 to see you all again and the new folks that are here as well. We're here this afternoon for a workshop in case number 19-07005-PTT, which is a request from the Vermont Department of Public Service for a workshop regarding service provider backup power obligations. This is our third workshop. The purpose of the third workshop I was in here in order to establish that we were going to do it is to provide the participants with the opportunity to make presentations both summarizing methods used for ensuring compliance with 47CFR section 12.5 and recommending best practices for minimizing disruptions to E-91 services during power outages. Workshop participants have been encouraged to file the draft presentations. I did see most of them. Well, at least all the ones that filed, I've seen them, whether any others that have not yet been filed. And they're encouraged to take the opportunity today to briefly summarize them and be available for questions and comment about their presentations. Any questions about where we're going to? As I noted in the order established in the third workshop, I'm in the fourth workshop sometime in October, probably early October, in order that I have more time to prepare a draft report to the legislature and then I can give you all a chance to look at that before it goes up. So we want to try to get that news in Missouri as possible so we can get that report to the legislature in December as required. With that, I think I'll ask who's here. Starting with you, Mike. Secretary Seven, Department of Public Service. Clay Burvis, Department of Public Service. John Flynn, Department of Public Service. Nancy Momquist, down for Act 1-1. Here for a try to fiberlink Vermont, CCA, Disponderment, and so on. Thank you, Brown Brown, for changing the fiber. Melissa Pierce, Comcast. Jerry Tarrant, Eric Gillis, St. Richardson, for Comcast. Jim White, Comcast. Jeff Austin, Consolidated. Paul Phillips, from the law firm, Department of Public Service, Dr. Bremer, Secretary Mackey, the Vermont Court of the Eight. Vermont Rural Telephone Companies. And I won't list them, but they do include our Vermont Telephone Company. Jennifer Matthews, select board member, town of Mount Holly. Jonathan Gibson, resident of Shrewsbury. Madeline Boone, from the select board, at the top of the year. I'm Chuck Finberg, also from the town of Shrewsbury. Board of Matthews, Vermont Telephone Company. Scott Connelly, Vermont Public Interest Research Group. He heard. Kevin Brassard, from Booktree. Thank you, Board. You have to mention that unfortunately, I had a conflict at two o'clock, so I'll be meeting at 10 o'clock, and Booktree turned as soon as possible. Since you may be not here when it comes up, we're the participants. I want to think of Shrewsbury, talked about the development of the E911, utility. I'm just wondering how duplicative would that be of the E911 board, and if you could provide a little bit of background to the folks here as to what the E911 board does, and where its authority comes from, what, you know, where its money comes from, all that kind of stuff. If you don't mind, I'm going to start with you once I find out who's on the phone. Who's on the phone? I said Susan or Lynn for charter. I'm sorry, could you repeat the name, please? Charit, Susan or Lynn, like the city, the ERLN. Is there anybody else on the phone? Okay, thank you. With that, Ms. Neal. Sure, so the Vermont enhanced E911 board is the state government agency responsible for the state-wide E911 system in Vermont, and our authority is in 30 VSA 71 through another number, 70, 60 perhaps. And so we have the responsibility for the oversight management of the state-wide E911 system. The board itself is made up of nine members representing state, local, and county law enforcement, not members of medical services, a fire service representative, the town or municipal representative and then three members of the public. So we have a staff of 10 who does the day-to-day management of the 911 system, and we have partnerships with various state, county, and local law enforcement agencies who are on the phone at six, Vermont Public Safety Answering Points, where all of the 911 calls are answered. We do not provide that service ourselves, rather we have these memorandum of understandings with those folks to do that. The question of how the E911 utility would be with the 911 board, I'm not certain that I can answer that without understanding what is envisioned in a 911 utility. I did read the comments, but I think before I comment on that further, I would really want to understand what it is that's being proposed or suggested. Okay, then you will be back after you- I will be back, yes, as soon as I can. Okay, just so that we can, of course, provide that to one of the discussion of the 911 utility comes up, because I'm not sure what it's about, but we've given funds to the E911 board. So the 911 board is funded through the Vermont Universal Service Fund, which I think everyone knows here is a 2% charge on your telecommunications bills, retail telecommunications sales. We are one of several programs that are funded through that, and that is where our funding comes from exclusively. So there's no general funds or other funds involved. What does that money go to from the E911 board? So it goes for the provision, if you will, of the system itself. So we have a contracted vendor that provides a 911 system in Vermont right now that's consolidated communications, and that is a hefty chunk of the yearly appropriation. It also goes to cover the staff personnel costs of the 10 people at the 911 board. Work of the 911 board includes information technology, manager and specialists who work with the system provider and with the PSAPs to ensure everything is operating as expected and in accordance with the terms of the contract with the provider itself. And then there is a large percentage of the, well, about 40% of our staff is as database-worthy so that it sounds GIS and GIS that we're tracking drives. Next generation 911 systems appropriately with training and communications staff and the administrative support staff as well. So all of that, those personnel costs are covered there as well. And if I put you on the spot, I get a little bit of an intro about the two ideas that we're talking about. I'm ready for you. And what you think about where the E911 board might fit in resolving the concerns about power loss and the ability to access E911 services and what role from a consumer education perspective, a technology perspective, et cetera, I think that the board might play. Well, I would add at this point that E979 requires that the E911 board initiate rule-making for an outage notification procedure that we apply both to telecommunications, both to voice service providers in Vermont as well as electric companies in Vermont, for the purpose of assessing how Vermonters are impacted by the various kinds of outages. And we're in the process of developing that rule now. We have not initiated the formal rule-making. It would be difficult for me to assess the impact of power outages on Vermonters access to 911 without the data to understand how often these happen. Now, the data may be available elsewhere and I can look into that, but at this point, I think that's the purpose of this rule is to better understand the impacts from those power outages. And it sounds like it's a database resolution or an attempt at a database resolution to the problem of power losses and the ability access to 911 when there are power losses. Right, and there are a number of factors that involve, so we're just trying to look at when any specific company, when any specific service is down, how are the customers of that service impacted? So it may be the 911 system is likely still up and running and so if a person has access to another type of telephone service, that they may not be impacted. So it's not an all or nothing proposition. So that we're trying to get at with the rule. So the rule would provide even more understanding as to the survey kind of fashion what happens in that circumstance and what may be good solutions to respond to. Right, I think understanding the scope of the problem is the first step in trying to figure out how to solve it. So that's what we're doing here is kind of complementary to what you're doing. Yes, and on your other question, but more detail perhaps of what the 911 board does, I'm happy to answer the questions when I get back or compile something a bit more comprehensive perhaps to submit. Yeah, it would be very useful in the report if you and the board were able to provide what your reflections are on what the discussions that occurred in the workshop and if you could help answer the questions that the legislature has given us to answer. Thank you. So I just wanted to add a clarification to what Ms. Neal said and asked that the 2% surcharge on the telephone bill is not devoted exclusively to the 911 board, but it has a number of statutory purposes including funding of connectivity funds for the Department of Public Service. Yes, thank you. Okay, with that, who wants to make a presentation? Jeff Otz and I consolidated. I figured we would go first. We're the incumbent local exchange carrier throughout most of Vermont cover about 200 pounds here in Vermont. You hadn't reached your hand on the point. Yeah, that's perfect. I think we can start right off. Please. But just to put to summary, so our network in Vermont, I think most people know, we have a lot of fiber. We have about 3,800 miles of fiber here in Vermont today. But that fiber, it's distribution fiber. It's part of our ring network. It's part of the network that moves all of our traffic, a lot of our broadband. Our voice does go over that, but not on a fiber to the premises aspect. So we do have fiber delivered in two locations in South Burlington. So I just kind of want to start knowing that our scope for the entire state, except for a couple of locations in South Burlington is completely still copper served for residential telephone service. Copper being line powered currently like it always has been line powered. Now we move though, because there's a lot of focus obviously on increased broadband speeds. And the way you increase broadband speeds is you either get a lot closer with the electronics to the copper network, which we've done in a lot of places, or you start delivering a new technology or different technology, fiber to the premises, gives you the ability to have one gig, 10 gig speeds depending on what the electronics are on the end of that. And ultimately what we're talking about today with the battery back up. So Consolidated does see it through the initial customer contact if we do get a call from a customer in one of those locations. We do advise them that their service will be provided over a fiber, over fiber facilities, and that if there's a commercial power outage without an alternate power source, they will not have access to 911 services. So following the FCC guidelines, we have that upfront conversation of the initial customer contact. We talked to them about obviously the options, where to find the information if they're interested in purchasing a battery backup. We advise them that we will send out a customer notice, which provides the other backup additional information to their billing address. Within a couple days after that, initial order is placed. And that is basically the customer letter that we added in the comments that we had sent. And then annually, again, following the FCC rules, we send a reminder notice that advises customers the same thing. And ultimately what we're talking about here today, the initial paragraphs of those notifications says you are from a service that in a commercial power outage you will not have to out on them unless you have a backup battery. It's educational. It's following the FCC guidelines. We don't have an impact yet here in Vermont, obviously, but we're moving toward that technology. So we will have an impact. And that's where we are today. Thank you. I have a question. Please. Jonathan Gibson. I'm sure he's ready. I think you and I have had informal conversations, a little bit on the part of your remarks that you could increase the broadband speak to be increased by getting fiber a little closer to the end user. Sure. There's some stations along the way or calls the counter centers. Yeah, in Vermont we have about a thousand remote terminals. These remote terminals extend the intelligence of our central office further, and they're mostly fiber pad further to our customers, ultimately allowing for increased broadband speeds, the closer you are to those electronics, and even those electronics evolve. Our previous speed maximum was 7 May that's increased to 25 May download, 2 May upload that's now increased to 100 May download, 40 May upload, depending on the technology and the distance you are from those remote terminals. And then these remote terminals are themselves fed by fiber optic, but they from the terminal to the home is still. Yes, and these remote terminals are fed by commercial power. We have battery backed up in the remote terminals in case there's a commercial power outage and for extended commercial power outages each of the remote terminals has a portable generator connector, so it's fully portable generator connected, started up those use obviously fuel, so you have to go out there and refuel them if it's an extended, extended commercial power outage but that's and then we could talk a lot more about that if you're interested, but that's not it. There's one quick follow up in there. You said they're supported by batteries. Can you describe those? Yeah, they're just actually they're just a battery pack, you know, battery strings that are put together depending on the amount of electronics and amperage that the electronics use their size appropriately for what's needed out there. Most of them, we have obviously some legacy technologies and newer technologies if we have two different pieces of equipment, one for phone and one for internet, those batteries are powering the phone, you know, electronics. If those electronics are combined, which is what we're using today, it's powering both of those. For how long? Those are between six and eight hours. Okay. Can I ask a question about the line power of the copper? Do you consolidate has a lot of residential customers in Vermont with line power service? Yes, yes, all of our copper network is line power. And if you were to install fiber service to those residences, would you be required to remove the copper wire? There's no requirement to remove it, but then you get into the fine, the economics of maintaining two networks in the same area. And that's where it may be difficult. What we would probably do, and I'm just kind of just talking conversationally, is retire the copper that was out there. We would not remove it from the poles everywhere necessarily, but we would want to only use and maintain one network, which ultimately can provide both internet and services. But if there were loss of power in that situation, in the fiber off that can be installed, that service would be interrupted with loss of power while the line power service would not be without a separate power source. We're correct. Thank you. I'm sorry but I'm reminded of experience, life and life. I lived in New Orleans for a couple of years, and it was right after my hurricane country, and I was in the Coast Guard at the time. On the weekends, I would go out and do, every Saturday I did habitat for humanity. And I was working in a wonderful project called Resitions Village, where they redid a whole area of the ninth form, and they had to actually have special security put, rewired home because they put, they wired one of these wonderful new habitat for humanity homes, and if it wasn't secured, within a couple weeks it no longer had anything copper. I was thinking about retiring copper, and that's what comes to my head. We've had those same issues of missing copper on this, or developments. Yeah, absolutely. I'm sorry. Any other questions for Consolidate? Thank you. Does Consolidate, what is, how does Consolidate maintain the batteries? The issue here is, in the in-home batteries, the batteries go flat. Sure. People don't replace them, or no one replace them. So, but this is the responsibility of Consolidate. How does Consolidate manage the the life of the battery and the replacement of that battery? Yeah. We have a maintenance, battery maintenance program, in all the states that we have to occupy. So, obviously, like I mentioned, we have a thousand, about a thousand of these around the state. So, it's a continuous yearly project that we have, and like you said, year-over-year basis in all of our territories for battery maintenance. And also, there's new technologies to allow batteries to actually last longer. You know, so there's always new developments and new technologies that we incorporate into our network to actually give the batteries more of a longer life span. Your second up, is the, do you have the on-site artist? Or don't have it fast yet? This makes it easier for everybody to hang out. Thanks. Thanks. Sorry, sir. I'm still Jonathan. When your battery people go out, I don't know if you've been with them or not, but what do you expect, what do they do to maintain those batteries for life and the replacement? You know, I don't know enough to be able to answer that problem, in a effective way. I think that's one of the issues I made for the individual homeowner. It is, you know, what you, I think it is communicated now in different ways by the telecom to the consumers, certainly at a point of selling and annually, I think, in one form or another, that it's the homeowner's responsibility. But what does that entail? You could look at the life see if it's blinking, but you might close the door on the closet or go up to the upstairs from your cellar and it would stop blinking. And there's a warning, I think, that one might get. I know some of the companies can, well, I don't know if all can or not, it really would be interested in knowing if I know one of the, the Wakefield company did mention this, and it certainly makes sense in my mind that you are able to send a signal to see if the battery in a given location is functioning. That's how they say how much battery life is left, but is it working at that time? So, I think this is one of the issues that we might want to talk about a little bit more is what can the consumer do, what tools does the consumer have to effectively monitor the status end to replace a battery as compared, let's say, to a professional battery maintenance specialist. I guess I would like to circulate that question if we could. Can all the companies that are offering cover services, or use one by one, can you identify the status of an individual consumer's battery at any given point in time? I know one of your R-Lex said yes to that. Right. I'll let Gordon speak about the details since you went short. But the R-Lex are also R-Lex, the same as Consolidated is in the bearing component carriers who have been serving in your respective service territories for many, many years. They're all in a slightly different situation, but the companies that are, at this point, have fiber-fed networks, our weights field and retail. Right. And it also happened to be the two largest of the R-Lex. The smaller R-Lex have copper-fed networks. In the case of Shoram telephone, which is over on the eastern Shoram link chain over by Middlebury, Shoram fiber network. But the other small companies, which are Topsom, are three TDS companies in San Franklin. So that's Ludlow, Northfield, Perkinsville and then Franklin are entirely copper-fed networks and so they don't offer presently offer carbon services. But they do have one power networks. In the case of weights field, and I apologize that Roger Mishie's not here today, but he had a deafness to be a family and so he's traveling and so what he has told me is, and this seems a little ironic I suppose, is that presently they do have the ability to monitor the batteries from the central office. That's because of the nature of the service they provide. As they upgrade the speeds, the vendor is telling them that the higher speed service does not have remote sensors of the batteries. So as they swap those out over time and they'll be doing that increasingly, they're actually going to lose that functionality. So that's another instance I think of where these companies are really subject to the perils if you go to the marketplace. Because they're reliant upon vendors who are selling their equipment nationally and internationally. They don't have a lot of influence over the development of technology but for whatever reason that particular functionality will be going away over time and I know that's unfortunate. And then in the case of VTEL, Gordon Matthews who's here must drive out VTEL's system operands. Yeah, we don't have the capability to monitor individual batteries and the status of an individual battery for the remaining capacity. We have to monitor the status of an ONT which is the unit that the battery powers in the outage. So we can tell if an ONT goes offline we don't currently monitor that on a network-wide basis. We're looking at setting up a system to do that because that's going to be, it looks like one of the requirements for the E911 new reporting rules. Regardless of the reason for an ONT going offline whether it's the problem of VTEL's network or it's due to a power out required, it looks like to report that to the 911 board. So that's going to require a separate monitoring system for all ONT's network-wide that we don't currently do. Do you think Roger was referring to the outside device, the network connection or was he referring to the battery at the house, the distinction that has just been made? You haven't known? I don't know specifically my impression was that he was referring to the battery. I thought that's what he said earlier but might have been something connected to the battery which is what you're referring to. Correct. That's at an individual house if there's somebody called and said I'm not getting service and you could check it from your office if the NID or ONT device is functional. Correct. Yes. Chuck Finberg and Rob in respect to what Mr. Matthews was saying, I'm a Vermontel customer we had an episode at our house earlier this summer where all power, all service was lost from the VTEL service so we had nothing. No phone, no internet, no television and no notification. We were not aware of the outage so I was, I had to without cell service, I had to get on the birth tube and run the contact VTEL luckily it was not during the hours when their service department was closed which is Saturday noon through Sunday and when I spoke to the gentleman there what he said was that they can tell whether there's an outage at the residence but he checked and saw that there was no power but they had no protocol for reaching out or for providing service or repair when they saw that. They didn't have any monitoring in place and that's what this service technician or the person in the office said and it seemed like a hole to me in the process when you don't even know that the 911 service is out. Continue with our survey around. Oh man, you had a question? I'm talking about it. I'm sorry, what was it that spoke? I didn't see. Sorry, what's your name? Cecile. Cecile, what's your last name? Begey. Cecile Begey. I'm probably the last person on your list. Okay, okay, okay. So, continue if you want. Please. So, we filed our comments. We just emphasized that we are presently in compliance with the FCC's rules. We did provide a chart which was basically a survey of the companies because in each case each company provides a little bit more than what the FCC requires strictly speaking but this is a list of additional or ancillary services that are related to back-up power that the companies provide and in our discussion as a group even though not all companies presently provide each of those services we decided that those were a good list of what we considered to be current practices or best practices that the companies are willing to provide you know, comprehensively among the group. That's what the FCC's wishes and so we can review those but I think they fall into a general category which is that there are ways that the end user the customer can extend the life of the battery and we would like to engage in additional education efforts to alert the customers for how they can take their 8 or 24 hour battery packs and use them most efficiently use them most wisely in a way that extends their battery life so that if there is an extended outage that lasts as great as the 24 hours they would still have the ability to use their point services for how long the battery pack can last and that's a focus that we'd like to consider because I think it's a good efficient way of using current technologies and current education efforts to address what are here to be the real poor problem here which is that these outages are getting more extended in time and so it's necessary for customers to have access to their voice services for longer periods of time. Which brings to mind to me one of the things that I was going to suggest that the participants do for the next meeting which is to review the best practices that have been proposed by the various packages that were submitted and to comment upon them if you think they're good ideas or not and why because that will be part of what the commission will consider when it forwards its report. But I won't ask for that today I'm just asking so you can take towards what people are talking and it helps you figure out if you'd like to figure that out. Question? Just a second. So that would be part of the initial comments and reply comments that you anticipate we will do that will file after the October workshop? No, I will I'll probably walk down for the October so that we can talk about them there to a greater degree possible. My question was then would that best practices list include the CSRIC list that Sarah was kind enough to refer to? Yes, absolutely. I want to include those documents in the report so that the legislature can see that the FCC has addressed the issue before in more comprehensive fashion. And the measures to be reviewed and that we've offered and compiled into that chart until a large measure come from the CSRIC report and we also included an element which we thought was interesting that the CSRIC felt there was some obligation on the part of local authorities to step up and take some responsibility for either warehousing batteries in some measure providing a resource for the residents and their communities. Understanding of course that in each case the CSRIC recommendations are not mandatory the FCC wants them to be voluntary but they are ideas and there's more tends to be a working group that has an expertise in these kinds of things. To that point and this is the time to add this to the record I mean it's perhaps the FCC order and report are by reference already part of the record I don't know, I'd like for there to be people can access that but with respect to that CSRIC recommendation the I believe it's in paragraph 60 if I'm not misvoting this I can stand correctly but there's a footnote number 194 that the paragraph is dealing with the information to consumers the requirements and the footnote says we, that's the FCC we emphasize that this information establishes a floor only and does not supplant the ability of states to the extent they have jurisdiction over the service to adopt additional obligations that do not prevent implementation of our rules. I do think it's just important that the cushion itself says that they recognize that while they did not adopt all of the CSRIC best practice recommendations in this instance with the current information that they don't state has jurisdiction exactly good point to capture that in your comments although I appreciate your stating them now I'm sorry Mr. Mr. Phillips we must appreciate Mr. Gibson's reference to that footnote I'm just looking at it here and the information the FCC is talking about is not the CSRIC recommendations it's actually the what they call the minimum information requirements thank you it was in that spirit of floor that we compiled this list which are additional educational requirements we talked about the FCC requirements may I ask in response to that are you suggesting that additional best practices could not be adopted by the state? I'm not making the legal determination about that I'll give you the legal answer which is okay it's hard to make a blanket answer to that question about the nature of the company that's involved in the technology and there's great uncertainty in the law as well in terms of the rule true question you mentioned something about the communities taking responsibility for backup batteries for the residents people a little further we need a slide for if you're talking about local governments taking on some responsibility there if I could if you want to look it up go ahead because I have thoughts on this as well that yes this is a public health issue not necessarily a telecommunications issue and there's a very real role that local emergency services play I have a son-in-law who is a paramedic of Romero County and when my fiance and I bought our house he said oh I've been there many times because the people who lived there before were elderly so there is an understanding that local fire departments, CMSs, paramedics et cetera have hands to who should be cared about when there is a power loss and I'm not sure how to fit those things into a machine about what the protocol should be but I think there's a lot of knowledge there and a lot of local knowledge there that can play a role in fitting some of these gaps and that's I think what the CESRIC reports are referring to as well so the specific reference that I always made the most of the CESRIC recommendations from September 2014 that just practices this and their new best practice from September 7 which is on page 21 and 23 is now just coded local public safety officials should create disaster response plans that include plans for backup battery supplies in the same way they have plans for food, water, and fuel and power outages and so that's just one of the recommendations that they've made which we thought was intriguing along with some of the other ones that we picked up on in our chart Yes, ma'am Sir, what is the cost of this to like an individual they're already paying for a service and they had a service that they relied on and now they picked up all of these responsibilities and I'm hearing that they're supposed to pay for them Well, the FCC Right, the FCC requires only that the companies offer for purchase by the customer these battery packs or we can recommend outside vendors that they can go to Okay, so somewhere along the way the contractual base with the customers now shifted whereas what was being provided before that we assumed was going to happen has now shifted somewhat and so the customer now has more responsibility to maintain that service I'm not sure I would agree that the contractual relationship has shifted I mean, so what's happened is that a, what used to be a standalone voice service that was offered over a copper fed line powered line that was just voice service has been essentially replaced by a much larger bundle of services that includes voice but also includes video and data substantial amounts of data and the power that's required to fund those additional services is more than a copper fed line and I'm understanding On the other hand that basic piece was the light was the connection to the world in a sense for emergencies for family and whatever and as these other things became more important to all of us I think many of us did not recognize the power for safety and security you know, like I rent an outside, I mean I paid VTEL boards in 1970s for this outside service, you know, line business just for that reason and as I'm talking to people in town I'm becoming more and more aware that most of us really do not understand what happened to us it's a little bit like going into surgery and not fully understand the fine print I'm not the policy maker here I'm simply representing the companies that do this and and so I will say that I represent landline companies who have been offering service for 100 plus years and certainly we were aware as competition came along and it was fiber cut service and it was a very robust service and my clients were having to compete there were going to be some technological changes and so from my own standpoint, you know, I said to my wife we're not giving up our landline that's our that's the line that stays in power when the power goes out we happen to live in a rural community where the power goes out with some frequency so we were aware of that only because I guess of the nature of my work and the fact that I knew this technology was changing but the FCC, you know which was kind of guiding this process has been attempting to keep people apprised and put out notices for, you know, five plus years and I certainly understand and appreciate from the end user perspective that, you know, you're sort of the last one to hear about it but at the same time as I sit here I recognize that you and I are not unique how many thousands of people in Vermont are affected how many nationally and do we continue to rig our hands or do we challenge those wonderful technical technical people to fix it for us to develop that next stage well, I do want to say from the small companies perspective and this was reflected in our comments as well that my clients the small companies have been under tremendous pressure over the last many years from the state and from the federal government to convert their networks and to replace the copper networks and, you know, I guess the good news is they didn't do it so quickly that we're not sitting here with entirely five or five networks I mean it's sort of ironic that now the copper network is considered as gold standard when it's been probably the street if you talk to the legislators about finding funds in the high-cost fund to maintain the existing networks you'd be left out of the building because they literally tell you to your face that they're not funding old technology and I have been left building it's happened so I appreciate your concern and again I feel compelled to talk about cars and how when you get in a car I had a friend who owns a Tesla and we were traveling the last two days and his Tesla was parking a lot on over here and he could pick up his phone and tell me how much electricity and how much battery power was available in that car then I think of my grandparents on their 50th anniversary drove up to the reception in a Model T and the difference between what's in that Model T as a piece of technology and what's in that Tesla and how huge that difference is and it's hard to point a finger at somebody and say who's responsible for that and I guess we sort of all are because we like Tesla's hand duties when it came out it's just moving with the pace of society and I appreciate the concern of there's a gap here where you need to fill it and that's why I was really encouraged by believe me not from Ms. Neal talking about how they're going to do a sort of comprehensive survey that will provide data that will show where the gaps are so I think that goes to your other question but in terms of who pays the consumer because the consumer is the one that's buying that service you know you can live off grid and not have anything at all you wouldn't have to pay but if you want to be able to get to that EMS service you're going to have to buy something you're going to have to pay for some kind of of a linkage to do that and rolling for the question is what the sweat board has indicated and does not really think that the consumer should be paying and I don't know where that is on the other hand there is no figure of approximately how much people can connect it's so unknown what Ms. Neal was talking about developing will provide a greater snapshot into what the gaps are and then from that can be developed a dollar figure that she may have to pay for as part of the 911 board's desire to deliver the 911 services comprehensive she may not it may be beyond what they do but she may be able to come up with that right now they're just Mr. Phillips doesn't know the answer to that question I don't know if he knows the answer to that question although it's a very good question and we are participating actively of the 911 board but I do want to say because it's reflected in our comments that we first established the backup power requirement the clients that I represent offered that 8 hours backup power for no charge they were willing to do that as a service for their customer understanding that this was a new development and wrinkle but it was something that the company was willing to offer and it was only at the point that CC will change this past spring to require 24 hours of backup power that they said well that's a greater cost than we can bear so as our comments reflect the companies are still willing to provide that first 8 hours of backup power at no charge but it's the additional 16 plus hours that will have a charge Mr. Phillips what brought me to my peculiar last April was the fact that there are many people in rural areas where there's no redundancy of service to that cell phone and copper wire cell phone and fiber was that there are people who have lifeline on service they can't afford the kind of services that we're talking about here there are people who have disabilities and maladies that need to lie on the service and they need to when there are emergencies from the outside and they need to be able to reach 9-1-1 and they can't bear these interruptions and they can't afford to go by replacement batteries for $120 or more and they don't really have the means to monitor the gradual weaknesses of the battery so the best practices that you'd like us to address after the session are really worth going through in detail but we haven't talked about funding has to take into account people who can't afford to do it themselves some of us can bi-generate what's going to happen when I came to Montpelier in April I said you have to ask whether even a 24-hour set of batteries is an adequate replacement for the uninterrupted 9-1-1 access that copper wire phones provided this is a gaping dangerous hole in the phone service that substitution of fiber optic wire for phone services caused and while expansion of robust internet service to rural areas throughout Vermont is admirable expending large sums of taxpayer subsidies upon this expansion without simultaneously assuring preservation of access to E-9-1-1 service is inviting tragedy to up and down the road the message I come to you today sir is that I think you're going to be digesting and synthesizing for the PUC to report back to the legislature in act 79 as it asks you to do is there's a tragedy of waiting down the road if there's interrupted E-9-1-1 service and expanding for business reasons and for the education of children in rural areas they're great ideals but they can't be implemented at the loss of robust E-9-1-1 service for people who can't afford it for people who need it most just one follow up comment just because I want to bring this down a couple of levels is whether it's on copper or fiber and I think we talked about this last time there's always an opportunity that something's going to happen that will affect 9-1-1 service so obviously their conversation here is related to fiber and minimizing those effects but I just want to make sure that everybody understands that whether it's a snow storm car accident it could be somebody digs something up stuff happens and we want to minimize that and we all work very hard to minimize that but the reality is there's always that potential but at the same time that doesn't mean we shouldn't attempt to address this this whole that technology and the spur of the change in technology has created and the FCC has sought to address it that's what the C-Strip kind of represents doesn't mean we shouldn't talk about it anymore but when we do talk about it we need to talk about it recognizing that it's been talked about before and there are still folks because that's a piece of general support as well so that's a good point we don't know what's going to happen three minutes from now east coast we're just going to go out because of some sort of cyber-terrorism we don't know that that's about it I'd like to bring down to what we can do and I would say that Mr. Phillips was kind enough to respond to the question about could their systems identify the status of a battery or an external terminal we didn't hear from Ryan I think what I'd like to do is if Mr. Phillips is finished with his overall presentation ask the other presenters to address that in their discussion I'm fine I'm done we're about to stop rather than just answering that question now that we would allow folks to do what their presentation was and address that as well as part of it there's a question that I'd like to add to that so we can maybe process a few of the scientific things that are on it and if they miss it don't be afraid to ask I won't the mention has been made of the cost the FCC talked about a balancing of costs now the Vermont legislature did not talk about a balancing you might assume that they would consider cost as well as effectiveness in minimizing disruption but they didn't explicitly charge these best practices with a cost filter the commission does on its own right to do so and appropriately it was called to my attention that in my annual in my monthly bill to my provider I have a number of instances in different categories of something called the regulatory recovery fee and it's not inconsequential there's a 5.50 item there's a 26 item it may appear other times I'm not sure which is which but the apparently the definition of a regulatory recovery fee is something that is used to defray rising costs associated with compliance with governmental regulations and programs this assessment will ensure that we provide or we the utilities provide greater accessibility to our services in accordance with the state and federal law so the fee varies by service so here's a fee that is not a tax that has to doesn't go to the Vermont service fund it's retained by the companies so my question would be what are those money used for are they fully used and what is the constraint that would prevent they're being used to step up some of the 9-1-1 continuity requests that the towns and individual citizens have made so I don't think we want to get into a detailed analysis of you're looking for money too I'm looking for money and here's a charge that's to comply with federal regulations now maybe it's exhausted by complying with 2015 order there's zero money left but it is in the pockets paid by the consumers of the in the accounts of the telecommunication company so I'm wondering if we could get a little shed of the light on whether that source of revenue might be to some extent devoted to to the extent folks are familiar with it and they're able to answer that I've not seen the bill I don't know what the charge is for what the rate is or anything like that I'm not familiar with that charge I will say that I represent eight different companies that have eight different systems five different building systems I mean I asked Gordon if he has any familiarity with that at all I wouldn't be able to tell you exactly how that breaks down what it's used for to the extent it could be used for this it appears every month and the company is one of your clients and so maybe what we'll do sir it's a fun that telecommunications rate proceeding so I can't say that unless somebody else here can provide a general answer to that maybe what we'll do is in your findings prior to the next workshop we'll ask to answer that question what is that fee for and could it be used in any way if in fact it's something that all the telecommunication providers do charge of their consumers whether it could be used to fund batteries for that I mean I think it would be helpful in this context if Mr. Gibson would give us a copy of that so we could talk to them get people back to the company I mean I brought it for this reason because I'm curious does anybody know what that charge is for it's called the regulatory recovery fee I think it's a fairly standard thing but I'll only deal with one just for a general answer if you don't that's fine I can say that different companies collect money under that group for different purposes that some of them collect their universal service fees under that some of them collect fees to serve their staff who have to file multiple FCC funds and some of them have it all on regulatory recovery and I don't know which companies are which I know our company doesn't charge any of those but I don't think there is an answer to that question it's a broad category that people use in different ways but it could conceivably fit paying for backup batteries given the fact that you don't have any other definition so to find the money you can either raise your rates or create little fees or pass it on to government but one way or another the money is going to be found and it's going to be named whatever way everyone wants to or unless we're directed to One point the FCC does have some consumer information on how to read a telephone bill subscriber bill I believe that they have a definition of regulatory recovery charge because I think it is something that most all telephone companies charge we're talking about the cost of the backup batteries here and it seems to me there's just been a real cost shift here you know following up on what Cecile said and Jonathan and Chuck as well we used to pay our phone bill and the phone would work now we have to pay our phone bill and if there's a power outage we have to pay for a backup battery and maybe if we have eight we might have eight hours and if we want more than that we have to pay an additional charge for 24 hours for 36 hours whatever it may be and it's falling I think very unfairly on the consumer being a small rural town in Vermont where most of our residents do not have deep pockets it's like why is this cost for a service that is supposed to be provided I mean I think the model for the telephone companies is to provide telephone service and yet it's not the service that's being provided without this charge and this charge and somehow there is as we said before there's got to be a balance there as to what is falling on customers for these charges or now perhaps on first responders or on communities seems to me and some of those charges really do belong with the telecommunications companies we're not going to resolve this issue I just wanted to but might do something and I'm thinking about my friends my friends Tesla and Tesla has cameras on it so that he can see if there's somebody around his car it has it has that app so that he can know exactly where his car is and see everybody around his car those are consumer products that he was willing to pay for with the technology and you know he can't buy a model T you know you can't buy a car with a crackdown window anymore you can't buy a car with a knobby radio you can't buy a car without a GPS practically anymore so it's kind of it's an industry function that you really have a heart is it the consumers fault is it the companies fault or is it just the pace of history's fault it's a hard question to really resolve we're not going to resolve it Brian it's a good question to ask I would like to just add that there's another player in the mix which is the regulatory agencies because this is not simply a market based service I mean it's a competitive service but in the face of my clients they're all designated as eligible telecommunications carriers which means that they're carriers of last resort they have to serve a customer because they do receive federal universal service funding for that privilege which they greatly appreciate but the amount of that funding has declined significantly and along with the decline in the revenue stream from the federal pools has been a concomitant substantial increase in the regulatory obligations so as part of an ETC designation now you are required to provide broadband and one of the supported services so you're no longer able to just provide the voice service that you used to provide you have to provide the broadband along with it and as I said before we're simply the companies that use the technology we're not the inventors and the designers of it and this technology comes with vendors and equipment providers and all that I would also just add that these state-wide there are communities that would absolutely kill for the kind of services that your town has yet and maybe they're not aware of the back-up power obligation but they are aware of the speed of the broadband that you have and what they're looking at is broadband and high-speed broadband as a economic development force that raises property values in towns that creates jobs in those towns and work from home and so there are tremendous economic benefits that come to the communities along with the broadband so I understand that you feel as though it's an unfair burden that you're bearing for the back-up power but what you're receiving is something that other towns are salivating two points there I think a lot of people did not understand that their phone was not going to work when the power was out for an extended period of time and I think that's almost universal from people I've spoken with they did not realize during prolonged power outages my phone was not going to work so I think there really is a need for greater education along those lines my other thing is just the cost shift you know we all welcome faster internet greater broadband speed that's all wonderful and I understand everything you're saying I think my concern is just the fact that really if you do want to use that phone you're going to have to pay an additional charge for it it's not just phone service any longer and that it falls on the consumer solely on the consumer yes Ben the Tesla still goes and it stops okay the Model T went and it stopped what we are working toward here is a both and we are not really wanting a world of either or and I think that is the dilemma is how do we create and somehow maintain the quality of life or safety for the period of time every corporation in America is working on safety and the fact that we at home now have so easily let that go is a real surprise and because we're not paying workers' comp I guess we're not expecting to notice but I think that the conversation of compliance and new technology is really a red gearing at the level of the both and I'm sorry at the level of what? of both and thank you we're really wanting both and maybe some people would say it's having our cake and eating it too but we know that technically we've been able to do many things that way the difficult question you said was so difficult to answer I think perhaps you already know this but the person who's been asked to answer that question first is you and the act said recommend best practices for minimizing disruptions E9M1 services during power outages through technical and financial assistance to consumers and communities so I think it's within the scope of this assignment which is like how do we how do we fund services how do we fund providing I'm not denying it I mean, that's the challenge I don't know that I'll answer the question and I don't think I should because that's not within the authority of what I can with the commission but we can propose possibilities they're asking for the recommended best practices and we can see what some needs are and that's why I was interested in this regulatory servicing problem quick comment I'm just, I'm not sure if Mrs. Beatty meant it but I thought I heard looking for a technical solution and as long as we're using erythin virus at last to deliver the voice back and forth there is no way to deliver power to those devices I think you can do that but I just want to make sure that it's clear to everyone in the room that the only solution is to provide power at the other end it's not going to come from the power company during an outage and it won't come from the communications company because there's no conductor of power to the other end so it has to be a battery or a generator or solar or something like that and so the technical solution is to be under graphs when the copper wires are taken away and not powered unless there's another form so could where the wires are not taken away and where there's not cell service in a rural community and where there's a demand for and provision of a good internet broadband services could is it technically possible for all non-technicians but is it possible that the remaining retained copper wire or let's say that which was pulled but could be returned in specific instances could go to a call station I don't know how these micro-cell things own poles are supposed to work maybe they extend cell coverage where there's not a good cell coverage that's one solution that's been proposed in fact the legislation talks about micro-cells and getting them out of warehouses and around the state and communities have been sent letters I think by the department you can confirm this or correct it saying there are some of these devices that if your community would like to locate some and propose to obtain them we should pursue that but my question is more about the telephones that are beside the road for motorists is it possible to have some as a maybe as an only an interim as a short term thing but a place where someone can go and make a phone call that is powered by nearer one of the field stations the field office is where the remote terminals near one of those or with the line that's been retired but it's still there they can be connected to a simple phone box where somebody can go if they really need to get the fire department to come and they can't reach them that's a is that a technical fix or is it just too preposterous and far out to work well technically you can put a phone out there if it's an emergency situation you have to drive two miles that's the problem with it it was proposed to me to ask the question if your house is burning down or if you're lying on the floor with a stroke you're not going to drive in your car and go even a quarter mile maybe that's where my son in law drives there because he knows there's somebody you have that problem and just checks that as part of the emergency response plan instead of relying upon a technology to do it so I would like to hear from the fiber companies that have never had circuit switch networks because as we know from the 911 I have been allowing the questions but I do want to get back into the cycle here for 80% of the 911 calls in the state of original so I think it's important to hear from them absolutely and we can do that now please okay I'm Jim White from Comcast and we made a very lengthy filing about our current practices it shows the information we give to customers the acknowledgments they give what's available on our website to give customers lots and lots of information about our service and limitations in the event of a power outage so just from the beginning we've been a connected way provider but we're an alternative provider we've never been line powered so from the very beginning it was clear to for the preservation of 911 service during a power outage that there would need to be a battery in the home and we start out with right from the beginning we'll need to sell a new customer voice service by federal regulation they have to complete an E911 acknowledgement and that's in paragraph 15 in our filing and it mentions the fact that there's a limitation during a power outage so you might need a battery backup that's step one if the customer does not complete that acknowledgement the order will not flow through it will not flow through the next thing happens is we have a battery disclosure statement and it's attachment A in our filing again it's very clear that there are limitations during a power outage once the service is once the customer gets the voice service many of these are now self-install kits you get a modem and you can provision it yourself usually with your cell phone or a few steps you can do this you get a welcome kit the welcome kit there's a snapshot from a welcome kit there's a very clear statement in there it's in addition the modem the modem comes with a battery sticker and this really goes back to 2005 when bondage was one of the first internet voice providers and all of a sudden I think people at the time were unclear about the limitations of calling 911 perhaps and the FCC required battery stickers so along with these stickers that come along with the service so when the self-install kit comes here comes the sticker as well right now what we've done over the past there have been many different kinds of modems as we upgrade our technology and upgrade our speeds we've changed the technology of our modems so we had a number of different kinds of modems each with different types of batteries what Comcast did when the 24-hour requirement came out is we now moved to one battery one 24-hour battery and one type of modem so now that the battery is depleted when the customer calls every once a battery what they get is Comcast's advanced tech it's called X-Fi Art we saw our products under X-Fi so X-Fi is our advanced gateway for modem they get that and they get a battery specifically designed for that modem it looks like Mr. Phillips adapter it's connected to a laptop it doesn't get inserted into the modem it's an external battery and there's a picture of it in our file it's a little bigger than the adapter going to Mr. Phillips laptop everybody knows what those look like so it's not everyone understands how to plug it in or get into the laptop and you plug it into the modem so we also give an annual notice and there's a sample in our file a very clear annual notice about limitations of backup battery we have lots of information on our website for example we attach these for example how to stay connected during storms what is E911 service what does it mean we have additional information such as if you have a cordless phone that may not work in a power outage it's not going to work in a power outage we advise you to have a corded phone we advise you to have a cell phone as well and we this multiple links in our file about the information we get customers so now in addition to Mr. Gibson's question we do monitor we do monitor we do call customers and the battery is nearing is depleted or nearing depletion we do that with a phone call let me just back up a little bit after all this notice the take rate for batteries is less than one percent and when we call customers I get to say now during this world of spam almost none of our calls are answered and it doesn't tend to generate any very very few requests for batteries this is a call that says what our calls when we we call customers that your battery is depleted or nearing depletion they don't answer the phone most of the time that we leave a message the battery is nearing depletion it does not generate a response and the some do I'm not going to say none but it just does not generate you said less than one percent of the batteries I'm not from the initial offering I'm not sure what the percentage is of those when the batteries depleted so we understand the position of the talents and you know I think there's a certain element that the technology has just changed if you look at the number of customers taking basic phone service from Consolidate at the IRP it's 60 percent I don't know what it was 10 years ago there's a decline so many more people are shifting to cell phone service so the Comcast we have a fair number of voice subscribers those are declining I'm not going to take exact name but those are declining as well more and more people are going to internet and cell phone are changing life changing technology change in the era but we feel that we're compliant you know we feel that we you know do a good job of trying to inform customers of limitations of our service and you know we noted in fact that the Vermont DPS website has information on VoIP that has public links of the limitations of VoIP and you see has that I believe that I wouldn't without Barbara here I wouldn't want to confirm this that sort of even that you know I'm one board I think might even have a risk with VoIP on it so with respect to costs one thing the FCC said is that it found in its order is that recognizing that someone's going to pay for that one way or another in the end I hate to say it does stop mercenary but in the end customers do pay one way or another through their charges and fees somehow it's just the way business is operating so but if a customer doesn't want to pay should they pay for those who do I mean that was one point I'm just throwing that out there's one point that the FCC made and that they didn't want to impose that on everyone. Now podcasts were not on ETC we do pay into the universal service fund so our customers aren't contributing to 9-1-1 relay service connectivity fund and things like that so it's basically our presentation thank you we'll take questions now couple of questions well for one thing we're a small world town we don't have cell service I think that's one of our great concerns about the fact that when we sit along the spine of the Green Mountains we get horrendous storms going through there and the power goes out and I do have to say as far as well it used to be CBPS now GMP they've really done a lot to minimize those power outages I mean it used to go out quite frequently and for days at a time that has been substantially reduced and we're most grateful especially because we don't have cell service it's not an option at Porus at the moment it's very dependent upon that phone line especially when the weather is bad during those power outages and I wish it was an option for our residents to just have that cell phone I'm just wondering how long did your battery back up the back up batteries last the one you used? well it was 24 hours if you talked on it for 2-3 hours and drained the battery down I'm not exactly sure how quickly it would drain but it would provide the 24 hours and our website advises people to limit you know calling to limit your non-essential calls things like that, there's information about that on the website do you have a charge for your batteries? yes it's right now it's $165 or what kind of battery? it's a lithium ion and it's exactly what capacity 24? well it's 24 hours it's a single battery for 24 hours and that's it there's no 8 hour there's no 8 hour it was getting too complicated we had too many different kinds of modems out there with different batteries so what we did this year is someone wants a battery for an older modem we send them faster modem and they get a new battery although they do pay for it is that $165 installed on the premises? it's $165 and it's like that adapter there that you plug in, there's really nothing to install they don't need a service visitation they could have one but they would be out of the house literally it's an adapter that looks like that you plug in to your modem there's a picture of it in the filing I was looking for it it's it looks kind of a smaller drawing I just wanted to follow up on Mr. White's comment related I know we've talked a lot about copper two-year point we see a year over year about a 7% decrease in traditional telephone service over the last decade or so so to the point that there are areas where there's no cell coverage where there's no potential wire line competition but in Vermont there's a lot of areas up to 75% in wire line competition there's cell phone coverage and certainly the major metropolitan areas a lot with the population exists so we've seen a vast decrease in our traditional copper telephone service wire line telephone service other presentations who would like to make a presentation that hasn't done so? I can speak but I have a presentation because we do not deliver voicing so we don't have a standard operating procedure we will do soon which is why I'm here and I want to learn and contribute to the process so I'm sure that I will replicate some of the things I've heard some of the things I've read in the FCC document some of your recommendations but as long as I'm speaking I'll make one comment that suggestion that when you do your recommendations to the board or the commission there might be a distinction between different kinds of entities that provide voice services certainly local exchange carriers are carried with them a certain obligation and information services don't necessarily carry that same obligation and are overlaying local exchange carriers so there's still the opportunity to have say a landline instead and the other aspects of that is there's a distinction between a national mega corporation and a small community based internet service provider in terms of their ability to fund the things that some of the people from the towns are suggesting might need to be funded by the providers if we were to provide $165 battery to each customer to take voice we wouldn't have to deep pockets to support that and Comcast doesn't either they charge for that but some Blacks do provide so the distinction between large and small companies is important as well and the FCC even makes those distinctions in awarding points and options for licenses and exempting through USF and other things that has to be taken into account as well or should I recommend that it is at this time I just might add that when the requirements said 8 hour back up battery charge was $75 and the take rate was slightly higher but not by much $71 the take rate for batteries was a little higher than it is now at $165 or 24 hour battery but it was extremely extremely small $75 it used to be $75 for an 8 hour battery now it's $165 or 24 hour battery and the take rate was still I think it was maybe just more than 1% and that's a national figure I have a question for Mr. White and that is would you say that that 1% take rate or whatever the school one is because some customers admittedly most customers just don't want to spend money but some customers might find alternate back up battery systems to take their modems into absolutely and we do have customer another level of difficulty is that customers can use certain modems that are compatible with the Comcast system and they can get their own batteries and we do not monitor batteries you know kind of bring your own that we haven't provided them we don't know what they are we can't vouch for them or anything like that but customers can bring their own modems and they can bring their own batteries so that were the case that maybe 10 or 20% of going up there and getting an accurate modem and an ATC battery to plug in you wouldn't want to charge all of your customers a uniform battery fee and we were bringing their own and out of interest I'm just curiosity last night I went on the internet and the battery for our current modem is called the XBD1 I believe and I found a number on eBay used you know the sound will say it's reliable and all that and we have no way you know some of these are coming from China Mexico, the other place in the US I don't click in there they were and there's no way but who knows what the real status of those batteries is I guess it means that some people know a lot about the need for batteries I'm bringing me back to what we want to do maybe in our next session which is to talk I think one of the larger concerns I have is people just don't know that they have a place where we're in a protocol despite the the E911 disclosure thing that they're supposed to sign when they get it they just don't know that there's a difference how do we overcome that how does the state in its public safety capacity overcome that and I know that consumer education costs money and is it the responsibility of the utility to do that or in fact the utility is being the federal standard already is it the responsibility of the slide board to do that and it's their people and they know who their people are who never read their flyers or maybe they do it isn't the department's responsibility it isn't the E911 board's responsibility we haven't talked about Shrewsbury's proposal the E911 utility I I ask this to talk about what they do first so that could inform your thoughts because I think they do what you were thinking about no go ahead well we've already been at this for an hour and a half I'm not sure when she's going to be back are there other comments we can wait yes ma'am can I ask a question of what you just said is it possible that this is really because of its extensive nature a shared responsibility every group that's involved with the public in this state of their mind somehow needs to inform them of the difference of the problems or the possibilities one can say it's already a shared responsibility and we're at the result of your act because it is that shared responsibility and it's delivered in the way that it is how can you police a person who doesn't read the flyers in their algorithms and when they sign that E911 thing I know I I don't have voice over internet protocol but it wouldn't surprise me if I got a package of things that tell me to sign all these things I would just sign all the places where there were X's without necessarily even with the expertise that I have and as a lawyer I would just do that because I want phone service without necessarily being concerned about this particular FCC protection that's out there and how do we overcome that that interest and knowledge sure a lot of people aren't responsible for but this is an opportunity to recommend to the legislature a protection fix and what should that be and at this meal you have really good timing because we were just talking I apologize that's okay but we were talking I think one of the principal issues that's out there that I think troubles of towns in particular is people don't know that they have battles if they have or what to do there's a difference between finer optic service and copper service generally with regard to loss of power and emergency services and what's the best way and I know the legislature points to that is what are the ways we can best educate our consumers so that it would come down I'm not sure what kind of role E-91, one board projects to play we're going to talk about what your vision was so that you can hear it and we can see what the distinctions were between what you all do and what he's thinking about Mr. Schultz before we get to that I wanted to follow up on something you were saying also that we were talking about in terms of share and responsibility since I make a comment like this in every workshop which is that at the end of the day we're talking about an outage that lasts longer than 24 hours there is some responsibility on a part of the power companies and I think that's reflected mostly in the part of acts 79 that deals with the E-91 one board because it actually talks about the power company's responsibility for maintaining one one accessor and power outages but I don't want to lose track of that thread that the FCC rule is for 24 hours of backup power I think that's a good connection if you go beyond that then you're in the level of the local police I'm sorry I was just saying that if you go beyond that 24 hours then you're in a different realm and I think that's the realm in which you're talking about electric reliability or in combination with local emergency services what is the disaster type and then this power beyond 24 hours how do they take care of their elderly when that occurs do they even have ambulances that they can send out can the firemen get there to do anything even just checking on people you know I've lived through a number of major natural disasters and everybody does their best that there are all these gaps planning helps especially post event planning and how can you fill those gaps and that's kind of what we're doing here is attempting to fill both the short term 24 hour gap at the FCC and also to fill the gap within that gap and then to go look beyond as well so yes sir I think each town has a group or person responsible for the antialid in the town the three addresses so there is a function in every town making sure that the addresses when you call 911 you've got to get the address in the phone number safe master street there is somebody in each town performing that function so that when emergency services are dispatched to go to the reckless there is some kernel in each town already associated with the 911 right that's correct the school coordinator in every town that's actually required by statute and we rely upon them to provide the address data for their towns when new buildings go up that address has changed they provide that data to the 911 board not only is it important for locating callers on individual calls it actually drives GIS data drives the next generation 911 system that's how call routing is done and how it plays a critical role so but yes there is a person in every town who has that responsibility what did they know where everybody lives well he has they tell us often it's like a zoning administrator or somebody in municipal government sometimes it's a volunteer other times it's someone who's in pain within the town or city government we typically have a different role and I could see just speculating about it that a larger urban setting the concerns we're talking about are quite as great because hospitals are not that far apart or emergency services are not necessarily that difficult to access it's a larger concern and the reason why we're seeing folks from small towns is because it's the small towns that have that concern and there are going to be a finite number of people and not the only has 630,000 people you know I live in Montpelier and it has 4,000 my fiance lives in Waterville and there are 630 and there's a distinction between those places and it makes it easier in some ways for the towns to play a role in the small towns than it is to play a big town but that is the best equipment we expect I'm not quite sure where this fits into the conversation we've already been there while I was gone so if I'm duplicating I apologize but you mentioned what role the 901 Board might have in this conversation and one aspect that I'm certain of but it's not the only aspect that you might have input on this one is the consumer education or the public education piece of this that's what I was hoping you would say well it is critical and historically there have been many changes in telecommunications technology since the 911 system came into being 20 years ago so then nearly every call was from a wire line telephone company presumably copper lines you know the line powered systems and then not too long after we went live came wireless technology and there was consumer education that was required of that so that people knew that the location information that a 911 call taker gets when you call on your wire line is quite specific to your specific location not so with your wireless phone and there was an evolution with your mobile wireless phone so there's been an evolution even in how accurate the information that the wireless carriers provide us there's been an evolution and it has improved but it's still not 100% it's still not so people need to know that they need to be aware of the technology that they're using and the benefits and limitations of each type of technology so we have some information available now on our website it's something that we are looking at to improve and also improve our outreach and likely would be through efforts with the public service department as well I think that would make a logical sense and I'm not saying that that's the only possible but I think it's critical it's kind of off the point a little bit in terms of the NELE database so one thing we offer it's interconnected void but it is still going over the internet although we have a separate channel it's still an internet type phone but we require our customers you have to have a registered location if you have different kinds of internet phones or you can take your phone number will follow you around you have to have a registered location so it can be put into the NELE database so it's accurate you can't move it Mr. if you could start with talking about the two provisions for your e911 could I have a few minutes to talk about this absolutely they weren't going to be convenient just to talk about this battery since it's out there I'll go for it alright I have a question for Comcast that's relevant to the discussion I think I'd like to ask it I'd like to talk about this and some of the positive and some of the better and some of the what is that this is a battery I can see that it has a battery it is a Bperiod battery VRLA rechargeable BP7.2-12 made in China VTEL put in at their expense in my cellar and I expect that in a town of about 1100 people I may be the only one ever to have held this in his or her hands it wasn't that easy just to disconnect to bring it up here I mean I wasn't sure that I might bend this little wire here that slipped down on the negative positive terminals and thereby have to buy a new one so this is it this is how I as a customer provide support for the infrastructure on which the companies customers pay their fees and I among them but what I wanted to segue from I mean these are not many that comes in a housing power unit I could not disconnect it because I really would have disabled my system I hope I can reconnect this when I get home but I did go to in fact I mentioned in a positive mention I want to reiterate of what our provider VTEL enclosed in a the last bill which was an attention getting yellow notice that says you can learn more about your battery dependency and how to take care of it by going to the website so I did go to the website and it included the same four pages the that we submitted as an exhibit previously we the town of Shrewsbury the VTEL gave you home battery information it's a four page flyer the last page says data our batteries replacements can be obtained at Amazon.com or at bat.com as well as the following local store Great Bar in Rutland, Vermont it has now since since April it has an additional four pages how do I connect to a 20 hour EPBP EPB sorry EPB and that's noted on the other flyer as well with a video it's a seven minute 23 second video which I want to say I was I found very positively impressive a woman is standing by batteries including the cyber power unit which she uncovers to show this battery and then there are some additional batteries that can be purchased for the 24 hour service I would say that that's it may not be a best practice but my telecom does offer a video I would wonder and maybe we're not going to be able to get around to each of the representatives here but I think it would be useful to know maybe they could respond in their written follow up do you have a a video that actually shows it shows how to do some of these things it seems to be pretty simple there's a plug in it's like what Pumpcast apparently says at least for the extra batteries I would like to know from my provider VTEL how many visits that particular video has had I think that would tell us something about the responsiveness whether it's less than one percent more than five percent eighteen and a half percent of the customer base how many people have actually looked at this video maybe it's just me this morning I don't know but maybe the company can tell us how many visits you had on this I then do you want to answer that question I would just say it's at least two because I looked at it last week Jackpot and so we have I don't want to extend too long either I mean I don't I wanted to make this final observation which is not such a positive one I did call great bar all right and I'm not sure I'll find my notes here but the person said we're getting a lot of calls the state of Vermont has been referring a lot of people to us and we actually you would do much better to call interstate now we brought some to the attention of the first workshop our calls to great bar which finally ended up in there saying stop calling us we don't have it we can order it this person was very helpful I certainly appreciated and expressed that he said look we could order it but none of our warehouses across the nation stock it you told me to go there it is that battery you have no it's the well I'm just calling about batteries I said eight hour or 24 hour and he was answering for both we don't we don't stop those we do other they provide other services to electricity electric customers of various types they're well regarded I think very hard is but they don't have it in their warehouses they could order it he said frankly you know if you have to pay for shipping and handling you're going to pay more with us detail then you would by going to our competitor interstate they have them under direct supply and so I mean I really think that between April and September it's not a good practice it's not a best practice it's pretty it's a bad practice to be referring people with your card to a website that didn't refer you to somebody who tells you don't buy from us buy from somebody else now the web the video has several other parties there you can also buy from some solar units it does just happen to have suppliers within their service area I'm in Rutland Perkinsville and Springfield are not as handy to me as the people that are in if you yesterday were installing the town of Shrewsbury so I mean I think we could look at the entire retail service area that would be a better practice to give the list of a comprehensive list of suppliers in a wider area for solar backup and for available better so I'm making a few points that are both positive and not so positive and I think this offers I'm trying to offer an example of the kind of detail of comparison that we could and should engage in and looking at what various companies are doing my question was to the Comcast I was injected in the stock was we have had an offer or a proposal from that 8th to voluntarily not if directed or required but voluntarily to offer some better practices that some of their some of them do offer and I would wonder if and Comcast's submission which was very helpful and thorough and informative did not in any way talk about best practices just talk about current practices and they're being compliant so my question would be it doesn't have to be answered now a little bit too long perhaps but is would you subscribe and would the other covered service companies subscribe to at least at a minimum that same list at least as a voluntary and then we'll get into discussion about what perhaps the legislature or the EUC might wish to require but I would like to know if that which I thought was a very interesting and positive proposal from Mr. Phillips his clients would be a proposal that others would join in and I'll speak about the alternative entity that some I'd offer that you can if you're prepared to answer that I will require that you answer it before the next in writing before the next meeting so I may want to defer your answer to Lance and I think more reserved comments I think you know to lump them all together as best practices without identifying specific ones and the costs etc you know I couldn't answer that now in addition we're on a national platform you know a little part of something national in scale I have the same thought that would be useful to find out one of the larger company thoughts about the IRLX proposal as well which is what I asked in the next round of comments on each other so we can capture those you know I can do a lot I can do what the guy like said if that is an answer or not yes can I ask a this is Clay Burvis of the department can I ask a clarifying question of Mr. Gibson and maybe a VHL as well you spoke of the battery was there a battery a single battery that fit into the same housing or are you required to buy additional housing for that battery and is that a separate issue from your efforts to buy the particular battery replacement well as they sometimes say I'm glad you asked I was just inquiring this morning about a battery this type of battery or a 24 hour battery a single 24 hour battery on the VTEL website and Comcast has referred to a single I believe a single 24 hour battery so there are all kind of batteries out there and VTEL's website pointed to some other sources the question that we need a technical answer for is whether any of those other batteries that are out there in the marketplace at differing prices and shipping and so forth are they compatible with the housing that VTEL installed and that I'm sort of you know set with if you will I'm not technically able to say I could go to a whole other system and still tie it into their optical terminal network terminal I don't know that but I have been told that the answer is no that I've got to buy a certain type of battery and a certain housing has to do with the leads or how they connect or something from the battery pack out to the optical network terminal so I really can't shop around necessarily I haven't tried the shopping around to buy those things just to try them out one after the other but I believe there may be some constraints by what VTEL shows knowingly presumably I mean they didn't know anything about from a vendor to put into their customers houses residences or places of business I don't know I think that's a very very important question about compatibility Mr. White has talked about customers are probably dealing with things to hook up directly to their motor now this is a this is a different sort of setup I think right this doesn't power this doesn't power the motor this powers the outside terminal that is probably not functioning my wife is hoping to use it but this had nine hours left when I checked it before a preceding workshop I just unplugged so it didn't get any power like I'm picking up the phone I think I related this proof it wasn't as some of my neighbors were trying to say these terrible utilities only last one hour I mean it lasted nine hours I was pleased that I had but right now it's not functioning we're supposed to that's a fairly standard battery you'll find dozens of places that sell them thank you the way to distinguish one from another how many amp hours do we have how many terminals on the top these guys they vary a little bit but once you know how many amp hours you want and the dimension and whether the terminals are on the top of the side you can then go online or go to battery places generally speaking and they don't know them as 8 hours or 24 hours batteries they know them as so many amp hours it's got to be the right numbers the whole stage but those are very standard and will they work in the housing that I have you're saying they're very standard but we had a big discussion on our tongue listserv about people trying to find these batteries and the only solution so far they have is higher electrician who comes and rewires the connection to the retail somebody under your service to tell people that they can just look at the label on the side and then go online and copy that into google and find them she's referring to the same thing that I've been informed of a person who is quite technically knowledgeable that there's something about the connection from the housing to the an ID or the ONT the conclusion may be that the housing that you're talking about is specific to the system so the housing is what essentially interfaces with the ONT and it's a standard issue 12 volt that's why we give you the model it can be swapped out it's not a battery that's specific to the backup unit that's installed when we is this supposed to be easy for Joe Hull owner? yeah it's not as easy as swapping out a flashlight well it's not because a flashlight battery is a pair of C batteries or you have AA batteries but in terms of connections and how long it takes to do it you open the unit you take out the battery this discussion itself illustrates that this is a consumer problem this is something that ordinary codes need to be educated about we recognize that that was part of the feedback that we took from someone and that was part of the the impetus for creating a DIY type video that you can find for pretty much anything these days and you can step yourself through it you know there's about 3 steps to replacing the battery and it looks like we've got about 100 people doing that so far I'm sorry yeah give it a name call it something it's a 12 volt and not a 2 model number so you can find it it's just not a cylinder that's lead it says there's a big X here that across the garbage can well you know it seems to me well I was just going to say that you know this it's back to what I was saying before which is that these companies aren't in the business of designing the equipment they're just in the business of using the equipment to provide a service and so what we're proposing in our comments is additional consumer education including item I think 4 hours of DIY instructional video for consumers to see you know a person doing it so they can follow along and do it themselves and we're not going to be able to redesign the batteries make them more like flashlight batteries but the best that we can do is to make it as simple as possible for the customer to learn how to do it and that's a big step because that and how we should not yet happen in any comprehensive way and that's really one of the things we're looking at I'm going to figure out I think that was my comment is that you know phone service used to be easy you call the phone company they install the service use the phone and it's become much more complicated now you know we welcome the services the additional services that come but there really is a missing piece there in terms of consumer education about what is involved with the cost is of having those additional services and this backup battery business I just I mean between the technical knowledge the limit of the life how you can extend those batteries how you check them how you monitor them how you replace them and then back to the cost I mean there's a lot that still needs to be addressed there and I think it would be wonderful if it didn't all fall on the customer adding to that I mean we have put all the different providers of all different services in one bin and earlier we're talking about a Tesla versus a Model T but for the residents of Andover we're not talking about choosing between a Tesla and a Model T we're talking about the road you cannot get Comcast in Andover they don't offer services there we are reliant on our state regulated utility for telephone service most of the town doesn't get telephone service there is no competition for retail for telephone service in Andover so I'm worried that the larger issues for all of the state you know Burlington gets a lot of attention Montpelier gets a lot of attention but if the state is regulated and the state's laws only work for Burlington and Montpelier they will not work for Andover because we don't have choices we're not deciding between a Tesla and a Model T we have one road in this town and it's retail and they have a monopoly because it's a tradeoff between being regulated by the state and having that monopoly there's also the issue of how do we serve clients who aren't served by the marketplace which would not be Andover it's a very small town people don't want to compete there there's nothing to compete for so I really appreciate hearing all these different ideas but I also want when you're thinking about just the legislature I hope you'll consider the fact that there's a lot of different issues here not because for some people they have choices and for some people they don't have a choice that they and for now this choice is an extreme change for over a hundred years people have expected the power for their telephone system to come from the telephone company we all understand that there's a battery to work the telephone but for the telephone system this is a huge change in a small amount of time and it's certainly for us and Andover taking a while for us to catch up but I have to say I don't know if that was a good change and as you're considering this in other small towns in Vermont whether they be subjected to the same thing what thank you Mr. Gibson did you want to talk about your E911 utility and we'll recollect that earlier you were going to give Mrs. Neal a chance to talk a little bit more about what they do maybe maybe that is suffice I don't know I'd be happy to do that if you get a very high level the 911 is responsible for the oversight of the statewide 911 system so we provide through our contract system provider the 911 system to which telephone companies connect and process those 911 calls and get them into the hands of the responders who then respond I don't know what level of detail I think it might be useful Mr. Gibson if you talked about your envisaging and then she could talk about whether she fits I would love I would love to for us to have a more extensive conversation that I think we're going to have at 335 today about this maybe to some extent it could be continued at the 4th workshop if you're not prepared we could wait I well I'm not fully prepared but let me just do a little intro and stop there because it isn't intriguing any I want to make sure we're all here well and I don't think I was the only one to mention it maybe at the first workshop as I understand it was in the 90's that electric utilities were being expected by some quarters of the society to offer energy conservation services as well as energy supply services and they were doing this in a fairly they were doing it in different ways and some were going fairly far to offer different kinds of information and services and maybe some financial incentives for people to buy new water heat, more efficient water heaters insulate their houses, what have you so others work and in the around 2000 per month the idea of an efficiency energy efficiency utility I believe I mean the public service department has a description of efficiency utilities, I don't need to read that but it is available on their website the short summary of efficiency Vermont how it came about, I mean not how it came about what it does and I have actually in front of me now an early description of that it's further outdated now so I wouldn't think it'd be too valuable to circulate but Vermont as I understand it was was created and then was modified about seven or eight years later maybe around 2008 in terms of its structure and the legislature is as I gather what and the public the public service board were both involved in in the creation and the structuring and it's an order of appointment it's a contractual sort of arrangement monies flow through an energy efficiency charge on electric consumers build and what efficiency Vermont has done in my community and my house and around the state and in a way that's exemplary in the nation is to help people save energy, save money energy, address climate change whatever agenda is at the top of the list if not all three combined and others and they've done it very well and the utilities certainly have their own programs and incentives and outreach but efficiency Vermont does the job and it just struck me anyway and some other folks that we have a situation here where there are gaps maybe they're limited to the rural towns that don't have cell service maybe it's a minority of the customers of a you know the people who don't have generators but it does exist it's a public safety issue it's very real my community got involved in the outset because we had a two and a half day twice the 24 hours and people were without and didn't know what to do and didn't really connect the dots until they said oh you couldn't make a call I couldn't make a call either what would have happened if you had a chimney part what would have happened if you had an accident how did you pay your overdue payment if you couldn't reach your credit card information whatever it might have been could reach a service provider so it seemed that maybe the utility seemed to vary in their practices somehow the videos some don't some will send out an installer and let the customer pay I haven't heard anyone who says we can get you alone you know we can help you we're working we're working with our local comprehensive community action agency which has a low interest loan program or which has followed a number of these batteries in bulk and you can get it from your town or from your community service agency if you're a lower income person or a special needs person or just a customer who you know is not too acquainted with this we can actually get it installed like like officially we're all sent around teams to install the insulation and other energy saving efficiency so it seemed to me that energy saving measures it seemed to me that there might be a model there where the utilities vary they don't really want to do too much beyond what they're required federally maybe there is some reluctance or some inability of the state of Vermont to require maybe what's needed but of the utilities but that doesn't mean that what's needed shouldn't be delivered and provided and perhaps there is a mechanism analogous and we'll have to look at it and just see what the comparisons what the differences are looking at efficiency Vermont structure and contract and evaluation procedures maybe there's a way to a value in having it considering the creation of an entity that would provide these kinds of services that aren't being provided presently best practices financing opportunities technical assistance on site individual interactions with customers information to customers how would that be paid for we talked earlier about you know you got to find money for this stuff if it's worth doing it's worth finding it's worth paying for maybe a I mean I alluded to the regulatory recovery cost I don't know where they're being used now but there could be other Vermont instituted charges that yes everyone would have to pay for but that would be in the society's best interest that's as much as I'm able to say at the moment in terms of what the concept was that and that concept I think must have been included in the legislative directly because it said or other entities alternative entities without specifying what but I think that that might have been a concept of the state house and there were some conversations about you know if the utilities can't do it who could and I did not hear a reference to the 911 board doing it they are referencing another section of that statute to do to do their rulemaking but not here so maybe it was maybe an efficient E911 utility was such an alternative entity and the legislature would want to know if the PUC has looked at that as part of its mandate to report back with recommendations and it needs to look at it so maybe it's up to you to decide how we look at it Mr. Dering officer this may take in a little different direction than Jonathan in Shrewsbury when we came back from one of the first workshop several of us met and it was a brainstorming session and some of the things that were talked about were how do we get people back up generators are there hand generators are there solar battery charges what do we do to reach out to people in the community in the neighborhood should we do the neighborhood groups what about satellite phones what about locations in towns fire the volunteer fire station the town office other places where people could go or where there could be a small mini tower what about the 2G towers what about outreach and education the session was a little amorphous and creation of some organized informed knowledgeable body or group of people who could help each of these communities do these things would be terrific I understand and that's what I thought you were going to talk about I have a great deal of familiarity with the EU's I work with them a lot on the EU team and one of my peers when I mentioned yeah and they're very useful there they are shaping the way Vermont's energy and it's not just efficiency Vermont there are a couple other ones too they're reshaping the way Vermont and Vermont's consumers use energy as well as Vermont businesses that's a unique problem that's been out there for several years and I think in some ways and I mentioned the idea it's one of my colleagues upstairs who does more with the 8-9-1-1 board than I do and he's like well you don't need that you got to eat 9-9-1-1 board because that is kind of their charter it's a very similarly state chartered and funded organization that has a very discreet E-9-1 oversight mission I think I don't know maybe I'm misstating what this Neil passed on earlier but it sounds like what he's envisaging is what he's thinking about is what you're doing well not to the extent that you're starting to have a program in place like efficiency from Vermont well it would be a much more discreet look I think in some ways efficiency from Vermont touches people in different ways than you do and I'm not very familiar with efficiency from Vermont but we're looking to see what the model looks like but we don't currently we certainly think that it's a good idea to expand different kinds of telecommunication services in Vermont so that Vermonters have more options or an option wherever they are but we don't fund that we don't build those networks or support those networks we provide a system to which they direct their 911 calls so so I need to think on how the 9-1-1 more would fulfill I'm not sure we I'm not even sure we have the authority you think that the similarity between the 9-1-1 more than the EU would be why I think it might be the right fit with some growth corrected by the legislature to ensure it can meet all the missions that you're thinking about is that fundamentally what the EU's do is they reduce demand for energy pretty discreet that touches a lot of parts of many people's lives and it's both and like you said I've had an energy audit done I've received rebates for my solar hot more my hot water heater and it's reduced the amount that I reduce energy so it's affected me that way I think when Ms. Neal was talking about the role of the 9-1-1 board earlier I was particularly happy to hear her talk about data gathering because that's where it starts you have to understand your problem before you could address it and you have to understand it with discreet data related to real events and there's a lot of great speculation here there's a lot of great stories being told about what's happened in certain circumstances and anecdotal information but the kind of data that will show when there's a gap is what's needed to show how do you fix it and I think that they're already on the road to doing that whether it... and they do have the same kind of independence that the EUs had at least initially as contract entities and which the EUs now have as independent utilities so there are a lot of similarities so I'm not disregarding the idea I'm saying that it's a good idea but it may or may not be there one... well as a purpose of a workshop like this is people play all the other people's critiques comments I'm very aware that use of the term one utility wherever it first came from is a misnomer for what my thinking anyway was because that limits it to emergency 911 communications and the problem that's been addressed by the communities here and by individual consumers is not just and that's the speeder that's where it really pierces if someone can't reach an emergency responder when that person needs help but it's really almost going back to the department's initial petition the problem is that we have entered this new era of telecommunications that's been well spoken to and they were all well aware of and all benefited from it's a backup power it's the reliance of the new telecommunications systems own separate electricity it's the backup power problem that really needs addressing how can citizens be equipped and it kind of overlaps whether quickly into energy management how can citizens be equipped to self provision if that's the term energy supply to their telecommunications system whatever the circumstances of needing that system whether it is daily communication with a relative or a business purpose or or a dire emergency I guess I would like to end this monologue by saying that I don't want to miss the concept because of a misnomer in the terminology that was initially and vetted by me used it's more about helping promoters take care of their need for electric power backup power in order to communicate so I think there's very good ideas for me and I think it's a hassle so I think we're still safe with the terminology but it's a great hook whether it's going to be for other kinds of communications or not when the power companies are out to have a backup system and it makes some sense to tie it to be a manual it could even be argued it could be tied to efficiency or not because we're not talking about a lot of different kinds of products to distribute just some batteries maybe it doesn't make sense to have a whole organization unless it's involved in a lot of products I was one of a dozen founders and the co-op wasn't a food store it evolved and moved to well clearly understand the fancy fancy store but originally it was a buyers co-op and what we did was we bought saxophone but we also bought chainsaws we bought all kinds of stuff for the townspeople who joined us members of the co-op I'm not suggesting every town or every region should rely on a co-op but that sort of model is roughly what you're talking about and one thing that's attractive about using is it E.E.U. or what you call it? energy efficiency utility using that sort of structure is that it's funded with appropriations no none at all rate payer dollars rate payer dollars as well as the dollars that come from customers who take advantage of them when they do be doing shoots down my argument about helping people who can't afford to pay as much because I like the graduate tax system helping that out maybe it should be funded by appropriated dollars that way the people who are less able to afford can still get the two dollar light bulb that other people helped pay for or the two dollar battery or whatever so we could consider that as a justice issue that's actually a good segue into what I wanted to comment on and I think I feel compelled to talk about it since the department represents rate payers is cost there is concern over cost related to consumers needing to purchase battery backup there's also concern over something like for lack of a better word we're calling it the E-911 utility efficiency Vermont is funded by rate payers another utility would be funded by rate payers presumably or if we go down another road there was a mention of E-911 board having some sort of role they are funded through the USF fund which is funded by providers that charge consumers for that either way or anyway the consumer is going to pay for this somehow so I just wanted to bring that up as an issue and one that the department is concerned about which I think is why there's a fundamental concern I have is to meet the public safety concern there's zero there on that button that I talked about the last time as opposed to maybe some of the other things you were thinking about and I think that's why I was pleased to hear and was to talk about where they're going in the E-911 because that might shape what the red button looks like you've been talking for a long time why don't we take a time break and I'll come back with some ideas that will shape our next meeting and we can talk about this so I'll find out in the next week it's now a little after four I think we're probably done for today I didn't want to talk about the next session I have also talked a little bit about an interim document to be filed by the interested parties the dates I'm thinking about and if these are two near I'm thinking October 10th will be the next filing from the parties and I think it would address sort of comments on the proposals that were articulated in the documents that were filed on the 12th in particular on the R-Lex recommendation and any other best practices that have been proposed by the parties whether or not they are reasonable in how they might be achieved they'll come in on the 10th as well as any final recommendation that the interested party might have then we would follow that up with another workshop on the 17th and this is really just kind of a final opportunity to address what came in on the 10th and to help shape the final the what would be the recommendation from the commission the way that we go forward is that I would craft an initial document sometime between October 17th and Thanksgiving or let's say in Veterans Day and I would make that available for comment for a week or so and the final document would be rendered by the commission based on any changes that are made to that draft document based on your reports and that would come out in time I think it's December 15th I don't know exactly for the report to be such a yes sir October 17th is a problem for our government relations folks who have a state conference on the 16th and 17th and that would kind of carry over to the 18th if it could be earlier than next week okay that sounds good 21st for some of us to move it would not work are the government relations people here are the government relations people yeah I know myself I will not be available on the 17th I know I'm out of town I'm out of town and my colleagues oh okay I didn't know how about the 15th we can push the due date for the document ahead to the 8th I'm sorry the department can't do the 15th okay okay how about the 21st yeah that's a one day release Monday okay so we'll continue with the documents due I'm holding the document on Friday the 11th because then we'll look at it until our next session together on the 21st yes ma'am at the beginning we talked about the introducing of a report that addresses the requirements that the legislature gave you or how the 901 board might support yes you would like by the time yes please and then we can all comment I'm going to inform any further discussion we might have in the next of the year thank you all for your patience and your comments