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KEY FACTS REGARDING NEW YORK
- COMPETITION IN NEW YORK
- New York State has some of the most intensely competitive local exchange and local exchange access markets in the nation. This track record of successful competition places Bell Atlanticís section 271 application in a different context than prior filings.
- Competitors in New York serve at least 651,793 lines using their own facilities, 152,055 lines using the UNE platform, and 314,332 lines through resale for a total of at least 1,118,180 lines.
- Competitors in New York serve at least 35,753 residential lines over their own facilities, provide service to 137,342 residential customers using the UNE platform and resell another 63,547 residential lines.
- THIRD PARTY TESTING OF BELL ATLANTIC OSS
- Incumbent LECs use a variety of systems, databases, and personnel (collectively referred to as OSS) to provide service to their customers at a certain level of quality, accuracy and timeliness. The Commission has found that nondiscriminatory access to OSS is a prerequisite to the development of meaningful local competition. For example, new entrants must have access to the functions performed by the incumbentís OSS in order to formulate and place orders for network elements or resale services, to install service to their customers, to maintain and repair network facilities, and to bill customers.
- The New York Commission retained KPMG Peat Marwick (KPMG) to conduct an independent, third-party test of the readiness of Bell Atlanticís OSS, interfaces, documentation and processes. Over the course of fifteen months, KPMG evaluated 855 separate items relating to pre-ordering, ordering, provisioning, maintenance and repair, billing, and relationship management and infrastructure, by performing both transaction and operational tests.
- In performing these tests, KPMG adopted a military-style test philosophy, or a mindset of "test until you pass." Thus, when situations arose where testing revealed that a Bell Atlantic process, document, or system did not meet expectations, Bell Atlantic would generally implement a fix and KPMG would retest the process, document, or system until satisfied.
- To the greatest extent possible, the KPMG test was both independent and blind. For example, KPMG required that all documents provided to them were generally available to all competing carriers. The New York Commission monitored phone calls between KPMG and Hewlett Packard and Bell Atlantic, and competing carriers were invited to attend conference calls. Hewlett Packard acted as a competing carrier information technology group, establishing electronic bonding with Bell Atlantic, translating back and forth between business and EDI rule formats, and resolving problems with missing orders and responses.
- The rigorous, comprehensive third party testing in New York identified numerous shortcomings in Bell Atlanticís OSS performance that were subsequently corrected and re-tested. The pseudo-competitive LEC, KPMG, released its final report on August 6, 1999, concluding that Bell Atlanticís OSS was commercially available and sufficient to handle reasonable, anticipated commercial volumes.
- NEW YORK DEVELOPMENT OF PERFORMANC MEASURES AND STANDARDS
- The New York Commission developed, and continues to refine, inter-carrier performance measures and service quality standards in its Carrier-to-Carrier proceeding. For example, the New York Commission has instituted collaborative proceedings to address xDSL issues and is developing xDSL specific performance measures and standards.
- To ensure that the companyís performance data or "metrics" are reported reliably in accordance with the New York Commissionís definitions, New York staff and KPMG reviewed the adequacy of internal controls surrounding the data collection process. In addition, the New York Commissionís staff verifies on a monthly basis that Bell Atlanticís reported results conform to the definitions developed in the Carrier-to-Carrier proceeding. The definitions and standards developed in that proceeding have done much to foster the development of consistent and meaningful data concerning Bell Atlanticís performance. This gives us greater confidence that our decision is based on performance data that accurately measures Bell Atlanticís actual performance.
- NEW YORK PERFORMANCE ASSURANCE PLAN
- New York has adopted a self-effectuating performance assurance plan that will provide significant financial incentives for Bell Atlantic to maintain an open market and prevent "backsliding" in the future provision of service by Bell Atlantic to competitive LECs.
- The New York Commission is committed to supervising the implementation of these plans.