Issue Petitioners' Proposed Contract Verizon's Proposed Contract

Issue Petitioners' Proposed Contract Verizon's Proposed ContractNo. Statement of Issue Lanl!Ua2e Petitioners' Rationale Lanl!Ua2e Verizon Rationale

agreement so that the terms thatgovern access to DAL data arecontained in the agreement itself.WorldCom will continue to work withVerizon to ensure that WorldCom hasuninterrupted access to DAL dataafter the DAL Agreement expires.(Caputo Rebuttal, 9/5, at 5-7).

IV-25 Should the Interconnection Attachment III, Section 13.6 et seq. During mediation the parties agreed UNE Attachment Verizon's Interconnection AgreementAgreement include detailed to the contract language attached proposed to WorldCom, Additionalprovisions regarding the Calling 13.6 CaUing Name (CNAM) hereto regarding provision of 11.1 In accordance with, but only to Services Attachment § 3 provides thatName (CNAM) database which Database. The "CNAM Database" Verizon's calling name database the extent required by, Applicable Verizon will provideVerizon must make available as an means the databse in which Verizon (CNAM). The only dispute in this Law, Verizon shall provide **CLEC nondiscriminatory access to itsunbundled network element? stores subscriber information area between the parties is whether with access to databases and directory assistance listings database

(including name and telephone Verizon must allow MCIm "batch" or associated signaling necessary for call through a mutually acceptable writtennumber) used to show the customer "full" access to Verizon's entire routing and completion by providing agreement. Such an agreement existsname of an incoming call on a display CNAM database in a bulk, SS7 Common Channel Signaling between WorldCom and Verizon andattached to the telephone whether or downloadable format or on a per dip ("CCS") Interconnection, and therefore this issue should not benot such database contains exclusively basis as proposed by Verizon. Interconnection and access to toll free included in this arbitration.CNAM information. Verizon shall service access code (e.g.,provide MCIm with access to Verizon's limited offering of access 800/888/877) databases, LIDB, and Acceptance of WorldCom's proposalVerizon's CNAM Database in on a "per-query" or "per-dip" basis is any other necessary databases. would require Verizon Verizon VA toaccordance with the following: inconsistent with applicable law. provide WorldCom with the entire[Agreed] Because CNAM is an unbundled Verizon also proposes to add the CNAM database in a bulk,

network element ("UNE"), following language: downloadable format. Verizon VA is13.6.1 Verizon shall provide to nondiscriminatory access to that call- required to do no more than provideMCIm all subscriber records used by related database under Section Calling Name Database (CNAM) WorldCom with access to its CNAMVerizon to create and maintain its 251(c)(3) of the Telecommunications database on a per query basis as itCNAM database, in a Non- Act of 1996 ("Act") entitles Verizon shall permit **CLEC to does for itself and all CLECs as wellDiscriminatory manner. MCIm may WorldCom to the same ready access transmit a query to Verizon's CNAM as independent telephone companiescombine this Network Element with to the database as Verizon enjoys. 47 database for the purpose of obtaining and LECs operating outside ofany other Network Element for the U.S.c. § 251(c)(3). the name associated with a line Verizon VA's service areas. Seeprovision of any Telecommunications number for delivery to **CLEC's Rule 51.319(e)(2)(A).Service. [Agreed] The "nondiscriminatory" requirement local exchange customers. To the

with respect to call-related databases extent **CLEC provides local Requiring Verizon VA to provide13.6.2 Verizon shall provide MCIm means that Verizon has a duty to switching utilizing its own switch, WorldCom with its CNAM databaseall ILEC, CLEC, and independent provide access to the databases in at **CLEC may request that Verizon in a bulk, downloadable format would

KEY WHERE DISTINCTION AMONG PETITIONERS IS NECESSARY: WorldCom (bold); Cox (underline text); AT&T (italic).

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telco subscriber records used by least the same manner that Verizon provide CNAM database storage and create a host of problems for VerizonVerizon within its CNAM database in provides it to itself. The FCC has validation services pursuant to Tariff VA. First, unlike Verizon VA's DALa non-discrimatory manner. Verizon stated repeatedly that any standard arrangements or a separate agreement. database, Verizon VA's CNAMshall provide MClm with a complete that would allow a LEC to provide database contains competitivelist of the ILECs, CLECs, and access to any competitor that is information to which WorldComindependent telcos whose subscriber inferior to that enjoyed by the LEC should not have access, as well asinformation is contained in the itself is inconsistent with Congress' information that Verizon VA hasVerizon CNAM database. [Agreed] objective of establishing competition committed to other LECs to not

in all telecommunications markets. provide in a manner other than a per13.6.3 Upon MClm's request, Local Competition Order Til00-105. query basis. In addition, Verizon VAVerizon shall provide via electronic This means that Verizon is obligated has no mechanism in place fordata transfer an initial load of to provide carriers with the same providing a full download. In fact, itsubscriber records contained in its access it provides itself. is unclear whether such a request isCNAM Database. The NPAs even technically feasible. Finally,included must represent the entire WorldCom has requested, and WorldCom has not even proposed toVerizon operating territory in the Verizon's language would prohibit, compensate Verizon VA for suchState. The initial load shall reflect all the transfer of the CNAM database to work.data that is current as of one business MClm as a "batch" file. This batchday prior to the provision date. file would allow MClm to use the WorldCom has presented no evidence

database in exactly the same readily supporting its position which is13.6.4 On a daily basis, Verizon shall accessible manner as Verizon enjoys. unique to it and contrary to acceptedprovide updates (end user and mass) Contrary to Verizon's claim, the fact industry practice.to the CNAM Database information that it dips into its own database,via electronic data transfer. Updates does not make this access the same as UNE Panel - Direct Testimony onmust be current as of one business day that offered to MCIm. This claim Mediation Issues, beginning at 13.prior to the date provided to MClm. ignores the fact that the database

resides in Verizon's own facilities and UNE Panel- Rebuttal Testimony on13.6.5 Verizon shall provide CNAM that it enjoys a level of control and Mediation Issues, beginning at 16.information at cost-based rates as access that MCIm does not (and willrequired by Applicable Law and on not if access is limited to a per dipthe same terms and conditions that basis).Verizon provides to itself, itsAffiliates, or any third party. [Agreed] A download of the CNAM database

would give MClm the same control13.6.6 Verizon shall provide a over the database enjoyed by Verizoncomplete refresh of the CNAM and allow it to use this UNE toinformation upon mutual agreement provision any telecommunicationofVerizon and MClm and subject to service as contemplated under theapplicable charges set forth in Act. Giving MCIm the information in

KEY WHERE DISTINCTION AMONG PETITIONERS IS NECESSARY: WoridCom (bold); Cox (underline text); AT&T (italic).

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Attachment I. a readily accessible format wouldfacilitate the incorporation of the data

13.6.7 Data Processing into MClm's facilities with no dialingRequirements. Verizon and MClm delays.shall mutually agree to standards onthe following data processing Access to the CNAM database andrequirements: access to another call-related

database, the directory assistance13.6.7.1 Identify the type of tape to listing (UDAL") database, should bebe used in sending the test and initial comparable. With respect to DAload data, e.g., reel or cartridge tape. databases, this Commission

specifically found that "LECs must13.6.7.2 Verizon shall, due to the transfer directory assistance databasessize of an initial load, provide the in readily accessible electronic,records on magnetic tape and the magnetic tape, or other formatdaily update activity via electronic specified by the requesting LECs,data transfer. promptly on request." In the Matters

of Implementation of the13.6.7.3 Daily update information Telecommunications Act of 1996,must be provided to MCIm on the Telecommunications Carriers' Use ofsame day as the change occurred Customer Proprietary Networkthrough the electronic data transfer Information and Other Customermedium, NDM. Information, Implementation of the

Local Competition Provisions of the13.6.7.4 Identify tape or dataset label Telecommunications Act of 1996,requirements. Provision of Directory Listing

Information, Third Report and Order13.6.7.5 Identify tracking information in CC Docket No. 96-115, Secondrequirements, e.g., use of header and Order on Reconsideration in CCtrailer records for tracking date and Docket No. 96-98, and Notice oftime, cycle numbers, sending and Proposed Rulemaking in CC Docketreceiving site codes, volume count for No. 99-273 (reI. September 9,1999)the given tape/dataset. (1999 Directory Listing Order) '153.

The Commission specifically held thatLECs may not restrict competitiveaccess to the DA database byrestricting access to per-query accessonly:


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Issue Petitioners' Proposed Contract Verizon's Proposed ContractNo. Statement of Issue Languaee Petitioners' Rationale Laneuaee Verizon Rationale

"Although some competing providersmay only want per-query access to theproviding LEC's directory assistancedatabase, per-query access does notconstitute equal access for acompeting provider that wants toprovide directory assistance from itsown platform. With only per-queryaccess to the providing LECsdatabase, new entrants would incurthe additional time and expense thatwould arise from having to take thedata from the providing LEC'sdatabase on a query-by-query basisthen entering the data into its owndatabase in a single transaction....Such extra costs and the inability tooffer comparable services wouldrender the access discriminatory."1999Directory Listing Order 1 152.

Similarly, the CNAM database is alsoa call-related database andcompetitors' access to this databaseshould not be limited to a per-queryor per-dip basis only. To allow such arestriction to stand allows Verizon todiscriminate against competingcarriers through limited access to theCNAM database, which theCommission has explicitly prohibitedin a similar context - access to theDAL database.

In addition. Verizon garners criticalproprietary and competitiveinformation through the dip process.By requiring dip only access, Verizon


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is able to follow MClm's use of thisdatabase, which reflects competitiveinformation with respect to MClm'soverall service and growth.

From a practical standpoint, requiringMClm to dip Verizon's database oraccess the database on a "per query"basis only, rather than access its owndatabase, forces MClm to incurdevelopment costs associated with acomplex routing scheme withinMClm's UNE platform to providequality service to its customers.Additionally, just as in the case ofdirectory assistance listings, acompetitive carrier may wish toobtain the full database in order toavoid the required dip for each andevery query. For some CLECs suchas MCIm, the cost of obtaining thefull contents of the database andmaintaining its own database may bemore economical than access that isrestricted to a per-dip or per-querybasis. Providing the alternative ofbulk data provides potential costsavings to CLECs.

Allowing full access to the CNAMdatabase means that MCIm has morecontrol over the quality of the serviceit offers. For example, CNAM allowsthe called customer premisesequipment, connected to a switchingsystem via a conventional line, toreceive a calling party's name and thedate and time of the call during thefirst silent interval in the ringing


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Issue Petitioners' Proposed Contract Verizon's Proposed ContractNo. Statement of Issue Lan2Wlee Petitioners' Rationale Lan2Uaee Verizon Rationale

cycle. This is a very limited timeframe within which to determine thename associated with the callingnumber. The time it takes to route thenumber request to the correct LEC'sdatabase to make the dip, return therequest, and provide exceptionhandling when the number is notfound in the database cannot alwaysbe completed within the short ringcycle required. If, however, MClmmaintains its own database, a lengthystep of the process can be eliminated,allowing MClm to provide service atleast as well as Verizon provides foritself.

Not only does limited access to theCNAM database, such as per-queryaccess only, prevent MClm fromcontrolling the service quality andmanagement of the database, but sucha limitation also restricts MClm'sability to offer other innovativeservice offerings that may be providedmore efficiently, quickly, and cheaply.

If MClm could operate its owndatabase to support services for itsend users, it would not be bound byVerizon's restrictions and coulddevelop the capability to offer CNAMdatabase services to other carriers viaother process methods that could bemore efficient and less costly. Forexample, it could offer CNAM overTCP/IP rather than on the costly SS7network.


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Issue Petitioners' Proposed Contract Verlzon's Proposed ContractNo. Statement of Issue LaD2Ua2e Petitioners' Rationale Lan2Ua2e Verlzon Rationale

At least two state PUCs have foundthat the ILEC is obligated to providefull or batch access to the CNAMdatabase in a downloadable format.The state commissions in Michiganand Georgia have ordered that theILECs must provide the CNAMdatabase in a downloadable format.

(Lehmkuhl Direct, 8/17, at 2-9).

Contrary to Verizon's claim, the factthat the CNAM database may containinformation from other LECs does notjustify imposition of an inferior per-dip form of access.

Verizon's assertions regarding thefield information it gathers (numberof lines, etc.) from other CLECs foruse in its CNAM database areirrelevant. If, as Verizon claims, itonly uses this database for theprovision of calling name services, itwould only need to collect and recordthe 15 digit identifier, the automaticnumber identification ("ANI"), andthe privacy indicator. Verizon doesnot indicate why it collects and keepsother extraneous information in itsCNAM database. Verizon should notbe able to use the fact that it collectsthis unused information to preventWorldCom from gainingnondiscriminatory access to theCNAM database. MClm is notinterested in the extraneousinformation Verizon may have


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Issue Petitioners' Proposed Contract Verizon's Proposed ContractNo. Statement of Issue Lan2Ua2e Petitioners' Rationale Lanmaee Verizon Rationale

included in its CNAM database.WorldCom wants onlynondiscriminatory access to the sameCNAM data Verizon uses to providecalling name service to its owncustomers. Only by receiving the datain a downloadable format, andallowing MCIm to create its owndatabase, will MCIm be free to offerthis service in the same manner asdoes Verizon.

Verizon fails to provide any supportfor its claim that it does not have thetechnological ability or processes toprovide a full CNAM download. TheCommission should be skeptical ofthis claim.

The PUCs in Michigan and Georgiahave ordered Ameritech-Michiganand BellSouth respectively to providebatch access to the CNAM database.In response to the Michigan PUC'sOrder. Ameritech Michigan hasalready developed a process by whichthe CNAM database is made availableto other LECs in a bulk format. Thebasic technical parameters for such aprocess are available and thustechnically feasible.

As long as data from other LECs canbe entered into and manipulated in itsCNAM database, that information canjust as easily be extracted. Forexample, once aLEC's contract tostore the CNAM information ends,Verizon must have a means of


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Issue Petitioners' Proposed Contract Verizon's Proposed ContractNo. Statement of Issue Lan2Wl2e Petitioners' Rationale Lan2Ua2e Verizon Rationale

extracting that data from the CNAMdatabase. Verizon has not explainedwhy information cannot be extractedor manipulated by Verizon when ittransfers the full CNAM database toMCIm.

The technical feasibility of offeringthis database in a downloadableformat is not a new phenomenon.Rather, it is obvious from Verizon'stestimony that if Verizon has thecapability of adding and deletingentries in its CNAM database, itshould have the ability to extract thedata for purposes of making theinformation available as a download.

Verizon raised this issue of thetechnical feasibility of providing adatabase via a download during thefirst round of arbitrations in 1996.Verizon claimed that it was nottechnically possible to provide thedirectory assistance database via adownload. Notwithstanding thisclaim, Verizon, then Bell Atlantic,found a way to provide the databasevia a download once it was ordered todo so by the Virginia StateCorporation Commission ("SCC")and other state commissions. In short,the claim regarding technicalfeasibility is not credible.

Contrary to Verizon's claims, batchaccess to CNAM does notcompromise customer proprietaryinformation or safeguards


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Issue Petitioners' Proposed Contract Verizon's Proposed ContractNo. Statement of Issue Language Petitioners' Rationale Laneuage Verizon Rationale

implemented by Verizon to preventmisuse of the database.

(Lehmkuhl Rebuttal, 915, at 2-8)

IV-26 Should the Interconnection Resolved per mediation session on ResolvedAgreement include a detailed 8nlOl by inclusion of language setdescription of the tandem switching forth in John Monroe's notes fornetwork element which Verizon must 8n101.provide on an unbundled basis?

IV-27 Should the Interconnection Resolved per mediation session of ResolvedAgreement contain provisions 8/9/01 by inclusion of single sectionspecifying cooperative testing regarding testing of UNEs.procedures for unbundled networkelements provided under theAgreement and specifying thatprotection, restoration, and disasterrecovery procedures for unbundlednetwork elements will occur at paritywith the procedures for Verizon'sown services, facilities, andequipment?

IV-28 Whether WoridCom should be Verizon shall permit MClm, at The agreement should make clear that Verizon shall provide to **CLEC, in Verizon VA will permit collocation ofpermitted to collocate advanced MClm's discretion, to collocate WorldCom is permitted to collocate accordance with this Agreement advanced services equipment to theservices equipment as mandated by DSLAMs, splitters used in DSLAMs and other advanced services (including, but not limited to, extent required by applicable law.FCC Orders. association with DSLAMs, and equipment necessary for Verizon's applicable Tariffs) and the Section 1 of the

other equipment necessarily located interconnection and unbundling as requirements of Applicable Law, Collocation Attachment to VerizonIs WorldCom entitled to collocate where the copper portion of the mandated by FCC Order. Collocation for the purpose of VA's proposed interconnectionadvanced services equipment, such as loop terminates in order to provide facilitating **CLEC's interconnection agreementDSLAMs, in Verizon's premises? DSL functionality, in Verizon's Collocation of advanced services with facilities or services of Verizon To WorldCom sufficiently provides

premises where the copper portion equipment is critical to a CLEC's or access to Unbundled Network for the collocation of advancedof the loop terminates, in ability to provide services such as Elements of Verizon; provided, that servicesaccordance with the rates, terms DSL service in competition with notwithstanding any other provision Equipment to the extent required byand conditions set forth in the Verizon. of this Agreement, Verizon shall be applicable law. Verizon VA willCollocation Attachment. The obligated to provide Collocation to amend its tariffs to comply with theparties agree to adopt rules to WorldCom's proposed amended **CLEC only to the extent required Commission's new collocation rulesimplement the FCC's Order in contract language specifies that by Applicable Law and may decline resulting from Order 01-204 inFCC Docket No. 98-147 providing DSLAMs and splitters associated with to provide Collocation to **CLEC to Docket 98-147 issued August 8, 2001.


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Issue Petitioners' Proposed Contract Verizon's Proposed ContractNo. Statement of Issue LanJtUa~e Petitioners' Rationale LanJtUa~e Verizon Rationale

for the collocation of multifunction DSLAMs and any other equipment the extent that provision ofequipment where an inability to necessarily located where the copper Collocation is not required by Verizon Advanced Services Paneldeploy that equipment would as a portion of the loop terminates in order Applicable Law. Subject to the Rebuttal Testimony at pages 65-66.practical, economic or operation to provide DSL functionality, can be foregoing, Verizon shall providematter preclude MCIm from collocated in Verizon premises. Collocation to **CLEC in accordanceobtaining interconnection or access Verizon has not filed testimony with the rates, terms and conditionsto unbundled network elements. disputing this language. set forth in Verizon's Collocation

tariff, and Verizon shall do so4.2.3 Verizon shall permit MCIm, at Verizon and WorldCom appear to regardless of whether or not suchMCIm's discretion, to collocate agree to adopt language implementing rates, terms and conditions areDSLAMs, splitters used in association the FCC's Order in Docket No. 98- effective.with DSLAMs, and other equipment 147 providing for the collocation ofnecessarily located where the copper multifunction equipment where anportion of the Loop terminates in inability to deploy that equipmentorder to provide DSL functionality, in would as a practical, economic orVerizon's premises where the copper operational matter precludeportion of the Loop terminates. The WorldCom from obtainingParties agree to adopt rules to interconnection or access toimplement the FCC's Order in FCC unbundled network elements.Docket No. 98-147 providing for the (Goldfarb, Lathrop, Buzacott Direct,collocation of multifunction 7/31 at 34-35).equipment where an inability todeploy that equipment would as a WorldCom's proposed languagepractical, economic, or operational memorializes WorldCom's rightsmatter precludes MCIm from under FCC 98-147 in aobtaining interconnection or access to straightforward non-controversialunbundled Network Elements. fashion.

IV-29 Should the contract language reflect During mediation WorldCom Verizon's 8/31 testimony indicates Resolvedthe FCC's decision to allow access to proposed the following revisions to this issue is resolved. The agreed -toinside wire? WorldCom's proposed language: language which was proposed during

mediation is reproduced herein and at4.1 Definition. Loop means a pages 25-26 of WorldCom's Replytransmission facility between a testimony. (Goldfarb, Lathrop,distribution frame, or its equivalent, in Buzacott, 9/5 Rebuttal, at 25-26).a Verizon central office or wirecenter, and the loop demarcationpoint at an end-user customerpremises, .1. .~ ~


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Issue Petitioners' Proposed Contract Verizon's Proposed ContractNo. Statement of Issue Lan2U8ee Petitioners' Rationale Laneuage Vernon Rationale

by "eHii!aB af aBe af"eriii!aB'SAffiliates. Based on Verizon'sassertion that neither Verizon nor itsAffiliates own any inside wire inVirginia. the Loop does not includeinside wire. The Loop includes allfeatures, functions, and capabilities ofthis transmission facility including,but not limited to, dark fiber, attachedelectronics (except those electronicsused for provision of advancedservices, such as DSLAMs), and lineconditioning. When Verizon providesMCIm with a Loop, MClm will haveexclusive use of this Loop element.The Loop may be used to providemodes of transmission that include,but are not limited to, two-wire andfour-wire analog voice-gradetransmission, and two-wire and four-wire transmission of ISDN, ADSL,HDSL, and DS1, DS3, fiber, andother high capacity signals.

4.3.1 Definition. The Subloop is anyportion of the Loop that isTechnically Feasible to access atterminals in Verizon's outside plant~

Based on Verizon's assertaion thatneither Verizon nor its Affiliates ownany inside wire in Virginia, theSubloop does not include, iBehuliRginside wire. An accessible terminal isany point on the Loop wheretechnicians can access the wire orfiber within the cable withoutremoving a splice case to reach thewire or fiber within, including, but notlimited to, the pole or pedestal, the


267

IssueNo. Statement of Issue

Petitioners' Proposed ContractLanpa2e

NID, the minimum point of entry, thesingle point of interconnection, themain distribution frame, the remoteterminal, and the LoopFeederlDistribution interface.

4.3.3 Verizon shall not interfere withMClm's access to inside wire MGImma} Sl:JtaiR, aRel "eFii3SR shallfJFS iele, assess ts VeAi!SR'S iRsielewire-at any TeshRisal1) l'easil:Jle pointincluding, but not limited to, the NIDQ!; the minimum point of entry,thesiRgle pSiRt sf iRterssRReetisR, thepeelestal, SF the psle. "Inside wire" isall bssfJ plaRt sW-Reell:J} VeAi!SR srSRe sf its Affiliates S8 e8el l:Iserwirefacilities el:lstsmer premises on thecustomer side of the NID, includinginside the customer's premise. as-faf'as the PSi8t sf elemarealis8 elefi8eel i8~eelisR (;8.3 efthe PeC's Riles,insll:leliRg the besp pla8l near the enell:Iser el:lslsmer premises.

4.3.5 In addition to its obligation toprovide Non-Discriminatory access toits Subloops under Section [4.3.2],Verizon shall provide MCIm a singlepoint of interconnection at multi-unitpremises that is suitable for use bymultiple carriers. The Parties shall ingood faith negotiate reasonable termsand conditions regarding a singlepoint of interconnection, including,but not limited to, compensation toVerizon under forward-lookingpricing principles. If suchnegotiations fail to produce a

Petitioners' RationaleVerizon's Proposed Contract

Lan2Ua2e Verizon Rationale


268

Issue Petitioners' Proposed Contract Verizon's Proposed ContractNo. Statement of Issue Lan~a2e Petitioners' Rationale Lan~a2e Verizon Rationale

mutually agreeable solution withinsixty (60) days after one Party'srequest to initiate such negotiations,either Party may seek resolution underthe Dispute Resolution provision ofPart A of this A~eement.

IV-80 Should the Interconnection [During mediation WorldCom Issues IV-80 and IV-81 concern WorldCom: Additional Services Verizon agrees that theAgreement contain provisions proposed the following language WoridCom's request that Directory Attachment § 3 interconnection agreement shouldregarding Directory Assistance regarding customized routing:] Assistance and Operator Services be contain provisions regardingService? provided as unbundled network 3. Directory Assistance (DA) Directory Assistance Service. The

Where Verizon has deployed an AIN elements. These issues also concern and Operator Services provisions offered by WoridCom,capability that allows routing of the provision of customized routing 3.1 Either Party may request that however, are outdated. Section 3 ofOS/DA calls to MClm's FGD trunks, because the Commission's rules the other Party provide the requesting the Additional Services Attachment toor where Verizon uses existing switch provide that OS/DA need not be Party with nondiscriminatory access Verizon's proposed interconnectionfeatures and functions to route OS/DA provided as UNEs ifVerizon provides to the other Party's directory agreement addresses these issuescalls to MCIm's FGD trunks, Verizon customized routing of WorldCom's assistance services (DA), IntraLATA satisfactorily and is in full complianceshall provide customized routing of OS/DA traffic to the Feature Group D operator call completion services with current law.OS/DA calls placed by MClm trunks designated by WorldCom. (OS), and/or directory assistancecustomers to the particular outgoing (Caputo Rebuttal, 9/5, at 7). listings database. If either Party Verizon VA has offered to providetrunks and associated routing tables makes such a request, the Parties shall WoridCom with customized routingdesignated by MClm, using FGD In its 8/17 direct testimony, Verizon enter into a mutually acceptable of OS/DA, including FG-D protocol.protocol, including trunks terminating asserts that there should be no written agreement for such access. Because AIN architecture has actuallyat OS/DA platforms designated by remaining issue because Verizon will 3.2 **CLEC shall arrange, at its been deployed throughout VerizonMClm. Where Verizon has not provide customized routing to the own expense, the trunking and other VA's service territory, there is nodeployed such AIN capability and has Feature Group D trunks designated by facilities required to transport traffic basis to include WorldCom'snot used such existing switch features, WoridCom through the AIN to and from the designated DA and irrelevant language. In fact, the onlyVerizon shall provide OS/DA services architecture available in Verizon OS switch locations. apparent basis for WorldCom'sto MClm as unbundled network VA's service territory. position is its hope to obtain languageelements. In that instance, upon that it would seek to import to anotherrequest by MClm, the Parties shall Verizon's obligations and jurisdiction where AIN architecturenegotiate the terms, conditions, and commitments and WorldCom's rights has not been deployed. WoridComcost-based rates for providing OS/DA should be reflected in the contract should not be permitted to negotiateservices as unbundled network between the parties. The terms that have no application inelements. Interconnection Agreement between Virginia.

the parties should reflect Verizon'sWhere Verizon provides OS/DA commitment to provide customized UNE Panel - Direct Testimony onservices to MClm on a resale basis, routing to the Feature Group D trunks Mediation Issues, beginning at 16.Verizon shall provide such services at designated by WorldCom through theParity and on a non-discriminatory AIN architecture available in Verizon UNE Panel - Rebuttal Testimony on


269

Issue Petitioners' Proposed Contract Verizon's Proposed ContractNo. Statement of Issue Lan".a2e Petitioners' Rationale Lan".age Verizon Rationale

basis. VA's service territory. The Mediation Issues, beginning at 30.Interconnection Agreement should

[The following paragraphs are also include terms which provide forproposed to reflect the attributes of the customized routing of OSIDADA Services where customized traffic to the Feature Group D trunksrouting is not provided.] designated by WorldCom through

means other than AIN, in the event6.1.3 Directory Assistance Service the AIN method becomes unavailable.

The Interconnection Agreement6.1.3.1 Verizon shall provide for the should also include a term providingrouting of Directory Assistance calls that DAlOS is available as a UNE in(including but not limited to 411, 555- the event that Verizon is unable to1212, NPA-555-1212) dialed by provide the required customizedMCIm subscribers directly to either routing. (Caputo Rebuttal, 9/5, at 7-the MCIm Directory Assistance 8).service platform or Verizon DirectoryAssistance service platform as Terms to memorialize these mattersspecified by MCIm. were offered during mediation and are

reproduced here. Also included are6.1.3.2 MCIm subscribers shall be terms describing OSIDA which willprovided the capability by Verizon to only apply in the event the customizeddial the same telephone numbers for routing specified above is notaccess to MCIm Directory Assistance provided.that Verizon subscribers are providedto access Verizon Directory The Caputo Direct testimony, 8/17, atAssistance. pages 10-20 contains a complete

discussion of the customized routing6.1.3.3 IfMCIm purchases from sought by WorldCom and required byVerizon MCIm-branded Directory the Commission's regulations.Assistance service selectively routed Included within the testimony areto Verizon's Directory Assistance discussions of Verizon's obligationplatform, MCIm shall give Verizon pursuant to the Commission's ordersprior written notice before terminating to provide customized routing to thethat arrangement by selectively Feature Group D trunks designated byrerouting Directory Assistance traffic WorldCom; the importance ofto another Directory Assistance satisfactory customized routing; theplatform. technical feasibility of the customized

routing proposed by WorldCom; the6.1.3.3.1 Verizon aJ?rees to provide technology used to provide


270

Issue Petitioners' Proposed Contract Verizon's Proposed ContractNo. Statement of Issue Laneuaee Petitioners' Rationale Lan2uage Verizon Rationale

MCIm subscribers with Directory customized routing; previous testingAssistance service at Parity. and use of customized routing by

WorldCom; the efficient routing of6.1.3.3.2 Verizon shall notify MClm OSIDA traffic using the customizedin advance of any changes or routing required by WorldCom; andenhancements to its Directory the provision of Feature group DAssistance service, and shall make signaling as part of customizedavailable such service enhancements routing. (Caputo Direct, 8/17, at 10-at Parity and on a Non-Discriminatory 20).basis with respect to other CLECs.

6.1.3.3.3 Verizon shall provideDirectory Assistance to MClmsubscribers in accordance withindustry standards. Verizon shallnotify MClm in advance of anychanges or enhancements to itsDirectory Assistance service, andshall make available to MClm suchservice enhancements on anondiscriminatory basis.

6.1.3.3.4 Verizon shall provideMCIm with provisioning of DirectoryAssistance at Parity.

6.1.3.3.5 Service levels shall comply,at a minimum, with applicable stateregulatory requirements, includingthose for number of rings to answerand disaster recovery options.

6.1.3.3.7 Verizon shall provide thefollowing minimum DirectoryAssistance capabilities to MClm'ssubscribers:

6.1.3.3.7.1 Verizon shall provide toMClm subscribers seeking Directory


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Issue Petitioners' Proposed Contract Verizon's Proposed ContractNo. Statement of Issue Lan2Uaee Petitioners' Rationale Lan2Ua2e Verizon Rationale

Assistance the same number ofresponses and detail of infonnationthat it provides its own subscribers.

6.1.3.3.7.2 Upon request bysubscriber, call completion to therequested number for local andintraLATA toll calls shall be returnedto the MClm network. Rating andbilling shall be done by MClm.

6.1.3.3.7.2.1 Upon MClm's requestand if Technically Feasible, Verizonshall provide blocking of DirectoryAssistance call completion on an ANIspecific basis.

6.1.3.3.7.3 Verizon shall populateMClm listings in the DirectoryAssistance database in the samemanner and in the same time frame asit does for Verizon subscribers.

6.1.3.3.7.4 Any infonnation providedby a Directory Assistance automaticresponse unit shall be repeated thesame number of times for MClmsubscribers as for Verizonsubscribers.

6.1.3.3.7.5 Verizon shall instructMClm subscribers to call a toll freenumber for MClm customer service torequest a credit. Verizon shallprovide one toll free number forbusiness subscribers and another forresidential subscribers.

IV-81 Should the Interconnection [During mediation WorldCom See IV-80. See IV-80 See Verizon's position on Issue IV-Agreement contain provisions proposed the following language 80.


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regarding Operator Services ("OS")? regarding customized routing:]

Where Verizon has deployed an AINcapability that allows routing ofOS/DA calls to MCIm's FGD trunks,or where Verizon uses existing switchfeatures and functions to route OS/DAcalls to MCIm's FGD trunks, Verizonshall provide customized routing ofOS/DA calls placed by MCImcustomers to the particular outgoingtrunks and associated routing tablesdesignated by MCIm, using FGDprotocol, including trunks terminatingat OS/DA platforms designated byMCIm. Where Verizon has notdeployed such AIN capability and hasnot used such existing switch features,Verizon shall provide OS/DA servicesto MCIm as unbundled networkelements. In that instance, uponrequest by MCIm. the Parties shallnegotiate the terms, conditions, andcost-based rates for providing OS/DAservices as unbundled networkelements.

Where Verizon provides OSIDAservices to MCIm on a resale basis,Verizon shall provide such services atParity and on a non-discriminatorybasis.

[The following paragraphs areproposed to reflect the attributes ofOS where customized routing is notprovided.]

6.1.4 Operator Services


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6.1.4.1 Verizon shall provide for therouting of 0+ local, 0- and operatortransfers for local Operator Servicescalls dialed by MClm subscribersdirectly to either the MClm OperatorService platform or Verizon OperatorService platform as specified byMClm and pursuant toAttachment III, Section [7.2.2].

6.1.4.2 MClm subscribers shall beprovided the capability by Verizon todial the same telephone numbers toaccess MClm operator service thatVerizon subscribers dial to accessVerizon Operator Service.

6.1.4.3 IfMClm purchases fromVerizon MClm-branded OperatorServices selectively routed toVerizon's Operator Services platform,MClm shall give Verizon priorwritten notice before terminating thatarrangement by selectively reroutingOperator Services traffic to anotherOperator Services platform.

6.1.4.3.1 Verizon agrees to provideMCIm subscribers Operator Servicesand service enhancements at Parityand on a Non-Discriminatory basis.

6.1.4.3.3 Verizon shall provide thefollowing minimum Operator Servicecapabilities to MClm subscribers atParity.

6.1.4.3.3.1 Completion of 0+ and 0-


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dialed local calls~

6.1.4.3.3.2 Completion of 0+intraLATA toll calls~

6.1.4.3.3.3 Completion ofcalls thatare billed to a calling card, with theexception of calls billed to proprietarycards, and MClm shall designate toVerizon the acceptable types ofspecial biIIing~

6.1.4.3.3.4 Completion of person-to-person calls;

6.1.4.3.3.5 Completion of collectcalls~

6.1.4.3.3.6 The capability for callersto bill to a third party and completesuch calls;

6.1.4.3.3.7 Completion of station-to-station calls~

6.1.4.3.3.8 The processing ofemergency calls~

6.1.4.3.3.9 The processing of LineStatus Verification and Verificationand Call Interrupt requests;

6.1.4.3.3.10 The processing ofoperator-assisted Directory Assistancecalls;

6.1.4.3.3.11 Provision of rate quotes;

6.1.4.3.3.12 The processing of time-


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and-charges requests; and

6.1.4.3.3.13 The routing of 0- trafficdirectly to a "live" operator team.

6.1.4.3.3.14 When requested byMCIm and commencing onavailability, Verizon shall providewhen Technically Feasible, credit onOperator Services calls as provided toVerizon subscribers or shall instructMCIm subscribers to call a toll freenumber for MCIm customer service torequest a credit. Verizon shallprovide one toll free number forbusiness subscribers and another forresidential subscribers.

6.1.4.3.3.15 Caller assistance for thedisabled; and

6.1.4.3.3.16 Provision of operator-assisted conference calling, whenTechnically Feasible.

6.1.4.3.3.17 Verizon shall accept andprocess overflow 911 traffic routedfrom MCIm to its Verizon OperatorServices platform without charge.

6.1.4.4 Operator Service shallprovide to the extent TechnicallyFeasible MCIm's local service rateswhen providing rate quote and time-and-charges services when brandingMCIm services pursuant toSection [6.1.4.3.2].

6.1.4.5 Verizon shall exercise at least


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the same level of fraud control inproviding Operator Service to MCImthat Verizon provides for its ownOperator Service.

6.1.4.6 Verizon shall perform billednumber screening when handlingcollect, third party, and calling cardcalls, both for station-to-station andperson-to-person call types.

6.1.4.7 Verizon shall refer subscriberaccount and other similar inquiries tothe subscriber service centersreasonably designated in advance byMClm from time to time.

6.1.4.8 Line Status Verification andCall Interrupt (LSV/CI)

6.1.4.8.1 Verizon shall permit MCImto connect its local Operator Serviceto Verizon's LSV/CI systems toenable MCIm to perform BLVlBLIservices.

6.1.4.8.2 Verizon shall engineer itsLSVlCI facilities to accommodate theanticipated volume of BLVIBLIrequests during the busy hour. MCImmay, from time to time, provide itsanticipated volume of BLVIBLIrequests to Verizon. In thoseinstances when the LSV/CI systemsbecome unavailable, Verizon shallinform MClm as soon as practicable.

6.1.4.9 Where LNP is deployed andwhen a BLVIBLI request for a ported


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number is directed to a Verizonoperator and the query is notsuccessful (Le., the request yields anabnormal result), the operator shall ifTechnically Feasible confirm whetherthe number has been ported and shalldirect the request to the appropriateoperator.

6.1.4.10 Verizon shall allow MClmto order provisioning of telephoneline number (TLN) calling cards andbilled number screening (BNS), in itsLIDB, for ported numbers, as agreedby the Parties. Verizon shall continueto allow MClm reasonable access toits L1DB for this purpose.

V-3 UNE-P Routing and Billing. Should The issue is the same as issue VA.a. This issue is the same issue VA.a. 5.7 Reciprocal Compensation Reciprocal Compensation should notreciprocal compensation provisions Please refer to the AT&Tcontract Please refer to the AT&T rationale for Arrangements -- Section 251(b)(5) apply to all traffic originating from anapply between AT&Tand Verizon for language for that issue. that issue. AT&T UNE-P customer and anotherall traffic originating from UNE-P 5.7.1 Reciprocal Compensation third-party facilities based CLEC.customers ofAT&Tand terminating arrangements address the transport AT&T is seeking to substituteto other retail customers in the same and termination of Local Traffic over reciprocal compensation for theLATA, andfor all traffic terminating the terminating carrier's switch in transit traffic charges that Verizonto AT&T UNE-P customers accordance with Section 251 (b)(5) of levies upon AT&T for the transitoriginated by other retail customers the Act. Verizon's delivery of Local services Verizon provides AT&T.in the same LATA? Traffic to AT&T that originates with Reciprocal compensation and

a third party carrier is addressed in compensation for transit traffic areSection 7.2. Where AT&T delivers meant to compensate LECs for twoany traffic originating with a third different services. Under AT&T'sparty carrier to Verizon, except as proposal, it is unclear exactly howmay be set forth herein or Verizon will be "compensated" bysubsequently agreed to by the Parties, paying reciprocal compensation forAT&T shall pay Verizon the same calls made and received by AT&T'samount that such third party carrier UNE-P customers. Currently, thewould have paid Verizon for OBF is developing a database thattermination of that traffic at the will enable carriers to determine thelocation the traffic is delivered to proper originating and terminatingVerizon by AT&T. Compensation for parties when Verizon provides transit


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Issue Petitioners' Proposed Contract Verizon's Proposed ContractNo. Statement of Issue Lan2Ual!e Petitioners' Rationale Lan2Uaee Verizon Rationale

the transport and termination of traffic services for AT&T and third-partynot specifically addressed in this facilities based LECs. Until it does,Section 5.7 shall be as provided however, AT&T's proposal onlyelsewhere in this Agreement, or, if not simplifies billing matters for AT&T.so provided, as required by the Tariffs Finally, AT&T seeks to use a bill andof the Party transporting and/or keep system selectively, only when itterminating the traffic. benefits AT&T. Under Verizon's

proposal each Party is fairly5.7.2 Nothing in this Agreement compensated.shall be construed to limit eitherParty's ability to designate the areas In all events, the entire spectrum ofwithin which that Party's Customers intercarrier compensation is fullymay make calls which that Party rates before the Commission in CC Docketas "local" in its Customer Tariffs. No. 01-92 In the Matter of

Developing ofa Unified Intercarrier5.7.3 The Parties shall compensate Regime in which a Notice ofeach other for the transport and Proposed Rulemaking was issued ontermination of Local Traffic in a April 27, 2001. The Commissionsymmetrical manner at the rates made it clear in the Status Conferenceprovided in the Detailed Schedule of that it was "disinclined" to addressItemized Charges (Exhibit A hereto), issues under consideration in otheras may be amended from time to time pending dockets (Status Conferencein accordance with Exhibit A and Tr. at 46) and this issue will get a fullSection 20 or, if not set forth therein, airing in that proceeding. Moreover,in the applicable Tariff(s) of the a "bill and keep" compensationterminating Party, as the case may be. scheme for a single type of traffic, asThese rates are to be applied at the advocated by AT&T, would be aAT&T-IP for traffic delivered by piecemeal implementation of aVerizon, and at the Verizon-IP for significant change in intercarriertraffic delivered by AT&T. Except as compensation and a pre-emptiveexpressly specified in this Agreement, volley into the pending rulemaking inno additional charges, including port CC Docket No. 01-92. This issueor transport charges, shall apply for should be deferred, pending thethe termination of Local Traffic Commission's full examination of thedelivered to the Verizon-IP or the issues in CC Docket No. 01-92.AT&T-IP by the other Party. WhenLocal Traffic is terminated over the UNE Panel--Direct Testimony onsame trunks as Toll Traffic, any port Non-Mediation Issues beginning ator transpOrt or other applicable access 33.


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charges related to the delivery of TollTraffic from the IP to an end user UNE Panel--Rebuttal Testimony onshall be prorated to be applied only to Non-Mediation Issues beginning atthe Toll Traffic. The designation of 31.traffic as Local or Non-Local Trafficfor purposes of ReciprocalCompensation shall be based on theactual originating and terminatingpoints of the complete end-to-endcommunication.

5.7.4 No ReciprocalCompensation shall apply to InternetTraffic. If the amount of traffic(excluding Toll Traffic) that Verizondelivers to AT&T exceeds twice theamount of traffic that AT&T deliversto Verizon as Local Traffic ("2: 1ratio"), then the amount of traffic thatVerizon delivers to AT&T in excessof such 2: 1 ratio shall be presumed tobe Internet Traffic and shall not besubject to Reciprocal Compensation.

5.7.5 Transport and termination ofthe following types of traffic shall notbe subject to the ReciprocalCompensation arrangements set forthin this Section 5.7, but instead shallbe treated as described or referencedbelow:

5.7.5.1 No ReciprocalCompensation shall apply tospecial access, private line, orany other traffic that is notswitched by the terminatingParty.


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5.7.5.2 IntraLATA intrastatealternate-billed calls (e.g.,collect, calling card, and third-party billed calls originated orauthorized by the Parties'respective Customers in Virginia)shall be treated in accordancewith an arrangement mutuallyagreed to by the Parties.

5.7.5.3 Switched ExchangeAccess Service and InterLATAor IntraLATA Toll Traffic shallcontinue to be governed by theterms and conditions of theapplicable federal and stateTariffs and, where applicable, bya Meet-Point Billing arrangementin accordance with Section 6.3.

5.7.5.3.1 At suchtime that the Parties reachagreement upon a mutuallyacceptable settlementprocess, the originating Partywill receive a credit forreciprocal compensation inthose instances:

(i) where IntraLATA 8YYToll Traffic calls aretranslated by the originatingParty prior to delivery bythat Party of such traffic tothe terminating Party, and

(ii) where theterminating Party bills theoriginating Party Reciprocal


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Compensation in error forsuch IntraLATA 8YY TollTraffic; and

(iii) where theoriginating Party providesappropriate records to theterminating Party tosubstantiate eachrequSubsequent to theEffective Date of thisAgreement, the Parties shallnegotiate a mutuallyacceptable settlementprocess for reciprocalcompensation credits inaccordance with this Section5.7.7.3.1.

7.2 Tandem Transit TrafficService ("Transit Service")

7.2.1 Transit Service providesAT&T with the transport of TandemTransit Traffic as provided below.Neither the originating norterminating Customer is a CustomerofVerizon.

7.2.2 Transit Traffic may berouted over the Traffic ExchangeTrunks described in Sections 4 and 5.AT&T shall deliver each TransitTraffic call to Verizon with CCS andthe appropriate TransactionalCapabilities Application Part(''TCAP'') message to facilitate fullinteroperability of those CLASSFeatures supported by Verizon and


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Documents

Issue Petitioners' Proposed Contract Verizon's Proposed Contract