Jason D. Topp Assistant General Counsel

(651) 312-5364

March 27, 2020

Ms. Robin Ancona Director, Communications Michigan Public Service Commission 7109 W. Saginaw Highway Lansing, Ml48909

Re: In the Matter of Broadwing Communications, LLC’s Notice of Discontinuance of Service in Michigan MPSC Case No. U-20714

Dear Ms. Ancona:

Please find the original of this letter and the Notice of Discontinuance of Service submitted on behalf of Broadwing Communications, LLC (“Broadwing” or “Company”) in the above-referenced docket.

A copy of the FCC's Public Notice granting the Application is attached hereto as Attachment 1.

Any questions you may have regarding this filing should be directed to Al Lubeck at 913-884-1116 or via email to al.lubeck@centurylink.com. Thank you for your assistance in this matter.

Sincerely,

Jason D. Topp

JDT/bardm

Enclosures

STATE OF MICHIGAN

BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION

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In the Matter of Broadwing Communications, LLC’s Notice of Discontinuance of Service in Michigan

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Case No. U-20714

NOTICE OF DISCONTINUANCE OF SERVICE

Pursuant to Section 313 of the Michigan Telecommunications Act, MCL

§ 484.2313(5)(b), Broadwing Communications, LLC (“Broadwing”) hereby provides notice that

it intends to discontinue the provisioning of switched-based local and long-distance voice

services on June 30, 2020 pending regulatory approval. The Section 63.71 Application of

Broadwing Communications, LLC to discontinue services in Michigan and other states was

deemed granted automatically by the Federal Communications Commission on March 20, 2020.

A copy of the FCC’s Public Notice granting the Application is attached hereto as Attachment A.

Broadwing will continue to provide other services in Michigan, including access services and

private line service and wishes to retain its existing authority to provide future services to

Michigan businesses. In support thereof, Broadwing states as follows:

Broadwing provides the following information in support of this Notice:

I. CONTACT INFORMATION

Questions and other correspondence regarding this Notice should be sent to:

Al Lubeck, Public Policy Director CenturyLink 13116 W 128th Street Overland Park, KS 66213 Telephone: 913-884-1116 Fax: 913-791-2376 Email: al.lubeck@centurylink.com

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Name and corporate headquarters address of filer:

Broadwing Communications, LLC 100 CenturyLink Drive Monroe, Louisiana 71203

II. BACKGROUND

Broadwing Communications, LLC was granted authority to provide Basic Local

Exchange Services throughout the areas in the state of Michigan served by Frontier and AT&T-

Michigan pursuant to an Order issued in Case No. U-14294 on December 2, 2004. Broadwing

currently serves 44 combined retail local and wholesale customers in Michigan. Broadwing

proposes to discontinue providing telecommunications services to all existing customers on or

after June 30, 2020, pending required regulatory approval.

III. REASON FOR DISCONTINUANCE AND CUSTOMER IMPACT

Due to changes in technology and market conditions, Broadwing has modified its focus

and seeks to discontinue provisioning switched-based local and long-distance voice services.

The customers can change to other services offered by Broadwing or its affiliates, or they can

subscribe to services offered by other local providers. Each of Broadwing’s customers have

other providers that offer local services, including AT&T Michigan and Frontier in their

respective service territories, competitive local service providers, Voice over Internet Protocol

providers, cable providers and wireless providers. Broadwing continues its proactive

communication with customers and no customer will be left without options for service.

Broadwing will prorate and refund any advance payments for service, as well as any

deposits, within 30 days of issuance of final customer invoices. No termination liabilities or

penalties will apply.

IV. LEGAL NOTICE

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Pursuant to Section 313 (5)(b) of the MTA, Mich. Comp. Laws § 484.2313(5)(b),

Broadwing will publish legal notice of this Application in a newspaper of statewide circulation

concurrently with the submission of this Notice. A copy of the text of the newspaper publication

is attached as Attachment B. Additionally, Broadwing began discussing this discontinuance with

its customers since July 2019 and provided initial customer notices included as Attachment C to

affected customers via U.S. 1st class mail on January 20, 2020. Broadwing also provided a

Michigan specific notice to customers via U.S. 1st class mail on February 25, 2020 (also included

in Attachment C). Broadwing will notify its remaining customers via U.S. 1st class mail of the

pending service termination (also in Attachment C).

AT&T Michigan and Frontier are alternative providers offering local exchange services

in their respective service territories and there are other competitive local exchange carriers who

offer services and serve as alternatives to Broadwing’s customers.

V. WHOLESALE

Broadwing has communicated with each wholesale customer and is following appropriate

interconnection agreement provisions to discontinue service to those customers.1 Broadwing has

also notified all interconnecting carriers and long distance providers and is following the

appropriate agreement provisions with those carriers.

VI. CONCLUSION

Broadwing Communications, LLC intends to discontinue the provision of Basic Local

Exchange services in Michigan on or after June 30, 2020. Although Broadwing will discontinue

Basic Local Exchange service to its existing customer base, it wishes to retain its local operating

1 Mich. Admin. Code r. 484.1005, applies to disconnections “due to a dispute concerning resale or purchase of a local wholesale product.” Because this application does not relate to a dispute, interconnection agreement terms, rather than this rule apply.

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authority because it will continue to offer other services to its customers, including access

services through its existing access services tariff.

Dated this 27th day of March, 2020.

BROADWING COMMUNICATIONS, LLC

Jason D. Topp CenturyLink 200 South Fifth Street, Room 2200 Minneapolis, MN 55402 (651) 312-5364 Jason.topp@centurylink.com

Not Admitted in Michigan

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Attachment A

FCC PUBLIC NOTICE

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Attachment B

NEWSPAPER PUBLICATION

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Important Notice Regarding the Planned Discontinuance of Certain Traditional Voice & Data

Services Provided by Broadwing Communications, LLC, a CenturyLink Company

Broadwing Communications, LLC, a CenturyLink Company, hereby notifies all interested parties that it is discontinuing certain voice and data services in Michigan as of June 30, 2020. Affected customers have been notified by first class U.S. Mail. A customer of Broadwing Communications may request the Commission to investigate the availability of comparable voice service with reliable access to 9-1-1. You may submit comments to the Commission via mail to the Executive Business Section, Michigan Public Service Commission, P.O. Box 30221, Lansing, MI 48909, referencing Docket No. U-20714. Electronic comments may be emailed to: mpscedockets@michigan.gov. All comments submitted to the Commission in this matter will become public information, posted on the Commission's website, and subject to disclosure. Comments should not include information a customer wishes to remain private. A person or telecommunications provider affected by this discontinuance can contact Broadwing’s Voice Advancement Team at 877-699-3201 or voiceadvancement@centurylink.com, or writing to Broadwing Communications, LLC, 100 Monroe Drive, Monroe, LA 71203. If you subscribe to other services from CenturyLink, those services will NOT be impacted by the anticipated discontinuance of the affected services listed above. Your other services will remain in place with no change to the applicable rates, terms, or conditions.

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Attachment C

CUSTOMER NOTICES

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Initial Customer Notice

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Michigan Specific Customer Notice

100 CenturyLink Drive Monroe, Louisiana 71203

www.CenturyLink.com February 25, 2020 Billing Account Number: 1-xxxxx xxxxxxxxxx xxxxxxxx ST DETROIT, Michigan 48201

Important Notice Regarding the Planned Discontinuance of Certain Traditional Voice & Data Services Provided in Michigan by Broadwing Communications, LLC, a CenturyLink Company Dear Valued Customer, A Notice was sent to you on January 22, 2020 advising that Broadwing Communications, LLC has filed an application to discontinue certain voice and data services effective as of March 20, 2020, or as soon after that date as authorized by the Federal Communications Commission and any other relevant state regulatory commissions. Pursuant to Michigan state law, the request has also been made with the Michigan Public Service Commission and if approved, will be effective as of June 30, 2020. You are receiving this notice because you currently subscribe to one or more of the following services provided by Broadwing Communications, LLC, which, subject to regulatory approval, will be discontinued as a result of this project. • • Local Trunking Business Line Service including POTS (Plain Old Telephone Service) voice-grade telephonic communications channels that are used to place or receive one call at a time.

• • Local Trunking PRI (Primary Rate Interface) transmits and receives video, voice and data simultaneously.

• • Local Trunking Local Inbound originates calls to CenturyLink provided telephone numbers, aggregate the traffic, and hands it off to single or multiple IP endpoints.

• • Local Trunking SIP (Session Initiation Protocol) send and receive calls via the Internet.

• • Local Trunking ELS (Enhanced Local Services) originates and terminates calls to and from CenturyLink provided telephone numbers, aggregates the traffic, and hands it off to single or multiple endpoints.

• • LD Outbound traditional long distance 1+ or direct dialed domestic and international (U.S. origination) calling services provided over switched or dedicated facilities.

• • LD Toll Free and Contact Center traditional long distance toll-free or 800 services, domestic and international (U.S. termination) calling services provided over switched or dedicated facilities.

• • Integrated Voice and Data Service (IVAD) allows a customer to utilize a single high capacity facility to integrate both voice and data services. IVAD service is available in different groups of channels and at varying bandwidth speeds.

In order to maintain continuous service at your location, CenturyLink would like to work with you to migrate your existing service to a similar service or, alternatively, a state-of-the-art platform that will provide your business with greater flexibility, simplicity, and efficiency. You should initiate a migration order or submit a disconnect request with CenturyLink by June 30, 2020 to avoid possible disruption of your service on June 30, 2020. Existing contracts for these services will not be renewed.

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Customers with a contract that expires prior to June 30, 2020 may retain their service(s) covered by that contract on a month-to-month basis until June 30, 2020. Our Voice Advancement Team is here to help you through the migration or disconnect process. Contact them at 877-699-3201 or voiceadvancement@centurylink.com. If you subscribe to other services from CenturyLink, those services will NOT be impacted by the anticipated discontinuance of the affected services listed above. Your other services will remain in place with no change to the applicable rates, terms, or conditions. When the telecommunication services are discontinued, the Company will automatically apply any credits for the service to your CenturyLink invoice. We value your business and appreciate your cooperation regarding this notice. Thank you, Broadwing Communications, LLC 877-699-3201

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April Customer Bill Insert

Important Notice Regarding the Planned Discontinuance of Certain Traditional Voice & Data Services Provided in Michigan by Broadwing Communications, LLC, a CenturyLink Company Dear Valued Customer, A Notice was sent to you on January 22, 2020 advising that Broadwing Communications, LLC has filed an application to discontinue certain voice and data services effective as of March 20, 2020, or as soon after that date as authorized by the Federal Communications Commission and any other relevant state regulatory commissions. Pursuant to Michigan state law, the request has also been made with the Michigan Public Service Commission and if approved, will be effective as of June 30, 2020. You may submit comments to the Commission via mail to the Executive Business Section, Michigan Public Service Commission, P.O. Box 30221, Lansing, MI 48909, referencing Docket No. U-20714. Electronic comments may be emailed to: mpscedockets@michigan.gov. All comments submitted to the Commission in this matter will become public information, posted on the Commission's website, and subject to disclosure. Comments should not include information a customer wishes to remain private. You are receiving this notice because you currently subscribe to one or more of the following services provided by Broadwing Communications, LLC, which, subject to regulatory approval, will be discontinued as a result of this project. • Local Trunking Business Line Service including POTS (Plain Old Telephone Service) voice-grade telephonic communications channels that are used to place or receive one call at a time. • Local Trunking PRI (Primary Rate Interface) transmits and receives video, voice and data simultaneously. • Local Trunking Local Inbound originates calls to CenturyLink provided telephone numbers, aggregate the traffic, and hands it off to single or multiple IP endpoints. • Local Trunking SIP (Session Initiation Protocol) send and receive calls via the Internet. • Local Trunking ELS (Enhanced Local Services) originates and terminates calls to and from CenturyLink provided telephone numbers, aggregates the traffic, and hands it off to single or multiple endpoints. • LD Outbound traditional long distance 1+ or direct dialed domestic and international (U.S. origination) calling services provided over switched or dedicated facilities. • LD Toll Free and Contact Center traditional long distance toll-free or 800 services, domestic and international (U.S. termination) calling services provided over switched or dedicated facilities. • Integrated Voice and Data Service (IVAD) allows a customer to utilize a single high capacity facility to integrate both voice and data services. IVAD service is available in different groups of channels and at varying bandwidth speeds.

In order to maintain continuous service at your location, CenturyLink would like to work with you to migrate your existing service to a similar service or, alternatively, a state-of-the-art platform that will provide your business with greater flexibility, simplicity, and efficiency. You should initiate a migration order or submit a disconnect request with CenturyLink by June 30, 2020 to avoid possible disruption of your service on June 30, 2020. Existing contracts for these services will not be renewed. Customers with a contract that expires prior to June 30, 2020 may retain their service(s) covered by that contract on a month-to-month basis until June 30, 2020. Our Voice Advancement Team is here to help you through the migration or disconnect process. Contact them at 877-699-3201 or voiceadvancement@centurylink.com. If you subscribe to other services from CenturyLink, those services will NOT be impacted by the anticipated discontinuance of the affected services listed above. Your other services will remain in place with no change to the applicable rates, terms, or conditions. When the telecommunication services are discontinued, the Company will automatically apply any credits for the service to your CenturyLink invoice. We value your business and appreciate your cooperation regarding this notice. Thank you, Broadwing Communications, LLC 877-699-3201