20031118ATT Comments & Counter Proposal.pdf

Mary B. Tribby
Letty S.D. Friesen
AT&T Communications of the
Mountain States, Inc.
1875 Lawrence Street, Suite 1575
Denver, Colorado 80202
[phone] (Phone)
[phone] (Fax)
Robert M. Pomeroy Jr.
Holland & Hart LLP
8390 E. Crescent Parkway, Suite.400
Greenwood Village, CO 80111-2800
Telephone: [phone]
Facsimile: [phone]
Attorneys for AT&T
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UTILITIES CO/",MJSSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IPUC RESPONSE TO
FCC ORDER ON REVIEW OF SECTION 251
UNBUNDLING OBLIGATIONS OF
INCUMBENT LOCAL EXCHANGE
CARRIERS (CC DOCKET NO. 01-338
NINE-MONTH REVIEW ON ECONOMIC
AND OPERATIONAL IMPAIRMENT
REGARDING ACCESS TO SPECIFIC UNES
CASE NO. GNR- T -03-
AT&T'S COMMENTS AND COUNTER PROPOSALS ON QWEST
CORPORATION'S BATCH HOT CUT PROPOSAL
AT&T Communications of the Mountain States, Inc. ("AT&T") submits the
following comments and counter proposals to Qwest Corporation s ("Qwest") batch hot
cut proposal.
INTRODUCTION
Fundamentally, every time a hot cut is performed, an incumbent local exchange
carrier ("ILEC") technician must physically disconnect the customer s loop from the
current carrier s switch and reconnect it to the new provider s network. Those same
manual, loop-by-Ioop activities must be performed whether they are done for one
customer or for a batch of customers. Qwest's proposal does nothing to change those
fundamental facts. Instead, Qwest's proposal reinforces why the FCC found the hot cut
process was a source of operational impairment and why the Federal Communications
Commission ("FCC"): concluded that ILECs must offer competitive local exchange
carriers ("CLECs ) access to mass market switching.
That is not to say that AT&T is uninterested in having Qwest improve its current
hot cut process. Any proposal that seeks to improve the efficiency, capacity, quality and
cost of the current individual hot cut process is a welcome step in the right direction.
However, based on AT&T's review , Qwest's proposal is but a very small step in what
may prove to be a long journey to get agreement on a batch hot cut process that the
Commissions and the CLECs can support and meets the FCC's requirements. AT&T
believes Qwest's proposal falls far short of curing the operational and economic
impairments that exist with the current hot cut process.
AT&T finds Qwest's proposal to be either short on essential details or outright
deficient in a number of critical areas such as cost, quality of service to the end user
scalability and functionality. As an initial matter, there are certain key principles that
must be followed during the batch hot cut collaborative. The first key principle is that
any process changes must consider the impact on Qwest, the CLEC(S)l and the CLEC'
customer. For example, a process change that reduces Qwest' s cost by $1.00 but
increases a CLEC's cost by $2.00 is a change that should not be made. Qwest should not
be the only party considered in the batch hot cut process design. A second key principle
is that any process changes must consider the effect on all of the critical hot cut
characteristics. For example, a change that reduces a cost but also increases the
frequency of customer outages should not be made. Changes should not be viewed in
isolation but should be viewed as part ofthe overall process. Unfortunately, many of
Qwest's proposed changes fail to consider all of the affected parties or suboptimize one
element at the expense of another. The following describes AT&T's primary concerns
with each of these key areas. As AT&T better understands Qwest's proposal , it reserves
the right to raise other concerns.
1 Multiple CLECs will be involved for the migration of an unbundled loop from one CLEC's switch to
another.
II.AT&T's CONCERNS
Cost of a Hot Cut
On page 3 of its proposal Qwest admits that it has not yet completed its detailed
cost studies; however, they state "it appears that in virtually every instance these
efficiencies will reduce Qwest' s cost of performing a batch hot cut." Emphasis added.
Qwest goes on to state on page 15 that "the batch conversion process that Qwest proposes
above will yield significant additional efficiencies and in most states the CLEC
community can expect to experience a significantly reduced rate." Emphasis added. The
Commissions and the CLECs cannot rely on vague statements such as these to get a sense
of whether Qwest's batch hot cut rates will even begin to address the economic
impairment concerns expressed by the FCC in the Triennial Review Order ("TRO"
Before the Commission considers this proposal Qwest should be required to specifically
state what its batch hot cut cost structure will be and provide the cost studies it conducted
to support its proposed rates.
With respect to its current loop hot cut non-recurring costs, Qwest congratulates
itself on page 15 of its proposal by stating, "As an initial matter, Qwest notes it is starting
from a better position than many other incumbent LECs in this regard. The FCC found in
the Triennial Review Order that currently hot cuts are often priced at rates that prohibit
facilities based competition for the mass market,' citing ILEC non-recurring charges
exceeding $100 and as high as $185. But Qwest's hot cut charges across its region are
not nearly this high. In virtually every state Qwest's current non-recurring charges for a
basic hot cut range between $29.10 and $65.00." Footnotes omitted. What Qwest has
failed to point out is that its coordinated installation with Cooperative Testing loop
installation option is as high as $171.87 per loop for the first installation. That rate would
place Qwest at the upper end of the range discussed by the FCC. Even assuming a Qwest
hot cut rate of $602 there remains much room for improvement to remedy the economic
impairment experienced by the CLECs when trying to serve the mass market with
unbundled loops. In contrast to the much less than $1.00 non-recurring charge the
CLECs pay Qwest to migrate a customer to UNE- P, Qwest needs to make significant
reductions in its hot cut non-recurring rates to make UNE-L a viable alternative for
serving the mass market from a non-recurring charge perspective.
Quality of Service
U sing the current hot cut process, which requires a physical disconnection of the
customer s line from its existing local service provider s switch and reconnecting it to the
new service provider s switch, a service outage is unavoidable. When each of the steps
of the process is done correctly this service outage can be measured in seconds.
However, because of the manual nature of the process and all of the human touch points
involved, there is a tremendous opportunity for human error and a resulting service
outage. When performing an individual hot cut from retail to UNE-L these outages are a
concern for the CLEC because it is the customer s first experience with the CLEC and
the CLEC does not want it to be a negative experience. However, when this does
happen, at least the CLEC can explain to its new customer that something went awry
during the migration process. On UNE-P (or resale) to UNE-L conversions, where the
2 The approved rate for a coordinated installation without cooperative testing is $59.81 in ten of the Qwest
states.3 Of course there are other economic impairment issues that the CLECs will face when trying to serve the
mass market with UNE-L such as the collocation and backhaul costs. These comments are only related to
the economic impairment issues associated with the hot cut non-recurring charges.
batch hot cut process will most likely be used 100% of the time (see functionality section
below), these service outages become even more of a concern for the CLEC. In these
cases the customer already has his/her service with the CLEC and may have been doing
business with that CLEC for an extended period of time. When a hot cut is performed on
these customer s lines and an outage occurs, the customer can only think that the CLEC
has a maintenance issue. Because the customer impacted by the outage did not request to
have his/her service modified, any outage is viewed as poor performance on the part of
the CLEC, even though it most likely would have been caused by Qwest. As far as this
customer is concerned Qwest is not even in the picture. Therefore, it is of critical
importance that hot cut migrations of existing CLEC UNE-P customers be as seamless
and go as flawlessly as possible. It should also be noted that Qwest is not above taking
advantage of quality problems experienced by CLEC customers that it may have created.
Qwest has recently been running radio and television advertisements where it describes
how a competitor "dropped the ball" with a customer and how Qwest saved the day.
Qwest's current batch hot cut proposal leaves much to be desired in the area of
service assurance and quality. Fundamentally, Qwest's proposal sacrifices service
assurance and quality for a reduction of a few process steps. There are many pitfalls
Qwest s proposed process that put the CLEC' s customers in jeopardy of an extended
service outage. Some of the service quality concerns that AT&T has with Qwest's
proposal include the following:
1. Batch Hot Cuts Limited to Basic Installation Only
One of the requirements of Qwest' s proposed batch hot cut process is "basic
installation only on batch conversions.,,4 Qwest further underscores the unavailability
of coordinated conversions when it states
, "
Coordinated and/or basic installation is
still offered for business as usual activities - for example - requests not identified as
part ofthe conversion or a part of a project managed hot cut."s Qwest's proposal to
limit batch hot cuts to basic installation only significantly and negatively impacts the
CLEC customer in two areas. The first area is that performance testing is not done
with basic installation for existing customers. Qwest's SGAT states:
2.2.1.1 For an existing End User, the Basic Installation option is a
lift and lay" procedure. The Central Office Technician (COT) "lifts" the
Loop from its current termination and "lays" it on a new termination
connecting to CLEC. There is no associated circuit testing performed.
Qwest identified the following testing activities as part of performance testing:
2- Wire and 4- Wire Analog Loops
No Opens, Grounds, Shorts, or Foreign Volts
Insertion Loss = 0 to -5 dB at 1004 Hz
Automatic Number Identification (ANI) when dial-tone is presene
While Qwest does propose to check for dial tone and ANI, its proposal does not
include the other types of performance testing. Qwest's proposal of only basic
installation for batch hot cuts is nothing more than reducing the amount and level of
testing that it typically does for hot cuts. Qwest's proposal to reduce testing will
potentially result in negative impacts on CLEC customers.
4 Qwest BHCP - Exhibit 7
, p. 1.
Id.6 Colorado SGAT, March 4 2003 (emphasis added).7 Colorado SGAT, March 4, 2003, ~ 9.2.2.
The second major problem with the basic installation only option is that it extends
the period of time a customer cannot receive incoming calls. With a coordinated
installation option, Qwest contacts the CLEC after the "lift and lay" procedure is
completed. Once the CLEC is notified, the CLEC can complete the number
portability activities. In contrast, with Qwest's new proposal , the CLEC will be
notified only when every line in the batch has been completed.
Page 12 of Qwest' s proposal states; "Upon completion of the orders identified on
the batch spreadsheet, Qwest will notify the CLEC via email that it has completed the
conversion. It remains the responsibility of the CLEC to ensure that each line is
triggered for number porting upon completion of the order." This is totally
unacceptable from a quality of customer service standpoint. From the moment that
Qwest migrates the customer s line on the MDF to the time that the CLEC issues the
trigger to port the customer s number, the customer cannot receive phone calls.
Considering that Qwest has indicated that a batch project can be as many as 100 lines
and Qwest has its technicians performing all of the work (e.g. pre-wiring, dial tone
checks, telephone number verifications, and actual "lift and lay" cutover) to migrate
these lines on the day of the cut it could literally take hours between the time the first
lines are cut over to the CLEC and the CLEC is informed via email of the completion
ofthe cutover. Leaving a customer without the ability to receive calls for this length
of time is totally unacceptable. Qwest must revisit its position regarding the timing of
the CLEC notification to make this proposal acceptable in this area.
Qwest's proposal of basic installation only clearly sacrifices the CLEC'
customer s experience for some yet unquantified benefit.
2. Pre-wiring of the circuit
For individual hot cut orders, Qwest currently performs the Main Distribution
frame ("MDF") pre-wiring of the CLEC's Connecting Facility Assignment ("CF A"
to the loop two days prior to the cutover. This lead time gives the Qwest frame
technician ample time to ensure all of the wiring work has been performed correctly,
and is connected to the proper CFA assignment for CLEC's collocated equipment and
to the proper cable and pair assignment for the customer s line. However, when this
pre-wiring is performed on the day of the cutover, as proposed by Qwest's batch
process, there is no margin for error on the part of the Qwest or the CLEC.
Considering Qwest's frame technicians work on activities other than batch hot cuts
including individual hot cut orders, new line installs for both retail and wholesale
customers, disconnect orders and trouble shooting of maintenance and repair trouble
tickets, many times these technicians may be stressed to the limit to complete all of
their work for that day. This is especially true in cases where the batch job
approaches the Qwest proposed 100 line limit. AT&T feels that to help ensure
continuity of customer service, this pre-wiring function must continue to have at least
a one day lead time from the batch project due date. Qwest's proposal to eliminate
the pre-wiring step sacrifices service quality and the customer s experience solely for
Qwest s oWfl efficiency.
3. Qwest's proposed spreadsheet
Qwest is short on details regarding how this spreadsheet is to be prepared and
how it is going to be used. AT&T supports the use of an electronically prepared
spreadsheet developed by Qwest's OSS' s based on the information supplied on the
batch project LSRs. However, if it is Qwest's intention to develop these spreadsheets
manually, this adds yet another human touch point to a process that is already very
manual. Human errors on this spreadsheet will create confusion and possibly delay
the project. They can also result in hot cuts being missed or service outages. Qwest
must be required to provide additional details on how this spreadsheet is to be
created, how it will be distributed to the stakeholders, what each stakeholder will use
the spreadsheet for, how the spreadsheet will be synchronized with the CLEC's LSRs
and Qwest's service orders and how errors found on the spreadsheet will be corrected.
In addition, creation of a spreadsheet appears on Qwest's proposed process as a new
step. It is likely that the spreadsheet creation step is going to put upward pressure on
Qwest's already uneconomic hot cut costs.
4. Dial tone checks
Qwest's current hot cut process requires the central office frame technician to
check for dial tone and verify the line for the proper telephone number two days prior
to the scheduled cutover date. Whereas, Qwest's batch hot cut proposal has its
technicians performing these verifications on the day of the cutover just prior to
performing the conversion. If a problem is discovered with the CLEC dial tone
Qwest's proposal gives the CLEC one hour to remedy the problem. If the problem
cannot be resolved, the affected line is removed from the project.
As was the case for the pre-wiring (item #2 above), AT&T is concerned that
performing this quality check on the day of the cut leaves no margin for error for
either Qwest or the CLEC. In cases where the no dial tone problem must be resolved
by the CLEC, often times one hour is not going to be sufficient, especially in
instances where the CLEC must dispatch a technician to its collocated equipment.
When the CLEC cannot quickly resolve these problems, the customer s line must be
removed from the batch project. When this happens for multi-line customers, the
CLEC must be assured that all lines for that customer are also removed from the
project to insure continuity of features such as hunting arrangements. Considering
the Qwest frame technicians will be working from either the individual internal
service orders that are created for each line that is included in the project or from the
proposed spreadsheet, it is not clear how the frame technician will be able to relate
the orders to make the determination that the line with no dial tone is associated with
a multi-line customer. It is also unclear how the technician will be able to determine
the other lines that need to be removed from the project even though they are not
experiencing the same no dial tone issues. Additionally, Qwest's proposal is silent on
what occurs if the technician discovers a no dial tone condition or an incorrect
telephone number on the customer s cable and pair on the line side of the frame.
This would be a problem that Qwest would need to correct. AT&T can only assume
that these lines will also be removed from the project. If so, the same issue involving
multi-line customers is of a concern. AT&T believes that without further details on
how the dial tone checks will be performed and how the CLECs can be assured that
the right lines are being removed from the project the proposal as written is too risky.
In addition, a Qwest decision to remove one or more lines from the project must
be accompanied by a step to assure that Qwest does not disconnect the customer
service under the assumption that the cut would have been completed. In very short
8 These problems can occur as a result of inaccurate cable and pair inventory records.
order, Qwest technicians must be able to communicate to Qwest's back office
systems that an order has been removed from a project and to ensure that no
associated disconnect orders are inadvertently completed.
5. CLEC notification
In addition to the previously mentioned problems with the timeliness of the
notification, AT&T has a concern with regard to the quality of Qwest' s notification
process. Qwest's statement indicates that this notification will be based "upon
completion of the orders identified on the batch spreadsheet" yet; as discussed in item
4 above, some line may have to be removed from the project even in cases where they
did not have a no dial tone problem. Qwest has not indicated how the CLEC will
know exactly which of the orders identified on the spreadsheet were cut over and
which were not. Unless the CLEC has absolutely accurate information regarding the
exact identification of the lines that were cut, the CLEC may port numbers that it
should not be porting, thereby adversely impacting customer service.
Scalability
As an initial matter, Qwest claims that it provisions "000 hot cuts per day on
average.,,9 The most recent results that Qwest published for the OP- 7 Coordinated "hot
cut" interval- Unbundled loops - Analog measurement belie that claim. In September of
2003, Qwest completed 9 488 hot cuts in the entire 14-state region. Assuming a twenty
day work month, Qwest averaged about 475 hot cuts a day in September of2003 - nearly
half of Qwest's claimed rate. Over the last year , Qwest's OP- 7 results show that Qwest
averaged about 400 analog loop hot cuts a day in its entire 14-state region. This
9 Qwest Proposal, p. 7.
represents an average of28 per workday per state. Qwest's current average daily volume
of hot cuts in a state would barely make what Qwest identifies as a minimum batch for its
proposed batch hot cut process. Either Qwest's claim of 1 000 hot cuts per day is
erroneous, or Qwest is excluding significant volumes of hot cuts from the OP- 7 results.
Qwest needs to explain the incongruity between its claim of 1 000 hot cuts per day and its
OP- 7 results for analog loops.
The only specifics that can be found in Qwest's proposal regarding the scalability
of the process is that an individual CLEC must have at least 25 and no more than 100
lines in a given CO to qualify for a batch project. 10 Qwest also, on page 14 of its
proposal, makes the premature assumption of a finding of non-impairment and therefore
lays out the timetable with vague and inaccurate formulas for determining how many hot
cuts will be required to convert the embedded base ofUNE-P customers. AT&T believes
that the Commission should not take Qwest's assumption of a non-impairment finding
seriously. Notwithstanding Qwest indulging itself with a little wishful thinking, Qwest
needs to provide specific information in the following areas with respect to its ability to
handle significantly larger numbers of hot cuts.
1. Limitations imposed on the process
Other than the stated limit of one project consisting of no more than 100 lines per
day per CLEC, what other limits does Qwest impose on its process? Some examples
of questions that Qwest needs to address are:
Will Qwest work with multiple CLECs in the same central office on the
same day if the sum of the CLECs' batch proj ects does not exceed 100
lines (e.g. four different CLECs where each CLEC had a bulk project of
25 lines)?
10 One can assume that CLEC's who have more than 100 lines may break them up into individual batches
ofless than 100, however, that is not specified in the Qwest proposal.
Does Qwest impose any limits on the number of CLECs that can migrate
100 lines in a central office in a day?
Will Qwest allow a CLEC that had two different collocation
arrangements in the same CO to include facilities in each of the
arrangements on the same project?ll
Are there any limitations on the number of simultaneous batch projects
Qwest is capable of working within a given geographic area?
Are these projects limited to central offices that Qwest has staffed on a
full time basis or can a project be performed in any central office?
2. Potential Hot Cut Volumes
Qwest's formulas for estimating the potential hot cut volumes it will be faced
with in a mass market environment do not provide any specifics with respect to the
number of actual hot cuts Qwest estimates it will have to perform during the 27
month transition period. Instead Qwest states
, "
To calculate the expected monthly
volumes in each state, the state commissions should apply the following formulas
based on the volumes ofUNE-P lines and UNE-L lines in each individual state.
Rather than ask the state commissions to estimate the hot cut volumes based on a
formula that is neither clear nor accurate (e., the formula does not account for the
significant hot cut activity that will be required by customer churn and Qwest win-
backs), Qwest should come forward on a state by state basis with its estimate of how
many hot cuts will be required each month. Qwest must also provide the details on
how it came up with this estimate.
3. Additional Qwest Personnel
Assuming that Qwest's work centers, field technicians and central office frame
technicians are currently working at optimal capacity, Qwest needs to disclose how
many additional people it will need to add to its staff to meet the hot cut demand
11 CLECs will sometimes have multiple collocation arrangements in the same central office as a result of an
acquisition of another CLEC.
estimated in item #2 above. Qwest also needs to specify how it arrived at this
estimate and how it plans on recruiting, hiring and training these people to ensure that
they are qualified to perform the work that will be required of them without impacting
customer service. Additionally, Qwest needs to reveal how the hiring of these
additional people will impact the CLEC's hot cut costs.
Functionality of the proposed process
The Qwest proposal is extremely short on many of the details needed to determine
whether its proposed batch hot cut process will be functional. Additionally, in other areas
where Qwest did provide specific information it is clear that there is much room for
improvement to make the process of value. Following are some ofthe specific areas of
concern for AT&T with respect to the functionality of the process.
1. Project Intervals
Qwest must clearly state what its interval is between the time the CLEC initiates a
request for a batch hot cut project and the due date for the project. In a robust market
with many CLECs requesting batch projects these intervals cannot be individually
negotiated on a project-by-project basis. Qwest must publish its standard interval for
these jobs and be measured on its performance in meeting these intervals. This is
particularly critical if a CLEC wants to use this process for a migration from Qwest
retail to UNE-, a migration that Qwest states is supported by its bulk process.
Unless the CLEC can give its prospective customer a date certain of when the
migration will occur this process can never be used for the migration of retail
customers to a CLEC.
12 It is critical to note that even with standard intervals, unless the interval is reasonable (e.g. 6 business
days or less), this process will be virtually useless for migrating retail customers to UNE-
Additionally, the introduction of a standard interval for requesting a batch hot cut
project will eliminate the time/resource consuming step of conducting the initial batch
hot cut project coordination meeting required by the Qwest proposal. With a standard
interval a CLEC can initiate a project via a simplified email notification to Qwest of
its intent to engage in a batch project. This email would supply Qwest with the
details it will need, such as the central office location, the desired project date and
time and the number of customer accounts and lines involved with the project. Qwest
can respond to this email with the project code and a confirmation of the date which
would trigger the CLEC to issue its LSRs. While Qwest's proposal is not entirely
clear, it appears that unique Qwest-supplied project codes would be required on the
individual LSRs that a CLEC submits as part of the batch. Qwest needs to clarify
whether unique project codes are required on an LSR; and, if so, how those project
codes are obtained.
2. The process must be voluntary
Qwest's proposal indicates on page 11 that at the initiation of a project request "
CLEC will perform pre-order functions including an initial batch coordination
meeting with Qwest." The initiation of a batch project must be at the option ofthe
CLEC and cannot be dictated by Qwest. There are many factors that would prevent a
CLEC from wanting to perform a batch hot cut job in a specific central office, even in
cases where the CLEC may have the requisite quantity of lines to qualify for a batch
project. These factors include, but are not limited to, not having a collocation
arrangement in the central office, not having sufficient spare capacity on the
collocated equipment that the CLEC has in the central office and a temporary
congestion problem that the CLEC may be experiencing on its network. There should
be no mistake that the batch hot cut process that the parties will be creating is
voluntary on the part of the CLEC. A CLEC may conclude that Qwest has not
reduced the economic or operational impairments of hot cuts sufficiently to justify
converting a UNE-P customer to UNE-L. The true measure of the worth of Qwest's
batch hot cut process will be seen when CLECs voluntarily choose to exercise that
process.
3. Limits on loop types
Qwest's proposal limits the loop types that qualify for a batch project to analog
POTS loops and further underscores the operational impairment involved with hot
cuts. On page 9 of its proposal Qwest states
, "
A batch conversion process is possible
for these analog DSO loops, which constitute the vast majority of Qwest' s outside
plant. But it is not feasible to gain these efficiencies when the underlying facility uses
integrated digital loop carrier systems ('IDLC'AT&T agrees that when the Qwest
network is viewed as a whole, the analog DSO loops do constitute the majority ofthe
loops. However, the batch job is not performed on a network-wide basis; it is
performed at a central office level.
When viewed at a central office level, the IDLC restriction becomes a bit more
problematic. Qwest has many large central offices with over 30 000 lines that have
30% or more IDLC lines. This is particularly true in states such as Arizona
Washington and Colorado that have experienced a high degree of growth over the
past 10 years. In these states, as well as in some of the other states, there are many
central offices that would have a large proportion of the loops that terminate in the
office precluded from the batch hot cut process under the current Qwest proposal.
fact there are a number of offices that have more than 50% of their lines on IDLC
facilities. 13
To make this process functional in a mass market environment, Qwest needs to
revisit its removal of IDLC lines from the process. In addition, Qwest needs to
disclose to the commission and the CLECs what its capacity is for migrating these
lines in the high density offices to non-IDLC facilities as required for a hot cut.
wire centers with a high number of hot cuts, Qwest may be limited in the amount of
spare copper/UDLC facilities it can use to overcome the IDLC problem. Qwest needs
to explain how it will ensure the necessary inventory of spare non-IDLC facilities.
In addition to the restriction ofIDLC loops, Qwest's proposal restricts the
migration ofline splitting loops. Qwest's rational for this is two-fold. First, Qwest
states
, "
The FCC expressly defined its batch-cut requirements in terms of developing
a process to migrate loops "from one carrier s local circuit switch to another carrier
local circuit switch.The FCC's definition of a 'batch cut process ' thus does not
include conversions including loop-splitting arrangements that also connect an
unbundled loop to a third carrier packet switch." Footnote omitted; emphasis
added. Qwest goes on to state
, "
conversions from UNE-P directly to loop-splitting
arrangements cannot be consolidated into a batch because each loop must be
individually checked to ensure it is capable of carrying DSL signals and, if not
13 Per
Qwest's ICONN database. See www.qwestcomliconn.
conditioned.,,14 It seems that on both of these points Qwest seems to have misstated
the facts.
To the first point, when cutting over a loop to a CLEC using a line splitting
arrangement, the voice frequency portion of the loop does not go to the CLEC'
packet switch. After the loop is connected to the CLEC's splitter, the voice frequency
is connected to the CLEC' s circuit switch. Therefore , the line is being connected
from one carrier s local circuit switch to another carrier s local circuit switch" just as
the FCC had envisioned. Secondly, it is highly unlikely that a customer who is
receiving standalone POTS service via UNE-P is going to need to be migrated to a
DSL capable loop as described by Qwest. However, it is very likely that a customer
who is currently on a line splitting arrangement today where the voice service is
provided via UNE- P will need to be converted to line splitting when the CLEC is
using Qwest's loop and connecting the voice frequency to a CLEC's switch. In these
cases there is no need to determine whether the loop requires conditioning for the
DSL service because the customer is already receiving DSL service on a loop that is
already meeting the requirements for a DSL service. Qwest's rational for restricting
line splitting loops from the batch process is without merit. AT&T believes that
Qwest should remove this restriction from its proposed process.
4. CLEC-to-CLEC migrations
Qwest's proposal indicates that its batch process will support CLEC-to-CLEC of
migrations. However, Qwest is silent on how it plans to include these migrations into
the ordering flow for a batch hot cut. Given the current lack of industry procedures
14 See Qwest's proposal on pages 9 and 10.
on CLEC-to-CLEC migrations, AT&T believes that Qwest needs to provide specific
details on how it plans to incorporate these types of migrations into a batch project.
5. Project cutover times
Qwest's proposal on page 13 states; "The CLEC must make resources readily
available to clear all loops identified on the batch spreadsheet in a timely manner
between the hours of 3:00PM CST and 11:00PM CST." For any of us who have sat
around waiting for the telephone installer or repair person who is supposed to show
up between the hours of 8 AM and 5 PM, we know how inefficient a use of time this
is for the person kept waiting. In addition to providing the CLEC more timely notice
on the status ofthe project as described in the "Quality of Service" section ofthis
document, Qwest needs to be more specific as to what time the project is going to
start and what time it anticipates it will end to allow the CLEC to properly plan the
workload for its staff members. Additionally, there are going to be times when
because of the nature of the customers being cutover, a CLEC may not wish to have
the migrations performed between the hours of 3:00PM and 11:00 PM. In these cases
the Batch process should be flexible enough to allow the CLEC to request a batch hot
cut project at any time ofthe day and on any day of the week.
6. Pending orders
The Qwest process has the CLEC issuing LSRs for the lines involved in the
project. However, as stated in #1 above, without knowing what the interval is for
these LSRs they may be waiting a considerable amount oftime in Qwest's systems as
pending orders before the due date of the batch project. Considering that these orders
will most likely be exclusively for existing CLEC customers, it is not clear what
happens to that order should the CLEC needs to issue an interim order to make a
change on the existing customer s account (e.g. a feature change to a UNE-
customer). Additionally, Qwest needs to clarify what the process is for ensuring that
the customer s line does not get migrated as part of the batch process in cases where
the customer churned over to another carrier in the time between when the batch
order was issued and the due date of the batch project.
7. Service outages
Qwest needs to make clear what the process is for the CLEC to quickly resolve
service outages discovered after the CLEC receives the project completion
notification. Specifically, will there be a process in place for a "throw-back" ofthe
affected customer s line to its original state to quickly restore the customer s service
or will the CLEC have to go through the normal trouble reporting process? AT&T
believes that Qwest needs to have a process in place that will allow Qwest and the
CLEC to work cooperatively to restore the customer s service in an expedited time
frame.
8. Testing the process
Qwest's proposal is also silent on how it proposes to test its batch hot cut proposal
to make sure it is operational. Because the industry has absolutely no experience with
operating in a mass market environment using a manual hot cut process, any process
being proposed must be thoroughly tested to guarantee its operational readiness.
Because of the incentive that Qwest has to make such a test appear that its proposed
process is flawless, AT&T believes that this testing should be closely monitored by
the Commissions and an independent third-party tester. Additionally, AT&T believes
that this test should not impact any CLEC customer s service and, therefore, should
be conducted by having Qwest using its proposed process to migrate a significant
number of its OWfl retail customers from a direct connection of the customer s line
from the existing Qwest switch over to another Qwest switch connected via
collocated equipment located in the original central office. Testing should include
independent third-party monitoring ofthe conversion activities and monthly
monitoring of performance results for the converted customers.
III.CONCLUSION
AT&T is encouraged by the fact that Qwest has taken the initial step to propose a
batch hot cut process. However, as indicated by these comments, AT&T has many
serious concerns about the cost, customer impact, scalability and functionality of the
process that was outlined by Qwest in its batch hot cut proposal. Additionally, AT&T is
also concerned about the necessary details that were not addressed by Qwest.
AT&T looks forward to working collaboratively with Qwest and the other
industry participants to work through the Qwest proposal to resolve these initial issues
identified by AT&T and issues that are raised by other participants. This collaborative
should also determine what other improvements need to be made to improve upon the
Qwest proposal and make the batch hot cut process one that is beneficial to Qwest, the
CLECs and, most importantly, to the end-user consumer.
Respectfully submitted this 17th day of November 2003.
AT&T COMMUNICATIONS OF THE
MOUNTAIN STATES, INC.
By:
Mary B. T bby
Letty S.D. Friesen
AT&T Communications of the
Mountain States, Inc.
1875 Lawrence Street, Room 1575
Denver, Colorado 80202
Telephone: [phone]
Facsimile: [phone]
E-mail: Isfriesen~att.com
Robert M. Pomeroy Jr.
Holland & Hart LLP
8390 E. Crescent Parkway, Suite.400
Greenwood Village, CO 80111-2800
Telephone: [phone]
Facsimile: [phone]
E-mail: rpomerov(gi,ho llandhart. com
CERTIFICATE OF SERVICE
GNR-03-
I certify that the original and seven copies of AT&T' Comments and Counter Proposals on Qwest
Corporation s Batch Hot Cut Proposal in Docket No. GNR- T -03-23 were sent by overnight
delivery on November 17 2003 to:
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, ID 83702-5983
and a true and correct copy was sent by U. S. Mail, postage prepaid, on November 17 2003 to:
Brian Thomas
Time Warner Telecom
223 Taylor Avenue North
Seattle, W A 98109
Dean J. Miller
McDevitt & Miller LLP
420 West Bannock Street
Boise, ID 83702
Marlin D. Ard
O. Box 2190
Sisters, OR 97759
Charles Carrathers
Verizon Northwest, Inc.
1800 41 st Street
Everett, W A 98201
Adam L. Sherr
Qwest
1600 ih Avenue, Room 3206
Seattle, WA 98191
Mary S. Hobson
Stoel Rives LLP
101 S. Capitol Blvd., Suite 1900
Boise, ID 83702-5958
Clay R. Sturgis
Moss Adams LLP
601 W. Riverside, Suite 1800
Spokane, WA 99201-0663
Conley E. Ward
Givins Pursley LLP
277 North 6th Street, Suite 200
Boise, ID 83701
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