BellSouths Wholesale Performance

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BellSouths Wholesale Performance

• CLEC Coalition Presentation for the Tennessee
  Performance Measures Workshop -- September 14,
  2004

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Current Status in Tennessee
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Tennessee Trends
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CLEC Mode of Entry
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CLEC Areas of Concern

• BellSouths Public Policy
• BellSouths Interaction with CLECs Retail
  Customers

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Outline of CLEC Presentations

• Chronic Reported Non-Compliance Under the Current
  Plan
• Current Plan Has Helped Improve Performance
• Discrepancy Exists between Reported Performance
  and Performance Experienced by CLEC
• Operational Issues Not Monitored Under the
  Current Plan

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• Chronic Reported Non-Compliance Under the Current
  Plan
• Customers experience trouble within 30 days of
  Service Order Completion for UNE-P, EELs, Resale
  Business, and other services
• Customer trouble report rate is not at parity
  with BellSouth retail
• Order Completion Interval is deficient
• Current Plan Has Helped Improve Performance
• Flow-Through
• Discrepancy Exists between Reported Performance
  and Performance Experienced by CLEC
• Firm Order Confirmations are received, but
  service is worked on date other than Firm Order
  Completion (FOC), or in some instances a Pending
  Facility (PF) is received after the FOC
• Operational Issues Not Monitored Under the
  Current Plan
• BellSouth refuses to provide details of testing
  which would help isolate the customers trouble
• BellSouth OSS systems validates address and takes
  telephone number reservations which are later
  rejected or assigned

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• Chronic Reported Non-Compliance Under the Current
  Plan
• Provisioning Troubles within 30 days
• Missed Repair Appointments
• Partially-Mechanized FOC Timeliness
• Current Plan Has Helped Improve Performance
• UNE-P Flow-Through
• Operational Issues Not Monitored Under the
  Current Plan
• Pending Service Orders (PSOs) suspiciously
  created by BellSouth retail on end-user accounts.
  End-user accounts cannot be converted to CLEC
  service when BellSouth retail PSOs are present
• Facility Issues, BellSouth retail resolving
  facility issues for specific customers (Pending
  Facility Orders) quicker than wholesale is able
  to

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• Chronic Reported Non-Compliance Under the Current
  Plan
• Covads Interconnection Agreement requires
  BellSouth to work cooperatively with Covad before
  closing a trouble ticket, however BellSouth
  appears to be moving troubles to a delayed
  maintenance status then automatically closing
  the trouble ticket after 24 hours
• High number of repeat troubles due to BellSouth
  equipment (i.e., repeater cards) and timing
  synchronization issues
• Service Order Accuracy on UNE orders submitted
  electronically but that fall out for manual
  handling continues to be a chronic problem.
  BellSouth reported non-parity performance and
  paid SEEM penalties to Covad on this sub-metric
  for the first 5 months of 2004. The current SEEM
  penalty fee is a flat 50, irrespective of the
  number of affected transactions. This is clearly
  not an effective enough incentive for BellSouth
• FOC Timeliness performance for Partially-Mechanize
  d UNE xDSL and UNE Line Sharing orders has
  worsened since 2003. During the first 6 months
  of 2004, BellSouth reported non-parity compliance
  for 3 out of 6 months for Partially-Mechanized
  UNE xDSL order and for all 6 months for
  Partially-Mechanized UNE Line Sharing orders

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• Current Plan Has Helped Identify Performance
  Improvements
• Missed Repair Appointments (UNE Line Sharing
  Non Dispatch)
• Maintenance Average Duration (UNE Line Sharing
  Non Dispatch)
• Also implemented Central Office Synchronization
  Test at the beginning of 2004 BellSouth
  technician uses same test equipment that they use
  on their Fast Access customers
• Operational Issues Not Monitored Under the
  Current Plan
• No automated process for returning jeopardy and
  clarification notices Covad sends in LSR via EDI
  but BellSouth returns jeopardy and clarification
  notices via facsimile requiring CLEC personnel to
  spend time and resources gathering facsimiles,
  determining clarification issue/jeopardy issue,
  inputting issues into the Covads systems, and
  responding to BellSouth. BellSouth should, at a
  minimum, e-mail clarifications/jeopardy
  notifications to Covad so that we get the
  information online and can copy/paste data into
  system reports, etc.
• No parity for MLT testing Covad is prohibited
  from running an MLT test on Line Shared loops
  when a trouble ticket is open, however BellSouth
  is able to run the MLT test regardless of whether
  a trouble ticket is open

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• Operational Issues Not Monitored Under the
  Current Plan contd.
• Covad has tried to initiate bi-weekly calls with
  BellSouth to discuss operational issues vs.
  bringing them to the regulatory arena. However,
  BellSouth refuses on the basis that they do not
  have the resources or the time. BellSouth is the
  only ILEC that has refused this request from
  Covad. Verizon, Sprint, and SBC do currently have
  bi-weekly operational calls with Covad
• BellSouth refuses to support changes to BellSouth
  operational processes that will enable CLECs to
  migrate to new business models post-TRO. The
  issues relate to mechanized migration paths from
  Line Sharing and Line Splitting to UNE-L as well
  as network cross-connect processes that are
  cost-prohibitive
• BellSouth refuses to correct BST CABS billing
  problems that are caused by BST non-conformance
  with industry standards. CLECs are unable to
  verify billing unless it is done manually.
  Manual verification is a significant resource
  constraint on CLECs
• BellSouth continues to back-bill CLECs without
  providing business rules or billing parameters
  prior to the back-billing process. This results
  in laborious analysis, requests for meetings with
  BellSouth and unnecessary submission of disputes
  due to inconsistent and inaccurate billing
  practices

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• Chronic Reported Non-Compliance Under the Current
  Plan
• Customer trouble reports are not at parity.
  Network Telephone (NTC) customers experience more
  problems with service than BellSouths retail
  customers
• Customers experience trouble within 30 days of
  service order completion for provisioning of UNE
  port/loop combinations
• NTC customers experience repeat troubles within
  30 days
• Current Plan Has Helped Improve Performance
• Flow-Through and Order Completion Intervals have
  improved

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• Customer Trouble Reports Rate for UNE Combo and
  UNE Digital
• Loop DS1
• NuVox customers are experiencing significant
  number of maintenance troubles
• NuVox is forced to submit multiple trouble
  tickets for the same customer trouble because
  BellSouth will replace or switch out equipment
  pairs or cards that the customer is connected to
  but the problem exists because the underlying
  equipment is old, damaged and causing repeat
  troubles
• In areas where multiple troubles are reported,
  BellSouths repair attempts are only a temporary
  patch when source of troubles is really old
  equipment and bad facilities, which should be
  replaced and/or updated vs. patching

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• Operational Issues Monitored Under the Current
  Plan
• ATT customers are experiencing significant
  numbers of maintenance troubles within 30 days of
  provisioning UNE-P orders
• ATT customers are not experiencing expedient
  resolution of problems. ATT is forced to submit
  multiple trouble tickets for the same UNE-P
  customer trouble prior to the actual resolution
  of the trouble
• Operational Issues Not Monitored Under the
  Current Plan
• BellSouth is not providing electronic closure
  notification for all electronically-submitted
  troubles.
• BellSouth is not completing orders in the Billing
  system in a timely manner which is prohibiting
  electronic submission of subsequent customer
  orders.

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Customer Problems within 30 Days After
Provisioning

• Small Business
• Time Frames (March thru July data)
• 27 Troubles within 5 days
• 22 Troubles within 6 to 10 days
• 18 Troubles within 11 to 15 days
• 10 Troubles within 15 to 20 days
• 23 Troubles within 21 to 30 days
• Primarily Facility-Related Troubles

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Operational Issues Not Monitored Under
the Current Plan

• BellSouth is not providing electronic closure
  notification for all electronically-submitted
  troubles
• BellSouth is not completing orders in the Billing
  system in a timely manner which is prohibiting
  electronic submission of subsequent customer
  orders

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ELECTRONIC NOTIFICATION PERFORMANCE(Small
Business)