anna hanna pllc attorneys law
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MAILING ADDRESS: P.Q. BOX 3967 CHARLESTON, WV 25339
ANNA & HANNA PLLC Attorneys at Law
1206 VIRGINIA STREET EAST, SUITE 201 CHARLESTON, WV 25301
TELEPHONE (304) 342-1687 FAX (304) 342-8761
www. hannalawpllc.com August 31,2021
VIA HAND DELIVERY Connie Graley Executive Secretary Public Service Commission 201 Brooks Street Charleston, W 25301
Re: Case No. 21 -051 5-CTV-SC-GI Cebridge Acquisition, LLC, dba Suddenlink Communications, et al.
Dear Ms. Graley:
On behalf of Cebridge Acquisition, LLC, Cequel Ill Communications I LLC, and Cequel Ill Communications II LLC, dba Suddenlink Communications (“Suddenlink), I hand you for filing the following:
1. The original and ten copies of the Public Version of the Response of Suddenlink Communications to Commission Order issued July 1,2021 , including one DVD containing the documents referenced in the Response.
2. The original and two copies of the Confidential Unredacted Version of the aforesaid Response, which Confidential Unredacted Version is filed herewith separately under seal. Pursuant to Rule 4.1.5. of the Commission Rules of Practice and Procedure, Suddenlink’s Motion for Protective Treatment will be filed within one week. Also included with the Confidential Unredacted Version of the Response is one DVD containing the confidential documents referenced in the Response.
A copy of the Public Version of Suddenlink’s Response has been served on all parties of record as indicated by the attached certificate of service. If you have any questions, please contact me.
Since re1 y ,
WV State Bar # 881 3 d [email protected]
DBH/dh Enclosure cc: L. Bouvette, Esq. / B. Hirst, Esq.
H. Osborn, Esq. R. Rodecker, Esq. / J. McGhee, Esq. A. Gunnoe, Esq.
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PUBLIC VERSION
PUBLIC SERVICE COMMISSION OF WEST VIRGINIA
CHARLESTON 'UBLIC SERVICE COMMISSION OF WEST JIRGINIA CHARLESTON,
Plaintiff,
V.
CEBRIDGE ACQUISITION, LLC, DBA SUDDENLINK COMMUNICATIONS, a provider of cable television service; CEQLTL 111 COMMUNICATIONS I LLC, DBA SUDDENLINK COMMUNICATIONS, a provider of cable television service; AND CEQUEL I11 COMMUNICATIONS I1 LLC, DBA SUDDENLINK COMMUNICATIONS, a provider of cable television service.
Defendant.
Case No. 2 1-05 15-CTV-SC-GI
RESPONSE OF SUDDENLINK COMMUNICATIONS TO COMMISSION ORDER ISSUED JULY 1,2021
CASE NO. 21-0515-CTV-SC-GI 1
SUDDENLIKXWVPSCOO3 63 6
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Altice USA, Inc. on behalf of its subsidiaries offering Suddenlmk video services in West
Virginia, including Cebridge Acquisition, LLC d/b/a Suddenlink Communications, Cequel I11
Communications I, LLC d/b/a Suddenlmk Communications and Cequel I11 Communications 11,
LLC d/b/a Suddenlmk Communications, (collectively, “Altice” or the “Company”) submits this
letter and the enclosed documents in response to the Public Service Commission of West
Virginia’s July 1, 202 1 Order to Show Cause regarding the provision of Suddenlink cable
television service to more than 300,000 households in West Virginia.
The Company requests that the Public Service Commission (the “Commission”) maintain
confidentiality of certain proprietary and highly confidential information and has submitted a
motion to the Commission requesting confidential treatment of such information pursuant to
W.Va. Code 4 29B-1-4(a)(l).
* * *
Altice recognizes that it has faced performance challenges in West Virginia, particularly
with respect to its delivery of field services and customer care. The Company has taken tangible
steps to improve its operating model, investing millions of dollars to bring a better experience for
its customers in West Virginia.
REORGANIZLUG FIELD SERVICE IN WEST VIRCEYIA
In 201 8, Altice migrated the delivery aspects of Suddenlmk field service operations to a
standalone and separately managed operating division, Altice Technical Services (“ATS”),
including construction, plant maintenance and field service (both installs and repair services)
across the Suddenlmk footprint. The model was intended to create independence and efficiencies
in field operations by separating it from the larger organization.
Over time, it became apparent that this organizational model introduced certain service
gaps and fhilties. In 2019, Suddenlmk observed a high volume of calls related to service issues
In this letter, Altice responds to the specific issues raised in the Order to Show Cause. Altice notes that during the May 6, 2021 meeting with the Commission, Chairman Lane directed Altice to correction plan that addressed how, among other things, Altice would fix problems with billing E-9 1 1 fees. Altice addressed this issue in Suddenlink’s June 7, 202 1 letter to Chairman Lane and it was not further raised in the Order to Show Cause, which is limited to Suddenlink’s compliance with the Cable Television Systems Act and the terms of its cable franchises. Accordingly, Altice does not address E-9 1 1 fees here.
-2- CASE NO. 21-05 15-CTV-SC-GI
SUDDENLNKWVPSC00363 7
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and a significant number of customers requiring a home visit. For example, approximately=
of Suddenlink customers in West Virginia required a second home visit in September 2019.
At the same time, a number of events transpired over the course of 2019-2020 that
impacted field service performance and exacerbated problems with the ATS business model:
0 In September 2019 (with prior notice to the Commission), Altice invested to
upgrade the Suddenlink networks to a new billing and operational support system
(BSS/OSS migration). During this migration, the Company’s online billing system
was inaccessible for several days, and installations and non-essential service visits
were temporarily halted. As a result, certain customers experienced billing and
provisioning is sues.
In 2020, the Company was faced with site closures, emergency declarations,
quarantines and other workplace restrictions, and employee/contractor absences
due to the COVID-19 pandemic, all of which impacted operations. At the same
time, demand for Suddenlink field services - new installations, changes of service,
and service attention - increased. This heightened demand strained Suddenlink’s
field service operations (as well as network capacity and customer care resources).
Severe weather during July-September 2020 also impacted company operations
and some customers’ service^.^
0
0
Altice took these issues seriously and substantially reorganized its field operations
organization in November 2020 by dissolving ATS and reabsorbing field operations directly into
Altice USA under the leadership of Pragash Pillai, Executive Vice President Operations, in order
to improve coordination with care, enhance network maintenance and improve service quality
’ Given the complexity of the migration, it took approximately three months to resolve these billing and provisions issues. Altice waived late fees for the time period before and after the migration and worked diligently to resolve other impacts which were reflected in decreased customer call volume, wait times, and abandonment after September 2019.
’ While the Company takes measures (including the use of backup power) to avoid the impact of severe weather on Suddenlink services, both Company facilities and customer homes rely heavily on the availability of commercial power. Temporary loss of Suddenllnk cable television service from commercial power loss, plant damage and/or restrictions on service vehicles’ access to roadways in a storm’s aftermath are common and largely unavoidable impacts of severe weather. As a result, Suddenlink customers in West Vlrginia were faced with outages.
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CASE NO. 2 1-05 15-CTV-SC-GI
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across the board. With thls operational c b g e , Altice has invested inillions of dollars into
personnel initiatives to unprove the overall customer experience and meet the slgntficant increase
in demand. Since December 2020, the Company has added m r e maintenance resources to
improve plant health and, as described below, continues to move forward with network upgrades
and proactive maintenance, augmenting capacity and q l e m e n t i n g node splits to improve
network performance. Altice has also -roved field services by improving technician timeliness
and increasing service time allowances so that technicians spend enough time in the customer’s
home to ensure that services are installed and inquiries are resolved on the techcian’s first visit.
Since thls change, field service performance is q r o v i n g across a range of metrics,
including the number of customers calling for t e c h c a l support, the number of customers
r e q u i r k a service visit, the timeliness of techniciau arrival for a service visit, improved quabty
of performance at the service visit (measured by ability of technician to resohe issue on first
visit), and overall customer satisfaction with the service visit.
,;ls shown in the chart below, 1z1 Ju€y 3021, the call rate for tecttlllcal issues was- calls
per customer in West Virguzia, droppmg f r o m u c a l l s per customer in December 2020 (a 33080
miprovemeutj The number of customers requirmg a home service visit has also declined
siLmficwtlyty, reachins only-per customer m July. a 27OJo mprovemeut &om- visits per
customer m Fall 2020. %time arrival and repeat service visit rate metrics have also lIuproved m
202 1 For example. the repeat wsit rate has dropped from- m Fall 2020 to
202 1 - a 34% mprovement.
m Ju1y
-4- CASE h-0. 2 1-05 1 SCTL--SC-GI
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Altice continues to work toward achieving and exceeding its target goals on these key
metrics.
ADDRESSLVG CUSTOMER SERVICE ISSUES
The Company is also working to improve its delivery of customer care, which has been
under the leadership of Greg Thomas, Senior Vice President Consumer Experience since
November 2020, with day-to-day call center operations overseen by Altice’s majority-owned
subsidiary, Intelcia USA, LLC (“Intelcia”). Ldse field services, customer care (telephone, chat,
and online customer billing and technical response) also suffered in 2020, exacerbating the
unfavorable trends that the Company observed in 2019. To address these issues, the Company
has invested millions to improve customer care and the new team leadership has focused its
efforts on improved forecasting and staffing, operational readiness, and the development and
improvement of agent training, tools, and customer service policies and procedures. For example,
Altice added more than 400 additional vendor customer service representatives in 2020 and
continues to add headcount as necessary to ensure that agents are available to answer customer
calls in a timely fashion. Among other proactive measures, the Company has trained= retention
-5- CASE NO. 2 1-05 15-CTV-SC-GI
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and outbound sales agents to handle Suddenlmk customer care calls relating to billing and general
inquiries. Altice has also trained a portion of its Optimum customer service work force on the
Suddenlmk platfonn, which allows the flexibility of shifting these resources to Suddenllnk as
needed.
The Company has also invested significant resources to improve and modernize its phone
system. The upgrades provide for more advanced call routing as well as customer callback
functionality, offering customers the option to receive a call back (rather than waiting in queue)
while holding their place in line during periods of high call volume. Altice has also upgraded its
call recording platform to allow for recording of agent screen interactions (in addition to the calls
themselves) and utilize call to speech analytics reporting to perform quality control monitoring of
customer interactions. In addition, the Company has started an upgrade to a new, state of the art
Interactive Voice Response (“IVR’) system that will provide additional voice to dialogue features
for an enhanced IVR customer experience.
The Company has introduced alternative means for customers to obtain care, including a
system to track social media to identify customer care complaints and to connect customers with
Customer Care agents for support. The Company has expanded the use of chat and instant
messaging for care. Altice now supports SMS and WhatsApp. Altice has made and continues to
make substantial investments in its chat fiinctionality through “LivePerson,” a program that
enables Suddenlink customers to contact the Company via chat for any assistance they need.
Altice is beginning to see the irnpact ofthe improvements to care and field service and
observed a substantial drop in calls in Q2 202 1 compared to Q4 2020. Nevertheless, the
Company has continued to experience temporary setbacks in the care space. In February and
March of 202 1, the Company saw some technological issues with the implementation of the
phone system upgrades referenced above, which resulted in increased hold times and call
abandonment rates. These issues were resolved and performance on these metrics was greatly
improved from April through June (see Response to No. (viii) below).
-6- CASE NO. 21-0515-CTV-SC-GI
SUDDENLMKWVPSC003 64 1
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In July 2021, Intelcia made some changes to its delivery model and the allocation of work
across its call center vendor n e t ~ o r k . ~ These changes resulted in a temporary reversal in these
call abandonment rate and handle time improvements due, in large part, to a greater than normal
number of new hires during this transition and inefficiencies associated with their development.
The Company is addressing this issue by prioritizing training and coaching for these new agents
and is working diligently to steer customer care back on a trajectory towards improvement.
Already, it is seeing results from these efforts, as there has been a steady week-over-week
improvement in average speed of answer throughout the month of August.
While Altice believes that its care model has the ability to deliver excellent service to
consumers, it is constantly re-assessing its service delivery models in response to performance
metrics and customer feedback.
The Company is currently in the process of transitioning from a BPO staffing and
compensation model focused on “interval hours” (i.e., the number of agents available to serve
customers during particular time periods) to a “full schedule” approach in which Altice also
forecasts and builds into the model additional headcount needed to offset agent attrition and
absences (e.g., agents calling in sick), as well as scheduled agent time spent off the phone. For
example, under th s new model,
training and coaching rather than handling customer calls. The Company believes that this
transition, which will start in the 4‘h quarter of 3021 with anticipated completion in the first
quarter of 2022, will improve efficiency around average handle time.
of an agent’s monthly scheduled hours will be devoted to
At the same time, training for new technical support agents is being redesigned to focus
on the critical skills required to resolve a customer’s service condition by providing a deep
understanding of the products offered, service delivery and fail points, common solutions for
service issues experienced and the proper systems and tools used to repair. Enhancements include
increased instructor-led course material supported by hands-on activities using simulations that
re-create “real life” interactions. These guided simulation activities provide agents the knowledge
required to diagnose and resolve a service problem. The Company is also increasing the time
‘These call center vendors are known as Business Partner Organizations or “BPOs.” -7-
CASE NO. 21-05 15-CTV-SC-GI
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agents spend in the transition “nesting” period between the end of training and when they begin to
take customer calls independently to hrther support agent development.
Finally, the Company has improved its Voice ofthe Customer (“VoC”) program, which
consists of post-transaction surveys in which customers are invited to provide feedback on the
service they received following a customer care or other interaction (e.g., field operations or retail
store). The surveys contain questions related to “likelihood to recommend,” satisfaction with
agents and certain agent attributes (e.g., resolved requestianswered question, understood
needslknew what to do, listenedreally wanted to help), and provide the opportunity for customers
to leave unstructured feedback. Survey data is aggregated and reported throughout the
organization and overall customer satisfaction (“OSAT”) is measured and used by the care
organization for improvement targeting and coaching at individual employee levels. Customer
service OSAT scores have improved steadily throughout 2021.
Altice continues to invest in customer care and expects to see substantial improvements to the
customer experience soon as a result of these initiatives.
INVESTING IN WEST VIRGINLA NETWORK
While the Company recognizes that it has faced challenges in its delivery of field services
and customer care, Altice is committed to ensuring that West Virginia residents enjoy reliable
television (as well as Internet and voice) service. Consistent with its obligations under W. Va.
Code 5 24D-I-I4(a), Altice offers safe, adequate and reliable service to more than 300,000
households and small businesses in West Virginia on Suddenlmk’s upgraded, fiber-rich hybrid
fiber optic-coaxial (“HFC”) network with more than- plant miles and 8 headends’ across the
state. Altice continues to invest in its network and spends millions of dollars in the Suddenlink to
upgrade and improve network infrastructure in West Virginia.
Since 2019, the Company has spent at leas- on completed network projects in
the state, including replacing cables and connectors, replacing or repairing amplifiers, weather
sealing the plant, improving and addressing signal leakage, plant upgrades, node splits, and
’ Headends are facilities that accept TV signals as input from satellites, process them into cable- quality signals, and then distribute them to homes and cable networks.
-8- CASE NO. 21-05 15-CTV-SC-GI
SUDDENLNKWPSC003 643
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upgrades to power infrastructure, and transport, routing and switching equipment. See Response
to (i). These investments directly benefit cable television subscribers and improve the reliability
of that service. For example, capacity management upgrades benefit two-way communication by
improving the hnctionality and reliability of cable television service features, such as video on
demand (“VOD”) and multi-room DVR (“MR-DVR’) service. Upgrades to market routers-
which channel internet and television signals into a specific market-have also helped to improve
reliability of the video network and services by adding more pipelines for video flow. It also
allows Altice to add more features l k e MR-DVR and VOD and additional channels. Likewise,
upgrades to pipeline equipment - for example, putting in new amplifiers - or splitting nodes
benefit Suddenlink cable TV service by improving system resilience and reliability and increasing
the number of channels that are potentially available.‘ See also Bates Nos.
SUDDENLINKWVPSC002022-SUDDENLINKWVPSCO02028.
Altice continues to invest in the Suddenlmk network in West Virginia. The Company
currently projects total investments of more than= = on pending network enhancement
projects in West Virginia for the remainder of 2021 through 2022 similar to those described
above. As with completed projects, these ongoing network enhancements will continue to
improve the resilience and reliability of cable television service.
Lkewise, upgrades to internet service (for example, the availability of 1 Gig service to 90% of homes passed in West Virginia) deliver added benefits to Suddenlunk subscribers that bundle cable and internet services. Cable subscribers receive access to the Altice One TV App, which enables them to enjoy the Suddenlink entertainment experience from any device. Suddenllnk customers can watch Live TV and on Demand content and stream DVR recordings from any device. Network enhancements improve the reliability and performance of the Altice One TV App in the home and on the go when connected to Suddenlink hotspots.
-9- CASE NO. 2 1-05 15-CTV-SC-GI
SLDDENLMWVPSC003644
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RESPONSES TO SPECIFIC REQUESTS IN ORDER TO SHOW CAUSE
i) A list of the projects that S u d d e W has completed in West Vir+ since 2019 to
repair, expand or improve cable television service, explaining the location and
purpose of each project and identifying the moun t of the investment m d e in each
project.
ESPONSE TO NO. (i)
Altice continries to invest in and improve its video service. M i c e has spent at least = on network infrastructwre projects in West Virginia since 20 19. As explained above,
Suddeddc cable television is transmitted on the same network as internet service. Thus,
upgrades to the network lufrastructure siLguflcantly benefit cable television subscribers because
they enhance rehab&@ and resilience for all customers. The tabIe bebw reflects m y of these
investments’ :
A c h e replacement projects serve to change the arnplrfiers that generate signals, including
teIeevlsion signals, or upgrade the fiber optic nodes, unprovmg the ability of the sqnals to travel
dlstauces and enhance theE overall reshence. Inside Plant projects serve to upgrade the
equpment w i d e the headend facrfrties to dehver and support the dehvery of semces over the
network. Upgrades to hckend equipment like lasers and transmitters unproves the efficiency of
the sicpal. Upgrades to the outside plant (Plant UpFades) rnclude upgrades to the aenal portion
of the network (ie.. pok to pole), underground, and buildings, include upgtrades to the fiber.
-I In addition to the investments kited in the table, Suddenlink spent an additional approximately c: routmo switching equpment. All of these mvestments in eclurpment benefit the delivery of cable television senices because they mpmve the backbone connections m West Virgllua improving the reliability and the resihence of the delivery of the television signal across the network.
since 20 19 on upgrades to the power inkastructure and to transport and
-10- CASE NO. 2 f-05 15-CT\--SC-GI
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coaxial cables, amplifiers, nodes, power supplies, and associated equipment located outside the
headend facility. Node Splits add additional nodes and receivers to reduce congestion and
performance in a geographic area. Such projects include upgrades on the outside plant as well as
inside the headend facilities, but are accounted and budgeted for separately from other Outside
Plant and Inside Plant upgrades. Finally, expenditures in new builds include projects to pass new
homes, building out underground and aerials to provide service to new areas.
We submit a list of Suddenlmk projects to repair, expand or improve cable television
service in West Virginia since 2019 in a spreadsheet labeled with the Bates Nos.
SUDDENLINKWVPSC002396-SUDDENLINKWVPSC002396. The tab labeled ”Proj Lists &
Pivots” includes the purpose of each project, the location, the start and completion dates for each
project, and the total cost of each project. The tab labeled “Summary by Year” summarizes this
information .
ii) A schedule of ftiture projects that will improve cable television service in West
Virginia with the same detail required for completed projects.
RESPONSE TO NO. (ii)
In addition to the completed investments described in the Company’s Response to No. (i),
the document submitted with the Bates No. SUDDENLINKWVPSC002396 identifies ongoing
network improvement projects in West Virginia and states the purpose of each project, the
location, the start and projected completion dates for each project, and the total estimated cost of
each project. As detailed in this document, Altice anticipates investments totaling more than= - in ongoing projects to improve the Suddenlmk network through 202 1 and 2022.
The Company continues to invest in new technologies to enhance the customer experience
in the home. In addition to network infrastructure upgrades and improvements, the Company has
made its Altice One enhanced television experience available to approximately 80% of West
Virginia customers since its introduction in February 2020. Altice One includes an all-in-one
gateway device and user interface that integrates traditional cable with over the top video service
and allows customers to stream apps llke Netflix, YouTube and Prime Video, watch live TV and
-1 1- CASE NO. 21-05 15-CTV-SC-GI
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On Demand anywhere in their home using WrFi, and manage DVR recordings anywhere on-the-
go (among other features).
-12- CASE NO. 21-05 15-CTV-SC-GI
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iii) A list of each outage in cable television service provided in West Virginia from
January 1, 2019, to the present, including the date(s) and time period, number of
customers affected, and cause and resolution of each outage, and a copy of each
written notice that Suddenlmk provided to the Public Service Commission from
January 1, 2019, to the present when service was not timely restored following an
outage.
RESPONSE TO NO. Ciii)
As described in Suddenlink’s response to Staff Request No. 1.44, the Company learns
about service interruptions and outages in the Suddenlink network via several mechanisms,
including: (1) alarms, (2) functional group notifications, (3) call volume/customer interactions,
and (4) third party notifications.
The document submitted with the Bates No. SUDDENLINKWVPSC002400 lists all NOC
tickets relating to service interruptions and outages that may have impacted cable television
services in West Virginia since January 1, 2019.8 For each ticket, it lists the issue (e.g., all
services out, channel problem), the symptom (e.g., modem offline), the duration and cause of the
interruption or outage (e.g., utility power outage, stonn/lightning/wind damage) and the total
number of impacted subscribers. Most of these interruptions and outages are for less than 24
hours, with an average duration of- In addition, the document reflects many outages
and interruptions that: (i) could not be restored until another company repaired its facilities (e.g.,
outages caused by utility outages), (ii) were due to storms or other weather events, and/or (iii)
were reported to the NOC as potential interruptions or outages but either no trouble was found
(‘%TF”) or the issue was found to have been resolved when field technicians investigated.
Removing these categories (less than 24 hours, utilitykhird party facility restoration,
severe weather, NTF), Altice has identified -outages that potentially impacted cable television
service in West Virginia. See Bates No. SUDDENLNKWVPSC002399. As indicated in
Column B of the “Export Worksheet,” the vast majority of these identified outages indicate
’ This mcludes a significant number of tickets tagged as relatmg to issues with “Internet/Voice/Interactive Services,” rather than video service or all services
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“internethoicehteractive services out.” and the exact impact of these outages on cable television
service is unknown. Only= of the
tagged as “All Services Out” and onlymoutages as “Video Service Out,” as shown in the
screens hot below:
outages identified as lasting for more than 24 hours are
It is Altice’s standard business practice to notify the PSC regarding outages exceeding 24
hours due to extenuating circumstances. Such notice is typically provided to the PSC’s
Telecommunication and Cable TV Supervisor either verbally or via e-mail.
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iv) Suddenlmk’s process or system to open trouble tickets and track and identify
outages, including an explanation of why trouble tickets are not generated in
response to all subscriber calls that report an outage.
RESPONSE TO NO. (iv)
See Response to No. (iii), above and Suddenlink’s response to Staff Request No. 1.44.
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v) The training program, number of field service employees and the number of contract
personnel who are assigned to work exclusively in West Virginia, where such
employees and contract personnel are based in West Virginia, the number of people
based at each location, and the turnover rates for such employees and contract
personnel.
RESPONSE TO NO. (v)
As stated in response to Staff Request No. 1.37, Altice has a comprehensive training
program for field service employees and contractor personnel. For in-house technicians, Altice
has a field organization training team that is responsible for developing all curricula and
certifying completion before a technician starts in the field. All training programs are stored
centrally and pushed to techs through in-house tools.
All vendor technicians employed by contractors are required to complete virtual training
courses offered by CATV, a third-party service provider, and must be trained in accordance to
industry standards for cable television. For information specific to Suddenlmk, Altice uses the
“train the trainer” model whereby it trains the contractor’s trainers and those trainers are then
responsible for training the technicians. Updates and additional readiness trainings will be
pushed to the contractor trainers to convey to the technicians.
In addition to training, technicians are monitored for performance. Altice uses scorecards
to monitor in-house technicians. Low performance technicians and outliers are monitored and a
dedicated quality control team at Altice conducts random quality control checks for all in-house
trainers. Contractors monitor their employees similar to the in-house monitoring Altice conducts
on its o w n employees.
The Company provides in response to Staff Request No. 1 .11 the number of field service
employees and contract personnel assigned to work in West Virginia and the number of people
based at each location. In t e r n of turnover, the field services organization had two employees
leave in 2019, 14 in 2020 and two in 202 1 across a variety ofjob hnctions (including clerical,
business systems analyst and administrative roles.) As noted above, Altice continues to expand
-16- CASE NO. 21-05 15-CTV-SC-GI
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its team of field services personnel and is currently onboarding 14 contractors and has 6 FTE
openings.
Altice does not have any field service employees or contractors based in other states that
perform a significant amount of work in West Virginia. However, in the event of an emergency
(e.g., a weather event), Altice may bring additional field service employees and/or contract
personnel from other states to temporarily assist in West Virginia.
-17- CASE NO. 2 1-05 15-CTV-SC-GI
SUDDENLRKWSCOO3652
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vi) The same information requested in v) above for field service employees and contract
personnel who are based or located in another state and perform a significant amount
of work in West Virginia.
RESPONSE TO NO. (vi)
See the Response to No. (v), above, and to Staff Request No. 1. I 1.
-18- CASE NO. 2 1-05 15-CTV-SC-GI
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vii) The location and hours of operation for each business office kt West Virginia,
number of personnel assigned to each office, the ntunber of personnel who are
Suddenlink employees, number of personnel who provide service by contract, and
the types of services provided to subscribers in each Suddenlink business office.
RESPONSE TO NO. IviQ
In the table below, we provide the location of each Suddenlink business oftice, the hours
of operation for wak-in retail locations, the specific services prowled to comimrs , the nimber
of employees and contractors associated with that location (where applicable). WMe we
understand the PSC’s request to be focused primarily on walk in retail Iocations, the chart
identifies a number of different types of facihties in West Vir_girua. including walk in r e t d
locatiom, ofGces (e+.. for sales team), engineering and field opemtion facilities, and
headendhub sites delivering cable TI’ service to end users.’
Suddenlink Business Offices 0
I existioe customer
Headends and hubs are facilities that accept T?’ sip& as mput from satehtes, process them into cable-quality signals, and then distribute them to homes and cable networks. The hsted headendihub locations iu West Vir-+a do not have employees or contractors associated with them
-19- CASE NO. 2 1-05 1 jCTC’-SC-GI
SUDDENLLVKWVPSCOO3654
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1 Elkins - 1513 Harrison Ave
-20- CASE N-0. 2 1-05 15-CW-SC-GI
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Wayne Tech Ops 2 field Operations -707 Terrace Drive 1 Narrows Hub - 223 Aspen Ln
HE/HUB site delivering Cable lV
-21- CASE XO. 2l-OGl5CTV-SC-GI
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Elkins HE - Rich Mount Rd ifleverhr. WV)
HE/HUB site delivering Cable R/ services t o end users
Chelyan - 14997 McCorWe ave (Cabin Creek
HE/HUB site delivering Cabte TV services to end users
Elkview - 5007 Elk River Rd
HEJHUB site delivering Cable TV
Pleasant S t delivering Cable TV I services to end users
Logan - Whftrnan Rd
HE/HUB site delivering Cable TV services to end users
Madison - 139 HEmUB site state st deljvering Cable N
services to and users Milton - 1406 I PikeSt
HE/HUB site delivering Cable N
Legends Hwy I I delivering Cable W services to end users
Princeton - 886 HE/HUB site Old Gardner Rd delivering Cabfe lV
services to end users Shinnston - Adarnsviile Rd
HEIHUB site deiivering Cable TV services to end users
St. Albans - 213 Swan Lane St
HEIHUB site delivering Cable TV services to end users
CASE NO. 2 f -05 1 SCT%--SC-GI
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St. Marys - 405 Cheny St
HE/HUB site delivering Cable TV
Williamson - 2341/2 Parkway Dr
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HE/HUB site delivering Cable TV services to end users
CASE NO. 21-05 15CTV-SC-GI
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1" Bill Question
viii) The asmuid call logs and records of customer complaints relating to cable television
service &om the last five years, If available, but, no less than the two years as
required by W. Va. Code 5 24D-1-19. RESPONSE TO 30. (a)
Altice maintains records of customer complaints consistent with W. Va. Code 5 24D- 1 - 1.
First, Altice maintains records of all customer service interactions. Call recordings are
maintained for a period oftwo years. In addition, as noted in response to (iii) above, a DSTX
ticket is created every time a customer calls customer service - whether or not the call involves a
complaint. Customer interactions are tracked via issue. cause and resolution codes that are
manually q u t into the DSTX ticket by the care agent and associated with the customer's
account. The following example illustrates various possible cause and resolution codes for billing
related issues.
Customer Education Balance inquiry Billing Address
Name Change Reauest
Advise of Balance Update Billing Address
Transfer to Sales
These codes enable Altice to track and cate3orize the issues customers raise, inclxidmg but
not limited to complaints relating to b i lhg , service or other issues." For fixed residential
services, inc luhg cable television service, the care organization tracks more than one hundred
codes.
One of the resohition paths for interactions that do involve a customer complaint
(assuming the issue cannot be resolved by the agent on the call) is to escalate the ticket to !&ice's
Customer Escalated Complaint Review ("CECR") team for handling. This CECR team is also
responsible for handling all complaints received from an outside agency (e.g7 the PSC, Attorney
General) or send by a customer directly to an M i c e executive outside of the care organization.
lo DSTX Tickets are overinchisive m that they track and code all customer interactions, not merely complaints. None of the code combinations in the 'Tssue, Cause and Resohtion Codes" table above would be reflective of a complaint.
-24- CASE NO. 3 1-05 1 S-CTc--SC-GI
SEDDENLINKWWSC003659
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The CECR team investigates and seeks to resolve these customer complaints and
maintains a record of them in a separate ticketing system known as an ”AFEC” ticket.” The
CECR agent creating the AFEC will apply issue and sub-issue Codes to the AFEC.
Attached as Bates No. SUDDENLINKWVPSC00240 1 ~ we provide a spreadsheet
containing a log of all AFEC ticket level complaints involving West Virginia cable television
customers from July 2018 to the present. This log includes complaints received from the PSC as
well as other agencies (e.g., West Virginia Attorney General, Federal Communication
Commission, Better Business Bureau) during this period.’’ As of August 2, 2021, Altice USA
has resolved over 98% of these complaints with the remainder still under investigation or pending
customer confirmation. In many circumstances, a credit was appliedi3 and, in other
circumstances, Suddenlmk sent a tech to the customer location, engaged in customer education to
ensure that the customer was properly using the service, explained the bill to the customer,
applied a promotion, or otherwise communicated with the customer regarding the complaint.
The Company has recognized the need to improve the customer experience in West
Virginia, including customer care. In spite of these efforts, the Company observed a marked
increase in the volume of complaints in 2020 due to a variety of factors such as the impact of the
COVID- 19 pandemic, severe weather and system integration issues.
While there is still work to be done, Altice saw some improvement in the frst and second
quarters of 202 1 as reflected in the chart below, with complaint volume for January - April 2021
largely returned to pre-pandemic levels. Unfortunately, the Company has observed a slight
increase in West Virginia complaints between May 202 1 and July 202 1. However, even then, the
I i Altice recently transitioned to Remedy as the tool for coding and tracking escalations. “AFEC” refers to the system in place through the Spring of 2021. I’ As substantial number of the AFEC tickets opened during this time period are unrelated to the delivery of cable television service. For example, (internet) or voice services, l A F E C s related to ‘ Bi ing i ssues ,”mAFEC’s related to “Fees,” while another related to a general mixture of “Customer Experience” or ”Appointment,” issues and other categories.
As described in more detail in response to Staff Request 1.59, since September 2019, Altice has issued approximately - in customer satisfactiodgoodwill credits to West Virginia customers.
AFEC’s related to issues with data
-25- CASE NO. 21-05 i5-CTV-SC-GI
SUDDENLNKWVPSC003660
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number of complaints received m July 202 1 represents a drop year over year compared to
h ly 2020 complaint vohune.
:
-26- ~~
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ix) Suddenlurk’s current organizational structure.
RESPONSE TO NO. (ix)
In December 2015, Altice USA, Inc. acquired Cequel Corporation and its subsidiaries
doing business as Suddenllnk Communications. In June 2016, Altice USA, Inc. acquired
Cablevision Systems Corporation and its subsidiaries, which included CSC Holdings, LLC,
which is the operating entity for the Optimum service area. In November 20 18, the
CequeYSuddenllnk entities were moved underneath CSC Holdings, LLC. Since then, CSC
Holdings LLC has also been the operating entity for Suddenlmk. Suddenlink Communications is
a dba used by several CSC Holdings subsidiaries, including the operating entities offering
Suddenlurk services in West Virginia:
0
0
*
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ARH, Ltd d/b/a Suddenlmk Communications
Cable Systems Inc. d/b/a Suddenlink Communications
Cebridge Acquisition, LLC d/b/a Suddenllnk Communications
Cequel I11 Communications I, LLC d/b/a Suddenlink Communications
Cequel I11 Communications XI, LLC d/b/a Suddenlink Communications
Hornell Television Services, Inc. d/b/a Suddenlink Communications
As stated above, from December 2016 through November 2020, ATS, the Altice operating
division focused on the delivery aspects of Altice’s operations, including network engineering
and construction, plant maintenance and field service. In November 2020, in the aftermath of
challenges arising from the COVID- 19 pandemic and severe weather events, ATS was dissolved
and field operations were reabsorbed into Altice USA under the leadership of Pragash Pillai.
Altice’s majority-owned subsidiary Intelcia operates and manages nine call centers and
two live chat agent locations that serve Suddenlink and Optimum customers nationwide,
including West Virginia cable subscribers.
The current corporate organizational structure for Altice USA, Inc. and its subsidiaries is
attached as Bates Nos. SUDDENLINKWVPSC002 166-SUDDENLINKWVPSCOO2179.
-27- CASE NO. 2 1-05 15-CTV-SC-GI
SUDDENLLVKWVPSC003662
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x> a copy of all Suddenllnk fianchises for cable television service in West Virginia
currently in effect,
RESPONSE TO NO. (x)
Copies of Suddenlink franchise agreements that are currently in effect for cable television
service in West Virginia are attached with the Bates Nos. SUDDENLINKWVPSCOO1162-
SUDDENLINKWVPSCOO153 1 and SUDDENLINKWVPSC002554-
SUDDENLINKWVPSCO03 63 5.
-28- CASE NO. 21-0515-CTV-SC-GI
SUDDENLNKWVPSCOO3663
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xi) supporting data for the statements made in the June 7,202 I letter to Chairman Lane,
RESPONSE TO NO. (xi’)
As stated above, the Company has experienced challenges with field service delivery and
customer care since 2019 and has invested significantly in improving the network, field service
and customer service delivery to improve the overall customer experience for customers in West
Virginia. In the June 7 Letter, Altice acknowledged that despite these efforts, issues such as the
COVID- 19 pandemic, severe weather events, and systems integrations challenges all exacerbated
the challenges the Company was already facing in the state and contributed to a spke in customer
complaints. However, the Company took notice of these issues and has worked to get on track
since then.
The Company is investing heavily in its network, field service, and operations in West
Virginia while, at the same time working to improve the field service and customer care
organizations. Details regarding the Company’s network and service investments in West
Virginia are provided in response to Numbers (i) and (ii) above. Additional details on challenges
the Company faced in 2020 and improvements it has made to field services are provided above.
See pages 2-5, above. As stated in response to Request No. (viii), the complaint volume has been
trending down overall from peak in 2020, when Altice, l ke other companies faced unprecedented
challenges.
Altice has focused on improving on-time arrival by technicians and improving the quality
of repairs, reducing the need for repeat visit. As a result of these improvements, customers are
calling less frequently because the repair was done right the first time and field customer
feedback has risen for interactions with Field Service technician. See page 5 , above.
-29- CASE NO. 21-05 15-CTV-SC-GI
SUDDENLINKWVPSCOO3664
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Additionally, AItice stated in the Jime 7 Letter that key service d i ca to r s for West
Virgmia customers had improved dramatically in recent quarters as result of the Company’s
network and service investments and improvements; indicating, for example, that the Company
was then responding to substantially more than=ofcustomer telephone calh within 30
seconds and had many fewer than- of calls abandoned. Thts statement is supported by &e
folIowmg average speed to answer (“ASA”) and abandonment metrics for -4pril- June 202 1 :
As noted above, the Company saw a reversal of these improvements in July, primarily as a
result of a re-allocation of work across Intelcia’s call center network which led to a greater than
normal number of new hires. The Company is addressing these issues by prioritizing training and
coachlng for these new agents and has already observed a week-over-week mprovement in ASA
in the month ofAu_mst. Altice continues to invest heavily in mpro-r;mg customer care resources
to create sustainable, long-term improvements that will bene& Suddenlink customers in West
Virginia, including by m v k g to a full schedule BPO call center staffing and compensation
model that Eictors tzl additional headcount for attrition and absertces as well as additional hours
for agent training.
-30- CASE NO. 2 1-05 1 S-CIc’-SC-GI
SUDDENLINKWTSC003665
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xii) the location, hours of operation, and number of personnel assigned to each back
office in which a customer service representative is available to receive calls from
Suddenlmk subscribers, the number of back office personnel who are Suddenlunk
employees and the number of back office personnel who provide service by contract,
RESPONSE TO NO. (xiQ
Altice uses a combination of in-house and external resources to provide call center and
live chat agent support to its Suddenlink customers, including those in West Virginia. This model
allows Altice to respond flexibly to call volumes and customer needs across its multistate
footprint .
Altice maintains a total budgeted headcount of 67 agents on its CECR team (described on
page 25 above), comprised of 15 internal Altice employees based in Jericho New York and 52
contracted agents based in Cairo E g s t . The CECR team resolves customer complaints that
cannot be resolved by an agent on the call. lJ
Through its subsidiary Intelcia, Altice operates an internal call center in Tyler Texas
staffed by 82 employees that support West Virginia customers. Intelcia contracts with and
manages various third-party BPO vendors that operate eight additional call centers providing
service to Suddenlmk customers in West Virginia.” In addition, Altice has a contractual
relationship with a vendor, Live Person, to provide live agent online chat support. LivePerson
manages two locations with agents that provide live online chat support to Suddenlink customers
in West Virginia.
Agent headcount in these additional call and chat center locations is variable and designed
to fluctuate based upon anticipated call volume: seasonality and other factors. l 6 As of June 202 1,
l 4 The CECR team is also responsible for handling all complaints received fiom an outside agency such as the PSC or an Attorney General and complaints sent by a customer directly to an Altice executive outside of the care organization. ‘j These BPO vendors currently include iTel, UX Centers, ERC and Emergia. .h In the normal course, various factors may impact call volumes, such as deployment of a major new product initiative, billing changes or severe weather events. In 2020, multiple factors associated with COVID- 19 also impacted Altice’s internal and external customer service operations and presented temporary challenges to handling increased call volume. These issues
-31- CASE NO. 21-05 15-CTV-SC-GI
SUDDENLINK%?IPSCOO3666
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a total of 4,767 external (BPO) agents were avdable to &e Suddenlink customers in West
ViTginia.
The locations of the call centers that serve Suddenlmk customers in West Virginia are
listed below.
The locations of the Live Person managed live chat agent locations that serve Suddenfink
customers in West Virginia are listed below:
LP Bogota (Outplex) Calle 8912-56 Coiom bia Torre de Cristal, Av.
LP Santo Domingo {Outplex) llradentes #49 Dominican Republic
In the chart below, ,Wee provides the hours of operation of each call center and h e chat
agent site supportins West Virginia customers.
were addressed by adding hmdreds of additional call center resources serving West VirgirUa. Suddenhk customers between January and October 2020.
-32- CASE XO. 2 1-03 15-CTv-SC-GI
SUDDENLMWVPSC003667
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Eel lntefcia Montego Bay (iTel) 7:OO AM 12:OO A M
lntelcia Kingston (iTel) 7:OO AM 12:OO A M
lntelcia Santo Doming0 (ERC) 8:OO A M 8:OO PM ERC
lntelcia South Africa (ERC)
8:OO A M 8:OO PM
lntelcia Sabaneta (Emergiaf 12:OO AM
tntelcia Tyler 7:00AM I 11:OO PM
LP Bogota (Outplex) 12:OO AM 12:W A M LP Santa Dminirro IOutulexl 12:OO A M 12:OO A M
lntelcia USA
Emerge/LivePerson (Outplex)
In additioa, the hours of operation for the CECR team located in Jericho New York are
9:OO AM - 6:OO Pbl.
-33- CASE NO. 2 1-05 15C’l3--SC-GI
SUDDENLINKWVPSC003 668
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xiii) the basis for Suddenlmk’s requirement that customers who report an outage of cable
television service make a second phone call to request a bill credit that is required
by W. Va. Code 9 24D-1-17, RESPONSE TO NO. (xiii)
Altice maintains a Contact Center Credit Policy with a built-in credit-decision tool
(“IBA’)), enabling customer care agents to make fair and consistent accommodations for
Suddenllnk customers. See Bates Nos. SUDDENLINKWVPSCOO2110-
SUDDENLINKWVPSC002114. The customer care agent will use the IBA credit-decision tool to
evaluate whether the customer is eligible for a credit. An automatic $20 bill credit will be
approved (without the customer having to make a second call) if the outage has been (or was)
open for longer than 24 hours as of the time of the call.
Below, we provide a screen shot of the outage credit process for West Virginia which
shows that an automatic $20 bill credit will be approved if the outage has been (or was) open for
longer than 24 hours as of the time of the call.
-34- CASE NO. 2 1-05 IS-CTV-SC-GI
SUDDENLTNKWSC003669
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As described in more detail in response to Staff Request 1.59, Altice has issued-in
service interruptiodservice problem related credits to West Virginia subscribers since September
20 1 9.17
’ An additional -in customer credits were coded as “customer satisfactiodgoodwill” rather than service mterruption or problem by the care agents. Some percentage of these credits were llkely storm or outage related as well but a more generic customer satisfaction credit code (e.g., “billing correction”) was used by the care agent to apply the credit.
-35- CASE NO. 21-0515-CTV-SC-GI
SUDDENLINKWVPSCO03 670
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I
I
xiv) the date and location of a call center to be established in West Virginia, and
RESPONSE TO NO. (xiv)
Altice does not currently have plans to establish a call center location in West Virginia.
Call center resources are managed for the benefit of all Altice USA customers (in both the
Suddenlink and Optimum footprints) by Altice’s subsidiary Intelcia. Through Intelcia, Altice
operates and manages nine call center and two live chat agent locations that serve West Virginia
cable subscribers. The current collective employee and contractor headcount for these locations
is over 4,800 agents and Intelcia’s business model allows for the rapid expansion of the agent
pool if deemed necessary based on forecasted call volume.
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xv) whether phone calls made by Suddenlmk to its subscribers may be identified
as coming from Altice or Suddenlink on caller identification service.
RESPONSE TO NO. (xv)
The Company is reviewing and updating its Caller ID displays to ensure that calls placed
to Suddenlink customers by various departments (including care, sales, field and collections)
andor the Company’s BPO call center vendors reflect either the Suddenlink or Altice USA name.
(Certain groups, such as CECR, call Optimum as well as Suddenlmk customers and, as such,
require an Altice USA display.) In certain circumstances, the caller ID display will not identify
either Suddenlink or Altice USA. For example, when a contractor (i.e., non-employee) field
service technician calls a customer, the contractor’s caller ID would be displayed.
SUDDENLIYKWVPSCOO3672
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CEBRIDGE TELECOM WV, LLC dba SUDDENLINK COMMUNICATIONS
By Counsel
David B. Hanna, Esq. (WVSB ## 88 13) Thomas N. Hanna, Esq. (WVSB ## 1581) Hanna & Hanna, PLLC P.O. Box 3967 Charleston, WV 25339 thaima(u'hannalau.pllc.com dhannaiz, hannalawp llc. corn
Dated: August 3 1, 2021
-38- CASE NO. 2 1-05 15-CTV-SC-GI
SUDDENLTNKWTSC003673
CERTIFICATE OF SERVICE
I, David B. Hanna, counsel for Cebridge Acquisition, LLC, Cequel Ill
Communications I LLC, and Cequel Ill Communications II LLC, dba Suddenlink
Communications (“Suddenlink”), hereby certify that copies of the foregoing Response of
Suddenlink Communications to Commission Order issued July 1, 2021, have been
served upon the following, by United States first class mail, postage prepaid, this 3Ist day
of August 2021
Linda Bouvette, Esq., VIA HAND DELIVERY Brooke Hirst, Esq. Legal Division Public Service Commission 201 Brooks Street Charleston, W 25301 I [email protected]. us [email protected]
Heather B. Osborn, Esq. VIA HAND DELIVERY Consumer Advocate Division 300 Capitol Street Suite 810 Charleston, W 25301 [email protected]
Robert R. Rodecker, Esq. John R. McGhee, Jr., Esq. Counsel, Cities of Beckley, Charleston and Elkins Kay Casto & Chaney PLLC PO Box 2031 Charleston, WV 25327 rrod ec ke r@ kavcast 0. co m jmcg [email protected]
Andrew T. Gunnoe, Esq. Kanawha County Commission PO Box 3627 Charleston, W 25336 [email protected] I/
DAVID B. HANNA