*Pages 1--6 from D:\Pdf2Text\Ready4Text_in\pdf\8119.pdf* Gordon Ft. Evans Vice President Federal Regulatory March 8,200l 1300 I Street, NW, Suite 400 West Washington, DC 20005 Phone 202 515- 2527 Pager 888 802- 1069 Fax 202 336- 7922 gordon. r. evans@ verizon. com Ms. Dorothy Attwood Chief- Common Carrier Bureau Federal Communications Commission 445 12 Street, SW, Fifth Floor Washington, DC 20554 Dear Ms. Attwood, This letter requests that the Commission authorize Verizon to stop providing Performance Monitoring Reports pursuant to Appendix C of the Bell Atlantic/ NYNEX Merger Order, 12 FCC Red 19985 (1997), effective immediately. The Carrier- to- Carrier Performance. Assurance Plan implemented pursuant to the Bell Atlantic/ GTE Merger Order provides more comprehensive, detailed, and accurate measures of Verizon’ s performance than do the Bell AtlanticMYNEX reports. Granting this request will conserve the Commission’ s resources. The Cornmission’ s ability effectively to monitor Verizon’ s performance will not be diminished by granting this request. Background Verizon provides quarterly Performance Monitoring Reports concerning the se& ice it provides to CLECs and to its retail customers as a condition of the Commission’ s approval of the Bell AtIantic/ NYNEX merger in 1997. The reports are provided 45 days after the end of each calendar quarter, and include performance results for fewer than120 measures in 22 categories. These measures were developed in 1997 at a time when competition in the local telecommunications market was at an early stage. Verizon also provides monthly performance results concerning the service it provides to CLECs and to its retail customers pursuant to the Carrier- to- Carrier Performance Assurance Plan (Plan) adopted as a condition of the Commission’ s approval of the Bell Atlantic/ GTE merger in 2000. The reports are provided 25 days after the end of each month, and include performance results, underlying volumes, as well as statistical information and “z- scores” where applicable, for approximately 160 measures in 17 categories. In addition, the Bell Atlantic/ GTE Plan specifies performance standards for each measure and, beginning with April 2001 performance, Verizon may be required to make voluntary payments to the U. S. Treasury if reported performance results do not meet specified thresholds. 1 The Bell Atlantic/ GTE Plan (for the former Bell Atlantic service areas) is based on the New York Performance Assurance Plan adopted by the New York Public Service Commission (PSC) in 1999, which became effective upon Bell Atlantic’ s entry into the long distance market in New York. The New York PIan inchtded the measures that the New York PSC determined were most important to competition from the Carrier- to- Carrier measures that had been developed through a two- year (and continuing) collaborative process with the CLECs under the auspices of the New York PSC. In approving the New York $27 I application, the Commission found that the New York Plan “provide[ s] strong assurance that the local market will remain open after Bell Atlantic receives section 271 authorization.” New York 271 Order, I429. I. The Bell Atlantic/ GTE Carrier- to- Carrier Performance Assurance Plan Provides The Commission With More Information Than The Bell AtlanticNYNEX Performance Monitoring Reports Attachment A provides a side- by- side comparison of the performance measure categories reported as part of the Bell Atlantic/ NYNEX Performance Monitoring Reports and those reported as part of the Bell Atlantic/ GTE Carrier- to- Carrier Performance Assurance Plan. As is evident, the Bell Atlantic/ GTE Plan includes measures for key areas of performance that are not measured under the Bell Atlantic/ NYNEX reports. These are Hot Cut Loops, Collocation, and Line Sharing. Moreover, even for the categories that overlap, the Bell Atlantic/ GTE Plan provides substantially more information in a number of areas than do the Bell Atlantic/ NYNEX reports. First, the Bell Atlantic/ GTE Plan provides a substantially greater level of disaggregation. Second, the Bell Atlantic/ GTE Plan provides more detail concerning each reported result. Finally, the Bell Atlantic/ GTE Plan specifies standards for the included measures, and provides self- executing remedies should Verizon’ s performance fall below the specified standard; the Bell AtlanticMYNEX reports do not specify standards or provide remedies. A. Disaggregation . . The Bell Atlantic/ GTE Plan disaggregates the measurement categories included in the Plan according to significantly more products than do the Bell AtlanticMYNEX reports. A few examples will demonstrate the difference: Pre- Ordering: The Bell Atlantic/ NYNEX reports include only two Response Time results - for CSRs, and for all other pre- ordering transactions in the a,, DoTegate. In addition, they include only a single interface. By contrast, the Bell Atlantic/ GTE Plan reports Response Time results separately for six pre- ordering transactions - CSRs, Due Date Availability, Address Validation, Product & Service Availability, Telephone Number Availability & Reservation, and Loop Qualification. In addition, the Bell Atlantic/ GTE Plan reports each of these response time results for each of the three different interfaces available to CLECs - EDI, CORBA, and the Web GUI. 2 Ordering: The Bell Atlantic/ NYNEX reports include order confirmation and reject timeliness results for Resale orders and for UNE orders. The results are disaggregated based on the number of lines on the order. The Bell Atlantic/ GTE Plan reports order confirmation and reject timeliness results separately for Resale POTS & Pre- qualified Complex Services, Resale 2- wire Digital Services, Resale 2- wire xDSL Services, Resale Special Services, UNE POTS & Pre- qualified Complex Services, UNE 2- wire Digital Services, UNE 2- wire xDSL Services, and UNE Special Services. Again, results are disaggregated based on the number of lines on the order. Provisioning: In the Bell Atlantic/ NYNEX reports, Verizon reports the Percent Missed Appointments measure for Retail POTS and Special Services; Resale POTS and Special Services; UNE POTS and Special Services; and for Retail (D( C) Trunks and Interconnection Trunks. The three POTS measures are disaggregated between dispatch and no dispatch orders. The Bell Atlantic/ GTE Plan, by contrast, includes Percent Missed Appointments for Resale POTS, Resale 2- wire Digital Services, Resale 2- wire xDSL Services, Resale Special Services; UNE POTS New Loops, UNE POTS Platform, UNE Special Services Total, UNE Special Services EEL, UNE Special Services IOF; and Interconnection Trunks. In addition, the Bell Atlantic/ GTE Plan includes Percent On Time (which is the inverse of the Percent Missed Appointments) measures for UNE Hot Cuts, UNE 2- wire Digital Services, UNE 2- wire xDSL Services, Physical Collocation, and Virtual Collocation. Where there is a “retail” analog, Verizon also reports its own (or its separate data affiliate’ s) performance. The POTS, 2- wire Digital, and 2- wire xDSL measures are disaggregated between dispatch and no dispatch orders (for UNE POTS, this is only relevant for Platform orders). Maintenance & Repair: The Mean Time to Repair measure in the Bell Atlantic/ NYNEX reports is reported for Retail POTS and Special Services; Resale POTS and Special Services; UNE POTS and Special Services; and for Retail (IXC) and Interconnection Trunks. The Mean Time to Repair measure in the Bell AtIantic/ GTE Plan is reported for Resale POTS & Complex; Resale Special Services; UNE Loops, UNE Platform, UNE 2- wire Digital, UNE 2- wire xDSL, UNE Special Services; and Interconnection Trunks. Where there is a “retail” analog, Verizon also reports its own (or its separate data affiliate’ s) performance. The POTS & Complex, Loop, Platform, 2- wire Digital, and 2- wire xDSL measures are disaggregated between troubles found in the loop and those found in the central office. As the foregoing makes clear, the Bell Atlantic/ GTE Plan measures provide a much greater level of product specificity than do the Bell Atlantic/ NYNEX reports. B. Reporting Detail The Bell Atlantic/ GTE Plan provides more information for each measure and provides the information in a more timely manner than do the Bell Atlantic/ NYNEX reports. The Bell Atlantic/ NYNEX reports include only the performance results for each measure. By contrast, 3 the Bell Atlantic/ GTE Plan provides, in addition to the results, the “observations” - or volumes - for each measure, the standard associated with the measure and, where the standard is p, tity, the z- score, standard deviation, and sampling error. Further, the Bell Atlantic/ NYNEX reports are submitted quarterly (including three months’ performance), 45 days after the end of each quarter. The Bell Atlantic/ GTE Plan reports are submitted monthly, 25 days after the end of each month, and therefore provide the Commission with more current information. II. The Commission’ s Ability To Monitor Verizon’ s Performance Will Not Be Harmed By Terminating The Bell Atlantic/ NYNEX Reports. As shown in Attachment A, there are only a few measures reported in the Bell Atlantic/ NYNEX reports that are not included in the Bell Atlantic/ GTE Plan. The Commission has already determined that several of these measures are flawed. The others are not necessary for the Commission’ s oversight of Verizon’ s performance, as is clear from their absence in the more comprehensive and up- to- date plans in place. As a result, the absence of these measures for the remaining months of the Bell AtlanticiNYNEX reports will not diminish the Commission’ s ability to monitor Verizon’ s performance. The first of these measures - Percent Rejects - is not included in the New York Performance Assurance Plan, on which the Bell Atlantic/ GTE Plan was modeled, because it is largely a measure of the care with which CLECs complete the Local Service Requests they send to Verizon, not Verizon’ s performance. For this reason, the Commission did not accord it significant weight in the New York 271 Order (q 175), and its absence from the Bell Atlantic/ GTE Plan will not diminish the Commission’ s ability to monitor Verizon’ s performance. The second group of measures are two categories of interval measures - Average Interval Offered and Average Interval Completed, including Percent Completed within 5 Business Days. The Commission has already determined in the New York. 27 1 Order, based on evidence submitted by Verizon, that these measures measure “factors outside of [Verizon’ s] control and unrelated to the timeliness and quality of [Verizon’ s] provisioning . . . to competing carriers.” As a result, the Commission determined that the interval measures were “flawed and therefore, should be accorded little weight in our analysis here.” (¶ 202) For the same reasons, the New York PSC did not include average interval offered or average interval completed measures in the New York Performance Assurance Plan, on which the Bell Atlantic/ GTE Plan was modeled, and their absence will not meaningfully affect the Commission’ s ability to monitor Verizon’ s performance. The third measure - Percent Common Trunk Blocking - also is not included in the New York Performance Assurance Plan. Common trunks carry traffic between Verizon end offices and the Verizon access tandem, including local traffic for both Verizon customers and CLEC customers. Since these trunks carry traffic for both Verizon and CLEC end users, any blockage will affect both Verizon and CLECs. As a result, there is “parity by design” and no purpose is served by measuring these trunk groups. 4 Similarly, the process measured in the fourth measure -Timeliness of Daily Usage Feed - is the same process through which usage detail is produced for retail. And the fifth measure - Timeliness of Completion Notification - measures a process that, as defined, is of little real concern to the CLECs. As such, it is no longer included in the New York Performance Assurance Plan. III. Conclusion . The Bell Atlantic/ GTE Carrier- to- Carrier Performance Assurance Plan provides an expanded set of measures and substantially more useful, current and accurate information than the Bell Atlantic/ NYNEX reports. Moreover, beginning with the April performance month, Verizon will be subject to remedies under the Bell Atlantic/ GTE Plan if its performance does not meet the specified standards. Given these facts, it makes little sense for the Commission to continue to devote resources to the Bell Atlantic/ NYNEX reports, or to require Verizon to continue to devote its resources to producing (or CLECs their resources to reviewing) these redundant and superceded reports. For these reasons, Verizon requests that the Commission authorize Verizon to stop providing Performance Monitoring Reports pursuant to Appendix C of the Bell Atlantic/ NYNEX Merger Order, effective immediately. Sincerely, Attachment cc: A. Dale C. Mattey M. Stone . . 5 Attachment C 1 BA/ GTE 1 BAAVYNEJ yes yes yes yes yes yes yes yes yes yes yes yes yes no no yes no no Metric ^^^ - onse Time ; Avalability - - tion Timeliness Order Contmna Reject Timeliness Percent Rejects Timeliness of Completion Notification Percent Flow Through Average Offered Interval Average Completed Interval ] Percent Completed within 5 Days Missed Appointments Facility Missed Orders Installation Quality Hot Cut Loops yes yes yes yes no yes yes yes yes yes Line Sharing Trouble R - eport Kate Missed Repair Appointments Trouble Duration Intervals *~ n* gt Trouble Reports - &Blocking iroup Blockage no yes yes yes yes yes yes yes yes yes yes yes no yes I Collocatic - - w Performance Timeliness of Daily Usage Feed Timeliness of Carrier Bill no yes VP9 yes no “PC BA/ NYNEX Metrics Not Included in W/ GTE: l Percent Rejects l Timeliness of Completion Notification l Average Offered and Completed Interval l Percent Common Trunk Blocking l Timeliness of Daily Usage Feed . . . BAfGTE Metrics Not Reported in BAfNYNEX: l Hot Cut Loops l Line Sharing l Collocation Performance 6