REDACTED – For Public Inspection
Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554
In the Matter of
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Joint Application by SBC Communications Inc.,
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Illinois Bell Telephone Company, Indiana Bell
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Telephone Company Incorporated, The Ohio Bell
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/WC Docket No. 03-167
Telephone Company Wisconsin Bell, Inc. and
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Southwestern Bell Communications Services, Inc.
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for Provision of In-Region, InterLATA Services
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in Illinois, Indiana, Ohio, and Wisconsin
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JOINT REPLY AFFIDAVIT OF
JUSTIN W. BROWN, MARK J. COTTRELL AND BETH LAWSON
REGARDING OPERATIONS SUPPORT SYSTEMS
AND THE LOCAL SERVICE CENTERS
TABLE OF CONTENTS
SUBJECT / PARAGRAPHOSS TEST ISSUES / 6
CHANGE MANAGEMENT / 10
“Unreject” Functionality / 10
Test Environment / 31
Versioning / 37
PRE-ORDERING / 42
CORBA Availability / 42
Living Unit Database / 54
ORDERING / 58
Reject Issues / 58
CLEC-To-CLEC Conversions / 67
Post To Bill Notices and Subsequent Orders / 76
Cross Boundary / 104
MISCELLANEOUS ISSUES / 107
IP Addresses / 107
911 / 116
CIMCO Communications Issues / 121
Line Loss Notifications / 145
Performance Measurements / 156
CONCLUSION / 162
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Schedule of Attachments
Attachment A / Michigan Cottrell AffidavitAttachment B / Michigan Cottrell/Lawson Reply Affidavit (Confidential)
Attachment C / Michigan Cottrell/Lawson Supplemental Affidavit
Attachment D / Michigan Cottrell/Lawson Supplemental Reply Affidavit
Attachment E / History Log for “Unreject” CCR
Attachment F / Michigan March 17, 2003 ex parte
Attachment G / E-mail to AT&T on July-August CORBA Outages
Attachment H / June 2003 CORBA Outages
Attachment I / Individual CLEC Reject Rates (Confidential)
Attachment J / AOI Reject Errors for June 2003 (Confidential)
Attachment K / SBC CLEC-to-CLEC Migration Policy
Attachment L / August Illinois LLN Report
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We, JUSTIN W. BROWN, MARK J. COTTRELL, and BETH LAWSON, being of lawful age, being duly sworn, depose and state:
1.My name is Justin W. Brown. I am General Manager – Local Service Center (“LSC”) / Local Operation Center (“LOC”) Regulatory. My background and qualifications are provided in the Justin W. Brown Affidavit for the Illinois, Indiana, Ohio, and Wisconsin application filed on July 17, 2003.[1]
2.My name is Mark J. Cottrell. I am Executive Director – Long Distance Compliance – Operations Support Systems (“OSS”) for SBC Midwest.[2] My background and qualifications are provided in the Joint Affidavit of Mark J. Cottrell and Beth Lawson for the Illinois, Indiana, Ohio, and Wisconsin application filed on July 17, 2003.[3]
3.My name is Beth Lawson. I am employed by SBC Management Services, Inc. as Executive Director – Regulatory Compliance. My background and qualifications also are provided in the Four-State Cottrell/Lawson Affidavit.
4.The purpose of this affidavit is to respond to CLEC allegations in this proceeding regarding SBC’s OSS Test for the individual states, pre-order interface stability, 13-state common systems and practices, and other miscellaneous issues. While this reply affidavit may not address all the issues to which SBC Midwest takes exception, the following addresses those issues where CLECs provided adequate information in their allegations for SBC to respond. The fact that we have not addressed every detail of the CLECs’ allegations does not mean that SBC believes their claims have merit.
5.In its comments, MCI incorporated its filings in the Michigan 271 proceeding, specifically attaching the declarations of Sherry Lichtenberg filed in that proceeding, on grounds that the issues MCI raises in this application “are largely a continuation of the problems MCI has already pointed out in Michigan.” Comments of MCI at 1 (“MCI Comments”). SBC provided extensive replies to the allegations of MCI and other CLECs in the Michigan proceeding. SBC’s Michigan filings pointed out inaccuracies and misstatements made by the CLECs, and demonstrated that SBC satisfies its obligations to provide all CLECs with non-discriminatory access to pre-order, order, maintenance and repair functionality. Those filings, including the Affidavit of Mark J. Cottrell for Michigan,[4] Joint Reply Affidavit of Mark J. Cottrell and Beth Lawson for Michigan,[5] Joint Supplemental Affidavit of Mark J. Cottrell and Beth Lawson,[6] and Joint Supplemental Reply Affidavit of Mark J. Cottrell and Beth Lawson[7] apply equally to this proceeding, are attached to this affidavit as Attachments A-D respectively, and are incorporated into this affidavit by reference.
OSS TEST ISSUES
6.The Indiana Office of Utility Consumer Counselors (“OUCC”) and TDS Metrocom complain that SBC’s 271 filing is somehow premature because testing of SBC’s OSS and performance metrics is not yet complete.[8] Contrary to these contentions, SBC’s 271 applications for the Midwest states are both timely and appropriate. On July 2, 2003, the Indiana Utility Regulatory Commission (“IURC”) specifically found that further operational OSS testing was “either infeasible, unnecessary or both.”[9] This finding followed the IURC’s earlier decision approving SBC’s May 13, 2003 motion to ramp down the test CLEC infrastructure, based on the fact that BearingPoint had completed all TVV and PPR testing as of May 6, 2003.[10] Although the performance metrics review portion of the OSS test is ongoing, the joint affidavit of James D. Ehr and Salvatore T. Fiorretti (App. A, Tab 22) demonstrates that there nonetheless is ample support in the record for the Commission to conclude that SBC’s performance data are reasonably accurate and reliable. Moreover, while acknowledging the importance of the eventual completion of the performance metrics test, each of the Midwest state public utility commissions nonetheless has recommended approval of SBC’s 271 application by the FCC based on the present record.
7.Nor is SBC attempting to “dodge commitments that it itself proposed” to “complete comprehensive third-party testing of its OSS on a ‘test until pass’ basis” as alleged by both the OUCC and the Ohio Consumer Counsel (“OCC”).[11] The Master Test Plans (“MTPs”) developed in Indiana, Ohio and the other Midwest states – including Michigan – basically are very similar to each other, with only minor differences resulting from state-specific issues, such as testing of line splitting/line sharing orders in Illinois and Michigan,[12] as required by those individual state commissions. All four MTPs specifically anticipated that the completion of all test criteria may not be possible, and provided the state commission with the authority to render a decision issues on any issues that remained open at the conclusion of testing.[13]
8.As noted in its Compliance Order, the IURC reviewed the issues raised by various parties in its proceeding and identified and addressed those issues which had a bearing in its decision to support SBC’s filing.[14] As such, the actions taken by the IURC leading up to its recommendation, and SBC’s subsequent FCC filing for 271 approvals, are entirely consistent with the provisions and intent of the Indiana MTP. Similarly, the Public Utility Commission of Ohio (“PUCO”) specifically disagreed with the OCC’s claims and accepted SBC’s commitment to continue the PMR test.[15] In doing so, it acknowledged that the BearingPoint test was an “exhaustive and very demanding test with a high degree of complexity” and opined that SBC’s inability to currently satisfy specific PMR test criteria is not indicative of SBC’s failure of the third-party test, but rather an indication that additional work was necessary.[16] SBC’s continuing commitment to complete the BearingPoint test is encapsulated within the Compliance Order issued by the PUCO on June 26, 2003. A similar requirement (for PMR test completion) is contained within orders issued by the Illinois, Indiana, Michigan and Wisconsin state commissions.[17]
9.The OCC incorrectly claims that seven OSS functionality issues remain unresolved.[18] Of the seven items listed, three successfully passed BearingPoint’s testing and four have been addressed in the improvement plans filed with the PUCO on July 3, 2003.[19] As fully detailed within Attachment B of the Four-State Cottrell/Lawson Affidavit, each of these plans describe specific actions being taken by SBC to address issues which were first identified in the Michigan 271 proceedings and discussed with CLECs during a collaborative workshop conducted March 4-5, 2003.[20] In ordering the implementation of these plans in Michigan, however, the MPSC made it clear that they were not required to demonstrate that SBC was “in compliance with each of the Section 271 competitive checklist items, including each of the areas addressed by the modified compliance and improvement plans.”[21] In Ohio, the PUCO concluded that these plans were sufficient in addressing the outstanding “Not Satisfied” TVV test items and instructed BearingPoint to discontinue all PPR and TVV test activities.[22] BearingPoint recently completed its evaluation of the SOC Timeliness Plan and reported that, based upon its sample of 447 actual SOC notices transmitted, SBC had achieved a 99.1 percent performance level for notices sent within one day of the service order completion – well above the 97% objective stated within the plan.[23] In compliance with commitments made within the other plans, SBC also filed interim progress reports with the PUCO for Pre-Order processing and repair coding on July 31, 2003, and for CSR and DL/DA updates on August 15, 2003. These reports demonstrate that SBC has already achieved significant progress in implementing the plans and that in many instances performance has improved as a result of that implementation.
CHANGE MANAGEMENT
“UNREJECT” FUNCTIONALITY
10.Choice One first raises an issue concerning SBC’s handling of Choice One’s change request to implement the “unreject” functionality that was previously available in LSOG 4.[24] As explained in detail in the Michigan Cottrell/Lawson Supplemental Reply Affidavit (Attachment D), ¶¶ 30-33, SBC takes CLEC-initiated change requests very seriously. Indeed, SBC’s handling of Choice One’s change request for “unreject” functionality confirms that SBC’s change management process provides CLECs with a meaningful opportunity to compete.
11.At the outset, as Choice One recognizes, ACN Comments at 24, this “unreject” functionality has never been offered in SBC’s West or Southwest regions. This functionality was eliminated in the Midwest region in conjunction with implementation of the Uniform & Enhanced Plan of Record (“U&E POR”) release in April of 2002, moving all 13 SBC states to uniform processes for the resubmission of CLEC LSRs after receipt of either rejects. CLECs were notified of this change with an Accessible Letter CLECAMS02-059, dated April 11, 2002 (App. J, Tab 27). Generally, as future changes are made, those changes are rolled out in all 13-states to ensure uniform platform functionality.
12.In June of 2002, Choice One submitted a CLEC Change Request (“CCR”), requesting that SBC restore this functionality for the Midwest, and implement it for the first time for the West and Southwest regions. Choice One’s allegation that SBC “immediately dismissed the request, without investigation” is untrue and belied by the record.[25] As documented by the CMP CCR history log for this request,[26] SBC initially deferred this request to April 2003 because SBC’s preliminary investigation indicated this functionality would require major rework for SBC. However, in November 2002, when another CLEC raised this issue in CMP, SBC agreed to reconsider the request prior to April 2003.
13.This CCR was actively discussed in CMP meetings in February, March, May, and June 2003. During this time, the CMP team, acting as advocates on behalf of the CLECs, continued to raise the issue within SBC. At each meeting, SBC and CLECs discussed Choice One’s CCR. CLECs also requested after each meeting that the CMP team bring back additional information. Each time the CMP team complied with the CLECs’ request.
14.In July 2003, this CCR was finally denied for the reasons set out in the CMP CCR log; primarily relating to the difficulty in reprogramming the systems. With the implementation of LSOG 5.0, the LASR platform was introduced as the common editing system for the SBC 13-State OSS. Given that LASR was never developed to support an unreject capability, this systems development would have been required across all of the SBC OSS systems. As such, SBC determined that the programming efforts required to develop this functionality were better devoted to quickly clearing the defects giving rise to the rejects, rather than expending resources on reprogramming to allow processing despite the rejects. In addition to the systems issues, this change would have also required a significant change for the Local Service Centers in the West, Southwest, and East and the included costs associated with training and management oversight.
15.Contrary to Choice One’s suggestion, the fact that Choice One’s CCR was ultimately denied does not mean the CMP did not work properly. Rather, SBC fully discussed Choice One’s CCR with CLECs in numerous CMP meetings before the final decision to deny Choice One’s CCR was made. Thus, SBC’s handling of this CCR demonstrates the change management process at work.
16.In this regard, Choice One also alleges that SBC has not lived up to its “continual[] promise” to rapidly resolve defects, citing SBC’s Enhanced Defect Report (“EDR”) as evidence that defect reports (“DRs”) have not decreased, and that the speed with which those defects are repaired has not improved. ACN Comments at 25; see also MCI Comments at 10. Choice One and MCI are, again, wrong on the facts.
17.Choice One and MCI neglect to mention that, unlike the earlier version of the Defect Report – which only listed defects reported by CLECs to OSS Support managers and/or the Mechanized Customer Production Support Center (“MCPSC”) – the new EDR (implemented in April 2003, as part of the Change Management Communications Plan) also lists potentially CLEC-impacting defects identified internally by SBC, as well as defects reported by CLECs to the LSC and/or IS Call Center. Thus, although the total number of reported defects has increased, the increase is simply a function of additional information being made available to the CLECs – and certainly is not an indication either of an increase in the actual number of defects, or a decrease in the quality of SBC’s releases. This additional information is provided to allow CLECs to more accurately anticipate the impact of any programming changes made to correct the reported defects. See Four-State Cottrell/Lawson Affidavit ¶172, n.75.
18.In fact, the overall quality of SBC’s releases is improving, as demonstrated by the significant decline in the number of defects opened after a release.[27] For example, for the LSOR version 5.0 release for the Midwest region in April 2002, there were 265 defects opened in the first seven days following the release. For the LSOR version 5.01 release in November 2002 and the version 5.02 release in March 2003, there were 217 and 167 defects, respectively, over the same period. For the June 2003 LSOR version 6.0 release (equivalent to the April 2002 release, as it implemented a new LSOG version), there were 169 defects for the seven-day period. This improvement demonstrates that SBC’s efforts to minimize defects are and have been successful.
19.Also contrary to the claims of Choice One and MCI, SBC addresses identified defects in a prompt manner. In support of its claims that defects have continued to “pile up,” MCI provides examples of the number of defects for each production release listed as “open” on the August 5, 2003 EDR. Declaration of Sherry Lichtenberg on Behalf of MCI, ¶12 (“Lichtenberg Decl.”);[28] see also ACN Comments at 25-26. Subsequent review shows that, as of August 19, 2003, 62 of the 221 defects listed on the August 5 EDR have been corrected, and an additional 54 defects have been assigned a fix date. SBC continues to manage the defect process on a daily basis and responds appropriately to any defect that has been identified as critical to a CLEC’s performance. For example, since June 16, 2003, a total of 40 defects have been categorized as “Severity 1,” indicating critical issues for CLEC production. As of August 5, 2003, all of those defects are closed or cancelled.
20.Finally, with regard to fixing defects, SBC has successfully implemented its Change Management Communications Plan (“CMCP”) that focuses on providing CLECs with notification and information regarding defects and maintenance releases. For example, if a defect is scheduled for a maintenance release and, as part of the “fix,” a new edit and/or a change to EDI mapping/CORBA structures are required, SBC communicates with CLECs via an Accessible Letter and holds a conference call with CLECs to discuss the “fix” and ensure that CLECs can accommodate the change on their side of the interface. For fixes that are scheduled for a maintenance release and that do not require a new edit or a change to EDI mapping /CORBA structures, SBC keeps CLECs current via the EDR. The EDR is a list of all CLEC impacting defects and provides useful information, such as the DR number, region(s) impacted, version impacted and the targeted fix date. It is updated daily. The EDR is also a standing agenda item for the monthly Change Management Process meetings. The CMCP also instituted additional processes and checkpoints within SBC to ensure that CLEC impact is properly identified, CLEC notification is provided and adequate testing of each fix is performed prior to the fix going into a maintenance release.