December 10, Ms. Mary Jo Kunkle Executive Secretary Michigan Public Service Commission 6545 Mercantile Way P.O. Box Lansing, MI 48909

Transcription

1 A. Randall Vogelzang General Counsel Great Lakes Region December 10, 2008 HQE02H Hidden Ridge P.O. Box Irving, TX Phone Fax Ms. Mary Jo Kunkle Executive Secretary Michigan Public Service Commission 6545 Mercantile Way P.O. Box Lansing, MI Subject: VERIZON DIRECT TESTIMONY MPSC CASE NO. U Dear Ms. Kunkle: Enclosed for electronic filing please find a copy of Verizon North Inc., Contel of the South, Inc. d/b/a Verizon North Systems, MCI Communications Services, Inc. d/b/a Verizon Business Services, and MCImetro Access Transmission Services LLC d/b/a Verizon Access Transmission Services (collectively Verizon ) Direct Testimony of Don Price. Also attached is the Certificate of Service. If you have any questions, please contact me. Sincerely, A. Randall Vogelzang c: Parties of Record Enclosures

2 STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION In the matter of the formal complaint of ) Michigan Bell Telephone Company, d/b/a ) Case No. U AT&T Michigan, against ACD Telecom, Inc ) ) DIRECT TESTIMONY OF DON PRICE ON BEHALF OF VERIZON NORTH INC., CONTEL OF SOUTH, INC. d/b/a VERIZON NORTH SYSTEMS, MCI COMMUNICATIONS SERVICES, INC. d/b/a VERIZON BUSINESS SERVICES, AND MCIMETRO ACCESS TRANSMISSION SERVICES LLC d/b/a VERIZON ACCESS TRANSMISSION SERVICES DECEMBER 10, 2008

3 1 2 3 Q. PLEASE STATE YOUR NAME AND BUSINESS ADDRESS. A. My name is Don Price, and my business address is 701 Brazos, Suite 600, Austin, Texas, Q. BY WHOM ARE YOU EMPLOYED AND WHAT IS YOUR POSITION? A. I am Director State Regulatory Policy in the Verizon Business Regulatory and Litigation Department. I am testifying here on behalf of Verizon North Inc., Contel of the South, Inc. d/b/a Verizon North Systems, MCI Communications Services, Inc. d/b/a Verizon Business Services, and MCImetro Access Transmission Services LLC d/b/a Verizon Access Transmission Services (collectively Verizon ) Q. WHAT IS YOUR PROFESSIONAL EXPERIENCE AND EDUCATIONAL BACKGROUND? A. I have 30 years experience in telecommunications, the vast majority of which is in the public policy area. I worked for the former GTE Southwest in the early 1980s, then moved to the Texas Public Utilities Commission in There, I acted as a Commission witness on rate-setting and policy issues. In 1986, I became Manager of Rates and Tariffs, and was responsible for Staff analyses of rate design and tariff policy issues in all telecommunications proceedings before the Commission. I was hired by MCI in 1986, where I spent 19 years in jobs focused on public policy issues relating to competition in telecommunications markets, including coordination of policy positions in interconnection agreement negotiations With the close of the Verizon/MCI merger in January 2006, I assumed my current position as Director State Regulatory Policy for Verizon Business. In that position, I 1

4 1 2 3 work with various corporate departments, including those involved with product development and network engineering, to develop and coordinate policies permitting Verizon Business to offer enterprise and wholesale products to meet customer demands During my career, I have testified before state regulators in at least 24 states on a wide range of issues in many types of proceedings, including those addressing intercarrier compensation (e.g., switched access rates) and interconnection agreement arbitrations between local exchange carriers. A list of those proceedings in which I furnished testimony is provided as. I earned master s and bachelor s degrees in sociology from the University of Texas at Arlington in 1978 and 1977, respectively Q. WHAT IS THE PURPOSE OF YOUR DIRECT TESTIMONY? A. I will discuss the claim filed by AT&T and provide my thoughts on ACD Telecom s counterclaim against Verizon Q. HAVE YOU REVIEWED THE COMPLAINT FILED BY AT&T MICHIGAN AGAINST ACD TELECOM, INC., INCLUDING THE DIRECT TESTIMONY OF MR. DAVID PIASECKI, AS WELL AS ACD TELECOM S ANSWER? A. Yes, I have Q. COULD YOU PLEASE SUMMARIZE WHAT YOU UNDERSTAND TO BE MR. PIASECKI S CONCLUSION REGARDING ACD TELECOM S MICHIGAN RATES? A. Yes. As I read Mr. Piasecki s direct testimony, he has concluded that ACD Telecom s switched access rates in Michigan are excessive in light of its retail toll rates. To understand this conclusion, one must have a working knowledge of switched access rates, 2

5 how those rates are applied, and what type of carrier pays them. Generically speaking, when an end user customer places a toll call, a local exchange company s network provides the switching and transport functions necessary to get the call to a toll provider. The toll provider then transmits the call over its network to the distant (terminating) end, and hands the call off to the local exchange company at the terminating end. The local exchange company at the terminating end then provides the transport and switching functions necessary to complete the call to the called person or business. The switched access charges, such as those of ACD Telecom that are at issue in the instant proceeding, represent wholesale charges that other carriers are required to pay for the originating 10 and/or terminating transport and switching functions described above. 1 Also, local exchange carriers may assess different switched access rates to access customers depending on whether the toll call originates and terminates in different states, or originates and terminates within the same state. It should also be noted that ACD Telecom, like other providers, offers both local exchange services and retail toll services in competition with the toll services of unaffiliated carriers a fact that is crucial to an understanding of Mr. Piasecki s conclusions Q. PLEASE EXPLAIN. A. There are particular competitive implications that arise when one group of carriers obtain wholesale inputs to their retail toll services from a company that also competes against them in the interexchange toll market. When a toll provider s customer places an interexchange call to a local customer of ACD Telecom, that carrier has no means of avoiding ACD Telecom s switched access rates. Stated differently, toll providers are 1 See also the direct testimony of Mr. Piaseck at pages

6 captive customers of ACD Telecom when terminating interexchange calls to ACD Telecom s local customers. If a local exchange company s switched access rates are excessive compared to market-based retail toll rates, such as is the case with ACD Telecom, the competitive process is harmed because the toll providers cost to terminate toll calls exceeds the retail toll rates charged to toll customers Q. HOW DOES YOUR PREVIOUS ANSWER RELATE TO THE FACTS IN THIS PROCEEDING? A. ACD Telecom attached a tariff sheet to its Answer in this proceeding confirming that the 10 switched access rate that ACD Telecom charges in Michigan is $0.10 per minute. 2 That amount represents the wholesale price input to the retail toll service of the provider purchasing ACD Telecom s access service As to the prices charges by carriers for their retail toll products in Michigan, I reviewed information from a website operated by ABTolls, indicating that carriers providing toll services in Michigan offer rate packages with per-minute prices ranging from as low as $0.02 per minute for some carriers and packages to more than $0.12 per minute for other 18 carriers and packages. 3 According to that website, rate packages for Michigan intrastate toll calling offered by both AT&T and MCI would result in consumers paying $0.07 per minute for intrastate toll calls. A toll provider incurs access expenses on both ends of the call, so a provider charging 7 (let alone 2 ) per-minute for its retail toll service 2 I understand from Mr. Piasecki s direct testimony at page 6, lines 16-17, that ACD Telecom s access rate for interstate traffic is approximately 1/3 per minute, or roughly 1/30 th the level of its 10 intrastate switched access rate. 3 See, visited on December 8,

7 1 2 obviously loses money on every call where it incurs ACD Telecom s 10 per-minute switched access rate on one end Q. HOW DOES THIS SITUATION RELATE TO THE IMPUTATION POINT RAISED BY MR. PIASECKI? A. As I noted, a carrier that pays 10 per minute for one end of a wholesale input when the retail rate is only 7 per minute or less is losing money on every call. Mr. Piasecki s point is that ACD Telecom is both a provider of local service as well as an IXC that competes with other IXCs, and prices its retail toll services at 5 per minute. Because ACD Telecom provides the functions of transport and switching for itself when it provides retail toll services to its own local service customers, its 10 per minute access rate cannot be squared with its retail toll prices that, at 5 per minute, are only half the level of the wholesale input price. Regulators often examine the price of a wholesale input relative to the finished product price, a test referred to as imputation meaning that the wholesale input price is imputed into the retail or finished product price. In the case of ACD Telecom s Michigan rates, such a test shows either that its retail toll service prices should be significantly increased, or that its wholesale switched access rates are multiples above reasonable rate levels Q. HAVE YOU REVIEWED THE ACD TELECOM COUNTERCLAIM AGAINST VERIZON FILED IN THIS PROCEEDING? A. Yes, I have. 23 5

8 Q. WHAT IS YOUR RESPONSE? A. Verizon disputes the counterclaim. ACD Telecom s proof consists of only a single phrase in one page of testimony without supporting documentation alleging that Verizon has failed to pay ACD local access switching charges in the amount of approximately $100, allegation. I have seen nothing that provides a factual basis for ACD Telecom s 8 9 Q. DOES THAT CONCLUDE YOUR DIRECT TESTIMONY? A. Yes. 4 Direct Testimony of Kevin Schoen in Support of Counterclaim against Verizon. 6

9 Page 1 of 15 DON PRICE ACADEMIC AND PROFESSIONAL QUALIFICATIONS, AND TESTIMONY PRESENTED BEFORE REGULATORY AGENCIES Academic Background: My academic background is in the social sciences. I received my Bachelor of Arts degree in Sociology from the University of Texas at Arlington May of 1977 and was awarded a Master of Arts degree in Sociology by the University of Texas at Arlington in Professional Qualifications: I have 30 years experience in telecommunications, the vast majority of which is in the area of public policy. In the early 1980s I was employed by GTE in the Southwest operating company territory where I held several positions of increasing responsibility in Economic Planning. In those positions I became quite familiar with local exchange telephone company functions such as the workings and design of the local exchange switching and outside plant networks, the network planning process, business office operation, and the design and operation of large billing systems. At the time of the divestiture of the Bell Operating Companies from the AT&T system in January, 1984, I was employed by the Public Utility Commission of Texas where I was responsible for analysis and expert testimony on behalf of the public interest on a variety of policy and rate setting issues. In 1986 I was promoted to Manager of Rates and Tariffs, and was directly responsible for staff analyses of rate design and tariff policy issues in all telecommunications proceedings before the PUC. In late 1986, I was hired into the MCI Regulatory organization to provide analyses of rates and tariffs affecting MCI s growing long distance business. Over my career with MCI until the merger of Verizon and MCI in 2006, my job functions related to public policy issues relating to competition in telecommunications markets. In the 1990s, my focus narrowed to public policy issues pertaining to competition in local telecommunications markets, and I have been involved

10 Page 2 of 15 directly and indirectly in interconnection negotiations, including a landmark agreement with Bell South negotiated prior to passage of the 1996 Telecommunications Act. I have presented policy testimony in numerous state arbitrations. On January 6, 2006, with the close of Verizon s merger with MCI, I assumed my current position as Director --- State Regulatory Policy in Verizon Business Regulatory and Litigation department. In that position, I am involved with various corporate departments in developing and coordinating policies that permit Verizon Business to offer the variety of enterprise and wholesale products demanded by our customers. I have appeared as a panelist and/or speaker before various professional and trade associations and public seminars during my professional career, including the Texas Society of CPAs, the University of Texas Department of Electrical and Computer Engineering Telecommunications Conference, the Alabama Telephone Association, the Arkansas Telephone Association, and the National Association of Regulatory Utility Attorneys. I have presented testimony before a number of regulatory commissions, including the Federal Communications Commission, and state regulatory agencies in Arizona, Arkansas, California, Colorado, Florida, Georgia, Illinois, Indiana, Kansas, Kentucky, Louisiana, Minnesota, Missouri, New Jersey, Nevada, North Carolina, Ohio, Oklahoma, Oregon, Pennsylvania, South Carolina, Tennessee, Texas, Virginia, and Washington. A list of those proceedings in which I have furnished testimony is provided below.

11 Page 3 of 15 Testimony Presented: FCC CC DOCKET NO. 00-4: IN THE MATTER OF APPLICATION BY SBC COMMUNICA- TIONS, INC., SOUTHWESTERN BELL TELEPHONE COMPANY, AND SOUTHWESTERN BELL COMMUNICATIONS SERVICES, INC. D/B/A SOUTHWESTERN BELL LONG DISTANCE FOR PROVISION OF IN-REGION, INTERLATA SERVICES IN TEXAS Arkansas Docket No U: IN RE IMPLEMENTATION OF TITLE IV OF THE AMERICANS WITH DISABILITIES ACT OF 1990 Docket No R: IN THE MATTER OF A PROCEEDING FOR THE DEVELOP-MENT OF RULES AND POLICIES CONCERNING OPERATOR SERVICE PROVIDERS Arizona Docket No. T-00000A : IN THE MATTER OF U S WEST COMMUNICATIONS, INC. S COMPLIANCE WITH SECTION 271 OF THE TELECOMMUNICATIONS ACT OF 1996 Docket Nos. T-00000D and T-01051B : IN THE MATTER OF INVESTIGATION OF THE COST OF TELECOMMUNICATIONS ACCESS, and IN THE MATTER OF QWEST CORPORATION S FILING AMENDED RENEWED PRICE REGULATION PLAN California APPLICATION A : APPLICATION BY PACIFIC BELL TELEPHONE COMPANY D/B/A SBC CALIFORNIA (U 1001 C) FOR ARBITRATION OF AN INTERCONNECTION AGREEMENT WITH MCIMETRO ACCESS TRANSMISSION SERVICES LLC (U 5253 C) PURSUANT TO SECTION 252(B) OF THE TELECOMMUNICATIONS ACT OF APPLICATION : APPLICATION BY PACIFIC BELL TELEPHONE COMPANY (U 1001 C) FOR ARBITRATION OF AN INTERCONNECTION AGREEMENT WITH MCIMETRO ACCESS TRANSMISSION SERVICES, L.L.C. (U 5253 C) PURSUANT TO SECTION 252(B) OF THE TELECOMMUNICATIONS ACT OF 1996

12 California (cont d) Page 4 of 15 RULEMAKING R , INVESTIGATION I : ON THE COMMISSION'S OWN MOTION TO GOVERN OPEN ACCESS TO BOTTLENECK SERVICES AND ESTABLISH A FRAMEWORK FOR NETWORK ARCHITECTURE DEVELOPMENT OF DOMINANT CARRIER NETWORKS; INVESTIGATION ON THE COMMISSION'S OWN MOTION INTO OPEN ACCESS AND NETWORK ARCHITECTURE DEVELOPMENT OF DOMINANT CARRIER NETWORKS Colorado Docket No. 00I1-494-T: IN THE MATTER OF THE INVESTIGATION INTO MODIFICATION OF COMMISSION PRACTICES AND POLICIES REGARDING INTERCARRIER COMPENSATION Docket Nos. 04A-411T & 04D-440T: IN THE MATTER OF THE COMBINED APPLICATION OF QWEST CORPORATION FOR RECLASSIFICATION AND DEREGULATION OF CERTAIN PART 2 PRODUCTS AND SERVICES AND DEREGULATION OF CERTAIN PART 3 PRODUCTS AND SERVICES; and STAFF OF THE COLORADO PUBLIC UTILITIES COMMISSION'S PETITION FOR A DECLARATORY ORDER CONCERNING THE RECLASSIFICATION AND DEREGULATION OF TELECOMMUNICATIONS SERVICES UNDER PARTS 2 AND 3, TITLE 40, ARTICLE 15 OF THE COLORADO REVISED STATUTES Florida Docket No TL: IN RE: SOUTHERN BELL TELEPHONE AND TELEGRAPH COMPANY'S PETITION FOR APPROVAL OF NUMBERING PLAN AREA RELIEF FOR 305 AREA CODE Docket No TP: IN RE: DETERMINATION OF FUNDING FOR UNIVERSAL SERVICE AND CARRIER OF LAST RESORT RESPONSIBILITIES. Docket No TP: IN RE: INVESTIGATION INTO TEMPORARY LOCAL TELEPHONE NUMBER PORTABILITY SOLUTION TO IMPLEMENT COMPETITION IN LOCAL EXCHANGE TELEPHONE MARKETS. Docket No TP: IN RE: RESOLUTION OF PETITION(S) TO ESTABLISH NON- DISCRIMINATORY RATES, TERMS, AND CONDITIONS FOR RESALE INVOLVING LOCAL EXCHANGE COMPANIES AND ALTERNATIVE LOCAL EXCHANGE COMPANIES PURSUANT TO SECTION , FLORIDA STATUTES. Docket No TP: IN RE: RESOLUTION OF PETITION(S) TO ESTABLISH NON- DISCRIMINATORY RATES, TERMS, AND CONDITIONS FOR INTERCONNECTION INVOLVING LOCAL EXCHANGE COMPANIES AND ALTERNATIVE LOCAL EXCHANGE COMPANIES PURSUANT TO SECTION , FLORIDA STATUTES.

13 Florida (cont d) Page 5 of 15 Docket No TP: IN RE: PETITION OF MCIMETRO ACCESS TRANSMISSION SERVICES, LLC AND MCI WORLDCOM COMMUNICATIONS, INC. FOR ARBITRATION OF CERTAIN TERMS AND CONDITIONS OF PROPOSED AGREEMENT WITH BELLSOUTH TELECOMMUNICATIONS, INC. CONCERNING INTERCONNECTION AND RESALE UNDER THE TELECOMMUNICATIONS ACT OF Docket No TP: IN THE MATTER OF PETITION OF MCIMETRO ACCESS TRANSMISSION SERVICES, LLC FOR ARBITRATION OF INTERCONNECTION AGREEMENT WITH BELLSOUTH TELECOMMUNICATIONS, INC. DOCKET NO TP: IN RE: PETITION OF MCIMETRO ACCESS TRANSMISSION SERVICES LLC D/B/A VERIZON ACCESS TRANSMISSION SERVICES FOR ARBITRATION OF DISPUTES ARISING FROM NEGOTIATION OF INTERCONNECTION AGREEMENT WITH EMBARQ FLORIDA, INC. Georgia Docket No U: IN RE: INVESTIGATION INTO THE FUNDING OF UNIVERSAL SERVICE. Docket No U: IN THE MATTER OF: MCIMETRO PETITION TO ESTABLISH NONDISCRIMINATORY RATES, TERMS AND CONDITIONS FOR UNBUNDLING AND RESALE OF LOCAL LOOPS. Docket No U: IN RE: PETITION OF MCIMETRO ACCESS TRANSMISSION SERVICES, LLC AND MCI WORLDCOM COMMUNICATIONS, INC. FOR ARBITRATION OF CERTAIN TERMS AND CONDITIONS OF PROPOSED AGREEMENT WITH BELLSOUTH TELECOMMUNICATIONS, INC. CONCERNING INTERCONNECTION AND RESALE UNDER THE TELECOMMUNICATIONS ACT OF Docket No U: IN RE: PETITION OF MCIMETRO ACCESS TRANSMISSION SERVICES LLC D/B/A VERIZON ACCESS TRANSMISSION SERVICES FOR ARBITRATION WITH BELLSOUTH TELECOMMUNICATIONS, INC. UNDER THE TELECOMMUNICATIONS ACT OF 1996 Docket No U: IN RE: APPLICATION OF MCI COMMUNICATIONS SERVICES, INC. D/B/A VERIZON BUSINESS SERVICES, MCIMETRO ACCESS TRANSMISSION SERVICES LLC D/B/A VERIZON ACCESS TRANSMISSION SERVICES, VERIZON SELECT SERVICES INC., AND TELECONNECT LONG DISTANCE SERVICES AND SYSTEMS COMPANY TO DETARIFF RETAIL BUSINESS SERVICES PURSUANT TO O.C.G.A

14 Illinois Page 6 of 15 Docket No : PETITION FOR ARBITRATION OF INTERCONNECTION RATES, TERMS AND CONDITIONS AND RELATED ARRANGEMENTS WITH ILLINOIS BELL TELEPHONE COMPANY PURSUANT TO SECTION 252(b) OF THE TELECOMMUNICATIONS ACT OF Indiana Cause No INT-01: PETITION OF MCIMETRO VERIZON ACCESS TRANSMISSION SERVICES LLC D/B/A VERIZON ACCESS TRANSMISSION SERVICES FOR ARBITRATION OF AN INTERCONNECTION AGREEMENT WITH UNITED TELEPHONE COMPANY OF INDIANA, INC. D/B/A EMBARQ UNDER SECTION 252(B) OF THE TELECOMMUNICATIONS ACT OF 1996 Kansas Docket No. 190,492-U: IN THE MATTER OF A GENERAL INVESTIGATION INTO COMPETITION WITHIN THE TELECOMMUNICATIONS INDUSTRY IN THE STATE OF KANSAS Docket No. 02-GIMT-678-GIT: IN THE MATTER OF A GENERAL INVESTIGATION INTO WINBACK/RETENTION PROMOTIONS AND PRACTICES Kentucky Docket No : AN INVESTIGATION INTO THE TRAFFIC DISPUTE BETWEEN WINDSTREAM KENTUCKY EAST, LLC, BRANDENBURG TELEPHONE COMPANY AND MCIMETRO ACCESS TRANSMISSION SERVICES LLC, D/B/A VERIZON ACCESS Louisiana Docket No. U-17957: IN RE: INVESTIGATION OF OPERATING PRACTICES OF ALTERNATIVE OPERATOR SERVICES PROVIDERS TO INCLUDE RATES AND CHARGES. Docket No. U-19806: IN RE: PETITION OF AT&T COMMUNICATIONS OF THE SOUTH CENTRAL STATES, INC., FOR REDUCED REGULATION OF INTRASTATE OPERATIONS. Docket No. U-20237: IN RE: OBJECTIONS TO THE FILING OF REDUCED WATS SAVER SERVICE RATES, INTRALATA, STATE OF LOUISIANA.

15 Louisiana (cont d) Page 7 of 15 Docket No. U-20710: IN RE: GENERIC HEARING TO CLARIFY THE PRICING/IMPUTATION STANDARD SET FORTH IN COMMISSION ORDER NO. U N ON A PROSPECTIVE BASIS ONLY, AS THE STANDARD RELATES TO LEC COMPETITIVE TOLL OFFERINGS. Docket No. U-20883: IN RE: THE DEVELOPMENT OF RULES AND REGULATIONS APPLICABLE TO THE ENTRY AND OPERATIONS OF, AND THE PROVIDING OF SERVICES BY, COMPETITIVE AND ALTERNATE ACCESS PROVIDERS IN THE LOCAL, INTRASTATE AND/OR INTEREXCHANGE TELECOMMUNICATIONS MARKET IN LOUISIANA. SUBDOCKET A: UNIVERSAL SERVICE. Docket No. U-25350: IN RE: PETITION OF MCIMETRO ACCESS TRANSMISSION SERVICES, LLC FOR ARBITRATION OF CERTAIN TERMS AND CONDITIONS OF PROPOSED AGREEMENT WITH BELLSOUTH TELECOMMUNICATIONS, INC. CONCERNING INTERCONNECTION AND RESALE UNDER THE TELECOMMUNICATIONS ACT OF Docket No. U-28992: IN RE: PETITION OF MCIMETRO ACCESS TRANSMISSION SERVICES LLC FOR ARBITRATION OF CERTAIN TERMS AND CONDITIONS OF PROPOSED AGREEMENT WITH BELLSOUTH TELECOMMUNICATIONS, INC. CONCERNING INTERCONNECTION AND RESALE UNDER THE TELECOMMUNICATIONS ACT OF 1996 Minnesota Docket No. P-421/CI : IN THE MATTER OF A COMMISSION INVESTIGA-TION INTO QWEST S COMPLIANCE WITH SECTION 271(c)(2)(B) OF THE TELECOMMUNICATIONS ACT OF 1996; CHECKLIST ITEMS 1, 2, 4, 5, 6, 11, 13, AND 14 Docket No. P-430,5321/M : IN THE MATTER OF THE PETITION OF MCIMETRO ACCESS TRANSMISSION SERVICES LLC D/B/A VERIZON ACCESS TRANSMISSION SERVICES FOR ARBITRATION OF AN INTERCONNECTION AGREEMENT WITH EMBARQ MINNESOTA, INC., PURSUANT TO 47 U.S.C. 252(B) Missouri Case No. TO-87-42: IN THE MATTER OF SOUTHWESTERN BELL TELEPHONE COMPANY FILING ACCESS SERVICES TARIFF REVISIONS AND WIDE AREA TELECOMMUNICATIONS SERVICE (WATS) TARIFF, INDEX, 6 th REVISED SHEET, ORIGINAL SHEET

16 Missouri (cont d) Page 8 of 15 Case No. TO , ET AL: IN THE MATTER OF AN INVESTIGATION INTO THE EXHAUSTION OF TELEPHONE NUMBERS IN THE 314 NUMBERING PLAN AREA. CASE NO. TC , ET AL.: MCI WORLDCOM COMMUNICATIONS, INC., BROOKS FIBER COMMUNICATIONS OF MISSOURI, INC., BROADSPAN COMMUNICATIONS, INC., D/B/A PRIMARY NETWORK COMMUNICATIONS, INC., COMPLAINANTS, VS. SOUTHWESTERN BELL TELEPHONE COMPANY, RESPONDENT. CASE NO. TO : IN THE MATTER OF THE INVESTIGATION OF THE STATE OF COMPETITION IN THE EXCHANGES OF SOUTHWESTERN BELL TELEPHONE COMPANY. CASE No. TO : PETITION OF MCImetro ACCESS TRANSMISSION SERVICES LLC, BROOKS FIBER COMMUNICATIONS OF MISSOURI, INC. AND MCI WORLDCOM COMMUNICATIONS, INC. FOR ARBITRATION OF AN INTERCONNECTION AGREEMENT WITH SOUTHWESTERN BELL TELEPHONE COMPANY UNDER THE TELECOMMUNICATIONS ACT OF 1996 CASE Nos. TT and TT : IN THE MATTER OF SOUTHWESTERN BELL TELEPHONE COMPANY S TARIFF FILING TO INITIATE RESIDENTIAL CUSTOMER WINBACK PROMOTION; AND IN THE MATTER OF SOUTHWESTERN BELL TELEPHONE COMPANY S TARIFF FILING TO EXTEND BUSINESS CUSTOMER WINBACK PROMOTIONS CASE No. TO : SOUTHWESTERN BELL TELEPHONE, L.P. d/b/a SBC MISSOURI S PETITION FOR COMPULSORY ARBITRATION OF UNRESOLVED ISSUES FOR A SUCCESSOR INTERCONNECTION AGREEMENT TO THE MISSOURI 271 AGREEMENT ( M2A ) Nebraska APPLICATION NO. C-3945/NUSF PI-93: IN THE MATTER OF THE NEBRASKA PUBLIC SERVICE COMMISSION, ON ITS OWN MOTION, SEEKING TO INVESTIGATE QWEST S SWITCHED ACCESS CHARGE RATES Nevada CASE NO : IN RE: APPLICATION OF CENTRAL TELEPHONE COMPANY - NEVADA d/b/a SPRINT OF NEVADA TO CONTINUE PARTICIPATION IN THE PLAN OF ALTERNATIVE REGULATION, INCLUDING A REQUEST TO INCREASE PRICES Docket No : PETITION OF MCIMETRO ACCESS TRANSMISSION SERVICES LLC FOR ARBITRATION OF AN INTERCONNECTION AGREEMENT WITH CENTRAL TELEPHONE COMPANY D/B/A EMBARQ

17 New Jersey Page 9 of 15 Docket No. TO : IN THE MATTER OF THE APPLICATION OF VERIZON NEW JERSEY, INC. FOR APPROVAL (I) OF A NEW PLAN FOR AN ALTERNATIVE FORM OF REGULATION AND (II) TO RECLASSIFY MULTI-LINE RATE REGULATED BUSINESS SERVICES AS COMPETITIVE SERVICES, AND COMPLIANCE FILING Docket No. TO : REVISED PETITION OF VERIZON ACCESS TRANSMISSION SERVICES INC. FOR ARBITRATION OF AN INTERCONNECTION AGREEMENT WITH UNITED TELEPHONE COMPANY OF NEW JERSEY D/B/A EMBARQ, UNDER SECTION 252(B) OF THE TELECOMMUNICATIONS ACT OF 1996 North Carolina Docket No. P-100, SUB 119: IN THE MATTER OF: ASSIGNMENT OF N11 DIALING CODES. Docket No. P-141, SUB 29: IN THE MATTER OF: PETITION OF MCI TELECOMMUNICATIONS CORPORATION FOR ARBITRATION OF INTERCONNECTION WITH BELLSOUTH TELECOMMUNICATIONS, INC. Docket No. P-474, SUB 10: IN RE: PETITION OF MCIMETRO ACCESS TRANSMISSION SERVICES, LLC FOR ARBITRATION OF CERTAIN TERMS AND CONDITIONS OF PROPOSED AGREEMENT WITH BELLSOUTH TELECOMMUNICATIONS, INC. CONCERNING INTERCONNECTION AND RESALE UNDER THE TELECOMMUNICATIONS ACT OF Docket No. P-474, Sub 18: IN THE MATTER OF: PETITION OF MCIMETRO ACCESS TRANSMISSION SERVICES LLC FOR ARBITRATION OF INTERCONNECTION AGREEMENT WITH CAROLINA TELEPHONE AND TELEGRAPH COMPANY, CENTRAL TELEPHONE COMPANY NORTH CAROLINA DIVISION, UNDER SECTION 252(B) OF THE TELECOMMUNICATIONS ACT OF 1996 Docket No. P-474, SUB14: IN THE MATTER OF PETITION OF MCIMETRO ACCESS TRANSMISSION SERVICES, LLC FOR ARBITRATION OF AN INTERCONNECTION AGREEMENT WITH BELLSOUTH TELECOMMUNICATIONS, INC. Docket No. P-474, SUB 18: IN THE MATTER OF PETITION OF MCIMETRO ACCESS TRANSMISSION SERVICES, LLC, D/B/A VERIZON ACCESS TRANSMISSION SERVICES, FOR ARBITRATION OF AN INTERCONNECTION AGREEMENT WITH CAROLINA TELEPHONE AND TELEGRAPH COMPANY AND CENTRAL TELEPHONE COMPANY NORTH CAROLINA DIVISION

18 Ohio Page 10 of 15 Docket No TP-ARB: IN THE MATTER OF MCIMETRO ACCESS TRANSMISSION SERVICES, LLC PETITION FOR ARBITRATION PURSUANT TO SECTION 252(b) OF THE TELECOMMUNICATIONS ACT OF 1996 TO ESTABLISH AN INTERCONNECTION AGREEMENT WITH AMERITECH OHIO. Docket No TP-ARB: IN THE MATTER OF THE PETITION OF VERIZON ACCESS TRANSMISSION SERVICES FOR ARBITRATION OF AN INTERCONNECTION AGREEMENT WITH UNITED TELEPHONE COMPANY OF OHIO D/B/A EMBARQ UNDER SECTION 252(B) OF THE TELECOMMUNICATIONS ACT OF 1996 Oklahoma Consolidated Dockets PUD NO : IN THE MATTER OF THE APPLICATION OF SOUTHWESTERN BELL TELEPHONE COMPANY FOR AN ORDER APPROVING PROPOSED CHANGES AND ADDITIONS IN APPLICANTS' WIDE AREA TELECOMMUNICATIONS SERVICE PLAN TARIFF; and, PUD NO : IN THE MATTER OF THE APPLICATION OF SOUTHWESTERN BELL TELEPHONE COMPANY FOR AN ORDER APPROVING PROPOSED ADDITIONS AND CHANGES IN APPLICANTS' ACCESS SERVICE TARIFF AND WIDE AREA TELECOMMUNICATIONS SERVICE PLAN TARIFF Consolidated Dockets PUD NO : IN THE MATTER OF THE APPLICATION OF THE OKLAHOMA RURAL TELEPHONE COALITION, GTE SOUTHWEST, INC., ALLTEL OKLAHOMA, INC., AND OKLAHOMA ALLTEL, INC. FOR AN ORDER ADOPTING THE OKLAHOMA ALTERNATIVE SETTLEMENT PLAN; and PUD NO : IN THE MATTER OF THE APPLICATION OF SOUTHWESTERN BELL TELEPHONE COMPANY FOR AN ORDER lmplementing TERMlNATlNG ACCESS CHARGES IN LIEU OF INTRALATA TOLL AND SURCHARGE POOLS; and PUD NO : IN RE: INQUIRY OF THE OKLAHOMA CORPORATION COMMISSION REGARDING WHETHER THE INTRALATA TOLL POOL AND SURCHARGE POOL SHOULD CONTINUE TO EXIST IN THE STATE OF OKLAHOMA Oregon Docket UN 1038: IN THE MATTER OF AN INVESTIGATION INTO ISSUES RELATED TO THE COMMISSION POLICY OF POSTING SERVICE QUALITY REPORTS TO ITS WEBSITE, PURSUANT TO ORS

19 Pennsylvania Page 11 of 15 Docket Nos. P F1000; R , P F1000; R , P F1000; R : 2006 ANNUAL PRICE STABILITY INDEX/SERVICE PRICE INDEX FILINGS OF BUFFALO VALLEY TELEPHONE COMPANY, CONESTOGA TELEPHONE & TELEGRAPH COMPANY AND DENVER & EPHRATA TELEPHONE & TELEGRAPH COMPANY Docket No. C : VERIZON PENNSYLVANIA INC., VERIZON NORTH INC., BELL ATLANTIC COMMUNICATIONS, INC. D/B/A VERIZON LONG DISTANCE, VERIZON SELECT SERVICES INC., VERIZON GLOBAL NETWORKS, INC., MCIMETRO ACCESS TRANSMISSION SERVICES, LLC D/B/A VERIZON ACCESS TRANSMISSION SERVICES, AND MCI COMMUNICATIONS SERVICES INC., COMPLAINANTS V. PENN TELECOM, INC., RESPONDENT Docket No. C : VERIZON PENNSYLVANIA INC., VERIZON NORTH INC., BELL ATLANTIC COMMUNICATIONS, INC. D/B/A VERIZON LONG DISTANCE, VERIZON SELECT SERVICES INC., VERIZON GLOBAL NETWORKS, INC., MCIMETRO ACCESS TRANSMISSION SERVICES, LLC D/B/A VERIZON ACCESS TRANSMISSION SERVICES, AND MCI COMMUNICATIONS SERVICES INC., COMPLAINANTS V. CTSI, LLC, RESPONDENT Consolidated Docket Nos. C , C , and C : VERIZON PENNSYLVANIA INC., VERIZON NORTH INC., BELL ATLANTIC COMMUNICATIONS, INC. D/B/A VERIZON LONG DISTANCE, VERIZON SELECT SERVICES INC., VERIZON GLOBAL NETWORKS, INC., MCIMETRO ACCESS TRANSMISSION SERVICES, LLC D/B/A VERIZON ACCESS TRANSMISSION SERVICES, AND MCI COMMUNICATIONS SERVICES INC., COMPLAINANTS V. CHOICE ONE COMMUNICATIONS OF PENNSYLVANIA, INC., CTC COMMUNICATIONS CORP., AND FIBERNET TELECOMMUNICATIONS OF PENNSYLVANIA, LLC, RESPONDENTS. South Carolina Docket No C: IN RE: N11 SERVICE CODES. Tennessee Docket No : IN RE: SHOW CAUSE PROCEEDING AGAINST CERTIFIED IXCS AND LECS TO PROVIDE TOLL FREE, COUNTY-WIDE CALLING. Docket No : IN RE: APPLICATION OF MCI METRO ACCESS TRANSMISSION SERVICES, INC. FOR AUTHORITY TO OFFER LOCAL EXCHANGE SERVICES WITHIN TENNESSEE. Docket No : INQUIRY FOR TELECOMMUNICATIONS RULEMAKING REGARDING COMPETITION IN THE LOCAL EXCHANGE.

20 Page 12 of 15 Tennessee (cont d) Docket No : UNIVERSAL SERVICE PROCEEDING, PART 1 - COST OF UNIVERSAL SERVICE AND CURRENT SOURCES OF UNIVERSAL SERVICE SUPPORT, AND PART 2 - ALTERNATIVE UNIVERSAL SERVICE SUPPORT MECHANISMS. Docket No : PETITION OF MCIMETRO ACCESS SERVICES, LLC AND BROOKS FIBER COMMUNICATIONS OF TENNESSEE, INC. FOR ARBITRATION UNDER THE TELECOMMUNICATIONS ACT OF 1996 Docket No : IN RE: PETITION OF MCIMETRO ACCESS TRANSMISSION SERVICES LLC FOR ARBITRATION OF CERTAIN TERMS AND CONDITIONS OF PROPOSED INTERCONNECTION AGREEMENT WITH BELLSOUTH TELECOMMUNICATIONS, INC. CONCERNING INTERCONNECTION AND RESALE UNDER THE TELECOMMUNICATIONS ACT OF 1996 Texas Docket 4992: APPLICATION OF GENERAL TELEPHONE COMPANY OF THE SOUTHWEST FOR A RATE/TARIFF REVISION. Docket 5113: PETITION OF PUBLIC UTILITY COMMISSION FOR AN INQUIRY CONCERNING THE EFFECTS OF THE MODIFIED FINAL JUDGMENT AND THE ACCESS CHARGE ORDER UPON SW BELL AND THE INDEPENDENT TELEPHONE COMPANIES OF TEXAS (Phase II). Docket 5610: APPLICATION OF GENERAL TELEPHONE COMPANY OF THE SOUTHWEST FOR A RATE INCREASE. Docket 5800: APPLICATION OF AT&T COMMUNICATIONS FOR AUTHORITY TO IMPLEMENT "REACH OUT TEXAS." Docket 5898; APPLICATION OF SAN ANGELO FOR REMOVAL OF THE EXTENDED AREA SERVICE CHARGE FROM GENERAL TELEPHONE COMPANY OF THE SOUTHWEST S RATES IN SAN ANGELO, TEXAS. Docket 5926: APPLICATION OF SOUTHWESTERN BELL TELEPHONE COMPANY TO ESTABLISH FEATURE GROUP "E" (FGE) ACCESS SERVICE FOR RADIO AND CELLULAR COMMON CARRIERS. Docket 5954: INQUIRY OF THE PUBLIC UTILITY COMMISSION OF TEXAS INTO OFFERING EXTENDED AREA SERVICE IN THE CITY OF ROCKWALL. Docket 6095: APPLICATION OF AT&T COMMUNICATION FOR A RATE INCREASE. Docket 6200: PETITION OF SOUTHWESTERN BELL TELEPHONE COMPANY FOR AUTHORITY TO CHANGE RATES.

21 Texas (cont d) Page 13 of 15 Docket 6264: PETITION OF THE GENERAL COUNSEL FOR INITIATION OF AN EVIDENTIARY PROCEEDING TO ESTABLISH TELECOMMUNICATIONS SUBMARKETS. Docket 6501: APPLICATION OF VALLEY VIEW TELEPHONE COMPANY FOR AN AMENDMENT TO CERTIFICATE OF CONVENIENCE AND NECESSITY. Docket 6635: APPLICATION OF MUSTANG TELEPHONE COMPANY FOR AUTHORITY TO CHANGE RATES. Docket 6740: APPLICATION OF SOUTHWEST TEXAS TELEPHONE COMPANY FOR RATE INCREASE. Docket 6935: APPLICATION OF SOUTHWESTERN BELL TELEPHONE COMPANY TO INTRODUCE MICROLINK II- PACKET SWITCHING DIGITAL SERVICE. Docket 8730: INQUIRY OF THE GENERAL COUNSEL INTO THE MEET-POINT BILLING PRACTICES OF GTE SOUTHWEST, INC. Docket 8218: INQUIRY OF THE GENERAL COUNSEL INTO THE WATS PRORATE CREDIT. Docket 8585: INQUIRY OF THE GENERAL COUNSEL INTO THE REASONABLENESS OF THE RATES AND SERVICES OF SOUTHWESTERN BELL TELEPHONE COMPANY. Docket 10127: APPLICATION OF SOUTHWESTERN BELL TELEPHONE COMPANY TO REVISE SECTION 2 OF ITS INTRASTATE ACCESS SERVICE TARIFF. Docket 11441: PETITIONS OF INFODIAL, INC., AND OTHERS FOR ASSIGNMENT OF ABBREVIATED N11 DIALING CODES. Docket 11840: JOINT PETITION OF SOUTHWESTERN BELL TELEPHONE COMPANY AND GTE SOUTHWEST, INC. TO PROVIDE EXTENDED AREA SERVICE TO CERTAIN COMMUNITIES IN THE LOWER RIO GRANDE VALLEY. Docket 14447: PETITION OF MCI TELECOMMUNICATIONS CORPORATION FOR AN INVESTIGATION OF THE PRACTICES OF SOUTHWESTERN BELL TELEPHONE COMPANY REGARDING THE EXHAUSTION OF TELEPHONE NUMBERS IN THE 214 NUMBERING PLAN AREA AND REQUEST FOR A CEASE AND DESIST ORDER AGAINST SOUTHWESTERN BELL TELEPHONE COMPANY. Dockets and 14943: APPLICATION OF SOUTHWESTERN BELL TELEPHONE COMPANY FOR INTERIM NUMBER PORTABILITY PURSUANT TO OF THE PUBLIC UTILITY REGULATORY ACT; AND APPLICATION OF GTE SOUTHWEST, INC. AND CONTEL OF TEXAS, INC. FOR INTERIM NUMBER PORTABILITY PURSUANT TO OF THE PUBLIC UTILITY REGULATORY ACT. Docket 16251: INVESTIGATION OF SOUTHWESTERN BELL TELEPHONE COMPANY'S ENTRY INTO THE INTERLATA TELECOMMUNICATIONS MARKET.

22 Texas (cont d) Page 14 of 15 Docket 16285: PETITION OF MCI TELECOMMUNICATIONS CORPORATION AND ITS AFFILIATE MCIMETRO ACCESS TRANSMISSION SERVICES, INC. FOR ARBITRATION AND REQUEST FOR MEDIATION UNDER THE FEDERAL TELECOMMUNICATIONS ACT OF Docket 18117: COMPLAINT OF MCI TELECOMMUNICATIONS CORPORATION AND MCIMETRO ACCESS TRANSMISSION SERVICE, INC. AGAINST SWBT FOR VIOLATION OF COMMISSION ORDER IN DOCKET NOS AND REGARDING PROVISIONING OF UNBUNDLED DEDICATED TRANSPORT. Docket 19075: PETITION OF MCI TELECOMMUNICATIONS CORPORATION FOR ARBITRATION OF DIRECTORY ASSISTANCE LISTINGS ISSUES UNDER FEDERAL TELECOMMUNICATIONS ACT OF Docket 21706: COMPLAINT OF MFS COMMUNICATIONS COMPANY, INC. AGAINST GTE SOUTHWEST, INCORPORATED REGARDING GTE S NONPAYMENT OF RECIPROCAL COMPENSATION Docket 21791: PETITION OF SOUTHWESTERN BELL TELEPHONE COMPANY FOR ARBITRATION WITH MCI WORLDCOM COMMUNICATIONS, INC. PURSUANT TO SECTION 252(B)(1) OF THE FEDERAL TELECOMMUNICATIONS ACT OF Docket 21982: PROCEEDING TO EXAMINE RECIPROCAL COMPENSATION PURSUANT TO SECTION 252 OF THE FEDERAL TELECOMMUNICATIONS ACT OF Dockets 22168/22469: PETITION OF IP COMMUNICATIONS CORPORATION TO ESTABLISH EXPEDITED PUBLIC UTILITY COMMISSION OF TEXAS OVERSIGHT CONCERNING LINE SHARING ISSUES; COMPLAINT OF COVAD COMMUNICATIONS COMPANY AND RHYTHMS LINKS, INC. AGAINST SOUTHWESTERN BELL TELEPHONE COMPANY AND GTE SOUTHWEST INC. FOR POST-INTERCONNECTION AGREEMENT DISPUTE RESOLUTION AND ARBITRATION UNDER THE TELECOMMUNICATIONS ACT OF 1996 REGARDING RATES, TERMS, CONDITIONS AND RELATED ARRANGEMENTS FOR LINE SHARING Docket 24542: PETITION OF MCIMETRO ACCESS TRANSMISSION SERVICES LLC FOR ARBITRATION OF AN INTERCONNECTION AGREEMENT WITH SOUTHWESTERN BELL TELEPHONE COMPANY UNDER THE TELECOMMUNICATIONS ACT OF 1996 DOCKET 28821: ARBITRATION OF NON-COSTING ISSUES FOR SUCCESSOR INTERCONNECTION AGREEMENTS TO THE TEXAS 271 AGREEMENT

23 Page 15 of 15 Virginia Docket No. PUC : PETITION OF VERIZON ACCESS TRANSMISSION SERVICES INC. FOR ARBITRATION OF AN INTERCONNECTION AGREEMENT WITH CENTRAL TELEPHONE COMPANY OF VIRGINIA D/B/A EMBARQ AND UNITED TELEPHONE SOUTHEAST, INC. D/B/A EMBARQ, UNDER SECTION 252(B) OF THE TELECOMMUNICATIONS ACT OF 1996 Washington Docket No. UT : IN THE MATTER OF THE INVESTIGATION INTO U S WEST COMMUNICATIONS, INC. S COMPLIANCE WITH SECTION 271 OF THE TELECOMMUNICATIONS ACT OF 1996 DOCKET NO. UT , Part D: IN THE MATTER OF THE CONTINUED COSTING AND PRICING OF UNBUNDLED NETWORK ELEMENTS, TRANSPORT, AND TERMINATION

24 STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION In the matter of the formal complaint of ) Michigan Bell Telephone Company, d/b/a ) Case No. U AT&T Michigan, against ACD Telecom, Inc ) ) PROOF OF SERVICE STATE OF TEXAS ) ) ss COUNTY OF DALLAS ) Patty A. Nelson, being first duly sworn, deposes and says that on December 10, 2008, a copy of Verizon s was served upon those parties listed on the attached service list via Subscribed and sworn to before me This 10 th date of December Patty A. Nelson Graci M. Scott, Notary Public Dallas County, Texas My Commission Expires: April 20, 2010

25 Service List Administrative Law Judge: Hon. Daniel Nickerson, Jr. ALJ Division Michigan Public Service Commission 6545 Mercantile Way, Suite 14 P.O. Box Lansing, MI Commission Staff: Anne M. Uitvlugt Assistant Attorney General Public Service Division Michigan Public Service Commission 6545 Mercantile Way, Suite 15 P.O. Box Lansing, MI Shannon Withenshaw Michigan Public Service Commission 6545 Mercantile Way P.O. Box Lansing, MI AT&T Michigan: Dickinson Wright PLLC William J. Champion III 215 S. Washington Square Suite 200 Lansing, Michigan Mark Ortlieb 221 N. Washington Square, 1 st Floor Lansing, MI mo2753@att.com ACD Telecom, Inc.: Gary L. Field Gary A. Gensch, Jr. Field Law Group, PLLC 915 N. Washington Avenue Lansing, MI glfield@fieldlawgroup.com gagensch@fieldlawgroup.com Kevin Shoen 1800 N. Grand River Ave. Ste. 1 Lansing, MI schoen.kevin@acd.net