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Date:` ` May 29, 1997 0*     X` hp x (#%'0*,.8135@8:0*H&H&@@Ԍ` `  MR. FONTEIX: There you go. It has been awhile since we have had an analogy to baseball. ` `  MS. HAM: Two of those states were within our five state region, and they were arbitrated. The two Commissions that ruled ruled that the quality of service measurements that we currently provide at least now are sufficient, but that does not, as we have said all along, close the door to future negotiations. ` `  MR. WELCH: Stuart? ` `  MR. KUPINSKY: I think it is important to point out where we are in the baseball game again. I think as more and more challenges to parity or a meaningful opportunity or the manner in which resale services and unbundled elements are provided come down the pipe, it is inevitable that a more comprehensive set of performance measures are going to have to be established. ` `  This is the only way of determining these parity issues. It is I think just a matter of time and not whether or not we will ever have these. ` `  MR. WELCH: Pat? ` `  MR. SOCCI: Wayne made a good point. We cannot just look at comparisons of the ILEC and CLEC intervals. That is not sufficient. I think we need to also look at the resale unit of the ILEC versus the main body of the ILEC as it serves its own customers.%?0*H&H&@@Ԍ` `  Also, remember that we are always talking about competition. There is a customer involved in competition, so I think we need to look at what our internal measurement is, customer concurred due date. What date does the customer want it? What date did the customer actually get it? ` `  That is the ultimate test, and I think that is the date we need to look at as to how the CLEC provides the service and the ILEC, not just intervals. How many times did we hit the target for the customer because the customer is part of the competition formula. ` `  MR. WELCH: On a somewhat related note, Pat, if I could follow up, when a competing carrier is taking elements from the incumbent, and, of course, obviously the incumbent does not provide elements to itself so you have a breakdown in this measurement of parity, what should be the proper basis of comparison for performance in that type of situation? Do you have any thoughts on that? ` `  MR. SOCCI: We are talking about ordering. Certainly, you know, when are the firm order commitments made? When are the products received? When are the circuits tested? Is there capacity available? If capacity is available, is it made available to the CLECs the same way it is made available to the ILEC for internal purposes? ` `  Those I think are the important things. We could%@0*H&H&@@ talk about maintenance and repair, but that is for other discussions later today. It is the availability of those services for the CLEC as measured against its availability for the ILEC itself. ` `  MR. WELCH: John? ` `  MR. LENAHAN: In our case, in those situations where there is not a comparable to the retail side of the basis, for example, unbundled loops, each of our interconnection agreements has a specific performance interval; five days if it is more than ten loops, ten days if it is ten to 20 loops. ` `  Those vary depending on the CLEC, and typically there are liquidated damage provisions if that interval, that specific interval, is not met. ` `  In those cases where there is no retail comparable, I think it is important that the interconnection agreement define the expected performance target. ` `  MS. HAM: We are in the same situation with liquidated damages. ` `  MR. FONTEIX: I would like to just offer one other relevant comparison, and that is in the case of purchase of a combined loop and unbundled switch where there is no actual physical work involved in cross connecting or pulling apart elements that are already in combination. Clearly it is not a physical change. It is a software change, and I%A0*H&H&@@ believe there are relevant comparisons within the existing retail operations. ` `  MR. WELCH: Well, one of the great things about baseball is that there is no clock. It is just whoever has the most runs at the end of the game. Unfortunately, we have a clock. ` `  The time on this panel has gone by very fast because I think it was terrific. We got a lot of interesting discussion back and forth. I would like to thank our panelists, Venkates Swaminathan, Pat Socci, Wayne Fonteix, Elizabeth Ham, John Lenahan, Charlotte TerKeurst and Stuart Kupinsky. Thank you very much. ` `  (Applause.) ` `  MR. WELCH: We will take a 15 minute break and start back up promptly at 11:45 a.m. ` `  (Whereupon, a short recess was taken.) // // // // // // // // //%B0*H&H&@@ ` `  MR. WELCH: Let's go ahead and get started with our second panel today, which will focus on issues involving billing. We have four panelists here. Going from right to left, we have Beth Lawson from Southwestern Bell. Beth is area manager of finance operations. Sitting next to Beth is Mary Berube from Southern New England Telephone Company. She is senior project manager and network marketing and sales. ` `  Next to Mary is Robert Falcone with AT&T. He is district manager of new market development, and finally, on the far left, we have Dennis Perkins. Dennis is with Brooks Fiber. He is vice president and corporate controller. ` `  So, this panel will focus in on billing issues and we will proceed as we have before, with brief opening statements from the four panelists, so why don't we start with Beth, if we could, please? 8)PANEL II ` `  MS. LAWSON: Good morning, I'm Beth Lawson from Southwestern Bell Telephone. Billing involves the exchange of information necessary for CLECs to bill their end users and also to process their end users claims and adjustments, and also to view Southwestern Bell's bills for services provided to the CLECs. Southwestern Bell provides multiple electronic options to receive billing data. We offer a product called Bill Plus, and this is essentially a paper%C0*H&H&@@ bill, has all the information that will be contained on the paper bill, and you can receive it via three different mechanisms. ` `  You can get a PC diskette, or you can have it downloaded to your computer system via modem, or we're getting ready to offer a new option in June of '97, which would be via a CDROM. This will include auxiliary information also included on there. ` `  With this Bill Plus, the CLECs can search for information on their bill, they can generate, standardize or customize reports using any data that appears on the bill, and they also can print any portion of the bill. Currently, we have over 650 retail business customers receiving their bills via bill plus, and this equates to over 25,000 accounts. ` `  We also offer a EDI 811 864. This is an industry standard ANSI XR12 electronic interphase. This enables the CLECs to receive data in an electronic format, from Southwestern Bell's CRIS database with the same information that would appear on their monthly resale bill. This also enables the CLECs to manipulate billing data without rekeying the data. It also generates reports involving the billing data, and also allows you to track your intraLATA calls and export data to the CLECs internal computer systems.%D0*H&H&@@Ԍ` `  Currently, we have 35 retail business customers receiving their bills, and this equates to over 30,000 accounts. ` `  We also offer a Bill Data Tape, BDT. This is available today to CLECs to receive data in electronic format from Southwestern Bell's CABS database with the same information that would appear on their paper bill for their unbundled network elements. ` `  We also offer Customer Network Administration, CNA. This is available today for on line access to obtain the same billing information for both resale and unbundled network elements that would appear on the CLECs paper bills. ` `  We also have introduced the usage extract feed. This provides the CLECs with daily information on usage that will be subsequently billed on their monthly bill, in the industry standard EMR format. This was implemented in December, 1996. We've sent several test files successfully to CLECs and we have two CLECs that are currently live receiving the usage extract feeds today. CLECs will have to complete the coding, though, to receive this usage data into their billing system, so that they can, in turn, rate and bill their end user customers. ` `  Southwestern Bell meets the requirements of the 1996 Act and complies with the FCC's order in terms of providing CLECs with at least minimum equivalent electronic%E0*H&H&@@ access to billing data that provides the same information that we provide to ourselves, our customers and carriers. Thank you. ` `  MS. BERUBE: Good morning. There are four major points I'd like to highlight regarding access to billing information. First, nondiscriminatory access to information, rather than to systems, will best meet select needs. ` `  Second, a single standard for billing format and media will not meet today's requirements and capabilities of all CLECs and ILECs. ` `  Third, if a CLEC requested billing functionality exceeds that which the ILEC provides for itself or its end users, CLECs should assume costs of development and implementation of that functionality. ` `  Finally, the quality, accuracy and timeliness of end user billing is the responsibility of the CLEC. ` `  On the first point, nondiscriminatory access to information rather than to the systems which store the information, will best meet CLEC needs. Over time, ILECs have developed large and complex systems to meet our customer and internal requirements. These systems collect, process, store, merge and distribute data to and from various other systems and process millions of transactions daily.%F0*H&H&@@Ԍ` `  It would be untimely, burdensome and expensive for even the largest and most sophisticated of carriers to directly access these billing systems, and for the smallest carriers, it would be impossible. It is the data within these systems that is critical to the CLECs, rather than direct access to the systems themselves. ` `  Basically, the major categories of data or information that the CLEC needs from the ILEC billing systems are billing detail for the services that the CLEC purchases from the ILEC, and, in a reseller environment, end user usage detail such as toll detail. ` `  Related to my second point, and, I think, a common theme in the discussions during the last few days, is that a single standard for the exchange of billing information will not meet the requirements and capabilities of all CLECs and ILECs. For example, only the largest CLECs operating in Connecticut can presently accommodate electronic transmission of billing information. The smaller CLECs continue to rely on traditional monthly paper bills. ` `  To mandate only an electronic standard discriminates against those CLECs who cannot at this time costjustify or implement electronic capabilities. ` `  As another example, many CLECs today in Connecticut cannot support and have not requested daily usage feeds. While daily usage feeds may provide more%G0*H&H&@@ timely data, some CLECs do not have the capability to accept and process this information. Out of the 19 certified CLECs in our territory, only two are currently using daily usage feeds. One was implemented approximately a year ago, and the other since the beginning of this year. ` `  Until the others have more fully defined the level of billing services they choose to provide their end users, this duality will continue to exist. ` `  To the third point, to meet the billing information needs of CLECs, an ILEC may be required to support new capabilities and functionalities which exceed what is currently available and provide it to itself and its end users. Costs will be incurred to meet these additional requirements. Consequently, CLECs must assume the costs to develop and implement these capabilities. This is also consistent with the FCC's definition of Unbundled Network Elements to include access to the OSS functions. ` `  Finally, the CLEC is responsible for the quality and accuracy of its end user billing. Since the CLEC has direct access to its customer information, with the possible exception of usage data, including the services which it orders for and provides to its end users, the CLEC has the best source of data for end user billing. The relationship for end user services exists between the CLEC and the customer, not between the customer and the ILEC.%H0*H&H&@@Ԍ` `  Thus, the CLECs should be accountable for the reconciliation of services provided to end users and not need to rely on the ILEC bill for that purpose. ` `  In closing and as discussed yesterday by the OBF representatives, much progress has been made and is being made in the industry to meet the billing needs and challenges of this new environment. As new competitive carriers gain experience providing local service, new billing requirements will be identified and appropriate cost recovery mechanisms will need to be established. ` `  In Connecticut, SNET and the CLECs are working hard to define and implement with state regulatory commission oversight, the best approaches to provide nondiscriminatory access to billing functionality. This work is an ongoing process, which should and will evolve as market forces dictate. Thank you. ` `  MR. WELCH: Thank you, Mary. Next we'll hear from Robert Falcone of AT&T. Robert? ` `  MR. FALCONE: Thank you, Richard. Billing is the most common and often the only way that local companies have to interface with their end users. End users today are accustomed to getting accurate bills from their incumbent local telephone company and simply will not tolerate inaccurate bills from CLECs. Therefore, it is absolutely critical that the incumbent billing operation support%I0*H&H&@@ systems support timely and accurate data to the new entrant for both resale services and unbundled elements, to allow the new entrant to bill their end users, IXCs for access and other local companies for reciprocal compensation. ` `  When a new entrant buys resale services, they need billing information from the incumbents' operational support systems, provided in electronic format, and meets three basic requirements. First, incumbents billing data must provide an accurate and complete record of the usage for the new, for the CLECs end users, both for their dialed usage and for any usage sensitive features that that CLEC customer may employ. ` `  Second, the incumbent must provide the usage data on a timely basis, based on agreed upon intervals, and third, the bill to the CLEC from the incumbent for the resale service, the discounted resale service, must be provided timely and accurately, both for the discounted service and for any appropriate nonrecurring charges. ` `  When a new entrant is buying unbundled elements from the incumbent LEC, they also need accurate and timely information, as I mentioned above, with resold services. However, billing for unbundled elements provides new challenges for the incumbent LEC in their operation support systems. Not only do they have to provide all the data that was mentioned above, but they have to develop their%J0*H&H&@@ operational support systems to allow them to bill for the unbundled elements that the CLEC is purchasing. This is particularly critical with elements such as the switch, which has both a flat rated component and a usage space component. ` `  These billing issues are further magnified, because a new entrant who buys unbundled switching not only needs the billing information I mentioned above from, with respect to resale, but they also need data to allow them to bill originating and terminating access to IXCs and the reciprocal compensation to the other LECs operating in the area. ` `  Although incumbents do not currently measure terminating access on a line by line basis, the data necessary to provide this information to CLECs is recorded in the switch and available. However, the incumbents' billing systems must be enhanced to allow them to cull out that information on a line by line basis, to provide the CLEC who is using an unbundled switch accurate access information, so that the CLEC can bill the IXCs the access that they're entitled to. ` `  In order not to preclude CLECs from purchasing unbundled switches until these billing enhancements come along, the CLECs must do two things to move the ball forward and allow us to buy unbundled switching and the platform,%K0*H&H&@@ until this enhancement to their billing systems is done. ` `  First, the incumbents must develop terminating access factors. These factors are needed to allocate determining access coming into the unbundled switch to determine what of that terminating access or how much of that terminating access the CLECs that are using that switch are entitled to. I think it's important to note that there's a history in the industry of using terminating originating factors dating back to divesture, when preequal access, the local companies could not bill terminating access at all. The capability was not there. They derived the terminating access from the originating usage, based on T to O ratios, until such time as the switches were enhanced to measure that terminating usage. ` `  Secondly, the incumbents must provide new entrants with carrier specific access usage information in a timely manner, so not only do we know how many terminating access minutes are we entitled to, we would know which of the IXCs operating in that area to bill those access minutes to, we, the CLECs. ` `  Again, appropriate hour assessed enhancements must be made, both to provide the short term solutions to allow us to move forward with purchase of the unbundled switch and get all the data that we need, and enhancements must refer them to allow for the long term solution to actually cull%L0*H&H&@@ out the line by line usage that is recorded in the switch and could be provided to the end user. Thank you very much. ` `  MR. WELCH: Thank you. ` `  Finally, we'll hear from Dennis Perkins from Brooks Fiber. Dennis? ` `  MR. PERKINS: The message I bring today is on the need for billing standards and interface standards. The telecommunication industry requires a significant amount of billing data to be passed between telephone companies. This data needs to be passed quickly and in a standard electronic format. As we work to establish our billing processes and the required data exchanges with the various RBOCs, it has highlighted the need for a fresh look at the current processes and standardization. ` `  Many standards do exist today, while many others need to be addressed. A standardization of interfaces needs to includes processes, data formats and required data elements that are necessary to insure accurate and timely billing information. ` `  As a new entrant in providing local exchange services, Brooks must set up interfaces with the RBOCs. Setting up the various required interfaces with one RBOC is difficult, and this is multiplied when dealing with multiple RBOCs. Brooks has had to work the same type issues with each RBOC on a one item at a time basis. In turn, this%M0*H&H&@@ makes the process more costly, as well as time consuming. ` `  In addition, each new entrant is faced with conforming to the existing RBOC systems in each region. In working with each RBOC, we hear statements like, this is how we do it in our region. In setting up our operations, we are required to conform to the unique and different practices in each region. This places a burden on the new entrant to expend resources and conform to each region. ` `  Some of the interfaces have not been previously done, and many interfaces and processes are being developed as they are encountered. In the absence of standards, these processes take on an individual life of their own. ` `  I have several examples that illustrate billing interface differences that we have encountered. My purpose in reviewing these is to highlight the need for performance and interface standards. For instance, when it is necessary to exchange clearing house records with Southwestern Bell, we must exchange records in EMR format as category 92 records. With Bell South, we use a different EMR format. ` `  Another area that has different interface requirements is IntraLATA toll access. For example, in New Mexico and Arizona, we must set up an interface with the originating responsibility plan to receive compensation for IntraLATA toll access. Other areas do not have an ORP process, and require different interphases.%N0*H&H&@@Ԍ` `  The next example deals with local access record exchange. There are not standards in the industry for format, data substantiation requirements or billing formats. In working with each RBOC, we are establishing the process and reporting requirements to bill each other for local access. A lack of standardization will lead to many disputes in this area. ` `  In the area of carrier access billing, some of the general requirements are the same between RBOCs, but each has a separate and different process. ` `  Another interface is billing and information for unbundled network elements. There is a need for standardization and providing of electronic data. These invoices are sometimes created electronic format and sometimes paper format. In many cases, the RBOCs have not yet identified how the information will be made available, for billing of certain network elements and electronic bill providing in a CABs format and other bills are sent in a paper format. ` `  At U.S. West, they will supply a paper bill or an EDI version, but in a CRIS format. Like I said, others to be determined. ` `  The last example I want to mention has to do with an electronic data exchange request with Ameritech. For alternatively billed calls to reported numbers, Ameritech%O0*H&H&@@ only supplies this information to Brooks on a paper bill. An electronic version of this information is not available. By only receiving the message detail on paper, Brooks does not have an electronic means to bill the end user. Without the electronic information, Brooks incurs expenses from Ameritech and sustains lost revenues from the lack of Brooks being able to bill these calls to its end user. ` `  In summary, these interfaces can be complex and they are made more complex by having multiple processes to accomplish the same task. The point that I want to make is that without performance and interface standardization, including processes, data formats, data requirements, an entry of competition will be slower and more expensive. Thanks. ` `  MR. WELCH: Thank you. Now we'll move to the question and answer session, and I'm going to turn to Kalpak Gude to take the lead in asking the questions. ` `  MR. GUDE: First, I want to direct the opening question to Beth. What processes are being or should be used to transmit billing information to competitors? I think you mentioned that briefly in your opening. Also, could you talk a little bit about whether these systems are fully tested and to some extent, how they were tested? ` `  MS. LAWSON: With regard to the billing information for resale, with our CRIS Resale 811, this has%P0*H&H&@@ been in existence for a number of years, and we have live customers receiving over 30,000 accounts currently today. So, we are in a live mode with this. This was something that we used in our retail business operations and the type of billing information for resale is the same products and services that we would sell in our retail operations. So, as far as resale, that was already in existence. ` `  With regard to Unbundled Network Elements, that was introduced as a feature group, you and our CABS billing system, so we utilized a local CABS bill data tape, which is similar to what they do in the access world, except it would be an access bill data tape. So, it's the same type of electronic format with a current CABS version that's been implemented. ` `  With regard to Bill Plus, that is a PC diskette and that is a proprietary system that we actually customize programming ourselves, so that we can provide the data so you wouldn't have to do any programming yourself, and provide standardized reports, but you can also do ad hoc reports if you would like. ` `  With regard to the usage extract, which is the new area that's been added, that is in standard EMR industry format that's been agreed to by OBF. ` `  MR. WELCH: From Mary, could we hear the response to that?%Q0*H&H&@@Ԍ` `  MS. BERUBE: Sure. Currently, we are providing on the resale side billing out of our CRIS system. For, as I mentioned earlier, for two of our customers, we're providing electronic via an NDM protocol, electronic transmission of billing detail data that more fully or finer point of granularity of the billing detail that's on the paper bill. ` `  For the remaining, it's paper bill. We are currently evaluating electronic means, however, we have not had specific requests from other CLECs at this point for electronic means, so our intention is to do our internal evaluation, and then propose to our CLECs some of the ideas that we've come up with. ` `  In terms of Unbundled Network Elements, it is our intention to provide those through CABS, so for those carriers with whom we have existing NDM transmissions for CABS billing data, that will continue. For others, we will need to have those discussions when they order those services from us on the transmission means that they intend to use. ` `  Daily usage feed is an NDM feed again in EMR standard format, for those customers who are presently availing themselves of that offering. ` `  MR. WELCH: Dennis earlier mentioned in his opening the problems with developing different systems to deal with different incumbents. %R0*H&H&@@Ԍ` `  As national standards are developed in the billing area, do you have plans to move towards the implementation of national standards? ` `  MS. BERUBE: I think it depends, in fact, what the national standards are and the services that are supported by those national standards. Certainly in the Unbundled Network Element area, those have been discussed at the OBF, data elements have been identified and the formats that are currently in place seem to fit those needs. ` `  In terms of resale, there is definitely a divergence of opinion by the industry where and how to best bill, out of what systems and how to best bill for those services. While, in the OBF, there are guidelines which have developed that identify the data elements, the systems that provide that information have been in question and we will continue to evaluate, based on our capability and our assessment of our customers' needs, the appropriate systems from which to bill those services. ` `  MS. LAWSON: Can I oh, what I was going to say was respond as far as with resale, the EDI that's being proposed in the ordering world as an industry standard, the 811 transactions that have been out there, it's been utilized, it is an industry standard. So, from Southwestern Bell's perspective, there is a standard that is available and can be utilized by any ILEC that and a lot of them do%S0*H&H&@@ go ahead and offer CRIS resale to their business customers, and they can make that option available, as well, to the CLECs. That way, the CLECs would be able to receive an industry standard, same format, for any type of billing. ` `  With regard to usage, that has been pretty well defined, that OBF with the EMR, and the unbundling, I think that's being further defined as they get into some of the component pieces, as the local switching and other unbundled elements get a little better definition. ` `  MR. GUDE: Bob? ` `  MR. FALCONE: Yes, Kalpak, thank you. I agree with my fellow panelists with respect to resale. There are interfaces established today. ` `  However, one of the problems, unless those interfaces are enhanced, if they're using their current retail model, there is a restriction on how many accounts you could put on the same billing account or how many lines you could put on the same billing account. So, what we're finding ourselves in, often, is a situation in resale of having multiple billing accounts to get our bills, because there's a max. So, I think there's some enhancement work that needs to be done to the retail biller to expand that, so we get one bill for our usage. ` `  With respect to unbundled elements, I also agree that CABS is the method of choice for us to receive our bill%T0*H&H&@@ for the elements and I think we only heard of one half of that unbundled element equation, though, and that's the bill to us for the use of the element. Where I think there's the major void is, as I mentioned in my opening remarks, is how do we get all the usage that we need from the unbundled elements, so that we can turn around and generate the bills that we have to generate as a CLEC operating in that area, specifically access, reciprocal compensation and user billing? I think that's a major void right now. ` `  MS. LAWSON: I would agree with what my panelist also said, as far as a void. Southwestern Bell has discussed looking at putting new, deploying new software in their switches that will provide the type of information that is being discussed. It's just a matter of timing to get funding for that software and then getting it deployed in the switch and identifying how the unbundled local switching product would be defined. I agree with moving there. ` `  And, with regard to the other comment, as far as number of bills, AT&T didn't mention Southwestern Bell, but I know that was very near and dear, based on some previous discussions we've had. We do agree that we need to look at the number of bills that we are issuing, because in a retail world, you do issue them to end users. When you get into a wholesale world, you need to look at summarizing those up%U0*H&H&@@ and offering fewer number of bills. We have agreed to look at what type of options, depending on the type of data that CLECs would be willing to receive. ` `  In other words, you could get your bill at one point and get the subsequent billing data at a different point, so that it could be aggregated, so that your bill would be at one time during the month, but your billing data could be spread out throughout the month, so you could get it that way. ` `  MS. BERUBE: I think from our perspective, we are also looking to add more flexibility to our current systems. As I mentioned earlier, there are many systems involved in billing. They're large, they're complex, they've been developed over a long period of time. ` `  If we had the resources and the opportunity and could make it happen tomorrow, possibly we would replace everything we have with something better and greater. However, that's not the case, and especially for a company of our size. We certainly cannot afford to do so. So, we are continuing to look at building flexibility into the systems that will accommodate the new customer environment, and working with the customers on short term and long term solutions to get there. ` `  MR. FALCONE: I was simply going to say that I purposely didn't implicate Southwest Bell, because if you%V0*H&H&@@ believe the newspaper articles that you're reading, I may be working for them soon. ` `  (Laughter.) ` `  MR. WELCH: I was going to comment on the last panel and I bit my tongue, but somehow, inadvertently, we had the Southwestern Bell and the AT&T people in the last panel sitting side by side and I wanted everybody to know that was completely inadvertent. ` `  (Laughter.) ` `  MR. GUDE: This one is directed towards you, Dennis. There's been a lot of talk about standardization in formats. What are the formats or standards you see industry moving towards or will continue to have, or will we continue to have multiple formats in the future? ` `  MR. PERKINS: Well, I hope we don't have multiple formats. There are a lot of standard out there today that exist. I mean, we've had mention of EMR formats, and I think that's a fairly standard format. But, the application of some of those standard formats are different between companies, which makes it difficult to program the different nuances of those into an existing system, when you're trying to do a national application. ` `  So, I believe there are formats out there that we can use. There are also systems that we can use to transmit data back and forth. We have NDM systems set up and CMDS%W0*H&H&@@ systems set up to transmit data throughout the country, between the different telephone companies. So, I see that there are things out there, in the exchange of records, messages for telephone billing, but there are some other issues that have been mentioned with the unbundled loop elements, and those that haven't been. ` `  There are also areas of just this week, I was asked by Southwestern Bell to provide two official company numbers, one for resell, one for our facility based operations. And, by having two in each state that we do business, that will make it confusing, as to which one people should use to put the operations and the transactions for Brooks, and to identify those. ` `  So, we're trying to develop systems around existing legacy systems that will cause problems when we exchange data. ` `  MS. BERUBE: If I could, I'd like make a comment on that. Dennis, I agree with you that across the country, different companies have implemented the billing functionality somewhat differently. ` `  I think, however, that is going to be the nature of the beast on the going forward basis. Although the names of the products and services that we will offer to CLECs might be the same, the terms and conditions under which they're offered and the specific tariff requirements may be%X0*H&H&@@ different, and that oftentimes drives the billing. ` `  So, to the extent that there might be a different term and condition or different pricing arrangements for certain services, the billing for those will be different from company to company, and I'm not sure how that can be avoided, quite honestly. ` `  MS. LAWSON: I might add to that, I know you mentioned earlier about the clearinghouse, some of those relationships like were mentioned with tariffs, also impact the independent companies that you're operating with and sharing records, so some of those types of relationships drive what type of record types get provided in the clearinghouses between the BOCs and the independents, so those can also impact. ` `  MR. GUDE: This is a question for Bob. In situations where the incumbent does not have sufficient billing information for exchange access, how do you propose to bill or how do you propose that they bill for exchange access when purchasing the unbundled local switching element? I think what I'm looking for is sort of a further explanation of the factor based approach that you mentioned earlier, and I would like the other panelists to comment on that approach, as well. ` `  MR. FALCONE: Before I go into the detail, which I certainly will, I want to stress that I believe the factor%Y0*H&H&@@ approach is an interim approach, subject to true up. So, the one thing that's important to note is that all the information is available. It's just that the billing systems that the incumbents have today never were required to cull out on a line by line basis which terminating access went to which line. It was just terminating access from an IXC and it got billed en masse. Now, there's a need to do that, and further downstream, the long term solution is to have further downstream systems, sort of do that line by line comparison and get the usage into the right pie. ` `  Until that happens, my proposal is the use of a terminating to originating ratio and how that would work is, you would, the incumbent elect knows that an end office level, the IXC, in aggregate, T to O ratio, is, they know the total originating usage for all IXCs on that end office. They know all the terminating usage and based on that, they can develop a ratio of whatever that is. That ratio would probably go out to five decimal places. You know, it might be .98763, but let's just say for argument's sake, it's .99, just to make it easy. ` `  So, that .99 means that for every hundred originating IXC calls in that end office, there is 99 terminating. So, now what would happen is, my total originating usage, me, as a CLEC, that 99 would be applied to my total originating access usage, and that's how we'd%Z0*H&H&@@ derive my total, a bucket of what I'm entitled to bill for terminating, cause under the assumption that my end users in that end office are mirroring the profile of that end office. ` `  So, if I originated 1,000 IXC minutes, my customers originated 1,000 IXC minutes, I would be able to bill terminating usage for 99 percent of that thousand. Then, how you would allocate that 99 percent amongst all the IXCs, because now I know how many minutes I'm entitled to, now I have to know who to bill them to, it would be a simple ratio of all the IXCs that operate on that switch, let's say there's five, what percent of their terminating traffic? ` `  So, if AT&T as an IXC terminates 50 percent of the traffic into that switch, I'm entitled to bill AT&T 50 percent of my bucket of terminating minutes, and if MCI was 30 percent, I'm entitled to bill MCI 30 percent and so on, so it would kind of be two ratios, one the T to O and then one based on the percent of IXCs operating in that switch for terminating traffic. ` `  MS. LAWSON: Southwestern Bell's current policy is that on resale lines, that the access is Southwestern Bell's revenue, so they therefore did not see a need to provide access records to the CLECs, because they have no need to receive them, since the revenue is Southwestern Bell's. However, if that policy does change and if we did lose it in%[0*H&H&@@ arbitration, we had talked about the factoring. The situation that you get in with doing factors in the access world, when this was done is, you get billing disputes, because it's not actual information. ` `  So, I'm developing a factor based on something that I think happened, but it's not an actual occurrence. So, when you develop factors, you do set yourself up that it's not what actually happened and there can be, oh, I really don't think I had 50 percent or I don't think I had 80 percent, are you sure your switch recorded it? ` `  So, we would prefer, if we did look at giving access records at some point in the future, to have that available coming off the switch, to identify which CLECs' record that was, so that we wouldn't get into a factoring position. ` `  MR. GUDE: Just one follow up. That was your position on resale, but what about the unbundled switch from the unbundled platform? ` `  MS. LAWSON: It is the same, too. ` `  MR. GUDE: That it is SBC's position that SBC holds the ` `  MS. LAWSON: The access revenue, correct. ` `  MR. GUDE: SNET's position? ` `  MS. BERUBE: On resale, we agree with SBC. In terms of switching at this point, we don't have our full%\0*H&H&@@ policy established. We don't have unbundled switching yet available. That is going to happen in third, fourth quarter this year, so we will roll out the whole product and at that point, make those decisions. ` `  MR. GUDE: Bob? ` `  MR. FALCONE: With respect to Beth's concern regarding, first of all, to her first concern, I don't agree with her at all on policy, but we won't even get into that. ` `  MS. LAWSON: We don't have to discuss that, right? ` `  (Laughter.) ` `  MR. FALCONE: Right, we won't go to that movie here. With respect to the second issue, I agree. As I said, there is a history here, and that history was kind of ugly. Factors do lead to billing disputes, no argument there. ` `  I think it's real important to stress this factor proposal is a short term, interim solution, because the data that's needed to give us the actual usage is there. It's just like, it's there, but you don't know how to extract it, and the proposal is that as soon as you develop the downstream system to extract that data, you go back and do it even on those records that we had factors, that we used factors for, and we true up those bills based on actual usage. ` `  So, Bell Atlantic, for example, has said to us%]0*H&H&@@ that they are developing this extraction means and they will have it available by August. So, that's great, and perhaps we won't even be in business with unbundled switching in Bell Atlantic territory until then, so we won't have to use these factors with Bell Atlantic. ` `  But, to the extent that some other company can't develop what Bell Atlantic has developed in time for us to use the unbundled switch, all I'm proposing is these factors be used until such time as they do. ` `  MS. BERUBE: One thing that I may add to the extent that companies do not currently have available to them this data, and have to go to large expense to implement the recording capability for that data, we have a cost recovery issue, as well, and that obviously remains to be determined as to what that mechanism will be, but I would propose that those costs need to be recovered. ` `  MR. GUDE: Dennis? ` `  MR. PERKINS: On our access recordings, what we've been doing is working with a switch vendor to work a way to record those minutes that are switched, the terminating minutes. In certain cases where they're not, we're exchanging originating minute information with the local ILEC to, for looking at the access billings. ` `  But, we are working with the switch vendors to look at, can we record those terminating minutes.%^0*H&H&@@Ԍ` `  MR. GUDE: Bob? ` `  MR. FALCONE: To Mary's concern, the industry standard for recording terminating access in the switch requires that you record the originating number, the terminating number, the carrier ID, so, again, the point is, the information is there. As long as Southern New England Telephone or any incumbent LEC is following the industry standard for recording terminating access records, the information is there. The incumbent LEC never needed all that information to bill the IXCs, the access, because it was billed in aggregate, but now they do need it, so that they could separate out what piece of that a CLEC is entitled to, as opposed to they're entitled to. That's where there may be some cost recovery, is whatever needs to be developed to separate that out. ` `  MR. GUDE: To Dennis, could you explain how originating and terminating access is billed when you purchase an unbundled loop and number portability? ` `  MR. PERKINS: That has had several disputes around developing formulas to capture those minutes with the interim number of portability. We have worked with historical data, looking at the originating and terminating minutes, and used that as a factor, and tried to identify the minutes that are particularly associated with the interim number of portability type calls, and used that, in%_0*H&H&@@ certain cases. ` `  In certain cases, we're still under negotiations on those terms, so we haven't come to a resolution on how to identify that access. But, we talked about in certain cases using our data or historical data to identify the types of calls that are coming through the switches. ` `  MR. GUDE: Would anybody else like to comment? ` `  MS. LAWSON: With our unbundled local switching right now our billing or our pricing is based on originating minutes, it is not based on terminating minutes, at all. Because as I mentioned earlier, we're looking at new software that will be deployed in the switch, so right now, the billing is based on originating minutes only for local switching. ` `  MS. BERUBE: Specific to number portability in our tariff, we use what SNET has for the past year measured for an average access minute, and we use that factor and that's specified in our tariffs. ` `  MR. GUDE: I think at this time we could open it up to questions from the audience. ` `  MR. WELCH: Please state your name and who you're with and direct your question. ` `  MR. MARLIN: Dave Marlin, LCI. Although I'd love to get into access charges, we haven't got enough time in the world. Directing it towards daily usage files and,%`0*H&H&@@ well, specifically, daily usage files, right now, with probably the worst delivery we get is, I think 15 percent of the calls in any one daily usage file are three days late, another 30 percent is four days late, another 20 percent is five days late, etc. ` `  We probably don't get the usage for any one date until about seven days after that particular cut off. Let's say our billing cut offs the end of the month. We have to wait seven days to get 90 percent of the data from a BOC for that day, so we can start billing. We aren't dealing with you right now, but I wonder, what are your service levels for delivering daily usage to the CLECs? ` `  MS. BERUBE: I don't have exact figures, but our standard is 95 percent within 24 hours. ` `  MS. LAWSON: What our price currently is is whatever comes into our CRIS billing system, or it would be our CABS billing system in the, for Unbundled Network Elements. When that usage is brought into that night's cycle, it is passed to the usage extract feed and that is available in that nightly usage excerpt feed that is available between midnight and 1 a.m. ` `  So, as soon as our billing system has it, your usage extract feed has it, just past that. Now, the only reason there would be a delay is if we were receiving it, like an incollect from someone else or an alternatively%a0*H&H&@@ billed call. But, we wouldn't have it in our billing system, as well, either. So, as soon as our billing system gets it, it goes in that nightly feed. ` `  MS. BERUBE: Right, since these systems are basically processed in a batch load to the extent that a call was made, just about the time that the recordings were dumped off to the usage feeds, you wouldn't see that the next day, but generally, when we have same thing with Southwest Bell, when we have it, you get it. ` `  MR. MARLIN: Okay, and in terms of the monthly you do send CABS and CRIS files monthly? ` `  MS. LAWSON: The usage, right. ` `  MR. MARLIN: When do those get to the CLECs? ` `  MS. LAWSON: It's between the midnight and the 1 a.m., the usage extract feed for any usage that's billed on the CABS bill or the CRIS bill will be included in the daily feeds. ` `  MR. MARLIN: Our experience has been with other RBOCs that it's been a long time, and we there's nothing that angers a customer more than getting service charges and call charges two months later. ` `  MS. BERUBE: And, on usage, I would agree with you 100 percent, which is why we recommend daily usage feed, so that data is timely. To the extent that some CLECs don't have the capability to process that information, that's%b0*H&H&@@ another issue. ` `  However, with nonrecurring charges and monthly charges, as I mentioned earlier, the CLEC is in control of the services that it provides to its end users and knows what it needs to charge for those services. There need be no reliance on the monthly bill that the ILEC sends for the services. The CLEC purchases from the ILEC, in order to do end user billing for those services. ` `  MR. MARLIN: Let me understand, then. Then, you mean the CLEC has all of the USOC charges and other service charges that you would provide for the CLEC? ` `  MS. BERUBE: No, I'm sorry, I mean that the CLEC is the one who is actually providing the services to the customer, and I'm assuming the CLEC has filed tariffs in its appropriate territories that define what those services are. The CLEC can therefore bill the end user for those services, because it knows what it's providing to its customer, and that is really independent of the services that the CLEC purchases from the ILEC. ` `  MR. MARLIN: But, the CLEC normally purchases customer premise service from you and then resells to the customer? ` `  MS. BERUBE: You have tariffs, however, that specify what those rates are for your customer and the charges that you supply to them, so while there is a%c0*H&H&@@ reconciliation that the CLEC might want to do between the charges that it receives from the ILEC and what it's billed its end user, certainly the CLEC has the capability to bill the end user based on the services that you provide and the tariffs that you file. ` `  MR. MARLIN: But, when do I find out how long you've been at the customer premise? ` `  MS. BERUBE: Excuse me? ` `  MR. MARLIN: When do I find out as a CLEC how long, how many hours, you've been on the customer premise site for a nonrecurring charge? ` `  MS. BERUBE: Again, that depends on tariffs. If there are hourly rates or if there are flat rates, there might be some need there. I know in Connecticut, our tariffs are flat rates. ` `  MR. MARLIN: Okay, you're flat rating. ` `  MR. GUDE: I think we need to move on to the next question. Are there any other questions in the audience? ` `  MR. BLAINE: Thank you, I'm Larry Blaine, staff economist, Nevada PSC. We're having a, I think, somewhat unique circumstance in Nevada, where Nevada Bell relies on Pacific Bell for billing and other OSS functions. Obviously, this creates a potential jurisdictional problem for us in that a CLEC, a Nevada CLEC, may find itself in the situation where it has to negotiate with Pacific Bell for%d0*H&H&@@ certain OSS functions. ` `  If that CLEC were then to seek arbitration before the Nevada Commission, since Pacific Bell is not a Nevada ILEC, time will tell. Fortunately, we have not been faced with that circumstance, but clearly, there may be a role for the FCC in that. ` `  I have a question, though, more of an economics question, in that, are there the economies in OSS function such that these systems ought to be developed at the holding company level rather than at the operations or operating company level? That's my question. ` `  MR. FALCONE: I could just answer based on what I know is happening and it varies by company. Some companies are having it done at what you're calling, Larry, the holding company level. Other companies, because of their Legacy systems and because the holding companies are I'll pick on Bell Atlantic if there's any Bell Atlantic people here, forgive me the holding company at Bell Atlantic was really a compilation of three smaller companies, New Jersey Bell, Bell P.A. and Diamond State. So, there's some Legacy systems there that, in effect, somehow prevents some companies necessarily of having a ubiquitous companywide system. I don't know if that's answering your question. ` `  MS. LAWSON: From Southwestern Bell's perspective, with the five states that was in Southwestern Bell's%e0*H&H&@@ telephone territory, that was the same. For Pacific and Nevada, those were two, and they did have different systems. So, as was alluded to, we have different Legacy systems. It makes it difficult because of the operating environment that you're in, could drive the type of OSSs to support those. ` `  MS. BERUBE: In SNET, our IT organization which maintains and administers the Legacy systems, is part of what we would consider the holding company. ` `  MR. GUDE: Any other questions? ` `  MS. BINGAMAN: I'm just curious what forum and how are you telling me the right to access charges on a network platform? ` `  MS. LAWSON: That's a policy decision that I don't get to make. ` `  MS. BINGAMAN: I just meant where? ` `  MS. LAWSON: In negotiations. ` `  MS. BINGAMAN: Before a convention, right now, do you know? ` `  MS. LAWSON: Not that I know. ` `  MS. BINGAMAN: You're not aware of a decision by a public body? ` `  MS. LAWSON: Not that I'm aware of. I'm not aware of some of the policy issues still in effect. They don't let me get involved in that, thank goodness. ` `  MS. MOORE: I'm Diane Moore from MCI. I have a%f0*H&H&@@ question from Mary. I understand that you've chosen to use CRIS for resale billing, and at MCI, I particularly support CABS for that, but I understand there's a difference. Whenever companies are choosing CRIS, there is, as Beth pointed out, a mechanized 811 EDI standard for CRIS. When SNET mechanized their CRIS, they did not choose that standard, which therefore caused me extra development work and cost to receive your bill in automated fashion. ` `  Two questions for you. One is, do you know why you did not go with an established mechanized interface when you did mechanize your CRIS system, and the second question is, since your decision to go nonstandard caused me excess work and extra cost. Can you help recover some of that cost? ` `  MS. BERUBE: I think I'll answer your first question first. ` `  (Laughter.) ` `  MS. BERUBE: Basically, because one or two of our customers had asked us for something mechanized, we used what we had readily available to get something out there right away, and that is the God's honest truth. Customers wanted something electronic, we had something that we provided on the end user side that was electronic in format, it fit the immediate need. ` `  In terms of the 811, that is one of the%g0*H&H&@@ alternatives we're evaluating. Since we don't offer that today internally, we don't use it for end user billing today, it is a new development process for us, so that is something that, as one of our alternatives, that we might present to our CLECs when we have done a full evaluation, but it just wasn't available at the time. It's not something we had been doing. Had it been, I'm sure we would have offered it to you. ` `  MS. MOORE: So, if you changed back to 811, I'd have to do more development work to change that to 811. And, if you're not being consistent with the way Southwestern Bell and others have done the 811, then I'll have more development work to receive your mechanized on top of what I've done to receive it already? ` `  MS. BERUBE: I think that would be up to you whether or not you wanted to change. We wouldn't eliminate support for what we are currently providing. ` `  MS. STROMBOTNY: I'm Tracy Strombotny from LCI, and basically, what I want to use bills from LECs for is to validate that what was provisioned by the LEC is what I'm charging my customer for. Because there are manual interfaces in some places, sometimes we find that what gets turned up for the customer isn't exactly what it was before or exactly what we asked for. ` `  What I'm wondering is, do you all have any plans%h0*H&H&@@ to provide some kind of a massive comparison system for the situation where what we're billing is not what you have provisioned, if things get truly, largely out of whack, where what I have asked you to order is not what got turned up. Do you have any plans to provide those systems to CLECs? ` `  MS. BERUBE: I think that's really part of an adjustment process, and we have an adjustment process that we've put in place. It is not fully mechanized at this point in time. I think it will take awhile before that process is fully mechanized, but certainly it is in our interest to make sure that what you've ordered is what's provisioned, and we would confirm on a service order completion for those services that have been ordered electronically, providing back the purchase order number and service order number that a service has been implemented, so that is our way of identifying that what you've requested has been provisioned. ` `  Then, that is further supported at the receipt of your monthly bill. So, to the extent that there is any discrepancy, we would expect that the adjustment process would apply. ` `  MS. STROMBOTNY: Just to follow up, does that mean that under that's USOC by USOC? ` `  MS. BERUBE: No, it's not.%i0*H&H&@@Ԍ` `  MS. STROMBOTNY: So, it's just this service order is complete and we can't compare service by service? Okay, thank you. ` `  MS. BERUBE: That's correct. ` `  MS. LAWSON: Are you looking for any type of validation back to what you're billing your end user, or are you just looking at what you ordered to what the ILEC would bill you? Because there has been some discussion that the CLEC would like be able to validate from their customer database the quantity of USOCs they have at a WTM level back to what I call auxiliary service information that could be provided with the billing detail. So, at some type of level of detail, of course, you would have timing differences there when you service order post it, that I've got 50,000 of USOC one. I've got 250,000 of USOC two, you know, at a high level. ` `  Then, if you want to go down at a WTN level. ` `  MS. STROMBOTNY: Yeah, I want to go down at a WTN level so I don't have a customer paying for a service that they're really not being provided, because it wasn't provisioned. So, I want to WTN, and by WTN compare those services and features by USOC, to make sure that I have accurately provisioned their order. ` `  MS. LAWSON: And, with the EDI 864, that gives you the auxiliary service information by USOC level of detail,%j0*H&H&@@ with the WTN, and with the Bill Plus, with the CDROM version, that will include auxiliary service information at a USOC level by WTN for what Southwestern Bell provides. ` `  MS. STROMBOTNY: But, isn't the 864 a free format transaction? ` `  MS. LAWSON: No, it's got the USOC level and would show the quantity. Then we have an implementation guide that maps that type ` `  MS. STROMBOTNY: Can I get a copy of your implementation guide? ` `  MS. LAWSON: Yes. ` `  MS. STROMBOTNY: Thank you. ` `  MR. WELCH: Okay, I think we're about out of time and we need to wrap this up. I'd like to thank our panelists on this, Dennis Perkins, Bob Falcone, Mary Berube and Beth Lawson. Thank you very much. ` `  We'll take a short break and reconvene promptly at noon for our last panel. ` `  (Whereupon, a short recess was taken.) ` `  MR. WELCH: Okay, why don't we get started with our fifth and final panel of the forum, please? This panel will be on maintenance and repair. Before we actually get into that, I'd like to thank a few people who were instrumental in helping put this forum together. ` `  We had some fine help from our Office of Public%k0*H&H&@@ Affairs, from the Public Service Division, and in particular, Martha Contee and Susan Szulman, who has been instrumental in keeping us on time, and we have hit all our deadlines. So, we thank them and also the folks working in our audiovisual department, tooling away back in the booth, have done a great job putting this production together, and it will result in a videotape, hopefully, that people will take home from Eros Blockbuster Video, excuse me. All these mergers, I have a hard time keeping up. ` `  We're going to now turn to maintenance and repair, and I harken back to the days of the local competition rulemaking here at the Commission, the 251 rulemaking back last summer, where we had this huge debate. One of my favorite issues that came before us was the maintenance and repair and how to handle this. ` `  There was a suggestion made that when the incumbents' repairman pulls up in the driveway at somebody's house, that they should whip out a little velcro badge and put it over the incumbents' logo and put the new entrants' logo and then take a panel and cover up the side of the truck, and put the new logo on. This is one of my favorites. The topic today, of course, is how that relates to OSS. ` `  So, let me introduce our panelists and then we'll have brief opening statements from the four of them. Going%l0*H&H&@@ from right to left we have Gloria Calhoun. Gloria is with Bell South Corporation. She is the director of Bell South. Sitting next to Gloria is David Swan. David is from Bell Atlantic, where he is vice president of carrier services. ` `  Next to David is Bob Welborn, and I apologize, Bob. He is with Sprint Corporation and I think there's been a substitution here. He is a director. I apologize, Bob. Then, finally, we have next to Bob, Rod Cox, who is with Consolidated Communications, Inc. Bob is manager of market expansion and operations. ` `  So, we'll hear from each one of these four folks briefly, and why don't we start with Gloria? Gloria, please? )PANEL III ` `  MS. CALHOUN: Thank you. Nondiscriminatory access requires Bell South to make available information and functions in substantially the same time and manner as Bell South's access for its retail customers. Bell South has met this obligation for repair and maintenance by providing CLECs with access to the same system used by Bell South's repair attendants to handle trouble reports for residence and business exchange services. ` `  Bell South also offers CLECs an electronic bonding gateway for trouble reporting on local interconnection trunking and other design services. Bell South's retail%m0*H&H&@@ repair attendants process local exchange trouble reports, using a system known as the Trouble Analysis Facilitation Interface, better known as TAFI. TAFI is a common presentation expert system that provides rapid, consistent and efficient automated trouble receipt, screening and problem resolution. ` `  It's an interactive system that prompts the repair attendant with questions and instructions while automatically interacting with other internal systems as appropriate. TAFI also provides the queuing of reports, enabling a repair attendant to work on several customer troubles simultaneously, and it also provides on line reference tools. ` `  TAFI is a user friendly interface that often enables trouble reports to be cleared remotely by the repair attendant handling the initial customer contact, often with the customer still on the line. With this system, any repair attendant can correctly handle a trouble report on any Bell South provided basic exchange service. ` `  TAFI provides electronic access to other Bell South systems that might be involved in resolving a trouble report, by automatically interacting with the correct Bell South system for a given situation, and TAFI also will execute the appropriate test or retrieve the appropriate data.%n0*H&H&@@Ԍ` `  For example, if a customer were to report that the customer's call forwarding feature was not working properly, the TAFI system would electronically verify that the feature was programmed in the switch serving the customer's line. Once the TAFI analysis of the trouble is complete, TAFI provides the repair attendant a recommendation of what is needed to correct the problem, and in some cases, actually implements the corrective action. ` `  In the above example, TAFI would correct the trouble by implementing a translation change in the switch to add the feature to the line. If the switch translations had been correct, the repair attendant could provide instructions on the proper use of the feature, using the TAFI help feature. ` `  Bell South has provided CLECs with nondiscriminatory access to its TAFI system. The CLEC TAFI system contains all the functionality described above that's contained in the Bell South TAFI system, including the capability to view maintenance histories. ` `  In addition, by providing access to TAFI, Bell South is making available to CLECs the functionality inherent in the many systems with which TAFI connects. The only difference between the CLEC TAFI system and the Bell South TAFI system is a security step that occurs electronically and nearly instantaneously. This security%o0*H&H&@@ screening step is required because the CLEC TAFI system will be used by repair attendants for multiple CLECs. Therefore, TAFI identifies each CLEC's repair attendants by company, and allows each CLEC's repair attendant to access only that customer's records. ` `  Once that validation check has been performed, the CLEC repair attendant has access to the full range of TAFI functionality that's available to Bell South's retail repair attendants for both business and residence exchange services. Other than the security check described above, TAFI functions identically for CLECs and for Bell South. TAFI has been used by three CLECs in the Bell South region, and Bell South is in discussion with nine other CLECs on the use of its TAFI system. That concludes my remarks. Thank you. ` `  MR. WELCH: Just for the record, could you spell that acronym, TAFI? ` `  MS. CALHOUN: It's TAFI. ` `  MR. WELCH: Okay, next we'll hear from David Swan. I love these acronyms. David, if you're going to tell me that your system acronym is SALT, I'll buy you lunch today. ` `  MR. SWAN: I guess I won't get lunch today. Good afternoon. I'm going to address my comments to three areas related to the subject of CLEC access to operating supporting system repair and maintenance functions. %p0*H&H&@@Ԍ` `  They are the quality of the access we're providing to our CLEC customers. The standards we've adopted to insure that the service provided is on par with what we provide to our end user and access services customers, and finally, the types of interfaces we have already deployed to make sure that high quality and dependable OSS access repair and maintenance is given. ` `  First, Bell Atlantic is committed to providing equivalent access to our CLEC customers, and that is the same or nearly the same access that we provide to our current customers. Currently, our end user customers call a Bell Atlantic trouble administration call receipt center to report troubles. POTS customers are connected to a voice response unit for trouble analysis and call clearance direction, and to close out as many reports initially as possible. Our design services customers call our centers that handle these services. ` `  Our access services customers may also call Bell Atlantic with their trouble reports or use either of our two electronic means for trouble reporting and repair and maintenance administration. These two include electronic bonding open systems interconnect or our communications gateway that we refer to as ECG. For our CLEC customers, Bell Atlantic will provide the same repair and maintenance capabilities. CLECs may call their trouble reports to our%q0*H&H&@@ regional CLEC maintenance case team, a dedicated regional center designed and staffed to support the CLEC repair maintenance administration. ` `  The CLECs may also choose to use one or both of our electronic means for trouble reporting, electronic bonding, OSI or ECG for both design services and POTS and this interface will be administered by the same regional CLEC maintenance case team. ` `  Both electronic bonding, OSI and ECG, provide direct access to the operating support system that administers the particular service. Almost for POTs type services and WFA, Work Force Administration for design services. Electronic bonding OSI allows a CLEC to create a trouble ticket, establish POTs appointments, change and receive status and close out information automatically. ECG provides the same automatic capability, except that it requires manual query from the CLEC for statusing. ` `  So, whether the CLEC calls or electronically sends a trouble report to Bell Atlantic, they will receive the same repair commitment. ` `  Regarding standards, Bell Atlantic has designed a repair maintenance process for our CLEC customers that is nearly identical to the process that is in place today for our own end user customers. There are no national standards at this point for CLEC POTS and design services trouble%r0*H&H&@@ report processing. There is, however, a national standard for the electronic interphase for access services customers, trouble report administration and electronic bonding open systems interconnect, which Bell Atlantic provides. ` `  Bell Atlantic additionally has developed an alternative electronic gateway capability previously mentioned, ECG, to also support this process. The ECG process is more cost effective and requires only a dial up or direct dedicated connection. ` `  This leads to my final comments, the types of electronic interfaces that we have currently deployed. As previously mentioned, the only national standard for interface in this area is the T1M1 guidelines for electronic bonding for access services using OSI, which Bell Atlantic provides. In fact, Bell Atlantic was the first ILEC to connect in OSI application to both AT&T and MCI for trouble report administration for access services. Bell Atlantic has agreed to use nearly the same electronic bonding application for repair maintenance for AT&T for local service, and is ready to meet AT&T's requirements in this area. ` `  Bell Atlantic has offered the same capability to MCI and any other CLEC who is interested. In addition, Bell Atlantic has developed, as we mentioned, a 3270 screen immolation process, dedicated or ECG, which offers much the%s0*H&H&@@ same functionality as electronic bonding OSI, but at a much more reasonable cost. ECG has been enhanced to fully support CLECs for most local services. ` `  Thank you very much for this opportunity to provide these comments regarding Bell Atlantic's efforts to provide CLEC access to its repair and maintenance OSS functions. ` `  MR. WELCH: Thank you, David. ` `  Next we'll hear from Bob Welborn at Sprint. ` `  MR. WELBORN: Good afternoon, it's a pleasure to be here and share a few thoughts on maintenance and repair. Before we start, though, I'm afraid Richard might have everybody at the ballpark, so I'd like to bring you back to reality. It's a rainy day, game's been canceled, you have to go to work. You're now in a repair bureau for the CLEC, and knowing your next call is going to be a customer in distress. Now we set the stage, let's go ahead and continue with the comments here. ` `  Repair and maintenance support systems is considered the most critical support element after service provisioning. End user customer problems require immediate action, especially if the customer has an out of service condition. Setting and satisfying customer expectations can only be accomplished through proper diagnosis of the problem, dependable appointment setting, timely dispatch,%t0*H&H&@@ accurate and timely correction of the problem, and constant customer communications. ` `  There are three components of repair and maintenance. They are prevention, detection and correction. Many times, we only look at the correction side of this and not the other two elements that are essential. Real time Operational Support System integration between the ILEC and CLEC are essential in providing these capabilities, whether it be total service resale or unbundled elements. Electronic bonding platform is a solution that may satisfy integration requirements. EB is currently being implemented in the access environment, however, EB must be enhanced or provide capability that will assist in testing customer troubles. ` `  Key elements to keep in mind, the "Big C" customer is the end user in all cases. Customers want their problems solved in a timely manner and accurate manner. They want to speak with informed and empowered customer repair representatives, who will solve their problems. These expectations cannot be satisfied without seamless operational support systems that provide the information and scheduling capabilities. Unfortunately, CLECs' repair and maintenance performance will be no better than the performance of their weakest network provider. ` `  Currently, many ILECs have established GUIs,%u0*H&H&@@ trouble handling that allow varying degrees of capabilities that differ markedly from ILEC to ILEC. MLT is an example of an essential tool that diagnoses trouble and can eliminate needless dispatches. Some ILECs have elected not to provide access to or provide only limited access to their MLT systems. Denying MLT access is an example of an area where an ILEC may have a service that differs from a CLEC. ` `  Sprint has been in the local market in California since the latter part of 1996 and has been purchasing service from PacBell and GTE on a resale basis. Communications of troubles have been through PacBell's LI Office GUI interface and manual telephone calls to GTE. Although Sprint currently has only a small number of local service resale customers, Sprint is experiencing an unacceptable level of inaccurate, incomplete and misplaced service requests. This has led to customer complaints, dissatisfaction, and in some cases, actual loss of the customer account to their previous carrier, who is the ILEC. ` `  Accuracy and timeliness of service provisioning has also impacted the repair experience, because customers have been inadvertently disconnected in the migration process. While GUI solutions move CLECs beyond the manual processing, they create nonstandard interfaces that add administrative and operational burdens. These proliferations of GUIs will continue to expand to likely%v0*H&H&@@ unmanageable levels as Sprint enters new markets. ` `  In addition to the multiple interface dilemmas, there is no real time access to the incumbent support systems to enter the customer service request, directly access appointment schedules, initiate status reports and perform full MLT testing in parity with the level of service that the incumbent provides to its own customers. ` `  Interim electronic interfaces are not adequate, short term or long term solutions, but only a bandage to meet today's insignificant levels of demand. In addition to the need for real time interfaces, to insure accurate and timely handling of customer expectations, there's a need for the ILECs to selfreport performance levels, to insure consistency of service delivery across all entities. Standard performance measurements need to benchmark the ILECs performance and their affiliates performance against individual and industry CLEC performances. Measures and calculation methodology have been proposed and the local competition user groups service quality measurement documents. ` `  In summary, it is essential that real time interfaces provide a seamless customer experience and provide efficient, timely and accurate information to the CLEC customer repair representatives, satisfying customer expectations, all based upon electronic systemsystem%w0*H&H&@@ platform integration. Thank you very much. ` `  MR. WELCH: Thank you, Bob. Last we'll hear from Rod Cox at consolidated communications. ` `  Rod? ` `  MR. COX: Thank you, Richard, and since I'm the last panelist, I think it's only appropriate that I can close with the baseball theme. I would like to start out by saying that last year in May, Consolidated Communications felt like a minor league team playing in a major league stadium. The first six innings were errors, full of errors and a lot of delays. The innings seven, eight and nine, we started swinging and reduced the errors. Now, we're in the 12th inning, extra innings, by the way, and we're all tied up. You can take that literally, if you like, but we're still in the game. ` `  I am confident we're going to win the first game of many series of games to come. For all you start up LECs out there, CLECs, practice, continual improvement and keep swinging. We can win. It's going to be a long season. That's my game story. ` `  Now, I'd like to give you a little brief history of Consolidated Communications. Consolidated Communications started in 1894 as Illinois Consolidated Telephone Company. Today, Illinois Consolidated Telephone Company is the 26th largest local service provider and the largest privately%x0*H&H&@@ held telephone company. ` `  Consolidated has grown as a fourth generation family owned company into a multiple facets of the telephone industry. Consolidated diversified by entering the IXC business in 1984 and then as a CLEC in 1996. Our 103 years experience in the telephone industry has proven invaluable. ` `  We were certified in the CLEC business in 1995 and began the facilities based unbundled loop offering in May of 1996. Our goal was to be the first in downstate Illinois to give to customers a choice in three chosen markets of Springfield, Decatur and ChampaignUrbana. The goal was accomplished, but not without tremendous pain and fast learning. ` `  My CLEC experience and my primary responsibilities for the last year have been to improve our internal processes, because some of those were broke, and improve the relationship with Ameritech, and to define and develop performance measurements that are, in my opinion, key to this business. ` `  I initiated the operational support systems, interfaced alternatives with Ameritech and personally have been excited and challenged by this effort and am honored to be here representing Consolidated Communications on this panel. ` `  What access should incumbent LECs provide for%y0*H&H&@@ repair and maintenance? The best case, give us access to everything you've got. The issue is to us not so much what you provide, but what it will cost us. We would like to have trouble ticket information matching real time, both systems, real time opening and closing of tickets, with clocks matching, which is not always easy. On line escalation status and comment fields, test results with access times and forced to load schedules should also be available. ` `  It is very important to understand how duration is measured, and who authorizes the clock to stop. Receipt to clear in this business is a two part process. Clearing back to the CLEC is the second part that should not be taken lightly. Having the ability to communicate to your customer what the status of that condition is is very critical to our business. ` `  What standards are necessary for parity? Consolidated supports standards for the industry that will insure parity. The key is making these standards efficient and affordable for all. Adhering to standards developed just for large companies with complex needs will drive cost up and force smaller players like us to use GUIs or inquiry only type systems. ` `  Standards should be tiered with varying levels of business needs, and with the flexibility to add%z0*H&H&@@ functionality as budgets exist or as budgets can handle it. What types of interfaces are we today using or proposing? Today, we are currently using a Trouble Administration GUI with Ameritech. We have just begun to use this process. It is a PC dial up software application that was provided by Ameritech. We are exploring other alternatives with them and with external consultants. ` `  As a final comment, Consolidated's experience in electronic bonding for operational support systems for maintenance repair are just beginning. We will continue to test simpler, less costly solutions. We will continue to work with Ameritech and other ILECs as we choose in pursuing these simpler solutions and we will openly share our success or shortcomings with other players in the CLEC arena. ` `  Electronic bonding of systems will only be as good as the linked processes that are in place and the commitment and the relationship between the ILEC and CLEC. Without that, we have nothing. Thank you. ` `  MR. WELCH: Thank you, Rod. Now we'll have some questions and hopefully we can generate some discussions back and forth among the panelists. ` `  Bob, if I could start off with you, please. Rod touched on this a little bit in his opening comments and I'd like to get your views on this, as well, from Sprint. This is a general question. What do you require from an%{0*H&H&@@ incumbent in terms of access to repair and maintenance functions in order to effectively serve your customers? What would you like to see them provide to you? ` `  MR. WELBORN: I think that, as Rod had stated, we need to be able, one, to generate the trouble report on a mechanized basis. We need to know what an accurate appointment time is, so that we can talk intelligently to our customer and build the expectation of when the trouble is going to be repaired. ` `  We also need to test that line while the customer is, while we have them on line, so we can diagnose whether it's probable that the customer can be corrected more immediately and apply the right appointment interval, as well as we need the communications and the statusing on a continual basis on line, so that when the customer calls in or at such time that we deem it necessary to understand the status of a trouble report that is available to us on line, as well as we need the communications back to us once the trouble has been repaired. That's most important, so that we can communicate with the customer, close it out and insure that there's customer satisfaction. ` `  MR. WELCH: Bob, I think you mentioned you were talking about your experience in California, that you're reselling in California at the moment? ` `  MR. WELBORN: Yes.%|0*H&H&@@Ԍ` `  MR. WELCH: I imagine at some point, if you're not already, that you have plans for utilizing unbundled loops? ` `  MR. WELBORN: Yes, we do. We are not using unbundled loops in California. We are doing it in Bell South territory. ` `  MR. WELCH: Okay, this question goes to who has the responsibility for testing unbundled loops and should you as the new entrant have the option of testing them yourself or requesting that the incumbent do so for you and should the incumbents be required to give you access to their mechanized loop test systems? ` `  MR. WELBORN: In the unbundled environment, I think that there are several stages. One, when I purchased the loop, I expect that loop to be a working loop, and therefore, there is a desire for the incumbent to test that loop prior to giving it to me in the initial provisioning process. ` `  At the same time, when that loop is in need of repair, I need to have the diagnostic tools available, which would include any sort of mechanized testing capability. ` `  MR. WELCH: Would anyone else on the panel like to comment on that? Rod, do you have any thoughts? ` `  MR. COX: Yeah, we do our own testing. Unfortunately, testing is not always foolproof, and we've made the decision to, if in doubt, we dispatch our own%}0*H&H&@@ people and confirm that it's dial tone to the NID. But, a lot of times, the test, you just can't tell. ` `  MR. WELCH: David or Gloria, do you have any thoughts on that? ` `  MS. CALHOUN: With an unbundled loop alone, I think that you have some issues about how you define an unbundled loop and some of the testing capability that is available on that loop that is associated with an integrated exchange service might not be present when the loop is separated from the switch. So, I don't think it's possible to make a categorical statement, but to your question, if I may generally talk about Unbundled Network Elements, Bell South's TAFI system that I described will also handle trouble reports for any Unbundled Network Element that can be identified with a telephone number. ` `  So, for example, an unbundled port can be reported through TAFI and appropriate status information can be obtained. A combination of a loop and port that can be identified with the telephone number will also be handled through TAFI, so it is possible for the Bell South system to provide an appropriate level of support for trouble reporting on Unbundled Network Elements, depending on how they're identified. ` `  Anything that's not identified with a telephone number generally is associated or identified by a circuit%~0*H&H&@@ number, and those reports can be handled electronically through the electronic communications gateway or the electronic bonding arrangement that's available for design services. ` `  MR. SWAN: I would agree with Bob and Rod both from their response. Bob initially commented at the time that the unbundled loop is placed in service, there's some coordination required and some testing in connection with that to assure that the service is in order. ` `  When there is trouble, as Rod indicated, the initial testing should start with the CLEC, and to the extent that that testing suggests there's some difficulty from an ILEC standpoint, of course, we would become involved to support that. ` `  MR. WELCH: Gloria, if I could ask you to address this, we've heard a lot about parity over the last two days and how the incumbent will provide the same type of access that they provided themselves to the new entrants. Could you please describe a little bit how your company will insure that there is nondiscriminatory access to your repair personnel and assets between your retail unit and your new entrants? Are you recording or evaluating your performance for retail business with what you provide your new entrants, and is that information made available? ` `  MS. CALHOUN: Well, there are two parts to your%0*H&H&@@ question, and the system part of it is that the system is identical and the system is oblivious to whether a request for repair is originating with a CLEC or with a retail customer. So, in terms of appointment times or handling the it's really immaterial how, from whom the trouble report is originating. ` `  But, in terms of, to get at the question of how you would measure that and how the trouble is actually handled, assuming that it requires a dispatch. Bell South has contractually agreed to contractual performance measurements. ` `  MR. WELCH: David, would you like to say how Bell Atlantic is handling that, as well? ` `  MR. SWAN: The process is basically parallel. There is, on a call from an end user, a check that we make initially to see if this in user, nonCLEC is the customer now of a reseller, for example, because some resellers have made it clear that should we receive that call directly, that we should refer it to the reseller. ` `  So, in that instance, there is some distinction in the way we handle the initial receipt of the call. But, once the call is received or the trouble is reported, it's just a trouble with the system at that point, and we would manage it and process it the same way. As with Bell South, we have agreed on some going forward reports on a%0*H&H&@@ comparative basis, to assure parity. ` `  We produced reports on a quarterly basis that would summarize the number of trouble reports, the average time to clear and some measure of average or total network availability, for an individual CLEC, and then for all of the CLECs for whom we're providing service. ` `  We also produced a summarization for the same metrics for Bell Atlantic retail customers in total, and then would include a similar analysis for our top three interexchange carriers, in this case AT&T, MCI and Sprint, again on a combined basis, to insure and to allow the CLEC to demonstrate that there's parity across that universe. ` `  MR. WELBORN: Richard, I'd like to interject something. I believe that once the trouble reports get into the systems, the prioritization is in concert with the ILECs. However, there are different methods, depending upon the different type of service, of entering trouble reports, such as in Bell South's area, some of our unbundled elements are handled on a telephone call basis. They're referred on a manual basis and then entered into the system. All of that process is on a manual type basis. ` `  So, you know, again, we need to take a look at what is mechanized, what is not mechanized, and realizing that there is a requirement to have everything mechanized so that it is handled the same all the way through the process.%0*H&H&@@Ԍ` `  MR. WELCH: Gloria, go ahead. ` `  MS. CALHOUN: Again, I will say that Bell South is prepared to accept electronic trouble reports for any service or element that can be identified with either a telephone number or a circuit number. ` `  MR. WELCH: As sort of a follow up to this, if I could ask Gloria and David to comment on it, do the new entrants have the ability to receive automatic notification of repair completion for both Unbundled Network Elements and for resold services, as well as the ability to track the status of those repairs as they're going on? Is that something that your systems offer? ` `  MS. CALHOUN: Yes, for Bell South. ` `  MR. SWAN: And, yes, for Bell Atlantic. It's a little different depending on the electronic interface employed. With electronic bonding OSI, it's the statusing and the clearance is automatic, but with ECG, a gateway process, there is some requirement that the CLEC query the system to confirm the status update and the clearance time. However, for the clearance of the report, at any time it wants what is cleared through the gateway, they could introduce a direct status that would inform them that the trouble had been cleared. But, the actual information related or describing what caused the problem and how it was cleared, they'd have to access on a query basis.%0*H&H&@@Ԍ` `  MR. WELCH: Bob and Rod, if I could ask each of you, is this something that you need and what has been your experience with this so far? ` `  MR. WELBORN: Richard, I'll take a stab at that. Yes, it is something that we need. It's something right now today in many cases there's no positive notification made when a trouble is clear. It's only whether or not you take the time to search through the system itself and gathered those statuses on your own. ` `  There is no proactiveness, and that differs from ILEC to ILEC. Some of them do notify you, such as they have the technician call your, the CLECs repair center, clear it out with the repair center. There are others that refuse to do that, and that it's totally on a passive basis. If you want to go in and see if the trouble was cleared, you can do so. ` `  MR. COX: I guess from our point of view now, we're pretty much a manual process with Ameritech, primarily calling back and forth and we have driven the issue pretty hard, especially out of service trouble, clear within 24 hours and those kind of things. We get a pretty good response back from them. ` `  The GUI that we're getting ready to test will provide that information. We'll be able to go in and see. The problem is, you have to have somebody going in there and%0*H&H&@@ scrolling for that information. We want some kind of flag back if we're going to use the GUI that says, you've got something in jeopardy here or it's getting close to the time when it should have been put into place or whatever or fixed. ` `  So, that is the problem with the GUI. An online system, you should have some kind of flag that would already come up and give you a red signal or something that's going on there. ` `  MR. WELCH: Okay, I think Kalpak has a question. ` `  MR. GUDE: This is directed towards both David and Gloria. If a service outage occurs for a CLECs end user, do you require CLEC authorization before a dispatch is made? ` `  MS. CALHOUN: I'm not sure I completely understand your question. ` `  MR. COX: I think what you're trying to get at, if there is an outage that you're aware of, is there authorization required by the CLEC before you will dispatch service people to address that problem? ` `  MR. GUDE: No, no, I'm talking for particular end users. ` `  MS. CALHOUN: So, you're saying, for example, if the CLEC end user were to call us directly, would we dispatch without contact of a CLEC? ` `  MR. GUDE: I'm saying, well, either in that case%0*H&H&@@ or the case that you become aware of it independently and you haven't been notified at that point? ` `  MS. CALHOUN: In the case of a CLECs end user calling us directly, we would ask the end user to contact their local service provider and any interaction we have with be with the CLEC, presumably through our electronic interfaces. ` `  If, I don't know the answer to your question, but if we became aware of a problem with a particular customer before a CLEC, my initial reaction is that we would probably work with a CLEC and not interact directly with their end user. ` `  MR. SWAN: In Bell Atlantic's case, I did much as Bell South's. If the CLEC user calls us direct and this is at the, again, the direction of the CLEC, we would refer the call to the CLEC. If the trouble, once provided to us, either verbally or through one of the electronic interfaces by the CLEC, results in a circumstance where a dispatch is necessary with the CLECs' concurrence, we would dispatch, and that concurrence could be given on a blanket basis for all of the troubles that would result in a dispatch on an individual basis, depending on the relationship that we've negotiated with the CLEC. ` `  MR. GUDE: Also, the other question is, have you trained or done other work with your repair personnel, to%0*H&H&@@ prepare them for their new roles as wholesale repairers? Is there sort of a different role for them? I think that's sort of a fundamental question for that? ` `  MS. CALHOUN: Well, I'm going to have to separate that question into the different types of folks who would be involved in repair. First of all, our Bell South repair attendants would not be, in most cases, dealing directly with a CLEC end user, because of what we just talked about. So, the folks who would actually become involved would be anybody who might need to be dispatched out and those people have been trained on their responsibilities, their obligation to provide nondiscriminatory service, their obligation not to interfere in anyway with the CLECs business relationship with their customer. ` `  MR. SWAN: In Bell Atlantic's case, again, much as with Bell South, the if there is a need to dispatch, of course there would be a Bell Atlantic repair person at the sight of the CLEC end user. Of course, we spent some time with our repair folks to prepare them for that circumstance. We have also worked with the group of CLECs who are our customers, on leave behind material or collateral that may be necessary to show, confirm that we're there on behalf of, and although we're a Bell Atlantic employee, we're there on behalf of CLEC A, CLEC B. ` `  Of course, there's been some orientation and%0*H&H&@@ training of the repair folks for that eventuality. For the repair attendants, because of the need, as to receive a call from the end user, to recognize that not all of the calls that will come into the center in the wholesale arrangement will be from the Bell Atlantic end user, may, in fact, be from the CLEC end user. There has been some training and orientation required, even for the inside attendant. ` `  We had considered the velcro patch for the badge and for the trucks, but we went beyond that. ` `  MR. WELCH: Okay, i think now we have an opportunity if there's anybody in the audience who'd like to pose some questions to the panelist. Please identify yourself and direct your question to a particular panelist, if you would, please? ` `  MS. DALTON: Good afternoon, Nancy Dalton with AT&T. My question is for Mr. Swan. Mr. Swan, in your opening remarks, you reference the LMO system that's used in Bell Atlantic today for repair and maintenance capabilities for POTS services and WFA is used for your design services. ` `  If a CLEC is to create a POT service, purchasing an unbundled loop and switch port from Bell Atlantic, which of those systems will be used to provide the OSS capabilities for repair and maintenance? ` `  MR. SWAN: I may have to take I don't know the exact answer to that. I believe that the way that we've%0*H&H&@@ established with in our systems the components for the unbundled or platform service, that they would exist within the LMO system. ` `  MS. DALTON: I believe that was the case for Bell South, as well, with the TAFI capabilities, is that right? ` `  MS. CALHOUN: Yes, our TAFI system is being taught, if you will, to recognize that a recombination of unbundled elements that replicates a retail exchange service is, for all intents and purposes, a retail exchange service, or, excuse me, a resold exchange service for repair purposes. ` `  So, yes, it would appear as an exchange service and would be handled in LMOs. ` `  MS. DALTON: So, then, parities being treated from, looking at the view of like services being treated equally, POT services being treated equally amongst carriers? ` `  MS. CALHOUN: Yes. ` `  MS. DALTON: Okay, thank you. ` `  MR. SWAN: No, no, if I understand the direction of the question, the unbundled element is not directly comparable in terms of how it's put in place, how it's implemented, how it's provisioned and how it's maintained from a facilities standpoint directly to an exchange line, if you will.%0*H&H&@@Ԍ` `  It's a series of unbundled elements which provide the same functionality and service as a local exchange line, but they're unbundled elements and that's the way that their provision and the way we maintain the facilities and the records. ` `  MS. CALHOUN: I would agree with that for Bell South. I would agree with that from the perspective of individual, unbundled elements, but for a recombination of unbundled elements, our TAFI system would translate that as an exchange line. ` `  MS. DALTON: I just want to make sure that I understand. If I am buying a series of elements and I'm buying them all from either of your companies and I'm purchasing them to create a POTS service, will I have the same capabilities for repair and maintenance as you each have with respect to servicing your POTS services? If I understood correctly, I'll have those capabilities through TAFI for POT services, just as Bell South provides to itself. ` `  I'm not sure, based upon the last clarification, if a CLEC would have those same POTS capabilities through LMOs, regardless of whether it's created the service through unbundled network elements or not? ` `  MR. SWAN: The distinction I was trying to make, and I apologize if I made it awkwardly, is that we view the%0*H&H&@@ platform again as a series of distinct, unbundled elements, which, though ordered separately, provisioned separately, provide in terms of service functionality, the same as basic local exchange service. ` `  Now, because they're ordered separately as separate Unbundled Network Elements, we provision them and maintain records and facilities on them as separate elements. They would occur within LMOs as those separate elements. ` `  The way that we would seek to complete trouble analysis and reporting may be more akin, if I could use that term, to the way we manage unbundled loops as opposed to regular POTS service. We're still working out those specific details. ` `  MS. DALTON: Thank you. ` `  MS. STROMBOTNY: I'm Tracy Strombotny with LCI. It sounds like from listening to people here that we're not alone in suffering disconnects during the provisioning process, and I'd like to know how Bell Atlantic and Bell South, how your trouble systems handle those disconnects, because in many cases, as the provisioning process is not complete, we're not the customer of record. And, so, we have a hard time getting those problems resolved, and yet our customer is out of service. ` `  So, I'd like to know how your systems handle that?%0*H&H&@@Ԍ` `  MS. CALHOUN: First of all, let me make sure I understand your question. Are you talking about a customer whose exchange service is being changed to something that would involve an unbundled loop, or are you talking about a migration of a ` `  MS. STROMBOTNY: In assume as is resale situation. ` `  MS. CALHOUN: In assume as is resale situation? The way Bell South is provisioning an assume as is resale, the disconnect should not occur. ` `  MS. STROMBOTNY: I understand it shouldn't, but it does, so that's why I'm asking. We've encountered this problem with every ILEC that we've dealt with, Bell South included. ` `  MS. CALHOUN: Again, if it's a situation where you're assuming it as is and there's no work required, the way our processes are set up, that should not be happening. Now, if you have some other ordering scenario that's occurring that's causing that, I don't know. ` `  From a repair perspective, there is a time period following issuance of a service order, where it's a provisioning question versus a maintenance question. But, in general, there is a single point of contact set up. We have an access customer advocacy center is what it has historically been called, and there is a center assigned to support CLECs, and that would be a point of resolution,%0*H&H&@@ single point of resolution for troubles associated with either provisioning or repair. ` `  MS. STROMBOTNY: Is this the same, then, as would be experienced by a Bell South end customer? Is that the same group or the same service that would be provided when you were trying to assume a customer or get a customer turned up? ` `  MS. CALHOUN: In terms of whether it's considered provisioning or maintenance? ` `  MS. STROMBOTNY: Mmhmm. ` `  MS. CALHOUN: Yes. ` `  MR. SWAN: From a Bell Atlantic standpoint on the question with the as is migration, again, no work required, no physical work required and no switchwork required, it's record exchange, and there would be no need for the service to be interrupted. ` `  In the resale migrations that we've completed to date, I'm not aware of any difficulty where we have inadvertently disconnected or disrupted any user service. ` `  MR. BRADBURY: Hi, Jay Bradbury with AT&T. Hi, Gloria. You and I have been talking about this subject since August of 1995. TAFI and EDI as they are today kind of bring each half a loaf to the table. You know, AT&T has a strong desire, just like Mr. Welborn discussed there for system integration.%0*H&H&@@Ԍ` `  The EDI interfaces existent in Bell South today has the mapping there for the access circuits that are used, but if you send a local over on it, it doesn't automatically give you back anything, because it's not mapped. ` `  TAFI, on the other hand, is a human to machine interface. We talked some time ago and I've been talking with many people in Bell South about marrying those two up together, putting TAFI, if you would, behind the EDI interface, to get the advantage of the standards and all of the system's expertise that exists in TAFI. ` `  Has anything happened since last April on that? ` `  MS. CALHOUN: Bell South has provided nondiscriminatory access to its TAFI system by making information and functions available to CLECs in substantially the same time and manner we have available for our retail customers. And, we've made that functionality available to AT&T in exactly the same way we have it available for ourselves. ` `  The trouble reporting gateway or the electronic bonding gateway has been available for use by our exchange carriers, such as AT&T, for the last couple of years, and when Bell South implemented that gateway, we agreed there were standards for an interface to what we call WFA, what Bell Atlantic calls WFA for design services and there were standards available for an interface to LMOs. And, our%0*H&H&@@ implementation agreement at that time was that we would only implement the WFA aspects of that, and we have agreed with AT&T that by December of 1997, we will go and build out the LMOs side of that electronic bonding interface, but we will do it in such a way that it meets the existing standards for the LMOs functionality in that interface. ` `  TAFI is something that, frankly, is far above and beyond what the current industry standards for trouble reporting in the access world provide for, and at this point, we have said that we have made full TAFI functionality available. We have agreed to build out the full functionality through the electronic bonding gateway that currently is supported by industry standards, and what we've not agreed to do is to replicate all of the TAFI functionality in the electronic bonding arrangement, because that would render it a nonstandard interface. ` `  So, what we've done is agree to provide a totally standard interface, and to provide all of the functionality for TAFI as currently available that's sitting today, ready and waiting to be used. ` `  MR. SWAN: I can say without hesitation, that nothing has happened in Bell Atlantic on that issue. ` `  MR. WELCH: Any other questions from the audience? ` `  MR. CLUBFELD: Hank Clubfeld from SAIC. Gloria mentioned a security check, which I think is an excellent%0*H&H&@@ approach. I was wondering if the panel had a chance to read on the FCC's Web page, on the Office of Engineering Technology on Damrick the planning for operations support interfaces that looks at the functionality of a gateway, the need to address security, given the fact that these are sensitive operation systems that need petition to make certain that the CLEC is the right CLEC for that party, and that the bad guys don't get in looking like the CLEC. ` `  Would you care to comment on that, particularly with respect to the discussion for the particular OSSs that each of you are trying to get addressed? ` `  MS. CALHOUN: Well, I can say that Bell South has participated in the development of the document that you're talking about and that we have stayed abreast of it and consider it in our planning and development efforts. ` `  MR. SWAN: As has Bell Atlantic. In preparation for the panel periods, we spent some time in conversation with the Bell Atlantic representative from Bell Corp. on that effort. ` `  And, security has been a primary focus at each point in our electronic interfaces to OSS functions, both through the gateway and through although not to the, with the same approach, even with our electronic bonding initiative. ` `  We do that from a far wall standpoint, and then%0*H&H&@@ actually when we get to the target operating support system database, for further security checks at the individual data customer level. ` `  MR. WELCH: Well, I think that concludes this panel. I want to thank our panelists, Rod Cox, Bob Welborn, David Swan and Gloria Calhoun, for being with us. ` `  I'd like to thank all the panelists over the last two days who went out of their way to come and join us and offer their views. It helped the FCC understand the issues. I hoped it helped the people in the industry understand the issues, and I will spare you any more baseball metaphors and just say, we're done. Thank you. ` `  (Whereupon, at 1:00 p.m., the hearing was concluded.) // // // // // // // // // // //%0*H&H&@@  ? (! &   ` X +V,@Heritage Reporting Corporation &(202) 6284888V "REPORTER'S CERTIFICATE ă  ?X  FCC DOCKET NO. : N/A  ?  CASE TITLE : Common Carrier Bureau Operations Support Systems Forum(#  ?@  HEARING DATE : May 29, 1997  ?  LOCATION :  Washington, D.C.  I hereby certify that the proceedings and evidence are contained fully and accurately on the tapes and notes reported by me at the hearing in the above case before the Federal Communications Commission. Date: _05/29/97_ _____________________________ Official Reporter Heritage Reporting Corporation 1220 "L" Street, N.W. Washington, D.C. 20005 Peter Knight Shonerd  ? <! TRANSCRIBER'S CERTIFICATE ă  I hereby certify that the proceedings and evidence were fully and accurately transcribed from the tapes and notes provided by the above named reporter in the above case before the Federal Communications Commission. Date: _06/06/97_ ______________________________ Official Transcriber Heritage Reporting Corporation Diane Duke  ?x  <!PROOFREADER'S CERTIFICATE ă  I hereby certify that the transcript of the proceedings and evidence in the above referenced case that was held before the Federal Communications Commission was proofread on the date specified below. Date: _06/09/97_ ______________________________ Official Proofreader Heritage Reporting Corporation Don R. Jennings