WPC  2=BAJX Z|xTimes New Roman (TT)Arial (TT)Courier New (TT)Symbol (TT)C\  P6QPJ2PQP"d6X@DQ@4a\  P[AP2J?oBHphoenix#XX2PQXP# 271 affidavits: Stacy Draft 3 AssociateTKiehn 2|6Default Paragraph FoDefault Paragraph Font11#XP\  P6QXP##XX2PQXP#CourtNameCourtName;1#Z6X@DQ@##XX2PQXP#footerfooterX` hp x (# !"  !" X` hp x (#page numberpage number11#XP\  P6QXP##XX2PQXP#2"  headerheaderX` hp x (# !"  !" X` hp x (#annotation referenceannotation reference11#6\  P6QP##XX2PQXP#annotation textannotation text;1#I2PQP##XX2PQXP#1e!2x` xdd footerX` hp x (# !" #XP\  P6QXP#page number#XP\  P6QXP##XX2PQXP#"page number"eX` hp x (# !"  footer !" p` P @ 0 p`P@0  !"X` hp x (#p` P @ 0 p`P@0  !"Before the  X FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of ) ) Application by BellSouth Corporation, )CC Docket No. _______ BellSouth Telecommunications, Inc.,) and BellSouth Long Distance, Inc., for)  Provision of InRegion, InterLATA ) Services in South Carolina)  AFFIDAVIT OF WILLIAM N. STACY William N. Stacy, being duly sworn, deposes and says: I.PROFESSIONAL EXPERIENCE 1. My name is William N. Stacy. I am employed by BellSouth Telecommunications, Inc. ( BellSouth). My business address is 675 West Peachtree Street, Atlanta, Georgia 30375. I am the Assistant Vice President Services for the Interconnection Operations department of BellSouth Telecommunications, Inc. (BST). In this position, I am responsible for development of the procedures used by BST personnel to process Competitive Local Exchange Carrier (CLEC) service requests, and for assisting the service centers in Interconnection Operations in implementing CLEC contracts in a manner consistent with State Commission and Federal Communications Commission ( FCC) rules and regulations governing local exchange competition. I have held numerous positions with BST in Network Engineering, Operator Services, Network Planning, and Network Operations. II.PURPOSE OF AFFIDAVIT 2. This declaration will address how BellSouth has adopted and committed to performance measures with which to compare BellSouths retail and wholesale in providing and maintaining services that are provided to both retail and wholesale customers; and to measure performance as a necessary prerequisite to demonstrating compliance with the Commissions nondiscrimination and meaningful opportunity to compete standards. 3. BellSouth believes that its existing performance measurement obligations are more than adequate to allow the commission to verify that BellSouth is providing CLECs with facilities and services in accordance with the nondiscrimination and meaningful opportunity to compete requirements, and will continue to do so. I will address BellSouths proactive efforts to develop wholesale and retail comparative measurements, and BSTs contractual commitment to performance measures through individual CLEC agreements. By way of introduction, I will describe the overall organizational structure and processes BellSouth has put in place to provide services to all CLECs. III.BELLSOUTH CLEC SUPPORT STRUCTURE  4. In order to meet its statutory and regulatory obligations, BST began development work in May, 1995 to create a process for handling the provisioning, maintenance and repair of all interconnection facilities, resold services, and unbundled network elements (UNEs) provided to the CLECs. Since that time, BST has created an entire new officer level organization, Interconnection Operations, which is responsible for all operational aspects of provisioning and maintaining services for CLECs. For resale and unbundled network element ordering, two Local Carrier Service Centers (LCSCs), located in Birmingham and Atlanta, serve as contact points for CLECs ordering services for resale or UNEs for facility based service offerings, and offer 24 hours per day, 7 days per week service. The following customers are supported by the Atlanta Center: AT&T, MCI, OPC, Intermedia, Nextlink and Georgia Comm South. All other CLECs are supported by the Birmingham Center. A Customer Support Manager is assigned to each CLEC in the centers to provide a single liaison point if the CLEC customers have operational issues that are not satisfactorily resolved by the normal center processes. 5. The Birmingham and Atlanta LCSCs are functionally equivalent. This arrangement provides a redundant (backup) capability to maximize efficiency and minimize volume surge impacts. The centers have the technology and systems support to share work. Each has the same systems access and the ability to handle the various service requests. The training path for Service Representatives is the same for each center. Depending upon the employees previous background and experience within BellSouth, training time for a Service Representative to handle resale orders could be less than 6 weeks. If the Service Representatives will be processing UNE orders, additional complex training is required. 6. The centers have also developed contingency plans to handle spikes in ordering volumes. The plan primarily addresses the use of overtime, sharing work between centers and utilizing other internal resources trained to process CLEC orders. Any difference in capacity or capability between the Birmingham and Atlanta centers is due to Atlanta currently handling primarily resale orders. Birmingham receives more unbundled network element (UNE) orders from the CLEC group it supports, and UNE orders require more time to handle. More detail regarding LCSC capacity and capability is discussed in my OSS affidavit. 7. Additionally, due to the complexity of managing services provided to CLECs large business customers, BST established a group of project management specialists as a separate part of each LCSC to provide project coordination for this type of activity. Finally, for daytoday provisioning activities for unbundled network elements, BST established UNE Centers staffed with highly trained technicians to coordinate the provisioning activities required to install the various UNE products. These groups and centers were staffed with a total of 422 people as of September, 1997, and staffing will increase as market needs dictate. 8. For provisioning of end user services, CLECs can place orders directly through one of the several electronic interfaces which BST has made available, or manually with the LCSC. These are discussed in detail in my OSS affidavit.    9. Provisioning and maintenance of local interconnection trunking is provided by BSTs Access Customer Service Centers (ACSCs), which are also part of the Interconnection Operations division. The ACSCs have provided similar services to the Interexchange Carriers (IXCs) for several years. BST technicians in the ACSC directly interface with the CLECs to perform turnup, testing, and repair of interconnection facilities. These technicians must pass a complex technical test to fill these positions. In addition, BST has a customized training curriculum which qualifies technicians to support facilitybased CLECs. The CLEC é specific training period for these employees is approximately 29 days, in addition to many months of basic equipment and service training. 10. In the case of maintenance and repair, CLECs can submit trouble reports for resold services, interconnection facilities, and unbundled network elements directly through one of the electronic interfaces or manually to the appropriate repair center. 11. BST is committed to provide all of these operations centers with sufficient resources to meet the demands of the CLECs. Additional managers and support personnel have been added to the existing centers and will continue to be added as needed to support increased CLEC activity. BST has forecasts of expected transaction/order volumes gathered directly from our CLEC customers by the BST account team responsible for each individual CLEC account. This information allows us to project ordering volumes, provisioning volumes, and trouble reporting volumes from the CLECs based upon BSTs own experience. Staffing initiatives, internal and external hiring, and training have been deployed to enable BST to effectively respond to CLEC provisioning and maintenance expectations. More detailed descriptions of the roles, responsibilities, and capacities of each of these centers are included in the my OSS affidavit and in the DOJ Operational Readiness Report, Exhibit WNS51 of my OSS affidavit.   IV.INTRODUCTION AND USE OF MEASUREMENTS 12. BellSouth realized in early 1996 that the Communications Act would have a tremendous impact on the way it provides service to its customers. The opening of the market to wholesale customers creates many challenges in the area of measurements which reflect whether CLECs receive the same quality of service as BSTs retail customers.  13. To enable effective ongoing production of measurements which monitor parity and provide meaningful data on a readily available basis, BellSouth has implemented a Data Warehouse. BellSouths existing Operations Support Systems (OSS) run on main frame computers, and computers are aligned by state/states in most instances and have multiple processors. An example of this is the Work Force Administration (WFA) system. WFA, which is used for provisioning and maintenance of designed services, has 7 processors. The query systems on the main frame computers are not flexible and cannot be easily manipulated to produce the measurements required to monitor parity between retail and wholesale customers. The Data Warehouse was developed as a system to meet this need. 14. Data in the newly designed system is loaded from mainframes and combined into regional databases. Every order processed by BellSouth for both its retail units and its CLEC customers is captured for analysis. Standard Query Language (SQL) queries are written against the databases to produce the measurements. These SQL queries provide the ability to recreate measurements that are currently in place on the mainframe systems and easily separate the retail and wholesale services results for reporting purposes. 15. BellSouth plans to provide CLECs with access to the Data Warehouse where CLECs specific results can be obtained. All measurements described p` P @ 0 p`P@0  !"` p`P@0  !"in this affidavit will be available in the Data Warehouse.   ` p`P@0  !"p` P @ 0 p`P@0  !" 16. BellSouth has utilized this data to produce reports in three different formats as our negotiations have progressed. These formats are described in this Affidavit and the Exhibits as:  p` P @ 0 p`P@0  !"Tp` P @ 0 p`P@0  !"Initial measurements Those measurements historically used by BST and applied to both BST and CLECs. AT&T measurements Those measurements contractually agreed to with AT&T. Tp` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !"Permanent measurements A set of generally available measures based on the AT&T measurement set with some additions and offered as additional support to demonstrate BellSouths commitment to performance measures. p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !" 17. BellSouth took an aggressive approach to creating a baseline set of parity measurements to enable the monitoring of levels of service provided to CLECs while the development of a full scope of parity measurements proceeded. Initial measurements became available in March of this year using February performance data. By measuring and monitoring these parity measurements, BST had the ability to identify, analyze, and address any perceived instances of disparity. BST has also produced and utilized the reports in various Public Service Commission (PSC) activities and hearings. V.SOUTH CAROLINA INITIAL PERFORMANCE MEASUREMENT REPORTS 18. A complete set of these reports for CLEC and BST operations in South Carolina is shown in Exhibits WNS1, WNS2, and WNS3 for the first 8 months of 1997. Examination of this data reveals that BST is providing services to the CLECs at parity with those provided to its retail operations in South Carolina and in the other BST states. While these reports are nonCLEC specific, individual based CLEC reports will be provided in accordance with the terms and conditions of individual CLEC Contracts.  NATURE OF DATA RESALE PARITY REPORT (EXHIBIT WNS1) 19. The data for these reports is grouped into categories that BST has historically used to manage its own performance for Residence services and Business services.  1. 1. 1. 1. 1. 1. 1. 1.p` P @ 0 p`P@0  !"rp` P @ 0 p`P@0  !" The percent of due dates met in provisioning orders for service rp` P @ 0 p`P@0  !"rp` P @ 0 p`P@0  !"The trouble report rate per 100 access lines in service The percent trouble reports which are resolved in less than 24 rp` P @ 0 p`P@0  !"wp` P @ 0 p`P@0  !" hours wp` P @ 0 p`P@0  !"w` P @ 0 p`P@0  !"The average duration in hours of the interval from receipt of a trouble until it is cleared The percent of missed appointments for maintenance reports w` P @ 0 p`P@0  !"wp` P @ 0 p`P@0  !"The percent of repeat trouble reports received on the same line received within 30 days The percent trouble reports within thirty days of installation of wp` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !" new service.  20 . For each of these categories, I have shown the performance for CLECs in South Carolina, for all CLECs in BSTs ninestate region, and comparable total data for all of BSTs retail customers. In addition, beginning in the month of June, the two resale categories were further disaggregated into two subcategories, Non Dispatch and Dispatch Out.  These new subcategories were added as we began to move from the initial set of measures to an arbitrated and negotiated measurement set that I will discuss in detail later in this affidavit. Finally, beginning with the month of July, I have shown data for BST in South Carolina. PERFORMANCE DATA CONCLUSIONSRESALE PARITY REPORT 21. In every category, it is clear that the CLECs have received service which is comparable to, and which is in most cases better than, the service received by BSTs retail customers. 22. While performance for CLECs in South Carolina is generally consistent with the overall performance to CLECs in the ninestate region, comparing overall performance to CLECs in the ninestate region with performance to BellSouths retail customers provides a more statistically stable view. I have highlighted the best performance in each regional category by showing that value in bolded, underlined text. These values confirm that CLECs customers are indeed receiving service at least in parity with or better than is provided to BellSouth retail customers    NATURE OF DATA LOCAL INTERCONNECTION TRUNKING/UNBUNDLED LOOPS    (EXHIBITS WNS2 AND WNS3)   23. The Local Interconnection Trunking Report (Exhibit WNS2) shows the following:  1. Total number of trunks in service as of the end of that month.   2. Number of trunk orders processed that month. 3. The number of order due dates missed (either due to the CLEC, or the CLECs end user, or for BellSouth reasons). 4. The percent order due dates met on time excluding customer misses. 5. The percentage of new circuit failures (Any failure in a trunk group    within 30 days of installation). 6. The total number of troubles in that month. 7. The average repair interval of troubles in hours.  24. The Unbundled Loops Report (Exhibit WNS3) shows the same data as the Local Interconnection Trunking Report but has one additional measure: Repeated Trouble Reports Within 30 Days.  PERFORMANCE DATA CONCLUSIONS LOCAL INTERCONNECTION TRUNKING/ UNBUNDLED LOOPS   25. In 7 of 8 months, CLEC interconnection trunks were installed on time or at a significantly better percentage than for trunks BellSouth installed for its retail customers. Specifically, January CLEC results were better than BellSouths (99.9% to 86.7%), worse in February (77.3% to 86.0%), but better in all the following months: March (97.8% to 88.5%), April (100.0% to 83.6%), May (98.9% to 91.2%), June (97.9% to 89.9%, July (99.4% to 89.9%) and August (100.0% to 94.9%). 26. Although no direct comparison to BST services is possible, unbundled loops were installed on time at a rate no lower than 86.8% (April) and as high as 100% in January with 6 of 8 months above the 90% level.. 27. The New Circuit Failure Rate on local interconnection trunks was better for CLECs than BellSouth retail customers for 6 of 8 months. Specifically, CLEC results were better in January (0.0% to 0.7%), February (0.0% to 0.5%), better in March (0.1% to 0.2%) and April (0.0% to 0.5%), worse in May (0.6% to 0.5%), better in June (0.0% to 0.5%), worse in July (1.1% to 0.3%) but better in August (0.0% to 0.4%).  p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !"VI.BELLSOUTHS CONTRACTUAL COMMITMENT TO PERFORMANCE MEASUREMENTS  p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !"28. During the period that the previous reports were being produced, BellSouth continued to negotiate and arbitrate specific performance measurements with various CLECs. As a result of these negotiations, BST and AT&T, on May 9, 1997, reached agreement on performance measurements and filed those measurements with the Georgia Public Service Commission. Those measurements included both the parity measures and nondiscriminatory access to systems and services measures. This specific agreement was signed in Georgia, but both parties agreed to extend its provisions to all nine states where BST provides services as an ILEC. This agreement was incorporated into the interconnection agreement between BST and AT&T filed with the South Carolina Public Service Commission and approved as effective on June 2, 1997. (Reference: Attachment 12, Paragraph 1.4 of the BellSouth AT&T Agreement, Exhibit WNS4.) BellSouth delivered to AT&T the August results on September 14, 1997, for the initial set of agreed to measurements. BST is willing, and in fact, continues to negotiate performance measurement obligations with other CLECs. A similar agreement was reached with Time Warner on September 5, 1997, which is also included as Exhibit WNS5. 29. In the BST and AT&T agreement, percentage target performance levels were not provided for some measurements, such as provisioning intervals for UNEs. BST and AT&T agreed to meet to discuss establishment of such targets quarterly, starting no later than ninety (90) days after actual performance occurs.   p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !"VII.ESTABLISHMENT OF COMPARATIVE MEASUREMENTS FOR EXISTING RESALE SERVICES p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !"   30 . For the AT&T measurements, BST proposed the use of statistical process control measures to determine whether those services are being provided at parity, and this approach was approved by the South Carolina PSC. BST performance data historically have variations from month to month due to many factors, such as severe weather, damage to our facilities, or other events that could not be anticipated. It is therefore important to study performance results over several months to determine what the acceptable upper and lower limits for various performance measures should be. This is done by plotting the monthly results on a graph or control chart. This creates a picture of the performance. Once data has been collected for a number of months, generally at least six, upper and lower levels of performance can be established. 31. The proposed reporting format uses the historical and current performance of BST as the standard to establish statistical process control parameters, using the process control chart format. After BSTs performance is used to establish the basic parameters (average, upper control limit, lower control limit) of the control chart, the services BST performs for all CLECs would be superimposed on this same chart. Once control limits are established, a comparison can easily be made between the BST data and the CLEC data. This type of comparison will be made for each agreed to group of services where BST provides similar retail services to its retail customers. 32. When reviewing comparative data (BST compared to CLECs) on a control chart, as long as the monthly performance is within the established upper and lower limits there generally would not be any concern unless one of the entities, i.e., a CLEC, for three consecutive months was higher or lower than the other entity, or a single monthly measure was outside a control limit. This would merit an investigation or a study, referred to as root cause analysis, to determine the reason for the consistent variation. Once this has been accomplished, a plan for corrective action would be initiated. This method of analyzing data avoids overreacting to insignificant variations and focuses on processes to insure consistent performance.  33. BSTs retail operations track service performance results on a companywide, and statewide basis, for groups of customer services. In general, the groups are separated in two ways; first, by the type of customer, i.e. consumer, small business, or large business; and second, by the type of service provided, i.e., POTS (also referred to as nondesigned), and designed or special services. BSTs proposed and negotiated measures for services provided to both CLECs and to BST retail units generally follow this pattern. 34. For the provisioning and maintenance measures, the groups of service to be measured and the specific measures to be applied to each group are listed in the table in Exhibit WNS6. Where the table entry SPC (Statistical Process Control) is shown, BST believes that sufficient historical data exist to establish statistical process control measures by September, 1997. Where IP (In Process) is shown, historical BST data do not exist, and the CLEC results will be produced without direct comparison to BST. p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !" VIII.ESTABLISHMENT OF MEASUREMENTS FOR UNBUNDLED NETWORK ELEMENTS THAT BST PROVIDES ONLY TO ITS CLEC CUSTOMERS p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !" 35. BST recognizes that insufficient historical data exists to establish process control measures for unbundled network elements it provides only to CLECs. BST has agreed to begin measurement of that data, and to continue to discuss targets as I indicated earlier. As suggested in various regulatory activities, BellSouth pursued the availability of winback data to assist in comparing UNE performance results between BST and the CLECs. However, no data is currently available from the retail units for such an analysis. 36. BST has published a set of target intervals for provisioning UNEs (Exhibit WNS7) and recently finalized a similar set of target intervals for maintenance of UNEs. (Exhibit WNS7A) These intervals will be used to establish the provisioning and maintenance due dates for the UNE categories, and will allow us to begin to generate the data for future SPC measurements. Until sufficient data are collected for each service category, BST proposes using negotiated measures to set estimated values for the average, the upper control limit, and the lower control limit, and to adjust these as additional data becomes available. The time period to accumulate statistically valid data for each category is a function of the CLECs ordering volume in each state and in each service category, and cannot be accurately predicted at this time. p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !"IX.ESTABLISHMENT OF COMPARATIVE MEASUREMENTS FOR LOCAL INTERCONNECTION TRUNKING SERVICES BELLSOUTH PROVIDES TO ITS CLEC CUSTOMERS p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !" 37. In addition to the measurements for resold services and unbundled network elements, BellSouth provides three groups of measurements related to local interconnection trunking. 38. The measurements for provisioning and maintaining local interconnection trunks parallel the resold service measurements in the sense that direct comparisons can be made between services provided to CLECs and those provided for the BST retail units. These measurements (provisioning and maintenance) are identical to the initial measurement set and are provided in Exhibit WNS2. 39. In addition to these measurements, BellSouth has received questions from various regulatory agencies regarding blocking of the trunking network interconnecting the facilitybased CLEC network to BellSouths network. The complexity of the interconnected networks makes this a somewhat difficult concept to explain. I will discuss the basis for this measurement in detail after I discuss the other measures agreed to in the AT&T Agreement which provides the platform for BSTs permanent measurements. X.MEASUREMENTS IN THE AT&T AGREEMENT 40. The AT&T agreement added several items to the set of initial measures by regrouping the service categories (Resale, UNE and Local Interconnection Trunking) into Dispatch Out and NonDispatch categories. Additionally, measures for billing, database access and accuracy, and account maintenance were developed specifically for AT&T. 41. As I indicated earlier, these measurements are defined in the BST AT&T agreement, (Exhibit WNS4) and are further explained in Exhibit WNS8. XI.DEVELOPMENT OF PERMANENT MEASUREMENTS 42. Based on knowledge and experience gained through CLEC negotiations, PSC activities, and other regulatory proceedings, the current measurements were developed. February through August measurement results for the BellSouth region (where available) are shown in Exhibit WNS9. State level data is being collected, but is not yet available . 43. Below is a summary description of these measurements.  All Services (Measured against individual total CLEC orders) Provisioning Order Reject/Error Notice (not available at this time) Provisioning Firm Order Confirmation (not available at this time) Resale Service Measurements   1. 1. 1. 1. 1. 1. 1. 1.p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !"% Provisioning Appointments Met p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !"% Troubles Within 30 days of New Service order being completed p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !"% Maintenance Appointments Met Maintenance Average Duration Receipt to Clear % Repeat Troubles Within 30 Days % Out of Service < 24 Hours % Trouble Report Rate Answer Time p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !" Resale Service Measurements Categories: p` P @ 0 p`P@0  !"` @ 0 p`P@0  !"CLEC Total by State BST Total by State CLEC Total Region BST Total Dispatched Out / Non Dispatched ` @ 0 p`P@0  !"p` P @ 0 p`P@0  !" Local Interconnection Trunking p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !"% Due Dates On Time % New Circuit Failure Rate Within 30 Days of New Service Order being completed Average Duration of Trouble (Responsible Duration) % Trouble Report Rate Answer Time p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !" Local Interconnection Trunking measurement categories:  p` P @ 0 p`P@0  !"` @ 0 p`P@0  !"CLEC Total by State BST Total by State CLEC Total Region BST Total ` @ 0 p`P@0  !"p` P @ 0 p`P@0  !"   Unbundled Network Elements Loop (UNE)  p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !"% Due Dates On Time % New Circuit Failure Rate Within 30 Days of New Service Order being completed(Currently Available) Average Duration of Trouble (Responsible Duration) """"""""1% Repeat Troubles Within 30 Days """"""""% Trouble Report Rate Answer Time p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !"  UNE (Loop) Measurement categories: p` P @ 0 p`P@0  !"` @ 0 p`P@0  !"CLEC Total by State CLEC Total Region ` @ 0 p`P@0  !"p` P @ 0 p`P@0  !" Unbundled Network Elements (NonLoop, Number Portability) p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !"% Provisioning Appointments Met % Troubles Within 30 Days of New Service Order Being Completed % Maintenance Appointments Met Maintenance Average Duration Receipt to Clear % Repeat Troubles Within 30 Days % Out of Service < 24 Hours % Trouble Report Rate Answer Time p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !"  UNE (nonloop) Measurement categories p` P @ 0 p`P@0  !"` @ 0 p`P@0  !"CLEC Total by State CLEC Total Region ` @ 0 p`P@0  !"p` P @ 0 p`P@0  !"  XII.RESALE SERVICE MEASUREMENTS CONCLUSION 44. Of the 28 Resale Service Measurements, 6 were within the upper and lower limits established, 7 were below the lower control limits (which actually indicates better performance results for the CLECs), and 1 was above the upper control limit (which also indicates better performance results for the CLECs). 45. Of the remaining measurements, only one measurement (% Provisioning Business NonDispatch) was out of range three consecutive months; however, the average year to date results for the CLECs is only .08 percentage points below BST year to date results. 46. Measurements Within Control Range: % Provisioning Appointments Met Business Dispatch Out % Maintenance Appointments Met Residential Dispatch Out % Maintenance Average Duration Residential Non Dispatch % Trouble Report Residential Dispatch Out % Provisioning Troubles Residential Non Dispatch % Out of Service Residential Dispatch Out  47.. Measurements Above Control Range ( Indicates Better Service to CLECs): % Provisioning Appointments Met Residential Non Dispatch 48.. Measurements Below Control Range Which Indicates Better Service to CLECs: Maintenance Average Duration Residential Dispatch Out Maintenance Average Duration Business Non Dispatch % Maintenance Repeat Troubles Residential Non Dispatch % Trouble Report Rate Residential Non Dispatch % Trouble Report Rate Business Non Dispatch Out % Provisioning Troubles Residential Dispatch Out % Provisioning Troubles Business Dispatch Out p` P @ 0 p`P@0  !"p`P@0  !"49. Measurements With Combinations (Both above and below range, with overall results indicating better service to CLECs): p`P@0  !"p` P @ 0 p`P@0  !" Maintenance Average Duration Business Dispatch Out % Maintenance Repeat Troubles Business Dispatch Out % Maintenance Repeat Troubles Business Non Dispatch % Trouble Report Business Non Dispatch % Provisioning Troubles Business Non Dispatch % Out of Service Business Non Dispatch % Out of Service Business Dispatch Out  p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !" 50. Measurements Below/Above Range (Indicates CLEC Results Lower Than BST Results): p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !" % Provisioning Appointments Met Residential Non Dispatch (CLEC results 0.33 percentage points lower than BST) % Provisioning Appointments Met Business Non Dispatch (CLEC results 0.08 below the LCL) % Maintenance Appointments Met Residential Non Dispatch (CLEC results 0.53 percentage points below LCL) % Maintenance Appointments Met Business Dispatch Out (Only one month out of control range year to date regional CLEC results within range) % Maintenance Repeat Troubles Residential Non Dispatch (CLEC year to date results 3.74 percentage points higher than BST)  51. Our initial analysis on these five measurements indicates these results are not significantly different except for % Provisioning Appointments Met Residential Non Dispatch. In that case, the results are impacted by the number of CLEC caused errors. These errors, which are detected in the provisioning process, create manual intervention and delays.  XIII.SERVICE ORDER INTERVAL MEASUREMENTS 52. During our discussions of this and future filings with the Department of Justice, they indicated that it would be useful for their evaluation of these measurements if BST were to produce data on the actual intervals for provisioning various services. BST has produced this data, and the measurement is defined and results produced in Exhibit WNS10. However, BST has not agreed to incorporate this data in the results regularly produced for the CLECs or state commissions, since the set of % Provisioning Appointments Met data already indicates BSTs performance in this area.  PERFORMANCE DATA CONCLUSIONS SERVICE ORDER INTERVALS 53. CLEC interval performance for dispatched orders (for residence and business) is better than overall BST performance. The Residence NonDispatch results indicate better service order interval results for BST. However, in assessing this, one should take into account the volume of CLEC caused errors which create manual handling and clarification by BST before the order can be corrected and released. The length of time it takes for a CLEC to respond to clarifications, on errors detected after the order is issued, has a direct impact on service order intervals. CLEC data on volume and response time for clarifications are discussed in my OSS affidavit and shown on the LCSC Weekly Operations Report referenced in the OSS affidavit. Following is a summary which indicates whether BST or the CLEC had better performance in a given month by order type. Details are shown in Exhibit WNS10. The  below indicates substantially equal levels of performance for both BST and the CLECs. SERVICE ORDER INTERVALS COMPARISON  TVZZV m @@@VZZV m @@@T        C ORDERSRESIDENCEBUSINESS hVZZVu@@@@@VZZVu@@@@@h "      "NONDISPATCHDISPATCHNONDISPATCHDISPATCH"      ""      "April CLECCLECBSTCLEC"      "MayܩCLECܩCLEC"      "JuneBST BSTBSTCLEC"      "July BSTܩBSTBST"          "AugustBSTܩBSTBST  TVZZV m @@@VZZV m @@@T        N ORDERSRESIDENCEBUSINESS hVZZV@@@@@VZZV@@@@@h "      "NONDISPATCHDISPATCHNONDISPATCHDISPATCH"      ""      "AprilBSTCLECCLECCLEC"      "MayܩCLECCLECCLEC"      "JuneܩCLECܩCLEC"      "JulyܩCLECܩCLEC"          "AugustBSTCLECCLECCLEC TVZZV m @@@VZZV m @@@T        T ORDERSRESIDENCEBUSINESS hVZZV@@@@@VZZV@@@@@h "      "NONDISPATCHDISPATCHNONDISPATCHDISPATCH"      ""      "AprilCLECCLECBSTBST"      "MayCLECCLECܩܩ"      "JuneCLECCLECBSTBST"      "JulyCLECCLECBSTܩ"          "AugustCLECCLECBSTBST 54. Additionally, Exhibit WNS10B and WNS10C provide average service order interval results for BST and the CLECs. Again, overall performance results reflect nondiscriminatory performance.  p` P @ 0 p`P@0  !"` @ 0 p`P@0  !"XIV.BST/CLEC TRUNK INTERCONNECTION/BLOCKAGE MEASUREMENTS ` @ 0 p`P@0  !"p` P @ 0 p`P@0  !"55. BellSouth has compiled an extensive set of measurements to demonstrate that calls through the BST network to CLEC customers are provided with nondiscriminatory access that is subject to the same design and implementation as the access provided to BellSouths retail end users. Since the trunking network is a complex set of interconnected interoffice paths, some background is essential to help understand these measures. p` P @ 0 p`P@0  !"` @ 0 p`P@0  !"PRECLEC TRUNKING ARCHITECTURE ` @ 0 p`P@0  !"p` P @ 0 p`P@0  !"56. In the preCLEC trunking architecture, BST had a twotier trunk network. One tier was for interLATA and intraLATA toll traffic. The other tier was for local service traffic. The two tiers did not interconnect with each other. The first set of trunk groups interconnect the end offices, access tandems, and other network nodes, such as IXC (Interexchange Carrier) POP (PointofPresence) that are used for interLATA/intraLATA toll traffic. The second set interconnect the end offices and local tandems that are used for local traffic. An interLATA or an intraLATA toll call could not use a trunk group in the local service tier, nor could a local service call use a trunk group in the interLATA/intraLATA toll tier. This was true even in locations where the access tandem used for the interLATA/intraLATA toll network is the same one used for the local tandem network. 57. There are two types of trunk groups; highusage and final. A highusage trunk group is usually between two end offices and is sized to overflow its excess traffic to a final trunk group interconnected with a tandem. A final trunk group does not overflow its excess traffic load to another trunk group. Instead, it provides an All Circuits Are Busy announcement for the excess calls. A final trunk group should have a DBO (Design Blocking Objective) which is an expression of the probability of blocking for calls offered it. The exception to this is a trunk group used to connect operator answering positions with a switch. Although the latter is a final trunk group, it is sized according to the number of positions, rather than the probability of blocking. 58. All of the final trunk groups in BellSouth use a DBO of 1.0% (10 calls out of 1000) during the TCBH (Time-Consistent Busy Hour) of the trunk group. The only exception to this is on trunk groups carrying firstroute interLATA calls through an access tandem. The DBO for these trunk groups is 0.5% (5 calls out of 1000) blocking during the TCBH of the trunk group. Thus, a final trunk group carrying firstroute interLATA traffic between the access tandem and an end office or IXC POP has a DBO of 0.5%. All other final trunk groups (between end office and local tandem, or end office to end office) have a DBO of 1.0%. 59. The reason why trunk groups carrying firstrouted interLATA traffic have a lower blocking objective is to meet BSTs equal access obligations as outlined at the time of the AT&T Divestiture. Equal access included the following: p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !"a. Equality in number of digits dialed by the end user. p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !"b.Equality in Probability of Blocking for traffic between the BST end office and an IXC. p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !" p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !"c. Equality in transmission quality. p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !" 60. At Divestiture, the AT&T trunk groups had a DBO of 1%. In most locations, the toll switch went to AT&T. BST had to establish access tandems to concentrate and distribute traffic since it was not economically justifiable for every IXC to establish a trunk group to every end office in the LATA. Thus, blocking equality was defined as 1% blocking for firstroute between the end office and an IXC POP. With the interjection of the access tandem, 0.5% became the DBO for the trunk group between the end office and the access tandem, and also for the trunk group between the access tandem and the IXC POP. The two halves of one percent added back up to 1% blocking between the end office and IXC POP. p` P @ 0 p`P@0  !"` @ 0 p`P@0  !"PostCLEC Trunking Architecture ` @ 0 p`P@0  !"p` P @ 0 p`P@0  !" 61. In the interest of establishing service with the CLECs as quickly as feasible, BST made a decision to interconnect with the CLECs at the interLATA/intraLATA tier of the trunk network rather than the local tier even though almost all of the calls are local. The interLATA/intraLATA tier was initially chosen for the following reasons: p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !" a. Much of the information that a CLEC needs for interconnection are the similar to the ones for used by the interexchange carrier industry. This information has been maintained in mechanized databases since Divestiture in order to facilitate interconnection between BST and the interexchange carriers. For example, vital data elements associated with the proper routing of a call on a trunk group are available for the interLATA/intraLATA toll tier of the network, but not for the local service tier. This routing information is in a mechanized system supported by Bellcore Traffic Routing Administration organization. One standard output product is the LERG (Local Exchange Routing Guide) which is used by the IXCs to determine where to route the NPANXXs for the calls IXCs handoff to BST. Bellcore enhanced their software capabilities in order for BST to load some data elements on the local service tier of the network into the LERG. p` P @ 0 p`P@0  !"(` @ 0 p`P@0  !" (` @ 0 p`P@0  !"p` P @ 0 p`P@0  !"b. Better ability to properly record the call for billing purposes. The access tandems and end offices associated with the interLATA/intraLATA tier of the network were equipped to properly make a record of the calls for billing purposes. Similar capabilities were not provided for the local service tier. Proper recording reduces both the number of artificial factors that must be developed, and billing disputes that must be resolved. p` P @ 0 p`P@0  !"r` @ 0 p`P@0  !" c. Better ability to provide 64CCC (Clear Channel Capability), which is required to process ISDN calls. Almost all of the tandems in the interLATA/intraLATA tier of the network are newer and of the digital type which can provide 64CCC. Many of the local tandems are older and of the analog type, which cannot provide 64CCC. r` @ 0 p`P@0  !"(` @ 0 p`P@0  !" (` @ 0 p`P@0  !"rp` P @ 0 p`P@0  !" d. Better trunking blocking objectives in most instances since the traffic is generally routed on the interLATA/intraLATA tier of the network in BST. As indicated in paragraph 24, the DBO is 0.5% instead of 1.0% for the local service tier. rp` P @ 0 p`P@0  !"` @ 0 p`P@0  !" ` @ 0 p`P@0  !"p` P @ 0 p`P@0  !" 62. The basic trunk network interconnecting BST with a CLEC consists of the following trunk groups: p` P @ 0 p`P@0  !"` @ 0 p`P@0  !" ` @ 0 p`P@0  !"p` P @ 0 p`P@0  !"a. A oneway trunk group from a BST end office switch or access tandem to the CLEC end office switch. This trunk group is for local & intraLATA toll traffic from BST end users to CLEC end users. From the inception of local service interconnection with CLECs, BST has allowed a trunk group to be directly connected between a BST end office and a CLEC end office switch. Usually the direct end office trunk is a high-usage trunk group overflowing to a final group interconnected with the tandem. BST is primarily responsible for sizing this trunk group which it orders from a CLEC. It is also responsible for the transport facilities to get the calls to the CLEC. The CLEC charges BST a MOU (Minutes of Use) fee for the traffic terminating to it on this trunk group. p` P @ 0 p`P@0  !"` @ 0 p`P@0  !" ` @ 0 p`P@0  !"p` P @ 0 p`P@0  !"b. A oneway trunk group from a CLEC end office switch to a BST end office switch or access tandem. This trunk group is for local & intraLATA toll traffic from CLEC end users to BST end users. From the inception of local service interconnection with the CLECs, BST has allowed a trunk group to be directly connected between a CLEC end office switch and a BST end office switch. Usually the direct end office trunk is a highusage trunk group overflowing to a final group interconnected with the tandem. The CLEC is primarily responsible for sizing this trunk group which it orders from BST. It is also responsible for the transport facilities to get the calls to BST. BST charges the CLEC a MOU fee for the traffic terminating to it on this trunk group. p` P @ 0 p`P@0  !"` @ 0 p`P@0  !" ` @ 0 p`P@0  !"p` P @ 0 p`P@0  !"c.A twoway trunk group between a CLEC end office switch and the BST access tandem. This trunk group is for transient traffic between CLEC end users and nonBST end users in that local calling area. The CLEC is primarily responsible for sizing this trunk group which it orders from BST. It is also responsible for the transport facilities to get the calls to or from BST. BST charges the CLEC a MOU fee for the traffic (originating or terminating to the CLEC) traversing this trunk group. The value added by BST on this trunk group is in switching the call with other carriers (Non-Bell, other CLECs, Interexchange Carriers, etc.) The twoway charge is primarily for the use of the access tandem in switching the call. The CLEC could interconnect directly with another party and thus bypass the tandem switching charge. p` P @ 0 p`P@0  !"` @ 0 p`P@0  !" ` @ 0 p`P@0  !"` @ 0 p`P@0  !"d.There are other trunk groups interconnecting BST with the CLECs. These are primarily for E911, and other services requested by the CLEC, such as, operator services, directory assistance, intercept, etc. ` @ 0 p`P@0  !"` @ 0 p`P@0  !" ` @ 0 p`P@0  !"p` P @ 0 p`P@0  !"63. BST has some trunk groups in the network that are associated with the trunk groups listed above, but are not ordered by CLECs. These are the CTTGs (Common Transport Trunk Groups) which interconnect the end office with the access tandem. Although these trunk groups primarily handle interLATA and intraLATA toll traffic, most of the CTTGs began handling local traffic as CLECs interconnected with BST at the access tandem. As mentioned in paragraph 24 and earlier in this paragraph, the DBO for the CTTGs is 0.5%. 64. Associated with the DBO is the MBT (Measured Blocking Threshold) which is the upper limit of blocking for a trunk group using that DBO. Since the trunking tables used in sizing final trunk groups are probability tables, there are statistical variances around the DBO. Measured blocking above the MBT is considered to be above the statistical tolerance limits of the algorithms used in trunk sizing. Listed below are the two DBOs used in BST and their associated MBTs: p` P @ 0 p`P@0  !"` @ 0 p`P@0  !"Design Blocking ObjectiveMeasured Blocking Threshold 1.0%3.0% 0.5% 2.0% ` @ 0 p`P@0  !"p` P @ 0 p`P@0  !" 65. Thus, any measured blocking of 3% or less in the timeconsistent busy hour is considered to be within the tolerance limits for a trunk group with a DBO of 1%. p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !" p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !"66.The following DBOs are used for the trunk groups listed in above. p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !" a.Oneway trunk group from a BST end office switch or access tandem to the CLEC end office switch: 1.0%. p` P @ 0 p`P@0  !" @ 0 p`P@0  !"  @ 0 p`P@0  !"p` P @ 0 p`P@0  !" b.Oneway trunk group from a CLEC end office switch to a BST end office switch or access tandem: 1.0%. p` P @ 0 p`P@0  !" P @ 0 p`P@0  !"  P @ 0 p`P@0  !"` P @ 0 p`P@0  !"c.Twoway trunk group between a CLEC end office switch and the BST access tandem: 0.5%, since it carries firstroute interLATA traffic through an access tandem. ` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !" p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !" Generally, the company with trunk sizing responsibility determines the DBO. p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !" p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !" 67. Since the first CLEC interconnection almost two years ago, the BST network architecture has evolved to where the CLEC can choose one or more of the following options in addition to the original ones listed in Paragraph 25 p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !" a.The oneway trunk groups can now be ordered as a twoway trunk group. The other twoway trunk group in Paragraph 25 remains a separate twoway trunk group. The other trunk group remains as is. b.All three trunk groups in Paragraph 62 can now be ordered as a single twoway trunk group. The other trunk groups remain as is. c.A CLEC can have trunk groups to only one access tandem instead of all of the access tandems in the LATA. A CLEC choosing this arrangement could decrease its call completion rate due to additional trunk groups involved in completing the call. d.A CLEC can have its trunk groups carrying local traffic interconnect at the local tandem. This is identical to the twotier network used by BST for interLATA/intraLATA toll and local service as mentioned in Paragraph 25. Trunk Service Performance Measurements  p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !"68. BST collects traffic measurements on the trunk groups interconnected with the CLECs as well as all other trunk groups in the network. The measurements are processed weekly through a mechanized system which calculates the percent blocking during the time-consistent busy hour. 69. On any oneway trunk group from the CLEC to BST, the blocking calculated by the mechanized system in BST will not be as accurate as those that are twoway or oneway from BST to the CLEC. This is due to technical constraints since BST cannot mechanically collect Peg Count and Overflow measurements, which are required to more accurately determine blocking. Peg Count and Overflow measurements are collected only at the originating end of the trunk group, which, for BST, would be a twoway or a oneway trunk group from BST to the CLEC. On a oneway trunk group from the CLEC to BST, all BST can collect is usage, which the system then uses to determine a theoretical blocking. This latter blocking is called theoretic since it was not calculated from Peg Count & Overflow measurements. It was derived by using only usage measurements and going backwards through the trunk capacity algorithms to determine the level of blocking. Also, due to the distortions caused by using only usage measurements on very small size trunk groups of two trunks or less, these groups are not included in service performance results. 70. The following categories are used in evaluating trunk group service performance on final trunk groups. (There are no trunk group service performance results for highusage trunk groups since a highusage trunk group overflows its excess traffic load to a final.): p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !" p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !"a.CLEC Local Service Trunk Group Interconnection This category contains the service performance results of final trunk groups between the CLEC switch and a BST tandem or end office. It is subdivided into two components, one for trunk groups ordered and administered by BST, and the other for trunk groups ordered and administered by CLECs. Starting with the June 1997 service period, BST began compiling trunk group service performance results for this category. Exhibit WNS11 contains a summary of the monthly results from June, 1997 to August, 1997. Exhibit WNS11A contains details on the four trunk groups ordered and administered by BST that are shown on the August, 1997 summary report. b.BST Local Service Trunk Group This category contains the service performance results of final trunk groups in the BST local service tier of the network. It includes trunk groups between the end office and the local tandem as well as final trunk groups between end offices. These trunk groups carry local service traffic for the BST retail customers. Starting with the June, 1997 service period, BST began compiling trunk group service performance results for this category. Exhibit WNS12 contains a summary of the monthly results from June, 1997 to August, 1997. Exhibits WNS12a 12c contain the details for each of those months. The results for Georgia may be inaccurate due to database errors. Many of their trunk groups were converted from finals to highusage for the Olympics. Due to the massive changes, the records may not properly reflect that change and be shown as a final even though its highusage overflowing to another final. c. CTTG (Common Transport Trunk Group) This category contains the service performance results of final trunks between the BST end office and BST tandem. As previously mentioned in paragraphs 24 and 25,these trunk groups primarily handle interLATA and intraLATA toll traffic. As mentioned in paragraph 25, the CTTGs began carrying local traffic between the access tandem and BST end offices with the advent of CLEC interconnection. p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !" p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !"71. Each month, two reports showing the CTTG trunk service performance results are sent to all interested parties. This report has been distributed since the mid1980s. Most of the recipients, both then and now, are IXCs since these trunk groups are used predominantly to transport calls between IXCs and end offices homing on the access tandems. Interested CLECs can receive a copy of these two reports which shows the following: p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !" p` P @ 0 p`P@0  !"` P @ 0 p`P@0  !"i.Onepage Statistical Summary for BST and for NonBell Entities. This report contains the following: ` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !" Total number of CTTGs Total number of CTTGs with measurements and processed mechanically Percent of CTTGs with data Total number of CTTGs with blocking exceeding the MBT p` P @ 0 p`P@0  !"` P @ 0 p`P@0  !"ii.A floppy disk datafile containing all of the CTTGs. The file is formatted in accordance with industry standard interface requirements as specified in Bellcore Special Report SR STS000317. Listed below are some of the information for each CTTG that are contained in the datafile: ` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !" Name of the Trunk Group Trunks InService Percent Blocking p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !"Busy Hour Number of Days of Data Used to Calculate the Blocking DBO (Design Blocking Objective) & MBT (Measured Blocking  Threshold) Number of Consecutive Reports the CTTG Was Reported with  Blocking Date of the Data Period Remarks Explaining the Blocking p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !" 72. A summary of the CTTG monthly trunk service performance results is sent to the FCC annually. This was sent quarterly until it was changed recently to an annual reporting. The data to the FCC is contained in Lines 180190 of the FCC Report 4305 ARMIS Service Quality Table 3. 73. Exhibit WNS13 contains the BST CTTG results for the period from January, 1997 through August, 1997. 1996 and prior years are available either from BST or the FCC. Exhibit WNS13a contains the details for the August, 1997 report month. Details for other months are available. 74. In most locations, traffic from a BST end office to the CLEC end office or from the CLEC end office to a BST end office, will go on a direct trunk group if there is one, or switch through the access tandem. If the call is switched through the access tandem, it would traverse the CTTG between the access tandem and end office. Thus, service performance results from the CLEC Local Service Trunk Group Interconnection (Exhibit WNS11) and CTTG (Exhibit WNS13) categories will provide a good assessment on the quality of the service provided on trunk groups carrying traffic to CLECs. This could then be compared to the service performance results for BST Local Service Trunk Group (Exhibit WNS12). p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !" p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !"Analysis of Trunk Service Performance p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !" p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !"75. For the last 13 months from July, 1996 to July ,997 the BST CTTG service performance results have been less than 1% of the trunk groups exceeding the MBT of 2.0% for each trunk group. (Several years ago, the industry established an objective of 2% or less, to be met on a companywide basis by the Local Exchange Carriers. No objective for individual state subdivision was established due to the smaller universe. BST is farexceeding the industry objectives.) 76. Looking at the most recent data (August, 1997) from Exhibit WNS11, BST had four trunk groups with blocking in excess of the MBT of 3%. All four groups incurred blocking due to one or more of the following reasons: p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !"a.the CLECs not telling BST in sufficient time to add trunks to the network b.the CLECs not ready to add the trunks as ordered by BST p` P @ 0 p`P@0  !"` P @ 0 p`P@0  !"c. the CLECs had a very long lead time of several weeks before being able to turn up trunks. ` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !" p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !"77. As mentioned previously, Exhibit WNS11a contains additional information regarding these four trunk groups. For all four trunk groups, the traffic load increased dramatically in a short period of time. When a BST end user dials a local call, they do not know if the distant end is a BST, CLEC, or nonBell LEC end office. All the end user wants is for BST to complete the calls without any undue blocking. If not, they would perceive BST and not the CLEC or nonBell carrier as providing inadequate service. Anytime there is a trunk blockage, it becomes a critical matter for BST to alleviate. The same attention, if not more, is made for trunk groups carrying traffic to a CLEC switch as for other trunk groups in the BST network. 78. Exhibit WNS11a suggests, for the four trunk groups, that if better communication of anticipated volumes was provided to BST, and/or if quicker turnup of trunks to BST by the CLECs occurred, the blocking problems would be quickly alleviated. We realize that there will be tremendous growth in the CLEC interconnection market. BST has met almost all of the CLEC trunk requirements in the time frames requested by the CLECs. Often, that is not the case with the CLECs. For example, in one state, BST submitted orders with a due date of April, 1997 for the establishmentt of 408 trunks in seven trunk groups. As of September 15, 1997, none of the trunks had been established. 79. For the four trunk groups referenced above, the trunks being added were in the hundreds per trunk group. This type of growth is very unusual in the existing BST network; nevertheless, as in this instance, BST strives to add the trunks as quickly as possible. In some locations, trunks cannot be added due to shortage of facilities and/or equipment. Thus, there is a great need for the CLECs to provide BST with their plans on network expansion. BST will continue to work with the CLECs on this endeavor. 80. Exhibit WNS12 shows that on a companywide basis, the BST local trunk service performance for its retail customers indicates between 1.7% to 2.7% of the trunk groups experience blocking above the MBT of 3%. Those numbers (1.7% to 2.7%) could double (3.4% to 5.4%) if the BST retail customers call had to go through a local tandem. If the nonGeorgia numbers were used, the range would be 1.1% to 3.0% instead of 1.7% to 2.7%. 81. BST has provided detail trunk group blocking information regarding its network for the CLECs as well as for its retail customers. Information provided includes percent blocking, size of trunk groups, and, busy hour. From the data, one can determine the magnitude of the trunk blockage. When comparing data for traffic switching through a tandem, one cannot simply add the trunk blocking for one trunk group to the trunk blocking for another group unless the two trunk groups had the busy hour in the same time period. For example, one trunk group on one side of the tandem had a busy hour of 10 a.m. during the month with blocking of 2.5%. The trunk group on the other side of the tandem had a 10 p.m. busy hour during the same time period with 1.5% blocking. For a call traversing those two trunk groups, the blocking is not 4.0% (2.5% + 1.5%). It is less than that, and possibly none at all, if the call is placed during one of the other hours. 82. Comparing the trunk service performance results from the CLEC Local Service Trunk Group Interconnection (Exhibit WNS11) and CTTG (Exhibit WNS13) categories with the BST Local Service Trunk Group (Exhibit WNS12), BST believes that the trunk blocking on interconnection provided to the CLECs is at least equal in quality to that provided to itself or any other party. In many instances the trunk blocking quality is superior to the one BST provides to itself due to the network architecture for serving the CLECs calls, either originating or terminating. 83. Using the latest data (August, 1997), and assuming that all of the trunk groups had the same busy hour in the same time period, the trunk blocking for CLECs is 2.9% (2.5% between the tandem and the CLEC switch, plus, 0.4% between the tandem and a BST end office). Compare that to 4.4% for BST (2.2% for each group to the tandem). Thus, the service quality provided to the CLECs is consistent with the service levels BST provides for its retail customers. If the four trunk groups, with service results affected by conditions beyond BSTs control, were discounted, the service quality level for CLEC interconnection trunk groups is much higher than those provided to BST retail customers (1.4%% for CLECs as compared to 4.4% for BST retail customers). p` P @ 0 p`P@0  !"p`P@0  !"   p`P@0  !"p`P@0  !"   p`P@0  !"p`P@0  !"TRUNK FORECASTS AND PLANNING MEETINGS p`P@0  !"p` P @ 0 p`P@0  !"84. BST continues to work with its CLEC customers on trunk forecast and planning meetings. BST has participated in numerous meetings with the CLECS to gather trunking information as well as further improve the trunk forecasting and information process. Some CLECs do provide trunk forecasts to BST, but the forecasts are more on a justintime basis versus a forecast. For example, one CLEC provided BST with a forecast on July 10, 1997, requesting approximately 10,000 trunks in one city, 6600 to be ordered by BST and 3400 by the CLEC. The trunks were to be installed starting August 1, 1997 through December 1, 1997. This was too short a time frame for provisioning that many trunks. BST does not have 10,000 terminations available for instant ordering or use. If a vendor has to add equipment, it could require up to 26 weeks to provide it. BST has requested vendors shorten their intervals, and they have, where feasible; but this type of abrupt, unplanned demand increases the opportunity for blocking. 85. Some CLECs do not provide a forecast at all. Rather, BellSouth receives the request for larger numbers of trunks after the CLEC has committed to the end user. In these instances, trunk group blocking can be a concern. BST had a recent experience like this where the blocking was in excess of 60%. While technically true that the calls were blocked in the BST network, more preplanning by the CLEC would have alleviated much, if not all, of the blockage. #I2PQP# p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !"#XX2PQXP#XV. SUMMARY p` P @ 0 p`P@0  !"p` P @ 0 p`P@0  !"  86. BellSouth established a policy early in 1997 that it would not only provide services to its CLEC customers in a nondiscriminatory fashion, but also that it would collect all necessary data to demonstrate this fact. In addition to collecting this data and reporting the results of these measurements, BellSouth has established contractual obligations with two major CLECs for specific performance measures. Finally, BellSouth has submitted proposed measures based on these contracts to the South Carolina PSC which approved these measures as part of BellSouth SGAT. 87.BellSouth believes that these measures are fully sufficient to demonstrate that we are providing nondiscriminatory access to services in South Carolina and throughout the BellSouth region. 88. I hereby swear that the foregoing is true and correct to the best of my information and belief.  ____________________________ William N. Stacy Assistant Vice President Interconnection Services BellSouth Telecommunications, Inc. Subscribed and sworn to before me this 26th day of September, 1997. __________________________________ Notary Public