Pennsylvania Final Report – Verizon’s Response to Appendices Recommendations VZ #

DCI Rec. #

DCI Finding #

DCI Recommendation

Complete The Exclusion Portion Of The C2C Guidelines.

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App. A Sec. D PO-3 REC. 1

App. A Sec. B PO-3 FIND. 2

The exclusion of company holiday call processing as used by Verizon PA in the metric creations should be added to the C2C guidelines.

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App. A Sec. B PO-3 FIND. 3

Verizon Position: Verizon disagrees. Rationale: Verizon is calculating the metric in accordance with the Guidelines. The URL reference contains the proper business hours of availability and holiday schedule. However, Verizon agrees that an additional clarification could be added to align the PO-3 language with the other PO metrics. Action Taken/Required: No action required. However, as specified in Verizon’s action plan to this document, Verizon will propose clarifying language to the appropriate CWG.

Verify PO-3-04 Data.

App. A Sec. D PO-3 REC. 2

Verizon Response

The additional information (busy call) should be supplied and verified as the source of the variance. Verizon PA should provide supporting detail for calculations both with and without busy calls for PO-3-04.

Implementation period: Verizon will make the above proposals to the NY CWG no later than the second quarter 2004. The Executive Director, Metrics Policy & Planning, will be responsible for this proposal. Verizon Position: Verizon disagrees that further action is necessary. Rationale: Verizon provided to DCI the Busy Call data as part of the responses to DR3.004. The data was contained in the following files: DR_3.004.PO_3_TB_DM_PO_CALL_DTL_FACT_April_2003 was sent on July 1, 2003. DR_3.004.PO_3_TB_DM_PO_CALL_DTL_FACT_May_2003 was sent on July 18, 2003. DR_3.004.PO_3_TB_DM_PO_CALL_DTL_FACT_June_2003 was sent on July 31, 2003. In Appendix A, p. 46, DCI noted that a clarifying data request was issued on Sept 8, 2003. Verizon has no record of that DR. Action Taken/Required: No further action required.

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Pennsylvania Final Report – Verizon’s Response to Appendices Recommendations VZ #

DCI Rec. #

DCI Finding #

DCI Recommendation Review The Titles, Formulae, And Change Notification Performance Standards Of Sub-Metrics PO-4-02 and PO-4-03.

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App. A Sec. D PO-4 REC. 1

App. A Sec. B PO-4 FIND. 2

The title of the PO-4-02 and PO-4-03 submetrics and the formulae in which they are to be calculated should be revised to support rather than contradict one another. In addition, the performance standard for the change notification associated with the regulatory type change should be revised to clarify whether it is negotiated on an individual case basis or defaults to the interval required for Type 3, 4 & 5 changes when not specified within the Regulatory Order itself.

Verizon Response Verizon Position: Verizon disagrees that there is conflicting information in the Guidelines. Rationale: Verizon is calculating the sub-metrics in accordance with the Guidelines. However, Verizon agrees that an additional clarification could be made to the definition section to specify the sub-metric measurements. Additional clarifications to the language would need to be reviewed with the NY CWG. Action Taken/Required: No action required. However, as specified in Verizon’s action plan to this document, Verizon will propose clarifying language to the appropriate CWG. Implementation period: Verizon has already proposed the language clarification for the sub-metrics to the NY CWG and it is currently under review. The proposal for the language related to change types will be made no later than second quarter 2004. The Executive Director, Metrics Policy & Planning, will be responsible for this proposal.

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Pennsylvania Final Report – Verizon’s Response to Appendices Recommendations VZ #

DCI Rec. #

DCI Finding #

DCI Recommendation Verizon PA Needs To Coordinate The Field Identifiers For RequestNet And Include Them Into The Source Data For The NMP.

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App. A Sec. D PO-8 REC. 1

App. A Sec. B PO-8 FIND. 1

Based on the information observed in the FACT Table, Verizon PA needs to coordinate the field identifiers for RequestNet and include them into the source data for the NMP. The fields needed for future reconciliation are: 1. 2. 3. 4. 5. 6.

CLEC Name CCNA PON numbers RequestNet SR#s Request type City/State

Verizon Response Verizon Position: Verizon disagrees. Rationale: This recommendation is addressed in Verizon response #28. Verizon is calculating the metric in accordance with the Guidelines. The PO-8 metric measures the response time for the provision of Loop Qualification information when such information is not available through an electronic database. This measurement of incoming and outgoing timestamps is done by the front-end interface system WISDOM. Request Net is a system behind WISDOM. The DCI recommendation is to include additional sub-system fields from RequestNet to assist future auditors. The intent of the metric is to measure the response time, and the intermediate fields from the RequestNet system are not used in the calculation of this metric. Action Taken/Required: No further action required.

These data fields combined with the sent/received data/time stamps taken from the gateway by Wisdom will allow future auditors sufficient information to complete the audit in a timely fashion.

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Pennsylvania Final Report – Verizon’s Response to Appendices Recommendations VZ #

DCI Rec. #

DCI Finding #

DCI Recommendation Verizon Should Review Its Calculation Of The OR-10-01 And OR-10-02 Metric Results For June 2003 To Determine The Reason For The Discrepancy With The Results Calculated By DCI.

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App. B Sec. D OR-10 REC. 1

App. B Sec. C OR-10 FIND. 1

As DCI was unable to duplicate the results presented in the June in the C2C Report, Verizon PA should review the accuracy of its data and calculations to determine if final results are accurate.1

Verizon Response Verizon Position: Verizon disagrees. Rationale: Verizon is calculating the metric in accordance with the Guidelines. Verizon reviewed the DCI code provided in Appendix B and it is not consistent with the algorithm provided in the CMA documentation. Verizon was able to match the OR–10 reported results 100% for the June data month by executing the PA June CMA against the data Verizon provided in response to Data Request D-011. Action Taken/Required: No further action required.

Note: This Appendix has presented detailed findings which support and amplify on findings in Chapters IV – Measurement Calculations, and V – Measurement Calculation Results. Potential recommendations, other than the one listed above, are subsumed in Recommendations located in either or both of those chapters. 1

This is an open item as of 11/14/03 as ER-B-009.

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Pennsylvania Final Report – Verizon’s Response to Appendices Recommendations VZ #

70

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DCI Rec. #

App. E Sec. D NP-1 REC. 1

DCI Finding #

App. E Sec. C NP-1 FIND. 1

DCI Recommendation Verizon PA Should Immediately Develop And Implement A Notification Process To Notify And Elicit A Response From The CLEC Party When It Is Determined That A Trunk Group Exceeding The Blocking Threshold Is To Be Excluded. Such a procedure should provide a reasonable time for the CLEC to respond, with the time clearly defined. Since the metric calculation indicates the CLEC must agree to the exclusion, provisions for dispute resolution should also be included with binding time frames for the involved parties.

Verizon Response Verizon Position: Verizon disagrees. Rationale: Verizon is calculating the metric consistent with the Guidelines. The Guidelines require Verizon give notification to the CLEC. Verizon does use a notification process to alert CLECs of blocking conditions that occur on trunk groups that exist between Verizon and the CLEC. CLECs are aware that these blocked trunk groups will be excluded from the metric unless the CLEC responds to the Carrier Account Team Center (CATC) project manager with documentation to have the groups included. Action Taken/Required: No further action required.

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Pennsylvania Final Report – Verizon’s Response to Appendices Recommendations VZ #

DCI Rec. #

DCI Finding #

DCI Recommendation The Process Developed Above Should Be Used For The Five CLEC Trunk Groups Excluded In April, The Seven In May, And The Two In June. (Refers to Finding 1, NP-1)

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App. E Sec. D NP-1 REC. 2

App. E Sec. C NP-1 FIND. 1

DCI believes the NP-1-01, NP-1-03, and NP1-04 metrics for the review period are not valid, in that the proper notification was not made per the C2C Guidelines. Assuming a worst case scenario, Verizon PA would be out of parity for two of the three months for NP-1-01, and would have four trunk groups in May that exceeded the blocking threshold for two consecutive months, and one group in June that exceeded the blocking threshold for three consecutive months. To gain validity for these measurements, the process developed above should be used for the five CLEC trunk groups excluded in April, the seven in May, and the two in June. From the outcome of the process, the metrics may stand as published. If there are groups with which the CLEC parties disagree, then the dispute resolution process should be followed. If this process results in groups that should not be excluded, the metrics should be withdrawn and re-published.

Verizon Response Verizon Position: Verizon disagrees. Rationale: As explained in Verizon's response to 70, Verizon is calculating the metric consistent with the Guidelines. Verizon has no obligation to include in the NP-1 metric calculations blocked final trunk groups for which the CLEC did not respond. Action Taken/Required: No further action required.

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Pennsylvania Final Report – Verizon’s Response to Appendices Recommendations VZ #

DCI Rec. #

DCI Finding #

DCI Recommendation This Section Of The Guidelines Should Be Revised To Include A Definitive List Of The Types Of FTGs That Are Not Included. (Refers to Finding 2, NP-1)

72

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App. E Sec. D NP-1 REC. 3

App. E Sec. D NP-2 REC. 1

App. E Sec. C NP-1 FIND. 2

App. E Sec. C NP-2 FIND. 1

This section of the Guidelines should be revised to include a definitive list of the types of FTGs that are not included, such as 911 trunks, Operator Services trunks, final two-way dedicated trunk groups, etc. Language in the Performance Standard section should be clarified, and appropriate references cited. Further, pertinent information from the process developed in Recommendation No. 1 - NP-1 should be added to the Guidelines. Verizon PA Should Develop And Implement Guidelines For The Use Of All CLEC Jeopardies, To Include Documentation Requirements With Retention Intervals Clearly Spelled Out. As noted in Finding No. 1 – NP-2, above, the amount of “stop clock” time attributable to the jeopardies can be substantial, with major potential impact on the percent on time accomplishments. Documented procedures are essential to ensure that the jeopardies are used appropriately, started and stopped on a timely basis, and that the involved CLEC is consistently notified per the C2C Guidelines, and the Pennsylvania tariff.

Verizon Response Verizon Position: Verizon agrees in part and disagrees in part. Rationale: Verizon is calculating the metrics consistent with the C2C guidelines. Verizon agrees the language in the NP-1 section of the C2C guidelines would benefit from clarification by including a definitive list of final trunk groups. No impact to reported results. Verizon disagrees that the process in NP-1 REC 1 needs to be clarified in the C2C guidelines for the reasons noted in Verizon response #70. Action Taken/Required: VZ will propose clarifying language to the NY CWG. Implementation period: Verizon will follow the regular process for adoption of changes from NY. Verizon Position: Verizon agrees Rationale: Verizon agrees the stop clock process could benefit from a documented procedure. Verizon completed and implemented a method and procedure in January 2004 that provides a process for the collocation program managers to follow when communicating jeopardy status to the CLECs when a collocation arrangement is assigned a “C” code. Action Taken/Required: No further action required. Implementation period: The method and procedure was implemented January 15, 2004.

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Pennsylvania Final Report – Verizon’s Response to Appendices Recommendations VZ #

DCI Rec. #

DCI Finding #

DCI Recommendation With CC # 10261 In Place The Metrics Should Be Rerun For The Affected Months And The Results Should Be RePublished.

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App. E Sec. D NP-2 REC. 2

App. E Sec. C NP-2 FIND. 2

While DCI agrees that the reported metric results should not change, the report format will change. A re-published NP-2 result will provide for consistency from the inception of the PA PAP, providing a definitive base for future analysis and reviews.

Verizon Response Verizon Position: Verizon disagrees. Rationale: This metrics change control was an administrative change implemented in September. The metrics change control removed the appearance of NP-2-03 from the augment category on the C2C reports. The C2C guidelines do not require augment reporting for NP-2-03, and therefore no data is reported for augments in NP-2-03. A review of reports after September will show that the template has been changed. Since the reported results did not change, no rerun is required for the affected months. The PA CWG has agreed that re-run results are not necessary for this type of change and have agreed to change the entire format of the reports. Action Taken/Required: No further action required.

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App. E Sec. D NP-2 REC. 3

App. E Sec. C NP-2 FIND. 3

The C2C Guidelines Should Be Revised To Accurately Reflect The Intent, In That The Metric Results As They Are Presently Published Do Not Include All Collocation Arrangements Ordered Via The State And Federal Tariffs.

Verizon Position: Verizon agrees in part and disagrees in part.

Since the Guidelines do not contain a list of metric inclusions, clarity requires that those arrangements that are excluded be specifically identified. Further, the Guidelines should be revised to accurately reflect the product types that are measured by each sub-metric. The Verizon PA C2C Performance Standards and Reports, provide for reporting NP-2-01 through NP-2-08 results for both new and augment applications, but the PA C2C Guidelines do not accurately reflect this.

Verizon agrees the NP-2 section of the C2C guidelines should be updated to list the products for the NP-2-06 through NP-2-08 sub-metrics.

Rationale: Verizon disagrees that the NP-2 section of the C2C guidelines needs to be clarified to list collocation arrangements that are excluded. The C2C reports include collocation arrangements that fit the criteria listed in the NP-2 section of the C2C guidelines.

Action Taken/Required: Verizon proposed a NP-2 Guidelines language clarification for report products to the NY CWG. This language is under review. Implementation period: Implementation is subject to NY CWG schedule.

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Pennsylvania Final Report – Verizon’s Response to Appendices Recommendations VZ #

DCI Rec. #

DCI Finding #

DCI Recommendation

Verizon Response

The CMA Should Be Updated For All Billing Metrics.

Verizon Position: Verizon agrees that the CLEC formula statement was omitted from the Draft April CMA; however, the algorithms contained the appropriate numerators and denominators for both Resale and UNE.

CMA documentation should be updated to show the correct mechanics for all BI metric calculations, as described herein.

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App. F Sec. D BI-3 REC. 1

App. F Sec. C BI-3 FIND. 1

Note: This Appendix has presented detailed findings which support and amplify on findings in Chapter IV – Measurement Calculations and Chapter V – Measurement Calculation Results. Potential recommendations, other than the one listed above, are included with recommendations located in either or both of those chapters. Some may be subsumed within broader recommendations.

Rationale: The CLEC formula, (measures BI-3-01-2030, BI-3-04-2030, BI-3-05-2030 and BI-6-01), (Numerator 1 + Numerator 2) / (Denominator 1 + Denominator 2) was missing from the Draft April CMA. This formula was included in the June CMA to DCI. (Appendix F, Section C BI-3 noted measure BI-2-04-2030 as missing the formula. Verizon believes DCI meant BI-3-04-2030 since BI-2-04-2030 is a non-existent measure.) Action Taken/Required: No further action required.

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