Frederick E. Moacdieh Executive Director Federal Regulatory and Legal Affairs

1300 I Street, NW, Suite 500 East Washington, DC 20005 Phone 202.515.2590 Fax 202.336.7922 frederick.moacdieh@.com

March 1, 2019

Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street, SW Washington, DC 20554

Re: Section 63.71 Application of Verizon Inc. and Verizon Inc.

Dear Ms. Dortch:

Verizon New York Inc. and Inc. submit the enclosed Application for authority under Section 214(a) of the Communications Act and 47 C.F.R. § 63.71 to grandfather and discontinue NYNEX Enterprise Services and NYNEX Enterprise Network Reconfiguration Service where they are offered in the states of New York and .

Sincerely,

Enclosure

cc: Department of Defense Chief Information Officer Governor of Each Impacted State Public Utilities Commission of Each Impacted State

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554

In the Matter of ) ) Section 63.71 Application of ) Inc. and Verizon New ) England Inc. ) File No.______) For Authority Pursuant to Section 214 of ) the Communications Act of 1934, As ) Amended, To Discontinue the Provision of ) Service )

SECTION 63.71 APPLICATION OF VERIZON NEW YORK INC. AND VERIZON NEW ENGLAND INC.

Verizon New York Inc. and Verizon New England Inc. (collectively “Verizon”) submit this Application for authority under Section 214(a) of the Communications Act and Section

63.71 of the Commission’s rules to grandfather and discontinue NYNEX Enterprise Services

(NES) where they are offered in the state of New York and NYNEX Enterprise Network

Reconfiguration Service (NRS) where it is offered in the states of New York and Massachusetts.

NES and NRS are currently provisioned and supported over an end-of-life legacy network and equipment that is increasingly manufacturer-discontinued. There are relatively few customers still subscribing to these services in the affected areas, as customers continue to migrate away from these older services toward more modern options. Given the low number of subscribers and high costs of maintaining discontinued equipment, we plan to grandfather NES and NRS on or after May 31, 2019 and discontinue the services on or after December 31, 2019.1

1 Modifications in service offerings for customers with existing contracts are subject to the terms of their contracts. 1

Consistent with Section 63.71(a) and (c) of the Commission’s rules, Verizon provides the following information:

1. Name and Address of Carrier (47 C.F.R. §§ 63.71 (a)(1), (c)(2)):

Verizon New York Inc. 140 West Street New York, NY 10007

Verizon New England Inc. 6 Bowdoin Square, 9th Floor , Massachusetts 02114

2. Date of Planned Service Discontinuation (47 C.F.R. §§ 63.71(a)(2), (c)(2)):

Subject to the Commission’s authorization, on or after May 31, 2019, Verizon will grandfather NES and NRS, no longer permitting orders for new customers and no longer permitting moves, additions, or changes for existing customers. Verizon intends to discontinue these services on or after December 31, 2019.2

3. Points of Geographic Areas of Service Affected (47 C.F.R. §§ 63.71(a)(3), (c)(2)):

Subject to the Commission’s authorization, Verizon intends to grandfather and discontinue NES where it offers the services in the state of New York. Verizon intends to grandfather and discontinue NRS where it offers the service in the states of New York and

Massachusetts. Exhibit A lists the wire centers where Verizon offers NES and NRS.

4. Brief Description of Type of Service Affected (47 C.F.R. §§ 63.71(a)(4), (c)(2)):

NES are digital channels operating at transmission speeds between 2.4 Kbps and 44.736

Mbps within a specified bandwidth capacity over a backbone network. NES are provided

2 For customers on tariffed term plans, Verizon will waive any applicable tariffed early termination liability.

2

between customer-designated premises and a or between hubs where NES functions are performed. NES are further described in Verizon’s FCC Tariff No. 11, Section 7.2.13.

NRS enables customers by use of a network controller or network management device to reconfigure specific special access services connected at digital cross-connect systems. The connection may be made either directly or through a hub where the special access service may be bridged or multiplexed. NRS is further described in Verizon’s FCC Tariff No. 11, Section 19.

Alternative Services and Products: Customers today can obtain alternative services and products from Verizon or other providers that may suit customers’ needs depending on the customers’ particular applications. Alternative services include IP-based services and special access services offered by Verizon under its FCC Tariff No. 11. For example, alternative services for wholesale customers include Fiber to the Internet, Switched Ethernet, Private

Internet Protocol, DS1, and DS3 services. Alternative services for retail customers include

Fiber-based voice, FIOS Internet, Switched Ethernet, Private Internet Protocol, DS1, and DS3 services.

Verizon will work with affected customers to identify suitable alternative solutions.

5. Brief Description of the Dates and Methods of Notice to All Affected Customers (47 C.F.R. § 63.71(c)(3)):

Verizon sent notices on or before March 1, 2019 by U.S. Mail to customers that currently subscribe to an affected service. A copy of the notice is attached as Exhibit B.

Verizon is sending copies of this Application by first class U.S. Mail to the governors and public utility commissions of the states of New York and Massachusetts, and to the Department of Defense Chief Information Officer, as required by Section 63.71(a) of the Commission’s rules. Tribal nations will not be impacted by this Section 63.71 application.

3

6. Regulatory Classification of Carrier (47 C.F.R. § 63.71(c)(4)):

Verizon is classified for regulatory purposes under the Commission’s rules as dominant with respect to NES and NRS.

CONCLUSION

Verizon respectfully requests that the Commission approve this Application.

Respectfully submitted,

______William H. Johnson Katharine R. Saunders Of Counsel Roy E. Litland Verizon 1300 I St NW, Suite 500E Washington, DC 20005-7101 (202) 515-2464 (Office)

March 1, 2019

4

CERTIFICATE OF SERVICE

I hereby certify that on or before this 1st day of March 2019, I caused to be served a copy of the foregoing Section 63.71 Application by U.S. Mail postage prepaid to the following parties on the attached service list.

______

Roy E. Litland

SERVICE LIST

Department of Defense Chief Information Officer Attn: Military Asst/Mobility Team The Pentagon Washington, DC 20301

Honorable Kathleen H. Burgess The Honorable Andrew M. Cuomo Secretary to the Commission Governor of New York New York Public Service Commission State Capitol Building Empire State Plaza Albany, NY 12224 Agency Building 3 Albany, NY 12223-1350

Karen Charles Peterson The Honorable Charlie Baker Commissioner Office of the Governor Massachusetts Department of State House, Room 280 Telecommunications and Cable Boston, MA 02133 1000 Washington Street, Suite 820 Boston, MA 02118-6500

EXHIBIT A

NYNEX Enterprise Services Wire Center CLLI Codes New York

ALBYNYSS NYCMNY37 BFLONYFR NYCMNY42 BFLONNYMA NYCMNY50 BNGHNYHY NYCMNY56 BRWDNYBW NYCMNY79 CICRNYCJ NYCMNYBS EMIRNYEM NYCMNYBW ENDCNYEN NYCMNYWS FLPKNYFP NYCQNYFH FRDLNYFM NYCQNYJA GLFLNYGF NYCQNYLI GRCYNYGC NYCQNYNW HCVLNYHV NYCRNYNS HMPSNYHS LYBRNYLB NYCXNYCR MINLNYMI NYCXNYTR MTKSNYMK PCHGNYPH MTVRNNYMV PGHKNYSH NWBRNYNW PLBGNYPB NYACNYNK PTSDNTPS NYCKNYAL RNKNNYRN RVHDNYRV NYCKNYAR SCHNNYSC NYCKNYBR SYRCNYSU NYCKNYWM SYVLNYSA NYCMNY13 UTICNYUT NYCMNY18 WHPLNYWP NYCMNY30 WTTWNYUN

NYCMNY36

NYNEX Enterprise Network Reconfiguration Service Wire Center CLLI Codes

New York Massachusetts

MTKSNYMK BRTNMACR NWBRNYNW CMBRMABE NYACNYNK FLRVMANM NYCKNYBR FTBGMAMA NYCKNYWM HYNSMAOC NYCMNY36 LWRNMACA NYCMNYBS LYNNMACH NYCQNYJA NATNMAMA NYCXNYCR PGHKNYSH PTFDMAAA SCHNNYSC PTFDMAFE WHPLNYWP QNCYMAHA SPFDMAWO WLPLMASS WLHMMASP WRCSMACE

EXHIBIT B

Verizon March 1, 2019 22001 Loudoun County Parkway D1-3-300 Ashburn, VA 20147

Billing Name Billing Address 1 Billing Address 2 Billing Address 3 City, State, ZIP

RE: Discontinuation of FCC NYNEX Enterprise Services and FCC NYNEX Enterprise Network Reconfiguration Service

As part of Verizon’s continuing effort to update its portfolio of network services, we are planning to terminate interstate NYNEX Enterprise Services and NYNEX Enterprise Network Reconfiguration Service (“Affected Services”) where offered in the states of New York and Massachusetts pursuant to Verizon’s FCC Tariff No. 11. Exhibit A lists the wire centers in which Verizon offers these services.

Interstate NYNEX Enterprise is a platform for providing digital channels operating at transmission speeds between 2.4 kbps and 44.736 Mbps with inherent grooming capability, and is further described in Verizon’s FCC Tariff No. 11, Sec. 7.2.13.

Interstate NYNEX Enterprise Network Reconfiguration Service enables customers, by use of a network controller or network management device, to reconfigure specific special access services connected at digital cross-connect systems. The connection may be made either directly or through a hub where the special access service may be bridged or multiplexed. NYNEX Enterprise Network Reconfiguration Service is further described in Verizon’s FCC Tariff No. 11, Sec. 19.

Customers who subscribe to the Affected Services may obtain a list of their impacted circuits by contacting their Verizon Account Manager.

This letter is being sent to inform you of our plans for service discontinuation and urge you to begin making arrangements to migrate applications that use these services to an alternative service.

On or after May 31, 2019, subject to FCC approval, Verizon will grandfather the Affected Services. At that time, Verizon will stop accepting orders and will no longer permit moves, additions and/or changes to these services.

On or after December 31, 2019, subject to FCC approval, Verizon will begin discontinuing the Affected Services. If you are purchasing the service under a term commitment that runs past December 31, 2019, Verizon may discontinue service before the term commitment expires and will waive early termination liability, if applicable. Following the expiration of your term plan, Verizon will continue to provide you with the affected service on a month-to-month basis until either you or Verizon terminates the affected service.

Verizon will provide you with written notice at least six months prior to terminating an affected service.

Modifications in service offerings for customers with existing contracts are subject to the terms of their contract.

Verizon offers several alternatives that may suit your needs, including (subject to availability):

• Fiber to the Internet Service • Switched Ethernet Service • Private Internet Protocol Service • DS1 Service • DS3 Service

Please contact your Verizon Account Manager to discuss alternative solutions.

Sincerely,

Verizon

on behalf of

Verizon New York Inc. 140 West Street New York, NY 10007

Verizon New England Inc. 6 Bowdoin Square, 9th Floor Boston, Massachusetts 02114

FCC Required Notice: The FCC will normally authorize this proposed discontinuance of service (or reduction or impairment) unless it is shown that customers would be unable to receive service or a reasonable substitute from another carrier or that the public convenience and necessity is otherwise adversely affected. If you wish to object, you should file your comments as soon as possible, but no later than 30 days after the Commission releases public notice of the proposed discontinuance. You may file your comments electronically through the FCC's Electronic Comment Filing System using the docket number established in the Commission's public notice for this proceeding, or you may address them to the Federal Communications Commission, Wireline Competition Bureau, Competition Policy Division, Washington, DC 20554, and include in your comments a reference to the §63.71 Application of Verizon New York Inc. and Verizon New England Inc. Comments should include specific information about the impact of this proposed discontinuance (or reduction or impairment) upon you or your company, including any inability to acquire reasonable substitute service.

2

Exhibit A

NYNEX Enterprise Services Wire Center CLLI Codes New York

ALBYNYSS NYCMNY37 BFLONYFR NYCMNY42 BFLONNYMA NYCMNY50 BNGHNYHY NYCMNY56 BRWDNYBW CICRNYCJ NYCMNY79 EMIRNYEM NYCMNYBS ENDCNYEN NYCMNYBW FLPKNYFP NYCMNYWS FRDLNYFM NYCQNYFH GLFLNYGF NYCQNYJA GRCYNYGC NYCQNYLI HCVLNYHV NYCQNYNW HMPSNYHS NYCRNYNS LYBRNYLB NYCXNYCR MINLNYMI NYCXNYTR MTKSNYMK PCHGNYPH MTVRNNYMV PGHKNYSH NWBRNYNW PLBGNYPB NYACNYNK PTSDNTPS NYCKNYAL RNKNNYRN NYCKNYAR RVHDNYRV NYCKNYBR SCHNNYSC SYRCNYSU NYCKNYWM SYVLNYSA NYCMNY13 UTICNYUT NYCMNY18 WHPLNYWP NYCMNY30 WTTWNYUN

NYCMNY36

3

NYNEX Enterprise Network Reconfiguration Service Wire Center CLLI Codes

Massachusetts New York BRTNMACR MTKSNYMK CMBRMABE NWBRNYNW FLRVMANM NYACNYNK FTBGMAMA NYCKNYBR HYNSMAOC NYCKNYWM LWRNMACA NYCMNY36 LYNNMACH NYCMNYBS NYCQNYJA NATNMAMA NYCXNYCR PTFDMAAA PGHKNYSH PTFDMAFE SCHNNYSC QNCYMAHA WHPLNYWP SPFDMAWO WLPLMASS WLHMMASP

WRCSMACE

4

March 1, 2019 Verizon

700 Hidden Ridge 02 Floor Room W02H215 Irving, TX USA 75038 1

RE: Discontinuation of FCC NYNEX Enterprise Services and FCC NYNEX Enterprise Network Reconfiguration Service

Dear Valued Customer,

Account and Circuit Number(s): See appendix

As part of Verizon's continuing effort to update its portfolio of network services, we are planning to terminate interstate NYNEX Enterprise Services and NYNEX Enterprise Network Reconfiguration Service (ªAffected Servicesº) where offered in the states of New York and Massachusetts pursuant to Verizon's FCC Tariff No. 11. Exhibit A lists the wire centers in which Verizon offers these services.

Interstate NYNEX Enterprise Services provides digital channels operating at transmission speeds between 2.4 Kbps and 44.736 Mbps with inherent grooming capability, and is further described in Verizon's FCC Tariff No. 11, Sec. 7.2.13.

Interstate NYNEX Enterprise Network Reconfiguration Service enables customers, by use of a network controller or network management device, to reconfigure specific special access services connected at digital cross-connect systems. The connection may be made either directly or through a hub where the special access service may be bridged or multiplexed. NYNEX Enterprise Network Reconfiguration Service is further described in Verizon's FCC Tariff No. 11, Sec. 19.

According to our records, you currently subscribe to the Affected Services.

This letter is being sent to inform you of our plans for service discontinuation and urge you to begin making arrangements to migrate applications that use these services to an alternative service.

1

 On or after May 31, 2019, subject to FCC approval, Verizon will grandfather the Affected Services. At that time, Verizon will stop accepting orders and will no longer permit moves, additions, and/or changes for these services.

On or after December 31, 2019, subject to FCC approval, Verizon will begin discontinuing the Affected Services. If you are purchasing an affected service under a term commitment that runs past December 31, 2019, Verizon may discontinue service before the term commitment expires and will waive early termination liability, if applicable. Following the expiration of your term plan, Verizon will continue to provide you with the affected service on a month-to-month basis until either you or Verizon terminates the affected service.

Verizon will provide you with written notice at least six months prior to terminating an affected service.

Modifications in service offerings for customers with existing contracts are subject to the terms of their contract.

Please review your application(s) that use one of the Affected Services, and determine what alternative Verizon service you may wish to migrate these applications to prior to the disconnect of your current service. Verizon offers several alternatives that may suit your needs, including (subject to availability):

· Fiber-based voice services · Fios Internet Service · Switched Ethernet Service · Private Internet Protocol Service · DS1 Service · DS3 Service

Please contact your Verizon Account Manager to discuss alternative solutions.

Sincerely, Verizon

Verizon New York Inc. 140 West Street New York, NY 10007

Verizon New England Inc. 6 Bowdoin Square, 9th Floor Boston, Massachusetts 02114

FCC Required Notice: The FCC will normally authorize this proposed discontinuance of service (or reduction or impairment) unless it is shown that customers would be unable to receive service or a reasonable substitute from another carrier or that the public convenience and necessity is otherwise adversely affected. If you wish to object, you should file your comments as soon as possible, but no later than 30 days after the Commission releases public notice of the proposed discontinuance. You may file your comments electronically through the FCC©s Electronic Comment Filing System using the docket number established in the Commission©s public notice for this proceeding, or you may address them to the Federal Communications Commission, Wireline Competition Bureau, Competition Policy Division, Washington, DC 20554, and include in your comments a reference to the §63.71 Application of Verizon New York Inc. and Verizon New England Inc. Comments should include specific information about the impact of this proposed discontinuance (or reduction or impairment) upon you or your company, including any inability to acquire reasonable substitute service.

 Appendix

ACCOUNT AND CIRCUIT NUMBERS(S):

 1 Exhibit A

NYNEX Enterprise Services Wire Center CLLI Codes New York

ALBYNYSS NYCMNY37 BFLONYFR NYCMNY42 BFLONNYMA BNGHNYHY NYCMNY50 BRWDNYBW NYCMNY56 CICRNYCJ NYCMNY79 EMIRNYEM NYCMNYBS ENDCNYEN NYCMNYBW FLPKNYFP NYCMNYWS FRDLNYFM NYCQNYFH GLFLNYGF NYCQNYJA GRCYNYGC NYCQNYLI HCVLNYHV NYCQNYNW HMPSNYHS NYCRNYNS LYBRNYLB NYCXNYCR MINLNYMI NYCXNYTR MTKSNYMK PCHGNYPH MTVRNNYMV PGHKNYSH NWBRNYNW PLBGNYPB NYACNYNK PTSDNTPS NYCKNYAL RNKNNYRN NYCKNYAR RVHDNYRV NYCKNYBR SCHNNYSC NYCKNYWM SYRCNYSU NYCMNY13 SYVLNYSA UTICNYUT NYCMNY18 WHPLNYWP NYCMNY30 WTTWNYUN NYCMNY36

NYNEX Enterprise Network Reconfiguration Service Wire Center CLLI Codes

Massachusetts New York BRTNMACR MTKSNYMK CMBRMABE NWBRNYNW FLRVMANM NYACNYNK FTBGMAMA NYCKNYBR HYNSMAOC NYCKNYWM LWRNMACA NYCMNY36 LYNNMACH NYCMNYBS NYCQNYJA NATNMAMA NYCXNYCR PTFDMAAA PGHKNYSH PTFDMAFE SCHNNYSC QNCYMAHA WHPLNYWP SPFDMAWO WLPLMASS WLHMMASP WRCSMACE