1990 K S TREET, N.W. WASHINGTON, D.C. 20006-1181 January 26

CAHILL GORDON & REINDEL LLP SUITE 950 1990 K STREET, N.W. AUGUSTINE HOUSE E IGHTY P INE S TREET WASHINGTON, D.C. 20006-1181 6A AUSTIN FRIARS N EW Y ORK, N.Y. 10005-1702 LONDON, ENGLAND EC2N 2HA (212) 701-3000 ____________ (011) 44.20.7920.9800 FAX: (212) 269-5420 FAX: (011) 44.20.7920.9825 ____________ TELEPHONE (202) 862-8900 FACSIMILE (202) 862-8958 ____________ C HÉRIE R. K ISER │ 202-862-8950 │ [email protected] January 26, 2009 Via Electronic Mail and Federal Express Catrice C. Williams Secretary Department of Telecommunications and Cable Two South Station Fourth Floor Boston, Massachusetts 02110 Re: D.T.C. 08-9, Petition for Arbitration of an Interconnection Agreement between Intrado Communications Inc. and Verizon New England Inc. d/b/a Verizon Massachusetts Dear Secretary Williams: Intrado Communications Inc. (“Intrado Comm”), by its attorneys, hereby respectfully submits its Response to the First Set of Information Requests of the Department of Telecommunications and Cable. If you have any questions concerning this matter, please contact the undersigned. Respectfully submitted, Chérie R. Kiser Counsel for Intrado Communications Inc. Enclosures cc: Service List 41495.1 Before the COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OF TELECOMMUNICATIONS AND CABLE ________________________________________________ ) In the Matter of the Petition of ) Intrado Communications Inc. for Arbitration ) DTC 08-9 Pursuant to Section 252(b) of the Communications Act ) of 1934, as amended, to Establish an Interconnection ) Agreement with Verizon New England Inc. ) d/b/a Verizon Massachusetts ) ________________________________________________) INTRADO COMMUNICATIONS INC. RESPONSE TO FIRST SET OF INFORMATION REQUESTS OF THE DEPARTMENT OF TELECOMMUNICATIONS AND CABLE TO INTRADO COMMUNICATIONS INC. Intrado Communications Inc. (“Intrado Comm”) responds to the First Set of Information Requests (“Requests”) from the Department of Telecommunications and Cable (“DTC”) as follows. Any answers provided by Intrado Comm in response to these Requests are provided subject to, and without waiver of, the following general objections. GENERAL OBJECTIONS 1. Intrado Comm reserves all objections as to relevance and materiality. Where Intrado Comm submits responses and produces materials in response to the Requests, it does so without conceding the relevancy or materiality of the information or materials sought or produced, or their subject matter, and without prejudice to Intrado Comm’s right to object to further discovery, or to object to the admissibility of proof on the subject matter of any response, or to the admissibility of any document or category of documents, at a future time. Any disclosure of information not responsive to the Requests is inadvertent and is not intended to waive Intrado Comm’s right not to produce similar or related information or documents. 41493.1 1 2. Intrado Comm objects to the Requests to the extent they seek information protected by the attorney-client privilege, the work-product doctrine, or other applicable privileges and protections. Intrado Comm hereby claims all applicable privileges and protections to the fullest extent implicated by the Requests and excludes privileged information and materials from its responses. Any disclosure of such information or materials as a result of Intrado Comm’s responses or otherwise is inadvertent and is not intended to waive any applicable privileges or protections. 3. Intrado Comm objects to all Information Requests that seek information about Intrado Inc. or any other Intrado Comm affiliate. Intrado Inc. and other affiliates are not parties to this proceeding and information regarding them is beyond the scope of this proceeding and not likely to result in admissible evidence in this proceeding. Subject to and without waiving the foregoing General Objections, each of which are incorporated by reference into the responses below as if fully restated therein, Intrado Comm provides the following responses to the Requests. Intrado Comm’s responses are based on the best information presently available; Intrado Comm reserves the right to amend, supplement, correct or clarify answers if other or additional information is obtained, and to interpose additional objections if deemed necessary. 41493.1 2 REQUESTS DTC - INTRADO 1-1: Explain why Intrado requires direct trunking between Verizon End Offices and Intrado’s network. Also explain why the network arrangement which would connect Verizon Selective Router with Intrado’s network is a lesser architectural arrangement. Provide complete and detailed documentation on how reliability and service quality are affected. INTRADO COMM RESPONSE: Intrado Comm’s proposed requirement for dedicated direct trunking between Verizon’s end offices and Intrado Comm’s network reflects best possible network interconnection arrangement for the provision of 911/E-911 services to public safety answering points (“PSAPs”) and other public safety agencies. For example, the Standards for Enhanced 911 adopted by the Massachusetts Statewide Emergency Telecommunications Board require “a minimum of two dedicated trunks from each telephone company or Alternative Local Exchange Carrier (ALEC) central office to any tandem” (560 CMR 2.00 - Appendix A, 9-1-1 System Design - Technical Standards at (2)(b)). For purposes of these requirements, a “tandem” is defined as a switching system in the E911 telephone network that establishes 911 call routing. The Massachusetts requirement is similar to requirements in Illinois and Texas. See, e.g., ILL. ADMIN CODE TIT. 83, § 725.500(c), (x) (requiring the use of dedicated direct trunking to the selective router serving the PSAP); Texas P.U.C. SUBST. R. 26.435 (stating that carriers are “responsible for providing such dedicated trunks from the [carrier] switching office or point of presence to the 9-1-1 selective router” and requiring carriers to deploy a minimum of two dedicated trunks to each selective router). Further, Intrado Comm’s proposed requirement for dedicated direct trunking reflects the 911 interconnection arrangements that are used in Verizon’s network today in order to promote overall 911/E911 network reliability. Verizon uses dedicated direct trunking from its end offices to its selective routers to route 911 calls destined for Verizon’s PSAP customers within its own network. See Verizon Pre-Filed Testimony at 15. Intrado Comm’s proposed language is also consistent with the 911 interconnection arrangements Verizon has adopted for competitors to route their end users’ 911 calls destined for Verizon’s PSAP customers. Specifically, competitors route their end users’ 911 calls to Verizon via direct dedicated trunking from the competitor’s switch or non-911 traffic point of interconnection to the appropriate selective router serving the PSAP to which the call is destined. See Verizon Pre-Filed Testimony at 16. Presumably, the Statewide Emergency Telecommunications Board and Verizon have implemented these network arrangements because they provide the most reliable and redundant network architecture arrangement for critical 911 services. Best practices used in engineering 911 networks minimize the number of possible points of failure for each circuit carrying originating 911 traffic from an end user’s end office to the 911 selective router. This includes network designs that minimize the number of switching points and facility transport routes necessary to reach the PSAP. 41493.1 3 There is no reason to use different POI or trunking arrangements when Intrado Comm is 911/E-911 service provider. Imposing a different type of interconnection arrangement on Intrado Comm is discriminatory and violates Intrado Comm’s right to interconnection arrangements that are equal in quality to those Verizon provides itself or any other carrier. Reports or documentation attesting to the reliability of routing all 911/E-911 calls are unavailable to Intrado Comm due to the proprietary nature of such statistics. Further, formal Federal Communications Commission outage reporting statistics also remain confidential and are only available to the reporting incumbent local exchange carrier (“ILEC”). RESPONSIBLE PERSON: Thomas Hicks, Director-Carrier Relations 41493.1 4 DTC - INTRADO 1-2: Provide any relevant information and/or documents to compare the reliability of existing 911 networks, which involve direct trunking between selective routers and PSAPs, with Intrado’s proposed Intelligent Emergency Network. INTRADO COMM RESPONSE: The highest level of reliability possible for 911 services is an absolute requirement regardless of the type of 911 network used. Intrado Comm has engineered its network to be highly reliable and fully redundant. Intrado Comm employs network design concepts that are consistent with industry-established practices, including the Federal Communications Commission’s Best Practices and recommendations by the National Emergency Number Association. Most notable would be requiring carriers interconnecting with Intrado Comm to utilize dedicated direct trunking from the originating switch to the Intrado Comm selective router serving the PSAP to which the call is directed, as well as employing diversity and redundancy throughout the network. RESPONSIBLE PERSON: Thomas Hicks, Director-Carrier Relations 41493.1 5 DTC - INTRADO 1-3: Provide a list of each docketed interconnection agreement arbitration proceeding commenced within the past two (2) years between (a) Intrado and Verizon and (b) Intrado and Embarq. For each proceeding, include the full

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