Before the Public Utilities Commission of the State of California

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Application of Frontier Communications Corporation, Frontier California Inc. (U1002C), Citizens Telecommunications Company of California Inc. (U1024C),

Frontier Communications of the Southwest Application 20-05-010 Inc. (U1026C), Frontier Communications (Filed May 22, 2020) Online and Long Distance Inc. (U7167C), Frontier Communications of America, Inc. (U5429C) for Determination that Corporate Restructuring is Exempt from or Compliant with Public Utilities Code Section 854.

RURAL COUNTY REPRESENTATIVES OF CALIFORNIA COMMENTS ON DECISION APPROVING CORPORATE RESTRUCTURING WITH CONDITIONS

Tracy Rhine Senior Legislative Affairs Advocate Rural County Representatives of California 1215 K Street, Suite 1650, Sacramento, CA 95814 Tel: (916) 447-4806 March 4, 2021 Email: [email protected] TABLE OF CONTENTS

SUMMARY OF RECOMMENDATIONS…………….…………………………… 2

DISCUSSION………………………………………………………………………. 3

CONCLUSION………………………………………….…………………………... 5

SUMMARY OF RECOMMENDATIONS

Per Rule 14.3 (b) of the Rules of Practice and Procedure, and as discussed below, RCRC respectfully requests that Item 19 in the Settlement Agreement reflected as Attachment 1 in the Proposed Decision be modified as follows:

Frontier commits to FTTP buildout to at least 350,000 rural locations, as defined by the United States Census Bureau or other appropriate definition as determined by the Commission, within six years from approval of the Settlement with the following milestones: 100,000 locations by December 31, 2022; 250,000 locations by December 31, 2024; and 350,000 locations by December 31, 2026.14 Frontier agrees that no less than 150,000 of the total 350,000 locations will be locations Frontier identified in its Modernization Report projections as having an Internal Rate of Return (“IRR”) of less than 20%. The 350,000 FTTP locations will not be considered to fulfill the Verizon Agreement Broadband Commitments that remain outstanding as of Frontier’s emergence from Chapter 11 and buildout obligations under any RDOF awards. However, for clarity, to the extent Frontier upgrades locations with FTTP after December 31, 2020 to which it had deployed broadband service of 6/1 Mbps and 10/1 Mbps under its Verizon Agreement Broadband Commitments on or before December 31, 2020, those locations can be considered in fulfilling this 350,000 FTTP commitment.

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Application of Frontier Communications Corporation, Frontier California Inc. (U1002C), Citizens Telecommunications Company of California Inc. (U1024C),

RURAL COUNTY REPRESENTATIVES OF CALIFORNIA COMMENTS ON DECISION APPROVING CORPORATE RESTRUCTURING WITH CONDITIONS

I. Introduction

In accordance with Rule 14.3 of the California Public Utilities Commission (“Commission”) Rules of Practice and Procedure (“Rules”), the Rural County Representatives of California (RCRC) respectfully submits comments on Decision Approving Corporate Restructuring with Conditions issued by Administrative Law Judge (ALJ) Peter Wercinski on February 12, 2021 in Application 20-05-010 (Proposed Decision).

II. Discussion RCRC is an association of thirty-seven rural California counties, and its Board of Directors is comprised of an elected supervisor from each of those member counties. RCRC was granted party status on September 30, 2020 via a written ruling by ALJ Wercinski.

Many RCRC member counties, such as the residents of County of Colusa, have current Frontier customers, including the County of Colusa itself that utilized various Frontier telephone and data services to support the core operation of delivering vital county services. Colusa County in particular has reported experiencing various outages relating to its Primary Rate Interface (PRI) voice lines, long distance calling, and wide area network. According to county representatives, on a number of occasions, staff were unable to place outgoing calls or long-distance calls due to an issue in the central office or long-distance circuit path. More alarming is the report of a recent equipment failure in the local central office that lasted a day-and-a-half, which resulted in a disabling of incoming calls as well as disruptions in the city police department and the Colusa County District Attorney circuit. It is imperative that Frontier improve reliability to critical services such as these, especially in rural fire-prone regions of the state that depend on telecommunications to secure safe evacuation of its residents. Therefore, RCRC is supportive of the Settlement Agreement entered into as of December 24, 2020, by and between Frontier Communications Corporation, Frontier California Inc., Citizens Telecommunications Company of California Inc., Frontier Communications of the Southwest Inc., Frontier Communications Online and Long Distance Inc., and Frontier Communications of America, Inc., Public Advocates Office at the California Public Utilities Commission, The Utility Reform Network and the Communications Workers of America, District 9 (Settle Agreement), reflected in the Proposed Decision as Attachment 1, particularly provisions requiring upgraded services to underserved areas. RCRC supports the terms of paragraph 19 of the Settlement Agreement, as outline on Page 91 of the Proposed Decision, that requires Frontier to build out Fiber To The Premises (FTTP) to at least 350,000 locations within six years, with additional conditions. Paragraph 19 of the Agreement should prioritize deployment of FTTH to rural areas, defined by the United States Census Bureau, or other appropriate definition as determined by the Commission. It is crucial that the deployment of broadband services in rural areas be prioritized within the efforts required by the Settlement Agreement. Additionally, RCRC also supports the comments and recommendations submitted by former Governor Edmund G. Brown, Jr. on the need for targeted investments in broadband services, especially in low-income and rural regions of the state.

III. Conclusion The Rural County Representatives of California respectfully requests that the Commission’s accept these comments for filing and incorporate the suggestions made therein.

Respectfully submitted,

/s/ Tracy Rhine Tracy Rhine Senior Legislative Affairs Advocate Rural County Representatives of California Tel: (916) 447-4806 E-mail: [email protected]

March 4, 2021