PC SECOND REQUEST FOR INFORMATION - CWA Name of Person Preparing Response: Billy Jack Gregg Date of Response: August 12,2009 Request 18 Re: p. 1 1, lines 4-1 1. Please provide copies of the WVASTF’s recommendations to the Public Commission regarding “policies to encourage deployment and use of broadband” and include annuals WVASTF reports for 2003 and 2007. Resaonse 18 These documents will be produced. CITIZENS TELECOMMUNICATIONS COMPANY OF WEST VIRGINIA DBA FRONTIER COMMUNICATIONS OF WEST VIRGINIA AND VERIZON WEST VIRGINIA, INC. WEST VIRGINIA PSC CASE NO. 09-0871-T-PC SECOND REQUEST FOR INFORMATION - CWA Name of Person Preparing Response: Billy Jack Gregg Date of Response: August 12,2009 Request 19 Re:-pp. 14-17. In Mr. Gregg’s opinion, does the fact that Frontier West Virginia has a significantly higher level of USF support per line than Verizon West Virginia affect each company’s ability to make broadband available in its service territories? Please elaborate. Response 19 Yes. As stated on page 9 of Mr. Gregg’s testimony, Verizon received $28.2 million in USF support in 2008, while Frontier received $15 million. Dividing these amounts of USF support by the 2008 access lines of both companies produces average support of $3.80 per line per month for Verizon and $8.68 per line per month for Frontier. Although at the current time USF support cannot be used directly for broadband, the higher level of support received by Frontier is obviously helpful in upgrading outside plant which can be used to provision both broadband and basic voice service. CITIZENS TELECOMMUNICATIONS COMPANY OF WEST VIRGINIA DBA FRONTIER COMMUNICATIONS OF WEST VIRGINIA AND VERIZON WEST VIRGINIA, INC. WEST VIRGINIA PSC CASE NO. 09-0871-T-PC SECOND REQUEST FOR INFORMATION - CWA Name of Person Preparing Response: Billy Jack Gregg Date of Response: August 12,2009 Rea ue st 2 0 Re: p. 15, footnote 13. Mr. Gregg uses the terms “households,” “residential access lines,” and “residential customers.” Please provide a workpaper showing separately for Verizon West Virginia and Frontier West Virginia, the number of “households,” “residential access lines,” and “residential customers” served by each at year-end 2008, and the number of each that had broadband access available. Response 20 “Households” is a broader category than “residential access lines” and “residential customers.” Many households do not have any type of telephone service and many households receive telephone service only from wireless providers and/or broadband providers. “Residential access lines” is a broader category than “residential customers” since many customers have more than one access line. Attached is a workpaper showing an estimation of “households,” “residential access lines” and “residential customers’’ for Verizon and Frontier at year-end 2008. Data Request 20 Attachment Verizon Frontier 12/3 l/2008 12/31/2008 Households (HH) 611,375 118,624 Residential Customers (Primary Lines) 421,678 105,273 Non-Primary Residential Lines 12,888 4,034 Total Residential Access Lines 434,566 109,307 Residential Customers w/ BB Available 253,007 95,798 Residential Customers Subscribed to BB 105,875 40,460 % of Customers w/ BB Available 60.00% 91.00% % of Customers Subscribed to BB 25.11% 38.43% % of Customers Subscribed w/ BB Ava ila b I e 41.85% 42.23% CITIZENS TELECOMMUNICATIONS COMPANY OF WEST VIRGINIA DBA FRONTIER COMMUNICATIONS OF WEST VIRGINIA AND VERIZON WEST VIRGINIA, INC. WEST VIRGINIA PSC CASE NO. 09-0871-T-PC SECOND REQUEST FOR INFORMATION - CWA Name of Person Preparing Response: Billy Jack Gregg Date of Response: August 12,2009 Request 2 1 Re: p. 16,line 20 to p. 17, line 6. Please confirm the following or revise as appropriate: 94% of Frontier’s customers have access to broadband. Approximately 43% of Frontier’s customers subscribe to broadband. Therefore, approximately 46% of those Frontier customers for whom broadband is an option subscribe to broadband. 60% of Verizon’s customers have access to broadband. Approximately 25% of Verizon’s customers subscribe to broadband. Therefore, approximately 42% of those Verizon customers for whom broadband is an option subscribe to broadband. Response 21 The statement is correct. See workpaper attached to data request 20. CITIZENS TELECOMMUNICATIONS COMPANY OF WEST VIRGINIA DBA FRONTIER COMMUNICATIONS OF WEST VIRGINIA AND VERIZON WEST VIRGINIA, INC. WEST VIRGINIA PSC CASE NO. 09-0871-T-PC SECOND REQUEST FOR INFORMATION - CWA Name of Person Preparing Response: Billy Jack Gregg Date of Response: August 12,2009 Request 22 Re: p. 16, lines 20-21: (a) Please provide the underlying data for these percentages. (b) Are the references to broadband intended to refer to any type of broadband or specifically to Frontier’s and Verizon’ s broadband service? (c) Please confirm that the analysis encompassed by the referenced statement does not include any households that are served by providers other than Verizon and Frontier. For example, the analysis does not include a customer that is located in Verizon’s territory but has migrated from Verizon to a cable company. Response 22 (a) Please see documents produced in response to Request No. 1. Frontier also provided household data for its service territory. Data for the Verizon WV territory was not provided by Verizon, but was derived by Mr. Gregg, as explained on the attachment hereto. Verizon confirmed that the derived data were accurate. (b) The references to broadband refer to Frontier and Verizon’s broadband service. Within Frontier and Verizon’s territory, more households have broadband service than subscribe to broadband from Frontier and Verizon. This is because there are other providers of broadband service, such as cable companies. (c) Confirmed, to the best of Mr. Gregg’s knowledge. See above. Data Request 22 Attachment DERIVATION OF BROADBAND SUBSCRIPTION DATA FOR VERIZON WEST VIRGINIA SERVICE TERRITORY At the time Mr. Gregg prepared his testimony, the most recent FCC broadband report showed 297,852 residential broadband and 38,43 1 business broadband customers in West Virginia as of the end of 2007. In other words, 88.5% of total broadband lines were residential. Of the total broadband customers, 137,948 were DSL customers. Assuming an addition of 33,000 DSL customers in 2008 (the same gain as for the last two years), Mr. Gregg estimated total DSL customers in West Virginia at the end of 2008 at 171,000. Assuming that 88.5% of these customers were residential, Mr. Gregg estimated that there were 151,335 DSL residential customers in West Virginia at the end of 2008. Mr. Gregg had access to Frontier’s broadband customer counts. Subtracting Frontier residential DSL totals at the end of 2008 (40,460) and subtracting an estimate of 5,000 residential DSL customers served by other ILECs in West Virginia left 105,875 residential DSL customers. Mr. Gregg concluded that these customers must be served by Verizon. Dividing Verizon DSL residential customers by total Verizon residential lines (primary and lifeline) as reported to the Public Service Commission - 42 1,678 - produced an estimate of 25% broadband subscription by Verizon customers in West Virginia. CITIZENS TELECOMMUNICATIONS COMPANY OF WEST VIRGINIA DBA FRONTIER COMMUNICATIONS OF WEST VIRGINIA AND VERIZON WEST VIRGINIA, INC. WEST VIRGINIA PSC CASE NO. 09-0871-T-PC SECOND REQUEST FOR INFORMATION - CWA Name of Person Preparing Response: Billy Jack Gregg Date of Response: August 12,2009 Request 23 Re: p. 17, lines 4-6. (a) Please provide the underlying data for these percentages. (b) Are the references to broadband intended to refer to any type of broadband or specifically to Frontier’s and Verizon’ s broadband service? Response 23 (a) See response to data request 22(a). (b) See response to data request 22(b). CITIZENS TELECOMMUNICATIONS COMPANY OF WEST VIRGINIA DBA FRONTIER COMMUNICATIONS OF WEST VIRGINIA AND VERIZON WEST VIRGINIA, INC. WEST VIRGINIA PSC CASE NO. 09-0871-T-PC SECOND REQUEST FOR INFORMATION - CWA Name of Person Preparing Response: Billy Jack Gregg Date of Response: August 12,2009 Request 24 Re: p. 17, lines 20-22. Has Mr. Gregg evaluated any differences in the level and intensity of competition from cable providers between Verizon West Virginia and Frontier West Virginia? Please elaborate. Response 24 Cable companies provide cable modem service in the service territories of both Verizon and Frontier. However, to the extent that Verizon serves more urban areas in West Virginia than Frontier, it may face more competition from cable companies in those urban areas. CITIZENS TELECOMMUNICATIONS COMPANY OF WEST VIRGINIA DBA FRONTIER COMMUNICATIONS OF WEST VIRGINIA AND VEIUZON WEST VIRGINIA, INC. WEST VIRGINIA PSC CASE NO. 09-0871-T-PC SECOND REQUEST FOR INFORMATION - CWA Name of Person Preparing Response: Billy Jack Gregg Date of Response: August 12,2009 Request 25 Re: p. 18, lines 13-15. Mr. Gregg states that he “would expect the Verizon service territory to achieve significantly higher deployment levels within several years following the closing of the transaction.” (a) Among other factors supporting this statement, Mr. Gregg cites “cash flow and universal service support that will be available to the combined companies . . .” What cash flows or universal service support will be available to the combined companies that are not available now? (b) Does Mr. Gregg anticipate that Frontier will reallocate cash flows and/or universal service support from its Frontier areas in West Virginia to its newly acquired Verizon areas in West Virginia? If so, please elaborate. If not, please explain why the proposed transaction will result in increased cash flows or universal service support to the Verizon service territories in West Virginia. (c) Has Mr. Gregg analyzed any new cash flow-impacting expenses associated with the transaction? If so, please elaborate. If not, why not? Response 25 (a) Although the cash flow and universal service support of Verizon West Virginia and Frontier West Virginia may change in the future, this would be true even if the transaction did not occur. However, because the combined companies will serve the entire state, all the resources of both companies can be deployed in a more rational manner to benefit the entire state. (b) As stated above, the combined companies will be able to deploy available resources to the entire state in a more rational manner. This may involve reallocation of cash flows from one part of the state to another. (c) No. See responses to data requests 14(d) and 15(a) above. CITIZENS TELECOMMUNICATIONS COMPANY OF WEST VIRGINIA DBA FRONTIER COMMUNICATIONS OF WEST VIRGINIA AND VERIZON WEST VIRGINIA, INC. WEST VIRGINIA PSC CASE NO. 09-0871-T-PC SECOND REQUEST FOR INFORMATION - CWA Name of Person Preparing Response: Billy Jack Gregg Date of Response: August 12,2009 Resue st 2 6 Re: pp. 22-25. With respect to Mr. Gregg’s statements regarding the problems associated with the Carlyle Group Hawaiian and FairPoint Northern New England transactions, (a) Please provide all documents, and summarize all discussions, prior to his testimony, upon which Mr. Gregg based his statements and conclusions. Prior to his testimony, did Mr. Gregg perform any independent analyses or investigations into the problems associated with either of these transactions? If so, please ~ provide the results of such analyses or investigations. If not, why not? (b) Please provide all documents shared with Mr. Gregg, and summarize all discussions with him, regarding the either of the above-referenced transactions, subsequent to his testimony. Response 26 (a) Prior to his testimony, Mr. Gregg read many articles and publicly available materials concerning the problems with the Hawaii and Northern New England transactions. Mr. Gregg also discussed the Hawaii transaction with Stephen G. Hill, a witness in the proceeding in Hawaii concerning the transaction, and Ken Mason of Frontier. Mr. Gregg did not perform any independent analysis or investigations into the problems associated with these transactions. (b) None. CITIZENS TELECOMMUNICATIONS COMPANY OF WEST VIRGINIA DBA FRONTIER COMMUNICATIONS OF WEST VIRGINIA AND VERIZON WEST VIRGINIA, INC. WEST VIRGINIA PSC CASE NO. 09-0871-T-PC SECOND REQUEST FOR INFORMATION - CWA Name of Person Preparing Response: Billy Jack Gregg Date of Response: August 12,2009 Request 27 Re: p. 23, lines 18-1 9. With respect to Mr. Gregg’s statement that “Frontier has already successfully integrated other acquisitions,” did Mr. Gregg, prior to his testimony, evaluate Fairpoint’s experience with integrating other acquisitions prior to the Verizon Northern New England transaction? If so, please elaborate. Response 27 No. While Mr. Gregg was aware that Fairpoint had made other acquisitions prior to the Northern New England transaction, he did not investigate Fairpoint’s integration of these acquisitions. CITIZENS TELECOMMUNICATIONS COMPANY OF WEST VIRGINIA DBA FRONTIER COMMUNICATIONS OF WEST VIRGINIA AND VERIZON WEST VIRGINIA, INC. WEST VIRGINIA PSC CASE NO. 09-0871-T-PC SECOND REQUEST FOR INFORMATION - CWA Name of Person Preparing Response: Billy Jack Gregg Date of Response: August 12,2009 Request 28 Re: pp. 23-25. Among the reasons Mr. Gregg cites in support of his statement that he “does not believe the same problems are likely to occur in West Virginia” as are being experienced by Fairpoint is the assertion that “the Frontierrnerizon transaction will actually reduce Frontier’s debt exposure.” At the time of his testimony, what was Mr. Gregg’s understanding of Fairpoint’s original expectation of the effect of the Northern New England transaction on Fairpoint’s debt exposure? Response 28 Mr. Gregg is unaware of Fairpoint’s original expectations. However, based on publicly available information, he is aware that the result of the transaction was an increase in Fairpoint’s debt exposure. CITIZENS TELECOMMUNICATIONS COMPANY OF WEST VIRGINIA DBA FRONTIER COMMUNICATIONS OF WEST VIRGINIA AND VERIZON WEST VIRGINIA, INC. WEST VIRGINIA PSC CASE NO. 09-0871-T-PC SECOND REQUEST FOR INFORMATION - CWA Name of Person Preparing Response: Billy Jack Gregg Date of Response: August 12,2009 Res uest 2 9 Please list the name and title of each person with whom Mr. Gregg discussed the Northern New England transition experience of Fairpoint prior to his testimony, and separately, list the name and title of each person, if any, with whom he discussed this following his testimony. Response 29 Prior to his testimony Mr. Gregg__ discussed the Fairpoint transaction with Stephen G. Hill, Principal of Hill & Associates, and Ken Mason, Vice-president, Regulatory Affairs, Frontier Communications. Following his testimony Mr. Gregg discussed the Fairpoint transaction with John Burke, Commissioner, Vermont Public Service Board; David Coen, Commissioner, Vermont Public Service Board; George Young, Vermont PSB Staff; Scott Hempling, Director, National Regulatory Research Institute; and Peter Bluhm, Principal Researcher, National Regulatory Research Institute. CITIZENS TELECOMMUNICATIONS COMPANY OF WEST VIRGINIA DBA FRONTIER COMMUNICATIONS OF WEST VIRGINIA AND VERIZON WEST VIRGINIA, INC. WEST VIRGINIA PSC CASE NO. 09-0871-T-PC SECOND REQUEST FOR INFORMATION - CWA Name of Person Preparing Response: Billy Jack Gregg Date of Response: August 12,2009 Request 30 Please list the name and title of each person with whom Mr. Gregg__ discussed the transition experience of Hawaiian Telecom, prior to his testimony, and separately, list the name and title of each person, if any, with whom he discussed this following his testimony. Response 30 Prior to his testimony Mr. Gregg discussed the Hawaiian Telecom transaction with Stephen G. Hill, Principal of Hill & Associates, and Ken Mason, Vice-president, Regulatory Affairs, Frontier Communications. Following his testimony Mr. Gregg discussed the Hawaiian Telecom transaction with Carlito Caliboso, Chairman, Hawaii Public Utilities Commission. CITIZENS TELECOMMUNICATIONS COMPANY OF WEST VIRGINIA DBA FRONTIER COMMUNICATIONS OF WEST VIRGINIA AND VERIZON WEST VIRGINIA, INC. WEST VIRGINIA PSC CASE NO. 09-0871-T-PC SECOND REQUEST FOR INFORMATION - CWA Name of Person Preparing Response: Billy Jack Gregg Date of Response: August 12,2009 Request 3 1 To the best of Mr. Gregg’s knowledge, has any former Bell Atlantic operating company sold any portion of its service area to another company? If so, please list the specific companies and operating areas involved and discuss any transition or conversion problems experienced by the new owner. If not, then what is the basis for Mr. Gregg’s conclusion that Frontier will be able to engage in such a transition and conversion without experiencing significant problems? Response 3 1 To Mr. Gregg’s knowledge, no portion of the former Bell Atlantic wireline operating company has been sold to another company. Mr. Gregg’s conclusion that Frontier will be able to engage in the current acquisition and conversion without experiencing significant problems is based on Frontier’s past acquisitions and conversions in West Virginia and other parts of the nation. CITIZENS TELECOMMUNICATIONS COMPANY OF WEST VIRGINIA DBA FRONTIER COMMUNICATIONS OF WEST VIRGINIA AND VERIZON WEST VIRGINIA, INC. WEST VIRGINIA PSC CASE NO. 09-0871-T-PC SECOND REQUEST FOR INFORMATION - CWA Name of Person Preparing Response: Billy Jack Gregg Date of Response: August 12,2009 Reauest 32 Re: p. 25, lines 13-22. Mr. Gregg discusses certain information conveyed to him by “Frontier officials.” Please identify the Frontier officials with whom Mr. Gregg discussed Frontier’s experience and plans with respect to the conversion of billing systems. Please disclose any information that Mr. Gregg obtained with respect to the conversion of billing and other systems at Commonwealth Telephone and Rochester Telephone, including the timing of key phases of such conversions. Response 32 Dan McCarthy, Chief Operating Officer, Frontier Communications; and Ken Mason, Vice- President, Regulatory Affairs, Frontier Communications. Discussions centered on results rather than procedures of such conversions. CITIZENS TELECOMMUNICATIONS COMPANY OF WEST VIRGINIA DBA FRONTIER COMMUNICATIONS OF WEST VIRGINIA AND VERIZON WEST VIRGINIA, INC. WEST VIRGINIA PSC CASE NO. 09-0871-T-PC SECOND REQUEST FOR INFORMATION - CWA Name of Person Preparing Response: Billy Jack Gregg Date of Response: August 12,2009 Request 33 Re: p. 26, line 3. Please provide any documents, data, reports, or other information relied upon by Mr. Gregg to conclude that “Frontier has a good track record on quality of service in West Virginia.” Response 33 The statement is based on Mr. Gregg’s experience with Frontier as a telecommunications provider in West Virginia since 1993. Mr. Gregg also researched quality of service complaints received by the Commission in 2009. Attached hereto is a printout of complaints (requests for assistance or RFAs) received by the Commission from January 1, 2009 through June 15,2009, concerning Frontier and Verizon, along with a worksheet prepared by Mr. Gregg from this RFA data. (Please note that customer names have been redacted.) Data Request 33 Attachment SERVICE QUALITY COMPLAINTS IN WEST VIRGINIA 2009 Category Verizon Frontier Total RFAs 997 53 1I.B. Reception or Transmission Problems 3 12 18 II.D.1. Customer Reported Outage 483 11 ll.D.2. Utility Reported Outage 11 0 Reception or Outage Complaints 806 29 Access Lines 617,068 143,982 Reception or Outage per 1000 Lines 1.31 0.20 Source: WV PSC Special Studies RFAs through June 15,2009 Data Request 33 Attachment Citizens Telecommunications Company of West VirginiaBrontier Communications of West Virginia January 1,2009 through June 15,2009 ComplaintNumber Loggedln ComplaintType CustRep Complainant 2009R-0 1870 212712009 I-B SLF Redacted 2009R-006 15 1/812009 I-E ELY Redacted 2009R-01458 211 112009 I-E JAT Redacted 2009R-03305 4/28/2009 I-E JAT Redacted 2009R-04475 611212009 I-E ALW Redacted 2009R-03062 411 712009 I-G SLF Redacted 2009R-03269 412712009 I-G JAT Redacted 2009R-00504 1/5/2009 JAT Redacted 2009R-00762 111312009 CAP Redacted 2009R-00806 111412009 JAT Redacted 2009R-00886 111 612009 SMM Redacted 2009R-0 16 16 211 812009 MMV Redacted 2009R-01898 31212009 MMV Redacted 2009R-02560 312712009 ALW Redacted 2009R-02997 411 512009 SLF Redacted 2009R-03051 411 712009 ALW Redacted 2009R-03298 412812009 SLF Redacted 2009R-03773 5l1412009 JAT Redacted 2009R-03 800 511512009 MMV Redacted 2009R-04029 512812009 SLF Redacted 2009R-04 1 82 61312009 ALW Redacted 2009R-04360 6/9/2009 JAT Redacted 2009R-043 70 61912009 ELY Redacted 2009R-04408 6/10/2009 ELY Redacted 2009R-04469 611212009 MMV Redacted 2009R-0 15 13 211312009 IT-B-~ JAT Redacted 2009R-0 1935 31312009 11-C-3 SLF Redacted 2009R-02668 313 112009 11-C-3 MMV Redacted 2009R-03429 5/4/2009 IT-c-3 SLF Redacted 2009R-03746 511 412009 IT-c-3 ELY Redacted 2009R-04 166 61312009 11-c-3 SLF Redacted 2009R-00905 112012009 11-C-4 ALW Redacted 2009R-00969 1I2 1I2009 11-C-4 SMM Redacted 2009R-0 1 807 212512009 11-C-4 ALW Redacted 2009R-02001 31512009 11-C-4 ELY Redacted 2009R-02 173 311 212009 11-C-4 MMV Redacted 2009R-02905 4/9/2009 11-C-4 JAT Redacted 2009R-04 174 61312009 --TT-C-4 - JAT Redacted 200913-00489 1l512009 11-D- 1 JAT Redacted 2009R-01469 211212009 11-D- 1 MMV Redacted 2009R-0 15 10 211312009 11-D-1 SMM Redacted 2009R-0 1 823 212512009 11-D-1 SLF Redacted 2009R-02398 312012009 11-D- 1 ALW Redacted Data Request 33 Attachment Citizens Telecommunications Company of West Virginiamrontier Communications of West Virginia January 1,2009 through June 15,2009 ComplaintNumber Loggedln ComplaintType CustRep Complainant 2009R-033 98 5/1/2009 SLF Redacted 2009R-03462 5/4/2009 ELY Redacted 2009R-03843 511 912009 MMV Redacted 2009R-03864 511 912009 JAT Redacted 2009R-04 164 6/3/2009 SLF Redacted 2009R-04240 6/5/2009 SLF Redacted - .. Data Request 33 Attachment Verizon West Virginia Inc. January I,2009 through June 15, 2009 ComplaintNumber Loggedln CompiaintType CustRep Complainant 2009R-00789 ll1412009 I-B MMV Redacted 2009R-0 1677 211 912009 I-B SLF Redacted 2009R-03056 411712009 I-B SLF Redacted 2009R-03373 413012009 I-B MMV Redacted 2009R-04252 61512009 I-B MMV Redacted 2009R-004 1 1 1/2/2009 I-E JAT Redacted 2009R-00440 112/2009 I-E CAP Redacted 2009R-00485 1/5/2009 I-E SMM Redacted 2009R-00497 1I512009 I-E JAT Redacted 2009R-00532 11612009 I-E ALW Redacted 2009R-00673 1/912009 I-E ELY Redacted 2009R-00681 1l912009 I-E ELY Redacted 2009R-00775 1l1312009 I-E CAP Redacted 2009R-00823 111 512009 I-E SMM Redacted 2009R-00835 111 512009 I-E SMM Redacted 2009R-00844 111 512009 I-E MMV Redacted 2009R-00904 1120/2009 I-E SMM Redacted 2009R-00907 1/20/2009 I-E MMV Redacted 2009R-0 1034 112312009 I-E SMM Redacted 2009R-0 1106 112712009 I-E JAT Redacted 2009R-0 1159 112912009 I-E ELY Redacted 2009R-01266 213 I2009 I-E ALW Redacted 2009R-0 1270 21412009 I-E MMV Redacted 2009R-0 1402 2l1012009 I-E CAP Redacted 2009R-0 14 10 2l1012009 I-E JAT Redacted 2009R-0 1524 211712009 I-E JAT Redacted 200913-01577 211 712009 I-E CAP Redacted 2009R-01780 212412009 I-E CAP Redacted 2009R-0 1790 212412009 I-E ELY Redacted 2009R-01794 212412009 I-E JAT Redacted 2009R-01952 31312009 I-E ALW Redacted 2009R-02021 31512009 I-E ELY Redacted 2009R-02025 31512009 I-E CAP Redacted 2009R-02175 3l1212009 I-E CAP Redacted 2009R-02178 311212009 I-E SMM Redacted 200913-02207 311212009 I-E CAP Redacted 2009R-022 12 311312009 I-E MMV Redacted 2009R-02236 311 612009 I-E SMM Redacted 2009R-02391 312012009 I-E JAT Redacted 2009R-02488 312412009 I-E ELY Redacted 2009R-02592 312712009 I-E MMV Redacted 2009R-02662 313 112009 I-E MMV Redacted 2009R-02674 313 112009 I-E MMV Redacted 2009R-02741 41312009 I-E SMM Redacted Data Request 33 Attachment Verizon West Virginia Inc. January 1,2009 through June 15, 2009 ComplaintNumber Loggedln ComplaintType CustRep Complainant 2009R-02878 4/9/2009 I-E SMM Redacted 2009R-03253 4/27/2009 I-E CAP Redacted 2009R-03778 5/15/2009 I-E MMV Redacted 2009R-039 11 512 112009 I-E ALW Redacted 2009R-0402 1 5/28/2009 I-E JAT Redacted 2009R-04027 5/28/2009 I-E ELY Redacted 2009R-04044 5/28/2009 I-E JAT Redacted 2009R-04079 5/29/2009 I-E SMM Redacted 2009R-04096 6/1/2009 I-E ALW Redacted 200913-04097 6/1/2009 I-E SLF Redacted 2009R-04204 6/4/2009 I-E ALW Redacted 2009R-04223 6/4/2009 I-E ELY Redacted 2009R-04229 6/4/2009 I-E SMM Redacted 2009R-04250 6/5/2009 I-E ALW Redacted 2009R-04293 6/8/2009 I-E SLF Redacted 2009R-04340 6/9/2009 I-E JAT Redacted 2009R-02824 4/7/2009 I-F-4 MMV Redacted 2009R-0 1464 2/12/2009 I-G SLF Redacted 2009R-02422 3/23/2009 I-G SLF Redacted 200913-02561 3/27/2009 I-G SLF Redacted 2009R-03 1 18 4/21/2009 I-G SLF Redacted 2009R-03294 4/28/2009 I-G SLF Redacted 2009R-03433 5/4/2009 I-G SLF Redacted 2009R-04495 6/12/2009 I-G MMV Redacted 2009R-00406 1/2/2009 SMM Redacted 2009R-00422 11212 0 09 ELY Redacted 2009R-00428 1/2/2009 SLF Redacted 2009R-0043 1 1I212009 JAT Redacted 2009R-00437 1/2/2009 SMM Redacted 2009R-00439 1/2/2009 MMV Redacted 2009R-00455 1I512009 SLF Redacted 2009R-00459 1/5/2009 SMM Redacted 2009R-00462 1/5/2009 SMM Redacted 2009R-00469 1/5/2009 ALW Redacted 2009R-00473 1/5/2009 MMV Redacted 2009R-00480 1I512009 JAT Redacted 2009R-00487 1/5/2009 SMM Redacted 2009R-00492 1/5/2009 SLF Redacted 2009R-00495 1/5/2009 SMM Redacted 2009R-005 15 1/6/2009 ELY Redacted 2009R-00525 1I612009 ELY Redacted 2009R-00528 1/6/2009 SIVfM Redacted 2009R-00536 1/6/2009 ALW Redacted 2009R-00548 1I612009 JAT Redacted 2009R-00555 1/7/2009 JAT Redacted Data Request 33 Attachment Verizon West Virginia Inc. January I,2009 through June 15,2009 ComplaintNumber Loggedln ComplaintType CustRep Complainant 2009R-00557 1/7/2009 ALW Redacted 2009R-00560 1/7/2009 JAT Redacted 2009R-00584 1/7/2009 SMM Redacted 2009R-00586 1/7/2009 SMM Redacted 2009R-00605 1/8/2009 CAP Redacted 2009R-00637 11812009 CAP Redacted 2009R-00657 1/9/2009 ALW Redacted 2009R-00666 1/9/2009 SMM Redacted 2009R-00677 1/9/2009 CJN Redacted 2009R-00702 1/12/2009 SMM Redacted 2009R-00710 1/12/2009 MMV Redacted 2009R-00732 1/ 12/2 00 9 CAP Redacted 2009R-00752 Ill 312009 MMV Redacted 2009R-00756 111 312009 MMV Redacted 2009R-00773 1I1 3I2009 MMV Redacted 2009R-00784 1/14/2009 SMM Redacted 2009R-00790 1I1 412009 SMM Redacted 2009R-00807 1/14/2009 SMM Redacted 2009R-008 10 111 412009 ELY Redacted 2009R-008 16 1l14l2009 CAP Redacted 2009R-00826 111 512009 ALW Redacted 2009R-00884 1/16/2009 MMV Redacted 2009R-00895 1/16/2009 MMV Redacted 2009R-00899 1l20l2009 SLF Redacted 2009R-00928 1/20/2009 ALW Redacted 2009R-00935 1/20/2009 ELY Redacted 2009R-00944 1/2112009 SMM Redacted 2009R-00964 112 112009 ELY Redacted 2009R-00974 1I2212009 MMY Redacted 2009R-00975 1/2212009 MMV Redacted 2009R-01032 1/22/2009 SLF Redacted 2009R-0 1054 112312009 SMM Redacted 2009R-0 1066 1/26/2009 MMV Redacted 2009R-0 1067 112612009 SLF Redacted 2009R-0 1073 112612009 MMV Redacted 2009R-01078 112612009 SLF Redacted 2009R-0 1086 112612009 ALW Redacted 2009R-0 1128 112812009 ELY Redacted 2009R-01131 1/28/2009 SLF Redacted 2009R-0 1 144 1/29/2009 CAP Redacted 2009R-01147 1129/2009 SLF Redacted 2009R-01149 112912009 SLF Redacted 2009R-0 1162 112912009 CAP Redacted 2009R-01212 21212009 SMM Redacted 200913-012 19 21212009 MMV Redacted Data Request 33 Attachment Verizon West Virginia Inc. January 1, 2009 through June 15, 2009 ComplaintNumber Loggedln CompiaintType Cust Re p Complainant 2009R-0 1234 2/2/2009 SMM Redacted 2009R-01250 2/3/2009 MMV Redacted 2009R-01258 2/3/2009 MMV Redacted 2009R-0 1262 2/3/2009 MMV Redacted 2009R-0 1264 2/3/2009 ALW Redacted 2009R-0 1277 2/4/2009 MMV Redacted 2009R-01322 2/5/2009 ELY Redacted 2009R-0 1352 2/6/2009 MMV Redacted 2009R-0 1378 2/9/2009 SLF Redacted 200913-01379 2/9/2009 MMV Redacted 2009R-01381 2/9/2009 CAP Redacted 2009R-01390 2/9/2009 JAT Redacted 2009R-0 140 1 211 012009 JAT Redacted 2009R-0 1404 211 012009 SLF Redacted 2009R-0 1406 211 012009 SMM Redacted 2009R-01415 2/10/2009 MMV Redacted 2009R-0 14 19 2/1012009 MMV Redacted 2009R-01420 211 012009 JAT Redacted 2009R-01423 211 ol2009 MMV Redacted 2009R-0 1429 211 112009 MMV Redacted 2009R-0143 1 211 112009 SMM Redacted 2009R-01432 211 112009 SLF Redacted 2009R-0 1457 211 112009 SLF Redacted 2009R-01461 211212009 MMV Redacted 2009R-01476 2/12/2009 MMV Redacted 2009R-0 1483 2r 12~009 MMV Redacted 2009R-015 12 211 312009 MMV Redacted 2009R-0 15 17 211 312009 MMV Redacted 2009R-0 1546 211 712009 MMV Redacted 2009R-01558 211 712009 CAP Redacted 2009R-0 1563 2/17/2009 MMV Redacted 2009R-01573 2/17/2009 CAP Redacted 2009R-0 1606 211 812009 MMV Redacted 2009R-0 16 12 211 812009 SMM Redacted 2009R-0 16 13 211 812009 SLF Redacted 2009R-0 16 18 2/18/2009 SMM Redacted 2009R-0 1622 211 812009 CAP Redacted 2009R-0 1624 211 812009 SLF Redacted 2009R-0 1625 211 812009 ALW Redacted 2009R-0 1627 211 812009 CAP Redacted 2009R-0 1650 211 912009 MMV Redacted 2009R-0 1673 211 912009 SMM Redacted 2009R-01678 2/19/2009 SMM Redacted 2009R-0 1679 2/19/2009 CAP Redacted 2009R-0 1693 212012009 CAP Redacted Data Request 33 Attachment Verizon West Virginia Inc. January 1, 2009 through June 15, 2009 ComplaintNumber Loggedln ComplaintType CustRep Complainant 2009R-0 1694 212012009 MMV Redacted 2009R-0 1700 212012009 JAT Redacted 2009R-0 1704 212012009 ELY Redacted 2009R-0 1 705 212 012 009 MMV Redacted 2009R-0 1728 212312009 MMV Redacted 2009R-01733 212312009 CAP Redacted 2009R-0 1739 212312009 MMV Redacted 2009R-0 1742 212312009 MMV Redacted 2009R-0 1762 212312009 CAP Redacted 2009R-0 1764 2123 I2009 CAP Redacted 2009R-0 1769 212 3I2 00 9 CAP Redacted 2009R-0 1798 212412009 MMV Redacted 2009R-0 1 804 212412009 CAP Redacted 2009R-0 18 18 212512009 JAT Redacted 2009R-01830 212 512009 CAP Redacted 2009R-0 1838 212612009 ELY Redacted 2009R-0 1845 212612009 SLF Redacted 2009R-0 1847 212612009 SLF Redacted 2009R-01867 212712009 MMV Redacted 2009R-0 1887 3/2/2009 SLF Redacted 2009R-0 1894 3/2/2009 SMM Redacted 2009R-0 1905 31212009 CAP Redacted 2009R-0 1925 3I3 I20 09 ELY Redacted 2009R-0 195 1 3/3/2009 CAP Redacted 2009R-02023 3/5/2009 ELY Redacted 2009R-02041 31612009 CAP Redacted 2009R-02056 31612009 SMM Redacted 2009R-02078 3/9/2009 ALW Redacted 2009R-02095 3/9/2009 JAT Redacted 2009R-02 132 3110/2009 MMV Redacted 2009R-02 176 311212009 MMV Redacted 2009R-02204 3/12/2009 CAP Redacted 2009R-02209 311 312009 SMM Redacted 2009R-02235 31 1612009 MMV Redacted 2009R-02237 311 612009 ELY Redacted 2009R-02239 311612009 ELY Redacted 2009R-02243 311612009 JAT Redacted 2009R-02244 311612009 MMV Redacted 2009R-02245 311612009 SLF Redacted 2009R-0225 1 311 612009 MMV Redacted 2009R-02270 31 1612009 SLF Redacted 2009R-02283 311 712009 JAT Redacted 2009R-023 1 1 311 812009 MMV Redacted 2009R-023 18 311 812009 ALW Redacted 2009R-02342 311912009 H-B MMV Redacted Data Request 33 Attachment Verizon West Virginia Inc. January I,2009 through June 15, 2009 ComplaintNumber Loggedln Com plain tType CustRep Complainant 2009R-02354 311912009 JAT Redacted 2009R-02360 311912009 MMV Redacted 2009R-02393 312012009 JAT Redacted 2009R-02400 312012009 MMV Redacted 2009R-02428 312312009 JAT Redacted 2009R-02435 312312009 JAT Redacted 200913-02442 312312009 MMV Redacted 2009R-02498 312512009 JAT Redacted 2009R-02524 312612009 SMM Redacted 2009R-02558 312712009 MMV Redacted 2009R-02564 312712009 SLF Redacted 2009R-02579 312712009 ALW Redacted 2009R-02600 313012009 ALW Redacted 2009R-02623 313012009 ELY Redacted 2009R-02637 3I3 012009 SLF Redacted 2009R-02643 313012009 JAT Redacted 2009R-02645 313 112009 MMV Redacted 2009R-02652 313 112009 SMM Redacted 2009R-02665 313 112009 MMV Redacted 2009R-02672 313 112009 ALW Redacted 2009R-02695 41112009 CAP Redacted 2009R-02688 4/1/2009 ALW Redacted 2009R-02701 41112009 MMV Redacted 200913-02704 4/1/2009 MMV Redacted 2009R-02705 411 I2009 CAP Redacted 2009R-02735 4/2/2009 ELY Redacted 2009R-02744 41312009 SMM Redacted 200913-02747 41312009 SLF Redacted 2009R-02750 4/3/2009 SLF Redacted 2009R-02796 4/6/2009 SLF Redacted 2009R-028 14 4/7/2009 ALW Redacted 2009R-02820 41712009 SLF Redacted 2009~-02a21 41712009 JAT Redacted 2009R-02853 4/8/2009 SLF Redacted 2009R-02857 4/8/2009 MMV Redacted 2009R-02864 4/8/2009 MMV Redacted 2009R-02875 4/9/2009 MMV Redacted 2009R-02902 4/9/2009 ELY Redacted 2009R-029 1 1 411012009 ELY Redacted 2009R-029 19 411 012009 MMV Redacted 2009R-02939 411312009 MMV Redacted 2009R-02956 411412009 MMV Redacted 2009R-02985 411 512009 MMV Redacted 2009R-03007 411 512009 CAP Redacted 2009R-03022 411 612009 SLF Redacted Data Request 33 Attachment Verizon West Virginia Inc. January 1, 2009 through June 15, 2009 ComplaintNumber Loggedln ComplaintType CustRep Complainant 200913-03052 411 712009 CAP Redacted 2009R-03057 411712009 ALW Redacted 2009R-03 1 15 412 112009 ELY Redacted 2009R-03 168 412212009 ALW Redacted 2009R-03 169 412212009 CAP Redacted 2009R-03 178 412212009 ELY Redacted 2009R-03 186 4/23/2009 SMM Redacted 2009R-03 194 412312009 ELY Redacted 2009R-03201 412 312 00 9 SLF Redacted 2009R-03213 412312009 CAP Redacted 2009R-03220 412412009 SMM Redacted 2009R-03223 412412009 ELY Redacted 2009R-03232 412412009 CAP Redacted 2009R-03252 412712009 SLF Redacted 2009R-0328 1 412712009 CAP Redacted 2009R-03332 412 912 00 9 SLF Redacted 2009R-03342 412912009 SLF Redacted 2009R-03361 413012009 JAT Redacted 2009R-03366 413012009 ALW Redacted 2009R-03414 51 1I2009 ALW Redacted 2009R-0343 1 5/4/2009 SMM Redacted 2009R-03432 51412009 JAT Redacted 2009R-03477 5/5/2009 MMV Redacted 2009R-03488 51512009 JAT Redacted 2009R-03494 5/512009 ELY Redacted 2009R-03497 51512009 SMM Redacted 2009R-035 11 5/5/2009 ELY Redacted 2009R-03529 5/6/2009 MMV Redacted 2009R-03575 5/7/2009 MMV Redacted 2009R-03 580 51712009 MMV Redacted 2009R-036 10 51812009 ALW Redacted 2009R-03616 5/8/2009 CAP Redacted 2009R-03622 51812009 CAP Redacted 200913-03 624 51812009 CAP Redacted 2009R-03633 511 112009 JAT Redacted 2009R-03636 511 112009 SMM Redacted 200913-03639 511 112009 ELY Redacted 2009R-03644 511 112009 JAT Redacted 2009R-03658 511 112009 ELY Redacted 2009R-03669 511212009 MMV Redacted 2009R-03673 5/12/2009 SMM Redacted 2009R-0373 8 511412009 SMM Redacted 2009R-03751 511412009 SMM Redacted 2009R-03700 511 512009 MMV Redacted 2009R-03814 511 812009 SMM Redacted Data Request 33 Attachment Verizon West Virginia Inc. January 1, 2009 through June 15, 2009 ComplaintNumber Loggedln ComplaintType CustRep Complainant 2009R-03863 5/19/2009 SMM Redacted 2009R-03939 5/26/2009 ELY Redacted 2009R-03949 5/26/2009 JAT Redacted 2009R-03 955 5/26/2009 ELY Redacted 2009R-03957 5/26/2009 ELY Redacted 2009R-03959 5/26/2009 ELY Redacted 2009R-03968 5/26/2009 ELY Redacted 2009R-03975 5/26/2009 SMM Redacted 2009R-03978 5/27/2009 MMV Redacted 2009R-03 983 512 712 00 9 MMV Redacted 2009R-04017 5/28/2009 JAT Redacted 2009R-04037 5/28/2009 ELY Redacted 2009R-04047 5/28/2009 JAT Redacted 2009R-04057 5/29/2009 SLF Redacted 2009R-04072 5/29/2009 SMM Redacted 2009R-04074 5/2912009 MMV Redacted 2009R-04085 6/1/2009 MMV Redacted 2009R-043 05 6/1/2009 ELY Redacted 2009R-04 108 6/1/2009 ALW Redacted 2009R-04 1 12 6/1/2009 JAT Redacted 2009R-04 1 15 6/1/2009 MMV Redacted 2009R-04122 6/1/2009 SLF Redacted 2009R-04 144 6/2/2009 MMV Redacted 2009R-04148 6/2/2009 SMM Redacted 2009R-01149 61212009 MMV Redacted 200913-04 171 61312009 JAT Redacted 2009R-042 12 61412009 SLF Redacted 2009R-04236 6/5/2009 SMM Redacted 2009R-04269 6/5/2009 SLF Redacted 2009R-04270 6/812009 MMV Redacted 2009R-04282 6/8/2009 MMV Redacted 2009R-04285 61812009 SLF Redacted 2009R-04288 6/8/2009 ELY Redacted 2009R-04290 6/8/2009 MMV Redacted 2009R-04298 6/8/2009 ALW Redacted 2009R-04320 6/8/2009 SMM Redacted 2009R-04326 6/8/2009 SLF Redacted 2009R-0433 1 6/9/2009 MMV Redacted 2009R-04334 6/9/2009 ELY Redacted 2009R-0433 5 6/9/2009 MMV Redacted 2009R-04343 6/9/2009 SLF Redacted 2009R-04346 6/9/2009 MMV Redacted 2009R-0435 1 6/9/2009 ALW Redacted 2009R-04353 6/9/2009 CAP Redacted 2009R-04366 6/9/2009 ALW Redacted Data Request 33 Attachment Verizon West Virginia Inc. January I,2009 through June 15, 2009 ComplaintNumber Loggedln ComplaintType CustRep Complainant 2009R-043 83 6110/2009 SMM Redacted 2009R-04387 611 012009 MMV Redacted 2009R-04397 611 012009 ALW Redacted 2009R-04400 611 012009 MMV Redacted 2009R-04409 611 012009 MMV Redacted 2009R-044 13 611 112009 ALW Redacted 2009R-044 18 611 112009 ELY Redacted 2009R-0442 1 611 112009 MMV Redacted 2009R-04429 611 112009 MMV Redacted 2009R-04430 611 112009 SMM Redacted 2009R-0443 1 611 112009 ALW Redacted 2009R-04458 611 212009 JAT Redacted 2009R-04459 6/12/2009 MMV Redacted 2009R-04470 6/12/2009 MMV Redacted 2009R-04479 611 212009 ALW Redacted 2009R-04499 6/12/2009 CAP Redacted 2009R-04509 611 512009 JAT Redacted 2009R-045 17 611 512009 ALW Redacted 2009R-0453 1 611 512009 MMV Redacted 2009R-04533 6/15/2009 CAP Redacted 2009R-04545 611 512009 CAP Redacted 2009R-00535 1/6/2009 11-B-5 SLF Redacted 2009R-0 1324 2/5/2009 11-B-5 CAP Redacted 2009R-0 1502 2/13/2009 11-B-5 JAT Redacted 2009R-01569 2/17/2009 11-B-5 JAT Redacted 2009R-0 1801 2/24/2009 11-B-5 JAT Redacted 2009R-01974 31412009 11-B-5 SLF Redacted 200913-02 13 1 311 012009 11-B-5 JAT Redacted 2009R-0233 1 3/18/2009 11-B-5 JAT Redacted 2009R-025 15 312512009 11-B-5 SLF Redacted 2009R-026 10 3/30/2009 11-B-5 SMM Redacted 2009R-02661 313 112009 IT-B-5 JAT Redacted 2009R-02982 4/14/2009 11-B-5 SLF Redacted 2009R-03420 5/1/2009 11-B-5 ELY Redacted 2009R-03577 5/7/2009 11-B-5 SLF Redacted 2009R-03729 5/13/2009 11-B-5 JAT Redacted 2009R-03878 511 912009 11-B-5 SLF Redacted 2009R-04253 6/5/2009 11-B-5 MMV Redacted 2009R-04299 6/8/2009 11-B-5 MMV Redacted 200913-044 19 611 112009 11-B-5 JAT Redacted 2009R-00965 1/21/2009 11-C-1 JAT Redacted 2009R-0 1 179 1/3012009 11-c-1 MMV Redacted 2009R-02 143 311 112009 11-C-1 SLF Redacted 2009R-03962 5/26/2009 11-C-1 SMM Redacted 2009R-04 161 6/3/2009 11-C-1 MMV Redacted Data Request 33 Attachment Verizon West Virginia Inc. January I,2009 through June 15, 2009 ComplaintNumber Loggedln ComplaintType CustRep Complainant 2009R-04534 611512009 11-c-1 MMV Redacted 2009R-00926 ll2012009 1142-2 ELY Redacted 2009R-01233 21212009 11-c-2 JAT Redacted 2009R-0 1445 211 1I2009 11-c-2 CAP Redacted 2009R-02550 312612009 11-c-2 CAP Redacted 2009R-03476 5/4/2009 11-c-2 ELY Redacted 2009R-0365 1 511 112009 11-c-2 SLF Redacted 2009R-03666 511 112009 1142-2 SLF Redacted 2009R-044 15 611 1I2009 11-c-2 ELY Redacted 2009R-00445 11212009 11-C-3 ELY Redacted 2009R-00476 11512009 11-C-3 ALW Redacted 2009R-00670 11912009 11-C-3 ALW Redacted 2009R-00785 1I1 412009 11-C-3 ELY Redacted 2009R-0083 1 1l15l2009 11-C-3 CAP Redacted 2009R-00990 112212009 11-C-3 SMM Redacted 2009R-0 1085 112612009 11-C-3 SMM Redacted 2009R-0 1545 211 712009 11-C-3 SMM Redacted 2009R-0 1599 211 712009 11-C-3 ELY Redacted 2009R-0 1675 211 912009 11-C-3 SMM Redacted 2009R-0 1741 212312009 11-C-3 CJN Redacted 2009R-01835 212512009 11-C-3 CAP Redacted 2009R-01895 3/2/2009 11-C-3 ALW Redacted 2009R-0 1943 31312009 TI-C-3 CAP Redacted 2009R-0 1964 3/4/2009 11-C-3 ALW Redacted 2009R-02024 3/5/2009 11-C-3 ELY Redacted 2009R-02044 31612009 11-C-3 ELY Redacted 2009R-02146 311 112009 11-C-3 SLF Redacted 2009R-02 149 311 112009 11-C-3 ELY Redacted 2009R-02 192 311212009 11-C-3 CAP Redacted 2009R-02225 311312009 11-C-3 ELY Redacted 2009R-02275 311 712009 11-C-3 SMM Redacted 2009R-02337 3118/2009 11-C-3 CAP Redacted 2009R-02378 311 912009 11-C-3 CAP Redacted 2009R-02394 312012009 11-C-3 SMM Redacted 2009R-02496 312512009 11-C-3 ELY Redacted 2009R-02569 312712009 11-C-3 ELY Redacted 2009R-027 1 1 41112009 11-C-3 ELY Redacted 2009R-02715 411 I2009 11-C-3 CAP Redacted 2009R-02789 41612009 1142-3 ELY Redacted 200913-02896 41912009 11-C-3 ALW Redacted 2009R-02940 411312009 11-C-3 SMM Redacted 2009R-02990 411512009 11-C-3 ALW Redacted 2009R-0299 1 411 512009 11-C-3 SLF Redacted 2009R-030 16 411 612009 11-C-3 ALW Redacted 2009R-03200 412312009 11-C-3 CAP Redacted Data Request 33 Attachment Verizon West Virginia Inc. January 1,2009 through June 15, 2009 ComplaintNumber Loggedln ComplaintType CustRep Complainant 2009R-033 10 4/28/2009 11-C-3 CAP Redacted 2009R-03574 5/7/2009 11-C-3 SLF Redacted 2009R-03680 5/12/2009 11-C-3 SLF Redacted 2009R-0390 1 5/21/2009 11-C-3 SLF Redacted 2009R-03974 5/26/2009 11-C-3 JAT Redacted 2009R-04005 5/27/2009 11-C-3 JAT Redacted 2009R-04061 5/29/2009 11-C-3 SMM Redacted 2009R-04069 5/29/2009 11-C-3 JAT Redacted 2009R-04 159 6/2/2009 1142-3 CAP Redacted 2009R-04276 6/8/2009 11-C-3 MMV Redacted 2009R-044 14 611 1/2009 11-C-3 JAT Redacted 2009R-045 1 1 611 512009 11-C-3 ELY Redacted 200913-04521 6/15/2009 11-C-3 ELY Redacted 2009R-006 10 1/8/2009 11-C-4 JAT Redacted 2009R-00930 1/20/2009 11-C-4 MMV Redacted 2009R-00959 1/21/2009 11-c-4 ELY Redacted 200913-00972 1/21/2009 11-C-4 CAP Redacted 2009R-01091 1/26/2009 11-C-4 SMM Redacted 2009R-0 1338 2/6/2009 11-C-4 JAT Redacted 2009R-0 1465 2/12/2009 11-C-4 ELY Redacted 2009R-0 1607 211 812009 11-C-4 ALW Redacted 2009R-0 1644 211 812009 11-C-4 JAT Redacted 2009R-0 1784 2/24/2009 11-C-4 ALW Redacted 2009R-0 1 822 2/25/2009 11-C-4 SLF Redacted 2009R-0 1984 3/4/2009 11-C-4 CAP Redacted 2009R-0 1991 3/4/2009 11-C-4 SLF Redacted 2009R-02047 3/6/2009 11-C-4 ALW Redacted 2009R-02067 3/9/2009 11-C-4 ALW Redacted 2009R-02 1 16 3/10/2009 11-C-4 ELY Redacted 2009R-02 148 311 112009 11-C-4 SLF Redacted 2009R-02267 311 612009 11-'2-4 ELY Redacted 2009R-02413 3/23/2009 11-C-4 ELY Redacted 2009R-02440 3/23/2009 11-C-4 ELY Redacted 2009R-02526 3/26/2009 11-C-4 ELY Redacted 2009R-02838 4/1/2009 11-C-4 ELY Redacted 2009R-02900 4/9/2009 11-C-4 SLF Redacted 2009R-02947 4/13/2009 11-C-4 ALW Redacted 2009R-03019 4/16/2009 11-C-4 SLF Redacted 2009R-03026 411 612009 11-C-4 SLF Redacted 2009R-032 1 1 4/23/2009 11-C-4 SLF Redacted 2009R-03241 4/27/2009 11-C-4 ALW Redacted 2009R-03313 4/28/2009 11-C-4 MMV Redacted 2009R-03523 5/5/2009 11-C-4 ELY Redacted 2009R-03690 5/12/2009 11-C-4 ELY Redacted 2009R-03739 5/14/2009 11-C-4 MMV Redacted Data Request 33 Attachment Verizon West Virginia Inc. January 1, 2009 through June 15, 2009 ComplaintNumber Loggedln ComplaintType CustRep Complainant 2009R-03835 511 812009 11-'2-4 SLF Redacted 2009R-03887 5/20/2009 11-C-4 JAT Redacted 2009R-04128 6/2/2009 11-C-4 MMV Redacted 2009R-04 135 6/2/2009 11-C-4 MMV Redacted 2009R-04301 6/8/2009 114-4 ALW Redacted 2009R-0449 1 6/12/2009 11-C-4 ALW Redacted 200913-00407 1/2/2009 SMM Redacted 2009R-004 13 1/2/2009 SLF Redacted 2009R-00427 1/2/2009 ELY Redacted 2009R-00429 1/2/2009 CAP Redacted 2009R-00442 1/2/2009 ELY Redacted 2009R-0045 1 1/5/2009 ELY Redacted 2009R-00460 1/5/2009 JAT Redacted 2009R-00477 1/5/2009 ELY Redacted 2009R-00479 1/5/2009 SMM Redacted 2009R-0048 1 1/5/2009 JAT Redacted 2009R-00482 1I512009 SMM Redacted 2009R-00493 1/5/2009 ALW Redacted 2009R-00498 1/6/2009 ELY Redacted 2009R-005 10 1/6/2009 SLF Redacted 2009R-005 12 1/6/2009 ALW Redacted 2009R-00517 1/6/2009 ALW Redacted 2009R-005 19 1/6/2009 SMM Redacted 2009R-00526 1/6/2009 ALW Redacted 2009R-00540 1/6/2009 SLF Redacted 2009R-00544 1/6/2009 ALW Redacted 2009R-00549 1/7/2009 SMM Redacted 200913-00577 1/7/2009 ALW Redacted 2009R-00588 1/7/2009 ALW Redacted 2009R-00589 11712009 ELY Redacted 2009R-00594 11712009 CAP Redacted 2009R-00595 1/8/2009 SMM Redacted 2009R-00598 lIS/2009 SLF Redacted 2009R-00599 1/8/2009 JAT Redacted 2009R-00600 1/8/2009 ALW Redacted 2009R-00602 1/8/2009 ELY Redacted 2009R-00624 1I812009 SLF Redacted 2009R-00630 1/8/2009 SLF Redacted 2009R-0063 1 1/8/2009 CAP Redacted 2009R-00640 1/9/2009 ALW Redacted 2009R-00644 1/9/2009 CAP Redacted 2009R-00646 1/9/2009 SMM Redacted 2009R-00648 1/9/2009 ELY Redacted 2009R-0065 1 1I912009 JAT Redacted 2009R-00654 1/9/2009 SLF Redacted Data Request 33 Attachment Verizon West Virginia Inc. January 1,2009 through June 15,2009 ComplaintNumber Loggedln ComplaintType CustRep Complainant 2009R-00658 1/9/2009 ELY Redacted 2009R-00672 1I912009 JAT Redacted 2009R-00674 1/9/2009 SLF Redacted 2009R-00675 1/9/2009 ALW Redacted 2009R-00684 1/9/2009 JAT Redacted 2009R-00686 1/9/2009 CAP Redacted 2009R-00695 111 212009 MMV Redacted 2009R-00708 1/12/2009 SMM Redacted 2009R-00709 1/12/2009 JAT Redacted 2009R-007 13 1/12/2009 SLF Redacted 2009R-007 16 1/12/2009 JAT Redacted 2009R-00733 111 2/2009 CAP Redacted 200913-00863 1/16/2009 MMV Redacted 2009R-00875 1/16/2009 ALW Redacted 2009R-00900 1/2012009 ALW Redacted 2009R-00914 1/20/2009 SMM Redacted 2009R-009 16 1/20/2009 ALW Redacted 2009R-00922 112012009 ALW Redacted 2009R-00927 1/20/2009 SMM Redacted 2009R-00936 1/20/2009 SMM Redacted 2009R-00938 1/21/2009 ALW Redacted 2009R-00963 1/21/2009 JAT Redacted 2009R-00988 1/22/2009 SMM Redacted 2009R-0 10 10 1I2212009 SLF Redacted 2009R-0 11 14 1/28/2009 SMM Redacted 2009R-0 11 16 1/28/2009 SMM Redacted 2009R-0 1132 1/29/2009 ALW Redacted 2009R-0 1163 1/29/2009 JAT Redacted 2009R-0 1 166 113 0/2009 SLF Redacted 2009R-0 1 170 1/30/2009 ELY Redacted 2009R-0 12 11 21212 009 SMM Redacted 2009R-0 1227 2/2/2009 MMV Redacted 2009R-0 1238 2/3/2009 SMM Redacted 2009R-0 1239 213 12 0 09 ALW Redacted 2009R-0 1241 2/3/2009 ALW Redacted 2009R-01247 2/3/2009 ALW Redacted 2009R-0 252 2/3/2009 SMM Redacted 2009R-0 260 2/3/2009 JAT Redacted 2009R-0 265 2/3/2009 MMV Redacted 2009R-0 278 2/4/2009 ELY Redacted 2009R-0 288 21412009 MMV Redacted 2009R-0 3 10 2/5/2009 CAP Redacted 2009R-0 32 1 2/5/2009 SLF Redacted 2009R-01326 2/5/2009 ELY Redacted 2009R-0 1327 2/5/2009 SMM Redacted Data Request 33 Attachment Verizon West Virginia Inc. January I,2009 through June 15, 2009 ComplaintNumber Loggedln ComplaintType CustRep Complainant 2009R-01336 2/6/2009 JAT Redacted 2009R-0 1342 2/6/2009 SMM Redacted 2009R-0 1345 21612009 SMM Redacted 2009R-0 1346 21612009 ELY Redacted 2009R-0 1356 2/6/2009 ELY Redacted 2009R-01371 2/9/2009 SMM Redacted 2009R-0 1395 2/9/2009 JAT Redacted 2009R-01398 211012009 MMV Redacted 2009R-0 1430 211 112009 SMM Redacted 2009R-0 1453 211 112009 SLF Redacted 2009R-0 1459 211 112009 SMM Redacted 2009R-0 1460 2/12/2009 MMV Redacted 2009R-0 1462 211212009 ELY Redacted 2009R-0 1463 211 212009 SMM Redacted 2009R-0 1466 211 212009 SMM Redacted 2009R-0 1470 211 212009 SLF Redacted 2009R-01472 21 1212009 JAT Redacted 2009R-01480 211 212009 ELY Redacted 2009R-0 1486 211212009 JAT Redacted 2009R-01492 211312009 ALW Redacted 2009R-01493 2113/2009 ALW Redacted 2009R-01495 2113l2009 ELY Redacted 2009R-01507 211312009 SMM Redacted 2009R-0 1523 211 712009 MMV Redacted 2009R-0 1528 2/17/2009 SMM Redacted 2009R-0 1529 2/1712009 ELY Redacted 2009R-0 1530 211 712009 JAT Redacted 2009R-0 1531 211 712009 SMM Redacted 2009R-01534 211 712009 SMM Redacted 2009R-0 1541 211 712009 ALW Redacted 2009R-0 1543 211 712009 ALW Redacted 2009R-0 1548 21 1712009 JAT Redacted 2009R-01552 211 712009 SMM Redacted 2009R-0 1553 211 712009 SLF Redacted 2009R-0 1562 211712009 ALW Redacted 2009R-0 1564 211 712009 MMV Redacted 2009R-0 1566 211712009 SMM Redacted 2009R-0 1567 211 712009 ELY Redacted 2009R-0 1570 211 712009 ELY Redacted 2009R-01576 211 712009 SMM Redacted 2009R-0 1585 211 712009 CAP Redacted 2009R-0 1601 211 812009 MMV Redacted 2009R-01605 211 812009 JAT Redacted 2009R-0 1608 211 812009 ALW Redacted 2009R-0 16 1 1 211 812009 JAT Redacted . .. Data Request 33 Attachment Verizon West Virginia Inc. January I,2009 through June 15, 2009 ComplaintNumber Loggedln ComplaintType CustRep Complainant 2009R-0 1620 211 812009 JAT Redacted 2009R-0 1633 211 812009 SLF Redacted 2009R-0 1634 211 812009 SLF Redacted 2009R-01637 211 812009 JAT Redacted 2009R-0 1642 211 812009 CAP Redacted 2009R-0 1648 211 812009 CAP Redacted 2009R-0 1656 211912009 JAT Redacted 2009R-0 166 1 211 912009 ALW Redacted 2009R-0 1662 211912009 MMV Redacted 2009R-01665 21 1912009 MMV Redacted 2009R-01674 211 912009 SLF Redacted 2009R-0 1680 21 1912009 SLF Redacted 2009R-01683 212012009 ALW Redacted 2009R-0 17 1 1 212012009 CAP Redacted 2009R-0 17 13 212012009 ELY Redacted 2009R-01716 2t2312009 JAT Redacted 2009R-0 17 1 8 212312009 ALW Redacted 2009R-0 17 19 212312009 ELY Redacted 2009R-01720 212312009 MMV Redacted 2009R-0 722 212312009 MMV Redacted 2009R-0 723 212 312 00 9 ELY Redacted 2009R-0 727 212 312 00 9 ALW Redacted 2009R-0 730 2/23 I2009 SLF Redacted 2009R-0 73 5 212312009 ELY Redacted 2009R-0 743 212312009 JAT Redacted 2009R-0 744 212312009 JAT Redacted 2009R-0 1745 212312009 SMM Redacted 2009R-0 1747 212312009 JAT Redacted 2009R-0 1758 212312009 ALW Redacted 2009R-0 1766 212312009 JAT Redacted 2009R-0 1772 212412009 SMM Redacted 2009R-0 1775 212412009 SMM Redacted 2009R-0 1776 212412009 SLF Redacted 2009R-0 1778 212412009 ALW Redacted 2009R-01783 212412009 ALW Redacted 2009R-01788 212412009 SMM Redacted 2009R-01789 212412009 CAP Redacted 2009R-0 1796 212412009 SMM Redacted 2009R-01797 212412009 MMV Redacted 2009R-0 1809 212512009 SMM Redacted 2009R-0 18 1 1 212512009 SLF Redacted 2009R-0 1 8 13 212512009 SLF Redacted 2009R-0 18 14 212 512 009 ALW Redacted 2009R-0 1826 212512009 CAP Redacted 2009R-0 1827 212512009 ELY Redacted Data Request 33 Attachment Verizon West Virginia Inc. January I,2009 through June 15, 2009 ComplaintNumber Loggedln Complaintiype CustRep Complainant 2009R-01829 212 512 00 9 SLF Redacted 2009R-0 1836 212612009 JAT Redacted 2009R-01837 212612009 SLF Redacted 2009R-0 1844 212612009 MMV Redacted 2009R-01852 212612009 SLF Redacted 2009R-01871 212712009 ALW Redacted 2009R-0 1876 31212009 MMV Redacted 2009R-0 1878 31212009 ELY Redacted 2009R-01892 31212009 SMM Redacted 2009R-0 1902 31212009 ALW Redacted 2009R-0 1907 31212009 SLF Redacted 2009R-0 1947 31312009 ALW Redacted 2009R-0 1960 3/4/2009 ELY Redacted 2009R-0 1986 31412009 ALW Redacted 2009R-01987 31412009 ELY Redacted 2009R-0 1997 31512009 ALW Redacted 2009R-0 1999 3I512009 JAT Redacted 2009R-02004 31512009 SMM Redacted 2009R-020 1 1 31512009 JAT Redacted 2009R-02027 31512009 SLF Redacted 200913-0205 1 31612009 ALW Redacted 2009R-02058 31612009 MMV Redacted 2009R-02068 31912009 JAT Redacted 2009R-02071 31912009 ALW Redacted 2009R-02097 31912009 SLF Redacted 2009R-02 1 14 311 012009 ELY Redacted 2009R-02 189 311212009 ALW Redacted 2009R-02254 311612009 JAT Redacted 2009R-02257 311612009 JAT Redacted 2009R-02258 311 612009 SMM Redacted 2009R-02259 311612009 JAT Redacted 2009R-02284 311712009 SMM Redacted 2009R-02290 311712009 ALW Red acte d 2009R-02302 311 712009 SMM Redacted 200913-02332 311 812009 ALW Redacted 2009R-023 33 311 812009 JAT Redacted 2009R-02336 311 812009 SLF Redacted 2009R-02346 311 912009 MMV Redacted 200913-0235 1 311912009 JAT Redacted 2009R-0236 1 311912009 SMM Redacted 2009R-02370 311 912009 JAT Redacted 2009R-02372 311912009 SMM Redacted 2009R-02392 312012009 SMM Redacted 2009R-02405 312012009 SMM Redacted 2009R-02409 312312009 JAT Redacted . Data Request 33 Attachment Verizon West Virginia Inc. January 1,2009 through June 15,2009 ComplaintNumber Loggedln ComplaintType CustRep Complainant 2009R-0242 1 312312009 SMM Redacted 2009R-02462 312412009 ELY Redacted 2009R-02468 312412009 MMV Redacted 2009R-02484 312412009 ALW Redacted 2009R-02489 312412009 JAT Redacted 2009R-02497 312512009 SLF Redacted 2009R-02500 312512009 JAT Redacted 2009R-02506 312512009 ALW Redacted 2009R-02508 312512009 JAT Redacted 2009R-02528 312612009 SMM Redacted 2009R-02549 312612009 SMM Redacted 2009R-02553 312612009 CAP Redacted 2009R-02559 3/21/2009 ELY Redacted 2009R-02563 312712009 SMM Redacted 2009R-02570 3I2 712 00 9 MMV Redacted 2009R-02572 312712009 JAT Redacted 2009R-02575 312712009 ALW Redacted 2009R-02593 312712009 JAT Redacted 2009R-02597 313012009 ALW Redacted 2009R-02611 313012009 ALW Redacted 2009R-02626 313012009 ALW Redacted 2009R-02658 313 112009 ELY Redacted 2009R-02680 41112009 MMV Redacted 2009R-02683 41112009 SMM Redacted 2009R-02684 41112009 SMM Redacted 2009R-02687 41112009 JAT Redacted 2009R-02690 411 I2009 ALW Redacted 2009R-02699 4/1/2009 ALW Redacted 2009R-027 19 4/2/2009 JAT Redacted 2009R-02728 41212009 ALW Redacted 2009R-02740 41212009 JAT Redacted 2009R-02758 413 I2009 MMV Redacted 2009R-02785 41612009 JAT Redacted 2009R-02790 41612009 JAT Redacted 2009R-02797 41612009 JAT Redacted 2009R-02807 41612009 ELY Redacted 2009R-02850 41812009 SMM Redacted 2009R-02851 4/8/2009 ALW Redacted 2009R-02858 41812009 JAT Redacted 2009R-02865 41812009 ALW Redacted 2009R-02869 4/8/2009 ELY Redacted 2009R-02873 4/9/2009 SMM Redacted 2009R-02874 41912009 ALW Redacted 2009R-02882 41912009 JAT Redacted 2009R-02904 41912009 SLF Redacted Data Request 33 Attachment Verizon West Virginia Inc. January 1, 2009 through June 15, 2009 ComplaintNumber Loggedln ComplaintType CustRep Complainant 2009R-02906 MMV Redacted 2009R-02908 SLF Redacted 2009R-029 16 JAT Redacted 2009R-02923 ALW Redacted 2009R-02934 ALW Redacted 2009R-02942 CAP Redacted 2009R-02950 MMV Redacted 2009R-02953 SMM Redacted 2009R-02968 ALW Redacted 2009R-02983 ALW Redacted 2009R-02992 SMM Redacted 2009R-02996 JAT Redacted 2009R-03002 SLF Redacted 2009R-03023 SMM Redacted 2009R-03029 CAP Redacted 2009R-03045 CAP Redacted 2009R-03090 ELY Redacted 2009R-03093 MMV Redacted 2009R-03 102 ELY Redacted 2009R-03 108 SMM Redacted 2009R-03 125 ALW Redacted 2009R-03 132 ALW Redacted 2009R-03 156 ELY Redacted 2009R-03 190 ELY Redacted 2009R-03204 SMM Redacted 2009R-03208 ELY Redacted 2009R-032 10 SMM Redacted 2009R-032 14 JAT Redacted 2009R-03237 ELY Redacted 2009R-03242 MMV Redacted 2009R-03245 ALW Redacted 2009R-03260 MMV Redacted 200913-03279 SMM Redacted 2009R-03296 ELY Redacted 2009R-03304 SMM Redacted 2009R-03307 JAT Redacted 2009R-03326 ELY Redacted 2009R-033 34 ALW Redacted 2009R-033 55 SMM Redacted 2009R-03356 ALW Redacted 2009R-03360 JAT Redacted 2009R-0337 1 SMM Redacted 2009R-03372 ALW Redacted 2009R-03375 ALW Redacted 2009R-033 82 SMM Redacted Data Request 33 Attachment Verizon West Virginia Inc. January 1,2009 through June 15, 2009 ComplaintNumber Loggedln ComplaintType CustRep Complainant 2009R-03 3 86 51112009 SMM Redacted 2009R-03 3 95 5/1/2009 ELY Redacted 2009R-03400 51 112009 ELY Redacted 2009R-03407 51 1I2009 ALW Redacted 2009R-03424 51112009 JAT Red acte d 2009R-03460 5/4/2009 CAP Redacted 2009R-03482 5/5/2009 SLF Redacted 2009R-03487 5/5/2009 SMM Redacted 2009R-03489 5/5/2009 ELY Redacted 2009R-03490 5/5/2009 ALW Redacted 2009R-03499 5/5/2009 JAT Redacted 2009R-03500 5/5/2009 JAT Redacted 2009R-03503 5/5/2009 SLF Redacted 2009R-03504 5/5/2009 ALW Redacted 2009R-03508 5/5/2009 MMV Redacted 2009R-035 10 51512009 ALW Redacted 2009R-03513 5/5/2009 SMM Redacted 2009R-03 5 30 5/6/2009 ALW Redacted 2009R-03 533 5/6/2009 SMM Redacted 2009R-03 53 7 5/6/2009 JAT Redacted 2009R-03548 5/6/2009 SLF Redacted 2009R-03 559 5/7/2009 MMV Redacted 2009R-03561 51712009 SMM Redacted 2009R-03565 51712009 SLF Redacted 2009R-03568 51712009 JAT Redacted 2009R-0357 1 51712009 SLF Redacted 2009R-03582 5/7/2009 MMV Redacted 2009R-03 5 86 5/7/2009 ALW Redacted 200913-03593 5/7/2009 SMM Redacted 2009R-03598 5/8/2009 JAT Redacted 2009R-03600 5/8/2009 SLF Redacted 2009R-03601 5/8/2009 JAT Redacted 2009R-03606 5/8/2009 CAP Redacted 2009R-03609 5/8/2009 ALW Redacted 2009R-03626 5/8/2009 SLF Redacted 2009R-03643 511 112009 ELY Redacted 2009R-03646 511 112009 MMV Redacted 2009R-03647 511 112009 MMV Redacted 2009R-03649 511 112009 ALW Redacted 2009R-03659 511 112009 ELY Redacted 2009R-03667 511 112009 ELY Redacted 2009R-03671 5/12/2009 MMV Redacted 2009R-03676 5/12/2009 ALW Redacted 2009R-03677 5/12/2009 ELY Redacted 2009R-03683 511212009 ALW Redacted Data Request 33 Attachment Verizon West Virginia Inc. January I,2009 through June 15, 2009 ComplaintNumber Loggedln ComplaintType CustRep Complainant 2009R-03687 JAT Redacted 2009R-03696 CJN Redacted 2009R-03709 ELY Redacted 2009R-03719 MMV Redacted 2009R-03726 SLF Redacted 2009R-03732 JAT Redacted 2009R-03752 ALW Redacted 2009R-03755 SMM Redacted 2009R-03798 JAT Redacted 2009R-03823 SMM Redacted 2009R-03834 SMM Redacted 2009R-03842 ELY Redacted 2009R-03894 MMV Redacted 2009R-03907 JAT Redacted 2009R-03930 SMM Redacted 2009R-03 942 JAT Redacted 2009R-03964 SMM Redacted 2009R-03 9 88 SMM Redacted 2009R-03993 SLF Redacted 2009R-040 10 ELY Redacted 2009R-04014 MMV Redacted 2009R-040 16 SLF Redacted 2009R-04038 ELY Redacted 2009R-04040 SLF Redacted 2009R-04042 ELY Redacted 2009R-0405 1 MMV Redacted 2009R-04052 JAT Redacted 2009R-04054 SLF Redacted 2009R-04064 JAT Redacted 2009R-04086 MMV Redacted 2009R-04087 ALW Redacted 2009R-04089 ALW Redacted 2009R-04090 JAT Redacted 2009R-04091 MMV Redacted 2009R-04093 ALW Redacted 2009R-04 1 13 ALW Redacted 200913-04 1 18 SMM Redacted 2009R-04 120 SMM Redacted 2009R-04125 MMV Redacted 2009R-04130 SMM Redacted 2009R-04 137 CJN Redacted 2009R-04 140 ALW Redacted 2009R-04 142 ALW Redacted 2009R-04 143 JAT Redacted 2009R-04145 JAT Redacted Data Request 33 Attachment Verizon West Virginia Inc. January 1,2009 through June 15, 2009 ComplaintNum ber Loggedln ComplaintType CustRep Complainant 2009R-04 15 1 6/2/2009 JAT Redacted 2009R-04153 6/2/2009 ALW Redacted 2009R-04 154 6/2/2009 JAT Redacted 2009R-04158 6/2/2009 CAP Redacted 2009R-04 162 6/3/2009 SMM Redacted 2009R-04 169 6/3/2009 SLF Redacted 2009R-04 184 6/3/2009 ELY Redacted 2009R-04 199 6/4/2009 ALW Redacted 2009R-04202 6/4/2009 ELY Redacted 2009R-04207 6/4/2009 ALW Redacted 2009R-04208 6/4/2009 ALW Redacted 2009R-04209 6/4/2009 ALW Redacted 2009R-042 13 6/4/2009 MMV Redacted 2009R-0423 8 6/5/2009 SMM Redacted 2009R-0423 9 6/5/2009 ELY Redacted 2009R-04249 6/5/2009 CAP Redacted 2009R-04254 6/5/2009 JAT Redacted 2009R-04257 6/5/2009 JAT Redacted 2009R-04260 6/5/2009 ALW Redacted 2009R-04264 6/5/2009 ELY Redacted 2009R-04265 615 12 0 09 MMV Redacted 2009R-0427 1 6/8/2009 ALW Redacted 2009R-04273 6/8/2009 MMV Redacted 2009R-04274 6/8/2009 ALW Redacted 2009R-04275 6/8/2009 MMV Redacted 2009R-04277 6/8/2009 JAT Redacted 2009R-04278 6/8/2009 ELY Redacted 2009R-04279 6/8/2009 ALW Redacted 2009R-04280 6/8/2009 MMV Redacted 2009R-04283 6/8/2009 ELY Redacted 2009R-04286 6/8/2009 SLF Redacted 2009R-04289 6/8/2009 CAP Redacted 2009R-04295 6/8/2009 ALW Redacted 2009R-04297 6/8/2009 ALW Redacted 200913-04303 6/8/2009 MMV Redacted 2009R-04304 6/8/2009 MMV Redacted 2009R-043 16 6/8/2009 ALW Redacted 2009R-043 17 6/8/2009 SLF Redacted 2009R-043 18 6/8/2009 ALW Redacted 2009R-043 19 6/8/2009 ALW Redacted 2009R-04332 6/9/2009 JAT Redacted 2009R-04352 6/9/2009 ELY Redacted 2009R-04357 6/9/2009 MMV Redacted 2009R-04359 6/9/2009 ALW Redacted 2009R-0436 1 6/9/2009 ELY Redacted Data Request 33 Attachment Verizon West Virginia Inc. January I,2009 through June 15, 2009 ComplaintNumber Loggedln ComplaintType CustRep Complainant 2009R-04363 61912009 ALW Redacted 2009R-04367 6/9/2009 CAP Redacted 2009R-04373 611 012009 MMV Redacted 2009R-04377 6/ lOl2009 SLF Redacted 2009R-04386 611 012009 SLF Redacted 2009R-043 90 611 012009 JAT Redacted 2009R-04391 611 012009 SLF Redacted 200913-04402 6/1012009 SLF Redacted 2009R-04405 611 012009 MMV Redacted 2009R-044 16 611 112009 SLF Redacted 2009R-044 17 611 112009 ALW Redacted 2009R-04420 611 112009 MMV Redacted 2009R-04424 611 112009 MMV Redacted 2009R-04426 611 112009 ELY Redacted 2009R-04448 611 112009 JAT Redacted 2009R-04450 611 112009 CAP Redacted 2009R-04453 611 112009 CAP Redacted 2009R-04456 611212009 ALW Redacted 2009R-0445 7 61 1212009 ALW Redacted 2009R-0446 1 6/12/2009 JAT Redacted 2009R-04462 6/12/2009 SLF Redacted 2009R-04465 6/12/2009 JAT Redacted 2009R-04467 611 212009 JAT Redacted 2009R-04471 611212009 JAT Redacted 2009R-04472 611212009 SMM Redacted 2009R-04473 6/12/2009 MMV Redacted 2009R-04474 611212009 JAT Redacted 2009R-0448 1 611 212009 JAT Redacted 2009R-044 8 5 611212009 SLF Redacted 2009R-04486 6/12/2009 CAP Redacted 2009R-04487 611 212009 SLF Redacted 2009R-04488 611212009 SLF Redacted 2009R-04493 6/12/2009 CAP Redacted 2009R-04497 611212009 SLF Redacted 2009R-04504 611 512009 JAT Redacted 2009R-045 10 611 512009 ALW Redacted 2009R-045 13 611 512009 MMV Redacted 2009’13-04529 611 512009 MMV Redacted 2009R-04530 61 15 12009 JAT Redacted 2009R-00687 1/9/2009 CAP Redacted 2009R-01120 112812009 ALW Redacted 2009R-02323 311 812009 JAT Redacted 2009R-02325 3/18/2009 ALW Redacted 2009R-03 134 412 112009 ALW Redacted 2009R-03 3 57 413012009 ALW Redacted Data Request 3 3 Attachment Verizon West Virginia Inc, January 1, 2009 through June 15, 2009 ComplaintNum ber Loggedln CustRep Compiaii iant 2009R-03448 5/4/2009 ALW Redacted 2009R-035 84 51712009 SLF Redacted 2009R-036 18 51812009 ALW Redacted 2009R-03619 5/8/2009 SLF Redacted 2009R-04379 611 012009 SLF Redacted CITIZENS TELECOMMUNICATIONS COMPANY OF WEST VIRGINIA DBA FRONTIER COMMUNICATIONS OF WEST VIRGINIA AND VERIZON WEST VIRGINIA, INC. WEST VIRGINIA PSC CASE NO. 09-0871-T-PC SECOND REQUEST FOR INFORMATION - CWA Name of Person Preparing Response: Billy Jack Gregg Date of Response: August 12,2009 Request 34 Re: p. 26, lines 20-22. Please provide any documents, data, reports, or other information relied upon by Mr. Gregg in support of his reference to the “current quality of service problems experienced by Verizon customers.” Response 34 See response to data request 33, and the record in PSC Case No. 08-0761-T-P. Verizon’s number of complaints (requests for assistance or RFA’s) received by the Commission are a matter of public record, and speak for themselves. CITIZENS TELECOMMUNICATIONS COMPANY OF WEST VIRGINIA DBA FRONTIER COMMUNICATIONS OF WEST VIRGINIA AND VERIZON WEST VIRGINIA, INC. WEST VIRGINIA PSC CASE NO. 09-0871-T-PC SECOND REQUEST FOR INFORMATION - CWA Name of Person Preparing Response: Billy Jack Gregg Date of Response: August 12,2009 Request 36 Is Mr. Gregg familiar with the condition of Verizon West Virginia’s physical plant? If so: (a) How would he characterize its condition? (b) Does he have a view regarding the additional investments and/or expenses (over and above what Verizon West Virginia spent in 2008 or plans to spend in 2009) that will be required to bring it up to - or maintain it at - a condition that Mr. Gregg considers acceptable? If so, what is that level of expenditure? Response 36 (a) Verizon’s physical network in West Virginia encompasses thousands of square miles of territory and thousands of linear miles of cable and wire facilities. While Mr. Gregg is familiar with Verizon’s physical network in West Virginia, he obviously has not inspected all of the network. Generally speaking, there are parts of the network that contain new, state of the art facilities and are well maintained, and parts of the network that are older. (b) It is Mr. Gregg’s understanding that as part of the Retail Service Quality Plan agreed to by Verizon in WV PSC Case No. 08-0761-T-GI, Verizon has committed to make $1 1 million in additional investment in its West Virginia network, over and above normal construction expenditures. See, Verizon West Virginia Inc., WV PSC Case No. 09-0761 -T-GI, “Commission Order” (Dec. 19,2009), p. 3. CITIZENS TELECOMMUNICATIONS COMPANY OF WEST VIRGINIA DBA FRONTIER COMMUNICATIONS OF WEST VIRGINIA AND VERIZON WEST VIRGINIA, INC. WEST VIRGINIA PSC CASE NO. 09-0871-T-PC SECOND REQUEST FOR INFORMATION - CWA Name of Person Preparing Response: Billy Jack Gregg Date of Response: August 12,2009 Request 3 7 Please provide a copy of Mr. Gregg’s testimony (including the transcript of any cross examination) in each of the following cases: a. Bell Atlantic-West Virginia, Case No. 97- 1461 -T-PC b. Citizens Telecommunications, Case No. 99- 1530-T-PC c. Verizon-West Virginia, Case No. 00-0705-T-PC d. Verizon- West Virginia, Case No. 04-0292-T-PC e. Verizon-West Virginia, Case No. 06-048 1-T-PC Response 37 Copies of prepared testimony in the referenced cases will be produced. (With respect to proprietary/confidential version of testimony, the proprietary/confidential version will be produced subject to an appropriate protective agreement.) Mr. Gregg does not have copies of the transcripts of hearings in the referenced cases. These may be requested from the archives of the West Virginia Public Service Commission. VERIFICATION STATE OF WEST VIRGINIA, COUNTY OF KANAWHA, to-wit: The Affiant, Billy Jack Gregg, states that the facts and opinions contained in the foregoing Responses are true and correct, except so far as they are stated upon information, and that, so far as they are stated upon information, he believes them to be true and correct. Taken, sworn to and subscribed before me this 12wday of August, 2009, CERTIFICATE OF SERVICE I, Joseph J. Starsick, do hereby certify that service of the foregoing Responses to the Second Set of Interrogatories, Data Requests or Requests For Information Directed to Citizens Telecommunication Company of Wet Virginia, DBA Frontier Communications of West Virginia and Verizon West Virginia, Inc., by the Communications Workers of America, AFL-CIO has been made upon the Plaintiff by First-class U.S. Mail postage prepaid this 12‘” day of August, 2009 to: 1200 Greenbrier Street Pat Pearlman Charleston, West Virginia 253 11 Consumer Advocate Division Fibernet, LLC State Of West Virginia Public Service Commission Jeffrey Ray 700 Union Building 113 Platinum Drive, Suite B 723 Kanawha Boulevard, East Bridgeport, West Virginia 26330 Charleston, West Virginia 25301 Citynet Consumer Advocate Division Amanda M. Ream Vincent Trivelli Lewis, Glasser, Casey & Rollins, PLLC The Law Office Of Vincent Trivelli, BB&T Square, Suite 700 PLLC 300 Summers Street 178 Chancery Row Charleston, West Virginia 25301 Morgantown, West Virginia 26505 Comcast Phone of West Virginia, LLC Communications of America AFL-CIO Robert R. Rodecker BB&T Square Lisa Wansley-Layne, Esquire 300 Summers Street, Suite 1230 Public Service Commission Of WV P.O. Box 3713 P.O. Box 812 Charleston, West Virginia 25337 Charleston, West Virginia 25323 USCOC of Cumberland Inc. staff Hardy Cellular James Kelsh Robert R: Rodecker Law Office Of James Kelsh BB&T Square 300 Summers St., Ste. 1230 300 Summers Street, Suite 1230 P.O. Box 3713 P.O. Box 3713 Charleston, West Virginia 25337-3713 Charleston, West Virginia 25337 NTELOS of West Virginia, Inc. Level 3 Communications, LLC Steven Hamula, Esquire Fibernet, LLC