FRIEND, HUDAK & HARRIS, LLP

Transcription

1 FRIEND, HUDAK & HARRIS, LLP ATTORNEYS AT LAW SUITE 1450 THREE RAVINIA DRIVE ATLANTA, GEORGIA VIA ELECTRONIC FILING Dr. Burl W. Haar Executive Secretary Minnesota Public Utilities Commission 121 Seventh Place East, Suite 350 St. Paul, Minnesota (770) FACSIMILE (770) WEB May 14, 2012 Writer's Re: In the Matter of the Annual Update of the 911 Plan of CC VIII, LLC, Docket P5615/ Dear Dr. Haar: Enclosed is the annual update to the 911 Plan of CC VIII, LLC ( CC VIII ). CC VIII submits this filing following consultations with the Minnesota Department of Public Safety (the Department of Public Safety ) and the Metropolitan Emergency Services Board (the Metro Board ). Also enclosed is an Affidavit of Service. Copies of the filing have been served concurrently on the Office of the Attorney General-Residential Utilities Division, the Minnesota Department of Commerce, the Department of Public Safety, the Metro Board, and persons identified in the 911 Plan who may be interested in this proceeding. If you have any questions regarding the foregoing, please contact the undersigned. Sincerely, KBW/jh Enc. cc: CC VIII, LLC (with enclosure) Charles A. Hudak, Esq. (without enclosure) /s/ Kennard B. Woods Attorney for CC VIII, LLC

2 COMPANY NAME: CC VIII, LLC NENA ID: CHTR Company is Doing Business As: Company is Formerly Known As: X Enter Company name and NENA ID in the header above CC VIII, LLC Original Reseller/UNE 911 Plan Update to existing 911 Plan Docket No. P5615/EP (approved December 3, 2009) (for all counties listed below, except for Meeker County, Dodge County and Houston County); Amended 911 Plan, Docket No. 5615/EP (approved July 20, 2010) (filed to include Meeker County); Docket No. P5615/EP (approved March 18, 2011) (for all counties listed below, except for Dodge County and Houston County); Docket No. P5615/EP (approval pending) (for all counties listed below, except Dodge County and Houston County); Docket No. P5615/EP (approval pending) (filed to add Monticello exchange in Wright County) Company Address: Powerscourt Drive St. Louis, MO Web Site Address: Company Contacts For: Name Telephone Number Address Primary Contact Mary Carol Hasty Marycarol.hasty@chartercom.com 911 Plans Mary Carol Hasty Marycarol.hasty@chartercom.com 911 Fee Submission Tim Fewell Tim.Fewell@chartercom.com Company 24/7 Telephone Number for Trouble Reporting: Company NENA Company ID (if applicable): N/A Certificate of Authority Type: PUC Docket Number Date Approved by PUC - Resale - Facilities Based P-3058/M P-5615/M P-5615/M P-5615/M P-5615/M August 17, 2009 August 17, 2009 June 2, 2010 March 21, 2012 Approval Pending Note: If facilities based authority, check one: X Company will NOT own/operate transmission & switching facilities, but will utilize an underlying carrier s services. Company WILL own/operate its own transmission & switching facilities. (Company must file a Facilities Based 911 Plan.) Company s Underlying Carriers: (Necessary certifications are included herein as Attachment A) Carrier Name NENA Co. ID 24/7 Call Trace /Trbl Telephone Number Address Charter Fiberlink CHTR Rptg No / Contact Person Mary Carol Hasty Page 1 of 21 Marycarol.hasty@chartercom.com

3 COMPANY NAME: CC VIII, LLC NENA ID: CHTR Company Service Area: List the counties and associated underlying carriers within which the Company has a certificate of authority to sell local service (e.g. Hennepin County CenturyLink, Citizens) County Underlying Carrier Underlying Carrier Underlying Carrier Carver Dakota Hennepin Ramsey St. Louis South Benton Sherburne Stearns Wright Freeborn Goodhue Mower Olmsted Rice and Steele Winona Aitkin Crow Wing Morrison Chippewa Kandiyohi Swift Blue Earth Page 2 of 21

4 COMPANY NAME: CC VIII, LLC NENA ID: CHTR Nicollet Becker Douglas Otter Tail Pope Todd Wadena Wilkin Lyon Hubbard Meeker Dodge Houston Page 3 of 21

5 COMPANY NAME: CC VIII, LLC NENA ID: CHTR Escalation Contacts: List the escalation contacts established by the Company that should be used in the event of a situation requiring resolution at higher levels. Escalation Level Name Telephone # address Supervisory NOC Supervisors Cell nocsup@chartercom.com Management NOC Mgr Gil Sisson Ofc Cell gil.sisson@chartercom.com Sr Manager NOC Brian Riebow Ofc Cell brian.riebow@chartercom.com Director, Engineering John Owens Ofc Cell john.owens@chartercom.com Officer VP Network Ops Matthew Cuneio Ofc matthew.cuneio@chartercom.com 911-Related Service to Other Entities 911 related services include acting as an underlying carrier for a reseller, providing a gateway from VoIP or non-traditional telecom services to traditional trunking, acting as a connection point to 911 selective routers, conducting data base services for the other entity or collection and remittance of 911 fees. Check one of the following: The Company has contracted to provide access to the 911 network or 911 related services on behalf of another entity. Details of the services provided and contact information are contained below. Page 4 of 21

6 COMPANY NAME: CC VIII, LLC NENA ID: CHTR X The Company has not contracted to provide access to the 911 network or 911 related services on behalf of another entity. If the Company has contracted to provide access to the 911 network or 911 related services to another entity, it is described below. (If more than one describe all) Entity Name Fixed location VoIP or conventional service provider Check all that are if applicable Nomadic VoIP Other non-traditional telecom services Specify: Contact Name Contact Phone Number Contact Address Check the appropriate box(es) and provide a detailed narrative description of the 911 services provided by the company to this entity including underlying carrier, gateway and meet-point locations, and ALI shell record maintenance, if applicable: Acting as an underlying carrier for a reseller entity Providing telephone numbers Providing a gateway from VoIP to traditional circuits Acting as a connection point to 911 selective routers Conducting data base services for the other entity Collection and remittance of 911 fees Page 5 of 21

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8 COMPANY NAME: CC VIII, LLC NENA ID: CHTR ATTACHMENT A (One Attachment A is required for EACH of the Company s Underlying Carriers) _ CC VIII, LLC _(hereinafter referred to as the Company ) has a use and sharing arrangement with (hereinafter referred to as the underlying carrier ); i.e., CC VIII, LLC will obtain any needed 911 services through, its affiliate. The Underlying Carrier certifies to the following: A. In accordance with Minnesota Rules Chapter 7580 (former Rules Chapter 1215), the underlying carrier has a contract with the State of Minnesota, and: (Check one or both as applicable to this plan) X X Metropolitan Emergency Services Board County/Counties (through the Department of Public Safety) B. The underlying carrier has integrated into the 911 selective router network as specified in the applicable MESB/County/Counties 911 Plans to achieve selective router-based choking. C. The underlying carrier will provide a p.01 grade of service on the 911 network. D. The underlying carrier will provide adequate diversity for the portion of the 911 network to be used by the Company s subscribers and provide default routing capability consistent with the MESB/County/Counties 911 Plans. E. The underlying carrier has cooperated with the 911 PSAP(s) and the 911 system integrator in developing a 911 contingency plan, and has in place their own contingency plan for events affecting Company subscribers access to 911 service. F. The underlying carrier has in place a 911 Contingency Plan that addresses, at a minimum, the conditions of: 1) ANI Failure, 2) No Record Found Condition, 3) SR/ALI Database Failure, 4) Circuit Failure, 5) 911 Selective router Failure, 6) Switching Center Isolation, 7) Conditional Routing Procedures to Reroute 911 Calls, 8) Emergency Contacts and Escalation Procedures. The underlying carrier will provide documentation of the 911 Contingency plan to the applicable MESB/County/Counties upon request. G. The underlying carrier maintains circuit routing profiles for 911 and expedite 911 service restoration. H. The underlying carrier has entered into non-disclosure agreements with the ALI database Provider. I. The underlying carrier has made arrangements to provide updates for the Company s subscribers to the ALI database provider as specified in the applicable MESB/County/Counties 911 Plan and in a format required by the ALI database provider. J. The underlying carrier will ensure that the underlying carrier s identity is shown on the ALI record and displayed at the PSAP as required by the applicable MESB/County/Counties 911 Plan. Specify the entity who registered the ID with NENA (National Emergency Number Association) The following NENA company ID will display at the PSAP CHTR Page 7 of 21

9 COMPANY NAME: CC VIII, LLC NENA ID: CHTR K. The underlying carrier will handle emergency contacts and escalation for the Company. The Underlying Carrier and the Company jointly certify to the following: L. The contract between the Company and the underlying carrier is consistent with the applicable MESB/County/Counties 911 Plan requirements. M. The Company will share customer information and data consistent with current national standards for sharing information related to providing emergency telephone service. N. The Company will provide the operator-assisted emergency calls, including calls from speech impaired, hearing-impaired, or non-english speaking customers. Operator services will be provided through/by, kgb (formerly Excell Services, the underlying carrier s operator services provider. O. The Company has provided its customers a 24/7 trouble reporting number for use in reporting problems with telephone service, including access to 911. The Company and underlying carrier have established 24/7 trouble coordination procedures. P. The Company has provided to the underlying carrier s operator services provider, the 24 hour emergency numbers for the PSAPs in the Company s service area. Q. The Company {specify: Company or underlying carrier} will collect and submit the 9-1-1/TAP/TAM fees from the Company s customers using the current fee submission form and information sheet, available from the State of Minnesota 911 Program website: R. If doing business in the Twin Cities metropolitan area: 1. The Company and the underlying carrier have reviewed and will comply with the current Metropolitan Emergency Services Board s Network Service Standards and Database Service Standards. The current standards, available from the MESB s website, are incorporated herein as an attachment to this 911 plan. 2. The Company and the underlying carrier have established procedures to ensure that data for the Company s subscribers will be exchanged, shared, processed, and managed in a manner consistent with the MESB Consolidated Metropolitan Area 911 Plan and Database Service Standards. 3. The Company is responsible for originating the subscriber records and for the daily transmission of the subscriber records to the underlying carrier. The underlying carrier is responsible for submitting the updates to the 911 database. 4. The underlying carrier will input the Company s daily service order updates using current national data quality standards. 5. The Company will be responsible for address pre-validation (prior to transmission of subscriber information to the 911 database) using the current ALI Data Provider MSAG. 6. The Company and the underlying carrier will be responsible for error correction, and source records will be updated by the underlying carrier in order to maintain consistency between the Company s source subscriber records and 911 data records. 7. The underlying carrier will comply with current NENA standards for Local Number Portability and will designate a 911/LNP data contact that will coordinate all 911/LNP activities between the underlying carrier and other carriers to ensure timely and accurate 911 database information for the Company s subscribers. 8. The underlying carrier has provided their operator services provider the current Community-to-PSAP table for use in determining the correct PSAP to reroute emergency calls to based on the community from which the caller is calling. If doing business outside of the Twin Cities metropolitan area: Page 8 of 21

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11 COMPANY NAME: CC VIII, LLC NENA ID: CHTR Metropolitan Emergency Services Board Network Service Standards (Applicable to Anoka, Carver, Chisago, Dakota, Hennepin, Isanti, Ramsey, Scott, and Washington Counties) INITIAL VERSION 8/20/1996 FIRST REVISION 10/11/2000 SECOND REVISION 3/9/2005 ELEMENT OF SERVICE STANDARD OVERALL 1 System integration - There will be a system integrator for the 911 system designated by the county in their 911 plan. The system integrator will perform coordination and oversight functions for the entire 911 system as jointly defined with the county. ROUTING 2 Selective Routing calls will automatically be routed, as specified by the county plan, to the PSAP that provides dispatching services for the public safety agencies serving the area from which the 911 is placed. 3 Redundant routing equipment - There will be redundant routing equipment so that if one router malfunctions the other switching device will continue to route all calls that originate in the 911 system. 4 Default routing plan - The system shall be designed so that if the normal means of routing a call malfunctions, a default routing plan, as adopted by the county, will be used to route the call to an alternate location. 5 Routing of 911 calls from central offices - Trunk groups will be set up so that for every trunk group to the primary selective router, a corresponding trunk group is set up to the secondary selective router. If the SS7 system fails and the call cannot be routed to the selective routers, the call will be routed to re-order tone. 6 Routing 911 calls from wireless telephones - The network will be capable of selectively routing wireless 911 calls to the PSAP that serves the area from which the call was placed calls from PBX extensions - The network and ALI database will be capable of selectively routing 911 calls from PBX extensions to the appropriate PSAP and delivering the correct ANI and ALI of the extension which placed the 911 call. VOICE NETWORK 8 Call Setup time calls will be completed within 8 seconds after the caller dials the last digit, 1. 9 Tone signals to the caller - The tones heard by the caller will be the same as are used in the public switch telephone network call delivery - The 911 system will be designed with dedicated voice trunks on dedicated facilities that are not shared with any other telecommunications traffic. 11 Call hold - The 911 system shall be designed so that the call taker can place a 911 call on hold, answer another call, and then return to the first call. 12 Identify dedicated 911 facilities - All telephone equipment that is used exclusively for 911, or which is essential to the operation of the 911 system, shall be clearly labeled as a 911 component to ensure proper handling. 13 Network capacity - P.01 minimum grade of service such that not more than one call out of 100 incoming calls receive a busy signal on the first dialing attempt during a busy hour of an average week during the busy month. 14 Traffic studies - Traffic studies for the entire network will be conducted at least annually with reports given to the PSAPs and the county s 911 system coordinator. If p.01 service is not being met, the system integrator will recommend the required trunking quantities. Carriers will conduct traffic busy studies for their respective end office 911 voice trunks. The system integrator will conduct usage studies on the incoming voice trunks to the tandem as well as busy & usage studies on the tandem to PSAP voice trunks. 15 SS7 Network Standards - All carriers will review their SS7 network annually and document to the Board and to the State that their systems are compliant with the SS7 Network Standards contained in their 911 Agreement as a part of the annual diversity audit. 16 Central office isolation and alternate routing - Trunking will be arranged to minimize the likelihood of central office isolation due to cable cuts or other equipment failures. There will be an alternate means of transmitting a 911 call to a PSAP in the event of failures. 17 Diversity voice trunks will have interoffice, loop & carrier system diversity when such diversity can be achieved using existing facilities. Voice trunks will be divided as equally as possible across available carrier systems. SS7 A Page 10 of 21

12 COMPANY NAME: CC VIII, LLC NENA ID: CHTR links will have interoffice, loop & carrier system diversity. If no diversity, an alternate means of completing the call will be provided at the option of the county. Diversity will be maintained or upgraded to utilize the highest level of diversity Metropolitan Emergency Services Board Network Service Standards (continued): available in the network. 120 days notification will be given prior to major network changes. Carriers will conduct & document an annual audit to confirm optimum diversity. 18 Monitoring of equipment and voice trunks - Carriers will monitor network equipment, SS7 networks, and voice trunks used for 911. Monitoring will be conducted by the system integrator at the individual trunk level for 911 voice trunks of all carriers at the tandem switch. 19 Affects of host-remote central offices on the 911 call delivery system - Host-remote central office technology will not degrade 911 service or affect 911 in any way. There will be separate trunk groups out of the host for each remote. Where the umbilical is not diverse, an alternate means of completing the 911 call will be provided at the option of the county. 20 Immediate Ring Tone - If the carrier s switch is capable, immediate ring tone shall be presented to the caller. 21 Transferring 911 calls to another PSAP - A PSAP receiving a transfer from another connected PSAP will have the correct ANI & ALI. The first call taker will be able to remain connected as a third party to the call. When they go off-line, the caller will remain connected to the transfer location. REPAIR SERVICE 22 Trouble reporting - A 24 hour, 7 day a week trouble reporting repair center will be maintained by the system integrator and staffed by employees trained in 911 and knowledgeable in the county s 911 system. All carriers will be available 24 hours, 7 days a week to receive trouble reports from the system integrator. 23 Repair service performance standards - Repair service will begin within 2 hours of receipt of a report of a malfunction. Repair service includes testing & diagnostic service from a remote location, dispatch of or on-site visit(s) of personnel. Technicians will be dispatched without delay. Priority effort will be given to trouble conditions which, in the opinion of the PSAP manager, require immediate attention due to the severity of the service impact. 24 PSAP notification of network & ALI failures - Affected PSAPs will be notified by the system integrator within 15 minutes of telco identification of the failure. If the problem persists, the system integrator will provide hourly updates to the impacted PSAP(s). Monthly outage summary reports will be provided by the system integrator to the county s 911 system coordinator, including an analysis of outages not corrected within 1 hour. 25 Disaster recovery plan - The system integrator will design, implement and maintain a disaster recovery process for the 911 network and database systems. All other carriers will design, implement, and maintain disaster recovery plans for their portion of the network. CLECs will include Disaster Recovery Plans in their 911 Plans filed with the Minnesota Public Utilities Commission. ANI 26 ANI - The telephone number of the device used to place the 911 call will be displayed at the PSAP at the time the call is answered. This includes the capability to provide 10-digit call back number. ALI NETWORK 27 ALI delivery time ALI information will be delivered to the PSAP within 2 seconds. Depending upon the type of CPE, the first character of the ALI is delivered in less than 2 seconds after the call is received by the equipment, or after the call is answered by a call taker. 28 Redundant location information databases - Location information databases and related hardware will be redundant and configured so that failure of one unit will not cause a malfunction of the 911 location information system. 29 Diversity of the location information network - ALI links will have interoffice, loop & carrier system diversity when such diversity can be achieved using existing facilities. ALI links will be divided as equally as possible across available carrier systems. Diversity will be maintained or upgraded to utilize the highest level of diversity available in the network. 120 days notification will be given prior to major network changes. 911 Service Provider will conduct & document an annual audit to confirm optimum diversity. Page 11 of 21

13 COMPANY NAME: CC VIII, LLC NENA ID: CHTR Metropolitan Emergency Services Board 911 Data Base Service Standards (Applicable to Anoka, Carver, Chisago, Dakota, Hennepin, Isanti, Ramsey, Scott, and Washington Counties) INITIAL VERSION - 8/20/1996 Updated by the Metropolitan Emergency Services Board 6/15/2005 ELEMENT OF SERVICE STANDARD DATA BASE UPDATES 1 Delivery of service order updates to System Integrator - Data providers will deliver 911 service order updates to the system integrator within 1 business day of the close of service order activity. 2 Service order update processing to ALI database - The system integrator will process the service order updates received from data providers within 1 business day of receipt by electronic file transfer. MASTER STREET ADDRESS GUIDE 3 Master Street Address Guide (MSAG) copies - The system integrator will provide to the county and the data providers a copy of the MSAG at least 4 times a year in a mutually agreeable format according to a mutually agreeable schedule. 4 MSAG update turnaround time - The system integrator will process or refer MSAG updates within 1 business day of receipt, provided the update does not have discrepancies or would not result in errors. Special large volume changes will be separately negotiated between the 911 Coordinator and the system integrator. 5 MSAG update distribution to data providers - The system integrator will distribute completed MSAG updates to data providers within 1 business day of completion. 6 Use of MSAG updates Data providers will establish a documented process to receive and utilize daily MSAG updates distributed from the system integrator. ERROR CORRECTION 7 Error distribution to data providers - The system integrator will distribute errors from 911 update processing to the appropriate data provider via electronic method within 1 business day of detection. 8 Address error percentage No more than 10% of the service order updates of a data provider will err due to a mismatch of addresses to the Master Street Address Guide (MSAG). 9 Error retrieval by data providers - Data Providers will retrieve 911 error files each business day as distributed to them by the system integrator from 911 update processing. 10 Error correction or referral to the 911 Coordinator - Data providers will correct or appropriately refer to the 911 Coordinator errors from 911 database update processing within 2 business days of retrieval of the error file by the data provider. 11 Attempts to resolve address errors before referral to 911 Coordinator - Data providers will refer errors to the 911 Coordinator after use of data provider's resources and three attempts to reach the customer. 12 Identification of any records with specific addresses unknown - The system integrator will identify the records monthly on a mutually agreeable date. NO RECORD FOUNDS 13 No record found identification and distribution - No record found conditions will be identified by the system integrator through the ALI audit trail and distributed to the appropriate data provider within 3 business days. 14 No record found resolution from audit trail - No record found conditions will be resolved by data providers within 5 business days of notification by the system integrator of the no record found conditions. 15 No record found percentage - No more than.5% of the 911 calls will receive a no record found condition. Any data provider exceeding.5% no record found conditions for 6 months cumulative average shall submit a corrective action plan to the Metropolitan Emergency Services Board staff. 16 Analysis of no record founds for cause The system integrator and 911 coordinator will conduct an analysis at least quarterly of no record found conditions in order to determine causes and recommend corrective or preventative action. MISROUTED 911 CALLS 17 Misroute percentage No more than.1% of the 911 calls will be misrouted. 18 Analysis of misrouted 911 calls for cause - The system integrator and 911 coordinator will conduct an analysis at least quarterly of misrouted 911 calls in order to determine causes and recommend corrective or preventative action. Page 12 of 21

14 COMPANY NAME: CC VIII, LLC NENA ID: CHTR inquiry distribution to data providers inquiries that identify problems with a data provider's data will be distributed by the system integrator to the appropriate data provider within 1 business day of receipt inquiry turnaround time 911 inquiries will be resolved within 5 business days of receipt by the appropriate data provider. DATA BASE RECONCILIATION 21 Copies of data provider data from the ALI system Data providers will request and the system integrator will provide to each data provider on an annual basis a copy of the data provider's data residing on the ALI system to allow the data provider to validate the data. 22 Data validation - Data providers will schedule a date for their annual data validation by 6/30 of each calendar year. Data providers will validate the ALI data for their subscribers annually by 12/31 of each calendar year. AUDIT TRAIL 23 Audit Trail Reports - Audit trail reports will be provided by the system integrator to the 911 Coordinator monthly by the fifteenth business day of the month. Page 13 of 21

15 COMPANY NAME: CC VIII, LLC NENA ID: CHTR State of Minnesota Network Service Standards INITIAL VERSION 1/1/2010 The following standards apply to services in all Minnesota counties outside of the metro area. The standards for services in the Metropolitan 9 county area (Anoka, Carver, Chisago, Dakota, Hennepin, Isanti, Ramsey, Scott, and Washington) still apply and are also part of the Reseller 911 plan and the Addendum A of the Facilities-Based 911 plan. ELEMENT OF SERVICE STANDARD ROUTING 1 Selective Routing calls will automatically be routed, as specified by the county plan, to the PSAP that provides dispatching services for the public safety agencies serving the area from which the 911 is placed. 2 Redundant routing equipment - There will be redundant routing equipment so that if one router malfunctions the other switching device will continue to route all calls that originate in the 911 system. 3 Default routing plan - The system shall be designed so that if the normal means of routing a call malfunctions, a default routing plan, as adopted by the county, will be used to route the call to an alternate location. 4 Routing of 911 calls from central offices For counties connected to one selective router, a minimum of two trunks should be set up to the selective router. For counties connected to two selective routers, a minimum of one trunk should be set up to each selective router. Calls that fail to be routed to the selective router(s) should be routed to re-order tone. 5 Routing 911 calls from wireless telephones - The network will be capable of selectively routing wireless 911 calls to the PSAP that serves the area from which the call was placed calls from PBX extensions - The network and ALI database will be capable of selectively routing 911 calls from PBX extensions to the appropriate PSAP and delivering the correct ANI and ALI of the extension which placed the 911 call. VOICE NETWORK 7 Call Setup time calls will be completed within 8 seconds after the caller dials the last digit, 1. 8 Tone signals to the caller - The tones heard by the caller will be the same as are used in the public switch telephone network call delivery - The 911 system will be designed with dedicated voice trunks on dedicated facilities that are not shared with any other telecommunications traffic. 10 Call hold - The 911 system shall be designed so that the call taker can place a 911 call on hold, answer another call, and then return to the first call. 11 Identify dedicated 911 facilities - All telephone equipment that is used exclusively for 911, or which is essential to the operation of the 911 system, shall be clearly labeled as a 911 component to ensure proper handling. 12 Network capacity - P.01 minimum grade of service such that not more than one call out of 100 incoming calls receive a busy signal on the first dialing attempt during a busy hour of an average week during the busy month. 13 Traffic studies - Traffic studies for the entire network will be conducted at least annually with reports provided to the State 911 Program Manager and the PSAP coordinator as requested. If p.01 service is not being met, the 911 service provider will recommend the required trunking quantities. Carriers will conduct traffic busy studies for their respective end office 911 voice trunks. The 911 service provider will conduct usage studies on the incoming voice trunks to the tandem as well as busy & usage studies on the tandem to PSAP voice trunks. 14 Central office isolation and alternate routing - Trunking will be arranged to minimize the likelihood of central office isolation due to cable cuts or other equipment failures. There will be an alternate means of transmitting a 911 call to a PSAP in the event of failures. 15 Diversity voice trunks will have interoffice, loop & carrier system diversity when such diversity can be achieved using existing facilities. Voice trunks will be divided as equally as possible across available carrier systems. SS7 A links will have interoffice, loop & carrier system diversity. If no diversity, an alternate means of completing the call will be provided at the option of the county. Diversity will be maintained or upgraded to utilize the highest level of diversity available in the network. 120 days notification will be given prior to major network changes. Carriers will conduct & document an annual audit to confirm optimum diversity. 16 Monitoring of equipment and voice trunks - Carriers will monitor network equipment, networks, and voice trunks used for 911. Monitoring will be conducted by the 911 service provider at the individual trunk level for 911 voice trunks of all carriers at the tandem switch. Page 14 of 21

16 COMPANY NAME: CC VIII, LLC NENA ID: CHTR 17 Affects of host-remote central offices on the 911 call delivery system - Host-remote central office technology will not degrade 911 service or affect 911 in any way. Where the umbilical is not diverse, an alternate means of completing the 911 call will be provided at the option of the county. 18 Immediate Ring Tone - If the carrier s switch is capable, immediate ring tone shall be presented to the caller. 19 Transferring 911 calls to another PSAP - A PSAP receiving a transfer from another connected PSAP will have the correct ANI & ALI. The first call taker will be able to remain connected as a third party to the call. When they go off-line, the caller will remain connected to the transfer location. REPAIR SERVICE 20 Trouble reporting - A 24 hour, 7 day a week trouble reporting repair center will be maintained by the 911 service provider and staffed by employees trained in 911 and knowledgeable in the county s 911 system. All carriers will be available 24 hours, 7 days a week to receive trouble reports from the 911 service provider. 21 Repair service performance standards - Repair service will begin within 2 hours of receipt of a report of a malfunction. Repair service includes testing & diagnostic service from a remote location, dispatch of or on-site visit(s) of personnel. Technicians will be dispatched without delay. Priority effort will be given to trouble conditions which, in the opinion of the PSAP manager, require immediate attention due to the severity of the service impact. 22 PSAP notification of network & ALI failures - Affected PSAPs will be notified by the 911 service provider within 15 minutes of telco identification of the failure. If the problem persists, the 911 service provider will provide hourly updates to the impacted PSAP(s). Monthly outage summary reports will be provided by the 911 service provider to the PSAP coordinator, including an analysis of outages not corrected within 1 hour. 23 Disaster recovery plan The 911 service provider will design, implement and maintain a disaster recovery process for the 911 network and database systems. All other carriers will design, implement, and maintain disaster recovery plans for their portion of the network. CLECs will include Disaster Recovery Plans in their 911 Plans filed with the Minnesota Public Utilities Commission. ANI 24 ANI - The telephone number of the device used to place the 911 call will be displayed at the PSAP at the time the call is answered. This includes the capability to provide 10-digit call back number. ALI NETWORK 25 ALI delivery time ALI information will be delivered to the PSAP within 2 seconds. Depending upon the type of CPE, the first character of the ALI is delivered in less than 2 seconds after the call is received by the equipment, or after the call is answered by a call taker. 26 Redundant location information databases - Location information databases and related hardware will be redundant and configured so that failure of one unit will not cause a malfunction of the 911 location information system. 27 Diversity of the location information network - ALI links will have interoffice, loop & carrier system diversity when such diversity can be achieved using existing facilities. ALI links will be divided as equally as possible across available carrier systems. Diversity will be maintained or upgraded to utilize the highest level of diversity available in the network. 120 days notification will be given prior to major network changes. 911 Service Provider will conduct & document an annual audit to confirm optimum diversity. Page 15 of 21

17 COMPANY NAME: CC VIII, LLC NENA ID: CHTR State of Minnesota 911 Data Base Service Standards INITIAL VERSION 1/1/2010 The following standards apply to services in all Minnesota counties outside of the metro area. The standards for services in the Metropolitan 9 county area (Anoka, Carver, Chisago, Dakota, Hennepin, Isanti, Ramsey, Scott, and Washington) still apply and are also part of the Reseller 911 plan and the Addendum A of the Facilities-Based 911 plan. ELEMENT OF SERVICE STANDARD DATA BASE UPDATES 1 Delivery of service order updates to the 911 data base service provider - Data providers will deliver 911 service order updates to 911 data base service provider within 1 business day of the close of service order activity. 2 Service order update processing to ALI database - The 911 data base service provider will process the service order updates received from data providers within 1 business day of receipt by electronic file transfer. MASTER STREET ADDRESS GUIDE 3 Master Street Address Guide (MSAG) copies - The 911 data base service provider will provide to the PSAP and the data providers a copy of the MSAG at least 4 times a year in a mutually agreeable format according to a mutually agreeable schedule. 4 MSAG update turnaround time - The 911 data base service provider will process or refer MSAG updates within 1 business day of receipt, provided the update does not have discrepancies or would not result in errors. Special large volume changes will be separately negotiated between the PSAP MSAG Coordinator and the 911 data base service provider. 5 MSAG update distribution to data providers - The 911 data base service provider will distribute completed MSAG updates to data providers within 1 business day of completion. 6 Use of MSAG updates Data providers will establish a documented process to receive and utilize daily MSAG updates distributed from the 911 data base service provider. ERROR CORRECTION 7 Error distribution to data providers - The 911 data base service provider will distribute errors from 911 update processing to the appropriate data provider via electronic method within 1 business day of detection. 8 Address error percentage No more than 10% of the service order updates of a data provider will err due to a mismatch of addresses to the MSAG. 9 Error retrieval by data providers - Data Providers will retrieve 911 error files each business day as distributed to them by the 911 data base service provider from 911 update processing. 10 Error correction or referral to the PSAP MSAG Coordinator - Data providers will correct or appropriately refer to the PSAP MSAG Coordinator errors from 911 database update processing within 2 business days of retrieval of the error file by the data provider. 11 Attempts to resolve address errors before referral to PSAP MSAG Coordinator - Data providers will refer errors to the PSAP MSAG Coordinator after use of data provider's resources and three attempts to reach the customer. 12 Identification of any records with specific addresses unknown - The 911 data base service provider will identify the records monthly on a mutually agreeable date. NO RECORD FOUNDS 13 No record found identification and distribution - No record found conditions will be identified by the 911 data base service provider through the ALI audit trail and distributed to the appropriate data provider within 3 business days. 14 No record found resolution from audit trail - No record found conditions will be resolved by data providers within 5 business days of notification by the 911 data base service provider of the no record found conditions. 15 No record found percentage - No more than.5% of the 911 calls will receive a no record found condition. Any data provider exceeding.5% no record found conditions for 6 months cumulative average shall submit a corrective action plan to the State of Minnesota 911 Program office. 16 Analysis of no record founds for cause - The 911 data base service provider and PSAP MSAG coordinator will conduct an analysis at least quarterly of no record found conditions in order to determine causes and recommend corrective or preventative action. Page 16 of 21

18 COMPANY NAME: CC VIII, LLC NENA ID: CHTR MISROUTED 911 CALLS 17 Misroute percentage No more than.1% of the 911 calls will be misrouted. 18 Analysis of misrouted 911 calls for cause - The 911 data base service provider and PSAP MSAG coordinator will conduct an analysis at least quarterly of misrouted 911 calls in order to determine causes and recommend corrective or preventative action. 911 INQUIRIES inquiry distribution to data providers inquiries that identify problems with a data provider's data will be distributed by the 911 data base service provider to the appropriate data provider within 1 business day of receipt inquiry turnaround time 911 inquiries will be resolved within 5 business days of receipt by the appropriate data provider. DATA BASE RECONCILIATION 21 Copies of data provider data from the ALI system - Data providers will request and the 911 data base service provider will provide to each data provider on an annual basis a copy of the data provider's data residing on the ALI system to allow the data provider to validate the data. 22 Data validation - Data providers will schedule a date for their annual data validation by 6/30 of each calendar year. Data providers will validate the ALI data for their subscribers annually by 12/31 of each calendar year. AUDIT TRAIL 23 Audit Trail Reports - Audit trail reports will be provided by the 911 data base service provider to the PSAP MSAG Coordinator monthly by the fifteenth business day of the month. Page 17 of 21

19 COMPANY NAME: CC VIII, LLC NENA ID: CHTR AFFIDAVIT OF SERVICE I,, on the day of, served the attached 911 Plan by Electronic Filing by depositing in the United States Mail at, true and correct copy thereof, properly enveloped with postage prepaid. by personal service by express mail by delivery service to all persons at the addresses indicated below or on the attached list 1 : In accordance with the Code of Minnesota Rules, Parts and the plan must be submitted to the Minnesota Public Utilities Commission and served on the Department of Commerce, Office of Attorney General-Residential Utilities Division (OAG-RUD), Commissioner of Public Safety, and, if the CLEC proposes to serve within the metropolitan area, as defined in Minnesota Statutes, Section , the Executive Director of the Metropolitan Emergency Services Board (successor to the Metropolitan 911 Board). Page 18 of 21

20 COMPANY NAME: CC VIII, LLC NENA ID: CHTR Burl Haar (e-file) Public Utilities Commission Do not send paper copies Covered by e-filing Jan Mottaz (e-file) Department of Commerce Do not send paper copies Covered by e-filing John Lindell (e-file) Minnesota Attorney General s Office Do not send paper copies Covered by e-filing Dana Wahlberg (e-file) Minnesota Department of Public Safety State 911 Program Manager Do not send paper copies Covered by e-filing If Serving in the Metropolitan Area: Executive Director (e-file) Metropolitan Emergency Services Board Do not send paper copies Covered by e-filing UNDERLYING CARRIER(S): Page 19 of 21

21 MINNESOTA RULES, PARTS Areas Served by LECs With Fewer Than 50,000 Subscribers in Minnesota EMERGENCY SERVICE CAPABILITIES AND REQUIREMENTS. Subpart 1. CLEC 911 plan. Before providing local service in a service area, a competitive local exchange carrier (CLEC) shall submit to the commission a comprehensive plan, detailing how it will provide 911 service to its customers in a manner consistent with applicable law, including chapter 7580 formerly 1215), and comparable to the provision of 911 service by the local exchange carrier (LEC) operating in the competitive local exchange carrier's service area. The CLEC filing the plan shall serve the plan on the department, Office of Attorney General-Residential Utilities Division (OAG-RUD), commissioner of public safety, and, if the CLEC proposes to serve within the metropolitan area, as defined in Minnesota Statutes, section , the Executive Director of the Metropolitan 911 Board [now the Metropolitan Emergency Services Board]. The commission shall not permit the CLEC to begin providing local service until the commission has approved the plan. Subp. 2. LEC cooperation. A LEC shall provide a CLEC with the access to facilities and information necessary to enable the CLEC to meet its 911 service obligations. With respect to resale service, the LEC shall provide a CLEC customer's name, address, and telephone number information to the automatic location identification (ALI) database provider within 24 hours of the daily close of service order activity. Subp. 3. Factors to apply in reviewing CLEC plan. In determining whether to approve a competitive local exchange carrier's 911 plan under subpart 1, the commission shall consider the competitive local exchange carrier's ability and intent to: A. comply with chapter 7580 (formerly 1215); B. integrate into the 911 tandem network as specified in the relevant county plan to achieve appropriate tandem-based choking, if the county is served by a tandem network; C. design a network with adequate diversity and default-routing capability; D. provide for the display at the public safety answering point (PSAP) of the customer's old and new telephone numbers when call-forwarding technology is used for interim number portability; E. cooperate with each relevant county and system integrator in developing a 911 contingency plan; F. maintain circuit-routing profiles and expedite service restoration; G. share customer information and data consistent with current national standards for sharing information related to providing emergency telephone service; H. enter into nondisclosure agreements with the ALI database provider; I. submit data to the ALI database provider in the format required by the database provider; J. ensure that the competitive local exchange carrier's identity is shown on the ALI record and displayed at the PSAP to the extent required by the county; K. provide for operator-assisted emergency calls, including calls from speech-impaired, hearingimpaired, or non-english speaking customers; and L. perform any other function relevant to the provision of 911 emergency service. Subp. 4. Use of decision criteria. The factors identified in subpart 3, items A to L, must be considered as criteria to assist the commission in its evaluation of the adequacy of 911 plans. No one factor need be considered dispositive. STAT AUTH: MS s ; ; HIST: 22 SR 2079; L Sp1 art 2 s 104 Current as of 10/24/05 Page 20 of 21

22 MINNESOTA RULES, PARTS Areas Served by LECs With 50,000 or More Subscribers in Minnesota EMERGENCY SERVICE CAPABILITIES AND REQUIREMENTS. Subpart 1. CLEC 911 plan. Before providing local service in a service area, a competitive local exchange carrier (CLEC) shall submit to the commission a comprehensive plan, detailing how it will provide 911 service to its customers in a manner consistent with applicable law, including chapter 7580 (formerly 1215), and comparable to the provision of 911 service by the local exchange carrier (LEC) operating in the competitive local exchange carrier's service area. The CLEC filing the plan shall serve the plan on the department, Office of Attorney General-Residential Utilities Division (OAG-RUD), commissioner of public safety, and, if the CLEC proposes to serve within the metropolitan area, as defined in Minnesota Statutes, section , the Executive Director of the Metropolitan 911 Board [now the Metropolitan Emergency Services Board]. The commission shall not permit the CLEC to begin providing local service until the commission has approved the plan. Subp. 2. LEC cooperation. A LEC shall provide a CLEC with the access to facilities and information necessary to enable the CLEC to meet its 911 service obligations. With respect to resale service, the LEC shall provide a CLEC customer's name, address, and telephone number information to the automatic location identification (ALI) database provider within 24 hours of the daily close of service order activity. Subp. 3. Factors to apply in reviewing CLEC plan. In determining whether to approve a competitive local exchange carrier's 911 plan under subpart 1, the commission shall consider, at a minimum, the competitive local exchange carrier's ability and intent to: A. comply with chapter 7580 (formerly 1215); B. integrate into the 911 tandem network as specified in the relevant county plan to achieve appropriate tandem-based choking, if the county is served by a tandem network; C. design a network with adequate diversity and default-routing capability; D. provide for the display at the public safety answering point (PSAP) of the customer's old and new telephone numbers when call-forwarding technology is used for interim number portability; E. cooperate with each relevant county and system integrator in developing a 911 contingency plan; F. maintain circuit-routing profiles and expedite service restoration; G. share customer information and data consistent with current national standards for sharing information related to providing emergency telephone service; H. enter into nondisclosure agreements with the ALI database provider; I. submit data to the ALI database provider in the format required by the database provider; J. ensure that the competitive local exchange carrier's identity is shown on the ALI record and displayed at the PSAP to the extent required by the county; and K. provide for operator-assisted emergency calls, including calls from speech-impaired, hearingimpaired, or non-english speaking customers. Subp. 4. Use of decision criteria. The factors identified in subpart 3, items A to K, must be considered as criteria to assist the commission in its evaluation of the adequacy of 911 plans. No one factor may be considered dispositive. STAT AUTH: MS s 216A.05; ; ; 237.HIST: 22 SR 46; 22 SR 2079; L Sp1 art 2 s 104 Current as of 10/24/05 Page 21 of 21

23 AFFIDAVIT OF SERVICE STATE OF GEORGIA ) ) ss COUNTY OF DEKALB ) In the Matter of the Annual Update of the 911 Plan of CC VIII, LLC MPUC Docket No. P6716/EP- Kennard B. Woods, being first duly sworn on oath, deposes and states that on the 14 th day of May, 2012, copies of the foregoing were mailed to the following: Dr. Burl W. Haar* Executive Secretary Minnesota Public Utilities Commission 121 Seventh Place E, Suite 350 Saint Paul, MN John Lindell* Minnesota Attorney General s Office 1200 NCL Tower 445 Minnesota Street Saint Paul, MN Ms. Jackie Mines* 911 Program Manager Minnesota Department of Public Safety 445 Minnesota Street, Suite 137 St. Paul, MN Mr. Martin Moody* Executive Director Metropolitan Emergency Services Board 2099 University Avenue West, Suite 201 St. Paul, MN Martha Ziese Administrative Assistance Metropolitan Emergency Services Board 2099 University Avenue West, Suite 201 St. Paul, MN Jack D. Phillips Regulatory Staff Manager Frontier Communications of Minnesota, Inc Burnhaven Drive Burnsville, MN Ms. Rita Bouie c/o Frontier Corporation Attn: Carrier Services 5th Floor 180 South Clinton Avenue Rochester, NY Ms. Linda Chavez* Telephone Docket Coordinator Minnesota Department of Commerce 85 Seventh Place East, Suite 500 Saint Paul, MN Julia Anderson OAG-RUD 1400 Bremer Tower 445 Minnesota Street St. Paul, MN Ms. Dana Wahlberg* 911 Program Manager Minnesota Department of Public Safety 444 Cedar Street Town Square, Suite 137 St. Paul, MN Cliff Woodbury Independent Emergency Services, LLC 235 Franklin Street SW Hutchinson, MN Paul Mraz Independent Emergency Services, LLC 235 Franklin Street SW Hutchinson, MN Cathy E. Clucas* Director, Governmental Affairs Embarq Minnesota, Inc. d/b/a CenturyLink 30 E 7th St, Suite 1630 St Paul, MN Todd Roesler Chief Executive Officer Ace Telephone Association 207 East Cedar Street Houston, MN 55943