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Before the


Washington, D.C. 20554

In the Matter of

Wireline Competition Bureau Short Term

Report No. NCD-2378

Network Change Notification filed by

Verizon Virginia LLC


Verizon is retiring copper in a small number of older cross boxes in the Midlothian wire

center that currently are used to provide just nineteen POTS lines and three broadband Internet

access lines. Upgrading these customers to Verizon’s more advanced and reliable fiber facilities

is an efficient and reasonable step. There has been no valid objection to the limited copper

retirement. In fact, no objections were filed by customers living or working in these areas or by

providers serving them, and no request for an extension of time made. The claims raised by the

only commenter, an industry advocacy group, are not specific to the facilities to be retired, and

have no merit.

A. Fiber Brings Tremendous Advantages to The Customers Here and There Is No

Reason to Continue to Maintain Redundant Copper Facilities

Most of the customers served by the facilities to be retired are purchasing retail plain old

telephone service, or POTS. Following the retirement of these facilities, they can continue to

receive the same traditional POTS service over fiber on the same terms and conditions and at the

same or better price as they received over copper. There is no change in the underlying features

and functionalities in the voice service available over fiber: voice mail, collect calling, and other

1 This response is filed on behalf of Verizon Virginia LLC (“Verizon”).



features will continue to work just as they did over copper; customers will continue to be able to

use fax machines, medical monitoring devices, and home alarms; and accessibility services –

such as relay services used by customers who are deaf or hard of hearing – also will continue to

work as before. There will be no change to customers’ ability to call 911; public safety

answering points will receive the same E911 information as before.

For the three customers purchasing broadband Internet services over the copper facilities

to be retired, FiOS Internet will offer them the ability to receive more than they are getting today.

To be clear: phone service received over fiber facilities is not the same thing as Verizon’s

FiOS service. Fiber refers to a physical medium: a network made up of fiber optic cables. FiOS

refers to particular Verizon branded voice, video, and data services, including FiOS Digital

Voice, FiOS TV, and FiOS Internet, that Verizon provides on an optional basis to customers over

fiber. While millions of customers have elected to switch to Verizon’s best-in-class FiOS

service – provisioned over fiber-optic cable – many others, including those who so choose in this

area, receive the same traditional phone service, with the same features and at the same or better

price, over Verizon’s advanced fiber network.

As customers and public entities have widely recognized, fiber is a safe, proven, and

known technology with a track record of serving communities well. From the perspective of

reliability, fiber is immune to many environmental factors that affect copper cable, and is less

likely to experience outages during weather events, homeland security incidents, or other public

safety emergencies. Fiber lines are generally more durable, do not corrode, have a much longer

lifespan, and require fewer repairs than copper lines.

The reliability advantages of fiber directly benefit customers. For example, as a result of

Verizon’s programs in recent years to encourage customers experiencing repeated service issues



with copper facilities to migrate to fiber, there have been approximately one million fewer repair

or trouble-shooting dispatches than would have been required had these customers remained on

copper facilities. This equates to one million instances in which customers have not experienced

an outage or other problem with their service. And for many of those customers, this also

equates to time savings, since they would not have to schedule repair appointments and take time

out to meet a repair technician. While the resulting consumer welfare gains may be difficult to

quantify precisely, to put this in perspective, if one million customers were able to avoid a repair

visit with a four hour window, a conservative estimate of the consumer welfare gains from those

avoided repairs would approach $100 million.2 Of course, there may be other ways to quantify

the benefits as well, but regardless of the calculation the point is the same; the benefits to

customers are significant and large. And the customer benefits from avoiding the outage or other

service problem in the first place.

Fiber also provides performance advantages, as it offers significantly greater bandwidth

and is much less sensitive to distance limitations than is copper. Because the fiber optic signal is

a light rather than an electrical signal, there is very little signal loss during transmission, and data

can move at higher speed and for greater distances. As a result, fiber can support much greater

broadband and higher speed services than copper.

Fiber facilities are also more energy efficient than copper because they use laser light –

not an electrical signal – reducing energy consumption and resulting in a greener network. Once

copper facilities are retired, there is no longer a need to power two parallel networks as there is

2 This values customers’ time based on the national average hourly wage of $24.45. See

Bureau of Labor Statistics, Table B-3: Average hourly and weekly earnings of all employees on

private nonfarm payrolls by industry sector, seasonally adjusted, (last update Aug. 1, 2014) (calculating average

wage at $24.45).



today. Instead, only the more efficient fiber network will consume energy going forward.

Additionally the move to fiber reduces the opportunity for the theft of copper cable which has

been on the rise in many areas.3 Within only a subset of Verizon’s ILEC footprint, there have

been over 1700 incidents of copper theft in recent years, resulting in customer outages, financial

losses and safety concerns. Retiring copper facilities that are no longer needed to serve

customers avoids these problems.

Based on the many benefits of fiber, communities throughout the United States have been

clamoring for the benefits of all-fiber networks. The President has praised fiber deployment and

investment; the Commission has had as a long-standing goal the encouragement of more

widespread fiber deployment. Indeed, providers across the country have deployed fiber cables in

their networks and to homes for decades.


There Are No Valid Objections to Verizon’s Copper Retirement Notice

As required by the Commission’s long-standing procedures in Sections 51.325 and

51.333,4 Verizon properly served and filed its copper retirement notice for the facilities in

question. Not a single objection was filed by a telecommunications or information services

provider, nor did the one comment submitted contain the information required under Section

51.333(c) to substantiate a proper objection. No commenter submitted specific reasons why it

could not accommodate these changes by the stated implementation dates six months after

filing,5 nor did any explain what steps it was taking to accommodate these changes. Nor did any

3 See, e.g., Verizon Offers $50,000 Reward in Copper Thefts, New Castle News,

0019bb2963f4.html (Aug. 15, 2014) (reporting that nearly 1,000 feet of copper cable worth

thousands of dollars has been stolen in Pennsylvania in the prior two weeks).

4 47 C.F.R. §§ 51.325, 51.333.

5 Verizon plans to retire these lines in Midlothian on or after November 1, 2014.



commenter submit comments or objections specific to compliance with this small retirement, nor

did residents of this area raise concerns.

Instead, the sole commenter reiterated its contentions only about copper retirement more

generally. The Alarm Industry Communications Committee (AICC) continues its claim that the

fiber and cable systems now supporting millions of customers nationwide are unsafe. It

separately argues that the Commission’s long-standing network change and copper retirement

notification process is not sufficient and argues that copper retirement will result in a reduction

or impairment of service and thus should be reviewed under Section 214. Both of its contentions

are meritless.

First, as noted above, fiber and coaxial cable based facilities are widely deployed across

the country and around the world, and provide reliable and efficient service to millions of

customers, including customers using alarm systems. Contrary to AICC’s comments, alarm

companies already rely heavily on fiber facilities and tout their products’ compatibility with

fiber, even though these systems all rely on some form of battery back-up. For example, ADT,

one of the country’s leading alarm companies and a member of AICC, acknowledged in 2007

that Verizon’s fiber facilities were approved to work with ADT alarm services, and Verizon is

continuing to work with ADT to ensure ongoing compliance with ADT requirements.

Second, as noted previously,6 AICC’s claims concerning the copper retirement notice

procedures have already been addressed and rejected by the Commission when it established the

procedures for copper retirement filings. Consistent with its other broadband policies, the

6 See, e.g., Verizon New York Inc. and Verizon Virginia LLC Response, Wireline

Competition Bureau Short Term Network Change Notifications, Report Nos. NCD-2353 and

NCD-2354, at 5-6 (May 28, 2014); Verizon New England d/b/a Verizon Massachusetts, et al.

Response, Wireline Competition Short Term Network Change Notifications, Report Nos. NCD-

2365, NCD-2372, and NCD-2373, at 5-8 (July 14, 2014).



Commission determined in the TRO that ILECs are permitted to retire copper facilities after

deploying fiber, subject only to the obligations to comply with the Commission’s network

disclosure rules and to provide competitive providers with access to narrowband capabilities over

fiber.7 Far from finding the move from copper to fiber an “impairment” to a particular service

that could possibly require a separate filing under Section 214, the Commission specifically

addressed and rejected proposals that would require affirmative regulatory approval prior to the

retirement of any copper loop facilities.8 The Commission concluded that such proposals were

“not necessary” and that the established network disclosure rules would best encourage all

providers, including non-ILECs, to invest in broadband facilities.9 Pursuant to these rules,10 the

Commission provided for a period of notice to the public and to interconnecting carriers, and

created a specific time frame for objections that would both allow well-founded objections to be

heard but also not delay retirement more than six months from the provider’s notice. The

Commission acknowledged that requiring providers to retain copper or other facilities no longer

needed to serve their customers would necessarily divert resources better spent deploying or

enhancing the networks that they intend to use to serve their customers, to the detriment of


7 See Review of the Section 251 Unbundling Obligations of Incumbent Local Exchange

Carriers, Report and Order and Order on Remand and Further Notice of Proposed Rulemaking,

18 FCC Rcd 16,978, ¶¶ 273, 281 ( 2003) (“TRO”).

8 TRO, ¶ 281.

9 Id.

10 See 47 C.F.R. § 51.333.

11 See FCC, Connecting America: The National Broadband Plan, at 48-49 (2010), (stating that incumbents forced

to retain redundant copper networks would have reduced incentives to invest in and deploy next

generation facilities) Relatedly, in the USF context the Commission has recognized that it makes

no sense to support duplicative networks, and has accordingly proposed that support be limited

to “[a] single fixed broadband connection” per residence/household. Connect America Fund; et



AICC offers no new evidence of any changed circumstances that would justify revisiting

those procedures or findings now (and the Commission could not do so absent a new rulemaking

in any event), nor does it argue that Verizon failed to comply with them here. As noted above,

alarm companies around the country including members of AICC agree that Verizon’s fiber-

based facilities may be used in connection with their alarm systems and have done so for many


AICC cannot dispute that the overwhelming majority of customers today – whether they

purchase service from cable providers, over-the-top providers, or wireless providers – do not

have a line-powered copper telephone, or that many of these customers already use alarm

systems that function on platforms other than copper and which have battery back-up for

instances of commercial power outages. Nor can AICC dispute that its own members have

widely accepted cable and fiber-based facilities and voice services, with their attendant battery

back-up, for use with their alarm systems. AICC also concedes that Verizon is offering affected

consumers here even more control over back-up battery for traditional voice customers during

commercial power outages by making available a battery back-up for voice services that uses

standard D Cell batteries.12 These batteries are widely available and replaceable, which allows

the customer to extend the amount of battery back-up.13

al., Report and Order and Further Notice of Proposed Rulemaking, 26 FCC Rcd 17,663, ¶ 1256


12 See, e.g., AICC Comments, Wireline Competition Bureau Short Term Network Change

Notification filed by Verizon Virginia LLC, Report No. NCD-2378, at 4-5 (Aug. 13, 2014).

13 Verizon provides customers with information about the back-up battery option on four

separate occasions: when customers receive a notification letter about the migration; when they

speak to a representative about migration; from the technician who migrates their service; and, in

their written welcome package.



AICC’s criticism of the battery back-up is ironic given the heavy reliance of its members

on batteries to support their alarm systems, both during commercial power outages and at other

times. Indeed, alarm systems themselves also rely heavily on back-up power units in the event

of a commercial power failure, often batteries similar to the 12v lead-acid battery Verizon has

traditionally used for its fiber-based customers. Even outside of the context of power outages,

alarm companies often rely on standard batteries to support some parts of home alarm systems,

such as smoke detectors, carbon-dioxide detectors, motion sensors, and door and window


Notwithstanding the reliance by consumers on batteries both in the context of their

communications and alarm services, AICC now makes alarmist claims that the D-cell back-up

option is “a public safety issue.”15 It levels this claim even as it states that “AICC has no quarrel

with the use of fiber optic technology in general and, in the main, is agnostic about fire and

burglary alarm transmission technology.”16 But AICC cannot have it both ways. Like alarm

systems, fiber and cable company transmission facilities are not line-powered, and thus all of

these platforms require some form of battery back-up during commercial power outages.

As Verizon has deployed fiber, it has consistently sought to provide customers with

battery back-up options that would meet their needs, including during times of power outages.

Verizon’s customers served over fiber have historically had the option of a using a 12 volt

battery back-up, which generally provided customers with up to 8 hours of backup during power

outages. Millions of Verizon’s customers have been well-served by these battery backup units

over the last decade, as fiber facilities have supported their communications needs – including in

14 See, e.g.,

15 AICC Comments at 2.

16 Id. at 7.



conjunction with their home alarm systems. Verizon’s introduction of its new D-Cell approach

to back-up battery will only improve this consumer experience, allowing customers to more

easily provide extended battery-backup using familiar and easy-to-obtain batteries. This

approach offers customers more control over their battery back-up, with the ability to purchase

replacement batteries at their convenience from almost any grocery or drug store. Rather than

the threat that AICC suggests, this is a best-in-class approach to battery backup that provides

substantial consumer benefits.

Respectfully submitted,

/s/ William H. Johnson

Michael E. Glover

William H. Johnson

Of Counsel

Katharine R. Saunders


1320 North Courthouse Road

9th Floor

Arlington, Virginia 22201

(703) 351-3060

August 20, 2014


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