BEFORE THE WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION In the Matter of the Investigation Into U S WEST ) Communications, Inc.’s Compliance with Section ) UT-970300 271 of the Telecommunications Act of 1996 ) INITIAL STAFF PROPOSAL FOR EVIDENTIARY REQUIREMENTS In compliance with the Commission’s Order on Investigation in this docket, the Staff of the Washington Utilities and Transportation Commission (Staff) has worked informally with other interested parties to develop a recommended content and format for the information U S WEST Communications, Inc. (U S WEST) should file with the Commission to allow a determination of compliance with Section 271 of the Telecommunications Act of 1996. The entities involved in this effort included representatives from U S WEST, Public Counsel, Telecommunications Resellers Association, MCI Communications, AT&T, NEXTLINK, and the Washington Independent Telephone Association. In addition to the documents referred to in the Order, the group reviewed numerous documents from other states, the Department of Justice, the FCC, and other entities in developing these recommendations. The attached Appendix A contains the proposed filing requirements for US WEST. Appendix B contains filing requirements for CLECs. Appendix C is a proposed timeline for these filings and parties’ responses to them. U S WEST has stated its intent to make its 271 filings in a standard format in all states in which it intends to file. That being the case, the filing requirements proposed by Staff and the working group may be included in the documents that the company intends to file at the FCC, or they may not. Therefore, the proposed filing requirements provide for U S WEST to cross-reference its responses to its FCC filing, rather than having to file the same data twice. Staff appreciates the time and effort by the participating entities to assist in this project and welcomes comments on the proposed filing requirements. Dated this 15th day of June, 1998. CHRISTINE O. GREGOIRE Attorney General SHANNON E. SMITH, WSBA No. 19077 Assistant Attorney General Counsel for Commission Defendants 1400 S. Evergreen Park Dr. SW Olympia, WA 98504-0128 (360) 664-1183 ______________________________________________________________________ Appendix A Information Required from U S WEST I. Instructions for U S WEST This appendix is organized in a format which follows section 271 (c) and (d) of the Act. In providing answers to questions posed in this appendix, U S WEST should conform to the following: 1. Pursuant to the Commission's Statement of Policy in Docket UT-970300, US WEST is required to file with the WUTC all information the Company will file with the FCC. Where the answer to a question is addressed within the Company's materials that will be filed with the FCC, the Company must provide an index reference that will enable users to easily locate answers within those documents. It is not necessary for the Company to provide the Commission with duplicative information that is already contained within the materials USWC intends to file at the FCC. 2. The filing should include a table of contents and contain an index that will enable users to easily locate answers in the documents filed. Both the index and the table of contents should be keyed to the structure of this Appendix. Where the answer is contained within the materials to be filed with the FCC, the index should reference the FCC materials. Where the answer is not contained within the materials to be filed with the FCC, the filing should include tabs for any attachments. 3. Answers should focus on quantitatively-based explanations, with accompanying general explanations. Discussions of data sources and techniques should be contained within the attachments or referenced to the materials to be filed at the FCC. Unless otherwise specified in the questions, answers should be interpreted as pertaining to the state of Washington. 4. All evidence and data should demonstrate present compliance, not promises of future compliance. 5. Please note that the generic questions in section V(A) are applicable to all checklist items. II. State of Local Competition, Pursuant to Section III(A), Par. 34 of the Ameritech/ Michigan Order The intent of this section is to gather and submit information to the FCC. For "State of Local Competition" questions, it should be noted that this Commission's consultative role with the FCC is not the appropriate forum to resolve disputes or complaints concerning previous decisions or on-going proceedings. To the best of U S WEST's knowledge, answer the following concerning the state of local competition in Washington: 1. On a statewide and exchange basis, state separately the number of active business and residential access lines with local exchange service provided by U S WEST? 2. On a statewide basis, state separately the number of business and residential customer accounts with local exchange service provided by U S WEST? 3. In terms of both lines and customer counts, what proportion of the local exchange market does U S WEST serve in its service territory? 4. What revenues did U S WEST derive from Washington in 1996 and 1997 from: 1) basic local residential services; 2) basic local business services; 3) intraLATA toll; 4) access charges; and 5) all other types of services? 5. What is the total number and identity of competitive local exchange carriers (CLECs) certified to provide service in U S WEST's service territory? Specify if CLECs are facilities-based, resellers, purchase Unbundled Network Elements (UNE’s) or some combination. Which of these CLECs are actually providing service? 6. What is U S WEST's opinion concerning the likely success or growth rate of CLECs in the local exchange market? 7. What is the number, type, and geographic location of customers in U S WEST’s service territory served by competing providers? III. Section 271(c)(1)(A) - Presence of a Facilities-Based Competitor Section 271(c)(1) of the Act requires the presence of a facilities-based competitor. To determine whether or not U S WEST meets this requirement, answer the following: 1. List the carriers registered by the WUTC as facilities-based CLECs to operate in U S WEST's service territory. 2. Which of the carriers listed above are currently providing service to local customers through: i) using exclusively their own facilities or, ii) a combination of U S WEST's and the competing carrier's facilities, with the latter predominating? Describe how service is being provided (e.g., U S WEST's unbundled loops connected to the CLEC's switch, etc.). 3. To what extent is each CLEC above providing: i) business exchange service; ii) residential exchange service, or; iii) exchange and/ or special access services? State the number of customers actually receiving service in each category and their geographic location. 4. For each of the services described above, indicate whether the services are provided via: i) resale; ii) UNEs; or iii) entirely over facilities owned by the CLEC. Indicate whether the service is provided either exclusively or predominantly over CLEC facilities. 5. How many loops (business and residential), by type (i.e., DSO, DS1), do CLECs lease from U S WEST, both throughout U S WEST's service territory and on an exchange basis? 6. How many line-side switch ports and unbundled local switching elements do CLECs lease from U S WEST, both throughout U S WEST's service territory and on an exchange basis? 7. On a statewide and exchange basis, how many U S WEST loops (business and residential), by size (i.e., DS0, DS1), are connected to a switch owned or controlled by CLECs? 8. On a statewide and exchange basis, how many loops (business and residential), by size (i.e., DS0, DS1), owned or leased by CLECs, are connected to U S WEST switches? 9. List each Central Office (CO) where U S WEST has implemented physical collocation, and indicate the number of collocators in each CO. Give the same information for virtual collocation. If U S WEST has implemented any other collocation options, specify type and CO location. 10. What is the average time for U S WEST to implement physical or virtual collocation? What installation schedule is used? 11. What are U S WEST's collocation rates? How do rates for physical collocation differ from those for virtual collocation? 12. What process does U S WEST utilize to determine if space is available for physical collocation? 13. Provide monthly traffic volumes separated by local and intraLATA toll traffic terminated to all CLECs in the aggregate during the most current three months. IV. Section 271(c)(2)(A) - Interconnection Agreements To determine whether or not U S WEST meets the requirements of Section 271's "Track A", the Commission requests the following information. Information provided in this section should be provided on a Washington state basis. 1. How many interconnection agreements has U S WEST negotiated or had arbitrated with CLECs pursuant to sections 251 and 252 of the Act? List the companies and the effective date of each agreement, and whether or not the agreement was negotiated or arbitrated. Provide copies of the agreements. 2. For all of the arbitrated agreements in #1 above, indicate whether U S WEST has appealed the Commission's decision to Federal District Court. Explain the issues in the appeal and its status. 3. Which CLECs have requested negotiations with U S WEST pursuant to sections 251 and 252, but have not yet entered into interconnection agreements with the company? What is the status of negotiations and/ or arbitrations that have not yet resulted in an approved agreement? What are the unresolved issues in each of those negotiations and arbitrations? 4. How many interconnection agreements has U S WEST negotiated with CLECs pursuant to state WUTC rules which have not been superseded by section 251/ 252 agreements? List the companies and give the effective date of each agreement. 5. What services are CLECs currently purchasing under their interconnection agreements? Show in tabular format, by carrier. 6. Which of U S WEST's interconnection agreeme lines served) CLECs. 7. For those interconnection agreements with implementation schedules, has U S WEST met the commitments specified? Have CLECs met their commitments? Give specific citations to the interconnection agreement and explain which party was responsible for not meeting each commitment. 8. Does U S WEST believe that any of the CLECs, with whom agreements could qualify U S WEST under Track A, negotiated in bad faith? If so, describe. 9. For those interconnection agreements with implementation schedules, does U S WEST believe that any of its competitors are engaging in strategic manipulation of local market entry - or have intentionally delayed implementation of their interconnection agreements - in order to prevent U S WEST from entering the in-region, interLATA market? If so, state the basis for such belief. 10. For each interconnection agreement with a CLEC currently providing service, provide traffic data for all traffic terminated to that CLEC on both a resale and facilities basis. For traffic terminated on a facilities basis distinguish between local and intraLATA toll traffic. All reports should include the three most current months. 11. Please list and describe the status of all suits or actions at law, other litigation, or administrative proceedings of any type, regarding US West’s interconnection practices or policies in the state of Washington. V. Section 271(c)(2)(B) - Competitive Checklist For each section 271 checklist item, U S WEST should provide relevant. detailed information in response to the generic questions below, as well as to the specific questions for each item. A. Checklist Items: Generic Questions For each individual checklist item, answer the following with quantitative information, and in tabular format where possible: 1. Has U S WEST fully implemented this checklist item as required by section 271 of the Act? 2. What performance standards must U S WEST meet regarding the quality, reliability, and timeliness of providing checklist items to CLEC’s, affiliates, and itself? How were these performance standards determined? 3. To whom is U S WEST presently providing, on a commercial basis, this checklist item? 4. Is the quality and reliability of checklist items provided to competitors by U S WEST comparable to the quality and reliability of such items U S WEST provides to itself or its own customers? 5. What technical standards and/or business rules is U S WEST providing to CLECs for each checklist item? Explain the process and scheduling for updating these technical standards and/or business rules. 6. What is the rate of each checklist item? How was the pricing of each item (as applicable) determined? Is pricing equitable? 7. If U S WEST is not currently providing this checklist item, is U S WEST offering the item? If so, how is it offering the item and under what terms, conditions, and rates? Describe how the checklist item is readily available and easily obtained by competitors. 8. If U S WEST is not currently offering this checklist item, is U S WEST capable of commercially providing it? What is U S WEST's anticipated schedule to provide the item? Has any CLEC requested the checklist item? 9. Has U S WEST received any formal or informal written complaints from new entrants regarding provision of this checklist item? If so, what was the nature of the complaint, what is its current status and, if applicable, how was it resolved? For complaints that were found to be valid, what steps did U S WEST take to avoid recurrences? 10. Is U S WEST able to provide this checklist item in all parts of its Washington state service territory? B. Checklist Item One: Interconnection, Section 271 (c)(2)(B)(i) 1. How is U S WEST offering interconnection in accordance with the requirements of sections 251 (c)(2) and 252(d)(1) of the Act? 2. On what dates did any nonaffiliated carriers actually interconnect with U S WEST? 3. At what points within its network does U S WEST provide or offer interconnection? 4. What is the price for interconnection, including all recurring and nonrecurring charges, and is it based on cost as required by section 252(d)(1)? 5. Does U S WEST impose material limitations on interconnection (i.e., one-way trunking, use of different trunk groups for different "types" of traffic, etc.)? 6. Provide comparative performance data for the three most current months on the time required to repair outages for U S WEST’s lines versus the CLECs’ lines. 7. Provide comparative performance data for the three most current months on call completion rates for originating and terminating calls across carriers. C. Checklist Item Two: Nondiscriminatory Access to Network Elements, Section 271 (c)(2)(B)(ii) 1. How is U S WEST providing nondiscriminatory access to unbundled network elements at just and reasonable rates and in accordance with the requirements of sections 251 (c)(3) and 252(d)(1) of the Act? 2. List each CLEC to which U S WEST is selling network elements, the network elements provided, the volume of each network element provided, and the date the element was first provided. 3. At current network capacity, what additional volume of each network element can U S WEST provide to CLECs? 4. Are there any network elements required by this Commission or the FCC that U S WEST does not plan to offer? Please list them and explain why US West does not plan to offer them. 5. For each element U S WEST does not plan to unbundle, has U S WEST demonstrated technical infeasibility and offered any alternative? For each such element, please describe why they are technically infeasible and what alternatives have been offered. 6. What methods can entrants use for physical access to UNEs? 7. Is U S WEST providing access to UNEs in a manner that allows requesting carriers to combine them? Describe the methods for these UNE combinations. Additionally, list all restrictions U S WEST imposes on CLEC requests for combinations of UNEs. List the length of time needed for new entrants to obtain and combine network elements, e.g. time required to build collocation cages; loop cutover times, etc. 8. Are there any UNE elements that U S WEST will offer only in combination (unseparated)? If so, what are they, and why? D. Checklist Item Three: Nondiscriminatory Access to Poles, Ducts, Conduits, and Rights-of-Way, Section 271 (c)(2)(B)(iii) 1. How is U S WEST providing nondiscriminatory access to poles, ducts, conduits and rights-of-way at just and reasonable rates? 2. Does U S WEST provide the same access to these facilities to CLECs as it provides itself? 3. Does U S WEST make available to CLECs its maps, plats, and other relevant data, and what are the terms and conditions of such availability? 4. Describe any municipal (or other type of government) franchise, grant, or additional requirement that affects U S WEST's access to pathways, poles, conduits, and rights-of-way differently from that of unaffiliated carriers. 5. What is U S WEST's policy for reservation of space for its own use? How does this affect access to rights-of-way of competitors? 6. How many competitors gain access to customer dwellings in multidwelling units, including access to interbuilding cabling? E. Checklist Item Four: Unbundled Local Loop Transmission, Section 271 (c)(2)(B)(iv) 1. How is U S WEST offering local loop transmission from the central office to the customers' premises unbundled from switching and other services offered by the incumbent carrier? 2. How many such loops is U S WEST providing each CLEC? F. Checklist Item Five: Local Transport, Section 271 (c)(2)(B)(v) 1. How is U S WEST providing local transport from the trunk side of its or a competing carrier's local exchange carrier switch unbundled from other switching or services offered by the incumbent carrier? G. Checklist Item Six: Local Switching, Section 271 (c)(2)(B)(vi) 1. How is U S WEST offering local switching unbundled from transport, local loop transmission, or other services? H. Checklist Item Seven: 911 and Other Services, Section 271 (c)(2)(B)(vii) 1. How is U S WEST providing nondiscriminatory access to 911 and E91I services? Directory assistance services? Operator call completion services? 2. How is U S WEST trying to resolve any problems it has experienced in integrating CLEC customer information into the 911 system? Discuss what problems, if any, are caused by CLEC error. 3. Please provide data showing the percentage of errors found in CLEC end user information and U S WEST end user information, respectively, and the frequency of updates to the database for CLEC end user information and U S WEST end user information, respectively. I. Checklist Item Eight: White Pages, Section 271 (c)(2)(B)(viii) 1. How is U S WEST providing white page directory listings for customers of the CLEC's telephone exchange service? 2. Under what terms does U S WEST provide white page directory listings? 3. Under what terms does U S WEST provide nondiscriminatory access to basic directory listings for business accounts (name. address, telephone number, and primary business classification)? 4. Under what terms does U S WEST provide: (1) complete content of white page local exchange directory in electronic format; (ii) specific white page directory publication schedules and deadlines; and (iii) specific white page directory publication schedules and delivery dates/ locations? 5. Under what terms does U S WEST deliver white and yellow page directories to customers of new carriers? How do those terms differ from those U S WEST affords itself, its affiliates, or its retail customers? How do they differ from the requirements contained in WAC 480-120-042? J. Checklist Item Nine: Nondiscriminatory Access to Telephone Numbers, Section 271 (c)(2)(B)(ix) 1. How is U S WEST providing nondiscriminatory access to telephone numbers for assignment to other carriers' telephone exchange service customers? 2. Under what terms do carriers, including U S WEST and its affiliates, obtain access to telephone numbers for assignment? 3. How is U S WEST managing limitations in numbering resources (e.g., NXX freezes)? K. Checklist Item Ten: Databases and Signaling, Section 271 (c)(2)(B)(x) 1. How is U S WEST providing nondiscriminatory access to databases and associated signaling necessary for call routing and completion? 2. To which CLECs is U S WEST providing such access, and under what terms, conditions, and rates? 3. Are there any databases that competitors have requested access to that U S WEST is unwilling or unable to supply? 4. Are there any pending requests for access to databases that U S WEST has not granted or completed? L. Checklist Item 11: Number Portability, Section 271 (c)(2)(B)(xi) 1. What methods of interim number portability is U S WEST providing? Specify if it is being offered under tariff or under the terms of specific interconnection agreements 2. To which CLECs is U S WEST providing interim number portability, and under what terms, conditions, and rates? 3. Has U S WEST denied interim number portability arrangements requested by any CLECs? If so, describe the circumstances in detail. 4. What has been U S WEST's operational experience in providing each type of interim local number portability? 5. What are the characteristics of each interim local number portability arrangement, including cost recovery and service quality implications? 6. Is U S WEST going to meet the FCC-mandated implementation schedule for permanent local number portability? If not. why not? 7. If U S WEST does not meet the FCC-mandated implementation schedule for permanent local number portability, how will this affect its ability to provide services to CLECs? M. Checklist Item 12: Dialing Parity, Section 271 (c)(2)(B)(xii) 1. How is U S WEST providing nondiscriminatory access to such services or information, as is necessary, to allow a requesting carrier to implement dialing parity in accordance with the requirements of section 251 (b)(3)? 2. What percentage of U S WEST switches are providing dialing parity to competitors for local calls? 3. What percentage of U S WEST switches, serving what percentage of access lines, have been equipped to provide dialing parity for intraLATA toll calls, and in what percentages of switches, serving what percentage of access lines, has that capability been tested? 4. Will intraLATA toll dialing parity be implemented in such switches using the "full 2-PIC" subscription method, and if not, what method will be used? 5. Does U S WEST plan to provide dialing parity for intraLATA toll calls before, or only coincident with, its provision of in-region interLATA services? Why or why not? 6. After receiving section 271 authorization, when a customer calls U S WEST to establish new local exchange service or to switch the location of its existing service, how does U S WEST plan to have its service representatives inform the customer of their long distance provider options in the manner prescribed in Ameritech/ Michigan and Bell South/ South Carolina Orders (i.e., offering to list the optional providers, using a random order)? Please provide scripts to be used by service representatives to inform customers of their provider options. N. Checklist Item 13: Reciprocal Compensation Arrangements, Section 271 (c)(2)(B)(xiii) 1. How is U S WEST providing reciprocal compensation arrangements in accordance with the requirements of section 252(d)(2)? 2. Describe arrangements for reciprocal compensation, including bill-and-keep, for local exchange traffic between U S WEST and CLECs and other ILECs? 3. For carriers with bill-and-keep arrangements, specify whether bill-and-keep is replaced with explicit compensation arrangements when traffic is not in balance. How is traffic balance determined? 4. For all carriers with explicit compensation arrangements, specify the type of arrangements and rates (i.e., call termination rates). O. Checklist Item 14: Resale, Section 271 (c)(2)(B)(xiv) 1. How is U S WEST providing telecommunications resale services in accordance with the requirements of sections 251(c)(4) and 252(d)(3)? 2. What services are offered for resale to CLECs? What services are not? 3. What is the level of wholesale discount for each service offered for resale? 4. Which vertical features are offered for resale to CLECs? Which are not? 5. What nonrecurring charges, if any, does U S WEST impose on resellers? 6. Does U S WEST impose changeover charges? If so, under what circumstances? 7. What has been U S WEST's operational experience (other than order processing) in providing each service for resale? 8. Will U S WEST brand resold operator call completion and directory assistance services at the reseller's request, or are those services offered on an unbranded basis only? What limitations does U S WEST impose on branding? 9. Does U S WEST provide all operator functions (i.e., operator billing options, rate quotes) on resold operator call completion services? 10. Does U S WEST route, at a reseller's request, operator and directory assistance calls to the reseller's own facilities? 11. Have all retail services (including Centrex and other central-office based switching services) offered by U S WEST after January 1, 1996, been made available for resale? If not, describe any restrictions, including the "grandfathering" of such services. 12. Per discussions in the Bell South/ South Carolina Order, is U S WEST offering Contract Service Arrangements (CSAs) at discount rates? With CSAs, does U S WEST use cancellation penalties? What written complaints, if any, has U S WEST received about CSAs? What resolution has been reached, if any, for CSA complaints? VI. OSS Parity To the extent that quantitative data is provided, U S WEST should explain all calculations and the data time period. A. General OSS Questions 1. What operational support systems (OSS) does U S WEST provide to CLECs? 2. What forms of OSS access are available to CLECs for: i) the purchase of unbundled network elements, ii) the resale of U S WEST retail services, and iii) maintenance and repair? 3. What testing does U S WEST perform on new OSS systems it provides in order to demonstrate that information will be delivered to new entrants in a timely, accurate, and useful manner? 4. Is OSS access provided to Washington CLECs pursuant to uniform interfaces intended for nationwide or region-wide implementation? 5. What is the current capacity for each of U S WEST's OSS systems (i.e., number and type of transactions that can be processed within specific time frames, the number of competitors that can be supported, etc.)? What are U S WEST's plans to expand such capacity? Is this capacity sufficient to meet CLECs’ needs? 6. What steps has U S WEST taken to ensure nondiscriminatory access to OSS for each checklist item? 7. What training has U S WEST provided for each available ordering interface to its own employees? Describe the procedures used for training new U S WEST service representatives on CLEC interface systems. Describe the procedures used for training new U S WEST Service representatives on U S WEST internal OSS systems. What proportion of training time do new representatives spend learning about U S WEST internal OSS systems versus CLEC OSS interfaces? 8. What training has U S WEST (or its subcontractors) provided to CLEC employees on its OSS interfaces? How much are CLECs charged for the training provided? 9. How does the timing for meeting competitor's demands for service compare with the timing under which U S WEST provides such items to itself or its own retail customers? 10. What is the personnel turnover rate at U S WEST's Local Service Center (LSC, specifically for order processors, account representatives, and customer support managers? How long does it take to train each of these types of LSC personnel? At the LSC, is there a mixing of personnel between retail/wholesale operations? 11. Does U S WEST provide integration between U S WEST's interfaces for preordering and ordering functions so that manual re-entering does not have to occur? 12. When completing pre-ordering inquiries and orders, is the information and interface type provided to competitors analogous to what U S WEST provides itself? 13. In the past, how have OSS interface specifications been made available to potential competitors? What system design and general information is U S WEST providing to CLECs about future modifications or design changes which will be necessary for interfacing with upgraded U S WEST legacy and access systems? 14. Are there any functional issues within the interfaces provided by U S WEST that result in more steps or additional time spent by CLECs? (Examples: having to scroll through long lists; ability to utilize "inquiry modes" to validate data before submitting orders, etc.) 15. What is U S WEST's experience with "operational readiness" problems (for example, software system "lock ups" or shut downs)? What are the problems, and how often do they occur? B. Pre-Ordering 1. Does U S WEST provide equivalent access to due dates (the date on which the order is scheduled to be completed) for service installation? Is the method of calculating due dates equivalent to the method U S WEST uses for its retail operations? 2. Does U S WEST provide equivalent access to telephone numbers? Does U S WEST limit the quantity of telephone numbers that a CLEC can reserve in a central office for either an individual customer or on the aggregate basis of all reservations made by a CLEC? Is there an equivalent restriction that applies to U S WEST's retail operations? 3. For pre-ordering information do CLECs have access that is equivalent to that of U S WEST's retail representatives? C. Ordering/ Provisioning 1. How and when does U S WEST provide a new entrant information concerning the status of the new entrant's resale or UNE order? 2. Describe order rejection rates for retail, resale, and UNE orders. For resale and UNEs break down the rates by the type of interface used - both electronic and manual, as well as different software types. 3. For both retail and resale, compare rejection rates for POTS services. 4. How does U S WEST notify a CLEC that an order has been rejected? How long does it take for an order rejection notice to be issued? 5. Provide statistics for loss of dial tone for customers leaving U S WEST and returning to U S WEST, separated on a resale and facilities basis. List the number of customers affected by loss of dial tone an