Agenda Date:  April 28. 1999
Item Number:

Docket:  UT-990261

Company:  Telecommunications-General
   Carrier-to-Carrier Service Quality Rulemaking

Staff:   Rebecca Beaton, Regulatory Consultant
   Glenn Blackmon, Assistant Director-Telecommunications
   David Griffith, Telecommunications Engineer
   Roger Kouchi, Consumer Program Specialist
   Bob Wallis, Review Judge

Recommendation:

Direct the Secretary of the Commission to file the preproposal statement of 
inquiry (CR-101) with the code reviser in Docket UT-990261 on the subject of 
carrier-to-carrier service quality standards.

Discussion:
The Telecommunications Act of 1996 and state law both allowed competition in 
the local exchange market.  Washington has over thirty registered competitive 
local exchange companies providing services in the local market.  Regulations 
were established to enable potential competitive local exchange carriers 
(CLECs) to enter and compete in the local markets.  These CLECs must 
interconnect with the incumbent local exchange company to provide services to 
customers.  Successful competition includes assurance that CLEC customers can 
receive at least equal levels of service to those the incumbent local exchange 
company provides to its own customers.  The timeliness and accuracy of 
information processed by incumbent local exchange companies for pre-ordering, 
ordering, provisioning, maintenance, repair, unbundled elements, and billing 
must be satisfactory. 

Specific carrier-to-carrier service capabilities need to be addressed to allow 
commercially available electronic systems and manual procedures to handle 
competitors’ current and future demand on a nondiscriminatory basis.  
Commission Staff (Staff) proposes opening a rule proceeding to investigate the 
needs of carrier-to-carrier operating requirements. Procedures may need 
standardization and simplification for order and repair functions to occur on 
an equal basis between telecommunications carriers to assure competition is not 
inhibited.  Establishing rules to assure competitors have equal access to an 
incumbent’s network is a key to effective competition in the market, and 
consistency between state and federal rules should be considered and pursued. 
Staff believes that the Commission rule process will allow needed investigation 
and consideration to take place.

Commission Staff anticipates that the rule discussions will concentrate on 
operating support systems (OSS), placing and filling orders, trunk blocking, 
repair, and related issues, but does not foreclose parties from raising other 
concerns.  Staff understands that several states in the western region 
(including Utah and Colorado) and other states (including New York and Texas) 
have initiated rules on these subjects.  There appears to be a body of 
documentation and rule models that the Commission and interested parties may 
consider in the Washington process.  

The rulemaking inquiry also will consider whether any of the performance and 
reporting requirements imposed on U S WEST in the MCImetro complaint case 
(Docket UT-971063) should be applied more broadly, so as to cover incumbents 
other than U S WEST and entrants other than MCImetro.  Staff anticipates 
coordinating a series of informal workshops, soliciting written comments and 
assuring all parties plenty of opportunity to file comments, participate and 
air the issues to the fullest extent.  Staff also expects data collection 
efforts will be important and encouraged for all industry participants to 
become involved and to contribute toward an effective outcome. 

Conclusion:
Staff recommends that the Commission direct that a rulemaking process be 
convened on this topic and that it order the Commission Secretary to file a 
Preproposal Statement of Inquiry (CR-101) to that effect with the code reviser.