June 11, 1999

Amy Putnam, Esq.

Public Utility Commission

Commonwealth of Pennsylvania

P.O. Box 3265

203 North Office Building

Harrisburg, PA 17105-3265

Dear Ms. Putnam:

In the Pennsylvania Public Utility Commission order in Docket No. M-00991228 dated April 29, 1999 and entitled “Contract for Evaluation and Testing of Bell Atlantic-PA Operations Support Systems”, it states on p. 7, “We direct KPMG to consider testing of unrestricted residential UNE-P and business UNE-P.” This letter contains our recommendations with regard to this matter.

From discussions we at KPMG have had with you, we understand the term “unrestricted” to mean the fullest possible range of UNE-P products. From a purely network perspective, we believe that there is no reason that any product that Bell Atlantic-PA makes available to CLECs through resale could not be made available as a UNE-P product also. This would include not only POTS but also other more complex products such as ISDN (both BRI and PRI), private line, Centrex, and PBX trunking. However, in order for KPMG to fulfill the objective of the test in evaluating the Bell Atlantic-PA operations support systems (OSS), it would be necessary for Bell Atlantic-PA to incorporate such products into their OSS in order to provide a meaningful test. In particular, Bell Atlantic-PA would need to incorporate the products into their ordering, maintenance and repair, and billing systems. Instead, in what they have made available to KPMG for the purposes of this test, Bell Atlantic-PA has chosen to limit the UNE-P product set to POTS and a restricted form of ISDN BRI.

KPMG believes that there are three basic approaches that could be taken at this point:

  1. Take the maximal approach and require Bell Atlantic-PA to make all possible UNE-P products available to KPMG for this test through its normal OSS. This would require the PUC to direct Bell Atlantic-PA to modify its OSS in order to incorporate these products. We believe that the most significant modifications would likely be required in the ordering and billing systems.
  2. Require the full range of products to be made available to KPMG but require them to be handled outside of the scope of the normal Bell Atlantic-PA OSS. This would probably involve such activities as the faxing of orders and manual production of bills.
  3. Confine the test to the set of products that Bell Atlantic-PA has made available.

After consideration of these alternatives, KPMG recommends the third alternative. While the first alternative best meets the spirit of the order and addresses the concerns of a number of the CLECs, we believe that it could significantly delay the test while Bell Atlantic-PA modifies its OSS. Furthermore, if the PUC did not choose ultimately to require these products to be offered by Bell Atlantic-PA, it would burden Bell Atlantic-PA with an unnecessary additional costs and tie up resources in our test on issues without any future relevance. The second alternative would avoid the problem of a test delay and the necessity for additional Bell Atlantic-PA OSS modifications. However, it is unclear how meaningful the test would be to an evaluation of Bell Atlantic-PA OSS for UNE-P products.

The third alternative seems, then, to be the most expeditious. Please confirm that the UNE-P products tested in the KPMG test should be restricted to POTS and BRI ISDN.

Very truly yours,

Raymond W. Sears III

San Francisco Consulting Group/KPMG LLP

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