PUBLIC VERSION AFFIDAVIT OF VICTORIA MURRAY

Transcription

1 PUBLIC VERSION AFFIDAVIT OF VICTORIA MURRAY TABLE OF CONTENTS SUBJECT PROFESSIONAL EXPERIENCE AND EDUCATIONAL BACKGROUND PARAGRAPH(S) 3-4 PURPOSE OF AFFIDAVIT 5-6 LSC LSC Description LSC Organization & Design LSC Staffing LSC Training LSC Efforts To Improve Communications LSC PROCESSES PRE-ORDERING ORDERING Resale Orders Resale Electronic Ordering Process Resale Manual Ordering Process Facilities Orders Facilities Electronic Ordering Process Facilities Manual Ordering Process xdsl Ordering Process Ordering Unbundled Network Elements Ordering Interconnection Trunks Jeopardy Notification Process Customer Care LISTINGS ESCALATIONS/EXPEDITES BILLING AND COLLOCATIONS Billing Claims Process & Dispute Resolutions Billing Forums ACCOUNT MANAGEMENT i

2 AFFIDAVIT OF VICTORIA MURRAY TABLE OF ATTACHMENTS Attachment Paragraph(s) Accessible Letter A 16 CLEC Handbook Internal Workshop Guide. FD. P.107, App. B, p.5, WS Agreement [PB Proprietary] B 18 Sample M& P showing Cross-reference to CLEC Handbook [PB Proprietary] C 21 Accessible Letter CLECC D 21 Accessible Letter CLECC E 21 Accessible Letter CLECC F 21 Accessible Letter CLECC G 22 Accessible Letter CLECC H 23 Accessible Letter CLECC I 23 Accessible Letter CLECC J 23 Accessible Letter CLECC K 26 CLEC Handbook, Forms, K1023 [PB Proprietary] L 38 Accessible Letter CLECCS M 38 Accessible Letter CLECCS N 38 CLEC Handbook, Carrier Code Guide, Tab 10 [PB Proprietary] 0 43 CLEC Handbook, CLEC Education, PB CLEC Workshop-UNE P 43 CLEC Handbook, Forms, ASR forms - unbundled switching Options A, B, and C Q 44 Sample Letter UNE Combinations (54) R 44 Sample Letter UNE Combinations (31) S 44 Sample Letter UNE Combinations (22) T 45 Accessible Letter CLECC U 45 Interconnection Trunk FOC V 46 Accessible Letter CLECC W 46 CLEC Handbook, Interconnection, 13.0[PB Proprietary] X 50 Accessible Letter CLECC Y 54 Accessible Letter CLECC Z 55 Escalations Matrix 1Q99 ii

3 AFFIDAVIT OF VICTORIA MURRAY TABLE OF ATTACHMENTS Attachment Paragraph(s) Accessible Letter AA 58 CLEC Handbook, Billing and Collections, [PB Proprietary] BB 59 CLEC Handbook, Billing and Collections, 4.2 [PB Proprietary] CC 60 Accessible Letter CLECC DD 65 Accessible Letter CLECC EE 66 Accessible Letter CLECC FF 66 Accessible Letter CLECC GG 67 Accessible Letter CLECC iii

4 AFFIANT S BACKGROUND AND DUTIES 1. My name is Victoria Murray. My business address is 200 Center Street Promenade, Room 400, Anaheim, California I currently hold the position of General Manager - LSC for Pacific Bell. In this capacity, I have overall responsibility for the Local Service Center (LSC) in Anaheim. PROFESSIONAL EXPERIENCE AND EDUCATIONAL BACKGROUND 3. I graduated with a Master of Business Administration (M.B.A.) degree from the Graziadio School of Business and Management at Pepperdine University in In 1998, I earned a doctorate (Ed.D.) from the Graduate School of Education and Psychology and the Graziadio School of Business and Management at Pepperdine University. My area of specialization is organization change. 4. I have 26 years of experience in the telecommunications industry. I have held a variety of line management and staff support positions in Mountain Bell, AT&T, and Pacific Bell. Further, I have performed in a number of functional disciplines including sales, contract administration, network engineering, human resources, process management, operations, and customer care. I joined Pacific Bell in 1

5 1997. Prior to my present assignment, I held the title of Area Manager-Network Operations for Pacific Bell where I was responsible for the direct supervision of central office personnel. I was assigned to my current position on November 15, PURPOSE OF AFFIDAVIT 5. The purpose of my affidavit is to describe how Pacific s LSCs provide pre-ordering, ordering, billing and collections services to CLECs for resold services, unbundled network elements, and interconnection ("Wholesale Products"). My affidavit describes the operations of the LSCs and how the LSCs have satisfied the requirements in D , issued December 17, 1998 ("Final Decision" or FD ), that relate to the LSCs responsibilities for preordering, ordering, and billing and collections. 6. CLEC wholesale service requests are received and processed by the LSCs. The LSCs are responsible for satisfying preorder and order requests and the creation of service orders for downstream processing. The LSCs Service Representatives create service orders from manually submitted CLEC service requests as well as electronically submitted service requests that do not flowthrough Pacific s electronic OSS, either as a result of CLEC error 2

6 or because the orders are not currently designed to flowthrough. See Viveros Affidavit for a description of OSS flowthrough. The LSCs are part of Local Wholesale Operations ( LWO ). LSC Description 7. The local wholesale market has seen explosive growth since the passage of the Federal Telecommunications Act of Through May 31, 1999, the LSCs have processed 1.2 million service requests received from more than 62 of the CLECs authorized to provide local service in California. These service requests have steadily increased, most notably in the facility-based market, since To satisfy this demand, the LSC organization 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 the LSCs ability to support future volumes of CLEC service requests. As part of the OSS Test, the LSC process for timely addition and movement (scalability) of resources will also be evaluated by the third party Test Administrator working as the Commission s subject matter expert. These results will 3

7 be compiled and included in the final OSS Test Results filed by the Test Administrator with the CPUC. LSC Organization Design 8. The LSCs were established to provide effective and efficient service to the CLECs for pre-ordering, ordering, billing and collections in an accurate, timely, and cost effective manner. 9. The LSCs provide managerial oversight of, and work production within, three distinct functional areas - the Resale LSCs ("RLSCs") are responsible for processing all resale product requests, the Facilities LSCs ("FLSCs") are responsible for processing requests for UNE and interconnection products, and the Billing and Collections LSC is responsible for all billing and collections related activities. LSC Staffing 10. As of May 31, 1999, the resale, facilities, and billing and collections work groups are supported by one General Manager LWO, who has overall responsibility for the performance of the LSCs. There are two General Managers for the LSCs, one in Anaheim and one in San Francisco, who have responsibility for the performance of their respective 4

8 center. There are eight Area Managers, four in San Francisco and four in Anaheim, who are assigned specific functional responsibilities within each center. There are 54 Managers, 26 in San Francisco and 28 in Anaheim, who directly supervise the LSCs 714 member non-salaried work force. Additionally, the LSC organization is supported by a team of staff managers who provide project coordination, human resources administration, process improvement, quality assurance and analysis, systems support, force management, and operational strategies and regulatory assistance. In total, 798 Pacific Bell employees are dedicated to the pre-ordering, ordering, and the billing and collections functions within the LSCs. These employees have processed over 236,000 resale service requests and 136,000 UNE service requests in the first five months of LSC Training 11. Rigorous training curriculums have been designed for each of the three distinct functional areas within the LSC. RLSC Service Representatives receive ten weeks of initial classroom training to process orders for new service, transfers from one location to another, and changes to existing service. They are also trained to suspend and 5

9 restore service for non-payment. This initial training includes instruction on how to process orders for a variety of features and functionalities such as Remote Call Forwarding and Toll Blocking. As the Service Representatives gain on-the-job experience they are provided with advanced training on more complex resale services such as Foreign Exchange, Private Branch Exchange ( PBX ) and Central Office Exchange Service ( Centrex ), Hunting, Off-premise Extensions, Direct Inward Dial, High Capacity Service ( HiCap ), and ADSL. This advanced training involves four weeks of classroom training, followed by several weeks of on-the-job coaching and observation. 12. FLSC Service Representatives also receive ten weeks of initial training to process orders for new service, transfers from one location to another, and changes to existing service. Experienced Service Representatives are provided with training on more complex unbundled network element ("UNE") products, such as PBX and Centrex, and interconnection products, such as E911 Trunks, Operator Assistance/Directory Assistance Trunks, and Signaling Systems 7 ( SS7 ) Links. This advanced training requires more than six weeks of classroom instruction. 6

10 13. Billing and Collections Service Representatives receive seven weeks of classroom training, followed by job coaching and observations. Continuation training is provided to resale, facilities, and billing and collections representatives as CLEC requirements change and new products are introduced. 14. In addition to training for these three functional areas, the LSCs have established several specialized work groups to meet the evolving pre-ordering, ordering, and billing needs of the CLECs. For example, each of the LSCs provide customer care support via a toll free telephone number to answer questions concerning the ordering process, to provide status on CLEC orders, to receive requests for expedites/escalations, and to assist in telephone number assignment, etc. Further, specialized customer support is provided to assist the CLECs in reserving circuit identifications and in navigating Pacific s OSS. The OSS Help Desk, which was established on March 9, 1998, answers questions on how to navigate the OSS and create an LSR. 15. As required by the Final Decision, the LSC OSS Help Desk representatives received additional training in Graphical User Interfaces (GUI). App. B, p. 5, WS Agreement From March through June of this year, OSS Help Desk Service Representatives were trained on GUI, Local Service Request 7

11 Exchange System ( LEX ) UNE, and LEX Resale, Folders Overview, StarWriter, DataGate, Toolbar, Circuit ID Reservations, OSS Help Desk M&P, Pacific Bell Service Manager ("PBSM") and Provisioning Order Status ( POS ) details. In total, these courses represent approximately four weeks of training over and above that normally received by the resale and facilities Service Representatives. 16. As required by the Final Decision, continuation training on Accessible Letters was created to better enable the RLSC and FLSC service representatives to assist the CLECs in their pre-ordering and ordering processes. On November 24, 1998, training materials on how to search for accessible letters were provided to the LSC Service Representatives. Murray Attachment A, CLEC Handbook, Internal Workshop Guide. This training was completed in both the San Francisco and Anaheim LSCs on March 31, FD, p. 102, App. B, p. 5, WS Agreement This enables the LSC representatives to respond to CLEC questions on accessible letters and to direct CLECs to specific accessible letters in response to their inquiries. 17. Pacific also provides training to the CLECs. Formal classroom training is provided which includes instruction on accessing various reference materials, including the 8

12 CLEC Handbook and OSS job aids. See Viveros Affidavit for discussion of CLEC OSS training. Upon receipt of a signed non-disclosure agreement, CLECs can access Pacific s Information Services (IS) Call Center Extranet for OSS job aids as well as the CLEC Handbook located on the web. 18. As required by the Final Decision, Pacific explored crossreferencing LSC Service Representative M&P to the CLEC Handbook to enable the LSCs to respond to the CLECs in language consistent with the CLEC Handbook. FD, p. 102, App B, p. 5, WS Agreement On April 30, 1999, Pacific completed a project to cross-reference LSC M&P with the corresponding section in the CLEC Handbook. In the LSC M&P, under the heading of References, the corresponding CLEC Handbook section now appears. See Murray Attachment B, for an example. LSC Efforts To Improve Communication With CLECs 19. The introduction of structured, repeatable processes has increased the responsiveness of the LSC to CLEC orders and inquiries. While the organization continuously monitors its own performance and initiates appropriate actions to improve the level of service provided to the CLECs, the organization also solicits input directly from the CLECs through formal and informal meetings. The LSCs, for 9

13 example, routinely meet with individual CLECs in person and via conference calls to discuss ways to jointly improve pre-ordering and ordering processes. 20. In addition, the LSCs hosted formal sessions in which all CLECs were invited to identify opportunities for improved service. 21. In September and October of 1998, Pacific distributed Accessible Letters CLECC , CLECC , and CLECC inviting the CLECs participation in focus group meetings. Murray Attachment C through E. App. B, p. 5, WS Agreement and App. B, p. 4. Attendees at one or more of the meetings included representatives from AT&T, PacWest Telecomm, MCI WorldCom, Working Assets, NextLink, COX, and Sprint. Minutes of these sessions, including the issues identified and the outcomes proposed, were distributed to the CLECs via Accessible Letter CLECC , dated December 29, Murray Attachment F. 22. Notification of a follow-up resale focus group meeting scheduled for March 4, 1999 was distributed on February 12, 1999, via Accessible Letter CLECC Murray Attachment G. Four CLECs attended the Resale Focus group: AT&T, PacWest, Advanced Telecom Group ( ATG ), and ELI. 23. As required by the Final Decision, Pacific also scheduled meetings with the facility-based CLECs. App. B, p

14 Notification was sent to the facilities CLECs on February 12, 1999 via Accessible Letter CLECC to announce follow-up focus group meetings to be held on March 4, Murray Attachment H. Six facility CLECs attended: MCI WorldCom, AT&T, ICG Comm, COX, NextLink, and ELI. Minutes of both the resale and facilities sessions, including the issues identified and the outcomes proposed, were distributed to the CLECs via Accessible Letter CLECC on March 30, Murray Attachment I. Several topics were discussed. One example was CLEC dissatisfaction with the level of product knowledge displayed by FLSC Service Representatives. The CLECs requested specialization by the Service Representatives, either by CLEC or by product. Following an analysis of FLSC work flows and order processes, the FLSC created specialized Customer Care queues based on the CLEC's product choice. For example, CLECs whose primary marketing activity is based on xdsl, can speak with a FLSC Service Representative who is dedicated to that product, while those whose primary marketing activity is facility-based interconnection can speak with FLSC Service Representatives dedicated to interconnection. 11

15 PRE-ORDERING: 24. Pre-ordering information is used by CLECs to prepare orders for both resold services and unbundled network elements. CLECs may access pre-ordering information through two electronic gateways - Verigate and DataGate. See Viveros Affidavit for pre-ordering OSS details. CLECs may also submit requests for customer service record information via facsimile to a specialized group in the San Francisco LSC. Further, CLECs may call the LSCs Customer Care groups for telephone number assignment, loop qualification, and for other requests related to service pre-ordering and ordering processes. 25. With respect to loop qualification, CLECs may request xdsl pre-order qualification to determine if the loops at a particular location are available and/or if the loops are able to support the xdsl technology chosen by the CLEC. CLECs may retrieve basic pre-order qualification information, such as customer address and a loop length indicator ( RTZ ), through the Verigate or DataGate interfaces. See affidavit of Viveros. CLECs who choose not to access this basic loop pre-order qualification information electronically, may call the FLSC s Customer Care group or fax the information request to the FLSC using 12

16 a K1023 CLEC Request Form. CLECs who require loop make-up for xdsl loops, may fax a K1023 request to the FLSC. 26. On May 13, 1999, Pacific issued Accessible Letter CLECC , which provided the CLECs with the New K1023 Request Form - California. Murray Attachment J. This form is used generally for facility availability and for prequalification of xdsl loops. This form is also contained in the CLEC Handbook under Forms. Murray Attachment K. 27. As agreed during the 271 Workshops, and subsequently ordered in the Final Decision, if requested by the CLEC, Pacific responds to the CLEC s K1023 xdsl pre-qualification request with information about loop length, the availability of copper loops or pair gain only and an equivalency factor. App. B, 17 and WS Agreement Currently, Pacific s response is returned to the CLEC via telephone or facsimile as requested by the CLEC. In addition, Pacific plans to implement a process in July 1999 to permit CLECs to submit the K1023 form to the FLSC by and to receive an electronic response. App. B, p The pre-qualification information returned in response to a K1023 request permits the CLEC to determine whether their selected DSL technology will work on an available loop. There are certain facility restrictions that apply to the 13

17 various DSL technologies. For example, certain xdsl technologies will only function within a certain distance from the central office. In addition, ADSL, SDSL, RADSL and 2-wire HDSL only work on non-conditioned copper Loops. If no copper loops are available, the order will be placed in a P102 jeopardy status and the CLEC will be notified of the Facilities Relief Date (FRD). If the area is only served by Digital Loop Carrier (DLC), i.e., pair gain, the CLEC will be notified and may elect to provision IDSL, as that technology will work on DLC and with other ISDN design components. ORDERING Resale Resale Electronic Ordering 30. CLECs submit resale orders to Pacific through six OSS: Service Order and Retrieval System ( SORD ), StarWriter, Local Service Request Exchange ( LEX ) system, Electronic Data Interchange ( EDI ), Resale Mechanized Interface ( RMI ), and Pacific Bell Service Manager Channel ( PBSM ). See Viveros Affidavit for discussion of OSS ordering. With the necessary investment in hardware and software, a CLEC may send and receive LSR information electronically. This 14

18 greatly increases the speed and efficiency by which Pacific and the CLEC can process the CLEC s orders. 31. Electronically submitted LSRs that exception out to the LSC, due to CLEC order-entry error or by design, are distributed to RLSC Service Representatives for manual processing. In those cases where the CLEC has provided insufficient or incorrect information to process the request, the Service Representative issues a reject to the CLEC via the CLEC s chosen electronic interface. The reject identifies the order defect through the use of a particular reject code. 32. In those cases where a service request is submitted electronically but requires manual intervention for review purposes only, i.e., for Quick Dial Tone or feature verification, the Service Representative reviews and validates the request and enters the information into SORD. Upon entry of the order into SORD, the Service Representative transmits a Firm Order Confirmation (FOC) to the CLEC via the CLEC s chosen electronic interface. If Pacific subsequently determines the due date provided on the FOC cannot be met, a jeopardy notification is sent through the same electronic interface. Upon completion of the SORD order, a completion notice or Service Order 15

19 Completion ( CN/SOC ) is sent electronically via the CLEC's chosen electronic interface. Resale Manual (Fax/Mail) Ordering Process 33. The manual ordering process was designed for orders submitted by CLECs who choose not to use the available electronic systems and for requests that cannot be processed electronically. Service requests received by the RLSCs via facsimile or mail are labor intensive as they must be manually processed. Upon receipt of fax/mail orders, the RLSC Service Representative enters the information from the paper request into the Local Tracking Database (LTD) system. The LTD system tracks the service request and, at the appropriate times, transmits a FOC and CN/SOC to the CLEC via a fax gateway. As of May 31, 1999, service requests received via facsimile comprised approximately 70% of the total daily order volume in the resale LSCs. Pacific expects this volume to be reduced following GTECC s migration to EDI effective June 28,

20 Facilities Facilities Electronic Ordering Processes 34. CLECs may choose from four OSS to submit facilities service requests electronically: SORD, CESAR, 1 EDI, and LEX. See Viveros Affidavit for discussion of OSS. 35. Electronically submitted LSRs that exception-out to the FLSC, due to CLEC order-entry errors or by design, are distributed to Service Representatives for manual processing. Where such an order is received by the FLSC, the request is reviewed for accuracy and completeness. If the request is incomplete or incorrect, the CLEC is notified of the error. The CLEC must resubmit a corrected service request. Upon receipt of a valid and error free request, the FLSC Service Representative enters the information into SORD and provides the CLEC with a FOC via the CLEC s chosen electronic interface. Facilities Manual (Fax/Mail) Ordering Process 36. Service requests received from the CLECs via facsimile or mail constitute approximately 10% of the total daily order volume in the FLSC. These requests are tracked and processed manually. A Service Representative reviews the 17

21 information provided by the CLEC for accuracy and completeness. If the request is incomplete or incorrect, the CLEC is notified of the error(s). Upon receipt of a valid and error free request, the FLSC Service Representative enters the information into SORD. FOCs, jeopardies and CNs/SOCs are returned to the CLEC via facsimile or a mutually agreed upon method. Ordering xdsl 37. As committed in the 271 Workshops, Pacific participated in four CLEC xdsl forums with facility-based CLECs between September 1998 and May See also App. B, p. 4. In the September joint forum, Pacific introduced the appropriate xdsl Network Channel/Network Channel Interface (NC/NCI) codes to the CLECs to be used when placing xdsl service requests. The xdsl technologies currently in use by the CLECs were discussed and information about qualification and ordering processes was disseminated. 38. The NC/NCI codes used for ordering xdsl loops are consistent with discussions with CLECs in the various xdsl forums. Orders must now specify the xdsl NC/NCI codes and contain a formatted statement specifying the type of DSL. In a May 4, 1999 joint forum and in associated Accessible 1 Customer Enhanced Service Access Request 18

22 Letters CLECCS and Accessible Letter CLECCS , both dated October 28, 1998, Pacific informed the CLECs that xdsl loop orders that did not use the xdsl NC/NCI codes and formatted statement would be rejected. Murray Attachments L and M, respectively. See also CLEC Handbook, Carrier Code Guide, Tab 10. Murray Attachment N. App. B, p The Final Decision required CLECs to specify the types of xdsl they intend to deploy over the loop. App. B, p. 19. Specifying the type of xdsl technology on the order ensures that the ordering, provisioning, and maintenance of the DSL loop will be consistent with the CLEC s intended service. 40. The Final Decision requires Pacific Bell to provide a standardized reporting format to the CLEC's explaining why loops were denied for spectral interference reasons. App. B, p. 19. Currently, Pacific Bell does not deny a CLEC request to deploy a specific technology on an xdsl loop based on spectral interference. Pacific Bell is working within industry forums to develop a technology that will identify and isolate spectral interference. If such technology is developed, Pacific Bell will develop a standardized format to notify a CLEC if its service request is denied based on spectral interference. 19

23 41. The Final Decision required Pacific to treat information about the xdsl service a CLEC intends to deploy and any associated orders as proprietary information, not to be shared with any of Pacific's retail operations or affiliates. This requirement is consistent with Pacific's "Code of Business Conduct" to treat customer information as proprietary. All Pacific employees receive mandatory coverage annually. Violation of the requirement to keep the CLEC information proprietary can result in disciplinary action, up to and including dismissal. App. B, p. 19. Ordering Unbundled Network Elements 42. CLECs receive training on UNE orders. The CLEC Education site includes course descriptions of available UNE classes, e.g., PB CLEC Workshops-UNE. Murray Attachment O. A description of each UNE class is provided in the course description. In total, Pacific offers 13 workshops and 17 OSS classes to CLECs. See the affidavit of Chris Viveros concerning CLEC OSS training. 43. The Final Decision required Pacific to develop methods and procedures for ordering and provisioning unbundled switching on a stand-alone basis or in combination with other unbundled network elements. App. B, p. 22. For switching ordered on a stand-alone basis, Pacific has 20

24 developed methods and procedures, Local Service Order Requests ("LSORs") and/or Access Service Requests ("ASRs") for ordering Options A, B, and C. Information on ordering unbundled switching appears in the CLEC Handbook, UNES, 2. ASR example forms to order unbundled switching Options A, B, and C are contained in the CLEC Handbook under the heading Appendices. Murray Attachment P. 44. In addition, Pacific advised each of the 27 CLECs whose interconnection agreement contains UNE combinations, how to order each specific combination, including those involving unbundled switching. Letters were sent to each of the CLECs on May 28, Attached to each letter was a matrix of the combinations in their interconnection agreement cross-referenced to a package of ordering instructions. Murray Attachment Q is a sample of the letter sent to Ameritech, AT&T, CRL Network, ICG, MCI WorldCom, and MediaOne, a matrix of the 54 combinations in these interconnection agreements cross-referenced to the applicable ASRs/LSRs, and a package of the applicable ASRs/LSRs forms. Murray Attachment R is a sample of the letter sent to Cable Plus, Ernest Communications, Inc, Spring and Winstar Wireless, a matrix listing the 31 combinations in these interconnection agreements crossreferenced to the applicable ASRs/LSRs and the same package 21

25 of applicable ASRs/LSRs attached to Murray Attachment Q. Murray Attachment S is a sample of the letter sent to ACN Communications, Advance Telecom Groups, Inc., Allegiance Telecom, e. Spire Communications, Focal Communications, Frontier Local Services, GST, GTE Communications, Level 3, North County Communications, Optel, Option One Communications, Paetec Communications, RCN Telecom, Sattal, Streamramp, and US Telepacific. Also attached is the matrix of the 22 combinations in these interconnection agreements cross-referenced to the applicable ASRs/LSRs. These CLECs also received the package of ASRs/LSRs attached to Murray Attachment Q. Ordering Interconnection Trunks 45. In the 271 Workshops, Pacific and the CLECs agreed to changes in Pacific s practices to mitigate problems associated with the timely and efficient provisioning of interconnection trunks. These revised practices are: Pacific shall provide firm order commitments (FOCs) for trunks within 4 business days for augments, and 7 business days for establishing new trunk groups. If there is a facility or switching equipment shortage, Pacific shall include a status for a relief date. The Remarks field of the FOC includes the cause of the shortage. If no relief date is available, further status due date shall be provided. 22

26 Pacific shall discontinue use of 9/9/99 as an indicator of no relief date. (e.g. No digital equipment available at this time. ) Remarks portion of the FOC shall state an expected status for the relief date and shall provide a contact name and number for the CLEC to review held-order status. By 5 p.m. on the day that the status is due, Pacific shall re-foc with current information. Pacific shall call CLECs on Held order-denied, as needed. If one-way analog trunks are offered and accepted, the held order will maintain its place on the held order list pending completion of the switch replacement. App. B, p , WS Agreements , ,and In the last six months, Pacific has made measurable improvements in both its processes and staff resources so that wholesale customers can consistently receive FOCs with the four and seven day averages in the performance measures standards. Trunk orders, both new and augments, are processed manually and are the most complex orders handled in the LSC. Three different organizations must work closely together to ensure that the FOC is completed with the correct information. While the LSC provides the front end contact with the customer on orders, it must coordinate its information flow with the Circuit Provisioning Center(CPC) and with the Trunk Provisioning 23

27 and Engineering Group (TP&E) to ensure that facilities are in place and available for the customer. Both the LSC and the CPC have continued to add resources during the past six months. An internal team of senior managers from the LSC, CPC and TP&E has developed a triage system for developing new process improvements and to eliminate roadblocks to efficient order processing. Process improvements developed by this team include revised M&P for communications within each group and between the three groups, escalation processes within each group and between the groups and tracking of orders as they are processed between the three groups. Additionally the three organizations continue to meet daily to review process changes, staffing and any other issues that could impact FOC delivery. IN addition to addressing the FOC agreement, Pacific revised its methods and procedures to reflect each of the remaining trunk agreements. Training was completed on April 30, On July 13, 1999, Accessible Letter was issued to confirm the implementation of the interconnection trunk FOC agreements. Murray Attachment T. Attachment U is a copy of a trunk FOC, with CLEC and customer specific information redacted. This FOC demonstrates Pacific s compliance with the interconnection trunk FOC requirements. Specifically, in the remark section, the FOC states that 24

28 the order is held/denied due to a lack of equipment in the Los Angeles 04 tandem office. The FOC shows an expected relief date of August 2, The Final Decision requires Pacific to publish and transmit to all CLECs an accessible letter regarding Customer Not Ready ( CNR ) notification letters, when the CLEC is unable to accept or not ready to perform an acceptance test on the due date. App. B, p. 15, WS Agreement On August 4, 1998, Pacific distributed Accessible Letter CLECC regarding CNR. Murray Attachment V. See also, CLEC Handbook, Interconnection, Murray Attachment W. In addition, Pacific updated its methods and procedures for its LSCs, and notified its trunk-provisioning technicians in its Local Field Operations Group and its Network Translation Group of the CNR process. Since January 1999, Pacific has issued over 900 CNR notification letters to CLECs. Jeopardy Notification Process 47. The CLECs are notified when a service installation date is in jeopardy. Jeopardy notifications may become necessary for a variety of reasons such as the need for additional design work, to secure network facilities, failure of the end-user to provide access to the network interface, etc. 25

29 48. When the LSC is notified of a jeopardy condition, the LSC notifies the CLEC of the jeopardy as well as the estimated service date. See Viveros Affidavit for discussing electronic jeopardy notification. A jeopardy tracking log is maintained in the LSC. The log includes the original order commitment date and time, date and time that the LSC was notified, and the date and time that the LSC notified the CLEC of the jeopardy. Customer Care 49. The LSCs Customer Care work groups were established to respond to inquires from the CLECs over the telephone. In the 271 Workshops the CLECs complained of calls not being answered in a timely manner and of being kept on hold for long periods of time. Further, the CLECs assigned to the Anaheim RLSC requested that they be given the ability to contact that center for their customer care needs rather than the San Francisco RLSC which, at the time, responded to customer care inquiries from all CLECs. Pacific agreed to install an Automatic Call Distribution (ACD) system to improve the LSCs responsiveness and to establish a Customer Care work group in the Anaheim RLSC. WS Agreement

30 50. On February 22, 1999 Pacific completed the installation of the ACD and included the Anaheim Customer Care Group and the Billing and Collections LSC on the system. In Accessible Letter CLECC , dated February 11, 1999, Pacific notified the CLECs of the new call menu options available in the Billing and Resale LSCs effective February 22, Murray Attachment X. Further, on March 1, 1999, Pacific expanded the ACD to include the Anaheim and San Francisco FLSCs. The ACD distributes and assigns calls to the Service Representatives on a first come, first served basis. As such, Pacific provides the same high quality service to each CLEC without regard to size. FD, p LISTINGS 51. Prior to the introduction of OSS flow-through, the LSC established a specialized work group in the Anaheim Resale LSC to correct resale listing errors. Resale listings errors are sent to the Anaheim Listings Error Correction work group for correction. The Operator Services Systems Technology organization, who operates and maintains the Listings Gateway, provides daily data feeds to the Listings Error Correction Unit to ensure timely error correction. Once the correction is input, it takes 3 to 4 business days to update the 411 Listings database. The same update in 27

31 Pacific s retail organization may take up to 5 business days. ESCALATIONS AND EXPEDITES 52. Requests for escalations or expedites are generally initiated by the CLEC through the appropriate RLSC or FLSC Customer Care work group. The Customer Care Service Representative attempts to resolve the issue with the CLEC online. If they are unable to resolve the issue, the Service Representative arranges for the CLEC to speak with a manager. Successive levels of management become involved in the escalation or expedite process depending on the particular circumstances surrounding the request. 53. First level and above escalations and expedites are tracked by the LSCs. Pacific tracks information on the CLEC initiating the request, the nature of the request, the root cause, the receipt to clear duration and the resolution. This data is used by the LSCs to improve the service provided to the CLECs. 54. Pacific agreed to provide the CLECs with specific escalation and expedite data on a per request basis. App. B, p. 5, and WS Agreement Pacific distributed Accessible Letter CLECC , dated October 29, 1998, notifying the CLECs that escalation and expedite data would 28

32 be available to them upon request on the 15th of each month for the previous month. Murray Attachment Y. As noted in the Accessible Letter, Pacific agreed to provide data on the number of first level and above escalations/expedites, root cause analysis information, receipt to clear duration and final resolution. Through May 1999, only two CLECs have requested escalation and expedite reports. 55. Subsequent to the 271 Workshop, Pacific agreed to provide the CPUC s Staff with aggregate level escalation and expedite data on a quarterly basis, beginning with the first quarter of Murray Attachment Z is the report of the CLEC aggregate esclations, including the quantity, reason for escalation, root cause analysis, and receipt to clear duration for January through June BILLING AND COLLECTIONS 56. The LSC Billing and Collections work group serves as the CLECs single point of contact for all billing and collections questions and issues. The group monitors all CLEC bills for payment, answers the billing inquires, makes adjustments for incorrectly billed amounts, and resolves billing disputes as they arise. Further, the Billing and Collections work group is responsible for establishing and 29

33 maintaining procedures that ensure prompt payment of monies owed to Pacific. Billing Claims Process And Dispute Resolution 57. There are two billing dispute processes for resale CLECs. One process applies to CLECs who purchase service under the terms of the California resale tariff, Schedule Cal. P.U.C. No.175-T. The other process applies to CLECs who do business with Pacific under a stand-alone resale agreement or a resale appendix of an interconnection agreement. There is only one billing dispute process for facilitybased CLECs in California. 58. The resale billing dispute processes are contained the following two sections of the CLEC Handbook, Billing and Collection: Resolving Resale Billing Disputes - California Resale Agreements Murray Attachment AA. Resolving Resale Billing Disputes - California Resale Tariffs Murray Attachment AA. 59. The Facility-based billing dispute process is located in the CLEC Handbook, Billing and Collections, 4.2, Resolving Billing Disputes for Facilities Based CLECs. Murray Attachment BB. 30

34 60. As agreed on the 271 Workshops, the CLEC Handbook was updated to reflect the current billing dispute and escrow establishment processes for resale and facility based CLECs. Pacific notified the CLECs of the update by Accessible Letter CLECC , dated May 5, Murray Attachment CC. WS Agreement When billing disputes occur, the Billing and Collections group accepts the CLEC s claim and takes the appropriate actions to investigate the dispute. In order to bring the process to resolution within 30 days the claim must be submitted by the CLEC with correct data, in a valid format, and in a timely manner. If the CLEC is untimely in their dispute submittal, resolution may take 30 to 90 days or more to resolve, depending on the complexity of the claim, as records need to be retrieved from archives. 62. If the dispute cannot be resolved with 30 days, Pacific notifies the CLEC of the status of the dispute, the expected resolution date, and the date that the credit will be issued. App. B, p. 4, WS Agreement The dispute resolution process ends when Pacific adjusts or sustains the billed amounts and provides the CLEC with a detailed explanation of its findings via a formal letter of resolution. This generally occurs within 30 to 60 days. 31

35 63. As required by the Final Decision, Pacific provides copies of its dispute logs to the CLECs upon request. Pacific tracks billing disputes and will provide a CLEC its dispute log upon request. App. B, p.4 and WS Agreement In order to minimize CLEC billing disputes, the Billing and Collections group conducts pre-bill and post-bill validations. The purpose of such validations is to improve the accuracy of the bill delivered to the CLEC. Currently, pre and post-bill validations are accomplished by reviewing a statistically valid sampling of resale CLEC bills. The pre-bill validation process compares the service order against the LSR before a bill is rendered. This minimizes the number of adjustments required during post-bill validation. The post-bill validation compares the LSR, the service order and the bill. Billing Forums 65. As a result of the 271 Workshops, Pacific agreed, and the Commission subsequently ordered, that Pacific would conduct a Billing Forum. App. B. p. 4 and WS Agreement Accessible Letter CLECC , dated October 16, 1998, announced a Billing Forum to be held on November 10, Murray Attachment DD. 32

36 66. Thirty-three representatives from the CLECs discussed 51 issues at the Billing Forum. On December 18, 1998, Pacific sent Accessible Letter CLECC communicating the record of open issues and outcomes that resulted from the Billing Forum. Murray Attachment EE. Discussion topics from this meeting included bill validation, an overview of 800 intralata traffic, media available for receipt of billing data, USOC descriptions, billing disputes and claims and meet point billing. 67. Accessible Letter CLECC and Accessible Letter CLECC , advised CLECs of a subsequent Billing Forum on March 5, Murray Attachment FF and GG, respectively. 68. As a result of the CLECs identification of issues during these meetings, Pacific implemented changes to its billing processes. For example, a CLEC found instances where individual Call Return Activation charges and the monthly recurring rate for Call Return Activation were both being billed on the same line. Pacific investigated and found and corrected a problem within its billing software. Another issue raised by the CLECs concerned an inappropriate billing for transport termination for calls of 0 miles. Pacific investigated and discovered that unbundled port was inappropriately being billed for 33

37 transport termination for calls of 0 miles. The error was corrected. ACCOUNT MANAGEMENT 69. CLECs are assigned to an Account Manager based on workload as determined by a monthly weighting analysis. The weighting process takes into consideration whether the CLEC is providing resale, UNE and/or interconnection services, whether the CLEC is in the negotiation, initial implementation or maintenance stage, the number of locations (cities) in which the the CLEC does business, and any special activities or projects. At the macro level, the ratio of active CLEC s to Account Managers is monitored to insure acceptable staffing levels. In addition, Account Directors make decisions on a regular basis to re-allocate work based on identified critical needs. For instance, if a particular customer is demanding more time based on service or operational issues, the Director may elect to off-load accounts to enable an Account Manager to focus his/her time on resolving the issues specific to that customer. 70. CLEC s mature through various stages of a lifecycle as they enter the local market. During the early stages of their relationship with Pacific, the CLEC focuses on contract 34

38 negotiations, and then matures to issues such as interconnection, OSS implementation, and finally on to passing orders to support their end-users. Within the account management team, certain individuals have built subject matter expertise in areas such as contract negotiation, interconnection, 911 services, collocation and OSS support. These subject matter experts are available to the assigned account manager to support the CLEC s service requirements. This approach allows the CLEC to maintain the convenience of a single point of contact, but provides for a ready stable of subject matter expertise to assist on the broad variety of issues encountered when entering the local market. This concludes my affidavit. [Signature Page Follows] 35

39 I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge. July, 1999 Victoria Murray General Manager-LSC Pacific Bell 36