i

PUBLIC VERSION

AFFIDAVIT OF WILLIAM C. DEERETABLE OF CONTENTS

SUBJECT PARAGRAPH (S)

CHECKLIST ITEM (i) INTERCONNECTION 8-46

CHECKLIST ITEM (ii) NONDISCRIMINATORYACCESS TO NETWORK ELEMENTS

47-80

CHECKLIST ITEM (iv) LOCAL LOOP 81-100

CHECKLIST ITEM (v) LOCAL TRANSPORT 101-111

CHECKLIST ITEM (vi) LOCAL SWITCHING 112-145

CHECKLIST ITEM (vii) E911, DIRECTORYASSISTANCE, AND OPERATOR CALLCOMPLETION

146-172

CHECKLIST ITEM (x) ACCESS TODATABASES AND ASSOCIATED SIGNALING

173-202

CHECKLIST ITEM (xi) NUMBERPORTABILITY

203-207

CHECKLIST ITEM (xii) LOCAL DIALINGPARITY

208-210

INTRALATA DIALING PARITY 211

CHECKLIST ITEM (ix) ACCESS TOTELEPHONE NUMBERS

212-221

OTHER NETWORK ISSUES 222-237

AFFIDAVIT OF WILLIAM C. DEERETABLE OF ATTACHMENTS

ii

Description AffidavitReference

A Advice Letter 20230 ¶¶17, 50B Accessible Letter CLECC 99-220 ¶17C Accessible Letter CLECC 99-100 ¶34D Accessible Letter CLECC 98-143 ¶36E CLEC Interconnection Trunk Forecast

Form from the CLEC Handbook¶36

F Accessible Letter CLECC 99-097 ¶36G Network Forms from the CLEC Handbook ¶¶40, 42H Accessible Letter CLECC 99-110 ¶¶40, 42I Accessible Letter CLECC 99-095 ¶43J Accessible Letter CLECC 99-109 ¶43K Accessible Letter CLECC 99-125 ¶44L Accessible Letter CLECC 99-049 ¶45M Collocation Handbook, § 1.9.1

PACIFIC BELL PROPRIETARY INFORMATION¶76

N Technical Publication TP76730 ¶90O Accessible Letter CLECC 99-067 ¶92P August 22, 1998 Letter re: Binder

Group Management Meeting¶93

Q Accessible Letter CLECC 98-110 ¶93R November 11, 1998 Letter re: Spectrum

Management Meeting¶93

S Accessible Letter CLECC 99-072 ¶93T Technical Publication L-780063 ¶¶37, 93U Effects of Digital Disturbances Graph

and Interference Table¶94

V Diagrams of IDLC and UDLC ¶96W April 27, 1999 Letter re: Deployment

of IDLC Loops¶99

X Transport Diagram ¶101Y Accessible Letter CLECC 98-116 ¶¶106, 108Z Accessible Letter CLECC 99-112 ¶¶106, 108AA CLEC Handbook, UNE, § 2

PACIFIC BELL PROPRIETARY INFORMATION¶¶113, 132,

232BB August 15, 1997 Letter re: Collapsing

SwitchesPACIFIC BELL AND THIRD PARTYPROPRIETARY INFORMATION

¶126

CC Accessible Letter CLECC 99-048 ¶126DD Accessible Letter CLECC 99-062 ¶126EE Accessible Letter CLECC 99-189 ¶¶130, 132

AFFIDAVIT OF WILLIAM C. DEERETABLE OF ATTACHMENTS

iii

FF Report of Results of Lucent 2PICTechnical TrialAttachment 3 to Report is PACIFIC BELLPROPRIETARY INFORMATION.

¶134

GG Report of Results of Nortel 2-PICTechnical Trial and Addendums

¶135

HH Accessible Letter CLECC 99-161 ¶136II Accessible Letter CLECC 99-173 ¶156JJ Training and Reference Guide for 911

GatewayPACIFIC BELL PROPRIETARY INFORMATION

¶165

KK CLEC Handbook, Ancillary Services, §8.0PACIFIC BELL PROPRIETARY INFORMATION

¶184

LL CLEC Handbook, Interconnection, § 5PACIFIC BELL PROPRIETARY INFORMATION

¶196

MM Accessible Letter CLECC 99-129 ¶196NN Accessible Letter CLECC 99-030 ¶211OO Advice Letters 20217 and 20217A

(Relevant Tariff Pages Included)¶211

PP Network Disclosure Accessible LetterSWA 99-115

¶223

QQ Accessible Letter CLECC 99-096 ¶224RR December 16, 1998 Letter re: Ancillary

Equipment¶227

SS Accessible Letter CLECC 99-147 ¶228TT Accessible Letters CLECC 99-203 and

CLECC 99-248¶228

UU Accessible Letter CLECC 99-152 ¶231VV Advice Letter 19412 ¶232WW June 30, 1999 Letter re: Ancillary

Equipment¶237

XX CLEC Handbook, Interconnection, § 15.0PACIFIC BELL PROPRIETARY INFORMATION

¶17

YY CLEC Handbook, Interconnection, § 14.0PACIFIC BELL PROPRIETARY INFORMATION

¶43

ZZ CLEC Handbook, Interconnection, § 3.0PACIFIC BELL PROPRIETARY INFORMATION

¶60

AFFIDAVIT OF WILLIAM C. DEERETABLE OF ATTACHMENTS

iv

AAA CLEC Handbook, UNE, § 1.0PACIFIC BELL PROPRIETARY INFORMATION

¶81

BBB CLEC Handbook, UNE, § 3.0PACIFIC BELL PROPRIETARY INFORMATION

¶102

CCC CLEC Handbook, Ancillary Services,§ 1.0PACIFIC BELL PROPRIETARY INFORMATION

¶167

DDD CLEC Handbook, UNE, § 4.0PACIFIC BELL PROPRIETARY INFORMATION

¶177

EEE October 28, 1998 Letter re: AncillaryEquipment

¶226

FFF CLEC Handbook, UNE, § 7.0PACIFIC BELL PROPRIETARY INFORMATION

¶228

1

1. My name is William C. Deere. My business address is One

Bell Plaza, Room 2312, Dallas, Texas 75202. I am the

Regional Manager-Planning and Engineering for Southwestern

Bell Telephone Company (“SWBT”), a wholly owned subsidiary

of SBC Corporation (“SBC”). In this position, I

participate in the development, planning, and engineering

of SWBT’s, Pacific Bell’s (“Pacific’s”) and Nevada Bell’s

telephone networks and act as the network regulatory and

legislative technical liaison in those companies. In this

position, I have testified before seven state public

utilities commissions concerning the technical issues

contained in this affidavit.

2. I have a Bachelor of Science - Electrical Engineering

degree from Southern Methodist University in Dallas, Texas.

I am a licensed professional engineer in Texas. I have

also completed training conducted by the Bell System, AT&T

(Lucent), Northern Telcom (Nortel), Ericsson, Bellcore, and

SWBT on switching systems, transmission systems, and local

network distribution systems.

3. I was employed by SWBT in 1961 as a student engineer. I

worked in the central office and the PBX engineering groups

of the Engineering Department until October 1969. At that

time, I was transferred to the Traffic Department where I

worked as the Manager-Switching Design and then the Traffic

Manager-Network Design where I supervised the PBX design

group for the north part of Texas until October 1978. I

worked in St. Louis for 18 months as the head of the

2

Business Services staff and then returned to Dallas as the

Division Manager-Network Administration. In October 1984,

I assumed the duties of Division Staff Manager-Network

Planning staff. My title was changed to Division Manager-

Network Engineering (Customer Services) on October 1, 1986,

as a result of a reorganization of the SWBT Network

Department. I assumed my present responsibilities for the

five states served by SWBT in October 1993. When SBC and

Pacific merged in 1997, I assumed the same responsibilities

for the Pacific and Nevada Bell networks.

4. The purpose of my affidavit is to describe how Pacific has

satisfied all of the network-related elements of the

competitive checklist set forth in section 271(c)(2)(B) of

the Telecommunications Act of 1996 (”Act”), and the related

requirements in D.98-12-069 issued by the California Public

Utilities Commission (“CPUC”) on December 17, 1998 (”Final

Decision”). In doing so, I will describe the network-

related elements Pacific provides to requesting carriers

through Pacific’s interconnection agreements with those

carriers.

5. Where applicable, I explain how Pacific’s contracts satisfy

its duties under sections 251 and 252 of the Act, the FCC’s

regulations implementing those sections (”FCC Rules”),1 the

FCC’s First Report and Order, FCC 96-325, released August

1 Code of Federal Regulations (“C.F.R.”), Part 51, Subpart D.

3

8, 1996 (”Order”);2 Second Report and Order, FCC 96-333,

released August 8, 1996 (”Second Order”);3 First Report and

Order on Reconsideration, FCC 96-394, released September

27, 1996 (”First Reconsideration Order”);4 Second Order on

Reconsideration, FCC 96-476, released December 13, 1996

(”Second Reconsideration Order”);5 Third Order on

Reconsideration, FCC 97-295, released August 18, 1997

(”Third Reconsideration Order”);6 and First Report and Order

and Further Notice of Proposed Rulemaking, FCC 99-48,

released March 31, 1999 (”Advanced Telecommunications

Order”).7

6. My affidavit demonstrates that Pacific currently offers all

network-related checklist items in its interconnection

agreements with CLECs in California.

2 In The Matter of Implementation of the Local Competition Provisions in heTelecommunications Act of 1996, CC Docket Nos. 96-98 and 95-185, FirstReport and Order, FCC No. 96-325, 11 FCC Rcd 15499 (rel. Aug. 8, 1996).

3 In the Matter of Implementation of the Local Competition Provisions of theTelecommunications Act of 1996, CC Docket Nos. 96-98 and 95-185, SecondReport and Order and Memorandum Opinion and Order, FCC No. 96-333, 11 FCCRcd. 19392 (rel. Aug. 8, 1996).

4 In The Matter of Implementation of the Local Competition Provisions in heTelecommunications Act of 1996, CC Docket Nos. 96-98 and 95-185, Order onReconsideration, FCC No. 96-394, 11 FCCR 13042 (rel. Sep. 27, 1996).

5 In The Matter of Implementation of the Local Competition Provisions in heTelecommunications Act of 1996, CC Docket Nos. 96-98 and 95-185, SecondOrder on Reconsideration, FCC No. 96-476, 11 FCCR 19738 (rel. Dec. 13,1996).

6 In The Matter of Implementation of the Local Competition Provisions in heTelecommunications Act of 1996, CC Docket Nos. 96-98 and 95-185, ThirdOrder on Reconsideration and Further Notice of Proposed Rulemaking, FCC No.97-295, 12 FCCR 12460 (rel. Aug. 18, 1997).

7 In the Matter of Deployment of Wireline Services Offering AdvancedTelecommunications Capability, CC Docket No. 98-147, First Report and Orderand Further Notice of Proposed Rulemaking, FCC No. 99-48, 1999 WL 176601(FCC), (rel. Mar. 31, 1999).

4

7. While abiding by the FCC’s decisions insofar as they are

effective, Pacific reserves its rights to modify negotiated

agreements in accordance with future court or

administrative decisions that expand or limit its

obligations, and consistent with the procedures set out in

Pacific’s agreements and section 252 of the Act.

I. CHECKLIST ITEM (i) INTERCONNECTION

8. A Bell Operating Company (”BOC”), such as Pacific, meets

the requirements of checklist item (i) if it offers

interconnection in accordance with the requirements of

sections 251(c)(2) and 252(d)(1). 47 U.S.C. §

271(c)(2)(B)(i). As detailed below, Pacific’s

interconnection agreements fully satisfy this mandate.

Methods of Interconnection

9. Consistent with section 251(c)(2)(A) of the Act and the FCC

Rules, Pacific provides interconnection with its network

for the transmission and routing of telephone exchange

traffic and/or exchange access traffic. 47 C.F.R. §

51.305(a)(1); Order ¶ 184. Pacific currently provides

interconnection using three alternatives and will provide

other technically feasible alternatives via the Bona Fide

Request (”BFR”) process8 discussed in the Hopfinger

Affidavit. In summary, Pacific offers: (1) mid-span fiber

interconnection (”MSFI”) or ”fiber-meet;” (2) collocation

8 The BFR process was formerly known in California as the Interconnection orNetwork Element Request ("INER") process.

5

interconnection; and (3) leased facilities interconnection.

Each of these interconnection arrangements provides a CLEC

with the ability to terminate a transport facility in

collocation arrangements so that CLEC circuits may be

interconnected to the Pacific network. AT&T,9 Att. 10, § 3,

Att. 18; ACI,10 § 11.0, 11.1, 11.5, 11.6; Brooks,11 § I,I-h,

§ XI, pp. 50-55; Cox,12 § III, A-E, § IV, A, 1-12, §. X;

MCI,13 Att. 10 § 3 & 18; and TW,14 Art. III, Art. IV, Art.

V, Art. XIII, Art. XVII.

10. A MSFI arrangement may be negotiated at any mutually

agreeable, economically, and technically feasible point

between a CLEC’s premises and a Pacific tandem or end

office. ACI, §§ 11.6.1 and 11.62; Brooks, § XI, F; TW,

Art. XIII, § 13.03(c)-(f); and Cox, §§ II.55, IV.A.3 & C.4.

Additionally, Pacific and MFS have agreed to contract

language for MSFI.15

9 “AT&T” - Agreement between Pacific and AT&T Communications of California,Inc., effective December 19, 1996, D.96-12-034.

10 “ACI” - Interconnection Agreement Between Accelerated Connections, Inc.,effective September 24, 1997.

11 “Brooks” - Interconnection Agreement Between Brooks Fiber Communications ofSacramento, Inc., Brooks Fiber Communications of San Jose, Inc., BrooksFiber Communications of Bakersfield, Inc., Brooks Fiber Communications ofStockton, Inc., Brooks Fiber Communications of Fresno, Inc. and Pacific,November 26, 1996, D.96-11-059.

12 ”Cox” - Local Interconnection Agreement between Cox California Telcom, Inc.and Pacific, October 9, 1996, D.96-10-040.

13 ”MCI” - Interconnection Agreement Between MCI TelecommunicationsCorporation and Pacific, February 3, 1997, D.97-01-039.

14 “TW” - Master Interconnection Agreement between Time Warner AxS ofCalifornia, L.P. and Pacific, January 23, 1997.

15 The Pacific/MFS interconnection agreement is being arbitrated; however, theMSFI language is not a disputed issue in the arbitration.

6

11. A MSFI may be used to provide interoffice trunking for the

purpose of originating and terminating calls between a

CLEC’s switch and a Pacific switch, and for transit calls

to or from a third party via Pacific’s tandem switch. 47

C.F.R. § 51.321(b). If MSFI is used to interconnect

Pacific’s and the requesting CLEC’s networks, the parties

jointly engineer and operate a single SONET transmission

system. ACI, § 11.6; Brooks, § XI; and TW, Art. XIII, §

13.03. There are two basic mid-span designs. In the first

design, a CLEC’s fiber cable and Pacific’s fiber cable are

connected at an economically and technically feasible point

between the CLEC’s location and the last entrance manhole

at Pacific’s central office or tandem switch location. For

the second design, a CLEC provides fiber cable to the last

entrance manhole at the Pacific central office or tandem

switch location, and provides sufficient length of fiber

optic cable for Pacific to pull the fiber optic cable to

the Pacific cable vault for termination on the Pacific

Fiber Distribution Frame (”FDF”). Pacific is responsible

for designing, provisioning, ownership and maintenance of

all equipment and facilities on its side of the Network

Interconnection Point (”NIP”). Similarly, the CLEC is

responsible for the same functions on its side of the NIP.

Each party is free to select the manufacturer of its Fiber

Optic Terminal (”FOT”). ACI, § 11.6.2; Brooks, § XI F.2;

and TW, Art. XIII, § 13.03a.

7

12. The CLEC location includes FOTs, multiplexing equipment,

and fiber required to take the optical signal from Pacific

for trunking or transport of unbundled loop traffic. The

fiber connection point may occur at several locations:

• A location with an existing Pacific fiber terminationpanel. In this situation, the NIP is outside the Pacificbuilding that houses the fiber termination panel.

• A location with no existing Pacific fiber terminationpanel. In this situation, Pacific and the CLEC negotiateprovision, maintenance, and ownership of a fibertermination panel and an aboveground outside cabinet as aNIP and for connection of the fiber cables.

• A manhole outside the Pacific central office or tandemswitch location. In this situation, the CLEC providessufficient length of fiber optic cable for Pacific topull the fiber optic cable to the Pacific cable vault fortermination on the Pacific FDF. The NIP is at themanhole and Pacific assumes ownership and maintenanceresponsibility for the fiber cabling from the manhole tothe FDF.

13. The Pacific central office or tandem switch location

includes all Pacific FOTs, multiplexing, and fiber required

to take the optical signal hand-off provided by the CLEC

for trunking. This location is Pacific’s responsibility to

provision and maintain. ACI, § 11.6.3; AT&T, Att. 6, §

5.2.5; Brooks, XI, F.3; and TW, Art. XIII, § 13.03a.

14. Any or all of the above methods of interconnection are

available at the trunk side of the local switch, the trunk

connection points of a tandem switch, central office cross-

connect points, out-of-band signaling transfer points, and

8

points of access to UNEs. Pacific provides requesting

CLECs options for interconnection at all of these points.

47 C.F.R. § 51.305(a)(2); AT&T, Att. 18; and Brooks, § I,

a-h, § XI.

15. The FCC Rules require the availability of interconnection

at the line side of a local switch. Paragraphs 210 and 211

of the FCC Order provide that an example of this type of

interconnection would be at the Main Distribution Frame

(”MDF”) in the central office, and would be useful for

CLECs that have their own distribution plant and seek to

interconnect to an Incumbent Local Exchange Carrier’s

(”ILEC’s”) switch. Pacific has not yet received any

requests for line side interconnection, but will make it

available upon request. 47 C.F.R. § 51.305(a)(2)(i); GST,16

Att. 6, Att. 18.

16. Pacific and a CLEC may mutually agree to utilize another

interconnection method when it is technically feasible.

ACI, 2.8 & 11.2; AT&T, Att. 6, 1.6.2; and TW, Art. XI,

11.02(b)(6).

17. The Final Decision requires Pacific to demonstrate it is

negotiating with, and providing, any interested CLEC with

frame relay Network-to-Network Interconnection ("NNI")

under sections 251 and 252 of the Act. App. B, p. 16.

Pacific has negotiated an amendment for frame relay NNI

with e.Spire. The amendment was filed with the Commission

16 “GST” - Agreement between Pacific and GST Telecom California, Inc., GSTPacific Lightwave, Inc., June 4, 1997.

9

as Advice Letter 20230 on May 6, 1999 and became effective

on June 4, 1999. Deere Attachment A. Accessible Letter

CLECC 99-220 issued June 15, 1999 notified CLECs of

Pacific's willingness to negotiate frame relay NNI. Deere

Attachment B. The CLEC Handbook, Interconnection, section

15 has been updated to provide a description of frame relay

NNI. Deere Attachment XX. Pacific has created and made

available generic frame relay NNI language to two CLECs for

possible amendments to their existing interconnection

agreements. In addition, methods and procedures have been

developed for the account teams and affected Pacific groups

to order and provision frame relay.

Collocation

18. Where space permits, a CLEC is allowed to arrange for the

collocation of its own equipment in Pacific’s equipment

buildings and structures when the CLEC’s equipment is used

for interconnection and/or access to UNEs. The Hopfinger

Affidavit explains the available collocation arrangements,

when each arrangement may be used, and any special

conditions related to each arrangement.

Trunking Arrangements

19. Pacific provides two options for interconnection trunking

in California. A CLEC may elect to use direct trunking

from its switch to a Pacific end office, or the CLEC may

elect to interconnect to Pacific end offices through each

of Pacific’s access tandems in the LATA in which it

10

originates or terminates local traffic. ACI, § 1.1; AT&T,

Att. 18; MCI, Att. 18; and TW, Art. IV & V.

Interconnection trunking may be used to exchange local and

intraLATA toll traffic. Separate meet-point trunks are

established for the joint provisioning of interLATA

switched access traffic. ACI, 1.6 & 1.7; AT&T, Att. 18,

I.; GST Att. 18; MCI, Att. 18; and Cox V,D.

20. When a CLEC interconnects directly to a Pacific end office,

local and intraLATA traffic will be terminated over a

direct trunk group to the end office. This trunk group

will be two-way and will utilize Signaling System 7 (“SS7”)

protocol signaling. 47 C.F.R. § 51.305(f); ACI, § 1; AT&T,

Att. 18; GST, Att. 18; and TW, Art. III & V.

21. Pacific allows interLATA traffic to be transported between

the CLEC central office and the Pacific access tandem over

a meet-point trunk group, separate from local and intraLATA

toll traffic. The access toll-connecting trunk group can

be established for the transmission and routing of exchange

access traffic between the CLEC’s end users and

interexchange carriers (“IXCs”) via a Pacific access

tandem. This trunk group may be set up as one-way or two-

way and can utilize SS7 or MF signaling protocol. 47

C.F.R. § 51.305(f); ACI, 1.7; AT&T, Att. 18; GST, Att. 18;

MCI, Att. 18; and TW, Art. V § 5.01, 5.02, & 5.03.

22. Tandem level terminating access requires the CLEC to

establish local interconnection trunk groups to each

Pacific access tandem in the LATA(s) in which it originates

11

or terminates local and/or toll traffic with Pacific. This

arrangement may be combined with end-office interconnection

arrangements to provide for alternate routing of calls.

Tandem trunking may use one-way or two-way interconnections

and may use either MF or SS7 signaling. ACI, § 1.1; AT&T,

Att. 18; GST, Att. 18; and MCI, Att. 18.

23. If the CLEC chooses, additional trunk groups may be

established for services such as E911, mass calling or

public response choke networks, and operator services

access. ACI, § 1.6.5 & 1.6.9; AT&T, Att. 18, J & K; MCI,

Att. § 18, 1.11 & 1.12; and Cox § IV, A, 10 & 11.

24. Pacific provides trunks either directly to a CLEC from a

Pacific end office or from each access tandem on a trunk

group separate from the interLATA meet-point trunk group.

25. InterLATA traffic is transported from Pacific’s access

tandem over a separate trunk group from local and intraLATA

toll traffic. This trunk group may be set up as one-way or

two-way and can utilize either MF or SS7 protocol

signaling.

26. Interconnection at all points and using all methods

available is provided under nondiscriminatory and

reasonable terms and at the same level of quality Pacific

provides comparable interconnections to itself and its

affiliates. 47 U.S.C. § 251(c)(2)(C) and (D). Equal

quality interconnections are achieved through the use of

the same facilities, interfaces, technical criteria, and

service standards as Pacific applies to itself. Order ¶

12

224; AT&T, Att. 11, 1; Brooks § II; and MCI, Att. 11, 1.1.

In May 1999, only 1.48 percent of total CLEC calls to final

trunk groups blocked in excess of 1 percent. The CLECs

have order control for these trunk groups; as a

consequence, Pacific cannot be held responsible for this

blockage.17 During this same period, 6.76 percent of total

Pacific calls to final trunk groups blocked in excess of

one percent. Additionally, where Pacific has order control

for one-way trunk groups to the CLEC, the blocking for

March and April was 0 percent.18 In May, the blocking was

.32 percent for the trunk group under Pacific’s control.

This was due to a two-hour blocking occurrence on one day

during the month of May on a single trunk group. In June,

there was 0 percent blocking.

27. As of May 31, 1999, over 513,000 trunks have been provided

to CLECs for interconnection to the Pacific network. In

addition, over 25,000 trunks have been installed at the

CLECs’ request for which the CLECs are not yet ready to

activate and put into service. These are referred to as

Customer Not Ready (“CNR”).19 Putting these pending trunks

into service would greatly reduce or eliminate blockage in

the trunk groups under the control of the CLECs. As noted

in the Murray Affidavit, Pacific has sent over 900 CNR

17 Order control means that the CLEC, not Pacific, has the responsibility toissue orders for new, augmented, or reduced trunk groups.

18 For one CLEC THIRD PARTY PROPRIETARY INFORMATION, Pacific has order controlfor one-way trunk groups originating with Pacific and terminating at theCLEC’s location.

19 See Murray Affidavit for a description of the CNR process.

13

notification letters this year and is working with the

CLECs to schedule firm dates to put these trunks into

service or to cancel the orders so the facilities may be

made available for other carriers.20 The CLECs have

administrative control to issue orders on two-way trunk

groups and they initiate action to increase or decrease the

number of trunks in service in two-way groups.

28. As of May 28, 1999, Pacific had 12 service requests for

two-way interconnect trunks that were held and denied. As

of May 28, 1999, there were no held and denied requests for

one-way interconnect trunks.

29. Pacific has worked diligently to provide trunks when and

where requested by CLECs. In order to free up the

requested trunk terminations, Pacific has made the

following types of major network rearrangements: combining

trunk groups, tandem rehomes (i.e., move trunk groups from

one tandem to another), tandem self-initiatives (e.g.,

removing Pacific trunks from tandems), and establishing

direct end-office trunks. These types of rearrangements

within the Pacific network have made available about

107,000 trunk terminations. The CLECs’ forecasts and

demand for trunks are often greatly overstated or

understated. For instance, as of June 14, 1999, 532,048

trunks were installed for CLEC traffic; however, only

210,907 trunks were required based on CLEC usage. At the

20 This is consistent with WS Agreement 1.2.1.5 and App. B, p. 13.

14

same time, the forecasts provided by the CLECs for 1999

indicated a requirement for over 1,000,000 trunks.

30. To minimize trunk blocking, all trunk forecasting and

servicing for the local and intraLATA toll trunk groups are

based upon the same industry standard objectives Pacific

uses for its own trunk groups, unless otherwise agreed to

by the CLEC and Pacific. Pacific designs trunk groups to a

blocking standard of one half of 1 percent (.005) during

the average busy hour for final trunk groups between the

CLEC network and the Pacific network carrying meet-point

traffic. All other final trunk groups are engineered with

a blocking standard of 1 percent (.01). ACI, 1.13; AT&T,

Att. 18, IX; Brooks, I. M.; GST, Att. 18, § 9; MCI, Att.

18, § 9; and Cox XVIII.

31. Pacific and the CLEC jointly manage the capacity of local

interconnection trunk groups. ACI, § 1.15; AT&T, Att. 18,

§ X. B; Brooks, § I. O; GST, Att. 18, § 10.2; MCI, Att. 18,

§ 10.2; TW, Art. XVIII, 18.05; and Cox § XIX, B.

32. Pacific uses standard trunk traffic engineering methods

described in Bell Communications Research, Inc. SR-TAP-

000191, Trunk Engineering Concepts and Applications. This

ensures all interconnection trunking is managed in the same

manner as Pacific does its own trunk groups.

33. In the 271 Workshops held in 1998, Pacific agreed to meet

with MCI to explain Trunk Carrier Identification Codes

(“TCIC”) and trunk numbering assignments. MCI was having

to issue supplemental orders to correct duplicate TCICs.

15

Pacific held a joint planning meeting with MCI on September

25, 1998 to explain how TCICs and trunk numbers are

assigned. Pacific explained and provided the guidelines

for TCIC and trunk number assignment. MCI has not

requested any additional information about this issue since

that meeting. 271 Workshop Agreement (“WS Agreement”)

1.2.1.1.

34. The Final Decision required Pacific to meet with the CLECs

and provide an explanation of Pacific’s system of assigning

Circuit Facility Assignment (“CFA”) and TCIC numbers so

that CLEC’s and Pacific’s systems can be “mapped.” App. B,

pp. 14-15, WS Agreements 1.2.1.2, 1.2.1.3, and 1.2.1.4. On

March 26, 1999, Pacific distributed Accessible Letter CLECC

99-100 along with its trunk number guidelines. Deere

Attachment C. This letter invited all CLECs to an

interconnection trunk forum on April 8, 1999. The forum

was conducted as scheduled to help CLECs map their systems

pursuant to Pacific’s trunk number guidelines.

35. As agreed to with the CLECs at the 271 Workshops and

described in the Final Decision (WS Agreement 1.2.1.6;

App. B, p. 12), Pacific provides a Joint and Cooperative

Planning (“JCP”) process that includes the following:

A. CLECs provide a new or updated forecast every January

and July to Pacific, using the Pacific form, or as

mutually agreed to by the parties.

B. In this process, Pacific and individual CLECs meet to

discuss specific projects, forecasting, network

16

architecture details, and/or plan and initiate

projects. CLECs bring to the meeting the completed

network information sheet.

C. In the JCP meetings, Pacific and the CLECs jointly

discuss forecasts and other information in Pacific’s

construction plans.

D. Pacific must publish sample forms to be used in the

JCP for interconnection trunk forecasting (“Local

Network Interconnection Trunk Forecast”) and network

planning (“Pacific Bell CLEC Network Information

Sheet”). These forms must be published in the CLEC

Handbook with descriptions and instructions for

completion, must be included in an accessible letter

to all CLECs, and must be made available

electronically to all CLECs.

36. To implement items A and D above, Pacific distributed

Accessible Letter CLECC 98-143 on December 23, 1998. This

accessible letter describes a process for CLECs to provide

trunk forecasts by January 1 and July 1 of every year.

Deere Attachment D. The forecast form and an example were

attached to the letter. The form identifies and explains

the data fields to be populated. Pacific revised the

forecast form to an electronic spreadsheet format and added

it to the CLEC Handbook, Forms section on February 24, 1999

and sent the revised form to all CLECs as an attachment to

Accessible Letter CLECC 99-097. Deere Attachments E and F.

17

37. In compliance with item B above, Pacific meets with CLECs

to review forecasts and network architecture issues.

Pacific also provides project management of trunk orders

for major augments, defined as greater than 3DS3s (2016

trunks). Pacific has taken steps to implement project

management of trunk orders for greater than 192 trunks and

less than 2016 trunks. For orders within this range,

project management will consist of critical date

coordination.21

38. From December 17, 1998 through May 31, 1999, Pacific has

conducted JCP meetings, as described in item C above, with

20 CLECs.

39. The Final Decision requires Pacific to publish sample forms

to be used in the JCP for interconnection trunk forecasting

(“Local Network Interconnection Trunk Forecast”) and

network planning (“Pacific CLEC Network Information

Sheet”). App. B, p. 12. As discussed above in paragraph

36, Pacific published the forecast form in Accessible

Letters CLECC 98-143 and CLECC 99-097 and added the form to

the CLEC Handbook, Forms section. The new form includes

information on how to populate all fields.

40. As required by the Final Decision, Pacific published a

sample network planning form22 in the CLEC Handbook, Forms

section on March 31, 1999. Deere Attachment G. On April

21 See Murray Attachment T for Accessible Letter CLEC 99-250 describing thisprocess.

22 This network planning form is the “network information sheet” referred toin paragraph 35.D.

18

1, 1999, Pacific released Accessible Letter CLECC 99-110

which distributed the network planning form along with a

description of the fields on the form. Deere Attachment H.

From June 1, 1998 through June 30, 1999, Pacific received

the network planning form from ten CLECs.23

41. The Final Decision requires Pacific to provide the

following four network utilization reports, upon request:

(1) the common transport data that Pacific currently

provides to the IXCs (this report will be provided on a

monthly basis to the CLECs via their account managers); (2)

trunk traffic (TIKI) reports monthly to all requesting

CLECs via their account managers; (3) electronic exchange

data (“DIXC”) (on a reciprocal basis) for trunk traffic

data on a weekly basis to CLECs who make electronic

exchange arrangements; and (4) ad-hoc point-to-point

traffic studies for use in JCP meetings as appropriate.

App. B, p. 13-14, WS Agreement 1.2.1.7.

42. The Final Decision requires that samples of the four

network utilization reports described above be published in

the CLEC Handbook in the format presented in the

collaborative process. App. B, p. 13. Pacific was

instructed to inform all CLECs of the availability of the

various traffic reports via accessible letter. The samples

for the common transport report, the TIKI report, and the

point-to-point traffic studies were added to the CLEC

23 THIRD PARTY PROPRIETARY INFORMATION

19

Handbook, Forms and the DIXC sample was added to the CLEC

Handbook, Interconnection, § 11.0. Deere Attachment G.

Accessible Letter CLECC 99-110 dated April 1, 1999,

notified CLECs of the availability of these four reports.

Deere Attachment H. Pacific attached samples of these

reports to the accessible letter, as well as explanations

of the reports. From issuance of the Final Decision to May

31, 1999, Pacific, upon CLEC request, has provided the TIKI

report to 13 CLECs, the common transport report to one

CLEC, and the point-to-point report to 11 CLECs. For the

same time period, Pacific did not receive any requests for

the exchange of DIXC data.

43. The Final Decision requires Pacific to demonstrate it

enforces provisions in Interconnection Agreements (“ICAs”)

regarding under-utilized trunks as follows: (1) Pacific

will not enforce ICA provisions regarding taking back

under-utilized trunks automatically; it will first consult

with the CLEC and issue the Trunk Group Service Report

(“TGSR”); (2) Pacific will initiate a JCP meeting with the

CLEC to attempt to resolve the trunk underutilization; and

(3) if the CLEC has adequate reason for keeping the

underutilized trunks operational, Pacific shall accommodate

the CLEC. App. B, p. 13, WS Agreement 1.2.1.5. Accessible

Letters CLECC 99-095 and CLECC 99-109, issued March 25,

1999 and March 31, 1999, respectively, notified CLECs of

20

Pacific’s process regarding underutilized trunks.24 Deere

Attachments I and J, respectively. Pacific also updated

the CLEC Handbook, Interconnection, section 14.0 to reflect

the process for underutilized trunks, and revised its

methods and procedures for its Trunk Planning and

Engineering (“TP&E”) group. Deere Attachment YY. This

process complies with the Commission’s requirements. Since

the issuance of the Final Decision, Pacific has sent TGSRs

to 15 CLECs.

44. The Final Decision requires Pacific to alert CLECs via

TGSRs if interconnection trunks are either under or over-

utilized. Written responses, except in blocking

situations, must be sent by the CLEC within 10 to 20 days.

In a blockage situation, Pacific must attempt to call the

CLEC prior to issuing the TGSR. The Local Operations

Center (“LOC”) shall accept trouble tickets regarding the

trunk blockage. Pacific also must report the resolution of

the blockage situation back to the CLEC. App. B, pp. 12-

13, WS Agreement 1.2.1.8. On April 8, 1999, Pacific

distributed Accessible Letter CLECC 99-125, which described

the TGSR process used when local interconnection trunks are

either over or under-utilized. Deere Attachment K.

Pacific also updated the CLEC Handbook, Interconnection,

section 14.0 to include a description of this process. In

24 Pacific issued Accessible Letter CLECC 99-109 to correct a minor error inAccessible Letter CLECC 99-095 (corrected “10 days” to “20 days” forscheduling the joint planning meeting).

21

addition, this process is set forth in Pacific’s methods

and procedures for its TP&E group, its facilities LSC, and

its LOC trunking maintenance group. Prior to issuing a

TSGR in a blocking situation, the TP&E group attempts to

contact the CLEC. Additionally, Pacific accepts trouble

tickets at the LOC regarding blocking and the LOC notifies

the CLEC of the results of its inquiry into the trouble

ticket.25

Central Office Code Issues

45. As a result of the 271 Workshops and the Final Decision,

effective April 4, 1999, Pacific provides positive

notification of NXX code openings via a posting to the on-

line CLEC Handbook, NXX Code Openings section. App. B, p.

15, WS Agreement 1.1.1.1. The NXX codes are posted to this

website within 24 hours of opening. This information

contains, by CLEC, the central office code and the date and

time the code was opened. This has been communicated to

the industry via Accessible Letter CLECC 99-049 dated

February 17, 1999. Deere Attachment L.

46. As required by the Final Decision and agreed to in the 271

Workshops, Pacific is deploying an automated code opening

system used in situations where there is pre-existing

routing information that can be used as a template. App.

B, p. 15. Phase I of the conversion was completed on July

9, 1999, and included OSS setup, testing of the vendor

25 See Tenerelli Affidavit for description of the LOC.

22

software, training for the technicians and upgrades to

approximately 50 switches. The final version of the

software will be deployed statewide in Phases II and III.

Phase II includes upgrades to an additional 170 switches

and is scheduled to be completed on or about August 13,

1999. The third and final phase is to be completed by the

end of the third quarter 1999 and will convert the

remaining 169 switches.

II. CHECKLIST ITEM (ii)NONDISCRIMINATORY ACCESS TO NETWORK ELEMENTS

General Unbundling Rules

47. A BOC, such as Pacific, meets the requirements of the

checklist if it offers access and interconnection that

includes nondiscriminatory access to network elements in

accordance with the requirements of sections 251(c)(3) and

252(d)(1).

48. In its Order (¶ 366), the FCC identified a minimum list of

unbundled network elements. These include unbundled access

to local loops, network interface devices, local and tandem

switching capability, interoffice transmission facilities,

signaling and call-related databases, operations support

systems functions, and operator services and directory

assistance facilities.

49. Pacific must provide access to each network element on an

unbundled basis; that is, without requiring the purchase of

any other network element as a condition for the purchase

of another. 47 C.F.R. § 51.307. Pacific is not allowed to

23

impose limitations, restrictions, or requirements on the

request, or the use of UNEs that would impair the ability

of a CLEC to offer a telecommunications service in the

manner it intends. 47 C.F.R. § 51.309. Network elements

and access to those elements must be equal in quality to

that which Pacific provides to itself. 47 C.F.R. § 51.311.

In addition, the terms and conditions pursuant to which

Pacific provides access to UNEs must be offered equally to

all requesting CLECs. 47 C.F.R. § 51.313. Pacific must

also allow requesting CLECs to combine network elements.

47 C.F.R § 51.315; ACI § 2.0.

50. Pacific provides requesting CLECs with nondiscriminatory,

unbundled access to network elements for use in providing

telecommunications services to their customers. Access to

network elements is provided on a nondiscriminatory and

equal-in-quality basis under the same terms and conditions

to all CLECs. A discussion of how CLECs access the UNEs in

order to combine them begins at paragraph 65 of this

affidavit. See Hopfinger Attachment A for number of UNEs

sold.

51. As required by 47 C.F.R. § 51.307, Pacific provides to a

requesting CLEC (for the provision of a telecommunications

service) nondiscriminatory access to network elements on an

unbundled basis at any technically feasible point. These

network features provide the CLEC access to all features,

functions, and capabilities of the network elements in a

manner that allows the CLEC to provide any

24

telecommunications service the network element is capable

of providing. 47 C.F.R. § 51.307(a), (c); AT&T, Att. 6, §

1; GST, Att. § 1; and TW, Art. XXVII, § 27.06.

52. Pacific also provides access to the facilities or

functionality of network elements separately from access to

other network elements and for a separate charge. 47

C.F.R. § 51.307(d); ACI, §2; AT&T, Att. 6; and MCI, Att. 6.

53. Pacific provides CLECs access to UNEs to permit CLECs to

combine network elements with other network elements

obtained from Pacific or with network components provided

by the CLEC itself to provide telecommunications services

to its customers, provided that such combination is

technically feasible and does not impair the ability of

other carriers to obtain access to other UNEs or to

interconnect with Pacific’s network. 47 C.F.R. §

51.309(a); ACI, § 2.0; AT&T, Att. 6, § 1.2; and MCI, Att.

6, § 1.2.

54. Pacific permits a CLEC to purchase UNEs in order to provide

service to its local end-user customers. AT&T, Att. 6, §

1.4.

55. Requesting CLECs receive exclusive use of an unbundled

network facility, and the use of features, functions, or

capabilities for a set period of time. 47 C.F.R. §

51.309(c). However, Pacific retains ownership of the

facility and retains the obligation to maintain, repair, or

replace UNEs as necessary. AT&T, Att. 12, § 1; MCI, Att.

12, § 1. Each UNE provided by Pacific to a CLEC meets the

25

standards set forth in the relevant interconnection

agreement, and is at least equal in quality and performance

as that which Pacific provides to itself. 47 C.F.R. §

51.311(a),(b); AT&T, Att. 6, § 11.2; GST, Att. 6, § 1.2;

and MCI, Att. 6, § 11.2.

56. The terms and conditions pursuant to which Pacific provides

access to UNEs are offered equally to all requesting CLECs.

47 C.F.R. § 51.313(a). The interconnection agreements

contain the terms and conditions available to any and all

CLECs through the “most favored nation” clause which allows

any CLEC to adopt the terms, conditions, and prices of

another CLEC’s agreement. AT&T, § 5.

57. Pacific provides UNEs in such a way that the CLEC may

combine network elements with other network elements

obtained from Pacific, or with network components provided

by itself. 47 C.F.R. § 51.315(a); AT&T, Att. 6, § 1.2;

GST, Att. 6, § 1.2; and MCI, Att. 6, § 1.2.

Unbundled Network Elements

58. As required by the Act and the non-vacated requirements of

the FCC’s Order, Pacific makes available nondiscriminatory

access to the following core unbundled network elements

(“UNEs”):

• Local Loop

• Network Interface Device

• Local Switching Capability

• Tandem Switching Capability

• Interoffice Transmission Facilities

26

• Signaling Networks and Call-Related Databases

• Operations Support Systems Functions

• Operator Services and Directory Assistance

47 C.F.R. § 51.319 (a)-(g); ACI, Sec. 2; AT&T, Att. 6; MCI,

Att. 6; Brooks, § II, A-H; and GST, Att. 6.

59. Most of the minimum set of network elements are separately

required by the checklist and are therefore discussed in

later sections of my affidavit. However, the Network

Interface Device (“NID”) will be discussed in this section.

The Operations Support Systems (“OSS”) functions are

discussed in the Viveros Affidavit.

60. The NID is a cross-connect device used to connect loop

facilities to a customer’s inside wiring. The NID contains

connection points to which the service provider and the

end-user customer each make their connections. Pacific

provides an electronic on-line CLEC Handbook accessible by

all carriers using passwords obtained from their account

managers. The CLEC Handbook, Interconnection, section 3.0

provides detailed information on the ability of a CLEC to

order and use a Pacific NID. Deere Attachment ZZ.

61. Where a CLEC provides its own loop facilities, the CLEC

provides its own NID and interfaces to the customer’s

premises wiring through connections in the customer chamber

of the Pacific NID. 47 C.F.R. § 51.319(2); AT&T, Att. 6, §

2.2.1; GST, Att. 6, § 2; and MCI, Att. 6, § 2.2.1.

62. CLECs may connect to the customer’s inside wire at the

Pacific NID, as is, at no charge. Any repairs, upgrades,

27

disconnects, or rearrangements required by the CLEC will be

performed by Pacific based on special construction charges.

AT&T, Att. 6, § 2.3.10 & Att. 8; GST, Att. 6, § 2.3.1.0 &

Att. 8; and MCI, Att. 6, § 2.3.10 & Att. 8.

63. If a CLEC obtains a local loop as a UNE from Pacific,

Pacific provides the NID. Pacific connects the drop wire

between the distribution plant facilities and the NID at no

additional charge to the CLEC. AT&T, Att. 6, § 2.3.1; MCI,

Att. 6, § 2.3.1.

64. At multiple dwelling units or multiple-unit business

premises, it is normally expected that the CLEC will

provide its own NID and will connect directly with the

customer’s inside wire without any requirement to connect

to the Pacific NID. In those situations where it is

necessary to relocate or rearrange the Pacific NID to allow

access to the customer’s inside wiring, such rearrangements

or relocations will be charged to the CLEC as a special

construction charge. AT&T, Att. 6, § 2.3.10 & Att. 8; MCI,

Att. 6, § 2.3.10 & Att. 8.

CLEC Access To Combine Unbundled Network Elements

65. Pacific offers five methods and conditions under which it

agrees to provide CLECs with access to Pacific UNEs for the

provision of services to CLEC end users.26 These methods

are intended to provide CLECs with access to the UNEs

without compromising the security, integrity, and

26 See Hopfinger Affidavit regarding UNE combinations.

28

reliability of the central office and the public switched

telephone network, as well as minimize the potential

service disruption to end users converting from service

provided by Pacific to service provided by a CLEC through

the use of UNEs.

66. CLECs may use the methods listed below to access and

combine identified UNEs within Pacific central offices or

tandem offices. The options listed below apply to local

loops, local switching, and dedicated transport. These

methods are provided in addition to the ability of a CLEC

to make cross connection in collocation space using cables

provided in conjunction with that space.

67. Method 1: If a CLEC is physically collocated in a Pacific

central office or tandem office, Pacific extends UNEs that

require cross connection to a Point of Termination (“POT”)

frame located inside the CLEC’s physical collocation space.

Using this method, the CLEC has secure access to its

circuits, and it is protected from access by others. This

option also allows cross connection to equipment provided

by the CLEC in the collocation space.

68. Method 2: If a CLEC is physically collocated in a Pacific

central office or tandem office, Pacific extends UNEs that

require cross connection to a CLEC UNE access point (common

frame) located in a collocation common area. This method

provides a CLEC an option of connecting UNEs that do not

require connection to CLEC equipment in the collocation

29

space. All physically-collocated CLECs choosing Method 2

in an office have access to the same access point.

69. Method 3: Pacific extends UNEs that require cross

connection to a CLEC UNE frame located in a common area

room space, other than collocation common area, within the

central office or tandem office building. The CLEC point

of access is located in a secure area of the building other

than the collocation space. This allows CLECs to share a

common frame for the connection of Pacific UNEs. The CLEC

does not have access to its own equipment from this point.

70. Method 4: Pacific extends UNEs to an external point of

presence, such as a cabinet located outside the central

office or tandem office building, provided by Pacific on

Pacific property. This arrangement operates like Method 3,

except the point of access will be outside of Pacific’s

building.

71. Method 5: Pacific allows extension of UNEs to a building

not controlled by Pacific via cabling provided by CLEC.

The CLEC provides the cable necessary to reach from a

manhole outside the central office building to the Pacific

distribution frame in the Pacific central office where the

CLEC requests connection. This method may be used to

combine not only Pacific-provided UNEs, but also a Pacific

-provided UNE and CLEC equipment or facilities.

72. The terms and conditions for CLECs choosing to access

Pacific UNEs through physical collocation arrangements are

set forth in ICAs. AT&T, Att. 10, § 3; MCI Att. 10, § 2.

30

73. Methods 1 and 2, listed above, are only available to

physically-collocated CLECs.

74. Methods 3 though 5 are available to both physically

collocated and non-collocated CLECs and are subject to the

availability of space and equipment as determined by

Pacific. Appendix UNE 2.9.2.3.

Cross-Connections

75. Cross-connections are the facility by which Pacific extends

its network to the point of access selected by a CLEC, as

described above. The cross-connect is the media between

the Pacific distribution frame and a CLEC-designated point

of access. MCI, Att. 6, § 1.5; AT&T, Att.6, § 1.5.

76. Cross-connections are wires, fibers, or equipment that

connect one piece of equipment to another on a semi-

permanent basis. For instance, some cross-connections are

made by a simple pair of copper wires called a jumper.

Pacific documentation refers to this as Expanded

Interconnection Service Cross Connect (“EISCC”). See

Collocation Handbook, section 1.9.1, Deere Attachment M.

The FCC’s Order required ILECs to provide such facilities

and stated that the ILEC could recover the costs associated

with providing cross-connections.

77. Different loop options require different types of cross-

connections. In fact, several cross-connections may be

required for many of the options. Pacific provides the

following types of loop cross-connects:

31

• 2-Wire Analog loop to point of access

• 4-Wire Digital loop to point of access

• DS3 to point of access

AT&T, Att. 6, § 3.3.1, Att. 8, App. A; MCI, Att. 6, §3.2.

78. These cross connections are the same type of connections

used by Pacific to connect local loops to equipment located

in a central office building. They are placed using the

same jumper wires, cables, and other materials used by

Pacific for its customers. The same methods and procedures

are used by technicians to place the cross-connections as

are used when cross-connecting loops used by Pacific

customers to equipment in the central office. Pacific

technicians have demonstrated the ability to place

thousands of cross connections every day in the

provisioning of telecommunications services.

79. The same types of cross-connections provided to connect

loops to the collocation cage are used to extend switch

ports to the point of access. This allows a CLEC to

connect the UNEs.

80. Cross-connections must be used with unbundled dedicated

transport (“UDT”). The following cross-connects are

provided with UDT:

• Voice Grade 2-Wire

• Voice Grade 4-Wire

• DS0-DCS to point of access

• DS1

• DS3

32

• OC3

• OC12

• OC48

AT&T, Att. 10, §3.2.9.

III. CHECKLIST ITEM (iv) LOCAL LOOP

81. The local loop network element is defined as a transmission

facility between a distribution frame (or its equivalent)

in an ILEC central office and an end-user customer’s

premises. The loop terminates in the NID at the customer’s

premises. 47 C.F.R. § 51.319(a). The terms “loops” and

“links” are synonymous in Pacific’s interconnection

agreements. The CLEC Handbook, UNE, section 1.0 provides

detailed information on the ordering of links and the terms

and conditions applicable to their use. Deere Attachment

AAA.

82. Pursuant to 47 U.S.C. section 271(c)(2)(b)(iv) Pacific

provides the following standard local loops as network

elements unbundled from local switching or other services:

• 2-Wire analog loop supporting analog voice frequency,with no more than 8 dB loss

• 4-Wire analog loop

• 2-Wire digital loop (160 Kilobits per second) to supportBasic Rate Integrated Services Digital Network (“ISDN”)based services

• 4-Wire digital loop (1.544 Megabits per second) tosupport DS1 services.

83. Pacific also provides a standard conditioning option on the

2-wire analog loop to reduce loss to no more than 5.5 dB.

33

In addition, Pacific offers options for PBX ground start

signaling and coin signaling on the 2-wire analog loops.

AT&T, Att. 6, § 3.2; GST, Att. 6, 3.2; and MCI Att. 6, §

3.2.

84. As agreed to in the 271 Workshops, Pacific has reviewed the

ability of CLECs to access copper loops at remote terminal

locations. WS Agreement 2.1.1. Based upon its review,

Pacific advised the CLECs and the CPUC Staff that it does

not provide access to copper loops at the remote terminal

of a pair-gain system because Pacific views this as sub-

loop unbundling. Sub-loop unbundling has not been ordered

by the CPUC. In fact, the CPUC specifically denied AT&T’s

request for sub-loop unbundling in its arbitrated ICA.27

While the FCC has not ordered sub-loop unbundling, it is

currently reviewing this issue on remand in CC Docket No.

96-98.28 Pacific will comply with the FCC’s final order in

that docket.

85. Digital Subscriber Line (“DSL”) based services are

dedicated, point-to-point public network access

technologies that allow multiple forms of data, voice, and

video to be carried over twisted-pair copper wire on the

local loop. DSL-based services are normally provided

between a network service provider’s central office and the

end user's site. The collection of these services is often

27 AT&T Application 96-08-040, Arbitrator’s Report, p. 25 (Oct. 31, 1996).28 Implementation of the Local Competition Provisions of the

Telecommunications Act of 1996.

34

referred to as xDSL services. The "x" is replaced with a

specific letter to define a particular technology. For

instance, HDSL represents High-bit-rate Digital Subscriber

Line, ADSL denotes Asymmetric Digital Subscriber Line, SDSL

represents Symmetric Digital Subscriber Line, and VDSL

represents Very High Bit-rate Digital Subscriber Line.29

86. To the extent technically feasible, CLECs may request

access to additional loop types not provided for in

interconnection agreements pursuant to the BFR process.

AT&T, Att. 6, § 1.6; ACI § 2.8; MCI Att. 6, § 1.6.1.

87. Pacific complies with the FCC’s Advanced Services Order

regarding spectrum compatibility and management to enable

the reasonable and safe deployment of advanced services

prior to the development of industry standards. Pacific’s

unbundled DSL loop offerings allow CLECs to use their

desired DSL technologies and equipment to provision DSL

services to their end-user customers. As discussed in the

Murray Affidavit, Pacific does not reject a CLEC’s xDSL

order based on the type of xDSL technology.

88. If a CLEC desires to use a new technology and the new

technology requires the use of a 2-wire or 4-wire loop

materially the same as one of the loops described above,

with materially the same loop conditioning, then Pacific

will provide the CLEC a loop capable of supporting the new

technology at the same rates listed for the appropriate 2-

29 The Murray Affidavit provides a description of the ordering requirementsfor specific xDSL loops.

35

wire and 4-wire loops and associated loop conditioning as

needed.

89. If the new technology requires a loop type that differs

materially from the existing 2-wire and/or 4-wire loops

defined above (e.g. different loop design, different

conditioning), Pacific will negotiate with the CLEC as to

the rates, terms, and conditions for an unbundled loop

capable of supporting the materially-different technology.

If negotiations fail, the dispute shall be resolved

pursuant to the dispute resolution process provided for in

the interconnection agreement or through arbitration

pursuant to section 252 of the Act.

90. Pacific has complied with the Final Decision requirement to

adopt ANSI standards for the provision of xDSL-based

services. App. B, p. 19. Currently, ANSI has adopted only

one xDSL-related standard, T1.413 (“Network and Customer

Installation Interfaces – ADSL Metallic Interface,” Issue

2, 1998), which addresses ADSL. Pacific created Technical

Publication TP76730, consistent with the ANSI standard, and

has deployed ADSL accordingly. Deere Attachment N.

Section 4 of this technical publication mirrors the power

spectral density definition found in standard T1.413-1998,

section 7.14 (for upstream transmission) and Annex F (for

downstream transmission), which demonstrates Pacific’s

standards are compliant with the ANSI standards.

91. The industry working group T1E1.4 is actively developing a

standard for spectrum management in the loop environment.

36

The focus of this effort is to minimize the potential

interference xDSL loop platforms can have on each other

under expected operating conditions. Because this standard

is not yet complete, and because Pacific and the CLECs are

both deploying a variety of xDSL loop technologies, Pacific

has sought a competitively neutral approach to minimizing

spectral interference so that all carriers’ xDSL-based

services operate in the most trouble-free environment

possible. To accomplish this objective, Pacific

implemented spectrum management guidelines designed to

minimize the risk of service degradation or failure, prior

to ANSI’s finalization of a national standard.

Furthermore, Pacific continues to monitor the status and

direction of the emerging ANSI standard so that Pacific’s

interim guidelines represent the best possible match to the

emerging standard. When this standard is finalized by

ANSI, Pacific will incorporate it into spectrum management

guidelines. Pacific has already incorporated the TR.28

recommendations for HDSL in its technical publications.

92. Pacific has complied with the Final Decision requirement to

keep the CLECs alerted of changes in the standards for xDSL

documented in Pacific’s technical publications. App. B, p.

19. Accessible Letter CLECC 99-067, dated March 10, 1999,

advised the CLECs of Pacific’s January 1999 update to TP

76730, which covers ADSL. Deere Attachment O. In

addition, this letter advised CLECs of the availability of

TP 76740 and 76750, which cover the mid-band and very-low-

37

band symmetrical technologies, respectively, as well as the

January 1999 update to Technical Publication L-780063,

which covers UNEs. As previously stated, when ANSI adopts

standards relating to these technologies, Pacific will

conform its technical publications to those standards.

93. Pacific has complied with the Final Decision requirement to

define xDSL-compatible loops in cooperation with the CLECs,

or according to industry standards. App. B, p. 3. In an

effort to define xDSL-compatible loops cooperatively with

the CLECs, Pacific has held several CLEC meetings to

discuss binder group management and Pacific’s use of

dedicated binder groups for ADSL. Deere Attachment P dated

August 28, 1998 is a sample of the letter sent to CLECs

announcing the September 22, 1998 meeting in San Francisco

to discuss spectrum management and other xDSL issues.

Deere Attachment Q is Accessible Letter CLECC 98-110, dated

October 19, 1998, which announced the second such meeting

on October 27, 1998 in San Francisco. Deere Attachment R

is Pacific’s letter dated November 4, 1998, announcing the

third such meeting on November 17, 1998 in San Francisco.

Last, Deere Attachment S is Accessible Letter CLECC 99-072,

dated March 12, 1998, which announced another meeting on

May 4, 1999 in San Francisco. These meetings demonstrate

Pacific’s efforts to meet the CLECs’ xDSL needs. Also, as

previously described in my affidavit, Pacific is actively

participating in and following the progress of ANSI’s

standards-setting effort for xDSL in order to manage loop

38

spectrum in accordance with current and future industry

standards. Collectively, these efforts have resulted in

the definition of xDSL-compatible loops in Pacific’s L-

76860, “Unbundled Network Elements,” Issue 4, June 1999,

section 3.0. Deere Attachment T. Having such a definition

of xDSL-compatible loops assures CLECs the ability to order

loops for their xDSL-based services.

94. Appendix B (p. 19) of the Final Decision requires Pacific

to demonstrate that its spectral management program used to

manage the deployment of xDSL services is competitively

neutral. Pacific is also required to provide test data as

well as supporting data and assumptions used to develop its

binder group management process, and to demonstrate that

its spectral management program allows the widest possible

deployment of xDSL services. Pacific has been and

continues to be actively involved in addressing the

spectral management issues associated with Pacific’s

selective feeder separation (“SFS”)30 at the national and

local levels. As previously described, Pacific has met

with CLECs and industry technical groups to define spectrum

problems, share technical data, test different

technologies, and consider deployment alternatives. As a

result of these discussions, and as a clear demonstration

of the competitive neutrality of its spectral management

30 SFS was previously referred to as binder group management. A name changewas necessary to avoid confusion with other spectrum management issues atthe ANSI national level.

39

program, Pacific does not deny any CLEC xDSL service

request based on the technology chosen by the CLEC. In

addition, Pacific’s SFS program incorporates a neutral

approach to spectrum management in that it takes advantage

of the technical differences between ADSL and other DSL

technologies to increase the overall spectral capacity of a

feeder cable for all technologies. While ADSL is a major

disturber of other DSL technologies,31 it creates little

interference with itself. Thus, SFS aggregates all ADSL

services into a single binder group containing no other DSL

services. Through this segregation, SFS minimizes the

impact of ADSL on the other DSL services in the feeder

cable, while maintaining an acceptable environment for the

ADSL services.

95. Pacific has incorporated CLECs’ input in developing SFS.

Pacific obtained CLEC input in the forums described in

paragraph 93. While Pacific did not accept all CLEC

suggestions, Pacific made changes, where appropriate, to

address CLEC concerns. For example, no other binder group

in a feeder cable is affected by the implementation of SFS,

other than for a reduction in total noise. In particular,

binder groups adjacent to the binder group designated for

ADSL services are not restricted, except with respect to

31 Deere Attachment U contains the “Effects of Digital Disturbers on ADSLProvisioning Distances” and “Interference Table – HDSL Reach in kft. ofEquivalent 26-gauge Cable.” These demonstrate the interference effects ofdifferent digital technologies on each other, and the importance ofspectrum management.

40

repeatered T1s. Because of another CLEC’s spectrum

proposal, Pacific now segregates all xDSL assignments from

binder group containing repeatered T1.

96. Digital Loop Carrier (“DLC”) is a technology that uses a

remote terminal located outside of the central office to

convert a number of analog customer lines to a digital

transmission and transport them on fewer physical

facilities. Integrated Digital Loop Carrier (”IDLC”) is a

special version of DLC that does not require the host

terminal in the central office, but instead the physical

connection from the loop plant terminates directly into the

central office switch. Universal DLC (“UDLC”) uses a

demultiplexer to separate the unbundled loop(s) prior to

connecting the remaining loops to the switch.32 By the

definition and design of the IDLC technology, there is no

way to separate the loop from the switch because the switch

performs the functions normally performed by the central

office host terminal. As of May 31, 1999, approximately

seven percent of Pacific’s assigned loops in California are

served on DLC and less than one percent of the loops are

served on IDLC.

97. If a customer is currently served by Pacific using IDLC,

and a CLEC converts that customer to its local service,

Pacific unbundles the loop from the switch, where possible.

In other words, if there is a non-integrated DLC operating

32 See Deere Attachment V for diagrams of IDLC and UDLC in the network.

41

in parallel with the IDLC, Pacific moves the customer’s

service to the DLC facility and cross-connects it to a

point of access. As required by the Final Decision,

Pacific does not require a BFR from the CLEC where copper

pairs or non-integrated DLC is available. Final Decision,

p. 162; App. B, p. 18.

98. If no parallel non-integrated facilities currently exist

for providing the requested loop unbundling, it will be

necessary for Pacific to design, engineer, and install the

necessary alternate facility. The CLEC is responsible for

the costs of these additional alternate facilities. Pacific

expects there to be few cases where an existing alternative

facility is not available; however, in such cases the BFR

process provides a way for the CLEC to request the

construction of the new facilities and to determine the

costs and the time required. This allows the CLEC to

decide if it wishes to incur the resultant costs.

99. Pacific has complied with the Final Decision to provide a

report of Pacific’s deployment of IDLC loops. App. B, p.

18. Deere Attachment W is the letter dated April 27, 1999,

transmitting the requested information as of the end of the

first quarter 1999.

100. The Final Decision (App. B, p. 18) requires Pacific to

demonstrate that the quality of the service provided to

CLEC customers served by UDLC is equivalent to the quality

of service provided to Pacific customers served by IDLC. A

traditional measurement of service quality is the trouble

42

reports rates per 100 lines in service. Therefore, Pacific

has analyzed trouble reports for CLEC customers on UDLC

versus Pacific customers on IDLC for the period February

1999 through May 1999. Using a standard statistical test,33

Pacific’s analysis shows that the CLEC UDLC service quality

was statistically in parity with the Pacific IDLC service

quality in three of these four months. Service quality did

not appear to be in parity in April 1999. However, of the

12 total reports for the CLEC UDLC in April 1999, only two

of these reports actually involved the UDLC technology.

The remaining ten trouble reports were coded to a problem

in the aerial pair or the central office switch, neither of

which can be attributed to the UDLC technology because

these pieces of the network are common to both

technologies. When the ten “non-UDLC technology” trouble

reports are removed from the April data, the CLEC UDLC

report rate is statistically in parity with the Pacific

IDLC report rate for that month.

Trouble Report Rate per 100 Lines

February1999

March 1999 April 199934 May 1999

CLEC UDLC 0.23 0.19 1.99 1.30

Pacific IDLC 0.96 0.43 0.35 0.92

33 Pacific used the “modified Z test” with parity determined by a differencein report rates of 1.645 standard deviations or less.

34 These data are not adjusted for the trouble reports that were unrelated toUDLC.

43

StandardDeviation ofDifference inReport Rates

1.58 0.82 6.57 0.98

Statistically inParity?35 Yes Yes No Yes

IV. CHECKLIST ITEM (v) LOCAL TRANSPORT

101. Local transport includes shared/common transport and

dedicated transport. Shared transport is defined as the

interoffice transport between two Pacific end offices and

between a Pacific end office and a Pacific tandem. Common

transport is a subset of shared transport and refers to

interoffice transport between a Pacific end office and a

Pacific tandem.36 Some of the interconnection agreements

signed by Pacific distinguish between common transport and

shared transport. In these contracts, common transport is

available through interconnection at a Pacific tandem and

shared transport is available only where a CLEC purchases

unbundled network switching in a central office. AT&T,

Att. 6, § 5; ACI App. F; GST, Att. 6 & § 5; and MCI Att. 6,

§ 5. In this affidavit, the term shared/common transport

is used to discuss both of these options.

102. Pacific is responsible for the engineering, provisioning,

and maintenance of the underlying equipment and facilities

used to provide shared/common transport. CLEC Handbook,

UNE, section 3.0 contains descriptions of unbundled

transport. Deere Attachment BBB.

35 See footnote 33 regarding the “modified Z test.”36 See Deere Attachment X for a diagram.

44

103. With shared/common transport, a call can be switched using

the unbundled local switching element to other Pacific end

offices and tandem switches over Pacific’s shared/common

transport network. The use of shared/common transport does

not require a CLEC to purchase trunk ports on the Pacific

switch, nor does it require the CLEC to specify routing

tables. Shared/common transport is provided in accordance

with the Third Reconsideration Order and revised 47 C.F.R.

§ 51.319(d)(12)(ii). AT&T, Att. 6, § 5.1.3 & 5.1.4; ACI

App. F, § 2.1.3 & 2.1.4; GST, Att. 6, § 5.1.3 & 5.1.4; and

MCI Att. 6, § 5.1.3 & 5.1.4.

104. Dedicated transport is an interoffice transmission path

dedicated to a particular customer or CLEC that provides

telecommunications between wire centers or switches owned

by Pacific or CLECs. 47 C.F.R. § 51.319(d)(1)(i).

Dedicated transport is available from any Pacific end

office or tandem office to any other Pacific office or CLEC

location within the area served by Pacific. AT&T, Att. 6,

5.1.2; ACI App. F § 2.1.2 & § 2.3.1; GST, Att. 6, § 5.1.2;

and MCI, Att. 6, § 5.1.2.

105. Pacific offers cross-boundary (i.e., between a Pacific

exchange and another, contiguous local exchange carrier’s

exchange) dedicated transport to a CLEC under the

conditions contained in the CLEC Handbook, UNE, section

3.0. As agreed to in the 271 Workshops, Pacific has

updated that section of the handbook. This update allows a

three-party meeting between Pacific, the other local

45

exchange carrier, and the CLEC to be optional if the CLEC

provides written confirmation that the other local exchange

carrier is prepared to provision the cross-boundary

dedicated transport and will work with Pacific without the

CLEC present. WS Agreement § 3.1.1. The CLEC must provide

its contact name and number to the other local exchange

carrier.

106. In addition, Pacific issued Accessible Letters CLECC 98-116

and CLECC 99-112, dated October 30, 1998 and April 1, 1999,

respectively, addressing cross-boundary dedicated

transport. Deere Attachments Y and Z, respectively. As

agreed to in the 271 Workshops, Pacific provided all

workshop participants a summary of its cross-boundary

dedicated transport methods and procedures and gave the

CPUC Staff the methods and procedures for this UNE.

107. Pacific has complied with the Final Decision requirement

that Pacific show CLECs are able to order cross-boundary

dedicated transport. App. B, p. 20. This is demonstrated

by the fact that Pacific is currently providing cross-

boundary unbundled transport to three CLECs.37

108. The Final Decision requires Pacific to identify the

specific circumstances in which a CLEC is required to

negotiate an amendment to its interconnection agreement to

order cross-boundary unbundled dedicated transport. App.

B, p. 20. Any CLEC that wants to purchase cross-boundary

37 THIRD PARTY PROPRIETARY INFORMATION

46

unbundled dedicated transport must have a provision for

this type of unbundled transport in its interconnection

agreement. Accessible Letters CLECC 98-116 and CLECC 99-

112 explained that an amendment including the terms and

conditions for cross-boundary unbundled dedicated transport

is required in order for a CLEC to obtain this UNE. Deere

Attachments Y and Z, respectively. CLECC 99-112 provided

Pacific’s proposed generic language for including cross-

boundary unbundled transport in a CLEC’s interconnection

agreement.

109. Pacific offers dedicated transport as a transmission path

dedicated to a CLEC. The following transmission speeds are

available:38

• DS0 (64 Kb/s)

• DS1 (1.544 Mb/s)

• DS3 (45 Mb/s)

• OC3 (155.520 Mb/s)

• OC12 (622.080 Mb/s)

• OC48 (2488.320 Mb/s) (on an ICB basis)

AT&T, Att. 6, 5.3.4; ACI App. F, 2.3.4; GST, Att. 6; and

MCI Att. 6, 5.3.4.

110. A Digital Cross-Connect System (“DCS”) is an electronic

device that provides the capability to rearrange circuits

on high-speed facilities without the need to de-multiplex

the signals. Without a DCS, signals cannot be exchanged

38 See Hopfinger Affidavit for a discussion of optical level unbundledtransport.

47

between high-speed circuits without returning all of the

circuits to analog electrical signals. Pacific offers DCS

in conjunction with the unbundled dedicated transport, with

the same functionality offered to interexchange carriers.

47 C.F.R 5.319 (d)(2)(iv); AT&T, Att. 6, § 5.1.2; GST, Att.

6, § 5.1.2; and MCI, Att. 6, 5.1.2. Pacific provides the

cross-connects necessary to extend dedicated transport

facilities to points of access designated by the CLEC. 47

C.F.R. § 51.319(d)(2)(iii).

111. To the extent required,39 Pacific’s unbundled transport

allows access to both shared and dedicated transport,

including existing transmission facilities, features,

functions, and capabilities that a CLEC can use in the

transmission, routing, or other provisioning of a

telecommunications service. 47 U.S.C. §§ 3, 29. In

addition to the standard arrangements, the CLEC may request

new or additional elements using the BFR process. AT&T,

Att. 6, § 1.6; ACI § 2.8; and MCI Att. 6, § 1.6.1.

V. CHECKLIST ITEM (vi) LOCAL SWITCHING

112. Section 271(c)(2)(B)(vi) and 47 C.F.R. § 51.319(c) require

Pacific to unbundle local switching from transport, local

loop transmission, or other services. The FCC Rules also

require unbundling of local and tandem switching

capabilities, including trunk-connect facilities,

39 The U.S. Supreme Court has remanded the issue of shared transport to theEighth Circuit Court of Appeals. Ameritech Corp. v. FCC, 1999 WL 116994(U.S.) (June 1, 1999).

48

including, but not limited to, the connection between trunk

termination at a cross-connect panel and a switch trunk

card, the basic switching function of connecting trunks,

and the functions centralized in tandem switches. 47

C.F.R. § 51.319(c)(2). Pacific satisfies these

requirements. AT&T, Att. 8, App. A; ACI App. F; Brooks, II

C; GST, Att. 6, § 4; and MCI Att. 6, § 4.

113. Pacific provides a local switching element that encompasses

line-side and trunk-side facilities plus the features,

functions, and capabilities of the switch. The line-side

facilities include the connection between a loop

termination at, for example, an MDF, and a switch line

card. 47 C.F.R. § 51.319(c)(1)(i)(A); AT&T, Att. 6, § 4;

Brooks, II C; and GST, Att. 6, § 4. The CLEC Handbook,

UNE, section 2.0 contains information concerning the

unbundled switching element. Deere Attachment AA.

114. The trunk-side facilities include the connection between,

for example, trunk termination at a trunk-side cross-

connect panel and a trunk card. 47 C.F.R. §

51.319(c)(1)(i)(B); AT&T, Att. 6, § 4.13; Brooks, II C.

115. The local switching element includes access to all

features, functions, and capabilities of the local switch,

including, but not limited to, the basic switching and

routing functions of connecting lines to lines, lines to

trunks, trunks to lines and trunks to trunks. The local

switching element includes the same capabilities available

to Pacific customers, such as a telephone number, dial

49

tone, signaling and access to 911, access to operator

services and directory assistance, and access to features

required by state law. In addition, the local switching

element includes access to all vertical features the switch

is capable of providing, including custom calling, CLASS

features, and Centrex-like features, as well as any

technically feasible routing features. 47 C.F.R. §

51.319(c)(1)(i)(C); AT&T, Att. 6, §4.1; Brooks, II B; GST,

Att. 6, § 4.1; and MCI Att. §6, 4.1.

116. When a CLEC requests unbundled shared/common transport,

Pacific’s local switching element routes calls on Pacific’s

existing shared/common transport network to the appropriate

trunks or lines for call origination or termination. The

CLEC is not required to purchase a trunk port for access to

the shared/common transport element. All routing to the

shared/common transport is done using the existing Pacific

switch routing table. AT&T, Att. 6, §4.1; MCI Att. 6,

§4.1.

Types of Unbundled Local Switching

117. The Final Decision requires Pacific to demonstrate that

unbundled switching is available to CLECs as a legal and

practical matter. App. B, p. 21. Under existing

interconnection agreements, Pacific offers three routing

configurations for unbundled switching, designated as

Options A, B, and C. In addition, Pacific offers Resale

Operator Alternate Routing (“ROAR”). Option A provides

CLECs with local switching and interoffice transport using

50

Pacific’s existing shared/common transport network. AT&T,

Att. 6, § 4.1.3; MCI, Att. 6, § 4.1.3; and GST, Att. 6.

Option B, Option C, and ROAR each require a specific custom

routing configuration to be established for each CLEC

served in each individual central office switch. Each

Option A, Option B, Option C, and ROAR routing

configuration is referred to as a Virtual Telephone

Exchange (“VTE”). A VTE uses Line Class Code (“LCC”)

technology and class of service screening to perform the

routing requested by the CLEC. The number of VTEs

available in any individual switch is limited by the switch

manufacturer’s LCC technology design. The CLEC Handbook,

UNE, Section 2.6.2 contains the ordering information for

Options A, B, C and ROAR. This section describes how a

CLEC establishes a VTE, or footprint, in a central office

switch. As of May 31, 1999, CLECs have submitted Access

Service Requests (“ASRs”) for Option A in 138 switches.40

Pacific has also provisioned line-side requests from three

CLECs for a total of 49 Option A switch ports.41 These

ports, which include shared transport, are combined with

loops. As of May 31, 1999, no CLEC has ordered Option B or

C. In February 1998, Pacific provisioned six ROAR VTEs in

six different switches for one CLEC.42

40 THIRD PARTY PROPRIETARY INFORMATION41 THIRD PARTY PROPRIETARY INFORMATION42 THIRD PARTY PROPRIETARY INFORMATION

51

118. The Final Decision requires 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. Pacific

has developed internal methods and procedures for ordering

each of the unbundled switching options on a stand-alone

basis and for ordering unbundled switching in conjunction

with other UNEs. For ordering of switching on a stand-

alone basis and in combination with other UNEs, see Murray

Affidavit.

119. Where capacity and technical capabilities permit, and when

incorporated in an interconnection agreement, a single

unbundled routing configuration (Option A, B, or C) is

provided for all of the CLEC’s subscribers in a single

central office switch. ROAR is provided in addition to

Option A, B, or C in an individual switch.

120. When a CLEC chooses Option A, the CLEC’s customers who are

served by UNEs in a Pacific central office have their calls

switched and routed over the same local shared/common

transport facilities used by the customers of Pacific

served from that same switch. AT&T, Att. 6, §4.1.3.1.

121. An Option A CLEC customer connected to a line port on a

central office switch uses the switching and transport

facilities of Pacific and the other local exchange carriers

and IXCs interconnected with the Pacific network. There is

no customized routing and all interoffice facilities are

shared/common transport facilities. All calls for local

52

operator assistance or directory assistance are routed to

Pacific’s operators. Option A is currently available to

any CLEC with an interconnection agreement that includes

the appropriate provisions for this option.

122. Option B differs from Option A by providing customized

routing of local 0+, 0- and/or directory assistance calls.

This option requires a specific custom routing

configuration to be established in each Pacific central

office switch where it is implemented. AT&T, Att. 6,

§4.1.3.2.

123. The differences between Option A and Option B are the owner

of the local operator assistance/directory assistance

platform and the use of dedicated transport instead of the

shared/common transport to access the operators. Calls,

other than local 0+, 0-, and directory assistance calls,

placed by a CLEC’s customer using Pacific local switching,

are transported over shared or common transport just as in

Option A. All local 0+, 0- and directory assistance calls

dialed by a CLEC customer are routed to a location

designated by the CLEC. The routing of the calls is

controlled by LCC and class of service screening. Each

CLEC customer line is assigned a LCC that contains pointers

to a dedicated trunk group when the dialed digits indicate

a local 0+, 0- or directory assistance call. The directory

assistance calls may be directed to a different trunk group

than the local 0+ and 0- calls.

53

124. Option B requires customized routing instructions

associated with the CLEC’s VTE in the central office switch

and the assignment of dedicated transport facilities to the

CLEC’s operator/directory services platform. The VTE must

be prepared and activated at each requested switch before

Option B is available. Option B can be placed into service

in central office switches, subject to the capacity

limitations associated with the LCC technology and

available transport facilities.

125. ROAR provides the ability for a CLEC to have calls from

customers that it serves through the resale of Pacific

telecommunications services to be custom routed to the

CLEC’s operator assistance and directory assistance service

platforms. As with Option B, a VTE containing a custom

routing configuration specific to the CLEC’s ordering

instructions must be prepared and activated at each

requested switch before ROAR is available. The ROAR VTE

functions in the same manner as an Option B VTE for CLEC

customers served with UNEs, and is subject to the same

capacity limitations as an Option B VTE.

VTEs in Collapsing and Dial-with-Dial Switch Replacements

126. The Final Decision sets forth three requirements with

respect to “collapsing” switches. 43 First, Pacific is

required not to re-institute certain conditions regarding

43 Collapsing refers to Pacific removing a switch from service and moving thelines served by that switch to an existing digital switch. See Final CPUCStaff Report, p. 122 (Oct. 5, 1998).

54

central office switches scheduled to collapse. App. B, p.

21. These conditions originally were contained in

Pacific’s letter to AT&T dated August 15, 1997.44 Deere

Attachment BB. In a letter to AT&T dated February 1, 1999,

Pacific rescinded these conditions. In addition, in

Accessible Letters CLECC 99-048 dated February 16, 1999,

and CLECC 99-062 dated March 4, 1999, Pacific advised all

CLECs of its policy regarding collapses and dial-with-dial

replacements which is described below in paragraphs 127-

129. Deere Attachments CC and DD, respectively.

127. Second, Pacific complied with the requirement to inform

CLECs in a collapse situation of the number of VTEs

available to CLECs in the digital switch. App. B, p. 21.

This policy was included in the May 12, 1999 update to the

CLEC Handbook, UNE, section 2.6.2. Accessible Letter CLECC

99-062 informed CLECs of this policy.

128. Third, Pacific has complied with the Final Decision

requirement to allow CLECs with VTEs in the collapsing

analog switch to reserve VTEs in the digital switch at no

charge. App. B, p. 21-22. If VTEs are in short supply in

the digital switch, a CLEC with an existing VTE in the

analog switch will have the option of immediately

installing its VTE footprint in the digital switch before

that capacity is given to another CLEC. CLECs were advised

44 The Final Decision states that Pacific’s letter of August 21, 1997,contained the conditions; the correct date of Pacific’s letter is August15, 1997. AT&T responded to Pacific’s letter with another letter datedAugust 21, 1997.

55

of this in Accessible Letter CLECC 99-062 dated March 4,

1999. Additionally, Pacific revised its methods and

procedures as well as the CLEC Handbook, UNE, section

2.6.2.

129. The Final Decision contains one requirement regarding dial-

with-dial switch replacement.45 Pacific has demonstrated

compliance with the Final Decision requirement not to

charge CLECs the cost of the VTE footprint in a dial-with-

dial switch replacement. App. B, p. 22. Accessible Letter

CLECC 99-048 advised CLECs that no charge is applied for

re-establishing their VTE in digital switches in dial-with-

dial replacements. Pacific updated its methods and

procedures so that CLECs would not be charged for a

footprint in a dial-with-dial switch replacement. Pacific

also revised the CLEC Handbook, UNE, section 2.6.2 to

comply with this item. When the SNFCCA19CG1 analog switch

was replaced with a new digital switch SNFCCA12DS1 on March

22, 1999, a CLEC’s existing ROAR VTE was moved from the

analog switch to the new digital switch at no cost to the

CLEC.46

Unbundled Switching, Option C

130. As agreed to in the 271 Workshops, Pacific developed a

standard ordering and provisioning process to support a

generic Option C request. WS Agreement 4.2.1.1.

45 Dial-with-dial replacement refers to Pacific removing a switch from serviceand moving the lines served by that switch to a new digital switch. SeeFinal CPUC Staff Report, p. 122.

46 THIRD PARTY PROPRIETARY INFORMATION

56

Accessible Letter CLECC 99-189 dated May 21, 1999 informed

CLECs of Pacific’s generic Option C offering.47 Deere

Attachment EE.

131. The CLEC Handbook, UNE, Section 2.2.3 describes Option C,

which provides for customized routing to the CLEC’s

unbundled dedicated transport facilities based upon class

of call or specific NPA-NXXs as designated by the CLEC.

The calls can be routed to the unbundled dedicated

transport facilities which exist between two Pacific end

office switches, a Pacific end office switch and a Pacific

tandem, or a Pacific end office switch and a CLEC’s switch.

With Option C, a CLEC can also order unbundled dedicated

transport to route local 0- and 0+ 10-digit operator

assisted calls and local directory assistance calls to a

CLEC’s operator services platform or directory assistance

platform. The CLEC may also request a combination of

shared/common transport and dedicated transport. This

option allows inter-switch calls to be routed to Pacific’s

shared/common transport network using Pacific’s existing

routing translations, or to be routed to the CLEC’s own

trunking network using unbundled dedicated transport as

described above. As of May 31, 1999, no CLEC has ordered

Option C.

132. The Final Decision requires Pacific to allow CLECs’ traffic

from dedicated transport facilities to overflow to

47 See Murray Affidavit for discussion information regarding ordering OptionC.

57

Pacific’s shared/common transport network. App. B, p. 21.

The Final Decision also states that CLECs have an

obligation to adequately size their dedicated transport

trunking based on traffic forecasts and that Pacific should

monitor CLEC’s dedicated transport facilities and meet with

CLECs to resolve over-utilization problems. In Accessible

Letter CLECC 99-189, dated May 21, 1999, and in an update

of the CLEC Handbook, UNE, Section 2.2.3, Pacific advised

CLECs of the availability of the overflow option. Deere

Attachments EE and AA. The overflow option is available

when a CLEC orders unbundled dedicated transport in

conjunction with Option C unbundled switching. Pacific

updated all internal methods and procedures pertaining to

the overflow option.48

Technical Workshop and Trials

133. The Final Decision required Pacific to conduct technical

trials of switching Options B and C in a 2-PIC (“primary

interexchange carrier”) environment (i.e., interLATA PIC

and intraLATA PIC) in conjunction with the CPUC Staff and

the CLECs within 30 days of a technical workshop and to

provide the results of those technical trials to the

Director, Telecommunications Division, no later than 30

days after the conclusion of the technical trials. App. B,

p. 21. In February 1999, the CPUC Staff held a technical

workshop to review custom routing requests. App. B, p. 21.

48 See Murray Affidavit for information regarding ordering of overflow option.

58

Prior to the workshop, Pacific and AT&T provided test

results for tests already performed. Information was also

obtained from Pacific’s switch vendors, Lucent and Nortel.

After the conclusion of the technical workshop, ALJ Reed

issued a Ruling on March 2, 1999 (“March 2 Ruling”) setting

forth the required testing. Attached to the ruling was the

Lucent 2-PIC test plan which the parties agreed to during

the workshop.

134. As directed by the March 2 Ruling, Pacific completed the

technical trial of the Lucent 2-PIC technology in the 5ESS

switch on March 29, 1999, and reported the results to the

Executive Director of the Telecommunications Division on

April 13, 1999. Deere Attachment FF.

135. Pursuant to the Final Decision and the March 2 Ruling,

Pacific, jointly with AT&T and MCI, submitted status

reports to the Executive Director of the Telecommunications

Division on the progress made toward testing customized

routing in the Nortel switch. These status reports began

on April 1, 1999, and have been submitted every month

thereafter. After extensive efforts by Pacific to work

with Nortel, Pacific obtained Nortel’s support of a test

plan for the 2-PIC technology. The test plan was shared

with AT&T and MCI for review on May 28, 1999. The Nortel

test plan mirrored the Lucent test plan to which AT&T and

MCI had previously agreed. However, on June 11, 1999, AT&T

requested additional test calls for Foreign Numbering Plan

Area (“FNPA”) 555-1212 be added to both the Lucent and

59

Nortel test plans. Pacific added addendums to both plans

to accommodate AT&T’s request. Pacific provided the test

results for the addendums and for the Nortel 2PIC test to

the Executive Director of the Telecommunications Division

on July 13, 1999. Deere Attachment GG.

136. Pacific has complied with the Final Decision by providing

custom routing functions which CLECs have requested and

which are technically feasible. App. B, p. 21. Pacific

has investigated and tested customized routing of directory

assistance calls as requested by AT&T. AT&T requested (1)

that 411 calls be converted to 900-555-4411 and routed on

an AT&T switched access service trunk group and (2) that

FNPA 555-1212 be routed to AT&T’s directory assistance

platform.49 Both of these local directory assistance custom

routing configurations for Option B, C, and ROAR can now be

ordered by CLECs. Pacific notified CLECs of the

availability of these arrangements in Accessible Letter

CLECC 99-161 dated May 10, 1999. Deere Attachment HH.

Also on May 10, 1999, Pacific updated the CLEC Handbook,

UNE, section 2.2.2 to include information on these local

directory assistance routing options. To make these

customized routing options available, Pacific developed and

implemented test plans, billing requirements, and internal

methods and procedures for ordering, provisioning, and

49 In comments submitted to the CPUC on June 18, 1999, AT&T along with MCI andSprint, have indicated they now want FNPA-555-1212 routed to the PIC 2carrier.

60

maintenance of these arrangements. As of June 30, 1999, no

CLEC has ordered either of these arrangements.

137. Pacific allows a CLEC to designate the features and

functions to be activated on a particular unbundled switch

port to the extent that such features and functions are

available. See CLEC Handbook, UNE, sections 2.3 and 2.4.

This is done using the same service order process used by

Pacific.

138. Access to unbundled local switching is provided through

switch ports. The following switch ports are available to

all CLECs:

• Analog Line Port (Basic Port): A line-side switchconnection available in either loop or ground startsignaling configurations used primarily for switchedvoice communications.

• Coin Port: A line-side switch connection that interfaceswith “smart” type coin telephone sets.

• Centrex Port: A line-side switch connection for use inproviding Centrex-like services.

• ISDN Basic Rate Interface (“BRI”) Port: A line-sideswitch connection which provides ISDN Basic RateInterface based capabilities.

• PBX Direct Inward Dialing (“DID”) Port: A trunk-sideswitch connection for use in providing DID service tocustomer premises switches.

• Unbundled ISDN Primary Rate Interface (“PRI”) Trunk Port:A trunk-side port connection located at a Pacific end-office switch that provides twenty-three 64 kbps “B”channels for digital voice and data, and one 64 kbps “D”channel to handle call control for the “B” channels.

61

AT&T, Att. 6, §4; ACI, App. F; Cox VIII; and MCI Att. 6,

App. A.

Unbundled Tandem Switching

139. Pacific’s unbundled tandem switching element meets all

requirements of the FCC’s Rules. Included are trunk-

connecting facilities, including, but not limited to, the

connection between trunk termination at a cross-connect

panel and a switch card; the basic switching function of

connecting trunks to trunks; and all technically feasible

functions centralized in tandem switches (as distinguished

from separate end-office switches), including but not

limited to call recording, the routing of calls to operator

services, and signaling conversion features. 47 C.F.R. §

51.319(c)(2); AT&T, Att. 6, § 4.2; ACI, App. F, § 1.2;

Brooks I, § A, F & G; and MCI, Att. 6, § 4.2.

140. Pacific offers a standard tandem switching option and three

custom tandem switching options. AT&T, Att. 6, § 4.2; MCI

Att. 6, § 4.2.1.

141. The standard tandem switching option allows use of the

Pacific tandem switch for the transmission of calls between

two switches connected to that tandem without any

customized routing. Pacific’s unbundled tandem switching

permits access to the tandem switch to originate a call to,

or terminate a call from, a CLEC switch to a Pacific end

office switch, another LEC switch, a wireless service

provider, or another tandem switch, using the normal

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routing established in Pacific’s tandem. AT&T, Att. 6, §

4.2.1.1; ACI, App. F, § 1.2.1.1; and MCI Att. 6, § 4.2.1.1.

142. In addition to the standard tandem switching capabilities,

custom tandem switching allows CLECs to originate a call

through Pacific’s tandem to a CLEC, another LEC, a wireless

service provider, or another tandem switch using the CLEC’s

own interoffice facilities. AT&T, Att. 6, §4.2.1.2; MCI

Att. 6, § 4.2.1.2; and ACI App. F, § 2.1.4. Custom tandem

switching consists of three options:

143. Option 1: Custom Basic – Use of Pacific’s common transport.

This option uses screening that treats the CLEC as a homing

end office. Custom basic unbundled tandem switching may

use dedicated tandem trunk groups that allow full LATA-wide

completion over Pacific’s common transport. Calls routed

to CLECs use normal Local Exchange Routing Guide (“LERG”)

routing. AT&T, Att. 6, § 4.2.1.2.1; ACI, App. F, §

2.1.4.1; MCI, and Att. 6, § 4.2.1.2.1.

144. Option 2: Custom Simple-Use of Pacific’s common transport.

This option uses screening that treats the CLEC as an IXC.

Custom simple unbundled tandem switching uses dedicated

trunk groups towards Pacific’s common transport that will

limit calls to the single tandem serving area. This option

is only able to use common transport in the terminating

direction. Originating calls from Pacific’s end offices

must use common transport to the tandem. The custom simple

option uses a type 2A trunk port with unique screening

capabilities to route traffic to common transport trunk

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groups. AT&T, Att. 6, §4.2.1.2.2; ACI, App. F, §1.1.3.2;

and MCI, Att. 6, §4.1.2.2.

145. Option 3: Custom Complex-Routing Designed to CLEC’s

specifications. Custom complex tandem unbundled switching

uses customized routing for calls sent from the CLEC to

Pacific’s tandem that will be designed to the CLEC’s

specifications, where technically feasible. Option 3

requests for tandem switching will be considered on an

individual case basis. ACI App. F, §1.1.3.3; AT&T, Att. 6,

§4.1.2.3.

VI. CHECKLIST ITEM (vii) E911, DIRECTORY ASSISTANCE, AND OPERATOR CALL COMPLETION

146. Checklist item (vii) requires Pacific to provide

nondiscriminatory access to 911 and E911 Services. 47

U.S.C. § 271(c)(2)(B)(vii)(I). Pacific satisfies this

requirement.

147. In California, state legislators enacted laws to ensure

basic 911 service would be available by the end of 1985.

Later, the State of California and Pacific, through a joint

partnership, embarked upon implementing statewide Enhanced

911. This effort was completed in November 1992.

148. E911 service is provided to CLECs and ILECs via tariff and

interconnection agreements. Pacific is committed to the

accurate nondiscriminatory population of the 911 database

for all customers, regardless of their telecommunications

provider. AT&T, Att. 5, §3.5. Forty CLEC resellers are

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served by the Pacific 911 Database as of May 31, 1999.50

Twenty facility-based CLECs in California currently are

entering data into the 911 database.51 The following is an

explanation of 911 database components; current procedures

for receiving, validating and updating customer records;

and the processing of rejected customer 911 records which

fail data integrity edits.52

149. The Automatic Location Identification (“ALI”) Retrieval

system is geographically split serving Northern and

Southern California with redundant systems in each area.

The current digital ALI network delivers 911 caller

information to the Public Safety Answering Point (“PSAP”)

for each 911 call received (approximately 12.5 million

calls annually). This information is used to dispatch the

emergency response to the correct address.

50 THIRD PARTY PROPRIETARY INFORMATION

51 THIRD PARTY PROPRIETARY INFORMATION

52 See Viveros Affidavit for a detailed description of OSS related to E911.

65

150. The former ALI network was comprised of duplex analog

circuits. Transmission speeds at that time were 1.2 Kbps.

This older architecture was modem intensive (about 800

modems) and prone to failure. The current frame relay

implementation provides increased speed and reliability,

while supporting enhanced user functionality such as

management information delivery to the State. In addition,

frame relay is capable of supporting future 911

functionality such as network mapping and master system

timing.

151. A key attribute of the 911 database system design is that

911 record updates are processed upon completion of the

service provisioning process. Provisioning of service to

the customer’s location must complete prior to 911 record

updates in order to ensure 911 record accuracy. This

attribute serves as a safeguard against erroneous or

incomplete data being processed, as all upstream

provisioning systems must first complete. This safeguard

applies to retail, resale, and facility-based 911 service.

The following diagram depicts the customer record flow for

various customers into the 911 system.

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Pacific BellProcess

ResaleMechanized

Process

Resale ManualProcess Facility ProcessILEC Process

PBBusiness

Office

SORD

WSM/CLEO LSC 911 Gateway

911 MS

911 SelectiveRouter911 ALI Retrieval

1

2

3

M1a

M1

M2

R2

R1 F1

F2

DIU

I1

Database RecordMaintenance

4b4a

Resale Processes

Pacific Bell Processes

Facility Processes

ILEC Processes ( Note: ILEC = All California Incumbent Local Exchange Companies Except Pacific Bell )

1 Subscriber requests service from Pacific

2 Pacific Business Office issues service order in SORD

3 Completed service order is forwarded to 911 ManagementSystem (MS).

4a All (Pacific, ILEC, Resale, & Facility) updates to 911MS are forwarded to 911 ALI Retrieval

4b All (Pacific, ILEC, Resale & Facility) updates to 911MS are forwarded to 911 Selective Router.

Incumbent Local ExchangeCarrier (ILEC)

I1 ILEC forwards completed service orders to Pacific 911MS

Facility Process

F1 Facility-based CLEC forwards completed servicerequests to 911 Gateway

F2 911 Gateway forwards completed service requests to 911MS

Resale Process – Manual

R1 CLEC forwards end-user listing request to LSC viapaper.

R2 LSC issues service order in SORD

Resale Process – Mechanized

M1 CLEC sends end-user listing request to WSM/CLEO viaNDM

M2 WSM/CLEO forwards a service order to SORD

M1a CLEC issues service order in SORD

67

152. Pacific customer records and all CLEC resale records are

processed through the Service Order Retrieval and

Distribution (“SORD”) system. SORD is a legacy

provisioning system that distributes customer account

information: name, address, type of service, etc. to

downstream systems. SORD electronically distributes 911

affecting customer information to the 911 database upon

service order completion. Updates are processed within 48

business hours (two business days) following the completion

of the customer’s order. Pacific’s E911 database systems

process over 99 percent of all service requests (retail and

resale) within 24 hours of service activation/modification.

Facility-based CLECs process their own E911 customer

records into Pacific’s E911 database and are responsible

for the timelines of their updates.

153. Facility-based CLECs update their own records to the 911

database after service-provisioning completion, through the

MS Gateway. ILECs update their own records to the 911

database via electronic update, or manually with paper

updates sent to the Pacific Data Integrity Unit (“DIU”).

Most of these carriers act as their own DIU performing

their own error correction. Pacific’s DIU, upon request

and under contract or tariff, will perform error correction

on records that fail the built-in edits to ensure database

integrity and accuracy. Cox IV, F; MCI Att. 5, 3.6.

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154. Resellers who do not use an electronic ordering interface

fax their Local Service Requests (“LSRs”) to the Pacific

LSC which generates a SORD order. The SORD order flows

through to E911 and is processed along with in the same

manner as retail orders. Pacific’s DIU performs error

correction on all rejected resale records that fail built-

in edits to ensure database integrity and accuracy. All

E911 updates for resale are processed via the SORD order

and errors are corrected by the Pacific DIU. There is no

involvement by the resale CLECs in updating E911 for their

customer records.

155. The Gateway is a firewall between the MS and Pacific’s

external customers. Facility-based CLECs enter data to the

MS through the Gateway. ILECs, based upon historic

processes, enter the MS directly. The concept of the 911

Gateway was presented by Pacific on September 18 and 19,

1995 to the Commission and interested telecommunications

providers as a model to serve the needs of local

competition. During this two-day session, Pacific shared

both the hardware architecture and high level design as

well as record format. The design supported low investment

and low cost dial up access for CLECs. Additionally, the

record format is consistent with the National Emergency

Number Associations (“NENA”) Version 2 standard for data

exchange. The NENA 2 standard is a national standard and

therefore simplifies record formatting for local

competitors.

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156. Currently access to the MS Gateway is dial up with

requirements for specific secured logon. Future

enhancements to the E911 database systems will support a

peer-to-peer type interface for data entry. While

implementation of the interface has not yet been scheduled,

the standards to be used in the development of the

interface have been documented and distributed to the CLECs

via Accessible Letter CLECC 99-173. Deere Attachment II.

The interface will be implemented some time in 2000 and

will be scheduled and introduced through the Change

Management Process.

157. Key attributes of the Gateway are:

• 24 hours/7 days per week availability to facility-basedCLECs providing increased ease and flexibility to theCLEC customer base.

• NENA version 2 standard for data exchange, therebyeliminating as much as possible Pacific customer recordconventions which may not be applicable on a nationalbasis.

• Mechanized Gateway processing and error notification.

• Audit trail consisting of the record for record reportingof all data sent to the Gateway for processing.

• Customer record file builder capability - This softwarewas originally developed for Private Switch ALI serviceproviders, but is available to CLECs that may choose touse it.

Key reports available to Gateway users through the Gateway

are:

• Station Update Report – This report is the record forrecord listing of the data sent to the MS Gateway. For

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every batch sent, this report is returned to the Gatewayfor retrieval by the CLEC to confirm record entry, reviewerrors, and take appropriate action for error correction.

• Station Range Listing – Details all records in the E911database for a specific NPA-NXX telephone number range,for NPA-NXX telephone numbers assigned to a facility-based CLEC.

• Monthly Summary Report – This report summarizes all E911update activity for the CLEC for the month.

• Monthly Usage Activity – This report summarizes batchactivity for a given user log on.

158. CLECs (resale and facility-based) are provided on-line

view-only access directly into the MS thereby providing the

capability for a CLEC to determine in real time the

accuracy of an individual customer record.

159. The DIU performs the database coordinator role for the

facility-based CLECs doing business within Pacific’s

franchise territory. This group coordinates the CLEC’s

initial capability to send and receive data to and from the

911 database as well as distributes methods and procedures

and security access policies. The DIU provides the

following services for facility-based CLECs:

• Establishes log on authorization

• User training

• Conducts initial data test and subsequent support forCLECs

• Maintains the Master Street Address Guide (“MSAG”) forcounties within the Pacific “franchise” area

• Acts as a point of contact for MSAG information

• Provides 911 Selective Router maps

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160. In addition, Pacific’s E911 staff, including an E911 CLEC

Database Product Manager, are available to assist the CLECs

in resolving any issues or pursuing alternate approaches to

data entry/data management. Gateway ease of use and all

CLEC/E911 processes and functions are discussed at the

quarterly Pacific E911 CLEC Database Forums. These user

group meetings are held to discuss current processes, best

practices, upcoming changes to the systems/processes, and

issues or problems. No CLEC introduced any complaints or

problems with the functionality of the Gateway or File

builder software. The E911 CLEC Database Product Manager

is also an active participant on the Pacific/CLEC E911 and

Listings “Fix-it” Team. This is a quality improvement team

focused on system and process improvements for E911 and

Directory Listings. No mention of Gateway access or ease

of use has been raised by any CLEC at these meetings.

161. The DIU utilizes several tools in order to maintain

database integrity. Key tools are Data Reconciliation,

Customer Record Information System (“CRIS”) compare and

internal audit processes.

162. Data Reconciliation is a weekly, statistical sample of

subscriber records in the 911 MS compared against the data

in the Pacific CRIS. Data reconciliation is performed to

ensure the integrity of the Pacific database. All

discrepancies identified during the comparison process are

investigated and resolved by the DIU. Investigation may

include the validation of 911 data against facility

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information, MSAG data, and/or calling the subscriber to

verify location and/or listing data.

163. Resale specific comparisons are also completed weekly.

These comparisons validate 100 percent of the resale

telephone number records in the 911 database against the

telephone number records in the CRIS database. The purpose

is to ensure that all records are in the 911 database and

that the subscriber address information is correct. The

results of these resale data reconciliation efforts are

available to the CLEC upon request.

164. Input error reports are produced daily. The report is

validated and any discrepancy is resolved within 48

business hours. Periodic process audits are also completed

to ensure continuous process improvement.

165. Deere Attachment JJ is a copy of Pacific’s training and

reference guide for 911 Gateway users. It is a

comprehensive manual which contains reject codes,

resolution procedures, methods and procedures, reports,

training requirements, and accepted protocols for building

and sending files. It includes job aids for error

correction, and instructions for processing the port-out

(unlock) and port-in (migrate) functions in support of

local number portability. It is a complete guide for

facility-based CLEC users.

166. Pacific has developed tools and job aids to assist

competitive entry into the 911 market while ensuring that

high 911 data integrity is maintained at a level superior

73

to or equal to the level prior to local competition. The

key tools and job aids are listed below.

167. CLEC Handbook: The CLEC Handbook is an on-line handbook

accessible by all carriers using passwords obtained from

their account managers. The CLEC Handbook, Ancillary,

section 1.0, is related to 911 service and data input.

Deere Attachment CCC. The CLEC Handbook was developed to

serve as a guide to resellers or facility-based CLECs

wanting to do business in California. Its purpose is to

provide an overview of services offered, as well as to

provide understanding of roles and responsibilities between

Pacific and new entrants into the State telecommunications

market. In the CLEC Handbook, Ancillary Services, section

1.0 is dedicated to 911 service. The following topics are

discussed in the 911 section.

• Selective Routing

• Automatic Number Identification (“ANI”) & ALI

• Pacific E911 Services

• E911 technology description

• E911 network call flow diagram

• E911 technical references

• E911 State of California requirements

• E911 Tariffs

• Limitations, terms and conditions of E911 service

• Consultative engineering for E911 service

• Ordering E911 service

• E911 network connectivity design options

• Installation of 911 trunks

74

• Maintenance & Trouble resolution for 911 trunks

• Ordering data management services for E911 service

• Input of E911 data

• Inserts (new connects)

• Deletes (disconnects)

• Change

• Unlock - for out-porting of local number portability(“LNP”)

• Migrate - for porting in LNP

• Billing and payment for E911 service

• E911 Table references

• A job aid for resolving MSAG address errors which mayhave passed PREMIS edits. This job aid addressed knownanomalies between the MSAG and other provisioning addressvalidations.

168. The purpose of the Master Street Address Guide (“MSAG”) is

to ensure correct address information. The MSAG is

maintained by the County Coordinator (a local governmental

position) and is a file of all streets and their numeric

address ranges within a community. When a customer record

is sent to the 911 database for processing, it must

validate against the MSAG. All MSAG media are under tariff

and are readily available for distribution to the CLECs to

assist them in accurate customer record input and

maintenance. Pacific provides the MSAG to CLECs at the

tariff rate, on three types of media: CD ROM, tape, or

paper. Schedule Cal. P.U.C. No. A9.2.5.C.5; AT&T. 5, § 3.5.

169. E911 control offices or selective routers are switches

which ensure that a 911 call is routed to the correct PSAP

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in order for the appropriate emergency response to be

formulated. Routing is based upon the telephone number of

the 911 caller and the associated Emergency Service Number

(“ESN”) which identifies the responsible PSAP. Facility-

based CLECs must purchase dedicated 911 trunks from their

central offices to the correct 911 selective router (911

tandems) in order for their customer base to be routed to

the correct PSAP when a 911 call is made. From the

selective router, the call is combined with Pacific’s 911

traffic over the Pacific 911 network and directed to the

PSAP. To assist facility-based CLECs in designing their

911 network, Pacific provides, under tariff, California

maps depicting 911 selective router locations. Schedule

Cal. P.U.C. No. A9.2.5.C.8. The maps include selective

router locations and Pacific exchange boundaries with

detailed descriptions of the Los Angeles and San Francisco

regions. Items listed are as follows:

• Exchange Boundaries

• Exchange Names

• Rate Center Boundaries

• Central Office Boundaries

• Central Office Name and Common Language LocationIdentification (“CLLI”)

• Selective Router name

• Selective Router boundary

• Selective Router Office Location and associated NPAs

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170. Pacific provides and maintains equipment at the E911

control office and the 911 management system (“911 MS”) as

necessary to perform E911 services for the requesting local

E911 customer. This includes some or all of the following,

as needed:

• Transporting the E911 calls from the CLEC’s switches tothe control office of the E911 system;

• Switching the E911 calls through the control office tothe public safety answering point;

• Storing the names, addresses, and associated telephonenumbers from the CLEC’s customers in the E911 databasemanagement system; and

• Transmission of the information associated with theCLEC’s customers to the public safety answering pointupon the customer calling 911.

171. Pacific provides and maintains sufficient dedicated E911

circuits according to provisions of the E911 tariff and

specifications of the E911 customer. Pacific also provides

the CLEC a description of the geographic area and public

safety answering points served by the E911 control office.

Because 911 call traffic fluctuates widely, the most

important factor in determining the number of trunks

required from a central office to a 911 control office is

the number of calls originated and blocked. This data for

proper sizing of 911 trunk groups can only be collected in

the originating central office switch. Therefore, the CLEC

must collect the traffic data and determine the proper

number of trunks for 911 service.

77

172. Pacific assures the confidentiality of proprietary

information about the CLEC’s customers when these records

are in Pacific’s 911 computer systems by strictly limiting

the number of people who have access to this information.

The only Pacific employees who have access to the E911 MS

database are those who specifically support 911 services.

No other employees have access to the dedicated computer

system where the MSAG and the ALI databases are stored.

CLEC data is retained with the NENA identifier of the CLEC

in each of their customer records. This restricts access

to the owner-company of the record.

VII. CHECKLIST ITEM (x) ACCESS TO DATABASESAND ASSOCIATED SIGNALING

173. The checklist requires that Pacific provide

nondiscriminatory access to databases and associated

signaling necessary for call routing and completion. 47

U.S.C. § 271(c)(2)(B)(x). The FCC Rules further expand this

responsibility to provide nondiscriminatory access to

signaling networks and call-related databases. 47 C.F.R. §

51.319(e). Pacific provides nondiscriminatory access to

its signaling networks and call-related databases used for

call routing and completion. AT&T, Att. 6, §6.1.1; ACI,

§2.6, App. F; and MCI, Att. 6, §6.

174. Pacific provides nondiscriminatory access to its signaling

links and signal transfer points (“STPs”) on an unbundled

basis. 47 C.F.R. § 51.319(e)(1)(i); AT&T, Att. 6, §6.2.4;

ACI, §2.6, App. F; and MCI Att. 6, §6.2.4. SS7

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interconnection is provided to CLECs for their use in

furnishing SS7-based services to their end users or the end

users of another CLEC subtending the signaling service

point or STP of the interconnecting CLEC. AT&T, Att. 6, §

6.2.5; ACI, § 2.6; and MCI Att. 6, § 6.2.5. This

arrangement, which is identical to the one used by Pacific

itself, permits CLECs to use Pacific’s SS7 signaling

network for signaling between their switches, between their

switches and Pacific’s switches, and between their switches

and the networks of other parties connected to the Pacific

SS7 network. 47 C.F.R. § 51.319(e)(1)(iii). As of May 31,

1999, 13 CLECs and 26 other carriers were connecting their

switches to Pacific’s SS7 network via a total of 410 links.

175. When a CLEC purchases unbundled switching capability,

Pacific provides access to its signaling network in the

same manner it provides such access to itself. Because all

unbundled switching elements are provided on switches

Pacific uses to provide service to its own customers, all

signaling functions are identical. 47 C.F.R. § 51.319

(e)(1)(ii); MCI Att. 6, § 6.2.9; and AT&T Att. 6, § 6.2.9.

176. Pacific’s SS7 interconnection service provides dedicated

two-way signaling links that interconnect Pacific STP

locations and the CLEC signaling points at signaling-point-

of-interface locations. The SS7 service consists of STP

port termination(s) for CLEC signaling and STP

interconnection facilities. The port terminations consist

of port connections of 56 Kilobits per second (Kb/s)

79

transmission facilities on Pacific’s STP. The STP

interconnection facility lies between the multiplexing hub,

which demultiplexes the CLEC’s 56 kb/s transmission from

DS1 transmission facilities, and the STP port. These

interconnection facilities may be provided by the CLEC, may

be obtained from Pacific as dedicated transport facilities,

or may be obtained from another provider. 47 C.F.R. §

51.319(e)(1)(ii); AT&T, Att. 6, §§ 6.2.4-6.2.6; and MCI,

Att. 6, §§ 6.2.4-6.2.6.

177. The CLEC Handbook, UNE, section 4.0 provides ordering and

provisioning procedures for obtaining unbundled signaling

links and/or STP access. Deere Attachment DDD.

178. The FCC Rules identify certain call-related databases at 47

C.F.R. section 51.319(e)(2)(ii). Pacific’s ICAs provide

access to its Line Information Database (“LIDB”). AT&T,

Att. 6, §6.5; ACI, 1.5, §2.6; and MCI Att. 6, §6.5. Many

carriers currently access Pacific’s LIDB. The ICAs also

provide for access to Pacific’s 800 service database, and

Advanced Intelligent Network (“AIN”) databases. AT&T, Att.

6, §6.6; ACI, 2.6; MCI, Att. 6, 6.6.

179. Pacific provides CLECs access to LIDB on the same basis as

Pacific obtains access itself. Pacific provides access to

LIDB through interconnection at the STP. LIDB service is

provided by Pacific to support Alternate Billing Services

(“ABS”), Calling Name Delivery Services (“CNAM”), and

Originating Line Number Screening Services (“OLNS”).

Pacific offers all of these services to CLECs.

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180. ABS is an operator service provider offering that allows

end users to bill calls to accounts that may not be

associated with the originating line, i.e., collect,

calling card, and third number billed calls. CNAM provides

called numbers with identification of the name associated

with the calling number. OLNS provides the originating

call processing and billing profiles of originating lines.

181. LIDB receives and responds to ANSI SS7 protocol queries as

defined in Bellcore Publication TR-TSV-000905 and Pacific

Publication PUBL-780023.

182. Access to LIDB is a function of a service platform capable

of correctly formatting and launching a LIDB query and

receiving, parsing, and using the LIDB response. There are

many types of such service platforms, including operator

service systems, end offices switches, IXC switches, and

AIN SCPs. When a CLEC deploys its own service platform, it

obtains access to LIDB by using the SS7 interconnection

service, and it has access to the same functions and

features of the database as does Pacific. 47 C.F.R. §

51.319(e)(2)(iv); AT&T, Att. 6, § 6.2.9; ACI, 2.6; and MCI

Att. 6, 6.5.1.

183. When a CLEC purchases unbundled local switching elements,

it obtains LIDB validation and OLNS through its designated

operator service provider for validation of alternately

billed calls and the screening profile of the originating

line. CLECs also access LIDB for calling name information

in a manner identical to Pacific’s access in the same

81

switch. 47 C.F.R. § 51.319(e)(2)(iii); § 51.319

(e)(2)(iv).

184. The CLEC Handbook, Ancillary Services, section 8.0 provides

information on ordering access to LIDB. Deere Attachment

KK.

185. Pacific allows CLECs to administer their LIDB and CNAM

information in the same manner Pacific administers its own

data. When a CLEC provides end-user services via resale,

data administration of the CLEC’s customer records will be

identical to Pacific’s administration of Pacific’s own

customer records. When a CLEC provides end-user services

through unbundled local switching, or through the CLEC’s

own switch, the CLEC will have electronic access to the

same data administration interfaces used by Pacific.

186. When a CLEC purchases unbundled switching elements from

Pacific, the CLEC has access to the CNAM database identical

to that used by Pacific in that switch. 47 C.F.R. §

51.319(e)(2)(iii).

187. Pacific provides access to the Service Management Systems

(“SMS”) associated with the LIDB described above in

accordance with 47 C.F.R. section 51.319(E)(3). Requesting

carriers are provided the relevant information necessary to

correctly enter, or format for entry, input into the

various databases by their associated SMSs.

188. Pacific processes LIDB updates continuously through service

order input to the LIDB Administrative System, (“LIDB/AS”)

which then updates LIDB. AT&T, Att. 6, §7.1.1. Service

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order access to LIDB/AS allows CLECs to create, modify,

update, or delete their end-user information in Pacific’s

LIDB when Pacific is the carrier of record in the LERG.

Updates to LIDB for CLECs that use Pacific’s service order

process are performed in the same manner as Pacific’s

updates.

189. Pacific provides access to LIDB/AS in a manner equivalent

to the access Pacific provides itself. CLECs have the

ability to create, modify, update, or delete information in

LIDB through service order processing, generated through

Pacific’s LSC or electronic service order entry. AT&T,

Att. 6, § 7.1.2.1; MCI, Att. 6, § 7.1.2.2

190. Pacific’s interconnection agreements provide the terms and

conditions for nondiscriminatory access the Pacific’s toll-

free calling database (800/888). Access to the toll-free

calling database allows a CLEC to access Pacific’s toll-

free calling database for the purpose of switch query and

database response. This provides the CLEC information

required to determine the appropriate routing for toll-free

numbers. CLEC query access to Pacific’s toll-free service

database is provided via interconnection at Pacific’s

regional or local STPs consistent with existing network

interface specifications. AT&T, Att 6, §6.4.3.1; MCI, Att.

6, §6.4.3.1.

191. When a CLEC purchases unbundled switching elements from

Pacific, the access to the 800 database is identical to

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that used by Pacific in the same switch. 47 C.F.R. §

51.319(e)(2)(iii).

192. AIN is a vendor-independent network architecture that

provides capabilities for creation of custom

telecommunications services invoked by SS7 messages from a

switch to a SCP database. CLECs may purchase the entire set

of AIN features or functions deployed by Pacific, or any

combination of such features or functions on a customer-

specific basis. Pacific will provide CLECs with query

access to AIN databases to support AIN services in two

ways: 1) from Pacific’s unbundled switch element or resold

line; or 2) from the CLEC’s own switch. Pacific will

provide CLECs access to Pacific’s deployed end-office

triggers when the CLEC purchase Pacific’s local switching

and any available AIN services. AIN database access may

not be used to access other Pacific databases. 47 C.F.R. §

51.319(e)(2)(iii)-(iv), § 51.319(e)(3)(C); AT&T, Att. 6, §

6.6.1; ACI, 2.6; and MCI, Att. § 6.6.1.

193. Access to AIN SMS is provided via electronic file transfer

of CLEC data to Pacific for entry by Pacific at one of

Pacific’s AIN administrative terminals as is currently used

by Pacific for maintenance of AIN service and subscriber

data. AT&T, Att. 6, § 7.2.2.1; MCI, Att. 6, §7.2.2.1. The

CLEC Handbook, Interconnection, section 5.0 pertains to

access to AIN functionality. Deere Affidavit LL.

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194. Pacific will respond to requests for additional

arrangements for access to call-related databases and

associated signaling facilities through the BFR process.

195. Pacific has complied with the Final Decision requirement to

demonstrate it will prevent the reoccurrence of SS7

problems similar to those reported by two CLECs during the

271 Workshops.53 App. B, p. 23. Since August 31, 1998,

Pacific has successfully implemented and maintained the

necessary process improvements for ordering, provisioning,

and maintaining database-driven features such as LIDB,

CNAM, and CLASS. Pacific has developed and implemented

methods and procedures for multiple workgroups to ensure

on-time, complete, and accurate implementation of these

database services. From late August 1998 through May 31,

1999, Pacific completed 48 orders from 12 CLECs on-time and

with no reoccurrence of any problems similar to those

reported by two CLECs at the 271 Workshops.

196. Pacific has complied with the Final Decision requirement to

demonstrate that AIN is available to CLECs. App. B. pp.

22-23. The fact that CLECs have access to AIN-based

services deployed in Pacific’s network is demonstrated by

the ICAs. ACN, Att. 6, 6.6; AT&T, Att. 6, 6.6; and MCI,

Att. 6, 6.6. Further, Deere Attachment MM is Accessible

Letter CLECC 98-129, dated November 20, 1998, which

informed all CLECs of the AIN application process. This

53 THIRD PARTY PROPRIETARY INFORMATION

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letter addresses both the process used by a CLEC to create

AIN-based services, i.e., service creation, and the process

used to order, provision, and maintain these services,

i.e., AIN SMS. In addition, these same processes are

covered in the CLEC Handbook, Interconnection, section 5,

dated April 15, 1999. Deere Attachment LL.

197. The Final Decision states that, unless no CLEC follows

through with ordering AIN Service Creation Environment

(“SCE”) functionality, Pacific must prove that the

processes it has developed for AIN deployment are fair and

nondiscriminatory. The best method of proof is to

chronicle the process used to provide particular CLECs with

the functionality they want. App. B, p. 22.

198. As of May 31, 1999, no CLEC has ordered AIN SCE and SMS.

Further, no CLEC has indicated through its account manager

any plans for ordering or providing AIN-based services.

Under ICAs, CLECs have three different options for creating

AIN services. ACN, Att. 6, 7.3; AT&T, Att. 6, 7.3; and MCI,

Att. 6, 7.3. CLECs can define the services themselves and

give the descriptions and flow charts to Pacific; they can

use Pacific’s SCE platform; or they can request that

Pacific create the service for them. CLECs that choose to

use Pacific’s AIN terminal to create their own services

must agree to a non-disclosure agreement, which describes

the Telcordia license controlling the software used by the

terminal. The application for AIN services along with the

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process to be used for service creation is contained in the

CLEC Handbook, Interconnection, section 5.0.

199. As noted in section 5.0 the CLEC Handbook, Pacific will

make available, upon request the following three technical

documents describing AIN functionality:(1)Pacific/Nevada

Bell Specification for Access to Advanced Intelligent

Network (AIN) 0.1 Capabilities; (2)Service Certification

Process for Access to Advanced Intelligent Network

Capabilities; and (3)AIN Service Creation Environment

(“SCE”) Requirements and Guidelines for CLEC Access to AIN

Service Creation and Management.

200. Pacific has also complied with the Final Decision to

demonstrate improvement in its communications with CLECs

regarding the availability of Pacific’s AIN-based service

offerings. App. B, p. 22. Accessible Letter CLECC 98-129

and the updated CLEC Handbook, Interconnection, section 5.0

are examples of the improved communications with the CLECs

related to AIN-based services.54

201. Pacific has also complied with the Final Decision with

respect to making the Bellcore AIN services supported by

Pacific’s network available to the CLECs. App. B, p. 23.

The CLECs were advised of the availability of the supported

Bellcore AIN services in Accessible Letter CLECC 98-129,

dated November 20, 1998. In addition, CLEC Handbook,

54 The numerous Accessible Letters and updated CLEC Handbook sectionscontained in this and the other affidavits submitted by Pacific demonstratethat Pacific has improved the communication of new or changed offerings ingeneral.

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Interconnection, section 5.2.1 was updated to include these

Bellcore AIN services.

202. In summary, as required by 47 C.F.R. § 51.319(e), Pacific

provides unbundled, nondiscriminatory access to its

signaling networks; to its call-related databases used in

the signaling networks for billing and collection or the

transmission, routing or other provisioning of

telecommunications services; and to the associated SMS for

each database. Each database is accessed through Pacific’s

STPs by a requesting CLEC in the same manner and via the

same signaling links used by Pacific.

VIII. CHECKLIST ITEM (xi) NUMBER PORTABILITY

203. Checklist item (xi) requires that:

Until the date by which the Commission issuesregulations pursuant to section 251 to require numberportability, interim telecommunications numberportability through remote call forwarding, directinward dialing trunks, or other comparablearrangements, with as little impairment offunctioning, quality, reliability, and convenience aspossible. After that date, full compliance with suchregulations.

204. Local number portability is a service arrangement whereby

an end user who switches subscription for local exchange

services from one local service provider to another is

permitted to retain the existing assigned telephone number,

provided the end user remains at the same location. Cox,

XV.

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205. Effective January 31, 1999, Pacific no longer accepts INP

orders because Long-Term Number Portability (“LNP”) has

been fully deployed in California.55 During the period when

INP was available, Pacific offered Interim Number

Portability (“INP”) to CLECs through Directory Number Call

Forwarding (“DNCF”), Flex Direct Inward Dialing (“Flex

DID”), and Route Indexing, which Pacific offered as Direct

Number-Route Index (“DN-RI”) and Route-Indexing-Portability

Hub (“RI-PH”). AT&T, Att. 15, 2.4; ACI, 7.1; and MCI, Att.

15, 2.4. These services were offered in accordance with

the FCC’s Rules and the FCC’s First Report and Order on

number portability.56 Effective February 1, 1999, Pacific

no longer provisions any new INP lines because all Pacific

switches are now capable of providing LNP.

206. While Pacific does not consider it a form of INP, Pacific

has reassigned exchange prefixes or NXX codes when all of

the customer numbers served in a particular NXX are

assigned to end-user customers who subscribe to a single

CLEC. If one customer has an entire NXX code and transfers

from Pacific to a CLEC, permanent portability for that

customer will be provided by utilizing reassignment of the

NXX code to the CLEC through the LERG. Updates to

translations in the Pacific switching office to which the

numbers were originally assigned will be made by Pacific

55 See Fleming Affidavit.56 In the Matter of Telephone Number Portability, CC Docket No. 95-116, First

Report and Order and Further Notice of Proposed Rulemaking (1996).

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prior to the date on which LERG changes become effective to

redirect calls to the CLEC’s switch via route indexing.

AT&T, Att. 15, §2.5; MCI, Att. 15, §2.4.

207. Information concerning Pacific’s methods of coordinating

with the CLECs for customer conversions from INP to LNP is

contained in the Tenerelli Affidavit. Information

concerning the implementation schedule for permanent number

portability, i.e., LNP, which has replaced INP, is

contained in the Fleming Affidavit.

IX. CHECKLIST ITEM (xii) LOCAL DIALING PARITY

208. Checklist item (xii) requires Pacific to provide:

Nondiscriminatory access to such services orinformation as are necessary to allow the requestingcarrier to implement local dialing parity inaccordance with the requirements of section 251(b)(3)47 U.S.C. § 271(c)(2)(B)(xii).

Section 251(b)(3) provides the following requirements:

Dialing parity — The duty to provide dialing parity tocompeting providers of telephone exchange service andtelephone toll service, and the duty to permit allsuch providers to have nondiscriminatory access totelephone numbers, operator services, directoryassistance, and directory listing, with nounreasonable dialing delays.

Pacific meets both of these requirements. ACI, 8.1, §8.2.

209. Pursuant to 47 C.F.R. section 51.207, local dialing parity

means that telephone exchange service customers within a

local calling area may dial the same number of digits to

make a local telephone call, regardless of the identity of

the customer’s or the called party’s CLEC. Pacific’s

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interconnection arrangements fully meet this requirement.

The FCC’s Second Order (¶ 71) stated that local dialing

parity is also achieved through the implementation of the

interconnection, number portability, and nondiscriminatory

access to telephone number requirements of section 251 of

the Act. As described herein, Pacific has implemented each

of these in accordance with the Act and the FCC Rules.

210. Pacific’s interconnection arrangements do not require any

CLEC to use access codes or additional digits to complete

local calls to Pacific customers. Neither are Pacific

customers required to dial any access codes or additional

digits to complete local calls to the customers of any

CLEC. The interconnection of the Pacific network and the

network of CLECs will be seamless from a customer

perspective. Because the CLEC central office switches are

connected to the trunk side of the Pacific tandem or

central office switches in the same manner as Pacific and

other local exchange carriers, there are no differences in

dialing requirements or built-in delays for a CLEC

customer. AT&T, Att. 18; ACI, §8.2.

X. INTRALATA DIALING PARITY

211. In addition to local dialing parity, Pacific provides toll

carriers intraLATA dialing parity in accordance with

section 251(b)(3). On May 7, 1999, Pacific implemented

IntraLATA Presubscription (“ILP”) in California, as

directed by the FCC and the CPUC. ILP allows customers to

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pre-select their intraLATA toll provider, just as they have

pre-selected their interLATA long distance provider for a

number of years. In the same way that interLATA long

distance presubscription works, ILP allows customers to

make intraLATA toll calls using their chosen provider

without having to dial extra digits. Pacific implemented

ILP in all of its switches using the full 2-PIC technology,

which permits customers to select the same or different

providers to handle their intraLATA toll calls and/or

interLATA long distance calls. The availability of ILP is

confirmed by Accessible Letter EA99-030, dated May 5, 1999,

and Pacific’s presubscription tariff, Schedule Cal. P.U.C.

No. 175-T, section 13 effective May 7, 1999, submitted as

Advice Letter No. 20217 filed April 30, 1999. Deere

Attachments NN and OO,57 respectively. Between May 7, 1999,

and June 26, 1999, Pacific completed 983,380 LPIC changes.

XI. CHECKLIST ITEM (ix) ACCESS TO TELEPHONE NUMBERS

Establishment of Federal Numbering Guidelines

212. In July 1995, the FCC issued a rulemaking in CC Docket No.

92-237 addressing number administration.58 In the NANP

Order, the FCC required the transfer and centralization of

number administration responsibilities to a neutral third

party. The FCC also created the North American Numbering

57 This attachment also includes Advice Letter No. 20217A filed May 4, 1999,which was a supplement to Advice Letter No. 20217. Only the relevanttariff sheets attached to these advice letters have been included in thisattachment.

58 In the Matter of Administration of the North American Numbering Plan,Report and Order (“NANP Order”).

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Council (“NANC”) to oversee this transfer and to set

numbering policies for the NANP. AT&T, Att. 15, §6.1.

213. Pacific is an active participant in the NANC. Pacific

fully supports the efforts of the NANC and, likewise, fully

supported the quick and responsible transfer of number

administration functions to a neutral third party.

214. In its Second Order (¶ 264), the FCC held that “the action

taken in the NANP Order satisfies the Section 251(e)(1)

requirement that the Commission create or designate an

impartial third party number administrator.” The FCC

“authorize[d] Bellcore and incumbent LECs to continue

performing the number administration functions they

performed prior to the enactment of the 1996 Act.” ¶ 328.

The FCC concluded “incumbent LEC’s should apply identical

standards and procedures for processing all numbering

requests, regardless of the identity of the party making

the request.” ¶ 334.

215. The FCC’s NANP Order transferred the number administration

functions formerly performed by Pacific to a new NANP

administrator. The FCC chose the new administrator,

Lockheed Martin. The transition of the code administration

function from Pacific to Lockheed Martin began on April 30,

1998. Pacific continued to perform code administration

functions until completion of the transition on March 19,

1999.

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Assignment of Central Office Codes

216. Checklist item (ix) requires that Pacific provide, “[u]ntil

the date by which telecommunications numbering

administration guidelines, plans, or rules are established,

nondiscriminatory access to telephone numbers for

assignment to the other carrier’s telephone exchange

service customers.” 47 U.S.C. § 271(c)(2)(B)(ix). The

FCC’s rules, in turn, require that a LEC permit competing

providers to have access to telephone numbers identical to

the access the LEC provides itself. 41 CFR § 51.217(I)(i).

217. As used in this affidavit, “Number Administration” refers

to the administration and assignment of central office

codes to requesting facility-based telecommunications

providers.

218. The North American Numbering Plan Administration (“NANPA”)

was assigned responsibilities for coordination and

administration of the North American Numbering/Dialing

Plans at divestiture. Pacific exercised these central

administration functions in an impartial manner toward all

industry segments while balancing the utilization of a

limited resource.

219. A telephone number is made up of three components, totaling

10 digits. The first three digits represent the “numbering

plan area” or “NPA.” The NPA is commonly referred to as

the “area code.” The second three digits constitute the

central office or “NXX” code. The final four digits of the

telephone number represent the specific line addresses

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within the NXX. The format of a telephone number is

therefore: NPA-NXX-XXXX.

220. In the NXX, any number from 2 to 9 may represent “N,” and

any number from 0 to 9 may represent “X.” There are 792

assignable NXX codes within each NPA (200 through 999, less

all “N11” codes such as 911, 411, etc., which are reserved

for emergency and other public access purposes), and 10,000

telephone numbers (NXX-0000 through NXX-9999) within each

NXX.

221. In order to provide facility-based local exchange telephone

service within the public switched telephone network,

carriers must have an NXX code(s) assigned to their

switching location for the provision of telephone numbers

to their subscribers. The regional Central Office Code

Administrator makes assignment of central office codes.

XII. OTHER NETWORK ISSUES

Network Disclosures

222. Section 251 (c)(5) of the Act requires ILECs to publicly

disclose changes in their networks. The FCC implemented

this section of the Act in its Second Order. The FCC Rules

established by this order require the ILEC to provide such

disclosure for any network change that will affect a

competing carrier’s performance or ability to provide

service, or the ability of the ILEC’s network to be

connected to and usefully exchange information with the

competing carrier’s network. 47 C.F.R. § 51.325. The

95

rules specify the content of these network disclosures,

including, for example, a description of the network

change, the implementation date of the change, and the

location where the change will occur. 47 C.F.R. § 51.327.

The rules also specify the allowable methods of

notification; the ILEC’s publicly accessible Internet site

is one of the allowed methods. 47 C.F.R. §51.329. The FCC

Rules require that these network disclosures generally be

made at the time when the ILEC must make or buy whatever

hardware or software is required to implement the change.

If this occurs less than six months before implementation,

at least six-months’ notice is generally required.

Similarly, if this occurs more than six but less than 12

months before implementation, at least 12-months’ notice is

generally required. If new hardware or software is not

required for the change, this timing is based upon the

ILEC’s decision to implement. Furthermore, if either the

make/buy point or decision to implement can occur in less

than six-months, the FCC has specified additional “short-

term” procedures for the ILEC to follow. 47 C.F.R. §

51.331-333.

223. Pacific complies with the FCC’s network disclosure rules by

posting all disclosures within the requisite time to the

SBC corporate Internet site, by FCC filings, and, for

short-term disclosures, via its accessible letters. Deere

Attachment PP is an example of the network disclosures made

by Pacific.

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Ancillary Equipment

224. The Final Decision requires Pacific to provide, at no

charge, any pieces of equipment required to make a UNE

function as specified the ICAs. App B, p. 16. To confirm

that Pacific will provide any UNE with all the

functionality described in the ICAs, Pacific issued

Accessible Letter CLECC 99-096 on March 25, 1999. Deere

Attachment QQ. As noted in the accessible letter, the

price listed in the pricing section of the ICA for a UNE

covers all functionality for the UNE, including all

necessary equipment.

225. As agreed in the 271 Workshop, Pacific met with CLEC

representatives on September 3, 1998 to develop a list of

ancillary equipment. WS Agreement 1.3.1.1. The parties

agreed that some of the items on the initial list could be

combined, and others were merely ordering options for UNE

loops and transport. The CLECs withdrew their requests for

stand-alone multiplexers, Dataphone Digital

Service/Automatic Network Dialing (“DDS/AND”), digital data

over voice, carrier network interconnection (cellular IC),

and high voltage protection. Two separate lists were

developed during this meeting. The first list included

equipment items desired by the CLECs. The second list

included services (as opposed to equipment) desired by the

CLECs. As it had done in the 271 Workshops, Pacific

advised the CLECs at the meeting that the service items

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were not subject to the ancillary equipment process, but

that Pacific would consider methods of providing the

services to CLECs where appropriate.

226. Following an analysis of the CLECs’ requests, on October

28, 1998, Pacific sent a letter to the CLECs that

participated in the September meeting. Deere Attachment

EEE. Pacific again advised the CLECs that it would provide

those items that were truly ancillary equipment. Pacific

restated that many of the items on the CLECs list would not

be provided as ancillary equipment because they were not

deployed in Pacific’s network; they were Customer Premise

Equipment (“CPE”); or they were a request for collocation,

a new UNE, or a new form of interconnection. As it had

done at the 271 Workshops and at the September meeting,

Pacific referred the CLECs to the appropriate processes

under their ICAs for collocation or to negotiate a new UNE

or form of interconnection. By this letter, Pacific also

asked the CLECs to prioritize the list of equipment so that

Pacific could prioritize the development work and respond

with cost studies for the most desired items first.

227. On December 16, 1998, MCI WorldCom, on behalf of the CLECs,

replied that the CLECs still demanded all items discussed

at the September meeting. Deere Attachment RR. The CLECs

did not provide a prioritized list to assist Pacific in

responding to their needs.

228. For the items that qualified as ancillary equipment,

Pacific proceeded with the development of methods and

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procedures, ordering scenarios, and updates to the CLEC

Handbook to permit the CLECs to order the ancillary

equipment. App. B, pp. 16-17, WS Agreement 1.3.1.2.

Pacific Accessible Letter CLECC 99-147, dated May 4, 1999,

advised CLECs of the availability and pricing of the

ancillary equipment. Deere Attachment SS. Accessible

Letter CLECC 99-203, dated June 1, 1999, advised CLECs that

ordering information for ancillary equipment was available

in the CLEC Handbook, UNE, Section 6.0. As stated in

Accessible Letter 99-248, the correct section is 7.0. See

Deere Attachment TT for Accessible Letters CLECC 99-203 and

CCLEC 99-248 and Deere Attachments FFF for a copy of the

CLEC Handbook, UNE, section 7.

229. The stand-alone ancillary equipment that Pacific agreed to

provide was:

• Analog Bridging

• Program Audio Bridging (hubbing arrangement)

• DCS Options (Digital Cross Connect Systems)

• Customer Network Reconfiguration

230. Although not ancillary equipment, Pacific also developed

descriptions, provisioning methods and procedures, and CLEC

Handbook updates for the following configurations requested

by the CLECs:

• DS1 Loop on Copper Facilities, CLEC Handbook, UNE,section 7.6.

• Transport UNE Diverse Routing, CLEC Handbook, UNE,section 7.2.

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231. Although not ancillary equipment, as requested by the

CLECs, Pacific provided ordering information to permit the

CLECs to order DS1/DS3 coding options. See Accessible

Letter CLECC 99-152, dated May 5, 1999, Deere Attachment

UU.

232. The CLECs had also requested DS1 line ports and PBX trunk

ports. Ports are unbundled switching, not ancillary

equipment. AT&T, which had originally negotiated the DS1

line port in its ICA, subsequently clarified that it really

wanted an ISDN PRI trunk port. AT&T, Amendment 4 (Advice

Letter 19412), Deere Attachment VV. The ISDN PRI and PBX

trunk port are available in the AT&T ICA, Attachment 6, §

4.1.1.1 and Attachment 8, Appendix A as amended in

Amendment 4. CLECs may either opt into the existing ICAs

containing these UNEs or they may request these ports

through an amendment to their own agreements. The ISDN PRI

trunk port and the PBX trunk port are referenced in the

CLEC Handbook, UNE, Section 2.1.2. Deere Attachment AA.

233. Pacific cannot provide the following items as stand-alone

equipment because there is no way to provision these items

without a loop or transmission circuit. However, these

items are made available at no cost to CLECs as options

when UNE loops and/or UNE transport are ordered:

• Digital Loop Repeater – A digital loop repeater will beprovided when necessary, at no additional charge, when aCLEC orders a 4-wire digital loop or a DS1 localtransport UNE.

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• D-Channel Banks – A D-channel bank is provided as amultiplexer associated with local transport (DS1). Allindividual channel plug-in options used by Pacific areavailable to the CLECs for use in providing customerservices at no additional charge when the CLEC ordersunbundled transport. These are ordered using NC/NCIcodes.

• Metallic Facility Termination (MFT) – Loop conditioningwill be provided on UNE loops as required to meet thespecified design criteria in the CLEC’s ICA at noadditional cost to the CLEC. All circuit plug-in optionsused by Pacific for retail are also available to theCLEC’s for use in providing customer services. If a CLECdesires to condition the loop to a different designcriteria, the CLEC must specify this criteria usingNC/NCI codes. Pacific will then provide the circuitpacks necessary to make the loop perform as ordered at nocost.

234. The following equipment and services requested by the CLECs

will not be offered by Pacific as ancillary equipment

because they are not available in Pacific’s central

offices:

• Alternate Line Protection Switch

• Bridge Lifters

• Line Switch in Central Office (A/B switch, tone orbattery operated)

• Echo Cancelers

• Digital Bridging – The only 4-wire digital loop currentlyoffered by Pacific in interconnection agreements is a 4-wire 1.544 Mbps capable loop. Pacific does not havedigital bridging equipment in its central offices capableof bridging 1.544 Mbps loops.

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• Video Repeaters – This equipment is not generallyavailable in Pacific’s network. Pacific provides videorepeaters to its retail customers on an ICB basis for aspecific customer under a special service arrangement. ACLEC may order this type of equipment from Pacific on thesame ICB basis as retail customers.

235. The following equipment and services requested by the CLECs

will not be offered by Pacific as ancillary equipment

because they are CPE. The CLEC may obtain such CPE from

multiple sources and install it on its own end-user’s

premise. Pacific does not install CPE for CLEC end users.

• 4-Wire Terminal Set at Customer’s Premise

• Customer Designated Receive

236. The following equipment and services requested by the CLECs

will not be offered by Pacific as ancillary equipment

because they are requests for a new UNE, a new form of

interconnection, or collocation. The ICAs require that new

request for interconnection or UNEs be negotiated or

submitted as BFRs. A request for collocation must be

submitted pursuant to the collocation request process.

• DSLAM – A DSLAM equipped to serve only 144 lines costsover $50,000 excluding engineering and test equipment. ADSLAM may be obtained from multiple vendors and deployedby the CLEC in a physical or virtual collocationarrangement.

• UDLC/IDLC – A minimum size arrangement to serve 96 linescost approximately $30,000. A DLC may be obtained frommultiple vendors and deployed by the CLEC in a physicalor virtual collocation arrangement. When a DLC is usedby Pacific to provide a UNE loop, all circuit plug-ins

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used by Pacific are available as options to the CLEC atno additional charge.

• ATM Transport and Frame Relay – This item constitutes arequest for a new transport UNE or a new form ofinterconnection. See paragraph 17 for a description ofPacific’s Frame Relay NNI offering.

• Ability to Order a Derived Channel on an Existing fiberSystem to a Customer Premises - This is a request forspectrum unbundling involving customer-owned multiplexingequipment at the customer’s premises - Pacific does notoffer CPE or spectrum unbundling.

• SONET Add/Drop Multiplexer Box – Subject to furtherdefinition by the requesting CLEC, this may be a requestfor collocation, a new UNE, or a new form ofinterconnection. Pacific already provides SONET-basedequipment, including ADM, to provide unbundled digitaltransport to CLECs. If a CLEC desires to use an ADM forits own purposes, it can obtain the equipment frommultiple vendors. A FLM2400 with a capacity of 48 DS3scosts approximately $48,000 plus engineering andinstallation. A CLEC may place the ADM in itscollocation arrangement and connect unbundled transportand/or loops or the CLEC may designate the equipment itwishes to deploy and Pacific will provide it pursuant toa valid request for virtual collocation.

• Packet Transport - Subject to further clarification bythe requesting CLEC, this may be a request for a new UNE,a new form of interconnection, or a request forcollocation. Packet switches are available from a largenumber of providers. A Nortel DPN100 packet switch withcapacity for 176 v. 35 trunks costs approximately$210,000 plus engineering and installation. A CLEC maypurchase packet switching equipment and place it in itscollocation space or the CLEC may designate the equipment

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it wishes to deploy and Pacific will provide it pursuantto a valid request for virtual collocation.

• SMDI Interface for Messaging – A fully SMDI system forthe provision of stutter dial tone in connection withvoice mail services requires the establishment of a huboffice where the voice mail service provider connects tothe network and data links to every other central officeto be used by that specific service provider. This is acustom configuration. To provide SMDI service to itscustomers, a CLEC needs to combine a number of switchingUNEs and local transport UNEs in a custom configuration.If a CLEC desires to use the existing SMDI capabilitiesof the Pacific network, it should negotiate with Pacificand provide the necessary engineering specifications forthe design of the service requested.

237. The Final Decision (App. B, p. 17) further requires Pacific

and the CLECs to negotiate any pricing issues related to

the ancillary equipment and to advise the Director of the

Telecommunications Division of any impasse in the setting

of these prices. Although the issues related to ancillary

equipment have not been fully resolved, the parties

continue to discuss this matter. Pacific’s prices for

ancillary equipment were issued on May 4, 1999 in

Accessible Letter CLECC 99-147. On June 30, 1999, the

CLECs sent a letter requesting information, including how

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the prices were determined. Deere Attachment WW. Pacific will

respond to the CLECs written request for further information.

This concludes my affidavit.

[Signature Page Follows]

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I declare under penalty of perjury that the foregoing

is true and correct to the best of my knowledge.

Executed on _________, 1999.

William C. DeereExecutive Director – Engineering& Planning

STATE OF CALIFORNIACOUNTY OF SAN FRANCISCO

Subscribed and sworn to before me this ______ day of_______________, 1999.

_____________________Notary Public