Embed Size (px)
Citation preview
2433
STATE OF MICHIGAN
BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION
In the matter, on the Commission's own motion, to consider AMERITECH MICHIGAN'S compliance with the competitive checklist in Section 271 Case No. U-12320 of the federal Telecommunications
Act of 1996. _____________________________________/
Proceedings had in the above-entitled
matter at the Michigan Public Service Commission, 6545
Mercantile Way, Lansing, Michigan.
SESSION OF WEDNESDAY, JUNE 7, 2000
VOLUME 17
- - -
BEFORE: THOMAS LONERGAN, Director MPSC Communications Staff
JOHN KERN, Facilitator
PARTICIPANTS
MPSC
ANN SCHNEIDEWIND, MPSC Communications Staff
2434
AMERITECH MICHIGAN
TERRY APPENZELLER, Vice President, Long Distance Compliance CRAIG ANDERSON, Legal ERIN GRAVELYN, Legal KELLY FENNELL, Director SUSAN FRENTZ, Director - Regulatory YVETTE PUGH
JOHN LENAHAN JOE ROGERS, SBC RICK DISHMAN JOE MAGIERA DONALD CALAMIA TIM GILLES ROBIN GLEASON
AT&T COMMUNICATIONS
TIM CONNOLLY JOANNE SAMONEK DAVE CHORZEMPA
CORECOMM
THOMAS O'BRIEN
WORLDCOM
JAMES R. DENNISTON, Legal KAREN A. COLEMAN SHERRY LICHTENBERG KATHY WILSON
NEXTLINK
TRUDI SEIDL ADAM GILBERT, via telephone
2435
CORECOMM
THOMAS O'BRIEN
RHYTHMS NETCONNECTIONS CLEC ASSOCIATION OF MICHIGAN McLEOD USA
LELAND ROSIER, CLEC Association, Legal, via telephone NORM OSLAND, McLeodUSA, via telephone CRAIG BROWN, Rhythms
HORIZON TELECOMMUNICATIONS, INC.
RICK GOULD, Regulatory
KPMG
JOHN ERINGIS, Senior Manager
CARLA MORREALE EUGENE GORFIN ANDREW WALKER
ATTORNEY GENERAL
ORJIAKOR ISIOGU, Assistant Attorney General
- - -
2436
1 Lansing, Michigan
2 Wednesday, June 7, 2000
3 8:50 A.M.
4 - - -
5 (The proceedings were resumed pursuant to
6 the adjournment.)
7 MR. KERN: Are we ready to begin? I'm
8 sorry for the slight delay this morning. We're trying to
9 get the test scenarios out. I sent them out by e-mail
10 this morning, but they're in a zip drive, so for those of
11 you who cannot open a zip file, we are reproducing them
12 here in hard copy, and so that's the cause of the slight
13 delay.
14 This morning what I'd like to do is we need
15 to talk about volume testing, all the issues associated
16 with volume testing including Issue 31, which I think is
17 an Ameritech issue.
18 We also need to talk about how we here in
19 Michigan want to handle the unresolved A-to-Y issues,
20 which are the LSOG 4 functionalities generally and the GUI
21 interfaces.
22 We also need to have -- when Rhythms shows
23 up, we'll go back to the matrix, we'll make sure that
24 their issues are covered, and ATT if they had any open
25 issues from their last page, we can cover those at that
2437
1 time as well.
2 And we will conclude with a short
3 discussion on what's going to happen on June 13th and
4 14th, and we will be out of here by 3:00 o'clock today.
5 So anybody else have anything to open with?
6 MS. SCHNEIDEWIND: John, we might also want
7 to spend just a couple minutes talking about Craig
8 Anderson's proposal of yesterday on how to deal with the
9 line sharing and those other tariffs.
10 MR. LONERGAN: Before you start, I'll just
11 make a comment.
12 KPMG and the staff at Ameritech have been
13 working on the contract and will fairly soon have what I
14 guess we'd call a final draft, and I think there was an
15 agreement way back when that we would circulate that to
16 the collaborative to look at. So we're getting close.
17 Our goal is to have the contract done
18 simultaneously with the master test plan. I think we're
19 on track to do that.
20 MR. APPENZELLER: John, before we conclude
21 today it would be good, I think, to conclude as to how far
22 along we are to getting the master test plan done and what
23 the next steps are beyond that I would think would be a
24 good conclusion.
25 MR. KERN: O.K. That's a good point.
2438
1 MR. APPENZELLER: And KPMG can lead us
2 through what the next steps are from their perspective,
3 because I assume they're going to have to work with HP,
4 and when can we really start some of the functionality
5 testing and other pieces of the test and that kind of
6 thing.
7 MR. KERN: Before we begin, let's have a
8 quick round of introductions, and then we'll go to the
9 conference bridge and see who's on the bridge, and then
10 we'll start with volume testing.
11 MR. ERINGIS: John Eringis, KPMG
12 Consulting.
13 MR. WALKER: Andy Walker, KPMG Consulting.
14 MR. GORFIN: Eugene Gorfin, KPMG
15 Consulting.
16 MS. MORREALE: Carla Morreale, KPMG
17 Consulting.
18 MR. ROGERS: Joe Rogers, Ameritech.
19 MR. DISHMAN: Rick Dishman, Ameritech.
20 MR. APPENZELLER: Terry Appenzeller,
21 Ameritech.
22 MR. LENAHAN: John Lenahan, Ameritech.
23 MR. ANDERSON: Craig Anderson, Ameritech.
24 MS. COLEMAN: Karen Coleman, WorldCom.
25 MS. WILSON: Kathy Wilson, WorldCom.
2439
1 MS. LICHTENBERG: Sherry Lichtenberg,
2 WorldCom.
3 MR. DENNISTON: Jim Denniston, WorldCom.
4 MS. SEIDL: Trudi Seidl, Nextlink.
5 MS. SCHNEIDEWIND: Ann Schneidewind,
6 Commission staff.
7 MR. LONERGAN: Tom Lonergan, ditto.
8 MR. CHORZEMPA: Dave Chorzempa, AT&T.
9 MR. CONNOLLY: Tim Connolly, AT&T.
10 MS. SAMONEK: Joanne Samonek, AT&T.
11 MR. O'BRIEN: Tom O'Brien, CoreComm.
12 MS. GRAVELYN: Erin Gravelyn, Ameritech.
13 MS. PUGH: Yvette Pugh, Ameritech.
14 MR. CALAMIA: Don Calamia, Ameritech.
15 MS. GLEASON: Robin Gleason, Ameritech.
16 MS. FENNELL: Kelly Fennell, Ameritech
17 Michigan regulatory.
18 MR. MAGIERA: Joe Magiera, Ameritech.
19 MR. GILLES: Tim Gilles, Ameritech.
20 MR. ISIOGU: Orji Isiogu, Michigan Attorney
21 General.
22 MR. GILBERT: Adam Gilbert, Nextlink.
23 MR. ROSIER: Leland Rosier, CLEC Association.
24 MR. OSLAND: Norm Osland, McLeod USA.
25 MR. KERN: O.K. Thank you. How do you
2440
1 want to handle the volume issues? Do you want to go back
2 to the matrix or do we want to talk about -- as I recall,
3 one of the open issues that we had was, does the stress
4 test occur, is it in off-peak hours or in normal business
5 hours? That was one issue that was in dispute. But how
6 do we want to handle the volume issue in general? Is
7 there a good way of handling it?
8 MS. LICHTENBERG: This is Sherry
9 Lichtenberg.
10 We could perhaps start with a proposal for
11 when the volume test should -- for how we can determine
12 the volumes themselves. One of the first discussion
13 issues we have was what volumes and how we come to those
14 numbers, and WorldCom would like to make a proposal on
15 that which would include the point in time at which we
16 would forecast.
17 I think from there once we have the how
18 will the test be handled, we could move on to the issue of
19 when do we do stress, is it during production or non-
20 production.
21 If that's acceptable, I can move forward
22 with a proposal.
23 WorldCom would suggest that since UNE-P and
24 the ability to bill and provision it are key to this
25 process, that we would have CLECs forecast by product type
2441
1 for a period 18 months out from the October date of the
2 shared transport and the ability to bill UNE-P using
3 standard CABS billing is made available.
4 So it would be October plus 18, would be
5 the volumes -- the date on which CLECs would forecast
6 volumes.
7 So that would show how we got the full ramp
8 volumes. We could assume that CLECs would begin to market
9 at that, beginning in 18 months the volumes would hit
10 their peak.
11 MR. ROGERS: The volumes within 18 months,
12 we would be at full open market volumes.
13 MS. LICHTENBERG: I think we would make
14 that assumption for purposes of the testing. It's what we
15 have done in other states. I think the issue is picking
16 the start date.
17 I ask, can KPMG help? Does that work for
18 you all, or would you have a counter-proposal?
19 MR. ERINGIS: I don't think at this time we
20 have a counter-proposal of a specific date in the future.
21 This has obviously been an issue that's
22 gotten a lot of attention in all of the jurisdictions
23 where testing has taken place, and I think at least from
24 what I have learned, I would rather be directed into what
25 date everyone can agree to as opposed to speculating on
2442
1 what is a good date.
2 I think everyone should recognize that's a
3 very difficult question. There's been argument to be made
4 for a date earlier, because one could say that this 18-
5 month -- 18 months after October 2000, it's been argued
6 that no one really knows what it's going to be like at
7 that time, that the peak may happen well before that. The
8 peak may be much higher than the people anticipated.
9 But I think that there are -- you know, the
10 argument to say that, well, then let's find a time frame
11 that's much closer to today. There's a whole other set of
12 arguments which have been made as well, so I really don't
13 have any other input in addition to the arguments that
14 have been made, just wish to point out that they have been
15 made, and we just need to pick a date.
16 MR. LONERGAN: Can you just give us sort of
17 a range of what some of the other states you have worked
18 with have selected?
19 MR. ERINGIS: I think it's been, an
20 argument has been, you know, sort of the six to 18 months
21 out, has been what's been considered.
22 And again, the process that generally
23 worked where there's a forecast provided, that forecast is
24 then analyzed, and we come up with a product mix and come
25 up with a volume test. I mean, it's a simulation, so we
2443
1 have to take the input from all the parties and make an
2 educated guess on our own part. The forecasts don't -- to
3 the extent that I have been involved in it and those,
4 Carla, you have been involved in analyzing some of these
5 forecasts as well, I can say that when you go through what
6 the industry's pulled together, it's, you know, that
7 forecast doesn't assemble really nice and neat and the
8 numbers don't all fall out into something you say, O.K.,
9 here's a good volume test. We will just implement this.
10 So there are a lot of factors that need to
11 be considered in order to make an educated guess as to
12 what the makeup of the volume test should be.
13 And that's what it is. It's really as much
14 art as it is science.
15 We feel comfortable that as long as we are
16 getting a lot of input and we understand the various
17 perspectives and we understand what people think what
18 their business plan is and we think it's going to happen
19 in the future, as long as we have a lot of information to
20 work with, we are in a better position to make those, to
21 make those guesses and we historically also -- I think my
22 final comment is that we have worked with the commissions
23 very closely and others to make sure that, you know, we
24 are putting together something that everybody says, yeah,
25 O.K., this is, this generally looks like it will work.
2444
1 MR. ROGERS: John, what type of validation
2 is done to say, you know, three carriers all think that
3 they are going to get 40 percent of the market in six
4 months?
5 MR. ERINGIS: It's very difficult to do
6 that. But when you point out the example that you just
7 pointed out, you can do the math and figure out that there
8 literally aren't enough customers to go around when you
9 put together every company's customers. So those are
10 actually easier. It's when that doesn't happen that you
11 have to make some guess as to what will happen.
12 I think we are in a better position today
13 than we were in the past, because we have some experience
14 from New York. And so we can, we can see now what's
15 happened in the past and validate against that. But as I
16 said before, this is as much an art as science.
17 There is a validation. It's like I think
18 you have said a few times, in New York, pretty much
19 sending open market volumes, you are at a -- if you were
20 to say New York's population is this and Ameritech's this,
21 it syncs up to say yeah.
22 MS. LICHTENBERG: We also have some volumes
23 now for WorldCom at least in Texas that we can provide
24 under confidentiality to KPMG to also sync against it.
25 It's not open yet. It's beginning, so you
2445
1 can see how the beginning of the ramping goes and how long
2 it takes if we compare to New York to hit that peak.
3 MR. ANDERSON: Craig Anderson.
4 John, do you have thoughts on what that
5 process you would anticipate for that validation? Would
6 you make a first stab at it and then share it with the
7 collaborative, and we discuss it? How would that work?
8 MR. ERINGIS: I think that we would like to
9 consider ways to do that. Again, we haven't done this in
10 a collaborative setting. I think that, you know,
11 pulling -- after we pull the forecasts together, that this
12 has generally been something that's done in confidence,
13 because we think it really -- it needs -- we need to
14 preserve the blindness of the test. But we recognize that
15 having, you know, more, a few more sets of eyes other than
16 outside, you know, KPMG to look at some things as
17 valuable. So we are open to suggestion about that right
18 now.
19 I'm not sure we -- after we get through
20 getting forecasts that we want to take that information
21 and circulate it. I certainly don't feel as though we are
22 going to have permission from anyone to take the forecasts
23 they submit to us and compile those and circulate them.
24 So we're sort of looking into some suggestions from the
25 collaborative here if anyone has any thoughts. But I
2446
1 think it's a difficult problem. I think you have to trust
2 that we are going to take the information and we are going
3 to validate it and we are going to come up with a volume
4 test that's reasonable. Again, we have done this in the
5 past. You can take a look at what we came up with in New
6 York. We have done this in Massachusetts. Pennsylvania.
7 I mean it's --
8 MR. ANDERSON: Is it your thought that
9 Ameritech would not be able to see the final result that
10 you come up with as to what the aggregate volume would be
11 because of the blindness concerns, but would Ameritech
12 perhaps be able to see the individual carrier's forecasts
13 even though on a confidential basis? I mean, that's the
14 kind of information carriers may typically share with
15 Ameritech anyway pursuant to their interconnection
16 agreements.
17 MS. LICHTENBERG: MCI WorldCom objects
18 strongly to that. We will not be sharing our forecast
19 with Ameritech. We will be providing it under
20 confidentiality to KPMG and to the Commission and will be
21 requesting that it be lumped together, if you will, with
22 all the other forecasts.
23 We do not provide forecasts to ILECs in a
24 residential environment, period.
25 MR. ANDERSON: Would then you anticipate
2447
1 that before KPMG made some look at what it would say for
2 the overall forecast to use for the test, that Ameritech
3 would be able to see the aggregate, Sherry? Does that
4 address your concern?
5 MS. LICHTENBERG: Neither Ameritech nor the
6 CLECs should see any forecast information until after the
7 test is concluded. It should be totally blind to both of
8 us so that there is no idea that anybody could have done
9 something with it, Craig. I think the point is it's blind
10 to all of us. We provide our data. I don't see AT&T's or
11 CoreComm's or anyone else's. You see nothing. Afterwards
12 KPMG reports "This is how many we sent and this is what
13 happened."
14 MR. ANDERSON: Then I guess given that, at
15 what point in the process is there a sanity check where
16 somebody has the ability to say, you know, those examples
17 are extreme of 40 percent each, but, you know, if it was
18 something less than that but somebody still felt it was
19 excessive or extreme, is that purely staff's role?
20 MR. ERINGIS: That's what we've done in the
21 past. Again, we employ people that know how to do this
22 and we have traditionally done it with the Commission.
23 We're not objecting to considering any other options that
24 people want to bring to the table about how to validate
25 it, because I'm not going to sit here and disagree with
2448
1 the assertion that, you know, some other experts to take a
2 look at this forecast who would not be compromised would
3 help the process. But I'm not sure how to implement that.
4 MS. LICHTENBERG: I think one of the things
5 we could do -- and I'm not sure if we've done it in other
6 states -- when my team puts together its forecast, we put
7 together a set of assumptions that are the assumptions we
8 use for market entry, because we do do some internal
9 forecasting as well. We could provide those assumptions
10 to KPMG along with our numbers, and the other CLECs could
11 do as well, and that would help with the sanity check.
12 For instance, if I said I'm going to
13 capture 100 percent of the market, KPMG could say, "No,
14 Sherry's really stretching here; she's really only going
15 to get 76 percent."
16 MR. ROGERS: The same 76 percent that AT&T
17 is going to get.
18 MS. LICHTENBERG: That's right, absolutely.
19 MR. LONERGAN: I guess from my point of
20 view staff would clearly wish to be involved in seeing
21 what KPMG's come up with. I think one way we could try to
22 verify would be to check to see what some of the other
23 states are doing simultaneously or in advance of what
24 we're doing. You know, that's kind of a benchmark that
25 we're on the right track.
2449
1 But I think probably I'm hearing a lot of
2 opposition to sharing this information, and I think
3 arguably that makes sense. In a competitive environment
4 you don't necessarily want to share your market forecasts.
5 I think this is one where, you know, you
6 have to kind of rely on KPMG, who has some experience,
7 will have more by the time we're doing this. Staff will
8 take an active role and consult with staff in New York and
9 Pennsylvania and the other states where this is going on
10 to make sure we're on a similar track.
11 MR. ROGERS: I just want to make sure that
12 this is a five-state forecast, because it is the same
13 systems in most cases.
14 MS. LICHTENBERG: I would suggest that the
15 requests that KPMG make be on a state-by-state basis and
16 then they can up it, but that obviously CLECs might be
17 proposing different forecasts per state.
18 MR. ROGERS: Right. I mean Tom may want to
19 check with other state commissions, too, whether they
20 think that's valid for their state.
21 MS. LICHTENBERG: What I do want to be
22 careful with, since we have not, I believe, agreed to do a
23 regional test here, that what we are looking at are purely
24 volumes that at some point in time when there is full
25 competition in all states will run into what Ameritech has
2450
1 stated is a single interface, and that while it is
2 possible, but highly unlikely, that Ameritech will
3 immediately pass the volume test, since the transactions
4 themselves will be Michigan transactions, that passing
5 grade will not necessarily say that Ohio or Wisconsin
6 actual transactions with actual Ohio and Wisconsin CILLI
7 codes and TNs would also pass successfully. So that we
8 are talking purely volume, we are not talking that the
9 specific transactions all work simultaneously.
10 MR. ROGERS: I have a little bit of concern
11 with that. How would it validate -- the Michigan would
12 actually be taking -- there would be more volume than
13 Michigan would ever get.
14 MS. LICHTENBERG: Here's my concern, Joe.
15 I believe, and we have seen in market entry, that sending
16 transactions in New York simultaneously with transactions
17 in Pennsylvania and simultaneously with transactions in
18 Massachusetts, while the system may be able to handle the
19 capacity, those are different transactions and are dealt
20 with differently in the back-end processor, because
21 clearly they're checking against varying databases and
22 other things are happening. So the fact that the
23 interface can handle the volume doesn't necessarily mean
24 that it works in every state with those state-specific
25 transactions. We've yet to really see that.
2451
1 MR. ROGERS: I think that that pretty much,
2 based on an understanding of what the architecture of all
3 the systems are, if our back-end systems are the exact
4 same back-end systems, we don't take them into the front
5 end and separate them off into five different back-end
6 systems and process. I think you've got a different
7 answer to that. I think that's really up to KPMG to say
8 then categorically up front that that can't happen.
9 MS. LICHTENBERG: We haven't tested that,
10 and since this is not a regional test, I would accept that
11 we just use Michigan volumes if that's what makes better
12 sense. I don't see how we would want to turn this
13 immediately into something regional by accepting an answer
14 here. I mean that's where I see you going.
15 MR. ROGERS: No. I am not saying that.
16 What I'm saying is I don't want to go to the opposite end
17 either and say that just because we're sending completely
18 Michigan volume, even though it could be a volume based on
19 sending orders across the region, that based on the
20 architecture and anything else KPMG is precluded from
21 saying that it would work in other states.
22 MS. LICHTENBERG: I would argue strongly
23 against a conclusion that KPMG drew like that unless they
24 could prove that that actually -- multiple kinds of
25 transactions from multiple states could be handled
2452
1 simultaneously, and I would leave that to KPMG and open
2 hearings or meetings or testimony to deal with that.
3 MR. LONERGAN: If I could clarify. Is your
4 concern that the tests that we do for Michigan might be
5 used or attempt to be used without customization in
6 Ohio --
7 MS. LICHTENBERG: Yes.
8 MR. LONERGAN: -- and Illinois and places
9 like that?
10 MS. LICHTENBERG: Yes. I am concerned,
11 based on the issues that we've seen in New York about
12 volumes and problems and the need to pull back support
13 from other states to focus on New York problems, that we
14 make sure that the transactions that are passed in each
15 state work in each state so that the consumers are not
16 somehow disadvantaged. So it is the ultimate use of that
17 data with which I am concerned.
18 MR. LONERGAN: Well, I guess my point would
19 be I don't think my colleagues in other states will let
20 that happen. They won't just default to the Michigan
21 test. I'd be incredibly surprised if they do that.
22 And likewise we wouldn't do that here.
23 We'd look at what KPMG measures for Michigan, including
24 consideration of regional volumes if that's a key factor.
25 MR. ERINGIS: I think it's -- this is John
2453
1 Eringis from KPMG. I think it's been stated previously we
2 would concur with the assertion that, depending on the
3 architecture of the system, you would need to design it in
4 such a way so that you're considering, you know, what
5 regional transaction volumes you would expect as well as
6 Michigan so in fact everything goes into the same system.
7 If you just had Michigan accounts and you just had
8 Michigan transactions running against that and you didn't
9 have anything else going on, and let's say that you were
10 doing something at 2:00 o'clock in the morning, the
11 results of that test wouldn't tell you anything because
12 you wouldn't be able to make a representation that, well,
13 this is what it's going to be like anything similar to the
14 real world.
15 MR. ROGERS: But it almost by deduction, if
16 you say we have to include volumes from other states, you
17 are saying that based on the architecture, that the
18 processing is -- you know, you have to put the load on it
19 for those other states to be able to do it.
20 MR. ERINGIS: And there are ways to put the
21 load on for the other states that may or may not -- I will
22 only say that factually the way to put the load on for the
23 other states is not necessarily what we're getting at
24 here.
25 MR. ROGERS: I guess what I'm getting at is
2454
1 I don't want to categorically say we're only going to do
2 one test and then we'll satisfy the region for the volume.
3 That's not what I'm saying. I just don't want to go to
4 the opposite end and say that based on your review of the
5 systems, based on that stuff, you may come to the
6 conclusion that these are all the same -- it's the same
7 code that does all the stuff all the way through the line,
8 so that it doesn't make any difference whether it's in
9 Ohio or in Illinois. You may, you may not. You may come
10 out and say these are completely -- you know, the code is
11 a lot more complex in Ohio than it is in Illinois, so you
12 have to run the volume through. I just don't want to
13 preclude that by saying categorically don't even look at
14 that.
15 MS. LICHTENBERG: Are the USOCs identical
16 in your entire region for features and orders?
17 MR. ROGERS: No, they are not.
18 MS. LICHTENBERG: So by definition.
19 MR. ROGERS: No, that's not true, Sherry,
20 because unless you're going to send an order through for
21 every USOC, you cannot pretty much say that the USOC is --
22 you know, if you use the exact same validation code
23 against them, unless you were going to send them to the
24 exact same ones -- you know, do the test four times or
25 five times with the exact same features and stuff in
2455
1 different states, you couldn't even tell whether there's a
2 difference.
3 MS. LICHTENBERG: Well, that's my point, I
4 don't know. Let's say call forwarding. It is the same
5 USOC in every single state in your footprint?
6 MR. ROGERS: No, it is not.
7 MS. LICHTENBERG: And therefore if I send a
8 transaction through in Michigan using the USOC for
9 Michigan, I can't be sure that that same transaction which
10 uses a different USOC will work in Ohio, because the USOC
11 itself, the flowthrough issues --
12 MR. ROGERS: From a functionalities
13 perspective I would agree with you. I'm not talking about
14 a functionality perspective, I'm talking about a capacity
15 test. I'm not talking about functionality. From a
16 functionality perspective, you're right. But from a
17 capacity, whether it's a left-hand call waiting, call
18 forwarding or whatever, it goes against the USOC table for
19 validation. If it's the same table for validation and
20 they're right next to each other and it does basically the
21 same code and said, well, if Illinois, it should be this
22 one, if Ohio it's this one.
23 MS. LICHTENBERG: But I guess my concern,
24 Joe -- and we'll have to find out in the test -- I mean
25 I'm not sure that we can answer that right here -- but if
2456
1 I'm sending those two transactions simultaneously, one for
2 Michigan, one for Ohio, and they're supposed to go look at
3 different tables to decide whether that order rejects or
4 that order receives a commitment, and they look at the
5 wrong table because they get confused because there's so
6 much volume hitting from different places simultaneously,
7 that will be a problem.
8 MR. ROGERS: You're right. You're
9 absolutely right, and that's what I'm saying. If KPMG
10 through their review says the way these things are
11 architectured that orders flow differently from Ohio than
12 they do in Illinois because there are different tables,
13 there are different things that they look at, then they
14 could say no, in order to do the test we have to rerun the
15 test because we're going against different tables and
16 different processes.
17 On the other hand, if they were to come in
18 and say no, this is all the exact same table, you know,
19 Illinois' codes are mixed right into it, they could come
20 up and say that an Illinois test could satisfy in Ohio
21 capacity -- just capacity, not functionality. I'm not
22 saying one way or the other which way it is.
23 MS. LICHTENBERG: O.K.
24 MR. ROGERS: All I'm saying is I don't want
25 to sit here and categorically go to one end of the
2457
1 spectrum or the other and say based on -- you know, your
2 presumption is that you will not -- you know, it is not
3 usable in other states. I'm not going to say it is usable
4 in all five states. I'm just saying I want to leave that
5 to KPMG in their findings to be able to do that
6 investigation, because we're going to ask them to do that,
7 because we don't want to run this thing five times. If
8 they come back and say no, it isn't because of XYZ, well,
9 then, fine, we have to run it again.
10 MS. LICHTENBERG: I think we're in violent
11 agreement, and as Tom Lonergan said, each state will make
12 its own decision about how to use the data, and I would
13 assume that KPMG will use all their due diligence to tell
14 us why they think that it's one way or the other. So I
15 think we're O.K. here now.
16 MR. LONERGAN: O.K.
17 MS. LICHTENBERG: The other question I
18 have, however, is with the change in architecture that
19 comes forward with SBC, which I think happens somewhere in
20 this time frame or begins to happen in this time frame, I
21 think we need to consider -- and potentially at that point
22 I don't think we know enough to consider it right this
23 minute -- how that would impact potentially a regional
24 test. I mean if all of the processing starts to take
25 place in Dallas, then volumes get even bigger.
2458
1 MR. ROGERS: We've talked about that a
2 little bit, too. I think the issue will be as those
3 changes are introduced -- and I think the first ones will
4 be in the March time frame -- that we need to keep KPMG
5 abreast of the changes in architecture that take place,
6 and at that time they can determine whether or not we need
7 to do an aggressive volume test or even the original
8 volume test, and maybe we'd have to amend it to say if
9 it's a single system, which right now I don't think it's
10 envisioned to be, then we'd have to include more than just
11 a five-state.
12 MS. LICHTENBERG: I concur. I think we
13 need some statement somewhere in the test plan that that
14 leaves open this issue -- or that focuses on how we handle
15 this issue of a change comes in, how we evaluate its
16 impact on Michigan, and how KPMG looks at testing it, and
17 I defer that to KPMG.
18 MR. APPENZELLER: Terry Appenzeller,
19 Ameritech. Can I kind of summarize where we're at. At
20 least my understanding at this point is for the volume
21 test, CLECs would submit volumes based on state and
22 regional, five states, to KPMG and the Commission under
23 confidential cover, and we rely upon then KPMG and the
24 Commission working together, KPMG using their knowledge of
25 how to look at these forecasts from New York and other
2459
1 states that they've done this kind of work for the
2 reasonability of the forecasts.
3 We're looking for in the end a forecast
4 that approximates full market conditions, openness, and so
5 Sherry's proposal is 18 months should be the volumes we're
6 looking for; that out of that sync-up process is the
7 reasonable forecast; and that KPMG would then be left in
8 the position to determine how to use that information to
9 run the volume portion of the test. And in some cases it
10 would be regional volumes, because you need the regional
11 volumes in order to approximate the market conditions here
12 in Michigan as well as any other state, and in some cases
13 it may be state depending upon what you find in the
14 functionality side.
15 And then Tom's point is that the other
16 states, I believe, would not accept sync-up without their
17 own review a Michigan test per se.
18 I think that's where we're at on all of
19 this, and Sherry, I don't believe that we're anything like
20 New York in terms of the way we set the systems up in the
21 Ameritech states. There's not state-specific systems like
22 there is in New York as much as you saw there. You're
23 going to see a much more regional system from a functional
24 perspective.
25 So we're going to have to have the regional
2460
1 numbers in order to test the functionality as well.
2 MS. LICHTENBERG: And we'll see all that in
3 the Rick Dishman Show next week.
4 MR. APPENZELLER: Yes, you will.
5 MR. ROGERS: It's been changed to Rick
6 Dishman Presents.
7 MR. KERN: Oscar-winning.
8 MR. LONERGAN: Is there any opposition to
9 the 18-month and the other points that Terry summarized
10 there? Is that O.K. with Ameritech?
11 MR. ROGERS: Yes.
12 MR. APPENZELLER: Yes.
13 MR. KERN: The other issue for volume, I
14 thought, was the stress test and when it occurs.
15 MR. ROGERS: I thought we pretty much
16 resolved that. That was -- well, before we get to that
17 one, I think if we're discussing 18 months where we have
18 an open market, I have a problem with doing 250 percent
19 and expecting to pass. In an open market how do you get
20 250 percent and expect to get that type of volume, pretty
21 much saying you're going to get -- you've got to test the
22 system to be able to handle 250 percent of what you will
23 never get.
24 MS. LICHTENBERG: Let us hope that you will
25 actually get the open market volumes, because clearly
2461
1 that's the intent.
2 In other jurisdictions KPMG used that
3 number, and maybe, John, you could start by telling us why
4 you used that higher percentage.
5 I'd also like you to look at -- to help me
6 understand or help all of us understand how we need
7 volumes and speed potentially to avoid a New York meltdown
8 problem, which I believe we still think is volume-related.
9 MR. ERINGIS: Well, on the --
10 MS. LICHTENBERG: Melted down after huge
11 volumes were going in, even though it started melting on
12 day one.
13 MR. WALKER: What was day one?
14 MS. LICHTENBERG: Day one was when I
15 testified to the 10,000 missing orders, which was early in
16 our launch, which was, what, April, wasn't it?
17 MR. ERINGIS: We'll decline to comment on
18 the second point and once again state that we don't know
19 and have any information that makes us conclude that from
20 our perspective that the problems that occurred in New
21 York were actually having to do with the volume of
22 transactions as opposed to the way that the system was
23 architected in general, so I can't comment on that.
24 What I can comment on is the stress volume
25 and how we came up with 250 percent. 250 percent is the
2462
1 ceiling at which we would stop testing. Design of the
2 stress test in the original concept was to ramp up to that
3 volume and that's the volume at which you would stop, and
4 that the stress test was intended to create results that
5 give information about system performance under load,
6 under extreme loads, and it was also meant to be stopped
7 and was stopped at the system breaks before the 250-
8 percent mark is reached.
9 So I'm not sure if there's any more
10 information that we needed. It's not that dissimilar from
11 an ordinary stress test of the system in its original
12 design.
13 MR. ROGERS: No. The discussion we had
14 last time was that it's not a stress test that was
15 somewhat expected to break. It was a --
16 MR. ERINGIS: Peak plus.
17 MR. ROGERS: -- another level of 150
18 percent that it was expected to pass, and I don't know of
19 any company who keeps 250 percent of their capacity for
20 any system. I'm assuming the Commission would be pretty
21 upset if we had all of our systems able to handle 250
22 percent of the capacity. Our rates would be a lot higher
23 than they are now.
24 MS. LICHTENBERG: Let's be sure, though,
25 that we put this in context. It's 250 percent of daily
2463
1 volumes, so that it is possible, for instance, that in a
2 marketing blitz, if I were doing 10,000 orders a day -- I
3 could be doing some huge number, two and a half times that
4 -- and it's that day volume that we focus on. So that
5 clearly it needs to be a large number because you're going
6 to see that with CLECs. If I go into a marketing blitz,
7 my competition is going to be going into a marketing
8 blitz, and you really could hit two and a half times on a
9 single day.
10 I think the issue is not how high could I
11 go before I crashed, because we don't want to crash the
12 systems. We want to understand there is something in the
13 system that as I begin to approach these higher numbers,
14 the system begins to slow down or crunch or whatever, and
15 I think it's important, since these things are going to
16 happen in real life --
17 MR. ROGERS: But see, I would argue that in
18 an open market that even in our system, I mean if you
19 consider that when we have sales campaigns or whatever,
20 our volumes do not fluctuate 250 percent because of a
21 sales campaign.
22 MS. LICHTENBERG: But your sales campaign,
23 Joe, is selling a new feature or a new function to a
24 customer. This is a sales campaign where I go out and
25 telemarket to people who have never changed their phone
2464
1 number or their carrier, and it's a very different process
2 and it doesn't get mapped, unfortunately, to your current
3 experience, and that's why it's so critical to look at
4 those higher volumes, because I have no historics for you
5 to say that you ever did that. I mean taking a bunch of
6 orders for call waiting is a lot different, I think.
7 MR. ROGERS: Well, I think the volumes -- I
8 mean the type of capacity it puts against the system for
9 call waiting is similar to the type of capacity it puts
10 against it for, say, a resale assumed. It's changing a
11 feature and stuff. It's not provisioning and all that. I
12 would assume that customers are more receptive to take
13 call waiting than they would be to take a completely
14 different telephone provider, so that the volumes we would
15 see on call waiting are probably higher than you would
16 ever see based upon a sales campaign for, you know, com-
17 pletely changing your thing. So the volumes are higher.
18 MS. SEIDL: The volumes already stand,
19 speak for themselves today at the end of every month. I
20 mean it happens every -- I mean it happens today. At the
21 end of every month everything shuts down. We go from, you
22 know, a minimal interval to a very large interval. It
23 happens today.
24 So I mean this is not -- I mean companies
25 are doing it already today, so that I don't think it's
2465
1 ridiculous what she's saying because it certainly can
2 happen. It happens and it does increase. It increases
3 substantially.
4 MR. ROGERS: Oh, I'd basically say, you
5 know, in the 18-month period, when you don't have an open
6 market, I would basically say you're right, because as
7 some CLECs are getting into the business and all of a
8 sudden, bam, they're sending thousands of orders, but once
9 you have an open market, you know, explain to me when the
10 open market, which pretty much order volumes are going
11 between it, how can order volumes fluctuate 250 percent?
12 MR. LONERGAN: Could I butt in here a
13 minute.
14 My understanding of the stress test from
15 the way John's described it is that they ramp up volumes
16 to see what happens, and there's nothing magical about
17 250. That's not a pass/fail point, that's just the point
18 at which they cease testing, because if you get to that
19 point, there's no point in going any farther.
20 So the real point of the stress test is to
21 see at a hundred percent or 150 or 200 where the system
22 starts to waiver, and it's not a pass/fail kind of a grade
23 at 250. That's the point at which they stop testing.
24 MR. ROGERS: If 250 -- I mean if 150 -- and
25 I'm assuming 150 we have to say no, you've got to get to
2466
1 that with flying colors -- but what we're saying is that
2 when we get to 250, if we start having problems, it
3 doesn't say we failed and then we do it, then I don't have
4 a problem.
5 MS. LICHTENBERG: Right.
6 MR. LONERGAN: That's my read of it, is it
7 is not a pass/fail grade, even at 200 percent, if you get
8 there.
9 MS. LICHTENBERG: Unless you just explode.
10 I mean KPMG in other markets has told us what happened,
11 and it's really been the commissions and later the FCC
12 that said, "Oh, gee, they did really great at 139 percent,
13 but when they got to 142 percent, everything exploded to
14 six days, so we're not going to recommend it," or
15 whatever.
16 So you're right, Joe, there's no pass/fail.
17 We just need to see, because there are going to be real
18 customers attached to these orders.
19 MR. LONERGAN: There's no performance
20 standard that says you have to meet 250, I guess is what
21 I'm hearing.
22 MR. ROGERS: Then we're O.K. with it.
23 MR. ANDERSON: So it's an exception from
24 the military-style testing in that aspect of the test.
25 MR. LONERGAN: Correct.
2467
1 MR. SEIDL: So what is the pass percentage?
2 MR. KERN: John?
3 MR. ERINGIS: Well, I mean there is no pass
4 percentage. We do not come up with a pass percentage
5 unless you direct us that they must pass at X number.
6 What the test is designed to do is create data that allows
7 other people to make a decision and reach conclusions
8 about what the data says.
9 The -- I'm sorry, I forgot my other
10 thought.
11 MR. ROGERS: I mean we have no problem with
12 the 150 that we have to meet and still meet the
13 performance criterias and all that. It's the 250 that we
14 have issue with.
15 MR. LENAHAN: I think now we're talking --
16 this is John Lenahan -- we're talking about the difference
17 between peak and stress, is that right, John, because it
18 seems that the master test plan defines 150 percent of
19 projected volume at some future date as the peak and the
20 stress goes up to 250.
21 MR. ERINGIS: Let me say the following, and
22 now I remembered my thought. It was in reaction to
23 Craig's point.
24 I don't think it's a full exception to the
25 military-style testing process. We don't have a passing
2468
1 or failing grade or a threshold for even the normal and
2 the 150 percent. But I think common sense says that if
3 the normal volume test or even the 150-percent test did
4 not go well, Ameritech probably would not be comfortable
5 going forward with that result. So in that respect -- and
6 that's an expectation that we have. So if we saw that the
7 normal and the peak volume tests had serious degradations
8 of performance prior to when we got to the high volumes in
9 the test, when we got to the top speed of the test, we
10 would publish those results and inform everyone that, you
11 know, this is not what all the parties were expecting the
12 system to behave like.
13 But we were not directed to repeat the
14 volume test -- I mean we wouldn't -- so in that respect we
15 don't see it as -- it's not something where we're going to
16 say this is unacceptable or it is unless there's a
17 complete inability to do any volumes. Again I think this
18 is one of those common-sense things where if the system
19 didn't work at all, you know, we got 15 minutes into the
20 volume test and everything started coming apart, we would
21 probably say that's not good. But short of that --
22 MR. ROGERS: We won't argue that one.
23 Maybe 30 minutes into it.
24 MS. LICHTENBERG: Right.
25 MR. ROGERS: O.K. The next issue is --
2469
1 MR. ISIOGU: Before we move on, you
2 mentioned in New York you used the 250 percent. Was that
3 what happened in New York, you ramped up to 250?
4 MR. ERINGIS: I believe in New York our
5 test design was to get to a 250-percent volume and stop if
6 the system didn't degrade beforehand.
7 There's a step function of transactions.
8 The way that the system test is done is there are a series
9 of transactions that are staged. We have a testing
10 simulator software and transactions are created beforehand
11 and they're canned and then they are launched. And so as
12 they are launched, the number of transactions that are
13 sent are ramped up.
14 When you design that test -- and it's all
15 done beforehand; it's kind of like you have it done
16 beforehand and then flip a switch and then it begins --
17 it's set up so that if you charted it out on a graph, the
18 step function goes up to 250 percent of whatever baseline
19 number you chose, and that there are these increments.
20 It's like every 15 minutes we kick it up a notch.
21 So the test is monitored in such a way so
22 that if you see that the system is completely breaking
23 down at, you know, an hour and 15 minutes, we're just not
24 getting responses back, et cetera, we turn it off.
25 So the 250 percent is really -- it should
2470
1 be thought of best as a ceiling and a way that we help
2 create -- you can visualize the step function that one
3 would have. If there's a four-hour test, you divide in
4 increments to go from minute one to hour four, get from
5 zero to 250.
6 MS. LICHTENBERG: The next issue was when
7 we would run this test. WorldCom would again propose that
8 this be run during normal production hours, period.
9 MR. LENAHAN: Sherry, on page 81 of the
10 master test plan -- I'm sorry. Were you referring to the
11 normal, the peak, or the stress test, or all three?
12 MS. LICHTENBERG: All of the above.
13 MR. LENAHAN: O.K. Because that probably
14 would be inconsistent with the current plan.
15 MS. LICHTENBERG: That is correct. That's
16 why I have that page marked and why WorldCom's comments
17 suggested that it be run during production time. Since
18 the production that is in place is the production of
19 CLECs, I would suggest that we poll the CLECs to determine
20 whether they concur.
21 MS. SEIDL: I'm doing it after hours. It's
22 not my reality because I can't talk to them after hours.
23 MS. LICHTENBERG: The CLECs all, I believe,
24 unless anyone says no -- anyone on the phone?
25 MR. OSLAND: I would agree with that.
2471
1 MR. ROGERS: Would you also agree to
2 suspend performance penalties during that period for the
3 stress?
4 MS. LICHTENBERG: During those four hours?
5 MR. ROGERS: Just the stress.
6 MS. LICHTENBERG: Yes.
7 MR. ISIOGU: I missed the question.
8 MR. ROGERS: To suspend performance
9 penalties during that stress.
10 MS. LICHTENBERG: Yes, absolutely, during
11 the period of the stress test.
12 MR. ISIOGU: So they have to tell you after
13 the fact when the test was done?
14 MS. LICHTENBERG: After the fact --
15 MR. LENAHAN: We will know.
16 MS. LICHTENBERG: Are the CLECs in
17 agreement with the suspending of the penalties during that
18 period, everyone on the phone as well?
19 UNIDENTIFIED SPEAKER: McLeod is.
20 MR. ANDERSON: Let me just raise a concern
21 that suspension of the performance penalties is one part
22 of it, but we also face various other consequences when we
23 have customers impacting situations. That could come from
24 customers, that could come from CLECs that have chosen not
25 to participate in this process. That could be not based
2472
1 on performance penalties, that could in essence be a
2 claim, a complaint to the Commission or something like
3 that.
4 MS. LICHTENBERG: We haven't seen that in
5 any other states where this has been done during production.
6 MR. ROGERS: Distress?
7 MS. LICHTENBERG: We've not seen customers
8 complaining. I understand your question and I think we
9 could probably work with the Commission to field that
10 specific window of issues.
11 MR. ROGERS: The only one we're contending
12 is the stress, not the peak, not the other one.
13 MR. LENAHAN: I don't know, Sherry, but has
14 stress testing in any state taken place in normal business
15 hours?
16 MS. LICHTENBERG: That's when we have
17 always requested it be done and I believe that's when it's
18 always been done.
19 MR. ROGERS: It's not that way in this test
20 plan or any other one.
21 MR. LENAHAN: I've never read a test plan
22 where --
23 MS. LICHTENBERG: The test plan you saw was
24 Florida, and I can't speak for Florida at this moment.
25 MR. LENAHAN: Maybe we could ask John.
2473
1 MS. LICHTENBERG: John, stress test during
2 production or non-production hours?
3 MR. ERINGIS: Non-production.
4 MS. LICHTENBERG: Pardon me?
5 MR. ERINGIS: Non-production.
6 MS. LICHTENBERG: Non-production. We've
7 not run them during production.
8 MR. ERINGIS: Let me bring up a couple of
9 points for people to consider. One is that these
10 percentages are net of current production. So if everyone
11 understands that, that the peak test using volumes at 150
12 percent is we take a look at what volumes are currently
13 processing and we make some adjustments to what the volume
14 test is so that the overall result is 150 percent.
15 So what we've done in the past is we've
16 designed a stress test in off-peak hours, because not
17 expecting volume, most of the volume that's generated
18 during the stress test is hours. So in many ways doing it
19 during off hours, you know, the concern that you're not
20 doing it when other people are sending their transactions
21 is somewhat mitigated, although we wouldn't represent that
22 it would be the exact same mix. I mean it's a more real-
23 world test if you're doing it during production, I'm not
24 going to argue that.
25 The one concern that we have about doing it
2474
1 during production is that if in fact it's a regional
2 system, we're uncomfortable being responsible for
3 launching a 250-percent volume test when we do not have
4 the consensus of the other states that may be impacted. I
5 mean I don't know that the Illinois commission or the
6 Indiana commission has said that they're comfortable with
7 KPMG submitting volumes at 250 percent on a production
8 day. You know, this is a day where let's just assume
9 we're going to bust your system for a period of time, and
10 that's one thing that makes us very concerned. I mean we
11 don't object to doing the test, but we've got to figure
12 out how to make sure that everyone is comfortable with
13 doing this simulation in the way that's being proposed.
14 MR. LENAHAN: Ameritech is very concerned,
15 as we stated the last time we talked about this issue, if
16 we conduct the stress test during normal business hours,
17 and we think it's a mistake and an unnecessary procedure,
18 and to my knowledge the testing that has taken place to
19 date -- the stress testing that has taken place to date
20 has not taken place during normal production business
21 hours.
22 MR. ERINGIS: The stress has not. The
23 other ones do take place during production.
24 MR. LENAHAN: And I'm focusing only on
25 the --
2475
1 MR. ROGERS: We're O.K. with the others.
2 MS. LICHTENBERG: CLECs believe that -- and
3 we've had this discussion in other venues, most recently
4 in Massachusetts -- that it is critical that we really
5 look at this during a production period.
6 MR. ROGERS: Why?
7 MS. LICHTENBERG: Because that is when the
8 stress will really happen. It will not happen on a Sunday
9 morning when nobody is sending transactions.
10 MR. ROGERS: So we're assuming the systems
11 realize it's Sunday? I mean systems, when you put the
12 volume in it, the systems aren't going to say, well, it's
13 Sunday so I'm going to give you more capacity.
14 I mean I guess I wouldn't say -- I wouldn't
15 object to doing it in off hours. I don't think, you know,
16 maybe not Sunday, but even on off-peak hours where there
17 is capacity, you know, some capacity in the system. We
18 just don't want to do it at 8:00 o'clock on Monday
19 morning.
20 MR. ANDERSON: And let me raise one
21 additional concern just by way of example, is the
22 potential impact not only on the CLEC ordering systems,
23 but, for example, a piece of an order may be an update to
24 a 911 database. That could cause some problem with the
25 updates to the 911 database. We have a process in
2476
1 Michigan that involves fines if these are not resolved in
2 one day. This could cause a breakdown not just with the
3 test scenarios, but existing production volume and
4 delaying stuff getting in the 911 database. Now, that's a
5 concern.
6 MR. CHORZEMPA: Let me just say -- this is
7 Dave Chorzempa from AT&T. Those concerns are why we're
8 doing a stress test. I mean the fact that those concerns
9 are there if you're at 250-percent volume or whatever the
10 volume we're looking for, that's why we're testing, to
11 make sure that it doesn't happen when it actually occurs.
12 MR. ANDERSON: And we agree.
13 MR. CHORZEMPA: But we should test it and
14 get it done so we don't have those problems later.
15 MR. ANDERSON: We agree, and that's why
16 we're saying do it in non-production hours so it doesn't
17 affect retail actual orders.
18 MR. LONERGAN: Let me just comment, I
19 guess.
20 No. 1, in the test plan we could provide a
21 little bit of immunity, if you will, in Michigan, but I
22 don't think we could provide you any immunity in any of
23 the other states if something goes wrong.
24 My problem with the stress test again is
25 it's designed to run your system till it breaks, correct?
2477
1 I mean that's basically what it is. So unless it holds it
2 together up to 250 percent, which it may very well not, it
3 is going to break at some point. It's like a submarine.
4 If you drop it far enough, it's going to implode, and
5 that's what this test is designed to do.
6 MR. CHORZEMPA: I remember the conversation
7 from last time and I thought there was a clear distinction
8 between that type of stress test and the test that we're
9 talking about here; that there is a type of stress test
10 where you do test until you break, and that's what I guess
11 some people would consider a traditional stress test and
12 that this isn't one of those tests, because we're picking
13 a number, 250 percent, that we certainly hope Ameritech
14 can pass.
15 MR. ISIOGU: So is it assumed, then, that
16 as we ramp up to 250 percent, if we get to, say, 175 and
17 the system seems to be faltering, the test stops then, or
18 do we have to push till we go to 250 percent?
19 MR. LENAHAN: By design.
20 MR. DENNISTON: But my understanding -- and
21 John is not here presently -- was that Ameritech can
22 always call time out on the test.
23 MS. SEIDL: Yes, they can always call time
24 out, I believe.
25 MS. COLEMAN: I think he said that, too.
2478
1 MR. ERINGIS: Let me make a statement. I
2 want to clarify a fact -- correct something I just said.
3 We had said that we have always run the
4 stress test during off peak, and again to us off peak does
5 not necessarily mean Sunday at 2:00 o'clock in the
6 morning. We have run stress tests during business days
7 and between the hours of 8:00 to 6:00. We've launched
8 them at the request of -- I think the Massachusetts
9 commission had us and the Pennsylvania commission had us
10 run some tests during the day. And so we have done some
11 of those. I wanted to clarify that.
12 I will say that we have not run those tests
13 at 8:00 o'clock on Monday morning, though, but were they
14 during business production days? Yes.
15 MS. MORREALE: And, you know, a call from
16 the ILEC to pull the plug because we're impacting real
17 CLECs, we've done that. We've pulled the plug. The ILEC
18 has also pulled the plug on us in Pennsylvania during one
19 of the tests because we were seriously impacting real
20 CLECs in the state. And we're ready to do that at any
21 moment.
22 MR. ERINGIS: And let me make one final
23 comment. The challenge in doing that is that if the plug
24 is pulled during production -- one of the challenges of
25 doing it during the day in production and trying to
2479
1 minimize the impact to customers is that you may pull the
2 plug much sooner than you would as if you were doing it at
3 8:00 or 9:00 o'clock at night. So in all of this from our
4 perspective again, and not taking a position as to when
5 it's appropriate to do it, we just want to share the
6 concern so that everyone's fully informed. It may be that
7 we don't get a lot of data from a stress test that's done
8 during the day because we don't get that far into it if
9 there are system problems during the test. I mean I think
10 that's what happened with some of the data you were
11 showing me.
12 MS. MORREALE: And just another point to
13 add is if we run it during the day, the feature function
14 part of the test is also running. So if we're pulling the
15 plug for some reason because of volume, you're also
16 impacting the feature function.
17 So in Pennsylvania where we did have
18 several volume issues, you know, those days of the volume
19 day, in and around the volume day, it seriously impacted
20 the results we got from the feature function test because
21 we weren't getting our responses back in a timely fashion.
22 So it was very hard to go back and match all of that data
23 and match it against metrics that Bell Atlantic had to
24 meet during that time period.
25 MS. LICHTENBERG: But this is exactly what
2480
1 the CLECs need to understand and see: that on a day when
2 there is high production, if I went out and I started to
3 sell -- and let me tell you, when we turn on our marketing
4 machine, we create major stress because we sell lots. If
5 there is degradation to the feature and function, to
6 provisioning, to the flowthrough, that's what we're
7 interested in, because we need it in order to plan and we
8 need to see this during production. It is something we
9 have asked for in every venue, we will continue to ask for
10 it, and we'll be happy to work with you to help you pull
11 the plug when it starts to fail.
12 MR. ISIOGU: I have a couple of questions.
13 First of all, when you say pull the plug,
14 does it imply that the ILEC knows when the stress test is
15 being conducted so they can call you up and say cut it
16 out?
17 MS. MORREALE: It's blind. I mean they
18 know that it will happen at some point during the test.
19 We don't let them know when we're going to run it, but
20 they can tell immediately that these huge volumes are
21 coming in.
22 MR. ROGERS: You may not know the bus is
23 coming, but when it hits you, you know it.
24 MR. ISIOGU: O.K.
25 MR. ERINGIS: It does not take long for
2481
1 them to figure out, ah, today's a volume day.
2 MS. MORREALE: But it's blind to everybody.
3 I mean it's blind to the CLECs, it's blind to the ILECs,
4 and it's blind to everybody as to exact days and times
5 we're going to run it.
6 MR. KERN: Is it possible to do this during
7 normal production periods but not at 8:00 o'clock on
8 Monday morning? Can it be limited a little bit in terms
9 of when during the production period you can run the
10 stress test?
11 MS. LICHTENBERG: I would accept that.
12 MS. SEIDL: I was going to say we can
13 compromise on it, start it at --
14 MR. KERN: 10:00 to 3:00 or something, I
15 don't know.
16 MR. ERINGIS: Well, we'd like to have the
17 discretion to do that as long as people help us with the
18 assumptions that they're comfortable with.
19 MR. ISIOGU: Just for the record, we'd
20 prefer that it doesn't interfere with normal life
21 functions, you know, so we don't have the public health,
22 welfare, and safety crises, you know.
23 MR. LENAHAN: We think a compromise would
24 be business off-peak hours for the stress test.
25 Everything I've heard, especially given the fact that
2482
1 we're doing the normal testing at 18 months forecast and a
2 peak test at 150 percent of that and both of those are
3 during normal business hours, this third test doesn't seem
4 to me, given the adverse consequences that it may have
5 either on the other testing or, God forbid, on real
6 customers, doesn't seem that the value of the stress test
7 during peak business hours outweighs the adverse
8 consequences that it might cause. So we would take the
9 strong, firm position that it should not take place during
10 peak hours on business days.
11 MS. LICHTENBERG: We concur.
12 MR. LENAHAN: But it could take place off
13 peak.
14 MS. LICHTENBERG: We concur. Could you
15 tell, just because everybody has a different set of peak
16 hours, what are your peak hours?
17 MR. ROGERS: We don't know.
18 MR. LENAHAN: We'll have to get back on
19 that.
20 MS. LICHTENBERG: O.K. We could do it
21 during the Rick Dishman Show?
22 MR. LENAHAN: That will be part of his
23 show.
24 (There were numerous simultaneous
25 comments.)
2483
1 MR. KERN: O.K., come on. Settle down.
2 MS. LICHTENBERG: Could we take a break?
3 MR. KERN: Let's close this out before we
4 take a break.
5 MR. CHORZEMPA: I had one clarification on
6 that, John. You're saying during business hours but not
7 during peak hours?
8 MR. LENAHAN: During off-peak hours on a
9 business day.
10 MS. LICHTENBERG: And help me understand.
11 Just to be clear, I understand that there are certain
12 times during -- the business day is 9:00 to 5:00 or 9:00
13 to 6:00 or something like that.
14 MR. LENAHAN: No, I'm talking business day
15 Monday through Friday, Monday through Saturday, whatever.
16 MS. LICHTENBERG: But we're not suggesting
17 Monday at midnight. We're suggesting if your peak is from
18 9:00 A.M. to Noon, that we might do it around 1:00
19 o'clock.
20 MR. LENAHAN: Right.
21 MS. LICHTENBERG: O.K.
22 MS. SEIDL: And again the other point is
23 not only what time, it's what time of the month also is a
24 big issue, because certain parts of the month are
25 definitely heavier anyway, and we want to hit it during a
2484
1 time when the reality is out there.
2 MS. WILSON: Like during billing cycles?
3 MS. SEIDL: Yeah. End of the month always
4 is a heavier time, end of the interval month, so the third
5 week in the month.
6 MS. LICHTENBERG: Don't compromise that
7 blindness just yet.
8 MS. SEIDL: Well, I mean I don't want to do
9 it -- you know, we'll say the last day of the month.
10 MR. KERN: O.K. So we have an agreement on
11 the stress test and when it's going to occur. Maybe this
12 is a good time to take a short break.
13 Do we have any more volume-related issues
14 for discussion or is the volume issue closed? Or not
15 closed but --
16 MR. LENAHAN: Now, a suggestion, and if
17 people think this is a waste of time, that's fine.
18 There were about eight or 10 references in
19 the grid that we went over yesterday that we might go back
20 now after the break and take a quick look and say is that
21 consistent with the discussion we've just had or --
22 MR. KERN: I was going to suggest --
23 actually John and I had kind of talked. I think he has
24 enough information to go back to those issues and modify
25 the master test plan based on this conversation.
2485
1 MR. ROGERS: I would agree with you except
2 for 31, because 31 doesn't get into capacity and the like,
3 and I would pretty much say we agree with what's in 31.
4 MR. KERN: O.K.
5 MR. ROGERS: So we don't have an issue with
6 what's in 31.
7 MR. LONERGAN: One last comment. You had
8 suggested relief from the penalties. Are we suggesting
9 that go right in the test plan, that there be a sentence
10 to that effect or what?
11 MS. LICHTENBERG: Just putting it in the
12 test plan isn't really --
13 MR. ANDERSON: I would ask --
14 MR. LONERGAN: No, but at least it brings
15 it to the Commission's attention if they're going to
16 approve this thing.
17 MR. ANDERSON: Tom, I guess I would ask on
18 behalf of Ameritech -- it's not just the penalty plan but
19 also other ramifications -- that you consider with John
20 what language would attempt to give us some --
21 MR. LONERGAN: You're requesting that it be
22 included in the test plan.
23 MR. ANDERSON: Yes, that there be some
24 language to that effect.
25 MR. CHORZEMPA: Would you still continue to
2486
1 measure during the stress test, though?
2 MR. ROGERS: Yes. I mean doing the test,
3 we pretty much have to continue to measure, but we'll say
4 that, you know, we've sent two and a half times things for
5 those orders that came in during that period of time. The
6 five-hour clock is now eight hours. We'd still tell you
7 that there were eight hours. But we'll say that because
8 of the stress, there's no penalties involved with it, but
9 the measurement would still be done.
10 MR. O'BRIEN: This is Tom O'Brien. At what
11 point after the stress test occurs will the penalties
12 resume?
13 MR. ROGERS: Let's go back and propose
14 something and then we can bring that back.
15 MR. CHORZEMPA: I'm not sure I could -- I
16 need to know the answer to that question.
17 MS. COLEMAN: That needs to be included in
18 the language.
19 MR. LENAHAN: Two years.
20 MR. ROGERS: Two years.
21 (Multiple statements were made
22 simultaneously.)
23 MR. KERN: O.K., we're on break. Five
24 minutes.
25 (A recess was taken.)
2487
1 MR. KERN: Let's get back to -- I would ask
2 Ameritech to give us their response on how we should
3 resolve our, how we should address the unresolved A-to-Y
4 issues that came out of Wisconsin and would be ripe for
5 any dispute resolution for Michigan.
6 You have heard what the CLECs prefer to do
7 yesterday. We are waiting for your response today.
8 MR. APPENZELLER: This is Terry
9 Appenzeller, Ameritech.
10 I believe that we are not as far apart as
11 people might have described yesterday in the collaborative
12 on these issues, and let me get into that to explain what
13 I mean.
14 There really are two issues. One is the
15 functionalities that need to be implemented, and I think
16 we are closer on those functionalities than might have
17 been characterized yesterday, and we need to probably work
18 through some of that, John, in terms of the
19 functionalities and what is the process for determining
20 which ones we are actually planning to implement.
21 Secondly, on the timing of those
22 functionalities, I believe we are both on the same side.
23 And the reason I say that is it is in my interests and
24 certainly in the rest of the Ameritech team's here
25 interest to get these functionalities into place as soon
2488
1 as possible.
2 We recognize that a lot of those
3 functionalities are vital for market entry, and that's why
4 the other side wants them, and we need those
5 functionalities in our judgment in order to obtain
6 approval from the Michigan commission and the FCC
7 ultimately for a 271 application.
8 So the motivation is very high on our part
9 to get that done as quickly as we possibly can.
10 The problem we have had so far is that we
11 have not been able to find a way to move the
12 functionalities and the GUIs up any sooner than our
13 present plan, which is March of 2001.
14 We are not done. We are continuing to work
15 on what we can do. We are using this pressure that we all
16 have to get ourselves done, get this test done as soon as
17 possible, internally as much as we can possibly do.
18 And I don't believe that that Commission
19 document is going to help us move this any quicker at this
20 point in time. We know what we have got to do, and so I
21 would be very cautious as to what you want the Commission
22 to do in either the functionality issues, which I think we
23 need to talk about a little further, or the timing issues
24 that are associated with it.
25 So if we could revisit a little bit from
2489
1 our perspective what functionalities, I think we can clear
2 a lot of that up, and I don't know, maybe the other side
3 -- I know was looking at this as well -- might find the
4 results looking at it the same way that I do in terms of
5 the timing. Our best answer is to do it as fast as we
6 can.
7 I don't think there's any lack of
8 motivation on our part to do that any quicker. I mean, we
9 are trying to do it as fast as we possibly can.
10 MR. CHORZEMPA: This is Dave Chorzempa from
11 AT&T.
12 I agree with Terry that, based on what's
13 happened yesterday, I think that there's a lot -- I think
14 the motivations are in the right place for us in relation
15 to the system upgrades and timings. That's for sure.
16 Although we still like to see those get moved up.
17 But based on the fact that you are saying
18 that the upgrades will be part of the test, the test won't
19 end up until the upgrades are done, I think the motivation
20 is, the onus is on Ameritech's side to get them done as
21 soon as possible. The sooner you get them done, the
22 sooner you get your test done.
23 In relation to the functionalities, I think
24 the three functionalities -- I think we are all in
25 agreement on the fact that Ameritech will implement
2490
1 certain functionalities and that those functionalities
2 will be tested. I think we came to agreement on most of
3 those items in Wisconsin.
4 There are -- I have just written down three
5 items that I think we would still view as open in the
6 sense that Ameritech is not committed to implement those
7 functionalities, and one would be complex completion
8 notices, which is the field of completion notice. Two, I
9 have an issue in relation to the fact that we have
10 different understanding of what synchronization between
11 preordering and ordering is, and this goes beyond just the
12 parsed CSR. I think we are in agreement on the parse CSR
13 that you are going to implement it, that it's going to be
14 tested. I think there's some disagreement on what full
15 integration of preordering and ordering is.
16 And I think the third issue I have written
17 down is frame due times, whether or not you are going to
18 provide the frame due times like your affiliated
19 companies, Pac Bell, do in the OSS process.
20 Those are the three I have. I don't know
21 if Joanne and Tim have anything else.
22 MR. APPENZELLER: O.K. Dave, this is Terry
23 Appenzeller again. I think we have to talk about those
24 three. We are willing to do that. I think we have some
25 dues that we can report about where we're at. Now, if I
2491
1 could start with the last one first and defer to Joe on
2 the other two on the frame due date, I believe that's
3 being discussed in conjunction with the subcommittee in
4 Wisconsin that has been formed on the hot-cut procedures.
5 And I think that is going to be included in the outcome of
6 the procedures they develop in order to use them not only
7 in Wisconsin but to import them here into Michigan as
8 well. So I believe there's progress being made there.
9 And that would be the vehicle that we would recommend that
10 that gets done in.
11 MR. ROGERS: To kind of expand on that a
12 little bit, they were under the impression that I was
13 taking it, and I punted it to them last week. I said it
14 really is part of the hot, overall hot-cut process. You
15 guys should be taking that whole thing, and I assumed that
16 they were taking it. So they clearly know that it's
17 within their responsibility to get it resolved.
18 MR. CHORZEMPA: Does this mean that
19 Ameritech's willing to provide frame due times at some
20 point in the future?
21 MR. ROGERS: I believe that we -- Bill is
22 here.
23 MS. FENNELL: I think the only point, and
24 maybe Tim will clarify this, the only point of contention
25 was I don't think we disagree with that the field is for.
2492
1 I think it was whether the system -- and that's why we
2 punted to you in Wisconsin, whether your system can
3 support it. And we think it could. So even if the
4 team --
5 MR. ROGERS: The issue with the team when I
6 punted to them I made it pretty clear, was that the issue
7 was how do you use the frame due time in the process, and
8 then once you say O.K., we can use it in the process, then
9 we go ahead and figure out how to put it in the system.
10 Because I believe it is functionality that is available,
11 you know, from a uniform perspective that we have to
12 provide the system.
13 But the biggest issue is not can we just
14 put it on the order, it's what the heck we are going to do
15 with it once it is on the order.
16 MS. SAMONEK: I think what we need to do,
17 we will get to you, back to you, we need to find out do we
18 put the cart before the horse or the horse before the
19 cart. If you have the functionality, it may drive out
20 people to using it.
21 I can't wait for them to say when I figure
22 out what to do with it, give me it on the system, because
23 we are in the OSS collaborative. I have to provide it
24 from the system perspective. The field is there, you can
25 populate it. This is what you are telling them, you want
2493
1 to cut it 2:00 o'clock on July 4th. And then we put the
2 MMPs behind it.
3 MR. ROGERS: When I gave it to Donna, I
4 said, "Donna, let me work out the process and include Rick
5 to make sure that we flowed any system issues that come
6 out."
7 MR. CHORZEMPA: My understanding of what's
8 happened in Wisconsin, and, Joanne, correct me if I am
9 wrong, is in relation to frame due times at least of the
10 three issues that I have listed, the frame due times is
11 not up for litigation in the July time frame, and when we
12 have to file our case in July that has been -- is that
13 right?
14 MR. APPENZELLER: That's correct.
15 MR. CHORZEMPA: And that it has been moved
16 to further discussion with parties, and we don't come to
17 resolution in future, and I would agree with that process.
18 I'm not saying that, I'm not saying that I'm not agreeing
19 to this we agree to abide by whatever happens in
20 Wisconsin, but I'm providing with going forward with this
21 process as put forward.
22 MR. APPENZELLER: I do believe that we have
23 a second process in Wisconsin for items that are in that
24 Category 3, and I believe this is in Category 3.
25 MR. CHORZEMPA: Yes.
2494
1 MR. KERN: Let me be very clear. I was
2 under the impression that frame due times was a
3 functionality that all parties agreed to do and the sub
4 team was working on how to do it. So I didn't think that
5 functionality was in dispute.
6 MR. APPENZELLER: I don't either. I think
7 that is one that we are working on.
8 MS. SAMONEK: From a system perspective?
9 MR. ROGERS: I don't think that that was
10 the case. I guess we disagree with you on that.
11 MR. CONNOLLY: Joanne's right, the last
12 item that was unresolved, unanswered when we were in
13 Madison was if we put frame due time on the LSR, are you
14 going to carry it through your process and provide that to
15 the tech and -- you know, on end-to-end basis. And the
16 question was, well, we didn't think about that. The sub
17 team didn't think about that. They had to go back and
18 talk to Joe, and that they would then bring that answer
19 back.
20 And we haven't gotten the answer back yet.
21 If Joe's answer is we'll get it there --
22 MR. ROGERS: My answer, I guess I've pretty
23 much said that the sub team is supposed to come up with
24 that answer. I'm not going to -- you know, it's like one
25 team's working on the process, and I didn't want to come
2495
1 back and say, here's a field that you got to work with.
2 You know, I put the whole thing on them to
3 say, you come up with it. You say here's the process of
4 using it, and that it needs a system change in order to
5 add it to the field. Rick will work with them to get the
6 system change put in.
7 MS. SAMONEK: We can send it today. We can
8 populate the field. It's optional. We can stick anything
9 we want to in this field. It's that you do nothing with
10 it when you get it. You don't return anything to us
11 saying, yes, July 4th we checked it out, our tech will be
12 having that day and time. So we will work with the sub
13 team as long as what we are hearing today is that
14 functionally you will make it work if the sub team agrees.
15 MR. ROGERS: Yes.
16 MS. SAMONEK: Then it's not an issue that I
17 need to take on July --
18 MR. APPENZELLER: I think the point is that
19 this one in particular of the three is clearly in the
20 hands of the sub team, that we are willing to support how
21 that comes out, and through that process and probably the
22 appropriate way to do it --
23 MR. CHORZEMPA: I'm fine with that.
24 MR. APPENZELLER: O.K. And then the other
25 two we probably need to work through.
2496
1 MR. LENAHAN: John, did you get that on the
2 frame due date time?
3 MR. KERN: The resolution?
4 Absolutely. Done.
5 MR. LENAHAN: We have agreed we will
6 continue to work that issue in the sub team, and we'll
7 abide by the sub team's conclusion.
8 MR. KERN: That's what I thought the issue
9 has always been, but --
10 MR. CHORZEMPA: Let me just point out,
11 Joanne's whispered in my ear, if there isn't any -- if
12 that doesn't come to resolution, we reserve our rights to
13 raise it to the Commission, we can't come to an agreement.
14 MR. APPENZELLER: You always do.
15 MS. SAMONEK: Joe, if you tell me you won't
16 support that deal till September 2001, then I am going to
17 say it's a timing issue.
18 MR. ROGERS: Absolutely.
19 MR. KERN: On the other two
20 functionalities.
21 MR. ROGERS: The other two, I want to
22 clarify on the record we had yesterday on page 2260 where
23 Mr. Rogers said no, "somewhere between 'No' and 'Hell,
24 no,'" it's also between maybe no and no.
25 Both of those issues, I think if we look at
2497
1 the issue from a purely, you know, one end of the spectrum
2 versus the other, the answer is still no, Hell, no. As
3 far as where we do an open-ended synchronization of the
4 preordering and ordering without scope around it, no.
5 Where we do the complex completion in any size, shape, and
6 form that people can think of, the answer is no.
7 But I believe both of the issues are still
8 up for collaboration within the -- I mean the -- all
9 parties agree to continue the process in Texas and to plan
10 a record to come up with what do we mean by each one of
11 these things and to get some movement on it.
12 That completes at the end of July. I
13 believe.
14 By the end of July we should have an
15 overall process that says yes, we have been able to
16 satisfy the parties, or we are at an impasse and we are
17 not going to do it.
18 So I would propose that we continue to let
19 that process work those two issues, because it's -- you
20 know, I mean I really think that's the best venue to do it
21 because it does include, you know, most CLECs, 13-state,
22 and scope.
23 MR. CHORZEMPA: That is an issue, though,
24 that has been teed up in Wisconsin, both these are teed up
25 in Wisconsin for resolution now. Is that right?
2498
1 MR. ROGERS: No. I think the way it is in
2 Wisconsin is that I think Ameritech was originally
3 considering bringing them up as issues tomorrow, because
4 the way the ALJ report was written, it looks like we
5 agreed to do them with just timing.
6 O.K. And we were yesterday going to say
7 no, we want to arbitrate whether or not we are going to do
8 them, but after thinking about it and looking at what's
9 happening in Texas, I think we would look to say, we would
10 reserve the right, based on what's happened in Texas, we
11 might want to at a future date, but don't arbitrate them
12 in Wisconsin even until maybe October if we can't make an
13 agreement in the July time frame.
14 We still reserve the right to say that, if
15 in July we are at an impasse, either us or the CLECs can
16 come and say, "No, that is something we are going to
17 arbitrate," in a couple different venues, one of them
18 being in the FCC venue, and then in the Wisconsin.
19 MR. CHORZEMPA: I have one question about
20 the FCC venue, because this just came up. In my mind,
21 when you guys were talking about taking what happens in
22 Wisconsin and applying it to Michigan, it's not only the
23 states that are running through these kind of A-through-Y
24 issues, but I think the FCC's Dallas collaborative
25 probably does too, as we have just identified that fact.
2499
1 The enhancements, not the uniformity, discussion going on
2 at the FCC, but the enhancements that are in the FCC POR
3 that come out of that process, those are the enhancements
4 you are talking about as being part of this test and not
5 -- and this test not ending until the enhancements are
6 made.
7 MR. ROGERS: No. The A to Y we are
8 discussing, the A to AA are the ones we are discussing.
9 By coincidence it is overlapping with the majority of the
10 stuff that's happening down in -- on the uniformity FCC,
11 but just like I wouldn't want to categorically say that we
12 will sync it, that we are going to do everything that
13 comes out of that as before this test would complete.
14 MR. CHORZEMPA: In relation to the
15 overlapping issues, the reason I bring this up, let's say,
16 in the FCC somebody arbitrates a date for implementation
17 of an issue that overlaps with A through AA and that date
18 gets moved up. I mean, that date gets moved, that's --
19 MR. ROGERS: Yeah. Of course. It would be
20 hard to say we are going to do it in 13 states but we are
21 not going to do it in one of them. Because by definition
22 you can't do it 13 and not do it in one.
23 MR. CHORZEMPA: If the dates get moved back
24 based on the FCC's review of this, that's true, too. I
25 mean I'm not sure how that process works.
2500
1 MR. ROGERS: In the case of dates it gets
2 moved back.
3 MS. SAMONEK: They could change based on I
4 guess a lot of things that could happen in Dallas. You're
5 tied to that as well as you are tied to giving us
6 functionality early if Dallas moves that, the
7 collaborative.
8 MR. ROGERS: Yes. We are tied to that.
9 MR. CHORZEMPA: You are basically proposing
10 that we -- that in Wisconsin and in Michigan and obviously
11 in Ohio, too, that we wait to arbitrate the complex
12 completion synchronization issues until at least the end
13 of July.
14 MR. ROGERS: And the frame due time.
15 MR. CHORZEMPA: And the frame due time.
16 Well, I think we were kind of agreed on the
17 frame due time.
18 MR. ROGERS: Yes. Like I say, you want to
19 leave it open in case something does happen.
20 MS. SAMONEK: But frame due time is kind of
21 different. We kind of agreed. We can put --
22 MR. ROGERS: Put that in a separate pot.
23 We are saying, if we get down the path, we find that
24 that's indeed not the case, those are the -- those -- you
25 know, if you don't want to put it in the bucket, that's
2501
1 fine, but I think for overall protection, you would want
2 to.
3 MS. LICHTENBERG: If I could ask a somewhat
4 related question that I believe will be answered when we
5 see the UNE platform tariff, one of the concerns that we
6 have in residential world is that, without the parse CSR,
7 if we have a requirement to use customer name and address,
8 service address, for migration, that we run a risk, a very
9 high risk of very high rejects. One of the things that
10 WorldCom has proposed is the ability to migrate customers
11 based on working telephone number. That is outside of
12 this or somehow inside of this?
13 MR. ROGERS: It is an A-to-Y issue. The
14 resolution we have put in place in Wisconsin is that we
15 will validate up to the first field of an address, so we
16 don't, we are not going to validate the entire address,
17 but we would like, if you provide us an address, we will
18 validate like the street number, and the telephone number.
19 If you don't give us an address, which is
20 something we didn't bring up, but based on some kind of
21 make it uniformity, if you just choose not to give us an
22 address, we do it on working telephone number.
23 MS. LICHTENBERG: You will dial it in on
24 working telephone number. So I can migrate purely on that
25 basis.
2502
1 MR. APPENZELLER: Sherry, we still owe you
2 an answer to how we are going to implement the UNE-P
3 product that we talked about on Monday.
4 MS. LICHTENBERG: Right.
5 MR. APPENZELLER: That's part of what we
6 need to develop for you.
7 MS. LICHTENBERG: Right. I just wanted to
8 make sure that the discussions of moving things to July
9 did not subsume or somehow take away that option which we
10 see as a good interim step.
11 MR. APPENZELLER: No. However, you know,
12 the parsed CSR capability, the full parsed CSR capability
13 that you all are interested in, and so is AT&T and others,
14 that currently is in the March hold one.
15 MS. LICHTENBERG: Yes, I realize that.
16 MR. APPENZELLER: But we are talking about
17 an interim procedure.
18 MS. LICHTENBERG: That is correct.
19 MR. APPENZELLER: Right.
20 MS. SAMONEK: Joe, just to your point
21 because it goes to where we are coming from, in Madison I
22 think what you agreed to do is take that, and I guess what
23 I am looking for is an update. That's what we call
24 relaxing the set so that you didn't have to sync up or
25 didn't have to sync up the two CSRs. You were going to
2503
1 see if you could do it for the UNEs also.
2 MR. ROGERS: We will.
3 MS. SAMONEK: All UNEs, you are going to,
4 not just UNE-P, unbundled loops? Thank you.
5 MR. ROGERS: How do you do unbundled loops,
6 just telephone number?
7 MS. SEIDL: It's based on the CSR on a
8 reuse and the salary on a new loop, so it's variable. I
9 mean really you could have both things happen at the same
10 time.
11 MR. CHORZEMPA: I guess what I would like
12 to see -- I think I am O.K. with what you proposed, Terry,
13 where you are going. I have to confirm that with my boss,
14 but I think that should be fine. I think I should confirm
15 that after lunch today.
16 But I think what I -- what I would like to
17 see is some type of place holder in the master test plan
18 that says, obviously we are going to have something in
19 there saying that Ameritech's -- these A-through-Y
20 enhancements are going to be part of the test, test alert
21 done. There are three, three issues parties currently are
22 in disagreement on whether or not the functionalities need
23 to be provided. They are continuing to discuss those,
24 that might be arbitrated by this Commission or other
25 commissions, and depending on the outcome of these
2504
1 discussions, they might be part of the test.
2 No. 2, we get down to No. 2, I guess we
3 also reference the fact that in relation to the A through
4 Y, that we agree that you will provide that there are
5 still the discussions going on in relation to how those
6 are going to be provided and what time frames or whatever
7 else, and that those will be reflected in the test as
8 well.
9 MR. APPENZELLER: This is Terry
10 Appenzeller.
11 We appreciate that. I think we are
12 comfortable with what you are proposing to do.
13 It -- contained with what you are saying I
14 believe is that we need to provide for KPMG a piece of the
15 input to this collaborative that the Wisconsin A to Y that
16 are being worked in bucket 3 be made available to KPMG to
17 incorporate into the test plan.
18 Which I think covers some of the issues
19 you're talking about, Dave, in terms of further work this
20 summer.
21 I do believe we are going to probably need
22 another collaborative meeting, sometime in July, which we
23 probably ought to talk about when we get to the end of the
24 meeting.
25 For KPMG probably to finalize the test
2505
1 plan, we probably need some place holders between now and
2 July, when we meet again, to cover the cases that you are
3 talking about, and obviously there are some other pieces
4 that need to come into play for that master test plan.
5 One we talked about earlier is the performance
6 measurements collaborative needs to be in, for example.
7 And I think we are quite comfortable. I think the worst
8 thing we could do as of now is to go to the Commission on
9 something we don't really have a disagreement and let us
10 continue to work on the issues that we are working on,
11 whether they are in Wisconsin or whether they are here.
12 It's premature. And the timing issues, as
13 you mentioned I think, are clearly in the right
14 motivation.
15 For both sides. We don't want this test to
16 go any longer than you want it to go. We don't want to
17 have to wait if we don't have to.
18 MR. CHORZEMPA: When is the Wisconsin
19 prehearing? Is that the 8th?
20 MR. LENAHAN: The Wisconsin prehearing is
21 tomorrow, and I will be there on behalf of Ameritech, and
22 I plan to suggest to them the same thing we have suggested
23 to this collaborative, that on the timing issue we really
24 don't have an issue that I believe needs to be litigated,
25 that we commit to providing this functionality as quickly
2506
1 as possible, and this same commitment we have made here, I
2 will make to the Wisconsin hearing examiner, that
3 Ameritech will continue to push to escalate the deployment
4 of this functionality as soon as is practical. We will
5 continue to look at work-arounds or alternatives, to
6 accelerate the deployment of the functionalities so that
7 the testing can begin as soon as possible, and that the
8 tests should take the position that this has to be tested
9 as soon as it's -- as soon as we notify the parties that
10 we believe it's ready to get tested, it can be tested.
11 And if it takes until March, then that's to
12 our disadvantage. If we can deploy it sooner than March,
13 that's to everybody's advantage.
14 MS. SAMONEK: John, just to the two pieces,
15 or possibly three, that we are agreeing to let be resolved
16 from the FCC POR, that's the --
17 MR. ROGERS: Right.
18 MS. SAMONEK: If those are not resolved or
19 are resolved against us, we would reserve the right back
20 in Michigan and in Wisconsin to bring those open issues
21 back there again.
22 MR. LENAHAN: I understand that, sure. I
23 am confident that we will be able to work those issues out
24 like we have worked out many, many, many issues so far.
25 MR. CHORZEMPA: I think this proposal gets
2507
1 rid of A-through-Y issues in Michigan for now.
2 MR. LENAHAN: I think that's our view.
3 MR. CHORZEMPA: I think that's true. There
4 might be some master test plan issues we might need to
5 raise still, but I think we are still talking about that,
6 so I'd agree with that.
7 MR. LENAHAN: It sounds like Terry's
8 suggesting that there would be at least one other
9 collaborative here on the master test plan before we get
10 to the point of having to decide whether we have a problem
11 or not. That would be sometime in July.
12 MR. APPENZELLER: That's correct.
13 MR. LENAHAN: In the meantime I think the
14 test plan development can continue, you know, with place
15 holders depending on the outcome and timing of those
16 particular issues. So this should not delay in any way
17 the continued progress on getting to a final test plan.
18 MR. APPENZELLER: This is Terry
19 Appenzeller.
20 I don't think this is going to stop KPMG
21 from going forward with Version 1.3. I assume that's the
22 next one in the numbering cycle. That comes from the
23 input from these two days, that that, that we would expect
24 that that plan be put together in some reasonable period
25 of time before we meet again and review it at that time,
2508
1 in that July meeting.
2 I am only bringing up July as the
3 appropriate time just looking at the calendar. We have
4 before us probably the time frame that we are looking at,
5 and by then we have to bring in the UNE-P tariff,
6 remember. We have talked about that in the tariff
7 collaboratives.
8 So that's a big chunk of void in the plan
9 at the moment that needs to be filled and is very
10 important. So we will have that and we will also have
11 then at that time hopefully the performance measurements
12 module as well.
13 So it should be possible to develop a
14 more -- maybe a final plan in this July meeting, if we can
15 agree to maybe an amendment at some future time if some of
16 these other items don't get resolved.
17 And that again would lead to the
18 possibility of the test itself getting started after that
19 test plan is put together, because I believe KPMG needs to
20 get started in actual implementation within their
21 organization of syncing up with Hewlett-Packard and
22 getting geared up to do the test. And we need to give
23 them that signal that that's what we want them to do.
24 And I don't think we want to delay much
25 longer.
2509
1 MR. CHORZEMPA: I agree. I would just add
2 that I would like to submit before you come out with 1.3,
3 I would like to take a shot at codifying kind of some of
4 the exit criteria, some of the issues relating to what's
5 the scope of, how the scope of the test has changed, it's
6 going to take these A-through-Y enhancements as part of
7 it. You know, we can get that done early next week and
8 submit it to KPMG and everybody else.
9 But otherwise, you know, whenever 1.3 makes
10 sense to come out. I'm not sure you are saying you want
11 to wait for the UNE-P stuff to flesh out more before 1.3
12 or not.
13 MR. KERN: Let's -- what -- we can talk
14 about that as part of the next steps. I really want to
15 try and get back -- are we closed out with the A-to-Y
16 issues now?
17 MS. LICHTENBERG: Yes.
18 MR. KERN: I want to get -- Craig Brown
19 from Rhythms has joined us, and I want to get back to the
20 matrix to make sure his issues are resolved, and Tim, or
21 -- I don't know if you have still some smoking issues on
22 your last item. Let's try and close out the matrix before
23 lunch. When we come back from lunch, we will finish up.
24 UNIDENTIFIED VOICE: John, can I ask,
25 before lunch can I get some time before the presentation?
2510
1 I am probably going to hit the road after lunch.
2 Shouldn't take that long.
3 MR. KERN: Yes, we will save you a few
4 minutes at the end.
5 Craig, I think your first page is page 28,
6 item 123.
7 MR. BROWN: Right. This is with regard to
8 collocation. And Rhythms just believes that there should
9 be, the test plan make sure that the collocation intervals
10 that Ameritech is subject to are being actually met.
11 And in the chart -- it refers to A-to-Y
12 issues. My understanding is that that was not addressed
13 in the A-to-Y issues.
14 MR. ROGERS: I believe there is performance
15 measures on that, and they would have to validate the
16 performance measures, they would have to validate that
17 timing and stuff of when those things are in are correct.
18 MS. SEIDL: I need to understand this. You
19 are talking about not only the ASR submitted for the
20 collocation but also the cage and pulling the cable and
21 every final walk-through and the whole handoff, doing a
22 whole collocation beginning to end, which is great.
23 MR. BROWN: Right. The installation
24 intervals and for the different types of collocation.
25 And I didn't see that in the master test
2511
1 plan, I mean as far as the --
2 MR. ROGERS: But I don't think in the
3 master test plan that they put in every performance
4 measure. I believe that that is one of the -- at least
5 several of them, there's intervals for collocation.
6 Do you know that, John?
7 MR. LENAHAN: This is John Lenahan.
8 Yes. The performance measurements have
9 measurements for our collocation, the time it takes us to
10 respond to a collocation request, the time it takes to
11 provision physical and virtual collocation, and the due
12 dates missed for collocation.
13 And so, because we do have those
14 performance measurements, the test will evaluate our data
15 collection for those measurements, and the application of
16 the business rules to that data, and, of course, then the
17 process will include an evaluation of our actual
18 performance results or collocation provisioning, you know,
19 from receipt of request to the completion of the order.
20 So, Craig, although it's not specifically
21 called out for in the A-to-Y grid because I don't perceive
22 that anybody had a problem with the way we were doing it,
23 but it is clearly part of the evaluation that will be
24 included within this test.
25 MR. BROWN: So exactly how will it be
2512
1 evaluated?
2 MR. LENAHAN: It will be evaluated I think
3 indirectly as part of the performance measurements
4 evaluation family of the test, because there are
5 performance measurements associated with collocation.
6 Those measurements will be evaluated as to whether or not
7 we are collecting that data in a reliable way and whether
8 we are applying the business rules to that data so that
9 our performance measurements on collocation are accurate
10 and reliable.
11 That is what the test will look at. Then
12 the evaluation as part of this docket will look at our
13 actual performance for provisioning of collocation.
14 MR. ERINGIS: This is John Eringis from
15 KPMG.
16 I would add that the collocation and
17 network design verification and validation review does
18 include a pretty thorough review of Ameritech's internal
19 procedures for managing collocations. That review would
20 include that, that their internal MPs for managing
21 collocations at data, how it's managed, we would be
22 looking at, you know, actual data of -- you know, in
23 tracking -- you know, how they actually manage the
24 collocation, we would work with CLECs. We have to work
25 with various CLECs that are in the process of doing
2513
1 collocations during the test to get data from them.
2 Historical when we have done this review we have done
3 sampling of -- let me describe it this way: We have
4 taken a look at a number of collocation projects that are
5 in process, and, for those that are delayed, we go and do
6 some additional analysis of why they are delayed and was
7 there an issue with the CLEC, was there an issue with
8 Ameritech, and we come up with qualitative findings that
9 explain what our overall assessment is of the
10 effectiveness of the process.
11 UNIDENTIFIED VOICE: That's PPR Test 6.
12 That's page 43.
13 MR. ERINGIS: Right. So there is a pretty
14 thorough review. There's a number of ways that you get at
15 getting information about how effective the collocation
16 process is at Ameritech in the test point.
17 MS. LICHTENBERG: If I could ask a related
18 question, again just a point of information, in terms of
19 network design, what we have referred to in the Bell
20 Atlantic model as the network design process, the NDR
21 process, where a CLEC creates line class codes that show
22 how calls will be routed, et cetera, using shared
23 transport and blocking options, is there a similar
24 process, do we know yet, for UNE platform here in the
25 Ameritech region, or is that something that you will
2514
1 answer later?
2 MR. LENAHAN: I am not sure I understand,
3 because with UNE-P you take the network as it is currently
4 designed. You don't do anything.
5 MS. LICHTENBERG: In the Bell Atlantic
6 region -- and I am not saying good or bad, either way, I
7 am just -- because it's a -- it's an entry time line
8 issue. In the UNE platform issue, in the UNE platform for
9 New York we needed to create our own line class codes,
10 even though we were routing on shared transport and doing
11 the same routing, because they weren't using an AIN
12 solution to validate the routing because it's an older
13 network configuration, so it's just a point of
14 clarification of how I would introduce blocking options.
15 Do I use USOCs, et cetera? I assume that's going to be
16 documented as we --
17 MR. ROGERS: I guess the answer is we are
18 not -- we don't know for sure, but if it's not documented,
19 I think we are going to fail.
20 MS. LICHTENBERG: At some point I'll be
21 able to find that documentation. Thank you.
22 MR. ERINGIS: Craig, the test looks for it.
23 MR. KERN: Craig, does that take care --
24 MS. LICHTENBERG: I am looking for it, too.
25 MR. KERN: Does that take care of your
2515
1 concern on Issue 123?
2 MR. BROWN: I think it does.
3 MR. LENAHAN: I think probably the right-
4 hand comment is probably misleading on that one.
5 MR. KERN: Yes.
6 Remember we'll have another master test
7 plan that's going to be coming out so that you can confirm
8 that your issue is in fact taken care of.
9 MR. BROWN: O.K.
10 MR. KERN: I think 125 is the next issue on
11 page 29.
12 MR. BROWN: Right.
13 This just relates to coordinated testing,
14 particularly the DSL loops.
15 And I understand that this was addressed in
16 Wisconsin, or is being addressed. But it's been a big
17 issue for Rhythms, because we have not, up until now we
18 have not been able to get -- have loop acceptance
19 practical -- coordinated testing prior to loop turnover,
20 and even though we can, we do have that in other parts of
21 SBC, we just want to make sure we have access to that and
22 that this is tested.
23 MR. LENAHAN: Yes, the coordinated hot-cut
24 procedure, there's a sub team on cuts in general, and
25 clearly, xDSL loops would be within the scope of that
2516
1 team.
2 MR. ERINGIS: We can confirm that it's our,
3 it was our intent in this test plan to test TBE 4 to
4 include review of coordinated testing and other
5 coordinated provisioning procedures, so the comment here
6 is it is our intent to test that.
7 And we'll review the master test plan to
8 ensure that if that point isn't in there, it's too subtle,
9 that we amplify it.
10 MR. BROWN: Would that be -- how when does
11 that occur, for -- when would that occur in the
12 provisioning process? Is that 48 hours prior to turnover?
13 MR. ROGERS: It's in the sub team. I don't
14 know. I don't believe it's --
15 MR. BROWN: Has that been resolved?
16 MR. LENAHAN: That hasn't been finalized.
17 That's part of the sub team, when it's, when the pre-cut
18 testing is done and what's included.
19 MR. BROWN: O.K.
20 MS. SAMONEK: Do you have a member of that
21 team?
22 MR. BROWN: We have had someone attending.
23 MR. KERN: Cindy Salise has been your
24 representative. She's actually a member of the hot-cut
25 team who is working out these amendments and procedures.
2517
1 MR. BROWN: O.K.
2 MR. KERN: 136 I believe is next, on page
3 30.
4 MR. BROWN: Obviously the issue of loop
5 makeup is important to Rhythms as well as other DSL
6 providers and we just wanted to make sure that all the
7 necessary information is being provided and that those
8 processes are tested. And I understand that this is an
9 issue that's being dealt with in Wisconsin. Is it the
10 case that the testing on this issue will not be undertaken
11 until those improvements are made?
12 MR. ROGERS: The additional information on
13 loop makeup was provided last month. So all the
14 information is there.
15 There is a graphical user interface that's
16 going to be provided that obviously won't be tested until
17 it's provided, but it's within the scope of the test, if
18 that's what you're asking.
19 MR. BROWN: That is what I'm asking. So
20 you're saying that there's a place holder for that until
21 it's actually -- I mean but the test won't conclude until
22 that has been tested or is available and has been tested?
23 MR. ROGERS: Yes, that's correct.
24 MR. BROWN: O.K.
25 MR. ERINGIS: Let me -- this is John
2518
1 Eringis from KPMG Consulting. Let me comment as well on
2 points 1 and 2 in comment 136, that KPMG would not be in a
3 position to evaluate the adequacy and completeness of the
4 loop makeup information because we're not sure that that's
5 our role, to opine on whether the loop makeup information
6 provided is what we would be testing, whether or not any
7 commitment you made or any order that you have to provide
8 loop makeup information is in fact provided.
9 MR. LENAHAN: And to that point, John, we
10 agree with that. Whether the loop makeup information that
11 we provided was consistent with the UNE remand order and
12 included everything that was necessary was in fact a
13 debate in the Wisconsin collaborative, and people pointed
14 out that they wanted additional information, which we then
15 agreed to include.
16 So the content of the loop makeup
17 information should be something that you just take as a
18 given, and what you should be evaluating is whether or not
19 we provide that within the parameters and the time
20 benchmarks that apply to preordering information, and when
21 people request a loop makeup, do they get a loop makeup or
22 do they get a CSR.
23 MR. BROWN: O.K.
24 MS. LICHTENBERG: I would assume, however,
25 that in the long term, as we work closely with KPMG, that
2519
1 if we begin to find that this data is wrong, that we'll
2 bring that to both the Commission's attention and KPMG's
3 and that, you know, we'll work through it as a
4 collaborative body.
5 MR. ERINGIS: The accuracy and the
6 completeness of the information with respect to what the
7 standard is is what we intend to test. So yes, we would
8 expect that.
9 MR. BROWN: The next one we have is --
10 MR. CONNOLLY: What was No. 3 in 136?
11 MR. BROWN: That was just a typo.
12 MR. ROGERS: We agree with that one.
13 MR. BROWN: 143 was the existence or lack
14 of a GUI interface for obtaining loop makeup information.
15 You've said that that will be tested once it's available,
16 so I think that's O.K.
17 And 144, I understand -- I mean you would
18 be testing the manual processes as well for loop makeup
19 information?
20 MR. ERINGIS: We would expect to do that.
21 We would expect to test that on whatever way it's
22 available.
23 MR. BROWN: O.K. So, for example, if it
24 was available via EDI, whatever the way that a CLEC would
25 get that information is the way that we would go and get
2520
1 that information during the test.
2 MS. SEIDL: And it's available several
3 ways --
4 MR. BROWN: If it's available separate
5 ways, we would anticipate going over it in several ways.
6 MR. ROGERS: Quite a few of our preordering
7 interfaces, once we put them up on EDI -- not EDI, excuse
8 me -- in GUIs, we no longer provide a manual process for
9 doing that, and this may be the case in this one. We may
10 say once we provide you a GUI, we are not providing a
11 manual process of doing it.
12 I mean I would agree that if we have a
13 manual process of doing any of the things that should be
14 tested, I'm saying that we will definitively provide a
15 manual process once this was available for you to go to.
16 MS. LICHTENBERG: And I am assuming that
17 any process that is added or subtracted will be
18 communicated via the standard change control methodology.
19 MR. ROGERS: Uh-huh.
20 MS. LICHTENBERG: Thank you.
21 MR. CONNOLLY: Isn't it the case that there
22 are circumstances under which loop makeup information is a
23 manual process and there's a survey done or there's a tech
24 sent out and they actually prepare a written response for
25 that? Regardless of how that EDI or GUI transaction was
2521
1 sent to Ameritech, there is physical labor involved in
2 processing that request. Isn't that what this is talking
3 about?
4 MR. ROGERS: I guess just to be clear, if
5 there are manual processes in place, we agree they should
6 be tested like you say. In a case that for this one we
7 have to actually send a tech out to survey the thing and
8 they write it out and we send that back to the CLEC, yeah,
9 that definitely should be tested. I just didn't want to
10 blanketly say that there is a manual process for doing all
11 of it, just what's in place. You know, whatever is in
12 place should be tested, but there may not be a 100-percent
13 manual process for doing loop makeup, O.K.?
14 MR. BROWN: Tim, are you referring to the
15 sort of detailed manual process? I think that was
16 discussed in the POR to the extent that data isn't
17 available electronically --
18 MR. CONNOLLY: Yeah, right.
19 MR. ROGERS: Right. We would still get it
20 either through a GUI or an electronic request for it, but
21 once it's processed it may require us to do additional
22 work because it's not in the systems and we may end up in
23 some of those cases faxing back information. I'm not
24 saying we do, but if we did, it would most definitely be a
25 part of the test. I'm just saying that we may not provide
2522
1 a mechanism without getting them to produce a proper
2 change management process, submitting that request via a
3 manual way.
4 It's an evolving process. I just don't
5 want to say one way or the other how it's going to be
6 done.
7 MR. BROWN: 145 talks about just making
8 sure that DSL services are included in the test scenarios,
9 and I understand that that has not been addressed yet. I
10 mean the test scenarios haven't been discussed yet in this
11 collaborative; is that correct?
12 MR. LENAHAN: It's currently a product that
13 we offer, so ...
14 MR. KERN: This might be a good time to
15 interject. We're going to be handing out -- everyone has
16 received a soft copy of the test scenarios, and a hard
17 will be handed out at the end of the day, and it's going
18 to be a homework project for all parties to make sure that
19 the test scenarios that have been identified so far are
20 the right ones to be tested. And if parties are in
21 disagreement that a particular scenario should be tested,
22 we kind of need to know that. And my thinking was if a
23 test scenario is not going to be tested -- for example,
24 interim number portability could be a test scenario that
25 would not be tested because Ameritech doesn't offer
2523
1 interim number portability -- we just need to know that.
2 We need to get all the test scenarios identified and
3 nailed down for Appendix A.
4 So that's everybody's homework assignment.
5 MR. ROGERS: You get the inputs so KPMG can
6 put together Appendix A.
7 MR. KERN: Exactly. But I also need your
8 feedback to make sure that a proposed scenario is --
9 MR. ROGERS: They can either accept and/or
10 ignore.
11 MR. KERN: And right now there's only two
12 test scenarios related to line sharing, just from what we
13 can tell, so I guess, Craig, if you or other carriers have
14 specific line-sharing scenarios you want to have tested,
15 we need to get those in as soon as possible.
16 MR. ERINGIS: John, I think that would
17 probably address Craig's point 145 and 146. They look
18 like input for scenarios, one being line sharing and one
19 being xDSL, just the point that we should have those as
20 part of our overall mix of transactions.
21 So if there's other additional detailed
22 information that Rhythms would wish to submit, we would
23 welcome seeing any additional detail, and once you have a
24 chance to reflect on all the other scenarios that get
25 distributed, you can determine whether they're
2524
1 satisfactory or whether you'd have additional ones to add
2 to that. We'd welcome that input.
3 MR. BROWN: O.K.
4 MS. LICHTENBERG: I think that we need
5 to say, Craig, that since you are really the expert on
6 this --
7 MR. BROWN: Well, I wouldn't say that.
8 MS. LICHTENBERG: -- or Rhythms is the
9 expert, that we really need you to provide those scenarios
10 in as much detail as possible to make sure that those of
11 us who aren't as good at providing line-sharing scenarios
12 don't make mistakes or miss something.
13 MR. BROWN: O.K.
14 There are some places within the master
15 test plan where we think that -- master test plan itself
16 where it would make sense to add references to line
17 sharing. For example, in the testing, I think it's Table
18 VI-1 -- in my version it's page 71 --
19 MR. ERINGIS: Table VI-1 --
20 MR. BROWN: Right.
21 MR. ERINGIS: -- is on page 77 of Version
22 1.2.
23 MR. BROWN: Right. And just under
24 "Ordering," having something convert -- a subprocess
25 convert customers to line-shared loop.
2525
1 MR. ROGERS: Shouldn't it be on the
2 previous page under the resale at the top, that feed list
3 that we changed yesterday, the UNE-P and EEL to just add
4 line sharing to it?
5 MR. LENAHAN: I would say yeah. Line
6 sharing is a new unbundled network element. It's the
7 high-frequency portion of the loop, the way the FCC
8 referred to it. So it's another version of obtaining
9 access to an unbundled loop. It's just access to the
10 high-frequency portion. So it could be another bullet or
11 it could be a sub bullet of unbundled loops.
12 MS. LICHTENBERG: I would concur with
13 Craig, though, that we also need to add some specific
14 scenarios, which I believe we've already addressed, that
15 would go into the POP process table on 77. That would
16 specifically say --
17 MR. ROGERS: But the POP process -- I mean,
18 John, you can probably shed some more light on it, but to
19 me it looks like these are generic-type processes that
20 should be ran across all of these things we previously
21 identified.
22 MR. LENAHAN: They're not product-specific.
23 MR. ROGERS: They're not product-specific.
24 MS. LICHTENBERG: You're right, but there
25 are certain ones that don't apply to other things.
2526
1 I don't know, John. I submit you make the
2 decision.
3 MR. ERINGIS: We understand the issue as
4 it's being framed and I think we can come up with language
5 in the next draft that people are happy with. We
6 understand that we need to make it less subtle, that line
7 sharing is going to be part of testing, and we can
8 incorporate that point in a way that makes it clear in
9 this section.
10 MR. LENAHAN: Line sharing is a network
11 element.
12 MR. ERINGIS: Yes.
13 MR. BROWN: And I think we'd want to test
14 both the situation where a line, a loop is converted from
15 a voice loop exclusively to a line-shared loop, and then
16 the other direction too.
17 MR. LENAHAN: Right. Those are scenarios
18 that Sherry wants you to help the group with.
19 MS. LICHTENBERG: Pardon me?
20 MR. LENAHAN: Those would be scenarios
21 that --
22 MS. LICHTENBERG: Yes, that is absolutely
23 the case. And would you add line-splitting to that, which
24 we refer to when a UNE-P holder wants to add someone
25 else's high-frequency portion to the voice loop they have.
2527
1 MR. ERINGIS: A narrative e-mail sent out
2 is what we've done with all the scenarios so that everyone
3 has the visibility into them, so if we could have that
4 done after this workshop, that would be helpful.
5 MR. BROWN: On the same table, Roman
6 numeral VI-1, at least on my version I didn't see loop
7 makeup inquiry as one of the preordering processes.
8 MR. ERINGIS: That's correct. We have not
9 done revisions of this table yet based on the discussions
10 that are still taking place with regard to A-through-Y
11 issues, so we would expect to make that table -- that's a
12 good point.
13 MR. LENAHAN: This really should be added.
14 It's a new preordering function.
15 MR. ERINGIS: Yes.
16 MR. ROGERS: I would assume that that would
17 be done after the Rick Dishman Presents.
18 MS. LICHTENBERG: Right.
19 If I could add something else, now that I
20 look at this table, that I think we ought to put in as a
21 process KPMG looks at.
22 One of the issues that we're seeing in
23 other states are how we manage what we refer to as the
24 line loss report. That is, if a customer goes back to the
25 ILEC or migrates to another CLEC, the original holder of
2528
1 that customer's loop receives notification that we have
2 lost the customer so that we can see spilling. I don't
3 know whether that is implicit in terms of the testing of
4 scenarios for the disconnection of customers or the
5 migrating back, but we have seen a number of problems now
6 in other states where we have not received a line loss
7 report, therefore we have not known to stop billing the
8 customer. However, they have gone somewhere else and they
9 are now getting two bills. So I'd like to see that
10 tested. I don't know how Ameritech provides that line
11 loss report, but I'm sure that the Rick Dishman Show will
12 help us out there.
13 MR. ROGERS: We've got it covered.
14 MR. KERN: Craig, do you have any other
15 issues you wanted to --
16 MR. BROWN: Well, on that same table
17 there's no -- and I don't know how to express this or
18 exactly what form this would take -- but there's nothing
19 that looks at the conditioning issues, at least that I
20 saw, the processes that Ameritech undertakes when
21 conditioning is necessary or other special construction,
22 and I think that would be -- both of those have been big
23 issues. I mean obviously special construction has been
24 very controversial. I mean I would hope that KPMG could
25 take a look at that process, examine that process, the
2529
1 special construction process, and whether that is
2 adequate, and then also look at whether it would be
3 intervals for conditioning or whatever other measures
4 could be made.
5 MR. LENAHAN: Craig -- this is John Lenahan
6 -- I believe loop conditioning is part of the new facility
7 availability policy that is Issue A in the Wisconsin
8 collaborative, and so I would assume that the
9 documentation with respect to our processes and procedures
10 with respect to loop conditioning would be part of that
11 evaluation.
12 And again, we do have a performance
13 measurement that would determine whether or not we're
14 providing conditioned loops in the required intervals, and
15 that performance measurement will be evaluated as part of
16 the performance measurement evaluation. So I think it's
17 covered.
18 MR. BROWN: Now, what about the special
19 construction policy in general?
20 MR. LENAHAN: I'm assuming that that new
21 process, which we sent an initial process overview out on
22 June 2nd and we will provide the final process overview on
23 June 15th, that will be evaluated and assessed as to
24 whether or not we have internal procedures that support
25 those processes. That's clearly Issue A. That's probably
2530
1 the major thing that we've talked about in Wisconsin.
2 MR. BROWN: O.K. I guess I'm not --
3 MR. LENAHAN: Not loop conditioning per se,
4 but that process, which loop conditioning is part of.
5 MR. BROWN: And how will that be worked
6 into this process exactly?
7 MR. LENAHAN: Well, that's one of kind of
8 the last remaining inputs that we need to provide: What
9 precisely is the result to AA, and of those issues which
10 will be included in this test. So it would be
11 incorporated into the test when that final portion of
12 the --
13 MR. KERN: Let me try and state it a little
14 bit differently if I could.
15 I mean in the whole preorder and order
16 portions of this test they're going to be looking at the
17 availability of loop makeup information, which would
18 include loop conditioning as well as any special
19 construction process, because that's all part of the loop
20 makeup area, and I think they would be looking at what the
21 process is, does the process work as it's documented to
22 work, and the performance interval associated with that
23 process.
24 So the test plan -- and please, Joe,
25 correct me if I'm wrong; this has been my understanding
2531
1 -- the test plan wouldn't actually specify the new system
2 enhancements and the functionalities coming on with A to
3 Y, but they are incorporated into the overall process that
4 the test is covering in terms of preorder, order,
5 provisioning, repair and maintenance. Is that a --
6 MR. ERINGIS: Yes.
7 MR. LENAHAN: That's a very good way to
8 state it. It's part of our overall provisioning. It
9 seems to me at a minimum it's part of our provisioning
10 processes which will be evaluated.
11 MR. ERINGIS: We would concur with that.
12 It will be evaluated as part of TBE 4.
13 MR. KERN: And I think, you know, one thing
14 that may help people is when KPMG rewrites the test plan,
15 as I think John already has indicated, he will try to
16 elevate the --
17 MR. LENAHAN: Put some of the words from
18 the AA issue --
19 MR. KERN: -- put some of the words from A
20 to Y, and more importantly to the data CLECs, you know,
21 put a little bit of emphasis that line sharing and xDSL
22 services are going to be included in the test or they're
23 not lost simply because they may not be stated as visibly
24 as they would like. I think some more words to that
25 effect may help.
2532
1 MR. BROWN: Right. And I guess I just want
2 to make sure that would also include an analysis or an
3 examination of the special construction policy just beyond
4 -- I mean I'm not familiar with this process overview that
5 came out on June 2nd, but I mean under the current process
6 we've had a lot of -- one of the biggest problems recently
7 has been the situations where we order a loop and then we
8 are told that there are no facilities available.
9 MR. KERN: That is exactly what the new
10 process is going to try to identify. If there's a problem
11 with facilities earlier in the process, that should be
12 identified earlier and communicated to you earlier.
13 Is that correct?
14 MR. LENAHAN: That's correct.
15 MR. KERN: I think what you really want to
16 go at is if there truly is a problem and there's no
17 facility that's available, is Ameritech's process and
18 procedure reasonable.
19 MR. BROWN: Well, I mean it's one thing to
20 the notification that there are no facilities available,
21 but it's also just the fact that they're claiming that
22 there are no facilities available. In other words, my
23 understanding is that in California SBC has a process in
24 place where facilities are provided. If there aren't
25 facilities in place for that particular order, work is
2533
1 undertaken to provide those facilities, and so that the
2 CLEC actually can provision the loop and it doesn't just
3 reach a dead end.
4 And so to the extent we're getting hundreds
5 of these notifications, I mean these are customers we
6 can't serve, and I just would want to look at that.
7 MR. LENAHAN: I think, Craig, that if you
8 read the policy, that that's precisely what has been
9 addressed.
10 MS. SEIDL: So they won't stop dead in the
11 water. That is a very valid point because that's what
12 happens today. There's just none.
13 MR. KERN: And I'll verify I did send out
14 that revised -- the first part of that policy, I did send
15 that out.
16 MR. BROWN: O.K.
17 MR. KERN: You might want to double check
18 your e-mail. If you don't have it, I can resend it to
19 you.
20 MR. BROWN: O.K.
21 MS. SEIDL: I didn't read that policy as
22 such, but I can go back and reread it.
23 MR. KERN: That was just the first piece of
24 it and there's more pieces coming.
25 MR. ROGERS: Well, I guess beyond that, I
2534
1 don't believe the test is going to test whether or not
2 it's the right policy, it's going to test whether or not
3 we're adhering to the policy presented. So if the
4 policy -- if it's viewed as being the policy is bad, I
5 don't think the test is the place that has to get that
6 evaluation.
7 MR. BROWN: Well, is there anywhere in
8 this --
9 MS. SEIDL: I was going to say how are we
10 going to account for that? I mean that it's O.K. just to
11 say oop, our policy says that we can't provide the
12 facilities anywhere, but that's what the policy stated so
13 it's O.K.? How are we accommodating for the fact that
14 just because it's a written policy doesn't make it -- I
15 don't know how to say this. I mean if it's a bad policy,
16 this place is where I think we should be bringing it up.
17 MR. LENAHAN: We think it's a significant
18 improvement, the policy is a significant improvement over
19 the facility availability process, and that was the intent
20 in putting it out. And to the extent when you do review
21 it, if you have questions, you know, let us know.
22 It has been the topic -- and John can
23 confirm this -- of extensive discussion in Wisconsin with
24 small, medium and large carriers, and each type of carrier
25 has unique needs. All the carriers who really were active
2535
1 were carriers who buy unbundled loops, so this is a real
2 issue for them, and I think we responded to the concerns.
3 So I think the policy is a good policy.
4 MR. ANDERSON: Well, let me add, I think
5 there is opportunity as this process -- we are not yet at
6 the point where we have filed our checklist compliance
7 details on each of the 14-point checklists, which is
8 separate, obviously, from the test, and we will as part of
9 that, as part of our loop compliance and access to
10 unbundled network elements, we will have to address this
11 issue, and concerns can be raised at that time. As John
12 Kern's indicated, it has been discussed extensively in
13 Wisconsin. We've listened to it, we've made
14 modifications, and we will present that as part of our
15 evidence of our checklist compliance and parties have a
16 chance to respond.
17 MR. O'BRIEN: This is Tom O'Brien. The
18 concern ultimately gets addressed through performance
19 measurements. One of the issues in the performance
20 measurements collaborative is how do you measure the
21 effect of special construction policies and the notices
22 for the need for BFR on how that affects the way CLECs can
23 get service to a customer versus the way Ameritech's
24 retail end would be able to get service to a customer in
25 the same circumstances, and I believe that the performance
2536
1 measurements have been developed and defined to try and
2 get at that distinction, and, of course, that's where the
3 problem shows up, is that we're all floundering because we
4 have to decide whether or not we want to spend thousands
5 of dollars to get the loop to correlate where the
6 (unintelligible) doesn't.
7 And so that's really where this issue
8 bubbles up as it affects the third parties' tests.
9 MR. BROWN: And by retail, you're referring
10 to AADS?
11 MR. ANDERSON: In your instance, yes, where
12 you're concerned.
13 MR. O'BRIEN: Yes. The disparate effect
14 wherever it falls out.
15 Now, I think one of the things that may
16 still be open for discussion is does that fall into --
17 does the affiliate get lumped in with all other CLECs or
18 are we going to make sure that their data affiliate is
19 treated as Ameritech retail for purposes of the test.
20 MR. BROWN: I think you need to look at
21 both. I mean you need to look at the case of, I guess on
22 the retail side, in the case of ISDN, and similar
23 conditioning needs and also the affiliates' needs.
24 MR. ISIOGU: Let me see if I understand the
25 issue about facilities being available. Is it the
2537
1 contention of the CLECs that all you need to establish is
2 that when the ILEC tells you that facilities are not
3 available, they are also equally unavailable to the ILECs
4 on the retail side, but not that you want the ILEC to go
5 out and use a facility to accommodate your needs. Is that
6 the same thing or two different issues?
7 MS. SEIDL: Two different. Both valid but
8 two different things. Both things can happen and are
9 happening, and we want to make sure that not only if I
10 came in as a CLEC and I wanted an unbundled loop I can
11 service you, and they come back and say no, you can't, but
12 me, Ameritech, I can service you because I happen to have
13 it on a SLC. So you get service by Ameritech but I cannot
14 service you.
15 The other one is if there only is a SLC out
16 there, what are you going to do about it. I mean are you
17 going to build another facility so I can service you or
18 just drop it dead. So Nextlink cannot service you ever in
19 this building, only I, Ameritech, can.
20 So there are two issues but they're both
21 very valid issues.
22 MR. ANDERSON: And that is what the policy
23 addresses, Orji.
24 MR. ISIOGU: The second part or the first
25 part?
2538
1 MR. ANDERSON: Both parts.
2 MR. BROWN: Just to respond to your points
3 about the policy, I understand that this is designed to be
4 responsive to the comments that were brought up to
5 Wisconsin, but --
6 MR. LENAHAN: Including Rhythms'.
7 MR. BROWN: But it is the case that this
8 policy came after these discussions, right?
9 MR. LENAHAN: The policy followed the
10 discussions.
11 MR. BROWN: So I mean I guess in my mind it
12 would be helpful for there at least to be the opportunity
13 here to discuss the policy and whether it really has
14 responded to the input of the CLECs.
15 MR. ANDERSON: In the OSS collaborative?
16 MR. BROWN: I mean somewhere in these
17 collaboratives and prior to the time that you actually
18 have filed your application.
19 MS. LICHTENBERG: One would assume -- let
20 me see if I can put this in a little perspective.
21 A policy exists and it will either be
22 followed or not, and KPMG will see that. They will look
23 at the process. I would assume also that as part of the
24 KPMG due diligence they will look at the process as it
25 applies to retail in some manner of speaking. I know you
2539
1 go in and you look at does the retail group have to stand
2 on its head when they submit orders or do they do it the
3 other way.
4 In addition, the metrics themselves, I
5 believe, will look at whether or not CLECs are getting
6 parity in terms of the provision of these loops. If every
7 time I order an unbundled loop it's not available, but
8 every time a retail -- or I assume it's just disaggregated
9 to the AADS subsidiary, they get it, it's always available
10 -- that should show in the metrics, which would also be
11 part of what will be tested against in this test.
12 Both of those I think implicitly give you
13 ability to comment on the validity and how well the
14 process works. Is that correct?
15 MR. CHORZEMPA: Let me say that I'd
16 anticipate -- this is Dave Chorzempa from AT&T -- that
17 this process, we just got it on June 2nd. I think I heard
18 John saying it's not complete yet.
19 My understanding is that in Wisconsin we're
20 going to continue to talk about the process as well. So
21 it's going to be tied into this test, but I think your
22 question is do we have a venue to talk about it --
23 MR. LENAHAN: Right. And the answer is
24 yes.
25 MR. CHORZEMPA: -- and I think we do.
2540
1 MR. KERN: I want to emphasize to people
2 that when you look at the Wisconsin A-to-Y issues, the
3 ones that have been classified as Category 3, there are
4 still open issues simply because the new policy or
5 procedure has not been deployed yet or is in the process
6 of being deployed and parties need to assess whether that
7 new policy or procedure actually fixes the problem that's
8 been identified.
9 That's why the Category 3 issues remain
10 open, but parties are saying we're not in dispute or we're
11 not at an impasse yet. We just need to see what the
12 policy is. We need to see if it fixes my problem.
13 If it doesn't fix the problem, at least in
14 Wisconsin, we have a second hearing date set up late fall
15 to go to hearing.
16 So I wouldn't categorically say that you
17 don't have an opportunity to respond to the new process if
18 it doesn't fix your needs. I think you do.
19 MR. DENNISTON: John.
20 MR. KERN: Jim Denniston.
21 MR. DENNISTON: I think another important
22 aspect to see whether the new policy in fact complies with
23 Michigan law -- Michigan has had two Commission cases
24 addressing, you know, when facilities are available and
25 when they are not, and my broad summary of those two cases
2541
1 is that facilities always exist if the request for
2 facility is in Ameritech Michigan's serving area. In
3 other words, you can never get rejected based on a
4 facility request.
5 MR. LENAHAN: I'd just as soon not get into
6 a discussion on PRE 1 or PRE 2, which were appealed, and
7 the district court interpreted those opinions, and we have
8 said, if the policy's not consistent with Michigan law,
9 then it has to conform to Michigan law. I think it does.
10 MR. DENNISTON: You are not deferring to
11 Wisconsin.
12 MR. LENAHAN: We are not.
13 MR. CHORZEMPA: The only thing is we view
14 Wisconsin is a place we are going to talk about. That's a
15 place where we are going to talk and negotiate, not to say
16 that we are deferring these issues to Wisconsin from
17 Michigan.
18 MR. LENAHAN: Right. Right.
19 MR. KERN: We have always been very
20 specific whenever an agreed-to issue would come to another
21 state but still needs to be modified, if necessary, to
22 conform to any state-specific issue.
23 MR. LENAHAN: Any policy in Michigan has to
24 conform to Michigan law, we understand that.
25 MS. SCHNEIDEWIND: Am I correct in this
2542
1 particular case there are certain modifications to the
2 policy that are applicable in Michigan because of these
3 cases?
4 MR. ANDERSON: Yes.
5 MR. APPENZELLER: John, I might add, to
6 feel more comfortable, there are dates associated with
7 implementation of the Category 3 issues. They are the
8 dates that I came up with that are in that report that we
9 are on the hook for to implement, and this new policy
10 really has a 6/15 date for it. We haven't seen it in
11 complete form yet. It's still in piece part.
12 So, as AT&T and MCI mentioned, we are still
13 negotiating some of these issues. As you will find on all
14 of the 20 or so Category 3 issues, they're being
15 implemented and are in various stages of discussion all
16 through the summer.
17 And so what we intend to do is to take a
18 process that we are using for those Category 3 issues and
19 import it over here as well and apply it to Michigan, but
20 you may not have something that is a done deal yet that
21 you can import directly, make some time, to work through
22 some of the issues, and this is one of them. Hot cuts is
23 another, for example, we are still working on.
24 We just haven't disagreed with one another,
25 so there is a process, if that occurs, and that's another
2543
1 hearing in Wisconsin. We may need another process here,
2 depends on the application in Michigan.
3 MR. KERN: Does that cover all your issues,
4 Craig?
5 MR. BROWN: Just except one other point of
6 clarification that as far as conditioning and special
7 construction that tests would look at whether retail
8 customers were being treated in the same way as CLECs.
9 MR. ERINGIS: That all depends on whether
10 the -- that all depends on whether the policy -- I mean,
11 if the policy is explicit that this is what, this is how
12 it's going to work, then there wouldn't -- you know, it
13 would be inappropriate to say it's not at parity to retail
14 because the policy -- I'm not sure how to address that
15 question because I would need a more specific example of
16 -- I would guess that the policy always takes precedence,
17 whatever policy gets hammered out. The focus of it is on
18 compliance.
19 MR. LENAHAN: The parity will be
20 demonstrated by the performance measurements and the
21 evaluation should be on adherence to the policy.
22 MR. BROWN: I guess parity, at least in my
23 mind parity would include, it would mean that the retail
24 customer is treated in the same way as the CLEC and
25 including situations where -- I mean, if the CLEC is
2544
1 charged for certain things, and the retail customers are
2 not, then that would not be in parity, and that would
3 include both special construction and condition.
4 MR. CHORZEMPA: This is Dave Chorzempa.
5 I think the scenario that we -- that has
6 been discussed in Wisconsin that I remember is certain
7 carriers brought forth examples of instances where
8 Ameritech says facilities aren't available for a customer,
9 and the customer calls Ameritech the next day and all of a
10 sudden facilities are available, the customer is served.
11 And I think as I remember the discussions there, the CLECs
12 asked for Ameritech to somehow be able to allow CLECs to
13 track that, if that's happening, in whatever process they
14 put forth for a loop assignment and facilities
15 availability.
16 I haven't read what came out June 2nd, so I
17 don't know if it does address that.
18 MR. BROWN: I guess it's a question of both
19 facilities availability and even where the facilities are
20 available, just a question of if those charges are being
21 assessed on CLECs but not on the retail customers.
22 MR. KERN: O.K. Let's go back to Issue
23 189. This was a list of issues that AT&T had identified
24 or actually listed, KPMG's initial concerns from the last
25 MTP, and Dave or Kim or Joanne, I don't know if you got a
2545
1 chance to take a look at all this to see which have
2 already been addressed or which have not.
3 MR. CONNOLLY: I did my homework, Mr. Kern.
4 MR. KERN: Good man.
5 MR. CHORZEMPA: I reviewed it.
6 MR. KERN: Joanne did, too.
7 MR. CONNOLLY: One is definitely open, has
8 not been covered in our discussions. That would be on
9 page 44, the fifth bullet point down: It is unclear if a
10 major software release will take place during the test
11 period.
12 I think the answer is definitely yes, but
13 it was an issue raised by KPMG in its initial review, and
14 I'd say that there isn't anything in the test plan that
15 brings up the point that was raised in the Common Carrier
16 Bureau letter to U.S. West that was circulated to all the
17 other ILECs and major participants in the previous case,
18 where the Common Carrier Bureau said that the changed
19 management evaluation needs to concern at least one major
20 software release during its -- the internal third-party
21 test.
22 MS. LICHTENBERG: Tim, if that were added
23 to the test plan and the changed management section, would
24 that satisfy this concern?
25 MR. CONNOLLY: I believe so.
2546
1 MS. LICHTENBERG: Would KPMG add it?
2 MR. ERINGIS: Yes.
3 MR. LENAHAN: We certainly don't object, as
4 long as it's agreed that the enhancements that we have
5 been talking about qualify as major enhancements, which I
6 think you agreed to.
7 MR. CONNOLLY: If they are, what they were
8 purported to be, significant enhancements.
9 MR. APPENZELLER: Otherwise we would be
10 defining is again.
11 MR. ERINGIS: There is a statement on page
12 33 of Version 1.2 that says, in the first paragraph under
13 Description, "Additionally, data will be reviewed to
14 evaluate changed management of a major software release
15 from initiation through implementation."
16 MS. LICHTENBERG: Closed.
17 MR. CONNOLLY: The last item on page 44,
18 "It is unclear what switch types will be included in the
19 test."
20 I wonder if that isn't something that we
21 find out from Mr. Dishman Presents.
22 MR. DISHMAN: No, I don't think so.
23 Seriously.
24 MS. LICHTENBERG: Could you tell us what
25 switches exist in your network just -- you know, you have
2547
1 got 5E's, you have got Siemens, you have got --
2 MR. ANDERSON: Nortel, Siemens, and Lucent.
3 MS. LICHTENBERG: Nortel, Siemens, and Lucent.
4 MR. ANDERSON: Yes.
5 MS. LICHTENBERG: I thought I saw that
6 actually in the 1.2 version. One would assume, therefore,
7 that when KPMG sets up its test plan, it will include one
8 from column A and one from column B and one from column C.
9 MR. ANDERSON: Assuming in Michigan we
10 still have all three.
11 MS. LICHTENBERG: Right.
12 Then that would have to be validated.
13 MR. ANDERSON: Yes.
14 MR. APPENZELLER: Tim, what detail do you want?
15 MR. CONNOLLY: I raised these, Terry, as
16 issues that I hadn't seen that there was closure on from
17 the point where KPMG originally raised these issues as
18 unclear to them, and they were, they raised them as
19 perhaps impediments to completing their job of authoring
20 this master test plan, and I brought them back up because
21 I thought also that they may still be impediments to
22 finishing this task writing the MTP.
23 So, identifying what switch types are I
24 believe has significant consequence in fleshing out the
25 actual scenarios, determining what sort of CLEC facilities
2548
1 need to be involved, what type of call type scripts would
2 be involved, et cetera, et cetera.
3 So I think that, as Sherry was pointing
4 out, it's appropriate to know what the switch types are
5 and to have representation of those in test transactions
6 and in perhaps even as far as provisioning goes.
7 MR. APPENZELLER: So it's what John and
8 KPMG needs that we need to respond to, then.
9 MR. ERINGIS: We would propose that in the
10 test band we will re-review it to ensure that there is a
11 statement to the effect that says that to the extent that
12 there are different switch types in Michigan, that that
13 needs to be considered in our design of the test band and
14 the test cases and the test instances and the test
15 scenarios.
16 In performing our design of the test band
17 specification, we would need to have specific information
18 provided by Ameritech about what switch types there are,
19 where they are, and --
20 MR. APPENZELLER: How many lines.
21 MR. ERINGIS: Right. We can do that.
22 MS. LICHTENBERG: Could I also request that
23 when we have the full UNE-P tariff if there are any
24 restrictions in the UNE-P provision based on switch type,
25 that that be -- I wouldn't expect there would be such, but
2549
1 maybe there's some old step offices that you can't use or
2 whatever.
3 I just want to see it in writing.
4 MR. ANDERSON: All right. We wouldn't put
5 in a tariff in Michigan, I wouldn't anticipate we would
6 put in the fact that we don't have any steps.
7 MS. LICHTENBERG: What I would want to see
8 is that there are no limitations on where residential
9 UNE-P could be provided and here are business UNE-P
10 restrictions or whatever.
11 MR. APPENZELLER: Got it.
12 MR. KERN: Is there any other issues you
13 have got, Tim?
14 MR. CONNOLLY: No. I found that the other
15 items, the other 15 or 16 items, in this list were covered
16 either in 8A events coming or tariff events coming, the
17 volumes discussion that we had this morning, areas that
18 will be discussed in Mr. Dishman's presentation, and last
19 but not least, in the performance measures as they are
20 brought in.
21 MR. KERN: Thank you.
22 Mr. Dishman, you have about five minutes to
23 talk about June 13th and 14th. Just -- I mean I just want
24 to let everybody know that we have everybody in contact
25 with Hewlett-Packard about when we should be bringing them
2550
1 into this process, and Hewlett-Packard is going to be in
2 attendance on June 13th and 14th, and -- just so the
3 parties aren't surprised when they show up.
4 MR. CHORZEMPA: We had a couple other open
5 issues that we did homework on. I don't know if you want
6 to swing back to that later. The DOJ issue --
7 MS. LICHTENBERG: Do you want to do it
8 after lunch?
9 MR. CHORZEMPA: We can do it after lunch.
10 MR. KERN: After lunch.
11 MR. DISHMAN: Everybody should have gotten
12 a copy of the accessible letter. We did issue an
13 accessible letter. I believe it went out Monday morning.
14 It has on it the presentation outline.
15 MS. LICHTENBERG: Rick, on the accessible
16 letter, you issued it by SBC, that accessible letter?
17 MR. DISHMAN: I did through the SBC Web
18 site.
19 MS. LICHTENBERG: I did not receive it.
20 John, didn't you distribute it?
21 I understand that. I am just concerned, if
22 you were using the SBC distri, it may not be working.
23 MR. DISHMAN: I will check that. People
24 should have it. It has an outline of the presentation is.
25 It also has a statement of what it's not, too. It sets
2551
1 the stage.
2 Again, the goal of this presentation is a
3 40,000-foot view of a little bit of outside the curtain,
4 basically what the CLECs interface with, how the account
5 teams are established, the connection there, and then to
6 behind the curtain, which are systems that are not
7 documented that will be the first time CLECs and KPMG and
8 HP will be able to see. That's back into our Legacy
9 process, what happens during that process.
10 One concern I have, we have got it set up
11 now. It's being hosted out of downtown Chicago. I know
12 we have got some hotel problems down there. People are
13 working through that.
14 But that site within itself holds about a
15 hundred people. So if CLECs are planning on bringing five
16 or better, we may be in trouble with space.
17 We've got to be -- I am a little concerned
18 about that.
19 So we do have video sites set up, one at
20 Hawthorn Estates in Chicago, another one in Madison,
21 Wisconsin. We just set up two brand new ones that were
22 not on the announcement, one in Cleveland. I have got to
23 get the address and get that out sometime today. John,
24 I'll probably get it to you and just have you distribute
25 it. And we also have one set up in Indiana.
2552
1 So if there's -- CLECs are planning on
2 bringing lots of people, I would ask you to use the video
3 sites. Don't all come to 350, Chicago.
4 MS. LICHTENBERG: Would you like RSVPs with
5 the number of people we'll have?
6 MR. DISHMAN: That would be extremely
7 helpful.
8 MS. LICHTENBERG: And how would you like --
9 shall we send that to John Kern, or what is the best way
10 to do it?
11 MR. DISHMAN: Send it to me.
12 MS. LICHTENBERG: Send it to you.
13 MR. DISHMAN: That's
15 And send -- what I would like to know is
16 how many people are coming and what sites you plan on
17 attending, where you plan on attending.
18 MR. KERN: Rick, let me make this
19 suggestion: Why don't you do a short e-mail and send it
20 to all three distributions, Michigan, Wisconsin, and Ohio,
21 because they have all been invited.
22 MR. DISHMAN: I don't have the
23 distribution.
24 MR. KERN: If you get it to me, I will
25 distribute it to all the collaboratives, and they will
2553
1 RSVP to you with that information. Identify what
2 information you want. I will forward it on.
3 MR. DISHMAN: I will get this to you this
4 afternoon.
5 And we are still working on the video
6 conference site in Michigan. We don't have one secured at
7 this time.
8 That's it.
9 MR. KERN: Is this a good time to break for
10 lunch?
11 Break until 1:00 o'clock.
12 (At 11:50 A.M., a recess was taken until
13 1:00 P.M. of the same day, Wednesday, June 7, 2000.)
14 - - -
15
16
17
18
19
20
21
22
23
24
25
2554
1 Lansing, Michigan
2 Wednesday, June 7, 2000
3 1:05 P.M.
4 - - -
5 (The proceedings were resumed pursuant to
6 the adjournment.)
7 MR. KERN: O.K., are we ready to begin?
8 We have a few more things to cover. We
9 want to be out of here by 3:00 o'clock. What I want to do
10 is go back to the matrix briefly and I think AT&T had one
11 or two small homework assignments they were responsible
12 for last night.
13 MR. CONNOLLY: And I reported on my first
14 assignment.
15 MR. KERN: You did, and you did a wonderful
16 job.
17 MR. CONNOLLY: Thank you, Mr. Kern.
18 MR. ROGERS: Oh, what a kiss-up. There are
19 certain things I've got to get on the record.
20 MR. CONNOLLY: And the second one, Mr.
21 Kern, was on issues that were raised by the DOJ, FCC, and
22 so forth, that are not otherwise covered in the test plan,
23 and the one of the several pages' worth that I've got
24 cites, one stands out in the DOJ's Appendix A on page 3,
25 and I'll read it:
2555
1 "In addition to automation in general,
2 adherence to industry standards for interfaces between
3 carriers in particular will generate further economic
4 benefits both for CLECs and incumbents."
5 And I think that, as we talked yesterday
6 about having KPMG provide an opinion on the extent to
7 which the interfaces conform to standards, would also
8 address that.
9 MR. KERN: O.K.
10 MR. CHORZEMPA: And on that issue we owe
11 the collaborative a list of those standards we're talking
12 about, and we're working on that. So that was not an
13 overnight assignment, Mr. Kern.
14 MS. LICHTENBERG: Did you bring your apple
15 for the teacher?
16 MR. KERN: Apples don't count.
17 O.K. That concludes the matrix.
18 MR. LENAHAN: Can I clarify? What just
19 happened?
20 MS. SEIDL: They still have a homework
21 assignment.
22 MR. LENAHAN: O.K.
23 MR. KERN: Yeah. That's all you need to
24 know.
25 MR. LENAHAN: Thank you.
2556
1 MR. CHORZEMPA: I think that what we left
2 uncovered was the one issue that would be found identified
3 by the DOJ, FCC and the MPSC that we felt was not
4 addressed in the master test plan, what we just quoted. I
5 thought that was an issue we already brought up yesterday
6 and kind of deferred for further homework.
7 MR. LENAHAN: I would prefer that we rely
8 on the FCC orders with respect to the adherence to
9 standards as opposed to the Department of Justice's 1997
10 evaluation. So to the extent the FCC has addressed the
11 extent that a company must adhere to industry standards, I
12 think that's a fair addition to the test plan, but I would
13 prefer that we rely upon the FCC's articulation of that as
14 opposed to the Department of Justice's, because it's the
15 FCC that I'm filing application with. They have addressed
16 this in their Bell Atlantic New York order.
17 MR. KERN: We need to circle back one more
18 time to the A-to-Y issues. I think WorldCom had a
19 question they wanted to have some clarification on.
20 MS. LICHTENBERG: This is really a
21 clarification. In the A-to-Y issues there is a certain
22 package that I guess had been referred to as those that
23 are deferred for timing. One of those issues, the GUI, is
24 critical to WorldCom, and I think particularly to the
25 smaller CLECs that have not done or will not do EDI
2557
1 development.
2 My question is, how do we deal with that
3 here? I would assume that when it appears at some date in
4 the future, hopefully the short future, it gets tested,
5 but I'm unclear about where we are with those timing
6 issues, the whole raft of them. Can someone help me?
7 MR. APPENZELLER: Sherry, is it just the
8 GUI timing issues you're concerned with?
9 MS. LICHTENBERG: I think it's the whole
10 bucket of timing issues that we didn't really talk about,
11 and I know something's happening with them in Wisconsin,
12 Terry, but I'm just unclear. The GUI is highest in my
13 mind.
14 MR. ROGERS: In Wisconsin there are dates
15 for all of them, and those are the dates as they sit
16 today. We have said it is in our best interest to try to
17 move those dates up, but right now we can't sit there and
18 say there's any movement or will guarantee to be any
19 movement on those dates. But the dates as they are are in
20 that A-to-Y document that John distributed.
21 MS. LICHTENBERG: And so the A-to-Y
22 document in Wisconsin for issues that are still open, such
23 as trying to move the timing up, is still part of what
24 we're dealing with here as well once they get settled.
25 They're open here just like they're open there?
2558
1 MR. ROGERS: I think the issue on moving
2 the date up is what Terry and them proposed; that instead
3 of arbitrating what the date should be, it is now, because
4 we agreed that it all is included, it's in our best
5 interest to move them up as quick as we can.
6 MS. LICHTENBERG: O.K., thank you. I just
7 wanted to clarify that.
8 MR. CHORZEMPA: On behalf of AT&T I would
9 just say that I would not object to deferring all the
10 arbitration issues that have been teed up in Wisconsin
11 until the FCC POR runs its course.
12 In relation to whether or not I wish to
13 continue to litigate the timing issues after that, I'm not
14 sure of the answer, and hopefully I didn't give you an
15 impression that I was saying that I wouldn't litigate
16 them. I might not because I understand the incentives on
17 your part have changed, but that's something I have to
18 assess, and that relates to when my clients might want to
19 enter the market.
20 MR. APPENZELLER: Sherry -- Terry again --
21 in this ALJ report you should have on page 10 and 11 the
22 dates that we committed to implement -- the 17th, it looks
23 like -- Category 3 issues, and they go anywhere from 6/15
24 to 9/30, is the farthest-out date. Those were the end
25 dates for those particular items. There are probably
2559
1 interim steps in some cases that we're going to have to
2 do.
3 MS. LICHTENBERG: Terry, can you help me
4 here? I can't find the GUI on this list, and it may just
5 be me.
6 MR. APPENZELLER: Well, GUI is in Category
7 1.
8 MS. LICHTENBERG: Oh, thank you. So if I
9 look at Category 1 --
10 MR. APPENZELLER: That was the one that we
11 said March of '01.
12 MS. LICHTENBERG: Right. And we're at an
13 impasse.
14 MR. APPENZELLER: And we are still working
15 on that, and if we can get it worked up, because we have
16 the incentive to move it up, we do.
17 MS. LICHTENBERG: O.K.
18 MR. APPENZELLER: And then we would work on
19 the UNE-P and other things where they work around GUI in
20 the interim.
21 MS. LICHTENBERG: Yes. And, you know, I
22 would certainly be open to work around solutions.
23 MR. APPENZELLER: So that's basically where
24 it sits.
25 MS. LICHTENBERG: Thank you. Just wanted
2560
1 to make sure we hadn't lost it.
2 MR. KERN: I want to circle back to one
3 other issue, and that was the 911 testing. I just want to
4 make sure people are clear about what's going on with the
5 911 issues.
6 MS. LICHTENBERG: Ameritech, WorldCom, the
7 Attorney General and anyone else who wishes to participate
8 will meet to review the 911 testing that WorldCom
9 undertook with Bell Atlantic and the New York Public
10 Service Commission and the New York PSAPs to come up with
11 a process to ensure that UNE-P customers primarily are
12 able to place 911 calls to the proper PSAPs with no
13 translation problems, and we'll report back to the
14 collaborative on what we come up with. Is that O.K.?
15 MR. ANDERSON: And in addition, we agreed
16 to provide Sherry and her subject matter expert with a bit
17 of the history of the 911 issues in Michigan that we've
18 had.
19 And Orji, you just came in late, but we
20 included you in that discussion.
21 MR. ISIOGU: O.K.
22 MS. LICHTENBERG: So we'll tee up a time
23 and have a conference call and begin to understand where
24 we are here, and we'll report to the collaborative.
25 MR. KERN: So that will be a separate
2561
1 effort separate and apart from this test.
2 MS. LICHTENBERG: That is correct.
3 MR. KERN: But it will still be an effort
4 to try and look at 911-related issues.
5 MS. LICHTENBERG: That's correct.
6 MR. ANDERSON: I would almost suggest
7 that's not as much an OSS test issue as it is a --
8 MS. LICHTENBERG: We just agreed to that.
9 MR. ANDERSON: Oh, O.K. I'm sorry.
10 MS. LICHTENBERG: That's all right. Don't
11 sell past the close.
12 MR. KERN: We've already talked about the
13 scenarios. Eugene, do you want to pass out the hard copy
14 of the scenarios?
15 You should have all received by this
16 morning in e-mail all the various scenarios. We have hard
17 copies for those who are unable to open a zip file.
18 We're off the record.
19 (There was a discussion off the record.)
20 MR. KERN: Let's go back on the record.
21 What you've been handed out are all the
22 test scenarios as they've been proposed to date for the
23 state of Michigan. I would like people to review -- this
24 is a homework project for everybody.
25 MR. CONNOLLY: Not just me, Mr. Kern?
2562
1 MR. KERN: I was going to single you out,
2 Mr. Connolly, but you did such a good job this morning, I
3 didn't think it was necessary.
4 MR. CONNOLLY: Thank you, Mr. Kern.
5 MR. KERN: Anyways, I need you all to look
6 at this to make sure that the scenarios are the right
7 scenarios. We also need to make sure that all the
8 scenarios you want to have addressed are included. And I
9 was just talking to John and we're hoping that this
10 exercise could be completed in two weeks.
11 MS. LICHTENBERG: Mr. Kern, sir, since I am
12 not totally aware of what products will be offered, and I
13 believe I will not know for two weeks, I will have a
14 difficult time completing this assignment. Should I make
15 the assumption that UNE-P as I like it is included?
16 MR. LENAHAN: I would say that it would be
17 fair to assume that UNE-P as described in the proposal
18 that was presented on Monday would be the working
19 assumption.
20 MS. LICHTENBERG: O.K. Thank you very
21 much.
22 MR. APPENZELLER: Your Honor, Mr. Kern --
23 MR. KERN: Yes, sir.
24 MR. APPENZELLER: -- Mr. Appenzeller
25 requests permission to speak.
2563
1 MR. ERINGIS: I'm sorry. Can we make the
2 firm date, then, that it's a little more than two weeks?
3 Is the 26th O.K.? That gives people the weekend. June
4 26th?
5 MS. COLEMAN: For our responses back?
6 MR. ERINGIS: Obviously we would appreciate
7 them as soon as possible, but we would like to close this
8 iteration of input on the test scenarios by the 26th.
9 That would give us an opportunity that by that time if
10 there are comments that Ameritech has in particular on the
11 scenarios where -- you know, the INP stuff, et cetera --
12 that all of that will have been circulated.
13 MR. APPENZELLER: Mr. Kern, I withdraw my
14 request to speak because Mr. Eringis already answered it.
15 MR. KERN: O.K. So everybody's in
16 agreement. Comments on the test scenarios will be done as
17 soon as possible but no later than June 26th.
18 O.K. Now --
19 MR. DENNISTON: John, you said responses.
20 Do you mean further scenarios or responses to the
21 scenarios?
22 MR. KERN: Yes.
23 MR. DENNISTON: Both?
24 MR. KERN: Both.
25 MR. DENNISTON: So if someone has a new
2564
1 scenario on June 26th, we have to respond to that scenario
2 on the same day?
3 MR. KERN: It was my hope that there
4 wouldn't be a whole lot of new scenarios with the
5 exception of maybe line sharing. But again, I would
6 encourage people to get the new scenarios as soon as
7 possible. I will circulate them as soon as I get them,
8 but we need to close this out by June 26th.
9 Let's go off the record for a minute.
10 (There was a discussion off the record.)
11 MR. KERN: Back on the record.
12 The collaborative has agreed to the
13 following schedule: KPMG will produce a Version 1.3 of
14 the master test plan which will be distributed to the
15 collaborative by July 12th.
16 Parties wishing to comment on that revised
17 draft should do so no later than July 17th, preferably in
18 the matrix form that we have been using.
19 KPMG will reproduce the matrix and will
20 send it back out on July 18th.
21 The next meeting of this collaborative will
22 be on Thursday, July 20th. We will begin at 8:30. We
23 will conclude by 3:00.
24 We will finalize the MTP at that point, and
25 we will also attempt to finalize the contract between KPMG
2565
1 and Ameritech.
2 Yes, one more point. I'm sorry.
3 The test scenarios that were handed out
4 previously, parties have two weeks to provide comments on
5 those, and should get back to KPMG on or before June 26th.
6 MR. LENAHAN: And the rest of the
7 distribution list?
8 MR. KERN: And the rest of the distribution
9 list, yes.
10 Tim.
11 MR. CONNOLLY: Mr. Kern, I have a question
12 about the scenarios packet that's been distributed.
13 MR. KERN: Proceed.
14 MR. CONNOLLY: Thank you, Mr. Kern.
15 The last section of it is 14 pages,
16 beginning on page 1 of 14 and ending on 14 of 14, and it's
17 unclear to me what all those X's represent in the cells
18 that correspond to the 50 various scenarios.
19 It's also not clear what company submitted
20 these. So I don't know who to ask about them.
21 So if somebody could help me to decode this
22 one in particular, then the next question would go to
23 decoding the one in the section prior to that, which I
24 also don't understand the format of.
25 MR. LENAHAN: Maybe we could just get
2566
1 walked through all of the scenarios.
2 MS. MORREALE: What we did for all comments
3 we had gotten is, except for MCI, we tried to incorporate
4 them into spreadsheets that would look like Appendix A for
5 everybody and so anybody who gave us preorders, we tried
6 to incorporate them into a preorder spreadsheet, resale
7 spreadsheet, UNE-P, UNE loop, et cetera.
8 In the back, actually beginning in the
9 middle, at the end of the spreadsheets, there's a page
10 that starts, EDI Test Case Guidelines. From this back,
11 those were scenarios that McLeod had sent us, and we were
12 a little confused also about how the first sheet listing
13 Scenarios 1 through 10 corresponded with some of the 50
14 scenarios in the back with the X's.
15 We have asked John Kern if we could, you
16 know, meet or talk with McLeod to get a better
17 understanding of how they set up the two documents.
18 MR. GORFIN: There are three documents, the
19 EDI test case guidelines document, then there is EDI job
20 type/transaction matrix, then there's the 50 scenarios
21 document, page 1 to 14, that Tim described.
22 We have asked John to -- if we could meet
23 with McLeod to gain an understanding of how we translate
24 this into a look and feel of Appendix A as the previous 10
25 or 15 pages look like.
2567
1 I guess we don't have that answer today
2 unless McLeod is on the phone and open for that
3 discussion.
4 MR. LENAHAN: This is obviously a U.S. West
5 document. If they and -- U.S. West and Ameritech are two
6 different companies. Maybe they could go through and make
7 sure that some of the products that they are proposing be
8 tested, in fact are products that they are using from
9 Ameritech.
10 MS. BEATON: This is McLeod. This is
11 Christine Beaton. I am attending for Rod Cox, who is out
12 of town today. I will address these issues with Rod, and
13 have him give you a call.
14 MR. KERN: It might be helpful, Carla, if
15 you and McLeod could wrap this up as quickly as possible
16 so we can get out to the collaborative what the actual
17 scenarios are McLeod would like to have tested, so that if
18 the parties care to comment on them, they can do so
19 intelligently.
20 MS. BEATON: Carla, do you have Rod's
21 telephone number?
22 MS. MORREALE: I do not, no.
23 MS. BEATON: Let me get that for you. Just
24 a moment.
25 Are you ready?
2568
1 MS. MORREALE: Yes.
2 MS. BEATON: His number is 217-258-2953.
3 MS. MORREALE: O.K. I will just contact
4 him directly, then.
5 MS. BEATON: Thank you.
6 MS. LICHTENBERG: I assume for purposes of
7 the homework assignment that CLECs should wait to review
8 the McLeod package until a new McLeod package is written.
9 Thank you.
10 MR. KERN: Tim, did you have another
11 follow-up?
12 MR. CONNOLLY: No. Sherry asked the
13 question I was thinking about.
14 MR. KERN: O.K.
15 MR. CONNOLLY: We have been excused from
16 the latter half of the document or homework?
17 MR. LENAHAN: From reviewing the U.S. West
18 scenarios.
19 MR. CONNOLLY: We have not been excused
20 from the MCI document nor the first half of the test
21 scenarios document.
22 MS. WILSON: Right.
23 MR. CONNOLLY: When you get the McLeod
24 scenarios incorporated, we will distribute those?
25 MS. MORREALE: That's correct.
2569
1 MR. CONNOLLY: We will have some comment
2 period for those; is that correct, Mr. Eringis?
3 MR. ERINGIS: Yes.
4 MR. CHORZEMPA: If you get that quick
5 enough, it will probably be in the same.
6 MR. CONNOLLY: That's my hope.
7 MR. ERINGIS: We will just assume that you
8 will have it early enough to get comments by the 26th. If
9 not, we will address that.
10 MS. WILSON: We'll do our homework.
11 MR. KERN: The only other thing I would
12 like to cover today, and John and I had a conversation
13 about this off line, and that is, you know, exactly when
14 KPMG can start doing the type of work you need to do
15 inside of KPMG to start ramping up to do whatever it is or
16 do all the things you need to do before the test actually
17 begins.
18 Is that a correct statement, or do you want
19 to summarize for us exactly what kind of --
20 MR. ERINGIS: All right. We have had a lot
21 of discussions about the staging of the test and the
22 appropriateness of certain activities in particular stages
23 of the test, and what we would feel fairly comfortable at
24 this time beginning with some of the test preparation
25 activities.
2570
1 The test preparation activities that I
2 think we would be comfortable doing if all of the parties
3 and the Commission were comfortable with it, is to do
4 those things that still do not require us to interact
5 directly with Ameritech per se. There's a lot of things
6 just institutionally that KPMG needs to do in the
7 background to get ready to go do the test. Some of it is
8 just organization building and getting people scheduled,
9 getting detailed project plans done. But we need to get,
10 we need to scale up and sort of get a larger contingent of
11 people very actively engaged on the project, to start
12 doing, you know, research on certain items, et cetera.
13 So what we don't want to -- there are
14 certain other test preparation activities that we don't
15 want to get started on that we think we cannot do until we
16 definitely have a final master test plan, and let me give
17 you an example of that.
18 I don't think that we can begin building a
19 gateway and doing any connectivity testing or something
20 like that. That's absolutely -- although that's test
21 preparation. I mean, I don't think that it's appropriate
22 for us to get started doing that.
23 But I think there's a whole bunch of other
24 things that I would characterize as transparent to
25 everyone that is not really in the scope of work that we
2571
1 intended right now under the letter of intent that we have
2 which is really strictly master test planning activity.
3 So what we really wanted to do is just put
4 that on the table and get some feedback from folks as to
5 -- you know whether -- are there things that you are
6 uncomfortable with us doing, are there things that you
7 would feel comfortable -- we are sort of looking for the
8 boundaries of our permission from everyone to see what we
9 can proceed with. To this point, we have pretty strictly
10 made sure that we only have people involved in master test
11 planning activities. We felt that, given the feedback
12 that we had in the participation that we have had in the
13 workshop that was the only thing that collectively
14 everyone was comfortable with us doing. We kept to that.
15 MS. SCHNEIDEWIND: I think staff had a
16 discussion about this over lunch, and the kinds of things
17 that you are delineating here we at least are comfortable
18 with you proceeding with because the test plan isn't going
19 to be completed for another month or so.
20 And so staff doesn't have any problem with
21 your going ahead with these activities and ramping up.
22 MR. ROGERS: Ameritech doesn't either.
23 MS. LICHTENBERG: WorldCom doesn't.
24 MR. CONNOLLY: AT&T doesn't, but I do have
25 a question about the CLEC-KPMG meetings, meeting process.
2572
1 Typically they have been a once-weekly conference call and
2 periodic face-to-face. At what point would you propose to
3 begin those again?
4 MR. ERINGIS: I think that's a good
5 question, something that we were thinking about as well.
6 From my perspective, I think we have been
7 reluctant to do that because people have such busy
8 schedules right now. Most of the people here would be
9 participating on those calls, so we didn't want to add
10 another meeting on everyone's schedule. But, Tim, you are
11 right, I think we are at the point where we need to start,
12 if we are going to start doing stuff, that we should
13 probably provide status about, then we need to start that
14 call.
15 Whether that's a weekly call right now, I
16 don't know. But we would be happy to get started if we
17 just pick an arbitrary time.
18 I don't know if we have to do that now or
19 later, but we are prepared to get started with sort of a
20 quick, you know, despite 15-, 20-minute call kind of
21 thing, conference bridge only, where we could report to
22 the CLECs and take any questions that they have outside of
23 a collaborative.
24 MR. CONNOLLY: John, I would think that the
25 first meeting might be one where we establish all the
2573
1 communication mechanisms that we need, and set up e-mail
2 distribution lists, yada, yada, yada.
3 MR. KERN: Would that be a topic for the
4 July 20th meeting, or would you propose to do that before
5 the July 20th meeting? Or does it matter?
6 MR. CONNOLLY: I don't think it really
7 matters. It's just a set of administrative tasks that
8 need to get done and scheduled and committed to.
9 MR. ERINGIS: And from our perspective,
10 that's exactly the kind of thing that right now we're not
11 really doing because that's test preparation per se. But
12 we would like to be able to do that because we do have --
13 we would not be, you know, running flat out. It's not
14 going to consume 40 hours of everybody's time every week
15 working on this, the test plan right now.
16 So we would like to, we would like to take
17 the opportunity to fill our time with productive tasks
18 like that and get some more people involved and ramp up
19 appropriately.
20 MS. LICHTENBERG: One of the issues that we
21 are going to face as this team as this test takes off, and
22 the Illinois test takes off, and the Ohio test begins, and
23 the Wisconsin test begins, is that a number of us are
24 involved in all of those.
25 I am not in favor of a regional test.
2574
1 However, I believe that, for the sake of people's time, we
2 may want to consider somehow putting at least the face-to-
3 face meetings, which I assume we will have monthly, into
4 some kind of joint organization. My suggestion would be,
5 and maybe this even works for the conference calls, that a
6 monthly day be set aside for the five-state Ameritech
7 region and that whichever tests are ongoing, that we meet
8 concerning all of those tests, in a single rotating
9 location, once a month. So that we would come to Michigan
10 in the month of September, but we would also cover the
11 other states, and we would have a conference bridge for
12 those who could not come to Michigan.
13 The next month the meeting could be in
14 Ohio, so that those who are in Ohio could attend in
15 person, and that we would rotate that way and that we
16 wouldn't have to continually cut ourselves into little
17 pieces and spend more time on planes and in meetings than
18 on doing work, and that there might be a way that we could
19 set aside a large block of time to do our conference calls
20 as well.
21 MR. KERN: Let me -- I think that's a very
22 good idea, and I think it may get there. My only question
23 is, I'm not convinced that at least Wisconsin, Indiana,
24 and Illinois are as far along as Michigan.
25 MS. LICHTENBERG: Right, right.
2575
1 MR. KERN: Now, Ohio is trying to stay
2 really close to the Michigan heels. If we get to the
3 point where everybody has got pretty much the same master
4 test plan and things are going on simultaneously, I think
5 your suggestion is excellent.
6 MS. LICHTENBERG: What I would like to do
7 is put this framework in place and then, as you are able
8 to slip in more blocks, it will simplify all of our lives.
9 MR. ERINGIS: We would be happy to bring it
10 up.
11 MR. CHORZEMPA: This is Dave Chorzempa of
12 AT&T.
13 Could you do that amount of work in a day,
14 I mean if this is a one-day meeting?
15 MS. LICHTENBERG: If I am talking a 20-
16 minute or a one-hour meeting, which is normally what we
17 have on our weekly CLEC call, and I have five, that's only
18 five hours.
19 And most of the -- and I don't think -- you
20 know, some would be shorter than others. I don't know,
21 Dave, maybe it's two days every month. I just think it
22 might be better to try to coordinate our travel.
23 MR. CHORZEMPA: I agree with that. I am
24 just wondering whether or not --
25 MR. KERN: In fact, I am going to Ohio
2576
1 tomorrow. I will make sure that the Ohio collaborative
2 learns of this suggestion, and hopefully will embrace.
3 And John, when you are in Wisconsin, if you
4 could raise it with the attorneys up there to see if they
5 would be willing to agree --
6 MS. LICHTENBERG: Ameritech won't be
7 attending those meetings.
8 MR. KERN: I'm sorry. Were you going to be
9 in Wisconsin tomorrow?
10 MR. CHORZEMPA: I'm going to be in Ohio.
11 MS. LICHTENBERG: I don't mind if Ameritech
12 brings it up. It's just that those are CLEC meetings.
13 MR. LENAHAN: I was not looking forward to
14 going to them.
15 MR. KERN: Never mind.
16 I will call the Wisconsin commission, and
17 I'll talk to them, to see if they would be comfortable
18 with this, and they can raise it with other members of the
19 Wisconsin collaborative.
20 I don't think they will have a problem.
21 MS. SCHNEIDEWIND: Michigan staff thinks
22 that's fine, particularly and frankly only if there's a
23 conference bridge, but if there is, that's fine.
24 MS. LICHTENBERG: I think there would need
25 to be a bridge for every one of these to make sure that
2577
1 everyone is available.
2 In the other states we have addressed, we
3 have tried to get together face to face only one time a
4 month, and we have met via bridge every other time.
5 MR. KERN: O.K. That sounds like a plan.
6 Does anybody else have anything else?
7 Because I don't.
8 MR. CHORZEMPA: Have we closed the
9 performance measure on the issue?
10 MS. WILSON: I think we deferred them to
11 the firm matrix.
12 MR. CHORZEMPA: Who is the performance
13 measure auditor?
14 MR. KERN: I thought that was going to be
15 KPMG. Am I wrong? Did I misunderstand?
16 MS. LICHTENBERG: That's what I thought.
17 MR. KERN: That KPMG would start the audit
18 as soon as practically possible?
19 MS. LICHTENBERG: Right.
20 MR. KERN: Then there was an issue that was
21 raised yesterday as to what standard of auditing you would
22 use to evaluate the compliance with the business rules.
23 MS. SCHNEIDEWIND: There was also an issue
24 raised yesterday as to the time of that. I think that
25 there were words placed in to suggest that that would be
2578
1 something that would occur more immediately.
2 MR. ERINGIS: As soon as possible.
3 MR. DENNISTON: John, I have a question.
4 It may be addressed to John.
5 Assuming that the master test plan is
6 finalized on July 20th, when would we expect testing to
7 start?
8 MR. ERINGIS: Well, transaction testing
9 cannot begin until there is a substantial amount of
10 preparation to do the transaction test. I would say that
11 if you took a look at the total effort required to carry
12 out the transaction test that's in here, 80 percent of the
13 effort is prep and that only 20 percent of it is the
14 actual doing of the test -- or the doing of the test
15 execution. There's a lot of work that is involved in
16 getting ready for it. And again, the getting ready for it
17 in some respects is also primary data that translates into
18 test results.
19 So if the question is when would the first
20 electronic transaction be submitted, that we don't know
21 until we put together a detailed work plan, but it would
22 easily be a couple of months after we're authorized to get
23 started without limitation to prepare.
24 There are other activities that can begin
25 because the entrance criteria and the test preparation
2579
1 required is fairly minimal, and then the question is
2 whether or not it is something that's advisable to do as
3 soon as possible or whether it's advisable to do as late
4 as possible. And, you know, the example I would use is it
5 probably doesn't make sense as soon as possible after July
6 20th for KPMG to have people to start doing field work to
7 evaluate all of the provisioning processes because there
8 are still things that you may be putting together, so
9 that's one of those things that I would do as late as
10 possible.
11 But we want to try to anticipate those
12 things that we want to back-load into the schedule so that
13 if there is retesting that's necessary during this test,
14 that we have as recent a set of data as possible, and then
15 there's a lot of guesswork involved in that.
16 So I think it's a complicated answer to
17 your question. There are some things that we begin
18 monitoring right away because the test execution requires
19 us to pay attention and monitor it for the duration of the
20 test period.
21 So change management begins on June 21st,
22 or whenever we have the go-ahead, and we would look at all
23 the data for that. There are other tests that we start as
24 late as possible. Transaction testing requires a number
25 of weeks, several months to get prepared.
2580
1 MR. DENNISTON: I mean ballpark, are we
2 talking September-October?
3 MR. ERINGIS: For transaction testing?
4 MR. DENNISTON: Yes.
5 MR. ERINGIS: That sounds like a good
6 guess.
7 MS. LICHTENBERG: Let me suggest that the
8 critical path item on UNE-P is presumably the final shared
9 transport availability and billing availability, which are
10 currently scheduled for October and which are absolutely
11 critical in terms of both the billing test and the
12 transaction test and most of the functional tests. So
13 that would give us, I guess, a gut feel of that critical
14 path item and how it plays in.
15 MR. APPENZELLER: But, John, I think I
16 heard earlier that you're going to start your test
17 preparation activities right away, or are you waiting
18 until the next edition of the master test plan?
19 MR. ERINGIS: Well, if it's O.K. with
20 everyone, we would like to begin certain test preparation
21 activities. But, for example, I think one of the things
22 that we would not be comfortable doing is starting, for
23 example, connectivity testing.
24 MR. APPENZELLER: Right.
25 MR. ERINGIS: I mean we don't want to do
2581
1 that now. We don't think it's appropriate to do now. So
2 there's a point to which we can get very close to being
3 able to do that, and then we would have to stop unless --
4 MR. APPENZELLER: But the translation is
5 it's time to staff up, get ready.
6 MR. ERINGIS: For us, yes.
7 MR. APPENZELLER: Right. Get your project
8 plan together, do all the preliminary work, and there's no
9 reason why you can't start that now.
10 MR. ERINGIS: Correct. From our view.
11 MR. APPENZELLER: Which would mean I would
12 start to see a bigger bill sooner rather than later,
13 because you'd be staffing up for that, and then the master
14 test plan shows up and we talk about it on July 20th, and
15 then you've got more pre-work that gets done because you
16 now have a master test plan to work from, and some types
17 of tests could actually be done after that master test
18 plan is finalized --
19 MR. ERINGIS: Yes.
20 MR. APPENZELLER: -- i.e., things like
21 account management, for example, that are not transaction
22 tests.
23 MR. ERINGIS: Right.
24 MR. APPENZELLER: So to get a roundabout
25 answer to MCI's question, actually the test is going to
2582
1 start right away because the preparation work is getting
2 started for it. Types of tests could actually occur after
3 July 20th, assuming we finalize, but the transaction tests
4 that are associated with the products probably would not
5 be until September-October; is that correct?
6 MR. ERINGIS: Uh-huh. I would agree with
7 that characterization.
8 MR. APPENZELLER: Is everybody comfortable
9 with that?
10 MS. LICHTENBERG: Yes.
11 MR. APPENZELLER: And when it ends, in the
12 discussion we had earlier, it's up to us to try to get
13 that done.
14 MR. KERN: One last thing before we close.
15 Ann, did you want to talk about the
16 proposed schedule that Craig Anderson has circulated on
17 the inclusion of UNE-P, EELs, line-sharing costs in the
18 new cost docket?
19 MS. SCHNEIDEWIND: Well, I think, Craig,
20 you may have some input on that, too. I think you were
21 suggesting this morning you maybe want to defer that, but
22 I would just add a couple of points to what Craig put in
23 writing here that he had discussed with staff, and one is
24 that I believe that the proposal at least in regard to
25 line sharing is to comment only on the prices and the
2583
1 costs that you have included in your tariff. If there are
2 terms and conditions kinds of issues, they are either at
3 issue right now in Wisconsin in arbitrations, perhaps even
4 before the FCC, and additionally a separate complaint
5 could be filed here and we could come up with a separate
6 schedule for that. But I think your proposal is to just
7 address the prices that you've included in your tariff
8 that you filed yesterday for line sharing.
9 MR. ANDERSON: That is true not only of
10 line sharing, but all the issues. The focus of all this
11 was on cost prices.
12 MS. SCHNEIDEWIND: Am I correct that except
13 for the connection charge for the UNE platform, all those
14 cost studies are available now and could be made available
15 to anybody that wanted to begin review of those now?
16 MR. ANDERSON: Yes, that does not already
17 have them in the cost docket.
18 MS. SCHNEIDEWIND: And the issue of whether
19 or not the UNE-P connection charge is already in the
20 present phase of the cost docket or in the future phase
21 would have to be addressed in the various parties'
22 comments; that's what you're proposing here?
23 MR. ANDERSON: Yes. It's certainly not
24 precluding anybody from taking a position that it has
25 already been addressed or whatever the positions might be.
2584
1 But that would be positions parties may take, certainly.
2 MS. SCHNEIDEWIND: And finally, I think
3 there was some discussion yesterday about whether or not
4 your first 28 days would begin when the Commission would
5 issue an order approving this next phase of comments in
6 the cost docket or whether you could begin to prepare that
7 now so that it would be available 28 days from now.
8 MR. ANDERSON: We would be willing, in
9 response to that suggestion, to use today's date and have
10 the target date for that be 28 days from today, or
11 depending if it falls on a weekend, the next day.
12 MS. SCHNEIDEWIND: And then staff would
13 only raise for consideration whether we would need that
14 final round of replies. We don't have it in the current
15 phase of the cost docket. I know you suggested we had it
16 in initial phases of cost dockets. That's something, I
17 think, that can be discussed. But I don't know whether
18 you want to finalize this proposal at this point, but
19 that's what I was suggesting we have a June 20th
20 Commission meeting for -- or we have a June 20th
21 Commission meeting scheduled, and if we were to attempt to
22 propose this to the Commission for resolution at that
23 time, obviously we'd have to get people's points of view
24 on it.
25 MR. ANDERSON: First with regard to your
2585
1 last point about the last round of comments, the purpose
2 of that was to be consistent with the rounds of comments
3 that were used in the initial cost docket.
4 I agree that there is neither a second or
5 third round -- or, I'm sorry -- third or fourth round in
6 this current one because I think it's a rehearing. But
7 that was the process that was used for reviewing new cost
8 studies; that is, get the studies out there, comments,
9 replies and comments, and the last round in large part was
10 because staff has in the past taken the position that it
11 wants to see what the other party said in the second round
12 and then have their comments in the third so that people
13 would realistically have a chance to respond to staff. It
14 was to accommodate that concern, which if staff wants to
15 say they'd do their comments in the second round before
16 they've seen everybody, which has not been staff's
17 position to date -- and I know that other staff members
18 have been involved -- that we would be amenable to that
19 approach, too.
20 It was not my intent necessarily to
21 finalize today because I understand Mr. Reidy's not here.
22 I don't know if there has been further discussion, and Mr.
23 Denniston had suggested that perhaps he and Mr. Reidy
24 might confer off line and respond by e-mail up to --
25 MS. SCHNEIDEWIND: That's fine.
2586
1 MR. DENNISTON: That's right. And I would
2 also like to talk off line with Rhythms and COVAD.
3 MS. SCHNEIDEWIND: I gave a copy of this to
4 Craig Brown before he left this morning, but he didn't
5 have time to review it. So I think that's appropriate.
6 MR. ISIOGU: And from my perspective,
7 conceptually I think it's an acceptable way to proceed.
8 So other than maybe the CLECs might want to see if these
9 time lines are acceptable in light of the additional
10 information that was submitted by Ameritech Michigan, that
11 I think is something I could live with.
12 MR. ANDERSON: O.K. Pending hearing back
13 from AT&T and MCI on that issue, or anybody else that
14 wants to respond by e-mail, Ameritech would attempt to
15 circulate a draft motion as soon as possible to the
16 collaborative to see if we could effectuate that and get
17 it to the Commission by the 20th.
18 MR. ISIOGU: My only concern is trying to
19 incorporate these parties that were not involved in 831
20 and are now involved in this collaborative process now, so
21 will we have to go back and get the information that was
22 provided under the confidential agreement in the 831 case
23 and how is that going to work out?
24 MR. ANDERSON: As you know, the information
25 already provided in the 831 case were cost studies for
2587
1 everything and would take up several boxes.
2 MR. ISIOGU: Exactly.
3 MR. ANDERSON: And really I don't know that
4 that's all pertinent to these additional cost studies, and
5 I don't know how many people realistically are really in
6 that position.
7 I mean we would have no objection -- and I
8 had touched on this, I think, yesterday -- to parties who
9 are participating in the collaborative and are interested
10 in these issues participating in the cost docket --
11 joining in and participating in this next phase of the
12 cost docket but taking the docket as they find it. I will
13 say that I will accommodate any requests if somebody
14 really needs a copy of all this, but I'd just ask people
15 to keep in mind it's a massive task and do you really want
16 all this confidential information from the past.
17 And a lot of times parties are represented
18 by a firm who already has that information in representing
19 another client, and there probably wouldn't be a need.
20 For example, I think Leland Rosier -- I don't know if
21 you're still on the phone -- I think his firm represents
22 several CLECs that if one of the CLECs was not in the cost
23 docket but is here in the collaborative and wanted to be,
24 or Mr. Gould, I don't know if you wanted all those cost
25 documents.
2588
1 MR. GOULD: I don't want all those.
2 MR. ANDERSON: I didn't think you did. But
3 we would get that. We'd do what we can. I understand the
4 concern.
5 MR. KERN: Does anybody else have anything
6 for today?
7 Hearing none, we are adjourned. Thank you.
8 (At 2:00 P.M., the proceedings were
9 adjourned to 2:00 P.M., Monday, June 19, 2000.)
10 - - -
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2589
C E R T I F I C A T E
We, the undersigned, do hereby certify
that we reported stenographically the foregoing
proceedings had in the within-entitled matter, being Case
No. U-12320, before John Kern, Facilitator, at the
Mercantile Building, Lansing, Michigan, on June 7, 2000,
and that the foregoing transcript constitutes a full,
true and correct transcript of our said stenographic
notes.
______________________________________
______________________________________
Dated: June 7, 2000
