Federal Communications Commission DA 15-74
Before the
Federal Communications Commission
Washington, DC 20554
In the Matter of
Verizon
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)
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)
)
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File No.:  EB-IHD-14-00014821
Acct. No.:  201532080007
FRN:  0004335592
ADOPTING ORDER
Adopted:  January 26, 2015 Released:  January 26, 2015
By the Chief, Enforcement Bureau:
1. The Enforcement Bureau (Bureau) of the Federal Communications Commission has 
entered into a Consent Decree to resolve its investigation into Verizon’s failure to investigate evidence it 
collected over an eight-month period that reflected potential problems with its delivery of calls to rural 
areas of the country.  Rural call completion problems have significant and immediate public interest 
ramifications.  They cause rural businesses to lose customers, impede medical professionals from 
reaching patients in rural areas, cut families off from their relatives, and create the potential for dangerous 
delays in public safety communications. To settle this matter, Verizon admits that it failed to investigate 
the cause of low call answer rates in 26 rural areas, and will pay a $2,000,000 fine.  Prospectively, 
Verizon also will implement a compliance plan in which it will spend an additional $3,000,000 on 
measures to advance and achieve Company and industry solutions to rural call completion problems.
2. After reviewing the terms of the Consent Decree and evaluating the facts before us, we 
find that the public interest would be served by adopting the Consent Decree and terminating the 
referenced investigation
1
regarding Verizon’s compliance with Sections 201(b) and 202(a) of the 
Communications Act of 1934, as amended
2
with respect to its investigation of its call completion to rural 
areas.
3. In the absence of material new evidence relating to this matter, we conclude that our 
investigation raises no substantial or material questions of fact as to whether Verizon possesses the basic 
qualifications, including those related to character, to hold or obtain any Commission license or 
authorization.
4. Accordingly, IT IS ORDERED that, pursuant to Section 4(i) of the Act
3
and the 
authority delegated by Sections 0.111 and 0.311 of the Rules,
4
the attached Consent Decree IS 
ADOPTED and its terms incorporated by reference.
5. IT IS FURTHER ORDERED that the above-captioned matter IS TERMINATED.
                                                     
1
This investigation was initiated under File No. EB-IHD-13-00011647 and subsequently assigned File No. EB-
IHD-14-00014821.
2
47 U.S.C. §§ 201(b), 202(a); see also Developing an Unified Intercarrier Compensation Regime, Declaratory 
Ruling, 27 FCC Rcd 1351 (Wireline Comp. Bur. 2012).
3
47 U.S.C. § 154(i).
4
47 C.F.R §§ 0.111, 0.311.
Federal Communications Commission DA 15-74
2
6. IT IS FURTHER ORDERED that a copy of this Order and Consent Decree shall be 
sent by first class mail and certified mail, return receipt requested, to Tamara Preiss, Vice President, 
Federal Regulatory Affairs, Verizon, 1300 I Street, NW, Suite 400 West, Washington, DC 20005.
FEDERAL COMMUNICATIONS COMMISSION
Travis LeBlanc
Chief 
Enforcement Bureau
Federal Communications Commission DA 15-74
Before the
Federal Communications Commission
Washington, DC 20554
In the Matter of
Verizon   
)
)
)
)
)
)
)
File No.:  EB-IHD-14-00014821
1
Acct. No.:  201532080007
FRN:  0004335592
CONSENT DECREE
1. The Enforcement Bureau of the Federal Communications Commission and Verizon, by their 
authorized representatives, hereby enter into this Consent Decree to resolve and terminate the 
Enforcement Bureau’s investigation into whether Verizon violated Sections 201(b) and 202(a) of the 
Communications Act of 1934, as amended (Act),
2
in connection with evidence collected over an eight-
month period that reflected potentially substandard delivery of long distance calls to certain rural areas.
I. DEFINITIONS
2. For the purposes of this Consent Decree, the following definitions
3
shall apply:
(a) “Act” means the Communications Act of 1934, as amended.
4
(b) “Adopting Order” means an order of the Commission or the Bureau adopting the 
terms of this Consent Decree without change, addition, deletion, or modification.
(c) “Answered Call” means a call that receives an answer message and a normal release 
cause code (e.g., a release cause code of 16 or 31 for calls signaled with SS7 or the 
corresponding normal release codes for calls signaled with session initiation 
protocol (SIP)).
(d) “Attempted Call” means a call that results in transmission by Verizon toward an 
incumbent rural local exchange carrier of the initial call setup message, regardless of 
the voice call signaling and transmission technology used.
(e) “Aggregate Rural Answer Rate” means the Call Answer Rate for calls to all Rural 
OCNs.
(f) “Bureau” means the Enforcement Bureau of the Federal Communications 
Commission.
(g) “Call Answer Rate” means a rate calculated by dividing (1) total Answered Calls by 
                                                     
1
This investigation was initiated under File No. EB-IHD-13-00011647 and subsequently assigned File No. EB-
IHD-14-00014821.
2
See 47 U.S.C. §§ 201(b), 202(a); see also Developing an Unified Intercarrier Compensation Regime, Declaratory 
Ruling, 27 FCC Rcd 1351 (Wireline Comp. Bur. 2012) (Rural Call Completion Declaratory Ruling).
3
The definitions herein are only for purposes of this Consent Decree and do not affect any definitions in any other 
Commission order or proceeding, including other matters dealing with rural call completion.  As an example, the 
definition of “answered call” in this Consent Decree has no effect on and does not alter the definition of “answered 
call” in the Rural Call Completion Order.
4
47 U.S.C. § 151 et seq.
Federal Communications Commission DA 15-74
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(2) total Attempted Calls minus Attempted Calls to unassigned numbers as indicated 
by the release cause code (e.g., a release cause code of 1 for calls signaled with SS7 
or the corresponding release cause code for calls signaled with session initiation 
protocol).
(h) “Commission” and “FCC” mean the Federal Communications Commission and all 
of its bureaus and offices.
(i) “Communications Laws” means collectively, the Act, the Rules, and the published 
and promulgated orders and decisions of the Commission to which Verizon is 
subject by virtue of its business activities.
(j) “Compliance Plan” means the compliance obligations, program, and procedures
described in this Consent Decree at paragraph 18.
(k) “Covered Employees” means all employees and agents of Verizon Business who 
perform, or supervise, oversee, or manage the performance of, duties directly related
to Verizon’s responsibilities under the Rural Call Completion Rules, including
Sections 201(b) and 202(a) of the Act, as interpreted in the Rural Call Completion 
Declaratory Ruling.
(l) “Effective Date” means the date by which both the Bureau and Verizon have signed 
the Consent Decree.
(m) “Intermediate Provider” has the meaning provided in Section 64.1600(f) of the 
Rules,
5
but excludes a tandem provider to which the terminating carrier subtends or 
a carrier to which the terminating carrier requires an indirectly interconnecting 
carrier to deliver traffic.
(n) “Investigation” means the investigation commenced by the Bureau under File No. 
EB-IHD-13-00011647 regarding whether Verizon violated Sections 201(b) and 
202(a) of the Act.
(o) “LOI” means the Letter of Inquiry issued by the Bureau to Verizon on February 3, 
2014.
(p) “Negative Spike” means a sharp, material decrease from prior measurements over a 
short interval.
(q) “OCN” means an Operating Company Number that is an alphanumeric code that 
uniquely identifies providers of local telecommunications service.
6
  
(r) “Operating Procedures” means the standard internal operating procedures and 
compliance policies established by Verizon to implement the Compliance Plan.
(s) “Parties” means Verizon and the Bureau, each of which is a “Party.”
(t) “Rules” means the Commission’s regulations found in Title 47 of the Code of 
Federal Regulations.
(u) “Rural Call Completion Declaratory Ruling” means the declaratory ruling captioned 
as Developing an Unified Intercarrier Compensation Regime, Declaratory Ruling, 
27 FCC Rcd 1351 (Wireline Comp. Bur. 2012). “Rural Call Completion Order”
means the order captioned as Rural Call Completion, Report and Order and Further 
Notice of Proposed Rulemaking, 28 FCC Rcd 16154 (2013), modified in part on 
                                                     
5
47 C.F.R. § 64.1600(f).
6
See Alliance for Telecommunications Industry Solutions, ATIS Telecom Glossary, available at
http://www.atis.org/glossary/definition.aspx?id=8448 (last accessed Dec. 22, 2014).
Federal Communications Commission DA 15-74
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recon., Order on Reconsideration, FCC 14-175, 2014 WL 6070709 (rel. Nov. 13, 
2014). 
(v) “Rural Call Completion Rules” means Sections 201(b) and 202(a) of the Act, as 
interpreted in the Rural Call Completion Declaratory Ruling, and the rules adopted 
in the Rural Call Completion Order, 47 C.F.R. Sections 64.2101, 64.2103, 64.2105, 
64.2107, 64.2109 and 64.2201, and other provisions of the Act, the Rules, and 
Commission orders related to Rural Call Completion.  
(w) “Rural OCN” means an OCN that is designated as rural on the annually updated list 
published by the National Exchange Carrier Association (NECA), as described in 
the Rural Call Completion Order, 28 FCC Rcd at 16187, para. 73.
(x) “Verizon” or “Company” means MCI Communications Services, Inc. d/b/a Verizon 
Business Services (“Verizon Business”).  
(y) “Verizon and its regulated affiliates” means the regulated wholly owned subsidiaries 
of Verizon Communications Inc., including but not limited to Verizon Business, 
Cellco Partnership d/b/a Verizon Wireless (“Verizon Wireless”), and all affiliated
incumbent local exchange carriers (“Verizon ILECs”).
(z) “Verizon RLEC Hotline” means (800) 285-3776 (or an alternative similarly 
designated number), the toll free number established by Verizon for use by carriers 
to report rural calling issues.
II. BACKGROUND
3. Section 201(b) of the Act provides that “[a]ll charges, practices, classifications, and 
regulations for and in connection with [interstate and foreign] communication service, shall be just and 
reasonable, and any such charge, practice, classification, or regulation that is unjust or unreasonable is 
declared to be unlawful.”
7
  Section 202(a) states that “[i]t shall be unlawful for any common carrier to 
make any unjust or unreasonable discrimination in charges, practices, classifications, regulations, 
facilities, or services for or in connection with like communication service, directly or indirectly, by any 
means or device, . . . or to subject any particular person, class of persons, or locality to any undue or 
unreasonable prejudice or disadvantage.”
8
4. The Commission has emphasized that “it is vital that our Nation maintains a 
communications network that offers reliable and resilient service.”
9
  The Commission has also recognized 
that “permitting blocking or the refusal to deliver voice telephone traffic, whether as a means of ‘self-
help’ to address perceived unreasonable intercarrier compensation charges or otherwise, risks 
‘degradation of the country’s telecommunications network.’”
10
  To prevent that result, the Commission 
                                                     
7
47 U.S.C. § 201(b).  
8
Id. § 202(a).
9
Reliability and Continuity of Communications Networks, Including Broadband Technologies, Notice of Inquiry, 26 
FCC Rcd 5614, 5616, para. 5 (2011); see also Establishing Just and Reasonable Rates for Local Exchange Carriers, 
Declaratory Ruling and Order, 22 FCC Rcd 11629, para. 1 (Wireline Comp. Bur. 2007) (explaining that “the 
ubiquity and reliability of the nation’s telecommunications network is of paramount importance to the explicit goals 
of the Communications Act”) (Call Blocking Declaratory Ruling).  
10
Connect America Fund, Report and Order and Further Notice of Proposed Rulemaking, 26 FCC Rcd 17663, 
18029, para. 973 (2011), aff’d sub nom. In re: FCC 11-161, 753 F.3d 1015 (10th Cir. 2014) (quoting Access Charge 
Reform, Seventh Report and Order and Further Notice of Proposed Rulemaking, 16 FCC Rcd 9923, 9933, para. 24 
(2001)) (footnotes omitted).  
Federal Communications Commission DA 15-74
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has consistently held that telecommunications carriers, including interexchange carriers, generally may 
not “‘block, choke, reduce or restrict traffic in any way.’”
11
5. In June 2011, a coalition of trade associations representing rural rate-of-return incumbent 
local exchange carriers (LECs) sent a letter to the Bureau concerning “a nationwide and industry-wide 
epidemic” of calls to rural LEC service areas failing to complete or having poor call quality.
12
  In 
September 2011, the Commission announced that it had created a Rural Call Completion Task Force “to 
investigate and address the growing problem of calls to rural customers that are being delayed or that fail 
to connect.”
13
6. On February 6, 2012, the Commission’s Wireline Competition Bureau (WCB) issued the 
Rural Call Completion Declaratory Ruling, which “clarif[ied] that a carrier that knows or should know 
that calls are not being completed to certain areas, and that engages in acts (or omissions) that allow or 
effectively allow these conditions to persist, may be liable for a violation of section 201 of the Act.”
14
  It 
found that “it is an unjust and unreasonable practice in violation of section 201 of the Act for a carrier that 
knows or should know that it is providing degraded service to certain areas to fail to correct the problem 
or to fail to ensure that intermediate providers, least-cost routers, or other entities acting for or employed 
by the carrier are performing adequately.”
15
  WCB further clarified that “adopting or perpetuating routing 
practices that result in lower quality service to rural or high-cost localities than like service to urban or 
lower cost localities (including other lower cost rural areas) may, in the absence of a persuasive 
explanation, constitute unjust or unreasonable discrimination in practices, facilities, or services and 
violate section 202 of the Act.”
16
7. On November 8, 2013, the Commission released the Rural Call Completion Order, 
which adopted rules requiring covered providers to record, retain, and report to the Commission call 
answer rates for long-distance calls.
17
  The Commission found that “rural call completion problems are 
serious and widespread,”
18
and that “[t]hese failures have significant and immediate public interest 
ramifications, causing rural businesses to lose customers, cutting families off from their relatives in rural 
areas, and creating potential for dangerous delays in public safety communications in rural areas.”
19
  The 
new rules require “covered providers”
20
to record and retain detailed information about long-distance calls 
                                                     
11
Id. at 17903, para. 734 (quoting Call Blocking Declaratory Ruling, 22 FCC Rcd at 11631, para. 6).  The 
Commission has permitted call blocking “only under rare and limited circumstances.”  See Call Blocking 
Declaratory Ruling, 22 FCC Rcd at 11631, para. 6 n.20.  
12
Letter from Michael Romano, National Telecommunications Cooperative Association, et al., to Theresa Z. 
Cavanaugh, Acting Chief, Investigations & Hearings Division, FCC Enforcement Bureau, and Margaret Dailey, 
Attorney Advisor, Investigations & Hearings Division, FCC Enforcement Bureau at 3 (June 13, 2011).  
13
FCC Launches Rural Call Completion Task Force to Address Call Routing and Termination Problems in Rural 
America, News Release, 2011 WL 4454097 (Sept. 26, 2011), available at http://www.fcc.gov/document/fcc-
launches-rural-call-completion-task-force-sets-oct-18-workshop.  The Task Force conducted a workshop on rural 
call completion issues on October 18, 2011.  See http://www.fcc.gov/events/rural-call-completion-workshop.  
14
Rural Call Completion Declaratory Ruling, 27 FCC Rcd at 1355, para. 11.
15
Id. at 1355–56, para. 12 (footnote omitted).  
16
Id. at 1357–58, para. 14. 
17
See Rural Call Completion Order, 28 FCC Rcd at 16211–14, Appendix A.  
18
Id. at 16161, para. 14.  
19
Id. at 16155, para. 1.  
20
“Covered provider” means “a provider of long-distance voice service that makes the initial long-distance call path 
choice for more than 100,000 domestic retail subscriber lines.”  See id. at 16165, 16211, para. 20, Appendix A 
§ 64.2101(c).  
Federal Communications Commission DA 15-74
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to customers of incumbent rural LECs,
21
identified by OCN. The rules also require covered providers to 
report to the Commission, on a quarterly basis, answer rates and call completion rates for long-distance 
calls delivered to each rural OCN and answer rates and call completion rates for long-distance calls 
delivered to non-rural OCNs in the aggregate.
22
  The information collections required by the Rural Call 
Completion Order will go into effect after the Office of Management and Budget approves the 
information collections and the Commission publishes a notice in the Federal Register announcing their 
effective date(s).
23
8. In its 2014 Rural Call Completion Reconsideration Order, the Commission stated that a 
failure “to investigate evidence of a rural call delivery problem or to correct a problem of degraded 
service about which [a carrier] knows or should know … may lead to enforcement action.”
24
9. Verizon and its affiliates are among the world’s leading providers of communications.  
Verizon and its wireline affiliates provide retail and wholesale local and long distance voice services to 
customers and carriers, including to their wireless affiliate, Verizon Wireless, as well as to businesses and 
government customers.  
10. In April 2013, Verizon began to collect weekly samples of its call answer rates to 
individual rural incumbent LECs, identified by OCN.
25
  These samples captured, for Wednesday of each 
week, all retail and wholesale traffic handled by Verizon’s TDM (Time Division Multiplex) 
long distance networks [that was] destined to wireline local exchange carriers in 
rural areas.  The data indicate the number of calls attempted to each rural 
destination and whether or not the call was answered, based on whether an SS7 
Answer Message was generated for the call.
26
  
Verizon collected this information for each Wednesday between April 24 and December 25, 2013 and 
periodically provided its weekly reports to the Enforcement Bureau.
27
  
                                                     
21
The Commission concluded that “the only call attempts that need to be retained are those to incumbent LECs that 
are rural telephone companies” because “rural call completion problems are largely confined to such carriers.”  Id. at 
16177–78, para. 49; see also 47 U.S.C. § 153(44).  
22
Rural Call Completion Order, 28 FCC Rcd at 16184, para. 65.  
23
Id. at 16207, para. 131.  
24
Rural Call Completion Reconsideration Order, 2014 WL 6070709, at *11, para. 38 (citing 2012 Declaratory 
Ruling, 27 FCC Rcd at 1355-56, 1358-59, paras. 12, 16).
25
The rural OCNs identified in Verizon’s reports were originally based on a list created by Verizon using a 
methodology devised by the Commission.  Subsequently, NECA published a list of rural OCNs, see Wireline 
Competition Bureau Announces Deadline for Comments on Rural Call Completion Notice of Proposed Rulemaking, 
Invites Comment on List of Rural Operating Carrier Numbers, Public Notice, 28 FCC Rcd 5190 (Wireline Comp. 
Bur. 2013), and, as of July 1, 2014, Verizon began using the NECA OCN list for its weekly reports.  See Letter from 
Tamara Preiss, Vice President, Federal Regulatory Affairs, Verizon, to Christopher Killion, Associate Chief, FCC 
Enforcement Bureau at 1 (Aug. 19, 2013) (on file in EB-IHD-14-00014821) (Verizon Aug. 19 Letter).  The 26 rural 
OCNs addressed here appear on both lists.  
26
See Verizon Aug. 19 Letter; see also E-mail from Tamara Preiss, Verizon, to Margaret Dailey, Investigations & 
Hearings Division, FCC Enforcement Bureau (June 6, 2013) (on file in EB-IHD-14-00014821).  
27
See E-mail from Tamara Preiss, Verizon, to Christopher Killion, FCC Enforcement Bureau (Jan. 17, 2014) (on 
file in EB-IHD-14-00014821) (enclosing reports for October – December 2013); Letter from Tamara Preiss, 
Verizon, to Christopher Killion, FCC Enforcement Bureau (Nov. 8, 2013) (on file in EB-IHD-14-00014821) 
(enclosing reports for April 24, May 1, 8, 15, and 22, and September 2013); Letter from Tamara Preiss, Verizon, to 
Christopher Killion, FCC Enforcement Bureau (Sept. 30, 2013) (on file in EB-IHD-14-00014821) (enclosing reports 
for August 2013); Verizon August 19 Letter (enclosing reports for July 2013); Letter from Tamara Preiss, Verizon, 
(continued….)
Federal Communications Commission DA 15-74
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11. After reviewing all of Verizon’s reports for 2013, the Bureau issued a letter of inquiry 
(LOI) to Verizon seeking information about what efforts Verizon had made to investigate the causes of its 
persistently low call answer rates in 39 specific rural OCNs.
28
  In its April 4, 2014 response to the LOI, 
Verizon acknowledged that, although it had previously initiated investigations or taken remedial action 
for 13 of the 39 OCNs, it had not done so for the remaining 26 OCNs prior to being served with the 
LOI.
29
  Verizon did undertake an investigation of the remaining 26 OCNs after receiving the LOI and 
provided the results to the Bureau showing that, in Verizon’s estimation, the low call answer rates were 
not attributable to Verizon’s network or call completion practices.
III. TERMS OF AGREEMENT
12. Adopting Order.  The provisions of this Consent Decree shall be incorporated by the 
Commission or the Bureau in an Adopting Order without change, addition, deletion, or modification.
13. Jurisdiction.  Verizon agrees that the Commission, acting through the Bureau, has 
jurisdiction over it and the matters contained in this Consent Decree and has the authority to enter into 
and adopt this Consent Decree.
14. Effective Date; Violations.  The Parties agree that this Consent Decree shall become 
effective on the Effective Date as defined herein.  As of the Effective Date, the Parties agree that this 
Consent Decree shall have the same force and effect as any other order of the Commission.  
15. Termination of Investigation.  In express reliance on the covenants and representations 
in this Consent Decree and to avoid further expenditure of public resources, the Bureau agrees to 
terminate the Investigation of Verizon and its regulated affiliates.  In consideration for the termination of 
the Investigation, Verizon agrees to the terms, conditions, and procedures contained herein. The Bureau 
further agrees that, in the absence of new material evidence, it will not use the facts developed in the
Investigation through the Effective Date, or the existence of this Consent Decree, to institute any new 
proceeding, formal or informal, or take any action against Verizon and its regulated affiliates concerning 
the matters that were the subject of the Investigation.  The Bureau also agrees that, in the absence of new 
material evidence, it will not use the facts developed in the Investigation through the Effective Date, or 
the existence of this Consent Decree, to institute any proceeding, formal or informal, or take any action 
against Verizon and its regulated affiliates with respect to their basic qualifications, including character 
qualifications, to be a Commission licensee or hold Commission licenses or authorizations.
16. Admissions.  Verizon admits for the purpose of this Consent Decree and in express 
reliance on the provisions of paragraph 15 herein, that its call answer rates for the 39 OCNs were 
substantially below its call answer rates to other rural areas, and that it investigated the cause of the low 
call answer rates or took remedial action prior to receipt of the LOI for 13 of these OCNs but did not do 
so for the remaining 26 OCNs.  Verizon did undertake an investigation of the remaining 26 OCNs after 
receiving the LOI and provided the results to the Bureau showing that, in Verizon’s estimation, the low 
call answer rates were not attributable to Verizon’s network or call completion practices.   
17. Compliance Officer.  Within thirty (30) calendar days after the Effective Date, Verizon
shall designate a vice president who will have oversight over rural call completion matters for Verizon 
and its regulated affiliates to serve as a Compliance Officer and to discharge the duties set forth below.  
(Continued from previous page)                                                            
to Margaret Dailey, Enforcement Bureau (July 19, 2013) (on file in EB-IHD-14-00014821) (enclosing reports for 
June 2013).  Verizon did not provide the FCC with its records for May 29, 2013.  
28
Letter from Theresa Cavanaugh, Chief, Investigations & Hearings Division, FCC Enforcement Bureau, to 
Christopher M. Miller, Assistant General Counsel, Verizon Communications Inc. (Feb. 3, 2014) (on file in EB-IHD-
14-00014821) (LOI).
29
See generally Letter from Mark Montano, Assistant General Counsel, Verizon, to Marlene Dortch, Secretary, 
FCC (April 4, 2014) (on file in EB-IHD-14-00014821).
Federal Communications Commission DA 15-74
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The Compliance Officer shall be the Company’s Rural Call Completion Ombudsperson and shall be 
responsible for developing, implementing, and administering the Compliance Plan, and for ensuring that 
Verizon complies with the terms and conditions of the Compliance Plan and this Consent Decree, 
including the investigation and resolution of rural call completion issues. In addition to the general 
knowledge of the Communications Laws necessary to discharge his or her duties under this Consent 
Decree, the Compliance Officer shall have specific knowledge of Sections 201(b) and 202(a) of the Act, 
as interpreted in the Rural Call Completion Declaratory Ruling, and the Rural Call Completion Rules, 
prior to assuming his/her duties.
18. Compliance Plan.  For purposes of settling the matters set forth herein, Verizon agrees 
that it shall, within ninety (90) calendar days after the Effective Date, develop and implement a 
Compliance Plan designed to ensure future compliance with the Rural Call Completion Rules and with 
the terms and conditions of this Consent Decree.  Except as otherwise provided below, the Compliance 
Plan and these subparts shall be adopted by and apply only to Verizon as defined in paragraph I(2)(x).
(a)   With respect to the Rural Call Completion Rules, Verizon will implement, at a minimum,
the following procedures:
? [1] Operating Procedures.  Within ninety (90) calendar days after the Effective 
Date, Verizon shall establish Operating Procedures that all Covered Employees must 
follow to help ensure Verizon’s compliance with the Rural Call Completion Rules
and this Consent Decree.  Verizon’s Operating Procedures shall include internal 
procedures and policies specifically designed to ensure that Verizon will timely 
investigate evidence of potential rural call completion problems about which it 
knows or should know, as further described below, and, if its investigation reveals a 
rural call completion problem, that Verizon will take appropriate steps to attempt to 
resolve the problem.  Verizon shall also develop a Compliance Checklist that 
describes the steps that a Covered Employee must follow to ensure compliance with 
the Rural Call Completion Rules.
? [2] Investigations.  Within ninety (90) calendar days after the Effective Date, 
Verizon shall commence monthly investigations of potential rural call completion 
problems using the metrics-driven approaches described below based on data from
Verizon’s three long distance networks (which formed the basis of Verizon’s 
previous data reporting to the Bureau).  Verizon will investigate its call delivery to 
20 Rural OCNs per month unless certain conditions are met, as described below.
A.Monthly Investigations:  Verizon shall investigate its call delivery to up 
to 20 Rural OCNs for which its Call Answer Rate fell below 80% of its 
Aggregate Rural Answer Rate in the prior month.  If Verizon’s Call 
Answer Rate falls below 80% of the Aggregate Rural Answer Rate in 20
or more Rural OCNs for any month, Verizon will investigate up to 20 
Rural OCNs, which will include the OCNs with the lowest Call Answer 
Rates during the prior month but exclude OCNs it investigated within the 
prior two months.    
B. Negative Spike Investigations:  Within 30 days of the Effective Date, 
Verizon shall establish a metric, subject to approval by the Bureau, to 
identify Negative Spikes in Call Answer Rates to individual Rural OCNs 
in order to capture sudden decreases and short material disruptions in the 
Call Answer Rate to a Rural OCN, which the monthly investigation 
process might not otherwise flag for prompt investigation.  Verizon shall 
investigate up to ten (10) “Negative Spike OCNs” per month.  Each 
Negative Spike OCN investigation shall reduce (from 20) the number of 
monthly investigations that Verizon is required to conduct each month.  
Verizon shall implement the Negative Spike OCN investigation process 
Federal Communications Commission DA 15-74
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as soon as possible following implementation of the monthly 
investigation process but no later than 120 days from the Bureau’s 
approval of the metric.
C. Complaint Investigation Process: Verizon shall continue its current 
practice of investigating rural call completion complaints that it receives 
from the FCC, its RLEC Hotline, customers, rural consumers, or other 
sources.  These investigations shall not count toward the 20 monthly or 
Negative Spike investigations described in paragraphs A and B above.
D. Investigation Checklist:  Verizon’s investigations, which shall be similar 
to its investigations of the Rural OCNs conducted in response to the LOI, 
shall include one or more of the following, depending on the scope and 
nature of information observed and identified during the course of the 
investigation:
? Contact with the rural LEC, tandem provider, and/or Intermediate 
Provider;
? Performance of milliwatt testing;
? Placement of manual test calls, including to previously 
unanswered numbers, utilizing SS7 call trace equipment to 
monitor the exchange of signaling information in real time and to 
confirm signaling messages were coming from the rural LEC or a 
tandem provider and not an Intermediate Provider;
? Review of routing arrangements, trunk capacity, and network 
translations;
? Consultation with Verizon’s fraud group to analyze traffic 
patterns that may reflect potential call reorigination or other 
fraudulent behavior;
? Review by Verizon network engineering personnel of call detail 
records, release cause codes, or other traffic data for the OCN, or 
switch and trunk data for the Verizon network; and
? Inquiry into whether other factors (e.g., prevalence of lines with 
answering technology such as voicemail, or autodialer traffic, or 
relative proportion of unassigned numbers) are relevant.
E. To the extent Verizon does not already have contact information, 
Verizon shall consult the Local Exchange Routing Guide (LERG) for 
rural LEC contact information.  In the absence of LERG contact 
information, Verizon will seek contact information using the rural LEC’s 
web site, the FCC’s Form 499 database, the NECA Tariff FCC No. 5, or 
other available resources.
F. If an investigation reveals a possible problem with the rural LEC’s 
network or call signaling practices, Verizon will promptly notify the rural 
LEC and request troubleshooting and correction.
G. Verizon will remove from routing any Intermediate Provider that it uses
that it has reason to believe is causing call completion problems, or will 
work cooperatively with each such Intermediate Provider to analyze and 
resolve such problems as soon as practicable.
? [3] Investigative Logs; Quarterly Reports; Meetings.  Verizon shall keep logs of 
its investigative and notification efforts and provide quarterly summaries to the 
Federal Communications Commission DA 15-74
9
Bureau.  The summaries shall specify, by individual investigated Rural OCN, the 
Investigative Checklist methods employed by Verizon and explain why the chosen 
investigative methods were appropriate for the individual Rural OCN.  At the 
Bureau’s request, Verizon will meet to discuss its investigations, identify lessons 
learned, and address whether to employ different or additional investigative methods 
going forward.  
? [4] Adjustment of Investigation Metrics.  After six months of investigations are 
complete, Verizon or the Bureau may periodically propose changes to the metrics or 
triggers used to identify Rural OCNs for investigation, and will consider whether the 
maximum number of Negative Spike investigations should be altered.  Subject to 
approval of the other Party, which will not be unreasonably withheld after 
consultation between the Parties, adjustments to the metrics, triggers, or maximum 
number of Negative Spike Investigations may be implemented.
? [5] Steps to Limit Verizon’s Use of Intermediate Providers.  Within six months 
of the Effective Date, for traffic from any of Verizon’s long distance networks that is 
destined for Rural OCNs, Verizon shall limit its use of Intermediate Providers in the 
following manner:  Verizon will route such traffic through Intermediate Providers 
only if the initial Intermediate Provider to which Verizon has delivered the traffic 
has committed to terminate traffic to the rural LEC (or the tandem switch that the 
rural LEC’s switch subtends) through direct connections (“onnet”) or through no 
more than one additional Intermediate Provider.  For purposes of this provision, any 
Intermediate Provider’s use of overflow arrangements (by which an Intermediate 
Provider’s traffic is routed to another provider’s network in the event of network 
outages or congestion) shall not be deemed to violate the requirements set forth in 
this paragraph. Verizon will seek agreement from each of its Intermediate Providers 
to provide a quarterly estimate of the percentage of that provider’s traffic that is 
routed through overflow arrangements, provided however that it is not a violation of 
this Consent Decree if Verizon does not obtain such agreement. Inadvertent routing 
of a non-material amount of traffic to Intermediate Providers other than as set forth 
above shall not constitute a violation of this section provided that Verizon corrects 
any such situation promptly upon learning of it.  Verizon shall retain the option to 
adopt the FCC’s safe harbor with respect to use of Intermediate Providers as an 
alternative way to satisfy this provision.
30
? [6] Intake Identification and Special Handling of Rural Call Completion 
Problems.  Within six months of the Effective Date, Verizon shall implement 
changes to its internal systems for customer complaint intake and handling that will 
result in the automatic flagging of issues related to rural call completion.  
Specifically, Verizon’s IT systems will compare the NPA-NXX of the “dialed-to” 
number contained in the complaint to the LERG database and will flag rural LEC 
issues for special handling pursuant to the Operating Procedures.  This provision 
shall apply to both Verizon and the Verizon ILECs.
? [7] Compliance Manual.  Within ninety (90) calendar days after the Effective Date, 
the Compliance Officer shall develop and distribute a Compliance Manual to all 
Covered Employees.  The Compliance Manual shall explain the Rural Call 
Completion Rules and set forth the Operating Procedures that Covered Employees 
shall follow to help ensure Verizon’s compliance with the Rural Call Completion
Rules and this Consent Decree.  Verizon shall periodically review and revise the 
Compliance Manual as necessary to ensure that the information set forth therein 
                                                     
30
See Rural Call Completion Order, 28 FCC Rcd at 16191-94, 16213, paras. 86-94, Appendix A §64.2107.
Federal Communications Commission DA 15-74
10
remains current and accurate.  Verizon shall distribute any revisions to the 
Compliance Manual promptly to all Covered Employees.
? [8] Compliance Training Program.  Verizon shall establish and implement a 
Compliance Training Program on compliance with the Rural Call Completion Rules 
and the Operating Procedures. As part of the Compliance Training Program, 
Covered Employees shall be advised of Verizon’s obligation to report any material
noncompliance with the Rural Call Completion Rules under paragraph 19 of this 
Consent Decree and shall be instructed on how to disclose noncompliance to the 
Compliance Officer.  All Covered Employees shall be trained pursuant to the 
Compliance Training Program within ninety (90) calendar days after the Effective 
Date, except that any person who becomes a Covered Employee at any time after the 
initial Compliance Training Program shall be trained within sixty (60) calendar days 
after the date such person becomes a Covered Employee.  Verizon shall repeat
compliance training on an annual basis, and shall periodically review and revise the 
Compliance Training Program as necessary to ensure that it remains current and 
complete and to enhance its effectiveness.
(b) Industry Engagement.  Verizon commits to undertake the following efforts to advance
an industry solution to rural call completion problems:
? [1] Workshops.  Verizon shall organize, fund and host two workshops. Workshop 1 
will be held in in the Washington, DC metro area within six months of the Effective 
Date to discuss methods to further identify and isolate the causes of, and to develop 
strategies to avoid, detect, and resolve rural call completion problems.  Workshop 2
will be held in the Washington, DC metro area approximately two years after 
Workshop 1 and will address the current state of rural call completion, notable 
successes, and continued challenges since the first Workshop.
? Verizon shall coordinate the organization, publicizing, and planning for 
the Workshops with rural representatives, including NTCA and NECA.  
In addition, Verizon will invite representatives of the relevant industry 
segments, including long distance and wireless providers, rural LECs, 
intermediate providers, relevant trade associations, such as USTelecom, 
CTIA, and COMPTEL, and relevant government agencies, including the 
FCC to both Workshops.  Each Workshop will include participants with 
technical expertise relevant to rural call completion issues.
? Verizon shall bear all costs of the venue and publicizing of Workshops 1 
and 2.  
? [2] Research.  Verizon shall commission a grant in the amount of $30,000-$50,000 
for an academic study on methods to detect and resolve rural call completion 
problems in real time.
? Verizon shall publicize the grant within three months of the Effective 
Date and will select the winning proposal, following consultation with 
the Bureau, within 45 days after Workshop 1.
? Verizon agrees to work with the grantee and the Bureau to provide 
reasonable access, consistent with all legal obligations, to traffic data, if 
necessary, for the academic study.
? The academic study shall be required to be completed within 18 months
of the selection and the grantee shall be required to present his or her 
findings to Verizon and the Bureau, as well as at Workshop 2.
Federal Communications Commission DA 15-74
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? [3] Communication.  Verizon will work with NECA, NTCA, and other rural 
representatives to publicize to the rural LEC community the Verizon RLEC Hotline, 
the availability of milliwatt testing, and the importance of maintaining updated 
contact information in the LERG.  
? In addition, Verizon shall maintain a list of contact information (e.g., 
phone numbers, e-mail addresses) for each rural LEC that it contacts 
during its investigations and will share with the FCC the contact 
information for rural LECs and other providers that it obtains through its 
investigations.
? [4] Public Report.  Verizon shall prepare a Public Report summarizing its 
investigations, lessons learned, and other information regarding avoidance, 
investigation, and resolution of rural call completion problems, including 
information presented in Workshop 2.  Verizon will share a draft of the report with 
the Bureau and work with the Bureau to prepare a final public version to be filed in 
WCB Docket No. 13-39 within 90 days of the Termination Date.
19. Reporting Noncompliance.  Verizon shall report any material noncompliance with the 
Rural Call Completion Rules and with the terms and conditions of this Consent Decree within fifteen (15) 
business days after discovery of such noncompliance.  Such reports shall include a detailed explanation 
of: (i) each instance of material noncompliance; (ii) the steps that Verizon has taken or will take to 
remedy such noncompliance; (iii) the schedule on which such remedial actions will be taken; and (iv) the 
steps that Verizon has taken or will take to prevent the recurrence of any such noncompliance.  All reports 
of noncompliance shall be submitted to the Chief, Investigations and Hearings Division, Enforcement 
Bureau, Federal Communications Commission, 445 12
th
Street, SW, Room 4-C224, Washington, DC 
20554, with a copy submitted electronically to Jeffrey Gee at Jeffrey.Gee@fcc.gov and Margaret Dailey 
at Margaret.Dailey@fcc.gov.
20. Compliance Reports.  Verizon shall file compliance reports with the Commission 120
calendar days after the Effective Date, twelve (12) months after the Effective Date, twenty-four (24) 
months after the Effective Date, and thirty-six (36) months after the Effective Date.  
(a) Each Compliance Report shall include a detailed description of Verizon’s efforts 
during the relevant period to comply with the terms and conditions of this Consent 
Decree and the Rural Call Completion Rules.  In addition, each Compliance Report 
shall include a certification by the Compliance Officer, as an agent of and on behalf 
of Verizon, stating that the Compliance Officer has personal knowledge that 
Verizon: (i) has established and implemented the Compliance Plan; (ii) has utilized 
the Operating Procedures since the implementation of the Compliance Plan; and (iii) 
is not aware of any instances of material noncompliance with the terms and 
conditions of this Consent Decree, including the reporting obligations set forth in 
paragraph 19 of this Consent Decree.
(b) The Compliance Officer’s certification shall be accompanied by a statement 
explaining the basis for such certification and shall comply with Section 1.16 of the 
Rules and be subscribed to as true under penalty of perjury in substantially the form 
set forth therein.
31
(c) If the Compliance Officer cannot provide the requisite certification, the Compliance 
Officer, as an agent of and on behalf of Verizon, shall provide the Commission with 
a detailed explanation of the reason(s) why and describe fully: (i) each instance of 
material noncompliance; (ii) the steps that Verizon has taken or will take to remedy 
                                                     
31
47 C.F.R. § 1.16.
Federal Communications Commission DA 15-74
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such noncompliance, including the schedule on which proposed remedial actions 
will be taken; and (iii) the steps that Verizon has taken or will take to prevent the 
recurrence of any such noncompliance, including the schedule on which such 
preventive action will be taken.
(d) All Compliance Reports shall be submitted to the Chief, Investigations and 
Hearings Division, Enforcement Bureau, Federal Communications Commission, 
445 12
th
Street, SW, Room 4-C224, Washington, DC 20554, with a copy submitted 
electronically to Jeffrey Gee at Jeffrey.Gee@fcc.gov and Margaret Dailey at 
Margaret.Dailey@fcc.gov.
21. Termination Date. Unless stated otherwise, the requirements set forth in paragraphs 17
through 20 of this Consent Decree shall expire thirty-six (36) months after the Effective Date.  
22. Section 208 Complaints; Subsequent Investigations.  Nothing in this Consent Decree 
shall prevent the Commission or its delegated authority from adjudicating complaints filed pursuant to 
Section 208 of the Act
32
against Verizon or its affiliates for alleged violations of the Act, or for any other 
type of alleged misconduct, regardless of when such misconduct took place.  The Commission’s 
adjudication of any such complaint will be based solely on the record developed in that proceeding.  
Except as expressly provided in this Consent Decree, this Consent Decree shall not prevent the 
Commission from investigating new evidence of noncompliance by Verizon with the Communications 
Laws.
23. Compliance with the Rural Call Completion Order and FCC Rules.  Nothing in this 
Consent Decree shall alter Verizon’s obligation to comply with the Rural Call Completion Order or any 
other FCC Rules or orders.
24. Fine.  Verizon will pay a fine to the United States Treasury in the amount of Two Million 
Dollars ($2,000,000) within thirty (30) calendar days of the Effective Date.  Verizon shall send electronic 
notification of payment to Jeffrey Gee at Jeffrey.Gee@fcc.gov and Margaret Dailey at 
Margaret.Dailey@fcc.gov on the date said payment is made.  The payment must be made by check or 
similar instrument, wire transfer, or credit card, and must include the Account Number and FRN 
referenced above. Regardless of the form of payment, a completed FCC Form 159 (Remittance Advice) 
must be submitted.
33
  When completing the FCC Form 159, enter the Account Number in block number 
23A (call sign/other ID) and enter the letters “FORF” in block number 24A (payment type code).  Below 
are additional instructions that should be followed based on the form of payment selected:
? Payment by check or money order must be made payable to the order of the Federal 
Communications Commission. Such payments (along with the completed Form 159) must be 
mailed to Federal Communications Commission, P.O. Box 979088, St. Louis, MO 63197-
9000, or sent via overnight mail to U.S. Bank – Government Lockbox #979088, 
SL-MO-C2-GL, 1005 Convention Plaza, St. Louis, MO 63101.
? Payment by wire transfer must be made to ABA Number 021030004, receiving bank 
TREAS/NYC, and Account Number 27000001.  To complete the wire transfer and ensure 
appropriate crediting of the wired funds, a completed Form 159 must be faxed to U.S. Bank 
at (314) 418-4232 on the same business day the wire transfer is initiated.
? Payment by credit card must be made by providing the required credit card information on 
FCC Form 159 and signing and dating the Form 159 to authorize the credit card payment.  
The completed Form 159 must then be mailed to Federal Communications Commission, P.O. 
Box 979088, St. Louis, MO 63197-9000, or sent via overnight mail to U.S. Bank –
                                                     
32
47 U.S.C. § 208.
33
An FCC Form 159 and detailed instructions for completing the form may be obtained at 
http://www.fcc.gov/forms#159.pdf.
Federal Communications Commission DA 15-74
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Government Lockbox #979088, SL-MO-C2-GL, 1005 Convention Plaza, St. Louis, MO 
63101.
Questions regarding payment procedures should be addressed to the Financial Operations Group Help 
Desk by phone, 1-877-480-3201, or by e-mail, ARINQUIRIES@fcc.gov.
25. Additional Financial Commitment.  In furtherance of this comprehensive settlement, 
and in addition to the fine specified in paragraph 24 above, Verizon commits to have spent prior to the 
Termination Date of this Consent Decree, at least Three Million Dollars ($3,000,000) on measures to 
advance and achieve Company and industry solutions to rural call completion problems, including 
through the measures specified in paragraph 18 above.  This Three Million Dollar rural call completion 
commitment is separate from and in addition to any expenditures Verizon otherwise would have made to 
comply with the Rural Call Completion Order and does not include expenses incurred responding to the 
LOI. Verizon will provide an overview of amounts spent for these purposes in its annual compliance 
reports to the Bureau.
26. Waivers.  As of the Effective Date, Verizon waives any and all rights it may have to seek 
administrative or judicial reconsideration, review, appeal or stay, or to otherwise challenge or contest the 
validity of this Consent Decree and the Adopting Order.  Verizon shall retain the right to challenge 
Commission interpretation of the Consent Decree or any terms contained herein.  If either Party (or the 
United States on behalf of the Commission) brings a judicial action to enforce the terms of the Consent 
Decree or the Adopting Order, neither Verizon nor the Commission shall contest the validity of the 
Consent Decree or the Adopting Order, and Verizon shall waive any statutory right to a trial de novo.  
Verizon hereby agrees to waive any claims it may otherwise have under the Equal Access to Justice Act
34
relating to the matters addressed in this Consent Decree.
27. Severability.  The Parties agree that if any of the provisions of the Consent Decree shall 
be held unenforceable by any court of competent jurisdiction, such unenforceability shall not render 
unenforceable the entire Consent Decree, but rather the entire Consent Decree shall be construed as if not 
containing the particular unenforceable provision or provisions, and the rights and obligations of the 
Parties shall be construed and enforced accordingly.
28. Invalidity.  In the event that this Consent Decree in its entirety is rendered invalid by any 
court of competent jurisdiction, it shall become null and void and may not be used in any manner in any 
legal proceeding.
29. Subsequent Rule or Order.  The Parties agree that if any provision of the Consent 
Decree conflicts with any subsequent Rule or Order adopted by the Commission (except an Order 
specifically intended to revise the terms of this Consent Decree to which Verizon does not expressly 
consent) that provision will be superseded by such Rule or Order.
30. Successors and Assigns.  Verizon agrees that the provisions of this Consent Decree shall 
be binding on its successors, assigns, and transferees.
31. Final Settlement.  The Parties agree and acknowledge that this Consent Decree shall 
constitute a final settlement between the Parties with respect to the Investigation.  
32. Modifications.  This Consent Decree cannot be modified without the advance written 
consent of both Parties.
33. Paragraph Headings.  The headings of the paragraphs in this Consent Decree are 
inserted for convenience only and are not intended to affect the meaning or interpretation of this Consent 
Decree.
34. Authorized Representative. Each Party represents and warrants to the other that it has 
full power and authority to enter into this Consent Decree.  Each person signing this Consent Decree on 
                                                     
34
See 5 U.S.C. § 504; 47 C.F.R. §§ 1.1501–1.1530.
Federal Communications Commission DA 15-74
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behalf of a Party hereby represents that he or she is fully authorized by the Party to execute this Consent 
Decree and to bind the Party to its terms and conditions.
35. Counterparts.  This Consent Decree may be signed in counterpart (including 
electronically or by facsimile).  Each counterpart, when executed and delivered, shall be an original, and 
all of the counterparts together shall constitute one and the same fully executed instrument.
________________________________
Travis LeBlanc
Chief
Enforcement Bureau
________________________________
Date
________________________________
Chris Miller
Vice President & Associate General Counsel
Verizon
________________________________
Date