Subject: VERIZON COMMENTS IN MPSC CASE NO. U-15619
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1 A. Randall Vogelzang General Counsel Great Lakes Region September 3, 2008 HQE02J Hidden Ridge P.O. Box Irving, TX Phone Fax Ms. Mary Jo Kunkle Executive Secretary Michigan Public Service Commission 6545 Mercantile Way P.O. Box Lansing, MI Subject: VERIZON COMMENTS IN MPSC CASE NO. U Dear Ms. Kunkle: Enclosed for filing is an electronic copy of Verizon North Inc., Contel South, Inc. d/b/a Verizon North Systems and MCImetro Access Transmission Services LLC d/b/a Verizon Access Transmission Services (collectively Verizon ) Comments to the Joint Application to transfer the Designation for Livingston County from the United Way Regional Call center to the Jackson Call center and designate the Jackson call Center as the answering point for Lenawee County. Also enclosed is the original proof of service. If you have any questions, you may contact me at (972) Sincerely, A. Randall Vogelzang Enclosures
2 STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION In the matter of the Joint Application of ) Jackson Call Center, a program of the, ) United Way of Jackson County in collaboration ) with the Capital Area United Way, Eaton County ) United Way, Hillsdale County United Way, ) Lenawee United Way, LifeWays and Livingston ) MPSC Case No. U County United Way to transfer the designation ) as the answering point for Livingston ) County from United Way Regional Call Center ) to Jackson Call Center and designate ) Jackson Call Center as the answering ) point for Lenawee County. ) ) VERIZON COMMENTS Verizon North Inc, Contel of the South, Inc. d/b/a/ Verizon North Systems, and MCImetro Access Transmission Services LLC d/b/a Verizon Access Transmission Services (collectively Verizon ) submit these comments pursuant to the Michigan Public Service Commission s ( Commission ) July 25, 2008 Notice of Opportunity to Comment in the above referenced proceeding. The relief Jackson 211 Call Center seeks will involve crossing a LATA boundary, which could prevent the implementation of the project if the existing 800 number for Jackson County is not used for both Livingston and Lanawee counties. Thus, Verizon does not object to Jackson Call Center assuming the designation in Livingston County or its designation as the answering point for Lenawee County so long as the Jackson Call Center utilizes its existing 800 number for calls to both Livingston and Lenawee counties. Since a call originating from a Verizon end-user customer to the Jackson Call Center would require 1
3 routing traffic across a LATA boundary, Verizon does not currently have local trunk groups that could be used to complete such calls using an AIN solution. If the existing 800 number for the Jackson Call Center is utilized for Livingston and Lenawee counties, Verizon s local switches will be able to convert a call to the Jackson Call Center 800 number, translate the 800 number, and appropriately route the Interlata call to the Jackson Call Center. This would make the relocation transparent to the end users in Livingston and Lenawee Counties and would greatly simplify the traffic reroute process. Verizon will work with the Jackson Call Center as needed to ensure a smooth transition for its end user customers. In addition, consistent with previous Commission orders, the number assignment should be done on an exchange basis rather than a county basis. 1 Verizon recommends that the Jackson Call Center should be responsible for interfacing with all telecommunications providers in the licensed area (county) of the Jackson Call Center to ensure appropriate routing of calls. This is necessary because there may be more than one telecommunications provider in a county and not all telecommunications providers service areas follow the county boundaries in which providers are licensed by the state. 1 May 16, 2002 Order in Case No. U (Application of Volunteer Center of Battle Creek, Inc.); September 16, 2002 Order in Case No. U (Application of Heart of West Michigan United Way); February 20, 2003 Order in Case No. U (Application of Gryphon Place); November 4, 2003 Order in Case No. U (Application of First Call of Ottawa County); August 31, 2004 Order in Case No. U (Application of First Call for Help of Jackson County); May 17, 2005 Order in Case No. U (Application of Community Access Line of the Lakeshore, Inc.); August 16, 2005 Order in Case No. U (Application of United Way of Southeast Michigan); October 18, 2005 Order in Case No (Application of UPCAP Services, Inc.); September 26, 2006 Order in Case No. U (Application of United Way Regional Call Center); February 14, 2007 Order in Case No. U (Application of Jackson Call Center); October 25, 2007 Order in Case No. U (Application of First Call of Ottawa County and Community Access Line of the Lakeshore, Inc.); and January 29, 2008 Order in Case No. U (Application of and Community Access Line of the Lakeshore, Inc.) 2
4 Respectfully submitted, VERIZON NORTH INC, CONTEL OF THE SOUTH, INC. d/b/a VERIZON NORTH SYSTEMS and MCIMETRO ACCESS TRANSMISSION SERVICES LLC d/b/a VERIZON ACCESS TRANSMISSION SERVICES By: A. Randall Vogelzang (P27998) Verizon North Inc., Contel Of The South, Inc. d/b/a Verizon North Systems and MCImetro Access Transmission Services LLC d/b/a Verizon Access Transmission Services HQE02J Hidden Ridge Irving, TX (972) Dated: September 3,
5 STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION In the matter of the Joint Application of ) Jackson Call Center, a program of the, ) United Way of Jackson County in collaboration ) with the Capital Area United Way, Eaton County ) United Way, Hillsdale County United Way, ) Lenawee United Way, LifeWays and Livingston ) MPSC Case No. U County United Way to transfer the designation ) as the answering point for Livingston ) County from United Way Regional Call Center ) to Jackson Call Center and designate ) Jackson Call Center as the answering ) point for Lenawee County. ) ) STATE OF TEXAS ) ) ss COUNTY OF DALLAS ) PROOF OF SERVICE Patty A. Nelson being first duly sworn, deposes and says that on September 3, 2008, a copy of Verizon s Comments was served upon the parties via Attorney for United Way of Jackson County / Jackson Call Center United Way of Jackson County William Marcoux Ken Toll Marcoux Allen Schomer Bower Executive Director Kendall Nichols & Lindsey, P.C. 536 North Jackson Street 145 South Jackson Street Jackson, MI P.O. Box 787 ktoll@uwjackson.org Jackson, MI wmarcoux@marcouxallen.com Subscribed and sworn to before me this 3 rd date of September Patty A. Nelson Graci M. Scott, Notary Public Dallas County, Texas My Commission Expires: April 20, 2010
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