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. Yes. An address is one method by which the FCC suggests an ILEC provide loop
140 qualification method. The FCC requires an ILEC to provide loop qualification
141 information in the same method that it provides it to itself. The paragraph 440 of
142 the UNE Remand Order in part states:
143 Consistent with our nondiscriminatory access obligations, the incumbent 144 LEC must provide loop qualification information based, for example, on 145 individual address or zip code of the end users in a particular wire center, 146 NXX code, or any other basis that the incumbent provides such information 147 to itself.
148 Paragraph 428 of the UNE Remand Order then sets forth the systems and
149 information to which an ILEC should provide a CLEC access; specifically, stating
150 that the information is not to be filtered.
’ Ameritech Tariff, ILL. C. C. No. 20, Part 19, Section 2, 2” Revised sheet No. 34.
7 Docket 00-0592 ICC Staff Ex. 1 .OO (Graves) Page8ofiO
151 428. In addition, we agree with Covad that an incumbent LEC should not 152 be permitted to deny a requesting carrier access to loop qualification 153 information for particular customers simply because the incumbent is not 154 providing xDSL or other services from a particular end office.[footnote 155 omitted] We also agree with commenters that an incumbent must provide 156 access to the underlying loop information and may not filter or digest such 157 information to provide only that information that is useful in the provision 158 of a particular type of xDSL that the incumbent chooses to offer. [footnote 159 omitted] For example, SBC provides ADSL service tomits customers which 160 has a general limitation of use for loops less than 18,000 feet. In order to 161 determine whether a particular loop is less than 18,000 feet, SBC has 162 developed a database used by its retail representatives that indicates only 163 whether the loop falls into a “green, yellow, or red” category. [footnote 164 omitted] Under our nondiscrimination requirement, an incumbent LEC can 165 not limit access to loop qualification information to such a “green, yellow, 166 or red” indicator. Instead, the incumbent LEC must provide access to the 167 underlvinq loop qualification information contained in its enqineering 168 records, plant records, and other back office systems so that requestinq 169 carriers can make their own iudqments about whether those loops are 170 suitable for the services the requestinq carriers seek to offer. Otherwise, 171 incumbent LECs would be able to discriminate against other xDSL 172 technologies in favor of their own xDSL technology. (emphasis added) 173 174 Although I am not an attorney, based on the aforementioned language,
175 Ameritech should be providing access to all underlying loop qualification
176 information so that requesting carriers can make their own decisions regarding
177 the suitability of the loops for the services they seek to offer. It should be up to
178 the wholesale customer ordering the loop to determine what loop they would like
179 provisioned.
180 181 Q. Ameritech does not believe that it is required to provide the OSS systems
182 ordered by the Commission. Do you agree with Ameritech’s position?
8 . .
Docket 00-0592 ICC Staff Ex. 1 .OO (Graves) Page90fio
183 A. No, Ameritech raised similar objections in its Reply Brief on Exceptions in the
184 Original Docket. The Commission rejected those arguments in its Order (at page
185 91) and should again reject them here.
186
487 Q. undoes If appear that .Ameritech has comp!Ied with the order in Docket ELM-
188 0592?
189 A. No. The Commission ordered that the Ameritech implement loop qualification
190 improvements to its pre-ordering and ordering systems by March 2001 and meet
191 with CLECs to “jointly determine the specific fields that will be returned in the
192 pre-order inquiry.“’ I have seen no evidence that Ameritech has made progress
193 in accomplishing or planning to accomplish either obligation. Instead, as stated
194 in Mileham’s testimony, Ameritech Illinois is presently writing requirements for
195 implementing the SWBIT DSL loop qualification enhancement implemented on
196 April 3,200l.
197 Q. Does this conclude your testimony?
198 A. Yes
199 200
’ Order, Docket 00-0592. at p. 90.
9 Docket 00-0592 Staff Ex. 1.OO (Graves) Attachment 1
Illinois Commerce Commission Docket 00-0592 Covad Data Request 21
Request:
Please provide all documents related or referring to the implementation or efforts necessary to implement the Illinois Commerce Commission’s January 24,200l order in Docket 00-0592 regarding DSL loop qualification and loop makeup information.
Response:
Ameritech Illinois objects to this request as being irrelevant to the issue on rehearing and unlikely to lead to the discovery of relevant information. Without waiving this objection, Ameritech Illinois states that no such documentation exists.