RFI No.: DMS-12/13-024 Amendment No. 2

REQUEST FOR INFORMATION STATE OF FLORIDA

FLORIDA’S TELECOMMUNICATIONS SERVICES

ENVIRONMENT

RFI NO.: DMS-12/13-024

AMENDMENT 2

The Department hereby formally provides written responses to questions received on the following page.

RFI No.: DMS-12/13-024 Amendment No. 2

All written questions are reproduced in the same format as submitted by the Respondent.

Question #1

In the title of Section D, “Impact of deregulation on unbundled local loop”, the RFI references deregulation. What deregulation are you referencing in that title? Is it the state deregulation of retail services in Florida referenced in this section? If not, please explain what is being referenced.

Answer #1

DMS is referring to the State and Federal deregulation of wholesale and retail telecommunication services in Florida.

During planning session, DMS assumed that regulatory requirements compelling local exchange agreements for local loop transport infrastructure have been eliminated. However, since it was an assumption, DMS needs to hear from the telecommunications industry on matters related to use of mutual local exchange agreements that may impact the sharing of facilities between service providers.

If regulatory requirements have been eliminated or changed, what is the impact of “bundling” the MFN2 core with local loop connections, or separating the MFN2 core from local loop? DMS wishes to understand whether a single bundled solution will offer the best value to its customers under the current telecommunications environment.

Question #2

In the first paragraph of Section D, the RFI states, “The elimination of regulatory requirements is unclear on the shared use of local loop transport infrastructure.

Answer #2 See Answer #3.

Question #3

Are the regulatory requirements discussed here associated with the deregulation referenced in question 1?

Answer #3

Yes, through the RFI process, DMS expects to understand the impact of all regulations (or deregulation), including State and Federal as it relates to whether or not DMS should bundle the local loop with MFN2 core in a future procurement.

Question #4

What services are being referenced when the RFI states shared use of local loop transport infrastructure?

Answer #4

DMS wishes to understand the regulatory and practical impact of local loop or inter-LATA transport use of telecommunication services in Florida between vendors. Under mutual local exchange agreements, are vendors compelled/required to allow other providers to resell infrastructure at a competitive cost; compelling sharing of access.

Question #5 What services are being referenced when the RFI refers to “local loops?”

RFI No.: DMS-12/13-024 Amendment No. 2

Answer #5

See the definition of “Local Loop Connection” under Section III, “Definitions”. Examples of these local loop connections are Ethernet, Cable, DSL, Mobile Cellular, and Frame Relay technologies. Local loop connections can also terminate to the closest switching infrastructure (not the MFN2 Core Node) for services. Inter-LATA transport services are another example of services where DMS wishes to understand the impact from a regulatory perspective.

Question #6

Are the constructed access facilities restricted in any way?

Answer #6

See Question and Answer #7.

Question #7

If restrictive language exists, can DMS provide the language for review?

Answer #7

Related to RFI question D.11 on the topic of special construction, DivTel has language on an access service tariff issued by BellSouth Telecommunications on July 1, 1996. The file copy was PSC authority number T-96-558. A scan copy of the document has been provided.

DMS is using question D.11 of the RFI to obtain information from the industry on special construction.

Question #8

Have special construction projects taken place for vendors other than the incumbent MFN contract holder or did the projects extend the incumbent’s network to the MFN customer?

Answer #8

8.a Have special construction projects taken place for vendors other than the incumbent MFN contract holder? No, only by the incumbent and their subcontractors.

8.b Did the projects extend the incumbent’s network to the MFN customer? Yes, only by the incumbent and their subcontractors.

Question #9 In general, any additional information that can be shared regarding the special construction projects including the site list would be helpful in developing a targeted RFI response.

Answer #9 The goal of this RFI is to provide DMS with the latest accurate information on the telecommunications services environment as well as other telecommunication issues within Florida as it relates to special construction projects. As additional information, a scanned copy of the Access Service Tariff is attached.

RFI No.: DMS-12/13-024 Amendment No. 2

Question #10 D. Impact of deregulation on unbundled local loop

For MFN2, DMS is clearly wrestling with the options of “bundling” the MFN2 core with local loop connections, or separating the MFN2 core from local loop purchases with contractual connectivity and performance mandates. The elimination of regulatory requirements is unclear on the shared use of local loop transport infrastructure.

Q> Reference is made throughout this document to the elimination of regulatory requirements. To what activities regarding the elimination of regulatory requirements are these points directed? We are aware of several filings that have been submitted to the FCC regarding questions to the Telecom Act of 1996 and its regulations, but no firm action has been taken in support of these filings.

Answer #10 Points are directed at understanding today’s telecommunications environment as it relates to replacing the current statewide Multi-Protocol Label Switching network known as MyFloridaNet with a new network (MFN2). DMS is using the RFI process to hear from the telecommunications industry to better understand the topic of regulatory requirements including the perspective of change over the years.

The current MFN network is bundled. A fundamental consideration for DivTel relates to the competitiveness of the MFN2 procurement and utilizing the RFI process to obtain insight from the telecommunications industry. The industry is being asked about the regulatory environment and how today’s environment impacts considerations related to bundling the MFN2 core with local loop connections or separating the MFN2 core from the local loop connection.

Question #11

It is DivTel’s opinion that unbundling the MFN2 core from local loop connections creates a common business dilemma from specialization. Firms that are well equipped to provide the MFN2 core may not be well equipped to also strike local loop agreements, process orders and charges for them, and rebill them to DMS.

This leads to numerous questions:

1) The explanation above indicates the regulatory requirements compelling shared use of local loop transport infrastructure have been eliminated. Is that a valid assumption? If not, please describe the conditions compelling shared access of the local loop transport infrastructure.

Q> Please explain the origin of the statement above that “regulatory requirements compelling shared use of local loop transport infrastructure have been eliminated”.

Answer #11

During a planning session, DMS assumed that regulatory requirements compelling local exchange agreements for local loop transport infrastructure have been eliminated. However, since it was an assumption, DMS needs to hear from the telecommunications industry on matters related to use of mutual local exchange agreements that may impact the sharing of facilities between service providers. DMS is using the RFI process to understand the competitive environment related to the telecommunications industry and where providers are compelled/required to allow other providers to resell infrastructure; compelling sharing of access.

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Question #12 2) Is there a distinction in the answer to the first question above (1 – regarding regulatory requirements compelling shared use) between copper and fiber? Is there an answer distinction between currently active verses inactive circuits?

Q> Please further explain the second part of question #2. Please define what is meant by an “active” circuit and an “inactive” circuit.

Answer #12 In a discussion on the topic of Florida’s regulatory environment a question arose related to infrastructure used by telecommunications providers. DMS wishes to know if there is a regulatory difference between active and inactive circuits, and if so, what is the difference.

If a circuit was active within a provider’s infrastructure, then would the existence of mutual local exchange agreements compel the provider to make that circuit available to another telecommunications provider for resale? For circuits or facilities that are inactive, could a provider deny use infrastructure for another provider wishing to use it for resale.

Question #13 3) If providers are really no longer compelled to share use of local loop transport infrastructure due to deregulation, what other leverage would a single vendor providing a bundled network have over other providers to gain competitive access to local loops?

Q> Are responding vendors required to purchase local loops from third-party vendors or could vendors propose construction to any off-net locations? Or connectivity through other means, i.e. wireless local loops. Microwave links, etc. What restrictions will be placed on potential local loop solutions?

Answer #13

For the purpose of an RFI, responding vendors are not required to propose service. The goal of this RFI is to provide DMS with the latest accurate information on the telecommunications services environment as well as other telecommunication issues within Florida as it relates to special construction projects.

Question #14

4) Bundling the MFN2 core and local loop connections may simplify DMS’s administrative processes and also eliminate some operational difficulties such as pinpointing vendor performance accountability where stringent SLAs (end to- end) are utilized. Has there been an impact of deregulation on these considerations?

Q> To what de-regulation activity is this question referring? Please specify docket number and/or agency enacting de-regulation requirements.

Answer #14

The goal of this RFI is to provide DMS with the latest accurate information on the telecommunications services environment as well as other telecommunication issues within Florida as it relates to Service Level Agreements.

To clarify, the RFI is trying to determine if there has been any deregulation activity with

RFI No.: DMS-12/13-024 Amendment No. 2

regard to these considerations and if so, what is the impact?

Question #15 5) In today’s environment, is there any compelling reason to avoid a procurement for local loop connections using an unbundled structure? In such an unbundled scenario, what would be the impact on SLAs, network performance, and pricing? Provide a list detailing the pros and cons of a bundled verses unbundled award strategy. Q> From which perspective would the pros and cons originate. If we examine the pros and cons from a carrier’s perspective versus the customer’s perspective (DMS’ perspective) the responses will more than likely have different focal points.

Answer #15 Respondents are asked to provide both perspectives and clearly indicate the perspectives offered.

Question #16 6) How best to provide a ubiquitous service delivery within a wide array of customer service needs; from public safety with aggressive 24x7x365 Service Level Agreements, to customers with less stringent SLAs?

Q> Specifically, what range of SLAs would be requested? min and max?

Answer #16 This question is attempting to gain industry insight on SLAs. DMS seeks the industry perspective on how MFN2 SLAs should be constructed to serve both the public safety clients and best effort clients. Since MFN has law enforcement and other public safety clients as customers, how best to construct an infrastructure with high availability as a requirement, but at the same time provide best value.

Question #17 7) Given the changes in the telecommunications environment since the original MFN award, is it still reasonable to expect that DMS could receive overall pricing for MFN2 that is lower than MFN if MFN2 services are bundled and its SLAs are equivalent to MFN’s? Please explain your response in detail.

Q> What is MFN paying today for the holistic solution? A ball-park estimate?

Answer #17 For 2012 calendar year, MFN vendor payments were approximately $42,000,000.

Question #18 8) What standards and restrictions should the department consider to address the local loop connection in a bundled and unbundled strategy to ensure end to-end operability, reliability, and security?

Q> To what specific requirements in terms of end-to-end operability, reliability, and security does MFN currently adhere? Is MFN currently satisfied with the network’s performance in terms of these criteria? Why or why not?

RFI No.: DMS-12/13-024 Amendment No. 2

Answer #18 18a. To what specific requirements in terms of end-to-end operability, reliability, and security does MFN currently adhere? The MFN contract has been provided.

18b. Is MFN currently satisfied with the network’s performance in terms of these criteria? Why or why not? The goal of this RFI is explore potential solutions for the next contract, not to comment on the performance under the current contract.

Question #19 9) What standards and restrictions should the department consider to address the MFN2 core design strategy to ensure end-to-end operability, reliability, and security under bundled and unbundled approaches?

Q> To what specific requirements in terms of end-to-end operability, reliability, and security does MFN currently adhere? Is MFN currently satisfied with the network’s performance in terms of these criteria? Why or why not?

Answer #19 See answer #18.

Question #20 10) Clearly, the number of MFN2 core nodes used to construct a statewide backbone has a direct impact on the cost. In recognition, DMS is attempting to balance the number of MFN2 core node locations with the desire to obtain low cost local loop connections. The need to understand these factors leads to a number of questions:

a. Does DMS need to require one or more MFN core nodes in each LATA to obtain low cost local loop connections? For reference, a LATA map can [RFI No.: DMS-12/13-024 Page 9 of 12][sic]

be found on the Public Service Commission web-site

http://www.psc.state.fl.us/utilities/telecomm/areacode/exchangemap.pdf)

Answer #20

See answer #21.

RFI No.: DMS-12/13-024 Amendment No. 2

Question #21

Q> Define more specifically the characteristics that MFN considers when specifying a location as a core node? For example, is there a square footage limitation, a bandwidth capability requirement of that location, etc.

c. Increasing the number of core nodes makes local loop connections shorter. Does increasing the number of MFN2 core nodes statewide make it possible for DMS to improve competition because more and more local loop connection providers can offer local loop connections to the MFN2 core node?

Answer #21

DMS would like to validate if the background in Question D.10 of the RFI is a true statement. DMS believes that the answer to Question D.10 of the RFI can be provided by the industry without any characteristics or specifics for the location of a core facility. Respondents are free to choose any location to illustrate their response.

Question #22

12) What are the deregulation related impacts DMS should consider in drafting the procurement document where design or administrative components are committed to exclusive use by SUNCOM customers rather than shared among a broader customer base (for example, financial institutions, hospitals and retail stores)?

Q> Please further define “design or administrative components” and to what level exclusivity must be met, i.e. separate wavelengths within same cable, separate fibers for each service, separate VLANs for each service, etc.

Answer #22

DMS seeks to understand the pros and cons of a private infrastructure dedicated to exclusive use by SUNCOM customers vs. using a provider’s commercial infrastructure where hospitals and retail stores exist as customers.

Core routers, NMS tools, Internet/Firewall equipment are examples of design components that are currently dedicated to the exclusive use by SUNCOM customer under MFN. Staff, billing, and SLA data scrubbing are examples of administrative components that are currently dedicated to the exclusive use by SUNCOM customer under MFN.

The goal of this RFI is to provide DMS with the latest accurate information on the telecommunications services environment as well as other telecommunication issues within Florida as it relates to infrastructure dedicated to MFN2 and infrastructure shared with provider’s commercial customers.

Question #23

15) Are there any other implications related to deregulation DMS should consider

in this procurement?

Q> Please further define what de-regulation activities are being considered in this question.

RFI No.: DMS-12/13-024 Amendment No. 2

Answer #23

RFI Question D.15 was written as a catchall for Respondent’s to use at their discretion. DMS wanted to allow the RFI respondents to offer any additional comments on the deregulation topic as it relates to the overall background question of should the MFN2 core be segregated from local loop.

Question #24

Does the MFN core network consist of any other WAN technologies besides MPLS? (i.e., Metro-Ethernet, Fiber rings, Private Lines, etc. between major node sites)

Answer #24

The fundamental MFN core technology that allows MFN to provide enterprise services is known as Multi-Protocol Label Switching (MPLS) over 10GE (WAN PHY and LAN PHY).

In addition, MFN provides local loop connections to the closest MFN core node using various layer-2 transport technologies. MFN supports and provides a variety of local loop connections such as Ethernet, Frame-Relay, Private-Line, DSL, Mobile Cellular, and Satellite. For details, please refer to the background under Section E of the RFI.

Question #25

Who is/are the incumbent provider(s)?

Answer #25

AT&T is the prime contractor holding subcontracts with providers such as Hayes and CenturyLink.

Question #26

RFI Page 4 Regarding the MFN network diagram:

Are the blue 10G connections shown in the drawing MPLS or point-to-point circuits?

Please describe.

RFI Section D, Question 7:

To provide a thorough answer, is it possible to get a list of current MFN WAN services.

RFI Section E:

Does MFN currently have an MPLS wholesale NNI with the incumbent?

Is it a 10A or 10B NNI?

Answer #26

26a. RFI Page 4 Regarding the MFN network diagram: Are the blue 10G connections shown in the drawing MPLS or point-to-point circuits? Please describe. – The blue 10GE connections are a combination of 10GE WAN PHY and LAN PHY.

26b. RFI Section D, Question 7: To provide a thorough answer, is it possible to get a list of current

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MFN WAN services? - MFN Core supports and provides a variety of local loop connections ranging from 56kbps to 1000Mbps supporting technologies such as Frame-Relay, Ethernet, Private-line, Satellite, Mobile Cellular, and DSL.

26c. RFI Section E: Does MFN currently have an MPLS wholesale NNI with the incumbent? Is it a 10A or 10B NNI? No.

Question #27

In the response to this RFI, is the State interested in receiving information regarding additional cloud services such as Hosted Unified Communication, IaaS, SaaS?

Answer #27 No.

Question #28

What is the expected time frame for the release of the RFP?

Answer #28

No final determination has been made on the timeline.

Question #29

Is the bidding open to all providers or only Tier 1?

Answer #29

This is an RFI, therefore no bidding is involved.

Question #30 Once the vendor has been selected how much time will be allotted to implement the new network?

Answer #30 No final determination has been made on the timeline.

Question #31 Will MFN and MFN2 run side by side or will there be phased hot cuts?

Answer #31 No final determination has been made.