AT&T has sent the Federal Communications Commission a bait and switch checklist that, despite the stated purpose of modernizing telecommunications networks, would also allow the company to completely abandon its landline network and win near-complete deregulation of its broadband service.

On Tuesday, August 28, Christopher Heimann and I met with Matthew Berry and Nicholas Degani, respectively Chief of Staff and Legal Advisor to Commissioner Pai, to discuss actions the Commission can and should take to facilitate the retirement of legacy TDM-based networks and services and transition to an IP-based Network/Ecosystem, consistent with federal policies and objectives, including those enunciated in the National Broadband Plan.

At the request of Commissioner Pai, AT&T has prepared and is submitting herewith a checklist of those actions, which identifies the critical first steps the Commission should undertake without delay to begin the transition as well as additional steps that would facilitate completion of that transition.

Under the existing statutory and regulatory framework, carriers already can undertake the steps necessary to make the transition, including, in some cases, steps requiring Commission approval (such as withdrawing legacy TDM-based services). But, insofar as the transition raises a number of novel and likely contentious issues, Commission action on the items included on the attached list would greatly facilitate and thus hasten completion of the transition. The steps we identify implicate an array of issues raised in the above-referenced dockets. Accordingly, we are filing the checklist in each such docket.

Respectfully submitted,

Robert W. Quinn, Jr.

AT&T’s letter and attached checklist are documents only a policy wonk or careful observer of Big Telecom could easily navigate. Despite the thicket of opaque terms like “TDM” and the not-immediately-apparent importance of the difference between an “information service” and a “telecommunications service,” AT&T has, to borrow a phrase from President Obama, some brass ones making its intentions perfectly clear.

With the help of Bruce Kushnick, executive director of New Networks Institute and a former telecom industry insider, we will guide you through AT&T’s filing and what it really means.

AT&T lists several “critical first steps” (we have put them in bold) to achieve the transition to an all-IP telecom world, retiring the traditional “public switched telecommunications network” (PSTN) which you know better as a landline.

1. Establish a date certain for an official TDM-services sunset, after which no carrier would be required to establish and maintain TDM-based services/networks, and purchasers of such services (including circuit-switched and dedicated transmission services) would have to switch to IP or other packet-based services.

No casual observer of FCC filings would be expected to understand the implication of setting a date to officially sunset “TDM services.” TDM is synonymous with the landline network Ma Bell established more than 100 years ago — the one that gives you a dial tone, DSL, and access to dial-up Internet where broadband is unavailable. AT&T wants the FCC to manage what the company has not been able to consistently accomplish on the state level: setting a final date when traditional landline service can be permanently disconnected, preferably at the convenience of the phone company.

2. Clarify that any state requirements forcing service providers to maintain TDM networks and services […] following the TDM sunset are preempted. Such requirements could deter investment in broadband, and thus are inconsistent with and pose an obstacle to federal law and policies encouraging the transition to all IP networks and services.

This provision would effectively eliminate any existing state laws or regulations that require AT&T to deliver a fairly-priced, well-run landline service for customers throughout its service area. Some states have not bought into AT&T’s lobbying juggernaut, often delivered with the help of the American Legislative Exchange Council (ALEC). Despite the enormous sums spent lobbying legislators, some states have kept oversight in place requiring AT&T to serve everyone that wants phone service. With this provision, those state laws and regulations would be pre-empted.

AT&T claims state requirements somehow deter broadband investment, a curious conclusion considering AT&T has already largely ceased its expansion of DSL and U-verse services.

3. Complete action in the IP-enabled services proceeding, and classify such services as information services, subject to minimal regulation only at the federal level. The Commission could permit service providers to offer DSL or other broadband transmission services on a common carrier basis if they so choose, but in no event should a provider be required to do so. 

Quinn

This is AT&T’s provision to kill regulation and destroy competition. Government rules, regulations, and oversight apply largely to “PSTN” landline services, not to IP-based or broadband networks. Basic landline service is designated a “telecommunications service” by the FCC, which makes it subject to regulator review. Broadband, on the other hand, and anything else using IP, is typically classified as an “information service,” where most oversight regulations do not apply.

AT&T’s plan is to shut down today’s landline “telecommunications” service in favor of IP-based Voice over IP, which would effectively reclassify your phone line as an “information service.” That means by changing just one word — “telecommunications” to “information” — AT&T can walk away from a century of basic consumer protection rules and regulations. AT&T also gets a divorce from its telecommunications service obligations as a “common carrier,” which requires AT&T to deliver service to any customer who requests it, at a fair and reasonable price, without changing its form or content.

If AT&T’s broadband networks were reclassified as a “telecommunications service,” Net Neutrality would be easy to enforce under the “without changing its form or content” provision of common carrier rules. Back in the 1996 Telecommunications Act, AT&T’s lobbyists had already made their mark, creating new “distinctions” of telecommunications services, some more regulated than others. Now AT&T is back to kill off the last regulatory obligations it still has to endure, taking Net Neutrality to the grave once and for all.

4. Reform Interconnection – after the official date for the TDM sunset, no carrier or other provider of TDM based services should be entitled to require others to interconnect in TDM. The Commission should take action to maintain the market-based, regulation-free interconnection regime that has applied to IP-based interconnection for decades.

[…] Reform wholesale obligations under section 251/271 to eliminate unbundling, resale, collocation and other requirements that could require ILECs to maintain TDM networks and services.

These particularly opaque sections give AT&T’s competitors real nightmares because they would wipe out requirements that phone companies open certain facilities to competitors who deliver services over AT&T’s network. If AT&T’s recommendation is adopted, no competitor would be safe if AT&T eventually padlocks access to its network.

But AT&T does not want its intentions to be that obvious. It throws a transparent bone to regulators to offer a facade of competition in both this and the preceding recommendation.

AT&T instructs the FCC it can mimic the time-honored patina of an open, competitive industry by allowing AT&T’s competitors to sell DSL or other broadband services over AT&T facilities, but only if AT&T feels like it (at comfortable prices that don’t undercut AT&T).

5. Eliminate regulatory underbrush/superstructure that accompanies TDM-based services. For example, phase out equal access, residual ONA/CEI, record-keeping, accounting, guidebook, dialing parity, payphone, and data collection (which should be limited to that which is collected on the Commission’s Form 477) requirements.

AT&T leaving town.

What AT&T calls “underbrush,” consumers and regulators call oversight and consumer protection.

“Sayonara any telco rules, regulations and oh yes, your rights,” says Bruce Kushnick. “Your service breaks… tough. Prices go up and there’s no direct competition — too bad. Networks weren’t upgraded — so what.”

Kushnick notes this provision would allow AT&T to avoid maintaining a public record of its performance (and its potential abusive practices, bad service, and high prices), including any requirement on the state or federal level to tell the public anything about how well we are being served by the wired monopoly.

Other things on AT&T’s hit list: “Equal Access,” which opened the door to competitive long distance calling and lower rates, “Dialing Parity” which lets you avoid dialing ten (or more) digits for every call (or being forced to learn more complicated numbers for things like directory assistance or other shortened dialing numbers), and public payphones. AT&T’s desire to kill off “residual ONA” refers to the costs to establish Open Network Architecture — the framework for opening up the nation’s phone monopoly for competition. Re-establish the monopoly and there is no reason to fret about the costs to maintain access for competitors AT&T will eventually eliminate.

6. Further reform USF to provide support for broadband regardless of the regulatory classification of broadband services, eliminate any obligation to offer such services on a common carriage basis to be eligible for such support, and provide incentives for service providers to invest and offer services necessary to ensure that no one is left behind by the transition to an all-IP, broadband ecosystem.

The reform of the Universal Service Fund has already opened up opportunities for rural telecommunications companies to apply for broadband infrastructure grants to expand broadband in rural America. Only AT&T has refused to participate in the current round of broadband grants because they do not like the rules. AT&T wants a free hand to receive broadband funding, so long as it faces no questions about where the money gets spent. Under AT&T’s recommendation, the company would receive money with no obligation to ensure everyone who wants broadband in rural America can get it. It also wants the government to hand out money to providers to implement their goal of regulatory nirvana — the conversion of basic landline service to Voice over IP, idolized as the golden calf of ultimate deregulation.

But although providers won’t be left behind, consumers might be:

7. Establish/reform rules to facilitate migration of customers from legacy to IP-based services and to prevent customers that procrastinate or fail to migrate from holding up the transition. For example, establish a process for identifying a default service provider if a customer fails to migrate, and/or permit service providers to notify customers that they will be dropped from service as of a date certain if they have not migrated to an alternative service/service provider. 

This particularly arrogant provision would put a stop to Aunt Maude holding up AT&T’s grand plan to live a regulation-free lifestyle. How dare she drag her feet with AT&T’s agenda at stake? If your elderly parents or extended family don’t understand why AT&T is meddling with their landline service and don’t want to change, AT&T has an unsympathetic solution. Under their recommendation, your parents would find themselves with a “default service provider” they might not want to do business with or, even worse, simply leave them with a dead phone line AT&T has no interest in repairing. But AT&T would likely still get their way. In rural areas they already cover, AT&T would be the “default service provider” because it is the only service provider. If Maude wants her phone line back, the only way she will get it is choosing the migration to Voice over IP AT&T intended all along.

AT&T’s language is remarkably frank, but was never intended to be viewed and explained to the public at large. It was the product of a phone company lobbyist talking to a politician, staffer, or regulator that one day could become an employee of that phone company. The only way to stop this cozy relationship is to tell regulators you are watching (and understanding) the game being played here.

Verizon is pulling back on its traditional landline service and FiOS expansion to continue focusing on its more-profitable wireless service.

Verizon Communications’ landline customers will endure continued cost cutting as the company focuses on its increasingly profitable wireless division, now set to bring in even more profits with Verizon Wireless’ transition to new, often higher-priced service plans.

Verizon executive vice-president and chief financial officer Fran Shammo yesterday told investors attending Bank of America-Merrill Lynch Media’s Communications & Entertainment Conference that the company is pleased with Verizon Wireless’ successful transition to Share Everything, which includes a shared data plan for multiple wireless devices.

Shammo characterized the true nature of Share Everything as a data plan that happens to include unlimited calling and messaging.

“It really comes down to data consumption and that is what drives revenue,” Shammo told investors. “And really the reason we did this was because we saw what happened in Asia with some of the text messaging and the dilution and voice migration.  So you are protecting that revenue stream going forward and we think that is beneficial to the consumer and the company.”

Shammo sees increased profits in Verizon’s future as customers transitioning away from unlimited data plans eventually bump up and over their new plan limits. But the revenue gains actually begin the moment customers sign up, as those bringing various wireless devices to a shared data plan are immediately told to upgrade for a larger data allowance at an additional cost.

“We are telling them that they really need 2GB per device,” Shammo said. “So if they want to bring five devices, they really should be buying the 10GB ($60/month) plan. What we are finding is customers are very receptive to that formula because they can get their head around the 2 gigabytes. They understand what their usage is. So part of it is that they are actually buying higher up packages than we’ve anticipated.”

Verizon also has a plan to deal with potential bill shock from customers using their wireless devices for high bandwidth applications. The company is receptive to letting content producers pay Verizon to cover customer usage charges.

Share Everything = a data plan that happens to include unlimited calling and messaging

“So when you look at that, revenue per account may not go up, but service revenue will because you are just getting it from someone else,” Shammo said. “So the LTE network allows the differentiation, and the way I like to classify it as you can have an 800 service over here, which is ‘free data’ because somebody else is paying for that and then you have your consumption data over here.”

Shammo believes customers who gave up their unlimited data plan believing Verizon’s basic data allowance will suffice for years to come will be surprised at how fast they will hit their limits as wireless data becomes more important.

“I think we are going to see this accretion faster than people think,” Shammo said. “If you look at our SpectrumCo [cable operators Cox, Comcast, Bright House Networks, and Time Warner Cable] deal, [CEO Lowell McAdam] and the team did an outstanding job convincing the Department of Justice about the innovation that can happen here and maybe being the first in the world to really integrate wireless with inside the home and content outside the home. And if you think about how that content can be streamed outside the home within cars, you really say this is unlimited as to where this can go. So I think the innovation is going to come very, very quickly here.”

With the spectrum deal with cable operators in place, Shammo said Verizon will not be in the market for any large spectrum acquisitions in the near future, and even plans to sell off some excess spectrum it does not currently need, so long as the company gets paid what it believes the spectrum is worth.

Verizon’s concern for keeping large amounts of cash on hand is evident as it continues to reduce investments in traditional landline service and FiOS. In fact, Verizon said it would continue increasing prices for its FiOS fiber network to more closely align with the higher prices cable companies are charging.

“We have really concentrated this year on getting our price points equivalent to where the rest of the market was,” Shammo said. “We were actually underpriced with a superior product to cable. So the concerted effort was we needed to do some price-ups and we are doing that over — we started in the first quarter. We did it in the second; we are doing it in the third. You saw some of that benefit come through in the second quarter where we delivered a 2.5% mass-market revenue increase, which was I think the best in years and I see that doubling by year-end. So I think that, coming out of this year, we will be on a very good path for a mass-market revenue increase.”

Two service calls in six months may get your traditional landline canceled and moved to Verizon FiOS phone service, which requires 10 digit dialing for every number.

But those rate increases will not deliver improved service. If fact, Shammo said Verizon will continue reducing costs and investments in its network. Much of its investment in the landline business has been to support Verizon Wireless’ growth through its IP backbone and fiber-to-cell-tower projects. Shammo predicts capital investments will continue to be flat to down.

One example where the cost-cutting is apparent is how Verizon deals with service calls for troubled phone lines.

Verizon landline customers in FiOS areas who report chronic service problems may find themselves disconnected and switched to FiOS Voice over IP phone service instead, because Verizon has quietly set new in-house rules about the number of permitted service calls for each customer.

“If we have a copper customer who is what we classify as a chronic (two truck rolls in a period of six months for that copper line), I am losing money on that copper customer,” Shammo said. “So if I can take that chronic customer and move them to FiOS, I deplete the amount of operational expense to keep that customer on and now I have moved them over to the FiOS network where they get the benefit of FiOS digital voice, which is clearer.”

Once a customer gets switched to FiOS, Verizon’s marketing machine swings into action.

“I now can put their DSL service onto FiOS Internet where they now realize the speeds of FiOS and what we are seeing preliminarily is even if we take a voice and DSL customer and move them, they are starting to buy up in bundles because they are starting to see the benefit of the higher speeds,” Shammo said. “Then we open up the sales routine to go after them, now for the FiOS TV product.”

Unlimited data holdouts can leave

Shammo added Verizon is becoming more concerned than ever about long term investments that leave the company waiting years for a return.

“Lowell and I have a very concerted effort to really make sure that the investments we make are returning their invested capital in a very short period of time,” said Shammo.

That spells trouble for landline service upgrades and future FiOS expansion, which both require the company to take a long term view recouping those investments. But even Verizon’s wireless business’ capital expenses are down — by $1.3 billion through the first half of this year.

Verizon Wireless has also picked up nearly $5 billion in cost savings through restructuring, including lucrative revenue earned from new activation and upgrade fees and also tightening up on subsidized wireless phone upgrades.

For customers holding onto unlimited data plans, intending to get their money’s worth from them, Shammo has a message:

“Quite honestly, they could leave my network because you are not making much money on those.”

Thousands of customers across northeast Massachusetts from Tewksbury to Rockport have been without Internet and phone service since early Monday after a mattress being used by a homeless man caught fire adjacent to Verizon’s copper and fiber optic cables on a bridge that crosses the Merrimack River.

”Your communications services may have been interrupted due to a fire in Lawrence that damaged a major cable providing service to your community,” Verizon’s dispatch manager Donna Powers wrote in letters sent to officials in the affected communities.

The outages are impacting communities including Gloucester, Manchester, Rockport, Essex, Littleton, Lawrence, Andover, North Andover and Tewksbury, and points in-between.

With high-capacity fiber circuits out of action, regional calls and certain Internet services were disrupted. Verizon is giving priority to restoring network operational and surveillance circuits, high-capacity fiber backbone circuits, and 911.

Verizon will not give a time frame when it expects to fully restore service, although the company indicated it is now rotating crews continuously to restore service to individual homes and businesses in the Lawrence and North Andover areas.

Lawrence Fire Chief Jack Bergeron said the problem started with a lit cigarette disposed on a vagrant’s mattress, which was on fire by the time firefighters arrived on scene. The mattress was on top of conduits that contained the copper and fiber cables, despite signs marked “danger” and “high-voltage.”

With no redundant backup facilities, a major outage can leave customers without service for days until repairs are completed.

Chickamauga Telephone Cooperative office (Courtesy: WRCB-Chattanooga)

AT&T and some of Georgia’s cable operators are under attack by telephone customers outraged to learn of a plan to force two independent phone companies to raise their rates because some think they charge too little.

Residents packed the Chickamauga Civic Center Monday night to loudly protest an effort by AT&T and the Georgia Cable TV Association to force both Chickmauga and Ringgold Telephone to raise their rates, in some cases by 100 percent.

“We’re here today because another company has complained about Chickamauga Telephone rates [claiming] that they are too low,” said Chickamauga city superintendent of schools Melody Day. “Maybe it’s just that their rates are too high.”

Retirees complained the rate increases demanded by AT&T and cable operators were unaffordable, with residential customers facing hikes of 42% for phone service. AT&T claims both phone companies are subsidizing their rates with money from the Universal Service Fund to an artificially low level. AT&T rates are considerably higher, and now AT&T wants the two independents to raise their rates accordingly.

If AT&T has their way with the Georgia Public Service Commission, Chickamauga residential customers currently paying $13.30 per month will be billed $18.83 per month for basic phone service with a limited local calling area. Business customer rates would double from $20.40 to $40.80 per month.

Local businesses and politicians are complaining loudly about the proposal, and want AT&T to mind its own business.

AT&T does not directly compete with landline service in the area, considered a suburb of nearby Chattanooga, Tenn. But cable operators do compete and AT&T sells cell phone service locally.

“It’s important for the Public Service Commission to be able to hear from our constituents around the state,” said PSC Chairman Tim Echols. “And we’re glad people packed the auditorium tonight.”

State regulators told the Times Free Press the Commission was unlikely to approve the kind of rate increase being demanded by AT&T. But they may approve a cut in state subsidies received by Chickamauga and Ringgold telephone companies, which would likely force both to raise rates anyway.

Chickamauga city manager John Culpepper said the city alone is looking at paying $200 more per month — money that will ultimately fall on the taxpayer. Culpepper says independent small businesses are already having a hard time competing with corporate America.

“When you double their rates, it is another financial impact.”

[flv width=”480″ height=”380″]http://www.phillipdampier.com/video/WRCB Chattanooga Walker County phone customers fighting rate increase 8-13-12.mp4[/flv]

WRCB in Chattanooga reports on the unrest among phone customers in Chickamauga, Ga. over a plan by AT&T and Georgia cable companies to get regulators to force their local telephone cooperative to increase rates by as much as double. (4 minutes)

Greenwich Village business owner Louis Wintermeyer has spent the last three months without phone or broadband service from Verizon Communications.

“It is hard to believe it has gone on this long,” Wintermeyer told the New York Post. “You feel like you’re in Bangladesh here. I mean we’re in the West Village!”

Across Manhattan, and well into upstate New York, Verizon customers who start experiencing landline problems often keep experiencing them for weeks or months on end.

Wintermeyer couldn’t wait that long — he relocated his car-export company to his Rockland County home. Another Verizon customer in the same building — the Darling advertising agency, experienced intermittent outages adding up to 10 weeks of no service since February.

“We really sounded like amateurs,” Jeroen Bours, president of the Darling advertising agency told the Post. “We would be in a conference call, and all of a sudden the call would go. It just doesn’t really make a good impression.”

In the Adirondack hamlet of Wanakena, when the rain arrives, Verizon service leaves a lot to be desired.

One person’s phone may be working but the one next door will be completely out of service or crackly at best, according to local residents.

“It’s almost comical,” Ranger school director Christopher L. Westbrook told the Watertown Daily Times. “It’s so bizarre because some phones will be working while others are not.”

[flv]http://www.phillipdampier.com/video/WWNY Watertown Phone Situation Improving Officials Say 8-3-12.mp4[/flv]

A fiber optic line cut near Cicero, N.Y. in early August disrupted phone and cellular service from Verizon across the North Country. WWNY in Watertown covers the event.  (1 minute)

One Adirondack Park Agency commissioner who lives in the area says he has been without a phone 15 times in the last two months. Unfortunately for North Country residents, cell phone service is often not an option, because carriers don’t provide reliable wireless service in the region.

Local businesses cannot process credit card transactions, broadband service goes down, and a handful of privately-owned pay phones out of service for months have been abandoned by their independent owner because of the ongoing service problems.

Verizon repair crews come and go, but affected customers report a real reluctance by Verizon technicians to complete repairs once and for all.

“The permanent fix is not happening,” says Angie K. Oliver, owner of the Wanakena General Store.

Bours said one Verizon technician told him the company no longer cares about its older copper wire landline business. Rural residents upstate sense the company has little interest spending money on deteriorating infrastructure.

Some Wanakena residents suspect Verizon has thrown in the towel in St. Lawrence and Franklin counties, where independent Nicholville Telephone subsidiary Slic Network Solutions is constructing over 800 miles of fiber optic cable and operates a fiber to the home broadband and phone service.

[flv]http://www.phillipdampier.com/video/WWNY Watertown Lewis County Phone Service Restored 8-20-11.mp4[/flv]

Last summer, Lewis County suffered a similar widespread phone service outage that left businesses and homes without service for days.  WWNY says Barnes Corners was hardest hit.  (1 minute) 

Verizon spokesman John J. Bonomo blamed lightning strikes for the problems in Wanakena, but said the cable serving the area was intact and should not be responsible for service outages.

Gray

Near Syracuse University, some businesses and residents were without phone service for nearly two weeks in June.

The largest outage began when more than 150 customers around SU lost service after a storm. More than a week later, nearly two dozen customers were still without service, including the 4,000 member U.S. Institute for Theater Technology.

A damaged underground phone cable was deemed responsible, but repairs were slow.

Earlier this month, Massena town supervisor Joseph Gray fired off a letter to the deputy Secretary of State after a major Verizon line north of Syracuse was damaged, cutting off landline and cell phone service throughout Jefferson and St. Lawrence counties.

“I would have called your office to speak with you directly, but I couldn’t because our telephone service was unavailable,” Gray wrote. “Since I became supervisor of the town of Massena just over two and a half years ago, on at least three different occasions telecommunications in the entire North Country has been thrown into chaos because a Verizon fiber optic cable was cut 150 miles from here. Many of us found our emergency services, business, residential, and cellular telephone service interrupted, not to mention disabled credit card machines, facsimile machines and Internet service in some cases.”

Gray criticized the Public Service Commission for allowing Verizon to operate without service redundancy in the state, providing backup facilities if a fiber cut occurs.

“As a result, the Public Service Commission (which perhaps should be given a different name if my experiences with them is typical), has done nothing to address this dangerous situation and, more incredibly, appears unwilling to acknowledge that the problem exists,” Gray said.

Attorney General Eric Schneiderman blasted Verizon’s poor landline service in a petition sent to the New York State Public Service Commission. Schneiderman called Verizon’s service unacceptable in New York, with customers forced to wait inordinate periods to get service restored.

“Verizon’s management has demonstrated that it is unwilling to compete to retain its wireline customer base, and instead is entirely focused on expanding its wireless business affiliate,” said Schneiderman’s office.

Schneiderman’s office filed evidence in July that Verizon was undercutting its landline business in New York and diverting money for other purposes:

• Verizon’s claim it had spent more than $1 billion in investments to its landline network was misleading: Roughly three-quarters of the money was actually spent on transport facilities to serve wireless cell sites and ongoing spending on FiOS in areas already committed to get the fiber-to-the-home service;
• Verizon investment in landlines has declined even faster than its line losses. The dollars per access line budgeted for 2012 is one-third less than the investment for the 2007-2009 period;
• In just a five month period, 19.5% of the company’s 4.3 million customer lines in New York required repair. This means every Verizon customer will need an average of one repair every five years;
• Verizon’s complaint rate with the PSC has exceeded the PSC’s own limit for good service every month since June 2010. Most recently, Verizon exceeded the limit by more than double the threshold;
• Verizon’s agreement with the Commission establishes two classes of customers: “core” customers (8%) that qualify for enhanced repair service because they are elderly and/or have medical problems and non-core customers (virtually everyone else). The Commission only enforces service standards and repair lapses with “core” customers, which are required to have out of service lines restored within 24 hours 80% of the time. Verizon is free to delay other repairs indefinitely without consequence.
• The PSC has already fined Verizon $400,000 earlier this year for poor service from October-December 2011.

[flv]http://www.phillipdampier.com/video/WWNY Watertown Gray Phone Disruptions Perilous Flaw 8-7-12.mp4[/flv]

WWNY talks with Massena town supervisor Joseph Gray, who has launched a campaign to force Verizon to develop a plan to better handle outages in northern New York. (2 minutes)