BEFORE THE PENNSYLVANIA PUBLIC UTILITY COMMISSION : M : : : M :

Transcription

1

2

3 BEFORE THE PENNSYLVANIA PUBLIC UTILITY COMMISSION PMO III DIRECTORY LISTINGS (F0016) PMO--PERFORMANCE MEASURES REMEDIES : M : : : M : COMMENTS OF VERIZON PENNSYLVANIA INC. IN SUPPORT OF ITS PETITION FOR APPROVAL OF A CLEC CUSTOMER DIRECTORY LISTING ERROR REMEDY PLAN, TARIFF REVISIONS, AND PENNSYLVANIA CARRIER-TO-CARRIER GUIDELINES REVISIONS Verizon Pennsylvania Inc. ( Verizon ) respectfully requests that the Commission approve the competitive local exchange carrier ( CLEC ) customer directory listing error remedy plan (the Plan ) submitted on October 1, 2009 with the consensus of the Pennsylvania Carrier Working Group. The Commission should also approve the associated revisions to Verizon Tariff Pa. P.U.C.-No. 216, and the deletion from the Pennsylvania Carrier-to-Carrier Guidelines Performance Standards and Reports ( PA Guidelines ) of Metrics GE-5, Directory Listing Verification Reports, and GE-6, Timely and Accurate Provisioning of White Page Directory Listings LSRs and DSRs, metrics that have never been implemented and that will be unneeded when the Plan takes effect.

4 I. The Commission Should Adopt the Plan. The Carrier Working Group which includes a diverse array of telephone carriers and the public advocates has developed the Plan to comply with this Commission s direction in the PMO II Order to recommend a remedy plan for errors in CLEC customer telephone directory listings. 1 Following careful analysis, the Carrier Working Group has reached consensus on the Plan, which is set out in proposed Verizon Tariff Pa. P.U.C.-No. 216, Section 2A (see, Exhibit 1, attached). Under the Plan, Verizon will reimburse a CLEC (referred to in the tariff as an Other Telephone Company or OTC 2 ) via a bill credit to the CLEC (a Reimbursement Bill Credit ) for the amount the CLEC has credited to its own customer as a result of a Verizon-caused error in the CLEC customer s listing (an OTC Customer Listing 3 ) in a Verizon telephone directory, up to a stated maximum amount. The stated maximum amounts are as follows: (i) Residence OTC Customer Listings: For each telephone number for which one or more OTC Customer Listings associated with that telephone number are subject to an Error: 1. $28.00 for the first OTC Customer Listing that is subject to an Error. 2. $14.00 per OTC Customer Listing for each of the second through fifth OTC Customer Listings that are subject to an Error. 3. No reimbursement will be provided for the sixth and subsequent OTC Customer Listings that are subject to an Error. (ii) Business and other Non-Residence OTC Customer Listings For each telephone number for which one or more OTC Customer Listings associated with that telephone number are subject to an Error: 1 Performance Measures Remedies, Final Opinion and Order On Performance Measures and Remedies for Wholesale Performance for Verizon Pennsylvania Inc. (PMO II), M , pp (12/10/02). 2 In order to participate in the Plan, an OTC must have an interconnection agreement with Verizon pursuant to 47 U.S.C. 251 and 252. Verizon Tariff Pa. P.U.C.-No. 216, Section 2A.B.1.b. 3 OTC Customer Listing means and includes an OTC end-user s name, address and telephone number. Verizon Tariff Pa. P.U.C.-No. 216, Section 2A.A.1.a. 2

5 1. $80.00 for the first OTC Customer Listing that is subject to an Error. 2. $40.00 per OTC Customer Listing for each of the second through fifth OTC Customer Listings that are subject to an Error. 3. No reimbursement will be provided for the sixth and subsequent OTC Customer Listings that are subject to an Error. 4 Under the Plan, Verizon also will provide to the CLEC an Administrative Bill Credit equal to twenty-five percent (25%) of the Reimbursement Bill Credit. 5 Thus, the maximum amount that a CLEC will be able to receive for a Verizon-caused error in a CLEC customer directory listing is: (i) Residence OTC Customer Listings: For each telephone number for which one or more OTC Customer Listings associated with that telephone number are subject to an Error: 1. $35.00 for the first OTC Customer Listing that is subject to an Error. 2. $ per OTC Customer Listing for each of the second through fifth OTC Customer Listings that are subject to an Error. (ii) Business and other Non-Residence OTC Customer Listings For each telephone number for which one or more OTC Customer Listings associated with that telephone number are subject to an Error: 1. $ for the first OTC Customer Listing that is subject to an Error. 2. $50.00 per OTC Customer Listing for each of the second through fifth OTC Customer Listings that are subject to an Error. 6 The Plan applies to the following Verizon-provided directory listings and listing services: (i) White Pages OTC Customer Listings provided by Verizon PA pursuant to Verizon PA Tariffs Pa. P.U.C.-No. 216, Section 2, and 4 Verizon Tariff Pa. P.U.C.-No. 216, Section 2A.B.2.a. 5 Verizon Tariff Pa. P.U.C.-No. 216, Section 2A.B.2.e. 6 For Residence, Business and other Non-Residence OTC Customer Listings, no reimbursement will be provided for the sixth and subsequent OTC Customer Listings that are subject to an Error. Verizon Tariff Pa. P.U.C.-No. 216, Section 2A.B.2.a. 3

6 Pa. P.U.C.-No. 500, Section 9 (including both White Pages listings for which no specific charge applies and White Pages listings for which a specific charge applies). (ii) (iii) The free OTC Customer Listing for OTC business end-users in a Verizon PA Yellow Pages (classified) telephone directory, provided by Verizon PA pursuant to Verizon PA Tariff Pa. P.U.C.-No. 216, Section 2. Non-Published Telephone Number Service and Non-Listed Telephone Number Service, provided by Verizon PA pursuant to Verizon PA Tariff Pa. P.U.C.-No. 500, Section 9. 7 The Plan does not apply to certain types of listings, such as: (i) (ii) (iii) (iv) (v) (vi) OTC Customer Listings associated with telecommunications service provided by Verizon PA to an OTC for resale; OTC Customer Listings associated with Verizon Wholesale Advantage Service (Verizon s UNE-P replacement service) (or any comparable successor service); OTC Customer Listings provided by Verizon PA to an OTC that are associated with telecommunications service provided by the OTC as an incumbent local exchange carrier; OTC Customer Listings provided by Verizon PA to an OTC pursuant to an agreement that excludes application of this remedy plan. an OTC Customer Listing Error for which the OTC end user has made a claim against Verizon PA and/or the directory publisher or printer (for instance, Idearc); to the extent an OTC arranges directly with the directory publisher or printer (for instance, Idearc) for publication of the OTC s OTC Customer Listings. 8 These exclusions reflect the expectation that in some circumstances, remedies for a CLEC customer directory listing error will be covered by an alternative arrangement, such as the applicable Verizon retail tariff for directory listings associated with resold service, or a contract between Verizon and a CLEC for the provision of Wholesale Advantage Service, or a 7 Verizon Tariff Pa. P.U.C.-No. 216, Section 2A.B.1.a. 8 Verizon Tariff Pa. P.U.C.-No. 216, Section 2A.B.1.c. 4

7 commercial agreement for directory listing services provided by Verizon to another incumbent local exchange carrier. Similarly, the proposed remedy plan would not appropriately apply if the end user has sought a remedy directly from Verizon or the directory publisher or printer (Idearc) or the CLEC has contracted directly for the listing service with the directory publisher or printer (Idearc) and not with Verizon. The Plan also does not apply in an instance where a CLEC decides to pursue remedies for a CLEC customer directory listing error under a plan or arrangement other than the Plan, such as an interconnection agreement remedy provision. 9 This protects against a double recovery of compensation for a listing error. The Plan provides compensation for the following types of directory listing Errors: (i) (ii) (iii) (iv) (v) omission from a printed Verizon PA telephone directory of an OTC Customer Listing that the OTC requested be included in the directory; publication in a printed Verizon PA telephone directory of an OTC Customer Listing that pursuant to Verizon PA s Non-Published Telephone Number Service or Non-Listed Telephone Number Service (Verizon PA Tariff Pa. P.U.C.-No. 500, Section 9) the OTC requested be excluded from the directory; publication in a printed Verizon PA telephone directory of an OTC end-user s name that differs from the name that the OTC requested Verizon PA to publish in the directory; publication in a printed Verizon PA telephone directory of an OTC end-user s address that differs from the address that the OTC requested Verizon PA to publish in the directory; and, publication in a printed Verizon PA telephone directory of an OTC end-user s telephone number that differs from the telephone number that the OTC requested Verizon PA to publish in the directory Verizon Tariff Pa. P.U.C.-No. 216, Section 2A.B.4. Under the Plan s No Double Dipping provision, if a CLEC has the right to bring a claim for a CLEC customer directory listing error under a plan or arrangement other than the Plan, such as under an interconnection agreement remedy provision, the CLEC must make an election as to whether it will seek compensation under the other plan or arrangement or under the Plan. If the CLEC elects to seek compensation under the other plan or arrangement, the CLEC may not seek compensation under the Plan. 10 Verizon Tariff Pa. P.U.C.-No. 216, Section 2A.A.1.b. Errors do not include any deficiency in an OTC Customer Listing that was requested, caused or contributed to by the OTC or the OTC s end-user. 5

8 The Plan sets out a process for a CLEC to submit a claim for credits due under the Plan. In brief, the CLEC would use a form provided by Verizon to submit the CLEC s claim for reimbursement of bill credits the CLEC has provided to a CLEC end user on account of a Verizon-caused error in the end user s listing in a Verizon directory. Verizon will review the claim and respond within sixty days as to whether Verizon will provide the requested credit to the CLEC. If Verizon agrees that a credit is due to the CLEC, Verizon will apply the credit to a CLEC bill within forty-five days of the date Verizon provides notice that a credit will be provided. 11 The Plan contains an extensive set of examples showing the credits that would be available to a CLEC under the Plan in the event of an error in its customer s listings. 12 For instance: 4. If a printed Verizon PA telephone directory contains Verizon PA caused Errors in which an OTC business end-user s White Pages Primary OTC Customer Listing and free Yellow Pages OTC Customer Listing are omitted from the directory, Verizon PA will provide to the OTC a bill credit (a Reimbursement Bill Credit ) equal to: (a) for the first omitted OTC Customer Listing, the lesser of (i) $80.00 or (ii) the amount actually credited by the OTC to its end-user on account of such omitted OTC Customer Listing; plus, (b) for the second omitted OTC Customer Listing, the lesser of (i) $40.00 or (ii) the amount actually credited by the OTC to its end-user on account of such omitted OTC Customer Listing. Verizon PA also will provide to the OTC a bill credit (an Administrative Bill Credit ) equal to twenty-five percent (25%) of the Reimbursement Bill Credit Verizon PA provided to the OTC. Accordingly, if the OTC credited its enduser $ for each omitted OTC Customer Listing on account of the omission of that OTC Customer Listing, Verizon PA will provide to the OTC a Reimbursement Bill Credit of $80.00 for the first omitted OTC Customer Listing, plus $40.00 for the second omitted OTC Customer Listing (a total Reimbursement Bill Credit of $120.00), and an Administrative Bill Credit of $20.00 for the first omitted OTC Customer Listing, plus $10.00 for the second omitted OTC Customer Listing (a total Administrative Bill Credit of $30.00) (resulting in a total Bill Credit of $150.00). If the OTC credited its end-user 11 Verizon Tariff Pa. P.U.C.-No. 216, Section 2A.B Verizon Tariff Pa. P.U.C.-No. 216, Section 2A.C. 6

9 $30.00 for each omitted OTC Customer Listing on account of the omission of that OTC Customer Listing, Verizon PA will provide to the OTC a Reimbursement Bill Credit of $30.00 for each omitted OTC Customer Listing (a total Reimbursement Bill Credit of $60.00), and an Administrative Bill Credit of $7.50 for each omitted OTC Customer Listing (a total Administrative Bill Credit of $15.00) (resulting in a total Bill Credit of $75.00). 13 The Plan will apply to directories published after the effective date of the new tariff section containing the Plan. 14 The Commission should adopt the Plan. The Plan will provide a substantial reimbursement to a CLEC for a credit the CLEC has provided to its end user on account of a Verizon-caused directory listing error. This will permit the CLEC, at no cost to the CLEC, to provide a substantial reimbursement to its customer for a Verizon-caused error in the customer s directory listing. The Plan also will compensate the CLEC for administrative costs the CLEC may have incurred in handling the directory listing error remedy claim from its customer. The Plan is the product of long and careful review by the Pennsylvania Carrier Working Group and reflects the consensus of the Carrier Working Group. II. The Commission Should Approve Revisions to Verizon Tariff Pa. P.U.C-No. 216 to Set Out the Plan and Improve the Text of the Existing Wholesale Directory Listing Provisions. In conjunction with its submission of the Plan, Verizon has submitted revisions to Verizon Tariff Pa. P.U.C.-No. 216 (see, Exhibit 1, attached). First, Verizon has added a new section to the tariff, Section 2A, which sets out the Plan. Second, Verizon has submitted administrative revisions to update Section 2 of the tariff, the tariff section under which Verizon provides directory listing services to CLECs, to correct 13 Verizon Tariff Pa. P.U.C.-No. 216, Section 2A.C Verizon Tariff Pa. P.U.C.-No. 216, Section 2A.C.8. 7

10 names and tariff cross references that have changed since Section 2 was last revised in 1997 and make minor improvements in grammar at a few points. The Commission should approve these tariff revisions. The tariff revisions are necessary for implementation of the Plan and to update the provisions of the tariff that pertain to Verizon s wholesale directory listing services. The tariff revisions have been reviewed by the Pennsylvania Carrier Working Group and reflect the consensus of the Carrier Working Group. III. The Commission Should Delete Metrics GE-5 and 6 from the PA Guidelines. The PA Guidelines adopted by the PMO II Order contain two directory listing metrics that are unique to Pennsylvania, Metrics GE-5, Directory Listing Verification Reports, and GE-6, Timely and Accurate Provisioning of White Page Directory Listings LSRs and DSRs. The PMO II Order directed the Pennsylvania Carrier Working Group to evaluate the adequacy of these metrics. 15 The Pennsylvania Carrier Working Group has determined that these metrics should be eliminated and replaced by the Plan. Because of the limited value of Metrics GE-5 and GE-6 and the extensive administrative burden and expense attendant upon implementing these metrics, as well as the lack of internal clarity of some of the sub-metrics which would have made implementing the submetrics difficult, these metrics, with the consensus of the Carrier Working Group, have never been implemented. With the adoption of the Plan, PA Guidelines directory listing metrics will not be needed because the Plan will provide Verizon with a strong incentive to accurately provide directory listings and will give CLECs adequate reimbursement for costs associated with Verizon-caused errors in CLEC customer directory listings. Therefore, Metrics GE-5 and GE-6 15 Performance Measures Remedies, Final Opinion and Order On Performance Measures and Remedies for Wholesale Performance for Verizon Pennsylvania Inc. (PMO II), M , pp (12/10/02). 8

11

12

13 TELEPHONE COMPANIES Section 2 Second Revised Sheet 1 Canceling First Revised Sheet 1 A. GENERAL DIRECTORY LISTINGS FOR OTHER TELEPHONE COMPANIES Directory listings are available to Other Telephone Companies (OTC) to list their end user customers in the alphabetic section of Verizon PA directories. These listings will be provided under the same terms and conditions as provided to Verizon PA s end users as specified in Pa. P.U.C.-No. 500, Sections 1 and 9, except as noted in this section. (C) (C) B. REGULATIONS 1. Primary Listings Primary listings will be provided to the OTC s end users as follows. No minimum number of listings per order is required. a. Residence For each residence telephone number at the time service is established, two (2) listings in the white page directory are provided. b. Business For each business telephone number listed, except numbers of Centrex or Centrex-like services or indialing service station lines, one (1) listing is provided in the white page directory and one (1) listing in the yellow page (classified) directory of the type provided to Verizon PA business customers for which no specific charge applies. 2. The OTC will be solely responsible for the accuracy and content of directory listings it provides and will insure that listings conform to Verizon PA s specifications with respect to its directories. If Verizon PA publishes such listings as submitted by the OTC, the OTC will indemnify Verizon PA and its affiliates, representatives and agents (and the directory publisher if different) from any and all damages (including attorney s fees) arising out of any claim for any reason relating to directory listings it provides to Verizon PA. (C) (C) (C) (C) (C) 3. Verizon PA reserves the right to limit the length of any listing in the (C) directory by the use of abbreviations when, in its judgment, the clearness of the listing or the identification of the customers is not impaired thereby. Where more than one line is required to properly list the customer, no additional charge applies. 4. Each listing must be designated Residential, Government or Business to be placed in the appropriate section of the directory. In order to aid the user of the directory, and to avoid misleading or deceiving the calling party as to the identity of the listed party, only business listings may be placed in the Business section and only residential listings in the Residential section. Verizon PA, upon notification to the OTC, will withdraw any listing which is found to be in violation of its rules. (C)

14 TELEPHONE COMPANIES Section 2 Second Revised Sheet 2 Canceling First Revised Sheet 2 B. REGULATIONS (Cont'd) DIRECTORY LISTINGS FOR OTHER TELEPHONE COMPANIES 5. Verizon PA may refuse listings which do not comply with Pa. P.U.C.-No. (C) 500, Section 9. Verizon PA, upon notification to the OTC, will withdraw (C) any listing which is found to be in violation of its rules with respect to that section. 6. The OTC will provide Verizon PA with daily listing information on its end (C) users in the format required by Verizon PA. The information shall (C) include the end user s name, address, telephone number, the delivery address and number of directories to be delivered and in the case of a business listing, the primary business heading in which the business customer desires to be placed and any other information necessary for the publication and delivery of directories. The OTC will also provide Verizon PA with daily listing information showing end users that have (C) disconnected or terminated service with the OTC. 7. In order for listings to appear in an upcoming Verizon PA directory, the (C) OTC must furnish the listing in time to meet the directory publishing schedule. 8. Verizon PA will also include the OTC s end users primary listings in the (C) Directory Assistance database on the same basis as Verizon PA s end users (C) are included, as well as in other audible and electronic listings in which Verizon PA s end users are ordinarily included, for no additional charge. (C) 9. Verizon PA will distribute to the OTC s end users copies of Verizon PA s (C) primary white page and yellow page directories at the same time and on the same basis as provided to Verizon PA s end users. Verizon PA will also (C) deliver a reasonable number of such directories to the OTC. 10. The OTC will adhere to all practices, standards, and ethical requirements of Verizon PA with regard to listings, and will reasonably warrant to Verizon PA that it has the right to place such listings on behalf of its end users, and that any business or person to be listed is authorized and has the right (1) to provide the product or service offered, and (2) to use any personal or corporate name, trade name or language used in the listing. (C) (C) 11. Verizon PA will give the OTC s end users directory listing information (C) the same level of confidentiality that Verizon PA gives its own directory (C) listing information. 12. Verizon PA will ensure that access to the OTC s end users customer (C) proprietary directory information will be used solely for the purpose of (C) providing directory services; except that Verizon PA may use or license its data base, to the extent permitted by law or regulation, for direct marketing so long as the OTC s end users are not separately identified as (C) such. 13. Verizon PA will ensure that the OTC s end users customer proprietary (C) confidential information will not be used by Verizon PA to separately (C) target OTC end users for the sale of telecommunications services unless those end users are identified through other means. 14. Verizon PA agrees to provide directories and directory listing services (C) available to the OTC through separate contracts.

15 TELEPHONE COMPANIES Section 2 Third Revised Sheet 3 Canceling Second Revised Sheet 3 C. RATES DIRECTORY LISTINGS FOR OTHER TELEPHONE COMPANIES Primary listings as described in section B above and ordered at the time of the initial unbundled network element (UNE) service order will be provided at no additional charge. The rates for the following listings and listing services are found in Pa. P.U.C.-No. 500, Section 9: (C) -- listings ordered in excess of the primary listings as described in section B above -- listings of a type other than primary listing -- listings not associated with a UNE service order -- primary listings described in section B above which are not ordered at the time of the initial UNE service order Books and delivery (annual home area directories only) -- No charge for normal numbers of books delivered to end users; bulk deliveries to CLEC per separate agreement.

16 TELEPHONE COMPANIES Section 2A Original Sheet 1 A. GENERAL OTHER TELEPHONE COMPANY (OTC) CUSTOMER LISTING ERROR REMEDY PLAN 1. Definitions The following definitions shall apply to Verizon PA Tariff Pa. P.U.C.-No. 216, Section 2A. a. OTC Customer Listing means and includes an OTC end-user s name, address and telephone number. b. Error means and includes: (i) (ii) (iii) (iv) (v) omission from a printed Verizon PA telephone directory of an OTC Customer Listing that the OTC requested be included in the directory; publication in a printed Verizon PA telephone directory of an OTC Customer Listing that pursuant to Verizon PA s Non- Published Telephone Number Service or Non-Listed Telephone Number Service (Verizon PA Tariff Pa. P.U.C.-No. 500, Section 9) the OTC requested be excluded from the directory; publication in a printed Verizon PA telephone directory of an OTC end-user s name that differs from the name that the OTC requested Verizon PA to publish in the directory; publication in a printed Verizon PA telephone directory of an OTC end-user s address that differs from the address that the OTC requested Verizon PA to publish in the directory; and, publication in a printed Verizon PA telephone directory of an OTC end-user s telephone number that differs from the telephone number that the OTC requested Verizon PA to publish in the directory. Errors do not include any publication or omission of, or change, modification, error or other deficiency in, an OTC Customer Listing, if Verizon PA s act or omission conforms to Verizon PA s tariffs and/or any Verizon PA directory rules, standards, practices and/or ethical requirements that are referenced in a Verizon PA tariff and made available to the OTC by Verizon PA (such as through a website accessible by the OTC). Errors also do not include any publication or omission of, or change, modification, error or other deficiency in, an OTC Customer Listing, that was requested, caused or contributed to by the OTC or the OTC s end-user. If an OTC submits a request to Verizon PA for action with regard to an OTC Customer Listing (such as inclusion of an OTC Customer Listing in, or exclusion of an OTC Customer Listing from, a Verizon PA telephone directory, or a change in an OTC Customer Listing) but the request is submitted after the final date set by Verizon PA for the OTC to submit such request for the applicable Verizon PA telephone directory, a failure by Verizon PA to take the requested action for that directory shall not be deemed to be an Error. 1 1 For instance, if the final date set by Verizon PA for OTCs to submit requests for new OTC Customer Listings to be included in the July 2010 West Chester Directory is April 15, 2010 and an OTC submits a request for a new OTC Customer Listing for the West Chester Directory on April 20, 2010, a failure by Verizon PA to include the requested OTC Customer Listing in the July 2010 West Chester Directory shall not be deemed to be an Error.

17 TELEPHONE COMPANIES Section 2A Original Sheet 2 B. REGULATIONS OTHER TELEPHONE COMPANY (OTC) CUSTOMER LISTING ERROR REMEDY PLAN 1. Scope of the Remedy Plan a. This remedy plan applies only to Verizon PA printed telephone directories and only to the following Verizon PA telephone directory listing services: (i) (ii) (iii) White Pages OTC Customer Listings provided by Verizon PA pursuant to Verizon PA Tariffs Pa. P.U.C.-No. 216, Section 2, and Pa. P.U.C.-No. 500, Section 9 (including both White Pages listings for which no specific charge applies and White Pages listings for which a specific charge applies). The free OTC Customer Listing for OTC business end-users in a Verizon PA Yellow Pages (classified) telephone directory, provided by Verizon PA pursuant to Verizon PA Tariff Pa. P.U.C.-No. 216, Section 2. Non-Published Telephone Number Service and Non-Listed Telephone Number Service, provided by Verizon PA pursuant to Verizon PA Tariff Pa. P.U.C.-No. 500, Section 9. b. This remedy plan is available only to an OTC that has an interconnection agreement with Verizon PA pursuant to 47 U.S.C. 251 and 252 and applies only to OTC Customer Listings that are ordered from Verizon PA by an OTC pursuant to such an interconnection agreement and the applicable Verizon PA tariff section as stated in subsection 2A.B.1.a, above. c. This remedy plan does not apply to: (i) (ii) (iii) (iv) (v) OTC Customer Listings associated with telecommunications service provided by Verizon PA to an OTC for resale (including, but not limited to, telecommunications service provided by Verizon PA to an OTC for resale pursuant to 47 U.S.C. 251(c)(4), 47 U.S.C. 251(b)(1), Verizon PA Tariff Pa. P.U.C.-No. 1, Section 1.8.1, Interim Resale Provisions, or an interconnection or resale agreement or tariff); OTC Customer Listings associated with Verizon Wholesale Advantage Service (or any comparable successor service); OTC Customer Listings provided by Verizon PA to an OTC that are associated with telecommunications service provided by the OTC as an incumbent local exchange carrier; OTC Customer Listings provided by Verizon PA to an OTC pursuant to an agreement that excludes application of this remedy plan; an OTC Customer Listing that was requested by an OTC but for which Verizon PA rejected the request, either in whole or as to any part (i.e., as to the name, address or telephone number), and gave notice of the rejection and the reason for the rejection to the OTC;

18 TELEPHONE COMPANIES Section 2A Original Sheet 3 B. REGULATIONS OTHER TELEPHONE COMPANY (OTC) CUSTOMER LISTING ERROR REMEDY PLAN 1. Scope of the Remedy Plan: (Cont d) c. This remedy plan does not apply to: (Cont d) 2. Remedy (vi) (vii) an OTC Customer Listing that pursuant to Verizon PA s Non- Published Telephone Number Service or Non-Listed Telephone Number Service (Verizon PA Tariff Pa. P.U.C.-No. 500, Section 9) the OTC requested be excluded from the directory but for which Verizon PA rejected the request for the OTC Customer Listing and/or the request for exclusion of the OTC Customer Listing from the directory, and gave notice of the rejection and the reason for the rejection to the OTC; an OTC Customer Listing Error for which the OTC end user has made a claim against Verizon PA and/or the directory publisher or printer (for instance, Idearc); (viii) the extent Verizon PA ceases to provide telephone directory listing services to OTCs pursuant to Verizon PA Tariff Pa. P.U.C.-No. 216, Section 2; (ix) (x) the extent Verizon PA ceases to provide telephone directory listing services to OTCs pursuant to Verizon PA Tariff Pa. P.U.C.-No. 500, Section 9; or, the extent an OTC arranges directly with the directory publisher or printer (for instance, Idearc) for publication of the OTC s OTC Customer Listings. a. If a printed Verizon PA telephone directory contains one or more Errors in an OTC s OTC Customer Listing and the Error or Errors were caused by Verizon PA (including by a contractor used by Verizon PA to publish or print the directory), Verizon PA will reimburse the OTC for any bill credit the OTC has provided to the OTC s end-user on account of the Error(s) up to an amount not to exceed the following: (i) Residence OTC Customer Listings: For each telephone number for which one or more OTC Customer Listings associated with that telephone number are subject to an Error: 1. $28.00 for the first OTC Customer Listing that is subject to an Error. 2. $14.00 per OTC Customer Listing for each of the second through fifth OTC Customer Listings that are subject to an Error. 3. No reimbursement will be provided for the sixth and subsequent OTC Customer Listings that are subject to an Error.

19 TELEPHONE COMPANIES Section 2A Original Sheet 4 B. REGULATIONS OTHER TELEPHONE COMPANY (OTC) CUSTOMER LISTING ERROR REMEDY PLAN 2. Remedy a. (Cont d) (ii) Business and other Non-Residence OTC Customer Listings For each telephone number for which one or more OTC Customer Listings associated with that telephone number are subject to an Error: 1. $80.00 for the first OTC Customer Listing that is subject to an Error. 2. $40.00 per OTC Customer Listing for each of the second through fifth OTC Customer Listings that are subject to an Error. 3. No reimbursement will be provided for the sixth and subsequent OTC Customer Listings that are subject to an Error. b. The amount of the reimbursement that Verizon PA is obligated to provide to an OTC shall not exceed the amount of any bill credit the OTC has actually provided to the OTC s end-user on account of the Error(s). c. The amount of the reimbursement that Verizon PA is obligated to provide to an OTC shall not exceed the amount specified in subsections 2A.B.2.a and b, above, even if an OTC Customer Listing contains more than one Error. d. The reimbursement that Verizon PA is obligated to provide to an OTC pursuant to subsections 2A.B.2.a through.c, above, shall be provided by Verizon PA by means of a credit to a Verizon PA bill to the OTC, in accordance with the process outlined in subsection 2A.B.3, following. e. When Verizon PA provides a bill credit to an OTC pursuant to subsections 2A.B.2.a through.d, above (hereinafter referred to as a Reimbursement Bill Credit ), Verizon PA also will provide to the OTC a bill credit (hereinafter referred to as an Administrative Bill Credit ) equal to twenty-five percent (25%) of the Reimbursement Bill Credit Verizon PA provided to the OTC. 3. Claims Process a. When making a claim for reimbursement of amounts credited to its enduser on account of an Error(s) in an OTC Customer Listing caused by Verizon PA, the OTC shall provide the following information to Verizon PA in writing on a form that shall be provided by Verizon PA:

20 TELEPHONE COMPANIES Section 2A Original Sheet 5 B. REGULATIONS OTHER TELEPHONE COMPANY (OTC) CUSTOMER LISTING ERROR REMEDY PLAN 3. Claims Process (Cont d) a. (Cont d) (i) (ii) (iii) (iv) (v) (vi) The end-user s name, service address and telephone number. The end-user s correct listed name, address and telephone number. The OTC Customer Listing that was requested (including, enduser name, address and telephone number), the directory that was to contain the OTC Customer Listing, whether the OTC Customer Listing was to be in the White Pages [residence endusers] or both the White Pages and Yellow Pages [business endusers], and, if the OTC Customer Listing was to be in the Yellow Pages [business end-users], the primary business heading under which the OTC Customer Listing was to appear. A description of the Error(s). The most recent PON establishing the listing. The amount of the bill credit the OTC has provided to its enduser as a result of the Error(s) and the date on which the bill containing the bill credit was issued to the OTC s end-user. b. Verification of Accuracy of OTC Claims for Reimbursement- Verizon PA shall have the right, once in each calendar year, to perform an audit of the portions of an OTC s end user bills that show the credits to end users for which the OTC has requested reimbursement under this remedy plan 2, in order to verify the accuracy of the OTC s requests under this remedy plan for reimbursement of amounts credited to the OTC s end-users on account of Errors in OTC Customer Listings. The audit shall be conducted in accordance with the procedures set out in the OTC s interconnection agreement with Verizon PA pursuant to which a party to the interconnection agreement may audit the accuracy of the other party s bills under the interconnection agreement. In the absence of such interconnection agreement procedures, the audit shall be conducted in accordance with reasonable procedures that shall be mutually agreed upon in good faith by Verizon PA and the OTC; provided that if Verizon PA and the OTC do not agree upon such procedures within thirty (30) days after Verizon PA gives notice to the OTC of Verizon PA s intent to conduct an audit, either Verizon PA or the OTC may request the Commission to determine the procedures that will apply. 2 For instance, the portions of a bill that show the end user s name, address and telephone number, the date of the bill, and the amount of the credit.

21 TELEPHONE COMPANIES Section 2A Original Sheet 6 B. REGULATIONS OTHER TELEPHONE COMPANY (OTC) CUSTOMER LISTING ERROR REMEDY PLAN 3. Claims Process (Cont d) c. OTC claims for reimbursement under this remedy plan must be submitted to Verizon PA in writing by the earlier of the following dates: (1) ninety calendar days after the OTC issues its first bill showing the bill credit being provided to the OTC s end-user on account of the Error(s); or, (2) one year after the last day of the month of initial publication of the Verizon PA telephone directory containing the Error(s). 3 d. Verizon PA shall provide a contact person or organization or electronic interface for OTCs to submit requests for reimbursement of bill credits provided to an OTC end-user as a result of an Error(s). Within sixty (60) calendar days after Verizon PA receives a properly completed OTC request for reimbursement of bill credits provided to an OTC end-user as a result of an Error(s), Verizon PA shall advise the OTC whether Verizon PA will provide the OTC with the requested reimbursement. If the request for reimbursement is denied (either in whole or in part), Verizon PA shall provide the OTC with a written explanation of the reason for the denial. If Verizon PA agrees that reimbursement is due to the OTC (either in whole or in part), Verizon PA shall provide the applicable reimbursement by means of a credit to a Verizon PA bill to the OTC within forty-five (45) calendar days after the date on which Verizon PA notifies the OTC that the reimbursement will be provided No Double Dipping An OTC may not obtain under both this remedy plan and another plan or arrangement 5 (a) reimbursement of compensation provided to its end-user for an Error or Errors in an OTC Customer Listing, or (b) other financial remedies or benefits for an Error or Errors in an OTC Customer Listing. An OTC may not submit a claim for an Error or Errors in an OTC Customer Listing under both this remedy plan and another plan or arrangement. Notwithstanding the preceding sentence of this subsection 2A.B.4, if an OTC submits a claim for an Error or Errors in an OTC Customer Listing under this remedy plan and Verizon PA denies such claim in its entirety and provides the OTC no reimbursement under this remedy plan for such Error or Errors in the OTC Customer Listing, the OTC may withdraw its claim under this remedy plan and pursue such remedies for the Error or Errors in the OTC Customer Listing as may be available to the OTC under another plan or arrangement. 3 For instance, for the July 2010 West Chester Directory, claims for reimbursement must be submitted by July 31, If Verizon PA provides a Reimbursement Bill Credit to an OTC, the Administrative Bill Credit associated with such Reimbursement Bill Credit will be applied to the Verizon PA bill to the OTC to which the Reimbursement Bill Credit is applied. 5 Such as a Federal or state regulatory commission plan or arrangement (for instance, the Performance Assurance Plan adopted by the PA PUC in Docket M ), or a performance plan, bill credit or remedies provision, or other provision, in a Verizon PA tariff or an interconnection agreement.

22 TELEPHONE COMPANIES Section 2A Original Sheet 7 OTHER TELEPHONE COMPANY (OTC) CUSTOMER LISTING ERROR REMEDY PLAN C. APPLICATION OF REMEDY PLAN Examples of the application of this remedy plan are set out in this subsection 2A.C. This remedy plan, though, is not limited to these examples. In Examples 1. through 6., following, the OTC end-user has only one telephone number for which one or more OTC Customer Listings associated with that telephone number are subject to an Error. In Example 7., following, the OTC end-user has two telephone numbers for which one or more OTC Customer Listings associated with those telephone numbers are subject to an Error. 1. If a printed Verizon PA telephone directory contains a Verizon PA caused Error in which an OTC business end-user s White Pages Primary OTC Customer Listing is omitted from the directory, Verizon PA will provide to the OTC a bill credit (a Reimbursement Bill Credit ) equal to the lesser of: (a) $80.00; or, (b) the amount actually credited by the OTC to its end-user on account of the omitted OTC Customer Listing. Verizon PA also will provide to the OTC a bill credit (an Administrative Bill Credit ) equal to twenty-five percent (25%) of the Reimbursement Bill Credit Verizon PA provided to the OTC. Accordingly, if the OTC credited its end-user $ on account of the omitted OTC Customer Listing, Verizon PA will provide to the OTC a Reimbursement Bill Credit of $80.00 and an Administrative Bill Credit of $20.00 (resulting in a total Bill Credit of $100.00). If the OTC credited its end-user $30.00 on account of the omitted OTC Customer Listing, Verizon PA will provide to the OTC a Reimbursement Bill Credit of $30.00 and an Administrative Bill Credit of $7.50 (resulting in a total Bill Credit of $37.50). 2. If a printed Verizon PA telephone directory contains Verizon PA caused Errors in which an OTC business end-user s White Pages Primary OTC Customer Listing contains a name that is spelled differently from the spelling requested by the OTC and a telephone number that is different from the telephone number requested by the OTC, Verizon PA will provide to the OTC a bill credit (a Reimbursement Bill Credit ) equal to the lesser of: (a) $80; or, (b) the amount actually credited by the OTC to its enduser on account of the Errors. Verizon PA also will provide to the OTC a bill credit (an Administrative Bill Credit ) equal to twenty-five percent (25%) of the Reimbursement Bill Credit Verizon PA provided to the OTC. Accordingly, if the OTC credited its end-user $ on account of the Errors, Verizon PA will provide to the OTC a Reimbursement Bill Credit of $80.00 and an Administrative Bill Credit of $20.00 (resulting in a total Bill Credit of $100.00). If the OTC credited its end-user $30.00 on account of the Errors, Verizon PA will provide to the OTC a Reimbursement Bill Credit of $30.00 and an Administrative Bill Credit of $7.50 (resulting in a total Bill Credit of $37.50).

23 TELEPHONE COMPANIES Section 2A Original Sheet 8 OTHER TELEPHONE COMPANY (OTC) CUSTOMER LISTING ERROR REMEDY PLAN C. APPLICATION OF REMEDY PLAN (Cont d) 3. If a printed Verizon PA telephone directory contains Verizon PA caused Errors in which both of an OTC residence end-user s White Pages Primary OTC Customer Listings are omitted from the directory, Verizon PA will provide to the OTC a bill credit (a Reimbursement Bill Credit ) equal to: (a) for the first omitted OTC Customer Listing, the lesser of (i) $28.00 or (ii) the amount actually credited by the OTC to its end-user on account of such omitted OTC Customer Listing; plus, (b) for the second omitted OTC Customer Listing, the lesser of (i) $14.00 or (ii) the amount actually credited by the OTC to its end-user on account of such omitted OTC Customer Listing. Verizon PA also will provide to the OTC a bill credit (an Administrative Bill Credit ) equal to twenty-five percent (25%) of the Reimbursement Bill Credit Verizon PA provided to the OTC. Accordingly, if the OTC credited its end-user $75.00 for each omitted OTC Customer Listing on account of the omission of that OTC Customer Listing, Verizon PA will provide to the OTC a Reimbursement Bill Credit of $28.00 for the first omitted OTC Customer Listing, plus $14.00 for the second omitted OTC Customer Listing (a total Reimbursement Bill Credit of $42.00), and an Administrative Bill Credit of $7.00 for the first omitted OTC Customer Listing, plus $3.50 for the second omitted OTC Customer Listing (a total Administrative Bill Credit of $10.50) (resulting in a total Bill Credit of $52.50). If the OTC credited its end-user $12.00 for each omitted OTC Customer Listing on account of the omission of that OTC Customer Listing, Verizon PA will provide to the OTC a Reimbursement Bill Credit of $12.00 for each omitted OTC Customer Listing (a total Reimbursement Bill Credit of $24.00) and an Administrative Bill Credit of $3.00 for each omitted OTC Customer Listing (a total Administrative Bill Credit of $6.00) (resulting in a total Bill Credit of $30.00).

24 TELEPHONE COMPANIES Section 2A Original Sheet 9 OTHER TELEPHONE COMPANY (OTC) CUSTOMER LISTING ERROR REMEDY PLAN C. APPLICATION OF REMEDY PLAN (Cont d) 4. If a printed Verizon PA telephone directory contains Verizon PA caused Errors in which an OTC business end-user s White Pages Primary OTC Customer Listing and free Yellow Pages OTC Customer Listing are omitted from the directory, Verizon PA will provide to the OTC a bill credit (a Reimbursement Bill Credit ) equal to: (a) for the first omitted OTC Customer Listing, the lesser of (i) $80.00 or (ii) the amount actually credited by the OTC to its end-user on account of such omitted OTC Customer Listing; plus, (b) for the second omitted OTC Customer Listing, the lesser of (i) $40.00 or (ii) the amount actually credited by the OTC to its end-user on account of such omitted OTC Customer Listing. Verizon PA also will provide to the OTC a bill credit (an Administrative Bill Credit ) equal to twenty-five percent (25%) of the Reimbursement Bill Credit Verizon PA provided to the OTC. Accordingly, if the OTC credited its end-user $ for each omitted OTC Customer Listing on account of the omission of that OTC Customer Listing, Verizon PA will provide to the OTC a Reimbursement Bill Credit of $80.00 for the first omitted OTC Customer Listing, plus $40.00 for the second omitted OTC Customer Listing (a total Reimbursement Bill Credit of $120.00), and an Administrative Bill Credit of $20.00 for the first omitted OTC Customer Listing, plus $10.00 for the second omitted OTC Customer Listing (a total Administrative Bill Credit of $30.00) (resulting in a total Bill Credit of $150.00). If the OTC credited its end-user $30.00 for each omitted OTC Customer Listing on account of the omission of that OTC Customer Listing, Verizon PA will provide to the OTC a Reimbursement Bill Credit of $30.00 for each omitted OTC Customer Listing (a total Reimbursement Bill Credit of $60.00), and an Administrative Bill Credit of $7.50 for each omitted OTC Customer Listing (a total Administrative Bill Credit of $15.00) (resulting in a total Bill Credit of $75.00).

25 TELEPHONE COMPANIES Section 2A Original Sheet 10 OTHER TELEPHONE COMPANY (OTC) CUSTOMER LISTING ERROR REMEDY PLAN C. APPLICATION OF REMEDY PLAN (Cont d) 5. If a printed Verizon PA telephone directory contains Verizon PA caused Errors in which an OTC business end-user s White Pages Primary OTC Customer Listing, free Yellow Pages OTC Customer Listing, and six paid White Pages Additional Listings (provided pursuant to Verizon PA Tariff Pa. P.U.C.-No. 500, Section 9), were omitted from the directory, Verizon PA will provide to the OTC a bill credit (a Reimbursement Bill Credit ) equal to: (a) for the first omitted OTC Customer Listing, the lesser of (i) $80.00 or (ii) the amount actually credited by the OTC to its end-user on account of such omitted OTC Customer Listing; (b) for the second omitted OTC Customer Listing, the lesser of (i) $40.00 or (ii) the amount actually credited by the OTC to its end-user on account of such omitted OTC Customer Listing; (c) for the third omitted OTC Customer Listing, the lesser of (i) $40.00 or (ii) the amount actually credited by the OTC to its end-user on account of such omitted OTC Customer Listing; (d) for the fourth omitted OTC Customer Listing, the lesser of (i) $40.00 or (ii) the amount actually credited by the OTC to its end-user on account of such omitted OTC Customer Listing; and, (e) for the fifth omitted OTC Customer Listing, the lesser of (i) $40.00 or (ii) the amount actually credited by the OTC to its end-user on account of such omitted OTC Customer Listing (Verizon PA will provide no bill credit for the sixth through eighth omitted OTC Customer Listings). Verizon PA also will provide to the OTC a bill credit (an Administrative Bill Credit ) equal to twenty-five percent (25%) of the Reimbursement Bill Credit Verizon PA provided to the OTC. Accordingly, if the OTC credited its end-user $ for each omitted OTC Customer Listing on account of the omission of that OTC Customer Listing, Verizon PA will provide to the OTC a Reimbursement Bill Credit of $80.00 for the first omitted OTC Customer Listing, plus $40.00 for each of the second through fifth omitted OTC Customer Listings (a total Reimbursement Bill Credit of $240.00) (Verizon PA will provide no bill credit for the sixth through eighth omitted OTC Customer Listings), plus an Administrative Bill Credit of $20.00 for the first omitted OTC Customer Listing, plus $10.00 for each of the second through fifth omitted OTC Customer Listings (a total Administrative Bill Credit of $60.00) (resulting in a total Bill Credit of $300.00). If the OTC credited its end-user $30.00 for each omitted OTC Customer Listing on account of the omission of that OTC Customer Listing, Verizon PA will provide to the OTC a Reimbursement Bill Credit of $30.00 for each of the first through fifth omitted OTC Customer Listings (a total Reimbursement Bill Credit of $150.00) (Verizon PA will provide no bill credit for the sixth through eighth omitted OTC Customer Listings), and an Administrative Bill Credit of $7.50 for each of the first through fifth omitted OTC Customer Listings (a total Administrative Bill Credit of $37.50) (resulting in a total Bill Credit of $187.50).

26 TELEPHONE COMPANIES Section 2A Original Sheet 11 OTHER TELEPHONE COMPANY (OTC) CUSTOMER LISTING ERROR REMEDY PLAN C. APPLICATION OF REMEDY PLAN (Cont d) 6. If a printed Verizon PA telephone directory contains a Verizon PA caused Error in which an OTC residence end-user s OTC Customer Listing was published in the White Pages portion of the directory and the OTC had requested that the OTC Customer Listing be omitted from the directory pursuant to Verizon PA s Non-Published Telephone Number Service (Verizon PA Tariff Pa. P.U.C.-No. 500, Section 9), Verizon PA will provide a bill credit (a Reimbursement Bill Credit ) to the OTC equal to the lesser of: (a) $28.00; or, (b) the amount actually credited by the OTC to its enduser on account of publication of the OTC Customer Listing. Verizon PA also will provide to the OTC a bill credit (an Administrative Bill Credit ) equal to twenty-five percent (25%) of the Reimbursement Bill Credit Verizon PA provided to the OTC. Accordingly, if the OTC credited its end-user $ on account of publication of the OTC Customer Listing, Verizon PA will provide to the OTC a Reimbursement Bill Credit of $28.00 and an Administrative Bill Credit of $7.00 (resulting in a total Bill Credit of $35.00). If the OTC credited its end-user $20.00 on account of the publication of the OTC Customer Listing, Verizon PA will provide to the OTC a Reimbursement Bill Credit of $20.00 and an Administrative Bill Credit of $5.00 (resulting in a total Bill Credit of $25.00). 7. If an OTC business end-user has two telephone numbers and a printed Verizon PA telephone directory contains Verizon PA caused Errors in which for the first telephone number the OTC business end-user s White Pages Primary OTC Customer Listing and free Yellow Pages OTC Customer Listing were omitted from the directory and for the second telephone number the OTC business end-user s White Pages Primary OTC Customer Listing was omitted from the directory, Verizon PA will provide bill credits to the OTC as follows: