ATTACHMENT D

SCHOLL AFFIDAVIT – ATTACHMENT D

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Rulemaking on the Commission's Own Motion to Govern Open Access to Bottleneck Services and Establish a Framework for Network Architecture Development of Dominant Carrier Networks.
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Investigation on the Commission's Own Motion into Open Access and Network Architecture Development of Dominant Carrier Networks. / R.93-04-003
I.93-04-002

DECLARATION OF BRADLEY T. SOUTHER IN SUPPORTOF RESPONSE OF PACIFIC BELL TELEPHONE COMPANY (U 1001 C)TO ALJ RULING

April 20, 2001

RS ATTACHMENT D-1

ATTACHMENT D

DECLARATION OF BRADLEY T. SOUTHER

I, Bradley T. Souther, hereby declare as follows:

I.INTRODUCTION

1.I am employed by SBC Operations, Inc., a subsidiary of SBC Communications Inc. ("SBC"). My position is Area ManagerNetwork Regulatory for SBC's incumbent local exchange carriers ("ILECs"). My current responsibilities include representing the planning, engineering, and operations of SBC's ILEC networks, including that of Pacific Bell, before federal and state regulatory bodies. In particular, my current responsibilities include such representation for issues related to the SBC ILECs' Project Pronto.

2.I have a Bachelor of Business Administration Degree – Business Management from the University of Texas in Arlington, Texas. Also, I have completed company and external training related to outside plant design, engineering and activation including fiber optics and next generation digital loop carrier equipment ("NGDLC").

3.I obtained fulltime employment from Southwestern Bell Telephone Company ("SWBT") in 1989. In my 12 years of service with SWBT I have held positions in the customer services, outside plant construction, outside plant engineering, and activation of digital electronics. I assumed my current responsibilities in October 2000.

4.The purpose of this declaration is to define GR303, to explain when Pacific Bell utilizes GR303, and to discuss the infeasibility of utilizing GR303 as a way to provide access to unbundled loops and switch ports.

II.GR303 DEFINED

5.With current Digital Loop Carrier ("DLC") and voice switching technology, individual end user's signals are assigned to specific time slots in a highspeed digital bit stream. These time slots are then used to transport and switch an end user signal to its destination.

6.GR303 is a set of technical specifications that can be deployed to serve as an interface between a DLC's Central Office Terminal ("COT") and a local digital switch. GR303 provides a dynamic way of utilizing the time slots within the digital bit stream[1] to connect DS1 signals directly into the switch from COTs such as those used with the Alcatel Litespan 2000 or 2012 equipment. As such, the GR303 interface is a form of integrated DLC ("IDLC"). GR303 is also an effective way to reduce the costs of provisioning bundled voice services and switched special services in that it reduces the number of DS1s required to provision services over IDLC compared to other integrated switch interfaces such as TR008.[2] However, GR303 does not reduce the costs of an unbundled loop or switch port as Ms.Murray suggests (Murray declaration page 5). This is because GR303 does not provide access to an individual unbundled switch port or individual UNE loop as explained in more detail below.

IIIGR303 DEPLOYMENT

7.GR303 will not be deployed ubiquitously across Pacific Bell as Ms.Pitts suggests (Pitts Declaration page 8). There are several considerations that must be evaluated before GR303 can be deployed. First, all existing TR008 and TR057[3] switch interface capacity will be utilized before installing new GR303 interface equipment. Second, only if a certain level of growth for voice and data services is forecasted will GR303 be deployed. It is incorrect to assume that all wire centers with digital switches should have integrated types of DLC. More specifically, it is also incorrect to assume that DLCs in a given wire center should be integrated, or that integrated DLC should use the GR303 interface. The economic breakeven point between integrated and universal types of DLC is sensitive to percentfill. This means the integrated DLC must be sufficiently utilized before it is more economical than universal DLC. Where existing equipment capacity must be relieved, SBC's current planning guidelines call for a minimum threshold of growth lines forecasted.

8.After the decision to deploy IDLC has been made, Pacific Bell still deploys a combination of GR303 IDLC and UDLC. Two channel banks (i.e., approximately 450 end user lines) in every new COT will be deployed in a universal configuration not only to accommodate access to unbundled loops for CLECs, but also to accommodate nonswitched services such as private line data, as well as services switched at a distant wire center, such as foreign exchange service.

IVUNBUNDLED LOOPS AND GR303

9.While IDLC generally (and the GR303 type of IDLC interface specifically) may be the least cost and most efficient means of provisioning bundled loops, Universal Digital Loop Carrier ("UDLC") is the least cost and most efficient method of providing unbundled loops provisioned over DLC. Because the IDLC's DS1s are connected directly to the voice switch in the central office, individual customer lines served by IDLC systems are not physically accessible to a CLEC. Instead, these individual customer lines exist only as digital pulses interspersed in the DS1 digital bit streams. Therefore, by its very design, IDLC technology does not provide a way to separate the loop from the switch on a customerbycustomer or loopbyloop basis. In contrast, when UDLC is deployed, each individual customer's line terminates on the MDF, thus giving CLECs access to the unbundled loop.

V.VIRTUAL INTERFACE GROUPS

10.One of the major limitations that makes unbundled access to integrated loops infeasible, is the GR303 Virtual Interface Group ("VIG"). A VIG is a grouping of DS1 facilities that carry traffic from a local digital switch, through the DLC COT, out to the DLC remote terminal ("RT"). Through the GR303 TSI feature, each customer is dynamically assigned a time slot in the VIG for each call rather than being assigned a permanent time slot in the digital bit stream from the DLC RT to the switch. The service order assigns each customer to a VIG where that customer remains until his service is disconnected, or is moved as a result of load balancing[4] on the switch.

Limitations:

  • At present an Alcatel Litespan RT can only have four VIGs.
  • Each VIG is must have a minimum of two DS1s.
  • Each VIG is also limited to a maximum of 20 DS1s because of the DS1 capacity of the digital switch's Integrated Digital Terminal ("IDT") equipment.
  • A VIG's DS1s can only be connected to one IDT at the digital switch.
  • Due to the limitation of only four VIGs per RT, a minimum of two are needed for POTS growth and the associated load balancing on the switch. Additionally, the other two VIGs could be needed for multientity/switch hosting where SBC has two separate switches within the same central office.

11.Due to the limitations stated above, a CLEC wanting GR303 DS1 access from an RT to its own digital switch would require at a minimum its own VIG and minimum of two DS1s. What makes a GR303 interface between the RT and the switch uneconomical is this minimum requirement even if the CLEC was only providing service to one customer. What makes GR303 infeasible is the limited number of VIGs available from the RT to the switch. With a single switch in a CO, SBC requires a minimum of two VIGs for its own use and potentially all four depending on pots growth and/or load balancing on the switch. Additionally, SBC could require all four VIGs in a multientity/switch office.

12.Finally, parity would also be an issue with the VIG limitation. Setting all the above limitations aside, even if it were possible to give a CLEC its own VIG, then at most only two CLECs could have a VIG.

VICONCLUSION

13.GR303 can not be used to provide access to unbundled loops or switch ports. UDLC is the most economic way of providing access to the loop and switch port. Pacific Bell has accurately captured these costs for access to the unbundled loop in its TELRIC cost study (see Declaration of Scott Pearsons). Additionally, Pacific Bell's TELRIC cost studies reflect the most modern technology that could be used to provide unbundled loops or switch ports.

RS ATTACHMENT D-1

[1] This GR303 feature is called dynamic time slot interchange ("TSI").

[2] TR008 is a static (i.e., non-TSI) interface between the COT and the switch.

[3] TR057 is a non-integrated switch-COT interface, usually referred to as universal DLC ("UDLC").

[4] Load balancing is creating an even distribution of customer traffic across a digital switch. This is accomplished by terminating the DLC's DS1s to that switch within multiple VIGs. This process would typically occur when a specific grouping of customers has a higher level of demand for service than the average demand. Without such load balancing, this higher demand could lead to blocked calls within the DLC and the switch. Thus, customers may be moved from one VIG to another in order to alleviate this problem.