******************************************************** NOTICE ******************************************************** This document was converted from WordPerfect to ASCII Text format. Content from the original version of the document such as headers, footers, footnotes, endnotes, graphics, and page numbers will not show up in this text version. All text attributes such as bold, italic, underlining, etc. from the original document will not show up in this text version. Features of the original document layout such as columns, tables, line and letter spacing, pagination, and margins will not be preserved in the text version. If you need the complete document, download the WordPerfect version or Adobe Acrobat version, if available. ***************************************************************** Federal Communications Commission Washington, D.C. 20554 In reply refer to: April 13, 1998 Released: April 13, 1998 Ms. Patricia E. Koch Assistant Vice President, Government Relations - FCC Bell Atlantic Corporation 1300 I Street NW, Suite 400W Washington, DC 20005 Dear Ms. Koch: The Accounting Safeguards Division ("ASD") has found several deficiencies in Bell Atlantic's Performance Monitoring Report ("PMR") submissions filed pursuant to the Bell Atlantic/NYNEX Merger Order. In this letter, we direct Bell Atlantic to revise its PMR definitions and to update its reporting procedures in order to ensure consistency with Appendix D of the Bell Atlantic/NYNEX Merger Order ("Appendix D"). In addition, we address several suggestions presented by Bell Atlantic to improve the definitions of individual metrics. Metric 2: OSS Interface Availability. Bell Atlantic appears to have mislabelled this measurement. Appendix D defines this metric as "% of Time OSS Interface is actually available compared to scheduled availability." Bell Atlantic's subsmissions indicate that this metric is reported in "hours" instead of a percentage. To maintain consistency with Appendix D, Bell Atlantic should revise the label of its subsmissions and report data in this metric as a percentage. Metric 8: Average Offered Interval. In its February 3, 1998 letter, Bell Atlantic suggests that future reports show the average offered interval for "Special Services - Dispatch (Total) for Retail, Resale, and UNE" because the line size breakouts specified in Appendix D do not produce meaningful measures. Specifically, Bell Atlantic noted that the intervals offered for Retail, Resale, and UNE Special Services are based on the product instead of the line size of the order. We believe that this is a reasonable suggestion and, therefore, we permit Bell Atlantic to file PMRs with this modified definition for Metric 8, so long as Bell Atlantic notes the modification on its future submissions. Metric 9: Average Completed Interval. In its February 3, 1998 letter, Bell Atlantic suggests that future reports for Metric 9 show the average completed interval for "Special Services - Dispatch (Total) for Retail, Resale, and UNE" because the line size breakout for special services does not produce meaningful measures. We believe that this is a reasonable suggestion and, therefore, permit Bell Atlantic to file PMRs with this modified definition for Metric 8, so long as Bell Atlantic notes the modification on its future submissions. Metric 11: % Missed Installation Appointment. Bell Atlantic entitled this metric "% Missed Appointment - BA," and reports Interconnection Trunks (11.10 and 11.11) as the percentage of trunks (for north states) and the percentage of orders (for south states). Appendix D of the Order labels this metric "% Missed Installation Appointments." To avoid possible confusion, Bell Atlantic should label this metric consistently with Appendix D of the Order. Additionally, Bell Atlantic should report Interconnection Trunks (11.10 and 11.11) as the percentage of orders for both northern and southern states as specified in Appendix D. Metric 12: Facility Missed Orders. Bell Atlantic entitled this metric "% Missed Appointment - Facilities," and reports Interconnection Trunks (12.07 and 12.08) as the percentage of trunks (for north states) and the percentage of orders (for south states). In Appendix D, this metric is labelled "Facility Missed Orders." To avoid possible confusion, Bell Atlantic should label this metric consistently with Appendix D of the Order. Additionally, Bell Atlantic should report Interconnection Trunks (12.07 and 12.08) as the percentage of orders for both northern and southern states as specified in Appendix D. In its February 3, 1998 letter, Bell Atlantic suggests that the reports for Metric 12 should show the percent of installation appointments missed due to lack of facilities for Retail POTS, Resale POTS, and UNE POTS without further disaggregating the measurements into "dispatch" and "no dispatch" categories. Because this change will increase the accuracy of the reports, Bell Atlantic is permitted to make this minor modification so long as Bell Atlantic annotates this modification on the reports filed with the Commission and provided to third parties. Metric 13: % Installation Troubles within 30 Days. Appendix D defines this metric as "Troubles received on lines within 30 days of service order activity as a percent of lines ordered in 30 days." Bell Atlantic's PMR Definitions describe this metric as reporting the "Percentage of Lines/Circuits/Trunks Installed for which a Network Trouble is reported and found within 30 days of installation (or service order activity)." We require Bell Atlantic to remove the qualifiers "network trouble" and "and found" from its definition, and report data in accordance with the definition in Appendix D. Metric 14: Customer Trouble Report Rate. Appendix D defines this metric as "Initial Customer direct or referred troubles reported within a calendar month where cause is determined to be found to be in the network (not customer premises equipment, inside wire, or carrier equipment) per 100 lines/circuits in service." Bell Atlantic's PMR Definitions describe this metric as reporting troubles on regulated services, but the Appendix D definition does not distinguish between regulated or nonregulated services. Therefore, Bell Atlantic should report all Customer Trouble Reports in accordance with the Appendix D definition. In addition, Bell Atlantic should include a notation in its data submissions for metric 14 identifying the unit of measurement as "per 100 lines/circuits in service." Metric 15: Missed Repair Appointments. Appendix D defines Metric 15 as the percent of Trouble Reports not cleared by the date and time committed, excluding misses where the competing carrier or end user causes the missed appointment. Bell Atlantic modifies the definition of Metric 15 with the phrase "Initial Customer Trouble Reports found to be network troubles." We require Bell Atlantic to remove the modification "Initial Customer Trouble Reports, found to be network troubles (Disposition Codes 3, 4, and 5" from its PMR Definitions, and report all Missed Repair Appointments except those explicitly excluded by Appendix D. Metric 16: Mean Time to Repair. Appendix D defines Metric 16 as the "[a]verage duration time from receipt of trouble report to clearing of trouble report." In its submissions, Bell Atlantic notes that it will report on "Initial Customer Trouble Reports found to be network troubles." We require Bell Atlantic to remove the qualifiers "Initial Customer Trouble Reports," and "found to be network troubles," and report the average duration of time to clear a trouble report as specified in Appendix D. Additionally, because Appendix D requires that special circuits and trunks be reported as "Stop Clock," Bell Atlantic should report metric 16.08 Interconnection Trunks as Stop Clock instead of "Total Hours." Metric 17: Out of Service > 24 Hours. Appendix D defines this metric as "the percent of troubles cleared in excess of 24 hours." Bell Atlantic's submissions describe this metric as reporting the "percentage of network troubles." Bell Atlantic's submissions further note that the "Out of Service period commences when the trouble is entered into BA's designated trouble reporting interface." We require Bell Atlantic to remove the qualifier "network troubles" from its definition and to report data in accordance with the definition in Appendix D. In addition, Bell Atlantic should measure the "Out of Service period" from the time they receive the trouble report in accordance with our ARMIS procedures, instead of when the trouble report is entered into Bell Atlantic's system. Metric 18: % Repeat Trouble Reports within 30 days. Appendix D defines this metric as "Trouble reports on the same line/circuit as a previous trouble report within the last 30 calendar days as a percent of total troubles reported." Bell Atlantic's PMR Definitions modifies this definition by reporting troubles that originated as a disposition code other than CPE or a customer code that has an additional trouble within 30 days for which a network trouble is found. We require Bell Atlantic to remove the qualifiers "other than CPE," and "for which a network trouble is found," and report data in accordance with the Appendix D definition. Metric 19: % Common Trunk Blocking. Bell Atlantic erroneously reported Dedicated Final Trunk Blockage in this metric. We require Bell Atlantic to correct this error and report the percentage of Common Trunk Blocking exceeding the engineering design blocking standard of B.005. We also direct Bell Atlantic to specify in its submissions that Metric 19 reports data using the design blocking standard of B.005 only. Metric 20: % Dedicated Final Trunk Blocking. Bell Atlantic erroneously reported Common Final Trunk Blockage in this metric. We require Bell Atlantic to correct this error and report the percentage of Dedicated Final Trunk Blocking exceeding the engineering design blocking standard of B.01. We also direct Bell Atlantic to specify in its submissions that Metric 20 reports data using the design blocking standard of B.01 only. We recognize that the data collection systems deployed in the northern states may be different than those used in the southern states, and that these systems may be the reasons behind certain differences in the way Bell Atlantic reports PMR data. Reporting measurements in a uniform manner, however, is absolutely critical for Commission staff to analyze and evaluate the PMR data. Therefore, we expect Bell Atlantic to standardize its reporting procedures and measurements between northern and southern states as soon as possible. For those PMRs that are not yet standardized, such as Metric 11 and Metric 12, Bell Atlantic should provide a plan, including an implementation schedule, for reporting the PMR data for the northern and southern states in a uniform manner. As a final matter, we expect Bell Atlantic to provide revised submissions of the PMRs within a reasonable time after receipt of this letter. Because resubmitting the PMRs may require Bell Atlantic to reference the raw data underlying the November 12, 1997 and February 17, 1998 filings, Bell Atlantic should take immediate steps to revise its PMR submissions, which may require keeping the raw data for longer than the 150 day period stated in Appendix D. If you have any questions concerning this letter or would like to discuss the issues addressed, please feel free to contact Anthony Dale at (202) 418-2260. Sincerely, Kenneth P. Moran Chief, Accounting Safeguards Division Common Carrier Bureau, FCC