AFFIDAVIT OF SAM TENERELLI TABLE OF CONTENTS LOCAL OPERATIONS CENTER AFFIDAVIT

Transcription

1 AFFIDAVIT OF SAM TENERELLI TABLE OF CONTENTS LOCAL OPERATIONS CENTER AFFIDAVIT SUBJECT PARAGRAPH(S) PROFESSIONAL EXPERIENCE AND EDUCATIONAL BACKGROUND 2-4 PURPOSE OF AFFIDAVIT 5,6 SERVICE CENTERS DESCRIPTIONS 7 - LOC LOC Organization and Design 8-10 LOC Training 11 LOC Staffing 12 LOC Efforts to Improve Communications with CLECs - WCSC WCSC Organization Design WCSC Training WCSC Staffing PROVISIONING Frame Due Time ( FDT ) To Be Called Cuts ( TBCC ) NXX Codes Identifying CLEC Demarcation xdsl LNP Interconnection Trunks MAINTENANCE AND REPAIR Electronic Trouble Ticket Manual Trouble Ticket Clearing Troubles Trouble History i

2 TABLE OF ATTACHMENTS TITLE Attachment Paragraphs Accessible Letter CLECC and A 13 Accessible Letter CLECC Q98 CLEC Aggregate FDT Reports B 21,22 Accessible Letter CLEC C 33,34,35 CLEC Handbook, Number Portability D [PB Proprietary] Accessible Letter CLEC E 29,30 CLEC Handbook, Number Portability F [PB Proprietary] Accessible Letter CLECC G 38 Accessible Letter CLECC H 39 Accessible Letter CLECC I 28 Accessible Letter CLECC J 40 CLEC Handbook Number Portability, K [PB Proprietary] TBCC Migration Trouble Report 1Q98 L 31 Accessible Letter CLEC M 45 Accessible Letter CLECC N 51 CLEC Handbook, UNE [PB Proprietary] O 51 ii

3 AFFIANT S BACKGROUND AND DUTIES 1. My name is Sam Tenerelli. My business address is 177 E. Colorado Boulevard, Pasadena, CA PROFESSIONAL EXPERIENCE AND EDUCATIONAL BACKGROUND: 2. I currently hold the position of General Manager Local Operations Center ( LOC ). My responsibilities include overall management of the provisioning and maintenance operations services provided to Competitive Local Exchange Carriers ( CLECs ) in California. Functionally, these services are provided by the LOCs in Pasadena and Reseda for maintenance and coordinated conversions and the Wholesale Customer Service Center ( WCSC ) in Sacramento for provisioning and number portability. 3. I attended California State University Los Angeles, majoring in Business Administration. I obtained a Bachelors Degree in Business Management from the University of Phoenix. 4. I began working for Pacific Bell in 1971 holding both nonmanagement and management positions in Service Operations. I have operations experience with the provisioning, maintenance and facility assignment of simple and complex access lines, and basic and key type phone sets. I have staff experience with marketing and switching. I managed 1

4 centers and field forces responsible for the maintenance, provisioning and facilities of Plain Old Telephone Service ( POTS ) and Special Services. I held an area staff position as a manager supporting operations, marketing and switching organizations from 1990 to I established the first fully functional provisioning center in Pacific Bell to assure quality service and proper end user completion notification. I led a team to standardize the ISDN provisioning and maintenance process in The process included service order writing, testing, maintenance and customer education. I was responsible for service results and analysis in the Los Angeles area from 1993 to As General Manager LOC, I am responsible for managing the LOC which is the Pacific Bell customer services organization that supports the day-to-day provisioning and maintenance activity for CLECs entering the local exchange market within California. PURPOSE OF AFFIDAVIT 5. The purpose of my affidavit is to describe how Pacific provides provisioning and maintenance and repair services to CLECs for resold services, unbundled network elements and interconnection ( Wholesale Products ). I will describe the operations of Pacific s LOCs and WCSC. Specifically, I will address the compliance items set forth 2

5 in D , issued December 17, 1998 ( CPUC s Final Decision ), as they relate to the provisioning and maintenance of Wholesale Products. 6. The LOC is the single point of contact for provisioning and for the coordination of all maintenance and repair activities for the CLECs. The WCSC manages Pacific s internal processes related to the provisioning of Wholesale Products. The LOC and WCSC are part of Pacific s Local Wholesale Operations ( LWO ). SERVICE CENTER DESCRIPTIONS 7. The local wholesale market has seen explosive growth since the passage of the Federal Telecommunications Act of To satisfy the demand, Pacific closely monitors its human resource requirements to ensure that CLEC growth will be accommodated in all aspects of the operation, albeit byand-large without the benefit of consistent or accurate forecasts from the CLECs. Furthermore, as a part of the CPUC s OSS Test, Pacific will demonstrate its ability to support future volumes of CLEC provisioning and maintenance requests. As part of the OSS Test, the LOC process for timely addition and movement of resources (scalability) will also be evaluated by the third party Test Administrator working under the direction of the CPUC 3

6 Staff. These results will be compiled and included in the final OSS Test Results filed by the Test Administrator. Local Operations Center LOC Organization Design 8. In September 1995, Pacific Bell established a LOC in Pasadena to serve as the CLECs primary point of contact for provisioning and maintenance and repair of all resold services, unbundled network elements, Local Number Portability ( LNP ) and interconnection. The LOC also maintains and repairs interconnection facilities. The mission of the LOC is to provide the CLECs with high quality service twenty-four hours per day, seven days per week. 9. As of May 31, 1999, the LOC has provisioned and is currently maintaining over 64,000 unbundled loops (ISDN, xdsl, Basic, and Assured) as well as 49 loop and port combinations. Currently, the LOC maintains a base of 267,000 resale lines and 513,000 interconnection trunks, including OA/DA and E911 trunks. The number of coordinated cuts the LOC performs each month has grown from 491 in December 1998, to 1,428 in May In the first five months of 1999, the LOC has responded to over 148,000 CLEC provisioning, maintenance and repair calls, including the status of trouble reports and dispatch information. 4

7 10. To respond to increased CLEC service orders, Pacific added a second LOC in April 1999 and restructured the organization to better serve the CLECs. The original LOC in Pasadena is now dedicated solely to serving the CLECs maintenance and repair needs. The new center, located in Reseda, supports the CLECs provisioning activities. The split in the LOC, was done in response to the CLEC s concerns during the 271 Workshops that problems discovered on initial installation were being treated as maintenance problems rather than as provisioning problems. Pacific split the maintenance and provisioning groups between two LOC s, with the latter now responsible for loops installation problems. LOC Training 11. LOC Maintenance Administrators ( MA ) training consists of eight weeks of classroom technical training in Single System Imaging ( SSI ). SSI training encompasses the legacy systems such as COSMOS, 1 LMOS, 2 SORD, 3 BOSS, 4 SWITCH, etc. Further, the LOC MAs receive additional on-the-job training before they are fully qualified to perform every function in the LOC. The total training period is approximately Computer System For Mainframe Operations Local Maintenance Operating System. Service Order and Retrieval System Billing Operational Support System 5

8 weeks. LOC Service Representatives receive 6 weeks training followed by coaching and observation. The LOC Service Representatives are trained on COSMOS, BOSS, SWITCH, SORD, and PBOD. 5 LOC Staffing 12. As the General Manager LOC, I am responsible for the performance of the Reseda provisioning LOC and the Pasadena maintenance and repair LOC. Each LOC, in turn, is managed by one Area Manager who oversees the daily operations of the center and manages a combined force of over 115 MAs. In addition to the two LOC Area Managers, there is one administrative Area Manager responsible for results and process improvement and one Service Management Area Manager responsible for CLEC specific service results. LOC Efforts To Improve Communication With CLECs 13. The LOCs routinely partner with the CLECs to address operational issues and meet with CLECs upon request to outline the available provisioning and maintenance services. For example, the LOC hosted a meeting on April 26, 1999 to provide an opportunity for all CLECs to discuss LOC maintenance and repair operations. During the meeting, Pacific and the CLECs discussed various issues relating to commit time, expedites and escalations, coordinated testing and other issues raised by the CLECs. See Tenerelli 5 Pacific Bell Operations Dispatch. 6

9 Attachment A for the notice scheduling the meeting and the meeting minutes. Accessible Letters CLECC and App. B, p In addition, CLEC-specific meetings and conference calls are conducted as needed to improve service and maintain open lines of communications. Many CLECs have participated, including ICG, Media One, Sprint, Frontier, TelePacific, Allegiance Telecom, Southern California Edison, RCN Telecom, MCI WorldCom, GST Telecom, AT&T, NextLink, First World, ACI, Teligent, Northpoint, COVAD, and MGC. WHOLESALE CUSTOMER SERVICE CENTER (WCSC) WCSC Organization Design 15. The WCSC ensures that once a wholesale order is entered into SORD it flows without error through all provisioning systems. As such, the WCSC primarily interacts with the Local Service Centers ( LSCs ) and the provisioning LOC, as well as various other Pacific organizations such as field technicians, engineers and central office forces. The first WCSC center was opened in In July 1998, the WCSC added a second center, the Local Number Portability Center ( LNPC ), to process CLEC orders to port telephone numbers within Pacific Bell s serving territory. In June 1999, the Digital Plant Control Office ( DPCO ) was added 7

10 to the WCSC organization. The DPCO S primary responsibility is the provisioning of ISDN and xdsl loops. WCSC Training 16. There are four functional work groups in the WCSC, LNPC and DPCO centers MAs, Recent Change Memory Administrators ( RCMAs ), Facilities Administrators ( FAs ), and Customer Service Associates ( CSAs ). 17. MAs are responsible for work performed in AMOS 6 and for monitoring Frame Due Time ( FDT ) orders. The RCMAs are responsible for inputs to MARCH for line translation such as custom calling features, service close, etc. The FAs are responsible for Pacific s cable pair assignments into LFACS. The CSAs are responsible for monitoring fallout from the provisioning systems to move orders through the provisioning systems. 18. Training curriculums have been designed for each of the four distinct functional work groups in the WCSC, LNPC and DPCO. The RCMAs receive eight weeks of initial training to process CLEC service requests. FAs receive 10 weeks of initial training on correcting LFACs fallout. CSAs receive 2 weeks of initial training on one or more of the various 6 Access Mechanized Order System 8

11 provisioning. MAs receive 5 weeks of training that includes, but is not limited to, interpreting service orders and introduction to the network. Depending on the WCSC s specialized functions, WCSC employees receive technical training on PBOD, SORD, LMOS, FACS 7, COSMOS, SWITCH, TIRKS, AMOS, and MARCH. In addition, LNPC and DPCO personnel are trained on LSMS. 8 Training for the WCSC, LNPC and DPCO personnel is followed by several weeks of on-thejob coaching and observation. WCSC Staffing 19. Currently the WCSC, LNPC and the DPCO are supported by one WCSC General Manager who is responsible for the performance of the three centers. Three Area Managers and their supervisory subordinates manage 125 non-salaried personnel across the three centers. PROVISIONING Frame Due Time (FDT) 20. CLECs placing unbundled loop or unbundled loop with related LNP orders, which the CLEC does not want coordinated, place standard, non-coordinated cut orders, specifying the FDT. The CLEC enters an FDT Field Identifier ( FID ) which activates the switch translations at on or after, the time specified by the CLEC. Once the CLEC order is entered into 7 8 Facility Assignment Control System Local Service management System 9

12 Pacific s provisioning systems, the order is queued with all other retail and wholesale orders scheduled for the same time and the same switch. 21. As agreed in the 271 Workshops, for three months after the implementation of LNP in California s largest MSAs, in December 1998, Pacific tracked FDT data to demonstrate the activation interval on FDT orders. These reports identified the elapsed time between the FDT on the order and the actual switch activation in increments of 0 to 30, 30 to 60 and over 60 minutes. The data was compiled monthly in the aggregate for all CLECs and/or CLEC specific detail. The monthly reports were sent to the Staff and to CLECs who had requested the report. For January through March 1999, these reports showed a rapidly declining base of FDT orders. For example, in the last four months of 1998 there were over 700 FDT orders. From January through March 1999, there were only 21 FDT orders. See Tenerelli Attachment B for copies of the January through March monthly aggregate CLEC reports. App B, p. 23 and WS Agreement Also as agreed in the 271 Workshop, for any FDT order with an elapsed activation interval greater than 60 minutes, Pacific performed a root cause analysis and took corrective action to improve the FDT ordering and provisioning 10

13 process. For January through March five orders flowed through more than 30 minutes of the FDT. The root cause analysis indicated that two were due to errors by the RCMAs and 3 were errors by the LSC. A report of this root cause analysis was forwarded to the Staff and the CLECs who had requested the reports. WS Agreement See Tenerelli Attachment B for copies of the January through March reports. To Be Called Cut (TBCC) 23. The purpose of the LOC s To Be Called Cut ( TBCC ) process is to enable the cutover from Pacific to an unbundled loop, with or without number portability, with minimal amount of service disruption. The CLEC initiates the process by issuing a service order for the end user s service. The CLEC can use the customer service record, which is available through Verigate, DataGate or by fax request, to verify end user service prior to migrating the customer. The LOC receives the service order from SORD to verify the Pacific s existing services and the associated facilities. 24. The CLEC is required to call the LOC at least 48 hours prior to the due date. This is known as the 48-Hour Call. During the 48-Hour Call, Pacific and the CLEC verify that they have matching customer record information and they schedule a 30-minute window on the due date to 11

14 begin the cutover. During the 48-Hour Call, any customer record discrepancies are resolved. 25. After the customer and cutover data have been verified by the LOC on the 48-Hour Call, the LOC prepares the final cut sheets, notes the cutover time and faxes the cut sheet to the central office. Upon receipt of the cut sheet, the central office facilities technician runs the new jumpers in from the main distribution frame to the CLEC point of interface to ensure that Pacific is prepared and can meet the 30-minute window commitment on the due date to cut the service over to the CLEC. 26. To prevent the premature or late cutover of the service, the cut does not occur until the CLEC calls the LOC on the due date within the 30-minute cut window to request service activation. The cut will not proceed without a call from the CLEC within the 30-minute window. However, the CLEC calls Pacific before or after the 30-minute window Pacific attempts to accommodate the CLEC if workforce and workload permit. If Pacific cannot accommodate the CLEC s premature or late call, Pacific will reschedule the cut. 27. On the due date, the CLEC calls the LOC Administrator within the 30-minute window to activate the cut. The LOC Administrator instructs the central office facility technician to proceed with the cut. The central office 12

15 facility technician performs a lift of the old jumper and lay of the new jumper to assure the end user has minimal service interruption. Once the central office work is complete, the LOC notifies the CLEC to test the loop. When the testing is complete and the CLEC has accepted the loop, the LOC completes the order in SORD. 28. As requested by the Final Decision, the CLEC is not charged for cancellation of after-hour TBCCs or changes to afterhour TBCCs if the CLEC calls Pacific prior to 3:00 PM on the due date. App. B, p. 23. Pacific distributed notification of this policy to CLECs on February 15, 1999 in Accessible Letter CLECC Tenerelli Attachment I. 29. As required by Final Decision, on January 27, 1999, Pacific reissued Accessible Letter CLECC to the CLECs to clarify the difference between is a coordinated cut and considered a coordinated cut. Tenerelli Attachment E. As stated in the letter, considered a coordinated cut refers to situations where the product did not truly require coordination, but the CLEC chose to use TBCC in place of FDT. Is a coordinated cut refers to those situations where coordination is required in order to avoid service outages or missed calls. (FD, p. 188). 30. To accommodate the CLEC s needs for TBCCs, a matrix was collaboratively designed during the 271 Workshops. WS 13

16 Agreement The matrix was made available to the CLEC s by Accessible Letter CLECC , dated January 27, 1999, and is referenced in the CLEC Handbook, Number Portability, section 3.2.2, Policy of Coordinated Cuts for LNP. Tenerelli Attachments E and F, respectively. App. B, p. 24 and WS Agreement As agreed in the 271 Workshop, in addition to the FDT data tracking, any troubles associated with TBCC were also tracked. A report was prepared and forwarded to the CLECs, giving information for all CLEC s in the aggregate and/or CLEC-specific detail, as requested by the CLEC. See Tenerelli Attachment L for copies of the CLEC aggregate TBCC migration trouble logs for January through March. WS Agreement The analysis of the data from January though April 1999 demonstrated that out of 5,392 TBCCs there were only 115 problems. Therefore, 97.8% of all TBCCs occurred as ordered. There were no reports of premature cut, or failure to wait for the call within the 30 minute window. App B., p. 23. The root cause analysis demonstrated that CLECs were responsible for 43 of the failures. Of the remaining, 72 troubles, the central office frame was responsible for 51, the LSC was responsible for 16, and 5 were miscellaneous. The central office frame problems were 14

17 due to the preliminary work not being done or done incorrectly or no central Office personnel available at the cut time. To address these problems, a daily conference call at Director level was initiated by the LOC to discuss failures. As a result, the number of central office frame failures has dropped from 23 in January to 14 in April, while the number of TBCCs for the same period nearly tripled from 682 to The LSC order entry errors were referred to the LSC for coaching. All CLEC failures are referred to the Account Team for discussion with the CLEC in Service Improvement Meetings. NXX Codes 33. Pacific provides the CLEC a single point of contact in the LOC for immediate resolution of any problems that would prevent Pacific from performing complete testing in conjunction with an NXX code opening, e.g., the CLEC s failure to provide a functioning test number. The CLEC is notified by the LOC within 24 hours of discovery of any problem that will prevent Pacific Bell from performing a test in regards to an NXX Code opening. App. B, p. 15, W S CLECs were advised of this process in Accessible Letter CLECC , dated June 1, Tenerelli Attachment C. 15

18 34. As required by the Final Decision, Pacific has done TruCall testing on 100% of the codes in the month following the code opening where functioning test numbers exist. App. B, p. 15. To complete TruCall testing, the CLEC must provide functioning test numbers. To run a TruCall test, Pacific makes a number of calls to the CLEC s test number. These calls must complete successfully and generate an Automated Message Accounting ( AMA ) billing record. The TruCall test verifies that these billing records have been created. Without a functioning test number, Pacific cannot perform the TruCall test. TruCall testing validates the AMA billing record, not the call routing. If Pacific determines that the CLEC has provided a test number that is not functional, the LOC notifies the CLEC within 24 hours. To proceed with TruCall testing after such notification, the CLEC must provide a functional test number within 10 days of receipt of written notification that the test number is non-functional. CLECs were advised of this process in Accessible Letter CLECC , dated June 1, Tenerelli Attachment C. 35. CLEC and retail trouble tickets involving NXX codes are handled in the same manner with one exception, Pacific does not perform a TruCall test in response to trouble tickets involving its own NXX codes. However, as required by the 16

19 Final Decision, Pacific initiates TruCall testing when a single trouble ticket pertaining to a CLEC NXX code is received by the LOC. When a trouble report is received, the LOC MA analyzes the trouble ticket to determine the workgroup that can resolve the problem. The MA sends the trouble ticket to the appropriate work group. If an NXX code error is suspected, the trouble ticket is simultaneously sent to the Automatic Messaging Answering Control Center ( AMACC ) to initiate TruCall testing. If an NXX code is not opened by a carrier in one or more of its switches by the LERG effective date calls cannot be completed to the end office(s) in which the NXX code has not been opened. If Pacific receives a trouble report that involves network translations Pacific makes every effort to have the trouble resolved within four hours. App. B, p. 15. This process was communicated to CLECs via Accessible Letter CLECC , dated June 1, 1999 and in the CLEC Handbook, NXX Code Openings, 3.1. Tenerelli Attachment C and D. respectively. App. B, p. 15. Identifying CLEC Demarcation 36. As required in the Final Decision, during the loop provisioning process, Pacific will clearly and visibly identify the demarcation point for a CLEC. App. B, p. 20. In the case of a Subscriber Network Interface ( SNI ), 17

20 Pacific will tag the individual binding post at the SNI, which will identify the circuit/telephone number by CLEC. In the case of a Minimum Point of Entry ( MPOE ), Pacific will identify with placards the terminal numbering scheme for the circuit/telephone. A PBOD report is generated each morning containing a list of service orders where no dispatch is required that are ( non-fielded ) due that day to have new lines or circuits installed. The service and equipment, remarks, and assignment sections of the order are reviewed for special instructions that might require that someone be dispatched to that field to work the order ( fielded ). If none of these items indicate a fielded order is required, then the order is reviewed and the PON, telephone number/circuit ID, binding post number, and terminal address are provided to the appropriate CLECs via fax. xdsl 37. The LOC also provides the maintenance DPCO support for ISDN/xDSL Loops. The DPCO responsibilities include ticket creation, dispatching, testing and meeting the repair commitments for these products. 38. As agreed in the 271 Workshops, the LOC provides acceptance testing during the provisioning of ISDN and xdsl loops to ensure the facility performs to the CLEC s order. WS 18

21 Agreement Pacific announced the availability of an acceptance testing trial in Accessible Letter CLECC , dated December 23, Tenerelli Attachment G. Acceptance testing is performed by the CLEC and Pacific, as required, at the time of installation to ensure continuity between the CLEC collocation and the end user served on a Pacific loop. 39. Beginning July 22, 1999, Pacific will charge CLECs for acceptance testing if the test demonstrates that the loop is designed and installed correctly on Pacific s side of the network as ordered by the CLEC. Pacific will not charge if the acceptance test demonstrates that the loop is not designed and installed correctly on Pacific s side of the network as ordered by the CLEC. Accessible Letter CLECC , dated June 22, 1999, informed CLECs of the end of the acceptance testing trial and the initiation of charges for acceptance testing where the problem was due to CLEC error in ordering or provisioning. Tenerelli Attachment H. 40. Pacific also notified CLECs of the availability of cooperative testing to resolve trouble tickets for ISDN/xDSL loops effective July 22, See Accessible Letter CLECC , dated June 22, Tenerelli Attachment J. As with acceptance testing at installation, 19

22 Pacific will charge for cooperative testing on trouble tickets where the test indicates the problem was due to CLEC error in ordering or provisioning. LNP 41. The LNPC receives all service orders that involve the porting of telephone numbers out of Pacific switching end offices. LNP allows customers changing local service providers to retain their original telephone number without disruption of service. The LNP service orders are assigned a standard due date by the FLSC and a FOC is sent by the FLSC. The due date intervals are stated in the CLEC Handbook, Number Portability, section 3.2.1, due date intervals for LNP. Tenerelli Attachment K. 42. Notification messages generated by LNP Systems are monitored by the LNPC and processed in order to resolve conflicts, timeouts, cancellations and other problems. The LNPC also provides courtesy support to CLECs when a CLEC fails to create subscriptions in a timely manner. See Fleming Affidavit for description of CLEC obligations relating to LNP. Pacific s courtesy support consists of the LNPC submitting a subscription on the CLECs behalf to avoid end user service disruption. 43. The LNPC will remove line translations to disconnect Pacific s access to the end user and to fully port the 20

23 number to the CLEC. CLECs may elect to have LNP performed by Pacific using one of three methods. With TBCC, the CLEC provides a specific time and the cut is coordinated. With FDT, the CLEC provides a four-hour window indicated as AM or PM on the service request. If the CLEC specifies a Non- Coordinated cut, no specific time is provided and the cut may be completed anytime after 12:01 AM on the due date. 44. On a service order where no coordination is requested, the LNPC will monitor provisioning systems for proper disconnect of translations at the default time of 10:00 PM on the Due Date. If the CLEC has requested a FDT rather than the default of 10:00 PM, the LNPC will initiate, at the specified time, any necessary wiring changes without coordinating with the CLEC. The LNPC monitors the MARCH system to ensure the automatic disconnect of line translations at the specified time where the 10-digit unconditional trigger feature ( TDT ) is not applied and at 10:00 PM when TDT is applied. WS Agreement As agreed in the 271 Workshop, a CLEC can request a simple business or residence FDT for stand alone LNP orders on Saturday. Accessible Letters CLECC notified CLECs of Saturday due date availability. Tenerelli Attachment M. W.S. Agreement

24 Interconnection Trunks 46. Pacific Bell uses the same process for the provisioning of CLEC interconnection facilities and message trunks as it does for Interexchange Carrier ( IEC ) trunking. Upon receipt of service order the special services testing technicians perform turn-up and testing on the interconnection facilities. Test results are provided to the CLEC in the same manner used by Pacific for retail and access customers. MAINTENANCE AND REPAIR Electronic Trouble Report 47. In the case of maintenance and repair, CLECs can submit trouble reports on all resale lines, interconnection facilities, and UNEs directly through PBSM or EBI. Trouble reports entered by the CLEC in PBSM or EBI are electronically transmitted to LMOS. LMOS is also used for retail maintenance and repair. 48. The CLECs may use PBSM or EBI to test a POTS-like resale or POTS-like UNE combination, issue a trouble report, verify the status of an open report and receive completion information from a terminal at their location. As of May 31, 1999, on average the LOC has received only 5% of the trouble reports electronically using PBSM or EBI. 22

25 Manual Trouble Reports 49. If a LOC MA receives a trouble report manually, the MA enters the trouble report into LMOS. The LOC MA performs a mechanized line test and provides the results to the CLEC. If a problem is found, Pacific provides a commitment time for restoration or repair of the service. This is precisely how trouble reports are handled on retail lines when a Pacific Bell retail customer calls the retail repair center. The commitment time for restoration or repair of a wholesale service is the same as for the analogous retail service. A commitment time for restoration or repair of interconnection facilities or UNEs is based on the type of service provided over the facility, e.g., residence, business, ISDN, xdsl etc. 50. After the LOC MA tests the circuits, the MA dispatches the trouble report to the appropriate organization for maintenance and repairs. While the trouble ticket is pending, the CLEC may call the LOC or access PBSM or EBI for status. Clearing Troubles 51. Provisioning troubles received from the CLEC where the service has never worked, will be treated as an installation problem. The CLECs were notified of this process in Accessible Letter CLECC , dated May 6, 23

26 1999. Tenerelli Attachment N. App. B, p. 20. The process is also contained in the CLEC Handbook, UNE, section 1.3.7, LOC Process for Installation Problems. Tenerelli Attachment O. If the loop was never functional, Pacific will resolve the problem using the LOC provisioning process. If the loop is functional during the CLEC testing but is non-functional after the testing technician leaves, Pacific resolves the problem using the LOC provisioning process, provided the problem was identified on the due date. If the loop is functional during the CLEC testing but a problem is identified after the due date, the trouble is resolved by Pacific using the LOC repair process. Pacific has provided and published an 800 number for the LOC provisioning process for non-functioning loops at installation. App. B, pp WS Agreement Trouble History 52. As agreed in the 271 Workshops, the trouble history of an end user remains in LMOS when a customer migrates from Pacific to a CLEC but retains the same telephone number or circuit ID. WS Agreement This concludes my affidavit. [Signature Page Follows] 24

27 I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge. Executed on July, Sam Tenerelli General Manager LOC 25