Frontier bungles redaction of network audit that it doesn’t need you to see

Frontier bungles redaction of network audit that it doesn’t want you to see

Enlarge / A Frontier Communications van.

Frontier Communications wants a lesson in find out how to redact paperwork.
Frontier is attempting to cover giant parts of an audit report from the general public, claiming that particulars concerning the ISP’s broadband-network issues are commerce secrets and techniques. But when Frontier made a redacted model of the report public, most of the blacked-out components theyre nonetheless readable just by copying and pasting from the doc.
The Frontier-edited model of the 164-page report, which was ordered by the West Virginia Public Service Commission (PSC) and written by a marketing consultant agency, contains about 80 redacted reveals and lots of pages which have been absolutely or partially blacked out. Frontier appears to have efficiently redacted the reveals, together with many charts, however the blacked-out textual content is simple to elevate. (Update: It seems a few of the reveals theyren’t correctly redacted, both.)
For instance, one redacted sentence says that “Frontier WV’s copper network has at least 952,163 connection points that are susceptible to moisture, corrosion, loose connections, etc. that may cause interruptions of service to customers.” That “952,163” quantity was blacked out, however it’s nonetheless readable for those who copy it from the doc. We’ve uploaded the doc to our server in case it will get taken down from the PSC theybsite—you’ll be able to view it right here.
Describing the connection factors, the report says that “Any electrically connected circuit has numerous points where connections are made. As systems and networks age, all of the connection points have the potential to cause service interruptions.” The 952,163 connection factors embody 376,897 overhead splices, 444,898 terminals, 4,508 crossboxes, and 125,865 pedestals. Copper networks theyre initially deployed with “a minimal number of splices,” however “later, splices have to be added as repairs are made,” the audit report mentioned. “No installation date data was available for splices.”


The failed redaction of the variety of connection factors was coupled with failed redactions concerning the age of the network. The marketing consultant agency’s report mentioned that 46.Eight p.c of Frontier’s West Virginia network is bettheyen 36 and 47 years outdated. Both the share and the numbers of years theyre unsuccessfully “redacted” by Frontier.
Other unsuccessfully redacted data contains the variety of clients and the variety of miles of copper within the network. “Frontier WV has to operate and maintain a 49,402.1-mile copper cable network currently serving 309,088 customers that was originally constructed to serve over 2 million [customers],” the report mentioned. Frontier’s fiber network in West Virginia is tiny by comparability, with simply 8,077 miles of fiber-optic cable. Another “redacted” portion says the fiber “provides digital capability to portions of the copper network.”
Here’s what all that data seems like within the report:
Schumaker & Company audit reportAnother redacted portion reveals that Frontier repeatedly failed to satisfy a service-quality benchmark that 85 p.c of outages needs to be mounted inside 48 hours. The knowledge reveals that “Frontier West Virginia missed the metric 21 of the 60 months [from 2015 to 2019], with 14 of those months falling in the past 24 months.” While Frontier makes use of a 48-hour benchmark internally, state laws say that outages needs to be mounted inside 24 hours of shoppers reporting them, the report mentioned.
It’s onerous to think about why Frontier redacted the variety of clients, as a result of it was already publicly identified that the corporate had about 300,000 clients within the state. In one other “redacted” portion, the audit report says that 175,131 of these clients subscribe to DSL Internet service. Many clients both purchase cellphone service by itself or a bundle with cellphone and Internet, however Frontier’s buyer base has dwindled over time.
Other “redaction” choices make even much less sense. One utterly blacked-out paragraph merely states the Federal Communications Commission’s broadband-speed customary of 25Mbps downstream and 3Mbps upstream, and it quotes from an FCC report that mentioned 93.5 p.c of the United States has broadband access, in comparison with 84.6 p.c in West Virginia. That FCC report is publicly accessible, but Frontier needs quotes from the report back to be handled as a Frontier commerce secret.

Regulator ordered report

The West Virginia PSC beforehand ordered the third-party audit of Frontier’s operations within the state in response to widespread outages and complaints from clients and a labor union. The ensuing audit report was submitted on March 18 by consultancy Schumaker and Company, however the utterly un-redacted model is below seal, for now.
Frontier on March 25 made its redacted model of the report public and filed a movement searching for confidential remedy of the redacted particulars. “The redactions primarily are of information that, if known to competitors, would provide them with key competitive insights into Frontier’s business and, conversely, would place Frontier at an undeserved competitive disadvantage, likely resulting in harm to Frontier,” the corporate advised the PSC.
The PSC is contemplating calls to make an un-redacted model public. West Virginia Public Broadcasting reporter Emily Allen filed a Freedom of Information Act (FoIA) request for the total, un-redacted report, and the PSC’s workers urged the fee to reject a lot of Frontier’s redactions.
PSC workers wrote:
[I]nformation relating to Internet service is West Virginia-specific and doesn’t point out another areas within the nation the place Frontier is providing companies, so it’s onerous to ponder how the knowledge relating to Internet service, together with federal applications which give federal funding sources for the provisioning of broadband companies and are available to different telecommunications suppliers, would pose any menace to a commerce secret important to Frontier’s operations.
The PSC requested that Frontier file a response to Allen’s FoIA request, and Frontier’s response got here in yesterday. Frontier advised the PSC that it operates “in a hotly competitive industry where it enjoys no protected service territory and no guaranteed rate of return whatsoever” and mentioned it could be “damage[d]… by the release of its competitively sensitive information.” Frontier claimed that the “redacted information is limited to trade secrets and other protected information that is truly exempt from disclosure under FOIA.” Frontier additionally mentioned:
In half, the redacted data contains nonpublic details about Frontier’s broadband enterprise—over which the Commission explicitly has no jurisdiction below state regulation. This data was included within the report over Frontier’s objection and has no bearing on the eight express areas the Commission directed the Auditors to look at relating to Frontier’s voice phone service—the topic over which the Commission has jurisdiction to conduct a centered audit. Releasing this data would solely serve to hurt the Frontier to the good thing about its big wi-fi, satellite tv for pc and cable broadband opponents.
As they beforehand reported, Frontier is getting ready to file for chapter after years of failing to take a position correctly in upgrading its copper-based DSL network to fiber broadband. The firm’s poor upkeep of its copper cellphone and broadband network has led to investigations and complaints of power outages in New York, Minnesota, Ohio, and West Virginia.
When the Minnesota Commerce Department completed its investigation into Frontier’s in depth failures final 12 months, the ensuing report was not redacted. It accused Frontier of violating greater than 35 legal guidelines and guidelines. Frontier finally settled with Minnesota.

Report reveals issues, regardless of redactions

Despite Frontier’s in depth redactions to reveals, the West Virginia report nonetheless gives particulars concerning the firm’s customer-service issues. Schumaker reported “negative trends” in six service metrics, specifically outages, service issues, restore anstheyr instances, restore troubles, restore appointments met, and residential and enterprise anstheyr instances. Unfortunately for subscribers, “Frontier does not provide customers credit in situations where the same trouble for the same service are reported on the same line within 30 days.”
Frontier’s upkeep processes are missing, the audit report mentioned. “Frontier WV does not have a documented process for performing preventative and corrective maintenance,” and the corporate “does not have a documented tree trimming policy and process.”
“Frontier has not had a pole inspection program that detects poles that do not meet strength requirements for a number of years,” the report mentioned. “This lack of knowledge about the condition of the pole population may have created a significant backlog of poles that need to be replaced.”
Frontier has “no standardized procedure/process to be follotheyd when determining root causes for the poor performance of any given wire center,” the report mentioned. Schumaker additionally identified that Frontier “does not have a computer system or management process for performing preventative maintenance” however mentioned the corporate was “in the process” of setting that system up whereas the investigation was ongoing.
“Overall capital expenditures have declined over the past nine years by 25 percent, from $65.9 million in 2010 to $49.4 million in 2018,” the report mentioned in one other portion that Frontier tried and did not redact.
“Plant-specific operations expenses” are listed within the report with out tried redactions, with the annual quantity steadily dropping lately, from $165.three million in 2012 to $120.5 million in 2018.
Complaints to the PSC about Frontier service have been rising, from about 30 formal complaints in 2015 to virtually 90 in 2019. Informal complaints rose from lower than 600 in 2015 to greater than 1,200 in 2018, earlier than dropping to slightly greater than 1,000 in 2019.
Enlarge / Informal complaints made about Frontier service by 12 months.Schumaker & Company audit reportMore than 775 members of the general public submitted feedback for the state’s investigation of Frontier, Schumaker wrote:
Over half (51 p.c) of the feedback theyre associated to DSL service, phone service represented 29 p.c and issues with each companies theyre famous in 20 p.c of the feedback. Regarding the small print of the feedback, the overwhelming majority of the DSL feedback theyre complaints on the gradual pace of Frontier’s service and delays in getting the service repaired. The main criticism with respect to the phone service centered on out-of-service and the poor high quality of the voice service (static on line).
In addition to blacking out big components of the report, Frontier mentioned it objects “to certain findings and recommendations” and that it intends to “correct various factual errors and inaccuracies throughout the Audit Report.” Frontier has till April 20 to offer a full response to the findings.

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