LOCAL TELECOMMUNICATIONS COMPETITION SURVEY 2015 ANNUAL REPORT Staff Report Public Utility Commission of Oregon December 2015 Competition Survey Year 2015 Final Report TABLE OF CONTENTS EXECUTIVE SUMMARY ................................................................................................ 1 I. II. SURVEY OVERVIEW .............................................................................................. 2 a) Purpose of the Survey .................................................................................. 2 b) Survey Participants & Responses ............................................................... 3 SERVICE TYPES ..................................................................................................... 4 a) ILEC Service Types ....................................................................................... 4 b) CLEC Service Types ..................................................................................... 5 III. SWITCHED SERVICES – MARKET SIZE AND SHARE ANALYSIS ...................... 6 a) Total Market Size and Shares....................................................................... 6 b) Business Market Share ................................................................................. 9 c) Residential Market Share............................................................................ 11 d) Ten Year Market Trends in Switched Access Services ........................... 12 e) CLEC Provisioning of Switched Service ................................................... 18 Facility-Based CLECs .......................................................................... 18 Competition based on Unbundled Network Elements (UNEs) ......... 20 IV. HIGH SPEED ACCESS SERVICES ...................................................................... 21 a) Private Line Service .................................................................................... 21 b) DSL Service ................................................................................................. 23 c) VoIP Service ................................................................................................ 24 d) CLEC Provisioning of Private Line Circuits .............................................. 25 Competition Survey Year 2015 Final Report V. MARKET SEGMENTS BY REGION AND TYPE OF SERVICE ............................ 26 a) Market Segments by Region ...................................................................... 27 Switched Services by Region ............................................................. 27 Private Line Service by Region ........................................................... 28 DSL Service by Region ........................................................................ 32 VI. BUSINESS PLANS AND COMPETITION ............................................................. 33 a) Capital Expenditures .................................................................................. 33 b) Competition for Residential Market ........................................................... 34 c) Landline telephone industry is shrinking ................................................. 35 CONCLUSIONS ............................................................................................................ 35 Competition Survey Year 2015 Final Report Executive Summary In January 2015, the Public Utility Commission of Oregon (OPUC) Staff sent out its annual survey to 238 certificated local exchange carriers (LECs) in Oregon and received responses from 100 percent of them. The purpose of this annual survey is to gather the data needed to complete the report required by ORS 759.050(9). This statute directs the OPUC to report annually on the status of telecommunications competition in Oregon to the Legislative Assembly. All carriers certificated by the OPUC, both incumbent local exchange carriers and competitive local exchange carriers, were asked to fill out the survey forms sent to them. These forms asked questions on the types of services that the company provided in 2014 as well as how many customers they were serving in total and at the regional level. The survey also asked the carriers for total 2014 Oregon gross revenues. The companies were instructed to provide all intrastate and interstate revenues for local exchange, switched access, long distance, private line, and DSL services. This report focuses on local exchange revenues. Although local exchange revenues currently account for only 30 percent of an ILEC’s total revenues, they are a good indicator of the state of competition. Table 1 provides some highlights from the survey. Table 1 shows that CLECs have made significant inroads into the ILEC customer base. Residential lines are now almost split equally between ILECs and CLECs. Given the current trend indicated by the percentage change from last year, the CLECs will likely have the larger market share within a year or two. The ILECs have also lost a significant number of their business customers, but they have fared better with the business segment than they have with the residential segment. Based on the current trend they should slightly increase their market share. While the CLECs have captured a significant portion of the ILEC market share in the past ten years, the number of CLEC companies has been relatively stable over this same period. In 2005, 134 of the 235 certificated companies were generating revenues. Ten years later in 2014, 153 of the 206 certificated companies were generating revenues. Over this ten-year period, the number of companies generating revenues in a given year has ranged from a high of 155 to a low of 130. Of the153 companies generating revenues in 2014, only 66 of them were generating local exchange service revenues, which we are tracking with this report. The most significant change documented in Table 1 is the 22 percent increase in VoIP phone numbers. This is significant because customers that are moving from an ILEC to an uncertificated VoIP company often take their phone number with them; thus, they do not require a new phone number. One possible explanation of this rapid growth is that phone numbers are now being used for different things. A number of companies now provide a service that allows the user to have simultaneous several different phone numbers that can reach their phone. When they select one of these numbers, their call appears to be coming Page 1 Competition Survey Year 2015 Final Report from that number. The user rents these numbers for just the length of time that they need them. Table 1 HIGHLIGHTS FROM 2014 DATA 2014 Highlights Oregon Local Exchange Service Revenues ILEC1 Revenue CLEC2 Revenue $ Millions 612.5 422.2 190.3 000's Total Switched Lines at year end (1) ILEC Lines CLEC Lines Total Residential Switched Lines at year end ILEC Residential Lines CLEC Residential Lines Total Business Lines at year end ILEC Business Lines CLEC Business Lines Total Wholesale Switched Lines at year end ILEC Wholesale Lines CLEC Wholesale Lines (2) UNE Lines (counted under ILEC wholesale lines) Total number of Private Line Circuits Lower Capacity Circuits Higher Capacity Circuits Total Number of Digital Subscriber Lines CLEC VoIP3 Phone Numbers 1,435.8 780.8 655.0 814.2 419.6 394.6 484.8 265.0 219.8 136.8 96.2 40.6 88.2 14.9 8.1 6.8 365.5 485.7 % Share ILEC/CLEC 68.9% 31.1% % Share % Change from 2013 ILEC/CLEC -0.1% 2.3% % Change from 2013 54.4% 45.6% -6.8% 9.4% 51.5% 48.5% -10.4% 4.3% 54.7% 45.3% 1.5% 0.8% 70.3% 29.7% -11.4% -0.5% 21.8% -5.4% 24.0% 0.1% 22.5% % of CLECs CLECS with certificates 206 CLECS doing business 153 74.3% I. Survey Overview a) Purpose of the Survey The purpose of the survey is to collect information from ILECs and CLECs to determine the status of competition for certain local exchange services in Oregon. The survey 1 2 Incumbent Local Exchange Carrier (ILEC). Competitive Local Exchange Carrier (CLEC). Page 2 Competition Survey Year 2015 Final Report collects data on five major types of services: (1) local exchange switched access; (2) intrastate private line; (3) DSL; (4) Unbundled Network Elements (UNEs); and (5) resale service. This study was a key component of the 1999 Oregon legislation requiring the OPUC to report on telecommunications issues. b) Survey Participants & Responses In January 2015, OPUC staff sent a survey to all 238 carriers holding a certificate to provide local services in Oregon issued by the OPUC. Of the 238 LECs, 32 are ILECs, and 206 are CLECs. The ILECs are the traditional local telephone service providers in the state. ILECs are statutorily designated as “carriers of last resort,” meaning they have the obligation to serve customers within OPUC approved service areas under OPUC approved terms and conditions. CLECs compete with ILECs within the approved terms and conditions of OPUC certificates. The survey asked each LEC to provide information related to their operations in 2014. The response rate for the 32 ILECs and the 206 CLECs was 100 percent (see Table 2, below). In 2014, 77.7 percent of all certificated carriers were generating revenues from the services that they were providing. This is an increase from 2013, when 62.5 percent reported that they were generating revenues from their services. Although the number of certificated CLECs is slightly less for 2014 than 2013 (206 versus 227), the percentage generating revenues from their services increased in 2014. Table 2, below, summarizes the survey response and service operation rates. The upper table shows the number of respondents and their response rate, while the lower table shows the number of respondents who actually provide some type of local exchange service in Oregon. The percentage of CLECs that reported providing service in 2014 was noticeably more than in 2013, but this is attributable to 30 of the CLECs providing service in 2014 not reporting that they provided service in 2013. Table 2. Survey Response Rates and Service Operation Rates 2014 Surveys Sent Responses Response Rate % Total LECs 238 238 100.0% ILECs 32 32 100.0% CLECs 206 206 100.0% Surveys Sent Service Provided Operation Rate % Total LECs 238 185 77.7% ILECs 32 32 100.0% CLECs 206 153 74.3% Page 3 Competition Survey Year 2015 Final Report II. Service Types a) ILEC Service Types Table 3 shows the various services offered by ILECs and the number and percentage of ILEC companies offering those services. What we have noticed is ILEC participation has not changed noticeably year-over-year. ILECs are not indicating they are using VoIP technology such as Softswitches to provide these services; however, Staff understands through other reports that ILECs are installing Softswitches4. As the use of VoIP technology by ILECs increases, ILEC lines served by VoIP will likely appear in the near future. The provision of “Other” services such as Internet Service increased from two in 2013 to six in 2014.5 Five of the six companies indicated their participation in Internet Services. The sixth “Other” respondent indicated a participation in Wireless resale. Table 3. ILEC Market Coverage by Service Category ILEC Service Types # of ILECs % of ILECs Providing Service Providing Service Local Exchange Switched Service 32 100.0% Local Exchange Private Line Service 29 90.6% Lower Capacity 28 87.5% Higher Capacity 25 78.1% Long Distance Service 14 43.8% DSL (Digital Subscriber Line) 32 100.0% Access service 30 93.8% Directory Assistance 15 46.9% Operator 11 34.4% Telecom using Cable TV Facilities 0 0.0% Telecom using VoIP 0 0.0% Other 6 18.8% 4 Softswitch is an abbreviation for software switch, the most modern version of central offices. Softswitches were originally designed for packet-switched (a.k.a., internet protocol (IP)) traffic but have evolved for use by both IP and circuit-switched traffic. 5 Other services include miscellaneous internet services and reselling video and wireless services. Page 4 Competition Survey Year 2015 Final Report As Figure 1, below, illustrates, in 2014 all 32 ILECs provided switched access and DSL service; 90.6 percent provided private line service; 43.8 percent provided long distance service; 93.8 percent provided access service to long distance or interexchange carriers; 46.9% provided directory assistance service; and 34.4 percent provided operator service. The 2014 participation of ILECs in all service types is not materially different than their participation in 2013. Figure 1. ILEC Service Types and Distributions Percentage of ILECs Providing Service Types - 2014 100.0% 80.0% 60.0% 40.0% 20.0% 0.0% % Types Switched Private line 100.0% 90.6% Long distance 43.8% xDSL 100.0% Access Service 93.8% Directory Assistance 46.9% Operator 34.4% b) CLEC Service Types Figure 2 and Table 4 display the number and percentages of CLECs providing various telecommunications services in 2014. As of December 2014, 153 (74.3 percent) of the 206 certificated CLECs were providing one or more of the identified telecommunications services in Oregon. Of the 153 CLECs providing service, 66 provided local exchange switched service compared to 57 CLECs providing switched service in 2013. In 2014, 82 CLECs provided long distance service and 49 provided intrastate private line services. Page 5 Competition Survey Year 2015 Final Report Figure 2. CLECs Providing Service by Type and Distributions Percentage of CLECs Providing Service byType - 2014 60% 40% 20% 0% % Types Switched Private line Long distance xDSL Access Service 43.1% 32.0% 53.6% 24.8% 28.1% Directory Assistan ce 16.3% Operator 13.1% Table 4. CLEC Market Coverage by Service Category CLEC Service Types Operating CLECs Local Exchange Switched Service Local Exchange Private Line Service: Lower Capacity Higher Capacity Long Distance Service DSL (Digital Subscriber Line) Access service Directory Assistance Operator Telecom using Cable TV Facilities Telecom using VoIP Others III. # of CLECs Providing Service 153 66 49 16 45 82 38 43 25 20 8 50 38 % of CLECs Providing Service 43.1% 32.0% 10.5% 29.4% 53.6% 24.8% 28.1% 16.3% 13.1% 5.2% 32.7% 24.8% Switched Services – Market Size and Share Analysis a) Total Market Size and Shares As shown in Table 5, below, the 153 CLECs competing in Oregon’s local telecommunication services market in 2014 had switched service market shares ranging from 33.5 percent to 46.3 percent depending on the metric used. The three metrics for measuring market share are switched access lines, revenues, and customers. Each of these metrics provides a different look at market share. In 2014, using switched access lines as the standard, the ILECs had a 54.4 percent market share and the CLECs had 45.6 percent share. When this standard changed to revenues, the ILECs share jumped to 66.5 percent leaving the CLECs with only a 33.5 Page 6 Competition Survey Year 2015 Final Report percent share. The CLECs fared best when their market share was measured using counts of retail business and residential customers6 as the standard. Using this metric, the ILECs got 53.7 percent of the customers compared to the 46.3 percent going to the CLECs. Figure 3 shows the ILEC-CLEC market share using customers as the standard. This chart shows that the customer base is very close to being equally divided between ILECs and CLECs. What it does not show is that ILECs, on a revenue basis, are still significantly ahead of the CLECs. Figure 3. Market Share for Switched Service by Number of Customers Switched Service Market Share by CUSTOMER - 2014 CLEC, 46.3% ILEC, 53.7% Oregon ILECs and CLECs together serve 916,000 local exchange switched customers and 1.4 million local switched telephone lines,7 which is nearly identical number of lines reported in 2013. The drop in lines between 2013 and 2014 was relatively small and not a good indicator of what has taken place. In 1999, the ILECs alone had 2.1 million lines; they are now down to 780,000 lines. Comparing the 2.1 million lines in 1999 to the present line count for ILECs and CLECs shows that 700,000 lines have been lost between then and now. Much of this loss can be attributed to cell phones. 6 The survey instructions define a customer as a person or entity that had applied for, been accepted, and was receiving service for a price during the period covered by this report. A customer that has multiple lines counts as one customer. 7 Local exchange line – the traditional definition is a voice-level transmission path (64 kbps digital, or less than 4 kHz analog) linking an end user location with the switching center providing dial tone. For purposes of this report, we include fixed interconnected VoIP lines provided by cable companies in this category. Page 7 Competition Survey Year 2015 Final Report Table 5. 2014 Oregon Switched Service Market Shares 2014 Customers Lines Revenue-($M) ILECS CLECS Total 492,046 423,997 916,043 780,842 654,993 1,435,835 276.1 139.3 415.5 % Customers Lines Revenue ILECS CLECS Total 53.7% 46.3% 100.0% 54.4% 45.6% 100.0% 66.5% 33.5% 100.0% Table 5 also shows that total retail revenues from the local switched access services, which are included in this survey, were an estimated $415.5 million in 2014 (down $15 million from the total for 2013). ILECs received $276.1 million8 (down $17 million from 2013), and CLECs received the remaining $139.3 million (down only $2 million from 2013). Table 6, below, illustrates that ILEC average annual switched service revenue per line was $354 in 2014 versus $309 in 2013. CLEC average annual switched service revenue per line was $213 in 2014 versus $236 in 2013. This difference in revenues per line is the reason the ILECs revenue share is significantly higher than its customer share. The driver of this difference does not appear to be the average number of lines per customer. This is almost identical for the two classes of companies. Table 6. Selected 2014 Switched Service Averages 2014 CLECs ILECs 1.5 1.6 Annual Revenue Per Line $213 $354 Annual Revenue Per Customer $329 $561 Lines Per Customer 8 Both ILEC and CLEC revenues discussed in this section refer to that subset of revenues from local exchange switched service only (including cable fixed interconnected VoIP service). Page 8 Competition Survey Year 2015 Final Report Table 7, below, compares the “big four” ILECs - CenturyTel, Qwest, United, and Frontier - with total ILECs and CLECs. In 2014, the “Big Four” had a 50 percent share of all ILEC and CLEC switched lines, and 61 percent of all reported switched service revenues. Table 7. 2014 Market Share of ILECs, CLECs, and the Big 4 ILECs Market Shares ILECs/Total CLECs/Total Big-4 ILECs/Total Residential Lines 51.5% 48.5% 45.7% Business Lines 54.7% 45.3% 51.6% Wholesale Lines 70.3% 29.7% 70.3% Total Lines 54.4% 45.6% 50.0% ILECs/Total CLECs/Total Residential Revenues 60.5% 39.5% 51.8% Business Revenues 68.4% 31.6% 65.5% Wholesale Revenues 93.1% 6.9% 93.1% Total Revenues 66.5% 33.5% 61.0% REVENUES b) Business Market Share Share of business lines: As shown in Figure 4, below, CLECs served 45.3 percent of business switched access lines in 2014, approximately the same figure for 2013. The ILEC and CLEC business switched access services market, based on the last two years may be reaching a stable level. Share of Business Revenues: As shown in Table 7, above, CLECs had a 31.6 percent share of business switched service revenues in 2014, compared to 33.5 percent (see Table 7) of total switched service revenues. A significant reason for this gap is the large difference in revenues per line. Revenue per line: CLECs reported revenue per business line of $260.33 in 2014. ILECs reported $468.13 per business line in 2014. Since Figure 4, below, indicates the business-line market share of the ILECs is less than 10 percent higher that CLECs, the substantially higher revenue per business line of the ILECs suggests they are serving a greater proportion of high revenue per line accounts than the CLECs. Page 9 Competition Survey Year 2015 Final Report Figure 4. Market Share as Measured by Business Switched Lines Market Share of Business Lines - 2014 CLECs, 45.3% ILECs, 54.7% Figure 5, below, illustrates the market share trend of the CLEC business switched access lines in the past ten years. The annual percentage share peaked at 48.8 percent in 2010. Beginning in 2011, the trend has dropped modestly every year with 2014 reaching 42.8 percent. Figure 5. CLEC Business Switched Access Line Market Share Growth CLEC Market Share - Business Switched Access Lines 2005- 2014 50.0% 40.0% 30.0% 20.0% 10.0% 0.0% Business Lines 2005 37.0% 2006 39.4% 2007 39.6% 2008 42.4% 2009 48.2% 2010 48.8% 2011 47.3% 2012 47.6% 2013 43.1% 2014 42.8% Page 10 Competition Survey Year 2015 Final Report c) Residential Market Share In 2014, CLECs served 49.8 percent of the residential customer market (see Table 8, below). According to the survey, Oregon carriers provided local exchange switched services to 769,517 Oregon residential customers. ILECs served 386,210 customers, or 50.2 percent of the total, while CLECs served 383,307 residential customers, or 49.8 percent of the total. CLEC residential market share remained relatively flat, near 5 percent, until 2007. Then cable companies began entering the market with more authority offering fixed interconnected VoIP telephone service as an alternative to the traditional landlines provided by ILECs. ILECs served 51.5 percent of residential local exchange lines in 2014, slightly down from 55.3 percent in 2013. The “big four” ILECs - CenturyTel, Qwest, United, and Frontier - provided 45.7 percent of total ILEC and CLEC residential lines in 2014 (see Table 7). Residential phone service is believed to be less profitable than business service due to the higher costs and lower revenues per line characteristics of the residential local exchange market. The lower concentration of residential customers directly drives the costs to serve the residential market. Additionally, residential local exchange rates are substantially lower than business rates. CLECs provided 48.5 percent of total residential lines, while ILECs provided 51.5 percent. Revenues from the residential market in 2014 were an estimated $202.2 million. Revenues were $208.2 million in 2013. Table 8. 2014 Residential Switched Services Market Share Residential Residential Residential Residential Market Shares Customers Lines Revenues ($M) ILECs 386,210 419,599 122.3 CLECs 383,307 394,620 79.9 Total 769,517 814,219 202.2 ILECs/Total 50.2% 51.5% 60.5% CLECs/Total 49.8% 48.5% 39.5% Page 11 Competition Survey Year 2015 Final Report d) Ten Year Market Trends in Switched Access Services Table 9, below, illustrates the ILEC and CLEC switched-access-lines market trends. The CLEC market access line share has steadily increased in the last ten years, reaching 45.6 percent in 2014, perhaps giving too strong an impression that the market size is increasing. However, both ILEC and CLEC total line counts have dropped due to service alternatives and customer demographics. ILECs lines have been steadily declining since the advent of the 1996 Communications Act due in part to the elimination of UNE-P services and increasing competition from wireless and VoIP alternatives. After nearly 20 years of competition, residential lines for ILECs may have reached a relatively steady state that is perhaps determined more by customer demographics (age, loyalty, income, household movement, technology awareness, etc.) than direct industry competition. The CLEC and ILEC shares of switched access lines in 2014 are 45.6 percent and 54.4 percent, respectively. Table 9. Trends in Switched Access Lines, 2005 to 2014 Date ILEC Lines CLEC Lines Total CLEC Share 2005 1,803,832 346,923 2,150,755 16.1% 2006 1,652,900 330,407 1,983,307 16.7% 2007 1,605,911 403,121 2,009,032 20.1% 2008 1,436,946 526,692 1,963,638 26.8% 2009 1,265,459 641,064 1,906,523 33.6% 2010 1,123,531 650,237 1,773,768 36.7% 2011 1,003,865 641,032 1,644,897 39.0% 2012 902,114 639,438 1,541,552 41.5% 2013 838,130 598,576 1,436,706 41.7% 2014 780,842 654,993 1,435,835 45.6% Page 12 Competition Survey Year 2015 Final Report Figure 6, below, illustrates the declining trend for the ILEC switched access services from 2005 to 2014. The ILEC and CLEC shares may be relatively stable but the market size is in major decline. From 2005 to 2014, the total access lines served by ILECs and CLECs declined by 33 percent, from 2,150,755 in 2005 to 1,435,835 in 2014. ILEC and CLEC local exchange market is becoming a smaller share of expanding telecommunications market. The market expansion is being driven by wireless and VoIP alternatives. Figure 6. ILEC Switched Access Services Market Share, 2005 to 2014 ILEC Market Share Percentage in Switched Access Services, 2005 - 2014 100% 95% 90% 85% 80% 75% 70% 66.47% 65% Revenues 60% 54.38% 55% 50% 2005 Lines 53.71% 2006 2007 2008 2009 2010 2011 2012 2013 Customers 2014 Figure 7. below, illustrates the CLEC switched access line trend from 2005 to 2014. As indicated in prior year reports, CLEC switched lines grew an average of 22.6 percent per year from 1998 (85,146 lines) to 2004 (271,344 lines). Total CLEC lines increased by 218 percent over that timeframe. During the same period, ILEC switched access lines declined by an average of 1.2 percent per year, from 2.12 million lines in 1998 to 1.96 million lines in 2004. Since 2005, total ILEC lines have declined by 57 percent. The total number of switched access lines, both ILEC and CLEC, has declined by 43 percent since 2005. As discussed at many points in this report, the ILEC and CLEC universe has been heavily impacted by wireless and VoIP technology alternatives. The latter equates to a full displacement of ILEC or CLEC landline service when customer transition occurs. The customer transition to wireless, however, is more complex and can take much longer since wireless it is not a direct substitute and is priced higher because of the Page 13 Competition Survey Year 2015 Final Report mobility functionality.9 Before completely displacing a landline phone, customers often add wireless phones, then over time shift their usage minutes to wireless and eventually displace their landline service as their understanding of wireless quality, prices and service reaches an acceptable level. The introduction of wireless to much younger and technology sophisticated customers will change this pattern. No replacement will ever take place as such customers will begin with wireless and will never have subscribed to ILEC or CLEC landline telephone services. Figure 7. CLEC Switched Access Lines CLEC Switched Access Line Trend 2005-2014 700,000 600,000 500,000 400,000 300,000 200,000 100,000 0 CLEC Lines 2005 346,923 2006 330,407 2007 403,121 2008 526,692 2009 641,064 2010 650,237 2011 641,032 2012 639,438 2013 598,576 2014 654,993 Figure 8, below, illustrates the CLEC total switched access services market share trend. From 2005 to 2014, CLEC total market share of revenues derived from switched service was an average of 25.8 percent, starting at 17.5 percent in 2005 and ending with 33.5 percent in 2014. In the same period, the CLEC market share of switched access lines averaged 31.8 percent; it started at 16.7 percent and ended at 45.6 percent in 2014. The CLEC total switched-service, customer share was an average of 26 percent in the same period, starting at 6.3 percent in 2005 and ending with 46.3 percent in 2014. 9 The quality of wireless service is often influenced by the geography and customer concentration. Wireless prices often appear much higher than landline since wireless voice is more tightly bundled with wireless broadband services. Wireless dialing, network access and phones are similar but different in key aspects from switched access line equivalents. Page 14 Competition Survey Year 2015 Final Report Figure 8. CLEC Switched Access Services Market Share 2005 to 2014 CLEC Market Share Percentage in Switched Access Services, 2005 - 2014 46.3% 50% Customers 45% 45.6% 40% Lines 35% 33.5% 30% Revenue 25% 20% 15% 10% 5% 0% 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 Figure 9, below, illustrates the CLEC residential switched access services market share trend. From 2005 to 2014, CLEC residential switched service revenue market share of was an average of 21.2 percent, starting at 10.1 percent in 2005 and ending with 39.5 percent in 2014. In the same period, the CLEC residential switched-access-line market share was an average of 25.1 percent, starting at 7.4 percent and ending at 48.5 percent in 2014. The CLEC residential switched-service customer share was an average of 26.5 percent in the same period, starting at 5.1 percent in 2005 and ending with 49.8 percent in 2014. Page 15 Competition Survey Year 2015 Final Report Figure 9. CLEC Residential Market Shares for Switched Access Services: 2005 to 2014 60% 55% 50% 45% 40% 35% 30% 25% 20% 15% 10% 5% 0% 2005 CLEC Residential Market Share in Switched Service, 2005-2014 48.5% Lines 49.8% Customers 39.5% Revenue 2006 2007 2008 2009 2010 2011 2012 2013 2014 Figure 10, below, illustrates the CLEC business switched-access services market share trend. From 2005 to 2014, CLEC business switched-service revenue market share was an average of 33.1 percent, starting at 29 percent in 2005 and ending with 31.6 percent in 2014. In the same period, the CLEC business switched-access-line market share was an average of 44.6 percent, starting at 37 percent and ending at 45.3 percent in 2014. The CLEC business switched service customer share was an average of 25.3 percent in the same period, starting at 19.8 percent in 2005 and ending with 22.3 percent in 2014. Figure 10. CLEC Business Market Shares for Switched Access Service: 2005 to 2014 CLEC BUSINESS Sector Market Share for Switched Service, 2005-2014 60% 50% 45.33% Lines 40% 31.56% 30% Revenues 20% 10% 0% 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 Page 16 Competition Survey Year 2015 Final Report Figure 11, below, was included in the 2014 report to illustrate how the CLEC switchedaccess-line share in Oregon compares with the CLEC share nationally. The comparison was based on the Federal Communications Commission’s (FCC) Local Telephone Competition, October 2014 Release, as of December 31, 2013. Additional analysis of the data submitted by the carriers to the issuance of the “October 2015 Release, as of December 31, 2014 2016. The information in Figure 11 is a comparison of the 2014 CLEC Market Share data with Staff’s estimate of the 2014 national last available four years in the FCC’s October 2014 Release. FCC has delayed report” until March Oregon ILEC and data based on the Page 17 Competition Survey Year 2015 Final Report Figure 11. Market Share Comparison of Switched Access Lines – U.S. vs. Oregon 2014 Market Share Comparison of Switched Access Lines - US vs Oregon 100% 80% 60% 40% 20% 0% US % Oregon % ILEC 55% 54% CLEC 45% 46% e) CLEC Provisioning of Switched Service In 2014, 32 of the 66 CLECs (48%) that reported providing local switched service participated in reselling ILEC services. Reselling requires that a CLEC buy retail service from the ILECs at discounted rates, and resell the service, usually with terms and conditions that equal, or are better than, ILEC tariff standards. CLECs will commonly utilize CLEC branding to reach and serve end-users customers. Facility-Based CLECs In 2014, 31 of the 66 CLECs (47%) providing local switched service were either fully or partially facility-based providers.10 These CLECs served some of their customers with their own facilities. The remaining 53 percent provided service solely by reselling the service of the ILECs. These fully or partially facility-based CLECs provided 654,918 switched access lines in 2014, essentially 100 percent of total CLEC lines. Cable telephony providers provided the majority of these lines. This data supports the generally understood service approach of CLECs – the resale of ILEC services is combined with CLEC facilities-based services, as needed, to serve customers. Few, if any, CLECs focus entirely on resale or facilities-based competition. 10 Facility-based providers own their switches and networks rather than lease assets from other providers. Page 18 Competition Survey Year 2015 Final Report As illustrated in Figure 12, below, 51 percent of facilities-based CLEC local telephone service was reported to be in the Portland region and 26 percent in the Willamette Valley region. Figure 12. Regional Distribution – Facility-based CLEC access lines Switched Access Lines from Facility- Central, 4% East, 2% Coast, 5% SW , 12% Portland, 51% Willamette, 26% Page 19 Competition Survey Year 2015 Final Report Competition based on Unbundled Network Elements (UNEs)11 Twenty-five CLECs reported purchasing ILEC UNEs for use in the provision of switched, private line or DSL services. Legal rulings that halted further UNE-P sales in 2007 resulted in a major decline. It is now more obvious that the CLEC industry subsequently changed its focus regarding UNE services. CLEC services based on UNE-P were at one time heavily oriented towards serving the residential market. With the rule change, UNE-P services were grandfathered and allowed to be churned-out with the shift of residence customers to communication alternatives combined with housing relocation. The reduced use of UNEs is expected to continue as ILECs shift from copper-based lines and end-user services demand more modern technology solutions from CLECs. Figure 13. UNE Lines in Oregon 2005-2014 UNE Lines in Oregon 2005-2014 250,000 200,000 150,000 100,000 50,000 0 UNE Lines 2005 210,695 2006 194,801 2007 138,506 2008 112,995 2009 103,357 2010 91,276 2011 84,903 2012 82,906 2013 72,362 2014 88,162 11 UNE is the commonly used industry term. In this report, it is intended to include UNE-Ps served in prior years. Page 20 Competition Survey Year 2015 Final Report IV. High Speed Access Services a) Private Line Service Intrastate private lines are dedicated circuits used by customers to transmit information between two or more pre-selected, fixed locations within the state of Oregon. Intrastate private line services are available in a range of capacities or bandwidths. The survey distinguishes between lower capacity circuits, with a bandwidth of less than 1.544 Megabits per second, and higher capacity circuits with a bandwidth of 1.544 Mbps or greater. Figure 14, below, illustrates that 54.5 percent of private line circuits were in the lower capacity category with 45.5 percent in the higher capacity category. Figure 14. Oregon Private Line Circuits by Types All LECs Private Line Circuits by Type, 2014 Higher Capacity 44.1% Lower Capacity 55.9% Total revenue from intrastate private line services was 11 percent of the total 2014reported ILEC and CLEC revenues. Digital Subscriber Lines, or DSL, accounted for 26.1 percent of those revenues and switched service accounted for the remaining 62.9 percent of them. DSL is generally only provided by ILECs and CLECs utilizing circuitswitched technology. Non-certificated providers12 utilize an IP based broadband service, usually bundled with video services. Revenues and line counts from such providers are not included in this report. Table 10, below, compares total counts and shows CLEC market share of intrastate private line services. Sixty-one CLECs reported that they provide intrastate private line 12 Non-certificated providers are telecommunications companies that are not certificated by the OPUC. Page 21 Competition Survey Year 2015 Final Report service. CLEC private line market shares ranged from 26.1 percent (measured by circuits) to 63.3 percent (measured by revenue). The percentage depends on how market share is defined. As with switched access lines, the survey measured CLECs’ market share in three ways: by customers, circuits, and revenues.13 Table 10. Intrastate Private Line Services 2014 Private Line Customers Total Private Line Circuits All LECs CLECs ILECs CLEC Share 2,962 795 2,167 26.8% 14,868 3,882 10,986 26.1% Lower Capacity 8,109 199 7,910 2.5% Higher Capacity 6,759 3,683 3,076 54.5% $58,210 $36,827 $21,383 63.3% Annual Revenues ($000) In 2014, the CLEC share of private line customers was 26.8 percent, or 795 customers,14 while ILECs provided local private line service to 2,167 customers, or 73.2 percent of the total. The CLEC market share of all private line circuits was 26.1 percent. The CLEC market share of lower capacity circuits was 2.5 percent, while the market share for higher capacity circuits was 54.5 percent. CLEC private line circuits, including lower and higher capacity circuits, totaled 3,882 in 2014. Table 11, below, shows that the CLEC share of total local private line service revenues15 was 63.3 percent. Total ILEC and CLEC revenues from local private line services in 2014 were an estimated $58.2 million. Of the total estimated annual revenues, ILECs received $21.4 million (36.7%) and CLECs $36.8 million (63.3%). 13 A circuit is a commonly accepted industry term for facilities, such DS1 and DS3 private lines or circuits, rather than switched access lines. Circuits, however, can equate to switched access lines. For example, a DS1 circuit can equal 24 switched access lines; a DS3 circuit can equal 672 switched access lines. A circuit may connect two customer locations. If so, customers will be billed for each connection or termination. Each circuit will have at least two terminations. The capacity of a circuit is determined by the capacity delivered to the customer at the point of termination, even though the customer may further subdivide that capacity using its own multiplexing or other equipment. 14 Note that survey results may overstate CLECs’ share of local private line customers, since local private line customers may buy private line services from more than one carrier at a time. As a result, a CLEC and an ILEC may report the same entity as a private line. Page 22 Competition Survey Year 2015 Final Report Table 11. Private Line Service Revenues: 2014 2014 Share $ Million/year Total ILECs CLECs 100.0% $58.2 36.7% $21.4 63.3% $36.8 b) DSL Service Digital subscriber line (DSL) is a service that uses a technology that combines two-way voice and data transmissions at very high speeds over copper telephone lines and hybrid networks that combined copper and fiber technology. The total number of ILEC and CLEC DSL lines in Oregon was 365,500 in 2014 and 365,228 in 2013. About 93 percent of the lines were provided by ILECs and 7 percent were provided by CLECs (see Figure 15, below). Figure 15. Oregon Digital Subscriber Lines (DSL) Digital Subscriber Lines (DSL) Service in Oregon 2014 CLEC 7% ILEC 93% DSL and private line services accounted for 32.2 percent of total local exchange revenue in 2014, a decrease of 2 percent over the 34.2 percent in 2013. Figure 16, below, illustrates the trend of high-speed digital access as a percentage of both ILEC and CLEC total revenue.16 In 2005, combined intrastate private line and DSL revenue comprised 16.6 percent of total revenues. The steady increase continued, reaching 32.2 percent in 2014. Broadband penetration is believed to be nearly 100 16 Total revenue here is limited to switched access lines, intrastate private lines and DSL. Page 23 Competition Survey Year 2015 Final Report percent in metro areas. As penetration levels increase in markets outside of metro areas, revenues will increase accordingly. Figure 16. Trend of Private Line and DSL Access in Oregon High-Speed Digital Access Share in Oregon Measured by Revenue 35.0% 30.0% 25.0% 20.0% 15.0% 10.0% 5.0% 0.0% 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 % 16.6% 19.4% 18.4% 21.4% 25.6% 25.7% 27.5% 32.4% 34.2% 32.2% c) VoIP Service The information available in 2013 indicated an upward trend in active VoIP telephone numbers, a surrogate for VoIP lines. Figure 17, below, illustrates that based on 2014 information the increase in residential and business VoIP service in Oregon has continued. Fixed interconnected VoIP Service is a service that enables real-time, twoway voice communications; requires Internet-protocol (IP) compatible customerpremises equipment (CPE); and permits users generally to receive or initiate calls that may originate or terminate, respectively, on the public switched telephone network (PSTN). The total number of Oregon active VoIP phone numbers reported in 2013 was 396,676, served by 29 reporting carriers. Cable companies served a large majority of the numbers. Figure 17, below, indicates that 485,744 VoIP phone numbers were reported in 2014 and were served by 45 reporting carriers. Although service details are not known, the generally accepted belief is that cable companies focus on residential customers. Additional 2014 information and analysis indicates that the huge majority of active Oregon VoIP phone numbers are being utilized Page 24 Competition Survey Year 2015 Final Report by CLECs and non-certificated affiliates17 believed to focus on business services. The 2014 information and analysis points to as many as 64 CLEC and non-certificated affiliates serving over 1.5 million VoIP phone numbers and participating in the delivery of Oregon VoIP services, some of which are known to not directly compete with Local Changes Services. Additional analysis will be needed to determine what percentage of the total CLEC and non-certificated VoIP phone numbers are used to displace local exchange service landlines and what percentage are used for the non-local exchange services. Figure 17. VoIP Trend Estimated Active Oregon CLEC & Non-certificated Affiliated VoIP Telephone Numbers 485,744 600,000 396,676 500,000 355,786 400,000 369,602 311,004 300,000 200,000 100,000 0 2010 2011 2012 2013 2014 d) CLEC Provisioning of Private Line Circuits Twenty-eight CLECs provided private line services by reselling ILEC services. Eleven CLECs provided private line service by reselling services of other CLECs. Most of this resale activity was to business customers in the Portland Metropolitan and Willamette Valley areas. 17Non-certificated affiliates depend on certificated CLEC affiliates, such as subsidiaries or parent companies, to facilitate local exchange interconnection needs and telephone number services. Page 25 Competition Survey Year 2015 Final Report V. Market Segments by Region and Type of Service The survey divided Oregon into six geographic regions. The following map shows the makeup of the regions based on the counties. The six regions are: Portland Metropolitan, Willamette Valley, Southwest Interior, Coast, Central, and East. Regions by Counties Page 26 Competition Survey Year 2015 Final Report a) Market Segments by Region Switched Services by Region The survey asked each LEC to report the number of switched local exchange lines served in each region. The Portland Metropolitan region, the most populous area of the state, continues to be the regional market with the largest share of lines with 46.1 percent (see Figure 18, below) of all local exchange switched lines in the state. The region with the second largest share was the Willamette Valley with 25.2 percent of switched access lines. The remaining four regions collectively accounted for nearly 30 percent: Southwest Interior (10.6%), Coast (7.1%), Central (6.1%), and East (4.9%). Figure 18. Oregon LEC Switched Lines by Region Switched Line Distribution by Region, All LECS, 2014 75.0% 50.0% 25.0% 0.0% % Portland 46.1% Willamette 25.2% S.W. 10.6% Coast 7.1% Central 6.1% East 4.9% Survey responses indicate that CLECs provided local switched service in all six Oregon regions. Statewide, CLECs had a 45.6 percent share of switched local exchange lines. For the Residential market, CLECs had 48.5 percent of lines in the state in 2014. For the Business market, CLECs had 45.3 percent of lines in the state. Page 27 Competition Survey Year 2015 Final Report Figure 19, below, illustrates the distribution of residential and business lines served by the CLECs across the six regions. Business lines comprise approximately 33.6 percent of the total lines served by CLECs. Sixty-eight percent of CLEC business switched lines are provisioned in the Portland region, with lower provisioning levels in the Willamette Valley, the Southwest, Central, Coast, and East regions. Residential lines comprise 60 percent of the 654,918 total lines served by CLECs. Slightly over 40 percent of all CLEC residential lines were reported in the Portland area with the Willamette area not far behind at 32.3 percent. Figure 19. Distribution of CLEC Switched Access Lines by Region Distribution of CLEC Provided Switched Access Lines in Oregon - 2014 60.0% 40.0% 20.0% 0.0% Residential Business Portland 40.2% Willamette 32.3% S.W. 14.7% Coast 7.0% Central 3.3% East 2.5% 68.2% 15.9% 5.2% 1.7% 6.2% 2.7% Private Line Service by Region Private lines are distributed across regions by circuit terminations rather than circuits. Therefore, as measured by terminations, the Portland Metropolitan region is the largest regional private line market, with 35 percent (see Figure 20, below) of all retail private line circuits in the state. The second largest region was the Willamette Valley, with 23.1 percent of private line circuits. Results for the remaining four regions are Central (11.3%), Southwest Interior (12.9%), East (9.6%), and Coast (8.0%). Page 28 Competition Survey Year 2015 Final Report Figure 20. Private Line Circuits Terminations by Region: 2014 All LECs Private Line Distribution, 2014 40% 30% 20% 10% 0% All LECs Portland 35.0% Willamette 23.1% S.W. 12.9% Coast 8.0% Central 11.3% East 9.6% Of the state's 14,868 local exchange private line circuits, the majority (54.5%) were in the lower capacity category. The Portland Metropolitan region was the largest market for lower capacity circuits, with 32.2 percent (see Figure 21, below). The second largest market was the Willamette Valley region with 25.8 percent, followed by the Central and East (both 12.2%), Southwest Interior (10.7%), and Coast (6.8%) regions. Figure 21. Lower Capacity Private Line Circuits by Region: 2014 All LECs Lower Capacity Circuits by Region, 2014 40% 30% 20% 10% 0% All LECs Portland 32.2% Willamette 25.8% S.W. 10.7% Coast 6.8% Central 12.2% East 12.2% Page 29 Competition Survey Year 2015 Final Report Higher capacity private line circuits accounted for 45.5 percent of the state's total private line circuits. In 2014, the largest market for higher capacity private line circuit terminations was the Portland Metropolitan region, with 38.6 percent of the state’s total (see Figure 21). The second largest market was the Willamette Valley region, with 19.8 percent, followed by the Southwest Interior (15.6%), Central (10.2%), Coast (9.4%), and East (6.4%) regions. Figure 22. Oregon Higher Capacity Circuits by Region: 2014 All LECs Higher Capacity Circuits by Region, 2014 40% 30% 20% 10% 0% All LECs Portland 38.6% Willamette 19.8% S.W. 15.6% Coast 9.4% Central 10.2% East 6.4% The regional distribution of all LEC private lines has fluctuated over the last several years as indicated in Figure 23, below. The Portland Metro region’s share of total private line circuit terminations was 35 percent in 2014 and seems to be declining slightly year over year. Page 30 Competition Survey Year 2015 Final Report Figure 23. Private Line Circuits Distribution: 2010 through 2014 Private Line Circuits Distribution by Region, 2010-2014 40.0% 35.0% 30.0% 25.0% 20.0% 15.0% 10.0% 5.0% 0.0% Portland 38.9% Willamette 26.0% S.W. 8.6% Coast 8.1% Central 9.3% East 9.1% 2011 36.7% 19.9% 12.5% 9.6% 10.9% 10.4% 2012 37.70% 21.7% 12.7% 9.9% 8.7% 9.4% 2013 35.9% 24.1% 12.5% 8.7% 10.1% 8.7% 2014 35.0% 23.1% 12.9% 8.0% 11.3% 9.6% 2010 Page 31 Competition Survey Year 2015 Final Report DSL Service by Region DSL (all types of digital subscriber lines) service was provided for 365,500 lines in 2014 and generated $138.8 million in revenue. Of all DSL, 47.9 percent was in the Portland Metropolitan region (see Figure 24), followed by the Willamette Valley (21.3%), Southwest Interior (9.5%), Coast (8%), Central (7%), and East (6.3%) regions. Figure 24. Oregon DSL by Region DSL in Oregon by Geographical Location 2014 50.0% 40.0% 30.0% 20.0% 10.0% 0.0% DSL Portland 47.9% Willamette 21.3% S.W. 9.5% Coast 8.0% Central 7.0% East 6.3% Page 32 Competition Survey Year 2015 Final Report VI. Business Plans and Competition a) Capital Expenditures Capital expenditures are funds invested to acquire or upgrade physical assets such as telecommunication switches and fiber optic cable. The survey asked for information on investment in capital assets. Total ILEC and CLEC capital expenditures in 2014 associated with providing local exchange service in Oregon were reported to be in the range of $71- $285 million. Only 154 of 206 certified CLECs responded to the request for capital expenditures. Of the 154 CLEC respondents, 79.9 percent (123 of 154) reported capital expenditures less than $10,000. As reported by the responding CLECs, 2014 capital expenditures are estimated to range from $20 - $117 million. Since the upper range of the potential CLEC capital investment actually exceeds the 2014 CLEC local exchange revenue of $109 million, the likely investment is probably going to be on the low side or mid-range. Thirty of the 32 certified ILECs reported capital expenditures in 2014. Total ILEC capital expenditures were reported to range from $51 - $167 million. Table 12. 2014 Capital Expenditures for Local Exchange Service Capital Expenditures ILECs CLECs All LECs Less than $10,000 3 123 126 $10,000-50,000 1 7 8 $50,001-100,000 3 3 6 $100,001-1,000,000 9 11 20 $1,000,001-10,000,000 10 9 19 More than $10,000,000 4 1 5 30 154 184 $51 - $167 $20 - $117 $71 - $285 # of LECs making Capital Expenditures Estimated Expenditures ($M) Page 33 Competition Survey Year 2015 Final Report b) Competition for Residential Market In response to the question "What do you believe are the reasons that you do not have a bigger share of Oregon's residential market?”19 of 32 ILECs (59%) noted that cell phone usage has reduced the demand for wireline (including second-line) services (see Table 13, below). Nine ILECs indicated that the lower residential customer density (than business density) made providing residential services difficult or expensive. Of the 206 CLEC respondents, 158 provided responses to the same question stated above. One hundred twenty-three of the responding CLECs indicated that they could not compete on price. That figure nearly equals the number of CLECs that responded to the entire set of question options in 2013 – 128 CLECs. Four indicated that they could not compete on facilities, ten stated that the incumbent local exchange-carrier name familiarity was a competitive issue, and 12 stated that they did not have enough capacity. Only six of the 158 CLECs responding to the question (3.8%) indicated that cell phone usage has reduced the demand for residential wireline services, and three CLECs considered geographic location a competitive disadvantage for serving residential customers. No firm conclusion can be taken from the CLEC responses regarding the difficulties of residential market competition. However, the extraordinary increase (123 in 2014 compared to 25 in 2013) in the selection of ‘price’ as a competitive disadvantage seems consistent with the business focus of CLECs. The cable companies and wireless companies are the key participants in residential local exchange services competition rather than the CLECs. Table 13. Residential Market Competition: 2014 Reasons # of ILECs # of CLECs Cannot compete on price 4 123 Cannot compete on facilities 2 4 ILEC has name familiarity 0 10 Do not have enough capacity 0 12 19 6 9 3 12 0 Cell phone decreased the wireline demand Hard to compete due to location Other (explain): Page 34 Competition Survey Year 2015 Final Report c) Landline telephone industry is shrinking The 2014 survey results support the generally understood belief that ILEC and CLEC market is declining as technology alternatives gain more acceptance. Reasons for the shrinking landline market include the development of fiber optics, cable telephony, and other new technologies, which enable alternatives for traditional landline phone service in some geographic areas. In addition, an increasing number of households have dropped landlines altogether and subscribe only to wireless telephone services. Oregon’s ILEC and CLEC lines have decreased from 2.1 million lines in 1999, when this survey was initiated, to 1 million in 2014, and revenue declined from $976 million in 1999 to $531.2 million in 2014. Conclusions Oregon's ILEC and CLEC local telecommunications market in 2014 is a $531.2 million industry that includes 1 million switched lines, 14,868 intrastate private line circuits, and 365,500 DSLs. Industry-wide, revenues for switched, private line and DSL services in Oregon increased by $3.8 million from those reported in 2013, including cable company information. The number of switched lines served in 2014 is approximately 35 percent lower than in 1999. The decrease reflects the competitive impact of wireless phones, and both mobile and fixed high-speed Internet access services and, just as important, changing demographics. Two major end-user factors are involved. End-users accustomed to only wireline local exchange phones have shifted some usage to wireless phones. As this demographic segment ages and drops local exchange service, the number of wireline local exchange customers will decline accordingly. New users entering the telecommunications market, however, are going directly to wireless phones without any dependence on wireline phones. A key provider factor is also involved. Rather than exit the residential market, as was originally expected of the CLECs in response to the major change in UNE-P rules, CLECs are choosing to compete indirectly for residential customers by providing interconnection and number services to non-certificated affiliates who serve end-users directly. This constitutes a business realignment strategy rather than an exit strategy. Cable companies are examples of this alignment. The alignment in the residential market may be a leading indicator of the alignment that will eventually occur in the business local exchange market. Page 35