FEDERAL COMMUNICATIONS COMMISSION

### Washington, D.C. 20554

#### Adopted: February 24, 2000

Released: February 24, 2000

Mr. Charles Foster

Group President

SBC Communications, Inc.

175 E. Houston Street

San Antonio, TX 78205

Dear Mr. Foster:

This letter responds to notifications from SBC Communications, Inc.
("SBC") and a coalition of several competitive local exchange carriers
("CLECs") regarding the status of advanced services operations support
systems ("OSS") collaborative sessions held pursuant to the
*SBC/Ameritech Merger Order*.[^1] Both SBC and participating CLECs
indicate that, although the parties reached agreement on a number of
issues, other issues remain unresolved. To provide SBC and participating
CLECs an opportunity to resolve the remaining issues, I am extending the
collaborative period until March 17, 2000.

The *SBC/Ameritech Merger Order* requires SBC to develop and deploy
enhancements to the pre-ordering and ordering interfaces for its OSS
used to provide digital subscriber line ("xDSL") and other advanced
services.[^2] To accomplish this task, the *Merger Conditions* establish
a three-phase approach. With respect to the second phase, the *Merger
Conditions* require SBC to "work collaboratively with CLECs . . . to
obtain written agreement on enhancements to the existing Datagate or
\[Electronic Data Interchange ("EDI")\] interfaces identified in the
Plan of Record, and a change management process, including a 12 month
forward-looking view of process changes and deployment schedule."[^3]
Completing the second phase depends entirely upon consummating a written
agreement.

I understand that, in January and February 2000, SBC and approximately
twenty CLECs participated in a series of collaborative sessions to
discuss operational and technical issues related to SBC's development
and deployment of enhancements to its advanced services OSS.[^4] On
February 7, 2000, SBC notified the Common Carrier Bureau ("Bureau")
regarding the conclusion of the collaborative sessions.[^5] Although SBC
indicated that the participants resolved fifteen operational and
technical issues, SBC further indicated that the collaborative sessions
left a number of issues unresolved. On February 8, 2000, Rhythms Link,
MCI Worldcom, AT&T, Sprint, and Northpoint (collectively "participating
CLECs") notified the Common Carrier Bureau ("Bureau") that the parties
were unable to reach agreement on a number of issues.[^6] The
participating CLECs further contend that SBC unduly limited the scope of
the collaborative sessions.

After discussing the issues with Bureau staff, both SBC and the
participating CLECs filed additional correspondence further explaining
their positions and describing the results of the earlier collaborative
sessions.[^7] In its letter of February 16, 2000, SBC acknowledged that
additional workshops would be productive on some issues and indicated
its willingness to extend the collaborative sessions to discuss these
issues. In addition, SBC requested guidance from the Bureau on the scope
of the collaborative sessions related to advanced services OSS.

SBC and the participating CLECs thus have failed to reach written
agreement on a number of issues discussed during the collaborative
sessions. For this situation, the *Merger Conditions* allow the Bureau
to extend the collaborative sessions in order to provide the parties an
opportunity to resolve any outstanding issues.[^8] In order to provide
SBC and the participating CLECs the opportunity to reach written
agreement expeditiously, I am extending the collaborative period for an
additional three weeks, through March 17, 2000. During this extended
period, I expect that SBC and the participating CLECs will reach written
agreement on a revised Plan of Record for enhancing SBC's advanced
services OSS. In addition, in view of the agreement reached on certain
issues,[^9] I expect SBC to begin implementing the agreed-upon changes
upon receipt of this letter. SBC should notify me in writing in the
event technical limitations prevent immediate implementation of the
agreed-upon changes. Furthermore, it is my understanding that, absent
arbitration or a directive from the Bureau, Phase 3 under *Merger
Condition III* will not begin until written agreement is reached on all
issues.

To facilitate the collaborative sessions and to assist in reaching a
written agreement between SBC and the participating CLECs, I offer the
following guidance with respect to the following issues:

1.  *Access to SBC Records, Databases, and Back-End Systems*: CLECs
    request that SBC identify the records, databases, and back-end
    systems that contain any loop makeup information available to SBC
    employees, as well as SBC's plans to make access to such records,
    databases and back-end systems available to CLECs. To the extent
    that SBC must provide information and access to records, databases,
    and back-end systems pursuant to the *Merger Conditions* or under
    the Commission's *UNE Remand Order*, such information and SBC's
    plans are relevant to SBC's obligation to upgrade its advanced
    services OSS. Because *Merger Condition III* addresses
    forward-looking enhancements to the interfaces for pre-ordering and
    ordering components used to provide advanced services, SBC should
    identify when it will make access to all records, databases and
    back-end systems available to CLECs. In its February 16^th^ Letter,
    SBC indicated its willingness to discuss in additional collaborative
    sessions access to loop qualification information and to provide
    details on the loop qualification data elements outlined in the Plan
    of Record, the enhancements outlined in the Addendum, and any
    additional enhancements planned as a result of the *UNE Remand
    Order*. SBC should do so during the ensuing three-week collaborative
    period.

2.  *Support for and Modification to CLEC User Interfaces*: CLECs assert
    that SBC's plans to enhance its graphical user interfaces for
    pre-ordering and ordering (including Verigate, LEX, and WebGUI) are
    inextricably linked to the company's plans to enhance Datagate and
    EDI interfaces for pre-ordering and ordering loops for advanced
    services, and therefore within the scope of the advanced services
    OSS collaboratives under *Merger Condition III*. Although SBC could
    address enhancements to its graphical user interfaces in the
    advanced services OSS collaborative sessions, these interfaces are
    directly addressed in the requirement for SBC to develop and deploy
    uniform and enhanced OSS interfaces (*Merger Condition VIII*). SBC
    has agreed to discuss deployment plans related to the GUI interfaces
    in the general uniform and enhanced OSS Plan of Record that will be
    filed in March 2000.[^10]

3.  *Population of Loop Qualification Data*: CLECs request that SBC
    update relevant databases as manual loop qualifications or
    engineering queries are performed. In its February 16^th^ Letter,
    SBC agreed to populate existing databases in all operating regions
    on a going forward basis as individual manual requests for loop
    qualification are performed. To the extent that SBC's obligations
    under *Merger Condition IV* (*i.e.*, to provide access to loop
    information for advanced services) or the *UNE Remand Order* require
    modifications to the OSS interfaces and/or business rules for
    pre-ordering and ordering loops used to provide advanced services,
    such plans are within the scope of the collaborative sessions under
    *Merger Condition III*.

4.  *Real-Time Flow-Through of CLEC Orders*: CLECs request that SBC
    describe how it will implement a real-time flow-through pre-ordering
    and ordering system for xDSL loops. To the extent that SBC's
    flow-through development plans for advanced services pre-order
    inquiries and orders require modifications to the OSS interfaces
    and/or business rules for pre-ordering and ordering loops used in
    advanced services, such plans are within the scope of the
    collaborative sessions under *Merger Condition III*. In its February
    16^th^ Letter, SBC explained that its Amended Plan of Record already
    addresses this issue.

5.  *Pre-Ordering and Order Intervals:* CLECs request that SBC discuss
    and commit to performance intervals for critical steps in the
    pre-ordering and ordering processes. Performance commitments for
    pre-ordering and ordering facilities used in advanced services are
    addressed in the performance measurements contained in the *Merger
    Condition VII* and are not within the scope of *Merger Condition
    III*. Nonetheless, to the extent that CLECs seek descriptions of
    relevant pre-ordering and ordering processes (*e.g.*, "a description
    of the reject process that clearly defines each step and the
    responsibilities of each party in clearing the reject"), such
    descriptions are within the scope of *Merger Condition III*.
    Furthermore, the CLECs' request for enhanced order status
    functionality is appropriately addressed in the uniform and enhanced
    OSS Plan of Record under *Merger Condition VIII*.

6.  *Parity:* CLECs request that SBC establish a process for providing
    information on the OSS systems used by SBC's internal operations
    and/or its Advanced Services Affiliate(s) for pre-ordering and
    ordering loops used in advanced services, as well as information
    regarding performance measures for internal versus CLEC systems. To
    the extent that CLECs request information regarding the processes
    used internally by SBC or its Advanced Services Affiliate(s), such
    information is necessary for CLECs to evaluate the sufficiency of
    SBC's advanced services OSS enhancements. It is always a relevant
    question for a CLEC to ask how will SBC's Advanced Services
    Affiliate(s) operate vis-à-vis SBC incumbent LECs so that a CLEC can
    be assured that it is eligible to use the same processes,
    interfaces, and systems. Naturally, SBC must explain its affiliate
    operating environment and provide any relevant information needed to
    understand fully the operating relationship between the SBC
    incumbent LECs and their affiliates. Specific performance parity
    considerations, however, are more appropriately addressed through
    the performance assurance plan in the *Merger Conditions* or the
    nondiscrimination safeguards that apply to the dealings between SBC
    incumbent LECs and their Advanced Services Affiliate(s).

7.  *Spectrum Management:* CLECs request that SBC complete the
    dismantling of its binder group management/selective feeder
    separation ("BGM/SFS") system immediately, which is within the scope
    of *Merger Condition III*. SBC indicates in its February 16^th^
    Letter that the issue is moot because it has resolved this issue by
    completing the required dismantling.

8.  *Line Sharing:* CLECs request that SBC provide information on the
    methods in which it will support ordering line sharing arrangements.
    SBC's plans to accommodate line sharing are within the scope of the
    advanced services OSS collaborative sessions because *Merger
    Condition III* addresses forward-looking enhancements to the
    interfaces for pre-ordering and ordering xDSL loops. SBC has
    committed to discuss implications for DataGate and EDI pre-ordering
    and ordering arising from the *Line Sharing Order* in additional
    collaborative sessions. SBC should do so during the ensuing
    three-week collaborative period.

9.  *Sample Data:* CLECs request that SBC provide sample data from its
    existing loop qualification process for 100 addresses in 13 states
    (i.e., 1300 addresses). Because sample data for existing and future
    loop qualification processes will facilitate the understanding and
    implementation of SBC's modifications to Datagate and EDI, SBC
    should provide the sample data requested by the participating CLECs.
    In its February 16^th^ Letter, SBC committed to provide such sample
    data in a spread sheet format.

10. *Loop Qualification Charges*: CLECs request that the structure of
    charges for loop qualification data provided during the pre-ordering
    and ordering of xDSL loops be deemed within the scope of the Plan of
    Record. The pricing of loop qualification processes does not appear
    to impact enhancements to Datagate or EDI and therefore appears to
    be outside the scope of the collaborative sessions under *Merger
    Condition III*.

11. *Continued Support for Pre-Qualification*: SBC and CLECs do not
    appear to agree on SBC's plans for continued maintenance and support
    of the Datagate and EDI interfaces, and therefore should discuss
    this issue further in collaborative sessions during the ensuing
    three-week collaborative period.

12. *Type of Service Field*: SBC should clarify its existing
    requirements and/or future plans for CLECs to disclose in the "Type
    of Service" field whether they will use unbundled loops for
    residential or business purposes. For example, SBC should clarify
    the "legal constraints" that impact this field.[^11]

13. *Methods and Procedures Documents for EDI/Datagate*. SBC should
    provide CLECs with documents describing in detail the modifications
    to its pre-ordering and ordering OSS systems for the Plan of Record
    upgrades. Such technical documentation is necessary for CLECs to
    evaluate the sufficiency of SBC's advanced services OSS
    enhancements. Consistent with the Change Management Process, SBC and
    participating CLECs should agree to a schedule for CLECs to receive
    any requisite documentation.

I must stress that the *Merger Conditions* require consummation of a
"written agreement." This requires SBC and the participating CLECs to
jointly embody *in writing* their understanding of the agreed-upon
resolutions. In order to reach written agreement, I expect SBC to
provide the participating CLECs with a draft amended Plan of Record in
time to review the document for accuracy before SBC submits the final
version to the Bureau.

As a final matter, I understand that one of SBC's Advanced Services
Affiliates, Advanced Services, Inc. ("ASI"), has not participated in the
January to February 2000 collaborative sessions pertaining to planned
enhancements to SBC's advanced services OSS, although the affiliate did
participate in earlier meetings to discuss line sharing issues. I am
surprised that ASI has not participated in these important collaborative
workshops since it will be using the interfaces and enhancements
developed during these sessions just like any other provider of advanced
services. I therefore encourage ASI to participate in the advanced
services OSS collaborative sessions.

Please do not hesitate to contact me if I can be of further assistance.
You may also contact Anthony Dale in the Common Carrier Bureau at (202)
418-2260 for further information on this matter.

Sincerely,

Lawrence E. Strickling

> Chief, Common Carrier Bureau

**EXHIBIT A**

##### Agreed-Upon Issues

SBC and the participating CLECs indicate that agreement was reached on
the issues that are summarized below.

1.  *Additional Data Elements in Loop Qualification*. In addition to the
    data elements that SBC identified in its initial Plan of Record, SBC
    and CLECs agreed that SBC will make additional data elements
    available no later than December 2, 2000. Specifically, SBC agrees
    to make available: (1) presence and location of repeaters; (2)
    quantity of repeaters; (3) type of repeaters; (4) type of plant
    (ariel or buried); (5) composition of loop (copper or fiber); (6)
    portion of loop and length of each composition; (7) availability of
    spare loops; (8) quantity of bridged tap by occurrence; (9) location
    of bridged tap by occurrence; (10) quantity of low pass
    filters; (11) location of low pass filters; (12) quantity of range
    extenders; (13) location of range extenders; (14) number of gauge
    changes; (15) location of pair gain devices; (16) location of
    digital loop carrier ("DLC"); (17) quantity of DLCs; (18) presence
    and location of remote switching unit; and (19) type of remote
    switching unit.

2.  *Elimination of Mandatory Tracking Number*. SBC and CLECs agree that
    SBC will eliminate the mandatory tracking number from its ordering
    system, thereby allowing CLECs to place an xDSL loop order without
    inclusion of the tracking number.

3.  *Value for Missing Data*. SBC and CLECs agree that SBC will provide
    a valid value rather than a blank when loop qualification data are
    missing.

4.  *Elimination of Loop Qualification Requirement for Loops 12,000 Feet
    or Less*. SBC and CLECs agree that once a CLEC determines that a
    loop is 12,000 feet or less (through loop pre-qualification process
    or otherwise), the CLEC may order the loop without having to perform
    a loop qualification.

5.  *Definition of Actual Loop Length*. SBC clarified the definition of
    actual loop length.

6.  *Clarification of DLR and DLR-Like*. SBC clarified the meaning of
    the terms DLR and DLR-Like documents as used by SBC in its Plan of
    Record.

7.  *Additional Data Elements in Pre-Qualification*. SBC agrees to
    unmask all the data fields currently available in its
    pre-qualification mini database, including the Wire Center Code and
    Design Cable Gauge Makeup.

8.  *Incorporating Reference to Change Management Process*. SBC agrees
    to follow its Change Management Process when making requested
    modifications to its OSS through the Plan of Record process.[^12]

9.  *Minutes from CLEC Meetings*. SBC distributed minutes from the
    November 3, 1999 CLEC meeting. SBC should ensure that all minutes
    and attachments are promptly distributed to participating LECs.

10. *Address Fields*. SBC agrees to remove the use of parsed address
    fields from its loop qualification specifications and to continue
    the use of cocatenated address fields until migration to LSOG4.

11. *Number of Plans of Record*. SBC clarified that it will issue five
    Plans of Record related to OSS issues for pre-ordering and ordering
    advanced services.

[^1]: Applications of Ameritech Corp., Transferor, and SBC
    Communications, Inc., Transferee, For Consent to Transfer Control of
    Corporations Holding Commission Licenses and Lines Pursuant to
    Sections 214 and 310(d) of the Communications Act and Parts 5, 22,
    24, 25, 63, 90, 95, and 101 of the Commission's Rules, CC Docket
    98-141, *Memorandum Opinion and Order*, 14 FCC Rcd 14712 (1999)
    ("*SBC/Ameritech Merger Order*").

[^2]: *SBC/Ameritech Merger Order* at Appendix C, para. 15(c).

[^3]: *Id*. at Appendix C, para. 15(c)(2).

[^4]: SBC held three collaborative workshops on the following dates:
    January 19, 2000; February 1, 2000; and February 2, 2000.

[^5]: Letter from Marian Dyer, Vice President -- Federal Regulatory, SBC
    Telecommunications, Inc., to Lawrence E. Strickling, Chief, Common
    Carrier Bureau, FCC (Feb. 7, 2000).

[^6]: *See* Notification of Unresolved Issues in Dispute (filed Feb. 8,
    2000) ("*CLEC Notification*").

[^7]: Letter from Marian Dyer, Vice President -- Federal Regulatory, SBC
    Telecommunications, Inc., to Lawrence E. Strickling, Chief, Common
    Carrier Bureau, FCC (Feb. 16, 2000) ("February 16^th^ Letter");
    *see* Letter from Anita Taff-Rice, Counsel for Rhythms Links, Inc.,
    to Lawrence E. Strickling, Chief, Common Carrier Bureau, FCC (Feb.
    14, 2000).

[^8]: *SBC/Ameritech Merger Order* at Appendix C, para. 15(c)(2).

[^9]: *See* Exhibit A.

[^10]: *See* SBC February 16^th^ Letter at 2.

[^11]: *See* SBC February 17^th^ Letter at 4.

[^12]: *See Merger Order*, App. C, para. 32.