AT&T Services, Inc. 310 Orange Street New Haven, Connecticut 06510 Phone (203) 771-8764 Fax (203) 771-6577
Deborah A. Verbil1
General Attorney
April 3, 2009
Kimberley J. Santopietro, Executive Secretary Department of Public Utility Control Ten Franklin Square New Britain, Connecticut 06051 Re: Potential Work Stoppage
Dear Ms. Santopietro: The Southern New England Telephone Company d/b/a AT&T Connecticut, AT&T Corp. and TCG Connecticut (collectively, “AT&T”) herein notify the Department of Public Utility Control (“Department”) that AT&T’s bargaining unit employees are authorized to call a work stoppage at any time after April 4, 2009, if ongoing negotiations do not result in an agreement. This notice does not mean that there will be a work stoppage, only that that the union has reserved that right. In the event that the bargaining unit does call a work stoppage, AT&T will notify the Department promptly. However, in preparation for a potential work stoppage, AT&T respectfully requests that, in accordance with the Regulations of Connecticut State Agencies §16-1-62 and the Department’s general authority, the Department grant extensions conditioned on the actual occurrence of a work stoppage, for each of the scheduled or to be scheduled activities associated with the proceedings and reporting requirements described below.3 AT&T requests that such extensions remain in place for the duration of any work stoppage and for thirty days thereafter. These extensions are necessary because management employees who would normally be involved in the management and development of these dockets and reports will be required in field
1
Only licensed to practice law in Texas and New Mexico.
2
“Extensions of Time. In the discretion of the commissioners or the presiding officer, for good cause shown, any time limit prescribed or allowed by these rules may be extended. All requests for extensions shall be made before the expiration of the period originally prescribed or as previously extended. The executive secretary of the commission shall notify all parties of the commission’s action upon such motion.”
3
AT&T has attempted to compile a comprehensive list of open activities that may be, but are not necessarily, scheduled at the current time. In addition, AT&T requests that the Department afford any open dockets that have remained dormant similar extensions. During the pendency of any work stoppage, AT&T
Kimberley J. Santopietro Page 2 April 3, 2009
positions to attend to the core needs of running the business. In the event that a work stoppage triggers these requested extensions, AT&T will make every effort to meet its docket and reporting obligations in a timely manner. However, AT&T wants to ensure that it is allowed sufficient time to focus on continuity of customer service operations subsequent to any work stoppage. Listed below are the proceedings and reporting requirements with activities currently scheduled between April 4, 2009 and September 30, 2009 (in docket number order): Docket No. 95-03-01 Application of The Southern New England Telephone Company for Financial Review and Proposed Framework for Alternative Regulation May 1st – Order No. 11 (Price Cap) Docket No. 98-02-20 Joint Application of SBC Communications, Inc. and Southern New England Telecommunications Corporation for a Change of Control 2nd week in May, 2nd week in July – Order No. 6 (10Q Report) August 15th – Order No. 3 (Short Term Borrowing and Lending Quarterly Report) Docket No. 99-07-28 DPUC Promulgation of Quality of Service Regulations for Connecticut Telephone and Certified Telecommunications Providers April 30th, May 30th, June 30th, July 30th, August 30th, September 30th – Monthly Exception Report that may be due in accordance with Regulations of Connecticut State Agencies §16-247g-2(c) July 30th – Semi-Annual Report due in accordance with Regulations of Connecticut State Agencies §16-247g-2(b)
will continue to meet any statutory or interconnection negotiation requirements and will file Custom Service Arrangements as required to meet customer needs.
Kimberley J. Santopietro Page 3 April 3, 2009
Docket No. 00-07-17 DPUC Investigation of The Southern New England Telephone Company’s Alternative Regulation Plan May 1st – Annual Report No. 10
Docket No. 07-02-13 DPUC Review of the State’s Public Service Company Utility Pole Make Ready Procedures April 9th – Subgroup Meeting April 24th – Working Group Meeting April 30th – Order No. 2 (Progress report) Note: AT&T believes that it will be able to participate in the meetings and the drafting and filing of this joint report. However, it reserves the right to reschedule these meetings and request and extension for the filing of the joint report if AT&T management participating in the Working Group are unable to continue such participation due to the work stoppage.
Docket No. 07-03-11 DPUC Review of BWG Audit of The Southern New England Telephone Company’s Affiliate Transactions April 30th – Order No. 2 (Amend AR-10 to reflect dividend calculation and payout information) Order No. 3 (Quarterly Report when payout of its dividends exceed 80% of net income)
Docket No. 07-03-34 April 30th – Order No. 3 (Quarterly Reports detailing adjoining proprietor’s consent) July 30th – Order No. 1 (Quarterly Progress Report) Order No. 3 (Quarterly Report detailing adjoining proprietor’s consent)
Docket No. 07-05-23 DPUC Review of AT&T Connecticut’s Community Access Funding Obligations April 15th, July 15th – Report of payments to PEG providers
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Docket No. 07-10-04 Application of The Southern New England Telephone Company for a Certificate of Video Franchise Authority April 15th, July 15th – Connecticut cities/towns where customers subscribed to U-verse
Docket No. 08-01-06 Annual Assessment Proceeding to Fund the Development and Administration of the Enhanced Emergency 911 Program April 30th, July 30th – Order No. 2 (Monthly payments/Quarterly Report)
Docket No. 08-01-16 Petition of Richard Blumenthal, Attorney General for the State of Connecticut, for Standardized Disclosure of Utility Executive and Officer Compensation July 1st – Order No. 3 (Annual Compensation of Officers and Directors for the prior year)
Docket No. 08-06-19 DPUC Investigation Into the Deployment of Distributed Antenna Systems (DAS) in the Public Rights of Way in Connecticut April 23rd – Interrogatory responses due April 30th – Hearing May 7th – Late-filed exhibits due May 14th – Late-filed exhibit hearing May 21st – Briefs May 28th – Reply Briefs
Docket No. 08-07-15 Petition of the Office of Consumer Counsel for Enforcement of Quality of Service Standards for The Southern New England Telephone Company d/b/a AT&T Connecticut (Phase I) April 13th – Reply Brief May 4th – Written Exceptions May 12th – Oral Argument Note: AT&T will file its Reply Brief on April 13th as scheduled.
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Docket No. 08-07-15 Petition of the Office of Consumer Counsel for Enforcement of Quality of Service Standards for The Southern New England Telephone Company d/b/a AT&T Connecticut (Phase II) May 27th – Interrogatories to be issued June 3rd – Responses to interrogatories due June 12th – Pre-filed testimony due
Docket No. 08-12-03 DPUC Investigation Into the Request by Alan M. Dressler to Remove a Video Ready Access Device (VRAD) Cabinet Installed at 3 Bailey road, Trumbull, Connecticut April 22nd – Hearing April 29th – Late-filed Exhibits May 12th – Late-filed Exhibit Hearing May 19th – Briefs May 28th – Reply Briefs
Docket No. 09-01-04 DPUC 2009 Annual Report to the General Assembly on the Status of Telecommunications in Connecticut Request has not been issued to date April- May (anticipated time frame) – Initial response to TE-1 June – July (anticipated time frame for subsequent responses due) Supplemental responses to TE-1 (if any) September (anticipated date) - Responses to Annual interrogatories due
Docket No. 09-01-12 DPUC Annual Community Access Support Review April 8th – Reply Comments
The following are other open dockets for which no activities are currently scheduled. AT&T respectfully requests that no due dates be established until after any work stoppage has concluded:
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Docket No. 08-12-04 Petition of Youghiogheny Communications-Northeast, LLC d/b/a Pocket Communications for a Declaratory Ruling that The Southern New England Telephone Company d/b/a AT&T Connecticut is in Violation of Section 16247b of the Connecticut General Statutes and the Department’s Orders in Docket No. 02-01-23 Relating to Transit Traffic and Federal and State Laws and Regulations Relating to the Transit Traffic Factor Docket No. 09-03-11 Application of The Southern New England Telephone Company d/b/a AT&T Connecticut to Sell Unimproved Real Property Located at 125 Brewer Street in East Hartford, Connecticut
In addition, AT&T designates the following agents to act on its behalf in the event of a work stoppage: Timothy P. Jensen Hinckley, Allen & Snyder LLP 185 Asylum Street CityPlace I, 35th Floor Hartford, CT 06103 Office Phone: 860-725-6200 Office Fax: 860-278-3802 Cell Phone: 203-376-8378 tjensen@haslaw.com www.haslaw.com Theresa A. Brown Director Regulatory – Connecticut AT&T Connecticut 310 Orange Street, 8th Floor New Haven, CT 06510 Office Phone: 203-771-4218 Office Fax: 203-946-2141 Cell Phone: 203-556-3521 tb3761@att.com Service has been made pursuant to §16-1-15 of the Regulations of Connecticut State Agencies. This filing is being submitted as an electronic web filing and is complete.
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Should there be any questions concerning this submission, please do not hesitate to contact me. Very truly yours,