Before the

**FEDERAL COMMUNICATIONS COMMISSION**

#### Washington, D.C. 20554 {#washington-d.c.-20554 .unnumbered}

In the Matter of )

> )

2000 Biennial Regulatory Review \-- ) CC Docket No. 00-229

Telecommunications Service Quality )

Reporting Requirements )

#### NOTICE OF PROPOSED RULEMAKING {#notice-of-proposed-rulemaking .unnumbered}

> Adopted: November 9, 2000 Released: November 9, 2000

By the Commission: Commissioner Tristani issuing a statement.

**Comment Date: January 12, 2001**

**Reply Comment Date: February 16, 2001**

TABLE OF CONTENTS

[paragraph]{.underline}

I.  INTRODUCTION 1

II. BACKGROUND 7

III. DISCUSSION 10

> A. Focus on End-User Consumers 11
>
> B. Categories of Performance Data 16
>
> 1\. Missed Installations 17
>
> 2\. Installation Intervals 18
>
> 3\. Trouble Reports 19
>
> 4\. Out-of-Service Troubles 20
>
> 5\. Missed Repair Appointments 21
>
> 6\. Repair Intervals 22
>
> 7\. Other Types of Information 23
>
> 8\. Definitions 24
>
> C. Broadband Services 25
>
> D. Disaggregation of Information 27
>
> E. Types of Reporting Entities 29
>
> F. Frequency of Reporting 33

G.  Public Disclosure of Service Quality Data 36

H.  Record Retention 38

I.  Elimination of Other Reporting Requirements 39

> 1\. Interexchange Carriers 39
>
> 2\. Network Reliability and Interoperability Council 40
>
> 3\. Complaints to Federal and State Commissions 41
>
> 4\. Customer Satisfaction Survey 42
>
> 5\. All Other Reporting Requirements 43

J. NARUC White Paper 44

IV\. CONCLUSION 45

V. PROCEDURAL MATTERS 46

APPENDIX A -- Current ARMIS Requirements

APPENDIX B -- Proposed Core Service Quality Reporting Requirements

APPENDIX C -- NARUC Service Quality White Paper

APPENDIX D -- Initial Regulatory Flexibility Analysis

# INTRODUCTION

1.  The purpose of the Telecommunications Act of 1996[^1] is "to promote
    competition and reduce regulation in order to secure lower prices
    and higher quality services for American telecommunications
    consumers and encourage the deployment of new telecommunications
    technologies."[^2] In this proceeding, we propose to streamline and
    reform our existing service quality monitoring program to further
    that congressional mandate. We propose to eliminate reporting of
    many categories of information and thereby significantly reduce the
    regulatory burden for carriers, as well as to modify how other
    information is reported so that it will be more useful to consumers
    and to state and federal regulators. We believe this new initiative
    will give consumers more of the tools they need to actively
    participate in a competitive marketplace and give state and federal
    regulators access to data necessary to determine if the service
    quality goals of the 1996 Act are being met. More specifically, our
    goals in initiating this proceeding are three-fold.

2.  First, we propose to eliminate the bulk of the existing service
    quality reporting requirements, which no longer make sense in
    today's marketplace. We must be vigilant to deregulate where
    appropriate, consistent with the 1996 Act. Moreover, section 11 of
    the Communications Act of 1934, as amended (the Communications Act),
    requires that the Commission, in every even-numbered year beginning
    in 1998, review all regulations that apply to the operations and
    activities of any provider of telecommunications service and
    determine whether any of these regulations are no longer necessary
    in the public interest as the result of meaningful economic
    competition between providers of the service.[^3] Consistent with
    that directive, we now undertake a review of our existing service
    quality requirements contained in our Automated Reporting Management
    Information System (ARMIS) [^4] 43-05 Report (Service Quality) and
    ARMIS 43-06 Report (Customer Satisfaction). We propose to reduce our
    reporting requirements from more than 30 categories of information
    down to six.[^5]

3.  Second, we seek to modify our existing reporting requirements to
    better serve our consumer protection goals. Significant marketplace
    changes have occurred since we adopted our current requirements
    in 1991. It is time to assess our service quality monitoring program
    as competition develops in local exchange markets, both in terms of
    who provides such information and what information is provided. The
    reporting program proposed in this Notice of Proposed Rulemaking
    (Notice) would arm consumers with the information that they need to
    make informed decisions. This should, in turn, enhance carriers'
    opportunities to distinguish their products based on quality, and
    motivate carriers to deliver even higher quality, more innovative
    communications services.

4.  Third, we hope to explore alternative ways we can continue to work
    with the states to ensure that consumers enjoy high quality
    telecommunications service throughout the United States. Two years
    ago the National Association of Regulatory Utility Commissioners
    (NARUC) proposed revisions to our current program in a White
    Paper.[^6] Many state commissions are actively involved with service
    quality issues.[^7] Many states also utilize information filed with
    this Commission pursuant to our current service quality reporting
    requirements.[^8]

5.  As we move forward in this area, we must do so in partnership with
    the states. Our basic role in service quality is to serve as an
    efficient clearinghouse for information. Carriers increasingly are
    operating on a national scale. Competitive local exchange carriers
    (CLECs) employ multistate entry strategies, while the largest
    companies are entering markets outside their region. Both the states
    and the Commission need to work together to confront the challenges
    of service quality in a changing marketplace.

6.  We believe that even in a robustly competitive environment, public
    disclosure of quality of service information can be an important way
    to safeguard consumer interests. We are committed to maintaining
    and, when possible, improving the traditionally high level of
    service quality enjoyed by American consumers, in furtherance of the
    1996 Act's mandate. Under our proposed streamlined reporting
    requirements, carriers will report a minimal set of six categories
    of consumer-oriented service quality data to the Commission.
    Although states may, and likely will, continue to impose additional
    service quality reporting and performance requirements on carriers
    operating in their jurisdictions, our proposed national monitoring
    "floor" represents a uniform framework that can serve to minimize
    overall burdens associated with reporting the information. In so
    doing, the proposed minimal national framework operates to provide
    an efficient method of data collection that serves the interests of
    the carriers, consumers, and state and federal regulators alike.

# BACKGROUND

7.  We recognize that "service quality" has many dimensions, including
    customer service, billing practices, and network performance. In
    this Notice, we refer to service quality as data regarding the
    provisioning of telecommunications services, the maintenance and
    repair of telecommunications equipment and facilities, and the
    frequency and duration of various network troubles.[^9]

8.  Our current monitoring program was implemented in 1991 as part of
    our transition to price cap regulation.[^10] The program was adopted
    to ensure that price cap local exchange carriers (LECs) would
    maintain a high level of service quality and to allow for a full
    evaluation of these carriers under price cap regulation.[^11] The
    Commission determined that all mandatory price cap LECs, as well as
    LECs that elect to be covered by price cap regulation, must submit
    quarterly service quality information. LECs for whom price cap
    regulation was mandatory \-- at that time, GTE, Ameritech, Bell
    Atlantic, BellSouth, NYNEX, Pactel, SWB, and US West \-- were also
    required to file annual infrastructure reports. The Commission
    delegated to the Chief of the Common Carrier Bureau (the Bureau)
    authority to establish reporting requirements to capture trends in
    service quality and infrastructure development in the telephone
    industry under price cap regulation. For administrative convenience,
    the service quality reports were integrated into ARMIS, our primary
    tool for regularly collecting financial and operating data from
    incumbent LECs.[^12] The Common Carrier Bureau, working with the
    states, periodically summarizes such information in the Joint Board
    Monitoring Report. Moreover, the Bureau makes available trend
    information on the Commission website.

9.  We note that the Commission adopted service quality reporting
    requirements, but not service quality standards. When the Commission
    adopted service quality reporting requirements, we stated that the
    Bureau and the Commission would revisit the service quality
    reporting issues to modify the reporting requirements as the
    technology and industry change.[^13] The time has come for that
    re-examination.

# DISCUSSION

10. In streamlining our existing service quality reporting requirements,
    we seek to address the needs of carriers, consumers, state public
    utility commissions and other interested parties. Our goal is to
    make available to consumers the service quality information they
    need to make informed choices as competition develops. Service
    quality information is of limited use to consumers if they do not
    have access to comparable information for all carriers in their
    area. Moreover, consumers potentially can choose from a broader
    array of services than ten years ago. As local exchange carriers
    begin to offer advanced services such as xDSL, it is time to
    consider whether consumers would benefit from having access to
    standardized information about the quality of such services as well
    as "Plain Old Telephone Service," or "POTS." We propose to require
    carriers to report fewer categories of service quality data in a
    more consumer-oriented format. We are aware that any new reporting
    requirements must be carefully designed to balance our objectives of
    ensuring that carriers maintain a high level of service quality with
    the need to minimize burdens imposed on carriers. We recognize that
    there may be some ways in which we could streamline reporting
    requirements without reducing the overall regulatory burden on
    carriers. Commenters should address how we can best avoid this
    unintended result. We encourage all interested parties, including
    state, consumer, community, and industry representatives, to
    participate in this proceeding.

**A. Focus on End-User Consumers**

11. As the telecommunications market grows more competitive, the need
    for companies to provide good service to attract and keep customers
    should serve as an incentive to maintain high quality service. Under
    such circumstances, we foresee less of a regulatory role in
    monitoring service quality. Given the relatively early stage of
    development of competition, however, mandating access to limited
    information about service quality may allow consumers to make
    informed choices about their telecommunications service providers.
    As we have recognized in our other recent consumer protection
    proceedings, the effective functioning of competitive markets is
    predicated on consumers having access (whether mandated access or
    access that arises voluntarily) to accurate, meaningful information,
    in a format they can understand.[^14] Information about service
    quality, like price, can and does have an effect on consumer
    purchasing decisions. Moreover, as we move into an era of multiple
    service providers and long-term service contracts, public
    availability of service quality information serves important
    consumer protection functions.[^15] Thus, in revamping our service
    quality reporting program, we seek to collect information that would
    be of the most import to consumers. We seek comment on this
    reasoning.

12. In considering how to revise and streamline our existing service
    quality rules, we find it instructive to consider the airline
    industry reporting program, administered by the Department of
    Transportation (DOT).[^16] In 1987, the DOT established formal
    reporting requirements for U.S. air carriers, in an effort to reduce
    flight delays and growing consumer dissatisfaction with airline
    service.[^17] The current DOT airline reporting program is
    consumer-oriented. Carriers are only required to report information
    that is pertinent to consumers, such as on-time flight performance
    and baggage handling statistics.[^18] The airline program imposes a
    very limited set of reporting requirements. It is also tailored to
    take into account carrier size and market share, requiring mandatory
    reporting for the largest carriers and voluntary for all other
    carriers.

13. We view the quality monitoring program used for the airline industry
    as a potential model for our service quality program. The program
    for the airline industry is predominantly voluntary. The information
    required from the airlines is minimal and well focused on
    measurements that have the greatest importance to consumers. We seek
    comment on whether our service quality program should model itself
    after the airline industry monitoring program.

14. Currently, in the ARMIS 43-05 Service Quality Report, price cap
    incumbent LECs provide information on more than 30 different
    measures of service quality. More specifically, this report
    organizes service quality information into five tables: (1)
    installation and repair intervals for interexchange carriers
    (IXCs);[^19] (2) installation and repair intervals for local service
    customers; (3) trunk blockage; (4) total switch downtime and
    occurrences of two minutes or more duration; and (5) federal and
    state service quality complaints.[^20] In the ARMIS 43-06 Customer
    Satisfaction Survey, carriers report information concerning the
    number of dissatisfied customers as determined in customer
    satisfaction surveys. This information is publicly available on our
    website. Thus, while consumers have been technically able to monitor
    trends using this information, much of it is technical in nature and
    may not be easily translated by consumers.

15. Accordingly, we propose to eliminate most of the current categories,
    and limit reporting to the areas that we believe are of particular
    interest to consumers.[^21] We note that in the course of
    discussions leading up to our Notice of Proposed Rulemaking in Phase
    2 of the Comprehensive Review of Accounting and Reporting
    Requirements,[^22] the United States Telecom Association (USTA) has
    proposed that, with minor modifications, the installation and repair
    portion of the NARUC White Paper be implemented as a revised ARMIS
    43-05, which is similar to the proposal set forth here.[^23] Our
    intent is to provide customers with relevant information about
    services that are of particular interest to them, not to increase
    our reporting requirements. We seek comment on the following
    proposals and encourage commenters to propose any alternatives they
    deem appropriate.

## Categories of Performance Data

16. As described below, we propose to continue reporting obligations for
    six categories of service quality information that we believe are
    relevant and important to consumers. At the most simplistic level,
    we think that what consumers care about is whether they can get
    service when they want it, and whether that service works. For that
    reason, we propose to retain reporting for the following
    measures: (1) the percentage of installation appointments that are
    missed; (2) the time it takes to install service; (3) the percentage
    of lines that have problems, including out of service lines; (4) the
    time it takes to have out of service lines repaired; (5) the
    percentage of repair appointments that are missed; and (6) the time
    it takes to repair service.

## 1. Missed Installations  {#missed-installations .unnumbered}

17. A missed installation occurs when service is not provided on or
    before the date and time of the commitment with the customer. [^24]
    Failing to appear on time for an installation appointment wastes
    consumers' time and results in slower, less efficient installation
    service. Information on missed installation commitments could help
    consumers evaluate a carrier's ability to deliver on its promise to
    install service on time. Data regarding the installation of services
    allow federal and state regulators, and consumers, to evaluate the
    adequacy of the carrier\'s telephone plant facilities and workforce,
    and the carrier\'s success at meeting customer expectations and
    their own commitments. We propose that carriers continue to report
    the number of missed installation commitments and the total number
    of installations that occur during the reporting period. Through
    these two numbers a percentage can be generated that can permit
    appropriate comparisons among companies by consumers. We seek
    comment on this proposal.

## 2. Installation Intervals {#installation-intervals .unnumbered}

18. Under our current ARMIS program, price cap incumbent LECs report the
    average time to complete an installation. We believe we should
    continue the reporting of installation time because consumers should
    know how long it is likely to take a particular carrier to provide
    service. We also seek comment, however, on whether we should measure
    installation intervals in a different way. An average completion
    time may not provide an accurate picture to consumers because
    outliers may skew the reported data. We seek comment on whether
    carriers should report the number of installation orders for service
    completed within a specified number of days, such as five working
    days, instead of the current average interval, and the total number
    of installation orders.

### **3. Trouble Reports** {#trouble-reports .unnumbered}

19. A "trouble" is an impairment on a customer's line. A trouble report
    is the record of when the repair office receives notification of a
    trouble. Under our existing ARMIS requirements, carriers are
    required to report the number of initial trouble reports and repeat
    trouble reports broken down into multiple subcategories.[^25] An
    initial trouble report is the first trouble report on a line. A
    repeat trouble report is a report on a trouble within 30 days after
    the initial report on that trouble has been resolved. While repeat
    and subsequent trouble information is useful as a diagnostic tool to
    regulators, multiple categories of different repair information may
    be confusing to the average consumer. We seek comment on whether
    carriers should report only the number of initial trouble reports
    and number of out-of-service troubles occurring within the reporting
    period, as well as the total number of access lines.

## 4. Out-of-Service Troubles {#out-of-service-troubles .unnumbered}

20. An out-of-service trouble means that a consumer cannot make or
    receive calls. In addition to the inconvenience and potential
    financial impact of such an outage, this also raises safety concerns
    because the consumer cannot make 911 emergency calls. Under our
    current ARMIS requirements carriers report average intervals for
    out-of-service troubles, as well as intervals for all other trouble
    reports. We believe consumers are more likely to care how long their
    telephone is out of service than, for instance, how long it takes to
    repair static on the line. We propose streamlining our current
    requirement to collect only information on average intervals for
    out-of-service troubles. We seek comment on this proposal.

## 5. Missed Repair Appointments {#missed-repair-appointments .unnumbered}

21. Accurate reported data about the repair of service will allow the
    Commission, state commissions, and consumer groups to evaluate the
    adequacy of a carrier's telephone plant facilities and workforce,
    and determine whether consumers are receiving corrective action when
    problems arise. Under our current ARMIS requirements, carriers only
    report repair intervals, but not whether they keep commitments to
    the customer. A missed repair commitment occurs when a customer
    trouble is not repaired on or before the date and time commitment
    with the customer. The number of missed repair commitments should
    have a direct impact on consumers who are waiting for service
    problems to be fixed. We propose that carriers report the number of
    missed repair commitments, and the total number of repair
    commitments. We seek comment on this proposal.

## Repair Intervals

22. Under our current ARMIS program, price cap incumbent LECs report the
    average time for repairs. We propose to continue measuring repair
    intervals and seek comment whether we should require an average or
    some other measure.

## Other Types of Information

23. We ask commenters whether there are other types of service quality
    information that consumers would find useful, and if so, what are
    the benefits, burdens and feasibility of requiring carriers to
    collect and disclose such information. For instance, we seek comment
    on whether carriers should report the length of time customers wait
    on hold before speaking to a customer service representative and the
    length of time a customer has to wait for a call back from a
    carrier. Commenters should discuss how carriers would collect this
    information. For all additional proposals, commenters should discuss
    how the measure should be defined, if adopted.

## Definitions

24. Our current ARMIS program provides basic definitions and
    instructions for the reporting the various service quality
    measurements.[^26] We seek comment on whether we need to specify
    with more particularity the definitions and business rules for the
    measures that we propose to retain, so that comparisons between
    carriers will be accurate and meaningful.[^27] We seek comment, for
    instance, on the definitions contained in the NARUC White Paper.

## C. Broadband Services {#c.-broadband-services .unnumbered}

25. The deployment of new technologies and new services is a matter of
    particular interest to the Commission. In the *Local Competition and
    Broadband Data Gathering Program*, we are undertaking efforts to
    better understand the provision of these services.[^28] The data
    collected through the *Local Competition and Broadband Data
    Gathering Program*, however, does not provide information on service
    quality for broadband services.[^29] Instead, the objective of the
    *Local Competition and Broadband Data Gathering Program* is to
    provide the Commission with information on local competition and the
    deployment of broadband in the United States. We are not aware of
    any systematic source of service quality information on xDSL or
    other advanced services.

26. Our current ARMIS reporting requirements only collect information
    about service quality for basic voice telephony (*e.g.,* POTS). We
    seek comment on whether to gather information and report about
    service quality in the provision of broadband and other advanced
    services.[^30] Commenters should discuss the services about which we
    should seek service quality information. We have received consumer
    complaints suggesting, for instance, that the process of initiating
    xDSL service can be time consuming. We seek comment on what
    information in this area consumers would find useful, and what are
    the costs and benefits of adding any new reporting requirements in
    this area. Our goal is to adapt our existing program to reflect a
    changing marketplace, without unduly burdening carriers with new
    requirements.

## D. Disaggregation of Information  {#d.-disaggregation-of-information .unnumbered}

27. Currently, carriers that file ARMIS Report 43-05 are required to
    report installation and repair information separately for business
    and residential customers. We propose to maintain this aspect of our
    reporting requirements. A review of data filed to date shows
    different quality of service performance in the residential market
    and business markets. Accordingly, we seek comment on maintaining
    this disaggregation. Permitting carriers to aggregate business and
    residential customers into one class could provide a misleading
    picture of the carrier's performance with respect to each group of
    customers.

28. To depict a carrier's service quality in urban and rural areas, the
    current ARMIS service quality reports disaggregate information into
    results in "Metropolitan Statistical Areas" (MSAs) and
    "Non-Metropolitan Statistical Areas" (Non-MSAs). USTA proposes that
    we no longer require carriers to disaggregate data into MSA and
    non-MSA categories.[^31] USTA argues that a review of data filed to
    date in ARMIS shows no significant variance in performance for MSA
    and non-MSA areas. We seek comment on this proposal.

## E. Types of Reporting Entities {#e.-types-of-reporting-entities .unnumbered}

29. Currently, only price cap LECs file the ARMIS 43-05 and 43-06
    reports. We do not collect service quality data from small incumbent
    LECs, including those serving rural areas, nor do we collect this
    data from competitive LECs (CLECs). The NARUC White Paper concludes
    that service quality data would be more meaningful for all
    interested parties, including consumers and state commissions, if
    all LECs \-- including CLECs \-- reported such data. We believe that
    if consumers had access to service quality data from all carriers
    providing local exchange service in their area, they would be in a
    better position to make an informed choice between, or among,
    carriers. We seek comment on the benefits and costs of imposing
    these new reduced service quality reporting requirements on a
    broader class of carriers than currently are subject to the more
    numerous requirements so that consumers may compare service quality
    of competing carriers. Commenters should discuss whether marketplace
    forces alone are likely to adequately provide incentives to
    competitors to incumbent LECs to disclose voluntarily information
    about service quality, and whether certain entities could be exempt
    from service quality reporting requirements without compromising our
    consumer protection objectives in this proceeding.[^32] Commenters
    also should address how imposition of these requirements on CLECs
    and smaller LECs fits into our traditional regulatory treatment of
    these entities, many of which may not have encountered regulatory
    burdens of this nature at the federal level. We are seeking to
    balance the consumer's need for information with the reporting
    burden on the industry. Furthermore, we are particularly mindful of
    the cost of collecting information, particularly on small carriers,
    and we are intent on minimizing such costs.

30. We seek comment on whether a viable alternative would be voluntary
    service quality reporting procedures for certain carriers. [^33] Our
    service quality program could, for example, establish mandatory
    service quality reporting for incumbent LECs exceeding a threshold
    of lines served, such as two percent of the nation's access
    lines,[^34] or annual revenue, and allow voluntary service quality
    reports for all other carriers, including CLECs. The voluntary
    reports would have to be in the same format and use the same
    definitions as the required reports to facilitate comparisons
    between carriers. In addition, the data in the voluntary reports
    would need to be reported with the same frequency required in the
    mandatory reports, to facilitate useful comparisons by consumers.

31. We seek comment on whether carriers should be relieved of all
    mandatory reporting under certain circumstances, and if so, when.
    For instance, we seek comment on whether a carrier should be
    relieved of any federal reporting obligation, if there are few or no
    service quality complaints relating to that carrier pending before a
    state commission, or if its performance meets a specified benchmark
    for a period of time. Such an approach, in essence, would relieve
    carriers of reporting obligations for good behavior, while enabling
    consumers to learn of problems in carrier performance. If we were to
    adopt such an approach, we seek comment on what the appropriate
    benchmarks should be.

32. We note that resellers and competitors that purchase network
    elements from an incumbent LEC may have no control over the service
    quality of the resold service or the purchased elements, which may
    impact their service to retail customers. Commenters should discuss
    how, if voluntary or mandatory reporting were extended to a broader
    class of carriers, service quality measures could take into account
    problems due to the conduct of the incumbent so that consumers would
    receive an accurate picture of the service quality provided by
    different carriers.[^35] Commenters should address the costs and
    benefits of adding any new reporting requirements in this area.

## F. Frequency of Reporting {#f.-frequency-of-reporting .unnumbered}

33. Currently, carriers subject to ARMIS 43-05 file such reports on an
    annual basis. In the 1996 Act, Congress required that ARMIS data be
    filed only on an annual basis.[^36] NARUC's Service Quality White
    Paper proposes that we gather service quality information on a
    quarterly basis. We seek comment on whether, in light of the greatly
    reduced amount of information being collected, it would better serve
    our consumer protection goals to collect service quality information
    more frequently than yearly, and how we might accomplish that
    mission. We seek comment on the burdens associated with increasing
    the reporting frequency and whether such burdens are outweighed by
    the incremental benefit to consumers.

34. Individual states may require more frequent service quality
    reporting, *e.g.*, quarterly. We seek comment on whether we should
    act as a federal clearinghouse for information gathered at the state
    level. We seek input from the states on whether they would be able
    to transmit to us whatever service quality information they collect
    on a more frequent basis. We also seek comment on whether variations
    in state reporting requirements would make it difficult to integrate
    such information into a unified national database.

35. Another alternative would be for carriers to file information in
    ARMIS on a yearly basis, but post service quality information on
    their own website on a more frequent basis. We seek comment on these
    proposals and any other proposals that would facilitate consumer
    access to service quality information on a more timely basis.

## G. Public Disclosure of Service Quality Data {#g.-public-disclosure-of-service-quality-data .unnumbered}

36. Service quality information can enable consumers to compare carriers
    in their area and make informed choices between, or among, carriers.
    We seek comment on whether an effective method of publicizing
    service quality data would be for carriers to post service quality
    data on their web sites. This data would be accessible to the
    general public, as well as to state commissions and other interested
    parties. We propose that carriers would continue to file the service
    quality reports with the Commission as well, which would continue to
    be a central clearinghouse for service quality data.[^37] We note
    that because carriers are required to report accurate information to
    the Commission,[^38] and the Commission can require carriers to
    correct inaccurate data, collecting information at the federal level
    provides some ability to ensure that the information is accurate,
    which ultimately benefits consumers. We seek comment on whether
    carriers should be required to post on their website the number of
    complaints pending before the FCC and state commission, and the
    number of issues raised before federal or state regulators that have
    been referred to the carrier for further investigation and action.
    In addition, we seek comment on whether other public disclosure
    methods should be available for those without access to the
    Internet.

37. We also seek comment on whether there are other public sources for
    service quality information. In particular, we ask the states to
    inform us of the extent to which they collect service quality
    information, and whether that information is publicly accessible. We
    seek comment on whether we should rely on state collected
    information, to the extent that states require carriers to report
    service quality information.

## H. Record Retention {#h.-record-retention .unnumbered}

38. Carriers that currently file ARMIS 43-05 data must retain the data
    for four years. We seek comment on how long the underlying data used
    to develop service quality reports should be retained and made
    available for inspection upon request to the Commission and state
    regulators. NARUC proposes, for instance, that the underlying data
    be retained for two years.

## I. Elimination of Other Reporting Requirements {#i.-elimination-of-other-reporting-requirements .unnumbered}

### **1. Interexchange Carriers** {#interexchange-carriers .unnumbered}

39. In Table I of the ARMIS Report 43-05 Service Quality Report, we
    currently collect information from price cap incumbent LECs about
    the installation and repair of access services provided to
    interexchange carriers. In Table III of the same report, price cap
    carriers provide information about common trunk group blockage. We
    seek comment on whether we should eliminate these categories of
    information from our service quality reporting program. This
    information reports the quality of service performed by incumbent
    LECs to interexchange carriers. We seek comment on whether IXCs are
    able to monitor service quality through operation of their business
    relationships with the incumbent local exchange carriers. Unlike
    residential and small business consumers, IXCs often have good
    bargaining positions when purchasing services from incumbent LECs
    because they purchase large volumes of telecommunications services
    on an individual basis.[^39] IXCs also are more likely to possess
    the analytical expertise and resources needed to protect themselves
    against service quality degradation. In addition, IXCs may have an
    independent ability to monitor service quality and have a vast
    amount of technical data at their disposal. In fact, we understand
    that, at least in some cases, IXCs provide each other the relevant
    service quality data without the need for regulatory involvement. We
    seek comment on whether revising our service quality reporting
    requirements to focus on categories of service quality data that are
    meaningful to end-user consumers is the more appropriate continuing
    regulatory focus. We therefore seek comment on whether this
    information \-- the service quality that LECs provide to IXCs \--
    should be eliminated from our service quality reporting
    requirements.

## 2. Network Reliability and Interoperability Council {#network-reliability-and-interoperability-council .unnumbered}

40. The Network Reliability and Interoperability Council (NRIC) was
    established by the FCC to bring together leaders of the
    telecommunications industry with academic and consumer organizations
    to explore and recommend measures that would enhance network
    reliability. Following the 1996 Act, the NRIC was charged with
    analyzing network and interconnectivity issues raised by Section 256
    of the Act.[^40] Carriers currently report in ARMIS 43-05, Table IV,
    the number of switches serving specified numbers of lines and the
    number of times switches are down from two minutes or longer. The
    number and duration of switch outages and interoffice transmission
    facility outages indicates the carrier\'s performance in providing
    continual access to the full capabilities and benefits of the
    network. This data has been gathered in ARMIS as a complement to
    information collected on large switches by the Network Reliability
    Council. Together this information has permitted regulators to
    monitor and assess network reliability, which is important to
    consumers because such outages affect service in their area. We seek
    comment on whether we should continue to collect the information
    contained in Table IV of ARMIS Report 43-05. We also seek comment on
    whether competitive pressures to achieve network reliability in
    today's marketplace have sufficiently replaced the need for
    reporting of network reliability data.

## 3. Complaints to Federal and State Commissions  {#complaints-to-federal-and-state-commissions .unnumbered}

41. Price cap incumbent LECs currently report to us, as part of ARMIS,
    the number of customer complaints made to federal and state
    regulators. We believe that this measure continues to be an
    important source of information for consumers in making carrier
    selections as well as an effective consumer protection tool. In this
    proceeding, we seek to reduce carrier reporting obligations if there
    is an alternative way we can obtain such information. We have access
    to the number of carrier complaints currently pending at the FCC. If
    carriers are required to post federal and state complaint
    information on their websites,[^41] however, would there be an
    additional regulatory burden for them to submit such information to
    the Commission as part of ARMIS? We seek comment on the feasibility
    of our obtaining state complaint information directly from the
    states, rather than from the carriers. We seek comment on the
    benefits and burdens of requiring companies to continue to file FCC
    and state complaint information as part of ARMIS. In addition, we
    seek comment on whether carriers should be required to report the
    number of complaints they receive directly from consumers.

## 4. Customer Satisfaction Survey {#customer-satisfaction-survey .unnumbered}

42. Price cap LECs currently are required to conduct a survey of their
    customers' satisfaction and report the results of that survey in
    ARMIS Report 43-06. We propose to eliminate this requirement. Actual
    complaint information may be a better indicator of trends in service
    quality than a telephone consumer survey. We seek comment on this
    proposal.

## 5. All Other Reporting Requirements {#all-other-reporting-requirements .unnumbered}

43. As discussed above, we propose to streamline our service quality
    reporting requirements to six core reporting categories, while
    eliminating all other reporting categories contained in ARMIS
    Service Quality Reports 43-05 and 43-06. We believe that
    streamlining our service quality reporting program to six
    requirements will allow us to fulfill our consumer protection goals,
    while reducing administrative burden on carriers that are currently
    required to file this information. We seek comment on the costs and
    benefits of eliminating this information from our service quality
    reporting program.

## J. NARUC White Paper  {#j.-naruc-white-paper .unnumbered}

44. The NARUC White Paper contains additional proposals for refining our
    service quality monitoring program. These include more detailed
    measurements related to maintenance and repair intervals, answer
    time performance, and network performance.[^42] The White Paper also
    proposes that the reports be made available to the public to allow
    interested parties to assess the data, and to provide consumers with
    information about their telecommunications carriers. We seek comment
    on the proposals in NARUC's White Paper.

# CONCLUSION

45. We are committed to improving the Commission's service quality
    monitoring program to give consumers the ability to compare the
    service quality of competing carriers. At the same time, we intend
    to limit the reporting burden on carriers by reducing the categories
    of reported data. By making available timely and reliable service
    quality data, we hope to meet the needs of consumers as competition
    grows in the local exchange marketplace. In various contexts, we
    have recognized the importance of information for a market to
    function efficiently.[^43] If consumers receive only limited
    information, the market will not function efficiently and consumers
    likely will not receive the quality they prefer.[^44] We hope to
    facilitate market efficiency by ensuring that consumers have the
    information they need to make informed buying decisions.

# PROCEDURAL MATTERS

## A. Ex Parte Presentations {#a.-ex-parte-presentations .unnumbered}

46. This is a \"permit-but-disclose\" rulemaking proceeding subject to
    the \"permit-but-disclose\" requirements under section 1.1206 of the
    Commission\'s rules, as revised.[^45] Additional rules pertaining to
    oral and written presentations are set forth in section 1.1206.

##  {#section .unnumbered}

## B. Initial Regulatory Flexibility Act Analysis {#b.-initial-regulatory-flexibility-act-analysis .unnumbered}

47. As required by the Regulatory Flexibility Act (RFA),[^46] the
    Commission has prepared an Initial Regulatory Flexibility Analysis
    (IRFA) of the possible significant economic impact on small entities
    of the policies and rules proposed in this Notice. The IRFA is set
    forth as Appendix D. Written public comments are requested with
    respect to the IRFA. These comments must be filed in accordance with
    the same filing deadlines for comments on the rest of this Notice
    and they must have a separate and distinct heading, designating the
    comments as responses to the IRFA.

## C. Initial Paperwork Reduction Act Analysis {#c.-initial-paperwork-reduction-act-analysis .unnumbered}

48. This Notice contains either a proposed or modified information
    collection. As part of our continuing effort to reduce paperwork
    burdens, we invite the general public to take this opportunity to
    comment on the information collections contained in this Notice,
    pursuant to the Paperwork Reduction Act of 1995, Pub. L. No. 104-13.
    Public and agency comments are due at the same time as other
    comments on this Notice. Comments should address: (a) whether the
    proposed collection of information is necessary for the proper
    performance of the functions of the Commission, including whether
    the information shall have practical utility; (b) the accuracy of
    the Commission\'s burden estimates; (c) ways to enhance the quality,
    utility, and clarity of the information collected; and (d) ways to
    minimize the burden of collection of information on respondents,
    including the use of automated collection techniques or other forms
    of information technology.

## D. Comment Filing Procedures {#d.-comment-filing-procedures .unnumbered}

D.  

```{=html}
<!-- -->
```
49. Pursuant to sections 1.415 and 1.419 of the Commission\'s rules, 47
    C.F.R. §§ 1.415, 1.419, interested parties may file comments on or
    before January 12, 2001 and reply comments on or before February
    16, 2001. Comments may be filed using the Commission\'s Electronic
    Comment Filing System (ECFS) or by filing paper copies.

50. Comments filed through the ECFS can be sent as an electronic file
    via the Internet to \<http://www.fcc.gov/e-file/ecfs.html\>.
    Generally, only one copy of an electronic submission must be filed.
    If multiple docket or rulemaking numbers appear in the caption of
    this proceeding, however, commenters must transmit one electronic
    copy of the comments to each docket or rulemaking number referenced
    in the caption. In completing the transmittal screen, commenters
    should include their full name, Postal Service mailing address, and
    the applicable docket or rulemaking number. Parties may also submit
    an electronic comment by Internet e-mail. To get filing instructions
    for e-mail comments, commenters should send an e-mail to
    ecfs@fcc.gov, and should include the following words in the body of
    the message, \"get form \<your e-mail address\>.\" A sample form and
    directions will be sent in reply.

51. Parties who choose to file by paper must file an original and four
    copies of each filing. If participants want each Commissioner to
    receive a personal copy of their comments, an original plus nine
    copies must be filed. If more than one docket or rulemaking number
    appear in the caption of this proceeding, commenters must submit two
    additional copies for each additional docket or rulemaking number.
    All filings by paper must be sent to the Commission\'s Secretary:
    Magalie Roman Salas, Office of the Secretary, Federal Communications
    Commission, 445 12th Street, S.W., Washington, D.C. 20554.

52. Parties who choose to file by paper should also submit their
    comments on diskette. Diskettes should be submitted to: Ernestine
    Creech, Accounting Safeguards Division, Federal Communications
    Commission, 445 12th Street, S.W., Washington, D.C. 20554. The
    required diskette copies of submissions should be on 3.5 inch
    diskettes formatted in an IBM compatible format using Word or
    compatible software. Each diskette should be accompanied by a cover
    letter and should be submitted in \"read only\" mode. The diskette
    should be clearly labeled with the commenter\'s name, proceeding (CC
    Docket No. 00-229), type of pleading (comment or reply comment),
    date of submission, and the name of the electronic file on the
    diskette. The label should also include the following phrase \"Disk
    Copy - Not an Original.\" Each diskette should contain only one
    party\'s pleadings, preferably in a single electronic file. In
    addition, parties who choose to file by paper must send diskette
    copies to the Commission\'s copy contractor, International
    Transcription Service, Inc., 1231 20th Street, N.W., Washington,
    D.C. 20036. Comments and reply comments will be available for public
    inspection during normal business hours in the FCC Reference
    Information Center, Courtyard Level, Suite CY-A257, 445 12th Street,
    S.W., Washington, D.C.

53. Written comments by the public on the proposed and/or modified
    information collections are due thirty days after date of
    publication in the Federal Register. Written comments must be
    submitted by the Office of Management and Budget (OMB) on the
    proposed and/or modified information collections on or before 60
    days after date of publication in the Federal Register. In addition
    to filing comments with the Secretary, a copy of any comments on the
    information collections contained herein should be submitted to Judy
    Boley, Federal Communications Commission, Room 1-C804, 445 12th
    Street, S.W., Washington, D.C. 20554, or via the Internet to
    jboley@fcc.gov and to Edward Springer, OMB Desk Officer, 10236 NEOB,
    725 - 17th Street, N.W., Washington, D.C. 20503.

# ORDERING CLAUSES

54. Accordingly, IT IS ORDERED that, pursuant to the authority contained
    in sections 4(i), 4(j), 201(b), 303(r), and 403 of the
    Communications Act of 1934, as amended, 47 U.S.C. §§ 154(i), 154(j),
    201(b), 303(r), and 403, this NOTICE OF PROPOSED RULEMAKING is
    hereby ADOPTED.

55. IT IS FURTHER ORDERED that the Commission\'s Consumer Information
    Bureau, Reference Information Center, SHALL SEND a copy of this
    NOTICE OF PROPOSED RULEMAKING, including the Initial Regulatory
    Flexibility Analysis, to the Chief Counsel for Advocacy of the Small
    Business Administration.

> FEDERAL COMMUNICATIONS COMMISSION
>
> Magalie Roman Salas
>
> Secretary

**APPENDIX A**

CURRENT ARMIS REQUIREMENTS

+----+----------------------+---+-------------+---+-------------+---+-------------+
| F  |                      |   |             |   |             |   |             |
| CC |                      |   |             |   |             |   |             |
| Re |                      |   |             |   |             |   |             |
| po |                      |   |             |   |             |   |             |
| rt |                      |   |             |   |             |   |             |
| 4  |                      |   |             |   |             |   |             |
| 3- |                      |   |             |   |             |   |             |
| 05 |                      |   |             |   |             |   |             |
|    |                      |   |             |   |             |   |             |
| A  |                      |   |             |   |             |   |             |
| RM |                      |   |             |   |             |   |             |
| IS |                      |   |             |   |             |   |             |
| S  |                      |   |             |   |             |   |             |
| ER |                      |   |             |   |             |   |             |
| VI |                      |   |             |   |             |   |             |
| CE |                      |   |             |   |             |   |             |
| Q  |                      |   |             |   |             |   |             |
| UA |                      |   |             |   |             |   |             |
| LI |                      |   |             |   |             |   |             |
| TY |                      |   |             |   |             |   |             |
| RE |                      |   |             |   |             |   |             |
| PO |                      |   |             |   |             |   |             |
| RT |                      |   |             |   |             |   |             |
|    |                      |   |             |   |             |   |             |
| CO |                      |   |             |   |             |   |             |
| MP |                      |   |             |   |             |   |             |
| AN |                      |   |             |   |             |   |             |
| Y: |                      |   |             |   |             |   |             |
| XX |                      |   |             |   |             |   |             |
| XX |                      |   |             |   |             |   |             |
| XX |                      |   |             |   |             |   |             |
| XX |                      |   |             |   |             |   |             |
| XX |                      |   |             |   |             |   |             |
| XX |                      |   |             |   |             |   |             |
| XX |                      |   |             |   |             |   |             |
| XX |                      |   |             |   |             |   |             |
| XX |                      |   |             |   |             |   |             |
| V  |                      |   |             |   |             |   |             |
| er |                      |   |             |   |             |   |             |
| si |                      |   |             |   |             |   |             |
| on |                      |   |             |   |             |   |             |
|    |                      |   |             |   |             |   |             |
| S  |                      |   |             |   |             |   |             |
| TU |                      |   |             |   |             |   |             |
| DY |                      |   |             |   |             |   |             |
| A  |                      |   |             |   |             |   |             |
| RE |                      |   |             |   |             |   |             |
| A: |                      |   |             |   |             |   |             |
| XX |                      |   |             |   |             |   |             |
| XX |                      |   |             |   |             |   |             |
| XX |                      |   |             |   |             |   |             |
| XX |                      |   |             |   |             |   |             |
| XX |                      |   |             |   |             |   |             |
| XX |                      |   |             |   |             |   |             |
| Su |                      |   |             |   |             |   |             |
| bm |                      |   |             |   |             |   |             |
| is |                      |   |             |   |             |   |             |
| si |                      |   |             |   |             |   |             |
| on |                      |   |             |   |             |   |             |
| X  |                      |   |             |   |             |   |             |
| XX |                      |   |             |   |             |   |             |
|    |                      |   |             |   |             |   |             |
| P  |                      |   |             |   |             |   |             |
| ER |                      |   |             |   |             |   |             |
| IO |                      |   |             |   |             |   |             |
| D: |                      |   |             |   |             |   |             |
| Fr |                      |   |             |   |             |   |             |
| om |                      |   |             |   |             |   |             |
| m  |                      |   |             |   |             |   |             |
| mm |                      |   |             |   |             |   |             |
| yy |                      |   |             |   |             |   |             |
| yy |                      |   |             |   |             |   |             |
| To |                      |   |             |   |             |   |             |
| m  |                      |   |             |   |             |   |             |
| mm |                      |   |             |   |             |   |             |
| yy |                      |   |             |   |             |   |             |
| yy |                      |   |             |   |             |   |             |
| T  |                      |   |             |   |             |   |             |
| AB |                      |   |             |   |             |   |             |
| LE |                      |   |             |   |             |   |             |
| I  |                      |   |             |   |             |   |             |
|    |                      |   |             |   |             |   |             |
| C  |                      |   |             |   |             |   |             |
| OS |                      |   |             |   |             |   |             |
| A: |                      |   |             |   |             |   |             |
| XX |                      |   |             |   |             |   |             |
| XX |                      |   |             |   |             |   |             |
| PA |                      |   |             |   |             |   |             |
| GE |                      |   |             |   |             |   |             |
| 1  |                      |   |             |   |             |   |             |
| OF |                      |   |             |   |             |   |             |
| 1  |                      |   |             |   |             |   |             |
+----+----------------------+---+-------------+---+-------------+---+-------------+
| *  |                      |   |             |   |             |   |             |
| *T |                      |   |             |   |             |   |             |
| AB |                      |   |             |   |             |   |             |
| LE |                      |   |             |   |             |   |             |
| I  |                      |   |             |   |             |   |             |
| -- |                      |   |             |   |             |   |             |
| IN |                      |   |             |   |             |   |             |
| ST |                      |   |             |   |             |   |             |
| AL |                      |   |             |   |             |   |             |
| LA |                      |   |             |   |             |   |             |
| TI |                      |   |             |   |             |   |             |
| ON |                      |   |             |   |             |   |             |
| A  |                      |   |             |   |             |   |             |
| ND |                      |   |             |   |             |   |             |
| RE |                      |   |             |   |             |   |             |
| PA |                      |   |             |   |             |   |             |
| IR |                      |   |             |   |             |   |             |
| I  |                      |   |             |   |             |   |             |
| NT |                      |   |             |   |             |   |             |
| ER |                      |   |             |   |             |   |             |
| VA |                      |   |             |   |             |   |             |
| LS |                      |   |             |   |             |   |             |
| ** |                      |   |             |   |             |   |             |
|    |                      |   |             |   |             |   |             |
| ** |                      |   |             |   |             |   |             |
| (I |                      |   |             |   |             |   |             |
| nt |                      |   |             |   |             |   |             |
| er |                      |   |             |   |             |   |             |
| ex |                      |   |             |   |             |   |             |
| ch |                      |   |             |   |             |   |             |
| an |                      |   |             |   |             |   |             |
| ge |                      |   |             |   |             |   |             |
| A  |                      |   |             |   |             |   |             |
| cc |                      |   |             |   |             |   |             |
| es |                      |   |             |   |             |   |             |
| s) |                      |   |             |   |             |   |             |
| ** |                      |   |             |   |             |   |             |
+----+----------------------+---+-------------+---+-------------+---+-------------+
| R  | CLASSIFICATION       | C |             |   |             |   |             |
| OW |                      | O |             |   |             |   |             |
|    |                      | L |             |   |             |   |             |
|    |                      | U |             |   |             |   |             |
|    |                      | M |             |   |             |   |             |
|    |                      | N |             |   |             |   |             |
+----+----------------------+---+-------------+---+-------------+---+-------------+
|    |                      | S |             | S |             |   |             |
|    |                      | w |             | p |             |   |             |
|    |                      | i |             | e |             |   |             |
|    |                      | t |             | c |             |   |             |
|    |                      | c |             | i |             |   |             |
|    |                      | h |             | a |             |   |             |
|    |                      | e |             | l |             |   |             |
|    |                      | d |             | A |             |   |             |
|    |                      | A |             | c |             |   |             |
|    |                      | c |             | c |             |   |             |
|    |                      | c |             | e |             |   |             |
|    |                      | e |             | s |             |   |             |
|    |                      | s |             | s |             |   |             |
|    |                      | s |             |   |             |   |             |
+----+----------------------+---+-------------+---+-------------+---+-------------+
|    |                      |   |             | H |             | A |             |
|    |                      |   |             | i |             | l |             |
|    |                      |   |             | g |             | l |             |
|    |                      |   |             | h |             |   |             |
|    |                      |   |             | S |             | S |             |
|    |                      |   |             | p |             | p |             |
|    |                      |   |             | e |             | e |             |
|    |                      |   |             | e |             | c |             |
|    |                      |   |             | d |             | i |             |
|    |                      |   |             |   |             | a |             |
|    |                      |   |             | S |             | l |             |
|    |                      |   |             | p |             | A |             |
|    |                      |   |             | e |             | c |             |
|    |                      |   |             | c |             | c |             |
|    |                      |   |             | i |             | e |             |
|    |                      |   |             | a |             | s |             |
|    |                      |   |             | l |             | s |             |
|    |                      |   |             | A |             |   |             |
|    |                      |   |             | c |             |   |             |
|    |                      |   |             | c |             |   |             |
|    |                      |   |             | e |             |   |             |
|    |                      |   |             | s |             |   |             |
|    |                      |   |             | s |             |   |             |
+----+----------------------+---+-------------+---+-------------+---+-------------+
|    |                      | ( |             | ( |             | ( |             |
|    |                      | a |             | a |             | a |             |
|    |                      | a |             | b |             | c |             |
|    |                      | ) |             | ) |             | ) |             |
+----+----------------------+---+-------------+---+-------------+---+-------------+
| IN |                      |   |             |   |             |   |             |
| ST |                      |   |             |   |             |   |             |
| AL |                      |   |             |   |             |   |             |
| LA |                      |   |             |   |             |   |             |
| TI |                      |   |             |   |             |   |             |
| ON |                      |   |             |   |             |   |             |
| IN |                      |   |             |   |             |   |             |
| TE |                      |   |             |   |             |   |             |
| RV |                      |   |             |   |             |   |             |
| AL |                      |   |             |   |             |   |             |
| S: |                      |   |             |   |             |   |             |
+----+----------------------+---+-------------+---+-------------+---+-------------+
| 01 | \# Total Number of   |   |             |   | N/A         |   |             |
| 10 | Orders or Circuits   |   |             |   |             |   |             |
+----+----------------------+---+-------------+---+-------------+---+-------------+
| 01 | \# Missed for        |   |             |   | N/A         |   |             |
| 11 | Customer Reasons     |   |             |   |             |   |             |
|    | (MCR)                |   |             |   |             |   |             |
+----+----------------------+---+-------------+---+-------------+---+-------------+
| 01 | \% Commitments Met   |   |             |   | N/A         |   |             |
| 12 |                      |   |             |   |             |   |             |
+----+----------------------+---+-------------+---+-------------+---+-------------+
| 01 | Average Interval (in |   |             |   | N/A         |   |             |
| 14 | days)                |   |             |   |             |   |             |
+----+----------------------+---+-------------+---+-------------+---+-------------+
| RE |                      |   |             |   |             |   |             |
| PA |                      |   |             |   |             |   |             |
| IR |                      |   |             |   |             |   |             |
| IN |                      |   |             |   |             |   |             |
| TE |                      |   |             |   |             |   |             |
| RV |                      |   |             |   |             |   |             |
| AL |                      |   |             |   |             |   |             |
| S: |                      |   |             |   |             |   |             |
+----+----------------------+---+-------------+---+-------------+---+-------------+
| 01 | \# Total Trouble     |   |             |   |             |   |             |
| 20 | Reports              |   |             |   |             |   |             |
+----+----------------------+---+-------------+---+-------------+---+-------------+
| 01 | Average Interval (in |   |             |   |             |   |             |
| 21 | hours)               |   |             |   |             |   |             |
+----+----------------------+---+-------------+---+-------------+---+-------------+
| *  |                      |   |             |   |             |   |             |
| *L |                      |   |             |   |             |   |             |
| eg |                      |   |             |   |             |   |             |
| en |                      |   |             |   |             |   |             |
| d: |                      |   |             |   |             |   |             |
| ** |                      |   |             |   |             |   |             |
|    |                      |   |             |   |             |   |             |
| \# |                      |   |             |   |             |   |             |
| i  |                      |   |             |   |             |   |             |
| nd |                      |   |             |   |             |   |             |
| ic |                      |   |             |   |             |   |             |
| at |                      |   |             |   |             |   |             |
| es |                      |   |             |   |             |   |             |
| i  |                      |   |             |   |             |   |             |
| te |                      |   |             |   |             |   |             |
| ms |                      |   |             |   |             |   |             |
| th |                      |   |             |   |             |   |             |
| at |                      |   |             |   |             |   |             |
| a  |                      |   |             |   |             |   |             |
| re |                      |   |             |   |             |   |             |
| n  |                      |   |             |   |             |   |             |
| ot |                      |   |             |   |             |   |             |
| d  |                      |   |             |   |             |   |             |
| ol |                      |   |             |   |             |   |             |
| la |                      |   |             |   |             |   |             |
| rs |                      |   |             |   |             |   |             |
| or |                      |   |             |   |             |   |             |
| pe |                      |   |             |   |             |   |             |
| rc |                      |   |             |   |             |   |             |
| en |                      |   |             |   |             |   |             |
| ts |                      |   |             |   |             |   |             |
|    |                      |   |             |   |             |   |             |
| \% |                      |   |             |   |             |   |             |
| i  |                      |   |             |   |             |   |             |
| nd |                      |   |             |   |             |   |             |
| ic |                      |   |             |   |             |   |             |
| at |                      |   |             |   |             |   |             |
| es |                      |   |             |   |             |   |             |
| i  |                      |   |             |   |             |   |             |
| te |                      |   |             |   |             |   |             |
| ms |                      |   |             |   |             |   |             |
| to |                      |   |             |   |             |   |             |
| be |                      |   |             |   |             |   |             |
| e  |                      |   |             |   |             |   |             |
| nt |                      |   |             |   |             |   |             |
| er |                      |   |             |   |             |   |             |
| ed |                      |   |             |   |             |   |             |
| as |                      |   |             |   |             |   |             |
| a  |                      |   |             |   |             |   |             |
| p  |                      |   |             |   |             |   |             |
| er |                      |   |             |   |             |   |             |
| ce |                      |   |             |   |             |   |             |
| nt |                      |   |             |   |             |   |             |
+----+----------------------+---+-------------+---+-------------+---+-------------+

<table>
<colgroup>
<col style="width: 6%" />
<col style="width: 0%" />
<col style="width: 25%" />
<col style="width: 9%" />
<col style="width: 9%" />
<col style="width: 9%" />
<col style="width: 0%" />
<col style="width: 9%" />
<col style="width: 9%" />
<col style="width: 9%" />
<col style="width: 0%" />
<col style="width: 9%" />
</colgroup>
<tbody>
<tr class="odd">
<td colspan="12"><p>FCC Report 43-05</p>
<p>ARMIS SERVICE QUALITY REPORT</p>
<p>COMPANY: XXXXXXXXXXXXXX XXXX Version</p>
<p>STUDY AREA: XXXXXXXXXXXX Submission XXX</p>
<p>PERIOD: From mmm yyyy To mmm yyyy TABLE II</p>
<p>COSA: XXXX PAGE 1 OF 1</p></td>
</tr>
<tr class="even">
<td colspan="12"><p><strong>TABLE II – INSTALLATION AND REPAIR
INTERVALS</strong></p>
<p><strong>(Local Service)</strong></p></td>
</tr>
<tr class="odd">
<td rowspan="4">ROW</td>
<td colspan="2" rowspan="4">CLASSIFICATION</td>
<td colspan="9">COLUMN</td>
</tr>
<tr class="even">
<td colspan="4">Residence</td>
<td colspan="4">Business</td>
<td rowspan="2">Total</td>
</tr>
<tr class="odd">
<td>MSA</td>
<td>Non-MSA</td>
<td>Total</td>
<td colspan="2">MSA</td>
<td>Non-MSA</td>
<td colspan="2">Total</td>
</tr>
<tr class="even">
<td>(ad)</td>
<td>(ae)</td>
<td>(af)</td>
<td colspan="2">(ag)</td>
<td>(ah)</td>
<td colspan="2">(ai)</td>
<td>(aj)</td>
</tr>
<tr class="odd">
<td colspan="12">INSTALLATION INTERVALS:</td>
</tr>
<tr class="even">
<td colspan="2">0130</td>
<td># Installation Orders</td>
<td></td>
<td></td>
<td></td>
<td colspan="2"></td>
<td></td>
<td></td>
<td colspan="2"></td>
</tr>
<tr class="odd">
<td colspan="2">0131</td>
<td># Missed/Cust. Reasons (MCR)</td>
<td></td>
<td></td>
<td></td>
<td colspan="2"></td>
<td></td>
<td></td>
<td colspan="2"></td>
</tr>
<tr class="even">
<td colspan="2">0132</td>
<td>% Commitments Met</td>
<td></td>
<td></td>
<td></td>
<td colspan="2"></td>
<td></td>
<td></td>
<td colspan="2"></td>
</tr>
<tr class="odd">
<td colspan="2">0134</td>
<td>Average Interval (in days)</td>
<td></td>
<td></td>
<td></td>
<td colspan="2"></td>
<td></td>
<td></td>
<td colspan="2"></td>
</tr>
<tr class="even">
<td colspan="12">REPAIR INTERVALS:</td>
</tr>
<tr class="odd">
<td colspan="2">0140</td>
<td># Total Access Lines</td>
<td></td>
<td></td>
<td></td>
<td colspan="2"></td>
<td></td>
<td></td>
<td colspan="2"></td>
</tr>
<tr class="even">
<td colspan="12">INITIAL TROUBLE REPORTS:</td>
</tr>
<tr class="odd">
<td colspan="2">0141</td>
<td># Init. Trouble Reports</td>
<td></td>
<td></td>
<td></td>
<td colspan="2"></td>
<td></td>
<td></td>
<td colspan="2"></td>
</tr>
<tr class="even">
<td colspan="2">0144</td>
<td># Out-of-Svc. Trbl. Rpts.</td>
<td></td>
<td></td>
<td></td>
<td colspan="2"></td>
<td></td>
<td></td>
<td colspan="2"></td>
</tr>
<tr class="odd">
<td colspan="2">0145</td>
<td>Out-of-Svc. Rpr. Intvl. (in hours)</td>
<td></td>
<td></td>
<td></td>
<td colspan="2"></td>
<td></td>
<td></td>
<td colspan="2"></td>
</tr>
<tr class="even">
<td colspan="2">0146</td>
<td># All Other Trbl. Rpts.</td>
<td></td>
<td></td>
<td></td>
<td colspan="2"></td>
<td></td>
<td></td>
<td colspan="2"></td>
</tr>
<tr class="odd">
<td colspan="2">0147</td>
<td>All Other Rpr. Intvl. (in hours)</td>
<td></td>
<td></td>
<td></td>
<td colspan="2"></td>
<td></td>
<td></td>
<td colspan="2"></td>
</tr>
<tr class="even">
<td colspan="2">0160</td>
<td># Subsequent-Initial Trbl. Rpts.</td>
<td></td>
<td></td>
<td></td>
<td colspan="2"></td>
<td></td>
<td></td>
<td colspan="2"></td>
</tr>
<tr class="odd">
<td colspan="12">REPEAT TROUBLE REPORTS:</td>
</tr>
<tr class="even">
<td colspan="2">0142</td>
<td># Repeat Trouble Reports</td>
<td></td>
<td></td>
<td></td>
<td colspan="2"></td>
<td></td>
<td></td>
<td colspan="2"></td>
</tr>
<tr class="odd">
<td colspan="2">0148</td>
<td># Out-of-Svc. Trbl. Rpts.</td>
<td></td>
<td></td>
<td></td>
<td colspan="2"></td>
<td></td>
<td></td>
<td colspan="2"></td>
</tr>
<tr class="even">
<td colspan="2">0149</td>
<td>Out-of-Svc. Rpr. Intvl. (in hours)</td>
<td></td>
<td></td>
<td></td>
<td colspan="2"></td>
<td></td>
<td></td>
<td colspan="2"></td>
</tr>
<tr class="odd">
<td colspan="2">0150</td>
<td># All Other Trbl. Rpts.</td>
<td></td>
<td></td>
<td></td>
<td colspan="2"></td>
<td></td>
<td></td>
<td colspan="2"></td>
</tr>
<tr class="even">
<td colspan="2">0151</td>
<td>All Other Rpr. Intvl. (in hours)</td>
<td></td>
<td></td>
<td></td>
<td colspan="2"></td>
<td></td>
<td></td>
<td colspan="2"></td>
</tr>
<tr class="odd">
<td colspan="2">0170</td>
<td># Subsequent-Repeat Trbl. Rpts.</td>
<td></td>
<td></td>
<td></td>
<td colspan="2"></td>
<td></td>
<td></td>
<td colspan="2"></td>
</tr>
<tr class="even">
<td colspan="12">NO TROUBLE FOUND:</td>
</tr>
<tr class="odd">
<td colspan="2">0143</td>
<td># Total No Trouble Found</td>
<td></td>
<td></td>
<td></td>
<td colspan="2"></td>
<td></td>
<td></td>
<td colspan="2"></td>
</tr>
<tr class="even">
<td colspan="12"><p><strong>Legend:</strong></p>
<p># indicates items that are not dollars or percents</p>
<p>% indicates items to be entered as a percent</p></td>
</tr>
</tbody>
</table>

+----+---+----------------------------+-------------------+----------------+
| F  |   |                            |                   |                |
| CC |   |                            |                   |                |
| Re |   |                            |                   |                |
| po |   |                            |                   |                |
| rt |   |                            |                   |                |
| 4  |   |                            |                   |                |
| 3- |   |                            |                   |                |
| 05 |   |                            |                   |                |
|    |   |                            |                   |                |
| A  |   |                            |                   |                |
| RM |   |                            |                   |                |
| IS |   |                            |                   |                |
| S  |   |                            |                   |                |
| ER |   |                            |                   |                |
| VI |   |                            |                   |                |
| CE |   |                            |                   |                |
| Q  |   |                            |                   |                |
| UA |   |                            |                   |                |
| LI |   |                            |                   |                |
| TY |   |                            |                   |                |
| RE |   |                            |                   |                |
| PO |   |                            |                   |                |
| RT |   |                            |                   |                |
|    |   |                            |                   |                |
| CO |   |                            |                   |                |
| MP |   |                            |                   |                |
| AN |   |                            |                   |                |
| Y: |   |                            |                   |                |
| XX |   |                            |                   |                |
| XX |   |                            |                   |                |
| XX |   |                            |                   |                |
| XX |   |                            |                   |                |
| XX |   |                            |                   |                |
| XX |   |                            |                   |                |
| XX |   |                            |                   |                |
| XX |   |                            |                   |                |
| XX |   |                            |                   |                |
| V  |   |                            |                   |                |
| er |   |                            |                   |                |
| si |   |                            |                   |                |
| on |   |                            |                   |                |
|    |   |                            |                   |                |
| S  |   |                            |                   |                |
| TU |   |                            |                   |                |
| DY |   |                            |                   |                |
| A  |   |                            |                   |                |
| RE |   |                            |                   |                |
| A: |   |                            |                   |                |
| XX |   |                            |                   |                |
| XX |   |                            |                   |                |
| XX |   |                            |                   |                |
| XX |   |                            |                   |                |
| XX |   |                            |                   |                |
| XX |   |                            |                   |                |
| Su |   |                            |                   |                |
| bm |   |                            |                   |                |
| is |   |                            |                   |                |
| si |   |                            |                   |                |
| on |   |                            |                   |                |
| X  |   |                            |                   |                |
| XX |   |                            |                   |                |
|    |   |                            |                   |                |
| P  |   |                            |                   |                |
| ER |   |                            |                   |                |
| IO |   |                            |                   |                |
| D: |   |                            |                   |                |
| Fr |   |                            |                   |                |
| om |   |                            |                   |                |
| m  |   |                            |                   |                |
| mm |   |                            |                   |                |
| yy |   |                            |                   |                |
| yy |   |                            |                   |                |
| To |   |                            |                   |                |
| m  |   |                            |                   |                |
| mm |   |                            |                   |                |
| yy |   |                            |                   |                |
| yy |   |                            |                   |                |
| T  |   |                            |                   |                |
| AB |   |                            |                   |                |
| LE |   |                            |                   |                |
| I  |   |                            |                   |                |
| II |   |                            |                   |                |
|    |   |                            |                   |                |
| C  |   |                            |                   |                |
| OS |   |                            |                   |                |
| A: |   |                            |                   |                |
| XX |   |                            |                   |                |
| XX |   |                            |                   |                |
| PA |   |                            |                   |                |
| GE |   |                            |                   |                |
| 1  |   |                            |                   |                |
| OF |   |                            |                   |                |
| 1  |   |                            |                   |                |
+----+---+----------------------------+-------------------+----------------+
| *  |   |                            |                   |                |
| *T |   |                            |                   |                |
| AB |   |                            |                   |                |
| LE |   |                            |                   |                |
| I  |   |                            |                   |                |
| II |   |                            |                   |                |
| -- |   |                            |                   |                |
| CO |   |                            |                   |                |
| MM |   |                            |                   |                |
| ON |   |                            |                   |                |
| T  |   |                            |                   |                |
| RU |   |                            |                   |                |
| NK |   |                            |                   |                |
| BL |   |                            |                   |                |
| OC |   |                            |                   |                |
| KA |   |                            |                   |                |
| GE |   |                            |                   |                |
| ** |   |                            |                   |                |
+----+---+----------------------------+-------------------+----------------+
| R  | C |                            | COLUMN            |                |
| OW | L |                            |                   |                |
|    | A |                            |                   |                |
|    | S |                            |                   |                |
|    | S |                            |                   |                |
|    | I |                            |                   |                |
|    | F |                            |                   |                |
|    | I |                            |                   |                |
|    | C |                            |                   |                |
|    | A |                            |                   |                |
|    | T |                            |                   |                |
|    | I |                            |                   |                |
|    | O |                            |                   |                |
|    | N |                            |                   |                |
+----+---+----------------------------+-------------------+----------------+
|    |   |                            | Annual            |                |
+----+---+----------------------------+-------------------+----------------+
|    |   |                            | (ak)              |                |
+----+---+----------------------------+-------------------+----------------+
|    |   |                            |                   |                |
+----+---+----------------------------+-------------------+----------------+
| 01 |   | \# Total Trunk Groups      |                   |                |
| 80 |   |                            |                   |                |
+----+---+----------------------------+-------------------+----------------+
| 01 |   | \# Groups Measured         |                   |                |
| 81 |   |                            |                   |                |
+----+---+----------------------------+-------------------+----------------+
| 01 |   | \# FGD Groups Exceeding    |                   |                |
| 85 |   | Threshold 3 Mos.           |                   |                |
+----+---+----------------------------+-------------------+----------------+
| 01 |   | \# Other Groups Exceeding  |                   |                |
| 86 |   | Threshold 3 Mos.           |                   |                |
+----+---+----------------------------+-------------------+----------------+
| 01 |   | \# FGD Groups Exceeding    |                   |                |
| 87 |   | Threshold 1 Mo.            |                   |                |
+----+---+----------------------------+-------------------+----------------+
| 01 |   | \# Other Groups Exceeding  |                   |                |
| 88 |   | Threshold 1 Mo.            |                   |                |
+----+---+----------------------------+-------------------+----------------+
| 01 |   | \# FGD Groups Exceeding    |                   |                |
| 89 |   | DBO 3 Mos.                 |                   |                |
+----+---+----------------------------+-------------------+----------------+
| 01 |   | \# Other Groups Exceeding  |                   |                |
| 90 |   | DBO 3 Mos.                 |                   |                |
+----+---+----------------------------+-------------------+----------------+
| *  |   |                            |                   |                |
| *L |   |                            |                   |                |
| eg |   |                            |                   |                |
| en |   |                            |                   |                |
| d: |   |                            |                   |                |
| ** |   |                            |                   |                |
|    |   |                            |                   |                |
| \# |   |                            |                   |                |
| i  |   |                            |                   |                |
| nd |   |                            |                   |                |
| ic |   |                            |                   |                |
| at |   |                            |                   |                |
| es |   |                            |                   |                |
| i  |   |                            |                   |                |
| te |   |                            |                   |                |
| ms |   |                            |                   |                |
| th |   |                            |                   |                |
| at |   |                            |                   |                |
| a  |   |                            |                   |                |
| re |   |                            |                   |                |
| n  |   |                            |                   |                |
| ot |   |                            |                   |                |
| d  |   |                            |                   |                |
| ol |   |                            |                   |                |
| la |   |                            |                   |                |
| rs |   |                            |                   |                |
| or |   |                            |                   |                |
| pe |   |                            |                   |                |
| rc |   |                            |                   |                |
| en |   |                            |                   |                |
| ts |   |                            |                   |                |
|    |   |                            |                   |                |
| \% |   |                            |                   |                |
| i  |   |                            |                   |                |
| nd |   |                            |                   |                |
| ic |   |                            |                   |                |
| at |   |                            |                   |                |
| es |   |                            |                   |                |
| i  |   |                            |                   |                |
| te |   |                            |                   |                |
| ms |   |                            |                   |                |
| to |   |                            |                   |                |
| be |   |                            |                   |                |
| e  |   |                            |                   |                |
| nt |   |                            |                   |                |
| er |   |                            |                   |                |
| ed |   |                            |                   |                |
| as |   |                            |                   |                |
| a  |   |                            |                   |                |
| p  |   |                            |                   |                |
| er |   |                            |                   |                |
| ce |   |                            |                   |                |
| nt |   |                            |                   |                |
+----+---+----------------------------+-------------------+----------------+

+---+----------------+-------+-------+-------+-------+-------+-------+---+
| F |                |       |       |       |       |       |       |   |
| C |                |       |       |       |       |       |       |   |
| C |                |       |       |       |       |       |       |   |
| R |                |       |       |       |       |       |       |   |
| e |                |       |       |       |       |       |       |   |
| p |                |       |       |       |       |       |       |   |
| o |                |       |       |       |       |       |       |   |
| r |                |       |       |       |       |       |       |   |
| t |                |       |       |       |       |       |       |   |
| 4 |                |       |       |       |       |       |       |   |
| 3 |                |       |       |       |       |       |       |   |
| - |                |       |       |       |       |       |       |   |
| 0 |                |       |       |       |       |       |       |   |
| 5 |                |       |       |       |       |       |       |   |
|   |                |       |       |       |       |       |       |   |
| A |                |       |       |       |       |       |       |   |
| R |                |       |       |       |       |       |       |   |
| M |                |       |       |       |       |       |       |   |
| I |                |       |       |       |       |       |       |   |
| S |                |       |       |       |       |       |       |   |
| S |                |       |       |       |       |       |       |   |
| E |                |       |       |       |       |       |       |   |
| R |                |       |       |       |       |       |       |   |
| V |                |       |       |       |       |       |       |   |
| I |                |       |       |       |       |       |       |   |
| C |                |       |       |       |       |       |       |   |
| E |                |       |       |       |       |       |       |   |
| Q |                |       |       |       |       |       |       |   |
| U |                |       |       |       |       |       |       |   |
| A |                |       |       |       |       |       |       |   |
| L |                |       |       |       |       |       |       |   |
| I |                |       |       |       |       |       |       |   |
| T |                |       |       |       |       |       |       |   |
| Y |                |       |       |       |       |       |       |   |
| R |                |       |       |       |       |       |       |   |
| E |                |       |       |       |       |       |       |   |
| P |                |       |       |       |       |       |       |   |
| O |                |       |       |       |       |       |       |   |
| R |                |       |       |       |       |       |       |   |
| T |                |       |       |       |       |       |       |   |
|   |                |       |       |       |       |       |       |   |
| C |                |       |       |       |       |       |       |   |
| O |                |       |       |       |       |       |       |   |
| M |                |       |       |       |       |       |       |   |
| P |                |       |       |       |       |       |       |   |
| A |                |       |       |       |       |       |       |   |
| N |                |       |       |       |       |       |       |   |
| Y |                |       |       |       |       |       |       |   |
| : |                |       |       |       |       |       |       |   |
| X |                |       |       |       |       |       |       |   |
| X |                |       |       |       |       |       |       |   |
| X |                |       |       |       |       |       |       |   |
| X |                |       |       |       |       |       |       |   |
| X |                |       |       |       |       |       |       |   |
| X |                |       |       |       |       |       |       |   |
| X |                |       |       |       |       |       |       |   |
| X |                |       |       |       |       |       |       |   |
| X |                |       |       |       |       |       |       |   |
| X |                |       |       |       |       |       |       |   |
| X |                |       |       |       |       |       |       |   |
| X |                |       |       |       |       |       |       |   |
| X |                |       |       |       |       |       |       |   |
| X |                |       |       |       |       |       |       |   |
| X |                |       |       |       |       |       |       |   |
| X |                |       |       |       |       |       |       |   |
| X |                |       |       |       |       |       |       |   |
| X |                |       |       |       |       |       |       |   |
| V |                |       |       |       |       |       |       |   |
| e |                |       |       |       |       |       |       |   |
| r |                |       |       |       |       |       |       |   |
| s |                |       |       |       |       |       |       |   |
| i |                |       |       |       |       |       |       |   |
| o |                |       |       |       |       |       |       |   |
| n |                |       |       |       |       |       |       |   |
|   |                |       |       |       |       |       |       |   |
| S |                |       |       |       |       |       |       |   |
| T |                |       |       |       |       |       |       |   |
| U |                |       |       |       |       |       |       |   |
| D |                |       |       |       |       |       |       |   |
| Y |                |       |       |       |       |       |       |   |
| A |                |       |       |       |       |       |       |   |
| R |                |       |       |       |       |       |       |   |
| E |                |       |       |       |       |       |       |   |
| A |                |       |       |       |       |       |       |   |
| : |                |       |       |       |       |       |       |   |
| X |                |       |       |       |       |       |       |   |
| X |                |       |       |       |       |       |       |   |
| X |                |       |       |       |       |       |       |   |
| X |                |       |       |       |       |       |       |   |
| X |                |       |       |       |       |       |       |   |
| X |                |       |       |       |       |       |       |   |
| X |                |       |       |       |       |       |       |   |
| X |                |       |       |       |       |       |       |   |
| X |                |       |       |       |       |       |       |   |
| X |                |       |       |       |       |       |       |   |
| X |                |       |       |       |       |       |       |   |
| X |                |       |       |       |       |       |       |   |
| S |                |       |       |       |       |       |       |   |
| u |                |       |       |       |       |       |       |   |
| b |                |       |       |       |       |       |       |   |
| m |                |       |       |       |       |       |       |   |
| i |                |       |       |       |       |       |       |   |
| s |                |       |       |       |       |       |       |   |
| s |                |       |       |       |       |       |       |   |
| i |                |       |       |       |       |       |       |   |
| o |                |       |       |       |       |       |       |   |
| n |                |       |       |       |       |       |       |   |
| X |                |       |       |       |       |       |       |   |
| X |                |       |       |       |       |       |       |   |
| X |                |       |       |       |       |       |       |   |
|   |                |       |       |       |       |       |       |   |
| P |                |       |       |       |       |       |       |   |
| E |                |       |       |       |       |       |       |   |
| R |                |       |       |       |       |       |       |   |
| I |                |       |       |       |       |       |       |   |
| O |                |       |       |       |       |       |       |   |
| D |                |       |       |       |       |       |       |   |
| : |                |       |       |       |       |       |       |   |
| F |                |       |       |       |       |       |       |   |
| r |                |       |       |       |       |       |       |   |
| o |                |       |       |       |       |       |       |   |
| m |                |       |       |       |       |       |       |   |
| m |                |       |       |       |       |       |       |   |
| m |                |       |       |       |       |       |       |   |
| m |                |       |       |       |       |       |       |   |
| y |                |       |       |       |       |       |       |   |
| y |                |       |       |       |       |       |       |   |
| y |                |       |       |       |       |       |       |   |
| y |                |       |       |       |       |       |       |   |
| T |                |       |       |       |       |       |       |   |
| o |                |       |       |       |       |       |       |   |
| m |                |       |       |       |       |       |       |   |
| m |                |       |       |       |       |       |       |   |
| m |                |       |       |       |       |       |       |   |
| y |                |       |       |       |       |       |       |   |
| y |                |       |       |       |       |       |       |   |
| y |                |       |       |       |       |       |       |   |
| y |                |       |       |       |       |       |       |   |
| T |                |       |       |       |       |       |       |   |
| A |                |       |       |       |       |       |       |   |
| B |                |       |       |       |       |       |       |   |
| L |                |       |       |       |       |       |       |   |
| E |                |       |       |       |       |       |       |   |
| I |                |       |       |       |       |       |       |   |
| V |                |       |       |       |       |       |       |   |
|   |                |       |       |       |       |       |       |   |
| C |                |       |       |       |       |       |       |   |
| O |                |       |       |       |       |       |       |   |
| S |                |       |       |       |       |       |       |   |
| A |                |       |       |       |       |       |       |   |
| : |                |       |       |       |       |       |       |   |
| X |                |       |       |       |       |       |       |   |
| X |                |       |       |       |       |       |       |   |
| X |                |       |       |       |       |       |       |   |
| X |                |       |       |       |       |       |       |   |
| P |                |       |       |       |       |       |       |   |
| A |                |       |       |       |       |       |       |   |
| G |                |       |       |       |       |       |       |   |
| E |                |       |       |       |       |       |       |   |
| 1 |                |       |       |       |       |       |       |   |
| O |                |       |       |       |       |       |       |   |
| F |                |       |       |       |       |       |       |   |
| 1 |                |       |       |       |       |       |       |   |
+---+----------------+-------+-------+-------+-------+-------+-------+---+
| * |                |       |       |       |       |       |       |   |
| * |                |       |       |       |       |       |       |   |
| T |                |       |       |       |       |       |       |   |
| A |                |       |       |       |       |       |       |   |
| B |                |       |       |       |       |       |       |   |
| L |                |       |       |       |       |       |       |   |
| E |                |       |       |       |       |       |       |   |
| I |                |       |       |       |       |       |       |   |
| V |                |       |       |       |       |       |       |   |
|   |                |       |       |       |       |       |       |   |
| - |                |       |       |       |       |       |       |   |
| T |                |       |       |       |       |       |       |   |
| O |                |       |       |       |       |       |       |   |
| T |                |       |       |       |       |       |       |   |
| A |                |       |       |       |       |       |       |   |
| L |                |       |       |       |       |       |       |   |
| S |                |       |       |       |       |       |       |   |
| W |                |       |       |       |       |       |       |   |
| I |                |       |       |       |       |       |       |   |
| T |                |       |       |       |       |       |       |   |
| C |                |       |       |       |       |       |       |   |
| H |                |       |       |       |       |       |       |   |
| D |                |       |       |       |       |       |       |   |
| O |                |       |       |       |       |       |       |   |
| W |                |       |       |       |       |       |       |   |
| N |                |       |       |       |       |       |       |   |
| T |                |       |       |       |       |       |       |   |
| I |                |       |       |       |       |       |       |   |
| M |                |       |       |       |       |       |       |   |
| E |                |       |       |       |       |       |       |   |
| * |                |       |       |       |       |       |       |   |
| * |                |       |       |       |       |       |       |   |
+---+----------------+-------+-------+-------+-------+-------+-------+---+
| R | CLASSIFICATION | C     |       |       |       |       |       |   |
| O |                | OLUMN |       |       |       |       |       |   |
| W |                |       |       |       |       |       |       |   |
+---+----------------+-------+-------+-------+-------+-------+-------+---+
|   |                | Total | Swi   | Total | Inci  |       |       |   |
|   |                | N     | tches | S     | dents |       |       |   |
|   |                | umber | With  | witch | Under |       |       |   |
|   |                |       |       |       | 2     |       |       |   |
|   |                | Swi   | Dow   | Dow   | Mi    |       |       |   |
|   |                | tches | ntime | ntime | nutes |       |       |   |
+---+----------------+-------+-------+-------+-------+-------+-------+---+
|   |                |       |       |       | Total | U     | \%    |   |
|   |                |       |       |       |       | nsche | U     |   |
|   |                |       |       |       |       | duled | nsche |   |
|   |                |       |       |       |       |       | duled |   |
+---+----------------+-------+-------+-------+-------+-------+-------+---+
|   |                | (an)  | (ao)  | (ap)  | (aq)  | (ar)  | (as)  |   |
+---+----------------+-------+-------+-------+-------+-------+-------+---+
|   |                |       |       |       |       |       |       |   |
+---+----------------+-------+-------+-------+-------+-------+-------+---+
| 0 | MSA            |       |       |       |       |       |       |   |
| 2 |                |       |       |       |       |       |       |   |
| 0 |                |       |       |       |       |       |       |   |
| 0 |                |       |       |       |       |       |       |   |
+---+----------------+-------+-------+-------+-------+-------+-------+---+
| 0 | Non-MSA        |       |       |       |       |       |       |   |
| 2 |                |       |       |       |       |       |       |   |
| 0 |                |       |       |       |       |       |       |   |
| 1 |                |       |       |       |       |       |       |   |
+---+----------------+-------+-------+-------+-------+-------+-------+---+
| 0 | Switches Under |       |       |       |       |       |       |   |
| 2 | 1000 Lines     |       |       |       |       |       |       |   |
| 1 |                |       |       |       |       |       |       |   |
| 0 |                |       |       |       |       |       |       |   |
+---+----------------+-------+-------+-------+-------+-------+-------+---+
| 0 | Switches       |       |       |       |       |       |       |   |
| 2 | 1000-4999      |       |       |       |       |       |       |   |
| 1 | Lines          |       |       |       |       |       |       |   |
| 1 |                |       |       |       |       |       |       |   |
+---+----------------+-------+-------+-------+-------+-------+-------+---+
| 0 | Switches       |       |       |       |       |       |       |   |
| 2 | 5000-9999      |       |       |       |       |       |       |   |
| 1 | Lines          |       |       |       |       |       |       |   |
| 2 |                |       |       |       |       |       |       |   |
+---+----------------+-------+-------+-------+-------+-------+-------+---+
| 0 | Switches       |       |       |       |       |       |       |   |
| 2 | 10000-19999    |       |       |       |       |       |       |   |
| 1 | Lines          |       |       |       |       |       |       |   |
| 3 |                |       |       |       |       |       |       |   |
+---+----------------+-------+-------+-------+-------+-------+-------+---+
| 0 | Switches 20000 |       |       |       |       |       |       |   |
| 2 | or More Lines  |       |       |       |       |       |       |   |
| 1 |                |       |       |       |       |       |       |   |
| 4 |                |       |       |       |       |       |       |   |
+---+----------------+-------+-------+-------+-------+-------+-------+---+

+---+--------+--------+--------+--------+--------+--------+--------+---+
| F |        |        |        |        |        |        |        |   |
| C |        |        |        |        |        |        |        |   |
| C |        |        |        |        |        |        |        |   |
| R |        |        |        |        |        |        |        |   |
| e |        |        |        |        |        |        |        |   |
| p |        |        |        |        |        |        |        |   |
| o |        |        |        |        |        |        |        |   |
| r |        |        |        |        |        |        |        |   |
| t |        |        |        |        |        |        |        |   |
| 4 |        |        |        |        |        |        |        |   |
| 3 |        |        |        |        |        |        |        |   |
| - |        |        |        |        |        |        |        |   |
| 0 |        |        |        |        |        |        |        |   |
| 5 |        |        |        |        |        |        |        |   |
|   |        |        |        |        |        |        |        |   |
| A |        |        |        |        |        |        |        |   |
| R |        |        |        |        |        |        |        |   |
| M |        |        |        |        |        |        |        |   |
| I |        |        |        |        |        |        |        |   |
| S |        |        |        |        |        |        |        |   |
| S |        |        |        |        |        |        |        |   |
| E |        |        |        |        |        |        |        |   |
| R |        |        |        |        |        |        |        |   |
| V |        |        |        |        |        |        |        |   |
| I |        |        |        |        |        |        |        |   |
| C |        |        |        |        |        |        |        |   |
| E |        |        |        |        |        |        |        |   |
| Q |        |        |        |        |        |        |        |   |
| U |        |        |        |        |        |        |        |   |
| A |        |        |        |        |        |        |        |   |
| L |        |        |        |        |        |        |        |   |
| I |        |        |        |        |        |        |        |   |
| T |        |        |        |        |        |        |        |   |
| Y |        |        |        |        |        |        |        |   |
| R |        |        |        |        |        |        |        |   |
| E |        |        |        |        |        |        |        |   |
| P |        |        |        |        |        |        |        |   |
| O |        |        |        |        |        |        |        |   |
| R |        |        |        |        |        |        |        |   |
| T |        |        |        |        |        |        |        |   |
|   |        |        |        |        |        |        |        |   |
| C |        |        |        |        |        |        |        |   |
| O |        |        |        |        |        |        |        |   |
| M |        |        |        |        |        |        |        |   |
| P |        |        |        |        |        |        |        |   |
| A |        |        |        |        |        |        |        |   |
| N |        |        |        |        |        |        |        |   |
| Y |        |        |        |        |        |        |        |   |
| : |        |        |        |        |        |        |        |   |
| X |        |        |        |        |        |        |        |   |
| X |        |        |        |        |        |        |        |   |
| X |        |        |        |        |        |        |        |   |
| X |        |        |        |        |        |        |        |   |
| X |        |        |        |        |        |        |        |   |
| X |        |        |        |        |        |        |        |   |
| X |        |        |        |        |        |        |        |   |
| X |        |        |        |        |        |        |        |   |
| X |        |        |        |        |        |        |        |   |
| X |        |        |        |        |        |        |        |   |
| X |        |        |        |        |        |        |        |   |
| X |        |        |        |        |        |        |        |   |
| X |        |        |        |        |        |        |        |   |
| X |        |        |        |        |        |        |        |   |
| X |        |        |        |        |        |        |        |   |
| X |        |        |        |        |        |        |        |   |
| X |        |        |        |        |        |        |        |   |
| X |        |        |        |        |        |        |        |   |
| V |        |        |        |        |        |        |        |   |
| e |        |        |        |        |        |        |        |   |
| r |        |        |        |        |        |        |        |   |
| s |        |        |        |        |        |        |        |   |
| i |        |        |        |        |        |        |        |   |
| o |        |        |        |        |        |        |        |   |
| n |        |        |        |        |        |        |        |   |
|   |        |        |        |        |        |        |        |   |
| S |        |        |        |        |        |        |        |   |
| T |        |        |        |        |        |        |        |   |
| U |        |        |        |        |        |        |        |   |
| D |        |        |        |        |        |        |        |   |
| Y |        |        |        |        |        |        |        |   |
| A |        |        |        |        |        |        |        |   |
| R |        |        |        |        |        |        |        |   |
| E |        |        |        |        |        |        |        |   |
| A |        |        |        |        |        |        |        |   |
| : |        |        |        |        |        |        |        |   |
| X |        |        |        |        |        |        |        |   |
| X |        |        |        |        |        |        |        |   |
| X |        |        |        |        |        |        |        |   |
| X |        |        |        |        |        |        |        |   |
| X |        |        |        |        |        |        |        |   |
| X |        |        |        |        |        |        |        |   |
| X |        |        |        |        |        |        |        |   |
| X |        |        |        |        |        |        |        |   |
| X |        |        |        |        |        |        |        |   |
| X |        |        |        |        |        |        |        |   |
| X |        |        |        |        |        |        |        |   |
| X |        |        |        |        |        |        |        |   |
| S |        |        |        |        |        |        |        |   |
| u |        |        |        |        |        |        |        |   |
| b |        |        |        |        |        |        |        |   |
| m |        |        |        |        |        |        |        |   |
| i |        |        |        |        |        |        |        |   |
| s |        |        |        |        |        |        |        |   |
| s |        |        |        |        |        |        |        |   |
| i |        |        |        |        |        |        |        |   |
| o |        |        |        |        |        |        |        |   |
| n |        |        |        |        |        |        |        |   |
| X |        |        |        |        |        |        |        |   |
| X |        |        |        |        |        |        |        |   |
| X |        |        |        |        |        |        |        |   |
|   |        |        |        |        |        |        |        |   |
| P |        |        |        |        |        |        |        |   |
| E |        |        |        |        |        |        |        |   |
| R |        |        |        |        |        |        |        |   |
| I |        |        |        |        |        |        |        |   |
| O |        |        |        |        |        |        |        |   |
| D |        |        |        |        |        |        |        |   |
| : |        |        |        |        |        |        |        |   |
| F |        |        |        |        |        |        |        |   |
| r |        |        |        |        |        |        |        |   |
| o |        |        |        |        |        |        |        |   |
| m |        |        |        |        |        |        |        |   |
| m |        |        |        |        |        |        |        |   |
| m |        |        |        |        |        |        |        |   |
| m |        |        |        |        |        |        |        |   |
| y |        |        |        |        |        |        |        |   |
| y |        |        |        |        |        |        |        |   |
| y |        |        |        |        |        |        |        |   |
| y |        |        |        |        |        |        |        |   |
| T |        |        |        |        |        |        |        |   |
| o |        |        |        |        |        |        |        |   |
| m |        |        |        |        |        |        |        |   |
| m |        |        |        |        |        |        |        |   |
| m |        |        |        |        |        |        |        |   |
| y |        |        |        |        |        |        |        |   |
| y |        |        |        |        |        |        |        |   |
| y |        |        |        |        |        |        |        |   |
| y |        |        |        |        |        |        |        |   |
| T |        |        |        |        |        |        |        |   |
| A |        |        |        |        |        |        |        |   |
| B |        |        |        |        |        |        |        |   |
| L |        |        |        |        |        |        |        |   |
| E |        |        |        |        |        |        |        |   |
| I |        |        |        |        |        |        |        |   |
| V |        |        |        |        |        |        |        |   |
| - |        |        |        |        |        |        |        |   |
| A |        |        |        |        |        |        |        |   |
|   |        |        |        |        |        |        |        |   |
| C |        |        |        |        |        |        |        |   |
| O |        |        |        |        |        |        |        |   |
| S |        |        |        |        |        |        |        |   |
| A |        |        |        |        |        |        |        |   |
| : |        |        |        |        |        |        |        |   |
| X |        |        |        |        |        |        |        |   |
| X |        |        |        |        |        |        |        |   |
| X |        |        |        |        |        |        |        |   |
| X |        |        |        |        |        |        |        |   |
| P |        |        |        |        |        |        |        |   |
| A |        |        |        |        |        |        |        |   |
| G |        |        |        |        |        |        |        |   |
| E |        |        |        |        |        |        |        |   |
| 1 |        |        |        |        |        |        |        |   |
| O |        |        |        |        |        |        |        |   |
| F |        |        |        |        |        |        |        |   |
| 1 |        |        |        |        |        |        |        |   |
+---+--------+--------+--------+--------+--------+--------+--------+---+
| * |        |        |        |        |        |        |        |   |
| * |        |        |        |        |        |        |        |   |
| T |        |        |        |        |        |        |        |   |
| A |        |        |        |        |        |        |        |   |
| B |        |        |        |        |        |        |        |   |
| L |        |        |        |        |        |        |        |   |
| E |        |        |        |        |        |        |        |   |
| I |        |        |        |        |        |        |        |   |
| V |        |        |        |        |        |        |        |   |
| - |        |        |        |        |        |        |        |   |
| A |        |        |        |        |        |        |        |   |
| - |        |        |        |        |        |        |        |   |
| - |        |        |        |        |        |        |        |   |
| O |        |        |        |        |        |        |        |   |
| C |        |        |        |        |        |        |        |   |
| C |        |        |        |        |        |        |        |   |
| U |        |        |        |        |        |        |        |   |
| R |        |        |        |        |        |        |        |   |
| R |        |        |        |        |        |        |        |   |
| E |        |        |        |        |        |        |        |   |
| N |        |        |        |        |        |        |        |   |
| C |        |        |        |        |        |        |        |   |
| E |        |        |        |        |        |        |        |   |
| S |        |        |        |        |        |        |        |   |
| O |        |        |        |        |        |        |        |   |
| F |        |        |        |        |        |        |        |   |
| T |        |        |        |        |        |        |        |   |
| W |        |        |        |        |        |        |        |   |
| O |        |        |        |        |        |        |        |   |
| M |        |        |        |        |        |        |        |   |
| I |        |        |        |        |        |        |        |   |
| N |        |        |        |        |        |        |        |   |
| U |        |        |        |        |        |        |        |   |
| T |        |        |        |        |        |        |        |   |
| E |        |        |        |        |        |        |        |   |
| S |        |        |        |        |        |        |        |   |
| O |        |        |        |        |        |        |        |   |
| R |        |        |        |        |        |        |        |   |
| M |        |        |        |        |        |        |        |   |
| O |        |        |        |        |        |        |        |   |
| R |        |        |        |        |        |        |        |   |
| E |        |        |        |        |        |        |        |   |
| D |        |        |        |        |        |        |        |   |
| U |        |        |        |        |        |        |        |   |
| R |        |        |        |        |        |        |        |   |
| A |        |        |        |        |        |        |        |   |
| T |        |        |        |        |        |        |        |   |
| I |        |        |        |        |        |        |        |   |
| O |        |        |        |        |        |        |        |   |
| N |        |        |        |        |        |        |        |   |
| D |        |        |        |        |        |        |        |   |
| O |        |        |        |        |        |        |        |   |
| W |        |        |        |        |        |        |        |   |
| N |        |        |        |        |        |        |        |   |
| T |        |        |        |        |        |        |        |   |
| I |        |        |        |        |        |        |        |   |
| M |        |        |        |        |        |        |        |   |
| E |        |        |        |        |        |        |        |   |
| * |        |        |        |        |        |        |        |   |
| * |        |        |        |        |        |        |        |   |
+---+--------+--------+--------+--------+--------+--------+--------+---+
| R | Cause  | CLLI   | Access | MSA    | Du     | Date   | Time   |   |
| O |        | Code   | Lines  |        | ration |        |        |   |
| W |        |        |        |        |        |        |        |   |
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+---+--------+--------+--------+--------+--------+--------+--------+---+
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+---+--------+--------+--------+--------+--------+--------+--------+---+
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+---+--------+--------+--------+--------+--------+--------+--------+---+
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+---+--------+--------+--------+--------+--------+--------+--------+---+
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| 4 |        |        |        |        |        |        |        |   |
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+---+--------+--------+--------+--------+--------+--------+--------+---+
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+---+--------+--------+--------+--------+--------+--------+--------+---+

+----+----------------------+-------------+-------------+-------------+---+
| F  |                      |             |             |             |   |
| CC |                      |             |             |             |   |
| Re |                      |             |             |             |   |
| po |                      |             |             |             |   |
| rt |                      |             |             |             |   |
| 4  |                      |             |             |             |   |
| 3- |                      |             |             |             |   |
| 05 |                      |             |             |             |   |
|    |                      |             |             |             |   |
| A  |                      |             |             |             |   |
| RM |                      |             |             |             |   |
| IS |                      |             |             |             |   |
| S  |                      |             |             |             |   |
| ER |                      |             |             |             |   |
| VI |                      |             |             |             |   |
| CE |                      |             |             |             |   |
| Q  |                      |             |             |             |   |
| UA |                      |             |             |             |   |
| LI |                      |             |             |             |   |
| TY |                      |             |             |             |   |
| RE |                      |             |             |             |   |
| PO |                      |             |             |             |   |
| RT |                      |             |             |             |   |
|    |                      |             |             |             |   |
| CO |                      |             |             |             |   |
| MP |                      |             |             |             |   |
| AN |                      |             |             |             |   |
| Y: |                      |             |             |             |   |
| XX |                      |             |             |             |   |
| XX |                      |             |             |             |   |
| XX |                      |             |             |             |   |
| XX |                      |             |             |             |   |
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| XX |                      |             |             |             |   |
| XX |                      |             |             |             |   |
| V  |                      |             |             |             |   |
| er |                      |             |             |             |   |
| si |                      |             |             |             |   |
| on |                      |             |             |             |   |
|    |                      |             |             |             |   |
| S  |                      |             |             |             |   |
| TU |                      |             |             |             |   |
| DY |                      |             |             |             |   |
| A  |                      |             |             |             |   |
| RE |                      |             |             |             |   |
| A: |                      |             |             |             |   |
| XX |                      |             |             |             |   |
| XX |                      |             |             |             |   |
| XX |                      |             |             |             |   |
| XX |                      |             |             |             |   |
| XX |                      |             |             |             |   |
| XX |                      |             |             |             |   |
| Su |                      |             |             |             |   |
| bm |                      |             |             |             |   |
| is |                      |             |             |             |   |
| si |                      |             |             |             |   |
| on |                      |             |             |             |   |
| X  |                      |             |             |             |   |
| XX |                      |             |             |             |   |
|    |                      |             |             |             |   |
| P  |                      |             |             |             |   |
| ER |                      |             |             |             |   |
| IO |                      |             |             |             |   |
| D: |                      |             |             |             |   |
| Fr |                      |             |             |             |   |
| om |                      |             |             |             |   |
| m  |                      |             |             |             |   |
| mm |                      |             |             |             |   |
| yy |                      |             |             |             |   |
| yy |                      |             |             |             |   |
| To |                      |             |             |             |   |
| m  |                      |             |             |             |   |
| mm |                      |             |             |             |   |
| yy |                      |             |             |             |   |
| yy |                      |             |             |             |   |
| T  |                      |             |             |             |   |
| AB |                      |             |             |             |   |
| LE |                      |             |             |             |   |
| V  |                      |             |             |             |   |
|    |                      |             |             |             |   |
| C  |                      |             |             |             |   |
| OS |                      |             |             |             |   |
| A: |                      |             |             |             |   |
| XX |                      |             |             |             |   |
| XX |                      |             |             |             |   |
| PA |                      |             |             |             |   |
| GE |                      |             |             |             |   |
| 1  |                      |             |             |             |   |
| OF |                      |             |             |             |   |
| 1  |                      |             |             |             |   |
+----+----------------------+-------------+-------------+-------------+---+
| *  |                      |             |             |             |   |
| *T |                      |             |             |             |   |
| AB |                      |             |             |             |   |
| LE |                      |             |             |             |   |
| V  |                      |             |             |             |   |
| -- |                      |             |             |             |   |
| S  |                      |             |             |             |   |
| ER |                      |             |             |             |   |
| VI |                      |             |             |             |   |
| CE |                      |             |             |             |   |
| Q  |                      |             |             |             |   |
| UA |                      |             |             |             |   |
| LI |                      |             |             |             |   |
| TY |                      |             |             |             |   |
| CO |                      |             |             |             |   |
| MP |                      |             |             |             |   |
| LA |                      |             |             |             |   |
| IN |                      |             |             |             |   |
| TS |                      |             |             |             |   |
| ** |                      |             |             |             |   |
+----+----------------------+-------------+-------------+-------------+---+
| R  | CLASSIFICATION       | COLUMN      |             |             |   |
| OW |                      |             |             |             |   |
+----+----------------------+-------------+-------------+-------------+---+
|    |                      | Total       | MSA         | Non-MSA     |   |
+----+----------------------+-------------+-------------+-------------+---+
|    |                      | (da)        | (db)        | \(dc\)      |   |
+----+----------------------+-------------+-------------+-------------+---+
|    |                      |             |             |             |   |
+----+----------------------+-------------+-------------+-------------+---+
| 03 | \# Business Access   |             |             |             |   |
| 20 | Lines                |             |             |             |   |
+----+----------------------+-------------+-------------+-------------+---+
| 03 | \# Federal           |             |             |             |   |
| 21 | Complaints-Business  |             |             |             |   |
+----+----------------------+-------------+-------------+-------------+---+
| 03 | \# State             |             |             |             |   |
| 22 | Complaints-Business  |             |             |             |   |
+----+----------------------+-------------+-------------+-------------+---+
| 03 | \# Residential       |             |             |             |   |
| 30 | Access Lines         |             |             |             |   |
+----+----------------------+-------------+-------------+-------------+---+
| 03 | \# Federal           |             |             |             |   |
| 31 | Complaints-Residence |             |             |             |   |
+----+----------------------+-------------+-------------+-------------+---+
| 03 | \# State             |             |             |             |   |
| 32 | Complaints-Residence |             |             |             |   |
+----+----------------------+-------------+-------------+-------------+---+
| *  |                      |             |             |             |   |
| *L |                      |             |             |             |   |
| eg |                      |             |             |             |   |
| en |                      |             |             |             |   |
| d: |                      |             |             |             |   |
| ** |                      |             |             |             |   |
|    |                      |             |             |             |   |
| \# |                      |             |             |             |   |
| i  |                      |             |             |             |   |
| nd |                      |             |             |             |   |
| ic |                      |             |             |             |   |
| at |                      |             |             |             |   |
| es |                      |             |             |             |   |
| i  |                      |             |             |             |   |
| te |                      |             |             |             |   |
| ms |                      |             |             |             |   |
| th |                      |             |             |             |   |
| at |                      |             |             |             |   |
| a  |                      |             |             |             |   |
| re |                      |             |             |             |   |
| n  |                      |             |             |             |   |
| ot |                      |             |             |             |   |
| d  |                      |             |             |             |   |
| ol |                      |             |             |             |   |
| la |                      |             |             |             |   |
| rs |                      |             |             |             |   |
| or |                      |             |             |             |   |
| pe |                      |             |             |             |   |
| rc |                      |             |             |             |   |
| en |                      |             |             |             |   |
| ts |                      |             |             |             |   |
|    |                      |             |             |             |   |
| \% |                      |             |             |             |   |
| i  |                      |             |             |             |   |
| nd |                      |             |             |             |   |
| ic |                      |             |             |             |   |
| at |                      |             |             |             |   |
| es |                      |             |             |             |   |
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| ms |                      |             |             |             |   |
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| e  |                      |             |             |             |   |
| nt |                      |             |             |             |   |
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| ed |                      |             |             |             |   |
| as |                      |             |             |             |   |
| a  |                      |             |             |             |   |
| p  |                      |             |             |             |   |
| er |                      |             |             |             |   |
| ce |                      |             |             |             |   |
| nt |                      |             |             |             |   |
+----+----------------------+-------------+-------------+-------------+---+

+----+----------+--------+--------+--------+--------+--------+--------+
| F  |          |        |        |        |        |        |        |
| CC |          |        |        |        |        |        |        |
| Re |          |        |        |        |        |        |        |
| po |          |        |        |        |        |        |        |
| rt |          |        |        |        |        |        |        |
| 4  |          |        |        |        |        |        |        |
| 3- |          |        |        |        |        |        |        |
| 06 |          |        |        |        |        |        |        |
|    |          |        |        |        |        |        |        |
| A  |          |        |        |        |        |        |        |
| RM |          |        |        |        |        |        |        |
| IS |          |        |        |        |        |        |        |
| CU |          |        |        |        |        |        |        |
| ST |          |        |        |        |        |        |        |
| OM |          |        |        |        |        |        |        |
| ER |          |        |        |        |        |        |        |
| SA |          |        |        |        |        |        |        |
| TI |          |        |        |        |        |        |        |
| SF |          |        |        |        |        |        |        |
| AC |          |        |        |        |        |        |        |
| TI |          |        |        |        |        |        |        |
| ON |          |        |        |        |        |        |        |
| RE |          |        |        |        |        |        |        |
| PO |          |        |        |        |        |        |        |
| RT |          |        |        |        |        |        |        |
|    |          |        |        |        |        |        |        |
| CO |          |        |        |        |        |        |        |
| MP |          |        |        |        |        |        |        |
| AN |          |        |        |        |        |        |        |
| Y: |          |        |        |        |        |        |        |
| XX |          |        |        |        |        |        |        |
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| XX |          |        |        |        |        |        |        |
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| V  |          |        |        |        |        |        |        |
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|    |          |        |        |        |        |        |        |
| S  |          |        |        |        |        |        |        |
| TU |          |        |        |        |        |        |        |
| DY |          |        |        |        |        |        |        |
| A  |          |        |        |        |        |        |        |
| RE |          |        |        |        |        |        |        |
| A: |          |        |        |        |        |        |        |
| XX |          |        |        |        |        |        |        |
| XX |          |        |        |        |        |        |        |
| XX |          |        |        |        |        |        |        |
| XX |          |        |        |        |        |        |        |
| XX |          |        |        |        |        |        |        |
| XX |          |        |        |        |        |        |        |
| Su |          |        |        |        |        |        |        |
| bm |          |        |        |        |        |        |        |
| is |          |        |        |        |        |        |        |
| si |          |        |        |        |        |        |        |
| on |          |        |        |        |        |        |        |
| X  |          |        |        |        |        |        |        |
| XX |          |        |        |        |        |        |        |
|    |          |        |        |        |        |        |        |
| P  |          |        |        |        |        |        |        |
| ER |          |        |        |        |        |        |        |
| IO |          |        |        |        |        |        |        |
| D: |          |        |        |        |        |        |        |
| Fr |          |        |        |        |        |        |        |
| om |          |        |        |        |        |        |        |
| m  |          |        |        |        |        |        |        |
| mm |          |        |        |        |        |        |        |
| yy |          |        |        |        |        |        |        |
| yy |          |        |        |        |        |        |        |
| To |          |        |        |        |        |        |        |
| m  |          |        |        |        |        |        |        |
| mm |          |        |        |        |        |        |        |
| yy |          |        |        |        |        |        |        |
| yy |          |        |        |        |        |        |        |
| T  |          |        |        |        |        |        |        |
| AB |          |        |        |        |        |        |        |
| LE |          |        |        |        |        |        |        |
| I  |          |        |        |        |        |        |        |
|    |          |        |        |        |        |        |        |
| C  |          |        |        |        |        |        |        |
| OS |          |        |        |        |        |        |        |
| A: |          |        |        |        |        |        |        |
| XX |          |        |        |        |        |        |        |
| XX |          |        |        |        |        |        |        |
| PA |          |        |        |        |        |        |        |
| GE |          |        |        |        |        |        |        |
| 1  |          |        |        |        |        |        |        |
| OF |          |        |        |        |        |        |        |
| 1  |          |        |        |        |        |        |        |
+----+----------+--------+--------+--------+--------+--------+--------+
| *  |          |        |        |        |        |        |        |
| *T |          |        |        |        |        |        |        |
| AB |          |        |        |        |        |        |        |
| LE |          |        |        |        |        |        |        |
| I  |          |        |        |        |        |        |        |
| -- |          |        |        |        |        |        |        |
| S  |          |        |        |        |        |        |        |
| UM |          |        |        |        |        |        |        |
| MA |          |        |        |        |        |        |        |
| RY |          |        |        |        |        |        |        |
| CU |          |        |        |        |        |        |        |
| ST |          |        |        |        |        |        |        |
| OM |          |        |        |        |        |        |        |
| ER |          |        |        |        |        |        |        |
| SA |          |        |        |        |        |        |        |
| TI |          |        |        |        |        |        |        |
| SF |          |        |        |        |        |        |        |
| AC |          |        |        |        |        |        |        |
| TI |          |        |        |        |        |        |        |
| ON |          |        |        |        |        |        |        |
| SU |          |        |        |        |        |        |        |
| RV |          |        |        |        |        |        |        |
| EY |          |        |        |        |        |        |        |
| ** |          |        |        |        |        |        |        |
+----+----------+--------+--------+--------+--------+--------+--------+
| R  | Classi   | COLUMN |        |        |        |        |        |
| OW | fication |        |        |        |        |        |        |
+----+----------+--------+--------+--------+--------+--------+--------+
|    |          | Resid  |        | Small  |        | Large  |        |
|    |          | ential |        | Bu     |        | Bu     |        |
|    |          |        |        | siness |        | siness |        |
+----+----------+--------+--------+--------+--------+--------+--------+
|    |          | Number | P      | Number | P      | Number | P      |
|    |          |        | ercent |        | ercent |        | ercent |
|    |          | Su     |        | Su     |        | Su     |        |
|    |          | rveyed | Dissat | rveyed | Dissat | rveyed | Dissat |
|    |          |        | isfied |        | isfied |        | isfied |
|    |          | (ab)   |        | (ad)   |        | (af)   |        |
|    |          |        | (ac)   |        | (ae)   |        | (ag)   |
+----+----------+--------+--------+--------+--------+--------+--------+
|    |          |        |        |        |        |        |        |
+----+----------+--------+--------+--------+--------+--------+--------+
|    |          |        |        |        |        |        |        |
+----+----------+--------+--------+--------+--------+--------+--------+
| 00 | Reserved | N/A    | N/A    | N/A    | N/A    | N/A    | N/A    |
| 20 |          |        |        |        |        |        |        |
+----+----------+--------+--------+--------+--------+--------+--------+
| 00 | Insta    |        |        |        |        |        |        |
| 40 | llations |        |        |        |        |        |        |
+----+----------+--------+--------+--------+--------+--------+--------+
| 00 | Repairs  |        |        |        |        |        |        |
| 60 |          |        |        |        |        |        |        |
+----+----------+--------+--------+--------+--------+--------+--------+
| 00 | Business |        |        |        |        |        |        |
| 80 | Office   |        |        |        |        |        |        |
+----+----------+--------+--------+--------+--------+--------+--------+

**APPENDIX B**

**PROPOSED CORE SERVICE QUALITY REPORTING REQUIREMENTS**

**Disaggregated into Residential/Business:**

**Installation**

**%Missed Installations \[# of Missed Installations / \# of
Installations\]**

**Installation Intervals \[Average or % within specified number of
days\]**

**Trouble Reports**

> **% Initial Trouble \[# of Initial Trouble (disaggregated into
> out-of-service trouble**
>
> **and all other trouble) / \# of Access Lines\]**

**Out-of-Service Intervals \[Average\]**

**Repairs**

**%Missed Repairs \[# of Missed Repairs / \# of Repair Commitments\]**

**Repair Intervals \[Average or % within specified number of days\]**

##### APPENDIX C {#appendix-c .unnumbered}

#### NARUC SERVICE QUALITY WHITE PAPER {#naruc-service-quality-white-paper .unnumbered}

Adopted in Convention November 11, 1998

NARUC Technology Policy Subgroup \"Service Quality White Paper\"

I. PREAMBLE

The Telecommunications Act of 1996 (\"1996 Act\") called for sweeping
changes in the way telephone services are delivered, with the principal
focus both on ensuring Universal Service and opening markets to
competition. Furthermore, the 1996 Act promoted higher quality service
to American telecommunications consumers. In this environment,
regulators at both the state and federal levels will be taking a number
of innovative actions to implement the Act\'s provisions.

This paper suggests that, by measuring and reporting telecommunications
service quality, all stakeholders can assure themselves service quality
is meeting customers\' needs and identify areas where there may be
weaknesses in need of corrective action. A highly-publicized service
quality reporting program will provide consumers with the information
necessary for making informed and rational choices. In addition,
publicizing service quality performance will both draw attention to
potential problem areas before impacting consumers and provide a strong
incentive for carriers to improve quality year after year.

The Technology Policy Subgroup suggests in this White Paper that
telecommunications carriers provide Service Quality measurements to the
FCC, and that a report of these performance measures be made available
to the public. This will allow interested parties to assess current
service quality levels among the states, and identify increasing or
decreasing trends over time.

The measures being suggested for inclusion meet the following criteria:

o They are considered by the states to be meaningful and significant
indicators of service quality, and experience suggests that failures in
these areas result in customer dissatisfaction and complaints.

o They are relatively consistent, in both use and definition, among the
states.

o Most, if not all, telephone companies already capture this data for
internal management purposes, and report it to state and/or federal
regulators. (This is not intended to require that a company not already
reporting for state or federal purposes would be required to do so for
this report.)

II\. SERVICE QUALITY REPORTING IN GENERAL

In March 1998, NARUC urged the collection of service quality data from
incumbent local exchange carriers (\"ILECs\") and competitive local
exchange carriers (\"CLECs\"). Because of the importance of monitoring
the service quality trends in a timely manner, the Technology Policy
Sub-Committee recommends that ILECs and CLECs collect service quality
data on a monthly basis and, to minimize their reporting burden, report
the monthly service quality data to Federal and state regulatory
commissions on a quarterly basis. In addition, the underlying data used
to develop such service quality reports should be retained for a period
of two years and made available upon request to federal and state
regulators.

III\. PERFORMANCE DATA

The Technology Policy Sub-Committee\'s Service Quality Working Group has
identified five major categories of performance data useful for
measuring the quality of telecommunications service. A brief description
accompanies each recommended category. Key definitions are provided in
Section IV of this White Paper.

1\. INSTALLATION

Reporting data about the installation of basic service allows
commissions to evaluate the adequacy of the carrier\'s telephone plant
facilities and workforce, and the carrier\'s success at meeting customer
expectations.

a\) Installation orders for basic service

Report the number of all installation orders for basic service occurring
within the reporting period. Installation orders include new orders,
transfer orders, and change orders. Disaggregate into business and
residential classifications and, where feasible, rural and urban.

b\) Installation orders for basic service completed within \'X\' working
days

Report the number of installation orders for basic service completed
within 5 working days. The working group recognizes that other time
periods, such as 3 days, may be appropriate in some states. Disaggregate
into business and residential classifications and, where feasible, rural
and urban.

c\) Held Orders (30 days)

Report the number of requests or orders for basic service delayed over
30 calendar days. In some states, monitoring requests or orders for
basic service delayed over 60 or 90 calendar days may be appropriate.

d\) Missed Installation Commitments

Report (1) the number of missed installation commitments, and (2) the
total installation commitments during the reporting period. Disaggregate
into business and residential classifications and, where feasible, rural
and urban.

2\. MAINTENANCE & REPAIR

Reporting data about the maintenance and repair of basic service allows
commissions to evaluate the adequacy of the carrier\'s telephone plant
facilities and workforce, and the carrier\'s success at providing
continual service for its customers.

a\) Trouble Reports

Report the number of initial and repeat trouble reports occurring within
the reporting period. Disaggregate into business and residential
classifications and, where feasible, rural and urban.

Most telecommunications carriers have company procedures in which
certain calls to the repair center are not counted as true \"troubles.\"
State commissions and U.S. Territories have encountered significant
discrepancies in the exceptions found in audits of telecommunications
carriers. One carrier may have a list of twenty or more reasons for
excluding a trouble ticket from the report, while another utility may
have only two or three acceptable exceptions. In order to facilitate
benchmarking carrier performance and analysis of service quality data,
the Technology Policy Subgroup suggests that telecommunications carriers
simply pass along all trouble report data. By excluding the use of such
exceptions, the Technology Policy Subgroup anticipates that the accuracy
of the reported service quality data will increase, while the reporting
burden on the carrier will decrease.

1\. Initial Trouble Reports

1.01 Number of Out-of-Service Initial Trouble Reports

1.02 Total Initial Trouble Reports

1.03 Total Subsequent Initial Trouble Reports

2\. Repeat Trouble Reports

2.01 Number of Out-of-Service Repeat Trouble Reports

2.02 Total Repeat Trouble Reports

2.03 Total Subsequent Repeat Trouble Reports

3\. Access Lines

3.01 Total Number of Access Lines Served by the Reporting Carrier

b\) Repair intervals

The carrier\'s repair interval provides a measure of the carrier\'s
operating procedures and workforce levels. Expected performance levels
may vary according to the state and the size of the reporting carrier.
Disaggregate into business and residential classifications and, where
feasible, rural and urban.

1\. Number of Out-of-Service Troubles for more than 24 hours

Report the number of out-of-service troubles that remain out-of-service
for 24 hours.

2\. Average Repair Interval

Report the average duration, in hours, to repair all basic service
troubles.

c\) Missed Repair Commitments

The number of missed repair commitments measures the adequacy of the
carrier\'s workforce and the efficiency of its maintenance and repair
operations. Report (1) the number of missed repair commitments, and (2)
the total number of repair commitments during the reporting period.
Disaggregate into business and residential classifications and, where
feasible, rural and urban.

3\. NETWORK PERFORMANCE

The number and duration of switch outages and interoffice transmission
facility outages indicate the carrier\'s success at providing continual
access to the full capabilities and benefits of the network. Besides
these categories, other indicators of network performance, such as trunk
blockage, provide valuable information about the end-to-end performance
of the public network. Disaggregate into business and residential
classifications and, where feasible, rural and urban.

a\) Switch and Line Concentrator Outages

Report the time, date, location, and duration of all switch and line
concentrator outages occurring for two or more minutes in duration.
Annotate the cause of the switch outages, if known. Report switch
outages resulting from regularly-scheduled maintenance separately from
unscheduled switch outages.

b\) Interoffice Transmission Facility Outages

Report the time, date, location, and duration of all interoffice
transmission facility outages occurring for 6 hours or more in duration,
affecting 500 or more working channels for ten minutes or longer, or
that totally isolate a switch or community. Annotate the cause of the
facility outage, if known.

4\. CUSTOMER PERCEPTION

Customer experience with a telecommunications carrier may not always be
reflected in installation, maintenance, and network performance data.
Monitoring customer complaints to State commissions and U.S. Territories
and the results of telephone surveys provides two methods for assessing
consumer perception of telecommunications service quality.

a\) Customer Complaints

Report the number of customer contacts to the state commission that were
referred to the carrier for action and/or investigated by the state
commission. Disaggregate into business and residential classifications
and, where feasible, rural and urban.

b\) Customer Surveys

Report, by state, the percentage of satisfied and dissatisfied customers
gathered from the company\'s internally conducted telephone satisfaction
survey. Disclose sample size, confidence level, and margin of error.
Disaggregate into business and residential classifications and, where
feasible, rural and urban.

5\. ANSWER TIME PERFORMANCE

Customers calling companies can obtain required service through both
automated systems and live attendants. To capture the performance of all
forms of systems, the working group recommends the following performance
measures as a way to monitor answer time performance.

Report the following measures for the business (including billing) and
repair offices:

a)Total calls attempted

b\) Total calls answered by recorded information

c\) Total calls live-answered by attendants

d\) Total calls abandoned or dropped

e\) Average waiting time for all calls answered live, as measured from
the time the customer chooses to talk to a live operator.

IV\. DEFINITIONS

Access Lines: An access line is a channel of varying size with an
associated telephone number. Access lines to be counted: All public
switched network lines, including residence, business, Centrex, ISDN,
Payphone, and voice-grade PBX trunks.

Basic Service: The provision of access to: one party line service,
local/toll calling, local usage, tone dialing, emergency services,
assistance services, telecommunications relay services, directory
listings, privacy protections and non-published service associated with
the public switched network.

Held Order: Requests or orders for basic service delayed over 30
calendar days because of telephone utility plant or workforce problems.

Missed Installation Commitment: A missed installation commitment occurs
when basic local exchange service is not provided to the consumer\'s
interface on or before the date and time of the commitment with the
customer.

Missed Repair Commitment: A missed repair commitment occurs when a
customer trouble is not repaired on or before the date and time of the
commitment with the customer.

Out-of-Service: A classification of a trouble report where the customer
indicates either: (1) an inability to complete incoming or outgoing
calls; or (2) the presence of interference which causes connected calls
to be incomprehensible.

Trouble: A trouble is an impairment of the telephone network, or a
deviation from its design specifications.

Trouble Report: The record of when the repair office personnel receives
notification of a trouble or perceived trouble by a subscriber, third
party, or employee acting as a subscriber or when other employees
receive notification of a trouble or perceived trouble by a subscriber,
third party, or employee acting as a subscriber and refers the report to
the repair office.

Initial Trouble Report: The first customer trouble report associated
with a specific trouble on a subscriber line for which there is no
pending trouble report.

Repeat Trouble Report: Customer trouble reports received within thirty
days after the resolution of an initial trouble report on the same line.

Subsequent Trouble Report: Customer trouble report made after an initial
or repeat trouble report, but before the carrier has resolved the
initial or repeat trouble report.

Urban/Rural Areas: Metropolitan Statistical Areas and non-Metropolitan
Statistical Areas are existing categories that can be used to facilitate
comparisons between urban and rural areas. Metropolitan Statistical
Areas (\"MSAs\") are designated by the Office of Management and Budget
in a list released following each decennial census. As a general rule,
an MSA includes at least one city with a minimum population of 50,000,
or an urbanized area with a population of at least 50,000. All counties
not part of an MSA are categorized as non-MSA areas. Carriers are
already familiar with the MSA and non-MSA categories because the FCC\'s
current reporting program uses MSA and non-MSA categories to depict
rural and urban results. Besides the MSA and non-MSA categories, States
may wish to use other methods for distinguishing between urban and rural
areas, such as the Census Bureau definitions, including central city.

**APPENDIX D**

**INITIAL REGULATORY FLEXIBILITY ANALYSIS**

As required by the Regulatory Flexibility Act (RFA),[^47] the Commission
has prepared this present Initial Regulatory Flexibility Analysis (IRFA)
of any possible significant economic impact on small entities by the
policies and rules proposed in this Notice of Proposed Rulemaking
(Notice). Written public comments are requested on this IRFA. Comments
must be identified as responses to the IRFA and must be filed by the
deadlines for comments on this Notice, which are set out in paragraph 49
of the Notice. The Commission will send a copy of this Notice, including
this IRFA, to the Chief Counsel for Advocacy of the Small Business
Administration.[^48] In addition, this Notice and IRFA (or summaries
thereof) will be published in the Federal Register.[^49]

# I. Need for, and Objectives of, the Proposed Action: {#i.-need-for-and-objectives-of-the-proposed-action .unnumbered}

The Commission has initiated this proceeding to determine whether it
should improve the current service quality monitoring program. The
Commission's goal is to ensure that the monitoring program will be
uniform and provide the information needed to carry out statutory and
policymaking responsibilities. The Commission notes that as competition
develops in the local exchange market, consumers will benefit from the
ability to compare carriers' service quality. This should in turn lead
to the availability of higher quality services for consumers.

**II. Legal Basis:**

The legal basis for the action as proposed for this rulemaking is
contained in sections 4(i), 4(j), 201(b), 303(r), and 403 of the
Communications Act of 1934, as amended, 47 U.S.C. §§ 154(i), 154(j),
201(b), 303(r), and 403.

III\. Description and Estimate of the Number of Small Entities to which
the Proposed Action May Apply:

Currently, only price cap incumbent local exchange carriers (LECs) file
service quality reports, the Automated Reporting Management Information
System (ARMIS) [^50] 43-05 Report (Service Quality) and the ARMIS 43-06
Report (Customer Satisfaction). The Commission seeks comment on whether
additional carriers, *e.g.*, all LECs, should comply with the proposed
service quality reporting requirements and if compliance should be on a
mandatory or voluntary basis. Below is a detailed description of the
types of entities that could be required to comply with the proposed
reporting requirement (either on a mandatory or voluntary basis).

The RFA directs agencies to provide a description of, and, where
feasible, an estimate of the number of small entities that may be
affected by the proposed rules, if adopted.[^51] To estimate the number
of small entities that may be affected by the proposed rules, we first
consider the statutory definition of \"small entity\" under the RFA. The
RFA generally defines \"small entity\" as having the same meaning as the
term \"small business,\" \"small organization,\" and \"small
governmental jurisdiction.\"[^52] In addition, the term \"small
business\" has the same meaning as the term \"small business concern\"
under the Small Business Act, unless the Commission has developed one or
more definitions that are appropriate to its activities.[^53] Under the
Small Business Act, a \"small business concern\" is one that: (1) is
independently owned and operated; (2) is not dominant in its field of
operation; and (3) meets any additional criteria established by the
Small Business Administration (SBA).[^54] The SBA has defined a small
business for Standard Industrial Classification (SIC) categories 4812
(Radiotelephone Communications) and 4813 (Telephone Communications,
Except Radiotelephone) to be small entities when they have no more than
1,500 employees.[^55]

The most reliable source of information regarding the total numbers of
common carrier and related providers nationwide, appears to be data the
Commission publishes in its *Trends in Telephone Service* report.[^56]
According to data in the most recent report, there are 4,144 interstate
carriers.[^57] These carriers include, *inter alia*, local exchange
carriers, wireline carriers and service providers, interexchange
carriers, competitive access providers, operator service providers, pay
telephone operators, providers of telephone toll service, providers of
telephone exchange service, and resellers.

We have included small incumbent LECs in this present RFA analysis. As
noted above, a \"small business\" under the RFA is one that, *inter
alia*, meets the pertinent small business size standard (*e.g*., a
telephone communications business having 1,500 or fewer employees), and
\"is not dominant in its field of operation.\"[^58] The SBA\'s Office of
Advocacy contends that, for RFA purposes, small incumbent LECs are not
dominant in their field of operation because any such dominance is not
\"national\" in scope.[^59] We have therefore included small incumbent
LECs in this RFA analysis, although we emphasize that this RFA action
has no effect on the Commission's analyses and determinations in other,
non-RFA contexts.

[Total Number of Telephone Companies Affected]{.underline}. The United
States Bureau of the Census (Census Bureau) reports that, at the end of
1992, there were 3,497 firms engaged in providing telephone services, as
defined therein, for at least one year.[^60] This number contains a
variety of different categories of carriers, including local exchange
carriers, interexchange carriers, competitive access providers, cellular
carriers, mobile service carriers, operator service providers, pay
telephone operators, personal communications services (PCS) providers,
covered specialized mobile radio (SMR) providers, and resellers. It
seems certain that some of those 3,497 telephone service firms may not
qualify as small entities or small incumbent LECs because they are not
\"independently owned and operated.\"[^61] For example, a PCS provider
that is affiliated with an interexchange carrier having more than 1,500
employees would not meet the definition of a small business. It seems
reasonable to conclude, therefore, that fewer than 3,497 telephone
service firms are small entity telephone service firms or small
incumbent LECs that may be affected by the decisions and rules proposed
in the Notice.

[Wireline Carriers and Service Providers]{.underline}. The SBA has
developed a definition of small entities for telephone communications
companies other than radiotelephone companies. The Census Bureau reports
that, there were 2,321 such telephone companies in operation for at
least one year at the end of 1992.[^62] According to SBA\'s definition,
a small business telephone company other than a radiotelephone company
is one employing no more than 1,500 persons.[^63] All but 26 of the
2,321 non-radiotelephone companies listed by the Census Bureau were
reported to have fewer than 1,000 employees. Thus, even if all 26 of
those companies had more than 1,500 employees, there would still be
2,295 non- radiotelephone companies that might qualify as small
incumbent LECs. It seems certain that some of these carriers are not
independently owned and operated, but we are unable at this time to
estimate with greater precision the number of wireline carriers and
service providers that would qualify as small business concerns under
SBA\'s definition. Consequently, we estimate that there are fewer than
2,295 small entity telephone communications companies other than
radiotelephone companies that may be affected by the decisions and rules
proposed in the Notice.

[Local Exchange Carriers, Interexchange Carriers, Competitive Access
Providers, and Resellers]{.underline}. Neither the Commission nor the
SBA has developed a definition of small LECs, interexchange carriers
(IXCs), competitive access providers (CAPs), or resellers. The closest
applicable definition for these carrier-types under SBA rules is for
telephone communications companies other than radiotelephone (wireless)
companies.[^64] According to recent *Trends in Telephone Service* data,
1,348 incumbent carriers reported that they were in the provision of
local exchange services.[^65] According to the most recent *Trends in
Telephone Service* data, 212 CAP/CLECs carriers and 10 other LECs
reported that they engaged in competitive local exchange services.[^66]
It seems certain that some of these carriers are not independently owned
and operated, or have more than 1,500 employees; however, we are unable
at this time to estimate with greater precision the number of these
carriers that would qualify as small business concerns under SBA\'s
definition. Consequently, we estimate that there are fewer than 1,348
small incumbent LECs, 212 small entity CAPs, and 10 other small entity
LECs that may be affected by the rules proposed in the Notice.

[Rural Radiotelephone Service]{.underline}. The Commission has not
adopted a definition of small entity specific to the Rural
Radiotelephone Service.[^67] A significant subset of the Rural
Radiotelephone Service is the Basic Exchange Telephone Radio Systems
(BETRS).[^68] We will use the SBA\'s definition applicable to
radiotelephone companies, *i.e*., an entity employing no more than 1,500
persons.[^69] There are approximately 1,000 licensees in the Rural
Radiotelephone Service, and we estimate that almost all of them qualify
as small entities under the SBA\'s definition.

## IV. Description of Proposed Reporting, Recordkeeping, and Other Compliance Requirements: {#iv.-description-of-proposed-reporting-recordkeeping-and-other-compliance-requirements .unnumbered}

The focus of this proceeding is whether the Commission should require
LECs to report certain service quality information in a more
consumer-friendly format instead of the format of the current ARMIS
reports. Historically, service quality reporting was limited to the
price cap LECs. With the emergence of competition in the local exchange
market, service quality information on competitive LECs would permit
consumers to compare carriers in their area. The Notice seeks comment on
the costs and benefits of imposing new service quality reporting
requirements on all LECs.[^70] The Notice seeks comment on whether the
Commission should modify its service quality reporting requirements by
reducing the quantity of data requested and if all LECs should report
this information on a mandatory or voluntary basis.

Commenters should discuss whether state commissions currently require
LECs to provide the proposed service quality information. If LECs \--
other than price cap incumbent LECs \-- are required to file this
service quality information with a state commission, is there an
additional cost in preparing and filing the service quality data with
the Commission? Commenters should discuss the costs to small entities of
preparing the proposed service quality reports for federal reporting
purposes.

The Notice sets out in detail, and seeks comment on, the types of
carriers that should report, frequency of reports, and data to be
reported. Under the proposal, there would be fewer categories of data
reported but more carriers may be required to report. The Notice seeks
comment on whether there are other types of service quality information
that consumers would find useful, and if so, what are the benefits,
burdens and feasibility of requiring carriers to collect and disclose
such information.[^71] Commenters should address the benefit of giving
consumers access to service quality data from all carriers providing
local exchange service in their area, including small entities, and
discuss the increased cost, if any, to smaller LECs.

**V. Steps Taken to Minimize Significant Economic Impact on Small
Entities, and Significant Alternatives Considered:**

The RFA requires an agency to describe any significant alternatives that
it has considered in reaching its proposed approach, which may include
the following four alternatives (among others): (1) the establishment of
differing compliance or reporting requirements or timetables that take
into account the resources available to small entities; (2) the
clarification, consolidation, or simplification of compliance or
reporting requirements under the rule for small entities; (3) the use of
performance, rather than design, standards; and (4) an exemption from
coverage of the rule, or any part thereof, for small entities. 5 U.S.C.
§ 603(c).

One of the goals in this proceeding is to consider whether consumers
should have access to service quality information that can be used to
make comparisons between the incumbent LEC and other carriers in their
area. Service quality information is of limited use if the consumers do
not have comparable information on all carriers in their area, including
any small entities that might provide service. With the emergence of
competition in the local exchange market, accurate service quality
information on all LECs would permit consumers to compare carriers. The
Notice seeks comment on the costs and benefits of imposing new service
quality reporting requirements on all LECs[^72] and on whether all LECs
should be required to report service quality data. Under this scenario,
small entities may be required to report service quality data. The
Commission is seeking to balance the consumers' need for information
with the reporting burden on the industry, particularly small entities.
Commenters should discuss how the imposition of service quality
reporting on carriers other than price cap incumbent LECs may be
burdensome, and the costs of compliance. Commenters should discuss
whether certain entities should be exempt from service quality reporting
requirements and how that could be done without compromising the goals
in this proceeding.

One alternative would be to limit service quality reporting to the
incumbent LECs. This alternative, however, would not permit consumers to
compare service providers in their area. The Commission observes that
the effective functioning of competitive markets is predicated on
consumers having access to accurate information. Thus, revising the
current service quality reporting requirements may be essential to allow
consumers to compare service quality among or between carriers and make
informed choices. A second alternative would be to make service quality
reporting voluntary for certain carriers. Commenters advocating limiting
service quality reporting to price cap LECs should discuss how consumers
would have access to service quality data on all LECs in their area if
only the price cap LECs were required to file service quality reports.
Another alternative would be to limit service quality reporting to
carriers whose performance fell below a specified performance benchmark.
This alternative would reduce reporting burdens for carriers, including
small carriers, that do not have significant service quality problems.

This proposed reporting requirement is less than the current service
quality reporting requirement (now limited to price cap LECs).
Commenters should discuss whether the proposed reporting requirements
should be streamlined for small entities and how this could be done
without compromising the goals in this proceeding. Commenters should
address any cost savings to small entities resulting from such
streamlining.

# Federal Rules that May Duplicate, Overlap, or Conflict With the Proposed Rule:

> None.

## SEPARATE STATEMENT OF COMMISSIONER GLORIA TRISTANI {#separate-statement-of-commissioner-gloria-tristani .unnumbered}

### *Re: 2000 Biennial Review -- Telecommunications Service Quality Reporting* {#re-2000-biennial-review-telecommunications-service-quality-reporting .unnumbered}

### *Requirements*, CC Docket No. 00-229 {#requirements-cc-docket-no.-00-229 .unnumbered}

I enthusiastically support the notice of proposed rulemaking we adopt
today. With this proceeding, we are taking a serious look at how the FCC
can provide information to consumers that will empower them in choosing
among competitive telecommunication providers.

This notice asks important questions regarding what types of information
will be useful to consumers in selecting their telecommunications
carriers. Such types of information may include the length of time
customers wait on hold before speaking to a customer service
representative and the number of complaints carriers receive directly
from consumers. Additionally, we inquire into whether we should expand
the types of services about which we collect service quality
information. For example, we ask whether there is service quality
information that will address consumer concerns regarding how time
consuming it often is to initiate broadband services. In each of these
areas we will need to consider the benefits of making such information
publicly available and the burden of reporting such information. I
strongly encourage consumer groups and state commissions that have
experience with these consumer issues to participate fully in this
proceeding.

[^1]: ^?^ The Telecommunications Act of 1996 (1996 Act), Pub. L. No.
    104-104, 110 Stat 56, *codified at* 47 U.S.C. §§ 151 *et seq*.,
    amended the Communications Act of 1934.

[^2]: ^?^ Joint Statement of Managers, S. Conf. Rep. No. 104-230,
    104^th^ Cong. 2d Sess. 1 (1996).

[^3]: ^?^ 47 U.S.C. § 161.

[^4]: ^?^ ARMIS is an automated system established by the Commission in
    1987 for collecting financial and operating data needed to
    administer the accounting, joint cost, separations, rate base
    disallowance, and access charge rules. *See* Automated Reporting
    Requirements for Certain Class A and Tier 1 Telephone Companies,
    *Report and Order*, 2 FCC Rcd 5770 (1987), *recon.*, 3 FCC Rcd 6375
    (1988).

[^5]: ^?^ Compare Appendix A with Appendix B.

[^6]: ^?^ National Association of Regulatory Utility Commissioners,
    S[ERVICE QUALITY WHITE PAPER]{.smallcaps} (rel. Nov. 1998). The
    NARUC White Paper is attached as Appendix C.

[^7]: ^?^ Thirty states currently apply service quality requirements to
    all local exchange carriers. *See* "Recent Developments in
    Telecommunications Service Quality Regulation," The National
    Regulatory Research Institute (July 20, 1998) at 2. In contrast to
    the FCC monitoring program, a number of states have established
    service quality standards for their incumbent local exchange
    companies, requiring certain levels of performance. We note that the
    five state commissions in the Ameritech region have recently been
    confronted with a sharp increase service quality complaints, ranging
    from repair delays to customers going for weeks without service.
    *See* Communications Daily, *Ameritech Region Service Quality
    Crisis*, October 2, 2000; *see also* Knight-Ridder Business News,
    September 29, 2000; Chicago Tribune September 30, 2000, p1. In
    response to the region-wide service quality problems, the five state
    commissions in the region held a joint hearing on service quality
    and issued a joint statement in September 2000. *See*
    http://cis.state.mi.us/mpsc/orders/press/2000/pr.txt.htm.

[^8]: ^?^ *See* "Telecommunications Service Quality," The National
    Regulatory Research Institute (March 1996) at 71.

[^9]: ^?^ In addition, common carriers that operate either transmission
    or switching facilities are required to notify the Commission of
    service outages that potentially affect 30,000 customers or that
    affect special facilities such as airports. Amendment of Part 63 of
    the Commission's Rules to Provide for Notification by Common
    Carriers of Service Disruptions, *Report and Order*, 7 FCC Rcd 2010
    (1992), *Second Report and Order*, 9 FCC Rcd 3911 (1994), *recon.*,
    10 FCC Rcd 11764 (1995). All communications common carriers are
    required to report network outages affecting 30,000 customers for 30
    minutes or longer. *See* 47 C.F.R. § 63.100.

[^10]: ^?^ Policy and Rules Concerning Rates for Dominant Carriers, CC
    Docket No. 87-313, *Second Report and Order*, 5 FCC Rcd 6786 (1990)
    (*LEC Price Cap Order*), *modified on recon.*, 6 FCC Rcd 2637
    (1991). The Commission previously had directed the Common Carrier
    Bureau to establish a service quality monitoring program at the
    divestiture of AT&T.

[^11]: ^?^ *See* Policy and Rules Concerning Rates for Dominant
    Carriers, CC Docket No. 87-313, *Memorandum Opinion and Order*, 6
    FCC Rcd 2974, 2994-95, ¶¶ 50-51 (1991) (*Service Quality Order*).

[^12]: ^?^ *See LEC Price Cap Order*, 5 FCC Rcd at 6827, ¶¶ 341-42, 352.

[^13]: ^?^ *See Service Quality Order*, 6 FCC Rcd at 2995, ¶ 51.

[^14]: ^?^ *See* Truth-in-Billing and Billing Format*,* CC Docket No.
    98-170, *First Report and Order and Further Notice of Proposed
    Rulemaking*, 14 FCC Rcd 7492 (1999) (*TIB Order*).

[^15]: ^?^ We recognized in our Truth-in-Billing and Truth in
    Advertising Proceedings that arming consumers with information can
    help protect against fraud and help them make informed choices. *See
    TIB Order*; *see also* Joint FCC/FTC Policy Statement for the
    Advertising of Dial-around and other Long Distance Services to
    Consumers, File No. 00-EB-TCD-1(PS) (rel. Mar. 1, 2000) (*Truth in
    Advertising* *Joint Statement*).

[^16]: ^?^ *See* 14 C.F.R. § 234.

[^17]: ^?^ *See* 52 FR 34056. Prior to 1984, the DOT used formal
    reporting requirements and performance standards to measure service
    quality in the airline industry. In 1984, the DOT rescinded its
    on-time flight reporting requirements concluding, at the time, that
    increased competition resulting from the deregulation of the airline
    industry provided sufficient economic incentives for carriers to
    schedule realistically, and, that the reporting program "did not
    perform an important function in helping passengers choose between
    competing airlines." Three years later, in 1987, in response to
    increased consumer complaints about flight delays, and the DOT's own
    investigation into carrier scheduling practices, the DOT
    re-implemented a modified set of flight performance reporting
    requirements.

[^18]: ^?^ *See* 14 C.F.R. § 234.

[^19]: ^?^ In Table I of ARMIS Report 43-05, price cap LECs report
    installation and repair data for switched and special access
    services provided to interexchange carriers.

[^20]: ^?^ Appendix A contains the current reporting requirements in
    ARMIS Reports 43-05 and 43-06.

[^21]: ^?^ Appendix B contains the six core streamlined reporting
    requirements.

[^22]: ^?^ *See* 2000 Biennial Regulatory Review -- Comprehensive Review
    of the Accounting Requirements and ARMIS Reporting Requirements for
    Incumbent Local Exchange Carriers: Phase 2 and Phase 3, CC Docket
    00-199, *Notice of Proposed Rulemaking,* FCC 00-364 (rel. October
    18, 2000).

[^23]: ^?^ *See* Letter from Linda Kent, USTA, to Joann Lucanik and Tim
    Peterson, Attachment at 6 (June 9, 2000).

[^24]: ^?^ This is currently reported in ARMIS 43-05, Table II.

[^25]: ^?^ *See* Appendix A.

[^26]: ^?^ *See, e.g.,* FCC Report 43-05, Reporting Procedures (December
    1999); Revision of ARMIS Annual Summary Report (FCC Report 43-01)
    *et al*., *Order,* 12 FCC Rcd 21831 (1997).

[^27]: ^?^ The NARUC White Paper notes that state commissions and U.S.
    Territories have encountered significant discrepancies in the way
    data was reported by carriers discovered through audits of the
    carriers. For example, one carrier may have a list of twenty or more
    reasons for excluding a trouble ticket from the report, while
    another utility may have only two or three exceptions.

[^28]: ^?^ *See* Local Competition and Broadband Reporting, CC Docket
    No. 99-301, *Report and Order*, 15 FCC Rcd 7717 (2000) (*Local
    Competition and Broadband Data Gathering Program*).

[^29]: ^?^ *Id*. While the data gathering efforts in the *Local
    Competition and Broadband Data Gathering Program* cover a broader
    range of providers than ARMIS (*e.g*., large and small providers,
    and entities other than incumbent local exchange carriers), it
    collects only a very limited amount of information from each
    reporting firm and no data at all on such subjects as revenues and
    service quality.

[^30]: ^?^ In our *Second 706 Report*, we defined high-speed services as
    infrastructure capable of delivering a speed in excess of 200 kbps
    in each direction. We denominated as \"high-speed\" those services
    capable of delivering transmission speeds in excess of 200 kbps in
    at least one direction. Advanced telecommunication capability and
    advanced services thus are a subset of the larger \"high-speed\"
    category. *See* Inquiry Concerning the Deployment of Advanced
    Telecommunications Capability to All Americans in a Reasonable and
    Timely Fashion, and Possible Steps to Accelerate Such Deployment
    Pursuant to Section 706 of the Telecommunications Act of 1996, CC
    Docket No. 98-146, *Second Report*, FCC 00-290 (rel. Aug. 21, 2000)
    (*Second 706 Report*).

[^31]: ^?^ *See* Letter from Linda Kent, USTA, to Joann Lucanik and Tim
    Peterson, FCC, Attachment at 6, (June 9, 2000).

[^32]: ^?^ The airline industry, for example, sets a threshold based on
    one percent of domestic revenues*.*

    *See* 14 C.F.R. § 234.3.

[^33]: ^?^ In our Local Competition and Broadband Reporting proceeding,
    however, we concluded that voluntary surveys were an inadequate
    source of data. *See Local Competition and Broadband Data Gathering
    Program*, 15 FCC Rcd at 7727, ¶¶ 15.

[^34]: ^?^ Currently, the incumbent local exchange carriers that have 2
    percent or more of the nations' access lines are Bell South, Qwest,
    Verizon, SBC Communications, and Sprint.

[^35]: ^?^ We note that in the section 271 context, the issue of whether
    disparities in performance are due to conduct of the BOC or
    competitors has been a fact-intensive, highly contested issue.

[^36]: ^?^ The Telecommunications Act of 1996 (1996 Act), Pub. L. No.
    104-104 § 402(b)(2).

[^37]: ^?^ ARMIS information is currently available on our website at
    [www.fcc.gov/ccb/armis](http://www.fcc.gov/ccb/armis).

[^38]: ^?^ Pursuant to section 1.17 of our rules, carriers are obliged
    to file accurate information with the Commission. *See* 47 C.F.R. §
    1.17. Section 1.80 provides for application of the statutory maximum
    forfeiture for "misrepresentation/lack of candor." *See* 47 C.F.R. §
    1.80(b)(4).

[^39]: ^?^ In 1998, for example, interexchange carriers purchased
    \$25.25 billion in interstate access services from incumbent LECs.
    *See* FCC, [Statistics of Communications Common
    Carriers]{.smallcaps} 154 (1998/1999 ed.).

[^40]: ^?^ *See* 47 U.S.C. § 256.

[^41]: ^?^ *See* paragraph 36, *supra.*

[^42]: ^?^ *See* NARUC White Paper in Appendix C.

[^43]: ^?^ *See, e.g*., Policy and Rules Concerning the Interstate
    Exchange Marketplace, *Second Order on Reconsideration and Erratum*,
    14 FCC Rcd 6004 (1999). *See also* *TIB Order* at 7497, ¶ 7.

[^44]: ^?^ [Modern Industrial Organization]{.smallcaps} at 554.

[^45]: ^?^ *See generally* 47 C.F.R. §§ 1.1202, 1.1203, 1.1206.

[^46]: ^?^ The RFA, *see* 5 U.S.C. § 601 *et seq.*, has been amended by
    the Contract With America Advancement Act of 1996, Pub. L. No.
    104-121, 110 Stat. 847 (1996) (CWAAA). Title II of the CWAAA is the
    Small Business Regulatory Enforcement Fairness Act of 1996 (SBREFA).

[^47]: ^?^ *See* 5 U.S.C. § 603. The RFA, *see* 5 U.S.C. § 601 *et
    seq.*, has been amended by the Contract with America Advancement Act
    of 1996, Pub. L. No. 104-121, 110 Stat. 847 (1996) (CWAAA). Title II
    of the CWAAA is the Small Business Regulatory Enforcement Fairness
    Act of 1996 (SBREFA).

[^48]: ^?^ *See* 5 U.S.C. § 603(a).

[^49]: ^?^ *Id.*

[^50]: ^?^ ARMIS is an automated system established by the Commission in
    1987 for collecting financial and operating data. *See* Automated
    Reporting Requirements for Certain Class A and Tier 1 Telephone
    Companies, *Report and Order*, 2 FCC Rcd 5770 (1987), *recon.*, 3
    FCC Rcd 6375 (1988).

[^51]: ^?^ 5 U.S.C. § 603(b)(3).

[^52]: ^?^ 5 U.S.C. § 601(6).

[^53]: ^?^ 5 U.S.C. § 601(3) (incorporating by reference the definition
    of \"small business concern\" in 15 U.S.C. § 632). Pursuant to 5
    U.S.C. § 601(3), the statutory definition of a small business
    applies \"unless an agency after consultation with the Office of
    Advocacy of the Small Business Administration and after opportunity
    for public comment, establishes one or more definitions of such term
    which are appropriate to the activities of the agency and publishes
    such definition in the Federal Register.\"

[^54]: ^?^ 15 U.S.C. § 632.

[^55]: ^?^ 13 C.F.R. § 121.201.

[^56]: ^?^ FCC, Common Carrier Bureau, Industry Analysis Division,
    *Trends in Telephone Service*, Table 19.3 (March 2000).

[^57]: ^?^ *Id*.

[^58]: ^?^ 5 U.S.C. § 601(3).

[^59]: ^?^ *See* letter from Jere W. Glover, Chief Counsel for Advocacy,
    SBA, to William E. Kennard, Chairman, FCC (May 27, 1999). The Small
    Business Act contains a definition of \"small business concern,\"
    which the RFA incorporates into its own definition of \"small
    business.\" *See* U.S.C. § 632(a) (Small Business Act); 5 U.S.C. §
    601(3) (RFA). SBA regulations interpret \"small business concern\"
    to include the concept of dominance on a national basis. 13 C.F.R. §
    121.102(b). Since 1996, out of an abundance of caution, the
    Commission has included small incumbent LECs in its regulatory
    flexibility analyses. *See, e.g*., Implementation of the Local
    Competition Provisions of the Telecommunications Act of 1996, CC
    Docket 96-98, *First Report and Order*, 11 FCC Rcd 15499, 16144-45
    (1996).

[^60]: ^?^ United States Department of Commerce, Bureau of the Census,
    1992 Census of Transportation, Communications, and Utilities:
    Establishment and Firm Size, at Firm Size 1-123 (1995) (*1992
    Census*).

[^61]: ^?^ 15 U.S.C. § 632(a)(1).

[^62]: ^?^ *1992 Census* at Firm Size 1-123.

[^63]: ^?^ 13 C.F.R. § 121.201, SIC Code 4813.

[^64]: ^?^ 13 C.F.R. § 121.201, SIC Code 4813.

[^65]: ^?^ FCC, Common Carrier Bureau, Industry Analysis Division,
    *Trends in Telephone Service*, Table 19.3 (March 2000).

[^66]: ^?^ *Id.*

[^67]: ^?^ The Rural Radiotelephone Service is defined in section 22.99
    of the Commission's rules, 47 C.F.R. § 22.99.

[^68]: ^?^ BETRS is defined in sections 22.757 and 22.759 of the
    Commission's rules, 47 C.F.R. §§ 22.757, 22.759.

[^69]: ^?^ 13 C.F.R. § 121.201, SIC Code 4812.

[^70]: ^?^ *See* paragraph 29, *supra.*

[^71]: ^?^ *See* paragraph 23, *supra.*

[^72]: ^?^ *See* *id.*