Local Telecommunications Competition Survey 2017 Annual Report

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Local Telecommunications Competition Survey 2017 Annual Report Report to the 2018 Oregon Legislature January 02, 2018

Intentionally Left Blank 2

Table of Contents Table of Contents... 3 Executive Summary... 6 I. Introduction... 8 II. Service Types... 12 a) ILEC Service Types... 12 b) CLEC Service Types... 12 III. Switched Services Market Size and Share Analysis... 14 a) Total Market Size... 14 b) Total Market Share... 15 c) Business Market Share... 18 d) Residential Market Share... 19 e) CLEC Provisioning of Switched Service... 21 Resellers... 21 Facility-Based CLECs... 22 f) Competition based on Unbundled Network Elements (UNEs)... 22 IV. High Speed Access Services... 24 a) CLEC Provisioning of Private Line Circuits... 24 b) Broadband Service... 25 V. VoIP Service... 26 VI. Market Segments by Region and Type of Service... 27 a) Switched Service by Region... 27 3

b) Private Line Service by Region... 29 c) Broadband Service by Region... 30 d) Level of Competition by Region... 31 VII. Business Plans and Competition... 34 a) Capital Expenditures... 34 b) Competition for Residential Market... 35 Appendix... 36 a) Survey Overview... 36 4

Intentionally Left Blank 5

Executive Summary Section 759.050(9), Oregon Statutes, requires the Public Utility Commission of Oregon (PUC) to report annually on the status of competition in the telecommunication industry to the Legislature. In January 2017, information requests were sent to the 32 incumbent local exchange companies (ILECs) and 223 competitive local exchange companies (CLECs) certified by the Commission to operate in Oregon, as of December 31, 2016. Additional information for this report was derived from the Federal Communications Commission s (FCC) Form 477 data, which is collected from all telecommunication companies and from financial information that the ILECs provide the PUC. Staff has been reporting on the status of competition since 2002 and collecting information on the number of certified operating companies since 1998, two years after the FCC opened ILEC franchises to competition. What we have observed over that time was a rapid buildup in the number of operating CLECs between 1998 and 2006. The number of operating CLECs hit a high of 153 in 2006 and then dropped off; the number did not hit that level again until 2012. Since 2012, that number has fluctuated with the count reaching a new high of 164 in 2015. In 2016, the count has decreased slightly to 157. Including ILEC companies, there are approximately 190 certificated wireline telecommunication companies providing local exchange service in Oregon. Of these 190 companies, seven account for 80 percent of the intrastate telecommunications revenues generated in the state. Using the Herfindahl- Hirschman Index (HHI), 1 which is a measure of market concentration, 2 the Oregon 1 The United States Department of Justice considers an HHI of less than 1,000 to be unconcentrated, an HHI of 1,000 and 1,800 to be moderately concentrated, and ones over 1,800 to be concentrated. 2 The term concentration refers to the extent that a few companies control a market. An unconcentrated market is relatively competitive; a market with an HHI near zero would be perfectly competitive. A concentrated market indicates a few companies control the market; a market with an HHI near 10,000 would be a monopoly-controlled market. 6

wireline market would be considered moderately concentrated when measured by share of revenues. The overall HHI index for Oregon is approximately 1,500; however, for residential service, the HHI is approximately 3,200, indicating the market is concentrated and not competitive. Although there are a large number of companies competing with each other, customer options are limited. Wireless providers, which have approximately 3.7 million subscribers, were not included in the calculation of the HHI indices because wireline and wireless companies are not full substitutes for each other. 3 The wireless segment is primarily voice and texting service while the wireline segment provides voice and broadband services. Had wireless companies been included, the HHI would have been even higher. The HHI index for wireless providers is 3,065, indicating a concentrated market with few customer choices. There are currently six wireless companies operating in Oregon, two of which account for 75 percent of the market. Although wireline and wireless services are not full substitutes for each other, the growth in the number of wireless subscribers is clearly tied to the loss of lines by the wireline companies. We particularly see this in business and residential line counts. Business line counts have stayed relatively flat between 2008 and 2016, 4 while the number of residential lines have fallen by more than 430,000. In 2016, ILECs continued to lose lines to both CLECs and wireless carries. While total line counts for ILECs and CLECs in aggregate dropped by 1.4 percent between 2015 and 2016, ILEC counts for business lines went up by 2.1 percent and counts for residential lines went down by 10 percent. Over this same period, CLEC residential line counts fell by a fraction of a percent and their business lines rose by 3.8 percent. On a year-to-year basis, ILEC revenues fell by 6 percent while CLEC revenues rose by almost 14 percent. The CLECs share of revenues are now just slightly under ILECs. 3 Mobile Broadband Service is Not an Adequate Substitute for Wireline, ctc technology & energy, October 2017. 4 This is a period where we have FCC data, which includes all categories of companies. 7

I. Introduction a. Overview This report provides a look at the state of telecommunication competition in Oregon and the impact this competition has had on the Incumbent Local Exchange Carriers (ILECs). The study focuses on local exchange services because they are a good indicator of the level of competition, even though local exchange services only comprise 42 percent of the ILECs revenues. This group of revenues excludes interstate and non-regulated revenues. The underlying study used for this report monitors the type of local exchange services offered by the ILECs and the Competitive Local Exchange Carriers (CLECs). The monitoring is done at the product group and regional levels. For the regional analysis, staff divided the state into six regions: one region is along the coast, another two regions cover the central and eastern part of the state, and the final three regions follow the I-5 corridor. The report begins by looking at the local exchange services offered by the ILECs and CLECs. It then looks at the state-level markets for these services and the ILEC and CLEC market share for each class of service. The report shifts its focus to high-speed services being offered, then looks at the regional markets and the services provided in those markets by the ILECs and CLECs. b. Key Findings Since the first study over 10 years ago, there has been a steady decline in ILEC line counts and a steady build up in CLEC line counts. This has not been a one-to-one transfer of lines from ILECS to CLECs. Figure 1, below, shows the ILEC and CLEC line counts from 2004 to 2016. From Figure 1, it is apparent that only a portion of the lines being lost by the ILECs are being picked up by the 8

CLECs. The overall drop that we are seeing is primarily due to an increased usage of wireless service. Figure 1. ILEC and CLEC Line Counts 2500 ILEC and CLEC Line Counts 2000 1500 1000 300 350 400 475 474 548 548 583 650 684 693 691 736 500 0 1933 1871 1740 1558 1387 1224 1086 971 890 802 755 697 635 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 ILEC CLEC The chart shows that ILEC line counts have fallen by 67 percent between 2004 and 2016. Over the same time period, CLEC and ILEC lines combined have decreased by 38 percent. Between 2004 and 2016, the wireline market lost 862,000 lines that most likely transferred to wireless providers. Lastly, it is worth noting that in 2015, the number of CLEC lines exceeded the number of ILEC lines for the first time, and have continued to do so since. The 2016 FCC Voice Telephone Service Report indicated there were 3.7 million mobile telephone subscriptions in Oregon at the end of June in 2016, up six percent from the previous year. Based on wireline line losses, approximately 20 percent of wireless telephone subscription came from customers shifting from wireline service. The remainder of the wireless subscriptions are fulfilling new market needs. Figure 2 provides another look at what has been happening to the wireline market. Figure 2 shows the growth in the number of certificated wireline telecommunication companies 9

providing local exchange services between the end of 1998 and the end of 2016. Not shown in Figure 2 are an additional 140 companies that are certificated but do not provide local exchange service. With the exception of a downturn in the economy that took place between 2006 and 2010, the number of certificated operating companies has been relatively constant since 2006. Figure 2.Companies providing Local Exchange Service Although there were almost 200 certificated wireline companies providing local exchange service in Oregon at the end of 2016, only seven were major telecommunication services providers. Those seven companies accounted for 80 percent of the intrastate telecommunications revenues generated in the state. Based on the Herfindahl- Hirschman Index (HHI), the overall Oregon wireline market would be classified as moderately concentrated. 5 However, the market for business service would be classified as concentrated (HHI 1827) as would be the market for residential service (HHI 3162). The Oregon market for wireless service would also be classified as concentrated (HHI 3065) as two wireless companies account for 75 percent of the market. 5 The United States Department of Justice considers an HHI of less than 1,000 to be unconcentrated, an HHI of 1,000 and 1,800 to be moderately concentrated and ones over 1,800 to be concentrated. 10

Even though there are almost 200 companies providing telecommunication service in Oregon, the HHI indices indicates that the number of viable service providers that a customer can choose from is limited for residential wireline and wireless customers. Although business customers also have limited options, they have more options than residential customers do. Table 1. Highlights from 2016 Data 2016 Highlights $ Millions % Share ILEC/CLEC % Change from 2015 Oregon Local Exchange Service Revenues 792.9 7.2% ILEC Revenue 396.7 50.00% -5.9% CLEC Revenue 396.2 50.00% 13.9% 000's % Share ILEC/CLEC % Change from 2015 Total Switched Lines at year end 1,371-1.4% ILEC Lines 635 46% -4.8% CLEC Lines 736 54% 1.7% Total Residential Switched Lines at year end 721-5.1% ILEC Residential Lines 342 47% -10.0% CLEC Residential Lines 379 53% -0.2% Total Business Lines at year end 650 3.0% ILEC Business Lines 293 45% 2.1% CLEC Business Lines 357 55% 3.8% 000's % Change from 2015 Other Statistics UNEs (included above under ILEC Business Lines ) 78.2-6.4% ILEC Private Line Circuits (Not Switched) 15.1-16.1% Table 1 provides a year-end snapshot and a look at what took place between 2015 and 2016. Starting with the changes from the prior year, we see that total revenues were up by seven percent; ILEC revenues were down by approximately six percent; and CLEC revenues were up 11

by approximately 14 percent. We also see that ILEC and CLEC line counts were both up for business and were both down for residential lines counts. Overall, total lines fell by 1.4 percent. II. Service Types a) ILEC Service Types In 2016, all 32 ILECs provided local exchange switched service and broadband; 94 percent provided private line service; 50 percent provided long distance service; 84 percent provided access service to long distance or interexchange carriers; 38 percent provided directory assistance service; and 38 percent provided operator service. The companies provisioning Other services such as Integrated Services Digital Network (ISDN) remained constant at four in 2016. 6 One ILEC indicated participation in wireless resale. Figure 3. ILEC Service Types and Distributions Percentage of ILECs Providing Service Types - 2016 100% 80% 60% 40% 20% 0% Switched Private Line Long Broadband Access Directory Operator Lines Distance Service Assistance % Types 100% 94% 50% 100% 84% 38% 38% b) CLEC Service Types Figure 4 shows the number and percentages of CLECs providing various telecommunications services in 2016. As of December 2016, 70 percent (157) of the certificated CLECs were 6 Other services include miscellaneous internet services and reselling video and wireless services. 12

providing one or more of the telecommunications services identified in Figure 4. Of the 157 CLECs providing service, 42 percent provided local exchange switched service, 32 percent provided private line service; 59 percent provided long distance service; 27 percent provided access service to long distance or interexchange carriers; 18 percent provided directory assistance service; 13 percent provided operator service; and 29 percent provided broadband. Figure 4. CLECs Providing Service by Type and Distributions 13

III. Switched Services Market Size and Share Analysis a) Total Market Size Oregon ILECs and CLECs, together, serve an estimated 795,000 local exchange switched access business and residential customers and 1.37 million local switched telephone lines; 7 this is down 1.4 percent from the year earlier. Figure 5 illustrates the change in line count that took place between 2004 when the total line count was 2.23 million to the end of 2016 when the line count was 1.37 million. Over this 12-year period, the wireline market lost 862,000 lines. Much of this loss since 2004 can be attributed to the continued growth in the number of wireless subscribers. Figure 5. Total Line Counts 2,500 2,233 2,221 2,140 2,033 Total Line Counts (000) 2,000 1,863 1,714 1,628 1,551 1,540 1,484 1,449 1,391 1,371 1,500 1,000 500 0 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 The wireline market can be further broken down into business and residential lines. Figure 6 shows the change in the business and residential market between 2008 and 2016. Over this period, business line counts have changed very little, while residential lines have dropped each year. 7 Local exchange line the traditional definition is a voice-level transmission path (64 kbps digital, or less than 4 khz analog) linking an end user location with a switching center providing dial tone. For purposes of this report, we include fixed interconnected VoIP lines provided by cable companies in this category. 14

Figure 6. Business and Residential Lines Business and Residential Lines (000) 1,400 1,200 1,000 800 600 705 1,158 1,075 1,020 982 946 904 639 608 569 594 580 804 760 721 645 631 650 400 200 0 2008 2009 2010 2011 2012 2013 2014 2015 2016 BUSINESS RESIDENTIAL b) Total Market Share Three common metrics for measuring telecommunications market share are (1) switched access lines, (2) revenues, and (3) customers. Each metric provides a unique market share perspective. In 2016, all three metrics show CLECs having a greater market share than ILECS. Using customers (both retail business and residential) as the standard, 8 CLECS are on par with the ILECS with both having 50 percent of the customer base. With revenues as the measure, the ILECs share becomes 45 percent and the CLECs share is 55 percent. Based on switched access lines; the ILECs market share drops to 46 percent and the CLECs share moves up to 54 percent. 8 The survey instructions define a customer as a person or entity that had applied for, been accepted, and was receiving service for a price during the period covered by this report. A customer that has multiple lines is counted as one customer. 15

Figure 7. 2016 Switched Services Market Share 2016 Switched Services Market Share 50% 50% 54% 55% 46% 45% Customers Lines Revenues ILEC CLEC Table 2 below, illustrates that ILEC average annual switched service revenue per line has changed little since 2015 ($371 in 2016 versus $366). The CLEC average annual switched service revenue per line fell by eight percent ($426 in 2015 versus $393 reported in 2016), whereas revenues per customers remained stable from 2015 to 2016, which would suggest that customers are utilizing more lines at lower prices. Table 2. Selected Switched Service Averages 2016 CLECs ILECs Lines Per Customer 1.9 1.6 Annual Revenue Per Line $393 $371 Annual Revenue Per Customer $730 $591 Figures 8 and 9 below show how market share for the ILECs and CLECs has changed over the past 10 years. From 2007 to 2016, ILEC total market share under all metrics decreased from over 80 percent to currently below 50 percent. ILEC total market share of revenues derived from switched service started at 82 percent in 2007, decreasing to 45 percent in 2016. In the same period, the 16

ILEC market share of switched access lines started at 80 percent and ended at 46 percent in 2016. The ILEC total switched-service customer share in the same period, started at 86 percent in 2007 and ended at 50 percent in 2016. Figure 8. ILEC Switched Access Services Market Share ILEC Market Share Percentage in Switched Access Services, 2007-2016 100% 90% 80% 70% 60% 50% 40% Customer Revenues Lines 30% 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 Predictably, as the ILEC market share continues to decline, the CLEC market share shows steady growth. From 2007 to 2016, CLEC total market share of revenues derived from switched service started at 18 percent in 2007 and increased to 55 percent in 2016, significantly higher with the increased inclusion of VoIP participants. In the same period, the CLEC market share of switched access lines started at 20 percent and ended at 57 percent in 2016. The CLEC total switched-service customer share in the same period started at 14 percent in 2007 and ended at 50 percent in 2016. 17

Figure 9. CLEC Switched Access Services Market Share CLEC Market Share Percentage in Switched Access Services, 2007-2016 Lines 60% 50% Revenue 40% Customer 30% 20% 10% 0% 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 c) Business Market Share In 2016, CLECs served 55 percent of business switched access lines. Previously it was thought that VoIP providers were concentrating on the lower cost residential market, however, the PUC now believes there is a definitive switch over to the more profitable (higher revenue per line) business market. Figure 10, below, illustrates the CLEC business switched access line market share trend. From 2007 to 2016, CLEC business switched-service line market share started at 43 percent in 2006 and increased to 55 percent in 2016. 18

Figure 10. CLEC Business Market Shares for Switched Access Service 9 CLEC Business Market Share Base on Lines Switched Service 2008-2016 60.0% 50.0% 40.0% 30.0% 20.0% 10.0% 0.0% 51.2% 53.6% 54.5% 54.9% 46.2% 46.7% 48.0% 43.4% 43.2% 2008 2009 2010 2011 2012 2013 2014 2015 2016 CLECs had a 63 percent share of business switched service revenues in 2016, which is much higher than their 55 percent share of total switched service revenues. A significant reason for this gap is the large difference in revenues per line. This supports the increased business services participation by VoIP providers. d) Residential Market Share The CLEC market share of the residential market continued to increase in 2016 and the CLECs now have a greater market share than the ILECs across all metrics. 9 Historical revenue and customer market share has been omitted since it is not available at this level. 19

Figure 11. 2016 Residential Switched Services Market Share 2016 Residential Market Share Metrics 53% 52% 52% 48% 47% 48% Customers Lines Revenues ILEC CLEC According to the 2016 survey responses, Oregon carriers provided local exchange switched services to 670,000 Oregon residential customers. ILECs served 320,000 customers, or 48 percent of the total, while CLECs served 349,000 residential customers, or 52 percent of the total (44 percent in 2015). The CLECs share of residential lines increased from 43 percent in 2015 to 53 percent in 2016, and the CLECs share of revenues went up from 44 to 52 percent. Figure 12, below, illustrates the CLEC residential switched access service line share trend. From 2008 to 2016, the CLEC residential switched access line market share started at 23 percent and increased to 53 percent in 2016. Figure 12. CLEC Residential Market Shares for Switched Access Services 10 60.0% CLEC Residential Market Share Based on Lines Switched Service 2008-2016 50.0% 40.0% 30.0% 20.0% 10.0% 23.2% 28.4% 34.3% 40.0% 44.5% 48.2% 47.6% 50.0% 52.6% 0.0% 2008 2009 2010 2011 2012 2013 2014 2015 2016 10 Ibid. 20

Figure 13, below, contains a comparison based on the most recent FCC report: Voice Telephone Service; Status as of June 30, 2016, released April 2017. ILEC and CLEC switched access lines in Oregon are compared with the ILEC and CLEC share nationally. The Oregon figures show market share competition in Oregon is ahead of what it is on a national level. Figure 13. Market Share Comparison of Switched Access Lines: U.S. vs. Oregon 11 2016 Market Share Comparison of Switched Access Lines - US vs Oregon 60% 40% 20% 0% ILEC CLEC Oregon % 46.0% 54.0% US % 53.6% 46.4% e) CLEC Provisioning of Switched Service Resellers In 2016, 61 percent of the CLECs (40 of the 66) that reported providing local switched service participated in reselling ILEC services. This is a slight increase from 2015 when 60 percent of the CLECs participated in reselling ILEC services. Reselling requires that a CLEC buy retail service from the ILECs at discounted rates and resell the service, usually with terms and conditions that equal, or are better than, ILEC tariff standards. CLECs will commonly utilize CLEC branding to reach and serve end-user customers. 11 Data from Voice Telephone Services Report, as of June 2016. 21

Facility-Based CLECs In 2016, 50 percent of the CLECs (33 of the 66) providing local switched service, were either fully or partially facility-based providers. 12, This data supports the generally understood service approach of CLECs the resale of ILEC services is combined with CLEC facilities-based services, as needed, to serve customers. Few, if any, CLECs focus entirely on resale or facilities-based competition. f) Competition based on Unbundled Network Elements (UNEs) 13 In 2016, 29 CLECs reported purchasing ILEC UNEs for use in the provision of switched, private line or broadband services. Legal rulings that halted further UNE-P 14 sales in 2007 resulted in a major decline of the use of UNEs. It is now more obvious that the CLEC industry subsequently changed its focus regarding UNE services. CLEC services based on UNE-P were at one time heavily oriented towards serving the residential market. With the rule change, UNE-P services were grandfathered and allowed to churn-out over time. The reduced use of UNEs was expected to continue as ILECs shifted from copper-based lines and as end-users demanded more modern technology solutions from CLECs. The reported data, if accurate, suggests that a relatively stable period was reached beginning in 2011, and has continued since. 12 Facility-based providers own their switches and networks rather than lease assets from other providers. 13 UNE are part of an ILEC s network that federal statute requires them to sell to CLECs. 14 A UNE-P (UNE-Platform) was a combination of UNEs sold as a package that allowed end-to-end service delivery. It consisted of a loop, switching, and interoffice facilities. 22

Figure 14. UNE Lines in Oregon 23

IV. High Speed Access Services In 2016, 50 CLECs reported they provided intrastate private line service 15 (52 in 2015,). 16 As with switched access lines, the survey measured CLECs market share in three ways: by customers, circuits, and revenues. 17 Table 3, below, compares total counts and displays CLEC market share of intrastate private line services. CLEC private-line market shares ranged from 62 percent (measured by circuits) to 70 percent (measured by revenue). Table 3. Intrastate Private Line Services 2016 All LECs CLECs ILECs CLEC Share Private Line Customers 3,902 2,221 1,681 57% Total Private Line Circuits 15,138 9,418 5,720 62% Lower Capacity 4,390 330 4,060 8% Higher Capacity 10,748 9,088 1,660 85% Annual Revenues ($000) $65,754 $45,731 $20,023 70% a) CLEC Provisioning of Private Line Circuits Twenty-nine CLECs provided private line services by reselling ILEC services. Thirteen CLECs provided private line service by reselling services of other CLECs. Most of this resale activity was to business customers in the Portland Metropolitan and Willamette Valley areas. 15 In 2016, five CLECs provided only lower capacity private line service; 30 CLECs provide only higher capacity private line service; 15 CLECs provide both lower capacity and higher capacity private line services. 16 In 2015, five CLECs provided only lower capacity private line service; 33 CLECs provide only higher capacity private line service; 14 CLECs provide both lower capacity and higher capacity private line services. 17 A circuit is a commonly accepted industry term for private line facilities, such as DS1 and DS3 private lines or circuits. Circuits, however, can equate to POTS switched access lines, also called DS0s. For example, a DS1 circuit can equal 24 DS0s; a DS3 circuit can equal 672 DS0s. A circuit may connect two customer locations. If so, customers will be billed for each connection or termination. Each circuit will have at least two terminations. The capacity of a circuit is determined by the capacity delivered to the customer at the point of termination, even though the customer may further subdivide that capacity using its own multiplexing or other equipment. 24

b) Broadband Service Although revenues and line counts from IP based broadband providers are included in limited form in this report as few submit corresponding information, the year-on-year changes and the comparison of revenue share gives an indication of the expansion of broadband in Oregon. The total number of ILEC and CLEC broadband lines reported in Oregon were 427,365 in 2016 and 395,534 in 2015, an increase of eight percent. Last year (2016) saw a significant shift in the provisioning of broadband with a substantial growth in the CLEC figures. Approximately 77 percent of the lines were provided by ILECs, down from 89 percent in 2015, and 23 percent were provided by CLECs, up from 11 percent in 2015. Figure 15, below, illustrates the trend of high-speed digital access as a percentage of both ILEC and CLEC total revenue. 18 In 2007, combined intrastate private line and broadband revenue comprised 18 percent of total revenues. This percentage steadily increased through 2016, reaching 34 percent. Broadband penetration is believed to be nearly 100 percent in metro areas due to the participation of interconnected VoIP and wireless. As penetration levels increase in markets outside of metro areas, revenues will increase accordingly. Figure 15. Trend of Private Line and Broadband Access in Oregon 18 Total revenue here is limited to switched access lines, intrastate private lines, and broadband. 25

V. VoIP Service Knowing that ILEC and CLECs had begun to use VoIP technology, Staff revised the 2016 data survey to request specifically data for VoIP served lines. VoIP service (primarily fixed interconnected VoIP Service) enables real-time, two-way voice communications using Internetprotocol (IP) compatible customer-premises equipment and IP compatible central office equipment (soft-switches). Tracking the move to the provisioning of voice services using VoIP provides useful information about the local exchange network and to some extent the focus of any investment. Thirteen percent (four) of the ILECs indicated a limited use of VoIP technology to provide local exchange services, compared to 46 percent (73) of the CLECs. The ILECs reported they are serving less than 1,000 VoIP lines total, which suggests that the ILECs are in an early stage of market testing or perhaps transitioning customers from POTS service. 19 VoIP service by the ILECs seems inevitable, as a number of the small ILECs have been installing soft-switches, 20 essential for the use of VoIP technology to serve end-users. 19 POTS is commonly understood to mean Plain Old Telephone Service, the copper-based, circuitswitched technology used by most ILECs and CLECs for local exchange service. 20 Softswitch is an abbreviation for software switch, the most modern version of central offices. Softswitches were originally designed for packet-switched (a.k.a., internet protocol (IP)) traffic, but have evolved for use by both IP and circuit-switched traffic. 26

VI. Market Segments by Region and Type of Service Staff divided Oregon into six, county-based geographic regions. The six regions identified by color are 1) Portland Metropolitan (Portland); 2) Willamette Valley (Willamette); 3) Southwest Interior (Southwest); 4) Coast; 5) Central; and 6) East. With the exception of the Coast region, which was pulled from the Portland, Willamette, and Southwest regions, the PUC s regions are the same as those used by the Oregon Department of Transportation. Form L Regions a) Switched Service by Region The Portland region is the most populous area of the state with a population almost twice as large as the next region. The next largest region is the Willamette region, followed by the Southwest, Central, and the remaining other regions. The Portland Metropolitan region has a 27

51 percent share of all local exchange switched lines in the state. The Willamette Valley has the second largest share with 24 percent of the switched access lines. The remaining four regions, in aggregate, only account for 25 percent: Southwest Interior (9 percent), Coast (5 percent), Central (7 percent), and East (3 percent). Figure 16 shows the distribution of combined ILEC and CLEC switched lines by region. Figure 16.Switched Line Regional Distribution Figure 17, below, provides a breakdown of the distribution found in Figure 16. Figure 17 looks only at CLEC lines and breaks those down into residential and business lines. Comparing Figure 16 and Figure 17, we see that in the Portland region, the CLECs are slightly more concentrated for both categories of lines then the combined distribution. There are slight variations from the combined distribution, but less than that in the Portland region. 28

Figure 17. CLEC Switched Line Regional Distribution b) Private Line Service by Region The distribution of private lines across regions is measured by circuit terminations rather than by circuits. Using this metric, the Portland Metropolitan region is the largest regional private line market, with 41 percent of all retail private-line circuit terminations in the state. The second largest region is the Willamette Valley, which has 20 percent of private line circuit terminations. The remaining four regions are Central (12 percent), Southwest Interior (11 percent), East (7 percent), and Coast (9 percent), which account for the remaining 39 percent. Figure 18 shows the distribution of circuit terminations across the six regions. The circuits have been separated into two groups: 1) low capacity, which are generally two and four wire loops with speeds below 64 kilobits per second, are typically used for alarm circuits or voice; and 2) high capacity loops, which have speeds starting at 1.5 megabits per second, are typically used for data. 29

Figure 18. Private Line Circuits by Region All LECSs - Circuits by Region, 2016 50% 40% 30% 20% 10% 0% Portland Willamette S.W. Coast Central East Lower Capacity 34% 24% 11% 8% 12% 12% Higher Capacity 47% 17% 12% 9% 11% 4% Of the state's 15,138 local exchange private line circuit terminations, 29 percent were in the lower capacity category and 71 percent were in the higher capacity category. The Portland Metropolitan region was the largest market for both lower and higher capacity circuits. c) Broadband Service by Region In the 2016 survey, ILEC and CLECs reported providing 427,365 broadband lines, which generated $201.8 million in revenue. Forty-one percent of the lines were in the Portland Metropolitan region (see Figure 19), which has the largest count, followed by the Central (19 percent), Willamette Valley (18 percent), Southwest Interior (10 percent), East (7 percent), and Coast (4 percent) regions. As stated previously, broadband data in this report is limited as few companies submit corresponding information. 30

Figure 19. Broadband by Region d) Level of Competition by Region Figure 20 and Figure 21 show the number of companies competing for residential and business customer in each of the regions. While the CLECs can compete across an entire region, the ILECs can only compete in their franchised serving area. The ILECs are not competing with other ILECs in a region. Figure 20. Residential Providers by Region 31

The number of CLEC companies competing for residential customers across all of the regions ranges from a high of 14 companies in the Willamette region to a low of 10 companies in the East region. There are a significantly larger number of CLEC companies competing for business customers. In the Portland region, there are four times as many companies competing for business customers as there are companies competing for residential customers. In all regions except the Southwest region, the number of companies competing for business customers is more than twice the number competing for residential customers. Figure 21. Business Providers by Region Figure 22 provides a look at the HHI used by the United States Department of Justice when determining if a market is competitive or concentrated. An HHI index of 10,000 indicates a monopoly; an index close to zero indicates the market is competitive. The business markets for the Southwest region would be considered unconcentrated; the East region s business market would be considered moderately concentrated; and all of the other business and residential markets would be considered concentrated. When a market is determined to be concentrated, it means a few businesses have a very significant market share and are able to control the prices in that market. 32

Figure 22. HHI Index by Region 21 21 The HHI for the regions was calculated based on line market share while the total state index was calculated using revenue market share. 33

VII. Business Plans and Competition a) Capital Expenditures Each year staff collects information from the companies on what was spent on adding and upgrading its network. Not all companies responded to this section of the questionnaire because they were not required to do so. This year only 80 percent of the CLECs responded to the question while all of the ILECs responded. Figure 23 shows how the ILEC companies responded to this question over the last three years. Figure 23. ILEC Capital Expenditure Given the relatively small size of many of the ILEC companies, their actual investments most likely falls on the low side of the ranges. This is particularly true for the companies reporting investments in the one-to-ten million-dollar range. Figure 24 shows the CLEC capital expenditures for the past three years. Although there are a number of CLEC companies that invest in building and maintaining a network, the majority of 34

them spend very little on their networks; these are the smaller companies. There are also 10 companies that spend in excess of $1 million per year on their networks. Figure 24. CLEC Capital Expenditure b) Competition for Residential Market The annual survey also had a section about the competition that companies were facing in the residential market. Sixty-nine percent of the ILECs responded to the question and 61 percent of the CLECs responded. The companies were allowed to mark multiple answers to the question, What do you believe are the reasons that you do not have a bigger share of Oregon's residential market? Table 4 shows possible reasons for a company not having a larger market share; it also shows how many ILECs and CLECs felt that reason applied to them. Table 4. Residential Market Competition: 2016 Reasons # of ILECs # of CLECs Cannot compete on price 5 29 Cannot compete on facilities 0 19 ILEC has name familiarity 0 17 Do not have enough capacity 0 16 Wireless phone decreased the wireline demand 22 22 Hard to compete due to location 13 16 Other (explain): 10 89 35

Appendix a) Survey Overview Purpose of the Survey The purpose of the survey is to determine the status of competition for certain local exchange services provided by ILECs and CLECs in Oregon. The survey collects data on five major types of services: (1) local exchange switched access; (2) intrastate private line; (3) broadband; (4) unbundled network elements (UNEs); and (5) resale service. Survey Participants and Responses In January 2017, the PUC sent a survey to all 255 carriers holding a certificate issued by the PUC to provide local services in Oregon. Of the 255 carriers, 32 are ILECs and 223 are CLECs. The ILECs are the traditional local telephone service providers, statutorily designated as carriers of last resort (COLR), obligating them to serve customers within PUC approved service areas under PUC approved terms and conditions. CLECs do not have COLR obligations. The survey requested information pertaining to carrier operations in 2016. Table 5, below, summarizes the survey response and service operation rates, defined as the percentage of companies offering local exchange service in Oregon. Table 5. Survey Response Rates and Service Operation Rates 2016 Surveys Sent Responses Response Rate % Total LECs 255 250 98.0% ILECs 32 32 100.0% CLECs 223 218 97.8% Surveys Sent Service Provided Operation Rate % Total LECs 255 189 74.1% ILECs 32 32 100.0% CLECs 223 157 70.4% 36