Federal Communications Commission DA 15-147
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Rural Call Completion
Petition for Limited Waiver of AT&T Services, 
Inc.
Petition for Waiver of CenturyLink
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WC Docket No. 13-39
ORDER 
Adopted:  February 2, 2015 Released:  February 2, 2015
By the Chief, Wireline Competition Bureau:  
I. INTRODUCTION
1. This Order addresses two Petitions for Limited Waiver of rules adopted by the Federal 
Communications Commission (Commission) in the Rural Call Completion Order.
1
  AT&T Services, Inc. 
(AT&T) requests a waiver of sections 64.2103 and 64.2105 of the Commission’s rules
2
for (1) certain 
portions of its Core and non-Core network traffic, and (2) in those instances where a terminating local 
exchange carrier (LEC) switch only supports multi-frequency signaling (MF signaling).
3
  CenturyLink 
also requests a waiver of recordkeeping, retention, and reporting rules where a terminating LEC switch 
only supports MF signaling.
4
2. Pursuant to section 1.3 of the Commission’s rules and the waiver procedure established in 
the Rural Call Completion Order,
5
the Wireline Competition Bureau (Bureau) conditionally grants
                                                     
1
See Rural Call Completion, WC Docket No. 13-39, Report and Order and Further Notice of Proposed Rulemaking, 
28 FCC Rcd 16154 (2013) (Rural Call Completion Order or Order); Order on Reconsideration, 29 FCC Rcd 14026 
(2014) (Rural Call Completion Recon Order).
2
See 47 C.F.R. §§ 64.2103, 64.2105.
3
See AT&T Services, Inc. (AT&T) Petition for Limited Waiver, WC Docket No. 13-39 at 4, 11, 14-15 (filed Apr. 
10, 2014) (AT&T Petition).
4
CenturyLink Petition for Waiver, WC Docket No. 13-39, at 2, 6 (filed July 28, 2014) (CenturyLink Petition).  In 
addition, both AT&T and CenturyLink requested a waiver of the recordkeeping, retention, and reporting rules for 
intraLATA/interexchange toll traffic where the originating LEC hands the traffic directly to the terminating provider 
or where the AT&T or CenturyLink LEC both originates and terminates the call.  The Commission previously 
dismissed these requests as moot when it determined that recordkeeping, retention, and reporting are not required for 
such traffic.  See Rural Call Completion Recon Order, 29 FCC Rcd at 14027, para. 2, 14051, para. 71-72.
5
See Rural Call Completion Order, 28 FCC Rcd at 16194-95, paras. 95-97; 47 C.F.R. § 1.3 (stating that the 
Commission may waive its rules, in whole or in part, for good cause shown).  To be clear, we grant this waiver 
pursuant to section 1.3 of the Commission’s rules.  Paragraph 96 of the Rural Call Completion Order provides 
factors that the Bureau should consider when deciding whether good cause to grant a waiver of our recordkeeping, 
retention, and reporting requirements has been shown.
Federal Communications Commission DA 15-147
2
AT&T’s request for limited waiver of certain aspects of the recordkeeping, retention, and reporting 
requirements in sections 64.2103 and 64.2105 of the Commission’s rules for certain portions of AT&T’s 
Core and non-Core network traffic.
6
The Bureau also clarifies that covered providers are not required to 
record, retain, and report on call attempt information that they are unable to obtain because the 
terminating LEC switch only supports multi-frequency signaling (MF signaling).
7
We believe that taking 
these steps is in the public interest, and will not compromise the Commission’s ability to address rural 
call completion problems.  In particular, the limited waiver we grant today is only available to providers 
that have taken significant steps toward preventing rural call completion problems from occurring by 
adopting practices that the Commission has identified as mitigating rural call completion issues.
8
II. BACKGROUND
3. Rural Call Completion Order.  Call completion performance for long-distance calls to 
rural areas can often be poor—a call may be significantly delayed, the called party’s phone may never 
ring, or a caller may hear a false busy signal, among other issues.
9
  These problems may be the result of 
practices that contravene prohibitions on blocking, choking, reducing, or restricting traffic and the 
Commission’s rules and precedents adopted under section 201 or 202 of the Communications Act of 
1934, as amended.
10
  The Rural Call Completion Order adopted, among other things, recordkeeping, 
retention, and reporting rules to improve the Commission’s ability to monitor the delivery of long-
distance calls to rural areas, and to aid enforcement action in connection with providers’ call completion 
practices as necessary.
11
  These rules apply to providers of long-distance voice service that make the 
initial long-distance call path choice for more than 100,000 domestic retail subscriber lines (covered 
providers).
12
  In most cases, the covered provider is the calling party’s long-distance provider—which 
includes LECs, interexchange carriers (IXCs),
13
commercial mobile radio service (CMRS) providers,
14
and VoIP service providers.
15
  
                                                     
6
See 47 C.F.R. §§ 64.2103, 64.2105.
7
Because this clarification addresses AT&T and CenturyLink’s respective requests for waiver of the Commission’s
recordkeeping and reporting rules where the terminating LEC switch only supports MF signaling, see AT&T 
Petition at 14-15, CenturyLink Petition at 6, we dismiss the CenturyLink Petition, and relevant portions of the 
AT&T Petition, as moot.
8
See Rural Call Completion Order, 28 FCC Rcd at 16194-95, paras. 95-97.
9
Id. at 16155, para. 1.
10
See Connect America Fund et al., WC Docket No. 10-90 et al., Report and Order and Further Notice of Proposed 
Rulemaking, 26 FCC Rcd 17663, 17903, para. 734, 18028-29, paras. 973-974 (2011), aff’d sub nom. In re: FCC 11-
161, 753 F.3d 1015 (10th Cir. 2014); Developing an Unified Intercarrier Compensation Regime; Establishing Just 
and Reasonable Rates for Local Exchange Carriers, CC Docket No. 01-92, WC Docket No. 07-135, Declaratory 
Ruling, 27 FCC Rcd 1351, 1356, para. 12 n.37 (Wireline Comp. Bur. 2012); Establishing Just and Reasonable 
Rates for Local Exchange Carriers; Call Blocking by Carriers, WC Docket No. 07-135, Declaratory Ruling and 
Order, 22 FCC Rcd 11629 (Wireline Comp. Bur. 2007); see also 47 U.S.C. §§ 201-202.
11
See Rural Call Completion Order, 28 FCC Rcd at 16164-91, paras. 19-84, 16211-214, Appx. A; 47 C.F.R. 
§§ 64.2103-64.2105.
12
See Rural Call Completion Order, 28 FCC Rcd at 16164, para. 19; 47 C.F.R. § 64.2101(c).  The “initial long-
distance call path choice,” refers to the static or dynamic selection of the path for a long-distance call based on the 
called number of the individual call.  For facilities-based providers, this decision may include choosing to deliver the 
call on the provider’s own network.  Rural Call Completion Order, 28 FCC Rcd at 16165, para. 20.  In addition, the 
Commission adopted a rule in the Rural Call Completion Order prohibiting all originating and intermediate 
providers from causing audible ringing to be sent to the caller before the terminating provider has signaled that the 
called party is being alerted.  See id. at 16202, para. 115.
13
An interexchange carrier is a telephone company that provides telephone toll service.  See 47 C.F.R. § 64.4001(d).
Federal Communications Commission DA 15-147
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4. Covered providers are generally required to record information about each call attempt to 
a rural Operating Company Number (OCN)
16
from subscriber lines for which the covered provider makes 
the initial long-distance call path choice, and retain the information in a readily retrievable form for a 
period that includes the six most recent complete calendar months.
17
  Covered providers must also 
electronically file quarterly, certified reports with the Commission.
18
  These reports must include the 
following information about subscriber lines for which the provider makes the initial long-distance call 
path choice, reported separately for each month in the quarter: (1) for each rural OCN – the OCN, the 
state, the total number of attempted interstate call attempts, the number of attempted interstate calls that 
were answered, and the number of attempted interstate calls that were not answered, reported separately 
for call attempts signaled as busy, ring no answer, or unassigned number; (2) the same information 
described in (1), but for intrastate calls; (3) the same information regarding attempted interstate calls 
described in (1), but for nonrural OCNs in the aggregate; and (4) the same information regarding 
attempted intrastate calls described in (2), but for nonrural OCNs in the aggregate.
19
  Based on these 
reports, the Commission can review the percentage of call attempts answered (the call answer rate) and 
the percentage of call attempts completed to the terminating provider regardless of whether answered or 
unanswered (the network effectiveness ratio), and can calculate the totals and values for the rural OCNs 
and the nonrural OCNs in the aggregate.
20
  
5. Managing Intermediate Provider Safe Harbor.  The rules adopted in the Rural Call 
Completion Order improve the Commission’s ability to monitor call completion practices in rural areas
and pursue enforcement actions where necessary.  At the same time, the Commission allowed providers 
that have practices consistent with the Commission’s call completion objectives to qualify for reduced 
reporting and retention requirements.  To this end, the Commission adopted the Managing Intermediate 
Provider Safe Harbor (Safe Harbor).  The Commission recognized that problems with routing calls to 
rural areas often arise where multiple intermediate providers are involved in transmitting a call.
21
  
Accordingly, the Commission adopted the Safe Harbor to encourage providers to reduce the number of 
intermediate providers in a call path to no more than two, thereby improving the ability to manage 
intermediate providers and call paths end-to-end.
22
  Qualifying providers may avail themselves of reduced 
(Continued from previous page)                                                            
14
See 47 C.F.R. § 20.9 (listing the mobile services that are regulated as CMRS).
15
See Rural Call Completion Order, 28 FCC Rcd at 16164, para. 19, 16166-67, paras. 22-23.  
16
An OCN is a four-place alphanumeric code that uniquely identifies providers of local telecommunications service.  
See id. at 16159, para. 8 n.28 (citing Alliance for Telecommunications Industry Solutions (ATIS), ATIS Telecom 
Glossary, http://www.atis.org/glossary/definition.aspx?id=8448 (last visited Jan. 8, 2015)).
17
Id. at 16182-84, paras. 61-65; 47 C.F.R. § 64.2103(a).  The specific information that each record must contain is 
set forth in sections 64.2103(c)-(e) of the Commission’s rules.  See 47 C.F.R. § 64.2103(c)-(e).
18
Rural Call Completion Order, 28 FCC Rcd at 16184-85, paras. 65-67; 47 C.F.R. § 64.2105(a).  
19
Rural Call Completion Order, 28 FCC Rcd at 16184, para. 65; 47 C.F.R. § 64.2105(b).
20
Rural Call Completion Order, 28 FCC Rcd at 16184, para. 65.
21
Id. at 16192, para. 87.  
22
See 47 C.F.R. § 64.2107; Rural Call Completion Order, 28 FCC Rcd at 16191-92, para. 86.  The Commission 
determined that an originating provider that limits the intermediate providers in the call path to two is better able to 
manage performance to rural destinations than an originating provider that sends calls through numerous 
intermediate providers, the identities of which the originating provider may not even know.  See Rural Call 
Completion Order, 28 FCC Rcd at 16192, para. 87.  Inteliquent notes that most call completion problems are caused 
by a “subset of providers ‘with a limited on-net footprint’ that use aggressive least cost routing strategies and ‘often 
route calls through extensive “daisy chains” of other intermediate providers which increases the likelihood of call 
completion problems due to excessive post-dial delay, looping, and other phenomenon.’  These aggressive least cost 
routers could not likely meet the Commission’s present Safe Harbor.”  Comments of Inteliquent in Support of 
(continued…)
Federal Communications Commission DA 15-147
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reporting and retention requirements through an annual self-certification process.
23
  Qualifying providers 
are required to report and retain data in the same manner as any non-qualifying provider but are limited to 
one year of reporting and are required to retain the information for only the three most recent complete 
calendar months.
24
6. Waivers of Data Collection and Retention Requirements.  Under the waiver process
established in the Rural Call Completion Order, the Bureau may consider requests for waiver of the 
specific reporting and data retention requirements in sections 64.2103-64.2105 of the Commission’s 
rules.
25
  In evaluating a provider’s waiver request, the Bureau will consider not only whether a provider 
has demonstrated that it qualifies for the Safe Harbor, but also whether it has processes in place to ensure 
that call attempts to rural incumbent LECs (ILECs) will reach their destinations, such as by adopting 
industry best practices.
26
  The Bureau will also consider whether the provider has demonstrated that it has 
capabilities and processes to monitor its performance by the OCN of the called party’s ILEC (rather than 
just at an aggregate level).
27
  The Bureau shall require, as a condition of a waiver, that a provider report 
information about rural call completion for a one-year period.
28
  Such a report may be based on a 
statistically valid sample of calls.
29
  In addition, the Bureau may require, as a condition of a waiver, that a 
provider collect and retain some data, such as data reflecting a statistically valid sample of calls to rural 
and nonrural areas.
30
7. AT&T and CenturyLink Waiver Petitions.  AT&T filed a Petition for Limited Waiver on 
April 10, 2014.
31
  Two commenters supported the petition and two opposed it.
32
  AT&T filed a Reply on 
(Continued from previous page)                                                            
AT&T’s Petition for Limited Waiver, WC Docket No. 13-39, at 4-5 (filed May 12, 2014) (quoting Reply Comments 
of Inteliquent, WC Docket No. 13-39, at 3 (filed June 11, 2013)) (Inteliquent Comments).
23
See 47 C.F.R. § 64.2107.
24
Id.  
25
Rural Call Completion Order, 28 FCC Rcd at 16195, paras. 95-97.  In the Rural Call Completion Order, the 
Commission delegated to the Bureau, in consultation with the Enforcement Bureau, the authority to act on such 
waiver requests.  See id. at 16195, para. 96.
26
See id.  In 2012, ATIS released the Intercarrier Call Completion/Call Termination Handbook outlining industry 
standards and practices relevant to ensuring call completion.  See ATIS, Intercarrier Call Completion/Call
Termination Handbook (Mar. 2013), https://www.atis.org/docstore/product.aspx?id=26780 (last visited Jan. 8, 2015)
(ATIS Handbook).
27
Rural Call Completion Order, 28 FCC Rcd at 16195, para. 96.
28
Id.
29
Id.
30
Id.
31
See generally AT&T Petition; Wireline Competition Bureau Seeks Comment on Petitions for Waiver Filed in the 
Rural Call Completion Proceeding, WC Docket No. 13-39, Public Notice, 29 FCC Rcd 4856 (Wireline Comp. Bur. 
2014).
32
See Comments of CenturyLink, WC Docket No. 13-39 (filed May 12, 2014) (CenturyLink Comments) 
(supporting the AT&T Petition); Inteliquent Comments (supporting the AT&T Petition); Comments of NTCA—The 
Rural Broadband Association, the National Exchange Carrier Association, the Eastern Rural Telecom Association, 
and WTA-Advocates for Rural Broadband (collectively the Rural Associations), WC Docket No. 13-39 (filed May 
12, 2014) (Rural Associations Comments) (opposing the AT&T Petition); Reply Comments of the National 
Association of Regulatory Utility Commissioners (NARUC), WC Docket No. 13-39 (filed May 19, 2014) (NARUC 
Reply) (opposing the AT&T Petition).  
Federal Communications Commission DA 15-147
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May 19, 2014.
33
  CenturyLink filed its Petition for Waiver on July 28, 2014.
34
Two commenters 
supported CenturyLink’s Petition.
35
III. DISCUSSION
8. The Commission adopted the recordkeeping, retention, and reporting requirements in 
sections 64.2103-64.2105 of its rules to improve the Commission’s ability to monitor call completion 
practices in rural areas and pursue enforcement actions where necessary.  As described above, the Safe 
Harbor allows providers that have practices consistent with these objectives to qualify for reduced 
reporting and retention requirements.
36
  The Commission created further incentives for providers to 
improve their rural call completion performance by adopting a waiver process for providers that are able 
to demonstrate that they have taken steps beyond those required for the Safe Harbor to ensure that calls to 
rural areas are being completed.
37
  The Commission adopted this waiver process to encourage providers 
to take immediate and decisive action to redress rural call completion problems and to adopt practices and 
processes to prevent rural call completion problems from occurring in the first place.
38
  
9. The Commission delegated to the Bureau, in consultation with the Enforcement Bureau, 
authority to act on waiver requests, such as the AT&T and CenturyLink Petitions for Limited Waiver.
39
  
Pursuant to this authority, we conditionally grant AT&T’s request for limited waiver of sections 64.2103-
64.2105 of the Commission’s rules regarding call data on AT&T’s Core Network and certain AT&T 
Mobility inter-MTA traffic that is not routed to rural OCNs.  We also grant AT&T’s request that it be 
given six months from the date of release of this Order to implement the system changes required to 
comply with the conditions of the grant of this waiver.
10. Our grant of these waiver requests is conditioned as follows: (1) AT&T must comply
with the Safe Harbor requirements set forth in section 64.2107(a)(1)-(2) of the Commission’s rules and 
file the required certifications;
40
(2) AT&T must develop and implement the systems needed to track calls 
on an ILEC-specific basis for rural OCNs and aggregate data for non-rural OCNs;
41
and (3) AT&T must
report information about rural call completion based on a statistically valid sample of calls for a one year 
period, and must retain such data for a three month period.
42
  We also condition our grant of AT&T’s 
request for limited waiver of sections 64.2103-64.2105 of the Commission’s rules regarding call data for 
                                                     
33
Reply Comments of AT&T, WC Docket No. 13-39 (filed May 19, 2014).
34
See CenturyLink Petition; Wireline Competition Bureau Seeks Comment on Petition for Waiver Filed in the Rural 
Call Completion Proceeding, WC Docket No. 13-39, Public Notice, 29 FCC Rcd 9440 (Wireline Comp. Bur. 2014).
35
See Comments of Public Utility Commission of Oregon, WC Docket No. 13-39 (filed Aug. 8, 2014) (supporting 
the CenturyLink Petition); Comments of AT&T Services, Inc., WC Docket No. 13-39 (filed Aug. 11, 2014)
(supporting CenturyLink’s request for a limited waiver).
36
See supra para. 5; 47 C.F.R. § 64.2107; Rural Call Completion Order, 28 FCC Rcd at 16191, para. 86.
37
See supra para. 6; Rural Call Completion Order, 28 FCC Rcd at 16191, para. 85, 16194-195, paras. 95-97.  The 
Commission may also waive its rules, in whole or in part, for good cause and may exercise its discretion to waive a 
regulation where the particular facts make strict compliance inconsistent with the public interest.  See 47 C.F.R. 
§ 1.3; Northeast Cellular Telephone Co. v. FCC, 897 F.2d 1164, 1166 (D.C. Cir. 1990) (citing WAIT Radio v. FCC, 
418 F.2d 1153, 1159 (D.C. Cir. 1969)).
38
See Rural Call Completion Order, 28 FCC Rcd at 16195, paras. 96-97. 
39
See id. at 16195, para. 96 (delegating to the Bureau, in consultation with the Enforcement Bureau, the authority to 
act on waiver requests of the specific reporting and data retention rules as described in the Rural Call Completion 
Order); see also 47 C.F.R. §§ 0.919(b) & (m), 0.291.
40
See infra paras. 23-25; 47 C.F.R. § 64.2107(a)(1)-(2).
41
See infra para. 30.
42
See infra paras. 27-30.
Federal Communications Commission DA 15-147
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AT&T Mobility inter-MTA traffic that is routed through non-AT&T intermediate providers as follows: 
(1) AT&T must not route calls subject to this waiver to rural OCNs; (2) AT&T must continue to 
contractually restrict its intermediate providers carrying AT&T originated traffic from using more than 
one additional intermediate provider in a call path before the call reaches the terminating provider or 
terminating tandem; and (3) AT&T and its intermediate providers must continue to comply with ATIS 
Best Practices.
43
11. We also clarify on our own motion that the Commission’s rules do not require covered 
providers to record, retain, and report information where the terminating LEC switch only supports multi-
frequency signaling (MF signaling) technology. We therefore dismiss as moot AT&T’s and 
CenturyLink’s requests for waiver of sections 64.2103-64.2105 of the Commission’s rules in instances 
where a terminating LEC switch only supports MF signaling.
44
A. AT&T’s Petition
12. AT&T requests waiver
45
of the recordkeeping, retention, and reporting requirements for
interexchange traffic transported by its Core Network
46
and AT&T Mobility inter-major trading area 
(inter-MTA) traffic that is not terminated through its Core Network and is not routed to rural OCNs.
47
  An 
MTA is a geographic boundary defined by the Commission for the purpose of issuing licenses for 
personal communications services (a low-powered, high-frequency alternative to traditional cellular 
services).
48
13. AT&T Core Network Traffic.  AT&T states that the vast majority of interexchange traffic 
transported by AT&T on a retail or wholesale basis is transported by the AT&T “Core Network.” The 
Core Network is owned and operated by AT&T Corp., AT&T’s primary interexchange service provider 
affiliate.
49
  AT&T “does not currently hand off traffic from its Core Network to any intermediate 
provider.”
50
  Instead, once a call enters the Core Network, AT&T terminates it either to the terminating 
tandem or directly to the terminating end office.
51
  The Core Network “transports traffic from: (1) AT&T 
and non-AT&T LEC customers that presubscribe to AT&T’s interexchange service; (2) wholesale 
customers; (3) enterprise direct connect customers; and (4) AT&T Mobility.”
52
  On March 13, 2014, 
AT&T acquired Leap Wireless, which operates under the Cricket brand.  AT&T plans to migrate at least 
some of Cricket’s traffic to the Core Network.
53
  AT&T proposes that, as Cricket traffic is migrated onto 
                                                     
43
See infra paras. 32-35.
44
The Bureau has delegated authority to act upon petitions for clarification under sections 0.91(b) & (m) and 0.291 
of the Commission’s rules.  See 47 C.F.R. §§ 0.919(b) & (m), 0.291.
45
AT&T seeks a “limited waiver of the call attempt recording, retention and reporting requirements in section 
64.2103-64.2105 of the Commission’s rules in those circumstances in which compliance with the new rules is 
technically infeasible using currently deployed equipment.”  AT&T Petition at 1.  It states that coming into full 
compliance with these rules would require AT&T to “invest millions of dollars in developing and executing costly 
and resource-intensive workarounds and retrofits, diverting resources from other priorities.”  Id. at 4.
46
Interexchange traffic is traffic carried by an interexchange carrier, which is defined in the Commission’s rules as a 
“telephone company that provides telephone toll service.  An interexchange carrier does not include commercial 
mobile radio service providers as defined by federal law.”  See 47 C.F.R. § 64.4001(d).
47
AT&T Petition at 11.  
48
See Harry Newton, Newton’s Telecom Dictionary 768, 873 (26th ed. 2011).
49
AT&T Petition at 8 n.30.
50
Id. at 8.
51
Id.
52
Id.
53
AT&T Petition at 11-12.
Federal Communications Commission DA 15-147
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AT&T’s Core Network, the traffic would fall within AT&T’s requested waiver for the Core Network 
traffic.
54
14. In support of its waiver requests, AT&T asserts that it meets the Safe Harbor 
requirements and has processes in place, including adopting industry best practices, to ensure that call 
attempts to rural ILECs reach their destinations.
55
  AT&T states, however, that even compliance with the 
more limited reporting and retention rules under the Safe Harbor would require AT&T to perform costly 
reprogramming of its TDM switches to collect data that it does not generally track today, costing from 
three to five million dollars.
56
  This is especially true, AT&T asserts, for the majority of calls on its Core 
Network, because “AT&T generally does not record data that is not used for billing, including for 
unanswered calls.”
57
  AT&T also states that, in some instances, this reprogramming may be technically 
infeasible.
58
  AT&T proposes to report instead on a statistically valid sample based on call attempts it 
already records.  The sample would include a subset of calls on the Core Network, including unanswered 
calls with cause codes.
59
  AT&T states that it is capable of monitoring its own performance, and ensuring 
that no systemic rural call completion issues arise, through use of data regarding this subset of calls on the 
Core Network, noting that all calls on the Core Network are routed the same way.
60
  AT&T proposes to 
collect and report on these calls for the one year period required by the Safe Harbor, but AT&T further 
requests that the obligations not begin until six months after the date that the limited waiver of the 
recordkeeping, retention, and reporting rules is granted, to allow AT&T an opportunity to change its 
recordkeeping system.
61
1. General Objections to the AT&T Petition and the Rural Call Completion 
Order Waiver Process
15. In filings responding to AT&T’s waiver request, NARUC and the Rural Associations 
voiced general concerns about the waiver process adopted in the Rural Call Completion Order, and also 
expressed concerns about AT&T’s Petition in particular.
62
  We first address the general concerns.  To the 
extent that parties argue that AT&T fails to satisfy the Commission’s waiver criteria, we address those 
arguments as part of our analysis of AT&T’s requests set out below.
63
16. The Rural Associations and NARUC assert that the Commission should consider waivers 
only in the narrowest of circumstances and only if the petitioner provides demonstrable proof that it
consistently completes calls to rural areas.
64
  As an initial matter, we note that to the extent that NARUC 
and the Rural Associations disagree with the waiver process the Commission adopted in the Rural Call 
Completion Order, the time for filing a petition for reconsideration has passed.
65
Moreover, the standard 
                                                     
54
Id.
55
Id. at 5-6.
56
Id. at 5-6, 9; see also 47 C.F.R. § 64.2107.
57
AT&T Petition at 9.
58
Id.
59
Id. at 9-10.  
60
Id. at 7, 10.
61
Id. at 15-16.
62
CenturyLink and Inteliquent filed comments in support of the AT&T Petition.  See generally CenturyLink 
Comments and Inteliquent Comments.
63
See infra paras. 21-39 (discussing AT&T’s waiver request for Core and Non-Core Network traffic).
64
See Rural Associations Comments at 2; NARUC Reply at 4.
65
A petition for reconsideration of a final order in a rulemaking proceeding must be filed within 30 days from the 
date of public notice of such action.  See 47 C.F.R. § 1.429(d).  The Rural Associations filed their comments on May 
(continued…)
Federal Communications Commission DA 15-147
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that the Rural Associations and NARUC propose would require a higher showing than the Commission 
originally articulated in determining whether a waiver request is justified.
66
  In the Rural Call Completion 
Order, the Commission set forth a specific process for considering whether to grant a waiver, and we 
apply that process to the facts presented.    
17. NARUC and the Rural Associations also assert that provider incentives and cost of 
compliance should counsel against a waiver grant.  NARUC argues that the problem of rural call 
completion has persisted for far too long, and that originating providers have the ability, but not always 
the financial incentive, to ensure that calls properly complete.
67
  The Rural Associations state that “given 
the substantial injury to rural communities attributable to call completion failure, the mere argument that 
compliance is ‘too expensive’ is offensive and must be rejected.”
68
  The Rural Associations also argue 
that the public’s interest in reliable voice service and the public safety and economic ramifications 
outweigh the financial inconvenience of compliance.
69
  NARUC argues that, in considering waivers, the 
Commission should ensure that crucial data needed to determine the scope and causes of rural call 
completion problems are not eliminated.
70
  NARUC notes that, because of AT&T’s size, the potential 
impact of granting AT&T a waiver is relatively significant.
71
  
18. We find these assertions unpersuasive.  In adopting the Rural Call Completion Order, the 
Commission carefully balanced the desire to obtain data on a significant portion of calls with the goal of 
encouraging good practices by reducing burdens for providers that implement practices designed to 
ensure successful call completion.  The waiver process was designed to give some measure of flexibility
(Continued from previous page)                                                            
12, 2014, one hundred forty-six days after publication of the Rural Call Completion Order in the Federal Register.  
NARUC filed its comments on May 19, 2014, one hundred fifty-three days after publication of the Order.  See 
NARUC Reply at 14; Rural Associations Comments at 4; FCC, Rural Call Completion, 78 Fed. Reg. 76218 (Dec. 
17, 2013), http://www.gpo.gov/fdsys/pkg/FR-2013-12-17/pdf/2013-29867.pdf.
66
For example, the Rural Associations also suggest that providers should conclusively demonstrate a minimum of 
“four quarters of comparable call completion performance between rural and nonrural areas before the Commission 
considers any relaxation of the data retention and reporting requirements.”  See Rural Association Comments at 2.  
Accord, NARUC Reply at 4.  Under the terms of the Rural Call Completion Order, however, the Bureau, in 
evaluating whether good cause exists to grant a provider’s waiver request, should consider:  (1) whether a provider 
has demonstrated that it qualifies for the Safe Harbor; (2) whether it persuasively demonstrates that it has processes 
in place to ensure that call attempts to rural ILECs successfully reach their destinations, such as by adopting industry 
best practices; and (3) whether the provider has demonstrated that it has capabilities and processes to monitor its 
own performance by the OCN of the called party’s ILEC (rather than just at an aggregate level).  Rural Call 
Completion Order, 28 FCC Rcd at 16195, para. 96; see also supra note 5.  As a condition of the waiver, the Bureau 
shall require that a provider report information about rural call completion for a one-year period, and such a report 
may be based on a statistically valid sample of calls.  Additionally, the Bureau may require as a condition of the 
waiver that a provider collect and retain some data, such as data reflecting a statistically valid sample of calls to rural 
and nonrural areas.  See Rural Call Completion Order, 28 FCC Rcd at 16195, para. 96.
67
NARUC Reply at 5.
68
Rural Associations Comments at 3.  NARUC argues further that the “expense of compliance may present some 
concern to those that need to comply,” but that the “Commission must not lose sight of the ongoing costs that 
failures to complete calls impose on rural consumers and businesses.”  NARUC Reply at 5.
69
Rural Associations Comments at 3.
70
NARUC Reply at 13.  NARUC notes further that data collection and retention requirements supply crucial tools 
that the Commission, State Commissions, and providers can use to determine the root causes and scope of call 
completion problems.  Id. at 12.  They argue that carrier data is indispensable to state and Commission staff 
investigations and enforcement of state and federal call completion mandates.  Id.  According to NARUC, a waiver, 
by definition, will eliminate at least some crucial data (or limit access to it) needed to determine the scope and 
causes of problems.  Id. at 13.
71
NARUC Reply at 4.
Federal Communications Commission DA 15-147
9
only to providers that have taken measures to ensure that calls to rural areas are being completed, 
regardless of their size or traffic volume.
72
  In other words, it is intended to encourage providers to adopt 
practices and processes that will prevent rural call completion problems from occurring in the first 
place.
73
  Imposing additional obligations as requested by the Rural Associations and NARUC would upset 
the balance struck by the Commission.  Accordingly, we reject the suggestion that we should deny the 
waiver merely because of AT&T’s size or traffic volume.  
19. We also disagree that cost of compliance should play no part in our decision to waive our 
rules.  Although cost alone may not justify a waiver, we find it reasonable to consider the costs of 
compliance, as well as the potential value of the data, in evaluating the waiver petition.  Thus, we are not 
convinced that we must disregard AT&T’s assertions about costs.  Nonetheless, our primary focus is 
ensuring that AT&T meets the waiver standards that the Commission set forth in the Rural Call 
Completion Order.  We do not anticipate that granting AT&T a limited waiver of our rules will negatively 
impact our data collections or undermine the objectives of our recordkeeping and retention rules.  As 
detailed below, AT&T will report on a statistically valid set of data for one year and will retain that data 
for three months.
20. In sum, we find that none of the objections raised by the Rural Associations or NARUC 
counsel in favor of denying the waiver when weighed against the countervailing arguments raised by 
AT&T.  As we discuss below, we believe AT&T has met its burden for a waiver because it has 
persuasively demonstrated that: (1) it is likely to qualify for the Safe Harbor upon filing the required 
certifications; (2) it has processes in place to ensure that call attempts to rural ILECs complete 
successfully; and (3) it will have capabilities and processes to monitor its own performance by the OCN 
of the called party’s ILEC upon implementing its planned system modifications.
2. AT&T Waiver Request for Core Network Traffic
21. AT&T seeks, and contends that it meets the requirements for, the waiver described in the 
Order
74
with respect to traffic transported by its Core Network.
75
  AT&T asserts that granting its waiver 
request is consistent with the public interest and warranted for good cause.
76
22. In evaluating AT&T’s waiver request, we consider whether AT&T persuasively 
demonstrated that it meets the criteria set out in the Rural Call Completion Order.  Specifically, we 
consider whether AT&T: (1) qualifies for the Safe Harbor; (2) has processes in place to ensure that call 
attempts to rural ILECs successfully reach their destinations, such as by adopting industry best practices; 
and (3) has capabilities and processes to monitor its own performance by the OCN of the called party’s 
ILEC (rather than just at an aggregate level).
77
  As a condition of the waiver, AT&T must report 
information about rural call completion based on a statistically valid sample of calls for a one-year 
period.
78
  For the reasons set forth below, we find that AT&T has met these criteria.  
                                                     
72
See Rural Call Completion Order, 28 FCC Rcd at 16194-195, paras. 95-97.
73
See id.
74
See Rural Call Completion Order, 28 FCC Rcd at 16195, para. 96.
75
See AT&T Petition at 4.
76
Id.
77
See Rural Call Completion Order, 28 FCC Rcd at 16195, para. 96.  
78
See Rural Call Completion Order, 28 FCC Rcd at 16195, para. 96 (stating that, as a condition of the waiver, the 
Bureau shall require that a provider report information about rural call completion for a one-year period, and that 
such a report may be based on a statistically valid sample of calls).  The Bureau may also require, as a condition of a 
waiver, that a provider collect and retain some data, such as data reflecting a statistically valid sample of calls to 
rural and nonrural areas.  Id.
Federal Communications Commission DA 15-147
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a. Qualification for the Safe Harbor
23. First, we address whether AT&T qualifies for the Safe Harbor.  In order to qualify for the
Safe Harbor, a covered provider must certify on any of the four quarterly filing dates and annually 
thereafter either that: (1) it uses no intermediate providers; or (2) it restricts by contract any intermediate 
provider to which the covered provider directs a call from permitting more than one additional 
intermediate provider in the call path (that is, a total of no more than two intermediate providers in the 
call path) before the call reaches the terminating provider or terminating tandem; any nondisclosure 
agreement with an intermediate provider permits the covered provider to reveal the identity of the 
intermediate provider and any additional intermediate provider to the Commission and to the rural 
ILEC(s) whose incoming long-distance calls are affected by the intermediate provider’s performance; and 
the covered provider has a process in place to monitor the performance of its intermediate providers.
79
  A 
covered provider that files the certification indicating that it does use intermediate providers must 
describe the process it has in place to monitor the performance of its intermediate providers.
80
  
24. AT&T states that it intends to file the section 64.2107 Safe Harbor certification and 
required materials on the first quarterly filing date and annually thereafter.
81
  It reports that it does not 
hand off traffic from the Core Network to any intermediate provider.
82
  AT&T further reports that it has 
internal procedures in place to ensure proper, high-quality routing and signaling.
83
  The record does not 
contain any claim that AT&T does not meet the Safe Harbor standards.  Specifically, NARUC notes that 
“AT&T will meet the [Safe Harbor] requirements if in its certification it includes a description of the 
process it has in place to monitor the performance of its intermediate providers.”
84
25. We find that AT&T has demonstrated in its petition that it is likely to qualify for the Safe 
Harbor.  And we note that because AT&T has not yet filed the required certification, we condition grant 
of this waiver on AT&T’s actual compliance with the Safe Harbor requirements set forth in section 
64.2107(a)(1)-(2) of the Commission’s rules.
85
  
b. Processes to Ensure Successful Rural Call Completion
26. Second, we address whether AT&T “has processes in place to ensure that call attempts to 
rural incumbent LECs successfully reach their destinations, such as by adopting industry best practices.”
86
We find, based on AT&T’s assertions in its petition, that AT&T meets this prong of the waiver criteria.
87
  
AT&T states that it “complies with and has been actively involved in development of call-completion 
                                                     
79
47 C.F.R. § 64.2107(a)(1).
80
47 C.F.R. § 64.2107(a)(2).
81
AT&T Petition at 6.  AT&T states that this certification “will not include AT&T’s newly acquired Cricket affiliate 
until its traffic is migrated onto the AT&T Core Network.”  Id. at 6 n.23, 12.  
82
AT&T Petition at 8.  
83
Id. at 6.
84
NARUC Reply at 7.  
85
47 C.F.R. § 64.2107(a)(1)-(2).  
86
See Rural Call Completion Order, 28 FCC Rcd at 16195, para. 96.
87
See AT&T Petition at 6.  AT&T also asserts that it does not contribute to rural call completion problems and that 
granting its waiver request will not result in the rural call completion problems that the rules were designed to 
prevent.  Id. at 4.  AT&T states that it will continue to actively manage its network and “continue to employ its well-
tested management of intermediate providers and use of industry best practices to ensure quality call completion.”  
Id.
Federal Communications Commission DA 15-147
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best practices through ATIS.”
88
  AT&T reports that it ensures proper, high-quality routing and signaling 
through internal procedures and that it holds itself and its vendors to high standards for handling all 
traffic.
89
  AT&T states that it takes all rural call completion complaints seriously and actively investigates 
each one, internally tracking call completion complaints and conducting voluntary testing in cooperation 
with rural LECs.
90
  AT&T notes that it will continue to monitor performance to ensure no systemic rural 
call completion concerns arise and to quickly resolve any isolated incidents in cooperation with the 
Commission and the relevant rural ILEC.
91
  We find these assertions credible and therefore find that 
AT&T has processes in place to ensure that call attempts to rural incumbent LECs successfully reach their 
destinations and that it meets this prong of the waiver criteria.
c. One Year Reporting Requirement and Monitoring Performance by 
OCN of the Called Party’s ILEC
27. Third, we address whether AT&T “has demonstrated that it has capabilities and processes 
to monitor its own performance by the OCN of the called party’s ILEC (rather than just at an aggregate 
level)” and the requirement that AT&T report information about rural call completion for a one-year 
period.
92
  Pursuant to the waiver process established in the Rural Call Completion Order, a provider must 
report information about rural call completion for a one-year period; such reporting may be based on a 
statistically valid sample of calls.
93
28. To meet the reporting prong of the waiver criteria, AT&T proposes to obtain and report 
on data using systems that it already has in place.  AT&T reports that it already records call attempts, 
including for unanswered calls with cause codes, for a subset of calls on its Core Network.
94
  To meet the 
reporting condition, it has “a comprehensive proposal to retain and report data based on a statistically 
valid sample of inter- and intrastate calls to rural and nonrural areas.”
95
  Specifically, AT&T proposes to 
submit data for one year based on AT&T’s Originating Access Charge Verification (O-ACV) records 
derived from “a random sample of switched access call attempts that originate from non-AT&T LECs.”
96
  
AT&T currently uses this information for verifying originating switched access bills received from non-
AT&T LECs.  AT&T reports that “[b]ecause all calls are routed the same way on the [Core] network 
regardless of how they originate, these records are representative of all traffic, even for types of calls not 
                                                     
88
AT&T Petition at 6. AT&T states that it complies with the call completion best practices in the ATIS Handbook.  
See id. at 6 n.27.  In 2012, the Alliance for Telecommunications Industry Solutions (ATIS) released the Intercarrier 
Call Completion/Call Termination Handbook outlining industry standards and practices relevant to ensuring call 
completion.  See Alliance for Telecommunications Industry Solutions, Intercarrier Call Completion/Call
Termination Handbook (Mar. 2013), https://www.atis.org/docstore/product.aspx?id=26780 (last visited Jan. 8, 2015) 
(ATIS Handbook).  For example, among other things, the ATIS Handbook proposes ways to better manage 
intermediate providers and prohibit looping (not handing the call to the same carrier that sent the call), suggests that 
originating carriers should maintain capacity to complete calls using their own networks, discourages false signaling 
information, recommends that any additional intermediate provider should be bound to the same standards as the 
first, provides recommendations on reporting, and encourages the development of a service provider contact 
directory (which includes IXC carrier-to-carrier contact points).  See generally ATIS Handbook.
89
AT&T Petition at 6.  
90
Id. at 7 n.29. 
91
Id. at 7.
92
See Rural Call Completion Order, 28 FCC Rcd at 16195, para. 96.  
93
Id.
94
See AT&T Petition at 9.  
95
Id. at 7.  
96
Id. at 10.
Federal Communications Commission DA 15-147
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included in the O-ACV records.”
97
  AT&T asserts that these records provide a large, statistically valid 
sample that is broadly representative of all traffic on AT&T’s Core Network.
98
  AT&T asserts that its 
proposed sample, on a representative day, amounts to roughly one-sixth of its interexchange Core 
Network traffic, therefore creating a sample of “tens of millions of records out of the hundreds of millions 
of calls on the AT&T Core Network on a given day.”
99
  AT&T states that, “[u]nder the terms of the Safe 
Harbor, AT&T will report the required data using this sampling method quarterly for one year and will 
retain data for three months.”
100
  AT&T further asserts that these data will provide ample information to 
monitor performance, ensure that no systemic rural call completion concerns occur, and quickly identify 
and resolve any problems that arise.
101
29. We find that these data represent a broad sample of calls and that AT&T’s method of 
reporting will provide the data necessary to meet our stated objectives of ensuring that long-distance calls 
to all Americans are completed and improving the Commission’s ability to monitor the delivery of long-
distance calls to rural areas.
102
  We are convinced that AT&T’s sample is representative of its overall 
traffic because calls included in the sample are subject to the same route choices as all other traffic on the 
network.
103
  We therefore conclude that, conditioned on AT&T developing and implementing a system 
that tracks calls on an ILEC-specific basis, AT&T’s proposed sample is adequate and AT&T has 
demonstrated that it has the “capabilities and processes to monitor its own performance by the OCN of 
the called party’s ILEC.”
104
AT&T will be required to report data for one year and will retain data for 
three months.  
30. NARUC asserts that the O-ACV records do not track calls on an ILEC-by ILEC basis.
105
   
NARUC also questions how AT&T’s procedures and practices ensure call delivery and identify problems 
if AT&T is not able to record and monitor traffic in compliance with the rules adopted in the Rural Call 
Completion Order.
106
  AT&T admits that its systems currently do not permit it to track calls by 
terminating OCN, but states that it will develop the systems necessary to track the calls in the sample on 
an ILEC-by-ILEC basis for rural OCNs and aggregate data for nonrural OCNs.
107
  So long as AT&T 
develops such systems, we find that AT&T will have the capability to monitor its own performance by 
the OCN of the called party’s ILEC.  We condition grant of this waiver on AT&T’s development and 
implementation of the systems needed to track calls on an ILEC-specific basis for rural OCNs and 
aggregate data for nonrural OCNs.  As explained below, AT&T requests, and we grant, a six-month 
waiver to permit AT&T to implement these systems and come into compliance with this prong of the 
waiver criteria.
108
                                                     
97
Id. at 9-10.  Because AT&T has “no business need to verify access records in some cases, O-ACV records are not 
made for calls originating from AT&T Mobility, AT&T LECs, enterprise direct connect customers, and wholesale 
customers.”  Id.at 10.
98
See AT&T Petition at 7, 10.  
99
Id. at 10 n.34.  
100
Id. at 7.
101
See id. at 7, 10.  
102
See Rural Call Completion Order, 28 FCC Rcd at 16155, paras. 1-2.
103
AT&T Petition at 7-9.  
104
Rural Call Completion Order, 28 FCC Rcd at 16195, para. 96.
105
NARUC Reply at 11.
106
Id. at 8-9.
107
See AT&T Petition at 7, 10.  
108
See infra para. 31.
Federal Communications Commission DA 15-147
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31. Implementation Schedule.  AT&T asserts that it will need to make significant system 
changes in order to record, retain, and report data based on the sample described above and to track 
performance on an ILEC-by-ILEC basis using OCNs.
109
  AT&T states that implementation will take six 
months and, requests a six-month waiver from the date that the limited waiver of the recordkeeping, 
retention, and reporting rules is granted to allow for these system changes.
110
  We find that, because 
AT&T does not route Core Network traffic to intermediate providers and has implemented ATIS call 
completion best practices, allowing AT&T additional time to implement these system changes will not 
undermine the objectives of the rules.  Accordingly, we grant AT&T’s request for six months from the 
date of release of this Order to begin complying with the recordkeeping, retention, and reporting rules.
111
3. AT&T Waiver Request for Non-Core Network Traffic
a. AT&T Mobility  
32. In addition to the waiver applicable to its Core Network traffic discussed above, AT&T 
also seeks a waiver of the recordkeeping, retention, and reporting requirements in sections 64.103-
64.2105 of the Commission’s rules for AT&T Mobility inter-MTA traffic that terminates using the small 
set of non-AT&T intermediate providers.
112
33. We consider whether AT&T qualifies for a waiver of these recordkeeping, retention, and 
reporting requirements with regards to this AT&T Mobility inter-MTA traffic.  In order to qualify, AT&T 
must demonstrate that granting the waiver is consistent with the public interest and warranted for good 
cause.
113
34. In support of its request, AT&T asserts that, with respect to its non-Core Network traffic 
that it routes to intermediate providers, it already contractually limits the number of intermediate 
providers in a call path to no more than two.
114
  AT&T further reports that it has internal procedures in 
place to ensure proper, high-quality routing and signaling, including rigorous oversight of non-Core 
Network intermediate providers.
115
  AT&T states that intermediate providers used by AT&T to receive 
non-Core Network traffic must comply with AT&T’s high standards for call termination, including 
limiting the total number of intermediate carriers to two or fewer in a call path and complying with ATIS 
best practices.
116
  Although AT&T would not have a process in place to monitor its performance on an 
ILEC by ILEC basis for this traffic, AT&T reports that this traffic currently is not routed to rural 
OCNs.
117
  Accordingly, AT&T would not be required to record and retain call detail records for the traffic 
                                                     
109
See AT&T Petition at 15.
110
Id. at 15-16.
111
See 47 C.F.R. § 1.3 (stating that the Commission may waive its rules, in whole or in part, for good cause shown).
112
AT&T Petition at 11.  The AT&T Mobility traffic that is routed through the Core Network falls within the scope 
of the Core Network traffic waiver discussed above in Section III.A.2.  AT&T Mobility traffic that is migrated to 
AT&T’s Core Network after release of this Order will fall under the Core Network waiver, as long as that traffic is 
treated as described in the AT&T Petition explanation of the Core Network (i.e. no intermediate providers, all traffic 
treated the same, etc.).
113
See 47 C.F.R. § 1.3.
114
AT&T Petition at 5 n.21, 8, 11 n.35.  
115
Id. at 6.
116
Id. at 11. AT&T reports that, when it uses an intermediate provider, “the contract provides that the intermediate 
provider itself may use no more than one additional intermediate provider, resulting in a total of no more than two 
intermediate providers in any call path.”  Id. at 11 n.35.
117
See id. at 11.  AT&T emphasizes that none of this traffic goes to a rural OCN and that AT&T “would not route 
traffic to a rural OCN through an intermediate provider unless and until it could report call attempt data in 
compliance with the rules (if ever).”  Id.
Federal Communications Commission DA 15-147
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at issue here.
118
  Because these calls are not routed to rural OCNs, AT&T contends that reporting data 
associated with these calls would provide limited meaningful information on AT&T’s performance 
related to calls completing to rural OCNs.
119
  Accordingly, AT&T argues that granting a waiver of the 
recordkeeping, retention, and reporting rules would not undermine the goals of the rules and given the 
relative costs and benefits would be in the public interest.
120
35. As AT&T points out in its waiver request, none of the traffic for which it seeks a waiver 
is terminated to rural OCNs.  A primary goal of collecting this information would be to compare the data 
with that of AT&T Mobility calls to rural OCNs, which in this case will not be carried by intermediate 
providers.
121
As such, and given AT&T’s contractual limitations on its intermediate providers, we grant 
this waiver request for AT&T Mobility’s inter-MTA traffic routed through non-AT&T intermediate 
providers.  This waiver shall remain in effect so long as: (1) no calls subject to this waiver request are 
routed to rural OCNs;
122
(2) AT&T continues to contractually restrict its intermediate providers from 
using more than one additional intermediate provider in a call path before the call reaches the terminating
provider or terminating tandem; and (3) AT&T and its intermediate providers continue to comply with 
ATIS Best Practices.
b. SBC Long Distance
36. We next consider whether SBC Services, Inc. and SBC Communications Inc. (together, 
SBC Long Distance) constitute a “covered provider” for the purposes of our rules. Under the Rural Call 
Completion Order, the recordkeeping, retention, and reporting requirements in sections 64.2103-64.2105 
apply only to “covered” providers of long-distance voice service that make the initial long-distance call 
path choice for more than 100,000 domestic retail subscriber lines, counting the total of all business and 
residential fixed subscriber lines and mobile phones and aggregated over all of the providers’ affiliates.
123
37. AT&T asserts that SBC Long Distance is not a covered provider under the rules.
124
  
AT&T reports that SBC Long Distance maintains a single contract with an intermediate provider for 
resale of long-distance voice services and simply hands off traffic to this intermediate provider without 
making the initial long-distance call path choice.
125
  To the extent that SBC Long Distance traffic is 
migrated onto AT&T’s Core Network, AT&T requests that we include it within the scope of our waiver 
grant of its Core Network traffic.
126
38. Since, as AT&T asserts, SBC Long Distance does not make the initial long-distance call 
path choice for any calls, SBC Long Distance is not presently required to report on its lines pursuant to 
sections 64.2103 and 64.2105 of our rules.
127
  To the extent SBC Long Distance traffic is migrated onto 
                                                     
118
AT&T would, however, be required to report aggregate data for traffic to nonrural OCNs.  See 47 C.F.R. § 
64.2015(b)(2).
119
Id.
120
Id.
121
We note that none of the commenters in this proceeding dispute AT&T’s claim that none of the AT&T Mobility 
inter-MTA traffic for which it seeks a waiver is routed to rural OCNs.
122
The list of rural OCNs can be downloaded from The National Exchange Carrier Association’s website at: 
https://www.neca.org/WorkArea/linkit.aspx?LinkIdentifier=id&ItemID=10171&libID=10191 (last visited Jan. 8, 
2015).  
123
Rural Call Completion Order, 28 FCC Rcd at 16164, para. 19.
124
AT&T Petition at 12-13.
125
Id. at 12-13. 
126
Id. at 13.
127
See 47 C.F.R. §§ 64.2103, 64.2105.  
Federal Communications Commission DA 15-147
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AT&T’s Core Network, we grant AT&T’s request to include such traffic within the scope of our grant 
related to its Core Network, discussed above.
128
  We note, however, that if SBC Long Distance has more 
than 100,000 domestic retail subscriber lines, it must file a letter in WC Docket No. 13-39 explaining that 
it does not make the initial long-distance call path choice for more than 100,000 long-distance voice 
service subscriber lines and identifying the long-distance provider or providers to which it hands off their 
end-user customers’ calls.
129
  We also note that if, at any time, SBC Long Distance begins to make the 
initial call path choice for any calls, it may fall under the reporting obligations contained in sections 
64.2103-64.2105.
c. Cricket  
39. On March 13, 2014, AT&T acquired Leap Wireless, which operates under the Cricket 
brand.
130
  AT&T states that it plans to migrate at least some of Cricket’s traffic to the Core Network and 
proposes that, as the traffic is migrated onto AT&T’s Core Network, the traffic would fall within AT&T’s 
requested waiver for the Core Network traffic.
131
  AT&T states that it will fully comply with the 
recordkeeping, retention, and reporting rules for Cricket traffic that has not been migrated to the Core 
Network when the rules go into effect.
132
  We consider the Cricket traffic that is migrated onto AT&T’s 
Core Network to be part of AT&T’s general waiver request for the Core Network.
133
  And, as such, we 
will apply the waiver we grant for AT&T’s Core Network traffic to this traffic as well.
B. MF Signaling Clarification
40. AT&T and CenturyLink (collectively Petitioners) request a limited waiver of the call 
attempt recordkeeping, retention, and reporting requirements in sections 64.2103-64.2105 of the 
Commission’s rules
134
in those instances where a terminating LEC switch only supports multi-frequency 
signaling (MF signaling).
135
  Petitioners assert that it is technically infeasible to report all call attempt 
categories in accordance with the rules adopted in the Rural Call Completion Order when the terminating 
LEC switch only supports MF signaling.
136
  As noted by Petitioners, the rules seem to create an obligation 
that is technically impossible to comply with in those cases where the terminating LEC switch only 
                                                     
128
See supra paras. 32-35; see also AT&T Petition at 13.  SBC Long Distance traffic that is migrated to AT&T’s 
Core Network after release of this Order will fall under the Core Network waiver, as long as that traffic is treated as 
described in the AT&T Petition explanation of the Core Network (i.e. no intermediate providers, all traffic treated 
the same, etc.).  
129
See Rural Call Completion Order, 28 FCC Rcd at 16185, para. 67.
130
AT&T Petition at 11.  
131
Id. at 11-12.
132
Id. at 12.  
133
Cricket traffic that is migrated to AT&T’s Core Network after release of this Order will fall under the Core 
Network waiver, as long as that traffic is treated as described in the AT&T Petition explanation of the Core Network 
(i.e. no intermediate providers, all traffic treated the same, etc.).  
134
See 47 C.F.R. §§ 64.2103-64.2105.
135
See AT&T Petition at 14-15; CenturyLink Petition at 6; see also Wireline Competition Bureau Seeks Comment
on Petitions for Waiver Filed in the Rural Call Completion Proceeding, WC Docket No. 13-39, Public Notice, 29 
FCC Rcd 4856 (2014); Wireline Competition Bureau Seeks Comment on Petition for Waiver Filed in the Rural Call 
Completion Proceeding, WC Docket No. 13-39, Public Notice, 29 FCC Rcd 9440 (2014). 
136
See AT&T Petition at 14-15; CenturyLink Petition at 9-10; see also Comments of General Communication, Inc. 
(GCI), WC Docket No. 13-39 at 1 (filed Jan. 16, 2014) (GCI Comments); Reply Comments of Alaska 
Communications Systems, WC Docket No. 13-39 at 3 (filed Feb. 18, 2014) (Alaska Communications Systems 
Reply).  We note that the AT&T and CenturyLink petitions are the only petitions formally before the Commission 
on this issue.
Federal Communications Commission DA 15-147
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supports MF signaling.  The Rural Call Completion Order did not provide guidance for how covered 
providers should address such a situation.  This lack of guidance constitutes an ambiguity, which we now 
clarify.
137
41. We clarify that the Commission did not intend to require covered providers to record, 
retain, and report information where the terminating LEC switch only supports MF signaling technology. 
In these instances, it is impossible for the covered provider to obtain all the information required by our 
rules.
138
  Given this clarification, we dismiss as moot AT&T and CenturyLink’s petitions for waiver 
insofar as they request a limited waiver of sections 64.2103-64.2105 of the Commission’s rules in 
instances where a terminating LEC switch only supports MF signaling.
42. When the Commission adopted the Rural Call Completion Order, it imposed on covered 
providers “the requirement to record and retain certain signaling cause code information.”
139
It did not, 
however, impose a requirement on rural ILECs to transmit these cause codes to the covered provider 
responsible for recording and retaining the relevant call detail records. While the Commission noted that 
this cause code information could be captured via Signaling System 7 and Session Initiation Protocol 
signaling,
140
it did not explicitly address MF signaling.
43. MF signaling, which was introduced by the Bell Systems after World War II, is a 
signaling technique using in-band frequencies for communications between network switches with codes 
that include 10 digits and special auxiliary signals.
141
  AT&T states that MF signaling will report “only 
whether a particular call completed or not; additional call detail and cause codes are not available.”
142
  
CenturyLink further asserts that MF signaling information does not provide the data required by sections 
64.2103-64.2105 of the Commission’s rules, because it “does not support the capability to gather all 
elements of Call Attempt Records.”
143
  These arguments are echoed in the filings by both General 
Communication, Inc. (GCI) and Alaska Communications Systems.
144
  GCI explains that for MF signaling, 
“off-hook” signals are only generated if the call is actually answered, and no other signal is generated if 
                                                     
137
See 47 U.S.C. § 154(j) (“The Commission may conduct its proceedings in such manner as will best conduce to 
the proper dispatch of business and to the ends of justice.”).
138
Because we clarify that Petitioners’ requests for waiver were based on an erroneous reading of the Commission’s 
rules, we dismiss their requests for relief regarding MF signaling issues as moot.
139
See Rural Call Completion Order, 28 FCC Rcd at 16175-76, para. 43.
140
Id. at 16176, para. 43 (noting the required retention of data associated with “an SS7 signaling cause code or SIP 
signaling message code associated with each call attempt”).
141
See Harry Newton, Newton’s Telecom Dictionary 618 (23rd ed. 2007); see also Rules and Policies Regarding 
Calling Number Identification Service – Caller ID, CC Docket No. 91-281, Memorandum Opinion and Order on 
Reconsideration, Second Report and Order and Third Notice of Proposed Rulemaking, 10 FCC Rcd 11700, 11704, 
para. 7 n.8 (1995) (Caller ID Order) (“When a switch uses multifrequency signaling to establish a circuit connecting 
it to another switch, it outpulses sequences of tones representing the call set up information on the same circuit that 
is used to connect the calling and called parties.”); GCI Comments at 3 (explaining how MF signaling works).   
142
AT&T Petition at 15.  
143
CenturyLink Petition at 9.
144
See GCI Comments at 1-5; Alaska Communications Systems Reply at 3.  The Commission has also 
acknowledged the technical limitations of MF signaling.  See, e.g., Connect America Fund et al., WC Docket No. 
10-90 et al., Report and Order and Further Notice of Proposed Rulemaking, 26 FCC Rcd 17663, 17895-896, para. 
716 (2011), aff’d sub nom. In re FCC 11-161, 753 F.3d 1015 (10th Cir. 2014).  In the caller ID context, we have 
also acknowledged the limitations of MF signaling compared to Signaling System Seven (SS7), stating “[w]ith 
multifrequency signaling, signaling information capable of identifying the calling party generally was not passed 
beyond the interexchange carrier (IXC), which used the information primarily for billing purposes.  SS7, however, 
makes information identifying the calling party available to the terminating carrier.”  Caller ID Order, 10 FCC Rcd 
at 11705, para. 9. 
Federal Communications Commission DA 15-147
17
the call rings no answer, is busy, rings an invalid number, receives an announcement, or otherwise fails.
145
  
It is therefore technically infeasible, according to AT&T, CenturyLink, GCI, and Alaska Communications 
Systems, to completely comply with our rules when a terminating switch supports MF signaling alone.
146
  
44. No party disputes that when Signaling System 7 (SS7)
147
or Session Initiation Protocol 
(SIP) technology
148
are deployed at the terminating switch, providers are incapable of generating the 
information necessary to comply with our reporting rules.
149
  GCI explains that an unanswered call 
attempted from a covered provider using SS7 signaling to a rural LEC serviced by GCI in Alaska using 
MF signaling is always indicated as “interworking, unspecified” (ISUP release code 127), which means 
the terminating status of the call is unknown.
150
  In other words, when a terminating LEC supports MF 
signaling alone, there is no practicable means to categorize an unanswered call as being busy, ring no 
answer, or to an unassigned number. And, there is no practicable way to modify this shortcoming other 
than for the terminating LEC to replace the switch:
151
an expensive obligation the Commission has not 
imposed in other contexts, nor did it intend to impose it here.
152
45. Although the Commission has no definitive list of the OCNs with switches that still use 
MF signaling, we believe a substantial portion of such OCNs to be in Alaska.
153
  We note that during the 
                                                     
145
See GCI Comments at 4; see also AT&T Petition at 15 (stating that MF signaling “will allow AT&T to report 
only whether a particular call completed or not; additional call detail and cause codes are not available”); Alaska 
Communications Systems Reply at 3 (noting that MF signaling “often provides little information beyond an 
‘answer’ or ‘no answer’ result”).
146
AT&T Petition at 14; CenturyLink Petition at 9-10; GCI Comments at 4; Alaska Communications Systems Reply 
at 3.  
147
SS7 “typically employs a dedicated 64 kilobit data circuit to carry packetized machine language messages about 
each call connected between and among machines of a network to achieve connection control.”  Harry Newton, 
Newton’s Telecom Dictionary 837 (23rd ed. 2007).
148
Session Initiation Protocol (SIP) is “an application-layer control (signaling) protocol for creating, modifying, and 
terminating sessions with one or more participants.  These sessions include Internet telephone calls, multimedia 
distribution, and multimedia conferences.”  Memorandum from J. Rosenberg et al., The Internet Society, on Session 
Initiation Protocol 1 (June 2002), http://www.ietf.org/rfc/rfc3261.txt (last visited Jan. 8, 2015).
149
See GCI Comments at 4 (explaining in detail the difference between MF signaling and SS7 technology). 
150
GCI Comments at 4-5.
151
See, e.g., AT&T Petition at 15 n.49 (noting that any solution “would not be entirely within AT&T’s control 
because it would require the terminating LEC to replace equipment using MF signaling with equipment using SS7 or 
SIP”).  
152
See, e.g., id. at 15 (noting that technical solutions to come into compliance for MF signaling would require costly 
switch upgrades or replacement of legacy equipment (if technically feasible at all)); 47 C.F.R. § 64.1601(a) (limiting 
the types of information that carriers using MF signaling are required to transmit in the Commission’s signaling 
rules).
153
See The Alaska Rural Coalition’s Petition for Limited Waiver, WC Docket Nos. 10-90, 07-135, 05-337, 03-109, 
CC Docket Nos. 01-92, 96-45, GN Docket No. 09-51, WT Docket No. 10-208 at 5 (filed Mar. 23, 2012) (Alaska 
Rural Coalition Petition) (noting that the Alaska Rural Coalition’s member companies all rely on traditional MF 
signaling in many areas of rural and remote Alaska); Alaska Communications Systems Group, Inc. (Alaska 
Communications Systems) Petition for Limited Waiver, WC Docket Nos. 10-90, 07-135, 05-337, 03-109, CC 
Docket Nos. 01-92, 96-45, GN Docket No. 09-51, WT Docket No. 10-208 at 1-4 (filed Mar. 16, 2012) (Alaska 
Communications Systems Petition) (requesting a limited waiver of the Commission’s “phantom traffic” rules 
because its MF signaling trunks are not capable of generating or passing the information required by the rules); GCI 
Petition for Limited Waiver, WC Docket Nos. 10-90, 07-135, 05-337, 03-109, CC Docket Nos. 01-92, 96-45, GN 
Docket No. 09-51, WT Docket No. 10-208 at 2 (filed Feb. 27, 2012) (GCI Petition) (stating that in remote Alaska, 
GCI’s Demand Assigned Multiple Access (DAMA) system relies on MF signaling).
Federal Communications Commission DA 15-147
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period from July 2013 through June 2014, the Commission received no rural call completion complaints 
from rural LEC subscribers in Alaska.  Finally, we note that all covered providers attempting calls to an 
OCN with a switch or switches that use MF signaling should encounter the same signaling conditions 
and, barring intermediate routing differences unrelated to that rural OCN, should exhibit the same 
proximate call answer rate when viewed by the Commission across all providers.   
46. The AT&T and CenturyLink waiver requests indicate there is a lack of clarity about 
whether providers are required to somehow record and retain information that is unavailable from a 
terminating LEC switch that supports only MF signaling. We clarify that providers are not required to 
collect or submit such information. We find that this clarification is consistent with Commission 
precedent and with the objectives of the Commission in the Rural Call Completion Order.
154
Thus, we 
clarify that the Commission did not require covered providers to record, retain, and report on call attempt 
information indicating whether a call attempt was signaled as busy, ring no answer, or unassigned number 
that a covered provider is unable to obtain because the terminating LEC switch supports only MF 
signaling.  However, covered providers will still be required to record, retain, and report information on 
the number of calls attempted and the number of calls answered for all rural OCNs, regardless of 
signaling capabilities.  
IV. ORDERING CLAUSES
47. Accordingly, IT IS ORDERED, pursuant to sections 0.91, 0.291, and 1.3 of the 
Commission’s rules, 47 C.F.R. §§ 0.91, 0.291, and 1.3, and paragraphs 95-97 of the Commission’s Rural 
Call Completion Order, that the Petition for Limited Waiver filed by AT&T Services, Inc. IS GRANTED
to the extent described herein and is otherwise DISMISSED AS MOOT.
48. IT IS FURTHER ORDERED, pursuant to sections 0.91 and 0.291 of the Commission’s 
rules, 47 C.F.R. §§ 0.91, 0.291, and paragraphs 95-97 of the Commission’s Rural Call Completion Order, 
that the Petition for Waiver filed by CenturyLink, Inc. IS DISMISSED AS MOOT.
                                                     
154
See, e.g., Implementation of the Telecommunications Act of 1996; Telecommunications Carriers’ Use of 
Customer Proprietary Network Information and Other Customer Information; Implementation of the Local 
Competition Provisions of the Telecommunications Act of 1996; Provision of Directory Listing Information under 
the Telecommunications Act of 1934, as Amended, CC Docket Nos. 96-115, 96-98, 99-273, Third Report and Order, 
Second Order on Reconsideration, and Notice of Proposed Rulemaking, 14 FCC Rcd 15550, 15626, para. 146
(1999) (clarifying that rebranding of operator or directory assistance services provided was not required where 
technically infeasible); Facilitating the Deployment of Text-to-911 and other Next Generation 911 Applications; 
Framework for Next Generation 911 Deployment, PS Docket Nos. 11-153, 10-255, Order on Reconsideration, 28 
FCC Rcd 14422, 14425, para. 8 (2013) (reconsidering a requirement where “under the current technical standard 
developed for SMS-based texting to 911” it was technically infeasible for a certain bounce-back message to be 
originated).  Requirements imposed on telecommunications relay services have also been routinely waived where 
compliance is technically infeasible.  See, e.g., Telecommunications Relay Services and Speech-to-Speech Services 
for Individuals with Hearing and Speech Disabilities, CG Docket No. 03-123, Order, 22 FCC Rcd 21869 (Consumer 
and Gov’t Affairs Bur. 2007) (waiving certain mandatory minimum standards where compliance was technically 
infeasible); Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and 
Speech Disabilities; E911 Requirements for IP-Enabled Services, CG Docket No. 03-123, WC Docket No. 05-196, 
Memorandum Opinion and Order, 29 FCC Rcd 7971 (Wireline Comp. Bur. & Consumer and Gov’t Affairs Bur. 
2014) (waiving the same standards).
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49. IT IS FURTHER ORDERED, pursuant to section 1.102(b)(1) of the Commission’s rules, 
47 C.F.R. § 1.102(b)(1), that this Order SHALL BE EFFECTIVE upon release.
FEDERAL COMMUNICATIONS COMMISSION
Julie A. Veach
Chief
Wireline Competition Bureau