BEFORE THE WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION


MCImetro ACCESS TRANSMISSION SERVICES, INC.,

 Complainant,

v.

U S WEST COMMUNICATIONS, INC.

 Respondent.	)
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		DOCKET NO. UT-971063
		
		 

 
 
U S WEST'S OPENING BRIEF



July 17, 1998
 
 
 
      


1



TABLE OF CONTENTS


INTRODUCTION  1

LEGAL STANDARDS  1

FACTUAL BACKGROUND  3

SPECIFIC ALLEGATIONS  5
MCI’s COMPLAINT THAT U S WEST HAS PURPOSEFULLY 
BLOCKED ITS ENTRY INTO THE LOCAL MARKET IS WITHOUT 
SUBSTANCE.  U S WEST HAS DEVOTED SIGNIFICANT 
RESOURCES TO PREPARE FOR AND ENABLE INTERCONNECTION  5

MCI CONTINUOUSLY MISREPRESENTS WHAT HAPPENED 
AND IS MISLEADING IN THE PICTURE IT PAINTS REGARDING 
THE DEALINGS BETWEEN THE COMPANIES  7

U S WEST Does Engage in Joint Planning and Forecasting 8

B8ZS Issues 8

NXX Issues 9

Access Tandem Interconnection 9

MCI’s Performance Standards are Meaningless and Misleading 9

U S WEST’S FORECASTING PROCESS IS REASONABLE 10

THE CAPACITY ISSUES CAUSED BY INTERNET USAGE, 
CLEC INTERCONNECTION AND NUMBER PORTABILITY 
COULD NOT HAVE BEEN FORESEEN 12

Internet Usage and Network Capacity 13

CLEC Interconnection 14

Number Portability 15

U S WEST PROVISIONED ADEQUATE FACILITIES 
BASED ON MCI’s FORECASTS 16

PROVISIONING OF FACILITIES 21

Ordering Procedures 21

Provisioning Intervals 21

DIRECT END-OFFICE TRUNKING ISSUES 23

CLEC FORECASTS 24

TRUNK BLOCKING ISSUES RAISED BY EXHIBIT C-123 25

U S WEST WILL PROVIDE MCI NOTICE OF NETWORK 
PROJECTS WHEN REQUIRED – TANDEM EXHAUST IS 
NOT A NETWORK PROJECT 25

ANY CLAIMS BY MCI OF HARM OR DAMAGES 
ARE NOT SUPPORTED ON THIS RECORD 27

RELIEF REQUESTED 28
THE COMMISSION SHOULD NOT IMPOSE PENALTIES 
AS RECOMMENDED BY STAFF 28

U S WEST SHOULD NOT BE REQUIRED TO
PROVIDE ADDITIONAL REPORTS 29

ADDITIONAL RELIEF REQUESTED BY MCI 30

CONCLUSION 33



INTRODUCTION

 This is a complaint by MCImetro Access Transmission Services, Inc. (MCI) 
against U S WEST Communications, Inc. (U S WEST).  U S WEST voluntarily 
negotiated an interconnection agreement with MCI in September of 1995, and 
began providing MCI local interconnection trunks for the exchange of traffic 
shortly thereafter.  The complex, time-consuming, and technically difficult 
process of local interconnection has demanded significant resources, planning, 
and cooperation by both parties to ensure success.  Unfortunately, instead of 
cooperatively working toward a mutually beneficial solution, MCI clearly 
prefers to litigate, both for the political advantage it gains, and for the 
possibility of leveraging the outcome of this and other complaints into civil 
lawsuits and as ammunition against U S WEST’s 271 filings for interLATA relief.
 Once you cut through MCI’s rhetoric, it is clear that the main, perhaps the 
only, issue in this case is the capacity.  As will be seen from the discussion 
below, U S WEST acted reasonably to forecast and provision adequate capacity.  
U S WEST’s forecasting process mirrors the process that MCI uses to forecast 
its capacity needs.  Capacity shortages were the result of circumstances and 
events that could not reasonably have been foreseen, and were exacerbated by 
MCI’s demand for capacity in excess of what it had originally forecast. 
Further, these shortages were generally short-lived, and affected the entire 
network, and all carriers and customers, not just MC