CaseNo. U-13891 Mass Market Batch Cut Proposed Process Page …

CaseNo. U-13891 AT&T Exhibit MDV-1 Page 1 of 1 Mass Market Batch Cut Proposed Process

Version 2 (10/29/03)

The Batch Process provides discounted coordinated hot cut rates for CLEC with multiple end users, multiple addresses and with multiple orders in a single wire center.

The Batch Cut Process provides CLECs the ability to handle new customer acquisitions and movement of embedded base of UNE-P.

ScoDe of Batch - Applies to Mass Market Customers with limited number of analog DSO POTs Service (plan assumption of 3 or less DSO POTs lines Der end user) like for like service: - UNE:P to UNE-Loop wlLNP - Resale to UNE-Loop wlLNP - (Does not include loop service via line splitting, line sharing, Broadband, DSI services).

SBC Retail to UNE-Loop w/LNP

Batch Process Options: a.

b.

Dail Batch - 2-50 Mass Market lines per day, per CLEC, per wire center (CHC) (Normal Due Date Intervals - M-F (8 -5) for both CHJFDT) (FDT will flow business as usual and not be structured within the Batch Cut Process) Defined Batch - 2-100 Mass Market lines per day, per CLEC, per wire center (CHC) 13 business day minimum scheduling required, can be within 24 hours, except Sundays (no porting capabilities on Sundays). Defined batch includes orders which require a specific timeframe and includes loops currently provisioned over IDLC. Bulk Project - l O l + lines Mass Market Customers - (CHC) Negotiated due dates with defined timeframe. Allows CLEC the ability to coordinate more orders within a designated time.

c.

The Batch Process will also provide a means of enhanced communication and pre-ordering tools: 'Investigating possibility of a pre-order tool to validate loops are not Served by IDLC * Order Flow through verification tool (Scheduler/PWS??- providing completion notice for minimal down time) CLEC notification

* Due Date Reservation Tool for Defined Batch (Due Date Interval Guide identifying criteria of clean orders received by required

' Defined Timeline for Batch (13 business days minimum with same criteria of clean orders received by required date to meet

is being assessed to be given for e.g.afler every 20 orders for the Defined Batch and Bulk Process Options. CLEC can complete LNP in advance to minimize down time.

date to meet date expected).

date and time expected). Defined Rate Structure for Daily, Defined and Bulk Processes.

hICHIGAN PUBLIC SERVICE COhWISSION -. / A I 3 841

L.-

1 EXHli3TN0.T-f7

CaseNo. U-13891 AT&T Exhibit MDV-2

Page 1 of4

OSS CHANGES ASSOCIATED WITH SBC’S PROPOSED HOT CUT ENHANCEMENTS

Summary and Implementation Status

New OSS offerings will enhance the existing pre-ordering, ordering and provisioning interfaces. These changes will provide CLECs more real time information during the pre-ordering and provisioning phases and will result in a more automated ordering process for hot cut requests.

The OSS changes outlined below represent the concept design at this stage in the product development cycle. The details remain to be worked out, and the design could be modified as a result of further analysis and investigation. SBC’s intent is to make these OSS enhancements available effective with its July 24,2004 release, barring unforeseen circumstances, such as conflicting regulatory rulings that could occur in each state jurisdiction.

agreed upon Change Management Process (CMP). Final Requirements are due to the CLECs on April 5,2004 (1 10 days prior to the release). A walk-through of these requirements is hosted by SBC if changes have been made since the Initial Requirements were published. Initial Requirements are shared with CLECs at least three weeks prior to the publication of the Final Requirements ( Initial Requirements will be published between February 23rd and March 15‘h.). CLECs have a 3-week comment period following the publication of the Initial Requirements. During the Initial Requirements comment period, a walk-through of requirements is hosted by SBC. Given the collaborative nature of the Batch Hot Cut proposal, SBC anticipates additional comments from CLECs resulting from the various workshops and proceedings that are being held in various states. However, due to timelines required in the software development cycle and the intent to have a new Batch Hot cut proposal available in the July 24‘h release, SBC has begun the business requirements and systems requirements process and may not be able to address all CLEC concerns regarding OSS changes to support the Batch Hot Cut process in its July 2004 release.

CLECs will receive detailed requirements via Accessible Letter according to the

A CLEC test window of 4 weeks is provided 5 weeks prior to release implementation, This test window is available on the ED1 and CORBA pre-order interfaces and the ED1 and LEX ordering interfaces.

Pre-Order OSS Changes

Within the preorder OSS environment, SBC will modify each of its exiting pre- order interfaces and implement two new functions: a transaction to validate IDLC, and as well as a reservatiodinquiry function for network cut capacity.

MICHiGAN PUBLIC SERVICE CQMMls~l0:j

SBC December 19,2003

Case No. U-13891 AT&T Exhibit MDV-2

Page 2 of 4

IDLC Validation Event

CLECs can perform a pre-order inquiry to check on the presence of IDLC. This capability will be available in both pre-order application-to-application interfaces (ED1 and CORBA) and the pre-order GUI (Verigate). The IDLC Validation event will be performed in real time to the SWITCH system, which contains an accurate indication of IDLC for the requested Telephone Number (TN). The validation event is a straightforward request in terms of input and output response. The CLEC will provide standard pre-ordering transaction input information as defined in the SBC Local Service Pre-ordering Requirements (LSPOR) document. The TN will also be required input to allow the specific search for an indication of IDLC for the input TN. After a search of the back-end SWITCH system, the response provided will be a “Y” or “ N which will indicate that the TN is served by IDLC (“Y”) or the TN is not served by IDLC (“‘N).

Inquiry/Reservation Event

CLECs will be able to perform an inquiryheservation event (optional for the Daily Batch), to reserve CO cut capacity for Frame Due Time (FDT) and Coordinated Hot Cuts (CHC) using the proposed new processes. Being able to reserve CO capacity provides the CLEC the ability to plan its work by Central Office (CO) on a confirmed basis, This new reservation process is more streamlined than the current process, in that it allows the CLEC to view CO capacity, and reserve and confirm a specific cut time without involving any manual intervention. This will be more efficient for both CLECs and SBC, in that it allows all parties to coordinate and allocate work force in advance.

There will be three basic functions to the Inquiry/Reservation Event available in the pre-order interfaces.

1. Inquiry 2. Reservation 3. SearcWEdit (ViewiModify/Cancel)

1. Inquiry Event The Inquiry Event will be performed in real time to the back office scheduler tool. CLECs will be able to view available cut schedules based on Central Office (CO) and Local Operations Center (LOC) capacities for a given Date/Time and quantity of lines requested. The CLEC will provide standard pre-ordering transaction input information as defined in the SBC Local LSPOR document. The pre- ordering response will display available cut schedules.

2. Reservation Event Based on the available cut schedule information, the CLEC will be able to reserve cut capacity for a given Date/Time and quantity of lines requested. The CLEC will provide standard pre-ordering transaction input information as defined in the

SBC December 19,2003 2


Page 3 of 4

LSPOR. The Reservation Event will also require a CO designation, the selected due date and time and the telephone numbers of the lines to be worked.

The Reservation Event response will retum a reservation number that will then be input on the LSRs by the CLEC for the specific TNs included in the pre-ordering reservation transaction.

CLEC batch requests will be prioritized based on first in, first out via the reservation process.

3. SearchlEdit (ViewlModifylCancel) The third function will provide the CLEC with the capability to view existing reservations and to modify and or cancel as necessary.

Order OSS Changes

In this step the CLEC completes an accurate LSR via either the application-to- application ordering interface (EDI) or the ordering GUI (LEX). According to the preliminary high-level design, within 24 hours of making the cut reservation, the CLEC will provide the reservation number on a valid LSR for the TNs. The CLEC would indicate DFDT (Desired Frame Due Time) or CHC as they do today and submit the LSR according to the Local Service Ordering Requirements (LSOR) for the request type and activity type desired.

SBC will design additional validations to be performed at this stage of the process by its edit engine (LASR), such as determination of mass market or enterprise, a valid reservation number, new acquisition or embedded, or presence of IDLC. These validations will take the form of new edits and error messages. SBC does not anticipate that CLECs will see any changes to the notification processes.

Modifications will be made to the order generation systems. SBC is planning for fully mechanized processing of BHC orders in all regions. With the December 13'h release, flow-through will exist for UNE-P to loop and UNE-P to Loop with Number Portability SBC West, the Midwest and the Southwest. This flow-through applies to same CLEC (embedded base projects) and CLEC-to-CLEC (Daily process for new acquisitions).

Billine

SBC does not anticipate any changes to its OSS for billing purposes. The current design allows for additional USOCs to be applied on a per line basis. These new USOCs will ensure that CLECs receive the appropriate rate for batch hot cuts.

Provisioning Website Enhancements

Provisioning enhancements will be made to SBC's Provisioning Website (PWS) PWS is a CLEC-specific web-based reporting tool that was created to help CLECs manage their LNP w/Loop FDT, TBCC (Coordinated Hot Cuts), and Local Number



Page 4 of 4

Portability (LNP) orders PWS is available through CLEC Online. SBC believes this functionality is easily accessible on the web site. Nonetheless, in response to recent requests of CLECs, SBC is evaluating whether it is feasible to consolidate the PWS status functionality within the pre-ordering interfaces.

This PWS web site provides four reports:

1. The “ Frame Due Time Orders” Report 2. The “To Be Called Cut Orders” Report (TBCC/CHC), 3. The “Past Due” Report and 4. The “All LNF”’ Order Report.

The PWS allows users to:

1. Search for orders using SBC SON, CLEC PON, Due Date Range, State or, CLLI code 2. View Status of TBCC, FDT LNP w/Loop and LNP PONS 3. Download Reports to Excel Spreadsheet. 4. Navigate the search results data using the page number hyperlink at the top of page.

A future enhancement to support the hot cut provisioning process includes the ability to view the real time results of the Dial Tone/ Automatic Number Identification (DT/ANI) testing (for both CHC and FDT orders) performed on Due Date minus two (DD-2). This will benefit CLECs in that they will have all provisioning status in one location.

The fields displayed for the DT/ANI Results Report will be as follows:

1. The Definition of the Status’ is as follows 2. Order Type (CHC or FDT) 3. Service Order Numbers 4. Results, which will be either:

o No Dial Tone- The CLEC does not have dial tone on their facilities at the time the test was performed

o Tested OK - The CLEC does have dial tone on their facilities.

The reports that are currently available on PWS will also be enhanced to be provided on a real time basis. Therefore, PWS will provide CLECs real time status through the provisioning process. Dial tone, AN1 and jeopardy information will be included within the status messaging. SBC’s enhancements will replace many manual processes and scheduler/load leveler will allow for mechanical tracking of manual processes.



Page 1 of 5

A Comparison of the Steps Involved in Migrating a Customer from an ILEC to a CLEC using UNE-P versus a Hot Cut

I. The Steps Involved in Migrating a Customer from an ILEC to a CLEC using UNE-P.

There are only a few significant steps involved in migrating a mass-market

customer from an ILEC to a CLEC using UNE-P:

After completing the sale to the customer, the CLEC accesses the ILEC’s pre- ordering OSS in order to obtain the necessary customer information, such as the correct name and address. A CLEC agent enters this information into the CLEC systems to create the CLEC customer service record and establish the CLEC bill. The agent must take special care to ensure the information used by the CLEC matches the ILEC’s records in order to avoid an order rejection by the ILEC.

The CLEC’s agent prepares the Local Service Request (“LSR”) and submits it electronically to the ILEC interface. The large majority of UNE-P migration orders can be processed by the ILEC without the need for any manual intervention by ILEC personnel. Thus, most UNE-P migration orders electronically flow-through the ILEC’s OSS, and can be provisioned on a same day or next day basis.

Upon receipt of the LSR, the ILEC electronically validates that the order is error- free, and electronically sends the CLEC a Firm Order Confirmation (“FOC”).

Upon receipt of the FOC, the CLEC updates its systems to reflect the due date of the order.

Thereafter, the remaining processes are electronic. On the due date, which is typically the same or next day, the ILEC’s OSS implement the order by making appropriate software changes that (i) transfer ownership of the account to the CLEC and establish wholesale billing to the CLEC for the customer and (ii) cause the ILEC’s internal systems to send a final retail bill to the end user.

When the CLEC receives the provisioning completion notice electronically from the ILEC, the CLEC closes out the order in its systems including such items as establishing the customer’s new billing arrangement.’

’ If the customer has requested voicemail, the CLEC must also build and test the voice mailbox, if applicable. MICHIGAN PUBLIC SERVICE COMMISSION

FILE @ l3%41 EXHIBIT NO.z&


Page 2 of 5

For UNE-P, therefore, the migration process is electronic with little opportunity

for human error. There is rarely a service interruption when a customer is migrated to a

CLEC using UNE-P. After ordering service from a competitive carrier, the entire

customer migration process is completely hidden from the end-user in a manner that

makes changing local carriers as seamless as changing long distance carriers. These

electronic processes are the rough equivalent of the Primary Inter-exchange Carrier

“PIC” process that was developed to support the competitive long distance market.

11. The Additional Steps Involved in Migrating a Customer from an ILEC to a CLEC using a Hot Cut.

When a CLEC seeks to use its own switch to serve mass market local customers

using a UNE-L architecture, the processes needed to change local carriers are more

complex, manual and costly than for UNE-P. They require physical work to transfer the

customer’s analog loop between carriers’ switches. For example, the CLEC must assign

the customer to facilities in its switch and equipment; both the CLEC and the ILEC must

conduct a series of number porting activities; and the ILEC must perform numerous

manual provisioning and testing activities in its central office and sometimes in the field.

Before the CLEC even submits an order for a hot cut, the CLEC must conduct the

following activities in addition to those required for a UNE-P migration (set forth above):

The CLEC negotiates a due date with the customer based on the standard intervals for loop migrations that are lengthier than UNE-P intervals. For business customers, a cutover time must also be negotiated to ensure the service outage does not impact the operation of the customer’s business.

The CLEC conducts an inventory of facilities and electronically assigns the customer’s loop to specific facilities in the CLEC’s switch, to equipment located in CLEC-owned collocation space and to a Connecting Facility


Page 3 of 5 Assignment (“CFA”) that will be used by the ILEC to connect the customer’s loop to the CLEC’s collocated equipment.

The CLEC accesses the ILEC’s Loop Facility Assignment Control System (“LFACS”) database to confirm that the availability of the CFA information in both companies’ databases match.

After completing these activities, the CLEC prepares and submits the LSR.

After submission of the LSR, the ILEC begins its activities, which include:

The ILEC checks its CFA database to ensure the CFA on the order matches its inventory.

The ILEC issues the number portability “trigger” order by setting switch triggers which will ensure the customer receives intra-switch calls between the period of time the CLEC ports the number to its switch until the ILEC disconnects the telephone number in its switch.

The ILEC inputs the order into its backend systems to create the internal service orders that will be needed to accomplish the migration.

Then the ILEC returns the FOC to the CLEC. Unlike with WE-P , after

receiving the FOC in a W E - L migration, the CLEC and the ILEC cannot rely on the

electronic systems to flawlessly provision the service. Instead, the following set of

activities occurs, activities that must be coordinated if the cut is to be successful for the

customer:

The CLEC confirms with the customer the specific time and date when the hot cut is scheduled to take place based on the information in the FOC.

The CLEC verifies that dial tone is being delivered from its switch to the CFA in the collocation cage.

The CLEC alerts the NPAC that reprogramming is needed to move the customer’s telephone number from the ILEC to the CLEC by sending an electronic “create” message to the Administrator. This begins the process of porting the customer’s telephone number. This “create” message prompts NPAC to send a message to the ILEC to ensure the ILEC consents. The ILEC has eighteen (1 8) hours to respond.


Page 4 of 5 After the CLEC completes these activities, the ILEC completes other

activities necessary to a hot cut that are not required for a UNE-P conversion, which

include:

0

0 .

The ILEC determines whether the facilities currently being used by the customer can be reused. For example, if the customer is on Integrated Digital Loop Carrier (“IDLC”), the facilities often cannot be reused and spare non- IDLC facilities must be identified and assigned to this customer.

The ILEC pre-wires the cross-connection frames.

The ILEC confirms the presence of dial tone from the CLEC’s switch on the cross-connects in the CLEC’s collocation space.

Upon receipt of the “create” message from NPAC, the ILEC will send a “concur” message back to WAC.

The ILEC verifies that the proper phone number is on the loop that is to be cut over.

After these activities, the ILEC contacts the CLEC to determine whether the

cut can proceed as scheduled. During this call the ILEC may also provide essential

information such as test results. Assuming nothing has gone wrong, on the day of the cut

over, the ILEC and the CLEC will perform the following activities:

The ILEC ensures it has the correct line for the cut.

The ILEC verifies dial tone on the line at the ILEC Main Distribution Frame (“MDF”).

The ILEC monitors the line and, when idle, removes the old cross connection jumper at the MDF that connected the customer’s loop to the ILEC’s switch. The ILEC then terminates the pre-wired cross connection from the CLEC’s CFA to the customer’s loop.

The ILEC provisioning center contacts the CLEC to advise that the conversion is complete.

The CLEC then conducts its own tests to ensure that all lines have been successfnlly migrated.

If testing is successful, the CLEC sends an “activate” message to NPAC advising that the customer’s number should be ported to the CLEC’s switch,

The CLEC then calls the ILEC to accept the service.


Page 5 of 5 The cut, however, is still not complete.

Upon receipt of the activate message from NPAC, the ILEC completes the disconnect order and sends an “unlock” message for the E911 database administration to allow the CLEC access to the E911 database record for the ported number.

Then the CLEC migrates the 91 1 record by updating the Automatic Location Indicator (“ALI”) database to identify the CLEC as the local service provider. This ALI information supports the Public Safety Answer Point (“PSAF’”) that receives 91 1 calls.

The ILEC must remove the old cross connections from its frame to free up the ILEC’s switch port for another customer.

Only after these last steps is the hot cut complete. Thus, in contrast to a UNE-P

migration, not only are there significantly more steps involved in a hot cut, but those

steps must be coordinated if a cut is to be successful in limiting the time the customer is

out of service.

Electronic Loop Provisioning (EL P) Enabling The Competitive, A //-Sewice Network Of The Future

c c c Background and Introduction > > >

cc c Network Architecture and Design > > >

c < < Investments and Costs > > >

ELP Overview - AT&T 2

N €3

W

W

Why The Need For ELP ? . The local network and loop access architecture was designed with one carrier and one carrier on[v in mind-the Incumbent LEC

As a result, there are inherent architectural impediments in the Incumbent LECs' local networks that effectively preclude practical and economic CLEC access to analog voice-grade loops used to provide voice services

. Unlike the ILECs, whose circuit switches are located at the same location where their end-users' loops terminate (i.e. the Local Serving Office or LSO), CLECs must create an extensive "backhaul network" to extend their end-users' loops to their circuit switches

I n order to connect their customers' loops to their switches, the ILECs merely run a jumDer wire from one side of a Main Distribution Frame ("MDF") to the other in the same K O

I n sharp contrast, CLECs face a significant "backhaul penalty" in order to connect UNE-Loops to their circuit switches

. The underlying network must change in order to accommodate practical, efficient and economical multi-carrier access to loops - ELP is one potential way

ELP O v e ~ i e ~ - AT 4

The CLEC Backhaul Penalty

. I n summary, the CLEC backhaul penalty includes the following costs :

(1) Engineering, establishing and maintaining collocation, including the associated space preparation and power requirements for sustaining collocation

(2) Installing and maintaining diclitization, concentration and multiplexing equipment at collocations, as well as related monitoring/testing and power distribution equipment

(3) Arranging for and providing tranmort between collocations and CLEC switch locations

(4) Engaging in the "coordinated hot-cut Drocess" in order to migrate loops from the ILEC's network to the CLEC's network, which starts at the CLEC collocation

Only after each of these requirements have been satisfied can a CLEC provision POTS service to end-users using an unbundled ILEC loop

This "backhaul penalty" makes it practically and economically prohibitive to service analog voice grade loops using a UNE-L facilities based entry

ELP Overview - 5

a

ILEC vs. CLEC Loop Access

I

End User

"Local LOOP"

ILEC LSO A (Switched Retail Customer)

......................................................................................

CLEC COHO #1

....................................................................................

ILEC LSO B (Location of CLEC Hub)

.....................................................................................

CLEC Collo #2

.......................................................................................

CLEC Switch Location

...................................................................

ILEC Backhaul -b CLEC Backhaul b

ELP Overview - 6

U

0 n >r,

m U n m

Z J L

a

Today's Loop Migration via "Hot-Cuts"

Source : BellSouth

ELP Overview -

ELP Is One Potential Solution . ELP addresses the underlying network architecture issues that impede competition for the so-called “mass-market” (i,e., residential and small business locations)

. ELP is a targeted infrastructure upgrade to the incumbent LECs’ local network that introduces currently available network transmission technology into the local access network that digitizes and packetizes all end-user communications traffic, both voice and data

. Digitization and Packetization of the local access network ...

. rn

... eliminates the need for manual, labor-intensive “hot-cuts”

... reduces the need for CLEC collocation and related equipment

... improves CLEC transport economies

. ELP (or a technological equivalent that provides CLECs equivalent access to end-user loops as the ILECs) in conjunction with pro-competitive policies is required in order to make it both (a) practical, and (b) economic for CLECs to serve mass market locations using UNE-L facilities based entry

. Absent such a solution, UNE-P is the only practical and economic entry stra bring local competition to mass market locations

ELP Overview - ~ o v e ~ ~ e r 2

A T& T's Proposed Solution

AT&T's ELP proposal is one way in which voice digitization and packetization in the access network can be achieved

It is premised on a 'true" NGDLC access architecture that employs ATM transmission protocol

. ELP introduces three network elements into the local access network:

. ATM modules . Voice Gateways (VGs)

'true" Next Generation Digital Loop Carrier (tNGDLC) equipment

. The introduction of these network elements transforms the local network into a digital, packet access network

. This fundamental change enables an open network architecture that will support nondiscriminatory multi-carrier access

ELP O v e ~ i e w -

m B r

I

N 0 0 w

Collocation Under ELP An A TM Module Port and Associated Transporf Facility*

ATM Module (Backplane View) CLEC Collocation can equal a DS1, 053, or OC-3 or higher port on the ATM Module w/associated transport facility

*NOTE : Collocation under ELP will vary/be dependent upon how it is architecturally implemented.

ELP O v e ~ i e w - 12

rn r fl

I

N 0 W

c” W

..

Tbree Key Elements

Three Prime Components in the ELP Architecture

"true" NGDLC (tNGDLC)

ATM module

Voice Gateway (VG)

tNGDLC. Performs the analog-to-digital conversion, voice and data "packetization" (e.g./ Voice Packet Processing or VPP), multiplexing and concentration of end-users' communications traffic

ATM Modu/e, Performs the multiplexing and concentration of end-users' communications traffic from sub-tending tNGDLC units in RTs or in the CO

VG. Performs the packet-to-circuit protocol conversion between the ATM based ELP access architecture and TDM based circuit switched architecture

ovember 2003 14

Generic ELP Network Architecture ILEC LSO

"Direct Copper Run" (e.g., Non-DLC Loop)

End User __. Copper Distribution

I "DLC Loop" I ILEC RT

End User ATM Uplink (Voice & Data)

Ex __.-__._ Copper Distribution

Copper Distribution Frame (MDF)

Fiber Feeder

Fiber Distribution Frame (FDF)

"true" NGDLC with Voice Cell Processor (VCP) TNGDLC VG Voice Gateway

n

.............................

"true" NGDLC Technology

. "True" NGDLC (tNGDLC) technolow converts current separate voice/data hardwired end-user to central office connections into software-defined connections that:

. Convert end-user analog voice signals into packet format before they are transported to the central office

. Combine these voice signals with data traffic (which current DSL technology already transports as packets)

. Transport these combined voice and data packets to the central office over all- fiber facilities

. The most convenient packet-like transport format is likely to be Asvnchronous Transfer Mode (ATMI protocol:

. ATM is the format currently used for nearly all DSL transport

ATM permits quality-controlled permanent virtual circuits (PVCs) to be established and maintained for voice traffic as well

Values of a Digitab Packet Access Network

By converting data andvoice traffic into packet format ...

All traffic rides on a converged loop network

A central office-located packet module (e.g., an ATM lodule) s e w s as an efficient interface point where all service providers can access all voice and data PVCs (“loops”) subtending this switch

An end-user‘s voice traffic may be unbundled separately from that end- user‘s data traffic Both ILECs and CLECs obtain identical access to these loops (although CLECs still face some asymmetric but reduced backhaul costs and issues)

Because the ”loop” and “network” ports on this packet module are software- controlled:

=

Loops can be assigned to different carriers instantaneously New services can be provisioned by all carriers equally Functionality analogous to 1980s FGD “equal access” with its automated PIC process for selecting long distance carriers is established for local loops and carriers

17

Preservation of Legacy Investments

. All other portions of current loop infrastructure may remain unchanged by ELP

. CPE used for voice services remains unchanged - as does CPE currently used for advanced services such as DSL or derived voice lines, etc.

. Copper distribution facilities remain unchanged (unless they need to be shortened and/or repaired or conditioned to improve service)

Fiber feeder facilities remain unchanged (copper facilities upgraded to fiber, as necessary)

Substantial portions of current ILEC NGDLC investment (and investment in legacv DLC systems) mav be reusable

Sites, cabinets, power systems

Channel banks, common cards and channel cards (depending on vendor of legacy equipment)

. ATM Modules (e.g., OCDs under Pronto, PARTS, etc.)

ELP Overview - i a

MPSC CaseNo. U-13981 Exhibit SL/MS-I

Page 1 of 15

MICHAEL STARKEY PROFESSIONAL INFORMATION

CONTACT INFORMATION:

QSI Consulting, Inc. 703 Cardinal Street Jefferson City, Missouri 65101

phone: 573.638.2681 fax: 573.638.2683

e-mail: [email protected]

CURRENT POSITION:

President and Founding Partner, QSI Consulting,

PROFESSIONAL EXPERIENCE:

Competitive Strategies Group, Ltd. Founding Partner Senior Vice President and Managing Director Telecommunications Sewices

Maryland Public Service Commission Telecommunications D ivision Director

Illinois Commerce Commission Office of Policy and Planning Senior Telecommunications Po/icy Analyst

Missouri Public Service Commission Utility Operations Division Telecommunications Department Economist

EDUCATION:

B.S. Economics I International Marketing - Southwest Missouri State University, Springfield, Missouri - Cum Laude Honor Graduate

Graduate Coursework, Finance - Southwest Missouri State University, Springfield, Missouri - Lincoln University, Jefferson City, Missouri

Page 1 .

MPSCCase No. U-13891 Exhibit SLIMS-1

Page 2 of I S


. Facilitator. C? Coalition (Competitive Carrier Coalition - Ameritech Region). Facilitate industry organization representing 10-15 competitive carriers seeking to share information and "best practices" with respect to obtaining effective interconnection, UNEs and resold services from SBC/Ameritech.

Former member of the Missouri Public Service Commission's Task Force on FCC Docket Nos. 91-141 and 91-213 regarding expanded interconnection, collocation, and access transport restructure

.

. Former member of the AT&T / Missouri Commission Staff, Total Quality Management Forum responsible for improving and streamlining the regulatory process for competitive carriers

Former member of the Missouri, Oklahoma, Kansas, Texas, and Arkansas five state

Former delegate to the Illinois, Michigan, Indiana, Ohio, and Wisconsin Ameritech

. Southwestern Bell Open Network Architecture (ONA) Oversight Conference

. Regional Regulatory Conference (ARRC) charged with the responsibility of analyzing Ameritech's "Customers First" local exchange competitive framework for formulation of recommendations to the FCC and the US. Department of Justice

. Former member of both the Illinois and Maryland Local Number Portability Industry Consortiums responsible for developing and implementing a permanent database number portability solution

Before the Public Utility Commission of Ohio Case No. 96-1310-TP-COI In the Matter of the Commission's Investigation into the Implementation of Section 276 of the Telecommunications Act of 1996 Regarding Pay TeleDhone Sewices On behalf of the Payphone Association of Ohio

Before the Wisconsin Public Service Commission Docket No. 6720-TI-177 lnvestigafion Into Ameritech Wisconsin's Loop Conditioning Services and Practices On behalf of WorldCom, Inc.. AT&T Communications of Wisconsin, L.P. and TCG Milwaukee, McLeodUSA Telecommunications Services, Inc.. TDS Metrocom. LLC

Before the Michigan Public Service Commission Case No. U-11756 - REMAND Complaint Pursuant to Sections 203 and 318 of the Michigan Telecommunications Act to Compel Respondents lo Comply with Section 276 of the Federal Telecommunications Act On behalf of the Michigan Pay Telephone Association

Page 2.

MPSC Case No. U-13891 Exhibit SL/MS-l

Page 3 of 15


Before the New York Public Service Commission Case No. 00-C-0127 Proceeding on the Motion of ihe commission to Examine Issues Concerning Provision of Digital Subscriber Line Services On behalf of MCI Worldcom Network Services, Inc.

Before the Indiana Utility Regulatory Commission Cause No. 42236 Complaint of Time Warner Jelecom Against Ameritech Indiana Regarding Its Unlawful Market Practice of Issuing Equipment Vouchers in Violation of the Indiana Code and Opportunity Indiana I1 and Petition for Emergency Suspension of any and all Ameritech Indiana Equipment Voucher Marketing Practices Pending Commission Investigation On behalf of Time Warner Telecom of Indiana. LP

Before the Pennsylvania Public Utility Commission Docket No. P-00930715FOOO2 Re: Verizon Pennsylvania Inc., Petition and Plan for Alternative Form of Regulation Under Chapter 30, 2000 Biennial Update to Network Modernization Plan On behalf of MCI Worldcom Network Services, Inc.

Before the Illinois Commerce Commission Docket No. 07-0609 investigation of the propriety of the rates, terms, and conditions related to the provision of the Basic COPTS Pod and the COPTS-Coin Line Poii On behalf of Payphone Services, Inc., DataNet Systems, LLC. Illinois Public Telecommunications Association

Before the Indiana Utility Regulatory Commission Cause No.40611-S1 (Phase II) In the Matter of: The Commission Investigation and Generic Proceeding on Ameritech Indiana's Rates for Interconnection Service, Unbundled Elements, and Transport and Termination under the Telecommunications Act of 1996 and Related Indiana Statutes On behalf of AT&T, Worldcom, Inc., and McLeodUSA Telecommunications Services, Inc.

Before the State of North Carolina Utility Commission Docket No. P-7, Sub 980, P-10, Sub 622 Enforcement of Interconnection Agreement Between KMC Teiecom 111, Inc. and KMC Telecom V, Inc., against Carolina Telephone and Telegraph Company and Central Telephone Company On behalf of KMC Telecom. inc.

Before the Illinois Commerce Commission Docket Nos. 98-0252,98-0335,98-0764 (Reopening) SBCIAmeritech Merger, Reopening to Discuss Settlement Agreement Regarding Merger Savings On behalf of AT&T, Worldcom, Inc., and McLeodUSA Telecommunications Sewices, Inc.

Before the Public Utility Commission of Ohio Docket No. 01-1319-TP-ARB In the Matter of MClmetro Access Transmission Services, LLC Petition for Arbitration Pursuant to Section 252(b) of the Telecommunications Act of 1996 to Establish an Interconnection Agreement with Ameritech Ohio On behalf of MCIWorldcom. Inc.

Page 3 .

MPSC Case No. U-13891 Exhibit SLIMS-1

Page4of 15


Before the Illinois Commerce Commission Docket No. 00-0393 (Rehearing) Illinois Bell Telephone Company, dlbla Ameritech Illinois Proposed Implementation of High Frequency Portion of the Loop (HFPL)lLine Sharing Service On behalf of AT8T Communications of Illinois, inc. and Worldcom. Inc.

Before the Wisconsin Public Service Commission Case No. 6720-TI-167 Complaint Against Ameritech Wisconsin Filed by Wisconsin Builders Association, Inc. On behalf of Wisconsin Builders Association. Inc.

Before the Public Service Commission of South Carolina Docket No. 2001-65-C In the Matter of Generic Proceeding to Establish Prices For BellSouth's Interconnection Services, Unbundled Network Elements and Other Related Elements and Services On behalf of NuVox Communications, Broadslate Networks, KMC Telecom, New South Communications, 1TC"Deltacom Communications

Before the Louisiana Public Service Commission Docket No. 27821 in lhe Matler of Generic Proceeding to Establish Interim and Permanent Prices for Docket No. 27821 xDSL Loops andior Related Elements and Services On behalf of Covad Communications

Before the Public Utility Commission of Ohio Case No. 00-942-TP-COI In the Matter of the Further Investigation into Ameritech Ohio's Entry into In-Region lnterlata Service Under Section 271 of the Telecommunications Act of 1996 On behalf of ATBT. WorldCom and XO Communications

Before the Washington Utilities and Transportation Commission Docket No. UT 003013, Part B In the Matter of the Continued Costing and Pricing of Unbundled Network Elements, Transport and Termination On behalf of Focal Communications, XO Washington, Inc.

Before the Illinois Commerce Commission Docket No. 98-0195 Investigation into certain payphone /sues as directed in Docket No. 97-0225 On behalf of the Illinois Pay Telephone Association

Before the Alabama Public Service Commission Docket No. 27821 Generic Proceeding to Establish Interim and Permanent Prices for xDSL Loops andlor Related ElelementS and Services On behalf of The Data Coalition (Covad Communications and Broadslate Networks of Alabama. InC.1

Before the Wisconsin Public Service Commission Docket No. 6720-TI-160 Docket No. 6720-TI-161 Investigation Into Ameritech Wisconsin's Unbundled Network Eiements On behalf of AT8T, Worldcom, McLeodUSA, TDS Metrocom, KMC Telecom, Time Warner Telecom, Rhythms Links,

Page 4 .

MPSCCaseNo. U-13891 Exhibit SLIMS-1

Page 5 of 15


Before the Tennessee Regulatory Authority Docket No. 00-00544 Generic Docket to Establish UNE Prices for Line Sharing per FCC 99-355, and Riser Cable end Terminating Wire as Ordered in Authority Docket No. 98-00123 On behalf of Covad Communications, inc., Mpower Communications and Broadslate Networks of Tennessee, Inc.

Before the Public Utilities Commission of the State of Hawaii Docket No. 7702, Phase 111 Instituting a Proceeding on Communications, including an Investigation of the Communications Infrastructure of the State of Hawaii On behalf of GST Telecom Hawaii, Inc.

Before the North Carolina Utilities Commission Docket P100 Sub 133d, Phase Ii General Proceeding to Determine Permanent Pricing for Unbundled Network elements On behalf of a consortium of 13 new entrant carriers

Before the Federal Communications Commission CCBICPD No. 00-1 In tne Marter of Wisconsu? Public Service Conimtss,on Order Directing Fhngs On ocna f of tne Wiscons'n Pay Telephone Associal on

Before the North Carolina Utilities Commission Dockel PlOO SJD 1336, Pnase I General Proceeding to Determine Permanent Pricing for UnDunuled Netu ork elements On oenalf of a consortidm of 13 new entrant carners

Before the State of New York Public Service Commission Case ho. 98.C-1357 Proceeuang on Moton ofthe Cornmisson ro Examine New York Telephone Company's Rates for Unbunuleu NelNork Nements On oena f of the C-EC Coal:t'on

Before the Public Utilities Commission of the State of California Rulemaking 0-02-05 Order Instituting Rulemaking on the Commission's Own Motion into reciprocal compensation for telephone traffic transmitted to Internet Service Providers modems On behalf of ICG Telecom Group, inc.

Before the Public Utilities Commission of the State of Colorado Docket No. 008-103J In the Matter of Petition by ICG Jelecom Group, Inc. for Arbitration of an Interconnection Agreement with US West Communications, Inc. Pursuant to Section 252(bj of the Telecommunications Act of 1996. On behalf of ICG Telecom Group, Inc.

Before the Delaware Public Sewice Commission PSC Docket No. 00-205 For Arbitration Pursuant to Section 252(bj of the Telecommunications Act of 1996 to Establish an Interconnection Agreement with Bell Atiantic - Delaware, Inc. On behalf of Focal Communications Corporation of Pennsylvania

Before the Georgia Public Service Commission

Page 5 *

MPSC CaseNo. U-13891 Exhibit SL/MS-I

Page 6 of 15


Case No. 116414 Petition of Biuester Networks. Inc. for Arbitration with BeilSouthDocket No. 11641-U Telecommunications. Inc. pursuant to Section 252(b) of the Telecommunications Act of 1996 On behalf of Bluestar Networks, Inc.

Before the New Jersey Board of Public Utilities Docket No. TO00030163 For Arbitration Pursuant to Section 252(bJ of the Telecommunications Act of 1996 to Establish an Interconnection Agreement with Bell Atlantic-New Jersey, Inc. On behalf of Focal Communications Corporation

Before the Pennsylvania Public Utility Commission Docket No. A-310630F.0002 For Arbitration Pursuant to Section 252(bJ of the Telecommunications Act of 1996 to Establish an Interconnection Agreement with Bell Atlantic-Pennsylvania On behalf of Focal Communications Corporation

Before the Michigan Public Service Commission Case No. U-12287 In the matter of the application, or in the alternative, complaint of AT&T COMMUNlCATiONS OF MICHIGAN, INC. against Michigan Bell Telephone Company, DIBiA, Ameritech Michigan On behalf of AT&T Communications of Michigan, Inc.

Before the Missouri Public Service Commission Case No. 99-483 An investigation for the Purpose of Clarifying and Determining Certain aspects Surrounding the Provisioning Of Metropolitan Calling Area Services After the Passage and implementation Of the Telecommunications Act of 1996 On behalf of McLeodUSA Telecommunications Services, Inc.

Before the Illinois Commerce Commission Docket No. 98-0396 Investigation into the compliance of Illinois Bell Telephone Company with the order in Docket 96-048610569 Consolidated regarding the filing of tariffs and the accompanying cost studies for interconnection, unbundled network elements and local transport and termination and regarding end to end bundling issues. On behalf of AT&T Communications of Illinois, Inc. and McLeodUSA Telecommunications Selvices, Inc.

Before the Illinois Commerce Commission Docket No. 99-0593 investigation of Construction Charges On behalf of McLeodUSA Telecommunications Services, Inc., MCI WorldCom, Inc. and Allegiance Telecom, Inc.

Before the Public Service Commission of Wisconsin Case No. 05-TI-283 Investigation of the Compensation Arrangements for the Exchange of Traffic Directed to Internet Service Providers On behalf of AT&T Communications of Wisconsin, AT&T Local Services, KMC Telewm, Inc., MCI WorldCom. Inc., McLeodUSA Telecommunications Services, Inc., TDS MetroComm. Time Warner Telecom

Before the Public Utility Commission of Texas Docket No. 21982 Proceeding to Examine Reciprocal Compensation Pursuant to Section 252 of the Federal Telecommunications Act of 1996 On behalf of ICG Communications, Inc.

Page 6.

MPSC Case No. U-13891 Exhibit SL/MS-I

Page 7 of 15


Before the Public Service Commission of the Commonwealth of Kentucky Case No. 99-498 Petition of BlueStar Networks, Inc. for Arbitration with BellSouth Telecommunications, Inc. Pursuant to Section 252 of the Telecommunications Act of 1996. On behalf of BlueStar Networks. Inc.

Before the Illinois Commerce Commission Docket No. 00-0027 Petition for Arbitration Pursuant to Section 252(bJ of the Telecommunications Act of 1996 to Establish an Interconnection Agreement with Illinois Bell Telephone Company dlbla Ameritech Illinois. On behalf of Focal Communications Corporation of Illinois

Before The Indiana Utility Regulatory Commission Cause No. 41 570 In the Matter of the Complaint of McLeodUSA Telecommunications Services, Inc. against Indiana Bell Telephone Company, Incorporated, dlbla Ameritech Indiana, Pursuant to the Provisions of I.C. $5 8-1-2-54, 81-12-68, 8-1-2-103 and 8-1-2-104 Concerning the Imposition of Special Construction Charges. On behalf of McLeodUSA Telecommunications Services, Inc.

Before the Florida Public Service Commission Docket No. 991838-TP Petition for Arbitration of BlueSfar Networks. Inc. with BellSouth Telecommunications. Inc. Pursuant to the Telecommunications Act of 1996 On behalf of BlueStar Networks, Inc.

Before the Public Utility Commission of Ohio Case No. 99-1153-TP-ARB In the Matter of ICG Telecom Group, Inc.'s Petition For Arbitration of Interconnection Rates, Terms and Conditions and Related Arrangements with Ameritech Ohio On behalf of ICG Telecom Group, Inc.

Before the Public Utility Commission of Oregon ARR l5d . .. ._ . - . Petition for Arbitration of GST Telecom Oregon, Inc. Against US West Communications, Inc. Under 47 U.S.C. $252(bJ On behalf of GST Telecom Oregon, inc.

Before the Michigan Public Service Commission Docket No. U-12072 In the matter of the application and complaint of WORLDCOM TECHNOLOGIES INC. (flkla MFS INTELENET OF MICHIGAN, INC., an MCI WORLDCOM company) against MICHIGAN BELL TELEPHONE COMPANY dlbla AMERITEHC MICHIGAN, AMERITECH SERVICES, INC., AMERIJECH INFORMATION INDUSTRY SERVICES, AND AMERIJECH LONG DIS JANCT INDUS TRY SERVICES relating to unbundled interoffice transport. On behalf of WorldCom Technologies. Inc.

Before the Illinois Commerce Commission Docket No. 99-0525 Ovation Communications, Inc. dlbla McLeodUSA, Complaint Against Illinois Bell Telephone Company dlbla Ameritech Illinois, Under Sections 13-514 and 13-515 of the Public Utilities Act Concerning the Imposition of Special Construction Charges and Seeking Emergency Relief Pursuant to Section 13-515(eJ On behalf of McLeodUSA

Page 7.

MPSC Case No. U-13891 Exhibit SL/MS-I

Page 8 of IS


Before the Public Service Commission of the Commonwealth of Kentucky Case No. 99-218 Petition of ICG Telecom Group, Inc. for Arbitration with BellSouth Telecommunications, Inc. Pursuant to Section 252 of the Telecommunications Act of 1996. On behalf of iCG Teiecom Group, Inc.

Before the Tennessee Regulatory Authority Docket No. 1999-259-C Petition for Arbitration of I TC”De1taCom Communications, Inc. with BeiiSouth Telecommunications, Inc Pursuant to the Telecommunications Act of 1996 On behalf of iCG Communications, Inc.

Before the New Mexico Public Regulation Commission Case No. 3131 in the Matter of GST Teiecom New Mexico, inc.’s Petition for Arbitration Against US West Communications, Inc., Under 47 U.S.C. $252(b). On behalf of GST Telecom New Mexico, Inc.

Before the Georgia Public Service Commission Docket No. 10767-U Petition of ICG Teiecom Group, inc. for Arbitration with BellSouth Telecommunications, Inc. Pursuant to Section 252 of the Teiecommunicaiions Act of 1996. On behalf of ICG Telecom Group, Inc.

Before the Public Service Commission of New York Case No. 99-C-0529 Proceeding on Motion of the Commission to Re-examine Reciprocal compensation On behalf of Focal Communications, Inc.

Before the Florida Public Service Commission Docket No. 990691-TP Petition by ICG Teiecom Group, inc. for Arbitration of an Interconnection Agreement with BellSouth Telecommunications, Inc. Pursuant to Section 252(b) of the Telecommunications Act of 1996 On behalf of ICG Telecom Group, Inc.

Before the Louisiana Public Service Commission Docket No. U-24206 Petition for Arbitration of 1TC”DeitaCom Communications, Inc. with BeilSouth Telecommunications, Inc. Pursuant to the Telecommunications Act of 1996 On behalf of 1TC”DeitaCom. Inc.

Before the South Carolina Public Service Commission Docket No. 199-259-C Petition for Arbitration of ITCTJeltaCom Communications. Inc. with BellSouth Telecommunications, Inc. Pursuant to the Telecommunications Act of 1996 On behail of ITC”Del1aCom. inc

Before the Alabama Public Service Commission Docket No. 27069 Petition by ICG Telecom Group, Inc. for Arbitration of an Interconnection Agreement with BellSouth Telecommunications, Inc. Pursuant to Section 252(b) of the Telecommunications Act of 1996 On behalf of ICG Telecom Group, Inc.

Before the State of North Carolina Utilities Commission

Page 8 .

MPSCCaseNo. U-13891 Exhibit SLIMS-I

Page 9 of 15


Docket No. P-582. Sub 6 Petition by ICG Telecom Group, Inc. for Arbitration of Interconnection Agreement with BellSouth Telecommunications, Inc. Pursuant to Section 252(b) of the Telecommunications Act of 1996 On behalf of ICG Telecom Group, Inc.

Before the Missouri Public Service Commission Case NO. TO-99-370 Petition of BroadsDan Communications, Inc. for Arbitration of Unresolved Interconnection Issues Regarding ADSL wilh Soulhiesrern Bell Telephonc Companj On benalf of Broadspan Comrnunical'ons. Inc

Before the Michigan Public Service Commission Case ho. d-11831 Iii lne Matler of me Commm!on's onn molion, 10 COOS!del rlle lolal servce long run !ncreinenlal costs for all access, roll, and local excliange sen ces provided ~y Ainerdech Mich.pan. On oehalf of MC Wor oCom. Inc

Before the Illinois Commerce Commission Domet hos. 38-0770.98-0771 cons Proposed Modificaf oils lo Terms and Cono8t.ons Governing rhe Prowrsm of Special Consrructm Arrangemenrs ano InJest8garton inlo Tariff Godemiiig the Prod;sion of Special Construcfions Arrangements On Oeha f of ATBT Cornrnm cations of lll.no s . Inc

Before the Michigan Public Service Commission Case ho ,-I1735 In lhe malrer of me complain1 oI BRE ConimJnicst8ons L L.C.. dmla PHONE MICHIGAN, agahsr tdichigan Bell Telephone Company, albia AMERITECH MICHIGAN, for wiolarions of Ihe Michigan Telecommunicat80ns Ac1 On Oeha f of BRE Cot1im.n cations. L.L C

Before the Indiana Utility Regulatory Commission Cause ho. 40830 In the Malrer of lhe request 01 Ihe Indiana Payphone Assocetion for rhe Commiss!on lo Conducl an ln/esrigalion of Local Exchange Compani Pay Telephone lariffs for Compliance aith Federal Regulalions. and to Holo Sucn Tariffs 111 Abeyance Pending Coniplelion of Such Proceeding On beha f of me #ndiana Paypnone Assoc(a1.on

Before the Michigan Public Service Commission Case No. U-11756 Complaint Pursuant lo Sections 203 and 318 of the Michigan Telecommunications Act to Compel Respondenls to Comply with Section 276 of the Federal Telecommunications Act On behalf of the Michigan Pay Telephone Association

Before the Missouri Public Service Commission Case NO. TO-98-278 In the Matler of the Petition of Birch Telecom of Missouri, Inc., for Arbitration of the Rates, Terms, Conditions, and Related Arrangements for Interconnection wilh Southwestern Bell Telephone COmpany On behalf of Birch Telecom of Missouri, Inc.

Before the Public Service Commission of the Commonwealth of Kentucky Administrative Case No. 361 Deregulation of Local Exchange Companies' Payphone Services On behalf of the Kentucky Payphone Association

Page 9.

MPSCCase No. U-13891 Exhibit SLIMS-I

Page 10 of I5


Before the Public Utilities Commission of Ohio Case No. 96-899-TP-ALT The Application of Cincinnati Bell Telephone Company for Approval of a Retail Pricing Plan Which May Result in Future Rate Increases On behalf of the MCI Telecommunications Corporation

Before the Public Utilities Commission of the State of Hawaii Docket No. 7702 Instituting a Proceeding on Communications, Including an Investigation of the Communications Infrastructure of the State of Hawaii On behalf of GST Telecom Hawaii, Inc.

Before the Michigan Public Service Commission Case No. U-11410 In the Matter of the Petition of the Michigan Pay Telephone Association to initiate an investigation to determine whether Michigan Bell Telephone Company dlbla Ameritech Michigan and GTE North Incorporated are in compliance with the Michigan Telecommunications Act and Section 276 of The Communications Act of 1934, as amended On behalf of the Michigan Pay Telephone Association

Before the Indiana Utility Regulatory Commission Cause No. 40849 In the matter of Petition of Indiana Bell Telephone Company, Incorporated dlbla Ameritech Indiana for the Commission to Decline to Exercise in Whole or in Part its Jurisdiction Over, and to Utilize Alternative Regulatofy Procedures For, Ameritech Indiana's Provision of Retail and Carrier Access Services Pursuant to I.C. 8-1-2.6 Et Seq. On behalf of AT&T Communications of Indiana, Inc.

Before the Federal Communication Commission C.C. Docket NO. 97-137 In the Matter of Application by Ameritech Michigan for Authorization under Section 271 of the Communications Act to Provide In-Region, InterLATA Service in the State of Michigan. On behalf of the AT&T Corporation

Before the Indiana Utility Regulatory Commission Cause No. 4061 1 In the Matter of the Commission Investigation and Generic Proceeding on Ameritech Indiana's Rates for Interconnection, Service, Unbundled Elements and Transport and Termination under the Telecommunications Act of 1996 and Related Indiana Statutes On behalf of the MCi Telecommunications Corporation

Before the Public Utility Commission of Ohio Case No. 97-152-TP-ARB In the matter of the petition of MCI Telecommunications Corporation for arbitration pursuant to section 252(b) of the Telecommunications Act of 1996 to establish an interconnection agreement with Cincinnati Bell Telephone Company On behalf of the MCI Telecommunications Corporation

Before the Michigan Public Service Commission Case No. U-11280 In the matter, on the Commission's own motion to consider the total service long run Incremental costs and to determine the prices of unbundled network elements, interconnection services, and basic local exchange services for AMERITECH MICHIGAN On behalf of the MCI Telecommunications Corporation

Page 1 0 .

MPSC Case No. U-13891 Exhibit SUMS-1

Page 11 of I5


Before the Illinois Commerce Commission Docket No. 96-0486 Investigation into fonvard looking cost studies and rates of Ameritech Illinois for interconnection, nehvork elements, transpod and termination of traffic On behalf of the MCI Telecommunications Corporation

Before the Public Utilitv Commission of Ohio Case No. 96-922-TP-UNk In the Matter of the Review of Ameritech Ohio's Economic Costs for Interconnection. Unbundled Network Eiemenls. and Reciprocal Conpensalion for Transpon and Ternimalson of Local Telecommunications JraH.c 011 bena f of lhe MC TelecommJnical ons Corpora1:on

Before the New Jersey Board of Public Utilities Docdet ho TX95120631 In lhe Matter 01 /he Inuesligalion Regardmg Local Exchange Competrrion for Telecommunica1,ons Scrvices On oena.1 of Ihc MCI Te.ecommLn'cat8ons Corporal on

Before the Michigan Public Service Commission Case ho. J-11104 In the mailer, on the Comm6soii's Own Moiion, 10 Currsraer Amer;lCch Michigaiik Compliance With the Conipctrrr.e Checkiisi in Sechon 277 of lhe Te~econanun.cslions ACI of 7996 On uma f of AT&T Comm,ntcations of nd.ana, Inc

Before the Public Utility Commission of Ohio Casc hos. 96.702-TP-CO.. 96-922-TP-UNC, 96.973-TP-ATA, 96-974-TP.ATA, Case No. 96-1057-TP-,NC In /he Matter of fne Invesbgabon tnfo Amerilech Ohio's Entry Inlo In-Reggon InterLATA Services Under Seclion 271 of the Telecommunical~ons Aclo l 1996. On Denalf of AT8T CommLnicai ons of Ohio. Inc.

Before the Illinois Commerce Commission Docket No. 96-0404 investioation Concernino lilinois Bell Teleohone Comoanvk Comaliance With Section 271kJ of the

. I

Telec~mmunications Acj of 1996 On behalf ofAT&T Communications of Illinois. Inc.

Before the Commonwealth of Massachusetts Department of Public Utilities inlheMatterot D.P.U. 96-73/74, D.P.U. 96-75, D.P.U. 96-80181, D.P.U. 96-83,D.P.U. 96-94, NYNEX- Arbitrations On behalf of the MCI Telecommunications Corporation

Before the Pennsylvania Public Utility Commission Docket No. A-31023670002 In the Matter of the Application of MCI Metro Access Transmission Services, lnc. Fora Certificate of Public Convenience and Necessity to Provide and Resell Local Exchange Telecommunications Services in Pennsylvania On behalf of MClmelro Access and Transmission Services. Inc.

Before the New Jersev Board of Public Utilities Docket No. T0960806il In the Matter of MCI Telecommunications Corooration for Arbitration with Bell Atlantic-New Jersev, Inc. Pursuant to Section 252 of fhe Telecommunicarions Act of 1996 On behalf of me MCI Te ecommJnica1;ons Corporation

Before the Indiana Utility Regulatory Commission Cause No. 40571-iNT-01

Page 11 *

MPSCCaseNo. U-13891 Exhibit SLIMS-I

Page 12 of I5


Petition for Arbitration of Interconnection Rates, Terms and Conditions, and Related Arrangements with Wisconsin Bell Telephone Company dlbla Ameritech Wisconsin On behalf of AT&T Communications of Wisconsin, InC.

Before the Public Utility Commission of Ohio Case No. 96-752-TP-ARB Petition for Arbitration of Interconnection Rates. Terms and Conditions, and Related Arrangements with Ohio Bell Telephone Company dlbla Ameritech Ohio On behalf of AT&T Communications of Ohio, inc.

Before the illinois Commerce Commission Docket No. 96-AB-003 Docket No. 96-AB-004 Consol. Petition for Arbitration of Interconnection Rates, Terms and Conditions, and Related Arrangements with Illinois Bell Telephone Company dlbla Ameritech Illinois On behalf of AT&T Communications of Illinois, Inc.

Before the Michigan Public Service Commission Case No. U-I 1151 Petition for Arbitrafion of Interconnection Rates, Terms and Conditions, and Related Arranaements wifh tA.cn8gair Bell Telepnone Company d. bla Amerdecn Micnigan On oena f of AT8T CommJn cat ons of M.cn’gan nc

Before the Indiana Ut i l i t y Regulatory Commission C a s e ho 40571-INT-01 l r i rne Matter of the Peririon ofAT8T Conmmicar!ons of Indnana. lnc. Requeslmg Arbilrabon of Cerfam Terms and Conddions and Prices lor Inrerconiiccrron ano Refaled Arrangemenfs from lndrana Bell Telephone Cornpan/, Incorporatea dlbla Amerifcch Indiana Pursuanf 10 Section 252 (bj Of fne Conimunical.ons Acr of 1934, as Amended by rhe Telecommunicatrons Acf of 1996. On beha f of AT&T Conimdwatqons of Ind.ana, Inc.

Before the Missouri Public Service Commission Case No. TT-96-268 Applicat!on of Sourlruesrern Be!, Telephone Company, Ioc. to Revise P.S.C. Mo:No. 26, Long Disfance Message Telecommunrcations Service TanH lo lnfroduce rhe Designated Number Opfionol Calling Plan On oena f of me MCI Te.ecomm,n cations Corporation

Before :he Corporation Commission of the State of Oklahoma CaLse No. PJD 950000411 Application of Southueslern Bell Telephone Company for an Order Approving Proposed Revisions in Applcant’s Long Disfance Message Telecommunications Service Taflff Soufhwesfern Bell Telephone Company’s lnlroducfion of I + Saver Directm On oehalf of the MCI Te ecommunica1:ons Corporat.on

Before the Georgia Public Service Commission Docdet No. 6415.U and 6537.~. cons. Petdion of MClmetro to Establish Nondiscriminalory Rates. Terms and Condrrions for lhe Unbundling and Resale of Local Loops On behalf of MClmetro Access Transmisson Services

Before the Public Service Commission of the State of Mississippi Docket No 95-UA-358 Rcgardmy a Docker to Consrocr Compctition in lhc Provision of Local Tclcphone Service On oehalf of me M SSISSIPPI Caole Te.ev sion Assoc:a:ion

Page 1 2 .

MPSC Case No. U-13891 Exhibit SLIMS-I

Page 13 of I5


Before the Maryland Public Service Commission Docket No. 8705 In the Matter of the Inquiry Into the Merits of Alternative Plans for New Telephone Area Codes in Marytand On behalf of the Staff of the Maryland Public Service Commission

Before the Maryland Public Service Commission Docket No. 8584, Phase II In the Matter of the Application of MFS lntelenet of Maryland, Inc. for Authority to Provide and Resell Local Exchange and Inter-Exchange Telephone Service; and Requesting the Establishment of Policies and Requirements for the Interconnection of Competing Local Exchange Networks

In fhe Matter of the Investigation of the Commission on its Own Motion Into Policies Regarding Competitive Local Exchange Telephone Service On behalf of the Staff of the Maryland Public Service Commission

Before the Illinois Commerce Commission Docket No. 94-0400 Application of MClmetro Access and Transmission Services, Inc. For a Cerlificafe of Exchange Service Authority Allowing it to Provide Facilities-Eased Local Service in the Chicago LATA On behalf of the Office of Policy and Planning, Illinois Commerce Commission

Before the Illinois Commerce Commission Docket No. 94-0315 Petition of Ameritech-Illinois for 708 NPA Relief bv Establishino 630 Area Code On~behalf of the Office of Policy and Planning, illi;lois Commerce Commission

Before the Illinois Commerce Commission Docket No. 94-0422 Complaints of MFS, TC Syslems, and MCI against Ameritech-Illinois Regarding Failure to Interconnect On behalf of the Office of Policy and Planning, illinois Commerce Commission

Before the Illinois Commerce Commission Docket Nos. 94-0096,94-0117, and 94-301 Proposed Introduction of a Trial of Ameritech's Customers First Plan in Illinois, et al. On behalf of the Office of Policy and Planning, illinois Commerce Commission

Before the Illinois Commerce Commission Docket No. 94-0049 Rulemaking on Line-Side and Reciprocal Interconnection On behalf of the Office of Policy and Planning, Illinois Commerce Commission

Before the Illinois Commerce Commission Docket No. 93-0409 MFS-lntelenet of Illinois, Inc. Application for an Amendment to its Certificate of Service Authorlty to Permit It to Operate as a Competitive Local Exchange Carrier of Business Services in Those Portions of MSA-1 Served by Illinois Bell Telephone and Central Telephone Company of lllinois On behalf of the Office of Policy and Planning. Illinois Commerce Commission

Before the Illinois Commerce Cornmission Docket No. 94-0042, 94-0043, 94-0045, and 94-0046 Illinois Commerce Cornmission on its own motion. Investigation Regarding the Access Transport Rate Elements for Illinois Consolidated Telephone Company (ICTC), Amentech-Illinois, GTE Notth, GTE South, and Central Telephone Company (Centel) On behalf of the Office of Policy and Planning. Illinois Commerce Commission

Page 13.

MPSCCase No. U-13891 Exhibit SLIMS-I

Page 14 of 15


Before the Illinois Commerce Commission Docket No. 93-0301 and 94-0041 GTE Noiih incorporated. Proposed Filing to Restructure and Consolidate the Local Exchange. Toll, and Access Tariffs with the Former Contel of Illinois, Inc. On behalf of the Office of Policy and Planning, Illinois Commerce Commission

Before the Public Service Commission of the State of Missouri Case No. TC-93-224 and TO-93-192 In the Matter of Proposals to Establish an Alternate Regulation Plan for Southwestern Bell Telephone Company On behalf of the Telecommunications Department, Missouri Public Service Commission

Before the Public Service Commission of the State of Missouri Case No. TO-93-1 16 In the Matter of Southwestern Bell Telephone Company’s Application for Classification of Caiiain Services as Transitionally Competitive On behalf of the Telecommunications Department, Missouri Public Service Commission

Litigating Telecommunications Cost Cases TELRIC Principles and Other Sources of Enlightenment Two Day Teaching Seminar for Commissions and their Staffs (Western States) Denver, Colorado, February 586. 2002

Interconnect Pricing Critique of FCC Working Paper Nos. 33 & 34 NARUC Winter Meeting 2001 Washington, D.C., February 25,2001

Telecommunications Costing and Pricing Interconnection and Inter-Carrier Compensation Advanced Regulatory Studies Program Michigan State University Cincinnati, Ohio, October 13, 2000

Telecommunications Pricing in Tomorrow’s Competitive Local Market Professional Pricing Societies 9” Annual Fall Conference Pricing From A to 2 Chicago, Illinois, October 30, 1998

Recombining Unbundled Network Elements: An Alternative to Resale ICM Conferences’ Strategic Pricing Forum January 27. 1998, New Orleans, Louisiana

MERGERS - Implications of Telecommunications Mergers for Local Subscribers National Association of State Utility Consumer Advocates Mid-Year Meeting, Chicago, Illinois. June 24 1996

Unbundling, Costing and Pricing Network Elements in a Co-Carrier World

Page 14 *

MPSC Case No. U-13891 Exhibit SL/MS-l

Page 15 of 15


Telecommunications Reports' Rethinking Access Charges & lntercarrier Compensation Washington, D.C.. April 17, 1996

Key Local Competition Issues Part I (novice) Key Local Competition Issues Part I1 (advanced) with Mark Long National Cable Television Associations' 1995 State Telecommunications Conference Washington, D.C.. November 2,1995

Competition in the Local Loop New York State Telephone Association and Telephone Association of New England Issues Forum Springfield, Massachusetts, October 18, 1995

Compensation in a Competitive Local Exchange National Association of Regulatory Utility Commissioner Subcommittee on Communications' Summer Meetings San Francisco, California, July 21, 1995

Fundamentals of Local Competition and Potential Dangers for Interexchange Carriers COMPTEL 1995 Summer Business Conference Seattle, Washington, June 12, 1995

Page 15 *

MPSC Case No. U-13891

Response Testimony of Sherry Lichtenberg and Michael Starkey

February 20,2004

Exhibit - (SL/MS - 2)

RIICHIGAN PUBLIC SERVICE COMMISSION

EXHIBIT NO. red>

HOT CUT VOLUMES POST "NO IMPAIRMENT" FINDING Output Chart by Month

LichtenberglStarkey Response

Exhibit-(SUMS-2) MPSC Case No. U-13891

Page 1

Total Incremental Hot Cut Demand for SBC Michigan

300,000

250,000

200,000

150,000

100,000

50,000

-

I ~

~~ ____-

Phase 2 Phase 3 Phase 4 Phase 1

HOT CUT VOLUMES POST "NO IMPAIRMENT" FINDING Input Sheet

Input Values Description 1,209,687 UNE-P base lines

30,780 Net UNE-P Monthly Growth Rate 5.00% UNE-P Monthly Churn Rate -- IntraCLEC 5.00% UNE-L Monthly Churn Rate - IntraCLEC 3.00% UNE-P Monthly Churn Rate - to ILEC 3.00% UNE-L Monthly Chum Rate -to ILEC 5.00% Repair Adjustment

LichtenbergEtarkey Response Exhibit-(SLIMS-2)

MPSC Case No. U-13891 Page 2

Source SBC Michigan, Attachment 2 Final Batch Hot Cut Process CLEC UNE-P lines over last 9 months (MPSC Staff Report 4th Market Conditions Survey May 2003, Attachment A and SBC Michigan, Attachment 2 Final Batch Hot Cut Process) Calculated from assumed 8 % churn for CLEC and assumed 3 % winbacks. Calculated from assumed 8 % chum for CLEC and assumed 3 % winbacks. Assumed Assumed Assumed

HOT CUT VOLUMES POST"N0 IMPAIRMENT" FINDING By Month for SBC Mlshlgan

lnsremcntal UNE-L Combin

1,240,487 1,271,267 1.302.027 1.3U.807 1,363,587 1.394.367 1,425,147 1.455.927 1.486.707 4,517,487 1,568,267 1.579.M7 1.609.827 1.640.W7 4,509,358 1.388.610 i.zn.521 1.175.319 1.081.294

994.790 915.207 661,990 734.937 636.449 545.839 452,478 385,786 315.229 250.347 212.412

145,456 115,940 88.105 63.802 40.818 33.433 26.638 20.387 14.537 9.346 4.478

m u g

162.029 313.557 455.426 588.408 713.213 830,491 940.860

1,M4;857 1.182.690 1.31 1.958 1.433.348 ,.547.489 1:654961 1.756.298 1.851.990 1,920,675 1,988,328 2.M9.191 2,108,487 2,187,422 2.223.185 2,276,949 2.315.114 2352.689 2,889,720 2.428250

1,240,467 1.271.247 1,302,027 1,332,807 7,363,587 1,396,367 4,425,747 1,455,327 1.486.707 1.517.487 1.548.267 1.579.047 I.Mi9.827 1,660,507 1,871,387 1.702.167 1.732.947 1,763,727 1,794,507 1.625287 1.856.067 1.886.667 1,317,627 1.948.407 . . 1,979,487 2.W9.%7 2,040,747 2,074,527 2,102,307 2.133.087 2.163.867 2.194.€47 2,225427 2.256207 2.288987 2.317.787 2;348:5%7 2,373,327 1&,","7

30.780 30.780 30.780 30.780 30.780 30.780 30.760 30.760 M.780 30.780 30.780 30.780 30.780 30.780 30.780 30.780 M.780 30.760 30.780 30.780 30.780 30,780 30.780 30.780 30.780 30.780 30.780 30.780 30.780 30.780 30.780 30.780 30.780 30.780 30:780 30,780 30.780 30.780 34780 30.780 30.780

82.030 75.468 69.430 63.876 58.756 54.065 49.740 65.760 42.100 36.747 31.822 27.292 23.124 19.289 15.761 12.516 10.621 8.877 7.273 5.797 4.439 3,190 2,041 1.672 1.332 1.019

732

8.101 15.678 22.771 29.420 35 661 ~~. ~

4t.525 47,043 52.243 39.694 58.134 39.694 65.598 39.694 71.667 39.691 77,374 39,694 82.748 39.694 87.815 39.694 92~MK) 17.880 96,034 17.880 99.316 17,880

102.460 17.880 105.474 17,880 108.371 17.880 111.159 17.880 113.847 4.120 115.756 1.120 117.636 4,120

36.291 31.214 36.137 39.061 39.984 40.908 41.831 42.754 43,618 44.601 45.525 46,448 47.371 48.295 49.218 45.261 41.658 38.326 35.280 32.439 29.844 27.456 25.260 22.048 19,093 16.315 13.874 11.574 9.457 7.510 6,372 5.326 4.3% 3.478 2.6% 1,914 1.225 1.003

799 612

4,881 9.407

13.663 17.652 21.396 24,915 28.226 31.316 35.481 39.359 43,000 46.425 49.669 52.689 55.560 57,620 59.590 81.476 63.285 65.023 66.698 68.308 69,453 70.581 71.692 ~~

439 280

112.610 118.210 121.295 131,090 136.619 141.802 146.959 151,809 196.162 201.836 207.253 212.434 217.597 222.180 226.739

212.936 216.443 219.868

209.335

223.216 226.493 229.705 2~9.097

118.451 125.171 131.561 137.6at 143.4s 118.99i 154.30; 159.m 205.971 211.921 217.81( 223.05! 228.26 233.261 236.071 219.80 223.58 227.26 230.86 234.37 237.81 241.19 230.05 232.87

., . . ., . . . 2.440887 119.486 4.120

431.855 234,861 I 216.70 erflmste4 W" rate

MPSC Case No. U-13891

Response Testimony of Sherry Lichtenberg and Michael Starltey

February 20,2004

Exhibit (SL/MS - 3)

MlCHlGAN PUBLIC SERVICE COMMISSION FILE - cf /3m/

EXHIBIT NO.%

LichtenbergiStarkey Response Exhibit - (SLMS-3)

MPSC Case No. U-13891 Page 1

Te I co rd I aTu Technologes Performance from Experience

S

Telcordia Technologies Special Report

Issue 4 October 2000

SR-2275

An SAIC Company

Lichtenbergistarkey Response Exhibit - (SLNS-3)

MPSC Case No. U-13891 Page 2 SR-2275

Telcordia Notes on !he Networks Issue 4 Copyright Page October 2000

Telcordia Notes on the Networks

SR-2275 replaces SR-2275, Bellcore Notes o n the Networks, Issue 3, December 1997.

Related documents:

SR-NOTES-SERIES-01, Telcordia Notes on the Synchronous Optical Network (SONET) SR-NOTES-SERIES-02, Telcmdia Notes o n Dmse Wavelength-Division Multiplexing (DWDM) and Optical Networking SR-NOTES-SERIES-03, Telcordia Notes on Number Portability and Number Pooling SR-NOTES-SERIES-04, Telcordia Notes on the Evolution of Enhanced Emergency Smvices.

To obtain copies of this document, contact your company’s document coordinator or your Telcordia account manager, or call t1 800.521.2673 (from the USA and Canada) or +1 732.699.5800 (all others), or visit our Web site at www.telcordia.com. Telcordia employees should call t 1 732.699.5802.

Copyright 0 2000 Telcordia Technologies, Inc. All rights reserved. This document may not be reproduced without the express written permission of Telcordia Technologies, and any reproduction without written authorization is an infringement of copyright.

Trademark Acknowledgments Telcordia is a trademark of Telcordia Technologies, Inc. CLCI, CLEI, CLFI, CLLI, ISCP, NhlA, and SEAS are trademarks of Telcordia Technologies, Inc. COhlMON LANGUAGE, SPACE, TELEGATE, AIRBOSS, and TIRKS are registered trademarks of

CLASS is a service mark of Telcordia Technologies, Inc. Appletalk is a registered trademark of Apple Computer, Inc. DECNet is a trademark of Digital Equipment Corporation. IIIAESS, 4ESS, SESS, Dataphone, and SLC are registered trademarks of Lucent Technologies, Inc. DMS-10, DMSlOOF, DATAF’ATH, and TOPS are trademarks of Nortel. DhIS-100 is a registered trademark of Nortel. NEAX-GIE is a trademark of NEC America, Inc. EWSD is a registered trademark of Siemens AG

Any other companies and products not specifically mentioned herein are trademarks or senice marks of lheir respective trademark and service mark owners.

Telcordia Technologies, Inc.

I ii

Issue 4 Telcordia Notes on the Nelworks October 2000 Disclaimer

Telcordia Technologies Special Report Notice of Disclaimer

This Special Report is published by Telcordia Technologies to inform the industry of the topics discussed in Telcordia Notes on the Networks.

Telcordia reserves the right to revise this document for any reason, including but not limited to, conformity with standards promulgated by various agencies, utilization of advances in the state of the technical arts, or the reflection of changes in the design of any equipment, techniques, or procedures described or referred to herein.

Telcordia specifically advises the reader that this Special Report does not directly or indirectly address any Year-2000 (“Y2K) issues that might be raised by the services, systems, equipment, specifications, descriptions, or interfaces addressed or referred to herein. As an example, and not a limitation, neither this Special Report nor Telcordia is directly or indirectly assessing or determining whether specific services, systems, or equipment, individually or together, in their current form or as they may be implemented, modified, or augmented in the future, will accurately process dates and date-related data within or between the twentieth and twenty-first centuries, in either direction, including elapsed time, time difference, and/or leap year calculations.

LOCAL CONDITIONS MAY GNE RISE TO A NEED FOR ADDITIONAL PROFESSIONAL INVESTIGATIONS, MODIFICATIONS, OR SAFEGUARDS TO

REQUIREMENTS. IN NO EVENT IS THIS INFORMATION INTENDED TO REPLACE FEDERAL, STATE, LOCAL, OR OTHER APPLICABLE CODES, LAWS, OR REGULATIONS. SPECIFIC APPLICATIONS WILL CONTAIN VARIABLES UNKNOWN TO OR BEYOND THE CONTROL OFTELCORDIA. AS A RESULT, TELCORDIA CANNOT WARRANT THAT THE APPLICATION OF THIS INFORMATION WILL PRODUCE THE TECHNICAL RESULT OR SAFETY ORIGINALLY INTENDED.

TELCORDIA MAKES NO REPRESENTATION OR WARRANTY, EXPRESS OR IMPLIED, WITH RESPECT TO THE SUFFICIENCY, ACCURACY, OR UTILITY OF ANY INFORMATION OR OPINION CONTAINED HEREIN. TELCORDIA EXPRESSLY ADVISES THAT ANY USE OF OR RELIANCE UPON SAID INFORMATION OR OPINION IS AT THE RISK OF THE USER AND THAT TELCORDIA SHALL NOT BE LIABLE FOR ANY DAMAGE OR INJURY INCURRED BY ANY PERSON ARISING OUT OF THE SUFFICIENCY, ACCURACY, OR UTILITY OF ANY INFORMATION OR OPINION CONTAINED HEREIN.

This Special Report is not to be construed as a suggestion to anyone to modify or change any product or service, nor does this Special Report represent any commitment by anyone, including but not limited to Telcordia or any funder of this Telcordia Special Report, to purchase, manufacture, or sell any product with the described characteristics.

Readers are specifically advised that any entity may have needs, specifications, or requirements different from the generic descriptions herein. Therefore, anyone

MEET SITE, EQUIPMENT, ENVIRONMENTAL SAFETY OR COMPANY-SPECIFIC

LichtenberdStarkey Response Exhibit - (SLNS-3)

MPSC CaseNo. U-13891 Page 4 SR-2275

Telcordia Notes on the Networks Issue 4 Disclaimer October 2000

wishing to know any entity's needs, specifications, or requirements should communicate directly with that entity.

Nothing contained herein shall be construed as conferring by implication, estoppel, or otherwise any license or right under any patent, whether or not the use of any information herein necessarily employs an invention of any existing or later issued patent.

TELCORDIA DOES NOT HEREBY RECOMMEND, APPROVE, CERTIFY, WARRANT, GUARANTEE, OR ENDORSE ANY PRODUCTS, PROCESSES, OR SERVICES, AND NOTHING CONTAINED HEREIN IS INTENDED ORSHOULD BE UNDERSTOOD AS ANY SUCH RECOMMENDATION, APPROVAL, CERTIFICATION, WARRANTY, GUARANTY, OR ENDORSEMENT TO ANYONE.

If further information regarding technical content is required, please contact:

Don M. Tow Telcordia Technologies 331 Newman Springs Road, Room 32-207 Red Bank, NJ 07701-5699

For general inforniation about this or any other Telcordia documents, please contact:

Telcordia Technologies Customer Service Piscataway, New Jersey 08854-4156 1-800-521-2673 (US and Canada) 1-732-699-5800 (all others) 1-732-3382559 (FAX) http://www.telcordia. com

I iv

LichtenberdStarkey Response Exhibit - (SL/MS-3)


Telcordia Notes on the Networks Issue 4 Distribution October 2000

Subsequent to the passing of the Telecommunications Act of 199G, the ILECs sought judicial relief and won an appeal at the US. Eighth Circuit Court to repeal the UNE mandates. Upon appeal by the FCC and CLECs, the US. Supreme Court issued its “FCC Remand Order,” which required the FCC to re-examine all seven UNEs and justify/explain the rationale for each UNE that the FCC considers necessary.

In November 1999, the FCC released its Docket 99-238, which eliminated the OperatorlDirectory Services UNE, but retained the other six UNEs. In addition, the FCC added a new UNE called “Sub-Loop”. A sub-loop unbundled network element refers to any portion of the ILEC‘s whole loop which is outside the central office and that a CLEC can access and make interconnection to offer service to a customer.

In December 1999, the FCC released its Docket 99-355, which mandated another UNE, this one relating to the high-frequency portion of the loop. The mandate requires line sharing arrangements between an ILEC and a CLEC for both whole loop and sub-loop unbundling configurations. Line sharing, which is also known as spectrum unbundling, refers to the same twisted copper pair being used by more than one carrier. The ILEC can carry traditional voice-switched telephone service within the 0- to 3-Khz spectrum, and the CLEC can provide DSL services over the spectrum above 3 Khz. All ILECs must begin line sharing implementations by mid- year 2000.

12.13.2 Loop Unbundling

There are two main types of loop unbundling. The first is called “whole loop” unbundling, which is the unbundling of a whole loop from the MDF in the ILEC‘s central office to the customer premises. The second type is called “sub-loop” unbundling, which refers to a portion of the ILEC‘s whole loop being offered to a CLEC. This section provides more infomiation about each type of loop unbundling.

12.13.2.1 Whole Loop Unbundling Configurations

Typically, when a customer requests dial tone service from a CLEC, the ILEC removes the wired connection to the ILEC switch in the central office and rewires the customer’s loop to a CLEC “meet” point in the central office. Figure 1232 depicts whole loop transfers in the ILEC central office when the customer is served by copper facilities or by a UDLC system. In most cases, there is an analog handoff to the CLEC. If the CLEC requests a digital handoff, the ILEC may utilize a D4 channel bank to digitize the circuits. Most CLECs transport the unbundled loops back to their central offices (switches) using GR-303 IDLC systems. To do this, the CLECs deploy GR-303 RDTs within their collocation cages in the ILEC‘s central offices.

The most critical factor associated with unbundling a customer loop is the type of loop facility that the customer is already utilizing for service, such as all-copper, UDLC system, or IDLC system.

I 12-52

LichtenbergIStarkey Response Exhibit - (SLMS-3)


Issue 4 Telcordia Notes on the Networks October 2000 Distribution

CLEC#l CLEW2 r t

Switch

. EC . . . . CO . . . . . .

D!

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ILEC circuils routed mrovgh MDFto ILEC switch CLEC CIICYI~S muled through MDF to CLEC collocation quiprnenl

Figure 12-32. Unbundling Loops Served by Copper or UDLC Systems

0 If the customer is receiving service over all-comer facilities, the transfer of the whole loop is straightforward as indicated in Figure 12-32. The ILEC removes the central office connection to its switch and places a jumper from the MDF to the meet point at the CLEC’s collocation cage. There is no need to rewire the outside plant or visit the customer premises.

whole loop can be straightforward as shown in Figure 12-32. The ILEC removes the central office connection to its switch and places a jumper from the MDF to the meet point at the CLEC‘s collocation cage. Again, there is no need to rewire the outside plant or visit the customer premises.

However, if the customer is served by an IDLC svstem, the loop is digitally transmitted to the ILEC switch. There are a variety of “technically feasible” options available to the ILEC to unbundle the loop. Each ILEC has established its own set of approved unbundling options along with the corresponding methods, procedures, and practices needed for implementing these options. Numerous unbundling options are possible because many of today’s RDTs support multiple kinds of interfaces such as: GR-303, TR-08, UDLC, and D4 DS1. Also, some RDTs are capable of supporting multiple GR-303 Interface Groups, thereby permitting a single RDT to connect to multiple switches

Some common IDLC unbundling options are:

If the customer is receiving service over a UDLC svstem, the transfer of the

1. Bypass the IDLC system and transfer the loop to an all-copper pair

If there are available spare copper facilities serving the customer’s neighborhood, transferring the IDLC customer to a spare all-copper circuit may be a viable option for the ILEC, as shown in Figure 12-33. Although this

12-53 I

Lichtenberg/Starkey Response Exhibit - (SLMS-3)

MPSC Case No. U-13891 Page I SR-2275

Issue 4 October 2000

Telcordia Notes on the Networks Distribution

Switch CLEC Customer

Figure 12-33. IDLC Unbundling - Bypass the IDLC System

procedure is relatively simple, it requires central office and outside plant rewiring to complete the new circuit from the MDF to the customer. The all- copper unbundled loop is the easiest unbundling architecture for the ILEC to perform maintenance and testing.

Some ILECs serve new neighborlioodshousing developments with DLC systems and install a very limited number of copper pairs to support certain services. In these areas, spare copper facilities can be quickly exhausted if used for unbundled loops.

2. Bypass the IDLC system and transfer the loop to a UDLC system

If there are no spare copper facilities in the customer’s neighborhood, the ILEC may transfer the customer’s circuit from the IDLC system to a UDLC system (see Figure 12-33). This transfer will also involve both central and outside plant work activity.

The customer fill rates at IDLCNDLC CEV sites are typically 50 to 70%. There is a moderate amount of spare capacity on the UDLC systems to support transfers from IDLC systems.

3. Utilize the UDLC capability of the IDLC system

If the IDLC system is equipped to support UDLC functionality, the ILEC can electronically re-provision the circuit from IDLC to UDLC (see Figure 12- 31). No outside plant work activity is needed. Central office work activity is needed to run jumpers from the MDF to the collocation cage and, if necessary, place a UDLC plug-in at the COT.

4. Utilize a separate GR-303 Interface Group for the CLEC customers

Figure 12-36 shows the use of separate GR-303 Interface Groups to cany ILEC and CLEC traffic. The RDT must support the MIG (Multiple Interface Group) capability defined in the GR-303 specification. This configuration allows a CLEC switch to connect to the ILEC’s RDT at the GR-303 interface level.

I 12-54

LichtenbergBtarkey Response Exhibit - (SLNS-3)


Telcordia Notes on the Networks issue 4 October 2000 Distribution

CLE

ILEC Eircut6 use GR-303 /

Analog Lines

MUXICOT j

I I:

RDT /

I ILEC CO ................................................ 1

CLEC circuits use UDLC

Figure 12-34. IDLC Unbundling Using the UDLC Capability of RDT

LEC CO ...............................................

RDT 1

U Figure 12-35. IDLC Unbundling Using Separate GR-303 Interface Groups

This arrangement may be cost effective for those CLECs having a "critical mass" of subscribers served by the RDT or group of RDTs in a CEV. Since the GR-303 Interface Group supports operations functionality, there are a variety of issues (provisioning, alarm reporting, sharing of test resources, etc.) that are currently being addressed by the industry.

In response to the Telecommunications Act of 199G, GR-303 requirements were changed in 1997 to permit a single DS1 to be called a 303 Interface Group. A minimum of two DSls was previously required. This change allows a CLEC to serve a small base of customers at an RDT more economically (but at the risk of lower service availability and reliability).

5. Share a GR-303 Interface Group and use the sidedoor port of the switch to transport CLEC traffic out of the ILEC switch

12-55 I

LichtenbergIStarke y Response Exhibit - (SLMSJ)

MPSC CaseNo. U-13891 Page 9 SR-2275


Figure 12-36 shows the use of a GR-303 Interface Group sharing ILEC and CLEC traffic where all CLEC traffic is routed through sidedoor port DSls out of the ILEC's switch.

........... *c t I

~ 1 ........................ ILEC CO ...................... j U

Figure 12-36. IDLC Unbundling Using Sidedoor Port

CLEC circuits are provisioned as non-switched, non-locally switched circuits within the IDLC system. While the DCS-1/0 is shown in the figure, it is not a requirement of this architecture. The advantage of using a DCS-1/0 is realized if the CLEC is not fully utilizing a DS1 from the ILEC LDS to the CLEC, and multiple switch modules with IDCUs are used by the ILEC. If a DCS-UO is placed between the LDS DS1 sidedoor port and the CLEC DSls, it would permit full utilization of the sidedoor LDSiIDCU hardware by enabling CLEC DSOs to be rearranged in the DCS-1/0 and placed on the individual CLEC DSls.

The ILEC must address the following issues associated with the sidedoor port arrangement:

A. The cost of a DS1 switch termination for a sidedoor port is about ten

B. Since each CLEC circuit requires a nailed up DSO, the ILEC may

times the cost for a DS1 line card on a RDT.

encounter blocking over the IDLC system as other circuits compete for DSO channels.

C. The number of sidedoor ports that can be engineered varies depending on the LDS supplier.

D. There is limited support in existing special services design systems and databases to support sidedoor port circuits.

E. The ILEC may need field visits to install special service D4 channel units at the RDT.

I 12-56

LichtenbergIStarkey Response Exhibit - (SLMS-3)

MPSC Case No. U-13891 SR-2275 Issue 4 Telcordia Notes on the Networks

Distribution Page 10

G . Utilize separate TR-08 Interface Groups to transport CLEC traffic

Figure 12-37 shows the use of separate TR-08 Interface Groups to carry CLEC traffic while utilizing the GR-303 Interface for ILEC traffic. In the figure, the RDT supports both GR-303 and TR-08 generic interface capabilities. CLEC switches can interconnect with the ILEC's RDT utilizing the DS1 handoff from the TR-08 interface.

I LDS D

T

r . . ....................................... .....,

CLEW1 j Handles ILEC ~lrcuits CLEC#2

RDT 111-08 DSl(r1

IC#2

GK-303 DSl(r)

I ILEC CO .................................................

Figure 12-37. IDLC Unbundling Using Separate TR-08 Interface Groups

7. CLEC leases entire RDT

Figure 12-38 shows the configuration when a CLEC leases an entire RDT from the ILEC.

CLEC#l j CLEW?.

CLEC C u s l o m ~ r s Leased ROT t

I MUX i /

................................................. I ILEC CO

Figure 12-38. IDLC Unbundling - CLEC Leases Entire RDT

LichtenbergBtarkey Response Exhibit - (SLMS-3)

MPSC Case No. U-13891 SR-2275 Page 11


RDT#1 serves the ILEC customers, and RDT#2 serves the CLEC customers. This unbundling option may be cost-effective for the CLEC if the CLEC has a significant number of residential customers in the neighborhood or is serving a business park or campus.

12.1 3.2.2 Sub-Loop Unbundling Configurations

Sub-loop unbundling occurs when a CLEC interconnects to aloop facility at apoint outside the ILEC’s central office. The Sub-hop UNE is defined by the FCC as portions of the loop that can be accessed at terminals in the ILEC‘s outside plant. An accessible terminal is apoint on the loop where technicians can access the wire or fiber within the cable without removing a splice case to reach the wire or fiber within. Examples of access terminals are: poles, pedestals, the NID, the Minimum Point Of Entry (MPOE) to the customer premises, the MDF, and the Feeder/ Distribution Interface (including CEVs, utility rooms, and DLC Remote Terminals). FigureI2-39 shows sub-loop unbundlingat a GR-303 Remote Terminal (RDT) where a CLEC interconnects at the ILEC‘s RDT using its own GR303 Interface Group facilities to provide service to its customers. In this configuration, the CLEC leases from the ILEC the RDT equipment and the RDT line facilities to each of its customer premises.

j I I I j

I CLEC co , ....................... RDT ILEC & CLEC - customers , ....................... ! m i

1 : lLECCuntomcrS ! ILEC 1 LDS i CR-303 DSl(s)

IC#l

’ !......................I ILEC CO U Figure 12-39. Sub-Loop Unbundling at an RDT

The FCC mandate on sub-loop network elements places the burden on each state regulatory commission to determine whether specific interconnection points in the outside plant are “technically feasible”. The law directs the state commission to examine the ILEC‘s specific architecture and the specific technology used over the loop to determine whether it is really technically feasible to unbundle the sub-loop at a potential access point where a competing carrierrequests access. Two key factors that are considered in this “technically feasible” determination are whether there is adequate space for collocated CLEC equipment to be installed and if the site has sufficient security safeguards to prevent mischief or sabotage. The FCC has

I 12-58

Issue 4 Telcordia Notes on the Networks October 2000 Distribution

indicated that its central office collocation rules are also applicable to collocation in outside plant locations.

Since the FCC sub-loop unbundling mandate was announced in 1999, there hasbeen little time for ILECs, CLECs, and state commissions to deal with this UNE. Sub-loop UNEs are an emerging market and, at this time, it is not clear which portions of the ILEC outside plant will be aggressively pursued by CLECs.

Numerous sub-loop unbundling configurations are possible. A CLEC may lease facilities from multiple carriers to create circuits, or it may deploy some of its own facilities and lease other facilities to extend its network to reach a greater customer base. Depending on the CLEC's network architecture, some of the transmission and technical issues associated with IDLC and UDLC configurations (described in Section 12.13.3) may be observed.

12.13.3 Unbundling Issues Associated with UDLC and IDLC Systems

There are various transmission and other technical issues associated with the use of UDLC and IDLC systems in the unbundling environment. In many loop unbundling configurations, the CLEC utilizes an IDLC system to economically transport unbundled loops from the ILEC's central office to the CLEC's central office. Issues arise when the ILEC terminates long length allcopper loops or DLC- transported loops to the CLEC's RDT (meet points at the collocation cage).

When an unbundled all-copper loop greater than 900 ohms or 12 Kft long is terminated at the CLEC's RDT, the customer may encounter degraded voice frequency transmission. To maintain the POTS grade of service, the CLEC may need to install an RDT line unit with a higher DC supervisoty range to accommodate the long loop.

When an unbundled UDLC loop is terminated at the CLEC's RDT, the following impacts may be observed

- Increased dial tone delay

- Degradation of on-hook transmission services, such as caller ID (due to delays)

- Degradation of signal quality (as a result of multiple A/D and D/A conversions)

- Reduction in analog modem operation speed (connection speed depends on loop length, number of AID conversions, local switch type, and interoffice facility type).

Figure 1240 shows the back-to-back DLC configuration.

12-59 1

LichtenberdStarkey Response Exhibit - (SLMS-3)



UDLC (iLEC) iDLC (CLEC) ILEC Customers n

CLEC Customers .......................................... lLEC Sewing OMee !

i CLECSwitch j j

! CLEC Serving j onics ! : ......................

Figure 12-40. ILEC/CLEC Back-To-Back DLC Configuration

12.13.4 The Evolving Loop Unbundling Environment

Initially, ILECs offered and provided unbundled circuits to CLECs as analog handoffs to the collocation cages of the CLECs. Many ILECs now offer DS-0 digital connectivity to the CLEC collocation cages. DS-1 interconnection is emerging. Less than 2% of all access lines in the U S . are currently unbundled, but this may rise to as much a s 30% in the next 5 to 10 years. The factors that will significantly impact the potential growth in unbundled loops are: additional FCC regulatorykourt changes, rate of implementation of ILECKLEC line sharing, and decisions by individual state commissions.

In the current loop unbundling environment, CLECs are largely focusing on unbundling ILEC business customers. The drivers behind this approach are economics and scalability. Provisioning and maintaining multiple unbundled loops from a single business customer lets the CLEC use digital subscriber lines over ILEC facilities. CLECs are requesting copper unbundled pairs and placing DSL equipment on these pairs to provide multiple POTS lines over no more than two unbundled copper pairs. The residence unbundling architecture presents agreater economic challenge to the CLEC because residential customers will generally request a single unbundled loop. CLECs fmd serving business customers much more profitable than serving residential customers. The FCC mandates on sub-loop unbundling and line sharing are expected to have a significant impact on CLEC expansion into the xDSL marketplace because CLECs will no longer be forced to incur the full cost of a separate copper line to serve customers.

The FCC orders mandating sub-loop unbundling and line sharing will likely be challenged in the courts. While this process evolves, CLECs will press for access to the local loop at the interconnection point nearest to the customer. When DLC systems are used to provide ILEC services, the CLEC will want to interconnect at the RDT. The reasoning for gaining access to the RDT on the analog customer side is to have the ability to provide all of the offered ILEC services without the

I 12-60

Issue 4 Telcordia Notes on Ihe Networks October 2000 Distribution

transmission impairments and operational issues associated with interconnection at any other location.

When these RDTs are within 3,000 feet of the customer, either the ILEC or CLEC can have the ability to use xDSL technology to offer high-speed data access as well as video services. The CLEC may also choose to offer traditional telephone services using "voice over I P technology. With this technology, it is possible to have the ILEC owning the 0- to 3-khz bandwidth on a twisted pair from the RDT to the customer NID and having no services connected at the customer premises. The CLEC utilizes the frequency above 3 kHz (xDSL) and provides voice, data, and video services.

The evolution of the loop plant is shifting toward greater fiber deployment. When fiber systems advance to the situation where a significant number of residences are served using FTTC systems, CLECs will request access to some of the interconnection points in the fiber network.

12-61 1

Documents

CaseNo. U-13891 Mass Market Batch Cut Proposed Process Page …