201 Brooks Street, P.O. Box 812 Phone: (304) 340-0300 Charleston, West Virginia 25323 Fax: (304) 340-0325

June 17,2019

Electronic Service Only

Joshua A. Johnson, Esq. Counsel, Frontier West Virginia Inc. 1500 MacCorkle Ave., S.E. Charleston, WV 25396

RE: Case No. 19-0502-T-PC Citizens Telecommunications of West Virginia dba Frontier Communications of West Virginia and Frontier West Virginia Inc.

Dear Mr. Johnson:

The Staff Memorandum issued today was served via email on the above-listed parties. Any responses must be submitted to the Executive Secretary’s Office in writing within 10 days of this date, unless directed otherwise. You will not receive a copy of the Staff Memorandum by regular mail.

Your failure to respond in writing to the utility’s answer, Staffs recommendations, or other documents may result in a decision in your case based on your original filing and the other documents in the case file, without further hearing or notice.

When you provide an email address, you will automatically receive electronic docket notifications as documents are filed in this proceeding. The email notifications allow recipients to view a document within an hour from the time the filing is processed.

Please note - the Public Service Commission does not accept electronic filings.

Sincerely,

IF/tg Ingrid Fdell, Director Enc. - Memo Executive Secretary Division FINAL JOINT STAFF MEMORANDUM

TO: INGRID FERRELL DATE: June 17,2019 Executive Secretary

FROM: LISA L. WANSLEY Staff Attorney

RE: 19-0502-T-PC CITIZENS TELECOMMUNICATIONS OF WEST VIRGINIA INC. DBA FRONTIER COMMUNICATIONS OF WEST VIRGINIA AND FRONTIER WEST VIRGINIA INC.

Legal Staff recommends that the Commission enter an order approving the interconnection agreement between Frontier and AT&T mobility.

On May 16, 2019, a petition for approval of the interconnection agreement between Frontier and AT&T Mobility was filed pursuant to W.Va. Code 524-2-12.

Attached for filing find Staffs Final Recommendation, drafted by Steve Wilson, Utilities Analyst, Utilities Division. Mr. Wilson reviewed the filing and recommends approval of the interconnection agreement between Frontier and AT&T mobility.

Legal Staff emphasizes that 47 U.S.C. 252(e)(4) sets forth a ninety (90) day time period for processing the subject action. Therefore, an order must be entered in this matter by August 14, 20 19.

Legal Staff notes that W.Va.Code 524-2-12 allows granting of such a petition if “the terms and conditions thereof are reasonable and that neither party thereto is given an undue advantage over the other, and do not adversely affect the public in this State.” It appears that the petition meets the conditions of W.Va Code 524-2-12, due to the fact that the proposed transaction will not disrupt service and has no adverse impact on customers. Legal Staff recommends that the interconnection agreement be approved without approving the terms and conditions and without notice and hearing.

LL W/dt Attachment

LJA

S:\-Staff-Files\LWansley\WORD\2019\19-0502-T-PC Citizens dba Frontier\Final2,doc PUBLIC SERVICE COMMISSION OF WEST VIRGINIA UTILITIES DIVISION FINAL MEMORANDUM

FROM: Steve Wilson, Utilities Analyst Utilities Division

DATE: June 14,2019

SUBJECT: CASE NO. 19-0502-T-PC CITIZENS TELECOMMUNICATIONS OF WEST VIRGINIA, INC., dba FRONTIER COMMUNICATIONS OF WEST VIRGINIA AND FRONTIER WEST VIRGINIA INC. Joint petition for approval of an interconnection agreement with AT&T Mobility. Statutory Deadline: (90 Days) August 14,2019

On May 16, 20 19, Citizens Telecommunications of West Virginia and Frontier West Virginia Inc. (collectively “Frontier”) submitted for approval with the Public Service Commission of West Virginia (“Commission”) an interconnection agreement (the “Agreement”) between New Cingular Wireless PSC, LLC, and its Commercial Mobile Radio Service (“CMRS”) operating affiliates, doing business as AT&T Mobility (“AT&T Mobility”), and Frontier. The filing is made pursuant to Sections 25 1 and 252 of the Telecommunications Act of 1996 and West Virginia Code Section 24-2-12. There is a statutory deadline of 90 days for processing the Agreement.

Staff filed an Initial Memorandum on June 11, 2019, informing the Commission that the Frontier attorney and Staff had been in discussion and Frontier was to supply additional information which would aid in processing the request.

On June 12,2019, Frontier filed an amended application for the approval of the interconnection agreement. The interconnection agreement attached to the original filing remains the same. The amended filing identifies prior interconnection agreements that are amended, extended, or restated by the proposed interconnection agreement and provides clarity to the previous and current activity.

In Case No. 02-008 1-T-PC, the Commission approved an interconnection agreement and Amendment No. 1 between Verizon West Virginia (now Frontier) and AT&T Wireless Services, Inc. (now New Cingular Wireless PCS, LLC). The date of the Final Commission Order is April 5, 2002. On March 14, 2003, the Commission approved Amendment No. 2 to the agreement between the same parties. Case No. 19-0502-T-PC June 14,2019 Page 2 of 3

The agreement in Case No. 02-008 1-T-PC provided for the interconnection of the two companies’ networks and provided AT&T with access to Verizon’s West Virginia E-9- 1- 1 network systems and databases enabling AT&T to provide E-9- 1- 1 services to its end user customers. The amendment’s (Amendment No. 1) key provision provided for the reciprocal compensation for terminating local traffic at per-minute-of- use rates that depend upon whether traffic is terminated on the Verizon WV network, or on the AT&T network.

The Staff Attorney stated in the Final Joint Staff Memorandum that the initial term of the proposed interconnection agreement expired on December 3 1, 200 1. However, the agreement provides that, upon expiration of the initial term or thereafter, the agreement continues until terminated.

Amendment No. 2 provided for terms and conditions for reciprocal compensation in compliance with the Federal Communication Commission’s (“FCC”) Order on Remand and Report and Order.

On November 28,2012, the Commission approved Amendment No. 3 to the interconnection agreement, now formally stated as being between Frontier West Virginia Inc. and New Cingular Wireless PCS, LLC. This third amendment incorporated recent changes to intrastate intercarrier compensation required by the FCC.

In Case No. 04-0698-C-PC, the Cornmission approved an interconnection agreement for CMRS between Citizens Telecommunications Company of West Virginia, dba Frontier Communications Company of West Virginia and AT&T Wireless Services, Inc. The agreement set forth the terms, conditions, and prices under which Citizens and AT&T will offer and provide network interconnection and reciprocal call transport and termination to each other in Citizens’ local serving areas within AT&T Wireless’ major trading area in West Virginia. The Final Order was entered on June 1 1,2004.

The proposed Agreement, upon approval by the Commission, hlly and completely replaces and cancels both agreements and amendments in these aforementioned cases, Case No. 02-008 1-T-PC and Case No. 04-0698-C-PC. The Agreement sets forth the terms, conditions, and prices under which Frontier and AT&T Mobility will offer and provide network interconnection, reciprocal call transport and termination, and ancillary network services to each other within the Local Access and Transport Area in which they both operate in West Virginia. Case No. 19-0502-T-PC June 14,2019 Page 3 of 3

Term and termination information are located on the second page of the Agreement. The Agreement shall continue in force unless cancelled or terminated as provided in the Agreement. Either AT&T Mobility or Frontier may terminate the Agreement by providing written notice of termination at least ninety (90) days in advance of the date of termination.

The Agreement does not discriminate against any other telecommunications carrier, as required by Section 252(e)(2)(a)(i). The interconnection arrangements contained in the Agreement are available to any other similarly situated telecommunications carrier under §252(i) of the 1996 Act.

Staff has reviewed this filing and concluded that the Agreement does not discriminate against any other telecommunications carrier not a party to the Agreement. Staff believes that the Agreement is consistent with the public interest, convenience, and necessity by furthering competition in the West Virginia marketplace.

Staff recommends approval of Case No. 19-0502-T-PC.

sw:sw