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WASHINGTON. DC 20510
January 18,2012
The Honorable Julius Genachowski
Chainnan
Federal Communications Commission
445 12
111
Street. SW
Washington, D.C. 20554
Dear Chairman Oenachowski.
As reliance on high-speed Internet and mobile communication continues to grow, it is important
to recognize that many Americans still rely on their traditionallandline phone to engage in
commerce, communicate with friends and family, and call for emergency assistance. Nearly two
thirds ofAmerican houscholds have landline phoncs, and 62 percent ofAmericans say the
serviee is a necessity. Unfortunately, this service has become less reliable in certain rural areas
due to a call origination, routing, and termination problem that is preventing the delivery of a
growing number ofcalls to customers ofrural local exchange carriers.
As you know. representatives for rural carriers have reported a staggering 2,000 percent increase
in complaints between April 2010 and March 2011 from consumers who have experienced calls
that fail to complete, are delayed, have poor voice quality, lack correct caller ID information, or
where the originating carrier simply refuses to place calls to certain rural areas. This problem.
commonly referred to as "call termination," "dropped calls." or "call completion," is widespread
and has been reported by local exchange companies in 36 states.
The failure to complete calls is having a negative effect on local businesses and people
throughout rural America and also presents a serious safety concern for affected consumers.
Small business owners who are affected by this problem are rightfully frustrated and demand a
solution, noting that in this challenging economic climate, businesses rcly on reliable telephone
service and cannot afford to lose a business opportunity because ofa dropped call. Additionally,
incomplete calls raise a significant public safety concern that could yield devastating outcomes if
this problem is not effectively and promptly addressed.
Despite efforts by rural local exchange companies, state regulatory commissions, and
telecommunications trade associations to identify the cause ofthis problem, there remain many
unanswered questions. We appreciate the Commission's creation ofthe Rural Call Completion
Task Force and the workshop that was conducted with key stakeholders on October 18, 2011 to
examine the extent ofand reasons for the call completion problem. We also hope that the
industry can continue to work with the Commission to examine the technical problems and help
develop meaningful and effective solutions. We remain concerned, however, that this problem
will continue to persist and negatively affect rural consumers without continued action and
oversight by your agency.
We respectfully request that you update us about the Commission's efforts to identify the cause
ofthis problem. Should your investigation reveal that responsible parties are engaging in
activities that violate the Communications Act or a Commission rule or order, we believe it is
critical that the Commission takes the necessary actions to protect consumers and ensure that the
widespread and frequent occurrence ofundelivered caUs to rural areas is addressed. We
appreciate your attention to our concerns regarding this problem and look forward to your
response.
Sincerely,
cc: Commissioner McDowell
Commissioner Clyburn