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Comment sought on clarifying Appendix C of Rural Call Completion Order

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Released: April 21, 2014


Federal Communications Commission

News Media Information 202 / 418-0500

445 12th St., S.W.


Washington, D.C. 20554

TTY: 1-888-835-5322

DA 14-526

Released: April 21, 2014



WC Docket No. 13-39

Comment Date: (7 days after date of publication in the Federal Register)

The Wireline Competition Bureau seeks comment on whether guidance or additional clarification
would assist providers with their filing obligations related to the Rural Call Completion Order.1
Specifically, we seek comment on whether to modify or otherwise provide assistance regarding the
criteria described in Appendix C of the Rural Call Completion Order for categorizing certain types of call
attempts. We release this Public Notice in response to questions raised in the record regarding the
“answered” and “ring no answer” categories of call attempts described in Appendix C, pursuant to
delegated authority.2 These questions raise the possibility that the relevant criteria in Appendix C were
inadvertently drafted in a way that fails to reflect the Commission’s clear intent, as expressed in the
“Answered” call attempts. The reporting requirements in the Rural Call Completion Order
require covered providers to categorize call attempts either as “answered” or as one of three types of calls
that are not answered: “busy,” “ring no answer,” or “unassigned number.” The Rural Call Completion
defines “answered call” as
a call that was answered by or on behalf of the called party (including calls completed to
devices, services or parties that answer the call such as an interactive voice response,
answering service, voicemail or call-forwarding system), causing the network to register
that the terminating party is prepared to receive information from the calling user.3
The Commission emphasized that “the call answer rate is the data point least susceptible to variations in
data reporting or to differences in the quality or accuracy of signaling: the called party either answered
the call or did not answer the call.”4

1 Rural Call Completion, WC Docket No. 13-39, Report and Order and Further Notice of Proposed Rulemaking,
28 FCC Rcd 16154 (2013) (Rural Call Completion Order or Order).
2 See id. at 16184, para. 66 (“[Wireline Competition] Bureau staff will work with providers to ensure that the
providers have the tools they need to complete and file the form [in Appendix C] in the least burdensome manner
3 Id. at 16187, para. 72.
4 Id. at 16186, para. 71.

Appendix C of the Rural Call Completion Order provides a spreadsheet that covered providers
must use to file the required call completion data with the Commission each quarter.5 The legend
accompanying the spreadsheet identifies specific “ISUP Cause values and corresponding SIP Response
messages” for each category of call attempt.6 An “answered” call is described in Appendix C as a call
attempt “signaled back with ISUP 16 & 31 and SIP BYE & CANCEL.”7
In recent meetings with Commission staff, Level 3 and Verizon explained that release cause
code 16—one of the codes identified in Appendix C as denoting an answered call—is also used to
indicate that the calling party has hung up before the called party answered.8 Level 3 contends that
including calling-party hangups as answered calls would result in a “much higher” reported call-
completion rate than a provider would report if it excluded them.9
In this Public Notice, we seek comment on this contention and on whether it would assist
providers if the Bureau clarified that, as specified in the Order, covered providers should record and
report calls as “answered” only to the extent that such calls satisfy the definition of “answered call” that
appears in paragraph 72 of the Rural Call Completion Order 10 Appendix C could be clarified to
eliminate any basis for interpreting it inconsistently with the definition of “answered call” in the Order.
If so, should the description of “answered call” in Appendix C be revised to include a different
description (e.g., a different set of release codes) of how networks identify answered calls?11 Or should
the legend in Appendix C simply be deleted, allowing each covered provider to identify answered calls in
a manner consistent with the definition in the Rural Call Completion Order and with industry practice?
“Ring no answer” call attempts. The Rural Call Completion Order requires covered providers to
record and report “ring no answer” call attempts, which are required to calculate the network
effectiveness ratio (NER).12 A “ring no answer” call is described in Appendix C as a call attempt that is
“signaled back with ISUP 18 & 19 and IP 408 & 480.” 13
Level 3 asserted that some of the criteria in Appendix C for “ring no answer” call attempts will
only capture a very small percentage of the intended call attempts.14 Verizon expressed concern about
using call signaling data to identify “ring no answer” calls at all.15 We therefore seek comment on

5 Id. at 16218, Appx. C.
6 These terms are release cause codes that are used within the network to identify the outcome of a given call.
7 Rural Call Completion Order, 28 FCC Rcd at 16218, Appx. C.
8 See Letter from Maggie McCready, Vice President, Federal Regulatory Affairs, Verizon, to Marlene H. Dortch,
Secretary, FCC, WC Docket No. 13-39 (filed Mar. 24, 2014) (Verizon Mar. 24, 2014 Ex Parte); Letter from Joseph
C. Cavender, Vice President, Federal Affairs, Level 3, to Marlene H. Dortch, Secretary, FCC, WC Docket No. 13-39
(filed Jan. 29, 2014) (Level 3 Jan. 29, 2014 Ex Parte).
9 Id. at 1.
10 Rural Call Completion Order, 28 FCC Rcd at 16187, para. 72.
11 Level 3, for example, states that it “only considers calls answered where it has received an ISUP Answer message
(ANM) or the SIP equivalent.” Level 3 Jan. 29, 2014 Ex Parte at 1.
12 Rural Call Completion Order, 28 FCC Rcd at 16185, para. 68.
13 Id. at 16218, Appx. C.
14 Level 3 Jan. 29, 2014 Ex Parte at 2 (stating that “release cause codes 18 and 19 are used so infrequently (typically
less than 1% of calls), and in Level 3’s experience, only on calls that the terminating LEC disconnects because of
excessive ringing, that tracking these codes serves little practical purpose”).
15 Verizon Mar. 24, 2014 Ex Parte at 1 (stating that “call signaling data, even when combined with switch or
conversation duration measures, cannot distinguish between calls where the caller heard ringing before hanging up

whether the description of “ring no answer” call attempts in Appendix C should be revised to provide
clearer guidance to covered providers, and if so, how. Alternatively, should the legend in Appendix C be
deleted, allowing each covered provider to interpret the required call attempt categories in a manner
consistent with industry practice and with the Commission’s stated intent in the Rural Call Completion
Interested parties may file comments on or before the date indicated on the first page of this
document. Comments should reference WC Docket No. 13-39. Comments may be filed using the
Commission’s Electronic Comment Filing System (ECFS) or by filing paper copies.16
 Electronic Filers: Comments may be filed electronically using the Internet by accessing the
 Paper Filers: Parties who choose to file by paper must file an original and one copy of each
filing. If more than one docket or rulemaking number appears in the caption of this proceeding,
filers must submit two additional copies for each additional docket or rulemaking number.
Filings can be sent by hand or messenger delivery, by commercial overnight courier, or by first-
class or overnight U.S. Postal Service mail. All filings must be addressed to the Commission’s
Secretary, Office of the Secretary, Federal Communications Commission.
All hand-delivered or messenger-delivered paper filings for the Commission’s Secretary
must be delivered to FCC Headquarters at 445 12th St., SW, Room TW-A325,
Washington, DC 20554. The filing hours are 8:00 a.m. to 7:00 p.m. All hand deliveries
must be held together with rubber bands or fasteners. Any envelopes and boxes must be
disposed of before entering the building.
Commercial overnight mail (other than U.S. Postal Service Express Mail and Priority
Mail) must be sent to 9300 East Hampton Drive, Capitol Heights, MD 20743.
U.S. Postal Service first-class, Express, and Priority mail must be addressed to 445 12th
Street, SW, Washington DC 20554.
 People with Disabilities: To request materials in accessible formats for people with disabilities
(braille, large print, electronic files, audio format), send an e-mail to or call the
Consumer & Governmental Affairs Bureau at 202-418-0530 (voice), 202-418-0432 (tty).
This matter shall be treated as a “permit-but-disclose” proceeding in accordance with the
Commission’s ex parte rules.17 Persons making ex parte presentations must file a copy of any written
presentation or a memorandum summarizing any oral presentation within two business days after the
presentation (unless a different deadline applicable to the Sunshine period applies). Persons making oral
ex parte presentations are reminded that memoranda summarizing the presentation must (1) list all
persons attending or otherwise participating in the meeting at which the ex parte presentation was made,
and (2) summarize all data presented and arguments made during the presentation. If the presentation
consisted in whole or in part of the presentation of data or arguments already reflected in the presenter’s

and calls where the caller listened to an announcement or other recording from the terminating LEC before hanging
16 See Electronic Filing of Documents in Rulemaking Proceedings, 63 FR 24121 (1999).
17 47 C.F.R. §§ 1.1200 et seq.

written comments, memoranda or other filings in the proceeding, the presenter may provide citations to
such data or arguments in his or her prior comments, memoranda, or other filings (specifying the relevant
page and/or paragraph numbers where such data or arguments can be found) in lieu of summarizing them
in the memorandum. Documents shown or given to Commission staff during ex parte meetings are
deemed to be written ex parte presentations and must be filed consistent with rule 1.1206(b). In
proceedings governed by rule 1.49(f) or for which the Commission has made available a method of
electronic filing, written ex parte presentations and memoranda summarizing oral ex parte presentations,
and all attachments thereto, must be filed through the electronic comment filing system available for that
proceeding, and must be filed in their native format (e.g., .doc, .xml, .ppt, searchable .pdf). Participants in
this proceeding should familiarize themselves with the Commission’s ex parte rules.
For further information, please contact Gregory Kwan, Competition Policy Division, Wireline
Competition Bureau at (202) 418-1191 or

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