JOSEPH J. STARSICK, JR. Associate General Counsel - Southeast Region d Communications 1500 MacCorkle Ave., S.E. Charleston, West Virginia 25396 (304)344-7644 Joseph. [email protected]

February 3,2012

Via Hand Delivery

Sandra S. Squire Executive Secretary Public Service Commission 201 Brooks Street Charleston, West Virginia 25323

Re: 11-1781-T-T

Dear Ms. Squire:

Please find enclosed for filing in the original plus 12 copies of the Responses Of Inc. To First Set Of Interrogatories, Data Request Or Requests For Information By The Staff Of The Public Service Commission Of West Virginia For Frontier West Virginia Inc. in the above-referenced matter.

Thank you for your attention to this matter.

Sincerely,

(State Bar No. 3576)

JJSjr/sc Enclosure cc: Kathy L. Buckley, Executive Director Chris Howard, Esq. .

PUBLIC SERVICE COMMISSION OF WEST VIRGINIA CHARLESTON

CASE NO. 11-1781-T-T

FRONTIER WEST VIRGINIA INC. Tariff Filing for Revision of Current Tariff

RESPONSES OF FRONTIER WEST VIRGINIA INC. TO FIRST SET OF INTERROGATORIES, DATA REQUEST OR REQUESTS FOR INFORMATION BY THE STAFF OF THE PUBLIC SERVICE COMMISSION OF WEST VIRGINIA

Frontier West Virginia Inc. (“Frontier”) hereby filly and completely answers

Staffs First Set of Interrogatories, Data Request or Requests for Information by the Staff

of the Public Service Commission of West Virginia (“Staffs First Discovery Requests”)

pursuant to the Commission’s Rules of Practice and Procedure, C.S.R. 150-1-1, et seq.

By hereby hlly and completely answering the Staffs First Discovery Requests, Frontier

reserves all objections, and waives none, including without limitation any objection with

respect to any future requests, even if related to a Request answered below.

1 STATE OF WEST VIRGINIA PUBLIC SERVICE COMMISSION STAFF’S FIRST DISCOVERY REQUESTS OF FRONTIER WEST VIRGINIA INC. PROPOUNDED JANUARY 13,2012 CASE NO. 11-1781-T-T

(1) Has Frontier-WV provided any notice to current and prospective customers affected by this proposed tariff change? If yes, please explain how such notice was provided and when.

Answer:

Yes.

Attached as Exhibit 1-lA is the notice to all Interexchange (“IXC”) Carriers, Competitive Local Exchange Carriers (“CLECs”) and Wireless Carriers, dated December 20, 201 1.

Attached as Exhibit 1-1B is the Public Notice of Tariff Filing That May Affect Rates, sent on January 20, 201 1for publication.

2 STATE OF WEST VIRGINIA PUBLIC SERVICE COMMISSION STAFF’S FIRST DISCOVERY REQUESTS OF FRONTIER WEST VIRGINIA INC. PROPOUNDED JANUARY 13,2012 CASE NO. 1 1- 178 1-T-T

(2) Proposed tariff Section 2.3.12. a methodology for calculating the “PVU factor”:

(a) Why is the “Relevant VoIP Traffic” minutes in this methodology limited to terminating VoIP-PSTN access minutes?

Answer:

The FCC was clear in its Order that it was not requiring reductions in originating access rates. The FCC stated that it was “limiting reform to terminating access charges at this time”, ’ and noted its intent to “fbrther evaluate” other charges such as originating access at a later date. The FCC explicitly noted that it could not take action on originating access because there was an insufficient record to do so. Accordingly, in the FNPRM, the FCC “seek[s] comment on that final transition for all originating access charge~,”~ which would necessarily include the access charges associated with calls that originate on the PSTN and terminate in VoIP.

We believe it is clear that the FCC intended to preserve the status quo for originating access rates for calls originating on the PSTN while it develops a record on appropriate transition and recovery mechanisms for these charges in the fbrther rulemaking. The parts of the Order capping and continuing intrastate access rates for the interim do not note any exception for traffic originated on the PSTN and terminated via VoIP.4 Moreover, the only portion of the Order’s VoIP-PSTN discussion that addresses originating access rates with any specificity itself acknowledges that originating access rates are “subject to the phase-down and elimination of those charges pursuant to a transition to be specified in response to the FNPRM’,’- in other words, there is no intent to flash-cut these rates to interstate levels in the present Order. The Order does not

’ Report & Order and FWPRMat 7 739.

* Id. “W]e address those elements in the FNPRM.” (that is, a Future Notice of Proposed Rulemaking).

Id. at 7 1298 (emphasis added).

4 Id. at 7 818. ‘‘[w]e take immediate action to cap all interstate originating access charges and intrastate originating access charges for price cap carriers. Although we do not establish the transitionfor rate reductions to bill-and-keep in this Order, we seek comment in the FNPRA4 on the appropriate transition and recovery mechanism for ultimately phasing down originating access charges. . . A cap on interstate originating access represents afirst step as part of our measured transition toward comprehensive reform. . . .” (Emphasis added.).

Id. at 7 961, n. 1976.

3 STATE OF WEST VIRGINIA PUBLIC SERVICE COMMISSION STAFF’S FIRST DISCOVERY REQUESTS OF FRONTIER WEST VIRGINIA INC. PROPOUNDED JANUARY 13,2012 CASE NO. 11-1781-T-T

include any revenue recovery available for these lost revenues, clearly something the FCC would have incorporated had they intended originating rates be reduced.

Requiring interstate rates for intrastate originating switched access on PSTN originating- VoIP terminating traffic would create a new arbitrage opportunities out of an Order that was intended to eliminate such gaming of the system. There has never been any dispute about originating access charges that terminate on VoIP. Frontier knows the jurisdiction of the traffic that originates on its network, but cannot determine how a call terminates - on the PSTN or via VoIP. As a result, Frontier would be forced to rely on another carrier’s specified percentage of VoIP-terminated traffic in a situation where the carrier has the incentive to inflate its actual percentage of VoIP traffic. A disparity in originating rates for intrastate traffic terminating on the PSTN versus on an IP network could incent an interexchange to specifj a larger percentage of VoIP-terminated traffic in an attempt to minimize their costs. Since the FCC does not set a timefi-ame for addressing originating traffic, as it does for terminating traffic, the arbitrage opportunity would continue in perpetuity until hrther FCC action.

(b) Will Frontier-WV allow the customer’s “PVU factor” to be based on the number of the customer’s retail VoIP subscriptions in West Virginia?

Answer:

Frontier’s carrier customer will be able to provide their Percentage VoIP Usage (“PVU”) to Frontier, and they can utilize the number of retail VoIP subscriptions as a percentage of their overall retail customers in establishing the PVU.

4 STATE OF WEST VIRGINIA PUBLIC SERVICE COMMISSION STAFF’S FIRST DISCOVERY REQUESTS OF FRONTIER WEST VIRGINIA INC. PROPOUNDED JANUARY 13,2012 CASE NO. 11-1781-T-T

(3) Is the Company’s billing system currently capable of implementing the “PVU factor” methodology proposed in this tariff filing? If not, what is the expected date of such implementation?

Answer:

Frontier’s billing system is capable of implementing the PVU provided by the customer, similar to how it implements PIU (Percent Interstate Usage) for switched access currently.

5 STATE OF WEST VIRGINIA PUBLIC SERVICE COMMISSION STAFF’S FIRST DISCOVERY REQUESTS OF FRONTIER WEST VIRGINIA INC. PROPOUNDED JANUARY 13,2012 CASE NO. 11-1781-T-T

(4) In regards to proposed tariff section 2.3.12(B) Rating of VoIP-PSTN Traffic:

(a) Please provide the current specific “rates equal to the Company’s applicable tariffed interstate switched access rates” to be applied to the “Relevant VoIP-PSTN Traffic” and the specific FCC tariff citation for each such applicable rate.

Answer:

Please see attached Exhibit 1-4.

(b) For VoIP-PSTN Traffic that is not calculated to be “Relevant VoIP-PSTN Traffic” by the proposed “PVU factor” methodology, please provide the applicable rate(s) that will be applied to such Traffic.

Answer:

“Relevant VoIP-PSTN Traffic” is simply that VoIP-PSTN traffic which is included in terminating intrastate access minutes. It is identified by the PVU. Other VoIP-PSTN Traffic is not subject to the filed tariff language and is to be billed at the rates currently in place. To the extent such traffic is included in terminating interstate access minutes, it is billed at terminating interstate access rates. To the extent such traffic is included in originating access minutes, it is billed the originating interstate or intrastate access rates according to what jurisdiction the traffic is. To the extent such traffic is not included in access minutes, it would be governed by an interconnection agreement between Frontier and the carrier exchanging such traffic with Frontier.

6 STATE OF WEST VIRGINIA PUBLIC SERVICE COMMISSION STAFF’S FIRST DISCOVERY REQUESTS OF FRONTIER WEST VIRGINIA INC. PROPOUNDED JANUARY 13,2012 CASE NO. 11-1781-T-T

(5) Is the Company’s current billing system capable of determining actual VoIP traffic ffom non-VoIP traffic? If no, does the Company plan to develop this capability? When?

Answer:

Frontier’s system cannot determine actual VoIP originated traffic that terminates on its network. It does not currently have plans to develop this capability, and does not believe that hnctionality exists due to the lack of requirements to identify traffic as such in the call detail or call signaling information that is passed between carriers.

7 STATE OF WEST VIRGINIA PUBLIC SERVICE COMMISSION STAFF’S FIRST DISCOVERY REQUESTS OF FRONTIER WEST VIRGINIA INC. PROPOUNDED JANUARY 13,2012 CASENO. 11-1781-T-T

(6) Please provide a copy ofthe Company’s most recent FCC Form 477.

Answer:

Please see attached Exhibit 1-6, which is the most recent FCC Form 477 for West Virginia. Please note that not all of the zip codes listed in Part V are viewable on the attached paper copy, but Frontier will provide Exhibit 1-6 on electronic media upon request.

8 EXHIBIT 1-1A

C/Carrier (ftstomer &lietin

Date of Bulletin: December 20, 201 1 Notice #: CCBFTROOl92 Audience: IXC Carriers, CLECs, Wireless Subject : FCC Tariff Filings VolP PSTN Compliance Date Effective: On or after January 1, 201 2

Frontier Communications provides notice of tariff filings complying with the billing of VolP-PSTN Traffic requirements in accordance with the FCC Order. Piease see below for details by State.

AZ Company, Inc. 12112111 2/15/12 AZ Citizens Telecommunications Company of the White Mountains, Inc. 12112111 2/15/12 AZ Frontier Communications of the Southwest, Inc. 12112111 2/15/12 ~ AZ Navajo Communications Company, Inc. 12112/11 2/15/12 cA Citizens Telecommunications Company of California Inc. 12112111 111112 CA Frontier Communications of the Southwest Inc. 12l12l11 111112 - CA Frontier Communications West Coast Inc. 12/12/11 111112 FL Frontier Communications of the South Inc. 12/29/11 111112 GA Frontier Communications of Georgia 12l19l11 111112 IA Frontier Communications of Iowa 12/9/11 1/12/12 I ID I Citizens Telecommunications Company of Idaho I 12115- ID Frontier Communications Northwest Inc. 12115111 111112 IL Citizens Telecommunications Company of IL 12l13l11 1130112 Frontier Communications Midland - 1 211 3 I 11 1I301 1 2 IL . Frontier Communications - Schuyler Concurs in Midland Frontier Communication of Illinois Concurs in Midland Frontier Communications of Lakeside concurs in Midland . Frontier Communications of Mt. Pulaski Concurs in Midland . Frontier Communications of Orion Concurs in Midland I II I Frontier Communications of Depue I 12/14/11 1 1/30/12 , Inc 12/14l11 1/30/12 IL . Frontier Communications of the Carolinas Concurs in Frontier North, Inc. IN Frontier North, Inc. 12/29/11 1/1/12 Frontier Communications of Indiana LLC 12/29/11 1/1/12 IN e Frontier Communications of Thorntown LLC concurs MI Frontier Communications of MI 12/12/11 1/30/12 MI Frontier North, Inc 12lI2l11 1130112 MN Citizens Communications of Minnesota (Lakes) 12/9/11 1/12/12

1 MN 1 Citizens Communications of Minnesota (South I 12/9M1 I 1/12/12

~ MN Frontier Communications of Minnesota 12/9/11 1/12/12 MT Citizens Telecommunications Company of Montana 12/13/11 1/14/12 NB Citizens Telecommunications Company of Nebraka 12/9/11 1/12/12 ~ ~ NC Frontier Communications of of the Carolinas Inc 12/16/11 1/1/12 NM Navajo Communications Company, Inc. 12/13/11 1/14/12 NV Citizens Telecommunications Company of Nevada 12/12/11 1/30/12 I NV I Frontier Communications of the Southwest Inc. I 12/12l11 I 1/30/12 I NV Frontier Communications of the Northwest Inc. 12/12/11 Frontier Communications of New York 12/8/11 1/7/12 NY 0 Frontier Communications of Ausable Valley Concurs in FC of New York 0 Frontier Communications of Seneca Gorham Concurs in FC of New York Frontier Communications of Sylvan Lake Concurs in FC of New York ..NY. Frontier Telephone of Rochester, Inc 12/8/11 11/7/12 I Citizens Telecommunications Company of New York, Inc., DBA Frontier 12/8/11 1/7/12 . NY Communications of New York OH Frontier North, Inc. 1/1/12

OR Citizens Communications Company of Oregon 12/9/11 1/12/12 I OR I Frontier Communications Northwest, Inc. PA Frontier Communications of Commonwealth Telephone 12t15111 1/1/12 pA Frontier Communications of Pennsylvania LLC 12/15/11 1/1/12 sc Frontier Communications of of the Carolinas Inc. 12/16Ill 1/1112 TN Citizens Telecommunications Company of Tennessee LLC 12/21/11 1/20/12 U~ Citizens Telecommunications Company of Utah 12/13/11 1/14/12 VA Frontier Communications of Virginia, Inc. 12/21/11 1/20/12 WA Frontier Communications of the Northwest Inc. 12~12lll 1/1/12 wI Frontier Communications - St Croix 12/9/11 1/12/12 wI Frontier Communications of Mondovi 12/9/11 1/12/12 wI Frontier Communications of Viroqua 12/9/11 1/12/12 wI Frontier Communications of Wisconsin 12/9/11 1/12/12 wI Frontier North, Inc 12/9/11 1/12/12 Wv Citizens Telecommunications Company of West Virginia 12/15/11 1/1/12 Wv Frontier West Virginia Inc. 12l15/11 1/1/12

0 201 1 Frontier Corporation -All rights reserved

This e.inail is the property of Frontier Corporation and/or ilc wievant affiiiatss and may contain confider:t;ai arid pi-iviirpged rnaic:t-:ai fol- the deuie of the iiiti?ndea recipient(r). Any ~-evietw,i.ise. distribtimn or disclosiire !,y oii?ers is strictiy proh!bicetl. if yo~a1.e !lot ei?e recipient (or authorized to rxeive for the rec!p!ent), please de!cte ali copies of the message. To be re~.iio\iedfrom t!ie distiihi.r:ioi; list, !:(ease seiect the delete action and provide jour contact iiiformatioii to Frostiw a%hm?:/i~ww.frontier,co~'~~holesale~notlf~cat~onuequest.~~~~ EXHIBIT 1-1B

PUBLIC NOTICE OF TARIFF FILING THAT MAY AFFECT RATES

NOTICE is hereby given that Frontier West Virginia Inc. and Citizens Telecommunications Company of West Virginia d/b/a Frontier Communications of West Virginia have filed tariffs in accordance with the Public Service Law and the Federal Communications Commission’s (FCC’s) Report and Order and Further Notice of Proposed Rulemaking, In the Matter of Connect America Fund, WC Docket No. 10-90 et al., FCC 11-1 61 (released Nov. 18,2011 and effective December 29,201 1) consisting of the following pages:

Frontier West Virginia Inc. Access Service Tariff - PSC WV No. 21 7 Contents - 1st Revised Page 2 Section 2 - 1st Revised Page 15 Section 2 - Original Pages 15a, 15b and 15c

Citizens Telecommunications Company of West Virginia d/b/a Frontier Communications of West Virginia Access Services Tariff - PSC WV No. 3 Check Sheet - 6th Revised Page 1 Contents - 1st Revised Page 7 Section 2 - 1st Revised Page 39 Section 2 - Original Pages 39.1 and 39.2

The purpose of these filings is to introduce a tariff section on Identification and Rating of Voice-over-Internet-Protocol- Public-Switched Telephone Network (VoIP- PSTN) Traffic as required by the FCC. The tariffs will affect VoIP traffic delivered by other carriers to Frontier for purposes of termination on Frontier’s network.

Anyone desiring to protest or intervene should file a written protest or notice of intervention prior to thirty (30) days from the date of this notice, unless otherwise modified by Commission order. Failure to timely protest or intervene can affect your rights to protest any rate increases and to participate in future proceedings. All protests or requests to intervene should briefly state the reason for the protest or intervention, Requests to intervene must comply with the Commission’s rule on intervention set forth in the Commission’s Rules of Practice and Procedure. All protests and interventions should be addressed to Executive Secretary, Public Service Commission of West Virginia, P. 0. Box 812, Charleston, West Virginia 25323.

A complete copy of both proposed tariffs, as well as a representative of the Company to provide any information requested concerning them, is available to all customers, prospective customers, or their agents at the following office of the Company:

1500 MacCorMe Avenue, SE, Charleston, WV

1 A copy of both proposed tariff filings is also available for public inspection at the office of the Executive Secretary of the PUBLIC SERVICE COMMISSION at 201 Brooks Street, Charleston, West Virginia.

2 Frontier Interstate Switched Access Rates (Terminating Usage) as of December, 201 1

CTC West Virginia CTC West Virginia Switched Access Rate Element Bluefieid & St. Marys Study Areas Mountain States Study Area Frontier West Virginia

Local Switching 0.00260000 FCC No. 1 Section 20.1.4 0.00364690 FCC No. 1 Section 20.2.4 0.00227300 FCC No. 4 Section 6.9.2 Shared Trunk Port 0.001 09690 FCC No. 1 Section 20.1.4 0.00104073 FCC No. 1 Section 20.2.4 0.00158100 FCC No. 4 Section 6.9.2

Tandem Transport Facility per minute-mile 0.00005000 FCC No. 1 Section 20.1.4 0.00005000 FCC No. 1 Section 20.2.4 0.00000200 FCC No. 4 Section 6.9.1 Tandem Transport Termination 0.00100000 FCC No. 1 Section 20.1.4 0.00010000 FCC No. 1 Section 20.2.4 0.00000000 FCC No. 4 Section 6.9.1 Tandem Switching 0.00005000 FCC No. 1 Section 20.1.4 0.00017103 FCC No. 1 Section 20.2.4 0.00168400 FCC No. 4 Section 6.9.1

Shared Multiplexing, per Tandem MOU 0.00005000 FCC No. 1 Section 20.1.4 0.00000000 FCC No. 1 Section 20.2.4 0.00000000 FCC No. 4 Section 6.9.1 Shared Multiplexing, per End Office MOU 0.00005000 FCC No. 1 Section 20.1.4 0.00010000 FCC No. 1 Section 20.2.4 #N/A

m X I EXHIBIT Form 477 Submission for FRN: 3576352, Company: Frontier Communications Cor 1-6 ILEC, Data as of Jun 30,2011 Status: On Aug 31,2011, the status for this Form 477 submission was changed to Original - Submitted. i Data as of Jun 30,2011 i 1. FRN 3576352 1 2. Company i I 3. Tvoe of ODerations I G ILEC r Non-ILEC

filers. !i i 5. State wv 1 6. Contact person (person who prepared the submitted data) /Cassandra Guinness

1 10. Official (corporate officer, managing partner, or sole i proprietor) whose signature certifies that he/she has examined I the information contained in this Form 477 and that, to the best /! of hisher knowledge, information and belief, all statements of fact contained in this Form 477 are true and correct. For 1 purposes of this Form 477, the entry of the official's name on I this line shall constitute that official's electronic signature to this certification. Persons making willful false statements in a Ii Form 477 can be punished by fine or imprisonment under the Communications Act, 47 U.S.C. 220(e).

11. Certifying official telephone number and email address I

part 1.A:Broadband - Asymmetric xDSL __-_1_1.1-_1______._..---1___._11_.1-__..1.____.._1_._._._____-II I /In Part I.A, report connections (wired "lines") to end users that you (including affiliates) equipped to enable the end user to /receive information from andor send information to the Internet at information transfer rates exceeding 200 kbps in at least lone direction. Report only in-service connections. The end user's Internet access service may be provided by you (including iaffiliates) or by an unaffiliated entity. For purposes of Part LA, Internet Service Providers (ISPs) are not end users. /Categorize the connection based on the technology employed by the part of the connection that terminates at the end user /location. (Do not report anywhere in Form 477 any high-capacity connections between two locations of the same end user /customer, ISP or communications carrier.) mhtml:file://Z:\2011 Activities\l 1-178 1& 1782-T-T VOIP Access Charges\Discovery\Staff ... 2/3/2012 - -.I...-.._ __ _--- - -.^I....I-. ~ ~ .-...-I" ll_l_-----.l_.l- -- _I_ __ .I__l_-l______...---. ~ l_.__.-l_l_. ~ l.-.l._ -~ -. . .---. (1) (2) (3) (4) Total connections to end users that you (including affiliates) Percentage of (1) Percentage of (1) that Percentage of (1) that equipped as broadband over your that you (including are billed (or connect to residential own local loop facilities or the affiliates) equipped incorporated in a Percentage of end users and have equivalent, or over UNE loops or over your own local service billed) to end (1) that connect information transfer other facilities you obtained loop facilities or the users by you, or your to residential end rates exceeding 200 from an unaffiliated entity. Do equivalent. (Enter 0 if affiliates or agents. users. (Enter 0 if kbps in both directions not convert lines into a voice- the true value is 0 (Enter 0 if the true the true value is 0 (Enter 0 if the true grade-equivalent measure. percent .) value is 0 percent.) valu nt.) fii [m ~ __ __ ..

ireak down the total connections reported in (1) to show the non-zero number in each of the following speed tiers. If the umber of connections in a particular speed tier is zero, leave that data cell blank.

:onnections reported in EACH data cell below must equal the sum of Asymmetric xDSL connections reported in Part VI by :ensus Tract, for that downloadupload combination, and the sum of ALL data cells below must equal the total connections :ported in (1).

x_ __^I_-II l-l_- --^-I---_.I- I- Download information transfer rate to the end user (8 categories): j Jpload (6) (7) (8) (9) (10) (1 1) (12) (13) nformation ransfer Greater Greater than Greater than Greater than Greater than Greater than Greater than *atefrom than 200 or equal to or equal to or equal to 3 or equal to 6 or equal to or equal to Greater he end kbps and 768 kbps 1.5 mbps mbps and mbps and 10 mbps and 25 mbps and than or iser (9 less than and less than and less than less than 6 less than 10 less than 25 less than 100 equal to :ategories): 768 kbps 1.5 mbps 3 mbps mbps mbps mbps mbps 100mbps Less than or :qual to 200 I--"- 7-7 7 1- 7 kbps Sreater than 200 kbps and less 1- 19808 7]13159 than 768 77 7 kbps Greater than or equal to 768 kbps and less I-l------r~-Irrr than 1.5 mbps Greater than or equal to 1.5mbps i------1-rrr and less than 3 mbps Greater than or equal to 3 mbps and I less than 6 mbps Greater than or equal to 6 mbps and less than 10 mbps

Greater than mhtinl:file://Z:\2011 Activitiedl 1-178 1& 1782-T-T VOIP Access Charges\Discovery\Staff ... 2/3/2012 or equal to 10 mbps and less than 25 mbps Greater than or equal to 25 rnbps and [-' less than 100 mbps Greater than or equal to 1- 7 100 mbps

This is the end of PART LA for Asymmetric xDSL. If you are an ILEC you MUST ALSO complete Part 1.B for xDSL

(asymmetricor ?xm!egj!)L-. ._...... ___ - . . - ......

distribution facilities. Providers of xDSL connections should base responses on the I ~'s.Oo0 service area of the affiliated ILECs. I .-.._ . -.

..__C..-______I

1i Voice-grade communications carriers ~ unaffiliated -- -

j equivalent lines under resale arrangements ~ communications carriers ri%neG& provided i and voice-grade including, among others, under any UNE loop 1 to unaffiliated 1 equivalent :ommercial agreements that 1 arrangement where you communications jwireless channels replaced UNE-P and resold did not also provide UNE carriers as WE-P. jin service to your end user i exchange, Centrex, and 1 ! (Do not convert UNEs to 1 UNEs to voice-grade _.I__.---. - ... - 1- .-%!to-~er!-__J channelized special-- access 1 1 voice-grade equivalents.)J equivalents. (a) Total number. See instructions on what to [r include. (b) Percentage of (a) that are residential lines (c) Percentage of (a) for which you (including affiliates) are mhtml:file://Z:\2011 Activities\l 1 1781 & 1782-T-T VOIP Access Charges\Discovery\Staff ... 2/3/2012 the presubscribed interstate long distance carrier (d) Percentage of (a) used for residential service AND for which you (including affiliates) are the presubscribed interstate long distance carrier (e) Percentage of (a) ?rovided over your own (including affiliates) local loop facilities or the equivalent (0Percentage of (a) provided over UNE loops obtained from an unaffiliated canier without also obtaining that carrier's UNE switching for that line (g) Percentage of (a) provided over UNE- Platform (but treat commercial agreements that replaced UNE-P as "provided by reselling," below) (h) Percentage of (a) provided by reselling unaffiliated-carrier services including, among others, commercial agreements that replaced UNE-P p%E---- and resold services such as local exchange, Centrex, and channelized special access (i) Percentage of (a) provided over optical fiber at the end user 1- premises (j)Percentage of (a) provided over coaxial cable at the end user 1- premises (k) Percentage of (a) provided over fixed wireless at the end user premises

?-PartV: Zip Code Information -- Local Voice Telephone Service and Interconnected VoIP------.-_-I i I I I /If you reported local exchange telephone lines in service to your end user customers, in Part 1I.A (t), jor VoIP subscriptions that end users purchased fi-om you, in Part 1I.B (1) or (2),you must list the 5-

~

idigit ZIP Codes in the state in which you had end user customers. Do not include any ZP Codes in ~ mhtml:file://Z:\2011 Activities\l 1-178 1& 1782-T-T VOIP Access Charges\Discovery\Staff ... 2/3/2012 ” ruiiii L) I I 3uDIriission 1or rKIy: 33 IO~~L,Lompany: rrontier Communications Corporati ... Page 5 of5

which you offered your local exchange telephone or VoIP service but had no end user custcjiimg-and /do not include any out-of-state ZIP Codes. ! :Type all five digit ZIP codes in the following text box, separated by either commas, spaces, or carriag Ps:

0,24853,24857,24860,24861,24867,24868,24870,24871,24873,24874,24878,24879,24881, 24888,24895,24901,24910,24915,24920,24924,24925,24927,24931,24934,24938,24944,24 945,24946,24951,24954,24957,24963,24966,24970,24977,24981,24983,24986,25003,2500 5,25009,25015,25019,25021,25022,25024,25028,25033,25035,25036,25039,25040,25~43, 25045,25047,25049,25053,25057,25063,25064,25067,25070,25071,25081,25082,25085,25 086,25093,25107,25108,25109,25111,25113,25114,25121,25123,25124,25125,25130,2513 3,25136,25141,25142,25143,25149,25154,25159,25164,25165,25168,25169,25177,25181, 25186,25202,25203,25206,25208,25209,25211,25213,25234,25235,25239,25241,25245,25 247,25248,25251,25252,25253,25259,25260,25261,25264,25265,25266,25267,25268,2527 1,25276,25285,25286,25287,25301,25302,25303,25304,25306,25309,25311,25312,25313, 25314,25315,25320,25389,25396,25401,25403,25404,25405,25411,25413,25414,25419,25 420,25422,25425,25427,25428,25430,25430,25431,25434,25437,25~38,25442,25443,25444,2544 6,25502,25503,25504,25505,25506,25507,25508,25510,25511,25512,25514,25517,25520,~ 25521,25526,25529,25530,25534,25535,25537,25540,25541,25545,25547,25550,25557,25 559,25560,25570,25573,25601,25606,25611,25612,25614,25621,25624,25625,25628,2563 2,25634,25635,25637,25638,25639,25646,25647,25649,25651,25652,25653,25661,25670, 25674,25678,25686,25688,25690,25692,25696,25701,25702,25703,25704,25705,25801,25 812,25813,25820,25823,25825,25826,25827,25831,25832,25839,25840,25843,25844,2585 5,25865,25868,25871,25673,25878,25879,25880,25882,25901,25911,25917,25916,25921, 25922,25932,25938,25951,25962,25971,25976,25984,25986,25989,26003,26030,26031,26 032,26033,26034,26035,26036,26037,26038,26040,26041,26047,26050,26059,26060,2606 2,26070,26074,26075,26101,26104,26105,26134,26136,26137,26138,26141,26142,26143,

mhtml:file://Z:\2011 Activities\l 1-178 1& 1782-T-T VOIP Access Charges\Discovery\Staff ... 2/3/2012 VERIFICATION

STATE OF WEST VIRGINIA

COUNTY OF MERCER

I, Angela C. McCall, after first being duly sworn, state that I am State Government Affairs Manager of Frontier West Virginia Inc, and that, as State Government Affairs Manager, I am authorized to verify the Response to SmsFirst Set of Interrogatories, Data Request or Request for Information of Frontier in Case No. 11 - 178 1-T-T and I state that said Answers are true and correct to the best of my knowledge, information and belief.

FRONTER WEST VIRGINIA INC.

B Titl

Sworn to and subscri beforemeonthis 3% day of ,2012.

Notary Public My Commission Expires: [L\ GL~

QFFLCIAL SEAL STATE OF WEST VIRGINIA NOTARY PUBLIC SHERl M. COMER 500 POPLAR LANE RIPLEY, WV 25271 Y commission expirun Dwemkr 27.2020 CERTIFICATE OF SERVICE

I, Joseph J. Starsick, Jr., counsel for Defendant, Frontier West Virginia Inc., do hereby certify that I have served the foregoing Responses Of Frontier West Virginia Inc. To First Set Of Interrogatories, Data Request Or Requests For Information By The Staff Of The Public Service Commission Of West Virginia For Frontier West Virginia Inc. upon the parties listed below via United States mail, postage prepaid, this 3rdday of February 2012, addressed as follows:

Chris Howard, Esquire Public Service Commission of West Virginia 201 Brooks Street Charleston, WV 25301

Kathy L. Buckley Verizon Select Services, Inc. Executive Director - Regulatory Matters 4700 MacCorkle Avenue, S.E. Suite 101, Box 3 Charleston, WV 25304