June 7, 2021

VIA ELECTRONIC MAIL

Chairman Charlotte Lane

Public Service Commission of West Virginia
201 Brooks Street
Charleston, WV 25301

Re: Suddenlink Response to Commission Regarding Customer Service

Dear Chairman Lane:
Altice USA, Inc. (“Altice” or the “Company”), which offers video, broadband and voice services
in West Virginia as Suddenlink, respectfully responds to the West Virginia Public Service
Commission’s (the “Commission’s”) informal request in a private meeting with the Company
and reflected in a press release by the Commission dated May 6, 2021 (the “May 6 release”)
concerning certain issues raised by Suddenlink customers.
We previously provided information to the Commission on investments made to ensure the
delivery of reliable products and services to West Virginia customers, consistent with applicable
legal/regulatory requirements, and to address customer complaints. We elaborate further
herein on those measures and on the specific issues raised by the Commission and in the May 6
release.1 Specifically, we address issues relating to customer service/call answering (i) and field
service (ii) in Section III of this submission, and those relating to billing (iii-vii) in Section IV.2
In summary:
- Altice Has Invested In West Virginia To Offer Advanced Products Over Upgraded Networks
and To Address Service Concerns: The Company is investing heavily in its network, products
and services in West Virginia. As a result of these investments, Suddenlink offers its 1 Gig
product to 90% of WV households passed and less expensive options for low income

1
The issues identified in the May 6 release were: (i) how and when the company will open a call center in
West Virginia; (ii) how and when the company will hire technicians and various other employees in West
Virginia to service West Virginia customers; (iii) how the company will fix problems with incorrect 911 fees
being billed to customers; (iv) how the company will accurately and timely process payments and credits to
customer accounts; (v) how the company will fix billing errors; (vi) how the company will ensure late fees are
accurately assessed; and (vii) identify who is doing the billing for the company.
2
Altice refers to and incorporates by reference its May 5, 2021 verbal presentation to Chairman Lane. To the
extent the Commission’s release seeks a “correction plan,” please consider the May 5 presentation and this
response as such a plan (which Altice is already executing).
 customers,3 is upgrading other markets to offer 400 Mbps4 and continues its investments to
address incidents of local congestion from increased network usage (remote work, school)
during the COVID-19 pandemic.5 The Company has had to manage through the impacts of
the pandemic, including the temporary unavailability of personnel resources due to site
closures, quarantines, and other pandemic impacts on customer and field service. In
addition, the Company has completed integration of the WV operational platform with the
rest of Altice’s system, which will facilitate future product and service enhancements in the
State, but which resulted in temporary disruptions for some customers.
- Altice Has Improved Service, and Its Practices Comply With Applicable Standards. As a
result of these investments and strategic modifications to operations, key service indicators
for WV customers have improved dramatically in recent quarters. The Company is now
responding to substantially more than 90% of customer telephone calls within 30 seconds,
has many fewer than 3% of calls abandoned, and has seen a noticeable decline in call
volume and complaints. Altice’s practices are built around compliance with these and other
applicable regulatory standards, and its current performance demonstrates as such.
- Altice Has Resolved Customer Complaints: The Company acknowledges that pandemic
impacts, severe weather, the system integration and other issues were factors in some of
the complaints since January 2019 cited in the Commission’s release.6 The Company has
successfully resolved 99% of those complaints, in many instances issuing credits for
customer inconvenience. However, to the extent the Commission forwards additional
individual cases, Altice will promptly investigate the matter and work to address specific
issues.
In the attached, we address the specific issues raised in the Commission’s release and in our
discussions. We believe that the continued improvement on the service quality metrics
described in this Response demonstrates that the issues raised to the Commission about
Altice’s provision of services are adequately addressed.7
We look forward to continued productive engagement with the Commission and other public
officials to focus investment and attention on the Suddenlink WV customers that Altice serves.

3
Altice is enthusiastically participating in the FCC’s Emergency Broadband Benefit Program (EBB) giving
eligible households a discount of up to $50 per month off monthly service. We note that the Company has
various initiatives in response to the COVID-19 pandemic – including free broadband for 60 days for
households with K-12 students -- to support customers, schools and students, communities and employees.
4
Through the FCC’s Rural Digital Opportunity Fund, Altice is expanding its network to serve households
without robust broadband today.
5
Altice seeks to partner with West Virginia, counties and individual municipalities to maximize the customer
benefits from the $120M in Federal COVID stimulus funding we understand the State has allocated to
broadband.
6
We note that 1,900 complaints – even if each were raised by unique customers on unique issues – would
constitute less than 1% of the Suddenlink WV customer base.
7
This Response also contains information on services and other aspects of the Company’s business that are
beyond the scope of the Commission’s authority, but about which we provide information in the interest of a
constructive dialogue. Altice respectfully reserves all of its rights and objections with respect to the scope of
the Requests, and this Response is not to be construed as a waiver of any rights and/or objections.

2
Sincerely,

James Campbell
Vice President, Government Affairs

CC: Karen Macon, Director

Carla Nelson, Information Complaints
Terri Blake, Supervisor

Enclosure

3
I. SUDDENLINK IN WEST VIRGINIA
Altice offers service to more than 300,000 households and small businesses in West Virginia
over an upgraded, fiber-rich hybrid fiber optic-coaxial (“HFC”) network with more than 8,500
plant miles and 8 headends across the state.
Altice is executing a range of investments in West Virginia, including:
• Network Enhancements. Altice has enhanced its network- to increase available
broadband speeds and improve performance. To address the unprecedented and rapid
increase in network demand resulting from the COVID-19 pandemic,8 Altice has been
investing millions to add capacity, increase speeds and address localized pockets of
network congestion. Altice invests in technologies to offer a safe and secure online
experience, including a built-in web link validation feature warning customers of
potentially-malicious websites at no incremental charge.
• Advanced Connectivity Equipment & Smart Wi-Fi: Throughout its WV service territory,
the Company offers Altice One, an all-in-one gateway device and user interface
integrating traditional cable and over-the-top video service and 40% better Wi-Fi
performance. In addition, Altice has introduced a Wi-Fi 5 internet gateway providing
access to higher Wi-Fi speeds and with a similar 40% better Wi-Fi performance than
previous routers. Altice has also enabled the Altice One Mini STB as a Wi-Fi repeater,
helping customers extend Wi-Fi coverage, and added intelligent Smart Wi-Fi to Altice
One to provide a better Wi-Fi experience. Just recently, Altice introduced Smart Wi-Fi 6
Gateway with the most advanced Wi-Fi technology.
• Free and Low-Cost Broadband Offers: The Company offers Altice Advantage Internet
(AAI) – with download speeds of up to 30 Mbps for $14.99 per month – to qualifying
low-income households throughout the Company’s WV service territory. Fully launched
in September 2017 to households with students eligible for the National School Lunch
Program and/or senior citizens eligible for Supplemental Security Income, AAI is now
also available to veterans that receive state or federal assistance. In 2020, the Company
twice offered 60 days of free AAI service to any customer household with students who
lack broadband at home.9
• Altice Mobile: Altice Mobile offers nationwide mobile service at customer-friendly
prices, creating a competitive alternative to comparable wireless providers. In January,
the Company upgraded Altice Mobile to leverage T-Mobile’s 5G network, the nation’s
largest, fastest, and most reliable network.
• Customer Service Tools: To give customers multiple ways to interact with the
Company, Altice has invested heavily in service tools, including –

8
As discussed further in Section II, by the end of 2020, data consumption was nearly 40% above Jan. 2020
levels.
9
This offer is currently available - https://www.alticeadvantageinternet.com/

4
 - IVR: Altice’s state-of-the-art Interactive Voice Response (“IVR”) system allows
customers to get balance information, pay their bill, find out if there is an outage
affecting their service, and obtain other information about their services.

- Skills-Based Routing and Call Back Option. For those customers wishing to speak
with a representative, the IVR routes those calls to a representative with knowledge
specific to the nature of the customer inquiry (e.g., video, broadband, Wi-Fi). To
accommodate customers who do not want to wait on hold, the IVR gives the option
for customers to request a call back when a representative is available, without
losing their place in the queue.

- Direct Message, Suddenlink.net, Chat, Support App, Social: Earlier this year, Altice
deployed a new support channel giving customers the option to transfer from the
IVR to interact with the Company via online messaging. Suddenlink.net allows a
customer to chat with customer service representatives to obtain a variety of
information and request service, get updates on outages, pay bills, and change
products/services. The Suddenlink support app available on android and iOS
platforms provides similar functionality and information. The Company proactively
monitors social media for issues suggesting a systemic service issue. Customers can
also get outage information via text message.

II. ALTICE HAS MADE SUBSTANTIAL PROGRESS IN ADDRESSING THE ISSUES GIVING RISE
TO MANY OF THE COMPLAINTS CITED BY THE COMMISSION
The Commission has specifically raised concerns about the fact it has received more than 1,900
complaints from Suddenlink customers since 2019. Altice’s goal is to provide excellent
customer service and mitigate any reason for customer complaints. However, during this time
period, there were four atypical events which contributed to some consumers’ frustrations.
• First, in September 2019, Altice invested in a new business and operations support
system that ultimately benefits customers by allowing the Company to rapidly deploy
product innovations and upgrades (such as Altice One and Smart Wi-Fi) and support
tools and information (such as customer service chat enhancements) to West Virginia
customers. However, at the time of the implementation, there were system glitches
that resulted in customer-facing issues that have now been resolved.
• Second, beginning in March 2020, the Company experienced the unexpected impacts of
the pandemic, which caused a major shift in network usage patterns, as customers
relied heavily on Suddenlink’s broadband offerings for both remote work and learning.
This rapid increase in demand on the network resulted in some localized network
congestion, and impacted Suddenlink’s care and field service resources directly.
• Third, severe weather events in July, August (including Tropical Storm Isaias) and
September 2020 impacted operations in Company’s West Virginia service territory;
these events, which often result in temporary service outages from loss of commercial
power and/or plant damage and increased call volume, are likely reflected in the
relative increases in complaints during the relevant period.

5
 • Fourth, delays in the U.S. Postal Service delivery in Q4 2020 through Q1 2021 resulted in
mailed payments being received beyond the due dates prominently included on
customer bills.
We are pleased to report that comparing July 2020 (where the pandemic effects were felt most
acutely) and April 2021, complaints to the Commission have declined by 65% and call volume
has declined by 25%, approaching pre-2019 levels. Below we provide more specifics on the
impacts of the these out-of-the-ordinary factors, and the Company’s responses to them.
Upgrade of the Suddenlink Business and Operations Support Systems Temporarily Disrupted
Certain Customers. In September 2019, and with prior notice to the Commission, Altice
invested to upgrade the Suddenlink networks to a new business and operations support system
(BSS/OSS migration) benefitting customers by allowing the Company to rapidly deploy product
innovations and upgrades (such as Altice One and Smart Wi-Fi) and support tools and
information (such as customer service chat enhancements) to West Virginia customers. While
the upgrade facilitates product and service enhancements to West Virginia customers, and
while services were not impacted, the online billing system was inaccessible for five days,
installations and non-essential service visits were temporarily halted, and certain customers
experienced billing and provisioning issues. Altice waived late fees for the time period before
and after the migration and worked diligently to resolve other impacts – which were reflected
in decreased customer call volume, wait times, and abandonment after September 2019.
Notably, Altice’s billing practices and procedures are handled in-house.
The COVID-19 pandemic posed unforeseeable, temporary challenges for Suddenlink’s network
and support personnel. The unprecedented transition to remote work and education during
the COVID-19 pandemic lead to a rapid and unforeseeable spike in data usage on the
Suddenlink network. Typically, Altice plans for a roughly 20% increase in data usage over any
given 12-month period. In 2020, data usage rose by 20% in just two months. By the end of
2020, data usage was up nearly 40% above January 2020 levels. The massive shift to remote
learning and work led to some customers reconfiguring their home networks, which caused an
increase in customer service issues unrelated to the performance of the Suddenlink network.
At the same time, the COVID-19 pandemic also temporarily affected Altice’s personnel
resources, as mandatory facility closures, employee quarantines, and other workplace
restrictions led to temporary limitations on our Customer Care and Field Service personnel
resources to address service issues. To respond nimbly to fluctuations in customer and field
service demands, the Company uses a mix of in house employees and contractors. Following
challenges to personnel availability, in some cases due to the pandemic, particularly in 2Q and
3Q 2020, Altice has secured additional personnel resources to serve customer requests,
including those from West Virginians, as reflected in the improved service metrics discussed
below.
US Post Office Delays Impacted Timeliness of Some Customer’s Payments. As widely reported,
the USPS struggled to deliver mail across the country during 4Q 2020 into 1Q 2021. By some
accounts, less than 50% of USPS delivered mail was considered delivered “on time” in this

6
period.10 These delays had adverse effects on consumers in many respects, including mortgage
payments, utility bills, and credit card bills. In response, the Company waived late fees for
affected customers, including through a specific prompt in its telephone response system
allowing customers to request such credits automatically. Altice also advised customers on
methods to ensure timely payment (such as electronic billing).
Severe Weather: Severe weather during July-September impacted some customers’ services.
While the Company takes measures (including the use of backup power) to avoid the impact of
severe weather on Suddenlink services, both Company facilities and customer homes rely
heavily on the availability of commercial power. Temporary loss of Suddenlink service from
commercial power loss, plant damage and/or restrictions on service vehicles’ access to
roadways in a storm’s aftermath are common and largely unavoidable impacts of severe
weather. The Company followed its protocols for pre-during-post storm preparations and
response.
III. ALTICE’S INVESTMENTS HAVE RESULTED IN SIGNIFICANT SERVICE IMPROVEMENTS, IN
COMPLIANCE WITH APPLICABLE REGULATORY STANDARDS
In response to the issues (i) and (ii) as identified in the Commission’s May 6 release – inquiring
about the opening of a call center and the hiring of technicians and other employees to service
Suddenlink customers in West Virginia -- Altice notes the following:
Call answering performance has dramatically improved. The Commission raised concerns
regarding Suddenlink’s service capabilities to handle customers contacting the Company by
phone. We did see temporary increases in call wait times beginning in September 2019 as a
result of BSS/OSS migration, and in 2Q and 3Q 2020 due to the impacts of the pandemic. In
response, Altice took measures to improve its Customer Care operations, including by:
- Increased Training: Cross training Customer Care agents to develop a more agile work
force capable of handling a broader range of customer issues;
- Remote Work Arrangements: In response to the pandemic, establishing work-from-
home capabilities for Customer Care personnel to mitigate the effects of site closures
and other workplace restrictions, and changing facility configurations to limit the need
for facility closures; and
- Self-Service Tools: Investing in additional service tools that offer alternatives to receiving
assistance via telephone, including developing guidance to help customers find the
optimal configuration of their home Wi-Fi networks;
As a result of these and other efforts, including substantial network investments, call answering
times in West Virginia normalized beginning in Q4 2020.11 These metrics now meet or exceed

10
See, e.g., New York Times, Postal Service Struggles to Speed Up Delivery, March 23, 2021; Washington Post,
USPS Delays Persist, February 26, 2021; A Traffic Jam of Mail, USPS Office of Inspector General, April 5, 2021.
11
In early 2021, the Company transitioned the Suddenlink networks to a new Cisco platform supporting call
routing and handling, and that transition has reduced call abandonment.

7
applicable FCC customer service standards, with average call wait times now under 30 seconds
and the call abandonment rate far below 3%.12
Field Service operations have improved significantly as a result of reorganization and
commitment of additional resources. Chairman Lane previously raised concerns regarding
Altice’s Field Service operations and technician performance. Altice acknowledges that its field
service operations were impacted by COVID-related factors, such as quarantines and safety
concerns about in-home service visits, as the Company balanced protection of customers and
employees with its service and repair goals. In addition, Altice took steps to replace field
operations resources that were not performing consistent with Altice’s expectations for service
quality. Lastly, Altice implemented a change in leadership and restructured Field Service
Operations in Fall 2020 to improve performance and the customer experience. The new
management team is focused on quality, including ensuring successful installation and service
requests on the first visit from a technician, without the need for repeat visits.
These changes have led to significant improvements. For example, the rate of calls received
from customers reporting technical issues has declined substantially since December 2020. In
addition, technicians’ on-time arrival rate is now at 96% as of April 2021, which reflects an
improvement since October 2020. The Company’s repeat service visit rate has also improved;
specifically, the number of repeat service visits within a 30-day period has declined by 26%
since October 2019 (just after BSS/OSS integration), and is now comparable to pre-BSS/OSS and
pre-COVID levels. As a result of resource augmentation, Suddenlink is resolving service-related
issues in a timely and effective manner. As of April 2021, overall customer satisfaction with the
Company’s field service performance is strong, with an average rating of 8.8 out of 10.
Altice has resolved 99% of all customer complaints and seen significant decreases in
complaint volume: Of the customer complaints between January 2019 and May 2021 the
Commission has raised to Altice, Suddenlink has resolved 99% of these complaints as of May 1,
with the remaining (fewer than 30) still under investigation or pending customer confirmation
that their issue has been resolved. For customers with specific billing-related issues, Altice has
corrected any errors and credited customers who were incorrectly assessed fees (including 911
and Late Fees) or other charges. Notably, the volume of complaints that Altice has received has
decreased significantly since the height of the COVID-19 pandemic; the Company’s April 2021
complaint total presents a significant decrease month-over-month.
IV. THE COMPANY’S BILLING AND OTHER PRACTICES ARE ESTABLISHED IN COMPLIANCE
WITH APPLICABLE LEGAL/REGULATORY/FRANCHISE STANDARDS
In response to the issues (iii) – (vii) in the Commission’s May 6 release – inquiring about the
Company’s plans to address problems with the billing of 911 fees, processing of payments and
credits to customer accounts, resolution of billing errors, late fee assessments, and that the
Company identify an individual responsible for customer billing -- Altice notes the following:

12
See 47 C.F.R. §§ 76.309(c)(1)(ii), 76.309(c)(1)(iv).

8
In the context of specific customer complaints, the Commission has inquired whether various
Company practices – including billing arrangements and late fees, pass through of government
fees and taxes, outage repair and credit rules, equipment return policies, field service
technician protocols, and telephone number porting – are in compliance with applicable legal,
regulatory, and franchise standards, including Chapter 150 of the Commission’s rules.
The Company takes compliance with applicable standards seriously, including state law
provisions on late fees, and designs its policies and procedures to meet or exceed those
standards. Customers affirmatively consent to the Company’s practices on pricing, fees and
taxes and receive multiple and prominent notices regarding same. The Company’s practice is
not to charge late fees or service visit assessments where the issue is attributable to
deficiencies in the Company’s network, products, services, support or billing protocols,
including charges associated faulty equipment or service visits missed by the technician. In
particular, we note that Enhanced Emergency Telephone System (“E-911”) fees that the
Company collects and remits to the State are established by each County in West Virginia, are
payable for an entire month regardless of the number of days the customer had service and
vary by County -- sometimes significantly.13 Occasionally, a customer’s service address is
incorrectly reflected in the Company’s billing database for various reasons, such as where their
billing address and service address are inadvertently miscoded. The Company’s policy is to
issue credits to the customer for such miscoding, in response to a customer inquiry or if
discovered through the Company’s own research.
In addition, Suddenlink complies with the FCC’s rules and policies on porting customer
telephone numbers to and from other voice carriers. Where we discover -- through internal
quality control and/or in response to customer, public official or other complaints or inquiries –
that a customer’s experience has not been in line with our practices – we provide a credit to the
customer and take other reasonable measures to mitigate any inconvenience. To the extent
the Commission has specific instances where customers raise such scenarios, we will promptly
investigate the matter, and contact the customer directly on our findings, and remedial steps, if
appropriate.

13
For example, the monthly E-911 fee in Kanawha County is $5.60 per local residential line v. $2.50 in Randolph
County (see http://www.psc.state.wv.us/E911_Plans/). See also W.Va. Code §7-1-3CC(b) (authorizing county
commissions to set these fees).