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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. 21-0515-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. Sincere1 y , WV State Bar # 881 3 [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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Page 1: ANNA HANNA PLLC Attorneys Law

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.

-5-

CASE NO. 2 1-05 15-CTV-SC-GI

SUDDENLMKWVPSC00363 8

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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

SIJDDENLINKWT’SCOO3639

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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

SUDDENLNKWVPSC003 640

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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

SUDDENLKKWVPSC003642

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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

SUDDENLINKWVPSCOO3645

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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

SUDDENLhKWVPSC003646

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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

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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.

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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.

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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

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1 Elkins - 1513 Harrison Ave

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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

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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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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.

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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

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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.

:

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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.

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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.

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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.

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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.

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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

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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.

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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.

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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.

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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.

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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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SUDDENLTNKWVP SC003 67 1

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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

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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