Redacted for Public Inspection

BEFORE THE FEDERAL COMMUNICATIONS COMMISSION WASHINGTON, D.C. 20554

In the Matter of ) ) Joint Application by SBC Communications Inc., ) Southwestern Bell Telephone Company, and ) Southwestern Bell Communications Services, ) CC Docket No. ______Inc. d/b/a Southwestern Bell Long Distance for ) Provision of In-Region, InterLATA Services in ) Kansas and Oklahoma )

JOINT AFFIDAVIT OF BRIAN D. NOLAND AND DAVID R. SMITH

STATE OF TEXAS ) ) COUNTY OF DALLAS )

TABLE OF CONTENTS LSC/LOC AFFIDAVIT

SUBJECT PARAGRAPH (S) PROFESSIONAL EXPERIENCE AND EDUCATIONAL 2 BACKGROUND BRIAN D. NOLAND 2 DAVID R. SMITH 5 EXECUTIVE SUMMARY 8 ORGANIZATIONAL STRUCTURE OF INTERCONNECTION 13 SERVICES LSC ORGANIZATION 14 LOC ORGANIZATION 18 ADDITIONAL SUPPORT GROUPS 23 LSC AND LOC AVAILABILITY 27 ORDER PROCESSING – LSC ROLE 29 ORDER CONFIRMATION NOTICES 30 REJECTS 38 MANUAL ORDER ENTRY 45 SERVICE ORDER ACCURACY 47 LSC PROCESS IMPROVEMENTS 50 Redacted For Public Inspection

SUBJECT PARAGRAPH (S) SCALABILITY 57 JEOPARDIES 65 COMPLETION NOTICES 88 POSTING 93 ORDER PROVISIONING – LOC ROLE 96 MAINTENANCE AND REPAIR 99 ORDERING AND PROVISIONING OF INP/LNP SERVICES 106 CHECKLIST ITEM 4 – UNBUNDLED LOCAL LOOPS 114 HOT CUT TIMELINESS 117 OUTAGES ON CONVERSION 120 PREMATURE DISCONNECTS 121 KANSAS OUTAGE RESULTS 122 OKLAHOMA OUTAGE RESULTS 129 TROUBLES AFTER INSTALLATION 132 FDT STATUS 137 DIGITAL SUBSCRIBER LINE (DSL) 140 BILLING 147 DISASTER RECOVERY 149 ADDITIONAL INTERCONNECTION SERVICES OFFERINGS 152 ESCALATION AND COMPLAINTS 156 INTERCONNECTION SERVICES COMMITMENT 165 CONCLUSION 167 LOG RETURNED TO CLEC – FOC ATTACHMENT A TRANSCRIPT (November 4, 1999, Pages 1 and 32-42) ATTACHMENT B PM 114.1 CONVERSION DURATION ATTACHMENT C PM 114.1 CONVERSION INTERVAL (CHC – FDT) ATTACHMENT D PM 114 PERCENT PREMATURE DISCONNECTS ATTACHMENT E PPIG OUTAGE DATA ATTACHMENT F I-7 REPORTS – UNE LOOPS ATTACHMENT G LOC ORIENTATION PRESENTATION ATTACHMENT H LOC ESCALATION LIST ATTACHMENT I LOC DISASTER RECOVERY PLAN ATTACHMENT J LSC DISASTER RECOVERY PLAN ATTACHMENT K CUSTOMER COMPLAINT FORM ATTACHMENT L PERFORMANCE MEASUREMENT LIST – LSC/LOC ATTACHMENT M CHC – FDT LINES PROVISIONED ATTACHMENT N APPENDIX 1 TO BUSINESS RULES – MISSED APPOINTMENT ATTACHMENT O CODES

2 Redacted For Public Inspection

Brian D. Noland and David R. Smith, being of lawful age and duly sworn upon my oath, do hereby depose and state as follows:

PROFESSIONAL EXPERIENCE AND EDUCATIONAL BACKGROUND

Brian D. Noland

2. My name is Brian D. Noland. My business address is 208 South Akard, Room 3120.80,

Dallas, Texas 75202.

3. I am currently Director – Regulatory Support. In this position, I am responsible for

monitoring LSC performance and investigating complaints involving or impacting LSC

operations. I coordinate changes within the LSC as necessary to comply with regulatory

requirements. In addition, I provide requested information and testimony to regulatory

bodies regarding LSC operations.

4. I am a graduate of the University of Arkansas, Fayetteville, Arkansas, with a Bachelor of

Science degree in Industrial Engineering. I began working for SWBT in August 1980 in El

Dorado, Arkansas, as an Installation Supervisor. I transferred to Fayetteville, Arkansas in

August 1981 and held several positions within the Installation and Repair Department

through 1987. In January 1988, I moved to Little Rock, Arkansas and held the position of

Manager – Special Services Design. I was promoted to Area Manager – External Affairs in

December 1988 and held this position until June 1989 at which time I was transferred to

Jonesboro, Arkansas as Area Manager – Residence Service Center (RSC). In May 1993, I

accepted the assignment of Area Manager – Installation and Repair in Jonesboro, a position

I held until September 1997 when I transferred to Fort Worth, Texas, as Area Manager –

Local Service Center (LSC). I held this position until January 1999, when I accepted

another assignment within the Local Wholesale Operations as Area Manager – Local

Number Portability Center (LNPC). I held this job until I was promoted to my current

position.

David R. Smith

5. My name is David R. Smith. My business address is 5501 Alliance Gateway Freeway, Ft.

Worth, Texas 76178.

6. I am Area Manager – LOC Regulatory. In this position, I am responsible for monitoring

LOC performance and investigating complaints involving or impacting LOC operations. I

coordinate changes within the LOC as necessary to comply with regulatory requirements. In

addition, I provide requested information and testimony to regulatory bodies regarding LOC

operations.

7. I received my BBA from Texas A&M University in 1980, and have been employed by SBC

Communications, Inc. and SWBT in various capacities since that time. I have managed

SWBT network functions including installation, repair, maintenance and assignment for

Plain Old Telephone Service (POTS) and Special Services and have held a position on the

SWBT Network Operations Staff. I also served as a Member – Technical Staff for Bellcore

in a rotational assignment reviewing Operational Support System (OSS) impacts from new

technologies. I have also held the position of Performance Consultant, SBC – Center for

Learning, where I had responsibilities for SWBT’s network curriculum.

EXECUTIVE SUMMARY

8. SWBT’s Interconnection Services Department, including the LSC, the LOC and other

support structures, are responsible for providing ordering, billing, provisioning, maintenance

and repair services to CLECs in their provisioning of telecommunication services.

9. On June 30, 2000, the FCC issued its Memorandum Opinion and Order approving SWBT’s

Section 271 application to provide interLATA long distance service in Texas. In that Order,

the FCC granted SWBT’s application, finding that SWBT has taken the statutorily required

steps to open its local exchange and exchange access markets to competition.1 With regard

to OSS, the FCC specifically found that SWBT provides non-discriminatory access to OSS

pre-ordering, ordering, maintenance and repair and billing functions, and that SWBT has

instituted a change management process that helps to ensure that changes to the OSS

interfaces do not adversely affect a carriers ability to access OSS functions. These findings

were primarily based on the actual commercial performance of SWBT’s OSS, as well as on

additional evidence of functionality and capability provided by the Telcordia third-party

OSS test.2

10. The FCC’s favorable evaluation of SWBT’s access to OSS for Texas included an evaluation

of the operations of the SWBT LSC and LOC, as well as a review of the scalability of those

operations to meet CLEC demand. Similarly, the FCC finding that SWBT provides

unbundled local loops in accordance with the requirements of Section 271 was based on a

review of the performance of the LSC and LOC in the provisioning of such loops through

the coordinated hot cut (CHC) and frame due time (FDT) processes.3

11. As noted throughout this affidavit, SWBT’s LSC and LOC operate on a five-state regional

basis. SWBT utilizes the same LSC and LOC facilities and personnel for all states in SWBT’s

five-state area. As such, the FCC’s findings that SWBT provides nondiscriminatory access to

1 Memorandum Opinion and Order, Application by SBC Communications Inc., Southwestern Bell Telephone Company, and Southwestern Bell Communications Services, Inc. d/b/a Southwestern Bell Long Distance Pursuant to Section 271 of the Telecommunications Act of 1996 to Provide In-Region, InterLATA Services in Texas, FCC 00-238, CC Docket No. 00-65 (FCC rel. June 30, 2000) (“Texas Order”). 2 Id. ¶¶ 91-212. 3 Id. ¶¶ 251-280. 5 Redacted For Public Inspection

OSS in Texas applies with equal force to Kansas and Oklahoma. Likewise, as set out in detail

below, SWBT satisfies its obligations under checklist item 4 for the provisioning of unbundled

local loops in Kansas and Oklahoma as measured using the same objective performance

measurements used to assess SWBT’s performance in Texas.

12. This affidavit, together with the Affidavits of Elizabeth Ham on OSS (App. A, Tab 15), and

William R. Dysart (App. A, Tab 18), concerning performance measurements, demonstrates that

SWBT satisfies its obligations under the Act and FCC rules to provide nondiscriminatory

access to its OSS functions.

ORGANIZATIONAL STRUCTURE OF INTERCONNECTION SERVICES

13. SWBT’s Interconnection Services organization is comprised of separate but cooperative groups

which work together to meet SWBT’s obligations under the Act. The functions of the LSC and

LOC units within Interconnection Services are described in detail in this affidavit. This

affidavit deals only with the five-state SWBT region, which includes Kansas and Oklahoma.

SBC utilizes different personnel and facilities to serve its local markets in California, Nevada,

Connecticut, Illinois, Indiana, Michigan, Ohio, and Wisconsin (specifically, Pacific Bell,

Nevada Bell, Southern New England Telephone, and Ameritech territories).

LSC ORGANIZATION

14. The LSC is part of SWBT’s Interconnection Services and provides CLECs with a single point

of contact for the purpose of ordering and billing related to interconnection facilities, resold

services and UNEs. SWBT created the LSC in 1995 to replicate its retail business offices.

Since its creation, the LSC has undergone many changes to better serve the local wholesale

market.

15. The LSC was initially established to support local competition under The Texas Public Utility

Regulatory Act (PURA) with 17 employees in a single location in Dallas, Texas. In order to

accommodate the growing CLEC service market under the Federal Telecommunications Act of

1996, SWBT opened a second LSC facility (Alliance I) outside Fort Worth, Texas, in 1997

near the Alliance Airport. Construction on this facility, capable of housing more than 700

employees, was completed at a cost of approximately $5 million. Additionally, SWBT opened

a third LSC facility (Alliance II) in August 2000 near the Fort Worth LSC. Construction on

this facility, capable of housing more than 400 employees, was completed at a cost of

approximately $4.5 million. LSC expenditures for 1999 were over $30 million and in 1998

expenditures were $27.7 million.

16. As of August 2000, the LSC employs 1,338 management and non-management employees with

an annual expenditure of more than $70 million. Eight hundred and one of these employees

currently work in the Alliance I facility, 211 work at the Alliance II facility, and another 326

work at the Dallas facility. LSC employees bear the same titles and perform the same functions

as employees in SWBT’s retail business offices. These employees include 3 Directors, 20 area

managers, 89 managers, 2 assistants, 1,176 service representatives, 22 communication

consultants and 26 clerical employees. The 20 area manager groups referenced above oversee

the pre-ordering, ordering and billing functions that support CLEC accounts and serve as

SWBT’s liaison with all CLECs for service order processing. Of these area manager groups,

15 are comprised of both management and non-management employees, including service

representatives and communications consultants. Area manager duties include personnel

administration, subordinate development, force management, assistance in negotiations with

CLECs and implementation of CLEC resale and interconnection agreements. Five area

managers handle specialized activities, namely billing and the Digital Subscriber Line (DSL)

17. The LSC employees and facilities discussed above serve all CLECs operating in the five-state

region. Work is divided between these facilities by CLEC account. The LSC facility to which

a CLEC account is assigned is responsible for processing the work for that CLEC. Within each

LSC facility, a functionalized work group that processes Local Service Requests (LSRs) for

different product types is assigned to each CLEC customer. This one-on-one contact with the

assigned work group gives the CLECs access to service representatives, manager(s) and an area

manager to handle their service requests and any associated issues for pre-order, order and

billing. The SWBT LSC facilities act as back-ups for each other, sharing workload as

necessary. SWBT provides the CLEC with contact names and telephone numbers of the

management team that is responsible for handling all requests and complaint resolutions for

that particular CLEC. However, the CLEC may, at any time, escalate problems or request

service expedites to any LSC or LOC team member, up to and including the Vice President –

Interconnection Services.

LOC ORGANIZATION

18. SWBT created the LOC in May of 1996 to serve as the single point of contact for CLECs in

connection with the provisioning, turn-up and acceptance testing of all interconnection facilities

and unbundled elements. The LOC also handles the receipt of maintenance reports and

maintenance work for all resold POTS services, interconnection facilities and UNEs. The LOC

was designed to replicate functions performed at the Customer Service Bureau and

Maintenance Centers in SWBT’s retail operations. The LOC provides these provisioning,

maintenance and repair services to the CLECs 24 hours a day, 7 days a week.

19. The mission of the LOC is to ensure that CLECs receive high quality provisioning,

maintenance and repair services in parity with that provided by SWBT’s retail operations.

In support of that objective, SWBT has committed considerable financial and personnel

resources. The LOC has three facilities, two in Fort Worth and one in Dallas, Texas, to

support various CLEC services. One of the Fort Worth LOC facilities handles provisioning

orders such as Resale Specials, Interconnection, and ISDN/BRI, and supports maintenance

requests from all CLECs for all services. The second LOC facility in Fort Worth handles

provisioning orders for INP/LNP orders, with and without loop. The LOC facility in Dallas

handles provisioning of xDSL services. The LOC’s 1999 annual expenditure exceeded $8

million for salaries, training and facilities; SWBT spent $5.9 million to support the LOC’s

operations in 1998. The LOC’s budget for 2000 is projected to exceed $50 million.

20. The job titles of LOC employees parallel those of employees in SWBT’s retail provisioning

and maintenance centers. As of August, 2000, the LOC workforce consisted of a total of

391 management and non-management employees, including 1 General Manager, 11 area

managers, 1 administrative assistant, 33 managers, 96 customer service representatives

(CSRs), 144 network center technicians (NCTs), 97 service representatives and 8 clerical

support personnel. These employees support SWBT’s efforts to provide parity service to all

CLECs doing business in SWBT’s five states. Of the eleven LOC area managers referenced

above; three are responsible for the center operations and personnel; one is responsible for

the DSL Unit; one is responsible for the Local Number Portability Center (LNPC); and six

are responsible for interfacing directly with CLECs on a five-state basis for service

assurance levels and service improvement plans. Managers within the LOC are specifically

assigned to supervise the CSRs and NCTs.

21. The 96 LOC CSRs referenced above directly interface with CLECs to receive maintenance

reports, perform trouble testing on POTS lines, dispatch repair teams and check the status of

repairs. CSR training consists of customer contact skills development, metallic line testing,

maintenance report entry and various SWBT internal systems training. This training takes

approximately four weeks.

22. The 144 LOC NCTs directly interface with the CLEC to perform turn-up, testing and repair

of interconnection facilities, design services and UNEs. The LOC NCTs must pass a

complex technical test to qualify for these positions. In addition, they attend a series of

pass/fail schools that must be completed successfully before the NCT is deemed qualified.

The training includes the same curriculum as that of retail maintenance employees. These

schools include basic electronics, electricity, print reading, trouble analysis, transmission

and digital technology. Once this training is successfully completed, the employee is

provided advanced training on digital technology, testing and trouble isolation using remote

test access processes. All employees must successfully complete the training to become a

LOC employee. The training period for NCTs is approximately 15 weeks and SWBT

invests $50,000 per employee to educate and develop the skills needed to serve CLECs.

ADDITIONAL SUPPORT GROUPS

23. As part of its technical support efforts, on August 15, 1998, SWBT established the Customer

Action Support Team (CAST). CAST is a second tier technical support team which

provides additional technical support to CLECs by interacting with SWBT Market Regions,

the Account Teams and the LOC/LSC organizations. The Account Teams’ duties are

discussed in the Sparks Affidavit (App. A, Tab 13). CAST is comprised of one area

manager, one dedicated manager, and nine CSRs who perform a variety of duties. CAST’s

responsibility is to enhance the existing contact and escalation processes to assist CLECs in

the resolution of operational issues pertaining to pre-ordering, ordering, provisioning,

maintenance and OSS. This team is available to CLECs for matters including escalation of

difficult or recurring trouble situations on complex services [e.g., ISDN and Direct Inward

Dialing (DID)], network outages and unresolved issues associated with pre-ordering and

ordering. The team focuses on improving the quality of SWBT’s service on an

interdepartmental basis and has overall responsibility as the direct interface with all SWBT

internal organizations for CLEC problem resolution. A “Hotline” has been established for

CLEC personnel to contact CAST. The “Hotline” is operational 24 hours a day, 7 days a

week. CLECs are encouraged to utilize the existing contact and escalation processes with

the Account Teams, LSC and LOC in their initial attempts to resolve operational issues.

However, the CAST provides additional contacts for the CLECs and SWBT’s internal

network organization to resolve problems or situations where the normal escalation channels

may not have provided a timely resolution. All escalations are documented and tracked to

ensure timely resolution with SWBT initiated status reports provided to CLECs. Centralized

data tracking provides SWBT with pertinent information to perform root cause analysis,

quantify and categorize issues, identify process gaps and implement process improvements.

24. In November 1997, a special unit was established to meet CLEC demand for Local Number

Portability (LNP) services. The LNPC and LNP support workforce includes 1 area manager

and 9 managers, who supervise 30 service representatives, 33 NCTs, 31 CSRs and 1 clerk.

More detail regarding this unit will be covered later in this affidavit.

25. SWBT also established a specialized unit in April 1999 to assist CLECs with Digital

Subscriber Line ordering and provisioning activity. As of August 31, 2000 this unit is

comprised of 4 area managers, 23 managers, 271 service representatives, 19 NCTs and 1

clerical employee assigned to the LSC and LOC. New manual ordering processes involving

Loop Qualification requirements will be discussed in more detail, later in this affidavit.

26. In addition, in April 1999, the LSC created a specialized Posting Order Service Team (POST),

formerly the Error Resolution Team (ERT) which has focused solely on clearing errors on

orders that have been completed, but for some reason cannot post for proper billing.

LSC AND LOC AVAILABILITY

27. The LSC provides pre-ordering and ordering services to CLECs Monday through Friday from

8:00 a.m. to 5:30 p.m. Central Standard Time. Additional LSC coverage can be requested as

needed by the CLECs. The LSC has also accommodated requests from CLECs for electronic

transaction processing during SWBT holidays and stands ready to meet similar requests from

CLECs for extended LSC coverage.

28. SWBT provides the CLECs with a Hotline number to the LOC for any service issue. This

line is staffed 24 hours a day, 7 days a week. The CLECs are advised to contact the LOC

for resolution of service problems occurring on or after the due date of the service request.

The exception is billing issues, which are to be referred to the LSC.

ORDER PROCESSING – LSC ROLE

29. SWBT’s LSC is responsible for manual processing of CLEC service requests. When a

CLEC chooses to submit its requests manually (whether by telephone, courier, U.S. Mail or

facsimile), the request is processed by the LSC through the appropriate systems. Similarly,

when a CLEC submits its LSRs via one of SWBT’s several electronic OSS, the LSC

provides manual handling on those orders which are not designed to flow-through, or which

otherwise require manual intervention before provisioning. In its Texas Order, the FCC

found that these manual processes enable SWBT to provide CLECs with timely and

nondiscriminatory order confirmation, service order completion, reject and jeopardy

notifications. Texas Order ¶ 170. Electronically submitted orders that do not flow-through

are handled in a prompt and accurate manner, and the LSC manual workforce is scalable to

meet demand. As set out in greater detail below, these findings remain true for Kansas and

Oklahoma today.

ORDER CONFIRMATION NOTICES

30. Once it is determined that the CLEC service request is complete and accurate,4 the LSC service

representative inputs the order into the same legacy systems that SWBT retail service

representatives utilize to process orders for SWBT’s retail customers. Once an order is input

into one of these systems, it is distributed to downstream departments that will complete the

order.

31. In the case of a manually submitted order, the CLEC is notified of the assigned telephone

number, order number and service due date for each order by a log, which SWBT faxes to the

CLEC. This log serves as a manual Firm Order Confirmation (FOC) (Attachment A).

32. On electronically submitted orders that require manual handling, the LSC utilizes LASR GUI

to return the FOC to the CLEC via the same interface (EDI or LEX) over which the request

was sent.5

4 LSC service representatives screen each order request that requires manual handling in its entirety prior to inputting the request into SWBT’s legacy systems. If errors are found, the LSC screeners will notify the CLEC of the type of error, either by fax or telephone (in the case of manually submitted orders) or via LASR GUI (for electronically submitted orders) within five hours of receipt.

5 LASR GUI is a graphical user interface to the LASR system that was designed for use by LSC service representatives and was implemented on July 1, 1999. LASR GUI enables LSC service representatives to send notifications on manually handled orders to the CLEC electronically, rather than by manual fax. See the affidavit of Elizabeth Ham for further detail (App. A, Tab 15). 13 Redacted For Public Inspection

33. Regardless of how the CLEC submits its order, SWBT assigns due dates for provisioning

CLEC service order requests on a non-discriminatory basis by utilizing a first-come, first-

served routine. Due date selection and provisioning flows (including such things as line

number assignment, facility assignment, etc.) utilized by the LSC for CLEC service requests

are the same as those utilized by SWBT’s retail service representatives for provisioning service

to SWBT’s retail customers. Due dates for residential and simple business orders are also

determined by accessing the same EASE system, and are assigned by work load demand on

installation forces regardless of whether the request is made on behalf of a SWBT retail

customer or a CLEC customer. Due dates for complex services are obtained based on the work

involved, using either a predetermined interval or a mutually negotiated due date. Again, the

same methods for due date assignment are utilized by SWBT’s retail operations. A due date is

not affected by whether the request is made on behalf of a SWBT retail customer or a CLEC

customer. “No field work” (i.e. dispatch of a technician to the customer’s premise is not

required, such as a request to change long distance carriers) change and conversion requests

received prior to 3:00 p.m. are eligible for the same business day due date. If received after

3:00 p.m., those orders will be assigned the next business day for the due date. If field work is

required, the next available date from the due date board will be assigned. Both retail and local

wholesale offices alike follow this due date procedure.

34. Performance Measurement 5 tracks SWBT’s actual performance in providing timely FOCs.

SWBT’s average firm order confirmation performance for June, July and August for PM 5-1

through 5-12 for orders submitted electronically in Kansas and Oklahoma reflect timely notices

to CLECs. For additional information regarding PM 5 see the Ham (App. A, Tab 15) and

Dysart Affidavits (App. A, Tab 18).

35. Additionally, PM 5-13 through 5-18 measure FOC on orders submitted manually to the LSC.

SWBT’s performance on these measurements reflect overall timely notices were provided to

Kansas and Oklahoma CLECs. In fact, in Kansas PM 5-13 (Residence and Simple Business)

and 5-14 (Complex Business) met or exceeded the 95% benchmark for each month of this year,

with an overall FOC percent returned in less than 24 hours of 97.5% and 98.8% respectively.

The only other manually submitted FOC measurement with data to report in Kansas (PM 5-16,

UNE Loop 1-49), reflect smaller volumes (average less than 20 orders per month) than the

other disaggregations previously mentioned. This measurement reflects a 90.3% overall

average for the first eight months of this year and has, in fact, been at 100% for the last three

months, June, July and August.

36. Likewise, SWBT’s overall performance on these measurements in Oklahoma reflect equally

timely returns. SWBT’s PM 5-13 (Residence and Simple Business) met the 95% benchmark

for 8 of the first 8 months of this year. PM 5-14 (Complex Business) reflects an overall

average of 93.8%, returned in less than 24 hours. The volumes on this measurement are

relatively small and notably very few misses can cause this measurement to miss the 95%

benchmark. For example, in the months that this benchmark was missed (March, April, June

and August), the data reflect volumes of only 12, 21, 25 and 46 orders, with 1, 4, 2 and 3

misses during those respective months. PM 5-16 (UNE Loop 1-49) SWBT met or exceeded 6

of the last 8 months, with misses in April and August only, for an overall twelve-month

average of 96.1%. For the only other manually submitted FOC measurement with data to

report in Oklahoma (PM 5-18, Switch Ports), SWBT reports 100% confirmations returned in

less than 24 hours.

37. SWBT’s performance regarding FOCs for xDSL capable loops is measured in PMs 5.1-01

through 5.1-06. SWBT has consistently met the benchmark for these measurements in Kansas

and Oklahoma for the last three months, with the exception of 5.1-05 (Manual 1-20 Loops).

However, the volumes for this disaggregated measurement are such that SWBT would need to

be virtually perfect to meet the benchmark. For example, in the months that SWBT missed the

benchmark for this measurement, July in Kansas and July and August in Oklahoma, a total of

2, 1 and 2 misses were recorded respectively.

REJECTS

38. The FCC concluded in its Texas Order, that SWBT demonstrates that it provides competing

carriers with timely order rejection notices in a manner which allows CLECs a reasonable

opportunity to compete. Id. ¶ 174. Additionally the FCC concluded, with respect to

manually generated reject notices that SWBT satisfies the nondiscrimination standard. Id.

¶ 175. SWBT provided, and continues to provide, reject notices, on average, in less than

eight hours and most of those rejects are returned electronically.

39. As stated previously, since July 1, 1999, the LSC uses LASR GUI to return all electronically

submitted rejects. Utilization of this tool within the LSC allows for a speedy rejection of a

service request back to the CLEC for comprehensive correction. SWBT provides individual

CLEC error-tracking reports, which allow the CLEC to analyze its own quality performance.

The benefits of this team approach are:

 Reduction of multiple rejects and response time;  Consistency in processing CLEC errors;  Improved efficiency; and  Implementation of consistent tracking among all CLECs.

40. Performance Measurement 10.1, Percent Manual Rejects Received Electronically and

Returned Within Five Hours, measures the percentage of LSRs that are sent electronically 16 Redacted For Public Inspection

by the CLEC and are then rejected manually by the LSC and returned to the CLEC via

LASR GUI. SWBT’s performance on PM 10.1 for the last three months has been below the

Texas PUC-approved benchmark of 97% rejects returned within 5 hours of receipt of the

LSR: Kansas (June 87.8%, July 87.4% and August 75.1%) and Oklahoma (June 94.3%, July

93.6% and August 80.2%). However, the actual amount of time it takes SWBT to return a

manual reject to the CLEC, as measured by PM 11.1 (Mean Time to Return Manual Rejects

Received via LEX or EDI), indicates that SWBT provides manual reject notices in a manner

which offers CLECs a meaningful opportunity to compete. SWBT returns manual rejects,

on average, in under 8 hours: Kansas (4.2 hours in June to 3.7 hours in July and 8.3 hours in

August) and Oklahoma (3.0 hours in June to 3.1 hours in July and 6.8 hours in August).

41. The dichotomy in the results on these two measures – in which SWBT’s mean time to return

rejects is typically below the 5 hour mark, while its actual percentage performance in

returning rejects is within the 5 hour time frame yet fails to meet the PM 10.1 benchmark –

is explained below.

42. The benchmark set by the Texas PUC for this measure provides SWBT with a five-hour

window for the return of all manual rejects, regardless of the complexity of the order. This

standard is significantly higher than the standard of 95% within 24 hours for all manual

reject returns approved by the FCC for Bell Atlantic-New York (BA-NY)6, and is also much

higher than the Texas PUC’s benchmark of 5 hours for FOC return on simple business and

residential orders, and 24 hours for complex orders (See PM 5). The Second Addendum to

Staff’s Report in Kansas found that SWBT’s performance data suggest that SWBT’s

6 Memorandum Opinion and Order, Application by Bell Atlantic New York for Authorization Under Section 271 of the Communications Act to Provide In-Region, InterLATA Service in the State of New York, 15 FCC Rcd 3953, 4047-8, ¶ 180 (1999) (“New York Order”). 17 Redacted For Public Inspection

behavior is in compliance in most instances and that it provides nondiscriminatory reject

notices.7 Notably, under the new Version 1.7 of the business rules, the benchmark for PM

10.1 has been raised to six hours.

43. In addition to the already strict benchmark on this measurement, in August SWBT

experienced additional difficulty in meeting this standard due to a problem which arose on

August 10, 2000, when a LASR program used to manage the internal processing of

transactions was run on this system in preparation for the August 12 Release. When this

program was invoked, it continued to run, which caused every other process in LASR to be

put on hold, including LASR GUI. As previously stated, LASR GUI is the tool utilized by

the LSC to return rejects and other manual notifications to the CLECs. SWBT’s

Information Technology organization applied a “fix” to this program on August 11 and the

problem has not reoccurred. However, by the time the “fix” was applied and LASR GUI

was restored, the problem, even though brief, had already caused a situation that adversely

impacted the LSC’s timely (within five hours of receipt) return of FOCs and manual rejects.

The all day outage of LASR on August 10, coupled with the loading of the August 12

EDI/LSR release did not allow the LSC the time needed to return the manual rejects on the

orders missed on August 10. The LSC was “locked out” of LASR while the August 12

release was loaded. This is normal business practice which occurs with any new release,

and had the incident not occurred on August 10, it would not have adversely impacted the

LSC’s ability to return timely notifications via LASR GUI. This problem impacted all

SWBT’s manual notification performance measurements, which utilize LASR GUI for the

7 Second Addendum to Staff’s Recommendation at 8, Southwestern Bell Telephone Company’s Kansas 271 Application, Southwestern Bell Telephone Company – Kansas’ Compliance with Section 271 of the Federal Telecommunications Act of 1996, Docket No. 97-SWBT-411-GIT (KCC Aug. 21, 2000) (“Second Addendum to KCC Staff’s Recommendation”) (App. C – KS, Tab 288). 18 Redacted For Public Inspection

return of manual notifications, including PMs 5 (FOC), 7.1 (SOC), 10.1 and 11.1 (Rejects)

and Jeopardies. Additionally, due to the build-up of service orders which were submitted

during this time period, it is anticipated that these manual performance measurements for

August and September will be impacted by this LASR GUI problem. In any event, SWBT

takes full responsibility for the LASR problem, and will be held accountable. Performance

measures impacted by this process problem are reflected in the results and SWBT will pay

appropriate performance penalties. For additional information regarding the problem with

LASR, see the Ham Affidavit and for information on performance measurements, see the

Dysart Affidavit (App. A, Tab 18).

44. Additionally, according to SWBT’s PM 11.1, averaging over the last four months, May

through August, SWBT has returned rejects to CLECs within 3.4 hours on average. These

results on PM 11.1 demonstrate that SWBT is providing the CLECs with rapid turn around

on manual rejects returned via LASR GUI, averaging 3.7 hours (Kansas) and 3.1 hours

(Oklahoma) in July for all orders in Kansas and Oklahoma, including complex. In fact, even

with the problems that SWBT experienced with LASR GUI during the month of August, the

LSC was still able to return rejects within an average of 8.3 and 6.8 hours respectively for

Kansas and Oklahoma CLECs during that month. Thus, the service currently provided by

SWBT on PM 10.1 surpasses the 95% standard within 24 hours deemed sufficient for BA-

NY. As previously stated, the FCC found that SWBT provides timely manual rejects which

offer an efficient competing carrier a meaningful opportunity to compete. Id. ¶ 175. In

Kansas and Oklahoma, as in Texas, SWBT provides manually generated rejects, on average,

in less than eight hours for June, July and August 2000, satisfying the nondiscrimination

standard.

MANUAL ORDER ENTRY

45. In response to CLEC concerns that manual order entry errors, including the manual creation of

service orders, could inject delays into the ordering process, the FCC found that even though

there was not performance data indicating performance measurement accuracy, that “SWBT

has processes in place to ensure the accuracy of these manual processes.” Id. ¶ 182. The FCC

also noted that Telcordia concluded that SWBT provides “a comprehensive approach for the

detection and analysis of manual data entry errors.” Id.

46. Since approval of the Texas 271 order, the LSC has continued to process orders on a manual

basis in a timely and satisfactory manner. SWBT’s Kansas and Oklahoma overall performance

as indicated by PM 35 (Percent Trouble Reports within 10 Days) and PM 59 (Percent Trouble

Reports within 30 Days) reflect that the LSC continues to provision orders accurately and with

little report of trouble by CLECs. Therefore, manual processing is not a significant source of

lost dial tone or other problems reported by CLECs. See the Dysart Affidavit (App. A, Tab 18)

for additional detail regarding these performance measurements and the Ham Affidavit (App.

A, Tab 15), regarding flow-through percentages. On average, during the past four months, the

LSC manually handled less than 20% of the total service orders submitted electronically.

SERVICE ORDER ACCURACY

47. Service Order Accuracy standards have been implemented in SWBT’s Local Service

Centers and are monitored and evaluated to determine individual service representative

errors. These standards are incorporated in the Non-management Performance Appraisal

Plan (NPAP) and are included in each service representatives overall performance rating.8

8 RESIDENCE REPRESENTATIVE BUSINESS REPRESENTATIVE* 100 – 99.1% Exceeds Expectations 100 – 95.1% Exceeds Expectations 99.0 – 98.0% Meets Expectations 95.0 – 86.0% Meets Expectations < 98% Below Expectations < 86% Below Expectations 20 Redacted For Public Inspection

In the event an individual service representative’s service order accuracy is rated “below

expectations,” disciplinary action is taken in compliance with the LSC NPAP standards and

in accordance with the 1998 Labor Agreements between SWBT and the Communications

Workers of America (CWA).

48. Telcordia reported that during its evaluation of the LSC’s manual processes, “monitoring

and validation of the Local Service Request (LSR) and Service Order data in context with

the manual LSC support functions did not uncover any major issues that impacted the

[functional test].”9 Furthermore, in reviewing the training programs, Telcordia reported that

“SWBT possesses the training programs that are required to assure that the LSC staff have

the necessary skills to adequately perform the manual LSC support functions.” Telcordia

Final Report at 95. Functions reviewed included the Posting Order Service Team (POST),

service order accuracy, appraisal standards and internal testing and auditing. Each function

was found to have “a comprehensive approach for the detection and analysis of manual data

entry errors, with a goal of reducing manual data entry errors.” Id. at 94. As noted earlier in

this affidavit, all of these observations apply equally to service provided by the LSC/LOC to

CLECs in Kansas and Oklahoma and across SWBT’s five-state region.

49. Service Order Accuracy is of significant importance and focus in SWBT’s LSC. In an effort

to minimize LSC service order entry error, SWBT collaborated with CLECs and the Texas

PUC to implement PM 12.1 as part of the new Version 1.7 business rules. This new PM

will track the accuracy of service orders typed by its LSC service representatives.

* The Business representative’s expectations are marginally lower than Residence representative’s expectations due to the complex nature of the service orders involved in the evaluation. 9 Telcordia Technologies at 95, The Public Utility Commission of Texas Southwestern Bell OSS Readiness Report (Sept. 1999) (“Telcordia Final Report”). 21 Redacted For Public Inspection

LSC PROCESS IMPROVEMENTS

50. While the LSC’s performance continues to meet the standards established by the FCC in its

Texas Order throughout its five-state region, including Kansas and Oklahoma, SWBT

continues to work with CLECs to provide enhancements to its processes in an effort to

provide CLECs with ever improving customer service.

51. The LSC has implemented additional initiatives to improve the quality of work that is

performed by LSC service representatives on orders that require manual intervention. This

information was shared with CLECs and the Texas PUC during a “UNE-P Three-Order

Process Workshop” held by the Texas Commission on Monday, September 11, 2000.

52. These LSC initiatives include the development of a Customer Care Training Packet for LSC

service representatives, which was developed based on information gathered through

collaborative meetings with the CLECs and internal analysis performed by the LSC

management team. The training package was covered with the LSC service representative

workforce in June and will be used in the training for new service representatives as well.

The Customer Care Training Packet includes detailed instruction in the following areas:

 Toll File Guide Issuance (“N” Order);  Jeopardies Returned;  Rejects Returned;  Errors and Error Reports;  Firm Order Confirmation Compliance;  Duplicate LSR/PONs Disposition; and  Responsiveness to CLECs.

53. In addition to the development of this training program, the LSC also has instituted the

Service Representative Development Manager position. These managers have been placed

in the individual line units that make up the LSC and specialize in the ordering processes

and procedures for particular product types (UNE loops, resale, LNP, etc.). These managers 22 Redacted For Public Inspection

are dedicated to “on-the-floor” coaching and developing the LSC service representatives,

conducting training and providing performance related feedback. The first development

managers were placed in the LSC in August of this year. The additional managers, a current

total of nine managers, were in place by the end of September.

54. SWBT also has refined the current non-management performance appraisal by instituting a

“scorecard” for each LSC service representative. This scorecard places additional emphasis

on the elimination of service affecting errors and the reporting of their error results through

the performance appraisal process. The service representatives in the LSC will be subject to

a random sampling and review of their orders. The service representative’s work from the

previous day will be sampled and will be reviewed for accuracy related to the service

order(s) and handling of the LSR (i.e. valid Reject, valid Jeopardy). The results of the

reviews will be tracked and shared with the service representative and the LSC management

55. The results will be used to evaluate each service representative in accordance with the Non-

management Performance Appraisal Plan (NPAP). The first occurrence of a service

affecting error will be documented in the employee record of discussion log, and the second

could result in disciplinary action being taken against the employee. SWBT is committed to

continuing to work with all CLECs to improve its processes and procedures to ensure that it

provides excellent service.

56. The Affidavit of Elizabeth Ham discusses the use of the RO and RRSO FIDs to ensure that

service orders remain related as they process through SWBT’s systems (App. A, Tab 15).

CLECs have expressed concern that these orders can become disassociated – leading to

disruption of service to the end user – due to order entry error by LSC service representatives. 23 Redacted For Public Inspection

As noted above, SWBT’s performance measurements demonstrate that disassociation of

service orders does not lead to service disruption on a significant number of CLEC orders.

However, in an effort to improve its service even further, additional documentation for the

handling of related orders was added to the existing Methods and Procedures for UNE-P on

August 27, 2000 and notification of this change was provided to all LSC service

representatives. This additional emphasis and training will assist in reducing the instances of

related service orders becoming disassociated as a result of due date or other changes. For due

date changes, the LSC has placed additional emphasis on ensuring that all service orders for

UNE-P conversion and new activity are related properly and that any change in the committed

due date is changed for all of the related orders.

SCALABILITY

57. The LSC monitors CLEC order activity on a daily and weekly basis to determine trends and is

prepared to respond to any increase in volume. SWBT has created a force model to anticipate

staffing needs based on historical trends, time and motion studies, internal forecasts and

referencing benchmarks.

58. Some of the elements considered by SWBT to determine force needs include: number of CLEC

applications pending for authority to provide services in SWBT’s five-state area; CLECs

approved and the type of agreements they have with SWBT; CLECs with approved tariffs; and

discounts for resold services and marketing efforts of the approved CLECs. Spikes in order

activity are handled by authorizing overtime, temporarily transferring personnel or

temporarily transferring responsibility for particular categories of orders from one group to

another. Initially, service representatives are hired and trained in one discipline, i.e. to

handle residential accounts or simple business accounts. As the need arises, LSC service

representatives are given additional training on the job to handle other types of order

requests. Because of this cross training, many LSC service representatives can handle

multiple types of service order requests. This gives the LSC the flexibility of moving

service representatives from one function to another, e.g., from business resale to residence

resale, and allows for greater flexibility in handling CLEC orders and responding to their

questions and issues.

59. After one year of service, SWBT employees are allowed to voluntarily transfer to the LSC;

however, company-wide quality and attendance standards must be met, just as in any

internal company transfer. These performance expectations are required for satisfactory

appraisal and continued employment throughout SWBT, whether in wholesale or retail

operations. Based on the factors outlined above, the LSC has staffed to its current level of

1,338 employees. Of these employees, 1,176 are service representatives trained in processing

manual and electronic orders. Continual monitoring of loads, market trends and internal

process improvements will ensure adequate force is available as customer activities continue.

60. A great deal of time and effort has been dedicated to tracking force requirements and

making sure that the LSC and LOC have a force model that ensures quality and parity of

service to the CLECs. Some of the basic data and assumptions that were used to develop

the force model include: number of business days per month, total minutes per day per

employee, productive minutes per day per employee, average handle time per report,

average reports per day per employee, forecasted reports based on class of service,

forecasted lines, forecasted report rate, reports received manually, mechanized reports,

forecasted new service turn-ups based on class of service and average turn-ups per

employee per day based on class of service. The model provides the ability to trend the

volumes. This provides a three-month, forward-looking prediction to determine if force

requirements should be accelerated to meet demand, allowing SWBT to provide the

required capacity in sufficient time to meet actual demand.

61. During the November 4, 1999 Texas PUC Open Meeting, the issue of scalability was

thoroughly revisited. At the request of the Texas PUC, SWBT provided Telcordia

additional information related to special Force Model studies as they pertain to variations in

CLEC transaction volumes and variations in error rates that cause transactions to require

manual processing. This was the third quarterly set of information that was reviewed by

Telcordia. Telcordia reviewed and verified the following:

 SWBT uses the same techniques for special studies and the normal monthly and quarterly Force Model and there was no variation in the techniques used for the special Force Model studies.  SWBT uses sound process techniques to develop the standards.  SWBT’s estimates, trends in adjustment factors and volumes were accurate.  SWBT includes all manual activities and adjustment factors and these were considered in the formulas used for all Force Model studies.  SWBT’s use of process standards and the estimations of adjustment factors were based on sound technique.  SWBT’s calculations are appropriate and mathematically correct.  SWBT provides continual monitoring and refinement of the estimates, based on historical data and/or time studies.

In summary, Telcordia found that the Force Model is based on sound engineering concepts

in terms of estimation and work force modeling and trending. During its evaluation of the

special studies, Telcordia concluded based on the range of predictions from the current case

scenario to the high case scenario, that SWBT should be able to meet CLEC demand over

the planning horizon.10

10 Open Hearing TR at 42, Investigation Into Southwestern Bell Telephone Company’s Entry Into In-Region, InterLATA Service Under Section 271 of the Telecommunications Act of 1996, Project No. 16251 (TPUC Nov. 4, 1999) (Attachment B to this affidavit). 26 Redacted For Public Inspection

62. Telcordia also conducted a thorough review of the scalability of the LSC/LOC manual

operations to meet projected demand and to accommodate unexpected, short-term “spikes”

in demand. As part of that review, Telcordia validated the Force Model estimation process,

volume contingency planning, disaster recovery planning, and scalability in context with

recruiting and training programs. Although Telcordia concluded that the procedures in place

were appropriate and adequate, the Texas PUC requested additional analysis in order to

satisfy its concerns regarding scalability. Specifically, the Texas PUC directed SWBT to

provide several force modeling scenarios (including fluctuating error rates and volumes) that

would test the impact on the force requirements and specified that those results must be

validated by Telcordia. As a result of this supplemental review, both Telcordia and the

Texas PUC concluded that the Force Model is based on sound engineering concepts and that

SWBT should be able to meet CLEC demand over the planning horizon.

63. The FCC found that SWBT’s mechanized and manual components of its ordering systems are

scalable to accommodate increasing demand. Texas Order ¶ 170. In fact, during this year,

January through August, CLEC order volumes, which are manually handled, have increased by

more than 160%, from more than 142,200 to 383,000. The LSC has scaled to handle this

dramatic increase in volume, and its continued compliant performance throughout the five-state

area demonstrates that the FCC’s findings in connection with the Texas Order remain true

today. The KCC Staff in its Final Report found that since SWBT follows the approved Force

Model and is staffed to the requirements of this model, and that the FCC’s findings on manual

scalability apply in Kansas.11 Additionally, after review of the information on the record in

Kansas, the KCC staff found that SWBT has adequate processes in place to address increases

11 Staff’s Recommendation at 20, Southwestern Bell Telephone Company’s Kansas 271 Application, Southwestern Bell Telephone Company – Kansas’ Compliance with Section 271 of the Federal Telecommunications Act of 1996, Docket No. 97-SWBT-411-GIT (KCC Aug. 21, 2000) (“KCC27 Staff’s Recommendation”) (App. C – KS, Tab 259). Redacted For Public Inspection

in volumes and that SWBT’s experience in responding to increased volumes without

significant degradation in performance supports this determination. KCC Staff’s

Recommendation at 20.

64. SWBT continues to provide the LSC’s staffing requirements in accordance with the same

force model that was reviewed and approved by Telcordia, the Texas PUC and by the FCC

in its decision that SWBT’s manual processes in combination with its OSS are scalable.

SWBT has increased the LSC’s service representative force in 2000 by more than 105%,

from more than 570 service representatives in January to more than 1,170 service

representatives in August. The LSC’s performance in this regard is all the more remarkable,

given that CLEC forecasting of anticipated volumes is almost non-existent. While CLEC

forecasts would enable SWBT to more accurately anticipate and plan for increases in CLEC

volumes, the LSC’s proven track record demonstrates that they are not necessary to enable

SWBT to scale its manual processes to handle reasonably foreseeable CLEC demand.

JEOPARDIES

65. After its review of SWBT’s jeopardy notices and processes, the FCC concluded that SWBT

provides CLECs in Texas with jeopardy notices in a nondiscriminatory manner. Texas

Order ¶ 184. SWBT’s “no facilities available” jeopardy notice is provided to CLECs in the

“same time and manner” as to its own operations. Id. Additionally SWBT’s process for

returning other jeopardy notifications via LASR GUI provides efficient CLECs with a

meaningful opportunity to compete. Id. ¶ 185. These findings are equally applicable to the

jeopardy notifications provided by SWBT to CLECs in Kansas and Oklahoma.

66. As set out in the Affidavit of Elizabeth Ham (App. A, Tab 15), in May 1999, SWBT

implemented a five-state process whereby a mechanized interface, Subscriber Held Service 28 Redacted For Public Inspection

Order Tracking System (SHOTS), provides mechanical feeds via LASR to LEX and EDI for

jeopardy situations relating to “no facilities available.” This type of jeopardy notice is

provided to CLECs in SWBT’s region in substantially the same time and manner as to

SWBT’s retail operations, which only receives jeopardy notifications when no facilities are

available.

67. Moreover, in August 1999, SWBT went beyond parity on jeopardy notification by

implementing a mechanical process covering jeopardy situations that are not addressed in

SWBT’s retail operations, such as no access. Although SWBT is not necessarily required to

actively provide electronic jeopardy notices, all applicable OBF-standard jeopardies can be

mechanically returned via LASR GUI to CLECs submitting orders through LEX or EDI.

These jeopardy situations are handled via LASR GUI like the electronic reject notifications

discussed above. Simply stated, a SWBT LSC service representative manually inputs one of

the applicable OBF-standard jeopardy codes into LASR GUI to produce an electronic

notification returned to CLECs via LEX or EDI.

68. The chart provided below for SWBT’s five-state area reflects the total number of jeopardy

notifications returned by SWBT via SHOTS and LASR GUI in the June through August

time frame. The percentage of SWBT caused jeopardies includes all jeopardy notifications

returned to the CLECs with a code indicating that the jeopardy was due to a SWBT cause,

including jeopardies due to a lack of facilities. The category of “CLEC or End User

Caused” includes all jeopardy notifications returned to the CLEC with a code indicating that

the jeopardy was the result of a CLEC cause. Such codes include jeopardies resulting from

such causes as the CLEC end-user not being ready; CLEC changes to the due date; no

access to the customer premises; and a CLEC requested due date that is less than published

interval.

# CLEC/EU % CLEC/EU # SWBT % SWBT Total Total Caused Caused Caused Caused LSRs Jeopardies Jeopardies Jeopardies Jeopardies Jeopardies June 255935 14945 8191 3.2% 6754 2.6% July 246274 18723 11430 4.6% 7293 3.0% August 315922 27113 17377 5.5% 9736 3.1%

69. Notably, SWBT caused jeopardies in the June through August time frame average only

2.9% of the total, while CLEC caused jeopardies represent 4.5%. Further, 23,174 of the

total 23,783 jeopardies attributable to SWBT resulted from lack of facilities, with only 609

(or 0.07%) resulting from some other SWBT cause. Thus relatively few jeopardy

notifications are attributable to SWBT causes and, as noted by the FCC in the Texas Order,

SWBT is held fully accountable for instances where SWBT-caused jeopardy situations

result in missed due dates.

70. SWBT “no facilities available” jeopardy notifications are provided to both SWBT retail and

CLEC orders in the same time and manner, utilizing the same databases via SHOTS. SWBT

provides real time jeopardy notification to CLECs utilizing the same electronic interface

used to submit the order. More than 98% of the remaining jeopardies are CLEC-caused, and

are returned to the CLEC via the LASR GUI interface. This additional jeopardy

notification, which goes beyond parity, provides CLECs in Oklahoma and Kansas – together

with those in Texas and throughout SWBT’s five-state region – with a meaningful

opportunity to compete in full compliance with the requirements of the Act.

71. Due date assignment and FOC return by the LSC are discussed at ¶¶ 30-37 above. Once the

FOC is returned to the CLEC, circumstances may arise that require a change in the due date. 30 Redacted For Public Inspection

These circumstances may be the result of a CLEC cause or a SWBT cause. Once SWBT

becomes aware that the order cannot be provisioned on the due date contained in the FOC, a

jeopardy notice is provided to the CLEC. This notification advises the CLEC that additional

action must be taken by either the CLEC or SWBT to change the due date before the order

can be provisioned and completed.

72. Once that action is taken, the due date is changed accordingly. A Missed Appointment Code

(MAC) identifying the cause for the original missed due date must be included on the service

order before the order can be completed and a SOC returned to the CLEC. The MAC codes

utilized to assign the miss to SWBT or to the CLEC are included in Appendix One of

Version 1.6 of the Business Rules.12

Examples of CLEC reasons are:

 Customer requests a later due date;

 Customer requests an earlier due date;

 No access at the customer premise;

 Customer not ready and requests a later date from the technician; or

 Building not ready for installation work.

Examples of SWBT reasons are:

 Company facilities not available (i.e. defective cable pair or service drop);

 Central Office Equipment not available on the due date; or

 Unable to complete the service order due to adverse weather conditions or heavy

work load.

73. Under LSC procedures, if a missed due date results from failure on the part of the LSC to

12 This same list also appears as Appendix One to the 1.6 version of the business rules. 31 Redacted For Public Inspection

timely clear an error condition, the change in the due date is assigned to a SWBT cause. In

other words, the LSC is responsible for acting in a timely manner to resolve error conditions

that place the order due date in jeopardy. Failure to do so counts against SWBT, even if the

underlying reason for the error condition is attributable to a CLEC cause. LSC service

representatives are required to review and work error conditions that will prevent a service

order from being provisioned on the due date a minimum of three times a day.

74. For resale and UNE-P orders, the assignment of a particular MAC code is relevant for the

calculation of the PMs for POTS (resale) and UNE Combination (UNE-P) provisioning (PMs

27–33). Under the Business Rules, missed due dates and associated delays in provisioning

are excluded from the calculation of these performance measurements if the Missed

Appointment Code indicates a CLEC cause for the missed due date.

75. SWBT offers all CLECs the option of reconciling the results of any performance measure. In

connection with one such reconciliation, SWBT provided a certain CLEC with raw data used

to calculate performance measurements on resale and UNE-P orders. On review, the CLEC

observed that the raw data did not include all orders that, according to their records, were

missed as a result of SWBT caused reasons. SWBT then proceeded to investigate the status

of those orders.

76. Upon reviewing service orders for this particular CLEC, the LSC discovered that a number

of missed due dates had been coded as CLEC-caused misses, when they should have been

coded as SWBT-caused misses. In investigating this miscoding further, the LSC discovered

that its service representatives had failed to consistently follow the appropriate methods for

assigning Missed Appointment Codes. SWBT also discovered that the service

representatives who had made these errors did not fully understand the potential impact of

the coding error on the above referenced performance measurements.

77. On Thursday, September 21, 2000, the LSC began implementing corrective actions to

address this issue. The LSC Service Representative Development Managers (RDMs) (See

¶ 53 above) reviewed the methods and procedures for coding missed due dates with all LSC

service representatives through intensive training sessions held during the latter part of

September through the beginning of October to ensure that future data would not be affected

by improper coding. The RDMs provided service representatives with an additional copy of

the list of MAC codes and reminded each of them about the location and use of the method.

They also discussed appropriate use of the MAC codes at length.

78. In addition, the RDMs are actively supervising the proper application of Missed

Appointment Codes as part of their quality reviews in the LSC.

79. The LSC first line managers also conduct service order reviews on the orders that are typed

and processed by their assigned service representatives. As part of this review, they have

placed additional emphasis on the use of the MAC to ensure coding accuracy. The managers

will provide immediate feedback to service representatives, together with additional training

as necessary. The potential for disciplinary action is discussed at ¶¶ 47-49 above.

80. In order to assess the impact of potential miscoding on the performance measurements

referenced above, the LSC undertook a comprehensive review of every Kansas and

Oklahoma service order coded to a CLEC MAC for the months of June through September.

The cause for the missed due date on each of these orders was determined by reading the

notes on the service order and by reviewing the change in status of the order from

distribution through completion. Information available from the Work and Force

Administration (WFA) system was also reviewed for fieldwork orders. Any errors in coding

on missed due dates were corrected. If during the course of this review there was any doubt

as to the correct code to apply for restating the performance measurements, the miss code

was attributed to SWBT.

81. Based on the recoding of these missed due dates by the LSC, the results of PMs 27 through

33 have been restated as set forth in the Affidavit of Randy Dysart.

82. The most frequently occurring cause of missed due dates on UNE-P and resale orders

identified during the course of the LSC review was failure on the part of the LSC to timely

resolve error conditions that prevented the order from being provisioned and completed on

the scheduled due date.

83. Upon realizing that errors preventing provisioning and completion were not consistently

being handled on a timely basis, the LSC quickly responded by reiterating to its workforce

that the conditions listed on the error reports must be resolved three times per day without

exception. The groups within the LSC responsible for handling manual SOC return also

have been given the added responsibility of monitoring error reports to further ensure that

errors are being handled on a timely basis.

84. Also, the LSC has implemented a new online reporting tool to give the service

representatives as well as LSC management the ability to monitor and manage progress as

the LSC works to eliminate the failure to resolve these conditions as a cause of missed due

dates. This reporting tool identifies all pending orders with conditions that must be cleared

before the order can be provisioned. Service representatives and managers can utilize this

report by filtering and sorting in different ways to allow everyone to monitor progress. For

instance, a manager can view a combined report of his or her entire workgroup, and an area

manager might pull a report by CLEC account. This added flexibility should greatly enhance

the LSC’s ability to stay informed on the status of these orders.

85. For various reasons, including the fact that some of the necessary data had been archived due

to age, the LSC was unable to determine the cause of the miss on a number of orders. As

noted earlier, any miss for which a cause could not be determined was assigned a SWBT

cause. The LSC has stressed to its service representatives the importance of providing

remarks concerning the cause of a missed due date on the service order, and the inclusion of

such remarks is one of the items being monitored by the RDMs, as referenced above.

86. The remaining restated missed due dates are attributable to a wide array of causes, none of

which occurred with a frequency that would indicate systemic process problems. In fact,

most causes had fewer than 5 instances in both states for all three months. Examples include

workload issues in the various downstream departments, address issues that were not

identified in the reject phase of the order, and other miscellaneous order issues.

87. The LSC is committed to continued progress and improvement in the coding of missed due

dates, as well as ensuring that all errors preventing an order from being provisioned and

completed on the due date are resolved on a timely basis.

COMPLETION NOTICES

88. In response to issues raised by CLECs during the Texas Collaborative Process regarding

Service Order Completions (SOCs), in September 1999, SWBT made available a FOC/SOC

Web Site, which allows CLECs submitting manual requests to check for FOC and SOC dates

and times via a personal computer. The FOC/SOC Website was created to provide increased

mechanization for those CLECs choosing to use the manual ordering process. Details of this

offering may be found in Accessible Letter CLEC99-118 (App. E-KS/OK, Tab 21). This web

site is password protected to the individual CLEC. This market-driven enhancement allows the

CLEC to elect to access information via this web site, or should they choose, the CLEC may

continue to receive FOCs via a manual fax as previously described. CLECs who submit orders

manually receive SOCs via the FOC/SOC web site.

89. SWBT measures service order completions in PM 7.1 (Percent Mechanized Completions

Returned Within 1 Day of Work Completion). SWBT has met the benchmark of 97% of

completions returned in Kansas for CLECs submitting orders via LEX for five of the last six

months and SWBT has met the benchmark for CLECs submitting orders via EDI for four of

the last six months. For orders submitted via EDI, volumes are relatively low in Kansas, and

SWBT’s misses on this measurement involve a total of seven misses in June and five in

August. SWBT’s overall average for the first eight months of this year reflect a very strong

performance, indicated by the 97.8% notifications returned within one day of work

completion for EDI and 97.2% for LEX. In fact, SWBT met the 97% benchmark for the

return of SOCs within one day (PM 7.1) in June and August when EDI and LEX orders are

considered together.

90. SWBT has met the benchmark of 97% of completions returned for Oklahoma CLECs

submitting orders via LEX for three of the last four months and SWBT has met the

benchmark for CLECs submitting orders via EDI for four of the last four months. SWBT’s

overall average for the first eight months of this year reflect a very strong performance,

indicated by the 98.8% notifications returned within one day of work completion for EDI

and 93.6% for LEX.

91. In an effort to address CLEC concerns regarding completion notices and improve SWBT’s

existing processes, the LSC has implemented the following process improvements:

 Reallocated resources to the Alliance LSC Service Order Completion and Posting Order Service Team (POST) (formerly Error Resolution Team) based on order volumes, projected forecasts and Root Cause Analysis;  POST is committed to continue its detailed analysis to determine the cause of service orders entering into error status;  Streamlined the process for the Posting Order Service Team to communicate progress on clearing outstanding orders with the SOC teams. This process improvement should eliminate any duplicate work that may have occurred during the investigation; and  Improved the process for tracking errors and providing feedback to individual service representatives. This improvement should provide better educational information to our service representatives, improving manual order input thus decreasing the recurrence of errors.

92. In addition, the following system enhancements either have been or are in the process of

being implemented:

 A LASR enhancement in the August 12, 2000 Release, relaxed the mismatch criteria for LSRs with canceled orders behind the request. This change will increase the number of orders that flow through and generate a mechanized SOC. The previous process required the LSC to review all of service orders and manually complete the order once the mismatch was addressed.  A LASR enhancement scheduled for September 2000 will add a SOC screen to LASR. This screen will assist in reducing the amount of time required to research and resolve each order. This screen will also provide the service representatives a more effective tool to monitor, prioritize and complete their workload.  An additional report is being developed that will provide the SOC team with a list of outstanding PONs. This report will enhance the ability of the LSC service representatives to ensure that all the data has been captured.

The process improvements and enhancements implemented, as a result of this effort will

apply to all CLECs in SWBT’s five-state area, including Kansas and Oklahoma CLECs.

POSTING

93. In April 1999, the LSC created a specialized Posting Order Service Team (POST), formerly

the Error Resolution Team (ERT) which has focused solely on clearing errors on orders that

have been completed, but for some reason cannot post for proper billing. This team

prioritizes its work by age of the error and bill date and is committed to having all errors

corrected prior to the date a bill would be rendered to the CLEC. The POST service 37 Redacted For Public Inspection

representatives check the BUC2 Report (Unposted Service Orders) daily to ensure that all

service orders are posting in a timely manner. The information obtained through this

approach is trended and given to LSC area managers to highlight areas that require

employee development or training. Additionally, SWBT provides this information to

CLECs to review their error trends. This approach to timely error resolution improved

SWBT’s overall billing completeness, as evidenced by PM 17, which reflects the percent of

service orders completed within the billing cycle that post in the Carrier Record Information

System (CRIS) or Carrier Access Billing System (CABS) prior to the CLEC’s billing

period. SWBT’s latest performance results for PM 17, which reflect near parity

performance with 98.1% (June), 96.3% (July) and 98.2% (August), and demonstrate that

SWBT has satisfied this requirement. SWBT’s performance on this Billing Completeness

measurement has met or exceeded parity for three of the last six months. However, even on

those months where SWBT did not meet parity, the difference was minimal and therefore

SWBT continues to offer CLECs a meaningful opportunity to compete. For additional

information on this performance measurement, see the Dysart Affidavit (App. A, Tab 18).

Additionally, the KCC Staff found that overall SWBT’s data on billing performance

demonstrates that its performance is adequate. KCC Staff’s Recommendation at 34.

94. The LSC and the CLECs have made great strides in reducing CLEC orders pending in error

status. LSC managers perform reviews to ensure the LSC’s objective to clear errors prior to

the next bill date is met. Timely error resolution is one of the factors considered in the

service representative’s job appraisal process. Increased attention has been given to this

critical area, with concentrated efforts to reduce the clearing time for errors to post to the

bill. In addition, now that CLECs can access SORD directly, CLEC service representatives

who have received training on error correction can monitor SORD fall-out and make

necessary corrections themselves.

95. In an effort to improve order processing and reduce orders in error status, each CLEC is

advised on how to do business with SWBT at the first workflow meeting with the CLEC.

Frequent meetings and conference calls are held with CLECs and, in some cases,

communication occurs on a weekly basis. Interconnection Services meetings are scheduled for

any CLEC who expresses a desire to meet on site with the LSC or LOC. These proactive

meetings are another tool that improves communication, resolves issues and demonstrates

SWBT’s interest in customer satisfaction. The LSC is focused on quality and demonstrates this

commitment with knowledgeable and experienced managers, extensive training and

development for service representatives and accurate service order performance. Process

improvements are evaluated internally and in partnership with CLECs.

ORDER PROVISIONING – LOC ROLE

96. The LOC’s role in provisioning CLEC orders for interconnection and unbundled elements

is a vital one. The CLEC first places its order directly for interconnection facilities and

UNEs through one of the electronic interfaces described in the Ham Affidavit (App. A,

Tab 15), or manually with the LSC, as discussed in this affidavit. In either case, SWBT’s

back-office systems (those systems not directly accessed by LSC service representatives,

but accessed by systems used by those service representatives) produce a work order that is

transmitted electronically to the LOC.

97. Upon receipt of the work order, the LOC network center technicians (NCTs) perform turn-

up and testing on the interconnection facilities, message trunks, unbundled elements or

resold special service circuits requested by the CLEC. At the same time turn-up is

performed, the NCT also provides testing of the element or service provided, to prove that

both quality of service and continuity are present. These tests are performed according to

the guidelines of the National Operations Forum (NOF), and results are provided to the

CLEC. Any CLEC that subscribes to Electronic Bonding (EB) will receive these results

electronically. If a CLEC chooses not to receive test results through EB, a LOC NCT will

provide the results to them over the telephone. More information on EB can be found in the

Ham Affidavit (App. A, Tab 15).

98. When the circuit is accepted by the CLEC, the order is completed and billing begins. The

acceptance process involves the LOC testing with the CLEC and the CLEC concurring with

the test results and accepting service. Alternatively, the CLEC is free to perform additional

testing without SWBT’s assistance, contacting the LOC only when it accepts service. If the

CLEC does not accept SWBT’s testing and elects to perform its own internal test or

monitoring, SWBT will hold the order open until close of business on the due date. On a

case-by-case basis, SWBT will work with the CLEC if it is determined that more time is

needed for acceptance. If no call is forthcoming from the CLEC, SWBT will close the

order.

MAINTENANCE AND REPAIR

99. The LOC handles all repair and maintenance requests of the CLECs and provides the

CLECs with the status of maintenance reports on demand. The LOC houses a specialized

group of 46 NCTs for the exclusive purpose of serving the CLECs maintenance and repair

needs. This group performs the same functions for all CLECs in the five-states, including

Oklahoma and Kansas. From January through August 2000, the LOC has successfully

processed 13,193 reports in Oklahoma, and 16,894 in Kansas. The LOC has already

processed over 83% of the number of reports for Oklahoma and Kansas in all of 1999 in the

first 8 months of 2000. The LOC maintains a hotline 24 hours, 7 days a week to allow

CLECs to call in trouble reports and receive status updates at any time.

100. In the Texas Order, the FCC found that “SWBT offers maintenance and repair interfaces

and systems that enable a requesting carrier to access all the same functions that are

available to SWBT’s retail representatives.” Texas Order ¶ 203. As in Texas, CLECs in

Kansas and Oklahoma may submit trouble reports to the LOC on all resold POTS lines,

interconnection facilities and UNEs through the Toolbar Trouble Administration (TBTA) or

the application-to-application Electronic Bonding Trouble Administration interface (EBTA)

(both described in the Ham Affidavit (App. A, Tab 15)), or by calling the LOC.

101. In its Texas Order, the FCC found that “SWBT repairs reported troubles [for] competing

carriers in substantially the same time and manner that it repairs troubles reported by its

own customers.” Id. ¶ 206. In order to make this determination, the FCC reviewed

performance data for measures 39 (Receipt to Clear Duration) and 52 (Mean Time to

Restore). Evidence that the FCC’s finding remains true for Kansas and Oklahoma can be

found in the performance SWBT has provided to CLECs in comparison to the performance

provided to its own retail customers on these measurements. Performance for UNE loop

and port combinations in Kansas and Oklahoma for PM 39, as addressed in the Dysart

Affidavit (App. A, Tab 18), shows parity or better than parity performance for the last three

months (June – August) in Kansas, and for all months in Oklahoma in which there is

sufficient data to make a determination of parity. In addition, Oklahoma data for PM 39-

01/02/03/04 (Receipt to Clear Duration – Affecting Service Dispatch/No Dispatch-

Residence/Business) indicates that on average SWBT clears troubles in less time for CLEC

customers than for its own retail customers. In Kansas, SWBT clears troubles on average

in less time for CLEC customers than its own retail customers on all equal measures, except

PM 39-03 (Residence-Affecting Service-No Dispatch). For this sub measure, SWBT

provides parity or better than parity performance in 9 of the last 12 months.

102. PM 52-01 (VGPL-Dispatch) and PM 52-06 (ISDN-BRI-Dispatch) are the only sub

measures for Mean Time to Restore in which there is any data to report in Oklahoma. For

the 10 trouble reports received for VGPL in the last 12 months under PM 52-01, SWBT

restored service in less time for CLEC customers than for its own customers. Equally, for

the 10 reports received for ISDN-BRI in the last 12 months, SWBT restored service in less

time for CLEC customers than for its own customers. In Kansas, PM 52-01 and PM 52-06,

are also the only sub measures in which there is a trend of data in which to analyze. For

PM 52-01, SWBT gave parity or better than parity service to CLEC customers in Kansas in

8 of the last 12 months. For PM 52-06, SWBT gave parity or better than parity service in 8

of the last 11 months. This evidence shows that Kansas and Oklahoma CLECs and their

customers receive the same or better level of service from SWBT than SWBT provides its

own customers with respect to the time and manner that SWBT repairs troubles.

103. The FCC also found in its Texas Order that “SWBT demonstrates that it performs

maintenance and repair work for customers of competing carriers at the same level of

quality as it performs for its retail customers.” Id. ¶ 209. The FCC reviewed performance

measures 37 (Trouble Report Rate) and 54 (Failure Frequency) in order to determine

SWBT provides quality maintenance work for CLEC customers. Evidence that the FCC’s

conclusion remains true for Oklahoma and Kansas CLECs can be found in the parity

performance demonstrated in PMs 37 and 54.

104. As discussed in the Dysart Affidavit (App. A, Tab 18), SWBT’s performance for UNE loop

and port combinations for PM 37-03 indicates that SWBT has provided parity or better than

parity service with respect to trouble reports rates for all of the last 12 months in Oklahoma

and 10 of the last 11 months in Kansas. In addition, for PM 37-01 (Residence - Trouble

Report Rate) and PM 37-02 (Business – Trouble Report Rate) SWBT has received on

average fewer trouble reports for CLEC customers than for its own retail customers for the

last 12 months in both Oklahoma and Kansas.

105. PM 54 reports data on PMs 54 - 01/06/07 (VGPL/ISDN-BRI/ISDN-PRI) in Oklahoma and

Kansas. In Oklahoma, SWBT has provided a smaller trouble report rate with respect to

failure frequency on CLEC ordered circuits on average over the last 12 months on all

reported measures under PM 54. In Kansas, for PM 54-01, SWBT provided parity or better

than parity performance for 10 of the last 12 months for CLEC customers. PM 54-06

indicates that Kansas CLEC customers issued fewer trouble reports than SWBT customers

over the last 12 months. PM 54-07 indicates that SWBT had a .05% (4 reports out of 8,704

ISDN-PRI circuits) trouble report rate for CLEC customers compared to a .03% trouble

report rate for its own customers in a 12 month period. This evidence clearly indicates that

SWBT is providing equal or better service to CLECs and their customers with respect to the

quality of work received during the provisioning and maintenance services provided by the

ORDERING AND PROVISIONING OF INP/LNP SERVICES

106. Number Portability (NP) is addressed in checklist item 11 of § 271 of the 1996 Act. SWBT

has devoted the time and effort necessary to ensure that NP is provided to CLECs “with as

little impairment of functioning, quality, reliability, and convenience as possible” in

compliance with Section 271(c)(2)(B)(xi).

107. SWBT’s NP offering has evolved over time as an effective and efficient means for CLECs

to acquire and retain customers. When NP began, the switches in the Central Offices (CO)

were not capable of handling Local Number Portability (LNP), which is primarily used

today. Instead, Interim Number Portability (INP) was used until SWBT upgraded its CO

switches to handle LNP. While INP orders will continue to be taken in areas where LNP is

not available, presently over 95% of the access lines in Kansas and 93% in Oklahoma are

now LNP capable. In fact, only two INP orders were issued in Kansas and 9 were issued in

Oklahoma between May and August 2000. The fact that Kansas and Oklahoma CLECs

have completed over 84,000 and 100,000 access lines respectively using LNP demonstrates

that SWBT has rolled out long-term portability commercially in both states.

108. To support CLEC LNP activity and minimize the potential for out-of-service conditions for

CLEC end users, SWBT established the LNP Center (LNPC) in 1997 for stand-alone LNP

conversions. Separate groups also were established to focus on LNP with loop conversions

through the coordinated hot cut and frame due time processes, discussed later in this

affidavit. Together, these groups constitute 94 highly trained employees who are dedicated

exclusively to LNP issues, both to support CLECs and internal LNP operations.

109. Extensive training is provided to all personnel involved with LNP. The LSC provides

training and reinforcement on the proper way to input all required information on all NP

service orders. SWBT also provides formal class instruction on LNP conversion processes,

trouble isolation and testing at the SBC – Center for Learning (CFL) for SWBT employees

and CLEC customers. In addition, “Flash” documents, which are “quick fix” procedures,

are distributed to ensure all involved organizations receive any method corrections as

quickly as possible.

110. A training manager position was instituted in the LNPC and coordinated conversion groups

in April 2000 for the benefit of SWBT employees responsible for the success of LNP

conversions. The training manager is responsible for technical instruction and quality

review for those employees who deal with LNP conversions.

111. Coordination and communication measures have improved in an effort to ensure that NP

orders are worked in a manner that is transparent to the end user. For instance, the LSC

service representative now contacts the LOC to schedule the port, confirm the due date and

frame conversion time and to make sure the LOC is aware that release of the order is

imminent. The LSC also improved communication between SWBT representatives and

CLECs regarding the importance of providing adequate notice for subsequent changes in

NP due dates and of providing correct information in its service request. February 16, 1999

CLEC Accessible letter CLEC99-023 communicates SBC’s position regarding due date

changes or cancellations of orders involving service provider number portability (App. E-

OK/KS, Tab 14).

112. Enhanced logging procedures have been implemented to track calls between SWBT

personnel and the CLECs to ensure adequate communication during the coordination

activities. This logging process tracks the progress of each NP order worked as a

coordinated conversion, as discussed in the Texas 271 Application. See Texas Conway

Affidavit ¶ 84 attached to Application of SBC Communications Inc., Southwestern Bell

Telephone Company, and Southwestern Bell Communications Services, Inc. d/b/a

Southwestern Bell Long Distance Pursuant to the Telecommunications Act of 1996 to

Provide In-Region, InterLATA Services in Texas, CC Docket 00-65 (FCC filed Jan. 10,

2000).

113. Performance measurements for stand-alone LNP conversions include PM 96: Percent of

Pre-mature Disconnects for LNP Orders; PM 97: Percent of Time SWBT Applies the 10-

Digit Trigger Prior to the LNP Due Date; PM 98: Percent LNP Installation Reports Within

10 Days of Conversion; PM 100: Average Time of Out of Service Condition; and PM 101:

Percent Out of Service Less than 60 Minutes. These measures and their results are

discussed in more detail in the Dysart Affidavit (App. A, Tab 18). Performance measures

related to LNP with loop are discussed in the Checklist Item 4 – Unbundled Local Loops

section of this affidavit.

CHECKLIST ITEM 4 – UNBUNDLED LOCAL LOOPS

114. SWBT offers switch-based CLECs a choice between two different methods for the

provisioning of unbundled “hot cut” loops: the coordinated hot cut (CHC) process and the

frame due time (FDT) process. These methods are used by CLECs to convert an active

SWBT customer to service provided by the CLEC. CHC orders are manually handled in

the SWBT LOC, and require coordination and communication between SWBT and the

CLEC during the cutover of the end user.13 By contrast, FDT orders do not require inter-

company communication at the time of the cutover; rather SWBT and the CLEC

independently perform the necessary work at pre-arranged times.14 CLECs may freely

13 Specifically, the CLEC contacts the LOC during the agreed upon conversion window. The LOC then contacts the SWBT central office technician to begin changing the wiring from the SWBT switch to the CLEC switch. The central office technician notifies the LOC when wiring changes are completed. The LOC then informs the CLEC that the wire transfer is complete and the CLEC activates the port of the telephone number. Conflicts are resolved via the interactive communication during the conversion. CHCs are required for requests for the migration of more than 24 UNE loops at a single end user address or requests for a migration to be worked with a Desired Frame Due Time (DFDT) outside normal installation business hours. 14 FDT is available during normal business hours, 8:00 a.m. to 5:00 p.m., Monday through Friday (excluding SWBT holidays) for orders of 24 or less UNE loops to a single user address, and where the 10 digit trigger process (described in the Affidavit of Gilbert Orozco) is available.46 At the scheduled time of an FDT, the SWBT central Redacted For Public Inspection

choose between CHC and FDT conversions, selecting the cutover method that best fits their

resources and their priorities.

115. In its evaluation of SWBT’s Texas 271 Application, the FCC concluded that SWBT

provisioned hot cut loops via the CHC process in compliance with the timeliness, quality

and outages criteria established in the Bell Atlantic New York Order. Id. ¶ 261.

Specifically, the FCC found that SWBT “provisions CHCs in a timely manner and at an

acceptable level of quality, with a minimal service disruption and a minimum number of

troubles following installation.” Id. As a result of problems relating to service disruptions,

the FCC found that SWBT could not establish checklist compliance based on FDT

conversions. Nevertheless, because CLECs may freely choose between the CHC and FDT

options, and because the CHC process affords efficient competitors a meaningful

opportunity to compete, the FCC concluded that SWBT provided nondiscriminatory access

to hot cut loops in compliance with checklist item (iv). Id. ¶¶ 267, 271.

116. The same CHC and FDT processes, procedures and performance measurements that the

FCC evaluated and approved in reviewing SWBT’s Texas 271 Application are in place and

available to CLECs in Kansas and Oklahoma. As described in greater detail below, SWBT

provides nondiscriminatory access to hot cut loops in Kansas and Oklahoma by: completing

at least 90% of hot cut orders of ten lines or less within one hour, with fewer than 5%

outages on conversions and 2% reported troubles within seven days of installation.

HOT CUT TIMELINESS

office technician removes the wires from the SWBT switch and positions the assigned wires from the CLEC switch to the cable pair. The CLEC activates the telephone number port 30 minutes after the scheduled conversion. FDT orders flow through SWBT’s systems because no interactive communication is required between SWBT and the CLEC for the FDT conversion process. FDT is offered free of charge (See Texas Order ¶ 271). 47 Redacted For Public Inspection

117. As noted above, the FCC established a timeliness standard in the Bell Atlantic New York

Order that requires 90% of CHC orders involving fewer than 10 lines to be completed

within one hour. New York Order, 15 FCC Rcd at 4105, ¶ 292. Applying a similar

standard (completion of 90% of hot cut orders involving ten lines or less within an hour) in

its Texas Order, the FCC concluded that “SWBT demonstrates that it can complete a

substantial percentage of CHC and FDT hot cuts it provisions within a reasonable time

interval.” Texas Order ¶ 262.

118. PM 114.1 measures SWBT’s ability to complete 100% of all hot cut loops of less than 25

lines within a two-hour window. Just as it did for Texas, in order to demonstrate that it

satisfies the BA-NY standard for Oklahoma and Kansas, SWBT has broken down PM

114.1 results for each state into the percentage of CHC and FDT cuts completed within in

one hour on orders of 1-10 lines.15 As detailed in Attachment C, between June and August,

SWBT completed 98.04% of CHC cuts in Oklahoma and 93.65% of CHC cuts in Kansas

within the one-hour time frame for orders of 10 lines or less. SWBT thus substantially

exceeds the FCC’s 90% timeliness standard in both Kansas and Oklahoma.

119. Very few CLECs in Kansas and Oklahoma have utilized the FDT provisioning process. In

the last three months, SWBT has received orders to provision only 2 loops via the FDT

process in Oklahoma, and 8 loops in Kansas. Both of the Oklahoma lines were provisioned

within the one-hour time period, for a performance level of 100%. Seven of the 8 Kansas

lines were on time, with one line taking 1½ hours to complete, resulting in an 87.50% FDT

on-time performance rate. Although SWBT falls just shy of the 90% threshold in Kansas,

15 This is the same process followed by SWBT for its Texas application. During the six-month performance measurement review conducted by the Texas PUC, PM 114.1 was revised. Under the new 1.7 version of the business rules, CHC and FDT conversions with loop will be specifically tracked on a one-hour completion basis for orders of less than 10 lines. Although not necessary for 271 purposes, SWBT agreed to revise the end-time of the CHC to include the time required to notify the CLEC that48 the cut has been completed. See Texas Order ¶ 266. Redacted For Public Inspection

the shortfall traces directly to the limited sample size and does not offer a complete picture

of SWBT’s ability to perform timely FDT cuts. A review of SWBT’s performance for

provisioning on time FDTs in Texas, where there are substantial volumes, provides a more

accurate portrait. As shown in Attachment D, for the same June – August time period

SWBT provisioned an average of 95.02% of the 5,441 FDTs in Texas within one hour.

Once Kansas CLECs begin to order FDT cuts in sufficient numbers to provide a more

accurate portrait of SWBT’s performance, there is no reason to believe that SWBT’s on-

time performance rates will not meet or exceed those in Texas.

OUTAGES ON CONVERSION

120. In its Texas Order, the FCC concluded that “SWBT demonstrates that the level of outages

competing carriers may experience as a result of failed SWBT CHCs is sufficiently small to

provide an efficient competitor with a meaningful opportunity to compete.” Id. ¶ 268. As

in Texas, outage information on hot cuts in Oklahoma and Kansas is available through PM

114, which reports premature disconnects on CHC and FDT conversions. Similarly, the

SWBT/AT&T Performance Process Improvement Group (PPIG) reconciled outage data for

the Kansas City, Kansas and Kansas City, Missouri serving area. No Oklahoma CLEC

requested a reconciliation of outage data.

a) Premature Disconnects

121. Under PM 114, a premature disconnect occurs when SWBT begins the conversion process

more than 10 minutes before the agreed-upon start time. As indicated in Attachment E,

there were no premature disconnects on any CHC or FDT conversions in Oklahoma or

Kansas during the June - August time frame, ruling out premature disconnects as a major

source of provisioning-related outages on either CHC or FDT conversions.

b) Kansas Outage Results

122. Under the auspices of the Texas Commission, SWBT and AT&T established the PPIG for

the purpose of identifying performance improvement opportunities for both companies on

CHC and FDT conversions. The PPIG has focused its efforts on reconciling performance

data related to outages occurring during the conversion process and, as of April, began

reconciling outage data for CHC and FDT conversions in the Kansas City area. Because

Kansas City Kansas and Kansas City Missouri are in the same LATA, and are served off a

single AT&T switch, the results for both cities have been combined pursuant to AT&T’s

request.

123. As noted above, the PPIG has focused on reconciling performance data for the purpose of

identifying CHC and FDT improvement opportunities. Because outages that occur on the

day of a CHC or FDT conversion currently are not picked up by any SWBT performance

measurement, that data has been reconciled as part of the PPIG process. In measuring

“outages,” however, the PPIG utilizes a broader definition than that employed by the FCC.

In particular, for performance improvement purposes, the PPIG also counts CHC

installation intervals of longer than 1 hour, and FDT installation intervals of longer than 30

minutes, as “outages.” Yet these timeliness deficiencies, which the PPIG labels “outages,”

are already captured by SWBT’s PM 114.1.

124. As set out in Attachment F, reconciled PPIG data for June, July and August shows a 2.76%

CHC “outage” rate, attributable to ***

*** Even including premature disconnects (of which there were

none), the 2.76% “outage” rate based on PPIG data clearly meets the 5% outage standard

set by the FCC.

125. In fact, none of these “outages” involved a disruption in service provided to the end user,

occurring after the conversion was complete. Rather, these *** *** all fell into the

PPIG “outage” category because their installation interval exceeded one hour. These ***

*** are all captured in the PM 114.1 results on provisioning timeliness.16

126. Similarly, PPIG data for FDT conversions counts ***

*** in June (the only month in which AT&T ordered FDT

conversions) as having sustained an “outage”. Again, each of these timeliness “outages” is

artificial. In each instance, the conversion was considered an “outage “ for purposes of the

PPIG because the cutover time exceeded 30 minutes in length. Where the conversion time

exceeded 1 hour, the standard used by the FCC, these FDTs are included in the PM 114.1

results.17

127. The FCC has made clear that there is a difference between measurements for the duration

of a hot cut (i.e., on-time performance as measured by PM 114.1) and measurements for

outages. This difference is reflected in the distinct FCC benchmarks for the two measures:

90% on-time performance as opposed to 5% BOC-caused unexpected outages. If the FCC

had intended that all conversions lasting longer than one hour would automatically be

counted as outages, it would not have established a lower benchmark for outages (5%) than

for over-length cuts (10%), as each cut exceeding 1 hour would necessarily be deemed an

outage. In other words, if untimely cuts were automatically considered outages, a 94% on-

time performance rate would translate into a 6% outage rate. Under the FCC’s standards,

16 Of the *** *** lines CHC in question, *** *** were provisioned in Kansas City, Kansas, and *** *** in Kansas City, Missouri. The Missouri lines are reflected in the reported Missouri results for PM 114.1. 17 Of the *** *** FDT lines in question, *** *** were provisioned in Kansas City, Kansas, and *** *** in Kansas City, Missouri. The Missouri lines are reflected in the reported51 Missouri results for PM 114.1. Redacted For Public Inspection

therefore, CHC and FDTs lasting longer than one hour should not count against SWBT

twice, once for PM 114.1, and then again as an outage.18

128. All of the CHC and FDT conversions that the PPIG data reconciliation deemed “outages”

for the June through August time period are attributable to conversions that exceeded one

hour in length for CHCs and 30 minutes for FDTs. There was no instance of an actual

outage occurring after the cut had been accepted as complete by AT&T, and there were no

premature disconnects. Therefore, SWBT has satisfied the outage standard for CHC and

FDT provisioning in Kansas.19

c) Oklahoma Outage Results

129. When the PPIG was initially established, SWBT advised AT&T that it was willing to

conduct data reconciliations across the five SWBT states. Although AT&T has requested

such reconciliations for Missouri and Kansas, it has made no request for reconciliations of

Oklahoma data. In fact, AT&T has not ordered any unbundled loops in Oklahoma to date.

Since October 1998 when SWBT first started reporting CHCs in Oklahoma for

performance measurement purposes, 1,853 unbundled loops have been provisioned via the

CHC process in Oklahoma for 50 CLECs, with more than 464 of those provisioned just

from January to August of this year. Notably, AT&T – a carrier with no unbundled loops

18 Although SWBT agreed to utilize a 30 minute duration interval on FDTs for PPIG process improvement purposes, the FCC’s standard for FDT on time performance is based on a one hour interval, with the FCC finding that “SWBT can provision a substantial percentage of competing carrier CHC and FDT hot cut loops within a 1 hour interval.” Texas Order ¶ 264. 19 During the course of the Kansas state 271 proceeding, Adelphia and KMC indicated that their performance measurement data on SWBT’s loop provisioning did not match up with the data provided by SWBT. As a result, SWBT scheduled meetings with both CLECs in an effort to address their concerns. The results of those meetings are summarized in SWBT’s Status Report filed with the Kansas Commission on September 15, 2000. (App. C-KS, Tab 278). Neither of these CLECs wished to reconcile data, choosing instead to focus on issues moving forward. While Adelphia disputed SWBT’s summary of the meeting, the Kansas Commission staff subsequently found that the “agreed action items appear to target the concerns identified in both Adelphia filings” and that the information in Adelphia’s additional filing “did not rise to a level that would prevent approval of SWBT’s application.” Second Addendum to Staff’s Recommendation at 2. No other CLEC52 has requested a reconciliation of data in Kansas. Redacted For Public Inspection

in the state – is the only CLEC that filed any comments in the Oklahoma state proceeding

related to hot cut performance.

130. In order to assess the outage rate in Oklahoma in the absence of data reconciliation, SWBT

has undertaken an internal review of its log notes for all unbundled loops provisioned via

either CHC or FDT from April through August 2000. The purpose of this review was to

determine if any of those cuts resulted in an outage after the cut had been accepted by the

CLEC on the day of or before noon on the day after the conversion. Based on SWBT’s

review, no such outages occurred. This evidence – together with SWBT’s 100%

performance on premature disconnects in Oklahoma, the absence of any CLEC complaints

indicating that any conversion-related outages have occurred, and the fact that no CLEC has

requested a reconciliation of hot cut data– demonstrates that SWBT’s overall outage rate in

Oklahoma remains well below the FCC’s 5% standard.

131. As part of the Texas six-month performance measurement review, the Texas PUC has

recently approved revisions agreed between SWBT and the CLECs for PMs 96, 114, 114.1

and 115, as well as a new PM 115.1. These Performance Measurements are designed to

further ensure that CHC and FDT provisioning are accurately measured, and are measured

in accordance with the standards established by the FCC in the Texas and New York 271

proceedings. In particular, the revised PM 115 will measure the percent of CHC/FDT

circuits for which the CLEC submits a trouble report on the day of conversion, or before

noon on the next business day. This measure thus will provide a “useful, standardized way

for competing carriers to assess FDT and CHC outage rates in the future and will enable

competing carriers to determine which method better suits their business plans.” However,

the fact that these measurements are not in place today does not impact the evidence

presented with this filing. Namely, the Kansas and Oklahoma data provided in this

affidavit are based on the same performance measurements and reconciliation processes

that were in place in Texas when SWBT’s Texas 271 application was approved by the FCC.

These measures demonstrate that SWBT’s performance on outages satisfies the FCC’s 5%

outage standard for both Kansas and Oklahoma.20

TROUBLES AFTER INSTALLATION

132. In the Texas Order, the FCC concluded “SWBT demonstrates that competing carrier end

users experience only very low rates of installation troubles on lines provisioned by CHCs

and FDT hot cuts.” Id. ¶ 274. That finding is equally applicable to both Kansas and

Oklahoma.

133. SWBT’s performance on troubles after installation is measured by PM 59: Percent

Installation Reports (Trouble Reports) Within 30 Days (I-30) of Installation. SWBT’s

performance for PM 59 is discussed in detail in Randy Dysart’s Affidavit (App. A, Tab 18).

Although I-30 information is tracked according to loop type (8db, 5db and BRI), the

information is not mechanically broken down into FDT and CHC conversions. In order to

provide a comparison to BA-NY, which measures its trouble reports on a 7-day basis,

SWBT has broken its I-30 report into trouble reports received on CHC and FDT

conversions within 7 days of installation for the months of June through August. Although

troubles received on the day of conversion are not included in the I-30 data under PM 59,

SWBT does include these trouble reports in its I-7 data.

134. Given the moderate volumes of LNP with loop activity in Kansas and Oklahoma, it takes

very few reported troubles to impact results that are expressed in percentages. In absolute

20 Based on the review of SWBT’s log notes discussed above, none of the CHCs in Oklahoma in the April-August time frame would have resulted in an outage trouble report under the new PM 115. Similarly, none of the AT&T CHC or FDT hot cuts reconciled in Kansas as part of the 54PPIG process would have resulted in such a report. Redacted For Public Inspection

terms, there were only 3 reported instances of trouble on a base of 128 CHC conversions in

Oklahoma, and 2 reported instances of trouble on a base of 138 CHC conversions in

Kansas. As Attachment G indicates, these minimal trouble reports translate to an I-7

performance rate of 2.34% in Oklahoma and 1.45% in Kansas.

135. SWBT provides the three-month view of performance results for the purpose of consistency

throughout this affidavit. However, if a four-month view (May – August) is taken with

respect to I-7s in Oklahoma, the report rate drops to 1.7% (3 reports out of a base of 176

CHC conversions).21 Using this broader view, which provides a more accurate picture of

SWBT’s Oklahoma performance in light of the limited sample size, SWBT easily satisfies

the 2% trouble report standard for both Oklahoma and Kansas.

136. Data for both Oklahoma and Kansas shows that no trouble reports were received in the first

seven days after installation on any of the FDTs ordered in the either state from June

through August. This performance shows that SWBT is providing CLECs quality service

with respect to FDT cutovers, as a viable alternative to the CHC process.

FDT STATUS

137. From January through August of this year, CLECs in Kansas have submitted 51 requests

for LNP with loop conversions on a non-coordinated basis using SWBT’s FDT process. In

August, SWBT received its first requests for FDT conversions in Oklahoma. As outlined

above, FDT is a voluntary ordering option developed by SWBT and made available to

CLECs for provisioning UNE loops on a non-coordinated basis. SWBT has devoted

considerable effort to developing and improving its FDT performance, and those efforts

21 For May I-7 results see Noland/Smith Supplemental Reply Affidavit Attachment I Attached to Application by SBC Communications Inc., Southwestern Bell Telephone Company, and Southwestern Bell Communications Services, Inc. d/b/a Southwestern Bell Long Distance Pursuant to Section 271 of the Telecommunications Act of 1996 to Provide In-Region, InterLATA Services in Texas, CC Docket 00-4 (FCC filed May 19, 2000). 55 Redacted For Public Inspection

benefit CLECs throughout the SWBT five-state region. As in Texas, Kansas and

Oklahoma CLECs may freely choose between the CHC and FDT methods for provisioning

unbundled loops.

138. CLECs have been taking advantage of the FDT option over SWBT’s five-state region, and

on average have been doing so in greater quantities than CHC. This is demonstrated in the

chart in Attachment N, which shows the quantities of lines ordered via CHC versus FDT

from January to August 2000 for the five states. The quantities of CHC versus FDT show

that over 54% of the unbundled hot cut loops provisioned in the five states were ordered as

FDT. This fact illustrates both the extent to which CLECs consider the FDT process a

viable alternative to CHC conversions, and that SWBT can provision FDTs at a level of

quality and timeliness that meets those CLECs expectations.

139. In the Order Regarding Recommendation on 271, the Oklahoma Commission found that

“Southwestern Bell provides nondiscriminatory access to hot cut loops in accordance with

the criteria suggested by the FCC in its New York Order and its Texas Order” and that

“Southwestern Bell additionally satisfies each of the performance measures for coordinated

conversion currently in effect in Oklahoma.”22 In addition, the Kansas Staff found that

“SWBT provides timely and reliable hot cut performance at levels exceeding those that the

FCC found to be nondiscriminatory when it evaluated Bell Atlantic’s New York

Application.”23 This Commission should reach the same conclusion.

DIGITAL SUBSCRIBER LINE (DSL)

140. DSL-capable loops are a relatively new product type introduced to the wholesale market and

offered to facility based CLECs in 1999. See the W.C. Deere (App. A, Tab 4) and Carol

22 Order at 182, Recommendation On 271 Application Pursuant To Telecommunications Act Of 1996, Cause No. PUD 97-560 (OCC Sept. 28, 2000) (“OCC Final Order”) (App. C – OK, Tab 275). 23 KCC Staff’s Recommendation at 49. 56 Redacted For Public Inspection

Chapman (App. A, Tab 3) Affidavits for greater detail regarding this product. The Ham

affidavit provides information on OSS availability and support for DSL (App. A, Tab 15).

141. SWBT created the DSL Tracking Web Site (an Intranet tool) to provide LSC service

representatives with an interim venue to communicate with Outside Plant (OSP) Engineering

to provide DSL manual loop qualification information to CLECs. DSL Tracker was

eliminated on May 25, 2000. With the April 18, 2000 Release of Loop Qual 3.0, it is no

longer necessary for the LSC to submit the Manual Loop Qual requests via DSL Tracker. In

addition, with this update, it is no longer necessary for the LSC to routinely submit Manual

Loop Quals for CLECs. If CLECs wish to receive Loop Qual information, the CLECs submit

Loop Qual requests via Verigate or Datagate. In the rare instance that the LSC needs to

submit a Manual Loop Qual request for a CLEC, the LSC would submit the request via

Verigate.24 For additional detail regarding this new process, see the Ham and Chapman

Affidavits.

142. SWBT provides CLECs with nondiscriminatory access to the same detailed information

about the loop that is available to itself. The FCC has already concluded that SWBT

provides CLECs equivalent access to the same loop makeup information that SWBT itself

uses, and in the exact same time frame. Id. ¶¶ 165-168. The FCC stated “[w]e find that

mechanized and manual processes provide competing carriers access to loop qualification

functionality in substantially the same time and manner as SWBT’s retail operations.” Id.

¶ 167. Likewise the KCC Staff determined that it believes that SWBT is providing the

information which is required. KCC Staff’s Recommendation at 29.

143. If the CLEC so chooses, the Universal Tracking DataBase (UTDB) will return an email

24 This manual process is only necessary when there is no designed or actual data loaded, or on an interim basis, for new CLECs until their OSS is in place. 57 Redacted For Public Inspection

notification to CLECs when the Loop Qual information is returned from OSP Engineers. The

CLEC must request this option via the LSC if they wish to receive email notification.

144. As with all LSC/LOC procedures, this agreement applies to Kansas and Oklahoma as well as

the other states in SWBT’s five-state region. For a comparison of CLEC and SWBT retail

DSL pre-ordering, ordering and provisioning processes, see the Chapman Affidavit.

145. In SWBT’s five-state region, as in New York, CLECs have been ordering DSL capable

loops for a “relatively short period of time.” New York Order, 15 FCC Rcd at 4119, ¶ 322.

In SWBT’s five-state area, since September 1999, there has been a steady increase in

demand (compare 19 DSL loops in September 1999, with more than 17,381 DSL loops in

August 2000).

146. SWBT has implemented the following methods and procedures as a result of the UNE

Remand Order:

 Special Access to UNE;  Dark Fiber;  Line Sharing; and  Sub Loop.

BILLING

147. The LSC is responsible for billing monies owed to SWBT by its CLEC customers for

services ordered. Interconnection agreements specifically address the CLECs’ financial

responsibilities regarding bill payment to ensure continuous service. It is the responsibility

of the CLEC to remit any monies due to SWBT, as stipulated by its contract. A centralized

group specializing in these activities was created as part of the LSC in January 1998. This

operation is similar to the billing teams in SWBT’s retail offices. This LSC group serves as

the single point of contact for CLECs on all billing issues and questions. It answers billing

questions, makes adjustments for incorrectly billed amounts and ensures parity among all 58 Redacted For Public Inspection

CLECs. Currently 1 area manager, 5 managers and 36 service representatives are dedicated to

billing activities. This team is also responsible for resolving any billing disputes that arise.

Some common types of disputed charges result from the service representative’s failure to:

waive installation charges; provide correct tax information, which results in an under or over

billing of the account; or correctly apply repair charges. The billing group shares this

information within the LSC to provide feedback to each order-provisioning unit. This process

helps identify additional training requirements and contributes to individual performance

evaluations. Additional disputed charges can also be caused by the CLEC, and include such

common mistakes as incorrectly associated account numbers (AANs), duplicate orders and

missing post office address (i.e. city and state). To date, the LSC billing group has resolved

several billing disputes with CLECs and has taken action to investigate and adjust incorrect

amounts or to explain why the amounts are correct and collect monies owed to SWBT. See

the Dysart Affidavit for a review of billing measurements (App. A, Tab 18).

148. Finally, this group works closely with the account managers and the legal department to

ensure contract compliance.

DISASTER RECOVERY

149. The LOC has developed a disaster recovery plan to ensure that a back-up maintenance

organization is available to provide service to CLECs in case of a national or local

emergency or weather-related event that would interrupt the operations of the LOC. The

disaster recovery plan documents the procedures and guidelines on the emergency transfer

of the LOC functionality to other workgroups with similar system access. To ensure

continuity of service, CLECs will be notified of the transition via an event notification

routine.

150. Similarly, the LSC has a disaster recovery plan in place to allow for continued operation of

center locations. This was reviewed and approved by Telcordia. Telcordia Final Report at

151. If a major network event such as a switch conversion is scheduled, which could

significantly impact the network, CLEC customers receive an Accessible Letter in advance

of the change. In addition, the CLEC can request to be notified via a Broadcast Fax on any

upcoming switch conversion or generic upgrade. The Centralized Network Operations

Center (CNOC) will fax this information, based on the CLECs request to its account

manager via the CLEC profile.

ADDITIONAL INTERCONNECTION SERVICES OFFERINGS

152. The LSC offers consultations and conferences to customers on SWBT premises or the

CLEC’s. Topics include workflow processes, contact lists and escalation processes and

address any unique request the individual customer may present. These meetings are

conducted as SWBT begins processing orders as well as any time the CLEC requests.

Several customers have requested and received ongoing conference calls to discuss

operational practices and individual service issues.

153. The LSC strives to establish a good working relationship with all CLECs. This is done, in

part, by training CLECs to utilize SWBT’s offerings properly. SWBT offers CLECs education

in two categories, workshops and OSS classes. All CLEC classes are instructor-led, in-class

sessions. This enables the instructor to ensure a quality learning experience and achieve a

certain level of understanding for each student rather than rely on self-instructional tools.

SWBT offers a variety of workshops on how to do business with our company. Workshops

cover operational information that is required for both manual and electronic order processing.

Workshops regarding operational issues are covered in detail in the Sparks Affidavit. Those

offered for OSS are included in the Ham Affidavit (App. A, Tab 15).

154. The workshops are followed by CLEC-specific operational workflow meetings, which outline

standard practices and procedures and discuss any request made by the individual CLEC. This

gives the CLEC the opportunity to discuss any specific need that may exist in its business,

which would require either a modification to standard procedures or the development of a new

SWBT practice. Examples of issues that have been addressed are how the CLEC can submit

orders, how due dates are determined and what charges are applicable to a particular type of

service. Once these specific practices are established and agreements and contracts are signed

and approved, the CLEC and SWBT can begin doing business. No matter how large and well-

funded a CLEC may be, starting a new enterprise is never easy, and SWBT recognizes this.

Although training and handbooks are provided, the LSC is ready to help with such tasks as

how to get an order issued, how to order directories and what procedures to follow if special

attention is needed for a service request. If problems occur in meeting CLECs’ expectations,

the LSC works cooperatively with the CLEC to resolve them. As was previously discussed,

one area of concern in the past was SWBT’s provisioning of INP. Close coordination and fine-

tuning of internal processes resolved customer problems with this offering.

155. In an effort to create a positive working atmosphere, SWBT invites CLECs to attend

individual orientation sessions at the LOC. These sessions include a presentation to define

what the CLEC can expect from the LOC. The CLEC will have an opportunity to meet

LOC personnel as well as see the tools the CSRs and NCTs use to provide provisioning and

maintenance functions. The presentation package includes contact lists, escalation lists and

details on the overall functionality of the LOC. Since February 1998, more than 45 CLECs

have elected to attend these presentations, tour the LOC and meet the LOC personnel in an

effort to begin the partnership on positive ground. The orientation presentation to the

CLECs is Attachment H to this affidavit.

ESCALATION AND COMPLAINTS

156. A well-documented escalation process is available to CLECs for their convenience and can

be found in the CLEC Handbook. For example, as soon as the LOC CSR is made aware of

a service outage regarding the CLEC’s overall network or any essential lines (those

designated important to a community, e.g. fire department, police, hospitals, etc.), the CLEC

is advised that the service condition will immediately be subject to management escalation.

The CLEC is immediately transferred to a manager or, if after hours, the duty supervisor is

notified. The after-hours duty supervisor contacts the CLEC within 30 minutes of receiving

the notification to provide the customer with a report regarding the status of trouble

resolution. The manager provides a status report every 30 minutes for the life of the trouble

ticket. The LOC management team coordinates with all involved SWBT departments to

ensure speedy resolution.

157. Escalation requests for CLECs’ end user POTS service are processed using the same

procedures and times as requests for escalation of retail POTS customers. Escalations for

special services (i.e., Voice Grade Private Line, Digital Data Services, etc.) are processed in

the same manner as escalations are processed in retail.

158. The LOC provides CLECs with contact or escalation lists and disaster recovery plans, and

educates them on the LOC’s internal work flows and processes (See Attachments I and J).

Escalation lists provide CLECs a handy reference for identifying SWBT management

contacts that may be called to expedite either a maintenance or provisioning request. The

escalation lists are available in the CLEC Handbook.

159. Likewise, the LSC has a disaster recovery plan in place to allow for continued operation of

center locations, which is Attachment K to this affidavit.

160. The LSC and LOC have implemented structured procedures for handling all formal and

informal complaints from CLEC customers, which require manager involvement. When a

complaint is received, it is immediately referred to a manager who is responsible for

completing a customer complaint investigation form (Attachment L) and hand delivering it

to the manager who will conduct the investigation. This manager, along with his area

manager, will review the initial complaint form for accuracy and completeness and deliver a

copy of it to the district office for tracking. Within 24 hours, a status report must be

submitted on a second form. This process continues for every 24-hour period that the

complaint is unresolved. Once resolution is reached, a final form closing out the complaint

is completed. As previously mentioned in this affidavit, SWBT also offers CAST, which

provides additional coordinated support to CLECs as well as, Account Teams, LSC and

LOC organizations. CAST may be contacted at any time by the CLEC to resolve and

coordinate any problem it may be having.

161. Interconnection Services reports over 85 performance measurements, negotiated to evaluate

the effectiveness of the pre-ordering, ordering, provisioning, maintenance and billing

services performed by LSC and LOC personnel. A listing of all performance measurements

that monitor this division’s performance is Attachment M to this affidavit. Specific results

can be found in the Dysart Affidavit (App. A, Tab 18).

162. At the request of the Texas PUC, and in conjunction with the CLEC community, SWBT

also developed and implemented a CLEC User Forum. These meetings began in Texas for

SWBT’s five-state region (including Kansas and Oklahoma) in December 1999 and are

ongoing and cover issues, which the participants deem critical to business requirements.

Notification of CLEC User Forum meetings/conference calls are distributed via Accessible

Letter to CLECs in SWBT’s five-state area. This forum allows discussion and sharing of

information on process and operational issues.

The purpose and scope of the CLEC User Forum has been defined by the participants to

include:

 Network Operations;  Business Processes;  Ordering and Provisioning;  Maintenance and Repair;  Billing; and  Other.

163. Processes defined for the forum include the following:

 Two-tier organization; 1. Executive Steering Committee (ESC) with one representative from each CLEC and one from SWBT; 2. CLEC User Forum (CUF) with assigned CLEC representative(s) as well as CLEC and SWBT subject matter experts;  Scheduled meetings [ESC will participate on conference calls twice per month (quarterly, will meet in person), and CUF will meet once a month];  Issues submission;  Issues tracking;  Issues resolution and Issues sponsorship; and  SWBT will provide conference bridge, meeting room, meeting schedule, issue tracking, SMEs for meetings/projects, coordinate tracking and follow-up of issues and release accessible letters as necessary.

164. The CLEC User Forum offers an arena for open discussion on operational issues and

processes. The issues addressed by this forum are those which impact the daily business

practices of multiple CLECs. The intention of all participants and the Forum as a whole is

to work cooperatively through a defined problem resolution process.

INTERCONNECTION SERVICES COMMITMENT

165.SWBT has committed substantial resources to assist its CLEC customers’ entry into the

local marketplace. The services provided and efforts expended demonstrate SWBT’s

dedication to this growing market. All Interconnection Services entities will continue to

concentrate on customer service and satisfaction. The steady improvements discussed above

will continue these organizations’ focus on providing efficient problem resolution and

improved responsiveness, and will ensure that issues, if they arise, are addressed by the

SWBT work group that can eliminate the problem. The mission of Interconnection Services

is to create the highest level of customer care in the industry.

166.Customer service is the hallmark of Interconnection Services. The Division was created

solely to serve the local marketplace, and it will remain dedicated to providing service to

CLECs. Management and non-management alike have their pay based on customer service

excellence. Non-management appraisals are impacted by customer comments, complaints

and compliments. Management pay is tied directly to performance for this market, with the

focus of these channels directed to supporting the CLEC customer.

CONCLUSION

167. Since 1996, SWBT’s LSC and LOC have been committed to providing the best possible

service to its CLEC customers. As stated in this affidavit, the LSC and LOC maintain

Force Models, which were developed and are utilized to ensure that its centers are

adequately staffed to meet CLEC requirements for SWBT’s five-state region, including

Kansas and Oklahoma. These Force Models were reviewed during the Texas Collaborative

Process on two separate occasions and found to be based on sound engineering concepts in

terms of estimation and work force modeling and trending.

168. Additionally, SWBT’s LSC service representatives undergo approximately three months of

training, similar to SWBT’s retail service representatives, to develop their skills in

processing CLEC transactions. The LSC monitors CLEC transactions on a daily and

weekly basis; this information, along with historical trends, time and motion studies,

internal forecasts, and referencing benchmarks, is used to ensure that the LSC always has

sufficient staffing.

169. The LOC ensures that its center is adequately staffed with knowledgeable personnel ready

to handle the provisioning and maintenance needs of CLECs at volumes they request. LOC

NCTs and CSRs undergo extensive technical and customer service training. LOC

personnel must complete specific training courses as a prerequisite for performing their job

duties, and then throughout their employment receive up to date training as it becomes

necessary to stay informed of current methods and procedures.

170. The LSC’s performance, as reflected in Version 1.6 of its Performance Remedy Plan,

support SWBT’s efforts to provide CLECs business needs. In fact, the LSC’s overall

performance is quite good and offers an efficient CLEC with a meaningful opportunity to

compete. SWBT and the CLECs have dedicated much effort to ensuring that SWBT’s

Performance Remedy plan includes those areas which CLECs deem important to a

successful entry into the wholesale marketplace.

171. The maintenance and provisioning groups within the LOC have provided CLECs a

meaningful opportunity to compete by performing maintenance functions at levels better or

equal to that given SWBT’s own retail customers,66 and provisioning unbundled loops Redacted For Public Inspection

through the hot cut processes with LNP at acceptable levels of timeliness and quality.

SWBT’s LOC has worked to comply with checklist item 4 in all of SWBT’s five-states,

including Oklahoma and Kansas. Review of the performance measurements in Version 1.6

as well as the three criteria set by the FCC in the Bell Atlantic Order and Texas Order

reveal that SWBT has satisfied checklist item 4 with respect to the provisioning of

unbundled loops through the CHC and FDT methods. SWBT has long been and will

continue to be committed to working with CLECs in providing resources to meet their end

user requirements.

172. This concludes our affidavit.

I declare under penalty of perjury that the foregoing is true and correct to the best of my

knowledge.

Executed on ______, 2000.

______Brian D. Noland Director – Wholesale Regulatory

STATE OF TEXAS )

COUNTY OF DALLAS )

Subscribed and sworn to before me this ______day of ______, 2000.

______

Notary Public