20031118Response of MCI to Qwest Proposal.pdf

ORIGINAL HECEIVEO (3)iLED
ZUG3 NOV 18 PH 4: 1
Dean J. Miller (ISB No. 1968)
McDEVITT & MILLER LLP
420 West Bannock Street
O. Box 2565-83701
Boise, Idaho 83702
Tel: [phone]
Fax: [phone]
I /\:;0 FU;:.LIC
UTILITIES COf1MISS1OH
Attorneysfor WorldCom, Inc./MCI
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 OF ECONOMIC AND
OPERATIONAL IMPAIRMENT REGARDING
ACCESS TO SPECIFIC UNES
Case No. GNR-03-
MCI'S RESPONSE TO
QWEST'S PROPOSAL FOR
REGION-WIDE BATCH
LOOP CONVERSION
PROCESS
WorldCom, Inc., on behalf of its regulated subsidiaries
, ("
MCI") submits this response to
Qwest Corporation s ("Qwest") proposal for a region-wide batch hot cut ("BHC") process. These
are preliminary comments based upon MCr's review of Qwest s proposal in less than a week.
Qwest's proposal is being circulated within MCI to its relevant business units and its information
technology personnel for review and comment. Accordingly, MCI requests and reserves the right
to provide additional and more complete comments as the 14-state collaborative forum progresses.
INTRODUCTION
Qwest has made a number of legal arguments concerning what it believes it is obligated to
provide for a batch hot cut process. MCI does not intend to address those legal arguments in depth
in this preliminary filing. Rather, MCI will state from a business perspective what it needs for a
batch hot cut process.
MCI'S RESPONSE TO QWEST'S PROPOSAL FOR REGION-WIDE BATCH LOOP CONVERSION PROCESS-
Although Qwest states that its current process to convert lines from one competitive local
exchange carrier s ("CLEC") circuit switch to another in a "batch process , is adequate, it
nevertheless has proposed modifications which, in MCr's opinion , are not sufficiently defined and
create risks that the end user customers may have a greater likelihood of losing service for longer
periods of time. In other words, Qwest's proposed changes tend to reduce the quality of services
proposed, for example, by eliminating certain testing, by eliminating the sending of test results, by
contacting CLECs bye-mail to notify of the completion of a hot cut, and by doing pre-wiring on
the day of the cut instead of in advance of the cut. This elimination of services associated with
conversion of lines poses greater risks to end users that their lines will be out of service longer
that the cut will not take place when scheduled, or that other service failures will increase.
Nevertheless, MCI remains hopeful that procedures and practices eventually emanating
from the Qwest s BHC process will help to facilitate the orderly and seamless migration of a
portion of its current, or embedded, UNE-based mass market customers to services provided
over unbundled loop ("UNE-) facilities purchased from Qwest and switching facilities owned
and/or controlled by MCI itself in areas where it is economically viable to do so. It is MCr's
expectation that any processes designed to facilitate such a migration will be efficient, economical
and, most importantly, non-customer impacting. MCI does not believe, however, that the mere
identification - as distinguished from the designing, testing, implementing and on-going
performance in a commercial environment - of a BHC process is sufficient to address questions of
actual impairment.
Mcr encourages Qwest, the Commission and its Staff, and all other Parties involved in this
collaborative forum to recognize that the establishment or modification of a BHC process must be
considered along with all other affected systems, procedures and practices in order to verify that
MCI'S RESPONSE TO QWEST'S PROPOSAL FOR REGION-WIDE BATCH LOOP CONVERSION PROCESS-
each such system, procedure and practice will effectively perform its designed functions
simultaneously under commercial loads. Also, a BHC process must address other areas of
impairment relating to other types of hot cuts - such as CLEC-to-CLEC migrations, CLEC-to-
ILEC migrations which will occur after the embedded base of a given has been transitioned to
UNE-L in a given geographic market or the migration of customers who have CLEC data services
from UNE-P line splitting to UNE-L line splitting.
MCI also encourages Qwest, the Commission and its Staff, and all other Parties involved
in this collaborative forum to remain focused on the long-term objectives involved with the
establishment of an efficient BHC process and to consider not only the short-term, manual
modifications, but the longer term possibilities including, for example, the wider implementation
of GR303 capable Integrated Digital Loop Carrier ("IDLC") systems which would allow for the
unbundling of IDLC based loops without migration to "other facilities " which often times
contributes to additional manual processing, delays and errors. The use of automated or robotic
frames should also be contemplated as a longer-term solution, particularly in unmanned central
offices ("CDs ) similar to those in which such technologies have already been tested, proven and
are currently operational.
Finally, consideration must be given to a competitively neutral cost recovery mechanism
for all costs. Qwest has failed to provide any total element long run incremental cost ("TELRIC"
studies or proposed any new rates for its proposed BHC process. This is critical since the pricing
must reflect Qwest's efficiencies gained from the BHC process. For instance, the BHC process
will significantly reduce coordination costs and such reductions should be reflected in the
economic costs.
MCI'S RESPONSE TO QWEST'S PROPOSAL FOR REGION-WIDE BATCH LOOP CONVERSION PROCESS-
SUMMARY OF MCI'S BHC PROCESS CRITERIA
The Federal Communications Commission s ("FCC") BHC process must be implemented
by Qwest for purposes of provisioning unbundled loops. (see FCC rule ~51.319( d)(2)(ii)). Any
BHC process implemented by MCI, including the internal systems/processes needed to
complement the Qwest process, will be directly affected by Qwest's BHC process ultimately
adopted by the Commission. It is not possible to identify all relevant CLEC operational issues in a
vacuum, because the systems of both Qwest and the CLECs must be considered together. That is
systems and processes must be in place in the functional areas of pre-ordering, ordering,
provisioning, and maintenance and repair in order to identify all operational issues.
There are, however, certain criteria that MCI believes must be captured by Qwest's BHC
process to be consistent with the FCC'Triennial Review Order TRO"
).
Those include at least
the following:
The process must be largely mechanized if it is to comply with the FCC's
requirements of seamlessness, scalability and low cost. MCI believes that the mechanized process
currently available for UNE-P migrations stands as a workable benchmark against which any
seamless, scalable and low cost BHC process should be measured.
The process must be largely free of exclusions, i., a CLEC must be allowed to use
the process to move any loop from another carrier s circuit switch to its own circuit switch. This
should include any line splitting scenarios, any equipment types such as IDLC and should not be
restricted by class or size of an end user customer.
The BHC process should not only accommodate these loops from a physical provisioning
standpoint, but should also include them in any performance metrics as well. The FCC places no
restrictions on the BHC process relative to different types of loops and MCI believes such
MCI'S RESPONSE TO QWEST'S PROPOSAL FOR REGION-WIDE BATCH LOOP CONVERSION PROCESS-4
restrictions would dramatically reduce the benefit and effectiveness of the BHC process as
envisioned by the FCC.
The process should maximize the ability for both Qwest and CLECs to rely upon
existing electronic bonded systems, such as electronic data interchange ("EDI"). While
opportunities exist for enhancements in this area, such as the passing of status information relative
to BHC pre-wiring, wiring, LNP in real-time, and system-to-system interface, graphical user
interfaces ("GUI") interfaces should be used only as a last resort but nevertheless be available to
obtain information. CLECs should be allowed to submit orders which identify a given hot cut
batch, using EDI or other established ordering mechanisms that generally flow through their
existing systems for individual or multiple lines. Qwest should not be allowed to require some
type of manual ordering scenario or require the CLEC to provide spreadsheets, or "cut sheets
even if such sheets are required for ordering loops today. Indeed, there should never be a need to
call Qwest provisioning centers or to exchange faxes or other time consuming and error prone
exchanges of information.
The BHC process should provide both a coordinated hot cut ("CHC") and frame
due time ("FDT") option. Both options should include a due date scheduling function that can be
accessed electronically by CLECs.
Performance measures, remedies and commercial testing must be an integral part of
any approval process. Again, the existing UNE-P migration process and related performance
criteria should be used as a starting point for these exercises. Provisioning intervals should be
established in advance. A CLEC should not be required to "negotiate" the provisioning date for
each BHC in advance.
MCI'S RESPONSE TO QWEST'S PROPOSAL FOR REGION-WIDE BATCH LOOP CONVERSION PROCESS-
The appropriate average completion intervals for BHC processes should be similar, if not
identical, to the existing UNE-P migration process and the applicable completion intervals that
exist therewith. Consistent with MCr's primary concern relative to the applicable customer
experience, it is absolutely imperative that the customer be completely oblivious to whether he/she
is being served via UNE-P or UNE-, or when that change in provisioning technology might have
taken place. Part of that transparency is the ability to serve customers on a relatively short
timeframe, consistent with the timeframe available using UNE-P today. Completion intervals for
the BHC process that exceed existing UNE-P migration intervals will not provide adequate
transparency for the customer and will negatively impact a CLEC's ability to effectively compete.
After having established proper metrics, the Commission should establish a testing
schedule for at least the long-term process to ensure that all systems work as advertised under
testing and commercial conditions.
After Qwest has successfully completed BHC process testing, a TELRIC-compliant
rate that reflects the efficiencies resulting from the "batch" processes must be established. MCI
would expect a rate structure that would reflect costs for the initial hot cut and additional hot cuts.
The pricing might also vary by 2-wire and 4-wire circuits. There is currently no detail in Qwest's
filing that would help MCI understand the pricing structure or underlying costs.
SPECIFI C COMMENTS
Qwest's filing begins by suggesting that the TRO's comments about problems with the
incumbent local exchange carriers ' current hot cut processes does not apply to Qwest , because its
Arizona 27l application was reviewed, presumably by the FCC, with the TRO findings in mind.
Nothing supports this assertion in the TRO. The TRO speaks to mass markets hot cuts at high
volumes so that customers may be transitioned from UNE-P to UNE-L. Nowhere does the TRO
MCI'S RESPONSE TO QWEST'S PROPOSAL FOR REGION-WIDE BATCH LOOP CONVERSION PROCESS-
state that Qwest has a process that meets its new criteria of a seamless, scalable, low-cost process.
The FCC has had Qwest's current process under 271 review for some time , and ifthe FCC
considered Qwest's process to be adequate , it likely would have said so and provided guidance to
other ILECs and CLECs.
Qwest states that its process applies when a CLEC has "requisite number of lines" and
defines that as 25 lines. MCI may want a lower number based on unique customer requirements
or other circumstances. CLECs should be allowed to determine a minimum or maximum amount
of orders to send per batch, per CO. This change allows CLECs the opportunity to continuously
examine their UNE-P customer base and/or targeted sales volume by CO location and make
informed decisions about which COs to convert with a BHC and which would be best served by
individual orders.
In addition, Qwest must define "sufficient volumes" for CLEC-to-CLEC migrations and
must provide another seamless process to move these customers. If MCI has to transition its
customer base, it appears that Qwest is stating that MCI cannot use the BHC if MCI does not have
enough lines/customers/orders for a Qwest-defined batch. This needs to be clarified.
MCr's initial transition ofUNE-P customers will be UNE-L with LNP 100% of the time.
Qwest must clarify how many orders it is able perform per CO, per CLEC in a single day for both
CHC and FDT hot cuts. In its proposal (Exhibit 7), it sets a cap at 100 "orders" per day, per CO.
While Qwest states that it will do batches of at least 25 "lines , its proposal does not address
multiple CLECs and the largest number ofBHCs it can do in a single day per CO. Qwest
discusses completing orders with line splitting during "normal business hours" but doesn t define
those hours or indicate whether batch cuts will be completed at times other than normal business
hours. These timing issues are critical since Qwest's process envisions "phoning the CLEC" to
MCI'S RESPONSE TO QWEST'S PROPOSAL FOR REGION-WIDE BATCH LOOP CONVERSION PROCESS-
resolve issues. Qwest's proposal includes only POTS lines; however, as noted above MCI also
requires that IDLC lines and line splitting/line sharing loops be included. It is MCr's
understanding that other incumbent local exchange carriers will include IDLC in their BHC
processes. Finally, Qwest uses "lines" and "orders" in addressing sizing and BHC limitations.
The correct nomenclature needs to be clarified.
The BHC (CHC and FDT) process and relevant systems and related processes must apply
to multiple scenarios including, but not limited to, CLEC UNE-P to UNE-L (same CLEC), CLEC
UNE-P to ILEC-retail, CLEC UNE-P to CLEC UNE-L (different CLEC), CLEC UNE-L to CLEC
UNE-L (different CLEC), just to name a few. All of the functional areas are implicated in one or
more ways-and more importantly, in different ways-by the various possible serving scenarios.
By way of example, beyond the processes associated with the physical cutover of Qwest' s loop to
the CLEC's collocation are numerous critical database issues , including Line Information
Database ("LlDB"), Customer Name ("CNAM"), 9-1 Automatic Location Identification ("ALl),
and directory listings and NP AC-Number Portability Administration Center impacts. Each of
these databases contains customer-impacting data, and there is a critical need to develop
coordinated, seamless, and scalable processes and systems addressing all of the possible serving
scenarios to avoid putting at risk a variety of customer features and functionalities
When MCI transitions its customers from UNE-P to UNE-L in a specific CO, MCI will
likely transition all lines in a given CO. MCI will also require migrating a line splitting line from
one carrier s circuit switch to another" when MCI moves an in-place line splitting customer. The
fact that CLECs continue to have an interest in the provision of DSL-based services-including,
for example, via line-splitting-adds yet another level of difficulty to the complexities already
MCI'S RESPONSE TO QWEST'S PROPOSAL FOR REGION-WIDE BATCH LOOP CONVERSION PROCESS-
noted. Loop splitting thus remains a critical area that must be reviewed and tested prior to any
finding that the BHC process has been adequately addressed.
Qwest must provide a detailed summary of its "new business rules" associated with the
process and a time frame for implementation. The final business rules cannot be developed
however, until the process is fully defined, in place and tested. Qwest must also provide
information on the current OSS used for this process and whether the orders "flow through" and
whether and under what circumstances orders will fall out to manual processing. The process
must be applicable for both EDI and GUr. Qwest's BHC Provisioning Flow (Exhibit 6) is not
nearly detailed enough. Finally, the BHC process must be implemented and tested to prove it is
effective and working as defined. Testing must also ensure that the BHC process works as defined
under commercial loads. There must be new metrics for the new process.
MCI does not want to have meetings to negotiate due dates. Spreadsheets or cut sheets
sent to the CLEC by Qwest are inadequate and cause delay. Qwest must develop an automated
due date scheduler or some other method of time selection that will allow CLECs to know when
the process can start and be completed. Negotiations and contacts with project managers must not
be required and only serve to increase the time required for the transitions. Qwest should develop
an electronically bonded and on-line system for communicating with CLECs similar to the
Verizon Wholesale Provisioning Tracking System ("WPTS") system.! This will eliminate work
steps and miscommunications and enhance efficiencies. MCI does not believe that a good process
requires that problems will be communicated by phone calls. This takes time and is a manual
process prone to errors. An on-line, real-time electronic system should be used.
1 By referencing the Verizon system does not mean that MCI considers that system in its presently identified status to
be ideal or acceptable to MCI; however, it is one form of an electronically bonded and on-line system for
communicating with CLECs.
MCI'S RESPONSE TO QWEST'S PROPOSAL FOR REGION-WIDE BATCH LOOP CONVERSION PROCESS-
Delaying a dial tone check and the final jeopardy until the day of the cut is dangerous for
consumers. MCI also disagrees with Qwest's proposal that CLECs be informed of cut completion
via an e-mail. This is a wholly manual process that will lead to additional problems. The
completion of the cutover should trigger an electronic service order completion ("SOC") notice
within 1 0 minutes of the cut in order to prevent undue delay for the LNP process calls for an
extended period of time that consequently delays when customers will be able to receive calls.
The Qwest BHC process takes a step backwards from the "migrate by telephone number
TN") procedures that MCI previously requested and were recently implemented by Qwest as a
result of MCr' s change request submitted through Qwest's change management process. CLECs
should not have to send service addresses or customer code for any ofthese orders. Moreover
Directory listings must be "migrated as is . Qwest must specify all ordering requirements. Qwest
must also provide the highest number of number portability transactions (ILEC to CLEC, CLEC to
ILEC, and CLEC to CLEC) done on one day over the past year. Additionally, Qwest must
provide a description of any metrics or measurements relating to the accuracy and seamlessness of
LNP transactions, both pertaining to conduct ofNeuStar and also relating to conduct of carriers in
general. Finally, Qwest's proposal eliminates the dial tone check two days prior to the cut date
DD-) and moves the dial tone check to the day of cut. This will not give the CLEC time to fix
any problems and will cause customer dissatisfaction.
Finally, some general observations are appropriate. Qwest never really discusses number
porting and how quickly after the BHC is completed, the TN is released. Qwest does not address
whether it will notify a CLEC only after the entire batch is completed or after a certain number of
orders within the batch are completed in order to allow the CLEC to continue updating its systems.
In Exhibit 6, Qwest refers standard "Record Retention Process , but does not describe that process
MCI'S RESPONSE TO QWEST'S PROPOSAL FOR REGION-WIDE BATCH LOOP CONVERSION PROCESS -
or what it entails. In Exhibit 7, under "CLEC Impacting , in the 1 st bullet there is a reference
order entry and prioritization of BHC by Qwest. What is Qwest prioritizing? Under "Qwest
Requirements , in the 2nd bullet, MCI does not need a spreadsheet from Qwest after the FOC, the
FOC should be sufficient. Finally, Qwest has not proposed a "throwback'" timeframe , during
which period such as three hours, after a cut has taken place, the CLEC can request the customer
be returned to UNE-P to address any subsequent problems that might arise and maintain a
customers telephone service.
RECOMMENDATIONS AND CONCLUSIONS
Allow CLECs to determine a minimum or maximum amount of orders to send per
batch per CO. This change allows CLECs the opportunity to continuously examine UNE-
customer base and/or targeted sales volume by CO location and make informed decisions about
which CO's to convert with a BHC and which would be best served by individual orders.
Allow CLECs to designate orders as part of a batch via a unique identifier on
individual LSR. CLECs should control which orders will be subject to BHC process and will
minimize changes to CLECs' order processing stream for order creation , work flow management
error resolution and reporting.
The data on LSR should be similar to what is required for UNE-P Migration-
minimal address fields, CF A, etc. This will minimize changes to LSR data population and reduces
chance for rejects because requiring less information means less editing by Qwest.
LSRs will specify a due date five (5) business days in the future. This interval
minimizes the amount of time a customer is held in a "limbo" state of no changes.
Qwest must process batch orders when received (first in first out). Qwest must
send both electronic and on-line notification to CLEC within 1 day of reject or if Busy carrier
MCI'S RESPONSE TO QWEST'S PROPOSAL FOR REGION-WIDE BATCH LOOP CONVERSION PROCESS -
facility assignments ("CF As ) are found. CLECs can expect a specific cutover window and better
manage the customer s experience. This also allows CLECs time to correct any CFA issues.
Qwest must refrain from any order activity against a customer s account while the
batch order is pending, except to cancel an individual batch order, or if a disconnect of dial tone or
migrate away order has a more current date than the conversion order (after which changes could
be made). Qwest should send electronic and on-line notification to CLEC if this should
nevertheless, occur. This still leaves the customer in a "no change" situation. However, selecting
a due date and shortening the due date interval positions CLECs to better manage their customers
expectations of when a change can be made to their account. Allowing disconnect or migration
away orders to override conversion orders will minimize delays the customer could experience
trying to migrate to other carriers after converting to UNE-
Qwest must send both electronic and on-line notification to CLECs 2 days prior to
cut date if there is no dial tone. "No Dial Tone" issues must be identified prior to the BHC in
order to allow CLECs time to correct prior to the cut date.
Qwest must send both electronic and on-line notifications as soon as BHC has
taken place. Ultimately notification should be real-time, but in any case no longer than 10 minutes
after cut completion. This also allows CLECs to develop better back-office processes for those
customers with time-sensitive needs, such a small business customers.
Qwest must submit the number-port activation order to NP AC w/in 10 minutes
after the BHC was completed on the due date. This offers potentially the quickest turnaround for
NP AC notification. Qwest would trigger its NP AC Release order within a specified interval, such
as 5 minutes, after cut completion, then initiate the winning CLEC's Port-In order to NPAC within
MCI'S RESPONSE TO QWEST'S PROPOSAL FOR REGION-WIDE BATCH LOOP CONVERSION PROCESS -
a specified interval, such as 5 minutes. CLECs would also need notification after successful
completion of each step.
10.Qwest must send EDI provisioning and completion notifications to close out LSR.
This is consistent with UNE-P workflow process. This would a CLECs to continue to acquiring
customers using UNE-P and convert after acquisition. This would also give CLECs the option to
continue acquiring customers and allow for churn.
11.Qwest must ensure the following are included in the batch hot cut process: l.
CLEC-to-CLEC UNE-L migrations, 2.) Lines provisioned with DSL, and 3.) Lines provisioned
by IDLe. This will remove the cumbersome "pre-qualification" selection for batch candidates and
minimize fallout.
Dated this 18th day of November, 2003.
~/~~
-1'7 Dean 1. Miller
McDEVITT & MILLER LLP
420 West Bannock Street
Boise, Idaho 83702
Attorneys for WorldCom, Inc./MCI
MCI'S RESPONSE TO QWEST'S PROPOSAL FOR REGION-WIDE BATCH LOOP CONVERSION PROCESS -
Certificate of Service
I hereby certify that on the 18th day of November, 2003, I caused to be served by the methodes) indicated
below, the foregoing document upon:
Charles Carrathers
VERIZON NORTHWEST INC.
180041" Street
Everett, Washington 98201
Tel:
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chuck. carra thers(fYverizon. com
Marlin D. Ard
ATTORNEY AT LAw
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Sisters, Oregon 97759
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marattv(fYqwest. net
Mary B. Tribby
Letty S.D. Friesen
AT&T COMMUNICATIONS OF THE MOUNTAIN STATES
1875 Lawrence Street, Suite 1575
Denver, Colorado 80202
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Robert M. Pomeroy, Jr.
HOLLAND & HART
8390 East Crescent Parkway, Suite 400
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Brian Thomas
TIME WARNER TELECOM
223 Taylor Avenue North
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Mary S. Hobson
STOEL RIVES LLP
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MCI'S RESPONSE TO QWESTS PROPOSAL FOR REGION-WIDE BATCH LOOP CONVERSION PROCESS -