Federal Communications Commission DA 15-217
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Rural Call Completion
)
)
) WC Docket No. 13-39
DECLARATORY RULING
Adopted:  February 13, 2015 Released: February 13, 2015
By the Chief, Wireline Competition Bureau:
I. INTRODUCTION
1. In October 2013, the Federal Communications Commission (Commission) adopted the 
Rural Call Completion Order, which requires telephone service providers to record, retain, and report 
certain data related to call completion.
1
  In this Declaratory Ruling, the Wireline Competition Bureau 
(Bureau) provides additional guidance regarding how providers must record, retain, and report the 
requisite information.
2
  Specifically, we clarify that covered providers must abide by the definitions of 
call attempt categories specified in the text of the Rural Call Completion Order.
3
  As set forth below, we 
find that the text of the Order and the language in Appendix C appended thereto can and should be read in 
a consistent manner.  Indeed, to read the Order and Appendix C as inconsistent requires an overly narrow 
construction of Appendix C that is at odds with the text of the Order as well as the Commission’s 
underlying goals. More specifically, to the extent that some parties contend that Appendix C permits
covered providers to count certain unanswered call attempts as answered calls for purposes of the new 
rules, we reject those contentions.  The Declaratory Ruling we adopt today will provide clarity and
effectuate the Commission’s intent in adopting the rural call completion rules.
II. BACKGROUND
2. Rural Call Completion Order.  In the Order, the Commission adopted rules to address 
significant concerns about the completion of long-distance call attempts to rural areas, including new 
reporting requirements.
4
  These rules require covered providers to record, retain, and report certain 
information about whether call attempts are “answered,” or signaled as “busy,” “ring no answer,” or 
                                                     
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).
2
See 47 C.F.R. §§ 64.2103, 64.2105; see also 5 U.S.C. § 554(e) (“The agency, with like effect as in the case of other 
orders and in its sound discretion, may issue a declaratory order to terminate a controversy or remove uncertainty.”);  
47 C.F.R. § 1.2 (“The Commission may, in accordance with section 5(d) of the Administrative Procedure Act, on 
motion or on its own motion issue a declaratory ruling terminating a controversy or removing uncertainty.”).  The 
Rural Call Completion Order directs that “[b]efore any reports are due, the Wireline Competition Bureau will 
release a public notice that explains the filing mechanism in detail.  Bureau staff will work with providers to ensure 
that the providers have the tools they need to complete and file the form in the least burdensome manner possible.”  
Rural Call Completion Order, 28 FCC Rcd at 16184, para. 66.
3
See Rural Call Completion Order, 28 FCC Rcd at 16174-76, 16184-88, paras. 42-43, 65-73.
4
See id. at 16155, para. 1.
Federal Communications Commission DA 15-217
2
“unassigned number.”
5
Covered providers must report information individually for each rural operating 
company number (“OCN”) and in the aggregate for nonrural OCNs.
6
The Rural Call Completion Order 
defined each category of call attempt as follows:
“Answered.”  The Rural Call Completion Order defined an “answered call” as “a call 
that was answered by or on behalf of the called party (including calls completed to 
devices, services or parties that answer the call such as an interactive voice response, 
answering service, voicemail, or call-forwarding system), causing the network to register 
that the terminating party is prepared to receive information from the calling user.”
7
  
“Ring No Answer.”  In the Rural Call Completion Order, the Commission noted that, if a 
call attempt is not answered, a “User” category cause value such as “‘no user responding’ 
(cause value 18) is returned.”
8
    
“Busy.”  The Rural Call Completion Order noted that the SIP cause code for a busy 
signal is 486 and that the SS7 cause code for a busy signal is cause value 17.
9
  It also 
stated “that user busy signaling may in reality reflect network problems.”
10
  
“Unassigned Number.”  The Rural Call Completion Order stated that, “[f]or purposes of 
this Order, an unassigned number is one for which a call cannot be completed because it 
is not assigned to an end user.”
11
  The Commission also noted that one “commonly 
occurring ‘User’ cause is ‘unallocated (unassigned) number’ (cause value 1), which 
indicates that the caller has dialed a properly formatted telephone number, but that 
number itself is not assigned to an end user.”
12
  
Appendix C to the Order provided a reporting template for covered providers to use when filing the 
required call completion data with the Commission each quarter.
13
  The legend accompanying this 
reporting template identified specific Integrated Services Digital Network User Part (ISUP) Cause values 
and corresponding Session Initiation Protocol (SIP) Response messages for each category of call attempt 
                                                     
5
47 C.F.R. §§ 64.2103(e)(8)-(9), 64.2105(b); Rural Call Completion Order, 28 FCC Rcd at 16174-77, 16184-87, 
paras. 40-46, 65, 68-72; see also Rural Call Completion, WC Docket No. 13-39, Order on Reconsideration, 29 FCC 
Rcd 14026 (2014) (Rural Call Completion Recon Order) (providing exemption for narrow category of intraLATA 
call attempts).
6
Rural Call Completion Order, 28 FCC Rcd at 16184-87, paras. 65, 68-72. 
7
Id. at 16187, para. 72.  The Commission emphasized that “the call answer rate is the data point least susceptible to 
variations in data reporting or to differences in the quality or accuracy of signaling:  the called party either answered 
the call or did not answer the call.”  Id. at 16186, para. 71.  
8
Id. at 16175, para. 43, n.120 (emphasis added).
9
Id. at 16175, 16187, para. 43 n.120, para. 71 n.195.  
10
Id. at 16176, para. 43.
11
Id. at 16185, para. 68 n.186.  
12
Id. at 16175, para. 43 n.120 (emphasis added).  
13
Id. at 16218, Appx. C.  The electronic spreadsheet will be provided by the Commission.  
Federal Communications Commission DA 15-217
3
that must be reported.
14
  In particular, Appendix C states, “Answered = calls signaled back with ISUP 16 
& 31 and SIP BYE & CANCEL.”
15
3. Public Notice.  Following release of the Rural Call Completion Order, Level 3 and 
Verizon raised concerns that release cause code 16 is also used to indicate that the calling party hung up 
before the called party answered, i.e., when the call attempt was not answered.  They assert that counting 
such unanswered call attempts as “answered” calls would result in much higher call answer rates.
16
  In 
response, the Bureau released a Public Notice on April 21, 2014,
17
seeking comment on “whether to 
modify or otherwise provide assistance regarding [the] criteria described in Appendix C of the Rural Call
Completion Order for categorizing certain types of call attempts.”
18
  The Bureau received comments from
Alliance for Telecommunications Industry Solutions (ATIS), CenturyLink, COMPTEL, Level 3, the 
National Cable & Telecommunications Association (NCTA), Verizon and Verizon Wireless (Verizon), 
the Voice Communication Exchange Committee (VCXC), XO Communications, LLC (XO), and 
ZipDX.
19
  
III. DISCUSSION
A. Covered Providers May Not Count Unanswered Call Attempts As Answered Calls
4. The Rural Call Completion Order made clear that the Commission did not intend to 
permit covered providers to count unanswered call attempts as answered calls.  The Order defined an 
“answered call” as “a call that was answered by or on behalf of the called party . . . causing the network to 
                                                     
14
ISUP and SIP release cause codes are used within the network to identify the outcome of a given call attempt.  See 
Harry Newton, Newton’s Telecom Dictionary 648, 1051 (26th ed. 2011).
15
Rural Call Completion Order, 28 FCC Rcd at 16218, Appx. C. Note that the Commission’s example of 
“Answered” in the Appendix C legend referred to a “call” whereas the examples of the unanswered subcategories all 
refer to “call attempts.” The Commission has also made it clear that the call attempt has to be first answered by the 
called party for a release code of 16 or 31 to indicate that the call was an answered call.  See Rural Call Completion, 
WC Docket No. 13-39, Notice of Proposed Rulemaking, 28 FCC Rcd 1569, 1578, para. 29 n.54 (2013) (“For 
example, when a call attempt is answered by the called party, the terminating provider typically sends one of the 
‘Call Completed’ category cause values, such as ‘normal call clearing’ (cause value 16) or ‘normal, unspecified’
(cause value 31) when one of the parties terminates the conversation by hanging up.”).   
16
See Letter from Maggie McCready, Vice President, Federal Regulatory Affairs, Verizon, to Marlene H. Dortch, 
Secretary, FCC, WC Docket No. 13-39 (filed Mar. 24, 2014) (Verizon Mar. 24, 2014 Ex Parte); Letter from Joseph 
C. Cavender, Vice President, Federal Affairs, Level 3, to Marlene H. Dortch, Secretary, FCC, WC Docket No. 13-39 
(filed Jan. 29, 2014) (Level 3 Jan. 29, 2014 Ex Parte).
17
See Wireline Competition Bureau Seeks Comment on Whether to Clarify Appendix C of the Rural Call Completion 
Order, WC Docket No. 13-39, Public Notice, 29 FCC Rcd 3927 (Wireline Comp. Bur. 2014) (Clarification PN).
18
Id. at 3928.
19
See ATIS Comments, WC Docket No. 13-39 (filed May 27, 2014) (ATIS Comments); CenturyLink Comments, 
WC Docket No. 13-39, at 1-3 (filed May 13, 2014) (CenturyLink Comments); COMPTEL Comments, WC Docket 
No. 13-39, at 3-5 (filed May 13, 2014) (COMPTEL Comments); Level 3 Comments, WC Docket No. 13-39 (filed 
May 13, 2014) (Level 3 Comments); National Cable & Telecommunications Association (NCTA) Comments, WC 
Docket No. 13-39, at 2 (filed May 13, 2014) (NCTA Comments); Verizon Comments, WC Docket No. 13-39 (filed 
May 13, 2014) (Verizon Comments); Voice Communication Exchange Committee (VCXC) Comments, WC Docket 
No. 13-39 (filed May 13, 2014) (VCXC Comments); XO Comments, WC Docket No. 13-39 (filed May 14, 2014) 
(XO Comments); ZipDX Comments, WC Docket No. 13-39 (filed Apr. 28, 2014) (ZipDX Comments).  Although 
the ATIS Comments and XO Comments were filed after the comment due date of May 13, 2014, we consider and 
respond to these comments in this Declaratory Ruling.
Federal Communications Commission DA 15-217
4
register that the terminating party is prepared to receive information from the calling user.”
20
That 
definition is not met when a calling party hangs up before the called party answers the call.  Nothing in 
Appendix C contradicts that intent.  
5. Appendix C was developed to provide a format for certain data reporting; it does not 
create, modify or narrow terms already discussed in detail in the Order.
21
  Moreover, we find that the 
legend to Appendix C must be viewed in light of the Rural Call Completion Order as a whole.  Some 
parties suggest that the legend to Appendix C, viewed in isolation, could be read to permit covered 
providers to count call attempts as “answered” as long as the network generates SIP cause code 16, even 
if the calling party hangs up before the call is answered.  We disagree.  That reading is inconsistent with 
the language of the Order and ignores the fact that Appendix C provides a filing “template.”
22
We 
therefore clarify that covered providers may count as answered calls only call attempts that meet the 
definition of “answered calls” in the Order.  If the calling party hangs up before a call attempt is 
answered, covered providers may not count that call attempt as an answered call even if it generates cause 
code 16.   
6. We also find that the Commission intended the cause codes referenced in the legend to 
Appendix C to be used as examples, rather than exhaustive definitions, of possible ways for providers to 
identify the different categories of call attempts required by the Order.
23
  We reject arguments that the 
legend to Appendix C is inconsistent with or overrides the language of the Order.
24
  Nothing in the Order
suggests such a reading, and, to the contrary, Appendix C readily lends itself to an interpretation that is 
consistent with the Order.  For instance, Appendix C states that call attempts are “generally” — not 
exclusively — categorized by the cause codes identified in the legend.
25
  The Order explained that an 
indication of whether a call attempt is signaled as “busy, ring no answer, or unassigned number” is “likely
to take the form of an SS7 signaling cause code or SIP signaling message code,” but the Order declined 
to fully specify the relevant cause codes.
26
  Similarly, the Order merely identifies several cause codes that 
may indicate that a call is “busy;” it does not state that these codes are the exclusive identifiers of “busy” 
call attempts.
27
  
7. Perhaps most significantly, the Commission stated in the Order that its intent is to collect 
the required data “while accommodating differences in the specific cause codes or other data that 
providers may have, to give them flexibility to report such data based on their own network 
configurations,” and “to accommodate differences in signaling technology.”
28
  Prescribing a rigid menu of 
specific codes that must always be used, regardless of circumstance, would be contrary to this specified 
                                                     
20
Rural Call Completion Order, 28 FCC Rcd. at 16187, para. 72.    
21
Rural Call Completion Order, 28 FCC Rcd at 16184, para. 66.
22
Id.
23
Rural Call Completion Order, 28 FCC Rcd at 16184, para. 66.
24
See, e.g., NCTA Comments at 2 (suggesting that calls should be reported as “answered” only if they meet criteria 
in the Appendix C legend and they are identified as answered); Verizon Comments at 1 (arguing that, as to 
“answered” call attempts, the Commission should retain the “release cause code” methodology in Appendix C).
25
See Rural Call Completion Order, 28 FCC Rcd at 16218, Appx. C.  
26
Id. at 16176, para. 43 (emphasis added).  For example, while the Order contemplates that one “commonly 
occurring ‘User’ cause is ‘unallocated (unassigned) number’ (cause value 1),” it does not suggest that this is the only 
cause code that might comport with the definition given therein.  Id. at 16175, para. 43 n.120. 
27
Id. at 16176, para. 43.  
28
Id. at 16187, para. 71 n.195.
Federal Communications Commission DA 15-217
5
intent.  The rules adopted in the Rural Call Completion Order that address recordkeeping and retention 
state that an “indication [of whether the call attempt was signaled busy, ring no answer, or unassigned 
number] may take the form of an SS7 signaling cause code or SIP signaling message code associated with 
each call attempt,” without specifying any particular codes.
29
  
8. Several commenters argue that categorizing “answered,” “busy,” “ring no answer,” and 
“unassigned number” call attempts consistent with the ISUP Cause values and corresponding SIP 
Response messages identified in the Appendix C legend will result in confusion and the submission of 
inaccurate data.
30
  We reject these claims because the Appendix C call attempt category descriptions 
merely serve as examples; they may not fully capture every call attempt category completely, and they 
may not be appropriate in all cases.  Since the Appendix C codes are merely examples, providers must 
determine whether they are appropriate for use in each case.  For similar reasons, we find no reason to 
adopt commenter suggestions to eliminate the specific ISUP cause codes included in the Appendix C
legend.
31
  Deleting the cause codes listed in Appendix C would not alter the definitions in the Order that 
covered providers must follow, and therefore there is nothing significant to be gained through their 
elimination.    
9. We also do not think it necessary to specify alternative codes or other call attempt 
categorization methods
32
and/or solicit further comment on the code definitions.
33
  Any undertaking to 
identify specific cause codes as the exclusive methods of categorizing call attempts will necessarily 
supersede the level of specificity in the Order and therefore conflict with the Order’s text and intent to 
provide flexibility.
34
  Indeed, the variations in the approaches proposed demonstrate that providers’ 
systems categorize call attempts differently.  Providers should rely on the definitions in the Rural Call 
Completion Order, and they may consider the codes specified in the Appendix C legend as relevant 
examples.  Because the Rural Call Completion Order does not precisely define certain call attempt 
categories, it permits some flexibility so long as the approach that providers adopt is consistent with the
language and goals in the Order.  
10. We disagree with commenters that argue that declining to specify mandatory codes 
heightens the chances for reporting inaccurate and/or misleading data.
35
  Allowing providers to identify 
                                                     
29
47 C.F.R. § 64.2103(e)(9); see also 47 C.F.R. § 64.2103(e)(8) (“[A]n indication of whether the call attempt was 
answered . . . may take the form of an SS7 signaling cause code or SIP signaling message code associated with each 
call attempt.”).
30
See, e.g., CenturyLink Comments at 2-3, COMPTEL Comments at 1-4; Level 3 Comments at 2-3; NCTA 
Comments at 1; XO Comments at 2-4; Verizon March 24, 2014 Ex Parte at 1.
31
See, e.g., COMPTEL Comments at 5-6; XO Comments at 2.
32
See, e.g., CenturyLink Comments at 2-3 (stating that the best means to categorize a call as an “answered call” is to 
investigate into the calls via the Call Detail Record (CDR) for the indicator of conversation time which aligns with 
how billing to customers is determined); NCTA Comments at 2 (asserting that when call detail records indicate that 
calls with ISUP 16 and 31 and SIP BYE and CANCEL codes are unanswered, they should be reported as “ring no 
answer” calls).
33
See, e.g., COMPTEL Comments at 5-6; Verizon Comments at 4; XO Comments at 2; see also ATIS Comments at 
2 (stating that there is “substantial evidence on the record that the Commission’s focus on reporting of call answer 
rates is misplaced and that call answer rates—however they are determined—will not reliably identify rural OCNs 
with call delivery issues”).  
34
Such arguments would have been more appropriately raised in a petition for reconsideration of the Rural Call 
Completion Order.  The Bureau does not have the authority to revisit the Commission’s decision.
35
See, e.g., XO Comments at 5-7.  
Federal Communications Commission DA 15-217
6
categories of call attempts in the way that comports best with their existing methods of tracking, 
recording, and billing (so long as doing so is consistent with the Order) will produce more accurate data.  
Provider descriptions of the methodologies used to identify call attempt categories will help to ensure that 
the Bureau is able to interpret the reported data accurately.  Providers therefore should make clear the 
method used to identify these call attempt categories in their quarterly reports.
36
  
B. Additional Commenter Requests
11. Additional Time.  Verizon requests additional time if we “modify what constitutes an 
answered call or require the reporting of additional data.”
37
  Similarly, COMPTEL and XO assert that the 
Commission should delay the effective date of the recordkeeping, retention, and reporting rules pending 
the issuance of clarifying instructions.
38
  Because we do not alter the data collection requirement by the 
Order or provide clarifying instructions, we conclude there is no reason to grant additional time.  Further,
our clarification in this Declaratory Ruling that covered providers have significant flexibility should 
obviate the need for extra time.
39
12. Estimate Severity of Rural Call Completion Problems.  VCXC recommends that before 
proceeding, the Commission should estimate the percentage of total calls reflecting rural call completion 
problems, the error rate for respondent call completion data, and the percentage of calls in the 
indeterminate category.
40
  VCXC further recommends that the Commission define the “confidence 
interval serving as the target for data reliability.”
41
  VCXC asserts that “[t]he exercise fails as a basis for 
FCC actions unless the error rate and the [indeterminate] category remain a small fraction of the 
problematic calls serving as the purpose for the data collection.”
42
13. We decline to undertake the calculations requested by VCXC.  To the extent that VCXC 
is seeking reconsideration of the Order, such a request is untimely.
43
Further, the Commission has a 
                                                     
36
Under 47 C.F.R. § 64.2105(a), covered providers are required to submit to the Commission quarterly reports 
containing the recording and retention data required by the rules adopted in the Rural Call Completion Order.  See 
47 C.F.R. §§ 64.2103, 64.2105; Rural Call Completion Order, 28 FCC Rcd at 16211-214, Appx. A.  Before any 
reports are due, the Bureau will release a public notice that explains the filing mechanism in detail. The effective 
date of the information collections in these rules will be announced in the Federal Register, and covered providers 
must begin recording the data included in the reports they file with the Commission on the first day of the calendar 
month that is at least 20 days after the effective date.  See Rural Call Completion Order, 28 FCC Rcd at 16184, para. 
66.
37
See Verizon Comments at 6.  
38
See COMPTEL Comments at 5; XO Comments at 2, 5.
39
We note that the data retention and reporting obligations adopted in the Rural Call Completion Order and 
modified in the Rural Call Completion Recon Order will not become effective until an announcement is published 
in the Federal Register of the Office of Management and Budget (OMB) providing approval.  See Rural Call 
Completion Recon Order, 29 FCC Rcd at 14044-45, para. 44.  OMB granted its approval on January 29, 2015.  See 
OMB Control Number History, OMB Control Number 3060-1186, 
http://www.reginfo.gov/public/do/PRAOMBHistory?ombControlNumber=3060-1186.  
40
VCXC Comments at 1.
41
Id. at 1.  VCXC states further that the anecdotes motivating the data collection suggest a problem with less than 
1% of calls, while a review of comments suggests that coding is uncertain for at least 20% of calls.  Id.  We note that 
VCXC provides no basis for asserting that coding is uncertain for 20% of calls.
42
Id. at 1.
43
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.  47 C.F.R. § 1.429(d).  VCXC’s comments in this proceeding were filed on May 
(continued….)
Federal Communications Commission DA 15-217
7
sufficient record of “frequent and pervasive” rural call completion problems
44
to justify its rules to 
address rural call completion issues, including the adoption of this Declaratory Ruling. The Commission, 
moreover, cannot determine the accuracy of respondent call completion data until such data are obtained 
and analyzed, as provided in the recordkeeping and retention rules adopted in the Rural Call Completion 
Order.  To the extent that VCXC is asserting that we must define call completion categories more 
precisely and prescriptively, we disagree.  Consistent with the Rural Call Completion Order, we 
anticipate that a certain degree of flexibility in reporting methodology is needed to ensure that we receive 
data that accurately accounts for differences in provider systems and technology.  
14. Additional Categories.  ZipDX argues that the reporting template should also include a 
column for “network failure,” noting that circumstances such as “all circuits busy” still occur and are 
distinct from “user busy.”
45
  ZipDX also asserts that there should be a column for “call was unanswered 
and we don’t know what happened.”
46
  ZipDX further argues that the data collection mandated in the 
Rural Call Completion Order will prove mostly ineffective and wasteful.
47
  Finally, ZipDX states that 
rural citizens and their providers “would be better served if the resources were invested in developing 
efficient, near-real-time methods and systems for quickly investigating and resolving call–completion 
problems on a case-by-case basis as they are reported.”
48
  These arguments are beyond the scope of this 
Declaratory Ruling and would require Commission reconsideration of its actions in the Rural Call 
Completion Order.
49
  Further, the actions taken in the Rural Call Completion Order were designed to 
enable the Commission to work with providers to address and resolve call completion problems, by 
ensuring that providers record, retain, and report information critical for that purpose.
50
  
IV. CONCLUSION
15. In sum, consistent with the Commission’s stated intent in the Order, we clarify that 
covered providers may not count unanswered call attempts as answered calls under the Commission’s 
data retention and reporting rules.  We clarify that the explanatory notes in Appendix C describing 
“answered” calls and “busy,” “ring no answer,” and “unassigned number” call attempts are intended to 
serve as examples rather than exclusive definitions.  We reiterate that providers should, as part of their 
quarterly reports to the Commission required under 47 C.F.R. § 64.2105, explain the method they used to 
identify these call attempt categories.
(Continued from previous page)                                                            
13, 2014, one hundred forty-seven days after the Rural Call Completion Order was published in the Federal Register 
on December 17, 2013.  See VCXC Comments at 1; FCC, Rural Call Completion, 78 Fed. Reg. 76218 (Dec. 17, 
2013), http://www.gpo.gov/fdsys/pkg/FR-2013-12-17/xml/FR-2013-12-17.xml#seqnum76218.
44
Rural Call Completion Order, 28 FCC Rcd at 16160-162, 16215-217, para. 13; see also id. at paras. 1-15, Appx. 
A.
45
ZipDX Comments at 4.  
46
Id.  
47
Id.  
48
Id.
49
ZipDX did not file a timely petition for reconsideration of the Commission’s Rural Call Completion Order.  
ZipDX’s comments were filed on April 28, 2014, one hundred thirty-two days after the Rural Call Completion 
Order was published in the Federal Register on December 17, 2013.  See ZipDX Comments at 1.
50
See Rural Call Completion Order, 28 FCC at 16174, 16184-185, paras. 40, 66-67.
Federal Communications Commission DA 15-217
8
V. ORDERING CLAUSES
16. Accordingly, IT IS ORDERED, pursuant to sections 1-5 and 201(b) of the 
Communications Act of 1934, as amended, 47 U.S.C. §§ 151-155, 201(b), and sections 0.91, 0.291, and 
1.2 of the Commission’s rules, 47 C.F.R. §§ 0.91, 0.291, and 1.2, that this Declaratory Ruling in WC 
Docket No. 13-39 IS ADOPTED.
17. IT IS FURTHER ORDERED that pursuant to section 1.102(b) of the Commission’s 
rules, 47 C.F.R. § 1.102(b), this Declaratory Ruling SHALL BE EFFECTIVE upon release.
FEDERAL COMMUNICATIONS COMMISSION
Julie A. Veach
Chief
Wireline Competition Bureau