Federal Communications Commission DA 15-987 
 
Before the 
Federal Communications Commission 
Washington, D.C. 20554 
 
 
In the Matter of 
 
Applications Filed by Frontier Communications 
Corporation and Verizon Communications Inc. for 
the Partial Assignment or Transfer of Control of  
Certain Assets in California, Florida, and Texas 
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WC Docket No. 15-44 
 
MEMORANDUM OPINION AND ORDER 
 
Adopted:  September 2, 2015 Released:  September 2, 2015 
 
By the Chief, Wireline Competition Bureau; Chief, International Bureau; and Chief, Wireless 
Telecommunications Bureau: 
 
I. INTRODUCTION 
 
1. Frontier Communications Corporation (Frontier) and Verizon Communications Inc. 
(Verizon) (together, Applicants) filed a series of applications1 pursuant to sections 214 and 310(d) of the 
Communications Act of 1934, as amended (Act), seeking consent to various assignments and the transfer 
of control of licenses and authorizations held by Verizon’s wholly-owned subsidiaries in California, 
Florida, and Texas to Frontier. 
2. On March 12, 2015, the Wireline Competition Bureau (WCB), the International Bureau 
(IB), and the Wireless Telecommunications Bureau (WTB) released a Public Notice seeking comment on 
the proposed transaction.2  In response to the Public Notice, we received a total of ten filings:  five 
comments expressing concern about the transaction,3 two petitions to deny the transaction,4 and three 
                                                     
1 See Verizon Communications Inc. and Frontier Communications Corporation Application for Consent to Partially 
Assign and Transfer Control of Authority to Provide Global Facilities-Based and Global Resale International 
Telecommunications Services and Transfer Control of Domestic Common Carrier Transmission Lines, Pursuant to 
Section 214 of the Communications Act of 1934, as Amended, WC Docket No. 15-44 (filed Feb. 24, 2015) 
(Application).  Applicants filed a supplement to the Application on March 6, 2015.  Letter from Jennifer L. Kostyu, 
Counsel to Frontier, to Marlene H. Dortch, Secretary, FCC, WC Docket No. 15-44 (filed Mar. 6, 2015). 
2 Applications Filed by Frontier Communications Corporation and Verizon Communications Inc. for the Partial 
Assignment or Transfer of Control of Certain Assets in California, Florida, and Texas, WC Docket No. 15-44, 
Public Notice, 30 FCC Rcd 2234 (WCB/IB/WTB 2015). 
3 See Comments of California Association of Competitive Telecommunications Companies, WC Docket No. 15-44 
(filed Apr. 13, 2015) (CALTEL Comments); Comments of COMPTEL, WC Docket No. 15-44 (filed Apr. 13, 2015) 
(COMPTEL Comments); Comments of Communications Workers of America, WC Docket No. 15-44 (filed Apr. 
13, 2015) (CWA Comments); Comments of TEXALTEL, WC Docket No. 15-44 (filed Apr. 13, 2015) (TEXALTEL 
Comments); Joint Comments of The Utility Reform Network, The National Association of State Utility Consumer 
Advocates (NASUCA), and the Center for Accessible Technology, WC Docket No.15-44 (filed Apr. 13, 2015) 
(jointly, Consumer Advocates Comments). 
4 The Greenlining Institute Petition to Deny, WC Docket No. 15-44 (filed Apr. 13, 2015) (Greenlining Petition); 
Petition to Deny of Florida Power & Light Company, WC Docket No. 15-44 (filed Apr. 17, 2015) (Florida Power & 
Light Petition).  Florida Power & Light requests acceptance of its late-filed petition, explaining that it attempted to 
file its petition on time on April 13, 2015, but experienced an electronic filing error.  It states that the delay did not 
(continued …) 
 Federal Communications Commission DA 15-987  
 
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replies.5  Three of the commenters are competitive local exchange carrier (LEC) trade associations 
(CALTEL, COMPTEL, TEXALTEL) that request continuing access to interconnection agreements, 
wholesale inputs, and more detail on the customer transition process.6  Communications Workers of 
America (CWA) and a joint group of Consumer Advocates express concerns about broadband 
deployment, service quality, Frontier’s financial qualifications, and job retention.7  Florida Power & Light 
petitioned the Commission to deny the transaction based on existing pole attachment disputes with 
Verizon.8  The Greenlining Institute expresses concern about the effect of the transaction on supplier 
diversity and employment, among other points.9  We also received replies from the Applicants as well as 
the Competitive Carriers Association (CCA), which support the competitive LECs’ arguments about 
wholesale inputs and interconnection,10 and from Lumos Networks, a competitive LEC that raises 
concerns about existing pole attachment disputes with Frontier in West Virginia.11  We discuss the issues 
raised by commenters and petitioners as part of our analysis below.12   
3. In addition to our review, the States of California and Texas are also conducting reviews 
to ensure that the transaction is in the public interest.13  We emphasize that our review of applications 
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cause prejudice to any party because it had already provided a timely copy of its petition via electronic mail to all of 
the relevant parties in the proceeding, including Commission staff.  Florida Power & Light Motion to Accept Late 
Filed Petition, WC Docket No. 15-44, at 1-2 (filed Apr. 17, 2015).  We agree that acceptance of Florida Power & 
Light’s petition does not adversely affect our consideration of any party’s comments in this proceeding.  We 
therefore grant Florida Power & Light’s request. 
5 Reply Comments of Competitive Carriers Association, WC Docket No. 15-44 (Apr. 13, 2015) (CCA Reply); 
Reply Comments of Lumos Networks, LLC and Lumos Networks of West Virginia, Inc., WC Docket No. 15-44 
(filed Apr. 18, 2015) (Lumos Reply).  On April 28, 2015, Applicants filed an opposition and reply to the 
commenters and petitioners.  Joint Opposition to Petitions to Deny and Reply to Comments by Frontier 
Communications Corporation and Verizon Communications Inc., WC Docket No. 15-44 (filed Apr. 28, 2015) 
(Applicant Reply).   
6 CALTEL Comments at 5-12; COMPTEL Comments at 5-13; TEXALTEL Comments at 5-7. 
7 Consumer Advocates Comments at 3-19; CWA Comments at 5-8.  On August 4, 2015, CWA filed a letter stating 
that it had reached an agreement with Frontier and now supports Commission consent to the transaction.  Letter 
from Debbie Goldman, Telecommunications Policy Director to Communications Workers of America, to Marlene 
H. Dortch, Secretary, FCC, WC Docket No. 14-22 (filed Aug. 4, 2015) (CWA Aug. 4, 2015 Ex Parte Letter). 
8 Florida Power & Light Petition at 4-22. 
9 Greenlining Petition at 1-9.  Greenlining states in its April 13, 2015 petition to deny that its filing is based on 
“information that is currently available” and that its “current position may not be its ultimate position.”  Id. at 1. 
10 CCA Reply at 3-8. 
11 Lumos Reply at 2-5. 
12 See infra at paras. 14-30. 
13 Joint Application of Frontier Communications Corporation, Frontier Communications of America, Inc. 
(U5429C), Verizon California, Inc. (U1002C), Verizon Long Distance LLC (U5732C), and Newco West Holdings 
LLC for Approval of Transfer of Control Over Verizon California, Inc. and Related Approval of Transfer of Assets 
and Certifications, 15-03-005 (Cal. Pub. Util. Comm., filed Mar. 18, 2015); Application of GTE Southwest 
Incorporated dba Verizon Southwest and Frontier Communications Corporation for an Amendment to a Certificate 
of Operating Authority, Proposed Order, Docket No. 44630 (Tex. Pub. Util. Comm., rel. Aug. 21, 2015).  Applicants 
state that there was no required approval process in Florida. Letter from William F. Maher, Jr., Counsel to Frontier 
Communications Corporation, to Marlene H. Dortch, Secretary, FCC, WC Docket No. 15-44 (filed Aug. 25, 2015) 
(Frontier Aug. 25, 2015 Ex Parte Letter).  On May 8, 2015, the U.S. Department of Justice (DOJ) granted early 
termination of its pre-merger review under the Hart-Scott-Rodino Antitrust Improvements Act of 1975.  Early 
Termination Notices, https://www.ftc.gov/enforcement/premerger-notification-program/early-termination-
notices/20150937. 
 Federal Communications Commission DA 15-987  
 
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filed with the Commission does not impact the states’ independent proceedings on the proposed 
transaction, nor do we intend any finding in this Memorandum Opinion and Order to pre-judge the states’ 
independent consideration of matters before them under applicable state law or precedent, which may 
differ from our standard of review. 
4. We have carefully reviewed the record, and requested and analyzed additional 
information from the Applicants.14  Based on our analysis, we find that approval of the transaction is 
unlikely to result in any potential public interest harms outweighing any potential public interest benefits.  
Accordingly, we find that the transaction, on balance, serves the public interest, and we consent to the 
proposed assignments and transfers.  
II. BACKGROUND 
A. Description of the Applicants 
1. Frontier Communications Corp. 
5. Frontier is the fourth largest incumbent LEC in the United States and serves primarily 
rural areas and smaller cities.15  Through its wholly-owned operating companies, Frontier provides 
residential and business customers with telecommunications and other services, including local and long 
distance voice services, broadband Internet access service, and multichannel video service.16  Frontier 
currently has approximately four million customers, including 2.3 million broadband customers in 28 
states.17  Applicants state that Frontier, a publicly traded Delaware corporation, has no entities or 
individuals that own 10 percent or more of its stock.18 
                                                     
14 Letter from Randy Clarke, Chief, Competition Policy Division, FCC, to William F. Maher and Patrick R. Halley, 
Counsel to Frontier Communications Corporation, and Kathleen M. Grillo, Senior Vice President, Federal 
Regulatory and Legal Affairs, Verizon, WC Docket No. 15-44 (filed June 17, 2015) (Supplemental Information 
Request Letter); Letter from William F. Maher, Jr., Counsel to Frontier Communications Corporation, to Marlene H. 
Dortch, Secretary, FCC WC Docket No. 15-44 (filed July 1, 2015) (Response to Information Request); Letter from 
William F. Maher, Jr., Counsel to Frontier Communications Corporation, to Marlene H. Dortch, Secretary, FCC, 
WC Docket No. 15-44 (filed June 10, 2015) (Frontier June 10, 2015 Ex Parte Letter). 
15 Frontier Communications Corp., Form 10-Q for the Quarterly Period Ended March 31, 2015 at 21 (May 7, 2015), 
available at http://investor.frontier.com/secfiling.cfm?filingID=20520-15-33&CIK=20520. 
16 Application, Exh. 1, Description of the Parties, Description of the Transaction, Public Interest Statement and 
Administrative Matters (Public Interest Statement) at 4-5. 
17 Id. at n.6.  Frontier currently serves customers in Alabama, Arizona, California, Florida, Georgia, Idaho, Illinois, 
Indiana, Iowa, Michigan, Minnesota, Mississippi, Montana, Nebraska, Nevada, New Mexico, New York, North 
Carolina, Ohio, Oregon, Pennsylvania, South Carolina, Tennessee, Utah, Washington, West Virginia, and 
Wisconsin. Frontier states that, as of August 1, 2015, the approximate numbers of customers broken down by the 
services the customers purchase are as follows:  approximately [Begin Confidential Information]  [End 
Confidential Information] customers purchase broadband service on a standalone basis; approximately [Begin 
Confidential Information]  [End Confidential Information] customers purchase voice service on a 
standalone basis; and approximately [Begin Confidential Information]  [End Confidential 
Information] customers purchase bundled broadband and voice services.  As of August 1, 2015, Frontier further 
states that it provides FiOS broadband service to approximately [Begin Confidential Information]  [End 
Confidential Information] customers, DSL broadband service to approximately [Begin Confidential 
Information]  [End Confidential Information] customers, and U-Verse (a video service) to 
approximately [Begin Confidential Information]  [End Confidential Information] customers.  Frontier 
Aug. 25, 2015 Ex Parte Letter at 1-2. 
18 Application at 6. 
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2. Verizon Communications Inc. 
6. Verizon’s operating subsidiaries, Verizon California Inc., Verizon Florida LLC, and GTE 
Southwest Incorporated d/b/a Verizon Southwest (together, the Transferring Companies) provide local 
and long distance retail and wholesale voice and data services, retail broadband services, and video 
services in portions of their respective states.19  Applicants state that these operations include 
approximately 3.7 million voice connections, 2.2 million broadband (DSL and FiOS) connections, and 
1.2 million FiOS video connections.20   
B. Description of the Transaction  
7. On February 5, 2015, Frontier and Verizon entered into a Securities Purchase Agreement 
(Agreement).21  Applicants describe the terms of the Agreement in their Application.  According to their 
Application, prior to closing, Verizon will create “Newco” as a wholly-owned subsidiary and the 
ownership interests of the Transferring Companies will be moved to Newco so that they will become 
wholly-owned, direct subsidiaries of Newco.22  Applicants state that Frontier will then purchase all of the 
ownership interests of Newco.23  Upon completion of the proposed transaction, Newco will become a 
wholly-owned, direct subsidiary of Frontier and, accordingly, the Transferring Companies will become 
wholly-owned, indirect subsidiaries of Frontier.24  In addition, Applicants state that certain voice long 
distance customers of Verizon Long Distance LLC will be assigned to Frontier Communications of 
America, Inc., an affiliate of Frontier.25  Applicants further state that these customers primarily originate 
switched long distance traffic initiating from the local exchanges in California, Florida, and Texas that are 
a part of the proposed transaction.26   
III. DISCUSSION 
A. Standard of Review 
8. Pursuant to sections 214(a) and 310(d) of the Act, the Commission must determine whether 
the proposed assignments and transfer of control of certain licenses and authorizations held and controlled 
by Verizon to Frontier will serve the public interest, convenience, and necessity.27  In making this 
determination, the Commission first assesses whether the proposed transaction complies with the specific 
provisions of the Act, other applicable statutes, and the Commission’s rules.28  If the proposed transaction 
does not violate a statute or rule, the Commission considers whether the transaction could result in public 
                                                     
19 Public Interest Statement at 1. 
20 Id. at 9.  
21 Id. at 8. 
22 Id. 
23 Id. 
24 Id. at 9.  See supra para. 6 (listing Transferring Companies). 
25 Id. 
26 Id. 
27 47 U.S.C. §§ 214(a), 310(d).  Section 310(d) of the Act requires that we consider applications for transfer of Title 
III licenses under the same standard as if the proposed transferee were applying for licenses directly under section 
308 of the Act, 47 U.S.C. § 308.  See, e.g., AT&T Inc. and BellSouth Corporation Application for Transfer of 
Control, WC Docket No. 06-74, Memorandum Opinion and Order, 22 FCC Rcd 5662, 5672, para. 19 (2007) 
(AT&T/BellSouth Order). 
28 Applications filed by Qwest Communications International Inc. and CenturyTel, Inc. d/b/a CenturyLink for 
Consent to Transfer Control, WC Docket No. 10-110, Memorandum Opinion and Order, 26 FCC Rcd 4194, 4199, 
para. 7 (2011) (Qwest/CenturyLink Order); AT&T/BellSouth Order, 22 FCC Rcd at 5671-72, para. 19. 
 Federal Communications Commission DA 15-987  
 
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interest harms by substantially frustrating or impairing the objectives or implementation of the Act or 
related statutes.29  The Commission then employs a balancing test, weighing any potential public interest 
harms of the proposed transaction against the potential public interest benefits.30  Applicants bear the 
burden of proving, by a preponderance of the evidence, that the proposed transaction, on balance, serves 
the public interest.31   
9. The public interest evaluation necessarily encompasses the “broad aims of the 
Communications Act,” which include, among other things, a deeply rooted preference to protect and 
promote competition in relevant markets, accelerate private-sector deployment of advanced services, 
ensure a diversity of license holdings, and generally manage spectrum in the public interest.32  The public 
interest analysis may also entail assessing whether the transaction will affect the quality of 
communications services or will result in the provision of new or additional services to consumers.33  In 
conducting this analysis, the Commission may consider technological and market changes, as well as 
trends within the communications industry, including the nature and rate of change.34 
10. The Commission’s competitive analysis, which forms an important part of the public 
interest evaluation, is informed by, but not limited to, traditional antitrust principles.35  The U.S. 
Department of Justice (DOJ) reviews telecommunications mergers pursuant to section 7 of the Clayton 
Act, and if it wishes to block a merger, it must demonstrate that the merger may substantially lessen 
competition or tend to create a monopoly.36  DOJ’s review is also limited solely to an examination of the 
competitive effects of the acquisition, without reference to other public interest considerations.37  The 
Commission’s competitive analysis under the public interest standard is somewhat broader.  For example, 
it considers whether a transaction will enhance, rather than merely preserve, existing competition, and it 
takes a more extensive view of potential and future competition and its impact on the relevant market.38 
11. The Commission’s analysis with respect to the claimed benefits of any proposed 
transaction considers a number of factors.39  First, the benefit must be transaction-specific.40  That is, the 
                                                     
29 See, e.g., AT&T/BellSouth Order, 22 FCC Rcd at 5672, para. 19. 
30 See, e.g., id.  
31 See, e.g., id. 
32 See, e.g., Applications of Softbank Corp., Starburst II, Inc., Sprint Nextel Corporation, and Clearwire 
Corporation for Consent to Transfer Control of Licenses and Authorizations; Petitions for Reconsideration of 
Applications of Clearwire Corporation for Pro Forma Transfer of Control, IB Docket No. 12-343, Memorandum 
Opinion and Order, Declaratory Ruling, and Order on Reconsideration, 28 FCC Rcd 9642, 9651, para. 24 (2013) 
(Softbank/Sprint Order); Application of AT&T Inc. and Qualcomm Incorporated for Consent to Assign Licenses and 
Authorizations, WT Docket No. 11-18, Order, 26 FCC Rcd 17589, 17603, para. 32 (2011) (AT&T/Qualcomm 
Order).  
33 See, e.g., Softbank/Sprint Order, 28 FCC Rcd at 9651, para. 24; AT&T/BellSouth Order, 22 FCC Rcd at 5673, 
para. 20. 
34 See, e.g., Softbank/Sprint Order, 28 FCC Rcd at 9651, para. 24; AT&T/Qualcomm Order, 26 FCC Rcd at 17599, 
para. 24.   
35 See, e.g., Softbank/Sprint Order, 28 FCC Rcd at 9651, para. 25 (2013); AT&T/BellSouth Order, 22 FCC Rcd at 
5673, para. 21. 
36 15 U.S.C. § 18. 
37 Id. 
38 See, e.g., Softbank/Sprint Order, 28 FCC Rcd at 9651-52, para. 25; AT&T/BellSouth Order, 22 FCC Rcd at 5673, 
para. 21.  
39 See, e.g., Softbank/Sprint Order, 28 FCC Rcd at 9677-78, para. 91; AT&T/BellSouth Order, 22 FCC Rcd at 5760, 
para. 200.   
 Federal Communications Commission DA 15-987  
 
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claimed benefit must be likely to occur as a result of the transaction, but unlikely to be realized by other 
practical means having fewer anticompetitive effects.41  Second, the benefit must be verifiable.42  Because 
much of the information relating to the potential benefits of a transaction is in the sole possession of the 
applicants, they are required to provide sufficient evidence supporting each claimed benefit to allow the 
Commission to verify its likelihood and magnitude.  Third, “the magnitude of benefits must be calculated 
net of the cost of achieving them.”43  Specifically, in evaluating the magnitude of benefits, the 
Commission assesses the efficiencies and benefits the applicants claim in light of the costs produced by 
the merger or incurred in achieving the efficiencies or benefits.44  Finally, the Commission applies a 
“sliding scale approach” to evaluating benefit claims.45  Under this sliding scale approach, where potential 
harms appear “both substantial and likely, a demonstration of claimed benefits also must reveal a higher 
degree of magnitude and likelihood than we would otherwise demand.”46  Based on the record, and to the 
extent that commenters raise potential concerns, for example addressing competitive harm or other 
negative impacts, the Commission evaluates whether the proposed transaction would be likely to result in 
those potential harms.  Conversely, where potential harms appear unlikely or less likely and less 
substantial, the Commission will accept a lesser showing of claimed benefits.47 
B. Applicants’ Qualifications 
12. As a threshold matter, we must determine whether the Applicants meet the requisite 
qualifications to hold and assign and transfer licenses under section 310(d) of the Act and the 
Commission’s rules.  In general, when evaluating assignments under section 310(d), we do not re-
evaluate the qualifications of the transferor.48  Exceptions to this rule occur where, for example, issues 
related to basic qualifications have been designated for hearing by the Commission or have been 
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40 See Applications of AT&T Inc. and DIRECTV for Consent to Assign or Transfer Control of Licenses and 
Authorizations, MB Docket No. 14-90, Memorandum Opinion and Order, FCC 15-94, para. 273 (2015) 
(AT&T/DIRECTV Order); Applications for Transfer of Control of Licenses from Comcast Corp. and AT&T Corp., 
Transferors, to AT&T Comcast Corp., Transferee, Memorandum Opinion and Order, 17 FCC Rcd 23246, 23310, 
para. 165 (2002) (disregarding purported harms that are speculative and not merger specific). 
41 Applications of Comcast Corp., General Electric Company and NBC Universal, Inc. for Consent to Assign 
Licenses and Transfer Control of Licensees, MB Docket No. 10-56, Memorandum Opinion and Order, 26 FCC Rcd 
4238, 4330-31, para. 226 (2011). 
42 See, e.g., AT&T/DIRECTV Order at para. 274; Softbank/Sprint Order, 28 FCC Rcd at 9677-78, para. 91. 
43 See, e.g., Softbank/Sprint Order, 28 FCC Rcd at 9677-78, para. 91.   
44 See Application of Echostar Communications Corporation, General Motors Corporation, and Hughes Electronics 
Corporation (Transferors) and Echostar Communications Corporation (Transferee), MB Docket No. 01-348, 
Hearing Designation Order, 17 FCC Rcd 20559, 20630-31, para 190, n.464 (2002) (citing Horizontal Merger 
Guidelines, issued by the U.S. Department of Justice & Federal Trade Commission, April 2, 1992, revised April 8, 
1997 at § 4). 
45 See, e.g., Softbank/Sprint Order, 28 FCC Rcd at 9677-78, para. 91. 
46 See, e.g., id. at 9678-79, para. 93. 
47 See, e.g., id. 
48 See, e.g., Applications of Sprint Nextel Corporation and Clearwire Corporation for Consent to Transfer Control 
of Licenses, Leases and Authorizations, WT Docket No. 08-94, Memorandum Opinion and Order and Declaratory 
Ruling, 23 FCC Rcd 17570, 17582-83, para. 23 (2008) (Sprint Nextel/Clearwire Order); Applications of Cellco 
Partnership d/b/a Verizon Wireless and Atlantis Holdings LLC For Consent To Transfer Control of Licenses, 
Authorizations, and Spectrum Manager and De Facto Transfer Leasing Arrangements, WT Docket No. 08-95, 
Memorandum Opinion and Order and Declaratory Ruling, 23 FCC Rcd 17444, 1764, para. 31 (2008) (Verizon 
Wireless/ALLTEL Order). 
 Federal Communications Commission DA 15-987  
 
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sufficiently raised in petitions to warrant the designation of a hearing.49  This is not the case here.  Thus, 
we need not evaluate Verizon’s basic qualifications.   
13. With respect to the proposed transferee, Section 310(d) requires that the Commission 
consider its qualifications as if it were applying for the license directly under section 308 of the Act.50  
Among the factors that the Commission considers in its public interest inquiry is whether the applicant for 
a license or license transfer has the requisite “citizenship, character, and financial, technical, and other 
qualifications.”51  CWA commented that Frontier should explain how it has the financial resources to 
maintain and expand services, including broadband and video services, in the affected exchanges.52  We 
address Frontier’s financial qualifications in section C.1.b., below. 
C. Public Interest Harms and Benefits 
14. In this section, we consider the potential harms and benefits arising from the merger.  As 
discussed below, we find that this transaction is likely to result in tangible potential benefits for customers 
through improved broadband service and investment, and certain synergies and cost savings.  Because 
Verizon and Frontier do not currently compete against each other in the affected exchanges, the 
transaction does not reduce the number of service providers in local markets.  Applicants have filed 
additional evidence in the record that adequately addresses other potential harms, and we find that certain 
issues raised in comments are not transaction-specific and are therefore outside the scope of our review.  
Overall, we find that the transaction’s potential benefits outweigh any potential public interest harms. 
1. Potential Harms 
a. Competition 
15. Based on the record evidence, we conclude that this transaction is unlikely to have 
adverse competitive effects.53  In order for a merger to have horizontal effects on competition, the parties 
must currently provide, or be very likely to provide, similar services within the same relevant geographic 
market.54  Where a company expands geographically, however, there may also be competitive effects, 
depending on its share of a larger geographic market.  Although Frontier and Verizon have adjacent local 
exchanges in three areas of California, Applicants assert that they do not compete for customers in the 
relevant market for the transaction because Frontier operates neither local exchange nor mobile facilities 
                                                     
49 See, e.g., Sprint Nextel/Clearwire Order, 23 FCC Rcd at 17582-83, para. 23; Verizon Wireless/ALLTEL Order, 23 
FCC Rcd at 17464, para. 31. 
50 47 U.S.C. § 310(d). 
51 47 U.S.C. §§ 308(b) (“All applications for station licenses, or modifications or renewals thereof, shall set forth 
such facts as the Commission by regulation may prescribe as to the citizenship, character, and financial, technical, 
and other qualifications of the applicant to operate the station . . .”), 310(d); 47 C.F.R. § 63.03(c)(1)(v) (stating that 
the Commission, acting through the Chief of the Wireline Competition Bureau, may determine that an application 
“requires further analysis to determine whether a proposed transfer of control would serve the public interest”).  See 
AT&T/BellSouth Order, 22 FCC Rcd at 5756, para. 191; Applications of SBC Communications Inc. and BellSouth 
Corporation for Consent to Transfer of Control or Assignment of Licenses and Authorizations, WT Docket No. 00-
81, Memorandum Opinion and Order, 15 FCC Rcd 25459, 25465, para. 14 (WTB/IB 2000). 
52 CWA Comments at 2.  See Applications Filed by Frontier Communications Corporation and Verizon 
Communications Inc. for Assignment or Transfer of Control, WC Docket 09-95, Memorandum Opinion and Order, 
25 FCC Rcd 5972, 5979-83, paras. 13-14, 18-25 (2010) (Verizon/Frontier Order). 
53 Verizon/Frontier Order, 25 FCC Rcd at 5980, paras. 15-16 (concluding that there were no horizontal effects in the 
transaction where Applicants did not compete for customers). 
54 The Commission has stated that a transaction is considered to be horizontal when the parties to the transaction sell 
products that are in the same relevant product and geographic markets.  See, e.g., AT&T/BellSouth Order, 22 FCC 
Rcd at 5675, para. 23 & n.82. 
 Federal Communications Commission DA 15-987  
 
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in any of the transferring exchanges.55  Further, Frontier states that, prior to the proposed transaction, it 
had no plans for expanding operations into the acquired territories.56   
16. Notably, no commenter asserts that the combined entity will hold market power or that 
the transaction would directly result in a significant reduction of competition at the local level or, based 
on any aggregation of subscribers, at a regional or national level.57  Applicants argue that the proposed 
transaction actually would result in increased competition by creating a stronger competitor to national 
telecommunications and cable companies.58  Applicants state that Verizon will retain all of its wireless 
operations in the affected states.59  Therefore, we find that, based on our review of the record, the 
transaction is unlikely to result in any reduction in competition. 
b. Frontier’s Financial Condition Post-Transaction  
17. Financial Issues.  As part of its public interest inquiry, the Commission must consider 
whether the applicant for a license transfer has the “requisite . . . financial, technical, and other 
qualifications.”60  In making this determination, the Commission will not substitute its judgment for that 
of the applicant or the market.61 
18. Some commenters expressed concern that Frontier might not be financially qualified to 
maintain and invest in the networks it is seeking to acquire in this transaction.  CWA expressed concern 
that, post-transaction, Frontier might be capital constrained due to competing demands on its resources for 
debt service and increased dividend payouts to shareholders, and that, as a result, Frontier might not be 
able to expand fiber and maintain copper networks that it is acquiring from Verizon.62  Other commenters 
                                                     
55 Public Interest Statement at 14-15, 18. 
56 Id. at 18. 
57 AT&T/DIRECTV Order at paras. 146-147, 155-156 (finding that although the transaction would result in some 
loss of competition between AT&T and DIRECTV, which provided overlapping video services, the transaction did 
not result in harmful horizontal effects because the parties focused their marketing efforts on customers of cable 
companies, which they considered to be their primary competitors, and because AT&T’s wireline and DIRECTV’s 
satellite video services were not “particularly close substitutes.”).  Similar concerns have not been raised regarding 
the proposed transaction, because there is no evidence Frontier will have market power on a national level.  We 
address claims raised by commenters and petitioners regarding the potential impact of the transaction on wholesale 
inputs and other issues that could affect competition in paras. 21-28 below.  
58 Public Interest Statement at 3-4, 15-16. 
59 Id. at 9, n.16. 
60 47 U.S.C. § 308; AT&T/BellSouth Order, 22 FCC Rcd at 5756, para. 190.  See Applications of Ameritech Corp., 
Transferor, and SBC Communications Inc., Transferee, CC Docket No. 98-141, Memorandum Opinion and Order, 
14 FCC Rcd 14712, 14947-48, para. 568 (1999); see 47 U.S.C. § 310(d). 
61 See Verizon/Frontier Order, 25 FCC Rcd at 5981-83, para. 19 (stating that “although the Commission has a 
responsibility to consider the financial qualifications of the transferee, it is not the Commission’s role to substitute 
its business judgment for that of the applicants or the market:  rather, the relevant question here is whether Frontier 
has the requisite financial qualifications to hold and use these Commission licenses and authorizations in the public 
interest.”).  
62 CWA Comments at 11-13.  CWA commented that a financial analyst projected that Frontier’s “capital intensity” 
(which is a measure of capital expenditures as a percent of Frontier’s revenues) might be below that of other 
telecommunications carriers, including rural carriers.  CWA cited to an analyst report that estimated that Frontier’s 
capital intensity would fall to 12.9 percent by 2018, as compared to its pre-acquisition capital intensity of 14.4 
percent.  CWA states that this would drop Frontier’s capital intensity to below the 2014 capital intensities of 
CenturyLink, Windstream, Verizon, and AT&T.  Id.  Frontier provided record information indicating that its capital 
intensity from 2010-2014 was consistent with and, in some cases, higher than other carriers.  Applicant Reply at 11 
and Exh. A, Declaration of John M. Jureller (Frontier Jureller Reply Decl.) at paras. 13-14.  We agree that there are 
no specific claims in the record about Frontier’s underinvestment in network assets.  In addition, as discussed below, 
(continued …) 
 Federal Communications Commission DA 15-987  
 
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also expressed concern regarding Frontier’s financial ability to manage its increased footprint post-
transaction.63  Commenters disagree with Frontier’s assertion that EBITDA (earnings before interest, 
taxes, depreciation, and amortization) is a useful calculation to demonstrate an improved capital structure 
and an ability to invest in its network.64  Further, some commenters express concern that Frontier is 
disinvesting in its network, claiming that, in each of the years 2011 through 2014, Frontier’s capital 
expenditures were less than network depreciation.65   
19. To address financial concerns raised in the record, we requested that Frontier provide 
information on any issues that would compromise its ability to improve its network and customer service 
quality, information on its debt level, and additional details on its financial expectations and cost 
reduction plans.66  Frontier submitted a declaration from its Executive Vice President and Chief Financial 
Officer stating that the transaction will strengthen Frontier’s financial profile and improve scalability so 
that it can better provide high-quality services in the long term.67  Frontier maintains that the major credit 
rating agencies expect that it will be able to use its increased cash flows and capital resources to improve 
services and network facilities, and that Moody’s Investors Service affirmed Frontier’s corporate credit 
rating after it announced the transaction, noting that the increased cash flow will improve Frontier’s 
ability to invest in its network.68  
20. While we cannot predict with certainty whether Frontier will be free of any financial 
difficulties after closing, no commenter has disputed the additional information in the record, and we are 
not persuaded that the transaction is unduly risky or will result in specific public interest harms.  We also 
agree with Frontier that it has not entered into this transaction with a disincentive to invest in its network 
and broadband infrastructure, which would impact its ability to compete against cable and wireless 
providers, and that it can most efficiently serve the wireline customer base in the transaction areas by 
investing in more economical, modernized equipment.69  After careful review, and as the Commission has 
found in prior Frontier transactions, we find that the general assessment of the financial community and 
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Verizon has acknowledged that it has no specific plans to further invest in infrastructure in the transaction areas, 
while Frontier has demonstrated that its business plans include significant investment after consummation of the 
transaction.  See infra at paras. 35-36. 
63 Consumer Advocates Comments at 6. 
64 Id. at 6-7.  EBITDA is widely used by industry observers, such as equity analysts, as an indicator of profitability 
in the telecommunications sector and provides perspective on operating cash flow.  See Applications of AT&T Inc. 
and Deutsche Telekom AG for Consent to Assign or Transfer Control of Licenses and Authorizations, WT Docket 
No. 11-65, Order, 26 FCC Rcd 16184, 16207, n.37 (Wireless Telecom. Bur. 2011).  Frontier has provided evidence 
in the record explaining that it expects its operations to support long term revenue and increased EBITDA 
generation.  Applicant Reply at 6-7; Frontier Jureller Reply Decl. at paras. 13-14; Response to Information Request 
at 3-4 (providing information on net debt to adjusted EBITDA ratio for the proposed transaction). 
65 Consumer Advocates Comments at 18-19, and Table 2.  Commenters argue that, in 2011, Frontier’s depreciation 
and amortization was $1.4 billion, and its capital expenditures were $748 million; in 2012, depreciation and 
amortization was $1.2 billion and capital expenditures were $748 million; in 2013, depreciation and amortization 
were $1.1 billion, while capital expenditures were $634 million; and, in 2014, depreciation and amortization were 
$1.1 billion and capital expenditures were $572 million.  Id. 
66 Response to Information Request, Exh. at 1. 
67 Frontier Jureller Reply Decl. at paras. 4-14. 
68 Response to Information Request at 2-3.  Frontier states that, as proof that the transaction has been positively 
received by the financial community, it recently closed equity offerings of $750 million of common stock and $1.75 
billion of mandatory convertible preferred stock, which will provide a portion of its capital structure.  Id. 
69 Applicant Reply at 9-15. 
 Federal Communications Commission DA 15-987  
 
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Frontier’s statements regarding its financial viability are reasonable.70  Other than the ordinary market 
risks that accompany any business transaction, there is no evidence in the record indicating that this 
transaction will be likely to result in financial harms that we expect would compromise Frontier’s ability 
to maintain and improve its networks.71  We find no persuasive evidence that Frontier is an underfunded 
or an irresponsible buyer unlikely to fulfill its obligations.  Based on the record before us, we therefore 
conclude that Frontier has shown that it has the requisite financial qualifications to undertake the 
proposed transaction.  
c. Other Issues 
21. Infrastructure and Service Quality.  In response to the Public Notice, certain commenters 
raised concerns about the current state of Verizon’s copper network, particularly in California, and assert 
that Verizon has a poor service quality record.72  They caution that Frontier may be unable or unwilling to 
remedy these issues, claiming that Frontier has urged the California Public Utilities Commission (CPUC) 
to “eliminate all service quality measurements and rely on competition to protect consumers and network 
reliability,”73 and that the record presented is insufficient to evaluate Frontier’s resources to support and 
maintain quality customer service.74  Similarly, with regard to Applicants’ network infrastructure, Florida 
Power & Light and Lumos raise concerns about both Applicants’ prior actions with respect to pole 
attachments.75  Florida Power & Light and Lumos urge the Commission to impose conditions on a grant 
of this transaction to remedy these alleged failures and violations and to ensure that the transaction serves 
the public interest.76   
22. In response, Applicants assert that the allegations regarding the state of Verizon’s 
network are beyond the scope of this proceeding, and note that they are the subject of an ongoing 
rulemaking proceeding with the CPUC.77  Applicants further contend that commenters’ pole attachment 
claims are non-transaction-specific and industry-wide policy issues that should be addressed in other 
proceedings.78  They also state that Florida Power & Light currently has complaint proceedings regarding 
these issues pending before the Commission, which were initiated prior to this transaction.79   
23. The Commission has previously found improved quality, enhanced service, and new 
products to be examples of consumer benefits resulting from merger-specific efficiencies that are relevant 
                                                     
70 Verizon/Frontier Order, 25 FCC Rcd at 5980-83, paras. 18-24; Applications Filed by Frontier Communications 
Corporation and AT&T Inc. for the Assignment or Transfer of Control of the Southern New England Telephone 
Company and SNET America, Inc., WC Docket No. 14-22, Memorandum Opinion and Order, 29 FCC Rcd 9203, 
9208-09, paras. 15-19 (WCB/IB/WTB 2014) (AT&T/Frontier Connecticut Order). 
71 See Verizon/Frontier Order, 25 FCC Rcd at 5980-83, paras. 18-24 (explaining that the Commission accepts that 
all transactions carry risks and that all companies are vulnerable to unforeseen events, but that Frontier, as the 
acquiring company, demonstrated that it was likely to be able to expand broadband and meet service quality 
commitments based on financial conditions at the time it entered into the transaction).   
72 See, e.g., CALTEL Comments at 3-4, 6, 8; CWA Comments at 4, 13. 
73 CALTEL Comments at 9-10. 
74 CALTEL Comments at 3-4; CWA Comments at 4, 13; Consumer Advocates Comments at 8-9, 12-13. 
75 Florida Power & Light Petition at 18-21; Lumos Reply at 3-4 (stating that Lumos has experienced significant 
difficulties in obtaining timely action on pole attachments from Frontier in West Virginia).  
76 Florida Power & Light Petition at 22-23; Lumos Reply at 5. 
77 Applicant Reply at 19-20.  The parties further note that “[w]hat is relevant . . . is that Frontier is committed to 
investing and providing high-quality wireline service in the areas it is acquiring.”  Id. at 20. 
78 Id. at 4.   
79 Id. at 27-28. 
 Federal Communications Commission DA 15-987  
 
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to the public interest analysis.80  As explained below, we find that Frontier is more likely to improve 
service quality and invest in infrastructure improvements, including for voice services, than Verizon 
would be absent the transaction,81 and we therefore disagree with commenter assertions that service 
quality concerns should function as a reason to deny or condition the proposed transaction.82  In response 
to concerns about state commission review of network service quality and ongoing state commitments, 
Applicants affirm that, post-closing, Frontier will continue to be subject to all applicable state regulatory 
commission rules and decisions addressing service quality and remediation, irrespective of the change in 
ownership.83  We also agree with Applicants that the concerns regarding pre-existing pole attachment 
disputes are not relevant to the proposed transaction.  As the Commission has repeatedly held, we will 
generally not impose conditions to remedy pre-existing harms or harms that are unrelated to the 
transaction at issue.84    
24. Wholesale Services and Agreements.  Several competitive LEC commenters ask the 
Commission to condition approval of the transaction on Frontier’s commitment to provide competitive 
agreements and pricing for critical inputs such as interconnection and special access services.85  These 
commenters disagree that Frontier will offer wholesale customers “substantially the same services on the 
same terms and conditions under their existing contracts, price lists and tariffs,” as Frontier committed to 
do in the Application.86  The competitive LECs ask the Commission to convert such assertions into 
enforceable conditions to protect against potential anticompetitive behavior post-closing.87  In particular, 
                                                     
80 See, e.g., Applications of Teleport Communications Group Inc. and AT&T Corp. for Consent to Transfer of 
Control of Point-to-Point Microwave Licenses and Authorizations to Provide International Facilities-Based and 
Resold Communications Services, CC Docket No. 98-24, Memorandum Opinion and Order, 13 FCC Rcd. 15236, 
15242 and n.40 (1998).  
81 See infra at paras. 35-36. 
82 Response to Information Request at 9 (stating that “network enhancements related to expanded deployment of 
broadband such as upgrading interoffice capacity and deploying fiber distribution facilities closer to the premises, 
will also improve the network utilized to provide voice services.”). 
83 Id. at 8. 
84 See Verizon Communications, Inc. and America Móvil, S.A. de C.V., Application for Authority to Transfer Control 
of Telecommunicaciones de Puerto Rico, WT Docket No. 07-43, Memorandum Opinion and Order and Declaratory 
Ruling, 22 FCC Rcd 6195, 6206-07, para. 25 (2007) (rejecting assertions that a transfer of control should be denied 
or conditioned based on non-merger-specific issues and finding that applicants were subject to existing 
requirements).  See Applications of AT&T Inc. and Centennial Communications Corp. For Consent to Transfer 
Control of Licenses, Authorizations, and Spectrum Leasing Arrangements, WT Docket No. 08-246, Memorandum 
Opinion and Order, 24 FCC Rcd 13915, 13929, para. 30, 13974-75, para. 150 (2009) (AT&T/Centennial Order) 
(stating that the Commission will not impose conditions in a merger proceeding to remedy pre-existing harms).   
85 See, e.g., COMPTEL Comments at ii, 6-7; TEXALTEL Comments at 6-7; CCA Reply at 3.  
86 COMPTEL Comments at 7-13; TEXALTEL Comments at 4-6; CCA Reply at 6-8.  See Application at 3, 20-21. 
87 COMPTEL Comments at 7-13; TEXALTEL Comments at 4-6; CCA Reply at 6-8.  COMPTEL also asserts that a 
condition requiring Frontier to honor Verizon interconnection obligations and provide access to wholesale inputs, 
including unbundled high capacity loops, should apply regardless of whether Frontier’s network uses time division 
multiplexing (TDM) or transitions to an all-Internet Protocol (IP) network in the future.  COMPTEL Comments at 
7-9.  As the Commission has held in other contexts, such a condition is not tailored to remedy any purported harms 
arising out of this transaction.  AT&T/Centennial Order, 24 FCC Rcd at 13972, para. 141.  In addition, the carrier 
transition to IP networks is the subject of an ongoing rulemaking proceeding to address such issues on an industry-
wide basis, and is more appropriately addressed in that context.  See Technology Transitions et al., GN Docket No. 
13-5 et al., Report and Order, Order on Reconsideration, and Further Notice of Proposed Rulemaking, FCC 15-97, 
para. 3 (rel. Aug. 7, 2015) (stating that the item is supporting the IP technology transitions by “adopting limited and 
targeted regulation to preserve competition and to protect consumers, especially those in vulnerable populations who 
have not yet voluntarily migrated from plain old telephone service (POTS) and other legacy services”). 
 Federal Communications Commission DA 15-987  
 
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commenters are concerned about Verizon interconnection agreements that are in “evergreen” status (i.e., 
agreements that have passed their expiration dates but continue in effect until canceled by either party),88 
and that Frontier will seek to exercise the rural exemption from wholesale and interconnection provisions 
of section 251 of the Act, to the detriment of competitive LECs.89   
25. In response, Applicants insist that there is no need to impose wholesale commitments on 
this transaction.90  According to Applicants, Frontier will assume existing Verizon wholesale 
agreements;91 will abide by all existing interconnection agreements, including those in rural and non-rural 
areas; will adhere to Verizon’s Statement of Rates for unbundled network elements included in 
interconnection agreements; and, will abide by existing volume and term agreements for wholesale 
customers.92  Frontier also asserts that it has no plans to terminate existing Verizon agreements that are in 
evergreen status after closing.93  In addition, with respect to the rural exemption, Frontier has agreed that, 
“for a term of three years after the Transaction closes, in the portions of the Transferring Areas that are 
rural, Frontier will not assert that it is exempt from section 251(c) obligations pursuant to the rural 
exemption.”94  Applicants also note that this transaction will not convert any non-rural lines into rural 
lines.95  Given these assurances, we find that the transaction is unlikely to result in public interest harms 
related to wholesale service and agreements. 
26. Operations Support Systems.  Commenters criticized the Application for its lack of detail 
regarding the conversion and transition of Verizon’s customers to Frontier’s systems.96  Applicants 
responded to these criticisms, noting that, after closing, the Applicants will transfer current Verizon 
customers onto Frontier’s existing operations support systems (OSS) and billing systems, which 
Applicants state are scalable and will support the operations to be transferred to Frontier.97  Additionally, 
unlike the 14-state Verizon acquisition in 2010, Frontier has its own functioning OSS and billing systems 
in place for the current transfer, and has significant experience with those systems.  It will not be working 
with replicated systems for a year before the cutover as it did before.98  Frontier also states that it already 
has “significant operational experience with systems similar to those of [Verizon], including FiOS.”99  
The parties have agreed to plan for integration and to test the data transfer process prior to conversion, 
and Frontier states that it plans to build on its experience with integrating Verizon’s operations as well as 
                                                     
88 CALTEL Comments at 5; TEXALTEL Comments at 5-6; CCA Reply at 6. 
89 COMPTEL Comments at 5-9; TEXALTEL Comments at 6.  See also 47 U.S.C. § 251(f). 
90 Applicant Reply at 25-26. 
91 Specifically, Frontier states that it will assume those Verizon agreements that relate to service wholly within the 
areas transferred in this transaction.  It further states that “for existing Verizon wholesale agreements that relate in 
part to service outside of the Transferring Areas, Frontier and the relevant counterparty will enter into an agreement 
under which those entities will continue to operate under the terms of the Verizon agreement after closing in the 
respective Transferring Areas only.”  Id. at 25. 
92 Id. at 26-27. 
93 Id. at 27. 
94 Frontier June 10, 2015 Ex Parte Letter at 4. 
95 Applicant Reply at 27. 
96 See, e.g., COMPTEL Comments at 13-14; TEXALTEL Comments at 7. 
97 Applicant Reply at 16. 
98 Id. at 16-17.  Applicants also claim that the transition in Connecticut following the 2014 transaction “overall was 
successful and did not result in prolonged or systemic problems,” stating that the issues which arose there were 
unique to that transaction and “were largely attributable to the unique aspects of transitioning AT&T U-verse 
services.”  Id. at 17. 
99 Id. at 18. 
 Federal Communications Commission DA 15-987  
 
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its experience with transitioning AT&T’s customers in Connecticut in 2014 to help achieve a smooth cut-
over process.100  Frontier further asserts that it has enhanced its data conversion and quality assurance 
processes since the 2010 and 2014 transactions, and that it intends to use its transition team from the 
conversion efforts after the 2014 transaction to implement the transition here.101 
27. In addition, Frontier claims that many wholesale customers in the affected states already 
use Frontier’s OSS, and therefore will not be required to change their existing systems interfaces to 
process orders, track provisioning, or manage troubles.  Frontier notes that it plans to undertake “a 
detailed communication and transition plan” to facilitate the use of the Frontier systems for wholesale 
customers who currently do not do business with Frontier and do not yet interface with Frontier’s 
systems.102  Frontier will provide training for wholesale carriers regarding ordering, provisioning, and 
managing wholesale service issues, and carriers will have the opportunity to conduct system interface 
testing prior to closing.103 
28. Nothing in the record indicates that Verizon’s wholesale or retail customers are likely to 
experience any loss in functionality as a result of the transaction.  Further, in response to the request of 
Commission staff, Frontier has provided detailed information about the cutover plan it is executing with 
Verizon to transition customers.  It states that the companies have established 140 working teams that are 
focused on functional transition plans for retail and wholesale customers and a deliverables schedule.104  
Applicants are currently undergoing a preparatory and testing phase to undertake mock conversions so 
that Frontier’s systems are ready to accept and complete orders, billing, network operations functions, and 
other requirements at the time the transaction closes.  Therefore, we find that, in light of this plan and 
Frontier’s transition experience in prior transactions, it is unlikely that the proposed transaction will result 
in public interest harms related to OSS. 
29. Employment.  CWA notes that the Application provided limited information regarding 
the impact of the transaction on Applicants’ employees, and sought “concrete commitments . . . to ensure 
that the transaction will not lead to any reduction in employment levels, workers’ living standards, and 
service to customers.”105  Similarly, Greenlining raises concerns about potential harm to current levels of 
internal employee diversity as well as supplier diversity, noting that Verizon’s diversity rates “greatly 
exceed Frontier’s,” and that the transaction may result in loss of employment for women or minorities.106  
Greenlining concedes that Applicants have indicated that the transfer will include Frontier’s assumption 
of all of Verizon’s current supplier diversity contracts.107  Other commenters also question whether 
Frontier will have and maintain adequate staffing levels post-closing to ensure that service quality is not 
impaired.108 
                                                     
100 Id. 
101 Id. 
102 Id. 
103 Id. at 18-19. 
104 Response to Information Request at 16-19 and Exh. B, Declaration of John Lass (Frontier Lass Reply Decl.) at 
paras. 10-13.  
105 CWA Comments at 6-7, 13-14.   
106 Greenlining Petition at 5, 7-8. 
107 Greenlining Petition at 7-8.  However, Greenlining cautions that “there is no guarantee Frontier would continue 
Verizon’s commitment to supplier diversity when those contracts expire and the CPUC cannot require it.”  Id. at 7-8. 
108 CALTEL Comments at 8; Consumer Advocates Comments at 12-13; see also Lumos Reply at 2 (“Lumos’ 
challenges attaching to Frontier’s poles are relevant [here] because . . . these issues are an outgrowth of Frontier’s 
inability to adequately manage the ILEC properties it has already acquired.”). 
 Federal Communications Commission DA 15-987  
 
 14 
30. As in previous transactions, Frontier states that it will honor all existing collective 
bargaining agreements, will give Verizon employees credit for the purposes of eligibility, vesting, and 
benefit levels under the company’s employee benefit plans, and will give non-union Verizon employees 
compensation, incentives, and benefits comparable to those they had prior to closing, for a period of one 
year, as well as annual bonus opportunities at the target level in effect immediately prior to closing.109  
Frontier also states that it plans to use the existing workforce that will transfer over with this acquisition, 
and will be hiring local general managers as well as filling other positions across the affected states.110  
On August 4, 2015, CWA filed a letter stating that they have reached an agreement with Frontier 
providing for “employment security protections, the addition of 150 jobs in California and 60 jobs in 
Texas, a commitment to a 100 percent U.S. based workforce, operational flexibility to enhance the service 
experience for customers, and two-year extension of the collective bargaining agreements.”111  Based on 
Frontier’s commitment to existing Verizon employees and commitment to local services and management 
in the affected states, we find that Frontier has provided sufficient assurances that the transaction is 
unlikely to result in public interest harms related to loss of employment.112   
2. Potential Benefits 
31. The Applicants claim that the transaction will result in public interest benefits in two 
primary areas:  improved broadband services and synergies of approximately $700 million by 
consolidating operations and increasing economies of scale.  As described below, based on the record 
before us, we find that the transaction is likely to result in benefits to consumers.113 
32. Improved Broadband Services.  Applicants claim that Frontier will maintain and 
strengthen broadband services in the transaction areas in California, Florida, and Texas.114  Currently, 
Applicants report that 73 percent of households in the transaction areas in all three states have broadband 
available from Verizon at varying speed tiers.115  Frontier states that it plans to expand this availability to 
                                                     
109 Applicant Reply at 21-22.  See also AT&T/Frontier Connecticut Order, 29 FCC Rcd at 9210-11, para. 21. 
110 Applicant Reply at 22. 
111 CWA Aug. 4, 2015 Ex Parte Letter at 1. 
112 See Applications Filed for the Transfer of Certain Spectrum Licenses and Section 214 Authorizations in the 
States of Maine, New Hampshire, and Vermont from Verizon Communications Inc. and its Subsidiaries to FairPoint 
Communications, Inc., WC Docket No. 07-22, Memorandum Opinion and Order, 23 FCC Rcd 514, 537, para. 38 
(2008) (finding that FairPoint’s plan to retain all employees and additional positions supported a conclusion that the 
transaction was not likely to result in the loss of employment).  The CPUC is also reviewing the potential 
employment impact associated with the transaction.  See CPUC July 2, 2015 Amended Scoping Ruling Order, at 6-
7, available at http://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M152/K971/152971955.PDF. 
 
113 The record does not support a finding of verifiable, tangible benefits to competition, and therefore, we do not rely 
upon it in our findings. 
114 Public Interest Statement at 13-14. 
115 Response to Information Request at 9-10 and Exh. 1.  Applicants report that, in California, [Begin Confidential 
Information]  [End Confidential Information] percent of Verizon households have FiOS, [Begin Confidential 
Information]  [End Confidential Information] percent of households have DSL with speeds of 1 Mbps or less, 
[Begin Confidential Information]  [End Confidential Information] percent have DSL with speeds over 1 and 
up to 5 Mbps, and [Begin Confidential Information]  [End Confidential Information] percent have DSL with 
speeds over 5 and up to 15 Mbps; in Florida, [Begin Confidential Information]  [End Confidential 
Information] percent of Verizon households have FiOS, [Begin Confidential Information]  [End 
Confidential Information] percent of households have DSL with speeds of 1 Mbps or less, [Begin Confidential 
Information]  [End Confidential Information] percent have DSL with speeds over 1 and up to 5 Mbps, and 
[Begin Confidential Information]  [End Confidential Information] percent have DSL with speeds over 5 and 
up to 15 Mbps; in Texas, [Begin Confidential Information]  [End Confidential Information] percent of 
Verizon households have FiOS, [Begin Confidential Information]  [End Confidential Information] percent 
(continued …) 
 Federal Communications Commission DA 15-987  
 
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areas where Verizon has not been providing broadband service.  Frontier further explains that those areas 
are primarily rural and are similar to many of Frontier’s service areas in its existing 28-state territory in 
which it has been able to increase broadband deployment.116  Frontier emphasizes that it currently offers 
stand-alone and bundled broadband service, which is its core growth driver, to approximately 92 percent 
of households throughout its current service territories.117  Frontier further states that, as of December 
2014, 55 percent of households in its service territory were capable of download speeds of 20 Mbps or 
more, 74 percent were capable of speeds of 12 Mbps or more, and 83 percent were capable of speeds of 6 
Mbps or more.118  It also states that it has started rolling out one gigabit speeds in certain markets as it 
upgrades its network.119   
33. Frontier affirms that it plans to use public funding, including Connect America Fund 
(CAF) Phase II support, combined with substantial amounts of its own capital, to complete a broadband 
build-out in high cost areas post-transaction.120  It states that it will expand fiber-based infrastructure 
within its network, upgrade network hardware, expand transport capacity in its middle mile and data 
backbone network in order to expand broadband, increase speeds available to customers, and improve the 
network for voice services.121  Overall, Frontier states that the transaction will provide it with an increased 
scale and scope, increased cash flow, improved access to capital, and enhanced purchasing power to fund 
network investments, and that, as a result, it will “increase the geographic reach of its current fiber 
network from 14 percent to 31 percent of its footprint.”122   
34. For several reasons, we conclude that Frontier is more likely to accelerate broadband 
service in the transaction market areas than Verizon would be absent the transaction, and that this 
potential for acceleration represents a tangible public interest benefit.  First, Frontier’s history of 
deploying broadband supports its assertion that it intends to expand broadband services in the transaction 
(Continued from previous page)                                                            
of households have DSL with speeds of 1 Mbps or less, [Begin Confidential Information]  [End Confidential 
Information] percent have DSL with speeds over 1 and up to 5 Mbps, and [Begin Confidential Information]  
[End Confidential Information] percent have DSL with speeds over 5 and up to 15 Mbps.  
116 Response to Information Request at 9-10. 
117 Id. at 9. 
118 Applicant Reply at 8-9 and Frontier Jureller Reply Decl. at para. 15; Response to Information Request at 9. 
119 Public Interest Statement at 7; Applicant Reply at 12-13 and Frontier Lass Reply Decl. at paras. 2-3.  
120 Response to Information Request at 11-12; Frontier Jureller Reply Decl. at para. 14.  In 2011, the Commission 
created CAF to ultimately replace all existing high-cost universal service support mechanisms and to help make 
broadband available to homes, businesses, and community anchor institutions in areas that do not, or would not 
otherwise, have broadband, including in the most remote areas of the nation.  Connect America Fund et al., WC 
Docket No. 10-90, et al., Report and Order and Further Notice of Proposed Rulemaking, 26 FCC Rcd 17663, 17673, 
para. 20 (2011).  CAF Phase II funding is designed to provide ongoing support to areas served by price cap carriers, 
including areas currently lacking broadband-capable infrastructure.  Id. at 17673-74, paras. 23-25.  On June 16, 
2015, the Commission announced that Frontier accepted $283.4 million from CAF to expand broadband to over 1.3 
million rural customers in its existing territory.  Press Release, FCC, Frontier Communications Accepts Over $283 
Million Connect America Fund Offer to Expand and Support Broadband for 1.3 Million Rural Americans (June 16, 
2015), https://www.fcc.gov/document/connect-america-fund-expanding-broadband-13-m-frontier-customers.  
Frontier states that if it is “able to obtain regulatory approvals for the Transaction prior to December 31, 2015, it will 
utilize funding for broadband deployment in the high costs areas within the Transferring Companies’ territories.”  
Response to Information Request at 11.   
121 Response to Information Request at 9-12.  Frontier states that customers that are part of its CAF Phase II build-
out will receive a minimum speed of 10 Mbps.  Id. at 12. 
122 Public Interest Statement at 2; Frontier June 10, 2015 Ex Parte Letter at 2 (citing Frontier Lass Reply Decl.at 
paras. 10-11); Response to Information Request at 2-3. 
 Federal Communications Commission DA 15-987  
 
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areas above Verizon’s existing 73 percent availability rate.123  In particular, Frontier’s 92 percent 
broadband availability rate demonstrates a steady and significant improvement above the approximately 
62 percent availability rate that existed at the time Frontier acquired mostly rural incumbent LEC 
operations in 14 states from Verizon in 2010, and the record demonstrates that Frontier intends to 
accomplish similar results with the proposed transaction.124  In addition, the record indicates that the 
transaction will result in the opportunity for customers to have access to increased speed tiers.  According 
to Applicants, Frontier offers speeds of 20 Mbps or more to 55 percent of the households in its current 
territory, while Verizon currently offers that speed tier to a lower percentage of households in the 
transaction areas in California and Texas.125  Specifically, Applicants state that Verizon FiOS, which 
offers speeds above 20 Mbps, is available to only [Begin Confidential Information]  [End 
Confidential Information] percent of households in the transaction areas in California and [Begin 
Confidential Information]  [End Confidential Information] percent  of households in Texas.126  In 
Florida, the Applicants report that [Begin Confidential Information]  [End Confidential 
Information] percent of households in the transaction area have access to FiOS.127   
35. Frontier has stated that it intends to extend broadband to regions that would not otherwise 
be able to receive wired broadband services from Verizon and that it will deploy fiber and other 
infrastructure that is capable of providing increased speeds and improving service not only for target 
locations but throughout its network.128  To this end, Frontier has committed to deliver, by the end of 
2020, broadband to an additional 750,000 households at speeds of 25 Mbps/2-3Mbps across its entire 
footprint, including in the transaction areas in California, Florida, and Texas.129  Frontier explains that it 
will deliver broadband at this increased speed by committing private investment, leveraging all currently 
available technologies, and deploying new technologies as they become available.130  It further states that 
                                                     
123 Public Interest Statement at 12-13; Frontier Jureller Reply Decl. at paras. 15-16 and Frontier Lass Reply Decl. at 
para. 8 (stating that Frontier’s business plan is to expand access to innovative products, including broadband 
services, in the transaction areas). 
124 Frontier Jureller Reply Decl. at para. 15.  See Verizon/Frontier Order, App. C., 25 FCC Rcd at 6002 and Letter 
from A.J. Burton, Frontier, to Alexis Johns, FCC, WC Docket No. 09-95 (filed July 21, 2015) (describing Frontier’s 
progress in increasing the percentage of housing units within the areas transferred from Verizon to Frontier that have 
broadband capability) (Frontier July 2015 Semi-Annual Reporting Ex Parte Letter).  
125 Response to Information Request at 9. 
126 Id. at 9 and Exh. 1.  The Commission stated in the 2015 Broadband Progress Report that Verizon’s current FiOS 
Internet offerings range from 25 Mbps to 500 Mbps downstream, with most customers now subscribing to the FiOS 
plans that offer download speeds of 50 Mbps or more.  Inquiry Concerning the Deployment of Advanced 
Telecommunications Capability to All Americans in a Reasonable and Timely Fashion, GN Docket No. 14-126, 
Broadband Progress Report and Notice of Inquiry on Immediate Action to Accelerate Deployment, 30 FCC Rcd 
1375, 1383-84, para. 16 (2015). 
127 Response to Information Request at 9 and Exh. 1.  Applicants state that Frontier is acquiring the existing FiOS 
broadband network and operations in the transaction areas and will continue to provide service after completion of 
the transaction.  Frontier states that it has experience with FiOS and currently has FiOS-branded broadband video 
operations in Washington, Oregon, and Indiana.  Public Interest Statement at 22. 
128 Response to Information Request at 10; Applicant Reply at 7 (stating that the transaction will produce public 
interest benefits because “Frontier will continue to invest in the Transferring Companies’ wireline facilities and 
operations,” and “by doing so, it will deliver speed and capacity improvements at reasonable prices to customers in 
each state, including the rural portions of the Transferring Areas.”). 
129 Letter from Daniel McCarthy, President and Chief Executive Officer, Frontier Communications Corporation, to 
The Honorable Tom Wheeler, Chairman, FCC, WC Docket No. 15-44, at 1 (filed Aug. 11, 2015) (Frontier Aug. 11, 
2015 Ex Parte Letter). 
130 Id. at 1-2.  Frontier described specific technologies referred to as VDSL2 (bonded and un-bonded) and ADSL2+ 
(bonded) and also identified a new technology referred to as vectoring.  Id. at 1 and Att. (“Frontier Communications 
(continued …) 
 Federal Communications Commission DA 15-987  
 
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it has spent the last five years building out its network and identifying ways to achieve high speeds over 
copper loops for its rural customers and that new equipment, combined with upgraded backbone 
transport, enables high speeds by supplementing its copper network with its fiber backbone.131   
36. Second, Applicants have acknowledged that Verizon did not have any specific plans to 
expand FiOS or to improve broadband service and speeds in the transaction areas beyond satisfying any 
pre-existing obligations.132  We fully recognize the concern of CWA, the Consumer Advocates, and 
Greenlining that Verizon has not deployed broadband to all customers in the transaction areas.133  We find 
it persuasive that, while Verizon has not demonstrated plans to invest further in the transaction areas, 
Frontier’s business strategy is predicated on “investing in wireline networks and providing advanced 
broadband capabilities and high-quality service.”134  Frontier states that all of its capital and human 
resources are concentrated on wireline services to assure optimal use of its high speed broadband 
infrastructure, and that it intends to focus its business plan on local engagement in the transaction areas in 
order to expand and improve service.135  We find Frontier’s statements to be credible in this respect.  We 
note that, in conjunction with its 2010 transaction, Frontier states that it has met its commitment to 
increase broadband access in the rural areas it acquired from Verizon.  It states that 38 percent of the 
households it acquired lacked any broadband services, and 50 percent of households did not have speeds 
greater than 3 Mbps in 2010.  Now, however, it states that 83 percent of customers across all of its 
markets have speeds of 6 Mbps or greater.136  To specifically demonstrate its prior experience in 
expanding broadband in California, Frontier filed information showing that, when it acquired 12 Verizon 
rural exchanges in California in 2010 serving 17,700 households, broadband had been deployed to about 
4,200 households, or about 24 percent of households in the exchanges.  As of 2015, Frontier states that 
broadband service is available to 14,700 households, or 82 percent of households in the acquired 
exchanges.137   
37. The Commission accepted a broadband commitment from Frontier as a benefit when it 
sought to acquire AT&T’s incumbent LEC operations in Connecticut in 2014.138  The commitment 
(Continued from previous page)                                                            
Broadband Expansion, August 2015”).  The Commission has stated that companies are testing technologies such as 
VDSL2 in order to provide speeds of 10 Gbps over copper.  Ensuring Customer Premises Equipment Backup Power 
for Continuity of Communications Technology Transitions, PS Docket No. 14-174, GN Docket No. 13-5, et al., 
Notice of Proposed Rulemaking, 29 FCC Rcd 14968, 14981-82, para. 22, n.70 (2014). 
131 Frontier Aug. 11, 2015 Ex Parte Letter at 1. 
132 Response to Information Request at 12.  Applicants state that the pre-existing obligations refer only to 
commitments under video franchise agreements to serve customers within Verizon’s existing FiOS footprint along 
with contracts to supply FiOS to customers (such as homeowners’ associations and multi-dwelling units) inside that 
footprint.  Applicants state that, post-closing, the Transferring Companies, as owned and operated by Frontier, will 
continue to be subject to those obligations irrespective of the change in ownership.  Frontier Aug. 25, 2015 Ex Parte 
Letter at 2. 
133 CWA Comments at 2-3, 3-14, Consumer Advocates Comments at 14; Greenlining Petition at 10-11.   
134 Frontier Lass Reply Decl. at para. 4. 
135 Public Interest Statement at 13-14; Response to Information Request at 13. 
136 Frontier Aug. 11, 2015 Ex Parte Letter at 1.  See Verizon/Frontier Order, 25 FCC Rcd at 5992-93, para. 50 and 
App. C; Frontier July 2015 Semi-Annual Reporting Ex Parte Letter, Attach.  Frontier’s broadband expansion plans 
at the time of the 2010 transaction were based on providing access to speeds of at least 3 Mbps and 4 Mbps 
downstream.  Verizon/Frontier Order, 25 FCC Rcd at 5992-93, para. 50. 
137 Letter from William F. Maher, Jr., Counsel to Frontier Communications Corporation, to Marlene H. Dortch, 
Secretary, FCC, WC Docket No. 15-44, at 1-2 (filed July 17, 2015) (Frontier July 17, 2015 Ex Parte Letter); Letter 
from William F. Maher, Jr., Counsel to Frontier Communications Corporation, to Marlene H. Dortch, Secretary, 
FCC, WC Docket No. 15-44, at 1-2 (filed July 28, 2015) (Frontier July 28, 2015 Ex Parte Letter). 
138 AT&T/Frontier Connecticut Order, 29 FCC Rcd at 9213-14, para. 27. 
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focused on expanding IP broadband data speeds of 10 Mbps or greater to more than 100,000 additional 
households and to construct an ultra-high speed middle mile fiber network and make other network 
improvements.139  Frontier now states that, since the transaction closed in October 2014, it has made these 
network improvements in order to expand broadband to 5,070 additional households with access to 
speeds of 10 Mbps or greater, with about 19,000 more households having access to 10 Mbps broadband 
service expected by the end of 2015.140  As the Commission has found in prior transactions, we expect 
that Frontier’s incentive to execute its broadband business plan, coupled with its prior experience 
acquiring incumbent LEC assets, including in rural areas, will accelerate broadband deployment in 
California, Texas, and Florida post-merger.141   
38. Third, the Commission has previously found that the commitment of private investment 
in broadband that Frontier describes in the record, including increasing its fiber network from 14 percent 
to about 31 percent of its footprint post-merger, and the competition this investment will promote among 
providers, is an important benefit in our transaction review.142  Thus, we believe, based on the facts 
presented, that the proposed transaction will promote broadband availability in the transaction areas.   
39. Synergies.  Applicants contend that the proposed transaction will also benefit the public 
interest by resulting in substantial cost savings.  As stated above, Frontier anticipates achieving cost 
savings of approximately $700 million annually within three years.143  CWA commented that Frontier’s 
claimed benefits in the Application were vague and not based on sufficient information.144  Consumer 
Advocates further questioned whether the savings would benefit consumers.145  The Commission 
requested additional information from the Applicants, and they provided further details about Frontier’s 
anticipated cost savings.146  In particular, Applicants state that “ . . . $525 million of the projected savings 
will come from elimination of Verizon corporate cost allocations for various shared services, line network 
operations, engineering, and accounting and administrative functions.”147  Frontier states that another 
$175 million in savings will be based on managing other allocations and costs.148  In response to our 
request for additional information, Frontier provided a more detailed description of its plans to utilize 
available funds to improve the local network in the transferring service areas and to improve the 
availability of broadband services,149 stating that “the network will come first in all of its markets, both 
                                                     
139 Id.    
140 Frontier July 17, 2015 Ex Parte Letter at 4; Frontier July 28, 2015 Ex Parte Letter at 2. 
141 Verizon/Frontier Order, 25 FCC Rcd at 5994, para. 56; AT&T/Frontier Connecticut Order, 29 FCC Rcd at 9210-
11, para. 21.  California Emerging Technology Fund (CETF) submitted late-filed comments raising concerns 
regarding broadband availability and pricing. Comments of California Emerging Technology Fund, WC Docket No. 
15-44 (filed July 29, 2015) (CETF Comments).  CETF did not include a motion to accept its filing.  See 47 C.F.R. 
§ 1.46(a).  Applicants filed a response arguing that the untimeliness of CETF’s filing is unjustified and raises non 
transaction-specific issues.  Letter from William F. Maher, Jr., Counsel to Frontier Communications Corporation, to 
Marlene H. Dortch, Secretary, FCC, WC Docket No. 15-44, at 1-2 (filed Aug. 6, 2015) (Frontier Aug. 6, 2015 Ex 
Parte Letter).  In any event, we note that the issues CETF discusses were previously raised in the record by other 
parties.   
142 Verizon/Frontier Order, 25 FCC Rcd at 5993-94, para. 53. 
143 Public Interest Statement at 17. 
144 CWA Comments at 2, 11. 
145 Consumer Advocates Comments at 13-14. 
146 See, e.g., Frontier June 10, 2015 Ex Parte Letter at 2; Supplemental Information Request Letter at 2.  
147 Frontier June 10, 2015 Ex Parte Letter at 2; Frontier Jureller Reply Decl. at 5.  See Applicant Reply at 13-14. 
148 Response to Information Request at 13.  
149 Id. 
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rural and urban . . . [and that] the Transaction provides significant flexibility for continued investment in 
the network and to operate the business.”150 
40. As evidence of the likelihood of achieving its projected savings in the proposed 
transaction, Frontier states that it successfully achieved its projected synergies in past transactions.151  
Frontier states that it exceeded the $500 million operating savings planned in its 2010 transaction with 
Verizon.152  Frontier states that, with regard to its 2014 purchase of AT&T’s operations in Connecticut, 
Frontier’s annualized cost savings have already totaled $165 million, and Frontier is on track to meet its 
estimated total operating expense savings of $200 million.153  Frontier states that these savings improved 
the finances and cash flow of the company and permitted it to “engage in a balanced, flexible, approach of 
investing in its network infrastructure, including paying for all commitments pursuant to the prior 
transactions. . . .”154  While we are unable to calculate a specific savings amount, we find that, based on 
the record before us, it is likely that Frontier will achieve its estimated cost savings, and, given its 
business model and investment plans described above,155 it is likely that at least some of those savings 
will further enable it to increase its infrastructure investment, including infrastructure supporting 
broadband services.156 
IV. CONCLUSION 
41. As discussed above, based on our careful review of the record, we find that the 
transaction is unlikely to result in any significant public interest harms.  We also find that the proposed 
transaction is likely to result in public interest benefits of increased investment in local networks facilities 
and broadband services in the transferring service territories and some cost savings.  Accordingly, we 
conclude that granting the Applications serves the public interest.   
V. ORDERING CLAUSES 
42. Accordingly, having reviewed the applications and the record in this matter, IT IS 
ORDERED that, pursuant to sections 4(i)-(j), 5(c), 214, 309, and 310(d) of the Communications Act of 
1934, as amended, 47 U.S.C. §§ 154(i)-(j), 155(c), 214, 310(d) and sections 0.51, 0.91, 0.131, 0.261, 
0.291, and 0.331 of the Commission’s Rules, 47 C.F.R. §§ 0.51, 0.91, 0.131, 0.261, 0.291, and 0.331, the 
Applications to assign and transfer control of domestic and international section 214 authorizations and 
section 310(d) wireless licenses ARE GRANTED. 
43. IT IS FURTHER ORDERED, pursuant to Section 4(i) of the Communications Act of 
1934, as amended, 47 U.S.C. § 154(i), and section 1.45 of the Commission’s Rules, 47 C.F.R. § 1.45, that 
the Florida Power & Light Motion to Accept Late-Filed Petition, filed on April 17, 2015, IS GRANTED. 
44. IT IS FURTHER ORDERED that, pursuant to sections 63.10, 63.13, and 1.939 of the 
Commission’s Rules, 47 C.F.R. §§ 63.10, 63.13, 1.939, the petitions of Greenlining and Florida Power & 
Light to deny the Applications ARE DENIED as discussed above. 
                                                     
150 Id. at 14. 
151 Public Interest Statement at 18. 
152 Id.  
153 Id.; Frontier July 17, 2015 Ex Parte Letter at 4. 
154 Frontier July 17, 2015 Ex Parte Letter at 4. 
155 See supra paras. 31-39. 
156 See Verizon/Frontier Order, 25 FCC Rcd at 5995, para. 57 (finding that transaction synergies were a potential 
transaction benefit, but relying on other merger benefits to support a determination that the transaction was in the 
public interest).  
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45. IT IS FURTHER ORDERED, pursuant to section 1.102(b)(1) of the Commission’s rules, 
47 C.F.R. § 1.102(b)(1), that this Memorandum Opinion and Order IS EFFECTIVE upon release.  
Petitions for reconsideration under section 1.106 of the Commission’s Rules, 47 C.F.R. § 1.106, or 
applications for review under section 1.115 of the Commission’s rules, 47 C.F.R. § 1.115, may be filed 
within thirty days of the date of public notice of this Memorandum Opinion and Order. 
 
 FEDERAL COMMUNICATIONS COMMISSION 
 
 
 
 
 Matthew S. DelNero 
 Chief, Wireline Competition Bureau 
 
 
 
  
 Mindel De La Torre 
 Chief, International Bureau 
 
 
 
 Roger Sherman 
 Chief, Wireless Telecommunications Bureau 
 
 Federal Communications Commission DA 15-987  
 
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APPENDIX 
 
SECTION 214 AUTHORIZATIONS 
 
A. International 
 
File Number Authorization Holder Authorization Number 
 
ITC-ASG-20150224-00052 
ITC-T/C-20150224-00055 
 
ITC-T/C-20150224-00056 
 
ITC-T/C-20150224-00057 
  
Verizon Long Distance LLC 
GTE Southwest Incorporated dba 
Verizon Southwest 
Verizon Florida LLC 
 
Verizon California, Inc. 
ITC-214-20001121-00680 
ITC-214-20080219-00077 
 
ITC-214-20080219-00064 
 
ITC-214-20080219-00063 
 
B. Domestic 
 
The application for approval to transfer control of domestic 214 authorizations is granted. 
 
  
SECTION 310(d) APPLICATIONS 
 
File Number 
 
Licensee 
 
Lead Call Sign 
 
0006674665 GTE Southwest Incorporated dba Verizon Southwest KG4012 
0006674669 Verizon Florida Inc. KIY21 
0006674674 Verizon California Inc. KF5881