Claverack Communications, LLC will adhere to the Pennsylvania Public Utility Commission’s (PUC or Commission) regulations regarding customer complaint procedures. 

Telephone Service (52 Pa Code Chapter 63)

A. Changing Local Service Providers

1. CLAVERACK COMMUNICATIONS will abide by the dispute procedures set forth in 52 Pa. Code § 63.221, et seq.
2. CLAVERACK COMMUNICATIONS shall preserve written or recorded complaints showing the name and address of the applicant or complainant, the date and character of the complaint, the action taken, and the date of final disposition.  Records of complaints for residential customers shall be kept pursuant to 52 Pa. Code § 64.192 (relating to record maintenance).
3. If a customer or applicant expresses dissatisfaction with CLAVERACK COMMUNICATIONS’ decision or explanation, then CLAVERACK COMMUNICATIONS will inform the customer or applicant of the right to have the dispute considered and reviewed by the PUC and shall provide the name and contact information of the appropriate PUC bureau. 
4. If the PUC refers a complaint from an applicant, customer, or third party, CLAVERACK COMMUNICATIONS will work with the PUC to process and resolve the complaint. 

B. General Service Complaint Procedures

1. CLAVERACK COMMUNICATIONS will abide by the complaint procedures set forth in 52 Pa. Code § 63.15.
2. CLAVERACK COMMUNICATIONS will make a full and prompt investigation of service complaints made to it via the PUC or directly by customers or third parties.  If a service complaint is resolved, then CLAVERACK COMMUNICATIONS will terminate the investigation by submitting or transmitting a copy of the service order which identified the action taken by CLAVERACK COMMUNICATIONS to resolve the service complaint.  In the event that the PUC refers a complaint to CLAVERACK COMMUNICATIONS, we will work with the PUC to process and resolve all complaints.
3. CLAVERACK COMMUNICATIONS will preserve written or recorded service complaints showing the name and address of the subscriber or complainant, the date and character of the complaint, the action taken, and the date of final disposition.  Records of complaints will be kept in accordance with 52 Pa. Code § 64.192 (relating to record maintenance) and 52 Pa. Code § 63.22 (relating to service records, generally). 
4. If a customer or applicant expresses dissatisfaction with CLAVERACK COMMUNICATIONS’ decision or explanation, then CLAVERACK COMMUNICATIONS will inform the customer or applicant of the right to have the dispute considered and reviewed by the PUC and shall provide the name and contact information of the appropriate PUC bureau. 

C. Extended Area Service (EAS) Complaints

1. CLAVERACK COMMUNICATIONS is aware of the provision regarding formal complaints seeking implementation of EAS, and CLAVERACK COMMUNICATIONS will abide by this provision as necessary. 
   CLAVERACK COMMUNICATIONS will consider the criteria set forth in 52 Pa. Code § 63.77 in evaluating EAS complaints.

D. Directories

1. Pursuant to 52 Pa. Code § 63.21(e), if CLAVERACK COMMUNICATIONS revises a directory and a customer files a complaint alleging that it is misleading, deceptive, or confusing, then CLAVERACK COMMUNICATIONS will investigate the complaint, and if it determines that the director is misleading, deceptive, or confusing, then CLAVERACK COMMUNICATIONS will delete the listing from future directories.  After reaching a decision, CLAVERACK COMMUNICATIONS will advise interested parties in writing of its opinion and shall inform them of the right to file a complaint with the PUC. 

E. Automatic Dialing Announcing Devices (ADADs)

1. Upon receiving a complaint in which the complainant can identify the ADAD user, CLAVERACK COMMUNICATIONS will abide by the procedures set forth in 52 Pa. Code § 63.60.

Billing Disputes for Residential Telephone Service (52 Pa. Code Chapter 64)

A. Disputes

1. If a customer registers a dispute, CLAVERACK COMMUNICATIONS will follow the processes for investigating and reviewing the matter as set forth in 52 Pa. Code §§ 64.131-64.142.

B. Informal Complaint Procedures

1. In the event of a billing dispute, CLAVERACK COMMUNICATIONS will work with the PUC and the complainant to review and address the issue.  CLAVERACK COMMUNICATIONS will follow the procedures set forth in 52 Pa. Code § 64.151-64.154.
2. In the event of a billing dispute, if a customer files an informal complaint with the PUC, CLAVERACK COMMUNICATIONS agrees that it will not suspend or terminate service based on the complainant’s nonpayment of any billed amount which is contested in the informal complaint until the complaint is resolved.  Similarly, CLAVERACK COMMUNICATIONS will not suspend or terminate service based on complainant’s nonpayment of additional billed amounts that reflect the same underlying disputed problem, other than a claimed inability to pay, as the billed amounts contested in the informal complaint. 
3. This limited stay does not prevent CLAVERACK COMMUNICATIONS from suspending or terminating service based on the complainant’s nonpayment of other billed amounts, where suspension or termination is otherwise permitted under Title 52, Part I, Subpart C, Chapter 64 of the Pennsylvania Administrative Code.

C. Formal Complaint Procedures

1. Should a customer, applicant, or third party file a complaint against CLAVERACK COMMUNICATIONS, we will abide by the PUC’s rules of practice and procedure in to review and litigate the claim.  CLAVERACK COMMUNICATIONS will also abide by 52 Pa. Code § 64.161-64.163.
2. CLAVERACK COMMUNICATIONS also agrees that it will abide by the restrictions against suspending and terminating service stated in 52 Pa. Code § 64.161(b).

D. Public Information and Record Maintenance

1. CLAVERACK COMMUNICATIONS will maintain records and public information in accordance with 52 Pa. Code § 64.191-64.192.

E. Contents of CLAVERACK COMMUNICATIONS’ Dispute Summaries

1. In the event of a dispute, CLAVERACK COMMUNICATIONS’ written report of the dispute will abide by 52 Pa. Code § 64.142 and include: a statement of the dispute or claim and a copy thereof if it was made in writing; the position of CLAVERACK COMMUNICATIONS and the results of the investigation; an itemized statement of the account specifying amounts credited or due as a result of the disputed subject matter; contact information at CLAVERACK COMMUNICATIONS where payment can be made or information obtained; a statement that service will not be suspended pending completion of the dispute process so long as the customer (1) pays all undisputed amounts and (2) files an informal complaint with the PUC within 10 days of the date on which CLAVERACK COMMUNICATIONS mails the written summary to the customer; a complete explanation of the procedures for filing an informal complaint with the PUC; and the date on or after which the account will be delinquent unless a payment agreement is entered into or an informal complaint is filed with the PUC (the date will not be earlier than the original due date of the bill or 10 days after the mailing or personal delivery of the written summary, whichever is later).  

F. Duties of Parties Regarding Undisputed Portion of Bills and Interest on Overpayment

1. CLAVERACK COMMUNICATIONS will follow the PUC’s provisions regarding undisputed portions of bills and interest on overpaid bills as written in 52 Pa. Code § 64.171.

G. Procedures Upon Customer Contact Before Suspension

1. CLAVERACK COMMUNICATIONS agrees to follow the procedures for notifying customers prior to suspension as contained in 52 Pa. Code §§ 64.73-64.74.

H. Allegations of “Cramming” or “Slamming”

In the event that a customer alleges that unauthorized charges are added to their bill (“cramming”), CLAVERACK COMMUNICATIONS will abide by the PUC’s procedures for reviewing and resolving such allegations under 52 Pa. Code § 64.23(a). 

In the event that a customer alleges that unauthorized charges are added to their long-distance carrier (“slamming”), CLAVERACK COMMUNICATIONS will abide by the PUC’s procedures for reviewing and resolving such allegations under 52 Pa. Code § 64.23(b).

I. Credit and Deposit Standards Policy

1. CLAVERACK COMMUNICATIONS agrees to abide by the notification procedures set forth in 52 Pa. Code § 64.35 regarding delinquent accounts.