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DIRECT TESTIMONY of CHRISTOPHER L. GRAVES TELECOMMUNICATIONS DIVISION ILLINOIS COMMERCE COMMISSION DOCKET NO. 00-0592 Re-Hearing

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DIRECT TESTIMONY of CHRISTOPHER L. GRAVES TELECOMMUNICATIONS DIVISION ILLINOIS COMMERCE COMMISSION DOCKET NO. 00-0592 Re-Hearing DIRECT TESTIMONY OF CHRISTOPHER L. GRAVES TELECOMMUNICATIONS DIVISION ILLINOIS COMMERCE COMMISSION DOCKET NO. 00-0592 Re-Hearing April 26, 2001 Docket 00-0592 ICC Staff Ex. 1 .OO (Graves) Page 1 of 10 1 Q. Please state your name, occupation and business address. 2 A. My name is Christopher L. Graves. I am employed by the Illinois Commerce 3 Commission as a Policy Analyst in the Telecommunications Division. My 4 business addrass is 527 East Capl.",..."‘tnl AmapotoI"", Snrinnfinlri-r#.'.J'-'-, .IIIi-pis~E;2794, . 5 6 Q. Please state your educational background. 7 A. I received a Bachelor of Arts degree in Economics from Illinois State University in 8 1990. Also, I hold a Master of Arts Degree in Economics from Southern Illinois 9 University at Edwardsville, which I received in November of 1997. 10 11 Q. Please state your professional experience. 12 A. While studying for my masters degree, I interned with the economics group of 13 the Revenue and Public Affairs Division of Southwestern Bell Telephone 14 Company in St. Louis. As an intern, I researched topics relating to 15 telecommunications economics and pricing for the staff economists. During the 16 summer of 1996, I worked briefly for INDETEC International as a litigation 17 support analyst. INDETEC is a consulting firm specializing in 16 telecommunications and utilities economics and costing practices. 19 20 Q. When did you join the Illinois Commerce Commission? 1 Docket 00-0592 ICC Staff Ex. 1 .OO (Graves) Pagezoflo 21 A. I joined the Commission in October of 1996. 22 23 Q. Please briefly describe your work duties with the Commission. 24 A. My responsibilities include reviewing tariff documents and cost studies submitted 25 ~&I the Com~misslon~~b\llte!ecommunlca!ions czrrierf 2nd making 26 recommendations to the Commission regarding those filings; providing economic 27 analysis on pricing and cost issues in dockets before the Commission; and 26 answering inquiries regarding wholesale pricing policies of the Commission. I 29 have provided testimony in the following docketed proceedings: Docket No. 99- 30 0593, Special Construction; Docket No. 00-0027, Focal Communications 31 Corporation Arbitration; Docket No. 99-0525, McLeodUSA Telecommunications 32 Service, Inc. (McLeod) complaint against Illinois Bell Telephone Company 33 (Ameritech Illinois); Docket No. 980866, Bell Atlantic Corporation’s proposed 34 merger with GTE Corporation (GTE); Docket No. 98-0555, SBC Communications 35 Corp. proposed merger with Ameritech Corp.; Docket No. 96-0503, the 36 investigation into GTE’s wholesale prices ; Docket No. 96-0404, Ameritech 37 Illinois’ Section 271 compliance Docket; Docket No. 96-0486, the investigation 30 into Ameritech Illinois’ unbundled network element (UNE) offering; Docket No. 39 97-0344, the Cable Companies’ complaint against Ameritech’s use of 40 “Americhecks”; Docket Nos. 97-0552 and 97-0553, the investigation of 41 Ameritech Illinois’ wholesale tariff; Docket No. 98-0860 regarding the 42 reclassification of Ameritech services as competitive; Docket 99-0593 the 2 Docket 00-0592 ICC Staff Ex. 1 .OO (Graves) Page30flo 43 investigation of Ameritech’s special construction charges; and Docket 00-0592 44 the arbitration of Ameritech’s Operation Support Systems (OSS). 45 46 Q. What new evidence has Ameritech provided in the pre-filed testimony 47 _“.actmhmi+tor’ ,111. I.. inmm. “.srnnnnc+ir\n I,,, ““.,“a, uri+h..*.a, +hic.,,,- ,“..“....r-h-2ripn .a that. ..-. rnmmla4-......” Inad.--- to- 2 chznge in 48 the Commission’s order? 49 A. Ameritech has described its new loop qualification interfaces implemented on 50 March 24, 2001, and the loop qualification enhancement made to Southwestern 51 Bell’s software as of April 3, 2001. Ameritech also indicated in their testimony 52 (Mileham, page 8, line 15) that a modification similar to that made to 53 Southwestern Bell’s loop qualification system is being considered for Illinois. 54 55 Q. Please summarize the issues the Commission addressed in the Original’ 56 OSS arbitration proceeding, Docket No. 00-0592, that related to Issues 57 29131 - DSL Loop Qualification? 58 A. The CLECs requested three modifications of Ameritech’s OSS. The CLECs 59 requested the OSS allow them to: 1) view the loop characte’ristics of all loops 60 serving an address; 2) reserve a particular loop from those serving an address 61 and order that loop during the ordering process; and 3) avoid disclosing to 62 Ameritech the service that the CLEC plans to provide for their end customer. 63 64 Q. Please summarize the Commission’s order in the Original OSS arbitration 3 . Docket 00-0592 ICC Staff Ex. 1 .OO (Graves) Page40flo 65 proceeding. 66 67 A. The Commission required that Ameritech should (i) provide information on a 68 maximum of ten (10) loops during the pre-ordering stage, (ii) implement a 69 method of identification for each of the up to ten loops returned to the CLECs 70 during the pre-ordering stage, and (iii) modify the ordering application so that the 71 CLECs can order a specific loop identified during the pre-ordering stage 72 understanding that this loop may not still be available (in other words, no 73 reservation policy was mandated). 74 75 Q. Do Ameritech’s new loop qualification systems implemented on March 24, 76 2001 comply with the Commission’s order? 77 A. No. While the “new” systems provide loop characteristics information for one 78 loop, they do not disclose characteristics for multiple loops serving a particular 79 address. In addition, the CLECs are not able to order a particular loop identified 80 in pre-qualification stage. 81 82 Q. Have other ILECs been able to address the issue of providing DSL’Loop 83 qualification information for multiple loops at an address? 84 A. As was noted in the Order for Docket No. 00-0592, Verizon, BellSouth and 85 Qwest all seem to have addressed this issue to some degree. As was noted in 86 the Order for Docket No. 00-0592 on page 88: 4 Docket 00-0592 ICC Staff Ex. 1 .OO (Graves) Page 5 of 10 87 . Bell Atlantic - allows CLECs to see details for a maximum of 10 available 88 loops. 89 . Bell South - allows up to 4 available loops to be viewed 90 l Qwest - has built a new tool for customer viewing of raw loop data. 91 92 It is my understanding that Ameritech has not taken issue with these findings. 93 94 95 Q. Has Ameritech provided any evidence why the aforementioned companies 96 could address the DSL Loop Qualification issues while Ameritech could 97 not? 98 A. No. In fact, Ameritech witness Zills explains that Loop Facility Assignment and 99 Control System (“LFACS”) used by Ameritech is not an Ameritech maintained 100 database system, rather, the software is owned by Telcordia. Telcordia is a 101 research firm that use to provide its services exclusively to the regional bell 102 operating companies, and now it provides services to the entire 103 telecommunications industry. It is probable Verizon, Bell South and Qwest have 104 the same LFACS database software that Ameritech claims can’t be modified to 105 accomplish qualification of multiple loops. In Ameritech’s testimony the only 106 assertion to support that Ameritech can’t implement the loop pre-qualification 107 and loop ordering functionality as ordered in Docket No. 00-0592 is the complaint 108 that Ameritech cannot accomplish it in the time frame ordered. 109 110 Q. Does Ameritech witness Zills’ testimony regarding BellSouth’s cost to 5 Docket 00-0592 ICC Staff Ex. 1 .OO (Graves) Page 6 of 10 111 modify LFACS (Zills at 8) imply that BellSouth’s systems are similar to 112 Ameritech Illinois’ system? 113 A. Yes. Zills implies that the two systems are similar if the costs are similar. But 114 there is no evidence to support Ameritech’s equation of the implementation costs Ii5 for the txo separate sys?ems. Before !he Comm,,sic innI”,. ..YYy.a.”3rmntc Mr1.11. ‘.-.a.”7illc’ cost 116 estimate it should require Ameritech to provide more proof of the asserted costs 117 than just a number from an unidentified source at BellSouth. Ameritech would 118 also have to establish that its costs of implementation would be similar. It 119 appears that Ameritech has done no planning in regards to implementing the 120 Commission’s order in Docket 00-0592 regarding DSL loop qualification and loop 121 characteristics. This was confirmed by Ameritech’s response to Covad’s data 122 request 21 attached hereto It is unclear how any reliable cost estimate can be 123 made without some research and planning. 124 125 Q. Has there been any other change in facts since the entry of the 126 Commission’s Order? 127 A. Yes. The Original Order in Docket No. 00-0592 quoted Covad’s testimony that 128 stated that the costs for loop conditioning would be: $905.82 for removal of a load 129 coil; $528.97 for removal of a bridge tap; and $326.86 for removal of repeaters. 130 The loop conditioning charges were reduced by the Commission’s Order in Docket 6 Docket 00-0592 ICC Staff Ex. 1 .OO (Graves) Page70flo 131 No. 00-0393; the respective rates are now, $14~.08, $14.00, and $21.49’. While 132 Ameritech has asked that these rates be reevaluated in its petition for rehearing of 133 Docket No. 00-0393. This reduction in conditioning prices substantially reduces 134 the economic impact of conditioning activities. This does not however affect the 135 time impact that conditioning could have. 136 137 Q. Does the FCC’s UNE Remand Order require loop qualification for all loops at 138 a particular address? 139 A.
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