Inbound Call Quality Findings September 2011

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Inbound Call Quality Findings

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ANPI ZONE Headquarters 3130 Pleasant Run, Springfield, IL 62711 877‐FON‐ANPI anpisolutions.com 2

Inbound Call Quality

September 2011

Summary

Between 4PM CDT Friday, September 2 and 2PM CDT Wednesday, September 7, 2011 (a Labor Day holiday weekend), ANPI ZONE asked customers to submit information and data about inbound call quality issues they have experienced. We received 42 responses from customers across 25 states. ANPI ZONE’s CEO, Dave Lewis, and Tier One Manager, Stacy Graham, presented this information to the FCC on September 7, 2011. Following are the responses we received permission to share with our customer base. If you would like to submit inbound call quality examples that we can provide to the FCC, please email [email protected].

Responses

“We have had several complaints from our subscribers all blaming us. I am worried that a call will not be completed and someone's life will be at stake. Businesses are losing money because of it as well.” Mike Henning, Interim General Manager and Director of Plant Facilities 3 Rivers Communications Fairfield, MT “Most of the issues seem to be from cell phones (biggest offender is Verizon) calling into our customers. What our customers are experiencing: Phone rings once or twice/either no one there or there is a terrible connection with a lot of noise and static. Caller ID is not showing the number of the person calling but shows a completely different number. Callers will get a fast busy signal even though our customer claims no one was on the line. Taking callers several attempts to call and get a good connection. Faxing issues because of latency in the calls.” Vicky Miller, Facility Resources Supervisor 3 Rivers Communications Fairfield, MT “Originating # 508 877 4076 to terminating # 410 658 6068 at 7:45 pm 9/5/11 gets recording, ‘this number is not in service’. Inbound # 941 587 8804 at 5:30 pm 9/5/11 to terminating # 410 658 8522 gets one way transmission then cuts off. Originating # 302 743 4862 to terminating number 410 658 2483 drops call at 2:30 pm 9/4/11. Originating # 302 368 0398 to terminating caller gets recording and cuts off.” Kevin Rolfe, Dispatcher Armstrong Telephone Company Rising Sun, MD

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Inbound Call Quality

September 2011

“We have been experiencing poor inbound call quality for the past two years. Most of these issues can be attributed to Least Cost Routing. Some of the main companies that we received reports of failed inbound calls are Verizon, Qwest, CenturyLink, and Alltel. This issue has been seen on interstate and intrastate calls as well as landline and wireless calls.” Steve Kapple, CO Technician BW Telcom Long Distance, Inc. Benkelman, NE “Please find attached a copy of the presentation Canby Telcom made to the Oregon Public Utility Commission regarding service quality issues and the service and economic impact of call termination issues. The OPUC used this presentation as the primary information to open a formal docket to investigate call termination issues in Oregon. The Nebraska Commission has also used Canby's data, and NARUC also used this information to unanimously adopt a resolution on call termination issues at their most recent meeting in July. You will find a wide variety of data we have collected, including specific examples of customer troubles, economic harm to the end‐user customers, economic impact to service providers, issues related to least cost routing, etc. The OPUC Commissioners and staff were particularly interested in the end‐user examples we provided that demonstrated economic harm to small businesses who have been unable to receive (and send) fax transmissions due to least cost routing and the technical issues underlying least cost routing. Thank you for taking the issue to the FCC. We have also been working with NTCA to schedule an ex parte with the FCC, but have not yet had an opportunity to present our entire findings to the FCC. Our President, Keith Galitz, did outline some of the call termination issues Canby has experienced in another ex parte on June 22, 2011.” Brandon Zupancic, Director of Network Operations Canby Telephone Association Canby, OR “We have several customers calling each week complaining about incoming calls. Dead air, one way audio, long delay on audio. Originating caller cannot get through and then calls dropped.” Janet McFarland, Customer Support Representative Centracom Interactive Fairview, UT “Being a small rural cooperative, we are experiencing call termination problems that affect our business greatly.” Tina Jordan, Director of Finance Chariton Valley Macon, MO

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Inbound Call Quality

September 2011

“A number of us from Minnesota met at the FCC on July 13th_{to share all of our tests on this issue.} We still battle it on and off and continue to build a database of issues — they (FCC) need to enforce the originating LD carrier to “own” the call until it is terminated — even when they use underlying carriers!” Kevin, Larson, CEO/General Manager Consolidated Telecommunications Company Brainerd MN “Since Clearwave began using ANPI for LD traffic (March 2008), our customers have experienced poor call quality issues on a regular, sporadic basis. However, these are NOT just INBOUND, but OUTBOUND, as well.” Kevin Edwards, Transport Engineer II Clearwave Communications Harrisburg, IL “One September 1 calls terminating to our 260‐353 NXX were not terminating as expected. With ANPI’s assistance, trouble tickets were submitted and eventually the issue was corrected. Without ANPI’s assistance we, as the terminating carrier, have little recourse in finding and correcting a network problem. Low cost (VOIP) carriers have created a growing problem in the telecom infrastructure and without FCC and State intervention it will only get worse.” Lee VonGunten, General Manager Craigville Telephone Company Inc. Craigville, IN “We had approximately 20 complaints of Incoming Call Failures in April 2011, 6 in June 2011, and 2 in July 2011. None in August 2011 and, so far, 1 in September 2011.” Kelly Powers, Customer Service Representative Foothills Telephone Cooperative Staffordsville, KY “GBTA has several customers in our 620‐xxx exchanges that continue to have incoming call issues on a daily basis. Rings on the called party end but nobody there when answered. Calling party reports ring back but nobody ever answers the call. Voice delay in the call. One way conversation.” Kirby Hagans, Plant Manager Golden Belt RushCenter, KS “For the past few months, we have had the poorest LD service in my 31 years in the industry. LD carriers are using Least Cost Routing to terminate calls into our network. Our customers are fortunate to get 1 in 3 incoming LD calls delivered. When the call is completed, it is likely so poor in quality that the customer has to hang up. Our customers are fed up. Doesn't the law state that rural America shall have comparable rates and comparable service? What are we supposed to tell our customers?” Ron Hinds, Assistant General Manager Grand River Mutual Telephone Corporation Princeton, MO

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Inbound Call Quality

September 2011

“This problem was really bad for our customers in Nov/Dec 2010. It has gotten better, but there are still issues and we are still getting calls from our customers. We are now up to over 600 different complaints over the last year.” Scott Sherman, General Manager Hardy Telecommunications Lost River, WV “InterBel was involved with the recent NECA test call study for call termination problems. I have attached the results of the two numbers I used to call from; one being a Magic Jack phone number I subscribed to and the other an InterBel number assigned to MCI long distance. As indicated the MCI worked for every call except 3, which gave back a Ring‐No‐Answer condition. However, the Magic Jack failed miserably and only worked 7 times out of 29 different numbers dialed around the country (from participating NECA member companies using landlines for the test). Also interesting with Magic Jack was the intercept recording they played – which is typed out and yellow highlighted on the spreadsheet. If you have any questions let me know. I will try and get the results to you of the other two lines we used for testing (whereby they called the same list of 27 phone numbers around the county). One was assigned to Global Crossing Long Distance and the other QWEST. You might ask Dave Lewis to contact Rick Kelly at NECA to learn the entire results of all the testing that was performed on the call termination problem last month (August). Rick can be reached at 303‐893‐4413.” Randy Wilson, General Manager Interbel Telephone Eureka, MT “We have been receiving a number of complaints and have been turning that information over to Tim Schwane of NECA. Have been trying to determine the long distance carriers, they are so varied...no pattern. Am sending a copy of a letter one of our subscribers received in response to their complaint to the FCC, it's interesting.” Mary Meyer, CEO Madison Telephone LLC Madison, KS

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Inbound Call Quality

September 2011

“Below are comments that we submitted in our State Association's letter to the FCC. 1. A daughter checks on her 90 year‐old mother by long distance phone calls on a daily basis. The long distance provider sends the call to a least cost router. On an almost monthly basis, the call cannot be completed. Although complaints have been made to the long distance provider, the problem persists. 2. A dentist working in one service territory could not complete calls to his home in another service territory. Although complaints have been made, the problem has continued at least twice. 3. Alarm and fire systems at some local schools could not call out or be polled because of poor VoIP provided by the long distance carrier. The long distance provider had to reroute the calls over a feature group trunk to correct the problem. The local telephone provider spent about a month trying to convince the schools that the problem was with their long distance provider and not the local telephone company. 4. At least one of our state parks cannot receive calls from a major metropolitan area in the state. The park is isolated and has no wireless coverage. 5. Local providers are universally getting the blame, receiving up to three or four calls daily from customers who say that their family and friends cannot call them on their home telephone. 6. Some long distance providers will not take calls from our local member companies when they try to contact them regarding these issues.” Brad Lyon, Vice President Moapa Valley Telephone Overton, NV “We have several complaints about choppy voice and faxes that won't work. Rarely a week goes by that we don't have to try and convince customers that it is the caller's LD company that they have to report the trouble to. Of course this has to be done by the calling party not our customer. And if we can convince them of it and they do report it, the distant company just blames us.” Jeff Vergin, Central Office Technician Mosaic Telecom Cameron, WI “Calls just die, one way communication, severe delays.” Jeffery Flanary, Central Office Supervisor MountaiNet Long Distance (Scott County) Gate City, VA “We have seen a decline in the number of these kind of troubles reported to us in the last few months. We were taking daily complaints over the fall of 2010 and winter of 2010/11. Since then we have seen either an improvement in the quality, or our subscribers are becoming educated on the subject. The issue we see the most now is the quality of calls coming into our toll free numbers.” Betz Paulson, Dispatch/Operations Supervisor Norvado Cable, WI

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Inbound Call Quality

September 2011

“48 reports from customers during August complaining callers from New York and New Jersey cannot reach them. Callers report, dead air, out of service recording on known working line or poor transmission on calls that do get through. Trouble reports have increased since the beginning of the Verizon strike.” Tom Lager, General Manager Palmerton Long Distance Palmerton, PA “Here are a few examples of troubles you have received from us over the last few months. Call cuts off cuts in and out clg # 541‐929‐8239 (541‐929‐3135) cld # 541‐807‐3131 Time of call 14:20 Date 09/02/2011 Hello, After reviewing your ticket and the call sample, we have gone ahead and made a route change away from the carrier causing the issue. Could you please retest after 1 hour and let us know the results once you have them. If you have any other questions, please let us know. Thank you. Clg # 541‐487‐4108 cld # 541‐265‐8644 541‐265‐6641 Time of calls approx 9:05 am to 9:15 am 8/22/2011 Hello, I tried reproducing that no ring back issue but wasn’t able to duplicate. We are now waiting for the carrier to provide feedback, so we made an internal route change in 1 hour to provide relief to your customer until we hear back from the carrier. Please retest; keep us posted. Thanks 541‐875‐2424 can’t be heard when calling long distance. From 541‐875‐2424 To 541‐902‐6114 10:16 am 8/19/2011 Hello, We have reviewed the ticket and looked at the call sample. We have made a route change away from the carrier causing the issue and would like to request a retest at this time. Please have your customer retest after 45 minutes and let us know the results when you have them. clg # 563‐5216 cld # 541‐336‐2373 Time of call 9:35 am three attempts got no ring number belongs to Ace Hardware in Toledo, Or Hello again. The call record was located for the example you provided. I made a routing change that will be complete within the next 30 minutes. Could you please retest in about half an hour and let us know your results? Thanks! 541‐265‐4455 huge wait before clicking in to ring tone then they could not hear me Tuesday at 9:50 Hello, Our carrier has completed their investigation and are unable to duplicate the issue at this time. Could you please retest and let us know if the issue is still happening. If the issue is still present please provide a new call sample and we will investigate that call with the carrier. Can you please look into the following trouble? Orig. 541‐929‐8239 Term 503‐226‐7600 TOD 2:50 8‐16‐11 Three calls Call never completes, near and far end never hear ringing. Good Morning, We have made a route change to correct the reported trouble. Please have the customer retest and advise us of the results at your earliest. Thank you!” Jon Cummings, Inside Plant Engineering Superintendent Pioneer Consolidated, Inc. Philomath, OR

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Inbound Call Quality

September 2011

“Started tracking inbound calling problems in February of this year. Have actively recorded 300 complaints, submitted 50 escalations to the FCC on behalf of customers/incoming callers and still have about 37 unresolved issues. latest complaint received was Thursday, 09/01/11. Very time‐ consuming on my end, and very frustrating on customer end.” Deb Gardner, Customer Service Clerk Range Forsyth, MT “Failures just today (Sept 6) on our toll reports and reported by our subscriber. There were 5 calls from Washington state and Utah to our subscriber. The orignating telephone number was changed to another telephone number (5 different numbers in states outside Washington & Utah); the call quality was so bad the originating callers had to hang up and call using their cell phone. The originating number appeared correct on the caller ID from the cell phone calls. Here is the detail of the calls: On an IXC direct trunk group (originating carrier unknown) delivered to our tandem for delivery to our end user (406‐676‐3232 in all 5 cases) from TWO different originating callers: Originating caller's telephone number is 253‐859‐3043 (Washington state): 8/21 at 14:20:20 From number appeared on caller ID as 978‐304‐9389 (Mass. area code) 8/21 at 14:21:25 From number appeared on caller ID as 978‐335‐1169 (Mass. area code) 8/21 at 14:22:20 From number appeared on caller ID as 760‐705‐8888 (California area code) Originating caller's telephone number is 801‐341‐8158 or 8‐1‐857‐5645 9/6 at 6:47:48 From number appeared on caller ID as 954‐478‐2416 (California area code) 9/6 at 6:45:45 From number appeared on caller ID as 760‐705‐8888 (Florida area code). The originating callers used their cell phones and were able to call 406‐676‐3232 with the caller ID coming through correctly and the connection with enough voice quality that they could carry on their conversation. We continue to have fax failures because the IP in the middle doesn't provide the quality of service needed to complete the faxes.” Rosa Tougas, President Ronan Telephone Company Ronan, MT

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Inbound Call Quality

September 2011

“My experience with call quality issues has been seeing and hearing the local impact from my customers. My customers' phone may ring but there's no one there when they pick up; someone tries to call my customer and it takes forever for the call to go through; the call doesn't go through at all or the call quality is intolerable if it does go through. My experience has been that the issue is exclusively with calls terminating to my customers — my customers, using SMTC as a long distance carrier, never have trouble making outbound calls. Anecdotally, I had one customer who works in Seattle but her husband lives in our Wise River exchange. Due to health problems, she was supposed to call her husband and check in on him every couple hours. She called me, frustrated because she couldn't complete calls to check on him. From SMT's perspective it's frustrating as well because the problem originates upstream from me — in most cases the calls never hit my switch and there's nothing I can do. My theory, although not proven, is that it costs so much for long distance carriers to terminate calls to my customer that some of them just choose not to do so — they choose to leave the call "high‐and‐dry" — rather than pay access charges on that call. And of course the finger get's pointed at SMTC as being the faulty carrier even though my switch never receives the call in most (if not all) cases. Message from customer weekend of 9/10/11: "Thanks for checking into this. However, you should know that the problem also occurs when people call from Florida, and Virginia. It occurs when calling on Comcast. Tmobile, and Verizon. It looks to me as if the one thing in common is SMTEL. So what next? The service STILL does not work. It clearly is not a Comcast problem." I find it interesting that when cell service died when the hurricane hit DC it got (and continues to get) all kinds of publicity but this call termination issue has been on‐going for, what, a year with little or no resolution. See Rockfeller’s comments: http://commerce.senate.gov/public/index.cfm?p=PressReleases&ContentRecord_id=b30092da‐ 003c‐48c3‐8ec0‐b50e7a17e9f3&ContentType_id=77eb43da‐aa94‐497d‐a73f‐ 5c951ff72372&Group_id=4b968841‐f3e8‐49da‐a529‐7b18e32fd69d and the FCC’s response at http://transition.fcc.gov/Daily_Releases/Daily_Business/2011/db0829/DOC‐309318A1.pdf” Larry Mason, General Manager Southern Montana Telephone Company Wisdom, MT “This past week (August 29th thru 31st), we had a person trying to call our company from Lincoln, NE. I didn't get any call samples. He told me he tried to call in several times and he would get the ‘reorder’ signal. When he was finally able to get through to us on Sept 1st, the call quality was terrible. The line was cracklely, and he told me I sounded like I was talking inside a barrel.” Neil Classen, General Manager Three Rivers Communications Lynch, NE “We have had numerous reports from our customers that they could not receive incoming calls from around the country. The calls either routed to ‘vacant dn announcements, or your call did not go through’. Check of inbound SS7 messaging shows calls never presented to our network.” Rick Coughlin, Central Office Engineer Volcano Long Distance Pine Grove, CA

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Inbound Call Quality

September 2011

“The problem has been apparent for over 2 years. Many people & businesses simply cannot complete calls into our rural area. If the call does complete, the quality may be poor, the caller ID is often incorrect, and the call may disconnect shortly after answered. Many many complaints. If the caller tries several times, they may eventually get a call to complete. Non‐completing calls to fax machines are a major issue too. Many callers report long delays before they ever hear a ring back, and often the call just goes dead. It is very upsetting to the customer as they can receive some calls, but not others and we as the local telephone company have no way to correct the situation. It seems to vary with whomever the caller has for a long distance carrier. This issue is hurting our local businesses as the callers assume the business has closed since it has ‘no phone service’, We also have a lot of elderly residents whose families rely on telephone service to keep in contact, and panic when they cannot complete the call to check on the elderly person.” Carol Larson, Office Manager Wahkiakum West Long Distance, Inc. Rosburg, WA “We have had calls from customers that report multiple attempts to completed and also severe call quality issues. It is sporadic but very frustrating especially to our business customers and this does impact our ability to grow as a competitive company.” Anonymous “We have received numerous calls from customers that are reporting trouble with inbound long distance calls. This problem has increased drastically in the last six to nine months. The types of trouble our customers are reporting are: 1) incoming calls that do not complete although the calling party hears the call ringing; 2) incoming calls of very poor quality; 3) incorrect caller ID information displayed to the called party. We highly value the customer service we provide and are extremely frustrated because we cannot fix these types of problems for our customers. Many of our customers are very frustrated with these problems and are reporting loss of business due to not being able to receive incoming calls. Others are very frustrated because members of their family cannot call them and become very concerned about them. We have attempted to work with the originating carriers of the calls to identify where the calls are failing, but we have not had much success with these attempts. We are not seeing these calls completing in our switch and, therefore, cannot identify the problem without the assistance of the originating carrier. At times, the problem will be fixed temporarily by the originating carrier and then begin again. We have explained to our customers that the calling party needs to report the trouble to their long distance carrier but some of our customers have reported that when the calling party tries to report trouble to their long distance carrier, the long distance carrier refuses to acknowledge the trouble and will not help them. Often times, we are told the originating carrier will tell the calling party it is the fault of the telephone company they are calling to. In most cases, the incoming call problems are from callers who have Sprint cellular service or Sprint long distance service. It is extremely important that our customers are able to receive incoming long distance calls and we would greatly appreciate assistance in resolving these issues.” Anonymous

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Inbound Call Quality

September 2011

“Wed Aug 31: A store in Yankton SD tried to call our office in Nebraska which is within a short driving distance. I saw the Caller ID of the store and answered. I could not hear anyone. Hung up the phone. They immediately called back according to the Caller ID and I again answered. Again, I can't hear anyone's voice. I hung up the handset and picked up the phone to call back to their office. As I was calling out, they (3rd attempt) called into our office again and one of our CSRs answered. The Caller ID displayed a strange number (347‐492‐7181), with the 347 area code not physically close to South Dakota, and the Caller ID name displayed was "VOIPE SCROWNOW". Seems to us that this indicates that VoIP providers have been the issue all along. Two years ago we traced 2 calls from the same store in Yankton when similar issues occurred. One call was switched through Ft. Lauderdale, FL, while the other call was switched by British Telecom (location unknown). Since our office is located just a short driving distance away from the originating party's location in South Dakota — a far cry from Florida — we are very tired of LD carriers using Least Cost Routing and VoIP solutions to “game” the system and avoid access charges, all the while hurting customers all across the US and “dumbing down” the public into acceptance of low quality calls that are similar in fashion to cellular calls that routinely drop their signal.” Anonymous “Faxes will not go through customers do not receive Long Distance calls false caller ID false responses back; i.e. should get a busy tone but rather get a recorded message that says "the number you are calling has been disconnected or is no longer in service.” Anonymous “Our customers occasionally complain about incoming calls either not ringing their lines or incorrect Calling Party Information which results in incorrect Calling Name Delivery. Voice quality (static and echo) is another complaint we receive. These complaints on incoming calls are out of our immediate control but the customers do no view this as a sufficient answer to their problems. Our attempts to educate one customer in particular resulted in a FCC complaint against us. The originators of the failed calls that I have dealt with are Magic Jack, Vonage, Verizon, Sprint PCS, US Cellular, and Windstream. Our customer will state that the calling party can call anywhere in the United States except our network. Telling our customers to have the originating party call their service provider and open a ticket with them is not providing any resolution to the situation. Most times if they do contact the Originating company that company will simply state that it is not their issue and direct them back to us which puts our customer in a loop with no resolution.” Anonymous

Attachments

Presentation to Oregon Public Utility Commission — Canby Telephone Association Call Samples — Grand River Mutual Telephone Corporation NECA Test Call Samples — Interbel Telephone Letter from FCC to Madison Telephone LLC’s Customer — Madison Telephone LLC August 2011 Trouble Reports — Palmerton Long Distance

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Least Cost Routing Analysis

Brandon Zupancic

Canby Telcom

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Least Cost Routing

Grew rapidly in late 2009 and early 2010. Increased sharply nationwide in 2H’10.

Very difficult to troubleshoot because there is

often no SS7 record or Call Detail Record generated

What is it?

• Routing calls based on criteria to obtain the lowest cost in real time

• Enable routing based on Time of Day, percent utilization, or Quality of

Service tiers

Intended to

• Reduce transport cost

• Streamline routing updates

• Standardize routing platforms

• Ensure greater survivability

Least Cost Routing, if implemented properly, would benefit everyone.

However, there are currently many unintended consequences of LCR!

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Summary of Problems Caused by LCR

• Most prevalent on toll calls to rural exchanges

• Calls do not complete

• Poor voice quality

• Cannot send or receive faxes

• High incidence of spoofed Calling Numbers

• Inhibits compliance with CALEA requests

• May pose a risk to 911 callers

• Causes significant, measurable financial harm to

business customers

• Causes significant, measurable financial harm to

service providers and increases intrastate toll rates

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Scope of the LCR Problem

February 2011 NECA Member Survey

• 176 companies in 35 states (85% of respondents)

have experienced problems terminating calls due to

LCR

• Most complaints started in 2010, esp. in 2H’10.

• Often cyclical / intermittent

• Some telcos receiving more than 20 customer

complaints in a single day

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Causes of LCR Problems

• Congestion or low quality IP routes that are designed for data, not

voice (high latency, high jitter, high packet loss)

• Some LCR providers use lowest cost private IP networks

• in some cases, they use the public Internet

• Improper Call Setup – LCR provider not having the CLLI codes of all

terminating end offices in their routing tables

• Some originating carriers route calls to LCR providers whose

contracts stipulate that they will not complete calls to certain

NPA-NXXs – but the originating carrier may not know that and keeps

sending calls to that LCR provider destined for that terminating

location

• Some nomadic VoIP providers have simply refused to terminate

calls to certain areas.

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Financial Impact of LCR

(Terminating Access)

July (August 1 bill date)

• 17.73% decrease in Interstate MOU

• 13.47% decrease in Intrastate MOU

• Total revenue decrease >$8,000 for

July terminating access traffic

October (November 1 bill date)

• 33.74% decrease in Interstate MOU

• 30.92% decrease in Intrastate MOU

• Total revenue decrease for the

month of October > $10,000

November (December 1 bill date)

• 32.35% decrease in Interstate MOU

• 44.05% decrease in Intrastate MOU

• Total revenue decrease for the

month of November > $10,000

0 200000 400000 600000 800000 1000000 1200000 1400000

Terminating Access MOU

Interstate Intrastate

CABS Billing Date

Corresponds directly to sudden decline in IXC#1 LD traffic Corresponds directly to sudden decline in RBOC Toll traffic and increase in RBOC EAS traffic

The IXCs may argue that our terminating access MOU is due to our declining access line count, but our access line

count remains largely unchanged from Jan 2010 (9,548) through Jan 2011 (9,553). More importantly, the data shows

LCR is the most likely cause . . .

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Probable Indicators of LCR

IXC#1 Long Distance TG Terminating traffic to Canby

~ 100 CCS

~26% decrease

~ 250 CCS

~ 175 CCS

~58% decrease*

~ 100 CCS

~ 150 CCS

~67% reduction

~ 50 CCS

~ 33% reduction

~ 325 CCS

87% decrease in 10 months

(mid-Jan through late-Oct)

These extremely abrupt changes in traffic are highly unusual and based on the change in CCS, are

strong indicators of changes to call routing. The magnitude of these changes could indicate

implementation of LCR on individual trunks at different times. Normal attrition would show a

consistent, uniform decline. The magnitude of the overall reduction in a 10 month period is

unprecedented and highly abnormal.

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Probable Indicators of LCR

IXC#2 Toll TG Terminating traffic to Canby

~130 CCS 100% decrease*

*IXC#2 issued a disconnect of one of two 24-member circuit, but re-pointed all traffic to the other existing

circuit, so we should not have seen any significant change in total traffic, and certainly not a 100% decrease

from IXC#2. 130 CCS drop in traffic for 1 month, followed by a sudden 70 CCS spike and 300% increase clearly

indicates routing changes. We have not yet determined where this traffic went, but we know IXC#2 did not

stop sending us traffic for a month.

** Extremely unusual, abrupt fluctuations in traffic at the start/end of calendar months clearly indicates

changes to routing.

~70 CCS increase** 4 weeks ~80 CCS ~37% decrease** ~90 CCS ~50% decrease** ~160 CCS_{~84% decrease**} ~40 CCS ~133% increase** 4 weeks 4 weeks 4 weeks 4 weeks 8 weeks 8 weeks 8 weeks 8 weeks 4 weeks

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Probable Indicators of LCR

IXC#3 Toll TG Terminating traffic to Canby

~75 CCS

19% decrease & increase*

2 weeks ~75 CCS 20% decrease* ~50 CCS 17% increase* ~125 CCS 39% increase* ~125 CCS 28% decrease*

*Probable indication of LCR. While this is a fairly normal traffic pattern, it does contain several large, abrupt

fluctuations in traffic at the start/end of calendar months which indicate routing changes.

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Probable Indicators of LCR

IXC#4 Toll TG Terminating traffic to Canby

~110 CCS

2200% increase & decrease* ~80 CCS

1600% increase* ~15 CCS

23% increase* ~30 CCS_{38% increase*}

~20 CCS 44% increase*

*Probable indication of LCR. Extremely unusual, abrupt fluctuations in traffic at the start/end of calendar

months clearly indicates changes to routing. We have not been able yet to identify where the late

December-mid January and mid February-end of March traffic was re-routed.

Note recurring 4-5 week pattern at the beginning / end of the calendar month when routing changes appear

~25 CCS 33% decrease* ~15 CCS 30% increase* ~20 CCS 26% decrease* ~25 CCS 42% increase*

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Other Aspects of LCR:

One Example (971) 230-xxxx*

This number is an aggregation point for Interstate and Intrastate calls

from a variety of IXCs actively utilizing LCR, and from a variety of VoIP

providers to actively circumvent PSTN call routing to avoid payment of

toll terminating access

During the week of January 23, 2011:

• Canby Telcom received a total of 513,836 inbound calls from 69,481 unique TNs

throughout North America

• 27,082, or 5.27% of the total inbound calls, had a Charge Number of (971)

230-xxxx and were routed to Canby via the RBOC Tandem (Portland), but actually

originated at TNs from across North America. Only one of these 27,082 calls

included a CIC code.

• Calls originating from Google Voice, at least one RBOC, Vonage, and possibly other

carriers route “through” this number to the RBOC tandem.

• This number is part of a 1000 block owned by a registered CLEC, and is from the

RBOC PTLDOR18DS0 switch

Note: The next 10 highest originating TNs of calls to our two switches are all large local businesses

* The switch shows 971-230-xxxx as the “Calling DN” for all 27,082 calls. More detailed analysis shows 971-230-xxxx is the “Charge Number” for all of these calls, but the actual Calling Party Number (CPN) is a different number (where it was not stripped off or spoofed).

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Examples of LCR

All of the following calls were routed to Canby on TG 38 (RBOC Toll Tandem) in

a 1-hour period in a single day. Our switch logged 408 inbound calls from

971-230-xxxx in this 1-hour period.

Originating TN

Charge Number*

Terminating TN

480-837-7xxx

971-230-xxxx

503-266-7xxx

541-491-1xxx

971-230-xxxx

503-651-2xxx

200-200-0000

971-230-xxxx

503-651-3xxx

209-800-1xxx

971-230-xxxx

503-263-2xxx

200-200-0000

971-230-xxxx

503-651-3xxx

972-331-9xxx

971-230-xxxx

503-651-3xxx

000-000-0000

971-230-xxxx

503-266-7xxx

406-948-8xxx

971-230-xxxx

503-263-6xxx

* (971) 230-xxxx belongs to a 1000s block owned by a registered CLEC

54 of the 408 calls

From 971-230-xxxx

Have 200-200-0000

as the originating TN

000 and 200 are not

valid NPAs. The real

originating TNs have

been manipulated.

Other examples include

(blank), 000, or just the

NPA

None of these calls

generates a billing

record because

they all have a local

(Portland) Charge

Number, no OCN,

and no CIC

LCR = Phantom Traffic

Illegally Spoofed

Numbers:

(24)

Consumer Confusion / Complaints

About (971) 230-xxxx

• “I have been receiving about 4 phone calls a day from this

number. It comes up in my comcast call list as: Wales R &

P....or TN Removal List....or Sales Dept. But most of the

time it comes up as Unknown. When I tried to call the

number back it says it is no longer in service.”

• “On my Phone Caller ID it said (360) 464-2xxx Olympia WA

but phone bill call record shows the number is (971)

230-xxxx.”

• “Keep getting these calls from different numbers. This one

shows on caller ID as NY,NY 212-999-8xxx, but on my

itemized bill, same call, same time, shows NY, NY

971-230-xxxx. Recorded message in Spanish. They are call spoofing.”

(25)

Examples of Fax Troubles Due to LCR

Calling Party

Number

Charge Number

Terminating

TN

Initiated

Connected

Ended

Duration

Trunk Group

Fax Status

602-863-xxxx

971-230-xxxx

*

503-651-xxxx

14:14:33

14:14:37

14:15:05

00:00:28

RBOC EAS*

Failed

602-863-xxxx

*

503-651-xxxx

14:13:08

14:13:12

14:13:30

00:00:18

RBOC EAS*

Failed

602-863-xxxx

*

503-651-xxxx

08:28:28

08:28:32

08:30:00

00:01:28

IXC#3 Toll

*

Failed

Test calls to a single Canby end-user small business customer.

* Concrete evidence of LCR = routing through a suspected aggregator of calls converted to IP and calls from nomadic VoIP providers,

and mis-routed over RBOC EAS trunk group and other trunk groups belonging to IXCs suspected of using LCR providers.

(26)

Customer Frustration With LCR

3/22/11 data provided by one of our customers from their fax server (Trunk Group is Canby data).

NPA NXX Rate Center OK/Fail Inbound Trunk Group 215 947 Philadelphia, PA OK No Call Record*

215 997 Line Lexington, PA FAILED RBOC EAS*

217 543 Arthur, IL FAILED RBOC EAS*

352 671 Ocala, FL FAILED No Call Record*

503 642 Beaverton, OR FAILED RBOC EAS 503 642 Beaverton, OR OK RBOC EAS 503 642 Beaverton, OR OK RBOC EAS 503 642 Beaverton, OR OK RBOC EAS 518 877 Jonesville, NY FAILED No Call Record*

585 657 Holcomb, NY FAILED RBOC EAS*

610 279 Philadelphia, PA FAILED x2 IXC#3 Toll** 612 866 Twin Cities, MN FAILED No Call Record*

617 497 Cambridge, MA OK IXC#2 Toll 619 233 San Diego, CA OK RBOC TOLL 631 582 Central Islip, NY FAILED RBOC EAS*

631 582 Central Islip, NY OK RBOC EAS*

682 564 Arlington, TX OK RBOC EAS*

701 255 Bismarck, ND FAILED RBOC EAS*

713 773 Houston, TX OK RBOC EAS*

717 939 Harrisburg City, PA FAILED RBOC EAS*

724 754 Canonsburg, PA FAILED IXC#3 Toll** 760 327 Palm Springs, CA FAILED x2 IXC#3 Toll** 813 626 Tampa, FL FAILED RBOC EAS*

905 761 Thornhill, ON Canada FAILED No Call Record*

928 854 Lake Havasu City, AZ OK RBOC EAS*

989 755 Saginaw, MI FAILED RBOC EAS*

*Strong evidence of LCR: calls mis-routed through the RBOC Local Tandem / EAS trunk instead of through the appropriate toll trunk group / RBOC Toll Tandem, or no call detail record generated in the switch for an Interstate call

** Possible evidence of LCR: calls correctly routed to a plausibly appropriate toll trunk group, but failing

We later sent 10 test faxes to this customer’s 4 fax numbers (fax machines and fax server), and all 10 completed successfully, demonstrating their fax machine and server are working flawlessly and affirming that the most likely culprit is LCR.

(27)

LCR Issues are Pervasive

Trouble reports January 1, 2011 through July 1, 2011

• Business experiencing “fading” and can barely hear when called by customer in Salem (503) 589

• Business having trouble receiving faxes from (541) 382

• Business incoming faxes unable to connect successfully. Local to local test faxes work fine.

• Business unable to receive faxes from VoIP systems or SIP phones including (337) 981, (214) 352,

(516) 681. Fax errors out with “bad connection” or unable to connect.

• Business cannot receive faxes from customer at (925)-820. Originating caller says they “always

have problems faxing to 503 Area Code”. Multiple reports (same originating & terminating

numbers)

• Business having “ongoing” issues with receiving faxes from CA.

• Business receiving multiple unsuccessful incoming fax attempts from (480)-924 two seconds apart.

Cannot consistently send faxes to this same number. AZ customer has VoIP system? Multiple

reports (same originating & terminating numbers)

• Business unable to receive faxes from customer (503) 708. Local to local test faxes work fine

• Multiple business customers unable to call or fax to or from Canby to Albany, Corvallis, and Eugene

the week of June 20 (4 days)

(28)

LCR: CALEA and 911

• LCR inhibits service providers from complying

with Lawful Intercept orders (CALEA) in cases

where the Calling Party Number (CPN) is

incomplete, missing, or spoofed

• LCR could pose a risk to life and limb in cases

where a caller places a 911 call and the Calling

Party Number (CPN) is incomplete, missing, or

spoofed

– 911 test call using Google Voice: Recorded

Announcement: “This number is not available for call

return. Goodbye.”

Our most recent data shows that 3.2% of all incoming calls had a missing, incomplete,

or spoofed CPN. That equates to more than 64,000 calls per month.

(29)

Terminating EAS Trunk Group Traffic

• 80,504 calls on EAS Trunk Group

– 13,301 (

16.5%

) are from NPA/NXX other than 503

or 971

• Not one of these interLATA call records includes a CIC

• 793 (1.0%) are from NPA 541

• 6,870 (

51.7%)

are from spoofed or incomplete calling

numbers

(30)

IntraState Toll Access Avoidance Data

• Data is from the week of January 23, 2011

• 4,164 calls originating from NPA 541

• 29.4%

(1,223) of these calls were routed to Canby

on the EAS trunk group

– None of the 1,223 calls included a CIC code

• In addition to the 4,164 calls originating from NPA

541, an additional 373 calls appear in the switch

with a manipulated originating CPN, preventing

determination of proper jurisdiction or actual

origin

(31)

Intrastate Calls over EAS

CPN

Called Party

Date/Time

541595xxxx

503266xxxx

06/13/11.21:56:20

541647xxxx

503263xxxx

06/13/11.22:06:30

541677xxxx

503266xxxx

06/13/11.22:05:21

541403xxxx

503263xxxx

06/13/11.22:11:38

541840xxxx

503263xxxx

06/13/11.22:14:53

541636xxxx

503310xxxx

06/13/11.22:17:59

541447xxxx

503266xxxx

06/13/11.22:19:07

541276xxxx

503266xxxx

06/13/11.22:21:55

541757xxxx

503266xxxx

06/13/11.22:32:07

541408xxxx

503266xxxx

06/13/11.22:34:50

541926xxxx

503651xxxx

06/13/11.23:07:59

541937xxxx

503266xxxx

06/13/11.22:47:48

793 calls, June 13-17 2011

(32)

Spoofed or Incomplete CPN Calls over

EAS

CPN

Called Party

Date/Time

101 503651xxxx

06/13/11.22:36:30

0 503266xxxx

06/13/11.22:55:28

6055

503266xxxx

06/13/11.23:04:19

23330964

503651xxxx

06/14/11.14:21:55

229380819

503263xxxx

06/14/11.14:36:20

503142310

503263xxxx

06/15/11.03:10:42

91659

503263xxxx

06/15/11.18:31:36

9999999999

503263xxxx

06/14/11.15:18:21

-

503266xxxx

06/13/11.22:03:34

-

503651xxxx

06/13/11.22:04:30

6870 calls, June 13-17 2011

(33)

Conclusion

“Least Cost Routing” directly generates at least a

portion of Phantom Traffic and

Toll Fraud. Illegal spoofing is increasingly prevalent

with calls routed via an LCR provider.

LCR Causes direct financial harm to end user

businesses and consumers nationwide, and every

service provider who serve them (whether ILEC,

(34)

Time of Call Carrier/Landline/Cell Description of Problem

10:49am Sprint/Cellphone Dead Air

7:30‐9:00 qwest long dist call never completed 10:40 cell from Flordia lots of trouble before will thru he said he only has trouble when he calls cainsville 10:00 all morning 8‐1‐11 calling from BTC bank/Galllatin said all circuits busy 8:45 Sprint Dead Air 9:00 p.m. Cell from Linden, CO the # ID'd A to Z Market

8/2/2011 3:45 to 4:00 PM Cell called phone did not ring

8/2/11 21:25 Land line Savanah exchange Called phone rang, received caller ID, but no talk path 1056am 8/3/11 Frontier no ring or rings 1 or 2 times then cuts off‐says can call anywhere else but this area 730am & 1000am 8/3/11 Frontier no ring or rings 1 or 2 times then cuts off‐says can call anywhere else but this area 8/4/11 16:45 Landlines Call completed but was noisy and voices garbled, could not converse

9:30am 8.5.11 landlines doesn't ring ‐ dead air

9:30:00 AM 8.5.11 fax lines busy ‐ poor line condition

8/4/11 7:55 Frontier no ring or rings 1 or 2 times then cuts off‐says can call anywhere else but this area 733 am & 805am Frontier no ring or rings 1 or 2 times then cuts off‐says can call anywhere else but this area

8/5/11 8:35am Windstream comes in w/ caller id of 917‐737‐7083 A‐Z Marketing

8/5/11 2:35pm Sprint Cellular calls not completed

8/8/11 9 a.m to 10 a.m bus/ wont go thru/delay/dead air/hesitation/crackling/etc 8/8/11 approx 8:00 p.m. scratchy & fax tone

various time no one can caller her doesn’t go thru/busy/disconnect 8‐08‐11 TO 8‐09‐11 VARIOUS TIMES ALL DAY Landlines

DEAD AIR/ CUSTOMER VERY UPSET KIDS TRYING TO CALL THEM AT ALL TIMES AND NOT GOING THRU

8/10/11 9:00am Landlines dead air or can't be heard hospital trying to set up surgery

8/10/11 1:00pm Landlines can't be heard &/or cuts off/ dead air

8/11/11 8:00 to 8:15 a.m. Landline ATT Delayed….never did get connected….getting quite frustrated various time no one can caller her doesn’t go thru/busy/disconnect

all times cell/land line doesn't ring ‐ dead air

random times landline says they get recording that the person they are calling is disconnected approx 12PM landline(fax) says it rings in and says its receiving but nothing ever comes through 12:40 landline can't be heard &/or cuts off/ dead air

all times cell/land line can't be heard &/or cuts off/ dead air

8‐15‐11, 13:20pm landline sounded like they were talking underwater. 8‐15‐11, 13:00pm Cell/Verizon Unable to connect. 8‐15‐11, 2:52 Cell/Verizon Caller has been trying to call multiple times, gets message "The number you have dialed is not in service at this time" 8‐15‐11, 3:00 Cell/Verizon Call was never delivered, make more than 1 attempt today. Never rings on callee end.

8/11/2011 has been going on for 2 months Cell/ Rings at callee home and then there is dead air Various times over the last 2 months Cell Phone Call is never delivered, never rings on

(35)

8/16/11 8:15 & 8:20 Formerly Sprint Calling Card Call volume bad, breaking up during conversation, very poor quality line. 8/15/11 730pm ATT Rang 4x's, loud click, dead air (Wattenbarger very elderly & on oxygen & at risk of cardiac arrest)

8/16 9:49am landline couldn't be heard..

8/16 9 & 10 am /2pm centurylink they could hear them pickup then line would go dead. 8/14 ‐ 10:40 to 11:05 pm. Several calls 937‐3166 would ring, when answer no‐one there. Call would repeat in a few moments 8/16/11 16:00 two calls 30 seconds of silence, then maybe one ring 8/16/11 landline says when they call the 800 attached to the 660‐944‐2227 it cuts off & doesn't ring in. 8/17/11 landline tried for 10 min before it finally went through.. 8‐16‐11/8‐17‐11 cell Call is never delivered, never rings on 8/17/11 9:30 landline says cutoff in middle of conversation…says for last few months It takes several tries to connect

8/16/2011 1:00 till 4:00 landline refused to give LDC dead air or ring twice and dead air

8/17/11 13:12 landline dead air 8/16/11 cell (didn't know carrier) dead air/when got connection delay in voice 8/17/11 LANDLINE call will not go thru/ happens various times 8/17/11 Landline‐Charter rang 15 times on callers end, only once on our customer, could answer after several hellos 8/17/11 Landline Fax would not go through 8/18/11 cell said 1st time she cut in & out..2nd time rand on her end but never rang at Betty's & 3rd time in/out 8/17/11 19:20 ATT Cellular Voices garbled, Made 3 calls before conversation could occur 8/18/2011 8:05:00 AM and 8:24 GRM Voices delayed and weak, 8:24 voices garbled

8/10/11 9:30am Landline/Maryville Carquest Dead Air

8/12/11 10:58am & 11:00am Landline/Maryville Carquest Dead Air

8/15/11 10:40, 10:42 & 10:44 Laneline Dead Air

18‐Aug Cell/Northwest Cellular doesn't ring ‐ dead air

8/18/11 after 8:00am 660‐367‐2384 Can't Receive Faxes 8/18/11 after 8:00am 660‐367‐4778 Can't Receive Faxes 8/18/11 after 8:00am 660‐367‐2150 Can't Receive Faxes 8/18/11 Can't receive calls 8/18/11 Can't receive calls 8/18/11 3:56PM Can't receive calls‐daughter can't call to ck on sub who is 91 yrs old 8/18/11 5:50pm landline tried 3‐4 times odd sounds and cut off.. 8/18/11 1:28PM Can't receive calls 8/18/11 Can't receive calls 8/18/2011 10:40am Can't receive calls

08/19‐11 all morning cell sprint rings once and will not connect…happens all the time

8/16/2011 953am GRLD open line, faint static, no completion‐‐turned in 8/19 so Zhone won't accept, also not completed 8/16/2011 955am GRLD open line, faint static, no completion‐‐turned in 8/19 so Zhone won't accept, also not completed 8/16/11 1019am GRLD open line, faint static, no completion‐‐turned in 8/19 so Zhone won't accept, also not completed

8/19/2011 955am unknown LD carrier calls won't go through‐via landline or cell phone

(36)

8/19/11 Can't receive calls 8/19/2011 11:42AM Lyrix Wireless Either rings 1‐2x's then disconnects or just keeps ringing but never ring into the house. 8/19/11 12:20PM Lyrix Wireless Either rings 1‐2x's then disconnects or just keeps ringing but never ring into the house.

8/17/11 8 a.m. landline/winser mo wont go thru/delay/dead air/hesitation/crackling/etc

8/10/11 1:00 Mo wont go thru/delay/dead air/hesitation/crackling/etc

8/19/11 151pm Can't receive calls

6/29/11 ‐ 7/21/11 landline & cell cut off / phone doesn't ring / noise on line ‐ 15 separate reports

all the time verizon wont go thru/delay/dead air/hesitation/crackling/etc

8/19/11 530pm unknown LD carrier static, can't be heard 8/20/11 900am unknown LD carrier caller gets message that our customer's phone has been disconnected 8/21/11 unknown LD carrier couldn't complete call 8/19‐8/21/11 US Cellular either rings continuous, or rings 1‐2x's then disconnects, or they get a message the phone has been disconnected

8/22/11 912am unknown LD carrier ring 1x then won't ring again, then delayed conversation

8/22/11 700am unknown LD carrier delayed conversation

8/20/11 300pm unknown LD carrier lots of issues with the call, multiple‐delayed, noisy, etc 8/22/11 9:20 a.m. centurylink wont go thru/delay/dead air/hesitation/crackling/etc weekend of 8/13/11 and 8/20/11 unknown LD carrier calls either can't connect or when they do the static is so bad that conversation is impossible. 8/15/11‐8/19/11 between 5‐7pm unknown LD carrier either rings continuous, or rings 1‐2x's then disconnects, or they be heardd 8/19/11 Sprint wouldn't connect..tried several times throughout day.

8/20/2011 every hour from 2‐8pm unknown LD carrier could not complete any calls 8/22/11 10‐1030am unknown LD carrier could not complete any calls

8/21/11 Qwest tells caller that customer is disconnected 8/21/11 21:00 not sure wont go thru/delay/dead air/hesitation/crackling/etc 8/21/2011 8:30‐9:00 PM landline wouldn't connect part of time and sometime connected but cutoff.. 8/22/11 Windstream caller gets message that our customer's phone has been disconnected 8/22/11 103pm unknown LD carrier dead air 8/22/11 ? One ring and quit 8/22/11 12:15 Peoria, IL Couldn't hear; delay in transmission 8/22/11 15:20 rang twice, quit 8/22/11 15:20 Phoeniz, AZ Couldn't hear; delay in transmission 8/22/11 15:45 Austin, TX Couldn't hear; delay in transmission 8/22/11 11:01 ? 8/22/11 11:27 ? 8/22/11 11:45 ? 8/22/11 13:40 ? Range once and stopped 8/22/11 13:48 ? Dropped call 8/22/11 10:37 Ohio poor quality 8/22/11 12:34 Oregon poor quality 8/22/11 13:15 California poor quality 8/22/11 14:10 North Carolina poor quality 8/22‐/11 2:32 pm Michagan poor quality 8/22/11 11:04 poor quality 8/22/11 12:16 poor quality

(37)

8/22/11 12:38 poor quality

8/22/11 13:34 ? rang once

8/22/11 14:06 ? rang once

8/22/11 14:20 poor quality

8/22/11 15:05 ? 2 rings, then stopped

8/22/2011 9:43AM Embark Delay and static

8/22/2011 2:37pm ? Rang once and dead air 8/22/11 3:49pm ? Dead Air 8/23/11 7:34 ? Didn't connect 8/22/11 7:52pm ? Doesn't ring in 8/22/11 6:47pm ? Doesn't ring in 8/22/11 6:21pm ? Doesn't ring in 8/22/11 11:49am ? Doesn't ring in 8/22/11 10:06am ? Doesn't ring in 8/22/11 9:23am ? Doesn't ring in 8/20/11 1:49pm ? Doesn't ring in 8/20/11 8:31am ? Doesn't ring in 8/23/11 11:00 a.m. ? Doesn't ring in 8/23/11 16:10 landline They get dead air or rings once & dead air. 8/23/11 8:53 ? delays in voice transmission 8/23/11 9:00 ? outgoing call: got disconnected 8/23/11 9:33 ? delays in voice transmission 8/23/11 10:45 ? delays in voice transmission 8/23/11 11:09 ? delays in voice transmission 8/23/11 12:20 ? delays in voice transmission 8/23/11 12:25 ? delays in voice transmission/bad connection 8/23/11 12:46 ? delays in voice transmission 8/23/11 14:20 ? delays in voice transmission 8/24/11 9:00 ? Recording: This # has been disconnected or no longer in service.

8/24/2011 7:03am US Cellular call not completed took several times to make call..

8/23/11 17:30 verizon calls not completed

8/24/11 10:30 & 10:45 sprint calls not completed

8/24/11 7:30 a.m. cell‐maryville wont go thru/delay/dead air/hesitation/crackling/etc 8/24/11 11:00 landline Bettendorff Ia wont go thru/delay/dead air/hesitation/crackling/etc

8/24/11 ? can't receive calls

July & Aug sprint calls dropped off

July & Aug sprint calls dropped

8/24/11 22:08 verizon had 2 connections when answered, heard several clicks then cut off waiting for call detail GRLD rings on callers end but never rings in at callee's end 26‐Aug US Cellular 1st time fast busy/ 2nd doesn't ring./3rd rings on her in but doesn't ring at the spicers

08.26.11 (10:15/10:45 AM) US Cellular never rings in

8‐26‐11 all morning verizon cell wont go thru/delay/dead air/hesitation/crackling/etc

8‐26‐11 all day wont go thru/delay/dead air/hesitation/crackling/etc

8‐26‐11 all day ? won't go thru….fax line

(38)

8‐26‐11 all morning ? wouldn't ever connect 8/29/11 and several wks prior ? son in New Boston Mo & daughter in Pella IA unable to complete calls with customer 8/29/11 11:00 Sprint Cellular connection was never made, wouldn't ring, or ring once then cut off 8/29/11 1211pm verizon cell 2 fast rings then drops 8/29/11 1211pm GRLD tried 4 times each resulting in 2 fast rings then drops 8/24/11 4:18pm Centurylink 1st time couldn't hear 2nd time busy signal…3rd time delayed voices 15‐20 min cuts off. 8/25/11 11:29 centurylink rings once cuts off…and 2nd time says misdialed # hang up & try again.

08‐29‐11 several time buncton mo cant get thru

8/29/11 4:40pm Sprint Cellular calls not completed 8/30/11 ? rings, no one there 8‐29‐11 19:48pm media com could not be heard… 8/30/11 9:03 Sprint (FAX LINE) SAYS POOR LINE CONDITION 8/30/11 ? can't receive calls all the time ? cant receive calls

all the time AT & T cell cant receive calls

9:30 am,11am,5pm & 7 pm landline rings once & cuts off…aug 28

all the time landline couldn't be heard..

8/30/11 12:30 landline rings once cuts off…and 2nd time says misdialed # hang up & try again. 8/30/11 ? missing business calls and others due to fact that incoming long distance will not complete 8/30/2011 btwn 5 & 7:30 p.m. grld tried 4 times ‐ 1st call, ID said 561 area code; 2nd call 561 area code (different #) 3rd call (954) area code; could not hear each time; 4th call..got thru 12:01pm 8/30 Sprint (FAX LINE) SAYS POOR LINE CONDITION 151pm 9/1/11 Verizon caller id says A‐Z Marketing… 9/1/11 ? can't receive calls/ some calls come through making caller sound like digital voice every evening ? can't receive calls 9‐6‐11 8:30 a.m. ? can't receive calls 9/6/11 17:27 landline/Surewest caller ID comes up Florida and couldn't be heard.

(39)

NECA Test Call Log Page 1 of 5

Session

Index Caller Tag Originating No. Service Provider Service Type LD Carrier Terminating No. Date Start Time EDT (HH:MM:SS) End Time EDT (HH:MM:SS) Call Result Call Quality 1320 46 406‐297‐7474 Interbel ILEC MCI (????) 406‐541‐1087 8/25/2011 0:49:06 0:49:45Completed ‐ Normal Setup TimeNo Call Quality Problems

1321 970‐562‐0001 8/25/2011 0:50:46 0:51:55Completed ‐ Normal Setup TimeNo Call Quality Problems

1325 918‐597‐0080 8/25/2011 0:56:19 0:57:26Completed ‐ Normal Setup TimeNo Call Quality Problems

1328 918‐535‐2203 8/25/2011 0:59:51 1:01:11 Ring No Answer N/A ‐ Call Did Not Complete

1339 608‐634‐7429 8/25/2011 1:23:08 1:23:48Completed ‐ Normal Setup TimeNo Call Quality Problems N/A ‐ Call Did Not

(40)

NECA Test Call Log Page 2 of 5

Session

Index Caller Tag Originating No. Service Provider Service Type LD Carrier Terminating No. Date Start Time EDT (HH:MM:SS) End Time EDT (HH:MM:SS) Call Result Call Quality 1341 406‐347‐2118 8/25/2011 1:25:46 1:26:22Completed ‐ Normal Setup TimeNo Call Quality Problems

1346 308‐265‐3570 8/25/2011 1:31:25 1:32:29 Ring No Answer N/A ‐ Call Did Not Complete

1348 406‐328‐9905 8/25/2011 1:34:08 1:35:08

Completed ‐

Normal Setup TimeNo Call Quality Problems

1349 47 406‐889‐8040 Interbel ILEC Global Crossing (0444) _{406‐541‐1087} 1350 970‐516‐1001 1351 970‐967‐0002 1352 575‐987‐2007 1353 660‐584‐6527 1354 918‐597‐0080 1355 605‐425‐5002 1356 618‐736‐2242 1357 918‐535‐3699 1358 207‐644‐1014 1359 207‐789‐5016 1360 724‐646‐8450