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 Federal  Communications  Commission  FCC  02-  260 
 Before  the  Federal  Communications  Commission 
 Washington,  D.  C.  20554 


 In  the  Matter  of 
 Joint  Application  by  BellSouth  Corporation,  BellSouth  Telecommunications,  Inc.,  And 
 BellSouth  Long  Distance,  Inc.  for  Provision  of  In-  Region,  InterLATA  Services  in 
 Alabama,  Kentucky,  Mississippi,  North  Carolina,  and  South  Carolina 


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 )  ) 
 )  ) 
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 WC  Docket  No.  02  -  150 


 MEMORANDUM  OPINION  AND  ORDER 
 Adopted:  September  18,  2002  Released:  September  18,  2002 
 By  the  Commission:  Commissioner  Copps  issuing  a  statement. 
 TABLE  OF  CONTENTS 
 Paragraph 
 I.  INTRODUCTION.................................................................................................................  1 


 II.  BACKGROUND...................................................................................................................  4 
 III.  EVIDENTIARY  CASE  ..................................................................................................  12 
 IV.  PRIMARY  ISSUES  IN  DISPUTE.................................................................................  20 
 A.  COMPLIANCE  WITH  SECTION  271(  C)(  1)(  A)........................................................................  22  B.  CHECKLIST  ITEM  2    UNBUNDLED  NETWORK  ELEMENTS..................................................  28 


 1.  Pricing  of  Unbundled  Network  Elements  .....................................................................  29  2.  Access  to  Operations  Support  Systems  ......................................................................  128 
 3.  UNE  Combinations  (UNE-  P  and  EELs).....................................................................  209 
 V.  OTHER  CHECKLIST  ITEMS  .......................................................................................  213 
 A.  CHECKLIST  ITEM  1    INTERCONNECTION  .........................................................................  213  B.  CHECKLIST  ITEM  4  -  UNBUNDLED  LOCAL  LOOPS............................................................  232 


 C.  CHECKLIST  ITEM  5    UNBUNDLED  TRANSPORT  ...............................................................  252  D.  CHECKLIST  ITEM  8    WHITE  PAGES  DIRECTORY  LISTINGS  ..............................................  255 
 E.  CHECKLIST  ITEM  10    DATABASES  AND  ASSOCIATED  SIGNALING...................................  257  F.  CHECKLIST  ITEM  11    NUMBER  PORTABILITY  .................................................................  261 
 G.  CHECKLIST  ITEM  12    LOCAL  DIALING  PARITY  ...............................................................  267 
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 H.  REMAINING  CHECKLIST  ITEMS  (3,  6,  7,  9,  13,  AND  14)  ....................................................  270 
 VI.  SECTION  272  COMPLIANCE...................................................................................  271 


 VII.  PUBLIC  INTEREST  ....................................................................................................  275 
 A.  DANGERS  OF  PREMATURE  ENTRY....................................................................................  278  B.  PRICE  SQUEEZE  ANALYSIS...............................................................................................  279 


 C.  ASSURANCE  OF  FUTURE  COMPLIANCE.............................................................................  293  D.  MARKETING  TACTICS  ......................................................................................................  296 
 E.  OTHER  ISSUES..................................................................................................................  297 
 VIII.  SECTION  271(  d)(  6)  ENFORCEMENT  AUTHORITY............................................  302 


 IX.  CONCLUSION  .............................................................................................................  305 
 X.  ORDERING  CLAUSES...................................................................................................  306 
 APPENDIX  A    LIST  OF  COMMENTERS 
 APPENDIX  B    ALABAMA  PERFORMANCE  METRICS 
 APPENDIX  C    KENTUCKY  PERFORMANCE  METRICS 
 APPENDIX  D    MISSISSIPPI  PERFORMANCE  METRICS 
 APPENDIX  E    NORTH  CAROLINA  PERFORMANCE  METRICS 
 APPENDIX  F    SOUTH  CAROLINA  PERFORMANCE  METRICS 
 APPENDIX  G    GEORGIA  PERFORMANCE  METRICS 
 APPENDIX  H    STATUTORY  APPENDIX 


 I.  INTRODUCTION 
 1.  On  June  20,  2002,  BellSouth  Corporation  and  its  subsidiaries,  BellSouth  Telecommunications,  Inc.,  and  BellSouth  Long  Distance,  Inc.  (collectively,  BellSouth)  filed  an 


 application  pursuant  to  section  271  of  the  Communications  Act  of  1934,  as  amended,  1  for  authority  to  provide  in-  region,  interLATA  service  originating  in  the  states  of  Alabama, 
 Kentucky,  Mississippi,  North  Carolina,  and  South  Carolina.  2  We  grant  BellSouths  application 
 1  We  refer  to  the  Communications  Act  of  1934,  as  amended,  as  the  Communications  Act  or  the  Act.  See  47 
 U.  S.  C.    151  et  seq. 
 2  See  Joint  Application  by  BellSouth  Corporation,  BellSouth  Telecommunications,  Inc.,  and  BellSouth  Long 
 Distance,  Inc.  for  Provision  of  In-  Region,  InterLATA  Services  in  Alabama,  Kentucky,  Mississippi,  North  Carolina,  and  South  Carolina,  WC  Docket  No.  02-  150  (filed  June  20,  2002)  (BellSouth  Application);  see  also  Comments 


 Requested  on  the  Joint  Application  by  BellSouth  Corporation  for  Authorization  under  Section  271  of  the  Communications  Act  to  Provide  In-  region  InterLata  Service  in  the  States  of  Alabama,  Kentucky,  Mississippi,  North 
 Carolina,  and  South  Carolina,  WC  Docket  No.  02-  150,  Public  Notice,  17  FCC  Rcd  11303  (2002). 
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 in  this  Order  based  on  our  conclusion  that  BellSouth  has  taken  the  statutorily  required  steps  to  open  its  local  exchange  markets  in  these  states  to  competition. 
 2.  In  ruling  on  BellSouths  application,  we  wish  to  acknowledge  the  effort  and  dedication  of  the  Alabama  Public  Service  Commission  (Alabama  Commission),  the  Kentucky 
 Public  Service  Commission  (Kentucky  Commission),  the  Mississippi  Public  Service  Commission  (Mississippi  Commission),  the  North  Carolina  Utilities  Commission  (North 
 Carolina  Commission),  and  the  South  Carolina  Public  Service  Commission  (South  Carolina  Commission)  (collectively,  state  commissions),  which  have  expended  significant  time  and  effort 
 overseeing  BellSouths  implementation  of  the  requirements  of  section  271.  The  state  commissions  conducted  proceedings  to  determine  BellSouths  section  271  compliance  and 
 provided  interested  third  parties  with  ample  opportunities  for  participation  in  their  proceedings.  The  state  commissions  also  adopted  a  broad  range  of  performance  measures  and  standards,  3  as 
 well  as  Performance  Assurance  Plans  designed  to  create  a  financial  incentive  for  BellSouths  post-  entry  compliance  with  section  271.  Moreover,  the  state  commissions  have  committed 
 themselves  to  actively  monitor  BellSouths  continuing  efforts  to  open  the  local  markets  to  competition.  The  Commission  recognizes  the  vital  role  of  the  state  commissions  in  conducting 
 section  271  proceedings  and  their  commitment  to  furthering  the  pro-  competitive  purposes  of  the  Act.  4  We  commend  and  thank  all  of  the  states  for  the  time  and  effort  they  spent  to  investigate 
 the  merits  of  this  application. 
 3.  We  also  recognize  BellSouth  for  the  progress  it  has  made  in  opening  its  local  exchange  markets  to  competition  in  each  of  the  five  states  subject  to  this  application.  According 


 to  BellSouth,  competitive  local  exchange  carriers  (competitive  LECs)  provide  facilities-  based  local  service  to  some  202,149  lines  in  Alabama,  93,252  lines  in  Kentucky,  84,637  lines  in 
 Mississippi,  353,542  lines  in  North  Carolina,  and  143,471  lines  in  South  Carolina.  5  In  addition,  BellSouth  states  that  competitive  LECs  have  gained  double-  digit  market  share  in  Alabama  (11.9 
 percent),  North  Carolina  (13.4  percent),  and  South  Carolina  (11.8  percent),  and  have  gained  nearly  as  much  market  share  in  Mississippi  (8.4  percent)  and  Kentucky  (8.4  percent).  6  Finally, 


 3  The  performance  metrics  measuring  BellSouths  performance  in  each  of  the  states  were  calculated  according  to 
 the  business  rules  (the  BellSouth  Service  Quality  Measurement  Plan  or  SQM)  developed  by  the  Georgia  Public  Service  Commission  (Georgia  Commission).  See  BellSouth  Application  App.  A,  Vol.  8a,  Tab  K,  Affidavit  of 


 Alphonso  J.  Varner  (BellSouth  Varner  Aff.)  at  para.  5. 
 4  See,  e.  g.,  Application  of  Verizon  New  York  Inc.,  Verizon  Enterprise  Solutions,  Verizon  Global  Networks  Inc., 
 and  Verizon  Select  Services,  Inc.,  for  Authorization  to  Provide  In-  Region,  InterLATA  Services  in  Connecticut,  CC  Docket  No.  01-  100,  Memorandum  Opinion  and  Order,  16  FCC  Rcd  14147,  14149,  para.  3  (2001)  (Verizon 


 Connecticut  Order);  Application  of  Verizon  New  England  Inc.,  Bell  Atlantic  Communications,  Inc.  (d/  b/  a  Verizon  Long  Distance),  NYNEX  Long  Distance  Company  (d/  b/  a  Verizon  Enterprise  Solutions)  and  Verizon  Global 
 Networks  Inc.  for  Authorization  to  Provide  In-  Region,  InterLATA  Services  in  Massachusetts,  CC  Docket  No.  01-  9,  Memorandum  Opinion  and  Order,  16  FCC  Rcd  8988,  8990,  para.  2  (2001)  (Verizon  Massachusetts  Order). 


 5  BellSouth  Application  App.  A,  Vol.  7,  Tab  J,  Affidavit  of  Elizabeth  A.  Stockdale  (BellSouth  Stockdale  Aff.)  at 
 Tables  1,  4,  7,  10,  13. 
 6  BellSouth  Reply  App.,  Vol.  4a,  Tab  I,  Reply  Affidavit  of  Elizabeth  A.  Stockdale  (BellSouth  Stockdale  Reply 
 Aff.)  at  para.  11. 
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 we  note  that,  as  of  June  30,  2002,  BellSouth  states  that  it  has  provisioned  approximately  15,913  loops  in  Alabama,  3,841  in  Kentucky,  6,258  in  Mississippi,  51,229  in  North  Carolina,  and 
 14,901  in  South  Carolina.  7 
 II.  BACKGROUND 
 4.  In  the  1996  amendments  to  the  Communications  Act,  Congress  required  the  Bell  Operating  Companies  (BOCs)  to  demonstrate  compliance  with  certain  market-  opening 


 requirements  contained  in  section  271  of  the  Act  before  they  would  be  permitted  to  provide  in-region,  interLATA  long  distance  service.  Congress  empowered  the  Commission  to  review  BOC 
 applications  to  provide  such  service,  and  to  consult  with  the  affected  state  and  the  Attorney  General.  8 


 5.  We  rely  heavily  on  the  work  completed  by  the  state  commissions  in  our  examination  of  this  joint  application.  As  noted  above,  each  of  the  state  commissions  has 
 undertaken  significant  review  of  BellSouths  section  271  compliance.  As  summarized  below,  each  commission  assures  us  that  BellSouth  adheres  to  the  pro-  competitive  requirements  of  the 
 1996  Act. 
 6.  Alabama.  On  May  8,  2001,  BellSouth  notified  the  Alabama  Commission  of  its  intent  to  file  an  application  to  provide  interLATA  service  in  Alabama.  9  In  response,  the 


 Alabama  Commission  initiated  a  proceeding  to  examine  BellSouths  compliance  with  the  requirements  of  section  271.  10  On  May  22,  2002,  the  Alabama  Commission  approved 
 BellSouths  petition  for  in-  region,  interLATA  authority.  11 


 7  Letter  from  Glenn  T.  Reynolds,  Vice  President    Federal  Regulatory,  BellSouth,  to  Marlene  H.  Dortch, 
 Secretary,  Federal  Communications  Commission,  WC  Docket  No.  02-  150  (filed  Aug.  14,  2002)  (BellSouth  August  14  OSS  and  Loops  Ex  Parte  Letter.) 


 8  The  Commission  has  summarized  the  relevant  statutory  framework  in  prior  section  271  orders.  See,  e.  g.,  Joint 
 Application  by  SBC  Communications  Inc.,  Southwestern  Bell  Tel.  Co.,  and  Southwestern  Bell  Communications  Services,  Inc.,  d/  b/  a  Southwestern  Bell  Long  Distance  for  Provision  of  In-  Region,  InterLATA  Services  in  Kansas 


 and  Oklahoma,  CC  Docket  No.  00-  217,  Memorandum  Opinion  and  Order,  16  FCC  Rcd  6237,  6241-  42,  paras.  7-  10  (2001)  (SWBT  Kansas/  Oklahoma  Order),  affd  in  part,  remanded  in  part  sub  nom.  Sprint  Communications  Co.  v. 
 FCC,  274  F.  3d  549  (D.  C.  Cir.  2001)  (Sprint  v.  FCC);  Application  by  SBC  Communications  Inc.,  Southwestern  Bell  Tel.  Co.  and  Southwestern  Bell  Communications  Services,  Inc.,  d/  b/  a  Southwestern  Bell  Long  Distance  pursuant  to 
 Section  271  of  the  Telecommunications  Act  of  1996  to  Provide  In-  Region,  InterLATA  Services  in  Texas,  CC  Docket  No.  00-  65,  Memorandum  Opinion  and  Order,  15  FCC  Rcd  18354,  18359-  61,  paras.  8-  11  (2000)  (SWBT  Texas 
 Order);  Application  by  Bell  Atlantic  New  York  for  Authorization  Under  Section  271  of  the  Communications  Act  to  Provide  In-  Region,  InterLATA  Service  in  the  State  of  New  York,  CC  Docket  No.  99-  295,  Memorandum  Opinion  and 
 Order,  15  FCC  3953,  3961-  63,  paras.  17-  20  (1999)  (Bell  Atlantic  New  York  Order),  affd,  AT&  T  Corp  v.  FCC,  220  F.  3d  607  (D.  C.  Cir.  2000). 


 9  BellSouth  Application  at  8. 
 10  Id.  at  8. 
 11  Id.  at  9. 
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 7.  Kentucky.  On  April  26,  2001,  the  Kentucky  Commission  initiated  a  proceeding  to  advise  the  Commission  as  to  whether  BellSouth  should  be  permitted  to  enter  the  in-  region, 
 interLATA  market  in  Kentucky  pursuant  to  section  271  of  the  Act.  12  The  Kentucky  Commission  held  formal  hearings  focusing  on  BellSouths  section  271  application,  and  issued  an  order 
 adopt[  ing]  the  performance  measures,  benchmarks  and  retail  analogs,  and  penalty  plan  adopted  by  the  Georgia  Public  Service  Commission.  13  On  April  26,  2002,  the  Kentucky  Commission 
 concluded  in  an  Advisory  Opinion  that  BellSouth  has  achieved  compliance  with  the  requirements  of  the  competitive  checklist  under  section  271  of  the  Act.  14 


 8.  Mississippi.  On  May  22,  2001,  BellSouth  notified  the  Mississippi  Commission  of  its  intent  to  file  a  section  271  application  for  Mississippi.  15  The  Mississippi  Commissions 
 proceeding,  which  was  open  to  participation  by  all  interested  parties,  culminated  in  an  October  4,  2001  order  concluding  that  BellSouth  has  met  all  legal  requirements  for  section  271 
 authorization.  16 
 9.  North  Carolina.  On  April  12,  2001,  BellSouth  notified  the  North  Carolina  Commission  of  its  intent  to  file  a  section  271  application  for  North  Carolina.  17  The  North 


 Carolina  Commission  held  evidentiary  hearings  from  October  29  through  November  6,  2001.  18  On  May  23,  2002,  the  North  Carolina  Commission  released  its  Notice  of  Decision,  finding  that 
 BellSouth  has  satisfied  its  obligations  under  the  competitive  checklist  and  Track  A  of  the  Act,  and  that  BellSouths  entry  into  the  interLATA  market  in  North  Carolina  is  consistent  with  the 
 public  interest.  19 
 10.  South  Carolina.  On  May  16,  2001,  BellSouth  notified  the  South  Carolina  Commission  of  its  intent  to  file  an  application  to  provide  interLATA  telecommunications 


 services  in  South  Carolina.  20  In  response,  the  South  Carolina  Commission  initiated  a  proceeding  to  examine  BellSouths  compliance  with  the  requirements  of  section  271.  On  February  14,  2002, 


 12  Kentucky  Commission  Comments  at  1. 
 13  BellSouth  Application  at  11. 
 14  Kentucky  Commission  Comments  at  41. 
 15  BellSouth  Application  at  13. 
 16  Id.  at  14. 
 17  Id.  at  16. 
 18  Id. 
 19  Id. 
 20  Id.  at  18. 
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 the  South  Carolina  Commission  issued  an  order  endorsing  BellSouths  application  to  provide  interLATA  service  originating  in  the  state  of  South  Carolina.  21 
 11.  The  Department  of  Justice  filed  its  recommendation  regarding  this  joint  application  on  July  30,  2002.  22  The  Department  of  Justice  recommended  approval  of  BellSouths 
 application  for  section  271  authority  in  the  five  states,  stating  that: 
 BellSouths  Application  demonstrates  that,  in  conjunction  with  the  state  commissions,  it  has  made  substantial  progress  in  addressing 


 issues  previously  identified  by  the  department.  23 
 However,  the  Department  expressed  concern  regarding  several  issues,  including  BellSouths  treatment  of  its  performance  metrics  and  its  change  management  process  for  operations  support 


 systems  (OSS).  24  In  supporting  approval  of  BellSouths  application,  the  Department  of  Justice  noted  that  its  conclusions  were  subject  to  the  Commissions  review  of  the  concerns  expressed  in 
 this  Evaluation.  25  Based  on  our  analysis  of  these  and  other  issues,  we  grant  BellSouths  application. 


 III.  EVIDENTIARY  CASE 
 12.  As  a  threshold  matter,  we  address  challenges  to  the  validity  of  the  data  submitted  by  BellSouth.  As  BellSouths  data  are  important  to  its  showing  of  compliance  with  several 


 different  checklist  items,  it  is  appropriate  for  us  to  dispose  of  this  issue  before  addressing  compliance  with  each  checklist  item.  26  BellSouth  has  submitted  performance  metric  data  with  its 


 21  Id. 
 22  Section  271  (d)(  2)(  A)  requires  us  to  give  substantial  weight  to  the  Departments  evaluation.  47  U.  S.  C. 
   271(  d)(  2)(  a). 
 23  Department  of  Justice  Evaluation  at  15. 


 24  Id.  at  8,  10,  11. 
 25  Id.  at  3. 
 26  We  note  that  the  Commission  discussed  the  importance  of  data  validity  issues  in  the  Bell  Atlantic  New  York 
 Order,  SWBT  Texas  Order,  Verizon  Massachusetts  Order,  and  BellSouth  Georgia/  Louisiana  Order.  See  Joint  Application  by  BellSouth  Corporation,  BellSouth  Telecommunications,  Inc.,  and  BellSouth  Long  Distance,  Inc.  for 


 Provision  of  In-  Region,  InterLATA  Services  in  Georgia  and  Louisiana,  CC  Docket  No.  02-  35,  Memorandum  Opinion  and  Order,  17  FCC  Rcd  9018,  9027,  para.  16  (2002)  (BellSouth  Georgia/  Louisiana  Order);  Bell  Atlantic 
 New  York  Order,  15  FCC  Rcd  at  3959,  para.  11  (stating  that  the  monthly  review  by  the  New  York  Commission  of  Bell  Atlantics  raw  data,  the  collaborative  proceedings  conducted  by  the  New  York  Commission  concerning  the 
 performance  metrics,  and  the  review  by  KPMG  and  the  New  York  Commission  of  Bell  Atlantics  internal  controls  surrounding  the  data  collection  process  ensured  that  the  performance  data  were  accurate,  consistent,  and 
 meaningful);  SWBT  Texas  Order,  15  FCC  Rcd  at  18377-  78,  para.  57  (noting  that  SWBTs  data  had  been  subject  to  scrutiny  and  review  by  interested  parties,  to  a  large  extent  its  accuracy  had  not  been  contested,  and  in  those 
 instances  where  it  had  been  disputed,  the  Commission  looked  first  to  the  results  of  data  reconciliations  between  SWBT  and  competing  carriers);  Verizon  Massachusetts  Order,  16  FCC  Rcd  at  9058-  59,  para.  129  (claiming  that 
 (continued.) 
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 application  as  evidence  of  meeting  its  nondiscriminatory  requirements  under  the  checklist.  Each  of  the  state  commissions  adopted  the  same  SQM  Plan  that  BellSouth  used  in  Georgia  and 
 Louisiana  for  purposes  of  assessing  section  271  compliance,  and  the  audits  and  other  checks  on  data  reliability  that  we  previously  relied  upon  are  also  applicable  here.  27  The  SQM  was 
 developed  in  an  open,  collaborative  proceeding  conducted  by  the  Georgia  Commission.  28  The  Georgia  performance  metric  data  has  been  subject  to  three  audits  ordered  by  the  Georgia 
 Commission,  of  which  the  first  two  are  almost  complete  and  the  third  is  still  in  progress.  29 
 13.  In  its  evaluation,  the  Department  of  Justice  expressed  concern  about  BellSouths  alleged  implementation  of  changes  to  the  performance  metrics  without  notification  to  competing 


 LECs  and  regulators  until  after  the  changes  were  implemented.  30  Commenters  also  contend  that  BellSouth  did  not  provide  competitive  LECs  with  adequate  prior  written  notice  when  it 
 implemented  the  Performance  Measurement  Analysis  Platform  (PMAP)  4.0.  31  We  agree  with  the  Department  of  Justice  that,  because  of  the  potential  impact  on  the  reliability  and  usefulness  of 
 reported  performance  data,  BOCs  should  provide  adequate  advanced  notice  and  obtain  prior  regulatory  approval  of  proposed  changes  to  performance  data.  32  We  find,  however,  that  there  is 
 no  evidence  in  the  record  that  BellSouths  alleged  failure  to  provide  competitive  LECs  prior  written  notice  impaired  the  quality  or  reliability  of  BellSouths  data  during  the  relevant  period. 
 In  addition,  the  record  makes  clear  that,  at  the  time,  there  was  no  formal  process  that  required  BellSouth  to  provide  notice  or  obtain  approval  prior  to  changing  metrics.  We  note,  however, 
 that  BellSouth  has  committed  itself  to  following  a  new  formal  notification  process  recently  ordered  by  the  Georgia  Commission  in  the  applicant  states,  33  in  which  regulators  and  competing 
 (Continued  from  previous  page)  when  performance  metric  data  are  challenged  and  have  not  been  audited,  competing  carriers  should  be  given  access 
 to  their  carrier-  specific  data,  and  to  the  underlying  data  used  for  any  special  studies  of  the  BOCs  performance). 
 27  BellSouth  Varner  Aff.  at  paras.  5,  26-  55;  see  also  BellSouth  Application  at  24. 


 28  BellSouth  Varner  Aff.  at  paras.  14-  25. 
 29  One  exception  remains  open  for  the  first  two  audits.  BellSouth  Varner  Aff.  at  paras.  127-  59.  An  exception 
 is  a  designation  made  by  KPMG  that  identifies  a  problem  with  BellSouths  performance  encountered  by  KPMG  in  the  course  of  its  audit  and  test,  which  KPMG  was  unable  to  resolve.  BellSouth  Application  Mississippi  App.  E,  Tab 


 29,  KPMG  OSS  Evaluation  at  II-  6. 
 30  Department  of  Justice  Evaluation  at  12-  14.  The  Department  noted,  in  particular,  that  the  changes  in  the 
 calculation  of  the  region-  wide  Service  Order  Accuracy  metrics,  and  the  conversion  from  the  PMAP  2.6  data  platform  to  PMAP  4.0,  were  made  without  advance  public  notice  and  regulatory  review  and  approval.  Id.  at  12-  13. 


 The  Department  argued  that  advance  notice  was  needed  for  three  reasons:  First,  metrics  calculated  under  new  rules  may  no  longer  be  directly  comparable  to  metrics  previously  reported.  Second,  changes  to  audited  measures 
 limit  the  applicability  of  those  audits.  Third,  changes  could  have  substantive  implications  on  commission-established  rules.  Department  of  Justice  Evaluation  at  13-  14. 


 31  See,  e.  g.,  AT&  T  Comments  App.,  Vol.  IV,  Declaration  of  Cheryl  Bursh  and  Sharon  Norris  (AT&  T 
 Bursh/  Norris  Decl.)  at  para.  16. 
 32  Department  of  Justice  Evaluation  at  13. 
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 carriers  will  be  notified  by  BellSouth  of  proposed  changes  to  the  metrics  at  least  one  month  before  they  take  effect.  This  will  give  competing  carriers  an  opportunity  to  comment  on  any 
 proposed  changes,  and  the  state  commissions  the  opportunity  to  review  them.  34  This  process  should  meet  the  Department  of  Justices  concerns  about  the  allegation  that  BellSouth  has 
 unilaterally  implemented  changes  to  the  metrics  without  advance  notice  or  regulatory  approval.  35 
 14.  AT&  T  and  ITC^  DeltaCom  also  challenge  the  validity  of  the  data  provided  by  BellSouth.  Specifically,  they  claim  that  there  are  numerous  discrepancies  and  errors  in  the 


 reported  data;  36  the  business  rules  were  not  implemented  properly;  37  the  pattern  of  restatements  of  the  data  by  BellSouth  and  BellSouths  acknowledgements  of  problems  with  certain  metrics 
 indicate  that  the  data  are  not  stable  enough  to  be  relied  upon;  38  and  the  data  discrepancies  uncovered  when  BellSouth  switched  from  the  PMAP  2.6  to  the  PMAP  4.0  data  platform 
 demonstrate  that  the  data  submitted  in  this  proceeding  using  PMAP  2.6  are  inaccurate,  and  raise  serious  questions  concerning  the  integrity  of  the  data  using  PMAP  4.0.  39  They  also  argue  that 
 BellSouth  unilaterally  changed  the  rules  by  which  the  metrics  are  calculated  after  the  Georgia  Commission  had  approved  them,  and  does  not  follow  a  formal  established  change  control 


 (Continued  from  previous  page)  33  BellSouth  Varner  Aff.  at  paras.  111-  16;  BellSouth  Application  Reply  App.,  Vol.  4a,  Tab  J,  Reply  Affidavit  of 
 Alphonso  J.  Varner  (BellSouth  Varner  Reply  Aff.)  at  paras.  5-  14.  In  response  to  an  emergency  motion  filed  in  Georgia  by  the  Southeast  Competitive  Carriers  Association  (SECCA),  which  represents  competing  LECs,  BellSouth 
 and  SECCA  reached  a  settlement  agreement  on  setting  up  a  workshop  to  discuss  the  establishment  of  a  formal  notification  process,  and  to  allow  participants  to  question  BellSouth  about  recent  changes  it  has  made  to  the  metric 
 calculations.  This  agreement  was  approved  by  the  Georgia  Commission  on  June  18,  2002.  BellSouth  Varner  Aff.  at  paras.  111-  13  &  Exh.  PM-  29.  On  July  2,  2002,  the  Georgia  Commission  approved  a  staff  recommendation, 
 based  on  an  agreement  between  BellSouth  and  SECCA,  that  established  a  formal  notification  process  for  changes  to  performance  metrics.  The  Georgia  Commission  ordered,  among  other  things,  that  BellSouth  provide  one  months 
 notice  of  proposed  changes  to  the  metrics  and  provide  regulators  and  competing  carriers  an  opportunity  to  ask  questions,  and  established  a  process  for  commenters  to  file  comments,  and  for  the  Georgia  Commission  to  block  the 
 changes  if  it  chooses.  BellSouth  Varner  Reply  Aff.  at  paras.  7-  9  &  Exh.  PM-  1. 
 34  BellSouth  Varner  Aff.  at  paras.  111-  16;  BellSouth  Varner  Reply  Aff.  at  paras.  5-  14  &  Exh.  PM-  1. 


 35  Department  of  Justice  Evaluation  at  12-  14.  We  will  monitor  BellSouth's  compliance  with  its  obligation  to 
 provide  notice.  If  evidence  becomes  available  to  the  Commission  sufficient  to  show  a  systemic  problem  with  BellSouth's  change  management  notification  process,  we  will  pursue  appropriate  enforcement  action. 


 36  AT&  T  Bursh/  Norris  Decl.  at  paras.  35-  40;  AT&  T  Reply  App.,  Tab  E,  Reply  Declaration  of  Cheryl  Bursh  and 
 Sharon  Norris  (AT&  T  Bursh/  Norris  Reply  Decl.)  at  paras.  11-  20;  Letter  from  Alan  C.  Geolot,  Counsel  to  AT&  T,  to  Marlene  H.  Dortch,  Secretary,  Federal  Communications  Commission,  WC  Docket  No.  02-  150  at  6  (filed  Aug.  23, 


 2002)  (AT&  T  August  23  OSS  and  Data  Integrity  Ex  Parte  Letter). 
 37  AT&  T  Bursh/  Norris  Decl.  at  paras.  41-  58;  ITC^  DeltaCom  Comments  at  2. 


 38  AT&  T  Bursh/  Norris  Decl.  at  paras.  59-  62;  ITC^  DeltaCom  Comments  at  2-  3.  ITC^  DeltaCom  recommends  that 
 the  Commission  conduct  an  annual  audit  of  BellSouths  performance  data.  ITC^  DeltaCom  Comments  at  3. 
 39  AT&  T  Bursh/  Norris  Reply  Decl.  at  paras.  23-  43;  AT&  T  August  23  OSS  and  Data  Integrity  Ex  Parte  Letter  at 
 5-  8. 
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 process  for  changing  the  metric  calculations  and  notifying  others  of  changes.  40  Commenters  contend  that  the  lack  of  a  completed  audit  and  the  problems  found  by  KPMG  in  its  Georgia  and 
 Florida  audits  of  BellSouths  metric  data,  demonstrate  that  the  data  are  unreliable;  41  and  BellSouth  has  failed  to  meaningfully  engage  in  data  reconciliations  as  it  had  promised.  42 


 15.  BellSouth  argues  that  its  internal  and  external  controls  and  checks  ensure  that  its  data  continue  to  be  reliable.  43  BellSouth  observes  that  the  data  have  been  subjected  to  repeated 
 audits  and  regular  review  by  state  commissions  in  which  competing  carriers  may  raise  concerns.  44  It  asserts  that  it  has  developed  a  data  platform  that  is  regional,  reliable,  accurate,  and 
 open  to  inspection  by  competing  LECs  and  regulators.  45  Regarding  the  conversion  from  PMAP  2.6  to  PMAP  4.0,  BellSouth  further  states  that  this  was  an  incremental  upgrade  of  its  processing 
 infrastructure  that  was  necessary  to  increase  the  capacity  of  its  system,  improve  its  auditability,  and  allow  BellSouth  to  provide  state-  specific  measurements  in  North  Carolina  and  Florida,  as 
 required  by  the  North  Carolina  and  Florida  Commissions.  46  BellSouth  further  contends  that  PMAP  2.6  and  PMAP  4.0  generated  substantially  similar  results  when  applied  to  the  same 
 months  data,  and  provided  extensive  evidence  to  demonstrate  that  the  data  discrepancies  that  appeared  were  small,  and  were  mostly  caused  by  corrections  to  errors  in  PMAP  2.6s 
 calculations  and  by  PMAP  4.0s  improved  ability  to  properly  identify  and  classify  orders.  47 


 40  AT&  T  Bursh/  Norris  Decl.  at  paras.  10-  21;  ITC^  DeltaCom  Comments  at  2-  3;  AT&  T  Bursh/  Norris  Reply  Decl. 
 at  paras.  44-  52;  AT&  T  August  23  OSS  and  Data  Integrity  Ex  Parte  Letter  at  5-  6. 
 41  AT&  T  Bursh/  Norris  Decl.  at  paras.  63-  75;  AT&  T  Bursh/  Norris  Reply  Decl.  at  para.  43;  AT&  T  August  23  OSS 
 and  Data  Integrity  Ex  Parte  Letter  at  n.  12. 
 42  AT&  T  Bursh/  Norris  Decl.  at  paras.  22-  34;  ITC^  DeltaCom  Comments  at  2;  AT&  T  Bursh/  Norris  Reply  Decl.  at 
 paras.  9,  21-  22;  AT&  T  August  23  OSS  and  Data  Integrity  Ex  Parte  Letter  at  5-  6.  AT&  T  proposes  that  a  formal  procedure  be  put  into  place,  with  detailed  deadlines  for  BellSouth  to  respond  to  competing  LEC  requests  for  data 


 reconciliation.  AT&  T  Bursh/  Norris  Reply  Decl.  at  para.  22;  Letter  from  Joan  Marsh,  Director    Federal  Government  Affairs,  AT&  T,  to  Marlene  H.  Dortch,  Secretary,  Federal  Communications  Commission,  WC  Docket 
 No.  02-  150  Attach.  at  2-  3  (filed  Sept.  9,  2002)  (AT&  T  September  9  Ex  Parte  Letter). 
 43  BellSouth  Varner  Aff.  at  paras.  117-  26. 


 44  Id.  at  paras.  125,  127-  59. 
 45  Id.  at  paras.  56-  73.  The  PMAP  database  processes  two  billion  records  composing  200  Gigabytes  each  month  to 
 produce  the  Monthly  State  Summary  (MSS)  and  SQM  performance  metric  reports  made  available  to  regulators  and  competing  LECs.  It  currently  contains  a  total  of  2.5  Terabytes  of  data.  Id.  at  paras.  65-  66. 


 46  Id.  at  paras.  74-  88. 
 47  BellSouth  Varner  Aff.  at  paras.  89-  103;  Letter  from  Kathleen  B.  Levitz,  Vice  President    Federal  Regulatory, 
 BellSouth,  to  Marlene  H.  Dortch,  Secretary,  Federal  Communications  Commission,  WC  Docket  No.  02-  150  (filed  July  18,  2002)  (BellSouth  July  18  PMAP  4  System  Analysis  Ex  Parte  Letter);  Letter  from  Kathleen  B.  Levitz,  Vice 


 President    Federal  Regulatory,  BellSouth,  to  Marlene  H.  Dortch,  Secretary,  Federal  Communications  Commission,  WC  Docket  No.  02-  150  (filed  Aug.  5,  2002)  (BellSouth  August  5  Ex  Parte  Letter);  BellSouth  Varner  Reply  Aff.  at 
 paras.  148-  240. 
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 16.  As  we  did  in  the  BellSouth  Georgia/  Louisiana  Order,  we  find  that,  as  a  general  matter,  BellSouths  performance  metric  data  are  accurate,  reliable,  and  useful.  This  is  based  on 
 extensive  third  party  auditing,  48  the  internal  and  external  data  controls,  49  BellSouths  making  available  the  raw  performance  data  to  competing  carriers  and  regulators,  50  BellSouths  readiness 
 to  engage  in  data  reconciliations,  51  and  the  oversight  and  review  of  the  data,  and  of  proposed  changes  to  the  metrics,  provided  by  state  commissions.  We  are  prepared  to  pursue  appropriate 
 enforcement  action  if  evidence  becomes  available  to  the  Commission  sufficient  to  show  that  incorrect  data  were  submitted  to  the  Commission  in  violation  of  Commission  rules. 


 17.  We  also  find  the  PMAP  4.0  metric  results  sufficient  to  rely  on  for  purposes  of  our  analysis  of  BellSouths  performance  in  the  five  states  during  the  relevant  period.  BellSouth 
 recently  converted  from  the  PMAP  2.6  to  the  PMAP  4.0  data  platforms,  and  this  change  is  first  reflected  in  the  April  2002  metric  report.  BellSouth  and  others  have  noted  that  there  were 
 certain  discrepancies  between  the  reports  produced  by  the  two  platforms  for  the  same  months  data,  and  commenter  have  suggested  that  these  discrepancies  prove  that  the  performance  metric 
 data  are  too  unreliable  to  use.  52  We  disagree.  Rather,  we  find,  based  on  the  evidence  currently  before  us  provided  to  us  by  BellSouth  concerning  the  metrics  involved,  and  the  sizes  and  causes 
 of  the  differences  in  results,  that,  for  the  relevant  period,  the  discrepancies  were  usually  small,  often  involving  just  a  handful  of  orders,  and  that  any  discrepancies  affecting  the  key  metrics  we 
 traditionally  rely  on  were  too  small  to  affect  our  analysis  for  the  most  important  product  categories.  53  We  note  that  the  current  audit  of  the  data  in  Georgia,  part  of  which  had  audited  the 
 PMAP  2.6  data,  will  be  extended  to  PMAP  4.0,  and  that  the  Georgia  Commission  will  review  the  implementation  of  4.0.  54  To  ensure  consistency  in  our  data  review,  we  do  not  rely  on  the 
 February  performance  metric  data,  which  was  generated  by  PMAP  2.6,  and  instead  rely  on  four  months  of  data  generated  by  PMAP  4.0  for  March  2002  through  June  2002.  55 


 48  BellSouth  Varner  Aff.  at  paras.  125,  127-  59. 
 49  Id.  at  paras.  117-  26. 
 50  Id.  at  paras.  56-  73. 
 51  BellSouth  Varner  Reply  Aff.  at  paras.  15-  24. 
 52  BellSouth  Varner  Aff.  at  paras.  92-  103;  AT&  T  Bursh/  Norris  Reply  Decl.  at  paras.  23-  43. 
 53  BellSouth  Varner  Aff.  at  paras.  89-  103;  BellSouth  July  18  PMAP  4  System  Analysis  Ex  Parte  Letter; 
 BellSouth  August  5  Ex  Parte  Letter;  BellSouth  Varner  Reply  Aff.  at  paras.  148-  240. 
 54  BellSouth  Varner  Aff.  at  paras.  104-  08  &  Exh.  PM-  29. 


 55  Although  the  change  from  PMAP  2.6  to  PMAP  4.0  took  place  in  April  2002,  BellSouth  recalculated  the  March 
 2002  data  for  each  of  the  five  states  and  Georgia  using  PMAP  4.0  and  submitted  the  results.  See,  e.  g.,  Letter  from  Kathleen  B.  Levitz,  Vice  President    Federal  Regulatory,  BellSouth,  to  Marlene  H.  Dortch,  Secretary,  Federal 


 Communications  Commission,  WC  Docket  No.  02-  150  (filed  July  3,  2002)  (BellSouth  July  3  Alabama  PMAP  4.0  Data  Ex  Parte  Letter);  Letter  from  Kathleen  B.  Levitz,  Vice  President    Federal  Regulatory,  BellSouth,  to  Marlene 
 H.  Dortch,  Secretary,  Federal  Communications  Commission,  WC  Docket  No.  02-  150  (filed  July  3,  2002)  (BellSouth  July  3  North  Carolina  PMAP  4.0  Data  Ex  Parte  Letter). 
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 18.  We  reject  AT&  T  and  ITC^  DeltaComs  argument  that  BellSouths  deficiencies  in  data  reconciliation  processes  with  competitive  LECs  preclude  our  reliance  on  BellSouths  data. 
 While  it  is  in  general  difficult  to  determine  whether  one  side  or  the  other  failed  to  act  in  good  faith  in  this  area,  either  because  they  did  not  make  reasonable  attempts  to  set  up  meetings,  or  did 
 not  provide  reasonable  requests  for  information,  or  provided  inadequate  responses  to  such  requests,  BellSouth  has  provided  evidence  that  it  has  responded  to  AT&  Ts  and  ITC^  Deltacoms 
 requests  to  meet,  and  did  provide  answers  to  questions  about  the  data.  56  We  note  the  importance  of  engaging  in  data  reconciliation  with  requesting  carriers,  and  of  making  the  appropriate  subject 
 matter  experts  available  for  answering  questions,  and  expect  BellSouth  to  maintain  this  policy.  57  We  cannot  overstate  the  importance  that  BellSouth  meet  with  competing  carriers  that  have 
 concerns  about  BellSouths  published  performance  metric  data  and,  when  appropriate,  engage  in  data  reconciliation  with  carriers. 


 19.  For  all  these  reasons,  we  find  that  BellSouths  data  is  sufficiently  reliable  for  purposes  of  our  section  271  analysis.  58  However,  where  specific  credible  challenges  have  been 
 made  to  the  BellSouth  data,  particularly  with  respect  to  checklist  items  2  and  4,  we  will  exercise  our  discretion  to  give  that  data  lesser  weight,  and,  as,  discussed  more  fully  below,  look  to  other 
 evidence  in  evaluating  whether  BellSouth  has  met  its  obligations  under  section  271.  Independent  of  our  section  271  determination  here,  we  note  that  access  to  complete  and  accurate 
 data  will  be  important  to  the  Commissions  assessment  of  BellSouths  future  performance  for  section  271(  d)(  6)  compliance.  As  discussed  below,  BellSouth  is  required  to  report  to  the 
 Commission  all  monthly  MSS  performance  metrics  reports  and  Self-  Effectuating  Enforcement  Mechanism  (SEEM)  monthly  reports  for  each  of  the  five  states.  Failure  to  provide  complete  and 
 accurate  data  to  the  Commission  could  result  in  enforcement  action. 
 IV.  PRIMARY  ISSUES  IN  DISPUTE 
 20.  As  in  past  section  271  orders,  we  will  not  repeat  here  the  analytical  framework  and  particular  legal  showing  required  to  establish  checklist  compliance  with  every  checklist 


 item.  Rather,  we  rely  on  the  legal  and  analytical  precedent  established  in  prior  section  271  orders,  and  we  attach  comprehensive  appendices  containing  performance  data  and  the  statutory 
 framework  for  evaluating  section  271  applications.  59  Our  conclusions  in  this  Order  are  based  on, 


 56  BellSouth  Varner  Reply  Aff.  at  paras.  15-  24  &  Exhs.  PM-  6,  6a. 
 57  We  encourage  commenters  that  are  dissatisfied  with  BellSouths  current  policy  to  raise  the  need  for  a  more 
 formal  process  before  the  relevant  state  commissions. 
 58  We  note  that  our  approval  of  this  application  is  based  upon  the  evidence  before  us,  including  the  metric  data 
 submitted.  If  new  evidence  becomes  available,  such  as  exceptions  found  by  KPMG  as  part  of  its  audit,  which  demonstrate  that  there  are  significant  problems  with  the  metric  data,  this  may  have  a  significant  impact  on  our 


 evaluation  of  the  metric  evidence  in  future  section  271  applications.  In  addition,  if  such  new  evidence  demonstrates  that  BellSouth  is  not  meeting  its  section  271  obligations  in  the  five  states,  this  may  constitute  grounds  for  an 
 enforcement  action  under  section  271(  d)(  6).  See  47  U.  S.  C.    271(  d)(  6). 
 59  See  generally  Appendices  B  (Alabama  Performance  Data),  C  (Kentucky  Performance  Data),  D  (Mississippi 
 Performance  Data),  E  (North  Carolina  Performance  Data),  F  (South  Carolina  Performance  Data),  G  (Georgia  (continued.) 
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 among  other  things,  performance  data  as  reported  in  monthly  performance  reports  reflecting  service  in  the  most  recent  months  before  filing  (March  2002  through  June  2002).  60 
 21.  We  focus  in  this  Order  on  the  issues  in  controversy  in  the  record.  Accordingly,  we  begin  by  addressing  whether  the  application  qualifies  for  consideration  under  section 
 271(  c)(  1)(  A)  (Track  A),  which  requires  the  presence  of  facilities-  based  competitors  serving  both  residential  and  business  customers.  Next,  we  address  checklist  item  number  2,  which 
 encompasses  access  to  unbundled  network  elements.  61  We  then  address  checklist  item  numbers  1,  4,  5,  8,  10,  11,  and  12,  which  cover  interconnection,  access  to  unbundled  local  loops, 
 transport,  directory  listings,  databases  and  associated  signaling,  number  portability,  and  dialing  parity,  respectively.  The  remaining  checklist  items  are  discussed  briefly  as  they  received  little  or 
 no  attention  from  commenting  parties,  and  our  own  review  of  the  record  leads  us  to  conclude  that  BellSouth  has  satisfied  these  requirements.  Finally,  we  discuss  issues  concerning 
 compliance  with  section  272  and  the  public  interest  requirements. 
 A.  Compliance  with  Section  271(  c)(  1)(  A) 
 22.  In  order  for  the  Commission  to  approve  a  BOCs  application  to  provide  in-  region,  interLATA  services,  a  BOC  must  first  demonstrate  that  it  satisfies  the  requirements  of  either 


 section  271(  c)(  1)(  A)  (Track  A)  or  271(  c)(  1)(  B)  (Track  B).  62  To  qualify  for  Track  A,  a  BOC  must  have  interconnection  agreements  with  one  or  more  competing  providers  of  telephone  exchange 
 service  .  .  .  to  residential  and  business  subscribers.  63  The  Act  states  that  such  telephone 
 (Continued  from  previous  page)  Performance  Data),  and  H  (Statutory  Requirements).  See  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at 
 9240,  Apps.  B,  C. 
 60  We  examine  data  through  June  2002  because  such  data  performance  occurred  before  comments  were  due  in 
 this  proceeding  on  July  11,  2002.  See  SWBT  Texas  Order,  15  FCC  Rcd  at  18372,  para.  39. 
 61  We  note  that  the  United  States  Court  of  Appeals  for  the  District  of  Columbia  Circuit  recently  opined  in  two 
 relevant  Commission  decisions,  Implementation  of  the  Local  Competition  Provisions  of  the  Telecommunications  Act  of  1996,  Third  Report  and  Order  and  Fourth  Further  Notice  of  Proposed  Rulemaking,  15  FCC  Rcd  3696  (1999) 


 (UNE  Remand  Order)  and  Deployment  of  Wireline  Services  Offering  Advanced  Telecommunications  Capability  and  Implementation  of  the  Local  Competition  Provisions  of  the  Telecommunications  Act  of  1996,  Third  Report  and 
 Order  in  CC  Doc.  No.  98-  147  and  Fourth  Report  and  Order  in  CC  Doc.  No.  96-  98,  14  FCC  Rcd  20912  (1999)  (Line  Sharing  Order).  USTA  v.  FCC,  290  F.  3d  415  (D.  C.  Cir.  2002),  petition  for  rehearing  and  suggestion  for  rehearing 
 en  banc  denied  Sept.  4,  2002.  The  court's  decision  addressed  both  our  UNE  rules  and  our  line  sharing  rules.  The  Commission  is  currently  reviewing  its  UNE  rules,  Review  of  the  Section  251  Unbundling  Obligations  of  Incumbent 
 Local  Exchange  Carriers,  16  FCC  Rcd  22781  (2001)  (Triennial  Review  Notice).  Further,  the  court  stated  that  the  Line  Sharing  Order  must  be  vacated  and  remanded.  USTA  v.  FCC,  290  F.  3d  at  429.  The  court  also  stated  that  it 
 grant[  ed]  the  petitions  for  review[]  and  remand[  ed]  the  Line  Sharing  Order  and  the  Local  Competition  Order  to  the  Commission  for  further  consideration  in  accordance  with  the  principles  outlined.  Id.  at  430.  On  September  4, 
 2002,  the  D.  C.  Circuit  denied  petitions  for  rehearing  filed  by  the  Commission  and  others.  See  Order,  Nos.  00-  1012  and  00-  1015  (D.  C.  Cir.  filed  Sept.  4,  2002). 


 62  47  U.  S.  C.    271(  d)(  3)(  A). 
 63  Id. 
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 service  may  be  offered  .  .  .  either  exclusively  over  [the  competitors]  own  telephone  exchange  service  facilities  or  predominantly  over  [the  competitors]  own  telephone  exchange  facilities  in 
 combination  with  the  resale  of  the  telecommunications  services  of  another  carrier.  64  The  Commission  has  concluded  that  section  271(  c)(  1)(  A)  is  satisfied  if  one  or  more  competing 
 providers  collectively  serve  residential  and  business  subscribers,  65  and  that  unbundled  network  elements  are  a  competing  providers  own  telephone  exchange  service  facilities  for  purposes  of 
 section  271(  c)(  1)(  A).  66  The  Commission  has  further  held  that  a  BOC  must  show  that  at  least  one  competing  provider  constitutes  an  actual  commercial  alternative  to  the  BOC,  67  which  a  BOC 
 can  do  by  demonstrating  that  the  provider  serves  more  than  a  de  minimis  number  of  subscribers.  68  The  Commission  has  interpreted  Track  A  not  to  require  any  particular  level  of 
 market  penetration,  however,  and  the  D.  C.  Circuit  has  affirmed  that  the  Act  imposes  no  volume  requirements  for  satisfaction  of  Track  A.  69 


 23.  We  conclude  that  BellSouth  satisfies  the  requirements  of  Track  A  in  Alabama.  We  base  this  decision  on  the  interconnection  agreements  BellSouth  has  implemented  with 
 competing  carriers  in  Alabama  and  the  number  of  firms  that  provide  local  telephone  exchange  service,  either  exclusively  or  predominantly  over  their  own  facilities,  to  residential  and  business 
 customers.  70  In  support  of  its  Track  A  showing,  BellSouth  relies  on  interconnection  agreements  with,  among  others,  Birch,  ICG  Communications,  ITC^  DeltaCom,  and  Knology.  71  Each  of  these 
 carriers  has  an  approved  interconnection  agreement  with  BellSouth,  and  each  provides  facilities- 


 64  Id. 
 65  Application  of  Ameritech  Michigan  Pursuant  to  Section  271  of  the  Communications  Act  of  1934,  as  amended, 
 To  Provide  In-  Region,  InterLATA  Services  in  Michigan,  CC  Docket  No.  97-  137,  Memorandum  Opinion  and  Order,  12  FCC  Rcd  20543,  20589,  para.  85  (1997)  (Ameritech  Michigan  Order);  see  also  Application  of  BellSouth 


 Corporation,  BellSouth  Telecommunications,  Inc.,  and  BellSouth  Long  Distance,  Inc.,  for  Provision  of  In-  Region,  InterLATA  Services  in  Louisiana,  CC  Docket  No.  98-  121,  Memorandum  Opinion  and  Order,  13  FCC  Rcd  20599, 
 20633-  35,  paras.  46-  48  (1998)  (Second  BellSouth  Louisiana  Order). 
 66  Ameritech  Michigan  Order,  12  FCC  Rcd  at  20598,  para.  101. 


 67  Application  by  SBC  Communications  Inc.,  Pursuant  to  Section  271  of  the  Communications  Act  of  1934,  as 
 amended,  To  Provide  In-  Region,  InterLATA  Services  in  Oklahoma,  CC  Docket  No.  97-  121,  Memorandum  Opinion  and  Order,  12  FCC  Rcd  8685,  8695,  para.  14  (1997)  (SWBT  Oklahoma  Order). 


 68  SWBT  Kansas/  Oklahoma  Order,  16  FCC  Rcd  at  6257,  para.  42;  see  also  Ameritech  Michigan  Order,  12  FCC 
 Rcd  at  20585,  para.  78. 
 69  Sprint  v.  FCC,  274  F.  3d  at  553-  54;  see  also  SBC  Communications  Inc.  v.  FCC,  138  F.  3d  410,  416  (D.  C.  Cir. 
 1998)  (SBC  v.  FCC)  (  Track  A  does  not  indicate  just  how  much  competition  a  provider  must  offer  either  the  business  or  residential  markets  before  it  is  deemed  a  competing  provider.) 


 70  BellSouth  Application  at  20-  21;  see  also  BellSouth  Stockdale  Aff.  at  paras.  6a,  57  &  Exhs.  ES-  1,  ES-  6,  ES-  11- 
 ES-  13  (citing  confidential  information). 
 71  BellSouth  Application  at  20-  21;  BellSouth  Stockdale  Aff.  at  paras.  17,  19  &  Table  2. 
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 based  service  to  both  business  and  residential  customers.  72  We  find  that  each  of  these  carriers  serves  more  than  a  de  minimis  number  of  residential  and  business  customers  predominantly  over 
 its  own  facilities  and  represents  an  actual  commercial  alternative  to  BellSouth  in  Alabama.  73  No  commenter  has  challenged  BellSouths  assertion  that  it  satisfies  the  requirements  for  Track  A 
 in  Alabama. 
 24.  In  Kentucky,  we  also  find  that  BellSouth  demonstrates  that  it  satisfies  the  requirements  of  Track  A  based  on  the  interconnection  agreements  it  has  implemented  with 


 competing  carriers  and  the  numerous  carriers  providing  facilities-  based  service  to  residential  and  business  customers  in  this  market.  74  In  support  of  its  Track  A  showing,  BellSouth  relies  on 
 interconnection  agreements  with,  among  others,  AT&  T  and  The  Other  Phone  Company  (AccessOne,  Talk.  Com,  Omnicall).  75  The  record  demonstrates  that  each  of  these  carriers  serves 
 more  than  a  de  minimis  number  of  residential  and  business  customers  via  UNE-  P  or  full-  facilities  lines.  76  Thus,  we  find  that  there  is  an  actual  commercial  alternative  to  BellSouth  in  Kentucky 
 and  that  BellSouth  satisfies  the  requirements  of  Track  A  in  Kentucky.  No  commenter  has  challenged  BellSouths  assertion  that  it  satisfies  the  requirements  for  Track  A  in  Kentucky. 


 25.  Based  on  the  evidence  in  the  record,  we  find  that  BellSouth  satisfies  Track  A  in  Mississippi.  In  support  of  its  showing,  BellSouth  cites  interconnection  agreements  with,  among 
 others,  ExpeTel  (LS-  One)  and  The  Other  Phone  Company  (AccessOne,  Talk.  Com,  Omnicall),  each  of  which  independently  satisfies  the  requirements  of  Track  A.  77  We  find  that  each  of  these 
 carriers  serves  more  than  a  de  minimis  number  of  residential  and  business  customers  predominantly  over  its  own  facilities.  This  represents  an  actual  commercial  alternative  to 
 BellSouth  in  Mississippi,  and  thus  we  conclude  that  BellSouth  satisfies  the  requirements  of  Track  A  in  that  state.  No  commenter  has  challenged  BellSouths  assertion  that  it  satisfies  the 
 requirements  for  Track  A  in  Mississippi. 
 26.  We  also  find  that  BellSouth  satisfies  the  requirements  of  Track  A  in  North  Carolina.  We  base  this  conclusion  on  interconnection  agreements  BellSouth  has  implemented 


 with  competitive  LECs,  and  the  numerous  carriers  providing  facilities-  based  service  to 


 72  BellSouth  Stockdale  Aff.  at  para.  19;  BellSouth  Stockdale  Reply  Aff.  at  Exhs.  ES-  3-  ES-  4  (citing  confidential 
 information). 
 73  SWBT  Oklahoma  Order,  12  FCC  Rcd  at  8695,  para.  14. 


 74  BellSouth  provides  evidence  that  there  are  at  least  28  facilities-  based  providers  in  Kentucky.  BellSouth 
 Application  at  21;  BellSouth  Stockdale  Aff.  at  para.  27  &  Table  5. 
 75  BellSouth  Application  at  21;  BellSouth  Stockdale  Aff.  at  para.  29  &  Exh.  ES-  7;  BellSouth  Application 
 Appendix  B-  Kentucky. 
 76  BellSouth  Stockdale  Aff.  at  Exhs.  ES-  14-  ES-  16  (citing  confidential  information);  Stockdale  Reply  Aff.  at 
 Exhs.  ES-  4-  ES-  5  (citing  confidential  information). 
 77  BellSouth  Stockdale  Aff.  at  para.  37  &  Table  8  &  Exh.  ES-  8;  BellSouth  Stockdale  Reply  Aff.  at  para.  37  & 
 Exhs.  ES-  6-  ES-  7  (citing  confidential  information);  BellSouth  Application  Appendix  B-  Mississippi. 
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 residential  and  business  customers  in  North  Carolina.  78  Among  these  facilities-  based  providers  are  Business  Telecom  (BTI),  CTC  Exchange  Services,  MCI/  Worldcom,  and  Time  Warner,  each 
 of  which  serves  more  than  a  de  minimis  number  of  residence  and  business  lines.  79  Notably,  the  North  Carolina  Commission  concludes  that  even  the  most  conservative  estimates  show  that 
 competitive  LECs  serve  more  than  a  de  minimis  number  of  residential  lines  through  their  own  facilities,  and  that  the  number  of  both  residential  and  business  lines  served  by  competitive  LECs 
 is  more  than  sufficient  to  show  that  there  are  competitive  alternatives  to  BellSouth  in  North  Carolina.  80  Given  this  evidence,  we  conclude  that  BellSouth  satisfies  the  requirements  of  Track 
 A  in  North  Carolina.  No  commenter  has  challenged  BellSouths  assertion  that  it  satisfies  the  requirements  for  Track  A  in  North  Carolina. 


 27.  Finally,  we  find  that  BellSouth  satisfies  the  requirements  of  Track  A  in  South  Carolina  based  on  interconnection  agreements  it  has  implemented  with  competitive  carriers  in 
 South  Carolina.  81  The  record  demonstrates  that  Birch,  ITC^  DeltaCom,  Knology,  and  The  Other  Phone  Company  (AccessOne,  Talk.  Com,  Omnicall)  each  serve  more  than  a  de  minimis  number 
 of  residential  and  business  customers  predominately  over  their  own  facilities  and  represent  an  actual  commercial  alternative  to  BellSouth  in  South  Carolina.  82  Given  this  evidence,  we 
 conclude  that  BellSouth  satisfies  the  requirements  of  Track  A  in  South  Carolina.  No  commenter  has  challenged  BellSouths  assertion  that  it  satisfies  the  requirements  for  Track  A  in  South 
 Carolina. 
 B.  Checklist  Item  2    Unbundled  Network  Elements 
 28.  Checklist  item  2  of  section  271  states  that  a  BOC  must  provide  nondiscriminatory  access  to  network  elements  in  accordance  with  sections  251(  c)(  3)  and 


 252(  d)(  1)  of  the  Act.  83  Section  251(  c)(  3)  requires  incumbent  LECs  to  provide 


 78  BellSouth  Stockdale  Aff.  at  para.  43. 
 79  BellSouth  Stockdale  Aff.  at  para.  44;  BellSouth  Stockdale  Reply  Aff.  at  Exhs.  ES-  8-  ES-  9  (citing  confidential 
 information). 
 80  North  Carolina  Commission  Comments  at  255. 


 81  BellSouth  Application  at  23. 
 82  Id.  See  also  BellSouth  Stockdale  Reply  Aff.  at  Exhs.  ES-  10-  ES-  11  (citing  confidential  information). 
 83  47  U.  S.  C.    271(  B)(  ii).  Overturning  a  1997  decision  of  the  Eighth  Circuit  Court  of  Appeals,  on  May  13,  2002, 
 the  U.  S.  Supreme  Court  upheld  sections  51.315(  c)-(  f)  of  the  Commissions  rules,  which,  subject  to  certain  limitations,  require  incumbent  LECs  to  provide  combinations  of  unbundled  network  elements  not  ordinarily 


 combined  in  the  incumbent  LECs  network  and  to  combine  unbundled  network  elements  with  the  elements  possessed  by  the  requesting  telecommunications  carrier.  Verizon  Communications,  Inc.  v.  FCC,  122  S.  Ct.  1646 
 (2002).  In  a  prior  decision,  the  Supreme  Court  upheld  the  Commissions  authority  to  adopt  sections  51.315(  a)-(  b)  of  the  Commissions  rules,  which  establish  the  general  obligation  of  an  incumbent  LEC  to  provide  combinations  of 
 network  elements  and  require  an  incumbent  LEC  not  to  separate  requested  elements  that  it  currently  combines,  except  upon  request.  AT&  T  Corp.  v.  Iowa  Utils.  Bd.,  525  U.  S.  366,  385,  393-  95  (1999). 
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 nondiscriminatory  access  to  network  elements  on  an  unbundled  basis  at  any  technically  feasible  point  on  rates,  terms,  and  conditions  that  are  just,  reasonable,  and  nondiscriminatory.  84 
 1.  Pricing  of  Unbundled  Network  Elements 
 29.  Section  252(  d)(  1)  provides  that  a  state  commissions  determination  of  the  just  and  reasonable  rates  for  network  elements  must  be  nondiscriminatory,  based  on  the  cost  of  providing 


 the  network  elements,  and  may  include  a  reasonable  profit.  85  Pursuant  to  this  statutory  mandate,  the  Commission  has  determined  that  prices  for  unbundled  network  elements  (UNEs)  must  be 
 based  on  the  total  element  long  run  incremental  cost  (TELRIC)  of  providing  those  elements.  86 
 30.  In  applying  the  Commissions  TELRIC  pricing  principles  in  this  application,  we  do  not  conduct  a  de  novo  review  of  a  states  pricing  determinations.  87  We  will,  however,  reject 


 an  application  if  basic  TELRIC  principles  are  violated  or  the  state  commission  makes  clear  errors  in  factual  findings  on  matters  so  substantial  that  the  end  result  falls  outside  the  range  that 
 the  reasonable  application  of  TELRIC  principles  would  produce.  88  We  note  that  different  states  may  reach  different  results  that  are  each  within  the  range  of  what  a  reasonable  application  of 
 TELRIC  principles  would  produce.  Accordingly,  an  input  rejected  elsewhere  might  be  reasonable  under  the  specific  circumstances  here. 


 31.  Commenters  in  these  proceedings  assert  numerous  challenges  to  BellSouths  pricing  that  were  never  raised  before  the  state  commissions.  Just  as  it  is  impractical  for  us  to 
 conduct  a  de  novo  review  of  the  state  commissions  pricing  determinations,  it  is  likewise  generally  impractical  for  us  to  make  determinations  about  issues  that  were  not  specifically  raised 
 before  the  state  commissions  in  the  first  instance.  During  the  course  of  their  UNE  pricing  proceedings,  the  state  commissions  are  able  to  cross  examine  witnesses,  compel  discovery,  and 
 direct  the  submission  of  additional  record  evidence  on  particular  issues.  This  Commission  lacks  the  time  to  employ  such  tools  during  the  course  of  the  90-  day  statutory  review  period  for  section 
 271  applications.  Without  the  means  to  test  and  evaluate  evidence  during  this  short  statutory 


 84  47  U.  S.  C.    251(  c)(  3). 
 85  47  U.  S.  C.    252(  d)(  1). 
 86  See  Implementation  of  the  Local  Competition  Provisions  in  the  Telecommunications  Act  of  1996,  CC  Docket 
 No.  96-  98,  First  Report  and  Order,  11  FCC  Rcd  15499,  15844-  47,  paras.  674-  79  (1996)  (Local  Competition  Order);  47  C.  F.  R.    51.501-  51.515.  The  Supreme  Court  has  recently  upheld  the  Commissions  forward-  looking  pricing 


 methodology  in  determining  the  costs  of  UNEs.  Verizon  v.  FCC,  122  S.  Ct.  at  1679. 
 87  Application  of  Verizon  Pennsylvania  Inc.,  Verizon  Long  Distance,  Verizon  Enterprise  Solutions,  Verizon 
 Global  Networks  Inc.,  and  Verizon  Select  Services  Inc.  for  Authorization  To  Provide  In-  Region,  InterLATA  Services  in  Pennsylvania,  CC  Docket  No.  01-  138,  Memorandum  Opinion  and  Order,  16  FCC  Rcd  17419,  17453,  para.  55 


 (2001)  (Verizon  Pennsylvania  Order)  (citations  omitted);  see  also  Sprint  v.  FCC,  274  F.  3d  at  556  (  When  the  Commission  adjudicates    271  applications,  it  does  not    and  cannot    conduct  de  novo  review  of  state  rate-  setting 
 determinations.  Instead,  it  makes  a  general  assessment  of  compliance  with  TELRIC  principles.). 
 88  Verizon  Pennsylvania  Order,  16  FCC  Rcd  at  17453,  para.  55. 
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 review  period,  and  without  a  state  record  to  analyze  with  respect  to  issues  not  raised  before  the  state  commissions,  we  are  often  left  to  resolve  factually  complex  issues  based  simply  on  the 
 untested  written  assertions  of  various  experts. 
 32.  We  take  this  opportunity  to  set  forth  the  analytical  framework  we  employ  to  review  section  271  applications  in  these  situations.  As  the  Commissions  previous  decisions 


 make  clear,  a  BOC  may  submit  as  part  of  its  prima  facie  case  a  valid  pricing  determination  from  a  state  commission.  In  such  cases,  we  will  conclude  that  the  BOC  meets  the  TELRIC  pricing 
 requirements  of  section  271,  89  unless  we  find  that  the  determination  violates  basic  TELRIC  principles  or  contains  clear  errors  of  fact  on  matters  so  substantial  that  the  end  result  falls  outside 
 the  range  that  a  reasonable  application  of  TELRIC  principles  would  produce.  90  Once  the  BOC  makes  a  prima  facie  case  of  compliance,  the  objecting  party  must  proffer  evidence  that 
 persuasively  rebuts  the  BOCs  prima  facie  showing.  The  burden  then  shifts  to  the  BOC  to  demonstrate  the  validity  of  its  evidence  or  the  state  commissions  approval  of  the  disputed  rate 
 or  charge.  91  When  a  party  raises  a  challenge  related  to  a  pricing  issue  for  the  first  time  in  the  Commissions  section  271  proceedings  without  showing  why  it  was  not  possible  to  raise  it 
 before  the  state  commission,  we  may  exercise  our  discretion  to  give  this  challenge  little  weight.  In  such  cases,  we  will  not  find  that  the  objecting  party  persuasively  rebuts  the  prima  facie 
 showing  of  TELRIC  compliance  if  the  BOC  provides  a  reasonable  explanation  concerning  the  issue  raised  by  the  objecting  party. 


 33.  With  these  principles  in  mind  and  after  thoroughly  reviewing  the  record  in  this  application,  we  find  that  BellSouths  UNE  rates  in  Alabama,  Kentucky,  Mississippi,  North 
 Carolina,  and  South  Carolina  are  just,  reasonable,  and  nondiscriminatory,  and  are  based  on  cost  plus  a  reasonable  profit  as  required  by  section  252(  d)(  1).  We  therefore  find  that  BellSouths 
 UNE  rates  in  the  five  states  satisfy  checklist  item  2.  Before  we  discuss  commenters  arguments  and  our  conclusions,  we  summarize  the  pricing  proceedings  in  each  of  the  five  states. 


 89  When  a  state  commission  makes  a  determination  that  rates  are  TELRIC-  compliant,  it  may  not  have  explicitly 
 analyzed  every  component  of  such  rates,  particularly  when  no  party  has  taken  issue  with  the  component.  Indeed,  we  do  not  provide  extensive  analysis  on  checklist  items  that  receive  little  or  no  attention  from  commenters  when  our 


 own  review  of  the  record  leads  us  to  conclude  that  the  BOC  has  satisfied  these  requirements. 
 90  See,  e.  g.,  Application  by  Verizon  New  Jersey  Inc.,  Bell  Atlantic  Communications,  Inc.  (d/  b/  a  Verizon  Long 
 Distance),  NYNEX  Long  Distance  Company  (d/  b/  a  Verizon  Enterprise  Solutions),  Verizon  Global  Networks  Inc.,  and  Verizon  Select  Services  Inc.,  for  Authorization  To  Provide  In-  Region,  InterLATA  Services  in  New  Jersey,  WC 


 Docket  No.  02-  67,  Memorandum  Opinion  and  Order,  17  FCC  Rcd  12275,  12305,  para.  68  (2002)  (Verizon  New  Jersey  Order). 


 91  Second  BellSouth  Louisiana  Order,  13  FCC  Rcd  at  20635-  39,  paras.  51-  59. 
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 a.  Background 
 34.  Alabama.  By  order  dated  August  25,  1998,  the  Alabama  Commission  first  established  UNE  rates  for  BellSouth  in  Docket  26029.  92  On  October  5,  2000,  the  Alabama 


 Commission  opened  Docket  27821  to  establish  interim  and/  or  permanent  rates  for  xDSL  loops  and  related  elements  and  services.  After  initially  denying  a  BellSouth  motion  to  consolidate 
 Docket  26029  (xDSL)  with  Docket  25980  (UNE  rates),  the  Alabama  Commission  reconsidered,  finding  that  a  combined  proceeding  for  BellSouth  would  result  in  the  most  efficient  use  of  the 
 resources  of  all  parties,  including  the  [Alabama]  Commission,  and  would  minimize  the  possibility  of  duplicative  proceedings  and  inconsistent  decisions  by  the  [Alabama] 
 Commission.  93  Hearings  on  the  newly  combined  docket  were  held  on  May  14-  18,  2001.  A  total  of  20  witnesses  testified,  and  additional  witnesses  filed  written  testimony  on  behalf  of  the 
 various  parties,  including  BellSouth,  ITC^  DeltaCom,  Covad,  BroadSlate,  WorldCom,  and  SECCA. 


 35.  In  its  UNE  Rate  Order,  the  Alabama  Commission  stated  that,  in  evaluating  BellSouths  UNE  pricing,  it  followed  the  Commissions  TELRIC  pricing  rules.  94  The  Alabama 
 Commission  also  adopted  the  following  BellSouth  cost  models:  (1)  the  BellSouth  Telecommunications  Loop  Model  (BSTLM)  to  support  the  cost  development  for  UNEs,  service-specific 
 loops,  and  UNE  combinations;  (2)  the  Model  Office  Module  of  Telecordias  Switching  Cost  Information  System  Model  (SCIS/  MO)  and  the  Simplified  Switching  Tool  (SST)  Model  to 
 support  the  cost  development  for  all  switch-  related  elements,  including  ports,  usage,  and  vertical  features;  (3)  the  BellSouth  Cost  Calculator,  which  converts  input  data  (material 
 prices/  investments  by  field  reporting  code,  recurring  additives,  non-  recurring  additives,  and  work  times  by  job  function  code)  into  non-  recurring  costs;  (4)  the  Capital  Cost  Calculator,  which 
 produces  depreciation,  cost  of  money,  and  income  tax  factors  that  are  applied  to  investments  to  calculate  capital  costs;  and  (5)  the  Loop  Multiplexer,  Digital  Loop  Carrier  (DLC),  SONET,  and 
 DS-  1  price  calculators,  which  develop  the  material  price  of  specialized  components  used  in  provisioning  various  network  capabilities.  95  None  of  the  competitive  LECs  proposed  alternative 
 models  but  focused  their  challenges  on  the  inputs  BellSouth  used  in  its  models.  96  Although  the  Alabama  Commission  determined  that  BellSouths  several  cost  models  were  appropriate  for  the 
 purpose  of  adopting  TELRIC-  compliant  rates,  it  adjusted  many  inputs  to  the  models.  97 


 92  See  Generic  Proceeding  to  Establish  Prices  for  Interconnection  Services  and  Unbundled  Network  Elements, 
 Alabama  Public  Service  Commission,  Order,  Docket  No.  27821  (May  31,  2002)  (UNE  Rate  Order  or  Alabama  Commission  UNE  Rate  Order)  at  2. 


 93  Id.  at  8. 
 94  Id.  at  11-  12. 
 95  Id.  at  13-  14. 
 96  Id.  at  18. 
 97  Id. 
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 36.  With  regard  to  the  BSTLM,  the  Alabama  Commission  accepted  BellSouths  use  of  five  different  scenarios  to  set  TELRIC  rates  and  reduced  BellSouths  recurring  loop  rates  by 
 17.5  percent.  98  In  setting  non-  recurring  rates,  however,  BellSouth  did  not  rely  on  a  cost  model  but  instead  chose  to  make  estimates  of  the  work  times  for  activities  required  to  provision  each 
 element.  99  BellSouth  subject  matter  experts  calculated  the  probability  of  each  activity  occurring.  100  These  estimates  were  then  entered  into  the  BellSouth  Cost  Calculator  on  the  non-recurring 
 input  sheet  by  element  and  multiplied  by  the  appropriate  labor  rate.  101  After  considering  all  of  the  evidence  in  the  record,  the  Alabama  Commission  discounted  non-  recurring 
 charges  by  50  percent,  with  the  exception  of  certain  xDSL  non-  recurring  charges,  which  were  reduced  by  53  percent.  102 


 37.  The  Alabama  Commission  also  addressed  a  number  of  other  pricing  issues  in  the  UNE  Rate  Order,  including  collocation  costs,  xDSL  loops,  loop  conditioning,  UNE  deaveraging, 
 line  splitting  and  sharing,  and  UNE  combinations.  The  Alabama  Commission  stated  that  it  would  entertain  requests  in  the  future  for  rate  modification  that  are  appropriately  supported  and 
 filed.  103 
 38.  Kentucky.  The  Kentucky  Commission  established  UNE  prices  and  the  methodology  for  establishing  UNE  and  interconnection  rates  on  December  18,  2001,  following 


 an  extensive  two-  year  proceeding.  104  The  proceeding  included  three  rounds  of  data  requests  and  responses,  105  as  well  as  informal  conferences  with  the  parties.  106  In  addition  to  reviewing  the 


 98  Id.  at  24-  25,  40-  41.  BellSouth  separately  determines  prices  for  loop  and  ports  on  a  stand-  alone  basis  and  loops 
 and  ports  in  combination.  See  section  IV.  B.  1.  b.(  i),  infra.  The  Commission  previously  approved  this  multiple  scenario  pricing  methodology  in  the  BellSouth  Georgia/  Louisiana  Order.  See  BellSouth  Georgia/  Louisiana 


 Order,  17  FCC  Rcd  at  9041,  para.  38. 
 99  Alabama  Commission  UNE  Rate  Order  at  40. 


 100  Id. 
 101  Id. 
 102  Id.  at  42. 
 103  Id.  at  90. 
 104  BellSouth  Application  App.  D,  Vol.  2,  Tab  17,  Administrative  Case  No.  382,  Kentucky  Commissions  Inquiry 
 into  the  Development  of  Deaveraged  Rates  for  Unbundled  Network  Elements  (Dec.  18,  2001)  (Kentucky  Commission  UNE  Rate  Order).  The  Kentucky  Commission  noted  also  that  it  had  previously  established 


 methodologies,  interconnection  prices,  and  UNE  prices  through  arbitration  proceedings.  Id.  at  2  (citing  Case  Nos.  96-  431,  Petition  by  MCI  for  Arbitration  of  Terms  and  Conditions  of  a  Proposed  Agreement  with  BellSouth 
 Telecommunications,  Inc.  Concerning  Interconnection  and  Resale  under  the  Telecommunications  Act  of  1996,  and  96-  478,  The  Interconnection  Agreement  Negotiations  Between  AT&  T  Communications  of  the  South  Central  States, 
 Inc.,  and  BellSouth  Telecommunications,  Inc.  Pursuant  to  47  U.  S.  C.  [sic]). 
 105  Kentucky  Commission  UNE  Rate  Order  at  6. 


 106  Id.  at  8. 
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 record  in  its  own  proceeding,  the  Kentucky  Commission  reviewed  the  records  and  decisions  of  other  commissions  in  the  BellSouth  region  regarding  the  development  of  UNE  rates.  107  In 
 conducting  its  evaluation  of  UNE  rates,  staff  from  the  Kentucky  Commission,  along  with  staff  from  the  Alabama  Commission,  traveled  to  the  offices  of  the  Florida  Commission  to  discuss 
 cost  study  models,  inputs  and  expected  results.  108  Although  the  Kentucky  Commission  specifically  solicited  requests  for  a  live  hearing,  no  party  requested  a  hearing.  109 


 39.  During  the  proceeding,  there  was  little,  if  any,  dispute  regarding  the  use  of  the  models  submitted  by  BellSouth,  110  which,  as  in  Alabama  and  Louisiana,  included  BSTLM, 
 SCIS/  MO,  SST,  the  BellSouth  Cost  Calculator,  the  Capital  Cost  Calculator,  the  SONET  Price  Calculator,  and  DS-  1  Channelization  Price  Calculator.  111  The  BellSouth  Cost  Calculator,  used  to 
 determine  non-  recurring  rates,  included  BellSouth  estimates  of  work  times  for  activities  required  to  provision  each  element  and  the  probability  of  each  activity  occurring.  112  Only  WorldCom  and 
 SECCA  filed  a  rebuttal  to  the  cost  studies  and  testimony  submitted  by  BellSouth,  113  which  the  Kentucky  Commission  evaluated  in  its  Order. 


 40.  The  Kentucky  Commission  adopted  the  results  of  a  late-  filed  run  of  BellSouths  cost  models,  which  resulted  in  an  additional  17.7  percent  reduction  in  UNE  rates.  114  During  the 
 course  of  the  proceeding,  the  Kentucky  Commission  approved  a  joint  stipulation  specifying  certain  deaveraged  rates  applying  to  a  limited  number  of  commonly  sought  network  elements.  115 
 In  concluding  its  proceeding,  the  Kentucky  Commission  adopted  rates  that  it  found  to  be  reasonable,  forward-  looking,  TELRIC-  based  prices,  while  also  advising  that  it  would 
 continually  monitor  the  appropriateness  of  these  rates.  116  Additionally,  the  Kentucky  Commission  ordered  BellSouth  to  submit  copies  of  all  documents  and  information  supplied  to 


 107  Id.  at  6. 
 108  Id. 
 109  Id. 
 110  Id.  at  8. 
 111  Id.  at  9-  11. 
 112  Id.  at  30-  31. 
 113  Id.  at  5. 
 114  Id.  at  35. 
 115  The  Joint  Stipulation  was  filed  by  AT&  T  of  the  South  Central  States,  Inc.,  BellSouth,  Cincinnati  Bell 
 Telephone,  GTE  South  Inc.  n/  k/  a  Verizon  South,  Inc.,  WorldCom,  and  TCG  of  Ohio.  This  stipulation  was  adopted  by  order  on  March  24,  2000,  and  implemented  on  May  1,  2000.  See  id.  at  2-  3. 


 116  Id.  at  35. 
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 the  Florida  Commission  in  its  UNE  docket  within  ten  days  of  filing  in  Florida  and  also  ordered  that  the  decisions  reached  by  the  Florida  Commission  would  be  implemented  in  Kentucky.  117 
 41.  Mississippi.  The  Mississippi  Commission  set  UNE  rates  over  the  course  of  three  proceedings  with  a  stated  goal  of  establishing  cost-  based  rates  that  are  consistent  with  the 
 Commissions  TELRIC  methodology.  118  It  first  established  permanent  rates  for  UNEs  and  interconnection  services  in  by  order  dated  August  25,  1998.  119  Then,  by  Order  dated  April  20, 
 2000,  the  Mississippi  Commission  established  different  rates  for  certain  UNEs  in  four  cost-related  rate  zones  within  the  State  of  Mississippi  in  order  to  reflect  geographic  cost 
 differences.  120  Subsequently,  in  response  to  a  petition  from  BellSouth  dated  December  8,  2000,  the  Mississippi  Commission  opened  a  proceeding  to  (1)  update  the  UNE  rates  that  it  had 
 established  in  1998;  (2)  establish  rates  for  additional  UNEs  identified  by  this  Commission  in  various  orders  issued  subsequent  to  the  Mississippi  Commissions  earlier  UNE  pricing  order; 
 and  (3)  set  permanent  geographically  deaveraged  rates  for  certain  UNEs  and  combinations  of  UNEs.  121 


 42.  As  part  of  this  proceeding,  the  Mississippi  Commission  conducted  an  evidentiary  hearing  on  June  26-  28,  2001,  in  which  BellSouth,  Brooks  Fiber,  WorldCom,  Access  Integrated, 
 and  DixieNet  participated.  122  On  October  12,  2001,  the  Mississippi  Commission  issued  a  final  UNE  rate  order.  123 


 43.  In  that  order,  the  Mississippi  Commission  found  that  BellSouths  cost  studies  complied  with  all  applicable  legal  standards  and  should  be  used  to  set  UNE  prices.  124  With 
 respect  to  recurring  UNE  rates,  the  Commission  found,  with  certain  modifications  discussed  below,  that  BellSouths  rates  were  cost-  based  and  were  the  product  of  detailed  cost  studies  that 


 117  Id.  at  38. 
 118  Generic  Proceeding  to  Establish  BellSouth  Telecommunications,  Inc.  s  Interconnection  Services,  Unbundled 
 Network  Elements  and  Other  Related  Elements  and  Services,  Docket  No.  00-  UA-  999  (Oct.  12,  2001)  (Mississippi  Commission  UNE  Rate  Order)  at  4-  10  (citing  Docket  No.  97-  AD-  544). 


 119  Id.  at  1. 
 120  PSCs  Order  Approving  UNE  Rates  for  BellSouth  per  Attached  Joint  Stipulation,  Docket  No.  2000-  AD-  42 
 (April  20,  2000).  These  rates  were  either  stipulated  to,  or  were  unopposed,  by  the  parties  in  that  docket  and  were  based  upon  the  statewide  deaveraged  rates  that  the  Mississippi  Commission  established  by  order  dated  August  25, 


 1998,  in  Docket  No.  97-  AD-  544.  See  Mississippi  Commission  UNE  Rate  Order  at  1-  2. 
 121  Id.  at  2.  See  BellSouths  Petition  for  Establishment  of  Generic  Proceeding  To  Establish  Prices  for  BellSouths 
 Interconnection  Services,  Unbundled  Network  Elements,  and  Other  Related  Elements  and  Services,  Docket  No.  00-  UA-  999  (Dec.  8,  2000). 


 122  Mississippi  Commission  UNE  Rate  Order  at  2-  3. 
 123  Id.  at  49. 
 124  Id.  at  8. 
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 complied  fully  with  the  pricing  standards  set  forth  in  the  Act  and  with  the  [Commissions]  pricing  rules.  125  Specifically,  the  Mississippi  Commission  found  that  the  BSTLM  properly 
 calculated  the  costs  of  loops  and  loop-  related  UNEs  126  and  that  BellSouths  use  of  five  BSTLM  scenarios  was  reasonable.  127 


 44.  The  Mississippi  Commission  also  rejected  most  of  WorldComs  proposed  input  changes  to  BellSouths  recurring  cost  studies,  including  inputs  relating  to  network  design; 
 engineering  assumptions;  structure,  cable,  and  material  costs;  and  expense  and  common  costs.  128  The  Mississippi  Commission  found  that  it  was  reasonable  to  use  economic  lives  that  it  adopted 
 in  1995  to  determine  BellSouths  depreciation  expense  129  rather  than  the  shorter  economic  lives  proposed  by  BellSouth,  which  were  based  on  a  2000  depreciation  study.  130  It  decided  to  use  an 
 overall  cost  of  capital  of  10  percent,  also  adopted  in  a  previous  order,  131  rather  than  the  11.25  percent  proposed  by  BellSouth.  132  In  addition,  the  Mississippi  Commission  imposed  a 
 competitive  discount  of  approximately  ten  percent  on  all  loop  and  UNE  combination  recurring  charges.  133 


 45.  With  respect  to  nonrecurring  charges  proposed  by  BellSouth,  the  Mississippi  Commission  adopted  a  50  percent  discount  in  order  to  further  stimulate  the  development  of 
 competition  in  Mississippi.  134  It  rejected,  however,  WorldComs  proposal  to  eliminate  non-recurring  charges  for  certain  collocation  costs,  OSS,  and  service  orders.  135  The  Mississippi 
 Commission  also  found  that  the  Unbundled  Loop  Modification  (ULM)  rates  for  load  coil  and  bridged  tap  removal  should  apply  whenever  BellSouth  performed  this  work  at  the  request  of  a 
 CLEC.  136  It  concluded,  however,  that  the  ULM-  Additive,  which  was  designed  to  recover  part 


 125  Id.  at  10. 
 126  Id.  at  11. 
 127  Id.  at  11-  14. 
 128  Id.  at  14-  24. 
 129  Id.  at  24. 
 130  Proceeding  to  Establish  BellSouth  Telecommunications,  Inc.  s  Interconnection  Services,  Unbundled  Network 
 Elements  and  Other  Related  Elements  and  Services,  Docket  No.  00-  UA-  999  (Aug.  30,  2001)  (BellSouths  Proposed  Mississippi  UNE  Rate  Order)  at  20-  21. 


 131  Mississippi  Commission  UNE  Rate  Order  at  24. 
 132  BellSouths  Proposed  Mississippi  UNE  Rate  Order  at  21-  22. 
 133  Mississippi  Commission  UNE  Rate  Order  at  24. 
 134  Id.  at  25. 
 135  Id.  at  26-  28. 
 136  Id.  at  35. 
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 of  the  cost  of  removing  load  coils  on  copper  loops  of  less  than  18,000  feet,  was  not  appropriate  and  should  not  be  charged  to  CLECs,  as  BellSouth  had  proposed.  137 
 46.  The  Mississippi  Commission  also  established  different  rates  for  UNEs  in  four  zones  based  on  logical  groupings  using  wire  centers,  proposed  by  BellSouth,  rather  than  the  nine 
 zones  proposed  by  WorldCom.  138  It  ordered  that  only  the  recurring  cost  of  unbundled  loops  and  local  channels  below  the  DS3  level  [including  sub-  loops  and  combinations  involving  those 
 elements]  will  be  geographically  deaveraged.  139  It  also  found  that  BellSouths  modified  daily  usage  file  charges  were  reasonable  and  should  be  adopted.  140 


 47.  North  Carolina.  In  its  UNE  proceeding,  Docket  No.  P-  100,  Sub  133d,  the  North  Carolina  Commission  held  hearings  that  began  in  1997  and  continued  through  2002.  On 
 December  10,  1998,  following  two  weeks  of  hearings  in  which  eight  competitive  LECs  participated  and  the  public  was  represented  by  the  Public  Staff  and  Attorney  General,  the  state 
 commission  adopted  permanent  prices  for  unbundled  network  elements.  141 
 48.  The  North  Carolina  Commission  demonstrated  its  commitment  to  developing  UNE  prices  based  on  a  forward-  looking  cost  methodology  and  the  Commissions  TELRIC 


 principles.  142  The  state  commission,  for  example,  rejected  BellSouths  proposed  residual  cost  additive  for  the  loop  and  port  in  its  1998  UNE  order  on  grounds  that  it  was  inconsistent  with 
 forward-  looking  pricing  and  would  permit  the  reinstatement  of  embedded  or  historical  cost  recovery.  143  The  North  Carolina  Commission  also  concluded  that  it  would  be  more  reasonable 
 to  modify  the  studies  presented  by  the  ILECs  than  to  discard  those  studies  in  favor  of  the  models 


 137  Id.  at  33. 
 138  Id.  at  35. 
 139  Id.  at  38. 
 140  Id.  at  43-  45. 
 141  General  Proceeding  to  Determine  Permanent  Pricing  for  Unbundled  Network  Elements,  Order  Adopting 
 Permanent  Prices  for  Unbundled  Network  Elements,  Docket  No.  P-  100,  Sub  133d  (Dec.  10,  1998)  (North  Carolina  Commission  UNE  Rate  Order).  After  rulings  in  this  docket  on  motions  for  reconsideration  (Aug.  18,  1999)  and  on 


 comments  and  reply  comments  (Jan.  28,  2000),  the  North  Carolina  Commission  issued  an  order  adopting  permanent  UNE  rates  on  March  13,  2000. 


 142  See  id.  at  11. 
 143  Id.  at  17-  18.  In  evaluating  the  appropriate  cost  methodology  for  cost-  based  rates,  the  North  Carolina 
 Commission  noted  the  following:  All  of  the  parties  to  this  proceeding  generally  agreed  and  took  the  position  that  the  appropriate  basis  for  establishing  permanent  prices  for  unbundled  network  elements  is  TELRIC  plus  a 


 reasonable  allocation  of  joint  and  common  costs.  Id.  at  10. 
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 presented  by  AT&  T  and  MCI  and  then  attempt  to  adjust  those  models  to  make  them  suitable  to  North  Carolina.  144 
 49.  North  Carolina  used  BellSouths  BSTLM,  the  Switched  Network  Calculator  Model  for  switching,  and  the  SCIS/  MO  for  ports  and  feature  costs.  Although  the  North  Carolina 
 Commission  adopted  BellSouths  cost  models,  it  modified  several  of  its  inputs,  including  those  related  to  residence/  business  line  weighting,  loop  distribution  fill  factor,  capital  structure,  cost  of 
 capital,  depreciation  and  tax  rates,  and  structure  sharing.  145  As  a  result  of  its  adjustments  and  modifications  to  BellSouths  inputs,  the  North  Carolina  Commission  approved  a  statewide 
 average  loop  cost  of  $15.60,  compared  to  BellSouths  proposed  $19.02.  146  It  also  modified  and  adjusted  BellSouths  nonrecurring  cost  studies  which  it  selected  over  the  Nonrecurring  Cost 
 Model  proposed  by  AT&  T  and  MCI.  147 
 50.  On  March  30,  2000,  the  North  Carolina  Commission  issued  an  order  that  established  a  Phase  I  proceeding  to  consider  geographic  deaveraging  and  issues  arising  from  the 


 Commissions  UNE  Remand  Order  148  and  Line  Sharing  Order.  149  An  evidentiary  hearing  that  began  on  September  25,  2000,  resulted  in  the  North  Carolina  Commission  issuing  an  order 


 144  Id.  at  17-  18;  see  also  Order  Adopting  Forward-  Looking  Economic  Cost  Model  and  Inputs,  Docket  No.  P-  100, 
 Sub  133b  (April  20,  1998)  (North  Carolina  Commission  FLEC  Order)  at  19  (rejecting  AT&  T  and  MCI  Hatfield  5.0  Model  inputs  for  determining  the  forward-  looking  economic  cost  of  providing  universal  service  in  North  Carolina 


 and  concluding  that  company-  specific  inputs,  where  they  are  forward  looking  and  reasonable,  should  be  used  in  lieu  of  default  values). 


 145  North  Carolina  Commission  UNE  Rate  Order  at  28-  29,  36,  41,  43,  50,  66.  The  North  Carolina  Commission 
 found  that  BellSouth  had  incorrectly  excluded  a  number  of  less  costly  business  lines  from  its  loop  sample  and  adjusted  the  residential/  business  line  make-  up  of  the  sample,  reducing  loop  rates  by  over  $1  per  month.  Id.  at  28- 


 29.  See  also  BellSouth  Application  App.  A,  Vol.  2,  Tab  C,  Affidavit  of  D.  Daonne  Caldwell  (BellSouth  Caldwell  Aff.)  at  para.  175.  The  state  commission  increased  BellSouths  distribution  fill  factor  to  44.6%  from  its  proposed 
 41.2%,  consistent  with  the  Universal  Service  Fund  Docket  P-  100,  Sub  133b.  North  Carolina  Commission  UNE  Rate  Order  at  66.  See  also  BellSouth  Caldwell  Aff.  at  para.  35.  The  forward-  looking  overall  cost  of  capital  was 
 changed  to  9.96%,  compared  to  BellSouths  proposed  11.25%.  Id.  at  para.  36.  Structure  sharing  percentages  were  adopted  as  approved  in  Docket  No.  P-  100,  Sub  133b.  Establishment  of  Universal  Support  Mechanisms  Pursuant  to 
 Section  254  of  the  Telecommunications  Act  of  1996,  Docket  No.  P-  100,  Sub  133b,  Order  on  Reconsideration,  at  13-  14  (July  2,  1998). 


 146  BellSouth  Application  App.  A,  Vol.  4a,  Tab  G,  Affidavit  of  John  A.  Ruscilli  and  Cynthia  K.  Cox  (BellSouth 
 Ruscilli/  Cox  Aff.)  at  para.  175.  The  North  Carolina  Commission  adjusted  BellSouths  cost  studies,  setting  a  rate  of  $15.88  ($  15.60  associated  with  the  loop  and  $0.28  with  the  amortized  disconnect  costs).  Id.;  see  also  BellSouth 


 Caldwell  Aff.  at  para.  188. 
 147  North  Carolina  Commission  UNE  Rate  Order  at  75-  83  (stating  that  the  Nonrecurring  Cost  Model  does  not  use 
 North  Carolina  specific  data,  makes  assumptions  that  are  not  reasonable  or  achievable,  and  produces  inappropriate  labor  costs). 


 148  UNE  Remand  Order,  15  FCC  Rcd  at  3696. 
 149  Line  Sharing  Order,  14  FCC  Rcd  at  20912. 
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 adopting  permanent  deaveraged  UNE  rates,  effective  December  11,  2001.  150  A  Phase  II  UNE  proceeding  was  held  on  October  23,  2000,  to  consider  several  policy  issues  concerning  UNE 
 combinations  and  the  appropriate  nonrecurring  charges  for  xDSL  loops.  151  The  North  Carolina  Commission  adopted  final  UNE  rates,  excluding  geographic  deaveraging,  from  its  Phase  I  and  II 
 UNE  proceedings  on  May  1,  2002.  152 
 51.  On  May  7  and  9,  2002,  BellSouth  voluntarily  amended  its  SGAT  to  reduce  many  of  its  nonrecurring  UNE  rates  in  North  Carolina  and  to  eliminate  the  recurring  and  nonrecurring 


 rates  associated  with  switching  vertical  features.  153  On  May  23,  2002,  the  North  Carolina  Commission  concluded  that  good  cause  exists  to  advise  the  Federal  Communications 
 Commission  that  BellSouth  satisfied  its  section  271  obligations,  including  the  competitive  checklist  provisions.  154  The  North  Carolina  Commission  has  opened  a  new  generic  cost 


 150  Proceeding  to  Determine  Permanent  Pricing  for  Unbundled  Network  Elements,  Order  Adopting  Final 
 Permanent  Deaveraged  UNE  Rates,  Docket  No.  P-  100,  Sub  133d  (April  5,  2002)  (North  Carolina  Deaveraged  UNE  Rates  Order).  Competitive  LECs  sponsored  10  witnesses  in  the  September  25,  2000,  hearing.  The  Public 


 Staff  and  Attorney  General  also  participated.  On  March  15,  2001,  the  North  Carolina  Commission  issued  a  recommended  order  and,  due  to  several  requests  for  reconsideration,  established  a  comment  cycle  on  its  order.  On 
 December  11,  2001,  the  state  commission  issued  its  order  finalizing  deaveraged  UNE  rates. 
 151  On  June  7,  2001,  the  North  Carolina  Commission  issued  a  185-  page  Recommended  Order  Concerning  All 
 Phase  I  and  Phase  II  UNE  Issues  Excluding  Geographic  Deaveraging.  After  considering  all  exceptions  filed  by  the  parties,  the  state  commission  issued  its  Order  Addressing  Exceptions  to  Recommended  Order  on  all  Phase  I  and  II 


 Issues  Except  Geographic  Deaveraging  on  December  31,  2001.  BellSouth  Ruscilli/  Cox  Aff.  at  Exh.  JAR/  CKC-  20. 
 152  General  Proceeding  to  Determine  Permanent  Pricing  for  Unbundled  Network  Elements,  Order  Adopting 
 Final  Permanent  Phase  I  and  Phase  II  UNE  Rates  for  BellSouth  and  Verizon,  Docket  No.  P-  100,  Sub  133d  (May  1,  2002). 


 153  Letter  from  Edward  L.  Rankin,  III,  Counsel  to  BellSouth,  to  Geneva  S.  Thigpen,  Chief  Clerk,  North  Carolina 
 Utilities  Commission,  Docket  Nos.  P-  55,  Sub  1022,  P-  100,  Sub  133d  (May  7,  2002)  (BellSouth  May  7  Letter).  If  an  ordered  nonrecurring  UNE  rate  in  Louisiana  was  lower  than  the  North  Carolina  rate,  BellSouth  substituted  the 


 Louisiana  rate  in  its  North  Carolina  SGAT  Price  List  [not  including  collocation].  Id.  at  2.  Although  BellSouth  agrees  with  its  state  commission  that  North  Carolina  rates  reflect  UNE  provisioning  costs,  it  recognized  that  some 
 of  the  nonrecurring  rates  in  North  Carolina  were  higher  than  .  .  .  in  other  BellSouth  states  [and]  to  avoid  any  conceivable  issue,  it  .  .  .  voluntarily  reduce[  d]  some  of  its  nonrecurring  rates  until  [the  new  generic  cost  proceeding] 
 is  completed.  BellSouth  Ruscilli/  Cox  Aff.  at  para.  175. 
 154  Application  of  BellSouth  Telecommunications,  Inc.  to  Provide  In-  Region  InterLATA  Service  Pursuant  to 
 Section  271  of  the  Telecommunications  Act  of  1966,  Notice  of  Decision,  Docket  No.  P-  55,  Sub  1022  (May  23,  2002)  (North  Carolina  Commission  271  Order)  at  1.  In  its  decision,  the  state  commission  also  approved  as  interim, 


 subject  to  true-  up,  BellSouths  rates  for  remote  terminal  and  virtual  collocation  elements,  cable  records,  assembly  point  arrangements  and  unbundled  copper  loops-  non-  design  (UCL-  ND),  including  engineering  information  and 
 testing.  BellSouth  has  requested  that  the  North  Carolina  Commission  establish  permanent  rates  for  these  elements  in  its  current  generic  UNE  proceeding.  BellSouth  Ruscilli/  Cox  Aff.  at  paras.  176-  77. 
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 proceeding,  scheduled  to  begin  in  November  2002,  to  review  updated  cost  information  and  revise  cost-  based  rates,  not  including  collocation.  155 
 52.  South  Carolina.  By  orders  dated  June  1,  1998  and  September  18,  1998,  the  South  Carolina  Commission  first  set  permanent  rates  for  UNEs  and  interconnection  services  in  Docket 
 97-  372-  C.  156  The  South  Carolina  Commission  also  established  interim  deaveraged  rates  for  certain  UNEs  by  order  dated  April  24,  2000.  157  At  BellSouths  request,  the  South  Carolina 
 Commission  opened  Docket  2001-  65-  C  to  update  the  1998  UNE  rates,  set  additional  UNE  rates,  and  to  establish  permanent  deaveraged  rates  for  certain  UNEs  and  UNE  combinations.  158  During 
 the  evidentiary  hearing  on  June  18-  21,  2001  for  Docket  2001-  65-  C,  the  South  Carolina  Commission  heard  testimony  from  11  witnesses  representing  BellSouth,  NewSouth,  NuVox, 
 Broadslate,  ITC^  DeltaCom,  KMC,  and  the  South  Carolina  Consumer  Advocate.  159  These  parties  also  filed  written  testimony  from  ten  additional  witnesses.  160  After  considering  all  of  the  pricing 
 evidence,  the  South  Carolina  Commission  issued  its  UNE  Rate  Order  on  November  30,  2001.  161 
 53.  In  concluding  that  BellSouths  UNE  rates  complied  with  the  Commissions  TELRIC  pricing  rules,  the  South  Carolina  Commission  specifically  approved  the  BSTLM  and 


 the  five  different  network  scenarios  that  BellSouth  used  to  develop  recurring  and  non-  recurring  charges.  162  The  South  Carolina  Commission  also  determined  that  certain  BellSouth  UNE  rates 
 fell  at  the  upper  end  of  a  range  of  reasonable  TELRIC  rates  and  therefore  adopted  the  following  competitive  discounts:  20  percent  discount  off  proposed  recurring  rates  for  all  UNE 
 loops  and  combinations,  except  for  the  four-  wire  DS1  digital  loops,  which  was  discounted  by  30  percent,  and  a  50  percent  discount  off  all  proposed  non-  recurring  charges.  163  According  to  the 


 155  BellSouth  has  proposed  collocation  rates  in  Docket  Nos.  P-  100,  Sub  133j  and  P-  55,  Sub  1022.  It  plans  to 
 update  its  SGAT  Price  List  when  the  North  Carolina  Commission  issues  its  final  orders  in  these  dockets.  BellSouth  May  7  Letter  at  2  n.  4. 


 156  Generic  Proceeding  to  Establish  Prices  for  BellSouth  Telecommunications,  Inc.  s  Interconnection  Services, 
 Unbundled  Network  Elements  and  other  Related  Services,  Public  Service  Commission  of  South  Carolina,  Order  on  UNE  Rates,  Docket  No.  2001-  65-  C  (Nov.  30,  2001)  (UNE  Rate  Order  or  South  Carolina  Commission  UNE  Rate 


 Order)  at  1. 
 157  Id. 


 158  Id.  at  1-  2. 
 159  Id.  at  2-  3. 
 160  Id. 
 161  Id.  at  3. 
 162  Id.  at  6. 
 163  Id. 
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 South  Carolina  Commission,  these  discounts  produce[  d]  rates  that  are  within,  and  possibly  below,  a  reasonable  TELRIC  range.  164 
 54.  The  South  Carolina  Commission  also  set  permanent  deaveraged  UNE  rates  in  the  UNE  Rate  Order.  165  After  noting  that  states  have  considerable  latitude  in  determining  how  to 
 deaverage  rates,  the  South  Carolina  Commission  adopted  BellSouths  deaveraging  proposal,  which  deaveraged  loop-  related  UNEs  into  three  geographic  areas  using  existing  BellSouth  rate 
 groups  based  on  BellSouths  SGAT.  166  The  South  Carolina  Commission  stated  that,  [  u]  nder  BellSouths  approach,  customers  who  are  located  in  the  same  geographic  area  and  who  have 
 similar  local  calling  areas  would  be  in  the  same  deaveraged  zone  for  UNE  pricing.  167  Although  the  South  Carolina  Commission  found  that  deaveraging  of  UNEs  will  result  in  rates  that  vary  in 
 the  opposite  directions  from  the  prices  for  BellSouths  retail  services,  168  it  nevertheless  stated  that  BellSouths  deaveraging  methodology  was  consistent  with  the  Commissions  rules.  169 


 55.  In  the  UNE  Rate  Order,  the  South  Carolina  Commission  also  made  determinations  concerning  rates  for  collocation,  loop  conditioning,  line  sharing  and  splitting,  and 
 UNE  combinations.  In  adopting  all  of  these  rates,  the  South  Carolina  Commission  noted  that  it  would  consider  any  new  evidence  in  a  subsequent  docket.  170 


 b.  Recurring  Charges 
 (i)  Loop  Rates 
 56.  Loop  Modeling.  BellSouth  separately  determines  prices  for  loops  and  ports  on  a  stand-  alone  basis  and  in  combination.  The  Commission  approved  this  multiple  scenario 


 pricing  methodology  when  considering  BellSouths  application  to  provide  in-  region,  interLATA  service  originating  in  Louisiana  pursuant  to  section  271.  171  Like  the  Louisiana  Commission,  the 
 Alabama,  Kentucky,  Mississippi,  and  South  Carolina  Commissions  also  approved  BellSouths  proposal  to  use  five  different  network  scenarios  for  costing  UNEs  and  UNE  combinations.  172 


 164  Id. 
 165  Id.  at  6-  8. 
 166  Id. 
 167  Id. 
 168  Id. 
 169  Id.  at  7-  8. 
 170  Id.  at  17. 
 171  See  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9041,  para.  38. 
 172  See  Alabama  Commission  UNE  Rate  Order  at  24-  25;  Kentucky  Commission  UNE  Rate  Order  at  13-  15; 
 Mississippi  Commission  UNE  Rate  Order  at  13-  14;  South  Carolina  Commission  UNE  Rate  Order  at  6. 
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 Those  five  scenarios  are:  (1)  the  BST  2000  scenario    used  to  develop  forward-  looking  investment  for  all  network  elements  except  copper  loops  and  UNE  combinations;  (2)  the  Combo 
 scenario    used  to  develop  the  material  investment  associated  with  loops  used  in  combinations  (two-  wire  analog  voice  grade  loop);  (3)  the  Copper  only  scenario    used  to  develop  the  material 
 investment  of  network  elements  served  only  by  unloaded  copper  feeder  and  distribution  facilities;  (4)  the  BST2000  ISDN  scenario    all  loops  in  BST2000  scenario  are  converted  to 
 ISDN  loops  and  ISDN  customers  are  added;  and  (5)  the  Combo-  ISDN  scenario    used  to  develop  the  costs  of  an  ISDN  loop  when  offered  in  combination.  173 


 57.  As  a  result  of  this  costing  methodology,  BellSouth  determines  prices  for  stand-alone  loops  based  on  the  assumed  use  of  Universal  Digital  Loop  Carrier  (UDLC)  but  determines 
 prices  for  UNE  loop/  port  combinations  based  on  the  assumed  use  of  Integrated  Digital  Loop  Carrier  (IDLC).  174  BellSouth  assumes  that  UDLC  is  the  appropriate  technology  for  provisioning 
 unbundled  loops  because  IDLC  technology  integrates  the  loop  directly  into  the  switch.  175  BellSouth  further  assumes  that  it  is  less  costly  to  provide  a  loop/  port  combination  using  IDLC 
 than  using  UDLC.  Therefore,  BellSouths  methodology  prices  a  loop  and  port,  when  purchased  as  individual  elements,  higher  than  a  UNE  loop/  port  combination  (UNE-  platform). 


 58.  WorldCom  argues  that  BellSouths  multiple  scenario  approach  overstates  costs  by  understating  economies  of  scope.  176  According  to  WorldCom,  there  are  inefficiencies  inherent  in 
 this  approach  because  it  allows  BellSouth  to  design  networks  for  customer  demand  that  would  otherwise  be  served  more  efficiently  using  an  alternate  network  design.  177  WorldCom  illustrates 
 its  argument  by  explaining  that,  in  developing  the  unbundled  copper  loop  rates,  BellSouth  utilizes  a  model  that  assumes  an  all-  copper  network  to  reach  all  customer  locations,  even  if  a 
 particular  customer  located  far  from  a  wire  center  would  be  more  efficiently  served  using  an  alternative  model,  such  as  a  remote  terminal  and  fiber  optics  facilities.  178  WorldCom  asserts  that, 


 173  BellSouth  Caldwell  Aff.  at  paras.  41-  53. 
 174  See  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9041,  para.  39.  As  explained  in  more  detail  in  the 
 BellSouth  Georgia/  Louisiana  Order,  UDLC  is  an  older  version  of  DLC  technology  that  is  not  directly  integrated  into  the  switch.  UDLC  requires  digital  signals  to  be  routed  through  a  central  office  terminal  and  converted  back  to 


 analog  signals  before  reaching  the  central  office  switch,  making  it  capable  of  interfacing  with  any  analog  or  digital  central  office  switch.  IDLC  technology  eliminates  the  need  for  digital-  to-  analog  signal  conversion  by  establishing  a 
 direct  digital  interface  to  a  digital  remote  terminal,  allowing  delivery  of  the  combined  traffic  directly  into  the  switch  without  first  separating  the  traffic  from  the  individual  lines.  As  a  result,  IDLC  can  operate  only  with  a  digital 
 switch.  See  id.  at  9042-  43,  para.  43. 
 175  See  BellSouth  Reply  App.,  Tab  B,  Reply  Affidavit  of  D.  Daonne  Caldwell  (BellSouth  Caldwell  Reply  Aff.)  at 
 para.  11. 
 176  WorldCom  Comments  at  15;  WorldCom  Comments,  Tab  B,  Declaration  of  Chris  Frentrup  (WorldCom 
 Frentrup  Decl.)  at  para.  13.  See  also  WorldCom  Reply  at  9-  10;  WorldCom  Reply,  Tab.  B,  Reply  Declaration  of  Chris  Frentrup  (WorldCom  Frentrup  Reply  Decl.)  at  paras.  9-  12. 


 177  WorldCom  Frentrup  Decl.  at  paras.  13-  14. 
 178  Id.  at  para.  14. 
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 because  the  model  assumes  the  existence  of  unrealistically  long  copper  loops,  and  averages  the  higher  cost  of  such  loops  with  the  shorter  loops  that  would  exist  in  an  efficient  network,  the 
 model  artificially  inflates  the  cost  of  copper  loops.  179  WorldCom  also  argues  that  this  approach  further  overstates  cost  by  assuming  only  UDLC  will  be  used  for  stand-  alone  loops  and  by 
 assuming  that  some  of  the  IDLC  used  to  provide  UNE-  platform  will  not  meet  the  current  industry  GR-  303  protocol.  180  WorldCom  contends  that  this  approach  violates  sections  51.505(  b), 
 51.511(  b),  and  51.503(  b)  of  the  Commissions  rules  181  by  failing  to  take  into  account  only  the  lowest  cost  network  configuration,  which,  in  turn,  must  take  into  account  BellSouths 
 provision  of  other  elements  and  which  must  also  be  based  on  current  levels  of  demand.  182  Finally,  WorldCom  argues  that  loops  should  have  been  priced  using  only  the  Combo  scenario 
 because  the  majority  of  demand  in  the  BellSouth  region  is  for  plain  old  telephone  service  (POTS),  and  therefore  prices  should  be  based  largely  on  provision  of  POTS.  183 


 59.  BellSouth  responds  that  the  multiple  scenario  approach  is  consistent  with  TELRIC  and  captures  economies  of  scale  and  scope.  BellSouth  represents  that  it  uses  the  same 
 overall  line  count  for  each  scenario  and  thus  considers  the  total  quantity  of  facilities  in  each  scenario.  184  BellSouth  further  contends  that  this  approach  most  accurately  reflects  actual  costs 
 because  it  accounts  for  the  differences  in  the  manner  in  which  BellSouth  provisions  different  loops  (e.  g.,  stand-  alone  loops,  UNE-  platform  loops)  and  reflects  the  cost  differences  associated 
 with  each.  185  BellSouth  also  notes  that,  because  it  cannot  know  today  how  a  loop  may  be  used  by  a  competitive  LEC  in  the  future,  its  use  of  multiple  scenarios  is  necessary.  186  BellSouth  explains 
 that  the  alleged  inflation  of  copper  loop  costs  described  by  WorldCom  is  impossible  because  specific  length  limits  are  imposed  when  developing  costs.  187 


 179  Id. 
 180  Id.  at  para.  15  n.  2. 
 181  47  C.  F.  R.    51.505(  b),  51.511,  51.503(  c). 
 182  See  WorldCom  Comments  at  15-  16;  see  also  WorldCom  Reply  at  10  n.  2. 
 183  WorldCom  Comments  at  16. 
 184  BellSouth  Caldwell  Reply  Aff.  at  paras.  13-  14. 
 185  BellSouth  contends  that  using  only  one  scenario  would,  in  fact,  lead  to  under-  recovery  of  costs  because  not  all 
 possible  uses  for  a  loop  specific  to  a  customer  can  be  considered  with  a  single  scenario.  BellSouth  Caldwell  Reply  Aff.  at  para.  11. 


 186  Id.  at  para.  14. 
 187  Letter  from  Glenn  T.  Reynolds,  Vice  President    Federal  Regulatory,  BellSouth,  to  Marlene  H.  Dortch, 
 Secretary,  Federal  Communication  Commission,  WC  Docket  No.  02-  150  at  4  (filed  Aug.  9,  2002)  (BellSouth  August  9  Ex  Parte  Letter).  BellSouth  explains  that  the  UCL-  Short  Loop  does  not  exceed  18,000  feet,  the  UCL-  ND 


 does  not  exceed  24,000  feet,  and  the  HDSL-  compatible  loop  does  not  exceed  12,000  feet.  Id.  Accordingly,  BellSouth  states  that  only  loops  that  meet  these  length  limitations  are  considered  when  the  costs  are  calculated,  and 
 therefore  it  is  impossible  for  the  average  cost  of  these  shorter  loops  to  be  inflated  by  costs  of  longer  loops.  Id. 
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 60.  As  an  initial  matter,  we  note  that  various  commenters,  including  WorldCom,  also  challenged  BellSouths  multiple  scenario  approach  in  response  to  BellSouths  application  to 
 provide  in-  region,  interLATA  service  originating  in  Louisiana  pursuant  to  section  271,  188  as  well  as  in  the  Alabama,  Kentucky,  and  Mississippi  UNE  rate  proceedings.  189  After  evaluating  such 
 arguments,  the  Commission  previously  concluded  that  BellSouths  multiple  scenario  methodology  is  consistent  with  TELRIC  and  does  reflect  economies  of  scale  and  scope  because 
 it  considers  the  entire  quantity  of  lines  in  each  scenario.  190  The  Alabama,  Kentucky,  Mississippi,  and  South  Carolina  Commissions  similarly  accepted  BellSouths  use  of  multiple  loop  modeling 
 scenarios  during  their  respective  state  UNE  rate  proceedings.  191  Based  on  the  record  before  us,  we  find  that  the  Alabama,  Kentucky,  Mississippi,  and  South  Carolina  Commissions  reasonably 
 accepted  BellSouths  use  of  multiple  scenarios  to  price  loops.  For  example,  the  Mississippi  Commission  addressed  this  issue  in  detail  in  its  UNE  rate  order.  It  rejected  WorldComs 
 contention  that  the  use  of  multiple  scenarios  violates  TELRIC,  emphasizing  that  BellSouth  used  the  same  overall  line  count  in  each  scenario,  therefore  ensuring  that  the  total  quantity  of  facilities 
 was  considered  in  each  scenario.  192  The  Mississippi  Commission  also  rejected  the  argument  that  the  multiple  scenario  approach  overstates  costs,  concluding  that  this  methodology  appropriately 
 accounts  for  the  differences  in  the  manner  in  which  BellSouth  provisions  different  loops,  and  is,  in  fact,  necessary  to  accurately  calculate  BellSouths  costs.  193 


 61.  We  defer  to  the  analyses  of  the  state  commissions,  and  we  therefore  reject  WorldComs  criticism  of  the  multiple  scenario  approach.  As  we  noted  in  the  BellSouth  Georgia/ 
 Louisiana  Order,  because  BellSouth  considers  the  entire  quantity  of  lines  in  each  scenario,  its  methodology  reflects  economy  of  scope.  194  Moreover,  WorldComs  criticism  does  not  respond 
 to  the  concern  noted  by  the  state  commissions  that  use  of  a  single  scenario  might  in  fact  result  in  under-  recovery  of  costs.  A  proper  loop  costing  methodology  must  reflect  that  some  customers 
 purchase  stand-  alone  loops,  and  BellSouth  is  entitled  to  recover  the  forward-  looking  costs 
 188  See  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9041-  42,  paras.  40-  41. 
 189  See  Alabama  Commission  UNE  Rate  Order  at  20-  24;  Kentucky  Commission  UNE  Rate  Order  at  13; 
 Mississippi  Commission  UNE  Rate  Order  at  13.  Although  the  South  Carolina  Commission  UNE  Rate  Order  did  not  reference  comments  on  this  issue,  it  did  specifically  evaluate  BellSouths  use  of  multiple  scenarios.  South  Carolina 


 Commission  UNE  Rate  Order  at  6. 
 190  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9041-  42,  para.  41. 


 191  See  Alabama  Commission  UNE  Rate  Order  at  24-  25;  Kentucky  Commission  UNE  Rate  Order  at  13-  15; 
 Mississippi  Commission  UNE  Rate  Order  at  13-  14;  South  Carolina  Commission  UNE  Rate  Order  at  6. 
 192  Mississippi  Commission  UNE  Rate  Order  at  13-  14. 


 193  Id.  at  14;  see  also  Mississippi  Commission  Reply  at  9;  Alabama  Commission  UNE  Rate  Order  at  25;  Kentucky 
 Commission  UNE  Rate  Order  at  11-  14;  South  Carolina  Commission  UNE  Rate  Order  at  6.  The  findings  of  these  state  commissions  are  consistent  with  the  findings  of  the  Louisiana  Commission,  which  found  that  using  only  one 


 scenario  would  lead  to  under-  recovery  of  BellSouths  costs.  See  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9041-  42,  para.  41. 


 194  See  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9041-  42,  para.  41. 
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 associated  with  provisioning  those  loops  that  may  differ  from  the  costs  associated  with  provisioning  a  loop/  switch  combination  (UNE-  platform).  195  WorldCom  does  not  explain  how 
 exclusive  use  of  the  Combo  scenario  would  provide  for  recovery  of  these  costs.  We  further  find  that  BellSouths  explanation  regarding  the  manner  in  which  copper  loops  are  priced  addresses 
 WorldComs  argument  that  the  prices  of  such  loops  are  inevitably  inflated. 
 62.  In  addition,  we  reject  WorldComs  arguments  regarding  the  impact  of  using  UDLC  technology  for  stand-  alone  loops.  WorldCom  has  not  provided  cost  analysis  to  show  that 


 IDLC  is  necessarily  less  expensive  than  UDLC  when  used  for  stand-  alone  loops  and  ports,  and  we  remain  unpersuaded,  based  on  the  evidence  before  us,  that  a  current  application  of  TELRIC 
 would  require  100  percent  use  of  such  technology  for  that  purpose.  196  Indeed,  as  we  explained  in  the  BellSouth  Georgia/  Louisiana  Order,  prior  Commission  orders  have  recognized  that  at  least 
 certain  IDLC  alternatives  would  likely  be  more  expensive.  197  WorldComs  related  argument,  that  BellSouths  prices  for  stand-  alone  loops  would  decrease  if  BellSouth  used  only  GR-  303 
 technology,  also  has  been  previously  rejected  by  this  Commission.  198  As  we  have  explained,  BellSouth  may  use  UDLC  to  set  prices  for  stand-  alone  loops,  and  UDLC  is  not  compatible  with 
 GR-  303  technology.  199 
 63.  Accordingly,  we  find  that  WorldCom  has  not  presented  evidence  sufficient  to  show  that  these  state  commissions  erred  in  their  decisions  or  to  overcome  the  record  evidence 


 BellSouth  has  presented  as  to  why  the  use  of  multiple  scenarios  is  appropriate. 
 64.  Loading  Factors.  WorldCom  contends  that  BellSouths  excessive  loading  factors  greatly  inflate  switching  and  loop  costs  in  each  of  the  five  states.  200  The  loading  factor  (also 


 called  the  EF&  I  factor,  for  Engineered,  Furnished  and  Installed)  represents  the  cost  of  labor  and  additional  materials  required  to  make  equipment  operational.  It  converts  material  costs  to 
 installed  investment  costs  and  thus  provides  for  recovery  of  EF&  I  costs.  201  Based  on  the  record,  we  conclude  that  each  of  the  five  state  commissions  made  a  reasonable  determination  that 


 195  See  Alabama  Commission  UNE  Rate  Order  at  25. 
 196  See  generally  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9046,  para.  50. 
 197  See  id. 
 198  See  id.  at  9046,  para.  50  n.  180.  BellSouth  states  that  there  are  additional  costs  and  limiting  factors  to  such  an 
 arrangement.  BellSouth  Caldwell  Reply  at  para.  17. 
 199  See  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9046,  para.  50  n.  180. 


 200  WorldCom  Comments  at  16. 
 201  Each  state  has  a  total  of  30  loading  factors.  Twenty-  four  of  them  relate  to  the  outside  plant  (OSP),  and  six  of 
 them  relate  to  the  central  office  equipment  (COE).  Half  of  both  of  the  OSP  and  COE  factors  are  material  factors  (applied  only  to  the  material),  and  half  are  telco  factors  (applied  to  material  and  vendor  engineering  and  vendor 


 installation).  See  Letter  from  Glenn  T.  Reynolds,  Vice  President    Federal  Regulatory,  BellSouth,  to  Marlene  H.  Dortch,  Secretary,  Federal  Communications  Commission,  WC  Docket  No.  02-  150  (filed  Aug.  16,  2002)  (BellSouth 
 August  16  Ex  Parte  Letter);  BellSouth  Caldwell  Reply  Decl.  at  para.  34. 
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 BellSouths  loading  factors  accord  with  TELRIC  principles.  As  WorldCom  itself  states,  competitive  carriers  adamantly  challenged  BellSouths  use  of  loading  factors  in  the  five  states 
 at  issue  here,  202  and,  in  each  case,  the  state  commissions  upheld  the  use  of  BellSouths  loading  factors.  203  We  also  note  that  WorldCom  does  not  dispute  BellSouths  assertion  that  the  loading 
 factor  methodology  challenged  here  is  the  same  methodology  that  we  reviewed  and  accepted  in  the  Georgia/  Louisiana  proceeding.  204  Furthermore,  we  note  that  no  party  in  this  proceeding  has 
 challenged  any  particular  loading  factor  or  asserted  that  the  derivation  of  any  particular  loading  factor  is  not  TELRIC-  compliant.  205 


 65.  WorldCom  argues  that  BellSouths  loading  factors  are  derived  from  an  embedded,  rather  than  forward-  looking,  network  and  that  this  substantially  overstates  the  EF&  I 
 costs  in  a  forward-  looking  network.  206  WorldCom  states  that  the  fact  that  the  loading  factors  vary  substantially  from  state  to  state  is  evidence  that  the  factors  are  improperly  determined.  207 
 As  an  example,  WorldCom  notes  that  the  material  in-  plant  loading  factor  for  digital  switching  equipment  in  Kentucky  was  28  [percent]  higher  than  the  factor  used  for  this  equipment  in 
 Mississippi,  even  though  the  cost  of  engineering  and  installing  digital  switching  equipment  should  not  vary  significantly  by  state.  208  WorldCom  also  contends  that,  based  on  runs  of  the 
 BellSouth  model  for  Florida  and  Georgia  with  certain  adjustments  WorldCom  made  to  the  loading  factors,  BellSouths  loading  factors  appear  to  have  overstated  costs  by  at  least  15 
 percent.  209  It  submits  exhibits  from  AT&  T  and  WorldCom  testimony  filed  in  pending  Florida 
 202  WorldCom  Comments  at  18. 
 203  Id.  at  16;  see  also  Alabama  Commission  UNE  Rate  Order  at  25-  34,  40-  41;  Kentucky  Commission  UNE  Rate 
 Order  at  15;  Mississippi  Commission  UNE  Rate  Order  at  17-  21;  North  Carolina  Commission  UNE  Rate  Order  at  50-  52.  Although  there  is  no  specific  mention  of  loading  factors  in  the  South  Carolina  Commission  UNE  Rate 


 Order,  it  is  clear  from  the  record  that  loading  factors  were  discussed  thoroughly  during  the  course  of  the  proceeding.  See  BellSouth  Caldwell  Reply  Aff.  at  Exh.  DDC-  15  (Testimony  of  Don  J.  Wood,  on  behalf  of 
 NewSouth  Communications,  NuVox  Communications,  Broadslate  Networks,  ITC^  DeltaCom  Communications,  and  KMC  Telecom,  in  the  South  Carolina  Commission  UNE  Rate  Proceeding  at  1253-  68  (June  4,  2001))  (Competitive 
 Coalition  Wood  South  Carolina  Testimony). 
 204  BellSouth  Application  at  43;  see  also  BellSouth  Caldwell  Aff.  at  para.  14. 


 205  WorldCom  does  assert  that  the  fact  that  the  material  inplant  loading  factor  for  digital  switching  in  Kentucky  is 
 28%  higher  that  the  material  inplant  loading  factor  used  for  digital  switching  in  Mississippi  is  evidence  that  the  loading  factors  are  improperly  determined.  We  disagree.  See  discussion  below. 


 206  WorldCom  Comments  at  17;  WorldCom  Frentrup  Decl.  at  paras.  17-  18.  WorldCom  states  that,  [  w]  hile 
 material  costs  would  decrease  in  a  forward-  looking  network,  the  costs  of  installation  and  maintenance  would  decrease  even  more,  reducing  the  ratio  of  material  to  installed  costs.  In  a  forward-  looking  network,  for  example, 


 most  loops  will  be  installed  electronically  via  a  circuit  board  without  any  need  to  rearrange  circuits  in  the  field.  WorldCom  Comments  at  17. 


 207  WorldCom  Frentrup  Decl.  at  para.  17. 
 208  Id. 
 209  WorldCom  Frentrup  Reply  Decl.  at  para.  13. 
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 and  Georgia  UNE  cases  that  it  says  itemizes  the  effect  of  correcting  [loading]  .  .  .  and  other  factors.  210 
 66.  BellSouth  counters  that  it  developed  its  in-  plant  loading  factors  based  on  the  latest  year-  end  data  available  at  the  time  the  studies  were  conducted  and  that  these  forward-looking 
 factors  were  applied  to  a  forward-  looking  material  price.  211  In  addition,  BellSouth  states  that  in-  plant  factors  should  and  do  vary  by  state  because  [  e]  ach  state  negotiates  vendor  contracts 
 independently,  the  work  performed  differs  due  to  such  factors  as  terrain  and  climate  conditions,  and  state  taxes  are  unique.  212  Finally,  BellSouth  argues  that  using  WorldComs  proposed  inputs 
 to  calculate  fully  loaded  material  prices  are  inappropriate  because,  among  other  reasons,  (  1)  they  do  not  reflect  BellSouths  material  prices;  [and]  (2)  the  installation  costs,  engineering  costs, 
 exempt  material  expenses,  and  taxes  are  not  reflective  of  BellSouth[  s]  incurred  costs.  213 
 67.  The  North  Carolina  Commission  addressed  the  argument  that  BellSouths  loading  factors  are  derived  from  an  embedded,  rather  than  forward-  looking,  network  in  its  UNE  pricing 


 order  and  found  that  it  was  appropriate  to  require  the  four  ILECs  to  input  the  loading  factors  [proposed  by  BellSouth  and]  adopted  and  approved  by  the  [North  Carolina]  Commission  in  the 
 FLEC  Docket.  214  It  specifically  noted  that  it  had  found  the  loading  factors  to  be  forward-looking  in  that  docket.  215  In  addition,  WorldCom  made  the  same  argument  before  the  Alabama  216 
 and  Mississippi  Commissions,  217  and  neither  Commission  found  the  argument  persuasive.  Competitive  carriers  also  asserted  that  BellSouths  loading  factors  in  Georgia  and  Louisiana 


 210  Id.  According  to  the  exhibit  that  WorldCom  submitted  to  the  Florida  Commission,  loop  costs  would  be 
 reduced  by  24.8%  if  the  BellSouth  model  were  changed  to  Correct  DLC  In-  plant  Factors;  Eliminate  25%  Closing  Factor  and  Correct  Contract  Labor  Data;  Update  Inflation  Factors;  Correct  Treatment  for  Exempt 


 Material;  and  Correct  Engineering  Factors.  Id.  at  para.  14.  Similarly,  according  to  the  exhibit  that  it  submitted  to  the  Georgia  Commission,  Zone  One  2-  Wire  Analog  Voice  Loop  costs  would  be  reduced  15%  if  changes  were 
 made  to  account  for  Inflation  Double  Count,  Closing  Factor,  Exempt  Material  Loading,  Indirect  Labor  Loading,  Engineering  Factors,  and  Bottoms-  Up  DLC  Inputs.  Id.  at  para.  14. 


 211  BellSouth  Caldwell  Aff.  at  para.  11. 
 212  Id.  at  para.  12. 
 213  BellSouth  Caldwell  Reply  Decl.  at  para.  25. 
 214  North  Carolina  Commission  UNE  Rate  Order  at  52.  The  FLEC  Docket  refers  to  a  proceeding  undertaken  by 
 the  North  Carolina  Commission  to  determine  the  forward-  looking  economic  costs  of  providing  universal  service  in  North  Carolina.  Id.  at  5. 


 215  Id.  at  52. 
 216  BellSouth  Application  App.  D,  Vol.  7a-  b,  Tab  16  Part  B,  (WorldCom,  Inc.  Direct  and  Rebuttal  Testimony  of 
 Greg  Darnell  Before  the  Alabama  Public  Service  Commission,  Docket  No.  27821,  at  2803-  06  (April  20,  2001)). 
 217  BellSouth  Application  Caldwell  Reply  Aff.  at  Exh.  DDC-  14,  (WorldCom,  Inc.  Direct  and  Rebuttal  Testimony 
 of  Greg  Darnell  Before  the  Mississippi  Public  Service  Commission,  Docket  No.  2000-  UA-  999,  at  14-  15  (April  16,  2001))  (WorldCom  Darnell  Mississippi  Testimony). 
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 reflected  embedded  costs,  218  but  we  concluded  that  the  loading  factors  in  Georgia  and  Louisiana  were  determined  in  accordance  with  TELRIC  principles.  219  WorldCom  has  not  presented  any 
 new  evidence  or  argument  that  persuades  us  that  the  state  commissions  committed  clear  error  in  their  choice  of  loading  factors. 


 68.  We  also  reject  WorldComs  assertion  that  the  fact  that  loading  factors  vary  from  state  to  state  is  evidence  that  the  factors  are  improperly  determined.  We  note  that  the  state 
 commissions  in  Alabama,  Kentucky,  Mississippi,  and  South  Carolina  did  not  accept  the  claims  of  competitive  carriers  that  argued  in  the  state  proceedings  that  it  was  appropriate  to  use  Florida 
 data  to  calculate  loading  factors  in  Alabama,  Kentucky,  Mississippi,  and  South  Carolina  because  these  costs  should  not  vary  by  state.  220  BellSouth  offers  credible  evidence  that  cost  variations 
 can  be  attributed  to  differences  in  vendor  contracts,  terrain  and  climate  conditions,  and  state  taxes,  and  WorldCom  has  not  rebutted  this  evidence.  Furthermore,  we  find  that  WorldCom  is 
 not  correct  when  it  states  that  the  material  in-  plant  loading  factor  for  digital  switching  equipment  in  Kentucky  is  28  percent  higher  than  the  factor  used  in  Mississippi.  BellSouth  has  submitted 
 documentation  showing  that  the  material  in-  plant  loading  factor  for  digital  switching  equipment  is  1.478  for  Kentucky  and  1.447  for  Mississippi,  approximately  a  two  percent  difference.  221  As 
 in  our  BellSouth  Georgia/  Louisiana  Order,  we  reject  WorldComs  unsupported  contention  that  BellSouths  loading  factors  vary  more  from  state  to  state  than  can  be  explained  by  labor  or  other 
 cost  differences.  222 


 218  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9046-  47,  para.  51,  9051,  para.  61. 
 219  See  id.  at  9047-  48,  paras.  52-  53,  9050-  51,  paras.  60-  61. 
 220  BellSouth  Application  App.  D,  Vol.  8,  Tab  17  (SECCA  Testimony  of  Cynthia  M.  Wilsky  and  Don  J.  Wood 
 Before  the  Alabama  Public  Service  Commission,  Docket  No.  27821  at  3206-  09  (April  20,  2001))  (SECCA  Wilsky/  Wood  Alabama  Testimony);  BellSouth  Caldwell  Reply  Aff.  at  Exh.  DDC-  13,  (SECCA  Rebuttal  Testimony 


 of  Cynthia  M.  Wilsky  and  Don  J.  Wood  Before  the  Kentucky  Public  Service  Commission,  Administrative  Case  No.  382  at  54-  55  (June  22,  2001))  (SECCA  Wilsky/  Wood  Kentucky  Testimony);  WorldCom  Darnell  Mississippi 
 Testimony  at  27-  28;  Competitive  Coalition  Wood  South  Carolina  Testimony  at  1261-  62.  Challengers  did  not  raise  this  issue  in  the  proceeding  before  the  North  Carolina  Commission. 


 221  BellSouth  Caldwell  Reply  Aff.  at  para.  34.  377C  is  the  field  reporting  code  for  digital  switching.  As  noted 
 previously,  WorldCom  does  not  challenge  any  particular  loading  factor  or  demonstrate  that  it  was  calculated  in  error.  It  merely  alleges  that  all  of  the  loading  factors  are  inflated  and  that  one  of  them  is  28%  higher  than  a 


 comparable  one  in  another  state.  Moreover,  we  note  that  even  if  WorldCom  were  to  establish  a  28%  difference  in  comparable  loading  factors  in  different  states,  a  mere  comparison,  without  anything  more,  is  not  sufficient  to 
 establish  clear  error.  See  Verizon  New  Jersey  Order,  17  FCC  Rcd  at  12306,  para  70;  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9035,  para.  26;  Application  by  Verizon  New  England,  Inc.,  Bell  Atlantic  Communications, 
 Inc.  (d/  b/  a  Verizon  Long  Distance),  NYNEX  Long  Distance  Company  (d/  b/  a  Verizon  Enterprise  Solutions),  Verizon  Global  Networks,  Inc.,  and  Verizon  Select  Services,  Inc.,  for  Authorization  to  Provide  In-  Region,  Inter-  LATA 
 Services  in  Vermont,  CC  Docket  No.  02-  7,  Memorandum  Opinion  and  Order,  17  FCC  Rcd  7625,  7644,  para.  35  (2002)  (Verizon  Vermont  Order). 


 222  See  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9047,  para.  52  n.  186  (rejecting,  due  to  lack  of 
 supporting  evidence,  WorldComs  assertions  that  loading  factors  varied  more  from  state  to  state  than  could  be  explained  by  labor  or  other  cost  differences). 
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 69.  Furthermore,  we  are  not  convinced  that  WorldComs  runs  of  the  BellSouth  model  for  Florida  and  Georgia,  which  purportedly  rely  on  WorldComs  adjustments  to  BellSouths 
 fully  loaded  material  prices,  demonstrate  that  BellSouths  loading  factors  for  other  BellSouth  states  overstate  costs  by  fifteen  percent.  First,  as  we  state  above,  WorldCom  has  not  rebutted 
 BellSouths  evidence  that  cost  variations  among  BellSouth  states  can  be  attributed  to  differences  in  vendor  contracts,  terrain  and  climate  conditions,  and  state  taxes.  Given  this  unrebutted 
 evidence,  WorldComs  model  runs  for  Georgia  and  Florida  do  not  provide  a  reliable  measure  of  any  overstatement  of  costs  caused  by  the  BellSouths  loading  factors  in  other  BellSouth  states. 
 Second,  WorldCom  merely  provides  itemizations  purporting  to  specify  what  items  were  inflated  that  it  has  submitted  to  the  Georgia  and  Florida  Commissions.  223  It  does  not  explain  or 
 document  the  methodology,  assumptions,  calculations,  or  data  relating  to  how  it  modified  BellSouths  loading  factors.  These  simple  itemizations  do  not  provide  us  with  an  adequate  basis 
 to  find  that  the  five  state  commissions  judgments  regarding  these  loading  factors  violate  basic  TELRIC  principles  or  constitute  clear  error. 


 70.  WorldCom  also  asserts  that  BellSouths  application  of  the  same  loading  factor  to  all  sizes  of  equipment  overstates  installed  investment  costs  in  more  densely  populated  areas  and 
 understates  these  costs  in  less  populated  areas.  224  WorldCom  states  that,  as  a  result,  BellSouth  does  not  properly  deaverage  costs.  225  BellSouth  counters  that  its  model  is  consistent  with  our 
 pricing  rules  because  its  loading  factors  fairly  reflect  the  average  costs  associated  with  installing  a  cable.  226  The  state  commissions  in  Alabama,  Kentucky,  Mississippi,  and  South  Carolina  all 
 considered  the  argument  that  applying  the  same  loading  factor  to  all  sizes  of  equipment  overstates  installed  investment  costs  in  more  densely  populated  areas  and  understates  these  costs 
 in  less  populated  areas,  and  in  each  case  the  states  did  not  adjust  their  loading  factors.  227  The  Mississippi  Commission  specifically  found  that  [  w]  hile  the  relationship  of  the  combined  costs 
 of  installation,  labor,  exempt  material,  sales  tax,  and  engineering  to  total  material  cost  may  not  be  perfectly  linear,  the  use  of  In-  Plant  factors  produces  representative  cost  results  when  viewed 
 on  a  total  cable  placement  basis.  228  WorldCom  also  argued  in  the  BellSouth  Georgia/  Louisiana  proceeding  that  applying  the  same  loading  factors  to  all  sizes  of  equipment  would  significantly 
 impact  total  costs.  229  As  we  did  in  that  proceeding,  230  we  conclude  that  WorldCom  has  not 
 223  WorldCom  Frentrup  Reply  Decl.  at  paras.  13-  14.  As  of  yet,  neither  the  Florida  nor  the  Georgia  Commission 
 has  issued  its  cost  order. 
 224  WorldCom  Comments  at  17;  WorldCom  Frentrup  Decl.  at  para.  21. 


 225  Id. 
 226  BellSouth  Caldwell  Aff.  at  para.  9. 
 227  SECCA  Wilsky/  Wood  Alabama  Testimony  at  3200-  03;  SECCA  Wilsky/  Wood  Kentucky  Testimony  at  48-  49; 
 WorldCom  Darnell  Mississippi  Testimony  at  26-  27;  Competitive  Coalition  Wood  South  Carolina  Testimony  at  1255.  Challengers  did  not  raise  this  issue  in  the  proceeding  before  the  North  Carolina  Commission. 


 228  Mississippi  Commission  UNE  Rate  Order  at  19. 
 229  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9049,  para.  56,  9052,  para.  63. 
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 presented  evidence  sufficient  to  demonstrate  that  the  state  commissions  committed  clear  error  with  respect  to  BellSouths  loading  factors. 
 71.  BellSouths  loading  factor  methodology  produces  the  average  loading  factor  for  all  cable  sizes  included  in  the  data  from  which  it  derives  the  factor.  Use  of  the  average  loading 
 factor  will  tend  to  overstate  the  cost  of  installing  a  cable  that  is  larger  than  the  average  cable  size  when  applied  to  the  unloaded  cable  cost  for  such  a  cable.  It  will  tend  to  understate  the  cost  of 
 installing  a  cable  that  is  smaller  than  average  when  applied  to  the  unloaded  cable  cost  for  such  a  cable.  It  overstates  installation  costs  for  large  cables  and  understates  these  costs  for  small  cables 
 because  cable  costs  are  not  a  constant  fraction  of  the  unloaded  cable  cost  to  which  the  loading  factor  is  applied.  In  concept,  however,  it  will  provide  an  accurate  estimate  of  the  cost  of 
 installing  the  average  size  cable  when  applied  to  the  unloaded  cable  cost  estimate  for  the  average  size  cable. 


 72.  We  find  for  several  reasons  that  BellSouths  use  of  an  average  loading  factor  for  all  cables  sizes  is  reasonable.  First,  while  not  perfect,  the  factor  does  reflect  that  cable 
 installation  costs  do  increase  with  the  size  of  the  cable  being  placed.  For  example,  splicing  costs  are  greater  for  a  large  cable  than  for  a  small  cable  because  more  labor  is  required  to  splice  the 
 larger  cable.  Applying  a  fixed  loading  factor  to  a  relatively  large  unloaded  cost  for  a  relatively  large  cable  produces,  as  it  should,  a  relatively  large  dollar  amount  for  engineering,  furnishing, 
 and  installing  such  a  cable.  In  fact,  the  loaded  cable  inputs  developed  by  the  Commission  for  use  in  its  synthesis  model    inputs  that  WorldCom  supports  for  use  in  developing  unbundled 
 loop  prices  231    rely  to  some  extent  on  fixed  percentage  loading  factors.  232 
 73.  Second,  BellSouth  provides  evidence  that  its  model  produces  a  loop  network  with  mostly  small  cables.  233  Use  of  an  average  loading  factor  for  every  cable  size  in  a  case  such  as 


 (Continued  from  previous  page)  230  Id.  at  9049,  para.  56,  9052,  para.  64. 
 231  WorldCom  Comments  at  18;  WorldCom  Frentrup  Decl.  at  para.  19. 
 232  Federal-  State  Joint  Board  on  Universal  Service  Forward-  Looking  Mechanism  for  High  Cost  Support  for  Non-Rural 
 LECs,  CC  Docket  No.  96-  45  and  CC  Docket  No.  97-  160,  Tenth  Report  and  Order,  14  FCC  Rcd  20156,  20231,  paras.  168-  69  (1999)  (Universal  Service  Tenth  Report  and  Order).  For  example,  the  Commission  adopted 


 loadings  for  splicing  costs  of  9.4%  and  4.7%  for  every  copper  and  fiber  cable  size,  respectively,  and  a  10%  loading  for  incumbent  LEC  engineering  costs  for  every  copper  and  fiber  cable  size.  Universal  Service  Tenth  Report  and 
 Order,  14  FCC  Rcd  at  20229,  paras.  164-  65. 
 233  While  copper  cable  typically  is  sold  in  sizes  ranging  from  approximately  25  pairs  to  4200  pairs,  BellSouth 
 supplied  data  showing  that  approximately  92%  of  the  copper  cable  in  its  model  loop  network  is  25  (63%),  50  (14%),  100  (10%),  or  200  (6%)  pair  cable.  BellSouth  Caldwell  Reply  Aff.  at  para.  21.  Based  on  these  BellSouth 


 data,  the  route-  feet  weighted  average  copper  cable  size  in  the  loop  network  produced  by  its  model  is  approximately  109  pair  cable.  While  fiber  cable  typically  is  sold  in  sizes  ranging  from  approximately  6  strands  to  216  strands, 
 BellSouth  supplied  data  showing  that  approximately  91%  of  the  fiber  cable  in  its  model  network  is  6  (3%),  12  (67%),  18  (9%),  24  (6%),  30  (4%),  or  36  (3%)  strand  cable.  See  Letter  from  Glenn  T.  Reynolds,  Vice  President   
 Federal  Regulatory,  BellSouth,  to  Marlene  H.  Dortch,  Secretary,  Federal  Communication  Commission,  WC  Docket  No.  02-  150  (filed  Aug.  29,  2002)  (BellSouth  August  29  Ex  Parte  Letter).  Based  on  these  BellSouth  data,  the  route-feet 
 weighted  average  fiber  cable  size  in  the  loop  network  produced  by  its  model  is  approximately  19  strand  cable. 
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 this,  where  the  size  of  a  substantially  large  percentage  of  the  cable  for  which  costs  are  developed  is  relatively  close  to  the  average  cable  size,  will  tend  to  produce  relatively  accurate  estimates  of 
 the  cost  of  installing  cable. 
 74.  Third,  BellSouth  also  provides  evidence  that  the  average  loading  factor  it  uses  to  develop  loop  costs  may  tend  to  understate  overall  installation  costs.  The  BellSouth  model 


 produces  a  loop  network  with  relatively  more  small  size  cable  than  the  actual  cable  placements  reflected  in  the  data  from  which  BellSouth  derives  the  copper  cable  loading  factors.  234  As  a 
 result,  cable  loading  factors  based  on  relatively  large  cable  sizes  are  applied  to  unloaded  cable  costs  for  relatively  small  cables.  Given  that  the  cost  of  installing  cable  is  typically  a  smaller 
 fraction  of  the  unloaded  cost  of  relatively  large  cables  compared  to  this  fraction  for  relatively  small  cables,  235  applying  loading  factors  derived  from  data  on  relatively  large  cables  to  unloaded 
 costs  for  relatively  small  cables  will  tend  to  understate  the  overall  installation  cost  for  cable. 
 75.  Fourth,  the  use  of  an  average  loading  factor  has  the  benefit  of  simplicity  without  a  significant  loss  of  precision  compared  to  use  of  multiple  loadings.  The  complexity  required  to 


 develop  different  loadings  for  different  cable  sizes,  including  the  compilation  and  analysis  of  an  enormous  amount  of  disaggregated  data  that  may  not  be  readily  available,  even  to  the  incumbent 
 LEC,  or  the  need  to  make  many  subjective  judgments  in  the  absence  of  these  data,  may  not  justify  any  possible  gain  in  the  precision  of  the  loading  estimates  resulting  from  such  a 
 methodology. 
 76.  For  the  foregoing  reasons,  WorldCom  has  not  presented  evidence  sufficient  to  show  that  the  five  state  commissions  committed  clear  error  in  their  decisions  with  respect  to 


 loading  factors.  Accordingly,  we  conclude  that  BellSouths  loading  factors  do  not  reflect  clear  errors  in  factual  findings  so  substantial  that  the  end  result  falls  outside  the  range  that  a 
 reasonable  application  of  TELRIC  principles  would  produce. 
 (ii)  Switching  Rates 
 77.  AT&  T  challenges  several  technical  aspects  of  BellSouths  switching  cost  study  and  asserts  TELRIC  errors  in  all  five  states  resulting  from  (1)  flawed  switch  discount 


 calculations;  (2)  embedded  trunking  cost  calculations;  (3)  inappropriate  assumptions  regarding  combined  local/  tandem  switches;  and  (4)  improper  allocation  of  getting  started  costs  to 


 234  In  particular,  85%  of  the  copper  cable  reflected  in  the  data  from  which  BellSouth  derives  its  loading  factors  is 
 25  (17%),  50  (28%),  100  (24%),  or  200  (16%)  pair  cable.  BellSouth  Caldwell  Reply  Aff.  at  para.  21.  Based  on  these  BellSouth  data,  the  route-  feet  weighted  average  copper  cable  size  is  approximately  156  pair  cable.  The  cable 


 in  these  data,  like  the  copper  cable  produced  by  BellSouths  model,  is  mostly  relatively  small  size  cable.  In  addition,  59%  of  the  fiber  cable  reflected  in  the  data  from  which  BellSouth  derives  its  fiber  cable  loading  factors  is 
 6  (approximately  0%),  12  (11%),  18  (1%),  24  (31%),  30  (approximately  0%),  or  36  (15%)  strand  cable.  See  BellSouth  August  29  Ex  Parte  Letter.  Based  on  these  BellSouth  data,  the  route-  feet  weighted  average  fiber  cable 
 size  is  approximately  49  strand  cable.  The  majority  of  the  cable  in  these  data,  like  the  fiber  cable  produced  by  BellSouths  model,  is  relatively  small-  size  cable. 


 235  This  is  true  due  to  the  existence  of  certain  fixed  installation  costs  that  do  not  vary  with  the  size  of  the  cable. 
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 switching  usage  and  features.  236  AT&  T  also  poses  detailed  and  overall  challenges  to  BellSouths  feature  cost  methodology,  including  the  feature  port  additive.  237 
 78.  At  the  outset,  we  note  that  all  of  these  issues  involve  complex  and  fact-  specific  challenges  related  to  BellSouths  switching  cost  model  or  inputs  which  were  approved  in 
 individual  states  only  after  state  commissions  made  adjustments  or  modifications  based  on  extensive  hearings  and  evidence.  Each  of  the  state  commissions  has  demonstrated  a 
 commitment  to  TELRIC  principles  in  setting  UNE  prices.  238  Despite  multiple  opportunities  over  several  years  to  bring  these  specific  issues  to  the  attention  of  state  commissions  in  ongoing  UNE 
 proceedings  in  each  of  the  five  states,  AT&  T  barely  did  so.  239  As  a  result,  state  commissions  in  the  applicant  states  have  not  been  afforded  the  opportunity  to  consider  many  fact-  intensive 
 questions  presented  for  the  first  time  by  AT&  T  in  response  to  this  section  271  application.  AT&  T,  furthermore,  did  not  raise  these  specific,  detailed  complaints  about  BellSouths  cost 
 models  before  the  Commission  when  we  evaluated  and  approved  BellSouths  section  271  application  for  Georgia  and  Louisiana  that  used  the  identical  models  underlying  this 
 application.  240  With  respect  to  the  complaints  that  AT&  T  raises  regarding  switch  discounts,  trunking  equipment,  combined  local/  tandem  offices  in  BellSouths  cost  models,  and  allocation  of 
 switching  costs,  as  discussed  below,  we  find  that  these  claims  are  insufficient  to  establish  that  the  state  commissions  committed  clear  error.  We  also  conclude  that  our  benchmark  analysis 
 demonstrates  that  non-  loop  rates,  which  include  the  cost  of  features,  in  Alabama,  Mississippi,  and  South  Carolina  fall  within  the  range  that  a  reasonable  application  of  TELRIC  principles 
 would  produce. 
 79.  Discounts.  AT&  T  contends  that  BellSouth  used  the  wrong  discount  for  the  5ESS  switch  because  it  does  not  reflect  the  actual  price  BellSouth  paid  for  new  switches.  241  AT&  T 


 asserts  that  BellSouth  used  a  small  sample  of  recent  switch  purchases  instead  of  using  contract-specific  new  switch  data  and  that,  after  applying  the  discount,  switch  prices  actually  exceeded 


 236  AT&  T  Comments  at  34. 
 237  Id.  at  34-  37. 
 238  See  section  IV.  B.  1.  a,  supra. 
 239  AT&  T  did  not  raise  the  switching  misallocation  issue  in  the  most  current  UNE  cost  proceedings  in  Alabama, 
 Kentucky,  Mississippi,  and  South  Carolina.  It  was  raised  in  1998  before  the  North  Carolina  Commission  and  in  early  generic  cost  dockets  in  other  states,  but  it  was  rejected.  AT&  T  raised  other  arguments  related  to  features  and 


 discounts  before  state  commissions,  but  not  the  specific  ones  it  raises  here.  The  arguments  related  to  trunk  equipment  technology  and  combined  local/  tandem  offices  were  never  presented  before  the  commissions  of  the  five 
 applicant  states.  As  we  made  clear  in  the  Verizon  Vermont  Order,  it  is  generally  impracticable  for  the  Commission  to  make  fact-  specific  findings  in  the  context  of  a  section  271  proceeding  when  the  state  commissions  fact-  specific 
 findings  were  not  challenged  at  the  state  level.  Verizon  Vermont  Order,  17  FCC  Rcd  at  7636,  para.  20. 
 240  All  five  states  use  the  Switch  Cost  Information  System  (SCIS)  Model  to  generate  switch  unit  investments. 
 North  Carolina  uses  the  model  that  is  identical  to  the  one  used  in  Georgia.  Alabama,  Kentucky,  Mississippi,  and  South  Carolina  use  the  same  model  as  Louisiana.  BellSouth  Caldwell  Aff.  at  para.  28. 


 241  AT&  T  Comments  App.,  Tab  E,  Declaration  of  Catherine  E.  Pitts  (AT&  T  Pitts  Decl.)  at  para.  5. 
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 the  contract  prices.  242  BellSouth  used  this  incorrect  discount,  according  to  AT&  T,  to  calculate  the  getting  started  cost  of  the  switch  and  in  the  new  and  growth  melding  process  that 
 determined  the  discount  applied  to  other  equipment,  resulting  in  inflated  switch  costs.  243  AT&  T  also  questions  whether  the  use  of  a  melded  discount  is  appropriate  244  and  whether  it  was  proper 
 to  use  1999-  2002  as  the  sample  period.  245  We  find  that  AT&  T  has  not  persuaded  us  that  commissions  in  the  five  applicant  states  committed  clear  error  in  adopting  BellSouths  new 
 switch  discount  for  use  in  the  SCIS  model. 
 80.  As  an  initial  matter,  we  found  in  the  BellSouth  Georgia/  Louisiana  Order  that  switching  prices  may  be  based  on  a  meld  of  new  and  growth  discounts.  246  We  recognized  that 


 certain  vendors  have  provided  a  greater  discount  for  new  switches  and  smaller  discounts  for  growth  or  expansion  of  existing  switches,  and  such  discounts  were  only  valid  when  an  overall 
 purchase  of  both  new  and  growth  equipment  was  made.  247  Moreover,  we  have  previously  stated  that  the  split  between  new  and  growth  discounts  is  a  fact-  intensive  and  specific  determination 
 that  should  be  decided  in  the  first  instance  by  state  commissions.  248  In  this  case,  however,  AT&  T  did  not  attempt  to  demonstrate  to  any  of  the  state  commissions,  as  it  specifically  asserts  here,  that 
 BellSouth  did  not  calculate  the  new  and  growth  discounts  properly,  or  how  AT&  T  would  have  calculated  them. 


 81.  As  the  record  shows,  switch  vendor  contracts  often  are  expressed  in  terms  of  a  price  per  equivalent  line,  rather  than  a  discount  off  the  list  price.  249  BellSouths  switching  cost 
 model,  however,  requires  an  input  of  a  percentage  off  the  list  price.  To  develop  a  vendor 
 242  AT&  T  Comments  at  37;  AT&  T  Pitts  Decl.  at  para.  6. 
 243  AT&  T  Pitts  Decl.  at  para.  6.  BellSouth  used  the  new  (replacement)  switch  price  for  equipment  included  in 
 the  first  cost  (getting  started  cost)  of  the  switch  and  a  melded  new  and  growth  price  for  all  remaining  switch  equipment.  Id.  at  para.  5.  The  first  cost  of  the  switch  is  the  initial  up-  front  cost  of  purchasing  a  replacement 


 switch,  while  the  growth  cost  is  the  cost  of  switch  equipment  for  adding  equipment  to  an  existing  switch.  Id.  at  n.  2.  BellSouth  disputes  AT&  Ts  claim  that  BellSouth  used  a  melded  new  and  growth  discount  for  the  entire  switch 
 in  North  Carolina.  AT&  T  Pitts  Decl.  at  para.  5  n.  1;  BellSouth  Caldwell  Reply  Aff.  at  para.  67. 
 244  AT&  T  Pitts  Decl.  at  para.  5. 


 245  Id.  at  para.  7;  see  also  AT&  T  Comments  at  37. 
 246  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9057-  58,  para.  78.  AT&  T  did  not  argue  there  that  the 
 specific  discounts  that  were  applied  by  BellSouth  were  inappropriate.  Id.  at  9059-  60,  para.  82. 
 247  Id.  at  9059,  para.  81. 


 248  Verizon  New  Jersey  Order,  17  FCC  Rcd  at  12293,  para.  43.  We  have  found,  however,  that  switch  prices 
 based  on  an  assumption  of  100%  growth  additions  did  not  comply  with  TELRIC.  Application  by  Verizon  New  England  Inc.,  Bell  Atlantic  Communications  Inc.  (d/  b/  a  Verizon  Long  Distance),  NYNEX  Long  Distance  Company 


 (d/  b/  a  Verizon  Enterprise  Solutions),  Verizon  Global  Networks  Inc.,  and  Verizon  Select  Services  Inc.,  for  Authorization  To  Provide  In-  Region,  InterLATA  Services  in  Rhode  Island,  CC  Docket  No.  01-  324,  Memorandum 
 Opinion  and  Order,  17  FCC  Rcd  3300,  3318,  para.  34  (2002)  (Verizon  Rhode  Island  Order). 
 249  BellSouth  Caldwell  Reply  Aff.  at  para.  69. 
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 discount  percentage  for  use  in  the  cost  model,  BellSouth  used  information  from  actual  switch  replacement  jobs  to  determine  what  the  price  for  a  new  switch  would  be  without  a  discount,  and 
 then  compared  it  to  what  was  billed  by  the  vendor  with  the  discount.  250  BellSouth  analyzed  each  of  its  28  new  switch  jobs  in  1998  covered  under  its  then-  current  vendor  contracts  that  reflected 
 what  BellSouth  paid  to  its  switch  vendors.  251  To  develop  forward-  looking  switch  costs,  it  is  reasonable  to  use  current  switch  prices,  reflecting  actual  purchases  and  existing  vendor 
 discounts,  as  a  starting  point.  LECs  today  generally  have  digital  switches  in  place  throughout  their  entire  network  and  are  purchasing  relatively  few  new  switches.  As  a  result,  a  study  size  of 
 28  new  switches  may  not  be  unreasonable.  Expanding  the  study  size  would  require  information  on  older  purchases  that  might  be  less  relevant  to  determining  what  BellSouth  would  pay  for  a 
 switch  on  a  forward-  looking  basis.  BellSouths  cost  studies  were  forward-  looking  in  omitting  analog  switches  and  considering  only  the  latest  releases  by  switch  vendors  for  switch  generics 
 and  the  latest  central  office  processor.  252 
 82.  The  state  commissions  determined  switch-  related  costs  and  set  rates  based  on  the  discount  rates  and  methodology  contained  in  BellSouths  cost  studies.  253  As  we  stated  in  prior 


 section  271  proceedings,  state  commissions  may  reasonably  find  that  cost  models  can,  in  a  forward-  looking  manner,  take  into  account  specific  new  and  growth  discounts  that  are  reflected 
 in  contracts  with  vendors.  254  Based  on  the  evidence,  we  do  not  believe  that  AT&  T  has  established  that  the  sample  of  recent  switch  purchases  by  BellSouth  was  clear  error  or  that 
 BellSouth  relies  on  embedded  switching  costs  that  are  inconsistent  with  TELRIC  principles.  255 


 250  Id.  Using  actual  orders,  BellSouth  populated  SCIS/  MO  with  engineering  data  (e.  g.,  number  of  lines,  number 
 of  trunks,  CCS  per  line,  etc.)  taken  directly  from  orders  used  to  purchase  new/  replacement  switches.  These  SCIS/  MO  runs  produced  a  total  non-  discounted  investment  for  the  switch.  The  total  material  price  was  then 


 compared  to  the  actual  billing  from  vendors.  Since  SCIS/  MO  requires  an  input  of  a  %  off  list  price,  BellSouth  used  an  [iterative]  process  (i.  e.,  repeatedly  changing  the  SCIS/  MO  discount  input)  to  determine  the  correct  switch 
 discount  required  to  match  the  amount  actually  billed  per  line.  .  .  .  Since  the  jobs  were  worked  under  the  auspices  of  the  current  switch  contracts,  the  actual  billed  data  from  actual  new/  replacement  jobs  reflect  the  appropriate  rates 
 per  contract.  Id.  at  paras.  69,  70. 
 251  Id.  at  para.  74.  BellSouth  used  billed  data  from  its  BellSouth  Construction  Activity  System  of 
 replacement/  new  switch  orders  that  reflected  the  amount  paid  by  BellSouth  to  either  Lucent  or  Nortel.  The  28  jobs  BellSouth  examined  is  [sic]  extensive  considering  that  the  requirement  for  placing  new  switches  or  replacing 


 existing  analog  switches  is  limited.  This  reflected  the  totality  of  all  replacement/  new  jobs  that  were  worked  under  the  current  contracts  and  closed  in  1998.  .  .  .  Id. 


 252  Id.  at  para.  58. 
 253  Id.  at  77.  In  the  generic  cost  dockets  in  Alabama,  Kentucky,  Mississippi,  North  Carolina,  and  South 
 Carolina,  []  the  state  commissions  established  switch-  related  rates  based  upon  BellSouths  cost  studies,  which  developed  switching  investment  by  using  BellSouths  existing  contracts  with  Nortel  and  Lucent  .  .  .  .  BellSouths 


 cost  studies  took  into  consideration  the  cost  associated  with  both  the  initial  placement  and  growth  of  the  switch  .  .  .  .  BellSouth  Caldwell  Aff.  at  para.  105. 


 254  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9058-  59,  paras.  79,  81. 
 255  AT&  T  Pitts  Decl.  at  para.  6;  Letter  from  Alan  C.  Geolot,  Counsel  to  AT&  T,  to  Marlene  H.  Dortch,  Secretary, 
 Federal  Communications  Commission,  WC  Docket  No.  02-  150  at  4  (filed  Aug.  23,  2002)  (AT&  T  August  23  (continued.) 
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 Furthermore,  BellSouth  provides  persuasive  evidence  that  using  actual  billed  data  for  jobs  worked  under  vendor  contracts  is  a  more  accurate  way  to  determine  discounts  than  attempting  to 
 derive  this  information  directly  from  contracts,  as  AT&  T  argues.  256  By  contrast,  we  are  left  with  no  analysis  or  work  papers  demonstrating  how  AT&  T  arrived  at  its  assertion  that  BellSouths 
 method  of  computing  discounts  led  to  prices  that  exceeded  the  contract  rate,  257  and,  without  more,  we  reject  that  assertion.  BellSouth  also  reasonably  explains  that  it  based  its  meld  of  new  and 
 growth  discounts  on  the  number  of  lines  projected  to  be  purchased  between  1999  and  2002.  We  do  not  believe,  as  AT&  T  contends,  that  this  is  an  inappropriate  sample  period.  We  find  that  it 
 rationally  corresponds  to  the  specified  time  frame  of  the  cost  study. 
 83.  AT&  T  also  asserts  that  the  appropriate  melded  discount  would  reflect  82  percent  of  the  new  switch  discount  and  18  percent  of  the  growth  discount.  258  AT&  T  apparently  assumes 


 that  BellSouth  would  have  received  the  same  new  and  growth  switch  contract  discounts  regardless  of  the  mix  of  new  and  growth  purchases  that  BellSouth  expected  to  make.  As  noted 
 above,  however,  although  vendors  offer  a  higher  discount  rate  for  new  switches  and  a  lower  discount  for  growth,  vendors  may  realistically  set  the  specific  discount  rates  on  the  basis  of  the 
 anticipated  overall  purchase.  259  BellSouth  argues  that  AT&  Ts  82%  new  purchase  assumption  is  not  realistic  because  switch  vendors  would  not  have  accepted  the  resulting  reduction  in  their 
 margin  and  that  it  would  invalidate  the  entire  discount  structure  under  which  the  contracts  were  negotiated.  260  We  find  merit  in  BellSouths  assertion  that  the  levels  of  new  and  growth  switch 
 discounts  reflect  the  vendors  judgments  about  anticipated  purchases.  AT&  T  has  not  persuaded  us  that  the  new-  growth  switch  discount  alone  could  be  changed  without  affecting  the  rest  of  the 
 negotiated  discount  structure  in  the  vendor  contracts. 
 84.  Using  a  meld  of  new  and  growth  discounts  in  developing  switching  rates  also  recognizes  that  it  may  not  be  cost-  effective  to  acquire  all  of  the  projected  switching  capacity 


 (Continued  from  previous  page)  Pricing  and  Growth  Tariff  Ex  Parte  Letter)  (contending  that  BellSouths  reliance  on  embedded  switches  and 
 overemphasis  on  growth/  add-  on  investment  violate  TELRIC  principles);  see  also  id.  App.,  Supplemental  Reply  Declaration  of  Catherine  E.  Pitts  (AT&  T  Pitts  Supp.  Reply  Decl.)  at  paras.  12-  16. 


 256  Id.;  BellSouth  Caldwell  Aff.  at  para.  71.  Switch  contracts  do  not  provide  the  necessary  detail  and  require 
 interpretation  and  clarification  of  which  rates  apply.  In  addition,  the  equivalent  lines  expressed  in  a  contract  are  not  the  same  as  the  line  count  entered  into  the  SCIS/  MO  cost  model,  so  taking  the  lines  from  the  cost  model  and 


 multiplying  by  the  price  per  equivalent  line  from  the  contract  would  understate  the  cost  of  a  new  switch.  BellSouth  Caldwell  Aff.  at  para.  72. 


 257  AT&  T  Pitts  Decl.  at  para.  6 
 258  AT&  T  Comments  at  37-  38;  AT&  T  Pitts  Decl.  at  para.  8,  Exh.  1. 
 259  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9059,  para.  81;  AT&  T  v.  FCC,  220  F.  3d  at  618  (stating 
 that  counsel  for  the  Commission  explained  at  oral  argument  that  growth  additions  to  existing  switches  cost  more  than  new  switches  because  vendors  offer  substantial  new  switch  discounts  in  order  to  make  telephone  companies 


 dependent  on  the  vendors  technology  to  update  the  switches). 
 260  BellSouth  Caldwell  Reply  Aff.  at  para.  76. 
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 needed  over  the  life  of  the  switch  at  the  outset.  261  In  calculating  switching  rates,  BellSouth  applied  the  higher  (new)  discount  rate  to  about  one-  third  of  the  investment,  leaving  the  melded 
 discount  rate  to  be  applied  to  the  remaining  two-  thirds  of  the  investment.  262  This  has  the  effect  of  substantially  narrowing  the  difference  in  rates  resulting  from  the  melded  discount  rate  that  was 
 used  by  BellSouth  and  that  advocated  by  AT&  T.  In  sum,  we  have  been  presented  with  no  evidence  or  rationale  that  would  persuade  us  that  the  split  of  new  to  growth  discounts  in  the  cost 
 models  approved  by  the  commissions  in  the  applicant  states  is  not  TELRIC-  compliant.  We  conclude,  therefore,  that  AT&  T  has  not  established  any  clear  error  by  the  commissions  in  the 
 five  applicant  states. 
 85.  Trunking  Technology.  AT&  T  claims  that  BellSouth  does  not  model  forward-looking  trunk  equipment  technology  because  it  fails  to  assume  the  ubiquitous  deployment  of  a 


 switch  component  known  as  Digital  Network  Unit-  SONET  (DNUS).  263  BellSouth  admits  that  DNUS  may  be  the  latest  technology  for  trunk  terminations,  but  it  disputes  AT&  Ts  contention 
 that  it  is  the  most  forward-  looking,  economical  deployment  in  all  instances  because  it  is  a  high-capacity  interface.  264  BellSouth  further  asserts  that,  where  the  yearly  growth  rate  justifies  a  high-capacity 
 interface,  BellSouths  model  assumes  DNUS  use.  265  Although  AT&  T  states  that  it  has  raised  this  issue  in  the  pending  Georgia  cost  proceeding,  it  did  not  do  so  in  any  of  the  five  states 
 at  issue  here. 
 86.  AT&  T  also  asserts  without  any  supporting  analysis  that  [  c]  orrecting  the  SCIS  inputs  to  reflect  the  DNUS  equipment  in  the  current  Georgia  [cost]  proceeding  lowered  the  trunk 


 costs  eight  percent.  266  Again,  we  note  that,  although  this  issue  is  apparently  under  consideration  in  the  Georgia  cost  proceeding,  AT&  T  did  not  raise  it  in  any  of  the  five  states  represented  in  this 
 section  271  application.  At  bottom,  we  have  nothing  more  than  AT&  Ts  bare  assertion  that  the  use  of  DNUS  technology  would  lower  trunking  costs,  at  least  under  certain  circumstances,  267 


 261  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9059-  60,  para.  82. 
 262  BellSouth  Caldwell  Reply  Aff.  at  Exh.  DDC-  5. 
 263  AT&  T  Pitts  Decl.  at  para.  9  (stating  that  BellSouth  assumes  the  use  of  a  Digital  Line  Trunk  Unit  (DLTU)). 
 264  BellSouth  Caldwell  Reply  Aff.  at  para.  78.  The  use  of  the  DNUS  decreases  the  cost  per  trunk,  but  only  if  it  is 
 fully  utilized.  The  DNUS  is  a  high  capacity  interface,  capable  of  terminating  8,064  trunks.  Thus,  the  utilization  is  relatively  low  except  in  a  limited  number  of  central  offices  where  demand  for  trunk  terminations  is  high.  Id. 


 (emphasis  in  original).  Because  DNUS  requires  that  the  interfaces  be  at  the  DS-  3  level,  it  may  also  require  additional  expensive  equipment  to  multiplex  individual  DS-  1s  to  the  DS-  3  level.  Id. 


 265  BellSouth  Reply  at  38.  DNUS  is  not  intended  to  replace  the  DLTU  in  every  office.  BellSouth  assumed  the 
 DNUS  was  present  in  an  office  if  .  .  .  the  growth  rate  that  triggers  placement  of  DNUS  equipment  is  250  trunks  per  year,  which  is  based  on  economic  considerations  .  .  .  .  BellSouth  Caldwell  Reply  Aff.  at  para.  79.  BellSouth  also 


 contends  that  it  chose  to  use  the  DLTU  in  all  cases  for  packet  trunks  (Primary  Rate  ISDN)  to  reduce  costs.  Id.  at  para.  80. 


 266  AT&  T  Pitts  Decl.  at  para.  9. 
 267  See  nn.  264-  65,  supra. 
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 although  it  has  not  established  the  magnitude  of  that  reduction  in  this  section  271  proceeding.  268  Given  the  lack  of  any  state  record  on  this  issue,  AT&  Ts  unsupported  assertions,  and  BellSouths 
 reasonable  explanation  that  DNUS  is  the  cost-  minimizing  technology  only  where  growth  rates  are  high,  269  we  conclude  that  AT&  T  has  not  demonstrated  that  any  of  the  states  committed  clear 
 error  in  adopting  BellSouths  assumption  regarding  trunk  equipment  technology. 
 87.  Combined  Local/  Tandem  Modeling.  AT&  T  claims  that  BellSouths  cost  model  assumes  its  network  uses  only  combined  local/  tandem  switches  and  that  there  are  no  switches 


 that  perform  only  local  end-  office  or  tandem  functions.  270  AT&  T  asserts  that  this  overstates  costs  by  failing  to  reflect  a  greater  discount  for  tandem  switches,  increasing  the  getting  started  costs, 
 and  understating  switch  utilization  levels.  271  Although  AT&  T  is  correct  that  BellSouth's  switching  model  assumes  the  exclusive  use  of  combined  local/  tandem  switches,  AT&  T  has  not 
 established  that  this  assumption  necessarily  overstates  costs.  272 
 88.  As  a  preliminary  matter,  we  note  that  it  is  appropriate  for  state  commissions  to  consider  these  kinds  of  fact-  specific  issues  pertaining  to  assumptions  used  in  BellSouths  cost 


 model,  but  neither  AT&  T  nor  any  other  party  raised  these  issues  in  the  state  proceedings.  In  response  to  AT&  Ts  arguments,  BellSouth  explains  that  it  employed  the  local/  end  office 
 combination  designation  to  capture  the  cost  difference  between  the  trunk  termination  of  a  local  trunk  and  the  termination  of  a  tandem  trunk.  273  In  order  to  capture  tandem  trunks  in  the  cost 
 calculation,  the  SCIS/  MO  requires  that  an  office  carry  the  local/  tandem  designation.  274  BellSouth  also  provides  an  analysis  showing  that,  despite  AT&  Ts  contrary  assertions,  the  combined 
 local/  tandem  office  designation  actually  decreases  getting  started  costs.  275  AT&  T  also  fails  to 
 268  AT&  T  Pitts  Decl.  at  para.  9.  Without  endorsing  AT&  Ts  claim,  BellSouth  provides  an  analysis  to  show  that 
 reducing  the  trunk  per  minute  of  use  rates  by  8%  (times  the  5ESS  distribution)  only  reduces  the  calculated  average  monthly  usage  rate  by  less  than  1%,  or  three  cents  on  average  per  line,  per  month  (based  on  standard  switching 


 assumptions  that  the  Commission  uses  in  its  benchmark  analysis).  BellSouth  Caldwell  Reply  Aff.  at  para.  81. 
 269  See  section  IV.  B.  1,  supra. 


 270  AT&  T  Comments  at  38;  AT&  T  Pitts  Decl.  at  para.  10. 
 271  AT&  T  Pitts  Decl.  at  para.  10.  AT&  T  appears  to  imply  that  tandem  switches  receive  a  greater  discount  than 
 local  end  offices,  and  BellSouth  does  not  reflect  this  in  its  cost  study. 
 272  The  SCIS  model  provides  long-  run,  forward  looking  costs,  but  the  program  was  not  specifically  developed 
 for  BellSouth  or  for  TELRIC  cost  studies.  North  Carolina  Commission  UNE  Rate  Order  at  54. 
 273  BellSouth  Caldwell  Reply  Aff.  at  para.  82. 


 274  Id.  The  difference  in  investment  is  slight  in  the  5ESS  switch.  However,  in  the  DMS  switch,  the  difference  is 
 more  substantial  since  Nortel  recommends  additional  testing  of  the  tandem  trunk  termination,  which  requires  additional  equipment.  Id. 


 275  Id.  at  para.  83.  The  getting  started  investment  for  a  5ESS  end  office/  tandem  is  approximately  $550 
 (discounted)  more  per  switch  than  an  end  office,  increasing  costs  by  $0.0008  per  millisecond.  The  getting  started  investment  for  a  DMS  end  office/  tandem  is  less  per  switch  than  the  equivalent  investment  for  an  end  office  by  about 


 $22,000,  reducing  costs  by  about  $0.03  per  millisecond. 
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 offer  sufficient  evidence  to  support  its  implied  conclusion  that  BellSouth  receives  a  greater  discount  for  combined  local/  tandem  switches  than  local  end  offices.  276  Furthermore,  AT&  T  fails 
 to  substantiate  its  assertion  that  BellSouth  overstates  costs  by  understating  the  higher  utilization  levels  associated  with  combined  tandem/  local  offices.  277  First,  AT&  T  offers  no  analysis  of  the 
 size  of  this  cost  impact,  so  we  cannot  evaluate  the  significance  of  its  assertion.  Second,  even  though  BellSouth  was  constrained  to  designate  only  combined  local/  tandem  offices  in  the  cost 
 model,  we  are  persuaded  by  BellSouths  explanation  that  it  was  reasonable  to  use  end  office  utilization  data  because  the  switch  is  actually  serving  an  end  office  function  in  the  network.  278  In 
 sum,  BellSouth  offers  reasonable  explanations  for  the  modeling  assumption  necessary  to  accommodate  the  limitations  of  the  SCIS  model.  Accordingly,  we  find  that  BellSouths  use  of 
 the  combined  local/  tandem  switch  in  its  cost  model  is  not  inconsistent  with  results  that  a  reasonable  application  of  TELRIC  principles  would  produce. 


 89.  Switch  Allocation  Issues.  AT&  T  raises  issues  related  to  the  allocation  of  switching  costs  and  rate  structure  design.  279  It  specifically  argues  that  BellSouth  should  recover 
 getting  started  costs  in  the  fixed  port  charges,  and  [its]  allocation  of  these  costs  to  the  minute-of-  use  and  feature  port  additive  charges  violates  TELRICs  cost-  causation  principles.  280  AT&  T 
 contends  that  this  disparity  between  the  way  BellSouth  attempts  to  recover  its  switch  costs  and 


 276  See  AT&  T  Pitts  Decl.  at  para.  10.  BellSouth  obtains  end  offices  under  contract,  but  purchases  tandem 
 switches  using  a  competitive  bid  process.  BellSouth,  however,  applies  only  its  end  office  discounts  .  .  .  to  all  of  its  switches.  Id.  BellSouth  responds  that  it  has  not  used  the  bid  process  since  the  late  1990s  for  end  offices  or 


 tandems.  BellSouth  Caldwell  Reply  Aff.  at  para.  85. 
 277  AT&  T  Comments  at  38.  AT&  T  contends  that  this  understated  utilization  leads  to  increased  costs  per-processor- 
 millisecond  and  inflated  end-  office  and  tandem  minute-  of-  use  and  feature  rate  charges. 
 278  BellSouth  Caldwell  Reply  Aff.  at  para.  84. 


 279  AT&  T  also  raises  similar  issues  to  those  it  raised  in  the  Maine  section  271  proceeding  in  which  AT&  T  argued 
 that  the  majority  of  switching  costs  are  not  usage-  sensitive  and  should  be  recovered  in  the  fixed  port  charge  rather  than  usage  elements.  AT&  T  Pitts  Decl.  at  para.  14;  Application  by  Verizon  New  England  Inc.,  Bell  Atlantic 


 Communications,  Inc.  (d/  b/  a/  Verizon  Long  Distance),  NYNEX  Long  Distance  Company  (d/  b/  a  Verizon  Enterprise  Solutions),  Verizon  Global  Networks  Inc.,  and  Verizon  Select  Services  Inc.,  for  Authorization  to  Provide  In-  Region, 
 InterLATA  Services  in  Maine,  CC  Docket  No.  02-  61,  Memorandum  Opinion  and  Order,  17  FCC  Rcd  11659,  11674-  75,  para.  27  (2002)  (Verizon  Maine  Order).  Consistent  with  prior  section  271  orders,  we  believe  that,  as  a  general 
 matter,  rate  design  is  appropriately  decided  by  state  commissions  in  the  first  instance.  See,  e.  g.,  Verizon  New  Jersey  Order,  17  FCC  Rcd  at  12300-  01,  para.  58  (concerning  recovery  of  labor  costs  associated  with  DUF  rates). 


 280  AT&  T  Comments  at  38-  39.  These  getting  started  costs  are  fixed  and  largely  associated  with  maintenance, 
 administrative,  test,  and  spare  equipment,  memory,  and  other  common  equipment  in  the  switch.  Such  getting  started  costs  do  not  vary  with  respect  to  the  number  of  lines  or  switch  usage.  BellSouth  has  very  low  switch-processor 


 utilization,  which  means  that  BellSouths  switch  processors  will  not  exhaust  on  calls,  and  thus  the  costs  are  not  traffic  sensitive.  Id.  According  to  AT&  T,  getting-  started  costs  should  be  allocated  to  the  port  and  not  traffic 
 sensitive  elements  because  the  number  of  switch  modules  required  is  driven  by  ports,  not  by  calls  or  other  usage.  AT&  T  Pitts  Decl.  at  paras.  11-  16;  AT&  T  Pitts  Supp.  Reply  Decl.  at  paras.  17-  19.  AT&  T  also  contends  that 
 BellSouth  similarly  misallocates  a  common  part  of  the  switch  called  Equivalent  POTS  Half  Call  to  traffic  sensitive  instead  of  fixed  rate  elements.  AT&  T  Comments  at  38-  39;  AT&  T  Pitts  Decl.  at  paras.  11-  16. 
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 the  way  it  incurs  costs  disadvantages  competitive  LECs.  281  We  conclude  that  BellSouths  allocation  of  switching  costs  conforms  to  our  rules  and  is  consistent  with  the  allocation  ratios 
 that  the  Commission  has  previously  approved.  AT&  Ts  evidence  thus  does  not  persuade  us  that  the  state  commissions  committed  clear  error  in  their  allocation  of  switching  costs. 


 90.  As  a  preliminary  matter,  AT&  T  here  refers  to  a  feature  port  additive  rate  element  that  BellSouth  no  longer  has  in  its  rate  structure.  282  To  the  extent  that  AT&  T  intends  to  refer  to 
 feature  elements,  we  also  note  that  BellSouth  presently  recovers  these  costs  through  the  port,  consistent  with  the  manner  in  which  AT&  T  contends  they  could  be  recovered.  283 


 91.  At  the  outset,  the  record  shows  that  no  party  raised  these  arguments  in  the  most  current  state  proceedings  in  Alabama,  Kentucky,  Mississippi,  and  South  Carolina.  284  In  the 
 North  Carolina  UNE  proceeding,  AT&  T  raised  the  same  argument  that  getting  started  investment  consists  of  non-  traffic  sensitive  costs  and  thus  should  be  recovered  in  the  non-  traffic 
 sensitive  port  rate  element,  but  it  was  rejected.  285  AT&  T  also  contended,  similar  to  its  assertion  here,  that  getting  started  costs  consist  of  one-  time  fixed  investments  and  that  it  is  inappropriate 
 to  assume  that  this  is  traffic  sensitive  because  it  does  not  follow  the  basic  TELRIC  principle  of  reflecting  costs  based  on  causation.  286  The  state  commission,  however,  did  not  adopt  AT&  Ts 
 proposal  and  maintained  BellSouths  allocation  between  non-  traffic  sensitive  and  traffic  sensitive  switch-  related  investments.  287  The  record  also  shows  that  the  state  commissions  in 
 Alabama,  Mississippi,  and  South  Carolina  reached  similar  findings.  288  As  we  discuss  below,  we 
 281  AT&  T  Pitts  Decl.  at  para.  15.  CLECs  will  incur  a  higher  cost  for  usage  than  BellSouth  incurs  because  the 
 CLECs  minute-  of-  use  element  is  inflated  by  the  fixed  costs.  Id. 
 282  We  discuss  features  separately.  See  para.  94,  infra.  Prior  to  its  section  271  application,  BellSouth  took  55% 
 of  the  then  existing  feature  port  additive  charge  and  added  it  to  the  port  element  in  Alabama,  Mississippi,  and  South  Carolina.  BellSouth  also  voluntarily  eliminated  charges  associated  with  UNE  vertical  features  in  North  Carolina. 


 There  was  no  separate  charge  for  features  in  Kentucky. 
 283  Letter  from  Joan  Marsh,  Director    Federal  Government  Affairs,  AT&  T,  to  Marlene  H.  Dortch,  Secretary, 
 Federal  Communications  Commission,  WC  Docket  No.  02-  150  (filed  Aug.  1,  2002)  (AT&  T  August  1  Ex  Parte  Letter).  AT&  T  disputed  the  feature  costs  that  BellSouth  seeks  to  recover  but  agreed  that  any  appropriate  costs 


 associated  with  features  should  be  recovered  through  the  port  element  rather  than  through  usage  charges.  Id. 
 284  BellSouth  Caldwell  Reply  Aff.  at  para.  95. 


 285  BellSouth  Application  App.  D,  Vol.  8a-  c,  Tab  10,  Part  C,  Docket  No.  P-  100,  Sub  133d  (Rebuttal  Testimony  of 
 Catherine  E.  Petzinger  (Pitts)  on  Behalf  of  AT&  T  Communications  of  the  Southern  States,  Inc.,  Before  the  North  Carolina  Utilities  Commission)  (filed  March  9,  1998)  at  981  (AT&  T  North  Carolina  Testimony);  BellSouth 


 Caldwell  Reply  at  para.  95. 
 286  AT&  T  North  Carolina  Testimony  at  981.  In  addition  to  the  processor,  there  are  numerous  other  items  in  the 
 SCIS/  MO  Getting  Started  Investment,  which  are  one-  time  fixed  investments  incurred  as  a  first  cost.  BellSouth,  however,  has  assumed  that  the  entire  Getting  Started  Investment  for  every  switch  is  traffic  sensitive.  Id. 


 287  BellSouth  Caldwell  Reply  Aff.  at  para.  95. 
 288  Id. 
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 believe  the  state  commissions  acted  in  a  manner  that  is  consistent  with  our  rules  and  previous  decisions. 
 92.  The  Local  Competition  Order  adopted  the  general  rule  that  incumbent  LECs  rates  for  interconnection  and  unbundled  elements  must  recover  costs  in  a  manner  that  reflects  the 
 way  they  are  incurred.  289  The  Commission  also  adopted  additional  rate  structure  rules  for  shared  facilities  that  give  states  the  flexibility  to  decide  whether  to  recover  these  costs  through  either 
 usage-  sensitive  or  flat-  rated  charges.  290  The  Commissions  rules  also  provide  that  local  switching  costs  shall  be  recovered  through  a  combination  of  a  flat-  rated  charge  for  line  ports 
 which  are  dedicated  facilities,  and  either  a  flat-  rated  or  per-  minute  usage  charge  for  the  switching  matrix  and  for  trunk  ports  which  are  shared  facilities.  291 


 93.  At  the  same  time,  the  Commission  declined  to  prescribe  the  appropriate  allocation  of  switching  costs  as  between  the  line  port,  which  must  be  flat-  rated,  and  the  switching  matrix 
 and  trunk  ports.  Because  the  Commission  did  not  prescribe  a  specific  allocation,  the  states  retain  the  flexibility  to  adopt  an  allocation  within  a  reasonable  range.  As  we  stated  in  the  Verizon 
 Maine  Order,  because  some  portion  of  switching  costs  is  fixed,  an  allocation  of  100  percent  of  the  switching  costs  to  the  minutes-  of-  use  element  would  be  unreasonable  per  se.  We  also  found 
 that  a  state  commissions  allocation  of  30  percent  fixed  to  70  percent  minutes-  of-  use  does  not  fall  outside  a  reasonable  range.  292  BellSouth  demonstrates  that  its  allocation  between  non-  traffic 
 sensitive  and  traffic  sensitive  charges  for  the  five  applicant  states  is  almost  exactly  the  same  here,  ranging  from  an  allocation  of  32  percent  fixed/  68  percent  minutes-  of-  use  (Alabama)  to  28 
 percent  fixed/  72  percent  minutes-  of-  use  (North  Carolina  and  South  Carolina).  293  Thus,  we  conclude  that  the  switching  allocations  adopted  by  these  five  states  are  consistent  with 
 allocations  the  Commission  has  previously  approved. 
 94.  Vertical  Features.  AT&  T  poses  a  number  of  challenges  to  BellSouths  feature  cost  development.  BellSouth  explains  that  it  attempted  to  determine  the  forward-  looking  costs 


 of  providing  competitive  LEC  customers  with  the  ability  to  access  all  of  the  available  features  in 


 289  Local  Competition  Order,  11  FCC  Rcd  at  15874,  para.  743. 
 290  Id.  at  15877,  para.  753.  Shared  facilities  are  those  used  by  multiple  parties.  Id.  at  15873,  para.  741;  see  also 
 47  C.  F.  R.    51.507(  c). 
 291  Local  Competition  Order,  11  FCC  Rcd  at  15905,  para.  810;  47  C.  F.  R.    51.509(  b).  AT&  T  refers  to  getting 
 started  costs  as  common  equipment  in  the  switch.  AT&  T  Pitts  Decl.  at  paras.  11,  14.  Thus,  AT&  T  does  not  dispute  that  getting  started  costs  refer  to  the  portion  of  the  switch  that  is  a  shared  facility. 


 292  Verizon  Maine  Order,  17  FCC  Rcd  at  11676,  para.  29. 
 293  Letter  from  Glenn  T.  Reynolds,  Vice  President    Federal  Regulatory,  BellSouth,  to  Marlene  H.  Dortch, 
 Secretary,  Federal  Communications  Commission,  WC  Docket  No.  02-  150  (filed  July  26,  2002)  (BellSouth  July  26  Ex  Parte  Letter).  Non-  traffic  sensitive  to  traffic  sensitive  comparisons  for  each  of  the  five  states  are  as  follows: 


 Alabama,  32%  to  68%;  Kentucky,  30%  to  70%;  Mississippi,  29%  to  71%;  North  and  South  Carolina,  28%  to  72%.  Id. 
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 a  switch.  294  The  SCIS/  MO  cost  model,  however,  was  not  designed  to  calculate  the  cost  of  access  to  all  switch  features,  so  BellSouth  developed  the  SST  model  to  derive  feature  costs.  295 
 Generally,  BellSouth  tried  to  determine  a  feature  cost  that  reflects  the  costs  BellSouth  incurs  to  give  a  typical  customer  access  to  all  features  and  functions  of  a  switch.  296 


 95.  More  specifically,  BellSouth  attempts  to  calculate  the  demand  placed  on  a  switch  in  a  peak  period  (busy  hour)  for  various  kinds  of  feature  calls  and  multiplies  this  by  the  number 
 of  features  used  by  an  average  customer.  297  To  get  the  average  busy  hour  use,  BellSouth  used  56  features  that  it  asserts  are  representative  because  they  reflect  a  mix  of  features  that  use  the 
 various  switch  resources  in  processing  feature-  related  calls,  including  the  processor,  line  equipment,  hardware,  and  signaling  system.  298  BellSouth  used  retail  cost  studies  to  develop  an 
 average  busy  hour  demand  placed  on  these  various  switch  resources.  299  BellSouth  then  multiplied  the  average  busy  hour  demand  by  the  number  of  features  per  average  customer  300  to 
 get  the  average  feature-  related  demand  placed  on  the  switch  per  line.  301  Finally,  it  multiplied  this  demand  by  the  cost  it  developed  from  another  study  which  analyzed  the  various  costs  of  the 
 switching  components  involved  in  providing  features.  302  BellSouth  also  attempts  to  show  that  its  features  costs  are  reasonable  by  offering  an  analysis  using  feature  penetration  rates  in  Georgia 
 and  comparing  BellSouths  feature  rates  to  Verizons  New  York  rates.  303 


 294  BellSouth  Caldwell  Reply  Aff.  at  para.  104. 
 295  Id.  at  paras.  104-  05.  [  N]  umerous  assumptions  had  to  be  made  in  the  modeling  process.  For  example,  how  to 
 condense  the  list  of  existing  features  to  a  palatable,  yet  representative,  subset;  how  to  accurately  reflect  the  variation  in  feature  switch  resource  requirements  (some  features  only  use  the  processor,  some  need  hardware,  etc.);  how  to 


 determine  a  reflective  input  for  the  number  of  milliseconds,  octets,  or  holding  times  required  by  the  typical  feature;  and  how  to  determine  the  CLEC  feature  usage  characteristics.  Id. 


 296  Id.  at  para.  104. 
 297  Switches  are  designed  to  handle  calling  for  a  peak  period,  or  busy  hour,  and  therefore  switch  costs  are  based 
 on  this  capacity. 
 298  BellSouth  Caldwell  Reply  Aff.  at  para.  107.  An  attempt  was  made  to  reflect  each  possible  combination  of  the 
 four  switch  components  (processor,  line,  hardware,  SS7)  in  the  list  of  56  features.  Additionally,  these  56  are  some  of  the  most  common  features  purchased.  Id.  They  also  are  a  substantial  portion  of  the  200  unique  features  that 


 are  available.  BellSouth  Reply  at  41;  see  also  BellSouth  Caldwell  Reply  Aff.  at  para.  108. 
 299  Id.  at  para.  110. 


 300  BellSouth  derived  the  number  of  features  per  average  user  from  its  Complete  Choice  retail  offering.  Complete 
 Choice  customers  have  access  to  an  extensive  list  of  features,  but  BellSouth  contends  that  the  average  customer  uses  only  four  features.  Id. 


 301  Id. 
 302  Letter  from  Sean  A.  Lev,  Counsel  to  BellSouth,  to  Marlene  H.  Dortch,  Secretary,  Federal  Communications 
 Commission,  WC  Docket  No.  02-  150  (filed  July  25,  2002)  (BellSouth  July  25  Ex  Parte  Letter). 
 303  BellSouth  Caldwell  Reply  Aff.  at  paras.  114,  122-  26  &  Exh.  DDC  9-  11. 
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 96.  BellSouth  used  its  cost  methodology  in  Alabama,  Mississippi,  and  South  Carolina  to  develop  an  average  feature  port  additive  rate  for  competitive  LEC  customers  that  ordered  one 
 or  more  features.  Prior  to  filing  this  section  271  application,  BellSouth  incorporated  55  percent  of  the  feature  port  additive  rate  into  the  port  charge,  paid  by  all  customers.  In  response  to  AT&  T 
 criticism,  BellSouth  asserts  that  its  modified  features  recovery  is  reasonable  because  55  percent  of  its  lines  have  at  least  one  vertical  feature  and  that  this  take  rate  is  now  reflected  in  the 
 revenue-  neutral  pricing  of  features  across  all  lines.  304  AT&  T  contends  that  BellSouths  cost  model  for  developing  a  composite  feature  rate  is  fatally  flawed.  305  AT&  T  bases  a  substantial 
 part  of  its  argument  related  to  feature  costs  on  several  technical  aspects  of  BellSouths  feature  cost  methodology  and  its  complex  calculations.  306  For  example,  AT&  T  argues  that  BellSouths 
 underlying  study  of  56  features  incorrectly  mixes  feature  use  together  for  various  classes  of  service,  fails  to  take  into  account  usage  characteristics  based  on  penetration  levels  of  features, 
 and  assumes  4.5  feature  calls  in  the  busy  hour  which  are  excessive.  307  AT&  T  also  criticizes  BellSouths  assumption  that  every  feature  uses  the  same  amount  of  processor  time  308  and 
 BellSouths  inclusion  of  both  central  and  distributed  processor  costs  in  the  5ESS  switch,  which  AT&  T  contends  results  in  double-  charging  for  features  that  do  not  use  the  central  processors.  309 
 AT&  T  further  claims  that  BellSouth  double-  counts  the  hardware  investment  related  to  providing  features,  incorrectly  uses  averages  in  developing  hardware  unit  investments,  and  does  not 


 304  BellSouth  Ruscilli/  Cox  Reply  Aff.  at  para.  33;  AT&  T  Comments  at  36-  37  (arguing  that  BellSouths  take-rate 
 is  too  high  and  that  as  a  result  of  BellSouths  modified  recovery  of  features,  all  customers,  instead  of  only  those  who  order  features,  pay  an  inflated  feature  charge  in  the  port  rate);  see  also  AT&  T  Reply  App.,  Tab  C,  Reply 


 Declaration  of  Catherine  E.  Pitts  (AT&  T  Pitts  Reply  Decl.)  at  paras.  2,  6  (asserting  that  North  Carolina  data  demonstrate  that  the  55%  factor  used  to  spread  the  cost  of  the  feature  port  additive  across  all  subscriber  lines  is 
 unsupported  by  BellSouth  information  on  the  take  rate  for  features);  AT&  T  Pitts  Supp.  Reply  Decl.  at  para.  9. 
 305  AT&  T  Pitts  Decl.  at  para.  20;  AT&  T  Comments  at  35-  37. 


 306  AT&  T  also  argues  that  BellSouths  feature  port  additive  rate  is  not  TELRIC-  compliant  because  the  same  rate 
 applied  whether  a  customer  incurs  the  costs  associated  with  one  feature  or  a  dozen  features.  AT&  T  Comments  at  35.  A  similar  claim  was  raised  before  the  Alabama  and  South  Carolina  Commissions.  AT&  T  Reply  at  Attachs.  13- 


 16.  AT&  T  also  criticizes  BellSouths  consideration  of  feature-  related  hardware  costs  and  the  assumption  that  different  switches  process  feature  calls  in  the  same  way.  AT&  T  Pitts  Decl.  at  paras.  21-  25. 


 307  AT&  T  Pitts  Decl.  at  paras.  19-  20;  AT&  T  Pitts  Reply  Decl.  at  paras.  2,  3-  4  (using  North  Carolina  data  to 
 support  its  argument  that  the  56  features  underlying  BellSouths  cost  methodology  are  not  representative  of  features  purchased  by  subscribers).  The  result  of  BellSouths  inappropriate  averaging  combined  with  usage  data  for  [a] 


 large  number  of  features  that  are  not  purchased  by  subscribers  produces  costs  that  are  inaccurate  and  are  not  based  on  cost  causation  principles.  Id.  at  para.  4;  see  also  AT&  T  August  23  Pricing  and  Growth  Tariff  Ex  Parte  Letter  at 
 3;  AT&  T  Pitts  Supp.  Reply  Decl.  at  paras.  3-  4,  6-  7. 
 308  AT&  T  Pitts  Decl.  at  para.  11  n.  13;  AT&  T  Pitts  Reply  Decl.  at  para.  5.  Even  if  it  were  correct  to  assign 
 getting  started  costs  and  EPHC  [Equivalent  POTS  Half  Call]  costs  to  features,  which  it  is  not,  such  an  assignment  should  not  assume  that  every  feature  uses  the  same  number  of  milliseconds  as  a  basic  call,  as  each  feature  is 


 different,  and  there  is  no  relationship  between  a  feature  and  the  number  of  milliseconds  for  a  basic  call.  Id. 
 309  AT&  T  Pitts  Decl.  at  para.  21. 
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 substantiate  hardware  component  costs.  310  In  addition,  AT&  T  contends  that  the  [hardware]  capacities  assume  some  level  of  average  utilization  that  has  not  been  identified  or  explained.  311 
 97.  AT&  T  did  not  raise  these  specific  challenges  to  BellSouths  feature  cost  methodology  before  any  of  the  state  commissions,  and  it  has  not  subsequently  asked  them  to 
 address  these  issues.  312  As  we  have  previously  stated,  the  Commission  does  not  have  the  time  or  the  resources  during  our  90-  day  statutory  review  period  for  section  271  applications  to  resolve 
 complex  technical  disputes  about  cost  model  assumptions.  313  That  is  why  our  decision-  making  process  gives  substantial  weight  to  evidence  that  is  submitted  by  the  state.  314  In  this  case, 
 however,  there  is  no  state  record  for  us  to  review  on  the  issues  that  AT&  T  raises,  and  we  do  not  have  the  benefit  of  any  state  commission  findings  or  evaluations  to  assist  us.  We  are  left  with 
 many  fact-  intensive,  complex  questions  related  to  BellSouths  new  cost  model  and  the  numerous  assumptions  and  inputs  that  it  developed,  such  as  whether  it  was  appropriate  for  BellSouth  to 
 develop  feature  costs  based  on  the  56  features  it  contends  are  representative,  whether  they  are  indeed  representative,  whether  BellSouth  reasonably  relied  on  demand  data  from  its  retail 
 Complete  Choice  plan  to  derive  the  number  of  features  per  average  user,  and  so  forth.  We  need  not,  however,  resolve  these  complex  issues  regarding  feature  cost  modeling  because  BellSouths 
 non-  loop  rates  in  Alabama,  Mississippi,  and  South  Carolina  pass  a  benchmark  comparison  to  BellSouths  non-  loop  rates  in  Louisiana.  We  conclude,  therefore,  that  the  non-  loop  rates  in  these 
 three  states,  which  include  the  cost  of  features,  fall  within  the  range  that  a  reasonable  application  of  TELRIC  principles  would  produce. 


 98.  Benchmark  Analysis.  States  have  considerable  flexibility  in  setting  UNE  rates,  and  certain  flaws  in  a  cost  study,  by  themselves,  may  not  result  in  rates  that  are  outside  the 
 reasonable  range  that  correct  application  of  TELRIC  principles  would  produce.  315  The 
 310  Id.  at  para.  22.  AT&  T  also  takes  issue  with  BellSouths  attempt  to  show  that  its  feature  rates  are  reasonable 
 based  on  a  comparison  with  Verizons  rates  in  New  York.  AT&  T  Pitts  Supp.  Reply  Decl.  at  paras.  10-  11  (responding  to  BellSouth  Caldwell  Reply  Aff.  at  paras.  122-  26).  AT&  T  asserts  that  direct  comparisons  are 


 inappropriate  because  BellSouth  and  Verizon  used  different  cost  studies  and  assumptions.  AT&  T  further  contends  that  the  comparison,  when  correctly  adjusted,  shows  that  BellSouths  hardware-  related  features  cost  is  significantly 
 overstated  once  feature  penetration  rates  are  appropriately  taken  into  account.  AT&  T  August  23  Pricing  and  Growth  Tariff  Ex  Parte  Letter  at  4. 


 311  AT&  T  Pitts  Decl.  at  para.  22. 
 312  AT&  T  asserts  that  feature-  related  issues  were  raised  before  the  Alabama  and  South  Carolina  Commissions, 
 but  the  documentation  it  provides  shows  different  arguments  were  presented  there  by  different  parties.  Specifically,  SECCA  argued  that  the  Alabama  Commission  should  reject  BellSouths  features  rate  because  there  is  no 


 incremental  cost  in  providing  features,  or,  alternatively,  require  BellSouth  to  unbundle  features  and  price  each  separately.  The  same  arguments  were  made  by  NewSouth,  NuVox,  Broadslate  Networks,  ITC^  DeltaCom,  KMC 
 Telecom,  and  WorldCom  before  the  South  Carolina  Commission.  AT&  T  Reply  at  Attachs.  13-  16. 
 313  SWBT  Texas  Order,  15  FCC  Rcd  at  18375,  para.  51. 


 314  Id. 
 315  Verizon  Rhode  Island  Order,  17  FCC  Rcd  at  3319-  20,  para.  37. 
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 Commission  has  addressed  past  claims  that  a  state  commission  has  not  applied  TELRIC  principles  or  has  done  so  improperly  by  looking  to  rates  in  other  section  271-  approved  states  to 
 see  if  the  applicant  states  rates  nonetheless  fall  within  the  range  that  a  reasonable  TELRIC-based  rate  proceeding  would  produce.  316  To  determine  whether  a  comparison  is  reasonable,  the 
 Commission  will  consider  whether  the  two  states  have  a  common  BOC;  whether  the  two  states  have  geographic  similarities;  whether  the  two  states  have  similar,  although  not  necessarily 
 identical,  rate  structures  for  comparison  purposes;  and  whether  the  Commission  has  already  found  the  rates  in  the  comparison  state  to  be  TELRIC-  compliant  or  an  appropriate  benchmark.  317 
 Applying  this  standard  to  BellSouths  rates  in  Alabama,  Mississippi,  and  South  Carolina,  we  find  that  Louisiana  is  a  permissible  state  for  UNE  rate  comparison  purposes.  318 


 99.  Having  determined  that  the  Louisiana  rates  are  appropriate  rates  for  the  benchmark  comparison,  we  compare  BellSouths  Alabama,  Mississippi,  and  South  Carolina  non-loop 
 rates  to  the  Louisiana  non-  loop  rates  using  our  benchmark  analysis,  using  state-  specific  data  for  weighting  rates.  319  We  find  that  BellSouths  non-  loop  rates  in  these  states  satisfy  our 
 benchmark  analysis  and  the  requirements  of  checklist  item  2.  Specifically,  BellSouths  non-  loop  rates  in  Alabama,  Mississippi,  and  South  Carolina  are  lower  than  BellSouths  non-  loop  rates  in 
 Louisiana  by  32,  25,  and  20  percent,  respectively.  Comparing  the  costs,  we  find  that  the  Alabama  and  Mississippi  non-  loop  costs  are  higher  than  the  Louisiana  non-  loop  costs  by  8  and 
 28  percent,  respectively;  the  non-  loop  cost  in  South  Carolina  is  9  percent  lower  than  in 


 316  See,  e.  g.,  Verizon  New  Jersey  Order,  17  FCC  Rcd  at  12295-  96,  para.  49;  SWBT  Kansas/  Oklahoma  Order,  16 
 FCC  Rcd  at  6276,  para.  82. 
 317  See  Verizon  New  Jersey  Order,  17  FCC  Rcd  at  12295-  96,  para.  49;  Verizon  Rhode  Island  Order,  17  FCC  Rcd 
 at  3320,  para.  38;  Joint  Application  by  SBC  Communications  Inc.,  Southwestern  Bell  Telephone  Company,  and  Southwestern  Bell  Communications  Services,  Inc.,  d/  b/  a  Southwestern  Bell  Long  Distance  Pursuant  to  Section  271 


 of  the  Telecommunications  Act  of  1996  to  Provide  In-  Region,  InterLATA  Services  in  Arkansas  and  Missouri,  16  FCC  Rcd  20719,  20746,  para.  56  (2001)  (SWBT  Arkansas/  Missouri  Order);  Verizon  Pennsylvania  Order,  16  FCC 
 Rcd  at  17457,  para.  63.  In  the  Verizon  Pennsylvania  Order,  we  found  that  several  of  the  criteria  should  be  treated  as  indicia  of  the  reasonableness  of  the  comparison.  Verizon  Pennsylvania  Order,  16  FCC  Rcd  at  17457,  para.  64; 
 see  also  Verizon  Massachusetts  Order,  16  FCC  Rcd  at  9002,  para.  28;  SWBT  Kansas/  Oklahoma  Order,  16  FCC  Rcd  at  6276,  para.  82. 


 318  Louisiana  is  in  the  same  geographic  region,  is  served  by  the  same  BOC,  has  a  similar  rate  structure,  and  the 
 Commission  has  already  found  Louisianas  rates  to  be  TELRIC-  compliant  on  their  own  merits.  See  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9033-  34,  paras.  23-  24.  No  commenter  disputes  that  the  Louisiana  rates 


 are  an  appropriate  benchmark  in  determining  TELRIC-  compliance. 
 319  As  in  past  applications,  our  benchmark  analysis  combines  per-  minute  switching  rates  with  other  non-  loop 
 rates,  such  as  port,  signaling,  and  transport  rates,  because  competing  LECs  most  often  purchase  these  together  rather  than  separately  and  because  state  commissions  often  differ  in  determining  how  to  recover  certain  costs.  Verizon 


 Rhode  Island  Order,  17  FCC  Rcd  at  3320-  21,  para.  40;  Verizon  New  Jersey  Order,  17  FCC  Rcd  at  12297-  98,  para.  53  (explaining  it  is  reasonable  to  use  state-  specific  assumptions).  No  party  in  this  proceeding  has  challenged  the 
 appropriateness  of  this  analysis.  The  cost  for  features  is  considered  in  the  port  rate.  BellSouth  provided  state-specific  usage  data  in  response  to  our  request.  Letter  from  Glenn  T.  Reynolds,  Vice  President    Federal  Regulatory, 
 BellSouth,  to  Marlene  H.  Dortch,  Secretary,  Federal  Communications  Commission,  WC  Docket  No.  02-  150  (filed  Aug.  8,  2002)  (BellSouth  August  8  Ex  Parte  Letter);  BellSouth  August  9  Ex  Parte  Letter. 
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 Louisiana.  Because  the  percentage  differences  between  BellSouths  Louisiana  non-  loop  rates  and  BellSouths  non-  loop  rates  in  Alabama,  Mississippi,  and  South  Carolina  do  not  exceed  the 
 percentage  differences  between  BellSouths  non-  loop  costs  in  Louisiana  and  BellSouths  costs  in  the  three  other  states,  we  conclude  that  BellSouths  recurring  non-  loop  rates  in  Alabama, 
 Mississippi,  and  South  Carolina  satisfy  our  benchmark  analysis.  320  This  analysis  demonstrates  that,  despite  concerns  raised  by  AT&  T  related  to  BellSouths  feature  cost  methodology  in  these 
 three  states,  BellSouths  non-  loop  rates,  including  the  costs  for  features  reflected  in  the  port  charge,  fall  within  a  range  of  rates  that  a  reasonable  application  of  TELRIC  principles  would 
 produce.  321 
 (iii)  Age  of  Rates 
 100.  AT&  T  contends  that  BellSouths  UNE  rates  for  loops  and  switching  in  North  Carolina  are  not  TELRIC-  compliant  because  they  are  based  on  outdated  cost  data  that  do  not 


 take  into  account  reduced  costs  from  current  technologies  and  growth  in  demand.  322  We  disagree.  As  background  for  our  analysis,  we  have  consistently  recognized  that  rates  may  well 
 evolve  over  time  to  reflect,  among  other  things,  new  information  and  technology.  323  The  U.  S.  Court  of  Appeals  for  the  D.  C.  Circuit  agreed  that  section  271  applications  might  never  be 
 approved  if  rates  had  to  be  updated  constantly  to  reflect  new  information.  324 
 101.  AT&  T  argues  here  that  BellSouths  out-  of-  date  cost  studies  that  underlie  its  UNE  rates  do  not  reflect  efficiencies  and  cost  reductions  in  loops  and  switching  equipment.  325 


 We  considered  this  argument  in  the  Verizon  Vermont  Order,  where  we  noted  [  m]  uch  of  the 


 320  Although  we  do  not  rely  on  a  benchmark  comparison  of  Kentucky  and  North  Carolina  non-  loop  rates,  we  note 
 that  such  comparison  reveals  that  Kentucky  non-  loop  rates  pass  a  benchmark  comparison  to  Louisiana  non-  loop  rates  (Kentuckys  non-  loop  costs  are  14%  higher;  its  non-  loop  rates  are  40%  lower),  and  North  Carolina  non-  loop 


 rates  come  within  1%  of  satisfying  the  benchmark  (North  Carolinas  non-  loop  costs  are  10%  lower  than  Louisianas;  its  non-  loop  rates  are  9.6%  lower). 


 321  Sprint  v.  FCC,  274  F.  3d  at  561  (upholding  the  use  of  our  benchmark  analysis). 
 322  AT&  T  Comments  at  39;  AT&  T  Comments  App.,  Tab  D,  Declaration  of  Michael  Lieberman  (AT&  T 
 Lieberman  Decl.)  at  para.  6  (  Because  provision  of  local  telecommunications  services  reflects  economies  of  scale,  scope  and  density,  the  substantial  growth  in  demand  that  has  occurred  since  1996  should  yield  reductions  in  loop 


 and  switch  UNE  costs.). 
 323  Verizon  Vermont  Order,  17  FCC  Rcd  at  7637,  para.  23;  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  4085- 
 86,  para.  247;  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9066,  para.  96.  Indeed,  the  Supreme  Court  has  recognized  the  regulatory  lag  that  accompanies  price  adjustments  as  one  of  the  pragmatic  features  of  the  TELRIC 


 plan.  Verizon  v.  FCC,  122  S.  Ct.  at  1679. 
 324  AT&  T  v.  FCC,  220  F.  3d  at  617  ([  W]  e  suspect  that  rates  may  often  need  adjustment  to  reflect  newly 
 discovered  information  .  .  .  .  If  new  information  automatically  required  rejection  of  section  271  applications,  we  cannot  imagine  how  such  applications  could  ever  be  approved  in  this  context  of  rapid  regulatory  and  technological 


 change.). 
 325  AT&  T  Comments  at  40. 
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 underpinning  of  complaints  by  AT&  T  and  WorldCom  regarding  Verizons  switching  rates  is  that  the  data  underlying  the  inputs  into  Verizons  switching  cost  studies  is  old.  326  We  noted  there 
 that  neither  AT&  T  nor  WorldCom  had  asked  the  Vermont  Commission  to  require  Verizon  to  update  the  data  and  inputs  for  its  switching  cost  studies  when  this  newer  information  had,  in  fact, 
 resulted  in  lower  rates  in  more  recent  proceedings.  327  In  this  case,  parties  complained  before  the  North  Carolina  Commission  that  UNE  rates  were  several  years  old,  and  the  state  commission 
 ordered  a  new  proceeding  to  allow  rates  to  better  reflect  current  conditions.  328  Hearings  are  scheduled  to  begin  in  November  2002. 


 102.  We  recognize,  as  AT&  T  asserts  here,  that  there  may  be  factors  that  cause  BellSouths  costs  to  decline  over  time.  329  At  the  same  time,  there  may  be  other  factors  that  cause 
 costs  to  increase  over  time.  Indeed,  the  D.  C.  Circuit  has  recognized  that  modifying  one  factor  in  a  cost  model  may  well  cause  modification  to  other  factors.  330  This  is  precisely  why  state 
 commissions  hold  hearings  to  update  rates  based  on  consideration  of  all  new  information  and  relevant  data  brought  before  them.  North  Carolina  is  in  the  process  of  revisiting  UNE  rates.  The 
 North  Carolina  Commission  has  demonstrated  its  commitment  to  set  UNE  prices  based  on  TELRIC  principles.  331  It  also  recognizes  that  its  work  is  far  from  complete.  332  AT&  T  may 
 appropriately  raise  its  arguments  regarding  more  recent  data  and  cost  studies  in  these  current  proceedings.  As  we  concluded  previously,  however,  the  mere  pendency  of  a  state  proceeding 
 where  rates  are  reviewed  in  light  of  new  information  does  not  require  the  rejection  of  a  section  271  application.  333 


 326  Verizon  Vermont  Order,  17  FCC  Rcd  at  7636,  para.  21. 
 327  Id.  at  7637,  para.  22. 
 328  Application  of  BellSouth  Telecommuncations,  Inc.  to  Provide  In-  Region  InterLATA  Service  Pursuant  to 
 Section  271  of  the  Telecommunications  Act  of  1996,  Proceeding  to  Determine  Permanent  Pricing  for  Unbundled  Network  Elements,  North  Carolina  Commission  Docket  Nos.  P-  55,  Sub  1022;  P-  100,  Sub  133d,  Order  Ruling  on 


 WorldCom  Petition  at  7  (March  20,  2002).  The  Public  Staff  noted  that  BellSouth  was  willing  to  re-  file  cost  support  data  based  on  updated  models  and  inputs  if  ordered  to  do  so.  Id.  at  5.  Pursuant  to  the  North  Carolina  Commissions 
 order,  AT&  T,  BellSouth,  and  WorldCom  on  April  15,  2002,  filed  a  joint  motion  to  establish  a  hearing  schedule  for  the  new  UNE  proceeding.  Proceeding  to  Determine  Permanent  Pricing  for  Unbundled  Network  Elements,  North 
 Carolina  Commission  Docket  No.  P-  100,  Sub  133d,  Order  Establishing  Schedule  for  New  UNE  Proceeding  (April  19,  2002). 


 329  AT&  T  Lieberman  Decl.  at  paras.  6-  9. 
 330  AT&  T  v.  FCC,  220  F.  3d  at  617. 
 331  See  section  IV.  B.  1.  a,  supra. 
 332  See  generally  North  Carolina  Commission  Comments. 
 333  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9066-  67,  para.  97;  Verizon  Rhode  Island  Order,  17  FCC 
 Rcd  at  3317,  para.  31  (citing  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  4085-  86,  para.  247,  affd,  AT&  T  Corp.  v.  FCC,  220  F.  3d  at  617). 
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 (iv)  Deaveraging 
 103.  WorldCom  contends  that  UNE  rates  in  South  Carolina  are  not  properly  deaveraged  and  therefore  violate  the  Commissions  rules  and  TELRIC  principles.  334  South 


 Carolina  allegedly  deaveraged  UNE  rates  according  to  retail  rate  zones,  not  geographic  cost  differences.  That  is,  end  users  in  South  Carolina  are  grouped  based  on  similarities  in  what  they 
 pay  in  local  retail  rates,  rather  than  what  it  costs  to  provide  service  to  them.  335  Geographic  cost  differences  between  wire  centers,  according  to  WorldCom,  do  not  determine  the  zone  in  which 
 wire  centers  are  placed.  336  As  a  result,  some  very  high  cost  wire  centers  are  included  in  zone  one,  and  some  very  low  cost  wire  centers  are  included  in  zones  two  and  three.  337  The  effect  of  this 
 error,  according  to  WorldCom,  is  that  the  gross  margin  in  zone  one,  which  should  be  the  most  profitable,  is  only  $2.76.  338  We  reject  WorldComs  claims  and  find  that  UNE  deaveraging  in 
 South  Carolina  complies  with  the  Local  Competition  Order  and  the  Commissions  TELRIC  rules. 


 104.  The  Commissions  regulations  provide  that  [  s]  tate  commissions  shall  establish  different  rates  for  elements  in  at  least  three  defined  geographic  areas  within  the  state  to  reflect 
 geographic  cost  differences.  339  The  regulations  also  provide  that,  [  t]  o  establish  geographically  deaveraged  rates,  state  commissions  may  use  existing  density-  related  zone  pricing  plans  .  .  .  or 
 other  such  cost-  related  zone  plans  established  pursuant  to  state  law.  340  In  the  Local  Competition  Order,  the  Commission  concluded  that  the  pricing  standard  for  interconnection 
 and  unbundled  elements  prohibits  deaveraging  that  is  not  cost  based.  341  The  requirement  is  important  because,  as  we  noted  in  the  CALLS  SLC  Cap  Order,  cost-  based  deaveraging 
 promotes  competition  and  efficiency  by  allowing  a  LEC  to  compete  for  subscribers  when  it  is  the  lowest  cost  service  provider  and  by  removing  support  flows  to  the  LECs  higher-  cost 
 customers.  342  By  contrast,  non-  cost-  based  deaveraging  may  distort  the  operation  of  the 


 334  WorldCom  Comments  at  13. 
 335  Id. 
 336  Id. 
 337  Id. 
 338  Id.;  see  also  WorldCom  Frentrup  Decl.  at  paras.  30-  31. 
 339  47  C.  F.  R.    51.507(  f). 
 340  47  C.  F.  R.    51.507(  f)(  1)  (emphasis  added). 
 341  Local  Competition  Order,  11  FCC  Rcd  at  15883,  para.  766. 
 342  Cost  Review  Proceeding  for  Residential  and  Single-  Line  Business  Subscriber  Line  Charge  (SLC)  Caps,  Access 
 Charge  Reform,  Price  Cap  Performance  Review  for  Local  Exchange  Carriers,  CC  Docket  Nos.  96-  262,  94-  1,  Order,  17  FCC  Rcd  10868,  10876-  77,  para.  18  (rel.  June  5,  2002)  (CALLS  SLC  Cap  Order),  pet.  for  review  filed, 


 No.  02-  1261  (D.  C.  Cir.  Aug.  16,  2002). 
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 markets  in  high-  cost  areas  because  LECs  must  offer  services  in  those  areas  at  prices  substantially  lower  than  their  costs  of  providing  service.  343 
 105.  In  its  UNE  Rate  Order,  the  South  Carolina  Commission  stated  that  BellSouth  proposed  deaveraging  loop-  related  UNEs  into  three  geographic  areas  utilizing  existing  BellSouth 
 rate  groups  based  upon  BellSouths  General  Subscriber  Service  Tariff.  344  BellSouth  calculated  average  monthly  costs  within  each  zone  by  weighting  the  wire-  center  level  costs  produced  by  the 
 BSTLM  by  wire  center  line  counts.  345  Under  BellSouths  approach,  according  to  the  South  Carolina  Commission,  customers  who  are  located  in  the  same  geographic  area  and  who  have 
 similar  local  calling  areas  would  be  in  the  same  deaveraged  zone  for  UNE  pricing.  346  Using  existing  rate  groups  as  the  basis  for  establishing  the  three  cost-  related  rate  zones  is  said  to  result 
 in  consistent  prices  for  customers  within  the  same  geographic  markets.  347  The  South  Carolina  Commission  noted,  however,  that  unlike  the  prices  for  UNEs,  BellSouths  rates  for  basic 
 service  were  established  in  an  inverse  relationship  to  cost  in  order  to  ensure  affordable  local  service  for  all  urban  and  rural  customers.  348  As  a  result,  the  South  Carolina  Commission 
 concluded,  UNE  deaveraging  will  result  in  rates  that  vary  in  the  opposite  direction  of  prices  for  BellSouths  retail  services.  349 


 106.  On  the  record  before  us,  we  conclude  that  the  South  Carolina  Commission  deaveraged  UNE  prices  according  to  a  valid  cost-  related  zone  plan  established  pursuant  to  state 
 law.  350  The  only  evidence  WorldCom  submits  to  the  contrary  is  the  general  allegation  that  some  very  high  cost  wire  centers  are  included  in  zone  1,  and  some  very  low  cost  wire  centers 
 are  included  in  zones  2  and  3.  351  This  allegation,  even  if  true,  is  not  persuasive:  the  mere  inclusion  of  a  few  wire  centers  in  zones  with  different  overall  cost  characteristics  does  not  show 
 that  the  overall  zone  plan  is  not  cost-  based.  Notably,  WorldCom  does  not  refute  BellSouths  evidence  that,  because  BellSouth  originally  established  retail  rate  zones  in  South  Carolina 
 according  to  underlying  wire  center  costs,  there  is  a  direct  correlation  between  South  Carolina 
 343  Id. 
 344  South  Carolina  Commission  UNE  Rate  Order  at  7. 
 345  Id. 
 346  Id. 
 347  Id.  According  to  the  South  Carolina  Commission,  defining  the  three  geographic  zones  by  rate  groups  also 
 provides  consistency  between  the  structure  of  BellSouths  retail  services,  resale,  and  UNE  prices.  Id.  The  need  for  such  consistency  should  be  obvious,  because  CLECs  use  UNEs  to  compete  with  services  offered  at  retail  by 


 BellSouth.  Id. 
 348  Id. 


 349  Id. 
 350  47  C.  F.  R.    51.507(  f)(  1). 
 351  WorldCom  Comments  at  13. 
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 retail  rate  zones  and  wire  center  costs.  352  BellSouths  evidence,  we  conclude,  demonstrates  that  the  South  Carolina  Commission  deaveraged  UNE  rates  according  to  a  cost-  related  zone  plan. 
 107.  In  addition,  there  is  evidence  in  the  record  that  adopting  a  UNE  deaveraging  methodology  in  South  Carolina  based  strictly  on  wire  center  costs  would  have  little  if  any  effect 
 on  the  resulting  UNE  rates.  We  note  that  the  Alabama  and  North  Carolina  Commissions  directed  BellSouth  to  deaverage  UNE  rates  strictly  according  to  a  wire  center  costs.  353  BellSouth 
 persuasively  demonstrates  that  applying  the  North  Carolina  UNE  deaveraging  methodology  to  South  Carolina  wire  center  costs  results  in  UNE  rates  that  are  reasonably  comparable  to  South 
 Carolinas  existing  UNE  rates.  354  According  to  BellSouths  analysis,  if  North  Carolinas  strict  wire  center  cost  deaveraging  method  were  used  in  South  Carolina,  UNE  loop  rates  in  South 
 Carolina  would  increase  in  zones  two  and  three  by  $1.74  and  $5.49,  respectively,  and  drop  in  zone  one  by  only  $0.18.  355  As  a  result,  we  find  that  there  is  a  direct  relationship  between  the 
 costs  of  wire  centers  in  South  Carolina  and  the  deaveraging  methodology  approved  by  the  South  Carolina  Commission,  which  is  based  on  retail  rate  zones.  For  these  reasons,  we  conclude  that 
 South  Carolinas  UNE  deaveraging  methodology  is  a  valid  state  cost-  related  zone  plan  as  required  by  47  C.  F.  R.    51.507(  f)(  1). 


 (v)  Daily  Usage  File  Rates 
 108.  Background.  Consistent  with  prior  section  271  orders,  a  BOC  must  demonstrate  that  it  provides  competing  carriers  with  complete,  accurate,  and  timely  reports  on  the  service 


 352  BellSouth  Application  Reply  App.,  Tab  F,  Reply  Affidavit  of  John  A.  Ruscilli  and  Cynthia  K.  Cox  (BellSouth 
 Ruscilli/  Cox  Reply  Aff.)  at  para.  28  (stating  that  the  deaveraging  methodology  applied  in  South  Carolina  utilized  the  wire  center  level  costs  for  the  wire  centers  that  were  included  in  each  zone  to  calculate  the  average  monthly  rate 


 for  each  zone).  BellSouth  demonstrates  that  UNE  zone  one  includes  retail  rate  groups  seven  and  six  (average  loop  costs  of  $14.75  and  $15.98,  respectively);  UNE  zone  two  includes  retail  rate  groups  five  and  four  (average  loop 
 costs  of  $21.45  and  $21.25,  respectively);  and  UNE  zone  three  includes  retail  rate  groups  three,  two,  and  one  (average  loop  costs  of  $24.97,  $27.40,  and  $33.80,  respectively).  See  id.  at  para.  27,  Table  1. 


 353  North  Carolina  Commission  Recommended  Order  Concerning  Geographic  Deaveraging  at  24,  42;  North 
 Carolina  Commission  Order  Finalizing  Deaveraged  UNE  Rates  at  3.  See  also  Alabama  Commission  UNE  Rate  Order  at  67-  68  (concluding  that  a  deaveraging  methodology  based  on  wire  center  costs  more  closely  meets  the 


 requirements  of  Rule  507(  f)  to  use  cost  related  zones  as  well  as  the  underlying  principals  [sic]  of  the  [19]  96  Act). 
 354  BellSouth  Ruscilli/  Cox  Reply  Aff.  at  para.  30  &  Tables  2-  3. 


 355  Id.  at  Table  3.  WorldCom  does  not  dispute  this  analysis  but  contends  that  use  of  the  Alabama  Commissions 
 deaveraging  approach  would  lower  UNE  loop  rates  in  zone  one  in  South  Carolina  by  $0.89.  WorldCom  Reply  Frentrup  Decl.  at  para.  19.  As  WorldCom  itself  concedes,  however,  such  an  approach  would  also  increase  UNE 


 loop  rates  in  zone  three  by  $4.03.  Id.  This  evidence  does  not  show  that  South  Carolinas  deaveraging  method  is  not  cost-  related  within  the  meaning  of  47  C.  F.  R.    51.507(  f)(  1).  In  addition,  state  commissions  have  considerable 
 discretion  in  setting  the  pricing  demarcations  between  UNE  rate  zones  (e.  g.,  whether  the  demarcation  between  zones  one  and  two  is  115%  or  150%  of  average  costs).  These  determinations  may  have  a  substantial  effect  on  UNE 
 rates,  whether  or  not  a  state  commission  adopts  a  wire-  center  cost  approach  to  deaveraging.  Thus,  that  the  use  of  the  Alabama  Commissions  approach  would  lower  UNE  rates  in  one  zone  but  raise  them  in  another  is  not 
 dispositive  here. 
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 usage  of  their  customers  in  substantially  the  same  time  and  manner  that  a  BOC  provides  such  information  to  itself.  356  BellSouth  offers  three  types  of  Daily  Usage  Files  (DUF)  in  Alabama, 
 Kentucky,  North  Carolina,  South  Carolina,  and  Mississippi:  the  Access  Daily  Usage  File  (ADUF);  357  the  Optional  Daily  Usage  File  (ODUF);  358  and  the  Enhanced  Optional  Daily  Usage 
 File  (EODUF).  359 
 109.  Challenges  to  the  DUF  Rate.  AT&  T  and  WorldCom  challenge  the  conclusions  of  the  Alabama,  Kentucky,  North  Carolina,  South  Carolina,  and  Mississippi  commissions  that 


 BellSouths  DUF  rates  comply  with  basic  TELRIC  principles.  360  Birch  also  raises  a  DUF-  related  issue  in  its  reply.  As  a  preliminary  matter,  we  dismiss  Birchs  argument  that  the  Commission 
 should  require  BellSouth  to  offer  Birch  SGAT  DUF  rates  in  its  private  interconnection  agreement  with  BellSouth.  361  As  Birch  concedes,  Commission  rules  do  not  require  BellSouth  to 
 make  SGAT  rates  available  in  an  interconnection  agreement.  362  Birch  is  not  alleging  any  error  with  respect  to  the  SGAT  DUF  rates.  Indeed,  Birch  has  not  alleged  any  specific  section  271 
 violation.  Accordingly,  we  reject  Birchs  arguments. 
 110.  We  also  dismiss  WorldComs  attack  on  DUF  rates  in  Alabama  and  South  Carolina  because  WorldCom  challenges  rates  that  are  not  currently  charged  by  BellSouth  in 


 those  states.  363  We  similarly  dismiss  AT&  Ts  attack  on  DUF  rates  in  North  Carolina  because 


 356  See,  e.  g.,  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9061-  62,  para.  85. 
 357  ADUF  provides  the  competitive  LEC  with  records  for  billing  interstate  and  intrastate  access  charges,  whether 
 the  call  was  handled  by  BellSouth  or  an  IXC.  ADUF  also  provides  records  for  billing  reciprocal  compensation  charges  to  other  local  exchange  carriers  and  IXCs  for  calls  originating  from  and  terminating  to  unbundled  switch 


 ports.  ADUF  includes  records  for  both  originating  and  terminating  traffic.  See  BellSouth  Application  App.  A,  Vol.  5,  Tab  H,  Affidavit  of  David  P.  Scollard  (BellSouth  Scollard  Aff.)  at  paras.  11-  12;  BellSouth  Georgia/  Louisiana 
 Order,  17  FCC  Rcd  at  9062,  para.  85  n.  292. 
 358  ODUF  contains  information  on  billable  transactions  for  resold  lines,  interim  number  portability  accounts,  and 
 unbundled  switch  ports.  For  end  users  who  are  served  by  resold  lines,  interim  number  portability,  or  unbundled  switch  ports  (including  the  UNE-  platform),  a  competitive  LEC  can  use  ODUF  to  bill  for  usage  events  associated 


 with  calls  placed  by  those  end  users  (e.  g.,  toll  calls,  operator  assistance).  BellSouth  Scollard  Aff.  at  para.  11;  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9062,  para.  85  n.  292. 


 359  EODUF  is  an  enhancement  to  ODUF  and  includes  usage  records  for  local  calls  originating  from  a  resellers 
 flat-  rated  lines  (BellSouths  retail  flat-  rated  local  service  offering  purchased  for  resale).  BellSouth  Scollard  Aff.  at  para.  11;  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9062,  para.  85  n.  292. 


 360  AT&  T  Comments  at  30-  34;  WorldCom  Comments  at  12-  13. 
 361  Birch  Reply  at  2-  4. 
 362  Id.  at  4. 
 363  See  Letter  from  Keith  L.  Seat,  Senior  Counsel    Federal  Advocacy,  WorldCom,  to  Marlene  H.  Dortch, 
 Secretary,  Federal  Communications  Commission,  WC  Docket  No.  02-  150  (filed  Aug.  1,  2002)  (WorldCom  August  1  Ex  Parte  Letter)  (acknowledging  that  the  rates  cited  in  the  WorldCom  Comments  are  not  the  current  BellSouth 


 SGAT  rates  in  South  Carolina  and  Alabama). 
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 this  challenge  is  based  on  rates  that  are  no  longer  in  effect.  364  We  find  that  this  modification  to  BellSouths  application  after  it  was  filed  did  not  substantially  burden  commenters  as  it  was  made 
 before  reply  comments  were  filed.  365  Furthermore,  no  party  has  separately  challenged  the  current  North  Carolina  DUF  rates.  We  address  below  AT&  Ts  arguments  regarding  the  cost  study 
 underlying  all  of  BellSouths  DUF  rates  and  WorldComs  argument  that  BellSouth  already  recovers  DUF-  related  costs  through  its  shared  and  common  cost  factors. 


 111.  AT&  T  attacks  the  cost  study  underlying  the  current  DUF  rates  in  Alabama,  Kentucky,  North  Carolina,  South  Carolina,  and  Mississippi  as  not  TELRIC-  compliant.  366  This 
 same  cost  study  was  also  used  as  the  basis  for  the  DUF  rates  in  Georgia.  367  AT&  T  alleges  that  DUF  costs  are  inflated  due  to  the  following  TELRIC  errors  in  BellSouths  DUF  cost  study:  (1) 
 the  costs  of  certain  messages  are  disproportionately  allocated  only  to  competitive  LECs  when  they  should  also  be  shared  by  BellSouth;  368  (2)  BellSouth  significantly  understates  the  number  of 
 competitive  LEC  ADUF  and  ODUF  messages;  369  (3)  the  cost  study  uses  inconsistent  and  inappropriate  cost  recovery  periods;  370  (4)  BellSouth  uses  improper  accounting  in  classifying 
 certain  expenses;  371  and  (5)  the  cost  of  magnetic  tapes  is  improperly  charged  to  customers  that  use  only  electronic  feed.  372 


 364  See  AT&  T  Comments  at  31-  32.  BellSouth  filed  new  rates  in  North  Carolina  on  July  22,  2002,  that  are  in  line 
 with  the  DUF  rates  in  the  other  BellSouth  states.  See  Letter  from  Glenn  T.  Reynolds,  Vice  President    Federal  Regulatory,  BellSouth,  to  Marlene  H.  Dortch,  Secretary,  Federal  Communications  Commission,  WC  Docket  No. 


 02-  150  (filed  July  24,  2002)  (BellSouth  July  24  Ex  Parte  Letter);  Letter  from  Glenn  T.  Reynolds,  Vice  President    Federal  Regulatory,  BellSouth  Corporation,  to  Marlene  Dortch,  Secretary,  Federal  Communications  Commission, 
 WC  Docket  No.  02-  150  (filed  Aug.  5,  2002)  (BellSouth  August  5  Ex  Parte  Letter).  These  rates  were  accepted  by  the  North  Carolina  Commission  on  August  5,  2002.  See  BellSouth  August  8  Ex  Parte  Letter  (attaching  order  of  the 
 North  Carolina  Commission  accepting  the  revised  rates). 
 365  See  SWBT  Arkansas/  Missouri  Order,  16  FCC  Rcd  at  20764,  para.  93  (stating  that  a  collocation  rate 
 modification  to  SWBT  271  application  did  not  substantially  burden  commenters  as  it  was  made  before  comments  were  filed);  see  also  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9064,  para.  89  (dismissing  criticism  of 


 Louisiana  DUF  rates  because  the  only  challenge  was  based  on  rates  that  existed  before  the  most  current  rates  were  filed  and  the  old  rates  are  no  longer  relevant). 


 366  AT&  T  Comments  at  30-  34. 
 367  BellSouth  Reply  at  43;  BellSouth  Caldwell  Reply  Aff.  at  para.  41. 
 368  AT&  T  Comments  at  32;  AT&  T  Comments  App.,  Tab  F,  Declaration  of  Steven  E.  Turner  (AT&  T  Turner 
 Decl.)  at  paras.  10,  26-  30. 
 369  Id.  at  paras.  15,  39-  48. 


 370  Id.  at  paras.  11,  31-  32. 
 371  Id.  at  paras.  13,  35-  36. 
 372  Id.  at  paras.  14,  37-  38.  AT&  T  originally  also  argued  that  the  cost  study  contains  mathematical  errors  related 
 to  investments  but  has  since  withdrawn  that  argument.  See  id.  at  paras.  12,  33-  34;  AT&  T  Reply  Comments  App.,  Tab  D,  Reply  Declaration  of  Steven  E.  Turner  (AT&  T  Turner  Reply  Decl.)  at  para.  1  n.  1. 
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 112.  We  note  at  the  outset  that  no  commenter  made  these  arguments  during  the  state  proceedings  when  DUF  rates  were  set.  373  Although  we  do  not  require  parties  to  raise  all  pricing 
 issues  at  the  state  level  before  raising  them  in  a  section  271  proceeding,  it  is  generally  impractical  for  us  to  make  the  fact-  specific  findings  AT&  T  requests  concerning  the  cost  study 
 underlying  the  DUF  rates.  374  In  any  event,  AT&  T  has  failed  to  demonstrate  that  any  of  the  state  commissions  committed  clear  error.  We  discuss  each  of  AT&  Ts  arguments  in  turn  below. 


 113.  AT&  T  first  argues  that  BellSouth  fails  to  include  the  appropriate  number  of  messages  in  calculating  DUF  rates.  375  AT&  T  also  argues  that  BellSouth  disproportionately 
 allocates  a  high  number  of  labor  hours  to  competitive  LEC  messages,  and  also  allocates  certain  DUF  processing  costs  solely  to  competitive  LEC  messages  that  should  be  allocated  to  all 
 messages,  including  those  of  BellSouth.  376  AT&  T  contends  that,  consequently,  BellSouths  DUF  study  fails  to  account  for  the  total  demand  for  DUF,  causing  competitive  LECs  to  pay  inflated 
 DUF  costs.  377  BellSouth  disputes  this  argument,  asserting  that  its  cost  study  accurately  reflects  the  appropriate  mix  of  message  types  based  on  the  particular  application  or  job.  378  BellSouth 
 states  that,  for  each  job,  it  first  calculates  the  total  cost  of  the  job  and  then  divides  that  cost  by  the  total  demand.  379  It  explains  that,  although  BellSouth  messages  are  not  labeled  as  DUF  in 
 the  cost  study,  the  cost  study  nonetheless  incorporates  BellSouth  demand  by  attributing  certain  processing  jobs  to  both  BellSouth  and  competitive  LEC  messages,  while  attributing  others  only 
 to  competitive  LEC  messages.  380  BellSouth  further  states  that  the  cost  of  a  DUF  job  in  terms  of  both  labor  and  computer  resources  is  spread  over  the  number  of  messages  processed  by  that 


 373  AT&  T  claims  that  it  did  not  have  an  opportunity  to  challenge  BellSouths  DUF  rates  in  Alabama,  Mississippi, 
 North  Carolina,  and  South  Carolina  prior  to  this  section  271  proceeding  because  the  DUF  rates  proposed  by  BellSouth  in  those  states  are  based  on  SGAT  filings  made  by  BellSouth  either  after  the  conclusion  of  state  rate 


 proceedings  or  in  the  weeks  prior  to  its  Section  271  application.  AT&  T  Reply  at  28  n.  28;  see  also  AT&  T  August  23  Pricing  and  Growth  Tariff  Ex  Parte  Letter  at  4-  5.  We  reject  this  assertion.  AT&  T  challenges  BellSouths  DUF 
 cost  study  from  which  the  DUF  rates  are  derived.  The  cost  study  underlying  the  DUF  rates  at  issue  here  is  the  same  cost  study  that  was  before  each  of  the  state  commissions  in  each  state  UNE  rate  proceeding,  except  that  the  demand 
 figures  have  been  updated  to  reflect  increased  DUF  demand,  thus  resulting  in  lower  rates.  Accordingly,  the  challenges  AT&  T  raised  here  could  in  fact  have  been  raised  in  state  proceedings.  BellSouth  August  29  Ex  Parte 
 Letter. 
 374  See  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9045,  para.  49;  see  also  section  IV.  B.  1,  supra. 


 375  AT&  T  Turner  Decl.  at  paras.  10,  26-  30. 
 376  Id. 
 377  AT&  T  Comments  at  32;  AT&  T  Turner  Decl.  at  paras.  10,  26-  30. 
 378  BellSouth  Caldwell  Reply  Aff.  at  para.  43. 
 379  Id. 
 380  Id.  For  example,  BellSouth  states  that  Jobs  QA01  and  MC01A01  include  BellSouth  demand,  while  Jobs 
 MD03A  and  MD03B  do  not.  BellSouth  Caldwell  Reply  Aff.  at  para.  43  &  Exh.  DDC-  3.  AT&  T,  however,  does  not  provide  any  specific  information  regarding  which,  if  any,  of  the  particular  jobs  detailed  in  the  cost  study  it  believes 


 are  incorrectly  attributed  only  to  competitive  LEC  messages. 
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 job.  381  BellSouth  finally  states  that  the  amount  of  labor  in  terms  of  developmental  hours,  by  job,  was  developed  by  the  experts  who  would  be  programming  and  maintaining  the  computer 
 systems  associated  with  DUFs.  382  In  the  absence  of  specific  and  credible  evidence  to  the  contrary,  we  find  that  BellSouths  allocation  of  labor  costs  and  other  DUF  processing  costs  is 
 reasonable.  Moreover,  AT&  T  could  have  raised  its  concerns  with  the  five  state  commissions  but  never  did  so.  Thus  we  lack  the  benefit  of  the  states  analyses  of  these  contentions.  Based  on  this 
 record,  we  conclude  that  the  state  commissions  did  not  commit  clear  error  in  adopting  DUF  rates  incorporating  these  assumptions. 


 114.  In  a  related  argument,  AT&  T  contends  that  the  BellSouth  cost  study  contains  various  errors  related  to  DUF  processing  forecasts.  383  AT&  T  first  contends  that  BellSouth  has 
 understated  the  quantity  of  ODUF  messages  in  the  cost  study,  thereby  overstating  the  cost  per  message  that  competitive  LECs  must  bear.  384  AT&  T  notes,  for  example,  that  while  the  cost  study 
 reflects  two  different  numbers  for  ODUF  messages  processed  in  April  2001,  BellSouth  inappropriately  uses  the  lower  number  as  the  starting  point  for  the  three  year  forecast.  385 
 BellSouth  states  that  it  correctly  used  the  lower  numbers  because  the  higher  numbers  referenced  by  AT&  T  include  messages  generated  by  competitive  LECs  that  do  not  order  DUFs  and  are 
 therefore  not  billed  for  such  messages.  386  We  agree  that  it  would  be  inappropriate  to  use  the  higher  numbers  in  the  forecasts  at  issue  if  those  additional  messages  are  never  billed  to  any 
 party. 
 115.  AT&  Ts  other  DUF  forecasting-  related  arguments  relate  to  the  assumptions  BellSouth  incorporates  into  the  future  projections  of  DUF  messages  and  future  DUF  costs. 


 AT&  T  argues  that  BellSouth  failed  to  incorporate  actual  data  in  forecasting  growth  rates  and  assumes  an  unrealistic  decline  in  UNE-  platform  competition  in  the  BellSouth  region,  resulting  in 
 unrealistically  low  projected  growth  rates.  387  Finally,  AT&  T  argues  that  BellSouth  assumes  an  unrealistically  high  growth  rate  in  DUF-  related  charges,  inconsistent  with  actual  growth  rates 


 381  BellSouth  Caldwell  Reply  Aff.  at  para.  43.  A  worksheet  to  the  cost  study  file  contains  the  number  of 
 messages  used  in  the  cost  study  and  the  annual  demands,  by  job.  Id.  at  para.  44.  Again,  AT&  T  does  not  provide  specific  detail  regarding  which  message  volume  or  annual  demand  figures  it  believes  are  inappropriate. 


 382  Id.  at  para.  45.  AT&  T  points  to  only  one  job  to  which  it  asserts  BellSouth  attributed  disproportionately  high 
 labor  costs  based  on  the  number  of  messages  processed,  but  it  offers  no  expert  testimony  or  other  evidence  to  demonstrate  that  this  particular  job  necessarily  requires  fewer  labor  hours.  AT&  T  Turner  Decl.  at  para.  29. 


 383  AT&  T  Turner  Decl.  at  paras.  39-  48. 
 384  Id.  at  paras.  40-  41. 
 385  Id.  at  para.  40. 
 386  See  Letter  from  Glenn  T.  Reynolds,  Vice  President    Federal  Regulatory,  BellSouth,  to  Marlene  Dortch, 
 Secretary,  Federal  Communications  Commission,  WC  Docket  No.  02-  150  (filed  Aug.  14,  2002)  (BellSouth  August  14  Ex  Parte  Letter). 


 387  AT&  T  Turner  Decl.  at  paras.  43-  46. 
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 and  also  with  BellSouths  low  projected  growth  rates  of  DUF  messages.  388  In  response  to  these  last  two  arguments,  BellSouth  replies  that  the  demand  data  used  to  develop  the  current  DUF 
 rates  are  consistent  with  the  recent  forecast  used  in  Georgia  and  correspond  to  the  timeframe  for  the  cost  studies.  389  Moreover,  BellSouth  emphasizes  that  the  forecasts  are  based  on  the  best 
 available,  most  recent  data.  390  We  find  that  BellSouth  has  provided  a  reasonable  explanation  of  its  DUF-  related  processing  forecasts.  BellSouths  forecast  of  incremental  messages  is  based  on  a 
 study  of  actual  message  growth  during  the  period  January  2000  to  February  2001,  and  its  projection  of  competitive  LEC  DUF-  related  charges  is  based  on  actual  data  from  September 
 2000  through  February  2001.  391  AT&  T  has  not  shown  that  these  study  periods  are  unreasonable  or  that  they  lead  to  a  TELRIC  error  in  the  resulting  forecasts.  In  the  circumstances  presented 
 here,  AT&  T  could  have  raised  its  concerns  with  the  five  state  commissions  but  never  did  so.  Based  on  the  record  before  us,  we  conclude  that  the  state  commissions  did  not  commit  clear  error 
 in  adopting  DUF  rates  incorporating  these  forecast  assumptions. 
 116.  AT&  T  next  argues  that  BellSouth  uses  inconsistent  and  inappropriate  cost  recovery  periods  for  its  DUF  costs.  392  AT&  T  uses  the  term  cost  recovery  period  to  refer  to  the 


 future  period  for  which  BellSouth  projects  DUF  investment  and  demand  to  develop  a  per  unit  investment.  393  We  prefer  to  use  the  term  "study  period"  to  refer  to  this  period  to  avoid  confusing 
 it  with  the  period  over  which  the  investment  is  depreciated  for  purposes  of  developing  a  rate.  BellSouth's  ODUF  per  unit  investment  estimate  reflects  three  years  of  investment  and  demand 
 data.  394  Its  ADUF  per  unit  investment  estimate  reflects  ten  years  of  investment  and  demand  data.  395  BellSouth  depreciates  on  a  straight-  line  basis  the  per  unit  investment  derived  from  these 
 data  over  a  60-  month  period,  BellSouth's  estimate  of  the  life  of  the  DUF  assets,  to  derive  a  monthly  rate.  That  is,  BellSouth's  monthly  rate  recovers  one-  sixtieth  of  the  per  unit  investment. 
 AT&  T  asserts  that  the  proper  study  period  is  five  years  because  this  is  the  time  period  over  which  BellSouth  amortizes  these  investments.  396  Although  it  may  be  preferable  for  BellSouth  to 
 use  a  study  period  that  matches  the  period  over  which  the  investment  is  depreciated,  AT&  T  has  not  demonstrated  that  BellSouths  use  of  three-  year  and  ten-  year  study  periods  causes 
 competitive  LECs  to  incur  higher  DUF  charges  than  they  would  have  had  BellSouth  adopted  a 


 388  Id.  at  paras.  47-  48. 
 389  BellSouth  Caldwell  Reply  at  para.  46;  see  also  BellSouth  August  14  Ex  Parte  Letter. 
 390  See  generally  BellSouth  August  14  Ex  Parte  letter. 
 391  See  id. 
 392  AT&  T  Turner  Decl.  at  paras.  11,  31-  32. 
 393  See  id.  at  paras.  11,  31-  32. 
 394  BellSouth  Caldwell  Reply  Aff.  at  para.  47. 
 395  Id. 
 396  AT&  T  Turner  Decl.  at  paras.  11,  31-  32. 
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 five-  year  study  period.  In  fact,  the  use  of  a  ten-  year  study  period  for  ADUF  rate  development  clearly  results  in  lower  rates  than  would  a  five-  year  period.  We  cannot  determine,  on  this  record 
 and  within  the  time  constraints  of  the  90-  day  statutory  review  period  for  section  271  applications,  the  degree  to  which  those  costs  savings  are  offset  by  the  shorter  study  period  used 
 to  develop  ODUF  rates.  In  the  circumstances  presented  here,  AT&  T  could  have  raised  its  concerns  with  the  five  state  commissions  but  never  did  so.  Based  on  the  record  before  us,  we 
 find  that  the  state  commissions  did  not  commit  clear  error  in  adopting  DUF  rates  incorporating  these  varying  cost  recovery  periods. 


 117.  Fourth,  AT&  T  argues  that  BellSouth  violates  TELRIC  principles  by  failing  to  capitalize  all  DUF  system  development  costs.  AT&  T  argues  that,  although  BellSouth  properly 
 capitalized  labor  hours  associated  with  DUF  system  development,  it  inappropriately  expensed  other  associated  costs.  397  BellSouth  maintains  that  it  has  followed  accepted  accounting  principles 
 in  expensing  such  costs.  BellSouth  explains  that,  under  accepted  accounting  practices,  it  is  appropriate  to  capitalize  actual  programming  costs  while  expensing  overhead  or  one-  time  costs 
 associated  with  development  of  internal  software.  398  We  find  that  BellSouths  explanation  of  its  accounting  methodology  is  reasonable  and  that  there  is  insufficient  evidence  to  show  that  the 
 state  commissions  committed  clear  error  in  adopting  DUF  rates  based  upon  this  accounting  methodology. 


 118.  AT&  Ts  final  argument  is  related  to  the  format  in  which  competitive  LECs  receive  DUF  messages.  BellSouth  offers  competitive  LECs  a  choice  of  receiving  such  messages 
 either  electronically  for  a  per-  message  charge,  or  via  magnetic  tape,  with  billing  on  a  per-  tape  basis.  AT&  T  argues  that  BellSouth  has  included  the  costs  of  providing  the  magnetic  tape  feed  in 
 the  general  message  processing  costs,  which  results  in  all  competitive  LECs  being  forced  to  bear  a  portion  of  the  magnetic  tape  charges.  399  BellSouth  contends  that  AT&  T  inaccurately 
 characterizes  the  costs  at  issue.  BellSouth  explains  that  these  are  not  recurring  charges  for  magnetic  tape  use,  but  actually  one-  time  development  costs  associated  with  the  initial  production 
 of  a  magnetic  tape  for  system  testing  purposes.  400  BellSouth  further  explains  that,  in  its  cost 
 397  Id.  at  paras.  35-  36. 


 398  BellSouth  states  that  this  methodology  is  consistent  with  the  Statement  of  Position  (SOP)  98-  01,  Accounting 
 for  the  Costs  of  Computer  Software  Developed  or  Obtained  for  Internal  Use,  which  has  been  accepted  by  the  Commission.  BellSouth  Caldwell  Reply  at  para.  51.  See  1998  Biennial  Regulatory  Review    Review  of  Accounting 


 and  Cost  Allocation  Requirements,  CC  Docket  No.  98-  81,  Report  and  Order,  14  FCC  Rcd  11396  (1999).  AT&  T  does  not  dispute  this  assertion.  AT&  T  does  dispute,  however,  that  SOP  98-  01  is  applicable  at  all,  arguing  that 
 paragraph  15  of  SOP  98-  1  establishes  that  SOP  98-  1  does  not  apply  to  computer  software  that  is  used  or  marketed  to  third  parties.  See  AT&  T  August  23  Pricing  and  Growth  Tariff  Ex  Parte  Letter  at  5.  AT&  T  asserts  that  BellSouth 
 is  marketing  the  DUF  software  development  and  processes  to  competitive  LECs  as  an  unbundled  element  and  that  the  provisions  of  SOP  98-  1  therefore  do  not  apply.  Id.  We  disagree.  BellSouth  sells  the  DUF  reports  themselves 
 and  not  DUF  software  to  competitive  LECs.  Indeed,  by  its  own  terms,  SOP  98-  01  applies  to  software  used  by  the  vendor  in  the  production  of  the  product  or  providing  the  service  where  the  customer  does  not  acquire  the  software 
 or  the  future  right  to  use  it.  SOP  98-  01  at  para.  15. 
 399  AT&  T  Turner  Decl.  at  paras.  37-  38. 


 400  BellSouth  Caldwell  Reply  at  para.  52. 
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 study,  all  developmental  costs  are  recovered  over  projected  number  of  messages,  including  the  cost  of  producing  the  initial  tape.  401  Based  on  the  record  before  us,  we  find  that  BellSouths 
 explanation  is  reasonable  and  that  there  is  insufficient  evidence  to  show  that  the  state  commissions  committed  clear  error  in  adopting  DUF  rates  incorporating  such  charges. 


 119.  WorldCom  argues  that  ODUF  and  ADUF  charges  should  be  eliminated  altogether  because  BellSouth  already  recovers  DUF  costs  in  the  shared  and  common  costs  that  BellSouth 
 adds  to  the  direct  costs  of  other  UNEs.  402  We  rejected  this  identical  argument  in  the  BellSouth  Georgia/  Louisiana  Order.  403  The  Mississippi  Commission  also  rejected  this  contention,  finding 
 that  BellSouths  cost  filing  in  this  proceeding  outlines  the  adjustments  BellSouth  made  to  remove  the  directly  identified  costs.  BellSouth  has  reduced  its  common  and  shared  factor  by  the 
 amount  of  expense  that  it  included  in  the  development  of  its  daily  usage  file  charges.  404  BellSouth  provides  evidence  that  the  company  identified  and  removed  DUF-  related  costs  that  are 
 directly  assigned  in  the  cost  studies  from  the  development  of  shared  and  common  factors  in  Alabama,  Kentucky,  North  Carolina,  South  Carolina,  and  Mississippi.  405  Accordingly,  we  reject 
 this  argument,  and  find  that  there  is  insufficient  evidence  to  show  that  the  state  commissions  committed  clear  error  in  adopting  separate  charges  for  ODUFs  and  ADUFs. 


 120.  Conclusion.  Based  on  the  foregoing,  we  find  that  the  rates  that  BellSouth  charges  to  provide  DUFs  to  competitive  LECs  are  just,  reasonable,  and  nondiscriminatory  in  compliance 
 with  checklist  item  2. 
 c.  Non-  Recurring  Charges 
 121.  OSS  Charge.  BellSouth  imposes  a  non-  recurring  charge  to  recover  the  incremental  costs  that  it  incurs  to  develop,  implement,  and  maintain  the  electronic  interfaces  to 


 its  OSS  in  order  to  provide  competitive  LECs  with  access  to  the  OSS.  406  BellSouth  states  that  these  costs  are  related  to  service  order  processing  and  are  imposed  per  Local  Service  Request 
 (LSR).  407  As  stated  in  BellSouths  SGATs,  these  per-  LSR  OSS  charges  are  $5.70  in  Mississippi,  $5.83  in  Alabama,  $5.92  in  South  Carolina,  and  $7.88  in  Kentucky.  408  The  OSS  charge  in  North 
 Carolina,  which  is  not  at  issue  here,  is  a  single  flat  monthly  fee  of  $305,  regardless  of  the  number 


 401  Id. 
 402  WorldCom  Comments  at  12;  WorldCom  Frentrup  Decl.  at  paras.  24-  25. 
 403  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9065,  para.  93. 
 404  See  Mississippi  Commission  UNE  Rate  Order  at  44;  see  also  Mississippi  Commission  Reply  at  9. 
 405  See  BellSouth  Caldwell  Reply  at  para.  42. 
 406  Mississippi  Commission  UNE  Rate  Order  at  27. 
 407  BellSouth  Caldwell  Reply  Aff.  at  para.  54. 
 408  Id.  at  para.  55. 
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 of  orders  (i.  e.,  loops)  processed.  409  BellSouth  also  states  that  it  offers  competitive  LECs  a  region-  wide  OSS  rate  of  $3.50  per  LSR  in  its  standard  interconnection  agreement,  which  many 
 competitive  LECs,  including  ITC^  DeltaCom  and  Talk  America,  have  agreed  to  pay  instead  of  the  OSS  charges  in  BellSouths  SGATs.  410 


 122.  Whether  a  competitive  LEC  pays  the  $5.70-$  7.88  OSS  charges  in  BellSouths  SGATs  or  the  $3.50  OSS  charge  available  in  BellSouths  region-  wide  interconnection 
 agreement,  BellSouth  states  that  up  to  25  loops  may  be  included  in  a  single  LSR  provided  that  the  loops  are  for  the  same  customer  at  the  same  location.  411  This  has  a  substantial  effect  on  the 
 final  per-  loop  OSS  charge.  For  example,  with  respect  to  UNE-  platform  orders  in  Kentucky,  the  OSS  charge  for  UNE  migration  can  be  as  low  as  $0.41  per  loop  if  a  competitive  LEC  bundles  25 
 loops  serving  the  same  location.  412 
 123.  WorldCom  challenges  the  per-  LSR  OSS  charges  in  BellSouths  SGATs  in  Mississippi,  Alabama,  South  Carolina,  and  Kentucky.  413  These  charges,  according  to 


 WorldCom,  do  not  compare  with  those  in  other  BellSouth  states,  such  as  Louisiana,  where  the  charge  is  $2.98,  or  Georgia,  where  it  is  $0.19.  414  WorldCom  claims  that  such  differences  in  OSS 
 charges  among  different  in-  region  states  cannot  be  justified  according  to  state-  specific  demand  because  BellSouths  OSS  is  regional.  415  WorldCom  also  contends  that  it  is  improper  for 


 409  Id.  at  para.  54.  BellSouth  has  recently  submitted  cost  studies  to  the  North  Carolina  Commission  that  would  re-structure 
 the  OSS  charge  to  be  identical  to  that  in  the  other  four  states    namely,  on  a  per-  LSR  basis.  Id.  See  also  Letter  from  Glenn  T.  Reynolds,  Vice  President    Federal  Regulatory,  BellSouth,  to  Marlene  H.  Dortch,  Secretary, 


 Federal  Communications  Commission,  WC  Docket  No.  02-  150  (Sept.  17,  2002)  (BellSouth  September  17  Ex  Parte  Letter). 


 410  BellSouth  Ruscilli/  Cox  Reply  Aff.  at  para.  44. 
 411  Letter  from  Glenn  T.  Reynolds,  Vice  President    Federal  Regulatory,  BellSouth,  to  Marlene  H.  Dortch, 
 Secretary,  Federal  Communications  Commission,  WC  Docket  No.  02-  150  at  10-  11  (Aug.  15,  2002)  (BellSouth  August  15  Ex  Parte  Letter);  BellSouth  September  17  Ex  Parte  Letter. 


 412  We  calculate  this  figure  by  dividing  $7.88  by  25  to  get  an  OSS  charge  of  $0.31  per  loop.  BellSouth  then  adds 
 a  $0.10  UNE-  platform  charge  that  is  imposed  on  each  loop,  regardless  of  the  number  of  loops  provisioned.  See  BellSouth  Application  App.  A,  Vol.  4a,  Tab  G,  Exh.  JAR/  CKC-  1at  13,  line  P.  1  (Alabama);  Vol.  4b,  Tab  G,  Exh. 


 JAR/  CKC-  2  at  10,  line  P.  1  (Kentucky);  Vol.  4c,  Tab  G,  Exh.  JAR/  CKC-  3  at  13,  line  P.  1  (Mississippi);  Vol.  4d,  Tab  G,  Exh.  JAR/  CKC-  4  at  14,  line  P.  1  (North  Carolina);  Vol.  4e,  Tab  G,  Exh.  JAR/  CKC-  5  at  15,  line  P.  1  (South 
 Carolina);  see  generally  BellSouth  Caldwell  Reply  Aff.  at  para.  54;  BellSouth  September  17  Ex  Parte  Letter. 
 413  WorldCom  Comments  at  11.  WorldCom  does  not  challenge  the  OSS  charge  in  North  Carolina,  which 
 WorldCom  estimates  is  $0.06.  Id.  WorldCom  derives  this  figure  by  assuming  that  a  competitive  LEC  places  5,000  orders  per  month  in  North  Carolina.  BellSouth  Caldwell  Reply  Aff.  at  para.  54.  BellSouth  contends  that  there  is  no 


 factual  basis  for  this  assumption.  Id.  We  need  not  resolve  this  dispute  because  AT&  T  does  not  challenge  the  North  Carolina  OSS  charge. 


 414  WorldCom  Comments  at  11. 
 415  Id. 
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 BellSouth  to  recover  any  cost  for  OSS  development  because  such  costs  are  already  recovered  in  the  common  cost  factor.  416 
 124.  WorldCom  limits  its  attacks  on  the  OSS  charges  to  the  two  issues  summarized  above    namely,  that  the  disputed  OSS  charges  are  higher  than  those  in  other  BellSouth  states 
 and  that,  in  any  event,  BellSouth  recovers  these  costs  twice.  Significantly,  WorldCom  does  not  challenge  the  cost  study  establishing  these  OSS  charges  and  does  not  otherwise  contend  that  the 
 disputed  OSS  charges  do  not  comply  with  the  Commissions  TELRIC  pricing  principles. 
 125.  As  an  initial  matter,  BellSouth  asserts  that  WorldCom  improperly  compares  OSS  charges  among  various  BellSouth  states.  417  BellSouth  points  out  that  the  Commission  has  not 


 previously  found  simple  comparisons  of  non-  recurring  charges  between  states  to  be  dispositive  of  TELRIC  compliance.  418  BellSouth  is  correct.  419  BellSouth  also  shows  that  the  OSS  charges  in 
 Georgia  and  North  Carolina  are  not  comparable  to  those  in  Alabama,  Kentucky,  Mississippi,  or  South  Carolina.  420  In  both  Georgia  and  North  Carolina,  OSS  costs  are  recovered  on  an  entirely 
 different  basis    that  is,  according  to  a  monthly  flat  fee.  421  In  Georgia,  this  fee  is  $550  for  the  first  1,000  orders,  and  in  North  Carolina,  as  noted  above,  the  charge  is  $305  for  an  unlimited 
 number  of  orders.  422  In  Louisiana,  BellSouth  filed  nearly  the  same  OSS  rate  ($  11.74)  as  it  did  in  Alabama  and  Kentucky  ($  11.66),  Mississippi  ($  11.71),  and  South  Carolina  ($  11.83).  423 


 126.  BellSouth  also  explains  that,  although  it  filed  the  same  regional  OSS  cost  study  with  each  state  commission,  the  state  commissions  directed  BellSouth  to  make  numerous  state-specific 
 adjustments  to  the  cost  study.  424  For  example,  the  Alabama,  Mississippi,  and  South  Carolina  Commissions  reduced  BellSouths  proposed  rates  by  50  percent,  425  resulting  in  similar 
 rates  in  these  states  --  $5.84  (Alabama);  $5.70  (Mississippi);  and  $5.92  (South  Carolina).  426  In 


 416  Id.  at  11-  12. 
 417  BellSouth  Reply  at  45-  46. 
 418  Id.  at  45. 
 419  See  Verizon  New  Jersey  Order,  17  FCC  Rcd  at  12306,  para.  70  n.  193  (stating  that  comparison  of  hot  cut  rates 
 between  states  is  not  dispositive  of  TELRIC  compliance). 
 420  BellSouth  Caldwell  Reply  Aff.  at  paras.  54,  57. 


 421  Id. 
 422  Id.;  see  also  BellSouth  September  17  Ex  Parte  Letter. 
 423  BellSouth  Caldwell  Reply  Aff.  at  para.  55. 
 424  Id. 
 425  Id.  at  para.  56. 
 426  Id. 
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 Kentucky,  the  commission  did  not  order  such  an  across-  the-  board  rate  reduction.  427  Instead,  it  reviewed  individual  work  time  estimates,  made  specific  adjustments  to  the  electronic  service 
 order  charge  (element  N.  1.1.),  and  accepted  BellSouths  proposed  electronic  interface  costs.  428  We  find  that  BellSouth  has  demonstrated  that  its  OSS  charges  are  in  fact  based  on  a  regional  cost 
 study,  and  it  has  provided  a  reasonable  explanation  of  the  variations  among  its  OSS  charges.  429  We  conclude  that  this  variation  among  states  is  not  sufficient  to  demonstrate  any  TELRIC  error, 
 and,  in  any  event,  WorldCom  does  not  claim  that  any  of  the  state-  specific  OSS  charge  adjustments  by  the  Alabama,  Kentucky,  Mississippi,  or  South  Carolina  Commissions  violate  the 
 Commissions  TELRIC  principles. 
 127.  Finally,  WorldCom  alleges  that  BellSouth  already  recovers  its  OSS  development  costs  in  its  shared  and  common  costs.  430  Both  the  Kentucky  and  Mississippi  Commissions 


 considered  and  rejected  this  specific  argument.  431  WorldCom  does  not  provide  any  evidence  in  support  of  this  broad  allegation.  BellSouth,  on  the  other  hand,  explains  that  the  OSS  costs 
 included  in  the  shared  and  common  costs  relate  to  legacy  systems  only,  not  the  costs  associated  with  developing,  programming  and  maintaining  the  new  ordering  interfaces  used  by 
 [competitive]  LECs.  432  Thus,  BellSouth  asserts  that  it  incurs  costs  in  providing  simple  access  to  OSS  and  that  such  costs  do  not  include  the  legacy  OSS  systems  themselves,  which  are  reflected 
 in  the  shared  and  common  costs.  433  Without  evidence  of  the  alleged  double  recovery  of  OSS  costs  and  in  light  of  BellSouths  explanation  of  the  different  OSS  costs  recovered  in  its  shared 
 and  common  costs,  we  conclude  that  BellSouths  OSS  charges  in  Alabama,  Kentucky,  Mississippi,  and  South  Carolina  comply  with  the  Commissions  TELRIC  pricing  principles. 


 427  Id. 
 428  Id. 
 429  Id.  We  find  that  any  de  minimis  cost  differences  between  Alabama  and  Kentucky  on  the  one  hand  and 
 Mississippi  and  South  Carolina  on  the  other  do  not  demonstrate  a  violation  of  TELRIC  principles. 
 430  WorldCom  Frentrup  Reply  Decl.  at  para.  29. 


 431  See  Kentucky  Commission  UNE  Rate  Order  at  32  (rejecting  WorldComs  argument  that  OSS  costs  are 
 included  in  BellSouths  common  costs  and  accepting  BellSouths  contention  that  the  OSS  costs  included  in  shared  and  common  costs  relate  to  legacy  systems  only);  Mississippi  Commission  UNE  Rate  Order  at  27  (finding  that 


 WorldCom  is  simply  wrong  that  OSS  costs  are  in  included  in  BellSouths  common  costs). 
 432  BellSouth  Caldwell  Reply  Aff.  at  para.  59. 


 433  BellSouth  Surrebuttal  Testimony  of  D.  Daonne  Caldwell  Before  the  Mississippi  Public  Service  Commission, 
 Docket  No.  2000-  UA-  999,  at  32  (June  11,  2001)  (emphasis  added).  That  WorldCom  has  not  provided  sufficient  evidence  of  double  recovery  of  OSS  costs  in  this  instance  should  not,  however,  be  construed  as  an  endorsement  or 


 rejection  of  any  particular  method  of  recovering  OSS  costs. 
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 2.  Access  to  Operations  Support  Systems 
 128.  We  find,  as  did  the  state  commissions,  434  that  BellSouth  provides  nondiscriminatory  access  to  its  OSS  and,  thus,  satisfies  the  requirements  of  checklist  item  2.  We 


 find  that  the  evidence  presented  in  this  record  shows  that  BellSouth  provides  nondiscriminatory  access  to  its  OSS  functions  for  pre-  ordering,  ordering,  provisioning,  maintenance  and  repair,  and 
 billing.  We  base  this  determination  on  BellSouths  actual  performance  in  each  of  the  states  and,  in  certain  instances,  on  its  performance  in  Georgia.  The  Commission  may  evaluate  BellSouths 
 performance  in  an  individual  state  for  enforcement  purposes  pursuant  to  section  271(  d)(  6).  435 
 129.  The  Commission  has  defined  OSS  as  the  various  systems,  databases,  and  personnel  used  by  incumbent  LECs  to  provide  service  to  their  customers,  436  and  consistently  has 


 found  that  nondiscriminatory  access  to  OSS  is  a  prerequisite  to  the  development  of  meaningful  local  competition.  437  We  analyze  whether  BellSouth  has  met  the  nondiscrimination  standard  for 
 each  OSS  function  using  the  two-  step  approach  outlined  in  prior  orders.  438  Under  the  first  inquiry,  a  BOC  must  demonstrate  that  it  has  developed  sufficient  electronic  (for  functions  that 
 the  BOC  accesses  electronically)  and  manual  interfaces  to  allow  competing  carriers  equivalent  access  to  all  of  the  necessary  OSS  functions.  439  Under  the  second  inquiry,  we  examine 
 performance  measurements  and  other  evidence  of  commercial  readiness  to  ascertain  whether  the  BOCs  OSS  is  handling  current  demand  and  will  be  able  to  handle  reasonably  foreseeable  future 
 volumes.  440  The  most  probative  evidence  that  OSS  functions  are  operationally  ready  is  actual 


 434  Alabama  Commission  Comments  at  173;  Kentucky  Commission  Comments  at  30;  Mississippi  Commission 
 Comments  at  11;  North  Carolina  Commission  Comments  at  163;  South  Carolina  Commission  Comments  at  1-  3. 
 435  47  U.  S.  C.    271(  d)(  6). 


 436  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  3989-  90,  para.  83;  Application  by  BellSouth  Corporation,  et  al., 
 Pursuant  to  Section  271  of  the  Communications  Act  of  1934,  as  amended,  to  Provide  In-  Region,  InterLATA  Service  in  South  Carolina,  CC  Docket  No.  97-  208,  Memorandum  Opinion  and  Order,  13  FCC  Rcd  539,  585,  para.  82 


 (BellSouth  South  Carolina  Order);  SWBT  Texas  Order,  15  FCC  Rcd  at  18396-  97,  para.  92. 
 437  See  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  3900,  para.  83;  Second  BellSouth  Louisiana  Order,  13  FCC 
 Rcd  at  20653-  57,  paras.  83-  90;  BellSouth  South  Carolina  Order,  13  FCC  Rcd  at  547-  49,  585,  paras.  14-  18,  82. 
 438  See,  e.  g.,  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  3991-  92,  paras.  85-  86;  SWBT  Kansas/  Oklahoma 
 Order,  16  FCC  Rcd  at  6284-  85,  paras.  104-  05. 
 439  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  3992,  para.  87;  Ameritech  Michigan  Order,  12  FCC  Rcd  at 
 20616,  para.  136  (stating  that  the  Commission  determines  whether  the  BOC  has  deployed  the  necessary  systems  and  personnel  to  provide  sufficient  access  to  each  of  the  necessary  OSS  functions  and  whether  the  BOC  is 


 adequately  assisting  competing  carriers  to  understand  how  to  implement  and  use  all  of  the  OSS  functions  available  to  them.).  For  example,  a  BOC  must  provide  competing  carriers  the  specifications  necessary  to  design  their 
 systems  interfaces  and  business  rules  necessary  to  format  orders,  and  demonstrate  that  systems  are  scalable  to  handle  current  and  projected  demand.  Id. 


 440  We  assess  whether  the  OSS  functions  that  the  BOC  has  deployed  are  operationally  ready,  as  a  practical 
 matter.  See  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  3992,  para.  88. 
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 commercial  usage  in  the  state  for  which  the  BOC  seeks  section  271  authorization.  441  Absent  sufficient  and  reliable  data  on  commercial  usage  in  a  state,  the  Commission  will  consider  the 
 results  of  carrier-  to-  carrier  testing,  independent  third-  party  testing,  and  internal  testing  in  assessing  the  commercial  readiness  of  a  BOCs  OSS.  Where,  as  here,  the  BOC  proves  that  many 
 of  the  OSS  functions  in  the  states  for  which  it  seeks  section  271  authorization  are  the  same  as  in  a  state  for  which  we  have  already  granted  such  authorization,  we  will  also  look  to  performance 
 in  the  latter  state  as  additional  evidence  with  which  to  make  our  determination.  442  Finally,  we  focus  our  analysis  in  this  Order  on  a  handful  of  issues  that  are  contested  by  commenting  parties 
 or  in  areas  where  performance  has  deteriorated  since  issuance  of  the  BellSouth  Georgia/  Louisiana  Order. 


 a.  Relevance  of  BellSouths  Georgia  OSS 
 130.  We  find  that  BellSouth,  through  the  Pricewaterhouse  Coopers  (PwC)  report,  provides  evidence  that  its  OSS  in  Georgia  are  substantially  the  same  as  the  OSS  in  each  of  the 


 five  states.  We  shall  consider  BellSouths  commercial  OSS  performance  in  Georgia  and  the  Georgia  third  party  test  to  support  this  application.  Moreover,  BellSouths  showing  enables  us 
 to  rely,  in  most  instances,  on  findings  relating  to  BellSouths  OSS  from  the  BellSouth  Georgia/  Louisiana  Order  in  our  analysis  of  BellSouths  OSS  in  the  five  states.  In  addition,  we 
 can  examine  data  reflecting  BellSouths  performance  in  Georgia  where  low  volumes  yield  inconclusive  or  inconsistent  information  concerning  BellSouths  compliance  with  the 
 competitive  checklist.  443  This  anchor  state  approach  was  developed  in  the  SWBT  Kansas/  Oklahoma  Order  444  and  has  been  used  frequently  since  then.  445 


 131.  Consistent  with  our  anchor  state  precedent,  as  articulated  in  the  SWBT  Kansas/  Oklahoma  Order,  446  BellSouth  relies  heavily  in  this  application  on  evidence  concerning 
 its  Georgia  OSS.  447  We  have  held  that  companies  may  use  evidence  from  an  anchor  state  when  the  OSS  are  regional.  448  BellSouth  asserts  that  its  OSS  in  Georgia  are  substantially  the  same  as 
 the  OSS  in  each  of  the  states  and,  therefore,  evidence  concerning  its  OSS  in  Georgia  is  relevant 


 441  See  SWBT  Kansas/  Oklahoma  Order,  16  FCC  Rcd  at  6285,  para.  105. 
 442  Id. 
 443  Id.  at  6254-  55,  paras.  36-  37,  6286-  87,  paras.  106-  08.  As  noted  above,  the  Commission  may  evaluate 
 BellSouths  performance  in  an  individual  state  for  enforcement  purposes  pursuant  to  section  271(  d)(  6). 
 444  Id. 


 445  See,  e.  g.,  Verizon  Rhode  Island  Order,  17  FCC  Rcd  at  3327-  28,  paras.  59-  60;  Verizon  Vermont  Order,  17  FCC 
 Rcd  at  7647,  para.  40;  Verizon  Maine  Order,  17  FCC  Rcd  at  11682-  83,  para.  36. 
 446  See  SWBT  Kansas/  Oklahoma  Order,  16  FCC  Rcd  at  6254-  55,  paras.  36-  37,  6286-  87,  paras.  106-  08. 


 447  Id.  at  6286-  87,  paras.  106-  07. 
 448  Id. 
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 and  should  be  considered  in  our  evaluation  of  each  states  OSS.  449  To  support  its  claim,  BellSouth  submits  the  PwC  report.  450 
 132.  PwC  conducted  an  attestation  examination  of  BellSouths  assertion  that:  (1)  the  same  pre-  ordering  and  ordering  OSS,  processes  and  procedures  are  used  to  support  competing 
 LEC  activity  across  BellSouths  nine-  state  region,  and  that  (2)  there  are  no  material  differences  in  the  functionality  or  performance  of  BellSouths  two  order  entry  systems:  Direct  Order  Entry 
 (DOE)  and  Service  Order  Negotiation  System  (SONGS).  451  PwC  concluded  that,  in  its  opinion,  BellSouths  assertions  were  fairly  stated,  in  all  material  respects.  452  In  addition,  as  the 
 Department  of  Justice  expressly  recognizes,  the  systems  and  processes  serving  the  five  states  are  largely  the  same  as  those  at  issue  and  approved  in  the  BellSouth  Georgia/  Louisiana  Order  and 
 therefore,  notwithstanding  the  lower  level  of  competition  in  the  five  states,  finds  OSS  sufficient  to  support  competitive  entry.  453 


 133.  We  reject  commenters  claims  that  BellSouths  OSS  are  not  regional.  454  The  record  indicates  that  the  PwC  examination  closely  modeled  the  successful  Five  State  Regional 
 OSS  Attestation  Examination  performed  in  the  context  of  SWBTs  Kansas/  Oklahoma  section  271  application.  BellSouth  has  provided  detailed  information  regarding  the  sameness  of 
 BellSouths  systems  in  the  five  states,  including  their  manual  systems  and  the  way  in  which  BellSouth  personnel  do  their  jobs.  455  Finally,  we  note  that,  while  commenters  initially  contended 


 449  BellSouth  Application  at  59-  61;  BellSouth  Application  App.  A,  Vol.  6a,  Tab  I,  Affidavit  of  William  N.  Stacy 
 (BellSouth  Stacy  Aff.)  at  para.  61;  BellSouth  Reply  at  22-  24;  BellSouth  Reply  App.,  Vol  3a,  Tab  H,  Reply  Affidavit  of  William  N.  Stacy  (BellSouth  Stacy  Reply  Aff.)  at  paras.  158-  69;  see  also  SWBT  Kansas/  Oklahoma  Order,  16 


 FCC  Rcd  at  6286-  87,  paras.  106-  07. 
 450  BellSouth  Stacy  Reply  Aff.  at  para.  159. 


 451  In  conducting  its  review,  PwC  examined  the  consistency  of  applications  and  technical  configurations  used  to 
 process  pre-  ordering  and  ordering  transactions  region-  wide,  and  reviewed  the  consistency  of  documentation  of  systems  and  processes  in  BellSouths  local  carrier  service  center  (LCSC).  BellSouth  Application  at  65-  66; 


 BellSouth  Stacy  Aff.  at  paras.  66-  70  &  Exh.  OSS-  10  at  para  7;  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9072-  73,  paras.  109-  10. 


 452  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9072,  para.  109;  BellSouth  Stacy  Aff.  at  para.  70. 
 453  Department  of  Justice  Evaluation  at  7. 
 454  See  AT&  T  Comments  at  18-  20;  AT&  T  Reply  at  18-  19;  WorldCom  Comments  at  1-  2,  8-  10;  WorldCom 
 Comments  App.,  Tab  A,  Declaration  of  Sherry  Lichtenberg  (WorldCom  Lichtenberg  Decl.)  at  paras.  27-  30;  WorldCom  Reply  at  7-  8.  AT&  T,  for  example,  states  that  BellSouths  staggered  single  C  implementation  process 


 made  little  sense  if  BellSouths  OSS  were  truly  regional.  AT&  T  Reply  at  19. 
 455  BellSouth  Application  at  60-  62;  BellSouth  Reply  at  22-  23;  BellSouth  Stacy  Reply  Aff.  at  para.  161;  BellSouth 
 Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9073,  para.  110. 
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 that  the  Commission  should  rely  upon  the  Tennessee  Regulatory  Authoritys  determination  that  BellSouths  OSS  are  not  regional,  456  this  determination  has  since  been  reversed.  457 
 134.  We  also  disagree  with  commenters  claims  that  BellSouths  application  should  fail  because  a  third  party  did  not  examine  BellSouths  OSS  in  each  of  the  states.  458  In  prior 
 orders,  the  Commission  has  held  that  third  party  tests  can  provide  critical  information  about  the  functionality  and  performance  of  a  BOCs  OSS.  459  The  Commission  has  not,  however,  stated 
 that  checklist  compliance  cannot  be  proven  without  a  third  party  test  of  an  applicants  OSS.  460  Moreover,  the  PwC  attestation  leads  us  to  conclude  that  the  KPMG  tests  in  Georgia  and  Florida 
 also  may  yield  information  that  is  relevant  and  useful  to  our  assessment  of  BellSouths  OSS  in  these  five  states.  In  any  event,  we  emphasize  that  our  analysis  of  an  applicants  OSS  rests  on  a 
 wide  range  of  evidence,  of  which  evidence  from  third  party  tests  is  but  one  part.  The  need  to  rely  on  a  third  party  test  is  reduced  in  this  instance  because  BellSouth  is  relying  on  an  OSS  that 
 this  Commission  recently  found  to  be  nondiscriminatory  in  the  BellSouth  Georgia/  Louisiana  271  Order. 


 135.  Finally,  we  reject  Covads  claim  that  the  independent  third-  party  test  in  Georgia  was  flawed  because  KPMG  failed  to  test  critical  aspects  of  BellSouths  OSS.  461  In  the  BellSouth 
 Georgia/  Louisiana  Order,  we  found  that  the  results  of  KPMGs  test  in  Georgia  provide  meaningful  evidence  that  is  relevant  to  our  analysis  of  BellSouths  OSS.  462  No  commenters  have 
 presented  sufficient  evidence  to  cause  us  to  reevaluate  this  conclusion. 
 b.  Pre-  Ordering 
 136.  To  comply  with  its  obligation  to  provide  nondiscriminatory  access  to  OSS  functions,  BOCs  must  provide  competing  carriers  with  access  to  pre-  ordering  functions  such  as 


 street  address  validation;  telephone  number  selection;  service  and  feature  availability;  due  date  information;  customer  service  record  information;  and  loop  qualification  information.  We 


 456  AT&  T  Comments  at  19;  AT&  T  Comments  App.,  Tab  G,  Declaration  of  Jay  M.  Bradbury  and  Sharon  E. 
 Norris  (AT&  T  Bradbury/  Norris  Decl.)  at  paras.  138-  46;  WorldCom  Comments  at  8. 
 457  See  BellSouth  Reply  at  23. 


 458  See  AT&  T  Comments  at  18-  20;  Covad  Comments  at  5-  7;  WorldCom  Comments  at  8-  10;  WorldCom 
 Lichtenberg  Decl.  at  10-  11.  AT&  T  also  contends  that  BellSouth  cannot  rely  on  the  PwC  report.  See  AT&  T  August  23  OSS  and  Data  Integrity  Ex  Parte  Letter  at  6-  7. 


 459  See  SWBT  Kansas/  Oklahoma  Order,  16  FCC  Rcd  at  6291,  para.  118. 
 460  See  id. 
 461  See  Covad  Comments  at  3,  5-  7  (claiming  that  KPMGs  third  party  test  failed  to  test:  1)  electronic  ordering  of 
 stand  alone  xDSL  loops  by  any  of  three  electronic  gateways  (TAG,  LENS  or  EDI);  2)  BellSouths  ability  to  handle  high  volumes  of  manual  orders  for  stand  alone  xDSL  loops  that  cannot  be  handled  manually;  3)  electronic  ordering 


 of  line  sharing  through  the  three  gateways;  and  4)  electronic  OSS  for  IDSL  loops). 
 462  See  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9072,  para.  108. 
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 conclude  that  for  each  of  the  application  states,  BellSouth  demonstrates  that  it  provides  competing  carriers  with  nondiscriminatory  access  to  pre-  ordering  functions.  We  find  that 
 BellSouth  generally  meets  or  exceeds  the  applicable  benchmarks  for  the  OSS  pre-  ordering  metrics.  As  discussed  above,  we  find  that  BellSouths  pre-  ordering  functions  are  provided  on  a 
 region-  wide  basis  and  therefore  we  rely  on  our  previous  approval  of  the  same  pre-  ordering  OSS  systems  and  processes  in  the  BellSouth  Georgia/  Louisiana  Order.  463  We  also  note  that  each  of 
 the  state  commissions  in  the  instant  application  found  that  BellSouths  pre-  ordering  functions  comply  with  this  checklist  item.  464 


 137.  AT&  T  claims  that  outages  in  BellSouths  ordering  interfaces  interfere  with  its  ability  to  obtain  nondiscriminatory  access  to  pre-  ordering  functions  and  that  BellSouths 
 performance  metrics  do  not  reflect  the  actual  number  of  times  that  the  ordering  interfaces  are  unavailable  to  competitors.  465  AT&  T  also  contends  that  BellSouth  improperly  includes  the  hours 
 of  test  servers  and  back-  up  servers  in  its  calculations  for  the  interface  availability  measure.  466  We  disagree  with  AT&  Ts  claims.  467  During  the  relevant  period  for  this  application,  BellSouth 
 generally  met  or  exceed  the  applicable  benchmarks  for  the  OSS  pre-  ordering  metrics.  468 


 463  See  id.  at  9069-  9073,  paras.  103-  11,  9076-  87,  117-  34. 
 464  See  Alabama  Commission  Comments  at  149-  61;  Kentucky  Commission  Comments  at  19-  21;  Mississippi 
 Commission  Comments  at  11;  North  Carolina  Commission  Comments  at  130-  33;  South  Carolina  Commission  Comments  at  1-  3. 


 465  AT&  T  Bursh/  Norris  Decl.  at  paras.  55-  56.  As  in  Georgia  and  Louisiana,  competing  carriers  may  use  one  of 
 two  BellSouth  pre-  ordering  interfaces:  (1)  the  Telecommunications  Access  Gateway  (TAG)  which  is  an  application-  to-  application  interface;  or  (2)  the  Local  Exchange  Navigation  System  (LENS)  which  is  a  graphical  user 


 interface  (GUI).  See  BellSouth  Application  at  77-  80;  BellSouth  Stacy  Aff.  at  paras.  171-  76.  Competitive  LECs  may  use  these  interfaces  to  submit  orders  for  end  users  region-  wide.  BellSouth  Application  at  77;  BellSouth  Stacy 
 Aff.  at  paras.  12,  173-  74,  176,  191.  See  also  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9076,  para.  117.  Both  interfaces  are  in  active  use  by  competitors  and  performance  data  submitted  by  BellSouth  in  its  application 
 demonstrate  that  both  interfaces  provide  competitors  with  equivalent  access  to  BellSouths  pre-  ordering  functions.  See  BellSouth  Stacy  Aff.  at  para.  13. 


 466  AT&  T  Bursh/  Norris  Decl.  at  paras.  55-  56. 
 467  In  a  declaration  attached  to  its  comments,  AT&  T  cites  instances  where  BellSouth  has  not  met  the  benchmark 
 or  parity  standards  during  the  relevant  period.  AT&  T  Bursh/  Norris  Decl.  at  paras.  76-  187.  We  fully  address  BellSouths  performance  with  respect  to  these  issues,  infra. 


 468  BellSouth  Stacy  Aff.  at  paras.  296-  307.  See  D.  1.1  (%  Interface  Availability    CLEC);  D.  1.2  (%  Interface 
 Availability    BST  &  CLEC);  D.  1.3  (Average  Response  Interval    CLEC  (LENS));  D.  1.3  (Average  Response  Interval    CLEC  (TAG)).  We  note  that  these  metrics  provide  regional  data.  In  addition,  the  percent  interface 


 availability  metrics  record  all  system  outages  regardless  of  duration  and  is  similar  to  the  metric  used  by  the  other  BOCs.  See  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9077  n.  393.  Furthermore,  BellSouth  has  generally 
 met  the  benchmark  or  provided  parity  for  almost  all  submetrics  from  March  through  June.  BellSouth  was  only  out  of  parity  region-  wide  in  one  month  for  the  following  metrics:  D.  1.1.7  (%  Interface  Availability  -  CLEC,  TAG); 
 D.  1.1.8  (%  Interface  Availability    CLEC,  PSIMS);  D.  1.2.1  (%  Interface  Availability    BST  &  CLEC,  ATLAS/  COFFI  );  and  for  D.  1.4.2.1  (Average  Response  Interval    CLEC  (TAG),  RSAG,  by  ADDR).  We  therefore 
 find  these  misses  to  be  isolated  and  not  indicative  of  a  downward  trend. 
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 BellSouth  states  that,  although  it  had  included  test  servers  in  the  interface  availability  measure  from  April  2001  to  November  2001,  it  has  corrected  this  problem  and  data  and  test  server  hours 
 are  no  longer  included  in  this  measure.  469  Due  to  this  correction,  we  find  that  this  problem,  as  well  as  AT&  Ts  assertions,  is  now  moot.  Moreover,  for  purposes  of  determining  BellSouths 
 compliance  with  checklist  item  2,  we  only  consider  data  for  the  relevant  period  (March  through  June).  We  also  note  that  the  performance  metrics  and  data  submitted  by  BellSouth  in  its 
 application  have  been  approved  by  the  state  commissions.  AT&  T  presents  no  evidence  in  its  comments  to  support  its  allegations  that  these  metrics  continue  to  include  back-  up  and  test 
 servers  or  that  BellSouth  is  not  accurately  reporting  its  performance.  Accordingly,  we  do  not  find  that  this  performance  warrants  a  finding  of  checklist  noncompliance.  Should  BellSouths 
 performance  in  this  area  deteriorate,  we  will  pursue  appropriate  enforcement  action. 
 138.  Birch  contends  that  BellSouths  placement  of  pending  service  orders  (PSOs)  on  customer  service  records  (CSRs)  adversely  impacts  competitors  using  BellSouths  pre-  ordering 


 functions.  470  Specifically,  Birch  states  that  PSOs  create  unnecessary  provisioning  delays  because  an  order  will  be  clarified  back  to  a  competitive  LEC  if  a  PSO  is  present  on  a  CSR.  471  Birch  also 
 asserts  that  BellSouths  OSS  systematically  inserts  unnecessary  PSOs  into  end-  user  CSRs  at  the  beginning  of  BellSouths  provisioning.  472  BellSouth  explains,  however,  that  its  systems  place  a 
 PSO  on  a  CSR  whenever  a  service  request  is  entered  into  BellSouths  ordering  systems,  including  a  conversion  request  from  a  competing  LEC  such  as  Birch.  473  In  addition,  although 
 Birch  suggests  that  BellSouth  is  intentionally  adding  false  PSOs  to  end-  user  CSRs  where  that  customer  has  chosen  to  switch  to  Birch,  nothing  in  the  record  substantiates  this  claim.  474  Rather, 
 BellSouth  investigated  the  two  examples  which  Birch  concluded  were  unexplained  and  found  that  the  PSOs  were  appropriately  placed.  475  Given  this  evidence,  we  do  not  find  that  BellSouth 
 fails  to  comply  with  this  checklist  item. 
 139.  We  also  reject  ITC^  DeltaComs  claim  that  BellSouth  does  not  provide  equivalent  access  to  information  concerning  PSOs  on  a  CSR.  476  Consistent  with  our  analysis  in  the 


 469  BellSouth  Varner  Reply  Aff.  at  para.  49.  BellSouth  also  states  that  there  was  no  significant  change  in  the 
 measurement  results  due  to  this  error.  BellSouth  Varner  Reply  Aff.  at  para.  49 
 470  Birch  Comments  at  16-  20. 


 471  Id.  at  16. 
 472  Id.  at  16-  19. 
 473  BellSouth  Reply  at  26;  BellSouth  Reply  App.,  Vol  1a,  Tab  A,  Reply  Affidavit  of  Ken  L.  Ainsworth 
 (BellSouth  Ainsworth  Reply  Aff.)  at  paras.  36-  37. 
 474  Although  Birch  cites  several  examples  of  PSOs  appearing  at  the  beginning  of  the  provisioning  process,  there 
 is  no  specific  evidence  indicating  that  these  accounts  were  targeted  by  BellSouth  retail  marketers.  See  Birch  Comments  at  16-  20. 


 475  BellSouth  also  found  that  the  PSOs  were  the  result  of  a  customer  request  or  Birch  acting  as  an  agent  for  its 
 customer.  BellSouth  Ainsworth  Reply  Aff.  at  paras.  36-  37. 
 476  ITC^  DeltaCom  Comments  at  1-  2. 
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 BellSouth  Georgia/  Louisiana  Order,  BellSouth  provides  a  PSO  flag  in  the  LENS  interface  to  alert  competitive  LECs  that  a  service  order  is  pending.  477  BellSouth  explains  that  PSO 
 information  is  proprietary  customer  information,  but  competitive  LECs  have  the  ability  to  track  the  details  of  pending  service  orders  for  their  own  customers  using  BellSouths  CSOTS.  478 
 Accordingly,  we  do  not  find  that  ITC^  DeltaComs  claim  warrants  a  finding  of  checklist  noncompliance. 


 140.  Covads  contention,  that  BellSouth  plans  to  discontinue  support  for  its  current  TAG  pre-  ordering  interface  prior  to  the  introduction  of  Electronic  Data  Interchange  (EDI) 
 support  for  pre-  ordering  functions  and  thereby  impose  additional  and  unnecessary  costs  on  Covad,  is  premature  and  thus  not  relevant  to  our  determination  here.  479  Specifically,  Covad 
 asserts  that  unless  the  Commission  requires  BellSouth  to  maintain  its  existing  TAG  interface  until  its  makes  its  EDI  interface  available  for  pre-  ordering  functions,  competitive  LECs  seeking 
 to  use  the  EDI  interface  for  pre-  ordering  will  have  to  migrate  from  the  TAG  interface  to  an  alternative  interface  only  to  migrate  again  to  the  EDI  interface.  480  Covads  claim  appears  to  be 
 inaccurate.  Under  BellSouths  current  plans,  no  competitive  carrier  would  have  to  transition  to  an  alternative  interface  prior  to  the  availability  of  an  EDI  pre-  ordering  interface.  481  We  therefore 
 reject  Covads  claim  and  do  not  find  that  it  warrants  checklist  noncompliance. 
 141.  Access  to  Loop  Qualification  Information.  We  find,  as  did  the  state  commissions,  482  that  BellSouth  provides  competitive  LECs  with  access  to  loop  qualification 


 information  consistent  with  the  requirements  of  the  UNE  Remand  Order.  483  Specifically,  we  find 
 477  The  Competitive  LEC  Service  Order  Tracking  System  (CSOTS)  alerts  competitive  LECs  to  the  presence  of  a 
 PSO  for  one  of  their  customers,  but  only  allows  the  competitive  LEC  access  to  the  actual  details  of  the  PSO  if  in  fact  the  PSO  was  placed  by  the  competitive  LEC.  See  ITC^  DeltaCom  Comments  at  1-  2  n.  1;  BellSouth  Ainsworth 


 Reply  Aff.  at  paras.  38-  39;  BellSouth  Stacy  Reply  Aff.  at  para.  170;  see  also  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9077  n.  392.  BellSouth  also  states  that  its  legacy  systems  are  common  to  both  retail  and  wholesale 
 competitive  LEC  services  and  need  to  be  accessed  by  both  BellSouth  retail  and  wholesale  representatives  to  handle  issues  dealing  with  an  order  already  in  progress.  See  BellSouth  August  14  OSS  and  Loops  Ex  Parte  Letter  at  7. 


 478  BellSouth  Ainsworth  Reply  Aff.  at  para.  39. 
 479  Covad  Comments  at  17.  The  TAG  gateway  allows  Covad  to  determine  at  the  pre-  ordering  stage  whether  or 
 not  it  can  provide  a  customer  with  the  DSL  services  that  they  want.  Id. 
 480  Covad  Comments  at  18. 


 481  BellSouth  explains  that  it  will  make  the  current  version  of  TAG  available  until  May  2003,  and  a  later  version 
 of  TAG  (scheduled  to  be  released  in  December  2002)  available  until  December  2003.  BellSouth  Stacy  Reply  Aff.  at  para.  174.  BellSouth  plans  to  make  EDI  support  for  pre-  ordering  available  in  March  2003,  before  BellSouth 


 discontinues  support  for  the  current  version  of  the  TAG  interface.  BellSouth  Stacy  Reply  Aff.  at  paras.  180-  81. 
 482  Alabama  Commission  Comments  at  211;  Kentucky  Commission  Comments  at  21;  Mississippi  Commission 
 Comments  at  3;  North  Carolina  Commission  Comments  at  132-  33;  South  Carolina  Commission  Comments  at  1-  3. 
 483  The  Commissions  rules  require  BellSouth  to  provide  competitors  with  access  to  all  loop  qualification 
 information  in  its  databases  or  internal  records  in  the  same  time  intervals  that  it  is  available  to  any  BellSouth  (continued.) 
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 that  BellSouth  provides  competitors  with  access  to  all  of  the  same  detailed  information  about  the  loop  that  is  available  to  itself  and  in  the  same  time  frame  as  any  of  its  personnel  could  obtain 
 it.  484 
 142.  Covad  claims  that  inaccuracies  in  the  loop  qualification  information  in  BellSouths  Loop  Facilities  Assignment  and  Control  System  (LFACS)  database  discriminate 


 against  competitive  LECs.  485  We  reject  this  argument.  The  Commission  has  never  required  incumbent  LECs  to  ensure  the  accuracy  of  their  loop  qualification  databases.  Instead,  the 
 Commission  requires  that,  to  the  extent  the  incumbent  LEC  has  compiled  loop  qualification  information  for  itself,  it  is  obligated  to  provide  competitive  LECs  with  nondiscriminatory  access 
 to  the  same  information.  486  Because  BellSouth  complies  with  this  requirement,  we  find  that  Covads  claims  regarding  the  alleged  inaccuracy  of  BellSouths  LFACS  database,  even  if  true, 
 do  not  warrant  a  finding  of  noncompliance  with  checklist  item  2.  487 
 143.  We  also  reject  Covads  claim  that  BellSouths  refusal  to  provide  it  with  sufficient  information  to  enable  its  technicians  to  locate  demarcation  points  for  the  UCL-  ND  warrants  a 


 finding  of  checklist  noncompliance.  488  The  record  makes  clear  that  BellSouths  records  typically  do  not  set  forth  the  precise  location  of  the  demarcation  point  for  a  given  loop.  489  Instead,  those 
 records  contain  more  general  information  that  BellSouths  technicians  are  able  to  access  to  help  them  locate  a  particular  demarcation  point.  490  BellSouth  states  that,  upon  request,  it  provides 
 Covad  with  the  same  general  information  regarding  the  location  of  demarcation  points  that  is 


 (Continued  from  previous  page)  personnel,  regardless  of  whether  BellSouth  personnel  actually  access  that  information.  See  UNE  Remand  Order,  15 
 FCC  Rcd  at  3885-  86,  paras.  427-  31. 
 484  See  BellSouth  Stacy  Aff.  at  paras.  241-  50;  BellSouth  Stacy  Reply  Aff.  at  paras.  185-  90;  see  also  Verizon 
 Massachusetts  Order,  15  FCC  Rcd  at  9016-  17,  para.  54. 
 485  Covad  Comments  at  23,  31-  32. 


 486  See  UNE  Remand  Order,  15  FCC  Rcd  at  3886,  para.  429. 
 487  We  note  that  BellSouth  disputes  Covads  allegation  that  BellSouths  LFACS  database  is  highly  inaccurate. 
 See  BellSouth  Stacy  Reply  Aff.  at  para.  185;  Covad  Comments  at  31-  32.  We  find  it  unnecessary  to  resolve  this  dispute  because,  as  BellSouth  has  shown,  competitive  LECs  have  nondiscriminatory  access  to  the  information  in 


 that  database. 
 488  Covad  Comments  at  24-  26.  Under  the  Commissions  rules,  a  demarcation  point  is  the  point  of  demarcation 
 and/  or  interconnection  between  the  communications  facilities  of  a  provider  of  wireline  telecommunications,  and  terminal  equipment,  protective  apparatus  or  wiring  at  a  subscriber's  premises.  47  C.  F.  R.    68.  3.  In  multi-  tenant 


 buildings,  demarcation  points  may  be  located  in  telecommunications  closets  or  equipment  rooms  where  numerous  loops  terminate  or  in  individual  office  suites  or  apartments.  47  C.  F.  R.    68.105(  b),  (d). 


 489  BellSouth  Application  Reply  App.,  Vol.  2,  Tab  F,  Reply  Affidavit  of  W.  Keith  Milner  (BellSouth  Milner 
 Reply  Aff.)  at  paras.  3-  4. 
 490  See  id.  at  para.  3. 
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 available  to  BellSouths  own  employees  and  in  the  same  timeframe.  491  Covad  thus  has  access  to  the  information  regarding  demarcation  point  locations  that  is  available  to  BellSouth  in 
 accordance  with  the  UNE  Remand  Order.  Therefore,  we  find  that  Covads  claim  does  not  raise  any  issue  regarding  checklist  noncompliance.  492 


 c.  Ordering 
 144.  In  this  section,  we  address  BellSouths  ability  to  provide  competing  carriers  with  access  to  the  OSS  functions  necessary  for  placing  wholesale  and  resale  orders.  We  find,  as  did 


 the  state  commissions,  493  that  BellSouth  provides  carriers  in  each  of  the  five  states  with  nondiscriminatory  access  to  its  ordering  systems.  In  the  following  discussion,  we  address  the 
 OSS  issues  primarily  in  dispute  in  this  application:  order  confirmation  notices;  reject  notices;  flow-  through;  order  completion  notices;  and  jeopardy  notices. 


 (i)  Order  Confirmation  Notices 
 145.  Based  on  the  evidence  in  the  record,  we  conclude,  as  did  the  state  commissions,  494  that  BellSouth  generally  provides  timely  order  confirmation  notices  to  competitive  LECs  in  each 


 of  the  five  states.  495  BellSouth  demonstrates  that  it  generally  meets  or  exceeds  the  relevant  benchmark  for  each  type  of  service  in  the  months  most  relevant  to  this  application.  496  During  the 


 491  BellSouth  Ainsworth  Reply  Aff.  at  para.  41;  BellSouth  Milner  Reply  Aff.  at  paras.  3-  4.  BellSouth  adds  that  it 
 is  currently  conducting  a  region-  wide  trial  under  which  it  will  provide  Covad  with  demarcation  point  locations  for  all  UCL-  ND  loops  even  if  their  provisioning  does  not  otherwise  require  a  dispatch.  BellSouth  Milner  Reply  Aff.  at 


 para.  6. 
 492  We  note  that  Covad  also  claims  that  BellSouths  practices  with  regard  to  demarcation  point  information 
 violate  BellSouths  interconnection  agreement  with  Covad.  Covad  Comments  at  25.  If  Covad  believes  that  BellSouths  practices  in  this  area  violate  these  parties  interconnection  agreement,  it  is  more  appropriate  for  Covad 


 to  seek  redress  before  the  state  commissions  under  section  252  of  the  Act  rather  than  in  this  proceeding. 
 493  Alabama  Commission  Comments  at  152-  61;  Kentucky  Commission  Comments  at  21-  27;  Mississippi 
 Commission  Comments  at  11;  North  Carolina  Commission  Comments  at  133-  39;  South  Carolina  Commission  Comments  at  1-  3. 


 494  See  Alabama  Commission  Comments  at  159;  Kentucky  Commission  Comments  at  21-  27;  Mississippi 
 Commission  Comments  at  11-  12;  North  Carolina  Commission  Comments  at  135-  36;  South  Carolina  Commission  Comments  at  1-  3. 


 495  BellSouth  submits  performance  data  showing  firm  order  confirmation  (FOC)  Timeliness  disaggregated  by: 
 (1)  fully  mechanized  orders  (i.  e.,  orders  that  flow  through);  (2)  partially  mechanized  orders  that  are  submitted  electronically  but  require  some  manual  processing;  and  (3)  manually  submitted  and  processed  orders.  See 


 BellSouth  Varner  Aff.  at  para.  170. 
 496  See  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  1.9  (FOC  Timeliness    Mechanized); 
 Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  1.  12  (FOC  Timeliness    Partially  Mechanized);  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  1.13  (FOC  Timeliness    Non-  Mechanized); 


 Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  A.  1.9  (FOC  Timeliness    Mechanized);  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  A.  1.12  (FOC  Timeliness    Partially  Mechanized); 
 Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  A.  1.13  (FOC  Timeliness    Non-  Mechanized). 
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 relevant  period,  BellSouth  met  or  exceeded  the  95  percent  within  the  three-  hour  standard  for  electronically  submitted  UNE-  P  orders  in  each  state  with  few  exceptions.  497  Similarly,  between 
 March  and  June,  BellSouth,  on  average,  met  or  exceeded  the  85  percent  within  10  hours  standard  for  partially  mechanized  orders  498  and  the  85  percent  within  36  hours  standard  for  non-mechanized 
 orders  on  all  product  types  with  one  exception.  499  For  resale  orders,  BellSouth  met  or  exceeded  the  relevant  benchmarks  for  almost  every  relevant  submetric.  500  Should  BellSouths 
 performance  in  this  area  deteriorate,  we  will  pursue  appropriate  enforcement  action. 
 146.  For  the  mechanized  and  partially  mechanized  firm  order  confirmation  (FOC)  timeliness  other  non-  design  category,  BellSouth  indicates  that  several  submetrics  fell  out  of 


 parity  when  BellSouth  switched  from  PMAP  2.6  to  4.0.  501  According  to  BellSouth,  the  primary  reason  for  the  failure  to  meet  the  benchmark  for  these  submetrics  is  an  erroneous  timestamp, 
 causing  certain  orders  to  appear  to  have  taken  too  long  to  process.  502  BellSouth  states  that  there  is  a  defect  in  PMAP  4.0  for  orders  submitted  via  LENS  that  occurs  when  the  FOC  and 
 completion  notice  both  are  issued  at  the  same  time.  503  Because  directory  listing  orders  are  generally  completed  at  about  the  same  time  the  FOC  is  returned,  this  problem  frequently  occurs 


 497  See  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  1.9  (FOC  Timeliness    Mechanized). 
 Specifically,  BellSouths  mechanized  FOC  timeliness  (other  design)  was  below  the  benchmark  in  Alabama  for  one  month  during  the  relevant  period.  See  Alabama  B.  1.9.14  (FOC  Timeliness    Mechanized,  Other  Design).  We  find 


 this  miss  to  be  an  exception  to  BellSouths  performance  and  not  indicative  of  a  downward  trend. 
 498  See  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  1.  12  (FOC  Timeliness    Partially 
 Mechanized    10  hours  ).  Specifically,  BellSouths  partially  mechanized  FOC  timeliness  for  UNE-  P  orders  was  below  the  benchmark  for  one  month  in  Alabama,  one  month  in  Kentucky,  and  one  month  in  South  Carolina.  See 


 Alabama/  Kentucky/  South  Carolina  B.  1.12.3  (FOC  Timeliness    Partially  Mechanized    10  hours,  Loop  +  Port  Combinations).  In  addition,  BellSouths  partially  mechanized  FOC  timeliness  (other  design)  was  below  the 
 benchmark  for  one  month  in  Alabama.  See  Alabama  B.  1.12.14  (FOC  Timeliness    Partially  Mechanized    10  hours,  Other  Design).  We  find  these  misses  to  be  isolated  and  not  indicative  of  a  downward  trend. 


 499  See  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  1.13  (FOC  Timeliness    Non-Mechanized). 
 Specifically,  BellSouths  non-  mechanized  FOC  timeliness  (other  design)  was  below  the  benchmark  for  one  month  in  Alabama.  See  Alabama  B.  1.13.14  (FOC  Timeliness    Non-  Mechanized,  Other  Design). 


 BellSouths  performance,  however,  was  less  than  two  percentage  points  below  the  benchmark. 
 500  See  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  A.  1.9  (FOC  Timeliness    Mechanized, 
 Resale);  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  A.  1.  12  (FOC  Timeliness    Partially  Mechanized    10  hours,  Resale);  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  A.  1.13  (FOC 


 Timeliness    Non-  Mechanized,  Resale).  Generally,  BellSouth  achieved  the  relevant  benchmark,  with  a  few  minor  exceptions.  Specifically,  BellSouths  partially  mechanized  FOC  timeliness  (residence)  was  below  the  benchmark 
 for  one  month  in  Kentucky  and  one  month  in  South  Carolina.  See  Kentucky/  South  Carolina  A.  1.12.1  (FOC  Timeliness    Partially  Mechanized    10  hours,  Residence).  BellSouths  performance,  however,  with  respect  to 
 these  measures,  was  less  than  four  percentage  points  below  the  benchmark. 
 501  See  BellSouth  Varner  Reply  Aff.  at  para.  159. 


 502  Id.  at  paras.  160-  162. 
 503  Id.  at  paras.  156-  61. 
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 in  the  mechanized  and  partially  mechanized  FOC  timeliness  other  non-  design  category,  which  is  comprised  almost  entirely  of  directory  listing  LSRs.  504  When  this  error  occurs,  the  timestamp  for 
 the  FOC  shown  was  at  times  erroneous  and  PMAP  was  fed  this  erroneous  data  to  calculate  FOC  timeliness.  505  BellSouth  has  provided  revised  data  for  each  of  the  states  and  generally  meets  the 
 benchmark  utilizing  the  correct  timestamp.  506  Accordingly,  based  on  BellSouths  overall  performance,  we  conclude  that  BellSouth  currently  provides  order  confirmation  notices  in  a 
 manner  that  provides  competitive  LECs  a  meaningful  opportunity  to  compete.  In  addition,  BellSouth  corrected  this  problem  with  its  10.6  release  on  August  24,  2002.  507  We,  therefore,  are 
 confident  that  this  issue  has  been  resolved.  We  also  note,  in  accordance  with  section  271(  d)(  6),  that  if  BellSouths  performance  in  this  area  deteriorates,  we  may  pursue  appropriate  enforcement 
 action. 
 147.  We  also  reject  AT&  Ts  claim  that  BellSouths  performance  in  providing  competitive  LECs  with  order  status  notices  is  inadequate  because  BellSouth  has  not  provided 


 them  in  a  timely,  accurate,  and  complete  manner.  508  Specifically,  AT&  T  claims  that,  on  average,  BellSouth  takes  eighteen  hours  to  return  a  FOC  or  reject  notice  for  electronically  submitted 
 LSRs  that  fall  out  for  manual  processing.  509  Because  the  record  evidence  of  BellSouths  performance  data  demonstrates  that  BellSouth  is  generally  meeting  the  relevant  benchmarks  for 
 this  measure,  and  since  AT&  T  has  not  explained  how  it  determined  this  eighteen-  hour 


 504  Id.  at  para.  162. 
 505  Id.  at  paras.  160-  61. 
 506  According  to  the  revised  data,  BellSouth  generally  met  the  relevant  benchmark.  Specifically,  BellSouths 
 mechanized  FOC  timeliness  (other  non-  design)  performance  was  below  the  benchmark  for  one  month  in  South  Carolina.  See  generally  South  Carolina  B.  1.9.15  (FOC  Timeliness    Mechanized,  Other  Non-  Design).  In  addition, 


 BellSouths  partially  mechanized  FOC  timeliness  (other  non-  design)  performance  data  show  that  it  was  below  the  benchmark  for  one  month  in  Alabama,  two  months  in  Kentucky,  one  month  in  Mississippi,  and  two  months  in 
 South  Carolina.  See  generally  Alabama/  Kentucky/  Mississippi/  South  Carolina  B.  1.12.15  (FOC  Timeliness    Partially  Mechanized    10  hours,  Other  Non-  Design).  Furthermore,  BellSouths  performance  in  this  area  generally 
 appears  to  be  improving.  See  BellSouth  Varner  Reply  Aff.  at  para.  163  &  BellSouth  Varner  Aff.  at  Exh.  PM-  28;  BellSouth  August  14  OSS  and  Loops  Ex  Parte  Letter  at  5-  6. 


 507  See  Letter  from  Glenn  T.  Reynolds,  Vice  President    Federal  Regulatory,  BellSouth,  to  Marlene  H.  Dortch, 
 Secretary,  Federal  Communications  Commission,  WC  Docket  No.  02-  150  at  7  (filed  Aug.  15,  2002)  (BellSouth  August  15  Non-  pricing  Ex  Parte  Letter);  Letter  from  Kathleen  B.  Levitz,  Vice  President    Federal  Regulatory, 


 BellSouth,  to  Marlene  H.  Dortch,  Secretary,  Federal  Communications  Commission,  WC  Docket  No.  02-  150  at  1  (filed  Sept.  9,  2002)  (BellSouth  September  9  Ex  Parte  Letter). 


 508  See  AT&  T  Comments  at  16. 
 509  Id.  at  16-  17.  AT&  T  notes  that  while  it  takes  18  hours  to  return  a  FOC  or  rejection  notice  for  a  partially 
 mechanized  order,  it  only  takes  15  minutes  to  return  a  FOC  or  rejection  notice  when  the  order  is  processed  electronically.  Thus,  AT&  T  claims  that  these  delays  will  result  in  the  assignment  of  later  due  dates  and 


 provisioning  delays  for  customers  whose  LSRs  are  processed  manually.  See  AT&  T  Bradbury/  Norris  Decl.  at  para.  105. 
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 timeframe,  or  its  relevance  to  our  analysis,  we  decline  to  make  a  finding  of  noncompliance  based  on  these  allegations. 
 148.  US  LEC  states  that  BellSouths  FOCs  fail  to  meet  the  requested  due  date  or  customer  desired  due  date.  510  Specifically,  US  LEC  contends  that  it  has  encountered  numerous 
 instances  of  blind  FOCs  where  the  competing  carrier  receives  an  order  confirmation  but  is  later  notified  that  facilities  are  not  available.  511  BellSouth,  however,  explains  that  when  it 
 receives  a  complete  and  corrected  LSR,  it  returns  a  FOC  and  checks  the  facilities  databases  to  determine  if  the  facilities  are  available  to  do  the  work.  512  Moreover,  BellSouth  claims  that  a 
 blind  FOC  could  be  issued  if  the  information  competitive  LEC  or  BellSouth  information  in  the  facilities  database  is  wrong  and  is  not  detected  until  the  due  date.  513  Therefore,  in  the  absence  of 
 further  evidence  indicating  systemic  discrimination  or  a  significant  anticompetitive  effect,  we  decline  to  find  that  this  assertion  warrants  a  finding  of  noncompliance. 


 (ii)  Order  Reject  Notices  and  Order  Rejections 
 149.  We  conclude,  as  did  the  state  commissions,  514  that  BellSouth  provides  competing  carriers  with  order  reject  notices  in  a  timely  and  nondiscriminatory  manner.  515  Although  we 


 recognize  BellSouth  has  failed  to  satisfy  the  benchmark  standard  for  mechanically  processed  reject  notices  in  each  of  the  states  for  several  submetrics,  we  find  that  BellSouths  overall 
 performance  is  nondiscriminatory.  516  According  to  BellSouth,  these  missed  submetrics  are 
 510  US  LEC  Comments  at  17. 
 511  Id.  at  17-  18. 
 512  See  BellSouth  August  14  OSS  and  Loops  Ex  Parte  Letter  at  7. 
 513  See  id. 
 514  See  Alabama  Commission  Comments  at  154-  59;  Kentucky  Commission  Comments  at  21-  27;  Mississippi 
 Commission  Comments  at  11-  12;  North  Carolina  Commission  Comments  at  136-  37;  South  Carolina  Commission  Comments  at  1-  3. 


 515  BellSouth  requests  that  the  Commission  not  rely  on  the  FOC  &  Reject  Response  Completeness  (Multiple 
 Responses)  metric  because  BellSouth  contends  that  it  does  not  provide  valuable  information  as  to  whether  a  particular  reject  or  response  was  appropriate  or  necessary.  See  BellSouth  Varner  Reply  Aff.  at  paras.  149-  50.  We 


 also  note  that  the  Commission  has  never  relied  on,  nor  do  the  state  commissions,  require  this  metric.  See  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9089-  90,  para.  140  n.  493.  Consistent  with  our  finding  in  the  BellSouth 
 Georgia/  Louisiana  Order,  we  believe  that  the  Reject  Interval  metric  provides  a  more  probative  evaluation  of  BellSouths  performance.  See  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  1.4  -  B.  1.8  (Reject 
 Interval). 
 516  Although  BellSouth  failed  to  meet  the  97%  in  one  hour  benchmark  for  mechanized  UNE  orders  for  several  of 
 the  submetrics  in  each  of  the  states,  we  note  that  BellSouths  performance  was  generally  within  six  percentage  points  of  the  benchmark  and  order  volumes  were  low.  See  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South 


 Carolina  B.  1.4  -  B.  1.8  (Reject  Interval).  There  were  no  major  deviations,  and  in  some  cases  performance  generally  improved,  during  the  relevant  period.  See  generally  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina 
 B.  1.4  (Reject  Interval    Mechanized);  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  A.  1.4  (Reject  Interval    Mechanized,  Resale).  The  most  significant  deviation  was  Alabama  B.  1.4.15  (Reject  Interval   
 (continued.) 
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 partially  the  result  of  the  over-  inclusion  of  certain  LSR  rejection  notices,  which  were  submitted  when  certain  BellSouth  legacy  systems  were  out  of  service  due  to  scheduled  down  time  for  OSS 
 maintenance.  517  BellSouth  claims,  and  we  agree,  that  such  LSRs  should  not  be  counted  in  the  measurement.  In  June,  BellSouth  implemented  a  coding  change  in  PMAP  to  ensure  that 
 scheduled  OSS  downtime  was  properly  excluded,  and  BellSouth  is  not  aware  of  any  remaining  problems.  518  AT&  T  also  alleges  that  BellSouth,  in  calculating  performance  results  for  rejected 
 mechanized  LSRs,  applies  exclusions  that  are  not  documented  in  BellSouths  SQM  or  the  Raw  Data  User  Manual.  519  BellSouth,  however,  notes  that  these  LSRs  are  included  in  the  Total 
 Mechanized  LSRs  category  in  the  Flow-  Through  Report.  520  Accordingly,  we  do  not  find  that  BellSouths  performance  warrants  a  finding  of  checklist  noncompliance.  Should  BellSouths 
 performance  in  this  area  deteriorate,  however,  we  may  pursue  appropriate  enforcement  action. 
 150.  Second,  BellSouth  demonstrates  that  it  provides  reject  notices  in  a  nondiscriminatory  manner  for  those  orders  that  require  partial  or  full  manual  processing. 


 Specifically,  BellSouth  met  the  benchmark  for  partially  mechanized  orders  with  only  minor  exceptions.  521  Moreover,  BellSouth  consistently  met  or  exceeded  the  benchmark  for  returning 


 (Continued  from  previous  page)  Mechanized,  Other  Non-  Design).  However,  as  discussed  below,  BellSouth  has  explained  that  such  deviations  were 
 due  to  the  improper  inclusion  of  certain  LSR  reject  notices  in  the  mechanized  design  and  non-  design  reject  intervals.  See  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  1.4.14  (Reject  Interval   
 Mechanized,  Other  Design);  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  1.4.15  (Reject  Interval    Mechanized,  Other  Non-  Design);  see  also  BellSouth  Varner  Reply  Aff.  at  paras.  155-  57. 


 517  See  BellSouth  Varner  Aff.  at  Exh.  PM-  2,  paras.  39-  44;  BellSouth  Varner  Reply  Aff.  at  para.  155;  Letter  from 
 Kathleen  B.  Levitz,  Vice  President    Federal  Regulatory,  BellSouth,  to  Marlene  H.  Dortch,  Secretary,  Federal  Communications  Commission,  WC  Docket  No.  02-  150  at  1  (filed  Aug.  20,  2002)  (BellSouth  August  20  Ex  Parte 


 Letter). 
 518  See  BellSouth  Varner  Reply  Aff.  at  paras.  155-  57.  BellSouth  has  also  explained  that  the  fully  mechanized 
 reject  interval  was  adversely  affected  when  a  FOC  was  followed  by  a  manual  clarification  and  the  LSR  erroneously  appeared  in  both  the  fully  mechanized  FOC  timeliness  and  reject  interval  measures.  In  this  case,  both  a  FOC  and  a 


 separate  reject  are  issued.  See  id.  at  para.  156.  Because  a  service  representative  cannot  claim  the  LSR  after  the  FOC  has  been  sent,  the  LSR  is  counted  as  fully  mechanized  and  appears  in  both  the  FOC  timeliness  and  reject 
 interval  metrics.  Id.  BellSouth  also  states  that  this  problem  overstates  the  time  required  for  BellSouths  fully  mechanized  reject  notice  and,  as  a  result,  understates  BellSouths  performance  of  the  timeliness  measure.  BellSouth 
 is  currently  working  to  develop  a  solution.  See  BellSouth  August  15  Non-  pricing  Ex  Parte  Letter  at  8.  In  addition,  BellSouth  states  that  there  is  also  a  LESOG  application  defect  that  affects  the  reject  interval  measure.  Currently  the 
 indicator  is  not  verified  in  the  LESOG  prior  to  the  issuance  of  FOC.  If  the  indicator  is  not  populated  on  orders  for  additional  lines,  the  order  is  manually  clarified  back  to  the  competitive  LEC.  See  BellSouth  Varner  Reply  Aff.  at 
 para.  157. 
 519  See  AT&  T  Bursh/  Norris  Decl.  at  paras.  44-  45. 


 520  See  BellSouth  Varner  Reply  Aff.  at  para.  42;  see  also  BellSouth  August  14  OSS  and  Loops  Ex  Parte  Letter  at 
 5. 
 521  Although  BellSouth  failed  to  meet  the  85%  within  10  hours  benchmark  for  UNE  and  resale  orders,  for  several 
 of  the  submetrics  in  each  of  the  states,  we  note  that  BellSouths  performance  data  show  that  it  was  generally  close  to  the  benchmark  or  order  volumes  were  low.  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  1.7 


 (Reject  Interval    Partially  Mechanized);  see  also  BellSouth  Application  at  82.  Specifically,  BellSouths  partially  (continued.) 
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 manually  processed  rejects.  522  Accordingly,  we  find  that  BellSouths  manual  reject  process  can  provide  competing  carriers  prompt  notice  that  an  order  has  encountered  a  problem,  and  the 
 opportunity  to  resolve  it  without  considerable  delay. 
 (iii)  Order  Flow-  Through  Rate 
 151.  We  conclude,  as  did  the  state  commissions,  523  that  BellSouths  OSS  are  capable  of  flowing  through  UNE  orders  in  a  manner  that  affords  competing  carriers  a  meaningful 


 opportunity  to  compete.  524  We  also  conclude  that  BellSouth  is  capable  of  flowing  through  resale  orders  in  substantially  the  same  time  and  manner  as  it  does  for  its  own  retail  customers.  525 
 Consistent  with  our  prior  section  271  orders,  we  emphasize  that  we  review  flow-  through  rates  as  one  of  several  factors  to  assess  the  BOCs  overall  ability  to  provide  access  to  its  ordering 
 functions  in  a  nondiscriminatory  manner.  526  Accordingly,  where  other  evidence  demonstrates  that  the  BOCs  OSS  are  able  to  process  competing  carriers  orders  at  reasonably  foreseeable 


 (Continued  from  previous  page)  mechanized  reject  interval  (other  non-  design)  was  below  the  benchmark  for  one  month  in  Alabama  and  one  month 
 in  South  Carolina.  In  Alabama,  BellSouths  performance  was  almost  13  percentage  points  below  the  benchmark  during  that  month  and  its  average  performance  was  over  91%  for  this  measure.  In  South  Carolina,  BellSouths 
 performance  was  only  1.43  percentage  points  below  the  benchmark  during  that  month  and  its  average  performance  was  over  93%  for  this  measure.  See  generally  Alabama/  South  Carolina  B.  1.7.3  (Reject  Interval    Partially 
 Mechanized    10  hours,  Loop  +  Port  Combinations).  BellSouths  partially  mechanized  reject  interval  (other  design)  performance  data  shows  that  BellSouth  missed  the  benchmark  for  two  months  in  Alabama,  one  month  in  Kentucky, 
 and  two  months  in  Mississippi.  These  missed  metrics,  however,  all  have  order  volumes  of  ten  or  less.  See  generally  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  1.7.14.  BellSouths  partially 
 mechanized  reject  interval  (other  non-  design)  was  below  the  benchmark  for  one  month  in  Alabama  and  two  months  in  North  Carolina.  These  missed  metrics,  however,  were  within  seven  percentage  points  of  the  benchmark.  See 
 generally  Alabama/  North  Carolina  B.  1.7.15.  (Reject  Interval    Partially  Mechanized    10  hours,  Non-  Design).  In  addition,  BellSouths  partially  mechanized  resale  reject  interval  (business)  performance  data  shows  that  it  missed 
 the  benchmark  in  North  Carolina  in  one  month.  This  miss,  however,  was  within  four  percentage  points  of  the  benchmark.  See  generally  North  Carolina  A.  1.7.2  (Reject  Interval    Partially  Mechanized    10  hours,  Business). 


 522  See  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  1.8  (Reject  Interval  -  Non-  Mechanized); 
 Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  A.  1.8  (Reject  Interval    Non-  Mechanized). 
 523  See  Alabama  Commission  Comments  at  155-  61;  Kentucky  Commission  Comments  at  23;  Mississippi 
 Commission  Comments  at  11-  12;  North  Carolina  Commission  Comments  at  137-  38;  South  Carolina  Commission  Comments  at  1-  3. 


 524  BellSouths  commercial  data  show,  on  the  average,  achieved  flow-  through  levels,  in  the  region  for  UNEs,  of 
 74.11%.  See  F.  1.2.5  (%  Flow-  Through  Service  Requests  -  Achieved,  UNE).  BellSouths  performance  data  for  the  percent  flow-  through  service  requests  metric  demonstrated  an  average  monthly  83.69%  total  flow-  through  for 


 UNEs  in  its  region.  See  F.  1.1.5  (%  Flow-  Through  Service  Requests,  UNE). 
 525  See  F.  1.1.3  (%  Flow-  Through  Service  Requests,  Residence);  F.  1.1.4  (%  Flow-  Through  Service  Requests, 
 Business). 
 526  These  factors  include  the  BOCs  ability  to:  (1)  accurately  process  manually  handled  orders;  (2)  timely  return 
 order  confirmations  and  reject  notices;  and  (3)  the  overall  scalability  of  its  systems  and  processes.  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9092-  93,  para.  143.  See  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at 


 4034-  35,  paras.  161-  63;  SWBT  Texas  Order,  15  FCC  Rcd  at  18443-  44,  para.  179. 
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 commercial  volumes,  it  is  not  necessary  to  focus  our  analysis  solely  on  flow-  through  rates.  527  BellSouth  demonstrates  that  it  provides  timely  order  confirmation  and  reject  notices  for  all 
 orders.  The  evidence  in  the  record  also  demonstrates  that  BellSouth  accurately  processes  both  manual  and  mechanized  orders.  Further,  BellSouths  system  is  scalable  to  handle  increased 
 volumes. 
 152.  We  have  previously  stated  that  a  BOCs  ability  to  flow-  through  orders  at  high  rates  is  dependent,  in  part,  on  the  performance  of  competing  carriers  to  place  orders 


 electronically.  528  We  find  it  particularly  informative  that  several  competing  carriers  are  achieving  much  higher  flow-  through  rates  than  other  carriers.  Specifically,  data  regarding  UNE 
 orders  shows  that  the  flow-  through  rates  of  the  top  five  competitive  LECs  range  from  77.06  percent  to  94.64  percent  for  the  first  quarter  of  2002.  529  In  addition,  flow-  through  rates  for  three 
 of  these  competitive  LECs  range  from  90.19  percent  to  94.64  percent  during  the  first  quarter.  530  During  the  second  quarter  of  2002,  data  regarding  UNE  orders  shows  that  the  flow-  through  rates 
 of  the  top  five  competitive  LECs  range  from  75.50  percent  to  95.10  percent.  531  The  flow-  through  rates  for  three  of  these  competitive  LECs  range  from  85.80  percent  to  95.10  percent  during  the 
 second  quarter.  532  This  evidence  indicates  that  BellSouths  systems  are  capable  of  flowing  through  UNE  orders  in  a  manner  that  allows  competitive  carriers  a  meaningful  opportunity  to 
 compete.  In  fact,  BellSouth  states  that  an  analysis  of  the  March  Percent  Flow-  Through  Service  Requests  (aggregate  detail)  report  reveals  that  246  users  experienced  flow-  through  rates  in 
 excess  of  90  percent.  533  In  June  2002,  277  users  experienced  flow-  through  rates  in  excess  of  90  percent.  534  Because  the  record  demonstrates  that  a  number  of  competitive  LECs  experience  high 


 527  See  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  4034,  para.  162  (stating  that  [  f]  low  through  rates  .  .  .  are 
 not  so  much  an  end  in  themselves,  but  rather  are  a  tool  used  to  indicate  a  wide  range  of  possible  differences  in  a  BOCs  OSS  that  may  deny  an  efficient  competitor  a  meaningful  opportunity  to  compete.). 


 528  See  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  4038-  39,  para.  166;  BellSouth  Georgia/  Louisiana  Order,  17 
 FCC  Rcd  at  9093,  para.  145. 
 529  See  BellSouth  Stacy  Aff.  at  para.  284. 


 530  See  id. 
 531  BellSouth  August  20  Ex  Parte  Letter  at  2. 
 532  Id. 
 533  BellSouth  Stacy  Aff.  at  para.  285;  BellSouth  Application  at  84.  We  note  that  BellSouth  uses  the  term  user, 
 instead  of  competitive  LEC,  when  referring  to  a  horizontal  line  of  data  represented  on  the  Flow-  Through  Report,  because  each  line  of  data  represents  an  Operating  Company  Number  (OCN)  and  some  competitive  LECs  have 


 multiple  OCNs.  Thus,  on  a  flow-  through  report,  two  or  more  users  may  represent  a  competitive  LECs  data.  BellSouth  Stacy  Aff.  at  n.  41.  In  addition,  39  of  these  users  electronically  submitted  in  excess  of  1,000  LSRs  and  80 
 users  submitted  between  100  and  999  LSRs.  See  BellSouth  Application  at  84;  BellSouth  Stacy  Aff.  at  para.  285.  In  May  2002,  39  users  that  submitted  more  than  1,000  LSRs  experienced  flow-  through  rates  of  90%  or  higher.  See 
 BellSouth  Reply  at  20;  BellSouth  Stacy  Reply  Aff.  at  paras.  151-  52. 
 534  In  addition,  47  of  these  users  submitted  in  excess  of  1,000  LSRs  and  85  users  submitted  between  100  and  999 
 LSRs.  See  BellSouth  August  20  Ex  Parte  Letter  at  3. 
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 flow-  through  rates,  we  conclude  that  it  is  inappropriate  to  attribute  the  wide  range  of  flow-through  results  entirely  to  BellSouth.  535  As  the  Commission  previously  stated,  a  BOC  is  not 
 accountable  for  orders  that  fail  to  flow  through  due  to  competing  carrier-  caused  errors.  536  Our  conclusion  that  BellSouths  OSS  are  capable  of  achieving  high  flow-  through  level  is  further 
 bolstered  by  KPMGs  Georgia  testing.  537 
 153.  We  note  that  we  have  previously  determined  that  BellSouths  OSS  are  sufficiently  scalable  to  handle  reasonably  foreseeable  commercial  volumes  of  orders  in  a  nondiscriminatory 


 manner.  538  Because  BellSouth  has  demonstrated  the  ability  to  handle  competitive  LEC  order  volumes  in  a  nondiscriminatory  manner,  even  as  order  volumes  increase,  we  are  persuaded  that 
 BellSouths  OSS  are  sufficiently  scalable  to  process  increases  in  competitive  LEC  order  volumes  in  the  foreseeable  future.  As  a  result,  in  this  application,  flow-  through  performance  has  less 
 value  as  an  indicator  of  deficiencies  in  OSS.  539 
 154.  Although  AT&  T  makes  several  claims  regarding  the  manual  nature  of  BellSouths  OSS,  540  we  find  that  AT&  Ts  concerns  regarding  BellSouths  flow-  through 


 performance  are  addressed  by  the  record  evidence,  cited  above,  demonstrating  that  BellSouth  is  capable  of  flowing  through  competitive  LEC  orders.  541  Additionally,  we  note  that  BellSouth  has 


 535  Should  BellSouths  performance  in  this  area  deteriorate,  we  will  pursue  appropriate  enforcement  action. 
 536  See  Second  BellSouth  Louisiana  Order,  13  FCC  Rcd  at  20674,  para.  111;  Bell  Atlantic  New  York  Order,  15 
 FCC  Rcd  at  4039-  40,  4049,  paras.  167,  181;  Verizon  Massachusetts  Order,  16  FCC  Rcd  at  9030-  31,  para.  78. 
 537  The  KPMG  test  evaluated  the  calculation  of  the  flow-  through  percentages  produced  by  BellSouth  for 
 competitive  LEC  activities  for  the  months  of  September,  October,  and  November  1999,  and  for  the  transactions  of  the  test  competitive  LEC  established  by  KPMG.  The  test  utilized  raw  data  to  calculate  flow-  through  and  fallout 


 statistics  and  compared  the  data  used  in  those  calculations  to  the  data  collected  by  KPMG.  See  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9093,  para.  145. 


 538  See  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9097,  para.  152. 
 539  Consistent  with  our  prior  section  271  orders,  we  do  not  review  flow-  through  measures  as  an  end  in  and  of 
 itself,  but  as  one  of  several  factors  that  we  review  to  assess  the  BOCs  overall  ability  to  provide  access  to  its  ordering  functions  in  a  nondiscriminatory  manner.  See  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9092- 


 93,  para.  143;  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  4034-  35,  paras.  161-  63;  SWBT  Texas  Order,  15  FCC  Rcd  at  18443-  44,  para.  179. 


 540  AT&  T  Comments  at  16;  AT&  T  Bursh/  Norris  Decl.  at  paras.  77-  81;  AT&  T  Reply  at  16-  17.  Specifically, 
 AT&  T  contends  that  BellSouths  reliance  on  manual  processing  delays  the  processing  of  orders  of  competitive  LEC  customers  and  increases  the  risk  of  errors  in  provisioning.  See  AT&  T  Reply  at  16-  17 


 541  BellSouth  states  that  between  June  2001  and  June  2002,  its  residential  resale,  business  resale,  and  UNE  flow-through 
 performance  has  improved,  and  that  its  UNE-  P  flow-  through  has  remained  steady,  despite  a  sharp  increase  in  ordering  volumes.  See  BellSouth  Reply  at  19;  BellSouth  Stacy  Reply  Aff.  at  paras.  112,  144-  49.  Although  the 


 regional  LNP  flow-  through  performance  dropped  slightly  in  June  2002,  BellSouth  explains  that  that  is  not  a  result  of  a  deterioration  of  BellSouths  capabilities,  but  rather,  stems  from  BellSouths  compliance  with  a  Florida 
 Commission  order,  requiring  BellSouth  to  perform  a  facilities  check  before  the  issuance  of  a  FOC.  BellSouth  Reply  at  19;  BellSouth  Stacy  Reply  Aff.  at  paras.  114-  15. 
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 continued  to  participate  in  the  Flow-  Through  Task  Force  established  by  the  Georgia  Commission  to  ensure  continued  compliance  with  the  benchmarks  and  to  develop  flow-  through 
 enhancements.  542  BellSouth  asserts  that  of  the  35  issues  identified  by  the  Task  Force,  31  have  previously  been  addressed  and  the  remaining  4  were  addressed  in  release  10.6  during  the 
 weekend  of  August  24-  25,  2002.  543  We  also  reject  AT&  Ts  claim  that  BellSouth  erroneously  calculates  flow-  through,  since,  as  we  already  determined  in  the  BellSouth  Georgia/  Louisiana 
 Order,  KPMG  evaluated  the  calculation  of  the  flow-  through  percentages  produced  by  BellSouth  for  competitive  LEC  activities  and  found  no  such  errors.  544  Moreover,  we  note  that  the  Florida 
 Commission  recently  ordered  double  SEEMS  penalties  if  BellSouth  does  not  meet  its  flow-through  benchmarks.  545  AT&  T,  however,  claims  that  the  new  penalties  are  inadequate  and  that 
 the  state  commissions  may  not  take  the  necessary  actions  to  improve  flow-  through  rates.  546  The  alleged  inadequacy  of  the  Florida  SEEMS  penalties,  however,  is  not  decisional  to  our  analysis  of 
 the  current  application.  Accordingly,  we  do  not  find  that  AT&  Ts  claims  warrant  a  finding  of  checklist  noncompliance. 


 155.  Finally,  Covad  expresses  concerns  regarding  the  manual  nature  of  BellSouths  OSS.  547  First,  Covad  contends  that  BellSouth  improperly  designs  its  systems  so  that  orders  fall 
 out  by  design  or  cannot  be  ordered  electronically.  548  Second,  Covad  asserts  that  a  high  portion  of  its  orders  submitted  electronically  are  falling  out  to  manual  handling  primarily  due  to  BellSouth 
 error.  549  We  reject  Covads  arguments.  Rather,  we  find,  as  we  did  in  BellSouth  Georgia/  Louisiana  Order,  that  BellSouth  properly  designs  its  systems  to  minimize  the  number  of 
 orders  that  are  processed  manually.  550  Moreover,  as  of  June  30,  2002,  competitive  LECs  had  only  636  UCL-  ND  in  service  region-  wide.  551  Additionally,  BellSouth  states  that  it  has  completed 


 542  See  BellSouth  Reply  at  20;  BellSouth  Stacy  Reply  Aff.  at  para.  153. 
 543  BellSouth  Application  at  85;  BellSouth  Stacy  Aff.  at  paras.  286-  87  &  Exh.  WNS-  49;  BellSouth  Stacy  Reply 
 Aff.  at  para.  153;  BellSouth  August  20  Ex  Parte  Letter  at  4;  BellSouth  September  9  Ex  Parte  Letter  at  1.  In  addition,  BellSouths  June  2002  data  reflects  the  fact  that  it  has  recently  implemented  a  number  of  coding  changes 


 to  enhance  flow-  through.  BellSouth  Reply  at  20;  BellSouth  Stacy  Reply  Aff.  at  paras.  15-  52. 
 544  KPMG  evaluated  the  calculation  of  the  flow-  through  in  its  Georgia  test,  utilized  raw  data  to  calculate  flow-through 
 and  fall  out  statistics,  and  compared  the  data  used  in  those  calculators  to  the  data  collected  by  KPMG.  See  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9093,  para.  145. 


 545  BellSouth  Stacy  Reply  Aff.  at  paras.  138-  43;  AT&  T  August  23  OSS  and  Data  Integrity  Ex  Parte  Letter  at  4. 
 546  AT&  T  August  23  OSS  and  Data  Integrity  Ex  Parte  Letter  at  4. 
 547  Covad  Comments  at  7-  17. 
 548  Id.  at  9-  10 
 549  Id.  at  10-  11. 
 550  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9095,  para.  149. 
 551  BellSouth  Stacy  Reply  Aff.  at  para.  214.  LSRs  for  UCL-  ND,  according  to  BellSouth,  represent  only  0.34%  of 
 all  manual  LSRs  submitted  and  0.  02%  of  all  LSRs  submitted.  See  BellSouth  August  20  Ex  Parte  Letter  at  4. 
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 only  nine  orders  for  xDSL  and  only  525  orders  for  line  sharing  requiring  loop  conditioning  for  January  though  May  region-  wide.  552  Given  the  fact  that  the  total  number  of  these  types  of  loops 
 in  each  of  the  states  is  low,  553  and  our  finding  in  the  BellSouth  Georgia/  Louisiana  Order  that  a  high  percentage  of  loops  can  be  ordered  electronically,  we  cannot  agree  with  Covad  that 
 BellSouths  ordering  systems  deny  carriers  a  meaningful  opportunity  to  compete.  554  Although  not  decisional  to  our  analysis,  BellSouth  acknowledges  that  it  does  not  currently  offer  electronic 
 ordering  of  ADSL-  compatible  or  Line  Sharing  loops  with  conditioning.  555  BellSouth,  however,  implemented  electronic  ordering  of  UCL-  ND  on  August  24,  2002,  556  and  will  implement  full 
 flow-  through  of  UCL-  ND  on  December  7,  2002.  557 
 (iv)  Order  Completion  Notices 
 156.  We  conclude,  as  did  the  state  commissions,  558  that  BellSouth  generally  provides  completion  notices  to  competitive  LECs  in  a  nondiscriminatory  manner.  Based  on  the  level  of 


 BellSouths  performance  in  the  most  recent  months  performance  data,  we  conclude  that  BellSouth  provides  completion  notices  in  a  manner  that  provides  competitive  LECs  a  meaningful 
 opportunity  to  compete.  559  AT&  T,  however,  alleges  that  4,174  completion  notices  reflected  in  BellSouths  March  2002  Average  Completion  Notice  Interval  (ACNI)  raw  data  file  were  not 
 included  in  BellSouths  March  2002  Order  Completion  Interval  (OCI)  raw  data  files.  560  Although  BellSouth  was  able  to  locate  all  of  the  orders  identified  by  AT&  T  in  the  OCI  raw  data 


 552  BellSouth  Stacy  Reply  Aff.  at  para.  215. 
 553  For  example,  as  of  June  30,  2002,  there  were  a  total  of  605  UCL-  ND  loops  in  service  region-  wide,  with  26  in 
 Alabama,  18  in  Kentucky,  214  in  Mississippi,  80  in  North  Carolina,  and  zero  in  South  Carolina.  See  BellSouth  August  14  Ex  Parte  OSS  and  Loops  Letter  at  2-  3. 


 554  See  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9096,  para.  150.  In  addition,  BellSouth  has 
 participated  in  numerous  collaborative  sessions  to  discuss  possible  solutions  to  Covads  requests.  See  BellSouth  Stacy  Reply  Aff.  at  paras.  220-  21. 


 555  BellSouth  Stacy  Reply  Aff.  at  para.  220. 
 556  BellSouth  September  9  Ex  Parte  Letter  at  1. 
 557  BellSouth  Stacy  Reply  Aff.  at  para.  220 
 558  See  Alabama  Commission  Comments  at  153,  Kentucky  Commission  Comments  at  23-  24;  Mississippi 
 Commission  Comments  at  11-  12;  North  Carolina  Commission  Comment  at  140-  41;  South  Carolina  Commission  Comments  at  1-  3. 


 559  There  were  only  minor  disparities  in  BellSouths  performance.  These  disparities  were  generally  between 
 0.12%  and  0.32%.  See  North  Carolina  B.  2.21.3.1.2  (Average  Completion  Notice  Interval    Mechanized,  Loop  +  Port  Combinations/<  10  Circuits/  Non-  Dispatch);  Alabama/  North  Carolina/  South  Carolina  B.  2.21.3.1.4  (Average 


 Completion  Notice  Interval    Mechanized,  Loop  +  Port  Combinations/<  10  Circuits/  Dispatch).  Thus,  these  misses  are  not  indicative  of  a  persistent  problem.  See  BellSouth  Application  at  87-  88;  BellSouth  Varner  Aff.  at  Exhs.  PM-2 
   PM-  5,  para.  53. 
 560  See  AT&  T  Bursh/  Norris  Decl.  at  para.  39;  AT&  T  August  23  OSS  and  Data  Integrity  Ex  Parte  Letter  at  6. 
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 file,  BellSouth  identified  a  defect  that  caused  incomplete  OCI  raw  data  files  to  be  downloaded  from  the  PMAP  website.  BellSouth  states,  however,  that  this  problem  only  occurred  in  March 
 and  had  no  effect  on  performance  data.  561  Given  this  evidence,  and  recognizing  that  BellSouth  met  or  exceeded  parity  with  the  relevant  retail  analogue  with  only  minor  disparities  during  the 
 relevant  period,  we  do  not  find  that  AT&  Ts  claims  warrants  a  finding  of  checklist  noncompliance.  Finally,  we  note  that  this  defect  has  been  corrected  and  BellSouth  provided 
 AT&  T  with  a  complete  March  2002  OCI  raw  data  file  in  July  2002.  562  Should  we  later  find  evidence  to  the  contrary,  however,  we  may  pursue  appropriate  enforcement  action. 


 157.  AT&  T  also  contends  that  the  multiple  fix  dates  which  BellSouth  has  provided  for  the  ACNI  are  confusing  when  orders  are  completed  in  one  month,  but  the  completion  notice  is 
 issued  in  another.  563  BellSouth  states  that  this  AT&  T  concern  refers  to  another  enhancement  from  a  Tennessee  discovery  request  that  BellSouth  originally  indicated  would  be  implemented  in 
 July.  564  We  do  not  address  this  issue  because  the  Tennessee  discovery  request  is  not  relevant  to  the  five  states  under  review  in  this  application.  Therefore,  we  do  not  find  that  these  allegations 
 warrant  a  finding  of  checklist  noncompliance. 
 (v)  Jeopardy  Notices 
 158.  We  conclude,  as  did  the  state  commissions,  565  that  BellSouth  provides  jeopardy  notices  to  competitive  LECs  on  a  nondiscriminatory  basis.  566  Based  on  the  level  of  BellSouths 


 performance  in  the  most  recent  months  performance  data,  we  conclude  that  BellSouth  provides  jeopardy  notices  in  a  manner  that  provides  competitive  LECs  a  meaningful  opportunity  to 
 compete.  567  AT&  T,  however,  alleges  that  BellSouth  unilaterally  excludes  jeopardy  notices  from  its  reporting  for  those  orders  that  fall  into  jeopardy  status  in  one  month  but  receive  a  notice  in  the 


 561  See  BellSouth  Varner  Reply  Aff.  at  para.  33.  BellSouth  explains  that  all  orders  were  correct  as  stated  and  that 
 all  orders  completed  in  March  2002  were  included  in  the  measurement.  See  BellSouth  August  20  Ex  Parte  Letter  at  4.  In  addition,  BellSouth  states  that  specific  service  representatives  within  its  Work  Management  Centers  have  been 


 assigned  to  resolve  any  completion  issues  that  required  attention.  See  BellSouth  Application  at  88. 
 562  See  BellSouth  Varner  Reply  Aff.  at  para.  33 


 563  See  AT&  T  Bursh/  Norris  Decl.  at  para.  43. 
 564  See  BellSouth  Varner  Reply  Aff.  at  para.  41.  This  change,  however,  has  yet  to  be  scheduled  and  BellSouth 
 has  amended  its  Tennessee  discovery  request  accordingly. 
 565  See  Alabama  Commission  Comments  at  162;  Kentucky  Commission  Comments  at  23-  24;  Mississippi 
 Commission  Comments  at  11-  12;  North  Carolina  Commission  Comment  at  138;  South  Carolina  Commission  Comments  at  1-  3. 


 566  See  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  2.8  (Average  Jeopardy  Notice  Interval  -Mechanized); 
 Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  2.9  (Average  Jeopardy  Notice  Interval  -  Non-  Mechanized).  See  also  BellSouth  Varner  Aff.  at  Exh.  PM-  2,  para.  55  . 


 567  See  BellSouth  Application  at  88-  89;  BellSouth  Varner  Aff.  at  Exh.  PM-  2,  para.  55. 
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 next  month,  causing  inaccurate  data.  568  BellSouth  explains  that  in  a  very  small  number  of  cases,  if  a  jeopardy  notice  is  issued  in  a  different  month  than  the  due  date,  the  order  cannot  be  counted 
 in  this  measure.  569  BellSouth  adds  that  the  average  jeopardy  notice  interval  was  not  relied  upon  until  March  2002,  and  that  this  issue  was  corrected  with  April  2002  data.  570  With  its  April  2002 
 data,  under  PMAP  4.0,  BellSouth  states  that  jeopardy  notices  associated  with  such  orders  are  reflected  in  the  data  for  the  month  in  which  the  due  date  occurs.  571  Given  this  evidence,  and 
 recognizing  that  BellSouth  met  or  exceeded  parity  with  the  relevant  retail  analogue  for  all  relevant  submetrics  with  data  reported,  we  do  not  find  that  AT&  Ts  claims  warrant  a  finding  of 
 checklist  noncompliance.  Should  we  later  find  evidence  to  the  contrary,  however,  we  may  pursue  appropriate  enforcement  action. 


 (vi)  Service  Order  Accuracy 
 159.  We  find,  as  did  the  state  commissions,  572  that  BellSouth  accurately  processes  manual  and  electronic  orders.  We  reject  AT&  Ts  claims  concerning  BellSouths  ability  to 


 accurately  process  manual  and  electronic  orders.  573  Although  BellSouth  failed  to  meet  the  benchmarks  for  several  months  during  the  relevant  period,  we  do  not  find  that  this  performance 
 warrants  a  finding  of  checklist  noncompliance.  574  We  find  that  these  missed  benchmarks  are  exceptions  to  BellSouths  performance  and  not  indicative  of  a  downward  trend.  BellSouth  also 
 explains  that  it  continues  to  dedicate  additional  resources  in  its  local  carrier  service  center  (LCSC)  to  review  live  orders  to  ensure  accuracy  in  the  provisioning  of  competitive  LEC  orders. 


 568  See  AT&  T  Bursh/  Norris  Decl.  at  paras.  57-  58. 
 569  See  BellSouth  Varner  Reply  Aff.  at  para.  50. 
 570  Id. 
 571  See  BellSouth  August  20  Ex  Parte  Letter  at  5.  BellSouth  explains,  that  prior  to  the  implementation  of  PMAP 
 4.0,  in  April  2002,  if  an  order  went  to  jeopardy  status  in  one  month  and  had  a  due  date  in  a  subsequent  month,  PMAP  did  not  have  the  beginning  timestamp  when  it  attempted  to  calculate  the  interval  in  the  month  of  the  due 


 date.  Id.  As  a  result,  the  notice  was  not  reflected  in  either  month.  BellSouth  also  notes  that  this  situation  occurred  very  infrequently.  Id. 


 572  See  Alabama  Commission  Comments  at  163;  Kentucky  Commission  Comments  at  21;  Mississippi 
 Commission  Comments  at  11-  12;  North  Carolina  Commission  Comments  at  133-  34;  South  Carolina  Commission  Comments  at  1-  3. 


 573  Specifically,  AT&  T  contends  that  BellSouths  reported  service  order  accuracy  rates  have  frequently  missed 
 the  applicable  benchmarks  in  recent  months,  particularly  for  resale  orders.  See  AT&  T  Comments  at  16. 
 574  See  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  2.34  (UNE  Service  Order  Accuracy   
 Regional);  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  A.  2.25  (Resale  Service  Order  Accuracy    Regional).  Specifically,  BellSouths  regional  UNE  service  order  accuracy  measures  were  89.91%  in  April;  67.07% 


 in  May;  and  ranged  from  69.33%  to  90.9%  in  June.  There  were  no  misses  in  March.  In  addition,  BellSouths  regional  resale  service  order  accuracy  measures  ranged  from  84.62%  to  93.85%  in  March;  77.78%  to  94.29%  in 
 April;  77.  78%  to  92.  59%  in  May;  and  76.  9%  to  94.  4%  in  June.  We  find,  nevertheless,  that  BellSouths  performance  is  within  the  range  of  what  we  approved  in  the  BellSouth  Georgia/  Louisiana  Order.  See  BellSouth 
 Reply  at  22;  BellSouth  Stacy  Reply  Aff.  at  para.  122. 
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 BellSouth  has  also  developed  corrective  action  plans  for  any  service  representatives  that  are  not  meeting  their  requirements.  575  Should  BellSouths  performance  in  this  area  deteriorate,  we  will 
 pursue  appropriate  enforcement  action. 
 160.  AT&  T  states  that  the  service  order  accuracy  data  submitted  by  BellSouth  in  its  July  23,  2002  ex  parte  letter  are  unreliable  due  to  inconsistencies  with  BellSouths  reported 


 data.  576  According  to  BellSouth,  however,  AT&  T  quoted  figures  from  the  wrong  MSS.  577  BellSouth  also  states  that  a  reason  for  the  difference  between  completed  service  orders  as  shown 
 on  the  MSS  and  the  population  tabulated  in  the  service  order  accuracy  report  is  due  to  several  large  conversions  in  UNE-  P  in  Georgia  and  Florida  that  were  completed  during  this  period.  578 
 Nevertheless,  BellSouth  maintains  that  the  number  of  orders  that  BellSouth  evaluated  is  more  than  sufficient  to  assess  performance.  579  Additionally,  BellSouth  states  that  AT&  T  miscalculated 
 the  accuracy  rate  for  the  non-  mechanized  resale  residence  submetric,  580  without  regard  for  the  fact  that  the  accuracy  rate  varies  for  each  disaggregation.  581  Accordingly,  given  this  evidence, 
 we  do  not  find  that  these  allegations  warrant  a  finding  of  checklist  noncompliance. 
 (vii)  Other  Ordering  Issues 
 161.  DSL  USOC.  We  reject  claims  that  BellSouth  has  created  a  significant  impediment  to  ordering  UNE-  P  by  placing  erroneous  DSL  universal  service  order  codes 


 (USOCs)  on  the  CSR  in  an  effort  to  delay  competitors  orders.  582  Specifically,  Birch  argues  that  BellSouth  virtually  crams  a  customers  CSR  with  the  DSL  USOC,  and  that  BellSouths 


 575  BellSouth  Varner  Reply  Aff.  at  para.  181.  BellSouth  notes  that  it  inadvertently  reversed  the  labels  for  the 
 mechanized  and  non-  mechanized  data.  Despite  this  error,  BellSouth  states  that  AT&  T  listed  the  correct  data  in  its  filing.  See  id.  at  para.  58;  BellSouth  August  20  Ex  Parte  Letter  at  5-  6. 


 576  AT&  T  Comments  at  16;  AT&  T  Bradbury/  Norris  Decl.  at  paras.  97-  98;  AT&  T  Reply  at  17;  AT&  T 
 Bursh/  Norris  Decl.  at  paras.  82-  87.  For  example,  AT&  T  claims  that  the  universe  of  completed  service  orders  in  the  ex  parte  appears  to  be  grossly  understated.  See  AT&  T  Reply  at  17.  AT&  T  claims  that  the  total  number  of 


 completed  service  orders  is  inconsistent  with  BellSouths  MSS  report  listing  such  orders  for  the  same  time  frame.  Id. 


 577  See  BellSouth  Varner  Reply  Aff.  at  para.  56. 
 578  See  id. 
 579  Id. 
 580  See  BellSouth  August  20  Ex  Parte  Letter  at  6. 
 581  See  BellSouth  Varner  Reply  Aff.  at  para.  53.  BellSouth  explains  that  that  the  accuracy  rate  for  this  submetric 
 is  the  average  accuracy  rate  for  the  four  product  dissagregations  that  compose  the  submetric.  See  BellSouth  August  20  Ex  Parte  Letter  at  6 


 582  Birch  Comments  at  4-  13,  Attach.  1. 
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 interim  process  583  for  removing  DSL  USOCs  is  inefficient  and  delays  conversions.  584  KMC  and  NuVox  claim  that  BellSouth  requires  that  its  USOC  for  DSL  service  be  removed  from  an  end 
 users  retail  account  prior  to  acceptance  of  a  competitive  LECs  order.  585  In  addition,  commenters  contend  that  BellSouths  representation  regarding  the  actual  impact  of  the  DSL 
 USOC  issue  is  flawed  and  that  erroneous  DSL  USOCs  are  subtle  ways  for  BellSouth  to  prevent  competitors  from  ever  providing  local  service  on  par  with  BellSouth.  586 


 162.  Consistent  with  the  BellSouth  Georgia/  Louisiana  Order,  we  find  that  the  DSL  USOC  issue  affects  a  small  amount  of  orders,  and  commenters  have  not  submitted  evidence  of  a 
 systemic  problem.  587  Indeed,  BellSouth  demonstrates  that  0.17  percent  of  total  UNE-  P  conversions  for  the  month  of  May  were  affected  by  the  DSL  USOC.  588  Further,  we  note  that 
 some  DSL  USOC  problems  may  be  the  result  of  delays  in  canceling  old  DSL  accounts  or  installing  new  DSL  accounts.  589  Moreover,  there  is  no  evidence  in  the  record,  beyond  Birchs 


 583  See  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9102  n.  571.  This  process  provides  a  competitive 
 LEC  (after  receiving  notice  of  the  USOC)  the  option  to  call  a  dedicated  group  at  BellSouths  LCSC  to  remove  the  DSL  USOC  if  the  end  user  is  not  receiving  DSL. 


 584  In  addition,  Birch  requests  that  BellSouth  allocate  resources  to  implement  an  effective  process  to  remove  DSL 
 USOC  that  already  exist  on  customer  accounts,  and  immediately  rectify  the  current  process  failures  by  taking  emergency  corrective  action  to  implement  a  systemic  fix  prior  to  BellSouths  Release  11.0  scheduled  for  December 


 7,  2002.  Birch  Comments  at  5-  6. 
 585  KMC/  NuVox  Comments  at  20. 


 586  Birch  Comments  at  9;  US  LEC  Reply  at  4  (citing  Birch  Comments  at  4-  13). 
 587  See  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9101,  para.  158. 
 588  See  BellSouth  Ainsworth  Reply  Aff.  para.  22.  In  May  2002,  2,791  LSRs  were  auto-  clarified  for  DSL  service 
 on  the  end-  users  line  which  equates  to  just  over  4%  of  the  total  orders  auto-  clarified  and  less  than  2.  27%  of  UNE-  P  conversions.  Id.  BellSouth  indicates  that  of  the  2,791  DSL-  clarified  orders,  only  204  were  auto-  clarified  for  DSL 


 service  on  the  end-  users  line  when  the  end-  user  either  did  not  have  working  high  speed  Internet  access  service,  or  was  actively  involved  in  adding  or  disconnecting  the  DSL  service,  which  equates  to  0.17%  of  total  UNE-  P 
 conversions  for  the  month  of  May  2002.  Id.  Similarly,  we  observed  in  the  BellSouth  Georgia/  Louisiana  Order  that,  in  February  2002,  0.37%  of  all  UNE-  P  conversions  involved  instances  where  the  end-  user  was  actively  adding 
 or  disconnecting  DSL  service,  or  did  not  have  working  DSL.  See  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9101-  02  n.  569.  We  are  not  persuaded  by  Birchs  argument  that  BellSouths  percentages,  which  are  based  on 
 auto-  clarifications,  do  not  accurately  reflect  the  true  universe  of  orders  that  are  affected  during  conversion  to  a  competitive  LEC.  See  Letter  from  Rose  Mulvany  Henry,  Director  of  Regulatory  &  Regulatory  Counsel,  Birch,  to 
 Marlene  H.  Dortch,  Secretary,  Federal  Communications  Commission,  WC  Docket  No.  02-  150  at  2  (filed  August  23,  2002)  (Birch  August  23  Ex  Parte  Letter).  BellSouth  indicates  that  the  DSL  USOC  clarifications  represent  the 
 number  of  migration  requests  BellSouth  receives  related  to  DSL  on  the  migrating  customers  CSR.  See  BellSouth  Application  App.  A,  Vol  1A,  Tab  A,  Affidavit  of  Ken  L.  Ainsworth  (BellSouth  Ainsworth  Aff.)  at  para.  19. 
 BellSouth  states  that  Birchs  argument  that  BellSouths  data  does  not  include  any  DSL  removal  request  by  a  competitive  LEC  prior  to  submission  of  a  migration  request  is  true,  but  BellSouth  points  out  that  competitive  LECs 
 can  request  removal  of  DSL  prior  to  submission  of  a  migration  request  or  request  removal  of  the  DSL  utilizing  the  interim  process  by  acting  on  the  end-  users  behalf.  BellSouth  states  that  the  clarification  data  is  representative  of 
 the  working  and  non-  working  DSL  USOCs  that  are  posted  on  the  CSR.  Id. 
 589  See  BellSouth  Ainsworth  Reply  Aff.  at  paras.  14-  15. 
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 mere  assertion,  to  suggest  that  BellSouth  intentionally  causes  this  problem.  590  In  fact,  BellSouth  has  recognized  the  DSL  USOC  problem  and  is  currently  working  with  competitive  LECs 
 through  an  interim  process  it  created  in  the  BellSouth  Georgia/  Louisiana  proceeding  to  quickly  handle  orders  affected  by  this  problem.  Moreover,  BellSouth  notes  that  since  it  instituted  this 
 interim  process,  only  99  requests  per  month  have  been  received  among  all  five  application  states.  591  We  therefore  find  that  there  is  no  evidence  in  the  record  that  BellSouth  acts  in  a 
 discriminatory  manner  or  denies  competitors  a  reasonable  opportunity  to  compete.  Although  not  decisional  to  our  evaluation,  we  also  note  that  BellSouth  will  provide  competitive  LECs  the 
 ability  to  electronically  request  removal  of  DSL  from  UNE-  P  migration  orders  with  its  December  8,  2002  system  release.  592 


 163.  We  also  reject  other  claims  by  commenters  that  BellSouth  has  a  policy  of  placing  DSL  on  the  customers  primary  telephone  line  or  the  billing  telephone  line  of  a  hunt  group  and 
 that  this  policy  is  discriminatory.  593  BellSouth  states  that  it  does  not  have  a  policy  of  placing  DSL  on  the  customers  primary  line  or  the  billing  line  of  a  hunt  group.  594  Rather,  as  we  noted  in 
 the  BellSouth  Georgia/  Louisiana  Order,  BellSouths  policy  permits  the  end  user  to  place  DSL  service  on  whichever  line  the  customer  requests.  595  We  also  note  that  Birch  also  requests  that  the 
 Commission  pursue  enforcement  action  against  BellSouth  in  Georgia  and  Louisiana  for  withholding  relevant  data  from  the  Commission  regarding  the  pervasiveness  of  the  problem.  596 
 We  believe  that  this  issue  is  more  appropriately  raised  in  an  enforcement  proceeding  under  section  271(  d)(  6)  of  the  Act,  rather  than  here.  597 


 590  Birch  has  submitted  several  customer-  specific  examples  of  customers  who  have  had  the  USOC  DSL  placed  on 
 their  accounts  to  illustrate  the  pervasiveness  of  the  problem.  BellSouth,  however,  explains  that  all  of  Birchs  examples,  for  which  there  was  sufficient  information  to  investigate,  are  scenarios  where  the  DSL  USOC  was  placed 


 on  the  CSR  as  a  result  of  an  order  from  an  ISP.  BellSouth  Ainsworth  Reply  Aff.  at  para.  15.  Birch  points  out  that  for  the  vast  majority  of  the  examples,  the  orders  were  placed  by  an  ISP,  but  it  was  BellSouths  retail  DSL  service 
 unit.  Birch  August  23  Ex  Parte  Letter  at  2.  We  find,  however,  that  there  is  no  evidence  on  the  record  that  BellSouth  or  its  retail  DSL  service  unit  crams  its  customers  accounts  with  the  DSL  USOC. 


 591  See  BellSouth  Ainsworth  Reply  Aff.  at  para.  26. 
 592  See  id.  at  para.  20. 
 593  Birch  Comments  at  13;  KMC/  NuVox  Comments  at  10,  17-  19. 
 594  See  BellSouth  Ainsworth  Reply  Aff.  at  para.  30. 
 595  See  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9101  n.  565;  BellSouth  Ainsworth  Reply  Aff.  at  para. 
 30.  BellSouth  states  that  if  the  telephone  number  provided  by  the  customer  qualifies  for  DSL,  then  the  sales  agent  is  instructed  to  place  the  DSL  order  on  the  line  requested  by  the  customer,  and  if  the  first  choice  does  not  currently 


 qualify  for  DSL  service  the  agent  will  usually  recommend  provisioning  the  DSL  service  on  the  customers  fax  line.  BellSouth  Ainsworth  Reply  Aff.  at  para.  30 


 596  Birch  Comments  at  5. 
 597  See  47  U.  S.  C.    271(  d)(  6);  47  U.  S.  C.    208. 
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 164.  Finally,  we  reject  claims  by  KMC  and  NuVox  that  BellSouths  practice  of  refusing  to  provide  DSL  service  on  the  same  line  over  which  an  end  user  subscribes  to  a 
 competitive  LEC's  voice  service  warrants  a  finding  of  noncompliance.  As  we  stated  in  the  BellSouth  Georgia/  Louisiana  Order,  an  incumbent  LEC  has  no  obligation,  under  our  rules,  to 
 provide  DSL  service  over  the  competitive  LECs  leased  facilities.  Moreover,  a  UNE-  P  carrier  has  the  right  to  engage  in  line  splitting  on  its  loop.  598  As  a  result,  a  UNE-  P  carrier  can  compete 
 with  BellSouths  combined  voice  and  data  offering  on  the  same  loop  by  providing  the  customer  with  line  splitting  voice  and  data  service  over  the  UNE-  P  loop  in  the  same  manner.  599 
 Accordingly,  we  cannot  agree  with  KMC  and  NuVox  that  BellSouths  policies  are  discriminatory  and  warrant  a  finding  of  checklist  noncompliance. 


 165.  Ordering  for  Line-  Shared  Loops.  Covad  claims  that  two  specific  defects  in  BellSouths  ordering  processes  for  line-  shared  loops  allow  BellSouth  to  achieve  a  greater  level 
 of  flow-  through  mechanization  than  competitive  LECs  are  able  to  achieve.  600  First,  Covad  asserts  that  BellSouths  automated  systems  are  unable  to  provide  Covad  with  pseudo  circuit 
 numbers  when  it  orders  line-  shared  loops.  601  Covad  states  that  it  needs  these  numbers  to  identify  the  line-  shared  loops  for  which  it  is  being  charged  and  that  BellSouths  systems  force  it 
 to  use  a  manual  work-  around  to  obtain  them.  602  Even  assuming  that  competitive  LECs  ordered  all  of  these  line-  shared  loops  manually,  603  a  point  on  which  neither  Covad  nor  BellSouth  was  able 
 to  elucidate  further  in  this  proceeding,  we  do  not  have  sufficient  evidence  in  the  record  to 
 598  Line  Sharing  Order,  14  FCC  Rcd  at  20912;  Deployment  of  Wireline  Services  Offering  Advanced 
 Telecommunications  Capability,  Third  Report  and  Order  on  Reconsideration,  CC  Docket  No.  96-  98,  Third  Further  Notice  of  Proposed  Rulemaking,  CC  Docket  No.  98-  147,  Sixth  Further  Notice  of  Proposed  Rulemaking,  CC  Docket 


 No.  96-  98,  16  FCC  Rcd  2101,  2109-  14,  paras.  14-  26  (Line  Sharing  Reconsideration  Order);  see  also  SWBT  Texas  Order,  15  FCC  Rcd  at  18517-  18,  para.  330. 


 599  SWBT  Texas  Order,  15  FCC  Rcd  at  18517-  18,  para.  330. 
 600  Covad  Comments  at  14-  15. 
 601  Id.  at  14.  Pseudo  circuit  numbers  are  numbers  that  BellSouth  uses  in  its  bills  to  identify  the  line-  shared 
 loops  for  which  competitive  LECs  are  being  charged.  Id.  at  14. 
 602  Id.  at  14-  15.  This  manual  work-  around  requires  that  a  competitive  LEC  stop  the  automated  ordering  process 
 and  manually  extract  the  pseudo  circuit  number  from  a  BellSouth  database  before  manually  completing  and  closing  an  order.  Covad  Comments  at  14-  15.  The  record  shows,  however,  that  competitive  LECs  ordered  from  BellSouth 


 only  165  line-  shared  loops  in  Alabama,  137  line-  shared  loops  in  Kentucky,  78  line-  shared  loops  in  North  Carolina,  and  no  line-  shared  loops  in  either  Mississippi  or  South  Carolina  during  the  applicable  four-  month  period. 
 Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  2.1.7.3.1-  B.  2.1.7.4.2  (Order  Completion  Interval,  Line  Sharing). 


 603  The  record  contains  no  data  on  either  the  number  of  line-  shared  loops  that  competitive  LECs  ordered  manually 
 during  the  applicable  period  or  the  number  of  line-  shared  loops  that  were  ordered  manually  as  a  result  of  this  pseudo  circuit  number  problem.  We  note  that  BellSouth  argues  that  Covad  need  interrupt  the  mechanized 


 ordering  process  in  order  to  obtain  a  pseudo  circuit  number.  BellSouth  August  20  Ex  Parte  Letter  at  2.  Instead,  according  to  BellSouth,  Covad  could  complete  an  order  for  line-  shared  loop  mechanically  and,  at  a  later  date,  use  a 
 manual  process  to  obtain  the  pseudo  circuit  number.  Id.  BellSouth  contends  that  this  alternative  work-  around  would  take  a  competitive  LEC  service  representative  less  than  five  minutes.  Id. 
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 determine  whether  the  additional  costs  and  delays  that  manually  ordering  these  loops  impose  on  competitive  LECs  would  be  competitively  significant.  604  We  therefore  conclude  that  BellSouths 
 inability  to  provide  pseudo  circuit  numbers  mechanically  does  not  warrant  a  finding  of  noncompliance  with  checklist  item  2.  Although  not  a  basis  for  our  decision  here,  we  note  that 
 BellSouth  acknowledges  that  this  inability  is  a  defect  and  will  correct  this  problem  its  OSS  11.0  release  targeted  for  December  8,  2002  605 


 166.  Covad  also  states  that  BellSouth  creates  two  separate  orders  when  it  receives  a  line-  shared  loop  order  from  a  competitive  LEC:  one  that  goes  to  BellSouths  billing  department; 
 and  another  that  goes  to  the  central  office  from  which  the  line-  shared  loop  will  be  provisioned.  606  Covad  states  that  BellSouth  generally  completes  the  billing  order  in  about  24  hours,  but  takes 
 longer  to  complete  the  loop  provisioning  order.  607  Covad  complains  that  it  cannot  modify  the  provisioning  order  to  request  changes,  such  as  loop  conditioning,  once  BellSouth  completes  the 
 billing  order.  608  Instead,  Covad  must  cancel  its  initial  order,  wait  for  BellSouth  to  process  that  cancellation,  and  then  submit  a  new  order  requesting  conditioning.  609  Covad  contends  that  this 
 process  is  considerably  more  expensive  and  time-  consuming  than  simply  modifying  the  initial  order  and  that  BellSouths  retail  operations  never  encounter  similar  burdens  under  similar 
 circumstances.  610  BellSouth  acknowledges  this  defect,  but  claims  that  it  rarely  affects  competitive  LEC  orders.  Indeed,  BellSouth  states  that  this  defect  affects  a  competitive  LEC  only 
 when  each  of  the  following  occurs:  (1)  the  bill  and  provisioning  order  due  dates  fall  out  of  synchrony  as  a  result  of  changes  in  the  due  dates;  (2)  the  billing  order  erroneously  completes 
 before  the  provisioning  work  is  completed;  and  (3)  the  loop  makeup  data  contained  in  LFACS  do  not  reflect  loop  conditions  (such  as  excessive  bridged  taps  or  load  coils)  that  are  incompatible 
 with  line  sharing  and  are  discovered  at  the  time  of  provisioning.  We  recognize  the  inconvenience  that  this  may  cause  Covad,  but  find  that  Covads  allegations  do  not  indicate 
 systemic  problems  with  BellSouths  ordering  processes.  Given  the  small  number  of  orders  affected  at  this  time,  we  do  not  believe  that  the  minor  additional  costs  and  delays  that  this 
 problem  imposes  on  competitive  LECs  are  competitively  significant.  Although  not  a  basis  for  our  evaluation  here,  we  note  that  BellSouth  will  implement  a  change  scheduled  for  completion 


 604  We  note  that  Covad  has  not  attempted  to  quantify  the  additional  costs  or  delays  of  ordering  a  line-  shared  loop 
 manually,  rather  than  mechanically. 
 605  BellSouth  Stacy  Reply  Aff.  at  paras.  225-  27;  see  also  Letter  from  Praveen  Goyal,  Senior  Counsel   
 Government  &  Regulatory  Affairs,  Covad,  to  Marlene  H.  Dortch,  Secretary,  Federal  Communications  Commission,  WC  Docket  No.  02-  150  Att.  A-  1A  at  4  (filed  July  23,  2002)  (Covad  July  23  Ex  Parte  Letter). 


 606  Covad  Comments  at  15. 
 607  Id.  at  16. 
 608  Id.  at  16-  17. 
 609  Id. 
 610  Id. 
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 that  will  be  included  in  BellSouths  OSS  11.0  release  targeted  for  December  8,  2002  to  correct  this  problem.  611 
 167.  Covad  also  contends  that  BellSouth  begins  billing  Covad  immediately  upon  completion  of  the  billing  order  and  that  Covad  should  not  have  to  pay  for  a  line-  shared  loop  until 
 it  is  installed.  612  Such  allegations  concern  us;  however,  in  this  case  there  is  little  supporting  evidence  to  substantiate  them.  Even  if  true,  moreover,  the  record  shows  that  any  early  billing 
 would  cost  Covad  only  about  $0.02  per  line-  shared  loop  per  day.  613  Because  that  amount  may  be  too  low  to  be  competitively  significant  and  because  BellSouth  offers  to  refund  any  excess 
 charges  to  Covad,  614  we  find  that  Covads  allegation  of  premature  billing  does  not  warrant  a  finding  of  checklist  noncompliance. 


 168.  Dial  Around  Compensation.  We  reject  Ernests  claim  that  BellSouth  fails  to  provide  nondiscriminatory  access  to  its  OSS.  615  Ernest  claims  that  without  FLEX  ANI  on  a 
 payphone  line,  a  long-  distance  call  cannot  be  identified  as  originating  from  a  payphone  and  a  payphone  service  provider  cannot  collect  dial-  around  compensation  for  calls  made  from  that 
 line.  616  Ernest  states  that  after  examining  its  orders,  it  discovered  that  the  payphone  USOC  that  was  ordered  properly  from  BellSouth  was  being  charged  to  a  business  line  USOC  by  BellSouths 
 OSS,  which  does  not  include  FLEX  ANI.  617  While  we  recognize  the  inconvenience  that  this  may  cause  Ernest  and  its  customers,  BellSouth  acknowledges  this  problem  and  states  that  it  offered 
 Ernest  an  interim  manual  solution  to  fully  resolve  this  problem.  618  Despite  an  interim  solution  in  place,  BellSouth  claims  that  Ernest  continues  to  submit  orders  electronically,  knowing  that  this 
 will  result  in  errors  that  will  need  to  be  corrected.  619  Given  this  evidence,  we  do  not  find  that  Ernests  claim  warrants  a  finding  of  checklist  noncompliance.  Although  not  decisional  to  our 
 analysis,  we  also  note  that  BellSouth  has  committed  to  implement  a  permanent  network  solution  to  this  problem  on  December  8,  2002.  620  Should  this  issue  prove  to  be  a  systemic  problem  with 


 611  BellSouth  Application  Reply  App.,  Vol  2,  Tab  G,  Reply  Affidavit  of  David  P.  Scollard  (BellSouth  Scollard 
 Reply  Aff.)  at  para.  16.  Should  BellSouths  performance  in  this  area  deteriorate,  we  will  pursue  appropriate  enforcement  action. 


 612  Covad  Comments  at  16. 
 613  See  BellSouth  Stacy  Reply  Aff.  at  para.  15. 
 614  See  id.  at  para.  15. 
 615  Ernest  Comments  at  4. 
 616  Id.  at  Affidavit  of  Steve  Reynolds  (Ernest  Reynolds  Aff.)  at  para.  4. 
 617  Ernest  Reynolds  Aff.  at  para.  7. 
 618  BellSouth  Application  Reply  App.,  Vol.  2,  Tab  C,  Reply  Affidavit  of  Trent  Lamar  Clark  (BellSouth  Clark 
 Reply  Aff.)  at  para.  5;  BellSouth  Stacy  Reply  Aff.  at  para.  200. 
 619  BellSouth  Clark  Reply  Aff.  at  para.  5 


 620  BellSouth  Reply  at  27;  BellSouth  Stacy  Reply  Aff.  at  para.  204. 
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 BellSouths  OSS,  or  should  the  scheduled  December  fix  prove  to  cause  carriers  competitive  harm,  the  Commission  may  take  appropriate  enforcement  action. 
 d.  Provisioning 
 169.  Based  on  the  evidence  in  the  record,  we  find,  as  did  the  state  commissions,  621  that  BellSouth  provisions  competitive  LEC  customers  orders  for  UNE-  platform  and  resale  services 


 in  substantially  the  same  time  and  manner  as  it  provisions  orders  for  its  own  retail  customers.  622  Overall,  BellSouths  performance  meets  the  parity  standards  in  key  metrics  that 
 measure  provisioning  for  resale  and  UNE-  platform  in  all  five  states  from  March  to  June.  623 
 170.  Based  on  the  results  of  BellSouths  performance  data,  we  find  that  BellSouth  generally  meets  the  parity  standard  with  respect  to  provisioning  timeliness  and  provisioning 


 quality  for  both  resale  and  UNE-  P.  624  Although  we  note  some  exceptions  with  respect  to  BellSouths  order  completion  interval  metric,  the  disparities  are  isolated  to  a  few  submetrics  with 
 low  volumes  and  are  not  competitively  significant.  625  Similarly,  BellSouths  inability  to  meet  the 
 621  See  Alabama  Commission  Comments  at  163;  Kentucky  Commission  Comments  at  21-  29;  Mississippi 
 Commission  Comments  at  11-  12;  North  Carolina  Commission  Comments  at  139-  41;  South  Carolina  Commission  Comments  at  1-  3. 


 622  The  systems,  procedures  and  personnel  used  by  BellSouth  to  offer  access  to  provisioning  timeliness  and 
 quality  are  the  same  in  Georgia  and  Louisiana  as  in  the  five  states  contained  in  this  application.  BellSouth  Application  at  90;  see  also  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9108-  09,  para.  166. 


 623  See  generally  BellSouth  Varner  Aff.  at  para.  182,  Exhs.  PM-  2    PM-  6. 
 624  In  all  five  states,  BellSouth  met  or  exceeded  parity  with  the  retail  analogue  for  the  resale  order  completion 
 interval  performance  metric  for  all  residential  orders,  which  account  for  the  vast  majority  of  resale  orders,  and  for  the  order  completion  interval  for  UNE-  P.  See  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina 


 A.  2.1.1.1.1    A.  2.1.1.2.2  (Order  Completion  Interval,  Residence);  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  2.1.3.1.1    B.  2.1.3.2.4  (Order  Completion  Interval,  Loop  +  Port  Combinations). 


 625  See  North  Carolina  A.  2.1.2.1.1  (Order  Completion  Interval,  Business/<  10  Circuits/  Dispatch).  BellSouth 
 explains  that  for  two  of  the  months  in  which  it  missed  the  parity  standard,  the  difference  between  the  BellSouth  and  competitive  LEC  intervals  can  be  attributed  to  a  handful  of  orders  in  each  month  with  extended  intervals.  BellSouth 


 Varner  Aff.  at  para.  202,  Exh.  PM-  5;  see  also  Varner  Reply  Aff.  at  para.  173.  Each  of  those  orders  was  either  initially  scheduled  with  an  extended  interval  at  the  customers  request  or  was  changed  based  on  a  missed 
 appointment  caused  by  the  end  user  customer  and  had  to  be  rescheduled.  Varner  Reply  Aff.  at  para.  173.  BellSouth  has  also  failed  to  meet  the  parity  standard  for  metric  B.  2.1.4.1.1.  (Order  Completion  Interval,  Combo  Other/<  10 
 Circuits/  Dispatch)  for  March  through  June  in  Kentucky,  for  March  through  June  in  North  Carolina,  and  for  April  through  June  in  South  Carolina.  Competitive  LEC  volumes    fewer  than  20  orders  in  any  given  month  in  Kentucky, 
 fewer  than  15  in  North  Carolina,  and  fewer  than  40  in  South  Carolina    are  not  substantial  enough,  however,  to  warrant  a  finding  of  checklist  noncompliance  in  light  of  BellSouths  overall  performance.  Furthermore,  as  we  noted 
 in  the  BellSouth  Georgia/  Louisiana  Order,  BellSouth  has  reached  an  agreement  with  competitive  LECs  to  create  a  separate  disaggregated  metric  for  EELs,  which  should  facilitate  the  detection  of  any  future  poor  performance.  See 
 BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9019,  para.  166.  Once  this  metric  is  established  for  EELs,  we  expect  that  BellSouths  performance  should  improve.  See  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at 
 9019,  para.  166.  Should  BellSouths  performance  in  this  area  deteriorate,  we  may  pursue  appropriate  enforcement  action. 
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 parity  standard  for  missed  installation  appointments  for  a  few  submetrics  lacks  competitive  significance.  626  Moreover,  BellSouth  demonstrates  that  it  has  met  an  average  of  at  least  99 
 percent  of  installation  appointments,  and  the  disparity  between  the  retail  and  wholesale  performance  is  extremely  small.  627  As  such,  the  competitive  LECs  ability  to  compete  has  not 
 been  hindered  by  BellSouths  failure  to  meet  these  submetrics.  Finally,  BellSouth  missed  several  submetrics  for  the  metric  measuring  percent  provisioning  troubles  within  30  days  for 
 both  resale  and  UNE-  platform.  628  However,  the  disparity  between  BellSouth  retail  and  competitive  LEC  performance  is  small  for  those  submetrics  with  high  volumes.  629  Furthermore, 
 BellSouth  claims  that  a  significant  number  of  its  trouble  reports  for  specific  submetrics  were  closed  without  a  trouble  being  found.  630  If  those  reports  were  excluded  from  the  performance 
 results,  BellSouth  would  have  met  the  parity  standard.  631  Nonetheless,  we  will  monitor  BellSouths  performance  in  this  area,  and,  should  it  deteriorate,  we  will  pursue  appropriate 
 enforcement  action. 
 171.  We  reject  WorldComs  complaint  that  the  Commission  has  not  had  enough  time  to  properly  evaluate  BellSouths  implementation  of  Single  C  ordering  in  each  of  the  five 


 626  The  exception  to  BellSouths  generally  timely  installations  is  metric  A.  2.  11.  1.  1.  2  (%  Missed  Installation 
 Appointments,  Residence/<  10  Circuits/  Dispatch)  for  resale  in  Alabama,  Mississippi,  North  Carolina,  and  South  Carolina.  BellSouth  Varner  Reply  Aff.  at  para.  230.  BellSouth  has  also  missed  two  UNE-  platform  metrics: 


 B.  2.18.3.1.2  (%  Missed  Installation  Appointments,  Loop  +  Port  Combination/<  10  Circuits/  Non-  dispatch)  and  B.  2.18.3.1.4  (%  Missed  Installation  Appointments,  Loop  +  Port  Combinations/<  10  Circuits/  Dispatch  In)  in  the  five 
 states. 
 627  BellSouth  Varner  Reply  Aff.  at  para.  230.  For  those  submetrics  not  at  parity  for  more  than  one  month,  only 
 one  submetric  has  higher  than  a  0.5%  average  rate  of  missed  appointments:  B.  2.18.3.1.4  for  North  Carolina  is  0.  56%.  In  addition,  the  disparity  between  the  retail  and  wholesale  performance  is  extremely  small.  BellSouth 


 Varner  Reply  Aff.  at  para.  192. 
 628  See  Alabama/  Mississippi/  North  Carolina  A.  2.12.1.1.2  (%  Provisioning  Troubles  Within  30  Days, 
 Residence/<  10  Circuits/  Non-  dispatch);  Mississippi  A.  2.12.4.1.2  (PBX/<  10  Circuits/  Non-  dispatch);  Mississippi  A.  2.12.5.1.2  (%  Provisioning  Troubles  Within  30  Days,  Centrex/<  10  Circuits/  Non-  dispatch);  North  Carolina 


 B.  2.19.3.1.1  (%  Provisioning  Troubles  Within  30  Days,  Loop  +  Port  Combination/<  10  Circuits/  Dispatch);  Alabama/  North  Carolina/  South  Carolina  B.  2.19.3.1.2  (%  Provisioning  Troubles  Within  30  Days,  Loop  +  Port 
 Combination/<  10  Circuits/  Non-  dispatch);  North  Carolina  B.  2.19.3.1.3  (%  Provisioning  Troubles  Within  30  Days,  Loop  +  Port  Combination/<  10  Circuits/  Switch-  based);  Alabama/  Mississippi/  North  Carolina/  South  Carolina 
 B.  2.19.3.1.4  (%  Provisioning  Troubles  Within  30  Days,  Loop  +  Port  Combination/<  10  Circuits/  Dispatch  In). 
 629  See,  e.  g.,  Alabama/  Mississippi  A.  2.12.1.1.2  and  Mississippi  B.  2.19.3.1.4  (less  than  1%  difference  between 
 BellSouth  retail  and  wholesale  performance);  Alabama/  South  Carolina/  North  Carolina  B.  2.19.3.1.2  and  B.  2.19.3.1.4  (approximately  or  less  than  1.5%  difference  between  BellSouth  retail  and  wholesale  performance). 


 630  BellSouth  Varner  Aff.  Exh.  PM-  2  at  paras.  58,  196  (Alabama);  BellSouth  Varner  Aff.  Exh.  PM-  4  at  paras.  58, 
 190  (Mississippi)  (a  significant  number  of  the  troubles  reported  were  closed  as  no  trouble  found);  BellSouth  Varner  Aff.  Exh.  PM-  5  at  paras.  58,  206  (North  Carolina)  (more  than  20%  of  the  troubles  reported  were  closed  as 


 no  trouble  found);  BellSouth  Varner  Aff.  Exh.  PM-  6  at  paras.  58,  188  (South  Carolina). 
 631  Id. 
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 states.  632  We  do  not  rely  on  enhancements  to  BellSouths  provisioning  process,  specifically  the  implementation  of  Single  C  ordering,  in  determining  checklist  compliance.  We  note,  however, 
 that  BellSouth  has  now  implemented  Single  C  ordering  in  each  of  the  states,  633  and  we  expect  BellSouth  to  take  the  necessary  steps  to  cure  any  problems  associated  with  the  implementation  of 
 Single  C  ordering. 
 e.  Maintenance  and  Repair 
 172.  We  find,  as  did  the  state  commissions,  that  BellSouth  provides  nondiscriminatory  access  to  its  maintenance  and  repair  OSS  functions  for  resale  and  UNE-  platform.  634  Moreover, 


 commercial  data  during  the  relevant  period  show  competing  carriers  have  access  to  these  functions  in  substantially  the  same  time  and  manner  635  as  BellSouths  retail  operations,  and 
 with  an  equivalent  level  of  quality.  636 
 173.  Although  we  note  slightly  higher  trouble  report  rates  in  the  Design,  PBX  and  ISDN  product  categories  for  resale  measures,  637  the  percentage  of  troubles  appears  to  be  low  in 


 632  WorldCom  asserts  that  it  has  experienced  line  loss  problems  and  that  it  is  attempting  to  determine  the  extent  of 
 the  problems  and  whether  they  are  related  to  the  Single  C  implementation.  Lichtenberg  Decl.  at  para.  24;  WorldCom  Reply  at  7. 


 633  BellSouth  Ainsworth  Reply  Aff.  at  para.  8;  BellSouth  Stacy  Reply  Aff.  at  para.  192.  BellSouth  implemented 
 Single  C  ordering  in  Mississippi  on  March  23,  2002,  in  Alabama  and  South  Carolina  on  July  21,  2002,  and  in  North  Carolina  and  Kentucky  on  August  3,  2002.  Single  C  was  previously  implemented  in  Florida,  Georgia, 


 Louisiana,  and  Mississippi.  BellSouth  Stacy  Reply  Aff.  at  para.  192. 
 634  See  Alabama  Commission  Comments  at  165;  Kentucky  Commission  Comments  at  26;  Mississippi 
 Commission  Comments  at  11-  12;  North  Carolina  Commission  Comments  at  142;  South  Carolina  Commission  Comments  at  1-  3. 


 635  First,  customers  of  competitive  LECs  were  out  of  service  for  less  time  than  BellSouth  customers.  BellSouth 
 provided  competing  carriers  better  than  parity  performance  in  the  Percentage  Out  of  Service  metric,  with  a  few  de  minimis  exceptions,  for  both  resale  and  UNE-  platform.  See  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South 


 Carolina  A.  3.5  and  B.  3.5  (%  Out  of  Service  More  Than  24  Hours).  Second,  the  performance  data  indicate  that  BellSouth  provides  better  than  parity  service  in  meeting  repair  appointments.  BellSouth  provided  better  than  parity 
 performance  across  all  product  categories  in  resale  and  across  UNE-  P  and  other  combination  categories,  with  a  few  de  minimis  exceptions.  See  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  A.  3.1  and  B.  3.1  (% 
 Missed  Repair  Appointments).  Finally,  BellSouth  performed  repair  work  faster  for  competing  carriers  than  it  did  for  its  own  customers.  BellSouth  met  or  exceeded  the  parity  standard  as  compared  to  the  retail  analog  for  the 
 Maintenance  Average  Duration  metric,  except  for  a  few  de  minimis  exceptions.  See  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  A.  3.3;  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina 
 B.  3.3  (Maintenance  Average  Duration). 
 636  BellSouth  provided  better  than  parity  performance  for  repair  quality  across  all  product  categories  in  resale  and 
 across  UNE-  P  and  other  combination  categories,  with  a  few  de  minimis  exceptions.  See  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  A.  3.4  (%  Repeat  Troubles  within  30  Days);  Alabama/  Kentucky/ 


 Mississippi/  North  Carolina/  South  Carolina  B.  3.4  (%  Repeat  Troubles  within  30  Days). 
 637  BellSouth  was  out  of  parity  for  at  least  three  months  for  the  following  metrics:  A.  3.2.3.1  (Customer  Trouble 
 Report  Rate,  Design/  Dispatch)  in  Mississippi;  A.  3.2.4.1  (Customer  Trouble  Report  Rate,  PBX/  Dispatch)  in  (continued.) 
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 nearly  every  case.  638  Similarly,  BellSouths  failure  to  achieve  parity  for  metric  for  Combinations,  Other/  Dispatch  in  North  Carolina  for  two  months  and  in  South  Carolina  for 
 three  months  during  the  relevant  period,  639  is  not  competitively  significant.  640  Accordingly,  BellSouths  performance  with  regard  to  this  metric  does  not  warrant  a  finding  of  noncompliance. 


 f.  Billing 
 174.  Like  the  state  commissions,  we  find  that  BellSouth  provides  nondiscriminatory  access  to  its  billing  functions.  641  BellSouths  performance  data  demonstrate  its  ability,  with  a 


 few  exceptions,  to  provide  competing  carriers  with  billing  usage  information  in  substantially  the  same  time  and  manner  that  BellSouth  provides  such  information  to  itself,  642  and  to  provide 
 wholesale  bills  in  a  manner  that  gives  competing  carriers  a  meaningful  opportunity  to  compete.  643  For  invoice  accuracy    both  resale  and  UNE  bills    BellSouth  did  not  meet  the  parity 


 (Continued  from  previous  page)  Alabama,  Kentucky  and  Mississippi;  A.  3.2.4.2  (Customer  Trouble  Report  Rate,  PBX/  Non-  dispatch)  in  Mississippi; 
 and  A.  3.2.6.1  (Customer  Trouble  Report  Rate,  ISDN/  Dispatch)  in  Alabama,  North  Carolina  and  South  Carolina.  BellSouth  notes  that  it  is  providing  more  than  97%  trouble-  free  lines  in  most  cases,  and  that  these  submetrics  are 
 sensitive  to  small  performance  differences.  BellSouth  Varner  Reply  Aff.  at  paras.  182-  89.  We  agree  with  BellSouth  that  the  difference  of  1%  to  2%  between  retail  and  wholesale  performance  was  more  a  function  of 
 variations  in  volume  rather  than  variations  in  treatment.  BellSouth  Varner  Reply  Aff.  at  para.  183.  However,  should  BellSouths  performance  in  this  area  deteriorate,  we  will  pursue  appropriate  enforcement  action. 


 638  See,  e.  g.,  Alabama  A.  3.2.4.1  (Customer  Trouble  Report  Rate,  PBX/  Dispatch)  (0.94%);  Alabama  A.  3.2.6.1 
 (Customer  Trouble  Report  Rate,  ISDN/  Dispatch)  (0.33%). 
 639  See  North  Carolina/  South  Carolina  B.  3.2.4.1  (Customer  Trouble  Report  Rate,  Combo  Other/  Dispatch). 


 640  In  South  Carolina,  the  average  difference  during  the  past  four  months  was  about  2%.  See  South  Carolina 
 B.  3.2.4.1  (Customer  Trouble  Report  Rate,  PBX/  Dispatch).  In  North  Carolina,  the  average  difference  was  about  1.5%.  See  North  Carolina  B.  3.2.4.1  (Customer  Trouble  Report  Rate,  PBX/  Dispatch).  Furthermore,  North 


 Carolinas  misses  were  in  March  and  April.  BellSouth  met  the  parity  standard  in  May  and  June  so  it  appears  that  its  performance  is  on  an  upward  trend.  Id. 


 641  See  Alabama  Commission  Comments  at  166;  Kentucky  Commission  Comments  at  145;  Mississippi 
 Commission  Comments  at  11-  12;  North  Carolina  Commission  Comments  at  145;  South  Carolina  Commission  Comments  at  1-  3. 


 642  BellSouth  provides  timely,  accurate,  and  complete  usage  data.  See  Alabama/  Kentucky/  Mississippi/  South 
 Carolina/  North  Carolina  F.  9.  2  (DUF  Delivery  Timeliness);  Alabama/  Kentucky/  Mississippi/  South  Carolina/  North  Carolina  F.  9.1  (DUF  Delivery  Accuracy);  Alabama/  Kentucky/  Mississippi/  South  Carolina/  North  Carolina  F.  9.3 


 (DUF  Delivery  Completeness);  Alabama/  Kentucky/  Mississippi/  South  Carolina/  North  Carolina  F.  9.  4  (Mean  Time  to  Deliver  Usage). 


 643  BellSouth  generally  provides  accurate  and  complete  carrier  bills.  See  Alabama/  Kentucky/  Mississippi/  South 
 Carolina/  North  Carolina  A.  4.1  (Invoice  Accuracy    Resale);  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  4.1  (Invoice  Accuracy    UNE).  BellSouth  also  has  generally  met  the  parity  standard  for  timely  delivery 


 of  bills.  See  Alabama/  Kentucky/  Mississippi/  South  Carolina/  North  Carolina  A.  4.2  (Mean  Time  to  Deliver  Resale  Invoices    CRIS);  Alabama/  Kentucky/  Mississippi/  South  Carolina/  North  Carolina  B.  4.2  (Mean  Time  to  Deliver 
 UNE  Invoices    CRIS). 
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 standard  in  a  few  months  in  Alabama  and  Mississippi.  644  However,  BellSouth  still  achieved  at  least  a  98  percent  accuracy  rate  overall.  645  As  a  result,  competitive  LECs  were  not  harmed  by 
 BellSouths  failure  to  meet  the  parity  standard  for  each  of  those  metrics  every  month.  In  addition,  BellSouths  missing  the  parity  standard  for  three  of  the  past  four  months  for  UNE  bill 
 timeliness  lacks  competitive  significance  because  those  misses  are  primarily  the  result  of  a  transition  to  a  new,  enhanced  billing  system.  646  Furthermore,  the  difference  between  retail  and 
 wholesale  performance  was  approximately  a  day,  647  and  BellSouth  has  demonstrated  an  upward  trend  in  its  performance.  648  Finally,  although  BellSouth  has  not  consistently  met  the  standards 
 for  charge  completeness,  649  it  has  averaged  more  than  90  percent    the  benchmark    during  the  March  to  June  period  for  both  UNE  and  interconnection  recurring  and  non-  recurring  charge 
 completeness,  with  only  one  exception.  650 


 644  During  March  through  June  2002,  BellSouth  failed  to  meet  the  parity  standard  for  resale  invoice  accuracy  in 
 Alabama  for  three  months  and  Mississippi  and  South  Carolina  each  for  one  month.  See  Alabama/  Mississippi/  South  Carolina  A.  4.1  (Invoice  Accuracy    Resale).  BellSouth  also  failed  to  meet  the  parity  standard  for  UNE  invoice 


 accuracy  for  two  months  for  both  Alabama  and  Mississippi  during  the  relevant  period.  See  Alabama/  Mississippi  B.  4.1  (Invoice  Accuracy    UNE). 


 645  However,  BellSouth  still  averaged  nearly  99%  resale  invoice  accuracy  for  competitive  LECs  in  Mississippi 
 and  South  Carolina.  See  Mississippi/  South  Carolina  A.  4.1  (Invoice  Accuracy    Resale).  BellSouth  averaged  more  than  98%  UNE  invoice  accuracy  for  competitive  LECs  in  Mississippi  and  more  than  99%  for  competitive  LECs  in 


 Alabama    a  higher  average  performance  in  Alabama  during  the  past  four  months  for  BellSouth  wholesale  than  for  BellSouth  retail.  See  Alabama/  Mississippi  B.  4.1  (Invoice  Accuracy    UNE). 


 646  Performance  data  show  that  BellSouth  has  not  consistently  met  the  parity  standard  for  metric 
 Alabama/  Kentucky/  Mississippi/  South  Carolina/  North  Carolina  B.  4.2.  (Mean  Time  to  Deliver  UNE  Invoices    CRIS).  From  March  to  June  2002,  BellSouth  missed  the  parity  standard  three  times.  BellSouth  explains  that  these 


 delays  were  associated  with  the  initial  implementation  of  a  new  enhanced  billing  system,  Integrated  Billing  System  (  IBS),  and  that  those  issues  have  been  resolved.  BellSouth  Varner  Reply  Aff.  at  para.  236;  BellSouth  Scollard 
 Aff.  at  paras.  8-  10. 
 647  The  gap  in  performance  during  the  four-  month  period  was  only  about  a  day,  which  is  not  a  substantial  period 
 of  time  for  this  metric  (an  average  of  4.  85  days  for  competitive  LECs  and  3.  71  days  for  BellSouth  from  March  to  June). 


 648  BellSouths  performance  has  demonstrated  an  upward  trend  from  March,  when  BellSouth  delivered  invoices 
 in  a  mean  time  of  7.29  days,  to  June,  when  BellSouth  met  the  parity  standard  and  delivered  invoices  in  a  mean  time  of  3.46  days.  See  Alabama/  Kentucky/  Mississippi/  South  Carolina/  North  Carolina  B.  4.2  (Mean  Time  to  Deliver 


 UNE  Invoices    CRIS). 
 649  See  generally  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  F.  9.5  (Recurring  Charge 
 Completeness);  Alabama/  Kentucky/  Mississippi/  South  Carolina/  North  Carolina  F.  9.6  (Non-  Recurring  Charge  Completeness). 


 650  Id.  The  exception  is  South  Carolina.  However,  March  and  April  performance  in  South  Carolina  were  both 
 abnormally  low.  These  two  months  are  at  least  partially  explained  by  the  extremely  low  volumes  for  interconnection  orders,  and  BellSouth  met  the  standard  for  May  and  June.  In  addition,  BellSouth  has  implemented 


 or  is  in  the  process  of  implementing  new  procedures  to  eliminate  or  correct  these  errors.  See  BellSouth  Varner  Aff.  Exh.  PM-  6  at  30-  32. 
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 175.  Moreover,  our  findings  that  competing  carriers  have  a  meaningful  opportunity  to  compete  are  supplemented  by  the  results  of  the  KPMG  third-  party  audit  in  Georgia,  which  found 
 BellSouths  billing  systems  to  be  accurate  and  reliable.  651  However,  we  note  that,  should  BellSouths  performance  in  this  area  deteriorate,  we  will  pursue  appropriate  enforcement  action. 


 176.  We  reject  competitive  LECs  contentions  that  BellSouth  fails  to  provide  nondiscriminatory  access  to  its  billing  functions.  AT&  T  and  NewSouth  assert  that  the  bills  that 
 they  have  received  from  BellSouth  contain  numerous  errors.  652  In  response,  BellSouth  states  that  AT&  T  has  disputed  only  about  1.5  percent  of  AT&  Ts  total  CABS  bills,  653  and  that  BellSouths 
 billing  to  NewSouth  has  been  accurate  more  than  95  percent  of  the  time.  654  AT&  T  also  claims  that  BellSouth  fails  to  respond  to  AT&  Ts  complaints  about  alleged  errors  in  billing  in  a  timely 
 fashion.  655  BellSouth  notes  that  the  parties  interconnection  agreement  provides  a  60-  day  period  for  BellSouth  to  respond.  656  In  addition,  BellSouth  and  AT&  T  meet  monthly  to  discuss  billing 
 disputes  and  other  issues.  657  Given  the  small  percentage  of  disputed  bills  and  the  overall  accuracy  of  BellSouths  billing,  we  find  that  AT&  Ts  and  NewSouths  allegations  do  not 
 indicate  a  systemic  failure  of  BellSouth  systems  or  processes;  instead,  they  are  indicative  of  the  type  of  disputes  over  bills  that  arise  in  the  normal  course  of  business.  Furthermore,  there  is  no 
 evidence  demonstrating  that  BellSouth  acts  in  a  discriminatory  manner  or  denies  competitors  a  meaningful  opportunity  to  compete.  To  the  extent  that  billing  disputes  arise,  carriers  are  able  to 
 address  their  disputes  through  the  billing  dispute  resolution  process  outlined  in  their  interconnection  agreements  658    and  the  record  indicates  that  they  are  actively  doing  so.  659 


 651  See  KPMG  Georgia  MTP  Final  Report  at  III-  C-  1  through  III-  C-  12  (Summary  of  Tests  BLG1  through  BLG5) 
 and  at  VI-  A  through  VI-  F  (Billing  Results  and  Analysis);  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9114-  15,  para.  174.  For  a  discussion  of  our  reliance  upon  the  Georgia  third-  party  test,  see  section  IV.  B.  2.  a,  supra. 


 652  AT&  T  Bradbury/  Norris  Decl.  at  para.  109;  Letter  from  John  J.  Heitmann,  Counsel  to  NewSouth,  to  Marlene 
 H.  Dortch,  Secretary,  Federal  Communications  Commission,  WC  Docket  No.  02-  150  at  7  (filed  Aug.  5,  2002)  (NewSouth  August  5  Ex  Parte  Letter).  AT&  T  claims  that  many  of  the  problems  arising  six  or  more  months  ago 


 remain  unresolved.  Id.  at  para.  110.  For  example,  AT&  T  claims  that  BellSouth  has  billed  AT&  T  several  hundred  thousand  dollars  for  originating  switching  charges  even  when  the  traffic  originates  on  AT&  Ts  switch;  billed  AT&  T 
 monthly  for  one-  time  charges  associated  with  collocations;  failed  to  bill  AT&  T  for  local  minutes  of  use  for  a  six-month  period;  sent  AT&  T  bills  on  new  accounts  that  erroneously  list  past  due  balances;  and  sent  retail,  instead  of 
 wholesale,  bills  to  AT&  T.  AT&  T  Bradbury/  Norris  Decl.  at  para.  109.  NewSouth  has  disputed  $8.2  million  in  charges  assessed  by  BellSouth  during  the  past  two  years.  Of  the  $8.  2  million  disputed,  $5  million  worth  of  disputes 
 have  been  resolved,  with  66%  resolved  in  NewSouths  favor.  NewSouth  August  5  Ex  Parte  Letter 
 653  BellSouth  Scollard  Reply  Aff.  at  para.  3.  The  Carrier  Access  Billing  System,  or  CABS,  is  used  by  BellSouth 
 to  bill  for  most  UNE  and  interconnection  services.  BellSouth  Scollard  Aff.  at  para.  7. 
 654  BellSouth  August  15  Non-  pricing  Ex  Parte  Letter  at  5. 


 655  AT&  T  Bradbury/  Norris  Decl.  at  para.  110. 
 656  BellSouth  Scollard  Reply  Aff.  at  para.  13. 
 657  Id. 
 658  Id.  at  para.  4. 
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 177.  NewSouth  also  states  that  BellSouth  does  not  remove  disputed  amounts  from  amounts  it  considers  to  be  past  due.  660  As  a  result,  NewSouth  claims  that  it  appears  that 
 NewSouth  takes  longer  to  pay  bills  than  it  actually  does,  resulting  in  BellSouths  requests  for  further  competitive  LEC  deposits.  661  BellSouth  replies  that  its  deposit  requests  are  justified  and 
 allowed  under  its  interconnection  agreement  with  NewSouth.  662  Because  we  believe  such  individualized  disputes  are  best  addressed  in  proceedings  outside  of  the  section  271 
 requirements,  663  we  do  not  find  that  NewSouths  claims  warrant  a  finding  of  checklist  noncompliance. 


 g.  Change  Management  and  Technical  Assistance 
 178.  We  conclude  that  BellSouth  demonstrates  that  it  meets  the  requirements  of  checklist  item  two  with  regard  to  change  management  and  technical  assistance  to  competing 


 carriers.  The  record  in  this  proceeding  shows  that  BellSouths  change  management  process,  and  its  performance  under  this  process,  are  comparable  to  or  better  than  what  we  approved  in  the 
 BellSouth  Georgia/  Louisiana  271  Order  recently.  664  We  find  that,  since  the  BellSouth  Georgia/  Louisiana  Order,  BellSouth  has  continued  to  improve  the  adequacy  of  its  plan  by 
 broadening  the  scope  of  the  CCP  and  by  increasing  the  role  of  competitive  LECs  in  the  process.  At  the  same  time,  we  agree  with  the  Department  of  Justice  that  many  of  the  same  problems  with 
 BellSouths  adherence  to  its  change  management  process  that  we  noted  in  the  BellSouth  Georgia/  Louisiana  Order  still  exist.  665  As  noted  by  the  Department  of  Justice,  however, 
 BellSouth  has  made  progress  in  the  past  few  months  toward  improving  its  implementation  of 
 (Continued  from  previous  page)  659  Id.  at  para.  13. 


 660  NewSouth  August  5  Ex  Parte  Letter  at  7. 
 661  Id. 
 662  BellSouth  August  15  Non-  pricing  Ex  Parte  Letter  at  5. 
 663  For  example,  the  Commission  has  suspended  BellSouths  Transmittal  No.  657  to  its  interstate  access  tariff, 
 FCC  No.  1,  to  review  similar  issues.  BellSouth  Telecommunications,  Inc.  Tariff  FCC  No.  1,  Transmittal  No.  657,  Order,  DA  02-  1886  (Pricing  Policy  Div.,  Wireline  Competition  Bur.,  rel.  Aug.  2,  2002). 


 664  BellSouth  uses  the  same  change  management  process  region-  wide.  BellSouth  Stacy  Aff.  at  para.  41. 
 Therefore,  BellSouths  Change  Control  Process  (CCP)  we  examine  here  is  the  same  plan  we  approved  in  the  BellSouth  Georgia/  Louisiana  Order,  with  the  exceptions  noted  herein.  BellSouth  Georgia/  Louisiana  Order,  17 


 FCC  Rcd  at  9118-  9122,  paras.  180-  85. 
 665  Department  of  Justice  Evaluation  at  8.  In  the  BellSouth  Georgia/  Louisiana  Order,  competitors  raised  various 
 complaints  alleging  that  BellSouths  change  management  process  did  not  afford  an  efficient  competitor  a  meaningful  opportunity  to  compete  by  providing  sufficient  access  to  the  BOCs  OSS.  Competitive  LECs  claimed, 


 among  other  things,  that  BellSouth  failed  to  implement  corrections  to  software  defects  in  a  timely  manner  and  that  there  were  unnecessary  defects  because  BellSouths  software  implementations  were  not  sufficiently  tested  before 
 release.  See  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9129,  para.  195.  Although  commenters  allegations  caused  us  concern,  we  nonetheless  found  that  BellSouth  adequately  met  the  change  management 
 requirements  of  checklist  item  two.  Id. 
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 change  requests.  666  Further,  we  recognize  that  change  management  is  not  an  area  that  can  be  considerably  improved  overnight,  and  that  time  is  required  to  demonstrate  the  results  of  process 
 enhancements. 
 179.  On  that  basis,  we  find  here  that  BellSouth  meets  the  change  management  requirements  of  checklist  item  two  for  Alabama,  Kentucky,  Mississippi,  North  Carolina,  and 


 South  Carolina.  We  recognize,  however,  that  as  a  general  matter,  section  271  requirements  are  constantly  evolving,  so  that  what  is  sufficient  for  checklist  compliance  today  may  not  be 
 sufficient  over  time.  667  In  light  of  the  short  period  that  has  passed  since  the  BellSouth  Georgia/  Louisiana  Order,  we  find  that  the  problems  with  BellSouths  change  management 
 process  identified  by  commenters  do  not  warrant  a  finding  of  checklist  noncompliance.  We  note  that,  in  this  case,  BellSouth  has  made  a  number  of  improvements  and  future  commitments  to  its 
 change  management  process  and  performance  that  fall  outside  the  period  of  our  review  of  these  applications.  As  we  make  clear  below,  we  do  not  rely  on  BellSouth  improvements  since  filing 
 this  application  or  its  future  commitments  for  our  decision  here.  668  However,  while  we  find  BellSouths  performance  to  be  adequate  here,  we  believe  it  is  essential  for  BellSouth  to  follow 
 through  on  its  commitment  to  improve  its  change  management  process  and  adherence.  We  note  specifically,  as  we  also  did  in  the  BellSouth  Georgia/  Louisiana  Order,  that  it  is  essential  that 
 BellSouth  continue  to  work  collaboratively  with  competitive  LECs  through  the  CCP  on  prioritization  issues,  provide  competitive  LECs  with  sufficient  information  to  be  able  to  make 
 informed  decisions  regarding  prioritization  of  proposed  systems  changes,  and  implement  changes  in  a  timely  manner.  669  Accordingly,  we  direct  the  Enforcement  Bureaus  Section  271 
 Compliance  Team  to  monitor  BellSouths  entire  change  management  process,  and  specifically  its  performance  under  that  process.  If  we  discover  problems  with  the  change  control  process  that 
 undermine  BellSouth's  ongoing  compliance  with  this  checklist  item,  we  will  not  hesitate  to  take  action  pursuant  to  section  271(  d)(  6). 


 (i)  Change  Management  Process 
 180.  In  its  prior  orders,  the  Commission  has  explained  that  it  must  review  a  BOCs  change  management  procedures  to  determine  whether  these  procedures  afford  an  efficient 


 competitor  a  meaningful  opportunity  to  compete  by  providing  sufficient  access  to  the  BOCs  OSS.  670  In  doing  so,  we  first  assess  whether  the  plan  is  adequate  by  determining  whether  the 
 evidence  demonstrates  that:  (1)  information  relating  to  the  change  management  process  is  clearly  organized  and  readily  accessible  to  competing  carriers;  (2)  competing  carriers  had 


 666  Department  of  Justice  Evaluation  at  8. 
 667  See  AT&  T  v.  FCC,  220  F.  3d  607,  625  (D.  C.  Cir.  2000). 
 668  See,  e.  g.,  paras.  182,  187,  189,  191-  92,  195-  96,  199-  202. 
 669  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9128-  30,  paras.  193-  95. 
 670  See  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  3999-  4000,  paras.  102-  03;  SWBT  Texas  Order,  15  FCC  Rcd 
 at  18403-  04,  paras.  106-  08. 
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 substantial  input  in  the  design  and  continued  operation  of  the  change  management  process;  (3)  the  change  management  plan  defines  a  procedure  for  the  timely  resolution  of  change 
 management  disputes;  (4)  the  availability  of  a  stable  testing  environment  that  mirrors  production;  and  (5)  the  efficacy  of  the  documentation  the  BOC  makes  available  for  the  purpose  of  building 
 an  electronic  gateway.  671  After  determining  whether  the  BOCs  change  management  plan  is  adequate,  we  evaluate  whether  the  BOC  has  demonstrated  a  pattern  of  compliance  with  this 
 plan.  672 
 (a)  Adequacy  of  the  Change  Management  Plan 
 181.  Change  Management  Plan  Organization.  Based  on  our  examination  of  the  record,  we  find,  on  balance,  that  BellSouths  CCP  plan  is  adequate  to  provide  competitive  LECs 


 access  to  BellSouth  OSS.  673  BellSouth  asserts  that,  since  the  filing  of  its  Georgia/  Louisiana  application  in  February  2002,  it  has  worked  with  competitive  LECs  to  improve  the  change 
 management  process  that  was  approved  by  the  Commission  in  the  BellSouth  Georgia/  Louisiana  Order.  674  For  example,  prior  to  filing  this  application,  BellSouth  agreed  to  competitive  LECs 
 requests  to  expand  the  definition  of  CLEC-  affecting  changes  to  BellSouths  systems,  accepting  the  competitive  LECs  proposed  definition  verbatim,  so  that  the  CCP  will  apply  to  a  broader 
 array  of  possible  changes.  675  Furthermore,  the  Department  of  Justice  and  WorldCom  acknowledge  BellSouths  efforts  to  improve  its  change  management  plan.  676 


 671  SWBT  Texas  Order,  15  FCC  Rcd  at  18404,  para.  108.  As  we  have  noted  previously,  we  are  open  to 
 consideration  of  change  management  plans  that  differ  from  those  already  found  to  be  compliant  with  the  requirements  of  section  271.  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  4004,  para.  111;  SWBT  Texas  Order,  15 


 FCC  Rcd  at  18404,  para.  109;  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9117-  18,  para.  179. 
 672  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  3999,  para.  101,  4004-  05,  para.  112. 


 673  BellSouths  Change  Control  Process  is  memorialized  in  a  single  document  entitled,  Change  Control  Process. 
 BellSouth  Stacy  Aff.  at  para.  85.,  Exh.  WNS-  13,  Change  Control  Process,  Version  3.1  (May  29,  2002)  (CCP).  The  Change  Control  Process  document  and  other  related  forms  are  available  on  BellSouths  website  and  are  updated  to 


 reflect  changes.  BellSouth  Stacy  Aff.  at  paras.  85-  86.  This  document  sets  forth  the  process  and  procedures  that  govern  the  communication  and  management  of  changes  to  electronic  interfaces  and  related  manual  processes  that 
 affect  external  users  of  BellSouths  Electronic  Interface  Applications.  See  generally  CCP  at  16. 
 674  BellSouth  Stacy  Aff.  at  para.  82.  Among  the  recent  improvements  to  the  CCP  are  the  inclusion  of  changes  to 
 the  process  only  with  the  concurrence  of  the  CCP  participants  or  as  directed  by  a  state  commission;  the  availability  of  appropriate  BellSouth  personnel  to  CCP  participants;  the  expansion  of  the  Monthly  System  Outage  Report  to 


 include  all  outages;  a  longer  notification  period  regarding  the  retirement  of  interface  versions  (from  120  to  180  days);  and  the  expansion  of  the  involvement  of  competitive  LECs  when  BellSouth  develops  and  introduces  new 
 interfaces.  BellSouth  Stacy  Aff.  at  paras.  82,  161. 
 675  BellSouth  Stacy  Aff.  at  para.  157;  BellSouth  Stacy  Reply  Aff.  at  para.  6.  A  CLEC-  affecting  change  is  any 
 change  that  potentially  may  cause  a  [competitive]  LEC  to  modify  the  way  it  operates  in  conducting  wholesale  business  transactions  with  BellSouth.  Modifications  to  the  way  [competitive]  LECs  operate  in  conducting 


 wholesale  business  transactions  with  BellSouth  include,  but  are  not  limited  to:  (1)  changes  to  [competitive]  LEC  system  code;  (2)  changes  in  [competitive]  LEC  employee  training;  (3)  changes  to  [competitive]  LEC  business 
 methods  and  procedures  at  the  transaction,  clarification,  or  escalation  levels  (4)  changes  to  the  work  assignments  of  (continued.) 
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 182.  Despite  these  improvements,  AT&  T  claims  that  BellSouths  change  management  plan  does  not  provide  adequate  information  to  competitive  carriers.  677  AT&  T  claims  that 
 BellSouth  denies  competitive  LECs  information  on  how  much  capacity  each  pending  request  will  consume,  the  changes  in  the  releases  that  BellSouth  has  scheduled  for  implementation  in  the 
 remainder  of  2002,  and  the  information  necessary  for  competitive  LECs  to  compare  projected  and  actual  release  capacity.  678  In  direct  contradiction  to  AT&  Ts  claims,  BellSouth  argues  that  it 
 has  agreed  to  provide  competitive  LECs  with  additional  information  concerning  future  change  requests  and  their  capacity  so  that  competitive  LECs  can  prioritize  change  requests  more 
 efficiently.  679  We  find  that,  overall,  BellSouths  change  management  plan  is  sufficient  for  checklist  compliance.  Specifically,  we  find  that  BellSouth  is  providing  competitive  LECs  with 
 sufficient  information  to  be  able  to  make  informed  decisions  regarding  prioritization  of  proposed  systems  changes.  680  In  addition,  BellSouth  is  providing  more  information  to  competitive  LECs 
 than  at  the  time  we  approved  the  Georgia/  Louisiana  application.  681  Moreover,  although  we  do  not  rely  upon  these  actions  for  our  decision,  state  commissions  continue  to  oversee 
 improvements  to  BellSouths  change  management  process.  682  Most  notably,  BellSouth  and  competitive  LECs  are  working  collaboratively  to  enhance  BellSouths  CCP  under  the  auspices  of 


 (Continued  from  previous  page)  [competitive]  LEC  personnel.  Internal  BellSouth  process  changes  (either  software  or  procedural)  unique  to  the 
 [competitive]  LEC  wholesale  environment  are  competitive  LEC  affecting.  BellSouth  Stacy  Aff.  at  para.  85,  Exh.  WNS-  13  (CCP  at  79). 


 676  Department  of  Justice  Evaluation  at  8;  WorldCom  Comments  at  1. 
 677  AT&  T  Bradbury/  Norris  Decl.  at  para.  26. 
 678  Id.  According  to  BellSouth,  capacity  is  measured  in  units.  Each  unit  represents  100  hours  of  programmer 
 time.  BellSouth  routinely  provides  software  programming  information  to  competitive  LECs  in  these  units  under  CCP  requirements.  For  example,  BellSouth  publishes  projected  and  historical  information  on  the  number  of  units 


 necessary  to  implement  software  changes.  Letter  from  Glenn  T.  Reynolds,  Vice  President    Federal  Regulatory,  BellSouth,  to  Marlene  H.  Dortch,  Secretary,  Federal  Communications  Commission,  WC  Docket  No.  02-  150  at  6 
 (filed  Aug.  16,  2002)  (BellSouth  August  16  CCP  Ex  Parte  Letter).  BellSouth  has  agreed  to  provide  to  the  competitive  LECs  information  on  BellSouths  legacy  system  releases  via  the  CCP  website,  all  BellSouth 
 maintenance  release  information  via  the  CCP  Change  Control  Release  Schedule,  and  is  now  posting  all  change  requests  to  the  Flagship  Feature  Release  Schedule  for  competitive  LECs  use.  BellSouth  Stacy  Reply  Aff.  at  para. 
 7.  In  addition,  BellSouth  has  provided  the  2002  and  2003  capacity  information  to  the  competitive  LECs,  and  will  continue  to  provide  capacity  reports  on  a  quarterly  basis.  BellSouth  Stacy  Reply  Aff.  at  para.  25.  BellSouth  also 
 publishes  a  quarterly  tracking  report,  which  summarizes  the  status  of  change  requests.  Id.;  see  also  Letter  from  Kathleen  B.  Levitz,  Vice  President    Federal  Regulatory,  BellSouth,  to  Marlene  H.  Dortch,  Secretary,  Federal 
 Communications  Commission,  WC  Docket  No.  02-  150  at  2  (filed  Aug.  30,  2002)  (BellSouth  August  30  Ex  Parte  Letter). 


 679  BellSouth  Stacy  Aff.  at  paras.  158-  59;  BellSouth  Stacy  Reply  Aff.  at  para.  7. 
 680  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9128,  para.  193. 
 681  BellSouth  Stacy  Aff.  at  paras.  82,  89. 
 682  BellSouth  Stacy  Aff.  at  para.  81;  see  also  Alabama  Commission  Comments  at  166-  70;  Kentucky  Commission 
 Comments  at  27-  29;  Mississippi  Commission  Comments  at  14-  16;  North  Carolina  Commission  Comments  at  154-  57;  South  Carolina  Commission  Comments  at  3. 
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 the  Georgia  and  Florida  Commissions.  683  The  change  management  process  is  designed,  by  nature,  as  an  evolving  one,  684  and  we  are  confident  that  it  is  continuing  to  improve,  as  evidenced 
 by  the  changes  agreed  to  by  BellSouth,  CCP  participants,  and  state  commissions.  685 
 183.  Competing  Carrier  Input.  AT&  T  alleges  that  BellSouth  does  not  allow  competing  carriers  adequate  input  into  the  change  management  process.  686  Specifically,  AT&  T 


 claims  that  BellSouth  has  complete  control  over  the  implementation  of  competitive  LEC  change  requests.  687  As  an  initial  matter,  we  find  that  the  version  of  BellSouths  CCP  included  with  this 
 application    Version  3.1,  filed  May  29,  2002    was,  like  the  earlier  versions,  developed  as  the  result  of  a  collaborative  process  between  competitive  LECs  and  BellSouth.  688  From  April 
 through  June  2002,  29  meetings  related  to  the  CCP  were  held  between  BellSouth  and  competitive  LECs.  689  Therefore,  we  believe  the  record  indicates  consistent  BellSouth 
 collaboration  with  competitive  LECs. 
 184.  To  address  concerns  raised  in  the  KPMG  third-  party  test  in  Florida,  BellSouth  proposed  the  concept  of  a  50/  50  plan  on  February  12,  2002.  690  After  the  May  2,  2002  CCP 


 meeting,  BellSouth  proceeded  to  implement  the  50/  50  plan.  691  The  50/  50  plan,  described  in 
 683  BellSouth  Stacy  Aff.  at  para.  81;  BellSouth  Stacy  Reply  Aff.  at  para.  24.  During  industry  workshops  in 
 Georgia  PSC  Docket  No.  7892-  U,  the  competitive  LECs  requested,  and  the  Georgia  Commission  agreed  to,  the  establishment  of  a  process  by  which  further  changes  to  the  CCP  could  be  addressed.  This  process  has  two  phases: 


 the  first,  which  is  nearly  complete,  involves  the  consideration  of  additional  performance  measures  related  to  the  CCP,  while  the  second  phase  involves  changes  to  the  CCP  itself.  Id.  The  Georgia  and  Florida  Commissions  have 
 ordered  or  are  considering  the  implementation  of  metrics  measuring  change  management  performance.  Letter  from  Kathleen  B.  Levitz,  Vice  President    Federal  Regulatory,  BellSouth,  to  Marlene  H.  Dortch,  Secretary,  Federal 
 Communications  Commission,  WC  Docket  No.  02-  150  at  1-  2  (filed  Aug.  9,  2002)  (BellSouth  August  9  CCP  Ex  Parte  Letter). 


 684  SWBT  Texas  Order,  15  FCC  Rcd  at  18410,  para.  117  (stating  that  the  Commission  does  not  expect  any  change 
 management  process  to  remain  static.) 
 685  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9119-  20,  para.  182. 


 686  AT&  T  Bradbury/  Norris  Decl.  at  paras.  18-  20. 
 687  Id.  at  para.  19. 
 688  BellSouth  Stacy  Aff.  at  para.  89;  BellSouth  Stacy  Reply  Aff.  at  para.  16. 
 689  Id.  at  para.  17. 
 690  See  id.  at  para.  30;  Consideration  of  BellSouth  Telecommunications,  Inc.  s  Entry  into  InterLATA  Services 
 Pursuant  to  Section  271  of  the  Federal  Telecommunications  Act  of  1996,  Docket  No.  960786B-  TL,  and  Petition  of  Competitive  Carriers  for  Commission  Action  To  Support  Local  Competition  in  BellSouth  Telecommunications, 


 Inc.  s  Service  Territory,  Docket  No.  981834-  TP,  Order  Requiring  Implementation  of  End-  to-  End  Process  Flow,  Draft  Version  2.1,  Order  No.  PSC-  02-  1034-  FOF-  TP  at  7  (July  30,  2002)  (Florida  50/  50  Plan  Order).  The  Florida 
 Commission  also  stated  that  it  intends  to  monitor  BellSouths  change  management  process  during  the  next  year.  Id.  at  7. 


 691  See  AT&  T  Bradbury/  Norris  Decl.  at  para.  20;  see  also  Letter  from  Kathleen  B.  Levitz,  Vice  President   
 Federal  Regulatory  BellSouth,  to  Marlene  H.  Dortch,  Secretary,  Federal  Communications  Commission,  WC  Docket  (continued.) 
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 detail  in  the  proprietary  End-  to-  End  Process  Flow,  Version  2.1  document,  is  designed  to  allocate  software  release  capacity  between  BellSouth  and  competitive  LECs.  692  Generally  speaking, 
 competing  carriers  that  wish  to  introduce  a  change  to  BellSouths  OSS  can  submit  a  change  request  to  the  CCP.  693  After  the  BellSouth  change  control  manager  validates  the  change,  694 
 competitive  LECs  jointly  prioritize  change  requests  using  information  BellSouth  provides  about  the  approximate  size  of  each  change  request  feature  and  estimates  of  available  capacity  in  future 
 releases.  695  Under  the  process  reviewed  in  the  BellSouth  Georgia/  Louisiana  Order,  BellSouth  then  internally  reviews  the  prioritization  and  sequences  change  requests  beginning  with  the  top 
 priority  request.  696  Under  the  new  50/  50  release  plan,  BellSouth  will  have  its  own  releases  and  competitive  LECs  will  jointly  have  their  own  releases.  697  The  plan  first  requires  implementation 
 of  all  regulatory  mandates,  all  needed  industry  standard  updates  and  all  scheduled  repairs  to  fix  defects.  698  After  those  changes  are  implemented,  competitive  LECs  and  BellSouth  share  equally 


 (Continued  from  previous  page)  No.  02-  35  (filed  May  14,  2002)  (dividing  releases  according  to  BellSouth  production  and  competitive  LEC 
 production)  (BellSouth  May  14  Ex  Parte  Letter).  BellSouth  began  using  the  plan  internally  and  to  provide  information  to  competitive  LECs  prior  to  the  filing  of  this  application.  BellSouth  Stacy  Aff.  at  para.  170,  Exh.  37  at 
 7-  8.  The  Florida  Commission  ordered  the  adoption  of  the  50/  50  plan  on  July  30,  2002,  to  address  Exception  88  in  the  KPMGs  June  21,  2002  Draft  Final  Operations  Support  Systems  Report.  Florida  50/  50  Plan  Order  at  7-  8. 


 692  BellSouth  Stacy  Reply  Aff.  at  para.  29. 
 693  See  BellSouth  Stacy  Aff.  at  para.  85,  Exh.  WNS-  13  (CCP  at  33). 
 694  BellSouth  will  validate  the  change  request  unless  the  change  goes  beyond  BellSouths  obligations  under 
 Commission  orders,  is  not  technically  feasible,  or  requires  BellSouth  to  make  a  substantial  investment  for  a  limited  competing  carrier  benefit.  See  BellSouth  Stacy  Aff.  at  para.  85,  Exh.  WNS-  13  (CCP  at  33)  (describing  the  process 


 flow  for  request  types  2-  5).  We  note  that  two  new  performance  metrics  will  measure  whether  BellSouth  performs  this  step  within  the  10-  day  interval  (CM-  7)  and  will  measure  how  many  requests  are  denied  by  BellSouth  for  any  of 
 the  reasons  stated  above  (CM-  8).  BellSouth  August  9  CCP  Ex  Parte  Letter  at  1-  2. 
 695  In  preparation  for  the  monthly  meeting  presentation,  BellSouth  has  five  to  seven  business  days  to  prepare  a 
 preliminary  assessment  of  the  size  and  scope  of  the  proposed  change.  BellSouth  Stacy  Aff.  at  para.  85,  Exh.  WNS-13  (CCP  at  37-  39)  (steps  four  and  five  of  the  process  flow  for  request  types  2-  5)  and  paras.  85,  Exh.  WNS-  13  (CCP 


 at  61-  64)  (detailing  the  prioritization  process).  We  note  that  BellSouth  recently  has  provided  competitive  LECs  with  available  capacity  and  a  release  schedule  for  each  release  planned  for  2003,  which  will  provide  competitive 
 LECs  an  additional  tool  to  more  efficiently  prioritize  change  requests. 
 696  BellSouth  Stacy  Aff.  at  para.  85,  Exh.  WNS-  13  (CCP  at  39)  (step  seven  of  the  process  flow  for  request  types 
 2-  5)  and  para.  85,  Exh.  WNS-  13  (CCP  at  64);  Letter  from  Kathleen  B.  Levitz,  Vice  President    Federal  Regulatory,  BellSouth,  to  Marlene  H.  Dortch,  Secretary,  Federal  Communications  Commission,  WC  Docket  No.  02-  150  at  1-  2 


 (filed  Aug.  21,  2002)  (BellSouth  August  21  Ex  Parte  Letter).  BellSouth  adequately  explains  its  internal  processes  to  competing  carriers  through  documentation  and  discussions  at  CCP  meetings.  BellSouth  Stacy  Aff.  at  para.  86; 
 BellSouth  Stacy  Reply  Aff.  at  para.  8.  Also,  as  noted  above,  competing  carriers  have  an  opportunity  for  input  at  release  package  meetings. 


 697  BellSouth  Stacy  Aff.  at  para.  167;  BellSouth  Stacy  Reply  Aff.  at  para.  9. 
 698  BellSouth  July  16  Ex  Parte  Letter  at  Att.  3,  p.  6.  The  CCP  is  designed  to  accommodate  six  different 
 categories  of  changes:  Type  1  requests  are  for  system  outages;  Type  2  requests  are  for  changes  mandated  by  regulatory  authorities;  Type  3  changes  are  for  updating  interfaces  to  an  industry  standard;  Type  4  requests  are 


 (continued.) 
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 the  remaining  release  capacity  for  the  year.  699  BellSouth  schedules  its  change  requests  and  shows  competitive  LECs  the  changes  it  had  initiated  and  intended  to  implement.  700  Likewise, 
 competitive  LECs  prioritize  their  change  requests,  and  these  are  slotted  for  implementation  in  competitive  LEC  releases.  701  BellSouth  and  competitive  LECs  each  have  the  right  to  prioritize 
 the  features  in  their  releases.  702 
 185.  We  disagree  with  AT&  Ts  characterization  of  BellSouths  50/  50  plan  as  patently  inadequate.  703  AT&  T  claims  that  the  50/  50  plan  arbitrarily  divides  releases  between 


 competitive  LECs  and  BellSouth,  instead  of  prioritizing  and  implementing  both  BellSouth  and  competitive  LEC  change  requests  as  needed.  704  Covad  also  claims  that  the  current  change 
 control  process  is  entirely  within  the  control  of  BellSouth.  705  We  find  that  BellSouths  proposal  allows  competitive  LECs  at  least  the  same  level  of  control  over  the  prioritization  of  their  change 
 requests  than  they  had  under  previous  versions  of  BellSouths  prioritization  process,  including 


 (Continued  from  previous  page)  BellSouth  initiated  changes;  Type  5  requests  are  competitive  LEC  initiated  changes;  and  Type  6  requests  are  to 
 correct  system  defects.  BellSouth  Stacy  Aff.  at  para.  85,  Exh.  WNS-  13  (CCP  at  23-  25);  BellSouth  Stacy  Aff.  at  paras.  136-  38.  The  process  for  each  type  is  well  defined,  including  timeliness  intervals,  and  an  expedited  procedure 
 is  also  available  for  all  Types  2  through  5  change  requests.  BellSouth  Stacy  Aff.  at  para.  85,  Exh.  WNS-  13  (CCP  at  26-  60). 


 699  BellSouth  July  16  Ex  Parte  Letter  at  Att.  3,  p.  6. 
 700  Id. 
 701  Id. 
 702  BellSouth  Stacy  Aff.  at  para.  167;  see  also  BellSouth  August  21  Ex  Parte  Letter  at  1-  2.  We  note  that 
 WorldCom  has  alleged  that  BellSouth  is  not  following  its  new  processes  to  implement  prioritized  change  requests.  Letter  from  Keith  L.  Seat,  Senior  Counsel    Federal  Advocacy,  World  Com,  to  Marlene  H.  Dortch,  Secretary, 


 Federal  Communications  Commission,  WC  Docket  No.  02-  150  at  1-  2  (filed  Sept.  12,  2002)  (WorldCom  September  12  Ex  Parte  Letter).  BellSouth  proposed  on  August  30,  2002,  that  competitive  LECs  change  their  prioritization 
 schedule.  Id.;  see  also  Letter  from  Kathleen  B.  Levitz,  Vice  President    Federal  Regulatory,  BellSouth,  to  Marlene  H.  Dortch,  Secretary,  Federal  Communications  Commission,  WC  Docket  No.  02-  150  at  Att.  1.  (filed  Sept.  4,  2002) 
 (BellSouth  September  4  Ex  Parte  Letter).  However,  because  of  our  freeze  frame  rule,  we  decline  to  consider  these  allegations  in  this  application.  See  Updated  Filing  Requirements  for  Bell  Operating  Company  Applications  Under 
 Section  271  of  the  Communications  Act,  Public  Notice,  16  FCC  Rcd  20948,  20950-  51  (2001)  (271  Filing  Requirements). 


 703  AT&  T  Comments  at  9.  AT&  T  also  claims  that  BellSouth  refuses  to  consider  any  change  to  the  CCP  that 
 would  alter  its  current,  exclusive  control  over  the  prioritization,  implementation,  timing  and  sequencing  of  change  requests.  AT&  T  Bradbury/  Norris  Decl.  at  para.  18.  We  believe  that  BellSouths  proposal  establishes  that  this  claim 


 is  inaccurate.  Furthermore,  as  AT&  T  notes,  disputes  regarding  the  change  management  process  are  now  being  considered  by  the  Georgia  Commission.  AT&  T  Bradbury/  Norris  Decl.  at  paras.  22-  24.  As  the  CCP  calls  for  state 
 commission  resolution  of  disputes  between  the  parties,  the  Georgia  Commissions  consideration  of  outstanding  issues  demonstrates  that  the  process  is  working  in  that  respect.  BellSouth  Stacy  Reply  Aff.  at  paras.  16,  24-  28. 


 704  AT&  T  Bradbury/  Norris  Decl.  at  para.  19;  see  also  Florida  50/  50  Plan  Order  at  6. 
 705  Covad  Comments  at  21. 
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 the  one  approved  in  the  BellSouth  Georgia/  Louisiana  Order.  706  We  also  reject  AT&  Ts  assertion  that  BellSouths  control  over  BellSouth  releases  and  over  the  total  amount  of  capacity  available 
 for  all  releases  means  that  carriers  do  not  have  adequate  input  into  the  change  management  process.  707  We  have  only  required  BOCs  to  provide  competitive  LECs  opportunities  for 
 meaningful  input  in  the  change  management  process,  not  to  relinquish  control  over  their  systems  or  to  provide  unlimited  resources  to  implement  all  change  requests.  708  BellSouths 
 reasonable  limitations  do  not  hinder  the  competitive  LECs  ability  to  provide  sufficient  input.  Furthermore,  BellSouth  has  recently  expanded  the  definition  of  CLEC-  affecting  in  a  manner 
 that  will  increase  the  amount  of  information  BellSouth  provides  to  competitive  LECs  regarding  future  releases.  709  Overall,  we  find  that  BellSouths  plan  will  ensure  that  competitive  LECs  are 
 informed  about  the  effects  of  systems  changes.  As  the  Department  of  Justice  notes,  KPMGs  Draft  Final  Report  states  that  the  BellSouth  proposals  to  increase  competitive  LEC  participation 
 in  the  prioritization  of  change  requests  would,  if  implemented,  address  the  concerns  identified  in  the  exception.  710  We  also  take  comfort  in  the  fact  that  BellSouth  appears  to  be  continuing  to 
 improve  its  change  management  process  under  the  auspices  of  the  Georgia  and  Florida  Commissions,  711  and  we  expect  BellSouth  to  continue  to  collaborate  with  competitive  LECs.  712 


 186.  Dispute  Resolution.  As  we  found  in  the  BellSouth  Georgia/  Louisiana  Order,  we  find  that  the  BellSouth  CCP  defines  a  procedure  for  the  timely  resolution  of  change 
 management  disputes.  713  Since  the  BellSouth  Georgia/  Louisiana  Order,  BellSouth  proposed  that  the  escalation  process  begin  and  end  at  higher  management  levels  than  was  provided  for  in 


 706  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9120-  21  &  n.  689,  para.  183. 
 707  Id. 
 708  See  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  4001-  02,  4011-  12,  paras.  106,  124;  SWBT  Texas  Order,  15 
 FCC  Rcd  18406,  para.  111;  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9128-  28,  para.  194. 
 709  BellSouth  Stacy  Aff.  at  para.  157. 


 710  Department  of  Justice  Evaluation  at  9;  KPMG  Draft  Final  Staff  Report  at  RMI  14-  19. 
 711  In  addition  to  Floridas  adoption  of  BellSouths  50/  50  plan,  we  note  that  the  Georgia  Commission  is  also 
 considering  adoption  of  this  plan.  AT&  T  Bradbury/  Norris  Decl.  at  para.  23.  As  change  management  is  a  region-wide  process,  changes  made  by  one  state  commission  have  the  potential  to  affect  the  entire  process. 


 712  We  recognize  that  some  discrete  steps  in  the  change  management  process  may  necessarily  involve  less 
 collaboration  than  others.  However,  we  note  that  effective  change  management  processes  require  a  good  working  relationship  between  BOCs  and  competing  carriers  and  that  efforts  to  develop  more  transparent  processes  enhance 


 the  usefulness  of  the  process  for  competing  carriers  as  well  as  BOCs.  In  fact,  through  a  collaborative  effort  in  the  CCP  actively  monitored  by  the  Georgia  Commission,  participants  are  negotiating  improvements  to  the  feature  sizing 
 and  resource  allocation  elements  of  the  CCP  and  are  considering  adding  intervals  for  implementing  feature  requests.  These  steps  could  improve  the  transparency  of  software  release  decisions.  We  encourage  BellSouth  to  continue  to 
 accommodate  competitive  LEC  requests  to  improve  the  transparency  and  effectiveness  of  its  CCP. 
 713  SWBT  Texas  Order,  15  FCC  Rcd  at  18404,  para.  108;  BellSouth  Georgia/  Louisiana  Order  at  9123,  para.  186; 
 BellSouth  Stacy  Aff.  at  para.  85,  Exh.  WNS-  13  (CCP  at  59-  63);  see  also  BellSouth  Stacy  Aff.  at  paras.  92-  97. 
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 the  CCP.  714  As  a  result,  if  necessary,  disputes  will  now  be  escalated  to  BellSouths  Network  Vice  President  for  Wholesale  Operations.  715 
 187.  Testing  Environment.  We  find  that  BellSouths  testing  environments  allow  competing  carriers  the  means  to  successfully  adapt  their  systems  to  changes  in  BellSouths  OSS. 
 The  same  testing  processes  and  systems  are  used  to  perform  testing  in  the  five  states  in  this  application  as  were  reviewed  and  approved  in  Georgia  and  Louisiana,  and  no  party  raises  an 
 issue  in  this  proceeding  that  causes  us  to  change  this  determination.  BellSouths  original  testing  environment  is  used  to  allow  competing  carriers  to  shift  from  a  manual  process  to  an 
 electronic  interface,  or  when  upgrading  to  a  new  industry  standard.  716  BellSouth  offers  its  more  recently  developed  [Competitive  LEC]  Application  Verification  Environment  (CAVE)  test 
 environment  to  test  the  ordering  and  pre-  ordering  functions  of  upgrades  to  the  EDI,  TAG,  and  LENS  interfaces.  717  We  are  thus  able  to  conclude,  for  the  same  reasons  we  did  in  the  BellSouth 
 Georgia/  Louisiana  Order,  that  BellSouths  testing  processes  are  adequate. 
 188.  AT&  T  argues  that  the  number  of  defects  contained  in  BellSouths  latest  software  release  indicates  that  BellSouths  testing  processes  are  either  not  adequate  or  not  being  properly 


 followed.  718  Although  we  recognize  that  BellSouth  has  experienced  a  number  of  defects  in  its  software  releases,  719  commenters  have  not  provided  the  evidence  necessary  to  demonstrate  that 
 these  defects  are  a  result  of  a  failure  by  BellSouth  to  follow  its  testing  procedures.  720  Based  on  the  evidence  in  the  record,  we  also  are  not  convinced  that  rejection  is  warranted  based  on 
 AT&  Ts  allegation  that  the  CAVE  test  scenarios  do  not  completely  mirror  what  individual  carriers  typically  order  in  the  production  environment.  721  The  Commission  has  never  required 


 714  BellSouth  Stacy  Aff.  at  para.  97.  The  escalation  will  begin  with  Operations  Assistant  Vice  President  and 
 end  with  Network    Vice  President.  BellSouth  Stacy  Reply  Aff.  at  para.  8.  CCP  participants  agreed  unanimously  to  this  change  as  part  of  ballot  13,  which  was  distributed  on  July  15,  2002,  and  BellSouth  updated  the  CCP  web  site 


 on  July  29,  2002.  Id.  Before  the  competitive  LECs  voted,  the  extra  escalation  step  was  optional,  not  mandatory,  for  competitive  LECs.  Id. 


 715  BellSouth  Stacy  Aff.  at  para.  97. 
 716  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9123  n.  701;  BellSouth  Stacy  Aff.  at  para.  99;  BellSouth 
 Stacy  Reply  Aff.  at  para.  94. 
 717  Id.  BellSouth  has  expanded  CAVE  testing  opportunities  for  competitive  LECs,  expanded  and  formalized  pre-release 
 communications  with  competitive  LECs  concerning  defects  and  has  proposed  a  formal  process  for  deferring  implementation  of  a  release  due  to  defects,  including  a  competitive  LEC  go/  no  go  recommendation  on  release 


 implementation.  BellSouth  August  16  CCP  Ex  Parte  Letter  at  6. 
 718  AT&  T  Comments  at  11  (stating  that  [  t]  he  Commission  has  already  noted  BellSouths  failure  to  comply  with 
 its  own  testing  procedures  and  its  resultant  inability  to  complete  software  releases  without  numerous  defects.). 
 719  For  a  discussion  of  BellSouths  software  quality,  see  section  IV.  B.  2.  g.(  b),  infra. 


 720  Rather,  most  of  the  defects  were  the  result  of  orders  caught  in  the  transition  from  Release  10.4  to  Release  10.5. 
 BellSouth  Stacy  Reply  Aff.  at  para.  77. 
 721  AT&  T  Bradbury/  Norris  Decl.  at  para.  57. 
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 that  test  scenarios  and  actual  production  orders  be  identical.  722  BellSouths  CAVE  testing  scenarios  are  substantially  similar  to  actual  production  orders.  Moreover,  BellSouth 
 demonstrates  that  competitive  carriers  can  acquire  test  orders  different  from  those  in  the  standard  catalog  to  more  closely  match  their  production  orders.  723  We  also  note  that  CAVE  provides 
 testing  for  a  wide  variety  of  competitive  LEC  order  types.  724  Accordingly,  we  find  these  procedures  give  competing  carriers  a  meaningful  opportunity  to  compete. 


 189.  Several  developments  give  us  additional  comfort  in  this  area.  BellSouth  states  that  it  is  in  the  process  of  expanding  the  number  of  test  cases  it  uses  during  testing.  725  Further, 
 BellSouth  has  recently  implemented  a  pre-  release  testing  status  report  identifying  unresolved  defects,  726  and  is  continuing  to  discuss  improvements  to  the  testing  process  on  a  collaborative 
 basis  with  competitive  carriers.  727  We  encourage  BellSouth  to  continue  to  accept  and  consider,  before  deciding  to  implement  a  new  software  release,  any  input  from  competitive  LECs 
 regarding  software  problems  they  discover  during  testing. 
 190.  Documentation  Adequacy.  We  find  that  BellSouth  provides  documentation  sufficient  to  allow  competing  carriers  to  design  their  systems  in  a  manner  that  will  allow  them  to 


 communicate  with  BellSouths  relevant  interfaces.  728  BellSouth  uses  the  same  documentation  processes  and  systems  in  the  five  states  in  this  application  as  we  reviewed  and  approved  in 


 722  SWBT  Texas  Order,  15  FCC  Rcd  at  18421-  22,  para.  138. 
 723  BellSouth  Stacy  Reply  Aff.  at  para.  106. 
 724  AT&  T  claimed  that  when  it  tested  BellSouths  parsed  CSR  functionality  in  April  2002  (three  months  after  the 
 functionality  was  implanted  in  commercial  production),  it  received  error  messages  because  that  functionality  had  not  been  implemented  in  CAVE.  AT&  T  Comments  at  11.  BellSouth  explained  that  its  initial  test  plan  with  AT&  T 


 did  not  include  testing  of  the  parsed  CSR  functionality.  BellSouth  Stacy  Aff.  at  para.  112.  While  AT&  Ts  testing  was  in  progress,  modifications  were  made  to  AT&  Ts  test  plan  to  add  parsed  CSR  testing.  BellSouth  Stacy  Reply 
 Aff.  at  para.  106.  The  parsed  CSR  functionality  was  operational  in  CAVE  prior  to  implementation  in  the  production  environment.  Id. 


 725  BellSouth  August  16  CCP  Ex  Parte  Letter  at  5. 
 726  This  report  provides  competitive  LECs  with  information  on  defects/  issues  in  the  release.  BellSouth  will 
 update  this  report  on  a  daily  basis  until  production  implementation  of  the  release.  BellSouth  Stacy  Reply  Aff.  at  para.  11.  BellSouth  is  also  conducting  weekly  conference  calls  during  pre-  release  CAVE  testing  to  provide  the 


 opportunity  for  comment  and  the  exchange  of  information  related  to  the  testing.  Id. 
 727  BellSouth  states  that  the  CCP  participants  are  discussing  the  establishment  of  a  testing  profile;  the  elimination 
 of  the  requirement  for  a  formal  test  agreement;  implementation  of  regression  testing;  and  the  implementation  of  a  more  defined  defect  management  process.  BellSouth  Stacy  Reply  Aff.  at  para.  11.  BellSouth  also  has  agreed  to 


 draft  change  requests  to  allow  competitive  LECs  to  test  in  CAVE  using  their  own  data  and  to  allow  competitive  LECs  to  test  multiple  versions  of  CAVE.  Id.  Additionally,  BellSouth  has  proposed  to  CCP  participants  that 
 competitive  LECs  that  have  tested  in  CAVE  participate  in  a  go/  no  go  decision  in  which  they  would  either  recommend  that  a  particular  release  go  forward  as  scheduled,  or  that  BellSouth  defer  implementation  to  a  later  date, 
 depending  upon  the  severity  of  the  defects  found  during  testing.  Id.  at  para.  12. 
 728  SWBT  Texas  Order,  15  FCC  Rcd  at  18411,  para.  119. 
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 Georgia  and  Louisiana,  and  no  party  raises  an  issue  in  this  proceeding  that  causes  us  to  change  this  determination.  729  In  particular,  BellSouth  demonstrates  that  it  makes  available  sufficiently 
 detailed  interface  design  specifications  to  offer  competing  carriers  a  meaningful  opportunity  to  compete.  730  BellSouth  demonstrates  compliance  with  its  documentation  responsibilities  by 
 showing  satisfaction  of  the  Georgia  third-  party  test  efforts  to  build  an  interface  as  well  as  demonstrating  that  competing  carriers  have  a  meaningful  opportunity  to  compete.  731 
 Furthermore,  numerous  competitors  are  now  using  electronic  interfaces  for  pre-  ordering,  ordering,  and  reporting  troubles,  732  and  the  record  does  not  indicate  that  BellSouth  provides 
 inadequate  or  discriminatory  treatment  to  these  competing  carriers.  Therefore,  we  find  that  BellSouth  demonstrates  that  it  provides  efficient  competitors  a  meaningful  opportunity  to 
 compete  by  enabling  them  to  understand  how  to  implement  and  use  all  of  the  OSS  functions  available  to  them. 


 (b)  Adherence  to  the  Change  Management  Process 
 191.  Accepting  Change  Requests.  BellSouth  demonstrates  that  it  validates  change  requests  for  acceptance  into  the  process  in  a  timely  manner  and  in  accordance  with  the  10-  day 


 interval  specified  by  the  CCP.  From  March  through  June  2002,  BellSouth  met  this  interval  for  10  out  of  13  requests.  733  We  note  that  BellSouth  has  agreed  to  implement  a  new  metric  (CM-  7) 
 that  will  measure  BellSouths  adherence  to  the  10-  day  CCP  deadline.  734  In  addition,  BellSouth  agreed  to  another  metric  (CM-  8)  that  measures  how  many  change  requests  are  denied  by 
 BellSouth  for  any  of  the  reasons  allowed  under  the  CCP.  735  BellSouth  has  adopted  both  of  these  metrics    and  their  associated  penalties    region-  wide,  including  in  the  five  states  in  this 


 729  See  BellSouth  Stacy  Aff.  at  paras.  125-  28 
 730  See  id.  at  para.  126. 
 731  See  id.  at  para.  125. 
 732  In  BellSouths  region  in  the  period  from  January  through  March  2002,  approximately  50  competing  carriers 
 used  EDI,  20  used  TAG,  and  240  used  LENS.  BellSouth  Stacy  Aff.  at  para.  15.  Using  these  interfaces,  competitive  LECs  are  submitting  more  than  1.  5  million  pre-  ordering  transactions  monthly.  BellSouth  Stacy  Aff.  at  para.  13. 


 733  BellSouth  August  30  Ex  Parte  Letter  at  2.  On  the  three  occasions  BellSouth  did  not  meet  the  interval, 
 BellSouth  notes  that  it  needed  additional  time  to  investigate  the  requests  and  informed  the  originating  competitive  LECs  that  additional  time  would  be  needed.  BellSouth  accepted  one  of  the  requests,  proposed  an  alternative 


 solution  for  another  one  of  the  requests,  and  rejected  the  third  request  that  the  competitive  LEC  subsequently  cancelled.  BellSouth  August  16  CCP  Ex  Parte  Letter  at  6. 


 734  BellSouth  August  9  CCP  Ex  Parte  Letter  at  1-  2;  see  also  Letter  from  Sean  A.  Lev,  Counsel  to  BellSouth,  to 
 Marlene  H.  Dortch,  Secretary,  Federal  Communications  Commission,  WC  Docket  No.  02-  150  at  1  (filed  Aug.  15,  2002)  (BellSouth  August  15  Metrics  Ex  Parte  Letter)  (correcting  attachment  to  August  9  CCP  Ex  Parte). 


 735  BellSouth  must  validate  the  change  request  unless  BellSouth  determines  that  the  competitive  LEC-  initiated 
 request  cannot  be  accepted  because  of  cost,  industry  direction  or  technical  infeasibility.  See  BellSouth  Stacy  Aff.  at  para.  85,  Exh.  WNS-  13  (CCP  at  36)  (describing  the  acceptance  process  for  request  types  2-  5). 
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 application.  736  Although  we  cannot  rely  on  these  metrics  for  purposes  of  the  instant  application,  we  believe  they  will  help  to  ensure  that  BellSouth  continues  to  accept  change  requests  in  a 
 timely  manner.  Also,  we  believe  metric  CM-  8  will  improve  the  ability  of  interested  parties  and  regulatory  bodies,  including  the  Commission,  to  monitor  the  reasons  behind  BellSouths 
 rejection  of  competitive  LEC  change  requests.  737  Although  the  metric  will  formally  quantify  the  number  of  change  requests  accepted  or  rejected  by  BellSouth,  it  does  not  affect  the  underlying 
 criteria  that  BellSouth  must  use  to  make  that  determination  as  outlined  in  the  CCP. 
 192.  Implementation  of  Prioritized  Changes.  Since  we  issued  the  BellSouth  Georgia/  Louisiana  Order,  BellSouth  has  made  progress  in  providing  information  to  the 


 competitive  LECs  through  the  change  management  process.  738  For  example,  BellSouth  has  provided  2002  and  2003  capacity  information  to  the  competitive  LECs  and  will  continue  to 
 provide  capacity  information  in  the  future.  739  BellSouth  has  issued  the  first  quarter  2002  capacity  use  report  using  the  format  requested  by  the  competitive  LECs,  and  BellSouth  provided 
 information  regarding  the  size  of  the  flow-  through  features  to  competitive  LECs  on  May  15,  2002.  740  In  addition,  BellSouth  is  publishing  a  quarterly  tracking  report  summarizing  the  status 
 of  the  change  requests.  741  Finally,  among  other  items,  BellSouth  and  competitive  LECs  are  working  collaboratively  to  revise  the  testing  environment  section  of  the  CCP.  742  Despite  these 
 improvements,  however,  competitive  LECs  continue  to  express  concerns  regarding  BellSouths  change  management  implementation,  focusing  primarily  on  two  issues:  the  backlog  of  approved 
 feature  change  requests  awaiting  implementation  and  the  quality  of  BellSouths  software  releases  (i.  e.,  number  of  defects).  743  We  consider  each  of  these  concerns  in  turn. 


 193.  Timely  Implementation  of  Change  Requests.  Competitive  LECs  argue  that  the  backlog  of  change  requests  awaiting  implementation  demonstrates  that  BellSouth  is  not 


 736  BellSouth  August  9  CCP  Ex  Parte  Letter  at  1-  2;  BellSouth  August  15  Metrics  Ex  Parte  Letter  at  1  (correcting 
 attachment  to  August  9  CCP  Ex  Parte);  see  also  Letter  from  Kathleen  B.  Levitz,  Vice  President    Federal  Regulatory,  BellSouth,  to  Marlene  H.  Dortch,  Secretary,  Federal  Communications  Commission,  WC  Docket  No. 


 02-  150  (filed  Aug.  22,  2000)  (BellSouth  August  22  Ex  Parte  Letter).  Failure  to  meet  these  metrics  will  result  in  Tier  II  penalties.  AT&  T  claims  that  these  penalties  are  not  sufficient  to  provide  an  incentive  for  BellSouth  to  meet 
 the  metric.  AT&  T  August  23  OSS  and  Data  Integrity  Ex  Parte  Letter  at  3.  However,  we  note  that  we  are  not  relying  upon  these  metrics  for  approval  of  this  application. 


 737  See  BellSouth  September  4  Ex  Parte  Letter  at  1;  cf.  AT&  T  September  9  Ex  Parte  Letter  at  1. 
 738  Department  of  Justice  Evaluation  at  9;  BellSouth  Stacy  Aff.  at  paras.  85-  86. 
 739  BellSouth  Stacy  Reply  Aff.  at  para.  25;  BellSouth  August  16  CCP  Ex  Parte  Letter  at  7. 
 740  BellSouth  Stacy  Reply  Aff.  at  para.  25. 
 741  Id.;  see  also  BellSouth  August  30  Ex  Parte  Letter  at  2. 
 742  BellSouth  Stacy  Reply  Aff.  at  paras.  25,  119. 
 743  AT&  T  Bradbury/  Norris  Decl.  at  paras.  31-  55;  AT&  T  August  23  OSS  and  Data  Integrity  Ex  Parte  Letter  at  1-4; 
 WorldCom  Lichtenberg  Decl.  at  paras.  5-  17. 
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 sufficiently  adhering  to  its  change  management  process.  744  While  acknowledging  that  63  feature  change  requests  awaited  implementation  as  of  the  date  of  this  applications  filing,  745  BellSouth 
 explains  that  it  is  implementing  change  requests  as  quickly  as  possible  given  the  CCPs  lengthy  timelines  and  the  limitations  of  its  OSS.  As  BellSouth  explains,  the  maximum  amount  of 
 capacity  per  year  for  change  requests  is  limited  by  its  OSS  architecture.  746 
 194.  We  find,  on  balance,  that  BellSouth  is  implementing  the  most  important  competitive  LEC-  initiated  change  requests  in  a  timely  fashion.  Notably,  the  backlog  as  it  exists 


 today  is  similar  to  the  backlog  as  it  existed  at  the  time  we  adopted  the  BellSouth  Georgia/  Louisiana  Order.  747  In  addition,  as  BellSouth  notes,  it  has  implemented  a  large  number 
 of  change  requests,  especially  during  the  past  six  months,  748  including  nine  of  the  15  top-  ranked  feature  change  requests  made  by  competitive  carriers.  749  We  acknowledge  that  the  Department 
 of  Justice  expressed  concern  about  whether  BellSouth  has  committed  sufficient  resources  to  reduce  the  backlog  of  change  requests  in  a  timely  manner.  750  However,  the  record  indicates  that 
 BellSouth  has  devoted  adequate  resources  to  develop  and  implement  change  requests    approximately  250,000  hours  of  work  per  year  to  implement  change  requests,  the  equivalent  of 


 744  AT&  T  Bradbury/  Norris  Decl.  at  paras.  33-  44;  see  also  Covad  Comments  at  21-  22  (regarding  timeliness  of 
 defect  corrections). 
 745  BellSouth  Stacy  Aff.  at  para.  136.  Change  feature  requests  include  Type  2  (changes  mandated  by  regulatory 
 authorities),  Type  3  (industry  standard),  Type  4  (BellSouth-  initiated),  and  Type  5  (competitive  LEC-  initiated  changes).  Not  included  in  that  figure  are  the  34  defect  repairs  that  were  accepted  by  the  change  management 


 process,  but  were  not  yet  implemented  as  of  the  filing  of  this  application.  Also  this  number  includes  only  those  change  requests  accepted  by  BellSouth  for  implementation;  18  competitive  LEC-  initiated  requests  were  awaiting 
 acceptance  or  rejection  by  BellSouth.  Id.  These  numbers  reflect  a  snapshot  of  the  change  requests  as  of  June  3,  2002.  See  also  BellSouth  Stacy  Reply  Aff.  at  paras.  21,  48. 


 746  BellSouth  explains  that  its  use  of  a  single  OSS  limits  the  number  of  simultaneous  software  releases  that  can  be 
 programmed  at  the  same  time.  BellSouth  August  16  CCP  Ex  Parte  Letter  at  3-  4.  As  BellSouth  explains,  software  developers  are  often  simultaneously  testing  one  release,  writing  code  for  another  and  in  the  initial  planning  stages  of 


 a  third  release.  Id.  The  releases  build  upon  one  another,  and  therefore,  there  is  a  limit  to  the  number  of  releases  that  can  be  efficiently  developed  at  the  same  time.  Id.  Although  we  do  not  rely  upon  this  as  a  basis  for  our  decision,  we 
 note  that  BellSouth  has  begun  to  deploy  a  new  infrastructure  that  will  provide  a  more  flexible,  scalable  architecture  that  will  continue  to  improve  BellSouths  ability  to  respond  to  CLEC  requests.  Id.  at  4.  Even  without  this 
 effective  cap  on  change  requests,  BellSouth  notes  that  an  assumption  that  all  requests  be  implemented  as  quickly  as  possible  could  overwhelm  its  systems  and  require  infinite  BellSouth  resources.  BellSouth  Stacy  Reply  Aff.  at  paras. 
 66-  67  (  There  are  hundreds  of  CLECs  that  could  make  .  .  .  requests  for  new  features.  The  CCP  does  not  limit  the  number  of  CLECs  that  can  participate  in  the  CCP,  nor  does  it  limit  the  number  of  change  requests  that  any  CLEC 
 may  submit.). 
 747  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9128,  para.  194. 


 748  BellSouth  Stacy  Reply  Aff.  at  para.  21. 
 749  BellSouth  Stacy  Aff.  at  para.  160.  BellSouth  plans  to  implement  all  of  the  top  15  requests  by  year-  end. 
 BellSouth  Stacy  Reply  at  para.  21. 
 750  Department  of  Justice  Evaluation  at  10. 
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 $108  million  in  expenditures.  751  Moreover,  we  agree  with  BellSouth  that  some  change  requests  will  always  be  pending  due  to  the  long  lead  times  inherent  in  the  CCP.  752 
 195.  Competitive  carriers  fear  that  the  backlog  of  competitive  LEC-  initiated  feature  change  requests  will  continue  to  grow,  given  the  number  of  defects  in  BellSouths  latest  releases 
 and  that  defects  will  typically  be  implemented  before  feature  change  requests.  753  We  do  not  think  this  is  a  likely  scenario.  BellSouth  has  demonstrated  that  defects  in  software  releases  are  not 
 significantly  contributing  to  the  backlog  because  defect  repairs  use  a  relatively  small  amount  of  capacity.  754  Moreover,  we  believe  BellSouths  recent  actions  demonstrate  that  it  is  working 
 efficiently  within  the  constraints  of  the  CCP  and  the  limitations  of  its  current  systems.  For  these  reasons,  we  find  that  the  way  BellSouth  has  implemented  competitive  LEC  change  requests  does 
 not  deny  an  efficient  competitor  a  meaningful  opportunity  to  compete. 
 196.  Notwithstanding  our  conclusion  regarding  the  way  BellSouth  implements  change  requests,  we  are  concerned  by  the  length  of  time  that  some  competitive  LECs  have  been  waiting 


 for  their  change  requests  to  be  implemented.  755  BellSouth  has  itself  acknowledged  that  it  will  not  significantly  reduce  the  backlog  of  feature  change  requests  until  the  end  of  2003  and  that  all 
 currently  accepted  feature  change  requests  will  not  be  implemented  until  the  third  quarter  of  2004.  756  Although  we  do  not  find  the  current  level  of  backlogged  change  requests  causes 
 BellSouth  to  fail  this  checklist  item,  it  is  not  a  trend  we  wish  to  see  continue.  Accordingly,  we  expect  BellSouth  to  follow  through  on  its  commitments  to  improve  the  efficiency  of  its  change 


 751  BellSouth  Stacy  Reply  Aff.  at  paras.  47,  68. 
 752  BellSouth  August  16  CCP  Ex  Parte  Letter  at  4-  5  (  It  is  unreasonable  to  expect  that  there  will  ever  come  a  time 
 that  the  New,  Pending  and  Candidate  Request  categories  are  empty    so  long  as  CLECs  continue  to  submit  requests  to  the  CCP,  there  will  be  requests  in  each  category.  The  critical  fact,  however,  is  that  requests  are  moving  through 


 the  process  and  are  being  implemented  in  a  timely  fashion.);  see  also  BellSouth  Stacy  Reply  Aff.  at  para.  50.  After  a  change  request  has  been  prioritized,  the  first  release  package  meeting  takes  place  36  weeks  before  a  production 
 release.  BellSouth  Stacy  Reply  Aff.  at  para.  50.  During  the  application  process,  BellSouth  revised  the  definition  of  major  and  minor  releases.  Both  are  now  referred  to  as  production  releases.  BellSouth  Stacy  Reply  Aff.  at  para. 
 50  n.  13. 
 753  Twenty-  five  feature  change  requests  were  implemented  from  January  through  June  2,  2002.  The  rest  of  the 
 change  requests    83,  or  more  than  75%  of  the  total  changes  implemented  this  year    were  necessary  to  correct  defects  in  BellSouth  systems.  AT&  T  Bradbury/  Norris  Decl.  at  para.  48.  For  the  remainder  of  2002,  BellSouth  has 


 scheduled  the  implementation  of  12  feature  change  requests.  Id. 
 754  BellSouth  August  16  CCP  Ex  Parte  Letter  at  6  (  The  amount  of  capacity  used  to  correct  the  defects  is  a  small 
 fraction  of  the  total  capacity  available.  .  .  .  In  2002,  BellSouth  used  less  than  8%  of  available  capacity  for  defect  correction.). 


 755  AT&  T  Bradbury/  Norris  Decl.  at  para.  44.  Most  of  the  feature  change  requests  implemented  in  Release  10.5 
 were  submitted  between  August  1999  and  August  2000    approximately  two  to  three  years  prior  to  implementation.  AT&  T  Bradbury/  Norris  at  para.  48.  See  also  Department  of  Justice  Evaluation  at  8  (stating  that  [  a]  n  important 


 issue  still  remains,  however,  regarding  whether  BellSouth  is  committing  sufficient  resources  overall  to  the  process  of  upgrading  the  interfaces  to  its  OSS  used  by  the  [competitive]  LECs.). 


 756  BellSouth  Stacy  Reply  Aff.  at  para.  57. 
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 management  process.  We  note  that  there  are  significantly  fewer  BellSouth-  initiated  change  requests  than  competitive  LEC-  initiated  change  requests.  757  As  allowed  by  its  50/  50  plan  in  the 
 CCP,  BellSouth  could  use  some  of  its  half  of  the  release  capacity  to  implement  some  of  the  more  highly  prioritized  or  older  competitive  LEC  requests  during  the  course  of  the  next  year.  If 
 BellSouth  continues  to  evidence  an  inability  to  reduce  its  backlog  of  change  requests,  we  will  consider  this  issue  in  the  context  of  a  section  271(  d)(  6)  enforcement  action.  Therefore,  we  will 
 monitor  BellSouths  performance,  and  we  expect  and  encourage  BellSouth  to  continue  to  devote  adequate  resources  to  this  issue. 


 197.  Although  not  of  decisional  weight,  BellSouth  has  adopted  region-  wide  a  metric  758  that  will  measure  the  number  of  accepted  competitive  LEC-  initiated  change  requests 
 implemented  within  60  weeks  of  competitive  LEC  prioritization.  759  Penalties,  which  will  also  apply  region-  wide,  will  be  assessed  if  BellSouth  fails  to  meet  the  95  percent  benchmark.  760  We 
 believe  this  metric  will  provide  an  incentive  for  BellSouth  to  improve  its  performance  in  this  area. 


 198.  Quality  of  Software  Releases.  AT&  T  and  WorldCom  allege  that  the  quality  of  BellSouths  software  releases  has  deteriorated  since  we  approved  BellSouths  Georgia/  Louisiana 
 application.  761  BellSouth  argues  that  its  performance  has  improved  and  that  its  most  recent  software  release  has  fewer  problems  than  earlier  releases.  762  We  find  that  the  quality  of 
 BellSouths  software  releases  has  not  impaired  competitors  access  to  BellSouths  OSS.  To  the  contrary,  we  find  that  the  quality  of  BellSouths  software  releases  has  slightly  improved,  not 
 deteriorated,  since  the  release  of  the  BellSouth  Georgia/  Louisiana  Order. 


 757  Of  the  63  outstanding  feature  changes,  42  have  been  requested  by  competitive  LECs  while  only  nine  have 
 been  requested  by  BellSouth.  BellSouth  Stacy  Reply  Aff.  at  para.  49.  Of  the  remaining  feature  change  requests,  27  are  Type  2  (regulatory  mandate)  while  one  is  a  Type  3  (industry  standard).  Id. 


 758  BellSouth  August  9  CCP  Ex  Parte  Letter  at  1-  2;  see  also  BellSouth  August  15  Metrics  Ex  Parte  Letter  at  1 
 (correcting  attachment  to  August  9  CCP  Ex  Parte  Letter). 
 759  When  a  feature  change  request  is  submitted  by  a  competitive  LEC,  BellSouth  has  10  days  to  accept  or  reject 
 the  request.  BellSouth  can  reject  competitive  LEC  change  requests  based  on  cost,  industry  direction  and  technical  infeasibility.  See  BellSouth  Stacy  Aff.  at  para.  85,  Exh.  WNS-  13  (CCP  at  33).  BellSouth  must  provide  competitive 


 LECs  with  a  rationale  for  its  decisions,  and  competitive  LECs  can  appeal  BellSouths  decision,  using  either  the  escalation  process  or  by  filing  a  complaint  with  a  regulatory  body.  If  a  change  request  is  accepted,  the  request  then 
 is  submitted  to  competitive  LECs  for  prioritization,  i.  e.,  a  competitive  LEC  ranking  of  how  important  the  change  request  is,  which  determines  how  soon  it  will  be  implemented. 


 760  BellSouth  August  9  CCP  Ex  Parte  Letter  at  1-  2;  see  also  BellSouth  August  15  Metrics  Ex  Parte  Letter  at  1 
 (correcting  attachment  to  August  9  CCP  Ex  Parte  Letter).  Failure  to  meet  these  metrics  will  result  in  Tier  II  penalties.  As  noted  above,  AT&  T  claims  that  these  penalties  are  not  sufficient  to  provide  an  incentive  for  BellSouth 


 to  meet  the  metric.  AT&  T  August  23  OSS  and  Data  Integrity  Ex  Parte  Letter  at  3.  However,  we  note  that  we  are  not  relying  upon  these  metrics  for  approval  of  this  application. 


 761  WorldCom  Comments  at  2;  AT&  T  Bradbury/  Norris  Decl.  at  paras.  63-  68. 
 762  BellSouth  Stacy  Reply  Aff.  at  para.  74;  BellSouth  August  16  CCP  Ex  Parte  Letter  at  5-  6. 
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 199.  Between  the  issuance  of  the  BellSouth  Georgia/  Louisiana  Order  and  the  filing  of  the  instant  application,  BellSouth  implemented  only  one  software  release    Release  10.5  on  June 
 1-  2,  2002.  763  BellSouth  identified  approximately  35  post-  production,  competitive  LEC-  affecting  defects  during  the  30  days  following  the  release  764    slightly  more  defects  than  identified  in  the 
 releases  examined  in  the  Georgia/  Louisiana  proceeding  (Releases  10.2  and  10.3).  765  Competitive  LECs  allege  that  the  number  of  defects  is  beyond  the  industry  standard  and  demonstrates  that 
 BellSouth  does  not  properly  perform  pre-  release  internal  testing.  766  However,  looking  only  at  the  number  of  defects  in  Release  10.5  does  not  tell  the  entire  story.  767  First,  when  compared  to  the 
 releases  examined  by  the  Commission  in  the  BellSouth  Georgia/  Louisiana  Order,  Release  10.5  had  fewer  problems  than  those  releases  when  the  complexity  of  the  releases  (defects  per  function 
 point)  is  taken  into  account.  768  For  example,  Release  10.3  had  0.00708  defects  per  function  point  while  Release  10.5  had  0.00467  defects  per  function  point.  769  Second,  we  reject  competitive 
 LEC  claims  that  they  were  significantly  harmed  by  the  defects.  770  Of  the  35  defects  in  Release 
 763  BellSouth  Stacy  Aff.  at  para.  144.  Release  10.5  was  implemented  on  June  1-  2,  2002,  with  two  severity  level  3 
 defects  (formerly  known  as  medium-  impact  defects).  BellSouth  Stacy  Reply  Aff.  at  para.  73. 
 764  BellSouth  also  indicated  that  there  were  only  34  competitive  LEC-  affecting  defects  in  Release  10.  5. 
 BellSouth  Stacy  Reply  Aff.  at  para.  74.  BellSouth  explained  that  a  consultant,  QP  Management,  analyzed  the  quality  of  Release  10.5  and  found  that  one  of  the  35  defects  attributed  to  Release  10.4  was  actually  attributable  to 


 Release  10.4.  BellSouth  August  21  Ex  Parte  Letter  at  2.  As  a  result,  in  analyzing  the  quality  of  Release  10.  5,  QP  Management  used  the  figure  of  34  competitive  LEC-  affecting  defects,  instead  of  35.  Id. 


 765  BellSouth  Stacy  Reply  Aff.  at  para.  73.  Release  10.5  was  delayed  two  weeks  while  BellSouth  corrected  other 
 defects  that  were  identified  in  pre-  production  testing.  BellSouth  Stacy  Aff.  at  para.  144. 
 766  WorldCom  Comments  at  2  (  Recent  Verizon  releases,  for  example,  had  almost  no  defects.). 


 767  Releases  10.2  and  10.3  were  examined  in  the  Georgia/  Louisiana  proceeding.  BellSouth  Georgia/  Louisiana 
 Order,  17  FCC  Rcd  at  9129,  para.  195.  Release  10.2  had  34  competitive  LEC-  affecting  defects  while  Release  10.3  had  25  competitive  LEC-  affecting  defects.  BellSouth  Stacy  Reply  Aff.  at  para.  75,  Exh.  WNS-  32  at  App.  A. 


 768  The  software  industry  uses  a  metric  called  defect  density  to  measure  the  quality  of  a  software  release.  This 
 metric  compares  the  number  of  identified  defects  to  the  number  of  function  points  implemented  in  the  release.  A  function  point  is  an  industry  standard  metric  for  defining  the  complexity  of  a  given  piece  of  software,  based  on  the 


 business  functionality  provided  by  the  software.  BellSouth  Stacy  Reply  Aff.  at  para.  74.  By  this  measure,  Release  10.5  had  34  competitive  LEC-  affecting  defects  and  60  non-  competitive  LEC-  affecting  defects  out  of  20,108 
 function  points  for  a  ratio  of  0.00467  defects  per  function  point.  By  contrast,  Release  10.3  had  39  competitive  LEC-  affecting  defects  with  a  ratio  of  0.00708  defects  per  function  point,  and  Release  10.4  had  54  competitive  LEC-affecting 
 defects  with  a  ratio  of  0.00682  defects  per  function  point.  In  addition,  BellSouth  points  out  that  Release  10.5  would  meet  the  industry  standard  of  best  in  class.  BellSouth  Stacy  Reply  Aff.  at  para.  74.  BellSouth  has 
 also  indicated  that  there  were  35  competitive  LEC-  affecting  defects  in  Release  10.  5.  BellSouth  Stacy  Reply  Aff.  at  para.  80. 


 769  BellSouth  Stacy  Reply  Aff.  at  para.  75,  Exh.  WNS-  32  at  App.  A. 
 770  WorldCom  states  that  one  of  the  defects  in  Release  10.5  temporarily  led  to  the  rejection  of  all  orders 
 requesting  migration  of  a  customer  from  one  competitive  LEC  to  another.  WorldCom  Comments  at  3.  Another  defect  led  to  rejection  of  all  supplemental  orders  for  customers  whose  addresses  include  a  Building,  Slip  or  Pier,  and 


 a  third  led  to  rejection  of  all  orders  submitted  by  competitive  LECs  using  BellSouths  TAG  interface  for  version  7.6  or  below.  Id. 
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 10.5,  30  of  the  defects  each  affected  only  a  handful  of  the  LSRs  that  were  in  progress  during  the  transition  from  software  version  10.4  to  10.5.  771  At  most,  only  about  9,000  competitive  LEC 
 orders  were  affected  by  all  the  defects,  a  number  equal  to  only  0.07  percent  of  total  LSR  volume.  772  As  BellSouth  demonstrates,  it  fixed,  within  the  10-  day  deadline  established  by  the 
 CCP,  those  five  defects  that  affected  a  significant  number  of  competitive  LEC  orders  or  had  a  significant  effect  on  the  competitive  LECs  ability  to  process  orders.  773  Third,  correcting  those 
 defects,  as  noted  above,  requires  only  minimal  capacity  and  does  not  add  to  the  current  backlog  of  change  features  waiting  to  be  implemented.  774 


 200.  Finally,  while  we  share  the  concern  expressed  by  the  Department  of  Justice  and  the  competitive  LECs  regarding  the  number  of  defects  in  BellSouths  releases,  775  we  note  that 
 BellSouth  has  adopted  practices  to  minimize  defects  in  future  releases.  776  In  fact,  although  not  a  basis  for  our  decision,  777  we  recognize  that  Release  10.6,  which  was  implemented  August  24, 


 771  BellSouth  Stacy  Reply  Aff.  at  para.  77. 
 772  BellSouth  Stacy  Aff.  at  para.  146;  BellSouth  Stacy  Reply  Aff.  at  para.  78. 
 773  BellSouth  Stacy  Reply  Aff.  at  para.  78.  All  CLEC-  affecting  high-  impact  defects  must  be  corrected  within 
 10  days.  BellSouth  Stacy  Aff.  at  para.  85,  Exh.  WNS-  13  (CCP  at  55).  Defect  CR0802,  which  caused  some  loop  make-  up  inquiries  and  firm  order  requests  submitted  from  LENS  to  fail  unexpectedly,  was  corrected  on  June  5, 


 2002.  Defect  CR0804  produced  an  error  code  that  was  being  set  incorrectly  for  resale  and  UNE-  P  migration  orders  conversion  and  specified  orders  when  the  LSR  competitive  LEC  OCN  and  the  OCN  on  the  CRIS  record  did  not 
 match.  The  defect  was  corrected  on  June  3,  2002.  Defect  CR0805,  which  caused  some  LSRs  to  be  auto-  clarified  even  though  the  LSRs  contained  the  correct  information,  was  corrected  on  June  5,  2002.  Defect  CR  0807,  which 
 caused  supplemental  orders  placed  on  LSRs  submitted  before  Release  10.5  to  be  routed  to  the  wrong  exception  handling  tool,  was  corrected  on  June  6,  2002.  Because  of  defect  CR0812,  BellSouths  OSS  did  not  send  a 
 completion  notice  to  the  competitive  LEC  for  certain  types  of  orders.  This  situation  occurred  only  on  certain  LSRs  that  existed  before  the  implementation  of  10.  5  but  the  actual  service  order  completion  was  after  the  implementation. 
 This  only  happened  after  an  auto-  clarification  had  been  sent  and  only  when  the  auto-  clarification  was  produced  from  a  certain  module  in  BellSouths  architecture.  This  problem  was  corrected  on  June  10,  2002.  BellSouth  Stacy 
 Reply  Aff.  at  para.  78. 
 774  BellSouth  August  16  CCP  Ex  Parte  Letter  at  6  (  The  amount  of  capacity  used  to  correct  the  defects  is  a  small 
 fraction  of  the  total  capacity  available.  .  .  .  In  2002,  BellSouth  used  less  than  8%  of  available  capacity  for  defect  correction.). 


 775  Department  of  Justice  Evaluation  at  12  (stating  that  [  t]  he  Commission  should  carefully  monitor  BellSouths 
 future  releases.). 
 776  BellSouth  Stacy  Reply  Aff.  at  paras.  81-  82.  Although  we  do  not  rely  upon  these  processes,  BellSouth  has 
 identified  a  few  changes  it  plans  to  make  to  decrease  the  number  of  defects.  First,  prior  to  the  software  release,  it  will  stop  taking  new  orders  and  let  the  orders  already  placed  make  their  way  through  BellSouths  systems. 


 BellSouth  August  16  CCP  Ex  Parte  Letter  at  6.  That  process  should  eliminate  some  defects  caused  by  orders  that  are  still  working  their  way  through  BellSouths  OSS  and  are  caught  in  the  transition.  Id.  Second,  BellSouth  is 
 expanding  the  number  of  test  cases  it  uses  during  testing  to  identify  any  problems  prior  to  production  implementation.  BellSouth  Stacy  Reply  Aff.  at  para.  82. 


 777  Because  of  our  freeze  frame  rule,  we  decline  to  consider  Release  10.6  in  this  Application.  See  271  Filing 
 Requirements  at  20950-  51. 
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 2002,  during  the  90-  day  statutory  timeframe  for  this  application,  contains  proportionately  fewer  defects  than  other  recent  releases.  778  We  are  encouraged  by  these  developments. 
 201.  Although  not  of  decisional  weight,  BellSouth  has  added  a  new  metric  that  will  measure  the  intervals  for  defect  repairs.  779  Under  the  new  metric,  high-  impact  defects  must  be 
 corrected  in  10  days,  medium  impact  must  be  corrected  in  30  days,  and  low  impact  defects  must  be  corrected  in  45  days.  780  BellSouth  has  adopted  these  metrics,  and  their  associated  penalties  in 
 the  SEEM  plan,  throughout  its  nine-  state  region,  including  in  the  states  that  are  the  subject  of  this  application.  781  We  believe  these  metrics  will  provide  an  incentive  for  BellSouth  to  improve 
 its  performance  in  this  area.  In  addition,  we  are  encouraged  that  BellSouth  is  working  with  state  regulators  and  competitive  LECs  to  change  its  procedures  to  reduce  the  number  of  defects  in  its 
 releases.  As  the  Department  of  Justice  notes,  if  additional  resources  are  required  to  correct  these  problems,  we  expect  BellSouth  to  provide  them.  782  Accordingly,  we  will  continue  to  monitor 
 BellSouths  performance  and  will  take  enforcement  action,  if  necessary. 
 202.  Furthermore,  we  are  not  persuaded  by  competitive  LEC  claims  that  BellSouth  misclassifies  its  change  requests  to  evade  repair  interval  requirements.  Competitive  LECs  claim 


 that  BellSouth  has  misclassified  a  number  of  defect  change  requests  as  feature  change  requests  or  as  change  requests  based  on  a  regulatory  mandate.  783  In  addition,  competitive  LECs  claim  that 
 BellSouth  is  assigning  defects  to  the  wrong  category,  e.  g.  labeling  a  high-  impact  defect  as  a  medium-  impact  defect,  to  take  advantage  of  longer  repair  intervals.  784  We  do  not  find  the 


 778  In  ex  parte  filings,  AT&  T  and  WorldCom  claim  that  BellSouths  Release  10.6  is  riddled  with  defects.  See 
 AT&  T  September  9  Ex  Parte  Letter  at  1;  WorldCom  September  12  Ex  Parte  Filing  at  1-  2.  However,  BellSouth  has  identified  only  seven  competitive  LEC-  affecting  defects  attributable  to  its  Release  10.  6.  Letter  from  Kathleen  B. 


 Levitz,  Vice  President    Federal  Regulatory,  BellSouth,  to  Marlene  H.  Dortch,  Secretary,  Federal  Communications  Commission,  WC  Docket  No.  02-  150  at  4  (filed  Sept.  10,  2002)  (BellSouth  September  10  Ex  Parte  Letter). 
 BellSouth  also  identified  five  other  defects  that  were  attributed  to  other  releases,  but  discovered  after  Release  10.6  was  implemented.  Id. 


 779  BellSouth  August  9  CCP  Ex  Parte  Letter  at  1-  2;  see  also  BellSouth  August  15  Metrics  Ex  Parte  Letter  at  1 
 (correcting  attachment  to  August  9  CCP  Ex  Parte  Letter). 
 780  The  prior  standard  required  high  impact  defects  to  be  corrected  in  10  business  days,  medium  impact  to  be 
 corrected  within  90  business  days,  and  low  impact  to  be  corrected  with  best  efforts  (although  BellSouth  had  committed  to  a  120-  day  interval).  BellSouth  Stacy  Aff.  at  para.  85,  Exh.  WNS-  13  (CCP  at  55). 


 781  BellSouth  August  9  CCP  Ex  Parte  Letter.  As  noted  above,  AT&  T  claims  that  these  penalties  are  not  sufficient 
 to  provide  an  incentive  for  BellSouth  to  meet  the  metric.  AT&  T  August  23  OSS  and  Data  Integrity  Ex  Parte  Letter  at  3.  However,  we  note  that  we  are  not  relying  upon  these  metrics  for  approval  of  this  application. 


 782  Department  of  Justice  Evaluation  at  12. 
 783  AT&  T  Comments  at  12,  13;  WorldCom  Lichtenberg  Decl.  at  para.  14. 
 784  WorldCom  September  12  Ex  Parte  Letter  at  3.  As  noted  above,  the  prior  standard  required  high  impact 
 defects  to  be  corrected  in  10  business  days,  medium  impact  to  be  corrected  within  90  business  days,  and  low  impact  to  be  corrected  with  best  efforts  (although  BellSouth  had  committed  to  a  120-  day  interval).  BellSouth 


 Stacy  Aff.  at  para.  85,  Exh.  WNS-  13  (CCP  at  55). 
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 competitive  LEC  assertion  that  BellSouth  is  purposefully  mischaracterizing  change  requests  in  order  to  avoid  CCP  requirements  persuasive.  Instead,  it  appears  this  problem  is  the  result  of  a 
 dispute  between  BellSouth  and  the  competitive  LECs  regarding  the  definition  of  a  defect.  785  The  shorter  intervals  to  repair  change  requests  should  decrease  any  incentive  BellSouth  may  have  to 
 mislabel  defects. 
 203.  Notification  Adequacy  and  Timeliness.  We  find  that  BellSouth  has  established  a  pattern  of  compliance  with  the  intervals  established  in  the  Change  Control  Process  for 


 notification  of  a  variety  of  system  changes.  786  Commercial  data  reveal  a  pattern  of  BellSouths  providing  notice  of  system  changes  in  a  timely,  complete,  and  accurate  manner.  787  In  addition, 
 the  Georgia  KPMG  test,  demonstrates  that  BellSouths  notification  procedures  are  sufficient  for  checklist  compliance.  788  Additionally,  we  find  that  BellSouth  generally  adheres  to  its 
 notification  schedule  789  and  that  the  documentation  for  the  most  recent  releases  has  been  timely 


 785  The  dispute  has  been  submitted  to  the  Georgia  Commission  for  resolution.  BellSouth  explains  that  under  the 
 existing  CCP,  a  competitive  LEC-  affecting  defect  is  defined  to  include  errors  that  are  made  when  designing  and  subsequently  coding  the  software  and  errors  made  because  of  an  oversight  in  documenting  the  functionality  that 


 should  be  created.  BellSouth  argues  that  the  latter  reason  is  not  truly  a  defect  because  developers  do  not  have  a  road  map  that  indicates  how  the  software  should  behave  or  what  changes  should  be  made  to  correct  the  problem. 
 BellSouth  Stacy  Reply  Aff.  at  paras.  91-  92.  To  correct  this  type  of  defect,  new  business  rules,  user  requirements,  and  system  requirements  must  be  developed.  BellSouth  argues  that  the  development  of  this  additional  functionality 
 is  a  new  change  request.  Id.  at  para.  92. 
 786  The  Commissions  prior  section  271  orders  recognize  the  importance  of  a  BOCs  provision  of  timely, 
 complete,  and  accurate  notice  of  alterations  to  its  systems  and  processes  and,  therefore,  the  Commission  requires  that  a  BOC  have  established  a  pattern  of  compliance  with  the  relevance  notification  and  documentation  intervals  in 


 its  Change  Agreement.  SWBT  Texas  Order,  15  FCC  Rcd  at  18415,  para.  126. 
 787  BellSouth  provides  notice  of  software  releases  in  a  timely  manner.  See  Alabama/  Kentucky/  Mississippi/  North 
 Carolina/  South  Carolina  F.  10.1  (%  Software  Release  Notices  Sent  on  Time);  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  F.  10.2  (Average  Software  Release  Notification  Delay  Days).  Third-  party  testing  also 


 shows  timely  notice  of  software  releases.  KPMG  MTP  Final  Report,  Test  CM-  1-  1-  5,  at  VIII-  A-  20  (finding  that  the  Change  Control  Process  has  defined  and  reasonable  intervals  for  considering  and  notifying  customers  about 
 proposed  changes).  See  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  F.  10.3  (%  Change  Management  Documentation  Sent  on  Time);  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  F.  10.5 
 (Average  Documentation  Release  Delay  Days);  BellSouth  Varner  Aff.  at  Exhs.  PM-  2,  paras.  93-  98;  PM-  3,  paras.  93-  98;  PM-  4,  paras.  92-  97;  PM-  5,  paras.  92-  97;  PM-  6,  paras.  92-  97. 


 788  See  KPMG  MTP  Final  Report,  Test  CM-  1-  1-  6,  at  VIII-  A-  21  (finding  that  [  d]  ocumentation  regarding 
 proposed  changes  is  distributed  on  a  timely  basis).  See  also  section  IV.  B.  2.  a,  supra  (discussing  the  regionality  of  BellSouths  OSS). 


 789  In  the  SWBT  Texas  Order,  the  Commission  found  SWBTs  provision  of  documentation  to  be  sufficiently 
 timely  despite  its  failure  to  strictly  meet  specified  deadlines.  SWBT  Texas  Order,  15  FCC  Rcd  at  18416,  paras.  128-  29  &  nn.  340,  343. 
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 and  complete.  790  Finally,  we  find  that  BellSouth  consistently  provides  competing  carriers  notice  of,  and  information  about,  access  to  its  electronic  interfaces.  791 
 204.  While  it  appears  that  BellSouth  is  generally  adhering  to  the  notification  intervals  required  by  the  CCP,  commenters  allege  that  BellSouth  has  failed  to  notify  competitive  LECs  of 
 some  interface  changes  either  at  all,  or  has  notified  them  significantly  after  a  competitive  CLEC-  affecting  change  has  been  implemented.  792  We  address  specific  allegations  in  this 
 regard  in  turn. 
 205.  First,  we  reject  Birchs  request  that  the  legacy  systems  of  BellSouths  directory  publisher  affiliate,  BellSouth  Advertising  Publishing  Company  (BAPCO),  be  subject  to  the 


 CCP.  793  Birch  alleges  that  competitive  LECs  were  not  properly  notified  of  a  change  to  BAPCOs  systems  to  fix  a  partial  directory  listing  deficiency,  which  resulted  in  telephone  numbers  of 
 Birchs  end  users  being  omitted  from  BAPCOs  telephone  book.  794  However,  the  scope  of  the  CCP  only  includes  BellSouth  gateways  or  interfaces  with  competitive  LECs.  795  As  we  have 
 noted  in  prior  orders,  changes  that  do  not  affect  OSS  interfaces  are  not  necessarily  required  to  be  a  part  of  the  change  management  process.  796  Accordingly,  we  do  not  find  that  Birchs  claim 
 warrants  a  finding  of  checklist  noncompliance. 
 206.  Second,  we  are  not  persuaded  that  BellSouths  failure  to  notify  competitive  LECs  of  its  intention  to  reject  competitive  LEC  orders  that  choose  BellSouth  Long  Distance  (BSLD)  as 


 the  end  users  primary  interexchange  carrier  (PIC)  warrants  a  finding  of  noncompliance.  797  Specifically,  WorldCom  contends  that  BellSouth  began  rejecting  orders  listing  BSLD  as  the  PIC 
 in  May,  but  did  not  notify  competitive  LECs  until  June  14,  2002.  798  BellSouth  acknowledges  that  it  posted  a  carrier  notification  on  June  14,  2002,  advising  competitive  LECs  that  BellSouth 


 790  BellSouth  Stacy  Aff.  at  para.  151. 
 791  See  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  F.  10.6  (%  Interface  Outage  Notices  Sent 
 Within  15  Minutes).  From  March  through  June,  BellSouth  had  a  perfect  record  of  providing  notice  to  competitive  LECs  about  interface  outages. 


 792  WorldCom  Lichtenberg  Decl.  at  paras.  25-  36;  Birch  Comments  at  20-  25;  Birch  August  23  Ex  Parte  Letter  at 
 5-  6. 
 793  Birch  Comments  at  25. 


 794  Id.  at  21. 
 795  BellSouth  Stacy  Aff.  at  para.  85,  Ex.  WNS-  13  (CCP  at  17);  see  also  BellSouth  August  30  Ex  Parte  Letter  at  3 
 (stating  that  the  BAPCO  system  change  had  no  affect[  sic]  on  [CLEC]  interfaces.). 
 796  Verizon  Pennsylvania  Order,  16  FCC  Rcd  at  17451,  para.  51  (accepting  Verizons  argument  that  the  changes 
 to  the  BOS  BDT  billing  systems  are  back-  office  OSS  changes  that  do  not  impact  OSS  interfaces). 
 797  WorldCom  Comments  at  6-  7. 


 798  These  orders  were  for  end  users  in  Georgia  and  Louisiana.  However,  this  issue  is  relevant  to  this  application 
 because  BellSouths  CCP  is  regionwide. 
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 would  not  accept  orders  for  BSLD  if  the  submitting  carrier  does  not  have  an  operational  agreement  with  BSLD.  799  BellSouth  explains,  however,  that  the  feature  rejecting  competitive 
 LEC  orders  for  BSLD  was  initiated  in  July  1997,  and  has  existed  in  BellSouths  systems  since  its  implementation.  800  BellSouth  therefore  states  that  the  June  14,  2002  announcement  was  a 
 reminder  to  competitive  LECs  of  its  existing  procedures.  While  we  do  not  discount  the  potential  inconvenience  this  may  have  caused  competitive  LECs,  we  do  not  find  that  this  isolated  instance 
 indicates  a  systemic  problem  with  BellSouths  change  management  notification  process  that  might  warrant  a  finding  of  checklist  noncompliance.  801 


 207.  Commenters  also  contend  that  BellSouth  did  not  provide  competitive  LECs  with  adequate  prior  written  notice  when  it  implemented  PMAP  4.0.  802  We  address  this  issue  above  in 
 our  discussion  of  the  reliability  of  BellSouths  data.  803 
 (ii)  Training,  Technical  Assistance,  and  Help  Desk  Support 
 208.  As  we  did  in  the  BellSouth  Georgia/  Louisiana  Order,  we  find  that  BellSouth  adequately  assists  competing  carriers  in  their  use  of  available  OSS  functions.  804  BellSouth 


 demonstrates  that  it  teaches  a  wide  variety  of  training  courses  for  competing  carriers  to  assist  in  programming  as  well  as  ordering,  pre-  ordering,  provisioning,  and  maintenance  and  repair.  805 
 Also,  BellSouth  provides  several  help  desks  to  assist  competing  carriers  in  using  OSS.  806  BellSouth  demonstrates  that  its  services  centers  are  adequately  staffed  and  able  to  handle  spikes 
 in  their  work  loads.  807  The  same  organizations  that  we  found  performed  these  functions  in  the  BellSouth  Georgia/  Louisiana  Order  also  perform  these  functions  for  competing  carriers 
 operating  in  the  five  states.  808  Because  the  support  organizations  personnel  are  the  same  as  those  used  by  competing  carriers  in  Georgia  and  Louisiana  and  because  the  record  does  not 
 indicate  the  BellSouth  organizations  provide  inadequate  or  discriminatory  treatment  to 


 799  Letter  from  Kathleen  B.  Levitz,  Vice  President    Federal  Regulatory,  BellSouth,  to  Marlene  H.  Dortch, 
 Secretary,  Federal  Communications  Commission,  WC  Docket  No.  02-  150  at  3  (filed  Aug.  9,  2002)  (BellSouth  August  9  OSS  Ex  Parte  Letter). 


 800  Id. 
 801  If  evidence  becomes  available  to  the  Commission  sufficient  to  show  that  a  systemic  problem  with  BellSouths 
 notification  process,  we  will  pursue  appropriate  enforcement  action. 
 802  See,  e.  g.,  AT&  T  Bursh/  Norris  Aff.  at  para.  16. 


 803  For  a  discussion  of  BellSouths  data  reliability,  see  section  III,  supra. 
 804  See  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  4012,  para.  126. 
 805  BellSouth  Ainsworth  Aff.  at  para.  42. 
 806  Id.  at  paras.  7-  38. 
 807  Id. 
 808  Id.  at  para.  5;  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9132,  para.  198. 
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 competing  carriers,  we  find  that  BellSouth  demonstrates  that  it  provides  efficient  competitors  a  meaningful  opportunity  to  compete  by  enabling  them  to  understand  how  to  implement  and  use 
 all  of  the  OSS  functions  available  to  them. 
 3.  UNE  Combinations  (UNE-  P  and  EELs) 
 209.  In  order  to  satisfy  section  271(  c)(  2)(  B)(  ii),  a  BOC  must  demonstrate  that  it  provides  nondiscriminatory  access  to  network  elements  on  an  unbundled  basis  at  any  technically 


 feasible  point  and  in  a  manner  that  allows  requesting  carriers  to  combine  such  elements.  809  In  addition,  a  BOC  must  not  separate  already  combined  elements,  except  at  the  specific  request  of 
 the  competing  carrier.  810 
 210.  BellSouth  has  demonstrated  that  it  has  a  legal  obligation,  under  its  Statement  of  Generally  Available  Terms  and  Conditions  (SGAT)  in  each  of  the  states,  to  provide  access  to 


 combinations  of  network  elements,  including  UNE-  platform,  a  loop-  switch  port  combination,  and  the  enhanced  extended  loop  (EEL),  a  combination  of  loop  and  transport  facilities. 
 Accordingly,  BellSouth  provides  UNEs,  including  UNE  combinations,  in  the  five  states  in  the  same  manner  as  the  Commission  approved  in  Georgia  and  Louisiana.  811  BellSouth  also  provides 
 a  variety  of  methods  that  allow  competitive  carriers  to  combine  unbundled  network  elements.  BellSouth  demonstrates  that  competitive  LECs  can  order  UNE-  P  and  EELs  electronically,  and 
 that  commercial  experience  proves  this  is  done  in  a  nondiscriminatory  manner.  812  Based  on  the  evidence  in  the  record,  we  conclude,  as  did  the  state  commissions,  that  BellSouth  provides 
 access  to  UNE  combinations  in  compliance  with  Commission  rules.  813 
 211.  We  reject  NewSouths  claims  that  BellSouth  does  not  comply  with  the  Commissions  requirements  regarding  EELs  audits.  814  NewSouth  alleges  that  BellSouth  has  not 


 identified  a  reasonable  concern  regarding  NewSouths  compliance  with  EELs  local  usage  restrictions.  Based  on  this  record,  it  does  not  appear  that  BellSouths  EELs  audit  request 


 809  47  U.  S.  C.    251(  c)(  3);  47  U.  S.  C.    271(  c)(  2)(  B)(  ii). 
 810  47  U.  S.  C.    271(  c)(  2)(  B)(  ii);  47  C.  F.  R.    51.313(  b). 
 811  BellSouth  Application  at  40;  BellSouth  Application  App.  A,  Vol.  3a,  Tab  F,  Affidavit  of  W.  Keith  Milner 
 (BellSouth  Milner  Aff.)  at  para.  63;  see  also  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9132-  33,  para.  199. 


 812  BellSouth  Stacy  Aff.  at  paras.  282-  84;  BellSouth  Stacy  Reply  Aff.  at  para.  145.  As  part  of  Release  10.5, 
 BellSouth  implemented  the  electronic  ordering  of  EELs.  Requests  for  EELs  are  then  routed  to  the  LCSC  for  manual  handling.  Competitive  LECs  also  may  still  order  EELs  manually.  BellSouth  Stacy  Aff.  at  paras.  280-  81. 


 813  BellSouth  Milner  Aff.  at  91;  BellSouth  Ruscilli/  Cox  Aff.  at  para.  6. 
 814  See  New  South  August  5  Ex  Parte  Letter  at  6  (claiming  that  BellSouth  insists  upon  harassing  NewSouth  and 
 other  competitors  with  audit  requests  that  do  not  comply  with  the  limitations  on  such  audits  established  in  [Commission]  orders.). 
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 expressly  violates  a  Commission  rule.  815  Moreover,  we  note  that  there  is  a  separate  proceeding  pending  before  the  Commission  on  the  appropriateness  of  EELs  audits.  816  Accordingly,  we 
 decline  to  find  that  this  issue  warrants  a  finding  of  checklist  noncompliance.  We  further  reject  NewSouths  contention  that  it  has  experienced  considerable  delays  in  the  conversion  of  special 
 access  to  EELs.  817  BellSouth  notes  that,  for  an  order  of  at  least  15  EELs  conversions  submitted  at  the  same  time,  the  target  implementation  interval  is  37  days.  818  BellSouth  claims  that  EELs 
 conversions  submitted  via  spreadsheets  for  all  competitive  LECs  and  for  NewSouth  specifically  have  averaged  approximately  43  days  during  the  past  seven  months.  819  While  we  find  that  this 
 issue  alone  does  not  warrant  a  finding  of  noncompliance  with  checklist  item  2,  we  emphasize  that  BellSouth  must  convert  special  access  to  EELs  in  a  timely  fashion,  in  accordance  with 
 current  requirements.  820 
 212.  US  LEC  argues  that  the  disallowance  of  co-  mingled  traffic,  early  termination  penalties,  and  surcharges  are  obstacles  to  its  ability  to  convert  special  access  circuits  to  EELs.  821 


 815  However,  we  emphasize  that  the  Commission  has  found  that  incumbent  LECs  may  conduct  limited  audits  only 
 to  the  extent  reasonably  necessary  to  determine  a  requesting  carriers  compliance  with  the  local  usage  options.  See  Implementation  of  the  Local  Competition  Provisions  of  the  Telecommunications  Act  of  1996,  CC  Docket  No.  96- 


 98,  Supplemental  Order  Clarification,  15  FCC  Rcd  9587,  9603  n.  86  (Supplemental  Order  Clarification)  ([  Certain  incumbent  LECs  and  competitive  LECs]  state  that  audits  will  not  be  routine  practice,  but  will  only  be  undertaken 
 when  the  incumbent  LEC  has  a  concern  that  a  requesting  carrier  has  not  met  the  criteria  for  providing  a  significant  amount  of  local  exchange  service.  .  .  .  We  agree  that  this  should  be  the  only  time  that  an  incumbent  LEC  should 
 request  an  audit.) 
 816  See  Pleading  Cycle  Established  for  Comments  on  NuVox,  Inc.  Petition  for  Declaratory  Ruling,  CC  Docket  No. 
 96-  98,  Public  Notice,  DA  02-  1302  (rel.  June  4,  2002).  These  claims  raise  issues  of  interpretation  under  our  rules  that  are  more  appropriately  resolved  in  an  enforcement  proceeding  rather  than  the  limited  timeframe  of  a  section 


 271  application. 
 817  NewSouth  August  5  Ex  Parte  Letter  at  7. 


 818  NewSouth  submits  a  list  of  the  circuits  to  be  converted  via  spreadsheet.  The  spreadsheets  are  sent  to 
 BellSouths  Local  Service  Manager,  who  verifies  that  the  circuits  qualify  for  EELs.  This  process  takes  seven  days.  Then  BellSouths  Local  Carrier  Service  Center  readies  the  spreadsheet  for  order  issuance  and  submits  the  required 


 service  orders  for  processing.  The  resulting  service  orders  are  then  verified  for  accuracy  and  any  errors  are  corrected.  This  part  of  the  process  is  scheduled  to  take  30  days.  In  total,  BellSouth  schedules  a  37-  day 
 implementation  process.  BellSouth  August  15  Non-  pricing  Ex  Parte  Letter  at  4. 
 819  BellSouth  August  15  Non-  pricing  Ex  Parte  Letter  at  4;  see  also  Letter  from  Kathleen  B.  Levitz,  Vice  President 
   Federal  Regulatory,  to  Marlene  H.  Dortch,  Secretary,  Federal  Communications  Commission,  WC  Docket  No.  02-  150  at  1  (filed  Sept.  3,  2002)  (BellSouth  September  3  Ex  Parte  Letter). 


 820  In  the  Supplemental  Order  Clarification,  the  Commission  found  that  the  incumbent  LEC  should  immediately 
 process  the  conversion  upon  its  receipt  of  a  conversion  request  that  indicates  that  the  circuits  involved  meet  one  of  the  three  thresholds  for  significant  local  usage.  Supplemental  Order  Clarification,  15  FCC  Rcd  at  9603,  para.  31. 


 As  the  Commission  noted  in  the  Bell  Atlantic  New  York  Order,  carriers  that  are  experiencing  delays  in  the  provisioning  of  special  access  circuits  ordered  from  incumbent  LEC  tariffs  should  address  these  issues  to  the 
 Commission  in  the  context  of  a  section  208  complaint.  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  4124,  para.  341. 
 821  US  LEC  Comments  at  9-  13.  Specifically,  US  LEC  alleges  that  the  current  rules  regarding  unbundled  loops 
 and  loop-  transport  combinations  (enhanced  extended  links  or  EELs)  have  impeded  its  ability  to  compete  with  (continued.) 
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 As  in  the  BellSouth  Georgia/  Louisiana  Order,  we  reject  these  claims.  822  We  have  found  some  of  these  practices  acceptable  while  others,  while  not  preferable  from  the  competitive  LEC 
 perspective,  do  not  expressly  violate  the  Commissions  rules.  Likewise,  the  Commission  declines  to  reevaluate  our  earlier  finding  that  checklist  compliance  does  not  encompass  the 
 provision  of  tariffed  interstate  access  services.  823 
 V.  OTHER  CHECKLIST  ITEMS 
 A.  Checklist  Item  1    Interconnection 
 213.  Section  271(  c)(  2)(  B)(  i)  requires  the  BOC  to  provide  equal-  in-  quality  interconnection  on  terms  and  conditions  that  are  just,  reasonable  and  nondiscriminatory  in 


 accordance  with  the  requirements  of  sections  251  and  252.  Based  on  our  review  of  the  record,  we  conclude,  as  did  the  state  commissions,  824  that  BellSouth  complies  with  the  requirements  of 
 this  checklist  item.  In  reaching  this  conclusion,  we  have  examined  BellSouths  performance  in  providing  collocation  and  interconnection  trunks  to  competing  carriers,  as  we  have  done  in  prior 
 section  271  proceedings.  We  find  that  BellSouths  performance  generally  satisfies  the  applicable  benchmark  or  retail  comparison  standards  for  this  checklist  item.  825 


 214.  NewSouth  contends  that  BellSouths  interconnection  performance  fails  to  comply  with  checklist  item  1.  826  In  particular,  NewSouth  states  that  over  the  last  ten  months,  it  has 
 experienced  seven  significant  interconnection  outages  with  BellSouth,  which  in  the  aggregate 


 (Continued  from  previous  page)  BellSouth.  Id.  at  9.  US  LEC  also  notes  that  it  has  experienced  protracted  negotiations,  delayed  conversion  requests, 
 and  long  provisioning  intervals  when  requesting  EELs.  Id.  US  LEC,  however,  did  not  provide  any  specifics  regarding  those  allegations  so  it  is  impossible  for  us  to  resolve  them  here.  Furthermore,  as  the  Commission  has 
 found  in  prior  proceedings,  the  section  208  complaint  process  is  the  more  appropriate  forum  to  examine  this  type  of  carrier-  specific  allegation.  See,  e.  g.,  Verizon  Vermont  Order,  17  FCC  Rcd  at  7651,  para.  46;  SWBT  Texas  Order,  15 
 FCC  Rcd  at  18366-  67,  paras.  22-  27  and  at  18541,  para.  383;  SWBT  Kansas/  Oklahoma  Order,  16  FCC  Rcd  at  6355,  para.  230. 


 822  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9133-  34,  para.  200  ([  W]  e  reject  comments  by  US 
 LEC/  XO  that  the  disallowance  of  co-  mingled  traffic,  early  termination  penalties,  and  surcharges  are  obstacles  to  their  ability  to  convert  special  access  circuits  to  EELs.);  Supplemental  Order  Clarification,  15  FCC  Rcd  at  9598- 


 9604,  paras.  21-  32;  see  also  SWBT  Texas  Order,  15  FCC  Rcd  at  18468-  70,  paras.  224-  28;  Verizon  Pennsylvania  Order,  16  FCC  Rcd  at  17460-  61,  paras.  73-  75. 


 823  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  4123,  para.  340. 
 824  See  Alabama  Commission  Comments  at  81;  Kentucky  Commission  Comments  at  15;  Mississippi  Commission 
 Comments  at  3;  North  Carolina  Commission  Comments  at  44;  South  Carolina  Commission  Comments  at  1. 
 825  We  review  the  order  completion  interval,  percent  missed  installation  appointment,  and  trunk  group 
 performance  metrics  to  determine  compliance  with  checklist  item  1.  BellSouth  met  or  exceeded  the  benchmark  and  parity  standards  for  these  metrics,  with  one  minor  exception.  See  Alabama  C.  2.1  (Order  Completion  Interval,  Local 


 Interconnection  Trunks)  (out  of  parity  in  April  in  Alabama). 
 826  NewSouth  August  5  Ex  Parte  Letter. 
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 lasted  more  than  63  hours,  and  resulted  in  more  than  150,000  blocked  calls.  827  In  each  instance,  New  South  contends  that  its  customers  were  unable  to  receive  or  complete  local  and/  or  long 
 distance  calls.  828  NewSouth  claims  that  the  outages  are  due  to  improperly  performed  translation  changes  or  upgrades  by  BellSouth  without  adequate  notice  of  the  specific  date  upon  which  they 
 were  scheduled  to  occur.  829  In  order  to  prevent  future  outages,  NewSouth  has  proposed,  among  other  things,  that  BellSouth  exchange  documents  relating  to  transition  changes,  notify  NewSouth 
 of  all  ongoing  and  planned  projects  which  might  impact  NewSouth,  provide  a  distribution  schedule  of  translations  and  switch  upgrade  projects  and  identification  of  contacts  for  each,  and  a 
 contractual  commitment  from  BellSouth  that  NewSouth  will  be  contacted  every  time  translations  are  modified  on  its  trunk  groups,  and  an  action  plan  that  details  the  specific  steps  BellSouth  is 
 implementing  in  the  LISC/  NISC  to  assure  that  errors  are  not  repeated.  830 
 215.  According  to  BellSouth,  however,  it  has  investigated  the  seven  outages  and  determined  that  only  three  were  specific  to  NewSouth,  and  could  not  find  a  record  of  a  trouble 


 report  for  the  seventh  outage  occurring  on  January  7,  2002,  in  Mobile,  Alabama.  831  BellSouth  indicates  that  the  six  outages  occurred  over  a  ten-  month  period  in  four  different  states,  and  no 
 systemic  operational  issues  have  been  identified.  832  BellSouth  also  explains  that  during  the  time  period  covered  by  these  six  outages,  it  made  thousands  of  translation  changes  in  its  switches  and, 
 for  the  overwhelming  majority,  the  changes  were  accomplished  without  incident.  833  BellSouth  states  that  for  NewSouth  alone,  BellSouth  has  made  translations  changes  for  approximately 
 4,863  trunks  during  this  time  period.  834 
 216.  We  find  that  the  record  demonstrates  that,  overall,  BellSouth  provides  interconnection  to  competing  LECs  at  an  acceptable  quality.  While  we  are  concerned  with  the 


 number  and  scope  of  network  outages  that  NewSouth  has  experienced  in  such  a  short  period  of  time,  we  do  not  believe  that  these  warrant  a  finding  of  checklist  noncompliance.  We  find  it 
 significant  that  BellSouth  has  performed  literally  thousands  of  translations  changes,  during  the  same  period,  without  any  reported  problems,  and  we  observe  that  there  is  no  evidence  that  the 
 problem  indicates  a  systemic  flaw  in  BellSouths  operations.  Furthermore,  as  in  prior  section 
 827  NewSouth  August  5  Ex  Parte  Letter  at  2.  NewSouth  indicates  that  the  outages  occurred  in  Mobile,  Alabama, 
 Charlotte,  North  Carolina,  Louisville,  Kentucky  and  Spartanburg,  South  Carolina.  Id.  NewSouth  contends  that  the  outages  had  an  almost  universal  impact  on  NewSouths  customer  base  in  Charlotte,  North  Carolina,  Mobile, 


 Alabama,  and  Spartanburg,  South  Carolina.  Id. 
 828  Id. 


 829  Id. 
 830  Id.  at  4-  5. 
 831  See  BellSouth  August  15  Non-  pricing  Ex  Parte  Letter  at  2. 
 832  Id. 
 833  Id. 
 834  Id. 
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 271  applications,  we  rely  on  trunk  blockage  data  to  evaluate  a  BOCs  interconnection  quality.  We  find  that  BellSouths  performance  data  demonstrate  that  it  provides  interconnection  that  is 
 equal-  in-  quality  to  the  interconnection  it  provides  in  its  own  network.  In  particular,  BellSouth  met  or  exceeded  the  benchmark  for  trunk  blockage  in  all  five  states  for  the  relevant  period.  835 
 Accordingly,  in  light  of  BellSouths  overall  trunk  blockage  performance  and  that  the  majority  of  its  switch  translations  are  accomplished  without  incident,  we  do  not  find  that  NewSouths  claims 
 warrant  a  finding  of  checklist  noncompliance.  Should  BellSouths  performance  in  this  area  deteriorate,  we  will  pursue  appropriate  enforcement  action. 


 217.  Collocation.  We  conclude  that  BellSouth  provides  legally  binding  terms  and  conditions  for  collocation  in  its  interconnection  agreements  and  SGATs.  In  reaching  this 
 conclusion,  we  note  that  BellSouth  states  that  it  permits  the  collocation  of  equipment  as  required  in  the  Collocation  Remand  Order.  836  Furthermore,  we  find  that  BellSouth  has  met  all  of  the 
 applicable  performance  metrics  for  collocation  for  the  relevant  months  in  each  of  the  states.  837 
 218.  Other  Issues.  Supra  claims  that  BellSouth  has  not  provided  competitive  LECs  with  nondiscriminatory  access  to  interconnection.  838  Supra  contends  that  in  seeking  to 


 implement  its  interconnection  agreement  with  BellSouth,  it  has  faced  numerous  problems  and  hurdles  put  in  place  by  BellSouth.  839  As  the  Commission  found  in  previous  proceedings,  given 
 the  time  constraints,  the  section  271  process  simply  could  not  function  if  we  were  required  to  resolve  every  interpretive  dispute  between  a  BOC  and  each  competitive  LEC  about  the  precise 
 content  of  the  BOCs  obligations  to  its  competitors.  840  These  claims  are  not  indicative  of  BellSouths  ability  to  provide  interconnection.  Rather,  these  claims  are  fact-  specific  disputes 
 between  independent  competitive  LECs  and  BellSouth  regarding  its  statutory  obligations.  We  find,  therefore,  that  a  complaint  brought  to  a  state  commission  or  to  this  Commission  pursuant  to 
 section  208  are  more  appropriate  venues  for  such  allegations  to  be  examined,  and  we  do  not  resolve  them  here. 


 219.  Pricing  of  Interconnection.  Commenters  allege  two  distinct  types  of  interconnection  pricing  violations.  KMC  and  NuVox  contend  that  BellSouth  is  charging  tariffed 
 access  rates  for  interconnection  trunks  and  facilities  in  violation  of  the  Commissions  TELRIC 


 835  See  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  C.  5.1  (Trunk  Group  Performance   
 Aggregate). 
 836  BellSouth  Application  at  33. 


 837  See  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  E.  1  (Collocation). 
 838  See  generally  Supra  Comments  at  2-  6. 
 839  Id.  at  2. 
 840  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9139,  para.  209;  Verizon  Pennsylvania  Order,  16  FCC 
 Rcd  at  17475,  para.  101;  SWBT  Kansas/  Oklahoma  Order,  16  FCC  Rcd  at  6355,  para.  230;  SWBT  Texas  Order,  15  FCC  Rcd  at  18366-  67,  paras.  22-  27. 
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 pricing  rules.  NewSouth  makes  similar  claims.  841  AT&  T  argues  that  BellSouth  denies  competitive  LECs  the  ability  to  define  the  scope  of  their  local  calling  areas  and  to  exchange  local 
 traffic  with  BellSouth  based  on  the  competitive  LECs  definition,  not  BellSouths  definition,  of  the  local  calling  area.  842  After  reviewing  the  record  before  us,  we  find  no  violation  of  checklist 
 item  1. 
 220.  KMC  and  NuVoxs  joint  comments  state  that  BellSouth  historically  has  charged  NuVox  and  other  CLECs  [tariffed]  access  rates  [for  interconnection  trunks  and  facilities]  .  .  .  in 


 violation  of  Section  252(  d)(  2)  of  the  Act  and  the  Commissions  pricing  rules  set  forth  in  the  Local  Competition  Order.  843  Since  the  filing  of  these  comments,  however,  KMC  and  BellSouth 
 have  reached  agreement  in  principle  on  billing  disputes  associated  with  interconnection  trunks  and  facilities,  subject  to  the  parties  execution  of  a  confidential  settlement  agreement 
 incorporating  those  terms.  844 
 221.  NuVox  and  BellSouth  also  have  resolved  their  billing  dispute  relating  to  interconnection  trunks  and  facilities  for  the  term  of  their  current  interconnection  agreement, 


 subject  to  incorporation  of  the  terms  of  settlement  into  a  confidential  settlement  agreement.  845  On  September  9,  2002,  prior  to  settling  this  billing  dispute,  NuVox  conceded  that,  if  BellSouth 
 complied  with  their  interconnection  agreement,  NuVoxs  concerns  would  certainly  be  addressed.  846  As  we  noted  above,  the  parties  have  settled  their  billing  dispute,  which  arguably 


 841  KMC/  NuVox  Comments  at  5;  NewSouth  August  5  Ex  Parte  Letter  at  5.  Although  KMC  and  NuVox  refer  to 
 special  access  rates  throughout  their  comments,  BellSouth  treats  these  comments  as  if  they  refer  to  switched  dedicated  access  rates.  BellSouth  Ruscilli/  Cox  Reply  Aff.  at  para.  7.  Neither  KMC  nor  NuVox  contends  that 


 BellSouth  is  incorrect.  See  also  Letter  from  John  J.  Heitmann,  Counsel  to  NuVox,  to  William  Maher,  Chief,  Wireline  Competition  Bureau,  Federal  Communications  Commission,  et  al.  WC  Docket  No.  02-  150  at  2,  3,  6  (filed 
 Aug.  29,  2002)  (NuVox  August  29  Ex  Parte  Letter)  (discussing  the  imposition  of  tariffed  access  rates). 
 842  AT&  T  Comments  at  26. 


 843  KMC/  NuVox  Comments  at  5.  See  also  NuVox  August  29  Ex  Parte  Letter  at  2;  Letter  from  John  J.  Heitmann, 
 Counsel  to  NuVox,  to  Marlene  H.  Dortch,  Secretary,  Federal  Communications  Commission,  WC  Docket  No.  02-  150  at  1  (filed  Sept.  9,  2002)  (NuVox  September  9  Ex  Parte  Letter).  NewSouth  makes  a  similar  argument.  See 


 NewSouth  August  5  Ex  Parte  Letter  at  5  (  BellSouth  charges  tariffed  access  charges  (federal  and  state)  for  all  or  portions  of  interconnection  trunks  that  NewSouth  orders  from  BellSouth.).  It  concedes,  however,  that  its 
 interconnection  agreement  with  BellSouth  provides  for  billing  a  percentage  of  interconnection  trunks  at  tariffed  rates.  Id.  NewSouths  contentions,  therefore,  relate  to  whether  BellSouth  is  billing  NewSouth  in  accordance  with 
 the  interconnection  agreement.  This  is  a  contractual  dispute  that  should  be  resolved  in  the  first  instance  by  state  commissions.  See  Verizon  Pennsylvania  Order,  16  FCC  Rcd  at  17484,  para.  118;  Verizon  New  Jersey  Order,  17 
 FCC  Rcd  at  12354,  para.  159. 
 844  Letter  from  Jonathan  Banks,  General  Attorney,  BellSouth,  to  Marlene  H.  Dortch,  Federal  Communications 
 Commission,  WC  Docket  No.  02-  150  (filed  Sept.  14,  2002)  (BellSouth  September  14  Ex  Parte  Letter). 
 845  Id.  See  also  Letter  from  John  J.  Heitmann,  Counsel  to  NuVox,  to  William  Maher,  Chief,  Wireline 
 Competition  Bureau,  Federal  Communications  Commission,  WC  Docket  No.  02-  150  at  1-  2  n.  1  (filed  Sept.  16,  2002)  (NuVox  September  16  Ex  Parte  Letter). 


 846  NuVox  September  9  Ex  Parte  Letter  at  4.  NuVox  alleges  that  BellSouth  has  not  abided  by  the  terms  of  that 
 agreement.  Id. 
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 resolves  issues  involving  compliance  with  their  interconnection  agreement  and  therefore  addresses  NuVoxs  concerns  as  stated  on  September  9.  However,  NuVox  and  BellSouth  each 
 expressly  reserved  its  rights  to  challenge  the  other  partys  legal  or  regulatory  position  concerning  the  appropriate  charges  for  interconnection  trunks  and  facilities.  847  Indeed,  NuVox  and 
 BellSouth  continue  to  disagree  concerning  the  proper  pricing  of  interconnection  trunks.  848  Thus,  we  briefly  address  the  parties  underlying  claims  below. 


 222.  The  dispute  between  BellSouth  and  NuVox  primarily  concerns  the  billing  for  a  one-  way  trunk  group  that  runs  from  NuVox  to  BellSouth  that  can  carry  all  types  of  traffic.  849 
 BellSouth  uses  factors  to  distinguish  interstate  from  intrastate  traffic,  and  to  distinguish  intrastate  local  traffic  from  intrastate  intraLATA  traffic  carried  on  this  trunk  group.  In  particular, 
 BellSouth  requires  NuVox  (and  other  carriers)  to  report  a  Percent  Interstate  Usage  (PIU)  factor  to  identify  the  percentage  of  interstate  traffic  on  interconnection  trunks  that  deliver  traffic  to 
 BellSouth.  850  The  remaining  traffic  is  deemed  to  be  intrastate.  851  According  to  BellSouth,  under  the  terms  of  the  BellSouth-  NuVox  interconnection  agreement,  all  non-  transit  local  intrastate 
 traffic  is  billed  according  to  bill-  and-  keep,  and  the  remaining  traffic  is  billed  according  to  the  appropriate  access  tariff.  852 


 223.  In  order  to  distinguish  the  local  intrastate  traffic  from  other  intrastate  traffic,  BellSouth  requires  NuVox  (and  other  carriers)  to  report  a  Percent  Local  Facility  (PLF).  853 
 BellSouth  concedes  that  the  interconnection  agreement  with  NuVox  does  not  contain  the  PLF  reporting  requirement.  854  By  Carrier  Notification  Letter  dated  June  1,  2000,  BellSouth  informed 
 competitive  LECs  that  it  would  be  imposing  the  PLF  billing  scheme.  855  BellSouth  justifies  the 
 847  BellSouth  September  14  Ex  Parte  Letter;  NuVox  September  16  Ex  Parte  Letter. 


 848  See,  e.  g.,  Letter  from  John  J.  Heitmann,  Counsel  to  NuVox,  to  William  Maher,  Chief,  Wireline  Competition 
 Bureau,  Federal  Communications  Commission,  et  al.,  WC  Docket  No.  02-  150  at  2  (filed  Sept.  13,  2002)  (NuVox  September  13  Ex  Parte  Letter);  NuVox  September  16  Ex  Parte  Letter  at  1-  2  n1. 


 849  Letter  from  Ernest  Bush,  BellSouth,  to  Marlene  H.  Dortch,  Federal  Communications  Commission,  WC  Docket 
 02-  150  at  1-  2  (filed  Sept.  13,  2002)  (BellSouth  September  13  Ex  Parte  Letter).  This  trunk  group  is  a  switched  dedicated  trunk  group.  Id.  There  is  also  a  two-  way  transit  trunk  group  that  runs  between  NuVox  and  BellSouth, 


 and  a  BellSouth  one-  way  trunk  group  that  runs  from  BellSouth  to  NuVox  and  carries  intraLATA  and  local  traffic.  Id.  To  the  extent  that  NuVoxs  arguments  apply  to  BellSouths  pricing  of  transit  trunks,  we  note  that  the 
 Commission  has  not  had  occasion  to  determine  whether  incumbent  LECs  have  a  duty  to  provide  transit  service  under  section  251(  c)(  2),  and  we  do  not  find  clear  Commission  precedent  or  rules  declaring  such  a  duty.  We 
 therefore  do  not  a  violation  of  checklist  item  1  in  connection  with  BellSouths  provision  of  transit  trunks. 
 850  BellSouth  September  13  Ex  Parte  Letter  at  2;  NuVox  August  29  Ex  Parte  Letter  Attach.  A  at  6  (defining  PIU). 


 851  BellSouth  September  13  Ex  Parte  Letter  at  2. 
 852  Id.  at  4. 
 853  Id. 
 854  Id. 
 855  Id. 
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 imposition  of  the  PLF  by  stating  that,  because  the  rates,  terms,  and  conditions  of  the  BellSouth-NuVox  interconnection  agreement  apply  only  to  local  interconnection,  it  is  necessary  to  have  an 
 operational  mechanism  to  separate  the  local  and  the  access  portion  of  the  facilities.  856  BellSouth  adds  that  requiring  the  reporting  of  a  PLF  represent[  s]  the  logical  means  by  which  the  parties 
 can  implement  the  intent  of  the  [a]  greement,  namely  that  the  rates,  terms  and  conditions  of  the  [a]  greement  apply  only  to  local  interconnection.  857  BellSouth  uses  the  PLF  to  charge  access 
 charges  for  the  portions  of  the  interconnection  trunks  carrying  interexchange  traffic.  According  to  BellSouth,  its  longstanding  policy  on  this  issue  has  never  been  challenged  in  an  arbitration 
 (or  a  complaint  proceeding)  in  any  of  BellSouths  nine  states.  858  We  note  that  this  policy  was  not  challenged  in  the  BellSouth  Georgia/  Louisiana  section  271  proceeding  before  this 
 Commission. 
 224.  NuVox  focuses  its  argument  on  the  application  of  the  PLF  to  interconnection  facilities.  NuVox  argues  that,  while  BellSouth  is  entitled  to  charge  access  rates  for  certain  types 


 of  traffic,  BellSouths  rates  for  the  interconnection  trunks  that  carry  any  traffic  must  be  cost-based.  859  NuVox  points  out  that  sections  251(  c)(  2)  and  252(  d)(  1)  of  the  Act  require  incumbent 
 LECs,  such  as  BellSouth,  to  provide  cost-  based  interconnection  trunks  and  facilities  for  the  transmission  and  routing  of  telephone  exchange  service  and  exchange  access.  860 


 225.  NuVox  and  BellSouth  differ  markedly  in  how  the  Commissions  interpretations  of  sections  251(  c)(  2)  and  252(  d)(  1)  apply  to  their  relationship.  861  NuVox  argues  that  the  only 
 type  of  carrier  not  entitled  to  cost-  based  interconnection  is  one  that  is  exclusively  an  IXC  requesting  interconnection  only  for  the  purpose  of  originating  or  terminating  its  interexchange 
 traffic.  862  NuVox  states  that  it  provides  both  telephone  exchange  service  and  exchange  access  service  over  the  one-  way  trunk  and  is  thus  clearly  entitled  to  cost-  based  interconnection  under 
 the  Act  and  the  Commissions  rules.  863  In  making  this  argument,  Nuvox  relies  on  the  Commissions  statement  in  the  Local  Competition  Order  that  an  IXC  that  requests 
 interconnection  solely  for  the  purpose  of  originating  or  terminating  its  interexchange  traffic,  not  for  the  provision  of  telephone  exchange  service  and  exchange  access  to  others,  on  an  incumbent 


 856  Id. 
 857  Id.  at  5. 
 858  Id.  at  8. 
 859  NuVox  September  9  Ex  Parte  Letter  at  1-  2. 
 860  47  U.  S.  C.    251(  c)(  2),  252(  d)(  1).  This  requirement  is  incorporated  in  checklist  item  1.  See  id.   
 271(  c)(  2)(  B)(  i). 
 861  See,  e.  g.,  NuVox  September  16  Ex  Parte  Letter  at  5-  6. 


 862  NuVox  August  29  Ex  Parte  Letter  at  11. 
 863  KMC/  NuVox  Comments  at  7. 
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 LECs  network  is  not  entitled  to  receive  interconnection  pursuant  to  section  251(  c)(  2).  864  NuVox  contends  that  it  provides  both  telephone  exchange  and  exchange  access  services  to  its 
 end  users  and  that  it  therefore  is  not  requesting  interconnection  solely  for  the  purpose  of  originating  and  terminating  its  interexchange  traffic  when  it  delivers  to  BellSouth  local  and  toll 
 traffic  originated  by  NuVoxs  end  user  customers.  865 
 226.  BellSouth,  however,  contends  that  the  Act  and  Commission  rules  authorize  its  practice  of  pricing  interconnection  trunks  according  to  the  traffic  that  is  carried  on  them.  It 


 argues  that  it  is  entitled  to  impose  access  charges  for  the  portion  of  interconnection  facilities  that  carries  non-  local  traffic.  866  BellSouth  relies  on  language  in  the  Local  Competition  Order  that 
 preserves  the  distinction  between  interconnection  under  section  251(  c)(  2)  and  access  charges.  867  In  particular,  the  Local  Competition  Order  states  that  access  charges  are  not  affected  by  our 
 rules  implementing  section  251(  c)(  2),  868  and  also  notes  that  access  charges  are  not  implicated  by  the  Commissions  decisions  regarding  whether  parties  who  seek  to  interconnect  solely  for  the 
 purpose  of  originating  or  terminating  interexchange  traffic  on  the  incumbents  network  are  entitled  to  obtain  interconnection  pursuant  to  section  252(  c)(  2).  869  BellSouth  notes  that  this 
 distinction  was  upheld  in  Competitive  Telecommunications  Assn  v.  FCC,  where  the  U.  S.  Court  of  Appeals  for  the  Eighth  Circuit  stated  that  LECs  will  continue  to  provide  exchange  access  to 
 IXCs  for  long-  distance  service,  and  continue  to  receive  payment,  under  the  pre-  Act  regulations  and  rates.  870 


 227.  The  issue  presented  by  NuVox  and  BellSouth  is  whether  access  charges  may  be  imposed  for  interconnection  facilities  to  the  extent  that  they  are  used  to  carry  interexchange 
 traffic,  including  interexchange  traffic  originated  by  end  users  to  whom  a  competitive  LEC  also  provides  telephone  exchange  service.  The  Commission  has  never  squarely  addressed  this  issue, 
 and  no  party  has  sought  arbitration  of  the  issue  with  BellSouth.  871  In  accordance  with  prior  section  271  orders,  new  interpretive  disputes  concerning  the  precise  content  of  an  incumbent 
 LECs  obligations  to  its  competitors,  disputes  that  our  rules  have  not  yet  addressed  and  that  do 
 864  Local  Competition  Order,  11  FCC  Rcd  at  15598,  para.  191  (original  emphasis). 
 865  KMC/  NuVox  Comments  at  6-  7;  NuVox  August  29  Ex  Parte  Letter  at  5,  11-  12.  See  also  NuVox  September 
 16  Ex  Parte  Letter  at  5. 
 866  BellSouth  September  13  Ex  Parte  Letter  at  5-  7. 


 867  See  id.  at  5-  6. 
 868  See  Local  Competition  Order,  11  FCC  Rcd  at  15590,  para.  176. 
 869  Id.  at  15598,  para.  191  n.  398. 
 870  BellSouth  September  13  Ex  Parte  Letter  at  6  (quoting  Competitive  Telecommunications  Assn  v.  FCC,  117 
 F.  3d  1068,  1073  (8  th  Cir.  1997)  (CompTel)).  In  the  CompTel  case,  IXCs  had  argued  that  LEC-  provided  interstate  access  services  fell  within  the  scope  of  interconnection  under  section  251(  c)(  2)  and  that,  therefore,  access  charges 


 should  be  governed  by  the  cost-  based  standard  of  section  252(  d)(  1).  See  CompTel,  117  F.  3d  at  1071. 
 871  BellSouth  September  13  Ex  Parte  Letter  at  8. 
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 not  involve  per  se  violations  of  the  Act  or  our  rules,  are  not  appropriately  dealt  with  in  the  context  of  a  section  271  proceeding.  872  We  therefore  decline  to  find  a  violation  of  checklist  item 
 1  based  on  the  existence  of  this  interpretive  dispute  between  BellSouth  and  NuVox.  Of  course,  in  the  event  that  the  Commission  issues  a  ruling  on  the  matters  raised  by  the  dispute  between 
 BellSouth  and  NuVox,  then  BellSouth  must  comply  with  the  ruling  or  be  subject  to  enforcement  action  by  the  Commission. 


 228.  AT&  T  also  alleges  that  BellSouth  does  not  comply  with  checklist  item  1.  BellSouth  allegedly  denies  AT&  T  and  other  competitive  LECs  the  practical  ability,  currently 
 enjoyed  by  BellSouth,  to  define  the  scope  of  their  local  calling  areas  and  to  exchange  local  traffic  with  BellSouth  based  on  the  CLECs  definition,  rather  than  BellSouths  definition,  of  the 
 local  calling  area.  873  BellSouth  implements  this  practice  by  insisting  that  AT&  T  and  other  CLECs  compensate  BellSouth  at  switched  access  rates  for  any  intraLATA  calls  that  originate  or 
 terminate  outside  the  local  calling  area  as  BellSouth  has  defined  it.  874  AT&  T  alleges  that  BellSouth  refuses  to  accept  the  higher  PLF  that  results  from  AT&  Ts  offer  of  LATA-  wide  local 
 calling.  875  As  a  result,  although  AT&  T  provides  local  service  to  customers  on  a  LATA-  wide  basis,  AT&  T  is  being  forced  to  compensate  BellSouth  at  switched  access  rather  than  reciprocal 
 compensation  rates  for  that  portion  of  the  traffic  that  originates  or  terminates  outside  the  BellSouth-  defined  calling  area.  876 


 229.  As  a  regulatory  matter,  telecommunications  traffic  subject  to  reciprocal  compensation  under  section  251(  b)(  5)  excludes,  inter  alia,  traffic  that  is  interstate  or  intrastate 
 exchange  access.  877  In  the  Local  Competition  Order,  the  Commission  concluded  that  state  commissions  have  the  authority  to  determine  whether  calls  passing  between  LECs  should  be 
 subject  to  access  charges  or  reciprocal  compensation  for  those  areas  where  LECs  service  areas  do  not  overlap.  878  Accordingly,  we  reject  AT&  Ts  request  that  we  modify  any  state 


 872  Verizon  Pennsylvania  Order,  16  FCC  Rcd  at  17470,  para.  92;  BellSouth  Georgia/  Louisiana  Order,  17  FCC 
 Rcd  at  9075,  para.  114;  SWBT  Texas  Order,  15  FCC  Rcd  at  18366,  para.  24;  SWBT  Kansas/  Oklahoma  Order,  16  FCC  Rcd  at  6246,  para.  19. 


 873  AT&  T  Comments  at  26;  see  also  AT&  T  August  23  Pricing  and  Growth  Tariff  Ex  Parte  Letter  at  8-  9 
 (  Nowhere  [in  BellSouths  Reply]  does  [BellSouth]  deny  that  it  is  free  to  define  the  scope  of  its  own  local  calling  areas,  or  that  it  has  taken  advantage  of  this  freedom  by  offering  extended-  area  service  plans  to  customers  throughout 


 its  region.). 
 874  Id.  at  28. 


 875  Id. 
 876  Id. 
 877  47  C.  F.  R.    51.701(  b)(  1). 
 878  Local  Competition  Order,  12  FCC  Rcd  at  16013,  para.  1035. 
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 commissions  distinction  between  those  calls  subject  to  access  charges  and  those  subject  to  reciprocal  compensation.  879 
 230.  In  any  event,  as  AT&  T  itself  recognizes,  the  interconnection  agreement  between  AT&  T  and  BellSouth  expressly  covers  the  LATA-  wide  calling  issue.  880  Indeed,  AT&  Ts 
 principal  complaint  is  that  BellSouth  refuses  to  perform  according  to  the  terms  in  its  interconnection  agreements.  881  Interpretive  disputes  concerning  interconnection  agreements  are 
 for  the  state  commissions  to  decide  in  the  first  instance,  and  this  Commission  will  not  normally  preempt  a  state  commissions  decisionmaking  process.  882 


 231.  For  the  foregoing  reasons,  we  reject  commenters  allegations  of  error  and  find  that  BellSouth  complies  with  checklist  item  1. 
 B.  Checklist  Item  4  -  Unbundled  Local  Loops 
 232.  Section  271(  c)(  2)(  B)(  iv)  of  the  Act  requires  that  a  BOC  provide  [  l]  ocal  loop  transmission  from  the  central  office  to  the  customers  premises,  unbundled  from  local  switching 


 or  other  services.  883  Based  on  the  evidence  in  the  record,  we  conclude,  as  did  the  state  commissions,  884  that  BellSouth  demonstrates  that  it  provides  unbundled  local  loops  in  accordance 


 879  AT&  T  Comments  at  28.  AT&  T  also  asserts  that  nothing  in  the  Virginia  Arbitration  Order  established  that 
 ILECs  may  deny  CLECs  equal  flexibility  to  define  their  local  calling  areas.  AT&  T  August  23  Pricing  and  Growth  Tariff  Ex  Parte  Letter  at  9  (citing  In  the  Matter  of  Petition  of  WorldCom,  Inc.  Pursuant  to  Section  252(  e)(  5)  of  the 


 Communications  Act  for  Preemption  of  the  Jurisdiction  of  the  Virginia  State  Corporation  Commission  Regarding  Interconnection  Disputes  with  Verizon  Virginia  Inc.,  and  for  Expedited  Arbitration,  CC  Docket  Nos.  00-  218,  00- 
 249,  and  00-  251,  Memorandum  Opinion  and  Order,  DA  02-  1731  (rel.  July  15,  2002)  (Virginia  Arbitration  Order).  Consistent  with  the  Local  Competition  Order,  however,  the  definition  of  a  local  calling  area  is  the  prerogative  of  a 
 state  commission.  Local  Competition  Order,  12  FCC  Rcd  at  16013,  para.  1035. 
 880  AT&  T  Comments  App.,  Ex.  A,  Declaration  of  Denise  Berger  (AT&  T  Berger  Decl.)  at  paras.  9-  11. 


 881  Id.  at  para.  15  (emphasis  added).  AT&  T  states  that  this  is  not  an  interconnection  agreement  dispute  because  of 
 BellSouths  belief  that  CLEC[  s]  do  not  have  a  right  to  LATA-  wide  calling.  AT&  T  August  23  Pricing  and  Growth  Tariff  Ex  Parte  Letter  at  10  (citation  omitted).  We  believe  that  a  more  accurate  characterization  of  the  issue 


 is  whether  state  commissions  have  the  authority  to  define  the  local  calling  area  as  they  see  fit.  See  Local  Competition  Order,  12  FCC  Rcd  at  16013,  para.  1035. 


 882  Verizon  Pennsylvania  Order,  16  FCC  Rcd  at  17484,  para.  118;  Verizon  New  Jersey  Order,  17  FCC  Rcd  at 
 12354,  para.  159. 
 883  47  U.  S.  C.    271(  c)(  2)(  B)(  iv).  The  Commission  has  defined  the  loop  as  a  transmission  facility  between  a 
 distribution  frame,  or  its  equivalent,  in  an  incumbent  LEC  central  office,  and  the  demarcation  point  at  the  customer  premises.  Dark  fiber  and  loop  conditioning  equipment  are  among  the  features,  functions,  and  capabilities  of  the 


 loop.  UNE  Remand  Order,  15  FCC  Rcd  at  3772-  73,  paras.  166-  67  n.  301.  For  a  discussion  of  the  requirements  of  checklist  item  4,  see  Appendix  H  at  paras.  48-  52,  infra. 


 884  See  Alabama  Commission  Comments  at  211;  Kentucky  Commission  Comments  at  31,  41;  Mississippi 
 Commission  Comments  at  3;  North  Carolina  Commission  Comments  at  206;  South  Carolina  Commission  Comments  at  1. 
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 with  the  requirements  of  section  271  and  our  rules.  As  in  past  section  271  orders,  our  conclusion  is  based  on  our  review  of  BellSouths  performance  for  all  loop  types,  including  voice  grade 
 loops,  xDSL-  capable  loops,  high  capacity  loops,  and  digital  loops,  as  well  as  our  review  of  BellSouths  hot  cut,  line-  sharing,  and  line  splitting  processes.  We  note  that,  as  of  June  30,  2002, 
 BellSouth  states  that  it  had  provisioned  15,913  loops  in  Alabama,  3,841  loops  in  Kentucky,  6,258  loops  in  Mississippi,  51,229  loops  in  North  Carolina,  and  14,901  loops  in  South 
 Carolina.  885 
 233.  Consistent  with  our  prior  section  271  orders,  we  do  not  address  aspects  of  BellSouths  loop  performance  where  our  review  of  the  record  satisfies  us  that  BellSouths 


 performance  complies  with  the  parity  and  benchmark  measures  established  in  the  relevant  states.  886  Instead,  we  focus  our  discussion  on  those  areas  where  the  record  indicates 
 discrepancies  between  BellSouths  performance  for  its  competitors  and  BellSouths  performance  for  its  own  retail  operations.  As  in  past  section  271  proceedings  in  the  course  of  our  review,  we 
 look  for  patterns  of  systemic  performance  disparities  that  have  resulted  in  competitive  harm  or  that  otherwise  have  denied  new  entrants  a  meaningful  opportunity  to  compete.  887  Where 
 BellSouths  competitive  LEC  volumes  in  a  particular  state  are  too  small  to  provide  a  meaningful  assessment  of  BellSouths  loop-  provisioning  capabilities,  we  look  to  BellSouths  recent 
 performance  in  Georgia  to  help  us  determine  whether  BellSouth  meets  this  checklist  item.  888 
 234.  Hot  Cut  Activity.  Like  the  state  commissions,  889  we  find  that  BellSouth  is  providing  voice  grade  loops  through  hot  cuts  in  each  state  in  accordance  with  the  requirements 


 of  checklist  item  4.  890  BellSouth  provides  hot  cuts  in  each  of  the  states  within  reasonable  time  intervals,  891  at  an  acceptable  level  of  quality,  with  minimal  service  disruption,  and  with  a 
 minimum  number  of  troubles  following  installation.  892 


 885  See  BellSouth  August  14  OSS  and  Loops  Ex  Parte  Letter  at  3. 
 886  See,  e.  g.,  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9144,  para.  219;  Verizon  Connecticut  Order,  16 
 FCC  Rcd  at  14151-  52,  para.  9. 
 887  See,  e.  g.,  Verizon  Massachusetts  Order,  16  FCC  Rcd  at  9055-  56,  para.  122. 


 888  See  SWBT  Kansas/  Oklahoma  Order,  16  FCC  Rcd  at  6254,  paras.  36-  37  (determining  that  recent  data 
 regarding  SWBTs  performance  in  Texas  provides  a  reliable  indicator  of  SWBTs  performance  in  Kansas  and  Oklahoma). 


 889889  See  Alabama  Commission  Comments  at  204;  Kentucky  Commission  Comments  at  32;  Mississippi 
 Commission  Comments  at  3;  North  Carolina  Commission  Comments  at  197;  South  Carolina  Commission  Comments  at  1. 


 890  A  hot  cut  is  the  process  of  converting  a  customer  from  one  network,  usually  a  UNE-  platform  served  by  an 
 incumbent  LEC's  switch,  to  a  UNE-  loop  served  by  another  carrier's  switch.  The  cut  is  said  to  be  hot  because  telephone  service  on  the  specific  customer's  loop  is  interrupted  for  a  brief  period  of  time  during  the  conversion 


 process.  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  3953,  4104,  para.  291  n.  925. 
 891  See  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  2.12.1-  B.  2.12.2  (Coordinated  Customer 
 Conversions);  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  2.13.1-  B.  2.13.4  (%  Hot  Cuts>  15  (continued.) 
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 235.  Voice  Grade  Loops.  We  find,  as  did  the  state  commissions,  893  that  BellSouth  provisions  voice  grade  loops  to  competitors  in  a  nondiscriminatory  manner.  BellSouth  met  the 
 benchmark  and  parity  standards  for  installation  timeliness,  894  installation  quality,  895  and  maintenance  and  repair  timeliness  and  quality  with  regard  to  voice  grade  loops  in  each  of  the 
 states  in  each  relevant  month,  with  minor  exceptions.  896  These  exceptions  are  relatively  slight  and  are  not  competitively  significant  to  competitive  LECs.  897  We  therefore  find  that  these 
 exceptions  do  not  warrant  a  finding  of  checklist  noncompliance. 
 (Continued  from  previous  page)  Minutes  Early);  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  2.14.1-  B.  2.14.4  (Hot  Cut 
 Timeliness);  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  2.15.1-  B.  2.15.4  (%  Hot  Cuts>  15  Minutes  Late);  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  2.16.1-  B.  2.16.2  (Average 
 Recovery  Time    CCC).  But  see  KMC  Comments  at  10  (alleging  that  BellSouths  hot  cut  coordination  is  substandard). 


 892  See  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  2.17.1.1-  B.  2.17.2.2  (%  Provisioning 
 Troubles  within  7  Days    Hot  Cuts).  We  note  that,  while  BellSouth  failed  to  meet  one  of  these  benchmarks  during  June  in  South  Carolina,  it  exceeded  that  benchmark  on  average  during  March  through  June  in  South  Carolina.  See 


 South  Carolina  B.  2.17.1.1  (%  Provisioning  Troubles  within  7  Days,  Hot  Cuts,  UNE  Loop  Design/  Dispatch).  We  therefore  find  that  the  disparity  in  June  does  not  rise  to  the  level  of  checklist  noncompliance.  We  also  note  that 
 although  BellSouths  volumes  were  low  for  certain  hot  cut  measures  in  the  applicable  states,  BellSouths  hot  cut  performance  in  Georgia  raises  no  issues  regarding  checklist  compliance.  See  Georgia  B.  2.12.1-  B.  2.17.2.2  (Hot  Cut 
 Provisioning). 
 893  See  Alabama  Commission  Comments  at  211;  Kentucky  Commission  Comments  at  31,  41;  Mississippi 
 Commission  Comments  at  3;  North  Carolina  Commission  Comments  at  190;  South  Carolina  Commission  Comments  at  1. 


 894  See  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  1.9.8.-  B.  1.9.13,  B.  1.12.8-  B.  1.1.12.13, 
 B.  1.13.8-  B.  1.13.13  (FOC  Timeliness,  2  Wire  Analog  Loops);  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  2.1.8.1.1-  B.  2.1.13.2.4  (Order  Completion  Interval,  2  Wire  Analog  Loops); 


 Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  2.18.8.1.1-  B.  2.18.13.2.4  (%  Missed  Installation  Appointments,  2  Wire  Analog  Loops). 


 895  See  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  2.19.8.1.1-  B.  2.19.13.2.4  (%  Provisioning 
 Troubles  within  30  Days,  2  Wire  Analog  Loops);  Alabama  B.  2.19.8.1.2-  B.  2.19.13.2.4  (%  Provisioning  Troubles  within  30  Days,  2  Wire  Analog  Loops);  Alabama/  Kentucky/  Mississippi  B.  3.2.8.1-  B.  3.2.9.2  (Customer  Trouble 


 Report  Rate,  2  Wire  Analog  Loops). 
 896  See  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  3.1.8.1-  B.  3.1.9.2  (%  Missed  Repair 
 Appointments,  2  Wire  Analog  Loops);  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  3.3.8.1-  B.  3.3.9.2  (Maintenance  Average  Duration,  2  Wire  Analog  Loops);  Alabama/  Kentucky/  Mississippi/  North 


 Carolina/  South  Carolina  B.  3.3.8.1-  B.  3.3.9.2  (%  Repeat  Troubles  within  30  Days,  2  Wire  Analog  Loops). 
 897  See  Alabama  B.  3.1.8.1  (Missed  Repair  Appointments,  2  Wire  Analog  Loops,  Design/  Dispatch)  (out  of  parity 
 in  June  with  a  11.54%  trouble  report  rate  for  competitive  LECs  and  a  6.79%  trouble  report  rate  for  BellSouths  retail  operations,  but  a  4.50%  overall  trouble  report  rate  for  competitive  LECs  and  a  6.30%  overall  trouble  report 


 rate  for  BellSouths  retail  operations  during  March  through  June);  South  Carolina  B.  3.2.9.1  (Customer  Trouble  Report  Rate,  2  Wire  Analog  Loops,  Non-  Design/  Dispatch)  (out  of  parity  in  two  months  with  a  4.38%  trouble  report 
 rate  during  March  and  a  7.05%  trouble  report  rate  during  April  for  competitive  LECs  and  a  1.60%  trouble  report  rate  during  March  and  a  1.82%  trouble  report  rate  during  April  for  BellSouths  retail  operations,  but  a  4.13%  overall 
 trouble  report  rate  for  competitive  LECs  and  a  1.83%  overall  trouble  report  rate  for  BellSouths  retail  operations  (continued.) 
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 236.  xDSL-  Capable  Loops.  We  find,  as  did  the  state  commissions,  898  that  BellSouth  demonstrates  that  it  provides  stand-  alone  xDSL-  capable  loops  in  accordance  with  checklist  item 
 4.  BellSouths  performance  with  respect  to  the  percentage  of  provisioning  troubles  within  30  days,  a  metric  that  measures  installation  quality,  appears  to  be  out  of  parity  in  Kentucky, 
 Mississippi,  North  Carolina,  and  South  Carolina  for  recent  months.  899  We  find,  however,  that  this  performance  does  not  warrant  a  finding  of  checklist  noncompliance  in  view  of  the  low 
 number  of  installation  troubles  reported  in  each  of  the  five  states.  We  recognize,  as  we  have  in  prior  section  271  orders,  that  a  small  handful  of  observations  can  cause  seemingly  large 
 variations  in  the  performance  measures.  900  Moreover,  given  BellSouths  parity  of  performance  with  respect  to  this  metric  in  Georgia  for  the  relevant  period,  we  find  that  BellSouth  provisions 
 xDSL  loops  in  a  nondiscriminatory  manner  in  all  five  states.  901  Next,  we  note  that  BellSouths  (Continued  from  previous  page) 
 from  March  through  June);  Georgia  B.  1.12.12  (FOC  Timeliness,  Partially  Mechanized,  2  Wire  Analog  Loops  with  LNP,  Design)  (under  benchmark  requiring  that  BellSouth  provide  firm  order  confirmations  within  10  hours  at  least 
 85%  of  the  time,  out  of  parity  in  May  with  an  83.41%  score  and  June  with  a  78.71%  score,  but  86.13%  overall  average  during  March  through  June);  Georgia  B.  2.1.13.1.4  (Order  Completion  Interval,  2  Wire  Analog  Loops  with 
 LNP/  Non-  Design/<  10  Circuits/  Dispatch)  (out  of  parity  from  March  through  June  with  average  intervals  of  4.90  days  for  competitive  LECs  and  1.  56  days  for  BellSouths  retail  operations;  competitive  LEC  volume  of  54  orders 
 represents  only  about  5.15%  of  total  voice  grade  loops  that  competitive  LECs  ordered  for  Georgia  during  the  same  period).  We  consider  these  data  for  Georgia  because  BellSouth  volumes  under  these  metrics  were  low  in  certain  of 
 the  applicable  states.  See,  e.  g.,  Kentucky  B.  1.12.12  (FOC  Timeliness,  Partially  Mechanized,  2  Wire  Analog  Loops  with  LNP,  Design);  Kentucky  B.  2.1.13.1.4  (Order  Completion  Interval,  2  Wire  Analog  Loops  with  LNP/  Non-Design/< 
 10  Circuits/  Dispatch). 
 898  See  Alabama  Commission  Comments  at  211;  Kentucky  Commission  Comments  at  31,  41;  Mississippi 
 Commission  Comments  at  3;  North  Carolina  Commission  Comments  at  192;  South  Carolina  Commission  Comments  at  1. 


 899  Specifically,  BellSouths  performance  data  show  that  it  was  out  of  parity  in  Kentucky,  Mississippi,  North 
 Carolina,  and  South  Carolina  in  April,  and  missed  parity  in  North  Carolina  in  May  and  South  Carolina  in  March.  In  Mississippi,  BellSouths  performance  data  show  that  competitive  LECs  experience  an  average  of  7.01%  trouble 


 reports  within  30  days  after  installation  of  an  xDSL  loop,  compared  to  an  average  of  3.14%  for  BellSouth  retail  operations  from  March  through  June.  In  North  Carolina,  competitive  LECs  experience  an  average  of  8.15%, 
 compared  to  an  average  of  3.09%  for  BellSouth  retail.  See  Mississippi/  North  Carolina  B.  2.19.5.1.1  (%  Provisioning  Troubles  within  30  Days,  ADSL,  HDSL  and  UCL<  10  Circuits/  Dispatch).  We  note  that  BellSouths  performance 
 data  is  based  on  low  volumes  in  Kentucky  and  South  Carolina.  Further,  there  are  no  volumes  reported  for  BellSouth  retail  operations  in  Kentucky  in  March,  May,  and  June.  In  Kentucky,  competitive  LECs  experience  an 
 average  of  5.26%  provisioning  trouble  reports  within  30  days,  compared  to  an  average  of  0.00%,  while  in  South  Carolina  competitors  experience  an  average  of  13.04%  trouble  reports  within  30  days,  compared  to  an  average  of 
 3.05%  for  BellSouth  retail  operations.  See  Kentucky/  South  Carolina  B.  2.19.5.1.1  (%  Provisioning  Troubles  within  30  Days,  ADSL,  HDSL  and  UCL<  10  Circuits/  Dispatch). 


 900  See  Verizon  Massachusetts  Order,  16  FCC  Rcd  at  8988,  para.  93  n.  296.  BellSouths  installation  quality 
 performance  data  show  that  competitive  LECs  volumes  were,  on  average,  44  in  Alabama,  10  in  Kentucky,  39  in  Mississippi,  58  in  North  Carolina,  and  6  in  South  Carolina  during  the  relevant  period.  See 


 Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  2.19.5.1.1  (%  Provisioning  Troubles  within  30  Days,  ADSL,  HDSL  and  UCL<  10  Circuits/  Dispatch). 


 901  In  Georgia,  BellSouths  performance  data  show  that  it  achieved  parity  for  this  metric  for  all  months  during  the 
 relevant  period.  See  Georgia  B.  2.19.5.1.1  (%  Provisioning  Troubles  within  30  Days,  ADSL,  HDSL  and  UCL<  10  Circuits/  Dispatch). 
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 order  processing  timeliness  performance  was  slightly  out  of  parity  in  Kentucky,  Mississippi,  and  North  Carolina  on  a  few  occasions.  902  We  find  that  these  performance  discrepancies  are  slight, 
 episodic,  and  do  not  appear  to  be  competitively  significant. 
 237.  Covad  alleges  that  its  own  data  show  that  BellSouths  UCL-  ND  order  completion  interval,  903  installation  quality,  904  and  maintenance  average  duration  905  performance  demonstrates 


 discriminatory  treatment.  906  BellSouth,  however,  contends  that  its  performance  with  respect  to  this  type  of  loop  has  been  excellent  and  that  it  installs  UCL-  ND  loops  in  a  timely  manner.  907  We 
 find  that  Covad-  specific  data  is  outweighed  by  evidence  of  BellSouths  overall  performance.  As  in  prior  section  271  orders,  performance  data  relative  to  competitive  LECs  on  an  aggregate  basis 
 is  the  most  persuasive  evidence  of  whether  a  BOC  meets  the  checklist  requirements.  908  BellSouths  performance  data  demonstrate  that  BellSouth  met  or  exceeded  the  parity  standard 
 for  the  order  completion  interval.  909  In  addition,  BellSouths  maintenance  and  repair  performance,  which  measures  the  timeliness  and  quality  of  the  maintenance  and  repair  functions, 


 902  BellSouth  met  the  vast  majority  of  its  order  processing  timeliness  benchmarks.  In  Kentucky,  BellSouth 
 missed  the  benchmark  (95%  within  3  hours)  for  mechanized  orders  in  March.  However,  competitive  LECs  experience  an  average  of  97.20%  within  3  hours  for  the  relevant  period.  See  Kentucky  B.  1.9.5  (FOC  Timeliness, 


 Mechanized,  ADSL,  HDSL  and  UCL).  For  partially  mechanized  orders  in  Mississippi  and  North  Carolina,  BellSouth  missed  the  benchmark  (85%  within  10  hours)  in  March  and  May,  respectively.  In  Mississippi, 
 competitive  LECs  experience  an  average  of  90.60%  within  10  hours,  and  in  North  Carolina  competitive  LECs  experience  an  average  of  88.57%  within  10  hours.  See  Mississippi/  North  Carolina  B.  1.12.5  (FOC  Timeliness, 
 Partially  Mechanized,  ADSL,  HDSL  and  UCL). 
 903  Covad  contends  that  for  orders  of  this  loop  requiring  dispatch,  BellSouth  completed  orders  for  its  own 
 customers  one  day  faster  than  Covads  orders  in  North  Carolina,  two  days  faster  in  Alabama,  and  five  days  faster  in  Kentucky.  Covad  Comments  at  27. 


 904  Covad  maintains  that  BellSouth  failed  to  properly  provision  38  of  50  UCL-  ND  orders  in  Florida  in  January 
 2002.  Covad  Comments  at  24. 
 905  Specifically,  Covad  states  that  in  Alabama  for  UCL-  ND  loops  not  requiring  dispatch,  BellSouth  fixed 
 problems  for  its  own  customers  in  8.10  hours,  while  taking  24  hours  to  get  Covads  customers  back  to  service.  Covad  Comments  at  29-  30. 


 906  See  generally  Covad  Comments  at  22-  31.  In  fact,  Covad  contends  that  BellSouths  provisioning  problems 
 with  the  UCL-  ND  loop  have  been  so  bad  that  Covad  was  forced  to  stop  ordering  the  loop  entirely  in  every  state  in  the  BellSouth  region  except  Florida.  Id.  at  23. 


 907  BellSouth  Reply  Comments  at  55;  BellSouth  Varner  Reply  Aff.  at  paras.  117,  120.  Concerning  Covads  claim 
 that  BellSouth  provides  retail  customers  faster  repair  services  on  average  than  it  provides  for  Covads  UCL-  ND  orders,  BellSouth  states  that  Covad  fails  to  note  the  differences  in  sample  size  and  the  effect  even  a  single  miss 


 can  have  on  the  reported  performance  for  the  competitive  LEC  product.  Id. 
 908  See,  e.  g.,  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9148,  para.  226. 


 909  See  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  2.  2.  2  (Order  Completion  Interval  within 
 7  Days,  ADSL,  HDSL  and  UCL/  Loop  without  Conditioning<  6  Circuits/  Dispatch). 
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 has  shown  parity  during  the  relevant  period.  910  Moreover,  as  discussed  above,  we  find  that  BellSouth  provisions  xDSL-  capable  loops  of  a  quality  sufficient  to  afford  competitors  a 
 meaningful  opportunity  to  compete.  Thus,  although  Covad  claims  that  its  data  show  discriminatory  performance,  allegedly  anomalous  results  for  a  single  carrier  in  this  instance  do 
 not  qualify  as  a  pattern  of  systemic  performance  disparities  that  result  in  competitive  harm.  911 
 238.  UNE  ISDN  Loops.  Like  the  state  commissions,  912  we  find  that  BellSouth  provides  ISDN  loops  to  competitors  in  a  nondiscriminatory  manner.  BellSouths  performance  under  the 


 order  completion  interval  and  the  percentage  missed  installation  appointment  submetrics  shows  that  BellSouth  has  been  timely  in  the  provisioning  of  ISDN  loops.  913  Further,  BellSouths 
 performance  data  demonstrate  that  it  generally  met  the  parity  standard  for  the  percentage  of  provisioning  troubles  within  30  days  (dispatch)  of  installation  metric.  914 


 239.  BellSouths  data,  however,  reveal  some  performance  issues  with  respect  to  the  maintenance  and  repair  of  ISDN  loops.  Specifically,  while  BellSouth  met  or  exceeded  the  parity 
 standard  for  metrics  measuring  the  percentage  of  missed  repairs,  maintenance  average  duration, 


 910  BellSouth  met  or  exceeded  parity  with  respect  to  the  percentage  of  missed  repair  appointments,  customer 
 trouble  report  rate,  and  maintenance  average  duration  metrics  in  each  of  the  states  during  the  relevant  period.  See  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  3.1.5.1-  B.  3.1.5.2  (%  Missed  Repair 


 Appointments,  ADSL,  HDSL  and  UCL/  Dispatch  and  Non-  Dispatch);  B.  3.2.5.1-  B.  3.2.5.2  (Customer  Trouble  Report  Rate,  ADSL,  HDSL  and  UCL/  Dispatch  and  Non-  Dispatch);  B.  3.3.5.1-  B.  3.3.5.2  (Maintenance  Average  Duration, 
 ADSL,  HDSL  and  UCL/  Dispatch  and  Non-  Dispatch).  BellSouth  met  the  standard  for  repeat  troubles  within  30  days,  with  two  minor  exceptions.  See  South  Carolina  B.  3.4.5.2  (%  Repeat  Troubles  within  30  Days,  ADSL,  HDSL 
 and  UCL/  Non-  Dispatch).  BellSouth  missed  this  metric  in  April  and  June. 
 911  If  evidence  becomes  available  to  the  Commission  in  the  future  sufficient  to  show  systemic  performance 
 disparities,  we  will  pursue  appropriate  enforcement  action. 
 912  See  Alabama  Commission  Comments  at  211;  Kentucky  Commission  Comments  at  31,  41;  Mississippi 
 Commission  Comments  at  3;  North  Carolina  Commission  Comments  at  192;  South  Carolina  Commission  Comments  at  1. 


 913  BellSouth  met  the  benchmark  for  installation  timeliness  and  missed  installation  appointments  for  each  month 
 in  all  five  states  during  the  relevant  period.  See  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  2.1.6.3.1  (Order  Completion  Interval,  UNE  ISDN<  6  Circuits/  Dispatch);  Alabama/  Kentucky/  Mississippi/  North 


 Carolina/  South  Carolina  B.  2.18.6.1.1  (%  Missed  Installation  Appointments,  UNE  ISDN<  10  Circuits/  Dispatch). 
 914  BellSouths  performance  data  show  that  it  provides  an  installation  quality  sufficient  to  afford  competitors  a 
 meaningful  opportunity  to  compete.  See  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  2.19.6.1.1  (%  Provisioning  Troubles  within  30  Days,  UNE  ISDN<  10  Circuits/  Dispatch).  However,  BellSouth 


 missed  one  month  in  Kentucky  and  two  months  in  North  Carolina.  In  Kentucky,  competitive  LECs  experienced  an  average  of  8.00%  provisioning  troubles  within  30  days  of  installation,  compared  to  6.79%  for  BellSouth  retail 
 operations.  See  Kentucky  B.  2.19.6.1.1  (%  Provisioning  Troubles  within  30  Days,  UNE  ISDN<  10  Circuits/  Dispatch).  In  North  Carolina,  competitors  experienced  an  average  of  8.  22%  compared  to  5.  82%  for 
 BellSouth  retail  for  the  same  period.  See  North  Carolina  B.  2.19.6.1.1  (%  Provisioning  Troubles  within  30  Days,  UNE  ISDN<  10  Circuits/  Dispatch.  We  find,  however,  that  BellSouths  overall  performance  for  this  metric  show 
 that  BellSouth  provides  competitors  with  sufficient  installation  quality. 
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 and  the  percentage  of  repeat  troubles  with  few  minor  exceptions,  915  BellSouth  was  out  of  parity  with  the  customer  trouble  report  rate  for  several  months  in  each  of  the  five  states.  916  We  do  not 
 find,  however,  that  these  performance  discrepancies  are  competitively  significant.  Further,  we  note  that  no  commenter  has  commented  on  BellSouths  ISDN  loop  performance  with  respect  to 
 this  metric.  Accordingly,  in  light  of  BellSouths  competitive  carrier  ISDN  loop  record  overall,  we  do  not  find  that  BellSouths  performance  demonstrates  that  it  fails  to  meet  the  requirements 
 of  checklist  item  4. 
 240.  Digital  Loops.  We  find,  as  did  the  state  commissions,  917  that  BellSouths  performance  with  respect  to  digital  loops  complies  with  checklist  item  4.  BellSouths 


 performance  in  this  area  generally  met  the  parity  standards  established  by  the  state  commissions  for  installation  timeliness.  918  We  recognize,  however,  that  BellSouths  performance  in  North 


 915  Specifically,  BellSouths  missed  repair  appointment  performance  (dispatch)  was  out  of  parity  for  two  months 
 in  North  Carolina  and  one  month  in  South  Carolina  during  the  relevant  period.  See  North  Carolina/  South  Carolina  B.  3.1.6.1  (%  Missed  Repair  Appointments,  UNE  ISDN/  Dispatch).  In  North  Carolina,  competitive  carriers 


 experienced  an  average  of  1.19%  missed  repair  appointments  compared  to  1.03%  for  BellSouth  retail  operations  from  March  through  June.  In  South  Carolina,  competitors  experienced  an  average  of  7.14%  compared  to  3.09%  for 
 BellSouth  retail  for  the  same  period.  Id.  In  Alabama,  BellSouth  was  only  out  of  parity  in  May  for  non-  dispatch  loops.  See  Alabama  B.  3.1.6.2  (%  Missed  Repair  Appointments,  UNE  ISDN/  Non-  Dispatch).  BellSouths 
 maintenance  average  duration  (dispatch)  was  only  out  of  parity  for  one  month  in  South  Carolina.  See  South  Carolina  B.  3.3.6.1  (Maintenance  Average  Duration,  UNE  ISDN/  Dispatch).  BellSouth  performance  data  show  that 
 it  was  out  of  parity  for  one  month  in  Alabama  and  South  Carolina  for  maintenance  average  duration  (non-  dispatch).  In  North  Carolina,  BellSouth  missed  parity  for  two  months,  and  competitive  carriers  experience  an  average  of 
 2.75%  misses  compared  to  an  average  of  1.73%  for  BellSouths  retail  operations  for  the  relevant  period.  See  Alabama/  North  Carolina/  South  Carolina  B.  3.3.6.2  (Maintenance  Average  Duration,  UNE  ISDN/  Non-  Dispatch). 
 BellSouth  was  also  slightly  out  of  parity  for  the  percentage  of  repeat  troubles  within  30  days  metric.  However,  BellSouths  performance  data  for  this  metric  show  that  BellSouth  was  out  of  parity  for  one  month  in  Alabama 
 (dispatch),  and  one  month  in  Mississippi  and  North  Carolina  (non-  dispatch).  See  Alabama  B.  3.4.6.1  (%  Repeat  Troubles  within  30  Days,  UNE  ISDN/  Dispatch);  Mississippi/  North  Carolina  B.  3.4.6.2  (%  Repeat  Troubles  within 
 30  Days,  UNE  ISDN/  Non-  Dispatch).  Should  BellSouths  performance  in  this  area  deteriorate,  we  will  pursue  appropriate  enforcement  action. 


 916  Specifically,  BellSouths  customer  trouble  report  rate  (dispatch)  was  out  of  parity  for  one  month  in  South 
 Carolina,  two  months  in  Alabama  and  Kentucky,  three  months  in  Mississippi,  and  four  months  in  North  Carolina.  See  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  3.2.6.1  (Customer  Trouble  Report  Rate,  UNE 


 ISDN/  Dispatch).  In  Mississippi,  competitive  carriers  experienced  an  average  of  1.33%  dispatch  trouble  reports  compared  to  an  average  of  0.61%  for  BellSouth  retail  operations  for  the  relevant  period.  In  North  Carolina, 
 competitors  experienced  an  average  of  1.18%  dispatch  trouble  reports  compared  to  an  average  of  0.64%  for  BellSouth  retail.  See  Mississippi/  North  Carolina  B.  3.2.6.1  (Customer  Trouble  Report  Rate,  UNE  ISDN/  Dispatch). 
 BellSouths  customer  trouble  report  rate  (non-  dispatch)  performance  data  show  that  BellSouth  was  in  parity  for  all  months  reported.  See  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  3.2.6.2  (Customer  Trouble 
 Report  Rate,  UNE  ISDN/  Non-  Dispatch). 
 917  See  Alabama  Commission  Comments  at  211;  Kentucky  Commission  Comments  at  31,  41;  Mississippi 
 Commission  Comments  at  3;  North  Carolina  Commission  Comments  at  192;  South  Carolina  Commission  Comments  at  1. 


 918  See  Kentucky/  Mississippi/  South  Carolina  B.  2.1.18.1.1  (Order  Competition  Interval,  Digital  Loops<  DS1/<  10 
 Circuits/  Dispatch);  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  2.1.18.1.2-  B.  2.1.18.2.2  (Order  (continued.) 
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 Carolina  with  respect  to  an  installation  timeliness  measure    the  order  completion  interval  metric  (dispatch)    was  out  of  parity  for  March  through  June.  919  The  record  shows,  however,  that  no 
 facilities  were  available  for  a  disproportionate  percentage  of  the  competitive  LEC  orders  reflected  in  this  metric  and  that  completing  these  orders  required  BellSouth  to  dispatch 
 technicians  to  provision  new  loops.  920  We  find  that  BellSouth  reasonably  assigned  these  orders  longer  intervals  than  it  assigned  to  orders  that  did  not  involve  the  dispatch  of  technicians. 
 Because  the  retail  orders  reflected  in  this  metric  typically  did  not  involve  the  dispatch  of  technicians,  we  also  find  that  the  disparity  in  BellSouths  performance  under  this  metric  does  not 
 raise  an  issue  of  checklist  noncompliance.  921  In  addition,  the  data  for  the  other  installation  timeliness  metric    percent  missed  installation  appointments    show  that  BellSouth  missed  no 
 installation  appointments  for  competitive  LECs  during  the  relevant  period  in  North  Carolina.  922  In  these  circumstances,  we  conclude  that  BellSouths  performance  under  this  order  completion 
 interval  metric  has  not  denied  competitive  LECs  a  meaningful  opportunity  to  compete  in  North  Carolina. 


 241.  We  reject  KMCs  argument  that  BellSouths  provisioning  and  maintenance  and  repair  performance  for  digital  loops  preclude  a  finding  of  checklist  compliance.  923  BellSouths 
 installation  quality  measure  for  digital  loops    the  percentage  of  provisioning  troubles  within  30  days    was  out  of  parity  for  certain  months  in  Kentucky,  Mississippi,  North  Carolina,  and  South 
 Carolina.  924  The  record  shows,  however,  that  BellSouth  has  implemented  several  initiatives  to 


 (Continued  from  previous  page)  Competition  Interval,  Other  Digital  Loops<  DS1);  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina 
 B.  2.18.18.1-  B.  2.18.18.2.2  (%  Missed  Installation  Appointments,  Digital  Loops<  DS1/<  10  Circuits). 
 919  See  North  Carolina  B.  2.1.18.1.1  (Order  Competition  Interval,  Digital  Loops<  DS1/<  10  Circuits/  Dispatch) 
 (monthly  averages  ranging  from  8.  72  days  to  9.  69  days  for  competitive  LECs  and  from  3.  74  days  to  5.  51  days  for  BellSouths  retail  operations). 


 920  BellSouth  August  14  Ex  Parte  Letter  at  3;  BellSouth  Varner  Reply  Aff.  at  para.  224. 
 921  BellSouth  August  14  Ex  Parte  Letter  at  3. 
 922  See  BellSouth  Varner  Reply  Aff.  at  para.  224;  North  Carolina  B.  2.18.18.1.1  (%  Missed  Installation 
 Appointments,  Digital  Loops<  DS1/<  10  Circuits/  Dispatch)  (no  missed  installation  appointments  for  competitive  LECs  from  March  through  June,  versus  an  overall  3.70  %  missed  installation  appointment  rate  for  BellSouths  retail 


 operations  during  the  same  period). 
 923  KMC  Comments  at  15-  16. 


 924  See  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  2.19.18.1.1  (%  Provisioning  Troubles  within  30 
 Days,  Digital  Loops<  DS1/<  10  Circuits/  Dispatch).  Specifically,  BellSouth  was  below  parity  for  this  metric  for  May  in  Kentucky  (11.76%  of  installations  for  competitive  LECs  having  troubles  within  30  days,  versus  1.25%  for 


 BellSouths  retail  operations);  for  April  in  Mississippi  (8.97%  of  installations  for  competitive  LECs  having  troubles  within  30  days,  versus  3.29%  for  BellSouths  retail  operations);  for  March  through  May  in  North  Carolina  (6.25%, 
 10.12%,  and  10.14%  of  installations  for  competitive  LECs  having  troubles  within  30  days,  versus  3.58%,  2.21%,  and  3.52%  for  BellSouths  retail  operations);  and  for  March  and  April  in  South  Carolina  (15.63%  and  9.43%  of 
 installations  for  competitive  LECs  having  troubles  within  30  days,  versus  3.24%  and  3.71%  for  BellSouths  retail  operations).  Id. 
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 reduce  provisioning  troubles.  925  These  initiatives  include  working  with  competitive  LECs  to  rectify  any  issues  and  concerns  prior  to  completing  a  service  order.  926  In  addition,  at  the 
 competitive  LECs  request,  BellSouth  will  engage  in  cooperative  testing  to  ensure  that  the  loop  being  provisioned  meets  the  relevant  technical  criteria.  927  Given  this  evidence,  and  recognizing 
 BellSouths  generally  acceptable  performance  for  other  categories  of  loops,  we  find  that  BellSouths  performance  under  this  installation  quality  metric  does  not  warrant  a  finding  of 
 checklist  noncompliance. 
 242.  Similarly,  although  BellSouths  maintenance  and  repair  performance  for  digital  loops  was  generally  in  parity  during  the  applicable  period,  928  one  measure  of  that  performance   


 the  customer  trouble  report  rate    was  out  of  parity  for  the  applicable  states  throughout  much  of  the  relevant  period.  929  Because  the  overall  trouble  report  rate  for  digital  loops  that  BellSouth 
 provided  competitive  LECs  was  low  during  the  relevant  period,  930  we  find  that  these  disparities  lack  competitive  significance.  931  BellSouth  also  was  out  of  parity  with  regard  to  another  measure 
 of  maintenance  and  repair  quality    maintenance  average  duration    during  certain  months  in  Alabama,  Mississippi,  North  Carolina,  and  South  Carolina.  932  However,  BellSouths  overall 


 925  See  BellSouth  August  14  OSS  and  Loops  Ex  Parte  Letter  at  4. 
 926  BellSouth  Ainsworth  Aff.  at  para.  139. 
 927  Id. 
 928  See  BellSouth  August  14  OSS  and  Loops  Ex  Parte  Letter  at  9,  11-  14,  21,  23-  27,  29-  32  (discussing  %  Missed 
 Repair  Appointments,  Maintenance  Average  Duration,  and  %  Repeat  Troubles  within  30  Days,  Digital  Loops).  We  note  that  while  BellSouth  has  provided  disaggregated  maintenance  and  repair  data  for  digital  loops,  no  metrics  have 


 been  established  for  these  data. 
 929  See  BellSouth  August  14  OSS  and  Loops  Ex  Parte  Letter  at  15,  17-  20  (discussing  Customer  Trouble  Report 
 Rate,  Digital  Loops<  DS1/  Dispatch)  (out  of  parity  in  applicable  states  throughout  relevant  period);  id.  (discussing  Customer  Trouble  Report  Rate,  Digital  Loops<  DS1/  Non-  Dispatch)  (out  of  parity  in  Alabama  during  April  and  May, 


 in  Mississippi  during  June,  in  North  Carolina  during  March  through  May,  and  in  South  Carolina  during  March). 
 930  During  that  period,  the  average  trouble  report  rate  for  digital  loops  provided  competitive  LECs  was  1.12%  in 
 Alabama,  1.27%  in  Kentucky,  1.54%  in  Mississippi,  1.64%  in  North  Carolina,  and  1.63%  in  South  Carolina.  See  BellSouth  August  14  Ex  Parte  Letter  at  15,  17-  20  (discussing  Customer  Trouble  Report  Rate,  Digital  Loops<  DS1). 


 931  See  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9150,  para.  230. 
 932  See  BellSouth  August  14  OSS  and  Loops  Ex  Parte  Letter  at  27,  29-  32  (discussing  Maintenance  Average 
 Duration,  Digital  Loops<  DS1/  Non-  Dispatch).  Specifically,  in  Alabama,  BellSouths  performance  for  this  measure  was  out  of  parity  in  April  with  an  average  duration  of  5.01  hours  for  competitive  LECs  and  2.28  hours  for 


 BellSouths  retail  operations,  and  in  May  with  an  average  duration  of  7.03  hours  for  competitive  LECs  and  2.55  hours  for  BellSouths  retail  operations.  In  Mississippi,  BellSouths  performance  was  out  of  parity  in  June  with  an 
 average  duration  of  5.63  hours  for  competitive  LECs  and  2.50  hours  for  BellSouths  retail  operations.  In  North  Carolina,  BellSouths  performance  was  out  of  parity  in  June  with  an  average  duration  of  4.29  hours  for  competitive 
 LECs  and  2.29  hours  for  BellSouths  retail  operations.  In  South  Carolina,  BellSouths  performance  was  out  of  parity  in  March  with  an  average  duration  of  4.87  hours  for  competitive  LECs  and  1.99  hours  for  BellSouths  retail 
 operations,  and  in  June  with  an  average  duration  of  3.92  hours  for  competitive  LECs  and  1.88  hours  for  BellSouths  retail  operations.  Id. 
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 performance  for  this  measure  during  the  applicable  period  for  competitive  LECs  was  comparable  to  its  performance  for  its  own  retail  operations.  933  We  therefore  find  that  the  disparities  in 
 maintenance  average  duration  also  lack  competitive  significance.  Moreover,  contrary  to  KMCs  assertion,  BellSouth  was  consistently  in  parity,  with  very  few  repeat  troubles,  with  regard  to  its 
 measure  for  repeat  troubles  within  30  days  of  maintenance  or  repair  of  digital  loops.  934 
 243.  High  Capacity  Loops.  We  find,  as  did  the  state  commissions,  935  that  BellSouths  performance  with  respect  to  high  capacity  loops  complies  with  checklist  item  4.  We  reach  this 


 conclusion  despite  the  fact  that  BellSouths  performance  with  respect  to  certain  performance  metrics    including  the  percentage  of  missed  installation  appointments  for  high  capacity  loops 
 and  the  percentage  of  troubles  found  within  30  days  following  installation  of  a  high  capacity  loop    is  out  of  parity  for  several  recent  months.  936  As  we  discuss  below,  however,  this 
 performance  does  not  warrant  a  finding  of  checklist  noncompliance.  As  the  Commission  has  stated  in  the  past,  isolated  cases  of  performance  disparity,  especially  when  the  margin  of 
 disparity  is  small,  generally  will  not  result  in  a  finding  of  checklist  noncompliance.  937 
 244.  First,  we  recognize  that  BellSouths  performance  with  respect  to  an  installation  timeliness  measure    the  missed  installation  appointments  metric    was  out  of  parity  for  most  of 


 the  months  in  Alabama.  938  The  record  shows,  however,  that  BellSouth  missed  few  installation 
 933  During  the  relevant  period,  BellSouths  maintenance  intervals  for  digital  loops  averaged  4.76  hours  for 
 competitive  LECs  and  4.25  hours  for  BellSouths  retail  operations  in  Alabama,  4.52  hours  for  competitive  LECs  and  3.78  hours  for  BellSouths  retail  operations  in  Kentucky,  4.83  hours  for  competitive  LECs  and  4.09  hours  for 


 BellSouths  retail  operations  in  Mississippi,  3.71  hours  for  competitive  LECs  and  3.83  hours  for  BellSouths  retail  operations  in  North  Carolina,  and  5.14  hours  for  competitive  LECs  and  3.39  hours  for  BellSouths  retail  operations 
 in  South  Carolina.  See  BellSouth  August  14  OSS  and  Loops  Ex  Parte  Letter  at  27,  29-  32  (discussing  Maintenance  Average  Duration,  Digital  Loops<  DS1). 


 934  See  KMC  Comments  at  16.  Specifically,  the  record  shows  that  during  the  relevant  period,  competitive  LECs 
 reported  only  77  repeat  troubles  for  digital  loops  in  the  applicable  states.  BellSouth  August  14  OSS  and  Loops  Ex  Parte  Letter  at  21,  23-  26  (discussing  %  Repeat  Troubles  within  30  Days,  Digital  Loops<  DS1). 


 935  See  Alabama  Commission  Comments  at  211;  Kentucky  Commission  Comments  at  31,  41;  Mississippi 
 Commission  Comments  at  3;  North  Carolina  Commission  Comments  at  206;  South  Carolina  Commission  Comments  at  1. 


 936  See  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  2.19.19.1.1  (%  Provisioning  Troubles 
 within  30  Days,  Digital  Loops>  DS1/<  10  Circuits/  Dispatch);  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  2.18.19.1.1  (%  Missed  Installation  Appointments,  Digital  Loops>  DS1/<  10  Circuits/  Dispatch).  Notes 


 941  and  944,  infra,  provide  the  relevant  data  regarding  BellSouths  performance  under  these  metrics. 
 937  See  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9144,  para.  619;  Verizon  Massachusetts  Order,  16 
 FCC  Rcd  at  9055-  56,  para.  22;  Verizon  Pennsylvania  Order,  16  FCC  Rcd  at  17468-  69,  para.  90  (finding  that  even  poor  performance  with  regard  to  high  capacity  loops  did  not  warrant  a  finding  of  checklist  noncompliance  for  all 


 loop  types  where  high  capacity  loops  represented  only  a  small  percentage  of  all  loops  ordered  by  competitors  in  a  state).  Should  BellSouths  performance  in  this  area  deteriorate,  we  will  pursue  appropriate  enforcement  action. 


 938  See  Alabama  B.  2.18.19.1.1  (%  Missed  Installation  Appointments,  Digital  Loops>  DS1/<  10  Circuits/  Dispatch). 
 BellSouths  data  for  Alabama  show  that,  from  March  through  June,  BellSouth  missed  4.62%  of  its  installation  appointments  for  its  retail  high  capacity  loop  operations  and  9.51%  of  its  installation  appointments  for  competitive 


 (continued.) 
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 appointments  for  either  wholesale  or  retail  high  capacity  loops  in  Alabama  during  the  applicable  period.  939  Therefore,  a  very  small  increase  in  the  number  of  missed  installation  appointments  for 
 competitive  LEC  customers  can  cause  BellSouth  to  fail  to  achieve  parity  for  this  metric  in  a  given  month.  940  BellSouths  data  show  that  it  missed  a  total  of  29  high  capacity  loop 
 appointments  for  competitive  LECs  during  the  relevant  period  and  that  14  fewer  missed  installation  appointments  would  have  allowed  BellSouth  to  achieve  parity  with  respect  to  this 
 metric  throughout  that  period.  941  Moreover,  we  note  that  BellSouths  performance  reflected  by  an  installation  timeliness  metric    the  order  completion  interval  metric  for  high  capacity  loops   
 satisfies  the  benchmark  for  all  months.  942  Given  this  evidence,  we  do  not  find  that  lack  of  parity  on  this  missed  installation  appointments  metric  warrants  a  finding  that  BellSouth  fails  to  meet 
 checklist  item  4  in  Alabama.  943 
 245.  Next,  in  each  applicable  state,  the  percentage  of  troubles  reported  within  30  days  following  installation  was  statistically  out  of  parity  during  much  of  the  relevant  period.  944  The 


 (Continued  from  previous  page)  LECs  high  capacity  loop  operations.  Id.  We  note  that  BellSouth  was  out  of  parity  for  this  metric  for  May  in 
 Kentucky  and  North  Carolina.  Kentucky/  North  Carolina  B.  2.1.19.1.1  (Order  Completion  Interval,  Digital  Loops>  DS1/<  10  Circuits/  Dispatch).  BellSouth,  however,  failed  to  keep  only  three  high  capacity  loop  appointments 
 for  May  in  Kentucky  and  only  one  high  capacity  loop  appointment  for  May  in  North  Carolina.  These  isolated  disparities  in  performance  do  not  undercut  BellSouths  otherwise  acceptable  level  of  performance  and,  thus,  do  not 
 require  a  finding  of  checklist  noncompliance.  See,  e.  g.,  Verizon  Massachusetts  Order,  16  FCC  Rcd  at  9055-  56,  para.  122. 


 939  BellSouth  Varner  Reply  Aff.  at  para.  226;  Alabama  B.  2.18.19.1.1  (%  Missed  Installation  Appointments, 
 Digital  Loops>  DS1/<  10  Circuits/  Dispatch). 
 940  BellSouth  Varner  Reply  Aff.  at  para.  226. 


 941  BellSouths  data  show  that  of  its  high  capacity  loop  appointments  for  competitive  LECs  in  Alabama,  it  missed 
 a  total  of  eight  in  March,  nine  in  April,  six  in  May,  and  six  in  June.  While  BellSouth  achieved  parity  for  this  metric  in  Alabama  during  March,  four  fewer  missed  appointments  during  April,  five  fewer  missed  appointments  during 


 May,  and  five  fewer  missed  appointments  during  June  would  have  enabled  BellSouth  to  achieve  parity  for  this  metric  in  Alabama  during  each  relevant  month.  See  Alabama  B.  2.18.19.1.1  (%  Missed  Installation  Appointments, 
 Digital  Loops>  DS1/<  10  Circuits/  Dispatch. 
 942  See  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  2.1.19.1.1  (Order  Completion  Interval, 
 Digital  Loops>  DS1/<  10  Circuits/  Dispatch);  see  also  BellSouth  August  15  Non-  pricing  Ex  Parte  Letter  at  9-  10  (arguing  that  the  need  to  construct  or  rearrange  facilities  serving  particular  end  users  caused  many  of  the  missed 


 installation  appointments  for  high  capacity  loops);  BellSouth  Varner  Reply  Aff.  at  para.  226  (stating  that  BellSouth  missed  six  high  capacity  loop  appointments  in  March  and  seven  high  capacity  loop  appointments  in  April  because  it 
 failed  to  add  needed  facilities  at  a  single  location  prior  to  the  scheduled  installation  dates). 
 943  See  SWBT  Kansas/  Oklahoma  Order,  16  FCC  Rcd  at  6344,  para.  213. 


 944  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  2.19.19.1.1  (%  Provisioning  Troubles  within 
 30  Days,  Digital  Loops>  DS1/<  10  Circuits/  Dispatch).  In  Alabama,  competing  carriers  experienced  an  average  of  12.26%  trouble  reports  within  30  days  after  installation  of  a  high  capacity  digital  loop,  compared  to  an  average  of 


 2.98%  for  BellSouth  retail  operations  from  March  through  June.  See  Alabama  B.  2.19.19.1.1  (%  Provisioning  Troubles  within  30  Days,  Digital  Loops>  DS1/<  10  Circuits/  Dispatch).  Kentucky  performance  data  show  that 
 competitive  carriers  experienced  an  average  of  7.38%  trouble  reports,  compared  to  an  average  of  2.28%  for  BellSouth  retail  operations  for  the  same  period.  See  Kentucky  B.  2.19.19.1.1  (%  Provisioning  Troubles  within  30 
 (continued.) 
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 record  makes  clear,  however,  that  many  of  the  troubles  competitive  LECs  reported  during  that  period  were  closed  without  any  trouble  being  found.  945  Adjusting  BellSouths  reported 
 performance  data  to  eliminate  these  trouble  reports  would  improve  the  reported  results  significantly.  946  In  addition,  BellSouth  has  implemented  an  ongoing  program  to  ensure 
 installation  quality  for  high  capacity  loops  throughout  its  region.  947  This  program  has  allowed  BellSouth  to  identify  and,  in  some  instances,  eliminate  the  problems  that  cause  installation 
 problems  with  high  capacity  loops.  948  As  with  digital  loops,  this  program  includes  an  opportunity  for  the  competitive  LEC  to  engage  in  cooperative  testing  with  BellSouth  to  ensure 
 that  a  high  capacity  loop  meets  relevant  technical  criteria  prior  to  its  being  handed  off  to  the  competitive  LEC.  949  BellSouth  indicates,  however,  that,  even  with  cooperative  testing,  some 
 problems  arise  cannot  be  detected  until  the  customer  premises  equipment  is  connected  to  the  loop,  which  typically  does  not  happen  until  several  days  after  BellSouth  hands  it  off  to  the 
 competitive  LEC.  950  Given  this  evidence,  and  recognizing  BellSouths  generally  acceptable  performance  for  other  categories  of  loops,  we  find  that  BellSouths  performance  is  in  compliance 
 with  checklist  item  4. 
 246.  We  reject  KMCs  contentions  that  BellSouths  provisioning  and  maintenance  and  repair  performance  for  high  capacity  loops  precludes  a  finding  of  checklist  compliance.  951  Given 
 (Continued  from  previous  page)  Days,  Digital  Loops>  DS1/<  10  Circuits/  Dispatch).  In  Mississippi,  the  comparable  figures  were  16.44%  for 
 competitive  LECs  and  5.  92%  for  BellSouth.  See  Mississippi  B.  2.19.19.1.1  (%  Provisioning  Troubles  within  30  Days,  Digital  Loops>  DS1/<  10  Circuits/  Dispatch).  In  North  Carolina,  they  were  12.  79%  for  competitive  LECs  and 
 5.00%  for  BellSouth.  See  North  Carolina  B.  2.19.19.1.1  (%  Provisioning  Troubles  within  30  Days,  Digital  Loops>  DS1/<  10  Circuits/  Dispatch).  In  South  Carolina,  they  were  12.  18%  for  competitive  LECs  and  4.  15%  for 
 BellSouth.  South  Carolina  B.  2.19.19.1.1  (%  Provisioning  Troubles  within  30  Days,  Digital  Loops>  DS1/<  10  Circuits/  Dispatch).  We  note  that  in  the  BellSouth  Georgia/  Louisiana  Order,  the  Commission  considered 
 performance  data  showing  averages  for  trouble  reports  within  30  days  of  7.87%  for  competitive  LECs  and  1.76%  for  BellSouths  retail  operations  in  Georgia,  and  6.  93%  for  competitive  LECs  and  1.  00%  for  BellSouth  retail 
 operations  in  Louisiana.  See  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9152  n.  907. 
 945  See  BellSouth  Varner  Reply  Aff.  at  para.  219. 


 946  See  id. 
 947  BellSouth  August  14  OSS  and  Loops  Ex  Parte  Letter  at  4;  BellSouth  Ainsworth  Aff.  at  para.  139;  BellSouth 
 Varner  Reply  Aff.  at  paras.  217;  see  also  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9152-  53,  para.  233.  This  program  also  addressed  digital  loops.  See  para.  241,  supra. 


 948  BellSouth  August  14  OSS  and  Loops  Ex  Parte  Letter  at  4;  BellSouth  Varner  Reply  Aff.  at  paras.  216-  18.  For 
 instance,  to  help  assure  that  its  technicians  test  high  capacity  loops  before  reporting  that  installations  are  complete,  BellSouth  now  requires  that  the  technicians  post  the  test  results.  BellSouth  Varner  Reply  Aff.  at  para.  216. 


 949  BellSouth  Ainsworth  Aff.  at  para.  139;  BellSouth  August  14  OSS  and  Loops  Ex  Parte  Letter  at  4. 
 950  See  BellSouth  Varner  Reply  Aff.  at  para.  215  (stating  that  the  customer  premises  equipment  adds  loop  length 
 and  resistance  to  the  circuit  that  may  push  it  beyond  viable  limits). 
 951  KMC  Comments  at  15-  16.  KMC  also  asserts  that  facilities-  based  carriers  like  KMC  will  have  no  meaningful 
 opportunity  to  compete  unless  the  Commission  forces  BellSouth  to  improve  its  high  capacity  loop  performance  by  denying  this  application.  KMC  Comments  at  8-  9. 
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 BellSouths  generally  acceptable  performance  with  regard  to  other  types  of  loops,  and  BellSouths  continuing  efforts  to  ensure  installation  quality  for  high  capacity  loops,  we  cannot 
 conclude  that  BellSouths  performance  with  regard  to  high  capacity  loops  denies  competitive  LECs  a  reasonable  opportunity  to  compete.  952  Contrary  to  KMCs  assertion,  953  repeat  troubles 
 are  not  a  major  problem  with  respect  to  high  capacity  loops.  During  the  relevant  four-  month  period,  competitive  LECs  reported  only  283  repeat  troubles  for  high  capacity  loops,  a  reporting 
 rate  generally  in  parity  with  the  retail  analogue.  954  Moreover,  BellSouth  generally  maintained  parity  performance  under  the  missed  repair  appointment  and  the  mean  time  to  repair  measures 
 during  the  relevant  period.  955  Although  one  measure  of  BellSouths  maintenance  and  repair  performance  for  high  capacity  loops    the  customer  trouble  report  rate    was  out  of  parity  for  the 
 applicable  states  throughout  much  of  the  relevant  period,  956  the  overall  trouble  report  rate  for  high  capacity  loops  that  BellSouth  provided  competitive  LECs  was  low  during  the  relevant 
 period.  957  We  therefore  find  that  these  disparities  lack  competitive  significance,  958  and  that  BellSouths  maintenance  and  repair  performance  for  high  capacity  loops  warrants  a  finding  of 
 checklist  compliance. 
 247.  We  also  reject  KMCs  argument  that  BellSouths  performance  for  the  percentage  of  jeopardy  notices  for  mechanized  high  capacity  loops,  which  is  significantly  out  of  parity 


 throughout  the  four-  month  period,  959  demonstrates  that  BellSouth  assigns  high  capacity  loops  in  a 
 952  See  Verizon  Pennsylvania  Order,  16  FCC  Rcd  at  17468-  69,  para.  90. 
 953  See  KMC  Comments  at  16. 
 954  BellSouth  August  14  OSS  and  Loops  Ex  Parte  Letter  at  21,  23-  26  (discussing  %  Repeat  Troubles  within  30 
 Days,  Digital  Loops>  DS1)  (parity  during  the  applicable  months  except  with  regard  to  high  capacity  loop  troubles  requiring  dispatch  in  Mississippi  in  April,  and  high  capacity  loop  troubles  not  requiring  dispatch  in  South  Carolina 


 in  April  and  Mississippi  in  May). 
 955  See  BellSouth  August  14  OSS  and  Loops  Ex  Parte  Letter  at  9,  11-  14  (discussing  Missed  Repair 
 Appointments,  Digital  Loops>  DS1)  (parity  throughout  the  applicable  states  for  the  relevant  period  except  with  regard  to  high  capacity  loop  maintenance  requiring  dispatch  in  North  Carolina  in  May);  id.  at  27-  33  (discussing 


 Maintenance  Average  Duration,  Digital  Loops>  DS1)  (parity  throughout  the  applicable  states  for  the  relevant  period  except  with  regard  to  high  capacity  loop  maintenance  requiring  dispatch  in  North  Carolina  in  May). 


 956  See  BellSouth  August  14  OSS  and  Loops  Ex  Parte  Letter  at  15,  17-  20  (discussing  Customer  Trouble  Report 
 Rate,  Digital  Loops>  DS1/  Dispatch)  (out  of  parity  in  applicable  states  throughout  relevant  period);  id.  (discussing  Customer  Trouble  Report  Rate,  Digital  Loops>  DS1/  Non-  Dispatch)  (out  of  parity  in  Alabama,  Mississippi,  North 


 Carolina,  and  South  Carolina  throughout  relevant  period  and  in  Kentucky  from  April  through  June). 
 957  During  that  period,  the  average  trouble  report  rate  for  high  capacity  loops  was  3.19%  in  Alabama,  4.04%  in 
 Kentucky,  7.82%  in  Mississippi,  3.84%  in  North  Carolina,  and  4.22%  in  South  Carolina.  See  id.  (Customer  Trouble  Report  Rate,  Digital  Loops>  DS1). 


 958  See  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9150,  para.  230. 
 959  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  Metric  B.  2.5.19  (%  Jeopardies,  Digital 
 Loops>  DS1,  Mechanized).  BellSouths  monthly  performance  data  for  this  metric  range  from  3.93%  to  35.87%  during  the  four-  month  period;  for  competitive  LECs,  the  percentages  range  from  60.  87%  to  93.  22%. 
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 discriminatory  manner.  960  This  difference  in  the  jeopardy  rates  simply  reflects  differences  between  the  types  and  locations  of  facilities  reflected  in  this  metric.  Because  virtually  all  of  the 
 high  capacity  loops  ordered  by  competitive  LECs  terminate  at  an  end  users  premises,  it  is  likely  that  a  temporary  facilities  shortage  would  place  a  competitive  LECs  order  in  jeopardy.  961  In 
 contrast,  a  significant  percentage  of  the  high  capacity  circuits  included  in  the  retail  analogue  for  this  metric  carry  traffic  between  BellSouth  central  offices,  where  temporary  facility  shortages  are 
 significantly  less  likely.  962  We  therefore  give  this  performance  data  minimal  weight  with  respect  to  whether  BellSouths  loop  assignment  practices  are  nondiscriminatory.  963 


 248.  Line  Sharing.  We  find,  as  did  the  state  commissions,  964  that  BellSouth  offers  nondiscriminatory  access  to  the  high  frequency  portion  of  the  loop  in  each  applicable  state.  965 
 We  note  that  competitive  LECs  in  Mississippi  and  South  Carolina  have  not  yet  ordered  any  line-sharing  arrangements  from  BellSouth.  966  Because  order  volumes  for  line-  shared  loops  are  low  in 
 each  of  the  states,  we  look  to  BellSouths  line-  sharing  performance  in  Georgia  to  inform  our  analysis.  967  We  further  note  that  no  party  has  alleged  that  BellSouths  line-  sharing  offerings  in 


 960  KMC  Comments  at  11.  We  note  that  KMC  makes  no  claim  that  BellSouth  provides  jeopardy  notices  for  high 
 capacity  loops  in  a  discriminatory  manner.  See  id. 
 961  BellSouth  Varner  Reply  Aff.  at  para.  127. 


 962  Id. 
 963  We  note  that  BellSouths  systems  and  procedures  are  designed  to  ensure  that  high  capacity  loops  are  assigned 
 on  a  nondiscriminatory  basis.  BellSouth  Milner  Reply  Aff.  at  para.  10.  Specifically,  BellSouth  shows  that  it  uses  a  mechanized  system,  LFACS,  to  assign  high  capacity  loops,  among  other  facilities,  on  a  first  come,  first  served 


 basis  to  its  wholesale  and  retail  customers.  If  LFACS  cannot  find  a  suitable  facility,  the  service  order  is  referred  to  BellSouths  Address  and  Facilities  Inventory  Group  (AFIG)  or  its  Service  Advocate  Center  (SAC).  These  groups 
 assign  high  capacity  loops  and  other  facilities  in  the  order  in  which  BellSouth  originally  received  the  service  orders.  Id.  We  also  note  that  BellSouths  data  make  clear  that  it  provides  jeopardy  notices  to  competitive  LECs 
 significantly  in  advance  of  scheduled  installation  dates.  See  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  B.  2.8.19  (Average  Jeopardy  Notice  Interval,  Digital  Loops>  DS1,  Mechanized)  (showing  compliance  with 
 benchmark  requiring  that  jeopardy  notices  be  provided  at  least  48  hours  prior  to  scheduled  installation).  We  therefore  reject  KMCs  argument  that  competitive  LECs  do  not  receive  adequate  notice  that  the  change  in  service 
 providers  will  not  take  place  as  scheduled.  KMC  Comments  at  14. 
 964  See  Alabama  Commission  Comments  at  211;  Kentucky  Commission  Comments  at  32-  33;  Mississippi 
 Commission  Comments  at  3;  North  Carolina  Commission  Comments  at  200;  South  Carolina  Commission  Comments  at  1. 


 965  As  discussed  in  note  61,  supra,  the  D.  C.  Circuit  recently  stated  that  the  Line  Sharing  Order  must  be  vacated 
 and  remanded.  USTA  v.  FCC,  290  F.  3d  415,  429.  The  court  also  stated  that  it  grant[  ed]  the  petitions  for  review[]  and  remand[  ed]  the  Line  Sharing  Order  .  .  .  to  the  Commission  for  further  consideration  in  accordance  with  the 


 principles  outlined.  Id.  at  430.  We  are  addressing  the  line  sharing  rules  as  part  of  our  Triennial  Review  Proceeding.  See  Triennial  Review  Notice,  16  FCC  Rcd  at  22805,  paras.  53-  54. 


 966  BellSouth  Milner  Aff.  at  para.  114. 
 967  See  para.  233,  supra. 
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 Mississippi  and  South  Carolina  fail  to  provide  nondiscriminatory  access  to  the  high  frequency  portion  of  the  loop. 
 249.  BellSouth  has  generally  met  the  benchmark  and  parity  standards  for  installation  timeliness,  968  installation  quality,  969  and  maintenance  and  repair  quality  for  line  sharing  in  the 
 other  relevant  states.  970  Because  BellSouths  performance  data  show  that  it  installs  line-  sharing  arrangements  in  accordance  with  the  standards  approved  by  the  state  commissions,  971  we  reject 
 Covads  reliance  on  BellSouths  alleged  failure  to  provision  line-  sharing  arrangements  within  the  time  frame  specified  in  its  interconnection  agreement  with  Covad.  972  Given  that  BellSouths 


 968  See  Alabama/  Kentucky/  North  Carolina  B.  1.9.7-  B.  1.13.7  (Firm  Order  Confirmation,  Line  Sharing); 
 Alabama/  Kentucky/  North  Carolina  B.  2.1.7.3.1-  B.  2.7.5.2  (Order  Completion  Interval,  Line  Sharing);  see  also  Georgia  B.  2.1.7.3.1-  B.  2.1.7.5.2  (Order  Completion  Interval,  Line  Sharing);  Georgia  B.  2.1.7.3.1-  B.  2.1.7.5.2  (Order 


 Completion  Interval,  Line  Sharing);  Alabama/  Kentucky/  North  Carolina/  Georgia  B.  2.18.7.1.1-  B.  2.18.7.2.2  (%  Missed  Installation  Appointments,  Line  Sharing). 


 969  See  Alabama/  Kentucky/  North  Carolina/  Georgia  B.  2.19.7.1.2-  B.  2.19.7.2.1  (%  Provisioning  Troubles  within  30 
 Days,  Line  Sharing);  Alabama/  Kentucky/  North  Carolina/  Georgia  B.  3.2.7.1-  B.  3.2.7.2  (Customer  Trouble  Report  Rate,  Line  Sharing). 


 970  See  Alabama/  Kentucky/  North  Carolina/  Georgia  B.  3.1.7.1-  B.  3.1.7.2  (%  Missed  Repair  Appointments,  Line 
 Sharing);  Alabama/  Kentucky/  North  Carolina/  Georgia  B.  3.3.7.1-  B.  3.3.7.2  (Maintenance  Average  Duration,  Line  Sharing);  Alabama/  Kentucky/  North  Carolina/  Georgia  B.  3.4.7.1-  B.  3.4.7.2  (%  Repeat  Troubles  within  30  Days,  Line 


 Sharing).  While  Covad  complains  that  BellSouth  took  longer  to  perform  line-  sharing  maintenance  for  competitive  LECs  than  for  its  own  retail  operations,  BellSouths  performance  under  the  metrics  for  maintenance  average 
 duration  is  generally  in  parity,  with  very  low  volumes,  in  Alabama,  Kentucky,  and  North  Carolina  from  March  through  June.  Covad  Comments  at  29-  30;  see  Alabama  B.  3.3.7.1-  B.  3.3.7.2  (Maintenance  Average  Duration,  Line 
 Sharing)  (parity  in  all  four  months  for  both  dispatch  and  non-  dispatch);  Kentucky  B.  3.3.7.1-  B.  3.3.7.2  (Maintenance  Average  Duration,  Line  Sharing)  (parity  in  all  four  months  for  both  dispatch  and  in  three  months  for  non-  dispatch); 
 North  Carolina  B.  3.3.7.1-  B.  3.3.7.2  (Maintenance  Average  Duration,  Line  Sharing)  (parity  in  all  four  months  for  both  dispatch  and  non-  dispatch). 


 971  See  Alabama/  Kentucky/  North  Carolina  B.  2.1.7.3.1-  B.  2.1.7.3.2  (Order  Completion  Interval,  Line  Sharing/<  6 
 Circuits).  We  note  that  BellSouths  order  completion  interval  performance  was  out  of  parity  during  June  in  Alabama,  Kentucky,  and  North  Carolina,  and  during  much  of  the  relevant  period  in  Georgia.  See 


 Alabama/  Kentucky/  North  Carolina  B.  2.1.7.3.2  (Order  Completion  Interval,  Line  Sharing/<  6  Circuits/  Non-Dispatch)  (average  June  intervals  of  4.  00  for  competitive  LECs  and  2.  43  days  for  BellSouths  retail  operations  in 
 Alabama,  3.  85  days  for  competitive  LECs  and  2.  46  days  for  BellSouths  retail  operations  in  Kentucky,  and  3.  63  days  for  competitive  LECs  and  2.  39  days  for  BellSouths  retail  operations  in  North  Carolina);  Georgia  B.  2.  1.  7.  3.  1-B. 
 2.1.7.5.2  (Order  Completion  Interval,  Line  Sharing)  (average  monthly  intervals  ranging  from  3.88  days  to  5.96  days  for  competitive  LECs  and  2.  39  days  to  4.  07  days  for  BellSouths  retail  operations).  The  data  indicate, 
 however,  that,  on  average  during  the  applicable  period,  BellSouths  order  completion  intervals  were  0.49  days  shorter  in  Alabama,  0.46  days  longer  in  Kentucky,  0.15  days  shorter  in  North  Carolina,  and  0.66  days  longer  in 
 Georgia  for  competitive  LECs  than  for  BellSouths  retail  operations.  Alabama/  Kentucky/  North  Carolina/  Georgia  B.  2.1.7.3.1-  B.  2.1.7.3.2  (Order  Completion  Interval,  Line  Sharing/<  6  Circuits).  We  find  these  differences  to  be 
 competitively  insignificant. 
 972  See  Covad  Comments  at  22-  23,  27  (asserting  that  BellSouths  failure  to  provision  line-  sharing  arrangements 
 within  the  three-  day  time  frame  specified  in  the  interconnection  agreement  adversely  affects  Covads  ability  to  serve  its  customers  with  the  speed  and  efficiency  they  expect). 
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 line-  sharing  provisioning  intervals  for  its  retail  customers  and  competitive  LECs  are  comparable,  and  recognizing  BellSouths  timeliness  performance  during  the  relevant  period  in  Georgia,  we 
 find  that  BellSouths  installation  performance  does  not  warrant  a  finding  of  checklist  noncompliance.  973  We  do  not,  however,  exclude  the  possibility  that  Covad  might  prevail  in  the 
 event  it  chose  to  pursue  this  as  a  dispute  under  its  agreement  with  BellSouth. 
 250.  We  also  reject  Covads  claim  that  BellSouths  line-  sharing  provisioning  and  maintenance  and  repair  performance  precludes  a  grant  of  long  distance  authority.  974  Although 


 BellSouths  performance  with  regard  to  certain  measures    customer  trouble  reports  within  30  days  of  installation  and  repeat  trouble  reports  within  30  days  of  maintenance  or  repair    is  out  of 
 parity  in  certain  months,  975  we  find  these  disparities  in  reported  performance  do  not  warrant  a  finding  of  checklist  noncompliance.  First,  as  BellSouth  argues,  certain  disparities  reflect  only  a 
 few  trouble  reports.  976  Second,  because  only  a  small  percentage  of  the  line-  sharing  arrangements  provided  by  BellSouth  resulted  in  initial  trouble  reports,  the  total  volume  of  repeat  troubles  is  too 


 973  We  note  that  Covad  provides  no  data  regarding  the  provisioning  intervals  for  the  line-  shared  loops  it  obtains 
 from  BellSouth.  See  Covad  Comments  at  27  (alleging  line-  sharing  provisioning  intervals  of  3.88  days  in  Alabama,  4.07  days  in  Kentucky,  and  3.78  days  in  North  Carolina).  In  any  event,  this  proceeding  is  not  the  proper  forum  for 


 redressing  any  interconnection  agreement  violations  by  BellSouth.  Covad  may  seek  enforcement  of  its  interconnection  agreement  by  the  state  commissions. 


 974  Covad  Comments  at  27-  29. 
 975  Alabama  B.  2.19.7.1.2  (%  Provisioning  Troubles  within  30  days,  Line  Sharing/<  10  Circuits/  Non-  Dispatch) 
 (out  of  parity  during  three  months  with  an  average  trouble  rate  of  8.43%  for  competitive  LECs  and  1.95%  for  BellSouths  retail  operations);  North  Carolina  B.  2.19.7.1.2  (%  Provisioning  Troubles  within  30  days,  Line 


 Sharing/<  10  Circuits/  Non-  Dispatch)  (out  of  parity  throughout  relevant  period  with  an  average  trouble  rate  of  20.  62%  for  competitive  LECs  and  2.  38%  for  BellSouths  retail  operations);  Georgia  B.  2.  19.  7.  1.  1-  B.  2.  19.  7.  1.  2  (% 
 Provisioning  Troubles  within  30  days,  Line  Sharing/<  10  Circuits)  (out  of  parity  throughout  relevant  period  with  trouble  rates  ranging  from  11.30%  to  39.42%  for  competitive  LECs  and  from  2.06%  to  5.27%  for  BellSouth);  North 
 Carolina  B.  3.4.7.2  (%  Repeat  Troubles  within  30  Days,  Line  Sharing/  Non-  Dispatch)  (out  of  parity  in  April  and  June  with  overall  repeat  trouble  rates  of  36.00%  for  competitive  LECs  and  22.19%  for  BellSouths  retail  operations 
 during  March  through  June);  Georgia  B.  3.4.7.1  (%  Repeat  Troubles  within  30  Days,  Line  Sharing/  Dispatch)  (out  of  parity  in  March,  May,  and  June  with  overall  repeat  trouble  rates  of  47.22%  for  competitive  LECs  and  26.94%  for 
 BellSouths  retail  operations  during  March  through  June);  Georgia  B.  3.4.7.2  (%  Repeat  Troubles  within  30  Days,  Line  Sharing/  Non-  Dispatch)  (out  of  parity  in  June  with  overall  repeat  trouble  rates  of  29.91%  for  competitive  LECs 
 and  26.04%  for  BellSouths  retail  operations  during  March  through  June). 
 976  BellSouth  Varner  Reply  Aff.  at  para.  121  (citing  confidential  data);  id.  at  para.  227;  Letter  from  Kathleen  B. 
 Levitz,  Vice  President    Federal  Regulatory,  BellSouth,  to  Marlene  H.  Dortch,  Secretary,  Federal  Communications  Commission,  WC  Docket  No.  02-  150  (filed  Sept.  6,  2002)  (BellSouth  September  6  Ex  Parte  Letter);  Alabama 


 B.  2.19.7.1.1  (%  Provisioning  Troubles  within  30  days,  Line  Sharing/<  10  Circuits/  Dispatch)  (out  of  parity  during  March  and  April  with  monthly  volumes  of  seven  for  competitive  LECs);  North  Carolina  B.  2.  19.  7.  1.  1  (% 
 Provisioning  Troubles  within  30  days,  Line  Sharing/<  10  Circuits/  Dispatch)  (out  of  parity  during  March  with  volume  of  five  for  competitive  LECs);  Kentucky  B.  2.19.7.1.2  (%  Provisioning  Troubles  within  30  days,  Line 
 Sharing/<  10  Circuits/  Non-  Dispatch)  (out  of  parity  during  April,  May,  and  June  with  respective  monthly  volumes  of  three,  four,  and  three  for  competitive  LECs). 
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 small  to  yield  statistically  significant  results.  977  BellSouth  generally  performed  at  or  above  parity  with  regard  to  line-  sharing  maintenance,  as  measured  by  its  trouble  report  rate  for  line-  sharing 
 arrangements,  during  the  relevant  period.  978  In  these  circumstances,  we  conclude  that  BellSouths  customer  trouble  report  and  repeat  trouble  report  rates  for  line  sharing  do  not 
 support  a  finding  of  checklist  noncompliance. 
 251.  Line  Splitting.  We  find  that  BellSouth  also  provides  nondiscriminatory  access  to  line  splitting  in  accordance  with  our  rules.  979  BellSouth  states  that  it  facilitates  line  splitting  by 


 cross  connecting  an  unbundled  loop  to  a  competitive  LECs  collocation  space.  Moreover,  BellSouth  implemented  permanent  OSS  for  line  splitting  on  January  5,  2002,  and  competitive 
 LECs  have  raised  no  complaints  about  this  process.  980 


 977  Kentucky  B.  3.2.7.2  (%  Repeat  Troubles  within  30  Days,  Line  Sharing/  Dispatch)  (out  of  parity  in  May  with 
 two  repeat  troubles);  North  Carolina  B.  3.4.7.2  (%  Repeat  Troubles  within  30  Days,  Line  Sharing/  Non-  Dispatch)  (out  of  parity  in  April  with  four  repeat  troubles  and  in  June  with  three  repeat  troubles);  Georgia  B.  3.4.7.1  (%  Repeat 


 Troubles  within  30  Days,  Line  Sharing/  Dispatch)  (out  of  parity  in  four  months  with  repeat  trouble  counts  ranging  from  three  to  16). 


 978  See,  e.  g.,  Alabama  B.  3.2.7.1  (Customer  Trouble  Report  Rate,  Line  Sharing/  Dispatch)  (overall  trouble  report 
 rates  of  20.  00%  for  competitive  LECs  and  50.  57%  for  BellSouth  for  dispatch  orders);  Alabama  B.  3.  2.  7.  2  (Customer  Trouble  Report  Rate,  Line  Sharing/  Non-  Dispatch)  (overall  trouble  report  rates  of  3.70%  for  competitive  LECs  and 


 3.49%  for  BellSouth  for  non-  dispatch  orders);  Kentucky  B.  3.2.7.1  (Customer  Trouble  Report  Rate,  Line  Sharing/  Dispatch)  (overall  trouble  report  rates  of  0.32%  for  competitive  LECs  and  1.24%  for  BellSouth  for  dispatch 
 orders);  Kentucky  B.  3.2.7.2  (Customer  Trouble  Report  Rate,  Line  Sharing/  Non-  Dispatch)  (overall  trouble  report  rates  of  1.41%  for  competitive  LECs  and  2.03%  for  BellSouth  for  non-  dispatch  orders);  North  Carolina  B.  3.2.7.1 
 (Customer  Trouble  Report  Rate,  Line  Sharing/  Dispatch)  (overall  trouble  report  rates  of  0.18%  for  competitive  LECs  and  0.81%  for  BellSouth  for  dispatch  orders);  North  Carolina  B.  3.2.7.2  (Customer  Trouble  Report  Rate,  Line 
 Sharing/  Non-  Dispatch)  (overall  trouble  report  rates  of  1.32%  for  competitive  LECs  and  1.61%  for  BellSouth  for  non-  dispatch  orders);  Georgia  B.  3.2.7.1  (Customer  Trouble  Report  Rate,  Line  Sharing/  Dispatch)  (overall  trouble 
 report  rates  of  0.  78%  for  competitive  LECs  and  1.  17%  for  BellSouth  for  dispatch  orders);  Georgia  B.  3.  2.  7.  2  (Customer  Trouble  Report  Rate,  Line  Sharing/  Non-  Dispatch)  (overall  trouble  report  rates  of  2.58%  for  competitive 
 LECs  and  2.85%  for  BellSouth  for  non-  dispatch  orders). 
 979  See  Line  Sharing  Reconsideration  Order,  16  FCC  Rcd  at  2111,  para.  20  n.  36. 


 980  See  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9157,  para.  243. 
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 C.  Checklist  Item  5    Unbundled  Transport 
 252.  Section  271(  c)(  2)(  B)(  v)  of  the  competitive  checklist  requires  a  BOC  to  provide  [  l]  ocal  transport  from  the  trunk  side  of  a  wireline  local  exchange  carrier  switch  unbundled  from 


 switching  or  other  services.  981  Based  on  the  evidence  in  the  record,  we  conclude,  as  did  the  state  commissions,  982  that  BellSouth  complies  with  the  requirements  of  checklist  item  5.  983 


 253.  The  Commission  has  previously  relied  on  the  missed  installation  appointment  rate  to  determine  whether  a  BOC  is  provisioning  transport  to  its  competitors  in  a  nondiscriminatory 
 manner.  984  Despite  the  low  transport  order  volume  for  competitive  LECs  in  each  of  the  five  states,  BellSouths  performance  data  show  that  it  missed  installation  appointments  for 
 provisioning  transport  at  a  lower  rate  for  its  competitors  than  for  its  own  retail  customers  during  the  relevant  period.  985  Given  this  evidence,  and  recognizing  BellSouths  parity  performance  in 
 Georgia,  we  conclude  that  BellSouths  provisioning  of  transport  to  competitive  LECs  is  nondiscriminatory.  986 


 254.  We  note  that  US  LEC  alleges  that  the  current  rules  regarding  loop-  transport  combinations,  EELs,  have  impeded  US  LECs  ability  to  compete  with  BellSouth  in  violation  of 
 checklist  item  5.  987  New  South  also  claims  that  BellSouth  does  not  comply  with  the  Commissions  orders  regarding  EELs  audits  and  contends  that  it  has  experienced  delays  in  the 
 conversion  of  special  access  circuits  to  EELs.  988  We  address  these  claims  in  our  discussion  of  checklist  item  2,  above.  989 


 981  47  U.  S.  C.    271(  c)(  2)(  B)(  v). 
 982  Alabama  Commission  Comments  at  213-  15;  Mississippi  Commission  Comments  at  3;  Kentucky  Commission 
 Comments  at  33;  North  Carolina  Commission  Comments  at  209;  South  Carolina  Commission  Comments  at  1. 
 983  BellSouth  Application  at  117-  18;  BellSouth  Milner  Aff.  at  paras.  137-  45. 


 984  See,  e.  g.,  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9158,  para.  246;  Verizon  Massachusetts  Order, 
 16  FCC  Rcd  at  9106-  07,  para.  210. 
 985  See  B.  2.18.2.1.1  (%  Missed  Installation  Appointments,  Local  Interoffice  Transport/<  10  Circuits/  Dispatch). 
 We  note  that,  during  the  months  with  reported  competitive  LEC  data,  BellSouth  achieved  parity  in  Alabama  (June),  Kentucky  (April,  May,  and  June),  Mississippi  (April,  May,  and  June),  and  North  Carolina  (March,  April,  May,  and 


 June).  See  Alabama/  Kentucky/  Mississippi/  North  Carolina  B.  2.18.2.1.1  (%  Missed  Installation  Appointments,  Local  Interoffice  Transport/<  10  Circuits/  Dispatch). 


 986  Because  order  volumes  for  transport  were  nonexistent  or  low  in  the  five  states  during  the  relevant  period,  we 
 look  to  Georgia  data  to  inform  our  analysis.  See  Georgia  B.  2.18.2.1.1  (%  Missed  Installation  Appointments,  Local  Interoffice  Transport/<  10  Circuits/  Dispatch). 


 987  US  LEC  Comments  at  7-  19;  US  LEC  Reply  at  4-  5. 
 988  New  South  August  5  Ex  Parte  Letter  at  6. 
 989  See  section  IV.  B.  3,  supra. 
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 D.  Checklist  Item  8    White  Pages  Directory  Listings 
 255.  Section  271(  c)(  2)(  B)(  viii)  of  the  competitive  checklist  requires  a  BOC  to  provide  [  w]  hite  page  directory  listings  for  customers  of  the  other  carriers  telephone  exchange 


 service.  990  Based  on  the  record  in  this  proceeding,  we  conclude,  as  did  the  state  commissions,  991  that  BellSouth  satisfies  the  requirements  of  checklist  item  8.  992 


 256.  We  note  that  Birch  alleges  that  competitive  LECs  were  not  properly  notified  of  a  change  to  BAPCOs  systems  to  fix  a  partial  directory  listing  deficiency,  which  resulted  in 
 telephone  numbers  of  Birchs  end  users  being  omitted  from  BAPCOs  telephone  book.  993  This  issue  is  addressed  in  the  change  management  discussion  in  checklist  item  2,  above.  994 


 E.  Checklist  Item  10    Databases  and  Associated  Signaling 
 257.  Section  271(  c)(  2)(  B)(  x)  of  the  competitive  checklist  requires  a  BOC  to  provide  nondiscriminatory  access  to  databases  and  associated  signaling  necessary  for  call  routing  and 


 completion.  995  Based  on  the  evidence  in  the  record,  we  conclude  that  BellSouth  satisfies  the  requirements  of  checklist  item  10. 


 258.  US  LEC  contends  that  BellSouths  Signaling  System  7  (SS7)  tariff  revisions  in  Mississippi  and  North  Carolina  are  discriminatory.  US  LEC  alleges,  for  example,  that  these 
 tariff  revisions  impose  per-  message  charges  on  every  call  regardless  of  whether  the  call 


 990  47  U.  S.  C.    271(  c)(  2)(  B)(  viii).  Section  251(  b)(  3)  of  the  1996  Act  obligates  all  LECs  to  permit  competitive 
 providers  of  telephone  exchange  service  and  telephone  toll  service  to  have  nondiscriminatory  access  to  directory  listings.  47  U.  S.  C.    251(  b)(  3). 


 991  Alabama  Commission  Comments  at  228;  Kentucky  Commission  Comments  at  35;  Mississippi  Commission 
 Comments  at  3;  North  Carolina  Commission  Comments  at  227;  South  Carolina  Commission  Comments  at  1. 
 992  BellSouth  states  that  it  offers  white  page  listings  to  competitive  LECs  at  no  extra  charge,  integrates  their 
 listings  with  the  listings  for  BellSouths  own  retail  customers,  publishes  the  entries  in  the  same  font  and  character  size,  uses  the  same  procedures  to  process  listings,  and  provides  the  same  accuracy  and  reliability.  BellSouth 


 Application  at  122;  BellSouth  Milner  Aff.  at  para.  205  &  Exh.  WKN-  14. 
 993  Birch  Comments  at  20-  25.  We  also  note  that  AT&  T  questions  the  reliability  of  BellSouths  percent  update 
 accuracy  metric,  which  measures  whether  BellSouth  accurately  updates  its  directory  listing  database,  because  BellSouth,  contrary  to  its  own  business  rules,  excludes  Directory  Listing  only  service  orders  from  the  samples 


 drawn.  AT&  T  Bursh/  Norris  Decl.  at  paras.  51-  52;  see  also  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  F.  13.2  (%  Update  Accuracy).  In  response,  BellSouth  states  that  these  orders  have  always  been  excluded 
 based  on  its  understanding  of  the  Commissions  requirements  implementing  the  SQM.  BellSouth  Varner  Reply  Aff.  at  para.  47.  BellSouth  further  adds  that  it  advised  AT&  T  that  it  would  include  the  less  complex  orders  in  the 
 measure,  which  may  slightly  improve  the  accuracy.  Id.  Thus,  we  do  not  find  that  AT&  Ts  reliability  claim  rises  to  the  level  of  checklist  noncompliance. 


 994  See  section  IV.  B.  2.  g,  supra. 
 995  47  U.  S.  C.    271(  c)(  2)(  B)(  x). 
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 originates  on  BellSouths  network  or  on  a  competitive  LECs  network.  996  We  reject  US  LECs  claims,  as  did  the  state  commissions.  997 
 259.  BellSouth  asserts,  and  we  agree,  that  the  issues  raised  by  US  LEC  pertain  to  the  manner  in  which  competitive  LECs  obtain  service  under  intrastate  access  tariffs  and  are  not 
 relevant  to  the  question  of  whether  BellSouth  provides  nondiscriminatory  access  to  databases  and  signaling  for  compliance  with  checklist  item  10.  998  BellSouth  also  states  that  [  r]  ates, 
 terms[,]  and  conditions  for  a  CLECs  use  of  BellSouths  CCS7  service  in  relation  to  local  calls  is  governed  by  the  CLECs  (e.  g.,  US  LEC)  approved  interconnection  agreement  with  BellSouth.  999 
 Because  US  LEC  limits  its  allegations  to  purported  tariff  revisions  and  makes  no  allegations  concerning  discriminatory  SS7  charges  in  any  interconnection  agreement  with  BellSouth,  we  do 
 not  find  that  US  LECs  allegations,  even  if  true,  state  a  violation  of  checklist  item  10.  1000  US  LECs  specific  concerns  regarding  the  intrastate  access  tariffs  revisions  are  more  appropriately 
 addressed  by  the  state  commissions  using  established  procedures  to  challenge  and  review  tariff  filings.  1001 


 260.  BellSouth  provides  persuasive  evidence  that  it  provides  access  to  its  signaling  networks  in  a  nondiscriminatory  manner.  1002  We  therefore  find  that  BellSouth  complies  with 
 checklist  item  10. 
 F.  Checklist  Item  11    Number  Portability 
 261.  Section  271(  c)(  2)(  B)(  xi)  of  the  Act  requires  a  BOC  to  comply  with  the  number  portability  regulations  adopted  by  the  Commission  pursuant  to  section  251.  1003  Section  251(  b)(  2) 


 996  US  LEC  Comments  at  3-  4. 
 997  Alabama  Commission  Comments  at  231;  Kentucky  Commission  Comments  at  37;  Mississippi  Commission 
 Comments  at  3;  North  Carolina  Commission  Comments  at  233;  South  Carolina  Commission  Comments  at  1. 
 998  BellSouth  Ruscilli/  Cox  Reply  Aff.  at  para.  45;  see  also  BellSouth  Reply  at  35  &  n.  8  (citing  Bell  Atlantic  New 
 York  Order  15  FCC  Rcd  at  4126,  para.  340  (  We  do  not  believe  that  checklist  compliance  is  intended  to  encompass  the  provision  of  tariffed  interstate  access  services  simply  because  these  services  use  some  of  the  same  physical 


 facilities  as  a  checklist  item.)). 
 999  BellSouth  Ruscilli/  Cox  Reply  Aff.  at  para.  45. 


 1000  US  LEC  Comments  at  2-  7.  As  long  as  BellSouth  offers  signaling  pursuant  to  a  state-  approved  interconnection 
 agreement,  section  252(  i)  of  the  Act  makes  such  terms  and  conditions  available  to  all  requesting  carriers,  thus  satisfying  BellSouths  obligation  pursuant  to  checklist  item  10.  See  SWBT  Texas  Order,  15  FCC  Rcd  at  18390, 


 para.  78  &  n.  175.  Whether  signaling  is  also  available  under  a  BellSouth  tariff  is  not  relevant  to  checklist  compliance. 


 1001  BellSouth  notes  that  the  Mississippi  Commission  approved  the  intrastate  access  tariff  revisions  while  the 
 tariff  filings  in  North  Carolina  are  pending  review  by  the  North  Carolina  Commission.  BellSouth  Ruscilli/  Cox  Reply  Aff.  at  para.  46. 


 1002  BellSouth  Milner  Aff.  at  paras.  217-  22. 
 1003  47  U.  S.  C.    271(  c)(  2)(  B)(  xi). 
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 requires  all  LECs  to  provide,  to  the  extent  technically  feasible,  number  portability  in  accordance  with  requirements  prescribed  by  the  Commission.  1004  Based  on  the  evidence  in  the 
 record,  we  find,  as  did  the  state  commissions,  1005  that  BellSouth  complies  with  the  requirements  of  checklist  item  11. 


 262.  US  LEC  raises  issues  concerning  BellSouths  compliance  with  its  number  portability  obligations,  none  of  which  demonstrates  that  BellSouth  fails  to  comply  with  the 
 requirements  of  checklist  item  11.  For  example,  US  LEC  states  that  when  a  customer  ports  fewer  than  all  of  its  lines  from  BellSouth,  BellSouth  will  continue  to  bill  that  customer  for  the 
 lines  it  has  ported  from  BellSouth,  thus  causing  the  customer  to  be  double  billed  for  those  lines.  1006  US  LEC  claims  that  this  problem  occurs  most  frequently  when  a  customer  retains 
 BellSouths  alarm  monitoring  service.  1007  BellSouth  explains  that  it  has  worked  with  state  collaboratives  to  investigate  and  resolve  any  double  billing  problem  attributable  to  BellSouth.  1008 
 While  we  do  not  discount  the  potential  inconvenience  that  competitive  LECs  and  customers  experience  as  a  result  of  BellSouths  erroneous  billing,  we  find  that  BellSouth  has  demonstrated 
 that  it  has  put  sufficient  processes  in  place  to  address  double  billing  disputes.  Moreover,  we  agree  with  the  Alabama  and  North  Carolina  Commissions  that  evidence  of  duplicate  billing  does 
 not  rise  to  the  level  of  noncompliance.  1009  Further,  although  not  decisional  to  our  analysis,  BellSouth  states  that  it  now  has  the  capability  to  convert  a  customer  from  BellSouth  to  a 
 competitive  LEC  using  a  single  service  order  which  minimizes  the  risk  that  the  order  to  discontinue  billing  the  end  user  will  be  delayed,  and  the  customer  mistakenly  billed  by  BellSouth 
 after  the  customer  has  migrated  to  a  competitive  LEC.  1010  Accordingly,  we  do  not  find  that  this  claim  warrants  a  finding  of  checklist  noncompliance.  Should  BellSouths  performance  in  this 
 area  deteriorate,  we  will  pursue  appropriate  enforcement  action. 
 263.  We  also  reject  US  LECs  claim  that  BellSouth  fails  checklist  item  11  because  BellSouth  frequently  ports  telephone  numbers  prior  to  the  facility  change  due  date,  an  error  that 


 often  results  in  competitive  LEC  customers  losing  telephone  service.  1011  As  a  result,  US  LEC  must  wait  until  BellSouth  achieves  its  facility  due  date  before  entering  the  LSR.  1012  According  to 


 1004  47  U.  S.  C.    251(  b)(  2). 
 1005  Alabama  Commission  Comments  at  238;  Kentucky  Commission  Comments  at  38;  Mississippi  Commission 
 Comments  at  3;  North  Carolina  Commission  Comments  at  240;  South  Carolina  Commission  Comments  at  1. 
 1006  US  LEC  Comments  at  20. 


 1007  Id. 
 1008  BellSouth  Scollard  Aff.  at  para.  24. 
 1009  Alabama  Commission  Comments  at  231-  39;  North  Carolina  Commission  Comments  at  233-  40. 
 1010  BellSouth  Scollard  Aff.  at  para.  24.  All  of  the  states  in  the  BellSouth  region  have  the  new  Single  C 
 ordering  process  which  should  minimize  the  risk  of  double  billing.  Id. 
 1011  US  LEC  Comments  at  21. 


 1012  Id. 
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 US  LEC,  the  facility  might  sit  idle  for  some  period  of  time  unused  by  the  customer  and  paid  for  by  US  LEC.  1013  US  LEC  also  contends  that,  in  a  number  of  instances,  despite  timely  notification 
 that  a  customer  has  postponed  its  loop  cutover  request,  BellSouth  will  disconnect  the  line  prematurely,  resulting  in  a  loss  of  service.  1014  BellSouth,  however,  states  that  for  the  vast 
 majority  of  its  orders,  the  Local  Number  Portability  (LNP)  Gateway  System  automatically  issues  a  trigger  order  with  a  zero  due  date,  which  does  not  require  manual  intervention,  and  meets  or 
 exceeds  any  national  standards  for  number  portability.  1015  For  instance,  BellSouth  states  that  92  percent  of  all  LNP  gateway  orders  were  processed  mechanically  in  June  2002.  1016  BellSouth  also 
 adds  that  the  LNP  Gateway  System  will  directly  transmit  the  remaining  complex  LSR  orders,  which  require  manual  intervention,  to  specific  BellSouth  representatives  for  the  issuance  of  the 
 trigger  order.  1017  Given  BellSouths  evidence  of  its  compliance  and  the  relatively  small  number  of  occurrences  cited  by  BellSouth,  we  conclude  that  US  LECs  allegations,  even  if  true,  do  not 
 indicate  a  systemic  failure  in  BellSouths  provision  of  number  portability  and,  therefore,  do  not  undermine  our  overall  finding  of  BellSouths  compliance  with  checklist  item  11.  1018  Should 
 BellSouths  performance  in  this  area  deteriorate,  we  will  pursue  appropriate  enforcement  action. 
 264.  Finally,  US  LEC  challenges  BellSouths  practice  of  requiring  US  LEC  to  pay  new  hourly  surcharges  for  any  coordinated  LNP  cuts  that  occur  between  5:  00  PM  and  8:  00 


 AM,  1019  a  practice  that  is  said  not  to  appear  on  any  interconnection  agreement  and  that  US  LEC  deems  unlawful.  1020  BellSouth  explains  that  the  charges  to  which  US  LEC  refers  are  for  Project 
 Management  Coordination  service  for  after  hours  cuts,  or  provisioning  of  LNP  cuts  outside  the  normal  8:  00  AM  to  5:  00  PM  workday.  1021  The  charges  cover  the  labor  costs  that  BellSouth 


 1013  Id. 
 1014  Id.  at  20-  21. 
 1015  BellSouth  Milner  Reply  Aff.  at  para.  20. 
 1016  BellSouth  August  14  OSS  and  Loops  Ex  Parte  Letter. 
 1017  BellSouth  Milner  Reply  Aff.  at  para.  20.  For  complex  orders,  the  LNP  gateway  transmits  the  LSR  to 
 BellSouths  Local  Carrier  Service  Center  to  issue  the  trigger  order.  Id. 
 1018  AT&  T  also  raises  several  data  reliability  issues  with  respect  to  LNP  orders,  none  of  which  rise  to  the  level  of 
 checklist  noncompliance.  AT&  T  Bursh/  Norris  Decl.  at  paras.  26-  38,  42,  46;  AT&  T  Bursh/  Norris  Reply  Decl.  at  paras.  10-  22;  AT&  T  August  23  OSS  and  Data  Integrity  Ex  Parte  Letter  at  6.  BellSouth  acknowledges,  for  instance, 


 665  of  the  issued  service  orders  in  the  March  2002  LNP  LSR  flow-  through  report  should  have  been  classified  as  fully  mechanized  instead  of  partially  mechanized  in  the  March  LNP  FOC  timeliness  raw  data.  BellSouth 
 Varner  Reply  Aff.  at  paras.  34-  35.  BellSouth,  however,  notes  that  steps  have  been  taken  to  remedy  this  and  other  LNP  processing  errors  and  each  of  AT&  Ts  issues  has  either  been  resolved  or  the  required  fix  is  scheduled.  Id.  at 
 35-  37,  43-  45;  BellSouth  August  30  Ex  Parte  Letter  at  4.  Given  that  BellSouth  has  responded  to  AT&  Ts  claims,  implemented  changes,  and  no  other  commenter  raised  the  same  issues,  we  find  that  BellSouth  complies  with  this 
 checklist  item. 
 1019  US  LEC  Comments  at  21. 


 1020  Id.  at  22. 
 1021  BellSouth  Ruscilli/  Cox  Aff.  at  para.  42. 
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 incurs  in  holding  employees  (or  calling  out  employees)  beyond  normal  business  hours  in  order  to  provide  dedicated  project  management  to  a  competitive  LEC  during  the  term  of  the  cut.  1022 
 BellSouth  points  out  that,  contrary  to  US  LECs  claims,  these  charges  are  in  fact  covered  by  the  interconnection  agreement.  1023  Attachment  6,  Section  1.2  of  a  US  LEC  interconnection 
 agreement  states  that  [  a]  ll  other  US  LEC  requests  for  provisioning  and  installation  services  are  considered  outside  of  the  normal  hours  of  operation  and  may  be  performed  subject  to  the 
 application  of  extra-  ordinary  billing  charges.  1024  US  LEC  does  not  refute  BellSouths  response.  Thus,  to  the  extent  US  LEC  deems  such  charges  unlawful,  it  may  seek  relief  from  the  state 
 commissions,  which  are  charged  with  interpreting  interconnection  agreements  in  the  first  instance. 


 265.  BellSouth  also  states  that,  because  of  the  confusing  nature  of  the  Carrier  Notification  concerning  recovery  of  after  hours  LNP  charges,  1025  it  is  currently  waiving  the 
 project  management  charges.  1026  BellSouth  states  that  it  has  not  charged  any  carrier,  and  will  not  charge  for  any  after  hours  coordination  performed  this  far.  1027  Until  BellSouth  completes  its 
 re-  evaluation  of  these  charges,  BellSouth  states  that  it  will  continue  to  waive  its  right  to  recover  these  charges  but  will  continue  to  perform  after  hours  coordinated  LNP  conversions.  1028  If  and 
 when  BellSouth  lifts  the  waiver  and  begins  imposing  the  disputed  charges,  US  LEC  and  any  other  affected  carriers  may  bring  any  challenges  before  the  relevant  state  commissions. 


 266.  For  the  foregoing  reasons,  we  reject  US  LECs  claims  that  BellSouth  does  not  comply  with  the  Commissions  number  portability  requirements.  We  therefore  conclude  that 
 BellSouth  satisfies  checklist  item  11. 
 G.  Checklist  Item  12    Local  Dialing  Parity 
 267.  Section  271(  c)(  2)(  B)(  xii)  requires  [  n]  ondiscriminatory  access  to  such  services  or  information  as  are  necessary  to  allow  the  requesting  carrier  to  implement  local  dialing  parity  in 


 accordance  with  the  requirements  of  section  251(  b)(  3).  1029  Based  on  the  evidence  in  the  record, 


 1022  Id. 
 1023  Id. 
 1024  Id. 
 1025  Id.  (stating  that,  by  Carrier  Notification  dated  January  16,  2002,  BellSouth  described  its  intent  to  begin 
 recovery  of  these  costs  on  a  trial  basis). 
 1026  Id.  at  para.  43. 


 1027  Id. 
 1028  Id. 
 1029  47  U.  S.  C.    271(  c)(  2)(  B)(  xii). 
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 we  find,  as  did  the  state  commissions,  1030  that  BellSouth  satisfies  the  requirements  of  checklist  item  12. 
 268.  We  reject  WorldComs  claim  that  BellSouths  misrouting  of  intraLATA  calls  as  local  calls  in  Florida  and  Georgia  rise  to  a  level  of  checklist  noncompliance  in  the  instant 
 application.  WorldCom  claims  that  BellSouths  explanation  that  the  misrouting  of  calls  in  Georgia  was  due  to  a  calling  scope  issue  unique  to  Georgia  (an  explanation  accepted  by  the 
 Commission  in  the  Georgia/  Louisiana  proceeding)  1031  is  inconsistent  with  its  explanation  that  the  identical  problem  in  Florida  is  caused  by  switch  translation  errors.  1032  BellSouth,  however, 
 denies  that  it  violates  this  checklist  item,  and  reiterates  the  explanation  it  gave  to  this  Commission  in  the  Georgia/  Louisiana  proceeding.  1033 


 269.  We  find  WorldComs  assertions  unpersuasive.  BellSouths  alleged  misrouting  of  intraLATA  calls  in  Florida  is  not  relevant  to  a  determination  of  whether  BellSouth  meets 
 checklist  item  12  in  Alabama,  Mississippi,  Kentucky,  North  Carolina,  and  South  Carolina.  1034  For  purposes  of  the  instant  application,  we  consider  only  whether  BellSouth  meets  the 
 requirements  of  section  271  in  the  five  states.  1035  Moreover,  no  other  commenter  has  challenged  BellSouths  provision  of  local  dialing  parity  in  the  five  states,  and  the  state  commissions 
 concluded  that  BellSouth  meets  this  checklist  item.  We  also  believe  that  any  concerns  regarding  the  Georgia  UNE-  P  calling  scope  issue  are  best  resolved  through  the  section  252  negotiation  and 
 arbitration  process  or  through  the  section  208  complaint  process.  Accordingly,  we  do  not  find  that  WorldComs  claim  warrants  a  finding  of  checklist  noncompliance.  Although  not  decisional 


 1030  Alabama  Commission  Comments  at  239;  Kentucky  Commission  Comments  at  39;  Mississippi  Commission 
 Comments  at  3;  North  Carolina  Comments  at  243;  South  Carolina  Comments  at  1. 
 1031  See  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9170-  72,  para.  269.  In  the  Georgia/  Louisiana 
 proceeding,  BellSouth  demonstrated  that  this  problem  was  not  a  systemic  switch  problem.  Id.  at  9171  &  n.  1057.  BellSouth  explained  that  WorldComs  complaint  arose  because,  in  Georgia,  there  is  a  slight  geographic  difference 


 between  flat-  rate  local  calling  areas  and  measured-  rate  local  calling  areas.  Id.  at  9171,  para.  269.  Additionally,  BellSouth  stated  that  because  UNE-  P  is  a  measured-  rate  service,  BellSouth  measures  UNE-  P  switching  based  on  the 
 slightly  larger  measured-  rate  local  calling  area.  Id.  We  accepted  BellSouths  calling  scope  explanation  because  we  found  that  the  dispute  had  a  limited  commercial  impact  and  no  other  competitive  LEC  raised  this  issue.  Id.  at  9172, 
 para.  269. 
 1032  WorldCom  Comments  at  5-  6;  WorldCom  Reply  at  7. 


 1033  BellSouth  Ruscilli/  Cox  Reply  at  para.  82. 
 1034  See  SWBT  Texas  Order,  15  FCC  Rcd  at  18528,  para.  351;  Bell  Atlantic  New  York  Order  15  FCC  Rcd  at  4151, 
 paras.  398-  99  (noting  that  rule  violations  in  other  states  are  not  relevant  to  a  determination  of  whether  Bell  Atlantic  meets  its  section  271  obligations  in  New  York). 


 1035  WorldCom  also  contends  that  BellSouths  OSS  is  inadequate  because,  even  though  BellSouth  plans  to  fix  the 
 Georgia  calling  scope  issue  with  its  10.6  Release  on  August  24,  2002,  BellSouth  is  requiring  WorldCom  for  the  first  time  to  amend  its  interconnection  agreement  to  take  advantage  of  the  change.  WorldCom  Reply  at  1-  2;  WorldCom 


 September  12  Ex  Parte  Letter.  We  believe  that  this  issue  should  be  appropriately  decided  by  the  state  commissions  in  the  first  instance. 
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 to  our  analysis,  we  note  that  BellSouth  addressed  this  calling  scope  issue  in  its  Release  10.6  on  August  24-  25,  2002.  1036 
 H.  Remaining  Checklist  Items  (3,  6,  7,  9,  13,  and  14) 
 270.  In  addition  to  showing  that  it  is  in  compliance  with  the  requirements  discussed  above,  an  applicant  under  section  271  must  demonstrate  that  it  complies  with  checklist  item  3 


 (access  to  poles,  ducts,  and  conduits),  1037  item  6  (unbundled  local  switching),  1038  item  7  (911/  E911  access  and  directory  assistance/  operator  services),  1039  item  9  (numbering 
 administration),  1040  item  13  (reciprocal  compensation),  1041  and  item  14  (resale).  1042  Based  on  the  evidence  in  the  record,  we  conclude  that  BellSouth  demonstrates  that  it  is  in  compliance  with 
 checklist  items  3,  6,  7,  9,  13,  and  14  in  the  five  states.  1043  No  parties  objected  to  BellSouths 


 1036  Parties  contend,  and  BellSouth  acknowledges,  that  Georgia  UNE-  P  orders  were  rejected  soon  after  the 
 implementation  of  Release  10.6.  BellSouth  September  10  Ex  Parte  Letter  at  1-  2;  see  also  AT&  T  September  9  Ex  Parte  Letter  at  1;  WorldCom  September  12  Ex  Parte  Letter  at  1-  3.  BellSouth  explains,  however,  that  the  rejections 


 were  caused  by  the  competitive  LECs  and  any  problems  associated  with  the  processing  of  these  orders  would  be  corrected.  BellSouth  also  states  that  AT&  Ts  UNE-  P  orders  for  Georgia  were  rejected  because  AT&  T  failed  to 
 update  its  interconnection  agreement  to  include  the  new  UNE-  P  calling  scope  USOCs,  AT&  T  did  not  populate  the  LSR  line  class  of  service  field,  and  incorrectly  added  primary  interLATA  carrier  changes  in  this  field  which  was 
 prohibited  by  Release  10.6.  BellSouth  September  10  Ex  Parte  Letter  at  1-  2. 
 1037  47  U.  S.  C.    271(  c)(  2)(  B)(  iii). 


 1038  47  U.  S.  C.    271(  c)(  2)(  B)(  vi). 
 1039  47  U.  S.  C.    271(  c)(  2)(  B)(  vii). 
 1040  47  U.  S.  C.    271(  c)(  2)(  B)(  ix). 
 1041  47  U.  S.  C    271(  c)(  2)(  B)(  xiii). 
 1042  47  U.  S.  C.    271(  c)(  2)(  B)(  xiv).  In  each  of  the  five  states,  BellSouth  generally  met  the  parity  standards  for 
 installation  timeliness  and  missed  installation  appointments.  See  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  A.  2.1.1.1.1-  A.  2.1.6.2.2  (Order  Completion  Interval,  Resale); 


 Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  A.  2.11.1.1.1-  A.  2.11.6.2.2  (%  Missed  Installation  Appointments,  Resale).  Additionally,  as  compared  to  BellSouth  retail  in  the  five  states,  competitors  generally 
 experienced  a  lower  average  of  %  trouble  reports  within  30  days  after  installation  of  a  resale  line.  See  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  A.  2.12.1.1.1-  A.  2.12.6.2.2  (%  Provisioning  Trouble 
 within  30  Days,  Resale).  Moreover,  BellSouth  generally  missed  fewer  repair  appointments  for  competitors.  See  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  A.  3.1.1.1-  A.  3.1.6.2  (Missed  Repair  Appointments, 
 Resale).  Finally,  BellSouths  repeat  trouble  rates  are  generally  in  parity  for  most  months  in  the  five  states.  Alabama/  Kentucky/  Mississippi/  North  Carolina/  South  Carolina  A.  3.4.1.1-  A.  3.4.6.2  (%  Repeat  Troubles  within  30 
 Days,  Resale).  For  a  discussion  of  BellSouths  resale  performance,  see  section  IV.  B.  2,  supra. 
 1043  See  BellSouth  Application  at  100-  01  (checklist  item  3),  118-  20  (checklist  item  6),  120-  22  (checklist  item  7), 
 123-  24  (checklist  item  9),  132-  33  (checklist  item  13),  134-  36  (checklist  item  14). 
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 compliance  with  these  checklist  items.  We  also  note  that  the  state  commissions  concluded  that  BellSouth  complies  with  the  requirements  of  each  of  these  checklist  items.  1044 
 VI.  SECTION  272  COMPLIANCE 
 271.  Section  271(  d)(  3)(  B)  provides  that  the  Commission  shall  not  approve  a  BOCs  application  to  provide  interLATA  services  unless  the  BOC  demonstrates  that  the  requested 


 authorization  will  be  carried  out  in  accordance  with  the  requirements  of  section  272.  1045  Based  on  the  record,  we  conclude  that  BellSouth  has  demonstrated  that  it  will  comply  with  the 
 requirements  of  section  272.  1046  BellSouth  provides  evidence  that  it  maintains  the  same  structural  separation  and  nondiscrimination  safeguards  in  Alabama,  Kentucky,  North  Carolina, 
 South  Carolina,  and  Mississippi  as  it  does  in  Georgia  and  Louisiana,  states  in  which  BellSouth  has  already  received  section  271  authority.  1047 


 272.  We  reject  AT&  Ts  argument  that  BellSouth  has  violated  section  272  through  its  interstate  and  intrastate  switched  access  (SWA)  tariffs.  1048  Section  272  prohibits  a  BOC  from 
 discriminating  in  favor  of  its  section  272  long  distance  affiliate  and  requires  that  a  BOC  charge  itself  or  its  affiliate  no  less  than  the  amount  charged  to  any  unaffiliated  IXC  for  access  to  its 
 telephone  exchange  service.  1049  A  BOC  must  make  volume  and  term  discounts  available  on  a  non-  discriminatory  basis  to  all  unaffiliated  interexchange  carriers.  1050  Growth  discounts  violate 
 this  mandate  because  they  offer  reduced  prices  based  on  growth  in  interexchange  traffic,  and  they  therefore  create  an  artificial  advantage  for  BOC  long  distance  affiliates  with  no 
 subscribers,  relative  to  existing  IXCs  and  other  new  entrants.  1051 


 1044  Alabama  Commission  Comments  at  174  (checklist  item  3),  216  (checklist  item  6),  227  (checklist  item  7),  229 
 (checklist  item  9),  243  (checklist  item  13),  247  (checklist  item  14);  Kentucky  Commission  Comments  at  31  (checklist  item  3),  34  (checklist  item  6),  35  (checklist  item  7),  36  (checklist  item  9),  40  (checklist  item  13),  41 


 (checklist  item  14);  Mississippi  Commission  Comments  at  3;  North  Carolina  Commission  Comments  at  167  (checklist  item  3),  218  (checklist  item  6),  224  (checklist  item  7),  229  (checklist  item  9),  245  (checklist  item  13),  251 
 (checklist  item  14);  South  Carolina  Commission  Comments  at  1. 
 1045  47  U.  S.  C.    271(  d)(  3)(  B). 


 1046  See  BellSouth  Application  App.  A,  Tab  B,  Affidavit  of  Pavan  Bhalla  (BellSouth  Bhalla  Aff.)  at  paras.  6-  16; 
 BellSouth  Ruscilli/  Cox  Aff.  at  paras.  225-  322. 
 1047  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9177,  para.  279;  BellSouth  Ruscilli/  Cox  Aff.  at  paras. 
 225-  322. 
 1048  AT&  T  Comments  at  45-  51. 


 1049  47  U.  S.  C.    272(  c)(  1),  (e)(  3). 
 1050  Implementation  of  the  Non-  Accounting  Safeguards  of  Sections  271  and  272  of  the  Communications  Act  of 
 1934,  as  amended,  CC  Docket  No.  96-  149,  First  Report  and  Order  and  Further  Notice  of  Proposed  Rulemaking,  11  FCC  Rcd  21905,  22028-  92,  para.  257  (1996). 


 1051  Access  Charge  Reform,  CC  Docket  No.  96-  262,  Fifth  Report  and  Order  and  Further  Notice  of  Proposed 
 Rulemaking,  14  FCC  Rcd  14221,  14294,  para.  134  (1999). 
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 273.  AT&  T  contends  that  BellSouths  FCC  Tariff  No.  1  (FCC  SWA  Tariff)  1052  and  intrastate  SWA  tariffs  in  Alabama,  Kentucky,  North  Carolina,  South  Carolina,  and  Mississippi  1053 
 contain  discriminatory  discounts  that  favor  BellSouths  long-  distance  affiliate,  BellSouth  Long  Distance,  by  offering  reduced  prices  based  on  growth  in  volume.  1054 


 274.  BellSouth  contends  that  there  is  no  section  272  violation  because  BellSouth  Long  Distance  is  not  eligible  to  take  service  under  the  tariffs  at  issue.  1055  We  agree.  1056  The  FCC  SWA 
 Tariff  contains  language  expressly  limiting  the  availability  of  the  tariff  only  to  customers  that  meet  certain  minimum  usage  requirements  associated  with  SWA  service.  1057  The  FCC  SWA 
 Tariff  also  mandates  that  customers  must  subscribe  within  30  days  of  the  tariffs  effective  date.  1058  The  intrastate  SWA  tariffs  at  issue  contain  similar  limiting  language.  1059  BellSouth 


 1052  BellSouth  Telecommunications,  Inc.  (BSTI),  Transmittal  No.  637,  F.  C.  C.  Tariff  No.  1,  Section  26,  SWA 
 Contract  Tariff  No.  2002-  01  (effective  May  18,  2002). 
 1053  See  Letter  from  Patrick  H.  Merrick,  Director    Regulatory  Affairs,  AT&  T,  to  Marlene  H.  Dortch,  Secretary, 
 Federal  Communications  Commission,  CC  Docket  No.  02-  35  [sic]  (filed  July  22,  2002)  (attaching  respective  SWA  tariffs  for  (1)  Kentucky  -  BSTI  Kentucky  Access  Service  Tariff  (AST),  E26.1  BellSouth  SWA  Contract  Tariff 


 KY2002-  01  (effective  June  28,  2002);  (2)  Mississippi  -  BSTI  Mississippi  AST,  E26.1  BellSouth  SWA  Contract  Tariff  MS2002-  01  (effective  June  14,  2002);  (3)  South  Carolina  -  BSTI  South  Carolina  AST,  E26.1  BellSouth  SWA 
 Contract  Tariff  SC2002-  01  (effective  June  26,  2002);  and  (4)  Alabama  -  BSTI  Alabama  AST,  E26.1  BellSouth  SWA  Contract  Tariff  AL2002-  01  (effective  June  17,  2002)).  In  an  August  13,  2002,  order,  the  North  Carolina 
 Commission  disapproved  BellSouths  SWA  tariff  as  not  being  in  the  public  interest  at  this  time  and  encouraged  BellSouth  to  consider  instead  volume-  based  discounts  for  access  services  that  are  not  biased  against  high-  volume 
 IXCs.  See  Letter  from  Glenn  T.  Reynolds,  Vice  President    Federal  Regulatory,  BellSouth,  to  Marlene  H.  Dortch,  Secretary,  Federal  Communications  Commission,  WC  Docket  No.  02-  150  (filed  Aug.  20,  2002)  (BellSouth  August 
 20  Ex  Parte  Letter)  (attaching  In  the  Matter  of  Tariff  Filing  by  BellSouth  Telecommunications,  Inc.  to  Establish  Contract  Rates  for  Switched  Access  Rate  Elements,  Order  Disapproving  Proposed  Tariff  at  4-  5,  North  Carolina 
 Public  Utilities  Commission  Docket  Nos.  P-  55,  Sub  1365,  and  P-  55,  Sub  1366  (Aug.  13,  2002)). 
 1054  AT&  T  Comments  at  45-  51. 


 1055  BellSouth  Reply  at  56;  BellSouth  Ruscilli/  Cox  Reply  Aff.  at  paras.  75-  76. 
 1056  Because  we  find  that  BellSouth  Long  Distance  is  not  eligible  for  service  under  those  tariffs,  we  need  not 
 reach  the  question  whether  those  tariffs  do  in  fact  offer  illegal  growth  discounts. 
 1057  FCC  SWA  Tariff  at  26.1.5(  B)  (reflecting  a  minimum  usage  requirement  of  3,385,697,632  minutes  in  year  one 
 and  increasing  in  subsequent  years).  AT&  T  contends  that  BellSouth  Long  Distance  somehow  can  take  advantage  of  the  tariff  because  the  tariff  is  based  on  the  individual  customers  usage  during  the  18  months  prior,  and  that  usage 


 becomes  the  baseline  against  which  future  growth  (and  size  of  the  discounts)  is  measured.  AT&  T  August  23  Pricing  and  Growth  Tariff  Ex  Parte  Letter  at  2.  This  challenge  is  contradicted  by  the  plain  language  of  the  SWA 
 tariffs,  which  provides  that  volume  discounts  are  not  applicable  to  any  usage  levels  outside  of  the  usage  ranges,  including  the  minimum  usage  amounts. 


 1058  FCC  SWA  Tariff  at  Introduction  (  In  order  to  take  advantage  of  the  volume  and  term  discount  plan  in 
 BellSouth  SWA  Contract  Tariff  No.  2002-  01,  customers  must  subscribe  to  the  tariff  within  30  days  of  the  tariffs  effective  date.). 


 1059  See,  e.  g.,  BellSouth  Kentucky  SWA  Contract  Tariff  at  E.  26.1.5.  B.  (reflecting  a  minimum  usage  requirement 
 of  103,254,229  minutes  in  year  one  and  increasing  in  subsequent  years).  See  also  id.  at  E26.1.1.  D  (  A  customer  (continued.) 
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 Long  Distance  did  not  meet  these  minimum  usage  requirements  and  did  not  subscribe  within  30  days  of  the  tariffs  effective  dates.  1060  BellSouth  Long  Distance  is  therefore  ineligible  for  any  of 
 these  tariffs.  Accordingly,  we  find  that  these  BellSouth  tariff  offerings  do  not  result  in  a  section  272  violation.  1061  We  add,  however,  that  if  BellSouth  Long  Distance  were  eligible  to  obtain 
 service  under  these  or  similar  tariffs,  we  could  then  address  allegations  that  such  tariffs  offer  illegal  growth  discounts  in  violation  of  section  272. 


 VII.  PUBLIC  INTEREST 
 275.  Apart  from  determining  whether  a  BOC  satisfies  the  competitive  checklist  and  will  comply  with  section  272,  Congress  directed  the  Commission  to  assess  whether  the  requested 


 authorization  would  be  consistent  with  the  public  interest,  convenience,  and  necessity.  1062  At  the  same  time,  section  271(  d)(  4)  of  the  Act  states  in  full  that  [  t]  he  Commission  may  not,  by  rule  or 
 otherwise,  limit  or  extend  the  terms  used  in  the  competitive  checklist  set  forth  in  subsection  (c)(  2)(  B).  1063  Accordingly,  although  the  Commission  must  make  a  separate  determination  that 
 approval  of  a  section  271  application  is  consistent  with  the  public  interest,  convenience,  and  necessity,  it  may  neither  limit  nor  extend  the  terms  of  the  competitive  checklist  of  section 
 271(  c)(  2)(  B).  The  Commission  views  the  public  interest  requirement  as  an  opportunity  to  review  the  circumstances  presented  by  the  application  to  ensure  that  no  other  relevant  factors 
 exist  that  would  frustrate  the  congressional  intent  that  markets  be  open,  as  required  by  the  competitive  checklist,  and  that  entry  will  serve  the  public  interest  as  Congress  expected. 


 (Continued  from  previous  page)  that  is  similarly  situated  may  subscribe  within  a  period  of  thirty  (30)  days  following  the  effective  date  of  the 
 BellSouth  SWA  Contract  Tariff  No.  KY2002-  01.). 
 1060  See  Letters  from  Sean  Lev,  Counsel  to  BellSouth,  to  Marlene  H.  Dortch,  Secretary,  Federal  Communications 
 Commission,  WC  Docket  No.  02-  150  (filed  Aug.  12  and  13,  2002)  (BellSouth  August  12/  13  Lev  Ex  Parte  Letter).  We  note  that  BellSouth  originally  emphasized  that  it  was  ineligible  for  the  tariffs  based  on  language  limiting 


 eligibility  to  customers  that  have  been  a  BellSouth  SWA  customer  for  the  previous  18  months.  BellSouth  Reply  at  56;  BellSouth  Ruscilli/  Cox  Reply  Aff.  at  para.  76.  See  also  FCC  SWA  Tariff  at  26.1.2(  B)  (  To  subscribe  to 
 BellSouth  SWA  Contract  Tariff  No.  2002-  01,  the  customer  must  have  been  a  BellSouth  SWA  customer  for  the  previous  18-  months.).  The  intrastate  SWA  tariffs  at  issue  contain  similar  limiting  language.  See,  e.  g.,  BellSouth 
 Kentucky  SWA  Contract  Tariff  at  E.  26.1.2.  B.  (  To  subscribe  to  BellSouth  SWA  Contract  Tariff  No.  KY2002-  01,  the  customer  must  have  been  a  BellSouth  SWA  customer  for  the  previous  18-  months.).  BellSouth  now  states, 
 however,  that  BellSouth  Long  Distance  has  in  fact  been  a  BellSouth  SWA  for  the  previous  18  months.  See  BellSouth  August  12/  13  Lev  Ex  Parte  Letter. 


 1061  Although  our  review  in  this  instance  is  limited  solely  to  section  271  compliance,  AT&  Ts  allegations,  if  true, 
 may  be  addressed  through  other  avenues.  For  example,  AT&  T  may  pursue  an  action  pursuant  to  sections  201,  202,  or  208  of  the  Act,  see  47  U.  S.  C.    201,  202,  208,  or  through  appropriate  state  proceedings.  AT&  T  also  argues  that 


 there  is  no  impediment  to  BellSouth  entering  into  the  same  arrangement  with  BellSouth  Long  Distance  sometime  in  the  future.  AT&  T  August  23  Pricing  and  Growth  Tariff  Ex  Parte  Letter  at  3.  We  reject  AT&  Ts 
 contention  that  we  should  find  a  violation  based  on  a  hypothetical  future  contract  with  BellSouth  Long  Distance. 
 1062  47  U.  S.  C.    271(  d)(  3)(  C);  Appendix  D  at  paras.  70-  71. 


 1063  Id.    271(  d)(  4). 
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 276.  We  conclude  that  approval  of  this  application  is  consistent  with  the  public  interest.  From  our  extensive  review  of  the  competitive  checklist,  which  embodies  the  critical 
 elements  of  market  entry  under  the  Act,  we  find  that  barriers  to  competitive  entry  in  the  local  exchange  markets  have  been  removed  and  the  local  exchange  markets  in  each  state  today  are 
 open  to  competition.  We  further  find  that  the  record  confirms  our  view,  as  noted  in  prior  section  271  orders,  that  BOC  entry  into  the  long  distance  market  will  benefit  consumers  and  competition 
 if  the  relevant  local  exchange  market  is  open  to  competition  consistent  with  the  competitive  checklist.  1064 


 277.  We  disagree  with  commenters  that  low  levels  of  facilities-  based  residential  competition  in  these  five  states  indicate  that  it  would  be  inconsistent  with  the  public  interest  to 
 grant  this  application.  1065  The  Commission  consistently  has  declined  to  adopt  a  market  share  or  other,  similar  test  for  BOC  entry  into  long  distance.  1066  Given  an  affirmative  showing  that  the 
 competitive  checklist  has  been  satisfied,  low  customer  volumes  in  any  one  particular  mode  of  entry  or  in  general  do  not  necessarily  undermine  that  showing.  Indeed,  the  Department  of 
 Justice  concluded  that  opportunities  for  facilities-  based  carriers  to  serve  business  customers  are  available  in  these  states  and  that,  despite  lower  levels  of  residential  competition,  as  the  systems 
 and  processes  serving  these  five  states  are  largely  the  same  as  those  approved  in  the  BellSouth  Georgia/  Louisiana  Order,  BellSouth  supports  opportunities  for  competitive  LECs  to  serve 
 residential  customers  via  facilities  and  to  serve  both  business  and  residential  customers  via  other  modes  of  entry.  1067  As  the  Commission  has  said  in  previous  section  271  orders,  factors  beyond 
 the  control  of  the  BOC,  such  as  individual  competitive  LEC  entry  strategies,  might  explain  a  low  residential  customer  base.  1068 


 A.  Dangers  of  Premature  Entry 
 278.  We  reject  US  LECs  claim  that  BellSouths  entry  into  the  long  distance  market  is  premature  and  will  cause  the  competitive  LEC  industry  to  shrink  because  BellSouth  will  be  able 


 to  offer  bundled  long  distance  and  local  service.  1069  As  discussed  above,  the  record  confirms  that  BOC  entry  into  the  long  distance  market  will  benefit  consumers  and  competition  if  the  relevant 
 local  exchange  market  is  open  to  competition  consistent  with  the  competitive  checklist.  1070  We  believe  that  the  bundling  of  both  local  and  long  distance  services  is  one  of  the  goals  of  section 


 1064  See  SWBT  Texas  Order,  15  FCC  Rcd  at  18558-  89,  para.  419. 
 1065  See,  e.  g.,  AT&  T  Comments  at  54-  56;  US  LEC  Comments  at  29-  30;  SouthEast  Telephone  Comments  at  1-  3. 
 1066  See,  e.  g.,  Ameritech  Michigan  Order,  12  FCC  Rcd  at  20748,  para.  391;  see  also  Sprint  v.  FCC,  274  F.  3d  at 
 553-  54  (  The  statute  imposes  no  volume  requirements  for  satisfaction  of  [section  271(  c)(  1)(  A].). 
 1067  Department  of  Justice  Evaluation  at  7;  see  also  BellSouth  Reply  at  68. 


 1068  See,  e.  g.,  Verizon  Pennsylvania  Order,  16  FCC  Rcd  at  17487,  para.  126. 
 1069  US  LEC  Comments  at  30-  31. 
 1070  See,  e.  g.,  SWBT  Texas  Order  15  FCC  Rcd  at  18558-  59,  para.  419. 
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 271,  and  if  the  checklist  is  otherwise  met,  it  would  be  very  difficult  for  us  to  deny  an  otherwise  unobjectionable  application  on  the  basis  that  the  BOCs  will  market  these  services.  For  the  same 
 reason,  we  disagree  with  AT&  Ts  assertion  that  the  public  interest  test  cannot  be  satisfied  simply  by  presuming  that  the  benefits  of  long-  distance  entry  will  outweigh  competitive  harms  from 
 premature  authorization,  and  that  if  competitive  LECs  cannot  profitably  offer  residential  service  to  customers,  they  cannot  and  will  not  effectively  compete  in  local  markets,  regardless  of 
 whether  the  incumbent  LEC  has  long-  distance  authorization.  1071  Entry  into  the  long  distance  market  is  not  premature  as  long  as  local  markets  have  been  opened  to  competition  pursuant  to 
 section  271. 
 B.  Price  Squeeze  Analysis 
 279.  Background.  WorldCom  contends  that  BellSouths  excessive  UNE  rates  contribute  to  a  price  squeeze  that  severely  limits  residential  competition  in  all  five  states.  1072 


 AT&  T  contends  that  BellSouths  UNE  rates  preclude  UNE  platform-  based  entry  in  North  Carolina.  1073  Before  analyzing  these  contentions,  we  begin  with  a  discussion  of  a  pending 
 remand  on  the  issue  of  how  allegations  of  a  price  squeeze  should  be  considered  under  the  public  interest  standard  of  section  271(  d)(  3)(  C).  In  the  Commissions  SWBT  Kansas/  Oklahoma  Order, 
 the  subject  of  Sprint  v.  FCC,  1074  the  Commission  declined  to  consider  allegations  that  approving  a  section  271  application  would  not  be  in  the  public  interest  because  competitors  are  unable  to 
 make  a  profit  in  the  residential  market  using  the  UNE-  platform.  1075  The  Commission  concluded  that  the  Act  requires  us  to  consider  whether  rates  are  cost-  based,  not  whether  market  entry  is 
 profitable.  1076  The  Commission  also  stated  that,  if  it  were  to  focus  on  profitability,  it  would  have  to  consider  a  states  retail  rates,  1077  which  are  generally  outside  its  jurisdictional  authority. 
 Appellants  asserted  that  their  inability  to  make  a  profit  in  the  residential  market  showed  that  granting  the  BOCs  section  271  application  was  not  in  the  public  interest.  1078  The  court 
 concluded  that  the  Commissions  rejection  of  the  appellants  profitability  argument  was  not  responsive  to  the  appellants  public  interest  argument.  1079  The  court  did  not,  however,  vacate  the 


 1071  AT&  T  Comments  at  52.  We  also  address  AT&  T's  claims  concerning  the  purported  difficulty  of  market  entry 
 in  the  price  squeeze  section  below. 
 1072  WorldCom  Comments  at  19. 


 1073  AT&  T  Comments  at  59. 
 1074  Sprint  v.  FCC,  274  F.  3d  549 
 1075  SWBT  Kansas/  Oklahoma  Order,  16  FCC  Rcd  at  6269,  para.  65,  6280-  81,  para.  92. 
 1076  Id.  at  6280-  81,  para.  92. 
 1077  Id. 
 1078  Sprint  v.  FCC,  274  F.  3d  at  553. 
 1079  Id.  at  554. 
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 order.  Instead,  it  remanded  the  Commissions  rejection  of  the  price  squeeze  issue  for  reconsideration.  1080 
 280.  The  Commission  intends  to  issue  an  order  addressing  the  questions  posed  in  Sprint  v.  FCC  about  how  we  should  consider  allegations  of  a  price  squeeze  that  are  raised  in 
 section  271  proceedings.  Because  we  have  not  yet  addressed  the  issues  remanded  by  the  court,  however,  we  consider  the  specific  allegations  presented  by  the  parties  in  this  case.  WorldCom 
 asserts  that  a  price  squeeze  analysis  is  relevant  in  each  of  the  five  states  1081  and  that  [  i]  t  is  contrary  to  the  public  interest  .  .  .  to  permit  BellSouth  into  the  long  distance  market  as  long  as  a 
 price  squeeze  exists  for  a  majority  of  consumers.  1082  AT&  T  argues  that  the  analysis  is  relevant,  at  least  for  the  state  of  North  Carolina.  It  argues  that,  even  if  BellSouths  rates  are  TELRIC-compliant, 
 if  the  rates  fall  at  the  high  end  of  the  TELRIC  range  and  foreclose  UNE  purchasers  from  economically  providing  residential  competition,  then  they  violate  section  271s  public 
 interest  requirement  as  well  as  checklist  item  2.  1083  We  conclude  that  neither  WorldCom  nor  AT&  T  has  established  the  existence  of  a  price  squeeze  because  they  have  not  shown  that  the 
 UNE  pricing  [at  issue]  doom[  s]  competitors  to  failure.  1084 
 281.  We  note  at  the  outset  that  the  factual  information  necessary  to  conduct  a  price  squeeze  analysis  is  highly  complex.  Courts  have  recognized  the  particular  difficulty  of 


 conducting  a  price  squeeze  inquiry  in  a  regulated  industry.  1085  Such  difficulty  is  exemplified  by  the  competing  analyses  proffered  by  AT&  T,  WorldCom,  and  BellSouth  in  this  case.  The  key 
 elements  --  input  costs,  revenues,  and  internal  costs  --  depend  on  numerous  variables,  only  some  of  which  are  reflected  in  the  analyses.  BellSouth,  AT&  T,  and  WorldCom  assume  different  input 
 costs  and  different  revenues  in  each  pricing  zone  within  each  state.  We  note  that  WorldComs  analysis  reflects  only  one  mode  of  entry,  UNE-  platform,  while  AT&  T  indicates  that  its 
 calculation  optimizes  other  possible  entry  strategies  such  as  resale.  1086 
 282.  A  comparison  of  BellSouths,  AT&  Ts,  and  WorldComs  assumptions  demonstrates  a  wide  range  of  estimates  as  to  the  potential  costs  incurred  by  and  revenue 


 opportunities  available  to  a  new  entrant.  BellSouths  gross  margin  estimates  are  significantly  higher  than  those  of  WorldCom  and  AT&  T.  For  example,  BellSouths  statewide  gross  margin 
 estimates  range  from  approximately  $9-$  13  higher  than  WorldComs  estimates  in  the  five  states, 
 1080  Id.  at  556. 
 1081  WorldCom  Comments  at  19-  20. 
 1082  WorldCom  Reply  at  11. 
 1083  AT&  T  Comments  at  42.  In  addition  to  violating  the  public  interest  requirement,  AT&  T  contends  that 
 BellSouths  UNE  rates  in  North  Carolina  are  discriminatory  in  violation  of  checklist  item  2.  See  discussion  below. 
 1084  Sprint  v.  FCC,  274  F.  3d  at  554  (emphasis  in  original). 


 1085  Concord  Massachusetts  v.  Boston  Edison  Co.,  915  F.  2d  17  (1  st  Cir.  1990). 
 1086  See  AT&  T  Comments  at  41. 
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 and  BellSouths  statewide  gross  margin  estimate  for  North  Carolina  is  higher  than  AT&  Ts  estimate.  1087  Most  of  the  differences  in  these  analyses  stem  from  the  fact  that  BellSouth  projects 
 revenues  based  on  a  premium  features  package  used  by  the  high-  end  customers  that  competitive  carriers  now  typically  serve,  whereas  WorldCom  and  AT&  T  project  the  revenues  of  a  competing 
 carrier  based  on  features  used  by  BellSouths  average  customer.  1088  Parties  also  make  different  assumptions  about  minutes  of  use,  the  amortization  of  non-  recurring  charges,  access  charges, 
 DUF  rates,  resale  revenues,  interLATA  and  intraLATA  tolls,  and  subscriber  line  charges.  1089  None  of  the  carriers  considers  revenue  from  services  other  than  traditional  voice  services,  even 
 though  the  UNE-  platform  provides  competitive  carriers  the  ability  to  offer  additional  services  not  offered  by  the  incumbent.  The  parties  also  do  not  consider  the  revenues  from  federal 
 universal  service  funds  1090  or  revenues  from  business  lines.  1091 


 1087  Compare  BellSouth  Ruscilli/  Cox  Aff.  at  para.  115,  Table  1;  para.  144,  Table  2;  para.  167,  Table  3;  para.  187, 
 Table  4;  and  para.  213,  Table  5  with  WorldCom  Comments  at  Exh.  1  and  AT&  T  Reply  Comments  App.  Tab  B,  Reply  Declaration  of  Michael  Lieberman  (AT&  T  Lieberman  Reply  Decl.)  at  Proprietary  Exh.  A. 


 1088  Compare  BellSouth  Ruscilli/  Cox  Aff.  at  para.  115,  Table  1;  para.  144,  Table  2;  para.  167,  Table  3;  para.  187, 
 Table  4;  and  para.  213,  Table  5  with  WorldCom  Comments  at  Exh.  1  and  AT&  T  Lieberman  Reply  Decl.  at  Proprietary  Exh.  A.  See  also  BellSouth  Ruscilli/  Cox  Aff.  at  para.  91;  AT&  T  Lieberman  Decl.  at  para.  23  and 


 AT&  T  Lieberman  Reply  Decl.  at  para.  6;  and  WorldCom  Reply  at  11. 
 1089  Compare  BellSouth  Ruscilli/  Cox  Aff.  at  para.  115,  Table  1;  para.  144,  Table  2;  para.  167,  Table  3;  para.  187, 
 Table  4;  and  para.  213,  Table  5  with  WorldCom  Comments  at  Exh.  1  and  AT&  T  Lieberman  Reply  Decl.  at  Proprietary  Exh.  A. 


 1090  In  the  third  quarter  of  2002,  federal  universal  service  funds  will  be  available  for  all  of  the  states  at  issue 
 except  North  Carolina.  See  Universal  Service  Administrative  Company,  Federal  Universal  Service  Support  Mechanisms  Fund  Size  Projections  for  the  Third  Quarter  2002  (May  2,  2002),  filed  pursuant  to  47  Section 


 54.709(  a)(  3).  In  the  fourth  quarter  of  2002,  federal  universal  funds  will  be  available  in  all  five  states.  See  Universal  Service  Administrative  Company,  Federal  Universal  Service  Support  Mechanisms  Fund  Size  Projections  for  the 
 Fourth  Quarter  2002  (Aug.  2,  2002),  filed  pursuant  to  47  Section  54.709(  a)(  3).  In  Alabama,  interstate  access  (CALLS)  support  of  $0.68  per  month  will  be  available  for  each  residential  and  single  line  business  line  in  zone  two; 
 $4.91  will  be  available  for  each  residential  and  single  line  business  in  zone  three;  and  $3.84  will  be  available  for  multi-  line  business  lines  in  zone  three.  Id.  at  Appendix  HC10.  In  addition,  approximately  $2,217,000  will  be 
 available  from  the  Incremental  Forward-  Looking  High  Cost  mechanism  (High  Cost  Fund),  ranging  from  no  support  in  some  wire  centers  to  $34  per  line  per  month  in  other  wire  centers  and  as  high  as  $168.87  per  line  per  month  in 
 one  wire  center.  The  average  will  be  approximately  $1.  10  per  line  per  month  for  every  line  in  the  study  area.  Id.  at  Appendix  HC11.  In  Kentucky,  CALLS  support  of  $2.05  per  month  will  be  available  for  each  residential  and  single 
 line  business  line  in  zone  three  and  $1.  11  will  be  available  for  multi-  line  business  lines  in  zone  three.  Id.  at  Appendix  HC10.  In  addition,  approximately  $178,000  per  month  will  be  available  from  the  High  Cost  Fund, 
 ranging  from  no  support  in  some  wire  centers  to  as  high  as  $2.08  in  others.  The  average  will  be  $0.14  per  line  per  month  for  every  line  in  the  study  area.  Id.  at  Appendix  HC11.  In  Mississippi,  CALLS  support  of  $0.52  per  month 
 will  be  available  for  each  residential  and  single  business  line  in  zone  three;  $4.78  will  be  available  for  each  residential  and  single  line  business  in  zone  four;  and  $4.13  is  available  for  each  multi-  line  business  line  in  zone  four. 
 Id.  at  Appendix  HC10.  In  addition,  approximately  $8,442,000  per  month  will  be  available  from  the  High  Cost  Fund,  ranging  from  no  support  in  some  wire  centers  to  as  high  as  $77  in  others.  The  average  will  be  $6.22  per  line 
 for  every  line  in  the  study  area.  Id.  at  Appendix  HC11.  In  North  Carolina,  CALLS  support  of  $0.58  per  month  will  be  available  for  each  residential  and  single  line  business  in  zone  two;  $2.85  will  be  available  for  each  residential  and 
 single  line  business  in  zone  three;  and  $1.  82  will  be  available  for  multi-  line  business  lines  in  zone  three.  Id.  at  (continued.) 
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 283.  Alabama,  Kentucky,  Mississippi,  South  Carolina.  WorldCom  asserts  that  the  statewide  gross  margin  is  not  sufficient  in  Alabama,  Kentucky,  Mississippi,  and  South  Carolina 
 for  a  competitive  carrier  to  cover  the  cost  of  leasing  the  elements  and  its  internal  costs.  1092  WorldCom  asserts  that  the  statewide  gross  margins  --  $4.03  in  Alabama,  $3.28  in  Kentucky, 
 negative  $0.79  in  Mississippi,  and  $0.02  in  South  Carolina  1093  --  are  not  enough  to  cover  its  internal  costs,  which  exceed  $10  per  month.  1094  Even  using  WorldComs  analysis,  WorldCom  is 
 unable  to  demonstrate  the  existence  of  a  price  squeeze  that  would  justify  a  denial  of  a  section  271  application. 


 284.  We  note,  as  we  did  in  the  Verizon  Vermont  Order  and  the  BellSouth  Georgia/  Louisiana  Order,  that  it  is  appropriate  to  look  beyond  the  low  statewide  gross  margins 
 and  consider  the  margins  that  are  available  in  individual  zones.  1095  In  the  BellSouth  Georgia/  Louisiana  Order,  for  example,  we  found  that,  although  the  statewide  margin  for 
 Louisiana  was  only  $2.63,  the  margin  available  in  67  percent  of  the  state  was  $8.12.  1096  Similarly,  using  WorldComs  analysis,  we  find  that  the  margins  in  zone  one  (and,  where 
 appropriate,  zone  two)  in  Alabama,  Kentucky,  Mississippi,  and  South  Carolina  are  significantly  higher  than  the  statewide  gross  margins  in  these  states.  According  to  WorldComs  analysis,  in 
 Alabama,  the  gross  margin  in  zone  one  (60  percent  of  the  state)  is  $9.09;  in  Kentucky,  the  gross  margin  in  zone  one  (43  percent  of  the  state)  is  $11.57  and  the  gross  margin  in  zone  two  (22 
 percent  of  the  state)  is  $6.84;  in  Mississippi,  the  gross  margin  in  zone  one  (26  percent  of  the  state)  is  $10.60  and  the  gross  margin  in  zone  two  (also  26  percent  of  the  state)  is  $5.97;  1097  and  in 
 South  Carolina,  the  gross  margin  in  zone  one  (69  percent  of  the  state)  is  $2.76.  We  find  the  gross  margins  in  Alabama,  Kentucky,  and  Mississippi  are  comparable  to  the  gross  margins  in 
 (Continued  from  previous  page)  Appendix  HC10.  In  North  Carolina,  no  high  costs  funds  will  be  available.  Id.  at  Appendix  HC11.  In  South 
 Carolina,  CALLS  support  of  $0.82  per  month  will  be  available  for  each  residential  and  single  line  business  line  in  zone  two;  $1.89  will  be  available  for  each  residential  and  single  line  business  line  in  zone  three;  and  $0.63  will  be 
 available  for  multi-  line  business  lines  in  zone  three.  Id.  at  Appendix  HC10.  In  South  Carolina,  no  high  cost  funds  will  be  available.  Id.  at  Appendix  HC11. 


 1091  See  SWBT  Missouri/  Arkansas  Order,  16  FCC  Rcd  at  20651,  para.  66. 
 1092  WorldCom  Comments  at  19.  WorldCom  makes  the  same  arguments  with  respect  to  North  Carolina,  which 
 we  discuss  below. 
 1093  WorldCom  Comments  at  19  &  Exh.  1. 


 1094  Id.  at  19-  20.  WorldCom  states  that  its  internal  costs  include  customer  service  costs,  costs  associated  with 
 customers  who  dont  pay  their  bills,  billing  and  collections,  overhead,  marketing  costs,  and  other  operational  costs.  Id. 


 1095  As  we  discuss  further  below,  we  find  it  significant  that  the  statewide  gross  margins  reflect  inclusion  of 
 negative  margins  from  rural  areas  and  are  low  as  a  result  of  an  intentional  state  policy  to  keep  retail  rates  affordable.  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9179-  80,  para.  286. 


 1096  Id. 
 1097  We  also  note  that,  as  discussed  above,  the  inclusion  of  federal  universal  service  support  revenues  in 
 Mississippi  might  result  in  a  gross  margin  in  zone  three  and  zone  four  high  enough  to  induce  competitors  to  enter. 
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 Louisiana,  where  we  did  not  find  a  price  squeeze.  While  we  do  not  find  that  South  Carolinas  gross  margins  are  comparable  to  Louisianas,  we  do  find  it  significant  that  WorldCom  is 
 currently  competing  in  each  of  these  states,  including  South  Carolina.  1098  Furthermore,  we  note  that  the  residential  competition  rates  in  each  of  these  four  states    ranging  from  4.0  to  5.5 
 percent  1099  --  are  higher  than  those  of  seven  states  at  the  time  their  section  271  applications  were  filed.  1100 


 285.  In  light  of  these  comparisons  and  WorldComs  competitive  entry  in  each  of  these  states,  we  find  it  significant  that  WorldCom  did  not  address  any  of  the  factors  that  we  identified 
 in  past  orders  as  relevant  to  a  price  squeeze  analysis.  WorldCom  did  not  analyze  how  using  a  mix  of  UNEs  and  resale  to  provide  service  would  affect  a  price  squeeze  analysis.  Nor  did  it 
 provide  an  analysis  to  demonstrate  the  internal  costs  of  an  efficient  competitor.  It  did  not  analyze  other  revenues  that  may  be  available  to  competitors,  such  as  toll  revenues  and  revenues 
 available  from  federal  universal  service  funds  1101  and  business  lines.  1102  Accordingly,  as  we  found  in  previous  orders,  1103  the  evidence  submitted  here  is  an  inadequate  basis  to  determine  that 
 a  price  squeeze  exists  in  the  residential  markets  in  Alabama,  Kentucky,  Mississippi,  and  South  Carolina. 


 286.  North  Carolina.  AT&  T  asserts  that  it  has  conducted  a  margin  analysis  that  shows  that  competitive  entry  in  the  residential  market  is  not  feasible  in  North  Carolina  because  the 
 statewide  gross  margin  is  insufficient,  even  when  considering  revenues  from  intraLATA  and  interLATA  toll  calls  and  the  effect  of  a  resale  entry  strategy.  1104  WorldCom,  which  does  not 
 consider  these  factors,  asserts  the  statewide  gross  margin  in  North  Carolina  is  $1.83.  1105  For  all  the  reasons  that  we  found  that  WorldCom  did  not  prove  a  price  squeeze  in  Alabama,  Kentucky, 
 Mississippi,  and  South  Carolina,  we  find  WorldCom  does  not  prove  a  price  squeeze  in  North 


 1098  WorldCom  Comments  at  19. 
 1099  According  to  the  Department  of  Justices  evaluation,  residential  competition  in  Alabama  is  4.  0%;  in 
 Kentucky,  4.0%;  in  Mississippi,  5.5%;  and  in  South  Carolina,  4.6%.  Department  of  Justice  Evaluation  at  6. 
 1100  See  Letter  from  Glenn  T.  Reynolds,  Vice  President    Federal  Regulatory,  BellSouth,  to  Marlene  H.  Dortch, 
 Secretary,  Federal  Communications  Commission,  WC  Docket  No.  02-  150  (filed  July  31,  2002)  (BellSouth  July  31  Ex  Parte  Letter)  (providing  citations  showing  residential  competition  in  states  at  the  time  section  271  applications 


 were  filed:  Connecticut  was  0.1%;  Vermont,  0.28%;  Maine,  0.55%;  New  Jersey,  1.32%;  New  York,  2.99%;  Missouri,  3.56%;  and  Louisiana,  3.92%).  We  granted  each  of  these  section  271  applications. 


 1101  SWBT  Missouri/  Arkansas  Order,  16  FCC  Rcd  at  20751,  para.  66. 
 1102  Id. 
 1103  Verizon  New  Jersey  Order,  17  FCC  Rcd  at  12362,  para.  175;  BellSouth  Georgia/  Louisiana  Order,  17  FCC 
 Rcd  at  9181,  para.  290;  Verizon  Vermont  Order,  17  FCC  Rcd  at  7665,  para.  73;  SWBT  Missouri/  Arkansas  Order,  16  FCC  Rcd  at  20751,  para.  66. 


 1104  AT&  T  Lieberman  Reply  Decl.  at  Proprietary  Exh.  A. 
 1105  WorldCom  Comments  at  19  &  Exh.  1 
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 Carolina,  and  we  will  not  consider  its  analysis  further.  Even  using  AT&  Ts  analysis,  moreover,  AT&  T  is  unable  to  demonstrate  the  existence  of  a  price  squeeze  that  would  justify  a  denial  of  a 
 section  271  application. 
 287.  Under  AT&  Ts  analysis  the  gross  margin  in  zone  one  (72  percent  of  the  state)  is  not  substantially  higher  than  the  statewide  gross  margin.  1106  We  find  it  significant  that 


 WorldCom  is  currently  competing  in  North  Carolina.  1107  Furthermore,  we  note  that  the  residential  competition  rate  in  North  Carolina  is  3.6  percent,  higher  than  that  of  six  states  at  the 
 time  that  their  271  applications  were  filed.  1108 
 288.  Although  AT&  T,  unlike  WorldCom,  purports  to  consider  some  of  the  factors  that  we  identified  in  our  Verizon  Vermont  Order  and  other  orders  as  relevant  to  a  price  squeeze 


 analysis  (such  as  the  effect  of  including  a  resale  entry  strategy;  the  internal  costs  of  an  efficient  competitor;  and  other  revenues  that  may  be  available  to  competitors,  such  as  toll  revenues  and 
 federal  universal  service  funds  revenues),  we  still  find  AT&  Ts  analysis  lacking.  First,  we  find  that  AT&  T  provides  us  with  insufficient  information  to  make  a  judgment  about  its  internal  costs 
 or  the  relationship  between  its  internal  costs  and  those  of  an  efficient  competitor.  AT&  T  purports  to  provide  a  breakdown  of  the  internal  costs  that  an  efficient  new  entrant  would  have  to 
 recover  when  entering  local  markets  in  North  Carolina.  1109  AT&  T  provides  confidential  line  items  for  local  customer  care,  uncollectible  expenses,  billing  and  collections,  marketing  and 
 sales  costs,  and  other  general  and  administrative  costs.  1110  AT&  T  does  not  provide  cost  or  other  data,  as  set  forth  in  our  Verizon  Vermont  Order,  to  verify  these  figures.  Nor  does  it  adequately 
 explain  why  these  figures  represent  those  of  an  efficient  competitor.  We  also  note  that,  while  AT&  T  claims  to  analyze  the  universal  service  funds  available  to  a  competitor  in  North  Carolina, 
 it  did  not  include  these  funds  in  its  analysis.  1111  Nor  did  it  consider  potential  revenues  from  business  lines. 


 289.  In  addition,  AT&  T  does  not  convincingly  analyze  the  modes  of  entry  that  are  available  to  competitors  in  North  Carolina.  AT&  T  does  provide  estimates  of  the  revenue  that  a 
 competitor  could  gain  from  resale  in  North  Carolina,  1112  but  it  did  not  provide  an  analysis  of 
 1106  AT&  T  Lieberman  Reply  Decl.  at  Proprietary  Exh.  A. 


 1107  WorldCom  Comments  at  19. 
 1108  See  BellSouth  July  24  Ex  Parte  Letter  at  Attach.  1  (providing  citations  showing  that  residential  competition  is 
 higher  in  North  Carolina  than  it  was  in  Connecticut,  Vermont,  Maine,  New  Jersey,  Missouri,  and  New  York  when  section  271  applications  were  filed  for  those  states).  We  granted  each  of  these  section  271  applications. 


 1109  AT&  T  Comments  App.,  Exh.  B,  Declaration  of  Stephen  Bickley  (AT&  T  Bickley  Decl.)  at  paras.  4-  11. 
 1110  Id. 
 1111  An  ETC  can  receive  CALLS  support  of  $0.58  per  month  for  each  residential  and  single  line  business  line  in 
 zone  two  and  $2.  85  in  zone  three  and  $1.  82  for  multi-  line  business  lines  in  zone  three. 
 1112  AT&  T  Lieberman  Reply  Decl.  at  para.  9,  Table  III.  Revenues  are  $3.93  statewide;  $3.98  in  zone  one;  $3.82 
 in  zone  two;  and  $3.74  in  zone  three. 
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 different  entry  strategies.  AT&  T  claims,  for  example,  that  UNE  platform-  based  local  entry  is  never  the  more  optimal  competitive  entry  solution  in  North  Carolina.  1113  But,  as  BellSouth 
 points  out,  WorldCom  states  in  its  comments  that  it  is  already  offering  UNE  platform-  based  service  in  North  Carolina.  1114  The  Department  of  Justice  finds  in  its  analysis  that  0.5  percent  of 
 residential  lines  (8431  lines)  are  served  by  UNE-  platform  in  North  Carolina.  1115  With  respect  to  facilities-  based  entry,  AT&  T  claims  that  a  UNE-  loop  strategy,  in  which  a  competitive  carrier 
 leases  BellSouths  loops  but  provides  its  own  switching,  is  wholly  uneconomic  1116  because  BellSouths  manual  hot  cut  process  is  plagued  by  ordering  problems  and  has  unacceptable 
 levels  of  service  outages.  1117  We  find  elsewhere  in  this  order  that  BellSouth  provides  hot  cuts  in  North  Carolina  within  reasonable  time  intervals,  at  an  acceptable  level  of  quality,  with  minimal 
 service  disruption,  and  with  a  minimum  number  of  troubles  following  installation.  1118  The  Department  of  Justice  finds  in  its  analysis  that  1.1  percent  of  residential  lines  (18,548  lines)  are 
 provided  through  facilities-  based  competition.  1119 
 290.  Finally,  AT&  T  is  incorrect  when  it  states  that  [  i]  t  is  .  .  .  not  relevant  that  intentional  state  policy  may  have  caused  wholesale  rates  to  exceed  retail  rates.  1120  In  weighing 


 any  price  squeeze  allegation,  we  must  consider  whether  the  price  squeeze  is  the  result  of  a  state  commission  policy  to  keep  rates  affordable  in  high-  cost  areas.  As  we  stated  in  the  Verizon 
 Vermont  Order,  it  is  possible  that  a  lack  of  profitability  in  entering  the  residential  market  may  be  the  result  of  subsidized  local  residential  rates  in  one  or  more  zones,  and  not  the  fact  that  UNE 
 rates  are  at  an  inappropriate  point  in  the  TELRIC  range.  1121  We  note  that  state  commissions  have  jurisdiction  over  retail  as  well  as  wholesale  prices.  1122  It  may  be  that,  until  states  rebalance 
 residential  and  business  rates,  or  make  high  cost  subsidies  explicit  and  portable,  the  UNE-platform  may  not  provide  a  viable  means  of  entry  for  certain  areas  in  some  states.  That  fact, 
 however,  needs  to  be  weighed  against  competing  public  policy  interests,  such  as  ensuring 


 1113  AT&  T  Lieberman  Decl.  at  para.  29. 
 1114  BellSouth  Reply  at  58  (citing  WorldCom  Comments  at  19). 
 1115  Department  of  Justice  Evaluation  at  6. 
 1116  AT&  T  Comments  at  65. 
 1117  AT&  T  Reply  at  32  (quoting  KMC  Telecom/  Nuvox  Comments  at  13-  14  and  15-  16). 
 1118  See  section  V.  B,  supra. 
 1119  Department  of  Justice  Evaluation  at  6. 
 1120  AT&  T  Comments  at  62. 
 1121  Verizon  Vermont  Order,  17  FCC  Rcd  at  7663-  64,  paras.  68-  69.  The  Court  of  Appeals  for  the  District  of 
 Columbia  Circuit  noted  this  argument  as  a  potential  basis  for  declining  to  find  a  price  squeeze.  The  Court  did  not  address  this  argument  because  the  Commission  did  not  rely  on  it  in  the  underlying  SWBT  Kansas/  Oklahoma  Order, 


 16  FCC  Rcd  6237  (2001).  Sprint  v.  FCC,  274  F.  3d  at  555. 
 1122  For  this  reason,  we  think  these  issues  are  best  presented  to  the  state  commission  in  the  first  instance. 
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 availability  and  affordability  of  local  telephone  services  in  rural  areas  and  the  benefit  to  consumers  from  the  BOCs  entry  into  the  interLATA  market.  Given  the  complex  and  competing 
 public  policy  interests  at  stake,  we  do  not  think  that  we  can  conclude  that  the  existence  of  subsidies  in  rural  areas  in  itself  is  a  circumstance  that  requires  a  finding  that  the  public  interest 
 requirement  has  not  been  satisfied. 
 291.  Checklist  Item  Two.  AT&  T  separately  contends  that  the  evidence  that  it  provides  of  a  price  squeeze  also  establishes  that  BellSouths  North  Carolina  UNE  rates  are  discriminatory 


 in  violation  of  checklist  item  two.  1123  As  discussed  above,  we  conclude  that  AT&  T  has  not  established  the  existence  of  a  price  squeeze  in  the  residential  market.  AT&  T  submits  no  separate 
 price  squeeze  analysis  in  support  of  this  claim.  Accordingly,  consistent  with  prior  section  271  orders,  we  need  not  decide  whether  the  existence  of  a  price  squeeze  in  the  residential  market 
 would  constitute  a  separate  violation  of  checklist  item  two.  1124 
 292.  For  the  reasons  stated  above,  we  reject  AT&  Ts  and  WorldComs  allegations  of  a  price  squeeze  and  conclude  that  there  is  no  evidence  in  the  record  that  warrants  disapproval  of 


 this  application  based  on  such  contentions,  whether  couched  as  discrimination  in  violation  of  checklist  item  two,  or  under  the  public  interest  standard. 


 C.  Assurance  of  Future  Compliance 
 293.  We  find  that  the  existing  SEEM  Plans  currently  in  place  for  these  states  provide  assurance  that  these  local  markets  will  remain  open  after  BellSouth  receives  section  271 


 authorization.  1125  According  to  BellSouth,  these  plans  use  the  same  statistical  methodology,  use  the  same  transaction-  based  remedy-  calculation  method,  provide  for  remedy  payments  both  to 
 individual  competitive  LECs  and  to  the  relevant  state  regulatory  bodies,  set  a  meaningful  and  substantial  cap  on  BellSouths  financial  liability,  and  provide  for  annual  audits,  performance 
 reviews,  and  a  dispute  resolution  procedure.  1126  The  Alabama  and  Kentucky  SEEM  plans  are  precisely  the  same  as  the  Georgia  SEEM  plan  already  reviewed  and  approved  by  this 
 Commission.  1127  The  SEEM  plans  in  each  of  the  other  states  are  substantially  identical,  although  each  includes  certain  minor  state-  specific  modifications.  1128  We  therefore  approve  of  these  plans 
 and  accord  them  the  same  probative  value  as  we  did  the  Georgia  plan.  Because  these  plans  are  modeled  after  the  Georgia  SEEM  plan  that  we  approved  in  the  BellSouth  Georgia/  Louisiana 


 1123  AT&  T  Comments  at  41-  43. 
 1124  Verizon  New  Jersey  Order,  17  FCC  Rcd  at  12361-  62,  para.  174;  BellSouth  Georgia/  Louisiana  17  FCC  Rcd  at 
 9181,  para.  289;  Verizon  Vermont  Order,  17  FCC  Rcd  at  7665,  para.  72. 
 1125  Ameritech  Michigan  Order,  12  FCC  Rcd  at  20748-  50,  paras.  393-  98. 


 1126  BellSouth  Reply  at  65.  See  also  BellSouth  Varner  Aff.  at  paras.  212-  13. 
 1127  See  BellSouth  Application  at  141;  see  also  BellSouth  Varner  Aff.  at  paras.  214-  15. 
 1128  BellSouth  Varner  Aff.  at  paras.  216-  19. 
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 Order,  1129  we  need  not  discuss  them  in  detail  here  but  refer  to  our  finding  in  that  Order.  1130  We  find  that  each  of  the  five  plans  provides  sufficient  incentives  to  foster  post-  entry  compliance. 
 294.  AT&  T  argues  that,  as  performance  remedy  plans  rely  on  performance  data  to  trigger  performance-  remedies  payments,  the  unreliability  of  BellSouths  performance  data  fatally 
 compromises  the  efficacy  of  all  of  the  performance  remedy  plans  that  are  the  subject  of  this  application.  1131  AT&  T  further  asserts  that  the  performance  plans  that  BellSouth  refers  to  in  its 
 applications  are  either  interim  plans  (Alabama)  or  have  not  been  finalized  (North  Carolina)  and  thus  the  Commission  cannot  assess  whether  these  plans  meet  its  criteria  for  an  effective  plan.  1132 
 We  reject  AT&  Ts  arguments.  With  respect  to  its  first  argument,  we  note  that  we  have  found  BellSouths  performance  data  to  be  reliable.  1133  In  addition,  as  we  stated  above,  the  performance 
 plans  that  BellSouth  has  already  implemented  or  plans  to  implement  in  these  states  are  essentially  the  same  as  the  plan  implemented  in  the  Georgia,  which  we  have  already  analyzed 
 and  approved.  With  respect  to  AT&  Ts  second  argument,  we  find  that  the  fact  that  the  plans  in  Alabama  and  North  Carolina  are  interim  plans  has  no  bearing  whatsoever  on  their  validity.  They 
 are  subject  in  any  case  to  final  approval  by  the  appropriate  state  commissions  and,  as  we  stated  in  the  BellSouth  Georgia/  Louisiana  Order,  the  performance  plans  adopted  by  each  state 
 commission  do  not  represent  the  only  means  of  ensuring  that  BellSouth  continues  to  provide  nondiscriminatory  service  to  competing  carriers.  1134  In  addition  to  the  financial  penalties 
 imposed  by  these  plans,  BellSouth  faces  other  consequences  if  it  fails  to  sustain  a  high  level  of  service  to  competing  carriers,  including  federal  enforcement  action  pursuant  to  section 
 271(  d)(  6),  1135  liquidated  damages  under  dozens  of  interconnection  agreements,  and  remedies  associated  with  antitrust  and  other  legal  actions.  1136 


 295.  In  addition,  WorldCom  argues  that,  because  the  South  Carolina  Commission  has  designated  BellSouths  performance  plan  as  voluntary,  liquidated  damages  under  the  plan  may 
 be  unenforceable  by  the  South  Carolina  Commission  under  state  law  and  are  only  recoverable  through  civil  litigation.  1137  The  South  Carolina  Commission  states  that  WorldComs  contention 
 that  it  lacks  jurisdiction  is  incorrect  and  nothing  reduces  the  South  Carolina  Commissions 


 1129  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9181-  83,  paras.  291-  93. 
 1130  Id. 
 1131  AT&  T  Comments  at  66. 
 1132  Id.  at  66-  69. 
 1133  We  discuss  the  reliability  of  BellSouth's  performance  data  in  section  III,  above. 
 1134  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9186,  para.  300. 
 1135  47  U.  S.  C.    271(  d)(  6). 
 1136  See  SWBT  Texas  Order,  15  FCC  Rcd  at  18561-  62,  para.  424. 
 1137  WorldCom  Comments  at  20-  21. 
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 jurisdiction  to  enforce  the  plan.  1138  We  note  that,  even  if  WorldComs  contention  was  valid,  a  point  we  do  not  address  here,  the  South  Carolina  Commission  has  ordered  BellSouth  to 
 incorporate  the  performance  plan  in  its  SGAT,  and  allowed  each  competitive  LEC  to  amend  its  interconnection  plan  with  BellSouth  to  incorporate  the  performance  plan.  1139  Therefore,  in  the 
 event  that  the  South  Carolina  Commission  failed  to  enforce  these  agreements,  a  competitive  LEC  may  be  able  to  seek  relief  pursuant  to  section  252(  e).  1140  This  is  in  addition  to  other  remedies  that 
 are  available  to  the  competitive  LECs,  as  stated  above. 
 D.  Marketing  Tactics 
 296.  We  also  reject  commenters  allegations  that  BellSouths  application  is  not  in  the  public  interest  because  of  marketing  tactics  employed  by  BellSouth.  1141  Some  commenters  allege 


 that  BellSouth  has  engaged  in  inappropriate  winback  1142  or  retention  marketing.  1143  In  the  CPNI  Order,  1144  we  concluded  that  winback  campaigns  are  consistent  with  section  222(  c)(  1)  of  the 
 Telecommunications  Act  and  are  thus  not  anticompetitive,  and  that  retention  marketing  campaigns  may  be  permissible  assuming  they  do  not  violate  the  provisions  of  section  222(  b)  of 
 the  Act,  which  prohibits  a  carrier  from  using  carrier  proprietary  information  (CPI)  to  retain  soon-to-  be  former  customers  when  the  carrier  gains  notice  of  a  customers  imminent  cancellation  of 
 service  through  the  provision  of  carrier-  to-  carrier  service.  1145  We  find,  as  we  did  in  the  BellSouth  Georgia/  Louisiana  Order,  that  in  the  absence  of  a  formal  complaint  to  the  Commission  that 
 BellSouth  has  failed  to  comply  with  the  provisions  of  section  222(  b),  these  allegations  should  be 


 1138  South  Carolina  Commission  Reply  at  2. 
 1139  Id. 
 1140  47  U.  S.  C.    252(  e). 
 1141  See  Birch  Comments  at  4,  10,  13  and  25-  26  (discussing  winbacks  and  Customer  Rewards.). 
 1142  See,  e.  g.,  US  LEC  Comments  at  36-  37;  Birch  Comments  at  10.  Winback  marketing  refers  to  situations  where 
 a  customer  has  switched  to  and  is  receiving  service  from  another  provider,  whereas  retention  marketing  refers  to  a  carriers  attempts  to  keep  an  existing  customer  before  that  customer  has  switched  to  another  carrier. 


 1143  Id. 
 1144  Implementation  of  the  Telecommunications  Act  of  1996,  Telecommunications  Carriers'  Use  of  Customer 
 Proprietary  Network  Information  and  Other  Customer  Information;  CC  Docket  No.  96-  115;  Implementation  Of  The  Non-  Accounting  Safeguards  Of  Sections  271  And  272  Of  The  Communications  Act  Of  1934,  As  Amended,  CC 


 Docket  No.  96-  149,  Order  On  Reconsideration  and  Petitions  for  Forbearance,  14  FCC  Rcd  14409,  14445,  para.  67  (1999)  (CPNI  Order).  See  also  Implementation  of  the  Telecommunications  Act  of  1996;  Telecommunications 
 Carriers  Use  of  Customer  Proprietary  Network  Information;  Implementation  of  the  Non-  Accounting  Safeguards  of  Section  271  and  272  of  the  Communications  Act  of  1934,  As  Amended,  2000  Biennial  Review    Review  of  Policies 
 and  Rules  Concerning  Unauthorized  Changes  of  Consumers  Long  Distance  Carriers,  CC  Docket  Nos.  96-  115,  96-  149,  00-  257,  Third  Report  and  Order  and  Third  Further  Notice  of  Proposed  Rulemaking,  FCC  02-  214  (rel.  July  25, 
 2002)  (CPNI  Third  Report  and  Order). 
 1145  CPNI  Order,  14  FCC  Rcd  at  14449,  para.  77;  see  also  CPNI  Third  Report  and  Order  at  para.  131. 
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 referred  to  the  appropriate  state  commission  for  disposition.  1146  The  North  Carolina  Commission  ordered  BellSouth  to  abstain  from  any  marketing  activities  directed  to  a  customer  for  seven  days 
 after  the  customer  switches  to  another  local  telephone  company.  1147  The  South  Carolina  Commission  issued  a  Winback  Order  prohibiting  BellSouth  from  engaging  in  any  winback 
 activities  for  ten  calendar  days  from  the  date  that  service  has  been  provided  to  a  customer  by  a  competitive  LEC.  1148  For  consistency  throughout  its  region,  BellSouth  has  adopted  as  its 
 standard  policy  that  it  will  not  engage  in  any  winback  activities  for  ten  calendar  days  from  the  date  that  service  has  been  provided  to  a  customer  by  a  competitive  LEC.  1149 


 E.  Other  Issues 
 297.  US  LEC  states  that  in  the  BellSouth  Georgia/  Louisiana  Order,  the  Commission  changed  its  policy  and  virtually  tied  approval  to  checklist  compliance.  1150  Specifically,  the  order 


 states  that  although  the  Commission  must  make  a  separate  determination  that  approval  of  a  section  271  application  is  consistent  with  the  public  interest,  convenience,  and  necessity,    it 
 may  neither  limit  nor  extend  the  terms  of  the  competitive  checklist  of  section  271(  c)(  2)(  B).  1151  This  standard,  however,  is  part  of  the  statute  and,  moreover,  has  been  followed  by  the 
 Commission  in  all  of  its  section  271  orders.  Thus,  there  is  no  basis  for  US  LECs  argument  that  the  public  interest  standard  has  been  weakened.  1152 


 298.  WorldCom  claims  that  on  June  14,  2002,  BellSouth  announced  a  policy  that  it  will  only  provide  long  distance  service  for  BellSouth  local  customers  and  not  competitive  LEC 
 local  customers,  1153  and  that  it  is  contrary  to  the  public  interest  to  allow  BellSouth  to  obtain  long 
 1146  See  BellSouth  Georgia/  Louisiana  Order,  17  FCC  Rcd  at  9187-  88,  para.  303. 
 1147  North  Carolina  Utilities  Commission,  Docket  No.  P-  55,  Sub  1022  (May  23,  2002)  at  1,  para.  1. 
 1148  South  Carolina  Public  Service  Commission,  Docket  No.  2000-  378-  C-  Order  No.  2001-  1036  (Oct.  29,  2001)  at 
 13,  para.  9.  See  also  South  Carolina  Public  Service  Commission,  Docket  No.  2000-  378-  C-  Order  No.  2002-  2  (Jan.  9,  2002)  at  unnumbered  2,  para.  2,  (clarifying  the  earlier  order  by  stating  that:  the  prohibition  on  the  sharing  of 


 information  among  BellSouth  divisions  found  in  Order  No.  2001-  1036  should  begin  a  the  time  that  BellSouth  comes  into  possession  of  information  from  the  CLEC  which  would  suggest  that  a  specific  customer  is  considering  a 
 proposal  from  the  CLEC.) 
 1149  BellSouth  August  15  Non-  pricing  Ex  Parte  Letter. 


 1150  US  LEC  Comments  at  25. 
 1151  Id. 
 1152  Although  we  find  that  US  LEC's  allegations  are  vague  and  unsupported,  we  disagree  that  BellSouths  ability 
 to  raise  prices  for  special  access  is  prima  facie  evidence  of  a  lack  of  local  competition.  Id.  at  29-  30.  We  do  not  consider  a  BOC's  simple  pricing  of  special  access,  by  itself,  to  be  dispositive  of  the  presence  or  absence  of  local 


 competition.  In  any  event,  the  analysis  in  a  section  271  application  focuses  on  checklist  compliance,  and  we  conclude  herein  that  BellSouth's  application  satisfies  all  checklist  requirements.  We  therefore  reject  US  LEC's 
 contentions. 
 1153  WorldCom  Comments  at  6. 
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 distance  authorization  while  this  policy  exists.  1154  BellSouth  states  that,  while  competitive  LECs  end  users  may  request  long  distance  from  BSLD,  the  competitive  LEC  must  have  an  operational 
 agreement  with  BSLD  in  order  for  the  request  to  be  fulfilled,  and  that  most  competitive  LECs  cannot  or  do  not  make  available  to  long  distance  carriers  the  broad  range  of  services  needed  by 
 BSLD  that  would  enable  BSLD  to  provide  service.  1155  BellSouth  indicates  that  while  it  is  working  to  provide  service  to  competitive  LECs,  it  must  continue  to  restrict  service  until  the 
 appropriate  integrative  services  are  made  available.  1156  While  we  recognize  the  inconvenience  this  may  have  caused  competitive  LECs,  absent  further  evidence  on  the  record,  we  do  not  find 
 that  BellSouths  current  policy  violates  the  public  interest  standard  of  section  271.  1157 
 299.  Finally,  we  note  that  BellSouth  disclosed  an  incident  of  premature  mail  solicitations  offering  long  distance  service  in  the  five  states  plus  Florida  and  Tennessee.  1158 


 According  to  BellSouth,  approximately  130,000  of  its  customers  in  these  states  inadvertently  received  such  a  solicitation  from  BellSouth  that  was  meant  to  be  sent  only  to  customers  in 
 Georgia  and  Louisiana.  1159  BellSouth  noted  that  the  mailings  contained  a  notice  in  fine  print,  that  the  advertised  service  was  available  only  in  Georgia  and  Louisiana.  1160  In  response  to 
 BellSouths  disclosure,  AT&  T  filed  a  motion  requesting  the  Commission  to  deny  this  application  on  the  grounds  that  BellSouth  has  not  met  the  public  interest  standard  of  section  271(  d)(  3)(  c)  and 
 issue  a  "standstill  order"  directing  BellSouth  to  immediately  cease  and  desist  from  advertising  long  distance  service  in  states  where  it  does  not  have  long  distance  authority.  1161  AT&  T  further 


 1154  Id.  at  7. 
 1155  BellSouth  Application  Reply  App.,  Vol.  2,  Tab  D,  Reply  Affidavit  of  Mary  M.  Dennis  (BellSouth  Dennis 
 Reply  Aff.)  at  1-  3. 
 1156  Id.  at  4. 


 1157  If  evidence  becomes  available  to  the  Commission  in  the  future  sufficient  to  show  BellSouths  actions  are  in 
 violation  of  the  Act  or  a  Commission  Rule,  we  will  pursue  appropriate  enforcement  action. 
 1158  See  Letter  from  Kathleen  B.  Levitz,  Vice  President    Federal  Regulatory,  BellSouth,  to  Marlene  H.  Dortch, 
 Secretary,  Federal  Communications  Commission,  WC  Docket  No.  02-  150  (filed  Aug.  8,  2002)  (BellSouth  August  8  Ex  Parte  Letter).  See  also  BellSouth  Corporations  Response  to  Motion  of  AT&  T  Corp.  for  Emergency  Relief,  WC 


 Docket  No.  02-  150,  at  1-  2  (filed  Aug.  23,  2002). 
 1159  Id.  According  to  BellSouth,  113,000  packages  were  sent  to  Florida,  3,300  were  sent  to  customers  in 
 Tennessee,  3,500  packages  were  sent  to  Alabama,  800  to  Kentucky,  600  to  Mississippi,  6,200  were  sent  to  North  Carolina,  and  1,700  were  sent  to  South  Carolina.  See  Letter  from  Jonathan  B.  Banks,  General  Attorney,  BellSouth, 


 to  Marlene  H.  Dortch,  Secretary,  Federal  Communications  Commission,  WC  Docket  No.  02-  150  at  3  (filed  Aug.  14,  2002)  (BellSouth  August  14  Banks  Ex  Parte  Letter). 


 1160  BellSouth  August  8  Ex  Parte  Letter  at  1.  See  also  Letter  from  Jonathan  B.  Banks,  General  Attorney, 
 BellSouth,  to  Marlene  H.  Dortch,  Secretary,  Federal  Communications  Commission,  WC  Docket  No.  02-  150  at  1  (filed  Aug.  23,  2002)  (BellSouth  August  23  Banks  Ex  Parte  Letter). 


 1161  Motion  of  AT&  T  Corp.  for  Emergency  Relief,  WC  Docket  No.  02-  150,  at  6-  7  (filed  Aug.  14,  2002)  (AT&  T 
 Emergency  Motion).  AT&  T  alleged  that  BellSouths  marketing  conduct  violated  sections  271(  a)  and  272(  g)(  2)  of  the  Act,  47  U.  S.  C.    271(  a),  272(  g)(  2). 
169
 Federal  Communications  Commission  FCC  02-  260 
 170 
 requested  the  Commission  to  direct  BellSouth  to  submit  a  sworn  statement  by  August  26,  2002  detailing  the  scope  of  the  mailings,  the  number  of  customer  inquiries  received  as  a  result,  how 
 these  inquiries  were  handled  by  customer  service  representatives,  what  remedial  steps  have  been  taken  to  correct  this  incident,  and  what  steps  have  been  taken  to  prevent  future  violations,  along 
 with  any  related  documentation.  1162 
 300.  Upon  learning  of  the  mailings,  BellSouth  notified  the  Commission  and  began  taking  corrective  action,  including  mailing  letters  to  affected  customers  to  inform  them  that  the 


 direct  mailings  and  bill  inserts  had  been  sent  erroneously  and  that  BellSouth  was  not  yet  authorized  to  provide  long  distance  service.  1163  BellSouth  also  began  developing  additional 
 internal  safeguards  to  prevent  incidents  of  this  nature  from  occurring  in  the  future.  1164  BellSouth  contends  that,  even  if  a  customer  were  to  call  to  request  long  distance  service  in  these  five  states, 
 its  customer  service  representatives  have  been  trained  to  respond  that  BellSouth  is  not  authorized  to  provide  such  service.  1165  Additionally,  BellSouth  claims  -  and  AT&  T  has  not  disputed  -  that,  if 
 a  customer  service  representative  were  to  submit  an  order  to  provide  BellSouth  long  distance  service  in  the  five  states  prior  to  Commission  approval  of  this  application,  any  long  distance  calls 
 placed  by  the  customer  would  be  blocked  and  would  not  go  through  because  the  long  distance  affiliate's  switching  equipment  has  not  been  modified  to  allow  such  calls  to  be  completed.  1166 


 301.  We  recognize  that  potential  violations  of  federal  telecommunications  law  could  be  relevant  to  the  section  271  inquiry.  1167  In  view  of  the  facts  presented  here,  however,  because 
 the  allegations  do  not  relate  to  the  openness  of  the  local  telecommunications  markets  to  competition,  we  reject  AT&  T's  argument  that  we  should  deny  or  delay  this  application  under  the 
 public  interest  standard.  1168  As  a  result,  we  take  no  position  on  the  validity  of  AT&  T's  sections 


 1162  Id.  at  7. 
 1163  BellSouth  August  14  Banks  Ex  Parte  Letter  at  4. 
 1164  Id.  See  also  BellSouth  August  23  Banks  Ex  Parte  Letter  at  1-  2.  BellSouth  says  that  it  has  retrained  personnel 
 in  its  advertising  group,  instituted  an  additional  check  on  all  promotional  mailings  concerning  BellSouth  long  distance  services,  designated  a  corporate  officer  to  be  specifically  responsible  for  the  proper  execution  of  all 


 promotional  mailings  for  long  distance,  and  will  include  a  statement  in  all  future  mailings  setting  out  the  states  where  BellSouth  has  been  approved  (or  not  approved)  by  the  Commission  to  provide  long  distance  service.  Id. 


 1165  Id.  at  1. 
 1166  Id. 
 1167  See  Ameritech  Michigan  Order,  12  FCC  Rcd  at  20749-  50,  para.  397  (  Because  the  success  of  the  market 
 opening  provisions  of  the  1996  Act  depend,  to  a  large  extent,  on  the  cooperation  of  incumbent  LECs,  including  the  BOCs,  with  new  entrants  and  good  faith  compliance  by  such  LECs  with  their  statutory  obligations,  evidence  that  a 


 BOC  has  engaged  in  a  pattern  of  discriminatory  conduct  or  disobeying  federal  and  state  telecommunications  regulations  would  tend  to  undermine  our  confidence  that  the  BOC's  local  market  is,  or  will  remain,  open  to 
 competition  once  the  BOC  has  received  interLATA  authority.). 
 1168  See,  e.  g.,  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  4126-  27,  para.  340;  Verizon  Massachusetts  Order,  16 
 FCC  Rcd  at  9107,  para.  211;  Verizon  New  Jersey  Order  at  para.  190. 
170
 Federal  Communications  Commission  FCC  02-  260 
 171 
 271(  a)  and  272(  g)  claims  here.  1169  Regardless  of  what  enforcement  action  we  may  take  in  the  future,  BOCs  should  not  market  long  distance  service  in  an  in-  region  state  prior  to  receiving 
 section  271  approval  from  the  Commission  for  that  particular  state,  and  should  implement  controls  to  prevent  such  marketing  from  taking  place.  We  remind  BellSouth  and  all  BOCs  to 
 exercise  caution  in  this  regard. 
 VIII.  SECTION  271(  d)(  6)  ENFORCEMENT  AUTHORITY 
 302.  Section  271(  d)(  6)  of  the  Act  requires  BellSouth  to  continue  to  satisfy  the  conditions  required  for  .  .  .  approval  of  its  section  271  application  after  the  Commission 


 approves  its  application.  1170  Thus,  the  Commission  has  a  responsibility  not  only  to  ensure  that  BellSouth  is  in  compliance  with  section  271  today,  but  also  that  it  remains  in  compliance  in  the 
 future.  As  the  Commission  has  already  described  the  post-  approval  enforcement  framework  and  its  section  271(  d)(  6)  enforcement  powers  in  detail  in  prior  orders,  it  is  unnecessary  to  do  so  again 
 here.  1171 
 303.  Working  with  each  of  the  state  commissions,  we  intend  to  closely  monitor  BellSouths  post-  approval  compliance  to  ensure  that  BellSouth  does  not  cease[]  to  meet  any  of 


 the  conditions  required  for  [section  271]  approval.  1172  We  stand  ready  to  exercise  our  various  statutory  enforcement  powers  quickly  and  decisively  in  appropriate  circumstances  to  ensure  that 
 the  local  market  remains  open  in  each  of  the  states. 
 304.  Consistent  with  prior  section  271  orders,  we  require  BellSouth  to  report  to  the  Commission  all  Alabama,  Kentucky,  Mississippi,  North  Carolina,  and  South  Carolina  Monthly 


 State  Summary  (MSS)  reports  and  the  MSS  Charts,  beginning  with  the  first  full  month  after  the  effective  date  of  this  Order,  and  for  each  month  thereafter  for  one  year,  unless  extended  by  the 
 Commission.  These  results  and  reports  will  allow  us  to  review  BellSouths  performance  on  an  ongoing  basis  to  ensure  continued  compliance  with  the  statutory  requirements.  We  are  confident 
 that  cooperative  state  and  federal  oversight  and  enforcement  can  address  any  backsliding  that  may  arise  with  respect  to  BellSouths  entry  into  Alabama,  Kentucky,  Mississippi,  North 
 Carolina,  and  South  Carolina. 


 1169  See  AT&  T  Emergency  Motion  at  1,  4-  5. 
 1170  47  U.  S.  C.    271(  d)(  6). 
 1171  See,  e.  g.,  SWBT  Kansas/  Oklahoma  Order,  16  FCC  Rcd  at  6382-  84,  paras.  283-  85;  SWBT  Texas  Order,  15 
 FCC  Rcd  at  18567-  68,  paras.  434-  36;  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  4174,  paras.  446-  53;  see  also  Appendix  H. 


 1172  47  U.  S.  C.    271(  d)(  6)(  A). 
171
 Federal  Communications  Commission  FCC  02-  260 
 172 
 IX.  CONCLUSION 
 305.  For  the  reasons  discussed  above,  we  grant  BellSouths  application  for  authorization  under  section  271  of  the  Act  to  provide  in-  region,  interLATA  services  in  the  states 


 of  Alabama,  Kentucky,  Mississippi,  North  Carolina,  and  South  Carolina. 
 X.  ORDERING  CLAUSES 
 306.  Accordingly,  IT  IS  ORDERED  that,  pursuant  to  sections  4(  i),  4(  j),  and  271  of  the  Communications  Act  of  1934,  as  amended,  47  U.  S.  C.    154(  i),  154(  j)  and  271,  BellSouths 


 application  to  provide  in-  region,  interLATA  service  in  the  states  of  Alabama,  Kentucky,  Mississippi,  North  Carolina,  and  South  Carolina,  filed  on  June  20,  2002,  IS  GRANTED. 


 307.  IT  IS  FURTHER  ORDERED  that  AT&  Ts  motion  for  emergency  relief,  filed  on  August  14,  2002,  IS  DENIED. 
 308.  IT  IS  FURTHER  ORDERED  that  this  Order  SHALL  BECOME  EFFECTIVE  September  27,  2002. 


 FEDERAL  COMMUNICATIONS  COMMISSION 
 Marlene  H.  Dortch  Secretary 
172
 Federal  Communications  Commission  FCC  02-  260 
 Appendix  A  Commenters  in  WC  Docket  No.  02-  150 


 Comments  Abbreviation 
 Alabama  Public  Service  Commission  Alabama  Commission  Alliance  for  Public  Technology  APT 
 AT&  T  Corp.  AT&  T  Birch  Telecom  of  the  South,  Inc.  Birch 
 Communications  Workers  of  America  CWA  Covad  Communications  Company  Covad 
 Ernest  Communications,  Inc.  Ernest  ITC^  Deltacom 
 Kentucky  Public  Service  Commission  Kentucky  Commission  KMC  Telecom  and  NuVox,  Inc.  KMC/  NuVox 
 North  Carolina  Utilities  Commission  North  Carolina  Commission  Mississippi  Public  Service  Commission  Mississippi  Commission 
 Public  Service  Commission  of  South  Carolina  South  Carolina  Commission  Southeast  Telephone 
 Supra  Technologies  Supra  US  LEC  Corp.  US  LEC 
 WorldCom  Inc.  WorldCom 


 Reply  Commenters 
 Replies  Abbreviation 
 Alabama  Public  Service  Commission  Alabama  Commission  AT&  T  Corp.  AT&  T 
 BellSouth  Corp.  BellSouth  Birch  Telecom  of  the  South,  Inc.  Birch 
 Mississippi  Public  Service  Commission  Mississippi  Commission  NewSouth  Communications,  Corp.  NewSouth 
 South  Carolina  Public  Service  Commission  South  Carolina  Commission  US  LEC  Corp.  US  LEC 
 WorldCom,  Inc.  WorldCom 
173
 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Appendix 
 B 


 Alabama 
 Performance 


 Metrics 


 Except 
 where 
 noted, 
 the 
 data 


 included 


 here 
 is 
 taken 


 from 
 the 
 Alabama 


 Monthly 
 State 
 Summary 


 (MSS) 
 Reports 


 provided 


 by 


 BellSouth, 
 calculated 
 according 
 to 
 the 


 Georgia 


 Service 
 Quality 
 Measurement 


 (SQM) 
 business 


 rules. 
 This 
 table 


 is 
 provided 


 as 
 a 


 reference 
 tool 
 for 
 the 
 convenience 


 of 
 the 


 reader. 


 No 
 conclusions 


 are 
 to 
 be 
 drawn 


 from 
 the 
 raw 


 data 
 contained 


 in 
 this 


 table. 


 Our 


 analysis 
 is 
 based 


 on 
 the 
 totality 


 of 
 the 
 circumstances, 


 such 
 that 
 we 
 may 


 use 
 non-  metric 


 evidence, 
 and 
 may 


 rely 
 more 


 heavily 


 on 
 some 


 metrics 
 more 
 than 
 others, 


 in 
 making 


 our 
 determination. 


 The 
 inclusion 


 of 
 these 


 particular 


 metrics 
 in 
 this 


 table 


 does 
 not 
 necessarily 


 mean 
 that 
 we 
 relied 


 on 
 all 
 of 
 these 


 metrics, 


 or 
 that 


 other 


 metrics 


 may 
 not 
 also 


 be 
 important 


 in 
 our 


 analysis. 


 Some 
 metrics 


 that 
 we 
 have 


 relied 
 on 
 in 
 the 


 past 


 and 
 may 


 rely 
 on 
 for 


 a 
 future 


 application 


 were 
 not 
 included 


 here 
 because 


 there 
 was 
 no 
 data 


 provided 


 for 
 them 


 (usually 
 either 
 because 


 there 
 was 
 no 
 activity, 


 or 
 because 


 the 
 metrics 


 are 
 still 


 under 


 development). 


 Metrics 
 with 
 no 
 retail 


 analog 


 provided 


 are 
 usually 


 compared 


 with 
 a 
 benchmark. 


 Note 
 that 
 for 
 some 


 metrics 


 during 
 the 
 period 


 provided 
 there 
 may 
 be 
 changes 


 in 
 the 


 metric 


 definition, 


 or 
 changes 


 in 
 the 


 retail 


 analog 


 applied, 


 making 
 it 
 difficult 


 to 
 compare 


 data 


 Note: 
 All 
 data 


 was 
 calculated 


 using 
 BellSouth's 


 data 
 platform 


 PMAP 
 4.0. 
 The 
 March 


 data 
 in 
 this 


 appendix 


 were 
 not 
 taken 


 from 
 the 


 MSS 
 reports, 


 which 
 for 
 that 


 month 


 were 
 calculated 


 using 
 PMAP 


 2.6, 
 but 
 instead 


 were 
 calculated 


 using 
 PMAP 


 4.0 
 by 
 BellSouth. 


 This 


 data 
 also 
 conforms 


 to 
 the 


 Georgia 


 Service 
 Quality 
 Measurement 


 business 
 rules 
 that 
 govern 


 the 
 regular 


 MSS 
 reports. 
174
 Metric  No. 
 SQM 
 No. 
 Metric 


 Name 


 Metric  No. 
 SQM 
 No. 
 Metric 


 Name 


 RESALE 
 A.  3.5 
 M&  R- 
 5 
 Out 


 of 
 Service 


 > 
 24 


 hours 


 Ordering 
 Billing 
 A.  1.1 
 O-  7 


 % 
 Rejected 


 Service 
 Requests 


  
 Mech. 


 A.  4.1 
 B-  1 


 Invoice 
 Accuracy 


 A.  1.2 
 O-  7 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Partially 


 Mech. 


 A.  4.2 
 B-  2 


 Mean 
 Time 
 to 
 Deliver 


 Invoices 


  
 CRIS 


 A.  1.3 
 O-  7 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Non-  Mech. 


 UNBUNDLED 
 NETWORK 
 ELEMENTS 


 A.  1.4 
 O-  8 


 Reject 
 Interval 


  
 Mech. 


 Ordering 


 A.  1.7 
 O-  8 


 Reject 
 Interval 


 - 
 Partially 


 Mech. 
  
 10 


 hours 


 B.  1.1 
 O-  7/ 
 O-  13 


 % 
 Rejected 


 Service 
 Requests 


  
 Mech. 


 A.  1.8 
 O-  8 


 Reject 
 Interval 


 - 
 Non-  Mech. 


 B.  1.2 
 O-  7/ 
 O-  13 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Partially 


 Mech. 


 A.  1.9 
 O-  9 


 FOC 
 Timeliness 


  
 Mech. 


 B.  1.3 
 O-  7/ 
 O-  13 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Non-  Mech. 


 A.  1.12 
 O-  9 


 FOC 
 Timeliness 


 - 
 Partially 


 Mech. 
 - 
 10 


 hours 


 B.  1.4 
 O-  8/ 
 O-  14 


 Reject 


 Interval 


  
 Mech. 


 A.  1.13 
 O-  9 


 FOC 
 Timeliness 


 - 
 Non-  Mech. 


 B.  1.7 
 O-  8/ 
 O-  14 


 Reject 


 Interval 


 - 
 Partially 


 Mech. 
 - 
 10 


 hours 


 A.  1.14 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Mech. 


 B.  1.8 
 O-  8/ 
 O-  14 


 Reject 


 Interval 


 - 
 Non-  Mech. 


 A.  1.15 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Partially 


 Mech. 


 B.  1.9 
 O-  9/ 
 O-  15 


 FOC 
 Timeliness 


  
 Mech. 


 A.  1.16 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Non-  Mech. 


 B.  1.12 
 O-  9/ 
 O-  15 


 FOC 
 Timeliness 


 - 
 Partially 


 Mech. 
 - 
 10 


 hours 


 Provisioning 
 B.  1.13 
 O-  9/ 
 O-  15 


 FOC 
 Timeliness 


 - 
 Non-  Mech. 


 A.  2.1 
 P-  4 


 Order 
 Completion 


 Interval 


 B.  1.14 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


  
 Mech. 


 A.  2.4 
 P-  2 


 % 
 Jeopardies 


 - 
 Mech. 


 B.  1.15 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


  
 Partially 


 Mech. 


 A.  2.5 
 P-  2 


 % 
 Jeopardies 


 - 
 Non-  Mech. 


 B.  1.16 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


  
 Non-  Mech. 


 A.  2.7 
 P-  2 


 Average 
 Jeopardy 
 Notice 
 Interval 


 - 
 Mech. 


 Provisioning 


 A.  2.8 
 P-  2 


 Average 
 Jeopardy 
 Notice 
 Interval 


 - 
 Non-  Mech. 


 B.  2.1 
 P-  4 


 Order 
 Completion 


 Interval 


 A.  2.9 
 P-  2 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Mech. 


 B.  2.2 
 P-  4 


 Order 
 Completion 


 Interval 
 within 
 X 
 days 


 - 
 xDSL 


 A.  2.10 
 P-  2 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Non-  Mech. 


 B.  2.5 
 P-  2 


 % 
 Jeopardies 


  
 Mech. 


 A.  2.11 
 P-  3 


 % 
 Missed 


 Installation 


 Appointments 


 B.  2.6 
 P-  2 


 % 
 Jeopardies 


 - 
 Non-  Mech. 


 A.  2.12 
 P-  9 


 % 
 Provisioning 


 Troubles 
 within 
 30 
 Days 


 B.  2.8 
 P-  2 


 Average 
 Jeopardy 
 Notice 
 Interval 


 - 
 Mech. 


 A.  2.14 
 P-  5 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Mech. 


 B.  2.9 
 P-  2 


 Average 
 Jeopardy 
 Notice 
 Interval 


 - 
 Non-  Mech. 


 A.  2.15 
 P-  5 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Non-  Mech. 


 B.  2.10 
 P-  2 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Mech. 


 A.  2.25 
 P-  11 


 Service 
 Order 
 Accuracy 


 B.  2.11 
 P-  2 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Non-  Mech. 


 Maintenance 
 and 
 Repair 


 B.  2.12 
 P-  7 
 Coordinated 


 Customers 
 Conversions 


 A.  3.1 
 M&  R- 
 1 
 Missed 


 Repair 
 Appointments 


 B.  2.13 
 P-  7A 


 % 
 Hot 


 Cuts 


 > 
 15 


 minutes 


 Early 


 A.  3.2 
 M&  R- 
 2 
 Customer 


 Trouble 
 Report 
 Rate 


 B.  2.14 
 P-  7A 


 Hot 
 Cut 
 Timeliness 


 A.  3.3 
 M&  R- 
 3 
 Maintenance 


 Average 
 Duration 


 B.  2.15 
 P-  7A 


 % 
 Hot 


 Cuts 


 > 
 15 


 minutes 


 Late 


 A.  3.4 
 M&  R- 
 4 
 % 
 Repeat 


 Troubles 


 within 
 30 
 Days 


 B.  2.16 
 P-  7B 


 Average 
 Recovery 


 Time 
  
 CCC 


 PERFORMANCE 
 METRIC 
 CATEGORIES 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 B-  2 
175
 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Metric  No. 
 SQM 
 No. 
 Metric 


 Name 


 Metric  No. 
 SQM 
 No. 
 Metric 


 Name 


 B.  2.17 
 P-  7C 


 % 
 Provisioning 


 Troubles 
 within 
 7 
 Days 


 - 
 Hot 


 Cuts 


 C.  3.3 
 M&  R- 
 3 
 Maintenance 


 Average 
 Duration 


 B.  2.18 
 P-  3/ 
 P-  12 


 % 
 Missed 


 Installation 


 Appointments 


 C.  3.4 
 M&  R- 
 4 
 % 
 Repeat 


 Troubles 


 within 
 30 
 Days 


 B.  2.19 
 P-  9 


 % 
 Provisioning 


 Troubles 
 within 
 30 
 Days 


 C.  3.5 
 M&  R- 
 5 
 Out 


 of 
 Service 


 > 
 24 


 hours 


 B.  2.21 
 P-  5 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Mech. 


 Billing 


 B.  2.22 
 P-  5 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Non-  Mech. 


 C.  4.1 
 B-  1 


 Invoice 
 Accuracy 


 B.  2.34 
 P-  11 


 Service 
 Order 
 Accuracy 


 C.  4.2 
 B-  2 


 Mean 
 Time 
 to 
 Deliver 


 Invoices 


 - 
 CABS 


 Maintenance 
 and 
 Repair 


 Trunk 
 Blocking 


 B.  3.1 
 M&  R- 
 1 
 Missed 


 Repair 
 Appointments 


 C.  5.1 
 TGP-  1 


 Trunk 
 Group 
 Performance 


 - 
 Aggregate 


 B.  3.2 
 M&  R- 
 2 
 Customer 


 Trouble 
 Report 
 Rate 


 OPERATIONS 
 SUPPORT 
 SYSTEMS 


 B.  3.3 
 M&  R- 
 3 
 Maintenance 


 Average 
 Duration 


 Pre-  Ordering 


 B.  3.4 
 M&  R- 
 4 
 % 
 Repeat 


 Troubles 


 within 
 30 
 Days 


 D.  1.1 
 OSS-  2 


 % 
 Interface 


 Availability 


 - 
 CLEC 


 B.  3.5 
 M&  R- 
 5 
 Out 


 of 
 Service 


 > 
 24 


 hours 


 D.  1.2 
 OSS-  2 


 % 
 Interface 


 Availability 


 - 
 BST 


 & 
 CLEC 


 Billing 
 D.  1.3 
 OSS-  1 


 Average 
 Response 


 Interval 
 - 
 CLEC 


 (LENS) 


 B.  4.1 
 B-  1 


 Invoice 
 Accuracy 


 D.  1.4 
 OSS-  1 


 Average 
 Response 


 Interval 
 - 
 CLEC 


 (TAG) 


 B.  4.2 
 B-  2 


 Mean 
 Time 
 to 
 Deliver 


 Invoices 


 - 
 CRIS 


 Maintenance 
 and 
 Repair 


 LOCAL 
 INTERCONNECTION 


 TRUNKS 


 D.  2.1 
 OSS-  3 


 % 
 Interface 


 Availability 


 - 
 BST 


 Ordering 
 D.  2.2 
 OSS-  3 


 % 
 Interface 


 Availability 


 - 
 CLEC 


 C.  1.1 
 O-  7 


 % 
 Rejected 


 Service 
 Requests 


 D.  2.3 
 OSS-  3 


 % 
 Interface 


 Availability 


 - 
 BST 


 & 
 CLEC 


 C.  1.2 
 O-  8 


 Reject 
 Interval 


 D.  2.4 
 OSS-  4 


 Average 
 Response 


 Interval 
 <= 
 4 
 Seconds 


 C.  1.3 
 O-  9 


 FOC 
 Timeliness 


 D.  2.5 
 OSS-  4 


 Average 
 Response 


 Interval 
 <= 
 10 
 Seconds 


 C.  1.4 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 D.  2.6 
 OSS-  4 


 Average 
 Response 


 Interval 
 > 
 10 


 Seconds 


 Provisioning 
 COLLOCATION 
 C.  2.1 
 P-  4 


 Order 
 Completion 


 Interval 


 Collocation 


 C.  2.2 
 P-  1 


 Held 
 Orders 


 E.  1.1 
 C-  1 


 Average 
 Response 


 Time 


 C.  2.3 
 P-  2 


 % 
 Jeopardies 


 E.  1.2 
 C-  2 


 Average 
 Arrangement 


 Time 


 C.  2.5 
 P-  3 


 % 
 Missed 


 Installation 


 Appointments 


 E.  1.3 
 C-  3 


 % 
 Due 


 Dates 


 Missed 


 C.  2.6 
 P-  9 


 % 
 Provisioning 


 Troubles 
 within 
 30 
 Days 


 GENERAL 


 C.  2.7 
 P-  5 


 Average 
 Completion 


 Notice 
 Interval 


 Flow 
 Through 


 C.  2.8 
 P-  10 


 Total 
 Service 


 Order 
 Cycle 
 Time 


 F.  1.1 
 O-  3 


 % 
 Flow 


 Through 


 Service 
 Requests 


 C.  2.10 
 P-  6 


 % 
 Completions 


 w/  o 
 Notice 


 or 
 < 
 24 


 hours 


 F.  1.2 
 O-  3 


 % 
 Flow 


 Through 


 Service 
 Requests 


 - 
 Achieved 


 C.  2.11 
 P-  11 


 Service 
 Order 
 Accuracy 


 F.  1.3 
 O-  3 


 % 
 Flow 


 Through 


 Service 
 Requests 


 - 
 LNP 


 Maintenance 
 and 
 Repair 


 Pre-  Ordering 


 C.  3.1 
 M&  R- 
 1 
 Missed 


 Repair 
 Appointments 


 F.  2.1 
 PO-  1 


 Loop 
 Makeup 


 Inquiry 
 (Manual) 


 C.  3.2 
 M&  R- 
 2 
 Customer 


 Trouble 
 Report 
 Rate 


 F.  2.2 
 PO-  2 


 Loop 
 Makeup 


 Inquiry 
 (Electronic) 


 B-  3 
176
 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Metric  No. 
 SQM 
 No. 
 Metric 


 Name 


 Metric  No. 
 SQM 
 No. 
 Metric 


 Name 


 Ordering 
 Database 
 Updates 


 F.  4.1 
 O-  12 


 Average 
 Speed 
 of 
 Answer 


 F.  13.1 
 D-  1 


 Average 
 Database 
 Update 
 Interval 


 Maintenance 
 Center 


 F.  13.2 
 D-  2 


 % 
 Update 


 Accuracy 


 F.  5.1 
 M&  R- 
 6 
 Average 


 Answer 
 Time 


 F.  13.3 
 D-  3 


 % 
 NXXs 


 / 
 LRNs 


 Loaded 


 by 
 LERG 


 Effective 


 Date 


 Operator 
 Services 
 (Toll) 


 Network 
 Outage 
 Notification 


 F.  6.1 
 OS-  1 


 Average 
 Speed 
 to 
 Answer 


 F.  14.1 
 M&  R- 
 7 
 Mean 


 Time 
 to 
 Notify 


 CLEC 
 of 
 Major 


 Network 


 Outages 


 F.  6.2 
 OS-  2 


 % 
 Answered 


 in 
 10 
 seconds 


 Directory 
 Assistance  F.  7.1  DA-  1  Average 


 Speed 
 to 
 Answer 


 F.  7.2 
 DA-  2 


 % 
 Answered 


 in 
 10 
 seconds 


 Billing  F.  9.1 
 B-  3 


 Usage 
 Data 
 Delivery 


 Accuracy 


 F.  9.2 
 B-  5 


 Usage 
 Data 
 Delivery 


 Timeliness 


 F.  9.3 
 B-  4 


 Usage 
 Data 
 Delivery 


 Completeness 


 F.  9.4 
 B-  6 


 Mean 
 Time 
 to 
 Deliver 


 Usage 


 F.  9.5 
 B-  7 


 Recurring 
 Charge 
 Completeness 


 F.  9.6 
 B-  8 


 Non-  Recurring 


 Charge 
 Completeness 


 Change 
 Management  F.  10.1  CM-  1  % 


 Software 
 Release 
 Notices 
 Sent 
 On 
 Time 


 F.  10.2 
 CM-  2 


 Average 
 Software 
 Release 
 Notice 
 Delay 
 Days 


 F.  10.3 
 CM-  3A 


 % 
 Change 


 Management 


 Documentation 


 Sent 
 On 
 Time 


 F.  10.4 
 CM-  3B 


 % 
 Change 


 Management 


 Documentation 


 (Defects, 


 Corrections, 
 etc.  ) 
 Sent 
 On 
 Time 


 F.  10.5 
 CM-  4 


 Average 
 Documentation 


 Release 
 Delay 
 Days 


 F.  10.6 
 CM-  5 


 % 
 CLEC 


 Interface 


 Outages 
 Sent 
 within 


 15 
 Minutes 


 New 
 Business 


 Requests 


 F.  11.1 
 BFR-  1 


 % 
 New 


 Business 


 Requests 
 Processed 


 in 
 30 


 Bus. 


 Days 


 F.  11.2 
 BFR-  2A 


 % 
 Quotes 


 Provided 


 within 
 X 
 Business 


 Days 


 Ordering  F.  12.1 
 O-  1 
 Acknowledgement 


 Message 
 Timeliness 


 F.  12.2 
 O-  2 
 Acknowledgement 


 Message 
 Completeness 


 B-  4 
177
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 RESALE 
 - 
 ORDERING  %  Rejected 


 Service 
 Requests 


 - 
 Mechanized 


 [O-  7] 


 A.  1.1.1 
 Residence/  AL 
 (%) 


 8.67% 
 6.92% 
 6.71% 
 7.50% 


 A.  1.1.2 
 Business/  AL 
 (%) 


 20.54% 
 28.42% 
 26.09% 
 28.24% 


 A.  1.1.4 
 PBX/  AL 
 (%) 


 0.00% 
 50.00% 


 1,2 


 A.  1.1.6 
 ISDN/  AL 
 (%) 


 0.00% 


 1 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Partially 


 Mechanized 


 [O-  7] 


 A.  1.2.1 
 Residence/  AL 
 (%) 


 17.58% 
 17.03% 
 21.84% 
 29.48% 


 A.  1.2.2 
 Business/  AL 
 (%) 


 43.92% 
 40.63% 
 58.33% 
 49.41% 


 A.  1.2.4 
 PBX/  AL 
 (%) 


 66.67% 
 0.00% 
 100.00% 


 0.00% 
 1,2,3,4 


 A.  1.2.6 
 ISDN/  AL 
 (%) 


 0.00% 
 0.00% 
 1,3 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Non-  Mechanized 


 [O-  7] 


 A.  1.3.1 
 Residence/  AL 
 (%) 


 41.28% 
 34.67% 
 31.47% 
 39.05% 


 A.  1.3.2 
 Business/  AL 
 (%) 


 54.07% 
 57.32% 
 59.90% 
 60.11% 


 A.  1.3.3 
 Desi 
 gn 
 (Specials)/  AL(%) 


 30.88% 
 34.92% 
 20.00% 
 29.41% 


 A.  1.3.4 
 PBX/  AL 
 (%) 


 54.55% 
 28.57% 
 33.33% 
 70.00% 
 2 


 A.  1.3.5 
 Centrex/  AL 
 (%) 


 0.00% 
 75.00% 
 42.86% 
 56.25% 
 1,2 


 A.  1.3.6 
 ISDN/  AL 
 (%) 


 50.00% 
 0.00% 
 50.00% 
 38.46% 
 1,2,3 


 Reject 
 Interval 


 - 
 Mechanized 


 [O-  8] 


 A.  1.4.1 
 Residence/  AL 
 (%) 


 95.72% 
 95.61% 
 94.43% 
 98.13% 


 A.  1.4.2 
 Business/  AL 
 (%) 


 100.00% 
 88.46% 
 97.92% 
 95.83% 


 A.  1.4.4 
 PBX/  AL 
 (%) 


 0.00% 
 2 


 Reject 
 Interval 


 - 
 Partially 


 Mechanized 


 - 
 10 


 hours 


 [O-  8] 


 A.  1.7.1 
 Residence/  AL 
 (%) 


 95.74% 
 94.98% 
 85.96% 
 94.22% 


 A.  1.7.2 
 Business/  AL 
 (%) 


 91.76% 
 98.46% 
 97.03% 
 98.85% 


 A.  1.7.4 
 PBX/  AL 
 (%) 


 50.00% 
 0.00% 
 100.00% 


 1,2,3 


 A.  1.7.6 
 ISDN/  AL 
 (%) 


 0.00% 
 2 


 Reject 
 Interval 


 - 
 Non-  Mechanized 


 [O-  8] 


 A.  1.8.1 
 Residence/  AL 
 (%) 


 95.65% 
 100.00% 


 98.00% 
 100.00% 


 A.  1.8.2 
 Business/  AL 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 97.27% 


 A.  1.8.3 
 Desi 
 gn 
 (Specials)/  AL(%) 


 95.45% 
 100.00% 
 100.00% 
 100.00% 
 3 


 A.  1.8.4 
 PBX/  AL 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3 


 A.  1.8.5 
 Centrex/  AL 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 June 


 March 
 May 
 April 


 Alabama 
 Performance 


 Metric 
 Data 


 B-  5 
178
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 June 


 March 
 May 
 April 


 Alabama 
 Performance 


 Metric 
 Data 


 A.  1.8.6 
 ISDN/  AL(%) 


 100.00% 
 100.00% 
 100.00% 
 1,3,4 


 FOC 
 Timeliness 


 - 
 Mechanized 


 [O-  9] 


 A.  1.9.1 
 Residence/  AL 
 (%) 


 99.85% 
 99.66% 
 99.22% 
 99.84% 


 A.  1.9.2 
 Business/  AL 
 (%) 


 99.29% 
 100.00% 


 99.12% 
 100.00% 


 A.  1.9.4 
 PBX/  AL 
 (%) 


 100.00% 
 100.00% 


 1,2 


 FOC 
 Timeliness 


 - 
 Partially 


 Mechanized 


 - 
 10 


 hours 


 [O-  9] 


 A.  1.12.1 
 Residence/  AL 
 (%) 


 92.43% 
 94.12% 
 86.76% 
 90.11% 


 A.  1.12.2 
 Business/  AL 
 (%) 


 93.91% 
 91.75% 
 86.73% 
 94.50% 


 A.  1.12.3 
 Desi 
 gn 
 (Specials)/  AL(%) 


 A.  1.12.4 
 PBX/  AL(%) 


 100.00% 
 50.00% 


 0.00% 
 1,2,4 


 A.  1.12.6 
 ISDN/  AL 
 (%) 


 0.00% 
 0.00% 
 1,3 


 FOC 
 Timeliness 


 - 
 Non-  Mechanized 


 [O-  9] 


 A.  1.13.1 
 Residence/  AL 
 (%) 


 98.51% 
 100.00% 
 100.00% 
 100.00% 


 A.  1.13.2 
 Business/  AL 
 (%) 


 98.31% 
 98.28% 
 100.00% 


 98.48% 


 A.  1.13.3 
 Desi 
 gn 
 (Specials)/  AL(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 A.  1.13.4 
 PBX/  AL 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 A.  1.13.5 
 Centrex/  AL 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,4 


 A.  1.13.6 
 ISDN/  AL 
 (%) 


 100.00% 
 87.50% 
 100.00% 
 100.00% 
 1,2,3,4 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Mechanized 


 [O-  11] 


 A.  1.14.1.1 
 Residence/  EDI/ 


 AL  (%) 


 100.00% 
 99.67% 
 98.41% 
 100.00% 


 A.  1.14.1.2 
 Residence/  TAG/ 


 AL  (%) 


 99.36% 
 99.65% 
 99.32% 
 99.99% 


 A.  1.14.2.1 
 Business/  EDI/ 
 AL 
 (%) 


 100.00% 
 100.00% 
 88.37% 
 100.00% 


 A.  1.14.2.2 
 Business/  TAG/ 


 AL 
 (%) 


 95.14% 
 97.73% 
 86.52% 
 100.00% 


 A.  1.14.4.2 
 PBX/  TAG/ 
 AL 
 (%) 


 100.00% 
 100.00% 


 1,2 


 A.  1.14.6.2 
 ISDN/  TAG/ 
 AL 
 (%) 


 0.00% 


 1 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Partially 


 Mechanized 


 [O-  11] 


 A.  1.15.1.1 
 Residence/  EDI/ 


 AL  (%) 


 100.00% 
 80.00% 
 100.00% 
 100.00% 
 4 


 A.  1.15.1.2 
 Residence/  TAG/ 


 AL  (%) 


 99.04% 
 98.64% 
 99.87% 
 99.89% 


 A.  1.15.2.1 
 Business/  EDI/ 
 AL 
 (%) 


 100.00% 
 100.00% 
 94.92% 
 100.00% 


 A.  1.15.2.2 
 Business/  TAG/ 


 AL 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 A.  1.15.4.2 
 PBX/  TAG/ 
 AL 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 A.  1.15.6.2 
 ISDN/  TAG/ 
 AL 
 (%) 


 100.00% 
 100.00% 
 1,3 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Non-  Mechanized 


 [O-  11] 
 B-  6 
179
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 June 


 March 
 May 
 April 


 Alabama 
 Performance 


 Metric 
 Data 


 A.  1.16.1 
 Residence/  AL(%) 


 95.41% 
 98.00% 
 97.20% 
 98.10% 


 A.  1.16.2 
 Business/  AL 
 (%) 


 97.78% 
 97.45% 
 94.55% 
 96.63% 


 A.  1.16.3 
 Desi 
 gn 
 (Specials)/  AL(%) 


 94.12% 
 100.00% 


 95.00% 
 100.00% 


 A.  1.16.4 
 PBX/  AL 
 (%) 


 100.00% 
 85.71% 
 83.33% 
 100.00% 
 2 


 A.  1.16.5 
 Centrex/  AL 
 (%) 


 100.00% 
 75.00% 
 90.48% 
 87.50% 
 1,2 


 A.  1.16.6 
 ISDN/  AL 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 92.31% 
 1,2,3 


 RESALE 
 - 
 PROVISIONING  Order  Completion 


 Interval 
 [P-  4] 


 A.  2.1.1.1.1 
 Residence/<  10 


 circuits/  Dis 
 patch/  AL( 
 days) 


 4.51 
 3.82 
 4.65 
 4.24 
 4.58 
 3.83 
 4.38 
 3.72 


 A.  2.1.1.1.2 
 Residence/<  10 


 circuits/  Non- 
 Dis  patch/ 
 AL( 
 days) 


 0.75 
 0.63 
 0.77 
 0.57 
 0.77 
 0.53 
 0.79 
 0.54 


 A.  2.1.1.2.1 
 Residence/>=  10 


 circuits/  Dis 
 patch/  AL( 
 days) 


 3.92 
 3.00 
 4.57 
 3.50 
 4.30 
 3.00 
 3.45 
 4.00 
 1,2,3,4 


 A.  2.1.2.1.1 
 Business/<  10 
 circuits/  Dis 
 patch/  AL( 
 days) 


 2.35 
 4.09 
 2.85 
 1.80 
 3.30 
 3.84 
 4.74 
 3.04 


 A.  2.1.2.1.2 
 Business/<  10 
 circuits/  Non- 
 Dis  patch/ 
 AL( 
 days) 


 1.29 
 2.47 
 1.34 
 1.02 
 1.31 
 0.85 
 1.31 
 0.64 


 A.  2.1.2.2.1 
 Business/>=  10 


 circuits/  Dis 
 patch/  AL( 
 days) 


 6.39 
 13.65 


 9.10 
 2.00 
 6.83 
 6.00 
 3,4 


 A.  2.1.2.2.2 
 Business/>=  10 


 circuits/  Non- 
 Dis  patch/ 
 AL( 
 days) 


 4.00 
 1.00 
 2.44 
 2.58 
 0.33 
 0.33 
 0.89 


 1,2,3 


 A.  2.1.3.1.1 
 Design 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 AL(  days) 
 27.63 
 8.00 
 19.26 


 1.67 
 17.08 


 8.50 
 16.31 


 13.00 
 1,2,3,4 


 A.  2.1.3.1.2 
 Design 
 (Specials)/<  10 


 circuits/  Non- 


 Dis 
 patch/  AL( 


 days) 


 4.23 
 3.00 
 8.70 
 5.23 
 7.68 
 4.00 
 12.43 


 4.57 
 3,4 


 A.  2.1.4.1.1 
 PBX/<  10 
 circuits/  Dis 


 patch/  AL( 
 days) 


 13.53 
 34.17 
 13.85 
 13.19 


 A.  2.1.4.1.2 
 PBX/<  10 
 circuits/  Non- 


 Dis 
 patch/  AL( 


 days) 


 2.44 
 1.78 
 3.25 
 5.04 
 1.47 
 0.56 
 3.15 
 4.05 
 1,2,3,4 


 A.  2.1.4.2.2 
 PBX/>=  10 
 circuits/  Non- 


 Dis  patch/ 
 AL( 
 days) 


 1.00 
 1.00 
 1.25 


 1.83 
 1.44 
 0.33 
 1,4 


 A.  2.1.5.1.2 
 Centrex/<  10 
 circuits/  Non- 
 Dis  patch/ 
 AL( 
 days) 


 1.38 


 1.18 
 1.63 
 3.08 
 1.54 
 7.00 


 4 


 A.  2.1.5.2.1 
 Centrex/>=  10 
 circuits/  Dis 
 patch/  AL( 
 days) 


 10.89 
 13.40 
 21.32 
 26.02 


 A.  2.1.6.1.1 
 ISDN/<  10 
 circuits/  Dis 
 patch/  AL( 
 days) 


 25.33 
 12.00 
 16.21 


 8.50 
 27.81 


 13.00 
 22.88 
 13.00 
 1,2,3,4 


 A.  2.1.6.1.2 
 ISDN/<  10 
 circuits/  Non- 


 Dis 
 patch/  AL( 


 days) 


 3.41 


 3.76 
 2.89 
 3.86 
 5.00 


 4 


 % 
 Jeopardies 


 - 
 Mechanized 


 [P-  2] 


 A.  2.4.1 
 Residence/  AL 
 (%) 


 0.39% 
 0.63% 
 0.39% 
 0.40% 
 0.31% 
 0.32% 
 0.31% 
 0.31% 


 A.  2.4.2 
 Business/  AL 
 (%) 


 1.11% 
 0.41% 
 1.65% 
 2.12% 
 1.66% 
 1.08% 
 1.37% 
 0.50% 


 A.  2.4.3 
 Desi 
 gn 
 (Specials)/  AL(%) 


 10.76% 
 12.18% 
 0.00% 
 12.79% 


 13.40% 


 2 


 A.  2.4.4 
 PBX/  AL 
 (%) 


 3.70% 
 0.00% 
 5.06% 
 0.00% 
 2.90% 


 7.25% 
 50.00% 


 1,2,4 


 A.  2.4.5 
 Centrex/  AL 
 (%) 


 3.27% 
 2.13% 
 2.85% 
 1.64% 
 0.00% 


 4 


 A.  2.4.6 
 ISDN/  AL 
 (%) 


 5.54% 
 4.91% 
 6.08% 
 10.06% 


 % 
 Jeopardies 


 - 
 Non-  Mechanized 


 [P-  2] 


 B-  7 
180
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 June 


 March 
 May 
 April 


 Alabama 
 Performance 


 Metric 
 Data 


 A.  2.5.1 
 Residence/  AL(%) 


 1.52% 
 2.66% 
 0.41% 
 0.46% 


 A.  2.5.2 
 Business/  AL 
 (%) 


 2.78% 
 0.00% 
 1.37% 
 0.00% 


 A.  2.5.3 
 Desi 
 gn 
 (Specials)/  AL(%) 


 27.27% 
 12.50% 
 18.18% 
 5.88% 


 A.  2.5.4 
 PBX/  AL 
 (%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3 


 A.  2.5.5 
 Centrex/  AL 
 (%) 


 0.00% 
 0.00% 
 0.00% 
 1,4 


 A.  2.5.6 
 ISDN/  AL 
 (%) 


 16.67% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3,4 


 Average 
 Jeopardy 


 Notice 
 Interval 


 - 
 Mechanized 


 [P-  2] 


 A.  2.7.1 
 Residence/  AL 
 (hours) 


 108.54 
 111.52 
 115.06 
 113.42 


 A.  2.7.2 
 Business/  AL 
 (hours) 


 134.77 
 124.88 


 48.05 
 49.25 
 1,2,3,4 


 A.  2.7.4 
 PBX/  AL 
 (hours) 


 173.20 
 4 


 Average 
 Jeopardy 


 Notice 
 Interval 


 - 
 Non-  Mechanized 


 [P-  2] 


 A.  2.8.1 
 Residence/  AL 
 (hours) 


 103.76 
 174.82 
 136.15 
 149.83 
 1,2,3,4 


 A.  2.8.2 
 Business/  AL 
 (hours) 


 243.97 
 520.22 
 1,3 


 A.  2.8.3 
 Desi 
 gn 
 (Specials)/  AL( 


 hours) 


 463.34 
 156.96 
 269.60 
 304.42 
 1,2,3,4 


 A.  2.8.4 
 PBX/  AL 
 (hours) 


 A.  2.8.6 
 ISDN/  AL( 
 hours) 


 184.37 


 1 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Mechanized 


 [P-  2] 


 A.  2.9.1 
 Residence/  AL 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 A.  2.9.2 
 Business/  AL 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 A.  2.9.4 
 PBX/  AL 
 (%) 


 100.00% 
 4 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Non-  Mechanized 


 [P-  2] 


 A.  2.10.1 
 Residence/  AL 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 A.  2.10.2 
 Business/  AL 
 (%) 


 100.00% 
 100.00% 
 1,3 


 A.  2.10.3 
 Desi 
 gn 
 (Specials)/  AL(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 A.  2.10.4 
 PBX/  AL 
 (%) 


 A.  2.10.6 
 ISDN/  AL(%) 


 100.00% 


 1 


 % 
 Missed 


 Installation 


 Appointments 


 [P-  3] 


 A.  2.11.1.1.1 
 Residence/<  10 


 circuits/  Dis 
 patch/  AL(%) 


 7.20% 
 3.21% 
 6.71% 
 4.88% 
 6.95% 
 3.65% 
 6.49% 
 3.85% 


 A.  2.11.1.1.2 
 Residence/<  10 


 circuits/  Non- 
 Dis  patch/ 
 AL(%) 


 0.09% 
 0.12% 
 0.01% 
 0.07% 
 0.02% 
 0.06% 
 0.01% 
 0.06% 


 A.  2.11.1.2.1 
 Residence/>=  10 


 circuits/  Dis 
 patch/  AL(%) 


 14.29% 
 0.00% 
 8.00% 
 50.00% 


 4.17% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3,4 


 A.  2.11.2.1.1 
 Business/<  10 
 circuits/  Dis 
 patch/  AL(%) 


 1.64% 
 14.10% 


 2.23% 
 2.08% 
 2.72% 
 1.85% 
 4.51% 
 0.00% 


 A.  2.11.2.1.2 
 Business/<  10 
 circuits/  Non- 
 Dis  patch/ 
 AL(%) 


 0.15% 
 0.00% 
 0.10% 
 0.00% 
 0.03% 
 0.49% 
 0.06% 
 0.94% 


 A.  2.11.2.2.1 
 Business/>=  10 


 circuits/  Dis 
 patch/  AL(%) 


 6.67% 
 2.78% 
 10.64% 
 0.00% 
 2.33% 
 0.00% 


 3,4 


 B-  8 
181
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 June 


 March 
 May 
 April 


 Alabama 
 Performance 


 Metric 
 Data 


 A.  2.11.2.2.2 
 Business/>=  10 


 circuits/  Non- 
 Dispatch/  AL(%) 


 0.00% 
 0.00% 
 33.33% 


 0.00% 
 0.00% 
 0.00% 
 0.00% 


 1,2,3 


 A.  2.11.3.1.1 
 Desi 
 gn 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 AL(%) 
 4.04% 
 22.22% 


 4.39% 
 0.00% 
 2.88% 
 0.00% 
 4.66% 
 14.29% 


 1,2,4 


 A.  2.11.3.1.2 
 Design 
 (Specials)/<  10 


 circuits/  Non- 
 Dispatch/  AL(%) 


 0.00% 
 0.00% 
 0.59% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 3 


 A.  2.11.4.1.1 
 PBX/<  10 
 circuits/  Dis 


 patch/  AL(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 


 A.  2.11.4.1.2 
 PBX/<  10 
 circuits/  Non- 


 Dis  patch/ 
 AL(%) 


 1.72% 
 0.00% 
 1.52% 
 0.00% 
 2.22% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3,4 


 A.  2.11.4.2.2 
 PBX/>=  10 
 circuits/  Non- 


 Dis  patch/ 
 AL(%) 


 0.00% 
 0.00% 
 0.00% 


 0.00% 
 0.00% 
 0.00% 


 1,4 


 A.  2.11.5.1.1 
 Centrex/<  10 
 circuits/  Dis 
 patch/  AL(%) 


 6.51% 
 1.62% 
 0.00% 
 2.99% 


 2.10% 


 2 


 A.  2.11.5.1.2 
 Centrex/<  10 
 circuits/  Non- 
 Dis  patch/ 
 AL(%) 


 0.00% 
 0.00% 
 0.00% 


 0.00% 
 0.00% 
 0.19% 
 0.00% 


 1 


 A.  2.11.5.2.1 
 Centrex/>=  10 
 circuits/  Dis 
 patch/  AL(%) 


 0.00% 
 0.00% 
 4.76% 
 0.00% 
 13.33% 


 3 


 A.  2.11.5.2.2 
 Centrex/>=  10 
 circuits/  Non- 
 Dis  patch/ 
 AL(%) 


 0.00% 
 0.00% 
 0.00% 


 0.00% 
 0.00% 
 1.75% 


 1,3 


 A.  2.11.6.1.1 
 ISDN/<  10 
 circuits/  Dis 
 patch/  AL(%) 


 8.67% 
 16.67% 


 7.87% 
 0.00% 
 5.06% 
 100.00% 


 4.23% 
 100.00% 


 1,2,3,4 


 A.  2.11.6.1.2 
 ISDN/<  10 
 circuits/  Non- 


 Dis 
 patch/  AL(%) 


 0.00% 
 0.00% 
 1.35% 
 0.00% 
 2.37% 


 3.33% 
 0.00% 
 1,2,4 


 % 
 Provisioning 


 Troubles 
 within 
 30 
 Days 


 [P-  9] 


 A.  2.12.1.1.1 
 Residence/<  10 


 circuits/  Dis 
 patch/  AL(%) 


 10.48% 
 8.87% 
 10.78% 


 8.73% 
 10.37% 
 10.77% 
 10.82% 
 11.36% 


 A.  2.12.1.1.2 
 Residence/<  10 


 circuits/  Non- 
 Dis  patch/ 
 AL(%) 


 2.81% 
 5.27% 
 2.98% 
 3.48% 
 2.65% 
 3.14% 
 2.51% 
 2.52% 


 A.  2.12.1.2.1 
 Residence/>=  10 


 circuits/  Dis 
 patch/  AL(%) 


 16.67% 
 23.81% 
 0.00% 
 8.00% 
 0.00% 
 4.17% 
 0.00% 
 2,3,4 


 A.  2.12.2.1.1 
 Business/<  10 
 circuits/  Dis 
 patch/  AL(%) 


 10.63% 
 4.48% 
 10.49% 


 7.69% 
 11.26% 


 4.17% 
 10.78% 
 11.11% 


 A.  2.12.2.1.2 
 Business/<  10 
 circuits/  Non- 
 Dis  patch/ 
 AL(%) 


 5.48% 
 6.67% 
 4.87% 
 3.88% 
 5.25% 
 6.41% 
 6.68% 
 4.85% 


 A.  2.12.2.2.1 
 Business/>=  10 


 circuits/  Dis 
 patch/  AL(%) 


 15.79% 
 23.33% 
 25.00% 
 23.40% 
 0.00% 


 4 


 A.  2.12.2.2.2 
 Business/>=  10 


 circuits/  Non- 
 Dis  patch/ 
 AL(%) 


 0.00% 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 50.00% 


 2,3,4 


 A.  2.12.3.1.1 
 Desi 
 gn 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 AL(%) 
 7.04% 
 24.00% 


 7.50% 
 33.33% 


 6.06% 
 0.00% 
 7.28% 
 7.69% 


 2,3 


 A.  2.12.3.1.2 
 Design 
 (Specials)/<  10 


 circuits/  Non- 
 Dispatch/  AL(%) 


 2.70% 
 0.00% 
 1.57% 
 8.33% 
 4.12% 
 0.00% 
 3.14% 
 0.00% 


 1,4 


 A.  2.12.4.1.1 
 PBX/<  10 
 circuits/  Dis 


 patch/  AL(%) 


 25.00% 
 50.00% 
 6.67% 


 0.00% 
 0.00% 


 1 


 A.  2.12.4.1.2 
 PBX/<  10 
 circuits/  Non- 


 Dis  patch/ 
 AL(%) 


 3.28% 
 0.00% 
 0.00% 
 0.00% 
 1.52% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3,4 


 A.  2.12.4.2.2 
 PBX/>=  10 
 circuits/  Non- 


 Dis  patch/ 
 AL(%) 


 10.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 0.00% 


 1,2 


 A.  2.12.5.1.1 
 Centrex/<  10 
 circuits/  Dis 
 patch/  AL(%) 


 5.42% 
 4.44% 
 4.86% 
 0.00% 
 5.43% 


 3 


 A.  2.12.5.1.2 
 Centrex/<  10 
 circuits/  Non- 
 Dis  patch/ 
 AL(%) 


 4.65% 
 0.00% 
 4.95% 
 0.00% 
 8.02% 


 2.99% 
 0.00% 


 1,2 


 A.  2.12.5.2.1 
 Centrex/>=  10 
 circuits/  Dis 
 patch/  AL(%) 


 35.71% 
 0.00% 
 11.11% 


 20.00% 
 19.05% 
 0.00% 
 1,4 


 A.  2.12.5.2.2 
 Centrex/>=  10 
 circuits/  Non- 
 Dis  patch/ 
 AL(%) 


 16.67% 


 17.65% 
 0.00% 
 12.50% 


 12.90% 
 0.00% 
 2,4 


 A.  2.12.6.1.1 
 ISDN/<  10 
 circuits/  Dis 
 patch/  AL(%) 


 4.14% 
 6.94% 
 0.00% 
 6.02% 
 0.00% 
 3.37% 
 100.00% 


 2,3,4 


 A.  2.12.6.1.2 
 ISDN/<  10 
 circuits/  Non- 


 Dis 
 patch/  AL(%) 


 0.58% 
 0.00% 
 1.52% 
 0.00% 
 0.45% 
 0.00% 
 0.00% 


 1,2,3 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Mechanized 


 [P-  5] 


 A.  2.14.1.1.1 
 Residence/<  10 


 circuits/  Dis 
 patch/  AL( 
 hours) 


 1.04 
 0.22 
 0.77 
 0.23 
 1.10 
 0.22 
 1.10 
 0.13 


 B-  9 
182
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 June 


 March 
 May 
 April 


 Alabama 
 Performance 


 Metric 
 Data 


 A.  2.14.1.1.2 
 Residence/<  10 


 circuits/  Non- 
 Dispatch/  AL( 
 hours) 


 0.51 
 0.53 
 0.50 
 0.53 
 0.55 
 0.59 
 0.58 
 0.60 


 A.  2.14.1.2.1 
 Residence/>=  10 


 circuits/  Dis 
 patch/  AL( 
 hours) 


 0.12 
 0.02 
 0.02 
 0.02 
 0.65 
 0.02 
 0.72 
 0.02 
 1,2,3,4 


 A.  2.14.2.1.1 
 Business/<  10 
 circuits/  Dis 
 patch/  AL( 
 hours) 


 1.40 
 1.77 
 2.05 
 0.22 
 1.76 
 2.06 
 2.44 
 0.22 


 A.  2.14.2.1.2 
 Business/<  10 
 circuits/  Non- 
 Dis  patch/ 
 AL( 
 hours) 


 1.51 
 2.57 
 2.09 
 0.47 
 2.43 
 0.51 
 1.26 
 0.53 


 A.  2.14.2.2.1 
 Business/>=  10 


 circuits/  Dis 
 patch/  AL( 
 hours) 


 2.17 
 1.90 
 1.81 
 0.02 
 3.93 


 3 


 A.  2.14.2.2.2 
 Business/>=  10 


 circuits/  Non- 
 Dis  patch/ 
 AL( 
 hours) 


 0.47 
 0.58 
 0.51 
 0.42 
 53.72 


 0.53 
 1,2 


 A.  2.14.3.1.1 
 Design 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 AL(  hours) 
 250.65 


 162.12 
 0.02 
 142.14 


 144.96 


 2 


 A.  2.14.4.1.2 
 PBX/<  10 
 circuits/  Non- 


 Dis 
 patch/  AL( 


 hours) 


 9.67 
 15.06 
 0.41 
 9.79 


 15.32 
 0.34 
 2,4 


 A.  2.14.4.2.2 
 PBX/>=  10 
 circuits/  Non- 


 Dis  patch/ 
 AL( 
 hours) 


 0.45 
 0.47 
 0.58 


 0.41 
 0.46 


 1 


 A.  2.14.5.1.2 
 Centrex/<  10 
 circuits/  Non- 
 Dis  patch/ 
 AL( 
 hours) 


 3.81 


 0.75 
 4.52 
 3.62 
 0.43 


 4 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Non-  Mechanized 


 [P-  5] 


 A.  2.15.1.1.1 
 Residence/<  10 


 circuits/  Dis 
 patch/  AL( 
 hours) 


 14.09 
 13.79 
 12.97 
 14.60 


 A.  2.15.1.1.2 
 Residence/<  10 


 circuits/  Non- 
 Dis  patch/ 
 AL( 
 hours) 


 5.56 
 5.99 
 10.43 


 6.56 


 A.  2.15.1.2.1 
 Residence/>=  10 


 circuits/  Dis 
 patch/  AL( 
 hours) 


 0.02 


 2 


 A.  2.15.2.1.1 
 Business/<  10 
 circuits/  Dis 
 patch/  AL( 
 hours) 


 46.61 
 17.56 
 31.27 
 26.66 


 A.  2.15.2.1.2 
 Business/<  10 
 circuits/  Non- 
 Dis  patch/ 
 AL( 
 hours) 


 12.32 
 13.65 
 12.93 
 11.19 


 A.  2.15.2.2.1 
 Business/>=  10 


 circuits/  Dis 
 patch/  AL( 
 hours) 


 14.90 
 4 


 A.  2.15.2.2.2 
 Business/>=  10 


 circuits/  Non- 
 Dis  patch/ 
 AL( 
 hours) 


 14.00 
 19.90 


 2,3 


 A.  2.15.3.1.1 
 Design 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 AL(  hours) 


 37.74 
 111.74 


 98.95 
 511.30 
 1,2,4 


 A.  2.15.3.1.2 
 Design 
 (Specials)/<  10 


 circuits/  Non- 


 Dis 
 patch/  AL( 


 hours) 


 29.82 
 62.85 
 85.27 
 23.61 
 3 


 A.  2.15.4.1.1 
 PBX/<  10 
 circuits/  Dis 


 patch/  AL( 
 hours) 


 A.  2.15.4.1.2 
 PBX/<  10 
 circuits/  Non- 


 Dispatch/  AL( 
 hours) 


 12.38 
 18.69 
 21.73 
 24.29 
 1,2,3,4 


 A.  2.15.4.2.2 
 PBX/>=  10 
 circuits/  Non- 


 Dis  patch/ 
 AL( 
 hours) 


 14.00 
 4 


 A.  2.15.5.1.1 
 Centrex/<  10 
 circuits/  Dis 
 patch/  AL( 
 hours) 


 0.02 
 2 


 A.  2.15.5.1.2 
 Centrex/<  10 
 circuits/  Non- 
 Dis  patch/ 
 AL( 
 hours) 


 14.00 


 14.00 
 13.19 
 1,4 


 A.  2.15.5.2.1 
 Centrex/>=  10 
 circuits/  Dis 
 patch/  AL( 
 hours) 


 0.02 
 3 


 A.  2.15.5.2.2 
 Centrex/>=  10 
 circuits/  Non- 
 Dis  patch/ 
 AL( 
 hours) 


 14.00 


 0.30 
 1,3 


 A.  2.15.6.1.1 
 ISDN/<  10 
 circuits/  Dis 
 patch/  AL( 
 hours) 


 28.10 
 82.86 
 92.12 
 16.43 
 1,2,3,4 


 A.  2.15.6.1.2 
 ISDN/<  10 
 circuits/  Non- 


 Dis 
 patch/  AL( 


 hours) 


 40.37 
 15.17 


 14.00 
 1,2,4 


 Service 
 Order 
 Accuracy 


 [P-  11] 


 A.  2.25.1.1.1 
 Residence/<  10 


 circuits/  Dis 
 patch/  AL(%) 


 92.14% 
 96.55% 
 90.77% 
 98.86% 


 A.  2.25.1.1.2 
 Residence/<  10 


 circuits/  Non- 
 Dis  patch/ 
 AL(%) 


 95.38% 
 94.29% 
 98.82% 
 98.56% 


 B-  10 
183
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 June 


 March 
 May 
 April 


 Alabama 
 Performance 


 Metric 
 Data 


 A.  2.25.1.2.1 
 Residence/>=  10 


 circuits/  Dispatch/ 


 AL(%) 


 100.00% 
 88.24% 
 100.00% 
 100.00% 
 4 


 A.  2.25.2.1.1 
 Business/<  10 
 circuits/  Dis 
 patch/  AL(%) 


 91.33% 
 95.76% 
 88.82% 
 94.44% 


 A.  2.25.2.1.2 
 Business/<  10 
 circuits/  Non- 
 Dis  patch/ 
 AL(%) 


 93.85% 
 97.93% 
 96.11% 
 97.22% 


 A.  2.25.2.2.1 
 Business/>=  10 


 circuits/  Dis 
 patch/  AL(%) 


 100.00% 
 77.78% 
 77.78% 
 76.92% 
 2 


 A.  2.25.2.2.2 
 Business/>=  10 


 circuits/  Non- 
 Dis  patch/ 
 AL(%) 


 84.62% 
 97.56% 
 92.59% 
 91.89% 


 A.  2.25.3.1.1 
 Desi 
 gn 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 AL(%) 


 81.08% 
 91.43% 
 80.49% 
 96.47% 


 A.  2.25.3.1.2 
 Design 
 (Specials)/<  10 


 circuits/  Non- 
 Dispatch/  AL(%) 


 91.84% 
 94.78% 
 91.43% 
 91.36% 


 A.  2.25.3.2.1 
 Design 
 (Specials)/>=  10 


 circuits/  Dispatch/ 


 AL(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 A.  2.25.3.2.2 
 Design 
 (Specials)/>=  10 


 circuits/  Non- 
 Dispatch/  AL(%) 


 100.00% 
 90.00% 
 92.31% 
 88.89% 
 1,4 


 RESALE 
 - 
 MAINTENANCE 


 AND 
 REPAIR 


 Missed 
 Repair 
 Appointments 


 [M&  R- 
 1] 


 A.  3.1.1.1 
 Residence/  Dis 
 patch/  AL(%) 


 5.49% 
 2.28% 
 5.25% 
 1.96% 
 5.94% 
 2.56% 
 6.13% 
 1.73% 


 A.  3.1.1.2 
 Residence/  Non- 


 Dis  patch/ 
 AL(%) 


 1.02% 
 0.00% 
 1.12% 
 0.00% 
 1.14% 
 0.60% 
 1.44% 
 0.53% 


 A.  3.1.2.1 
 Business/  Dis 
 patch/  AL(%) 


 8.60% 
 6.94% 
 8.06% 
 2.04% 
 10.91% 
 12.90% 
 11.09% 
 19.05% 


 A.  3.1.2.2 
 Business/  Non- 


 Dis 
 patch/  AL(%) 


 3.68% 
 0.00% 
 2.53% 
 3.23% 
 3.09% 
 18.18% 


 3.23% 
 0.00% 


 A.  3.1.3.1 
 Desi 
 gn 
 (Specials)/  Dispatch/ 


 AL(%) 


 1.91% 
 0.00% 
 1.41% 
 0.00% 
 1.34% 
 0.00% 
 0.86% 
 0.00% 


 A.  3.1.3.2 
 Desi 
 gn 
 (Specials)/  Non- 


 Dispatch/  AL(%) 


 0.55% 
 0.00% 
 0.24% 
 0.00% 
 0.26% 
 0.00% 
 0.51% 
 3.57% 


 1 


 A.  3.1.4.1 
 PBX/  Dis 
 patch/  AL(%) 


 8.33% 
 33.33% 


 9.84% 
 0.00% 
 6.45% 
 0.00% 
 13.64% 
 91.67% 


 1,2 


 A.  3.1.4.2 
 PBX/  Non- 
 Dis 
 patch/  AL(%) 


 1.41% 
 0.00% 
 5.00% 
 0.00% 
 3.85% 
 0.00% 
 1.64% 
 0.00% 


 2,4 


 A.  3.1.5.1 
 Centrex/  Dis 
 patch/  AL(%) 


 14.73% 
 0.00% 
 21.51% 


 0.00% 
 17.87% 


 0.00% 
 15.96% 


 0.00% 


 A.  3.1.5.2 
 Centrex/  Non- 
 Dis  patch/ 
 AL(%) 


 7.00% 
 0.00% 
 3.83% 
 0.00% 
 6.49% 
 0.00% 
 2.88% 
 0.00% 


 1,3 


 A.  3.1.6.1 
 ISDN/  Dis 
 patch/  AL(%) 


 6.12% 
 0.00% 
 5.17% 
 0.00% 
 12.99% 


 0.00% 
 3.51% 
 0.00% 
 1,3,4 


 A.  3.1.6.2 
 ISDN/  Non- 
 Dis 
 patch/  AL(%) 


 1.47% 
 0.00% 
 0.90% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 33.33% 
 1,2,3,4 


 Customer 
 Trouble 
 Report 
 Rate 
 [M&  R- 


 2] 


 A.  3.2.1.1 
 Residence/  Dis 
 patch/  AL(%) 


 1.81% 
 1.93% 
 1.92% 
 1.86% 
 2.12% 
 2.03% 
 2.01% 
 2.03% 


 A.  3.2.1.2 
 Residence/  Non- 


 Dis  patch/ 
 AL(%) 


 1.04% 
 0.48% 
 0.98% 
 0.42% 
 1.18% 
 0.48% 
 1.21% 
 0.55% 


 A.  3.2.2.1 
 Business/  Dis 
 patch/  AL(%) 


 1.07% 
 1.08% 
 1.17% 
 0.74% 
 1.23% 
 0.98% 
 1.14% 
 1.34% 


 A.  3.2.2.2 
 Business/  Non- 


 Dis 
 patch/  AL(%) 


 0.61% 
 0.54% 
 0.57% 
 0.47% 
 0.68% 
 0.35% 
 0.70% 
 0.65% 


 A.  3.2.3.1 
 Desi 
 gn 
 (Specials)/  Dispatch/ 


 AL(%) 


 0.85% 
 0.91% 
 0.85% 
 1.48% 
 1.02% 
 1.59% 
 0.90% 
 0.93% 


 A.  3.2.3.2 
 Desi 
 gn 
 (Specials)/  Non- 


 Dispatch/  AL(%) 


 1.07% 
 0.33% 
 1.26% 
 0.52% 
 1.19% 
 0.82% 
 1.21% 
 1.37% 


 A.  3.2.4.1 
 PBX/  Dis 
 patch/  AL(%) 


 0.12% 
 0.32% 
 0.10% 
 0.20% 
 0.11% 
 2.12% 
 0.12% 
 1.22% 


 A.  3.2.4.2 
 PBX/  Non- 
 Dis 
 patch/  AL(%) 


 0.12% 
 0.00% 
 0.10% 
 0.20% 
 0.09% 
 0.00% 
 0.11% 
 0.30% 


 B-  11 
184
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 June 


 March 
 May 
 April 


 Alabama 
 Performance 


 Metric 
 Data 


 A.  3.2.5.1 
 Centrex/  Dispatch/ 


 AL(%) 


 0.29% 
 0.00% 
 0.35% 
 0.00% 
 0.32% 
 0.00% 
 0.32% 
 0.00% 


 A.  3.2.5.2 
 Centrex/  Non- 
 Dis  patch/ 
 AL(%) 


 0.26% 
 0.30% 
 0.26% 
 0.00% 
 0.31% 
 0.37% 
 0.29% 
 0.00% 


 A.  3.2.6.1 
 ISDN/  Dis 
 patch/  AL(%) 


 0.03% 
 0.27% 
 0.04% 
 0.00% 
 0.05% 
 0.58% 
 0.04% 
 0.34% 


 A.  3.2.6.2 
 ISDN/  Non- 
 Dis 
 patch/  AL(%) 


 0.09% 
 0.41% 
 0.08% 
 0.12% 
 0.10% 
 0.12% 
 0.08% 
 0.34% 


 Maintenance 
 Average 
 Duration 


 [M&  R- 
 3] 


 A.  3.3.1.1 
 Residence/  Dis 
 patch/  AL( 
 hours) 


 21.66 
 17.04 
 22.67 
 16.03 
 26.14 
 18.86 
 25.01 
 20.63 


 A.  3.3.1.2 
 Residence/  Non- 


 Dis  patch/ 
 AL( 
 hours) 


 8.82 
 4.67 
 8.77 
 4.27 
 11.07 


 5.75 
 10.65 


 6.12 


 A.  3.3.2.1 
 Business/  Dis 
 patch/  AL( 
 hours) 


 12.58 
 14.22 
 11.64 


 8.78 
 12.77 


 10.69 
 12.04 
 17.65 


 A.  3.3.2.2 
 Business/  Non- 


 Dis 
 patch/  AL( 


 hours) 


 4.29 
 2.08 
 3.76 
 2.84 
 4.20 
 4.00 
 3.92 
 7.27 


 A.  3.3.3.1 
 Desi 
 gn 
 (Specials)/  Dispatch/ 


 AL( 
 hours) 


 5.40 
 3.76 
 5.16 
 4.65 
 5.12 
 4.02 
 5.11 
 4.76 


 A.  3.3.3.2 
 Desi 
 gn 
 (Specials)/  Non- 


 Dispatch/  AL( 
 hours) 


 2.29 
 0.91 
 2.03 
 2.28 
 2.22 
 2.67 
 2.33 
 2.56 


 1 


 A.  3.3.4.1 
 PBX/  Dis 
 patch/  AL( 


 hours) 


 8.61 
 10.08 


 12.83 


 0.84 
 8.22 
 9.22 
 8.17 
 49.92 


 1,2 


 A.  3.3.4.2 
 PBX/  Non- 
 Dis 
 patch/  AL( 


 hours) 


 4.03 
 0.00 
 3.69 
 0.50 
 5.80 
 0.00 
 4.79 
 3.96 
 2,4 


 A.  3.3.5.1 
 Centrex/  Dis 
 patch/  AL( 
 hours) 


 14.78 
 0.00 
 12.27 


 0.00 
 13.25 


 0.00 
 12.21 


 0.00 


 A.  3.3.5.2 
 Centrex/  Non- 
 Dis 
 patch/  AL( 


 hours) 


 3.36 
 9.13 
 2.63 
 0.00 
 4.57 
 5.00 
 3.71 
 0.00 
 1,3 


 A.  3.3.6.1 
 ISDN/  Dis 
 patch/  AL( 
 hours) 


 7.76 
 2.14 
 8.58 
 0.00 
 10.65 


 4.44 
 8.61 
 2.89 
 1,3,4 


 A.  3.3.6.2 
 ISDN/  Non- 
 Dis 
 patch/  AL( 


 hours) 


 3.41 
 1.68 
 3.16 
 0.40 
 2.91 
 9.13 
 2.46 
 11.48 
 1,2,3,4 


 % 
 Repeat 


 Troubles 


 within 
 30 
 Days 


 [M&  R- 


 4] 


 A.  3.4.1.1 
 Residence/  Dis 
 patch/  AL(%) 


 16.35% 
 10.62% 
 18.02% 
 11.04% 
 17.84% 
 9.40% 
 18.04% 
 11.08% 


 A.  3.4.1.2 
 Residence/  Non- 


 Dis  patch/ 
 AL(%) 


 14.41% 
 11.11% 
 15.47% 
 13.04% 
 15.85% 
 9.04% 
 16.49% 
 13.83% 


 A.  3.4.2.1 
 Business/  Dis 
 patch/  AL(%) 


 14.40% 
 12.50% 
 12.49% 
 10.20% 
 14.16% 
 6.45% 
 12.18% 


 9.52% 


 A.  3.4.2.2 
 Business/  Non- 


 Dis 
 patch/  AL(%) 


 12.01% 
 11.11% 
 11.46% 
 19.35% 
 12.77% 
 0.00% 
 12.97% 
 12.20% 


 A.  3.4.3.1 
 Desi 
 gn 
 (Specials)/  Dispatch/ 


 AL(%) 


 22.53% 
 26.32% 
 21.34% 
 25.81% 
 20.54% 
 9.09% 
 22.72% 
 15.79% 


 A.  3.4.3.2 
 Desi 
 gn 
 (Specials)/  Non- 


 Dispatch/  AL(%) 


 18.98% 
 42.86% 
 15.09% 
 9.09% 
 13.92% 
 23.53% 
 15.54% 
 10.71% 


 1 


 A.  3.4.4.1 
 PBX/  Dis 
 patch/  AL(%) 


 11.11% 
 0.00% 
 11.48% 


 0.00% 
 4.84% 
 14.29% 


 3.03% 
 0.00% 


 1,2 


 A.  3.4.4.2 
 PBX/  Non- 
 Dis 
 patch/  AL(%) 


 7.04% 
 0.00% 
 3.33% 
 0.00% 
 5.77% 
 0.00% 
 4.92% 
 0.00% 


 2,4 


 A.  3.4.5.1 
 Centrex/  Dis 
 patch/  AL(%) 


 16.10% 
 0.00% 
 15.41% 


 0.00% 
 13.17% 


 0.00% 
 13.03% 


 0.00% 


 A.  3.4.5.2 
 Centrex/  Non- 
 Dis  patch/ 
 AL(%) 


 15.95% 
 0.00% 
 14.56% 


 0.00% 
 13.96% 


 0.00% 
 11.51% 


 0.00% 
 1,3 


 A.  3.4.6.1 
 ISDN/  Dis 
 patch/  AL(%) 


 6.12% 
 50.00% 
 25.86% 
 0.00% 
 23.38% 
 20.00% 
 5.26% 
 0.00% 
 1,3,4 


 A.  3.4.6.2 
 ISDN/  Non- 
 Dis 
 patch/  AL(%) 


 11.76% 
 66.67% 
 12.61% 
 100.00% 


 5.11% 
 0.00% 
 10.43% 


 0.00% 
 1,2,3,4 


 Out 
 of 
 Service 


 > 
 24 


 hours 


 [M&  R- 


 5] 


 A.  3.5.1.1 
 Residence/  Dis 
 patch/  AL(%) 


 26.38% 
 18.45% 
 29.00% 
 20.39% 
 34.86% 
 27.96% 
 35.12% 
 33.93% 


 A.  3.5.1.2 
 Residence/  Non- 


 Dis  patch/ 
 AL(%) 


 15.91% 
 1.89% 
 18.15% 


 5.41% 
 21.82% 
 12.79% 
 19.89% 
 10.75% 


 B-  12 
185
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 June 


 March 
 May 
 April 


 Alabama 
 Performance 


 Metric 
 Data 


 A.  3.5.2.1 
 Business/  Dispatch/ 


 AL(%) 


 10.10% 
 9.76% 
 9.91% 
 0.00% 
 9.53% 
 4.88% 
 12.80% 
 20.00% 


 A.  3.5.2.2 
 Business/  Non- 


 Dis 
 patch/  AL(%) 


 4.92% 
 0.00% 
 3.71% 
 0.00% 
 5.82% 
 0.00% 
 3.40% 
 0.00% 


 A.  3.5.3.1 
 Desi 
 gn 
 (Specials)/  Dispatch/ 


 AL(%) 


 1.91% 
 0.00% 
 1.41% 
 0.00% 
 1.34% 
 0.00% 
 0.86% 
 0.00% 


 A.  3.5.3.2 
 Desi 
 gn 
 (Specials)/  Non- 


 Dispatch/  AL(%) 


 0.55% 
 0.00% 
 0.24% 
 0.00% 
 0.26% 
 0.00% 
 0.51% 
 3.57% 


 1 


 A.  3.5.4.1 
 PBX/  Dis 
 patch/  AL(%) 


 8.06% 
 50.00% 
 10.20% 
 0.00% 
 3.77% 
 0.00% 
 6.67% 
 100.00% 


 1,2,4 


 A.  3.5.4.2 
 PBX/  Non- 
 Dis 
 patch/  AL(%) 


 1.67% 
 0.00% 
 5.88% 
 0.00% 
 5.00% 
 0.00% 
 1.85% 
 0.00% 


 2,4 


 A.  3.5.5.1 
 Centrex/  Dis 
 patch/  AL(%) 


 13.58% 
 0.00% 
 10.29% 


 0.00% 
 8.84% 
 0.00% 
 17.68% 


 0.00% 


 A.  3.5.5.2 
 Centrex/  Non- 
 Dis  patch/ 
 AL(%) 


 1.69% 
 0.00% 
 1.74% 
 0.00% 
 6.51% 
 0.00% 
 2.17% 
 0.00% 


 1,3 


 A.  3.5.6.1 
 ISDN/  Dis 
 patch/  AL(%) 


 6.25% 
 0.00% 
 5.17% 
 0.00% 
 12.99% 


 0.00% 
 3.51% 
 0.00% 
 1,3,4 


 A.  3.5.6.2 
 ISDN/  Non- 
 Dis 
 patch/  AL(%) 


 1.48% 
 0.00% 
 0.90% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 33.33% 
 1,2,3,4 


 RESALE 
 - 
 BILLING  Invoice  Accuracy 


 [B-  1] 


 A.  4.1 
 AL 
 (%) 


 99.13% 
 99.80% 
 99.33% 
 99.23% 
 98.94% 
 98.70% 
 98.33% 
 97.31% 


 Mean 
 Time 
 to 
 Deliver 


 Invoices 


 - 
 CRIS 


 [B-  2] 


 A.  4.2 
 Re 
 gion( 


 business 


 days) 


 3.68 
 3.56 
 3.86 
 3.27 
 3.47 
 3.16 
 3.82 
 3.37 


 UNBUNDLED 
 NETWORK 
 ELEMENTS 


 - 
 ORDERING 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Mechanized 


 [O-  7] 


 B.  1.1.1 
 Switch 
 Ports/  AL 


 (%) 


 B.  1.1.3 
 Loop 
 + 
 Port 


 Combinations/  AL(%) 


 17.22% 
 19.22% 
 28.28% 
 17.65% 


 B.  1.1.4 
 Combo 
 Other/  AL 


 (%) 


 100.00% 


 1 


 B.  1.1.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  AL(%) 


 17.65% 
 22.22% 
 28.28% 
 11.02% 


 B.  1.1.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  AL(%) 


 0.00% 
 25.00% 
 33.33% 
 19.44% 
 1,2,3 


 B.  1.1.7 
 Line 
 Sharin  g/ 


 AL(%) 


 15.58% 
 24.00% 
 20.34% 
 22.73% 


 B.  1.1.8 
 2W 
 Analo  g 


 Loop 
 Design/  AL(%) 


 38.51% 
 35.48% 
 44.44% 
 43.24% 


 B.  1.1.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  AL(%) 


 87.50% 
 40.00% 


 75.00% 
 1,2,4 


 B.  1.1.14 
 Other 
 Desi  gn/ 


 AL(%) 


 19.30% 
 20.75% 
 11.11% 
 20.45% 


 B.  1.1.15 
 Other 
 Non-  Desi 


 gn/  AL(%) 


 29.53% 
 27.19% 
 30.49% 
 28.36% 


 B.  1.1.17 
 LNP 
 Standalone/  AL 


 (%) 


 7.14% 
 8.77% 
 5.52% 
 7.09% 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Partially 


 Mechanized 


 [O-  7] 


 B.  1.2.3 
 Loo  p 
 + 
 Port 


 Combinations/  AL(%) 


 31.19% 
 37.91% 
 37.28% 
 35.56% 


 B.  1.2.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  AL(%) 


 0.00% 
 7.69% 
 0.00% 


 1 


 B.  1.2.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  AL(%) 


 13.04% 
 10.17% 
 16.25% 
 20.00% 
 4 


 B.  1.2.7 
 Line 
 Sharin  g/ 


 AL(%) 


 41.18% 
 40.00% 
 60.00% 
 12.50% 
 4 


 B-  13 
186
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 June 


 March 
 May 
 April 


 Alabama 
 Performance 


 Metric 
 Data 


 B.  1.2.8 
 2W 
 Analog 


 Loop 
 Design/  AL(%) 


 27.45% 
 12.50% 
 31.03% 
 42.86% 


 B.  1.2.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  AL(%) 


 32.69% 
 20.83% 
 80.00% 
 34.29% 


 B.  1.2.14 
 Other 
 Desi  gn/ 


 AL(%) 


 45.10% 
 36.59% 
 15.87% 
 14.29% 


 B.  1.2.15 
 Other 
 Non-  Desi 


 gn/  AL(%) 


 33.41% 
 23.94% 
 20.19% 
 25.71% 


 B.  1.2.17 
 LNP 
 Standalone/  AL 


 (%) 


 16.95% 
 17.21% 
 15.16% 
 16.76% 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Non-  Mechanized 


 [O-  7] 


 B.  1.3.1 
 Switch 
 Ports/  AL 


 (%) 


 100.00% 


 1 


 B.  1.3.2 
 Local 
 Interoffice 


 Trans  port/ 
 AL(%) 


 50.00% 
 33.33% 
 2,4 


 B.  1.3.3 
 Loo  p 
 + 
 Port 


 Combinations/  AL(%) 


 51.06% 
 41.97% 
 51.87% 
 51.30% 


 B.  1.3.4 
 Combo 
 Other/  AL 


 (%) 


 0.00% 
 3 


 B.  1.3.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  AL(%) 


 34.78% 
 28.00% 
 36.36% 
 20.00% 


 B.  1.3.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  AL(%) 


 50.00% 
 50.00% 
 20.00% 
 50.00% 
 1,2,3,4 


 B.  1.3.7 
 Line 
 Sharin  g/ 


 AL(%) 


 28.57% 
 25.00% 
 0.00% 
 33.33% 
 1,2,3 


 B.  1.3.8 
 2W 
 Analo  g 


 Loop 
 Design/  AL(%) 


 35.71% 
 21.05% 
 26.92% 
 32.81% 


 B.  1.3.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 AL(%) 


 45.83% 
 43.40% 
 41.46% 


 B.  1.3.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  AL(%) 


 44.44% 
 0.00% 


 66.67% 
 1,2,4 


 B.  1.3.13 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Non-  Design/ 


 AL(%) 


 100.00% 


 2 


 B.  1.3.14 
 Other 
 Desi  gn/ 


 AL(%) 


 41.03% 
 35.00% 
 56.10% 
 30.43% 


 B.  1.3.15 
 Other 
 Non-  Desi 


 gn/  AL(%) 


 45.59% 
 38.24% 
 30.12% 
 31.51% 


 B.  1.3.16 
 INP 
 Standalone/  AL 


 (%) 


 41.67% 
 50.00% 
 35.71% 
 58.82% 


 B.  1.3.17 
 LNP 
 Standalone/  AL 


 (%) 


 23.81% 
 28.07% 
 23.88% 
 24.55% 


 Reject 
 Interval 


 - 
 Mechanized 


 [O-  8] 


 B.  1.4.3 
 Loo  p 
 + 
 Port 


 Combinations/  AL(%) 


 96.42% 
 94.82% 
 96.29% 
 94.31% 


 B.  1.4.4 
 Combo 
 Other/  AL 


 (%) 


 50.00% 


 1 


 B.  1.4.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  AL(%) 


 100.00% 
 100.00% 
 96.43% 
 100.00% 


 B.  1.4.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  AL(%) 


 0.00% 
 0.00% 
 100.00% 
 2,3,4 


 B.  1.4.7 
 Line 
 Sharin  g/ 


 AL(%) 


 66.67% 
 85.00% 
 71.43% 
 54.55% 


 B.  1.4.8 
 2W 
 Analo  g 


 Loop 
 Design/  AL(%) 


 85.48% 
 90.91% 
 96.43% 
 93.75% 


 B.  1.4.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  AL(%) 


 100.00% 
 100.00% 


 100.00% 
 1,2,4 


 B.  1.4.14 
 Other 
 Desi  gn/ 


 AL(%) 


 63.64% 
 100.00% 


 60.00% 
 66.67% 
 4 


 B.  1.4.15 
 Other 
 Non-  Desi 


 gn/  AL(%) 


 76.69% 
 75.23% 
 73.67% 
 61.90% 


 B.  1.4.17 
 LNP 
 Standalone/  AL 


 (%) 


 97.50% 
 97.78% 
 100.00% 


 88.64% 


 Reject 
 Interval 


 - 
 Partially 


 Mechanized 


 - 
 10 


 hours 


 [O-  8] 


 B-  14 
187
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 June 


 March 
 May 
 April 


 Alabama 
 Performance 


 Metric 
 Data 


 B.  1.7.3 
 Loop 
 + 
 Port 


 Combinations/  AL(%) 


 97.66% 
 97.30% 
 72.46% 
 96.96% 


 B.  1.7.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  AL(%) 


 100.00% 
 2 


 B.  1.7.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  AL(%) 


 88.89% 
 100.00% 


 84.62% 
 50.00% 
 1,2,4 


 B.  1.7.7 
 Line 
 Sharin  g/ 


 AL(%) 


 100.00% 
 100.00% 
 66.67% 
 100.00% 
 1,2,3,4 


 B.  1.7.8 
 2W 
 Analo  g 


 Loop 
 Design/  AL(%) 


 78.57% 
 50.00% 
 66.67% 
 83.33% 
 2,3,4 


 B.  1.7.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  AL(%) 


 94.12% 
 80.00% 
 81.82% 
 83.33% 
 2 


 B.  1.7.14 
 Other 
 Desi  gn/ 


 AL(%) 


 92.00% 
 100.00% 


 80.00% 
 60.00% 
 4 


 B.  1.7.15 
 Other 
 Non-  Desi 


 gn/  AL(%) 


 79.43% 
 92.08% 
 98.11% 
 93.53% 


 B.  1.7.17 
 LNP 
 Standalone/  AL 


 (%) 


 94.37% 
 100.00% 


 87.50% 
 87.50% 


 Reject 
 Interval 


 - 
 Non-  Mechanized 


 [O-  8] 


 B.  1.8.1 
 Switch 
 Ports/  AL 


 (%) 


 100.00% 


 1 


 B.  1.8.2 
 Local 
 Interoffice 


 Trans  port/ 
 AL(%) 


 100.00% 
 100.00% 
 2,4 


 B.  1.8.3 
 Loo  p 
 + 
 Port 


 Combinations/  AL(%) 


 97.98% 
 100.00% 


 99.22% 
 99.29% 


 B.  1.8.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  AL(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 B.  1.8.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  AL(%) 


 100.00% 
 100.00% 
 100.00% 


 0.00% 
 1,2,3,4 


 B.  1.8.7 
 Line 
 Sharin  g/ 


 AL(%) 


 100.00% 
 100.00% 


 100.00% 
 1,2,4 


 B.  1.8.8 
 2W 
 Analo  g 


 Loop 
 Design/  AL(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  1.8.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 AL(%) 


 100.00% 
 100.00% 
 100.00% 


 B.  1.8.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  AL(%) 


 75.00% 


 100.00% 
 1,4 


 B.  1.8.13 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Non-  Design/ 


 AL(%) 


 100.00% 


 2 


 B.  1.8.14 
 Other 
 Desi  gn/ 


 AL(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 4 


 B.  1.8.15 
 Other 
 Non-  Desi 


 gn/  AL(%) 


 100.00% 
 99.00% 
 98.78% 
 100.00% 


 B.  1.8.16 
 INP 
 Standalone/  AL 


 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2,3 


 B.  1.8.17 
 LNP 
 Standalone/  AL 


 (%) 


 100.00% 
 99.17% 
 100.00% 
 100.00% 


 FOC 
 Timeliness 


 - 
 Mechanized 


 [O-  9] 


 B.  1.9.3 
 Loo  p 
 + 
 Port 


 Combinations/  AL(%) 


 99.22% 
 99.08% 
 98.91% 
 97.58% 


 B.  1.9.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  AL(%) 


 95.60% 
 98.84% 
 95.59% 
 99.04% 


 B.  1.9.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  AL(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3 


 B.  1.9.7 
 Line 
 Sharin  g/ 


 AL(%) 


 98.51% 
 100.00% 
 100.00% 
 100.00% 


 B.  1.9.8 
 2W 
 Analo  g 


 Loop 
 Design/  AL(%) 


 100.00% 
 95.24% 
 96.88% 
 95.24% 


 B.  1.9.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  AL(%) 


 100.00% 
 100.00% 


 100.00% 
 1,2,4 


 B.  1.9.14 
 Other 
 Desi  gn/ 


 AL(%) 


 95.74% 
 100.00% 


 95.31% 
 91.43% 


 B.  1.9.15 
 Other 
 Non-  Desi 


 gn/  AL(%) 


 95.16% 
 95.07% 
 96.13% 
 92.53% 


 B-  15 
188
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 June 


 March 
 May 
 April 


 Alabama 
 Performance 


 Metric 
 Data 


 B.  1.9.17 
 LNP 
 Standalone/  AL(%) 


 99.81% 
 98.50% 
 90.60% 
 93.13% 


 FOC 
 Timeliness 


 - 
 Partially 


 Mechanized 


 - 
 10 


 hours 


 [O-  9] 


 B.  1.12.3 
 Loo  p 
 + 
 Port 


 Combinations/  AL(%) 


 91.37% 
 89.79% 
 79.92% 
 90.50% 


 B.  1.12.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  AL(%) 


 100.00% 
 90.91% 
 92.31% 


 1 


 B.  1.12.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  AL(%) 


 95.16% 
 98.04% 
 94.37% 
 100.00% 
 4 


 B.  1.12.7 
 Line 
 Sharin  g/ 


 AL(%) 


 100.00% 
 80.00% 
 83.33% 
 100.00% 
 3,4 


 B.  1.12.8 
 2W 
 Analo  g 


 Loop 
 Design/  AL(%) 


 97.62% 
 92.31% 
 91.67% 
 88.89% 
 4 


 B.  1.12.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  AL(%) 


 82.86% 
 82.35% 
 100.00% 
 100.00% 
 3 


 B.  1.12.14 
 Other 
 Desi  gn/ 


 AL(%) 


 96.30% 
 80.77% 
 93.88% 
 91.43% 


 B.  1.12.15 
 Other 
 Non-  Desi 


 gn/  AL(%) 


 70.12% 
 91.25% 
 95.05% 
 91.88% 


 B.  1.12.17 
 LNP 
 Standalone/  AL 


 (%) 


 95.65% 
 96.88% 
 87.93% 
 93.56% 


 FOC 
 Timeliness 


 - 
 Non-  Mechanized 


 [O-  9] 


 B.  1.13.1 
 Switch 
 Ports/  AL 


 (%) 


 B.  1.13.2 
 Local 
 Interoffice 


 Transport/  AL(%) 


 100.00% 
 100.00% 
 2,4 


 B.  1.13.3 
 Loo  p 
 + 
 Port 


 Combinations/  AL(%) 


 97.65% 
 98.89% 
 96.46% 
 99.20% 


 B.  1.13.4 
 Combo 
 Other/  AL 


 (%) 


 100.00% 
 3 


 B.  1.13.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  AL(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 4 


 B.  1.13.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  AL(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 B.  1.13.7 
 Line 
 Sharin  g/ 


 AL(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3 


 B.  1.13.8 
 2W 
 Analo  g 


 Loop 
 Design/  AL(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  1.13.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 AL(%) 


 100.00% 
 100.00% 
 100.00% 


 B.  1.13.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  AL(%) 


 100.00% 


 100.00% 
 1,4 


 B.  1.13.14 
 Other 
 Desi  gn/ 


 AL(%) 


 95.83% 
 100.00% 
 100.00% 
 83.33% 


 B.  1.13.15 
 Other 
 Non-  Desi 


 gn/  AL(%) 


 100.00% 
 96.82% 
 100.00% 
 100.00% 


 B.  1.13.16 
 INP 
 Standalone/  AL 


 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 B.  1.13.17 
 LNP 
 Standalone/  AL 


 (%) 


 100.00% 
 99.64% 
 100.00% 
 100.00% 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Mechanized 


 [O-  11] 


 B.  1.14.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  EDI/ 


 AL(%) 


 99.68% 
 100.00% 


 96.12% 
 99.92% 


 B.  1.14.3.2 
 Loo  p 
 + 
 Port 


 Combinations/  TAG/ 


 AL(%) 


 99.24% 
 98.23% 
 97.97% 
 99.89% 


 B.  1.14.4.1 
 Combo 
 Other/  EDI/ 


 AL  (%) 


 100.00% 


 1 


 B.  1.14.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  EDI/ 


 AL(%) 


 95.96% 
 97.98% 
 97.80% 
 98.99% 


 B.  1.14.5.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  TAG/ 


 AL(%) 


 85.00% 
 77.78% 
 100.00% 
 100.00% 
 3 


 B.  1.14.6.1 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  EDI/ 


 AL(%) 


 100.00% 


 100.00% 
 100.00% 
 1,3 


 B-  16 
189
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 June 


 March 
 May 
 April 


 Alabama 
 Performance 


 Metric 
 Data 


 B.  1.14.6.2 
 ISDN 
 Loop 
 (UDN, 


 UDC)/  TAG/ 


 AL(%) 


 66.67% 
 100.00% 


 100.00% 
 1,2,4 


 B.  1.14.7.1 
 Line 
 Sharin  g/ 


 EDI/  AL(%) 


 100.00% 
 100.00% 
 100.00% 
 97.44% 


 B.  1.14.7.2 
 Line 
 Sharin  g/ 


 TAG/  AL(%) 


 94.74% 
 100.00% 
 100.00% 
 100.00% 
 3,4 


 B.  1.14.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  EDI/ 


 AL(%) 


 100.00% 
 100.00% 
 97.67% 
 100.00% 


 B.  1.14.8.2 
 2W 
 Analo  g 


 Loop 
 Design/  TAG/ 


 AL(%) 


 100.00% 
 100.00% 
 90.00% 
 100.00% 
 2 


 B.  1.14.12.1 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  EDI/ 


 AL(%) 


 100.00% 


 1 


 B.  1.14.12.2 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  TAG/ 


 AL(%) 


 100.00% 
 60.00% 


 87.50% 
 1,2,4 


 B.  1.14.14.1 
 Other 
 Desi  gn/ 


 EDI/  AL(%) 


 100.00% 
 100.00% 
 83.33% 
 100.00% 


 B.  1.14.14.2 
 Other 
 Desi  gn/ 


 TAG/  AL(%) 


 100.00% 
 93.33% 
 100.00% 
 100.00% 


 B.  1.14.15.1 
 Other 
 Non-  Desi 


 gn/  EDI/ 
 AL(%) 


 100.00% 
 100.00% 
 95.65% 
 100.00% 
 2 


 B.  1.14.15.2 
 Other 
 Non-  Desi 


 gn/  TAG/ 
 AL(%) 


 99.16% 
 97.85% 
 98.16% 
 99.53% 


 B.  1.14.17.1 
 LNP 
 Standalone/  EDI/ 


 AL  (%) 


 100.00% 
 100.00% 
 98.31% 
 100.00% 
 1 


 B.  1.14.17.2 
 LNP 
 Standalone/  TAG/ 


 AL  (%) 


 99.64% 
 100.00% 


 97.77% 
 95.61% 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Partially 


 Mechanized 


 [O-  11] 


 B.  1.15.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  EDI/ 


 AL(%) 


 100.00% 
 99.71% 
 97.77% 
 99.46% 


 B.  1.15.3.2 
 Loo  p 
 + 
 Port 


 Combinations/  TAG/ 


 AL(%) 


 99.76% 
 99.46% 
 99.72% 
 99.61% 


 B.  1.15.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  EDI/ 


 AL(%) 


 0.00% 
 83.33% 
 100.00% 


 1 


 B.  1.15.5.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  TAG/ 


 AL(%) 


 20.00% 
 100.00% 
 100.00% 


 1,2,3 


 B.  1.15.6.1 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  EDI/ 


 AL(%) 


 100.00% 
 100.00% 
 95.00% 
 100.00% 
 4 


 B.  1.15.6.2 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  TAG/ 


 AL(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 4 


 B.  1.15.7.1 
 Line 
 Sharin  g/ 


 EDI/  AL(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 B.  1.15.7.2 
 Line 
 Sharin  g/ 


 TAG/  AL(%) 


 100.00% 
 100.00% 
 100.00% 


 1,2,3 


 B.  1.15.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  EDI/ 


 AL(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 B.  1.15.8.2 
 2W 
 Analo  g 


 Loop 
 Design/  TAG/ 


 AL(%) 


 100.00% 
 92.31% 
 100.00% 
 100.00% 
 4 


 B.  1.15.12.1 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  EDI/ 


 AL(%) 


 100.00% 
 100.00% 


 100.00% 
 2,4 


 B.  1.15.12.2 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  TAG/ 


 AL(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  1.15.14.1 
 Other 
 Desi  gn/ 


 EDI/  AL(%) 


 100.00% 
 100.00% 
 92.45% 
 100.00% 


 B.  1.15.14.2 
 Other 
 Desi  gn/ 


 TAG/  AL(%) 


 100.00% 
 94.44% 
 100.00% 
 100.00% 
 4 


 B.  1.15.15.1 
 Other 
 Non-  Desi 


 gn/  EDI/ 
 AL(%) 


 88.33% 
 88.68% 
 100.00% 
 100.00% 


 B.  1.15.15.2 
 Other 
 Non-  Desi 


 gn/  TAG/ 
 AL(%) 


 97.77% 
 98.28% 
 99.58% 
 99.79% 


 B.  1.15.17.1 
 LNP 
 Standalone/  EDI/ 


 AL  (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  1.15.17.2 
 LNP 
 Standalone/  TAG/ 


 AL  (%) 


 100.00% 
 99.76% 
 100.00% 


 99.57% 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Non-  Mechanized 


 [O-  11] 
 B-  17 
190
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 June 


 March 
 May 
 April 


 Alabama 
 Performance 


 Metric 
 Data 


 B.  1.16.1 
 Switch 
 Ports/  AL(%) 


 100.00% 


 1 


 B.  1.16.2 
 Local 
 Interoffice 


 Trans  port/ 
 AL(%) 


 100.00% 
 100.00% 
 2,4 


 B.  1.16.3 
 Loo  p 
 + 
 Port 


 Combinations/  AL(%) 


 97.87% 
 96.89% 
 94.61% 
 95.17% 


 B.  1.16.4 
 Combo 
 Other/  AL 


 (%) 


 100.00% 
 3 


 B.  1.16.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  AL(%) 


 100.00% 
 96.00% 
 95.45% 
 100.00% 


 B.  1.16.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  AL(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 B.  1.16.7 
 Line 
 Sharin  g/ 


 AL(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3 


 B.  1.16.8 
 2W 
 Analo  g 


 Loop 
 Design/  AL(%) 


 100.00% 
 98.25% 
 98.72% 
 100.00% 


 B.  1.16.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 AL(%) 


 100.00% 
 96.23% 
 100.00% 


 B.  1.16.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  AL(%) 


 100.00% 
 100.00% 


 100.00% 
 1,2,4 


 B.  1.16.13 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Non-  Design/ 


 AL(%) 


 100.00% 


 2 


 B.  1.16.14 
 Other 
 Desi  gn/ 


 AL(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  1.16.15 
 Other 
 Non-  Desi 


 gn/  AL(%) 


 98.77% 
 98.47% 
 95.75% 
 99.16% 


 B.  1.16.16 
 INP 
 Standalone/  AL 


 (%) 


 95.83% 
 94.44% 
 64.29% 
 100.00% 


 B.  1.16.17 
 LNP 
 Standalone/  AL 


 (%) 


 98.10% 
 98.82% 
 95.16% 
 98.92% 


 UNBUNDLED 
 NETWORK 
 ELEMENTS 


 - 
 PROVISIONING 


 Order 
 Completion 


 Interval 
 [P-  4] 


 B.  2.1.2.1.1 
 Local 
 Interoffice 


 Transport/<  10 


 circuits/  Dis 
 patch/  AL( 
 days) 


 14.87 
 15.51 
 14.07 
 16.47 
 30.00 


 4 


 B.  2.1.3.1.1 
 Loop 
 + 
 Port 


 Combinations/<  10  circuits/  Dis  patch/  AL(  days) 


 3.63 
 3.57 
 4.05 
 2.94 
 4.27 
 3.01 
 4.57 
 2.85 


 B.  2.1.3.1.2 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Non- 


 Dis 
 patch/  AL( 


 days) 


 0.77 
 0.56 
 0.80 
 0.55 
 0.80 
 0.57 
 0.82 
 0.57 


 B.  2.1.3.1.3 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Switch 
 Based 


 Orders/  AL 
 (days) 


 0.33 
 0.33 
 0.33 
 0.33 
 0.33 
 0.33 
 0.33 
 0.33 


 B.  2.1.3.1.4 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Dispatch 


 In/  AL 
 (days) 


 1.53 
 1.11 
 1.51 
 1.09 
 1.49 
 1.14 
 1.53 
 1.22 


 B.  2.1.3.2.1 
 Loop 
 + 
 Port 


 Combinations/>=  10  circuits/  Dis  patch/  AL(  days) 


 6.20 
 2.00 
 10.36 


 4.63 
 10.85 


 2.00 
 9.31 
 6.90 
 1,2,3,4 


 B.  2.1.3.2.2 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Non- 


 Dis 
 patch/  AL( 


 days) 


 3.90 
 1.67 
 4.73 
 4.57 
 0.33 


 4 


 B.  2.1.3.2.3 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Switch 


 Based 
 Orders/  AL 


 (days) 


 0.33 
 0.33 
 0.33 
 0.33 
 0.33 


 4 


 B-  18 
191
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 June 


 March 
 May 
 April 


 Alabama 
 Performance 


 Metric 
 Data 


 B.  2.1.3.2.4 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Dispatch 


 In/  AL 
 (days) 


 6.05 
 2.31 
 5.78 
 5.39 


 B.  2.1.4.1.1 
 Combo 
 Other/<  10 


 circuits/  Dis 
 patch/  AL( 
 days) 


 4.95 
 12.75 


 4.92 
 12.00 


 5.11 
 10.67 


 5.51 


 1,2,3 


 B.  2.1.6.3.1 
 UNE 
 ISDN/<  6 


 circuits/  Dis 


 patch/  AL( 
 days) 


 16.95 
 9.89 
 12.80 


 10.60 
 12.85 


 9.73 
 12.65 


 11.21 


 B.  2.1.7.3.1 
 Line 
 Sharin  g/< 


 6 
 circuits/  Dispatch/ 


 AL( 
 days) 


 11.21 
 5.29 
 4.94 
 5.25 
 4.87 
 4.00 
 3.57 
 3.33 
 1,2,3,4 


 B.  2.1.7.3.2 
 Line 
 Sharin  g/< 


 6 
 circuits/  Non- 


 Dispatch/  AL( 


 days) 


 3.68 
 3.72 
 3.82 
 3.72 
 3.74 
 3.82 
 2.43 
 4.00 


 B.  2.1.8.1.1 
 2W 
 Analog 


 Loop 
 Design/<  10 


 circuits/  Dis 
 patch/  AL( 
 days) 


 3.63 
 4.18 
 4.05 
 4.42 
 4.27 
 4.00 
 4.57 
 4.07 


 B.  2.1.8.2.1 
 2W 
 Analog 


 Loop 
 Design/>=  10 


 circuits/  Dis 
 patch/  AL( 
 days) 


 6.20 
 6.00 
 10.36 


 10.85 


 9.31 
 1 


 B.  2.1.12.1.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/<  10 


 circuits/  Dis 
 patch/  AL( 
 days) 


 3.63 
 4.86 
 4.05 
 5.10 
 4.27 
 5.00 
 4.57 
 6.00 
 1,3,4 


 B.  2.1.14.1.1 
 Other 
 Desi  gn/< 


 10 
 circuits/  Dispatch/ 


 AL( 
 days) 


 27.80 


 19.64 
 19.83 
 18.12 


 B.  2.1.15.1.1 
 Other 
 Non-  Design/< 


 10 
 circuits/  Dispatch/ 


 AL(  days) 
 3.63 
 6.00 
 4.05 
 6.00 
 4.27 
 6.25 
 4.57 


 1,2,3 


 B.  2.1.15.1.2 
 Other 
 Non-  Design/< 


 10 
 circuits/  Non- 


 Dis 
 patch/  AL( 


 days) 


 0.77 
 0.80 
 0.80 
 0.82 


 B.  2.1.16.1.2 
 INP 
 (Standalone)/<  10 


 circuits/  Non- 
 Dispatch/  AL( 


 days) 
 0.77 


 0.33 
 0.79 
 0.33 
 0.79 
 0.33 
 0.82 


 1,2,3 


 B.  2.1.17.1.2 
 LNP 
 (Standalone)/<  10 


 circuits/  Non- 


 Dis 
 patch/  AL( 


 days) 


 0.77 
 0.53 
 0.79 
 0.55 
 0.79 
 0.54 
 0.82 
 0.63 


 B.  2.1.17.2.2 
 LNP 
 (Standalone)/>=  10 


 circuits/  Non- 


 Dis 
 patch/  AL( 


 days) 


 4.00 
 0.67 
 2.44 
 0.33 
 0.33 
 6.00 
 0.89 
 0.33 
 1,2,3,4 


 B.  2.1.18.1.1 
 Digital 
 Loop 
 < 
 DS1/<  10 


 circuits/  Dispatch/ 


 AL(  days) 
 11.95 
 6.84 
 7.39 
 6.97 
 7.45 
 6.58 
 5.76 
 7.29 


 B.  2.1.19.1.1 
 Digital 
 Loop 
 >= 
 DS1/<  10 


 circuits/  Dispatch/ 


 AL(  days) 
 28.98 
 5.88 
 18.52 


 7.48 
 37.05 


 6.33 
 25.92 


 6.03 


 Order 
 Completion 


 Interval 
 within 
 X 
 days 


 [P-  4] 


 B.  2.2.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL) 


 Loop 
 w/  o 


 Conditionin  g/< 
 6 
 circuits/  Dispatch/ 


 AL( 
 days) 


 4.44 
 4.37 
 3.81 
 4.42 


 % 
 Jeopardies 


 - 
 Mechanized 


 [P-  2] 


 B.  2.5.3 
 Loo  p 
 + 
 Port 


 Combinations/  AL(%) 


 0.45% 
 0.60% 
 0.48% 
 0.29% 
 0.41% 
 0.28% 
 0.39% 
 0.16% 


 B.  2.5.4 
 Combo 
 Other/  AL 


 (%) 


 5.86% 
 6.81% 
 0.00% 
 6.49% 


 7.27% 


 2 


 B-  19 
192
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 June 


 March 
 May 
 April 


 Alabama 
 Performance 


 Metric 
 Data 


 B.  2.5.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  AL(%) 


 10.69% 
 15.48% 
 7.92% 
 7.27% 
 3.03% 


 B.  2.5.6 
 UNE 
 ISDN/  AL 


 (%) 


 8.33% 
 18.52% 


 3.86% 
 10.34% 


 4.02% 
 22.22% 


 6.47% 
 17.65% 


 B.  2.5.7 
 Line 
 Sharin  g/ 


 AL(%) 


 10.69% 
 0.00% 
 15.48% 


 0.00% 
 7.92% 
 0.00% 
 7.27% 
 0.00% 
 1,2,3,4 


 B.  2.5.8 
 2W 
 Analo  g 


 Loop 
 Design/  AL(%) 


 0.45% 
 7.14% 
 0.48% 
 0.00% 
 0.41% 
 5.88% 
 0.39% 
 0.00% 


 4 


 B.  2.5.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  AL(%) 


 0.45% 
 5.26% 
 0.48% 
 0.00% 
 0.41% 
 0.00% 
 0.39% 
 0.00% 


 3 


 B.  2.5.14 
 Other 
 Desi  gn/ 


 AL(%) 


 11.33% 
 12.07% 
 12.85% 
 14.34% 


 B.  2.5.15 
 Other 
 Non-  Desi 


 gn/  AL(%) 


 0.45% 
 0.48% 
 0.41% 
 0.39% 


 B.  2.5.16 
 INP 
 (Standalone)/  AL(%) 


 0.44% 
 0.00% 
 0.48% 


 0.39% 
 0.38% 


 1 


 B.  2.5.17 
 LNP 
 (Standalone)/  AL(%) 


 0.44% 
 0.00% 
 0.48% 
 0.00% 
 0.39% 
 0.00% 
 0.38% 
 0.00% 


 B.  2.5.18 
 Di  gital 
 Loop 
 < 
 DS1/  AL(%) 


 10.60% 
 18.52% 
 14.52% 
 10.34% 
 8.14% 
 22.22% 


 8.07% 
 10.45% 


 B.  2.5.19 
 Di 
 gital 


 Loop 


 >= 
 DS1/  AL(%) 


 7.76% 
 75.86% 


 9.09% 
 77.78% 
 11.58% 
 82.80% 
 16.40% 
 80.95% 


 % 
 Jeopardies 


 - 
 Non-  Mechanized 


 [P-  2] 


 B.  2.6.2 
 Local 
 Interoffice 


 Trans  port/ 
 AL(%) 


 0.00% 
 4 


 B.  2.6.3 
 Loo  p 
 + 
 Port 


 Combinations/  AL(%) 


 0.00% 
 2.48% 
 2.85% 
 1.40% 


 B.  2.6.4 
 Combo 
 Other/  AL 


 (%) 


 42.86% 
 33.33% 
 50.00% 
 100.00% 
 1,2,3,4 


 B.  2.6.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  AL(%) 


 0.00% 
 2.00% 
 6.12% 
 0.00% 


 B.  2.6.6 
 UNE 
 ISDN/  AL 


 (%) 


 0.00% 
 100.00% 


 0.00% 
 0.00% 
 1,2,3,4 


 B.  2.6.7 
 Line 
 Sharin  g/ 


 AL(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 


 B.  2.6.8 
 2W 
 Analo  g 


 Loop 
 Design/  AL(%) 


 5.88% 
 7.14% 
 15.38% 


 4.17% 


 B.  2.6.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  AL(%) 


 0.00% 
 0.00% 


 0.00% 
 1,2,4 


 B.  2.6.15 
 Other 
 Non-  Desi 


 gn/  AL(%) 


 0.00% 
 0.00% 
 0.00% 


 1,3 


 B.  2.6.16 
 INP 
 (Standalone)/  AL(%) 


 0.00% 
 0.00% 


 2,3 


 B.  2.6.17 
 LNP 
 (Standalone)/  AL(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 


 B.  2.6.18 
 Di 
 gital 


 Loop 


 < 
 DS1/  AL(%) 


 0.00% 
 3.92% 
 5.88% 
 0.00% 


 B.  2.6.19 
 Di 
 gital 


 Loop 


 >= 
 DS1/  AL(%) 


 68.75% 
 71.43% 
 45.45% 
 71.43% 
 2,4 


 Average 
 Jeopardy 


 Notice 
 Interval 


 - 
 Mechanized 


 [P-  2] 


 B.  2.8.3 
 Loo  p 
 + 
 Port 


 Combinations/  AL( 


 hours) 


 115.43 
 153.61 
 165.18 
 189.51 
 4 


 B.  2.8.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  AL( 


 hours) 


 169.75 
 4 


 B.  2.8.6 
 UNE 
 ISDN/  AL 


 (hours) 


 258.78 
 244.26 
 275.48 
 287.84 
 1,2,3,4 


 B.  2.8.8 
 2W 
 Analo  g 


 Loop 
 Design/  AL( 


 hours) 


 114.65 


 104.43 
 1,3 


 B.  2.8.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  AL( 


 hours) 


 124.75 


 1 


 B.  2.8.18 
 Di 
 gital 


 Loop 


 < 
 DS1/  AL( 


 hours) 


 258.78 
 244.26 
 275.48 
 268.16 
 1,2,3,4 


 B.  2.8.19 
 Di 
 gital 


 Loop 


 >= 
 DS1/  AL( 


 hours) 


 225.76 
 206.99 
 176.29 
 182.79 


 B-  20 
193
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 June 


 March 
 May 
 April 


 Alabama 
 Performance 


 Metric 
 Data 


 Average 
 Jeopardy 


 Notice 
 Interval 


 - 
 Non-  Mechanized 


 [P-  2] 


 B.  2.9.3 
 Loo  p 
 + 
 Port 


 Combinations/  AL( 


 hours) 


 391.68 
 170.65 
 241.12 
 2,3,4 


 B.  2.9.4 
 Combo 
 Other/  AL 


 (hours) 


 333.46 
 352.50 
 328.31 
 328.50 
 1,2,3,4 


 B.  2.9.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  AL( 


 hours) 


 160.47 
 142.32 


 2,3 


 B.  2.9.6 
 UNE 
 ISDN/  AL 


 (hours) 


 112.43 
 2 


 B.  2.9.8 
 2W 
 Analo  g 


 Loop 
 Design/  AL( 


 hours) 


 135.95 
 88.50 
 664.37 
 2,3,4 


 B.  2.9.18 
 Di 
 gital 


 Loop 


 < 
 DS1/  AL( 


 hours) 


 136.45 
 142.32 


 2,3 


 B.  2.9.19 
 Di 
 gital 


 Loop 


 >= 
 DS1/  AL( 


 hours) 


 196.20 
 221.98 
 227.65 
 166.46 
 2,3,4 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Mechanized 


 [P-  2] 


 B.  2.10.3 
 Loo  p 
 + 
 Port 


 Combinations/  AL(%) 


 100.00% 
 100.00% 
 94.74% 
 100.00% 
 4 


 B.  2.10.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  AL(%) 


 100.00% 
 4 


 B.  2.10.6 
 UNE 
 ISDN/  AL 


 (%) 


 80.00% 
 100.00% 
 100.00% 
 80.00% 
 1,2,3,4 


 B.  2.10.8 
 2W 
 Analo  g 


 Loop 
 Design/  AL(%) 


 100.00% 
 100.00% 
 1,3 


 B.  2.10.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  AL(%) 


 100.00% 


 1 


 B.  2.10.18 
 Di 
 gital 


 Loop 


 < 
 DS1/  AL(%) 


 80.00% 
 100.00% 
 100.00% 
 83.33% 
 1,2,3,4 


 B.  2.10.19 
 Di 
 gital 


 Loop 


 >= 
 DS1/  AL(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Non-  Mechanized 


 [P-  2] 


 B.  2.11.3 
 Loo  p 
 + 
 Port 


 Combinations/  AL(%) 


 100.00% 
 85.71% 
 100.00% 
 2,3,4 


 B.  2.11.4 
 Combo 
 Other/  AL 


 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 B.  2.11.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  AL(%) 


 100.00% 
 100.00% 


 2,3 


 B.  2.11.6 
 UNE 
 ISDN/  AL 


 (%) 


 100.00% 
 2 


 B.  2.11.8 
 2W 
 Analo  g 


 Loop 
 Design/  AL(%) 


 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 B.  2.11.18 
 Di 
 gital 


 Loop 


 < 
 DS1/  AL(%) 


 100.00% 
 100.00% 


 2,3 


 B.  2.11.19 
 Di 
 gital 


 Loop 


 >= 
 DS1/  AL(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 Coordinated 
 Customers 
 Conversions 


 [P-  7] 


 B.  2.12.2 
 Loo  ps 
 with 
 LNP/  AL(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 3 


 % 
 Hot 


 Cuts 


 > 
 15 


 minutes 


 Early 
 [P-  7A] 


 B.  2.13.2 
 Time-  S 
 pecific 
 SL2/  AL(%) 


 0.00% 
 0.00% 


 1 


 B.  2.13.4 
 Non-  Time 
 Specific 
 SL2/  AL(%) 


 0.00% 
 0.00% 


 0.00% 
 2,4 


 Hot 
 Cut 
 Timeliness 


 [P-  7A] 


 B.  2.14.2 
 Time-  S 
 pecific 
 SL2/  AL(%) 


 100.00% 
 100.00% 


 1 


 B.  2.14.4 
 Non-  Time 
 Specific 
 SL2/  AL(%) 


 100.00% 
 100.00% 


 100.00% 
 2,4 


 % 
 Hot 


 Cuts 


 > 
 15 


 minutes 


 Late 
 [P-  7A] 


 B-  21 
194
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 June 


 March 
 May 
 April 


 Alabama 
 Performance 


 Metric 
 Data 


 B.  2.15.2 
 Time-  Specific 


 SL2/  AL(%) 


 0.00% 
 0.00% 


 1 


 B.  2.15.4 
 Non-  Time 
 Specific 
 SL2/  AL(%) 


 0.00% 
 0.00% 


 0.00% 
 2,4 


 % 
 Provisioning 


 Troubles 
 within 
 7 
 Days 


 - 
 Hot 


 Cuts 


 [P-  7C] 


 B.  2.17.1.1 
 UNE 
 Loo 
 p 
 Design/  Dispatch/ 


 AL(%) 


 0.00% 
 0.00% 
 16.67% 
 4 


 % 
 Missed 


 Installation 


 Appointments 


 [P-  3] 


 B.  2.18.2.1.1 
 Local 
 Interoffice 


 Transport/<  10 


 circuits/  Dis 
 patch/  AL(%) 


 0.25% 
 0.00% 
 0.77% 
 0.84% 
 0.00% 


 4 


 B.  2.18.3.1.1 
 Loop 
 + 
 Port 


 Combinations/<  10  circuits/  Dis  patch/  AL(%) 


 4.94% 
 4.84% 
 4.88% 
 3.08% 
 5.50% 
 3.13% 
 5.92% 
 5.82% 


 B.  2.18.3.1.2 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Non- 


 Dis 
 patch/  AL(%) 


 0.10% 
 0.19% 
 0.02% 
 0.11% 
 0.02% 
 0.06% 
 0.02% 
 0.22% 


 B.  2.18.3.1.3 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Switch 
 Based 


 Orders/  AL 
 (%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 B.  2.18.3.1.4 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Dispatch 


 In/  AL 
 (%) 


 0.24% 
 0.39% 
 0.04% 
 0.25% 
 0.04% 
 0.09% 
 0.04% 
 0.39% 


 B.  2.18.3.2.1 
 Loop 
 + 
 Port 


 Combinations/>=  10  circuits/  Dis  patch/  AL(%) 


 8.33% 
 0.00% 
 4.48% 
 11.11% 


 7.53% 
 0.00% 
 2.56% 
 14.29% 
 1,2,3,4 


 B.  2.18.3.2.2 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Non- 


 Dis 
 patch/  AL(%) 


 0.00% 
 2.17% 
 0.00% 
 0.00% 
 1.43% 
 0.00% 


 3,4 


 B.  2.18.3.2.3 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Switch 


 Based 
 Orders/  AL 


 (%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 4 


 B.  2.18.3.2.4 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Dispatch 


 In/  AL 
 (%) 


 0.00% 
 3.13% 
 0.00% 
 0.00% 
 1.72% 


 3 


 B.  2.18.4.1.1 
 Combo 
 Other/<  10 


 circuits/  Dis 
 patch/  AL(%) 


 4.94% 
 16.67% 


 4.91% 
 0.00% 
 5.39% 
 0.00% 
 5.84% 


 1,2,3 


 B.  2.18.5.1.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/<  10 


 circuits/  Dis 
 patch/  AL(%) 


 21.81% 
 1.92% 
 9.87% 
 0.00% 
 10.49% 


 0.00% 
 12.54% 


 2.04% 


 B.  2.18.6.1.1 
 UNE 
 ISDN/<  10 


 circuits/  Dis 
 patch/  AL(%) 


 15.85% 
 3.03% 
 14.66% 


 0.00% 
 9.68% 
 2.50% 
 10.96% 


 2.94% 


 B.  2.18.7.1.1 
 Line 
 Sharin  g/< 


 10 
 circuits/  Dispatch/ 


 AL(%) 


 21.81% 
 14.29% 
 9.87% 
 25.00% 
 10.49% 
 0.00% 
 12.54% 


 0.00% 
 1,2,3,4 


 B.  2.18.7.1.2 
 Line 
 Sharin  g/< 


 10 
 circuits/  Non- 


 Dispatch/  AL(%) 


 0.00% 
 0.00% 
 0.07% 
 0.00% 
 0.00% 
 0.00% 
 0.06% 
 0.00% 


 B.  2.18.8.1.1 
 2W 
 Analog 


 Loop 
 Design/<  10 


 circuits/  Dis 
 patch/  AL(%) 


 4.94% 
 0.00% 
 4.88% 
 2.38% 
 5.50% 
 0.00% 
 5.92% 
 0.00% 


 B.  2.18.8.2.1 
 2W 
 Analog 


 Loop 
 Design/>=  10 


 circuits/  Dis 
 patch/  AL(%) 


 8.33% 
 0.00% 
 4.48% 


 7.53% 
 2.56% 


 1 


 B-  22 
195
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 June 


 March 
 May 
 April 


 Alabama 
 Performance 


 Metric 
 Data 


 B.  2.18.12.1.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/<  10 


 circuits/  Dis 
 patch/  AL(%) 


 4.94% 
 0.00% 
 4.88% 
 0.00% 
 5.50% 
 0.00% 
 5.92% 
 0.00% 


 3 


 B.  2.18.14.1.1 
 Other 
 Desi  gn/< 


 10 
 circuits/  Dispatch/ 


 AL(%) 


 5.00% 
 5.43% 
 3.41% 
 4.61% 


 B.  2.18.15.1.1 
 Other 
 Non-  Desi 


 gn/<  10 
 circuits/  Dispatch/ 


 AL(%) 
 4.94% 
 0.00% 
 4.88% 
 0.00% 
 5.50% 
 16.67% 


 5.92% 


 1,3 


 B.  2.18.15.1.2 
 Other 
 Non-  Design/< 


 10 
 circuits/  Non- 


 Dispatch/  AL(%) 


 0.10% 
 0.02% 
 0.02% 
 0.02% 


 B.  2.18.16.1.2 
 INP 
 (Standalone)/<  10 


 circuits/  Non- 
 Dispatch/  AL(%) 


 0.10% 
 0.00% 
 0.02% 
 0.00% 
 0.02% 
 0.00% 
 0.01% 


 1,2,3 


 B.  2.18.17.1.2 
 LNP 
 (Standalone)/<  10 


 circuits/  Non- 
 Dispatch/  AL(%) 


 0.10% 
 0.12% 
 0.02% 
 0.13% 
 0.02% 
 1.72% 
 0.01% 
 0.00% 


 B.  2.18.17.2.2 
 LNP 
 (Standalone)/>=  10 


 circuits/  Non- 
 Dispatch/  AL(%) 


 0.00% 
 0.00% 
 33.33% 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3,4 


 B.  2.18.18.1.1 
 Di  gital 
 Loop 
 < 
 DS1/<  10 


 circuits/  Dispatch/ 


 AL(%) 
 20.19% 
 2.41% 
 9.69% 
 0.00% 
 9.73% 
 1.15% 
 11.65% 


 2.41% 


 B.  2.18.19.1.1 
 Di 
 gital 


 Loop 


 >= 
 DS1/<  10 


 circuits/  Dispatch/ 


 AL(%) 
 7.45% 
 10.53% 


 7.88% 
 16.07% 


 0.88% 
 6.25% 
 0.69% 
 7.79% 


 % 
 Provisioning 


 Troubles 
 within 
 30 
 Days 


 [P-  9] 


 B.  2.19.3.1.1 
 Loop 
 + 
 Port 


 Combinations/<  10  circuits/  Dis  patch/  AL(%) 


 10.40% 
 11.66% 
 10.54% 
 9.68% 
 10.54% 
 11.08% 
 10.67% 
 9.40% 


 B.  2.19.3.1.2 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Non- 


 Dis 
 patch/  AL(%) 


 2.92% 
 4.99% 
 3.06% 
 4.34% 
 2.77% 
 4.23% 
 2.67% 
 3.22% 


 B.  2.19.3.1.3 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Switch 
 Based 


 Orders/  AL 
 (%) 


 3.09% 
 5.28% 
 3.18% 
 3.32% 
 2.99% 
 3.54% 
 2.75% 
 2.93% 


 B.  2.19.3.1.4 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Dispatch 


 In/  AL 
 (%) 


 2.68% 
 4.70% 
 2.89% 
 5.47% 
 2.48% 
 5.09% 
 2.57% 
 3.38% 


 B.  2.19.3.2.1 
 Loop 
 + 
 Port 


 Combinations/>=  10  circuits/  Dis  patch/  AL(%) 


 18.46% 
 0.00% 
 21.67% 
 25.00% 
 17.91% 
 22.22% 
 17.20% 
 0.00% 
 1,2,3,4 


 B.  2.19.3.2.2 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Non- 


 Dis 
 patch/  AL(%) 


 10.45% 
 100.00% 


 9.38% 


 8.70% 
 6.35% 
 0.00% 


 1,4 


 B.  2.19.3.2.3 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Switch 


 Based 
 Orders/  AL 


 (%) 


 16.00% 
 8.70% 
 7.14% 
 8.33% 


 B.  2.19.3.2.4 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Dispatch 


 In/  AL 
 (%) 


 7.14% 
 100.00% 


 9.76% 


 9.38% 
 5.88% 
 0.00% 


 1,4 


 B.  2.19.4.1.1 
 Combo 
 Other/<  10 


 circuits/  Dis 
 patch/  AL(%) 


 10.26% 
 25.00% 
 10.39% 
 16.67% 
 10.32% 
 0.00% 
 10.46% 
 25.00% 
 1,2,3,4 


 B.  2.19.5.1.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/<  10 


 circuits/  Dis 
 patch/  AL(%) 


 2.64% 
 7.14% 
 3.86% 
 1.92% 
 3.95% 
 1.96% 
 4.88% 
 2.13% 


 B-  23 
196
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 June 


 March 
 May 
 April 


 Alabama 
 Performance 


 Metric 
 Data 


 B.  2.19.6.1.1 
 UNE 
 ISDN/<  10 


 circuits/  Dispatch/ 


 AL(%) 


 9.43% 
 11.11% 


 4.88% 
 3.03% 
 8.62% 
 13.79% 


 6.45% 
 7.50% 


 B.  2.19.7.1.1 
 Line 
 Sharin  g/< 


 10 
 circuits/  Dispatch/ 


 AL(%) 


 2.64% 
 28.57% 


 3.86% 
 28.57% 


 3.95% 
 0.00% 
 4.88% 
 0.00% 
 1,2,3,4 


 B.  2.19.7.1.2 
 Line 
 Sharin  g/< 


 10 
 circuits/  Non- 


 Dispatch/  AL(%) 


 2.23% 
 2.38% 
 1.37% 
 6.78% 
 2.09% 
 14.71% 


 2.11% 
 12.90% 


 B.  2.19.8.1.1 
 2W 
 Analog 


 Loop 
 Design/<  10 


 circuits/  Dis 
 patch/  AL(%) 


 10.40% 
 12.24% 
 10.54% 
 4.17% 
 10.54% 


 4.76% 
 10.67% 


 0.00% 


 B.  2.19.8.2.1 
 2W 
 Analog 


 Loop 
 Design/>=  10 


 circuits/  Dis 
 patch/  AL(%) 


 18.46% 
 21.67% 
 0.00% 
 17.91% 


 17.20% 


 2 


 B.  2.19.12.1.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/<  10 


 circuits/  Dis 
 patch/  AL(%) 


 10.40% 
 0.00% 
 10.54% 


 0.00% 
 10.54% 


 4.76% 
 10.67% 
 33.33% 


 4 


 B.  2.19.14.1.1 
 Other 
 Desi  gn/< 


 10 
 circuits/  Dispatch/ 


 AL(%) 


 7.13% 
 7.64% 
 6.26% 
 6.45% 


 B.  2.19.15.1.1 
 Other 
 Non-  Desi 


 gn/<  10 
 circuits/  Dispatch/ 


 AL(%) 
 10.40% 
 40.00% 
 10.54% 
 20.00% 
 10.54% 
 20.00% 
 10.67% 
 0.00% 
 1,2,4 


 B.  2.19.16.1.2 
 INP 
 (Standalone)/<  10 


 circuits/  Non- 
 Dispatch/  AL(%) 


 2.92% 
 0.00% 
 3.06% 
 0.00% 
 2.76% 
 0.00% 
 2.67% 
 0.00% 
 1,2,3,4 


 B.  2.19.17.1.2 
 LNP 
 (Standalone)/<  10 


 circuits/  Non- 
 Dispatch/  AL(%) 


 2.92% 
 0.00% 
 3.06% 
 0.00% 
 2.76% 
 0.00% 
 2.67% 
 0.00% 


 B.  2.19.17.2.2 
 LNP 
 (Standalone)/>=  10 


 circuits/  Non- 
 Dispatch/  AL(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3,4 


 B.  2.19.18.1.1 
 Di 
 gital 


 Loop 


 < 
 DS1/<  10 


 circuits/  Dispatch/ 


 AL(%) 
 3.56% 
 7.41% 
 4.19% 
 2.41% 
 4.40% 
 6.25% 
 5.20% 
 4.60% 


 B.  2.19.19.1.1 
 Di  gital 
 Loop 
 >= 
 DS1/<  10 


 circuits/  Dispatch/ 


 AL(%) 
 1.30% 
 13.41% 


 8.07% 
 11.84% 


 2.42% 
 10.71% 


 0.00% 
 12.50% 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Mechanized 


 [P-  5] 


 B.  2.21.3.1.1 
 Loop 
 + 
 Port 


 Combinations/<  10  circuits/  Dis  patch/  AL(  hours) 


 1.29 
 0.16 
 1.51 
 0.17 
 1.40 
 0.77 
 1.45 
 0.26 


 B.  2.21.3.1.2 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Non- 


 Dis 
 patch/  AL( 


 hours) 


 0.56 
 0.58 
 0.57 
 0.59 
 0.63 
 0.69 
 0.63 
 0.67 


 B.  2.21.3.1.3 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Switch 
 Based 


 Orders/  AL 
 (hours) 


 0.56 
 0.53 
 0.61 
 0.56 
 0.67 
 0.61 
 0.66 
 0.61 


 B.  2.21.3.1.4 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Dispatch 


 In/  AL 
 (hours) 


 0.56 
 0.64 
 0.52 
 0.62 
 0.57 
 0.73 
 0.59 
 0.71 


 B.  2.21.3.2.1 
 Loop 
 + 
 Port 


 Combinations/>=  10  circuits/  Dis  patch/  AL(  hours) 


 1.47 
 0.02 
 1.00 
 0.02 
 2.94 
 0.02 
 4.04 
 0.02 
 1,2,3,4 


 B.  2.21.3.2.2 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Non- 


 Dis 
 patch/  AL( 


 hours) 


 0.46 
 0.49 
 3.98 
 0.47 


 B.  2.21.3.2.4 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Dispatch 


 In/  AL 
 (hours) 


 0.47 
 0.48 
 0.53 
 0.45 


 B-  24 
197
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 June 


 March 
 May 
 April 


 Alabama 
 Performance 


 Metric 
 Data 


 B.  2.21.4.1.1 
 Combo 
 Other/<  10 


 circuits/  Dispatch/ 


 AL( 
 hours) 


 12.73 


 9.50 
 88.13 


 9.80 


 10.51 


 2 


 B.  2.21.5.1.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/<  10 


 circuits/  Dis 
 patch/  AL( 
 hours) 


 3.57 
 4.54 
 3.48 
 2.83 
 2.47 


 B.  2.21.6.1.1 
 UNE 
 ISDN/<  10 


 circuits/  Dis 
 patch/  AL( 
 hours) 


 56.01 
 21.50 
 58.64 


 5.85 
 40.17 


 9.60 
 41.67 


 20.82 


 B.  2.21.7.1.2 
 Line 
 Sharing/<  10 


 circuits/  Non- 
 Dispatch/  AL( 
 hours) 
 0.57 
 0.47 
 0.46 
 0.55 
 0.70 
 0.48 
 0.67 
 0.32 
 1,2,3,4 


 B.  2.21.8.1.1 
 2W 
 Analog 


 Loop 
 Design/<  10 


 circuits/  Dispatch/ 
 AL( 
 hours) 


 1.29 
 3.63 
 1.51 
 18.03 


 1.40 
 7.48 
 1.45 
 15.63 


 4 


 B.  2.21.8.2.1 
 2W 
 Analog 


 Loop 
 Design/>=  10 


 circuits/  Dis 
 patch/  AL( 
 hours) 


 1.47 
 0.08 
 1.00 


 2.94 
 4.04 


 1 


 B.  2.21.12.1.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/<  10 


 circuits/  Dis 
 patch/  AL( 
 hours) 


 1.29 
 25.74 


 1.51 
 42.31 


 1.40 
 1.75 
 1.45 
 1.55 


 3 


 B.  2.21.16.1.2 
 INP 
 (Standalone)/<  10 


 circuits/  Non- 


 Dis 
 patch/  AL( 


 hours) 


 0.55 
 0.28 
 0.57 


 0.62 
 0.62 


 1 


 B.  2.21.17.1.2 
 LNP 
 (Standalone)/<  10 


 circuits/  Non- 


 Dis 
 patch/  AL( 


 hours) 


 0.55 
 0.46 
 0.57 
 0.46 
 0.62 
 0.49 
 0.62 
 0.51 


 B.  2.21.17.2.2 
 LNP 
 (Standalone)/>=  10 


 circuits/  Non- 


 Dis 
 patch/  AL( 


 hours) 


 0.47 
 0.02 
 0.51 


 43.08 
 0.50 
 0.53 
 0.57 
 1,3,4 


 B.  2.21.18.1.1 
 Digital 
 Loop 
 < 
 DS1/<  10 


 circuits/  Dispatch/ 


 AL(  hours) 
 13.85 
 21.50 
 23.84 


 5.85 
 12.54 


 9.60 
 13.82 


 11.64 


 B.  2.21.19.1.1 
 Digital 
 Loop 
 >= 
 DS1/<  10 


 circuits/  Dispatch/ 


 AL(  hours) 
 231.29 
 29.88 
 143.05 


 37.69 
 425.46 


 31.46 
 207.00 


 40.29 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Non-  Mechanized 


 [P-  5] 


 B.  2.22.2.1.1 
 Local 
 Interoffice 


 Transport/<  10 


 circuits/  Dis 
 patch/  AL( 
 hours) 


 19.74 
 4 


 B.  2.22.3.1.1 
 Loop 
 + 
 Port 


 Combinations/<  10  circuits/  Dis  patch/  AL(  hours) 


 17.59 
 9.60 
 13.13 


 13.52 


 B.  2.22.3.1.2 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Non- 


 Dis 
 patch/  AL( 


 hours) 


 5.69 
 5.59 
 2.69 
 6.28 


 B.  2.22.3.1.3 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Switch 
 Based 


 Orders/  AL 
 (hours) 


 4.26 
 4.72 
 2.04 
 6.03 


 B.  2.22.3.1.4 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Dispatch 


 In/  AL 
 (hours) 


 8.38 
 10.32 


 5.53 
 7.43 


 B-  25 
198
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 June 


 March 
 May 
 April 


 Alabama 
 Performance 


 Metric 
 Data 


 B.  2.22.3.2.1 
 Loop 
 + 
 Port 


 Combinations/>=  10  circuits/  Dis  patch/  AL(  hours) 


 36.90 
 0.02 
 15.57 


 1,2,3 


 B.  2.22.3.2.2 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Non- 


 Dis 
 patch/  AL( 


 hours) 


 24.45 
 14.00 
 3,4 


 B.  2.22.3.2.3 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Switch 


 Based 
 Orders/  AL 


 (hours) 


 14.00 
 4 


 B.  2.22.3.2.4 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Dispatch 


 In/  AL 
 (hours) 


 24.45 
 3 


 B.  2.22.4.1.1 
 Combo 
 Other/<  10 


 circuits/  Dis 
 patch/  AL( 
 hours) 


 100.33 
 82.69 
 44.31 


 1,2,3 


 B.  2.22.5.1.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/<  10 


 circuits/  Dis 
 patch/  AL( 
 hours) 


 10.11 
 13.99 
 10.10 
 20.29 


 B.  2.22.6.1.1 
 UNE 
 ISDN/<  10 


 circuits/  Dis 
 patch/  AL( 
 hours) 


 47.61 
 15.17 
 18.00 
 17.07 
 1,2,3,4 


 B.  2.22.7.1.1 
 Line 
 Sharin  g/< 


 10 
 circuits/  Dispatch/ 


 AL( 
 hours) 


 0.65 
 0.02 
 0.02 
 0.02 
 1,2,3,4 


 B.  2.22.7.1.2 
 Line 
 Sharing/<  10 


 circuits/  Non- 
 Dispatch/  AL( 
 hours) 


 0.50 
 0.53 
 0.48 
 0.49 


 B.  2.22.8.1.1 
 2W 
 Analog 


 Loop 
 Design/<  10 


 circuits/  Dis 
 patch/  AL( 
 hours) 


 49.67 
 48.34 
 39.20 
 29.86 


 B.  2.22.12.1.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/<  10 


 circuits/  Dis 
 patch/  AL( 
 hours) 


 38.91 
 14.25 


 17.50 
 1,2,4 


 B.  2.22.14.1.1 
 Other 
 Desi  gn/< 


 10 
 circuits/  Dispatch/ 


 AL( 
 hours) 


 B.  2.22.15.1.1 
 Other 
 Non-  Design/< 


 10 
 circuits/  Dispatch/ 


 AL(  hours) 


 42.15 
 30.21 
 23.36 


 1,3 


 B.  2.22.15.1.2 
 Other 
 Non-  Design/< 


 10 
 circuits/  Non- 


 Dis 
 patch/  AL( 


 hours) 


 B.  2.22.16.1.2 
 INP 
 (Standalone)/<  10 


 circuits/  Non- 


 Dis 
 patch/  AL( 


 hours) 


 0.72 
 34.45 


 2,3 


 B.  2.22.17.1.2 
 LNP 
 (Standalone)/<  10 


 circuits/  Non- 


 Dis 
 patch/  AL( 


 hours) 


 2.75 
 1.71 
 0.94 
 0.94 


 B.  2.22.17.2.2 
 LNP 
 (Standalone)/>=  10 


 circuits/  Non- 


 Dis 
 patch/  AL( 


 hours) 


 0.64 
 0.27 
 0.46 
 0.65 
 1,2,3,4 


 B.  2.22.18.1.1 
 Digital 
 Loop 
 < 
 DS1/<  10 


 circuits/  Dispatch/ 


 AL(  hours) 


 11.65 
 14.02 
 10.58 
 20.10 


 B.  2.22.19.1.1 
 Digital 
 Loop 
 >= 
 DS1/<  10 


 circuits/  Dispatch/ 


 AL(  hours) 


 52.94 
 66.01 
 63.40 
 38.02 
 2,4 


 B-  26 
199
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 June 


 March 
 May 
 April 


 Alabama 
 Performance 


 Metric 
 Data 


 Service 
 Order 
 Accuracy 


 [P-  11] 


 B.  2.34.1.1.1 
 Desi 
 gn 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 AL(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  2.34.1.1.2 
 Design 
 (Specials)/<  10 


 circuits/  Non- 
 Dispatch/  AL(%) 


 100.00% 
 67.07% 
 69.33% 


 B.  2.34.1.2.1 
 Desi 
 gn 
 (Specials)/>=  10 


 circuits/  Dispatch/ 


 AL(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  2.34.1.2.2 
 Design 
 (Specials)/>=  10 


 circuits/  Non- 
 Dispatch/  AL(%) 


 100.00% 
 90.91% 
 3 


 B.  2.34.2.1.1 
 Loo  ps 
 Non-  Design/< 


 10 
 circuits/  Dispatch/ 


 AL(%) 


 98.18% 
 95.65% 
 96.00% 
 96.33% 


 B.  2.34.2.1.2 
 Loops 
 Non-  Design/< 


 10 
 circuits/  Non- 


 Dispatch/  AL(%) 


 99.09% 
 98.18% 
 100.00% 


 98.02% 


 B.  2.34.2.2.1 
 Loo  ps 
 Non-  Design/>= 


 10 
 circuits/  Dispatch/ 


 AL(%) 


 97.75% 
 89.81% 
 97.90% 
 97.73% 


 B.  2.34.2.2.2 
 Loops 
 Non-  Design/>= 


 10 
 circuits/  Non- 


 Dis 
 patch/  AL(%) 


 97.20% 
 97.98% 
 98.73% 
 97.53% 


 UNBUNDLED 
 NETWORK 
 ELEMENTS 


 - 
 MAINTENANCE 


 AND 
 REPAIR 


 Missed 
 Repair 
 Appointments 


 [M&  R- 
 1] 


 B.  3.1.2.1 
 Local 
 Interoffice 


 Trans  port/ 
 Dispatch/  AL(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.33% 
 0.00% 
 0.00% 
 0.00% 


 4 


 B.  3.1.2.2 
 Local 
 Interoffice 


 Trans  port/ 
 Non-  Dispatch/ 


 AL(%) 
 0.00% 
 0.00% 
 0.54% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 3 


 B.  3.1.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  Dispatch/ 


 AL(%) 
 5.95% 
 3.14% 
 5.77% 
 4.00% 
 6.63% 
 6.24% 
 6.79% 
 8.88% 


 B.  3.1.3.2 
 Loo  p 
 + 
 Port 


 Combinations/  Non- 


 Dispatch/  AL(%) 


 1.43% 
 2.56% 
 1.32% 
 5.71% 
 1.45% 
 3.28% 
 1.65% 
 2.77% 


 B.  3.1.4.1 
 Combo 
 Other/  Dis 


 patch/  AL(%) 


 5.87% 
 0.00% 
 5.70% 
 0.00% 
 6.52% 
 0.00% 
 6.67% 
 0.00% 
 1,2,3,4 


 B.  3.1.4.2 
 Combo 
 Other/  Non- 


 Dis  patch/ 
 AL(%) 


 5.87% 
 0.00% 
 5.70% 
 0.00% 
 6.52% 
 0.00% 
 6.67% 
 0.00% 
 1,2,3,4 


 B.  3.1.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Dispatch/ 


 AL(%) 
 50.51% 
 0.00% 
 49.87% 


 0.00% 
 51.90% 


 0.00% 
 49.79% 


 0.00% 
 1,2,4 


 B.  3.1.5.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Non- 


 Dispatch/  AL(%) 


 3.75% 
 0.00% 
 3.51% 
 0.00% 
 2.40% 
 0.00% 
 3.16% 
 0.00% 
 2,3,4 


 B.  3.1.6.1 
 UNE 
 ISDN/  Dis 


 patch/  AL(%) 


 9.68% 
 10.00% 


 7.50% 
 0.00% 
 18.52% 


 0.00% 
 5.00% 
 0.00% 


 2,4 


 B.  3.1.6.2 
 UNE 
 ISDN/  Non- 


 Dis 
 patch/  AL(%) 


 2.20% 
 0.00% 
 1.61% 
 0.00% 
 0.00% 
 9.09% 
 0.00% 
 0.00% 
 1,2,4 


 B.  3.1.7.1 
 Line 
 Sharin  g/ 


 Dispatch/  AL(%) 


 50.51% 
 0.00% 
 49.87% 
 100.00% 


 51.90% 
 0.00% 
 49.79% 


 0.00% 
 2,3 


 B.  3.1.7.2 
 Line 
 Sharin  g/ 


 Non-  Dispatch/ 


 AL(%) 


 3.75% 
 0.00% 
 3.51% 
 0.00% 
 2.40% 
 0.00% 
 3.16% 
 50.00% 
 1,2,3,4 


 B.  3.1.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  Dispatch/ 


 AL(%) 


 5.95% 
 1.69% 
 5.77% 
 2.35% 
 6.63% 
 2.25% 
 6.79% 
 11.54% 


 B.  3.1.8.2 
 2W 
 Analo  g 


 Loop 
 Design/  Non- 


 Dispatch/  AL(%) 


 5.95% 
 0.00% 
 5.77% 
 0.00% 
 6.63% 
 0.00% 
 6.79% 
 0.00% 


 B.  3.1.9.1 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 Dispatch/  AL(%) 


 5.82% 
 0.00% 
 5.57% 
 0.00% 
 6.49% 
 0.00% 
 6.65% 
 0.00% 


 B.  3.1.9.2 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 Non-  Dispatch/ 


 AL(%) 
 1.32% 
 0.00% 
 1.12% 
 0.00% 
 1.36% 
 0.00% 
 1.22% 
 0.00% 


 B-  27 
200
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 June 


 March 
 May 
 April 


 Alabama 
 Performance 


 Metric 
 Data 


 B.  3.1.10.1 
 Other 
 Design/  Dispatch/ 


 AL(%) 


 2.78% 
 0.00% 
 2.38% 
 0.00% 
 2.38% 
 0.00% 
 1.58% 
 0.00% 


 B.  3.1.10.2 
 Other 
 Desi  gn/ 


 Non-  Dispatch/ 


 AL(%) 


 0.65% 
 0.00% 
 0.60% 
 0.00% 
 0.51% 
 0.00% 
 0.62% 
 0.00% 


 B.  3.1.11.1 
 Other 
 Non-  Desi 


 gn/  Dispatch/ 


 AL(%) 


 5.95% 
 0.00% 
 5.77% 
 33.33% 


 6.63% 
 50.00% 


 6.79% 
 0.00% 


 2,3 


 B.  3.1.11.2 
 Other 
 Non-  Desi 


 gn/  Non- 
 Dispatch/  AL(%) 


 1.43% 
 0.00% 
 1.32% 
 100.00% 


 1.45% 
 0.00% 
 1.65% 
 0.00% 


 2,3 


 Customer 
 Trouble 
 Report 
 Rate 
 [M&  R- 


 2] 


 B.  3.2.2.1 
 Local 
 Interoffice 


 Trans  port/ 
 Dispatch/  AL(%) 


 1.90% 
 0.00% 
 1.91% 
 0.00% 
 2.22% 
 0.00% 
 1.99% 
 1.75% 


 B.  3.2.2.2 
 Local 
 Interoffice 


 Trans  port/ 
 Non-  Dispatch/ 


 AL(%) 
 1.38% 
 0.00% 
 1.37% 
 0.00% 
 1.53% 
 1.82% 
 1.62% 
 0.00% 


 B.  3.2.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  Dispatch/ 


 AL(%) 
 1.57% 
 1.13% 
 1.68% 
 1.31% 
 1.83% 
 1.26% 
 1.74% 
 1.40% 


 B.  3.2.3.2 
 Loo  p 
 + 
 Port 


 Combinations/  Non- 


 Dispatch/  AL(%) 


 0.91% 
 0.38% 
 0.86% 
 0.43% 
 1.02% 
 0.40% 
 1.06% 
 0.45% 


 B.  3.2.4.1 
 Combo 
 Other/  Dis 


 patch/  AL(%) 


 1.35% 
 2.06% 
 1.44% 
 6.50% 
 1.58% 
 2.40% 
 1.49% 
 4.10% 


 B.  3.2.4.2 
 Combo 
 Other/  Non- 


 Dis  patch/ 
 AL(%) 


 1.35% 
 3.09% 
 1.44% 
 4.07% 
 1.58% 
 1.60% 
 1.49% 
 4.10% 


 B.  3.2.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Dispatch/ 


 AL(%) 
 0.87% 
 0.32% 
 1.11% 
 0.39% 
 1.27% 
 0.70% 
 1.26% 
 0.38% 


 B.  3.2.5.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Non- 


 Dispatch/  AL(%) 


 1.18% 
 0.00% 
 2.08% 
 0.13% 
 2.22% 
 0.06% 
 2.45% 
 0.54% 


 B.  3.2.6.1 
 UNE 
 ISDN/  Dis 


 patch/  AL(%) 


 0.39% 
 1.03% 
 0.51% 
 0.72% 
 0.70% 
 1.19% 
 0.53% 
 0.68% 


 B.  3.2.6.2 
 UNE 
 ISDN/  Non- 


 Dis 
 patch/  AL(%) 


 1.15% 
 0.41% 
 0.79% 
 0.92% 
 0.87% 
 1.09% 
 0.86% 
 0.19% 


 B.  3.2.7.1 
 Line 
 Sharin  g/ 


 Dispatch/  AL(%) 


 0.87% 
 0.00% 
 1.11% 
 0.18% 
 1.27% 
 0.52% 
 1.26% 
 0.00% 


 B.  3.2.7.2 
 Line 
 Sharin  g/ 


 Non-  Dispatch/ 


 AL(%) 


 1.18% 
 1.11% 
 2.08% 
 0.71% 
 2.22% 
 0.35% 
 2.45% 
 0.34% 


 B.  3.2.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  Dispatch/ 


 AL(%) 


 1.57% 
 0.48% 
 1.68% 
 0.69% 
 1.83% 
 0.74% 
 1.74% 
 0.66% 


 B.  3.2.8.2 
 2W 
 Analo  g 


 Loop 
 Design/  Non- 


 Dispatch/  AL(%) 


 1.57% 
 0.16% 
 1.68% 
 0.13% 
 1.83% 
 0.16% 
 1.74% 
 0.10% 


 B.  3.2.9.1 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 Dispatch/  AL(%) 


 1.67% 
 0.00% 
 1.78% 
 0.00% 
 1.96% 
 0.00% 
 1.85% 
 0.00% 


 B.  3.2.9.2 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 Non-  Dispatch/ 


 AL(%) 
 0.86% 
 0.00% 
 0.82% 
 0.00% 
 1.00% 
 0.00% 
 0.98% 
 0.00% 


 B.  3.2.10.1 
 Other 
 Desi  gn/ 
 Dispatch/  AL(%) 


 0.20% 
 0.00% 
 0.20% 
 0.00% 
 0.24% 
 0.00% 
 0.21% 
 0.00% 
 1,2,3,4 


 B.  3.2.10.2 
 Other 
 Desi  gn/ 


 Non-  Dispatch/ 


 AL(%) 


 0.27% 
 0.00% 
 0.30% 
 0.00% 
 0.29% 
 0.00% 
 0.29% 
 0.00% 
 1,2,3,4 


 B.  3.2.11.1 
 Other 
 Non-  Desi 


 gn/  Dispatch/ 


 AL(%) 


 1.57% 
 0.00% 
 1.68% 
 0.20% 
 1.83% 
 0.13% 
 1.74% 
 0.00% 


 B.  3.2.11.2 
 Other 
 Non-  Desi 


 gn/  Non- 
 Dispatch/  AL(%) 


 0.91% 
 0.00% 
 0.86% 
 0.07% 
 1.02% 
 0.07% 
 1.06% 
 0.00% 


 Maintenance 
 Average 
 Duration 


 [M&  R- 
 3] 


 B.  3.3.2.1 
 Local 
 Interoffice 


 Trans  port/ 
 Dispatch/  AL( 


 hours) 


 3.60 
 0.00 
 3.47 
 0.00 
 3.81 
 0.00 
 3.68 
 6.07 


 4 


 B.  3.3.2.2 
 Local 
 Interoffice 


 Transport/  Non- 


 Dispatch/  AL( 
 hours) 
 1.65 
 0.00 
 1.44 
 0.00 
 1.61 
 0.40 
 1.62 
 0.00 


 3 


 B.  3.3.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  Dispatch/ 


 AL( 
 hours) 


 20.54 
 10.46 
 21.25 
 10.62 
 24.51 
 11.23 
 23.46 
 14.44 


 B-  28 
201
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 June 


 March 
 May 
 April 


 Alabama 
 Performance 


 Metric 
 Data 


 B.  3.3.3.2 
 Loop 
 + 
 Port 


 Combinations/  Non- 


 Dispatch/  AL( 
 hours) 
 8.22 
 4.00 
 8.10 
 4.88 
 10.19 


 5.26 
 9.80 
 4.01 


 B.  3.3.4.1 
 Combo 
 Other/  Dis 


 patch/  AL( 
 hours) 


 20.19 
 4.04 
 20.91 


 3.76 
 24.05 


 6.57 
 23.06 


 5.97 
 1,2,3,4 


 B.  3.3.4.2 
 Combo 
 Other/  Non- 


 Dis  patch/ 
 AL( 
 hours) 


 20.19 
 1.47 
 20.91 


 1.60 
 24.05 


 4.78 
 23.06 


 2.50 
 1,2,3,4 


 B.  3.3.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Dispatch/ 


 AL(  hours) 
 48.03 
 2.77 
 41.83 


 3.07 
 51.68 


 3.54 
 97.86 


 6.83 
 1,2,4 


 B.  3.3.5.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Non- 


 Dispatch/  AL( 
 hours) 


 4.11 
 0.00 
 3.56 
 0.14 
 1.97 
 1.13 
 3.12 
 2.03 
 2,3,4 


 B.  3.3.6.1 
 UNE 
 ISDN/  Dis 


 patch/  AL( 
 hours) 


 10.27 
 6.20 
 10.62 


 4.62 
 12.95 


 5.61 
 10.11 


 3.58 
 2,4 


 B.  3.3.6.2 
 UNE 
 ISDN/  Non- 


 Dis 
 patch/  AL( 


 hours) 


 3.74 
 5.75 
 3.54 
 6.10 
 3.29 
 7.57 
 2.84 
 1.53 
 1,2,4 


 B.  3.3.7.1 
 Line 
 Sharin  g/ 


 Dispatch/  AL( 


 hours) 


 48.03 
 0.00 
 41.83 


 70.00 
 51.68 
 13.33 
 97.86 


 0.00 
 2,3 


 B.  3.3.7.2 
 Line 
 Sharin  g/ 


 Non-  Dispatch/ 


 AL( 
 hours) 


 4.11 
 11.28 


 3.56 
 12.00 


 1.97 
 9.00 
 3.12 
 28.00 
 1,2,3,4 


 B.  3.3.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  Dispatch/ 


 AL( 
 hours) 


 20.54 
 5.82 
 21.25 


 5.50 
 24.51 


 4.72 
 23.46 


 8.40 


 B.  3.3.8.2 
 2W 
 Analog 


 Loop 
 Design/  Non- 


 Dispatch/  AL( 


 hours) 
 20.54 
 1.15 
 21.25 


 2.64 
 24.51 


 3.03 
 23.46 


 2.73 


 B.  3.3.9.1 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 Dispatch/  AL( 


 hours) 
 20.61 
 0.00 
 21.35 


 0.00 
 24.63 


 0.00 
 23.58 


 0.00 


 B.  3.3.9.2 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 Non- 


 Dis 
 patch/  AL( 


 hours) 


 8.88 
 0.00 
 8.65 
 0.00 
 10.92 


 0.00 
 10.56 


 0.00 


 B.  3.3.10.1 
 Other 
 Desi  gn/ 
 Dispatch/  AL( 


 hours) 


 5.81 
 0.00 
 5.81 
 0.00 
 5.68 
 0.00 
 5.61 
 0.00 


 B.  3.3.10.2 
 Other 
 Desi  gn/ 


 Non-  Dispatch/ 


 AL( 
 hours) 


 2.51 
 0.00 
 2.28 
 0.00 
 2.55 
 0.00 
 2.53 
 0.00 


 B.  3.3.11.1 
 Other 
 Non-  Desi 


 gn/  Dispatch/ 


 AL( 
 hours) 


 20.54 
 0.00 
 21.25 


 13.00 
 24.51 
 41.50 
 23.46 


 0.00 
 2,3 


 B.  3.3.11.2 
 Other 
 Non-  Desi 


 gn/  Non- 
 Dispatch/  AL( 


 hours) 


 8.22 
 0.00 
 8.10 
 24.00 


 10.19 


 5.00 
 9.80 
 0.00 
 2,3 


 % 
 Repeat 


 Troubles 


 within 
 30 
 Days 


 [M&  R- 


 4] 


 B.  3.4.2.1 
 Local 
 Interoffice 


 Trans  port/ 
 Dispatch/  AL(%) 


 27.06% 
 0.00% 
 24.12% 


 0.00% 
 19.27% 


 0.00% 
 25.00% 


 0.00% 


 4 


 B.  3.4.2.2 
 Local 
 Interoffice 


 Trans  port/ 
 Non-  Dispatch/ 


 AL(%) 
 16.13% 
 0.00% 
 24.32% 


 0.00% 
 16.35% 


 0.00% 
 20.27% 


 0.00% 


 3 


 B.  3.4.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  Dispatch/ 


 AL(%) 
 16.12% 
 14.12% 
 17.34% 
 17.67% 
 17.38% 
 12.01% 
 17.34% 
 10.06% 


 B.  3.4.3.2 
 Loo  p 
 + 
 Port 


 Combinations/  Non- 


 Dispatch/  AL(%) 


 14.16% 
 14.10% 
 14.96% 
 18.57% 
 15.49% 
 11.31% 
 16.03% 
 15.08% 


 B.  3.4.4.1 
 Combo 
 Other/  Dis 


 patch/  AL(%) 


 16.23% 
 0.00% 
 17.42% 
 12.50% 
 17.43% 
 0.00% 
 17.39% 
 20.00% 
 1,2,3,4 


 B.  3.4.4.2 
 Combo 
 Other/  Non- 


 Dis  patch/ 
 AL(%) 


 16.23% 
 33.33% 
 17.42% 
 20.00% 
 17.43% 
 0.00% 
 17.39% 


 0.00% 
 1,2,3,4 


 B.  3.4.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Dispatch/ 


 AL(%) 
 16.16% 
 0.00% 
 23.80% 


 0.00% 
 24.26% 


 0.00% 
 23.05% 
 40.00% 
 1,2,4 


 B.  3.4.5.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Non- 


 Dispatch/  AL(%) 


 16.00% 
 0.00% 
 23.78% 


 0.00% 
 24.76% 


 0.00% 
 26.48% 


 0.00% 
 2,3,4 


 B.  3.4.6.1 
 UNE 
 ISDN/  Dis 


 patch/  AL(%) 


 9.68% 
 0.00% 
 22.50% 
 28.57% 
 25.93% 
 0.00% 
 5.00% 
 28.57% 


 2,4 


 B-  29 
202
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 June 


 March 
 May 
 April 


 Alabama 
 Performance 


 Metric 
 Data 


 B.  3.4.6.2 
 UNE 
 ISDN/  Non- 


 Dispatch/  AL(%) 


 15.38% 
 0.00% 
 12.90% 
 11.11% 
 7.46% 
 18.18% 
 10.77% 
 0.00% 
 1,2,4 


 B.  3.4.7.1 
 Line 
 Sharin  g/ 


 Dispatch/  AL(%) 


 16.16% 
 0.00% 
 23.80% 


 0.00% 
 24.26% 
 66.67% 
 23.05% 
 0.00% 
 2,3 


 B.  3.4.7.2 
 Line 
 Sharin  g/ 


 Non-  Dispatch/ 


 AL(%) 


 16.00% 
 16.67% 
 23.78% 
 0.00% 
 24.76% 


 0.00% 
 26.48% 


 0.00% 
 1,2,3,4 


 B.  3.4.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  Dispatch/ 


 AL(%) 


 16.12% 
 10.17% 
 17.34% 
 3.53% 
 17.38% 


 2.25% 
 17.34% 


 3.85% 


 B.  3.4.8.2 
 2W 
 Analo  g 


 Loop 
 Design/  Non- 


 Dispatch/  AL(%) 


 16.12% 
 5.00% 
 17.34% 
 12.50% 
 17.38% 
 5.26% 
 17.34% 


 0.00% 


 B.  3.4.9.1 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 Dispatch/  AL(%) 


 16.12% 
 0.00% 
 17.36% 


 0.00% 
 17.42% 


 0.00% 
 17.37% 


 0.00% 


 B.  3.4.9.2 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 Non-  Dispatch/ 


 AL(%) 
 14.17% 


 0.00% 
 15.38% 


 0.00% 
 15.84% 


 0.00% 
 15.29% 


 0.00% 


 B.  3.4.10.1 
 Other 
 Desi  gn/ 
 Dispatch/  AL(%) 


 20.61% 
 0.00% 
 21.13% 


 0.00% 
 19.77% 


 0.00% 
 19.57% 


 0.00% 


 B.  3.4.10.2 
 Other 
 Desi  gn/ 


 Non-  Dispatch/ 


 AL(%) 


 17.12% 
 0.00% 
 14.86% 


 0.00% 
 12.10% 


 0.00% 
 14.23% 


 0.00% 


 B.  3.4.11.1 
 Other 
 Non-  Desi 


 gn/  Dispatch/ 


 AL(%) 


 16.12% 
 0.00% 
 17.34% 
 33.33% 
 17.38% 
 50.00% 
 17.34% 
 0.00% 
 2,3 


 B.  3.4.11.2 
 Other 
 Non-  Desi 


 gn/  Non- 
 Dispatch/  AL(%) 


 14.16% 
 0.00% 
 14.96% 


 0.00% 
 15.49% 


 0.00% 
 16.03% 


 0.00% 
 2,3 


 Out 
 of 
 Service 


 > 
 24 


 hours 


 [M&  R- 


 5] 


 B.  3.5.2.1 
 Local 
 Interoffice 


 Trans  port/ 
 Dispatch/  AL(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.33% 
 0.00% 
 0.00% 
 0.00% 


 4 


 B.  3.5.2.2 
 Local 
 Interoffice 


 Trans  port/ 
 Non-  Dispatch/ 


 AL(%) 
 0.00% 
 0.00% 
 0.54% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 3 


 B.  3.5.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  Dispatch/ 


 AL(%) 
 24.54% 
 6.77% 
 26.66% 


 7.32% 
 32.08% 


 9.73% 
 32.70% 
 16.02% 


 B.  3.5.3.2 
 Loo  p 
 + 
 Port 


 Combinations/  Non- 


 Dispatch/  AL(%) 


 14.41% 
 1.94% 
 15.86% 


 5.51% 
 19.40% 


 7.30% 
 17.41% 


 4.80% 


 B.  3.5.4.1 
 Combo 
 Other/  Dis 


 patch/  AL(%) 


 23.73% 
 0.00% 
 25.83% 


 0.00% 
 30.99% 


 0.00% 
 31.66% 


 0.00% 
 1,2,3,4 


 B.  3.5.4.2 
 Combo 
 Other/  Non- 


 Dis  patch/ 
 AL(%) 


 23.73% 
 0.00% 
 25.83% 


 0.00% 
 30.99% 


 0.00% 
 31.66% 


 0.00% 
 1,2,3,4 


 B.  3.5.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Dispatch/ 


 AL(%) 
 50.51% 
 0.00% 
 49.87% 


 0.00% 
 51.90% 


 0.00% 
 49.79% 


 0.00% 
 1,2,4 


 B.  3.5.5.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Non- 


 Dispatch/  AL(%) 


 3.75% 
 0.00% 
 3.51% 
 0.00% 
 2.40% 
 0.00% 
 3.16% 
 0.00% 
 2,3,4 


 B.  3.5.6.1 
 UNE 
 ISDN/  Dis 


 patch/  AL(%) 


 9.68% 
 10.00% 


 7.50% 
 0.00% 
 18.52% 


 0.00% 
 5.00% 
 0.00% 


 2,4 


 B.  3.5.6.2 
 UNE 
 ISDN/  Non- 


 Dis 
 patch/  AL(%) 


 2.22% 
 0.00% 
 1.61% 
 0.00% 
 0.00% 
 9.09% 
 0.00% 
 0.00% 
 1,2,4 


 B.  3.5.7.1 
 Line 
 Sharin  g/ 


 Dispatch/  AL(%) 


 50.51% 
 0.00% 
 49.87% 


 0.00% 
 51.90% 


 0.00% 
 49.79% 


 0.00% 


 B.  3.5.7.2 
 Line 
 Sharin  g/ 


 Non-  Dispatch/ 


 AL(%) 


 3.75% 
 0.00% 
 3.51% 
 0.00% 
 2.40% 
 0.00% 
 3.16% 
 0.00% 


 B.  3.5.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  Dispatch/ 


 AL(%) 


 24.54% 
 1.69% 
 26.66% 


 2.35% 
 32.08% 


 2.25% 
 32.70% 
 11.54% 


 B.  3.5.8.2 
 2W 
 Analo  g 


 Loop 
 Design/  Non- 


 Dispatch/  AL(%) 


 24.54% 
 0.00% 
 26.66% 


 0.00% 
 32.08% 


 0.00% 
 32.70% 


 0.00% 


 B.  3.5.9.1 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 Dispatch/  AL(%) 


 24.65% 
 0.00% 
 26.84% 


 0.00% 
 32.27% 


 0.00% 
 32.85% 


 0.00% 


 B.  3.5.9.2 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 Non-  Dispatch/ 


 AL(%) 
 14.66% 


 0.00% 
 16.27% 


 0.00% 
 19.74% 


 0.00% 
 17.74% 


 0.00% 


 B.  3.5.10.1 
 Other 
 Desi  gn/ 
 Dispatch/  AL(%) 


 2.78% 
 0.00% 
 2.38% 
 0.00% 
 2.38% 
 0.00% 
 1.58% 
 0.00% 


 B.  3.5.10.2 
 Other 
 Desi  gn/ 


 Non-  Dispatch/ 


 AL(%) 


 0.65% 
 0.00% 
 0.60% 
 0.00% 
 0.51% 
 0.00% 
 0.62% 
 0.00% 


 B.  3.5.11.1 
 Other 
 Non-  Desi 


 gn/  Dispatch/ 


 AL(%) 


 24.54% 
 0.00% 
 26.66% 


 0.00% 
 32.08% 
 50.00% 
 32.70% 
 0.00% 
 2,3 


 B-  30 
203
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 June 


 March 
 May 
 April 


 Alabama 
 Performance 


 Metric 
 Data 


 B.  3.5.11.2 
 Other 
 Non-  Design/ 


 Non-  Dispatch/ 


 AL(%) 


 14.41% 
 0.00% 
 15.86% 


 0.00% 
 19.40% 


 0.00% 
 17.41% 


 0.00% 
 2,3 


 UNBUNDLED 
 NETWORK 
 ELEMENTS 


 - 
 BILLING 


 Invoice 
 Accuracy 


 [B-  1] 


 B.  4.1 
 AL 
 (%) 


 99.13% 
 98.43% 
 99.33% 
 99.66% 
 98.94% 
 98.44% 
 98.33% 
 99.99% 


 Mean 
 Time 
 to 
 Deliver 


 Invoices 


 - 
 CRIS 


 [B-  2] 


 B.  4.2 
 Re  gion( 
 business 


 days) 


 3.68 
 7.29 
 3.86 
 4.97 
 3.47 
 3.78 
 3.82 
 3.46 


 LOCAL 
 INTERCONNECTION 


 TRUNKS 
 - 
 ORDERING 


 % 
 Rejected 


 Service 
 Requests 


 [O-  7] 


 C.  1.1 
 Local 
 Interconnection 


 Trunks/  AL 
 (%) 


 50.00% 
 34.15% 
 76.92% 
 45.83% 


 Reject 
 Interval 


 [O-  8] 


 C.  1.2 
 Local 
 Interconnection 


 Trunks/  AL 
 (%) 


 90.00% 
 100.00% 
 100.00% 
 100.00% 


 FOC 
 Timeliness 


 [O-  9] 


 C.  1.3 
 Local 
 Interconnection 


 Trunks/  AL 
 (%) 


 97.06% 
 100.00% 


 100.00% 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 [O-  11] 


 C.  1.4 
 Local 
 Interconnection 


 Trunks/  AL 
 (%) 


 92.31% 
 100.00% 
 100.00% 
 100.00% 


 LOCAL 
 INTERCONNECTION 


 TRUNKS 
 - 
 PROVISIONING 


 Order 
 Completion 


 Interval 
 [P-  4] 


 C.  2.1 
 Local 
 Interconnection 


 Trunks/  AL 
 (days) 


 42.37 
 25.74 
 20.21 
 26.08 
 21.85 
 16.06 
 19.11 
 21.33 
 3,4 


 Held 
 Orders 


 [P-  1] 


 C.  2.2 
 Local 
 Interconnection 


 Trunks/  AL 
 (days) 


 0.00 
 0.00 
 0.00 
 0.00 
 0.00 
 0.00 
 0.00 
 0.00 


 % 
 Jeopardies 


 [P-  2] 


 C.  2.3 
 Local 
 Interconnection 


 Trunks/  AL 
 (%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 3,4 


 Average 
 Jeopardy 


 Notice 
 Interval 


 [P-  2] 


 % 
 Missed 


 Installation 


 Appointments 


 [P-  3] 


 C.  2.5 
 Local 
 Interconnection 


 Trunks/  AL 
 (%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 3,4 


 % 
 Provisioning 


 Troubles 
 within 
 30 
 Days 


 [P-  9] 


 C.  2.6 
 Local 
 Interconnection 


 Trunks/  AL 
 (%) 


 1.45% 
 0.00% 
 0.12% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 Average 
 Completion 


 Notice 
 Interval 


 [P-  5] 


 C.  2.7 
 Local 
 Interconnection 


 Trunks/  AL 
 (hours) 


 173.25 
 63.31 
 247.83 


 6.31 
 137.95 


 0.12 
 123.66 


 19.65 
 3,4 


 Total 
 Service 


 Order 
 Cycle 
 Time 
 [P-  10] 


 C.  2.8 
 Local 
 Interconnection 


 Trunks/  AL 
 (days) 


 26.79 
 22.58 
 17.51 
 22.91 
 2,3,4 


 % 
 Completions 


 w/  o 
 Notice 


 or 
 < 
 24 


 hours 


 [P-  6] 


 C.  2.10.1 
 Local 
 Interconnection 


 Trunks/  Dis 
 patch/  AL(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 3,4 


 B-  31 
204
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 June 


 March 
 May 
 April 


 Alabama 
 Performance 


 Metric 
 Data 


 C.  2.10.2 
 Local 
 Interconnection 


 Trunks/  Non- 
 Dispatch/  AL(%) 


 0.00% 
 3 


 Service 
 Order 
 Accuracy 


 [P-  11] 


 C.  2.11.1.1 
 Local 
 Interconnection 


 Trunks/<  10 


 circuits/  Dis 
 patch/  AL(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 C.  2.11.1.2 
 Local 
 Interconnection 


 Trunks/<  10 
 circuits/  Non- 


 Dis 
 patch/  AL(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 C.  2.11.2.1 
 Local 
 Interconnection 


 Trunks/>=  10 


 circuits/  Dis 
 patch/  AL(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,4 


 C.  2.11.2.2 
 Local 
 Interconnection 


 Trunks/>=  10 
 circuits/  Non- 


 Dis 
 patch/  AL(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2 


 LOCAL 
 INTERCONNECTION 


 TRUNKS 
 - 
 MAINTENANCE 


 AND 
 REPAIR 


 Missed 
 Repair 
 Appointments 


 [M&  R- 
 1] 


 C.  3.1.1 
 Local 
 Interconnection 


 Trunks/  Dis 
 patch/  AL(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 C.  3.1.2 
 Local 
 Interconnection 


 Trunks/  Non- 
 Dispatch/  AL(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 4 


 Customer 
 Trouble 
 Report 
 Rate 
 [M&  R- 


 2] 


 C.  3.2.1 
 Local 
 Interconnection 


 Trunks/  Dis 
 patch/  AL(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 C.  3.2.2 
 Local 
 Interconnection 


 Trunks/  Non- 
 Dispatch/  AL(%) 


 0.02% 
 0.00% 
 0.10% 
 0.00% 
 0.08% 
 0.00% 
 0.04% 
 0.01% 


 Maintenance 
 Average 
 Duration 


 [M&  R- 
 3] 


 C.  3.3.1 
 Local 
 Interconnection 


 Trunks/  Dispatch/ 


 AL(  hours) 


 0.00 
 0.00 
 0.00 
 0.00 
 0.00 
 0.00 
 0.00 
 0.00 


 C.  3.3.2 
 Local 
 Interconnection 


 Trunks/  Non- 


 Dis 
 patch/  AL( 


 hours) 


 0.75 
 0.00 
 0.27 
 0.00 
 0.17 
 0.00 
 0.31 
 10.52 


 4 


 % 
 Repeat 


 Troubles 


 within 
 30 
 Days 


 [M&  R- 


 4] 


 C.  3.4.1 
 Local 
 Interconnection 


 Trunks/  Dis 
 patch/  AL(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 C.  3.4.2 
 Local 
 Interconnection 


 Trunks/  Non- 
 Dispatch/  AL(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 4 


 Out 
 of 
 Service 


 > 
 24 


 hours 


 [M&  R- 


 5] 


 C.  3.5.1 
 Local 
 Interconnection 


 Trunks/  Dis 
 patch/  AL(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 C.  3.5.2 
 Local 
 Interconnection 


 Trunks/  Non- 
 Dispatch/  AL(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 4 


 B-  32 
205
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 June 


 March 
 May 
 April 


 Alabama 
 Performance 


 Metric 
 Data 


 LOCAL 
 INTERCONNECTION 


 TRUNKS 
 - 
 BILLING 


 Invoice 
 Accuracy 


 [B-  1] 


 C.  4.1 
 AL 
 (%) 


 99.13% 
 99.97% 
 99.33% 
 95.88% 
 98.94% 
 95.42% 
 98.33% 
 97.11% 


 Mean 
 Time 
 to 
 Deliver 


 Invoices 


 - 
 CABS 


 [B-  2] 


 C.  4.2 
 Re  gion( 
 calendar 


 days) 


 4.84 
 4.54 
 3.94 
 3.89 
 4.96 
 4.92 
 4.54 
 4.29 


 LOCAL 
 INTERCONNECTION 


 TRUNKS 
 - 
 TRUNK 


 BLOCKING 


 Trunk 
 Group 
 Performance 


 - 
 Aggregate 


 [TGP-  1] 


 C.  5.1 
 AL 


 0 
 0 
 0 
 0 


 OPERATIONS 
 SUPPORT 
 SYSTEMS 
 - 
 PRE-  ORDERING 


 % 
 Interface 


 Availability 


 - 
 CLEC 


 [OSS-  2] 


 D.  1.1.1 
 EDI/  Re 
 gion(%) 


 99.71% 
 100.00% 


 99.64% 
 100.00% 


 D.  1.1.2 
 HAL/  Re 
 gion(%) 


 100.00% 
 100.00% 


 D.  1.1.3 
 LENS/  Re 
 gion(%) 


 99.99% 
 99.98% 
 99.85% 
 99.76% 


 D.  1.1.4 
 LEO 
 MAINFRAME/  Re 


 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 D.  1.1.5 
 LEO 
 UNIX/  Re 


 gion(%) 


 D.  1.1.6 
 LESOG/  Region(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 D.  1.1.7 
 TAG/  Re 
 gion(%) 


 100.00% 
 99.95% 
 99.99% 
 99.86% 


 D.  1.1.8 
 PSIMS/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 % 
 Interface 


 Availability 


 - 
 BST 


 & 
 CLEC 


 [OSS-  2] 


 D.  1.2.1 
 ATLAS/  COFFI/ 


 Re 
 gion(%) 


 100.00% 
 100.00% 


 D.  1.2.2 
 BOCRIS/  Re 
 gion(%) 


 100.00% 
 100.00% 
 99.96% 
 99.99% 


 D.  1.2.3 
 DSAP/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.98% 


 D.  1.2.4 
 RSAG/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.99% 


 D.  1.2.5 
 SOCS/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.99% 


 D.  1.2.6 
 SONGS/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.86% 


 D.  1.2.7 
 DOE/  Re 
 gion(%) 


 99.99% 
 99.99% 
 99.99% 
 99.26% 


 D.  1.2.8 
 LNP 
 Gatewa 


 y/  Region(%) 


 100.00% 
 99.99% 
 100.00% 


 99.49% 


 D.  1.2.9 
 COG/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.48% 


 D.  1.2.10 
 DOM/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.99% 


 D.  1.2.11 
 SOG/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 D.  1.2.1- 
 new 
 ATLAS/  Region 


 (%) 


 100.00% 
 99.99% 


 D.  1.2.2- 
 new 
 COFFI/  Region 


 (%) 


 100.00% 
 99.99% 


 Average 
 Response 


 Interval 
 - 
 CLEC 


 (LENS) 


 (BST 
 Measure 


 Includes 
 Additional 


 2 
 Seconds) 


 [OSS-  1] 


 B-  33 
206
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 June 


 March 
 May 
 April 


 Alabama 
 Performance 


 Metric 
 Data 


 D.  1.3.1.1 
 RSAG, 
 by 
 TN/  Region( 


 seconds) 


 1440.12 
 0.91 
 1782.46 


 1.11 
 2.87 
 1.20 
 2.88 
 1.02 


 D.  1.3.1.2 
 RSAG, 
 b 
 y 


 TN/  Region( 


 seconds) 


 2.96 
 0.91 
 2.95 
 1.11 
 2.94 
 1.20 
 2.91 
 1.02 


 D.  1.3.2.1 
 RSAG, 
 b 
 y 
 ADDR/  Region( 


 seconds) 


 712.69 
 0.91 
 1204.18 


 1.02 
 2.99 
 1.10 
 3.03 
 0.93 


 D.  1.3.2.2 
 RSAG, 
 b 
 y 
 ADDR/  Region( 


 seconds) 


 4.82 
 0.91 
 4.86 
 1.02 
 4.77 
 1.10 
 4.76 
 0.93 


 D.  1.3.3.1 
 ATLAS/  Re 
 gion( 
 seconds) 


 1330.23 
 0.88 
 2.95 
 0.88 
 2.95 
 0.88 
 3.01 
 0.80 


 D.  1.3.3.2 
 ATLAS/  Re 
 gion( 
 seconds) 


 2.61 
 0.88 
 2.61 
 0.88 
 2.60 
 0.88 
 2.61 
 0.80 


 D.  1.3.4.1 
 DSAP/  Re 
 gion( 
 seconds) 


 2.68 
 0.53 
 2.70 
 0.57 
 2.71 
 0.53 
 2.71 
 0.52 


 D.  1.3.4.2 
 DSAP/  Re 
 gion( 
 seconds) 


 2.58 
 0.53 
 2.58 
 0.57 
 2.57 
 0.53 
 2.57 
 0.52 


 D.  1.3.5.1 
 CRSECSRL/  Re 


 gion( 
 seconds) 


 3.20 
 1.08 
 212.02 


 1.25 
 3.21 
 2.12 
 3.24 
 1.14 


 D.  1.3.5.2 
 CRSECSRL/  Re 


 gion( 
 seconds) 


 2.95 
 1.08 
 2.91 
 1.25 
 2.87 
 2.12 
 2.95 
 1.14 


 D.  1.3.6.1 
 COFFI/  Re 
 gion( 
 seconds) 


 4.46 
 0.63 
 4.40 
 0.67 
 4.60 
 0.63 
 4.35 
 0.64 


 D.  1.3.6.2 
 COFFI/  Re 
 gion( 
 seconds) 


 3.81 
 0.63 
 3.92 
 0.67 
 7.28 
 0.63 
 3.73 
 0.64 


 D.  1.3.7.1 
 PSIMS/  ORB/ 
 Re 
 gion( 


 seconds) 


 4.46 
 0.03 
 4.40 
 0.04 
 4.60 
 0.04 
 4.35 
 0.04 


 D.  1.3.7.2 
 PSIMS/  ORB/ 
 Re 
 gion( 


 seconds) 


 3.81 
 0.03 
 3.92 
 0.04 
 7.28 
 0.04 
 3.73 
 0.04 


 Average 
 Response 


 Interval 
 - 
 CLEC 


 (TAG) 
 (BST 
 Measure 


 Includes 
 Additional 


 2 
 Seconds) 


 [OSS-  1] 


 D.  1.4.1.1 
 RSAG, 
 b 
 y 


 TN/  Region( 


 seconds) 


 1440.12 
 1.10 
 1782.46 


 1.31 
 2.87 
 1.60 
 2.88 
 1.52 


 D.  1.4.1.2 
 RSAG, 
 b 
 y 


 TN/  Region( 


 seconds) 


 2.96 
 1.10 
 2.95 
 1.31 
 2.94 
 1.60 
 2.91 
 1.52 


 D.  1.4.2.1 
 RSAG, 
 b 
 y 
 ADDR/  Region( 


 seconds) 


 712.69 
 1.62 
 1204.18 


 1.85 
 2.99 
 3.05 
 3.03 
 2.34 


 D.  1.4.2.2 
 RSAG, 
 b 
 y 
 ADDR/  Region( 


 seconds) 


 4.82 
 1.62 
 4.86 
 1.85 
 4.77 
 3.05 
 4.76 
 2.34 


 D.  1.4.4.1 
 ATLAS 
 - 
 DID/  Re 


 gion( 
 seconds) 


 1.48 
 2.18 
 1.76 
 1.37 


 D.  1.4.4.2 
 ATLAS 
 - 
 DID/  Re 


 gion( 
 seconds) 


 1.48 
 2.18 
 1.76 
 1.37 


 D.  1.4.5.1 
 ATLAS 
 - 
 TN/  Re 


 gion( 
 seconds) 


 1330.23 
 1.35 
 2.95 
 1.56 
 2.95 
 1.86 
 3.01 
 1.89 


 D.  1.4.5.2 
 ATLAS 
 - 
 TN/  Re 


 gion( 
 seconds) 


 2.61 
 1.35 
 2.61 
 1.56 
 2.60 
 1.86 
 2.61 
 1.89 


 D.  1.4.6.1 
 DSAP/  Re 
 gion( 
 seconds) 


 2.68 
 1.58 
 2.70 
 1.71 
 2.71 
 1.74 
 2.71 
 1.83 


 D.  1.4.6.2 
 DSAP/  Re 
 gion( 
 seconds) 


 2.58 
 1.58 
 2.58 
 1.71 
 2.57 
 1.74 
 2.57 
 1.83 


 D.  1.4.7.1 
 TAG/  Re 
 gion( 
 seconds) 


 3.20 
 1.75 
 212.02 


 2.15 
 3.21 
 2.51 
 3.24 
 2.85 


 D.  1.4.7.2 
 TAG/  Re 
 gion( 
 seconds) 


 2.95 
 1.75 
 2.91 
 2.15 
 2.87 
 2.51 
 2.95 
 2.85 


 OPERATIONS 
 SUPPORT 
 SYSTEMS 
 - 
 MAINTENANCE 


 AND 
 REPAIR 


 % 
 Interface 


 Availability 


 - 
 CLEC 


 [OSS-  3] 


 D.  2.2.1 
 CLEC 
 TAFI/  Re 


 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 D.  2.2.2 
 ECTA/  Re 
 gion(%) 


 100.00% 
 99.95% 
 100.00% 


 99.86% 


 % 
 Interface 


 Availability 


 - 
 BST 


 & 
 CLEC 


 [OSS-  3] 


 D.  2.3.1 
 CRIS/  Re 
 gion(%) 


 100.00% 
 100.00% 
 99.96% 
 99.99% 


 B-  34 
207
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 June 


 March 
 May 
 April 


 Alabama 
 Performance 


 Metric 
 Data 


 D.  2.3.2 
 LMOS 
 HOST/  Region(%) 


 100.00% 
 100.00% 
 99.91% 
 100.00% 


 D.  2.3.3 
 LNP/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.91% 


 D.  2.3.4 
 MARCH/  Re 
 gion(%) 


 100.00% 
 99.99% 
 100.00% 
 100.00% 


 D.  2.3.5 
 OSPCM/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 D.  2.3.6 
 Predictor/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.92% 


 D.  2.3.7 
 SOCS/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.99% 


 Average 
 Response 


 Interval 
 <= 
 4 
 Seconds 


 [OSS-  4] 


 D.  2.4.1 
 CRIS/  Re 
 gion(%) 


 94.91% 
 94.17% 
 94.75% 
 94.83% 
 95.12% 
 94.99% 
 94.95% 
 94.66% 


 D.  2.4.2 
 DLETH/  Re 
 gion(%) 


 3.07% 
 3.22% 
 3.14% 
 4.03% 
 3.16% 
 4.59% 
 2.58% 
 3.67% 


 D.  2.4.3 
 DLR/  Re 
 gion(%) 


 4.30% 
 2.41% 
 4.07% 
 2.41% 
 4.03% 
 3.36% 
 4.47% 
 7.51% 


 D.  2.4.4 
 LMOS/  Re 
 gion(%) 


 99.67% 
 99.69% 
 99.63% 
 99.59% 
 99.60% 
 99.60% 
 99.61% 
 99.58% 


 D.  2.4.5 
 LMOSu 
 pd/  Region(%) 


 78.95% 
 70.39% 
 76.71% 
 65.38% 
 78.49% 
 66.19% 
 79.21% 
 66.24% 


 D.  2.4.6 
 LNP/  Re 
 gion(%) 


 99.78% 
 99.37% 
 99.31% 
 99.09% 
 99.68% 
 99.19% 
 99.65% 
 98.81% 


 D.  2.4.7 
 MARCH/  Re 
 gion(%) 


 28.35% 
 33.16% 
 28.32% 
 26.44% 
 28.04% 
 31.69% 
 28.10% 
 29.64% 


 D.  2.4.8 
 OSPCM/  Re 
 gion(%) 


 23.94% 
 13.59% 
 27.25% 
 20.73% 
 31.23% 
 24.50% 
 33.15% 
 21.43% 


 D.  2.4.9 
 Predictor/  Re 
 gion(%) 


 15.78% 
 19.48% 
 15.03% 
 20.43% 
 13.82% 
 19.61% 
 12.71% 
 21.73% 


 D.  2.4.10 
 SOCS/  Re 
 gion(%) 


 99.84% 
 99.91% 
 99.83% 
 99.90% 
 99.85% 
 99.88% 
 99.81% 
 99.86% 


 D.  2.4.11 
 NIW/  Region(%) 


 82.97% 
 81.81% 
 84.38% 
 83.15% 
 84.01% 
 83.00% 
 82.83% 
 81.89% 


 Average 
 Response 


 Interval 
 <= 
 10 
 Seconds 


 [OSS-  4] 


 D.  2.5.1 
 CRIS/  Re 
 gion(%) 


 98.99% 
 99.34% 
 98.97% 
 99.34% 
 99.05% 
 99.46% 
 99.02% 
 99.39% 


 D.  2.5.2 
 DLETH/  Re 
 gion(%) 


 78.81% 
 86.16% 
 78.96% 
 87.92% 
 79.20% 
 85.30% 
 77.66% 
 82.58% 


 D.  2.5.3 
 DLR/  Re 
 gion(%) 


 77.94% 
 92.02% 
 77.45% 
 91.98% 
 76.65% 
 88.18% 
 71.08% 
 41.67% 


 D.  2.5.4 
 LMOS/  Re 
 gion(%) 


 99.81% 
 99.86% 
 99.79% 
 99.82% 
 99.79% 
 99.84% 
 99.80% 
 99.85% 


 D.  2.5.5 
 LMOSu 
 pd/  Region(%) 


 90.95% 
 83.33% 
 89.31% 
 80.59% 
 90.04% 
 80.25% 
 90.59% 
 80.53% 


 D.  2.5.6 
 LNP/  Re 
 gion(%) 


 99.93% 
 99.87% 
 99.54% 
 99.72% 
 99.81% 
 99.63% 
 99.83% 
 99.52% 


 D.  2.5.7 
 MARCH/  Re 
 gion(%) 


 28.35% 
 33.16% 
 28.32% 
 26.44% 
 28.04% 
 31.69% 
 28.10% 
 29.64% 


 D.  2.5.8 
 OSPCM/  Re 
 gion(%) 


 96.89% 
 96.12% 
 97.38% 
 95.12% 
 97.81% 
 97.35% 
 98.41% 
 95.83% 


 D.  2.5.9 
 Predictor/  Re 
 gion(%) 


 15.78% 
 19.48% 
 15.03% 
 20.43% 
 13.82% 
 19.61% 
 12.71% 
 21.73% 


 D.  2.5.10 
 SOCS/  Re 
 gion(%) 


 99.99% 
 99.99% 
 99.99% 
 99.98% 
 99.98% 
 100.00% 


 99.98% 
 100.00% 


 D.  2.5.11 
 NIW/  Region(%) 


 99.17% 
 98.96% 
 99.49% 
 99.33% 
 99.39% 
 99.21% 
 99.42% 
 99.25% 


 Average 
 Response 


 Interval 
 > 
 10 


 Seconds 


 [OSS-  4] 


 D.  2.6.1 
 CRIS/  Re 
 gion(%) 


 1.01% 
 0.66% 
 1.03% 
 0.66% 
 0.95% 
 0.54% 
 0.98% 
 0.61% 


 D.  2.6.2 
 DLETH/  Re 
 gion(%) 


 21.19% 
 13.84% 
 21.04% 
 12.08% 
 20.80% 
 14.70% 
 22.34% 
 17.42% 


 B-  35 
208
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 June 


 March 
 May 
 April 


 Alabama 
 Performance 


 Metric 
 Data 


 D.  2.6.3 
 DLR/  Region(%) 


 22.06% 
 7.98% 
 22.55% 


 8.02% 
 23.35% 
 11.82% 
 28.92% 
 58.33% 


 D.  2.6.4 
 LMOS/  Re 
 gion(%) 


 0.19% 
 0.14% 
 0.21% 
 0.18% 
 0.21% 
 0.16% 
 0.20% 
 0.15% 


 D.  2.6.5 
 LMOSu 
 pd/  Region(%) 


 9.05% 
 16.67% 
 10.69% 
 19.41% 
 9.96% 
 19.75% 


 9.41% 
 19.47% 


 D.  2.6.6 
 LNP/  Re 
 gion(%) 


 0.07% 
 0.13% 
 0.46% 
 0.28% 
 0.19% 
 0.37% 
 0.17% 
 0.48% 


 D.  2.6.7 
 MARCH/  Re 
 gion(%) 


 71.65% 
 66.84% 
 71.68% 
 73.56% 
 71.96% 
 68.31% 
 71.90% 
 70.36% 


 D.  2.6.8 
 OSPCM/  Re 
 gion(%) 


 3.11% 
 3.88% 
 2.62% 
 4.88% 
 2.19% 
 2.65% 
 1.59% 
 4.17% 


 D.  2.6.9 
 Predictor/  Re 
 gion(%) 


 84.22% 
 80.52% 
 84.97% 
 79.57% 
 86.18% 
 80.39% 
 87.29% 
 78.27% 


 D.  2.6.10 
 SOCS/  Re 
 gion(%) 


 0.01% 
 0.01% 
 0.01% 
 0.02% 
 0.02% 
 0.00% 
 0.02% 
 0.00% 


 D.  2.6.11 
 NIW/  Region(%) 


 0.83% 
 1.04% 
 0.51% 
 0.67% 
 0.61% 
 0.79% 
 0.58% 
 0.75% 


 COLLOCATION 
 - 
 COLLOCATION  Average  Response  Time  [C- 


 1] 


 E.  1.1.1 
 Virtual/  AL 
 (calendar 
 days) 


 E.  1.1.3 
 Physical 
 Caged/  AL( 


 business 
 days) 


 4 
 5 


 1,2 


 E.  1.1.4 
 Ph  ysical 
 Cageless/  AL( 


 business 
 days) 


 19 
 9 
 17 


 17 
 1,2,3,4 


 Average 
 Arrangement 


 Time 
 [C-  2] 


 E.  1.2.4 
 Ph  ysical 
 Caged-  Ordinary/ 


 AL( 
 business 


 days) 


 17 
 14 


 1,2 


 E.  1.2.6 
 Ph  ysical 
 Cageless-  Ordinary/ 


 AL( 
 calendar 


 days) 


 15 
 13 
 2,4 


 % 
 Due 


 Dates 


 Missed 


 [C-  3] 


 E.  1.3.2 
 Ph 
 ysical/  AL(%) 


 0.00% 
 0.00% 


 0.00% 
 1,2,4 


 GENERAL 
 - 
 FLOW 


 THROUGH  %  Flow  Through  Service 


 Requests 
 [O-  3] 


 F.  1.1.1 
 Summar  y/ 
 Region(%) 


 85.28% 
 86.05% 
 84.50% 
 85.96% 


 F.  1.1.2 
 A 
 ggregate/  Region(%) 


 85.28% 
 86.05% 
 84.50% 
 85.96% 


 F.  1.1.3 
 Residence/  Re 
 gion(%) 


 86.49% 
 87.39% 
 86.74% 
 88.58% 


 F.  1.1.4 
 Business/  Re 
 gion(%) 


 73.55% 
 71.89% 
 69.54% 
 73.74% 


 F.  1.1.5 
 UNE/  Re 
 gion(%) 


 83.88% 
 84.78% 
 82.57% 
 83.84% 


 % 
 Flow 


 Through 


 Service 
 Requests 


 - 
 Achieved 


 [O-  3] 


 F.  1.2.1 
 Summar  y/ 
 Region(%) 


 75.79% 
 77.51% 
 76.58% 
 78.96% 


 F.  1.2.2 
 A 
 ggregate/  Region(%) 


 75.79% 
 77.51% 
 76.58% 
 78.96% 


 F.  1.2.3 
 Residence/  Re 
 gion(%) 


 79.16% 
 80.53% 
 79.88% 
 81.68% 


 F.  1.2.4 
 Business/  Re 
 gion(%) 


 50.63% 
 51.15% 
 51.58% 
 53.42% 


 F.  1.2.5 
 UNE/  Re 
 gion(%) 


 72.17% 
 74.87% 
 74.12% 
 77.27% 


 % 
 Flow 


 Through 


 Service 
 Requests 


 - 
 LNP 


 [O-  3] 


 B-  36 
209
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 June 


 March 
 May 
 April 


 Alabama 
 Performance 


 Metric 
 Data 


 F.  1.3.1 
 Summary/  Region(%) 


 92.25% 
 92.59% 
 89.75% 
 83.63% 


 F.  1.3.2 
 A 
 ggregate/  Region(%) 


 92.25% 
 92.59% 
 89.75% 
 83.63% 


 GENERAL 
 - 
 PRE-  ORDERING  Loop  Makeup 


 Inquiry 
 (Electronic) 


 [PO-  2] 


 F.  2.2 
 Loo 
 ps/  AL(%) 


 97.58% 
 99.47% 
 99.44% 
 84.17% 


 GENERAL 
 - 
 ORDERING  Average  Speed 


 of 
 Answer 


 [O-  12] 


 F.  4.1 
 Re 
 gion( 


 seconds) 


 141.64 
 30.33 
 137.90 


 28.63 
 194.86 


 35.16 
 259.48 


 58.19 


 GENERAL 
 - 
 MAINTENANCE 


 CENTER 
 Average 
 Answer 
 Time 
 [M&  R- 


 6] 


 F.  5.1 
 Re 
 gion( 


 seconds) 


 43.10 
 26.35 
 41.00 
 23.60 
 64.68 
 25.99 
 52.80 
 28.04 


 GENERAL 
 - 
 OPERATOR 


 SERVICES 
 (TOLL) 


 Average 
 Speed 
 to 
 Answer 


 [OS-  1] 


 F.  6.1 
 AL 
 (seconds) 


 6.08 
 5.86 
 6.00 
 5.53 


 % 
 Answered 


 in 
 10 
 seconds 


 [OS-  2] 


 F.  6.2 
 AL 
 (%) 


 76.40% 
 77.20% 
 76.80% 
 78.80% 


 GENERAL 
 - 
 DIRECTORY 


 ASSISTANCE 
 Average 
 Speed 
 to 
 Answer 


 [DA-  1] 


 F.  7.1 
 AL 
 (seconds) 


 4.26 
 4.80 
 5.06 
 4.54 


 % 
 Answered 


 in 
 10 
 seconds 


 [DA-  2] 


 F.  7.2 
 AL 
 (%) 


 87.10% 
 84.60% 
 83.50% 
 86.10% 


 GENERAL 
 - 
 BILLING  Usage  Data 


 Delivery 
 Accuracy 


 [B-  3] 


 F.  9.1 
 Re 
 gion(%) 


 100.00% 
 100.00% 
 97.75% 
 100.00% 


 95.22% 
 100.00% 
 100.00% 
 100.00% 


 Usage 
 Data 
 Delivery 


 Timeliness 


 [B-  5] 


 F.  9.2 
 Re 
 gion(%) 


 98.37% 
 93.14% 
 75.41% 
 94.80% 
 94.93% 
 97.64% 
 99.33% 
 99.38% 


 Usage 
 Data 
 Delivery 


 Completeness 


 [B-  4] 


 F.  9.3 
 Re 
 gion(%) 


 99.38% 
 99.89% 
 99.77% 
 99.54% 
 97.21% 
 99.95% 
 99.92% 
 99.91% 


 Mean 
 Time 
 to 
 Deliver 


 Usage 
 [B-  6] 


 F.  9.4 
 Re 
 gion( 


 days) 


 3.49 
 3.05 
 6.85 
 3.29 
 4.34 
 2.52 
 3.24 
 2.43 


 Recurring 
 Charge 
 Completeness 


 [B-  7] 


 F.  9.5.1 
 Resale/  AL 
 (%) 


 80.46% 
 98.00% 
 76.52% 
 52.07% 
 85.17% 
 97.71% 
 85.80% 
 97.94% 


 F.  9.5.2 
 UNE/  AL 
 (%) 


 98.85% 
 99.43% 
 98.83% 
 99.64% 


 B-  37 
210
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 June 


 March 
 May 
 April 


 Alabama 
 Performance 


 Metric 
 Data 


 F.  9.5.3 
 Interconnection/  AL(%) 


 99.94% 
 98.90% 
 97.40% 
 99.64% 


 Non-  Recurring 
 Charge 
 Completeness 


 [B-  8] 


 F.  9.6.1 
 Resale/  AL 
 (%) 


 97.06% 
 96.71% 
 83.65% 
 97.61% 
 88.06% 
 98.38% 
 89.07% 
 98.02% 


 F.  9.6.2 
 UNE/  AL 
 (%) 


 99.24% 
 99.39% 
 98.91% 
 98.57% 


 F.  9.6.3 
 Interconnection/  AL 


 (%) 


 96.03% 
 98.65% 
 93.53% 
 95.66% 


 GENERAL 
 - 
 CHANGE 


 MANAGEMENT  %  Software  Release  Notices  Sent 


 On 
 Time 


 [CM-  1] 


 F.  10.1 
 AL 
 (%) 


 100.00% 
 100.00% 


 2,3 


 % 
 Change 


 Management 


 Documentation 


 Sent 
 On 
 Time 


 [CM-  3A] 


 F.  10.3 
 AL 
 (%) 


 100.00% 
 100.00% 
 1,4 


 % 
 Change 


 Management 


 Documentation 


 (Defects, 
 Corrections, 


 etc.) 
 Sent 
 On 
 Time 


 [CM-  3B] 


 F.  10.4 
 AL 
 (%) 


 77.78% 
 2 


 Average 
 Documentation 


 Release 
 Delay 
 Days 
 [CM-  4] 


 F.  10.5 
 AL 
 (average)  %  CLEC  Interface 


 Outages 
 Sent 
 within 


 15 
 Minutes 


 [CM-  5] 


 F.  10.6 
 AL 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 GENERAL 
 - 
 NEW 


 BUSINESS 


 REQUESTS 


 % 
 New 


 Business 


 Requests 
 Processed 


 within 
 30 
 Business 


 Days 
 [BFR-  1] 


 F.  11.1 
 Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 % 
 Quotes 


 Provided 


 within 
 X 
 Business 


 Days 
 [BFR-  2A] 


 F.  11.2.1 
 Re 
 gion(%) 


 100.00% 
 100.00% 
 1,3 


 F.  11.2.3 
 Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 GENERAL 
 - 
 ORDERING  Acknowledgement 


 Message 
 Timeliness 


 [O-  1] 


 F.  12.1.1 
 EDI/  Re 
 gion(%) 


 99.97% 
 99.99% 
 100.00% 
 100.00% 


 F.  12.1.2 
 TAG/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 Acknowledgement 
 Message 
 Completeness 


 [O-  2] 


 F.  12.2.1 
 EDI/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.62% 


 F.  12.2.2 
 TAG/  Re 
 gion(%) 


 100.00% 
 100.00% 
 99.99% 
 100.00% 


 GENERAL 
 - 
 DATABASE 


 UPDATES 
 Average 
 Database 


 Update 
 Interval 


 [D-  1] 


 F.  13.1.1 
 LIDB/  AL 
 (hours) 


 0.52 
 0.52 
 0.60 
 0.60 
 0.46 
 0.46 
 0.49 
 0.49 


 F.  13.1.2 
 Director  y 
 Listings/  AL( 


 hours) 


 0.10 
 0.10 
 0.09 
 0.09 
 0.10 
 0.10 
 0.11 
 0.11 


 B-  38 
211
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 June 


 March 
 May 
 April 


 Alabama 
 Performance 


 Metric 
 Data 


 F.  13.1.3 
 Directory 
 Assistance/  AL( 


 hours) 


 4.52 
 4.52 
 4.90 
 4.90 
 4.72 
 4.71 
 6.51 
 6.46 


 % 
 Update 


 Accuracy 


 [D-  2] 


 F.  13.2.1 
 LIDB/  AL 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 93.48% 


 F.  13.2.2 
 Director  y 
 Listings/  AL(%) 


 99.38% 
 99.03% 
 99.79% 
 99.35% 


 F.  13.2.3 
 Director  y 
 Assistance/  AL(%) 


 100.00% 
 100.00% 
 97.87% 
 99.19% 


 % 
 NXXs 


 / 
 LRNs 


 Loaded 


 by 
 LERG 


 Effective 


 Date 
 [D-  3] 


 F.  13.3 
 Re 
 gion(%) 


 96.77% 
 100.00% 
 100.00% 
 98.41% 


 GENERAL 
 - 
 NETWORK 


 OUTAGE 
 NOTIFICATION 


 Mean 
 Time 
 to 
 Notify 


 CLEC 
 of 
 Major 


 Network 


 Outages 
 [M&  R- 
 7] 


 F.  14.1 
 Region(  minutes) 


 739 
 218 


 0 
 0 
 154 


 123 
 791 
 602 
 1,3,4 


 Abbreviations:  blank  cell  =  no  data 
 available 
 Notes:  1  =  Sample 
 Size 
 under 


 10 
 in 
 March 


 2 
 = 
 Sample 


 Size 
 under 


 10 
 in 
 April 


 2 
 = 
 Sample 


 Size 
 under 


 10 
 in 
 May 


 4 
 = 
 Sample 


 Size 
 under 


 10 
 in 
 June 


 B-  39 
212
 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Appendix 
 C 


 Kentucky 
 Performance 


 Metrics 


 Except 
 where 
 noted, 
 the 
 data 


 included 


 here 
 is 
 taken 


 from 
 the 
 Kentucky 


 Monthly 
 State 
 Summary 


 (MSS) 
 Reports 


 provided 


 by 


 BellSouth, 
 calculated 
 according 
 to 
 the 


 Georgia 


 Service 
 Quality 
 Measurement 


 (SQM) 
 business 


 rules. 
 This 
 table 


 is 
 provided 


 as 
 a 


 reference 
 tool 
 for 
 the 
 convenience 


 of 
 the 


 reader. 


 No 
 conclusions 


 are 
 to 
 be 
 drawn 


 from 
 the 
 raw 


 data 
 contained 


 in 
 this 


 table. 


 Our 


 analysis 
 is 
 based 


 on 
 the 
 totality 


 of 
 the 
 circumstances, 


 such 
 that 
 we 
 may 


 use 
 non-  metric 


 evidence, 
 and 
 may 


 rely 
 more 


 heavily 


 on 
 some 


 metrics 
 more 
 than 
 others, 


 in 
 making 


 our 
 determination. 


 The 
 inclusion 


 of 
 these 


 particular 


 metrics 
 in 
 this 


 table 


 does 
 not 
 necessarily 


 mean 
 that 
 we 
 relied 


 on 
 all 
 of 
 these 


 metrics, 


 or 
 that 


 other 


 metrics 


 may 
 not 
 also 


 be 
 important 


 in 
 our 


 analysis. 


 Some 
 metrics 


 that 
 we 
 have 


 relied 
 on 
 in 
 the 


 past 


 and 
 may 


 rely 
 on 
 for 


 a 
 future 


 application 


 were 
 not 
 included 


 here 
 because 


 there 
 was 
 no 
 data 


 provided 


 for 
 them 


 (usually 
 either 
 because 


 there 
 was 
 no 
 activity, 


 or 
 because 


 the 
 metrics 


 are 
 still 


 under 


 development). 


 Metrics 
 with 
 no 
 retail 


 analog 


 provided 


 are 
 usually 


 compared 


 with 
 a 
 benchmark. 


 Note 
 that 
 for 
 some 


 metrics 


 during 
 the 
 period 


 provided 
 there 
 may 
 be 
 changes 


 in 
 the 


 metric 


 definition, 


 or 
 changes 


 in 
 the 


 retail 


 analog 


 applied, 


 making 
 it 
 difficult 


 to 
 compare 


 data 


 Note: 
 All 
 data 


 was 
 calculated 


 using 
 BellSouth's 


 data 
 platform 


 PMAP 
 4.0. 
 The 
 March 


 data 
 in 
 this 


 appendix 


 were 
 not 
 taken 


 from 
 the 


 MSS 
 reports, 


 which 
 for 
 that 


 month 


 were 
 calculated 


 using 
 PMAP 


 2.6, 
 but 
 instead 


 were 
 calculated 


 using 
 PMAP 


 4.0 
 by 
 BellSouth. 


 This 


 data 
 also 
 conforms 


 to 
 the 


 Georgia 


 Service 
 Quality 
 Measurement 


 business 
 rules 
 that 
 govern 


 the 
 regular 


 MSS 
 reports. 
213
 Metric  No. 
 SQM 
 No. 
 Metric 


 Name 


 Metric  No. 
 SQM 
 No. 
 Metric 


 Name 


 RESALE 
 A.  3.5 
 M&  R- 
 5 
 Out 


 of 
 Service 


 > 
 24 


 hours 


 Ordering 
 Billing 
 A.  1.1 
 O-  7 


 % 
 Rejected 


 Service 
 Requests 


  
 Mech. 


 A.  4.1 
 B-  1 


 Invoice 
 Accuracy 


 A.  1.2 
 O-  7 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Partially 


 Mech. 


 A.  4.2 
 B-  2 


 Mean 
 Time 
 to 
 Deliver 


 Invoices 


  
 CRIS 


 A.  1.3 
 O-  7 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Non-  Mech. 


 UNBUNDLED 
 NETWORK 
 ELEMENTS 


 A.  1.4 
 O-  8 


 Reject 
 Interval 


  
 Mech. 


 Ordering 


 A.  1.7 
 O-  8 


 Reject 
 Interval 


 - 
 Partially 


 Mech. 
  
 10 


 hours 


 B.  1.1 
 O-  7/ 
 O-  13 


 % 
 Rejected 


 Service 
 Requests 


  
 Mech. 


 A.  1.8 
 O-  8 


 Reject 
 Interval 


 - 
 Non-  Mech. 


 B.  1.2 
 O-  7/ 
 O-  13 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Partially 


 Mech. 


 A.  1.9 
 O-  9 


 FOC 
 Timeliness 


  
 Mech. 


 B.  1.3 
 O-  7/ 
 O-  13 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Non-  Mech. 


 A.  1.12 
 O-  9 


 FOC 
 Timeliness 


 - 
 Partially 


 Mech. 
 - 
 10 


 hours 


 B.  1.4 
 O-  8/ 
 O-  14 


 Reject 


 Interval 


  
 Mech. 


 A.  1.13 
 O-  9 


 FOC 
 Timeliness 


 - 
 Non-  Mech. 


 B.  1.7 
 O-  8/ 
 O-  14 


 Reject 


 Interval 


 - 
 Partially 


 Mech. 
 - 
 10 


 hours 


 A.  1.14 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Mech. 


 B.  1.8 
 O-  8/ 
 O-  14 


 Reject 


 Interval 


 - 
 Non-  Mech. 


 A.  1.15 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Partially 


 Mech. 


 B.  1.9 
 O-  9/ 
 O-  15 


 FOC 
 Timeliness 


  
 Mech. 


 A.  1.16 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Non-  Mech. 


 B.  1.12 
 O-  9/ 
 O-  15 


 FOC 
 Timeliness 


 - 
 Partially 


 Mech. 
 - 
 10 


 hours 


 Provisioning 
 B.  1.13 
 O-  9/ 
 O-  15 


 FOC 
 Timeliness 


 - 
 Non-  Mech. 


 A.  2.1 
 P-  4 


 Order 
 Completion 


 Interval 


 B.  1.14 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


  
 Mech. 


 A.  2.4 
 P-  2 


 % 
 Jeopardies 


 - 
 Mech. 


 B.  1.15 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


  
 Partially 


 Mech. 


 A.  2.5 
 P-  2 


 % 
 Jeopardies 


 - 
 Non-  Mech. 


 B.  1.16 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


  
 Non-  Mech. 


 A.  2.7 
 P-  2 


 Average 
 Jeopardy 
 Notice 
 Interval 


 - 
 Mech. 


 Provisioning 


 A.  2.8 
 P-  2 


 Average 
 Jeopardy 
 Notice 
 Interval 


 - 
 Non-  Mech. 


 B.  2.1 
 P-  4 


 Order 
 Completion 


 Interval 


 A.  2.9 
 P-  2 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Mech. 


 B.  2.2 
 P-  4 


 Order 
 Completion 


 Interval 
 within 
 X 
 days 


 - 
 xDSL 


 A.  2.10 
 P-  2 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Non-  Mech. 


 B.  2.5 
 P-  2 


 % 
 Jeopardies 


  
 Mech. 


 A.  2.11 
 P-  3 


 % 
 Missed 


 Installation 


 Appointments 


 B.  2.6 
 P-  2 


 % 
 Jeopardies 


 - 
 Non-  Mech. 


 A.  2.12 
 P-  9 


 % 
 Provisioning 


 Troubles 
 within 
 30 
 Days 


 B.  2.8 
 P-  2 


 Average 
 Jeopardy 
 Notice 
 Interval 


 - 
 Mech. 


 A.  2.14 
 P-  5 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Mech. 


 B.  2.9 
 P-  2 


 Average 
 Jeopardy 
 Notice 
 Interval 


 - 
 Non-  Mech. 


 A.  2.15 
 P-  5 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Non-  Mech. 


 B.  2.10 
 P-  2 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Mech. 


 A.  2.25 
 P-  11 


 Service 
 Order 
 Accuracy 


 B.  2.11 
 P-  2 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Non-  Mech. 


 Maintenance 
 and 
 Repair 


 B.  2.12 
 P-  7 
 Coordinated 


 Customers 
 Conversions 


 A.  3.1 
 M&  R- 
 1 
 Missed 


 Repair 
 Appointments 


 B.  2.13 
 P-  7A 


 % 
 Hot 


 Cuts 


 > 
 15 


 minutes 


 Early 


 A.  3.2 
 M&  R- 
 2 
 Customer 


 Trouble 
 Report 
 Rate 


 B.  2.14 
 P-  7A 


 Hot 
 Cut 
 Timeliness 


 A.  3.3 
 M&  R- 
 3 
 Maintenance 


 Average 
 Duration 


 B.  2.15 
 P-  7A 


 % 
 Hot 


 Cuts 


 > 
 15 


 minutes 


 Late 


 A.  3.4 
 M&  R- 
 4 
 % 
 Repeat 


 Troubles 


 within 
 30 
 Days 


 B.  2.16 
 P-  7B 


 Average 
 Recovery 


 Time 
  
 CCC 


 PERFORMANCE 
 METRIC 
 CATEGORIES 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 C-  2 
214
 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Metric  No. 
 SQM 
 No. 
 Metric 


 Name 


 Metric  No. 
 SQM 
 No. 
 Metric 


 Name 


 B.  2.17 
 P-  7C 


 % 
 Provisioning 


 Troubles 
 within 
 7 
 Days 


 - 
 Hot 


 Cuts 


 C.  3.3 
 M&  R- 
 3 
 Maintenance 


 Average 
 Duration 


 B.  2.18 
 P-  3/ 
 P-  12 


 % 
 Missed 


 Installation 


 Appointments 


 C.  3.4 
 M&  R- 
 4 
 % 
 Repeat 


 Troubles 


 within 
 30 
 Days 


 B.  2.19 
 P-  9 


 % 
 Provisioning 


 Troubles 
 within 
 30 
 Days 


 C.  3.5 
 M&  R- 
 5 
 Out 


 of 
 Service 


 > 
 24 


 hours 


 B.  2.21 
 P-  5 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Mech. 


 Billing 


 B.  2.22 
 P-  5 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Non-  Mech. 


 C.  4.1 
 B-  1 


 Invoice 
 Accuracy 


 B.  2.34 
 P-  11 


 Service 
 Order 
 Accuracy 


 C.  4.2 
 B-  2 


 Mean 
 Time 
 to 
 Deliver 


 Invoices 


 - 
 CABS 


 Maintenance 
 and 
 Repair 


 Trunk 
 Blocking 


 B.  3.1 
 M&  R- 
 1 
 Missed 


 Repair 
 Appointments 


 C.  5.1 
 TGP-  1 


 Trunk 
 Group 
 Performance 


 - 
 Aggregate 


 B.  3.2 
 M&  R- 
 2 
 Customer 


 Trouble 
 Report 
 Rate 


 OPERATIONS 
 SUPPORT 
 SYSTEMS 


 B.  3.3 
 M&  R- 
 3 
 Maintenance 


 Average 
 Duration 


 Pre-  Ordering 


 B.  3.4 
 M&  R- 
 4 
 % 
 Repeat 


 Troubles 


 within 
 30 
 Days 


 D.  1.1 
 OSS-  2 


 % 
 Interface 


 Availability 


 - 
 CLEC 


 B.  3.5 
 M&  R- 
 5 
 Out 


 of 
 Service 


 > 
 24 


 hours 


 D.  1.2 
 OSS-  2 


 % 
 Interface 


 Availability 


 - 
 BST 


 & 
 CLEC 


 Billing 
 D.  1.3 
 OSS-  1 


 Average 
 Response 


 Interval 
 - 
 CLEC 


 (LENS) 


 B.  4.1 
 B-  1 


 Invoice 
 Accuracy 


 D.  1.4 
 OSS-  1 


 Average 
 Response 


 Interval 
 - 
 CLEC 


 (TAG) 


 B.  4.2 
 B-  2 


 Mean 
 Time 
 to 
 Deliver 


 Invoices 


 - 
 CRIS 


 Maintenance 
 and 
 Repair 


 LOCAL 
 INTERCONNECTION 


 TRUNKS 


 D.  2.1 
 OSS-  3 


 % 
 Interface 


 Availability 


 - 
 BST 


 Ordering 
 D.  2.2 
 OSS-  3 


 % 
 Interface 


 Availability 


 - 
 CLEC 


 C.  1.1 
 O-  7 


 % 
 Rejected 


 Service 
 Requests 


 D.  2.3 
 OSS-  3 


 % 
 Interface 


 Availability 


 - 
 BST 


 & 
 CLEC 


 C.  1.2 
 O-  8 


 Reject 
 Interval 


 D.  2.4 
 OSS-  4 


 Average 
 Response 


 Interval 
 <= 
 4 
 Seconds 


 C.  1.3 
 O-  9 


 FOC 
 Timeliness 


 D.  2.5 
 OSS-  4 


 Average 
 Response 


 Interval 
 <= 
 10 
 Seconds 


 C.  1.4 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 D.  2.6 
 OSS-  4 


 Average 
 Response 


 Interval 
 > 
 10 


 Seconds 


 Provisioning 
 COLLOCATION 
 C.  2.1 
 P-  4 


 Order 
 Completion 


 Interval 


 Collocation 


 C.  2.2 
 P-  1 


 Held 
 Orders 


 E.  1.1 
 C-  1 


 Average 
 Response 


 Time 


 C.  2.3 
 P-  2 


 % 
 Jeopardies 


 E.  1.2 
 C-  2 


 Average 
 Arrangement 


 Time 


 C.  2.5 
 P-  3 


 % 
 Missed 


 Installation 


 Appointments 


 E.  1.3 
 C-  3 


 % 
 Due 


 Dates 


 Missed 


 C.  2.6 
 P-  9 


 % 
 Provisioning 


 Troubles 
 within 
 30 
 Days 


 GENERAL 


 C.  2.7 
 P-  5 


 Average 
 Completion 


 Notice 
 Interval 


 Flow 
 Through 


 C.  2.8 
 P-  10 


 Total 
 Service 


 Order 
 Cycle 
 Time 


 F.  1.1 
 O-  3 


 % 
 Flow 


 Through 


 Service 
 Requests 


 C.  2.10 
 P-  6 


 % 
 Completions 


 w/  o 
 Notice 


 or 
 < 
 24 


 hours 


 F.  1.2 
 O-  3 


 % 
 Flow 


 Through 


 Service 
 Requests 


 - 
 Achieved 


 C.  2.11 
 P-  11 


 Service 
 Order 
 Accuracy 


 F.  1.3 
 O-  3 


 % 
 Flow 


 Through 


 Service 
 Requests 


 - 
 LNP 


 Maintenance 
 and 
 Repair 


 Pre-  Ordering 


 C.  3.1 
 M&  R- 
 1 
 Missed 


 Repair 
 Appointments 


 F.  2.1 
 PO-  1 


 Loop 
 Makeup 


 Inquiry 
 (Manual) 


 C.  3.2 
 M&  R- 
 2 
 Customer 


 Trouble 
 Report 
 Rate 


 F.  2.2 
 PO-  2 


 Loop 
 Makeup 


 Inquiry 
 (Electronic) 


 C-  3 
215
 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Metric  No. 
 SQM 
 No. 
 Metric 


 Name 


 Metric  No. 
 SQM 
 No. 
 Metric 


 Name 


 Ordering 
 Database 
 Updates 


 F.  4.1 
 O-  12 


 Average 
 Speed 
 of 
 Answer 


 F.  13.1 
 D-  1 


 Average 
 Database 
 Update 
 Interval 


 Maintenance 
 Center 


 F.  13.2 
 D-  2 


 % 
 Update 


 Accuracy 


 F.  5.1 
 M&  R- 
 6 
 Average 


 Answer 
 Time 


 F.  13.3 
 D-  3 


 % 
 NXXs 


 / 
 LRNs 


 Loaded 


 by 
 LERG 


 Effective 


 Date 


 Operator 
 Services 
 (Toll) 


 Network 
 Outage 
 Notification 


 F.  6.1 
 OS-  1 


 Average 
 Speed 
 to 
 Answer 


 F.  14.1 
 M&  R- 
 7 
 Mean 


 Time 
 to 
 Notify 


 CLEC 
 of 
 Major 


 Network 


 Outages 


 F.  6.2 
 OS-  2 


 % 
 Answered 


 in 
 10 
 seconds 


 Directory 
 Assistance  F.  7.1  DA-  1  Average 


 Speed 
 to 
 Answer 


 F.  7.2 
 DA-  2 


 % 
 Answered 


 in 
 10 
 seconds 


 Billing  F.  9.1 
 B-  3 


 Usage 
 Data 
 Delivery 


 Accuracy 


 F.  9.2 
 B-  5 


 Usage 
 Data 
 Delivery 


 Timeliness 


 F.  9.3 
 B-  4 


 Usage 
 Data 
 Delivery 


 Completeness 


 F.  9.4 
 B-  6 


 Mean 
 Time 
 to 
 Deliver 


 Usage 


 F.  9.5 
 B-  7 


 Recurring 
 Charge 
 Completeness 


 F.  9.6 
 B-  8 


 Non-  Recurring 


 Charge 
 Completeness 


 Change 
 Management  F.  10.1  CM-  1  % 


 Software 
 Release 
 Notices 
 Sent 
 On 
 Time 


 F.  10.2 
 CM-  2 


 Average 
 Software 
 Release 
 Notice 
 Delay 
 Days 


 F.  10.3 
 CM-  3A 


 % 
 Change 


 Management 


 Documentation 


 Sent 
 On 
 Time 


 F.  10.4 
 CM-  3B 


 % 
 Change 


 Management 


 Documentation 


 (Defects, 


 Corrections, 
 etc.  ) 
 Sent 
 On 
 Time 


 F.  10.5 
 CM-  4 


 Average 
 Documentation 


 Release 
 Delay 
 Days 


 F.  10.6 
 CM-  5 


 % 
 CLEC 


 Interface 


 Outages 
 Sent 
 within 


 15 
 Minutes 


 New 
 Business 


 Requests 


 F.  11.1 
 BFR-  1 


 % 
 New 


 Business 


 Requests 
 Processed 


 in 
 30 


 Bus. 


 Days 


 F.  11.2 
 BFR-  2A 


 % 
 Quotes 


 Provided 


 within 
 X 
 Business 


 Days 


 Ordering  F.  12.1 
 O-  1 
 Acknowledgement 


 Message 
 Timeliness 


 F.  12.2 
 O-  2 
 Acknowledgement 


 Message 
 Completeness 


 C-  4 
216
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 RESALE 
 - 
 ORDERING  %  Rejected 


 Service 
 Requests 


 - 
 Mechanized 


 [O-  7] 


 A.  1.1.1 
 Residence/  KY 
 (%) 


 8.83% 
 8.46% 
 9.57% 
 7.83% 


 A.  1.1.2 
 Business/  KY 
 (%) 


 16.75% 
 23.48% 
 25.76% 
 19.48% 


 A.  1.1.4 
 PBX/  KY 
 (%) 


 100.00% 


 1 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Partially 


 Mechanized 


 [O-  7] 


 A.  1.2.1 
 Residence/  KY 
 (%) 


 23.05% 
 19.74% 
 25.67% 
 33.78% 


 A.  1.2.2 
 Business/  KY 
 (%) 


 50.32% 
 38.26% 
 58.82% 
 36.89% 


 A.  1.2.4 
 PBX/  KY 
 (%) 


 50.00% 
 4 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Non-  Mechanized 


 [O-  7] 


 A.  1.3.1 
 Residence/  KY 
 (%) 


 43.14% 
 43.52% 
 43.36% 
 41.35% 


 A.  1.3.2 
 Business/  KY 
 (%) 


 58.56% 
 40.57% 
 50.00% 
 47.54% 


 A.  1.3.3 
 Desi 
 gn 
 (Specials)/  KY(%) 


 37.36% 
 37.50% 
 52.63% 
 34.38% 
 2 


 A.  1.3.4 
 PBX/  KY 
 (%) 


 50.00% 
 33.33% 
 50.00% 
 0.00% 
 3,4 


 A.  1.3.5 
 Centrex/  KY 
 (%) 


 100.00% 
 33.33% 
 16.67% 
 50.00% 
 1,2,3,4 


 A.  1.3.6 
 ISDN/  KY 
 (%) 


 18.18% 
 35.71% 
 0.00% 
 20.00% 
 3,4 


 Reject 
 Interval 


 - 
 Mechanized 


 [O-  8] 


 A.  1.4.1 
 Residence/  KY 
 (%) 


 93.50% 
 98.25% 
 97.38% 
 97.06% 


 A.  1.4.2 
 Business/  KY 
 (%) 


 93.94% 
 94.83% 
 93.22% 
 96.67% 


 A.  1.4.4 
 PBX/  KY 
 (%) 


 0.00% 


 1 


 Reject 
 Interval 


 - 
 Partially 


 Mechanized 


 - 
 10 


 hours 


 [O-  8] 


 A.  1.7.1 
 Residence/  KY 
 (%) 


 91.32% 
 95.03% 
 91.25% 
 95.61% 


 A.  1.7.2 
 Business/  KY 
 (%) 


 97.59% 
 87.93% 
 97.06% 
 94.74% 


 A.  1.7.4 
 PBX/  KY 
 (%) 


 100.00% 
 4 


 Reject 
 Interval 


 - 
 Non-  Mechanized 


 [O-  8] 


 A.  1.8.1 
 Residence/  KY 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 A.  1.8.2 
 Business/  KY 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 A.  1.8.3 
 Desi 
 gn 
 (Specials)/  KY(%) 


 97.30% 
 100.00% 
 100.00% 
 91.67% 
 2 


 A.  1.8.4 
 PBX/  KY 
 (%) 


 88.89% 
 75.00% 
 100.00% 


 1,2,3 


 A.  1.8.5 
 Centrex/  KY 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 A.  1.8.6 
 ISDN/  KY 
 (%) 


 100.00% 
 100.00% 


 100.00% 
 1,2,4 


 FOC 
 Timeliness 


 - 
 Mechanized 


 [O-  9] 


 A.  1.9.1 
 Residence/  KY 
 (%) 


 99.42% 
 99.56% 
 99.00% 
 99.12% 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Kentucky 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 C-  5 
217
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Kentucky 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 A.  1.9.2 
 Business/  KY(%) 


 99.28% 
 100.00% 


 98.77% 
 100.00% 


 FOC 
 Timeliness 


 - 
 Partially 


 Mechanized 


 - 
 10 


 hours 


 [O-  9] 


 A.  1.12.1 
 Residence/  KY 
 (%) 


 93.24% 
 90.29% 
 84.68% 
 85.52% 


 A.  1.12.2 
 Business/  KY 
 (%) 


 97.62% 
 95.60% 
 92.94% 
 100.00% 


 A.  1.12.4 
 PBX/  KY 
 (%) 
 FOC 
 Timeliness 


 - 
 Non-  Mechanized 


 [O-  9] 


 A.  1.13.1 
 Residence/  KY 
 (%) 


 100.00% 
 100.00% 
 98.25% 
 100.00% 


 A.  1.13.2 
 Business/  KY 
 (%) 


 100.00% 
 97.83% 
 100.00% 
 100.00% 


 A.  1.13.3 
 Desi 
 gn 
 (Specials)/  KY(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2,3 


 A.  1.13.4 
 PBX/  KY 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 A.  1.13.5 
 Centrex/  KY 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 A.  1.13.6 
 ISDN/  KY 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Mechanized 


 [O-  11] 


 A.  1.14.1.1 
 Residence/  EDI/ 


 KY  (%) 


 100.00% 
 98.81% 
 93.24% 
 100.00% 


 A.  1.14.1.2 
 Residence/  TAG/ 


 KY  (%) 


 99.78% 
 99.71% 
 99.13% 
 99.77% 


 A.  1.14.2.1 
 Business/  EDI/ 
 KY 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 2,4 


 A.  1.14.2.2 
 Business/  TAG/ 


 KY 
 (%) 


 85.28% 
 97.95% 
 94.98% 
 100.00% 


 A.  1.14.4.2 
 PBX/  TAG/ 
 KY 
 (%) 


 100.00% 


 1 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Partially 


 Mechanized 


 [O-  11] 


 A.  1.15.1.1 
 Residence/  EDI/ 


 KY  (%) 


 100.00% 
 93.75% 
 100.00% 
 100.00% 
 3,4 


 A.  1.15.1.2 
 Residence/  TAG/ 


 KY  (%) 


 99.31% 
 99.11% 
 99.50% 
 99.59% 


 A.  1.15.2.1 
 Business/  EDI/ 
 KY 
 (%) 


 100.00% 
 100.00% 


 2 


 A.  1.15.2.2 
 Business/  TAG/ 


 KY 
 (%) 


 99.36% 
 100.00% 
 100.00% 
 100.00% 


 A.  1.15.4.2 
 PBX/  TAG/ 
 KY 
 (%) 


 50.00% 
 4 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Non-  Mechanized 


 [O-  11] 


 A.  1.16.1 
 Residence/  KY 
 (%) 


 93.14% 
 97.22% 
 95.58% 
 98.50% 


 A.  1.16.2 
 Business/  KY 
 (%) 


 99.10% 
 94.34% 
 92.65% 
 91.80% 


 A.  1.16.3 
 Desi 
 gn 
 (Specials)/  KY(%) 


 94.51% 
 87.50% 
 78.95% 
 93.75% 
 2 


 A.  1.16.4 
 PBX/  KY 
 (%) 


 100.00% 
 91.67% 
 100.00% 
 100.00% 
 3,4 


 A.  1.16.5 
 Centrex/  KY 
 (%) 


 100.00% 
 100.00% 
 83.33% 
 100.00% 
 1,2,3,4 


 A.  1.16.6 
 ISDN/  KY 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 3,4 


 RESALE 
 - 
 PROVISIONING  Order  Completion 


 Interval 
 [P-  4] 


 C-  6 
218
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Kentucky 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 A.  2.1.1.1.1 
 Residence/<  10 


 circuits/  Dispatch/ 


 KY( 
 days) 


 5.58 
 4.89 
 5.81 
 4.83 
 6.31 
 5.50 
 6.21 
 6.00 


 A.  2.1.1.1.2 
 Residence/<  10 


 circuits/  Non- 
 Dis  patch/ 
 KY( 
 days) 


 0.90 
 0.65 
 0.89 
 0.59 
 0.89 
 0.62 
 0.89 
 0.60 


 A.  2.1.1.2.1 
 Residence/>=  10 


 circuits/  Dis 
 patch/  KY( 
 days) 


 4.88 


 5.00 
 3.00 
 5.83 


 5.38 


 2 


 A.  2.1.2.1.1 
 Business/<  10 
 circuits/  Dis 
 patch/  KY( 
 days) 


 2.40 
 2.77 
 3.26 
 2.53 
 3.75 
 3.75 
 5.45 
 3.40 


 A.  2.1.2.1.2 
 Business/<  10 
 circuits/  Non- 
 Dis  patch/ 
 KY( 
 days) 


 1.28 
 0.92 
 1.22 
 0.76 
 1.65 
 0.99 
 1.18 
 0.76 


 A.  2.1.2.2.1 
 Business/>=  10 


 circuits/  Dis 
 patch/  KY( 
 days) 


 9.19 
 19.00 


 7.54 


 10.82 


 15.00 


 1 


 A.  2.1.3.1.1 
 Desi 
 gn 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 KY( 
 days) 


 23.73 
 2.38 
 21.79 


 6.67 
 19.77 


 3.00 
 18.76 


 9.33 
 1,2,3,4 


 A.  2.1.3.1.2 
 Design 
 (Specials)/<  10 


 circuits/  Non- 


 Dis 
 patch/  KY( 


 days) 


 4.15 
 3.49 
 2.55 
 3.88 
 6.92 
 3.75 
 6.57 
 2.00 
 3,4 


 A.  2.1.4.1.1 
 PBX/<  10 
 circuits/  Dis 


 patch/  KY( 
 days) 


 4.73 
 24.35 
 7.00 
 14.73 


 17.15 


 2 


 A.  2.1.4.1.2 
 PBX/<  10 
 circuits/  Non- 


 Dis  patch/ 
 KY( 
 days) 


 2.66 
 2.30 
 2.27 
 2.33 
 3.53 
 2.67 
 1.59 
 2.00 
 1,2,3,4 


 A.  2.1.4.2.2 
 PBX/>=  10 
 circuits/  Non- 


 Dis  patch/ 
 KY( 
 days) 


 0.96 


 1.24 
 3.00 
 4.80 


 1.33 
 2.00 
 2,4 


 A.  2.1.5.1.1 
 Centrex/<  10 
 circuits/  Dis 
 patch/  KY( 
 days) 


 7.08 
 5.99 
 1.00 
 6.16 


 6.47 


 2 


 A.  2.1.5.1.2 
 Centrex/<  10 
 circuits/  Non- 
 Dis  patch/ 
 KY( 
 days) 


 4.02 


 3.18 
 1.22 
 7.68 
 32.00 


 2.01 
 1.17 
 2,3,4 


 A.  2.1.6.1.1 
 ISDN/<  10 
 circuits/  Dis 
 patch/  KY( 
 days) 


 18.92 
 13.06 
 14.60 
 16.49 


 15.63 
 6.00 
 2,4 


 A.  2.1.6.1.2 
 ISDN/<  10 
 circuits/  Non- 


 Dis 
 patch/  KY( 


 days) 


 4.20 
 2.49 
 1.61 
 2.12 
 7.67 
 3.64 
 1.67 
 2,3,4 


 A.  2.1.6.2.1 
 ISDN/>=  10 
 circuits/  Dis 
 patch/  KY( 
 days) 


 12.00 
 4 


 % 
 Jeopardies 


 - 
 Mechanized 


 [P-  2] 


 A.  2.4.1 
 Residence/  KY 
 (%) 


 0.58% 
 0.66% 
 0.51% 
 0.60% 
 0.43% 
 0.40% 
 0.39% 
 0.35% 


 A.  2.4.2 
 Business/  KY 
 (%) 


 1.38% 
 1.56% 
 1.66% 
 0.00% 
 2.06% 
 2.69% 
 1.46% 
 0.67% 


 A.  2.4.4 
 PBX/  KY 
 (%) 


 3.08% 
 2.74% 
 0.00% 
 3.57% 


 2.08% 


 2 


 A.  2.4.5 
 Centrex/  KY 
 (%) 


 4.98% 
 4.07% 
 0.00% 
 5.51% 


 1.37% 
 0.00% 


 2,4 


 A.  2.4.6 
 ISDN/  KY 
 (%) 


 10.53% 
 8.33% 
 0.00% 
 8.23% 
 0.00% 
 2.64% 
 0.00% 
 2,3,4 


 % 
 Jeopardies 


 - 
 Non-  Mechanized 


 [P-  2] 


 A.  2.5.1 
 Residence/  KY 
 (%) 


 1.77% 
 3.26% 
 0.00% 
 0.68% 


 A.  2.5.2 
 Business/  KY 
 (%) 


 1.56% 
 1.08% 
 0.00% 
 0.00% 


 A.  2.5.3 
 Desi 
 gn 
 (Specials)/  KY(%) 


 0.00% 
 0.00% 
 0.00% 
 25.00% 
 3 


 A.  2.5.4 
 PBX/  KY 
 (%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3,4 


 A.  2.5.5 
 Centrex/  KY 
 (%) 


 0.00% 
 0.00% 
 0.00% 
 2,3,4 


 A.  2.5.6 
 ISDN/  KY 
 (%) 


 0.00% 
 20.00% 


 0.00% 
 0.00% 
 1,3,4 


 Average 
 Jeopardy 


 Notice 
 Interval 


 - 
 Mechanized 


 [P-  2] 


 A.  2.7.1 
 Residence/  KY 
 (hours) 


 272.93 
 136.01 
 151.35 
 165.48 


 A.  2.7.2 
 Business/  KY 
 (hours) 


 243.88 
 150.95 
 148.92 
 1,3,4 


 C-  7 
219
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Kentucky 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 Average 
 Jeopardy 


 Notice 
 Interval 


 - 
 Non-  Mechanized 


 [P-  2] 


 A.  2.8.1 
 Residence/  KY 
 (hours) 


 286.92 
 48.84 


 1,2 


 A.  2.8.2 
 Business/  KY 
 (hours) 


 40.18 
 33.15 


 1,2 


 A.  2.8.3 
 Desi 
 gn 
 (Specials)/  KY( 


 hours) 


 288.09 
 4 


 A.  2.8.6 
 ISDN/  KY 
 (hours) 


 496.22 
 2 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Mechanized 


 [P-  2] 


 A.  2.9.1 
 Residence/  KY 
 (%) 


 97.30% 
 100.00% 
 100.00% 
 100.00% 


 A.  2.9.2 
 Business/  KY 
 (%) 


 100.00% 
 80.00% 
 100.00% 
 1,3,4 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Non-  Mechanized 


 [P-  2] 


 A.  2.10.1 
 Residence/  KY 
 (%) 


 100.00% 
 50.00% 


 1,2 


 A.  2.10.2 
 Business/  KY 
 (%) 


 0.00% 
 0.00% 


 1,2 


 A.  2.10.3 
 Desi 
 gn 
 (Specials)/  KY(%) 


 100.00% 
 4 


 A.  2.10.6 
 ISDN/  KY 
 (%) 


 100.00% 
 2 


 % 
 Missed 


 Installation 


 Appointments 


 [P-  3] 


 A.  2.11.1.1.1 
 Residence/<  10 


 circuits/  Dis 
 patch/  KY(%) 


 7.61% 
 4.95% 
 7.31% 
 5.74% 
 15.04% 


 9.91% 
 13.82% 
 11.36% 


 A.  2.11.1.1.2 
 Residence/<  10 


 circuits/  Non- 
 Dis  patch/ 
 KY(%) 


 0.06% 
 0.08% 
 0.03% 
 0.04% 
 0.03% 
 0.06% 
 0.03% 
 0.02% 


 A.  2.11.1.2.1 
 Residence/>=  10 


 circuits/  Dis 
 patch/  KY(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 7.14% 


 13.33% 


 1,2 


 A.  2.11.2.1.1 
 Business/<  10 
 circuits/  Dis 
 patch/  KY(%) 


 1.30% 
 4.48% 
 1.42% 
 2.33% 
 3.48% 
 11.11% 


 6.92% 
 2.38% 


 A.  2.11.2.1.2 
 Business/<  10 
 circuits/  Non- 
 Dis  patch/ 
 KY(%) 


 0.28% 
 0.00% 
 0.03% 
 0.34% 
 0.02% 
 0.00% 
 0.07% 
 0.65% 


 A.  2.11.2.2.1 
 Business/>=  10 


 circuits/  Dis 
 patch/  KY(%) 


 8.89% 
 50.00% 


 3.39% 


 2.94% 
 6.25% 


 1 


 A.  2.11.2.2.2 
 Business/>=  10 


 circuits/  Non- 
 Dis  patch/ 
 KY(%) 


 0.00% 
 0.00% 


 0.00% 
 0.00% 


 1 


 A.  2.11.3.1.1 
 Desi 
 gn 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 KY(%) 
 2.49% 
 0.00% 
 3.83% 
 0.00% 
 5.42% 
 0.00% 
 6.08% 
 0.00% 
 2,3,4 


 A.  2.11.3.1.2 
 Design 
 (Specials)/<  10 


 circuits/  Non- 
 Dispatch/  KY(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.95% 
 25.00% 


 0.00% 
 0.00% 


 3,4 


 A.  2.11.4.1.1 
 PBX/<  10 
 circuits/  Dis 


 patch/  KY(%) 


 0.00% 
 3.45% 
 0.00% 
 11.76% 


 0.00% 


 2 


 A.  2.11.4.1.2 
 PBX/<  10 
 circuits/  Non- 


 Dis 
 patch/  KY(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 2.56% 
 0.00% 
 3.85% 
 0.00% 
 1,2,3,4 


 A.  2.11.4.2.2 
 PBX/>=  10 
 circuits/  Non- 


 Dis 
 patch/  KY(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 


 0.00% 
 0.00% 


 2,4 


 A.  2.11.5.1.1 
 Centrex/<  10 
 circuits/  Dis 
 patch/  KY(%) 


 0.00% 
 1.67% 
 0.00% 
 2.70% 


 3.39% 


 2 


 A.  2.11.5.1.2 
 Centrex/<  10 
 circuits/  Non- 
 Dis  patch/ 
 KY(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.81% 
 0.00% 
 2,3,4 


 A.  2.11.5.2.2 
 Centrex/>=  10 
 circuits/  Non- 
 Dis  patch/ 
 KY(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 3 


 A.  2.11.6.1.1 
 ISDN/<  10 
 circuits/  Dis 
 patch/  KY(%) 


 1.90% 
 0.81% 
 0.00% 
 2.50% 


 5.97% 
 0.00% 


 2,4 


 A.  2.11.6.1.2 
 ISDN/<  10 
 circuits/  Non- 


 Dis 
 patch/  KY(%) 


 1.52% 
 11.11% 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3,4 


 A.  2.11.6.2.1 
 ISDN/>=  10 
 circuits/  Dis 
 patch/  KY(%) 


 0.00% 
 4 


 C-  8 
220
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Kentucky 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 % 
 Provisioning 


 Troubles 
 within 
 30 
 Days 


 [P-  9] 


 A.  2.12.1.1.1 
 Residence/<  10 


 circuits/  Dis 
 patch/  KY(%) 


 10.76% 
 7.69% 
 9.65% 
 9.71% 
 11.76% 


 7.38% 
 11.36% 


 7.76% 


 A.  2.12.1.1.2 
 Residence/<  10 


 circuits/  Non- 
 Dis  patch/ 
 KY(%) 


 3.13% 
 6.21% 
 3.39% 
 4.58% 
 3.26% 
 3.39% 
 3.24% 
 3.41% 


 A.  2.12.1.2.1 
 Residence/>=  10 


 circuits/  Dis 
 patch/  KY(%) 


 25.00% 
 0.00% 
 100.00% 


 0.00% 
 0.00% 
 7.14% 


 2,3 


 A.  2.12.2.1.1 
 Business/<  10 
 circuits/  Dis 
 patch/  KY(%) 


 8.98% 
 14.29% 


 9.41% 
 19.70% 


 9.82% 
 4.65% 
 12.26% 


 3.17% 


 A.  2.12.2.1.2 
 Business/<  10 
 circuits/  Non- 
 Dis  patch/ 
 KY(%) 


 4.63% 
 5.29% 
 5.75% 
 1.05% 
 5.53% 
 4.79% 
 6.67% 
 4.43% 


 A.  2.12.2.2.1 
 Business/>=  10 


 circuits/  Dis 
 patch/  KY(%) 


 9.09% 
 13.33% 
 50.00% 
 15.25% 


 8.82% 


 2 


 A.  2.12.2.2.2 
 Business/>=  10 


 circuits/  Non- 
 Dis  patch/ 
 KY(%) 


 100.00% 
 0.00% 


 0.00% 
 2 


 A.  2.12.3.1.1 
 Desi 
 gn 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 KY(%) 
 4.84% 
 9.09% 
 4.59% 
 0.00% 
 6.05% 
 0.00% 
 3.80% 
 25.00% 


 3,4 


 A.  2.12.3.1.2 
 Design 
 (Specials)/<  10 


 circuits/  Non- 
 Dispatch/  KY(%) 


 3.24% 
 0.00% 
 0.00% 
 1.54% 
 2.01% 
 4.35% 
 2.86% 
 0.00% 


 1,4 


 A.  2.12.4.1.1 
 PBX/<  10 
 circuits/  Dis 


 patch/  KY(%) 


 23.08% 
 6.25% 
 0.00% 
 0.00% 
 0.00% 


 3 


 A.  2.12.4.1.2 
 PBX/<  10 
 circuits/  Non- 


 Dis 
 patch/  KY(%) 


 2.94% 
 0.00% 
 0.00% 
 11.11% 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3,4 


 A.  2.12.4.2.2 
 PBX/>=  10 
 circuits/  Non- 


 Dis 
 patch/  KY(%) 


 0.00% 
 0.00% 
 14.29% 
 0.00% 
 0.00% 


 3 


 A.  2.12.5.1.1 
 Centrex/<  10 
 circuits/  Dis 
 patch/  KY(%) 


 8.08% 
 0.00% 
 6.67% 
 0.00% 
 16.22% 


 3 


 A.  2.12.5.1.2 
 Centrex/<  10 
 circuits/  Non- 
 Dis  patch/ 
 KY(%) 


 6.62% 
 5.10% 
 5.94% 
 0.00% 
 7.24% 
 0.00% 


 3,4 


 A.  2.12.5.2.1 
 Centrex/>=  10 
 circuits/  Dis 
 patch/  KY(%) 


 0.00% 
 12.50% 


 7.14% 
 20.00% 


 A.  2.12.5.2.2 
 Centrex/>=  10 
 circuits/  Non- 
 Dis  patch/ 
 KY(%) 


 0.00% 
 0.00% 
 30.77% 
 22.73% 
 0.00% 


 4 


 A.  2.12.6.1.1 
 ISDN/<  10 
 circuits/  Dis 
 patch/  KY(%) 


 6.92% 
 6.33% 
 2.44% 
 0.00% 
 6.25% 


 3 


 A.  2.12.6.1.2 
 ISDN/<  10 
 circuits/  Non- 


 Dis 
 patch/  KY(%) 


 0.00% 
 0.00% 
 1.52% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3,4 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Mechanized 


 [P-  5] 


 A.  2.14.1.1.1 
 Residence/<  10 


 circuits/  Dis 
 patch/  KY( 
 hours) 


 4.13 
 0.15 
 2.94 
 0.60 
 2.30 
 0.02 
 1.86 
 0.02 


 A.  2.14.1.1.2 
 Residence/<  10 


 circuits/  Non- 
 Dis  patch/ 
 KY( 
 hours) 


 0.63 
 0.31 
 0.48 
 0.32 
 0.44 
 0.33 
 0.51 
 0.33 


 A.  2.14.2.1.1 
 Business/<  10 
 circuits/  Dis 
 patch/  KY( 
 hours) 


 1.81 
 0.94 
 3.12 
 0.25 
 1.91 
 0.94 
 2.00 
 0.02 


 A.  2.14.2.1.2 
 Business/<  10 
 circuits/  Non- 
 Dis  patch/ 
 KY( 
 hours) 


 1.06 
 0.25 
 1.48 
 0.29 
 1.43 
 0.30 
 0.88 
 0.29 


 A.  2.14.2.2.1 
 Business/>=  10 


 circuits/  Dis 
 patch/  KY( 
 hours) 


 0.64 
 0.02 
 1.30 


 5.17 
 0.02 


 1 


 A.  2.14.4.1.2 
 PBX/<  10 
 circuits/  Non- 


 Dis  patch/ 
 KY( 
 hours) 


 2.80 
 7.79 
 0.02 
 5.93 


 2.35 


 2 


 A.  2.14.5.1.2 
 Centrex/<  10 
 circuits/  Non- 
 Dis  patch/ 
 KY( 
 hours) 


 0.58 


 1.19 
 0.20 
 6.85 
 0.43 
 1.87 
 0.15 
 2,3,4 


 A.  2.14.6.1.2 
 ISDN/<  10 
 circuits/  Non- 


 Dis 
 patch/  KY( 


 hours) 


 12.27 


 11.08 
 0.02 
 7.72 
 0.28 
 10.09 


 0.30 
 2,3,4 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Non-  Mechanized 


 [P-  5] 


 A.  2.15.1.1.1 
 Residence/<  10 


 circuits/  Dis 
 patch/  KY( 
 hours) 


 13.67 
 21.23 
 11.52 
 21.19 


 A.  2.15.1.1.2 
 Residence/<  10 


 circuits/  Non- 
 Dis  patch/ 
 KY( 
 hours) 


 7.87 
 8.15 
 3.30 
 8.17 


 A.  2.15.1.2.1 
 Residence/>=  10 


 circuits/  Dis 
 patch/  KY( 
 hours) 


 15.23 
 0.02 


 1,2 


 C-  9 
221
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Kentucky 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 A.  2.15.2.1.1 
 Business/<  10 
 circuits/  Dispatch/ 


 KY( 
 hours) 


 12.56 
 18.00 
 20.42 
 21.05 


 A.  2.15.2.1.2 
 Business/<  10 
 circuits/  Non- 
 Dis  patch/ 
 KY( 
 hours) 


 9.78 
 11.53 


 14.23 
 16.13 


 A.  2.15.2.2.1 
 Business/>=  10 


 circuits/  Dis 
 patch/  KY( 
 hours) 


 15.73 


 1 


 A.  2.15.2.2.2 
 Business/>=  10 


 circuits/  Non- 
 Dis  patch/ 
 KY( 
 hours) 


 0.15 


 1 


 A.  2.15.3.1.1 
 Design 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 KY(  hours) 


 29.67 
 81.51 
 31.74 
 39.59 
 2,3,4 


 A.  2.15.3.1.2 
 Design 
 (Specials)/<  10 


 circuits/  Non- 


 Dispatch/  KY( 
 hours) 


 80.83 
 51.84 
 138.75 


 19.52 
 3,4 


 A.  2.15.4.1.1 
 PBX/<  10 
 circuits/  Dis 


 patch/  KY( 
 hours) 


 81.77 
 2 


 A.  2.15.4.1.2 
 PBX/<  10 
 circuits/  Non- 


 Dis  patch/ 
 KY( 
 hours) 


 39.38 
 35.81 
 20.54 
 14.00 
 1,2,3,4 


 A.  2.15.4.2.2 
 PBX/>=  10 
 circuits/  Non- 


 Dis 
 patch/  KY( 


 hours) 


 13.93 
 0.18 
 2,4 


 A.  2.15.5.1.1 
 Centrex/<  10 
 circuits/  Dis 
 patch/  KY( 
 hours) 


 23.93 
 2 


 A.  2.15.5.1.2 
 Centrex/<  10 
 circuits/  Non- 
 Dis  patch/ 
 KY( 
 hours) 


 14.48 
 22.38 
 15.32 
 2,3,4 


 A.  2.15.5.2.2 
 Centrex/>=  10 
 circuits/  Non- 
 Dis  patch/ 
 KY( 
 hours) 


 14.00 
 3 


 A.  2.15.6.1.1 
 ISDN/<  10 
 circuits/  Dis 
 patch/  KY( 
 hours) 


 68.13 
 166.57 
 2,4 


 A.  2.15.6.1.2 
 ISDN/<  10 
 circuits/  Non- 


 Dis 
 patch/  KY( 


 hours) 


 12.79 
 25.78 
 26.00 
 39.88 
 1,2,3,4 


 A.  2.15.6.2.1 
 ISDN/>=  10 
 circuits/  Dis 
 patch/  KY( 
 hours) 


 426.23 
 4 


 Service 
 Order 
 Accuracy 


 [P-  11] 


 A.  2.25.1.1.1 
 Residence/<  10 


 circuits/  Dis 
 patch/  KY(%) 


 92.14% 
 96.55% 
 90.77% 
 98.86% 


 A.  2.25.1.1.2 
 Residence/<  10 


 circuits/  Non- 
 Dis  patch/ 
 KY(%) 


 95.38% 
 94.29% 
 98.82% 
 98.56% 


 A.  2.25.1.2.1 
 Residence/>=  10 


 circuits/  Dis 
 patch/  KY(%) 


 100.00% 
 88.24% 
 100.00% 
 100.00% 
 4 


 A.  2.25.2.1.1 
 Business/<  10 
 circuits/  Dis 
 patch/  KY(%) 


 91.33% 
 95.76% 
 88.82% 
 94.44% 


 A.  2.25.2.1.2 
 Business/<  10 
 circuits/  Non- 
 Dis  patch/ 
 KY(%) 


 93.85% 
 97.93% 
 96.11% 
 97.22% 


 A.  2.25.2.2.1 
 Business/>=  10 


 circuits/  Dis 
 patch/  KY(%) 


 100.00% 
 77.78% 
 77.78% 
 76.92% 
 2 


 A.  2.25.2.2.2 
 Business/>=  10 


 circuits/  Non- 
 Dis  patch/ 
 KY(%) 


 84.62% 
 97.56% 
 92.59% 
 91.89% 


 A.  2.25.3.1.1 
 Desi 
 gn 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 KY(%) 


 81.08% 
 91.43% 
 80.49% 
 96.47% 


 A.  2.25.3.1.2 
 Design 
 (Specials)/<  10 


 circuits/  Non- 
 Dispatch/  KY(%) 


 91.84% 
 94.78% 
 91.43% 
 91.36% 


 A.  2.25.3.2.1 
 Desi 
 gn 
 (Specials)/>=  10 


 circuits/  Dispatch/ 


 KY(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 A.  2.25.3.2.2 
 Design 
 (Specials)/>=  10 


 circuits/  Non- 
 Dispatch/  KY(%) 


 100.00% 
 90.00% 
 92.31% 
 88.89% 
 1,4 


 RESALE 
 - 
 MAINTENANCE 


 AND 
 REPAIR 


 Missed 
 Repair 
 Appointments 


 [M&  R- 
 1] 


 A.  3.1.1.1 
 Residence/  Dis 
 patch/  KY(%) 


 9.05% 
 5.00% 
 8.60% 
 4.39% 
 15.82% 


 8.98% 
 14.43% 


 9.49% 


 C-  10 
222
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Kentucky 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 A.  3.1.1.2 
 Residence/  Non- 


 Dispatch/  KY(%) 


 1.39% 
 0.00% 
 1.31% 
 1.01% 
 2.41% 
 2.25% 
 2.11% 
 2.91% 


 A.  3.1.2.1 
 Business/  Dis 
 patch/  KY(%) 


 7.99% 
 12.86% 


 6.62% 
 6.49% 
 14.99% 


 5.88% 
 16.21% 
 17.44% 


 A.  3.1.2.2 
 Business/  Non- 


 Dis 
 patch/  KY(%) 


 2.14% 
 0.00% 
 1.09% 
 0.00% 
 1.94% 
 0.00% 
 2.98% 
 0.00% 


 A.  3.1.3.1 
 Desi 
 gn 
 (Specials)/  Dispatch/ 


 KY(%) 


 2.16% 
 0.00% 
 1.70% 
 0.00% 
 1.83% 
 0.00% 
 2.50% 
 0.00% 
 1,2,3,4 


 A.  3.1.3.2 
 Desi 
 gn 
 (Specials)/  Non- 


 Dispatch/  KY(%) 


 0.37% 
 0.00% 
 0.83% 
 0.00% 
 0.52% 
 6.25% 
 0.31% 
 0.00% 


 2 


 A.  3.1.4.1 
 PBX/  Dis 
 patch/  KY(%) 


 14.46% 
 0.00% 
 4.44% 
 0.00% 
 4.00% 
 0.00% 
 7.06% 
 8.33% 


 3 


 A.  3.1.4.2 
 PBX/  Non- 
 Dis 
 patch/  KY(%) 


 1.92% 
 0.00% 
 3.08% 
 0.00% 
 1.37% 
 0.00% 
 2.33% 
 0.00% 


 3 


 A.  3.1.5.1 
 Centrex/  Dis 
 patch/  KY(%) 


 9.04% 
 33.33% 


 5.93% 
 50.00% 
 27.91% 
 0.00% 
 19.18% 


 0.00% 
 1,2,3 


 A.  3.1.5.2 
 Centrex/  Non- 
 Dis 
 patch/  KY(%) 


 4.94% 
 0.00% 
 3.95% 
 0.00% 
 5.78% 
 0.00% 
 11.90% 


 0.00% 


 A.  3.1.6.1 
 ISDN/  Dis 
 patch/  KY(%) 


 0.00% 
 0.00% 
 2.33% 
 0.00% 
 0.00% 
 0.00% 
 2.08% 
 0.00% 


 2,3 


 A.  3.1.6.2 
 ISDN/  Non- 
 Dis 
 patch/  KY(%) 


 1.49% 
 0.00% 
 1.56% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1,3,4 


 Customer 
 Trouble 
 Report 
 Rate 
 [M&  R- 


 2] 


 A.  3.2.1.1 
 Residence/  Dis 
 patch/  KY(%) 


 2.09% 
 2.19% 
 2.33% 
 1.88% 
 2.63% 
 2.81% 
 2.50% 
 2.62% 


 A.  3.2.1.2 
 Residence/  Non- 


 Dis  patch/ 
 KY(%) 


 0.96% 
 0.48% 
 0.90% 
 0.37% 
 1.06% 
 0.43% 
 1.06% 
 0.51% 


 A.  3.2.2.1 
 Business/  Dis 
 patch/  KY(%) 


 1.14% 
 0.94% 
 1.19% 
 1.09% 
 1.37% 
 1.24% 
 1.33% 
 1.29% 


 A.  3.2.2.2 
 Business/  Non- 


 Dis 
 patch/  KY(%) 


 0.43% 
 0.40% 
 0.53% 
 0.30% 
 0.53% 
 0.18% 
 0.53% 
 0.30% 


 A.  3.2.3.1 
 Desi 
 gn 
 (Specials)/  Dispatch/ 


 KY(%) 


 1.41% 
 0.87% 
 1.40% 
 0.87% 
 1.49% 
 0.86% 
 1.93% 
 0.24% 


 A.  3.2.3.2 
 Desi 
 gn 
 (Specials)/  Non- 


 Dispatch/  KY(%) 


 1.85% 
 1.24% 
 1.64% 
 0.37% 
 1.96% 
 1.98% 
 2.25% 
 1.96% 


 A.  3.2.4.1 
 PBX/  Dis 
 patch/  KY(%) 


 0.21% 
 0.00% 
 0.23% 
 2.41% 
 0.19% 
 1.54% 
 0.22% 
 2.28% 


 A.  3.2.4.2 
 PBX/  Non- 
 Dis 
 patch/  KY(%) 


 0.13% 
 0.00% 
 0.17% 
 0.00% 
 0.19% 
 0.58% 
 0.11% 
 0.00% 


 A.  3.2.5.1 
 Centrex/  Dis 
 patch/  KY(%) 


 0.34% 
 0.69% 
 0.24% 
 0.52% 
 0.46% 
 0.34% 
 0.39% 
 0.00% 


 A.  3.2.5.2 
 Centrex/  Non- 
 Dis 
 patch/  KY(%) 


 0.15% 
 0.00% 
 0.14% 
 0.00% 
 0.31% 
 0.00% 
 0.22% 
 0.00% 


 A.  3.2.6.1 
 ISDN/  Dis 
 patch/  KY(%) 


 0.05% 
 0.00% 
 0.06% 
 0.51% 
 0.03% 
 0.35% 
 0.06% 
 0.00% 


 A.  3.2.6.2 
 ISDN/  Non- 
 Dis 
 patch/  KY(%) 


 0.09% 
 0.63% 
 0.08% 
 0.00% 
 0.08% 
 0.52% 
 0.08% 
 0.16% 


 Maintenance 
 Average 
 Duration 


 [M&  R- 
 3] 


 A.  3.3.1.1 
 Residence/  Dis 
 patch/  KY( 
 hours) 


 23.04 
 18.62 
 22.21 
 17.13 
 32.47 
 27.17 
 33.11 
 26.73 


 A.  3.3.1.2 
 Residence/  Non- 


 Dis  patch/ 
 KY( 
 hours) 


 8.96 
 5.79 
 7.37 
 3.43 
 12.01 


 11.71 
 13.00 


 5.12 


 A.  3.3.2.1 
 Business/  Dis 
 patch/  KY( 
 hours) 


 9.46 
 12.56 


 9.81 
 9.17 
 13.52 


 11.66 
 13.21 
 13.12 


 A.  3.3.2.2 
 Business/  Non- 


 Dis 
 patch/  KY( 


 hours) 


 2.65 
 3.44 
 2.53 
 1.81 
 3.57 
 2.00 
 3.64 
 3.40 


 A.  3.3.3.1 
 Desi 
 gn 
 (Specials)/  Dispatch/ 


 KY( 
 hours) 


 4.73 
 2.56 
 4.52 
 2.95 
 5.59 
 4.96 
 5.00 
 1.21 
 1,2,3,4 


 A.  3.3.3.2 
 Desi 
 gn 
 (Specials)/  Non- 


 Dispatch/  KY( 
 hours) 


 2.25 
 3.11 
 2.30 
 1.52 
 2.32 
 3.04 
 2.50 
 0.74 


 2 


 A.  3.3.4.1 
 PBX/  Dis 
 patch/  KY( 


 hours) 


 11.03 
 0.00 
 7.91 
 14.83 


 7.90 
 6.92 
 7.60 
 23.94 


 3 


 A.  3.3.4.2 
 PBX/  Non- 
 Dis 
 patch/  KY( 


 hours) 


 3.92 
 0.00 
 4.36 
 0.00 
 3.69 
 9.18 
 5.04 
 0.00 


 3 


 A.  3.3.5.1 
 Centrex/  Dis 
 patch/  KY( 
 hours) 


 12.58 
 22.75 
 12.60 
 14.50 
 14.95 


 6.00 
 14.17 


 0.00 
 1,2,3 


 C-  11 
223
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Kentucky 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 A.  3.3.5.2 
 Centrex/  Non- 
 Dispatch/  KY( 
 hours) 


 4.23 
 0.00 
 6.14 
 0.00 
 6.75 
 0.00 
 5.64 
 0.00 


 A.  3.3.6.1 
 ISDN/  Dis 
 patch/  KY( 
 hours) 


 4.74 
 0.00 
 5.58 
 3.17 
 6.48 
 7.74 
 6.49 
 0.00 
 2,3 


 A.  3.3.6.2 
 ISDN/  Non- 
 Dis 
 patch/  KY( 


 hours) 


 2.37 
 4.78 
 2.86 
 0.00 
 2.64 
 3.13 
 4.92 
 0.55 
 1,3,4 


 % 
 Repeat 


 Troubles 


 within 
 30 
 Days 


 [M&  R- 


 4] 


 A.  3.4.1.1 
 Residence/  Dis 
 patch/  KY(%) 


 17.15% 
 12.33% 
 18.83% 
 12.97% 
 20.30% 
 13.99% 
 20.14% 
 15.18% 


 A.  3.4.1.2 
 Residence/  Non- 


 Dis  patch/ 
 KY(%) 


 14.79% 
 12.21% 
 15.85% 
 9.09% 
 16.93% 
 10.11% 
 15.67% 
 14.56% 


 A.  3.4.2.1 
 Business/  Dis 
 patch/  KY(%) 


 14.12% 
 12.86% 
 14.49% 
 10.39% 
 13.92% 
 11.76% 
 15.95% 
 10.47% 


 A.  3.4.2.2 
 Business/  Non- 


 Dis 
 patch/  KY(%) 


 14.08% 
 10.00% 
 11.80% 
 4.76% 
 14.31% 
 16.67% 
 9.51% 
 5.00% 


 A.  3.4.3.1 
 Desi 
 gn 
 (Specials)/  Dispatch/ 


 KY(%) 


 17.03% 
 28.57% 
 23.54% 
 28.57% 
 17.39% 
 0.00% 
 26.96% 


 0.00% 
 1,2,3,4 


 A.  3.4.3.2 
 Desi 
 gn 
 (Specials)/  Non- 


 Dispatch/  KY(%) 


 13.03% 
 10.00% 
 18.22% 
 0.00% 
 16.46% 


 6.25% 
 18.47% 


 6.25% 


 2 


 A.  3.4.4.1 
 PBX/  Dis 
 patch/  KY(%) 


 8.43% 
 0.00% 
 5.56% 
 0.00% 
 13.33% 
 25.00% 
 9.41% 
 25.00% 


 3 


 A.  3.4.4.2 
 PBX/  Non- 
 Dis 
 patch/  KY(%) 


 3.85% 
 0.00% 
 9.23% 
 0.00% 
 4.11% 
 0.00% 
 9.30% 
 0.00% 


 3 


 A.  3.4.5.1 
 Centrex/  Dis 
 patch/  KY(%) 


 11.70% 
 33.33% 
 10.37% 
 0.00% 
 11.63% 


 0.00% 
 10.96% 


 0.00% 
 1,2,3 


 A.  3.4.5.2 
 Centrex/  Non- 
 Dis 
 patch/  KY(%) 


 6.17% 
 0.00% 
 11.84% 


 0.00% 
 7.51% 
 0.00% 
 15.08% 


 0.00% 


 A.  3.4.6.1 
 ISDN/  Dis 
 patch/  KY(%) 


 13.16% 
 0.00% 
 16.28% 


 0.00% 
 16.67% 
 50.00% 
 16.67% 
 0.00% 
 2,3 


 A.  3.4.6.2 
 ISDN/  Non- 
 Dis 
 patch/  KY(%) 


 8.96% 
 0.00% 
 14.06% 


 0.00% 
 19.70% 
 33.33% 
 8.06% 
 0.00% 
 1,3,4 


 Out 
 of 
 Service 


 > 
 24 


 hours 


 [M&  R- 


 5] 


 A.  3.5.1.1 
 Residence/  Dis 
 patch/  KY(%) 


 14.08% 
 8.66% 
 14.22% 


 9.02% 
 26.76% 
 17.76% 
 16.96% 
 10.42% 


 A.  3.5.1.2 
 Residence/  Non- 


 Dis  patch/ 
 KY(%) 


 6.18% 
 5.17% 
 5.32% 
 2.44% 
 10.49% 


 7.69% 
 7.58% 
 5.17% 


 A.  3.5.2.1 
 Business/  Dis 
 patch/  KY(%) 


 3.12% 
 2.08% 
 4.21% 
 2.27% 
 8.39% 
 4.00% 
 7.38% 
 8.77% 


 A.  3.5.2.2 
 Business/  Non- 


 Dis 
 patch/  KY(%) 


 1.06% 
 0.00% 
 1.47% 
 0.00% 
 2.76% 
 0.00% 
 2.57% 
 0.00% 


 3,4 


 A.  3.5.3.1 
 Desi 
 gn 
 (Specials)/  Dispatch/ 


 KY(%) 


 2.16% 
 0.00% 
 1.70% 
 0.00% 
 1.83% 
 0.00% 
 2.50% 
 0.00% 
 1,2,3,4 


 A.  3.5.3.2 
 Desi 
 gn 
 (Specials)/  Non- 


 Dispatch/  KY(%) 


 0.37% 
 0.00% 
 0.83% 
 0.00% 
 0.52% 
 6.25% 
 0.31% 
 0.00% 


 2 


 A.  3.5.4.1 
 PBX/  Dis 
 patch/  KY(%) 


 6.06% 
 0.00% 
 3.61% 
 0.00% 
 3.08% 
 0.00% 
 5.00% 
 0.00% 
 2,3,4 


 A.  3.5.4.2 
 PBX/  Non- 
 Dis 
 patch/  KY(%) 


 2.27% 
 0.00% 
 3.45% 
 0.00% 
 2.13% 
 0.00% 
 2.50% 
 0.00% 


 3 


 A.  3.5.5.1 
 Centrex/  Dis 
 patch/  KY(%) 


 5.10% 
 0.00% 
 6.10% 
 0.00% 
 9.66% 
 0.00% 
 13.49% 


 0.00% 
 1,3 


 A.  3.5.5.2 
 Centrex/  Non- 
 Dis 
 patch/  KY(%) 


 4.65% 
 0.00% 
 0.00% 
 0.00% 
 6.19% 
 0.00% 
 6.25% 
 0.00% 


 A.  3.5.6.1 
 ISDN/  Dis 
 patch/  KY(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 2.08% 
 0.00% 


 2,3 


 A.  3.5.6.2 
 ISDN/  Non- 
 Dis 
 patch/  KY(%) 


 1.49% 
 0.00% 
 1.56% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1,3,4 


 RESALE 
 - 
 BILLING  Invoice  Accuracy 


 [B-  1] 


 A.  4.1 
 KY 
 (%) 


 99.18% 
 99.79% 
 98.68% 
 99.59% 
 98.67% 
 99.68% 
 98.38% 
 99.18% 


 Mean 
 Time 
 to 
 Deliver 


 Invoices 


 - 
 CRIS 


 [B-  2] 


 C-  12 
224
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Kentucky 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 A.  4.2 
 Region( 
 business 


 days) 


 3.68 
 3.56 
 3.86 
 3.27 
 3.47 
 3.16 
 3.82 
 3.37 


 UNBUNDLED 
 NETWORK 
 ELEMENTS 


 - 
 ORDERING 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Mechanized 


 [O-  7] 


 B.  1.1.3 
 Loo  p 
 + 
 Port 


 Combinations/  KY(%) 


 23.64% 
 20.18% 
 23.00% 
 22.38% 


 B.  1.1.4 
 Combo 
 Other/  KY 


 (%) 


 50.00% 
 4 


 B.  1.1.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  KY(%) 


 33.33% 
 17.50% 
 5.56% 
 16.88% 


 B.  1.1.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  KY(%) 


 25.00% 
 0.00% 
 25.00% 
 36.36% 
 1,2 


 B.  1.1.7 
 Line 
 Sharin  g/ 


 KY(%) 


 15.71% 
 25.45% 
 29.41% 
 17.39% 


 B.  1.1.8 
 2W 
 Analo  g 


 Loop 
 Design/  KY(%) 


 16.00% 
 10.42% 
 33.33% 
 55.81% 


 B.  1.1.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 KY(%) 


 27.27% 
 28.57% 
 0.00% 
 0.00% 
 2,3,4 


 B.  1.1.14 
 Other 
 Desi  gn/ 


 KY(%) 


 61.29% 
 20.34% 
 37.50% 
 25.00% 


 B.  1.1.15 
 Other 
 Non-  Desi 


 gn/  KY(%) 


 18.70% 
 9.40% 
 8.76% 
 16.97% 


 B.  1.1.17 
 LNP 
 Standalone/  KY 


 (%) 


 4.07% 
 5.32% 
 4.16% 
 4.17% 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Partially 


 Mechanized 


 [O-  7] 


 B.  1.2.3 
 Loo  p 
 + 
 Port 


 Combinations/  KY(%) 


 26.57% 
 32.36% 
 42.27% 
 35.24% 


 B.  1.2.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  KY(%) 


 0.00% 
 100.00% 


 0.00% 


 1,2,3 


 B.  1.2.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  KY(%) 


 10.00% 
 12.50% 
 10.00% 


 B.  1.2.7 
 Line 
 Sharin  g/ 


 KY(%) 


 57.14% 
 63.16% 
 11.11% 
 58.82% 
 1,3 


 B.  1.2.8 
 2W 
 Analo  g 


 Loop 
 Design/  KY(%) 


 45.00% 
 0.00% 
 50.00% 


 0.00% 
 2,3,4 


 B.  1.2.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 KY(%) 


 75.00% 
 0.00% 
 100.00% 


 50.00% 
 1,2,3,4 


 B.  1.2.14 
 Other 
 Desi  gn/ 


 KY(%) 


 31.25% 
 38.24% 
 38.10% 
 15.38% 


 B.  1.2.15 
 Other 
 Non-  Desi 


 gn/  KY(%) 


 44.62% 
 20.00% 
 19.85% 
 16.97% 


 B.  1.2.17 
 LNP 
 Standalone/  KY 


 (%) 


 15.94% 
 12.88% 
 11.29% 
 8.27% 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Non-  Mechanized 


 [O-  7] 


 B.  1.3.2 
 Local 
 Interoffice 


 Trans  port/ 
 KY(%) 


 50.00% 
 20.00% 
 0.00% 


 1,3 


 B.  1.3.3 
 Loo  p 
 + 
 Port 


 Combinations/  KY(%) 


 51.71% 
 43.24% 
 54.07% 
 44.33% 


 B.  1.3.4 
 Combo 
 Other/  KY 


 (%) 


 66.67% 
 25.00% 
 43.33% 
 1,3 


 B.  1.3.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  KY(%) 


 33.33% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3,4 


 B.  1.3.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  KY(%) 


 0.00% 
 50.00% 
 100.00% 


 0.00% 
 1,2,3,4 


 B.  1.3.7 
 Line 
 Sharin  g/ 


 KY(%) 


 13.33% 
 40.00% 
 27.27% 
 100.00% 
 2,4 


 B.  1.3.8 
 2W 
 Analo  g 


 Loop 
 Design/  KY(%) 


 0.00% 
 0.00% 
 0.00% 
 1,3,4 


 B.  1.3.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 KY(%) 


 42.86% 
 50.00% 
 75.00% 
 2,3,4 


 B.  1.3.14 
 Other 
 Desi 
 gn/  KY(%) 


 38.78% 
 27.59% 
 27.08% 
 27.27% 


 C-  13 
225
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Kentucky 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 B.  1.3.15 
 Other 
 Non-  Design/ 


 KY(%) 


 29.63% 
 32.08% 
 36.26% 
 42.11% 


 B.  1.3.16 
 INP 
 Standalone/  KY 


 (%) 


 75.00% 
 40.00% 
 0.00% 
 50.00% 
 1,3,4 


 B.  1.3.17 
 LNP 
 Standalone/  KY 


 (%) 


 27.27% 
 37.19% 
 27.03% 
 27.12% 


 Reject 
 Interval 


 - 
 Mechanized 


 [O-  8] 


 B.  1.4.3 
 Loo  p 
 + 
 Port 


 Combinations/  KY(%) 


 93.58% 
 92.55% 
 93.37% 
 95.71% 


 B.  1.4.4 
 Combo 
 Other/  KY 


 (%) 


 0.00% 
 4 


 B.  1.4.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  KY(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2,3 


 B.  1.4.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  KY(%) 


 100.00% 
 100.00% 
 100.00% 
 1,3,4 


 B.  1.4.7 
 Line 
 Sharin  g/ 


 KY(%) 


 81.82% 
 42.86% 
 100.00% 


 87.50% 
 4 


 B.  1.4.8 
 2W 
 Analo  g 


 Loop 
 Design/  KY(%) 


 62.50% 
 100.00% 


 46.15% 
 66.67% 
 1,2 


 B.  1.4.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 KY(%) 


 33.33% 
 50.00% 


 1,2 


 B.  1.4.14 
 Other 
 Desi  gn/ 


 KY(%) 


 94.74% 
 66.67% 
 85.71% 
 54.55% 


 B.  1.4.15 
 Other 
 Non-  Desi 


 gn/  KY(%) 


 96.65% 
 94.37% 
 84.33% 
 79.33% 


 B.  1.4.17 
 LNP 
 Standalone/  KY 


 (%) 


 100.00% 
 98.55% 
 95.16% 
 100.00% 


 Reject 
 Interval 


 - 
 Partially 


 Mechanized 


 - 
 10 


 hours 


 [O-  8] 


 B.  1.7.3 
 Loo  p 
 + 
 Port 


 Combinations/  KY(%) 


 94.37% 
 98.42% 
 60.86% 
 96.55% 


 B.  1.7.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  KY(%) 


 0.00% 
 2 


 B.  1.7.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  KY(%) 


 100.00% 
 100.00% 
 100.00% 


 1,2,3 


 B.  1.7.7 
 Line 
 Sharin  g/ 


 KY(%) 


 100.00% 
 100.00% 


 0.00% 
 100.00% 
 1,3 


 B.  1.7.8 
 2W 
 Analo  g 


 Loop 
 Design/  KY(%) 


 88.89% 
 66.67% 
 1,3 


 B.  1.7.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 KY(%) 


 100.00% 


 0.00% 
 100.00% 
 1,3,4 


 B.  1.7.14 
 Other 
 Desi  gn/ 


 KY(%) 


 86.67% 
 100.00% 


 62.50% 
 100.00% 
 3,4 


 B.  1.7.15 
 Other 
 Non-  Desi 


 gn/  KY(%) 


 93.10% 
 95.24% 
 98.08% 
 92.98% 


 B.  1.7.17 
 LNP 
 Standalone/  KY 


 (%) 


 84.93% 
 91.06% 
 92.86% 
 92.86% 


 Reject 
 Interval 


 - 
 Non-  Mechanized 


 [O-  8] 


 B.  1.8.2 
 Local 
 Interoffice 


 Trans  port/ 
 KY(%) 


 100.00% 
 100.00% 


 1,2 


 B.  1.8.3 
 Loo  p 
 + 
 Port 


 Combinations/  KY(%) 


 98.17% 
 98.44% 
 97.89% 
 97.73% 


 B.  1.8.4 
 Combo 
 Other/  KY 


 (%) 


 100.00% 
 100.00% 
 100.00% 
 1,3 


 B.  1.8.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  KY(%) 


 100.00% 


 100.00% 
 1,4 


 B.  1.8.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  KY(%) 


 100.00% 
 100.00% 


 2,3 


 B.  1.8.7 
 Line 
 Sharin  g/ 


 KY(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 B.  1.8.8 
 2W 
 Analo  g 


 Loop 
 Design/  KY(%) 


 B.  1.8.9 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 KY(%) 


 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 C-  14 
226
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Kentucky 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 B.  1.8.14 
 Other 
 Design/  KY(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2,4 


 B.  1.8.15 
 Other 
 Non-  Desi 


 gn/  KY(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  1.8.16 
 INP 
 Standalone/  KY 


 (%) 


 100.00% 
 100.00% 


 100.00% 
 1,2,4 


 B.  1.8.17 
 LNP 
 Standalone/  KY 


 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 FOC 
 Timeliness 


 - 
 Mechanized 


 [O-  9] 


 B.  1.9.3 
 Loo  p 
 + 
 Port 


 Combinations/  KY(%) 


 99.27% 
 98.95% 
 99.29% 
 97.46% 


 B.  1.9.4 
 Combo 
 Other/  KY 


 (%) 


 0.00% 
 4 


 B.  1.9.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  KY(%) 


 92.59% 
 100.00% 


 96.55% 
 98.15% 


 B.  1.9.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  KY(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 B.  1.9.7 
 Line 
 Sharin  g/ 


 KY(%) 


 100.00% 
 100.00% 
 100.00% 
 97.44% 


 B.  1.9.8 
 2W 
 Analo  g 


 Loop 
 Design/  KY(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  1.9.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 KY(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 B.  1.9.14 
 Other 
 Desi  gn/ 


 KY(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  1.9.15 
 Other 
 Non-  Desi 


 gn/  KY(%) 


 96.36% 
 95.27% 
 97.84% 
 97.95% 


 B.  1.9.17 
 LNP 
 Standalone/  KY 


 (%) 


 99.91% 
 100.00% 


 96.18% 
 93.71% 


 FOC 
 Timeliness 


 - 
 Partially 


 Mechanized 


 - 
 10 


 hours 


 [O-  9] 


 B.  1.12.3 
 Loo  p 
 + 
 Port 


 Combinations/  KY(%) 


 92.80% 
 94.01% 
 78.91% 
 89.59% 


 B.  1.12.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  KY(%) 


 100.00% 
 100.00% 
 100.00% 


 1,2,3 


 B.  1.12.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  KY(%) 


 96.30% 
 96.15% 
 100.00% 


 B.  1.12.7 
 Line 
 Sharin  g/ 


 KY(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 B.  1.12.8 
 2W 
 Analo  g 


 Loop 
 Design/  KY(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 B.  1.12.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 KY(%) 


 100.00% 
 66.67% 


 100.00% 
 1,2,4 


 B.  1.12.14 
 Other 
 Desi  gn/ 


 KY(%) 


 97.14% 
 100.00% 


 93.75% 
 100.00% 


 B.  1.12.15 
 Other 
 Non-  Desi 


 gn/  KY(%) 


 63.77% 
 68.57% 
 93.23% 
 92.28% 


 B.  1.12.17 
 LNP 
 Standalone/  KY 


 (%) 


 66.74% 
 71.43% 
 89.03% 
 91.88% 


 FOC 
 Timeliness 


 - 
 Non-  Mechanized 


 [O-  9] 


 B.  1.13.2 
 Local 
 Interoffice 


 Trans  port/ 
 KY(%) 


 100.00% 
 100.00% 
 100.00% 


 1,2,3 


 B.  1.13.3 
 Loo  p 
 + 
 Port 


 Combinations/  KY(%) 


 100.00% 
 96.88% 
 96.34% 
 97.83% 


 B.  1.13.4 
 Combo 
 Other/  KY 


 (%) 


 100.00% 
 100.00% 
 100.00% 
 1,3 


 B.  1.13.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  KY(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 B.  1.13.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  KY(%) 


 100.00% 
 100.00% 


 100.00% 
 1,2,4 


 B.  1.13.7 
 Line 
 Sharin  g/ 


 KY(%) 


 100.00% 
 100.00% 
 100.00% 


 2,3 


 B.  1.13.8 
 2W 
 Analo  g 


 Loop 
 Design/  KY(%) 


 100.00% 
 100.00% 
 100.00% 
 1,3,4 


 C-  15 
227
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Kentucky 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 B.  1.13.9 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 KY(%) 


 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 B.  1.13.14 
 Other 
 Desi 
 gn/  KY(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 4 


 B.  1.13.15 
 Other 
 Non-  Desi 


 gn/  KY(%) 


 100.00% 
 100.00% 
 100.00% 
 98.63% 


 B.  1.13.16 
 INP 
 Standalone/  KY 


 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 B.  1.13.17 
 LNP 
 Standalone/  KY 


 (%) 


 98.00% 
 100.00% 
 100.00% 
 100.00% 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Mechanized 


 [O-  11] 


 B.  1.14.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  EDI/ 


 KY(%) 


 98.46% 
 99.86% 
 96.91% 
 99.77% 


 B.  1.14.3.2 
 Loo  p 
 + 
 Port 


 Combinations/  TAG/ 


 KY(%) 


 98.52% 
 98.45% 
 98.18% 
 99.84% 


 B.  1.14.4.2 
 Combo 
 Other/  TAG/ 


 KY  (%) 


 50.00% 
 4 


 B.  1.14.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  EDI/ 


 KY(%) 


 87.50% 
 100.00% 


 80.65% 
 95.56% 


 B.  1.14.5.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  TAG/ 


 KY(%) 


 78.95% 
 100.00% 
 100.00% 
 75.00% 
 2,3 


 B.  1.14.6.1 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  EDI/ 


 KY(%) 


 0.00% 


 100.00% 
 1 


 B.  1.14.6.2 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  TAG/ 


 KY(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,4 


 B.  1.14.7.1 
 Line 
 Sharin  g/ 


 EDI/  KY(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  1.14.7.2 
 Line 
 Sharin  g/ 


 TAG/  KY(%) 


 94.74% 
 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 B.  1.14.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  EDI/ 


 KY(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 3,4 


 B.  1.14.8.2 
 2W 
 Analo  g 


 Loop 
 Design/  TAG/ 


 KY(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  1.14.9.2 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 TAG/  KY(%) 


 63.64% 
 100.00% 


 75.00% 
 100.00% 
 2,3,4 


 B.  1.14.14.1 
 Other 
 Desi  gn/ 


 EDI/  KY(%) 


 100.00% 
 95.65% 
 92.31% 
 100.00% 


 B.  1.14.14.2 
 Other 
 Desi  gn/ 


 TAG/  KY(%) 


 100.00% 
 100.00% 
 95.35% 
 100.00% 


 B.  1.14.15.1 
 Other 
 Non-  Desi 


 gn/  EDI/ 
 KY(%) 


 100.00% 
 99.86% 
 99.39% 
 98.34% 


 B.  1.14.15.2 
 Other 
 Non-  Desi 


 gn/  TAG/ 
 KY(%) 


 76.27% 
 93.88% 
 90.48% 
 90.00% 


 B.  1.14.17.1 
 LNP 
 Standalone/  EDI/ 


 KY  (%) 


 100.00% 
 99.92% 
 98.99% 
 100.00% 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Partially 


 Mechanized 


 [O-  11] 


 B.  1.15.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  EDI/ 


 KY(%) 


 100.00% 
 99.76% 
 98.64% 
 99.63% 


 B.  1.15.3.2 
 Loo  p 
 + 
 Port 


 Combinations/  TAG/ 


 KY(%) 


 99.49% 
 99.07% 
 99.78% 
 99.92% 


 B.  1.15.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  EDI/ 


 KY(%) 


 100.00% 
 100.00% 


 2,3 


 B.  1.15.5.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  TAG/ 


 KY(%) 


 100.00% 


 1 


 B.  1.15.6.1 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  EDI/ 


 KY(%) 


 100.00% 
 100.00% 
 100.00% 


 1 


 B.  1.15.6.2 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  TAG/ 


 KY(%) 


 100.00% 
 100.00% 
 100.00% 


 B.  1.15.7.1 
 Line 
 Sharin  g/ 


 EDI/  KY(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,3 


 B.  1.15.7.2 
 Line 
 Sharin  g/ 


 TAG/  KY(%) 


 100.00% 
 83.33% 
 100.00% 


 66.67% 
 1,2,3,4 


 B.  1.15.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  EDI/ 


 KY(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 B.  1.15.8.2 
 2W 
 Analo  g 


 Loop 
 Design/  TAG/ 


 KY(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 C-  16 
228
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Kentucky 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 B.  1.15.9.2 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 TAG/  KY(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 B.  1.15.14.1 
 Other 
 Desi  gn/ 


 EDI/  KY(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 B.  1.15.14.2 
 Other 
 Desi  gn/ 


 TAG/  KY(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 4 


 B.  1.15.15.1 
 Other 
 Non-  Desi 


 gn/  EDI/ 
 KY(%) 


 100.00% 
 100.00% 
 88.70% 
 99.37% 


 B.  1.15.15.2 
 Other 
 Non-  Desi 


 gn/  TAG/ 
 KY(%) 


 97.37% 
 96.55% 
 96.88% 
 85.71% 


 B.  1.15.17.1 
 LNP 
 Standalone/  EDI/ 


 KY  (%) 


 98.91% 
 97.60% 
 100.00% 


 99.38% 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Non-  Mechanized 


 [O-  11] 


 B.  1.16.2 
 Local 
 Interoffice 


 Trans  port/ 
 KY(%) 


 100.00% 
 90.00% 
 62.50% 


 1,3 


 B.  1.16.3 
 Loo  p 
 + 
 Port 


 Combinations/  KY(%) 


 97.56% 
 96.62% 
 98.84% 
 92.78% 


 B.  1.16.4 
 Combo 
 Other/  KY 


 (%) 


 100.00% 
 100.00% 
 100.00% 
 1,3 


 B.  1.16.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  KY(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 B.  1.16.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  KY(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 B.  1.16.7 
 Line 
 Sharin  g/ 


 KY(%) 


 93.33% 
 100.00% 
 100.00% 
 100.00% 
 2,4 


 B.  1.16.8 
 2W 
 Analo  g 


 Loop 
 Design/  KY(%) 


 100.00% 
 100.00% 
 100.00% 
 1,3,4 


 B.  1.16.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 KY(%) 


 100.00% 
 62.50% 
 100.00% 
 2,3,4 


 B.  1.16.14 
 Other 
 Desi 
 gn/  KY(%) 


 97.96% 
 100.00% 


 97.92% 
 90.91% 


 B.  1.16.15 
 Other 
 Non-  Desi 


 gn/  KY(%) 


 98.77% 
 99.06% 
 97.80% 
 99.25% 


 B.  1.16.16 
 INP 
 Standalone/  KY 


 (%) 


 75.00% 
 90.00% 
 100.00% 
 100.00% 
 1,3,4 


 B.  1.16.17 
 LNP 
 Standalone/  KY 


 (%) 


 96.97% 
 99.17% 
 99.10% 
 98.31% 


 UNBUNDLED 
 NETWORK 
 ELEMENTS 


 - 
 PROVISIONING 


 Order 
 Completion 


 Interval 
 [P-  4] 


 B.  2.1.2.1.1 
 Local 
 Interoffice 


 Transport/<  10 


 circuits/  Dis 
 patch/  KY( 
 days) 


 16.89 
 18.92 
 14.00 
 17.57 
 17.00 
 16.18 
 19.00 
 2,3,4 


 B.  2.1.3.1.1 
 Loop 
 + 
 Port 


 Combinations/<  10  circuits/  Dis  patch/  KY(  days) 


 3.96 
 2.74 
 4.70 
 2.95 
 5.29 
 3.53 
 6.03 
 3.11 


 B.  2.1.3.1.2 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Non- 


 Dis 
 patch/  KY( 


 days) 


 0.92 
 0.60 
 0.91 
 0.60 
 0.94 
 0.63 
 0.91 
 0.68 


 B.  2.1.3.1.3 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Switch 
 Based 


 Orders/  KY 
 (days) 


 0.33 
 0.33 
 0.33 
 0.33 
 0.33 
 0.33 
 0.33 
 0.33 


 B.  2.1.3.1.4 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Dispatch 


 In/  KY 
 (days) 


 1.57 
 1.25 
 1.56 
 1.14 
 1.55 
 1.18 
 1.49 
 1.21 


 B.  2.1.3.2.1 
 Loop 
 + 
 Port 


 Combinations/>=  10  circuits/  Dis  patch/  KY(  days) 


 9.60 
 2.00 
 7.87 


 9.19 
 1.00 
 10.02 


 1.67 
 1,3,4 


 B.  2.1.4.1.1 
 Combo 
 Other/<  10 


 circuits/  Dis 
 patch/  KY( 
 days) 


 5.06 
 10.91 


 5.68 
 11.21 


 6.26 
 11.44 


 7.09 
 13.92 


 C-  17 
229
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Kentucky 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 B.  2.1.6.3.1 
 UNE 
 ISDN/<  6 


 circuits/  Dispatch/ 


 KY( 
 days) 


 13.26 
 8.64 
 11.41 


 8.56 
 11.83 


 8.63 
 13.39 


 8.46 
 2 


 B.  2.1.7.3.1 
 Line 
 Sharin  g/< 


 6 
 circuits/  Dispatch/ 


 KY( 
 days) 


 3.92 
 3.00 
 4.38 
 4.20 
 4.02 
 5.00 
 3.04 
 4.00 
 1,2,3,4 


 B.  2.1.7.3.2 
 Line 
 Sharin  g/< 


 6 
 circuits/  Non- 


 Dispatch/  KY( 


 days) 
 3.75 


 3.83 
 4.05 
 3.61 
 3.93 
 2.46 
 3.85 


 B.  2.1.8.1.1 
 2W 
 Analog 


 Loop 
 Design/<  10 


 circuits/  Dis 
 patch/  KY( 
 days) 


 3.96 
 4.70 
 5.29 
 3.00 
 6.03 
 5.50 
 3,4 


 B.  2.1.9.1.1 
 2W 
 Analog 


 Loop 
 Non-  Design/< 


 10 


 circuits/  Dis 
 patch/  KY( 
 days) 


 3.97 
 4.00 
 4.69 
 3.60 
 5.27 


 6.03 
 3.60 
 1,2,4 


 B.  2.1.15.1.1 
 Other 
 Non-  Desi 


 gn/<  10 
 circuits/  Dispatch/ 


 KY( 
 days) 


 3.96 
 6.33 
 4.70 
 10.33 


 5.29 
 6.00 
 6.03 


 1,2,3 


 B.  2.1.15.1.2 
 Other 
 Non-  Design/< 


 10 
 circuits/  Non- 


 Dis 
 patch/  KY( 


 days) 


 0.92 
 0.91 
 0.94 
 0.91 


 B.  2.1.16.1.2 
 INP 
 (Standalone)/<  10 


 circuits/  Non- 
 Dispatch/  KY( 


 days) 
 0.92 


 0.91 
 0.33 
 0.93 
 2.00 
 0.91 


 2,3 


 B.  2.1.17.1.2 
 LNP 
 (Standalone)/<  10 


 circuits/  Non- 


 Dis 
 patch/  KY( 


 days) 


 0.92 
 0.83 
 0.91 
 0.77 
 0.93 
 0.85 
 0.91 
 0.87 


 B.  2.1.17.2.2 
 LNP 
 (Standalone)/>=  10 


 circuits/  Non- 


 Dis 
 patch/  KY( 


 days) 


 0.33 
 1.67 
 0.33 
 7.00 


 4 


 B.  2.1.18.1.1 
 Digital 
 Loop 
 < 
 DS1/<  10 


 circuits/  Dispatch/ 


 KY(  days) 
 14.78 
 6.65 
 17.82 


 7.07 
 13.31 


 7.70 
 16.13 


 6.25 


 B.  2.1.19.1.1 
 Digital 
 Loop 
 >= 
 DS1/<  10 


 circuits/  Dispatch/ 


 KY(  days) 
 25.51 
 6.13 
 15.76 


 5.27 
 14.02 


 5.60 
 14.85 


 6.06 


 Order 
 Completion 


 Interval 
 within 
 X 
 days 


 [P-  4] 


 B.  2.2.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL) 


 Loop 
 w/  o 


 Conditionin  g/< 
 6 
 circuits/  Dispatch/ 


 KY( 
 days) 


 4.33 
 4.40 
 4.00 
 4.33 
 2,3 


 % 
 Jeopardies 


 - 
 Mechanized 


 [P-  2] 


 B.  2.5.3 
 Loo  p 
 + 
 Port 


 Combinations/  KY(%) 


 0.65% 
 0.19% 
 0.60% 
 0.23% 
 0.55% 
 0.07% 
 0.47% 
 0.06% 


 B.  2.5.4 
 Combo 
 Other/  KY 


 (%) 


 7.49% 
 8.02% 
 8.90% 
 8.85% 


 B.  2.5.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  KY(%) 


 100.00% 
 0.00% 
 0.00% 


 0.00% 
 4 


 B.  2.5.6 
 UNE 
 ISDN/  KY 


 (%) 


 10.14% 
 0.00% 
 7.87% 
 33.33% 


 5.88% 
 11.76% 


 8.96% 
 11.11% 


 1,2,4 


 B.  2.5.7 
 Line 
 Sharin  g/ 


 KY(%) 


 9.78% 
 0.00% 
 8.85% 
 0.00% 
 6.74% 


 4.60% 
 0.00% 
 1,2,4 


 B.  2.5.8 
 2W 
 Analo  g 


 Loop 
 Design/  KY(%) 


 0.65% 
 0.60% 
 0.55% 
 0.00% 
 0.47% 
 0.00% 


 3,4 


 B.  2.5.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 KY(%) 


 1.19% 
 0.00% 
 1.11% 
 0.00% 
 0.98% 
 0.00% 
 0.86% 
 0.00% 
 1,2,3,4 


 B.  2.5.15 
 Other 
 Non-  Desi 


 gn/  KY(%) 


 0.65% 
 0.60% 
 0.55% 
 0.47% 


 B.  2.5.17 
 LNP 
 (Standalone)/  KY(%) 


 0.65% 
 0.00% 
 0.59% 
 0.00% 
 0.54% 
 0.00% 
 0.47% 
 0.00% 


 B.  2.5.18 
 Di 
 gital 


 Loop 


 < 
 DS1/  KY(%) 


 7.07% 
 0.00% 
 5.83% 
 33.33% 


 7.66% 
 11.76% 


 6.95% 
 5.88% 


 1,2 


 C-  18 
230
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Kentucky 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 B.  2.5.19 
 Digital 
 Loop 
 >= 
 DS1/  KY(%) 


 17.89% 
 61.54% 
 24.14% 
 81.58% 
 35.87% 
 78.57% 
 5.54% 
 60.87% 


 % 
 Jeopardies 


 - 
 Non-  Mechanized 


 [P-  2] 


 B.  2.6.2 
 Local 
 Interoffice 


 Trans  port/ 
 KY(%) 


 50.00% 
 0.00% 
 0.00% 
 2,3,4 


 B.  2.6.3 
 Loo  p 
 + 
 Port 


 Combinations/  KY(%) 


 2.78% 
 1.63% 
 0.38% 
 0.51% 


 B.  2.6.4 
 Combo 
 Other/  KY 


 (%) 


 69.23% 
 57.89% 
 73.91% 
 61.54% 


 B.  2.6.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  KY(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 2,3,4 


 B.  2.6.6 
 UNE 
 ISDN/  KY 


 (%) 


 0.00% 


 100.00% 
 1,4 


 B.  2.6.7 
 Line 
 Sharin  g/ 


 KY(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 


 B.  2.6.8 
 2W 
 Analo  g 


 Loop 
 Design/  KY(%) 


 0.00% 
 4 


 B.  2.6.15 
 Other 
 Non-  Desi 


 gn/  KY(%) 


 0.00% 
 0.00% 
 0.00% 


 1,2,3 


 B.  2.6.16 
 INP 
 (Standalone)/  KY(%) 


 0.00% 
 0.00% 


 2,3 


 B.  2.6.17 
 LNP 
 (Standalone)/  KY(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 


 B.  2.6.18 
 Di  gital 
 Loop 
 < 
 DS1/  KY(%) 


 0.00% 
 0.00% 
 0.00% 
 11.11% 
 2,3,4 


 B.  2.6.19 
 Di  gital 
 Loop 
 >= 
 DS1/  KY(%) 


 42.86% 
 100.00% 


 25.00% 
 40.00% 
 1,2,3,4 


 Average 
 Jeopardy 


 Notice 
 Interval 


 - 
 Mechanized 


 [P-  2] 


 B.  2.8.3 
 Loo  p 
 + 
 Port 


 Combinations/  KY( 


 hours) 


 180.47 
 118.31 
 155.55 
 103.39 
 1,2,3,4 


 B.  2.8.4 
 Combo 
 Other/  KY 


 (hours) 


 B.  2.8.6 
 UNE 
 ISDN/  KY( 


 hours) 


 336.61 
 350.93 
 342.68 
 2,3,4 


 B.  2.8.18 
 Di 
 gital 


 Loop 


 < 
 DS1/  KY( 


 hours) 


 336.61 
 350.93 
 342.68 
 2,3,4 


 B.  2.8.19 
 Di 
 gital 


 Loop 


 >= 
 DS1/  KY( 


 hours) 


 223.64 
 194.23 
 189.63 
 190.94 
 1 


 Average 
 Jeopardy 


 Notice 
 Interval 


 - 
 Non-  Mechanized 


 [P-  2] 


 B.  2.9.2 
 Local 
 Interoffice 


 Trans  port/ 
 KY( 
 hours) 


 544.28 
 2 


 B.  2.9.3 
 Loo  p 
 + 
 Port 


 Combinations/  KY( 


 hours) 


 200.51 
 80.07 
 352.13 


 40.13 
 1,2,3,4 


 B.  2.9.4 
 Combo 
 Other/  KY 


 (hours) 


 325.60 
 331.47 
 312.10 
 375.09 
 1,4 


 B.  2.9.6 
 UNE 
 ISDN/  KY 


 (hours) 


 304.20 
 4 


 B.  2.9.18 
 Di 
 gital 


 Loop 


 < 
 DS1/  KY( 


 hours) 


 304.20 
 4 


 B.  2.9.19 
 Di 
 gital 


 Loop 


 >= 
 DS1/  KY( 


 hours) 


 251.81 
 125.65 
 272.73 
 1,3,4 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Mechanized 


 [P-  2] 


 B.  2.10.3 
 Loo  p 
 + 
 Port 


 Combinations/  KY(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 B.  2.10.4 
 Combo 
 Other/  KY 


 (%) 


 B.  2.10.6 
 UNE 
 ISDN/  KY(%) 


 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 B.  2.10.18 
 Di 
 gital 


 Loop 


 < 
 DS1/  KY(%) 


 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 B.  2.10.19 
 Di 
 gital 


 Loop 


 >= 
 DS1/  KY(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1 


 C-  19 
231
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Kentucky 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Non-  Mechanized 


 [P-  2] 


 B.  2.11.2 
 Local 
 Interoffice 


 Trans  port/ 
 KY(%) 


 100.00% 
 2 


 B.  2.11.3 
 Loo  p 
 + 
 Port 


 Combinations/  KY(%) 


 100.00% 
 100.00% 
 100.00% 


 0.00% 
 1,2,3,4 


 B.  2.11.4 
 Combo 
 Other/  KY 


 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,4 


 B.  2.11.6 
 UNE 
 ISDN/  KY 


 (%) 


 100.00% 
 4 


 B.  2.11.18 
 Di 
 gital 


 Loop 


 < 
 DS1/  KY(%) 


 100.00% 
 4 


 B.  2.11.19 
 Di 
 gital 


 Loop 


 >= 
 DS1/  KY(%) 


 100.00% 
 100.00% 
 100.00% 
 1,3,4 


 % 
 Provisioning 


 Troubles 
 within 
 7 
 Days 


 - 
 Hot 


 Cuts 


 [P-  7C] 


 B.  2.17.1.1 
 UNE 
 Loo 
 p 
 Design/  Dispatch/ 


 KY(%) 


 % 
 Missed 


 Installation 


 Appointments 


 [P-  3] 


 B.  2.18.2.1.1 
 Local 
 Interoffice 


 Transport/<  10 


 circuits/  Dis 
 patch/  KY(%) 


 0.95% 
 8.91% 
 0.00% 
 2.54% 
 0.00% 
 2.61% 
 0.00% 
 2,3,4 


 B.  2.18.3.1.1 
 Loop 
 + 
 Port 


 Combinations/<  10  circuits/  Dis  patch/  KY(%) 


 4.57% 
 3.65% 
 4.79% 
 7.09% 
 10.49% 


 6.67% 
 12.09% 


 7.75% 


 B.  2.18.3.1.2 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Non- 


 Dis 
 patch/  KY(%) 


 0.07% 
 0.53% 
 0.03% 
 0.00% 
 0.03% 
 0.04% 
 0.03% 
 0.08% 


 B.  2.18.3.1.3 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Switch 
 Based 


 Orders/  KY 
 (%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 B.  2.18.3.1.4 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Dispatch 


 In/  KY 
 (%) 


 0.13% 
 1.24% 
 0.06% 
 0.00% 
 0.05% 
 0.07% 
 0.07% 
 0.13% 


 B.  2.18.3.2.1 
 Loop 
 + 
 Port 


 Combinations/>=  10  circuits/  Dis  patch/  KY(%) 


 5.48% 
 0.00% 
 2.11% 
 0.00% 
 8.62% 
 0.00% 
 6.67% 
 0.00% 
 1,2,3,4 


 B.  2.18.3.2.2 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Non- 


 Dis 
 patch/  KY(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 


 0.00% 


 2 


 B.  2.18.3.2.4 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Dispatch 


 In/  KY 
 (%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 


 0.00% 


 2 


 B.  2.18.4.1.1 
 Combo 
 Other/<  10 


 circuits/  Dis 
 patch/  KY(%) 


 4.44% 
 7.69% 
 4.71% 
 10.53% 
 10.15% 
 4.55% 
 11.61% 


 7.69% 


 B.  2.18.5.1.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/<  10 


 circuits/  Dis 
 patch/  KY(%) 


 66.67% 
 0.00% 


 0.00% 
 0.00% 
 0.00% 
 2,3 


 B.  2.18.6.1.1 
 UNE 
 ISDN/<  10 


 circuits/  Dis 
 patch/  KY(%) 


 0.92% 
 0.00% 
 1.20% 
 0.00% 
 4.88% 
 0.00% 
 4.88% 
 0.00% 


 2 


 B.  2.18.7.1.1 
 Line 
 Sharin  g/< 


 10 
 circuits/  Dispatch/ 


 KY(%) 


 5.42% 
 0.00% 
 5.24% 
 14.29% 


 7.62% 
 0.00% 
 9.86% 
 0.00% 
 1,2,3,4 


 B.  2.18.7.1.2 
 Line 
 Sharin  g/< 


 10 
 circuits/  Non- 


 Dispatch/  KY(%) 


 0.78 
 0.39% 
 0.00% 
 0.08% 
 0.00% 
 0.07% 
 0.00% 


 C-  20 
232
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Kentucky 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 B.  2.18.8.1.1 
 2W 
 Analog 


 Loop 
 Design/<  10 


 circuits/  Dispatch/ 


 KY(%) 
 4.57% 


 4.79% 
 10.49% 
 0.00% 
 12.09% 


 0.00% 
 3,4 


 B.  2.18.9.1.1 
 2W 
 Analog 


 Loop 
 Non-  Design/< 


 10 


 circuits/  Dis 
 patch/  KY(%) 


 4.60% 
 0.00% 
 4.83% 
 0.00% 
 10.61% 


 0.00% 
 12.24% 


 0.00% 
 1,2,3,4 


 B.  2.18.15.1.1 
 Other 
 Non-  Desi 


 gn/<  10 
 circuits/  Dispatch/ 


 KY(%) 
 4.57% 
 0.00% 
 4.79% 
 0.00% 
 10.49% 


 0.00% 
 12.09% 


 1,2,3 


 B.  2.18.15.1.2 
 Other 
 Non-  Design/< 


 10 
 circuits/  Non- 


 Dispatch/  KY(%) 


 0.07% 
 0.03% 
 0.03% 
 0.03% 


 B.  2.18.16.1.1 
 INP 
 (Standalone)/<  10 


 circuits/  Dispatch/ 
 KY(%) 
 4.60% 


 4.83% 
 10.61% 
 100.00% 


 12.24% 


 3 


 B.  2.18.16.1.2 
 INP 
 (Standalone)/<  10 


 circuits/  Non- 
 Dispatch/  KY(%) 


 0.07% 
 0.03% 
 0.00% 
 0.03% 
 0.00% 
 0.03% 


 2,3 


 B.  2.18.17.1.2 
 LNP 
 (Standalone)/<  10 


 circuits/  Non- 
 Dispatch/  KY(%) 


 0.07% 
 0.31% 
 0.03% 
 0.06% 
 0.03% 
 0.54% 
 0.03% 
 0.13% 


 B.  2.18.17.2.2 
 LNP 
 (Standalone)/>=  10 


 circuits/  Non- 
 Dispatch/  KY(%) 


 0.00% 
 0.00% 


 0.00% 
 0.00% 
 0.00% 


 1,4 


 B.  2.18.18.1.1 
 Di 
 gital 


 Loop 


 < 
 DS1/<  10 


 circuits/  Dispatch/ 


 KY(%) 
 2.44% 
 0.00% 
 1.88% 
 0.00% 
 3.33% 
 0.00% 
 12.17% 


 0.00% 


 B.  2.18.19.1.1 
 Di 
 gital 


 Loop 


 >= 
 DS1/<  10 


 circuits/  Dispatch/ 


 KY(%) 
 3.85% 
 0.00% 
 1.12% 
 0.00% 
 1.50% 
 8.57% 
 8.20% 
 3.70% 


 % 
 Provisioning 


 Troubles 
 within 
 30 
 Days 


 [P-  9] 


 B.  2.19.2.1.1 
 Local 
 Interoffice 


 Transport/<  10 


 circuits/  Dis 
 patch/  KY(%) 


 8.74% 
 7.89% 
 10.34% 
 0.00% 
 7.97% 
 0.00% 


 3,4 


 B.  2.19.3.1.1 
 Loop 
 + 
 Port 


 Combinations/<  10  circuits/  Dis  patch/  KY(%) 


 9.95% 
 11.61% 


 9.48% 
 8.15% 
 10.89% 
 10.24% 
 11.77% 
 16.00% 


 B.  2.19.3.1.2 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Non- 


 Dis 
 patch/  KY(%) 


 3.20% 
 3.90% 
 3.50% 
 3.38% 
 3.36% 
 3.41% 
 3.40% 
 3.61% 


 B.  2.19.3.1.3 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Switch 
 Based 


 Orders/  KY 
 (%) 


 3.05% 
 3.16% 
 3.46% 
 3.02% 
 3.35% 
 3.68% 
 3.20% 
 3.36% 


 B.  2.19.3.1.4 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Dispatch 


 In/  KY 
 (%) 


 3.35% 
 4.93% 
 3.54% 
 3.84% 
 3.38% 
 3.18% 
 3.59% 
 3.84% 


 B.  2.19.3.2.1 
 Loop 
 + 
 Port 


 Combinations/>=  10  circuits/  Dis  patch/  KY(%) 


 11.76% 
 50.00% 
 10.96% 
 0.00% 
 10.53% 


 0.00% 
 10.34% 


 0.00% 
 1,2,3,4 


 B.  2.19.3.2.2 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Non- 


 Dis 
 patch/  KY(%) 


 0.00% 
 2.63% 
 19.23% 
 0.00% 
 15.15% 


 3 


 B.  2.19.3.2.3 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Switch 
 Based 


 Orders/  KY 
 (%) 


 0.00% 
 11.11% 
 16.67% 
 0.00% 


 C-  21 
233
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Kentucky 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 B.  2.19.3.2.4 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Dispatch 


 In/  KY 
 (%) 


 0.00% 
 0.00% 
 20.00% 
 0.00% 
 15.63% 


 3 


 B.  2.19.4.1.1 
 Combo 
 Other/<  10 


 circuits/  Dis 
 patch/  KY(%) 


 9.68% 
 7.69% 
 9.24% 
 7.69% 
 10.57% 
 21.05% 
 11.28% 
 13.64% 


 B.  2.19.4.1.4 
 Combo 
 Other/<  10 


 circuits/  Dis 


 patch 
 In/  KY(%) 


 9.68% 
 9.24% 
 10.57% 
 11.28% 


 B.  2.19.5.1.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/<  10 


 circuits/  Dis 
 patch/  KY(%) 


 0.00% 
 0.00% 
 14.29% 


 0.00% 
 0.00% 
 3,4 


 B.  2.19.6.1.1 
 UNE 
 ISDN/<  10 


 circuits/  Dis 
 patch/  KY(%) 


 7.89% 
 10.00% 


 9.17% 
 0.00% 
 2.41% 
 22.22% 


 7.32% 
 5.88% 


 3 


 B.  2.19.7.1.1 
 Line 
 Sharin  g/< 


 10 
 circuits/  Dispatch/ 


 KY(%) 


 8.54% 
 0.00% 
 4.14% 
 0.00% 
 4.27% 
 14.29% 


 4.86% 
 0.00% 
 1,2,3,4 


 B.  2.19.7.1.2 
 Line 
 Sharin  g/< 


 10 
 circuits/  Non- 


 Dispatch/  KY(%) 


 8.19% 
 0.00% 
 1.49% 
 5.88% 
 4.11% 
 17.39% 


 2.25% 
 10.34% 


 1 


 B.  2.19.8.1.1 
 2W 
 Analog 


 Loop 
 Design/<  10 


 circuits/  Dispatch/ 


 KY(%) 
 9.95% 


 9.48% 
 10.89% 
 11.77% 
 0.00% 


 4 


 B.  2.19.9.1.1 
 2W 
 Analog 


 Loop 
 Non-  Design/< 


 10 


 circuits/  Dis 
 patch/  KY(%) 


 9.97% 
 0.00% 
 9.54% 
 0.00% 
 10.95% 


 0.00% 
 11.71% 


 0.00% 
 1,2,3,4 


 B.  2.19.12.1.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/<  10 


 circuits/  Dis 
 patch/  KY(%) 


 9.95% 
 9.48% 
 10.89% 
 11.77% 


 B.  2.19.14.1.1 
 Other 
 Desi  gn/< 


 10 
 circuits/  Dispatch/ 


 KY(%) 


 5.59% 
 4.89% 
 5.17% 
 4.05% 


 B.  2.19.15.1.1 
 Other 
 Non-  Desi 


 gn/<  10 
 circuits/  Dispatch/ 


 KY(%) 
 9.95% 
 0.00% 
 9.48% 
 16.67% 
 10.89% 
 66.67% 
 11.77% 
 0.00% 
 1,2,3,4 


 B.  2.19.15.1.2 
 Other 
 Non-  Design/< 


 10 
 circuits/  Non- 


 Dispatch/  KY(%) 


 3.20% 
 3.50% 
 3.36% 
 3.40% 


 B.  2.19.16.1.1 
 INP 
 (Standalone)/<  10 


 circuits/  Dispatch/ 
 KY(%) 
 9.97% 


 9.54% 
 10.95% 
 11.71% 
 0.00% 


 4 


 B.  2.19.16.1.2 
 INP 
 (Standalone)/<  10 


 circuits/  Non- 
 Dispatch/  KY(%) 


 3.20% 
 3.50% 
 3.36% 
 0.00% 
 3.40% 
 0.00% 


 3,4 


 B.  2.19.17.1.2 
 LNP 
 (Standalone)/<  10 


 circuits/  Non- 
 Dispatch/  KY(%) 


 3.20% 
 0.00% 
 3.50% 
 0.00% 
 3.36% 
 0.00% 
 3.40% 
 0.00% 


 B.  2.19.17.2.2 
 LNP 
 (Standalone)/>=  10 


 circuits/  Non- 
 Dispatch/  KY(%) 


 0.00% 
 100.00% 


 0.00% 


 0.00% 
 1,2 


 B.  2.19.18.1.1 
 Di 
 gital 


 Loop 


 < 
 DS1/<  10 


 circuits/  Dispatch/ 


 KY(%) 
 6.58% 
 4.76% 
 6.10% 
 7.14% 
 1.25% 
 11.76% 


 6.67% 
 4.55% 


 B.  2.19.19.1.1 
 Di 
 gital 


 Loop 


 >= 
 DS1/<  10 


 circuits/  Dispatch/ 


 KY(%) 
 3.19% 
 0.00% 
 2.56% 
 9.52% 
 2.25% 
 5.13% 
 1.50% 
 14.29% 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Mechanized 


 [P-  5] 


 B.  2.21.3.1.1 
 Loop 
 + 
 Port 


 Combinations/<  10  circuits/  Dis  patch/  KY(  hours) 


 3.03 
 0.22 
 3.01 
 0.24 
 2.27 
 0.19 
 1.89 
 0.08 


 B.  2.21.3.1.2 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Non- 


 Dis 
 patch/  KY( 


 hours) 


 0.65 
 0.34 
 0.52 
 0.36 
 0.50 
 0.38 
 0.53 
 0.38 


 C-  22 
234
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Kentucky 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 B.  2.21.3.1.3 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Switch 
 Based 


 Orders/  KY 
 (hours) 


 0.80 
 0.32 
 0.64 
 0.34 
 0.61 
 0.35 
 0.66 
 0.36 


 B.  2.21.3.1.4 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Dispatch 


 In/  KY 
 (hours) 


 0.51 
 0.35 
 0.41 
 0.37 
 0.39 
 0.40 
 0.42 
 0.39 


 B.  2.21.3.2.1 
 Loop 
 + 
 Port 


 Combinations/>=  10  circuits/  Dis  patch/  KY(  hours) 


 0.49 
 49.28 


 0.82 
 0.02 
 3.25 
 0.02 
 0.36 
 0.02 
 1,2,3,4 


 B.  2.21.5.1.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/<  10 


 circuits/  Dis 
 patch/  KY( 
 hours) 


 0.02 


 0.57 
 4 


 B.  2.21.6.1.1 
 UNE 
 ISDN/<  10 


 circuits/  Dis 
 patch/  KY( 
 hours) 


 26.45 
 0.93 
 47.73 


 0.59 
 44.65 


 13.67 
 38.49 


 0.44 
 1,2 


 B.  2.21.7.1.2 
 Line 
 Sharing/<  10 


 circuits/  Non- 
 Dispatch/  KY( 


 hours) 
 0.35 


 0.76 
 0.17 
 0.34 


 0.43 
 0.53 
 2,4 


 B.  2.21.8.1.1 
 2W 
 Analog 


 Loop 
 Design/<  10 


 circuits/  Dis 
 patch/  KY( 
 hours) 


 3.03 
 3.01 
 2.27 
 117.95 


 1.89 
 12.36 


 3,4 


 B.  2.21.9.1.1 
 2W 
 Analog 


 Loop 
 Non-  Design/< 


 10 


 circuits/  Dis 
 patch/  KY( 
 hours) 


 3.02 
 0.02 
 3.01 
 3.12 
 2.15 
 3.81 
 1.89 
 0.02 
 1,2,3,4 


 B.  2.21.17.1.2 
 LNP 
 (Standalone)/<  10 


 circuits/  Non- 


 Dis 
 patch/  KY( 


 hours) 


 0.65 
 0.26 
 0.52 
 0.26 
 0.49 
 0.28 
 0.53 
 0.27 


 B.  2.21.17.2.2 
 LNP 
 (Standalone)/>=  10 


 circuits/  Non- 


 Dis 
 patch/  KY( 


 hours) 


 0.42 
 0.32 
 0.13 


 B.  2.21.18.1.1 
 Digital 
 Loop 
 < 
 DS1/<  10 


 circuits/  Dispatch/ 


 KY(  hours) 
 41.56 
 0.93 
 224.62 


 0.59 
 96.72 


 13.67 
 177.90 


 0.49 
 1,2 


 B.  2.21.19.1.1 
 Digital 
 Loop 
 >= 
 DS1/<  10 


 circuits/  Dispatch/ 


 KY(  hours) 
 284.45 
 12.21 
 145.82 


 56.76 
 124.46 


 23.03 
 95.60 
 25.84 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Non-  Mechanized 


 [P-  5] 


 B.  2.22.2.1.1 
 Local 
 Interoffice 


 Transport/<  10 


 circuits/  Dis 
 patch/  KY( 
 hours) 


 14.70 
 15.90 
 27.26 
 2,3,4 


 B.  2.22.3.1.1 
 Loop 
 + 
 Port 


 Combinations/<  10  circuits/  Dis  patch/  KY(  hours) 


 12.14 
 12.16 
 24.53 
 11.19 


 B.  2.22.3.1.2 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Non- 


 Dis 
 patch/  KY( 


 hours) 


 8.71 
 8.51 
 6.51 
 9.26 


 B.  2.22.3.1.3 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Switch 
 Based 


 Orders/  KY 
 (hours) 


 7.81 
 2.49 
 1.31 
 8.53 


 B.  2.22.3.1.4 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Dispatch 


 In/  KY 
 (hours) 


 9.76 
 19.83 


 17.70 
 11.39 


 C-  23 
235
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Kentucky 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 B.  2.22.3.2.1 
 Loop 
 + 
 Port 


 Combinations/>=  10  circuits/  Dis  patch/  KY(  hours) 


 B.  2.22.3.2.2 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Non- 


 Dis 
 patch/  KY( 


 hours) 


 38.00 
 2 


 B.  2.22.3.2.4 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Dispatch 


 In/  KY 
 (hours) 


 38.00 
 2 


 B.  2.22.4.1.1 
 Combo 
 Other/<  10 


 circuits/  Dis 
 patch/  KY( 
 hours) 


 61.62 
 77.74 
 60.32 
 47.99 


 B.  2.22.5.1.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/<  10 


 circuits/  Dis 
 patch/  KY( 
 hours) 


 9.09 
 10.32 


 8.67 
 7.61 
 2,3,4 


 B.  2.22.6.1.1 
 UNE 
 ISDN/<  10 


 circuits/  Dis 
 patch/  KY( 
 hours) 


 27.29 


 19.32 
 1,4 


 B.  2.22.7.1.1 
 Line 
 Sharin  g/< 


 10 
 circuits/  Dispatch/ 


 KY( 
 hours) 


 0.02 
 0.27 
 0.02 
 0.02 
 1,2,3,4 


 B.  2.22.7.1.2 
 Line 
 Sharing/<  10 


 circuits/  Non- 
 Dispatch/  KY( 


 hours) 


 0.54 
 1.53 
 0.72 
 0.28 


 B.  2.22.8.1.1 
 2W 
 Analog 


 Loop 
 Design/<  10 


 circuits/  Dispatch/ 
 KY( 
 hours) 


 111.05 
 4 


 B.  2.22.15.1.1 
 Other 
 Non-  Design/< 


 10 
 circuits/  Dispatch/ 


 KY(  hours) 


 19.28 
 35.87 
 16.48 


 1,2,3 


 B.  2.22.15.1.2 
 Other 
 Non-  Design/< 


 10 
 circuits/  Non- 


 Dis 
 patch/  KY( 


 hours) 


 B.  2.22.16.1.1 
 INP 
 (Standalone)/<  10 


 circuits/  Dispatch/ 
 KY( 
 hours) 


 14.00 
 3 


 B.  2.22.16.1.2 
 INP 
 (Standalone)/<  10 


 circuits/  Non- 


 Dis 
 patch/  KY( 


 hours) 


 14.00 
 81.68 


 2,3 


 B.  2.22.17.1.2 
 LNP 
 (Standalone)/<  10 


 circuits/  Non- 


 Dis 
 patch/  KY( 


 hours) 


 5.60 
 3.39 
 2.56 
 1.75 


 B.  2.22.17.2.2 
 LNP 
 (Standalone)/>=  10 


 circuits/  Non- 


 Dis 
 patch/  KY( 


 hours) 


 0.20 


 0.28 
 1,4 


 B.  2.22.18.1.1 
 Digital 
 Loop 
 < 
 DS1/<  10 


 circuits/  Dispatch/ 


 KY(  hours) 


 13.88 
 10.32 


 8.67 
 8.91 
 2,3,4 


 B.  2.22.19.1.1 
 Digital 
 Loop 
 >= 
 DS1/<  10 


 circuits/  Dispatch/ 


 KY(  hours) 


 33.75 
 55.33 
 25.19 
 45.05 
 1,2,3,4 


 Service 
 Order 
 Accuracy 


 [P-  11] 


 B.  2.34.1.1.1 
 Desi 
 gn 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 KY(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  2.34.1.1.2 
 Design 
 (Specials)/<  10 


 circuits/  Non- 
 Dispatch/  KY(%) 


 100.00% 
 67.07% 
 69.33% 


 C-  24 
236
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Kentucky 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 B.  2.34.1.2.1 
 Design 
 (Specials)/>=  10 


 circuits/  Dispatch/ 


 KY(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  2.34.1.2.2 
 Design 
 (Specials)/>=  10 


 circuits/  Non- 
 Dispatch/  KY(%) 


 100.00% 
 90.91% 
 3 


 B.  2.34.2.1.1 
 Loo  ps 
 Non-  Design/< 


 10 
 circuits/  Dispatch/ 


 KY(%) 


 98.18% 
 95.65% 
 96.00% 
 96.33% 


 B.  2.34.2.1.2 
 Loops 
 Non-  Design/< 


 10 
 circuits/  Non- 


 Dispatch/  KY(%) 


 99.09% 
 98.18% 
 100.00% 


 98.02% 


 B.  2.34.2.2.1 
 Loo  ps 
 Non-  Design/>= 


 10 
 circuits/  Dispatch/ 


 KY(%) 


 97.75% 
 89.81% 
 97.90% 
 97.73% 


 B.  2.34.2.2.2 
 Loops 
 Non-  Design/>= 


 10 
 circuits/  Non- 


 Dis 
 patch/  KY(%) 


 97.20% 
 97.98% 
 98.73% 
 97.53% 


 UNBUNDLED 
 NETWORK 
 ELEMENTS 


 - 
 MAINTENANCE 


 AND 
 REPAIR 


 Missed 
 Repair 
 Appointments 


 [M&  R- 
 1] 


 B.  3.1.2.1 
 Local 
 Interoffice 


 Trans  port/ 
 Dispatch/  KY(%) 


 0.75% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1.33% 
 0.00% 


 B.  3.1.2.2 
 Local 
 Interoffice 


 Trans  port/ 
 Non-  Dispatch/ 


 KY(%) 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 B.  3.1.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  Dispatch/ 


 KY(%) 
 8.95% 
 5.11% 
 8.37% 
 4.62% 
 15.85% 
 12.14% 
 14.68% 
 10.96% 


 B.  3.1.3.2 
 Loo  p 
 + 
 Port 


 Combinations/  Non- 


 Dispatch/  KY(%) 


 1.49% 
 1.52% 
 1.30% 
 0.00% 
 2.41% 
 1.97% 
 2.31% 
 1.19% 


 B.  3.1.4.1 
 Combo 
 Other/  Dis 


 patch/  KY(%) 


 8.79% 
 0.00% 
 8.22% 
 0.00% 
 15.56% 


 0.00% 
 14.34% 


 0.00% 
 1,2 


 B.  3.1.4.2 
 Combo 
 Other/  Non- 


 Dis  patch/ 
 KY(%) 


 8.79% 
 0.00% 
 8.22% 
 0.00% 
 15.56% 


 0.00% 
 14.34% 


 0.00% 
 1,2,3,4 


 B.  3.1.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Dispatch/ 


 KY(%) 
 50.00% 
 0.00% 
 40.21% 


 0.00% 
 51.40% 


 0.00% 
 52.22% 


 0.00% 
 1,2,3,4 


 B.  3.1.5.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Non- 


 Dispatch/  KY(%) 


 3.90% 
 0.00% 
 3.93% 
 0.00% 
 3.39% 
 0.00% 
 2.17% 
 0.00% 
 2,3,4 


 B.  3.1.6.1 
 UNE 
 ISDN/  Dis 


 patch/  KY(%) 


 0.00% 
 0.00% 
 3.85% 
 16.67% 


 0.00% 
 0.00% 
 3.03% 
 0.00% 
 2,3,4 


 B.  3.1.6.2 
 UNE 
 ISDN/  Non- 


 Dis 
 patch/  KY(%) 


 2.08% 
 0.00% 
 2.44% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3,4 


 B.  3.1.7.1 
 Line 
 Sharin  g/ 


 Dispatch/  KY(%) 


 50.00% 
 0.00% 
 40.21% 


 0.00% 
 51.40% 


 0.00% 
 52.22% 


 0.00% 
 1,3,4 


 B.  3.1.7.2 
 Line 
 Sharin  g/ 


 Non-  Dispatch/ 


 KY(%) 


 3.90% 
 25.00% 


 3.93% 
 0.00% 
 3.39% 
 0.00% 
 2.17% 
 0.00% 
 1,2,3,4 


 B.  3.1.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  Dispatch/ 


 KY(%) 


 8.95% 
 0.00% 
 8.37% 
 0.00% 
 15.85% 


 0.00% 
 14.68% 


 0.00% 


 2 


 B.  3.1.8.2 
 2W 
 Analo  g 


 Loop 
 Design/  Non- 


 Dispatch/  KY(%) 


 8.95% 
 0.00% 
 8.37% 
 0.00% 
 15.85% 


 0.00% 
 14.68% 


 0.00% 
 1,3 


 B.  3.1.9.1 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 Dispatch/  KY(%) 


 8.86% 
 0.00% 
 8.36% 
 0.00% 
 15.72% 


 0.00% 
 14.59% 


 0.00% 


 B.  3.1.9.2 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 Non-  Dispatch/ 


 KY(%) 
 1.51% 
 0.00% 
 1.18% 
 0.00% 
 2.42% 
 0.00% 
 2.18% 
 0.00% 


 B.  3.1.10.1 
 Other 
 Desi  gn/ 
 Dispatch/  KY(%) 


 2.51% 
 0.00% 
 1.69% 
 0.00% 
 1.72% 
 0.00% 
 2.75% 
 0.00% 


 B.  3.1.10.2 
 Other 
 Desi  gn/ 


 Non-  Dispatch/ 


 KY(%) 


 0.60% 
 0.00% 
 1.16% 
 0.00% 
 0.58% 
 0.00% 
 0.53% 
 0.00% 


 B.  3.1.11.1 
 Other 
 Non-  Desi 


 gn/  Dispatch/ 


 KY(%) 


 8.95% 
 0.00% 
 8.37% 
 0.00% 
 15.85% 


 0.00% 
 14.68% 


 0.00% 


 2 


 B.  3.1.11.2 
 Other 
 Non-  Desi 


 gn/  Non- 
 Dispatch/  KY(%) 


 1.49% 
 0.00% 
 1.30% 
 0.00% 
 2.41% 
 0.00% 
 2.31% 
 0.00% 


 1 


 Customer 
 Trouble 
 Report 
 Rate 
 [M&  R- 


 2] 


 C-  25 
237
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Kentucky 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 B.  3.2.2.1 
 Local 
 Interoffice 


 Transport/  Dispatch/ 


 KY(%) 
 1.57% 
 0.00% 
 1.88% 
 0.00% 
 1.72% 
 0.00% 
 1.73% 
 0.00% 


 B.  3.2.2.2 
 Local 
 Interoffice 


 Trans  port/ 
 Non-  Dispatch/ 


 KY(%) 
 1.19% 
 0.00% 
 1.42% 
 0.00% 
 1.16% 
 0.00% 
 1.52% 
 0.00% 


 B.  3.2.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  Dispatch/ 


 KY(%) 
 1.80% 
 1.06% 
 1.98% 
 1.20% 
 2.25% 
 1.55% 
 2.13% 
 1.50% 


 B.  3.2.3.2 
 Loo  p 
 + 
 Port 


 Combinations/  Non- 


 Dispatch/  KY(%) 


 0.81% 
 0.45% 
 0.78% 
 0.40% 
 0.91% 
 0.43% 
 0.90% 
 0.43% 


 B.  3.2.4.1 
 Combo 
 Other/  Dis 


 patch/  KY(%) 


 1.59% 
 1.55% 
 1.74% 
 3.47% 
 1.96% 
 8.72% 
 1.88% 
 6.04% 


 B.  3.2.4.2 
 Combo 
 Other/  Non- 


 Dis  patch/ 
 KY(%) 


 1.59% 
 0.78% 
 1.74% 
 1.39% 
 1.96% 
 2.91% 
 1.88% 
 2.75% 


 B.  3.2.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Dispatch/ 


 KY(%) 
 0.91% 
 0.26% 
 1.18% 
 0.80% 
 1.52% 
 0.54% 
 1.43% 
 0.54% 


 B.  3.2.5.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Non- 


 Dispatch/  KY(%) 


 1.37% 
 0.00% 
 2.20% 
 0.27% 
 2.17% 
 0.27% 
 2.92% 
 0.54% 


 B.  3.2.6.1 
 UNE 
 ISDN/  Dis 


 patch/  KY(%) 


 0.66% 
 1.80% 
 0.67% 
 1.13% 
 0.41% 
 0.94% 
 0.86% 
 1.35% 


 B.  3.2.6.2 
 UNE 
 ISDN/  Non- 


 Dis 
 patch/  KY(%) 


 1.21% 
 0.36% 
 1.05% 
 0.19% 
 1.03% 
 0.19% 
 0.68% 
 0.19% 


 B.  3.2.7.1 
 Line 
 Sharin  g/ 


 Dispatch/  KY(%) 


 0.91% 
 0.23% 
 1.18% 
 0.00% 
 1.52% 
 0.65% 
 1.43% 
 0.63% 


 B.  3.2.7.2 
 Line 
 Sharin  g/ 


 Non-  Dispatch/ 


 KY(%) 


 1.37% 
 0.92% 
 2.20% 
 1.12% 
 2.17% 
 1.74% 
 2.92% 
 1.68% 


 B.  3.2.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  Dispatch/ 


 KY(%) 


 1.80% 
 0.64% 
 1.98% 
 0.35% 
 2.25% 
 0.62% 
 2.13% 
 0.44% 


 B.  3.2.8.2 
 2W 
 Analo  g 


 Loop 
 Design/  Non- 


 Dispatch/  KY(%) 


 1.80% 
 0.23% 
 1.98% 
 0.51% 
 2.25% 
 0.17% 
 2.13% 
 0.83% 


 B.  3.2.9.1 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 Dispatch/  KY(%) 


 1.90% 
 0.00% 
 2.10% 
 0.00% 
 2.38% 
 0.00% 
 2.26% 
 0.00% 


 B.  3.2.9.2 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 Non-  Dispatch/ 


 KY(%) 
 0.77% 
 0.00% 
 0.75% 
 0.00% 
 0.87% 
 0.00% 
 0.88% 
 0.00% 


 B.  3.2.10.1 
 Other 
 Desi  gn/ 
 Dispatch/  KY(%) 


 0.28% 
 0.00% 
 0.29% 
 0.00% 
 0.28% 
 0.00% 
 0.36% 
 0.00% 


 B.  3.2.10.2 
 Other 
 Desi  gn/ 


 Non-  Dispatch/ 


 KY(%) 


 0.36% 
 0.00% 
 0.32% 
 0.00% 
 0.36% 
 0.00% 
 0.40% 
 0.00% 


 B.  3.2.11.1 
 Other 
 Non-  Desi 


 gn/  Dispatch/ 


 KY(%) 


 1.80% 
 0.00% 
 1.98% 
 1.80% 
 2.25% 
 0.00% 
 2.13% 
 0.00% 


 B.  3.2.11.2 
 Other 
 Non-  Desi 


 gn/  Non- 
 Dispatch/  KY(%) 


 0.81% 
 0.86% 
 0.78% 
 0.00% 
 0.91% 
 0.00% 
 0.90% 
 0.00% 


 Maintenance 
 Average 
 Duration 


 [M&  R- 
 3] 


 B.  3.3.2.1 
 Local 
 Interoffice 


 Trans  port/ 
 Dispatch/  KY( 


 hours) 


 4.48 
 0.00 
 4.27 
 0.00 
 4.69 
 0.00 
 4.76 
 0.00 


 B.  3.3.2.2 
 Local 
 Interoffice 


 Transport/  Non- 


 Dispatch/  KY( 
 hours) 
 1.66 
 0.00 
 1.42 
 0.00 
 1.72 
 0.00 
 2.21 
 0.00 


 B.  3.3.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  Dispatch/ 


 KY( 
 hours) 


 21.36 
 11.82 
 20.79 
 10.76 
 30.19 
 15.29 
 30.68 
 17.16 


 B.  3.3.3.2 
 Loop 
 + 
 Port 


 Combinations/  Non- 


 Dispatch/  KY( 
 hours) 
 8.30 
 5.03 
 6.75 
 3.49 
 11.01 


 4.15 
 11.92 


 4.97 


 B.  3.3.4.1 
 Combo 
 Other/  Dis 


 patch/  KY( 


 hours) 


 20.96 
 1.39 
 20.42 


 3.56 
 29.69 


 4.37 
 29.97 


 5.70 
 1,2 


 B.  3.3.4.2 
 Combo 
 Other/  Non- 


 Dis  patch/ 
 KY( 
 hours) 


 20.96 
 0.60 
 20.42 


 1.83 
 29.69 


 0.78 
 29.97 


 1.19 
 1,2,3,4 


 B.  3.3.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Dispatch/ 


 KY(  hours) 
 44.37 
 2.40 
 36.69 


 4.71 
 46.14 


 4.33 
 44.50 


 3.68 
 1,2,3,4 


 C-  26 
238
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Kentucky 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 B.  3.3.5.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Non- 


 Dis 
 patch/  KY( 


 hours) 


 2.82 
 0.00 
 3.85 
 9.22 
 3.14 
 0.28 
 2.05 
 1.88 
 2,3,4 


 B.  3.3.6.1 
 UNE 
 ISDN/  Dis 


 patch/  KY( 
 hours) 


 5.19 
 3.61 
 5.61 
 8.16 
 5.87 
 5.68 
 6.65 
 4.52 
 2,3,4 


 B.  3.3.6.2 
 UNE 
 ISDN/  Non- 


 Dis 
 patch/  KY( 


 hours) 


 2.33 
 2.55 
 3.11 
 1.12 
 2.03 
 7.38 
 1.84 
 1.90 
 1,2,3,4 


 B.  3.3.7.1 
 Line 
 Sharin  g/ 


 Dispatch/  KY( 


 hours) 


 44.37 
 1.57 
 36.69 


 0.00 
 46.14 


 41.67 
 44.50 
 49.33 
 1,3,4 


 B.  3.3.7.2 
 Line 
 Sharin  g/ 


 Non-  Dispatch/ 


 KY( 
 hours) 


 2.82 
 25.95 


 3.85 
 2.20 
 3.14 
 11.50 


 2.05 
 11.38 
 1,2,3,4 


 B.  3.3.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  Dispatch/ 


 KY( 
 hours) 


 21.36 
 2.96 
 20.79 


 4.03 
 30.19 


 5.65 
 30.68 


 5.45 
 2 


 B.  3.3.8.2 
 2W 
 Analog 


 Loop 
 Design/  Non- 


 Dispatch/  KY( 


 hours) 
 21.36 
 0.84 
 20.79 


 2.06 
 30.19 


 2.65 
 30.68 


 3.61 
 1,3 


 B.  3.3.9.1 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 Dispatch/  KY( 


 hours) 
 21.44 
 0.00 
 20.83 


 0.00 
 30.36 


 0.00 
 30.80 


 0.00 


 B.  3.3.9.2 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 Non- 


 Dis 
 patch/  KY( 


 hours) 


 8.91 
 0.00 
 7.10 
 0.00 
 11.75 


 0.00 
 12.66 


 0.00 


 B.  3.3.10.1 
 Other 
 Desi  gn/ 
 Dispatch/  KY( 


 hours) 


 5.25 
 0.00 
 4.75 
 0.00 
 5.71 
 0.00 
 5.31 
 0.00 


 B.  3.3.10.2 
 Other 
 Desi  gn/ 


 Non-  Dispatch/ 


 KY( 
 hours) 


 2.47 
 0.00 
 2.60 
 0.00 
 2.43 
 0.00 
 2.88 
 0.00 


 B.  3.3.11.1 
 Other 
 Non-  Desi 


 gn/  Dispatch/ 


 KY( 
 hours) 


 21.36 
 0.00 
 20.79 


 2.50 
 30.19 


 0.00 
 30.68 


 0.00 
 2 


 B.  3.3.11.2 
 Other 
 Non-  Desi 


 gn/  Non- 
 Dispatch/  KY( 


 hours) 


 8.30 
 1.32 
 6.75 
 0.00 
 11.01 


 0.00 
 11.92 


 0.00 
 1 


 % 
 Repeat 


 Troubles 


 within 
 30 
 Days 


 [M&  R- 


 4] 


 B.  3.4.2.1 
 Local 
 Interoffice 


 Trans  port/ 
 Dispatch/  KY(%) 


 18.05% 
 0.00% 
 19.38% 


 0.00% 
 23.65% 


 0.00% 
 25.33% 


 0.00% 


 B.  3.4.2.2 
 Local 
 Interoffice 


 Trans  port/ 
 Non-  Dispatch/ 


 KY(%) 
 12.87% 
 0.00% 
 22.31% 


 0.00% 
 19.00% 


 0.00% 
 18.18% 


 0.00% 


 B.  3.4.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  Dispatch/ 


 KY(%) 
 16.74% 
 12.14% 
 18.29% 
 10.26% 
 19.50% 
 13.59% 
 19.58% 
 17.29% 


 B.  3.4.3.2 
 Loo  p 
 + 
 Port 


 Combinations/  Non- 


 Dispatch/  KY(%) 


 14.63% 
 13.64% 
 15.30% 
 11.54% 
 16.47% 
 13.16% 
 14.99% 
 17.26% 


 B.  3.4.4.1 
 Combo 
 Other/  Dis 


 patch/  KY(%) 


 16.71% 
 0.00% 
 18.34% 
 20.00% 
 19.45% 
 40.00% 
 19.71% 
 45.45% 


 1,2 


 B.  3.4.4.2 
 Combo 
 Other/  Non- 


 Dis  patch/ 
 KY(%) 


 16.71% 
 0.00% 
 18.34% 


 0.00% 
 19.45% 
 40.00% 
 19.71% 
 0.00% 
 1,2,3,4 


 B.  3.4.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Dispatch/ 


 KY(%) 
 17.96% 
 0.00% 
 22.73% 


 0.00% 
 24.43% 


 0.00% 
 27.42% 


 0.00% 
 1,2,3,4 


 B.  3.4.5.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Non- 


 Dispatch/  KY(%) 


 19.48% 
 0.00% 
 26.59% 


 0.00% 
 26.20% 


 0.00% 
 30.14% 


 0.00% 
 2,3,4 


 B.  3.4.6.1 
 UNE 
 ISDN/  Dis 


 patch/  KY(%) 


 11.54% 
 10.00% 
 15.38% 
 16.67% 
 12.50% 
 0.00% 
 18.18% 
 14.29% 
 2,3,4 


 B.  3.4.6.2 
 UNE 
 ISDN/  Non- 


 Dis 
 patch/  KY(%) 


 8.33% 
 0.00% 
 21.95% 


 0.00% 
 22.50% 


 0.00% 
 11.54% 


 0.00% 
 1,2,3,4 


 B.  3.4.7.1 
 Line 
 Sharin  g/ 


 Dispatch/  KY(%) 


 17.96% 
 0.00% 
 22.73% 


 0.00% 
 24.43% 
 66.67% 
 27.42% 
 66.67% 
 1,3,4 


 B.  3.4.7.2 
 Line 
 Sharin  g/ 


 Non-  Dispatch/ 


 KY(%) 


 19.48% 
 0.00% 
 26.59% 
 40.00% 
 26.20% 
 50.00% 
 30.14% 
 25.00% 
 1,2,3,4 


 B.  3.4.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  Dispatch/ 


 KY(%) 


 16.74% 
 11.76% 
 18.29% 
 22.22% 
 19.50% 
 0.00% 
 19.58% 
 10.00% 


 2 


 B.  3.4.8.2 
 2W 
 Analo  g 


 Loop 
 Design/  Non- 


 Dispatch/  KY(%) 


 16.74% 
 0.00% 
 18.29% 
 15.38% 
 19.50% 
 25.00% 
 19.58% 
 0.00% 
 1,3 


 B.  3.4.9.1 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 Dispatch/  KY(%) 


 16.76% 
 0.00% 
 18.34% 


 0.00% 
 19.58% 


 0.00% 
 19.64% 


 0.00% 


 C-  27 
239
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Kentucky 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 B.  3.4.9.2 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 Non-  Dispatch/ 


 KY(%) 
 14.90% 
 0.00% 
 15.57% 


 0.00% 
 16.97% 


 0.00% 
 15.26% 


 0.00% 


 B.  3.4.10.1 
 Other 
 Desi  gn/ 
 Dispatch/  KY(%) 


 15.64% 
 0.00% 
 20.22% 


 0.00% 
 17.05% 


 0.00% 
 24.20% 


 0.00% 


 B.  3.4.10.2 
 Other 
 Desi 
 gn/  Non- 


 Dispatch/  KY(%) 


 12.07% 
 0.00% 
 17.02% 


 0.00% 
 15.87% 


 0.00% 
 17.37% 


 0.00% 


 B.  3.4.11.1 
 Other 
 Non-  Desi 


 gn/  Dispatch/ 


 KY(%) 


 16.74% 
 0.00% 
 18.29% 


 0.00% 
 19.50% 


 0.00% 
 19.58% 


 0.00% 


 2 


 B.  3.4.11.2 
 Other 
 Non-  Desi 


 gn/  Non- 
 Dispatch/  KY(%) 


 14.63% 
 0.00% 
 15.30% 


 0.00% 
 16.47% 


 0.00% 
 14.99% 


 0.00% 


 1 


 Out 
 of 
 Service 


 > 
 24 


 hours 


 [M&  R- 


 5] 


 B.  3.5.2.1 
 Local 
 Interoffice 


 Trans  port/ 
 Dispatch/  KY(%) 


 0.75% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1.33% 
 0.00% 


 B.  3.5.2.2 
 Local 
 Interoffice 


 Trans  port/ 
 Non-  Dispatch/ 


 KY(%) 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 B.  3.5.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  Dispatch/ 


 KY(%) 
 12.83% 
 5.94% 
 13.20% 


 4.65% 
 24.76% 
 13.12% 
 15.94% 
 8.40% 


 B.  3.5.3.2 
 Loo  p 
 + 
 Port 


 Combinations/  Non- 


 Dispatch/  KY(%) 


 5.59% 
 0.00% 
 4.62% 
 0.00% 
 9.43% 
 1.49% 
 6.86% 
 2.25% 


 B.  3.5.4.1 
 Combo 
 Other/  Dis 


 patch/  KY(%) 


 12.42% 
 0.00% 
 12.78% 


 0.00% 
 24.05% 


 0.00% 
 15.38% 


 0.00% 
 1,2 


 B.  3.5.4.2 
 Combo 
 Other/  Non- 


 Dis  patch/ 
 KY(%) 


 12.42% 
 0.00% 
 12.78% 


 0.00% 
 24.05% 


 0.00% 
 15.38% 


 0.00% 
 1,2,3,4 


 B.  3.5.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Dispatch/ 


 KY(%) 
 50.00% 
 0.00% 
 40.21% 


 0.00% 
 51.40% 


 0.00% 
 52.22% 


 0.00% 
 1,2,3,4 


 B.  3.5.5.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Non- 


 Dispatch/  KY(%) 


 3.90% 
 0.00% 
 3.93% 
 0.00% 
 3.39% 
 0.00% 
 2.17% 
 0.00% 
 2,3,4 


 B.  3.5.6.1 
 UNE 
 ISDN/  Dis 


 patch/  KY(%) 


 0.00% 
 0.00% 
 0.00% 
 16.67% 


 0.00% 
 0.00% 
 3.03% 
 0.00% 
 2,3,4 


 B.  3.5.6.2 
 UNE 
 ISDN/  Non- 


 Dis 
 patch/  KY(%) 


 2.08% 
 0.00% 
 2.44% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3,4 


 B.  3.5.7.1 
 Line 
 Sharin  g/ 


 Dispatch/  KY(%) 


 50.00% 
 0.00% 
 40.21% 


 0.00% 
 51.40% 


 0.00% 
 52.22% 


 0.00% 


 B.  3.5.7.2 
 Line 
 Sharin  g/ 


 Non-  Dispatch/ 


 KY(%) 


 3.90% 
 0.00% 
 3.93% 
 0.00% 
 3.39% 
 0.00% 
 2.17% 
 0.00% 


 4 


 B.  3.5.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  Dispatch/ 


 KY(%) 


 12.83% 
 0.00% 
 13.20% 


 0.00% 
 24.76% 


 0.00% 
 15.94% 


 0.00% 


 2 


 B.  3.5.8.2 
 2W 
 Analo  g 


 Loop 
 Design/  Non- 


 Dispatch/  KY(%) 


 12.83% 
 0.00% 
 13.20% 


 0.00% 
 24.76% 


 0.00% 
 15.94% 


 0.00% 
 1,3 


 B.  3.5.9.1 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 Dispatch/  KY(%) 


 12.89% 
 0.00% 
 13.24% 


 0.00% 
 24.88% 


 0.00% 
 15.95% 


 0.00% 


 B.  3.5.9.2 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 Non-  Dispatch/ 


 KY(%) 
 5.59% 
 0.00% 
 4.72% 
 0.00% 
 9.54% 
 0.00% 
 6.76% 
 0.00% 


 B.  3.5.10.1 
 Other 
 Desi 
 gn/  Dispatch/ 


 KY(%) 


 2.51% 
 0.00% 
 1.69% 
 0.00% 
 1.72% 
 0.00% 
 2.75% 
 0.00% 


 B.  3.5.10.2 
 Other 
 Desi  gn/ 


 Non-  Dispatch/ 


 KY(%) 


 0.60% 
 0.00% 
 1.16% 
 0.00% 
 0.58% 
 0.00% 
 0.53% 
 0.00% 


 B.  3.5.11.1 
 Other 
 Non-  Desi 


 gn/  Dispatch/ 


 KY(%) 


 12.83% 
 0.00% 
 13.20% 


 0.00% 
 24.76% 


 0.00% 
 15.94% 


 0.00% 


 2 


 B.  3.5.11.2 
 Other 
 Non-  Desi 


 gn/  Non- 
 Dispatch/  KY(%) 


 5.59% 
 0.00% 
 4.62% 
 0.00% 
 9.43% 
 0.00% 
 6.86% 
 0.00% 


 1 


 UNBUNDLED 
 NETWORK 
 ELEMENTS 


 - 
 BILLING 


 Invoice 
 Accuracy 


 [B-  1] 


 B.  4.1 
 KY 
 (%) 


 99.18% 
 99.97% 
 98.68% 
 99.96% 
 98.67% 
 99.65% 
 98.38% 
 99.95% 


 Mean 
 Time 
 to 
 Deliver 


 Invoices 


 - 
 CRIS 


 [B-  2] 


 C-  28 
240
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Kentucky 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 B.  4.2 
 Region( 
 business 


 days) 


 3.68 
 7.29 
 3.86 
 4.97 
 3.47 
 3.78 
 3.82 
 3.46 


 LOCAL 
 INTERCONNECTION 


 TRUNKS 
 - 
 ORDERING 


 % 
 Rejected 


 Service 
 Requests 


 [O-  7] 


 C.  1.1 
 Local 
 Interconnection 


 Trunks/  KY 
 (%) 


 69.57% 
 50.00% 
 75.86% 
 74.29% 


 Reject 
 Interval 


 [O-  8] 


 C.  1.2 
 Local 
 Interconnection 


 Trunks/  KY 
 (%) 


 100.00% 
 91.30% 
 100.00% 
 100.00% 


 FOC 
 Timeliness 


 [O-  9] 


 C.  1.3 
 Local 
 Interconnection 


 Trunks/  KY 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 [O-  11] 


 C.  1.4 
 Local 
 Interconnection 


 Trunks/  KY 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 LOCAL 
 INTERCONNECTION 


 TRUNKS 
 - 
 PROVISIONING 


 Order 
 Completion 


 Interval 
 [P-  4] 


 C.  2.1 
 Local 
 Interconnection 


 Trunks/  KY 
 (days) 


 17.82 
 19.00 
 20.64 
 13.89 
 20.56 
 20.83 
 25.53 
 16.77 
 1,2 


 Held 
 Orders 


 [P-  1] 


 C.  2.2 
 Local 
 Interconnection 


 Trunks/  KY 
 (days) 


 0.00 
 0.00 
 0.00 
 0.00 
 0.00 
 0.00 
 0.00 
 0.00 


 % 
 Jeopardies 


 [P-  2] 


 C.  2.3 
 Local 
 Interconnection 


 Trunks/  KY 
 (%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 1,2 


 % 
 Missed 


 Installation 


 Appointments 


 [P-  3] 


 C.  2.5 
 Local 
 Interconnection 


 Trunks/  KY 
 (%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 1 


 % 
 Provisioning 


 Troubles 
 within 
 30 
 Days 


 [P-  9] 


 C.  2.6 
 Local 
 Interconnection 


 Trunks/  KY 
 (%) 


 0.00% 
 0.27% 
 0.59% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 Average 
 Completion 


 Notice 
 Interval 


 [P-  5] 


 C.  2.7 
 Local 
 Interconnection 


 Trunks/  KY 
 (hours) 


 141.24 
 0.07 
 183.44 


 10.97 
 348.48 


 11.78 
 283.57 


 16.49 


 1 


 Total 
 Service 


 Order 
 Cycle 
 Time 
 [P-  10] 


 C.  2.8 
 Local 
 Interconnection 


 Trunks/  KY 
 (days) 


 14.83 
 15.67 
 22.16 
 17.34 
 1,2,3 


 % 
 Completions 


 w/  o 
 Notice 


 or 
 < 
 24 


 hours 


 [P-  6] 


 0.00% 


 C.  2.10.1 
 Local 
 Interconnection 


 Trunks/  Dis 
 patch/  KY(%) 


 0.00% 
 0.00% 
 0.00% 


 1,2 


 C.  2.10.2 
 Local 
 Interconnection 


 Trunks/  Non- 
 Dispatch/  KY(%) 


 100.00% 


 Service 
 Order 
 Accuracy 


 [P-  11] 


 100.00% 


 C.  2.11.1.1 
 Local 
 Interconnection 


 Trunks/<  10 


 circuits/  Dis 
 patch/  KY(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 4 


 C-  29 
241
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Kentucky 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 C.  2.11.1.2 
 Local 
 Interconnection 


 Trunks/<  10 
 circuits/  Non- 


 Dis 
 patch/  KY(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 C.  2.11.2.1 
 Local 
 Interconnection 


 Trunks/>=  10 


 circuits/  Dis 
 patch/  KY(%) 


 100.00% 
 100.00% 
 100.00% 


 1,2 


 C.  2.11.2.2 
 Local 
 Interconnection 


 Trunks/>=  10 
 circuits/  Non- 


 Dis 
 patch/  KY(%) 


 100.00% 
 100.00% 
 100.00% 


 2 


 LOCAL 
 INTERCONNECTION 


 TRUNKS 
 - 
 MAINTENANCE 


 AND 
 REPAIR 


 Missed 
 Repair 
 Appointments 


 [M&  R- 
 1] 


 C.  3.1.1 
 Local 
 Interconnection 


 Trunks/  Dis 
 patch/  KY(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 C.  3.1.2 
 Local 
 Interconnection 


 Trunks/  Non- 
 Dispatch/  KY(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 4 


 Customer 
 Trouble 
 Report 
 Rate 
 [M&  R- 


 2] 


 C.  3.2.1 
 Local 
 Interconnection 


 Trunks/  Dis 
 patch/  KY(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 C.  3.2.2 
 Local 
 Interconnection 


 Trunks/  Non- 
 Dispatch/  KY(%) 


 0.12% 
 0.00% 
 0.06% 
 0.00% 
 0.03% 
 0.00% 
 0.05% 
 0.01% 


 Maintenance 
 Average 
 Duration 


 [M&  R- 
 3] 


 C.  3.3.1 
 Local 
 Interconnection 


 Trunks/  Dis 
 patch/  KY( 
 hours) 


 0.00 
 0.00 
 0.18 
 0.00 
 0.00 
 0.00 
 0.00 
 0.00 


 C.  3.3.2 
 Local 
 Interconnection 


 Trunks/  Non- 


 Dis 
 patch/  KY( 


 hours) 


 0.13 
 0.00 
 0.11 
 0.00 
 0.10 
 0.00 
 0.08 
 3.35 


 4 


 % 
 Repeat 


 Troubles 


 within 
 30 
 Days 


 [M&  R- 


 4] 


 C.  3.4.1 
 Local 
 Interconnection 


 Trunks/  Dis 
 patch/  KY(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 C.  3.4.2 
 Local 
 Interconnection 


 Trunks/  Non- 
 Dispatch/  KY(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 4 


 Out 
 of 
 Service 


 > 
 24 


 hours 


 [M&  R- 


 5] 


 C.  3.5.1 
 Local 
 Interconnection 


 Trunks/  Dis 
 patch/  KY(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 C.  3.5.2 
 Local 
 Interconnection 


 Trunks/  Non- 
 Dispatch/  KY(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 4 


 LOCAL 
 INTERCONNECTION 


 TRUNKS 
 - 
 BILLING 


 Invoice 
 Accuracy 


 [B-  1] 


 C.  4.1 
 KY 
 (%) 


 99.18% 
 99.74% 
 98.68% 
 98.86% 
 98.67% 
 97.71% 
 98.38% 
 99.74% 


 Mean 
 Time 
 to 
 Deliver 


 Invoices 


 - 
 CABS 


 [B-  2] 


 C.  4.2 
 Re  gion( 
 calendar 


 days) 


 4.84 
 4.54 
 3.94 
 3.89 
 4.96 
 4.92 
 4.54 
 4.29 


 LOCAL 
 INTERCONNECTION 


 TRUNKS 
 - 
 TRUNK 


 BLOCKING 


 C-  30 
242
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Kentucky 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 Trunk 
 Group 
 Performance 


 - 
 Aggregate 


 [TGP-  1] 


 C.  5.1 
 KY 


 0 
 0 
 0 
 0 


 OPERATIONS 
 SUPPORT 
 SYSTEMS 
 - 
 PRE-  ORDERING 


 % 
 Interface 


 Availability 


 - 
 CLEC 


 [OSS-  2] 


 D.  1.1.1 
 EDI/  Re 
 gion(%) 


 99.71% 
 100.00% 


 99.64% 
 100.00% 


 D.  1.1.2 
 HAL/  Re 
 gion(%) 


 100.00% 
 100.00% 


 D.  1.1.3 
 LENS/  Re 
 gion(%) 


 99.99% 
 99.98% 
 99.85% 
 99.76% 


 D.  1.1.4 
 LEO 
 MAINFRAME/  Re 


 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 D.  1.1.6 
 LESOG/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 D.  1.1.7 
 TAG/  Re 
 gion(%) 


 100.00% 
 99.95% 
 99.99% 
 99.86% 


 D.  1.1.8 
 PSIMS/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 % 
 Interface 


 Availability 


 - 
 BST 


 & 
 CLEC 


 [OSS-  2] 


 D.  1.2.1 
 ATLAS/  COFFI/ 


 Re 
 gion(%) 


 100.00% 
 100.00% 


 D.  1.2.2 
 BOCRIS/  Re 
 gion(%) 


 100.00% 
 100.00% 
 99.96% 
 99.99% 


 D.  1.2.3 
 DSAP/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.98% 


 D.  1.2.4 
 RSAG/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.99% 


 D.  1.2.5 
 SOCS/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.99% 


 D.  1.2.6 
 SONGS/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.86% 


 D.  1.2.7 
 DOE/  Re 
 gion(%) 


 99.99% 
 99.99% 
 99.99% 
 99.26% 


 D.  1.2.8 
 LNP 
 Gatewa 


 y/  Region(%) 


 100.00% 
 99.99% 
 100.00% 


 99.49% 


 D.  1.2.9 
 COG/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.48% 


 D.  1.2.10 
 DOM/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.99% 


 D.  1.2.11 
 SOG/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 D.  1.2.1- 
 new 
 ATLAS/  Re 


 gion 
 (%) 


 100.00% 
 99.99% 


 D.  1.2.2- 
 new 
 COFFI/  Re 


 gion 
 (%) 


 100.00% 
 99.99% 


 Average 
 Response 


 Interval 
 - 
 CLEC 


 (LENS) 


 (BST 
 Measure 


 Includes 
 Additional 


 2 
 Seconds) 


 [OSS-  1] 


 D.  1.3.1.1 
 RSAG, 
 b 
 y 


 TN/  Region( 


 seconds) 


 1440.12 
 0.91 
 1782.46 


 1.11 
 2.87 
 1.20 
 2.88 
 1.02 


 D.  1.3.1.2 
 RSAG, 
 b 
 y 


 TN/  Region( 


 seconds) 


 2.96 
 0.91 
 2.95 
 1.11 
 2.94 
 1.20 
 2.91 
 1.02 


 D.  1.3.2.1 
 RSAG, 
 b 
 y 
 ADDR/  Region( 


 seconds) 


 712.69 
 0.91 
 1204.18 


 1.02 
 2.99 
 1.10 
 3.03 
 0.93 


 D.  1.3.2.2 
 RSAG, 
 b 
 y 
 ADDR/  Region( 


 seconds) 


 4.82 
 0.91 
 4.86 
 1.02 
 4.77 
 1.10 
 4.76 
 0.93 


 D.  1.3.3.1 
 ATLAS/  Re 
 gion( 
 seconds) 


 1330.23 
 0.88 
 2.95 
 0.88 
 2.95 
 0.88 
 3.01 
 0.80 


 D.  1.3.3.2 
 ATLAS/  Re 
 gion( 
 seconds) 


 2.61 
 0.88 
 2.61 
 0.88 
 2.60 
 0.88 
 2.61 
 0.80 


 D.  1.3.4.1 
 DSAP/  Re 
 gion( 
 seconds) 


 2.68 
 0.53 
 2.70 
 0.57 
 2.71 
 0.53 
 2.71 
 0.52 


 C-  31 
243
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Kentucky 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 D.  1.3.4.2 
 DSAP/  Region( 


 seconds) 


 2.58 
 0.53 
 2.58 
 0.57 
 2.57 
 0.53 
 2.57 
 0.52 


 D.  1.3.5.1 
 CRSECSRL/  Re 


 gion( 
 seconds) 


 3.20 
 1.08 
 212.02 


 1.25 
 3.21 
 2.12 
 3.24 
 1.14 


 D.  1.3.5.2 
 CRSECSRL/  Re 


 gion( 
 seconds) 


 2.95 
 1.08 
 2.91 
 1.25 
 2.87 
 2.12 
 2.95 
 1.14 


 D.  1.3.6.1 
 COFFI/  Re 
 gion( 
 seconds) 


 4.46 
 0.63 
 4.40 
 0.67 
 4.60 
 0.63 
 4.35 
 0.64 


 D.  1.3.6.2 
 COFFI/  Re 
 gion( 
 seconds) 


 3.81 
 0.63 
 3.92 
 0.67 
 7.28 
 0.63 
 3.73 
 0.64 


 D.  1.3.7.1 
 PSIMS/  ORB/ 
 Re 
 gion( 


 seconds) 


 4.46 
 0.03 
 4.40 
 0.04 
 4.60 
 0.04 
 4.35 
 0.04 


 D.  1.3.7.2 
 PSIMS/  ORB/ 
 Re 
 gion( 


 seconds) 


 3.81 
 0.03 
 3.92 
 0.04 
 7.28 
 0.04 
 3.73 
 0.04 


 Average 
 Response 


 Interval 
 - 
 CLEC 


 (TAG) 
 (BST 
 Measure 


 Includes 
 Additional 


 2 
 Seconds) 


 [OSS-  1] 


 D.  1.4.1.1 
 RSAG, 
 b 
 y 


 TN/  Region( 


 seconds) 


 1440.12 
 1.10 
 1782.46 


 1.31 
 2.87 
 1.60 
 2.88 
 1.52 


 D.  1.4.1.2 
 RSAG, 
 b 
 y 


 TN/  Region( 


 seconds) 


 2.96 
 1.10 
 2.95 
 1.31 
 2.94 
 1.60 
 2.91 
 1.52 


 D.  1.4.2.1 
 RSAG, 
 b 
 y 
 ADDR/  Region( 


 seconds) 


 712.69 
 1.62 
 1204.18 


 1.85 
 2.99 
 3.05 
 3.03 
 2.34 


 D.  1.4.2.2 
 RSAG, 
 b 
 y 
 ADDR/  Region( 


 seconds) 


 4.82 
 1.62 
 4.86 
 1.85 
 4.77 
 3.05 
 4.76 
 2.34 


 D.  1.4.4.1 
 ATLAS 
 - 
 DID/  Re 


 gion( 
 seconds) 


 1.48 
 2.18 
 1.76 
 1.37 


 D.  1.4.4.2 
 ATLAS 
 - 
 DID/  Re 


 gion( 
 seconds) 


 1.48 
 2.18 
 1.76 
 1.37 


 D.  1.4.5.1 
 ATLAS 
 - 
 TN/  Re 


 gion( 
 seconds) 


 1330.23 
 1.35 
 2.95 
 1.56 
 2.95 
 1.86 
 3.01 
 1.89 


 D.  1.4.5.2 
 ATLAS 
 - 
 TN/  Re 


 gion( 
 seconds) 


 2.61 
 1.35 
 2.61 
 1.56 
 2.60 
 1.86 
 2.61 
 1.89 


 D.  1.4.6.1 
 DSAP/  Re 
 gion( 
 seconds) 


 2.68 
 1.58 
 2.70 
 1.71 
 2.71 
 1.74 
 2.71 
 1.83 


 D.  1.4.6.2 
 DSAP/  Re 
 gion( 
 seconds) 


 2.58 
 1.58 
 2.58 
 1.71 
 2.57 
 1.74 
 2.57 
 1.83 


 D.  1.4.7.1 
 TAG/  Re 
 gion( 
 seconds) 


 3.20 
 1.75 
 212.02 


 2.15 
 3.21 
 2.51 
 3.24 
 2.85 


 D.  1.4.7.2 
 TAG/  Re 
 gion( 
 seconds) 


 2.95 
 1.75 
 2.91 
 2.15 
 2.87 
 2.51 
 2.95 
 2.85 


 OPERATIONS 
 SUPPORT 
 SYSTEMS 
 - 
 MAINTENANCE 


 AND 
 REPAIR 


 % 
 Interface 


 Availability 


 - 
 CLEC 


 [OSS-  3] 


 D.  2.2.1 
 CLEC 
 TAFI/  Re 


 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 D.  2.2.2 
 ECTA/  Re 
 gion(%) 


 100.00% 
 99.95% 
 100.00% 


 99.86% 


 % 
 Interface 


 Availability 


 - 
 BST 


 & 
 CLEC 


 [OSS-  3] 


 D.  2.3.1 
 CRIS/  Re 
 gion(%) 


 100.00% 
 100.00% 
 99.96% 
 99.99% 


 D.  2.3.2 
 LMOS 
 HOST/  Re 


 gion(%) 


 100.00% 
 100.00% 
 99.91% 
 100.00% 


 D.  2.3.3 
 LNP/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.91% 


 D.  2.3.4 
 MARCH/  Re 
 gion(%) 


 100.00% 
 99.99% 
 100.00% 
 100.00% 


 D.  2.3.5 
 OSPCM/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 D.  2.3.6 
 Predictor/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.92% 


 D.  2.3.7 
 SOCS/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.99% 


 Average 
 Response 


 Interval 
 <= 
 4 
 Seconds 


 [OSS-  4] 


 C-  32 
244
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Kentucky 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 D.  2.4.1 
 CRIS/  Region(%) 


 94.91% 
 94.17% 
 94.75% 
 94.83% 
 95.12% 
 94.99% 
 94.95% 
 94.66% 


 D.  2.4.2 
 DLETH/  Re 
 gion(%) 


 3.07% 
 3.22% 
 3.14% 
 4.03% 
 3.16% 
 4.59% 
 2.58% 
 3.67% 


 D.  2.4.3 
 DLR/  Re 
 gion(%) 


 4.30% 
 2.41% 
 4.07% 
 2.41% 
 4.03% 
 3.36% 
 4.47% 
 7.51% 


 D.  2.4.4 
 LMOS/  Re 
 gion(%) 


 99.67% 
 99.69% 
 99.63% 
 99.59% 
 99.60% 
 99.60% 
 99.61% 
 99.58% 


 D.  2.4.5 
 LMOSu 
 pd/  Region(%) 


 78.95% 
 70.39% 
 76.71% 
 65.38% 
 78.49% 
 66.19% 
 79.21% 
 66.24% 


 D.  2.4.6 
 LNP/  Re 
 gion(%) 


 99.78% 
 99.37% 
 99.31% 
 99.09% 
 99.68% 
 99.19% 
 99.65% 
 98.81% 


 D.  2.4.7 
 MARCH/  Re 
 gion(%) 


 28.35% 
 33.16% 
 28.32% 
 26.44% 
 28.04% 
 31.69% 
 28.10% 
 29.64% 


 D.  2.4.8 
 OSPCM/  Re 
 gion(%) 


 23.94% 
 13.59% 
 27.25% 
 20.73% 
 31.23% 
 24.50% 
 33.15% 
 21.43% 


 D.  2.4.9 
 Predictor/  Re 
 gion(%) 


 15.78% 
 19.48% 
 15.03% 
 20.43% 
 13.82% 
 19.61% 
 12.71% 
 21.73% 


 D.  2.4.10 
 SOCS/  Re 
 gion(%) 


 99.84% 
 99.91% 
 99.83% 
 99.90% 
 99.85% 
 99.88% 
 99.81% 
 99.86% 


 D.  2.4.11 
 NIW/  Region(%) 


 82.97% 
 81.81% 
 84.38% 
 83.15% 
 84.01% 
 83.00% 
 82.83% 
 81.89% 


 Average 
 Response 


 Interval 
 <= 
 10 
 Seconds 


 [OSS-  4] 


 D.  2.5.1 
 CRIS/  Re 
 gion(%) 


 98.99% 
 99.34% 
 98.97% 
 99.34% 
 99.05% 
 99.46% 
 99.02% 
 99.39% 


 D.  2.5.2 
 DLETH/  Re 
 gion(%) 


 78.81% 
 86.16% 
 78.96% 
 87.92% 
 79.20% 
 85.30% 
 77.66% 
 82.58% 


 D.  2.5.3 
 DLR/  Re 
 gion(%) 


 77.94% 
 92.02% 
 77.45% 
 91.98% 
 76.65% 
 88.18% 
 71.08% 
 41.67% 


 D.  2.5.4 
 LMOS/  Re 
 gion(%) 


 99.81% 
 99.86% 
 99.79% 
 99.82% 
 99.79% 
 99.84% 
 99.80% 
 99.85% 


 D.  2.5.5 
 LMOSu 
 pd/  Region(%) 


 90.95% 
 83.33% 
 89.31% 
 80.59% 
 90.04% 
 80.25% 
 90.59% 
 80.53% 


 D.  2.5.6 
 LNP/  Re 
 gion(%) 


 99.93% 
 99.87% 
 99.54% 
 99.72% 
 99.81% 
 99.63% 
 99.83% 
 99.52% 


 D.  2.5.7 
 MARCH/  Re 
 gion(%) 


 28.35% 
 33.16% 
 28.32% 
 26.44% 
 28.04% 
 31.69% 
 28.10% 
 29.64% 


 D.  2.5.8 
 OSPCM/  Re 
 gion(%) 


 96.89% 
 96.12% 
 97.38% 
 95.12% 
 97.81% 
 97.35% 
 98.41% 
 95.83% 


 D.  2.5.9 
 Predictor/  Re 
 gion(%) 


 15.78% 
 19.48% 
 15.03% 
 20.43% 
 13.82% 
 19.61% 
 12.71% 
 21.73% 


 D.  2.5.10 
 SOCS/  Re 
 gion(%) 


 99.99% 
 99.99% 
 99.99% 
 99.98% 
 99.98% 
 100.00% 


 99.98% 
 100.00% 


 D.  2.5.11 
 NIW/  Region(%) 


 99.17% 
 98.96% 
 99.49% 
 99.33% 
 99.39% 
 99.21% 
 99.42% 
 99.25% 


 Average 
 Response 


 Interval 
 > 
 10 


 Seconds 


 [OSS-  4] 


 D.  2.6.1 
 CRIS/  Re 
 gion(%) 


 1.01% 
 0.66% 
 1.03% 
 0.66% 
 0.95% 
 0.54% 
 0.98% 
 0.61% 


 D.  2.6.2 
 DLETH/  Re 
 gion(%) 


 21.19% 
 13.84% 
 21.04% 
 12.08% 
 20.80% 
 14.70% 
 22.34% 
 17.42% 


 D.  2.6.3 
 DLR/  Re 
 gion(%) 


 22.06% 
 7.98% 
 22.55% 


 8.02% 
 23.35% 
 11.82% 
 28.92% 
 58.33% 


 D.  2.6.4 
 LMOS/  Re 
 gion(%) 


 0.19% 
 0.14% 
 0.21% 
 0.18% 
 0.21% 
 0.16% 
 0.20% 
 0.15% 


 D.  2.6.5 
 LMOSu 
 pd/  Region(%) 


 9.05% 
 16.67% 
 10.69% 
 19.41% 
 9.96% 
 19.75% 


 9.41% 
 19.47% 


 D.  2.6.6 
 LNP/  Re 
 gion(%) 


 0.07% 
 0.13% 
 0.46% 
 0.28% 
 0.19% 
 0.37% 
 0.17% 
 0.48% 


 D.  2.6.7 
 MARCH/  Re 
 gion(%) 


 71.65% 
 66.84% 
 71.68% 
 73.56% 
 71.96% 
 68.31% 
 71.90% 
 70.36% 


 D.  2.6.8 
 OSPCM/  Re 
 gion(%) 


 3.11% 
 3.88% 
 2.62% 
 4.88% 
 2.19% 
 2.65% 
 1.59% 
 4.17% 


 D.  2.6.9 
 Predictor/  Re 
 gion(%) 


 84.22% 
 80.52% 
 84.97% 
 79.57% 
 86.18% 
 80.39% 
 87.29% 
 78.27% 


 D.  2.6.10 
 SOCS/  Re 
 gion(%) 


 0.01% 
 0.01% 
 0.01% 
 0.02% 
 0.02% 
 0.00% 
 0.02% 
 0.00% 


 C-  33 
245
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Kentucky 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 D.  2.6.11 
 NIW/  Region(%) 


 0.83% 
 1.04% 
 0.51% 
 0.67% 
 0.61% 
 0.79% 
 0.58% 
 0.75% 


 COLLOCATION 
 - 
 COLLOCATION  Average  Response  Time  [C- 


 1] 


 E.  1.1.2 
 Ph 
 ysical 


 Caged/  KY( 


 calendar 
 days) 


 2 
 8 
 3,4 


 E.  1.1.3 
 Ph  ysical 
 Cageless/  KY( 


 calendar 
 days) 


 9 


 14 
 1,3 


 Average 
 Arrangement 


 Time 
 [C-  2] 


 E.  1.2.3 
 Ph  ysical 
 Caged/  KY( 


 calendar 
 days) 


 61 


 33 
 1,4 


 E.  1.2.4 
 Ph  ysical 
 Cageless/  KY( 


 calendar 
 days) 


 58 
 4 


 % 
 Due 


 Dates 


 Missed 


 [C-  3] 


 E.  1.3.2 
 Ph 
 ysical/  KY(%) 


 0.00% 
 0.00% 
 1,4 


 GENERAL 
 - 
 FLOW 


 THROUGH  %  Flow  Through  Service 


 Requests 
 [O-  3] 


 F.  1.1.1 
 Summar  y/ 
 Region(%) 


 85.28% 
 86.05% 
 84.50% 
 85.96% 


 F.  1.1.2 
 A 
 ggregate/  Region(%) 


 85.28% 
 86.05% 
 84.50% 
 85.96% 


 F.  1.1.3 
 Residence/  Re 
 gion(%) 


 86.49% 
 87.39% 
 86.74% 
 88.58% 


 F.  1.1.4 
 Business/  Re 
 gion(%) 


 73.55% 
 71.89% 
 69.54% 
 73.74% 


 F.  1.1.5 
 UNE/  Re 
 gion(%) 


 83.88% 
 84.78% 
 82.57% 
 83.84% 


 % 
 Flow 


 Through 


 Service 
 Requests 


 - 
 Achieved 


 [O-  3] 


 F.  1.2.1 
 Summar  y/ 
 Region(%) 


 75.79% 
 77.51% 
 76.58% 
 78.96% 


 F.  1.2.2 
 A 
 ggregate/  Region(%) 


 75.79% 
 77.51% 
 76.58% 
 78.96% 


 F.  1.2.3 
 Residence/  Re 
 gion(%) 


 79.16% 
 80.53% 
 79.88% 
 81.68% 


 F.  1.2.4 
 Business/  Re 
 gion(%) 


 50.63% 
 51.15% 
 51.58% 
 53.42% 


 F.  1.2.5 
 UNE/  Re 
 gion(%) 


 72.17% 
 74.87% 
 74.12% 
 77.27% 


 % 
 Flow 


 Through 


 Service 
 Requests 


 - 
 LNP 


 [O-  3] 


 F.  1.3.1 
 Summar  y/ 
 Region(%) 


 92.25% 
 92.59% 
 89.75% 
 83.63% 


 F.  1.3.2 
 A 
 ggregate/  Region(%) 


 92.25% 
 92.59% 
 89.75% 
 83.63% 


 GENERAL 
 - 
 PRE-  ORDERING  Loop  Makeup 


 Inquiry 
 (Manual) 


 [PO-  1] 


 F.  2.1 
 Loo 
 ps/  KY(%) 


 55.56% 
 0.00% 
 50.00% 
 1,3,4 


 Loop 
 Makeup 


 Inquiry 
 (Electronic) 


 [PO-  2] 


 F.  2.2 
 Loo 
 ps/  KY(%) 


 99.08% 
 99.52% 
 100.00% 


 75.88% 


 GENERAL 
 - 
 ORDERING  Average  Speed 


 of 
 Answer 


 [O-  12] 


 C-  34 
246
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Kentucky 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 F.  4.1 
 Region( 
 seconds) 


 141.64 
 30.33 
 137.90 


 28.63 
 194.86 


 35.16 
 259.48 


 58.19 


 GENERAL 
 - 
 MAINTENANCE 


 CENTER 
 Average 
 Answer 
 Time 
 [M&  R- 


 6] 


 F.  5.1 
 Re 
 gion( 


 seconds) 


 43.10 
 26.35 
 41.00 
 23.60 
 64.68 
 25.99 
 52.80 
 28.04 


 GENERAL 
 - 
 OPERATOR 


 SERVICES 
 (TOLL) 


 Average 
 Speed 
 to 
 Answer 


 [OS-  1] 


 F.  6.1 
 KY 
 (seconds) 


 6.08 
 5.86 
 6.00 
 5.53 


 % 
 Answered 


 in 
 10 
 seconds 


 [OS-  2] 


 F.  6.2 
 KY 
 (%) 


 76.40% 
 77.20% 
 76.80% 
 78.80% 


 GENERAL 
 - 
 DIRECTORY 


 ASSISTANCE 
 Average 
 Speed 
 to 
 Answer 


 [DA-  1] 


 F.  7.1 
 KY 
 (seconds) 


 4.26 
 4.80 
 5.06 
 4.54 


 % 
 Answered 


 in 
 12 
 seconds 


 [DA-  2] 


 F.  7.2 
 KY 
 (%) 


 90.90% 
 88.80% 
 87.90% 
 90.10% 


 GENERAL 
 - 
 BILLING  Usage  Data 


 Delivery 
 Accuracy 


 [B-  3] 


 F.  9.1 
 Re 
 gion(%) 


 100.00% 
 100.00% 
 97.75% 
 100.00% 


 95.22% 
 100.00% 
 100.00% 
 100.00% 


 Usage 
 Data 
 Delivery 


 Timeliness 


 [B-  5] 


 F.  9.2 
 Re 
 gion(%) 


 98.37% 
 93.14% 
 75.41% 
 94.80% 
 94.93% 
 97.64% 
 99.33% 
 99.38% 


 Usage 
 Data 
 Delivery 


 Completeness 


 [B-  4] 


 F.  9.3 
 Re 
 gion(%) 


 99.38% 
 99.89% 
 99.77% 
 99.54% 
 97.21% 
 99.95% 
 99.92% 
 99.91% 


 Mean 
 Time 
 to 
 Deliver 


 Usage 
 [B-  6] 


 F.  9.4 
 Re 
 gion( 


 days) 


 3.49 
 3.05 
 6.85 
 3.29 
 4.34 
 2.52 
 3.24 
 2.43 


 Recurring 
 Charge 
 Completeness 


 [B-  7] 


 F.  9.5.1 
 Resale/  KY 
 (%) 


 86.40% 
 98.75% 
 85.43% 
 79.30% 
 87.84% 
 79.72% 
 87.09% 
 99.14% 


 F.  9.5.2 
 UNE/  KY 
 (%) 


 99.53% 
 99.69% 
 98.48% 
 99.76% 


 F.  9.5.3 
 Interconnection/  KY 


 (%) 


 89.30% 
 99.89% 
 99.19% 
 94.48% 


 Non-  Recurring 
 Charge 
 Completeness 


 [B-  8] 


 F.  9.6.1 
 Resale/  KY 
 (%) 


 94.78% 
 96.65% 
 85.02% 
 98.85% 
 87.21% 
 98.11% 
 82.23% 
 98.60% 


 F.  9.6.2 
 UNE/  KY 
 (%) 


 99.06% 
 99.14% 
 98.75% 
 98.65% 


 F.  9.6.3 
 Interconnection/  KY 


 (%) 


 99.06% 
 99.26% 
 98.64% 
 96.71% 


 GENERAL 
 - 
 CHANGE 


 MANAGEMENT  %  Software  Release  Notices  Sent 


 On 
 Time 


 [CM-  1] 


 C-  35 
247
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Kentucky 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 F.  10.1 
 KY(%) 


 100.00% 
 100.00% 


 2,3 


 % 
 Change 


 Management 


 Documentation 


 Sent 
 On 
 Time 


 [CM-  3A] 


 F.  10.3 
 KY 
 (%) 


 100.00% 
 100.00% 
 1,4 


 % 
 Change 


 Management 


 Documentation 


 (Defects, 
 Corrections, 


 etc.) 
 Sent 
 On 
 Time 


 [CM-  3B] 


 F.  10.4 
 KY 
 (%) 


 77.78% 
 2 


 Average 
 Documentation 


 Release 
 Delay 
 Days 
 [CM-  4] 


 F.  10.5 
 KY 
 (average)  %  CLEC  Interface 


 Outages 
 Sent 
 within 


 15 
 Minutes 


 [CM-  5] 


 F.  10.6 
 KY 
 (%) 


 100.00% 
 100.00% 


 100.00% 


 GENERAL 
 - 
 NEW 


 BUSINESS 


 REQUESTS 


 % 
 New 


 Business 


 Requests 
 Processed 


 within 
 30 
 Business 


 Days 
 [BFR-  1] 


 F.  11.1 
 Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 % 
 Quotes 


 Provided 


 within 
 X 
 Business 


 Days 
 [BFR-  2A] 


 F.  11.2.1 
 Re 
 gion(%) 


 100.00% 
 100.00% 
 1,3 


 F.  11.2.3 
 Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 GENERAL 
 - 
 ORDERING  Acknowledgement 


 Message 
 Timeliness 


 [O-  1] 


 F.  12.1.1 
 EDI/  Re 
 gion(%) 


 99.97% 
 99.99% 
 100.00% 
 100.00% 


 F.  12.1.2 
 TAG/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 Acknowledgement 
 Message 
 Completeness 


 [O-  2] 


 F.  12.2.1 
 EDI/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.62% 


 F.  12.2.2 
 TAG/  Re 
 gion(%) 


 100.00% 
 100.00% 
 99.99% 
 100.00% 


 GENERAL 
 - 
 DATABASE 


 UPDATES 
 Average 
 Database 


 Update 
 Interval 


 [D-  1] 


 F.  13.1.1 
 LIDB/  KY 
 (hours) 


 0.30 
 0.30 
 0.36 
 0.36 
 0.28 
 0.28 
 0.28 
 0.28 


 F.  13.1.2 
 Director  y 
 Listings/  KY( 


 hours) 


 0.10 
 0.10 
 0.09 
 0.09 
 0.10 
 0.10 
 0.11 
 0.11 


 F.  13.1.3 
 Director  y 
 Assistance/  KY( 


 hours) 


 4.30 
 4.30 
 4.62 
 4.62 
 4.35 
 4.35 
 6.30 
 6.30 


 % 
 Update 


 Accuracy 


 [D-  2] 


 F.  13.2.1 
 LIDB/  KY 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 93.48% 


 F.  13.2.2 
 Director  y 
 Listings/  KY(%) 


 99.38% 
 99.03% 
 99.79% 
 99.35% 


 F.  13.2.3 
 Director  y 
 Assistance/  KY(%) 


 100.00% 
 100.00% 
 97.87% 
 99.19% 


 % 
 NXXs 


 / 
 LRNs 


 Loaded 


 by 
 LERG 


 Effective 


 Date 
 [D-  3] 


 F.  13.3 
 Re 
 gion(%) 


 96.77% 
 100.00% 
 100.00% 
 98.41% 


 C-  36 
248
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Kentucky 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 GENERAL 
 - 
 NETWORK 


 OUTAGE 
 NOTIFICATION 


 Mean 
 Time 
 to 
 Notify 


 CLEC 
 of 
 Major 


 Network 


 Outages 
 [M&  R- 
 7] 


 F.  14.1 
 Region(  minutes) 


 739 
 218 


 0 
 0 
 154 


 123 
 791 
 602 
 1,3,4 


 Abbreviations:  blank  cell  =  no  data 
 available 
 Notes:  1  =  Sample 
 Size 
 under 


 10 
 in 
 March 


 2 
 = 
 Sample 


 Size 
 under 


 10 
 in 
 April 


 2 
 = 
 Sample 


 Size 
 under 


 10 
 in 
 May 


 4 
 = 
 Sample 


 Size 
 under 


 10 
 in 
 June 


 C-  37 
249
 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Appendix 
 D 


 Mississippi 
 Performance 


 Metrics 


 Except 
 where 
 noted, 
 the 
 data 


 included 


 here 
 is 
 taken 


 from 
 the 
 Mississippi 


 Monthly 
 State 
 Summary 


 (MSS) 
 Reports 


 provided 


 by 


 BellSouth, 
 calculated 
 according 
 to 
 the 


 Georgia 


 Service 
 Quality 
 Measurement 


 (SQM) 
 business 


 rules. 
 This 
 table 


 is 
 provided 


 as 
 a 


 reference 
 tool 
 for 
 the 
 convenience 


 of 
 the 


 reader. 


 No 
 conclusions 


 are 
 to 
 be 
 drawn 


 from 
 the 
 raw 


 data 
 contained 


 in 
 this 


 table. 


 Our 


 analysis 
 is 
 based 


 on 
 the 
 totality 


 of 
 the 
 circumstances, 


 such 
 that 
 we 
 may 


 use 
 non-  metric 


 evidence, 
 and 
 may 


 rely 
 more 


 heavily 


 on 
 some 


 metrics 
 more 
 than 
 others, 


 in 
 making 


 our 
 determination. 


 The 
 inclusion 


 of 
 these 


 particular 


 metrics 
 in 
 this 


 table 


 does 
 not 
 necessarily 


 mean 
 that 
 we 
 relied 


 on 
 all 
 of 
 these 


 metrics, 


 or 
 that 


 other 


 metrics 


 may 
 not 
 also 


 be 
 important 


 in 
 our 


 analysis. 


 Some 
 metrics 


 that 
 we 
 have 


 relied 
 on 
 in 
 the 


 past 


 and 
 may 


 rely 
 on 
 for 


 a 
 future 


 application 


 were 
 not 
 included 


 here 
 because 


 there 
 was 
 no 
 data 


 provided 


 for 
 them 


 (usually 
 either 
 because 


 there 
 was 
 no 
 activity, 


 or 
 because 


 the 
 metrics 


 are 
 still 


 under 


 development). 


 Metrics 
 with 
 no 
 retail 


 analog 


 provided 


 are 
 usually 


 compared 


 with 
 a 
 benchmark. 


 Note 
 that 
 for 
 some 


 metrics 


 during 
 the 
 period 


 provided 
 there 
 may 
 be 
 changes 


 in 
 the 


 metric 


 definition, 


 or 
 changes 


 in 
 the 


 retail 


 analog 


 applied, 


 making 
 it 
 difficult 


 to 
 compare 


 data 


 Note: 
 All 
 data 


 was 
 calculated 


 using 
 BellSouth's 


 data 
 platform 


 PMAP 
 4.0. 
 The 
 March 


 data 
 in 
 this 


 appendix 


 were 
 not 
 taken 


 from 
 the 


 MSS 
 reports, 


 which 
 for 
 that 


 month 


 were 
 calculated 


 using 
 PMAP 


 2.6, 
 but 
 instead 


 were 
 calculated 


 using 
 PMAP 


 4.0 
 by 
 BellSouth. 


 This 


 data 
 also 
 conforms 


 to 
 the 


 Georgia 


 Service 
 Quality 
 Measurement 


 business 
 rules 
 that 
 govern 


 the 
 regular 


 MSS 
 reports. 
250
 Metric  No. 
 SQM 
 No. 
 Metric 


 Name 


 Metric  No. 
 SQM 
 No. 
 Metric 


 Name 


 RESALE 
 A.  3.5 
 M&  R- 
 5 
 Out 


 of 
 Service 


 > 
 24 


 hours 


 Ordering 
 Billing 
 A.  1.1 
 O-  7 


 % 
 Rejected 


 Service 
 Requests 


  
 Mech. 


 A.  4.1 
 B-  1 


 Invoice 
 Accuracy 


 A.  1.2 
 O-  7 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Partially 


 Mech. 


 A.  4.2 
 B-  2 


 Mean 
 Time 
 to 
 Deliver 


 Invoices 


  
 CRIS 


 A.  1.3 
 O-  7 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Non-  Mech. 


 UNBUNDLED 
 NETWORK 
 ELEMENTS 


 A.  1.4 
 O-  8 


 Reject 
 Interval 


  
 Mech. 


 Ordering 


 A.  1.7 
 O-  8 


 Reject 
 Interval 


 - 
 Partially 


 Mech. 
  
 10 


 hours 


 B.  1.1 
 O-  7/ 
 O-  13 


 % 
 Rejected 


 Service 
 Requests 


  
 Mech. 


 A.  1.8 
 O-  8 


 Reject 
 Interval 


 - 
 Non-  Mech. 


 B.  1.2 
 O-  7/ 
 O-  13 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Partially 


 Mech. 


 A.  1.9 
 O-  9 


 FOC 
 Timeliness 


  
 Mech. 


 B.  1.3 
 O-  7/ 
 O-  13 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Non-  Mech. 


 A.  1.12 
 O-  9 


 FOC 
 Timeliness 


 - 
 Partially 


 Mech. 
 - 
 10 


 hours 


 B.  1.4 
 O-  8/ 
 O-  14 


 Reject 


 Interval 


  
 Mech. 


 A.  1.13 
 O-  9 


 FOC 
 Timeliness 


 - 
 Non-  Mech. 


 B.  1.7 
 O-  8/ 
 O-  14 


 Reject 


 Interval 


 - 
 Partially 


 Mech. 
 - 
 10 


 hours 


 A.  1.14 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Mech. 


 B.  1.8 
 O-  8/ 
 O-  14 


 Reject 


 Interval 


 - 
 Non-  Mech. 


 A.  1.15 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Partially 


 Mech. 


 B.  1.9 
 O-  9/ 
 O-  15 


 FOC 
 Timeliness 


  
 Mech. 


 A.  1.16 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Non-  Mech. 


 B.  1.12 
 O-  9/ 
 O-  15 


 FOC 
 Timeliness 


 - 
 Partially 


 Mech. 
 - 
 10 


 hours 


 Provisioning 
 B.  1.13 
 O-  9/ 
 O-  15 


 FOC 
 Timeliness 


 - 
 Non-  Mech. 


 A.  2.1 
 P-  4 


 Order 
 Completion 


 Interval 


 B.  1.14 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


  
 Mech. 


 A.  2.4 
 P-  2 


 % 
 Jeopardies 


 - 
 Mech. 


 B.  1.15 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


  
 Partially 


 Mech. 


 A.  2.5 
 P-  2 


 % 
 Jeopardies 


 - 
 Non-  Mech. 


 B.  1.16 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


  
 Non-  Mech. 


 A.  2.7 
 P-  2 


 Average 
 Jeopardy 
 Notice 
 Interval 


 - 
 Mech. 


 Provisioning 


 A.  2.8 
 P-  2 


 Average 
 Jeopardy 
 Notice 
 Interval 


 - 
 Non-  Mech. 


 B.  2.1 
 P-  4 


 Order 
 Completion 


 Interval 


 A.  2.9 
 P-  2 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Mech. 


 B.  2.2 
 P-  4 


 Order 
 Completion 


 Interval 
 within 
 X 
 days 


 - 
 xDSL 


 A.  2.10 
 P-  2 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Non-  Mech. 


 B.  2.5 
 P-  2 


 % 
 Jeopardies 


  
 Mech. 


 A.  2.11 
 P-  3 


 % 
 Missed 


 Installation 


 Appointments 


 B.  2.6 
 P-  2 


 % 
 Jeopardies 


 - 
 Non-  Mech. 


 A.  2.12 
 P-  9 


 % 
 Provisioning 


 Troubles 
 within 
 30 
 Days 


 B.  2.8 
 P-  2 


 Average 
 Jeopardy 
 Notice 
 Interval 


 - 
 Mech. 


 A.  2.14 
 P-  5 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Mech. 


 B.  2.9 
 P-  2 


 Average 
 Jeopardy 
 Notice 
 Interval 


 - 
 Non-  Mech. 


 A.  2.15 
 P-  5 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Non-  Mech. 


 B.  2.10 
 P-  2 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Mech. 


 A.  2.25 
 P-  11 


 Service 
 Order 
 Accuracy 


 B.  2.11 
 P-  2 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Non-  Mech. 


 Maintenance 
 and 
 Repair 


 B.  2.12 
 P-  7 
 Coordinated 


 Customers 
 Conversions 


 A.  3.1 
 M&  R- 
 1 
 Missed 


 Repair 
 Appointments 


 B.  2.13 
 P-  7A 


 % 
 Hot 


 Cuts 


 > 
 15 


 minutes 


 Early 


 A.  3.2 
 M&  R- 
 2 
 Customer 


 Trouble 
 Report 
 Rate 


 B.  2.14 
 P-  7A 


 Hot 
 Cut 
 Timeliness 


 A.  3.3 
 M&  R- 
 3 
 Maintenance 


 Average 
 Duration 


 B.  2.15 
 P-  7A 


 % 
 Hot 


 Cuts 


 > 
 15 


 minutes 


 Late 


 A.  3.4 
 M&  R- 
 4 
 % 
 Repeat 


 Troubles 


 within 
 30 
 Days 


 B.  2.16 
 P-  7B 


 Average 
 Recovery 


 Time 
  
 CCC 


 PERFORMANCE 
 METRIC 
 CATEGORIES 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 D-  2 
251
 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Metric  No. 
 SQM 
 No. 
 Metric 


 Name 


 Metric  No. 
 SQM 
 No. 
 Metric 


 Name 


 B.  2.17 
 P-  7C 


 % 
 Provisioning 


 Troubles 
 within 
 7 
 Days 


 - 
 Hot 


 Cuts 


 C.  3.3 
 M&  R- 
 3 
 Maintenance 


 Average 
 Duration 


 B.  2.18 
 P-  3/ 
 P-  12 


 % 
 Missed 


 Installation 


 Appointments 


 C.  3.4 
 M&  R- 
 4 
 % 
 Repeat 


 Troubles 


 within 
 30 
 Days 


 B.  2.19 
 P-  9 


 % 
 Provisioning 


 Troubles 
 within 
 30 
 Days 


 C.  3.5 
 M&  R- 
 5 
 Out 


 of 
 Service 


 > 
 24 


 hours 


 B.  2.21 
 P-  5 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Mech. 


 Billing 


 B.  2.22 
 P-  5 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Non-  Mech. 


 C.  4.1 
 B-  1 


 Invoice 
 Accuracy 


 B.  2.34 
 P-  11 


 Service 
 Order 
 Accuracy 


 C.  4.2 
 B-  2 


 Mean 
 Time 
 to 
 Deliver 


 Invoices 


 - 
 CABS 


 Maintenance 
 and 
 Repair 


 Trunk 
 Blocking 


 B.  3.1 
 M&  R- 
 1 
 Missed 


 Repair 
 Appointments 


 C.  5.1 
 TGP-  1 


 Trunk 
 Group 
 Performance 


 - 
 Aggregate 


 B.  3.2 
 M&  R- 
 2 
 Customer 


 Trouble 
 Report 
 Rate 


 OPERATIONS 
 SUPPORT 
 SYSTEMS 


 B.  3.3 
 M&  R- 
 3 
 Maintenance 


 Average 
 Duration 


 Pre-  Ordering 


 B.  3.4 
 M&  R- 
 4 
 % 
 Repeat 


 Troubles 


 within 
 30 
 Days 


 D.  1.1 
 OSS-  2 


 % 
 Interface 


 Availability 


 - 
 CLEC 


 B.  3.5 
 M&  R- 
 5 
 Out 


 of 
 Service 


 > 
 24 


 hours 


 D.  1.2 
 OSS-  2 


 % 
 Interface 


 Availability 


 - 
 BST 


 & 
 CLEC 


 Billing 
 D.  1.3 
 OSS-  1 


 Average 
 Response 


 Interval 
 - 
 CLEC 


 (LENS) 


 B.  4.1 
 B-  1 


 Invoice 
 Accuracy 


 D.  1.4 
 OSS-  1 


 Average 
 Response 


 Interval 
 - 
 CLEC 


 (TAG) 


 B.  4.2 
 B-  2 


 Mean 
 Time 
 to 
 Deliver 


 Invoices 


 - 
 CRIS 


 Maintenance 
 and 
 Repair 


 LOCAL 
 INTERCONNECTION 


 TRUNKS 


 D.  2.1 
 OSS-  3 


 % 
 Interface 


 Availability 


 - 
 BST 


 Ordering 
 D.  2.2 
 OSS-  3 


 % 
 Interface 


 Availability 


 - 
 CLEC 


 C.  1.1 
 O-  7 


 % 
 Rejected 


 Service 
 Requests 


 D.  2.3 
 OSS-  3 


 % 
 Interface 


 Availability 


 - 
 BST 


 & 
 CLEC 


 C.  1.2 
 O-  8 


 Reject 
 Interval 


 D.  2.4 
 OSS-  4 


 Average 
 Response 


 Interval 
 <= 
 4 
 Seconds 


 C.  1.3 
 O-  9 


 FOC 
 Timeliness 


 D.  2.5 
 OSS-  4 


 Average 
 Response 


 Interval 
 <= 
 10 
 Seconds 


 C.  1.4 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 D.  2.6 
 OSS-  4 


 Average 
 Response 


 Interval 
 > 
 10 


 Seconds 


 Provisioning 
 COLLOCATION 
 C.  2.1 
 P-  4 


 Order 
 Completion 


 Interval 


 Collocation 


 C.  2.2 
 P-  1 


 Held 
 Orders 


 E.  1.1 
 C-  1 


 Average 
 Response 


 Time 


 C.  2.3 
 P-  2 


 % 
 Jeopardies 


 E.  1.2 
 C-  2 


 Average 
 Arrangement 


 Time 


 C.  2.5 
 P-  3 


 % 
 Missed 


 Installation 


 Appointments 


 E.  1.3 
 C-  3 


 % 
 Due 


 Dates 


 Missed 


 C.  2.6 
 P-  9 


 % 
 Provisioning 


 Troubles 
 within 
 30 
 Days 


 GENERAL 


 C.  2.7 
 P-  5 


 Average 
 Completion 


 Notice 
 Interval 


 Flow 
 Through 


 C.  2.8 
 P-  10 


 Total 
 Service 


 Order 
 Cycle 
 Time 


 F.  1.1 
 O-  3 


 % 
 Flow 


 Through 


 Service 
 Requests 


 C.  2.10 
 P-  6 


 % 
 Completions 


 w/  o 
 Notice 


 or 
 < 
 24 


 hours 


 F.  1.2 
 O-  3 


 % 
 Flow 


 Through 


 Service 
 Requests 


 - 
 Achieved 


 C.  2.11 
 P-  11 


 Service 
 Order 
 Accuracy 


 F.  1.3 
 O-  3 


 % 
 Flow 


 Through 


 Service 
 Requests 


 - 
 LNP 


 Maintenance 
 and 
 Repair 


 Pre-  Ordering 


 C.  3.1 
 M&  R- 
 1 
 Missed 


 Repair 
 Appointments 


 F.  2.1 
 PO-  1 


 Loop 
 Makeup 


 Inquiry 
 (Manual) 


 C.  3.2 
 M&  R- 
 2 
 Customer 


 Trouble 
 Report 
 Rate 


 F.  2.2 
 PO-  2 


 Loop 
 Makeup 


 Inquiry 
 (Electronic) 


 D-  3 
252
 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Metric  No. 
 SQM 
 No. 
 Metric 


 Name 


 Metric  No. 
 SQM 
 No. 
 Metric 


 Name 


 Ordering 
 Database 
 Updates 


 F.  4.1 
 O-  12 


 Average 
 Speed 
 of 
 Answer 


 F.  13.1 
 D-  1 


 Average 
 Database 
 Update 
 Interval 


 Maintenance 
 Center 


 F.  13.2 
 D-  2 


 % 
 Update 


 Accuracy 


 F.  5.1 
 M&  R- 
 6 
 Average 


 Answer 
 Time 


 F.  13.3 
 D-  3 


 % 
 NXXs 


 / 
 LRNs 


 Loaded 


 by 
 LERG 


 Effective 


 Date 


 Operator 
 Services 
 (Toll) 


 Network 
 Outage 
 Notification 


 F.  6.1 
 OS-  1 


 Average 
 Speed 
 to 
 Answer 


 F.  14.1 
 M&  R- 
 7 
 Mean 


 Time 
 to 
 Notify 


 CLEC 
 of 
 Major 


 Network 


 Outages 


 F.  6.2 
 OS-  2 


 % 
 Answered 


 in 
 10 
 seconds 


 Directory 
 Assistance  F.  7.1  DA-  1  Average 


 Speed 
 to 
 Answer 


 F.  7.2 
 DA-  2 


 % 
 Answered 


 in 
 10 
 seconds 


 Billing  F.  9.1 
 B-  3 


 Usage 
 Data 
 Delivery 


 Accuracy 


 F.  9.2 
 B-  5 


 Usage 
 Data 
 Delivery 


 Timeliness 


 F.  9.3 
 B-  4 


 Usage 
 Data 
 Delivery 


 Completeness 


 F.  9.4 
 B-  6 


 Mean 
 Time 
 to 
 Deliver 


 Usage 


 F.  9.5 
 B-  7 


 Recurring 
 Charge 
 Completeness 


 F.  9.6 
 B-  8 


 Non-  Recurring 


 Charge 
 Completeness 


 Change 
 Management  F.  10.1  CM-  1  % 


 Software 
 Release 
 Notices 
 Sent 
 On 
 Time 


 F.  10.2 
 CM-  2 


 Average 
 Software 
 Release 
 Notice 
 Delay 
 Days 


 F.  10.3 
 CM-  3A 


 % 
 Change 


 Management 


 Documentation 


 Sent 
 On 
 Time 


 F.  10.4 
 CM-  3B 


 % 
 Change 


 Management 


 Documentation 


 (Defects, 


 Corrections, 
 etc.  ) 
 Sent 
 On 
 Time 


 F.  10.5 
 CM-  4 


 Average 
 Documentation 


 Release 
 Delay 
 Days 


 F.  10.6 
 CM-  5 


 % 
 CLEC 


 Interface 


 Outages 
 Sent 
 within 


 15 
 Minutes 


 New 
 Business 


 Requests 


 F.  11.1 
 BFR-  1 


 % 
 New 


 Business 


 Requests 
 Processed 


 in 
 30 


 Bus. 


 Days 


 F.  11.2 
 BFR-  2A 


 % 
 Quotes 


 Provided 


 within 
 X 
 Business 


 Days 


 Ordering  F.  12.1 
 O-  1 
 Acknowledgement 


 Message 
 Timeliness 


 F.  12.2 
 O-  2 
 Acknowledgement 


 Message 
 Completeness 


 D-  4 
253
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 RESALE 
 - 
 ORDERING  %  Rejected 


 Service 
 Requests 


 - 
 Mechanized 


 [O-  7] 


 A.  1.1.1 
 Residence/  MS 
 (%) 


 8.43% 
 8.90% 
 7.35% 
 8.77% 


 A.  1.1.2 
 Business/  MS 
 (%) 


 20.15% 
 22.94% 
 25.32% 
 25.98% 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Partially 


 Mechanized 


 [O-  7] 


 A.  1.2.1 
 Residence/  MS 
 (%) 


 21.76% 
 18.55% 
 30.08% 
 33.01% 


 A.  1.2.2 
 Business/  MS 
 (%) 


 26.80% 
 37.93% 
 36.59% 
 30.00% 


 A.  1.2.4 
 PBX/  MS 
 (%) 


 0.00% 
 33.33% 


 0.00% 
 66.67% 
 1,2,3,4 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Non-  Mechanized 


 [O-  7] 


 A.  1.3.1 
 Residence/  MS 
 (%) 


 40.00% 
 42.25% 
 57.61% 
 53.49% 


 A.  1.3.2 
 Business/  MS 
 (%) 


 40.00% 
 36.44% 
 57.28% 
 50.62% 


 A.  1.3.3 
 Desi 
 gn 
 (Specials)/  MS(%) 


 35.71% 
 11.85% 
 10.74% 
 38.41% 


 A.  1.3.4 
 PBX/  MS 
 (%) 


 63.64% 
 35.71% 
 25.00% 
 40.00% 
 3 


 A.  1.3.5 
 Centrex/  MS 
 (%) 


 47.06% 
 34.04% 


 A.  1.3.6 
 ISDN/  MS 
 (%) 


 50.00% 
 40.00% 
 33.33% 
 33.33% 
 1,4 


 Reject 
 Interval 


 - 
 Mechanized 


 [O-  8] 


 A.  1.4.1 
 Residence/  MS 
 (%) 


 89.96% 
 96.98% 
 95.58% 
 97.68% 


 A.  1.4.2 
 Business/  MS 
 (%) 


 96.30% 
 92.45% 
 98.31% 
 96.97% 


 Reject 
 Interval 


 - 
 Partially 


 Mechanized 


 - 
 10 


 hours 


 [O-  8] 


 A.  1.7.1 
 Residence/  MS 
 (%) 


 94.08% 
 91.89% 
 94.07% 
 96.63% 


 A.  1.7.2 
 Business/  MS 
 (%) 


 91.04% 
 97.73% 
 97.40% 
 98.33% 


 A.  1.7.4 
 PBX/  MS 
 (%) 


 0.00% 
 75.00% 
 2,4 


 Reject 
 Interval 


 - 
 Non-  Mechanized 


 [O-  8] 


 A.  1.8.1 
 Residence/  MS 
 (%) 


 100.00% 
 100.00% 
 98.15% 
 97.92% 


 A.  1.8.2 
 Business/  MS 
 (%) 


 100.00% 
 97.67% 
 100.00% 
 100.00% 


 A.  1.8.3 
 Desi 
 gn 
 (Specials)/  MS(%) 


 100.00% 
 92.00% 
 100.00% 


 98.28% 


 A.  1.8.4 
 PBX/  MS 
 (%) 


 85.71% 
 60.00% 
 100.00% 
 100.00% 
 2,3,4 


 A.  1.8.5 
 Centrex/  MS 
 (%) 


 100.00% 
 94.44% 
 3 


 A.  1.8.6 
 ISDN/  MS 
 (%) 


 100.00% 
 83.33% 
 75.00% 
 100.00% 
 1,2,3,4 


 FOC 
 Timeliness 


 - 
 Mechanized 


 [O-  9] 


 A.  1.9.1 
 Residence/  MS 
 (%) 


 99.60% 
 99.45% 
 99.09% 
 99.69% 


 A.  1.9.2 
 Business/  MS 
 (%) 


 99.52% 
 100.00% 
 100.00% 
 100.00% 


 FOC 
 Timeliness 


 - 
 Partially 


 Mechanized 


 - 
 10 


 hours 


 [O-  9] 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Mississippi 
 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 D-  5 
254
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Mississippi 
 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 A.  1.12.1 
 Residence/  MS(%) 


 92.93% 
 93.14% 
 88.96% 
 90.73% 


 A.  1.12.2 
 Business/  MS 
 (%) 


 93.68% 
 97.92% 
 96.75% 
 96.10% 


 A.  1.12.4 
 PBX/  MS 
 (%) 


 50.00% 
 50.00% 
 50.00% 
 25.00% 
 1,2,3,4 


 FOC 
 Timeliness 


 - 
 Non-  Mechanized 


 [O-  9] 


 A.  1.13.1 
 Residence/  MS 
 (%) 


 100.00% 
 97.67% 
 100.00% 
 100.00% 


 A.  1.13.2 
 Business/  MS 
 (%) 


 100.00% 
 98.08% 
 100.00% 


 96.97% 


 A.  1.13.3 
 Desi 
 gn 
 (Specials)/  MS(%) 


 100.00% 
 99.39% 
 97.66% 
 97.47% 


 A.  1.13.4 
 PBX/  MS 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 A.  1.13.5 
 Centrex/  MS 
 (%) 


 100.00% 
 100.00% 
 3 


 A.  1.13.6 
 ISDN/  MS 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Mechanized 


 [O-  11] 


 A.  1.14.1.1 
 Residence/  EDI/ 


 MS  (%) 


 99.51% 
 99.36% 
 98.50% 
 100.00% 


 A.  1.14.1.2 
 Residence/  TAG/ 


 MS  (%) 


 99.36% 
 99.46% 
 99.15% 
 99.98% 


 A.  1.14.2.1 
 Business/  EDI/ 
 MS 
 (%) 


 100.00% 
 100.00% 
 82.35% 
 100.00% 


 A.  1.14.2.2 
 Business/  TAG/ 


 MS 
 (%) 


 98.00% 
 91.36% 
 93.52% 
 100.00% 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Partially 


 Mechanized 


 [O-  11] 


 A.  1.15.1.1 
 Residence/  EDI/ 


 MS  (%) 


 100.00% 
 91.43% 
 88.89% 
 100.00% 
 3 


 A.  1.15.1.2 
 Residence/  TAG/ 


 MS  (%) 


 99.84% 
 99.78% 
 99.94% 
 100.00% 


 A.  1.15.2.1 
 Business/  EDI/ 
 MS 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 3 


 A.  1.15.2.2 
 Business/  TAG/ 


 MS 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 A.  1.15.4.2 
 PBX/  TAG/ 
 MS 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Non-  Mechanized 


 [O-  11] 


 A.  1.16.1 
 Residence/  MS 
 (%) 


 95.38% 
 100.00% 


 98.91% 
 98.84% 


 A.  1.16.2 
 Business/  MS 
 (%) 


 97.00% 
 96.61% 
 98.06% 
 91.36% 


 A.  1.16.3 
 Desi 
 gn 
 (Specials)/  MS(%) 


 90.00% 
 89.10% 
 93.96% 
 90.73% 


 A.  1.16.4 
 PBX/  MS 
 (%) 


 95.45% 
 100.00% 
 100.00% 
 100.00% 
 3 


 A.  1.16.5 
 Centrex/  MS 
 (%) 


 88.24% 
 93.62% 


 A.  1.16.6 
 ISDN/  MS 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,4 


 RESALE 
 - 
 PROVISIONING  Order  Completion 


 Interval 
 [P-  4] 


 A.  2.1.1.1.1 
 Residence/<  10 


 circuits/  Dis 
 patch/  MS( 
 days) 


 6.29 
 5.61 
 6.26 
 5.42 
 5.64 
 4.91 
 5.31 
 4.68 


 A.  2.1.1.1.2 
 Residence/<  10 


 circuits/  Non- 
 Dis  patch/ 
 MS( 
 days) 


 0.74 
 0.63 
 0.79 
 0.55 
 0.77 
 0.54 
 0.76 
 0.56 


 A.  2.1.1.2.1 
 Residence/>=  10 


 circuits/  Dis 
 patch/  MS( 
 days) 


 5.80 


 5.38 
 5.00 
 4.58 
 4.00 
 7.45 


 2,3 


 D-  6 
255
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Mississippi 
 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 A.  2.1.2.1.1 
 Business/<  10 
 circuits/  Dispatch/ 


 MS( 
 days) 


 2.59 
 2.68 
 3.10 
 2.65 
 3.67 
 2.64 
 4.54 
 2.81 


 A.  2.1.2.1.2 
 Business/<  10 
 circuits/  Non- 
 Dis  patch/ 
 MS( 
 days) 


 1.12 
 0.68 
 1.35 
 0.77 
 1.32 
 0.95 
 1.08 
 0.64 


 A.  2.1.2.2.1 
 Business/>=  10 


 circuits/  Dis 
 patch/  MS( 
 days) 


 9.33 
 1.00 
 14.48 


 9.00 
 11.00 


 6.21 
 1,2 


 A.  2.1.3.1.1 
 Desi 
 gn 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 MS( 
 days) 


 24.58 
 9.00 
 19.56 


 1.92 
 22.40 


 8.00 
 21.15 


 8.75 
 1,3,4 


 A.  2.1.3.1.2 
 Design 
 (Specials)/<  10 


 circuits/  Non- 


 Dis 
 patch/  MS( 


 days) 


 6.11 
 2.76 
 10.26 


 3.19 
 4.90 
 2.87 
 7.58 
 3.48 
 1,2,3,4 


 A.  2.1.4.1.2 
 PBX/<  10 
 circuits/  Non- 


 Dis  patch/ 
 MS( 
 days) 


 4.96 
 3.54 
 1.66 
 2.00 
 4.50 
 2.63 
 1.83 
 1.48 
 1,2,3,4 


 A.  2.1.4.2.2 
 Desi 
 gn 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 KY( 
 days) 


 0.53 
 2.00 
 1.76 
 0.33 
 1.98 
 6.00 
 3.44 


 1,2,3 


 A.  2.1.5.1.1 
 Centrex/<  10 
 circuits/  Dis 
 patch/  MS( 
 days) 


 4.29 
 3.00 
 5.42 


 5.76 
 4.87 


 1 


 A.  2.1.5.1.2 
 Centrex/<  10 
 circuits/  Non- 
 Dis  patch/ 
 MS( 
 days) 


 1.32 
 0.33 
 1.45 
 2.50 
 1.38 
 2.00 
 1.05 
 2.37 
 1,2,3 


 A.  2.1.5.2.2 
 Centrex/>=  10 
 circuits/  Non- 
 Dis  patch/ 
 MS( 
 days) 


 1.21 


 3.61 
 1.89 
 0.67 


 A.  2.1.6.1.1 
 ISDN/<  10 
 circuits/  Dis 
 patch/  MS( 
 days) 


 19.41 
 22.17 
 22.77 
 12.00 
 13.61 
 12.00 
 3,4 


 A.  2.1.6.1.2 
 ISDN/<  10 
 circuits/  Non- 


 Dis 
 patch/  MS( 


 days) 


 3.93 
 10.00 


 13.16 


 1.67 
 10.26 


 3.86 
 2.40 
 1,2,4 


 A.  2.1.6.2.2 
 ISDN/>=  10 
 circuits/  Non- 


 Dis 
 patch/  MS( 


 days) 


 4.63 


 7.48 
 7.25 
 11.37 
 3.00 
 4 


 % 
 Jeopardies 


 - 
 Mechanized 


 [P-  2] 


 A.  2.4.1 
 Residence/  MS 
 (%) 


 0.68% 
 1.22% 
 0.71% 
 1.11% 
 0.63% 
 0.77% 
 0.55% 
 0.74% 


 A.  2.4.2 
 Business/  MS 
 (%) 


 1.59% 
 1.18% 
 2.26% 
 0.89% 
 2.44% 
 1.19% 
 1.91% 
 0.40% 


 A.  2.4.3 
 Desi 
 gn 
 (Specials)/  MS(%) 


 13.41% 
 20.06% 
 0.00% 
 12.94% 


 13.05% 
 0.00% 


 4 


 A.  2.4.4 
 PBX/  MS 
 (%) 


 3.31% 
 0.00% 
 4.08% 
 0.00% 
 3.33% 
 0.00% 
 2.17% 
 0.00% 
 1,2,3,4 


 A.  2.4.5 
 Centrex/  MS 
 (%) 


 2.66% 
 1.44% 
 0.00% 
 2.02% 


 1.18% 
 0.00% 


 2,4 


 A.  2.4.6 
 ISDN/  MS 
 (%) 


 6.85% 
 8.60% 
 0.00% 
 9.87% 


 3.78% 


 2 


 % 
 Jeopardies 


 - 
 Non-  Mechanized 


 [P-  2] 


 A.  2.5.1 
 Residence/  MS 
 (%) 


 0.00% 
 1.77% 
 0.00% 
 2.61% 


 A.  2.5.2 
 Business/  MS 
 (%) 


 2.13% 
 1.23% 
 0.00% 
 0.00% 


 A.  2.5.3 
 Desi 
 gn 
 (Specials)/  MS(%) 


 20.83% 
 19.23% 
 38.38% 
 33.33% 


 A.  2.5.4 
 PBX/  MS 
 (%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 4 


 A.  2.5.5 
 Centrex/  MS 
 (%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 2,3 


 A.  2.5.6 
 ISDN/  MS 
 (%) 


 0.00% 
 0.00% 
 25.00% 


 0.00% 
 2,3,4 


 Average 
 Jeopardy 


 Notice 
 Interval 


 - 
 Mechanized 


 [P-  2] 


 A.  2.7.1 
 Residence/  MS 
 (hours) 


 170.14 
 151.68 
 134.80 
 138.60 


 A.  2.7.2 
 Business/  MS 
 (hours) 


 103.89 
 156.53 
 162.19 


 1,2,3 


 Average 
 Jeopardy 


 Notice 
 Interval 


 - 
 Non-  Mechanized 


 [P-  2] 


 A.  2.8.1 
 Residence/  MS 
 (hours) 


 93.17 
 132.55 
 2,4 


 D-  7 
256
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Mississippi 
 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 A.  2.8.2 
 Business/  MS( 
 hours) 


 51.63 
 63.95 


 1,2 


 A.  2.8.3 
 Desi 
 gn 
 (Specials)/  MS( 


 hours) 


 427.19 
 409.26 
 765.60 
 683.37 
 1,2 


 A.  2.8.6 
 ISDN/  MS 
 (hours) 


 39.63 
 3 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Mechanized 


 [P-  2] 


 A.  2.9.1 
 Residence/  MS 
 (%) 


 98.81% 
 98.82% 
 100.00% 
 100.00% 


 A.  2.9.2 
 Business/  MS 
 (%) 


 75.00% 
 100.00% 
 100.00% 


 1,2,3 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Non-  Mechanized 


 [P-  2] 


 A.  2.10.1 
 Residence/  MS 
 (%) 


 100.00% 
 33.33% 
 2,4 


 A.  2.10.2 
 Business/  MS 
 (%) 


 100.00% 
 100.00% 


 1,2 


 A.  2.10.3 
 Desi 
 gn 
 (Specials)/  MS(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2 


 A.  2.10.6 
 ISDN/  MS 
 (%) 


 0.00% 
 3 


 % 
 Missed 


 Installation 


 Appointments 


 [P-  3] 


 A.  2.11.1.1.1 
 Residence/<  10 


 circuits/  Dis 
 patch/  MS(%) 


 6.01% 
 2.08% 
 8.53% 
 2.90% 
 8.21% 
 3.85% 
 7.77% 
 3.85% 


 A.  2.11.1.1.2 
 Residence/<  10 


 circuits/  Non- 
 Dis  patch/ 
 MS(%) 


 0.02% 
 0.01% 
 0.10% 
 0.14% 
 0.01% 
 0.16% 
 0.01% 
 0.10% 


 A.  2.11.1.2.1 
 Residence/>=  10 


 circuits/  Dis 
 patch/  MS(%) 


 0.00% 
 12.50% 
 0.00% 
 6.67% 
 0.00% 
 16.67% 


 2,3 


 A.  2.11.2.1.1 
 Business/<  10 
 circuits/  Dis 
 patch/  MS(%) 


 1.98% 
 4.71% 
 2.25% 
 1.89% 
 2.83% 
 5.17% 
 4.89% 
 0.00% 


 A.  2.11.2.1.2 
 Business/<  10 
 circuits/  Non- 
 Dis  patch/ 
 MS(%) 


 0.01% 
 0.00% 
 0.01% 
 0.39% 
 0.04% 
 0.39% 
 0.08% 
 0.00% 


 A.  2.11.2.2.1 
 Business/>=  10 


 circuits/  Dis 
 patch/  MS(%) 


 12.00% 
 0.00% 
 3.23% 
 0.00% 
 7.41% 
 0.00% 
 5.56% 


 1,2,3 


 A.  2.11.3.1.1 
 Desi 
 gn 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 MS(%) 
 2.91% 
 0.00% 
 2.97% 
 0.00% 
 2.02% 
 0.00% 
 2.88% 
 0.00% 


 A.  2.11.3.1.2 
 Design 
 (Specials)/<  10 


 circuits/  Non- 
 Dispatch/  MS(%) 


 1.23% 
 0.00% 
 0.00% 
 0.00% 
 0.32% 
 0.00% 
 1.98% 
 0.00% 


 A.  2.11.4.1.2 
 PBX/<  10 
 circuits/  Non- 


 Dis 
 patch/  MS(%) 


 3.26% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1.82% 
 0.00% 


 A.  2.11.4.2.2 
 PBX/>=  10 
 circuits/  Non- 


 Dis 
 patch/  MS(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 1,2,3 


 A.  2.11.5.1.1 
 Design 
 (Specials)/<  10 


 circuits/  Non- 
 Dispatch/  KY(%) 


 3.10% 
 0.00% 
 3.28% 


 2.44% 
 6.34% 


 1 


 A.  2.11.5.1.2 
 Centrex/<  10 
 circuits/  Non- 
 Dis  patch/ 
 MS(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3 


 A.  2.11.5.2.2 
 Centrex/>=  10 
 circuits/  Non- 
 Dis  patch/ 
 MS(%) 


 0.00% 
 0.00% 
 0.00% 


 0.00% 
 0.00% 


 A.  2.11.6.1.1 
 ISDN/<  10 
 circuits/  Dis 
 patch/  MS(%) 


 1.32% 
 2.80% 
 5.30% 
 0.00% 
 1.10% 
 0.00% 


 3,4 


 A.  2.11.6.1.2 
 ISDN/<  10 
 circuits/  Non- 


 Dis 
 patch/  MS(%) 


 0.56% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 2,3,4 


 A.  2.11.6.2.2 
 ISDN/>=  10 
 circuits/  Non- 


 Dis 
 patch/  MS(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 4 


 % 
 Provisioning 


 Troubles 
 within 
 30 
 Days 


 [P-  9] 


 A.  2.12.1.1.1 
 Residence/<  10 


 circuits/  Dis 
 patch/  MS(%) 


 10.62% 
 6.34% 
 10.91% 


 7.39% 
 10.69% 


 6.56% 
 11.51% 


 7.48% 


 A.  2.12.1.1.2 
 Residence/<  10 


 circuits/  Non- 
 Dis  patch/ 
 MS(%) 


 3.06% 
 4.98% 
 3.28% 
 3.98% 
 2.72% 
 3.12% 
 2.68% 
 2.75% 


 D-  8 
257
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Mississippi 
 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 A.  2.12.1.2.1 
 Residence/>=  10 


 circuits/  Dispatch/ 
 MS(%) 


 0.00% 
 0.00% 
 0.00% 


 8.33% 
 0.00% 
 6.67% 
 0.00% 
 1,3,4 


 A.  2.12.2.1.1 
 Business/<  10 
 circuits/  Dis 
 patch/  MS(%) 


 9.40% 
 11.48% 
 10.14% 
 7.41% 
 9.97% 
 5.66% 
 11.39% 
 12.07% 


 A.  2.12.2.1.2 
 Business/<  10 
 circuits/  Non- 
 Dis  patch/ 
 MS(%) 


 5.13% 
 3.54% 
 4.97% 
 4.49% 
 5.45% 
 3.53% 
 5.69% 
 6.56% 


 A.  2.12.2.2.1 
 Business/>=  10 


 circuits/  Dis 
 patch/  MS(%) 


 11.76% 
 0.00% 
 12.00% 


 0.00% 
 6.45% 
 0.00% 
 14.81% 


 0.00% 
 1,2,3,4 


 A.  2.12.3.1.1 
 Desi 
 gn 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 MS(%) 
 8.04% 
 4.84% 
 6.78% 
 33.33% 


 9.65% 
 6.45% 
 9.57% 
 8.70% 


 A.  2.12.3.1.2 
 Design 
 (Specials)/<  10 


 circuits/  Non- 
 Dispatch/  MS(%) 


 2.60% 
 12.50% 


 3.70% 
 28.57% 


 2.87% 
 0.00% 
 2.60% 
 4.17% 


 2 


 A.  2.12.4.1.2 
 PBX/<  10 
 circuits/  Non- 


 Dis 
 patch/  MS(%) 


 2.78% 
 0.00% 
 3.26% 
 12.50% 


 0.00% 
 8.33% 
 0.00% 
 10.00% 


 1,2 


 A.  2.12.4.2.2 
 PBX/>=  10 
 circuits/  Non- 


 Dis 
 patch/  MS(%) 


 0.00% 
 0.00% 
 8.33% 


 0.00% 
 0.00% 
 5.26% 
 0.00% 
 1,3,4 


 A.  2.12.5.1.2 
 Centrex/<  10 
 circuits/  Non- 
 Dis  patch/ 
 MS(%) 


 1.62% 
 100.00% 


 6.04% 
 33.33% 


 3.62% 
 0.00% 
 4.76% 
 33.33% 
 1,2,3,4 


 A.  2.12.5.2.2 
 Centrex/>=  10 
 circuits/  Non- 
 Dis  patch/ 
 MS(%) 


 13.33% 
 50.00% 
 22.22% 


 24.24% 
 17.07% 


 1 


 A.  2.12.6.1.1 
 Design 
 (Specials)/<  10 


 circuits/  Non- 
 Dispatch/  KY(%) 


 1.90% 
 0.00% 
 4.61% 


 4.20% 
 5.30% 
 33.33% 


 1,4 


 A.  2.12.6.1.2 
 ISDN/<  10 
 circuits/  Non- 


 Dis 
 patch/  MS(%) 


 1.52% 
 8.33% 
 1.12% 
 0.00% 
 0.60% 
 0.00% 
 0.51% 
 0.00% 


 3,4 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Mechanized 


 [P-  5] 


 A.  2.14.1.1.1 
 Residence/<  10 


 circuits/  Dis 
 patch/  MS( 
 hours) 


 1.38 
 0.17 
 1.51 
 0.09 
 1.14 
 0.19 
 1.21 
 0.19 


 A.  2.14.1.1.2 
 Residence/<  10 


 circuits/  Non- 
 Dis  patch/ 
 MS( 
 hours) 


 0.66 
 0.35 
 0.40 
 0.36 
 0.41 
 0.39 
 0.46 
 0.41 


 A.  2.14.1.2.1 
 Residence/>=  10 


 circuits/  Dis 
 patch/  MS( 
 hours) 


 0.02 


 1.29 
 0.02 
 1.01 
 0.02 
 0.02 


 2,3 


 A.  2.14.2.1.1 
 Business/<  10 
 circuits/  Dis 
 patch/  MS( 
 hours) 


 1.62 
 1.42 
 2.38 
 0.02 
 2.39 
 0.89 
 1.93 
 0.29 


 A.  2.14.2.1.2 
 Business/<  10 
 circuits/  Non- 
 Dis  patch/ 
 MS( 
 hours) 


 1.43 
 0.28 
 2.26 
 0.38 
 1.97 
 0.33 
 2.82 
 0.39 


 A.  2.14.2.2.1 
 Business/>=  10 


 circuits/  Dis 
 patch/  MS( 
 hours) 


 1.53 
 0.02 
 3.15 
 0.02 
 6.05 
 0.02 
 0.04 


 1,2,3 


 A.  2.14.3.1.1 
 Design 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 MS(  hours) 
 215.77 


 163.78 
 0.48 
 119.06 


 115.09 


 A.  2.14.3.1.2 
 Design 
 (Specials)/<  10 


 circuits/  Non- 


 Dispatch/  MS( 
 hours) 


 22.95 
 275.05 


 23.65 
 0.02 
 3.75 


 41.22 


 1,2 


 A.  2.14.4.1.2 
 PBX/<  10 
 circuits/  Non- 


 Dis 
 patch/  MS( 


 hours) 


 49.81 
 0.16 
 11.49 


 0.02 
 7.80 
 0.11 
 2.30 
 0.14 
 1,2,3,4 


 A.  2.14.5.1.2 
 Centrex/<  10 
 circuits/  Non- 
 Dis  patch/ 
 MS( 
 hours) 


 0.57 


 1.77 
 0.45 
 1.53 


 0.81 
 0.27 
 2,4 


 A.  2.14.6.1.2 
 ISDN/<  10 
 circuits/  Non- 


 Dis 
 patch/  MS( 


 hours) 


 5.32 
 207.78 
 0.02 
 89.13 


 14.44 


 2 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Non-  Mechanized 


 [P-  5] 


 A.  2.15.1.1.1 
 Residence/<  10 


 circuits/  Dis 
 patch/  MS( 
 hours) 


 18.55 
 11.01 
 20.13 
 18.57 


 A.  2.15.1.1.2 
 Residence/<  10 


 circuits/  Non- 
 Dis  patch/ 
 MS( 
 hours) 


 6.84 
 7.35 
 2.86 
 7.15 


 A.  2.15.2.1.1 
 Business/<  10 
 circuits/  Dis 
 patch/  MS( 
 hours) 


 26.39 
 13.32 
 24.85 
 23.92 
 1 


 A.  2.15.2.1.2 
 Business/<  10 
 circuits/  Non- 
 Dis  patch/ 
 MS( 
 hours) 


 10.87 
 7.94 
 9.51 
 9.17 


 D-  9 
258
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Mississippi 
 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 A.  2.15.3.1.1 
 Design 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 MS(  hours) 


 68.34 
 81.91 
 131.25 
 161.25 


 A.  2.15.3.1.2 
 Design 
 (Specials)/<  10 


 circuits/  Non- 


 Dis 
 patch/  MS( 


 hours) 


 45.19 
 30.75 
 42.55 
 40.06 


 A.  2.15.4.1.2 
 PBX/<  10 
 circuits/  Non- 


 Dis 
 patch/  MS( 


 hours) 


 26.96 
 24.27 
 23.36 


 9.05 
 1,3,4 


 A.  2.15.4.2.2 
 PBX/>=  10 
 circuits/  Non- 


 Dis 
 patch/  MS( 


 hours) 


 38.00 
 0.38 
 4.74 


 1,2,3 


 A.  2.15.5.1.1 
 Centrex/<  10 
 circuits/  Dis 
 patch/  MS( 
 hours) 


 16.75 


 1 


 A.  2.15.5.1.2 
 Centrex/<  10 
 circuits/  Non- 
 Dis  patch/ 
 MS( 
 hours) 


 22.00 
 0.47 
 9.42 
 10.45 
 1,2,3 


 A.  2.15.5.2.2 
 Centrex/>=  10 
 circuits/  Non- 
 Dis  patch/ 
 MS( 
 hours) 


 37.38 


 A.  2.15.6.1.1 
 ISDN/<  10 
 circuits/  Dis 
 patch/  MS( 
 hours) 


 37.17 
 64.92 
 3,4 


 A.  2.15.6.1.2 
 Design 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 KY(  hours) 


 29.26 
 33.62 
 42.82 
 18.50 
 2,3,4 


 A.  2.15.6.2.2 
 ISDN/>=  10 
 circuits/  Non- 


 Dis 
 patch/  MS( 


 hours) 


 14.00 
 4 


 Service 
 Order 
 Accuracy 


 [P-  11] 


 A.  2.25.1.1.1 
 Residence/<  10 


 circuits/  Dis 
 patch/  MS(%) 


 92.14% 
 96.55% 
 90.77% 
 98.86% 


 A.  2.25.1.1.2 
 Residence/<  10 


 circuits/  Non- 
 Dis  patch/ 
 MS(%) 


 95.38% 
 94.29% 
 98.82% 
 98.56% 


 A.  2.25.1.2.1 
 Residence/>=  10 


 circuits/  Dis 
 patch/  MS(%) 


 100.00% 
 88.24% 
 100.00% 
 100.00% 
 4 


 A.  2.25.2.1.1 
 Business/<  10 
 circuits/  Dis 
 patch/  MS(%) 


 91.33% 
 95.76% 
 88.82% 
 94.44% 


 A.  2.25.2.1.2 
 Business/<  10 
 circuits/  Non- 
 Dis  patch/ 
 MS(%) 


 93.85% 
 97.93% 
 96.11% 
 97.22% 


 A.  2.25.2.2.1 
 Business/>=  10 


 circuits/  Dis 
 patch/  MS(%) 


 100.00% 
 77.78% 
 77.78% 
 76.92% 
 2 


 A.  2.25.2.2.2 
 Business/>=  10 


 circuits/  Non- 
 Dis  patch/ 
 MS(%) 


 84.62% 
 97.56% 
 92.59% 
 91.89% 


 A.  2.25.3.1.1 
 Desi 
 gn 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 MS(%) 


 81.08% 
 91.43% 
 80.49% 
 96.47% 


 A.  2.25.3.1.2 
 Design 
 (Specials)/<  10 


 circuits/  Non- 
 Dispatch/  MS(%) 


 91.84% 
 94.78% 
 91.43% 
 91.36% 


 A.  2.25.3.2.1 
 Desi 
 gn 
 (Specials)/>=  10 


 circuits/  Dispatch/ 


 MS(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 A.  2.25.3.2.2 
 Design 
 (Specials)/>=  10 


 circuits/  Non- 
 Dispatch/  MS(%) 


 100.00% 
 90.00% 
 92.31% 
 88.89% 
 1,4 


 RESALE 
 - 
 MAINTENANCE 


 AND 
 REPAIR 


 Missed 
 Repair 
 Appointments 


 [M&  R- 
 1] 


 A.  3.1.1.1 
 Residence/  Dis 
 patch/  MS(%) 


 4.45% 
 0.96% 
 4.51% 
 1.07% 
 5.27% 
 1.29% 
 5.46% 
 2.41% 


 A.  3.1.1.2 
 Residence/  Non- 


 Dis  patch/ 
 MS(%) 


 0.80% 
 0.00% 
 1.00% 
 1.40% 
 0.93% 
 0.64% 
 0.85% 
 0.00% 


 A.  3.1.2.1 
 Business/  Dis 
 patch/  MS(%) 


 4.13% 
 1.67% 
 5.26% 
 4.63% 
 6.46% 
 1.47% 
 5.06% 
 2.78% 


 A.  3.1.2.2 
 Business/  Non- 


 Dis 
 patch/  MS(%) 


 1.38% 
 0.00% 
 1.03% 
 0.00% 
 1.14% 
 0.00% 
 1.58% 
 0.00% 


 D-  10 
259
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Mississippi 
 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 A.  3.1.3.1 
 Design 
 (Specials)/<  10 


 circuits/  Non- 
 Dispatch/  KY(%) 


 0.58% 
 0.00% 
 0.78% 
 0.00% 
 0.18% 
 0.00% 
 1.16% 
 0.00% 


 A.  3.1.3.2 
 Desi 
 gn 
 (Specials)/  Non- 


 Dispatch/  MS(%) 


 0.19% 
 0.00% 
 0.19% 
 0.00% 
 0.00% 
 3.57% 
 0.18% 
 0.00% 


 A.  3.1.4.1 
 PBX/  Dis 
 patch/  MS(%) 


 0.00% 
 0.00% 
 2.56% 
 0.00% 
 3.39% 
 11.11% 


 0.00% 
 0.00% 
 1,3,4 


 A.  3.1.4.2 
 PBX/  Non- 
 Dis 
 patch/  MS(%) 


 10.71% 
 0.00% 
 2.33% 
 0.00% 
 7.69% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3 


 A.  3.1.5.1 
 Centrex/  Dis 
 patch/  MS(%) 


 5.18% 
 0.00% 
 4.15% 
 0.00% 
 7.04% 
 0.00% 
 5.59% 
 0.00% 
 1,2,3,4 


 A.  3.1.5.2 
 Centrex/  Non- 
 Dis 
 patch/  MS(%) 


 0.98% 
 0.00% 
 0.40% 
 0.00% 
 1.00% 
 0.00% 
 1.92% 
 0.00% 


 2,4 


 A.  3.1.6.1 
 ISDN/  Dis 
 patch/  MS(%) 


 0.00% 
 0.00% 
 2.33% 
 0.00% 
 2.78% 
 0.00% 
 2.56% 
 0.00% 
 1,2,3,4 


 A.  3.1.6.2 
 ISDN/  Non- 
 Dis 
 patch/  MS(%) 


 5.56% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1.59% 
 0.00% 
 1,2,3,4 


 Customer 
 Trouble 
 Report 
 Rate 
 [M&  R- 


 2] 


 A.  3.2.1.1 
 Residence/  Dis 
 patch/  MS(%) 


 2.39% 
 2.09% 
 2.63% 
 2.14% 
 2.71% 
 2.35% 
 2.76% 
 2.44% 


 A.  3.2.1.2 
 Residence/  Non- 


 Dis  patch/ 
 MS(%) 


 1.20% 
 0.43% 
 1.21% 
 0.36% 
 1.24% 
 0.47% 
 1.27% 
 0.50% 


 A.  3.2.2.1 
 Business/  Dis 
 patch/  MS(%) 


 1.25% 
 1.27% 
 1.38% 
 1.15% 
 1.45% 
 1.47% 
 1.38% 
 1.21% 


 A.  3.2.2.2 
 Business/  Non- 


 Dis 
 patch/  MS(%) 


 0.65% 
 0.35% 
 0.75% 
 0.30% 
 0.71% 
 0.38% 
 0.66% 
 0.33% 


 A.  3.2.3.1 
 Desi 
 gn 
 (Specials)/  Dispatch/ 


 MS(%) 


 1.45% 
 2.70% 
 1.47% 
 2.87% 
 1.64% 
 3.53% 
 1.75% 
 3.42% 


 A.  3.2.3.2 
 Desi 
 gn 
 (Specials)/  Non- 


 Dispatch/  MS(%) 


 1.51% 
 1.40% 
 1.51% 
 1.21% 
 1.68% 
 1.32% 
 1.60% 
 1.66% 


 A.  3.2.4.1 
 PBX/  Dis 
 patch/  MS(%) 


 0.12% 
 0.48% 
 0.09% 
 1.56% 
 0.14% 
 1.37% 
 0.08% 
 0.31% 


 A.  3.2.4.2 
 PBX/  Non- 
 Dis 
 patch/  MS(%) 


 0.13% 
 0.63% 
 0.10% 
 0.78% 
 0.10% 
 0.31% 
 0.06% 
 0.00% 


 A.  3.2.5.1 
 Centrex/  Dis 
 patch/  MS(%) 


 0.51% 
 0.12% 
 0.54% 
 0.24% 
 0.47% 
 0.50% 
 0.45% 
 1.07% 


 A.  3.2.5.2 
 Centrex/  Non- 
 Dis 
 patch/  MS(%) 


 0.28% 
 0.00% 
 0.35% 
 0.49% 
 0.42% 
 0.00% 
 0.36% 
 0.84% 


 A.  3.2.6.1 
 ISDN/  Dis 
 patch/  MS(%) 


 0.03% 
 0.05% 
 0.05% 
 0.13% 
 0.04% 
 0.18% 
 0.04% 
 0.04% 


 A.  3.2.6.2 
 ISDN/  Non- 
 Dis 
 patch/  MS(%) 


 0.06% 
 0.14% 
 0.09% 
 0.04% 
 0.05% 
 0.04% 
 0.07% 
 0.18% 


 Maintenance 
 Average 
 Duration 


 [M&  R- 
 3] 


 A.  3.3.1.1 
 Residence/  Dis 
 patch/  MS( 
 hours) 


 21.00 
 16.16 
 21.95 
 18.39 
 23.97 
 19.90 
 25.53 
 22.86 


 A.  3.3.1.2 
 Residence/  Non- 


 Dis  patch/ 
 MS( 
 hours) 


 8.26 
 3.52 
 9.23 
 5.09 
 10.44 


 4.38 
 11.03 


 8.04 


 A.  3.3.2.1 
 Business/  Dis 
 patch/  MS( 
 hours) 


 8.76 
 7.89 
 8.99 
 9.88 
 10.68 


 9.52 
 9.71 
 9.46 


 A.  3.3.2.2 
 Business/  Non- 


 Dis 
 patch/  MS( 


 hours) 


 3.78 
 3.04 
 3.26 
 3.21 
 3.20 
 1.20 
 3.59 
 3.28 


 A.  3.3.3.1 
 Desi 
 gn 
 (Specials)/  Dispatch/ 


 MS( 
 hours) 


 4.77 
 4.49 
 5.05 
 4.94 
 5.17 
 4.77 
 5.45 
 4.48 


 A.  3.3.3.2 
 Desi 
 gn 
 (Specials)/  Non- 


 Dispatch/  MS( 
 hours) 


 2.37 
 2.17 
 1.97 
 2.54 
 1.95 
 4.42 
 2.10 
 2.08 


 A.  3.3.4.1 
 PBX/  Dis 
 patch/  MS( 


 hours) 


 6.53 
 13.52 


 6.60 
 5.12 
 6.03 
 11.69 


 7.11 
 11.91 
 1,3,4 


 A.  3.3.4.2 
 PBX/  Non- 
 Dis 
 patch/  MS( 


 hours) 


 13.16 
 0.00 
 6.59 
 3.62 
 6.00 
 1.93 
 3.45 
 0.00 
 1,2,3 


 A.  3.3.5.1 
 Centrex/  Dis 
 patch/  MS( 
 hours) 


 10.35 
 21.10 


 9.72 
 12.50 


 8.69 
 7.50 
 9.62 
 5.78 
 1,2,3,4 


 A.  3.3.5.2 
 Centrex/  Non- 
 Dis 
 patch/  MS( 


 hours) 


 1.89 
 0.00 
 3.87 
 0.25 
 2.94 
 0.00 
 2.47 
 1.29 
 2,4 


 A.  3.3.6.1 
 ISDN/  Dis 
 patch/  MS( 
 hours) 


 4.97 
 4.20 
 6.69 
 3.58 
 5.76 
 4.06 
 6.49 
 3.02 
 1,2,3,4 


 D-  11 
260
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Mississippi 
 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 A.  3.3.6.2 
 ISDN/  Non- 
 Dispatch/  MS( 


 hours) 


 5.79 
 0.56 
 1.67 
 0.93 
 2.66 
 1.28 
 6.25 
 0.65 
 1,2,3,4 


 % 
 Repeat 


 Troubles 


 within 
 30 
 Days 


 [M&  R- 


 4] 


 A.  3.4.1.1 
 Residence/  Dis 
 patch/  MS(%) 


 17.53% 
 9.80% 
 19.99% 
 11.10% 
 18.29% 
 11.73% 
 20.00% 
 12.42% 


 A.  3.4.1.2 
 Residence/  Non- 


 Dis  patch/ 
 MS(%) 


 14.91% 
 12.07% 
 16.52% 
 16.08% 
 15.71% 
 16.67% 
 17.43% 
 11.11% 


 A.  3.4.2.1 
 Business/  Dis 
 patch/  MS(%) 


 12.02% 
 19.17% 
 12.93% 
 14.81% 
 13.33% 
 8.82% 
 15.17% 
 12.04% 


 A.  3.4.2.2 
 Business/  Non- 


 Dis 
 patch/  MS(%) 


 13.08% 
 15.15% 
 12.00% 
 7.14% 
 14.24% 
 11.43% 
 15.27% 
 17.24% 


 A.  3.4.3.1 
 Desi 
 gn 
 (Specials)/  Dispatch/ 


 MS(%) 


 18.99% 
 39.29% 
 19.96% 
 35.59% 
 19.82% 
 17.33% 
 27.32% 
 24.32% 


 A.  3.4.3.2 
 Desi 
 gn 
 (Specials)/  Non- 


 Dispatch/  MS(%) 


 19.74% 
 31.03% 
 20.57% 
 20.00% 
 17.29% 
 32.14% 
 18.66% 
 22.22% 


 A.  3.4.4.1 
 PBX/  Dis 
 patch/  MS(%) 


 7.69% 
 0.00% 
 12.82% 
 30.00% 
 16.95% 
 55.56% 
 3.13% 
 0.00% 
 1,3,4 


 A.  3.4.4.2 
 PBX/  Non- 
 Dis 
 patch/  MS(%) 


 5.36% 
 0.00% 
 13.95% 


 0.00% 
 2.56% 
 50.00% 


 0.00% 
 0.00% 
 1,2,3 


 A.  3.4.5.1 
 Centrex/  Dis 
 patch/  MS(%) 


 12.26% 
 0.00% 
 11.92% 
 50.00% 
 11.73% 
 0.00% 
 13.35% 
 22.22% 
 1,2,3,4 


 A.  3.4.5.2 
 Centrex/  Non- 
 Dis 
 patch/  MS(%) 


 8.82% 
 0.00% 
 11.55% 


 0.00% 
 12.33% 


 0.00% 
 13.41% 
 42.86% 


 2,4 


 A.  3.4.6.1 
 ISDN/  Dis 
 patch/  MS(%) 


 0.00% 
 0.00% 
 9.30% 
 0.00% 
 19.44% 
 25.00% 
 25.64% 
 0.00% 
 1,2,3,4 


 A.  3.4.6.2 
 ISDN/  Non- 
 Dis 
 patch/  MS(%) 


 9.26% 
 33.33% 
 12.00% 
 0.00% 
 13.33% 


 0.00% 
 12.70% 
 25.00% 
 1,2,3,4 


 Out 
 of 
 Service 


 > 
 24 


 hours 


 [M&  R- 


 5] 


 A.  3.5.1.1 
 Residence/  Dis 
 patch/  MS(%) 


 29.13% 
 22.68% 
 29.98% 
 25.44% 
 32.73% 
 31.62% 
 35.67% 
 38.14% 


 A.  3.5.1.2 
 Residence/  Non- 


 Dis  patch/ 
 MS(%) 


 14.96% 
 3.85% 
 15.60% 


 2.74% 
 20.04% 


 8.75% 
 22.57% 
 10.23% 


 A.  3.5.2.1 
 Business/  Dis 
 patch/  MS(%) 


 4.56% 
 0.00% 
 4.15% 
 4.05% 
 5.75% 
 9.38% 
 5.39% 
 4.55% 


 A.  3.5.2.2 
 Business/  Non- 


 Dis 
 patch/  MS(%) 


 1.51% 
 0.00% 
 1.48% 
 0.00% 
 1.92% 
 0.00% 
 1.90% 
 0.00% 


 A.  3.5.3.1 
 Desi 
 gn 
 (Specials)/  Dispatch/ 


 MS(%) 


 0.58% 
 0.00% 
 0.78% 
 0.00% 
 0.18% 
 0.00% 
 1.16% 
 0.00% 


 A.  3.5.3.2 
 Desi 
 gn 
 (Specials)/  Non- 


 Dispatch/  MS(%) 


 0.19% 
 0.00% 
 0.19% 
 0.00% 
 0.00% 
 3.57% 
 0.18% 
 0.00% 


 A.  3.5.4.1 
 PBX/  Dis 
 patch/  MS(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 11.11% 


 0.00% 
 0.00% 
 1,2,3,4 


 A.  3.5.4.2 
 PBX/  Non- 
 Dis 
 patch/  MS(%) 


 11.32% 
 0.00% 
 2.44% 
 0.00% 
 6.45% 
 0.00% 
 0.00% 
 0.00% 


 2,3 


 A.  3.5.5.1 
 Centrex/  Dis 
 patch/  MS(%) 


 5.77% 
 0.00% 
 4.78% 
 0.00% 
 5.53% 
 0.00% 
 6.88% 
 0.00% 
 2,3,4 


 A.  3.5.5.2 
 Centrex/  Non- 
 Dis 
 patch/  MS(%) 


 1.33% 
 0.00% 
 0.83% 
 0.00% 
 1.21% 
 0.00% 
 0.00% 
 0.00% 


 2,4 


 A.  3.5.6.1 
 ISDN/  Dis 
 patch/  MS(%) 


 0.00% 
 0.00% 
 4.76% 
 0.00% 
 2.78% 
 0.00% 
 2.56% 
 0.00% 
 1,2,3,4 


 A.  3.5.6.2 
 ISDN/  Non- 
 Dis 
 patch/  MS(%) 


 5.56% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1.64% 
 0.00% 
 1,2,3,4 


 RESALE 
 - 
 BILLING  Invoice  Accuracy 


 [B-  1] 


 A.  4.1 
 MS 
 (%) 


 98.86% 
 99.34% 
 99.03% 
 98.29% 
 98.60% 
 99.61% 
 98.67% 
 99.78% 


 Mean 
 Time 
 to 
 Deliver 


 Invoices 


 - 
 CRIS 


 [B-  2] 


 A.  4.2 
 Re 
 gion( 


 business 


 days) 


 3.68 
 3.56 
 3.86 
 3.27 
 3.47 
 3.16 
 3.82 
 3.37 


 UNBUNDLED 
 NETWORK 
 ELEMENTS 


 - 
 ORDERING 


 D-  12 
261
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Mississippi 
 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Mechanized 


 [O-  7] 


 B.  1.1.3 
 Loo  p 
 + 
 Port 


 Combinations/  MS(%) 


 11.27% 
 10.47% 
 10.90% 
 13.35% 


 B.  1.1.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  MS(%) 


 13.33% 
 25.40% 
 24.53% 
 15.52% 


 B.  1.1.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  MS(%) 


 66.67% 
 50.00% 
 40.00% 
 16.00% 
 1,2,3 


 B.  1.1.8 
 2W 
 Analo  g 


 Loop 
 Design/  MS(%) 


 35.71% 
 69.23% 
 25.00% 
 50.00% 


 B.  1.1.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 MS(%) 


 0.00% 
 20.00% 
 40.00% 
 0.00% 
 2 


 B.  1.1.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  MS(%) 


 100.00% 
 2 


 B.  1.1.14 
 Other 
 Desi 
 gn/  MS(%) 


 9.00% 
 16.67% 
 12.07% 
 21.88% 


 B.  1.1.15 
 Other 
 Non-  Desi 


 gn/  MS(%) 


 20.00% 
 11.67% 
 12.70% 
 15.87% 


 B.  1.1.17 
 LNP 
 Standalone/  MS 


 (%) 


 7.69% 
 6.82% 
 12.26% 
 18.06% 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Partially 


 Mechanized 


 [O-  7] 


 B.  1.2.3 
 Loo  p 
 + 
 Port 


 Combinations/  MS(%) 


 33.16% 
 29.54% 
 33.05% 
 28.96% 


 B.  1.2.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  MS(%) 


 0.00% 
 0.00% 
 0.00% 


 1,2,3 


 B.  1.2.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  MS(%) 


 33.33% 
 28.57% 
 5.26% 
 25.00% 
 4 


 B.  1.2.8 
 2W 
 Analo  g 


 Loop 
 Design/  MS(%) 


 21.43% 
 0.00% 
 25.00% 
 75.00% 
 2,3,4 


 B.  1.2.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 MS(%) 


 0.00% 
 9.09% 
 16.67% 
 40.00% 
 1 


 B.  1.2.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  MS(%) 


 0.00% 
 100.00% 


 100.00% 
 80.00% 
 1,2,3,4 


 B.  1.2.14 
 Other 
 Desi  gn/ 


 MS(%) 


 35.71% 
 50.00% 
 35.71% 
 37.50% 
 2,4 


 B.  1.2.15 
 Other 
 Non-  Desi 


 gn/  MS(%) 


 24.44% 
 32.35% 
 36.67% 
 38.71% 


 B.  1.2.17 
 LNP 
 Standalone/  MS 


 (%) 


 12.00% 
 13.79% 
 21.51% 
 8.18% 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Non-  Mechanized 


 [O-  7] 


 B.  1.3.2 
 Local 
 Interoffice 


 Trans  port/ 
 MS(%) 


 0.00% 
 55.56% 
 14.29% 
 16.67% 
 1,2,3,4 


 B.  1.3.3 
 Loo  p 
 + 
 Port 


 Combinations/  MS(%) 


 43.88% 
 41.57% 
 44.63% 
 51.71% 


 B.  1.3.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  MS(%) 


 10.00% 
 19.05% 
 23.81% 
 0.00% 
 4 


 B.  1.3.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  MS(%) 


 60.00% 
 50.00% 
 0.00% 
 71.43% 
 2,3,4 


 B.  1.3.8 
 2W 
 Analo  g 


 Loop 
 Design/  MS(%) 


 30.77% 
 38.89% 
 60.00% 
 37.93% 
 3 


 B.  1.3.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 MS(%) 


 0.00% 
 51.85% 
 52.38% 
 33.33% 
 1 


 B.  1.3.11 
 2W 
 Analo  g 


 Loop 
 w/  INP 


 Non-  Design/ 


 MS(%) 


 0.00% 
 71.43% 
 100.00% 
 2,3,4 


 B.  1.3.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  MS(%) 


 75.00% 
 0.00% 
 64.29% 


 0.00% 
 2,4 


 B.  1.3.13 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Non-  Design/ 


 MS(%) 


 44.19% 
 34.69% 
 39.62% 
 31.03% 


 B.  1.3.14 
 Other 
 Desi  gn/ 


 MS(%) 


 37.84% 
 50.00% 
 37.78% 
 48.39% 


 B.  1.3.15 
 Other 
 Non-  Desi 


 gn/  MS(%) 


 42.70% 
 27.55% 
 22.03% 
 20.75% 


 B.  1.3.16 
 INP 
 Standalone/  MS 


 (%) 


 33.33% 
 60.00% 
 57.14% 
 42.86% 
 1,2,3,4 


 D-  13 
262
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Mississippi 
 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  1.3.17 
 LNP 
 Standalone/  MS(%) 


 31.17% 
 26.60% 
 26.98% 
 32.29% 


 Reject 
 Interval 


 - 
 Mechanized 


 [O-  8] 


 B.  1.4.3 
 Loo  p 
 + 
 Port 


 Combinations/  MS(%) 


 90.44% 
 93.00% 
 91.70% 
 95.17% 


 B.  1.4.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  MS(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,4 


 B.  1.4.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  MS(%) 


 0.00% 
 33.33% 


 0.00% 
 100.00% 
 1,2,3,4 


 B.  1.4.8 
 2W 
 Analo  g 


 Loop 
 Design/  MS(%) 


 100.00% 
 94.44% 
 100.00% 
 100.00% 
 1,3 


 B.  1.4.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 MS(%) 


 0.00% 
 100.00% 


 2,3 


 B.  1.4.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  MS(%) 


 100.00% 
 2 


 B.  1.4.14 
 Other 
 Desi 
 gn/  MS(%) 


 77.78% 
 92.86% 
 100.00% 


 85.71% 
 1,3,4 


 B.  1.4.15 
 Other 
 Non-  Desi 


 gn/  MS(%) 


 70.59% 
 100.00% 


 62.50% 
 60.00% 
 2,3 


 B.  1.4.17 
 LNP 
 Standalone/  MS 


 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2 


 Reject 
 Interval 


 - 
 Partially 


 Mechanized 


 - 
 10 


 hours 


 [O-  8] 


 B.  1.7.3 
 Loo  p 
 + 
 Port 


 Combinations/  MS(%) 


 97.01% 
 97.40% 
 85.69% 
 96.73% 


 B.  1.7.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  MS(%) 


 77.78% 
 100.00% 


 50.00% 
 80.00% 
 3,4 


 B.  1.7.8 
 2W 
 Analo  g 


 Loop 
 Design/  MS(%) 


 100.00% 
 100.00% 
 83.33% 
 1,3,4 


 B.  1.7.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 MS(%) 


 100.00% 
 100.00% 
 66.67% 
 2,3,4 


 B.  1.7.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  MS(%) 


 0.00% 
 100.00% 


 75.00% 
 2,3,4 


 B.  1.7.14 
 Other 
 Desi  gn/ 


 MS(%) 


 100.00% 
 100.00% 
 80.00% 
 66.67% 
 2,3,4 


 B.  1.7.15 
 Other 
 Non-  Desi 


 gn/  MS(%) 


 90.91% 
 90.91% 
 90.91% 
 91.67% 


 B.  1.7.17 
 LNP 
 Standalone/  MS 


 (%) 


 25.00% 
 66.67% 
 95.00% 
 66.67% 
 1 


 Reject 
 Interval 


 - 
 Non-  Mechanized 


 [O-  8] 


 B.  1.8.2 
 Local 
 Interoffice 


 Trans  port/ 
 MS(%) 


 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 B.  1.8.3 
 Loo  p 
 + 
 Port 


 Combinations/  MS(%) 


 100.00% 
 94.59% 
 100.00% 


 96.52% 


 B.  1.8.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  MS(%) 


 100.00% 
 100.00% 
 100.00% 


 1,2,3 


 B.  1.8.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  MS(%) 


 88.89% 
 100.00% 


 100.00% 
 1,2,4 


 B.  1.8.8 
 2W 
 Analo  g 


 Loop 
 Design/  MS(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3 


 B.  1.8.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 MS(%) 


 100.00% 
 100.00% 
 100.00% 
 4 


 B.  1.8.11 
 2W 
 Analo  g 


 Loop 
 w/  INP 


 Non-  Design/ 


 MS(%) 


 100.00% 
 100.00% 
 3,4 


 B.  1.8.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  MS(%) 


 100.00% 
 100.00% 
 1,3 


 B.  1.8.13 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Non-  Design/ 


 MS(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 4 


 B.  1.8.14 
 Other 
 Desi  gn/ 


 MS(%) 


 100.00% 
 100.00% 
 94.74% 
 100.00% 


 B.  1.8.15 
 Other 
 Non-  Desi 


 gn/  MS(%) 


 97.44% 
 96.30% 
 100.00% 


 95.45% 


 B.  1.8.16 
 INP 
 Standalone/  MS 


 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 D-  14 
263
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Mississippi 
 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  1.8.17 
 LNP 
 Standalone/  MS(%) 


 100.00% 
 96.00% 
 100.00% 


 96.88% 


 FOC 
 Timeliness 


 - 
 Mechanized 


 [O-  9] 


 B.  1.9.3 
 Loo  p 
 + 
 Port 


 Combinations/  MS(%) 


 99.41% 
 97.79% 
 96.52% 
 99.19% 


 B.  1.9.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  MS(%) 


 100.00% 
 97.87% 
 97.37% 
 95.74% 


 B.  1.9.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  MS(%) 


 100.00% 
 100.00% 


 100.00% 
 1,2 


 B.  1.9.8 
 2W 
 Analo  g 


 Loop 
 Design/  MS(%) 


 100.00% 
 100.00% 
 100.00% 
 90.00% 
 1,2,3 


 B.  1.9.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 MS(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2,3 


 B.  1.9.14 
 Other 
 Desi  gn/ 


 MS(%) 


 100.00% 
 100.00% 
 97.92% 
 100.00% 


 B.  1.9.15 
 Other 
 Non-  Desi 


 gn/  MS(%) 


 52.11% 
 58.00% 
 46.94% 
 51.85% 


 B.  1.9.17 
 LNP 
 Standalone/  MS 


 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 FOC 
 Timeliness 


 - 
 Partially 


 Mechanized 


 - 
 10 


 hours 


 [O-  9] 


 B.  1.12.3 
 Loo  p 
 + 
 Port 


 Combinations/  MS(%) 


 94.65% 
 94.65% 
 88.27% 
 94.13% 


 B.  1.12.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  MS(%) 


 57.14% 
 100.00% 
 100.00% 


 1,2,3 


 B.  1.12.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  MS(%) 


 89.58% 
 100.00% 


 83.78% 
 100.00% 
 4 


 B.  1.12.8 
 2W 
 Analo  g 


 Loop 
 Design/  MS(%) 


 90.91% 
 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 B.  1.12.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 MS(%) 


 100.00% 
 100.00% 
 86.67% 
 100.00% 
 1 


 B.  1.12.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  MS(%) 


 100.00% 


 100.00% 
 1,4 


 B.  1.12.14 
 Other 
 Desi  gn/ 


 MS(%) 


 100.00% 
 85.71% 
 88.89% 
 100.00% 
 2,3,4 


 B.  1.12.15 
 Other 
 Non-  Desi 


 gn/  MS(%) 


 25.00% 
 26.92% 
 52.63% 
 61.11% 


 B.  1.12.17 
 LNP 
 Standalone/  MS 


 (%) 


 95.45% 
 92.11% 
 90.91% 
 94.23% 


 FOC 
 Timeliness 


 - 
 Non-  Mechanized 


 [O-  9] 


 B.  1.13.2 
 Local 
 Interoffice 


 Trans  port/ 
 MS(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 B.  1.13.3 
 Loo  p 
 + 
 Port 


 Combinations/  MS(%) 


 100.00% 
 93.48% 
 100.00% 


 97.89% 


 B.  1.13.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  MS(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 4 


 B.  1.13.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  MS(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 B.  1.13.8 
 2W 
 Analo  g 


 Loop 
 Design/  MS(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 3 


 B.  1.13.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 MS(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 B.  1.13.11 
 2W 
 Analo  g 


 Loop 
 w/  INP 


 Non-  Design/ 


 MS(%) 


 100.00% 
 100.00% 


 2,3 


 B.  1.13.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  MS(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 B.  1.13.13 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Non-  Design/ 


 MS(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  1.13.14 
 Other 
 Desi  gn/ 


 MS(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  1.13.15 
 Other 
 Non-  Desi 


 gn/  MS(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  1.13.16 
 INP 
 Standalone/  MS 


 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 D-  15 
264
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Mississippi 
 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  1.13.17 
 LNP 
 Standalone/  MS(%) 


 100.00% 
 98.46% 
 100.00% 
 100.00% 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Mechanized 


 [O-  11] 


 B.  1.14.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  EDI/ 


 MS(%) 


 100.00% 
 99.89% 
 97.27% 
 100.00% 


 B.  1.14.3.2 
 Loo  p 
 + 
 Port 


 Combinations/  TAG/ 


 MS(%) 


 99.62% 
 98.99% 
 99.39% 
 99.96% 


 B.  1.14.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  EDI/ 


 MS(%) 


 97.78% 
 98.41% 
 96.08% 
 96.00% 


 B.  1.14.5.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  TAG/ 


 MS(%) 


 100.00% 
 75.00% 
 3,4 


 B.  1.14.6.1 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  EDI/ 


 MS(%) 


 100.00% 
 100.00% 
 40.00% 
 100.00% 
 1,2,3 


 B.  1.14.6.2 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  TAG/ 


 MS(%) 


 100.00% 
 2 


 B.  1.14.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  EDI/ 


 MS(%) 


 B.  1.14.8.2 
 2W 
 Analog 


 Loop 
 Design/  TAG/ 


 MS(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  1.14.9.2 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 TAG/  MS(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2 


 B.  1.14.12.2 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  TAG/ 


 MS(%) 


 100.00% 


 2 


 B.  1.14.14.1 
 Other 
 Desi 
 gn/  EDI/ 


 MS(%) 


 98.95% 
 100.00% 


 96.23% 
 100.00% 


 B.  1.14.14.2 
 Other 
 Desi  gn/ 


 TAG/  MS(%) 


 100.00% 
 91.67% 
 80.00% 
 100.00% 
 1,3,4 


 B.  1.14.15.1 
 Other 
 Non-  Desi 


 gn/  EDI/ 
 MS(%) 


 100.00% 
 87.50% 
 100.00% 
 2,3 


 B.  1.14.15.2 
 Other 
 Non-  Desi 


 gn/  TAG/ 
 MS(%) 


 90.59% 
 84.75% 
 89.09% 
 91.11% 


 B.  1.14.17.1 
 LNP 
 Standalone/  EDI/ 


 MS  (%) 


 100.00% 
 100.00% 
 97.14% 
 100.00% 


 B.  1.14.17.2 
 LNP 
 Standalone/  TAG/ 


 MS  (%) 


 66.67% 
 100.00% 
 100.00% 


 1,3 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Partially 


 Mechanized 


 [O-  11] 


 B.  1.15.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  EDI/ 


 MS(%) 


 100.00% 
 99.77% 
 96.18% 
 99.81% 


 B.  1.15.3.2 
 Loo  p 
 + 
 Port 


 Combinations/  TAG/ 


 MS(%) 


 99.40% 
 99.27% 
 99.85% 
 99.85% 


 B.  1.15.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  EDI/ 


 MS(%) 


 87.50% 
 100.00% 
 100.00% 


 1,2,3 


 B.  1.15.5.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  TAG/ 


 MS(%) 


 B.  1.15.6.1 
 ISDN 
 Loop 
 (UDN, 


 UDC)/  EDI/ 


 MS(%) 


 100.00% 
 100.00% 
 97.37% 
 100.00% 
 4 


 B.  1.15.6.2 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  TAG/ 


 MS(%) 


 95.65% 


 100.00% 
 4 


 B.  1.15.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  EDI/ 


 MS(%) 


 B.  1.15.8.2 
 2W 
 Analog 


 Loop 
 Design/  TAG/ 


 MS(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 B.  1.15.9.2 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 TAG/  MS(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1 


 B.  1.15.12.1 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  EDI/ 


 MS(%) 


 100.00% 
 3 


 B.  1.15.12.2 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  TAG/ 


 MS(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 B.  1.15.14.1 
 Other 
 Desi  gn/ 


 EDI/  MS(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2,4 


 B.  1.15.14.2 
 Other 
 Desi  gn/ 


 TAG/  MS(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 B.  1.15.15.1 
 Other 
 Non-  Desi 


 gn/  EDI/ 
 MS(%) 


 100.00% 
 100.00% 
 3,4 


 B.  1.15.15.2 
 Other 
 Non-  Desi 


 gn/  TAG/ 
 MS(%) 


 86.67% 
 88.24% 
 93.10% 
 96.30% 


 D-  16 
265
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Mississippi 
 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  1.15.17.1 
 LNP 
 Standalone/  EDI/ 


 MS(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  1.15.17.2 
 LNP 
 Standalone/  TAG/ 


 MS  (%) 


 100.00% 
 100.00% 
 1,3 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Non-  Mechanized 


 [O-  11] 


 B.  1.16.2 
 Local 
 Interoffice 


 Trans  port/ 
 MS(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 B.  1.16.3 
 Loo  p 
 + 
 Port 


 Combinations/  MS(%) 


 96.94% 
 95.51% 
 89.26% 
 94.15% 


 B.  1.16.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  MS(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 4 


 B.  1.16.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  MS(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 B.  1.16.8 
 2W 
 Analo  g 


 Loop 
 Design/  MS(%) 


 96.15% 
 100.00% 
 100.00% 
 100.00% 
 3 


 B.  1.16.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 MS(%) 


 100.00% 
 100.00% 
 80.95% 
 100.00% 
 1 


 B.  1.16.11 
 2W 
 Analo  g 


 Loop 
 w/  INP 


 Non-  Design/ 


 MS(%) 


 66.67% 
 100.00% 
 100.00% 
 2,3,4 


 B.  1.16.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  MS(%) 


 100.00% 
 100.00% 
 100.00% 
 66.67% 
 2,4 


 B.  1.16.13 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Non-  Design/ 


 MS(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  1.16.14 
 Other 
 Desi  gn/ 


 MS(%) 


 100.00% 
 100.00% 
 97.78% 
 100.00% 


 B.  1.16.15 
 Other 
 Non-  Desi 


 gn/  MS(%) 


 97.19% 
 100.00% 


 94.92% 
 98.11% 


 B.  1.16.16 
 INP 
 Standalone/  MS 


 (%) 


 100.00% 
 100.00% 
 71.43% 
 100.00% 
 1,2,3,4 


 B.  1.16.17 
 LNP 
 Standalone/  MS 


 (%) 


 100.00% 
 98.94% 
 96.83% 
 97.92% 


 UNBUNDLED 
 NETWORK 
 ELEMENTS 


 - 
 PROVISIONING 


 Order 
 Completion 


 Interval 
 [P-  4] 


 B.  2.1.2.1.1 
 Local 
 Interoffice 


 Transport/<  10 


 circuits/  Dis 
 patch/  MS( 
 days) 


 12.07 
 14.43 
 30.00 
 18.33 
 20.00 
 17.15 
 20.00 
 2,3,4 


 B.  2.1.3.1.1 
 Loop 
 + 
 Port 


 Combinations/<  10  circuits/  Dis  patch/  MS(  days) 


 4.85 
 5.00 
 5.10 
 3.97 
 5.01 
 3.92 
 5.12 
 3.85 


 B.  2.1.3.1.2 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Non- 


 Dis 
 patch/  MS( 


 days) 


 0.77 
 0.55 
 0.82 
 0.53 
 0.80 
 0.51 
 0.78 
 0.51 


 B.  2.1.3.1.3 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Switch 
 Based 


 Orders/  MS 
 (days) 


 0.33 
 0.33 
 0.33 
 0.33 
 0.33 
 0.33 
 0.33 
 0.33 


 B.  2.1.3.1.4 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Dispatch 


 In/  MS 
 (days) 


 1.54 
 1.24 
 1.56 
 1.25 
 1.49 
 1.33 
 1.43 
 1.25 


 B.  2.1.3.2.1 
 Loop 
 + 
 Port 


 Combinations/>=  10  circuits/  Dis  patch/  MS(  days) 


 8.81 
 1.17 
 11.51 


 1.00 
 9.48 


 8.62 
 1,2 


 B.  2.1.3.2.2 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Non- 


 Dis 
 patch/  MS( 


 days) 


 2.07 
 3.89 
 1.11 
 2.18 
 2.00 
 3.39 


 2,3 


 B.  2.1.3.2.3 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Switch 
 Based 


 Orders/  MS 
 (days) 


 0.33 
 0.33 
 0.33 
 0.33 


 0.33 


 2 


 D-  17 
266
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Mississippi 
 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  2.1.3.2.4 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Dispatch 


 In/  MS 
 (days) 


 3.80 
 5.58 
 1.50 
 3.46 
 2.00 
 6.20 


 2,3 


 B.  2.1.4.1.1 
 Combo 
 Other/<  10 


 circuits/  Dis 
 patch/  MS( 
 days) 


 5.69 


 5.75 
 11.20 


 5.79 
 10.83 


 5.65 
 10.00 
 2,3,4 


 B.  2.1.6.3.1 
 UNE 
 ISDN/<  6 


 circuits/  Dis 


 patch/  MS( 
 days) 


 13.74 
 10.69 
 10.58 
 10.31 
 14.66 
 10.73 
 15.60 
 11.13 


 B.  2.1.8.1.1 
 2W 
 Analog 


 Loop 
 Design/<  10 


 circuits/  Dis 
 patch/  MS( 
 days) 


 4.85 
 5.56 
 5.10 
 4.80 
 5.01 
 4.00 
 5.12 
 6.25 
 1,2,3,4 


 B.  2.1.9.1.1 
 2W 
 Analog 


 Loop 
 Non-  Design/< 


 10 


 circuits/  Dis 
 patch/  MS( 
 days) 


 4.85 
 3.80 
 5.11 
 5.25 
 4.99 
 4.14 
 5.14 
 6.00 
 1,2,3,4 


 B.  2.1.10.1.1 
 2W 
 Analog 


 Loop 
 w/  INP 


 Design/<  10 


 circuits/  Dis 
 patch/  MS( 
 days) 


 4.85 
 5.10 
 5.01 
 5.12 
 3.00 


 4 


 B.  2.1.11.1.1 
 2W 
 Analog 


 Loop 
 w/  INP 


 Non-  Design/< 


 10 


 circuits/  Dis 
 patch/  MS( 
 days) 


 4.85 
 5.11 
 6.00 
 4.99 


 5.14 


 2 


 B.  2.1.12.1.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/<  10 


 circuits/  Dis 
 patch/  MS( 
 days) 


 4.85 
 6.00 
 5.10 
 5.00 
 5.01 
 7.00 
 5.12 
 5.50 
 1,2,3,4 


 B.  2.1.13.1.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/< 


 10 


 circuits/  Dis 
 patch/  MS( 
 days) 


 4.85 
 4.86 
 5.11 
 6.14 
 4.99 
 4.51 
 5.14 
 5.00 
 2,4 


 B.  2.1.13.2.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/>= 


 10 


 circuits/  Dis 
 patch/  MS( 
 days) 


 8.29 
 3.00 
 10.58 


 8.86 
 6.76 


 1 


 B.  2.1.15.1.1 
 Other 
 Non-  Design/< 


 10 
 circuits/  Dispatch/ 


 MS(  days) 
 4.85 
 5.74 
 5.10 
 5.78 
 5.01 
 5.46 
 5.12 
 5.55 


 B.  2.1.15.1.2 
 Other 
 Non-  Design/< 


 10 
 circuits/  Non- 


 Dis 
 patch/  MS( 


 days) 


 0.77 
 0.82 
 9.00 
 0.80 


 0.78 


 2 


 B.  2.1.16.1.2 
 INP 
 (Standalone)/<  10 


 circuits/  Non- 
 Dispatch/  MS( 


 days) 
 0.76 


 0.81 
 0.79 
 0.83 
 0.77 


 3 


 B.  2.1.17.1.2 
 LNP 
 (Standalone)/<  10 


 circuits/  Non- 


 Dis 
 patch/  MS( 


 days) 


 0.76 
 0.45 
 0.81 
 0.47 
 0.79 
 0.59 
 0.77 
 0.61 


 B.  2.1.17.2.2 
 LNP 
 (Standalone)/>=  10 


 circuits/  Non- 


 Dis 
 patch/  MS( 


 days) 


 1.53 
 0.33 
 0.56 
 0.33 
 0.83 


 3 


 B.  2.1.18.1.1 
 Digital 
 Loop 
 < 
 DS1/<  10 


 circuits/  Dispatch/ 


 MS(  days) 
 9.17 
 7.44 
 7.16 
 6.74 
 7.61 
 7.17 
 5.60 
 6.72 


 B.  2.1.19.1.1 
 Digital 
 Loop 
 >= 
 DS1/<  10 


 circuits/  Dispatch/ 


 MS(  days) 
 23.39 
 5.69 
 24.99 


 5.75 
 24.94 


 5.95 
 12.94 


 5.69 


 Order 
 Completion 


 Interval 
 within 
 X 
 days 


 [P-  4] 


 D-  18 
267
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Mississippi 
 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  2.2.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL) 


 Loop 
 with 


 Conditionin  g/< 
 6 
 circuits/  Dispatch/ 


 MS( 
 days) 


 7.00 
 4 


 B.  2.2.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL) 


 Loop 
 w/  o 


 Conditionin  g/< 
 6 
 circuits/  Dispatch/ 


 MS( 
 days) 


 4.43 
 4.54 
 5.19 
 4.37 


 % 
 Jeopardies 


 - 
 Mechanized 


 [P-  2] 


 B.  2.5.3 
 Loo  p 
 + 
 Port 


 Combinations/  MS(%) 


 0.75% 
 0.64% 
 0.81% 
 0.53% 
 0.76% 
 0.49% 
 0.65% 
 0.29% 


 B.  2.5.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  MS(%) 


 14.97% 
 8.71% 
 2.61% 
 10.17% 
 0.00% 


 B.  2.5.6 
 UNE 
 ISDN/  MS 


 (%) 


 8.11% 
 43.48% 


 6.86% 
 36.84% 
 12.75% 
 42.86% 
 7.00% 
 47.37% 


 B.  2.5.8 
 2W 
 Analo  g 


 Loop 
 Design/  MS(%) 


 0.75% 
 0.00% 
 0.81% 
 0.00% 
 0.76% 
 0.00% 
 0.65% 
 50.00% 
 1,2,3,4 


 B.  2.5.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 MS(%) 


 1.71% 
 16.67% 


 1.78% 
 20.00% 


 1.62% 
 26.67% 


 1.41% 
 36.36% 


 B.  2.5.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  MS(%) 


 0.75% 
 0.00% 
 0.81% 
 0.00% 
 0.76% 


 0.65% 
 0.00% 
 1,2,4 


 B.  2.5.14 
 Other 
 Desi  gn/ 


 MS(%) 


 14.09% 
 20.57% 
 14.58% 
 12.36% 


 B.  2.5.15 
 Other 
 Non-  Desi 


 gn/  MS(%) 


 0.75% 
 0.81% 
 0.76% 
 0.65% 


 B.  2.5.16 
 INP 
 (Standalone)/  MS(%) 


 0.75% 
 0.81% 
 0.75% 
 0.65% 


 B.  2.5.17 
 LNP 
 (Standalone)/  MS(%) 


 0.75% 
 0.00% 
 0.81% 
 0.00% 
 0.75% 
 0.00% 
 0.65% 
 0.00% 


 B.  2.5.18 
 Di 
 gital 


 Loop 


 < 
 DS1/  MS(%) 


 14.57% 
 43.48% 
 10.46% 
 36.84% 
 5.18% 
 42.86% 


 9.71% 
 21.43% 


 B.  2.5.19 
 Di 
 gital 


 Loop 


 >= 
 DS1/  MS(%) 


 11.37% 
 91.03% 
 12.32% 
 86.96% 
 12.96% 
 93.22% 
 6.90% 
 86.96% 


 % 
 Jeopardies 


 - 
 Non-  Mechanized 


 [P-  2] 


 B.  2.6.2 
 Local 
 Interoffice 


 Trans  port/ 
 MS(%) 


 0.00% 
 0.00% 
 0.00% 
 2,3,4 


 B.  2.6.3 
 Loo  p 
 + 
 Port 


 Combinations/  MS(%) 


 1.45% 
 2.89% 
 1.76% 
 0.91% 


 B.  2.6.4 
 Combo 
 Other/  MS 


 (%) 


 40.00% 
 42.86% 
 50.00% 
 2,3,4 


 B.  2.6.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  MS(%) 


 4.17% 
 2.50% 
 7.89% 
 20.00% 


 B.  2.6.6 
 UNE 
 ISDN/  MS 


 (%) 


 20.00% 


 1 


 B.  2.6.8 
 2W 
 Analo  g 


 Loop 
 Design/  MS(%) 


 14.29% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3,4 


 B.  2.6.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 MS(%) 


 0.00% 
 0.00% 
 25.00% 


 0.00% 
 1,2,3,4 


 B.  2.6.10 
 2W 
 Analo  g 


 Loop 
 w/  INP 


 Design/  MS(%) 


 0.00% 
 4 


 B.  2.6.11 
 2W 
 Analo  g 


 Loop 
 w/  INP 


 Non-  Design/ 


 MS(%) 


 0.00% 
 0.00% 


 0.00% 
 1,2,4 


 B.  2.6.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  MS(%) 


 0.00% 
 100.00% 
 60.00% 
 1,3,4 


 B.  2.6.13 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Non-  Design/ 


 MS(%) 


 4.55% 
 5.56% 
 0.00% 
 10.00% 


 B.  2.6.15 
 Other 
 Non-  Desi 


 gn/  MS(%) 


 9.09% 
 18.92% 
 11.11% 
 12.00% 


 B.  2.6.16 
 INP 
 (Standalone)/  MS(%) 


 0.00% 
 3 


 B.  2.6.17 
 LNP 
 (Standalone)/  MS(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 


 B.  2.6.18 
 Di  gital 
 Loop 
 < 
 DS1/  MS(%) 


 5.66% 
 2.50% 
 7.89% 
 20.00% 


 B.  2.6.19 
 Di  gital 
 Loop 
 >= 
 DS1/  MS(%) 


 90.00% 
 41.67% 
 15.38% 
 30.00% 


 D-  19 
268
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Mississippi 
 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 Average 
 Jeopardy 


 Notice 
 Interval 


 - 
 Mechanized 


 [P-  2] 


 B.  2.8.3 
 Loo  p 
 + 
 Port 


 Combinations/  MS( 


 hours) 


 183.35 
 155.33 
 137.28 
 132.68 


 B.  2.8.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  MS( 


 hours) 


 B.  2.8.6 
 UNE 
 ISDN/  MS( 


 hours) 


 334.05 
 320.36 
 357.13 
 343.01 
 2,3,4 


 B.  2.8.8 
 2W 
 Analo  g 


 Loop 
 Design/  MS( 


 hours) 


 436.07 
 4 


 B.  2.8.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 MS( 
 hours) 


 31.00 
 108.74 
 134.47 


 93.05 
 1,2,3,4 


 B.  2.8.18 
 Di 
 gital 


 Loop 


 < 
 DS1/  MS( 


 hours) 


 334.05 
 320.36 
 357.13 
 343.01 
 2,3,4 


 B.  2.8.19 
 Di 
 gital 


 Loop 


 >= 
 DS1/  MS( 


 hours) 


 178.34 
 203.30 
 184.67 
 170.05 


 Average 
 Jeopardy 


 Notice 
 Interval 


 - 
 Non-  Mechanized 


 [P-  2] 


 B.  2.9.3 
 Loo  p 
 + 
 Port 


 Combinations/  MS( 


 hours) 


 280.97 
 145.64 


 56.10 
 97.88 
 1,2,3,4 


 B.  2.9.4 
 Combo 
 Other/  MS 


 (hours) 


 299.53 
 341.14 
 339.71 
 2,3,4 


 B.  2.9.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  MS( 


 hours) 


 135.85 
 111.77 
 215.84 
 143.51 
 1,2,3,4 


 B.  2.9.6 
 UNE 
 ISDN/  MS 


 (hours) 


 326.52 


 1 


 B.  2.9.8 
 2W 
 Analo  g 


 Loop 
 Design/  MS( 


 hours) 


 206.20 


 1 


 B.  2.9.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 MS( 
 hours) 


 39.45 
 3 


 B.  2.9.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  MS( 


 hours) 


 25.03 
 164.20 
 3,4 


 B.  2.9.13 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Non-  Design/ 


 MS( 
 hours) 


 111.72 
 136.15 


 63.68 
 1,2,4 


 B.  2.9.15 
 Other 
 Non-  Desi 


 gn/  MS( 
 hours) 


 99.76 
 126.47 
 156.76 


 87.70 
 1,2,3,4 


 B.  2.9.18 
 Di 
 gital 


 Loop 


 < 
 DS1/  MS( 


 hours) 


 231.18 
 111.77 
 215.84 
 143.51 
 1,2,3,4 


 B.  2.9.19 
 Di 
 gital 


 Loop 


 >= 
 DS1/  MS( 


 hours) 


 170.58 
 212.12 
 171.76 
 179.97 
 1,2,3,4 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Mechanized 


 [P-  2] 


 B.  2.10.3 
 Loo  p 
 + 
 Port 


 Combinations/  MS(%) 


 100.00% 
 100.00% 
 100.00% 
 96.00% 


 B.  2.10.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  MS(%) 


 B.  2.10.6 
 UNE 
 ISDN/  MS(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 B.  2.10.8 
 2W 
 Analo  g 


 Loop 
 Design/  MS(%) 


 100.00% 
 4 


 B.  2.10.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 MS(%) 


 0.00% 
 100.00% 


 100.00% 
 100.00% 
 1,2,3,4 


 B.  2.10.18 
 Di  gital 
 Loop 
 < 
 DS1/  MS(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 B.  2.10.19 
 Di 
 gital 


 Loop 


 >= 
 DS1/  MS(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Non-  Mechanized 


 [P-  2] 


 B.  2.11.3 
 Loo  p 
 + 
 Port 


 Combinations/  MS(%) 


 100.00% 
 75.00% 
 50.00% 
 66.67% 
 1,2,3,4 


 B.  2.11.4 
 Combo 
 Other/  MS 


 (%) 


 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 B.  2.11.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  MS(%) 


 100.00% 
 100.00% 
 100.00% 
 50.00% 
 1,2,3,4 


 B.  2.11.6 
 UNE 
 ISDN/  MS 


 (%) 


 100.00% 


 1 


 D-  20 
269
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Mississippi 
 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  2.11.8 
 2W 
 Analog 


 Loop 
 Design/  MS(%) 


 100.00% 


 1 


 B.  2.11.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 MS(%) 


 0.00% 
 3 


 B.  2.11.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  MS(%) 


 0.00% 
 100.00% 
 3,4 


 B.  2.11.13 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Non-  Design/ 


 MS(%) 


 100.00% 
 100.00% 


 100.00% 
 1,2,4 


 B.  2.11.15 
 Other 
 Non-  Desi 


 gn/  MS(%) 


 50.00% 
 100.00% 
 100.00% 
 40.00% 
 1,2,3,4 


 B.  2.11.18 
 Di 
 gital 


 Loop 


 < 
 DS1/  MS(%) 


 100.00% 
 100.00% 
 100.00% 
 50.00% 
 1,2,3,4 


 B.  2.11.19 
 Di 
 gital 


 Loop 


 >= 
 DS1/  MS(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 Coordinated 
 Customers 
 Conversions 


 [P-  7] 


 B.  2.12.2 
 Loo  ps 
 with 
 LNP/  MS(%) 


 100.00% 
 100.00% 
 50.00% 
 100.00% 
 2,3 


 % 
 Hot 


 Cuts 


 > 
 15 


 minutes 


 Early 
 [P-  7A] 


 B.  2.13.2 
 Time-  S 
 pecific 
 SL2/  MS(%) 


 0.00% 
 0.00% 
 3,4 


 B.  2.13.4 
 Non-  Time 
 Specific 
 SL2/  MS(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3,4 


 Hot 
 Cut 
 Timeliness 


 [P-  7A] 


 B.  2.14.2 
 Time-  S 
 pecific 
 SL2/  MS(%) 


 100.00% 
 100.00% 
 3,4 


 B.  2.14.4 
 Non-  Time 
 Specific 
 SL2/  MS(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 % 
 Hot 


 Cuts 


 > 
 15 


 minutes 


 Late 
 [P-  7A] 


 B.  2.15.2 
 Time-  S 
 pecific 
 SL2/  MS(%) 


 0.00% 
 0.00% 
 3,4 


 B.  2.15.4 
 Non-  Time 
 Specific 
 SL2/  MS(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3,4 


 % 
 Provisioning 


 Troubles 
 within 
 7 
 Days 


 - 
 Hot 


 Cuts 


 [P-  7C] 


 B.  2.17.1.1 
 UNE 
 Loo 
 p 
 Design/  Dispatch/ 


 MS(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 3,4 


 % 
 Missed 


 Installation 


 Appointments 


 [P-  3] 


 B.  2.18.2.1.1 
 Local 
 Interoffice 


 Transport/<  10 


 circuits/  Dis 
 patch/  MS(%) 


 1.22% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 2,3,4 


 B.  2.18.3.1.1 
 Loop 
 + 
 Port 


 Combinations/<  10  circuits/  Dis  patch/  MS(%) 


 4.50% 
 1.72% 
 6.28% 
 2.28% 
 6.47% 
 3.02% 
 7.09% 
 4.35% 


 B.  2.18.3.1.2 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Non- 


 Dis 
 patch/  MS(%) 


 0.02% 
 0.03% 
 0.09% 
 0.21% 
 0.01% 
 0.04% 
 0.02% 
 0.04% 


 B.  2.18.3.1.3 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Switch 
 Based 


 Orders/  MS 
 (%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 B.  2.18.3.1.4 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Dispatch 


 In/  MS 
 (%) 


 0.05% 
 0.09% 
 0.22% 
 0.59% 
 0.03% 
 0.11% 
 0.04% 
 0.11% 


 B.  2.18.3.2.1 
 Loop 
 + 
 Port 


 Combinations/>=  10  circuits/  Dis  patch/  MS(%) 


 9.30% 
 0.00% 
 6.15% 
 0.00% 
 7.84% 


 10.26% 


 1,2 


 D-  21 
270
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Mississippi 
 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  2.18.3.2.2 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Non- 


 Dis 
 patch/  MS(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 2,3 


 B.  2.18.3.2.3 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Switch 
 Based 


 Orders/  MS 
 (%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 


 0.00% 


 2 


 B.  2.18.3.2.4 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Dispatch 


 In/  MS 
 (%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 2,3 


 B.  2.18.4.1.1 
 Combo 
 Other/<  10 


 circuits/  Dis 
 patch/  MS(%) 


 4.43% 
 6.16% 
 0.00% 
 6.34% 
 0.00% 
 6.94% 
 0.00% 
 2,3,4 


 B.  2.18.5.1.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/<  10 


 circuits/  Dis 
 patch/  MS(%) 


 3.06% 
 0.00% 
 4.91% 
 0.00% 
 3.97% 
 0.00% 
 5.91% 
 0.00% 


 B.  2.18.6.1.1 
 UNE 
 ISDN/<  10 


 circuits/  Dis 
 patch/  MS(%) 


 3.92% 
 3.45% 
 2.27% 
 0.00% 
 5.56% 
 0.00% 
 3.45% 
 11.11% 


 B.  2.18.8.1.1 
 2W 
 Analog 


 Loop 
 Design/<  10 


 circuits/  Dispatch/ 


 MS(%) 
 4.50% 


 0.00% 
 6.28% 
 0.00% 
 6.47% 
 0.00% 
 7.09% 
 0.00% 
 2,3,4 


 B.  2.18.9.1.1 
 2W 
 Analog 


 Loop 
 Non-  Design/< 


 10 


 circuits/  Dispatch/ 
 MS(%) 


 4.52% 
 0.00% 
 6.34% 
 0.00% 
 6.52% 
 0.00% 
 7.13% 
 13.33% 


 B.  2.18.10.1.1 
 2W 
 Analog 


 Loop 
 w/  INP 


 Design/<  10 


 circuits/  Dis 
 patch/  MS(%) 


 4.50% 
 6.28% 
 6.47% 
 7.09% 
 0.00% 


 4 


 B.  2.18.11.1.1 
 2W 
 Analog 


 Loop 
 w/  INP 


 Non-  Design/< 


 10 


 circuits/  Dis 
 patch/  MS(%) 


 4.52% 
 0.00% 
 6.34% 
 0.00% 
 6.52% 


 7.13% 
 0.00% 
 1,2,4 


 B.  2.18.12.1.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/<  10 


 circuits/  Dis 
 patch/  MS(%) 


 4.50% 
 0.00% 
 6.28% 
 0.00% 
 6.47% 
 0.00% 
 7.09% 
 0.00% 
 1,2,3,4 


 B.  2.18.13.1.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/< 


 10 


 circuits/  Dis 
 patch/  MS(%) 


 4.52% 
 0.00% 
 6.34% 
 0.00% 
 6.52% 
 0.00% 
 7.13% 
 0.00% 


 B.  2.18.13.2.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/>= 


 10 


 circuits/  Dis 
 patch/  MS(%) 


 8.57% 
 0.00% 
 7.27% 


 7.14% 
 10.00% 


 1 


 B.  2.18.15.1.1 
 Other 
 Non-  Desi 


 gn/<  10 
 circuits/  Dispatch/ 


 MS(%) 
 4.50% 
 0.00% 
 6.28% 
 0.00% 
 6.47% 
 0.00% 
 7.09% 
 0.00% 


 B.  2.18.15.1.2 
 Other 
 Non-  Design/< 


 10 
 circuits/  Non- 


 Dispatch/  MS(%) 


 0.02% 
 0.09% 
 0.00% 
 0.01% 


 0.02% 


 2 


 B.  2.18.16.1.2 
 INP 
 (Standalone)/<  10 


 circuits/  Non- 
 Dispatch/  MS(%) 


 0.02% 
 0.09% 
 0.01% 
 0.00% 
 0.02% 


 3 


 B.  2.18.17.1.2 
 LNP 
 (Standalone)/<  10 


 circuits/  Non- 
 Dispatch/  MS(%) 


 0.02% 
 0.00% 
 0.09% 
 0.49% 
 0.01% 
 0.00% 
 0.02% 
 0.00% 


 B.  2.18.17.2.2 
 LNP 
 (Standalone)/>=  10 


 circuits/  Non- 
 Dispatch/  MS(%) 


 0.00% 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 2,3,4 


 B.  2.18.18.1.1 
 Di 
 gital 


 Loop 


 < 
 DS1/<  10 


 circuits/  Dispatch/ 


 MS(%) 
 3.39% 
 1.28% 
 4.72% 
 0.00% 
 3.98% 
 0.00% 
 5.80% 
 3.92% 


 D-  22 
271
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Mississippi 
 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  2.18.19.1.1 
 Digital 
 Loop 
 >= 
 DS1/<  10 


 circuits/  Dispatch/ 


 MS(%) 
 3.94% 
 1.05% 
 4.07% 
 0.00% 
 5.36% 
 2.78% 
 2.47% 
 0.00% 


 % 
 Provisioning 


 Troubles 
 within 
 30 
 Days 


 [P-  9] 


 B.  2.19.2.1.1 
 Local 
 Interoffice 


 Transport/<  10 


 circuits/  Dis 
 patch/  MS(%) 


 8.06% 
 0.00% 
 12.80% 


 11.79% 
 0.00% 
 7.00% 
 0.00% 
 1,3,4 


 B.  2.19.3.1.1 
 Loop 
 + 
 Port 


 Combinations/<  10  circuits/  Dis  patch/  MS(%) 


 10.04% 
 8.04% 
 10.62% 


 9.65% 
 10.40% 
 10.26% 
 11.48% 
 10.16% 


 B.  2.19.3.1.2 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Non- 


 Dis 
 patch/  MS(%) 


 3.11% 
 2.65% 
 3.36% 
 2.66% 
 2.83% 
 2.10% 
 2.82% 
 1.97% 


 B.  2.19.3.1.3 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Switch 
 Based 


 Orders/  MS 
 (%) 


 3.44% 
 2.05% 
 3.63% 
 1.79% 
 3.27% 
 1.39% 
 3.10% 
 1.55% 


 B.  2.19.3.1.4 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Dispatch 


 In/  MS 
 (%) 


 2.61% 
 3.61% 
 2.93% 
 4.76% 
 2.21% 
 3.38% 
 2.43% 
 2.57% 


 B.  2.19.3.2.1 
 Loop 
 + 
 Port 


 Combinations/>=  10  circuits/  Dis  patch/  MS(%) 


 11.76% 
 50.00% 
 11.63% 
 25.00% 
 9.23% 
 0.00% 
 15.69% 


 1,2,3 


 B.  2.19.3.2.2 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Non- 


 Dis 
 patch/  MS(%) 


 7.55% 
 11.48% 
 15.79% 
 0.00% 
 11.43% 


 0.00% 
 3,4 


 B.  2.19.3.2.3 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Switch 
 Based 


 Orders/  MS 
 (%) 


 10.53% 
 10.00% 
 0.00% 
 0.00% 
 11.11% 


 3 


 B.  2.19.3.2.4 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Dispatch 


 In/  MS 
 (%) 


 5.88% 
 12.90% 
 23.08% 
 0.00% 
 11.63% 


 0.00% 
 3,4 


 B.  2.19.4.1.1 
 Combo 
 Other/<  10 


 circuits/  Dis 
 patch/  MS(%) 


 9.89% 
 10.43% 
 10.32% 
 20.00% 
 11.36% 
 14.29% 


 3,4 


 B.  2.19.5.1.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/<  10 


 circuits/  Dis 
 patch/  MS(%) 


 3.18% 
 3.13% 
 2.12% 
 10.20% 


 3.03% 
 5.13% 
 4.96% 
 8.11% 


 B.  2.19.6.1.1 
 UNE 
 ISDN/<  10 


 circuits/  Dis 
 patch/  MS(%) 


 1.96% 
 0.00% 
 3.92% 
 6.90% 
 6.82% 
 4.76% 
 2.78% 
 0.00% 


 B.  2.19.8.1.1 
 2W 
 Analog 


 Loop 
 Design/<  10 


 circuits/  Dispatch/ 


 MS(%) 
 10.04% 


 0.00% 
 10.62% 
 13.33% 
 10.40% 
 11.11% 
 11.48% 
 0.00% 
 3,4 


 B.  2.19.9.1.1 
 2W 
 Analog 


 Loop 
 Non-  Design/< 


 10 


 circuits/  Dispatch/ 
 MS(%) 


 10.19% 
 0.00% 
 10.62% 


 0.00% 
 10.44% 


 0.00% 
 11.47% 


 0.00% 


 B.  2.19.11.1.1 
 2W 
 Analog 


 Loop 
 w/  INP 


 Non-  Design/< 


 10 


 circuits/  Dis 
 patch/  MS(%) 


 10.19% 
 10.62% 
 0.00% 
 10.44% 


 0.00% 
 11.47% 


 2,3 


 B.  2.19.12.1.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/<  10 


 circuits/  Dis 
 patch/  MS(%) 


 10.04% 
 0.00% 
 10.62% 
 14.29% 
 10.40% 
 0.00% 
 11.48% 


 0.00% 
 1,2,3,4 


 B.  2.19.13.1.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/< 


 10 


 circuits/  Dis 
 patch/  MS(%) 


 10.19% 
 6.67% 
 10.62% 


 0.00% 
 10.44% 


 0.00% 
 11.47% 


 0.00% 


 D-  23 
272
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Mississippi 
 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  2.19.13.2.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/>= 


 10 


 circuits/  Dis 
 patch/  MS(%) 


 10.53% 
 8.57% 
 0.00% 
 7.27% 


 11.90% 


 2 


 B.  2.19.14.1.1 
 Other 
 Desi 
 gn/<  10 


 circuits/  Dispatch/ 


 MS(%) 


 6.64% 
 100.00% 


 6.21% 


 8.45% 
 8.52% 


 1 


 B.  2.19.15.1.1 
 Other 
 Non-  Desi 


 gn/<  10 
 circuits/  Dispatch/ 


 MS(%) 
 10.04% 
 0.00% 
 10.62% 


 9.09% 
 10.40% 


 8.33% 
 11.48% 
 11.11% 


 B.  2.19.15.1.2 
 Other 
 Non-  Design/< 


 10 
 circuits/  Non- 


 Dispatch/  MS(%) 


 3.11% 
 3.36% 
 2.83% 
 0.00% 
 2.82% 


 3 


 B.  2.19.16.1.2 
 INP 
 (Standalone)/<  10 


 circuits/  Non- 
 Dispatch/  MS(%) 


 3.15% 
 0.00% 
 3.36% 


 2.83% 
 2.81% 
 0.00% 


 1,4 


 B.  2.19.17.1.2 
 LNP 
 (Standalone)/<  10 


 circuits/  Non- 
 Dispatch/  MS(%) 


 3.15% 
 0.00% 
 3.36% 
 0.00% 
 2.83% 
 0.00% 
 2.81% 
 0.00% 


 B.  2.19.17.2.2 
 LNP 
 (Standalone)/>=  10 


 circuits/  Non- 
 Dispatch/  MS(%) 


 0.00% 
 0.00% 
 0.00% 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1,3,4 


 B.  2.19.18.1.1 
 Di 
 gital 


 Loop 


 < 
 DS1/<  10 


 circuits/  Dispatch/ 


 MS(%) 
 3.99% 
 2.17% 
 3.29% 
 8.97% 
 4.08% 
 5.00% 
 5.01% 
 5.77% 


 B.  2.19.19.1.1 
 Di 
 gital 


 Loop 


 >= 
 DS1/<  10 


 circuits/  Dispatch/ 


 MS(%) 
 4.69% 
 13.95% 


 6.30% 
 17.89% 


 6.50% 
 17.07% 


 6.25% 
 15.28% 


 B.  2.19.19.1.2 
 Digital 
 Loop 
 >= 
 DS1/<  10 


 circuits/  Non- 


 Dis 
 patch/  MS(%) 


 1.98% 
 1.73% 
 0.85% 
 0.65% 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Mechanized 


 [P-  5] 


 B.  2.21.3.1.1 
 Loop 
 + 
 Port 


 Combinations/<  10  circuits/  Dis  patch/  MS(  hours) 


 1.49 
 0.45 
 1.83 
 0.33 
 1.59 
 0.36 
 1.41 
 0.29 


 B.  2.21.3.1.2 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Non- 


 Dis 
 patch/  MS( 


 hours) 


 0.69 
 0.35 
 0.48 
 0.34 
 0.49 
 0.33 
 0.60 
 0.36 


 B.  2.21.3.1.3 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Switch 
 Based 


 Orders/  MS 
 (hours) 


 0.48 
 0.34 
 0.54 
 0.32 
 0.56 
 0.34 
 0.61 
 0.37 


 B.  2.21.3.1.4 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Dispatch 


 In/  MS 
 (hours) 


 1.04 
 0.37 
 0.41 
 0.37 
 0.39 
 0.32 
 0.59 
 0.34 


 B.  2.21.3.2.1 
 Loop 
 + 
 Port 


 Combinations/>=  10  circuits/  Dis  patch/  MS(  hours) 


 3.44 
 0.02 
 3.40 


 3.92 
 0.03 


 1 


 B.  2.21.3.2.2 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Non- 


 Dis 
 patch/  MS( 


 hours) 


 0.29 
 1.27 
 0.31 
 0.38 


 2.07 


 2 


 B.  2.21.3.2.3 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Switch 
 Based 


 Orders/  MS 
 (hours) 


 0.28 
 0.27 
 0.27 
 0.35 


 1.19 


 2 


 B.  2.21.3.2.4 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Dispatch 


 In/  MS 
 (hours) 


 0.30 
 1.74 
 0.32 
 0.39 


 2.84 


 2 


 D-  24 
273
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Mississippi 
 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  2.21.5.1.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/<  10 


 circuits/  Dis 
 patch/  MS( 
 hours) 


 6.29 
 5.00 
 3.78 
 1.63 
 5.82 


 B.  2.21.6.1.1 
 UNE 
 ISDN/<  10 


 circuits/  Dis 
 patch/  MS( 
 hours) 


 55.61 
 29.74 
 60.05 


 1.87 
 26.91 


 9.42 
 38.53 


 3.77 


 B.  2.21.8.1.1 
 2W 
 Analog 


 Loop 
 Design/<  10 


 circuits/  Dis 
 patch/  MS( 
 hours) 


 1.49 
 26.62 


 1.83 
 0.12 
 1.59 
 0.29 
 1.41 
 27.55 
 1,2,3,4 


 B.  2.21.9.1.1 
 2W 
 Analog 


 Loop 
 Non-  Design/< 


 10 


 circuits/  Dis 
 patch/  MS( 
 hours) 


 1.47 
 0.02 
 1.82 
 0.74 
 1.53 
 0.02 
 1.37 
 0.02 


 B.  2.21.12.1.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/<  10 


 circuits/  Dis 
 patch/  MS( 
 hours) 


 1.49 
 14.88 


 1.83 
 60.14 


 1.59 


 1.41 
 0.02 
 1,2,4 


 B.  2.21.17.1.2 
 LNP 
 (Standalone)/<  10 


 circuits/  Non- 


 Dis 
 patch/  MS( 


 hours) 


 0.69 
 0.32 
 0.47 
 0.28 
 0.48 
 0.29 
 0.60 
 0.37 


 B.  2.21.18.1.1 
 Digital 
 Loop 
 < 
 DS1/<  10 


 circuits/  Dispatch/ 


 MS(  hours) 
 42.32 
 29.74 
 29.36 


 1.87 
 16.32 


 9.42 
 11.73 


 4.92 


 B.  2.21.19.1.1 
 Digital 
 Loop 
 >= 
 DS1/<  10 


 circuits/  Dispatch/ 


 MS(  hours) 
 218.93 
 20.00 
 390.28 


 13.61 
 200.76 


 18.28 
 121.39 


 50.31 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Non-  Mechanized 


 [P-  5] 


 B.  2.22.2.1.1 
 Local 
 Interoffice 


 Transport/<  10 


 circuits/  Dis 
 patch/  MS( 
 hours) 


 21.07 
 36.80 
 19.34 
 2,3,4 


 B.  2.22.3.1.1 
 Loop 
 + 
 Port 


 Combinations/<  10  circuits/  Dis  patch/  MS(  hours) 


 12.71 
 9.13 
 19.89 


 15.23 


 B.  2.22.3.1.2 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Non- 


 Dis 
 patch/  MS( 


 hours) 


 6.27 
 4.52 
 3.54 
 8.20 


 B.  2.22.3.1.3 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Switch 
 Based 


 Orders/  MS 
 (hours) 


 2.87 
 2.30 
 1.15 
 8.18 


 B.  2.22.3.1.4 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Dispatch 


 In/  MS 
 (hours) 


 12.60 
 12.88 
 12.26 


 8.37 


 B.  2.22.3.2.1 
 Loop 
 + 
 Port 


 Combinations/>=  10  circuits/  Dis  patch/  MS(  hours) 


 0.02 
 22.58 


 1,2 


 B.  2.22.3.2.2 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Non- 


 Dis 
 patch/  MS( 


 hours) 


 20.75 
 3 


 B.  2.22.3.2.4 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Dispatch 


 In/  MS 
 (hours) 


 20.75 
 3 


 B.  2.22.4.1.1 
 Combo 
 Other/<  10 


 circuits/  Dis 
 patch/  MS( 
 hours) 


 24.37 
 44.48 
 49.22 
 2,3,4 


 D-  25 
274
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Mississippi 
 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  2.22.5.1.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/<  10 


 circuits/  Dis 
 patch/  MS( 
 hours) 


 19.87 
 9.53 
 15.99 


 12.59 


 B.  2.22.6.1.1 
 UNE 
 ISDN/<  10 


 circuits/  Dis 
 patch/  MS( 
 hours) 


 27.17 
 229.17 


 1,2 


 B.  2.22.8.1.1 
 2W 
 Analog 


 Loop 
 Design/<  10 


 circuits/  Dis 
 patch/  MS( 
 hours) 


 55.33 
 41.07 
 390.11 


 17.69 
 1,2,3,4 


 B.  2.22.9.1.1 
 2W 
 Analog 


 Loop 
 Non-  Design/< 


 10 


 circuits/  Dis 
 patch/  MS( 
 hours) 


 36.18 
 10.32 
 29.68 
 22.83 
 1,2,3,4 


 B.  2.22.10.1.1 
 2W 
 Analog 


 Loop 
 w/  INP 


 Design/<  10 


 circuits/  Dis 
 patch/  MS( 
 hours) 


 38.77 
 4 


 B.  2.22.11.1.1 
 2W 
 Analog 


 Loop 
 w/  INP 


 Non-  Design/< 


 10 


 circuits/  Dis 
 patch/  MS( 
 hours) 


 15.42 
 44.87 


 20.73 
 1,2,4 


 B.  2.22.12.1.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/<  10 


 circuits/  Dis 
 patch/  MS( 
 hours) 


 52.87 
 19.98 
 45.51 
 1,3,4 


 B.  2.22.13.1.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/< 


 10 


 circuits/  Dis 
 patch/  MS( 
 hours) 


 23.64 
 18.23 
 23.61 
 20.19 


 B.  2.22.13.2.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/>= 


 10 


 circuits/  Dis 
 patch/  MS( 
 hours) 


 37.32 


 1 


 B.  2.22.15.1.1 
 Other 
 Non-  Design/< 


 10 
 circuits/  Dispatch/ 


 MS(  hours) 


 24.04 
 18.39 
 17.94 
 19.74 


 B.  2.22.15.1.2 
 Other 
 Non-  Design/< 


 10 
 circuits/  Non- 


 Dis 
 patch/  MS( 


 hours) 


 0.53 
 2 


 B.  2.22.16.1.2 
 INP 
 (Standalone)/<  10 


 circuits/  Non- 


 Dis 
 patch/  MS( 


 hours) 


 18.92 
 3 


 B.  2.22.17.1.2 
 LNP 
 (Standalone)/<  10 


 circuits/  Non- 


 Dis 
 patch/  MS( 


 hours) 


 3.83 
 4.03 
 7.00 
 4.45 


 B.  2.22.17.2.2 
 LNP 
 (Standalone)/>=  10 


 circuits/  Non- 


 Dis 
 patch/  MS( 


 hours) 


 0.40 
 0.29 
 0.27 
 2,3,4 


 B.  2.22.18.1.1 
 Digital 
 Loop 
 < 
 DS1/<  10 


 circuits/  Dispatch/ 


 MS(  hours) 


 20.55 
 15.47 
 15.99 
 12.59 


 B.  2.22.19.1.1 
 Digital 
 Loop 
 >= 
 DS1/<  10 


 circuits/  Dispatch/ 


 MS(  hours) 


 39.73 
 33.50 
 45.78 
 35.40 
 4 


 Service 
 Order 
 Accuracy 


 [P-  11] 


 B.  2.34.1.1.1 
 Desi 
 gn 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 MS(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 D-  26 
275
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Mississippi 
 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  2.34.1.1.2 
 Design 
 (Specials)/<  10 


 circuits/  Non- 
 Dispatch/  MS(%) 


 100.00% 
 67.07% 
 69.33% 


 B.  2.34.1.2.1 
 Desi 
 gn 
 (Specials)/>=  10 


 circuits/  Dispatch/ 


 MS(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  2.34.1.2.2 
 Design 
 (Specials)/>=  10 


 circuits/  Non- 
 Dispatch/  MS(%) 


 100.00% 
 90.91% 
 3 


 B.  2.34.2.1.1 
 Loo  ps 
 Non-  Design/< 


 10 
 circuits/  Dispatch/ 


 MS(%) 


 98.18% 
 95.65% 
 96.00% 
 96.33% 


 B.  2.34.2.1.2 
 Loops 
 Non-  Design/< 


 10 
 circuits/  Non- 


 Dispatch/  MS(%) 


 99.09% 
 98.18% 
 100.00% 


 98.02% 


 B.  2.34.2.2.1 
 Loo  ps 
 Non-  Design/>= 


 10 
 circuits/  Dispatch/ 


 MS(%) 


 97.75% 
 89.81% 
 97.90% 
 97.73% 


 B.  2.34.2.2.2 
 Loops 
 Non-  Design/>= 


 10 
 circuits/  Non- 


 Dis 
 patch/  MS(%) 


 97.20% 
 97.98% 
 98.73% 
 97.53% 


 UNBUNDLED 
 NETWORK 
 ELEMENTS 


 - 
 MAINTENANCE 


 AND 
 REPAIR 


 Missed 
 Repair 
 Appointments 


 [M&  R- 
 1] 


 B.  3.1.2.1 
 Local 
 Interoffice 


 Trans  port/ 
 Dispatch/  MS(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 B.  3.1.2.2 
 Local 
 Interoffice 


 Trans  port/ 
 Non-  Dispatch/ 


 MS(%) 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 4 


 B.  3.1.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  Dispatch/ 


 MS(%) 
 4.42% 
 1.77% 
 4.60% 
 1.83% 
 5.44% 
 1.71% 
 5.41% 
 1.79% 


 B.  3.1.3.2 
 Loo  p 
 + 
 Port 


 Combinations/  Non- 


 Dispatch/  MS(%) 


 0.91% 
 0.97% 
 0.99% 
 0.40% 
 0.97% 
 0.00% 
 0.95% 
 0.36% 


 B.  3.1.4.1 
 Combo 
 Other/  Dis 


 patch/  MS(%) 


 4.33% 
 0.00% 
 4.52% 
 0.00% 
 5.32% 
 0.00% 
 5.32% 
 0.00% 
 2,3,4 


 B.  3.1.4.2 
 Combo 
 Other/  Non- 


 Dis  patch/ 
 MS(%) 


 4.33% 
 0.00% 
 4.52% 
 0.00% 
 5.32% 
 0.00% 
 5.32% 
 0.00% 


 2,4 


 B.  3.1.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Dispatch/ 


 MS(%) 
 44.44% 
 0.00% 
 42.98% 


 0.00% 
 40.22% 


 0.00% 
 44.34% 


 0.00% 
 2,3,4 


 B.  3.1.5.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Non- 


 Dispatch/  MS(%) 


 2.23% 
 0.00% 
 5.62% 
 0.00% 
 2.17% 
 0.00% 
 2.73% 
 0.00% 
 1,2,3,4 


 B.  3.1.6.1 
 UNE 
 ISDN/  Dis 


 patch/  MS(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 5.26% 
 0.00% 
 5.56% 
 0.00% 


 1,2 


 B.  3.1.6.2 
 UNE 
 ISDN/  Non- 


 Dis 
 patch/  MS(%) 


 5.56% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3,4 


 B.  3.1.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  Dispatch/ 


 MS(%) 


 4.42% 
 0.00% 
 4.60% 
 0.00% 
 5.44% 
 0.00% 
 5.41% 
 3.03% 


 B.  3.1.8.2 
 2W 
 Analo  g 


 Loop 
 Design/  Non- 


 Dispatch/  MS(%) 


 4.42% 
 0.00% 
 4.60% 
 0.00% 
 5.44% 
 0.00% 
 5.41% 
 0.00% 
 1,2,3,4 


 B.  3.1.9.1 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 Dispatch/  MS(%) 


 4.36% 
 0.00% 
 4.55% 
 0.00% 
 5.40% 
 0.00% 
 5.37% 
 0.00% 


 2,4 


 B.  3.1.9.2 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 Non-  Dispatch/ 


 MS(%) 
 0.76% 
 0.00% 
 0.90% 
 0.00% 
 0.94% 
 0.00% 
 0.89% 
 0.00% 


 B.  3.1.10.1 
 Other 
 Desi  gn/ 
 Dispatch/  MS(%) 


 0.52% 
 0.00% 
 0.68% 
 0.00% 
 0.31% 
 0.00% 
 1.21% 
 0.00% 


 B.  3.1.10.2 
 Other 
 Desi  gn/ 


 Non-  Dispatch/ 


 MS(%) 


 0.78% 
 0.00% 
 0.31% 
 0.00% 
 0.30% 
 0.00% 
 0.32% 
 0.00% 


 B.  3.1.11.1 
 Other 
 Non-  Desi 


 gn/  Dispatch/ 


 MS(%) 


 4.42% 
 25.00% 


 4.60% 
 0.00% 
 5.44% 
 0.00% 
 5.41% 
 50.00% 
 1,2,3,4 


 B.  3.1.11.2 
 Other 
 Non-  Desi 


 gn/  Non- 
 Dispatch/  MS(%) 


 0.91% 
 0.00% 
 0.99% 
 0.00% 
 0.97% 
 0.00% 
 0.95% 
 0.00% 


 1 


 Customer 
 Trouble 
 Report 
 Rate 
 [M&  R- 


 2] 


 D-  27 
276
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Mississippi 
 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  3.2.2.1 
 Local 
 Interoffice 


 Transport/  Dispatch/ 


 MS(%) 
 2.53% 
 0.00% 
 2.35% 
 0.00% 
 3.05% 
 0.00% 
 2.70% 
 0.00% 


 B.  3.2.2.2 
 Local 
 Interoffice 


 Trans  port/ 
 Non-  Dispatch/ 


 MS(%) 
 1.35% 
 0.00% 
 1.55% 
 0.00% 
 1.48% 
 0.00% 
 1.25% 
 2.94% 


 B.  3.2.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  Dispatch/ 


 MS(%) 
 2.02% 
 1.37% 
 2.23% 
 1.46% 
 2.30% 
 1.46% 
 2.32% 
 1.55% 


 B.  3.2.3.2 
 Loo  p 
 + 
 Port 


 Combinations/  Non- 


 Dispatch/  MS(%) 


 1.02% 
 0.38% 
 1.05% 
 0.45% 
 1.07% 
 0.36% 
 1.08% 
 0.48% 


 B.  3.2.4.1 
 Combo 
 Other/  Dis 


 patch/  MS(%) 


 1.77% 
 0.00% 
 1.95% 
 10.00% 


 2.01% 
 9.09% 
 2.03% 
 2.56% 


 B.  3.2.4.2 
 Combo 
 Other/  Non- 


 Dis  patch/ 
 MS(%) 


 1.77% 
 0.00% 
 1.95% 
 3.33% 
 2.01% 
 0.00% 
 2.03% 
 5.13% 


 B.  3.2.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Dispatch/ 


 MS(%) 
 1.07% 
 1.36% 
 1.32% 
 1.00% 
 1.37% 
 0.64% 
 1.53% 
 0.34% 


 B.  3.2.5.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Non- 


 Dispatch/  MS(%) 


 1.33% 
 0.11% 
 2.32% 
 0.22% 
 2.33% 
 0.32% 
 2.41% 
 0.57% 


 B.  3.2.6.1 
 UNE 
 ISDN/  Dis 


 patch/  MS(%) 


 0.50% 
 1.18% 
 0.70% 
 0.50% 
 0.64% 
 1.80% 
 0.61% 
 1.83% 


 B.  3.2.6.2 
 UNE 
 ISDN/  Non- 


 Dis 
 patch/  MS(%) 


 1.19% 
 0.17% 
 1.17% 
 0.17% 
 0.84% 
 0.66% 
 1.12% 
 1.00% 


 B.  3.2.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  Dispatch/ 


 MS(%) 


 2.02% 
 0.66% 
 2.23% 
 0.76% 
 2.30% 
 0.58% 
 2.32% 
 1.01% 


 B.  3.2.8.2 
 2W 
 Analo  g 


 Loop 
 Design/  Non- 


 Dispatch/  MS(%) 


 2.02% 
 0.27% 
 2.23% 
 0.06% 
 2.30% 
 0.09% 
 2.32% 
 0.06% 


 B.  3.2.9.1 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 Dispatch/  MS(%) 


 2.15% 
 0.00% 
 2.38% 
 0.48% 
 2.46% 
 0.00% 
 2.48% 
 0.33% 


 B.  3.2.9.2 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 Non-  Dispatch/ 


 MS(%) 
 0.98% 
 0.00% 
 1.03% 
 0.00% 
 1.06% 
 0.00% 
 1.07% 
 0.00% 


 B.  3.2.10.1 
 Other 
 Desi  gn/ 
 Dispatch/  MS(%) 


 0.28% 
 0.00% 
 0.29% 
 0.00% 
 0.32% 
 0.00% 
 0.33% 
 0.00% 
 1,2,3,4 


 B.  3.2.10.2 
 Other 
 Desi  gn/ 


 Non-  Dispatch/ 


 MS(%) 


 0.32% 
 0.00% 
 0.32% 
 0.00% 
 0.32% 
 0.00% 
 0.31% 
 0.00% 
 1,2,3,4 


 B.  3.2.11.1 
 Other 
 Non-  Desi 


 gn/  Dispatch/ 


 MS(%) 


 2.02% 
 3.74% 
 2.23% 
 7.69% 
 2.30% 
 3.41% 
 2.32% 
 4.35% 


 B.  3.2.11.2 
 Other 
 Non-  Desi 


 gn/  Non- 
 Dispatch/  MS(%) 


 1.02% 
 0.93% 
 1.05% 
 0.00% 
 1.07% 
 0.00% 
 1.08% 
 0.00% 


 Maintenance 
 Average 
 Duration 


 [M&  R- 
 3] 


 B.  3.3.2.1 
 Local 
 Interoffice 


 Trans  port/ 
 Dispatch/  MS( 


 hours) 


 3.72 
 0.00 
 4.07 
 0.00 
 4.06 
 0.00 
 4.01 
 0.00 


 B.  3.3.2.2 
 Local 
 Interoffice 


 Transport/  Non- 


 Dispatch/  MS( 
 hours) 
 2.00 
 0.00 
 2.80 
 0.00 
 1.74 
 0.00 
 1.97 
 2.85 


 4 


 B.  3.3.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  Dispatch/ 


 MS( 
 hours) 


 19.44 
 14.32 
 20.31 
 13.00 
 22.24 
 12.75 
 23.62 
 15.19 


 B.  3.3.3.2 
 Loop 
 + 
 Port 


 Combinations/  Non- 


 Dispatch/  MS( 
 hours) 
 7.66 
 3.96 
 8.35 
 3.53 
 9.38 
 4.72 
 10.02 


 5.07 


 B.  3.3.4.1 
 Combo 
 Other/  Dis 


 patch/  MS( 


 hours) 


 19.10 
 0.00 
 19.98 


 5.17 
 21.85 


 4.15 
 23.19 


 6.35 
 2,3,4 


 B.  3.3.4.2 
 Combo 
 Other/  Non- 


 Dis  patch/ 
 MS( 
 hours) 


 19.10 
 0.00 
 19.98 


 1.23 
 21.85 


 0.00 
 23.19 


 5.23 
 2,4 


 B.  3.3.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Dispatch/ 


 MS(  hours) 
 50.88 
 5.49 
 35.89 


 4.61 
 32.65 


 4.20 
 32.38 


 4.45 
 2,3,4 


 B.  3.3.5.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Non- 


 Dis 
 patch/  MS( 


 hours) 


 3.73 
 3.35 
 5.40 
 4.66 
 2.93 
 1.16 
 1.72 
 4.47 
 1,2,3,4 


 B.  3.3.6.1 
 UNE 
 ISDN/  Dis 


 patch/  MS( 
 hours) 


 4.98 
 6.26 
 5.46 
 5.95 
 6.69 
 5.27 
 7.35 
 6.27 
 1,2 


 D-  28 
277
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Mississippi 
 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  3.3.6.2 
 UNE 
 ISDN/  Non- 


 Dispatch/  MS( 


 hours) 


 6.11 
 1.47 
 1.82 
 1.33 
 3.03 
 1.55 
 5.17 
 6.61 
 1,2,3,4 


 B.  3.3.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  Dispatch/ 


 MS( 
 hours) 


 19.44 
 4.87 
 20.31 


 3.52 
 22.24 


 5.44 
 23.62 


 6.99 


 B.  3.3.8.2 
 2W 
 Analog 


 Loop 
 Design/  Non- 


 Dispatch/  MS( 


 hours) 
 19.44 
 2.36 
 20.31 


 3.23 
 22.24 


 1.42 
 23.62 


 5.71 
 1,2,3,4 


 B.  3.3.9.1 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 Dispatch/  MS( 


 hours) 
 19.57 
 0.00 
 20.46 


 2.00 
 22.42 


 0.00 
 23.79 


 4.00 
 2,4 


 B.  3.3.9.2 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 Non- 


 Dis 
 patch/  MS( 


 hours) 


 8.19 
 0.00 
 8.79 
 0.00 
 10.03 


 0.00 
 10.70 


 0.00 


 B.  3.3.10.1 
 Other 
 Desi  gn/ 
 Dispatch/  MS( 


 hours) 


 4.84 
 0.00 
 5.09 
 0.00 
 5.21 
 0.00 
 5.50 
 0.00 


 B.  3.3.10.2 
 Other 
 Desi  gn/ 


 Non-  Dispatch/ 


 MS( 
 hours) 


 2.95 
 0.00 
 2.25 
 0.00 
 2.20 
 0.00 
 2.50 
 0.00 


 B.  3.3.11.1 
 Other 
 Non-  Desi 


 gn/  Dispatch/ 


 MS( 
 hours) 


 19.44 
 7.78 
 20.31 


 13.71 
 22.24 
 11.00 
 23.62 
 24.75 
 1,2,3,4 


 B.  3.3.11.2 
 Other 
 Non-  Desi 


 gn/  Non- 
 Dispatch/  MS( 


 hours) 


 7.66 
 2.73 
 8.35 
 0.00 
 9.38 
 0.00 
 10.02 


 0.00 
 1 


 % 
 Repeat 


 Troubles 


 within 
 30 
 Days 


 [M&  R- 


 4] 


 B.  3.4.2.1 
 Local 
 Interoffice 


 Trans  port/ 
 Dispatch/  MS(%) 


 28.17% 
 0.00% 
 22.73% 


 0.00% 
 28.32% 


 0.00% 
 25.48% 


 0.00% 


 B.  3.4.2.2 
 Local 
 Interoffice 


 Trans  port/ 
 Non-  Dispatch/ 


 MS(%) 
 27.63% 
 0.00% 
 18.39% 


 0.00% 
 14.29% 


 0.00% 
 15.07% 


 0.00% 


 4 


 B.  3.4.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  Dispatch/ 


 MS(%) 
 16.81% 
 12.11% 
 19.07% 
 13.81% 
 17.64% 
 10.85% 
 19.39% 
 14.53% 


 B.  3.4.3.2 
 Loo  p 
 + 
 Port 


 Combinations/  Non- 


 Dispatch/  MS(%) 


 14.59% 
 16.02% 
 15.84% 
 13.20% 
 15.44% 
 11.88% 
 17.09% 
 12.36% 


 B.  3.4.4.1 
 Combo 
 Other/  Dis 


 patch/  MS(%) 


 16.83% 
 0.00% 
 19.07% 
 33.33% 
 17.68% 
 0.00% 
 19.56% 


 0.00% 
 2,3,4 


 B.  3.4.4.2 
 Combo 
 Other/  Non- 


 Dis  patch/ 
 MS(%) 


 16.83% 
 0.00% 
 19.07% 


 0.00% 
 17.68% 


 0.00% 
 19.56% 
 50.00% 


 2,4 


 B.  3.4.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Dispatch/ 


 MS(%) 
 11.67% 
 0.00% 
 20.66% 
 11.11% 
 24.72% 
 0.00% 
 26.91% 


 0.00% 
 2,3,4 


 B.  3.4.5.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Non- 


 Dispatch/  MS(%) 


 16.52% 
 0.00% 
 23.89% 


 0.00% 
 23.04% 


 0.00% 
 29.63% 


 0.00% 
 1,2,3,4 


 B.  3.4.6.1 
 UNE 
 ISDN/  Dis 


 patch/  MS(%) 


 0.00% 
 0.00% 
 14.29% 


 0.00% 
 10.53% 
 27.27% 
 27.78% 
 27.27% 


 1,2 


 B.  3.4.6.2 
 UNE 
 ISDN/  Non- 


 Dis 
 patch/  MS(%) 


 13.89% 
 0.00% 
 17.14% 


 0.00% 
 8.00% 
 25.00% 


 6.06% 
 33.33% 
 1,2,3,4 


 B.  3.4.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  Dispatch/ 


 MS(%) 


 16.81% 
 13.64% 
 19.07% 
 4.00% 
 17.64% 


 5.26% 
 19.39% 


 6.06% 


 B.  3.4.8.2 
 2W 
 Analo  g 


 Loop 
 Design/  Non- 


 Dispatch/  MS(%) 


 16.81% 
 0.00% 
 19.07% 


 0.00% 
 17.64% 
 33.33% 
 19.39% 
 0.00% 
 1,2,3,4 


 B.  3.4.9.1 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 Dispatch/  MS(%) 


 16.88% 
 0.00% 
 19.16% 


 0.00% 
 17.70% 


 0.00% 
 19.44% 


 0.00% 
 2,4 


 B.  3.4.9.2 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 Non-  Dispatch/ 


 MS(%) 
 14.51% 
 0.00% 
 16.11% 


 0.00% 
 15.58% 


 0.00% 
 17.35% 


 0.00% 


 B.  3.4.10.1 
 Other 
 Desi 
 gn/  Dispatch/ 


 MS(%) 


 17.71% 
 0.00% 
 18.85% 


 0.00% 
 19.45% 


 0.00% 
 26.55% 


 0.00% 


 B.  3.4.10.2 
 Other 
 Desi 
 gn/  Non- 


 Dispatch/  MS(%) 


 17.70% 
 0.00% 
 19.16% 


 0.00% 
 16.57% 


 0.00% 
 17.70% 


 0.00% 


 B.  3.4.11.1 
 Other 
 Non-  Desi 


 gn/  Dispatch/ 


 MS(%) 


 16.81% 
 25.00% 
 19.07% 
 14.29% 
 17.64% 
 0.00% 
 19.39% 


 0.00% 
 1,2,3,4 


 B.  3.4.11.2 
 Other 
 Non-  Desi 


 gn/  Non- 
 Dispatch/  MS(%) 


 14.59% 
 0.00% 
 15.84% 


 0.00% 
 15.44% 


 0.00% 
 17.09% 


 0.00% 


 1 


 Out 
 of 
 Service 


 > 
 24 


 hours 


 [M&  R- 


 5] 


 D-  29 
278
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Mississippi 
 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  3.5.2.1 
 Local 
 Interoffice 


 Transport/  Dispatch/ 


 MS(%) 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 B.  3.5.2.2 
 Local 
 Interoffice 


 Trans  port/ 
 Non-  Dispatch/ 


 MS(%) 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 4 


 B.  3.5.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  Dispatch/ 


 MS(%) 
 26.22% 
 18.44% 
 26.92% 
 12.12% 
 29.58% 
 13.65% 
 32.31% 
 19.16% 


 B.  3.5.3.2 
 Loo  p 
 + 
 Port 


 Combinations/  Non- 


 Dispatch/  MS(%) 


 13.13% 
 3.06% 
 13.16% 


 2.24% 
 17.00% 


 6.73% 
 19.19% 


 4.57% 


 B.  3.5.4.1 
 Combo 
 Other/  Dis 


 patch/  MS(%) 


 25.30% 
 0.00% 
 26.06% 


 0.00% 
 28.56% 


 0.00% 
 31.21% 


 0.00% 
 2,3,4 


 B.  3.5.4.2 
 Combo 
 Other/  Non- 


 Dis  patch/ 
 MS(%) 


 25.30% 
 0.00% 
 26.06% 


 0.00% 
 28.56% 


 0.00% 
 31.21% 


 0.00% 
 2,4 


 B.  3.5.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Dispatch/ 


 MS(%) 
 44.44% 
 0.00% 
 42.98% 


 0.00% 
 40.22% 


 0.00% 
 44.34% 


 0.00% 
 2,3,4 


 B.  3.5.5.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Non- 


 Dispatch/  MS(%) 


 2.23% 
 0.00% 
 5.62% 
 0.00% 
 2.17% 
 0.00% 
 2.73% 
 0.00% 
 1,2,3,4 


 B.  3.5.6.1 
 UNE 
 ISDN/  Dis 


 patch/  MS(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 5.26% 
 0.00% 
 5.56% 
 0.00% 


 1,2 


 B.  3.5.6.2 
 UNE 
 ISDN/  Non- 


 Dis 
 patch/  MS(%) 


 5.56% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3,4 


 B.  3.5.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  Dispatch/ 


 MS(%) 


 26.22% 
 0.00% 
 26.92% 


 0.00% 
 29.58% 


 0.00% 
 32.31% 


 3.03% 


 B.  3.5.8.2 
 2W 
 Analo  g 


 Loop 
 Design/  Non- 


 Dispatch/  MS(%) 


 26.22% 
 0.00% 
 26.92% 


 0.00% 
 29.58% 


 0.00% 
 32.31% 


 0.00% 
 1,2,3,4 


 B.  3.5.9.1 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 Dispatch/  MS(%) 


 26.51% 
 0.00% 
 27.20% 


 0.00% 
 29.84% 


 0.00% 
 32.59% 


 0.00% 
 2,4 


 B.  3.5.9.2 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 Non-  Dispatch/ 


 MS(%) 
 13.25% 
 0.00% 
 13.48% 


 0.00% 
 17.58% 


 0.00% 
 19.90% 


 0.00% 


 B.  3.5.10.1 
 Other 
 Desi 
 gn/  Dispatch/ 


 MS(%) 


 0.52% 
 0.00% 
 0.68% 
 0.00% 
 0.31% 
 0.00% 
 1.21% 
 0.00% 


 B.  3.5.10.2 
 Other 
 Desi  gn/ 


 Non-  Dispatch/ 


 MS(%) 


 0.78% 
 0.00% 
 0.31% 
 0.00% 
 0.30% 
 0.00% 
 0.32% 
 0.00% 


 B.  3.5.11.1 
 Other 
 Non-  Desi 


 gn/  Dispatch/ 


 MS(%) 


 26.22% 
 0.00% 
 26.92% 


 0.00% 
 29.58% 


 0.00% 
 32.31% 
 25.00% 
 1,2,3,4 


 B.  3.5.11.2 
 Other 
 Non-  Desi 


 gn/  Non- 
 Dispatch/  MS(%) 


 13.13% 
 0.00% 
 13.16% 


 0.00% 
 17.00% 


 0.00% 
 19.19% 


 0.00% 


 1 


 UNBUNDLED 
 NETWORK 
 ELEMENTS 


 - 
 BILLING 


 Invoice 
 Accuracy 


 [B-  1] 


 B.  4.1 
 MS 
 (%) 


 98.86% 
 96.50% 
 99.03% 
 95.07% 
 98.60% 
 99.85% 
 98.67% 
 100.00% 


 Mean 
 Time 
 to 
 Deliver 


 Invoices 


 - 
 CRIS 


 [B-  2] 


 B.  4.2 
 Re  gion( 
 business 


 days) 


 3.68 
 7.29 
 3.86 
 4.97 
 3.47 
 3.78 
 3.82 
 3.46 


 LOCAL 
 INTERCONNECTION 


 TRUNKS 
 - 
 ORDERING 


 % 
 Rejected 


 Service 
 Requests 


 [O-  7] 


 C.  1.1 
 Local 
 Interconnection 


 Trunks/  MS 
 (%) 


 40.00% 
 50.00% 
 72.73% 
 75.00% 


 Reject 
 Interval 


 [O-  8] 


 C.  1.2 
 Local 
 Interconnection 


 Trunks/  MS 
 (%) 


 100.00% 
 100.00% 
 100.00% 


 1,2,3 


 FOC 
 Timeliness 


 [O-  9] 


 C.  1.3 
 Local 
 Interconnection 


 Trunks/  MS 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 3,4 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 [O-  11] 


 D-  30 
279
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Mississippi 
 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 C.  1.4 
 Local 
 Interconnection 


 Trunks/  MS(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 LOCAL 
 INTERCONNECTION 


 TRUNKS 
 - 
 PROVISIONING 


 Order 
 Completion 


 Interval 
 [P-  4] 


 C.  2.1 
 Local 
 Interconnection 


 Trunks/  MS 
 (days) 


 23.12 
 6.00 
 28.63 


 23.00 
 25.31 


 6.00 
 32.87 


 12.50 
 1,2,3,4 


 Held 
 Orders 


 [P-  1] 


 C.  2.2 
 Local 
 Interconnection 


 Trunks/  MS 
 (days) 


 0.00 
 0.00 
 0.00 
 0.00 
 0.00 
 0.00 
 0.00 
 0.00 


 % 
 Jeopardies 


 [P-  2] 


 C.  2.3 
 Local 
 Interconnection 


 Trunks/  MS 
 (%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3,4 


 % 
 Missed 


 Installation 


 Appointments 


 [P-  3] 


 C.  2.5 
 Local 
 Interconnection 


 Trunks/  MS 
 (%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3,4 


 % 
 Provisioning 


 Troubles 
 within 
 30 
 Days 


 [P-  9] 


 C.  2.6 
 Local 
 Interconnection 


 Trunks/  MS 
 (%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 Average 
 Completion 


 Notice 
 Interval 


 [P-  5] 


 C.  2.7 
 Local 
 Interconnection 


 Trunks/  MS 
 (hours) 


 24.64 
 18.24 
 133.06 


 2.34 
 109.90 


 0.02 
 36.77 


 8.57 
 1,2,3,4 


 Total 
 Service 


 Order 
 Cycle 
 Time 
 [P-  10] 


 C.  2.8 
 Local 
 Interconnection 


 Trunks/  MS 
 (days) 


 8.47 
 24.13 


 7.30 
 14.02 
 1,2,3,4 


 % 
 Completions 


 w/  o 
 Notice 


 or 
 < 
 24 


 hours 


 [P-  6] 


 C.  2.10.1 
 Local 
 Interconnection 


 Trunks/  Dis 
 patch/  MS(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3,4 


 Service 
 Order 
 Accuracy 


 [P-  11] 


 C.  2.11.1.1 
 Local 
 Interconnection 


 Trunks/<  10 


 circuits/  Dis 
 patch/  MS(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 C.  2.11.1.2 
 Local 
 Interconnection 


 Trunks/<  10 
 circuits/  Non- 


 Dis 
 patch/  MS(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 C.  2.11.2.1 
 Local 
 Interconnection 


 Trunks/>=  10 


 circuits/  Dis 
 patch/  MS(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,4 


 C.  2.11.2.2 
 Local 
 Interconnection 


 Trunks/>=  10 
 circuits/  Non- 


 Dis 
 patch/  MS(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2 


 LOCAL 
 INTERCONNECTION 


 TRUNKS 
 - 
 MAINTENANCE 


 AND 
 REPAIR 


 Missed 
 Repair 
 Appointments 


 [M&  R- 
 1] 


 C.  3.1.1 
 Local 
 Interconnection 


 Trunks/  Dis 
 patch/  MS(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 C.  3.1.2 
 Local 
 Interconnection 


 Trunks/  Non- 
 Dispatch/  MS(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 Customer 
 Trouble 
 Report 
 Rate 
 [M&  R- 


 2] 


 D-  31 
280
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Mississippi 
 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 C.  3.2.1 
 Local 
 Interconnection 


 Trunks/  Dispatch/ 


 MS(%) 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 C.  3.2.2 
 Local 
 Interconnection 


 Trunks/  Non- 
 Dispatch/  MS(%) 


 0.03% 
 0.00% 
 0.04% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 Maintenance 
 Average 
 Duration 


 [M&  R- 
 3] 


 C.  3.3.1 
 Local 
 Interconnection 


 Trunks/  Dispatch/ 


 MS(  hours) 


 0.00 
 0.00 
 0.00 
 0.00 
 0.00 
 0.00 
 0.00 
 0.00 


 C.  3.3.2 
 Local 
 Interconnection 


 Trunks/  Non- 


 Dis 
 patch/  MS( 


 hours) 


 0.46 
 0.00 
 0.22 
 0.00 
 3.52 
 0.00 
 2.03 
 0.00 


 % 
 Repeat 


 Troubles 


 within 
 30 
 Days 


 [M&  R- 


 4] 


 C.  3.4.1 
 Local 
 Interconnection 


 Trunks/  Dis 
 patch/  MS(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 C.  3.4.2 
 Local 
 Interconnection 


 Trunks/  Non- 
 Dispatch/  MS(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 Out 
 of 
 Service 


 > 
 24 


 hours 


 [M&  R- 


 5] 


 C.  3.5.1 
 Local 
 Interconnection 


 Trunks/  Dis 
 patch/  MS(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 C.  3.5.2 
 Local 
 Interconnection 


 Trunks/  Non- 
 Dispatch/  MS(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 LOCAL 
 INTERCONNECTION 


 TRUNKS 
 - 
 BILLING 


 Invoice 
 Accuracy 


 [B-  1] 


 C.  4.1 
 MS 
 (%) 


 98.86% 
 98.47% 
 99.03% 
 99.48% 
 98.60% 
 99.82% 
 98.67% 
 99.87% 


 Mean 
 Time 
 to 
 Deliver 


 Invoices 


 - 
 CABS 


 [B-  2] 


 C.  4.2 
 Re  gion( 
 calendar 


 days) 


 4.84 
 4.54 
 3.94 
 3.89 
 4.96 
 4.92 
 4.54 
 4.29 


 LOCAL 
 INTERCONNECTION 


 TRUNKS 
 - 
 TRUNK 


 BLOCKING 


 Trunk 
 Group 
 Performance 


 - 
 Aggregate 


 [TGP-  1] 


 C.  5.1 
 MS 


 0 
 0 
 0 
 0 


 OPERATIONS 
 SUPPORT 
 SYSTEMS 
 - 
 PRE-  ORDERING 


 % 
 Interface 


 Availability 


 - 
 CLEC 


 [OSS-  2] 


 D.  1.1.1 
 EDI/  Re 
 gion(%) 


 99.71% 
 100.00% 


 99.64% 
 100.00% 


 D.  1.1.2 
 HAL/  Re 
 gion(%) 


 100.00% 
 100.00% 


 D.  1.1.3 
 LENS/  Re 
 gion(%) 


 99.99% 
 99.98% 
 99.85% 
 99.76% 


 D.  1.1.4 
 LEO 
 MAINFRAME/  Re 


 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 D.  1.1.6 
 LESOG/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 D.  1.1.7 
 TAG/  Re 
 gion(%) 


 100.00% 
 99.95% 
 99.99% 
 99.86% 


 D.  1.1.8 
 PSIMS/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 D-  32 
281
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Mississippi 
 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 % 
 Interface 


 Availability 


 - 
 BST 


 & 
 CLEC 


 [OSS-  2] 


 D.  1.2.1 
 ATLAS/  COFFI/ 


 Re 
 gion(%) 


 100.00% 
 100.00% 


 D.  1.2.2 
 BOCRIS/  Re 
 gion(%) 


 100.00% 
 100.00% 
 99.96% 
 99.99% 


 D.  1.2.3 
 DSAP/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.98% 


 D.  1.2.4 
 RSAG/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.99% 


 D.  1.2.5 
 SOCS/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.99% 


 D.  1.2.6 
 SONGS/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.86% 


 D.  1.2.7 
 DOE/  Re 
 gion(%) 


 99.99% 
 99.99% 
 99.99% 
 99.26% 


 D.  1.2.8 
 LNP 
 Gatewa 


 y/  Region(%) 


 100.00% 
 99.99% 
 100.00% 


 99.49% 


 D.  1.2.9 
 COG/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.48% 


 D.  1.2.10 
 DOM/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.99% 


 D.  1.2.11 
 SOG/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 D.  1.2.1- 
 new 
 ATLAS/  Re 


 gion 
 (%) 


 100.00% 
 99.99% 


 D.  1.2.2- 
 new 
 COFFI/  Re 


 gion 
 (%) 


 100.00% 
 99.99% 


 Average 
 Response 


 Interval 
 - 
 CLEC 


 (LENS) 


 (BST 
 Measure 


 Includes 
 Additional 


 2 
 Seconds) 


 [OSS-  1] 


 D.  1.3.1.1 
 RSAG, 
 b 
 y 


 TN/  Region( 


 seconds) 


 1440.12 
 0.91 
 1782.46 


 1.11 
 2.87 
 1.20 
 2.88 
 1.02 


 D.  1.3.1.2 
 RSAG, 
 b 
 y 


 TN/  Region( 


 seconds) 


 2.96 
 0.91 
 2.95 
 1.11 
 2.94 
 1.20 
 2.91 
 1.02 


 D.  1.3.2.1 
 RSAG, 
 b 
 y 
 ADDR/  Region( 


 seconds) 


 712.69 
 0.91 
 1204.18 


 1.02 
 2.99 
 1.10 
 3.03 
 0.93 


 D.  1.3.2.2 
 RSAG, 
 b 
 y 
 ADDR/  Region( 


 seconds) 


 4.82 
 0.91 
 4.86 
 1.02 
 4.77 
 1.10 
 4.76 
 0.93 


 D.  1.3.3.1 
 ATLAS/  Re 
 gion( 
 seconds) 


 1330.23 
 0.88 
 2.95 
 0.88 
 2.95 
 0.88 
 3.01 
 0.80 


 D.  1.3.3.2 
 ATLAS/  Re 
 gion( 
 seconds) 


 2.61 
 0.88 
 2.61 
 0.88 
 2.60 
 0.88 
 2.61 
 0.80 


 D.  1.3.4.1 
 DSAP/  Re 
 gion( 
 seconds) 


 2.68 
 0.53 
 2.70 
 0.57 
 2.71 
 0.53 
 2.71 
 0.52 


 D.  1.3.4.2 
 DSAP/  Re 
 gion( 
 seconds) 


 2.58 
 0.53 
 2.58 
 0.57 
 2.57 
 0.53 
 2.57 
 0.52 


 D.  1.3.5.1 
 CRSECSRL/  Re 


 gion( 
 seconds) 


 3.20 
 1.08 
 212.02 


 1.25 
 3.21 
 2.12 
 3.24 
 1.14 


 D.  1.3.5.2 
 CRSECSRL/  Re 


 gion( 
 seconds) 


 2.95 
 1.08 
 2.91 
 1.25 
 2.87 
 2.12 
 2.95 
 1.14 


 D.  1.3.6.1 
 COFFI/  Re 
 gion( 
 seconds) 


 4.46 
 0.63 
 4.40 
 0.67 
 4.60 
 0.63 
 4.35 
 0.64 


 D.  1.3.6.2 
 COFFI/  Re 
 gion( 
 seconds) 


 3.81 
 0.63 
 3.92 
 0.67 
 7.28 
 0.63 
 3.73 
 0.64 


 D.  1.3.7.1 
 PSIMS/  ORB/ 
 Re 
 gion( 


 seconds) 


 4.46 
 0.03 
 4.40 
 0.04 
 4.60 
 0.04 
 4.35 
 0.04 


 D.  1.3.7.2 
 PSIMS/  ORB/ 
 Re 
 gion( 


 seconds) 


 3.81 
 0.03 
 3.92 
 0.04 
 7.28 
 0.04 
 3.73 
 0.04 


 Average 
 Response 


 Interval 
 - 
 CLEC 


 (TAG) 
 (BST 
 Measure 


 Includes 
 Additional 


 2 
 Seconds) 


 [OSS-  1] 


 D.  1.4.1.1 
 RSAG, 
 b 
 y 


 TN/  Region( 


 seconds) 


 1440.12 
 1.10 
 1782.46 


 1.31 
 2.87 
 1.60 
 2.88 
 1.52 


 D.  1.4.1.2 
 RSAG, 
 b 
 y 


 TN/  Region( 


 seconds) 


 2.96 
 1.10 
 2.95 
 1.31 
 2.94 
 1.60 
 2.91 
 1.52 


 D.  1.4.2.1 
 RSAG, 
 b 
 y 
 ADDR/  Region( 


 seconds) 


 712.69 
 1.62 
 1204.18 


 1.85 
 2.99 
 3.05 
 3.03 
 2.34 


 D-  33 
282
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Mississippi 
 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 D.  1.4.2.2 
 RSAG, 
 by 
 ADDR/  Region( 


 seconds) 


 4.82 
 1.62 
 4.86 
 1.85 
 4.77 
 3.05 
 4.76 
 2.34 


 D.  1.4.4.1 
 ATLAS 
 - 
 DID/  Re 


 gion( 
 seconds) 


 1.48 
 2.18 
 1.76 
 1.37 


 D.  1.4.4.2 
 ATLAS 
 - 
 DID/  Re 


 gion( 
 seconds) 


 1.48 
 2.18 
 1.76 
 1.37 


 D.  1.4.5.1 
 ATLAS 
 - 
 TN/  Re 


 gion( 
 seconds) 


 1330.23 
 1.35 
 2.95 
 1.56 
 2.95 
 1.86 
 3.01 
 1.89 


 D.  1.4.5.2 
 ATLAS 
 - 
 TN/  Re 


 gion( 
 seconds) 


 2.61 
 1.35 
 2.61 
 1.56 
 2.60 
 1.86 
 2.61 
 1.89 


 D.  1.4.6.1 
 DSAP/  Re 
 gion( 
 seconds) 


 2.68 
 1.58 
 2.70 
 1.71 
 2.71 
 1.74 
 2.71 
 1.83 


 D.  1.4.6.2 
 DSAP/  Re 
 gion( 
 seconds) 


 2.58 
 1.58 
 2.58 
 1.71 
 2.57 
 1.74 
 2.57 
 1.83 


 D.  1.4.7.1 
 TAG/  Re 
 gion( 
 seconds) 


 3.20 
 1.75 
 212.02 


 2.15 
 3.21 
 2.51 
 3.24 
 2.85 


 D.  1.4.7.2 
 TAG/  Re 
 gion( 
 seconds) 


 2.95 
 1.75 
 2.91 
 2.15 
 2.87 
 2.51 
 2.95 
 2.85 


 OPERATIONS 
 SUPPORT 
 SYSTEMS 
 - 
 MAINTENANCE 


 AND 
 REPAIR 


 % 
 Interface 


 Availability 


 - 
 CLEC 


 [OSS-  3] 


 D.  2.2.1 
 CLEC 
 TAFI/  Re 


 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 D.  2.2.2 
 ECTA/  Re 
 gion(%) 


 100.00% 
 99.95% 
 100.00% 


 99.86% 


 % 
 Interface 


 Availability 


 - 
 BST 


 & 
 CLEC 


 [OSS-  3] 


 D.  2.3.1 
 CRIS/  Re 
 gion(%) 


 100.00% 
 100.00% 
 99.96% 
 99.99% 


 D.  2.3.2 
 LMOS 
 HOST/  Re 


 gion(%) 


 100.00% 
 100.00% 
 99.91% 
 100.00% 


 D.  2.3.3 
 LNP/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.91% 


 D.  2.3.4 
 MARCH/  Re 
 gion(%) 


 100.00% 
 99.99% 
 100.00% 
 100.00% 


 D.  2.3.5 
 OSPCM/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 D.  2.3.6 
 Predictor/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.92% 


 D.  2.3.7 
 SOCS/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.99% 


 Average 
 Response 


 Interval 
 <= 
 4 
 Seconds 


 [OSS-  4] 


 D.  2.4.1 
 CRIS/  Re 
 gion(%) 


 94.91% 
 94.17% 
 94.75% 
 94.83% 
 95.12% 
 94.99% 
 94.95% 
 94.66% 


 D.  2.4.2 
 DLETH/  Re 
 gion(%) 


 3.07% 
 3.22% 
 3.14% 
 4.03% 
 3.16% 
 4.59% 
 2.58% 
 3.67% 


 D.  2.4.3 
 DLR/  Re 
 gion(%) 


 4.30% 
 2.41% 
 4.07% 
 2.41% 
 4.03% 
 3.36% 
 4.47% 
 7.51% 


 D.  2.4.4 
 LMOS/  Re 
 gion(%) 


 99.67% 
 99.69% 
 99.63% 
 99.59% 
 99.60% 
 99.60% 
 99.61% 
 99.58% 


 D.  2.4.5 
 LMOSu 
 pd/  Region(%) 


 78.95% 
 70.39% 
 76.71% 
 65.38% 
 78.49% 
 66.19% 
 79.21% 
 66.24% 


 D.  2.4.6 
 LNP/  Re 
 gion(%) 


 99.78% 
 99.37% 
 99.31% 
 99.09% 
 99.68% 
 99.19% 
 99.65% 
 98.81% 


 D.  2.4.7 
 MARCH/  Re 
 gion(%) 


 28.35% 
 33.16% 
 28.32% 
 26.44% 
 28.04% 
 31.69% 
 28.10% 
 29.64% 


 D.  2.4.8 
 OSPCM/  Re 
 gion(%) 


 23.94% 
 13.59% 
 27.25% 
 20.73% 
 31.23% 
 24.50% 
 33.15% 
 21.43% 


 D.  2.4.9 
 Predictor/  Re 
 gion(%) 


 15.78% 
 19.48% 
 15.03% 
 20.43% 
 13.82% 
 19.61% 
 12.71% 
 21.73% 


 D.  2.4.10 
 SOCS/  Re 
 gion(%) 


 99.84% 
 99.91% 
 99.83% 
 99.90% 
 99.85% 
 99.88% 
 99.81% 
 99.86% 


 D.  2.4.11 
 NIW/  Region(%) 


 82.97% 
 81.81% 
 84.38% 
 83.15% 
 84.01% 
 83.00% 
 82.83% 
 81.89% 


 D-  34 
283
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Mississippi 
 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 Average 
 Response 


 Interval 
 <= 
 10 
 Seconds 


 [OSS-  4] 


 D.  2.5.1 
 CRIS/  Re 
 gion(%) 


 98.99% 
 99.34% 
 98.97% 
 99.34% 
 99.05% 
 99.46% 
 99.02% 
 99.39% 


 D.  2.5.2 
 DLETH/  Re 
 gion(%) 


 78.81% 
 86.16% 
 78.96% 
 87.92% 
 79.20% 
 85.30% 
 77.66% 
 82.58% 


 D.  2.5.3 
 DLR/  Re 
 gion(%) 


 77.94% 
 92.02% 
 77.45% 
 91.98% 
 76.65% 
 88.18% 
 71.08% 
 41.67% 


 D.  2.5.4 
 LMOS/  Re 
 gion(%) 


 99.81% 
 99.86% 
 99.79% 
 99.82% 
 99.79% 
 99.84% 
 99.80% 
 99.85% 


 D.  2.5.5 
 LMOSu 
 pd/  Region(%) 


 90.95% 
 83.33% 
 89.31% 
 80.59% 
 90.04% 
 80.25% 
 90.59% 
 80.53% 


 D.  2.5.6 
 LNP/  Re 
 gion(%) 


 99.93% 
 99.87% 
 99.54% 
 99.72% 
 99.81% 
 99.63% 
 99.83% 
 99.52% 


 D.  2.5.7 
 MARCH/  Re 
 gion(%) 


 28.35% 
 33.16% 
 28.32% 
 26.44% 
 28.04% 
 31.69% 
 28.10% 
 29.64% 


 D.  2.5.8 
 OSPCM/  Re 
 gion(%) 


 96.89% 
 96.12% 
 97.38% 
 95.12% 
 97.81% 
 97.35% 
 98.41% 
 95.83% 


 D.  2.5.9 
 Predictor/  Re 
 gion(%) 


 15.78% 
 19.48% 
 15.03% 
 20.43% 
 13.82% 
 19.61% 
 12.71% 
 21.73% 


 D.  2.5.10 
 SOCS/  Re 
 gion(%) 


 99.99% 
 99.99% 
 99.99% 
 99.98% 
 99.98% 
 100.00% 


 99.98% 
 100.00% 


 D.  2.5.11 
 NIW/  Region(%) 


 99.17% 
 98.96% 
 99.49% 
 99.33% 
 99.39% 
 99.21% 
 99.42% 
 99.25% 


 Average 
 Response 


 Interval 
 > 
 10 


 Seconds 


 [OSS-  4] 


 D.  2.6.1 
 CRIS/  Re 
 gion(%) 


 1.01% 
 0.66% 
 1.03% 
 0.66% 
 0.95% 
 0.54% 
 0.98% 
 0.61% 


 D.  2.6.2 
 DLETH/  Re 
 gion(%) 


 21.19% 
 13.84% 
 21.04% 
 12.08% 
 20.80% 
 14.70% 
 22.34% 
 17.42% 


 D.  2.6.3 
 DLR/  Re 
 gion(%) 


 22.06% 
 7.98% 
 22.55% 


 8.02% 
 23.35% 
 11.82% 
 28.92% 
 58.33% 


 D.  2.6.4 
 LMOS/  Re 
 gion(%) 


 0.19% 
 0.14% 
 0.21% 
 0.18% 
 0.21% 
 0.16% 
 0.20% 
 0.15% 


 D.  2.6.5 
 LMOSu 
 pd/  Region(%) 


 9.05% 
 16.67% 
 10.69% 
 19.41% 
 9.96% 
 19.75% 


 9.41% 
 19.47% 


 D.  2.6.6 
 LNP/  Re 
 gion(%) 


 0.07% 
 0.13% 
 0.46% 
 0.28% 
 0.19% 
 0.37% 
 0.17% 
 0.48% 


 D.  2.6.7 
 MARCH/  Re 
 gion(%) 


 71.65% 
 66.84% 
 71.68% 
 73.56% 
 71.96% 
 68.31% 
 71.90% 
 70.36% 


 D.  2.6.8 
 OSPCM/  Re 
 gion(%) 


 3.11% 
 3.88% 
 2.62% 
 4.88% 
 2.19% 
 2.65% 
 1.59% 
 4.17% 


 D.  2.6.9 
 Predictor/  Re 
 gion(%) 


 84.22% 
 80.52% 
 84.97% 
 79.57% 
 86.18% 
 80.39% 
 87.29% 
 78.27% 


 D.  2.6.10 
 SOCS/  Re 
 gion(%) 


 0.01% 
 0.01% 
 0.01% 
 0.02% 
 0.02% 
 0.00% 
 0.02% 
 0.00% 


 D.  2.6.11 
 NIW/  Region(%) 


 0.83% 
 1.04% 
 0.51% 
 0.67% 
 0.61% 
 0.79% 
 0.58% 
 0.75% 


 COLLOCATION 
 - 
 COLLOCATION  Average  Response  Time  [C- 


 1] 


 E.  1.1.3 
 Ph 
 ysical 


 Cageless/  MS( 


 calendar 
 days) 


 4 
 3 


 1,2 


 Average 
 Arrangement 


 Time 
 [C-  2] 


 E.  1.2.1 
 Virtual-  Ordinar 


 y/  MS( 
 calendar 


 days) 


 E.  1.2.3 
 Physical 
 Caged/  MS( 


 calendar 
 days) 


 82 
 2 


 E.  1.2.4 
 Ph 
 ysical 


 Cageless/  MS( 


 calendar 
 days) 


 50 
 55 
 58 
 58 
 1,2,3,4 


 % 
 Due 


 Dates 


 Missed 


 [C-  3] 


 E.  1.3.1 
 Virtual/  MS 
 (%) 


 D-  35 
284
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Mississippi 
 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 E.  1.3.2 
 Physical/  MS(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3,4 


 GENERAL 
 - 
 FLOW 


 THROUGH  %  Flow  Through  Service 


 Requests 
 [O-  3] 


 F.  1.1.1 
 Summar  y/ 
 Region(%) 


 85.28% 
 86.05% 
 84.50% 
 85.96% 


 F.  1.1.2 
 A 
 ggregate/  Region(%) 


 85.28% 
 86.05% 
 84.50% 
 85.96% 


 F.  1.1.3 
 Residence/  Re 
 gion(%) 


 86.49% 
 87.39% 
 86.74% 
 88.58% 


 F.  1.1.4 
 Business/  Re 
 gion(%) 


 73.55% 
 71.89% 
 69.54% 
 73.74% 


 F.  1.1.5 
 UNE/  Re 
 gion(%) 


 83.88% 
 84.78% 
 82.57% 
 83.84% 


 % 
 Flow 


 Through 


 Service 
 Requests 


 - 
 Achieved 


 [O-  3] 


 F.  1.2.1 
 Summar  y/ 
 Region(%) 


 75.79% 
 77.51% 
 76.58% 
 78.96% 


 F.  1.2.2 
 A 
 ggregate/  Region(%) 


 75.79% 
 77.51% 
 76.58% 
 78.96% 


 F.  1.2.3 
 Residence/  Re 
 gion(%) 


 79.16% 
 80.53% 
 79.88% 
 81.68% 


 F.  1.2.4 
 Business/  Re 
 gion(%) 


 50.63% 
 51.15% 
 51.58% 
 53.42% 


 F.  1.2.5 
 UNE/  Re 
 gion(%) 


 72.17% 
 74.87% 
 74.12% 
 77.27% 


 % 
 Flow 


 Through 


 Service 
 Requests 


 - 
 LNP 


 [O-  3] 


 F.  1.3.1 
 Summar  y/ 
 Region(%) 


 92.25% 
 92.59% 
 89.75% 
 83.63% 


 F.  1.3.2 
 A 
 ggregate/  Region(%) 


 92.25% 
 92.59% 
 89.75% 
 83.63% 


 GENERAL 
 - 
 PRE-  ORDERING  Loop  Makeup 


 Inquiry 
 (Manual) 


 [PO-  1] 


 F.  2.1 
 Loo 
 ps/  MS(%) 


 10.00% 


 Loop 
 Makeup 


 Inquiry 
 (Electronic) 


 [PO-  2] 


 F.  2.2 
 Loo 
 ps/  MS(%) 


 99.23% 
 99.50% 
 99.90% 
 79.62% 


 GENERAL 
 - 
 ORDERING  Average  Speed 


 of 
 Answer 


 [O-  12] 


 F.  4.1 
 Re 
 gion( 


 seconds) 


 141.64 
 30.33 
 137.90 


 28.63 
 194.86 


 35.16 
 259.48 


 58.19 


 GENERAL 
 - 
 MAINTENANCE 


 CENTER 
 Average 
 Answer 
 Time 
 [M&  R- 


 6] 


 F.  5.1 
 Re 
 gion( 


 seconds) 


 43.10 
 26.35 
 41.00 
 23.60 
 64.68 
 25.99 
 52.80 
 28.04 


 GENERAL 
 - 
 OPERATOR 


 SERVICES 
 (TOLL) 


 Average 
 Speed 
 to 
 Answer 


 [OS-  1] 


 F.  6.1 
 MS 
 (seconds) 


 6.08 
 5.86 
 6.00 
 5.53 


 % 
 Answered 


 in 
 10 
 seconds 


 [OS-  2] 


 F.  6.2 
 MS 
 (%) 


 76.40% 
 77.20% 
 76.80% 
 78.80% 


 D-  36 
285
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Mississippi 
 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 GENERAL 
 - 
 DIRECTORY 


 ASSISTANCE 
 Average 
 Speed 
 to 
 Answer 


 [DA-  1] 


 F.  7.1 
 MS 
 (seconds) 


 4.26 
 4.80 
 5.06 
 4.54 


 % 
 Answered 


 in 
 12 
 seconds 


 [DA-  2] 


 F.  7.2 
 MS 
 (%) 


 90.90% 
 88.80% 
 87.90% 
 90.10% 


 GENERAL 
 - 
 BILLING  Usage  Data 


 Delivery 
 Accuracy 


 [B-  3] 


 F.  9.1 
 Re 
 gion(%) 


 100.00% 
 100.00% 
 97.75% 
 100.00% 


 95.22% 
 100.00% 
 100.00% 
 100.00% 


 Usage 
 Data 
 Delivery 


 Timeliness 


 [B-  5] 


 F.  9.2 
 Re 
 gion(%) 


 98.37% 
 93.14% 
 75.41% 
 94.80% 
 94.93% 
 97.64% 
 99.33% 
 99.38% 


 Usage 
 Data 
 Delivery 


 Completeness 


 [B-  4] 


 F.  9.3 
 Re 
 gion(%) 


 99.38% 
 99.89% 
 99.77% 
 99.54% 
 97.21% 
 99.95% 
 99.92% 
 99.91% 


 Mean 
 Time 
 to 
 Deliver 


 Usage 
 [B-  6] 


 F.  9.4 
 Re 
 gion( 


 days) 


 3.49 
 3.05 
 6.85 
 3.29 
 4.34 
 2.52 
 3.24 
 2.43 


 Recurring 
 Charge 
 Completeness 


 [B-  7] 


 F.  9.5.1 
 Resale/  MS 
 (%) 


 81.34% 
 98.45% 
 83.16% 
 47.87% 
 86.18% 
 94.89% 
 89.04% 
 99.47% 


 F.  9.5.2 
 UNE/  MS 
 (%) 


 99.43% 
 97.88% 
 98.66% 
 97.45% 


 F.  9.5.3 
 Interconnection/  MS 


 (%) 


 93.57% 
 100.00% 


 99.96% 
 88.52% 


 Non-  Recurring 
 Charge 
 Completeness 


 [B-  8] 


 F.  9.6.1 
 Resale/  MS 
 (%) 


 93.31% 
 95.16% 
 73.62% 
 88.16% 
 86.41% 
 98.04% 
 86.28% 
 98.65% 


 F.  9.6.2 
 UNE/  MS 
 (%) 


 98.99% 
 98.45% 
 96.68% 
 97.94% 


 F.  9.6.3 
 Interconnection/  MS 


 (%) 


 70.18% 
 98.16% 
 96.24% 
 96.49% 


 GENERAL 
 - 
 CHANGE 


 MANAGEMENT  %  Software  Release  Notices  Sent 


 On 
 Time 


 [CM-  1] 


 F.  10.1 
 MS 
 (%) 


 100.00% 
 100.00% 


 2,3 


 % 
 Change 


 Management 


 Documentation 


 Sent 
 On 
 Time 


 [CM-  3A] 


 F.  10.3 
 MS 
 (%) 


 100.00% 
 100.00% 
 1,4 


 % 
 Change 


 Management 


 Documentation 


 (Defects, 
 Corrections, 


 etc.) 
 Sent 
 On 
 Time 


 [CM-  3B] 


 F.  10.4 
 MS 
 (%) 


 77.78% 
 2 


 Average 
 Documentation 


 Release 
 Delay 
 Days 
 [CM-  4] 


 F.  10.5 
 MS 
 (average)  %  CLEC  Interface 


 Outages 
 Sent 
 within 


 15 
 Minutes 


 [CM-  5] 


 F.  10.6 
 MS 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 D-  37 
286
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Mississippi 
 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 GENERAL 
 - 
 NEW 


 BUSINESS 


 REQUESTS 


 % 
 New 


 Business 


 Requests 
 Processed 


 within 
 30 
 Business 


 Days 
 [BFR-  1] 


 F.  11.1 
 Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 % 
 Quotes 


 Provided 


 within 
 X 
 Business 


 Days 
 [BFR-  2A] 


 F.  11.2.1 
 Re 
 gion(%) 


 100.00% 
 100.00% 
 1,3 


 F.  11.2.3 
 Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 GENERAL 
 - 
 ORDERING  Acknowledgement 


 Message 
 Timeliness 


 [O-  1] 


 F.  12.1.1 
 EDI/  Re 
 gion(%) 


 99.97% 
 99.99% 
 100.00% 
 100.00% 


 F.  12.1.2 
 TAG/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 Acknowledgement 
 Message 
 Completeness 


 [O-  2] 


 F.  12.2.1 
 EDI/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.62% 


 F.  12.2.2 
 TAG/  Re 
 gion(%) 


 100.00% 
 100.00% 
 99.99% 
 100.00% 


 GENERAL 
 - 
 DATABASE 


 UPDATES 
 Average 
 Database 


 Update 
 Interval 


 [D-  1] 


 F.  13.1.1 
 LIDB/  MS 
 (hours) 


 1.12 
 1.12 
 0.44 
 0.44 
 0.35 
 0.35 
 1.10 
 1.10 


 F.  13.1.2 
 Director  y 
 Listings/  MS( 


 hours) 


 0.10 
 0.10 
 0.09 
 0.09 
 0.10 
 0.10 
 0.11 
 0.11 


 F.  13.1.3 
 Director  y 
 Assistance/  MS( 


 hours) 


 3.47 
 3.46 
 3.92 
 3.92 
 3.59 
 3.58 
 5.48 
 5.38 


 % 
 Update 


 Accuracy 


 [D-  2] 


 F.  13.2.1 
 LIDB/  MS 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 93.48% 


 F.  13.2.2 
 Director  y 
 Listings/  MS(%) 


 99.38% 
 99.03% 
 99.79% 
 99.35% 


 F.  13.2.3 
 Director  y 
 Assistance/  MS(%) 


 100.00% 
 100.00% 
 97.87% 
 99.19% 


 % 
 NXXs 


 / 
 LRNs 


 Loaded 


 by 
 LERG 


 Effective 


 Date 
 [D-  3] 


 F.  13.3 
 Re 
 gion(%) 


 96.77% 
 100.00% 
 100.00% 
 98.41% 


 GENERAL 
 - 
 NETWORK 


 OUTAGE 
 NOTIFICATION 


 Mean 
 Time 
 to 
 Notify 


 CLEC 
 of 
 Major 


 Network 


 Outages 
 [M&  R- 
 7] 


 F.  14.1 
 Region(  minutes) 


 739 
 218 


 0 
 0 
 154 


 123 
 791 
 602 
 1,3,4 


 Abbreviations:  blank  cell  =  no  data 
 available 
 Notes: 


 D-  38 
287
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Mississippi 
 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 1 
 = 
 Sample 


 Size 
 under 


 10 
 in 
 March 


 2 
 = 
 Sample 


 Size 
 under 


 10 
 in 
 April 


 2 
 = 
 Sample 


 Size 
 under 


 10 
 in 
 May 


 4 
 = 
 Sample 


 Size 
 under 


 10 
 in 
 June 


 D-  39 
288
 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Appendix 
 E 


 North 
 Carolina 


 Performance 


 Metrics 


 Except 
 where 
 noted, 
 the 
 data 


 included 


 here 
 is 
 taken 


 from 
 the 
 North 


 Carolina 


 Monthly 
 State 
 Summary 


 (MSS) 
 Reports 


 provided 


 by 


 BellSouth, 
 calculated 
 according 
 to 
 the 


 Georgia 


 Service 
 Quality 
 Measurement 


 (SQM) 
 business 


 rules. 
 This 
 table 


 is 
 provided 


 as 
 a 


 reference 
 tool 
 for 
 the 
 convenience 


 of 
 the 


 reader. 


 No 
 conclusions 


 are 
 to 
 be 
 drawn 


 from 
 the 
 raw 


 data 
 contained 


 in 
 this 


 table. 


 Our 


 analysis 
 is 
 based 


 on 
 the 
 totality 


 of 
 the 
 circumstances, 


 such 
 that 
 we 
 may 


 use 
 non-  metric 


 evidence, 
 and 
 may 


 rely 
 more 


 heavily 


 on 
 some 


 metrics 
 more 
 than 
 others, 


 in 
 making 


 our 
 determination. 


 The 
 inclusion 


 of 
 these 


 particular 


 metrics 
 in 
 this 


 table 


 does 
 not 
 necessarily 


 mean 
 that 
 we 
 relied 


 on 
 all 
 of 
 these 


 metrics, 


 or 
 that 


 other 


 metrics 


 may 
 not 
 also 


 be 
 important 


 in 
 our 


 analysis. 


 Some 
 metrics 


 that 
 we 
 have 


 relied 
 on 
 in 
 the 


 past 


 and 
 may 


 rely 
 on 
 for 


 a 
 future 


 application 


 were 
 not 
 included 


 here 
 because 


 there 
 was 
 no 
 data 


 provided 


 for 
 them 


 (usually 
 either 
 because 


 there 
 was 
 no 
 activity, 


 or 
 because 


 the 
 metrics 


 are 
 still 


 under 


 development). 


 Metrics 
 with 
 no 
 retail 


 analog 


 provided 


 are 
 usually 


 compared 


 with 
 a 
 benchmark. 


 Note 
 that 
 for 
 some 


 metrics 


 during 
 the 
 period 


 provided 
 there 
 may 
 be 
 changes 


 in 
 the 


 metric 


 definition, 


 or 
 changes 


 in 
 the 


 retail 


 analog 


 applied, 


 making 
 it 
 difficult 


 to 
 compare 


 data 


 Note: 
 All 
 data 


 was 
 calculated 


 using 
 BellSouth's 


 data 
 platform 


 PMAP 
 4.0. 
 The 
 March 


 data 
 in 
 this 


 appendix 


 were 
 not 
 taken 


 from 
 the 


 MSS 
 reports, 


 which 
 for 
 that 


 month 


 were 
 calculated 


 using 
 PMAP 


 2.6, 
 but 
 instead 


 were 
 calculated 


 using 
 PMAP 


 4.0 
 by 
 BellSouth. 


 This 


 data 
 also 
 conforms 


 to 
 the 


 Georgia 


 Service 
 Quality 
 Measurement 


 business 
 rules 
 that 
 govern 


 the 
 regular 


 MSS 
 reports. 
289
 Metric  No. 
 SQM 
 No. 
 Metric 


 Name 


 Metric  No. 
 SQM 
 No. 
 Metric 


 Name 


 RESALE 
 A.  3.5 
 M&  R- 
 5 
 Out 


 of 
 Service 


 > 
 24 


 hours 


 Ordering 
 Billing 
 A.  1.1 
 O-  7 


 % 
 Rejected 


 Service 
 Requests 


  
 Mech. 


 A.  4.1 
 B-  1 


 Invoice 
 Accuracy 


 A.  1.2 
 O-  7 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Partially 


 Mech. 


 A.  4.2 
 B-  2 


 Mean 
 Time 
 to 
 Deliver 


 Invoices 


  
 CRIS 


 A.  1.3 
 O-  7 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Non-  Mech. 


 UNBUNDLED 
 NETWORK 
 ELEMENTS 


 A.  1.4 
 O-  8 


 Reject 
 Interval 


  
 Mech. 


 Ordering 


 A.  1.7 
 O-  8 


 Reject 
 Interval 


 - 
 Partially 


 Mech. 
  
 10 


 hours 


 B.  1.1 
 O-  7/ 
 O-  13 


 % 
 Rejected 


 Service 
 Requests 


  
 Mech. 


 A.  1.8 
 O-  8 


 Reject 
 Interval 


 - 
 Non-  Mech. 


 B.  1.2 
 O-  7/ 
 O-  13 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Partially 


 Mech. 


 A.  1.9 
 O-  9 


 FOC 
 Timeliness 


  
 Mech. 


 B.  1.3 
 O-  7/ 
 O-  13 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Non-  Mech. 


 A.  1.12 
 O-  9 


 FOC 
 Timeliness 


 - 
 Partially 


 Mech. 
 - 
 10 


 hours 


 B.  1.4 
 O-  8/ 
 O-  14 


 Reject 


 Interval 


  
 Mech. 


 A.  1.13 
 O-  9 


 FOC 
 Timeliness 


 - 
 Non-  Mech. 


 B.  1.7 
 O-  8/ 
 O-  14 


 Reject 


 Interval 


 - 
 Partially 


 Mech. 
 - 
 10 


 hours 


 A.  1.14 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Mech. 


 B.  1.8 
 O-  8/ 
 O-  14 


 Reject 


 Interval 


 - 
 Non-  Mech. 


 A.  1.15 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Partially 


 Mech. 


 B.  1.9 
 O-  9/ 
 O-  15 


 FOC 
 Timeliness 


  
 Mech. 


 A.  1.16 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Non-  Mech. 


 B.  1.12 
 O-  9/ 
 O-  15 


 FOC 
 Timeliness 


 - 
 Partially 


 Mech. 
 - 
 10 


 hours 


 Provisioning 
 B.  1.13 
 O-  9/ 
 O-  15 


 FOC 
 Timeliness 


 - 
 Non-  Mech. 


 A.  2.1 
 P-  4 


 Order 
 Completion 


 Interval 


 B.  1.14 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


  
 Mech. 


 A.  2.4 
 P-  2 


 % 
 Jeopardies 


 - 
 Mech. 


 B.  1.15 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


  
 Partially 


 Mech. 


 A.  2.5 
 P-  2 


 % 
 Jeopardies 


 - 
 Non-  Mech. 


 B.  1.16 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


  
 Non-  Mech. 


 A.  2.7 
 P-  2 


 Average 
 Jeopardy 
 Notice 
 Interval 


 - 
 Mech. 


 Provisioning 


 A.  2.8 
 P-  2 


 Average 
 Jeopardy 
 Notice 
 Interval 


 - 
 Non-  Mech. 


 B.  2.1 
 P-  4 


 Order 
 Completion 


 Interval 


 A.  2.9 
 P-  2 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Mech. 


 B.  2.2 
 P-  4 


 Order 
 Completion 


 Interval 
 within 
 X 
 days 


 - 
 xDSL 


 A.  2.10 
 P-  2 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Non-  Mech. 


 B.  2.5 
 P-  2 


 % 
 Jeopardies 


  
 Mech. 


 A.  2.11 
 P-  3 


 % 
 Missed 


 Installation 


 Appointments 


 B.  2.6 
 P-  2 


 % 
 Jeopardies 


 - 
 Non-  Mech. 


 A.  2.12 
 P-  9 


 % 
 Provisioning 


 Troubles 
 within 
 30 
 Days 


 B.  2.8 
 P-  2 


 Average 
 Jeopardy 
 Notice 
 Interval 


 - 
 Mech. 


 A.  2.14 
 P-  5 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Mech. 


 B.  2.9 
 P-  2 


 Average 
 Jeopardy 
 Notice 
 Interval 


 - 
 Non-  Mech. 


 A.  2.15 
 P-  5 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Non-  Mech. 


 B.  2.10 
 P-  2 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Mech. 


 A.  2.25 
 P-  11 


 Service 
 Order 
 Accuracy 


 B.  2.11 
 P-  2 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Non-  Mech. 


 Maintenance 
 and 
 Repair 


 B.  2.12 
 P-  7 
 Coordinated 


 Customers 
 Conversions 


 A.  3.1 
 M&  R- 
 1 
 Missed 


 Repair 
 Appointments 


 B.  2.13 
 P-  7A 


 % 
 Hot 


 Cuts 


 > 
 15 


 minutes 


 Early 


 A.  3.2 
 M&  R- 
 2 
 Customer 


 Trouble 
 Report 
 Rate 


 B.  2.14 
 P-  7A 


 Hot 
 Cut 
 Timeliness 


 A.  3.3 
 M&  R- 
 3 
 Maintenance 


 Average 
 Duration 


 B.  2.15 
 P-  7A 


 % 
 Hot 


 Cuts 


 > 
 15 


 minutes 


 Late 


 A.  3.4 
 M&  R- 
 4 
 % 
 Repeat 


 Troubles 


 within 
 30 
 Days 


 B.  2.16 
 P-  7B 


 Average 
 Recovery 


 Time 
  
 CCC 


 PERFORMANCE 
 METRIC 
 CATEGORIES 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 E-  2 
290
 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Metric  No. 
 SQM 
 No. 
 Metric 


 Name 


 Metric  No. 
 SQM 
 No. 
 Metric 


 Name 


 B.  2.17 
 P-  7C 


 % 
 Provisioning 


 Troubles 
 within 
 7 
 Days 


 - 
 Hot 


 Cuts 


 C.  3.3 
 M&  R- 
 3 
 Maintenance 


 Average 
 Duration 


 B.  2.18 
 P-  3/ 
 P-  12 


 % 
 Missed 


 Installation 


 Appointments 


 C.  3.4 
 M&  R- 
 4 
 % 
 Repeat 


 Troubles 


 within 
 30 
 Days 


 B.  2.19 
 P-  9 


 % 
 Provisioning 


 Troubles 
 within 
 30 
 Days 


 C.  3.5 
 M&  R- 
 5 
 Out 


 of 
 Service 


 > 
 24 


 hours 


 B.  2.21 
 P-  5 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Mech. 


 Billing 


 B.  2.22 
 P-  5 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Non-  Mech. 


 C.  4.1 
 B-  1 


 Invoice 
 Accuracy 


 B.  2.34 
 P-  11 


 Service 
 Order 
 Accuracy 


 C.  4.2 
 B-  2 


 Mean 
 Time 
 to 
 Deliver 


 Invoices 


 - 
 CABS 


 Maintenance 
 and 
 Repair 


 Trunk 
 Blocking 


 B.  3.1 
 M&  R- 
 1 
 Missed 


 Repair 
 Appointments 


 C.  5.1 
 TGP-  1 


 Trunk 
 Group 
 Performance 


 - 
 Aggregate 


 B.  3.2 
 M&  R- 
 2 
 Customer 


 Trouble 
 Report 
 Rate 


 OPERATIONS 
 SUPPORT 
 SYSTEMS 


 B.  3.3 
 M&  R- 
 3 
 Maintenance 


 Average 
 Duration 


 Pre-  Ordering 


 B.  3.4 
 M&  R- 
 4 
 % 
 Repeat 


 Troubles 


 within 
 30 
 Days 


 D.  1.1 
 OSS-  2 


 % 
 Interface 


 Availability 


 - 
 CLEC 


 B.  3.5 
 M&  R- 
 5 
 Out 


 of 
 Service 


 > 
 24 


 hours 


 D.  1.2 
 OSS-  2 


 % 
 Interface 


 Availability 


 - 
 BST 


 & 
 CLEC 


 Billing 
 D.  1.3 
 OSS-  1 


 Average 
 Response 


 Interval 
 - 
 CLEC 


 (LENS) 


 B.  4.1 
 B-  1 


 Invoice 
 Accuracy 


 D.  1.4 
 OSS-  1 


 Average 
 Response 


 Interval 
 - 
 CLEC 


 (TAG) 


 B.  4.2 
 B-  2 


 Mean 
 Time 
 to 
 Deliver 


 Invoices 


 - 
 CRIS 


 Maintenance 
 and 
 Repair 


 LOCAL 
 INTERCONNECTION 


 TRUNKS 


 D.  2.1 
 OSS-  3 


 % 
 Interface 


 Availability 


 - 
 BST 


 Ordering 
 D.  2.2 
 OSS-  3 


 % 
 Interface 


 Availability 


 - 
 CLEC 


 C.  1.1 
 O-  7 


 % 
 Rejected 


 Service 
 Requests 


 D.  2.3 
 OSS-  3 


 % 
 Interface 


 Availability 


 - 
 BST 


 & 
 CLEC 


 C.  1.2 
 O-  8 


 Reject 
 Interval 


 D.  2.4 
 OSS-  4 


 Average 
 Response 


 Interval 
 <= 
 4 
 Seconds 


 C.  1.3 
 O-  9 


 FOC 
 Timeliness 


 D.  2.5 
 OSS-  4 


 Average 
 Response 


 Interval 
 <= 
 10 
 Seconds 


 C.  1.4 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 D.  2.6 
 OSS-  4 


 Average 
 Response 


 Interval 
 > 
 10 


 Seconds 


 Provisioning 
 COLLOCATION 
 C.  2.1 
 P-  4 


 Order 
 Completion 


 Interval 


 Collocation 


 C.  2.2 
 P-  1 


 Held 
 Orders 


 E.  1.1 
 C-  1 


 Average 
 Response 


 Time 


 C.  2.3 
 P-  2 


 % 
 Jeopardies 


 E.  1.2 
 C-  2 


 Average 
 Arrangement 


 Time 


 C.  2.5 
 P-  3 


 % 
 Missed 


 Installation 


 Appointments 


 E.  1.3 
 C-  3 


 % 
 Due 


 Dates 


 Missed 


 C.  2.6 
 P-  9 


 % 
 Provisioning 


 Troubles 
 within 
 30 
 Days 


 GENERAL 


 C.  2.7 
 P-  5 


 Average 
 Completion 


 Notice 
 Interval 


 Flow 
 Through 


 C.  2.8 
 P-  10 


 Total 
 Service 


 Order 
 Cycle 
 Time 


 F.  1.1 
 O-  3 


 % 
 Flow 


 Through 


 Service 
 Requests 


 C.  2.10 
 P-  6 


 % 
 Completions 


 w/  o 
 Notice 


 or 
 < 
 24 


 hours 


 F.  1.2 
 O-  3 


 % 
 Flow 


 Through 


 Service 
 Requests 


 - 
 Achieved 


 C.  2.11 
 P-  11 


 Service 
 Order 
 Accuracy 


 F.  1.3 
 O-  3 


 % 
 Flow 


 Through 


 Service 
 Requests 


 - 
 LNP 


 Maintenance 
 and 
 Repair 


 Pre-  Ordering 


 C.  3.1 
 M&  R- 
 1 
 Missed 


 Repair 
 Appointments 


 F.  2.1 
 PO-  1 


 Loop 
 Makeup 


 Inquiry 
 (Manual) 


 C.  3.2 
 M&  R- 
 2 
 Customer 


 Trouble 
 Report 
 Rate 


 F.  2.2 
 PO-  2 


 Loop 
 Makeup 


 Inquiry 
 (Electronic) 


 E-  3 
291
 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Metric  No. 
 SQM 
 No. 
 Metric 


 Name 


 Metric  No. 
 SQM 
 No. 
 Metric 


 Name 


 Ordering 
 Database 
 Updates 


 F.  4.1 
 O-  12 


 Average 
 Speed 
 of 
 Answer 


 F.  13.1 
 D-  1 


 Average 
 Database 
 Update 
 Interval 


 Maintenance 
 Center 


 F.  13.2 
 D-  2 


 % 
 Update 


 Accuracy 


 F.  5.1 
 M&  R- 
 6 
 Average 


 Answer 
 Time 


 F.  13.3 
 D-  3 


 % 
 NXXs 


 / 
 LRNs 


 Loaded 


 by 
 LERG 


 Effective 


 Date 


 Operator 
 Services 
 (Toll) 


 Network 
 Outage 
 Notification 


 F.  6.1 
 OS-  1 


 Average 
 Speed 
 to 
 Answer 


 F.  14.1 
 M&  R- 
 7 
 Mean 


 Time 
 to 
 Notify 


 CLEC 
 of 
 Major 


 Network 


 Outages 


 F.  6.2 
 OS-  2 


 % 
 Answered 


 in 
 10 
 seconds 


 Directory 
 Assistance  F.  7.1  DA-  1  Average 


 Speed 
 to 
 Answer 


 F.  7.2 
 DA-  2 


 % 
 Answered 


 in 
 10 
 seconds 


 Billing  F.  9.1 
 B-  3 


 Usage 
 Data 
 Delivery 


 Accuracy 


 F.  9.2 
 B-  5 


 Usage 
 Data 
 Delivery 


 Timeliness 


 F.  9.3 
 B-  4 


 Usage 
 Data 
 Delivery 


 Completeness 


 F.  9.4 
 B-  6 


 Mean 
 Time 
 to 
 Deliver 


 Usage 


 F.  9.5 
 B-  7 


 Recurring 
 Charge 
 Completeness 


 F.  9.6 
 B-  8 


 Non-  Recurring 


 Charge 
 Completeness 


 Change 
 Management  F.  10.1  CM-  1  % 


 Software 
 Release 
 Notices 
 Sent 
 On 
 Time 


 F.  10.2 
 CM-  2 


 Average 
 Software 
 Release 
 Notice 
 Delay 
 Days 


 F.  10.3 
 CM-  3A 


 % 
 Change 


 Management 


 Documentation 


 Sent 
 On 
 Time 


 F.  10.4 
 CM-  3B 


 % 
 Change 


 Management 


 Documentation 


 (Defects, 


 Corrections, 
 etc.  ) 
 Sent 
 On 
 Time 


 F.  10.5 
 CM-  4 


 Average 
 Documentation 


 Release 
 Delay 
 Days 


 F.  10.6 
 CM-  5 


 % 
 CLEC 


 Interface 


 Outages 
 Sent 
 within 


 15 
 Minutes 


 New 
 Business 


 Requests 


 F.  11.1 
 BFR-  1 


 % 
 New 


 Business 


 Requests 
 Processed 


 in 
 30 


 Bus. 


 Days 


 F.  11.2 
 BFR-  2A 


 % 
 Quotes 


 Provided 


 within 
 X 
 Business 


 Days 


 Ordering  F.  12.1 
 O-  1 
 Acknowledgement 


 Message 
 Timeliness 


 F.  12.2 
 O-  2 
 Acknowledgement 


 Message 
 Completeness 


 E-  4 
292
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 RESALE 
 - 
 ORDERING  %  Rejected 


 Service 
 Requests 


 - 
 Mechanized 


 [O-  7] 


 A.  1.1.1 
 Residence/  NC 
 (%) 


 8.64% 
 7.68% 
 7.32% 
 7.86% 


 A.  1.1.2 
 Business/  NC 
 (%) 


 24.61% 
 23.81% 
 21.85% 
 24.35% 


 A.  1.1.4 
 PBX/  NC 
 (%) 


 0.00% 


 100.00% 
 1,4 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Partially 


 Mechanized 


 [O-  7] 


 A.  1.2.1 
 Residence/  NC 
 (%) 


 18.67% 
 15.55% 
 22.57% 
 26.86% 


 A.  1.2.2 
 Business/  NC 
 (%) 


 41.78% 
 54.72% 
 39.86% 
 50.26% 


 A.  1.2.4 
 PBX/  NC 
 (%) 


 50.00% 
 0.00% 


 62.50% 
 1,2,4 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Non-  Mechanized 


 [O-  7] 


 A.  1.3.1 
 Residence/  NC 
 (%) 


 50.50% 
 51.35% 
 47.57% 
 46.84% 


 A.  1.3.2 
 Business/  NC 
 (%) 


 50.65% 
 52.09% 
 54.71% 
 55.85% 


 A.  1.3.3 
 Desi 
 gn 
 (Specials)/  NC(%) 


 22.22% 
 25.00% 
 27.45% 
 40.00% 


 A.  1.3.4 
 PBX/  NC 
 (%) 


 23.53% 
 52.63% 
 37.50% 
 60.00% 
 3 


 A.  1.3.5 
 Centrex/  NC 
 (%) 


 100.00% 
 62.50% 
 53.57% 
 60.71% 
 1,2 


 A.  1.3.6 
 ISDN/  NC 
 (%) 


 26.09% 
 18.18% 
 12.50% 
 41.18% 
 3 


 Reject 
 Interval 


 - 
 Mechanized 


 [O-  8] 


 A.  1.4.1 
 Residence/  NC 
 (%) 


 92.67% 
 93.74% 
 93.96% 
 95.07% 


 A.  1.4.2 
 Business/  NC 
 (%) 


 89.47% 
 90.63% 
 85.07% 
 89.55% 


 A.  1.4.4 
 PBX/  NC 
 (%) 


 0.00% 
 4 


 Reject 
 Interval 


 - 
 Partially 


 Mechanized 


 - 
 10 


 hours 


 [O-  8] 


 A.  1.7.1 
 Residence/  NC 
 (%) 


 88.58% 
 93.33% 
 88.79% 
 93.90% 


 A.  1.7.2 
 Business/  NC 
 (%) 


 97.78% 
 98.28% 
 81.97% 
 95.00% 


 A.  1.7.4 
 PBX/  NC 
 (%) 


 0.00% 


 60.00% 
 1,4 


 Reject 
 Interval 


 - 
 Non-  Mechanized 


 [O-  8] 


 A.  1.8.1 
 Residence/  NC 
 (%) 


 98.08% 
 100.00% 
 100.00% 
 100.00% 


 A.  1.8.2 
 Business/  NC 
 (%) 


 100.00% 
 98.21% 
 98.95% 
 99.09% 


 A.  1.8.3 
 Desi 
 gn 
 (Specials)/  NC(%) 


 100.00% 
 100.00% 
 86.67% 
 100.00% 


 A.  1.8.4 
 PBX/  NC 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,3 


 A.  1.8.5 
 Centrex/  NC 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 88.24% 
 1,2 


 A.  1.8.6 
 ISDN/  NC 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 FOC 
 Timeliness 


 - 
 Mechanized 


 [O-  9] 


 A.  1.9.1 
 Residence/  NC 
 (%) 


 99.84% 
 99.71% 
 99.70% 
 99.95% 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 North 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 E-  5 
293
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 North 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 A.  1.9.2 
 Business/  NC(%) 


 100.00% 
 99.67% 
 100.00% 


 99.04% 


 FOC 
 Timeliness 


 - 
 Partially 


 Mechanized 


 - 
 10 


 hours 


 [O-  9] 


 A.  1.12.1 
 Residence/  NC 
 (%) 


 90.32% 
 90.98% 
 86.07% 
 89.82% 


 A.  1.12.2 
 Business/  NC 
 (%) 


 93.33% 
 94.16% 
 92.38% 
 95.69% 


 A.  1.12.4 
 PBX/  NC 
 (%) 


 0.00% 
 0.00% 


 33.33% 
 1,2,4 


 FOC 
 Timeliness 


 - 
 Non-  Mechanized 


 [O-  9] 


 A.  1.13.1 
 Residence/  NC 
 (%) 


 98.25% 
 94.29% 
 100.00% 


 95.24% 


 A.  1.13.2 
 Business/  NC 
 (%) 


 100.00% 
 97.09% 
 98.44% 
 98.73% 


 A.  1.13.3 
 Desi 
 gn 
 (Specials)/  NC(%) 


 95.83% 
 100.00% 


 97.06% 
 100.00% 


 A.  1.13.4 
 PBX/  NC 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 87.50% 
 1,2,3,4 


 A.  1.13.5 
 Centrex/  NC 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 2 


 A.  1.13.6 
 ISDN/  NC 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 3 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Mechanized 


 [O-  11] 


 A.  1.14.1.1 
 Residence/  EDI/ 


 NC  (%) 


 99.33% 
 99.12% 
 95.63% 
 100.00% 


 A.  1.14.1.2 
 Residence/  TAG/ 


 NC  (%) 


 99.63% 
 99.72% 
 99.37% 
 100.00% 


 A.  1.14.2.1 
 Business/  EDI/ 
 NC 
 (%) 


 100.00% 
 100.00% 
 84.62% 
 100.00% 
 1,4 


 A.  1.14.2.2 
 Business/  TAG/ 


 NC 
 (%) 


 95.53% 
 97.68% 
 96.54% 
 100.00% 


 A.  1.14.4.2 
 PBX/  TAG/ 
 NC 
 (%) 


 0.00% 


 100.00% 
 1,4 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Partially 


 Mechanized 


 [O-  11] 


 A.  1.15.1.1 
 Residence/  EDI/ 


 NC  (%) 


 99.08% 
 98.62% 
 93.85% 
 100.00% 


 A.  1.15.1.2 
 Residence/  TAG/ 


 NC  (%) 


 99.62% 
 99.58% 
 99.94% 
 99.85% 


 A.  1.15.2.1 
 Business/  EDI/ 
 NC 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 A.  1.15.2.2 
 Business/  TAG/ 


 NC 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 A.  1.15.4.2 
 PBX/  TAG/ 
 NC 
 (%) 


 100.00% 
 100.00% 


 100.00% 
 1,2,4 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Non-  Mechanized 


 [O-  11] 


 A.  1.16.1 
 Residence/  NC 
 (%) 


 98.02% 
 94.59% 
 96.76% 
 97.47% 


 A.  1.16.2 
 Business/  NC 
 (%) 


 95.45% 
 97.21% 
 92.94% 
 94.68% 


 A.  1.16.3 
 Desi 
 gn 
 (Specials)/  NC(%) 


 91.11% 
 97.22% 
 92.16% 
 97.14% 


 A.  1.16.4 
 PBX/  NC 
 (%) 


 82.35% 
 100.00% 


 87.50% 
 95.00% 
 3 


 A.  1.16.5 
 Centrex/  NC 
 (%) 


 100.00% 
 100.00% 
 96.43% 
 100.00% 
 1,2 


 A.  1.16.6 
 ISDN/  NC 
 (%) 


 73.91% 
 100.00% 
 100.00% 
 100.00% 
 3 


 RESALE 
 - 
 PROVISIONING  Order  Completion 


 Interval 
 [P-  4] 


 E-  6 
294
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 North 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 A.  2.1.1.1.1 
 Residence/<  10 


 circuits/  Dispatch/ 


 NC( 
 days) 


 5.22 
 4.74 
 5.29 
 4.64 
 5.36 
 4.72 
 5.45 
 4.93 


 A.  2.1.1.1.2 
 Residence/<  10 


 circuits/  Non- 
 Dis  patch/ 
 NC( 
 days) 


 0.85 
 0.63 
 0.85 
 0.58 
 0.86 
 0.60 
 0.87 
 0.56 


 A.  2.1.1.2.1 
 Residence/>=  10 


 circuits/  Dis 
 patch/  NC( 
 days) 


 5.74 
 4.00 
 4.88 
 5.00 
 5.13 


 5.09 
 1,2 


 A.  2.1.2.1.1 
 Business/<  10 
 circuits/  Dis 
 patch/  NC( 
 days) 


 2.58 
 4.70 
 3.28 
 5.01 
 3.82 
 7.54 
 5.49 
 4.45 


 A.  2.1.2.1.2 
 Business/<  10 
 circuits/  Non- 
 Dis  patch/ 
 NC( 
 days) 


 1.18 
 1.51 
 1.28 
 0.77 
 1.29 
 0.72 
 1.04 
 0.84 


 A.  2.1.2.2.1 
 Business/>=  10 


 circuits/  Dis 
 patch/  NC( 
 days) 


 14.93 
 12.00 
 12.46 


 2.50 
 9.48 


 15.90 


 1,2 


 A.  2.1.2.2.2 
 Desi 
 gn 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 KY( 
 days) 


 1.88 


 2.67 
 0.75 
 1.00 
 1.23 


 3 


 A.  2.1.3.1.1 
 Desi 
 gn 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 NC( 
 days) 


 20.30 
 10.27 
 22.59 
 12.33 
 20.08 
 12.00 
 18.58 


 7.46 
 4 


 A.  2.1.3.1.2 
 Design 
 (Specials)/<  10 


 circuits/  Non- 


 Dis 
 patch/  NC( 


 days) 


 17.19 
 9.00 
 16.63 


 3.00 
 10.37 


 4.00 
 11.76 


 12.00 
 2,3,4 


 A.  2.1.4.1.1 
 PBX/<  10 
 circuits/  Dis 


 patch/  NC( 
 days) 


 14.85 
 6.00 
 16.14 


 17.68 
 2.00 
 23.76 


 2.00 
 1,3,4 


 A.  2.1.4.1.2 
 PBX/<  10 
 circuits/  Non- 


 Dis 
 patch/  NC( 


 days) 


 3.17 
 1.44 
 3.03 
 2.95 
 4.85 
 0.33 
 5.16 
 0.93 
 1,2,3,4 


 A.  2.1.4.2.2 
 PBX/>=  10 
 circuits/  Non- 


 Dis  patch/ 
 NC( 
 days) 


 2.33 


 2.43 
 3.71 
 1.38 


 A.  2.1.5.1.1 
 Centrex/<  10 
 circuits/  Dis 
 patch/  NC( 
 days) 


 9.47 
 2.33 
 2.00 
 8.02 
 1.67 
 5.67 


 2,3 


 A.  2.1.5.1.2 
 Centrex/<  10 
 circuits/  Non- 
 Dis  patch/ 
 NC( 
 days) 


 2.58 
 2.33 
 2.84 
 0.67 
 3.69 
 2.50 
 1.33 
 1.58 
 1,2,3,4 


 A.  2.1.6.1.1 
 ISDN/<  10 
 circuits/  Dis 
 patch/  NC( 
 days) 


 29.21 
 20.76 
 10.50 
 22.05 
 12.00 
 18.11 


 2,3 


 A.  2.1.6.1.2 
 ISDN/<  10 
 circuits/  Non- 


 Dis 
 patch/  NC( 


 days) 


 1.83 
 2.50 
 9.64 
 3.71 
 2.92 


 2.90 
 1.89 
 1,2,4 


 % 
 Jeopardies 


 - 
 Mechanized 


 [P-  2] 


 A.  2.4.1 
 Residence/  NC 
 (%) 


 0.38% 
 0.55% 
 0.33% 
 0.32% 
 0.31% 
 0.18% 
 0.30% 
 0.15% 


 A.  2.4.2 
 Business/  NC 
 (%) 


 1.44% 
 1.24% 
 1.82% 
 0.49% 
 1.99% 
 0.60% 
 1.45% 
 0.00% 


 A.  2.4.3 
 Desi 
 gn 
 (Specials)/  NC(%) 


 9.36% 
 12.38% 
 11.98% 
 10.26% 
 0.00% 


 4 


 A.  2.4.4 
 PBX/  NC 
 (%) 


 3.33% 
 0.00% 
 8.70% 
 0.00% 
 8.50% 
 0.00% 
 5.34% 
 0.00% 
 1,2,3 


 A.  2.4.5 
 Centrex/  NC 
 (%) 


 2.41% 
 0.00% 
 1.45% 
 0.00% 
 2.51% 


 3.49% 


 1,2 


 A.  2.4.6 
 ISDN/  NC 
 (%) 


 3.87% 
 13.29% 
 0.00% 
 11.26% 


 0.00% 
 7.66% 
 0.00% 
 2,3,4 


 % 
 Jeopardies 


 - 
 Non-  Mechanized 


 [P-  2] 


 A.  2.5.1 
 Residence/  NC 
 (%) 


 0.94% 
 0.00% 
 1.32% 
 0.72% 


 A.  2.5.2 
 Business/  NC 
 (%) 


 0.00% 
 0.72% 
 0.00% 
 0.00% 


 A.  2.5.3 
 Desi 
 gn 
 (Specials)/  NC(%) 


 15.69% 
 14.29% 
 15.63% 
 20.00% 
 4 


 A.  2.5.4 
 PBX/  NC 
 (%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3,4 


 A.  2.5.5 
 Centrex/  NC 
 (%) 


 0.00% 
 0.00% 
 9.09% 
 0.00% 
 1,2,4 


 A.  2.5.6 
 ISDN/  NC 
 (%) 


 0.00% 
 11.11% 
 20.00% 
 0.00% 
 1,2,3,4 


 Average 
 Jeopardy 


 Notice 
 Interval 


 - 
 Mechanized 


 [P-  2] 


 A.  2.7.1 
 Residence/  NC 
 (hours) 


 131.83 
 138.85 
 139.17 
 142.37 


 E-  7 
295
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 North 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 A.  2.7.2 
 Business/  NC( 
 hours) 


 168.37 
 151.82 
 148.60 


 1,2,3 


 Average 
 Jeopardy 


 Notice 
 Interval 


 - 
 Non-  Mechanized 


 [P-  2] 


 A.  2.8.1 
 Residence/  NC 
 (hours) 


 151.22 
 32.08 
 131.33 
 1,3,4 


 A.  2.8.3 
 Desi 
 gn 
 (Specials)/  NC( 


 hours) 


 306.33 
 301.05 
 207.89 
 588.08 
 1,2,3,4 


 A.  2.8.5 
 Centrex/  NC 
 (hours) 


 83.85 
 3 


 A.  2.8.6 
 ISDN/  NC 
 (hours) 


 420.23 
 322.28 


 2,3 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Mechanized 


 [P-  2] 


 A.  2.9.1 
 Residence/  NC 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 A.  2.9.2 
 Business/  NC 
 (%) 


 100.00% 
 100.00% 
 100.00% 


 1,2,3 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Non-  Mechanized 


 [P-  2] 


 A.  2.10.1 
 Residence/  NC 
 (%) 


 100.00% 
 0.00% 
 100.00% 
 1,3,4 


 A.  2.10.3 
 Desi 
 gn 
 (Specials)/  NC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 A.  2.10.5 
 Centrex/  NC 
 (%) 


 100.00% 
 3 


 A.  2.10.6 
 ISDN/  NC 
 (%) 


 100.00% 
 100.00% 


 2,3 


 % 
 Missed 


 Installation 


 Appointments 


 [P-  3] 


 A.  2.11.1.1.1 
 Residence/<  10 


 circuits/  Dis 
 patch/  NC(%) 


 3.70% 
 0.15% 
 3.34% 
 0.21% 
 3.26% 
 0.62% 
 3.66% 
 1.40% 


 A.  2.11.1.1.2 
 Residence/<  10 


 circuits/  Non- 
 Dis  patch/ 
 NC(%) 


 0.15% 
 0.21% 
 0.03% 
 0.09% 
 0.02% 
 0.16% 
 0.02% 
 0.07% 


 A.  2.11.1.2.1 
 Residence/>=  10 


 circuits/  Dis 
 patch/  NC(%) 


 4.65% 
 0.00% 
 11.11% 


 0.00% 
 5.41% 


 6.45% 
 0.00% 
 1,2,4 


 A.  2.11.2.1.1 
 Business/<  10 
 circuits/  Dis 
 patch/  NC(%) 


 1.14% 
 0.00% 
 1.24% 
 3.91% 
 1.93% 
 0.00% 
 3.37% 
 0.81% 


 A.  2.11.2.1.2 
 Business/<  10 
 circuits/  Non- 
 Dis  patch/ 
 NC(%) 


 0.00% 
 0.00% 
 0.12% 
 0.00% 
 0.06% 
 0.37% 
 0.05% 
 0.31% 


 A.  2.11.2.2.1 
 Business/>=  10 


 circuits/  Dis 
 patch/  NC(%) 


 1.69% 
 0.00% 
 1.37% 
 0.00% 
 4.48% 


 4.17% 


 1,2 


 A.  2.11.2.2.2 
 Business/>=  10 


 circuits/  Non- 
 Dis  patch/ 
 NC(%) 


 0.00% 
 0.00% 
 0.00% 


 0.00% 
 0.00% 
 0.00% 


 1,3 


 A.  2.11.3.1.1 
 Design 
 (Specials)/<  10 


 circuits/  Non- 
 Dispatch/  KY(%) 


 5.95% 
 0.00% 
 5.06% 
 0.00% 
 5.48% 
 25.00% 


 4.68% 
 0.00% 


 A.  2.11.3.1.2 
 Design 
 (Specials)/<  10 


 circuits/  Non- 
 Dispatch/  NC(%) 


 0.23% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.47% 
 33.33% 


 2,3,4 


 A.  2.11.4.1.1 
 PBX/<  10 
 circuits/  Dis 


 patch/  NC(%) 


 3.64% 
 0.00% 
 2.44% 


 3.45% 
 0.00% 
 0.00% 
 0.00% 
 1,3,4 


 A.  2.11.4.1.2 
 PBX/<  10 
 circuits/  Non- 


 Dis 
 patch/  NC(%) 


 1.22% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 2.50% 
 0.00% 


 1,3 


 A.  2.11.4.2.2 
 PBX/>=  10 
 circuits/  Non- 


 Dis 
 patch/  NC(%) 


 0.00% 
 0.00% 
 0.00% 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1,3,4 


 A.  2.11.5.1.1 
 Centrex/<  10 
 circuits/  Dis 
 patch/  NC(%) 


 1.39% 
 0.53% 
 0.00% 
 1.37% 
 0.00% 
 1.62% 


 2,3 


 A.  2.11.5.1.2 
 Centrex/<  10 
 circuits/  Non- 
 Dis  patch/ 
 NC(%) 


 0.35% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3,4 


 A.  2.11.5.2.2 
 Centrex/>=  10 
 circuits/  Non- 
 Dis  patch/ 
 NC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.66% 
 0.00% 
 0.00% 


 2,3 


 A.  2.11.6.1.1 
 ISDN/<  10 
 circuits/  Dis 
 patch/  NC(%) 


 0.82% 
 0.00% 
 0.75% 
 0.00% 
 0.00% 
 0.00% 
 1.52% 
 0.00% 
 1,2,3,4 


 E-  8 
296
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 North 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 A.  2.11.6.1.2 
 ISDN/<  10 
 circuits/  Non- 


 Dispatch/  NC(%) 


 0.75% 
 0.00% 
 0.51% 
 0.00% 
 0.47% 
 0.00% 
 1.23% 
 0.00% 
 1,2,3,4 


 A.  2.11.6.2.2 
 ISDN/>=  10 
 circuits/  Non- 


 Dis 
 patch/  NC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 2,3 


 % 
 Provisioning 


 Troubles 
 within 
 30 
 Days 


 [P-  9] 


 A.  2.12.1.1.1 
 Residence/<  10 


 circuits/  Dis 
 patch/  NC(%) 


 9.52% 
 7.09% 
 9.89% 
 6.24% 
 9.75% 
 5.31% 
 10.81% 


 9.48% 


 A.  2.12.1.1.2 
 Residence/<  10 


 circuits/  Non- 
 Dis  patch/ 
 NC(%) 


 2.37% 
 5.57% 
 2.50% 
 4.10% 
 2.25% 
 3.23% 
 2.40% 
 3.42% 


 A.  2.12.1.2.1 
 Residence/>=  10 


 circuits/  Dis 
 patch/  NC(%) 


 3.23% 
 0.00% 
 0.00% 
 33.33% 
 19.44% 
 0.00% 
 2.70% 


 1,2,3 


 A.  2.12.2.1.1 
 Business/<  10 
 circuits/  Dis 
 patch/  NC(%) 


 9.84% 
 6.78% 
 9.51% 
 7.91% 
 9.64% 
 8.59% 
 10.44% 


 8.33% 


 A.  2.12.2.1.2 
 Business/<  10 
 circuits/  Non- 
 Dis  patch/ 
 NC(%) 


 5.55% 
 3.57% 
 6.21% 
 4.51% 
 5.39% 
 3.56% 
 6.71% 
 5.17% 


 A.  2.12.2.2.1 
 Business/>=  10 


 circuits/  Dis 
 patch/  NC(%) 


 21.43% 
 0.00% 
 15.25% 


 0.00% 
 24.66% 


 0.00% 
 19.40% 


 1,2,3 


 A.  2.12.2.2.2 
 Business/>=  10 


 circuits/  Non- 
 Dis  patch/ 
 NC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 10.00% 
 100.00% 


 1,2,4 


 A.  2.12.3.1.1 
 Design 
 (Specials)/<  10 


 circuits/  Non- 
 Dispatch/  KY(%) 


 5.98% 
 14.29% 


 6.75% 
 5.00% 
 5.88% 
 14.81% 


 7.59% 
 0.00% 


 1 


 A.  2.12.3.1.2 
 Design 
 (Specials)/<  10 


 circuits/  Non- 
 Dispatch/  NC(%) 


 3.21% 
 16.67% 


 5.73% 
 0.00% 
 5.38% 
 0.00% 
 5.52% 
 0.00% 
 1,3,4 


 A.  2.12.4.1.1 
 PBX/<  10 
 circuits/  Dis 


 patch/  NC(%) 


 15.38% 
 0.00% 
 0.00% 
 0.00% 
 4.88% 


 3.45% 
 0.00% 
 1,2,4 


 A.  2.12.4.1.2 
 PBX/<  10 
 circuits/  Non- 


 Dis 
 patch/  NC(%) 


 5.48% 
 0.00% 
 2.44% 
 0.00% 
 5.38% 
 0.00% 
 4.04% 
 0.00% 
 1,2,4 


 A.  2.12.4.2.2 
 PBX/>=  10 
 circuits/  Non- 


 Dis 
 patch/  NC(%) 


 11.76% 
 100.00% 


 0.00% 
 0.00% 
 0.00% 


 0.00% 
 0.00% 
 1,2,4 


 A.  2.12.5.1.1 
 Centrex/<  10 
 circuits/  Dis 
 patch/  NC(%) 


 5.85% 
 3.24% 
 2.35% 
 0.00% 
 5.47% 
 25.00% 


 3,4 


 A.  2.12.5.1.2 
 Centrex/<  10 
 circuits/  Non- 
 Dis  patch/ 
 NC(%) 


 3.78% 
 0.00% 
 8.60% 
 11.11% 


 5.70% 
 0.00% 
 6.29% 
 0.00% 
 1,2,3,4 


 A.  2.12.5.2.2 
 Centrex/>=  10 
 circuits/  Non- 
 Dis  patch/ 
 NC(%) 


 7.84% 
 0.00% 
 6.67% 


 10.26% 
 0.00% 
 3.97% 
 0.00% 
 1,3,4 


 A.  2.12.6.1.1 
 ISDN/<  10 
 circuits/  Dis 
 patch/  NC(%) 


 6.96% 
 5.33% 
 0.00% 
 4.89% 
 33.33% 


 1.79% 
 0.00% 
 2,3,4 


 A.  2.12.6.1.2 
 ISDN/<  10 
 circuits/  Non- 


 Dis 
 patch/  NC(%) 


 0.79% 
 0.00% 
 0.45% 
 0.00% 
 0.00% 
 0.00% 
 1.42% 
 0.00% 
 1,2,3,4 


 A.  2.12.6.2.2 
 ISDN/>=  10 
 circuits/  Non- 


 Dis 
 patch/  NC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 3,4 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Mechanized 


 [P-  5] 


 A.  2.14.1.1.1 
 Residence/<  10 


 circuits/  Dis 
 patch/  NC( 
 hours) 


 1.79 
 0.11 
 1.29 
 0.45 
 1.60 
 0.07 
 1.24 
 0.05 


 A.  2.14.1.1.2 
 Residence/<  10 


 circuits/  Non- 
 Dis  patch/ 
 NC( 
 hours) 


 0.73 
 0.78 
 0.69 
 0.80 
 0.69 
 0.83 
 0.73 
 0.84 


 A.  2.14.1.2.1 
 Residence/>=  10 


 circuits/  Dis 
 patch/  NC( 
 hours) 


 3.22 
 0.02 
 6.50 
 0.02 
 2.03 


 0.02 
 0.02 
 1,2,4 


 A.  2.14.2.1.1 
 Business/<  10 
 circuits/  Dis 
 patch/  NC( 
 hours) 


 1.09 
 0.63 
 2.16 
 0.04 
 1.73 
 0.14 
 2.50 
 0.30 


 A.  2.14.2.1.2 
 Business/<  10 
 circuits/  Non- 
 Dis  patch/ 
 NC( 
 hours) 


 2.07 
 0.55 
 3.55 
 0.60 
 2.13 
 0.70 
 1.74 
 0.70 


 A.  2.14.2.2.1 
 Business/>=  10 


 circuits/  Dis 
 patch/  NC( 
 hours) 


 2.26 
 0.02 
 4.76 
 0.02 
 0.40 


 0.57 
 1,2 


 A.  2.14.2.2.2 
 Business/>=  10 


 circuits/  Non- 
 Dis  patch/ 
 NC( 
 hours) 


 0.82 


 7.26 
 0.71 
 0.53 


 A.  2.14.3.1.1 
 Design 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 NC(  hours) 
 266.02 


 300.86 
 258.22 
 253.35 
 0.02 
 4 


 A.  2.14.4.1.1 
 PBX/<  10 
 circuits/  Dis 


 patch/  NC( 
 hours) 


 215.77 
 127.09 


 99.62 
 0.02 
 199.85 


 2.43 
 3,4 


 E-  9 
297
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 North 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 A.  2.14.4.1.2 
 PBX/<  10 
 circuits/  Non- 


 Dispatch/  NC( 


 hours) 


 25.52 
 0.43 
 19.63 


 0.39 
 35.97 


 0.02 
 27.58 


 0.14 
 1,2,3,4 


 A.  2.14.4.2.2 
 PBX/>=  10 
 circuits/  Non- 


 Dis  patch/ 
 NC( 
 hours) 


 0.79 
 10.90 


 3.40 
 0.47 
 6.92 
 0.93 
 3,4 


 A.  2.14.5.1.2 
 Centrex/<  10 
 circuits/  Non- 
 Dis  patch/ 
 NC( 
 hours) 


 5.07 
 0.47 
 3.86 
 0.02 
 3.70 


 3.90 
 1,2 


 A.  2.14.6.1.1 
 ISDN/<  10 
 circuits/  Dis 
 patch/  NC( 
 hours) 


 552.33 
 220.62 
 250.61 
 164.11 
 0.02 
 4 


 A.  2.14.6.1.2 
 ISDN/<  10 
 circuits/  Non- 


 Dis 
 patch/  NC( 


 hours) 


 2.45 
 118.35 
 0.02 
 8.49 


 2.31 
 0.02 
 2,4 


 A.  2.14.6.2.2 
 ISDN/>=  10 
 circuits/  Non- 


 Dis 
 patch/  NC( 


 hours) 


 0.61 


 0.63 
 0.69 
 0.02 
 0.78 


 3 


 Design 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 KY(  hours) 


 A.  2.15.1.1.1 
 Residence/<  10 


 circuits/  Dis 
 patch/  NC( 
 hours) 


 14.06 
 10.99 
 10.11 
 16.69 


 A.  2.15.1.1.2 
 Residence/<  10 


 circuits/  Non- 
 Dis  patch/ 
 NC( 
 hours) 


 4.05 
 6.86 
 4.84 
 4.93 


 A.  2.15.2.1.1 
 Business/<  10 
 circuits/  Dis 
 patch/  NC( 
 hours) 


 34.65 
 25.62 
 24.65 
 22.64 


 A.  2.15.2.1.2 
 Business/<  10 
 circuits/  Non- 
 Dis  patch/ 
 NC( 
 hours) 


 10.99 
 14.28 
 14.17 
 11.96 


 A.  2.15.2.2.2 
 Business/>=  10 


 circuits/  Non- 
 Dis  patch/ 
 NC( 
 hours) 


 0.38 


 14.00 
 1,3 


 A.  2.15.3.1.1 
 Design 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 NC(  hours) 


 115.36 
 206.30 
 214.22 
 329.96 
 4 


 A.  2.15.3.1.2 
 Design 
 (Specials)/<  10 


 circuits/  Non- 


 Dispatch/  NC( 
 hours) 


 141.40 
 34.03 
 27.32 
 300.85 
 2,3,4 


 A.  2.15.4.1.1 
 PBX/<  10 
 circuits/  Dis 


 patch/  NC( 
 hours) 


 32.23 


 21.07 
 1,3 


 A.  2.15.4.1.2 
 PBX/<  10 
 circuits/  Non- 


 Dis 
 patch/  NC( 


 hours) 


 10.19 
 23.62 


 3.75 
 13.11 
 1,2,3,4 


 A.  2.15.4.2.2 
 PBX/>=  10 
 circuits/  Non- 


 Dis 
 patch/  NC( 


 hours) 


 0.40 


 0.58 
 1,3 


 A.  2.15.5.1.1 
 Centrex/<  10 
 circuits/  Dis 
 patch/  NC( 
 hours) 


 21.65 
 23.60 


 2,3 


 A.  2.15.5.1.2 
 Centrex/<  10 
 circuits/  Non- 
 Dis  patch/ 
 NC( 
 hours) 


 14.32 
 14.05 
 14.00 
 22.97 
 1,2,3,4 


 A.  2.15.5.2.2 
 Centrex/>=  10 
 circuits/  Non- 
 Dis  patch/ 
 NC( 
 hours) 


 0.67 
 14.00 


 2,3 


 A.  2.15.6.1.1 
 ISDN/<  10 
 circuits/  Dis 
 patch/  NC( 
 hours) 


 155.38 
 126.06 
 174.73 


 1,2,3 


 A.  2.15.6.1.2 
 ISDN/<  10 
 circuits/  Non- 


 Dis 
 patch/  NC( 


 hours) 


 20.38 
 42.91 
 20.78 
 101.56 
 1,2,3,4 


 A.  2.15.6.2.2 
 ISDN/>=  10 
 circuits/  Non- 


 Dis 
 patch/  NC( 


 hours) 


 0.02 
 20.83 


 2,3 


 Service 
 Order 
 Accuracy 


 [P-  11] 


 A.  2.25.1.1.1 
 Residence/<  10 


 circuits/  Dis 
 patch/  NC(%) 


 92.14% 
 96.55% 
 90.77% 
 98.86% 


 A.  2.25.1.1.2 
 Residence/<  10 


 circuits/  Non- 
 Dis  patch/ 
 NC(%) 


 95.38% 
 94.29% 
 98.82% 
 98.56% 


 A.  2.25.1.2.1 
 Design 
 (Specials)/<  10 


 circuits/  Non- 
 Dispatch/  KY(%) 


 100.00% 
 88.24% 
 100.00% 
 100.00% 
 4 


 A.  2.25.2.1.1 
 Business/<  10 
 circuits/  Dis 
 patch/  NC(%) 


 91.33% 
 95.76% 
 88.82% 
 94.44% 


 A.  2.25.2.1.2 
 Business/<  10 
 circuits/  Non- 
 Dis  patch/ 
 NC(%) 


 93.85% 
 97.93% 
 96.11% 
 97.22% 


 A.  2.25.2.2.1 
 Business/>=  10 


 circuits/  Dis 
 patch/  NC(%) 


 100.00% 
 77.78% 
 77.78% 
 76.92% 
 2 


 A.  2.25.2.2.2 
 Business/>=  10 


 circuits/  Non- 
 Dis  patch/ 
 NC(%) 


 84.62% 
 97.56% 
 92.59% 
 91.89% 


 E-  10 
298
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 North 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 A.  2.25.3.1.1 
 Design 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 NC(%) 


 81.08% 
 91.43% 
 80.49% 
 96.47% 


 A.  2.25.3.1.2 
 Design 
 (Specials)/<  10 


 circuits/  Non- 
 Dispatch/  NC(%) 


 91.84% 
 94.78% 
 91.43% 
 91.36% 


 A.  2.25.3.2.1 
 Desi 
 gn 
 (Specials)/>=  10 


 circuits/  Dispatch/ 


 NC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 A.  2.25.3.2.2 
 Design 
 (Specials)/>=  10 


 circuits/  Non- 
 Dispatch/  NC(%) 


 100.00% 
 90.00% 
 92.31% 
 88.89% 
 1,4 


 RESALE 
 - 
 MAINTENANCE 


 AND 
 REPAIR 


 Missed 
 Repair 
 Appointments 


 [M&  R- 
 1] 


 A.  3.1.1.1 
 Residence/  Dis 
 patch/  NC(%) 


 3.97% 
 0.74% 
 3.99% 
 0.51% 
 3.60% 
 0.50% 
 3.74% 
 0.48% 


 A.  3.1.1.2 
 Residence/  Non- 


 Dis  patch/ 
 NC(%) 


 0.61% 
 0.00% 
 0.77% 
 0.00% 
 0.51% 
 0.00% 
 1.21% 
 0.00% 


 A.  3.1.2.1 
 Business/  Dis 
 patch/  NC(%) 


 4.14% 
 1.25% 
 5.69% 
 0.59% 
 5.27% 
 1.28% 
 5.73% 
 13.53% 


 A.  3.1.2.2 
 Business/  Non- 


 Dis 
 patch/  NC(%) 


 0.97% 
 0.00% 
 2.15% 
 2.56% 
 1.71% 
 1.52% 
 1.27% 
 0.00% 


 A.  3.1.3.1 
 Desi 
 gn 
 (Specials)/  Dispatch/ 


 NC(%) 


 0.00% 
 0.00% 
 0.63% 
 4.00% 
 0.29% 
 2.78% 
 1.43% 
 0.00% 


 A.  3.1.3.2 
 Desi 
 gn 
 (Specials)/  Non- 


 Dispatch/  NC(%) 


 0.49% 
 0.00% 
 0.28% 
 0.00% 
 0.32% 
 0.00% 
 0.26% 
 0.00% 


 A.  3.1.4.1 
 PBX/  Dis 
 patch/  NC(%) 


 6.94% 
 0.00% 
 4.32% 
 0.00% 
 4.40% 
 0.00% 
 6.67% 
 0.00% 
 1,2,3 


 A.  3.1.4.2 
 PBX/  Non- 
 Dis 
 patch/  NC(%) 


 6.21% 
 0.00% 
 0.00% 
 0.00% 
 6.63% 
 0.00% 
 1.18% 
 0.00% 
 2,3,4 


 A.  3.1.5.1 
 Centrex/  Dis 
 patch/  NC(%) 


 8.14% 
 0.00% 
 10.47% 


 0.00% 
 9.07% 
 0.00% 
 9.68% 
 0.00% 


 3,4 


 A.  3.1.5.2 
 Centrex/  Non- 
 Dis 
 patch/  NC(%) 


 2.70% 
 0.00% 
 2.10% 
 0.00% 
 1.00% 
 0.00% 
 1.33% 
 0.00% 


 2,3 


 A.  3.1.6.1 
 ISDN/  Dis 
 patch/  NC(%) 


 0.00% 
 0.00% 
 0.85% 
 0.00% 
 0.00% 
 0.00% 
 2.02% 
 0.00% 
 1,2,3,4 


 A.  3.1.6.2 
 ISDN/  Non- 
 Dis 
 patch/  NC(%) 


 0.00% 
 0.00% 
 0.53% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3,4 


 Customer 
 Trouble 
 Report 
 Rate 
 [M&  R- 


 2] 


 A.  3.2.1.1 
 Residence/  Dis 
 patch/  NC(%) 


 1.73% 
 1.61% 
 1.95% 
 1.43% 
 2.05% 
 1.83% 
 2.17% 
 1.91% 


 A.  3.2.1.2 
 Residence/  Non- 


 Dis  patch/ 
 NC(%) 


 0.87% 
 0.40% 
 0.87% 
 0.32% 
 0.89% 
 0.38% 
 0.94% 
 0.44% 


 A.  3.2.2.1 
 Business/  Dis 
 patch/  NC(%) 


 1.02% 
 0.95% 
 1.22% 
 1.06% 
 1.22% 
 1.07% 
 1.25% 
 1.29% 


 A.  3.2.2.2 
 Business/  Non- 


 Dis 
 patch/  NC(%) 


 0.60% 
 0.33% 
 0.59% 
 0.24% 
 0.66% 
 0.45% 
 0.66% 
 0.45% 


 A.  3.2.3.1 
 Desi 
 gn 
 (Specials)/  Dispatch/ 


 NC(%) 


 0.70% 
 0.99% 
 0.82% 
 1.73% 
 0.90% 
 2.48% 
 0.99% 
 0.98% 


 A.  3.2.3.2 
 Desi 
 gn 
 (Specials)/  Non- 


 Dispatch/  NC(%) 


 1.29% 
 0.85% 
 1.37% 
 1.93% 
 1.59% 
 1.17% 
 1.49% 
 1.26% 


 A.  3.2.4.1 
 PBX/  Dis 
 patch/  NC(%) 


 0.18% 
 1.08% 
 0.20% 
 0.46% 
 0.20% 
 0.46% 
 0.21% 
 6.32% 


 A.  3.2.4.2 
 PBX/  Non- 
 Dis 
 patch/  NC(%) 


 0.20% 
 0.00% 
 0.18% 
 0.31% 
 0.21% 
 0.31% 
 0.22% 
 0.16% 


 A.  3.2.5.1 
 Centrex/  Dis 
 patch/  NC(%) 


 0.44% 
 0.98% 
 0.47% 
 0.00% 
 0.49% 
 0.65% 
 0.35% 
 0.74% 


 A.  3.2.5.2 
 Centrex/  Non- 
 Dis 
 patch/  NC(%) 


 0.36% 
 0.00% 
 0.34% 
 0.31% 
 0.31% 
 0.65% 
 0.27% 
 0.00% 


 A.  3.2.6.1 
 ISDN/  Dis 
 patch/  NC(%) 


 0.05% 
 0.51% 
 0.07% 
 0.35% 
 0.05% 
 0.21% 
 0.06% 
 0.11% 


 A.  3.2.6.2 
 ISDN/  Non- 
 Dis 
 patch/  NC(%) 


 0.11% 
 0.51% 
 0.11% 
 0.23% 
 0.10% 
 0.11% 
 0.12% 
 0.11% 


 E-  11 
299
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 North 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 Maintenance 
 Average 
 Duration 


 [M&  R- 
 3] 


 A.  3.3.1.1 
 Residence/  Dis 
 patch/  NC( 
 hours) 


 15.66 
 10.06 
 17.15 
 11.69 
 17.46 
 11.11 
 19.31 
 11.93 


 A.  3.3.1.2 
 Residence/  Non- 


 Dis  patch/ 
 NC( 
 hours) 


 5.05 
 3.01 
 5.81 
 2.80 
 6.25 
 2.78 
 7.26 
 2.44 


 A.  3.3.2.1 
 Business/  Dis 
 patch/  NC( 
 hours) 


 11.37 
 10.71 
 11.76 


 8.87 
 11.36 


 8.76 
 11.89 


 9.51 


 A.  3.3.2.2 
 Business/  Non- 


 Dis 
 patch/  NC( 


 hours) 


 3.05 
 3.97 
 4.09 
 3.21 
 3.34 
 1.67 
 3.01 
 2.53 


 A.  3.3.3.1 
 Desi 
 gn 
 (Specials)/  Dispatch/ 


 NC( 
 hours) 


 4.25 
 3.21 
 5.13 
 5.52 
 4.37 
 4.33 
 5.17 
 3.78 


 A.  3.3.3.2 
 Desi 
 gn 
 (Specials)/  Non- 


 Dispatch/  NC( 
 hours) 


 2.24 
 2.16 
 2.30 
 2.00 
 2.12 
 3.00 
 2.27 
 2.48 


 A.  3.3.4.1 
 PBX/  Dis 
 patch/  NC( 


 hours) 


 13.28 
 11.12 


 9.88 
 2.88 
 10.82 


 4.50 
 8.52 
 6.23 
 1,2,3 


 A.  3.3.4.2 
 PBX/  Non- 
 Dis 
 patch/  NC( 


 hours) 


 4.63 
 0.00 
 2.69 
 2.28 
 4.85 
 2.93 
 2.63 
 1.00 
 2,3,4 


 A.  3.3.5.1 
 Centrex/  Dis 
 patch/  NC( 
 hours) 


 12.36 
 3.97 
 14.48 


 0.00 
 13.08 


 12.33 
 14.48 
 38.83 
 3,4 


 A.  3.3.5.2 
 Centrex/  Non- 
 Dis 
 patch/  NC( 


 hours) 


 3.03 
 0.00 
 3.54 
 2.67 
 3.52 
 2.00 
 3.13 
 0.00 
 2,3 


 A.  3.3.6.1 
 ISDN/  Dis 
 patch/  NC( 
 hours) 


 3.76 
 3.22 
 4.94 
 2.35 
 4.19 
 2.80 
 5.99 
 4.88 
 1,2,3,4 


 A.  3.3.6.2 
 ISDN/  Non- 
 Dis 
 patch/  NC( 


 hours) 


 1.77 
 2.00 
 2.15 
 2.48 
 1.42 
 0.35 
 1.96 
 0.32 
 1,2,3,4 


 % 
 Repeat 


 Troubles 


 within 
 30 
 Days 


 [M&  R- 


 4] 


 A.  3.4.1.1 
 Residence/  Dis 
 patch/  NC(%) 


 14.77% 
 7.58% 
 16.67% 


 7.97% 
 15.50% 


 9.53% 
 15.65% 
 11.74% 


 A.  3.4.1.2 
 Residence/  Non- 


 Dis  patch/ 
 NC(%) 


 13.19% 
 14.29% 
 14.33% 
 16.54% 
 13.68% 
 12.80% 
 14.58% 
 14.79% 


 A.  3.4.2.1 
 Business/  Dis 
 patch/  NC(%) 


 11.25% 
 6.25% 
 12.63% 


 5.33% 
 13.52% 
 14.74% 
 14.11% 
 11.76% 


 A.  3.4.2.2 
 Business/  Non- 


 Dis 
 patch/  NC(%) 


 10.77% 
 3.64% 
 12.68% 


 7.69% 
 11.56% 
 15.15% 
 14.10% 
 6.78% 


 A.  3.4.3.1 
 Desi 
 gn 
 (Specials)/  Dispatch/ 


 NC(%) 


 16.49% 
 21.43% 
 21.00% 
 20.00% 
 20.71% 
 33.33% 
 24.48% 
 14.29% 


 A.  3.4.3.2 
 Desi 
 gn 
 (Specials)/  Non- 


 Dispatch/  NC(%) 


 15.67% 
 0.00% 
 17.88% 


 7.14% 
 16.81% 
 29.41% 
 16.90% 
 11.11% 


 A.  3.4.4.1 
 PBX/  Dis 
 patch/  NC(%) 


 9.03% 
 28.57% 
 13.58% 
 33.33% 
 15.72% 
 0.00% 
 16.36% 
 47.50% 
 1,2,3 


 A.  3.4.4.2 
 PBX/  Non- 
 Dis 
 patch/  NC(%) 


 8.70% 
 0.00% 
 10.07% 
 50.00% 
 7.23% 
 0.00% 
 15.38% 


 0.00% 
 2,3,4 


 A.  3.4.5.1 
 Centrex/  Dis 
 patch/  NC(%) 


 12.67% 
 0.00% 
 13.41% 


 0.00% 
 10.43% 


 0.00% 
 13.44% 
 16.67% 


 3,4 


 A.  3.4.5.2 
 Centrex/  Non- 
 Dis 
 patch/  NC(%) 


 11.91% 
 0.00% 
 14.67% 


 0.00% 
 10.15% 
 16.67% 
 15.40% 
 0.00% 
 2,3 


 A.  3.4.6.1 
 ISDN/  Dis 
 patch/  NC(%) 


 8.79% 
 33.33% 
 14.53% 
 0.00% 
 17.24% 


 0.00% 
 15.15% 


 0.00% 
 1,2,3,4 


 A.  3.4.6.2 
 ISDN/  Non- 
 Dis 
 patch/  NC(%) 


 11.24% 
 33.33% 
 9.09% 
 0.00% 
 13.22% 


 0.00% 
 17.09% 


 0.00% 
 1,2,3,4 


 Out 
 of 
 Service 


 > 
 24 


 hours 


 [M&  R- 


 5] 


 A.  3.5.1.1 
 Residence/  Dis 
 patch/  NC(%) 


 5.30% 
 2.53% 
 6.91% 
 2.00% 
 7.03% 
 2.97% 
 9.84% 
 3.49% 


 A.  3.5.1.2 
 Residence/  Non- 


 Dis  patch/ 
 NC(%) 


 2.04% 
 0.00% 
 2.01% 
 0.00% 
 2.70% 
 0.00% 
 4.53% 
 4.11% 


 A.  3.5.2.1 
 Business/  Dis 
 patch/  NC(%) 


 4.50% 
 1.77% 
 5.91% 
 0.83% 
 5.33% 
 3.48% 
 5.24% 
 3.17% 


 A.  3.5.2.2 
 Business/  Non- 


 Dis 
 patch/  NC(%) 


 1.66% 
 0.00% 
 2.97% 
 0.00% 
 1.67% 
 0.00% 
 1.66% 
 0.00% 


 A.  3.5.3.1 
 Desi 
 gn 
 (Specials)/  Dispatch/ 


 NC(%) 


 0.00% 
 0.00% 
 0.63% 
 4.00% 
 0.29% 
 2.78% 
 1.43% 
 0.00% 


 A.  3.5.3.2 
 Desi 
 gn 
 (Specials)/  Non- 


 Dispatch/  NC(%) 


 0.49% 
 0.00% 
 0.28% 
 0.00% 
 0.32% 
 0.00% 
 0.26% 
 0.00% 


 E-  12 
300
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 North 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 A.  3.5.4.1 
 PBX/  Dispatch/ 


 NC(%) 


 9.52% 
 0.00% 
 4.69% 
 0.00% 
 2.42% 
 0.00% 
 3.20% 
 0.00% 
 1,2,3 


 A.  3.5.4.2 
 PBX/  Non- 
 Dis 
 patch/  NC(%) 


 7.46% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 2,3 


 A.  3.5.5.1 
 Centrex/  Dis 
 patch/  NC(%) 


 8.40% 
 0.00% 
 9.12% 
 0.00% 
 11.36% 


 0.00% 
 12.03% 
 50.00% 
 1,3,4 


 A.  3.5.5.2 
 Centrex/  Non- 
 Dis 
 patch/  NC(%) 


 1.55% 
 0.00% 
 1.68% 
 0.00% 
 0.74% 
 0.00% 
 1.61% 
 0.00% 


 2,3 


 A.  3.5.6.1 
 ISDN/  Dis 
 patch/  NC(%) 


 0.00% 
 0.00% 
 0.85% 
 0.00% 
 0.00% 
 0.00% 
 2.04% 
 0.00% 
 1,2,3,4 


 A.  3.5.6.2 
 ISDN/  Non- 
 Dis 
 patch/  NC(%) 


 0.00% 
 0.00% 
 0.54% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3,4 


 RESALE 
 - 
 BILLING  Invoice  Accuracy 


 [B-  1] 


 A.  4.1 
 NC(%) 


 98.45% 
 99.56% 
 98.22% 
 99.91% 
 98.73% 
 99.47% 
 98.73% 
 99.91% 


 Mean 
 Time 
 to 
 Deliver 


 Invoices 


 - 
 CRIS 


 [B-  2] 


 A.  4.2 
 Re 
 gion( 


 business 


 days) 


 3.68 
 3.56 
 3.86 
 3.27 
 3.47 
 3.16 
 3.82 
 3.37 


 UNBUNDLED 
 NETWORK 
 ELEMENTS 


 - 
 ORDERING 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Mechanized 


 [O-  7] 


 B.  1.1.3 
 Loo  p 
 + 
 Port 


 Combinations/  NC(%) 


 19.81% 
 15.17% 
 14.21% 
 13.37% 


 B.  1.1.4 
 Combo 
 Other/  NC 


 (%) 


 20.00% 


 B.  1.1.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  NC(%) 


 42.66% 
 28.26% 
 17.83% 
 18.90% 


 B.  1.1.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  NC(%) 


 41.67% 
 30.00% 
 7.69% 
 32.14% 


 B.  1.1.7 
 Line 
 Sharin  g/ 


 NC(%) 


 20.59% 
 33.33% 
 37.04% 
 44.83% 


 B.  1.1.8 
 2W 
 Analo  g 


 Loop 
 Design/  NC(%) 


 25.35% 
 22.89% 
 25.57% 
 15.92% 


 B.  1.1.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 NC(%) 


 2.78% 
 6.15% 
 0.00% 
 0.00% 
 3 


 B.  1.1.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  NC(%) 


 23.53% 
 51.85% 
 19.61% 
 55.56% 


 B.  1.1.14 
 Other 
 Desi  gn/ 


 NC(%) 


 7.48% 
 11.79% 


 8.97% 
 14.13% 


 B.  1.1.15 
 Other 
 Non-  Desi 


 gn/  NC(%) 


 21.05% 
 6.91% 
 9.81% 
 10.78% 


 B.  1.1.16 
 INP 
 Standalone/  NC 


 (%) 


 0.00% 
 0.00% 


 1,2 


 B.  1.1.17 
 LNP 
 Standalone/  NC 


 (%) 


 12.69% 
 11.97% 
 9.40% 
 12.32% 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Partially 


 Mechanized 


 [O-  7] 


 B.  1.2.3 
 Loo  p 
 + 
 Port 


 Combinations/  NC(%) 


 25.43% 
 22.20% 
 29.36% 
 34.05% 


 B.  1.2.4 
 Combo 
 Other/  NC 


 (%) 


 0.00% 
 4 


 B.  1.2.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  NC(%) 


 0.00% 
 5.56% 
 6.67% 
 0.00% 
 4 


 B.  1.2.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  NC(%) 


 5.26% 
 8.40% 
 10.11% 


 7.14% 


 B.  1.2.7 
 Line 
 Sharin  g/ 


 NC(%) 


 53.06% 
 40.43% 
 41.30% 
 25.00% 


 B.  1.2.8 
 2W 
 Analo  g 


 Loop 
 Design/  NC(%) 


 26.18% 
 24.53% 
 25.37% 
 15.29% 


 B.  1.2.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 NC(%) 


 50.00% 
 33.33% 
 0.00% 
 0.00% 
 1,2,3,4 


 E-  13 
301
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 North 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  1.2.12 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/  NC(%) 


 24.50% 
 26.24% 
 29.15% 
 28.20% 


 B.  1.2.13 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Non-  Design/ 


 NC(%) 


 33.33% 
 4 


 B.  1.2.14 
 Other 
 Desi 
 gn/  NC(%) 


 19.85% 
 17.69% 
 25.66% 
 13.76% 


 B.  1.2.15 
 Other 
 Non-  Desi 


 gn/  NC(%) 


 25.93% 
 38.54% 
 27.48% 
 48.10% 


 B.  1.2.16 
 INP 
 Standalone/  NC 


 (%) 


 100.00% 


 1 


 B.  1.2.17 
 LNP 
 Standalone/  NC 


 (%) 


 36.26% 
 27.80% 
 36.45% 
 34.90% 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Non-  Mechanized 


 [O-  7] 


 B.  1.3.1 
 Switch 
 Ports/  NC 


 (%) 


 0.00% 
 3 


 B.  1.3.2 
 Local 
 Interoffice 


 Trans  port/ 
 NC(%) 


 61.11% 
 26.67% 
 16.67% 


 3 


 B.  1.3.3 
 Loo  p 
 + 
 Port 


 Combinations/  NC(%) 


 61.25% 
 38.67% 
 52.45% 
 45.95% 


 B.  1.3.4 
 Combo 
 Other/  NC 


 (%) 


 0.00% 
 35.71% 
 3 


 B.  1.3.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  NC(%) 


 33.85% 
 25.64% 
 28.13% 
 11.11% 


 B.  1.3.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  NC(%) 


 22.88% 
 25.61% 
 19.51% 
 19.57% 


 B.  1.3.7 
 Line 
 Sharin  g/ 


 NC(%) 


 23.81% 
 27.27% 
 36.36% 
 44.44% 
 4 


 B.  1.3.8 
 2W 
 Analo  g 


 Loop 
 Design/  NC(%) 


 23.64% 
 26.52% 
 30.58% 
 26.85% 


 B.  1.3.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 NC(%) 


 25.00% 
 47.93% 
 41.09% 
 44.78% 
 1 


 B.  1.3.10 
 2W 
 Analo  g 


 Loop 
 w/  INP 


 Design/  NC(%) 


 26.67% 
 33.33% 
 0.00% 
 18.18% 
 3 


 B.  1.3.11 
 2W 
 Analo  g 


 Loop 
 w/  INP 


 Non-  Design/ 


 NC(%) 


 0.00% 
 100.00% 


 2,3 


 B.  1.3.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  NC(%) 


 34.34% 
 27.10% 
 32.35% 
 41.29% 


 B.  1.3.13 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Non-  Design/ 


 NC(%) 


 33.33% 
 100.00% 
 3,4 


 B.  1.3.14 
 Other 
 Desi  gn/ 


 NC(%) 


 33.67% 
 30.97% 
 35.82% 
 32.26% 


 B.  1.3.15 
 Other 
 Non-  Desi 


 gn/  NC(%) 


 27.08% 
 29.81% 
 34.33% 
 34.61% 


 B.  1.3.16 
 INP 
 Standalone/  NC 


 (%) 


 50.00% 
 55.56% 
 39.13% 
 38.10% 


 B.  1.3.17 
 LNP 
 Standalone/  NC 


 (%) 


 35.45% 
 32.25% 
 34.92% 
 30.28% 


 Reject 
 Interval 


 - 
 Mechanized 


 [O-  8] 


 B.  1.4.3 
 Loo  p 
 + 
 Port 


 Combinations/  NC(%) 


 95.85% 
 97.81% 
 92.56% 
 93.73% 


 B.  1.4.4 
 Combo 
 Other/  NC 


 (%) 


 50.00% 
 4 


 B.  1.4.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  NC(%) 


 98.92% 
 100.00% 


 97.62% 
 97.92% 


 B.  1.4.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  NC(%) 


 66.67% 
 66.67% 
 100.00% 


 90.00% 
 2,3 


 B.  1.4.7 
 Line 
 Sharin  g/ 


 NC(%) 


 42.86% 
 80.00% 
 80.00% 
 61.54% 
 1 


 B.  1.4.8 
 2W 
 Analo  g 


 Loop 
 Design/  NC(%) 


 90.00% 
 82.76% 
 86.18% 
 77.66% 


 B.  1.4.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 NC(%) 


 100.00% 
 100.00% 


 1,2 


 B.  1.4.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  NC(%) 


 100.00% 
 100.00% 
 80.00% 
 100.00% 


 B.  1.4.14 
 Other 
 Desi  gn/ 


 NC(%) 


 81.25% 
 69.23% 
 47.62% 
 71.43% 


 E-  14 
302
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 North 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  1.4.15 
 Other 
 Non-  Design/ 


 NC(%) 


 93.75% 
 78.95% 
 67.74% 
 75.61% 


 B.  1.4.17 
 LNP 
 Standalone/  NC 


 (%) 


 100.00% 
 100.00% 
 100.00% 
 94.44% 


 Reject 
 Interval 


 - 
 Partially 


 Mechanized 


 - 
 10 


 hours 


 [O-  8] 


 B.  1.7.3 
 Loo  p 
 + 
 Port 


 Combinations/  NC(%) 


 94.95% 
 97.59% 
 95.96% 
 96.36% 


 B.  1.7.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  NC(%) 


 0.00% 
 100.00% 


 2,3 


 B.  1.7.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  NC(%) 


 100.00% 
 70.00% 
 81.82% 
 100.00% 
 1,4 


 B.  1.7.7 
 Line 
 Sharin  g/ 


 NC(%) 


 88.46% 
 90.00% 
 78.95% 
 100.00% 
 4 


 B.  1.7.8 
 2W 
 Analo  g 


 Loop 
 Design/  NC(%) 


 79.22% 
 82.05% 
 88.24% 
 63.33% 


 B.  1.7.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 NC(%) 


 100.00% 
 0.00% 


 100.00% 
 1,2,4 


 B.  1.7.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  NC(%) 


 98.75% 
 94.83% 
 87.88% 
 85.71% 


 B.  1.7.13 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Non-  Design/ 


 NC(%) 


 0.00% 


 100.00% 
 1,4 


 B.  1.7.14 
 Other 
 Desi  gn/ 


 NC(%) 


 100.00% 
 86.96% 
 89.66% 
 93.33% 


 B.  1.7.15 
 Other 
 Non-  Desi 


 gn/  NC(%) 


 95.45% 
 100.00% 


 78.95% 
 80.85% 


 B.  1.7.16 
 INP 
 Standalone/  NC 


 (%) 


 66.67% 


 1 


 B.  1.7.17 
 LNP 
 Standalone/  NC 


 (%) 


 73.44% 
 84.13% 
 77.63% 
 85.92% 


 Reject 
 Interval 


 - 
 Non-  Mechanized 


 [O-  8] 


 B.  1.8.2 
 Local 
 Interoffice 


 Trans  port/ 
 NC(%) 


 100.00% 
 100.00% 
 100.00% 


 2,3 


 B.  1.8.3 
 Loo  p 
 + 
 Port 


 Combinations/  NC(%) 


 98.83% 
 98.31% 
 99.12% 
 97.67% 


 B.  1.8.4 
 Combo 
 Other/  NC 


 (%) 


 100.00% 
 4 


 B.  1.8.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  NC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 3,4 


 B.  1.8.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  NC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  1.8.7 
 Line 
 Sharin  g/ 


 NC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 B.  1.8.8 
 2W 
 Analo  g 


 Loop 
 Design/  NC(%) 


 96.43% 
 100.00% 
 100.00% 
 100.00% 


 B.  1.8.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 NC(%) 


 100.00% 
 98.31% 
 100.00% 
 100.00% 
 1 


 B.  1.8.10 
 2W 
 Analo  g 


 Loop 
 w/  INP 


 Design/  NC(%) 


 75.00% 
 100.00% 


 100.00% 
 1,2,4 


 B.  1.8.11 
 2W 
 Analo  g 


 Loop 
 w/  INP 


 Non-  Design/ 


 NC(%) 


 60.00% 
 3 


 B.  1.8.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  NC(%) 


 100.00% 
 97.62% 
 98.21% 
 100.00% 


 B.  1.8.13 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Non-  Design/ 


 NC(%) 


 100.00% 
 100.00% 
 3,4 


 B.  1.8.14 
 Other 
 Desi  gn/ 


 NC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  1.8.15 
 Other 
 Non-  Desi 


 gn/  NC(%) 


 100.00% 
 99.48% 
 99.23% 
 100.00% 


 B.  1.8.16 
 INP 
 Standalone/  NC 


 (%) 


 83.33% 
 100.00% 
 100.00% 
 100.00% 
 4 


 B.  1.8.17 
 LNP 
 Standalone/  NC 


 (%) 


 98.52% 
 97.50% 
 98.18% 
 98.98% 


 FOC 
 Timeliness 


 - 
 Mechanized 


 [O-  9] 


 E-  15 
303
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 North 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  1.9.3 
 Loop 
 + 
 Port 


 Combinations/  NC(%) 


 99.33% 
 96.70% 
 97.49% 
 98.02% 


 B.  1.9.4 
 Combo 
 Other/  NC 


 (%) 


 83.33% 
 4 


 B.  1.9.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  NC(%) 


 98.00% 
 97.24% 
 96.70% 
 100.00% 


 B.  1.9.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  NC(%) 


 95.24% 
 100.00% 
 100.00% 
 100.00% 
 3 


 B.  1.9.7 
 Line 
 Sharin  g/ 


 NC(%) 


 100.00% 
 100.00% 
 100.00% 
 94.12% 


 B.  1.9.8 
 2W 
 Analo  g 


 Loop 
 Design/  NC(%) 


 100.00% 
 99.67% 
 98.59% 
 97.99% 


 B.  1.9.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 NC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 3 


 B.  1.9.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  NC(%) 


 94.87% 
 100.00% 


 97.22% 
 100.00% 


 B.  1.9.14 
 Other 
 Desi  gn/ 


 NC(%) 


 100.00% 
 100.00% 
 98.04% 
 98.11% 


 B.  1.9.15 
 Other 
 Non-  Desi 


 gn/  NC(%) 


 69.89% 
 50.46% 
 47.86% 
 41.18% 


 B.  1.9.16 
 INP 
 Standalone/  NC 


 (%) 


 100.00% 
 100.00% 


 1,2 


 B.  1.9.17 
 LNP 
 Standalone/  NC 


 (%) 


 100.00% 
 99.03% 
 100.00% 


 96.64% 


 FOC 
 Timeliness 


 - 
 Partially 


 Mechanized 


 - 
 10 


 hours 


 [O-  9] 


 B.  1.12.3 
 Loo  p 
 + 
 Port 


 Combinations/  NC(%) 


 93.11% 
 91.56% 
 87.96% 
 91.93% 


 B.  1.12.4 
 Combo 
 Other/  NC 


 (%) 


 100.00% 
 4 


 B.  1.12.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  NC(%) 


 88.89% 
 91.67% 
 84.62% 
 100.00% 
 1,4 


 B.  1.12.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  NC(%) 


 94.51% 
 94.23% 
 91.86% 
 94.44% 


 B.  1.12.7 
 Line 
 Sharin  g/ 


 NC(%) 


 83.33% 
 100.00% 
 100.00% 
 80.95% 


 B.  1.12.8 
 2W 
 Analo  g 


 Loop 
 Design/  NC(%) 


 91.28% 
 95.31% 
 93.46% 
 95.71% 


 B.  1.12.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 NC(%) 


 50.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 B.  1.12.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  NC(%) 


 96.14% 
 94.77% 
 91.70% 
 91.75% 


 B.  1.12.13 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Non-  Design/ 


 NC(%) 


 0.00% 
 4 


 B.  1.12.14 
 Other 
 Desi 
 gn/  NC(%) 


 87.72% 
 91.96% 
 90.43% 
 91.00% 


 B.  1.12.15 
 Other 
 Non-  Desi 


 gn/  NC(%) 


 68.75% 
 63.41% 
 81.93% 
 66.00% 


 B.  1.12.16 
 INP 
 Standalone/  NC 


 (%) 


 B.  1.12.17 
 LNP 
 Standalone/  NC(%) 


 86.11% 
 87.82% 
 88.15% 
 83.74% 


 FOC 
 Timeliness 


 - 
 Non-  Mechanized 


 [O-  9] 


 B.  1.13.1 
 Switch 
 Ports/  NC 


 (%) 


 100.00% 
 3 


 B.  1.13.2 
 Local 
 Interoffice 


 Trans  port/ 
 NC(%) 


 100.00% 
 100.00% 
 100.00% 


 1,2,3 


 B.  1.13.3 
 Loo  p 
 + 
 Port 


 Combinations/  NC(%) 


 98.85% 
 100.00% 


 98.81% 
 100.00% 


 B.  1.13.4 
 Combo 
 Other/  NC 


 (%) 


 100.00% 
 100.00% 
 3,4 


 B.  1.13.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  NC(%) 


 100.00% 
 100.00% 
 100.00% 
 91.67% 


 B.  1.13.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  NC(%) 


 100.00% 
 100.00% 
 100.00% 
 96.40% 


 B.  1.13.7 
 Line 
 Sharin  g/ 


 NC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 E-  16 
304
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 North 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  1.13.8 
 2W 
 Analog 


 Loop 
 Design/  NC(%) 


 100.00% 
 99.44% 
 99.40% 
 100.00% 


 B.  1.13.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 NC(%) 


 100.00% 
 98.36% 
 100.00% 
 100.00% 
 1 


 B.  1.13.10 
 2W 
 Analo  g 


 Loop 
 w/  INP 


 Design/  NC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2,3 


 B.  1.13.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  NC(%) 


 97.35% 
 98.78% 
 100.00% 


 98.94% 


 B.  1.13.13 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Non-  Design/ 


 NC(%) 


 100.00% 
 100.00% 
 3,4 


 B.  1.13.14 
 Other 
 Desi  gn/ 


 NC(%) 


 99.23% 
 100.00% 
 100.00% 
 99.24% 


 B.  1.13.15 
 Other 
 Non-  Desi 


 gn/  NC(%) 


 99.39% 
 99.26% 
 99.37% 
 98.47% 


 B.  1.13.16 
 INP 
 Standalone/  NC 


 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2 


 B.  1.13.17 
 LNP 
 Standalone/  NC 


 (%) 


 100.00% 
 98.94% 
 100.00% 


 99.53% 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Mechanized 


 [O-  11] 


 B.  1.14.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  EDI/ 


 NC(%) 


 98.64% 
 100.00% 


 91.28% 
 93.49% 


 B.  1.14.3.2 
 Loo  p 
 + 
 Port 


 Combinations/  TAG/ 


 NC(%) 


 99.23% 
 98.56% 
 98.43% 
 99.91% 


 B.  1.14.4.2 
 Combo 
 Other/  TAG/ 


 NC  (%) 


 80.00% 


 B.  1.14.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  EDI/ 


 NC(%) 


 97.56% 
 96.61% 
 98.05% 
 95.28% 


 B.  1.14.5.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  TAG/ 


 NC(%) 


 73.68% 
 90.00% 
 84.00% 
 80.31% 


 B.  1.14.6.1 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  EDI/ 


 NC(%) 


 100.00% 


 0.00% 
 90.91% 
 1,3 


 B.  1.14.6.2 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  TAG/ 


 NC(%) 


 97.14% 
 90.00% 
 58.33% 
 100.00% 


 B.  1.14.7.1 
 Line 
 Sharin  g/ 


 EDI/  NC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  1.14.7.2 
 Line 
 Sharin  g/ 


 TAG/  NC(%) 


 90.91% 
 80.00% 
 87.50% 
 100.00% 
 3 


 B.  1.14.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  EDI/ 


 NC(%) 


 98.83% 
 99.37% 
 96.92% 
 98.12% 


 B.  1.14.8.2 
 2W 
 Analo  g 


 Loop 
 Design/  TAG/ 


 NC(%) 


 100.00% 
 96.77% 
 94.51% 
 100.00% 


 B.  1.14.9.1 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 EDI/  NC(%) 


 100.00% 
 96.55% 
 100.00% 
 100.00% 
 3,4 


 B.  1.14.9.2 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 TAG/  NC(%) 


 91.67% 
 100.00% 


 75.00% 
 100.00% 
 2,3 


 B.  1.14.12.1 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  EDI/ 


 NC(%) 


 100.00% 
 96.30% 
 88.00% 
 92.59% 


 B.  1.14.12.2 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  TAG/ 


 NC(%) 


 100.00% 


 100.00% 
 1,3 


 B.  1.14.14.1 
 Other 
 Desi  gn/ 


 EDI/  NC(%) 


 99.35% 
 100.00% 


 93.12% 
 98.53% 


 B.  1.14.14.2 
 Other 
 Desi  gn/ 


 TAG/  NC(%) 


 98.33% 
 97.67% 
 100.00% 
 100.00% 


 B.  1.14.15.1 
 Other 
 Non-  Desi 


 gn/  EDI/ 
 NC(%) 


 100.00% 
 100.00% 
 87.50% 
 100.00% 


 B.  1.14.15.2 
 Other 
 Non-  Desi 


 gn/  TAG/ 
 NC(%) 


 77.66% 
 80.89% 
 77.90% 
 80.51% 


 B.  1.14.16.1 
 INP 
 Standalone/  EDI/ 


 NC  (%) 


 100.00% 
 100.00% 


 1,2 


 B.  1.14.17.1 
 LNP 
 Standalone/  EDI/ 


 NC  (%) 


 98.35% 
 100.00% 


 96.30% 
 97.64% 


 B.  1.14.17.2 
 LNP 
 Standalone/  TAG/ 


 NC  (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2,3 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Partially 


 Mechanized 


 [O-  11] 


 B.  1.15.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  EDI/ 


 NC(%) 


 100.00% 
 100.00% 
 100.00% 
 97.96% 


 E-  17 
305
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 North 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  1.15.3.2 
 Loop 
 + 
 Port 


 Combinations/  TAG/ 


 NC(%) 


 99.06% 
 98.79% 
 99.20% 
 100.00% 


 B.  1.15.4.2 
 Combo 
 Other/  TAG/ 


 NC  (%) 


 50.00% 
 4 


 B.  1.15.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  EDI/ 


 NC(%) 


 54.55% 
 60.00% 
 70.00% 


 B.  1.15.5.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  TAG/ 


 NC(%) 


 28.57% 
 100.00% 
 100.00% 
 50.00% 
 2,3,4 


 B.  1.15.6.1 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  EDI/ 


 NC(%) 


 100.00% 
 100.00% 
 90.48% 
 100.00% 
 4 


 B.  1.15.6.2 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  TAG/ 


 NC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 4 


 B.  1.15.7.1 
 Line 
 Sharin  g/ 


 EDI/  NC(%) 


 100.00% 
 100.00% 
 92.86% 
 100.00% 


 B.  1.15.7.2 
 Line 
 Sharin  g/ 


 TAG/  NC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  1.15.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  EDI/ 


 NC(%) 


 100.00% 
 100.00% 
 92.77% 
 100.00% 


 B.  1.15.8.2 
 2W 
 Analo  g 


 Loop 
 Design/  TAG/ 


 NC(%) 


 97.26% 
 100.00% 
 100.00% 
 100.00% 


 B.  1.15.9.1 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 EDI/  NC(%) 


 100.00% 
 100.00% 
 100.00% 


 1,2,3 


 B.  1.15.9.2 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 TAG/  NC(%) 


 100.00% 
 100.00% 


 100.00% 
 1,2,4 


 B.  1.15.12.1 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  EDI/ 


 NC(%) 


 99.64% 
 99.51% 
 100.00% 


 99.60% 


 B.  1.15.12.2 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  TAG/ 


 NC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  1.15.13.1 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Non-  Design/ 


 EDI/  NC(%) 


 B.  1.15.13.2 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/ 


 TAG/  NC(%) 


 100.00% 
 4 


 B.  1.15.14.1 
 Other 
 Desi  gn/ 


 EDI/  NC(%) 


 100.00% 
 100.00% 
 89.71% 
 100.00% 


 B.  1.15.14.2 
 Other 
 Desi  gn/ 


 TAG/  NC(%) 


 100.00% 
 97.73% 
 100.00% 
 100.00% 


 B.  1.15.15.1 
 Other 
 Non-  Desi 


 gn/  EDI/ 
 NC(%) 


 100.00% 
 100.00% 
 92.50% 
 100.00% 


 B.  1.15.15.2 
 Other 
 Non-  Desi 


 gn/  TAG/ 
 NC(%) 


 94.44% 
 93.06% 
 83.52% 
 94.92% 


 B.  1.15.16.1 
 INP 
 Standalone/  EDI/ 


 NC  (%) 


 100.00% 


 1 


 B.  1.15.17.1 
 LNP 
 Standalone/  EDI/ 


 NC  (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  1.15.17.2 
 LNP 
 Standalone/  TAG/ 


 NC  (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Non-  Mechanized 


 [O-  11] 


 B.  1.16.1 
 Switch 
 Ports/  NC 


 (%) 


 100.00% 
 3 


 B.  1.16.2 
 Local 
 Interoffice 


 Trans  port/ 
 NC(%) 


 100.00% 
 93.33% 
 100.00% 


 3 


 B.  1.16.3 
 Loo  p 
 + 
 Port 


 Combinations/  NC(%) 


 92.25% 
 97.33% 
 94.61% 
 94.05% 


 B.  1.16.4 
 Combo 
 Other/  NC 


 (%) 


 100.00% 
 92.86% 
 3 


 B.  1.16.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  NC(%) 


 99.23% 
 97.44% 
 96.88% 
 100.00% 


 B.  1.16.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  NC(%) 


 99.26% 
 98.78% 
 97.56% 
 97.83% 


 B.  1.16.7 
 Line 
 Sharin  g/ 


 NC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 4 


 B.  1.16.8 
 2W 
 Analo  g 


 Loop 
 Design/  NC(%) 


 94.55% 
 97.73% 
 96.28% 
 100.00% 


 B.  1.16.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 NC(%) 


 87.50% 
 99.17% 
 89.92% 
 97.76% 
 1 


 B.  1.16.10 
 2W 
 Analo  g 


 Loop 
 w/  INP 


 Design/  NC(%) 


 100.00% 
 91.67% 
 40.00% 
 100.00% 
 3 


 E-  18 
306
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 North 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  1.16.11 
 2W 
 Analog 


 Loop 
 w/  INP 


 Non-  Design/ 


 NC(%) 


 0.00% 
 100.00% 


 2,3 


 B.  1.16.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  NC(%) 


 94.44% 
 98.71% 
 96.47% 
 97.42% 


 B.  1.16.13 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Non-  Design/ 


 NC(%) 


 66.67% 
 100.00% 
 3,4 


 B.  1.16.14 
 Other 
 Desi  gn/ 


 NC(%) 


 98.99% 
 96.77% 
 98.51% 
 99.46% 


 B.  1.16.15 
 Other 
 Non-  Desi 


 gn/  NC(%) 


 97.77% 
 96.06% 
 96.47% 
 99.23% 


 B.  1.16.16 
 INP 
 Standalone/  NC 


 (%) 


 87.50% 
 100.00% 


 82.61% 
 85.71% 


 B.  1.16.17 
 LNP 
 Standalone/  NC 


 (%) 


 97.09% 
 96.48% 
 94.58% 
 96.21% 


 UNBUNDLED 
 NETWORK 
 ELEMENTS 


 - 
 PROVISIONING 


 Order 
 Completion 


 Interval 
 [P-  4] 


 B.  2.1.2.1.1 
 Local 
 Interoffice 


 Transport/<  10 


 circuits/  Dis 
 patch/  NC( 
 days) 


 14.91 
 11.00 
 19.32 
 16.00 
 15.98 
 14.25 
 16.70 


 1,2,3 


 B.  2.1.3.1.1 
 Loop 
 + 
 Port 


 Combinations/<  10  circuits/  Dis  patch/  NC(  days) 


 3.95 
 2.78 
 4.00 
 3.06 
 4.82 
 3.05 
 5.47 
 3.11 


 B.  2.1.3.1.2 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Non- 


 Dis 
 patch/  NC( 


 days) 


 0.88 
 0.60 
 0.88 
 0.55 
 0.89 
 0.57 
 0.89 
 0.64 


 B.  2.1.3.1.3 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Switch 
 Based 


 Orders/  NC 
 (days) 


 0.33 
 0.33 
 0.33 
 0.33 
 0.33 
 0.33 
 0.33 
 0.33 


 B.  2.1.3.1.4 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Dispatch 


 In/  NC 
 (days) 


 1.49 
 1.09 
 1.47 
 1.10 
 1.49 
 1.15 
 1.47 
 1.22 


 B.  2.1.3.2.1 
 Loop 
 + 
 Port 


 Combinations/>=  10  circuits/  Dis  patch/  NC(  days) 


 13.99 
 2.00 
 10.42 


 4.00 
 9.00 


 10.33 
 2.00 
 1,2,4 


 B.  2.1.3.2.2 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Non- 


 Dis 
 patch/  NC( 


 days) 


 3.21 
 3.89 
 7.17 
 1.87 
 0.33 


 4 


 B.  2.1.3.2.3 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Switch 
 Based 


 Orders/  NC 
 (days) 


 0.33 
 0.33 
 0.33 
 0.33 
 0.33 


 4 


 B.  2.1.4.1.1 
 Combo 
 Other/<  10 


 circuits/  Dis 
 patch/  NC( 
 days) 


 5.02 
 12.07 


 4.97 
 10.67 


 5.79 
 10.70 


 6.51 
 11.31 


 B.  2.1.6.3.1 
 UNE 
 ISDN/<  6 


 circuits/  Dis 


 patch/  NC( 
 days) 


 14.50 
 10.40 
 15.30 


 9.99 
 14.31 


 10.38 
 19.27 
 11.06 


 B.  2.1.7.3.1 
 Line 
 Sharin  g/< 


 6 
 circuits/  Dispatch/ 


 NC( 
 days) 


 4.06 
 4.75 
 4.19 
 4.60 
 3.90 
 5.00 
 2.53 
 3.00 
 1,2,3,4 


 B.  2.1.7.3.2 
 Line 
 Sharin  g/< 


 6 
 circuits/  Non- 


 Dispatch/  NC( 


 days) 


 3.56 
 3.47 
 3.81 
 3.75 
 3.54 
 3.71 
 2.39 
 3.63 


 B.  2.1.8.1.1 
 2W 
 Analog 


 Loop 
 Design/<  10 


 circuits/  Dis 
 patch/  NC( 
 days) 


 3.95 
 4.66 
 4.00 
 4.63 
 4.82 
 4.84 
 5.47 
 4.69 


 B.  2.1.8.2.1 
 2W 
 Analog 


 Loop 
 Design/>=  10 


 circuits/  Dis 
 patch/  NC( 
 days) 


 13.99 
 7.00 
 10.42 


 9.00 
 10.33 
 13.00 
 1,4 


 E-  19 
307
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 North 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  2.1.9.1.1 
 2W 
 Analog 


 Loop 
 Non-  Design/< 


 10 


 circuits/  Dis 
 patch/  NC( 
 days) 


 3.82 
 4.00 
 4.25 
 3.00 
 4.67 
 5.00 
 5.46 
 3.50 
 1,2,3,4 


 B.  2.1.10.1.1 
 2W 
 Analog 


 Loop 
 w/  INP 


 Design/<  10 


 circuits/  Dis 
 patch/  NC( 
 days) 


 3.95 
 7.00 
 4.00 
 5.00 
 4.82 
 5.00 
 5.47 
 6.33 
 1,2,3,4 


 B.  2.1.12.1.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/<  10 


 circuits/  Dis 
 patch/  NC( 
 days) 


 3.95 
 5.63 
 4.00 
 5.36 
 4.82 
 5.54 
 5.47 
 5.25 


 B.  2.1.12.2.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/>=  10 


 circuits/  Dis 
 patch/  NC( 
 days) 


 13.99 
 7.00 
 10.42 


 6.00 
 9.00 
 7.00 
 10.33 


 5.50 
 1,2,3,4 


 B.  2.1.13.1.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/< 


 10 


 circuits/  Dis 
 patch/  NC( 
 days) 


 3.82 
 4.25 
 4.67 
 5.46 


 B.  2.1.14.1.1 
 Other 
 Desi  gn/< 


 10 
 circuits/  Dispatch/ 


 NC( 
 days) 


 21.99 


 21.77 
 27.00 
 20.48 


 18.65 


 2 


 B.  2.1.15.1.1 
 Other 
 Non-  Desi 


 gn/<  10 
 circuits/  Dispatch/ 


 NC( 
 days) 


 3.95 
 5.70 
 4.00 
 5.09 
 4.82 
 5.88 
 5.47 
 5.86 


 4 


 B.  2.1.15.1.2 
 Other 
 Non-  Design/< 


 10 
 circuits/  Non- 


 Dis 
 patch/  NC( 


 days) 


 0.88 
 0.88 
 0.89 
 0.89 


 B.  2.1.16.1.2 
 INP 
 (Standalone)/<  10 


 circuits/  Non- 
 Dispatch/  NC( 


 days) 
 0.87 


 0.87 
 0.33 
 0.88 


 0.88 


 2 


 B.  2.1.17.1.1 
 LNP 
 (Standalone)/<  10 


 circuits/  Dispatch/ 
 NC( 
 days) 


 3.82 
 0.33 
 4.25 
 0.33 
 4.67 
 0.33 
 5.46 
 0.33 
 1,2,3,4 


 B.  2.1.17.1.2 
 LNP 
 (Standalone)/<  10 


 circuits/  Non- 


 Dis 
 patch/  NC( 


 days) 


 0.87 
 0.49 
 0.87 
 0.66 
 0.88 
 0.57 
 0.88 
 0.53 


 B.  2.1.17.2.1 
 LNP 
 (Standalone)/>=  10 


 circuits/  Dispatch/ 
 NC(  days) 
 11.29 


 10.23 
 2.00 
 8.28 


 11.81 


 2 


 B.  2.1.17.2.2 
 LNP 
 (Standalone)/>=  10 


 circuits/  Non- 


 Dis 
 patch/  NC( 


 days) 


 1.78 
 0.33 
 2.67 
 0.42 
 0.70 
 0.67 
 1.23 
 0.33 
 1,2,3,4 


 B.  2.1.18.1.1 
 Digital 
 Loop 
 < 
 DS1/<  10 


 circuits/  Dispatch/ 


 NC(  days) 
 5.51 
 8.72 
 5.45 
 8.83 
 5.21 
 9.42 
 3.74 
 9.69 


 B.  2.1.19.1.1 
 Digital 
 Loop 
 >= 
 DS1/<  10 


 circuits/  Dispatch/ 


 NC(  days) 
 39.96 
 6.09 
 27.98 


 5.83 
 27.92 


 5.64 
 18.81 


 5.90 


 B.  2.1.19.2.1 
 Digital 
 Loop 
 >= 
 DS1/>=  10 


 circuits/  Dispatch/ 


 NC(  days) 
 207.53 


 4.00 
 5.00 
 4 


 Order 
 Completion 


 Interval 
 within 
 X 
 days 


 [P-  4] 


 B.  2.2.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL) 


 Loop 
 with 


 Conditionin  g/< 
 6 
 circuits/  Dispatch/ 


 NC( 
 days) 


 B.  2.2.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL) 


 Loop 
 w/  o 


 Conditionin  g/< 
 6 
 circuits/  Dispatch/ 


 NC( 
 days) 


 4.72 
 4.36 
 4.67 
 4.74 


 E-  20 
308
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 North 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 % 
 Jeopardies 


 - 
 Mechanized 


 [P-  2] 


 B.  2.5.3 
 Loo  p 
 + 
 Port 


 Combinations/  NC(%) 


 0.48% 
 0.22% 
 0.45% 
 0.34% 
 0.43% 
 0.12% 
 0.40% 
 0.12% 


 B.  2.5.4 
 Combo 
 Other/  NC 


 (%) 


 6.13% 
 100.00% 


 6.14% 


 6.91% 
 100.00% 


 7.28% 
 25.00% 


 1,3,4 


 B.  2.5.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  NC(%) 


 13.86% 
 8.69% 
 7.48% 
 7.20% 
 5.26% 


 B.  2.5.6 
 UNE 
 ISDN/  NC 


 (%) 


 7.41% 
 38.64% 
 16.28% 
 24.14% 
 13.48% 
 18.18% 
 7.42% 
 25.00% 


 B.  2.5.7 
 Line 
 Sharin  g/ 


 NC(%) 


 13.86% 
 8.69% 
 0.00% 
 7.48% 


 7.20% 
 0.00% 


 2,4 


 B.  2.5.8 
 2W 
 Analo  g 


 Loop 
 Design/  NC(%) 


 0.48% 
 14.84% 


 0.45% 
 6.20% 
 0.43% 
 12.95% 


 0.40% 
 7.69% 


 B.  2.5.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 NC(%) 


 0.87% 
 0.00% 
 0.81% 
 0.00% 
 0.77% 
 0.00% 
 0.71% 
 0.00% 
 1,2,3,4 


 B.  2.5.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  NC(%) 


 0.48% 
 6.58% 
 0.45% 
 0.98% 
 0.43% 
 6.10% 
 0.40% 
 5.37% 


 B.  2.5.13 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Non-  Design/ 


 NC(%) 


 0.87% 


 0.81% 
 0.77% 
 0.71% 


 B.  2.5.14 
 Other 
 Desi  gn/ 


 NC(%) 


 10.68% 
 14.91% 
 13.70% 
 11.60% 


 B.  2.5.15 
 Other 
 Non-  Desi 


 gn/  NC(%) 


 0.48% 
 0.45% 
 0.43% 
 0.40% 


 B.  2.5.16 
 INP 
 (Standalone)/  NC(%) 


 0.47% 
 0.44% 
 0.42% 
 0.38% 


 B.  2.5.17 
 LNP 
 (Standalone)/  NC(%) 


 0.47% 
 0.00% 
 0.44% 
 0.00% 
 0.42% 
 0.00% 
 0.38% 
 0.00% 


 B.  2.5.18 
 Di 
 gital 


 Loop 


 < 
 DS1/  NC(%) 


 13.14% 
 38.64% 
 9.22% 
 24.14% 


 8.43% 
 18.18% 


 7.53% 
 18.00% 


 B.  2.5.19 
 Di 
 gital 


 Loop 


 >= 
 DS1/  NC(%) 


 3.93% 
 68.66% 
 13.91% 
 64.38% 
 12.92% 
 79.55% 
 14.38% 
 66.67% 


 % 
 Jeopardies 


 - 
 Non-  Mechanized 


 [P-  2] 


 B.  2.6.2 
 Local 
 Interoffice 


 Trans  port/ 
 NC(%) 


 0.00% 
 0.00% 
 12.50% 


 0.00% 
 1,2,3,4 


 B.  2.6.3 
 Loo  p 
 + 
 Port 


 Combinations/  NC(%) 


 0.70% 
 1.61% 
 2.16% 
 2.08% 


 B.  2.6.4 
 Combo 
 Other/  NC 


 (%) 


 52.63% 
 20.00% 
 45.45% 
 41.18% 


 B.  2.6.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  NC(%) 


 1.94% 
 6.25% 
 5.00% 
 11.11% 


 B.  2.6.6 
 UNE 
 ISDN/  NC 


 (%) 


 20.20% 
 24.62% 
 10.91% 
 9.38% 


 B.  2.6.7 
 Line 
 Sharin  g/ 


 NC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 


 B.  2.6.8 
 2W 
 Analo  g 


 Loop 
 Design/  NC(%) 


 2.27% 
 4.71% 
 6.00% 
 3.95% 


 B.  2.6.10 
 2W 
 Analo  g 


 Loop 
 w/  INP 


 Design/  NC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3,4 


 B.  2.6.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  NC(%) 


 2.33% 
 5.32% 
 3.33% 
 1.47% 


 B.  2.6.13 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Non-  Design/ 


 NC(%) 


 B.  2.6.14 
 Other 
 Design/  NC(%) 


 0.00% 
 0.00% 
 2,4 


 B.  2.6.15 
 Other 
 Non-  Desi 


 gn/  NC(%) 


 0.00% 
 0.00% 
 0.00% 
 8.33% 


 B.  2.6.16 
 INP 
 (Standalone)/  NC(%) 


 0.00% 
 2 


 B.  2.6.17 
 LNP 
 (Standalone)/  NC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 


 B.  2.6.18 
 Di  gital 
 Loop 
 < 
 DS1/  NC(%) 


 11.11% 
 16.81% 
 7.53% 
 9.88% 


 B.  2.6.19 
 Di 
 gital 


 Loop 


 >= 
 DS1/  NC(%) 


 28.17% 
 32.50% 
 25.71% 
 30.30% 


 E-  21 
309
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 North 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 Average 
 Jeopardy 


 Notice 
 Interval 


 - 
 Mechanized 


 [P-  2] 


 B.  2.8.3 
 Loo  p 
 + 
 Port 


 Combinations/  NC( 


 hours) 


 114.82 
 220.96 
 100.65 
 153.36 
 1,3,4 


 B.  2.8.4 
 Combo 
 Other/  NC 


 (hours) 


 339.10 
 145.90 
 343.07 
 1,3,4 


 B.  2.8.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  NC( 


 hours) 


 103.57 
 4 


 B.  2.8.6 
 UNE 
 ISDN/  NC 


 (hours) 


 347.84 
 304.91 
 294.31 
 318.57 
 2,3,4 


 B.  2.8.8 
 2W 
 Analo  g 


 Loop 
 Design/  NC( 


 hours) 


 198.13 
 200.36 
 172.06 
 265.38 
 2,4 


 B.  2.8.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 NC( 
 hours) 


 B.  2.8.12 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/  NC( 


 hours) 


 183.81 
 173.43 
 167.55 
 149.55 
 2,3,4 


 B.  2.8.13 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Non-  Design/ 


 NC( 
 hours) 


 B.  2.8.14 
 Other 
 Design/  NC( 


 hours) 


 B.  2.8.18 
 Digital 
 Loop 
 < 
 DS1/  NC( 


 hours) 


 347.84 
 304.91 
 294.31 
 294.68 
 2,3,4 


 B.  2.8.19 
 Di 
 gital 


 Loop 


 >= 
 DS1/  NC( 


 hours) 


 197.61 
 227.84 
 211.06 
 247.14 


 Average 
 Jeopardy 


 Notice 
 Interval 


 - 
 Non-  Mechanized 


 [P-  2] 


 B.  2.9.2 
 Local 
 Interoffice 


 Trans  port/ 
 NC( 
 hours) 


 562.57 
 3 


 B.  2.9.3 
 Loo  p 
 + 
 Port 


 Combinations/  NC( 


 hours) 


 178.97 
 207.80 


 71.35 
 93.61 
 1,2,3,4 


 B.  2.9.4 
 Combo 
 Other/  NC 


 (hours) 


 308.61 
 295.28 
 313.49 
 530.82 
 2,3,4 


 B.  2.9.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  NC( 


 hours) 


 165.00 
 200.79 
 174.74 
 140.94 
 1,2,3,4 


 B.  2.9.6 
 UNE 
 ISDN/  NC 


 (hours) 


 332.95 
 303.55 
 321.50 
 331.66 
 3,4 


 B.  2.9.8 
 2W 
 Analo  g 


 Loop 
 Design/  NC( 


 hours) 


 131.97 
 124.89 
 138.37 
 121.85 
 1,2,3,4 


 B.  2.9.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  NC( 


 hours) 


 179.27 
 269.68 
 114.99 
 180.38 
 1,2,3,4 


 B.  2.9.15 
 Other 
 Non-  Desi 


 gn/  NC( 
 hours) 


 104.67 
 4 


 B.  2.9.18 
 Di 
 gital 


 Loop 


 < 
 DS1/  NC( 


 hours) 


 315.27 
 285.42 
 297.05 
 283.98 
 3,4 


 B.  2.9.19 
 Di 
 gital 


 Loop 


 >= 
 DS1/  NC( 


 hours) 


 192.66 
 181.88 
 182.42 
 177.55 
 3 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Mechanized 


 [P-  2] 


 B.  2.10.3 
 Loo  p 
 + 
 Port 


 Combinations/  NC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,3,4 


 B.  2.10.4 
 Combo 
 Other/  NC 


 (%) 


 100.00% 
 100.00% 
 100.00% 
 1,3,4 


 B.  2.10.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  NC(%) 


 100.00% 
 4 


 B.  2.10.6 
 UNE 
 ISDN/  NC 


 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 B.  2.10.8 
 2W 
 Analo  g 


 Loop 
 Design/  NC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2,4 


 B.  2.10.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 NC(%) 


 B.  2.10.12 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/  NC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 B.  2.10.13 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Non-  Design/ 


 NC(%) 


 B.  2.10.14 
 Other 
 Design/  NC(%) 


 E-  22 
310
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 North 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  2.10.18 
 Digital 
 Loop 
 < 
 DS1/  NC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 B.  2.10.19 
 Di 
 gital 


 Loop 


 >= 
 DS1/  NC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Non-  Mechanized 


 [P-  2] 


 B.  2.11.2 
 Local 
 Interoffice 


 Trans  port/ 
 NC(%) 


 100.00% 
 3 


 B.  2.11.3 
 Loo  p 
 + 
 Port 


 Combinations/  NC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 B.  2.11.4 
 Combo 
 Other/  NC 


 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 B.  2.11.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  NC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 B.  2.11.6 
 UNE 
 ISDN/  NC 


 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 3,4 


 B.  2.11.8 
 2W 
 Analo  g 


 Loop 
 Design/  NC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 B.  2.11.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  NC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 B.  2.11.15 
 Other 
 Non-  Desi 


 gn/  NC(%) 


 100.00% 
 4 


 B.  2.11.18 
 Di 
 gital 


 Loop 


 < 
 DS1/  NC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 3,4 


 B.  2.11.19 
 Di 
 gital 


 Loop 


 >= 
 DS1/  NC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 3 


 Coordinated 
 Customers 
 Conversions 


 [P-  7] 


 B.  2.12.2 
 Loo  ps 
 with 
 LNP/  NC(%) 


 100.00% 
 98.91% 
 99.72% 
 99.17% 


 % 
 Hot 


 Cuts 


 > 
 15 


 minutes 


 Early 
 [P-  7A] 


 B.  2.13.1 
 Time-  S 
 pecific 
 SL1/  NC(%) 


 B.  2.13.2 
 Time-  Specific 


 SL2/  NC(%) 


 0.00% 
 1.14% 
 0.00% 
 1.43% 


 B.  2.13.3 
 Non-  Time 
 Specific 
 SL1/  NC(%) 


 B.  2.13.4 
 Non-  Time 
 Specific 
 SL2/  NC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 


 Hot 
 Cut 
 Timeliness 


 [P-  7A] 


 B.  2.14.1 
 Time-  S 
 pecific 
 SL1/  NC(%) 


 B.  2.14.2 
 Time-  Specific 


 SL2/  NC(%) 


 99.18% 
 96.59% 
 100.00% 


 98.57% 


 B.  2.14.3 
 Non-  Time 
 Specific 
 SL1/  NC(%) 


 B.  2.14.4 
 Non-  Time 
 Specific 
 SL2/  NC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 % 
 Hot 


 Cuts 


 > 
 15 


 minutes 


 Late 
 [P-  7A] 


 B.  2.15.1 
 Time-  S 
 pecific 
 SL1/  NC(%) 


 B.  2.15.2 
 Time-  Specific 


 SL2/  NC(%) 


 0.82% 
 2.27% 
 0.00% 
 0.00% 


 B.  2.15.3 
 Non-  Time 
 Specific 
 SL1/  NC(%) 


 B.  2.15.4 
 Non-  Time 
 Specific 
 SL2/  NC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 


 Average 
 Recovery 


 Time 
 - 
 CCC 


 [P-  7B] 


 B.  2.16.2 
 Loo  ps 
 with 
 LNP/  NC( 


 minutes) 


 116.57 
 113.46 


 52.00 
 362.30 
 1,2,3,4 


 % 
 Provisioning 


 Troubles 
 within 
 7 
 Days 


 - 
 Hot 


 Cuts 


 [P-  7C] 


 E-  23 
311
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 North 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  2.17.1.1 
 UNE 
 Loop 
 Design/  Dispatch/ 


 NC(%) 


 0.95% 
 0.52% 
 2.25% 
 1.80% 


 B.  2.17.1.2 
 UNE 
 Loo 
 p 
 Design/  Non- 


 Dispatch/  NC(%) 


 0.00% 
 4 


 B.  2.17.2.1 
 UNE 
 Loo 
 p 
 Non-  Design/ 


 Dispatch/  NC(%) 


 0.00% 


 B.  2.17.2.2 
 UNE 
 Loo 
 p 
 Non-  Design/ 


 Non-  Dispatch/ 


 NC(%) 


 0.00% 


 % 
 Missed 


 Installation 


 Appointments 


 [P-  3] 


 B.  2.18.2.1.1 
 Local 
 Interoffice 


 Transport/<  10 


 circuits/  Dis 
 patch/  NC(%) 


 0.26% 
 0.00% 
 0.77% 
 0.00% 
 0.00% 
 0.00% 
 0.12% 
 0.00% 
 1,2,3,4 


 B.  2.18.3.1.1 
 Loop 
 + 
 Port 


 Combinations/<  10  circuits/  Dis  patch/  NC(%) 


 2.45% 
 1.34% 
 2.13% 
 0.99% 
 2.69% 
 1.29% 
 3.48% 
 3.02% 


 B.  2.18.3.1.2 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Non- 


 Dis 
 patch/  NC(%) 


 0.14% 
 0.45% 
 0.03% 
 0.18% 
 0.02% 
 0.47% 
 0.03% 
 0.06% 


 B.  2.18.3.1.3 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Switch 
 Based 


 Orders/  NC 
 (%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 B.  2.18.3.1.4 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Dispatch 


 In/  NC 
 (%) 


 0.29% 
 0.97% 
 0.07% 
 0.43% 
 0.04% 
 1.08% 
 0.05% 
 0.11% 


 B.  2.18.3.2.1 
 Loop 
 + 
 Port 


 Combinations/>=  10  circuits/  Dis  patch/  NC(%) 


 4.88% 
 0.00% 
 3.55% 
 0.00% 
 4.41% 
 0.00% 
 3.15% 
 0.00% 
 1,2,3,4 


 B.  2.18.3.2.2 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Non- 


 Dis 
 patch/  NC(%) 


 0.00% 
 0.00% 
 0.00% 


 0.53% 
 0.00% 
 0.00% 
 0.00% 
 1,3,4 


 B.  2.18.3.2.3 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Switch 
 Based 


 Orders/  NC 
 (%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 4 


 B.  2.18.3.2.4 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Dispatch 


 In/  NC 
 (%) 


 0.00% 
 0.00% 
 0.00% 


 0.66% 
 0.00% 
 0.00% 
 0.00% 
 1,3,4 


 B.  2.18.4.1.1 
 Combo 
 Other/<  10 


 circuits/  Dis 
 patch/  NC(%) 


 2.57% 
 0.00% 
 2.25% 
 0.00% 
 2.78% 
 0.00% 
 3.52% 
 0.00% 


 B.  2.18.5.1.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/<  10 


 circuits/  Dis 
 patch/  NC(%) 


 3.77% 
 0.00% 
 5.23% 
 0.00% 
 2.54% 
 0.00% 
 3.16% 
 0.00% 


 B.  2.18.6.1.1 
 UNE 
 ISDN/<  10 


 circuits/  Dis 
 patch/  NC(%) 


 1.57% 
 0.00% 
 1.25% 
 0.00% 
 0.00% 
 0.00% 
 1.89% 
 0.00% 


 B.  2.18.7.1.1 
 Line 
 Sharin  g/< 


 10 
 circuits/  Dispatch/ 


 NC(%) 


 3.77% 
 20.00% 


 5.23% 
 0.00% 
 2.54% 
 0.00% 
 3.16% 
 0.00% 
 1,2,3,4 


 B.  2.18.7.1.2 
 Line 
 Sharin  g/< 


 10 
 circuits/  Non- 


 Dispatch/  NC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.14% 
 0.00% 
 0.00% 
 0.00% 


 B.  2.18.8.1.1 
 2W 
 Analog 


 Loop 
 Design/<  10 


 circuits/  Dispatch/ 


 NC(%) 
 2.45% 


 0.00% 
 2.13% 
 0.00% 
 2.69% 
 0.00% 
 3.48% 
 0.60% 


 B.  2.18.8.2.1 
 2W 
 Analog 


 Loop 
 Design/>=  10 


 circuits/  Dis 
 patch/  NC(%) 


 4.88% 
 0.00% 
 3.55% 
 0.00% 
 4.41% 
 0.00% 
 3.15% 
 0.00% 
 1,2,3,4 


 E-  24 
312
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 North 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  2.18.9.1.1 
 2W 
 Analog 


 Loop 
 Non-  Design/< 


 10 


 circuits/  Dis 
 patch/  NC(%) 


 2.49% 
 0.00% 
 2.36% 
 0.00% 
 2.74% 
 0.00% 
 3.59% 
 0.00% 
 1,2,3,4 


 B.  2.18.9.1.4 
 2W 
 Analog 


 Loop 
 Non-  Design/< 


 10 
 circuits/  Dispatch 


 In/  NC 
 (%) 


 0.28% 
 0.00% 
 0.07% 


 0.04% 
 0.05% 


 1 


 B.  2.18.10.1.1 
 2W 
 Analog 


 Loop 
 w/  INP 


 Design/<  10 


 circuits/  Dis 
 patch/  NC(%) 


 2.45% 
 0.00% 
 2.13% 
 0.00% 
 2.69% 
 0.00% 
 3.48% 
 0.00% 
 1,2,3,4 


 B.  2.18.12.1.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/<  10 


 circuits/  Dis 
 patch/  NC(%) 


 2.45% 
 0.00% 
 2.13% 
 0.00% 
 2.69% 
 0.00% 
 3.48% 
 0.00% 


 B.  2.18.12.2.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/>=  10 


 circuits/  Dis 
 patch/  NC(%) 


 4.88% 
 0.00% 
 3.55% 
 0.00% 
 4.41% 
 0.00% 
 3.15% 
 0.00% 
 1,2,3,4 


 B.  2.18.13.1.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/< 


 10 


 circuits/  Dis 
 patch/  NC(%) 


 2.49% 
 2.36% 
 2.74% 
 3.59% 


 B.  2.18.13.1.4 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/< 


 10 


 circuits/  Dis 
 patch 
 In/  NC(%) 


 0.28% 
 0.07% 
 0.04% 
 0.05% 


 B.  2.18.13.2.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/>= 


 10 


 circuits/  Dis 
 patch/  NC(%) 


 2.94% 
 4.59% 
 4.81% 
 5.06% 


 B.  2.18.13.2.4 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/>= 


 10 


 circuits/  Dis 
 patch 
 In/  NC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 


 B.  2.18.14.1.1 
 Other 
 Desi  gn/< 


 10 
 circuits/  Dispatch/ 


 NC(%) 


 4.73% 
 4.56% 
 0.00% 
 4.42% 


 4.02% 
 0.00% 


 2,4 


 B.  2.18.15.1.1 
 Other 
 Non-  Desi 


 gn/<  10 
 circuits/  Dispatch/ 


 NC(%) 
 2.45% 
 0.00% 
 2.13% 
 0.00% 
 2.69% 
 0.00% 
 3.48% 
 0.00% 


 B.  2.18.15.1.2 
 Other 
 Non-  Design/< 


 10 
 circuits/  Non- 


 Dispatch/  NC(%) 


 0.14% 
 0.03% 
 0.02% 
 0.03% 


 B.  2.18.16.1.2 
 INP 
 (Standalone)/<  10 


 circuits/  Non- 
 Dispatch/  NC(%) 


 0.14% 
 0.03% 
 0.00% 
 0.02% 


 0.02% 


 2 


 B.  2.18.17.1.1 
 LNP 
 (Standalone)/<  10 


 circuits/  Dispatch/ 
 NC(%) 
 2.49% 
 0.00% 
 2.36% 
 0.00% 
 2.74% 
 0.00% 
 3.59% 
 0.00% 
 1,2,3,4 


 B.  2.18.17.1.2 
 LNP 
 (Standalone)/<  10 


 circuits/  Non- 
 Dispatch/  NC(%) 


 0.14% 
 0.00% 
 0.03% 
 0.00% 
 0.02% 
 0.84% 
 0.02% 
 0.00% 


 B.  2.18.17.2.1 
 LNP 
 (Standalone)/>=  10 


 circuits/  Dispatch/ 
 NC(%) 
 2.94% 


 4.59% 
 0.00% 
 4.81% 


 5.06% 


 2 


 B.  2.18.17.2.2 
 LNP 
 (Standalone)/>=  10 


 circuits/  Non- 
 Dispatch/  NC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1,3,4 


 B.  2.18.18.1.1 
 Di 
 gital 


 Loop 


 < 
 DS1/<  10 


 circuits/  Dispatch/ 


 NC(%) 
 3.96% 
 0.00% 
 5.04% 
 0.00% 
 2.48% 
 0.00% 
 3.16% 
 0.00% 


 B.  2.18.19.1.1 
 Di 
 gital 


 Loop 


 >= 
 DS1/<  10 


 circuits/  Dispatch/ 


 NC(%) 
 0.69% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.85% 
 0.82% 
 0.00% 


 B.  2.18.19.2.1 
 Digital 
 Loop 
 >= 
 DS1/>=  10 


 circuits/  Dispatch/ 


 NC(%) 
 0.00% 


 0.00% 
 0.00% 
 4 


 E-  25 
313
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 North 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 % 
 Provisioning 


 Troubles 
 within 
 30 
 Days 


 [P-  9] 


 B.  2.19.2.1.1 
 Local 
 Interoffice 


 Transport/<  10 


 circuits/  Dis 
 patch/  NC(%) 


 8.80% 
 9.46% 
 0.00% 
 8.08% 
 0.00% 
 8.21% 
 0.00% 
 2,3,4 


 B.  2.19.3.1.1 
 Loop 
 + 
 Port 


 Combinations/<  10  circuits/  Dis  patch/  NC(%) 


 9.49% 
 15.49% 


 9.52% 
 13.84% 


 8.87% 
 17.33% 
 10.47% 
 11.21% 


 B.  2.19.3.1.2 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Non- 


 Dis 
 patch/  NC(%) 


 2.52% 
 3.86% 
 2.67% 
 3.69% 
 2.39% 
 3.65% 
 2.60% 
 4.32% 


 B.  2.19.3.1.3 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Switch 
 Based 


 Orders/  NC 
 (%) 


 2.43% 
 3.42% 
 2.52% 
 3.28% 
 2.29% 
 3.19% 
 2.33% 
 3.68% 


 B.  2.19.3.1.4 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Dispatch 


 In/  NC 
 (%) 


 2.62% 
 4.42% 
 2.83% 
 4.15% 
 2.49% 
 4.28% 
 2.86% 
 5.17% 


 B.  2.19.3.2.1 
 Loop 
 + 
 Port 


 Combinations/>=  10  circuits/  Dis  patch/  NC(%) 


 14.85% 
 50.00% 
 12.20% 
 33.33% 
 21.99% 
 20.00% 
 13.97% 
 0.00% 
 1,2,3,4 


 B.  2.19.3.2.2 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Non- 


 Dis 
 patch/  NC(%) 


 6.64% 
 3.42% 
 0.00% 
 5.19% 


 3.72% 
 0.00% 


 2,4 


 B.  2.19.3.2.4 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Dispatch 


 In/  NC 
 (%) 


 6.15% 
 4.30% 
 0.00% 
 6.56% 


 1.32% 
 0.00% 


 2,4 


 B.  2.19.4.1.1 
 Combo 
 Other/<  10 


 circuits/  Dis 
 patch/  NC(%) 


 9.34% 
 0.00% 
 9.32% 
 22.73% 


 8.70% 
 0.00% 
 10.24% 


 0.00% 


 B.  2.19.5.1.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/<  10 


 circuits/  Dis 
 patch/  NC(%) 


 3.13% 
 6.98% 
 1.81% 
 10.68% 


 3.38% 
 8.33% 
 4.23% 
 2.56% 


 B.  2.19.6.1.1 
 UNE 
 ISDN/<  10 


 circuits/  Dis 
 patch/  NC(%) 


 8.13% 
 5.94% 
 5.51% 
 10.14% 


 5.63% 
 11.00% 


 2.91% 
 4.95% 


 B.  2.19.7.1.1 
 Line 
 Sharin  g/< 


 10 
 circuits/  Dispatch/ 


 NC(%) 


 3.13% 
 75.00% 


 1.81% 
 40.00% 


 3.38% 
 16.67% 


 4.23% 
 0.00% 
 1,2,3,4 


 B.  2.19.7.1.2 
 Line 
 Sharin  g/< 


 10 
 circuits/  Non- 


 Dispatch/  NC(%) 


 2.11% 
 25.00% 


 1.24% 
 17.39% 


 2.28% 
 11.11% 


 4.01% 
 31.58% 


 B.  2.19.8.1.1 
 2W 
 Analog 


 Loop 
 Design/<  10 


 circuits/  Dispatch/ 


 NC(%) 
 9.49% 


 6.10% 
 9.52% 
 9.13% 
 8.87% 
 10.23% 
 10.47% 
 6.61% 


 B.  2.19.8.2.1 
 2W 
 Analog 


 Loop 
 Design/>=  10 


 circuits/  Dispatch/ 
 NC(%) 


 14.85% 
 50.00% 
 12.20% 
 0.00% 
 21.99% 


 0.00% 
 13.97% 
 100.00% 
 1,2,3,4 


 B.  2.19.9.1.1 
 2W 
 Analog 


 Loop 
 Non-  Design/< 


 10 


 circuits/  Dis 
 patch/  NC(%) 


 9.66% 
 0.00% 
 9.71% 
 0.00% 
 9.70% 
 0.00% 
 10.67% 


 0.00% 
 1,2,3,4 


 B.  2.19.9.1.4 
 2W 
 Analog 


 Loop 
 Non-  Design/< 


 10 
 circuits/  Dispatch 


 In/  NC 
 (%) 


 2.61% 
 2.81% 
 0.00% 
 2.48% 


 2.85% 


 2 


 B.  2.19.9.2.1 
 2W 
 Analog 


 Loop 
 Non-  Design/>= 


 10 


 circuits/  Dis 
 patch/  NC(%) 


 13.70% 
 8.82% 
 22.94% 
 13.46% 


 E-  26 
314
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 North 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  2.19.10.1.1 
 2W 
 Analog 


 Loop 
 w/  INP 


 Design/<  10 


 circuits/  Dis 
 patch/  NC(%) 


 9.49% 
 0.00% 
 9.52% 
 0.00% 
 8.87% 
 0.00% 
 10.47% 


 0.00% 
 1,2,3,4 


 B.  2.19.12.1.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/<  10 


 circuits/  Dis 
 patch/  NC(%) 


 9.49% 
 4.23% 
 9.52% 
 3.60% 
 8.87% 
 7.58% 
 10.47% 


 5.86% 


 B.  2.19.12.2.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/>=  10 


 circuits/  Dis 
 patch/  NC(%) 


 14.85% 
 33.33% 
 12.20% 
 0.00% 
 21.99% 
 40.00% 
 13.97% 
 25.00% 
 1,2,3,4 


 B.  2.19.13.1.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/< 


 10 


 circuits/  Dis 
 patch/  NC(%) 


 9.66% 
 5.88% 
 9.71% 


 9.70% 
 10.67% 


 B.  2.19.13.1.4 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/< 


 10 


 circuits/  Dis 
 patch 
 In/  NC(%) 


 2.61% 
 0.00% 
 2.81% 


 2.48% 
 2.85% 


 B.  2.19.13.2.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/>= 


 10 


 circuits/  Dis 
 patch/  NC(%) 


 13.70% 
 0.00% 
 8.82% 


 22.94% 
 13.46% 


 1 


 B.  2.19.13.2.4 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/>= 


 10 


 circuits/  Dis 
 patch 
 In/  NC(%) 


 0.00% 
 0.00% 
 0.00% 


 0.00% 
 0.00% 


 1 


 B.  2.19.14.1.1 
 Other 
 Desi  gn/< 


 10 
 circuits/  Dispatch/ 


 NC(%) 


 6.50% 
 5.73% 
 5.57% 
 0.00% 
 6.34% 


 3 


 B.  2.19.15.1.1 
 Other 
 Non-  Desi 


 gn/<  10 
 circuits/  Dispatch/ 


 NC(%) 
 9.49% 
 15.00% 


 9.52% 
 12.50% 


 8.87% 
 14.29% 
 10.47% 
 16.67% 


 B.  2.19.16.1.2 
 INP 
 (Standalone)/<  10 


 circuits/  Non- 
 Dispatch/  NC(%) 


 2.52% 
 2.66% 
 2.38% 
 0.00% 
 2.59% 


 3 


 B.  2.19.17.1.1 
 LNP 
 (Standalone)/<  10 


 circuits/  Dispatch/ 
 NC(%) 
 9.66% 
 0.00% 
 9.71% 
 0.00% 
 9.70% 
 0.00% 
 10.67% 


 0.00% 
 1,2,3,4 


 B.  2.19.17.1.2 
 LNP 
 (Standalone)/<  10 


 circuits/  Non- 
 Dispatch/  NC(%) 


 2.52% 
 0.00% 
 2.66% 
 0.00% 
 2.38% 
 0.00% 
 2.59% 
 0.00% 


 B.  2.19.17.2.1 
 LNP 
 (Standalone)/>=  10 


 circuits/  Dispatch/ 
 NC(%) 
 13.70% 


 8.82% 
 22.94% 
 0.00% 
 13.46% 


 3 


 B.  2.19.17.2.2 
 LNP 
 (Standalone)/>=  10 


 circuits/  Non- 
 Dispatch/  NC(%) 


 2.56% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 9.09% 
 0.00% 


 2,4 


 B.  2.19.18.1.1 
 Di 
 gital 


 Loop 


 < 
 DS1/<  10 


 circuits/  Dispatch/ 


 NC(%) 
 3.58% 
 6.25% 
 2.21% 
 10.12% 


 3.52% 
 10.14% 


 4.32% 
 3.62% 


 B.  2.19.19.1.1 
 Di 
 gital 


 Loop 


 >= 
 DS1/<  10 


 circuits/  Dispatch/ 


 NC(%) 
 3.30% 
 13.43% 


 7.59% 
 11.03% 


 6.25% 
 8.33% 
 2.21% 
 18.80% 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Mechanized 


 [P-  5] 


 B.  2.21.3.1.1 
 Loop 
 + 
 Port 


 Combinations/<  10  circuits/  Dis  patch/  NC(  hours) 


 1.76 
 0.13 
 2.79 
 0.04 
 1.67 
 0.05 
 1.67 
 0.06 


 B.  2.21.3.1.2 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Non- 


 Dis 
 patch/  NC( 


 hours) 


 0.79 
 0.82 
 0.82 
 0.90 
 0.76 
 0.85 
 0.80 
 1.03 


 B.  2.21.3.1.3 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Switch 
 Based 


 Orders/  NC 
 (hours) 


 0.79 
 0.80 
 0.82 
 0.90 
 0.82 
 0.82 
 0.81 
 0.91 


 E-  27 
315
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 North 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  2.21.3.1.4 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Dispatch 


 In/  NC 
 (hours) 


 0.79 
 0.84 
 0.83 
 0.90 
 0.71 
 0.89 
 0.79 
 1.11 


 B.  2.21.3.2.1 
 Loop 
 + 
 Port 


 Combinations/>=  10  circuits/  Dis  patch/  NC(  hours) 


 2.26 
 0.02 
 4.47 
 0.02 
 1.94 
 0.02 
 1.94 
 0.02 
 1,2,3,4 


 B.  2.21.3.2.2 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Non- 


 Dis 
 patch/  NC( 


 hours) 


 0.69 
 4.70 
 1.62 
 4.07 
 0.42 


 4 


 B.  2.21.3.2.4 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Dispatch 


 In/  NC 
 (hours) 


 0.71 
 4.70 
 0.67 
 2.95 
 0.42 


 4 


 B.  2.21.4.1.1 
 Combo 
 Other/<  10 


 circuits/  Dis 
 patch/  NC( 
 hours) 


 17.29 
 67.82 
 15.69 


 15.25 
 0.02 
 18.08 


 38.84 
 1,3,4 


 B.  2.21.5.1.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/<  10 


 circuits/  Dis 
 patch/  NC( 
 hours) 


 20.63 
 26.21 
 28.48 
 12.55 
 12.25 


 B.  2.21.6.1.1 
 UNE 
 ISDN/<  10 


 circuits/  Dis 
 patch/  NC( 
 hours) 


 121.15 
 21.69 
 105.35 


 9.38 
 134.72 


 6.22 
 165.10 


 26.47 


 B.  2.21.7.1.2 
 Line 
 Sharing/<  10 


 circuits/  Non- 
 Dispatch/  NC( 


 hours) 
 0.92 


 1.71 
 0.55 
 1.18 


 1.76 
 0.67 
 2,4 


 B.  2.21.8.1.1 
 2W 
 Analog 


 Loop 
 Design/<  10 


 circuits/  Dispatch/ 
 NC( 
 hours) 


 1.76 
 23.70 


 2.79 
 10.84 


 1.67 
 9.45 
 1.67 
 18.46 


 B.  2.21.8.2.1 
 2W 
 Analog 


 Loop 
 Design/>=  10 


 circuits/  Dis 
 patch/  NC( 
 hours) 


 2.26 
 0.02 
 4.47 
 3.57 
 1.94 
 0.02 
 1.94 
 19.73 
 1,2,3,4 


 B.  2.21.9.1.1 
 2W 
 Analog 


 Loop 
 Non-  Design/< 


 10 


 circuits/  Dis 
 patch/  NC( 
 hours) 


 1.46 
 0.02 
 1.70 
 0.02 
 1.65 
 0.02 
 1.55 
 0.02 
 1,2,3,4 


 B.  2.21.9.1.4 
 2W 
 Analog 


 Loop 
 Non-  Design/< 


 10 
 circuits/  Dispatch 


 In/  NC 
 (hours) 


 0.78 
 0.02 
 0.82 


 0.71 
 0.78 


 1 


 B.  2.21.12.1.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/<  10 


 circuits/  Dis 
 patch/  NC( 
 hours) 


 1.76 
 16.42 


 2.79 
 15.24 


 1.67 
 12.87 


 1.67 
 13.35 


 B.  2.21.12.2.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/>=  10 


 circuits/  Dis 
 patch/  NC( 
 hours) 


 2.26 
 4.47 
 10.92 


 1.94 
 0.03 
 1.94 
 0.02 
 2,3,4 


 B.  2.21.13.1.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/< 


 10 


 circuits/  Dis 
 patch/  NC( 
 hours) 


 1.46 
 1.70 
 1.65 
 1.55 


 B.  2.21.13.1.4 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/< 


 10 


 circuits/  Dis 
 patch 
 In/  NC( 


 hours) 


 0.78 
 0.82 
 0.71 
 0.78 


 B.  2.21.13.2.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/>= 


 10 


 circuits/  Dis 
 patch/  NC( 
 hours) 


 2.67 
 5.34 
 0.99 
 0.35 


 B.  2.21.13.2.4 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/>= 


 10 


 circuits/  Dis 
 patch 
 In/  NC( 


 hours) 


 0.85 
 2.61 
 0.77 
 0.55 


 E-  28 
316
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 North 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  2.21.17.1.1 
 LNP 
 (Standalone)/<  10 


 circuits/  Dispatch/ 
 NC(  hours) 
 1.46 


 1.70 
 0.05 
 1.65 
 0.02 
 1.55 


 2,3 


 B.  2.21.17.1.2 
 LNP 
 (Standalone)/<  10 


 circuits/  Non- 


 Dis 
 patch/  NC( 


 hours) 


 0.79 
 0.59 
 0.82 
 1.12 
 0.75 
 0.63 
 0.79 
 0.67 


 B.  2.21.17.2.1 
 LNP 
 (Standalone)/>=  10 


 circuits/  Dispatch/ 
 NC(  hours) 
 2.67 


 5.34 
 0.02 
 0.99 


 0.35 


 2 


 B.  2.21.17.2.2 
 LNP 
 (Standalone)/>=  10 


 circuits/  Non- 


 Dis 
 patch/  NC( 


 hours) 


 0.83 
 0.40 
 7.26 
 0.52 
 0.73 
 0.63 
 0.53 


 1,2,3 


 B.  2.21.18.1.1 
 Digital 
 Loop 
 < 
 DS1/<  10 


 circuits/  Dispatch/ 


 NC(  hours) 
 29.67 
 21.69 
 35.47 


 9.38 
 36.38 


 6.22 
 26.67 


 21.19 


 B.  2.21.19.1.1 
 Digital 
 Loop 
 >= 
 DS1/<  10 


 circuits/  Dispatch/ 


 NC(  hours) 
 839.29 
 34.10 
 368.83 


 66.27 
 331.99 


 52.15 
 183.42 


 54.56 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Non-  Mechanized 


 [P-  5] 


 B.  2.22.2.1.1 
 Local 
 Interoffice 


 Transport/<  10 


 circuits/  Dis 
 patch/  NC( 
 hours) 


 18.22 
 50.38 
 16.88 
 41.81 
 1,2,3,4 


 B.  2.22.3.1.1 
 Loop 
 + 
 Port 


 Combinations/<  10  circuits/  Dis  patch/  NC(  hours) 


 19.06 
 17.97 
 13.22 
 14.13 


 B.  2.22.3.1.2 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Non- 


 Dis 
 patch/  NC( 


 hours) 


 4.53 
 15.00 


 4.35 
 6.48 


 B.  2.22.3.1.3 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Switch 
 Based 


 Orders/  NC 
 (hours) 


 3.45 
 12.49 


 3.36 
 6.89 


 B.  2.22.3.1.4 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Dispatch 


 In/  NC 
 (hours) 


 6.57 
 20.07 


 7.91 
 5.09 


 B.  2.22.3.2.1 
 Loop 
 + 
 Port 


 Combinations/>=  10  circuits/  Dis  patch/  NC(  hours) 


 0.02 
 0.02 


 14.40 
 1,2,4 


 B.  2.22.3.2.2 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Non- 


 Dis 
 patch/  NC( 


 hours) 


 14.00 
 38.00 
 15.07 
 1,3,4 


 B.  2.22.3.2.3 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Switch 
 Based 


 Orders/  NC 
 (hours) 


 14.00 
 4 


 B.  2.22.3.2.4 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Dispatch 


 In/  NC 
 (hours) 


 14.00 
 38.00 
 15.60 
 1,3,4 


 B.  2.22.4.1.1 
 Combo 
 Other/<  10 


 circuits/  Dis 
 patch/  NC( 
 hours) 


 89.06 
 58.23 
 95.29 
 90.00 


 B.  2.22.5.1.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/<  10 


 circuits/  Dis 
 patch/  NC( 
 hours) 


 34.40 
 35.91 
 13.48 
 17.00 


 E-  29 
317
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 North 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  2.22.6.1.1 
 UNE 
 ISDN/<  10 


 circuits/  Dispatch/ 


 NC( 
 hours) 


 52.60 
 55.80 
 56.71 
 30.47 


 B.  2.22.7.1.1 
 Line 
 Sharin  g/< 


 10 
 circuits/  Dispatch/ 


 NC( 
 hours) 


 3.36 
 0.02 
 0.02 
 0.03 
 1,2,3,4 


 B.  2.22.7.1.2 
 Line 
 Sharing/<  10 


 circuits/  Non- 
 Dispatch/  NC( 


 hours) 


 1.26 
 0.57 
 0.48 
 0.63 


 B.  2.22.8.1.1 
 2W 
 Analog 


 Loop 
 Design/<  10 


 circuits/  Dispatch/ 
 NC( 
 hours) 


 46.78 
 45.09 
 29.36 
 42.62 


 B.  2.22.8.2.1 
 2W 
 Analog 


 Loop 
 Design/>=  10 


 circuits/  Dis 
 patch/  NC( 
 hours) 


 80.93 


 1 


 B.  2.22.10.1.1 
 2W 
 Analog 


 Loop 
 w/  INP 


 Design/<  10 


 circuits/  Dis 
 patch/  NC( 
 hours) 


 35.10 
 30.77 
 24.16 
 36.06 
 1,2,3,4 


 B.  2.22.12.1.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/<  10 


 circuits/  Dis 
 patch/  NC( 
 hours) 


 56.47 
 32.50 
 25.69 
 40.10 


 B.  2.22.12.2.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/>=  10 


 circuits/  Dis 
 patch/  NC( 
 hours) 


 80.97 
 48.72 
 22.83 
 18.57 
 1,2,3,4 


 B.  2.22.13.1.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/< 


 10 


 circuits/  Dis 
 patch/  NC( 
 hours) 


 B.  2.22.14.1.1 
 Other 
 Design/<  10 


 circuits/  Dispatch/ 


 NC( 
 hours) 


 21.47 
 15.87 
 2,4 


 B.  2.22.15.1.1 
 Other 
 Non-  Design/< 


 10 
 circuits/  Dispatch/ 


 NC(  hours) 


 31.13 
 25.33 
 19.91 
 31.72 


 B.  2.22.15.1.2 
 Other 
 Non-  Design/< 


 10 
 circuits/  Non- 


 Dispatch/  NC( 
 hours) 


 B.  2.22.16.1.2 
 INP 
 (Standalone)/<  10 


 circuits/  Non- 


 Dis 
 patch/  NC( 


 hours) 


 18.27 
 2 


 B.  2.22.17.1.1 
 LNP 
 (Standalone)/<  10 


 circuits/  Dispatch/ 
 NC(  hours) 


 9.66 


 0.02 
 0.02 
 1,3,4 


 B.  2.22.17.1.2 
 LNP 
 (Standalone)/<  10 


 circuits/  Non- 


 Dis 
 patch/  NC( 


 hours) 


 3.29 
 2.49 
 5.42 
 2.66 


 B.  2.22.17.2.2 
 LNP 
 (Standalone)/>=  10 


 circuits/  Non- 


 Dis 
 patch/  NC( 


 hours) 


 0.62 
 0.61 
 0.59 
 0.51 
 1,2,3,4 


 B.  2.22.18.1.1 
 Digital 
 Loop 
 < 
 DS1/<  10 


 circuits/  Dispatch/ 


 NC(  hours) 


 43.43 
 47.60 
 39.04 
 27.69 


 B.  2.22.19.1.1 
 Digital 
 Loop 
 >= 
 DS1/<  10 


 circuits/  Dispatch/ 


 NC(  hours) 


 85.79 
 52.79 
 54.70 
 56.39 


 E-  30 
318
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 North 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  2.22.19.2.1 
 Digital 
 Loop 
 >= 
 DS1/>=  10 


 circuits/  Dis 
 patch/  NC( 
 hours) 


 35.72 
 4 


 Service 
 Order 
 Accuracy 


 [P-  11] 


 B.  2.34.1.1.1 
 Desi 
 gn 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 NC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  2.34.1.1.2 
 Design 
 (Specials)/<  10 


 circuits/  Non- 
 Dispatch/  NC(%) 


 100.00% 
 67.07% 
 69.33% 


 B.  2.34.1.2.1 
 Desi 
 gn 
 (Specials)/>=  10 


 circuits/  Dispatch/ 


 NC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  2.34.1.2.2 
 Design 
 (Specials)/>=  10 


 circuits/  Non- 
 Dispatch/  NC(%) 


 100.00% 
 90.91% 
 3 


 B.  2.34.2.1.1 
 Loo  ps 
 Non-  Design/< 


 10 
 circuits/  Dispatch/ 


 NC(%) 


 98.18% 
 95.65% 
 96.00% 
 96.33% 


 B.  2.34.2.1.2 
 Loops 
 Non-  Design/< 


 10 
 circuits/  Non- 


 Dispatch/  NC(%) 


 99.09% 
 98.18% 
 100.00% 


 98.02% 


 B.  2.34.2.2.1 
 Loo  ps 
 Non-  Design/>= 


 10 
 circuits/  Dispatch/ 


 NC(%) 


 97.75% 
 89.81% 
 97.90% 
 97.73% 


 B.  2.34.2.2.2 
 Loops 
 Non-  Design/>= 


 10 
 circuits/  Non- 


 Dis 
 patch/  NC(%) 


 97.20% 
 97.98% 
 98.73% 
 97.53% 


 UNBUNDLED 
 NETWORK 
 ELEMENTS 


 - 
 MAINTENANCE 


 AND 
 REPAIR 


 Missed 
 Repair 
 Appointments 


 [M&  R- 
 1] 


 B.  3.1.2.1 
 Local 
 Interoffice 


 Trans  port/ 
 Dispatch/  NC(%) 


 0.24% 
 0.00% 
 0.00% 
 0.00% 
 0.39% 
 0.00% 
 0.00% 
 0.00% 


 4 


 B.  3.1.2.2 
 Local 
 Interoffice 


 Trans  port/ 
 Non-  Dispatch/ 


 NC(%) 
 0.00% 
 0.00% 
 0.24% 
 0.00% 
 0.00% 
 0.00% 
 0.18% 
 0.00% 
 1,2,4 


 B.  3.1.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  Dispatch/ 


 NC(%) 
 4.10% 
 0.00% 
 4.39% 
 0.45% 
 3.96% 
 0.71% 
 4.12% 
 0.61% 


 B.  3.1.3.2 
 Loo  p 
 + 
 Port 


 Combinations/  Non- 


 Dispatch/  NC(%) 


 0.80% 
 0.00% 
 1.03% 
 1.08% 
 0.78% 
 0.00% 
 1.23% 
 1.07% 


 B.  3.1.4.1 
 Combo 
 Other/  Dis 


 patch/  NC(%) 


 4.03% 
 0.00% 
 4.31% 
 0.00% 
 3.89% 
 0.00% 
 4.06% 
 0.00% 
 1,3,4 


 B.  3.1.4.2 
 Combo 
 Other/  Non- 


 Dis  patch/ 
 NC(%) 


 4.03% 
 0.00% 
 4.31% 
 0.00% 
 3.89% 
 0.00% 
 4.06% 
 0.00% 
 1,2,3,4 


 B.  3.1.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Dispatch/ 


 NC(%) 
 48.06% 
 0.00% 
 51.94% 


 0.00% 
 53.33% 


 0.00% 
 48.72% 


 7.14% 


 B.  3.1.5.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Non- 


 Dispatch/  NC(%) 


 3.35% 
 0.00% 
 2.60% 
 0.00% 
 3.70% 
 0.00% 
 1.32% 
 0.00% 
 2,3,4 


 B.  3.1.6.1 
 UNE 
 ISDN/  Dis 


 patch/  NC(%) 


 0.00% 
 3.13% 
 1.27% 
 0.00% 
 0.00% 
 2.70% 
 2.50% 
 0.00% 


 B.  3.1.6.2 
 UNE 
 ISDN/  Non- 


 Dis 
 patch/  NC(%) 


 0.00% 
 0.00% 
 0.87% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 B.  3.1.7.1 
 Line 
 Sharin  g/ 


 Dispatch/  NC(%) 


 48.06% 
 0.00% 
 51.94% 


 0.00% 
 53.33% 


 0.00% 
 48.72% 
 100.00% 
 1,2,3,4 


 B.  3.1.7.2 
 Line 
 Sharin  g/ 


 Non-  Dispatch/ 


 NC(%) 


 3.35% 
 0.00% 
 2.60% 
 0.00% 
 3.70% 
 0.00% 
 1.32% 
 0.00% 
 1,2,3,4 


 B.  3.1.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  Dispatch/ 


 NC(%) 


 4.10% 
 0.58% 
 4.39% 
 0.42% 
 3.96% 
 0.00% 
 4.12% 
 0.00% 


 B.  3.1.8.2 
 2W 
 Analo  g 


 Loop 
 Design/  Non- 


 Dispatch/  NC(%) 


 4.10% 
 0.00% 
 4.39% 
 0.00% 
 3.96% 
 0.00% 
 4.12% 
 0.00% 


 B.  3.1.9.1 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 Dispatch/  NC(%) 


 3.96% 
 0.00% 
 4.20% 
 0.00% 
 3.80% 
 0.00% 
 4.00% 
 0.00% 


 4 


 E-  31 
319
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 North 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  3.1.9.2 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 Non-  Dispatch/ 


 NC(%) 
 0.48% 
 0.00% 
 0.83% 
 0.00% 
 0.65% 
 0.00% 
 1.11% 
 0.00% 


 1,2 


 B.  3.1.10.1 
 Other 
 Desi  gn/ 
 Dispatch/  NC(%) 


 0.83% 
 0.00% 
 0.73% 
 0.00% 
 0.24% 
 0.00% 
 1.41% 
 0.00% 


 1 


 B.  3.1.10.2 
 Other 
 Desi  gn/ 


 Non-  Dispatch/ 


 NC(%) 


 0.38% 
 0.00% 
 0.29% 
 0.00% 
 0.26% 
 0.00% 
 0.21% 
 0.00% 


 B.  3.1.11.1 
 Other 
 Non-  Desi 


 gn/  Dispatch/ 


 NC(%) 


 4.10% 
 0.00% 
 4.39% 
 0.00% 
 3.96% 
 0.00% 
 4.12% 
 0.00% 
 1,2,3,4 


 B.  3.1.11.2 
 Other 
 Non-  Desi 


 gn/  Non- 
 Dispatch/  NC(%) 


 0.80% 
 0.00% 
 1.03% 
 0.00% 
 0.78% 
 0.00% 
 1.23% 
 0.00% 
 1,2,3,4 


 Customer 
 Trouble 
 Report 
 Rate 
 [M&  R- 


 2] 


 B.  3.2.2.1 
 Local 
 Interoffice 


 Trans  port/ 
 Dispatch/  NC(%) 


 1.32% 
 0.00% 
 1.70% 
 0.00% 
 1.61% 
 0.00% 
 1.90% 
 0.65% 


 B.  3.2.2.2 
 Local 
 Interoffice 


 Trans  port/ 
 Non-  Dispatch/ 


 NC(%) 
 1.53% 
 2.03% 
 1.34% 
 0.66% 
 1.86% 
 0.00% 
 1.78% 
 1.31% 


 B.  3.2.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  Dispatch/ 


 NC(%) 
 1.46% 
 1.05% 
 1.65% 
 1.20% 
 1.73% 
 1.51% 
 1.81% 
 1.34% 


 B.  3.2.3.2 
 Loo  p 
 + 
 Port 


 Combinations/  Non- 


 Dispatch/  NC(%) 


 0.76% 
 0.39% 
 0.76% 
 0.34% 
 0.78% 
 0.40% 
 0.82% 
 0.46% 


 B.  3.2.4.1 
 Combo 
 Other/  Dis 


 patch/  NC(%) 


 1.25% 
 2.77% 
 1.42% 
 5.19% 
 1.48% 
 1.52% 
 1.55% 
 2.46% 


 B.  3.2.4.2 
 Combo 
 Other/  Non- 


 Dis  patch/ 
 NC(%) 


 1.25% 
 2.08% 
 1.42% 
 1.95% 
 1.48% 
 1.82% 
 1.55% 
 0.27% 


 B.  3.2.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Dispatch/ 


 NC(%) 
 0.64% 
 0.58% 
 0.79% 
 0.77% 
 0.83% 
 0.75% 
 0.97% 
 0.88% 


 B.  3.2.5.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Non- 


 Dispatch/  NC(%) 


 1.33% 
 0.53% 
 1.70% 
 0.22% 
 1.67% 
 0.40% 
 2.24% 
 0.19% 


 B.  3.2.6.1 
 UNE 
 ISDN/  Dis 


 patch/  NC(%) 


 0.60% 
 0.89% 
 0.70% 
 1.60% 
 0.56% 
 1.04% 
 0.71% 
 1.19% 


 B.  3.2.6.2 
 UNE 
 ISDN/  Non- 


 Dis 
 patch/  NC(%) 


 1.12% 
 0.73% 
 1.01% 
 0.70% 
 1.04% 
 0.76% 
 1.14% 
 0.56% 


 B.  3.2.7.1 
 Line 
 Sharin  g/ 


 Dispatch/  NC(%) 


 0.64% 
 0.22% 
 0.79% 
 0.22% 
 0.83% 
 0.22% 
 0.97% 
 0.21% 


 B.  3.2.7.2 
 Line 
 Sharin  g/ 


 Non-  Dispatch/ 


 NC(%) 


 1.33% 
 1.56% 
 1.70% 
 1.51% 
 1.67% 
 1.52% 
 2.24% 
 0.85% 


 B.  3.2.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  Dispatch/ 


 NC(%) 


 1.46% 
 0.83% 
 1.65% 
 1.15% 
 1.73% 
 0.84% 
 1.81% 
 0.83% 


 B.  3.2.8.2 
 2W 
 Analo  g 


 Loop 
 Design/  Non- 


 Dispatch/  NC(%) 


 1.46% 
 0.24% 
 1.65% 
 0.27% 
 1.73% 
 0.30% 
 1.81% 
 0.29% 


 B.  3.2.9.1 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 Dispatch/  NC(%) 


 1.58% 
 1.29% 
 1.79% 
 0.00% 
 1.87% 
 0.00% 
 1.98% 
 1.64% 


 B.  3.2.9.2 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 Non-  Dispatch/ 


 NC(%) 
 0.69% 
 0.13% 
 0.71% 
 0.46% 
 0.74% 
 0.00% 
 0.79% 
 0.00% 


 B.  3.2.10.1 
 Other 
 Desi  gn/ 
 Dispatch/  NC(%) 


 0.16% 
 14.29% 


 0.19% 
 0.00% 
 0.19% 
 0.00% 
 0.21% 
 0.00% 
 1,2,3,4 


 B.  3.2.10.2 
 Other 
 Desi  gn/ 


 Non-  Dispatch/ 


 NC(%) 


 0.30% 
 0.00% 
 0.31% 
 0.00% 
 0.34% 
 0.00% 
 0.32% 
 0.00% 
 1,2,3,4 


 B.  3.2.11.1 
 Other 
 Non-  Desi 


 gn/  Dispatch/ 


 NC(%) 


 1.46% 
 0.39% 
 1.65% 
 0.41% 
 1.73% 
 1.62% 
 1.81% 
 0.32% 


 B.  3.2.11.2 
 Other 
 Non-  Desi 


 gn/  Non- 
 Dispatch/  NC(%) 


 0.76% 
 0.19% 
 0.76% 
 0.20% 
 0.78% 
 1.30% 
 0.82% 
 0.65% 


 Maintenance 
 Average 
 Duration 


 [M&  R- 
 3] 


 B.  3.3.2.1 
 Local 
 Interoffice 


 Trans  port/ 
 Dispatch/  NC( 


 hours) 


 3.43 
 0.00 
 3.63 
 0.00 
 3.81 
 0.00 
 4.11 
 4.55 


 4 


 B.  3.3.2.2 
 Local 
 Interoffice 


 Transport/  Non- 


 Dispatch/  NC( 
 hours) 
 2.09 
 1.20 
 1.92 
 8.38 
 1.48 
 0.00 
 1.77 
 1.50 
 1,2,4 


 B.  3.3.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  Dispatch/ 


 NC( 
 hours) 


 15.02 
 10.44 
 16.33 
 10.80 
 16.54 


 9.47 
 18.25 


 10.29 


 E-  32 
320
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 North 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  3.3.3.2 
 Loop 
 + 
 Port 


 Combinations/  Non- 


 Dispatch/  NC( 
 hours) 
 4.68 
 2.90 
 5.47 
 4.13 
 5.70 
 2.64 
 6.48 
 3.25 


 B.  3.3.4.1 
 Combo 
 Other/  Dis 


 patch/  NC( 
 hours) 


 14.80 
 4.72 
 16.09 


 4.31 
 16.28 


 2.60 
 17.96 


 4.87 
 1,3,4 


 B.  3.3.4.2 
 Combo 
 Other/  Non- 


 Dis  patch/ 
 NC( 
 hours) 


 14.80 
 0.71 
 16.09 


 1.48 
 16.28 


 0.73 
 17.96 


 0.33 
 1,2,3,4 


 B.  3.3.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Dispatch/ 


 NC(  hours) 
 63.82 
 5.87 
 45.57 


 4.72 
 51.23 


 4.16 
 48.99 


 5.29 


 B.  3.3.5.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Non- 


 Dispatch/  NC( 
 hours) 


 3.48 
 2.61 
 2.77 
 2.58 
 4.25 
 1.20 
 1.81 
 6.15 
 2,3,4 


 B.  3.3.6.1 
 UNE 
 ISDN/  Dis 


 patch/  NC( 
 hours) 


 4.11 
 4.38 
 5.29 
 4.03 
 4.35 
 4.40 
 6.56 
 3.76 


 B.  3.3.6.2 
 UNE 
 ISDN/  Non- 


 Dis 
 patch/  NC( 


 hours) 


 1.76 
 2.56 
 2.10 
 1.89 
 1.20 
 2.81 
 1.87 
 4.01 


 B.  3.3.7.1 
 Line 
 Sharin  g/ 


 Dispatch/  NC( 


 hours) 


 63.82 
 4.37 
 45.57 


 51.00 
 51.23 
 21.00 
 48.99 
 72.00 
 1,2,3,4 


 B.  3.3.7.2 
 Line 
 Sharin  g/ 


 Non-  Dispatch/ 


 NC( 
 hours) 


 3.48 
 2.54 
 2.77 
 1.71 
 4.25 
 7.86 
 1.81 
 7.50 
 1,2,3,4 


 B.  3.3.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  Dispatch/ 


 NC( 
 hours) 


 15.02 
 4.31 
 16.33 


 4.27 
 16.54 


 3.74 
 18.25 


 3.79 


 B.  3.3.8.2 
 2W 
 Analog 


 Loop 
 Design/  Non- 


 Dispatch/  NC( 


 hours) 
 15.02 
 1.84 
 16.33 


 1.94 
 16.54 


 2.64 
 18.25 


 2.78 


 B.  3.3.9.1 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 Dispatch/  NC( 


 hours) 
 15.06 
 3.30 
 16.37 


 0.00 
 16.63 


 0.00 
 18.33 


 8.33 
 4 


 B.  3.3.9.2 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 Non- 


 Dis 
 patch/  NC( 


 hours) 


 5.03 
 0.55 
 5.84 
 20.00 


 6.22 
 0.00 
 6.96 
 0.00 
 1,2 


 B.  3.3.10.1 
 Other 
 Desi  gn/ 
 Dispatch/  NC( 


 hours) 


 4.38 
 2.28 
 5.08 
 0.00 
 4.30 
 0.00 
 5.17 
 0.00 


 1 


 B.  3.3.10.2 
 Other 
 Desi  gn/ 


 Non-  Dispatch/ 


 NC( 
 hours) 


 2.27 
 0.00 
 2.30 
 0.00 
 2.17 
 0.00 
 2.29 
 0.00 


 B.  3.3.11.1 
 Other 
 Non-  Desi 


 gn/  Dispatch/ 


 NC( 
 hours) 


 15.02 
 19.04 
 16.33 


 4.50 
 16.54 


 17.00 
 18.25 
 28.00 
 1,2,3,4 


 B.  3.3.11.2 
 Other 
 Non-  Desi 


 gn/  Non- 
 Dispatch/  NC( 


 hours) 


 4.68 
 2.67 
 5.47 
 2.00 
 5.70 
 1.75 
 6.48 
 11.00 
 1,2,3,4 


 % 
 Repeat 


 Troubles 


 within 
 30 
 Days 


 [M&  R- 


 4] 


 B.  3.4.2.1 
 Local 
 Interoffice 


 Trans  port/ 
 Dispatch/  NC(%) 


 21.58% 
 0.00% 
 22.45% 


 0.00% 
 20.51% 


 0.00% 
 24.46% 


 0.00% 


 4 


 B.  3.4.2.2 
 Local 
 Interoffice 


 Trans  port/ 
 Non-  Dispatch/ 


 NC(%) 
 13.07% 
 0.00% 
 16.78% 


 0.00% 
 17.43% 


 0.00% 
 21.20% 


 0.00% 
 1,2,4 


 B.  3.4.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  Dispatch/ 


 NC(%) 
 14.24% 
 10.93% 
 16.02% 
 12.42% 
 15.12% 
 11.52% 
 15.43% 
 13.19% 


 B.  3.4.3.2 
 Loo  p 
 + 
 Port 


 Combinations/  Non- 


 Dispatch/  NC(%) 


 12.72% 
 10.84% 
 14.13% 
 21.08% 
 13.23% 
 11.66% 
 14.55% 
 18.15% 


 B.  3.4.4.1 
 Combo 
 Other/  Dis 


 patch/  NC(%) 


 14.25% 
 12.50% 
 16.10% 
 12.50% 
 15.22% 
 0.00% 
 15.59% 


 0.00% 
 1,3,4 


 B.  3.4.4.2 
 Combo 
 Other/  Non- 


 Dis  patch/ 
 NC(%) 


 14.25% 
 0.00% 
 16.10% 


 0.00% 
 15.22% 


 0.00% 
 15.59% 


 0.00% 
 1,2,3,4 


 B.  3.4.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Dispatch/ 


 NC(%) 
 16.67% 
 0.00% 
 18.53% 


 7.14% 
 23.73% 
 15.38% 
 25.88% 
 21.43% 


 B.  3.4.5.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Non- 


 Dispatch/  NC(%) 


 17.14% 
 20.00% 
 23.50% 
 0.00% 
 19.77% 
 14.29% 
 25.62% 
 0.00% 
 2,3,4 


 B.  3.4.6.1 
 UNE 
 ISDN/  Dis 


 patch/  NC(%) 


 10.14% 
 9.38% 
 16.46% 


 8.77% 
 17.46% 
 21.62% 
 12.50% 
 11.90% 


 E-  33 
321
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 North 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  3.4.6.2 
 UNE 
 ISDN/  Non- 


 Dispatch/  NC(%) 


 12.40% 
 3.85% 
 9.57% 
 28.00% 
 16.24% 
 7.41% 
 22.05% 
 10.00% 


 B.  3.4.7.1 
 Line 
 Sharin  g/ 


 Dispatch/  NC(%) 


 16.67% 
 0.00% 
 18.53% 


 0.00% 
 23.73% 


 0.00% 
 25.88% 


 0.00% 
 1,2,3,4 


 B.  3.4.7.2 
 Line 
 Sharin  g/ 


 Non-  Dispatch/ 


 NC(%) 


 17.14% 
 0.00% 
 23.50% 
 57.14% 
 19.77% 
 28.57% 
 25.62% 
 75.00% 
 1,2,3,4 


 B.  3.4.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  Dispatch/ 


 NC(%) 


 14.24% 
 10.50% 
 16.02% 
 6.68% 
 15.12% 


 5.41% 
 15.43% 
 12.03% 


 B.  3.4.8.2 
 2W 
 Analo  g 


 Loop 
 Design/  Non- 


 Dispatch/  NC(%) 


 14.24% 
 8.00% 
 16.02% 


 7.89% 
 15.12% 


 8.87% 
 15.43% 


 8.13% 


 B.  3.4.9.1 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 Dispatch/  NC(%) 


 14.26% 
 20.00% 
 16.08% 
 0.00% 
 15.22% 


 0.00% 
 15.44% 


 0.00% 


 4 


 B.  3.4.9.2 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 Non-  Dispatch/ 


 NC(%) 
 12.82% 
 0.00% 
 14.15% 


 0.00% 
 13.52% 


 0.00% 
 14.25% 


 0.00% 
 1,2 


 B.  3.4.10.1 
 Other 
 Desi 
 gn/  Dispatch/ 


 NC(%) 


 14.72% 
 0.00% 
 19.46% 


 0.00% 
 19.95% 


 0.00% 
 22.63% 


 0.00% 


 1 


 B.  3.4.10.2 
 Other 
 Desi 
 gn/  Non- 


 Dispatch/  NC(%) 


 15.13% 
 0.00% 
 15.69% 


 0.00% 
 15.48% 


 0.00% 
 16.69% 


 0.00% 


 B.  3.4.11.1 
 Other 
 Non-  Desi 


 gn/  Dispatch/ 


 NC(%) 


 14.24% 
 50.00% 
 16.02% 
 0.00% 
 15.12% 
 40.00% 
 15.43% 
 0.00% 
 1,2,3,4 


 B.  3.4.11.2 
 Other 
 Non-  Desi 


 gn/  Non- 
 Dispatch/  NC(%) 


 12.72% 
 0.00% 
 14.13% 


 0.00% 
 13.23% 
 50.00% 
 14.55% 
 100.00% 
 1,2,3,4 


 Out 
 of 
 Service 


 > 
 24 


 hours 


 [M&  R- 


 5] 


 B.  3.5.2.1 
 Local 
 Interoffice 


 Trans  port/ 
 Dispatch/  NC(%) 


 0.24% 
 0.00% 
 0.00% 
 0.00% 
 0.39% 
 0.00% 
 0.00% 
 0.00% 


 4 


 B.  3.5.2.2 
 Local 
 Interoffice 


 Trans  port/ 
 Non-  Dispatch/ 


 NC(%) 
 0.00% 
 0.00% 
 0.24% 
 0.00% 
 0.00% 
 0.00% 
 0.18% 
 0.00% 
 1,2,4 


 B.  3.5.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  Dispatch/ 


 NC(%) 
 5.29% 
 1.65% 
 6.84% 
 1.77% 
 6.91% 
 2.12% 
 9.33% 
 2.57% 


 B.  3.5.3.2 
 Loo  p 
 + 
 Port 


 Combinations/  Non- 


 Dispatch/  NC(%) 


 2.12% 
 1.02% 
 2.16% 
 1.11% 
 2.42% 
 0.00% 
 3.91% 
 0.71% 


 B.  3.5.4.1 
 Combo 
 Other/  Dis 


 patch/  NC(%) 


 5.15% 
 0.00% 
 6.65% 
 0.00% 
 6.71% 
 0.00% 
 9.08% 
 0.00% 
 1,3,4 


 B.  3.5.4.2 
 Combo 
 Other/  Non- 


 Dis  patch/ 
 NC(%) 


 5.15% 
 0.00% 
 6.65% 
 0.00% 
 6.71% 
 0.00% 
 9.08% 
 0.00% 
 1,2,3,4 


 B.  3.5.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Dispatch/ 


 NC(%) 
 48.06% 
 0.00% 
 51.94% 


 0.00% 
 53.33% 


 0.00% 
 48.72% 


 7.14% 


 B.  3.5.5.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Non- 


 Dispatch/  NC(%) 


 3.35% 
 0.00% 
 2.60% 
 0.00% 
 3.70% 
 0.00% 
 1.32% 
 0.00% 
 2,3,4 


 B.  3.5.6.1 
 UNE 
 ISDN/  Dis 


 patch/  NC(%) 


 0.00% 
 3.13% 
 1.27% 
 0.00% 
 0.00% 
 2.70% 
 2.53% 
 0.00% 


 B.  3.5.6.2 
 UNE 
 ISDN/  Non- 


 Dis 
 patch/  NC(%) 


 0.00% 
 0.00% 
 0.88% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 B.  3.5.7.1 
 Line 
 Sharin  g/ 


 Dispatch/  NC(%) 


 48.06% 
 0.00% 
 51.94% 


 0.00% 
 53.33% 


 0.00% 
 48.72% 


 0.00% 


 B.  3.5.7.2 
 Line 
 Sharin  g/ 


 Non-  Dispatch/ 


 NC(%) 


 3.35% 
 0.00% 
 2.60% 
 0.00% 
 3.70% 
 0.00% 
 1.32% 
 0.00% 


 B.  3.5.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  Dispatch/ 


 NC(%) 


 5.29% 
 0.58% 
 6.84% 
 0.42% 
 6.91% 
 0.00% 
 9.33% 
 0.00% 


 B.  3.5.8.2 
 2W 
 Analo  g 


 Loop 
 Design/  Non- 


 Dispatch/  NC(%) 


 5.29% 
 0.00% 
 6.84% 
 0.00% 
 6.91% 
 0.00% 
 9.33% 
 0.00% 


 B.  3.5.9.1 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 Dispatch/  NC(%) 


 5.20% 
 0.00% 
 6.78% 
 0.00% 
 6.82% 
 0.00% 
 9.30% 
 0.00% 


 4 


 B.  3.5.9.2 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 Non-  Dispatch/ 


 NC(%) 
 1.95% 
 0.00% 
 2.19% 
 0.00% 
 2.51% 
 0.00% 
 4.05% 
 0.00% 


 B.  3.5.10.1 
 Other 
 Desi  gn/ 
 Dispatch/  NC(%) 


 0.83% 
 0.00% 
 0.73% 
 0.00% 
 0.24% 
 0.00% 
 1.41% 
 0.00% 


 1 


 B.  3.5.10.2 
 Other 
 Desi  gn/ 


 Non-  Dispatch/ 


 NC(%) 


 0.38% 
 0.00% 
 0.29% 
 0.00% 
 0.26% 
 0.00% 
 0.21% 
 0.00% 


 B.  3.5.11.1 
 Other 
 Non-  Desi 


 gn/  Dispatch/ 


 NC(%) 


 5.29% 
 0.00% 
 6.84% 
 0.00% 
 6.91% 
 20.00% 


 9.33% 
 100.00% 


 1,2,3,4 


 E-  34 
322
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 North 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  3.5.11.2 
 Other 
 Non-  Design/ 


 Non-  Dispatch/ 


 NC(%) 


 2.12% 
 0.00% 
 2.16% 
 0.00% 
 2.42% 
 0.00% 
 3.91% 
 0.00% 
 1,2,3,4 


 UNBUNDLED 
 NETWORK 
 ELEMENTS 


 - 
 BILLING 


 Invoice 
 Accuracy 


 [B-  1] 


 B.  4.1 
 NC(%) 


 98.45% 
 99.38% 
 98.22% 
 99.97% 
 98.73% 
 99.88% 
 98.73% 
 99.99% 


 Mean 
 Time 
 to 
 Deliver 


 Invoices 


 - 
 CRIS 


 [B-  2] 


 B.  4.2 
 Re  gion( 
 business 


 days) 


 3.68 
 7.29 
 3.86 
 4.97 
 3.47 
 3.78 
 3.82 
 3.46 


 LOCAL 
 INTERCONNECTION 


 TRUNKS 
 - 
 ORDERING 


 % 
 Rejected 


 Service 
 Requests 


 [O-  7] 


 C.  1.1 
 Local 
 Interconnection 


 Trunks/  NC 
 (%) 


 50.88% 
 51.02% 
 75.86% 
 41.27% 


 Reject 
 Interval 


 [O-  8] 


 C.  1.2 
 Local 
 Interconnection 


 Trunks/  NC 
 (%) 


 96.55% 
 100.00% 


 86.36% 
 100.00% 


 FOC 
 Timeliness 


 [O-  9] 


 C.  1.3 
 Local 
 Interconnection 


 Trunks/  NC 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 [O-  11] 


 C.  1.4 
 Local 
 Interconnection 


 Trunks/  NC 
 (%) 


 97.56% 
 100.00% 
 100.00% 


 LOCAL 
 INTERCONNECTION 


 TRUNKS 
 - 
 PROVISIONING 


 Order 
 Completion 


 Interval 
 [P-  4] 


 C.  2.1 
 Local 
 Interconnection 


 Trunks/  NC 
 (days) 


 27.38 
 17.35 
 40.32 
 15.83 
 25.54 
 18.09 
 17.92 
 13.33 


 4 


 Held 
 Orders 


 [P-  1] 


 C.  2.2 
 Local 
 Interconnection 


 Trunks/  NC 
 (days) 


 0.00 
 0.00 
 0.00 
 0.00 
 0.00 
 0.00 
 0.00 
 0.00 


 % 
 Jeopardies 


 [P-  2] 


 C.  2.3 
 Local 
 Interconnection 


 Trunks/  NC 
 (%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 4 


 % 
 Missed 


 Installation 


 Appointments 


 [P-  3] 


 C.  2.5 
 Local 
 Interconnection 


 Trunks/  NC 
 (%) 


 1.52% 
 0.00% 
 0.00% 
 0.00% 
 2.22% 
 0.00% 
 2.82% 
 0.00% 


 % 
 Provisioning 


 Troubles 
 within 
 30 
 Days 


 [P-  9] 


 C.  2.6 
 Local 
 Interconnection 


 Trunks/  NC 
 (%) 


 0.00% 
 0.00% 
 0.87% 
 0.00% 
 0.66% 
 0.00% 
 0.00% 
 0.00% 


 Average 
 Completion 


 Notice 
 Interval 


 [P-  5] 


 C.  2.7 
 Local 
 Interconnection 


 Trunks/  NC 
 (hours) 


 268.75 
 38.43 
 775.79 


 31.34 
 317.25 


 18.31 
 264.34 


 32.96 


 4 


 Total 
 Service 


 Order 
 Cycle 
 Time 
 [P-  10] 


 C.  2.8 
 Local 
 Interconnection 


 Trunks/  NC 
 (days) 


 23.35 
 18.83 
 18.90 
 14.54 
 4 


 % 
 Completions 


 w/  o 
 Notice 


 or 
 < 
 24 


 hours 


 [P-  6] 


 C.  2.10.1 
 Local 
 Interconnection 


 Trunks/  Dis 
 patch/  NC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 4 


 Service 
 Order 
 Accuracy 


 [P-  11] 


 E-  35 
323
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 North 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 C.  2.11.1.1 
 Local 
 Interconnection 


 Trunks/<  10 


 circuits/  Dis 
 patch/  NC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 C.  2.11.1.2 
 Local 
 Interconnection 


 Trunks/<  10 
 circuits/  Non- 


 Dis 
 patch/  NC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 C.  2.11.2.1 
 Local 
 Interconnection 


 Trunks/>=  10 


 circuits/  Dis 
 patch/  NC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,4 


 C.  2.11.2.2 
 Local 
 Interconnection 


 Trunks/>=  10 
 circuits/  Non- 


 Dis 
 patch/  NC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2 


 LOCAL 
 INTERCONNECTION 


 TRUNKS 
 - 
 MAINTENANCE 


 AND 
 REPAIR 


 Missed 
 Repair 
 Appointments 


 [M&  R- 
 1] 


 C.  3.1.1 
 Local 
 Interconnection 


 Trunks/  Dis 
 patch/  NC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 C.  3.1.2 
 Local 
 Interconnection 


 Trunks/  Non- 
 Dispatch/  NC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 3,4 


 Customer 
 Trouble 
 Report 
 Rate 
 [M&  R- 


 2] 


 C.  3.2.1 
 Local 
 Interconnection 


 Trunks/  Dis 
 patch/  NC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 C.  3.2.2 
 Local 
 Interconnection 


 Trunks/  Non- 
 Dispatch/  NC(%) 


 0.01% 
 0.00% 
 0.07% 
 0.00% 
 0.03% 
 0.00% 
 0.03% 
 0.00% 


 Maintenance 
 Average 
 Duration 


 [M&  R- 
 3] 


 C.  3.3.1 
 Local 
 Interconnection 


 Trunks/  Dis 
 patch/  NC( 
 hours) 


 0.00 
 0.00 
 0.00 
 0.00 
 0.00 
 0.00 
 0.00 
 0.00 


 C.  3.3.2 
 Local 
 Interconnection 


 Trunks/  Non- 


 Dis 
 patch/  NC( 


 hours) 


 0.14 
 0.00 
 0.08 
 0.00 
 0.71 
 1.80 
 0.16 
 2.83 
 3,4 


 % 
 Repeat 


 Troubles 


 within 
 30 
 Days 


 [M&  R- 


 4] 


 C.  3.4.1 
 Local 
 Interconnection 


 Trunks/  Dis 
 patch/  NC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 C.  3.4.2 
 Local 
 Interconnection 


 Trunks/  Non- 
 Dispatch/  NC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1.85% 
 0.00% 
 1.49% 
 0.00% 


 3,4 


 Out 
 of 
 Service 


 > 
 24 


 hours 


 [M&  R- 


 5] 


 C.  3.5.1 
 Local 
 Interconnection 


 Trunks/  Dis 
 patch/  NC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 C.  3.5.2 
 Local 
 Interconnection 


 Trunks/  Non- 
 Dispatch/  NC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 3,4 


 LOCAL 
 INTERCONNECTION 


 TRUNKS 
 - 
 BILLING 


 Invoice 
 Accuracy 


 [B-  1] 


 C.  4.1 
 NC(%) 


 98.45% 
 98.78% 
 98.22% 
 99.70% 
 98.73% 
 99.06% 
 98.73% 
 98.25% 


 Mean 
 Time 
 to 
 Deliver 


 Invoices 


 - 
 CABS 


 [B-  2] 


 E-  36 
324
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 North 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 C.  4.2 
 Region( 
 calendar 


 days) 


 4.84 
 4.54 
 3.94 
 3.89 
 4.96 
 4.92 
 4.54 
 4.29 


 LOCAL 
 INTERCONNECTION 


 TRUNKS 
 - 
 TRUNK 


 BLOCKING 


 Trunk 
 Group 
 Performance 


 - 
 Aggregate 


 [TGP-  1] 


 C.  5.1 
 NC 


 0 
 0 
 0 
 0 


 OPERATIONS 
 SUPPORT 
 SYSTEMS 
 - 
 PRE-  ORDERING 


 % 
 Interface 


 Availability 


 - 
 CLEC 


 [OSS-  2] 


 D.  1.1.1 
 EDI/  Re 
 gion(%) 


 99.71% 
 100.00% 


 99.64% 
 100.00% 


 D.  1.1.2 
 HAL/  Re 
 gion(%) 


 100.00% 
 100.00% 


 D.  1.1.3 
 LENS/  Re 
 gion(%) 


 99.99% 
 99.98% 
 99.85% 
 99.76% 


 D.  1.1.4 
 LEO 
 MAINFRAME/  Re 


 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 D.  1.1.6 
 LESOG/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 D.  1.1.7 
 TAG/  Re 
 gion(%) 


 100.00% 
 99.95% 
 99.99% 
 99.86% 


 D.  1.1.8 
 PSIMS/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 % 
 Interface 


 Availability 


 - 
 BST 


 & 
 CLEC 


 [OSS-  2] 


 D.  1.2.1 
 ATLAS/  COFFI/ 


 Re 
 gion(%) 


 100.00% 
 100.00% 


 D.  1.2.2 
 BOCRIS/  Re 
 gion(%) 


 100.00% 
 100.00% 
 99.96% 
 99.99% 


 D.  1.2.3 
 DSAP/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.98% 


 D.  1.2.4 
 RSAG/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.99% 


 D.  1.2.5 
 SOCS/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.99% 


 D.  1.2.6 
 SONGS/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.86% 


 D.  1.2.7 
 DOE/  Re 
 gion(%) 


 99.99% 
 99.99% 
 99.99% 
 99.26% 


 D.  1.2.8 
 LNP 
 Gatewa 


 y/  Region(%) 


 100.00% 
 99.99% 
 100.00% 


 99.49% 


 D.  1.2.9 
 COG/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.48% 


 D.  1.2.10 
 DOM/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.99% 


 D.  1.2.11 
 SOG/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 D.  1.2.1- 
 new 
 ATLAS/  Re 


 gion 
 (%) 


 100.00% 
 99.99% 


 D.  1.2.2- 
 new 
 COFFI/  Re 


 gion 
 (%) 


 100.00% 
 99.99% 


 Average 
 Response 


 Interval 
 - 
 CLEC 


 (LENS) 


 (BST 
 Measure 


 Includes 
 Additional 


 2 
 Seconds) 


 [OSS-  1] 


 D.  1.3.1.1 
 RSAG, 
 b 
 y 


 TN/  Region( 


 seconds) 


 1440.12 
 0.91 
 1782.46 


 1.11 
 2.87 
 1.20 
 2.88 
 1.02 


 D.  1.3.1.2 
 RSAG, 
 b 
 y 


 TN/  Region( 


 seconds) 


 2.96 
 0.91 
 2.95 
 1.11 
 2.94 
 1.20 
 2.91 
 1.02 


 D.  1.3.2.1 
 RSAG, 
 b 
 y 
 ADDR/  Region( 


 seconds) 


 712.69 
 0.91 
 1204.18 


 1.02 
 2.99 
 1.10 
 3.03 
 0.93 


 D.  1.3.2.2 
 RSAG, 
 b 
 y 
 ADDR/  Region( 


 seconds) 


 4.82 
 0.91 
 4.86 
 1.02 
 4.77 
 1.10 
 4.76 
 0.93 


 D.  1.3.3.1 
 ATLAS/  Re 
 gion( 
 seconds) 


 1330.23 
 0.88 
 2.95 
 0.88 
 2.95 
 0.88 
 3.01 
 0.80 


 E-  37 
325
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 North 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 D.  1.3.3.2 
 ATLAS/  Region( 


 seconds) 


 2.61 
 0.88 
 2.61 
 0.88 
 2.60 
 0.88 
 2.61 
 0.80 


 D.  1.3.4.1 
 DSAP/  Re 
 gion( 
 seconds) 


 2.68 
 0.53 
 2.70 
 0.57 
 2.71 
 0.53 
 2.71 
 0.52 


 D.  1.3.4.2 
 DSAP/  Re 
 gion( 
 seconds) 


 2.58 
 0.53 
 2.58 
 0.57 
 2.57 
 0.53 
 2.57 
 0.52 


 D.  1.3.5.1 
 CRSECSRL/  Re 


 gion( 
 seconds) 


 3.20 
 1.08 
 212.02 


 1.25 
 3.21 
 2.12 
 3.24 
 1.14 


 D.  1.3.5.2 
 CRSECSRL/  Re 


 gion( 
 seconds) 


 2.95 
 1.08 
 2.91 
 1.25 
 2.87 
 2.12 
 2.95 
 1.14 


 D.  1.3.6.1 
 COFFI/  Re 
 gion( 
 seconds) 


 4.46 
 0.63 
 4.40 
 0.67 
 4.60 
 0.63 
 4.35 
 0.64 


 D.  1.3.6.2 
 COFFI/  Re 
 gion( 
 seconds) 


 3.81 
 0.63 
 3.92 
 0.67 
 7.28 
 0.63 
 3.73 
 0.64 


 D.  1.3.7.1 
 PSIMS/  ORB/ 
 Re 
 gion( 


 seconds) 


 4.46 
 0.03 
 4.40 
 0.04 
 4.60 
 0.04 
 4.35 
 0.04 


 D.  1.3.7.2 
 PSIMS/  ORB/ 
 Re 
 gion( 


 seconds) 


 3.81 
 0.03 
 3.92 
 0.04 
 7.28 
 0.04 
 3.73 
 0.04 


 Average 
 Response 


 Interval 
 - 
 CLEC 


 (TAG) 
 (BST 
 Measure 


 Includes 
 Additional 


 2 
 Seconds) 


 [OSS-  1] 


 D.  1.4.1.1 
 RSAG, 
 b 
 y 


 TN/  Region( 


 seconds) 


 1440.12 
 1.10 
 1782.46 


 1.31 
 2.87 
 1.60 
 2.88 
 1.52 


 D.  1.4.1.2 
 RSAG, 
 b 
 y 


 TN/  Region( 


 seconds) 


 2.96 
 1.10 
 2.95 
 1.31 
 2.94 
 1.60 
 2.91 
 1.52 


 D.  1.4.2.1 
 RSAG, 
 b 
 y 
 ADDR/  Region( 


 seconds) 


 712.69 
 1.62 
 1204.18 


 1.85 
 2.99 
 3.05 
 3.03 
 2.34 


 D.  1.4.2.2 
 RSAG, 
 b 
 y 
 ADDR/  Region( 


 seconds) 


 4.82 
 1.62 
 4.86 
 1.85 
 4.77 
 3.05 
 4.76 
 2.34 


 D.  1.4.4.1 
 ATLAS 
 - 
 DID/  Re 


 gion( 
 seconds) 


 1.48 
 2.18 
 1.76 
 1.37 


 D.  1.4.4.2 
 ATLAS 
 - 
 DID/  Re 


 gion( 
 seconds) 


 1.48 
 2.18 
 1.76 
 1.37 


 D.  1.4.5.1 
 ATLAS 
 - 
 TN/  Re 


 gion( 
 seconds) 


 1330.23 
 1.35 
 2.95 
 1.56 
 2.95 
 1.86 
 3.01 
 1.89 


 D.  1.4.5.2 
 ATLAS 
 - 
 TN/  Re 


 gion( 
 seconds) 


 2.61 
 1.35 
 2.61 
 1.56 
 2.60 
 1.86 
 2.61 
 1.89 


 D.  1.4.6.1 
 DSAP/  Re 
 gion( 
 seconds) 


 2.68 
 1.58 
 2.70 
 1.71 
 2.71 
 1.74 
 2.71 
 1.83 


 D.  1.4.6.2 
 DSAP/  Re 
 gion( 
 seconds) 


 2.58 
 1.58 
 2.58 
 1.71 
 2.57 
 1.74 
 2.57 
 1.83 


 D.  1.4.7.1 
 TAG/  Re 
 gion( 
 seconds) 


 3.20 
 1.75 
 212.02 


 2.15 
 3.21 
 2.51 
 3.24 
 2.85 


 D.  1.4.7.2 
 TAG/  Re 
 gion( 
 seconds) 


 2.95 
 1.75 
 2.91 
 2.15 
 2.87 
 2.51 
 2.95 
 2.85 


 OPERATIONS 
 SUPPORT 
 SYSTEMS 
 - 
 MAINTENANCE 


 AND 
 REPAIR 


 % 
 Interface 


 Availability 


 - 
 CLEC 


 [OSS-  3] 


 D.  2.2.1 
 CLEC 
 TAFI/  Re 


 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 D.  2.2.2 
 ECTA/  Re 
 gion(%) 


 100.00% 
 99.95% 
 100.00% 


 99.86% 


 % 
 Interface 


 Availability 


 - 
 BST 


 & 
 CLEC 


 [OSS-  3] 


 D.  2.3.1 
 CRIS/  Re 
 gion(%) 


 100.00% 
 100.00% 
 99.96% 
 99.99% 


 D.  2.3.2 
 LMOS 
 HOST/  Re 


 gion(%) 


 100.00% 
 100.00% 
 99.91% 
 100.00% 


 D.  2.3.3 
 LNP/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.91% 


 D.  2.3.4 
 MARCH/  Re 
 gion(%) 


 100.00% 
 99.99% 
 100.00% 
 100.00% 


 D.  2.3.5 
 OSPCM/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 D.  2.3.6 
 Predictor/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.92% 


 E-  38 
326
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 North 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 D.  2.3.7 
 SOCS/  Region(%) 


 100.00% 
 100.00% 
 100.00% 
 99.99% 


 Average 
 Response 


 Interval 
 <= 
 4 
 Seconds 


 [OSS-  4] 


 D.  2.4.1 
 CRIS/  Re 
 gion(%) 


 94.91% 
 94.17% 
 94.75% 
 94.83% 
 95.12% 
 94.99% 
 94.95% 
 94.66% 


 D.  2.4.2 
 DLETH/  Re 
 gion(%) 


 3.07% 
 3.22% 
 3.14% 
 4.03% 
 3.16% 
 4.59% 
 2.58% 
 3.67% 


 D.  2.4.3 
 DLR/  Re 
 gion(%) 


 4.30% 
 2.41% 
 4.07% 
 2.41% 
 4.03% 
 3.36% 
 4.47% 
 7.51% 


 D.  2.4.4 
 LMOS/  Re 
 gion(%) 


 99.67% 
 99.69% 
 99.63% 
 99.59% 
 99.60% 
 99.60% 
 99.61% 
 99.58% 


 D.  2.4.5 
 LMOSu 
 pd/  Region(%) 


 78.95% 
 70.39% 
 76.71% 
 65.38% 
 78.49% 
 66.19% 
 79.21% 
 66.24% 


 D.  2.4.6 
 LNP/  Re 
 gion(%) 


 99.78% 
 99.37% 
 99.31% 
 99.09% 
 99.68% 
 99.19% 
 99.65% 
 98.81% 


 D.  2.4.7 
 MARCH/  Re 
 gion(%) 


 28.35% 
 33.16% 
 28.32% 
 26.44% 
 28.04% 
 31.69% 
 28.10% 
 29.64% 


 D.  2.4.8 
 OSPCM/  Re 
 gion(%) 


 23.94% 
 13.59% 
 27.25% 
 20.73% 
 31.23% 
 24.50% 
 33.15% 
 21.43% 


 D.  2.4.9 
 Predictor/  Re 
 gion(%) 


 15.78% 
 19.48% 
 15.03% 
 20.43% 
 13.82% 
 19.61% 
 12.71% 
 21.73% 


 D.  2.4.10 
 SOCS/  Re 
 gion(%) 


 99.84% 
 99.91% 
 99.83% 
 99.90% 
 99.85% 
 99.88% 
 99.81% 
 99.86% 


 D.  2.4.11 
 NIW/  Region(%) 


 82.97% 
 81.81% 
 84.38% 
 83.15% 
 84.01% 
 83.00% 
 82.83% 
 81.89% 


 Average 
 Response 


 Interval 
 <= 
 10 
 Seconds 


 [OSS-  4] 


 D.  2.5.1 
 CRIS/  Re 
 gion(%) 


 98.99% 
 99.34% 
 98.97% 
 99.34% 
 99.05% 
 99.46% 
 99.02% 
 99.39% 


 D.  2.5.2 
 DLETH/  Re 
 gion(%) 


 78.81% 
 86.16% 
 78.96% 
 87.92% 
 79.20% 
 85.30% 
 77.66% 
 82.58% 


 D.  2.5.3 
 DLR/  Re 
 gion(%) 


 77.94% 
 92.02% 
 77.45% 
 91.98% 
 76.65% 
 88.18% 
 71.08% 
 41.67% 


 D.  2.5.4 
 LMOS/  Re 
 gion(%) 


 99.81% 
 99.86% 
 99.79% 
 99.82% 
 99.79% 
 99.84% 
 99.80% 
 99.85% 


 D.  2.5.5 
 LMOSu 
 pd/  Region(%) 


 90.95% 
 83.33% 
 89.31% 
 80.59% 
 90.04% 
 80.25% 
 90.59% 
 80.53% 


 D.  2.5.6 
 LNP/  Re 
 gion(%) 


 99.93% 
 99.87% 
 99.54% 
 99.72% 
 99.81% 
 99.63% 
 99.83% 
 99.52% 


 D.  2.5.7 
 MARCH/  Re 
 gion(%) 


 28.35% 
 33.16% 
 28.32% 
 26.44% 
 28.04% 
 31.69% 
 28.10% 
 29.64% 


 D.  2.5.8 
 OSPCM/  Re 
 gion(%) 


 96.89% 
 96.12% 
 97.38% 
 95.12% 
 97.81% 
 97.35% 
 98.41% 
 95.83% 


 D.  2.5.9 
 Predictor/  Re 
 gion(%) 


 15.78% 
 19.48% 
 15.03% 
 20.43% 
 13.82% 
 19.61% 
 12.71% 
 21.73% 


 D.  2.5.10 
 SOCS/  Re 
 gion(%) 


 99.99% 
 99.99% 
 99.99% 
 99.98% 
 99.98% 
 100.00% 


 99.98% 
 100.00% 


 D.  2.5.11 
 NIW/  Region(%) 


 99.17% 
 98.96% 
 99.49% 
 99.33% 
 99.39% 
 99.21% 
 99.42% 
 99.25% 


 Average 
 Response 


 Interval 
 > 
 10 


 Seconds 


 [OSS-  4] 


 D.  2.6.1 
 CRIS/  Re 
 gion(%) 


 1.01% 
 0.66% 
 1.03% 
 0.66% 
 0.95% 
 0.54% 
 0.98% 
 0.61% 


 D.  2.6.2 
 DLETH/  Re 
 gion(%) 


 21.19% 
 13.84% 
 21.04% 
 12.08% 
 20.80% 
 14.70% 
 22.34% 
 17.42% 


 D.  2.6.3 
 DLR/  Re 
 gion(%) 


 22.06% 
 7.98% 
 22.55% 


 8.02% 
 23.35% 
 11.82% 
 28.92% 
 58.33% 


 D.  2.6.4 
 LMOS/  Re 
 gion(%) 


 0.19% 
 0.14% 
 0.21% 
 0.18% 
 0.21% 
 0.16% 
 0.20% 
 0.15% 


 D.  2.6.5 
 LMOSu 
 pd/  Region(%) 


 9.05% 
 16.67% 
 10.69% 
 19.41% 
 9.96% 
 19.75% 


 9.41% 
 19.47% 


 D.  2.6.6 
 LNP/  Re 
 gion(%) 


 0.07% 
 0.13% 
 0.46% 
 0.28% 
 0.19% 
 0.37% 
 0.17% 
 0.48% 


 D.  2.6.7 
 MARCH/  Re 
 gion(%) 


 71.65% 
 66.84% 
 71.68% 
 73.56% 
 71.96% 
 68.31% 
 71.90% 
 70.36% 


 E-  39 
327
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 North 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 D.  2.6.8 
 OSPCM/  Region(%) 


 3.11% 
 3.88% 
 2.62% 
 4.88% 
 2.19% 
 2.65% 
 1.59% 
 4.17% 


 D.  2.6.9 
 Predictor/  Re 
 gion(%) 


 84.22% 
 80.52% 
 84.97% 
 79.57% 
 86.18% 
 80.39% 
 87.29% 
 78.27% 


 D.  2.6.10 
 SOCS/  Re 
 gion(%) 


 0.01% 
 0.01% 
 0.01% 
 0.02% 
 0.02% 
 0.00% 
 0.02% 
 0.00% 


 D.  2.6.11 
 NIW/  Region(%) 


 0.83% 
 1.04% 
 0.51% 
 0.67% 
 0.61% 
 0.79% 
 0.58% 
 0.75% 


 COLLOCATION 
 - 
 COLLOCATION  Average  Response  Time  [C- 


 1] 


 E.  1.1.1 
 Virtual/  NC 
 (calendar 
 days) 


 6 
 4 


 0 
 1,2,4 


 E.  1.1.3 
 Ph  ysical 
 Caged/  NC( 


 business 
 days) 


 5 
 4 
 3 
 81,3,4 


 E.  1.1.4 
 Ph  ysical 
 Cageless/  NC( 


 business 
 days) 


 3 
 3 
 7 
 31,2,3 


 Average 
 Arrangement 


 Time 
 [C-  2] 


 E.  1.2.1 
 Virtual-  Ordinar 


 y/  NC( 
 calendar 


 days) 


 48 
 34 
 3,4 


 E.  1.2.4 
 Ph  ysical 
 Caged-  Ordinary/ 


 NC( 
 business 


 days) 


 27 
 40 
 51 
 34 
 1,4 


 E.  1.2.6 
 Ph  ysical 
 Cageless-  Ordinary/ 


 NC( 
 business 


 days) 


 32 
 65 
 58 
 16 
 1 


 % 
 Due 


 Dates 


 Missed 


 [C-  3] 


 E.  1.3.1 
 Virtual/  NC 
 (%) 


 0.00% 
 0.00% 
 3,4 


 E.  1.3.2 
 Ph  ysical/ 
 NC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 


 GENERAL 
 - 
 FLOW 


 THROUGH  %  Flow  Through  Service 


 Requests 
 [O-  3] 


 F.  1.1.1 
 Summar  y/ 
 Region(%) 


 85.28% 
 86.05% 
 84.50% 
 85.96% 


 F.  1.1.2 
 A 
 ggregate/  Region(%) 


 85.28% 
 86.05% 
 84.50% 
 85.96% 


 F.  1.1.3 
 Residence/  Re 
 gion(%) 


 86.49% 
 87.39% 
 86.74% 
 88.58% 


 F.  1.1.4 
 Business/  Re 
 gion(%) 


 73.55% 
 71.89% 
 69.54% 
 73.74% 


 F.  1.1.5 
 UNE/  Re 
 gion(%) 


 83.88% 
 84.78% 
 82.57% 
 83.84% 


 % 
 Flow 


 Through 


 Service 
 Requests 


 - 
 Achieved 


 [O-  3] 


 F.  1.2.1 
 Summar  y/ 
 Region(%) 


 75.79% 
 77.51% 
 76.58% 
 78.96% 


 F.  1.2.2 
 A 
 ggregate/  Region(%) 


 75.79% 
 77.51% 
 76.58% 
 78.96% 


 F.  1.2.3 
 Residence/  Re 
 gion(%) 


 79.16% 
 80.53% 
 79.88% 
 81.68% 


 F.  1.2.4 
 Business/  Re 
 gion(%) 


 50.63% 
 51.15% 
 51.58% 
 53.42% 


 F.  1.2.5 
 UNE/  Re 
 gion(%) 


 72.17% 
 74.87% 
 74.12% 
 77.27% 


 % 
 Flow 


 Through 


 Service 
 Requests 


 - 
 LNP 


 [O-  3] 


 F.  1.3.1 
 Summar  y/ 
 Region(%) 


 92.25% 
 92.59% 
 89.75% 
 83.63% 


 F.  1.3.2 
 A 
 ggregate/  Region(%) 


 92.25% 
 92.59% 
 89.75% 
 83.63% 


 GENERAL 
 - 
 PRE-  ORDERING 


 E-  40 
328
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 North 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 Loop 
 Makeup 


 Inquiry 
 (Manual) 


 [PO-  1] 


 F.  2.1 
 Loo 
 ps/  NC(%) 


 73.33% 
 33.33% 
 33.33% 
 54.55% 
 2,3 


 Loop 
 Makeup 


 Inquiry 
 (Electronic) 


 [PO-  2] 


 F.  2.2 
 Loo 
 ps/  NC(%) 


 98.41% 
 96.32% 
 99.48% 
 77.44% 


 GENERAL 
 - 
 ORDERING  Average  Speed 


 of 
 Answer 


 [O-  12] 


 F.  4.1 
 Re 
 gion( 


 seconds) 


 141.64 
 30.33 
 137.90 


 28.63 
 194.86 


 35.16 
 259.48 


 58.19 


 GENERAL 
 - 
 MAINTENANCE 


 CENTER 
 Average 
 Answer 
 Time 
 [M&  R- 


 6] 


 F.  5.1 
 Re 
 gion( 


 seconds) 


 43.10 
 26.35 
 41.00 
 23.60 
 64.68 
 25.99 
 52.80 
 28.04 


 GENERAL 
 - 
 OPERATOR 


 SERVICES 
 (TOLL) 


 Average 
 Speed 
 to 
 Answer 


 [OS-  1] 


 F.  6.1 
 NC( 
 seconds) 


 2.50 
 2.31 
 2.24 
 2.44 


 % 
 Answered 


 in 
 10 
 seconds 


 [OS-  2] 


 F.  6.2 
 NC(%) 


 92.30% 
 93.20% 
 93.70% 
 92.80% 


 GENERAL 
 - 
 DIRECTORY 


 ASSISTANCE 
 Average 
 Speed 
 to 
 Answer 


 [DA-  1] 


 F.  7.1 
 NC( 
 seconds) 


 3.32 
 3.57 
 3.12 
 2.97 


 % 
 Answered 


 in 
 10 
 seconds 


 [DA-  2] 


 F.  7.2 
 NC(%) 


 91.80% 
 90.30% 
 92.70% 
 93.70% 


 GENERAL 
 - 
 BILLING  Usage  Data 


 Delivery 
 Accuracy 


 [B-  3] 


 F.  9.1 
 Re 
 gion(%) 


 100.00% 
 100.00% 
 97.75% 
 100.00% 


 95.22% 
 100.00% 
 100.00% 
 100.00% 


 Usage 
 Data 
 Delivery 


 Timeliness 


 [B-  5] 


 F.  9.2 
 Re 
 gion(%) 


 98.37% 
 93.14% 
 75.41% 
 94.80% 
 94.93% 
 97.64% 
 99.33% 
 99.38% 


 Usage 
 Data 
 Delivery 


 Completeness 


 [B-  4] 


 F.  9.3 
 Re 
 gion(%) 


 99.38% 
 99.89% 
 99.77% 
 99.54% 
 97.21% 
 99.95% 
 99.92% 
 99.91% 


 Mean 
 Time 
 to 
 Deliver 


 Usage 
 [B-  6] 


 F.  9.4 
 Re 
 gion( 


 days) 


 3.49 
 3.05 
 6.85 
 3.29 
 4.34 
 2.52 
 3.24 
 2.43 


 Recurring 
 Charge 
 Completeness 


 [B-  7] 


 F.  9.5.1 
 Resale/  NC 
 (%) 


 73.98% 
 99.28% 
 86.47% 
 78.71% 
 72.01% 
 95.98% 
 82.09% 
 99.04% 


 F.  9.5.2 
 UNE/  NC 
 (%) 


 96.85% 
 97.39% 
 98.66% 
 98.88% 


 F.  9.5.3 
 Interconnection/  NC 


 (%) 


 94.49% 
 95.62% 
 99.96% 
 98.68% 


 E-  41 
329
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 North 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 Non-  Recurring 
 Charge 
 Completeness 


 [B-  8] 


 F.  9.6.1 
 Resale/  NC 
 (%) 


 90.24% 
 88.34% 
 83.78% 
 98.19% 
 85.83% 
 97.29% 
 84.41% 
 98.92% 


 F.  9.6.2 
 UNE/  NC 
 (%) 


 97.26% 
 98.82% 
 99.01% 
 98.64% 


 F.  9.6.3 
 Interconnection/  NC 


 (%) 


 84.30% 
 87.76% 
 98.63% 
 97.97% 


 GENERAL 
 - 
 CHANGE 


 MANAGEMENT  %  Software  Release  Notices  Sent 


 On 
 Time 


 [CM-  1] 


 F.  10.1 
 NC(%) 


 100.00% 
 100.00% 


 2,3 


 % 
 Change 


 Management 


 Documentation 


 Sent 
 On 
 Time 


 [CM-  3A] 


 F.  10.3 
 NC(%) 


 100.00% 
 100.00% 
 1,4 


 % 
 Change 


 Management 


 Documentation 


 (Defects, 
 Corrections, 


 etc.) 
 Sent 
 On 
 Time 


 [CM-  3B] 


 F.  10.4 
 NC(%) 


 77.78% 
 2 


 Average 
 Documentation 


 Release 
 Delay 
 Days 
 [CM-  4] 


 F.  10.5 
 NC( 
 average)  %  CLEC  Interface 


 Outages 
 Sent 
 within 


 15 
 Minutes 


 [CM-  5] 


 F.  10.6 
 NC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 GENERAL 
 - 
 NEW 


 BUSINESS 


 REQUESTS 


 % 
 New 


 Business 


 Requests 
 Processed 


 within 
 30 
 Business 


 Days 
 [BFR-  1] 


 F.  11.1 
 Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 % 
 Quotes 


 Provided 


 within 
 X 
 Business 


 Days 
 [BFR-  2A] 


 F.  11.2.1 
 Re 
 gion(%) 


 100.00% 
 100.00% 
 1,3 


 F.  11.2.3 
 Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 GENERAL 
 - 
 ORDERING  Acknowledgement 


 Message 
 Timeliness 


 [O-  1] 


 F.  12.1.1 
 EDI/  Re 
 gion(%) 


 99.97% 
 99.99% 
 100.00% 
 100.00% 


 F.  12.1.2 
 TAG/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 Acknowledgement 
 Message 
 Completeness 


 [O-  2] 


 F.  12.2.1 
 EDI/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.62% 


 F.  12.2.2 
 TAG/  Re 
 gion(%) 


 100.00% 
 100.00% 
 99.99% 
 100.00% 


 GENERAL 
 - 
 DATABASE 


 UPDATES 
 Average 
 Database 


 Update 
 Interval 


 [D-  1] 


 F.  13.1.1 
 LIDB/  NC 
 (hours) 


 0.55 
 0.55 
 1.49 
 1.49 
 0.53 
 0.51 
 0.52 
 0.52 


 F.  13.1.2 
 Director  y 
 Listings/  NC( 


 hours) 


 0.10 
 0.10 
 0.09 
 0.09 
 0.10 
 0.10 
 0.11 
 0.11 


 F.  13.1.3 
 Director  y 
 Assistance/  NC( 


 hours) 


 4.49 
 4.48 
 4.80 
 4.80 
 4.60 
 4.60 
 6.48 
 6.48 


 E-  42 
330
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 North 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 % 
 Update 


 Accuracy 


 [D-  2] 


 F.  13.2.1 
 LIDB/  NC 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 93.48% 


 F.  13.2.2 
 Director  y 
 Listings/  NC(%) 


 99.38% 
 99.03% 
 99.79% 
 99.35% 


 F.  13.2.3 
 Director  y 
 Assistance/  NC(%) 


 100.00% 
 100.00% 
 97.87% 
 99.19% 


 % 
 NXXs 


 / 
 LRNs 


 Loaded 


 by 
 LERG 


 Effective 


 Date 
 [D-  3] 


 F.  13.3 
 Re 
 gion(%) 


 96.77% 
 100.00% 
 100.00% 
 98.41% 


 GENERAL 
 - 
 NETWORK 


 OUTAGE 
 NOTIFICATION 


 Mean 
 Time 
 to 
 Notify 


 CLEC 
 of 
 Major 


 Network 


 Outages 
 [M&  R- 
 7] 


 F.  14.1 
 Region(  minutes) 


 739 
 218 


 0 
 0 
 154 


 123 
 791 
 602 
 1,3,4 


 Abbreviations:  blank  cell  =  no  data 
 available 
 Notes:  1  =  Sample 
 Size 
 under 


 10 
 in 
 March 


 2 
 = 
 Sample 


 Size 
 under 


 10 
 in 
 April 


 2 
 = 
 Sample 


 Size 
 under 


 10 
 in 
 May 


 4 
 = 
 Sample 


 Size 
 under 


 10 
 in 
 June 


 E-  43 
331
 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Appendix 
 F 


 South 
 Carolina 


 Performance 


 Metrics 


 Except 
 where 
 noted, 
 the 
 data 


 included 


 here 
 is 
 taken 


 from 
 the 
 South 


 Carolina 


 Monthly 
 State 
 Summary 


 (MSS) 
 Reports 


 provided 


 by 


 BellSouth, 
 calculated 
 according 
 to 
 the 


 Georgia 


 Service 
 Quality 
 Measurement 


 (SQM) 
 business 


 rules. 
 This 
 table 


 is 
 provided 


 as 
 a 


 reference 
 tool 
 for 
 the 
 convenience 


 of 
 the 


 reader. 


 No 
 conclusions 


 are 
 to 
 be 
 drawn 


 from 
 the 
 raw 


 data 
 contained 


 in 
 this 


 table. 


 Our 


 analysis 
 is 
 based 


 on 
 the 
 totality 


 of 
 the 
 circumstances, 


 such 
 that 
 we 
 may 


 use 
 non-  metric 


 evidence, 
 and 
 may 


 rely 
 more 


 heavily 


 on 
 some 


 metrics 
 more 
 than 
 others, 


 in 
 making 


 our 
 determination. 


 The 
 inclusion 


 of 
 these 


 particular 


 metrics 
 in 
 this 


 table 


 does 
 not 
 necessarily 


 mean 
 that 
 we 
 relied 


 on 
 all 
 of 
 these 


 metrics, 


 or 
 that 


 other 


 metrics 


 may 
 not 
 also 


 be 
 important 


 in 
 our 


 analysis. 


 Some 
 metrics 


 that 
 we 
 have 


 relied 
 on 
 in 
 the 


 past 


 and 
 may 


 rely 
 on 
 for 


 a 
 future 


 application 


 were 
 not 
 included 


 here 
 because 


 there 
 was 
 no 
 data 


 provided 


 for 
 them 


 (usually 
 either 
 because 


 there 
 was 
 no 
 activity, 


 or 
 because 


 the 
 metrics 


 are 
 still 


 under 


 development). 


 Metrics 
 with 
 no 
 retail 


 analog 


 provided 


 are 
 usually 


 compared 


 with 
 a 
 benchmark. 


 Note 
 that 
 for 
 some 


 metrics 


 during 
 the 
 period 


 provided 
 there 
 may 
 be 
 changes 


 in 
 the 


 metric 


 definition, 


 or 
 changes 


 in 
 the 


 retail 


 analog 


 applied, 


 making 
 it 
 difficult 


 to 
 compare 


 data 


 Note: 
 All 
 data 


 was 
 calculated 


 using 
 BellSouth's 


 data 
 platform 


 PMAP 
 4.0. 
 The 
 March 


 data 
 in 
 this 


 appendix 


 were 
 not 
 taken 


 from 
 the 


 MSS 
 reports, 


 which 
 for 
 that 


 month 


 were 
 calculated 


 using 
 PMAP 


 2.6, 
 but 
 instead 


 were 
 calculated 


 using 
 PMAP 


 4.0 
 by 
 BellSouth. 


 This 


 data 
 also 
 conforms 


 to 
 the 


 Georgia 


 Service 
 Quality 
 Measurement 


 business 
 rules 
 that 
 govern 


 the 
 regular 


 MSS 
 reports. 
332
 Metric  No. 
 SQM 
 No. 
 Metric 


 Name 


 Metric  No. 
 SQM 
 No. 
 Metric 


 Name 


 RESALE 
 A.  3.5 
 M&  R- 
 5 
 Out 


 of 
 Service 


 > 
 24 


 hours 


 Ordering 
 Billing 
 A.  1.1 
 O-  7 


 % 
 Rejected 


 Service 
 Requests 


  
 Mech. 


 A.  4.1 
 B-  1 


 Invoice 
 Accuracy 


 A.  1.2 
 O-  7 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Partially 


 Mech. 


 A.  4.2 
 B-  2 


 Mean 
 Time 
 to 
 Deliver 


 Invoices 


  
 CRIS 


 A.  1.3 
 O-  7 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Non-  Mech. 


 UNBUNDLED 
 NETWORK 
 ELEMENTS 


 A.  1.4 
 O-  8 


 Reject 
 Interval 


  
 Mech. 


 Ordering 


 A.  1.7 
 O-  8 


 Reject 
 Interval 


 - 
 Partially 


 Mech. 
  
 10 


 hours 


 B.  1.1 
 O-  7/ 
 O-  13 


 % 
 Rejected 


 Service 
 Requests 


  
 Mech. 


 A.  1.8 
 O-  8 


 Reject 
 Interval 


 - 
 Non-  Mech. 


 B.  1.2 
 O-  7/ 
 O-  13 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Partially 


 Mech. 


 A.  1.9 
 O-  9 


 FOC 
 Timeliness 


  
 Mech. 


 B.  1.3 
 O-  7/ 
 O-  13 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Non-  Mech. 


 A.  1.12 
 O-  9 


 FOC 
 Timeliness 


 - 
 Partially 


 Mech. 
 - 
 10 


 hours 


 B.  1.4 
 O-  8/ 
 O-  14 


 Reject 


 Interval 


  
 Mech. 


 A.  1.13 
 O-  9 


 FOC 
 Timeliness 


 - 
 Non-  Mech. 


 B.  1.7 
 O-  8/ 
 O-  14 


 Reject 


 Interval 


 - 
 Partially 


 Mech. 
 - 
 10 


 hours 


 A.  1.14 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Mech. 


 B.  1.8 
 O-  8/ 
 O-  14 


 Reject 


 Interval 


 - 
 Non-  Mech. 


 A.  1.15 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Partially 


 Mech. 


 B.  1.9 
 O-  9/ 
 O-  15 


 FOC 
 Timeliness 


  
 Mech. 


 A.  1.16 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Non-  Mech. 


 B.  1.12 
 O-  9/ 
 O-  15 


 FOC 
 Timeliness 


 - 
 Partially 


 Mech. 
 - 
 10 


 hours 


 Provisioning 
 B.  1.13 
 O-  9/ 
 O-  15 


 FOC 
 Timeliness 


 - 
 Non-  Mech. 


 A.  2.1 
 P-  4 


 Order 
 Completion 


 Interval 


 B.  1.14 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


  
 Mech. 


 A.  2.4 
 P-  2 


 % 
 Jeopardies 


 - 
 Mech. 


 B.  1.15 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


  
 Partially 


 Mech. 


 A.  2.5 
 P-  2 


 % 
 Jeopardies 


 - 
 Non-  Mech. 


 B.  1.16 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


  
 Non-  Mech. 


 A.  2.7 
 P-  2 


 Average 
 Jeopardy 
 Notice 
 Interval 


 - 
 Mech. 


 Provisioning 


 A.  2.8 
 P-  2 


 Average 
 Jeopardy 
 Notice 
 Interval 


 - 
 Non-  Mech. 


 B.  2.1 
 P-  4 


 Order 
 Completion 


 Interval 


 A.  2.9 
 P-  2 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Mech. 


 B.  2.2 
 P-  4 


 Order 
 Completion 


 Interval 
 within 
 X 
 days 


 - 
 xDSL 


 A.  2.10 
 P-  2 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Non-  Mech. 


 B.  2.5 
 P-  2 


 % 
 Jeopardies 


  
 Mech. 


 A.  2.11 
 P-  3 


 % 
 Missed 


 Installation 


 Appointments 


 B.  2.6 
 P-  2 


 % 
 Jeopardies 


 - 
 Non-  Mech. 


 A.  2.12 
 P-  9 


 % 
 Provisioning 


 Troubles 
 within 
 30 
 Days 


 B.  2.8 
 P-  2 


 Average 
 Jeopardy 
 Notice 
 Interval 


 - 
 Mech. 


 A.  2.14 
 P-  5 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Mech. 


 B.  2.9 
 P-  2 


 Average 
 Jeopardy 
 Notice 
 Interval 


 - 
 Non-  Mech. 


 A.  2.15 
 P-  5 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Non-  Mech. 


 B.  2.10 
 P-  2 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Mech. 


 A.  2.25 
 P-  11 


 Service 
 Order 
 Accuracy 


 B.  2.11 
 P-  2 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Non-  Mech. 


 Maintenance 
 and 
 Repair 


 B.  2.12 
 P-  7 
 Coordinated 


 Customers 
 Conversions 


 A.  3.1 
 M&  R- 
 1 
 Missed 


 Repair 
 Appointments 


 B.  2.13 
 P-  7A 


 % 
 Hot 


 Cuts 


 > 
 15 


 minutes 


 Early 


 A.  3.2 
 M&  R- 
 2 
 Customer 


 Trouble 
 Report 
 Rate 


 B.  2.14 
 P-  7A 


 Hot 
 Cut 
 Timeliness 


 A.  3.3 
 M&  R- 
 3 
 Maintenance 


 Average 
 Duration 


 B.  2.15 
 P-  7A 


 % 
 Hot 


 Cuts 


 > 
 15 


 minutes 


 Late 


 A.  3.4 
 M&  R- 
 4 
 % 
 Repeat 


 Troubles 


 within 
 30 
 Days 


 B.  2.16 
 P-  7B 


 Average 
 Recovery 


 Time 
  
 CCC 


 PERFORMANCE 
 METRIC 
 CATEGORIES 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 F-  2 
333
 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Metric  No. 
 SQM 
 No. 
 Metric 


 Name 


 Metric  No. 
 SQM 
 No. 
 Metric 


 Name 


 B.  2.17 
 P-  7C 


 % 
 Provisioning 


 Troubles 
 within 
 7 
 Days 


 - 
 Hot 


 Cuts 


 C.  3.3 
 M&  R- 
 3 
 Maintenance 


 Average 
 Duration 


 B.  2.18 
 P-  3/ 
 P-  12 


 % 
 Missed 


 Installation 


 Appointments 


 C.  3.4 
 M&  R- 
 4 
 % 
 Repeat 


 Troubles 


 within 
 30 
 Days 


 B.  2.19 
 P-  9 


 % 
 Provisioning 


 Troubles 
 within 
 30 
 Days 


 C.  3.5 
 M&  R- 
 5 
 Out 


 of 
 Service 


 > 
 24 


 hours 


 B.  2.21 
 P-  5 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Mech. 


 Billing 


 B.  2.22 
 P-  5 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Non-  Mech. 


 C.  4.1 
 B-  1 


 Invoice 
 Accuracy 


 B.  2.34 
 P-  11 


 Service 
 Order 
 Accuracy 


 C.  4.2 
 B-  2 


 Mean 
 Time 
 to 
 Deliver 


 Invoices 


 - 
 CABS 


 Maintenance 
 and 
 Repair 


 Trunk 
 Blocking 


 B.  3.1 
 M&  R- 
 1 
 Missed 


 Repair 
 Appointments 


 C.  5.1 
 TGP-  1 


 Trunk 
 Group 
 Performance 


 - 
 Aggregate 


 B.  3.2 
 M&  R- 
 2 
 Customer 


 Trouble 
 Report 
 Rate 


 OPERATIONS 
 SUPPORT 
 SYSTEMS 


 B.  3.3 
 M&  R- 
 3 
 Maintenance 


 Average 
 Duration 


 Pre-  Ordering 


 B.  3.4 
 M&  R- 
 4 
 % 
 Repeat 


 Troubles 


 within 
 30 
 Days 


 D.  1.1 
 OSS-  2 


 % 
 Interface 


 Availability 


 - 
 CLEC 


 B.  3.5 
 M&  R- 
 5 
 Out 


 of 
 Service 


 > 
 24 


 hours 


 D.  1.2 
 OSS-  2 


 % 
 Interface 


 Availability 


 - 
 BST 


 & 
 CLEC 


 Billing 
 D.  1.3 
 OSS-  1 


 Average 
 Response 


 Interval 
 - 
 CLEC 


 (LENS) 


 B.  4.1 
 B-  1 


 Invoice 
 Accuracy 


 D.  1.4 
 OSS-  1 


 Average 
 Response 


 Interval 
 - 
 CLEC 


 (TAG) 


 B.  4.2 
 B-  2 


 Mean 
 Time 
 to 
 Deliver 


 Invoices 


 - 
 CRIS 


 Maintenance 
 and 
 Repair 


 LOCAL 
 INTERCONNECTION 


 TRUNKS 


 D.  2.1 
 OSS-  3 


 % 
 Interface 


 Availability 


 - 
 BST 


 Ordering 
 D.  2.2 
 OSS-  3 


 % 
 Interface 


 Availability 


 - 
 CLEC 


 C.  1.1 
 O-  7 


 % 
 Rejected 


 Service 
 Requests 


 D.  2.3 
 OSS-  3 


 % 
 Interface 


 Availability 


 - 
 BST 


 & 
 CLEC 


 C.  1.2 
 O-  8 


 Reject 
 Interval 


 D.  2.4 
 OSS-  4 


 Average 
 Response 


 Interval 
 <= 
 4 
 Seconds 


 C.  1.3 
 O-  9 


 FOC 
 Timeliness 


 D.  2.5 
 OSS-  4 


 Average 
 Response 


 Interval 
 <= 
 10 
 Seconds 


 C.  1.4 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 D.  2.6 
 OSS-  4 


 Average 
 Response 


 Interval 
 > 
 10 


 Seconds 


 Provisioning 
 COLLOCATION 
 C.  2.1 
 P-  4 


 Order 
 Completion 


 Interval 


 Collocation 


 C.  2.2 
 P-  1 


 Held 
 Orders 


 E.  1.1 
 C-  1 


 Average 
 Response 


 Time 


 C.  2.3 
 P-  2 


 % 
 Jeopardies 


 E.  1.2 
 C-  2 


 Average 
 Arrangement 


 Time 


 C.  2.5 
 P-  3 


 % 
 Missed 


 Installation 


 Appointments 


 E.  1.3 
 C-  3 


 % 
 Due 


 Dates 


 Missed 


 C.  2.6 
 P-  9 


 % 
 Provisioning 


 Troubles 
 within 
 30 
 Days 


 GENERAL 


 C.  2.7 
 P-  5 


 Average 
 Completion 


 Notice 
 Interval 


 Flow 
 Through 


 C.  2.8 
 P-  10 


 Total 
 Service 


 Order 
 Cycle 
 Time 


 F.  1.1 
 O-  3 


 % 
 Flow 


 Through 


 Service 
 Requests 


 C.  2.10 
 P-  6 


 % 
 Completions 


 w/  o 
 Notice 


 or 
 < 
 24 


 hours 


 F.  1.2 
 O-  3 


 % 
 Flow 


 Through 


 Service 
 Requests 


 - 
 Achieved 


 C.  2.11 
 P-  11 


 Service 
 Order 
 Accuracy 


 F.  1.3 
 O-  3 


 % 
 Flow 


 Through 


 Service 
 Requests 


 - 
 LNP 


 Maintenance 
 and 
 Repair 


 Pre-  Ordering 


 C.  3.1 
 M&  R- 
 1 
 Missed 


 Repair 
 Appointments 


 F.  2.1 
 PO-  1 


 Loop 
 Makeup 


 Inquiry 
 (Manual) 


 C.  3.2 
 M&  R- 
 2 
 Customer 


 Trouble 
 Report 
 Rate 


 F.  2.2 
 PO-  2 


 Loop 
 Makeup 


 Inquiry 
 (Electronic) 


 F-  3 
334
 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Metric  No. 
 SQM 
 No. 
 Metric 


 Name 


 Metric  No. 
 SQM 
 No. 
 Metric 


 Name 


 Ordering 
 Database 
 Updates 


 F.  4.1 
 O-  12 


 Average 
 Speed 
 of 
 Answer 


 F.  13.1 
 D-  1 


 Average 
 Database 
 Update 
 Interval 


 Maintenance 
 Center 


 F.  13.2 
 D-  2 


 % 
 Update 


 Accuracy 


 F.  5.1 
 M&  R- 
 6 
 Average 


 Answer 
 Time 


 F.  13.3 
 D-  3 


 % 
 NXXs 


 / 
 LRNs 


 Loaded 


 by 
 LERG 


 Effective 


 Date 


 Operator 
 Services 
 (Toll) 


 Network 
 Outage 
 Notification 


 F.  6.1 
 OS-  1 


 Average 
 Speed 
 to 
 Answer 


 F.  14.1 
 M&  R- 
 7 
 Mean 


 Time 
 to 
 Notify 


 CLEC 
 of 
 Major 


 Network 


 Outages 


 F.  6.2 
 OS-  2 


 % 
 Answered 


 in 
 10 
 seconds 


 Directory 
 Assistance  F.  7.1  DA-  1  Average 


 Speed 
 to 
 Answer 


 F.  7.2 
 DA-  2 


 % 
 Answered 


 in 
 10 
 seconds 


 Billing  F.  9.1 
 B-  3 


 Usage 
 Data 
 Delivery 


 Accuracy 


 F.  9.2 
 B-  5 


 Usage 
 Data 
 Delivery 


 Timeliness 


 F.  9.3 
 B-  4 


 Usage 
 Data 
 Delivery 


 Completeness 


 F.  9.4 
 B-  6 


 Mean 
 Time 
 to 
 Deliver 


 Usage 


 F.  9.5 
 B-  7 


 Recurring 
 Charge 
 Completeness 


 F.  9.6 
 B-  8 


 Non-  Recurring 


 Charge 
 Completeness 


 Change 
 Management  F.  10.1  CM-  1  % 


 Software 
 Release 
 Notices 
 Sent 
 On 
 Time 


 F.  10.2 
 CM-  2 


 Average 
 Software 
 Release 
 Notice 
 Delay 
 Days 


 F.  10.3 
 CM-  3A 


 % 
 Change 


 Management 


 Documentation 


 Sent 
 On 
 Time 


 F.  10.4 
 CM-  3B 


 % 
 Change 


 Management 


 Documentation 


 (Defects, 


 Corrections, 
 etc.  ) 
 Sent 
 On 
 Time 


 F.  10.5 
 CM-  4 


 Average 
 Documentation 


 Release 
 Delay 
 Days 


 F.  10.6 
 CM-  5 


 % 
 CLEC 


 Interface 


 Outages 
 Sent 
 within 


 15 
 Minutes 


 New 
 Business 


 Requests 


 F.  11.1 
 BFR-  1 


 % 
 New 


 Business 


 Requests 
 Processed 


 in 
 30 


 Bus. 


 Days 


 F.  11.2 
 BFR-  2A 


 % 
 Quotes 


 Provided 


 within 
 X 
 Business 


 Days 


 Ordering  F.  12.1 
 O-  1 
 Acknowledgement 


 Message 
 Timeliness 


 F.  12.2 
 O-  2 
 Acknowledgement 


 Message 
 Completeness 


 F-  4 
335
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 RESALE 
 - 
 ORDERING  %  Rejected 


 Service 
 Requests 


 - 
 Mechanized 


 [O-  7] 


 A.  1.1.1 
 Residence/  SC 
 (%) 


 8.77% 
 7.25% 
 8.31% 
 7.40% 


 A.  1.1.2 
 Business/  SC 
 (%) 


 22.28% 
 22.22% 
 16.44% 
 27.47% 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Partially 


 Mechanized 


 [O-  7] 


 A.  1.2.1 
 Residence/  SC 
 (%) 


 13.84% 
 16.77% 
 20.04% 
 27.06% 


 A.  1.2.2 
 Business/  SC 
 (%) 


 35.76% 
 49.40% 
 37.36% 
 46.46% 


 A.  1.2.4 
 PBX/  SC 
 (%) 


 50.00% 
 100.00% 
 100.00% 
 2,3,4 


 A.  1.2.6 
 ISDN/  SC 
 (%) 


 100.00% 


 1 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Non-  Mechanized 


 [O-  7] 


 A.  1.3.1 
 Residence/  SC 
 (%) 


 41.12% 
 41.53% 
 40.00% 
 44.92% 


 A.  1.3.2 
 Business/  SC 
 (%) 


 57.29% 
 43.59% 
 42.11% 
 49.12% 


 A.  1.3.3 
 Desi 
 gn 
 (Specials)/  SC(%) 


 42.50% 
 47.06% 
 25.00% 
 36.84% 


 A.  1.3.4 
 PBX/  SC 
 (%) 


 28.57% 
 42.86% 
 38.46% 
 33.33% 
 1,2,4 


 A.  1.3.5 
 Centrex/  SC 
 (%) 


 62.50% 
 80.00% 
 50.00% 
 40.00% 
 1,2,4 


 A.  1.3.6 
 ISDN/  SC 
 (%) 


 28.57% 
 27.78% 
 0.00% 
 62.50% 
 1,3,4 


 Reject 
 Interval 


 - 
 Mechanized 


 [O-  8] 


 A.  1.4.1 
 Residence/  SC 
 (%) 


 96.14% 
 96.24% 
 95.99% 
 97.02% 


 A.  1.4.2 
 Business/  SC 
 (%) 


 86.67% 
 97.83% 
 91.89% 
 92.19% 


 Reject 
 Interval 


 - 
 Partially 


 Mechanized 


 - 
 10 


 hours 


 [O-  8] 


 A.  1.7.1 
 Residence/  SC 
 (%) 


 92.58% 
 90.77% 
 85.53% 
 93.35% 


 A.  1.7.2 
 Business/  SC 
 (%) 


 89.83% 
 90.36% 
 86.76% 
 93.75% 


 A.  1.7.4 
 PBX/  SC 
 (%) 


 100.00% 
 0.00% 
 100.00% 
 2,3,4 


 A.  1.7.6 
 ISDN/  SC 
 (%) 


 0.00% 


 1 


 Reject 
 Interval 


 - 
 Non-  Mechanized 


 [O-  8] 


 A.  1.8.1 
 Residence/  SC 
 (%) 


 100.00% 
 100.00% 
 96.83% 
 100.00% 


 A.  1.8.2 
 Business/  SC 
 (%) 


 98.18% 
 96.08% 
 96.15% 
 100.00% 


 A.  1.8.3 
 Desi 
 gn 
 (Specials)/  SC(%) 


 94.74% 
 100.00% 
 100.00% 
 100.00% 
 3,4 


 A.  1.8.4 
 PBX/  SC 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 A.  1.8.5 
 Centrex/  SC 
 (%) 


 80.00% 
 100.00% 


 85.71% 
 100.00% 
 1,2,3,4 


 A.  1.8.6 
 ISDN/  SC 
 (%) 


 100.00% 
 100.00% 


 100.00% 
 1,2,4 


 FOC 
 Timeliness 


 - 
 Mechanized 


 [O-  9] 


 A.  1.9.1 
 Residence/  SC 
 (%) 


 99.45% 
 99.52% 
 98.73% 
 99.31% 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 South 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 F-  5 
336
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 South 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 A.  1.9.2 
 Business/  SC(%) 


 100.00% 
 99.34% 
 99.38% 
 99.43% 


 FOC 
 Timeliness 


 - 
 Partially 


 Mechanized 


 - 
 10 


 hours 


 [O-  9] 


 A.  1.12.1 
 Residence/  SC 
 (%) 


 89.91% 
 88.30% 
 82.91% 
 85.81% 


 A.  1.12.2 
 Business/  SC 
 (%) 


 96.58% 
 91.95% 
 92.37% 
 94.33% 


 A.  1.12.4 
 PBX/  SC 
 (%) 


 0.00% 
 0.00% 


 2,3 


 A.  1.12.6 
 ISDN/  SC 
 (%) 


 0.00% 
 2 


 FOC 
 Timeliness 


 - 
 Non-  Mechanized 


 [O-  9] 


 A.  1.13.1 
 Residence/  SC 
 (%) 


 100.00% 
 98.39% 
 100.00% 


 97.01% 


 A.  1.13.2 
 Business/  SC 
 (%) 


 100.00% 
 98.28% 
 100.00% 
 100.00% 


 A.  1.13.3 
 Desi 
 gn 
 (Specials)/  SC(%) 


 87.50% 
 100.00% 


 76.92% 
 100.00% 
 4 


 A.  1.13.4 
 PBX/  SC 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 A.  1.13.5 
 Centrex/  SC 
 (%) 


 100.00% 
 100.00% 
 83.33% 
 100.00% 
 1,2,3,4 


 A.  1.13.6 
 ISDN/  SC 
 (%) 


 100.00% 
 85.71% 
 100.00% 
 100.00% 
 1,3,4 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Mechanized 


 [O-  11] 


 A.  1.14.1.1 
 Residence/  EDI/ 


 SC  (%) 


 99.46% 
 99.00% 
 96.09% 
 99.59% 


 A.  1.14.1.2 
 Residence/  TAG/ 


 SC  (%) 


 99.65% 
 99.72% 
 99.25% 
 99.91% 


 A.  1.14.2.1 
 Business/  EDI/ 
 SC 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 A.  1.14.2.2 
 Business/  TAG/ 


 SC 
 (%) 


 95.19% 
 94.97% 
 88.79% 
 100.00% 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Partially 


 Mechanized 


 [O-  11] 


 A.  1.15.1.1 
 Residence/  EDI/ 


 SC  (%) 


 97.87% 
 96.40% 
 95.37% 
 100.00% 


 A.  1.15.1.2 
 Residence/  TAG/ 


 SC  (%) 


 99.71% 
 99.33% 
 99.95% 
 99.91% 


 A.  1.15.2.1 
 Business/  EDI/ 
 SC 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 A.  1.15.2.2 
 Business/  TAG/ 


 SC 
 (%) 


 100.00% 
 100.00% 
 99.43% 
 100.00% 


 A.  1.15.4.2 
 PBX/  TAG/ 
 SC 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 A.  1.15.6.2 
 ISDN/  TAG/ 
 SC 
 (%) 


 100.00% 


 1 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Non-  Mechanized 


 [O-  11] 


 A.  1.16.1 
 Residence/  SC 
 (%) 


 96.26% 
 94.07% 
 95.33% 
 95.76% 


 A.  1.16.2 
 Business/  SC 
 (%) 


 94.79% 
 97.44% 
 92.98% 
 91.23% 


 A.  1.16.3 
 Desi 
 gn 
 (Specials)/  SC(%) 


 87.50% 
 94.12% 
 80.00% 
 100.00% 


 A.  1.16.4 
 PBX/  SC 
 (%) 


 100.00% 
 100.00% 
 92.31% 
 100.00% 
 1,2,4 


 A.  1.16.5 
 Centrex/  SC 
 (%) 


 87.50% 
 100.00% 
 100.00% 
 100.00% 
 1,2,4 


 A.  1.16.6 
 ISDN/  SC 
 (%) 


 71.43% 
 100.00% 


 83.33% 
 100.00% 
 1,3,4 


 RESALE 
 - 
 PROVISIONING 


 F-  6 
337
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 South 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 Order 
 Completion 


 Interval 
 [P-  4] 


 A.  2.1.1.1.1 
 Residence/<  10 


 circuits/  Dis 
 patch/  SC( 
 days) 


 5.06 
 5.24 
 5.13 
 5.27 
 5.17 
 5.12 
 5.36 
 5.30 


 A.  2.1.1.1.2 
 Residence/<  10 


 circuits/  Non- 
 Dis  patch/ 
 SC( 
 days) 


 0.86 
 0.61 
 0.88 
 0.55 
 0.87 
 0.56 
 0.87 
 0.58 


 A.  2.1.1.2.1 
 Residence/>=  10 


 circuits/  Dis 
 patch/  SC( 
 days) 


 4.94 


 5.64 
 7.00 
 5.33 


 4.57 


 2 


 A.  2.1.2.1.1 
 Business/<  10 
 circuits/  Dis 
 patch/  SC( 
 days) 


 2.59 
 3.70 
 3.16 
 6.50 
 3.67 
 3.79 
 5.82 
 5.20 


 A.  2.1.2.1.2 
 Business/<  10 
 circuits/  Non- 
 Dis  patch/ 
 SC( 
 days) 


 1.05 
 0.70 
 1.21 
 1.16 
 1.20 
 0.93 
 1.07 
 1.25 


 A.  2.1.2.2.1 
 Desi 
 gn 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 KY( 
 days) 


 8.07 


 16.07 
 21.00 
 12.31 


 18.92 


 2 


 A.  2.1.3.1.1 
 Desi 
 gn 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 SC( 
 days) 


 19.70 
 10.33 
 22.86 


 8.67 
 19.63 


 10.14 
 20.00 


 1,2,3 


 A.  2.1.3.1.2 
 Design 
 (Specials)/<  10 


 circuits/  Non- 


 Dis 
 patch/  SC( 


 days) 


 12.68 
 12.00 


 9.64 
 4.00 
 10.07 


 6.00 
 10.42 


 4.00 
 1,2,3,4 


 A.  2.1.4.1.1 
 PBX/<  10 
 circuits/  Dis 


 patch/  SC( 
 days) 


 12.61 
 28.52 


 6.23 
 13.47 


 A.  2.1.4.1.2 
 PBX/<  10 
 circuits/  Non- 


 Dis 
 patch/  SC( 


 days) 


 3.26 
 1.50 
 3.65 
 0.67 
 3.14 
 3.78 
 4.13 
 1.78 
 1,2,3,4 


 A.  2.1.4.2.2 
 PBX/>=  10 
 circuits/  Non- 


 Dis  patch/ 
 SC( 
 days) 


 0.83 
 2.00 
 1.13 


 1.14 
 6.06 


 1 


 A.  2.1.5.1.1 
 Centrex/<  10 
 circuits/  Dis 
 patch/  SC( 
 days) 


 4.52 
 2.00 
 7.26 


 9.16 
 3.00 
 7.87 


 1,3 


 A.  2.1.5.1.2 
 Centrex/<  10 
 circuits/  Non- 
 Dis  patch/ 
 SC( 
 days) 


 2.29 


 1.64 
 3.00 
 1.72 
 2.17 
 1.35 
 2.00 
 2,3,4 


 A.  2.1.5.2.2 
 Centrex/>=  10 
 circuits/  Non- 
 Dis  patch/ 
 SC( 
 days) 


 1.73 


 3.47 
 3.00 
 1.00 
 0.88 


 3 


 A.  2.1.6.1.1 
 ISDN/<  10 
 circuits/  Dis 
 patch/  SC( 
 days) 


 67.98 
 19.20 
 12.00 
 16.26 


 18.72 
 0.33 
 2,4 


 A.  2.1.6.1.2 
 ISDN/<  10 
 circuits/  Non- 


 Dis 
 patch/  SC( 


 days) 


 3.67 
 1.50 
 1.45 
 1.75 
 11.16 


 0.33 
 3.98 
 0.33 
 1,2,3,4 


 A.  2.1.6.2.2 
 ISDN/>=  10 
 circuits/  Non- 


 Dis 
 patch/  SC( 


 days) 


 2.29 


 2.65 
 3.00 
 2.20 


 4.67 


 2 


 % 
 Jeopardies 


 - 
 Mechanized 


 [P-  2] 


 A.  2.4.1 
 Residence/  SC 
 (%) 


 0.42% 
 0.34% 
 0.42% 
 0.24% 
 0.34% 
 0.25% 
 0.33% 
 0.07% 


 A.  2.4.2 
 Business/  SC 
 (%) 


 1.55% 
 0.00% 
 1.67% 
 0.49% 
 1.86% 
 1.22% 
 1.47% 
 0.74% 


 A.  2.4.4 
 PBX/  SC 
 (%) 


 2.50% 
 0.00% 
 6.56% 
 0.00% 
 7.53% 


 0.00% 
 0.00% 
 1,2,4 


 A.  2.4.5 
 Centrex/  SC 
 (%) 


 0.76% 
 2.39% 
 2.43% 
 0.00% 
 3.34% 


 3 


 A.  2.4.6 
 ISDN/  SC 
 (%) 


 9.35% 
 0.00% 
 7.82% 
 0.00% 
 11.81% 


 0.00% 
 10.98% 


 0.00% 
 1,2,3,4 


 % 
 Jeopardies 


 - 
 Non-  Mechanized 


 [P-  2] 


 A.  2.5.1 
 Residence/  SC 
 (%) 


 0.00% 
 0.66% 
 0.62% 
 0.47% 


 A.  2.5.2 
 Business/  SC 
 (%) 


 1.28% 
 0.89% 
 0.00% 
 0.00% 


 A.  2.5.3 
 Desi 
 gn 
 (Specials)/  SC(%) 


 36.84% 
 23.08% 
 0.00% 
 0.00% 
 4 


 A.  2.5.4 
 PBX/  SC 
 (%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3,4 


 A.  2.5.5 
 Centrex/  SC 
 (%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1,2,4 


 A.  2.5.6 
 ISDN/  SC 
 (%) 


 0.00% 
 10.00% 


 0.00% 
 0.00% 
 1,3,4 


 Average 
 Jeopardy 


 Notice 
 Interval 


 - 
 Mechanized 


 [P-  2] 


 F-  7 
338
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 South 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 A.  2.7.1 
 Residence/  SC( 
 hours) 


 137.03 
 142.70 
 143.68 
 166.30 
 4 


 A.  2.7.2 
 Business/  SC 
 (hours) 


 142.45 
 146.69 
 149.68 
 2,3,4 


 Average 
 Jeopardy 


 Notice 
 Interval 


 - 
 Non-  Mechanized 


 [P-  2] 


 A.  2.8.1 
 Residence/  SC 
 (hours) 


 126.92 
 61.85 
 168.48 
 2,3,4 


 A.  2.8.2 
 Business/  SC 
 (hours) 


 132.45 
 367.53 


 1,2 


 A.  2.8.3 
 Desi 
 gn 
 (Specials)/  SC( 


 hours) 


 466.35 
 345.48 


 1,2 


 A.  2.8.6 
 ISDN/  SC 
 (hours) 


 324.12 
 2 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Mechanized 


 [P-  2] 


 A.  2.9.1 
 Residence/  SC 
 (%) 


 96.88% 
 100.00% 
 100.00% 
 100.00% 
 4 


 A.  2.9.2 
 Business/  SC 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Non-  Mechanized 


 [P-  2] 


 A.  2.10.1 
 Residence/  SC 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 A.  2.10.2 
 Business/  SC 
 (%) 


 100.00% 
 100.00% 


 1,2 


 A.  2.10.3 
 Desi 
 gn 
 (Specials)/  SC(%) 


 100.00% 
 100.00% 


 1,2 


 A.  2.10.6 
 ISDN/  SC 
 (%) 


 100.00% 
 2 


 % 
 Missed 


 Installation 


 Appointments 


 [P-  3] 


 A.  2.11.1.1.1 
 Residence/<  10 


 circuits/  Dis 
 patch/  SC(%) 


 6.16% 
 0.47% 
 6.45% 
 0.60% 
 7.66% 
 0.23% 
 8.66% 
 1.64% 


 A.  2.11.1.1.2 
 Residence/<  10 


 circuits/  Non- 
 Dis  patch/ 
 SC(%) 


 0.11% 
 0.18% 
 0.01% 
 0.06% 
 0.01% 
 0.12% 
 0.01% 
 0.05% 


 A.  2.11.1.2.1 
 Residence/>=  10 


 circuits/  Dis 
 patch/  SC(%) 


 5.00% 
 23.08% 
 0.00% 
 0.00% 


 0.00% 


 2 


 A.  2.11.2.1.1 
 Business/<  10 
 circuits/  Dis 
 patch/  SC(%) 


 2.12% 
 1.75% 
 2.22% 
 2.70% 
 3.38% 
 0.81% 
 4.74% 
 1.87% 


 A.  2.11.2.1.2 
 Business/<  10 
 circuits/  Non- 
 Dis  patch/ 
 SC(%) 


 0.01% 
 0.47% 
 0.10% 
 0.41% 
 0.05% 
 0.42% 
 0.04% 
 0.00% 


 A.  2.11.2.2.1 
 Business/>=  10 


 circuits/  Dis 
 patch/  SC(%) 


 2.56% 
 5.26% 
 0.00% 
 11.11% 


 3.57% 


 2 


 A.  2.11.3.1.1 
 Design 
 (Specials)/<  10 


 circuits/  Non- 
 Dispatch/  KY(%) 


 4.86% 
 0.00% 
 4.68% 
 20.00% 


 4.95% 
 0.00% 
 6.20% 


 3 


 A.  2.11.3.1.2 
 Design 
 (Specials)/<  10 


 circuits/  Non- 
 Dispatch/  SC(%) 


 3.09% 
 25.00% 


 0.75% 
 0.00% 
 0.88% 
 0.00% 
 1.83% 
 0.00% 
 1,2,3,4 


 A.  2.11.4.1.1 
 PBX/<  10 
 circuits/  Dis 


 patch/  SC(%) 


 8.11% 
 3.45% 
 0.00% 
 7.69% 
 0.00% 
 10.00% 


 2,3 


 A.  2.11.4.1.2 
 PBX/<  10 
 circuits/  Non- 


 Dis 
 patch/  SC(%) 


 0.00% 
 0.00% 
 3.45% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3,4 


 A.  2.11.4.2.2 
 PBX/>=  10 
 circuits/  Non- 


 Dis 
 patch/  SC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 1,2,3 


 A.  2.11.5.1.1 
 Centrex/<  10 
 circuits/  Dis 
 patch/  SC(%) 


 7.62% 
 0.00% 
 4.41% 


 1.34% 
 0.00% 
 3.23% 


 1,3 


 A.  2.11.5.1.2 
 Centrex/<  10 
 circuits/  Non- 
 Dis  patch/ 
 SC(%) 


 2.78% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 2,3,4 


 A.  2.11.5.2.2 
 Centrex/>=  10 
 circuits/  Non- 
 Dis  patch/ 
 SC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 1,2,3 


 A.  2.11.6.1.1 
 ISDN/<  10 
 circuits/  Dis 
 patch/  SC(%) 


 1.23% 
 2.76% 
 0.00% 
 5.11% 


 1.40% 
 0.00% 


 2,4 


 F-  8 
339
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 South 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 A.  2.11.6.1.2 
 ISDN/<  10 
 circuits/  Non- 


 Dispatch/  SC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 13.70% 


 0.00% 
 0.00% 
 0.00% 
 1,2,3,4 


 A.  2.11.6.2.2 
 ISDN/>=  10 
 circuits/  Non- 


 Dis 
 patch/  SC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 


 0.00% 


 2 


 % 
 Provisioning 


 Troubles 
 within 
 30 
 Days 


 [P-  9] 


 A.  2.12.1.1.1 
 Residence/<  10 


 circuits/  Dis 
 patch/  SC(%) 


 10.43% 
 7.68% 
 10.11% 


 8.12% 
 11.60% 


 8.43% 
 11.45% 


 5.99% 


 A.  2.12.1.1.2 
 Residence/<  10 


 circuits/  Non- 
 Dis  patch/ 
 SC(%) 


 2.80% 
 4.08% 
 2.66% 
 2.86% 
 2.74% 
 2.59% 
 2.67% 
 2.69% 


 A.  2.12.1.2.1 
 Residence/>=  10 


 circuits/  Dis 
 patch/  SC(%) 


 18.18% 
 0.00% 
 15.00% 


 7.69% 
 0.00% 
 44.44% 


 1,3 


 A.  2.12.2.1.1 
 Business/<  10 
 circuits/  Dis 
 patch/  SC(%) 


 8.37% 
 7.02% 
 9.34% 
 6.14% 
 10.83% 


 5.41% 
 11.68% 


 4.07% 


 A.  2.12.2.1.2 
 Business/<  10 
 circuits/  Non- 
 Dis  patch/ 
 SC(%) 


 4.74% 
 5.26% 
 5.32% 
 5.21% 
 5.58% 
 9.05% 
 5.99% 
 4.64% 


 A.  2.12.2.2.1 
 Business/>=  10 


 circuits/  Dis 
 patch/  SC(%) 


 37.50% 
 12.82% 
 26.32% 
 50.00% 
 33.33% 


 3 


 A.  2.12.3.1.1 
 Desi 
 gn 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 SC(%) 
 3.64% 
 12.50% 


 5.38% 
 6.67% 
 7.36% 
 0.00% 
 5.72% 
 0.00% 


 1,4 


 A.  2.12.3.1.2 
 Design 
 (Specials)/<  10 


 circuits/  Non- 
 Dispatch/  KY(%) 


 4.27% 
 0.00% 
 6.19% 
 0.00% 
 4.48% 
 0.00% 
 6.19% 
 0.00% 
 1,2,3,4 


 A.  2.12.4.1.1 
 PBX/<  10 
 circuits/  Dis 


 patch/  SC(%) 


 12.50% 
 0.00% 
 2.70% 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1,3,4 


 A.  2.12.4.1.2 
 PBX/<  10 
 circuits/  Non- 


 Dis 
 patch/  SC(%) 


 1.85% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 2.08% 
 0.00% 
 1,2,3,4 


 A.  2.12.4.2.2 
 PBX/>=  10 
 circuits/  Non- 


 Dis 
 patch/  SC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 42.86% 


 0.00% 
 1,2,3,4 


 A.  2.12.5.1.1 
 Centrex/<  10 
 circuits/  Dis 
 patch/  SC(%) 


 9.59% 
 5.24% 
 0.00% 
 11.89% 


 12.05% 
 0.00% 
 2,4 


 A.  2.12.5.1.2 
 Centrex/<  10 
 circuits/  Non- 
 Dis  patch/ 
 SC(%) 


 6.66% 
 0.00% 
 3.25% 


 7.21% 
 33.33% 


 4.76% 
 11.11% 


 1,3,4 


 A.  2.12.5.2.2 
 Centrex/>=  10 
 circuits/  Non- 
 Dis  patch/ 
 SC(%) 


 8.33% 
 0.00% 
 17.07% 


 0.00% 
 18.31% 


 0.00% 
 10.53% 


 0.00% 
 1,2,3,4 


 A.  2.12.6.1.1 
 ISDN/<  10 
 circuits/  Dis 
 patch/  SC(%) 


 4.82% 
 0.00% 
 6.13% 


 5.52% 
 0.00% 
 7.30% 


 1,3 


 A.  2.12.6.1.2 
 ISDN/<  10 
 circuits/  Non- 


 Dis 
 patch/  SC(%) 


 0.38% 
 0.00% 
 1.38% 
 0.00% 
 0.00% 
 0.00% 
 3.42% 
 0.00% 
 1,2,3,4 


 A.  2.12.6.2.2 
 ISDN/>=  10 
 circuits/  Non- 


 Dis 
 patch/  SC(%) 


 2.56% 
 0.00% 
 0.00% 
 0.00% 
 2.27% 


 3 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Mechanized 


 [P-  5] 


 A.  2.14.1.1.1 
 Residence/<  10 


 circuits/  Dis 
 patch/  SC( 
 hours) 


 1.01 
 0.08 
 1.10 
 0.10 
 0.73 
 0.13 
 1.19 
 0.17 


 A.  2.14.1.1.2 
 Residence/<  10 


 circuits/  Non- 
 Dis  patch/ 
 SC( 
 hours) 


 0.50 
 0.52 
 0.51 
 0.57 
 0.57 
 0.57 
 0.51 
 0.55 


 A.  2.14.1.2.1 
 Residence/>=  10 


 circuits/  Dis 
 patch/  SC( 
 hours) 


 0.30 


 0.06 
 0.02 
 0.03 


 0.09 


 2 


 A.  2.14.2.1.1 
 Business/<  10 
 circuits/  Dis 
 patch/  SC( 
 hours) 


 1.33 
 0.45 
 2.14 
 0.03 
 2.63 
 0.55 
 2.56 
 0.53 


 A.  2.14.2.1.2 
 Business/<  10 
 circuits/  Non- 
 Dis  patch/ 
 SC( 
 hours) 


 2.19 
 0.42 
 3.64 
 0.44 
 3.02 
 0.45 
 1.58 
 0.53 


 A.  2.14.4.1.2 
 PBX/<  10 
 circuits/  Non- 


 Dis  patch/ 
 SC( 
 hours) 


 22.82 
 0.02 
 20.34 


 0.14 
 1.56 


 5.47 
 0.02 
 1,2,4 


 A.  2.14.5.1.2 
 Centrex/<  10 
 circuits/  Non- 
 Dis  patch/ 
 SC( 
 hours) 


 3.06 


 2.81 
 1.94 
 0.35 
 2.35 


 3 


 A.  2.14.6.1.1 
 ISDN/<  10 
 circuits/  Dis 
 patch/  SC( 
 hours) 


 1555.78 
 219.63 
 126.22 
 185.26 
 0.02 
 4 


 A.  2.14.6.1.2 
 ISDN/<  10 
 circuits/  Non- 


 Dis 
 patch/  SC( 


 hours) 


 27.20 
 0.25 
 5.68 
 0.02 
 38.21 


 0.02 
 16.48 


 1,2,3 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Non-  Mechanized 


 [P-  5] 


 A.  2.15.1.1.1 
 Residence/<  10 


 circuits/  Dis 
 patch/  SC( 
 hours) 


 15.56 
 15.19 
 19.39 
 17.56 


 F-  9 
340
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 South 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 A.  2.15.1.1.2 
 Residence/<  10 


 circuits/  Non- 
 Dispatch/  SC( 
 hours) 


 7.28 
 11.85 


 9.08 
 7.68 


 A.  2.15.2.1.1 
 Business/<  10 
 circuits/  Dis 
 patch/  SC( 
 hours) 


 26.30 
 26.20 
 31.27 
 29.22 


 A.  2.15.2.1.2 
 Business/<  10 
 circuits/  Non- 
 Dis  patch/ 
 SC( 
 hours) 


 10.93 
 15.75 
 10.41 


 7.89 


 A.  2.15.2.2.1 
 Business/>=  10 


 circuits/  Dis 
 patch/  SC( 
 hours) 


 28.82 


 2 


 A.  2.15.3.1.1 
 Design 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 SC(  hours) 


 85.47 
 155.32 


 60.96 


 3 


 A.  2.15.3.1.2 
 Design 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 KY(  hours) 


 118.85 
 58.22 
 15.71 
 135.97 
 1,2,3,4 


 A.  2.15.4.1.1 
 PBX/<  10 
 circuits/  Dis 


 patch/  SC( 
 hours) 


 103.27 
 20.52 


 2,3 


 A.  2.15.4.1.2 
 PBX/<  10 
 circuits/  Non- 


 Dis 
 patch/  SC( 


 hours) 


 14.00 


 22.68 
 14.66 
 1,3,4 


 A.  2.15.4.2.2 
 PBX/>=  10 
 circuits/  Non- 


 Dis 
 patch/  SC( 


 hours) 


 14.00 
 72.93 
 14.00 


 1,2,3 


 A.  2.15.5.1.1 
 Centrex/<  10 
 circuits/  Dis 
 patch/  SC( 
 hours) 


 15.90 


 41.23 
 1,3 


 A.  2.15.5.1.2 
 Centrex/<  10 
 circuits/  Non- 
 Dis  patch/ 
 SC( 
 hours) 


 9.34 
 19.20 


 9.52 
 2,3,4 


 A.  2.15.5.2.2 
 Centrex/>=  10 
 circuits/  Non- 
 Dis  patch/ 
 SC( 
 hours) 


 7.12 
 7.01 
 14.00 


 1,2,3 


 A.  2.15.6.1.1 
 ISDN/<  10 
 circuits/  Dis 
 patch/  SC( 
 hours) 


 106.65 
 2 


 A.  2.15.6.1.2 
 ISDN/<  10 
 circuits/  Non- 


 Dis 
 patch/  SC( 


 hours) 


 16.00 
 23.20 
 13.42 


 0.02 
 1,2,3,4 


 A.  2.15.6.2.2 
 ISDN/>=  10 
 circuits/  Non- 


 Dis 
 patch/  SC( 


 hours) 


 7.92 


 2 


 Service 
 Order 
 Accuracy 


 [P-  11] 


 A.  2.25.1.1.1 
 Residence/<  10 


 circuits/  Dis 
 patch/  SC(%) 


 92.14% 
 96.55% 
 90.77% 
 98.86% 


 A.  2.25.1.1.2 
 Residence/<  10 


 circuits/  Non- 
 Dis  patch/ 
 SC(%) 


 95.38% 
 94.29% 
 98.82% 
 98.56% 


 A.  2.25.1.2.1 
 Residence/>=  10 


 circuits/  Dis 
 patch/  SC(%) 


 100.00% 
 88.24% 
 100.00% 
 100.00% 
 4 


 A.  2.25.2.1.1 
 Business/<  10 
 circuits/  Dis 
 patch/  SC(%) 


 91.33% 
 95.76% 
 88.82% 
 94.44% 


 A.  2.25.2.1.2 
 Business/<  10 
 circuits/  Non- 
 Dis  patch/ 
 SC(%) 


 93.85% 
 97.93% 
 96.11% 
 97.22% 


 A.  2.25.2.2.1 
 Business/>=  10 


 circuits/  Dis 
 patch/  SC(%) 


 100.00% 
 77.78% 
 77.78% 
 76.92% 
 2 


 A.  2.25.2.2.2 
 Business/>=  10 


 circuits/  Non- 
 Dis  patch/ 
 SC(%) 


 84.62% 
 97.56% 
 92.59% 
 91.89% 


 A.  2.25.3.1.1 
 Desi 
 gn 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 SC(%) 


 81.08% 
 91.43% 
 80.49% 
 96.47% 


 A.  2.25.3.1.2 
 Design 
 (Specials)/<  10 


 circuits/  Non- 
 Dispatch/  SC(%) 


 91.84% 
 94.78% 
 91.43% 
 91.36% 


 A.  2.25.3.2.1 
 Design 
 (Specials)/<  10 


 circuits/  Non- 
 Dispatch/  KY(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 A.  2.25.3.2.2 
 Design 
 (Specials)/>=  10 


 circuits/  Non- 
 Dispatch/  SC(%) 


 100.00% 
 90.00% 
 92.31% 
 88.89% 
 1,4 


 RESALE 
 - 
 MAINTENANCE 


 AND 
 REPAIR 


 Missed 
 Repair 
 Appointments 


 [M&  R- 
 1] 


 F-  10 
341
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 South 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 A.  3.1.1.1 
 Residence/  Dispatch/ 


 SC(%) 


 4.49% 
 0.57% 
 4.48% 
 0.00% 
 5.95% 
 0.00% 
 6.40% 
 0.45% 


 A.  3.1.1.2 
 Residence/  Non- 


 Dis  patch/ 
 SC(%) 


 0.62% 
 0.00% 
 1.00% 
 0.91% 
 0.67% 
 0.00% 
 1.23% 
 0.62% 


 A.  3.1.2.1 
 Business/  Dis 
 patch/  SC(%) 


 6.51% 
 1.45% 
 7.99% 
 0.00% 
 8.79% 
 2.70% 
 10.06% 


 0.00% 


 A.  3.1.2.2 
 Business/  Non- 


 Dis 
 patch/  SC(%) 


 1.79% 
 3.03% 
 1.68% 
 0.00% 
 1.50% 
 0.00% 
 1.43% 
 0.00% 


 A.  3.1.3.1 
 Desi 
 gn 
 (Specials)/  Dispatch/ 


 SC(%) 


 1.09% 
 0.00% 
 0.49% 
 16.67% 


 0.77% 
 0.00% 
 1.40% 
 0.00% 


 1,2 


 A.  3.1.3.2 
 Desi 
 gn 
 (Specials)/  Non- 


 Dispatch/  SC(%) 


 0.00% 
 0.00% 
 0.40% 
 0.00% 
 0.65% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3,4 


 A.  3.1.4.1 
 PBX/  Dis 
 patch/  SC(%) 


 6.25% 
 0.00% 
 4.88% 
 0.00% 
 6.31% 
 0.00% 
 5.33% 
 0.00% 
 1,3,4 


 A.  3.1.4.2 
 PBX/  Non- 
 Dis 
 patch/  SC(%) 


 6.49% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1.20% 
 0.00% 


 1,3 


 A.  3.1.5.1 
 Centrex/  Dis 
 patch/  SC(%) 


 8.65% 
 0.00% 
 12.50% 


 0.00% 
 11.51% 


 0.00% 
 11.55% 


 0.00% 
 2,4 


 A.  3.1.5.2 
 Centrex/  Non- 
 Dis 
 patch/  SC(%) 


 1.34% 
 0.00% 
 1.40% 
 0.00% 
 1.90% 
 0.00% 
 1.36% 
 0.00% 


 2,4 


 A.  3.1.6.1 
 ISDN/  Dis 
 patch/  SC(%) 


 2.22% 
 0.00% 
 4.41% 
 0.00% 
 0.00% 
 0.00% 
 1.64% 
 0.00% 
 1,3,4 


 A.  3.1.6.2 
 ISDN/  Non- 
 Dis 
 patch/  SC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.92% 
 0.00% 


 3,4 


 Customer 
 Trouble 
 Report 
 Rate 
 [M&  R- 


 2] 


 A.  3.2.1.1 
 Residence/  Dis 
 patch/  SC(%) 


 1.72% 
 1.42% 
 1.97% 
 1.37% 
 2.12% 
 1.75% 
 2.08% 
 1.76% 


 A.  3.2.1.2 
 Residence/  Non- 


 Dis  patch/ 
 SC(%) 


 0.92% 
 0.36% 
 0.88% 
 0.23% 
 1.02% 
 0.36% 
 0.99% 
 0.42% 


 A.  3.2.2.1 
 Business/  Dis 
 patch/  SC(%) 


 1.14% 
 1.02% 
 1.22% 
 1.18% 
 1.37% 
 1.22% 
 1.30% 
 1.74% 


 A.  3.2.2.2 
 Business/  Non- 


 Dis 
 patch/  SC(%) 


 0.54% 
 0.49% 
 0.55% 
 0.38% 
 0.60% 
 0.30% 
 0.63% 
 0.47% 


 A.  3.2.3.1 
 Desi 
 gn 
 (Specials)/  Dispatch/ 


 SC(%) 


 1.30% 
 0.98% 
 1.45% 
 0.86% 
 1.88% 
 2.08% 
 1.56% 
 1.81% 


 A.  3.2.3.2 
 Desi 
 gn 
 (Specials)/  Non- 


 Dispatch/  SC(%) 


 1.84% 
 1.12% 
 1.78% 
 0.71% 
 2.22% 
 0.89% 
 2.19% 
 1.36% 


 A.  3.2.4.1 
 PBX/  Dis 
 patch/  SC(%) 


 0.11% 
 0.92% 
 0.19% 
 1.74% 
 0.26% 
 0.36% 
 0.18% 
 0.36% 


 A.  3.2.4.2 
 PBX/  Non- 
 Dis 
 patch/  SC(%) 


 0.18% 
 0.39% 
 0.15% 
 0.00% 
 0.23% 
 0.18% 
 0.19% 
 0.00% 


 A.  3.2.5.1 
 Centrex/  Dis 
 patch/  SC(%) 


 0.45% 
 5.85% 
 0.53% 
 0.27% 
 0.57% 
 1.15% 
 0.49% 
 0.66% 


 A.  3.2.5.2 
 Centrex/  Non- 
 Dis 
 patch/  SC(%) 


 0.46% 
 1.78% 
 0.52% 
 0.53% 
 0.45% 
 0.00% 
 0.45% 
 0.11% 


 A.  3.2.6.1 
 ISDN/  Dis 
 patch/  SC(%) 


 0.04% 
 0.24% 
 0.06% 
 0.00% 
 0.06% 
 0.23% 
 0.06% 
 0.35% 


 A.  3.2.6.2 
 ISDN/  Non- 
 Dis 
 patch/  SC(%) 


 0.09% 
 0.00% 
 0.10% 
 0.00% 
 0.11% 
 0.23% 
 0.11% 
 0.12% 


 Maintenance 
 Average 
 Duration 


 [M&  R- 
 3] 


 A.  3.3.1.1 
 Residence/  Dis 
 patch/  SC( 
 hours) 


 18.59 
 14.52 
 20.08 
 14.54 
 23.10 
 17.17 
 24.09 
 16.43 


 A.  3.3.1.2 
 Residence/  Non- 


 Dis  patch/ 
 SC( 
 hours) 


 6.35 
 3.97 
 6.56 
 4.56 
 8.14 
 3.17 
 8.29 
 6.48 


 A.  3.3.2.1 
 Business/  Dis 
 patch/  SC( 
 hours) 


 11.90 
 9.19 
 12.75 


 10.48 
 13.43 
 10.58 
 14.87 
 14.39 


 A.  3.3.2.2 
 Business/  Non- 


 Dis 
 patch/  SC( 


 hours) 


 3.40 
 4.13 
 3.56 
 1.64 
 3.65 
 6.22 
 3.76 
 10.41 


 A.  3.3.3.1 
 Desi 
 gn 
 (Specials)/  Dispatch/ 


 SC( 
 hours) 


 4.90 
 3.64 
 5.04 
 7.26 
 5.06 
 2.65 
 5.40 
 3.44 
 1,2 


 A.  3.3.3.2 
 Desi 
 gn 
 (Specials)/  Non- 


 Dispatch/  SC( 
 hours) 


 1.96 
 1.76 
 2.39 
 1.54 
 2.24 
 2.27 
 1.84 
 2.59 
 1,2,3,4 


 A.  3.3.4.1 
 PBX/  Dis 
 patch/  SC( 


 hours) 


 9.57 
 10.53 


 7.21 
 18.36 


 10.50 
 16.00 
 14.87 


 8.83 
 1,3,4 


 A.  3.3.4.2 
 PBX/  Non- 
 Dis 
 patch/  SC( 


 hours) 


 4.96 
 5.39 
 2.45 
 0.00 
 2.20 
 5.88 
 3.11 
 0.00 
 1,3 


 F-  11 
342
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 South 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 A.  3.3.5.1 
 Centrex/  Dispatch/ 


 SC( 
 hours) 


 12.26 
 8.75 
 16.75 


 4.33 
 15.08 


 15.64 
 17.97 
 18.50 
 2,4 


 A.  3.3.5.2 
 Centrex/  Non- 
 Dis 
 patch/  SC( 


 hours) 


 2.32 
 5.16 
 2.55 
 2.00 
 3.08 
 0.00 
 2.62 
 1.00 
 2,4 


 A.  3.3.6.1 
 ISDN/  Dis 
 patch/  SC( 
 hours) 


 5.20 
 5.71 
 6.53 
 0.00 
 5.03 
 2.43 
 6.19 
 3.58 
 1,3,4 


 A.  3.3.6.2 
 ISDN/  Non- 
 Dis 
 patch/  SC( 


 hours) 


 1.92 
 0.00 
 1.74 
 0.00 
 2.09 
 1.70 
 1.61 
 16.55 


 3,4 


 % 
 Repeat 


 Troubles 


 within 
 30 
 Days 


 [M&  R- 


 4] 


 A.  3.4.1.1 
 Residence/  Dis 
 patch/  SC(%) 


 16.27% 
 10.57% 
 15.79% 
 7.80% 
 16.60% 


 8.97% 
 16.41% 
 11.14% 


 A.  3.4.1.2 
 Residence/  Non- 


 Dis  patch/ 
 SC(%) 


 14.57% 
 12.85% 
 14.39% 
 6.36% 
 14.70% 


 9.93% 
 14.65% 


 8.02% 


 A.  3.4.2.1 
 Business/  Dis 
 patch/  SC(%) 


 13.19% 
 2.90% 
 12.85% 


 7.79% 
 13.77% 


 9.46% 
 14.90% 
 17.00% 


 A.  3.4.2.2 
 Business/  Non- 


 Dis 
 patch/  SC(%) 


 11.21% 
 21.21% 
 12.23% 
 12.00% 
 12.74% 
 5.56% 
 13.08% 
 25.93% 


 A.  3.4.3.1 
 Desi 
 gn 
 (Specials)/  Dispatch/ 


 SC(%) 


 17.49% 
 0.00% 
 20.25% 
 16.67% 
 18.08% 
 7.14% 
 21.63% 
 25.00% 


 1,2 


 A.  3.4.3.2 
 Desi 
 gn 
 (Specials)/  Non- 


 Dispatch/  SC(%) 


 17.53% 
 0.00% 
 14.23% 


 0.00% 
 17.37% 
 16.67% 
 20.03% 
 22.22% 
 1,2,3,4 


 A.  3.4.4.1 
 PBX/  Dis 
 patch/  SC(%) 


 4.17% 
 28.57% 


 4.88% 
 9.09% 
 18.92% 


 0.00% 
 13.33% 


 0.00% 
 1,3,4 


 A.  3.4.4.2 
 PBX/  Non- 
 Dis 
 patch/  SC(%) 


 9.09% 
 0.00% 
 9.38% 
 0.00% 
 20.79% 


 0.00% 
 8.43% 
 0.00% 


 1,3 


 A.  3.4.5.1 
 Centrex/  Dis 
 patch/  SC(%) 


 12.16% 
 33.33% 
 14.12% 
 0.00% 
 18.55% 


 9.09% 
 13.51% 


 0.00% 
 2,4 


 A.  3.4.5.2 
 Centrex/  Non- 
 Dis 
 patch/  SC(%) 


 11.76% 
 4.76% 
 14.88% 
 83.33% 
 12.20% 
 0.00% 
 7.05% 
 0.00% 


 2,4 


 A.  3.4.6.1 
 ISDN/  Dis 
 patch/  SC(%) 


 13.33% 
 0.00% 
 25.00% 


 0.00% 
 17.74% 
 50.00% 
 18.03% 
 0.00% 
 1,3,4 


 A.  3.4.6.2 
 ISDN/  Non- 
 Dis 
 patch/  SC(%) 


 16.84% 
 0.00% 
 14.68% 


 0.00% 
 14.29% 


 0.00% 
 11.93% 


 0.00% 
 3,4 


 Out 
 of 
 Service 


 > 
 24 


 hours 


 [M&  R- 


 5] 


 A.  3.5.1.1 
 Residence/  Dis 
 patch/  SC(%) 


 16.62% 
 7.88% 
 16.96% 


 8.68% 
 22.51% 
 12.07% 
 23.40% 
 12.52% 


 A.  3.5.1.2 
 Residence/  Non- 


 Dis  patch/ 
 SC(%) 


 6.97% 
 3.66% 
 7.47% 
 6.38% 
 8.94% 
 1.61% 
 10.61% 


 5.26% 


 A.  3.5.2.1 
 Business/  Dis 
 patch/  SC(%) 


 7.16% 
 0.00% 
 7.93% 
 2.08% 
 7.42% 
 7.14% 
 10.08% 


 5.00% 


 A.  3.5.2.2 
 Business/  Non- 


 Dis 
 patch/  SC(%) 


 2.08% 
 0.00% 
 3.09% 
 0.00% 
 2.75% 
 0.00% 
 2.93% 
 0.00% 
 1,3,4 


 A.  3.5.3.1 
 Desi 
 gn 
 (Specials)/  Dispatch/ 


 SC(%) 


 1.09% 
 0.00% 
 0.49% 
 16.67% 


 0.77% 
 0.00% 
 1.40% 
 0.00% 


 1,2 


 A.  3.5.3.2 
 Desi 
 gn 
 (Specials)/  Non- 


 Dispatch/  SC(%) 


 0.00% 
 0.00% 
 0.40% 
 0.00% 
 0.65% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3,4 


 A.  3.5.4.1 
 PBX/  Dis 
 patch/  SC(%) 


 0.00% 
 0.00% 
 1.54% 
 0.00% 
 9.09% 
 0.00% 
 10.00% 


 0.00% 
 1,2,3,4 


 A.  3.5.4.2 
 PBX/  Non- 
 Dis 
 patch/  SC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1.72% 
 0.00% 


 1,3 


 A.  3.5.5.1 
 Centrex/  Dis 
 patch/  SC(%) 


 5.12% 
 2.08% 
 15.90% 


 0.00% 
 11.78% 


 0.00% 
 14.80% 


 0.00% 
 2,3,4 


 A.  3.5.5.2 
 Centrex/  Non- 
 Dis 
 patch/  SC(%) 


 0.74% 
 0.00% 
 2.35% 
 0.00% 
 1.80% 
 0.00% 
 0.65% 
 0.00% 


 2,4 


 A.  3.5.6.1 
 ISDN/  Dis 
 patch/  SC(%) 


 2.22% 
 0.00% 
 4.41% 
 0.00% 
 0.00% 
 0.00% 
 1.64% 
 0.00% 
 1,3,4 


 A.  3.5.6.2 
 ISDN/  Non- 
 Dis 
 patch/  SC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.97% 
 0.00% 


 3,4 


 RESALE 
 - 
 BILLING  Invoice  Accuracy 


 [B-  1] 


 A.  4.1 
 SC 
 (%) 


 98.49% 
 99.46% 
 98.65% 
 99.83% 
 98.76% 
 99.85% 
 98.73% 
 98.18% 


 F-  12 
343
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 South 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 Mean 
 Time 
 to 
 Deliver 


 Invoices 


 - 
 CRIS 


 [B-  2] 


 A.  4.2 
 Re 
 gion( 


 business 


 days) 


 3.68 
 3.56 
 3.86 
 3.27 
 3.47 
 3.16 
 3.82 
 3.37 


 UNBUNDLED 
 NETWORK 
 ELEMENTS 


 - 
 ORDERING 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Mechanized 


 [O-  7] 


 B.  1.1.3 
 Loo  p 
 + 
 Port 


 Combinations/  SC(%) 


 20.13% 
 15.28% 
 18.12% 
 12.92% 


 B.  1.1.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  SC(%) 


 36.36% 
 0.00% 
 0.00% 
 0.00% 
 2,3,4 


 B.  1.1.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  SC(%) 


 0.00% 
 4 


 B.  1.1.8 
 2W 
 Analo  g 


 Loop 
 Design/  SC(%) 


 88.64% 
 90.00% 
 100.00% 


 89.66% 


 B.  1.1.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 SC(%) 


 0.00% 
 0.00% 


 1,2 


 B.  1.1.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  SC(%) 


 75.00% 
 83.33% 
 57.14% 
 50.00% 
 1,3,4 


 B.  1.1.14 
 Other 
 Desi  gn/ 


 SC(%) 


 85.71% 
 84.38% 
 79.41% 
 80.00% 


 B.  1.1.15 
 Other 
 Non-  Desi 


 gn/  SC(%) 


 25.16% 
 30.10% 
 30.71% 
 26.79% 


 B.  1.1.17 
 LNP 
 Standalone/  SC 


 (%) 


 4.74% 
 4.15% 
 6.91% 
 7.82% 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Partially 


 Mechanized 


 [O-  7] 


 B.  1.2.3 
 Loo  p 
 + 
 Port 


 Combinations/  SC(%) 


 32.86% 
 40.06% 
 35.14% 
 31.06% 


 B.  1.2.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  SC(%) 


 0.00% 


 1 


 B.  1.2.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  SC(%) 


 100.00% 
 3 


 B.  1.2.8 
 2W 
 Analo  g 


 Loop 
 Design/  SC(%) 


 71.43% 
 100.00% 
 100.00% 
 95.00% 
 1,2,3 


 B.  1.2.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 SC(%) 


 66.67% 
 3 


 B.  1.2.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  SC(%) 


 36.00% 
 28.57% 
 39.58% 
 51.43% 


 B.  1.2.14 
 Other 
 Desi  gn/ 


 SC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 3,4 


 B.  1.2.15 
 Other 
 Non-  Desi 


 gn/  SC(%) 


 26.57% 
 15.20% 
 26.80% 
 23.03% 


 B.  1.2.17 
 LNP 
 Standalone/  SC 


 (%) 


 25.90% 
 26.45% 
 26.97% 
 22.22% 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Non-  Mechanized 


 [O-  7] 


 B.  1.3.1 
 Switch 
 Ports/  SC 


 (%) 


 B.  1.3.3 
 Loop 
 + 
 Port 


 Combinations/  SC(%) 


 56.49% 
 48.67% 
 53.15% 
 51.49% 


 B.  1.3.4 
 Combo 
 Other/  SC 


 (%) 


 27.27% 
 27.78% 


 B.  1.3.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  SC(%) 


 23.08% 
 42.86% 
 25.00% 
 100.00% 
 3,4 


 B.  1.3.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  SC(%) 


 29.63% 
 30.30% 
 11.36% 
 19.44% 


 B.  1.3.8 
 2W 
 Analo  g 


 Loop 
 Design/  SC(%) 


 20.59% 
 20.59% 
 30.36% 
 24.42% 


 B.  1.3.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 SC(%) 


 0.00% 
 24.00% 
 31.25% 
 39.29% 
 1 


 B.  1.3.10 
 2W 
 Analo  g 


 Loop 
 w/  INP 


 Design/  SC(%) 


 100.00% 
 4 


 B.  1.3.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  SC(%) 


 0.00% 
 100.00% 


 100.00% 
 1,2,4 


 F-  13 
344
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 South 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  1.3.14 
 Other 
 Design/  SC(%) 


 23.15% 
 24.03% 
 20.90% 
 18.03% 


 B.  1.3.15 
 Other 
 Non-  Desi 


 gn/  SC(%) 


 28.85% 
 34.90% 
 33.92% 
 32.14% 


 B.  1.3.16 
 INP 
 Standalone/  SC 


 (%) 


 25.00% 
 20.00% 
 33.33% 
 15.38% 
 3 


 B.  1.3.17 
 LNP 
 Standalone/  SC 


 (%) 


 22.61% 
 28.21% 
 27.01% 
 22.75% 


 Reject 
 Interval 


 - 
 Mechanized 


 [O-  8] 


 B.  1.4.3 
 Loo  p 
 + 
 Port 


 Combinations/  SC(%) 


 93.87% 
 91.71% 
 94.61% 
 91.62% 


 B.  1.4.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  SC(%) 


 100.00% 


 1 


 B.  1.4.8 
 2W 
 Analo  g 


 Loop 
 Design/  SC(%) 


 94.87% 
 100.00% 
 100.00% 
 92.31% 


 B.  1.4.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  SC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,3,4 


 B.  1.4.14 
 Other 
 Desi  gn/ 


 SC(%) 


 100.00% 
 96.30% 
 81.48% 
 75.00% 
 4 


 B.  1.4.15 
 Other 
 Non-  Desi 


 gn/  SC(%) 


 73.42% 
 80.46% 
 67.83% 
 68.27% 


 B.  1.4.17 
 LNP 
 Standalone/  SC 


 (%) 


 100.00% 
 100.00% 
 100.00% 
 95.65% 


 Reject 
 Interval 


 - 
 Partially 


 Mechanized 


 - 
 10 


 hours 


 [O-  8] 


 B.  1.7.3 
 Loo  p 
 + 
 Port 


 Combinations/  SC(%) 


 96.54% 
 97.42% 
 83.57% 
 96.30% 


 B.  1.7.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  SC(%) 


 100.00% 
 3 


 B.  1.7.8 
 2W 
 Analo  g 


 Loop 
 Design/  SC(%) 


 100.00% 
 100.00% 
 100.00% 
 89.47% 
 1,2,3 


 B.  1.7.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 SC(%) 


 100.00% 
 3 


 B.  1.7.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  SC(%) 


 100.00% 
 100.00% 
 94.74% 
 77.78% 


 B.  1.7.14 
 Other 
 Desi  gn/ 


 SC(%) 


 94.12% 
 100.00% 
 100.00% 
 100.00% 
 3,4 


 B.  1.7.15 
 Other 
 Non-  Desi 


 gn/  SC(%) 


 84.21% 
 100.00% 


 80.77% 
 97.14% 


 B.  1.7.17 
 LNP 
 Standalone/  SC 


 (%) 


 83.78% 
 87.80% 
 82.69% 
 82.22% 


 Reject 
 Interval 


 - 
 Non-  Mechanized 


 [O-  8] 


 B.  1.8.3 
 Loo  p 
 + 
 Port 


 Combinations/  SC(%) 


 100.00% 
 98.18% 
 98.33% 
 97.22% 


 B.  1.8.4 
 Combo 
 Other/  SC 


 (%) 


 100.00% 
 100.00% 
 3 


 B.  1.8.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  SC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 B.  1.8.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  SC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 3,4 


 B.  1.8.8 
 2W 
 Analo  g 


 Loop 
 Design/  SC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2 


 B.  1.8.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 SC(%) 


 100.00% 
 100.00% 
 100.00% 


 B.  1.8.10 
 2W 
 Analo  g 


 Loop 
 w/  INP 


 Design/  SC(%) 


 100.00% 
 4 


 B.  1.8.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  SC(%) 


 100.00% 
 100.00% 
 2,4 


 B.  1.8.14 
 Other 
 Desi 
 gn/  SC(%) 


 100.00% 
 100.00% 
 100.00% 
 95.65% 


 B.  1.8.15 
 Other 
 Non-  Desi 


 gn/  SC(%) 


 100.00% 
 98.41% 
 99.39% 
 99.45% 


 B.  1.8.16 
 INP 
 Standalone/  SC 


 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 F-  14 
345
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 South 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  1.8.17 
 LNP 
 Standalone/  SC(%) 


 100.00% 
 97.47% 
 93.55% 
 100.00% 


 FOC 
 Timeliness 


 - 
 Mechanized 


 [O-  9] 


 B.  1.9.3 
 Loo  p 
 + 
 Port 


 Combinations/  SC(%) 


 99.16% 
 98.53% 
 98.39% 
 97.27% 


 B.  1.9.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  SC(%) 


 100.00% 
 100.00% 
 100.00% 


 1,2,3 


 B.  1.9.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  SC(%) 


 100.00% 
 4 


 B.  1.9.8 
 2W 
 Analo  g 


 Loop 
 Design/  SC(%) 


 100.00% 
 100.00% 


 100.00% 
 1,2,4 


 B.  1.9.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 SC(%) 


 100.00% 
 100.00% 


 1,2 


 B.  1.9.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  SC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 B.  1.9.14 
 Other 
 Desi  gn/ 


 SC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 B.  1.9.15 
 Other 
 Non-  Desi 


 gn/  SC(%) 


 84.98% 
 88.59% 
 91.83% 
 87.46% 


 B.  1.9.17 
 LNP 
 Standalone/  SC 


 (%) 


 99.55% 
 97.23% 
 94.83% 
 87.50% 


 FOC 
 Timeliness 


 - 
 Partially 


 Mechanized 


 - 
 10 


 hours 


 [O-  9] 


 B.  1.12.3 
 Loo  p 
 + 
 Port 


 Combinations/  SC(%) 


 92.33% 
 92.77% 
 84.72% 
 89.35% 


 B.  1.12.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  SC(%) 


 100.00% 


 1 


 B.  1.12.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  SC(%) 


 B.  1.12.8 
 2W 
 Analog 


 Loop 
 Design/  SC(%) 


 100.00% 


 1 


 B.  1.12.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 SC(%) 


 100.00% 
 3 


 B.  1.12.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  SC(%) 


 100.00% 
 100.00% 
 96.55% 
 94.74% 


 B.  1.12.15 
 Other 
 Non-  Desi 


 gn/  SC(%) 


 73.27% 
 93.50% 
 77.02% 
 90.91% 


 B.  1.12.17 
 LNP 
 Standalone/  SC 


 (%) 


 91.26% 
 94.74% 
 89.31% 
 87.25% 


 FOC 
 Timeliness 


 - 
 Non-  Mechanized 


 [O-  9] 


 B.  1.13.1 
 Switch 
 Ports/  SC 


 (%) 


 B.  1.13.3 
 Loop 
 + 
 Port 


 Combinations/  SC(%) 


 100.00% 
 100.00% 
 95.16% 
 98.39% 


 B.  1.13.4 
 Combo 
 Other/  SC 


 (%) 


 100.00% 
 100.00% 


 B.  1.13.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  SC(%) 


 100.00% 
 100.00% 
 100.00% 


 2,3 


 B.  1.13.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  SC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  1.13.8 
 2W 
 Analo  g 


 Loop 
 Design/  SC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  1.13.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 SC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1 


 B.  1.13.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  SC(%) 


 100.00% 
 100.00% 


 1,2 


 B.  1.13.14 
 Other 
 Desi  gn/ 


 SC(%) 


 100.00% 
 98.88% 
 98.56% 
 100.00% 


 B.  1.13.15 
 Other 
 Non-  Desi 


 gn/  SC(%) 


 100.00% 
 100.00% 
 99.30% 
 99.46% 


 B.  1.13.16 
 INP 
 Standalone/  SC 


 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,3 


 B.  1.13.17 
 LNP 
 Standalone/  SC 


 (%) 


 98.91% 
 100.00% 
 100.00% 
 100.00% 


 F-  15 
346
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 South 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Mechanized 


 [O-  11] 


 B.  1.14.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  EDI/ 


 SC(%) 


 99.35% 
 100.00% 


 95.46% 
 100.00% 


 B.  1.14.3.2 
 Loo  p 
 + 
 Port 


 Combinations/  TAG/ 


 SC(%) 


 99.29% 
 98.53% 
 98.90% 
 99.89% 


 B.  1.14.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  EDI/ 


 SC(%) 


 63.64% 
 100.00% 
 100.00% 


 0.00% 
 2,3,4 


 B.  1.14.6.1 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  EDI/ 


 SC(%) 


 100.00% 
 4 


 B.  1.14.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  EDI/ 


 SC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  1.14.8.2 
 2W 
 Analo  g 


 Loop 
 Design/  TAG/ 


 SC(%) 


 100.00% 
 100.00% 


 100.00% 
 1,2,4 


 B.  1.14.9.1 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 EDI/  SC(%) 


 100.00% 
 100.00% 


 1,2 


 B.  1.14.12.1 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  EDI/ 


 SC(%) 


 100.00% 
 100.00% 
 100.00% 
 83.33% 
 1,3,4 


 B.  1.14.12.2 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  TAG/ 


 SC(%) 


 B.  1.14.14.1 
 Other 
 Design/  EDI/ 


 SC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 4 


 B.  1.14.14.2 
 Other 
 Desi  gn/ 


 TAG/  SC(%) 


 100.00% 
 77.78% 
 100.00% 
 100.00% 
 1,2,4 


 B.  1.14.15.1 
 Other 
 Non-  Desi 


 gn/  EDI/ 
 SC(%) 


 100.00% 
 100.00% 
 86.36% 
 100.00% 
 1 


 B.  1.14.15.2 
 Other 
 Non-  Desi 


 gn/  TAG/ 
 SC(%) 


 97.37% 
 97.04% 
 96.82% 
 98.85% 


 B.  1.14.17.1 
 LNP 
 Standalone/  EDI/ 


 SC  (%) 


 100.00% 
 96.39% 
 98.55% 
 100.00% 


 B.  1.14.17.2 
 LNP 
 Standalone/  TAG/ 


 SC  (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Partially 


 Mechanized 


 [O-  11] 


 B.  1.15.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  EDI/ 


 SC(%) 


 100.00% 
 100.00% 
 97.81% 
 98.74% 


 B.  1.15.3.2 
 Loo  p 
 + 
 Port 


 Combinations/  TAG/ 


 SC(%) 


 99.90% 
 99.07% 
 99.74% 
 92.63% 


 B.  1.15.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  EDI/ 


 SC(%) 


 100.00% 


 1 


 B.  1.15.6.1 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  EDI/ 


 SC(%) 


 100.00% 
 3 


 B.  1.15.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  EDI/ 


 SC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3 


 B.  1.15.8.2 
 2W 
 Analo  g 


 Loop 
 Design/  TAG/ 


 SC(%) 


 100.00% 
 100.00% 


 2,3 


 B.  1.15.9.1 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 EDI/  SC(%) 


 100.00% 
 3 


 B.  1.15.12.1 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  EDI/ 


 SC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  1.15.12.2 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  TAG/ 


 SC(%) 


 100.00% 
 100.00% 


 1,2 


 B.  1.15.14.1 
 Other 
 Desi  gn/ 


 EDI/  SC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 B.  1.15.14.2 
 Other 
 Desi  gn/ 


 TAG/  SC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,3,4 


 B.  1.15.15.1 
 Other 
 Non-  Desi 


 gn/  EDI/ 
 SC(%) 


 90.91% 
 100.00% 


 93.33% 
 100.00% 
 2 


 B.  1.15.15.2 
 Other 
 Non-  Desi 


 gn/  TAG/ 
 SC(%) 


 96.97% 
 98.15% 
 98.32% 
 97.16% 


 B.  1.15.17.1 
 LNP 
 Standalone/  EDI/ 


 SC  (%) 


 100.00% 
 100.00% 
 99.24% 
 100.00% 


 B.  1.15.17.2 
 LNP 
 Standalone/  TAG/ 


 SC  (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Non-  Mechanized 


 [O-  11] 
 F-  16 
347
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 South 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  1.16.1 
 Switch 
 Ports/  SC(%) 


 B.  1.16.3 
 Loop 
 + 
 Port 


 Combinations/  SC(%) 


 93.13% 
 98.23% 
 99.10% 
 95.52% 


 B.  1.16.4 
 Combo 
 Other/  SC 


 (%) 


 95.45% 
 100.00% 


 B.  1.16.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  SC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 3,4 


 B.  1.16.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  SC(%) 


 100.00% 
 96.97% 
 95.45% 
 100.00% 


 B.  1.16.8 
 2W 
 Analo  g 


 Loop 
 Design/  SC(%) 


 100.00% 
 100.00% 
 80.36% 
 98.84% 


 B.  1.16.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 SC(%) 


 100.00% 
 100.00% 
 80.00% 
 98.21% 
 1 


 B.  1.16.10 
 2W 
 Analo  g 


 Loop 
 w/  INP 


 Design/  SC(%) 


 100.00% 
 4 


 B.  1.16.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  SC(%) 


 100.00% 
 100.00% 


 100.00% 
 1,2,4 


 B.  1.16.14 
 Other 
 Desi  gn/ 


 SC(%) 


 97.22% 
 97.67% 
 96.61% 
 99.18% 


 B.  1.16.15 
 Other 
 Non-  Desi 


 gn/  SC(%) 


 97.31% 
 95.84% 
 93.00% 
 99.43% 


 B.  1.16.16 
 INP 
 Standalone/  SC 


 (%) 


 100.00% 
 100.00% 
 88.89% 
 100.00% 
 3 


 B.  1.16.17 
 LNP 
 Standalone/  SC 


 (%) 


 98.85% 
 98.21% 
 94.31% 
 99.47% 


 UNBUNDLED 
 NETWORK 
 ELEMENTS 


 - 
 PROVISIONING 


 Order 
 Completion 


 Interval 
 [P-  4] 


 B.  2.1.3.1.1 
 Loop 
 + 
 Port 


 Combinations/<  10  circuits/  Dis  patch/  SC(  days) 


 3.94 
 3.20 
 4.38 
 4.01 
 4.69 
 3.11 
 5.54 
 3.70 


 B.  2.1.3.1.2 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Non- 


 Dis 
 patch/  SC( 


 days) 


 0.89 
 0.58 
 0.90 
 0.56 
 0.89 
 0.60 
 0.89 
 0.58 


 B.  2.1.3.1.3 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Switch 
 Based 


 Orders/  SC 
 (days) 


 0.33 
 0.33 
 0.33 
 0.33 
 0.33 
 0.33 
 0.33 
 0.33 


 B.  2.1.3.1.4 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Dispatch 


 In/  SC 
 (days) 


 1.46 
 1.17 
 1.45 
 1.15 
 1.43 
 1.08 
 1.41 
 1.12 


 B.  2.1.3.2.1 
 Loop 
 + 
 Port 


 Combinations/>=  10  circuits/  Dis  patch/  SC(  days) 


 7.88 
 11.53 


 12.51 
 7.00 
 17.32 


 3 


 B.  2.1.3.2.2 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Non- 


 Dis 
 patch/  SC( 


 days) 


 1.83 
 3.18 
 2.44 
 2.00 
 1.97 


 3 


 B.  2.1.3.2.4 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Dispatch 


 In/  SC 
 (days) 


 3.83 
 5.16 
 2.84 
 2.00 
 4.08 


 3 


 B.  2.1.4.1.1 
 Combo 
 Other/<  10 


 circuits/  Dis 
 patch/  SC( 
 days) 


 5.58 
 12.00 


 5.49 
 11.65 


 5.70 
 11.91 


 6.80 
 12.24 


 B.  2.1.6.3.1 
 UNE 
 ISDN/<  6 


 circuits/  Dis 


 patch/  SC( 
 days) 


 15.82 
 9.95 
 16.70 


 10.58 
 15.37 


 9.63 
 16.83 


 10.03 


 B.  2.1.8.1.1 
 2W 
 Analog 


 Loop 
 Design/<  10 


 circuits/  Dis 
 patch/  SC( 
 days) 


 3.94 
 5.00 
 4.38 
 5.05 
 4.69 
 5.25 
 5.54 
 5.16 


 F-  17 
348
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 South 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  2.1.12.1.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/<  10 


 circuits/  Dis 
 patch/  SC( 
 days) 


 3.94 
 5.19 
 4.38 
 5.89 
 4.69 
 5.74 
 5.54 
 5.08 


 B.  2.1.14.1.1 
 Other 
 Desi  gn/< 


 10 
 circuits/  Dispatch/ 


 SC( 
 days) 


 28.47 


 23.03 
 30.00 
 19.11 
 19.00 
 19.76 


 2,3 


 B.  2.1.15.1.2 
 Other 
 Non-  Design/< 


 10 
 circuits/  Non- 


 Dis 
 patch/  SC( 


 days) 


 0.89 
 0.90 
 0.89 
 0.89 


 B.  2.1.16.1.2 
 INP 
 (Standalone)/<  10 


 circuits/  Non- 
 Dispatch/  SC( 
 days) 
 0.87 


 0.90 
 0.88 
 0.89 


 B.  2.1.17.1.1 
 LNP 
 (Standalone)/<  10 


 circuits/  Dispatch/ 
 SC( 
 days) 


 3.94 
 0.33 
 4.32 
 1.17 
 4.61 
 0.89 
 5.49 
 0.33 
 1,2,3,4 


 B.  2.1.17.1.2 
 LNP 
 (Standalone)/<  10 


 circuits/  Non- 
 Dispatch/  SC( 
 days) 
 0.87 


 0.52 
 0.90 
 0.57 
 0.88 
 0.56 
 0.89 
 0.59 


 B.  2.1.17.2.1 
 LNP 
 (Standalone)/>=  10 


 circuits/  Dispatch/ 
 SC(  days) 
 7.07 


 12.24 


 10.41 
 15.68 


 B.  2.1.17.2.2 
 LNP 
 (Standalone)/>=  10 


 circuits/  Non- 


 Dis 
 patch/  SC( 


 days) 


 2.92 
 0.56 
 2.92 
 0.33 
 0.33 
 0.33 
 0.33 
 0.33 
 1,2,3,4 


 B.  2.1.18.1.1 
 Digital 
 Loop 
 < 
 DS1/<  10 


 circuits/  Dispatch/ 


 SC(  days) 
 8.57 
 9.60 
 8.62 
 10.33 


 8.66 
 9.27 
 6.61 
 10.03 


 B.  2.1.19.1.1 
 Digital 
 Loop 
 >= 
 DS1/<  10 


 circuits/  Dispatch/ 


 SC(  days) 
 88.57 
 6.48 
 26.15 


 6.52 
 21.05 


 6.79 
 20.59 


 6.06 


 Order 
 Completion 


 Interval 
 within 
 X 
 days 


 [P-  4] 


 B.  2.2.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL) 


 Loop 
 with 


 Conditionin  g/< 
 6 
 circuits/  Dispatch/ 


 SC( 
 days) 


 5.00 
 3 


 B.  2.2.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL) 


 Loop 
 w/  o 


 Conditionin  g/< 
 6 
 circuits/  Dispatch/ 


 SC( 
 days) 


 5.00 
 4.00 
 5.00 


 1,2,3 


 % 
 Jeopardies 


 - 
 Mechanized 


 [P-  2] 


 B.  2.5.3 
 Loo  p 
 + 
 Port 


 Combinations/  SC(%) 


 0.51% 
 0.31% 
 0.52% 
 0.70% 
 0.46% 
 0.22% 
 0.44% 
 0.12% 


 B.  2.5.4 
 Combo 
 Other/  SC 


 (%) 


 6.96% 
 7.57% 
 7.40% 
 7.80% 


 B.  2.5.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  SC(%) 


 9.91% 
 11.81% 


 8.19% 
 15.14% 


 B.  2.5.6 
 UNE 
 ISDN/  SC 


 (%) 


 12.66% 
 0.00% 
 7.32% 
 0.00% 
 16.05% 


 7.75% 
 100.00% 


 1,2,4 


 B.  2.5.8 
 2W 
 Analo  g 


 Loop 
 Design/  SC(%) 


 0.51% 
 21.43% 


 0.52% 
 12.90% 


 0.46% 
 17.14% 


 0.44% 
 13.73% 


 B.  2.5.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  SC(%) 


 0.51% 
 30.77% 


 0.52% 
 22.22% 


 0.46% 
 11.63% 


 0.44% 
 9.68% 


 B.  2.5.15 
 Other 
 Non-  Desi 


 gn/  SC(%) 


 0.51% 
 0.52% 
 0.46% 
 0.44% 


 B.  2.5.16 
 INP 
 (Standalone)/  SC(%) 


 0.51% 
 0.51% 
 0.44% 
 0.43% 


 B.  2.5.17 
 LNP 
 (Standalone)/  SC(%) 


 0.51% 
 0.00% 
 0.51% 
 0.00% 
 0.44% 
 0.00% 
 0.43% 
 0.00% 


 B.  2.5.18 
 Di 
 gital 


 Loop 


 < 
 DS1/  SC(%) 


 11.84% 
 0.00% 
 12.37% 


 0.00% 
 10.36% 


 15.83% 
 100.00% 


 1,2,4 


 F-  18 
349
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 South 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  2.5.19 
 Digital 
 Loop 
 >= 
 DS1/  SC(%) 


 12.57% 
 79.67% 
 16.77% 
 79.78% 
 12.17% 
 73.45% 
 17.48% 
 67.24% 


 % 
 Jeopardies 


 - 
 Non-  Mechanized 


 [P-  2] 


 B.  2.6.3 
 Loo  p 
 + 
 Port 


 Combinations/  SC(%) 


 0.76% 
 1.44% 
 0.77% 
 1.60% 


 B.  2.6.4 
 Combo 
 Other/  SC 


 (%) 


 78.26% 
 68.75% 
 66.67% 
 60.47% 


 B.  2.6.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  SC(%) 


 16.67% 
 0.00% 
 16.67% 


 1,2,3 


 B.  2.6.6 
 UNE 
 ISDN/  SC 


 (%) 


 34.78% 
 33.33% 
 23.08% 
 12.50% 


 B.  2.6.8 
 2W 
 Analo  g 


 Loop 
 Design/  SC(%) 


 18.18% 
 18.18% 
 50.00% 
 5.88% 
 3 


 B.  2.6.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  SC(%) 


 0.00% 
 0.00% 
 0.00% 


 1,2,3 


 B.  2.6.14 
 Other 
 Desi  gn/ 


 SC(%) 


 0.00% 
 0.00% 


 2,3 


 B.  2.6.17 
 LNP 
 (Standalone)/  SC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 


 B.  2.6.18 
 Di  gital 
 Loop 
 < 
 DS1/  SC(%) 


 32.69% 
 31.25% 
 21.88% 
 12.50% 


 B.  2.6.19 
 Di 
 gital 


 Loop 


 >= 
 DS1/  SC(%) 


 47.83% 
 53.33% 
 43.33% 
 38.46% 


 Average 
 Jeopardy 


 Notice 
 Interval 


 - 
 Mechanized 


 [P-  2] 


 B.  2.8.3 
 Loo  p 
 + 
 Port 


 Combinations/  SC( 


 hours) 


 131.39 
 294.43 
 128.95 
 201.43 
 1,3,4 


 B.  2.8.6 
 UNE 
 ISDN/  SC 


 (hours) 


 362.28 
 4 


 B.  2.8.8 
 2W 
 Analo  g 


 Loop 
 Design/  SC( 


 hours) 


 155.01 
 166.37 
 246.50 
 185.75 
 1,2,3,4 


 B.  2.8.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  SC( 


 hours) 


 187.31 
 231.88 
 181.83 
 241.63 
 2,3,4 


 B.  2.8.18 
 Di 
 gital 


 Loop 


 < 
 DS1/  SC( 


 hours) 


 362.28 
 4 


 B.  2.8.19 
 Di 
 gital 


 Loop 


 >= 
 DS1/  SC( 


 hours) 


 192.27 
 229.75 
 210.87 
 198.18 


 Average 
 Jeopardy 


 Notice 
 Interval 


 - 
 Non-  Mechanized 


 [P-  2] 


 B.  2.9.3 
 Loo  p 
 + 
 Port 


 Combinations/  SC( 


 hours) 


 0.70 
 431.23 


 522.77 
 1,2,4 


 B.  2.9.4 
 Combo 
 Other/  SC 


 (hours) 


 328.28 
 341.45 
 329.92 
 348.29 


 B.  2.9.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  SC( 


 hours) 


 255.68 


 418.60 
 1,3 


 B.  2.9.6 
 UNE 
 ISDN/  SC 


 (hours) 


 324.51 
 303.78 
 277.06 
 323.08 
 3,4 


 B.  2.9.8 
 2W 
 Analo  g 


 Loop 
 Design/  SC( 


 hours) 


 166.56 
 143.33 
 591.63 
 274.88 
 1,2,3,4 


 B.  2.9.18 
 Di 
 gital 


 Loop 


 < 
 DS1/  SC( 


 hours) 


 319.22 
 303.78 
 297.28 
 323.08 
 3,4 


 B.  2.9.19 
 Di 
 gital 


 Loop 


 >= 
 DS1/  SC( 


 hours) 


 203.77 
 170.96 
 200.89 
 256.24 
 2 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Mechanized 


 [P-  2] 


 B.  2.10.3 
 Loo  p 
 + 
 Port 


 Combinations/  SC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,3,4 


 B.  2.10.6 
 UNE 
 ISDN/  SC 


 (%) 


 100.00% 
 4 


 B.  2.10.8 
 2W 
 Analo  g 


 Loop 
 Design/  SC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 B.  2.10.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  SC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 B.  2.10.18 
 Di 
 gital 


 Loop 


 < 
 DS1/  SC(%) 


 100.00% 
 4 


 F-  19 
350
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 South 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  2.10.19 
 Digital 
 Loop 
 >= 
 DS1/  SC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Non-  Mechanized 


 [P-  2] 


 B.  2.11.3 
 Loo  p 
 + 
 Port 


 Combinations/  SC(%) 


 0.00% 
 100.00% 


 100.00% 
 1,2,4 


 B.  2.11.4 
 Combo 
 Other/  SC 


 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  2.11.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  SC(%) 


 100.00% 


 100.00% 
 1,3 


 B.  2.11.6 
 UNE 
 ISDN/  SC 


 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 3,4 


 B.  2.11.8 
 2W 
 Analo  g 


 Loop 
 Design/  SC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 B.  2.11.18 
 Di 
 gital 


 Loop 


 < 
 DS1/  SC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 3,4 


 B.  2.11.19 
 Di 
 gital 


 Loop 


 >= 
 DS1/  SC(%) 


 90.91% 
 100.00% 
 100.00% 
 100.00% 
 2 


 Coordinated 
 Customers 
 Conversions 


 [P-  7] 


 B.  2.12.2 
 Loo  ps 
 with 
 LNP/  SC(%) 


 100.00% 
 100.00% 
 95.45% 
 100.00% 


 % 
 Hot 


 Cuts 


 > 
 15 


 minutes 


 Early 
 [P-  7A] 


 B.  2.13.2 
 Time-  S 
 pecific 
 SL2/  SC(%) 


 0.00% 


 1 


 B.  2.13.4 
 Non-  Time 
 Specific 
 SL2/  SC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 


 Hot 
 Cut 
 Timeliness 


 [P-  7A] 


 B.  2.14.2 
 Time-  S 
 pecific 
 SL2/  SC(%) 


 100.00% 


 1 


 B.  2.14.4 
 Non-  Time 
 Specific 
 SL2/  SC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 % 
 Hot 


 Cuts 


 > 
 15 


 minutes 


 Late 
 [P-  7A] 


 B.  2.15.2 
 Time-  S 
 pecific 
 SL2/  SC(%) 


 0.00% 


 1 


 B.  2.15.4 
 Non-  Time 
 Specific 
 SL2/  SC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 


 Average 
 Recovery 


 Time 
 - 
 CCC 


 [P-  7B] 


 B.  2.16.2 
 Loo  ps 
 with 
 LNP/  SC( 


 minutes) 


 145.88 
 175.00 


 43.00 
 2,3,4 


 % 
 Provisioning 


 Troubles 
 within 
 7 
 Days 


 - 
 Hot 


 Cuts 


 [P-  7C] 


 B.  2.17.1.1 
 UNE 
 Loo 
 p 
 Design/  Dispatch/ 


 SC(%) 


 1.54% 
 2.74% 
 3.60% 
 6.82% 


 % 
 Missed 


 Installation 


 Appointments 


 [P-  3] 


 B.  2.18.3.1.1 
 Loop 
 + 
 Port 


 Combinations/<  10  circuits/  Dis  patch/  SC(%) 


 4.54% 
 0.52% 
 4.86% 
 0.58% 
 6.13% 
 1.17% 
 7.62% 
 1.97% 


 B.  2.18.3.1.2 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Non- 


 Dis 
 patch/  SC(%) 


 0.14% 
 0.16% 
 0.02% 
 0.04% 
 0.01% 
 0.06% 
 0.01% 
 0.02% 


 B.  2.18.3.1.3 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Switch 
 Based 


 Orders/  SC 
 (%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 B.  2.18.3.1.4 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Dispatch 


 In/  SC 
 (%) 


 0.27% 
 0.37% 
 0.03% 
 0.09% 
 0.02% 
 0.11% 
 0.02% 
 0.05% 


 F-  20 
351
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 South 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  2.18.3.2.1 
 Loop 
 + 
 Port 


 Combinations/>=  10  circuits/  Dis  patch/  SC(%) 


 5.56% 
 0.00% 
 9.62% 


 4.76% 
 0.00% 
 4.00% 
 0.00% 
 1,3,4 


 B.  2.18.3.2.2 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Non- 


 Dis 
 patch/  SC(%) 


 0.00% 
 0.00% 
 1.03% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 1,2,3 


 B.  2.18.3.2.4 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Dispatch 


 In/  SC 
 (%) 


 0.00% 
 0.00% 
 1.72% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 1,2,3 


 B.  2.18.4.1.1 
 Combo 
 Other/<  10 


 circuits/  Dis 
 patch/  SC(%) 


 4.53% 
 0.00% 
 4.83% 
 0.00% 
 6.07% 
 0.00% 
 7.44% 
 4.35% 


 B.  2.18.5.1.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/<  10 


 circuits/  Dis 
 patch/  SC(%) 


 1.46% 
 0.00% 
 1.84% 
 0.00% 
 3.02% 
 0.00% 
 3.07% 


 1,2,3 


 B.  2.18.6.1.1 
 UNE 
 ISDN/<  10 


 circuits/  Dis 
 patch/  SC(%) 


 2.56% 
 0.00% 
 3.45% 
 0.00% 
 8.43% 
 0.00% 
 2.53% 
 0.00% 


 B.  2.18.8.1.1 
 2W 
 Analog 


 Loop 
 Design/<  10 


 circuits/  Dispatch/ 


 SC(%) 
 4.54% 


 0.00% 
 4.86% 
 0.00% 
 6.13% 
 0.00% 
 7.62% 
 0.00% 


 B.  2.18.12.1.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/<  10 


 circuits/  Dispatch/ 
 SC(%) 


 4.54% 
 2.56% 
 4.86% 
 0.00% 
 6.13% 
 0.00% 
 7.62% 
 0.00% 


 B.  2.18.12.2.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/>=  10 


 circuits/  Dis 
 patch/  SC(%) 


 5.56% 
 9.62% 
 4.76% 
 4.00% 


 B.  2.18.14.1.1 
 Other 
 Desi  gn/< 


 10 
 circuits/  Dispatch/ 


 SC(%) 


 4.33% 
 4.30% 
 0.00% 
 5.08% 
 0.00% 
 5.41% 


 2,3 


 B.  2.18.15.1.2 
 Other 
 Non-  Design/< 


 10 
 circuits/  Non- 


 Dispatch/  SC(%) 


 0.14% 
 0.02% 
 0.01% 
 0.01% 


 B.  2.18.16.1.2 
 INP 
 (Standalone)/<  10 


 circuits/  Non- 
 Dispatch/  SC(%) 


 0.11% 
 0.02% 
 0.01% 
 0.01% 


 B.  2.18.17.1.1 
 LNP 
 (Standalone)/<  10 


 circuits/  Dispatch/ 
 SC(%) 
 4.49% 
 0.00% 
 4.87% 
 0.00% 
 6.23% 
 0.00% 
 7.69% 
 0.00% 
 1,2,3,4 


 B.  2.18.17.1.2 
 LNP 
 (Standalone)/<  10 


 circuits/  Non- 
 Dispatch/  SC(%) 


 0.11% 
 0.24% 
 0.02% 
 0.23% 
 0.01% 
 0.40% 
 0.01% 
 0.00% 


 B.  2.18.17.2.1 
 LNP 
 (Standalone)/>=  10 


 circuits/  Dispatch/ 
 SC(%) 
 3.39% 


 12.50% 


 7.41% 
 2.70% 


 B.  2.18.17.2.2 
 LNP 
 (Standalone)/>=  10 


 circuits/  Non- 
 Dispatch/  SC(%) 


 0.00% 
 0.00% 
 25.00% 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3,4 


 B.  2.18.18.1.1 
 Di 
 gital 


 Loop 


 < 
 DS1/<  10 


 circuits/  Dispatch/ 


 SC(%) 
 2.65% 
 0.00% 
 2.54% 
 0.00% 
 3.55% 
 0.00% 
 3.77% 
 0.00% 


 B.  2.18.19.1.1 
 Di 
 gital 


 Loop 


 >= 
 DS1/<  10 


 circuits/  Dispatch/ 


 SC(%) 
 0.83% 
 0.00% 
 1.19% 
 0.99% 
 3.75% 
 0.00% 
 1.19% 
 1.18% 


 % 
 Provisioning 


 Troubles 
 within 
 30 
 Days 


 [P-  9] 


 B.  2.19.2.1.1 
 Local 
 Interoffice 


 Transport/<  10 


 circuits/  Dis 
 patch/  SC(%) 


 7.17% 
 6.07% 
 10.15% 


 7.98% 


 B.  2.19.3.1.1 
 Loop 
 + 
 Port 


 Combinations/<  10  circuits/  Dis  patch/  SC(%) 


 9.54% 
 11.28% 


 9.70% 
 11.98% 
 11.30% 
 14.04% 
 11.51% 
 18.13% 


 F-  21 
352
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 South 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  2.19.3.1.2 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Non- 


 Dis 
 patch/  SC(%) 


 2.91% 
 3.82% 
 2.78% 
 3.88% 
 2.89% 
 3.61% 
 2.84% 
 3.55% 


 B.  2.19.3.1.3 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Switch 
 Based 


 Orders/  SC 
 (%) 


 2.73% 
 3.31% 
 2.70% 
 2.92% 
 2.84% 
 3.79% 
 2.62% 
 3.14% 


 B.  2.19.3.1.4 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Dispatch 


 In/  SC 
 (%) 


 3.09% 
 4.28% 
 2.85% 
 5.14% 
 2.93% 
 3.39% 
 3.03% 
 3.91% 


 B.  2.19.3.2.1 
 Loop 
 + 
 Port 


 Combinations/>=  10  circuits/  Dis  patch/  SC(%) 


 32.00% 
 0.00% 
 15.28% 


 0.00% 
 21.15% 


 28.57% 
 0.00% 
 1,2,4 


 B.  2.19.3.2.2 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Non- 


 Dis 
 patch/  SC(%) 


 3.70% 
 14.04% 
 0.00% 
 13.40% 


 0.00% 
 8.89% 
 0.00% 
 2,3,4 


 B.  2.19.3.2.4 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Dispatch 


 In/  SC 
 (%) 


 3.57% 
 8.00% 
 0.00% 
 12.07% 


 0.00% 
 6.58% 
 0.00% 
 2,3,4 


 B.  2.19.4.1.1 
 Combo 
 Other/<  10 


 circuits/  Dis 
 patch/  SC(%) 


 8.98% 
 20.00% 


 9.45% 
 4.17% 
 11.07% 


 6.06% 
 11.16% 


 6.45% 


 1 


 B.  2.19.5.1.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/<  10 


 circuits/  Dis 
 patch/  SC(%) 


 2.90% 
 33.33% 


 2.92% 
 14.29% 


 3.20% 
 0.00% 
 3.14% 
 0.00% 
 1,2,3,4 


 B.  2.19.6.1.1 
 UNE 
 ISDN/<  10 


 circuits/  Dis 
 patch/  SC(%) 


 11.24% 
 11.54% 
 8.97% 
 8.70% 
 9.20% 
 3.23% 
 7.23% 
 3.33% 


 B.  2.19.8.1.1 
 2W 
 Analog 


 Loop 
 Design/<  10 


 circuits/  Dispatch/ 


 SC(%) 
 9.54% 


 5.13% 
 9.70% 
 12.50% 
 11.30% 
 11.90% 
 11.51% 
 16.67% 


 B.  2.19.8.2.1 
 2W 
 Analog 


 Loop 
 Design/>=  10 


 circuits/  Dispatch/ 
 SC(%) 


 32.00% 
 15.28% 
 21.15% 
 28.57% 


 B.  2.19.11.1.1 
 2W 
 Analog 


 Loop 
 w/  INP 


 Non-  Design/< 


 10 


 circuits/  Dis 
 patch/  SC(%) 


 9.54% 
 9.79% 
 11.31% 
 11.52% 


 B.  2.19.12.1.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/<  10 


 circuits/  Dis 
 patch/  SC(%) 


 9.54% 
 8.11% 
 9.70% 
 17.95% 
 11.30% 
 8.11% 
 11.51% 


 4.65% 


 B.  2.19.12.2.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/>=  10 


 circuits/  Dis 
 patch/  SC(%) 


 32.00% 
 0.00% 
 15.28% 


 21.15% 
 28.57% 


 1 


 B.  2.19.14.1.1 
 Other 
 Desi 
 gn/<  10 


 circuits/  Dispatch/ 


 SC(%) 


 3.97% 
 5.63% 
 6.99% 
 25.00% 


 5.96% 
 0.00% 


 3,4 


 B.  2.19.15.1.2 
 Other 
 Non-  Design/< 


 10 
 circuits/  Non- 


 Dispatch/  SC(%) 


 2.91% 
 2.78% 
 2.89% 
 2.84% 


 B.  2.19.16.1.2 
 INP 
 (Standalone)/<  10 


 circuits/  Non- 
 Dispatch/  SC(%) 


 2.90% 
 0.00% 
 2.78% 


 2.87% 
 2.83% 


 1 


 B.  2.19.17.1.1 
 LNP 
 (Standalone)/<  10 


 circuits/  Dispatch/ 
 SC(%) 
 9.54% 
 0.00% 
 9.79% 
 0.00% 
 11.31% 


 0.00% 
 11.52% 


 0.00% 
 1,2,3,4 


 B.  2.19.17.1.2 
 LNP 
 (Standalone)/<  10 


 circuits/  Non- 
 Dispatch/  SC(%) 


 2.90% 
 0.00% 
 2.78% 
 0.00% 
 2.87% 
 0.00% 
 2.83% 
 0.00% 


 F-  22 
353
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 South 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  2.19.17.2.1 
 LNP 
 (Standalone)/>=  10 


 circuits/  Dispatch/ 
 SC(%) 
 31.43% 
 0.00% 
 13.56% 


 18.75% 
 37.04% 


 1 


 B.  2.19.17.2.2 
 LNP 
 (Standalone)/>=  10 


 circuits/  Non- 
 Dispatch/  SC(%) 


 0.00% 
 0.00% 
 25.00% 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 2,3,4 


 B.  2.19.18.1.1 
 Di 
 gital 


 Loop 


 < 
 DS1/<  10 


 circuits/  Dispatch/ 


 SC(%) 
 3.24% 
 15.63% 


 3.71% 
 9.43% 
 4.15% 
 2.94% 
 4.68% 
 2.70% 


 B.  2.19.19.1.1 
 Di 
 gital 


 Loop 


 >= 
 DS1/<  10 


 circuits/  Dispatch/ 


 SC(%) 
 2.30% 
 9.32% 
 5.83% 
 15.03% 


 4.76% 
 15.84% 


 5.00% 
 8.97% 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Mechanized 


 [P-  5] 


 B.  2.21.3.1.1 
 Loop 
 + 
 Port 


 Combinations/<  10  circuits/  Dis  patch/  SC(  hours) 


 1.16 
 0.48 
 1.67 
 0.17 
 1.38 
 0.08 
 1.85 
 0.46 


 B.  2.21.3.1.2 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Non- 


 Dis 
 patch/  SC( 


 hours) 


 0.61 
 0.56 
 0.65 
 0.60 
 0.69 
 0.61 
 0.60 
 0.62 


 B.  2.21.3.1.3 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Switch 
 Based 


 Orders/  SC 
 (hours) 


 0.70 
 0.53 
 0.77 
 0.58 
 0.79 
 0.59 
 0.71 
 0.59 


 B.  2.21.3.1.4 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Dispatch 


 In/  SC 
 (hours) 


 0.54 
 0.60 
 0.54 
 0.62 
 0.61 
 0.62 
 0.50 
 0.66 


 B.  2.21.3.2.1 
 Loop 
 + 
 Port 


 Combinations/>=  10  circuits/  Dis  patch/  SC(  hours) 


 9.46 
 0.04 
 3.01 


 2.73 
 0.07 
 9.13 


 1,3 


 B.  2.21.4.1.1 
 Combo 
 Other/<  10 


 circuits/  Dis 
 patch/  SC( 
 hours) 


 26.11 


 14.57 
 13.69 
 17.60 


 B.  2.21.6.1.1 
 UNE 
 ISDN/<  10 


 circuits/  Dis 
 patch/  SC( 
 hours) 


 75.35 
 0.02 
 160.93 


 0.02 
 80.14 


 113.95 
 19.22 
 1,2,4 


 B.  2.21.8.1.1 
 2W 
 Analog 


 Loop 
 Design/<  10 


 circuits/  Dis 
 patch/  SC( 
 hours) 


 1.16 
 23.18 


 1.67 
 13.65 


 1.38 
 6.06 
 1.85 
 27.79 


 B.  2.21.12.1.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/<  10 


 circuits/  Dis 
 patch/  SC( 
 hours) 


 1.16 
 51.32 


 1.67 
 70.52 


 1.38 
 57.81 


 1.85 
 65.41 


 B.  2.21.12.2.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/>=  10 


 circuits/  Dis 
 patch/  SC( 
 hours) 


 9.46 
 3.01 
 2.73 
 9.13 


 B.  2.21.17.1.1 
 LNP 
 (Standalone)/<  10 


 circuits/  Dispatch/ 
 SC( 
 hours) 


 1.14 


 1.49 
 0.02 
 1.36 
 0.02 
 1.52 
 0.02 
 2,3,4 


 B.  2.21.17.1.2 
 LNP 
 (Standalone)/<  10 


 circuits/  Non- 


 Dis 
 patch/  SC( 


 hours) 


 0.58 
 0.41 
 0.64 
 0.42 
 0.68 
 0.42 
 0.59 
 0.39 


 B.  2.21.17.2.1 
 LNP 
 (Standalone)/>=  10 


 circuits/  Dispatch/ 
 SC(  hours) 
 1.90 


 2.20 
 3.13 
 0.62 


 B.  2.21.17.2.2 
 LNP 
 (Standalone)/>=  10 


 circuits/  Non- 


 Dis 
 patch/  SC( 


 hours) 


 0.40 
 0.33 
 0.30 
 0.23 
 0.42 
 0.27 
 0.35 
 0.32 
 1,2,3,4 


 B.  2.21.18.1.1 
 Digital 
 Loop 
 < 
 DS1/<  10 


 circuits/  Dispatch/ 


 SC(  hours) 
 32.66 
 0.02 
 36.30 


 0.02 
 32.48 


 28.34 
 19.22 
 1,2,4 


 F-  23 
354
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 South 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  2.21.19.1.1 
 Digital 
 Loop 
 >= 
 DS1/<  10 


 circuits/  Dispatch/ 


 SC(  hours) 
 2093.19 
 43.17 
 298.17 


 62.35 
 264.35 


 28.91 
 258.56 


 34.45 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Non-  Mechanized 


 [P-  5] 


 B.  2.22.3.1.1 
 Loop 
 + 
 Port 


 Combinations/<  10  circuits/  Dis  patch/  SC(  hours) 


 9.04 
 23.91 


 11.16 
 13.24 


 B.  2.22.3.1.2 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Non- 


 Dis 
 patch/  SC( 


 hours) 


 3.44 
 3.81 
 3.11 
 4.32 


 B.  2.22.3.1.3 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Switch 
 Based 


 Orders/  SC 
 (hours) 


 2.51 
 3.60 
 2.39 
 2.84 


 B.  2.22.3.1.4 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Dispatch 


 In/  SC 
 (hours) 


 6.10 
 4.46 
 5.08 
 8.70 


 B.  2.22.3.2.1 
 Loop 
 + 
 Port 


 Combinations/>=  10  circuits/  Dis  patch/  SC(  hours) 


 0.02 
 18.90 
 3,4 


 B.  2.22.3.2.2 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Non- 


 Dis 
 patch/  SC( 


 hours) 


 14.00 
 0.02 
 7.01 


 1,2,3 


 B.  2.22.3.2.4 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Dispatch 


 In/  SC 
 (hours) 


 14.00 
 0.02 
 7.01 


 1,2,3 


 B.  2.22.4.1.1 
 Combo 
 Other/<  10 


 circuits/  Dis 
 patch/  SC( 
 hours) 


 65.15 
 64.80 
 71.59 
 74.38 


 B.  2.22.5.1.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/<  10 


 circuits/  Dis 
 patch/  SC( 
 hours) 


 39.29 
 50.45 
 15.10 


 1,2,3 


 B.  2.22.6.1.1 
 UNE 
 ISDN/<  10 


 circuits/  Dis 
 patch/  SC( 
 hours) 


 41.28 
 34.19 
 32.32 
 33.85 


 B.  2.22.8.1.1 
 2W 
 Analog 


 Loop 
 Design/<  10 


 circuits/  Dis 
 patch/  SC( 
 hours) 


 62.43 
 39.61 
 55.93 
 25.78 
 3 


 B.  2.22.12.1.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/<  10 


 circuits/  Dis 
 patch/  SC( 
 hours) 


 18.32 
 154.48 


 27.78 


 1,2,3 


 B.  2.22.14.1.1 
 Other 
 Desi  gn/< 


 10 
 circuits/  Dispatch/ 


 SC( 
 hours) 


 22.10 
 17.77 


 2,3 


 B.  2.22.15.1.2 
 Other 
 Non-  Design/< 


 10 
 circuits/  Non- 


 Dis 
 patch/  SC( 


 hours) 


 B.  2.22.16.1.2 
 INP 
 (Standalone)/<  10 


 circuits/  Non- 


 Dis 
 patch/  SC( 


 hours) 


 B.  2.22.17.1.1 
 LNP 
 (Standalone)/<  10 


 circuits/  Dispatch/ 
 SC( 
 hours) 


 16.80 
 35.35 
 15.03 
 28.80 
 1,2,3,4 


 B.  2.22.17.1.2 
 LNP 
 (Standalone)/<  10 


 circuits/  Non- 


 Dis 
 patch/  SC( 


 hours) 


 4.93 
 5.93 
 4.51 
 2.93 


 F-  24 
355
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 South 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  2.22.17.2.2 
 LNP 
 (Standalone)/>=  10 


 circuits/  Non- 


 Dis 
 patch/  SC( 


 hours) 


 5.87 
 0.48 
 4.87 


 1,2,3 


 B.  2.22.18.1.1 
 Digital 
 Loop 
 < 
 DS1/<  10 


 circuits/  Dispatch/ 


 SC(  hours) 


 41.01 
 35.76 
 29.07 
 33.85 


 B.  2.22.19.1.1 
 Digital 
 Loop 
 >= 
 DS1/<  10 


 circuits/  Dispatch/ 


 SC(  hours) 


 50.79 
 55.51 
 63.66 
 54.16 


 Service 
 Order 
 Accuracy 


 [P-  11] 


 B.  2.34.1.1.1 
 Desi 
 gn 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 SC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  2.34.1.1.2 
 Design 
 (Specials)/<  10 


 circuits/  Non- 
 Dispatch/  SC(%) 


 100.00% 
 67.07% 
 69.33% 


 B.  2.34.1.2.1 
 Desi 
 gn 
 (Specials)/>=  10 


 circuits/  Dispatch/ 


 SC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  2.34.1.2.2 
 Design 
 (Specials)/>=  10 


 circuits/  Non- 
 Dispatch/  SC(%) 


 100.00% 
 90.91% 
 3 


 B.  2.34.2.1.1 
 Loo  ps 
 Non-  Design/< 


 10 
 circuits/  Dispatch/ 


 SC(%) 


 98.18% 
 95.65% 
 96.00% 
 96.33% 


 B.  2.34.2.1.2 
 Loops 
 Non-  Design/< 


 10 
 circuits/  Non- 


 Dispatch/  SC(%) 


 99.09% 
 98.18% 
 100.00% 


 98.02% 


 B.  2.34.2.2.1 
 Loo  ps 
 Non-  Design/>= 


 10 
 circuits/  Dispatch/ 


 SC(%) 


 97.75% 
 89.81% 
 97.90% 
 97.73% 


 B.  2.34.2.2.2 
 Loops 
 Non-  Design/>= 


 10 
 circuits/  Non- 


 Dispatch/  SC(%) 


 97.20% 
 97.98% 
 98.73% 
 97.53% 


 UNBUNDLED 
 NETWORK 
 ELEMENTS 


 - 
 MAINTENANCE 


 AND 
 REPAIR 


 Missed 
 Repair 
 Appointments 


 [M&  R- 
 1] 


 B.  3.1.2.1 
 Local 
 Interoffice 


 Trans  port/ 
 Dispatch/  SC(%) 


 0.88% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.35% 
 0.00% 


 B.  3.1.2.2 
 Local 
 Interoffice 


 Trans  port/ 
 Non-  Dispatch/ 


 SC(%) 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.45% 
 0.00% 


 B.  3.1.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  Dispatch/ 


 SC(%) 
 4.84% 
 0.81% 
 5.08% 
 0.60% 
 6.41% 
 0.35% 
 6.94% 
 0.49% 


 B.  3.1.3.2 
 Loo  p 
 + 
 Port 


 Combinations/  Non- 


 Dispatch/  SC(%) 


 0.83% 
 1.84% 
 1.10% 
 0.00% 
 0.80% 
 0.00% 
 1.26% 
 0.00% 


 B.  3.1.4.1 
 Combo 
 Other/  Dis 


 patch/  SC(%) 


 4.77% 
 0.00% 
 4.98% 
 0.00% 
 6.28% 
 0.00% 
 6.82% 
 0.00% 


 1,2 


 B.  3.1.4.2 
 Combo 
 Other/  Non- 


 Dis  patch/ 
 SC(%) 


 4.77% 
 0.00% 
 4.98% 
 0.00% 
 6.28% 
 0.00% 
 6.82% 
 0.00% 
 1,2,3,4 


 B.  3.1.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Dispatch/ 


 SC(%) 
 46.58% 
 0.00% 
 57.14% 


 0.00% 
 45.42% 


 0.00% 
 55.91% 


 0.00% 
 1,2,3,4 


 B.  3.1.5.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Non- 


 Dispatch/  SC(%) 


 4.11% 
 0.00% 
 3.66% 
 0.00% 
 3.57% 
 0.00% 
 1.86% 
 0.00% 
 1,2,4 


 B.  3.1.6.1 
 UNE 
 ISDN/  Dis 


 patch/  SC(%) 


 3.03% 
 28.57% 


 6.38% 
 9.09% 
 0.00% 
 0.00% 
 2.78% 
 0.00% 


 1 


 B.  3.1.6.2 
 UNE 
 ISDN/  Non- 


 Dis 
 patch/  SC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1.30% 
 0.00% 
 2,3,4 


 B.  3.1.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  Dispatch/ 


 SC(%) 


 4.84% 
 0.00% 
 5.08% 
 0.00% 
 6.41% 
 0.00% 
 6.94% 
 0.00% 


 B.  3.1.8.2 
 2W 
 Analo  g 


 Loop 
 Design/  Non- 


 Dispatch/  SC(%) 


 4.84% 
 0.00% 
 5.08% 
 0.00% 
 6.41% 
 0.00% 
 6.94% 
 0.00% 


 F-  25 
356
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 South 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  3.1.9.1 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 Dispatch/  SC(%) 


 4.72% 
 0.00% 
 4.89% 
 0.00% 
 6.27% 
 0.00% 
 6.82% 
 0.00% 
 1,3,4 


 B.  3.1.9.2 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 Non-  Dispatch/ 


 SC(%) 
 0.64% 
 0.00% 
 0.97% 
 0.00% 
 0.72% 
 0.00% 
 1.20% 
 0.00% 


 B.  3.1.10.1 
 Other 
 Desi  gn/ 
 Dispatch/  SC(%) 


 1.14% 
 0.00% 
 0.60% 
 0.00% 
 1.13% 
 0.00% 
 1.35% 
 0.00% 


 3 


 B.  3.1.10.2 
 Other 
 Desi  gn/ 


 Non-  Dispatch/ 


 SC(%) 


 0.00% 
 0.00% 
 0.30% 
 0.00% 
 0.52% 
 0.00% 
 0.27% 
 0.00% 


 3 


 B.  3.1.11.1 
 Other 
 Non-  Desi 


 gn/  Dispatch/ 


 SC(%) 


 4.84% 
 0.00% 
 5.08% 
 0.00% 
 6.41% 
 0.00% 
 6.94% 
 0.00% 


 B.  3.1.11.2 
 Other 
 Non-  Desi 


 gn/  Non- 
 Dispatch/  SC(%) 


 0.83% 
 0.00% 
 1.10% 
 0.00% 
 0.80% 
 0.00% 
 1.26% 
 0.00% 


 Customer 
 Trouble 
 Report 
 Rate 
 [M&  R- 


 2] 


 B.  3.2.2.1 
 Local 
 Interoffice 


 Trans  port/ 
 Dispatch/  SC(%) 


 1.55% 
 0.00% 
 1.54% 
 0.00% 
 1.92% 
 0.00% 
 1.95% 
 0.00% 


 4 


 B.  3.2.2.2 
 Local 
 Interoffice 


 Trans  port/ 
 Non-  Dispatch/ 


 SC(%) 
 1.25% 
 0.00% 
 1.21% 
 0.00% 
 1.44% 
 0.00% 
 1.52% 
 0.00% 


 4 


 B.  3.2.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  Dispatch/ 


 SC(%) 
 1.51% 
 1.36% 
 1.72% 
 1.33% 
 1.86% 
 1.46% 
 1.82% 
 1.47% 


 B.  3.2.3.2 
 Loo  p 
 + 
 Port 


 Combinations/  Non- 


 Dispatch/  SC(%) 


 0.81% 
 0.45% 
 0.79% 
 0.25% 
 0.90% 
 0.33% 
 0.88% 
 0.44% 


 B.  3.2.4.1 
 Combo 
 Other/  Dis 


 patch/  SC(%) 


 1.31% 
 1.29% 
 1.49% 
 4.74% 
 1.62% 
 3.85% 
 1.57% 
 3.69% 


 B.  3.2.4.2 
 Combo 
 Other/  Non- 


 Dis  patch/ 
 SC(%) 


 1.31% 
 1.94% 
 1.49% 
 1.58% 
 1.62% 
 0.77% 
 1.57% 
 1.42% 


 B.  3.2.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Dispatch/ 


 SC(%) 
 0.78% 
 1.13% 
 1.04% 
 0.75% 
 1.24% 
 0.75% 
 1.23% 
 0.56% 


 B.  3.2.5.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Non- 


 Dispatch/  SC(%) 


 1.06% 
 0.57% 
 1.96% 
 0.19% 
 1.77% 
 0.00% 
 2.11% 
 0.28% 


 B.  3.2.6.1 
 UNE 
 ISDN/  Dis 


 patch/  SC(%) 


 0.53% 
 0.78% 
 0.75% 
 1.19% 
 0.74% 
 1.18% 
 0.59% 
 1.39% 


 B.  3.2.6.2 
 UNE 
 ISDN/  Non- 


 Dis 
 patch/  SC(%) 


 1.12% 
 1.33% 
 1.31% 
 0.54% 
 1.30% 
 0.32% 
 1.26% 
 0.43% 


 B.  3.2.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  Dispatch/ 


 SC(%) 


 1.51% 
 0.77% 
 1.72% 
 1.04% 
 1.86% 
 0.76% 
 1.82% 
 0.71% 


 B.  3.2.8.2 
 2W 
 Analo  g 


 Loop 
 Design/  Non- 


 Dispatch/  SC(%) 


 1.51% 
 0.28% 
 1.72% 
 0.17% 
 1.86% 
 0.23% 
 1.82% 
 0.23% 


 B.  3.2.9.1 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 Dispatch/  SC(%) 


 1.60% 
 4.38% 
 1.82% 
 7.05% 
 1.97% 
 3.18% 
 1.93% 
 1.91% 


 B.  3.2.9.2 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 Non-  Dispatch/ 


 SC(%) 
 0.74% 
 0.00% 
 0.73% 
 0.00% 
 0.85% 
 0.00% 
 0.83% 
 0.00% 


 B.  3.2.10.1 
 Other 
 Desi  gn/ 
 Dispatch/  SC(%) 


 0.18% 
 0.00% 
 0.20% 
 0.00% 
 0.25% 
 3.13% 
 0.21% 
 0.00% 


 B.  3.2.10.2 
 Other 
 Desi  gn/ 


 Non-  Dispatch/ 


 SC(%) 


 0.28% 
 0.00% 
 0.27% 
 0.00% 
 0.31% 
 3.13% 
 0.31% 
 0.00% 


 B.  3.2.11.1 
 Other 
 Non-  Desi 


 gn/  Dispatch/ 


 SC(%) 


 1.51% 
 0.00% 
 1.72% 
 0.00% 
 1.86% 
 0.00% 
 1.82% 
 0.00% 


 B.  3.2.11.2 
 Other 
 Non-  Desi 


 gn/  Non- 
 Dispatch/  SC(%) 


 0.81% 
 0.00% 
 0.79% 
 0.00% 
 0.90% 
 0.00% 
 0.88% 
 0.00% 


 Maintenance 
 Average 
 Duration 


 [M&  R- 
 3] 


 B.  3.3.2.1 
 Local 
 Interoffice 


 Trans  port/ 
 Dispatch/  SC( 


 hours) 


 4.34 
 0.00 
 3.70 
 0.00 
 4.13 
 0.00 
 4.68 
 0.00 


 B.  3.3.2.2 
 Local 
 Interoffice 


 Transport/  Non- 


 Dispatch/  SC( 
 hours) 
 1.63 
 0.00 
 1.52 
 0.00 
 1.77 
 0.00 
 1.55 
 0.00 


 B.  3.3.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  Dispatch/ 


 SC( 
 hours) 


 17.59 
 9.70 
 19.09 


 10.90 
 21.70 
 12.28 
 22.85 
 12.93 


 F-  26 
357
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 South 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  3.3.3.2 
 Loop 
 + 
 Port 


 Combinations/  Non- 


 Dispatch/  SC( 
 hours) 
 5.88 
 3.94 
 6.03 
 2.86 
 7.44 
 2.28 
 7.53 
 4.94 


 B.  3.3.4.1 
 Combo 
 Other/  Dis 


 patch/  SC( 
 hours) 


 17.33 
 4.93 
 18.80 


 5.78 
 21.30 


 3.54 
 22.49 


 4.10 
 1,2 


 B.  3.3.4.2 
 Combo 
 Other/  Non- 


 Dis  patch/ 
 SC( 
 hours) 


 17.33 
 1.04 
 18.80 


 1.09 
 21.30 


 0.42 
 22.49 


 2.12 
 1,2,3,4 


 B.  3.3.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Dispatch/ 


 SC( 
 hours) 


 48.33 
 2.30 
 47.74 


 5.54 
 36.21 


 6.06 
 45.27 


 4.52 
 1,2,3,4 


 B.  3.3.5.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Non- 


 Dis 
 patch/  SC( 


 hours) 


 5.85 
 3.03 
 3.37 
 6.43 
 2.86 
 0.00 
 1.58 
 11.80 
 1,2,4 


 B.  3.3.6.1 
 UNE 
 ISDN/  Dis 


 patch/  SC( 
 hours) 


 5.66 
 10.32 


 7.58 
 5.99 
 5.00 
 5.65 
 7.04 
 3.55 


 1 


 B.  3.3.6.2 
 UNE 
 ISDN/  Non- 


 Dis 
 patch/  SC( 


 hours) 


 1.93 
 5.33 
 1.72 
 3.63 
 2.15 
 2.42 
 1.61 
 1.95 
 2,3,4 


 B.  3.3.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  Dispatch/ 


 SC( 
 hours) 


 17.59 
 4.11 
 19.09 


 4.00 
 21.70 


 3.55 
 22.85 


 4.65 


 B.  3.3.8.2 
 2W 
 Analog 


 Loop 
 Design/  Non- 


 Dispatch/  SC( 
 hours) 
 17.59 
 2.92 
 19.09 


 3.16 
 21.70 


 1.78 
 22.85 


 4.01 


 B.  3.3.9.1 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 Dispatch/  SC( 
 hours) 
 17.65 
 10.11 
 19.13 


 7.18 
 21.84 


 31.80 
 22.94 
 35.00 
 1,3,4 


 B.  3.3.9.2 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 Non- 


 Dis 
 patch/  SC( 


 hours) 


 6.32 
 0.00 
 6.52 
 0.00 
 8.09 
 0.00 
 8.23 
 0.00 


 B.  3.3.10.1 
 Other 
 Desi  gn/ 
 Dispatch/  SC( 


 hours) 


 5.02 
 0.00 
 5.00 
 0.00 
 5.19 
 3.43 
 5.53 
 0.00 


 3 


 B.  3.3.10.2 
 Other 
 Desi  gn/ 


 Non-  Dispatch/ 


 SC( 
 hours) 


 2.10 
 0.00 
 2.32 
 0.00 
 2.25 
 0.68 
 1.88 
 0.00 


 3 


 B.  3.3.11.1 
 Other 
 Non-  Desi 


 gn/  Dispatch/ 


 SC( 
 hours) 


 17.59 
 0.00 
 19.09 


 0.00 
 21.70 


 0.00 
 22.85 


 0.00 


 B.  3.3.11.2 
 Other 
 Non-  Desi 


 gn/  Non- 
 Dispatch/  SC( 


 hours) 


 5.88 
 0.00 
 6.03 
 0.00 
 7.44 
 0.00 
 7.53 
 0.00 


 % 
 Repeat 


 Troubles 


 within 
 30 
 Days 


 [M&  R- 


 4] 


 B.  3.4.2.1 
 Local 
 Interoffice 


 Trans  port/ 
 Dispatch/  SC(%) 


 23.79% 
 0.00% 
 24.67% 


 0.00% 
 17.44% 


 0.00% 
 27.62% 


 0.00% 


 B.  3.4.2.2 
 Local 
 Interoffice 


 Trans  port/ 
 Non-  Dispatch/ 


 SC(%) 
 20.88% 
 0.00% 
 16.76% 


 0.00% 
 17.62% 


 0.00% 
 18.39% 


 0.00% 


 B.  3.4.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  Dispatch/ 


 SC(%) 
 15.78% 
 13.62% 
 15.37% 
 9.00% 
 16.31% 
 10.18% 
 16.18% 
 13.38% 


 B.  3.4.3.2 
 Loo  p 
 + 
 Port 


 Combinations/  Non- 


 Dispatch/  SC(%) 


 14.07% 
 16.56% 
 14.16% 
 11.83% 
 14.47% 
 8.59% 
 14.20% 
 16.30% 


 B.  3.4.4.1 
 Combo 
 Other/  Dis 


 patch/  SC(%) 


 15.79% 
 0.00% 
 15.47% 
 33.33% 
 16.33% 
 30.00% 
 16.27% 
 23.08% 


 1,2 


 B.  3.4.4.2 
 Combo 
 Other/  Non- 


 Dis  patch/ 
 SC(%) 


 15.79% 
 66.67% 
 15.47% 
 0.00% 
 16.33% 


 0.00% 
 16.27% 
 20.00% 
 1,2,3,4 


 B.  3.4.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Dispatch/ 


 SC(%) 
 16.15% 
 0.00% 
 23.81% 


 0.00% 
 25.08% 


 0.00% 
 25.24% 


 0.00% 
 1,2,3,4 


 B.  3.4.5.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Non- 


 Dispatch/  SC(%) 


 15.98% 
 0.00% 
 25.17% 
 100.00% 


 25.95% 
 0.00% 
 26.82% 
 100.00% 


 1,2,4 


 B.  3.4.6.1 
 UNE 
 ISDN/  Dis 


 patch/  SC(%) 


 9.09% 
 0.00% 
 23.40% 
 27.27% 
 19.57% 
 18.18% 
 8.33% 
 7.69% 


 1 


 B.  3.4.6.2 
 UNE 
 ISDN/  Non- 


 Dis 
 patch/  SC(%) 


 15.71% 
 16.67% 
 13.41% 
 0.00% 
 16.05% 


 0.00% 
 7.79% 
 0.00% 
 2,3,4 


 B.  3.4.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  Dispatch/ 


 SC(%) 


 15.78% 
 16.05% 
 15.37% 
 2.73% 
 16.31% 
 20.25% 
 16.18% 
 11.27% 


 B.  3.4.8.2 
 2W 
 Analo  g 


 Loop 
 Design/  Non- 


 Dispatch/  SC(%) 


 15.78% 
 13.33% 
 15.37% 
 5.56% 
 16.31% 


 0.00% 
 16.18% 


 8.70% 


 F-  27 
358
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 South 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 B.  3.4.9.1 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 Dispatch/  SC(%) 


 15.81% 
 0.00% 
 15.40% 


 0.00% 
 16.22% 


 0.00% 
 16.19% 


 0.00% 
 1,3,4 


 B.  3.4.9.2 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 Non-  Dispatch/ 


 SC(%) 
 14.51% 
 0.00% 
 14.15% 


 0.00% 
 14.79% 


 0.00% 
 14.73% 


 0.00% 


 B.  3.4.10.1 
 Other 
 Desi 
 gn/  Dispatch/ 


 SC(%) 


 16.21% 
 0.00% 
 20.36% 


 0.00% 
 17.20% 
 100.00% 


 20.46% 
 0.00% 


 3 


 B.  3.4.10.2 
 Other 
 Desi 
 gn/  Non- 


 Dispatch/  SC(%) 


 16.72% 
 0.00% 
 13.73% 


 0.00% 
 16.49% 


 0.00% 
 18.22% 


 0.00% 


 3 


 B.  3.4.11.1 
 Other 
 Non-  Desi 


 gn/  Dispatch/ 


 SC(%) 


 15.78% 
 0.00% 
 15.37% 


 0.00% 
 16.31% 


 0.00% 
 16.18% 


 0.00% 


 B.  3.4.11.2 
 Other 
 Non-  Desi 


 gn/  Non- 
 Dispatch/  SC(%) 


 14.07% 
 0.00% 
 14.16% 


 0.00% 
 14.47% 


 0.00% 
 14.20% 


 0.00% 


 Out 
 of 
 Service 


 > 
 24 


 hours 


 [M&  R- 


 5] 


 B.  3.5.2.1 
 Local 
 Interoffice 


 Trans  port/ 
 Dispatch/  SC(%) 


 0.88% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.35% 
 0.00% 


 B.  3.5.2.2 
 Local 
 Interoffice 


 Trans  port/ 
 Non-  Dispatch/ 


 SC(%) 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.45% 
 0.00% 


 B.  3.5.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  Dispatch/ 


 SC(%) 
 15.28% 
 2.73% 
 15.92% 


 3.86% 
 20.58% 


 6.07% 
 21.82% 


 4.27% 


 B.  3.5.3.2 
 Loo  p 
 + 
 Port 


 Combinations/  Non- 


 Dispatch/  SC(%) 


 6.14% 
 0.00% 
 6.64% 
 0.00% 
 7.86% 
 1.45% 
 9.16% 
 1.05% 


 B.  3.5.4.1 
 Combo 
 Other/  Dis 


 patch/  SC(%) 


 14.84% 
 0.00% 
 15.46% 


 0.00% 
 19.90% 


 0.00% 
 21.20% 


 0.00% 
 1,2 


 B.  3.5.4.2 
 Combo 
 Other/  Non- 


 Dis  patch/ 
 SC(%) 


 14.84% 
 0.00% 
 15.46% 


 0.00% 
 19.90% 


 0.00% 
 21.20% 


 0.00% 
 1,2,3,4 


 B.  3.5.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Dispatch/ 


 SC(%) 
 46.58% 
 0.00% 
 57.14% 


 0.00% 
 45.42% 


 0.00% 
 55.91% 


 0.00% 
 1,2,3,4 


 B.  3.5.5.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Non- 


 Dispatch/  SC(%) 


 4.11% 
 0.00% 
 3.66% 
 0.00% 
 3.57% 
 0.00% 
 1.86% 
 0.00% 
 1,2,4 


 B.  3.5.6.1 
 UNE 
 ISDN/  Dis 


 patch/  SC(%) 


 3.03% 
 28.57% 


 6.38% 
 9.09% 
 0.00% 
 0.00% 
 2.78% 
 0.00% 


 1 


 B.  3.5.6.2 
 UNE 
 ISDN/  Non- 


 Dis 
 patch/  SC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1.41% 
 0.00% 
 2,3,4 


 B.  3.5.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  Dispatch/ 


 SC(%) 


 15.28% 
 0.00% 
 15.92% 


 0.00% 
 20.58% 


 0.00% 
 21.82% 


 0.00% 


 B.  3.5.8.2 
 2W 
 Analo  g 


 Loop 
 Design/  Non- 


 Dispatch/  SC(%) 


 15.28% 
 0.00% 
 15.92% 


 0.00% 
 20.58% 


 0.00% 
 21.82% 


 0.00% 


 B.  3.5.9.1 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 Dispatch/  SC(%) 


 15.46% 
 0.00% 
 15.95% 


 0.00% 
 20.76% 


 0.00% 
 21.90% 


 0.00% 
 1,2,4 


 B.  3.5.9.2 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 Non-  Dispatch/ 


 SC(%) 
 6.36% 
 0.00% 
 6.86% 
 0.00% 
 8.18% 
 0.00% 
 9.55% 
 0.00% 


 B.  3.5.10.1 
 Other 
 Desi 
 gn/  Dispatch/ 


 SC(%) 


 1.14% 
 0.00% 
 0.60% 
 0.00% 
 1.13% 
 0.00% 
 1.35% 
 0.00% 


 3 


 B.  3.5.10.2 
 Other 
 Desi  gn/ 


 Non-  Dispatch/ 


 SC(%) 


 0.00% 
 0.00% 
 0.30% 
 0.00% 
 0.52% 
 0.00% 
 0.27% 
 0.00% 


 3 


 B.  3.5.11.1 
 Other 
 Non-  Desi 


 gn/  Dispatch/ 


 SC(%) 


 15.28% 
 0.00% 
 15.92% 


 0.00% 
 20.58% 


 0.00% 
 21.82% 


 0.00% 


 B.  3.5.11.2 
 Other 
 Non-  Desi 


 gn/  Non- 
 Dispatch/  SC(%) 


 6.14% 
 0.00% 
 6.64% 
 0.00% 
 7.86% 
 0.00% 
 9.16% 
 0.00% 


 UNBUNDLED 
 NETWORK 
 ELEMENTS 


 - 
 BILLING 


 Invoice 
 Accuracy 


 [B-  1] 


 B.  4.1 
 SC 
 (%) 


 98.49% 
 99.55% 
 98.65% 
 99.84% 
 98.76% 
 99.71% 
 98.73% 
 99.99% 


 Mean 
 Time 
 to 
 Deliver 


 Invoices 


 - 
 CRIS 


 [B-  2] 


 B.  4.2 
 Re  gion( 
 business 


 days) 


 3.68 
 7.29 
 3.86 
 4.97 
 3.47 
 3.78 
 3.82 
 3.46 


 F-  28 
359
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 South 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 LOCAL 
 INTERCONNECTION 


 TRUNKS 
 - 
 ORDERING 


 % 
 Rejected 


 Service 
 Requests 


 [O-  7] 


 C.  1.1 
 Local 
 Interconnection 


 Trunks/  SC 
 (%) 


 40.00% 
 78.57% 
 50.00% 
 52.83% 


 Reject 
 Interval 


 [O-  8] 


 C.  1.2 
 Local 
 Interconnection 


 Trunks/  SC 
 (%) 


 100.00% 
 100.00% 
 75.00% 
 96.43% 
 1,3 


 FOC 
 Timeliness 


 [O-  9] 


 C.  1.3 
 Local 
 Interconnection 


 Trunks/  SC 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 [O-  11] 


 C.  1.4 
 Local 
 Interconnection 


 Trunks/  SC 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 LOCAL 
 INTERCONNECTION 


 TRUNKS 
 - 
 PROVISIONING 


 Order 
 Completion 


 Interval 
 [P-  4] 


 C.  2.1 
 Local 
 Interconnection 


 Trunks/  SC 
 (days) 


 21.04 
 19.43 
 17.94 
 13.90 
 26.22 
 12.64 
 18.90 
 13.00 
 1,4 


 Held 
 Orders 


 [P-  1] 


 C.  2.2 
 Local 
 Interconnection 


 Trunks/  SC 
 (days) 


 0.00 
 0.00 
 0.00 
 0.00 
 0.00 
 0.00 
 0.00 
 0.00 


 % 
 Jeopardies 


 [P-  2] 


 C.  2.3 
 Local 
 Interconnection 


 Trunks/  SC 
 (%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 1,4 


 % 
 Missed 


 Installation 


 Appointments 


 [P-  3] 


 C.  2.5 
 Local 
 Interconnection 


 Trunks/  SC 
 (%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 3.33% 
 0.00% 


 1,4 


 % 
 Provisioning 


 Troubles 
 within 
 30 
 Days 


 [P-  9] 


 C.  2.6 
 Local 
 Interconnection 


 Trunks/  SC 
 (%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 Average 
 Completion 


 Notice 
 Interval 


 [P-  5] 


 C.  2.7 
 Local 
 Interconnection 


 Trunks/  SC 
 (hours) 


 117.68 
 0.02 
 242.38 


 7.95 
 254.09 


 35.91 
 154.30 


 0.02 
 1,4 


 Total 
 Service 


 Order 
 Cycle 
 Time 
 [P-  10] 


 C.  2.8 
 Local 
 Interconnection 


 Trunks/  SC 
 (days) 


 21.08 
 15.78 
 13.85 
 14.18 
 1,4 


 % 
 Completions 


 w/  o 
 Notice 


 or 
 < 
 24 


 hours 


 [P-  6] 


 C.  2.10.1 
 Local 
 Interconnection 


 Trunks/  Dis 
 patch/  SC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1,4 


 Service 
 Order 
 Accuracy 


 [P-  11] 


 C.  2.11.1.1 
 Local 
 Interconnection 


 Trunks/<  10 


 circuits/  Dis 
 patch/  SC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 C.  2.11.1.2 
 Local 
 Interconnection 


 Trunks/<  10 
 circuits/  Non- 


 Dis 
 patch/  SC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 C.  2.11.2.1 
 Local 
 Interconnection 


 Trunks/>=  10 


 circuits/  Dis 
 patch/  SC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,4 


 F-  29 
360
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 South 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 C.  2.11.2.2 
 Local 
 Interconnection 


 Trunks/>=  10 
 circuits/  Non- 


 Dis 
 patch/  SC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2 


 LOCAL 
 INTERCONNECTION 


 TRUNKS 
 - 
 MAINTENANCE 


 AND 
 REPAIR 


 Missed 
 Repair 
 Appointments 


 [M&  R- 
 1] 


 C.  3.1.1 
 Local 
 Interconnection 


 Trunks/  Dis 
 patch/  SC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 4 


 C.  3.1.2 
 Local 
 Interconnection 


 Trunks/  Non- 
 Dispatch/  SC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 Customer 
 Trouble 
 Report 
 Rate 
 [M&  R- 


 2] 


 C.  3.2.1 
 Local 
 Interconnection 


 Trunks/  Dis 
 patch/  SC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 C.  3.2.2 
 Local 
 Interconnection 


 Trunks/  Non- 
 Dispatch/  SC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 Maintenance 
 Average 
 Duration 


 [M&  R- 
 3] 


 C.  3.3.1 
 Local 
 Interconnection 


 Trunks/  Dis 
 patch/  SC( 
 hours) 


 0.00 
 0.00 
 0.00 
 0.00 
 0.00 
 0.00 
 0.00 
 0.43 


 4 


 C.  3.3.2 
 Local 
 Interconnection 


 Trunks/  Non- 
 Dispatch/  SC( 
 hours) 
 1.39 


 0.00 
 0.00 
 0.00 
 3.84 
 0.00 
 0.93 
 0.00 


 % 
 Repeat 


 Troubles 


 within 
 30 
 Days 


 [M&  R- 


 4] 


 C.  3.4.1 
 Local 
 Interconnection 


 Trunks/  Dis 
 patch/  SC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 4 


 C.  3.4.2 
 Local 
 Interconnection 


 Trunks/  Non- 
 Dispatch/  SC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 Out 
 of 
 Service 


 > 
 24 


 hours 


 [M&  R- 


 5] 


 C.  3.5.1 
 Local 
 Interconnection 


 Trunks/  Dis 
 patch/  SC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 4 


 C.  3.5.2 
 Local 
 Interconnection 


 Trunks/  Non- 
 Dispatch/  SC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 LOCAL 
 INTERCONNECTION 


 TRUNKS 
 - 
 BILLING 


 Invoice 
 Accuracy 


 [B-  1] 


 C.  4.1 
 SC 
 (%) 


 98.49% 
 99.92% 
 98.65% 
 87.50% 
 98.76% 
 96.66% 
 98.73% 
 90.10% 


 Mean 
 Time 
 to 
 Deliver 


 Invoices 


 - 
 CABS 


 [B-  2] 


 C.  4.2 
 Re  gion( 
 calendar 


 days) 


 4.84 
 4.54 
 3.94 
 3.89 
 4.96 
 4.92 
 4.54 
 4.29 


 LOCAL 
 INTERCONNECTION 


 TRUNKS 
 - 
 TRUNK 


 BLOCKING 


 Trunk 
 Group 
 Performance 


 - 
 Aggregate 


 [TGP-  1] 


 C.  5.1 
 SC 


 0 
 0 
 0 
 0 


 OPERATIONS 
 SUPPORT 
 SYSTEMS 
 - 
 PRE-  ORDERING 


 % 
 Interface 


 Availability 


 - 
 CLEC 


 [OSS-  2] 


 F-  30 
361
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 South 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 D.  1.1.1 
 EDI/  Region(%) 


 99.71% 
 100.00% 


 99.64% 
 100.00% 


 D.  1.1.2 
 HAL/  Re 
 gion(%) 


 100.00% 
 100.00% 


 D.  1.1.3 
 LENS/  Re 
 gion(%) 


 99.99% 
 99.98% 
 99.85% 
 99.76% 


 D.  1.1.4 
 LEO 
 MAINFRAME/  Re 


 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 D.  1.1.6 
 LESOG/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 D.  1.1.7 
 TAG/  Re 
 gion(%) 


 100.00% 
 99.95% 
 99.99% 
 99.86% 


 D.  1.1.8 
 PSIMS/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 % 
 Interface 


 Availability 


 - 
 BST 


 & 
 CLEC 


 [OSS-  2] 


 D.  1.2.1 
 ATLAS/  COFFI/ 


 Re 
 gion(%) 


 100.00% 
 100.00% 


 D.  1.2.2 
 BOCRIS/  Re 
 gion(%) 


 100.00% 
 100.00% 
 99.96% 
 99.99% 


 D.  1.2.3 
 DSAP/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.98% 


 D.  1.2.4 
 RSAG/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.99% 


 D.  1.2.5 
 SOCS/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.99% 


 D.  1.2.6 
 SONGS/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.86% 


 D.  1.2.7 
 DOE/  Re 
 gion(%) 


 99.99% 
 99.99% 
 99.99% 
 99.26% 


 D.  1.2.8 
 LNP 
 Gatewa 


 y/  Region(%) 


 100.00% 
 99.99% 
 100.00% 


 99.49% 


 D.  1.2.9 
 COG/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.48% 


 D.  1.2.10 
 DOM/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.99% 


 D.  1.2.11 
 SOG/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 D.  1.2.1- 
 new 
 ATLAS/  Re 


 gion 
 (%) 


 100.00% 
 99.99% 


 D.  1.2.2- 
 new 
 COFFI/  Re 


 gion 
 (%) 


 100.00% 
 99.99% 


 Average 
 Response 


 Interval 
 - 
 CLEC 


 (LENS) 


 (BST 
 Measure 


 Includes 
 Additional 


 2 
 Seconds) 


 [OSS-  1] 


 D.  1.3.1.1 
 RSAG, 
 b 
 y 


 TN/  Region( 


 seconds) 


 1440.12 
 0.91 
 1782.46 


 1.11 
 2.87 
 1.20 
 2.88 
 1.02 


 D.  1.3.1.2 
 RSAG, 
 b 
 y 


 TN/  Region( 


 seconds) 


 2.96 
 0.91 
 2.95 
 1.11 
 2.94 
 1.20 
 2.91 
 1.02 


 D.  1.3.2.1 
 RSAG, 
 b 
 y 
 ADDR/  Region( 


 seconds) 


 712.69 
 0.91 
 1204.18 


 1.02 
 2.99 
 1.10 
 3.03 
 0.93 


 D.  1.3.2.2 
 RSAG, 
 b 
 y 
 ADDR/  Region( 


 seconds) 


 4.82 
 0.91 
 4.86 
 1.02 
 4.77 
 1.10 
 4.76 
 0.93 


 D.  1.3.3.1 
 ATLAS/  Re 
 gion( 
 seconds) 


 1330.23 
 0.88 
 2.95 
 0.88 
 2.95 
 0.88 
 3.01 
 0.80 


 D.  1.3.3.2 
 ATLAS/  Re 
 gion( 
 seconds) 


 2.61 
 0.88 
 2.61 
 0.88 
 2.60 
 0.88 
 2.61 
 0.80 


 D.  1.3.4.1 
 DSAP/  Re 
 gion( 
 seconds) 


 2.68 
 0.53 
 2.70 
 0.57 
 2.71 
 0.53 
 2.71 
 0.52 


 D.  1.3.4.2 
 DSAP/  Re 
 gion( 
 seconds) 


 2.58 
 0.53 
 2.58 
 0.57 
 2.57 
 0.53 
 2.57 
 0.52 


 D.  1.3.5.1 
 CRSECSRL/  Re 


 gion( 
 seconds) 


 3.20 
 1.08 
 212.02 


 1.25 
 3.21 
 2.12 
 3.24 
 1.14 


 D.  1.3.5.2 
 CRSECSRL/  Re 


 gion( 
 seconds) 


 2.95 
 1.08 
 2.91 
 1.25 
 2.87 
 2.12 
 2.95 
 1.14 


 D.  1.3.6.1 
 COFFI/  Re 
 gion( 
 seconds) 


 4.46 
 0.63 
 4.40 
 0.67 
 4.60 
 0.63 
 4.35 
 0.64 


 D.  1.3.6.2 
 COFFI/  Re 
 gion( 
 seconds) 


 3.81 
 0.63 
 3.92 
 0.67 
 7.28 
 0.63 
 3.73 
 0.64 


 F-  31 
362
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 South 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 D.  1.3.7.1 
 PSIMS/  ORB/ 
 Region( 
 seconds) 


 4.46 
 0.03 
 4.40 
 0.04 
 4.60 
 0.04 
 4.35 
 0.04 


 D.  1.3.7.2 
 PSIMS/  ORB/ 
 Re 
 gion( 


 seconds) 


 3.81 
 0.03 
 3.92 
 0.04 
 7.28 
 0.04 
 3.73 
 0.04 


 Average 
 Response 


 Interval 
 - 
 CLEC 


 (TAG) 
 (BST 
 Measure 


 Includes 
 Additional 


 2 
 Seconds) 


 [OSS-  1] 


 D.  1.4.1.1 
 RSAG, 
 b 
 y 


 TN/  Region( 


 seconds) 


 1440.12 
 1.10 
 1782.46 


 1.31 
 2.87 
 1.60 
 2.88 
 1.52 


 D.  1.4.1.2 
 RSAG, 
 b 
 y 


 TN/  Region( 


 seconds) 


 2.96 
 1.10 
 2.95 
 1.31 
 2.94 
 1.60 
 2.91 
 1.52 


 D.  1.4.2.1 
 RSAG, 
 b 
 y 
 ADDR/  Region( 


 seconds) 


 712.69 
 1.62 
 1204.18 


 1.85 
 2.99 
 3.05 
 3.03 
 2.34 


 D.  1.4.2.2 
 RSAG, 
 b 
 y 
 ADDR/  Region( 


 seconds) 


 4.82 
 1.62 
 4.86 
 1.85 
 4.77 
 3.05 
 4.76 
 2.34 


 D.  1.4.4.1 
 ATLAS 
 - 
 DID/  Re 


 gion( 
 seconds) 


 1.48 
 2.18 
 1.76 
 1.37 


 D.  1.4.4.2 
 ATLAS 
 - 
 DID/  Re 


 gion( 
 seconds) 


 1.48 
 2.18 
 1.76 
 1.37 


 D.  1.4.5.1 
 ATLAS 
 - 
 TN/  Re 


 gion( 
 seconds) 


 1330.23 
 1.35 
 2.95 
 1.56 
 2.95 
 1.86 
 3.01 
 1.89 


 D.  1.4.5.2 
 ATLAS 
 - 
 TN/  Re 


 gion( 
 seconds) 


 2.61 
 1.35 
 2.61 
 1.56 
 2.60 
 1.86 
 2.61 
 1.89 


 D.  1.4.6.1 
 DSAP/  Re 
 gion( 
 seconds) 


 2.68 
 1.58 
 2.70 
 1.71 
 2.71 
 1.74 
 2.71 
 1.83 


 D.  1.4.6.2 
 DSAP/  Re 
 gion( 
 seconds) 


 2.58 
 1.58 
 2.58 
 1.71 
 2.57 
 1.74 
 2.57 
 1.83 


 D.  1.4.7.1 
 TAG/  Re 
 gion( 
 seconds) 


 3.20 
 1.75 
 212.02 


 2.15 
 3.21 
 2.51 
 3.24 
 2.85 


 D.  1.4.7.2 
 TAG/  Re 
 gion( 
 seconds) 


 2.95 
 1.75 
 2.91 
 2.15 
 2.87 
 2.51 
 2.95 
 2.85 


 OPERATIONS 
 SUPPORT 
 SYSTEMS 
 - 
 MAINTENANCE 


 AND 
 REPAIR 


 % 
 Interface 


 Availability 


 - 
 CLEC 


 [OSS-  3] 


 D.  2.2.1 
 CLEC 
 TAFI/  Re 


 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 D.  2.2.2 
 ECTA/  Re 
 gion(%) 


 100.00% 
 99.95% 
 100.00% 


 99.86% 


 % 
 Interface 


 Availability 


 - 
 BST 


 & 
 CLEC 


 [OSS-  3] 


 D.  2.3.1 
 CRIS/  Re 
 gion(%) 


 100.00% 
 100.00% 
 99.96% 
 99.99% 


 D.  2.3.2 
 LMOS 
 HOST/  Re 


 gion(%) 


 100.00% 
 100.00% 
 99.91% 
 100.00% 


 D.  2.3.3 
 LNP/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.91% 


 D.  2.3.4 
 MARCH/  Re 
 gion(%) 


 100.00% 
 99.99% 
 100.00% 
 100.00% 


 D.  2.3.5 
 OSPCM/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 D.  2.3.6 
 Predictor/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.92% 


 D.  2.3.7 
 SOCS/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.99% 


 Average 
 Response 


 Interval 
 <= 
 4 
 Seconds 


 [OSS-  4] 


 D.  2.4.1 
 CRIS/  Re 
 gion(%) 


 94.91% 
 94.17% 
 94.75% 
 94.83% 
 95.12% 
 94.99% 
 94.95% 
 94.66% 


 D.  2.4.2 
 DLETH/  Re 
 gion(%) 


 3.07% 
 3.22% 
 3.14% 
 4.03% 
 3.16% 
 4.59% 
 2.58% 
 3.67% 


 D.  2.4.3 
 DLR/  Re 
 gion(%) 


 4.30% 
 2.41% 
 4.07% 
 2.41% 
 4.03% 
 3.36% 
 4.47% 
 7.51% 


 D.  2.4.4 
 LMOS/  Re 
 gion(%) 


 99.67% 
 99.69% 
 99.63% 
 99.59% 
 99.60% 
 99.60% 
 99.61% 
 99.58% 


 D.  2.4.5 
 LMOSu 
 pd/  Region(%) 


 78.95% 
 70.39% 
 76.71% 
 65.38% 
 78.49% 
 66.19% 
 79.21% 
 66.24% 


 F-  32 
363
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 South 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 D.  2.4.6 
 LNP/  Region(%) 


 99.78% 
 99.37% 
 99.31% 
 99.09% 
 99.68% 
 99.19% 
 99.65% 
 98.81% 


 D.  2.4.7 
 MARCH/  Re 
 gion(%) 


 28.35% 
 33.16% 
 28.32% 
 26.44% 
 28.04% 
 31.69% 
 28.10% 
 29.64% 


 D.  2.4.8 
 OSPCM/  Re 
 gion(%) 


 23.94% 
 13.59% 
 27.25% 
 20.73% 
 31.23% 
 24.50% 
 33.15% 
 21.43% 


 D.  2.4.9 
 Predictor/  Re 
 gion(%) 


 15.78% 
 19.48% 
 15.03% 
 20.43% 
 13.82% 
 19.61% 
 12.71% 
 21.73% 


 D.  2.4.10 
 SOCS/  Re 
 gion(%) 


 99.84% 
 99.91% 
 99.83% 
 99.90% 
 99.85% 
 99.88% 
 99.81% 
 99.86% 


 D.  2.4.11 
 NIW/  Region(%) 


 82.97% 
 81.81% 
 84.38% 
 83.15% 
 84.01% 
 83.00% 
 82.83% 
 81.89% 


 Average 
 Response 


 Interval 
 <= 
 10 
 Seconds 


 [OSS-  4] 


 D.  2.5.1 
 CRIS/  Re 
 gion(%) 


 98.99% 
 99.34% 
 98.97% 
 99.34% 
 99.05% 
 99.46% 
 99.02% 
 99.39% 


 D.  2.5.2 
 DLETH/  Re 
 gion(%) 


 78.81% 
 86.16% 
 78.96% 
 87.92% 
 79.20% 
 85.30% 
 77.66% 
 82.58% 


 D.  2.5.3 
 DLR/  Re 
 gion(%) 


 77.94% 
 92.02% 
 77.45% 
 91.98% 
 76.65% 
 88.18% 
 71.08% 
 41.67% 


 D.  2.5.4 
 LMOS/  Re 
 gion(%) 


 99.81% 
 99.86% 
 99.79% 
 99.82% 
 99.79% 
 99.84% 
 99.80% 
 99.85% 


 D.  2.5.5 
 LMOSu 
 pd/  Region(%) 


 90.95% 
 83.33% 
 89.31% 
 80.59% 
 90.04% 
 80.25% 
 90.59% 
 80.53% 


 D.  2.5.6 
 LNP/  Re 
 gion(%) 


 99.93% 
 99.87% 
 99.54% 
 99.72% 
 99.81% 
 99.63% 
 99.83% 
 99.52% 


 D.  2.5.7 
 MARCH/  Re 
 gion(%) 


 28.35% 
 33.16% 
 28.32% 
 26.44% 
 28.04% 
 31.69% 
 28.10% 
 29.64% 


 D.  2.5.8 
 OSPCM/  Re 
 gion(%) 


 96.89% 
 96.12% 
 97.38% 
 95.12% 
 97.81% 
 97.35% 
 98.41% 
 95.83% 


 D.  2.5.9 
 Predictor/  Re 
 gion(%) 


 15.78% 
 19.48% 
 15.03% 
 20.43% 
 13.82% 
 19.61% 
 12.71% 
 21.73% 


 D.  2.5.10 
 SOCS/  Re 
 gion(%) 


 99.99% 
 99.99% 
 99.99% 
 99.98% 
 99.98% 
 100.00% 


 99.98% 
 100.00% 


 D.  2.5.11 
 NIW/  Region(%) 


 99.17% 
 98.96% 
 99.49% 
 99.33% 
 99.39% 
 99.21% 
 99.42% 
 99.25% 


 Average 
 Response 


 Interval 
 > 
 10 


 Seconds 


 [OSS-  4] 


 D.  2.6.1 
 CRIS/  Re 
 gion(%) 


 1.01% 
 0.66% 
 1.03% 
 0.66% 
 0.95% 
 0.54% 
 0.98% 
 0.61% 


 D.  2.6.2 
 DLETH/  Re 
 gion(%) 


 21.19% 
 13.84% 
 21.04% 
 12.08% 
 20.80% 
 14.70% 
 22.34% 
 17.42% 


 D.  2.6.3 
 DLR/  Re 
 gion(%) 


 22.06% 
 7.98% 
 22.55% 


 8.02% 
 23.35% 
 11.82% 
 28.92% 
 58.33% 


 D.  2.6.4 
 LMOS/  Re 
 gion(%) 


 0.19% 
 0.14% 
 0.21% 
 0.18% 
 0.21% 
 0.16% 
 0.20% 
 0.15% 


 D.  2.6.5 
 LMOSu 
 pd/  Region(%) 


 9.05% 
 16.67% 
 10.69% 
 19.41% 
 9.96% 
 19.75% 


 9.41% 
 19.47% 


 D.  2.6.6 
 LNP/  Re 
 gion(%) 


 0.07% 
 0.13% 
 0.46% 
 0.28% 
 0.19% 
 0.37% 
 0.17% 
 0.48% 


 D.  2.6.7 
 MARCH/  Re 
 gion(%) 


 71.65% 
 66.84% 
 71.68% 
 73.56% 
 71.96% 
 68.31% 
 71.90% 
 70.36% 


 D.  2.6.8 
 OSPCM/  Re 
 gion(%) 


 3.11% 
 3.88% 
 2.62% 
 4.88% 
 2.19% 
 2.65% 
 1.59% 
 4.17% 


 D.  2.6.9 
 Predictor/  Re 
 gion(%) 


 84.22% 
 80.52% 
 84.97% 
 79.57% 
 86.18% 
 80.39% 
 87.29% 
 78.27% 


 D.  2.6.10 
 SOCS/  Re 
 gion(%) 


 0.01% 
 0.01% 
 0.01% 
 0.02% 
 0.02% 
 0.00% 
 0.02% 
 0.00% 


 D.  2.6.11 
 NIW/  Region(%) 


 0.83% 
 1.04% 
 0.51% 
 0.67% 
 0.61% 
 0.79% 
 0.58% 
 0.75% 


 COLLOCATION 
 - 
 COLLOCATION  Average  Response  Time  [C- 


 1] 


 E.  1.1.2 
 Ph 
 ysical 


 Caged/  SC( 


 calendar 
 days) 


 9 
 4 
 10 


 4 
 1,2,3,4 


 F-  33 
364
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 South 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 E.  1.1.3 
 Physical 
 Cageless/  SC( 


 calendar 
 days) 


 7 
 15 


 18 


 1,2,3 


 Average 
 Arrangement 


 Time 
 [C-  2] 


 E.  1.2.1 
 Virtual-  Ordinar 


 y/  SC( 
 calendar 


 days) 


 E.  1.2.3 
 Physical 
 Caged-  Ordinary/ 


 SC( 
 calendar 


 days) 


 34 
 15 
 52 
 41 
 1,2,3,4 


 E.  1.2.4 
 Ph  ysical 
 Cageless-  Ordinary/ 


 SC( 
 calendar 


 days) 


 1 


 15 
 55 
 1,3,4 


 % 
 Due 


 Dates 


 Missed 


 [C-  3] 


 E.  1.3.1 
 Virtual/  SC 
 (%) 


 E.  1.3.2 
 Physical/  SC(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3,4 


 GENERAL 
 - 
 FLOW 


 THROUGH  %  Flow  Through  Service 


 Requests 
 [O-  3] 


 F.  1.1.1 
 Summar  y/ 
 Region(%) 


 85.28% 
 86.05% 
 84.50% 
 85.96% 


 F.  1.1.2 
 A 
 ggregate/  Region(%) 


 85.28% 
 86.05% 
 84.50% 
 85.96% 


 F.  1.1.3 
 Residence/  Re 
 gion(%) 


 86.49% 
 87.39% 
 86.74% 
 88.58% 


 F.  1.1.4 
 Business/  Re 
 gion(%) 


 73.55% 
 71.89% 
 69.54% 
 73.74% 


 F.  1.1.5 
 UNE/  Re 
 gion(%) 


 83.88% 
 84.78% 
 82.57% 
 83.84% 


 % 
 Flow 


 Through 


 Service 
 Requests 


 - 
 Achieved 


 [O-  3] 


 F.  1.2.1 
 Summar  y/ 
 Region(%) 


 75.79% 
 77.51% 
 76.58% 
 78.96% 


 F.  1.2.2 
 A 
 ggregate/  Region(%) 


 75.79% 
 77.51% 
 76.58% 
 78.96% 


 F.  1.2.3 
 Residence/  Re 
 gion(%) 


 79.16% 
 80.53% 
 79.88% 
 81.68% 


 F.  1.2.4 
 Business/  Re 
 gion(%) 


 50.63% 
 51.15% 
 51.58% 
 53.42% 


 F.  1.2.5 
 UNE/  Re 
 gion(%) 


 72.17% 
 74.87% 
 74.12% 
 77.27% 


 % 
 Flow 


 Through 


 Service 
 Requests 


 - 
 LNP 


 [O-  3] 


 F.  1.3.1 
 Summar  y/ 
 Region(%) 


 92.25% 
 92.59% 
 89.75% 
 83.63% 


 F.  1.3.2 
 A 
 ggregate/  Region(%) 


 92.25% 
 92.59% 
 89.75% 
 83.63% 


 GENERAL 
 - 
 PRE-  ORDERING  Loop  Makeup 


 Inquiry 
 (Manual) 


 [PO-  1] 


 F.  2.1 
 Loo 
 ps/  SC(%) 


 41.67% 
 50.00% 
 0.00% 
 0.00% 
 2,3,4 


 Loop 
 Makeup 


 Inquiry 
 (Electronic) 


 [PO-  2] 


 F.  2.2 
 Loo 
 ps/  SC(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 GENERAL 
 - 
 ORDERING  Average  Speed 


 of 
 Answer 


 [O-  12] 


 F.  4.1 
 Re 
 gion( 


 seconds) 


 141.64 
 30.33 
 137.90 


 28.63 
 194.86 


 35.16 
 259.48 


 58.19 


 GENERAL 
 - 
 MAINTENANCE 


 CENTER 


 F-  34 
365
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 South 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 Average 
 Answer 
 Time 
 [M&  R- 


 6] 


 F.  5.1 
 Re 
 gion( 


 seconds) 


 43.10 
 26.35 
 41.00 
 23.60 
 64.68 
 25.99 
 52.80 
 28.04 


 GENERAL 
 - 
 OPERATOR 


 SERVICES 
 (TOLL) 


 Average 
 Speed 
 to 
 Answer 


 [OS-  1] 


 F.  6.1 
 SC 
 (seconds) 


 2.50 
 2.31 
 2.24 
 2.44 


 % 
 Answered 


 in 
 10 
 seconds 


 [OS-  2] 


 F.  6.2 
 SC 
 (%) 


 92.30% 
 93.20% 
 93.70% 
 92.80% 


 GENERAL 
 - 
 DIRECTORY 


 ASSISTANCE 
 Average 
 Speed 
 to 
 Answer 


 [DA-  1] 


 F.  7.1 
 SC 
 (seconds) 


 7.31 
 7.74 
 6.88 
 6.68 


 % 
 Answered 


 in 
 12 
 seconds 


 [DA-  2] 


 F.  7.2 
 SC 
 (%) 


 78.00% 
 76.30% 
 80.00% 
 80.80% 


 GENERAL 
 - 
 BILLING  Usage  Data 


 Delivery 
 Accuracy 


 [B-  3] 


 F.  9.1 
 Re 
 gion(%) 


 100.00% 
 100.00% 
 97.75% 
 100.00% 


 95.22% 
 100.00% 
 100.00% 
 100.00% 


 Usage 
 Data 
 Delivery 


 Timeliness 


 [B-  5] 


 F.  9.2 
 Re 
 gion(%) 


 98.37% 
 93.14% 
 75.41% 
 94.80% 
 94.93% 
 97.64% 
 99.33% 
 99.38% 


 Usage 
 Data 
 Delivery 


 Completeness 


 [B-  4] 


 F.  9.3 
 Re 
 gion(%) 


 99.38% 
 99.89% 
 99.77% 
 99.54% 
 97.21% 
 99.95% 
 99.92% 
 99.91% 


 Mean 
 Time 
 to 
 Deliver 


 Usage 
 [B-  6] 


 F.  9.4 
 Re 
 gion( 


 days) 


 3.49 
 3.05 
 6.85 
 3.29 
 4.34 
 2.52 
 3.24 
 2.43 


 Recurring 
 Charge 
 Completeness 


 [B-  7] 


 F.  9.5.1 
 Resale/  SC 
 (%) 


 68.35% 
 98.17% 
 77.68% 
 98.03% 
 83.68% 
 99.30% 
 81.33% 
 99.03% 


 F.  9.5.2 
 UNE/  SC 
 (%) 


 99.22% 
 99.24% 
 99.47% 
 98.94% 


 F.  9.5.3 
 Interconnection/  SC 


 (%) 


 71.82% 
 38.65% 
 99.94% 
 100.00% 


 Non-  Recurring 
 Charge 
 Completeness 


 [B-  8] 


 F.  9.6.1 
 Resale/  SC 
 (%) 


 77.66% 
 93.86% 
 78.80% 
 98.70% 
 80.89% 
 98.42% 
 76.68% 
 98.73% 


 F.  9.6.2 
 UNE/  SC 
 (%) 


 97.19% 
 99.17% 
 98.93% 
 99.00% 


 F.  9.6.3 
 Interconnection/  SC 


 (%) 


 75.47% 
 98.70% 
 96.47% 
 98.52% 


 GENERAL 
 - 
 CHANGE 


 MANAGEMENT  %  Software  Release  Notices  Sent 


 On 
 Time 


 [CM-  1] 


 F.  10.1 
 SC 
 (%) 


 100.00% 
 100.00% 


 2,3 


 % 
 Change 


 Management 


 Documentation 


 Sent 
 On 
 Time 


 [CM-  3A] 


 F-  35 
366
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 South 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 F.  10.3 
 SC(%) 


 100.00% 
 100.00% 
 1,4 


 % 
 Change 


 Management 


 Documentation 


 (Defects, 
 Corrections, 


 etc.) 
 Sent 
 On 
 Time 


 [CM-  3B] 


 F.  10.4 
 SC 
 (%) 


 77.78% 
 2 


 Average 
 Documentation 


 Release 
 Delay 
 Days 
 [CM-  4] 


 F.  10.5 
 SC 
 (average)  %  CLEC  Interface 


 Outages 
 Sent 
 within 


 15 
 Minutes 


 [CM-  5] 


 F.  10.6 
 SC 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 GENERAL 
 - 
 NEW 


 BUSINESS 


 REQUESTS 


 % 
 New 


 Business 


 Requests 
 Processed 


 within 
 30 
 Business 


 Days 
 [BFR-  1] 


 F.  11.1 
 Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 % 
 Quotes 


 Provided 


 within 
 X 
 Business 


 Days 
 [BFR-  2A] 


 F.  11.2.1 
 Re 
 gion(%) 


 100.00% 
 100.00% 
 1,3 


 F.  11.2.3 
 Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 GENERAL 
 - 
 ORDERING  Acknowledgement 


 Message 
 Timeliness 


 [O-  1] 


 F.  12.1.1 
 EDI/  Re 
 gion(%) 


 99.97% 
 99.99% 
 100.00% 
 100.00% 


 F.  12.1.2 
 TAG/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 Acknowledgement 
 Message 
 Completeness 


 [O-  2] 


 F.  12.2.1 
 EDI/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.62% 


 F.  12.2.2 
 TAG/  Re 
 gion(%) 


 100.00% 
 100.00% 
 99.99% 
 100.00% 


 GENERAL 
 - 
 DATABASE 


 UPDATES 
 Average 
 Database 


 Update 
 Interval 


 [D-  1] 


 F.  13.1.1 
 LIDB/  SC 
 (hours) 


 0.48 
 0.48 
 0.51 
 0.51 
 0.41 
 0.41 
 1.40 
 1.40 


 F.  13.1.2 
 Director  y 
 Listings/  SC( 


 hours) 


 0.10 
 0.10 
 0.09 
 0.09 
 0.10 
 0.10 
 0.11 
 0.11 


 F.  13.1.3 
 Director  y 
 Assistance/  SC( 


 hours) 


 3.77 
 3.77 
 4.32 
 4.32 
 3.80 
 3.80 
 5.83 
 5.83 


 % 
 Update 


 Accuracy 


 [D-  2] 


 F.  13.2.1 
 LIDB/  SC 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 93.48% 


 F.  13.2.2 
 Director  y 
 Listings/  SC(%) 


 99.38% 
 99.03% 
 99.79% 
 99.35% 


 F.  13.2.3 
 Director  y 
 Assistance/  SC(%) 


 100.00% 
 100.00% 
 97.87% 
 99.19% 


 % 
 NXXs 


 / 
 LRNs 


 Loaded 


 by 
 LERG 


 Effective 


 Date 
 [D-  3] 


 F.  13.3 
 Re 
 gion(%) 


 96.77% 
 100.00% 
 100.00% 
 98.41% 


 GENERAL 
 - 
 NETWORK 


 OUTAGE 
 NOTIFICATION 


 Mean 
 Time 
 to 
 Notify 


 CLEC 
 of 
 Major 


 Network 


 Outages 
 [M&  R- 
 7]  F-  36 
367
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 South 
 Carolina 


 Performance 


 Metric 
 Data 


 March 
 April 
 May 
 June 


 F.  14.1 
 Region(  minutes) 


 739 
 218 


 0 
 0 
 154 


 123 
 791 
 602 
 1,3,4 


 Abbreviations:  blank  cell  =  no  data 
 available 
 Notes:  1  =  Sample 
 Size 
 under 


 10 
 in 
 March 


 2 
 = 
 Sample 


 Size 
 under 


 10 
 in 
 April 


 2 
 = 
 Sample 


 Size 
 under 


 10 
 in 
 May 


 4 
 = 
 Sample 


 Size 
 under 


 10 
 in 
 June 


 F-  37 
368
 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Appendix 
 G 


 Georgia 
 Performance 


 Metrics 


 Except 
 where 
 noted, 
 the 
 data 


 included 


 here 
 is 
 taken 


 from 
 the 
 Georgia 


 Monthly 


 State 
 Summary 


 (MSS) 
 Reports 


 provided 


 by 
 BellSouth, 


 calculated 
 according 
 to 
 the 


 Georgia 


 Service 
 Quality 
 Measurement 


 (SQM) 
 business 


 rules. 
 This 
 table 


 is 
 provided 


 as 
 a 
 reference 


 tool 
 for 


 the 
 convenience 


 of 
 the 


 reader. 


 No 
 conclusions 


 are 
 to 
 be 
 drawn 


 from 
 the 
 raw 


 data 
 contained 


 in 
 this 


 table. 


 Our 
 analysis 


 is 
 based 


 on 
 the 


 totality 
 of 
 the 
 circumstances, 


 such 
 that 
 we 
 may 


 use 
 non-  metric 


 evidence, 
 and 
 may 


 rely 
 more 


 heavily 


 on 
 some 


 metrics 


 more 
 than 


 others, 
 in 
 making 


 our 
 determination. 


 The 
 inclusion 


 of 
 these 


 particular 


 metrics 
 in 
 this 


 table 


 does 
 not 
 necessarily 


 mean 
 that 
 we 
 relied 


 o  n 


 all 
 of 
 these 


 metrics, 


 or 
 that 


 other 


 metrics 


 may 
 not 
 also 


 be 
 important 


 in 
 our 


 analysis. 


 Some 
 metrics 


 that 
 we 
 have 


 relied 


 on 
 in 
 the 


 past 


 and 
 may 


 rely 
 on 
 for 


 a 
 future 


 application 


 were 
 not 
 included 


 here 
 because 


 there 
 was 
 no 
 data 


 provided 


 for 
 them 


 (usually 


 either 
 because 


 there 
 was 
 no 
 activity, 


 or 
 because 


 the 
 metrics 


 are 
 still 


 under 


 development). 


 Metrics 
 with 
 no 
 retail 


 analog 


 provided 


 are 
 usually 


 compared 


 with 
 a 
 benchmark. 


 Note 
 that 
 for 
 some 


 metrics 


 during 
 the 
 period 


 provided 
 there 
 may 
 be 
 changes 


 in 
 the 


 metric 


 definition, 


 or 
 changes 


 in 
 the 


 retail 


 analog 


 applied, 


 making 
 it 
 difficult 


 to 
 compare 


 data 


 Note: 
 All 
 data 


 was 
 calculated 


 using 
 BellSouth's 


 data 
 platform 


 PMAP 
 4.0. 
 The 
 March 


 data 
 in 
 this 


 appendix 


 were 
 not 
 taken 


 from 
 the 


 MSS 
 reports, 


 which 
 for 
 that 


 month 


 were 
 calculated 


 using 
 PMAP 


 2.6, 
 but 
 instead 


 were 
 calculated 


 using 
 PMAP 


 4.0 
 by 
 BellSouth. 


 This 


 data 
 also 
 conforms 


 to 
 the 


 Georgia 


 Service 
 Quality 
 Measurement 


 business 
 rules 
 that 
 govern 


 the 
 regular 


 MSS 
 reports. 
369
 Metric  No. 
 SQM 
 No. 
 Metric 


 Name 


 Metric  No. 
 SQM 
 No. 
 Metric 


 Name 


 RESALE 
 A.  3.5 
 M&  R- 
 5 
 Out 


 of 
 Service 


 > 
 24 


 hours 


 Ordering 
 Billing 
 A.  1.1 
 O-  7 


 % 
 Rejected 


 Service 
 Requests 


  
 Mech. 


 A.  4.1 
 B-  1 


 Invoice 
 Accuracy 


 A.  1.2 
 O-  7 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Partially 


 Mech. 


 A.  4.2 
 B-  2 


 Mean 
 Time 
 to 
 Deliver 


 Invoices 


  
 CRIS 


 A.  1.3 
 O-  7 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Non-  Mech. 


 UNBUNDLED 
 NETWORK 
 ELEMENTS 


 A.  1.4 
 O-  8 


 Reject 
 Interval 


  
 Mech. 


 Ordering 


 A.  1.7 
 O-  8 


 Reject 
 Interval 


 - 
 Partially 


 Mech. 
  
 10 


 hours 


 B.  1.1 
 O-  7/ 
 O-  13 


 % 
 Rejected 


 Service 
 Requests 


  
 Mech. 


 A.  1.8 
 O-  8 


 Reject 
 Interval 


 - 
 Non-  Mech. 


 B.  1.2 
 O-  7/ 
 O-  13 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Partially 


 Mech. 


 A.  1.9 
 O-  9 


 FOC 
 Timeliness 


  
 Mech. 


 B.  1.3 
 O-  7/ 
 O-  13 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Non-  Mech. 


 A.  1.12 
 O-  9 


 FOC 
 Timeliness 


 - 
 Partially 


 Mech. 
 - 
 10 


 hours 


 B.  1.4 
 O-  8/ 
 O-  14 


 Reject 


 Interval 


  
 Mech. 


 A.  1.13 
 O-  9 


 FOC 
 Timeliness 


 - 
 Non-  Mech. 


 B.  1.7 
 O-  8/ 
 O-  14 


 Reject 


 Interval 


 - 
 Partially 


 Mech. 
 - 
 10 


 hours 


 A.  1.14 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Mech. 


 B.  1.8 
 O-  8/ 
 O-  14 


 Reject 


 Interval 


 - 
 Non-  Mech. 


 A.  1.15 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Partially 


 Mech. 


 B.  1.9 
 O-  9/ 
 O-  15 


 FOC 
 Timeliness 


  
 Mech. 


 A.  1.16 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Non-  Mech. 


 B.  1.12 
 O-  9/ 
 O-  15 


 FOC 
 Timeliness 


 - 
 Partially 


 Mech. 
 - 
 10 


 hours 


 Provisioning 
 B.  1.13 
 O-  9/ 
 O-  15 


 FOC 
 Timeliness 


 - 
 Non-  Mech. 


 A.  2.1 
 P-  4 


 Order 
 Completion 


 Interval 


 B.  1.14 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


  
 Mech. 


 A.  2.4 
 P-  2 


 % 
 Jeopardies 


 - 
 Mech. 


 B.  1.15 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


  
 Partially 


 Mech. 


 A.  2.5 
 P-  2 


 % 
 Jeopardies 


 - 
 Non-  Mech. 


 B.  1.16 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


  
 Non-  Mech. 


 A.  2.7 
 P-  2 


 Average 
 Jeopardy 
 Notice 
 Interval 


 - 
 Mech. 


 Provisioning 


 A.  2.8 
 P-  2 


 Average 
 Jeopardy 
 Notice 
 Interval 


 - 
 Non-  Mech. 


 B.  2.1 
 P-  4 


 Order 
 Completion 


 Interval 


 A.  2.9 
 P-  2 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Mech. 


 B.  2.2 
 P-  4 


 Order 
 Completion 


 Interval 
 within 
 X 
 days 


 - 
 xDSL 


 A.  2.10 
 P-  2 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Non-  Mech. 


 B.  2.5 
 P-  2 


 % 
 Jeopardies 


  
 Mech. 


 A.  2.11 
 P-  3 


 % 
 Missed 


 Installation 


 Appointments 


 B.  2.6 
 P-  2 


 % 
 Jeopardies 


 - 
 Non-  Mech. 


 A.  2.12 
 P-  9 


 % 
 Provisioning 


 Troubles 
 within 
 30 
 Days 


 B.  2.8 
 P-  2 


 Average 
 Jeopardy 
 Notice 
 Interval 


 - 
 Mech. 


 A.  2.14 
 P-  5 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Mech. 


 B.  2.9 
 P-  2 


 Average 
 Jeopardy 
 Notice 
 Interval 


 - 
 Non-  Mech. 


 A.  2.15 
 P-  5 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Non-  Mech. 


 B.  2.10 
 P-  2 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Mech. 


 A.  2.25 
 P-  11 


 Service 
 Order 
 Accuracy 


 B.  2.11 
 P-  2 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Non-  Mech. 


 Maintenance 
 and 
 Repair 


 B.  2.12 
 P-  7 
 Coordinated 


 Customers 
 Conversions 


 A.  3.1 
 M&  R- 
 1 
 Missed 


 Repair 
 Appointments 


 B.  2.13 
 P-  7A 


 % 
 Hot 


 Cuts 


 > 
 15 


 minutes 


 Early 


 A.  3.2 
 M&  R- 
 2 
 Customer 


 Trouble 
 Report 
 Rate 


 B.  2.14 
 P-  7A 


 Hot 
 Cut 
 Timeliness 


 A.  3.3 
 M&  R- 
 3 
 Maintenance 


 Average 
 Duration 


 B.  2.15 
 P-  7A 


 % 
 Hot 


 Cuts 


 > 
 15 


 minutes 


 Late 


 A.  3.4 
 M&  R- 
 4 
 % 
 Repeat 


 Troubles 


 within 
 30 
 Days 


 B.  2.16 
 P-  7B 


 Average 
 Recovery 


 Time 
  
 CCC 


 PERFORMANCE 
 METRIC 
 CATEGORIES 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 G-  2 
370
 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Metric  No. 
 SQM 
 No. 
 Metric 


 Name 


 Metric  No. 
 SQM 
 No. 
 Metric 


 Name 


 B.  2.17 
 P-  7C 


 % 
 Provisioning 


 Troubles 
 within 
 7 
 Days 


 - 
 Hot 


 Cuts 


 C.  3.3 
 M&  R- 
 3 
 Maintenance 


 Average 
 Duration 


 B.  2.18 
 P-  3/ 
 P-  12 


 % 
 Missed 


 Installation 


 Appointments 


 C.  3.4 
 M&  R- 
 4 
 % 
 Repeat 


 Troubles 


 within 
 30 
 Days 


 B.  2.19 
 P-  9 


 % 
 Provisioning 


 Troubles 
 within 
 30 
 Days 


 C.  3.5 
 M&  R- 
 5 
 Out 


 of 
 Service 


 > 
 24 


 hours 


 B.  2.21 
 P-  5 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Mech. 


 Billing 


 B.  2.22 
 P-  5 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Non-  Mech. 


 C.  4.1 
 B-  1 


 Invoice 
 Accuracy 


 B.  2.34 
 P-  11 


 Service 
 Order 
 Accuracy 


 C.  4.2 
 B-  2 


 Mean 
 Time 
 to 
 Deliver 


 Invoices 


 - 
 CABS 


 Maintenance 
 and 
 Repair 


 Trunk 
 Blocking 


 B.  3.1 
 M&  R- 
 1 
 Missed 


 Repair 
 Appointments 


 C.  5.1 
 TGP-  1 


 Trunk 
 Group 
 Performance 


 - 
 Aggregate 


 B.  3.2 
 M&  R- 
 2 
 Customer 


 Trouble 
 Report 
 Rate 


 OPERATIONS 
 SUPPORT 
 SYSTEMS 


 B.  3.3 
 M&  R- 
 3 
 Maintenance 


 Average 
 Duration 


 Pre-  Ordering 


 B.  3.4 
 M&  R- 
 4 
 % 
 Repeat 


 Troubles 


 within 
 30 
 Days 


 D.  1.1 
 OSS-  2 


 % 
 Interface 


 Availability 


 - 
 CLEC 


 B.  3.5 
 M&  R- 
 5 
 Out 


 of 
 Service 


 > 
 24 


 hours 


 D.  1.2 
 OSS-  2 


 % 
 Interface 


 Availability 


 - 
 BST 


 & 
 CLEC 


 Billing 
 D.  1.3 
 OSS-  1 


 Average 
 Response 


 Interval 
 - 
 CLEC 


 (LENS) 


 B.  4.1 
 B-  1 


 Invoice 
 Accuracy 


 D.  1.4 
 OSS-  1 


 Average 
 Response 


 Interval 
 - 
 CLEC 


 (TAG) 


 B.  4.2 
 B-  2 


 Mean 
 Time 
 to 
 Deliver 


 Invoices 


 - 
 CRIS 


 Maintenance 
 and 
 Repair 


 LOCAL 
 INTERCONNECTION 


 TRUNKS 


 D.  2.1 
 OSS-  3 


 % 
 Interface 


 Availability 


 - 
 BST 


 Ordering 
 D.  2.2 
 OSS-  3 


 % 
 Interface 


 Availability 


 - 
 CLEC 


 C.  1.1 
 O-  7 


 % 
 Rejected 


 Service 
 Requests 


 D.  2.3 
 OSS-  3 


 % 
 Interface 


 Availability 


 - 
 BST 


 & 
 CLEC 


 C.  1.2 
 O-  8 


 Reject 
 Interval 


 D.  2.4 
 OSS-  4 


 Average 
 Response 


 Interval 
 <= 
 4 
 Seconds 


 C.  1.3 
 O-  9 


 FOC 
 Timeliness 


 D.  2.5 
 OSS-  4 


 Average 
 Response 


 Interval 
 <= 
 10 
 Seconds 


 C.  1.4 
 O-  11 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 D.  2.6 
 OSS-  4 


 Average 
 Response 


 Interval 
 > 
 10 


 Seconds 


 Provisioning 
 COLLOCATION 
 C.  2.1 
 P-  4 


 Order 
 Completion 


 Interval 


 Collocation 


 C.  2.2 
 P-  1 


 Held 
 Orders 


 E.  1.1 
 C-  1 


 Average 
 Response 


 Time 


 C.  2.3 
 P-  2 


 % 
 Jeopardies 


 E.  1.2 
 C-  2 


 Average 
 Arrangement 


 Time 


 C.  2.5 
 P-  3 


 % 
 Missed 


 Installation 


 Appointments 


 E.  1.3 
 C-  3 


 % 
 Due 


 Dates 


 Missed 


 C.  2.6 
 P-  9 


 % 
 Provisioning 


 Troubles 
 within 
 30 
 Days 


 GENERAL 


 C.  2.7 
 P-  5 


 Average 
 Completion 


 Notice 
 Interval 


 Flow 
 Through 


 C.  2.8 
 P-  10 


 Total 
 Service 


 Order 
 Cycle 
 Time 


 F.  1.1 
 O-  3 


 % 
 Flow 


 Through 


 Service 
 Requests 


 C.  2.10 
 P-  6 


 % 
 Completions 


 w/  o 
 Notice 


 or 
 < 
 24 


 hours 


 F.  1.2 
 O-  3 


 % 
 Flow 


 Through 


 Service 
 Requests 


 - 
 Achieved 


 C.  2.11 
 P-  11 


 Service 
 Order 
 Accuracy 


 F.  1.3 
 O-  3 


 % 
 Flow 


 Through 


 Service 
 Requests 


 - 
 LNP 


 Maintenance 
 and 
 Repair 


 Pre-  Ordering 


 C.  3.1 
 M&  R- 
 1 
 Missed 


 Repair 
 Appointments 


 F.  2.1 
 PO-  1 


 Loop 
 Makeup 


 Inquiry 
 (Manual) 


 C.  3.2 
 M&  R- 
 2 
 Customer 


 Trouble 
 Report 
 Rate 


 F.  2.2 
 PO-  2 


 Loop 
 Makeup 


 Inquiry 
 (Electronic) 


 G-  3 
371
 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Metric  No. 
 SQM 
 No. 
 Metric 


 Name 


 Metric  No. 
 SQM 
 No. 
 Metric 


 Name 


 Ordering 
 Database 
 Updates 


 F.  4.1 
 O-  12 


 Average 
 Speed 
 of 
 Answer 


 F.  13.1 
 D-  1 


 Average 
 Database 
 Update 
 Interval 


 Maintenance 
 Center 


 F.  13.2 
 D-  2 


 % 
 Update 


 Accuracy 


 F.  5.1 
 M&  R- 
 6 
 Average 


 Answer 
 Time 


 F.  13.3 
 D-  3 


 % 
 NXXs 


 / 
 LRNs 


 Loaded 


 by 
 LERG 


 Effective 


 Date 


 Operator 
 Services 
 (Toll) 


 Network 
 Outage 
 Notification 


 F.  6.1 
 OS-  1 


 Average 
 Speed 
 to 
 Answer 


 F.  14.1 
 M&  R- 
 7 
 Mean 


 Time 
 to 
 Notify 


 CLEC 
 of 
 Major 


 Network 


 Outages 


 F.  6.2 
 OS-  2 


 % 
 Answered 


 in 
 10 
 seconds 


 Directory 
 Assistance  F.  7.1  DA-  1  Average 


 Speed 
 to 
 Answer 


 F.  7.2 
 DA-  2 


 % 
 Answered 


 in 
 10 
 seconds 


 Billing  F.  9.1 
 B-  3 


 Usage 
 Data 
 Delivery 


 Accuracy 


 F.  9.2 
 B-  5 


 Usage 
 Data 
 Delivery 


 Timeliness 


 F.  9.3 
 B-  4 


 Usage 
 Data 
 Delivery 


 Completeness 


 F.  9.4 
 B-  6 


 Mean 
 Time 
 to 
 Deliver 


 Usage 


 F.  9.5 
 B-  7 


 Recurring 
 Charge 
 Completeness 


 F.  9.6 
 B-  8 


 Non-  Recurring 


 Charge 
 Completeness 


 Change 
 Management  F.  10.1  CM-  1  % 


 Software 
 Release 
 Notices 
 Sent 
 On 
 Time 


 F.  10.2 
 CM-  2 


 Average 
 Software 
 Release 
 Notice 
 Delay 
 Days 


 F.  10.3 
 CM-  3A 


 % 
 Change 


 Management 


 Documentation 


 Sent 
 On 
 Time 


 F.  10.4 
 CM-  3B 


 % 
 Change 


 Management 


 Documentation 


 (Defects, 


 Corrections, 
 etc.  ) 
 Sent 
 On 
 Time 


 F.  10.5 
 CM-  4 


 Average 
 Documentation 


 Release 
 Delay 
 Days 


 F.  10.6 
 CM-  5 


 % 
 CLEC 


 Interface 


 Outages 
 Sent 
 within 


 15 
 Minutes 


 New 
 Business 


 Requests 


 F.  11.1 
 BFR-  1 


 % 
 New 


 Business 


 Requests 
 Processed 


 in 
 30 


 Bus. 


 Days 


 F.  11.2 
 BFR-  2A 


 % 
 Quotes 


 Provided 


 within 
 X 
 Business 


 Days 


 Ordering  F.  12.1 
 O-  1 
 Acknowledgement 


 Message 
 Timeliness 


 F.  12.2 
 O-  2 
 Acknowledgement 


 Message 
 Completeness 


 G-  4 
372
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 RESALE 
 - 
 ORDERING  %  Rejected 


 Service 
 Requests 


 - 
 Mechanized 


 [O-  7] 


 A.  1.1.1 
 Residence/  GA 
 (%) 


 10.92% 
 10.20% 
 12.39% 
 9.81% 


 A.  1.1.2 
 Business/  GA 
 (%) 


 13.01% 
 18.81% 
 17.69% 
 24.45% 


 A.  1.1.4 
 PBX/  GA 
 (%) 
 % 
 Rejected 


 Service 
 Requests 


 - 
 Partially 


 Mechanized 


 [O-  7] 


 A.  1.2.1 
 Residence/  GA 
 (%) 


 18.94% 
 21.47% 
 26.03% 
 35.71% 


 A.  1.2.2 
 Business/  GA 
 (%) 


 54.48% 
 52.56% 
 58.24% 
 60.25% 


 A.  1.2.4 
 PBX/  GA 
 (%) 


 100.00% 
 100.00% 
 50.00% 
 60.00% 
 1,2,3,4 


 A.  1.2.6 
 ISDN/  GA 
 (%) 


 0.00% 


 1 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Non-  Mechanized 


 [O-  7] 


 A.  1.3.1 
 Residence/  GA 
 (%) 


 40.72% 
 33.81% 
 44.88% 
 52.82% 


 A.  1.3.2 
 Business/  GA 
 (%) 


 51.77% 
 50.69% 
 62.57% 
 60.16% 


 A.  1.3.3 
 Desi 
 gn 
 (Specials)/  GA(%) 


 38.37% 
 31.25% 
 26.81% 
 32.06% 


 A.  1.3.4 
 PBX/  GA 
 (%) 


 52.73% 
 30.30% 
 44.83% 
 53.85% 


 A.  1.3.5 
 Centrex/  GA 
 (%) 


 42.86% 
 75.00% 
 51.65% 
 48.94% 
 2 


 A.  1.3.6 
 ISDN/  GA 
 (%) 


 33.33% 
 15.79% 
 45.45% 
 27.27% 


 Reject 
 Interval 


 - 
 Mechanized 


 [O-  8] 


 A.  1.4.1 
 Residence/  GA 
 (%) 


 95.68% 
 97.27% 
 96.67% 
 97.06% 


 A.  1.4.2 
 Business/  GA 
 (%) 


 95.89% 
 91.58% 
 95.06% 
 93.41% 


 Reject 
 Interval 


 - 
 Partially 


 Mechanized 


 - 
 10 


 hours 


 [O-  8] 


 A.  1.7.1 
 Residence/  GA 
 (%) 


 90.36% 
 91.75% 
 87.76% 
 94.12% 


 A.  1.7.2 
 Business/  GA 
 (%) 


 96.54% 
 95.72% 
 95.03% 
 99.33% 


 A.  1.7.4 
 PBX/  GA 
 (%) 


 0.00% 
 50.00% 


 0.00% 
 33.33% 
 1,2,3,4 


 Reject 
 Interval 


 - 
 Non-  Mechanized 


 [O-  8] 


 A.  1.8.1 
 Residence/  GA 
 (%) 


 100.00% 
 98.78% 
 99.16% 
 96.81% 


 A.  1.8.2 
 Business/  GA 
 (%) 


 99.33% 
 99.55% 
 99.08% 
 98.75% 


 A.  1.8.3 
 Desi 
 gn 
 (Specials)/  GA(%) 


 98.61% 
 95.24% 
 94.59% 
 100.00% 


 A.  1.8.4 
 PBX/  GA 
 (%) 


 100.00% 
 90.00% 
 76.92% 
 92.86% 


 A.  1.8.5 
 Centrex/  GA 
 (%) 


 100.00% 
 100.00% 
 94.00% 
 88.46% 
 1,2 


 A.  1.8.6 
 ISDN/  GA 
 (%) 


 100.00% 
 100.00% 
 90.91% 
 100.00% 
 1,2,4 


 FOC 
 Timeliness 


 - 
 Mechanized 


 [O-  9] 


 A.  1.9.1 
 Residence/  GA 
 (%) 


 99.63% 
 99.81% 
 99.56% 
 99.47% 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Georgia 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 G-  5 
373
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Georgia 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 A.  1.9.2 
 Business/  GA(%) 


 99.78% 
 99.26% 
 99.73% 
 99.64% 


 A.  1.9.4 
 PBX/  GA 
 (%) 
 FOC 
 Timeliness 


 - 
 Partially 


 Mechanized 


 - 
 10 


 hours 


 [O-  9] 


 A.  1.12.1 
 Residence/  GA 
 (%) 


 89.81% 
 88.52% 
 82.64% 
 85.54% 


 A.  1.12.2 
 Business/  GA 
 (%) 


 88.56% 
 91.48% 
 88.36% 
 92.17% 


 A.  1.12.4 
 PBX/  GA 
 (%) 


 0.00% 
 0.00% 
 0.00% 
 1,3,4 


 A.  1.12.6 
 ISDN/  GA 
 (%) 


 0.00% 


 1 


 FOC 
 Timeliness 


 - 
 Non-  Mechanized 


 [O-  9] 


 A.  1.13.1 
 Residence/  GA 
 (%) 


 100.00% 
 99.65% 
 99.63% 
 98.09% 


 A.  1.13.2 
 Business/  GA 
 (%) 


 100.00% 
 100.00% 
 99.16% 
 100.00% 


 A.  1.13.3 
 Desi 
 gn 
 (Specials)/  GA(%) 


 98.85% 
 94.67% 
 96.59% 
 100.00% 


 A.  1.13.4 
 PBX/  GA 
 (%) 


 84.21% 
 88.24% 
 88.24% 
 90.91% 


 A.  1.13.5 
 Centrex/  GA 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2 


 A.  1.13.6 
 ISDN/  GA 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 4 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Mechanized 


 [O-  11] 


 A.  1.14.1.1 
 Residence/  EDI/ 


 GA  (%) 


 100.00% 
 96.10% 
 96.84% 
 100.00% 


 A.  1.14.1.2 
 Residence/  TAG/ 


 GA  (%) 


 99.48% 
 99.59% 
 99.10% 
 99.92% 


 A.  1.14.2.1 
 Business/  EDI/ 
 GA 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 A.  1.14.2.2 
 Business/  TAG/ 


 GA 
 (%) 


 94.12% 
 97.34% 
 96.72% 
 99.69% 


 A.  1.14.4.2 
 PBX/  TAG/ 
 GA 
 (%) 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Partially 


 Mechanized 


 [O-  11] 


 A.  1.15.1.1 
 Residence/  EDI/ 


 GA  (%) 


 100.00% 
 98.29% 
 97.20% 
 99.06% 


 A.  1.15.1.2 
 Residence/  TAG/ 


 GA  (%) 


 99.72% 
 99.77% 
 99.87% 
 99.78% 


 A.  1.15.2.1 
 Business/  EDI/ 
 GA 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 A.  1.15.2.2 
 Business/  TAG/ 


 GA 
 (%) 


 99.50% 
 100.00% 
 100.00% 
 100.00% 


 A.  1.15.4.2 
 PBX/  TAG/ 
 GA 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 A.  1.15.6.2 
 ISDN/  TAG/ 
 GA 
 (%) 


 100.00% 


 1 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Non-  Mechanized 


 [O-  11] 


 A.  1.16.1 
 Residence/  GA 
 (%) 


 97.60% 
 96.91% 
 97.44% 
 95.55% 


 A.  1.16.2 
 Business/  GA 
 (%) 


 95.04% 
 98.62% 
 96.71% 
 96.48% 


 A.  1.16.3 
 Desi 
 gn 
 (Specials)/  GA(%) 


 93.60% 
 96.09% 
 86.23% 
 98.47% 


 A.  1.16.4 
 PBX/  GA 
 (%) 


 90.91% 
 96.97% 
 96.55% 
 96.15% 


 A.  1.16.5 
 Centrex/  GA 
 (%) 


 92.86% 
 100.00% 


 87.91% 
 93.62% 
 2 


 G-  6 
374
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Georgia 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 A.  1.16.6 
 ISDN/  GA(%) 


 100.00% 
 94.74% 
 100.00% 


 90.91% 


 RESALE 
 - 
 PROVISIONING  Order  Completion 


 Interval 
 [P-  4] 


 A.  2.1.1.1.1 
 Residence/<  10 


 circuits/  Dis 
 patch/  GA( 
 days) 


 5.39 
 5.12 
 5.79 
 5.17 
 6.06 
 5.14 
 6.02 
 5.27 


 A.  2.1.1.1.2 
 Residence/<  10 


 circuits/  Non- 
 Dis  patch/ 
 GA( 
 days) 


 0.81 
 0.64 
 0.77 
 0.57 
 0.78 
 0.62 
 0.78 
 0.54 


 A.  2.1.1.2.1 
 Residence/>=  10 


 circuits/  Dis 
 patch/  GA( 
 days) 


 5.21 
 6.00 
 5.16 
 6.00 
 5.85 
 4.00 
 5.78 
 6.00 
 1,2,3,4 


 A.  2.1.2.1.1 
 Desi 
 gn 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 KY( 
 days) 


 2.26 
 4.31 
 2.78 
 6.54 
 3.44 
 7.60 
 6.12 
 5.03 


 A.  2.1.2.1.2 
 Business/<  10 
 circuits/  Non- 
 Dis  patch/ 
 GA( 
 days) 


 1.20 
 0.78 
 1.37 
 1.09 
 1.22 
 1.03 
 1.22 
 0.85 


 A.  2.1.2.2.1 
 Business/>=  10 


 circuits/  Dis 
 patch/  GA( 
 days) 


 9.91 
 12.10 


 12.88 
 12.00 
 11.61 


 7.00 
 3,4 


 A.  2.1.2.2.2 
 Business/>=  10 


 circuits/  Non- 
 Dis  patch/ 
 GA( 
 days) 


 0.50 
 6.00 
 3.79 
 2.17 
 2.79 
 0.33 
 0.44 


 1,2,3 


 A.  2.1.3.1.1 
 Desi 
 gn 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 GA( 
 days) 


 28.35 
 11.40 
 25.45 
 12.31 
 19.99 
 14.33 
 21.68 


 7.58 
 3 


 A.  2.1.3.1.2 
 Design 
 (Specials)/<  10 


 circuits/  Non- 


 Dis 
 patch/  GA( 


 days) 


 10.43 
 4.53 
 12.87 


 3.36 
 11.11 


 3.80 
 11.60 


 4.33 
 4 


 A.  2.1.4.1.1 
 PBX/<  10 
 circuits/  Dis 


 patch/  GA( 
 days) 


 7.85 
 4.44 
 12.83 


 13.00 
 12.12 


 3.00 
 9.47 
 5.00 
 1,2,3,4 


 A.  2.1.4.1.2 
 PBX/<  10 
 circuits/  Non- 


 Dis  patch/ 
 GA( 
 days) 


 2.46 
 6.40 
 3.25 
 2.32 
 2.71 
 1.92 
 5.04 
 2.58 


 4 


 A.  2.1.4.2.1 
 PBX/>=  10 
 circuits/  Dis 
 patch/  GA( 
 days) 


 9.33 
 4.00 
 10.67 


 23.11 


 5.00 
 5.00 


 2,3 


 A.  2.1.4.2.2 
 PBX/>=  10 
 circuits/  Non- 


 Dis  patch/ 
 GA( 
 days) 


 1.95 
 0.67 
 2.32 
 0.33 
 1.17 


 2.27 
 1,2 


 A.  2.1.5.1.1 
 Centrex/<  10 
 circuits/  Dis 
 patch/  GA( 
 days) 


 6.16 
 6.00 
 7.08 
 2.80 
 20.00 


 7.00 
 9.14 
 3.00 
 1,2,3,4 


 A.  2.1.5.1.2 
 Centrex/<  10 
 circuits/  Non- 
 Dis  patch/ 
 GA( 
 days) 


 1.16 
 1.90 
 2.08 
 1.15 
 2.17 
 1.11 
 1.71 
 2.28 


 A.  2.1.5.2.1 
 Centrex/>=  10 
 circuits/  Dis 
 patch/  GA( 
 days) 


 14.57 
 6.00 
 12.85 


 2.00 
 16.15 


 13.63 
 1,2 


 A.  2.1.5.2.2 
 Centrex/>=  10 
 circuits/  Non- 
 Dis  patch/ 
 GA( 
 days) 


 3.52 
 2.67 
 5.30 
 3.47 
 5.40 
 2.44 
 3.23 
 3.44 
 1,2,3,4 


 A.  2.1.6.1.1 
 ISDN/<  10 
 circuits/  Dis 
 patch/  GA( 
 days) 


 20.32 
 19.57 
 7.00 
 18.90 


 9.40 
 19.87 


 11.29 
 2,3,4 


 A.  2.1.6.1.2 
 ISDN/<  10 
 circuits/  Non- 


 Dis 
 patch/  GA( 


 days) 


 4.46 
 4.67 
 3.61 
 4.56 
 3.67 
 4.74 
 1.20 
 6.00 
 2,3,4 


 A.  2.1.6.2.1 
 ISDN/>=  10 
 circuits/  Dis 
 patch/  GA( 
 days) 


 69.75 
 42.00 
 9.00 
 11.67 


 19.37 


 2 


 A.  2.1.6.2.2 
 ISDN/>=  10 
 circuits/  Non- 


 Dis 
 patch/  GA( 


 days) 


 3.88 


 5.63 
 2.00 
 2.80 
 3.89 
 7.34 


 2,3 


 % 
 Jeopardies 


 - 
 Mechanized 


 [P-  2] 


 A.  2.4.1 
 Residence/  GA 
 (%) 


 0.58% 
 0.59% 
 0.55% 
 0.52% 
 0.47% 
 0.34% 
 0.40% 
 0.22% 


 A.  2.4.2 
 Business/  GA 
 (%) 


 1.25% 
 0.52% 
 1.40% 
 0.62% 
 1.39% 
 0.68% 
 1.11% 
 0.25% 


 A.  2.4.3 
 Desi 
 gn 
 (Specials)/  GA(%) 


 12.36% 
 0.00% 
 13.74% 


 0.00% 
 11.49% 


 14.47% 


 1,2 


 A.  2.4.4 
 PBX/  GA 
 (%) 


 2.69% 
 0.00% 
 3.08% 
 0.00% 
 5.51% 
 0.00% 
 6.03% 
 0.00% 
 1,3,4 


 A.  2.4.5 
 Centrex/  GA 
 (%) 


 0.77% 
 0.00% 
 2.62% 
 0.00% 
 1.72% 
 0.00% 
 4.20% 
 0.00% 
 1,2,3,4 


 A.  2.4.6 
 ISDN/  GA 
 (%) 


 6.99% 
 8.31% 
 0.00% 
 7.33% 
 0.00% 
 0.97% 
 0.00% 
 2,3,4 


 % 
 Jeopardies 


 - 
 Non-  Mechanized 


 [P-  2] 


 G-  7 
375
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Georgia 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 A.  2.5.1 
 Residence/  GA(%) 


 0.35% 
 0.37% 
 0.15% 
 0.65% 


 A.  2.5.2 
 Business/  GA 
 (%) 


 1.27% 
 0.00% 
 0.26% 
 0.56% 


 A.  2.5.3 
 Desi 
 gn 
 (Specials)/  GA(%) 


 7.00% 
 7.50% 
 4.17% 
 8.70% 


 A.  2.5.4 
 PBX/  GA 
 (%) 


 0.00% 
 4.76% 
 0.00% 
 0.00% 
 4 


 A.  2.5.5 
 Centrex/  GA 
 (%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 


 A.  2.5.6 
 ISDN/  GA 
 (%) 


 2.94% 
 3.70% 
 3.13% 
 20.00% 


 Average 
 Jeopardy 


 Notice 
 Interval 


 - 
 Mechanized 


 [P-  2] 


 A.  2.7.1 
 Residence/  GA 
 (hours) 


 148.48 
 155.55 
 155.68 
 169.23 


 A.  2.7.2 
 Business/  GA 
 (hours) 


 66.42 
 100.07 
 110.65 
 145.05 
 1,2,3,4 


 Average 
 Jeopardy 


 Notice 
 Interval 


 - 
 Non-  Mechanized 


 [P-  2] 


 A.  2.8.1 
 Residence/  GA 
 (hours) 


 90.20 
 37.88 
 168.83 
 108.91 
 1,2,3,4 


 A.  2.8.2 
 Business/  GA 
 (hours) 


 85.08 
 158.52 
 149.22 
 1,3,4 


 A.  2.8.3 
 Desi 
 gn 
 (Specials)/  GA( 


 hours) 


 422.17 
 294.36 
 160.26 
 315.74 
 1,2,3 


 A.  2.8.4 
 PBX/  GA 
 (hours) 


 230.75 
 2 


 A.  2.8.6 
 ISDN/  GA 
 (hours) 


 326.73 
 294.85 
 464.08 
 303.12 
 1,2,3,4 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Mechanized 


 [P-  2] 


 A.  2.9.1 
 Residence/  GA 
 (%) 


 100.00% 
 98.72% 
 100.00% 
 100.00% 


 A.  2.9.2 
 Business/  GA 
 (%) 


 66.67% 
 75.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Non-  Mechanized 


 [P-  2] 


 A.  2.10.1 
 Residence/  GA 
 (%) 


 100.00% 
 0.00% 
 100.00% 


 100.00% 
 1,2,3,4 


 A.  2.10.2 
 Business/  GA 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 1,3,4 


 A.  2.10.3 
 Desi 
 gn 
 (Specials)/  GA(%) 


 100.00% 
 100.00% 
 100.00% 
 91.67% 
 1,2,3 


 A.  2.10.4 
 Design 
 (Specials)/<  10 


 circuits/  Non- 
 Dispatch/  KY(%) 


 100.00% 


 2 


 A.  2.10.6 
 ISDN/  GA 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 % 
 Missed 


 Installation 


 Appointments 


 [P-  3] 


 A.  2.11.1.1.1 
 Residence/<  10 


 circuits/  Dis 
 patch/  GA(%) 


 5.36% 
 4.68% 
 5.01% 
 3.40% 
 5.66% 
 4.29% 
 6.45% 
 3.44% 


 A.  2.11.1.1.2 
 Residence/<  10 


 circuits/  Non- 
 Dis  patch/ 
 GA(%) 


 0.01% 
 0.13% 
 0.01% 
 0.15% 
 0.17% 
 0.43% 
 0.06% 
 0.12% 


 A.  2.11.1.2.1 
 Residence/>=  10 


 circuits/  Dis 
 patch/  GA(%) 


 1.59% 
 0.00% 
 5.33% 
 0.00% 
 4.69% 
 0.00% 
 6.56% 
 0.00% 
 1,2,3,4 


 A.  2.11.2.1.1 
 Business/<  10 
 circuits/  Dis 
 patch/  GA(%) 


 1.31% 
 3.45% 
 1.27% 
 3.94% 
 1.77% 
 1.43% 
 4.10% 
 2.50% 


 A.  2.11.2.1.2 
 Business/<  10 
 circuits/  Non- 
 Dis  patch/ 
 GA(%) 


 0.02% 
 0.00% 
 0.07% 
 0.00% 
 0.09% 
 0.26% 
 0.06% 
 0.66% 


 A.  2.11.2.2.1 
 Business/>=  10 


 circuits/  Dis 
 patch/  GA(%) 


 5.71% 
 7.26% 
 6.77% 
 0.00% 
 3.73% 
 0.00% 


 3,4 


 A.  2.11.2.2.2 
 Business/>=  10 


 circuits/  Non- 
 Dis  patch/ 
 GA(%) 


 0.00% 
 0.00% 
 37.50% 


 0.00% 
 0.00% 
 0.00% 
 0.00% 


 1,2,3 


 G-  8 
376
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Georgia 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 A.  2.11.3.1.1 
 Design 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 GA(%) 
 3.99% 
 7.41% 
 3.82% 
 15.38% 


 4.32% 
 12.50% 


 4.75% 
 7.89% 


 3 


 A.  2.11.3.1.2 
 Design 
 (Specials)/<  10 


 circuits/  Non- 
 Dispatch/  GA(%) 


 4.40% 
 2.04% 
 1.79% 
 0.00% 
 0.95% 
 0.00% 
 0.60% 
 0.00% 


 A.  2.11.3.2.2 
 Design 
 (Specials)/>=  10 


 circuits/  Non- 
 Dispatch/  GA(%) 


 0.00% 


 0.00% 
 0.00% 
 0.00% 


 2 


 A.  2.11.4.1.1 
 PBX/<  10 
 circuits/  Dis 


 patch/  GA(%) 


 8.82% 
 25.00% 


 9.43% 
 0.00% 
 3.57% 
 0.00% 
 2.38% 
 0.00% 
 1,2,3,4 


 A.  2.11.4.1.2 
 PBX/<  10 
 circuits/  Non- 


 Dis 
 patch/  GA(%) 


 2.44% 
 42.11% 


 3.53% 
 0.00% 
 2.14% 
 0.00% 
 0.00% 
 0.00% 


 4 


 A.  2.11.4.2.1 
 PBX/>=  10 
 circuits/  Dis 
 patch/  GA(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 2,3 


 A.  2.11.4.2.2 
 PBX/>=  10 
 circuits/  Non- 


 Dis 
 patch/  GA(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3,4 


 A.  2.11.5.1.1 
 Centrex/<  10 
 circuits/  Dis 
 patch/  GA(%) 


 4.61% 
 0.00% 
 3.92% 
 0.00% 
 2.28% 
 50.00% 


 3.15% 
 0.00% 
 1,2,3,4 


 A.  2.11.5.1.2 
 Centrex/<  10 
 circuits/  Non- 
 Dis  patch/ 
 GA(%) 


 0.03% 
 0.00% 
 0.16% 
 0.00% 
 0.13% 
 0.00% 
 0.00% 
 0.00% 


 A.  2.11.5.2.1 
 Design 
 (Specials)/<  10 


 circuits/  Non- 
 Dispatch/  KY(%) 


 5.13% 
 0.00% 
 5.93% 
 0.00% 
 3.66% 


 5.71% 


 1,2 


 A.  2.11.5.2.2 
 Centrex/>=  10 
 circuits/  Non- 
 Dis  patch/ 
 GA(%) 


 0.00% 
 0.00% 
 1.56% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3,4 


 A.  2.11.6.1.1 
 ISDN/<  10 
 circuits/  Dis 
 patch/  GA(%) 


 6.17% 
 0.00% 
 3.69% 
 0.00% 
 3.61% 
 0.00% 
 3.61% 
 11.11% 
 1,2,3,4 


 A.  2.11.6.1.2 
 ISDN/<  10 
 circuits/  Non- 


 Dis 
 patch/  GA(%) 


 0.28% 
 0.00% 
 0.23% 
 0.00% 
 0.00% 
 0.00% 
 0.07% 
 0.00% 


 4 


 A.  2.11.6.2.1 
 ISDN/>=  10 
 circuits/  Dis 
 patch/  GA(%) 


 0.00% 
 25.00% 
 0.00% 
 0.00% 


 0.00% 


 2 


 A.  2.11.6.2.2 
 ISDN/>=  10 
 circuits/  Non- 


 Dis 
 patch/  GA(%) 


 0.00% 
 30.00% 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 2,3 


 % 
 Provisioning 


 Troubles 
 within 
 30 
 Days 


 [P-  9] 


 A.  2.12.1.1.1 
 Residence/<  10 


 circuits/  Dis 
 patch/  GA(%) 


 11.91% 
 9.78% 
 11.47% 


 9.13% 
 11.91% 
 10.73% 
 12.67% 
 13.11% 


 A.  2.12.1.1.2 
 Residence/<  10 


 circuits/  Non- 
 Dis  patch/ 
 GA(%) 


 3.91% 
 6.10% 
 4.04% 
 4.63% 
 3.97% 
 4.14% 
 3.88% 
 4.58% 


 A.  2.12.1.2.1 
 Residence/>=  10 


 circuits/  Dis 
 patch/  GA(%) 


 16.95% 
 0.00% 
 6.35% 
 50.00% 
 10.67% 
 0.00% 
 9.38% 
 0.00% 
 1,2,3,4 


 A.  2.12.2.1.1 
 Business/<  10 
 circuits/  Dis 
 patch/  GA(%) 


 12.06% 
 12.84% 
 11.43% 
 6.21% 
 12.03% 


 7.87% 
 14.03% 


 6.19% 


 A.  2.12.2.1.2 
 Business/<  10 
 circuits/  Non- 
 Dis  patch/ 
 GA(%) 


 6.08% 
 4.78% 
 6.50% 
 5.10% 
 7.32% 
 5.58% 
 8.75% 
 5.49% 


 A.  2.12.2.2.1 
 Business/>=  10 


 circuits/  Dis 
 patch/  GA(%) 


 22.58% 
 20.71% 
 19.35% 
 27.07% 
 50.00% 


 4 


 A.  2.12.2.2.2 
 Business/>=  10 


 circuits/  Non- 
 Dis  patch/ 
 GA(%) 


 15.79% 


 30.00% 
 0.00% 
 12.50% 


 0.00% 
 7.69% 
 0.00% 
 2,3,4 


 A.  2.12.3.1.1 
 Desi 
 gn 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 GA(%) 
 5.34% 
 12.00% 


 6.59% 
 12.96% 


 7.79% 
 19.23% 


 5.89% 
 0.00% 


 4 


 A.  2.12.3.1.2 
 Design 
 (Specials)/<  10 


 circuits/  Non- 
 Dispatch/  GA(%) 


 5.97% 
 0.00% 
 3.77% 
 8.16% 
 3.23% 
 0.00% 
 3.33% 
 0.00% 


 A.  2.12.3.2.2 
 Design 
 (Specials)/>=  10 


 circuits/  Non- 
 Dispatch/  GA(%) 


 0.00% 


 0.00% 
 0.00% 
 0.00% 
 0.00% 


 3 


 A.  2.12.4.1.1 
 PBX/<  10 
 circuits/  Dis 


 patch/  GA(%) 


 17.39% 
 0.00% 
 1.47% 
 0.00% 
 1.89% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3,4 


 A.  2.12.4.1.2 
 PBX/<  10 
 circuits/  Non- 


 Dis 
 patch/  GA(%) 


 7.83% 
 0.00% 
 8.54% 
 0.00% 
 1.18% 
 4.00% 
 3.57% 
 0.00% 


 A.  2.12.4.2.1 
 PBX/>=  10 
 circuits/  Dis 
 patch/  GA(%) 


 0.00% 
 0.00% 
 0.00% 
 33.33% 
 20.00% 
 0.00% 
 3,4 


 G-  9 
377
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Georgia 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 A.  2.12.4.2.2 
 PBX/>=  10 
 circuits/  Non- 


 Dispatch/  GA(%) 


 4.35% 
 0.00% 
 6.90% 
 0.00% 
 7.14% 
 0.00% 
 4.00% 
 0.00% 
 1,2,3,4 


 A.  2.12.5.1.1 
 Centrex/<  10 
 circuits/  Dis 
 patch/  GA(%) 


 9.54% 
 50.00% 
 10.60% 
 33.33% 
 12.27% 
 25.00% 
 7.96% 
 0.00% 
 1,2,3,4 


 A.  2.12.5.1.2 
 Centrex/<  10 
 circuits/  Non- 
 Dis  patch/ 
 GA(%) 


 0.93% 
 18.18% 


 1.76% 
 0.00% 
 8.05% 
 18.18% 


 5.13% 
 4.17% 


 A.  2.12.5.2.1 
 Centrex/>=  10 
 circuits/  Dis 
 patch/  GA(%) 


 19.30% 
 21.79% 
 100.00% 


 22.03% 
 0.00% 
 23.17% 


 2,3 


 A.  2.12.5.2.2 
 Centrex/>=  10 
 circuits/  Non- 
 Dis  patch/ 
 GA(%) 


 16.09% 


 21.74% 
 40.00% 
 20.31% 
 20.00% 
 16.58% 
 0.00% 
 2,3,4 


 A.  2.12.6.1.1 
 ISDN/<  10 
 circuits/  Dis 
 patch/  GA(%) 


 8.41% 
 0.00% 
 7.52% 
 0.00% 
 8.12% 
 0.00% 
 11.95% 


 0.00% 
 1,2,3,4 


 A.  2.12.6.1.2 
 ISDN/<  10 
 circuits/  Non- 


 Dis 
 patch/  GA(%) 


 1.00% 
 5.56% 
 2.09% 
 0.00% 
 2.20% 
 0.00% 
 0.79% 
 0.00% 


 A.  2.12.6.2.1 
 Design 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 KY(  hours) 
 0.00% 
 0.00% 
 0.00% 


 0.00% 
 0.00% 
 0.00% 


 1,3 


 A.  2.12.6.2.2 
 ISDN/>=  10 
 circuits/  Non- 


 Dis 
 patch/  GA(%) 


 0.00% 
 0.00% 
 0.00% 
 10.00% 


 0.90% 
 0.00% 
 0.24% 
 0.00% 
 1,3,4 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Mechanized 


 [P-  5] 


 A.  2.14.1.1.1 
 Residence/<  10 


 circuits/  Dis 
 patch/  GA( 
 hours) 


 2.70 
 0.07 
 3.26 
 0.62 
 1.30 
 0.73 
 2.17 
 0.09 


 A.  2.14.1.1.2 
 Residence/<  10 


 circuits/  Non- 
 Dis  patch/ 
 GA( 
 hours) 


 0.88 
 0.71 
 0.78 
 0.75 
 0.86 
 0.77 
 1.02 
 0.79 


 A.  2.14.1.2.1 
 Residence/>=  10 


 circuits/  Dis 
 patch/  GA( 
 hours) 


 0.33 
 0.02 
 0.06 
 0.02 
 3.75 
 0.02 
 1.14 
 0.14 
 1,2,3,4 


 A.  2.14.2.1.1 
 Business/<  10 
 circuits/  Dis 
 patch/  GA( 
 hours) 


 1.59 
 0.21 
 2.31 
 0.79 
 2.22 
 0.23 
 3.43 
 0.12 


 A.  2.14.2.1.2 
 Business/<  10 
 circuits/  Non- 
 Dis  patch/ 
 GA( 
 hours) 


 1.98 
 0.69 
 2.27 
 1.22 
 3.32 
 1.37 
 2.35 
 1.00 


 A.  2.14.2.2.1 
 Business/>=  10 


 circuits/  Dis 
 patch/  GA( 
 hours) 


 3.07 
 8.52 
 3.25 
 0.02 
 7.30 
 0.08 
 3,4 


 A.  2.14.3.1.1 
 Design 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 GA(  hours) 
 329.71 
 2.57 
 304.31 


 41.83 
 205.54 


 222.78 


 1,2 


 A.  2.14.3.1.2 
 Design 
 (Specials)/<  10 


 circuits/  Non- 


 Dispatch/  GA( 
 hours) 


 27.50 
 23.06 
 0.66 
 8.98 


 14.54 


 2 


 A.  2.14.4.1.1 
 PBX/<  10 
 circuits/  Dis 


 patch/  GA( 
 hours) 


 86.96 
 77.79 
 110.17 


 39.97 
 715.20 


 4 


 A.  2.14.4.1.2 
 PBX/<  10 
 circuits/  Non- 


 Dis 
 patch/  GA( 


 hours) 


 24.63 
 58.60 
 55.08 


 0.62 
 37.40 


 47.96 
 15.97 


 0.02 
 1,3,4 


 A.  2.14.4.2.1 
 PBX/>=  10 
 circuits/  Dis 
 patch/  GA( 
 hours) 


 105.05 
 0.03 
 0.02 
 71.29 


 191.50 


 2 


 A.  2.14.4.2.2 
 PBX/>=  10 
 circuits/  Non- 


 Dis  patch/ 
 GA( 
 hours) 


 20.22 


 24.66 
 0.47 
 0.66 


 1.42 


 2 


 A.  2.14.5.1.1 
 Centrex/<  10 
 circuits/  Dis 
 patch/  GA( 
 hours) 


 13.20 
 0.02 
 8.33 
 0.03 
 13.34 


 7.00 
 1,2 


 A.  2.14.5.1.2 
 Centrex/<  10 
 circuits/  Non- 
 Dis  patch/ 
 GA( 
 hours) 


 1.42 
 0.44 
 2.17 
 0.45 
 2.01 
 0.36 
 7.35 
 0.19 
 1,2,3,4 


 A.  2.14.6.1.2 
 ISDN/<  10 
 circuits/  Non- 


 Dis 
 patch/  GA( 


 hours) 


 19.50 


 26.17 
 0.82 
 16.52 


 0.43 
 2.41 


 2,3 


 A.  2.14.6.2.2 
 ISDN/>=  10 
 circuits/  Non- 


 Dis 
 patch/  GA( 


 hours) 


 3.62 


 9.23 
 20.60 
 0.42 
 43.66 


 3 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Non-  Mechanized 


 [P-  5] 


 A.  2.15.1.1.1 
 Design 
 (Specials)/<  10 


 circuits/  Non- 
 Dispatch/  KY(%) 


 15.02 
 14.17 
 13.59 
 15.15 


 A.  2.15.1.1.2 
 Residence/<  10 


 circuits/  Non- 
 Dis  patch/ 
 GA( 
 hours) 


 8.82 
 6.89 
 9.16 
 7.93 


 A.  2.15.1.2.1 
 Residence/>=  10 


 circuits/  Dis 
 patch/  GA( 
 hours) 


 18.73 
 4 


 G-  10 
378
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Georgia 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 A.  2.15.2.1.1 
 Business/<  10 
 circuits/  Dispatch/ 


 GA( 
 hours) 


 26.63 
 33.33 
 31.51 
 23.16 


 A.  2.15.2.1.2 
 Business/<  10 
 circuits/  Non- 
 Dis  patch/ 
 GA( 
 hours) 


 8.81 
 9.18 
 17.20 


 12.91 


 A.  2.15.2.2.1 
 Business/>=  10 


 circuits/  Dis 
 patch/  GA( 
 hours) 


 0.02 
 3 


 A.  2.15.2.2.2 
 Business/>=  10 


 circuits/  Non- 
 Dis  patch/ 
 GA( 
 hours) 


 14.00 
 14.00 


 0.02 


 1,2,3 


 A.  2.15.3.1.1 
 Design 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 GA(  hours) 


 150.54 
 174.98 
 322.06 
 121.19 
 3 


 A.  2.15.3.1.2 
 Design 
 (Specials)/<  10 


 circuits/  Non- 


 Dispatch/  GA( 
 hours) 


 29.59 
 21.87 
 51.65 
 75.40 


 A.  2.15.3.2.2 
 Design 
 (Specials)/>=  10 


 circuits/  Non- 


 Dis 
 patch/  GA( 


 hours) 


 15.63 
 2 


 A.  2.15.4.1.1 
 PBX/<  10 
 circuits/  Dis 


 patch/  GA( 
 hours) 


 36.55 
 28.97 
 67.28 
 62.58 
 1,2,3,4 


 A.  2.15.4.1.2 
 PBX/<  10 
 circuits/  Non- 


 Dis 
 patch/  GA( 


 hours) 


 55.66 
 21.50 
 29.70 
 21.03 
 4 


 A.  2.15.4.2.1 
 PBX/>=  10 
 circuits/  Dis 
 patch/  GA( 
 hours) 


 48.21 
 10.94 


 2,3 


 A.  2.15.4.2.2 
 PBX/>=  10 
 circuits/  Non- 


 Dis  patch/ 
 GA( 
 hours) 


 22.15 
 0.63 
 15.38 


 22.38 
 1,2,3,4 


 A.  2.15.5.1.1 
 Centrex/<  10 
 circuits/  Dis 
 patch/  GA( 
 hours) 


 18.18 
 20.08 
 20.42 
 16.15 
 1,2,3,4 


 A.  2.15.5.1.2 
 Centrex/<  10 
 circuits/  Non- 
 Dis  patch/ 
 GA( 
 hours) 


 17.01 
 21.86 
 12.00 
 24.89 


 A.  2.15.5.2.1 
 Centrex/>=  10 
 circuits/  Dis 
 patch/  GA( 
 hours) 


 14.17 
 35.48 


 1,2 


 A.  2.15.5.2.2 
 Centrex/>=  10 
 circuits/  Non- 
 Dis  patch/ 
 GA( 
 hours) 


 14.00 
 18.80 
 21.27 
 14.00 
 1,2,3,4 


 A.  2.15.6.1.1 
 ISDN/<  10 
 circuits/  Dis 
 patch/  GA( 
 hours) 


 40.36 
 27.66 
 49.44 
 50.16 
 1,2,3,4 


 A.  2.15.6.1.2 
 ISDN/<  10 
 circuits/  Non- 


 Dis 
 patch/  GA( 


 hours) 


 6.25 
 68.37 


 40.09 
 65.14 
 4 


 A.  2.15.6.2.1 
 ISDN/>=  10 
 circuits/  Dis 
 patch/  GA( 
 hours) 


 8.87 
 2 


 A.  2.15.6.2.2 
 ISDN/>=  10 
 circuits/  Non- 


 Dis 
 patch/  GA( 


 hours) 


 9.42 
 14.00 


 18.68 


 2,3 


 Service 
 Order 
 Accuracy 


 [P-  11] 


 A.  2.25.1.1.1 
 Residence/<  10 


 circuits/  Dis 
 patch/  GA(%) 


 92.14% 
 96.55% 
 90.77% 
 98.86% 


 A.  2.25.1.1.2 
 Residence/<  10 


 circuits/  Non- 
 Dis  patch/ 
 GA(%) 


 95.38% 
 94.29% 
 98.82% 
 98.56% 


 A.  2.25.1.2.1 
 Residence/>=  10 


 circuits/  Dis 
 patch/  GA(%) 


 100.00% 
 88.24% 
 100.00% 
 100.00% 
 4 


 A.  2.25.2.1.1 
 Business/<  10 
 circuits/  Dis 
 patch/  GA(%) 


 91.33% 
 95.76% 
 88.82% 
 94.44% 


 A.  2.25.2.1.2 
 Business/<  10 
 circuits/  Non- 
 Dis  patch/ 
 GA(%) 


 93.85% 
 97.93% 
 96.11% 
 97.22% 


 A.  2.25.2.2.1 
 Business/>=  10 


 circuits/  Dis 
 patch/  GA(%) 


 100.00% 
 77.78% 
 77.78% 
 76.92% 
 2 


 A.  2.25.2.2.2 
 Business/>=  10 


 circuits/  Non- 
 Dis  patch/ 
 GA(%) 


 84.62% 
 97.56% 
 92.59% 
 91.89% 


 A.  2.25.3.1.1 
 Desi 
 gn 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 GA(%) 


 81.08% 
 91.43% 
 80.49% 
 96.47% 


 A.  2.25.3.1.2 
 Design 
 (Specials)/<  10 


 circuits/  Non- 
 Dispatch/  GA(%) 


 91.84% 
 94.78% 
 91.43% 
 91.36% 


 A.  2.25.3.2.1 
 Desi 
 gn 
 (Specials)/>=  10 


 circuits/  Dispatch/ 


 GA(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 G-  11 
379
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Georgia 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 A.  2.25.3.2.2 
 Design 
 (Specials)/>=  10 


 circuits/  Non- 
 Dispatch/  GA(%) 


 100.00% 
 90.00% 
 92.31% 
 88.89% 
 1,4 


 RESALE 
 - 
 MAINTENANCE 


 AND 
 REPAIR 


 Missed 
 Repair 
 Appointments 


 [M&  R- 
 1] 


 A.  3.1.1.1 
 Residence/  Dis 
 patch/  GA(%) 


 8.79% 
 1.43% 
 7.45% 
 1.65% 
 6.78% 
 2.33% 
 6.44% 
 2.02% 


 A.  3.1.1.2 
 Residence/  Non- 


 Dis  patch/ 
 GA(%) 


 0.86% 
 0.60% 
 0.90% 
 0.60% 
 1.20% 
 1.43% 
 1.05% 
 0.21% 


 A.  3.1.2.1 
 Business/  Dis 
 patch/  GA(%) 


 6.06% 
 2.70% 
 5.99% 
 3.23% 
 6.28% 
 3.83% 
 7.69% 
 8.33% 


 A.  3.1.2.2 
 Business/  Non- 


 Dis 
 patch/  GA(%) 


 2.22% 
 4.50% 
 2.02% 
 0.00% 
 4.68% 
 0.76% 
 2.94% 
 1.25% 


 A.  3.1.3.1 
 Desi 
 gn 
 (Specials)/  Dispatch/ 


 GA(%) 


 0.61% 
 0.00% 
 0.25% 
 0.00% 
 1.03% 
 1.18% 
 0.77% 
 0.00% 


 A.  3.1.3.2 
 Desi 
 gn 
 (Specials)/  Non- 


 Dispatch/  GA(%) 


 0.04% 
 0.00% 
 0.29% 
 0.00% 
 0.20% 
 0.00% 
 0.21% 
 0.00% 


 A.  3.1.4.1 
 PBX/  Dis 
 patch/  GA(%) 


 6.69% 
 0.00% 
 2.54% 
 8.33% 
 2.65% 
 0.00% 
 11.93% 


 0.00% 


 3 


 A.  3.1.4.2 
 PBX/  Non- 
 Dis 
 patch/  GA(%) 


 2.12% 
 0.00% 
 0.44% 
 0.00% 
 0.33% 
 0.00% 
 0.19% 
 5.56% 


 A.  3.1.5.1 
 Centrex/  Dis 
 patch/  GA(%) 


 7.98% 
 13.33% 


 6.51% 
 16.13% 


 6.86% 
 0.00% 
 8.32% 
 0.00% 


 A.  3.1.5.2 
 Centrex/  Non- 
 Dis 
 patch/  GA(%) 


 3.71% 
 0.00% 
 4.08% 
 7.69% 
 6.11% 
 0.00% 
 3.10% 
 0.00% 


 4 


 A.  3.1.6.1 
 ISDN/  Dis 
 patch/  GA(%) 


 10.68% 
 0.00% 
 13.28% 
 50.00% 
 8.17% 
 0.00% 
 14.03% 


 0.00% 
 1,2,3,4 


 A.  3.1.6.2 
 ISDN/  Non- 
 Dis 
 patch/  GA(%) 


 1.69% 
 0.00% 
 2.43% 
 0.00% 
 1.71% 
 0.00% 
 1.96% 
 0.00% 
 2,3,4 


 Customer 
 Trouble 
 Report 
 Rate 
 [M&  R- 


 2] 


 A.  3.2.1.1 
 Residence/  Dis 
 patch/  GA(%) 


 2.02% 
 2.12% 
 2.25% 
 2.13% 
 2.42% 
 2.53% 
 2.43% 
 2.52% 


 A.  3.2.1.2 
 Residence/  Non- 


 Dis  patch/ 
 GA(%) 


 1.30% 
 0.65% 
 1.28% 
 0.67% 
 1.40% 
 0.80% 
 1.35% 
 0.81% 


 A.  3.2.2.1 
 Business/  Dis 
 patch/  GA(%) 


 1.19% 
 1.30% 
 1.27% 
 1.19% 
 1.35% 
 1.36% 
 1.35% 
 1.28% 


 A.  3.2.2.2 
 Business/  Non- 


 Dis 
 patch/  GA(%) 


 0.74% 
 0.65% 
 0.77% 
 0.68% 
 0.94% 
 0.97% 
 0.77% 
 0.66% 


 A.  3.2.3.1 
 Desi 
 gn 
 (Specials)/  Dispatch/ 


 GA(%) 


 1.26% 
 1.42% 
 1.35% 
 2.06% 
 1.43% 
 1.71% 
 1.48% 
 1.41% 


 A.  3.2.3.2 
 Desi 
 gn 
 (Specials)/  Non- 


 Dispatch/  GA(%) 


 1.97% 
 1.42% 
 2.09% 
 1.48% 
 2.19% 
 1.06% 
 2.06% 
 1.41% 


 A.  3.2.4.1 
 PBX/  Dis 
 patch/  GA(%) 


 0.18% 
 0.96% 
 0.17% 
 0.50% 
 0.17% 
 0.20% 
 0.14% 
 0.75% 


 A.  3.2.4.2 
 PBX/  Non- 
 Dis 
 patch/  GA(%) 


 0.26% 
 0.73% 
 0.29% 
 0.42% 
 0.38% 
 0.79% 
 0.34% 
 0.97% 


 A.  3.2.5.1 
 Centrex/  Dis 
 patch/  GA(%) 


 0.45% 
 0.64% 
 0.54% 
 1.40% 
 0.54% 
 0.84% 
 0.51% 
 1.37% 


 A.  3.2.5.2 
 Centrex/  Non- 
 Dis 
 patch/  GA(%) 


 0.29% 
 1.07% 
 0.34% 
 0.59% 
 0.38% 
 0.52% 
 0.34% 
 0.16% 


 A.  3.2.6.1 
 ISDN/  Dis 
 patch/  GA(%) 


 0.13% 
 0.40% 
 0.13% 
 0.13% 
 0.12% 
 0.20% 
 0.13% 
 0.31% 


 A.  3.2.6.2 
 ISDN/  Non- 
 Dis 
 patch/  GA(%) 


 0.22% 
 0.00% 
 0.19% 
 0.44% 
 0.24% 
 0.20% 
 0.21% 
 0.31% 


 Maintenance 
 Average 
 Duration 


 [M&  R- 
 3] 


 A.  3.3.1.1 
 Residence/  Dis 
 patch/  GA( 
 hours) 


 24.69 
 11.20 
 26.34 
 11.62 
 22.36 
 11.91 
 22.43 
 12.25 


 A.  3.3.1.2 
 Residence/  Non- 


 Dis  patch/ 
 GA( 
 hours) 


 5.78 
 3.46 
 6.10 
 2.82 
 6.78 
 3.67 
 7.11 
 3.32 


 A.  3.3.2.1 
 Business/  Dis 
 patch/  GA( 
 hours) 


 11.11 
 10.00 
 11.06 
 10.66 
 11.45 


 9.63 
 11.79 


 11.32 


 G-  12 
380
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Georgia 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 A.  3.3.2.2 
 Business/  Non- 
 Dispatch/  GA( 
 hours) 


 3.61 
 4.26 
 3.55 
 2.68 
 4.82 
 3.90 
 4.66 
 1.63 


 A.  3.3.3.1 
 Desi 
 gn 
 (Specials)/  Dispatch/ 


 GA( 
 hours) 


 7.09 
 2.84 
 4.34 
 3.92 
 6.33 
 3.59 
 4.90 
 4.78 


 A.  3.3.3.2 
 Desi 
 gn 
 (Specials)/  Non- 


 Dispatch/  GA( 
 hours) 


 1.85 
 1.88 
 2.52 
 1.85 
 1.81 
 2.00 
 2.24 
 1.50 


 A.  3.3.4.1 
 PBX/  Dis 
 patch/  GA( 


 hours) 


 8.48 
 6.28 
 6.87 
 9.15 
 6.01 
 2.32 
 8.98 
 8.16 


 3 


 A.  3.3.4.2 
 PBX/  Non- 
 Dis 
 patch/  GA( 


 hours) 


 2.99 
 6.86 
 2.08 
 5.18 
 1.91 
 6.40 
 2.15 
 13.76 


 A.  3.3.5.1 
 Centrex/  Dis 
 patch/  GA( 
 hours) 


 12.82 
 14.57 
 12.53 
 11.65 
 12.36 


 5.81 
 12.40 


 6.04 


 A.  3.3.5.2 
 Centrex/  Non- 
 Dis 
 patch/  GA( 


 hours) 


 4.94 
 1.27 
 3.96 
 3.92 
 5.88 
 4.10 
 4.78 
 0.67 


 4 


 A.  3.3.6.1 
 ISDN/  Dis 
 patch/  GA( 
 hours) 


 15.65 
 7.61 
 15.49 


 45.28 
 12.68 


 9.58 
 14.12 


 6.67 
 1,2,3,4 


 A.  3.3.6.2 
 ISDN/  Non- 
 Dis 
 patch/  GA( 


 hours) 


 3.17 
 0.00 
 2.97 
 4.70 
 3.59 
 2.57 
 3.03 
 2.60 
 2,3,4 


 % 
 Repeat 


 Troubles 


 within 
 30 
 Days 


 [M&  R- 


 4] 


 A.  3.4.1.1 
 Residence/  Dis 
 patch/  GA(%) 


 17.55% 
 11.33% 
 18.23% 
 11.61% 
 18.40% 
 11.83% 
 18.14% 
 11.86% 


 A.  3.4.1.2 
 Residence/  Non- 


 Dis  patch/ 
 GA(%) 


 14.73% 
 12.88% 
 15.47% 
 15.32% 
 14.70% 
 16.16% 
 15.04% 
 10.74% 


 A.  3.4.2.1 
 Business/  Dis 
 patch/  GA(%) 


 14.26% 
 12.61% 
 14.77% 
 15.05% 
 15.05% 
 12.02% 
 14.06% 
 16.67% 


 A.  3.4.2.2 
 Business/  Non- 


 Dis 
 patch/  GA(%) 


 13.27% 
 11.71% 
 14.32% 
 15.09% 
 13.86% 
 10.69% 
 12.85% 
 11.25% 


 A.  3.4.3.1 
 Desi 
 gn 
 (Specials)/  Dispatch/ 


 GA(%) 


 22.15% 
 22.22% 
 23.82% 
 26.21% 
 21.63% 
 16.47% 
 25.12% 
 22.22% 


 A.  3.4.3.2 
 Desi 
 gn 
 (Specials)/  Non- 


 Dispatch/  GA(%) 


 19.08% 
 16.67% 
 18.35% 
 17.57% 
 19.02% 
 18.87% 
 20.91% 
 15.28% 


 A.  3.4.4.1 
 PBX/  Dis 
 patch/  GA(%) 


 12.04% 
 20.00% 
 12.32% 
 8.33% 
 12.12% 
 25.00% 
 11.01% 
 28.57% 


 3 


 A.  3.4.4.2 
 PBX/  Non- 
 Dis 
 patch/  GA(%) 


 11.79% 
 15.79% 
 9.85% 
 20.00% 
 12.04% 
 25.00% 
 14.61% 
 11.11% 


 A.  3.4.5.1 
 Centrex/  Dis 
 patch/  GA(%) 


 12.32% 
 26.67% 
 14.11% 
 29.03% 
 12.92% 
 12.50% 
 13.85% 
 7.69% 


 A.  3.4.5.2 
 Centrex/  Non- 
 Dis 
 patch/  GA(%) 


 12.24% 
 20.00% 
 13.44% 
 30.77% 
 12.76% 
 0.00% 
 14.27% 
 33.33% 


 4 


 A.  3.4.6.1 
 ISDN/  Dis 
 patch/  GA(%) 


 21.88% 
 20.00% 
 20.80% 
 0.00% 
 16.90% 
 33.33% 
 20.26% 
 50.00% 
 1,2,3,4 


 A.  3.4.6.2 
 ISDN/  Non- 
 Dis 
 patch/  GA(%) 


 15.18% 
 0.00% 
 19.30% 


 0.00% 
 14.00% 
 33.33% 
 17.65% 
 0.00% 
 2,3,4 


 Out 
 of 
 Service 


 > 
 24 


 hours 


 [M&  R- 


 5] 


 A.  3.5.1.1 
 Residence/  Dis 
 patch/  GA(%) 


 25.22% 
 6.96% 
 27.14% 


 8.75% 
 26.60% 


 9.40% 
 27.78% 


 8.86% 


 A.  3.5.1.2 
 Residence/  Non- 


 Dis  patch/ 
 GA(%) 


 8.12% 
 2.07% 
 9.53% 
 1.05% 
 10.79% 


 2.62% 
 11.19% 


 0.99% 


 A.  3.5.2.1 
 Business/  Dis 
 patch/  GA(%) 


 8.30% 
 5.63% 
 8.18% 
 8.03% 
 9.35% 
 6.45% 
 9.48% 
 5.05% 


 A.  3.5.2.2 
 Business/  Non- 


 Dis 
 patch/  GA(%) 


 2.48% 
 6.67% 
 2.20% 
 0.00% 
 5.25% 
 1.64% 
 4.20% 
 0.00% 


 A.  3.5.3.1 
 Desi 
 gn 
 (Specials)/  Dispatch/ 


 GA(%) 


 0.61% 
 0.00% 
 0.25% 
 0.00% 
 1.03% 
 1.18% 
 0.77% 
 0.00% 


 A.  3.5.3.2 
 Desi 
 gn 
 (Specials)/  Non- 


 Dispatch/  GA(%) 


 0.04% 
 0.00% 
 0.29% 
 0.00% 
 0.20% 
 0.00% 
 0.21% 
 0.00% 


 A.  3.5.4.1 
 PBX/  Dis 
 patch/  GA(%) 


 3.43% 
 0.00% 
 2.61% 
 9.09% 
 3.57% 
 0.00% 
 5.98% 
 0.00% 


 3 


 A.  3.5.4.2 
 PBX/  Non- 
 Dis 
 patch/  GA(%) 


 2.22% 
 0.00% 
 0.50% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 1,2 


 A.  3.5.5.1 
 Centrex/  Dis 
 patch/  GA(%) 


 12.19% 
 0.00% 
 9.23% 
 4.17% 
 11.95% 


 0.00% 
 10.23% 


 0.00% 


 1 


 A.  3.5.5.2 
 Centrex/  Non- 
 Dis 
 patch/  GA(%) 


 3.73% 
 0.00% 
 2.51% 
 0.00% 
 2.74% 
 0.00% 
 1.78% 
 0.00% 
 2,3,4 


 A.  3.5.6.1 
 ISDN/  Dis 
 patch/  GA(%) 


 14.08% 
 20.00% 
 16.71% 
 50.00% 
 11.49% 
 0.00% 
 17.80% 


 0.00% 
 1,2,3,4 


 G-  13 
381
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Georgia 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 A.  3.5.6.2 
 ISDN/  Non- 
 Dispatch/  GA(%) 


 1.50% 
 0.00% 
 0.95% 
 0.00% 
 1.55% 
 0.00% 
 1.39% 
 0.00% 
 2,3,4 


 RESALE 
 - 
 BILLING  Invoice  Accuracy 


 [B-  1] 


 A.  4.1 
 GA 
 (%) 


 98.28% 
 99.61% 
 98.50% 
 99.36% 
 98.72% 
 99.80% 
 98.05% 
 99.35% 


 Mean 
 Time 
 to 
 Deliver 


 Invoices 


 - 
 CRIS 


 [B-  2] 


 A.  4.2 
 Re 
 gion( 


 business 


 days) 


 3.68 
 3.56 
 3.86 
 3.27 
 3.47 
 3.16 
 3.82 
 3.37 


 UNBUNDLED 
 NETWORK 
 ELEMENTS 


 - 
 ORDERING 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Mechanized 


 [O-  7] 


 B.  1.1.3 
 Loo  p 
 + 
 Port 


 Combinations/  GA(%) 


 11.66% 
 13.23% 
 20.33% 
 15.22% 


 B.  1.1.4 
 Combo 
 Other/  GA 


 (%) 


 20.00% 


 B.  1.1.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  GA(%) 


 35.56% 
 46.29% 
 42.41% 
 26.56% 


 B.  1.1.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  GA(%) 


 17.65% 
 8.14% 
 16.30% 


 6.34% 


 B.  1.1.7 
 Line 
 Sharin  g/ 


 GA(%) 


 25.00% 
 25.04% 
 22.27% 
 25.44% 


 B.  1.1.8 
 2W 
 Analo  g 


 Loop 
 Design/  GA(%) 


 29.82% 
 37.16% 
 34.74% 
 23.51% 


 B.  1.1.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 GA(%) 


 6.15% 
 11.48% 


 9.86% 
 6.01% 


 B.  1.1.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  GA(%) 


 63.64% 
 58.33% 
 46.38% 
 52.17% 


 B.  1.1.13 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Non-  Design/ 


 GA(%) 


 90.91% 
 100.00% 


 60.00% 
 87.50% 
 2,4 


 B.  1.1.14 
 Other 
 Desi  gn/ 


 GA(%) 


 30.37% 
 11.90% 
 28.25% 
 22.16% 


 B.  1.1.15 
 Other 
 Non-  Desi 


 gn/  GA(%) 


 26.38% 
 30.18% 
 26.03% 
 22.74% 


 B.  1.1.17 
 LNP 
 Standalone/  GA 


 (%) 


 10.35% 
 8.65% 
 7.22% 
 9.04% 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Partially 


 Mechanized 


 [O-  7] 


 B.  1.2.3 
 Loo  p 
 + 
 Port 


 Combinations/  GA(%) 


 30.42% 
 30.48% 
 41.71% 
 23.43% 


 B.  1.2.4 
 Combo 
 Other/  GA 


 (%) 


 0.00% 
 4 


 B.  1.2.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  GA(%) 


 2.90% 
 10.53% 
 10.45% 
 0.00% 


 B.  1.2.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  GA(%) 


 12.73% 
 8.15% 
 8.76% 
 0.00% 


 B.  1.2.7 
 Line 
 Sharin  g/ 


 GA(%) 


 51.98% 
 43.59% 
 34.67% 
 48.18% 


 B.  1.2.8 
 2W 
 Analo  g 


 Loop 
 Design/  GA(%) 


 22.32% 
 24.56% 
 29.89% 
 20.66% 


 B.  1.2.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 GA(%) 


 25.00% 
 27.85% 
 14.71% 
 17.39% 


 B.  1.2.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  GA(%) 


 31.03% 
 29.47% 
 33.03% 
 24.37% 


 B.  1.2.13 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Non-  Design/ 


 GA(%) 


 16.15% 
 26.21% 
 23.85% 
 21.30% 


 B.  1.2.14 
 Other 
 Desi  gn/ 


 GA(%) 


 31.11% 
 30.93% 
 25.12% 
 26.20% 


 B.  1.2.15 
 Other 
 Non-  Desi 


 gn/  GA(%) 


 17.46% 
 14.42% 
 15.41% 
 13.82% 


 B.  1.2.17 
 LNP 
 Standalone/  GA 


 (%) 


 20.84% 
 24.72% 
 22.96% 
 20.96% 


 G-  14 
382
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Georgia 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 % 
 Rejected 


 Service 
 Requests 


 - 
 Non-  Mechanized 


 [O-  7] 


 B.  1.3.1 
 Switch 
 Ports/  GA 


 (%) 


 0.00% 
 75.00% 
 66.67% 


 1,2,3 


 B.  1.3.2 
 Local 
 Interoffice 


 Trans  port/ 
 GA(%) 


 63.33% 
 28.57% 
 66.67% 
 41.67% 
 2,3 


 B.  1.3.3 
 Loo  p 
 + 
 Port 


 Combinations/  GA(%) 


 45.33% 
 45.14% 
 45.97% 
 53.56% 


 B.  1.3.4 
 Combo 
 Other/  GA 


 (%) 


 22.14% 
 35.71% 
 45.16% 
 39.13% 


 B.  1.3.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  GA(%) 


 28.36% 
 28.26% 
 42.08% 
 20.25% 


 B.  1.3.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  GA(%) 


 21.24% 
 21.74% 
 29.41% 
 31.37% 


 B.  1.3.7 
 Line 
 Sharin  g/ 


 GA(%) 


 22.36% 
 28.71% 
 32.94% 
 38.98% 


 B.  1.3.8 
 2W 
 Analo  g 


 Loop 
 Design/  GA(%) 


 24.64% 
 42.86% 
 46.49% 
 52.73% 


 B.  1.3.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 GA(%) 


 13.71% 
 22.96% 
 21.38% 
 23.32% 


 B.  1.3.10 
 2W 
 Analo  g 


 Loop 
 w/  INP 


 Design/  GA(%) 


 33.33% 
 75.00% 
 3,4 


 B.  1.3.11 
 2W 
 Analo  g 


 Loop 
 w/  INP 


 Non-  Design/ 


 GA(%) 


 50.00% 


 2 


 B.  1.3.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  GA(%) 


 66.67% 
 45.00% 
 68.18% 
 57.14% 


 B.  1.3.13 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Non-  Design/ 


 GA(%) 


 19.44% 
 39.29% 
 53.33% 
 42.11% 


 B.  1.3.14 
 Other 
 Desi  gn/ 


 GA(%) 


 29.00% 
 29.81% 
 30.30% 
 27.78% 


 B.  1.3.15 
 Other 
 Non-  Desi 


 gn/  GA(%) 


 29.06% 
 30.65% 
 26.86% 
 33.74% 


 B.  1.3.16 
 INP 
 Standalone/  GA 


 (%) 


 24.24% 
 41.67% 
 26.09% 
 40.00% 


 B.  1.3.17 
 LNP 
 Standalone/  GA 


 (%) 


 23.65% 
 26.86% 
 26.62% 
 34.02% 


 Reject 
 Interval 


 - 
 Mechanized 


 [O-  8] 


 B.  1.4.3 
 Loo  p 
 + 
 Port 


 Combinations/  GA(%) 


 92.70% 
 94.39% 
 94.64% 
 94.47% 


 B.  1.4.4 
 Combo 
 Other/  GA 


 (%) 


 50.00% 
 4 


 B.  1.4.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  GA(%) 


 99.65% 
 99.72% 
 98.23% 
 100.00% 


 B.  1.4.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  GA(%) 


 39.29% 
 42.86% 
 73.33% 
 77.78% 
 4 


 B.  1.4.7 
 Line 
 Sharin  g/ 


 GA(%) 


 29.81% 
 40.49% 
 43.86% 
 56.18% 


 B.  1.4.8 
 2W 
 Analo  g 


 Loop 
 Design/  GA(%) 


 86.44% 
 85.37% 
 87.84% 
 89.66% 


 B.  1.4.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 GA(%) 


 55.56% 
 50.00% 
 57.14% 
 60.00% 
 1 


 B.  1.4.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  GA(%) 


 92.86% 
 100.00% 


 96.88% 
 91.67% 
 2 


 B.  1.4.13 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Non-  Design/ 


 GA(%) 


 90.00% 
 100.00% 
 100.00% 
 85.71% 
 2,3,4 


 B.  1.4.14 
 Other 
 Desi  gn/ 


 GA(%) 


 95.24% 
 75.00% 
 70.77% 
 75.68% 


 B.  1.4.15 
 Other 
 Non-  Desi 


 gn/  GA(%) 


 53.50% 
 56.60% 
 51.11% 
 43.31% 


 B.  1.4.17 
 LNP 
 Standalone/  GA 


 (%) 


 100.00% 
 97.49% 
 94.84% 
 96.77% 


 Reject 
 Interval 


 - 
 Partially 


 Mechanized 


 - 
 10 


 hours 


 [O-  8] 


 B.  1.7.3 
 Loo  p 
 + 
 Port 


 Combinations/  GA(%) 


 95.69% 
 95.68% 
 86.55% 
 96.98% 


 G-  15 
383
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Georgia 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 B.  1.7.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  GA(%) 


 100.00% 
 75.00% 
 100.00% 


 1,2,3 


 B.  1.7.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  GA(%) 


 95.16% 
 100.00% 


 81.25% 
 50.00% 
 4 


 B.  1.7.7 
 Line 
 Sharin  g/ 


 GA(%) 


 74.77% 
 89.53% 
 83.93% 
 89.66% 


 B.  1.7.8 
 2W 
 Analo  g 


 Loop 
 Design/  GA(%) 


 94.00% 
 100.00% 


 78.18% 
 87.50% 


 B.  1.7.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 GA(%) 


 82.14% 
 95.45% 
 100.00% 


 90.63% 


 B.  1.7.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  GA(%) 


 89.19% 
 82.46% 
 83.05% 
 77.78% 


 B.  1.7.13 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Non-  Design/ 


 GA(%) 


 97.56% 
 86.84% 
 80.77% 
 95.83% 


 B.  1.7.14 
 Other 
 Desi  gn/ 


 GA(%) 


 93.94% 
 90.32% 
 90.74% 
 90.00% 


 B.  1.7.15 
 Other 
 Non-  Desi 


 gn/  GA(%) 


 78.60% 
 91.49% 
 93.55% 
 93.43% 


 B.  1.7.17 
 LNP 
 Standalone/  GA 


 (%) 


 87.87% 
 92.24% 
 93.01% 
 93.09% 


 Reject 
 Interval 


 - 
 Non-  Mechanized 


 [O-  8] 


 B.  1.8.1 
 Switch 
 Ports/  GA 


 (%) 


 100.00% 
 100.00% 


 2,3 


 B.  1.8.2 
 Local 
 Interoffice 


 Trans  port/ 
 GA(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 B.  1.8.3 
 Loo  p 
 + 
 Port 


 Combinations/  GA(%) 


 98.35% 
 99.48% 
 95.66% 
 97.99% 


 B.  1.8.4 
 Combo 
 Other/  GA 


 (%) 


 100.00% 
 100.00% 
 100.00% 
 98.18% 


 B.  1.8.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  GA(%) 


 100.00% 
 95.00% 
 98.70% 
 97.14% 


 B.  1.8.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  GA(%) 


 97.62% 
 100.00% 
 100.00% 
 100.00% 


 B.  1.8.7 
 Line 
 Sharin  g/ 


 GA(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  1.8.8 
 2W 
 Analo  g 


 Loop 
 Design/  GA(%) 


 100.00% 
 100.00% 
 100.00% 
 96.67% 


 B.  1.8.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 GA(%) 


 100.00% 
 100.00% 
 100.00% 
 98.94% 


 B.  1.8.10 
 2W 
 Analo  g 


 Loop 
 w/  INP 


 Design/  GA(%) 


 100.00% 
 100.00% 
 100.00% 
 1,3,4 


 B.  1.8.11 
 2W 
 Analo  g 


 Loop 
 w/  INP 


 Non-  Design/ 


 GA(%) 


 100.00% 


 2 


 B.  1.8.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  GA(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2 


 B.  1.8.13 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Non-  Design/ 


 GA(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,3,4 


 B.  1.8.14 
 Other 
 Desi  gn/ 


 GA(%) 


 99.44% 
 100.00% 


 98.59% 
 100.00% 


 B.  1.8.15 
 Other 
 Non-  Desi 


 gn/  GA(%) 


 99.30% 
 99.81% 
 99.49% 
 99.31% 


 B.  1.8.16 
 INP 
 Standalone/  GA 


 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1 


 B.  1.8.17 
 LNP 
 Standalone/  GA 


 (%) 


 100.00% 
 98.67% 
 98.40% 
 100.00% 


 FOC 
 Timeliness 


 - 
 Mechanized 


 [O-  9] 


 B.  1.9.3 
 Loo  p 
 + 
 Port 


 Combinations/  GA(%) 


 99.41% 
 99.55% 
 98.96% 
 98.82% 


 B.  1.9.4 
 Combo 
 Other/  GA 


 (%) 


 42.86% 


 B.  1.9.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  GA(%) 


 94.84% 
 92.12% 
 90.84% 
 98.08% 


 B.  1.9.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  GA(%) 


 95.87% 
 96.08% 
 91.30% 
 96.92% 


 B.  1.9.7 
 Line 
 Sharin  g/ 


 GA(%) 


 97.80% 
 98.82% 
 96.97% 
 98.19% 


 G-  16 
384
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Georgia 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 B.  1.9.8 
 2W 
 Analog 


 Loop 
 Design/  GA(%) 


 99.26% 
 100.00% 
 100.00% 
 98.94% 


 B.  1.9.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 GA(%) 


 100.00% 
 100.00% 
 97.64% 
 99.44% 


 B.  1.9.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  GA(%) 


 100.00% 
 100.00% 
 96.77% 
 100.00% 
 1,2 


 B.  1.9.13 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Non-  Design/ 


 GA(%) 


 100.00% 


 100.00% 
 100.00% 
 1,3,4 


 B.  1.9.14 
 Other 
 Desi  gn/ 


 GA(%) 


 98.95% 
 100.00% 


 98.70% 
 96.03% 


 B.  1.9.15 
 Other 
 Non-  Desi 


 gn/  GA(%) 


 97.18% 
 97.40% 
 96.84% 
 96.87% 


 B.  1.9.17 
 LNP 
 Standalone/  GA 


 (%) 


 98.48% 
 99.76% 
 98.79% 
 97.23% 


 FOC 
 Timeliness 


 - 
 Partially 


 Mechanized 


 - 
 10 


 hours 


 [O-  9] 


 B.  1.12.3 
 Loo  p 
 + 
 Port 


 Combinations/  GA(%) 


 93.45% 
 93.46% 
 90.53% 
 95.80% 


 B.  1.12.4 
 Combo 
 Other/  GA 


 (%) 


 50.00% 
 4 


 B.  1.12.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  GA(%) 


 78.95% 
 80.00% 
 94.23% 
 66.67% 
 4 


 B.  1.12.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  GA(%) 


 97.05% 
 99.16% 
 91.32% 
 85.00% 


 B.  1.12.7 
 Line 
 Sharin  g/ 


 GA(%) 


 89.08% 
 90.00% 
 93.58% 
 93.94% 


 B.  1.12.8 
 2W 
 Analo  g 


 Loop 
 Design/  GA(%) 


 97.22% 
 98.60% 
 82.09% 
 90.53% 


 B.  1.12.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 GA(%) 


 80.43% 
 82.61% 
 90.00% 
 92.47% 


 B.  1.12.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  GA(%) 


 92.41% 
 92.13% 
 83.41% 
 78.71% 


 B.  1.12.13 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Non-  Design/ 


 GA(%) 


 92.81% 
 96.23% 
 92.86% 
 89.41% 


 B.  1.12.14 
 Other 
 Desi  gn/ 


 GA(%) 


 91.18% 
 89.55% 
 92.50% 
 92.41% 


 B.  1.12.15 
 Other 
 Non-  Desi 


 gn/  GA(%) 


 72.50% 
 88.16% 
 94.53% 
 95.47% 


 B.  1.12.17 
 LNP 
 Standalone/  GA 


 (%) 


 93.74% 
 97.34% 
 92.99% 
 93.81% 


 FOC 
 Timeliness 


 - 
 Non-  Mechanized 


 [O-  9] 


 B.  1.13.1 
 Switch 
 Ports/  GA 


 (%) 


 100.00% 
 100.00% 
 100.00% 


 1,2,3 


 B.  1.13.2 
 Local 
 Interoffice 


 Trans  port/ 
 GA(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 B.  1.13.3 
 Loo  p 
 + 
 Port 


 Combinations/  GA(%) 


 98.66% 
 98.96% 
 97.63% 
 97.74% 


 B.  1.13.4 
 Combo 
 Other/  GA 


 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  1.13.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  GA(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  1.13.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  GA(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  1.13.7 
 Line 
 Sharin  g/ 


 GA(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  1.13.8 
 2W 
 Analo  g 


 Loop 
 Design/  GA(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  1.13.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 GA(%) 


 100.00% 
 100.00% 
 100.00% 
 99.69% 


 B.  1.13.10 
 2W 
 Analo  g 


 Loop 
 w/  INP 


 Design/  GA(%) 


 100.00% 
 100.00% 
 3,4 


 B.  1.13.11 
 2W 
 Analo  g 


 Loop 
 w/  INP 


 Non-  Design/ 


 GA(%) 


 B.  1.13.12 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/  GA(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3 


 B.  1.13.13 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Non-  Design/ 


 GA(%) 


 100.00% 
 100.00% 
 90.00% 
 100.00% 


 G-  17 
385
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Georgia 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 B.  1.13.14 
 Other 
 Design/  GA(%) 


 100.00% 
 99.76% 
 98.70% 
 99.33% 


 B.  1.13.15 
 Other 
 Non-  Desi 


 gn/  GA(%) 


 99.90% 
 99.58% 
 99.76% 
 98.72% 


 B.  1.13.16 
 INP 
 Standalone/  GA 


 (%) 


 95.00% 
 100.00% 
 100.00% 
 94.12% 


 B.  1.13.17 
 LNP 
 Standalone/  GA 


 (%) 


 100.00% 
 99.83% 
 99.58% 
 99.55% 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Mechanized 


 [O-  11] 


 B.  1.14.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  EDI/ 


 GA(%) 


 98.60% 
 98.89% 
 96.57% 
 99.55% 


 B.  1.14.3.2 
 Loo  p 
 + 
 Port 


 Combinations/  TAG/ 


 GA(%) 


 99.40% 
 98.92% 
 98.51% 
 99.97% 


 B.  1.14.4.1 
 Combo 
 Other/  EDI/ 


 GA  (%) 


 90.00% 


 B.  1.14.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  EDI/ 


 GA(%) 


 75.38% 
 98.48% 
 95.26% 
 97.64% 


 B.  1.14.5.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  TAG/ 


 GA(%) 


 79.31% 
 89.88% 
 87.06% 
 84.43% 


 B.  1.14.6.1 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  EDI/ 


 GA(%) 


 100.00% 
 100.00% 
 80.00% 
 92.59% 


 B.  1.14.6.2 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  TAG/ 


 GA(%) 


 95.10% 
 96.13% 
 91.46% 
 99.13% 


 B.  1.14.7.1 
 Line 
 Sharin  g/ 


 EDI/  GA(%) 


 99.78% 
 99.55% 
 96.31% 
 100.00% 


 B.  1.14.7.2 
 Line 
 Sharin  g/ 


 TAG/  GA(%) 


 95.71% 
 99.30% 
 93.55% 
 100.00% 


 B.  1.14.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  EDI/ 


 GA(%) 


 97.19% 
 95.79% 
 91.09% 
 97.86% 


 B.  1.14.8.2 
 2W 
 Analo  g 


 Loop 
 Design/  TAG/ 


 GA(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  1.14.9.1 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 EDI/  GA(%) 


 100.00% 
 94.74% 
 100.00% 
 2 


 B.  1.14.9.2 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 TAG/  GA(%) 


 95.38% 
 95.04% 
 98.37% 
 99.26% 


 B.  1.14.12.1 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  EDI/ 


 GA(%) 


 100.00% 
 91.67% 
 90.91% 
 100.00% 


 B.  1.14.12.2 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  TAG/ 


 GA(%) 


 100.00% 


 100.00% 
 1,3 


 B.  1.14.13.2 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/ 


 TAG/  GA(%) 


 100.00% 
 100.00% 
 80.00% 
 100.00% 
 2,4 


 B.  1.14.14.1 
 Other 
 Desi  gn/ 


 EDI/  GA(%) 


 100.00% 
 99.22% 
 93.26% 
 95.00% 


 B.  1.14.14.2 
 Other 
 Desi  gn/ 


 TAG/  GA(%) 


 100.00% 
 94.87% 
 100.00% 


 97.87% 


 B.  1.14.15.1 
 Other 
 Non-  Desi 


 gn/  EDI/ 
 GA(%) 


 97.90% 
 99.39% 
 96.96% 
 98.37% 


 B.  1.14.15.2 
 Other 
 Non-  Desi 


 gn/  TAG/ 
 GA(%) 


 98.12% 
 95.60% 
 96.83% 
 98.02% 


 B.  1.14.17.1 
 LNP 
 Standalone/  EDI/ 


 GA  (%) 


 98.54% 
 99.77% 
 99.48% 
 99.91% 


 B.  1.14.17.2 
 LNP 
 Standalone/  TAG/ 


 GA  (%) 


 100.00% 
 99.41% 
 95.93% 
 99.57% 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Partially 


 Mechanized 


 [O-  11] 


 B.  1.15.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  EDI/ 


 GA(%) 


 96.60% 
 96.23% 
 96.08% 
 98.74% 


 B.  1.15.3.2 
 Loo  p 
 + 
 Port 


 Combinations/  TAG/ 


 GA(%) 


 99.63% 
 99.58% 
 99.83% 
 99.83% 


 B.  1.15.4.1 
 Combo 
 Other/  EDI/ 


 GA  (%) 


 100.00% 
 4 


 B.  1.15.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  EDI/ 


 GA(%) 


 20.59% 
 67.39% 
 83.67% 
 66.67% 
 4 


 B.  1.15.5.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  TAG/ 


 GA(%) 


 40.00% 
 70.00% 
 66.67% 
 50.00% 
 4 


 G-  18 
386
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Georgia 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 B.  1.15.6.1 
 ISDN 
 Loop 
 (UDN, 


 UDC)/  EDI/ 


 GA(%) 


 100.00% 
 100.00% 
 93.10% 
 100.00% 
 4 


 B.  1.15.6.2 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  TAG/ 


 GA(%) 


 99.48% 
 100.00% 
 100.00% 
 100.00% 


 B.  1.15.7.1 
 Line 
 Sharin  g/ 


 EDI/  GA(%) 


 100.00% 
 100.00% 
 96.05% 
 100.00% 


 B.  1.15.7.2 
 Line 
 Sharin  g/ 


 TAG/  GA(%) 


 98.15% 
 98.85% 
 100.00% 
 100.00% 


 B.  1.15.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  EDI/ 


 GA(%) 


 98.94% 
 99.63% 
 93.04% 
 99.69% 


 B.  1.15.8.2 
 2W 
 Analo  g 


 Loop 
 Design/  TAG/ 


 GA(%) 


 100.00% 
 91.67% 
 100.00% 
 100.00% 
 4 


 B.  1.15.9.1 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 EDI/  GA(%) 


 100.00% 
 100.00% 


 100.00% 
 1,2,4 


 B.  1.15.9.2 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 TAG/  GA(%) 


 100.00% 
 98.70% 
 100.00% 


 99.44% 


 B.  1.15.12.1 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  EDI/ 


 GA(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  1.15.12.2 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  TAG/ 


 GA(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 3,4 


 B.  1.15.13.1 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Non-  Design/ 


 EDI/  GA(%) 


 100.00% 


 1 


 B.  1.15.13.2 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/ 


 TAG/  GA(%) 


 100.00% 
 100.00% 
 100.00% 
 99.07% 


 B.  1.15.14.1 
 Other 
 Desi  gn/ 


 EDI/  GA(%) 


 98.41% 
 100.00% 


 95.83% 
 99.38% 


 B.  1.15.14.2 
 Other 
 Desi  gn/ 


 TAG/  GA(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  1.15.15.1 
 Other 
 Non-  Desi 


 gn/  EDI/ 
 GA(%) 


 99.38% 
 94.79% 
 96.99% 
 99.71% 


 B.  1.15.15.2 
 Other 
 Non-  Desi 


 gn/  TAG/ 
 GA(%) 


 97.41% 
 98.05% 
 99.13% 
 99.79% 


 B.  1.15.17.1 
 LNP 
 Standalone/  EDI/ 


 GA  (%) 


 98.49% 
 99.76% 
 100.00% 
 100.00% 


 B.  1.15.17.2 
 LNP 
 Standalone/  TAG/ 


 GA  (%) 


 99.48% 
 100.00% 


 99.50% 
 98.87% 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 - 
 Non-  Mechanized 


 [O-  11] 


 B.  1.16.1 
 Switch 
 Ports/  GA 


 (%) 


 100.00% 
 100.00% 
 100.00% 


 1,2,3 


 B.  1.16.2 
 Local 
 Interoffice 


 Trans  port/ 
 GA(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2,3 


 B.  1.16.3 
 Loo  p 
 + 
 Port 


 Combinations/  GA(%) 


 94.82% 
 96.21% 
 94.59% 
 96.44% 


 B.  1.16.4 
 Combo 
 Other/  GA 


 (%) 


 97.14% 
 88.10% 
 98.92% 
 98.55% 


 B.  1.16.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  GA(%) 


 97.09% 
 100.00% 


 97.81% 
 96.32% 


 B.  1.16.6 
 ISDN 
 Loo 
 p 
 (UDN, 


 UDC)/  GA(%) 


 98.45% 
 98.55% 
 100.00% 
 100.00% 


 B.  1.16.7 
 Line 
 Sharin  g/ 


 GA(%) 


 100.00% 
 99.01% 
 97.65% 
 98.31% 


 B.  1.16.8 
 2W 
 Analo  g 


 Loop 
 Design/  GA(%) 


 94.20% 
 96.83% 
 96.49% 
 100.00% 


 B.  1.16.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 GA(%) 


 93.33% 
 91.51% 
 90.43% 
 95.85% 


 B.  1.16.10 
 2W 
 Analo  g 


 Loop 
 w/  INP 


 Design/  GA(%) 


 66.67% 
 100.00% 
 3,4 


 B.  1.16.11 
 2W 
 Analo  g 


 Loop 
 w/  INP 


 Non-  Design/ 


 GA(%) 


 50.00% 


 2 


 B.  1.16.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  GA(%) 


 91.67% 
 95.00% 
 95.45% 
 100.00% 


 B.  1.16.13 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Non-  Design/ 


 GA(%) 


 97.22% 
 96.43% 
 100.00% 
 100.00% 


 B.  1.16.14 
 Other 
 Desi  gn/ 


 GA(%) 


 98.85% 
 97.80% 
 96.13% 
 97.47% 


 G-  19 
387
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Georgia 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 B.  1.16.15 
 Other 
 Non-  Design/ 


 GA(%) 


 96.11% 
 96.34% 
 96.65% 
 98.94% 


 B.  1.16.16 
 INP 
 Standalone/  GA 


 (%) 


 84.85% 
 89.58% 
 73.91% 
 88.57% 


 B.  1.16.17 
 LNP 
 Standalone/  GA 


 (%) 


 96.40% 
 98.20% 
 94.26% 
 99.26% 


 UNBUNDLED 
 NETWORK 
 ELEMENTS 


 - 
 PROVISIONING 


 Order 
 Completion 


 Interval 
 [P-  4] 


 B.  2.1.2.1.1 
 Local 
 Interoffice 


 Transport/<  10 


 circuits/  Dis 
 patch/  GA( 
 days) 


 37.42 
 15.50 
 28.09 
 17.00 
 17.78 
 30.00 
 17.22 
 38.00 
 1,3,4 


 B.  2.1.3.1.1 
 Loop 
 + 
 Port 


 Combinations/<  10  circuits/  Dis  patch/  GA(  days) 


 3.79 
 4.24 
 4.28 
 4.53 
 5.47 
 4.81 
 6.26 
 4.98 


 B.  2.1.3.1.2 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Non- 


 Dis 
 patch/  GA( 


 days) 


 0.84 
 0.71 
 0.81 
 0.71 
 0.82 
 0.70 
 0.84 
 0.79 


 B.  2.1.3.1.3 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Switch 
 Based 


 Orders/  GA 
 (days) 


 0.33 
 0.33 
 0.33 
 0.33 
 0.33 
 0.33 
 0.33 
 0.33 


 B.  2.1.3.1.4 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Dispatch 


 In/  GA 
 (days) 


 1.54 
 1.26 
 1.59 
 1.38 
 1.57 
 1.29 
 1.51 
 1.41 


 B.  2.1.3.2.1 
 Loop 
 + 
 Port 


 Combinations/>=  10  circuits/  Dis  patch/  GA(  days) 


 10.23 
 6.86 
 11.03 


 5.18 
 12.42 


 5.42 
 10.91 


 21.33 
 1,4 


 B.  2.1.3.2.2 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Non- 


 Dis 
 patch/  GA( 


 days) 


 3.25 
 3.00 
 4.72 


 2.76 
 6.25 
 3.43 
 2.75 
 1,3,4 


 B.  2.1.3.2.4 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Dispatch 


 In/  GA 
 (days) 


 4.77 
 3.00 
 5.71 


 3.11 
 6.25 
 5.65 
 2.75 
 1,3,4 


 B.  2.1.4.1.1 
 Combo 
 Other/<  10 


 circuits/  Dis 
 patch/  GA( 
 days) 


 4.87 
 12.23 


 5.12 
 12.74 


 6.12 
 11.82 


 7.26 
 11.89 


 B.  2.1.6.3.1 
 UNE 
 ISDN/<  6 


 circuits/  Dis 


 patch/  GA( 
 days) 


 14.39 
 11.31 
 12.59 
 11.07 
 12.88 
 11.62 
 14.05 
 11.52 


 B.  2.1.6.4.1 
 UNE 
 ISDN/  6- 


 13 
 circuits/  Dis 


 patch/  GA( 
 days) 


 12.00 
 12.00 
 18.00 


 1 


 B.  2.1.7.3.1 
 Line 
 Sharin  g/< 


 6 
 circuits/  Dispatch/ 


 GA( 
 days) 


 3.97 
 5.96 
 3.99 
 5.07 
 4.07 
 5.42 
 2.78 
 4.55 


 B.  2.1.7.3.2 
 Line 
 Sharin  g/< 


 6 
 circuits/  Non- 


 Dispatch/  GA( 


 days) 


 3.58 
 3.88 
 3.78 
 4.15 
 3.65 
 3.84 
 2.39 
 3.81 


 B.  2.1.8.1.1 
 2W 
 Analog 


 Loop 
 Design/<  10 


 circuits/  Dis 
 patch/  GA( 
 days) 


 3.79 
 5.00 
 4.28 
 5.47 
 5.47 
 5.06 
 6.26 
 5.02 


 B.  2.1.8.2.1 
 2W 
 Analog 


 Loop 
 Design/>=  10 


 circuits/  Dis 
 patch/  GA( 
 days) 


 10.23 
 6.00 
 11.03 


 7.00 
 12.42 


 10.91 
 5.00 
 1,2,4 


 B.  2.1.9.1.1 
 2W 
 Analog 


 Loop 
 Non-  Design/< 


 10 


 circuits/  Dis 
 patch/  GA( 
 days) 


 3.69 
 3.42 
 4.17 
 3.75 
 4.80 
 3.28 
 6.05 
 3.65 


 B.  2.1.9.1.4 
 2W 
 Analog 


 Loop 
 Non-  Design/< 


 10 
 circuits/  Dispatch 


 In/  GA 
 (days) 


 1.55 
 1.57 
 1.50 
 1.55 
 1.00 
 1.53 
 4.00 
 2,3,4 


 G-  20 
388
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Georgia 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 B.  2.1.9.2.1 
 2W 
 Analog 


 Loop 
 Non-  Design/>= 


 10 


 circuits/  Dis 
 patch/  GA( 
 days) 


 8.53 
 6.00 
 9.60 
 6.00 
 10.68 


 6.00 
 9.88 
 4.00 
 1,2,3,4 


 B.  2.1.11.1.4 
 2W 
 Analog 


 Loop 
 w/  INP 


 Non-  Design/< 


 10 


 circuits/  Dis 
 patch 
 In/  GA( 


 days) 


 1.55 
 1.57 
 1.55 
 1.53 


 B.  2.1.12.1.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/<  10 


 circuits/  Dis 
 patch/  GA( 
 days) 


 3.79 
 4.94 
 4.28 
 5.09 
 5.47 
 5.35 
 6.26 
 6.00 


 B.  2.1.12.2.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/>=  10 


 circuits/  Dis 
 patch/  GA( 
 days) 


 10.23 
 11.03 
 6.00 
 12.42 


 12.00 
 10.91 


 6.00 
 2,3,4 


 B.  2.1.13.1.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/< 


 10 


 circuits/  Dis 
 patch/  GA( 
 days) 


 3.69 
 5.41 
 4.17 
 5.17 
 4.80 
 4.90 
 6.05 
 5.21 


 B.  2.1.13.1.4 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/< 


 10 


 circuits/  Dis 
 patch 
 In/  GA( 


 days) 


 1.55 
 4.50 
 1.57 
 5.11 
 1.55 
 5.00 
 1.53 
 5.13 


 2 


 B.  2.1.13.2.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/>= 


 10 


 circuits/  Dis 
 patch/  GA( 
 days) 


 8.53 
 7.67 
 9.60 
 7.00 
 10.68 


 7.80 
 9.88 
 8.00 
 1,2,3,4 


 B.  2.1.13.2.4 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/>= 


 10 


 circuits/  Dis 
 patch 
 In/  GA( 


 days) 


 1.00 
 3.88 
 5.67 
 6.00 
 1.25 


 3 


 B.  2.1.14.1.1 
 Other 
 Desi  gn/< 


 10 
 circuits/  Dispatch/ 


 GA( 
 days) 


 28.13 
 28.00 
 25.82 
 30.00 
 20.77 


 22.17 
 1,2 


 B.  2.1.15.1.1 
 Other 
 Non-  Design/< 


 10 
 circuits/  Dispatch/ 


 GA(  days) 
 3.79 
 6.00 
 4.28 
 6.00 
 5.47 
 6.00 
 6.26 


 1,2,3 


 B.  2.1.15.1.2 
 Other 
 Non-  Design/< 


 10 
 circuits/  Non- 


 Dispatch/  GA( 
 days) 


 0.84 
 0.33 
 0.81 
 0.33 
 0.82 


 0.84 
 10.00 
 1,2,4 


 B.  2.1.16.1.2 
 INP 
 (Standalone)/<  10 


 circuits/  Non- 
 Dispatch/  GA( 


 days) 
 0.83 


 0.80 
 0.81 
 1.00 
 0.82 
 0.33 
 3,4 


 B.  2.1.17.1.1 
 LNP 
 (Standalone)/<  10 


 circuits/  Dispatch/ 
 GA( 
 days) 


 3.69 
 0.33 
 4.17 


 4.80 
 0.56 
 6.05 
 0.33 
 1,3,4 


 B.  2.1.17.1.2 
 LNP 
 (Standalone)/<  10 


 circuits/  Non- 


 Dis 
 patch/  GA( 


 days) 


 0.83 
 0.68 
 0.80 
 0.79 
 0.81 
 0.74 
 0.82 
 0.75 


 B.  2.1.17.2.2 
 LNP 
 (Standalone)/>=  10 


 circuits/  Non- 


 Dis 
 patch/  GA( 


 days) 


 0.50 
 0.33 
 1.75 
 0.61 
 2.62 
 0.47 
 0.44 
 0.33 
 1,3,4 


 B.  2.1.18.1.1 
 Digital 
 Loop 
 < 
 DS1/<  10 


 circuits/  Dispatch/ 


 GA(  days) 
 5.03 
 8.66 
 4.85 
 8.21 
 5.02 
 8.88 
 3.79 
 8.05 


 B.  2.1.19.1.1 
 Digital 
 Loop 
 >= 
 DS1/<  10 


 circuits/  Dispatch/ 


 GA(  days) 
 26.81 
 6.27 
 28.27 


 5.93 
 25.90 


 6.01 
 25.27 


 6.33 


 Order 
 Completion 


 Interval 
 within 
 X 
 days 


 [P-  4] 


 G-  21 
389
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Georgia 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 B.  2.2.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL) 


 Loop 
 with 


 Conditionin  g/< 
 6 
 circuits/  Dispatch/ 


 GA( 
 days) 


 16.00 
 13.00 
 15.50 


 1,2,3 


 B.  2.2.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL) 


 Loop 
 w/  o 


 Conditionin  g/< 
 6 
 circuits/  Dispatch/ 


 GA( 
 days) 


 5.01 
 4.74 
 4.73 
 4.98 


 % 
 Jeopardies 


 - 
 Mechanized 


 [P-  2] 


 B.  2.5.3 
 Loo  p 
 + 
 Port 


 Combinations/  GA(%) 


 0.66% 
 0.16% 
 0.66% 
 0.16% 
 0.59% 
 0.14% 
 0.50% 
 0.11% 


 B.  2.5.4 
 Combo 
 Other/  GA 


 (%) 


 5.74% 
 6.03% 
 6.21% 
 7.62% 
 100.00% 


 4 


 B.  2.5.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  GA(%) 


 16.20% 
 17.68% 
 12.37% 
 10.10% 
 0.00% 


 B.  2.5.6 
 UNE 
 ISDN/  GA 


 (%) 


 8.76% 
 28.95% 


 7.90% 
 24.22% 
 10.43% 
 23.81% 
 11.15% 
 17.50% 


 B.  2.5.7 
 Line 
 Sharin  g/ 


 GA(%) 


 16.20% 
 0.00% 
 17.68% 


 0.00% 
 12.37% 


 0.00% 
 10.10% 


 0.00% 
 1,2,3,4 


 B.  2.5.8 
 2W 
 Analo  g 


 Loop 
 Design/  GA(%) 


 0.66% 
 12.41% 


 0.66% 
 7.14% 
 0.59% 
 9.04% 
 0.50% 
 7.96% 


 B.  2.5.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 GA(%) 


 1.29% 
 7.95% 
 1.33% 
 8.59% 
 1.16% 
 10.29% 


 0.97% 
 6.78% 


 B.  2.5.10 
 2W 
 Analo  g 


 Loop 
 w/  INP 


 Design/  GA(%) 


 0.66% 
 0.66% 
 0.59% 
 0.50% 


 B.  2.5.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  GA(%) 


 0.66% 
 3.17% 
 0.66% 
 3.64% 
 0.59% 
 3.27% 
 0.50% 
 2.94% 


 B.  2.5.13 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Non-  Design/ 


 GA(%) 


 1.29% 
 5.93% 
 1.33% 
 2.38% 
 1.16% 
 4.49% 
 0.97% 
 3.70% 


 B.  2.5.14 
 Other 
 Desi  gn/ 


 GA(%) 


 12.51% 
 14.68% 
 12.20% 
 13.91% 


 B.  2.5.15 
 Other 
 Non-  Desi 


 gn/  GA(%) 


 0.66% 
 0.66% 
 0.59% 
 0.50% 
 0.00% 


 4 


 B.  2.5.16 
 INP 
 (Standalone)/  GA(%) 


 0.65% 
 0.63% 
 0.56% 
 0.48% 


 B.  2.5.17 
 LNP 
 (Standalone)/  GA(%) 


 0.65% 
 0.00% 
 0.63% 
 0.00% 
 0.56% 
 0.00% 
 0.48% 
 0.00% 


 B.  2.5.18 
 Di 
 gital 


 Loop 


 < 
 DS1/  GA(%) 


 15.69% 
 28.95% 
 17.05% 
 24.22% 
 12.52% 
 23.81% 
 10.53% 
 9.81% 


 B.  2.5.19 
 Di 
 gital 


 Loop 


 >= 
 DS1/  GA(%) 


 8.55% 
 63.01% 
 11.76% 
 69.11% 
 8.21% 
 72.19% 


 0.78% 
 64.33% 


 % 
 Jeopardies 


 - 
 Non-  Mechanized 


 [P-  2] 


 B.  2.6.2 
 Local 
 Interoffice 


 Trans  port/ 
 GA(%) 


 0.00% 
 0.00% 
 0.00% 
 3,4 


 B.  2.6.3 
 Loo  p 
 + 
 Port 


 Combinations/  GA(%) 


 2.11% 
 2.41% 
 1.67% 
 1.74% 


 B.  2.6.4 
 Combo 
 Other/  GA 


 (%) 


 43.43% 
 41.27% 
 40.00% 
 37.16% 


 B.  2.6.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  GA(%) 


 4.15% 
 3.85% 
 4.00% 
 1.14% 


 B.  2.6.6 
 UNE 
 ISDN/  GA 


 (%) 


 12.00% 
 19.23% 
 9.09% 
 30.77% 


 B.  2.6.7 
 Line 
 Sharin  g/ 


 GA(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 


 B.  2.6.8 
 2W 
 Analo  g 


 Loop 
 Design/  GA(%) 


 8.70% 
 12.50% 


 5.00% 
 0.00% 
 2 


 B.  2.6.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 GA(%) 


 0.00% 
 4.88% 
 2.33% 
 5.26% 


 B.  2.6.10 
 2W 
 Analo  g 


 Loop 
 w/  INP 


 Design/  GA(%) 


 B.  2.6.11 
 2W 
 Analog 


 Loop 
 w/  INP 


 Non-  Design/ 


 GA(%) 


 0.00% 
 4 


 B.  2.6.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  GA(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3,4 


 B.  2.6.13 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Non-  Design/ 


 GA(%) 


 0.00% 
 6.25% 
 0.00% 
 0.00% 
 4 


 G-  22 
390
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Georgia 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 B.  2.6.14 
 Other 
 Design/  GA(%) 


 0.00% 
 0.00% 


 1,2 


 B.  2.6.15 
 Other 
 Non-  Desi 


 gn/  GA(%) 


 0.00% 
 0.00% 
 0.00% 


 1,2,3 


 B.  2.6.16 
 INP 
 (Standalone)/  GA(%) 


 0.00% 
 0.00% 
 3,4 


 B.  2.6.17 
 LNP 
 (Standalone)/  GA(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 


 B.  2.6.18 
 Di  gital 
 Loop 
 < 
 DS1/  GA(%) 


 5.26% 
 5.48% 
 3.02% 
 5.75% 


 B.  2.6.19 
 Di  gital 
 Loop 
 >= 
 DS1/  GA(%) 


 37.72% 
 37.01% 
 38.55% 
 46.15% 


 Average 
 Jeopardy 


 Notice 
 Interval 


 - 
 Mechanized 


 [P-  2] 


 B.  2.8.3 
 Loo  p 
 + 
 Port 


 Combinations/  GA( 


 hours) 


 168.96 
 187.34 
 208.03 
 218.01 


 B.  2.8.4 
 Combo 
 Other/  GA 


 (hours) 


 338.02 
 4 


 B.  2.8.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  GA( 


 hours) 


 B.  2.8.6 
 UNE 
 ISDN/  GA( 


 hours) 


 326.52 
 339.47 
 326.01 
 346.69 


 B.  2.8.8 
 2W 
 Analo  g 


 Loop 
 Design/  GA( 


 hours) 


 176.21 
 208.03 
 135.74 
 192.65 
 4 


 B.  2.8.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 GA( 
 hours) 


 154.25 
 118.23 
 179.09 
 181.93 
 4 


 B.  2.8.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  GA( 


 hours) 


 247.68 
 173.85 
 153.74 
 228.25 
 1,2,3,4 


 B.  2.8.13 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Non-  Design/ 


 GA( 
 hours) 


 153.30 
 159.48 
 226.60 
 145.22 
 1,2,3,4 


 B.  2.8.18 
 Di 
 gital 


 Loop 


 < 
 DS1/  GA( 


 hours) 


 326.52 
 339.47 
 326.01 
 346.69 


 B.  2.8.19 
 Di 
 gital 


 Loop 


 >= 
 DS1/  GA( 


 hours) 


 194.00 
 192.20 
 190.20 
 186.75 


 Average 
 Jeopardy 


 Notice 
 Interval 


 - 
 Non-  Mechanized 


 [P-  2] 


 B.  2.9.3 
 Loo  p 
 + 
 Port 


 Combinations/  GA( 


 hours) 


 163.27 
 157.89 
 211.97 
 147.04 


 B.  2.9.4 
 Combo 
 Other/  GA 


 (hours) 


 320.84 
 333.11 
 328.43 
 328.61 


 B.  2.9.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  GA( 


 hours) 


 223.24 
 352.47 
 196.11 
 135.12 
 1,2,3,4 


 B.  2.9.6 
 UNE 
 ISDN/  GA 


 (hours) 


 323.34 
 316.84 
 326.98 
 289.35 
 2,3,4 


 B.  2.9.8 
 2W 
 Analo  g 


 Loop 
 Design/  GA( 


 hours) 


 115.67 
 75.78 
 135.27 


 1,2,3 


 B.  2.9.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 GA( 
 hours) 


 175.23 
 158.63 


 62.67 
 2,3,4 


 B.  2.9.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  GA( 


 hours) 


 B.  2.9.18 
 Digital 
 Loop 
 < 
 DS1/  GA( 


 hours) 


 286.37 
 328.72 
 316.13 
 258.50 
 2,3,4 


 B.  2.9.19 
 Di 
 gital 


 Loop 


 >= 
 DS1/  GA( 


 hours) 


 175.56 
 195.67 
 188.22 
 255.22 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Mechanized 


 [P-  2] 


 B.  2.10.3 
 Loo  p 
 + 
 Port 


 Combinations/  GA(%) 


 100.00% 
 100.00% 
 98.67% 
 100.00% 


 B.  2.10.4 
 Combo 
 Other/  GA 


 (%) 


 100.00% 
 4 


 B.  2.10.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  GA(%) 


 B.  2.10.6 
 UNE 
 ISDN/  GA(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  2.10.8 
 2W 
 Analo  g 


 Loop 
 Design/  GA(%) 


 100.00% 
 100.00% 
 100.00% 
 88.89% 
 4 


 G-  23 
391
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Georgia 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 B.  2.10.9 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 GA(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 4 


 B.  2.10.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  GA(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 B.  2.10.13 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Non-  Design/ 


 GA(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 B.  2.10.18 
 Di 
 gital 


 Loop 


 < 
 DS1/  GA(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  2.10.19 
 Di 
 gital 


 Loop 


 >= 
 DS1/  GA(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 % 
 Jeopardy 


 Notice 
 >= 
 48 
 hours 


 - 
 Non-  Mechanized 


 [P-  2] 


 B.  2.11.3 
 Loo  p 
 + 
 Port 


 Combinations/  GA(%) 


 100.00% 
 92.86% 
 100.00% 


 90.91% 


 B.  2.11.4 
 Combo 
 Other/  GA 


 (%) 


 100.00% 
 100.00% 
 99.33% 
 98.92% 


 B.  2.11.5 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  GA(%) 


 100.00% 
 100.00% 
 87.50% 
 100.00% 
 1,2,3,4 


 B.  2.11.6 
 UNE 
 ISDN/  GA 


 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 B.  2.11.8 
 2W 
 Analo  g 


 Loop 
 Design/  GA(%) 


 100.00% 
 100.00% 
 100.00% 


 1,2,3 


 B.  2.11.9 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 GA(%) 


 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 B.  2.11.12 
 2W 
 Analo  g 


 Loop 
 w/  LNP 


 Design/  GA(%) 


 B.  2.11.18 
 Digital 
 Loop 
 < 
 DS1/  GA(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 B.  2.11.19 
 Di 
 gital 


 Loop 


 >= 
 DS1/  GA(%) 


 100.00% 
 98.21% 
 100.00% 
 100.00% 


 Coordinated 
 Customers 
 Conversions 


 [P-  7] 


 B.  2.12.1 
 Loo  ps 
 with 
 INP/  GA(%) 


 B.  2.12.2 
 Loops 
 with 
 LNP/  GA(%) 


 99.88% 
 99.15% 
 99.87% 
 99.64% 


 % 
 Hot 


 Cuts 


 > 
 15 


 minutes 


 Early 
 [P-  7A] 


 B.  2.13.1 
 Time-  S 
 pecific 
 SL1/  GA(%) 


 1.74% 
 0.00% 
 0.00% 
 0.00% 


 B.  2.13.2 
 Time-  S 
 pecific 
 SL2/  GA(%) 


 2.08% 
 0.00% 
 3.85% 
 8.33% 


 B.  2.13.3 
 Non-  Time 
 Specific 
 SL1/  GA(%) 


 0.00% 
 0.00% 


 0.00% 
 2,4 


 B.  2.13.4 
 Non-  Time 
 Specific 
 SL2/  GA(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 


 Hot 
 Cut 
 Timeliness 


 [P-  7A] 


 B.  2.14.1 
 Time-  S 
 pecific 
 SL1/  GA(%) 


 98.26% 
 97.80% 
 100.00% 
 100.00% 


 B.  2.14.2 
 Time-  S 
 pecific 
 SL2/  GA(%) 


 97.92% 
 92.31% 
 96.15% 
 91.67% 


 B.  2.14.3 
 Non-  Time 
 Specific 
 SL1/  GA(%) 


 100.00% 
 100.00% 


 100.00% 
 2,4 


 B.  2.14.4 
 Non-  Time 
 Specific 
 SL2/  GA(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 % 
 Hot 


 Cuts 


 > 
 15 


 minutes 


 Late 
 [P-  7A] 


 B.  2.15.1 
 Time-  S 
 pecific 
 SL1/  GA(%) 


 0.00% 
 2.20% 
 0.00% 
 0.00% 


 B.  2.15.2 
 Time-  S 
 pecific 
 SL2/  GA(%) 


 0.00% 
 7.69% 
 0.00% 
 0.00% 


 B.  2.15.3 
 Non-  Time 
 Specific 
 SL1/  GA(%) 


 0.00% 
 0.00% 


 0.00% 
 2,4 


 B.  2.15.4 
 Non-  Time 
 Specific 
 SL2/  GA(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 


 G-  24 
392
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Georgia 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 Average 
 Recovery 


 Time 
 - 
 CCC 


 [P-  7B] 


 B.  2.16.2 
 Loo  ps 
 with 
 LNP/  GA( 


 minutes) 


 119.87 
 129.63 
 114.22 
 255.34 
 1,2,3,4 


 % 
 Provisioning 


 Troubles 
 within 
 7 
 Days 


 - 
 Hot 


 Cuts 


 [P-  7C] 


 B.  2.17.1.1 
 UNE 
 Loo 
 p 
 Design/  Dispatch/ 


 GA(%) 


 2.86% 
 1.30% 
 1.91% 
 4.27% 


 B.  2.17.2.1 
 UNE 
 Loo 
 p 
 Non-  Design/ 


 Dispatch/  GA(%) 


 2.46% 
 0.68% 
 2.33% 
 0.34% 


 B.  2.17.2.2 
 UNE 
 Loo 
 p 
 Non-  Design/ 


 Non-  Dispatch/ 


 GA(%) 


 1.96% 
 0.00% 
 2.17% 
 0.00% 


 % 
 Missed 


 Installation 


 Appointments 


 [P-  3] 


 B.  2.18.2.1.1 
 Local 
 Interoffice 


 Transport/<  10 


 circuits/  Dis 
 patch/  GA(%) 


 0.68% 
 0.00% 
 0.68% 
 0.00% 
 0.95% 
 0.00% 
 1.22% 
 0.00% 
 1,3,4 


 B.  2.18.3.1.1 
 Loop 
 + 
 Port 


 Combinations/<  10  circuits/  Dis  patch/  GA(%) 


 3.40% 
 3.54% 
 3.17% 
 2.70% 
 3.91% 
 2.85% 
 5.77% 
 2.75% 


 B.  2.18.3.1.2 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Non- 


 Dis 
 patch/  GA(%) 


 0.01% 
 0.05% 
 0.01% 
 0.06% 
 0.17% 
 0.08% 
 0.06% 
 0.06% 


 B.  2.18.3.1.3 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Switch 
 Based 


 Orders/  GA 
 (%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 B.  2.18.3.1.4 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Dispatch 


 In/  GA 
 (%) 


 0.03% 
 0.07% 
 0.04% 
 0.08% 
 0.38% 
 0.09% 
 0.12% 
 0.07% 


 B.  2.18.3.2.1 
 Loop 
 + 
 Port 


 Combinations/>=  10  circuits/  Dis  patch/  GA(%) 


 4.58% 
 27.27% 


 5.66% 
 13.33% 


 5.28% 
 6.25% 
 4.85% 
 16.67% 


 4 


 B.  2.18.3.2.2 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Non- 


 Dis 
 patch/  GA(%) 


 0.00% 
 0.00% 
 1.76% 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1,3,4 


 B.  2.18.3.2.4 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Dispatch 


 In/  GA 
 (%) 


 0.00% 
 0.00% 
 2.17% 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 1,3,4 


 B.  2.18.4.1.1 
 Combo 
 Other/<  10 


 circuits/  Dis 
 patch/  GA(%) 


 3.44% 
 0.58% 
 3.21% 
 1.08% 
 3.92% 
 0.00% 
 5.70% 
 1.10% 


 B.  2.18.5.1.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/<  10 


 circuits/  Dis 
 patch/  GA(%) 


 4.01% 
 0.45% 
 3.51% 
 0.00% 
 4.17% 
 0.00% 
 5.20% 
 0.00% 


 B.  2.18.6.1.1 
 UNE 
 ISDN/<  10 


 circuits/  Dis 
 patch/  GA(%) 


 8.00% 
 2.31% 
 3.25% 
 0.00% 
 5.35% 
 1.11% 
 4.58% 
 2.13% 


 B.  2.18.7.1.1 
 Line 
 Sharin  g/< 


 10 
 circuits/  Dispatch/ 


 GA(%) 


 4.01% 
 4.81% 
 3.51% 
 5.49% 
 4.17% 
 2.99% 
 5.20% 
 10.00% 


 B.  2.18.7.1.2 
 Line 
 Sharin  g/< 


 10 
 circuits/  Non- 


 Dispatch/  GA(%) 


 0.00% 
 0.00% 
 0.06% 
 0.00% 
 0.00% 
 0.00% 
 0.03% 
 0.98% 


 B.  2.18.8.1.1 
 2W 
 Analog 


 Loop 
 Design/<  10 


 circuits/  Dispatch/ 


 GA(%) 
 3.40% 


 0.63% 
 3.17% 
 0.00% 
 3.91% 
 0.55% 
 5.77% 
 2.34% 


 B.  2.18.8.2.1 
 2W 
 Analog 


 Loop 
 Design/>=  10 


 circuits/  Dispatch/ 
 GA(%) 


 4.58% 
 0.00% 
 5.66% 
 0.00% 
 5.28% 
 0.00% 
 4.85% 
 0.00% 
 1,2,3,4 


 G-  25 
393
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Georgia 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 B.  2.18.9.1.1 
 2W 
 Analog 


 Loop 
 Non-  Design/< 


 10 


 circuits/  Dis 
 patch/  GA(%) 


 3.36% 
 1.17% 
 3.16% 
 0.00% 
 3.97% 
 0.00% 
 5.90% 
 0.00% 


 B.  2.18.9.1.4 
 2W 
 Analog 


 Loop 
 Non-  Design/< 


 10 
 circuits/  Dispatch 


 In/  GA 
 (%) 


 0.02% 
 0.00% 
 0.03% 
 0.00% 
 0.39% 
 0.00% 
 0.13% 
 0.00% 
 1,2,3,4 


 B.  2.18.9.2.1 
 2W 
 Analog 


 Loop 
 Non-  Design/>= 


 10 


 circuits/  Dis 
 patch/  GA(%) 


 4.43% 
 0.00% 
 6.53% 
 0.00% 
 6.09% 
 0.00% 
 4.62% 
 25.00% 
 1,2,3,4 


 B.  2.18.10.1.1 
 2W 
 Analog 


 Loop 
 w/  INP 


 Design/<  10 


 circuits/  Dis 
 patch/  GA(%) 


 3.40% 
 3.17% 
 3.91% 
 5.77% 


 B.  2.18.11.1.1 
 2W 
 Analog 


 Loop 
 w/  INP 


 Non-  Design/< 


 10 


 circuits/  Dis 
 patch/  GA(%) 


 3.36% 
 3.16% 
 3.97% 
 5.90% 
 0.00% 


 4 


 B.  2.18.11.1.4 
 2W 
 Analog 


 Loop 
 w/  INP 


 Non-  Design/< 


 10 


 circuits/  Dis 
 patch 
 In/  GA(%) 


 0.02% 
 0.03% 
 0.39% 
 0.13% 


 B.  2.18.12.1.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/<  10 


 circuits/  Dis 
 patch/  GA(%) 


 3.40% 
 0.00% 
 3.17% 
 0.00% 
 3.91% 
 0.00% 
 5.77% 
 0.00% 


 B.  2.18.12.2.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/>=  10 


 circuits/  Dis 
 patch/  GA(%) 


 4.58% 
 0.00% 
 5.66% 
 0.00% 
 5.28% 
 0.00% 
 4.85% 
 25.00% 
 1,2,3,4 


 B.  2.18.13.1.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/< 


 10 


 circuits/  Dis 
 patch/  GA(%) 


 3.36% 
 0.00% 
 3.16% 
 0.00% 
 3.97% 
 0.00% 
 5.90% 
 0.00% 


 B.  2.18.13.1.4 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/< 


 10 


 circuits/  Dis 
 patch 
 In/  GA(%) 


 0.02% 
 0.00% 
 0.03% 
 0.00% 
 0.39% 
 0.00% 
 0.13% 
 0.00% 


 B.  2.18.13.2.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/>= 


 10 


 circuits/  Dis 
 patch/  GA(%) 


 4.43% 
 0.00% 
 6.53% 
 0.00% 
 6.09% 
 0.00% 
 4.62% 
 0.00% 
 1,2,3,4 


 B.  2.18.13.2.4 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/>= 


 10 


 circuits/  Dis 
 patch 
 In/  GA(%) 


 0.00% 
 37.50% 


 0.00% 
 0.00% 
 0.00% 


 3 


 B.  2.18.14.1.1 
 Other 
 Desi  gn/< 


 10 
 circuits/  Dispatch/ 


 GA(%) 


 4.36% 
 0.00% 
 4.12% 
 0.00% 
 4.01% 


 4.62% 


 1,2 


 B.  2.18.15.1.1 
 Other 
 Non-  Desi 


 gn/<  10 
 circuits/  Dispatch/ 


 GA(%) 
 3.40% 
 0.00% 
 3.17% 
 0.00% 
 3.91% 
 0.00% 
 5.77% 


 1,2,3 


 B.  2.18.15.1.2 
 Other 
 Non-  Design/< 


 10 
 circuits/  Non- 


 Dispatch/  GA(%) 


 0.01% 
 0.00% 
 0.01% 
 0.00% 
 0.17% 


 0.06% 
 0.00% 
 1,2,4 


 B.  2.18.16.1.2 
 INP 
 (Standalone)/<  10 


 circuits/  Non- 
 Dispatch/  GA(%) 


 0.01% 
 0.01% 
 0.17% 
 0.00% 
 0.06% 
 0.00% 


 3,4 


 B.  2.18.17.1.1 
 LNP 
 (Standalone)/<  10 


 circuits/  Dispatch/ 
 GA(%) 
 3.36% 
 0.00% 
 3.16% 
 0.00% 
 3.97% 
 0.00% 
 5.90% 
 0.00% 
 1,2,3,4 


 B.  2.18.17.1.2 
 LNP 
 (Standalone)/<  10 


 circuits/  Non- 
 Dispatch/  GA(%) 


 0.01% 
 0.06% 
 0.01% 
 0.07% 
 0.17% 
 0.34% 
 0.06% 
 0.06% 


 B.  2.18.17.2.1 
 LNP 
 (Standalone)/>=  10 


 circuits/  Dispatch/ 
 GA(%) 
 4.43% 


 6.53% 
 6.09% 
 0.00% 
 4.62% 


 3 


 G-  26 
394
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Georgia 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 B.  2.18.17.2.2 
 LNP 
 (Standalone)/>=  10 


 circuits/  Non- 
 Dispatch/  GA(%) 


 0.00% 
 0.00% 
 15.00% 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 1 


 B.  2.18.18.1.1 
 Di 
 gital 


 Loop 


 < 
 DS1/<  10 


 circuits/  Dispatch/ 


 GA(%) 
 4.21% 
 1.42% 
 3.53% 
 0.00% 
 4.23% 
 0.57% 
 5.30% 
 0.99% 


 B.  2.18.19.1.1 
 Di 
 gital 


 Loop 


 >= 
 DS1/<  10 


 circuits/  Dispatch/ 


 GA(%) 
 3.49% 
 0.51% 
 4.39% 
 1.08% 
 4.58% 
 2.56% 
 2.07% 
 0.96% 


 % 
 Provisioning 


 Troubles 
 within 
 30 
 Days 


 [P-  9] 


 B.  2.19.2.1.1 
 Local 
 Interoffice 


 Transport/<  10 


 circuits/  Dis 
 patch/  GA(%) 


 6.82% 
 0.00% 
 6.68% 
 50.00% 


 8.31% 
 0.00% 
 8.35% 
 0.00% 
 1,2,4 


 B.  2.19.3.1.1 
 Loop 
 + 
 Port 


 Combinations/<  10  circuits/  Dis  patch/  GA(%) 


 11.92% 
 12.58% 
 11.43% 
 12.25% 
 11.97% 
 11.17% 
 13.09% 
 10.04% 


 B.  2.19.3.1.2 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Non- 


 Dis 
 patch/  GA(%) 


 3.93% 
 2.71% 
 4.13% 
 2.59% 
 4.16% 
 2.58% 
 4.22% 
 2.62% 


 B.  2.19.3.1.3 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Switch 
 Based 


 Orders/  GA 
 (%) 


 4.20% 
 3.49% 
 4.46% 
 3.33% 
 4.67% 
 3.25% 
 4.47% 
 3.07% 


 B.  2.19.3.1.4 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Dispatch 


 In/  GA 
 (%) 


 3.62% 
 2.50% 
 3.72% 
 2.38% 
 3.45% 
 2.43% 
 3.89% 
 2.53% 


 B.  2.19.3.2.1 
 Loop 
 + 
 Port 


 Combinations/>=  10  circuits/  Dis  patch/  GA(%) 


 20.00% 
 27.27% 
 17.61% 
 0.00% 
 18.24% 
 13.33% 
 21.83% 
 18.75% 


 B.  2.19.3.2.2 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Non- 


 Dis 
 patch/  GA(%) 


 4.76% 
 7.69% 
 9.95% 
 50.00% 
 10.92% 


 5.46% 
 20.00% 


 2,4 


 B.  2.19.3.2.3 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Switch 
 Based 


 Orders/  GA 
 (%) 


 17.07% 
 13.24% 
 16.67% 
 14.77% 


 B.  2.19.3.2.4 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Dispatch 


 In/  GA 
 (%) 


 3.26% 
 7.69% 
 8.27% 
 50.00% 


 9.57% 


 3.98% 
 20.00% 


 2,4 


 B.  2.19.4.1.1 
 Combo 
 Other/<  10 


 circuits/  Dis 
 patch/  GA(%) 


 11.67% 
 17.39% 
 11.21% 
 14.70% 
 11.80% 
 13.21% 
 12.80% 
 12.14% 


 B.  2.19.4.1.4 
 Combo 
 Other/<  10 


 circuits/  Dis 


 patch 
 In/  GA(%) 


 11.67% 
 11.21% 
 11.80% 
 12.80% 


 B.  2.19.5.1.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/<  10 


 circuits/  Dis 
 patch/  GA(%) 


 5.09% 
 4.12% 
 3.97% 
 4.05% 
 5.27% 
 5.16% 
 4.77% 
 5.43% 


 B.  2.19.6.1.1 
 UNE 
 ISDN/<  10 


 circuits/  Dis 
 patch/  GA(%) 


 10.37% 
 5.85% 
 10.12% 


 5.09% 
 10.06% 
 10.06% 
 17.30% 
 6.11% 


 B.  2.19.7.1.1 
 Line 
 Sharin  g/< 


 10 
 circuits/  Dispatch/ 


 GA(%) 


 5.09% 
 27.06% 


 3.97% 
 39.42% 


 5.27% 
 35.16% 


 4.77% 
 28.36% 


 B.  2.19.7.1.2 
 Line 
 Sharin  g/< 


 10 
 circuits/  Non- 


 Dispatch/  GA(%) 


 2.56% 
 19.40% 


 2.06% 
 11.30% 


 3.51% 
 13.11% 


 4.13% 
 16.15% 


 B.  2.19.8.1.1 
 2W 
 Analog 


 Loop 
 Design/<  10 


 circuits/  Dispatch/ 


 GA(%) 
 11.92% 


 5.00% 
 11.43% 


 8.23% 
 11.97% 


 8.28% 
 13.09% 


 9.29% 


 B.  2.19.8.2.1 
 2W 
 Analog 


 Loop 
 Design/>=  10 


 circuits/  Dis 
 patch/  GA(%) 


 20.00% 
 0.00% 
 17.61% 


 0.00% 
 18.24% 


 0.00% 
 21.83% 


 0.00% 
 1,2,3,4 


 G-  27 
395
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Georgia 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 B.  2.19.9.1.1 
 2W 
 Analog 


 Loop 
 Non-  Design/< 


 10 


 circuits/  Dis 
 patch/  GA(%) 


 11.98% 
 5.75% 
 11.45% 


 7.02% 
 11.97% 
 10.18% 
 13.26% 
 8.09% 


 B.  2.19.9.1.4 
 2W 
 Analog 


 Loop 
 Non-  Design/< 


 10 
 circuits/  Dispatch 


 In/  GA 
 (%) 


 3.80% 
 3.82% 
 0.00% 
 3.43% 
 50.00% 


 3.91% 
 0.00% 
 2,3,4 


 B.  2.19.9.2.1 
 2W 
 Analog 


 Loop 
 Non-  Design/>= 


 10 


 circuits/  Dis 
 patch/  GA(%) 


 20.39% 
 0.00% 
 16.26% 


 0.00% 
 16.08% 


 0.00% 
 21.32% 


 0.00% 
 1,2,3,4 


 B.  2.19.10.1.1 
 2W 
 Analog 


 Loop 
 w/  INP 


 Design/<  10 


 circuits/  Dis 
 patch/  GA(%) 


 11.92% 
 0.00% 
 11.43% 


 11.97% 
 13.09% 


 1 


 B.  2.19.11.1.1 
 2W 
 Analog 


 Loop 
 w/  INP 


 Non-  Design/< 


 10 


 circuits/  Dis 
 patch/  GA(%) 


 11.98% 
 11.45% 
 11.97% 
 13.26% 


 B.  2.19.11.1.4 
 2W 
 Analog 


 Loop 
 w/  INP 


 Non-  Design/< 


 10 


 circuits/  Dis 
 patch 
 In/  GA(%) 


 3.80% 
 0.00% 
 3.82% 


 3.43% 
 3.91% 


 1 


 B.  2.19.11.2.1 
 2W 
 Analog 


 Loop 
 w/  INP 


 Non-  Design/>= 


 10 


 circuits/  Dis 
 patch/  GA(%) 


 20.39% 
 16.26% 
 16.08% 
 21.32% 


 B.  2.19.12.1.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/<  10 


 circuits/  Dis 
 patch/  GA(%) 


 11.92% 
 10.61% 
 11.43% 
 6.35% 
 11.97% 


 8.41% 
 13.09% 
 14.62% 


 B.  2.19.12.2.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/>=  10 


 circuits/  Dis 
 patch/  GA(%) 


 20.00% 
 0.00% 
 17.61% 
 100.00% 


 18.24% 
 0.00% 
 21.83% 


 0.00% 
 1,2,3,4 


 B.  2.19.13.1.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/< 


 10 


 circuits/  Dis 
 patch/  GA(%) 


 11.98% 
 9.09% 
 11.45% 


 3.09% 
 11.97% 
 12.66% 
 13.26% 
 5.06% 


 B.  2.19.13.1.4 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/< 


 10 


 circuits/  Dis 
 patch 
 In/  GA(%) 


 3.80% 
 4.55% 
 3.82% 
 0.00% 
 3.43% 
 5.88% 
 3.91% 
 0.00% 


 B.  2.19.13.2.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/>= 


 10 


 circuits/  Dis 
 patch/  GA(%) 


 20.39% 
 0.00% 
 16.26% 


 0.00% 
 16.08% 


 0.00% 
 21.32% 
 28.57% 
 1,2,3,4 


 B.  2.19.13.2.4 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/>= 


 10 


 circuits/  Dis 
 patch 
 In/  GA(%) 


 12.50% 
 0.00% 
 50.00% 


 0.00% 
 0.00% 
 0.00% 


 1,4 


 B.  2.19.14.1.1 
 Other 
 Desi 
 gn/<  10 


 circuits/  Dispatch/ 


 GA(%) 


 5.71% 
 0.00% 
 6.16% 
 0.00% 
 7.32% 
 0.00% 
 5.73% 


 1,2,3 


 B.  2.19.15.1.1 
 Other 
 Non-  Desi 


 gn/<  10 
 circuits/  Dispatch/ 


 GA(%) 
 11.92% 


 11.43% 
 0.00% 
 11.97% 
 50.00% 
 13.09% 
 0.00% 
 2,3,4 


 B.  2.19.15.1.2 
 Other 
 Non-  Design/< 


 10 
 circuits/  Non- 


 Dispatch/  GA(%) 


 3.93% 
 4.13% 
 0.00% 
 4.16% 
 0.00% 
 4.22% 


 2,3 


 B.  2.19.15.2.1 
 Other 
 Non-  Desi 


 gn/>=  10 
 circuits/  Dispatch/ 


 GA(%) 
 20.00% 


 17.61% 
 18.24% 
 21.83% 


 B.  2.19.16.1.2 
 INP 
 (Standalone)/<  10 


 circuits/  Non- 
 Dispatch/  GA(%) 


 4.02% 
 4.16% 
 4.15% 
 4.22% 
 0.00% 


 4 


 B.  2.19.17.1.1 
 LNP 
 (Standalone)/<  10 


 circuits/  Dispatch/ 
 GA(%) 
 11.98% 
 0.00% 
 11.45% 


 0.00% 
 11.97% 


 0.00% 
 13.26% 


 0.00% 
 1,2,3,4 


 G-  28 
396
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Georgia 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 B.  2.19.17.1.2 
 LNP 
 (Standalone)/<  10 


 circuits/  Non- 
 Dispatch/  GA(%) 


 4.02% 
 0.00% 
 4.16% 
 0.00% 
 4.15% 
 0.00% 
 4.22% 
 0.00% 


 B.  2.19.17.2.1 
 LNP 
 (Standalone)/>=  10 


 circuits/  Dispatch/ 
 GA(%) 
 20.39% 


 16.26% 
 16.08% 
 21.32% 
 0.00% 


 4 


 B.  2.19.17.2.2 
 LNP 
 (Standalone)/>=  10 


 circuits/  Non- 
 Dispatch/  GA(%) 


 15.79% 
 0.00% 
 30.00% 


 0.00% 
 10.00% 


 0.00% 
 7.14% 
 0.00% 


 B.  2.19.18.1.1 
 Di 
 gital 


 Loop 


 < 
 DS1/<  10 


 circuits/  Dispatch/ 


 GA(%) 
 5.36% 
 5.20% 
 4.23% 
 4.50% 
 5.58% 
 7.26% 
 5.29% 
 5.95% 


 B.  2.19.19.1.1 
 Di 
 gital 


 Loop 


 >= 
 DS1/<  10 


 circuits/  Dispatch/ 


 GA(%) 
 5.10% 
 17.89% 


 5.71% 
 15.23% 


 7.43% 
 16.13% 


 5.73% 
 13.68% 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Mechanized 


 [P-  5] 


 B.  2.21.3.1.1 
 Loop 
 + 
 Port 


 Combinations/<  10  circuits/  Dis  patch/  GA(  hours) 


 2.30 
 0.24 
 2.92 
 0.14 
 2.11 
 0.40 
 2.63 
 0.19 


 B.  2.21.3.1.2 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Non- 


 Dis 
 patch/  GA( 


 hours) 


 0.95 
 0.87 
 0.88 
 0.77 
 1.04 
 0.75 
 1.17 
 0.79 


 B.  2.21.3.1.3 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Switch 
 Based 


 Orders/  GA 
 (hours) 


 1.04 
 0.75 
 0.96 
 0.71 
 1.12 
 0.73 
 1.28 
 0.77 


 B.  2.21.3.1.4 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Dispatch 


 In/  GA 
 (hours) 


 0.84 
 0.90 
 0.76 
 0.78 
 0.94 
 0.75 
 1.05 
 0.79 


 B.  2.21.3.2.1 
 Loop 
 + 
 Port 


 Combinations/>=  10  circuits/  Dis  patch/  GA(  hours) 


 5.88 
 0.05 
 13.76 


 0.70 
 10.34 


 0.05 
 7.66 
 0.06 
 1,4 


 B.  2.21.3.2.2 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Non- 


 Dis 
 patch/  GA( 


 hours) 


 6.04 
 1.27 
 3.37 
 2.81 
 0.02 


 4 


 B.  2.21.3.2.4 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Dispatch 


 In/  GA 
 (hours) 


 2.95 
 1.43 
 3.51 
 1.52 
 0.02 


 4 


 B.  2.21.4.1.1 
 Combo 
 Other/<  10 


 circuits/  Dis 
 patch/  GA( 
 hours) 


 14.80 


 13.96 
 10.70 
 15.94 
 17.85 


 4 


 B.  2.21.5.1.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/<  10 


 circuits/  Dis 
 patch/  GA( 
 hours) 


 9.22 
 10.14 


 2.46 
 2.24 
 8.94 


 B.  2.21.6.1.1 
 UNE 
 ISDN/<  10 


 circuits/  Dis 
 patch/  GA( 
 hours) 


 22.50 
 17.25 
 22.99 
 15.81 
 11.82 


 8.19 
 9.55 
 13.98 


 B.  2.21.7.1.1 
 Line 
 Sharin  g/< 


 10 
 circuits/  Dispatch/ 


 GA( 
 hours) 


 9.22 
 0.02 
 10.14 


 0.05 
 2.46 


 2.24 
 0.07 
 1,2,4 


 B.  2.21.7.1.2 
 Line 
 Sharing/<  10 


 circuits/  Non- 
 Dispatch/  GA( 


 hours) 
 0.91 
 0.68 
 0.86 
 0.34 
 1.12 
 0.54 
 1.77 
 0.02 
 1,2,3,4 


 B.  2.21.8.1.1 
 2W 
 Analog 


 Loop 
 Design/<  10 


 circuits/  Dis 
 patch/  GA( 
 hours) 


 2.30 
 19.53 


 2.92 
 21.85 


 2.11 
 11.42 


 2.63 
 23.04 


 B.  2.21.8.2.1 
 2W 
 Analog 


 Loop 
 Design/>=  10 


 circuits/  Dis 
 patch/  GA( 
 hours) 


 5.88 
 0.02 
 13.76 


 63.27 
 10.34 


 0.02 
 7.66 
 0.02 
 1,2,3,4 


 G-  29 
397
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Georgia 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 B.  2.21.9.1.1 
 2W 
 Analog 


 Loop 
 Non-  Design/< 


 10 


 circuits/  Dis 
 patch/  GA( 
 hours) 


 2.15 
 0.24 
 2.79 
 0.18 
 1.70 
 0.08 
 2.47 
 0.27 


 B.  2.21.9.1.4 
 2W 
 Analog 


 Loop 
 Non-  Design/< 


 10 
 circuits/  Dispatch 


 In/  GA 
 (hours) 


 0.83 
 0.74 
 0.91 
 1.04 
 0.02 


 4 


 B.  2.21.9.2.1 
 2W 
 Analog 


 Loop 
 Non-  Design/>= 


 10 


 circuits/  Dis 
 patch/  GA( 
 hours) 


 2.22 
 0.02 
 5.34 
 0.02 
 3.41 
 0.02 
 5.34 
 0.10 
 1,2,3,4 


 B.  2.21.12.1.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/<  10 


 circuits/  Dis 
 patch/  GA( 
 hours) 


 2.30 
 9.65 
 2.92 
 11.85 


 2.11 
 9.02 
 2.63 
 15.93 


 B.  2.21.12.2.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/>=  10 


 circuits/  Dis 
 patch/  GA( 
 hours) 


 5.88 
 3.38 
 13.76 


 8.95 
 10.34 


 7.12 
 7.66 
 36.23 
 1,2,3,4 


 B.  2.21.13.1.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/< 


 10 


 circuits/  Dis 
 patch/  GA( 
 hours) 


 2.15 
 0.30 
 2.79 
 0.03 
 1.70 
 0.09 
 2.47 
 0.10 


 B.  2.21.13.1.4 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/< 


 10 


 circuits/  Dis 
 patch 
 In/  GA( 


 hours) 


 0.83 
 0.05 
 0.74 
 0.02 
 0.91 
 0.04 
 1.04 
 0.15 


 B.  2.21.13.2.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/>= 


 10 


 circuits/  Dis 
 patch/  GA( 
 hours) 


 2.22 
 0.02 
 5.34 
 0.02 
 3.41 
 0.51 
 5.34 
 0.48 
 1,2,3,4 


 B.  2.21.13.2.4 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/>= 


 10 


 circuits/  Dis 
 patch 
 In/  GA( 


 hours) 


 0.65 
 0.40 
 30.53 
 0.03 
 4.95 


 3 


 B.  2.21.15.1.2 
 Other 
 Non-  Design/< 


 10 
 circuits/  Non- 


 Dis 
 patch/  GA( 


 hours) 


 0.95 
 0.88 
 1.04 
 1.17 
 0.88 


 4 


 B.  2.21.17.1.1 
 LNP 
 (Standalone)/<  10 


 circuits/  Dispatch/ 
 GA(  hours) 
 2.15 
 0.13 
 2.79 


 1.70 
 0.02 
 2.47 


 1,3 


 B.  2.21.17.1.2 
 LNP 
 (Standalone)/<  10 


 circuits/  Non- 


 Dis 
 patch/  GA( 


 hours) 


 0.94 
 0.69 
 0.87 
 0.98 
 1.03 
 0.75 
 1.16 
 0.71 


 B.  2.21.17.2.2 
 LNP 
 (Standalone)/>=  10 


 circuits/  Non- 


 Dis 
 patch/  GA( 


 hours) 


 11.99 
 0.69 
 0.56 
 0.58 
 13.49 


 0.50 
 2.02 
 0.59 
 1,2,3,4 


 B.  2.21.18.1.1 
 Digital 
 Loop 
 < 
 DS1/<  10 


 circuits/  Dispatch/ 


 GA(  hours) 
 12.46 
 17.25 
 12.95 
 15.81 


 6.20 
 8.19 
 7.80 
 11.98 


 B.  2.21.19.1.1 
 Digital 
 Loop 
 >= 
 DS1/<  10 


 circuits/  Dispatch/ 


 GA(  hours) 
 413.42 
 33.04 
 372.69 


 34.26 
 370.70 


 25.26 
 366.18 


 21.65 


 Average 
 Completion 


 Notice 
 Interval 


 - 
 Non-  Mechanized 


 [P-  5] 


 B.  2.22.2.1.1 
 Local 
 Interoffice 


 Transport/<  10 


 circuits/  Dis 
 patch/  GA( 
 hours) 


 19.38 
 88.31 
 20.65 
 14.28 
 1,3,4 


 G-  30 
398
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Georgia 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 B.  2.22.3.1.1 
 Loop 
 + 
 Port 


 Combinations/<  10  circuits/  Dis  patch/  GA(  hours) 


 18.21 
 16.99 
 12.60 
 16.00 


 B.  2.22.3.1.2 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Non- 


 Dis 
 patch/  GA( 


 hours) 


 9.33 
 11.71 


 11.80 


 9.49 


 B.  2.22.3.1.3 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Switch 
 Based 


 Orders/  GA 
 (hours) 


 3.93 
 5.40 
 10.64 


 5.86 


 B.  2.22.3.1.4 
 Loop 
 + 
 Port 


 Combinations/<  10 


 circuits/  Dispatch 


 In/  GA 
 (hours) 


 15.56 
 18.74 
 15.07 
 13.13 


 B.  2.22.3.2.1 
 Loop 
 + 
 Port 


 Combinations/>=  10  circuits/  Dis  patch/  GA(  hours) 


 26.23 
 18.73 


 9.42 
 0.02 
 1,2,3,4 


 B.  2.22.3.2.2 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Non- 


 Dis 
 patch/  GA( 


 hours) 


 0.78 
 14.01 
 19.73 
 1,3,4 


 B.  2.22.3.2.4 
 Loop 
 + 
 Port 


 Combinations/>=  10 


 circuits/  Dispatch 


 In/  GA 
 (hours) 


 0.78 
 14.01 
 19.73 
 1,3,4 


 B.  2.22.4.1.1 
 Combo 
 Other/<  10 


 circuits/  Dis 
 patch/  GA( 
 hours) 


 59.14 
 86.54 
 56.18 
 42.46 


 B.  2.22.5.1.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/<  10 


 circuits/  Dis 
 patch/  GA( 
 hours) 


 32.86 
 36.18 
 19.03 
 27.10 


 B.  2.22.6.1.1 
 UNE 
 ISDN/<  10 


 circuits/  Dis 
 patch/  GA( 
 hours) 


 52.92 
 75.54 
 105.22 


 44.53 


 B.  2.22.7.1.1 
 Line 
 Sharin  g/< 


 10 
 circuits/  Dispatch/ 


 GA( 
 hours) 


 3.82 
 1.17 
 2.27 
 5.27 


 B.  2.22.7.1.2 
 Line 
 Sharing/<  10 


 circuits/  Non- 
 Dispatch/  GA( 


 hours) 


 0.88 
 1.13 
 0.97 
 3.00 


 B.  2.22.8.1.1 
 2W 
 Analog 


 Loop 
 Design/<  10 


 circuits/  Dispatch/ 
 GA( 
 hours) 


 29.87 
 44.84 
 40.94 
 37.17 


 B.  2.22.8.2.1 
 2W 
 Analog 


 Loop 
 Design/>=  10 


 circuits/  Dis 
 patch/  GA( 
 hours) 


 17.92 
 59.78 
 1,3 


 B.  2.22.9.1.1 
 2W 
 Analog 


 Loop 
 Non-  Design/< 


 10 


 circuits/  Dis 
 patch/  GA( 
 hours) 


 18.75 
 22.13 
 22.67 
 18.43 


 B.  2.22.9.1.4 
 2W 
 Analog 


 Loop 
 Non-  Design/< 


 10 
 circuits/  Dispatch 


 In/  GA 
 (hours) 


 0.02 
 21.43 


 14.55 


 1,2,3 


 B.  2.22.9.2.1 
 2W 
 Analog 


 Loop 
 Non-  Design/>= 


 10 


 circuits/  Dis 
 patch/  GA( 
 hours) 


 59.57 
 22.58 


 9.28 
 2,3,4 


 B.  2.22.10.1.1 
 2W 
 Analog 


 Loop 
 w/  INP 


 Design/<  10 


 circuits/  Dis 
 patch/  GA( 
 hours) 


 G-  31 
399
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Georgia 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 B.  2.22.11.1.1 
 2W 
 Analog 


 Loop 
 w/  INP 


 Non-  Design/< 


 10 


 circuits/  Dis 
 patch/  GA( 
 hours) 


 20.72 
 4 


 B.  2.22.11.1.4 
 2W 
 Analog 


 Loop 
 w/  INP 


 Non-  Design/< 


 10 


 circuits/  Dis 
 patch 
 In/  GA( 


 hours) 


 B.  2.22.12.1.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/<  10 


 circuits/  Dis 
 patch/  GA( 
 hours) 


 64.76 
 22.88 
 32.18 
 24.29 
 1,2,3,4 


 B.  2.22.12.2.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Design/>=  10 


 circuits/  Dis 
 patch/  GA( 
 hours) 


 B.  2.22.13.1.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/< 


 10 


 circuits/  Dis 
 patch/  GA( 
 hours) 


 19.50 
 14.12 
 21.75 
 19.67 
 4 


 B.  2.22.13.1.4 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/< 


 10 


 circuits/  Dis 
 patch 
 In/  GA( 


 hours) 


 20.82 
 19.08 
 31.76 
 19.46 
 2,3,4 


 B.  2.22.13.2.1 
 2W 
 Analog 


 Loop 
 w/  LNP 


 Non-  Design/>= 


 10 


 circuits/  Dis 
 patch/  GA( 
 hours) 


 17.55 
 27.25 


 7.19 


 1,2,3 


 B.  2.22.14.1.1 
 Other 
 Desi  gn/< 


 10 
 circuits/  Dispatch/ 


 GA( 
 hours) 


 15.02 
 61.73 


 1,2 


 B.  2.22.15.1.1 
 Other 
 Non-  Design/< 


 10 
 circuits/  Dispatch/ 


 GA(  hours) 


 17.05 
 18.48 
 20.02 


 1,2,3 


 B.  2.22.15.1.2 
 Other 
 Non-  Design/< 


 10 
 circuits/  Non- 


 Dispatch/  GA( 
 hours) 


 35.47 
 27.70 


 1,2 


 B.  2.22.16.1.2 
 INP 
 (Standalone)/<  10 


 circuits/  Non- 


 Dis 
 patch/  GA( 


 hours) 


 14.00 
 14.00 
 3,4 


 B.  2.22.17.1.1 
 LNP 
 (Standalone)/<  10 


 circuits/  Dispatch/ 
 GA(  hours) 


 10.28 
 0.02 
 8.23 
 35.00 
 1,2,3,4 


 B.  2.22.17.1.2 
 LNP 
 (Standalone)/<  10 


 circuits/  Non- 


 Dis 
 patch/  GA( 


 hours) 


 2.93 
 2.55 
 2.34 
 2.56 


 B.  2.22.17.2.1 
 LNP 
 (Standalone)/>=  10 


 circuits/  Dispatch/ 
 GA(  hours) 


 0.02 
 3 


 B.  2.22.17.2.2 
 LNP 
 (Standalone)/>=  10 


 circuits/  Non- 


 Dis 
 patch/  GA( 


 hours) 


 0.59 
 3.73 
 0.53 
 0.70 
 1,4 


 B.  2.22.18.1.1 
 Digital 
 Loop 
 < 
 DS1/<  10 


 circuits/  Dispatch/ 


 GA(  hours) 


 38.28 
 42.32 
 24.04 
 22.47 


 B.  2.22.19.1.1 
 Digital 
 Loop 
 >= 
 DS1/<  10 


 circuits/  Dispatch/ 


 GA(  hours) 


 49.93 
 70.35 
 93.95 
 65.15 


 Service 
 Order 
 Accuracy 


 [P-  11] 


 G-  32 
400
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Georgia 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 B.  2.34.1.1.1 
 Design 
 (Specials)/<  10 


 circuits/  Dispatch/ 


 GA(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  2.34.1.1.2 
 Design 
 (Specials)/<  10 


 circuits/  Non- 
 Dispatch/  GA(%) 


 100.00% 
 67.07% 
 69.33% 


 B.  2.34.1.2.1 
 Desi 
 gn 
 (Specials)/>=  10 


 circuits/  Dispatch/ 


 GA(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 B.  2.34.1.2.2 
 Design 
 (Specials)/>=  10 


 circuits/  Non- 
 Dispatch/  GA(%) 


 100.00% 
 90.91% 
 3 


 B.  2.34.2.1.1 
 Loo  ps 
 Non-  Design/< 


 10 
 circuits/  Dispatch/ 


 GA(%) 


 98.18% 
 95.65% 
 96.00% 
 96.33% 


 B.  2.34.2.1.2 
 Loops 
 Non-  Design/< 


 10 
 circuits/  Non- 


 Dispatch/  GA(%) 


 99.09% 
 98.18% 
 100.00% 


 98.02% 


 B.  2.34.2.2.1 
 Loo  ps 
 Non-  Design/>= 


 10 
 circuits/  Dispatch/ 


 GA(%) 


 97.75% 
 89.81% 
 97.90% 
 97.73% 


 B.  2.34.2.2.2 
 Loops 
 Non-  Design/>= 


 10 
 circuits/  Non- 


 Dis 
 patch/  GA(%) 


 97.20% 
 97.98% 
 98.73% 
 97.53% 


 UNBUNDLED 
 NETWORK 
 ELEMENTS 


 - 
 MAINTENANCE 


 AND 
 REPAIR 


 Missed 
 Repair 
 Appointments 


 [M&  R- 
 1] 


 B.  3.1.1.1 
 Switch 
 Ports/  Dis 


 patch/  GA(%) 


 8.42% 
 7.26% 
 6.72% 
 0.00% 
 6.61% 
 0.00% 


 4 


 B.  3.1.1.2 
 Switch 
 Ports/  Non- 


 Dis 
 patch/  GA(%) 


 1.04% 
 1.06% 
 1.74% 
 0.00% 
 1.31% 
 0.00% 


 4 


 B.  3.1.2.1 
 Local 
 Interoffice 


 Trans  port/ 
 Dispatch/  GA(%) 


 0.44% 
 0.00% 
 0.11% 
 0.00% 
 0.39% 
 0.00% 
 0.91% 
 0.00% 


 3 


 B.  3.1.2.2 
 Local 
 Interoffice 


 Trans  port/ 
 Non-  Dispatch/ 


 GA(%) 
 0.40% 
 0.00% 
 0.16% 
 0.00% 
 0.27% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3,4 


 B.  3.1.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  Dispatch/ 


 GA(%) 
 8.46% 
 3.21% 
 7.29% 
 3.98% 
 6.74% 
 3.51% 
 6.73% 
 3.36% 


 B.  3.1.3.2 
 Loo  p 
 + 
 Port 


 Combinations/  Non- 


 Dispatch/  GA(%) 


 1.15% 
 1.88% 
 1.18% 
 1.13% 
 1.89% 
 0.77% 
 1.38% 
 1.57% 


 B.  3.1.4.1 
 Combo 
 Other/  Dis 


 patch/  GA(%) 


 8.23% 
 0.69% 
 7.10% 
 2.49% 
 6.58% 
 1.16% 
 6.57% 
 1.97% 


 B.  3.1.4.2 
 Combo 
 Other/  Non- 


 Dis  patch/ 
 GA(%) 


 8.23% 
 0.00% 
 7.10% 
 0.00% 
 6.58% 
 0.00% 
 6.57% 
 0.78% 


 B.  3.1.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Dispatch/ 


 GA(%) 
 49.12% 
 0.00% 
 55.07% 


 0.00% 
 46.01% 


 3.03% 
 45.82% 


 0.00% 


 B.  3.1.5.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Non- 


 Dispatch/  GA(%) 


 3.25% 
 0.00% 
 3.45% 
 0.00% 
 1.54% 
 0.00% 
 1.75% 
 0.00% 


 B.  3.1.6.1 
 UNE 
 ISDN/  Dis 


 patch/  GA(%) 


 13.38% 
 2.86% 
 17.45% 


 1.19% 
 11.11% 


 0.00% 
 18.62% 


 0.00% 


 B.  3.1.6.2 
 UNE 
 ISDN/  Non- 


 Dis 
 patch/  GA(%) 


 2.89% 
 3.23% 
 4.61% 
 0.00% 
 3.40% 
 0.00% 
 4.12% 
 0.00% 


 B.  3.1.7.1 
 Line 
 Sharin  g/ 


 Dispatch/  GA(%) 


 49.12% 
 0.00% 
 55.07% 


 0.00% 
 46.01% 
 13.79% 
 45.82% 
 7.69% 


 1 


 B.  3.1.7.2 
 Line 
 Sharin  g/ 


 Non-  Dispatch/ 


 GA(%) 


 3.25% 
 4.44% 
 3.45% 
 1.69% 
 1.54% 
 7.84% 
 1.75% 
 13.04% 


 B.  3.1.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  Dispatch/ 


 GA(%) 


 8.46% 
 4.55% 
 7.29% 
 0.37% 
 6.74% 
 2.36% 
 6.73% 
 0.39% 


 B.  3.1.8.2 
 2W 
 Analo  g 


 Loop 
 Design/  Non- 


 Dispatch/  GA(%) 


 8.46% 
 0.00% 
 7.29% 
 0.00% 
 6.74% 
 0.75% 
 6.73% 
 0.00% 


 B.  3.1.9.1 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 Dispatch/  GA(%) 


 8.41% 
 4.54% 
 7.24% 
 2.62% 
 6.69% 
 4.68% 
 6.59% 
 4.37% 


 B.  3.1.9.2 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 Non-  Dispatch/ 


 GA(%) 
 0.86% 
 0.00% 
 0.87% 
 8.33% 
 1.74% 
 3.57% 
 1.17% 
 0.00% 


 4 


 G-  33 
401
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Georgia 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 B.  3.1.10.1 
 Other 
 Design/  Dispatch/ 


 GA(%) 


 0.56% 
 0.00% 
 0.37% 
 0.00% 
 0.87% 
 0.00% 
 0.72% 
 0.00% 
 1,3,4 


 B.  3.1.10.2 
 Other 
 Desi  gn/ 


 Non-  Dispatch/ 


 GA(%) 


 0.07% 
 0.00% 
 0.22% 
 0.00% 
 0.18% 
 0.00% 
 0.16% 
 0.00% 
 1,2,3,4 


 B.  3.1.11.1 
 Other 
 Non-  Desi 


 gn/  Dispatch/ 


 GA(%) 


 8.46% 
 0.00% 
 7.29% 
 0.00% 
 6.74% 
 0.00% 
 6.73% 
 0.00% 


 4 


 B.  3.1.11.2 
 Other 
 Non-  Desi 


 gn/  Non- 
 Dispatch/  GA(%) 


 1.15% 
 0.00% 
 1.18% 
 0.00% 
 1.89% 
 0.00% 
 1.38% 
 0.00% 


 3 


 Customer 
 Trouble 
 Report 
 Rate 
 [M&  R- 


 2] 


 B.  3.2.1.1 
 Switch 
 Ports/  Dis 


 patch/  GA(%) 


 1.85% 
 2.05% 
 2.19% 
 0.00% 
 2.20% 
 11.11% 


 3,4 


 B.  3.2.1.2 
 Switch 
 Ports/  Non- 


 Dis 
 patch/  GA(%) 


 1.19% 
 1.17% 
 1.30% 
 0.00% 
 1.23% 
 22.22% 


 3,4 


 B.  3.2.2.1 
 Local 
 Interoffice 


 Trans  port/ 
 Dispatch/  GA(%) 


 1.99% 
 0.00% 
 2.04% 
 0.00% 
 2.24% 
 0.37% 
 2.15% 
 0.00% 


 B.  3.2.2.2 
 Local 
 Interoffice 


 Trans  port/ 
 Non-  Dispatch/ 


 GA(%) 
 1.65% 
 1.89% 
 1.40% 
 2.54% 
 1.60% 
 1.47% 
 1.62% 
 0.35% 


 B.  3.2.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  Dispatch/ 


 GA(%) 
 1.68% 
 1.15% 
 1.86% 
 1.18% 
 1.99% 
 1.21% 
 1.99% 
 1.46% 


 B.  3.2.3.2 
 Loo  p 
 + 
 Port 


 Combinations/  Non- 


 Dispatch/  GA(%) 


 1.08% 
 0.44% 
 1.08% 
 0.40% 
 1.19% 
 0.38% 
 1.12% 
 0.39% 


 B.  3.2.4.1 
 Combo 
 Other/  Dis 


 patch/  GA(%) 


 1.43% 
 4.10% 
 1.58% 
 5.31% 
 1.69% 
 4.29% 
 1.69% 
 4.80% 


 B.  3.2.4.2 
 Combo 
 Other/  Non- 


 Dis  patch/ 
 GA(%) 


 1.43% 
 2.16% 
 1.58% 
 2.64% 
 1.69% 
 2.48% 
 1.69% 
 3.05% 


 B.  3.2.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Dispatch/ 


 GA(%) 
 0.89% 
 0.58% 
 1.31% 
 0.94% 
 1.36% 
 0.86% 
 1.26% 
 1.25% 


 B.  3.2.5.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Non- 


 Dispatch/  GA(%) 


 2.08% 
 0.63% 
 3.43% 
 0.44% 
 4.63% 
 0.31% 
 2.74% 
 0.52% 


 B.  3.2.6.1 
 UNE 
 ISDN/  Dis 


 patch/  GA(%) 


 4.92% 
 1.31% 
 5.03% 
 1.65% 
 4.45% 
 1.39% 
 4.99% 
 1.37% 


 B.  3.2.6.2 
 UNE 
 ISDN/  Non- 


 Dis 
 patch/  GA(%) 


 6.27% 
 0.58% 
 5.13% 
 0.65% 
 6.02% 
 0.54% 
 5.00% 
 0.67% 


 B.  3.2.7.1 
 Line 
 Sharin  g/ 


 Dispatch/  GA(%) 


 0.89% 
 0.33% 
 1.31% 
 0.52% 
 1.36% 
 1.21% 
 1.26% 
 1.02% 


 B.  3.2.7.2 
 Line 
 Sharin  g/ 


 Non-  Dispatch/ 


 GA(%) 


 2.08% 
 2.49% 
 3.43% 
 2.78% 
 4.63% 
 2.13% 
 2.74% 
 2.70% 


 B.  3.2.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  Dispatch/ 


 GA(%) 


 1.68% 
 0.74% 
 1.86% 
 0.83% 
 1.99% 
 0.94% 
 1.99% 
 0.85% 


 B.  3.2.8.2 
 2W 
 Analo  g 


 Loop 
 Design/  Non- 


 Dispatch/  GA(%) 


 1.68% 
 0.37% 
 1.86% 
 0.32% 
 1.99% 
 0.42% 
 1.99% 
 0.45% 


 B.  3.2.9.1 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 Dispatch/  GA(%) 


 1.84% 
 1.19% 
 2.04% 
 1.30% 
 2.19% 
 1.13% 
 2.19% 
 1.25% 


 B.  3.2.9.2 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 Non-  Dispatch/ 


 GA(%) 
 0.93% 
 0.04% 
 0.93% 
 0.03% 
 1.06% 
 0.09% 
 1.03% 
 0.01% 


 B.  3.2.10.1 
 Other 
 Desi  gn/ 
 Dispatch/  GA(%) 


 0.24% 
 0.53% 
 0.25% 
 0.00% 
 0.26% 
 1.12% 
 0.26% 
 1.11% 


 B.  3.2.10.2 
 Other 
 Desi  gn/ 


 Non-  Dispatch/ 


 GA(%) 


 0.40% 
 0.53% 
 0.42% 
 0.55% 
 0.45% 
 1.12% 
 0.43% 
 0.56% 


 B.  3.2.11.1 
 Other 
 Non-  Desi 


 gn/  Dispatch/ 


 GA(%) 


 1.68% 
 0.00% 
 1.86% 
 0.00% 
 1.99% 
 0.00% 
 1.99% 
 0.17% 


 B.  3.2.11.2 
 Other 
 Non-  Desi 


 gn/  Non- 
 Dispatch/  GA(%) 


 1.08% 
 0.00% 
 1.08% 
 0.00% 
 1.19% 
 0.17% 
 1.12% 
 0.00% 


 Maintenance 
 Average 
 Duration 


 [M&  R- 
 3] 


 B.  3.3.1.1 
 Switch 
 Ports/  Dis 


 patch/  GA( 


 hours) 


 22.85 
 24.35 
 20.94 
 0.00 
 21.05 


 19.00 


 4 


 B.  3.3.1.2 
 Switch 
 Ports/  Non- 


 Dis 
 patch/  GA( 


 hours) 


 5.50 
 5.75 
 6.48 
 0.00 
 6.78 
 0.50 


 4 


 B.  3.3.2.1 
 Local 
 Interoffice 


 Trans  port/ 
 Dispatch/  GA( 


 hours) 


 3.49 
 0.00 
 3.52 
 0.00 
 3.66 
 0.98 
 4.03 
 0.00 


 3 


 G-  34 
402
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Georgia 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 B.  3.3.2.2 
 Local 
 Interoffice 


 Transport/  Non- 


 Dispatch/  GA( 
 hours) 
 1.81 
 2.79 
 1.68 
 3.86 
 1.48 
 3.76 
 1.62 
 8.47 
 1,2,3,4 


 B.  3.3.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  Dispatch/ 


 GA( 
 hours) 


 22.57 
 11.54 
 24.00 
 11.59 
 20.69 
 11.76 
 20.82 
 11.89 


 B.  3.3.3.2 
 Loop 
 + 
 Port 


 Combinations/  Non- 


 Dispatch/  GA( 
 hours) 
 5.49 
 3.59 
 5.69 
 3.45 
 6.45 
 3.96 
 6.72 
 5.04 


 B.  3.3.4.1 
 Combo 
 Other/  Dis 


 patch/  GA( 


 hours) 


 22.12 
 4.31 
 23.46 


 4.87 
 20.30 


 4.52 
 20.39 


 5.13 


 B.  3.3.4.2 
 Combo 
 Other/  Non- 


 Dis  patch/ 
 GA( 
 hours) 


 22.12 
 1.64 
 23.46 


 1.53 
 20.30 


 1.47 
 20.39 


 1.63 


 B.  3.3.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Dispatch/ 


 GA(  hours) 
 55.62 
 5.14 
 66.87 


 3.56 
 44.06 


 8.84 
 32.41 


 4.30 


 B.  3.3.5.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Non- 


 Dis 
 patch/  GA( 


 hours) 


 3.38 
 1.35 
 4.77 
 2.56 
 2.65 
 2.13 
 1.59 
 2.40 


 B.  3.3.6.1 
 UNE 
 ISDN/  Dis 


 patch/  GA( 
 hours) 


 18.74 
 4.92 
 19.14 


 3.99 
 15.71 


 4.03 
 17.38 


 4.09 


 B.  3.3.6.2 
 UNE 
 ISDN/  Non- 


 Dis 
 patch/  GA( 


 hours) 


 4.73 
 3.43 
 4.77 
 2.30 
 6.04 
 2.83 
 5.63 
 3.44 


 B.  3.3.7.1 
 Line 
 Sharin  g/ 


 Dispatch/  GA( 


 hours) 


 55.62 
 12.25 
 66.87 
 18.27 
 44.06 
 23.14 
 32.41 
 21.27 


 1 


 B.  3.3.7.2 
 Line 
 Sharin  g/ 


 Non-  Dispatch/ 


 GA( 
 hours) 


 3.38 
 5.63 
 4.77 
 3.53 
 2.65 
 6.88 
 1.59 
 13.46 


 B.  3.3.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  Dispatch/ 


 GA( 
 hours) 


 22.57 
 5.11 
 24.00 


 4.76 
 20.69 


 5.10 
 20.82 


 4.28 


 B.  3.3.8.2 
 2W 
 Analog 


 Loop 
 Design/  Non- 


 Dispatch/  GA( 


 hours) 
 22.57 
 1.95 
 24.00 


 1.97 
 20.69 


 2.42 
 20.82 


 2.21 


 B.  3.3.9.1 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 Dispatch/  GA( 


 hours) 
 22.86 
 10.36 
 24.36 


 9.07 
 20.94 


 9.39 
 21.03 


 8.94 


 B.  3.3.9.2 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 Non- 


 Dis 
 patch/  GA( 


 hours) 


 5.91 
 8.09 
 6.20 
 9.50 
 7.08 
 7.36 
 7.28 
 6.50 


 4 


 B.  3.3.10.1 
 Other 
 Desi  gn/ 
 Dispatch/  GA( 


 hours) 


 6.66 
 1.42 
 4.46 
 0.00 
 6.03 
 7.22 
 4.87 
 1.68 
 1,3,4 


 B.  3.3.10.2 
 Other 
 Desi  gn/ 


 Non-  Dispatch/ 


 GA( 
 hours) 


 1.82 
 6.98 
 2.27 
 0.42 
 1.79 
 1.37 
 2.02 
 1.00 
 1,2,3,4 


 B.  3.3.11.1 
 Other 
 Non-  Desi 


 gn/  Dispatch/ 


 GA( 
 hours) 


 22.57 
 0.00 
 24.00 


 0.00 
 20.69 


 0.00 
 20.82 


 21.50 


 4 


 B.  3.3.11.2 
 Other 
 Non-  Desi 


 gn/  Non- 
 Dispatch/  GA( 


 hours) 


 5.49 
 0.00 
 5.69 
 0.00 
 6.45 
 3.00 
 6.72 
 0.00 


 3 


 % 
 Repeat 


 Troubles 


 within 
 30 
 Days 


 [M&  R- 


 4] 


 B.  3.4.1.1 
 Switch 
 Ports/  Dis 


 patch/  GA(%) 


 17.11% 
 17.78% 
 17.96% 
 0.00% 
 17.61% 
 100.00% 


 4 


 B.  3.4.1.2 
 Switch 
 Ports/  Non- 


 Dis 
 patch/  GA(%) 


 14.54% 
 15.31% 
 14.57% 
 0.00% 
 14.75% 


 0.00% 


 4 


 B.  3.4.2.1 
 Local 
 Interoffice 


 Trans  port/ 
 Dispatch/  GA(%) 


 22.73% 
 0.00% 
 22.33% 


 0.00% 
 18.05% 


 0.00% 
 20.85% 


 0.00% 


 3 


 B.  3.4.2.2 
 Local 
 Interoffice 


 Trans  port/ 
 Non-  Dispatch/ 


 GA(%) 
 16.60% 
 0.00% 
 15.53% 


 0.00% 
 13.56% 
 25.00% 
 20.32% 
 0.00% 
 1,2,3,4 


 B.  3.4.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  Dispatch/ 


 GA(%) 
 17.00% 
 14.34% 
 17.69% 
 12.31% 
 17.83% 
 12.28% 
 17.53% 
 11.16% 


 B.  3.4.3.2 
 Loo  p 
 + 
 Port 


 Combinations/  Non- 


 Dispatch/  GA(%) 


 14.51% 
 12.79% 
 15.31% 
 12.63% 
 14.59% 
 11.28% 
 14.77% 
 9.95% 


 B.  3.4.4.1 
 Combo 
 Other/  Dis 


 patch/  GA(%) 


 17.11% 
 26.39% 
 17.82% 
 24.38% 
 17.89% 
 24.86% 
 17.68% 
 26.60% 


 G-  35 
403
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Georgia 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 B.  3.4.4.2 
 Combo 
 Other/  Non- 


 Dispatch/  GA(%) 


 17.11% 
 17.11% 
 17.82% 
 19.00% 
 17.89% 
 20.00% 
 17.68% 
 21.71% 


 B.  3.4.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Dispatch/ 


 GA(%) 
 16.88% 
 4.55% 
 21.45% 
 19.44% 
 24.55% 
 6.06% 
 26.43% 


 6.25% 


 B.  3.4.5.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Non- 


 Dispatch/  GA(%) 


 22.29% 
 0.00% 
 24.13% 


 0.00% 
 27.29% 


 0.00% 
 28.63% 
 10.00% 


 B.  3.4.6.1 
 UNE 
 ISDN/  Dis 


 patch/  GA(%) 


 20.07% 
 18.57% 
 20.81% 
 14.29% 
 17.62% 
 11.43% 
 22.76% 
 17.91% 


 B.  3.4.6.2 
 UNE 
 ISDN/  Non- 


 Dis 
 patch/  GA(%) 


 19.69% 
 9.68% 
 24.01% 


 9.09% 
 21.53% 
 11.11% 
 21.31% 
 6.06% 


 B.  3.4.7.1 
 Line 
 Sharin  g/ 


 Dispatch/  GA(%) 


 16.88% 
 50.00% 
 21.45% 
 27.27% 
 24.55% 
 55.17% 
 26.43% 
 46.15% 


 1 


 B.  3.4.7.2 
 Line 
 Sharin  g/ 


 Non-  Dispatch/ 


 GA(%) 


 22.29% 
 20.00% 
 24.13% 
 32.20% 
 27.29% 
 25.49% 
 28.63% 
 37.68% 


 B.  3.4.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  Dispatch/ 


 GA(%) 


 17.00% 
 11.98% 
 17.69% 
 10.86% 
 17.83% 
 10.47% 
 17.53% 
 7.87% 


 B.  3.4.8.2 
 2W 
 Analo  g 


 Loop 
 Design/  Non- 


 Dispatch/  GA(%) 


 17.00% 
 6.72% 
 17.69% 


 5.88% 
 17.83% 


 3.76% 
 17.53% 


 6.77% 


 B.  3.4.9.1 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 Dispatch/  GA(%) 


 17.08% 
 13.38% 
 17.74% 
 10.48% 
 17.94% 
 9.64% 
 17.58% 


 6.41% 


 B.  3.4.9.2 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 Non-  Dispatch/ 


 GA(%) 
 13.98% 
 12.50% 
 15.13% 
 16.67% 
 14.25% 
 3.57% 
 14.34% 


 0.00% 


 4 


 B.  3.4.10.1 
 Other 
 Desi 
 gn/  Dispatch/ 


 GA(%) 


 21.03% 
 0.00% 
 22.49% 


 0.00% 
 20.02% 


 0.00% 
 23.38% 


 0.00% 
 1,3,4 


 B.  3.4.10.2 
 Other 
 Desi 
 gn/  Non- 


 Dispatch/  GA(%) 


 17.46% 
 0.00% 
 16.93% 


 0.00% 
 16.35% 
 50.00% 
 19.39% 
 0.00% 
 1,2,3,4 


 B.  3.4.11.1 
 Other 
 Non-  Desi 


 gn/  Dispatch/ 


 GA(%) 


 17.00% 
 0.00% 
 17.69% 


 0.00% 
 17.83% 


 0.00% 
 17.53% 


 0.00% 


 4 


 B.  3.4.11.2 
 Other 
 Non-  Desi 


 gn/  Non- 
 Dispatch/  GA(%) 


 14.51% 
 0.00% 
 15.31% 


 0.00% 
 14.59% 


 0.00% 
 14.77% 


 0.00% 


 3 


 Out 
 of 
 Service 


 > 
 24 


 hours 


 [M&  R- 


 5] 


 B.  3.5.1.1 
 Switch 
 Ports/  Dis 


 patch/  GA(%) 


 23.00% 
 24.72% 
 24.42% 
 0.00% 
 25.48% 


 0.00% 


 4 


 B.  3.5.1.2 
 Switch 
 Ports/  Non- 


 Dis 
 patch/  GA(%) 


 7.17% 
 8.19% 
 9.74% 
 0.00% 
 10.06% 


 0.00% 


 B.  3.5.2.1 
 Local 
 Interoffice 


 Trans  port/ 
 Dispatch/  GA(%) 


 0.44% 
 0.00% 
 0.11% 
 0.00% 
 0.39% 
 0.00% 
 0.91% 
 0.00% 


 3 


 B.  3.5.2.2 
 Local 
 Interoffice 


 Trans  port/ 
 Non-  Dispatch/ 


 GA(%) 
 0.40% 
 0.00% 
 0.16% 
 0.00% 
 0.27% 
 0.00% 
 0.00% 
 0.00% 
 1,2,3,4 


 B.  3.5.3.1 
 Loo  p 
 + 
 Port 


 Combinations/  Dispatch/ 


 GA(%) 
 22.69% 
 7.14% 
 24.27% 


 7.54% 
 24.07% 


 9.97% 
 25.11% 


 9.23% 


 B.  3.5.3.2 
 Loo  p 
 + 
 Port 


 Combinations/  Non- 


 Dispatch/  GA(%) 


 7.04% 
 3.06% 
 7.85% 
 2.53% 
 9.24% 
 2.21% 
 9.60% 
 1.75% 


 B.  3.5.4.1 
 Combo 
 Other/  Dis 


 patch/  GA(%) 


 21.71% 
 0.69% 
 23.25% 


 2.49% 
 23.14% 


 1.16% 
 24.11% 


 1.97% 


 B.  3.5.4.2 
 Combo 
 Other/  Non- 


 Dis  patch/ 
 GA(%) 


 21.71% 
 0.00% 
 23.25% 


 0.00% 
 23.14% 


 0.00% 
 24.11% 


 0.78% 


 B.  3.5.5.1 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Dispatch/ 


 GA(%) 
 49.12% 
 0.00% 
 55.07% 


 0.00% 
 46.01% 


 3.03% 
 45.82% 


 0.00% 


 B.  3.5.5.2 
 xDSL 
 (ADSL, 


 HDSL 
 and 
 UCL)/  Non- 


 Dispatch/  GA(%) 


 3.25% 
 0.00% 
 3.45% 
 0.00% 
 1.54% 
 0.00% 
 1.75% 
 0.00% 


 B.  3.5.6.1 
 UNE 
 ISDN/  Dis 


 patch/  GA(%) 


 18.25% 
 2.86% 
 22.73% 


 1.19% 
 16.23% 


 0.00% 
 24.32% 


 0.00% 


 B.  3.5.6.2 
 UNE 
 ISDN/  Non- 


 Dis 
 patch/  GA(%) 


 2.74% 
 3.23% 
 1.95% 
 0.00% 
 3.33% 
 0.00% 
 3.15% 
 0.00% 


 B.  3.5.7.1 
 Line 
 Sharin  g/ 


 Dispatch/  GA(%) 


 49.12% 
 0.00% 
 55.07% 


 0.00% 
 46.01% 


 0.00% 
 45.82% 
 100.00% 


 4 


 B.  3.5.7.2 
 Line 
 Sharin  g/ 


 Non-  Dispatch/ 


 GA(%) 


 3.25% 
 0.00% 
 3.45% 
 0.00% 
 1.54% 
 0.00% 
 1.75% 
 0.00% 


 B.  3.5.8.1 
 2W 
 Analo  g 


 Loop 
 Design/  Dispatch/ 


 GA(%) 


 22.69% 
 4.55% 
 24.27% 


 0.37% 
 24.07% 


 2.36% 
 25.11% 


 0.39% 


 G-  36 
404
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Georgia 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 B.  3.5.8.2 
 2W 
 Analog 


 Loop 
 Design/  Non- 


 Dispatch/  GA(%) 


 22.69% 
 0.00% 
 24.27% 


 0.00% 
 24.07% 


 0.75% 
 25.11% 


 0.00% 


 B.  3.5.9.1 
 2W 
 Analo  g 


 Loop 
 Non-  Design/ 


 Dispatch/  GA(%) 


 23.00% 
 13.33% 
 24.72% 
 10.00% 
 24.41% 
 8.00% 
 25.47% 


 8.33% 


 B.  3.5.9.2 
 2W 
 Analog 


 Loop 
 Non-  Design/ 


 Non-  Dispatch/ 


 GA(%) 
 7.18% 
 0.00% 
 8.21% 
 0.00% 
 9.76% 
 0.00% 
 10.05% 


 0.00% 
 1,2,3 


 B.  3.5.10.1 
 Other 
 Desi 
 gn/  Dispatch/ 


 GA(%) 


 0.56% 
 0.00% 
 0.37% 
 0.00% 
 0.87% 
 0.00% 
 0.72% 
 0.00% 
 1,3,4 


 B.  3.5.10.2 
 Other 
 Desi  gn/ 


 Non-  Dispatch/ 


 GA(%) 


 0.07% 
 0.00% 
 0.22% 
 0.00% 
 0.18% 
 0.00% 
 0.16% 
 0.00% 
 1,2,3,4 


 B.  3.5.11.1 
 Other 
 Non-  Desi 


 gn/  Dispatch/ 


 GA(%) 


 22.69% 
 0.00% 
 24.27% 


 0.00% 
 24.07% 


 0.00% 
 25.11% 


 0.00% 


 B.  3.5.11.2 
 Other 
 Non-  Desi 


 gn/  Non- 
 Dispatch/  GA(%) 


 7.04% 
 0.00% 
 7.85% 
 0.00% 
 9.24% 
 0.00% 
 9.60% 
 0.00% 


 3 


 UNBUNDLED 
 NETWORK 
 ELEMENTS 


 - 
 BILLING 


 Invoice 
 Accuracy 


 [B-  1] 


 B.  4.1 
 GA 
 (%) 


 98.28% 
 99.93% 
 98.50% 
 100.00% 


 98.72% 
 99.95% 
 98.05% 
 100.00% 


 Mean 
 Time 
 to 
 Deliver 


 Invoices 


 - 
 CRIS 


 [B-  2] 


 B.  4.2 
 Re  gion( 
 business 


 days) 


 3.68 
 7.29 
 3.86 
 4.97 
 3.47 
 3.78 
 3.82 
 3.46 


 LOCAL 
 INTERCONNECTION 


 TRUNKS 
 - 
 ORDERING 


 % 
 Rejected 


 Service 
 Requests 


 [O-  7] 


 C.  1.1 
 Local 
 Interconnection 


 Trunks/  GA 
 (%) 


 6.04% 
 52.87% 
 40.74% 
 51.02% 


 Reject 
 Interval 


 [O-  8] 


 C.  1.2 
 Local 
 Interconnection 


 Trunks/  GA 
 (%) 


 100.00% 
 97.83% 
 93.18% 
 97.33% 


 FOC 
 Timeliness 


 [O-  9] 


 C.  1.3 
 Local 
 Interconnection 


 Trunks/  GA 
 (%) 


 100.00% 
 98.91% 
 100.00% 


 99.24% 


 FOC 
 & 
 Reject 


 Response 


 Completeness 


 [O-  11] 


 C.  1.4 
 Local 
 Interconnection 


 Trunks/  GA 
 (%) 


 75.84% 
 99.16% 
 100.00% 


 99.22% 


 LOCAL 
 INTERCONNECTION 


 TRUNKS 
 - 
 PROVISIONING 


 Order 
 Completion 


 Interval 
 [P-  4] 


 C.  2.1 
 Local 
 Interconnection 


 Trunks/  GA 
 (days) 


 25.90 
 27.46 
 21.79 
 28.01 
 25.06 
 21.60 
 19.33 
 20.60 


 Held 
 Orders 


 [P-  1] 


 C.  2.2 
 Local 
 Interconnection 


 Trunks/  GA 
 (days) 


 0.00 
 0.00 
 0.00 
 0.00 
 0.00 
 0.00 
 0.00 
 0.00 


 % 
 Jeopardies 


 [P-  2] 


 C.  2.3 
 Local 
 Interconnection 


 Trunks/  GA 
 (%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 % 
 Missed 


 Installation 


 Appointments 


 [P-  3] 


 C.  2.5 
 Local 
 Interconnection 


 Trunks/  GA 
 (%) 


 0.00% 
 0.00% 
 9.62% 
 2.65% 
 1.16% 
 0.00% 
 0.00% 
 0.00% 


 % 
 Provisioning 


 Troubles 
 within 
 30 
 Days 


 [P-  9] 


 C.  2.6 
 Local 
 Interconnection 


 Trunks/  GA 
 (%) 


 4.85% 
 0.00% 
 1.65% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 G-  37 
405
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Georgia 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 Average 
 Completion 


 Notice 
 Interval 


 [P-  5] 


 C.  2.7 
 Local 
 Interconnection 


 Trunks/  GA 
 (hours) 


 185.87 
 11.85 
 234.39 


 30.43 
 289.67 


 56.90 
 125.60 


 15.74 


 Total 
 Service 


 Order 
 Cycle 
 Time 
 [P-  10] 


 C.  2.8 
 Local 
 Interconnection 


 Trunks/  GA 
 (days) 


 29.69 
 27.83 
 23.46 
 22.44 


 % 
 Completions 


 w/  o 
 Notice 


 or 
 < 
 24 


 hours 


 [P-  6] 


 C.  2.10.1 
 Local 
 Interconnection 


 Trunks/  Dis 
 patch/  GA(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 


 Service 
 Order 
 Accuracy 


 [P-  11] 


 C.  2.11.1.1 
 Local 
 Interconnection 


 Trunks/<  10 


 circuits/  Dis 
 patch/  GA(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 C.  2.11.1.2 
 Local 
 Interconnection 


 Trunks/<  10 
 circuits/  Non- 


 Dis 
 patch/  GA(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 C.  2.11.2.1 
 Local 
 Interconnection 


 Trunks/>=  10 


 circuits/  Dis 
 patch/  GA(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,4 


 C.  2.11.2.2 
 Local 
 Interconnection 


 Trunks/>=  10 
 circuits/  Non- 


 Dis 
 patch/  GA(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 2 


 LOCAL 
 INTERCONNECTION 


 TRUNKS 
 - 
 MAINTENANCE 


 AND 
 REPAIR 


 Missed 
 Repair 
 Appointments 


 [M&  R- 
 1] 


 C.  3.1.1 
 Local 
 Interconnection 


 Trunks/  Dis 
 patch/  GA(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 C.  3.1.2 
 Local 
 Interconnection 


 Trunks/  Non- 
 Dispatch/  GA(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 3,4 


 Customer 
 Trouble 
 Report 
 Rate 
 [M&  R- 


 2] 


 C.  3.2.1 
 Local 
 Interconnection 


 Trunks/  Dis 
 patch/  GA(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.01% 
 0.00% 


 C.  3.2.2 
 Local 
 Interconnection 


 Trunks/  Non- 
 Dispatch/  GA(%) 


 0.07% 
 0.00% 
 0.05% 
 0.00% 
 0.06% 
 0.00% 
 0.11% 
 0.00% 


 Maintenance 
 Average 
 Duration 


 [M&  R- 
 3] 


 C.  3.3.1 
 Local 
 Interconnection 


 Trunks/  Dispatch/ 


 GA(  hours) 


 1.55 
 0.00 
 1.63 
 0.00 
 0.00 
 0.00 
 2.43 
 0.00 


 C.  3.3.2 
 Local 
 Interconnection 


 Trunks/  Non- 


 Dis 
 patch/  GA( 


 hours) 


 0.60 
 0.00 
 0.42 
 0.00 
 0.73 
 2.94 
 0.37 
 3.47 
 3,4 


 % 
 Repeat 


 Troubles 


 within 
 30 
 Days 


 [M&  R- 


 4] 


 C.  3.4.1 
 Local 
 Interconnection 


 Trunks/  Dis 
 patch/  GA(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 C.  3.4.2 
 Local 
 Interconnection 


 Trunks/  Non- 
 Dispatch/  GA(%) 


 5.74% 
 0.00% 
 10.24% 


 0.00% 
 4.91% 
 0.00% 
 7.12% 
 0.00% 


 3,4 


 G-  38 
406
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Georgia 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 Out 
 of 
 Service 


 > 
 24 


 hours 


 [M&  R- 


 5] 


 C.  3.5.1 
 Local 
 Interconnection 


 Trunks/  Dis 
 patch/  GA(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 C.  3.5.2 
 Local 
 Interconnection 


 Trunks/  Non- 
 Dispatch/  GA(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 
 0.00% 


 3,4 


 LOCAL 
 INTERCONNECTION 


 TRUNKS 
 - 
 BILLING 


 Invoice 
 Accuracy 


 [B-  1] 


 C.  4.1 
 GA 
 (%) 


 98.28% 
 99.26% 
 98.50% 
 99.26% 
 98.72% 
 99.48% 
 98.05% 
 99.07% 


 Mean 
 Time 
 to 
 Deliver 


 Invoices 


 - 
 CABS 


 [B-  2] 


 C.  4.2 
 Re  gion( 
 calendar 


 days) 


 4.84 
 4.54 
 3.94 
 3.89 
 4.96 
 4.92 
 4.54 
 4.29 


 LOCAL 
 INTERCONNECTION 


 TRUNKS 
 - 
 TRUNK 


 BLOCKING 


 Trunk 
 Group 
 Performance 


 - 
 Aggregate 


 [TGP-  1] 


 C.  5.1 
 GA 


 0 
 0 
 0 
 0 


 OPERATIONS 
 SUPPORT 
 SYSTEMS 
 - 
 PRE-  ORDERING 


 % 
 Interface 


 Availability 


 - 
 CLEC 


 [OSS-  2] 


 D.  1.1.1 
 EDI/  Re 
 gion(%) 


 99.71% 
 100.00% 


 99.64% 
 100.00% 


 D.  1.1.2 
 HAL/  Re 
 gion(%) 


 100.00% 
 100.00% 


 D.  1.1.3 
 LENS/  Re 
 gion(%) 


 99.99% 
 99.98% 
 99.85% 
 99.76% 


 D.  1.1.4 
 LEO 
 MAINFRAME/  Re 


 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 D.  1.1.6 
 LESOG/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 D.  1.1.7 
 TAG/  Re 
 gion(%) 


 100.00% 
 99.95% 
 99.99% 
 99.86% 


 D.  1.1.8 
 PSIMS/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 % 
 Interface 


 Availability 


 - 
 BST 


 & 
 CLEC 


 [OSS-  2] 


 D.  1.2.1 
 ATLAS/  COFFI/ 


 Re 
 gion(%) 


 100.00% 
 100.00% 


 D.  1.2.2 
 BOCRIS/  Re 
 gion(%) 


 100.00% 
 100.00% 
 99.96% 
 99.99% 


 D.  1.2.3 
 DSAP/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.98% 


 D.  1.2.4 
 RSAG/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.99% 


 D.  1.2.5 
 SOCS/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.99% 


 D.  1.2.6 
 SONGS/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.86% 


 D.  1.2.7 
 DOE/  Re 
 gion(%) 


 99.99% 
 99.99% 
 99.99% 
 99.26% 


 D.  1.2.8 
 LNP 
 Gatewa 


 y/  Region(%) 


 100.00% 
 99.99% 
 100.00% 


 99.49% 


 D.  1.2.9 
 COG/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.48% 


 D.  1.2.10 
 DOM/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.99% 


 D.  1.2.11 
 SOG/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 G-  39 
407
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Georgia 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 D.  1.2.1- 
 new 
 ATLAS/  Region 


 (%) 


 100.00% 
 99.99% 


 D.  1.2.2- 
 new 
 COFFI/  Re 


 gion 
 (%) 


 100.00% 
 99.99% 


 Average 
 Response 


 Interval 
 - 
 CLEC 


 (LENS) 


 (BST 
 Measure 


 Includes 
 Additional 


 2 
 Seconds) 


 [OSS-  1] 


 D.  1.3.1.1 
 RSAG, 
 b 
 y 


 TN/  Region( 


 seconds) 


 1440.12 
 0.91 
 1782.46 


 1.11 
 2.87 
 1.20 
 2.88 
 1.02 


 D.  1.3.1.2 
 RSAG, 
 b 
 y 


 TN/  Region( 


 seconds) 


 2.96 
 0.91 
 2.95 
 1.11 
 2.94 
 1.20 
 2.91 
 1.02 


 D.  1.3.2.1 
 RSAG, 
 b 
 y 
 ADDR/  Region( 


 seconds) 


 712.69 
 0.91 
 1204.18 


 1.02 
 2.99 
 1.10 
 3.03 
 0.93 


 D.  1.3.2.2 
 RSAG, 
 b 
 y 
 ADDR/  Region( 


 seconds) 


 4.82 
 0.91 
 4.86 
 1.02 
 4.77 
 1.10 
 4.76 
 0.93 


 D.  1.3.3.1 
 ATLAS/  Re 
 gion( 
 seconds) 


 1330.23 
 0.88 
 2.95 
 0.88 
 2.95 
 0.88 
 3.01 
 0.80 


 D.  1.3.3.2 
 ATLAS/  Re 
 gion( 
 seconds) 


 2.61 
 0.88 
 2.61 
 0.88 
 2.60 
 0.88 
 2.61 
 0.80 


 D.  1.3.4.1 
 DSAP/  Re 
 gion( 
 seconds) 


 2.68 
 0.53 
 2.70 
 0.57 
 2.71 
 0.53 
 2.71 
 0.52 


 D.  1.3.4.2 
 DSAP/  Re 
 gion( 
 seconds) 


 2.58 
 0.53 
 2.58 
 0.57 
 2.57 
 0.53 
 2.57 
 0.52 


 D.  1.3.5.1 
 CRSECSRL/  Re 


 gion( 
 seconds) 


 3.20 
 1.08 
 212.02 


 1.25 
 3.21 
 2.12 
 3.24 
 1.14 


 D.  1.3.5.2 
 CRSECSRL/  Re 


 gion( 
 seconds) 


 2.95 
 1.08 
 2.91 
 1.25 
 2.87 
 2.12 
 2.95 
 1.14 


 D.  1.3.6.1 
 COFFI/  Re 
 gion( 
 seconds) 


 4.46 
 0.63 
 4.40 
 0.67 
 4.60 
 0.63 
 4.35 
 0.64 


 D.  1.3.6.2 
 COFFI/  Re 
 gion( 
 seconds) 


 3.81 
 0.63 
 3.92 
 0.67 
 7.28 
 0.63 
 3.73 
 0.64 


 D.  1.3.7.1 
 PSIMS/  ORB/ 
 Re 
 gion( 


 seconds) 


 4.46 
 0.03 
 4.40 
 0.04 
 4.60 
 0.04 
 4.35 
 0.04 


 D.  1.3.7.2 
 PSIMS/  ORB/ 
 Re 
 gion( 


 seconds) 


 3.81 
 0.03 
 3.92 
 0.04 
 7.28 
 0.04 
 3.73 
 0.04 


 Average 
 Response 


 Interval 
 - 
 CLEC 


 (TAG) 
 (BST 
 Measure 


 Includes 
 Additional 


 2 
 Seconds) 


 [OSS-  1] 


 D.  1.4.1.1 
 RSAG, 
 b 
 y 


 TN/  Region( 


 seconds) 


 1440.12 
 1.10 
 1782.46 


 1.31 
 2.87 
 1.60 
 2.88 
 1.52 


 D.  1.4.1.2 
 RSAG, 
 b 
 y 


 TN/  Region( 


 seconds) 


 2.96 
 1.10 
 2.95 
 1.31 
 2.94 
 1.60 
 2.91 
 1.52 


 D.  1.4.2.1 
 RSAG, 
 b 
 y 
 ADDR/  Region( 


 seconds) 


 712.69 
 1.62 
 1204.18 


 1.85 
 2.99 
 3.05 
 3.03 
 2.34 


 D.  1.4.2.2 
 RSAG, 
 b 
 y 
 ADDR/  Region( 


 seconds) 


 4.82 
 1.62 
 4.86 
 1.85 
 4.77 
 3.05 
 4.76 
 2.34 


 D.  1.4.4.1 
 ATLAS 
 - 
 DID/  Re 


 gion( 
 seconds) 


 1.48 
 2.18 
 1.76 
 1.37 


 D.  1.4.4.2 
 ATLAS 
 - 
 DID/  Re 


 gion( 
 seconds) 


 1.48 
 2.18 
 1.76 
 1.37 


 D.  1.4.5.1 
 ATLAS 
 - 
 TN/  Re 


 gion( 
 seconds) 


 1330.23 
 1.35 
 2.95 
 1.56 
 2.95 
 1.86 
 3.01 
 1.89 


 D.  1.4.5.2 
 ATLAS 
 - 
 TN/  Re 


 gion( 
 seconds) 


 2.61 
 1.35 
 2.61 
 1.56 
 2.60 
 1.86 
 2.61 
 1.89 


 D.  1.4.6.1 
 DSAP/  Re 
 gion( 
 seconds) 


 2.68 
 1.58 
 2.70 
 1.71 
 2.71 
 1.74 
 2.71 
 1.83 


 D.  1.4.6.2 
 DSAP/  Re 
 gion( 
 seconds) 


 2.58 
 1.58 
 2.58 
 1.71 
 2.57 
 1.74 
 2.57 
 1.83 


 D.  1.4.7.1 
 TAG/  Re 
 gion( 
 seconds) 


 3.20 
 1.75 
 212.02 


 2.15 
 3.21 
 2.51 
 3.24 
 2.85 


 D.  1.4.7.2 
 TAG/  Re 
 gion( 
 seconds) 


 2.95 
 1.75 
 2.91 
 2.15 
 2.87 
 2.51 
 2.95 
 2.85 


 OPERATIONS 
 SUPPORT 
 SYSTEMS 
 - 
 MAINTENANCE 


 AND 
 REPAIR 


 % 
 Interface 


 Availability 


 - 
 CLEC 


 [OSS-  3] 


 D.  2.2.1 
 CLEC 
 TAFI/  Re 


 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 G-  40 
408
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Georgia 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 D.  2.2.2 
 ECTA/  Region(%) 


 100.00% 
 99.95% 
 100.00% 


 99.86% 


 % 
 Interface 


 Availability 


 - 
 BST 


 & 
 CLEC 


 [OSS-  3] 


 D.  2.3.1 
 CRIS/  Re 
 gion(%) 


 100.00% 
 100.00% 
 99.96% 
 99.99% 


 D.  2.3.2 
 LMOS 
 HOST/  Re 


 gion(%) 


 100.00% 
 100.00% 
 99.91% 
 100.00% 


 D.  2.3.3 
 LNP/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.91% 


 D.  2.3.4 
 MARCH/  Re 
 gion(%) 


 100.00% 
 99.99% 
 100.00% 
 100.00% 


 D.  2.3.5 
 OSPCM/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 D.  2.3.6 
 Predictor/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.92% 


 D.  2.3.7 
 SOCS/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.99% 


 Average 
 Response 


 Interval 
 <= 
 4 
 Seconds 


 [OSS-  4] 


 D.  2.4.1 
 CRIS/  Re 
 gion(%) 


 94.91% 
 94.17% 
 94.75% 
 94.83% 
 95.12% 
 94.99% 
 94.95% 
 94.66% 


 D.  2.4.2 
 DLETH/  Re 
 gion(%) 


 3.07% 
 3.22% 
 3.14% 
 4.03% 
 3.16% 
 4.59% 
 2.58% 
 3.67% 


 D.  2.4.3 
 DLR/  Re 
 gion(%) 


 4.30% 
 2.41% 
 4.07% 
 2.41% 
 4.03% 
 3.36% 
 4.47% 
 7.51% 


 D.  2.4.4 
 LMOS/  Re 
 gion(%) 


 99.67% 
 99.69% 
 99.63% 
 99.59% 
 99.60% 
 99.60% 
 99.61% 
 99.58% 


 D.  2.4.5 
 LMOSu 
 pd/  Region(%) 


 78.95% 
 70.39% 
 76.71% 
 65.38% 
 78.49% 
 66.19% 
 79.21% 
 66.24% 


 D.  2.4.6 
 LNP/  Re 
 gion(%) 


 99.78% 
 99.37% 
 99.31% 
 99.09% 
 99.68% 
 99.19% 
 99.65% 
 98.81% 


 D.  2.4.7 
 MARCH/  Re 
 gion(%) 


 28.35% 
 33.16% 
 28.32% 
 26.44% 
 28.04% 
 31.69% 
 28.10% 
 29.64% 


 D.  2.4.8 
 OSPCM/  Re 
 gion(%) 


 23.94% 
 13.59% 
 27.25% 
 20.73% 
 31.23% 
 24.50% 
 33.15% 
 21.43% 


 D.  2.4.9 
 Predictor/  Re 
 gion(%) 


 15.78% 
 19.48% 
 15.03% 
 20.43% 
 13.82% 
 19.61% 
 12.71% 
 21.73% 


 D.  2.4.10 
 SOCS/  Re 
 gion(%) 


 99.84% 
 99.91% 
 99.83% 
 99.90% 
 99.85% 
 99.88% 
 99.81% 
 99.86% 


 D.  2.4.11 
 NIW/  Region(%) 


 82.97% 
 81.81% 
 84.38% 
 83.15% 
 84.01% 
 83.00% 
 82.83% 
 81.89% 


 Average 
 Response 


 Interval 
 <= 
 10 
 Seconds 


 [OSS-  4] 


 D.  2.5.1 
 CRIS/  Re 
 gion(%) 


 98.99% 
 99.34% 
 98.97% 
 99.34% 
 99.05% 
 99.46% 
 99.02% 
 99.39% 


 D.  2.5.2 
 DLETH/  Re 
 gion(%) 


 78.81% 
 86.16% 
 78.96% 
 87.92% 
 79.20% 
 85.30% 
 77.66% 
 82.58% 


 D.  2.5.3 
 DLR/  Re 
 gion(%) 


 77.94% 
 92.02% 
 77.45% 
 91.98% 
 76.65% 
 88.18% 
 71.08% 
 41.67% 


 D.  2.5.4 
 LMOS/  Re 
 gion(%) 


 99.81% 
 99.86% 
 99.79% 
 99.82% 
 99.79% 
 99.84% 
 99.80% 
 99.85% 


 D.  2.5.5 
 LMOSu 
 pd/  Region(%) 


 90.95% 
 83.33% 
 89.31% 
 80.59% 
 90.04% 
 80.25% 
 90.59% 
 80.53% 


 D.  2.5.6 
 LNP/  Re 
 gion(%) 


 99.93% 
 99.87% 
 99.54% 
 99.72% 
 99.81% 
 99.63% 
 99.83% 
 99.52% 


 D.  2.5.7 
 MARCH/  Re 
 gion(%) 


 28.35% 
 33.16% 
 28.32% 
 26.44% 
 28.04% 
 31.69% 
 28.10% 
 29.64% 


 D.  2.5.8 
 OSPCM/  Re 
 gion(%) 


 96.89% 
 96.12% 
 97.38% 
 95.12% 
 97.81% 
 97.35% 
 98.41% 
 95.83% 


 D.  2.5.9 
 Predictor/  Re 
 gion(%) 


 15.78% 
 19.48% 
 15.03% 
 20.43% 
 13.82% 
 19.61% 
 12.71% 
 21.73% 


 D.  2.5.10 
 SOCS/  Re 
 gion(%) 


 99.99% 
 99.99% 
 99.99% 
 99.98% 
 99.98% 
 100.00% 


 99.98% 
 100.00% 


 D.  2.5.11 
 NIW/  Region(%) 


 99.17% 
 98.96% 
 99.49% 
 99.33% 
 99.39% 
 99.21% 
 99.42% 
 99.25% 


 G-  41 
409
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Georgia 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 Average 
 Response 


 Interval 
 > 
 10 


 Seconds 


 [OSS-  4] 


 D.  2.6.1 
 CRIS/  Re 
 gion(%) 


 1.01% 
 0.66% 
 1.03% 
 0.66% 
 0.95% 
 0.54% 
 0.98% 
 0.61% 


 D.  2.6.2 
 DLETH/  Re 
 gion(%) 


 21.19% 
 13.84% 
 21.04% 
 12.08% 
 20.80% 
 14.70% 
 22.34% 
 17.42% 


 D.  2.6.3 
 DLR/  Re 
 gion(%) 


 22.06% 
 7.98% 
 22.55% 


 8.02% 
 23.35% 
 11.82% 
 28.92% 
 58.33% 


 D.  2.6.4 
 LMOS/  Re 
 gion(%) 


 0.19% 
 0.14% 
 0.21% 
 0.18% 
 0.21% 
 0.16% 
 0.20% 
 0.15% 


 D.  2.6.5 
 LMOSu 
 pd/  Region(%) 


 9.05% 
 16.67% 
 10.69% 
 19.41% 
 9.96% 
 19.75% 


 9.41% 
 19.47% 


 D.  2.6.6 
 LNP/  Re 
 gion(%) 


 0.07% 
 0.13% 
 0.46% 
 0.28% 
 0.19% 
 0.37% 
 0.17% 
 0.48% 


 D.  2.6.7 
 MARCH/  Re 
 gion(%) 


 71.65% 
 66.84% 
 71.68% 
 73.56% 
 71.96% 
 68.31% 
 71.90% 
 70.36% 


 D.  2.6.8 
 OSPCM/  Re 
 gion(%) 


 3.11% 
 3.88% 
 2.62% 
 4.88% 
 2.19% 
 2.65% 
 1.59% 
 4.17% 


 D.  2.6.9 
 Predictor/  Re 
 gion(%) 


 84.22% 
 80.52% 
 84.97% 
 79.57% 
 86.18% 
 80.39% 
 87.29% 
 78.27% 


 D.  2.6.10 
 SOCS/  Re 
 gion(%) 


 0.01% 
 0.01% 
 0.01% 
 0.02% 
 0.02% 
 0.00% 
 0.02% 
 0.00% 


 D.  2.6.11 
 NIW/  Region(%) 


 0.83% 
 1.04% 
 0.51% 
 0.67% 
 0.61% 
 0.79% 
 0.58% 
 0.75% 


 COLLOCATION 
 - 
 COLLOCATION  Average  Response  Time  [C- 


 1] 


 E.  1.1.1 
 Virtual/  GA 
 (calendar 
 days) 


 6 
 7 
 5 
 51,2,3,4 


 E.  1.1.2 
 Ph  ysical 
 Caged/  GA( 


 calendar 
 days) 


 9 
 12 


 13 


 9 
 1,3,4 


 E.  1.1.3 
 Ph  ysical 
 Cageless/  GA( 


 calendar 
 days) 


 17 
 14 
 13 
 12 
 3,4 


 Average 
 Arrangement 


 Time 
 [C-  2] 


 E.  1.2.1 
 Virtual-  Ordinar 


 y/  GA( 
 calendar 


 days) 


 31 
 41 
 48 
 2,3,4 


 E.  1.2.3 
 Ph 
 ysical 


 Caged/  GA( 


 calendar 
 days) 


 58 
 57 
 84 
 79 
 3,4 


 E.  1.2.4 
 Ph  ysical 
 Cageless/  GA( 


 calendar 
 days) 


 48 
 53 
 57 
 54 
 1,3 


 % 
 Due 


 Dates 


 Missed 


 [C-  3] 


 E.  1.3.1 
 Virtual/  GA 
 (%) 


 0.00% 
 0.00% 
 0.00% 
 2,3,4 


 E.  1.3.2 
 Ph 
 ysical/  GA(%) 


 0.00% 
 0.00% 
 0.00% 
 0.00% 


 GENERAL 
 - 
 FLOW 


 THROUGH  %  Flow  Through  Service 


 Requests 
 [O-  3] 


 F.  1.1.1 
 Summar  y/ 
 Region(%) 


 85.28% 
 86.05% 
 84.50% 
 85.96% 


 F.  1.1.2 
 A 
 ggregate/  Region(%) 


 85.28% 
 86.05% 
 84.50% 
 85.96% 


 F.  1.1.3 
 Residence/  Re 
 gion(%) 


 86.49% 
 87.39% 
 86.74% 
 88.58% 


 F.  1.1.4 
 Business/  Re 
 gion(%) 


 73.55% 
 71.89% 
 69.54% 
 73.74% 


 F.  1.1.5 
 UNE/  Re 
 gion(%) 


 83.88% 
 84.78% 
 82.57% 
 83.84% 


 % 
 Flow 


 Through 


 Service 
 Requests 


 - 
 Achieved 


 [O-  3] 


 F.  1.2.1 
 Summar  y/ 
 Region(%) 


 75.79% 
 77.51% 
 76.58% 
 78.96% 


 G-  42 
410
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Georgia 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 F.  1.2.2 
 Aggregate/  Region(%) 


 75.79% 
 77.51% 
 76.58% 
 78.96% 


 F.  1.2.3 
 Residence/  Re 
 gion(%) 


 79.16% 
 80.53% 
 79.88% 
 81.68% 


 F.  1.2.4 
 Business/  Re 
 gion(%) 


 50.63% 
 51.15% 
 51.58% 
 53.42% 


 F.  1.2.5 
 UNE/  Re 
 gion(%) 


 72.17% 
 74.87% 
 74.12% 
 77.27% 


 % 
 Flow 


 Through 


 Service 
 Requests 


 - 
 LNP 


 [O-  3] 


 F.  1.3.1 
 Summar  y/ 
 Region(%) 


 92.25% 
 92.59% 
 89.75% 
 83.63% 


 F.  1.3.2 
 A 
 ggregate/  Region(%) 


 92.25% 
 92.59% 
 89.75% 
 83.63% 


 GENERAL 
 - 
 PRE-  ORDERING  Loop  Makeup 


 Inquiry 
 (Manual) 


 [PO-  1] 


 F.  2.1 
 Loo 
 ps/  GA(%) 


 100.00% 
 66.67% 
 38.89% 
 2,3 


 Loop 
 Makeup 


 Inquiry 
 (Electronic) 


 [PO-  2] 


 F.  2.2 
 Loo 
 ps/  GA(%) 


 95.99% 
 92.13% 
 97.90% 
 80.60% 


 GENERAL 
 - 
 ORDERING  Average  Speed 


 of 
 Answer 


 [O-  12] 


 F.  4.1 
 Re 
 gion( 


 seconds) 


 141.64 
 30.33 
 137.90 


 28.63 
 194.86 


 35.16 
 259.48 


 58.19 


 GENERAL 
 - 
 MAINTENANCE 


 CENTER 
 Average 
 Answer 
 Time 
 [M&  R- 


 6] 


 F.  5.1 
 Re 
 gion( 


 seconds) 


 43.10 
 26.35 
 41.00 
 23.60 
 64.68 
 25.99 
 52.80 
 28.04 


 GENERAL 
 - 
 OPERATOR 


 SERVICES 
 (TOLL) 


 Average 
 Speed 
 to 
 Answer 


 [OS-  1] 


 F.  6.1 
 GA 
 (seconds) 


 2.50 
 2.31 
 2.24 
 2.44 


 % 
 Answered 


 in 
 10 
 seconds 


 [OS-  2] 


 F.  6.2 
 GA 
 (%) 


 92.30% 
 93.20% 
 93.70% 
 92.80% 


 GENERAL 
 - 
 DIRECTORY 


 ASSISTANCE 
 Average 
 Speed 
 to 
 Answer 


 [DA-  1] 


 F.  7.1 
 GA 
 (seconds) 


 6.11 
 6.25 
 5.79 
 5.66 


 % 
 Answered 


 in 
 12 
 seconds 


 [DA-  2] 


 F.  7.2 
 GA 
 (%) 


 83.00% 
 82.10% 
 84.60% 
 85.00% 


 GENERAL 
 - 
 BILLING  Usage  Data 


 Delivery 
 Accuracy 


 [B-  3] 


 F.  9.1 
 Re 
 gion(%) 


 100.00% 
 100.00% 
 97.75% 
 100.00% 


 95.22% 
 100.00% 
 100.00% 
 100.00% 


 Usage 
 Data 
 Delivery 


 Timeliness 


 [B-  5] 


 F.  9.2 
 Re 
 gion(%) 


 98.37% 
 93.14% 
 75.41% 
 94.80% 
 94.93% 
 97.64% 
 99.33% 
 99.38% 


 G-  43 
411
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Georgia 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 Usage 
 Data 
 Delivery 


 Completeness 


 [B-  4] 


 F.  9.3 
 Re 
 gion(%) 


 99.38% 
 99.89% 
 99.77% 
 99.54% 
 97.21% 
 99.95% 
 99.92% 
 99.91% 


 Mean 
 Time 
 to 
 Deliver 


 Usage 
 [B-  6] 


 F.  9.4 
 Re 
 gion( 


 days) 


 3.49 
 3.05 
 6.85 
 3.29 
 4.34 
 2.52 
 3.24 
 2.43 


 Recurring 
 Charge 
 Completeness 


 [B-  7] 


 F.  9.5.1 
 Resale/  GA 
 (%) 


 77.01% 
 96.32% 
 82.68% 
 94.20% 
 77.51% 
 97.80% 
 81.54% 
 98.83% 


 F.  9.5.2 
 UNE/  GA 
 (%) 


 99.46% 
 99.29% 
 99.11% 
 98.29% 


 F.  9.5.3 
 Interconnection/  GA 


 (%) 


 97.49% 
 97.47% 
 99.53% 
 90.58% 


 Non-  Recurring 
 Charge 
 Completeness 


 [B-  8] 


 F.  9.6.1 
 Resale/  GA 
 (%) 


 90.17% 
 93.79% 
 85.38% 
 95.44% 
 90.83% 
 98.37% 
 90.45% 
 98.59% 


 F.  9.6.2 
 UNE/  GA 
 (%) 


 94.41% 
 95.60% 
 97.59% 
 97.67% 


 F.  9.6.3 
 Interconnection/  GA 


 (%) 


 69.98% 
 98.02% 
 94.37% 
 94.38% 


 GENERAL 
 - 
 CHANGE 


 MANAGEMENT  %  Software  Release  Notices  Sent 


 On 
 Time 


 [CM-  1] 


 F.  10.1 
 GA 
 (%) 


 100.00% 
 100.00% 


 2,3 


 % 
 Change 


 Management 


 Documentation 


 Sent 
 On 
 Time 


 [CM-  3A] 


 F.  10.3 
 GA 
 (%) 


 100.00% 
 100.00% 
 1,4 


 % 
 Change 


 Management 


 Documentation 


 (Defects, 
 Corrections, 


 etc.) 
 Sent 
 On 
 Time 


 [CM-  3B] 


 F.  10.4 
 GA 
 (%) 


 77.78% 
 2 


 Average 
 Documentation 


 Release 
 Delay 
 Days 
 [CM-  4] 


 F.  10.5 
 GA 
 (average)  %  CLEC  Interface 


 Outages 
 Sent 
 within 


 15 
 Minutes 


 [CM-  5] 


 F.  10.6 
 GA 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 GENERAL 
 - 
 NEW 


 BUSINESS 


 REQUESTS 


 % 
 New 


 Business 


 Requests 
 Processed 


 within 
 30 
 Business 


 Days 
 [BFR-  1] 


 F.  11.1 
 Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 
 1,2,3,4 


 % 
 Quotes 


 Provided 


 within 
 X 
 Business 


 Days 
 [BFR-  2A] 


 F.  11.2.1 
 Re 
 gion(%) 


 100.00% 
 100.00% 
 1,3 


 F.  11.2.3 
 Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 2,3,4 


 GENERAL 
 - 
 ORDERING  Acknowledgement 


 Message 
 Timeliness 


 [O-  1] 


 F.  12.1.1 
 EDI/  Re 
 gion(%) 


 99.97% 
 99.99% 
 100.00% 
 100.00% 


 F.  12.1.2 
 TAG/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 100.00% 


 G-  44 
412
 Metric 
 Metric 
 Name 
 [SQM 
 Number] 


 Number 
 and 
 Disaggregation 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 


 BST 
 CLEC 
 Notes 


 Federal 
 Communications 


 Commission 


 FCC 
 02-  260 


 Georgia 
 Performance 


 Metric 
 Data 


 March 


 April 
 May 
 June 


 Acknowledgement 
 Message 
 Completeness 


 [O-  2] 


 F.  12.2.1 
 EDI/  Re 
 gion(%) 


 100.00% 
 100.00% 
 100.00% 
 99.62% 


 F.  12.2.2 
 TAG/  Re 
 gion(%) 


 100.00% 
 100.00% 
 99.99% 
 100.00% 


 GENERAL 
 - 
 DATABASE 


 UPDATES 
 Average 
 Database 


 Update 
 Interval 


 [D-  1] 


 F.  13.1.1 
 LIDB/  GA 
 (hours) 


 1.38 
 1.38 
 1.01 
 1.01 
 1.06 
 1.06 
 0.87 
 0.87 


 F.  13.1.2 
 Director  y 
 Listings/  GA( 


 hours) 


 0.10 
 0.10 
 0.09 
 0.09 
 0.10 
 0.10 
 0.11 
 0.11 


 F.  13.1.3 
 Director  y 
 Assistance/  GA( 


 hours) 


 3.65 
 3.44 
 4.03 
 3.63 
 4.15 
 3.29 
 5.98 
 5.09 


 % 
 Update 


 Accuracy 


 [D-  2] 


 F.  13.2.1 
 LIDB/  GA 
 (%) 


 100.00% 
 100.00% 
 100.00% 
 93.48% 


 F.  13.2.2 
 Director  y 
 Listings/  GA(%) 


 99.38% 
 99.03% 
 99.79% 
 99.35% 


 F.  13.2.3 
 Director  y 
 Assistance/  GA(%) 


 100.00% 
 100.00% 
 97.87% 
 99.19% 


 % 
 NXXs 


 / 
 LRNs 


 Loaded 


 by 
 LERG 


 Effective 


 Date 
 [D-  3] 


 F.  13.3 
 Re 
 gion(%) 


 96.77% 
 100.00% 
 100.00% 
 98.41% 


 GENERAL 
 - 
 NETWORK 


 OUTAGE 
 NOTIFICATION 


 Mean 
 Time 
 to 
 Notify 


 CLEC 
 of 
 Major 


 Network 


 Outages 
 [M&  R- 
 7] 


 F.  14.1 
 Region(  minutes) 


 739 
 218 


 0 
 0 
 154 


 123 
 791 
 602 
 1,3,4 


 Abbreviations:  blank  cell  =  no  data 
 available 
 Notes:  1  =  Sample 
 Size 
 under 


 10 
 in 
 March 


 2 
 = 
 Sample 


 Size 
 under 


 10 
 in 
 April 


 2 
 = 
 Sample 


 Size 
 under 


 10 
 in 
 May 


 4 
 = 
 Sample 


 Size 
 under 


 10 
 in 
 June 


 G-  45 
413
 Federal  Communications  Commission  FCC  02-  260 
 Appendix  H  Statutory  Requirements 
 I.  STATUTORY  FRAMEWORK 
 1.  The  1996  Act  conditions  BOC  entry  into  the  market  for  provision  of  in-  region  interLATA  services  on  compliance  with  certain  provisions  of  section  271.  1  BOCs  must  apply  to 


 the  Federal  Communications  Commission  (Commission  or  FCC)  for  authorization  to  provide  interLATA  services  originating  in  any  in-  region  state.  2  The  Commission  must  issue  a  written 
 determination  on  each  application  no  later  than  90  days  after  receiving  such  application.  3  Section  271(  d)(  2)(  A)  requires  the  Commission  to  consult  with  the  Attorney  General  before 
 making  any  determination  approving  or  denying  a  section  271  application.  The  Attorney  General  is  entitled  to  evaluate  the  application  using  any  standard  the  Attorney  General 
 considers  appropriate,  and  the  Commission  is  required  to  give  substantial  weight  to  the  Attorney  Generals  evaluation.  4 


 2.  In  addition,  the  Commission  must  consult  with  the  relevant  state  commission  to  verify  that  the  BOC  has  one  or  more  state-  approved  interconnection  agreements  with  a  facilities-based 
 competitor,  or  a  Statement  of  Generally  Available  Terms  and  Conditions  (SGAT),  and  that  either  the  agreement(  s)  or  general  statement  satisfy  the  competitive  checklist.  5  Because  the 
 Act  does  not  prescribe  any  standard  for  the  consideration  of  a  state  commissions  verification  under  section  271(  d)(  2)(  B),  the  Commission  has  discretion  in  each  section  271  proceeding  to 


 1  For  purposes  of  section  271  proceedings,  the  Commission  uses  the  definition  of  the  term  Bell  Operating 
 Company  contained  in  47  U.  S.  C.    153(  4). 
 2  47  U.  S.  C.    271(  d)(  1).  For  purposes  of  section  271  proceedings,  the  Commission  utilizes  the  definition  of  the 
 term  in-  region  state  that  is  contained  in  47  U.  S.  C.    271(  i)(  1).  Section  271(  j)  provides  that  a  BOCs  in-  region  services  include  800  service,  private  line  service,  or  their  equivalents  that  terminate  in  an  in-  region  state  of  that 


 BOC  and  that  allow  the  called  party  to  determine  the  interLATA  carrier,  even  if  such  services  originate  out-  of-region.  Id.    271(  j).  The  1996  Act  defines  interLATA  services  as  telecommunications  between  a  point  located 
 in  a  local  access  and  transport  area  and  a  point  located  outside  such  area.  Id.    153(  21).  Under  the  1996  Act,  a  local  access  and  transport  area  (LATA)  is  a  contiguous  geographic  area  (A)  established  before  the  date  of 
 enactment  of  the  [1996  Act]  by  a  [BOC]  such  that  no  exchange  area  includes  points  within  more  than  1  metropolitan  statistical  area,  consolidated  metropolitan  statistical  area,  or  State,  except  as  expressly  permitted  under 
 the  AT&  T  Consent  Decree;  or  (B)  established  or  modified  by  a  [BOC]  after  such  date  of  enactment  and  approved  by  the  Commission.  Id.    153(  25).  LATAs  were  created  as  part  of  the  Modification  of  Final  Judgments  (MFJ) 
 plan  of  reorganization.  United  States  v.  Western  Elec.  Co.,  569  F.  Supp.  1057  (D.  D.  C.  1983),  affd  sub  nom.  California  v.  United  States,  464  U.  S.  1013  (1983).  Pursuant  to  the  MFJ,  all  [BOC]  territory  in  the  continental 
 United  States  [was]  divided  into  LATAs,  generally  centering  upon  a  city  or  other  identifiable  community  of  interest.  United  States  v.  Western  Elec.  Co.,  569  F.  Supp.  990,  993-  94  (D.  D.  C.  1983). 


 3  47  U.  S.  C.    271(  d)(  3). 
 4  Id.    271(  d)(  2)(  A). 
 5  Id.    271(  d)(  2)(  B). 
414
 Federal  Communications  Commission  FCC  02-  260 
 H-  2 
 determine  the  amount  of  weight  to  accord  the  state  commissions  verification.  6  The  Commission  has  held  that,  although  it  will  consider  carefully  state  determinations  of  fact  that  are  supported  by 
 a  detailed  and  extensive  record,  it  is  the  FCCs  role  to  determine  whether  the  factual  record  supports  the  conclusion  that  particular  requirements  of  section  271  have  been  met.  7 


 3.  Section  271  requires  the  Commission  to  make  various  findings  before  approving  BOC  entry.  In  order  for  the  Commission  to  approve  a  BOCs  application  to  provide  in-  region, 
 interLATA  services,  a  BOC  must  first  demonstrate,  with  respect  to  each  state  for  which  it  seeks  authorization,  that  it  satisfies  the  requirements  of  either  section  271(  c)(  1)(  A)  (Track  A)  or 
 271(  c)(  1)(  B)  (Track  B).  8  In  order  to  obtain  authorization  under  section  271,  the  BOC  must  also  show  that:  (1)  it  has  fully  implemented  the  competitive  checklist  contained  in  section 
 271(  c)(  2)(  B);  9  (2)  the  requested  authorization  will  be  carried  out  in  accordance  with  the  requirements  of  section  272;  10  and  (3)  the  BOCs  entry  into  the  in-  region  interLATA  market  is 
 consistent  with  the  public  interest,  convenience,  and  necessity.  11  The  statute  specifies  that,  unless  the  Commission  finds  that  these  criteria  have  been  satisfied,  the  Commission  shall  not 
 approve  the  requested  authorization.  12 


 6  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  3962,  para.  20;  Application  of  Ameritech  Michigan  Pursuant  to 
 Section  271  of  the  Communications  Act  of  1934,  as  amended,  CC  Docket  No.  97-  137,  12  FCC  Rcd  20543,  20559-  60  (1997)  (Ameritech  Michigan  Order).  As  the  D.  C.  Circuit  has  held,  [  a]  lthough  the  Commission  must  consult 


 with  the  state  commissions,  the  statute  does  not  require  the  Commission  to  give  State  Commissions  views  any  particular  weight.  SBC  Communications  Inc.  v.  FCC,  138  F.  3d  410,  416  (D.  C.  Cir.  1998). 


 7  Ameritech  Michigan  Order,  12  FCC  Rcd  at  20560;  SBC  Communications  v.  FCC,  138  F.  3d  at  416-  17. 
 8  47  U.  S.  C.    271(  d)(  3)(  A).  See  Section  III,  infra,  for  a  complete  discussion  of  Track  A  and  Track  B 
 requirements. 
 9  Id.    271(  c)(  2)(  B),  271(  d)(  3)(  A)(  i). 


 10  Id.    272;  see  Implementation  of  the  Non-  Accounting  Safeguards  of  Sections  271  and  272  of  the 
 Communications  Act  of  1934,  as  amended,  CC  Docket  No.  96-  149,  First  Report  and  Order  and  Further  Notice  of  Proposed  Rulemaking,  11  FCC  Rcd  21905  (1996)  (Non-  Accounting  Safeguards  Order),  recon.,  Order  on 


 Reconsideration,  12  FCC  Rcd  2297  (1997),  review  pending  sub  nom.,  SBC  Communications  v.  FCC,  No.  97-  1118  (D.  C.  Cir.,  filed  Mar.  6,  1997)  (held  in  abeyance  pursuant  to  court  order  filed  May  7,  1997),  remanded  in  part  sub 
 nom.,  Bell  Atlantic  Telephone  Companies  v.  FCC,  No.  97-  1067  (D.  C.  Cir.,  filed  Mar.  31,  1997),  on  remand,  Second  Order  on  Reconsideration,  FCC  97-  222  (rel.  June  24,  1997),  petition  for  review  denied  sub  nom.  Bell  Atlantic 
 Telephone  Companies  v.  FCC,  113  F.  3d  1044  (D.  C.  Cir.  1997);  Implementation  of  the  Telecommunications  Act  of  1996;  Accounting  Safeguards  Under  the  Telecommunications  Act  of  1996,  Report  and  Order,  11  FCC  Rcd  17539 
 (1996). 
 11  47  U.  S.  C.    271(  d)(  3)(  C). 


 12  Id.    271(  d)(  3);  see  SBC  Communications,  Inc.  v.  FCC,  138  F.  3d  at  416. 
415
 Federal  Communications  Commission  FCC  02-  260 
 H-  3 
 II.  PROCEDURAL  AND  ANALYTICAL  FRAMEWORK 
 4.  To  determine  whether  a  BOC  applicant  has  met  the  prerequisites  for  entry  into  the  long  distance  market,  the  Commission  evaluates  its  compliance  with  the  competitive  checklist, 


 as  developed  in  the  FCCs  local  competition  rules  and  orders  in  effect  at  the  time  the  application  was  filed.  Despite  the  comprehensiveness  of  these  rules,  there  will  inevitably  be,  in  any  section 
 271  proceeding,  disputes  over  an  incumbent  LECs  precise  obligations  to  its  competitors  that  FCC  rules  have  not  addressed  and  that  do  not  involve  per  se  violations  of  self-  executing 
 requirements  of  the  Act.  As  explained  in  prior  orders,  the  section  271  process  simply  could  not  function  as  Congress  intended  if  the  Commission  were  required  to  resolve  all  such  disputes  as  a 
 precondition  to  granting  a  section  271  application.  13  In  the  context  of  section  271s  adjudicatory  framework,  the  Commission  has  established  certain  procedural  rules  governing  BOC  section  271 
 applications.  14  The  Commission  has  explained  in  prior  orders  the  procedural  rules  it  has  developed  to  facilitate  the  review  process.  15  Here  we  describe  how  the  Commission  considers 
 the  evidence  of  compliance  that  the  BOC  presents  in  its  application. 
 5.  As  part  of  the  determination  that  a  BOC  has  satisfied  the  requirements  of  section  271,  the  Commission  considers  whether  the  BOC  has  fully  implemented  the  competitive 


 checklist  in  subsection  (c)(  2)(  B).  The  BOC  at  all  times  bears  the  burden  of  proof  of  compliance  with  section  271,  even  if  no  party  challenges  its  compliance  with  a  particular  requirement.  16  In 
 demonstrating  its  compliance,  a  BOC  must  show  that  it  has  a  concrete  and  specific  legal  obligation  to  furnish  the  item  upon  request  pursuant  to  state-  approved  interconnection 
 agreements  that  set  forth  prices  and  other  terms  and  conditions  for  each  checklist  item,  and  that  it  is  currently  furnishing,  or  is  ready  to  furnish,  the  checklist  items  in  quantities  that  competitors 
 may  reasonably  demand  and  at  an  acceptable  level  of  quality.  17  In  particular,  the  BOC  must  demonstrate  that  it  is  offering  interconnection  and  access  to  network  elements  on  a 


 13  See  SWBT  Kansas/  Oklahoma  Order,  16  FCC  Rcd  at  6246,  para.  19;  see  also  American  Tel.  &  Tel.  Co.  v.  FCC, 
 220  F.  3d  607,  631  (D.  C.  Cir.  2000). 
 14  See  Procedures  for  Bell  Operating  Company  Applications  Under  New  Section  271  of  the  Communications  Act, 
 Public  Notice,  11  FCC  Rcd  19708,  19711  (1996);  Revised  Comment  Schedule  For  Ameritech  Michigan  Application,  as  amended,  for  Authorization  Under  Section  271  of  the  Communications  Act  to  Provide  In-  Region,  InterLATA 


 Services  in  the  State  of  Michigan,  Public  Notice,  DA  97-  127  (rel.  Jan.  17,  1997);  Revised  Procedures  for  Bell  Operating  Company  Applications  Under  Section  271  of  the  Communications  Act,  Public  Notice,  13  FCC  Rcd  17457 
 (1997);  Updated  Filing  Requirements  for  Bell  Operating  Company  Applications  Under  Section  271  of  the  Communications  Act,  Public  Notice,  DA  99-  1994  (rel.  Sept.  28,  1999);  Updated  Filing  Requirements  for  Bell 
 Operating  Company  Applications  Under  Section  271  of  the  Communications  Act,  Public  Notice,  DA  01-  734  (CCB  rel.  Mar.  23,  2001)  (collectively  271  Procedural  Public  Notices). 


 15  See,  e.  g.,  SWBT  Kansas/  Oklahoma  Order  16  FCC  Rcd  at  6247-  50,  paras.  21-  27;  SWBT  Texas  Order,  15  FCC 
 Rcd  at  18370-  73,  paras.  34-  42;  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  3968-  71,  paras.  32-  42. 
 16  See  SWBT  Texas  Order,  15  FCC  Rcd  at  18374,  para.  46;  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  3972, 
 para.  46. 
 17  See  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  3973-  74,  para.  52. 
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 nondiscriminatory  basis.  18  Previous  Commission  orders  addressing  section  271  applications  have  elaborated  on  this  statutory  standard.  19  First,  for  those  functions  the  BOC  provides  to 
 competing  carriers  that  are  analogous  to  the  functions  a  BOC  provides  to  itself  in  connection  with  its  own  retail  service  offerings,  the  BOC  must  provide  access  to  competing  carriers  in 
 substantially  the  same  time  and  manner  as  it  provides  to  itself.  20  Thus,  where  a  retail  analogue  exists,  a  BOC  must  provide  access  that  is  equal  to  (i.  e.,  substantially  the  same  as)  the  level  of 
 access  that  the  BOC  provides  itself,  its  customers,  or  its  affiliates,  in  terms  of  quality,  accuracy,  and  timeliness.  21  For  those  functions  that  have  no  retail  analogue,  the  BOC  must  demonstrate  that 
 the  access  it  provides  to  competing  carriers  would  offer  an  efficient  carrier  a  meaningful  opportunity  to  compete.  22 


 6.  The  determination  of  whether  the  statutory  standard  is  met  is  ultimately  a  judgment  the  Commission  must  make  based  on  its  expertise  in  promoting  competition  in  local 
 markets  and  in  telecommunications  regulation  generally.  23  The  Commission  has  not  established,  nor  does  it  believe  it  appropriate  to  establish,  specific  objective  criteria  for  what  constitutes 
 substantially  the  same  time  and  manner  or  a  meaningful  opportunity  to  compete.  24  Whether  this  legal  standard  is  met  can  only  be  decided  based  on  an  analysis  of  specific  facts  and 
 circumstances.  Therefore,  the  Commission  looks  at  each  application  on  a  case-  by-  case  basis  and  considers  the  totality  of  the  circumstances,  including  the  origin  and  quality  of  the  information  in 
 the  record,  to  determine  whether  the  nondiscrimination  requirements  of  the  Act  are  met. 
 A.  Performance  Data 
 7.  As  established  in  prior  section  271  orders,  the  Commission  has  found  that  performance  measurements  provide  valuable  evidence  regarding  a  BOCs  compliance  or 


 noncompliance  with  individual  checklist  items.  The  Commission  expects  that,  in  its  prima  facie  case  in  the  initial  application,  a  BOC  relying  on  performance  data  will: 


 18  See  47  U.  S.  C.    271(  c)(  2)(  B)(  i),  (ii). 
 19  See  SWBT  Kansas/  Oklahoma  Order,  16  FCC  Rcd  at  6250-  51,  paras.  28-  29;  Bell  Atlantic  New  York  Order,  15 
 FCC  Rcd  at  3971-  72,  paras.  44-  46. 
 20  SWBT  Texas  Order,  15  FCC  Rcd  at  18373,  para.  44;  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  3971,  para. 
 44. 
 21  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  3971,  para.  44;  Ameritech  Michigan  Order,  12  FCC  Rcd  at 
 20618-  19. 
 22  Id. 


 23  SWBT  Texas  Order,  15  FCC  Rcd  at  18374,  para.  46;  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  3972,  para. 
 46. 
 24  Id. 
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 a)  provide  sufficient  performance  data  to  support  its  contention  that  the  statutory  requirements  are  satisfied; 
 b)  identify  the  facial  disparities  between  the  applicants  performance  for  itself  and  its  performance  for  competitors; 
 c)  explain  why  those  facial  disparities  are  anomalous,  caused  by  forces  beyond  the  applicants  control  (e.  g.,  competing  carrier-  caused  errors),  or  have  no  meaningful  adverse  impact  on  a 
 competing  carriers  ability  to  obtain  and  serve  customers;  and 
 d)  provide  the  underlying  data,  analysis,  and  methodologies  necessary  to  enable  the  Commission  and  commenters  meaningfully  to  evaluate  and  contest  the  validity  of  the 


 applicants  explanations  for  performance  disparities,  including,  for  example,  carrier  specific  carrier-  to-  carrier  performance  data. 


 8.  The  Commission  has  explained  in  prior  orders  that  parity  and  benchmark  standards  established  by  state  commissions  do  not  represent  absolute  maximum  or  minimum 
 levels  of  performance  necessary  to  satisfy  the  competitive  checklist.  Rather,  where  these  standards  are  developed  through  open  proceedings  with  input  from  both  the  incumbent  and 
 competing  carriers,  these  standards  can  represent  informed  and  reliable  attempts  to  objectively  approximate  whether  competing  carriers  are  being  served  by  the  incumbent  in  substantially  the 
 same  time  and  manner,  or  in  a  way  that  provides  them  a  meaningful  opportunity  to  compete.  25  Thus,  to  the  extent  there  is  no  statistically  significant  difference  between  a  BOCs  provision  of 
 service  to  competing  carriers  and  its  own  retail  customers,  the  Commission  generally  need  not  look  any  further.  Likewise,  if  a  BOCs  provision  of  service  to  competing  carriers  satisfies  the 
 performance  benchmark,  the  analysis  is  usually  done.  Otherwise,  the  Commission  will  examine  the  evidence  further  to  make  a  determination  whether  the  statutory  nondiscrimination 
 requirements  are  met.  26  Thus,  the  Commission  will  examine  the  explanations  that  a  BOC  and  others  provide  about  whether  these  data  accurately  depict  the  quality  of  the  BOCs  performance. 
 The  Commission  also  may  examine  how  many  months  a  variation  in  performance  has  existed  and  what  the  recent  trend  has  been.  The  Commission  may  find  that  statistically  significant 
 differences  exist,  but  conclude  that  such  differences  have  little  or  no  competitive  significance  in  the  marketplace.  In  such  cases,  the  Commission  may  conclude  that  the  differences  are  not 
 meaningful  in  terms  of  statutory  compliance.  Ultimately,  the  determination  of  whether  a  BOCs  performance  meets  the  statutory  requirements  necessarily  is  a  contextual  decision  based  on  the 
 totality  of  the  circumstances  and  information  before  the  Commission. 
 9.  Where  there  are  multiple  performance  measures  associated  with  a  particular  checklist  item,  the  Commission  would  consider  the  performance  demonstrated  by  all  the 


 measurements  as  a  whole.  Accordingly,  a  disparity  in  performance  for  one  measure,  by  itself, 
 25  See  SWBT  Kansas/  Oklahoma  Order,  16  FCC  Rcd  at  6252,  para.  31;  SWBT  Texas  Order,  15  FCC  Rcd  at  18377, 
 para.  55  &  n.  102. 
 26  See  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  3970,  para.  59. 
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 may  not  provide  a  basis  for  finding  noncompliance  with  the  checklist.  The  Commission  may  also  find  that  the  reported  performance  data  are  affected  by  factors  beyond  a  BOCs  control,  a 
 finding  that  would  make  it  less  likely  to  hold  the  BOC  wholly  accountable  for  the  disparity.  This  is  not  to  say,  however,  that  performance  discrepancies  on  a  single  performance  metric  are 
 unimportant.  Indeed,  under  certain  circumstances,  disparity  with  respect  to  one  performance  measurement  may  support  a  finding  of  statutory  noncompliance,  particularly  if  the  disparity  is 
 substantial  or  has  endured  for  a  long  time,  or  if  it  is  accompanied  by  other  evidence  of  discriminatory  conduct  or  evidence  that  competing  carriers  have  been  denied  a  meaningful 
 opportunity  to  compete. 
 10.  In  sum,  the  Commission  does  not  use  performance  measurements  as  a  substitute  for  the  14-  point  competitive  checklist.  Rather,  it  uses  performance  measurements  as  valuable 


 evidence  with  which  to  inform  the  judgment  as  to  whether  a  BOC  has  complied  with  the  checklist  requirements.  Although  performance  measurements  add  necessary  objectivity  and 
 predictability  to  the  review,  they  cannot  wholly  replace  the  Commissions  own  judgment  as  to  whether  a  BOC  has  complied  with  the  competitive  checklist. 


 B.  Relevance  of  Previous  Section  271  Approvals 
 11.  In  some  section  271  applications,  the  volumes  of  the  BOCs  commercial  orders  may  be  significantly  lower  than  they  were  in  prior  proceedings.  In  certain  instances,  volumes 


 may  be  so  low  as  to  render  the  performance  data  inconsistent  and  inconclusive.  27  Performance  data  based  on  low  volumes  of  orders  or  other  transactions  are  not  as  reliable  an  indicator  of 
 checklist  compliance  as  performance  based  on  larger  numbers  of  observations.  Indeed,  where  performance  data  are  based  on  a  low  number  of  observations,  small  variations  in  performance 
 may  produce  wide  swings  in  the  reported  performance  data.  It  is  thus  not  possible  to  place  the  same  evidentiary  weight  upon    and  to  draw  the  same  types  of  conclusions  from    performance 
 data  where  volumes  are  low,  as  for  data  based  on  more  robust  activity. 
 12.  In  such  cases,  findings  in  prior,  related  section  271  proceedings  may  be  a  relevant  factor  in  the  Commissions  analysis.  Where  a  BOC  provides  evidence  that  a  particular  system 


 reviewed  and  approved  in  a  prior  section  271  proceeding  is  also  used  in  the  proceeding  at  hand,  the  Commissions  review  of  the  same  system  in  the  current  proceeding  will  be  informed  by  the 
 findings  in  the  prior  one.  Indeed,  to  the  extent  that  issues  have  already  been  briefed,  reviewed  and  resolved  in  a  prior  section  271  proceeding,  and  absent  new  evidence  or  changed 
 circumstances,  an  application  for  a  related  state  should  not  be  a  forum  for  re-  litigating  and  reconsidering  those  issues.  Appropriately  employed,  such  a  practice  can  give  us  a  fuller  picture 
 of  the  BOCs  compliance  with  the  section  271  requirements  while  avoiding,  for  all  parties 


 27  The  Commission  has  never  required,  however,  an  applicant  to  demonstrate  that  it  processes  and  provisions  a 
 substantial  commercial  volume  of  orders,  or  has  achieved  a  specific  market  share  in  its  service  area,  as  a  prerequisite  for  satisfying  the  competitive  checklist.  See  Ameritech  Michigan  Order,  12  FCC  Rcd  at  20585,  para. 


 77  (explaining  that  Congress  had  considered  and  rejected  language  that  would  have  imposed  a  market  share  requirement  in  section  271(  c)(  1)(  A)). 
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 involved  in  the  section  271  process,  the  delay  and  expense  associated  with  redundant  and  unnecessary  proceedings  and  submissions. 
 13.  However,  the  statute  requires  the  Commission  to  make  a  separate  determination  of  checklist  compliance  for  each  state  and,  accordingly,  we  do  not  consider  any  finding  from 
 previous  section  271  orders  to  be  dispositive  of  checklist  compliance  in  current  proceedings.  While  the  Commissions  review  may  be  informed  by  prior  findings,  the  Commission  will 
 consider  all  relevant  evidence  in  the  record,  including  state-  specific  factors  identified  by  commenting  parties,  the  states,  the  Department  of  Justice.  However,  the  Commission  has  always 
 held  that  an  applicants  performance  towards  competing  carriers  in  an  actual  commercial  environment  is  the  best  evidence  of  nondiscriminatory  access  to  OSS  and  other  network 
 elements.  28  Thus,  the  BOCs  actual  performance  in  the  applicant  state  may  be  relevant  to  the  analysis  and  determinations  with  respect  to  the  14  checklist  items.  Evidence  of  satisfactory 
 performance  in  another  state  cannot  trump  convincing  evidence  that  an  applicant  fails  to  provide  nondiscriminatory  access  to  a  network  element  in  the  applicant  state. 


 14.  Moreover,  because  the  Commissions  review  of  a  section  271  application  must  be  based  on  a  snapshot  of  a  BOCs  recent  performance  at  the  time  an  application  is  filed,  the 
 Commission  cannot  simply  rely  on  findings  relating  to  an  applicants  performance  in  an  anchor  state  at  the  time  it  issued  the  determination  for  that  state.  The  performance  in  that  state  could 
 change  due  to  a  multitude  of  factors,  such  as  increased  order  volumes  or  shifts  in  the  mix  of  the  types  of  services  or  UNEs  requested  by  competing  carriers.  Thus,  even  when  the  applicant 
 makes  a  convincing  showing  of  the  relevance  of  anchor  state  data,  the  Commission  must  examine  how  recent  performance  in  that  state  compares  to  performance  at  the  time  it  approved 
 that  states  section  271  application,  in  order  to  determine  if  the  systems  and  processes  continue  to  perform  at  acceptable  levels. 


 III.  COMPLIANCE  WITH  ENTRY  REQUIREMENTS    SECTIONS  271(  c)(  1)(  A)  &  271(  c)(  1)(  B) 
 15.  As  noted  above,  in  order  for  the  Commission  to  approve  a  BOCs  application  to  provide  in-  region,  interLATA  services,  a  BOC  must  first  demonstrate  that  it  satisfies  the 
 requirements  of  either  section  271(  c)(  1)(  A)  (Track  A)  or  271(  c)(  1)(  B)  (Track  B).  29  To  qualify  for  Track  A,  a  BOC  must  have  interconnection  agreements  with  one  or  more  competing 
 providers  of  telephone  exchange  service  .  .  .  to  residential  and  business  subscribers.  30  The  Act  states  that  such  telephone  service  may  be  offered  .  .  .  either  exclusively  over  [the  competitors] 
 own  telephone  exchange  service  facilities  or  predominantly  over  [the  competitors]  own  telephone  exchange  facilities  in  combination  with  the  resale  of  the  telecommunications  services 


 28  See  SWBT  Texas  Order,  15  FCC  Rcd  at  18376,  para.  53;  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  3974, 
 para.  53. 
 29  See  47  U.  S.  C.    271(  d)(  3)(  A). 


 30  Id. 
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 of  another  carrier.  31  The  Commission  concluded  in  the  Ameritech  Michigan  Order  that  section  271(  c)(  1)(  A)  is  satisfied  if  one  or  more  competing  providers  collectively  serve  residential  and 
 business  subscribers.  32 
 16.  As  an  alternative  to  Track  A,  Section  271(  c)(  1)(  B)  permits  BOCs  to  obtain  authority  to  provide  in-  region,  interLATA  services  if,  after  10  months  from  the  date  of 


 enactment,  no  facilities-  based  provider,  as  described  in  subparagraph  (A),  has  requested  the  access  and  interconnection  arrangements  described  therein  (referencing  one  or  more  binding 
 agreements  approved  under  Section  252),  but  the  state  has  approved  an  SGAT  that  satisfies  the  competitive  checklist  of  subsection  (c)(  2)(  B).  Under  section  271(  d)(  3)(  A)(  ii),  the  Commission 
 shall  not  approve  such  a  request  for  in-  region,  interLATA  service  unless  the  BOC  demonstrates  that,  with  respect  to  access  and  interconnection  generally  offered  pursuant  to  [an  SGAT],  such 
 statement  offers  all  of  the  items  included  in  the  competitive  checklist.  33  Track  B,  however,  is  not  available  to  a  BOC  if  it  has  already  received  a  request  for  access  and  interconnection  from  a 
 prospective  competing  provider  of  telephone  exchange  service.  34 
 IV.  COMPLIANCE  WITH  THE  COMPETITIVE  CHECKLIST    SECTION  271(  c)(  2)(  B) 


 A.  Checklist  Item  1    Interconnection 
 17.  Section  271(  c)(  2)(  B)(  i)  of  the  Act  requires  a  section  271  applicant  to  provide  [  i]  nterconnection  in  accordance  with  the  requirements  of  sections  251(  c)(  2)  and  252(  d)(  1).  35 


 Section  251(  c)(  2)  imposes  a  duty  on  incumbent  LECs  to  provide,  for  the  facilities  and  equipment  of  any  requesting  telecommunications  carrier,  interconnection  with  the  local 
 exchange  carriers  network  .  .  .  for  the  transmission  and  routing  of  telephone  exchange  service  and  exchange  access.  36  In  the  Local  Competition  First  Report  and  Order,  the  Commission 
 concluded  that  interconnection  referred  only  to  the  physical  linking  of  two  networks  for  the 


 31  Id. 
 32  See  Ameritech  Michigan  Order,  12  FCC  Rcd  at  20589,  para.  85;  see  also  Second  BellSouth  Louisiana  Order, 
 13  FCC  Rcd  at  20633-  35,  paras.  46-  48. 
 33  47  U.  S.  C.    271(  d)(  3)(  A)(  ii). 


 34  See  Ameritech  Michigan  Order,  12  FCC  Rcd  at  20561-  62,  para.  34.  Nevertheless,  the  above-  mentioned 
 foreclosure  of  Track  B  as  an  option  is  subject  to  limited  exceptions.  See  47  U.  S.  C.    271(  c)(  1)(  B);  see  also  Ameritech  Michigan  Order,  12  FCC  Rcd  at  20563-  64,  paras.  37-  38. 


 35  47  U.  S.  C.    271(  c)(  2)(  B)(  i);  see  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  3977-  78,  para.  63;  Second 
 BellSouth  Louisiana  Order,  13  FCC  Rcd  at  20640,  para.  61;  Ameritech  Michigan  Order,  12  FCC  Rcd  at  20662,  para.  222. 


 36  47  U.  S.  C.    251(  c)(  2)(  A). 
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 mutual  exchange  of  traffic.  37  Section  251  contains  three  requirements  for  the  provision  of  interconnection.  First,  an  incumbent  LEC  must  provide  interconnection  at  any  technically 
 feasible  point  within  the  carriers  network.  38  Second,  an  incumbent  LEC  must  provide  interconnection  that  is  at  least  equal  in  quality  to  that  provided  by  the  local  exchange  carrier  to 
 itself.  39  Finally,  the  incumbent  LEC  must  provide  interconnection  on  rates,  terms,  and  conditions  that  are  just,  reasonable,  and  nondiscriminatory,  in  accordance  with  the  terms  of  the 
 agreement  and  the  requirements  of  [section  251]  and  section  252.  40 
 18.  To  implement  the  equal-  in-  quality  requirement  in  section  251,  the  Commissions  rules  require  an  incumbent  LEC  to  design  and  operate  its  interconnection  facilities  to  meet  the 


 same  technical  criteria  and  service  standards  that  are  used  for  the  interoffice  trunks  within  the  incumbent  LECs  network.  41  In  the  Local  Competition  First  Report  and  Order,  the  Commission 
 identified  trunk  group  blockage  and  transmission  standards  as  indicators  of  an  incumbent  LECs  technical  criteria  and  service  standards.  42  In  prior  section  271  applications,  the  Commission 
 concluded  that  disparities  in  trunk  group  blockage  indicated  a  failure  to  provide  interconnection  to  competing  carriers  equal-  in-  quality  to  the  interconnection  the  BOC  provided  to  its  own  retail 
 operations.  43 
 19.  In  the  Local  Competition  First  Report  and  Order,  the  Commission  concluded  that  the  requirement  to  provide  interconnection  on  terms  and  conditions  that  are  just,  reasonable, 


 and  nondiscriminatory  means  that  an  incumbent  LEC  must  provide  interconnection  to  a  competitor  in  a  manner  no  less  efficient  than  the  way  in  which  the  incumbent  LEC  provides  the 


 37  Implementation  of  the  Local  Competition  Provisions  in  the  Telecommunications  Act  of  1996,  First  Report  and 
 Order,  11  FCC  Rcd  15499,  15590,  para.  176  (1996)  (Local  Competition  First  Report  and  Order).  Transport  and  termination  of  traffic  are  therefore  excluded  from  the  Commissions  definition  of  interconnection.  See  id. 


 38  47  U.  S.  C.    251(  c)(  2)(  B).  In  the  Local  Competition  First  Report  and  Order,  the  Commission  identified  a 
 minimum  set  of  technically  feasible  points  of  interconnection.  See  Local  Competition  First  Report  and  Order,  11  FCC  Rcd  at  15607-  09,  paras.  204-  11. 


 39  47  U.  S.  C.    251(  c)(  2)(  C). 
 40  Id.    251(  c)(  2)(  D). 
 41  Local  Competition  First  Report  and  Order,  11  FCC  Rcd  at  15613-  15,  paras.  221-  225;  see  Bell  Atlantic  New 
 York  Order,  15  FCC  Rcd  at  3978,  para.  64;  Second  BellSouth  Louisiana  Order,  13  FCC  Rcd  at  20641-  42,  paras.  63-  64. 


 42  Local  Competition  First  Report  and  Order,  11  FCC  Rcd  at  15614-  15,  paras.  224-  25. 
 43  See  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  3978,  para.  64;  Second  BellSouth  Louisiana  Order,  13  FCC 
 Rcd  at  20648-  50,  paras.  74-  77;  Ameritech  Michigan  Order,  12  FCC  Rcd  at  20671-  74,  paras.  240-  45.  The  Commission  has  relied  on  trunk  blockage  data  to  evaluate  a  BOCs  interconnection  performance.  Trunk  group 


 blockage  indicates  that  end  users  are  experiencing  difficulty  completing  or  receiving  calls,  which  may  have  a  direct  impact  on  the  customers  perception  of  a  competitive  LECs  service  quality. 
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 comparable  function  to  its  own  retail  operations.  44  The  Commissions  rules  interpret  this  obligation  to  include,  among  other  things,  the  incumbent  LECs  installation  time  for 
 interconnection  service  45  and  its  provisioning  of  two-  way  trunking  arrangements.  46  Similarly,  repair  time  for  troubles  affecting  interconnection  trunks  is  useful  for  determining  whether  a  BOC 
 provides  interconnection  service  under  terms  and  conditions  that  are  no  less  favorable  than  the  terms  and  conditions  the  BOC  provides  to  its  own  retail  operations.  47 


 20.  Competing  carriers  may  choose  any  method  of  technically  feasible  interconnection  at  a  particular  point  on  the  incumbent  LECs  network.  48  Incumbent  LEC 
 provision  of  interconnection  trunking  is  one  common  means  of  interconnection.  Technically  feasible  methods  also  include,  but  are  not  limited  to,  physical  and  virtual  collocation  and  meet 
 point  arrangements.  49  The  provision  of  collocation  is  an  essential  prerequisite  to  demonstrating  compliance  with  item  1  of  the  competitive  checklist.  50  In  the  Advanced  Services  First  Report 
 and  Order,  the  Commission  revised  its  collocation  rules  to  require  incumbent  LECs  to  include  shared  cage  and  cageless  collocation  arrangements  as  part  of  their  physical  collocation 
 offerings.  51  In  response  to  a  remand  from  the  D.  C.  Circuit,  the  Commission  adopted  the  Collocation  Remand  Order,  establishing  revised  criteria  for  equipment  for  which  incumbent 
 LECs  must  permit  collocation,  requiring  incumbent  LECs  to  provide  cross-  connects  between 


 44  Local  Competition  First  Report  and  Order,  11  FCC  Rcd  at  15612,  para.  218;  see  also  Bell  Atlantic  New  York 
 Order,  15  FCC  Rcd  at  3978,  para.  65;  Second  BellSouth  Louisiana  Order,  13  FCC  Rcd  at  20642,  para.  65. 
 45  47  C.  F.  R.    51.305(  a)(  5). 


 46  The  Commissions  rules  require  an  incumbent  LEC  to  provide  two-  way  trunking  upon  request,  wherever  two-way 
 trunking  arrangements  are  technically  feasible.  47  C.  F.  R.    51.305(  f);  see  also  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  3978-  79,  para.  65;  Second  BellSouth  Louisiana  Order,  13  FCC  Rcd  at  20642,  para.  65;  Local 


 Competition  First  Report  and  Order,  11  FCC  Rcd  15612-  13,  paras.  219-  20. 
 47  47  C.  F.  R.    51.305(  a)(  5). 


 48  Local  Competition  First  Report  and  Order,  11  FCC  Rcd  at  15779,  paras.  549-  50;  see  Bell  Atlantic  New  York 
 Order,  15  FCC  Rcd  at  3979,  para.  66;  Second  BellSouth  Louisiana  Order,  13  FCC  Rcd  at  20640-  41,  para.  61. 
 49  47  C.  F.  R.    51.321(  b);  Local  Competition  First  Report  and  Order,  11  FCC  Rcd  at  15779-  82,  paras.  549-  50;  see 
 also  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  3979,  para.  66;  Second  BellSouth  Louisiana  Order,  13  FCC  Rcd  at  20640-  41,  para.  62. 


 50  47  U.  S.  C.    251(  c)(  6)  (requiring  incumbent  LECs  to  provide  physical  collocation);  Bell  Atlantic  New  York 
 Order,  15  FCC  Rcd  at  3979,  para.  66;  Second  BellSouth  Louisiana  Order,  13  FCC  Rcd  at  20640-  41,  paras.  61-  62. 
 51  Deployment  of  Wireline  Services  offering  Advanced  Telecommunications  Capability,  First  Report  and  Order 
 and  Further  Notice  of  Proposed  Rulemaking,  14  FCC  Rcd  4761,  4784-  86,  paras.  41-  43  (1999),  affd  in  part  and  vacated  and  remanded  in  part  sub  nom.  GTE  Service  Corp.  v.  FCC,  205  F.  3d  416  (D.  C.  Cir.  2000),  on  recon., 


 Collocation  Reconsideration  Order,  15  FCC  Rcd  17806  (2000);  on  remand,  Deployment  of  Wireline  Services  Offering  Advanced  Telecommunications  Capability,  Fourth  Report  and  Order,  16  FCC  Rcd  15435  (2001) 
 (Collocation  Remand  Order),  petition  for  recon.  pending. 
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 collocated  carriers,  and  establishing  principles  for  physical  collocation  space  and  configuration.  52  To  show  compliance  with  its  collocation  obligations,  a  BOC  must  have  processes  and  procedures 
 in  place  to  ensure  that  all  applicable  collocation  arrangements  are  available  on  terms  and  conditions  that  are  just,  reasonable,  and  nondiscriminatory  in  accordance  with  section 
 251(  c)(  6)  and  the  FCCs  implementing  rules.  53  Data  showing  the  quality  of  procedures  for  processing  applications  for  collocation  space,  as  well  as  the  timeliness  and  efficiency  of 
 provisioning  collocation  space,  help  the  Commission  evaluate  a  BOCs  compliance  with  its  collocation  obligations.  54 


 21.  As  stated  above,  checklist  item  1  requires  a  BOC  to  provide  interconnection  in  accordance  with  the  requirements  of  sections  251(  c)(  2)  and  252(  d)(  1).  55  Section  252(  d)(  1) 
 requires  state  determinations  regarding  the  rates,  terms,  and  conditions  of  interconnection  to  be  based  on  cost  and  to  be  nondiscriminatory,  and  allows  the  rates  to  include  a  reasonable  profit.  56 
 The  Commissions  pricing  rules  require,  among  other  things,  that  in  order  to  comply  with  its  collocation  obligations,  an  incumbent  LEC  provide  collocation  based  on  TELRIC.  57 


 22.  To  the  extent  pricing  disputes  arise,  the  Commission  will  not  duplicate  the  work  of  the  state  commissions.  As  noted  in  the  SWBT  Texas  Order,  the  Act  authorizes  the  state 
 commissions  to  resolve  specific  carrier-  to-  carrier  disputes  arising  under  the  local  competition  provisions,  and  it  authorizes  the  federal  district  courts  to  ensure  that  the  results  of  the  state 
 arbitration  process  are  consistent  with  federal  law.  58  Although  the  Commission  has  an  independent  statutory  obligation  to  ensure  compliance  with  the  checklist,  section  271  does  not 
 compel  us  to  preempt  the  orderly  disposition  of  intercarrier  disputes  by  the  state  commissions,  particularly  now  that  the  Supreme  Court  has  restored  the  Commissions  pricing  jurisdiction  and 
 has  thereby  directed  the  state  commissions  to  follow  FCC  pricing  rules  in  their  disposition  of  those  disputes.  59 


 52  See  Collocation  Remand  Order,  16  FCC  Rcd  at  15441-  42,  para.  12. 
 53  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  3979,  para.  66;  Second  BellSouth  Louisiana  Order,  13  FCC  Rcd 
 at  20643,  para.  66;  BellSouth  Carolina  Order,  13  FCC  Rcd  at  649-  51,  para.  62. 
 54  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  3979,  para.  66;  Second  BellSouth  Louisiana  Order,  13  FCC  Rcd 
 at  20640-  41,  paras.  61-  62. 
 55  47  U.  S.  C.    271(  c)(  2)(  B)(  i)  (emphasis  added). 


 56  Id.    252(  d)(  1). 
 57  See  47  C.  F.  R.    51.501-  07,  51.509(  g);  Local  Competition  First  Report  and  Order,  11  FCC  Rcd  at  15812-  16, 
 15844-  61,  15874-  76,  15912,  paras.  618-  29,  674-  712,  743-  51,  826. 
 58  See  SWBT  Texas  Order,  15  FCC  Rcd  at  18394,  para.  88;  see  also  47  U.  S.  C.    252(  c),  (e)(  6);  American  Tel.  & 
 Tel  Co.  v.  Iowa  Utils.  Bd.,  525  U.  S.  366  (1999)  (AT&  T  v.  Iowa  Utils.  Bd.). 
 59  SWBT  Texas  Order,  15  FCC  Rcd  at  18394,  para.  88;  AT&  T  Corp.  v.  Iowa  Utils.  Bd.,  525  U.  S.  at  377-  86. 
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 23.  Consistent  with  the  Commissions  precedent,  the  mere  presence  of  interim  rates  will  not  generally  threaten  a  section  271  application  so  long  as:  (1)  an  interim  solution  to  a 
 particular  rate  dispute  is  reasonable  under  the  circumstances;  (2)  the  state  commission  has  demonstrated  its  commitment  to  the  Commissions  pricing  rules;  and  (3)  provision  is  made  for 
 refunds  or  true-  ups  once  permanent  rates  are  set.  60  In  addition,  the  Commission  has  determined  that  rates  contained  within  an  approved  section  271  application,  including  those  that  are  interim, 
 are  reasonable  starting  points  for  interim  rates  for  the  same  carrier  in  an  adjoining  state.  61 
 24.  Although  the  Commission  has  been  willing  to  grant  a  section  271  application  with  a  limited  number  of  interim  rates  where  the  above-  mentioned  three-  part  test  is  met,  it  is  clearly 


 preferable  to  analyze  a  section  271  application  on  the  basis  of  rates  derived  from  a  permanent  rate  proceeding.  62  At  some  point,  states  will  have  had  sufficient  time  to  complete  these 
 proceedings.  The  Commission  will,  therefore,  become  more  reluctant  to  continue  approving  section  271  applications  containing  interim  rates.  It  would  not  be  sound  policy  for  interim  rates 
 to  become  a  substitute  for  completing  these  significant  proceedings. 
 B.  Checklist  Item  2    Unbundled  Network  Elements  63 
 1.  Access  to  Operations  Support  Systems 
 25.  Incumbent  LECs  use  a  variety  of  systems,  databases,  and  personnel  (collectively  referred  to  as  OSS)  to  provide  service  to  their  customers.  64  The  Commission  consistently  has 


 60  SWBT  Texas  Order,  15  FCC  Rcd  at  18394,  para.  88;  see  also  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at 
 4091,  para.  258  (explaining  the  Commissions  case-  by-  case  review  of  interim  prices). 
 61  SWBT  Kansas/  Oklahoma  Order,  16  FCC  Rcd  at  6359-  60,  para.  239. 


 62  See  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  4091,  para.  260. 
 63  We  note  that  the  United  States  Court  of  Appeals  for  the  District  of  Columbia  Circuit  recently  opined  in  two 
 relevant  Commission  decisions,  Implementation  of  the  Local  Competition  Provisions  of  the  Telecommunications  Act  of  1996,  Third  Report  and  Order  and  Fourth  Further  Notice  of  Proposed  Rulemaking,  15  FCC  Rcd  3696  (1999) 


 (Local  Competition  Order)  and  Deployment  of  Wireline  Services  Offering  Advanced  Telecommunications  Capability  and  Implementation  of  the  Local  Competition  Provisions  of  the  Telecommunications  Act  of  1996,  Third 
 Report  and  Order  in  CC  Doc.  No.  98-  147  and  Fourth  Report  and  Order  in  CC  Doc.  No.  96-  98,  14  FCC  Rcd  20912  (1999)  (Line  Sharing  Order).  USTA  v.  FCC,  290  F.  3d  415  (D.  C.  Cir.  2002),  petition  for  rehearing  and  suggestion 
 for  rehearing  en  banc  denied  Sept.  4,  2002.  The  court's  decision  addressed  both  our  UNE  rules  and  our  line  sharing  rules.  The  Commission  is  currently  reviewing  its  UNE  rules,  Review  of  the  Section  251  Unbundling  Obligations  of 
 Incumbent  Local  Exchange  Carriers,  16  FCC  Rcd  22781  (2001)  (Triennial  Review  Notice).  Further,  the  court  stated  that  the  Line  Sharing  Order  must  be  vacated  and  remanded.  USTA  v.  FCC,  290  F.  3d  at  429.  The  court 
 also  stated  that  it  grant[  ed]  the  petitions  for  review[]  and  remand[  ed]  the  Line  Sharing  Order  and  the  Local  Competition  Order  to  the  Commission  for  further  consideration  in  accordance  with  the  principles  outlined.  Id.  at 
 430.  On  September  4,  2002,  the  D.  C.  Circuit  denied  petitions  for  rehearing  filed  by  the  Commission  and  others.  See  Order,  Nos.  00-  1012  and  00-  1015  (D.  C.  Circuit,  filed  Sept.  4,  2002). 


 64  Id.  at  3989-  90,  para.  83;  BellSouth  South  Carolina  Order,  13  FCC  Rcd  at  585. 
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 found  that  nondiscriminatory  access  to  OSS  is  a  prerequisite  to  the  development  of  meaningful  local  competition.  65  For  example,  new  entrants  must  have  access  to  the  functions  performed  by 
 the  incumbents  OSS  in  order  to  formulate  and  place  orders  for  network  elements  or  resale  services,  to  install  service  to  their  customers,  to  maintain  and  repair  network  facilities,  and  to  bill 
 customers.  66  The  Commission  has  determined  that  without  nondiscriminatory  access  to  the  BOCs  OSS,  a  competing  carrier  will  be  severely  disadvantaged,  if  not  precluded  altogether, 
 from  fairly  competing  in  the  local  exchange  market.  67 
 26.  Section  271  requires  the  Commission  to  determine  whether  a  BOC  offers  nondiscriminatory  access  to  OSS  functions.  Section  271(  c)(  2)(  B)(  ii)  requires  a  BOC  to  provide 


 nondiscriminatory  access  to  network  elements  in  accordance  with  the  requirements  of  sections  251(  c)(  3)  and  252(  d)(  1).  68  The  Commission  has  determined  that  access  to  OSS  functions  falls 
 squarely  within  an  incumbent  LECs  duty  under  section  251(  c)(  3)  to  provide  unbundled  network  elements  (UNEs)  under  terms  and  conditions  that  are  nondiscriminatory  and  just  and  reasonable, 
 and  its  duty  under  section  251(  c)(  4)  to  offer  resale  services  without  imposing  any  limitations  or  conditions  that  are  discriminatory  or  unreasonable.  69  The  Commission  must  therefore  examine  a 
 BOCs  OSS  performance  to  evaluate  compliance  with  section  271(  c)(  2)(  B)(  ii)  and  (xiv).  70  In  addition,  the  Commission  has  also  concluded  that  the  duty  to  provide  nondiscriminatory  access 
 to  OSS  functions  is  embodied  in  other  terms  of  the  competitive  checklist  as  well.  71  Consistent  with  prior  orders,  the  Commission  examines  a  BOCs  OSS  performance  directly  under  checklist 
 items  2  and  14,  as  well  as  other  checklist  terms.  72 
 27.  As  part  of  its  statutory  obligation  to  provide  nondiscriminatory  access  to  OSS  functions,  a  BOC  must  provide  access  that  sufficiently  supports  each  of  the  three  modes  of 


 competitive  entry  envisioned  by  the  1996  Act    competitor-  owned  facilities,  UNEs,  and  resale.  73 
 65  See  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  3990,  para.  83;  BellSouth  South  Carolina  Order,  13  FCC 
 Rcd  at  547-  48,  585;  Second  BellSouth  Louisiana  Order,  13  FCC  Rcd  at  20653. 
 66  See  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  3990,  para.  83. 


 67  Id. 
 68  47  U.  S.  C.    271(  c)(  2)(  B)(  ii). 
 69  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  3990,  para.  84. 
 70  Id. 
 71  Id.  As  part  of  a  BOCs  demonstration  that  it  is  providing  a  checklist  item  (e.  g.,  unbundled  loops,  unbundled 
 local  switching,  resale  services),  it  must  demonstrate  that  it  is  providing  nondiscriminatory  access  to  the  systems,  information,  and  personnel  that  support  that  element  or  service.  An  examination  of  a  BOCs  OSS  performance  is 


 therefore  integral  to  the  determination  of  whether  a  BOC  is  offering  all  of  the  items  contained  in  the  competitive  checklist.  Id. 


 72  Id.  at  3990-  91,  para.  84. 
 73  Id.  at  3991,  para.  85. 
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 For  OSS  functions  that  are  analogous  to  those  that  a  BOC  provides  to  itself,  its  customers  or  its  affiliates,  the  nondiscrimination  standard  requires  the  BOC  to  offer  requesting  carriers  access 
 that  is  equivalent  in  terms  of  quality,  accuracy,  and  timeliness.  74  The  BOC  must  provide  access  that  permits  competing  carriers  to  perform  these  functions  in  substantially  the  same  time  and 
 manner  as  the  BOC.  75  The  Commission  has  recognized  in  prior  orders  that  there  may  be  situations  in  which  a  BOC  contends  that,  although  equivalent  access  has  not  been  achieved  for 
 an  analogous  function,  the  access  that  it  provides  is  nonetheless  nondiscriminatory  within  the  meaning  of  the  statute.  76 


 28.  For  OSS  functions  that  have  no  retail  analogue,  the  BOC  must  offer  access  sufficient  to  allow  an  efficient  competitor  a  meaningful  opportunity  to  compete.  77  In  assessing 
 whether  the  quality  of  access  affords  an  efficient  competitor  a  meaningful  opportunity  to  compete,  the  Commission  will  examine,  in  the  first  instance,  whether  specific  performance 
 standards  exist  for  those  functions.  78  In  particular,  the  Commission  will  consider  whether  appropriate  standards  for  measuring  OSS  performance  have  been  adopted  by  the  relevant  state 
 commission  or  agreed  upon  by  the  BOC  in  an  interconnection  agreement  or  during  the  implementation  of  such  an  agreement.  79  If  such  performance  standards  exist,  the  Commission 
 will  evaluate  whether  the  BOCs  performance  is  sufficient  to  allow  an  efficient  competitor  a  meaningful  opportunity  to  compete.  80 


 29.  The  Commission  analyzes  whether  a  BOC  has  met  the  nondiscrimination  standard  for  each  OSS  function  using  a  two-  step  approach.  First,  the  Commission  determines 
 whether  the  BOC  has  deployed  the  necessary  systems  and  personnel  to  provide  sufficient  access  to  each  of  the  necessary  OSS  functions  and  whether  the  BOC  is  adequately  assisting 
 competing  carriers  to  understand  how  to  implement  and  use  all  of  the  OSS  functions  available  to 


 74  Id. 
 75  Id.  For  example,  the  Commission  would  not  deem  an  incumbent  LEC  to  be  providing  nondiscriminatory  access 
 to  OSS  if  limitations  on  the  processing  of  information  between  the  interface  and  the  back  office  systems  prevented  a  competitor  from  performing  a  specific  function  in  substantially  the  same  time  and  manner  as  the  incumbent 


 performs  that  function  for  itself. 
 76  See  id. 


 77  Id.  at  3991,  para.  86. 
 78  Id. 
 79  Id.  As  a  general  proposition,  specific  performance  standards  adopted  by  a  state  commission  in  an  arbitration 
 decision  would  be  more  persuasive  evidence  of  commercial  reasonableness  than  a  standard  unilaterally  adopted  by  the  BOC  outside  of  its  interconnection  agreement.  Id.  at  20619-  20. 


 80  See  id.  at  3991-  92,  para.  86. 
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 them.  81  The  Commission  next  assesses  whether  the  OSS  functions  that  the  BOC  has  deployed  are  operationally  ready,  as  a  practical  matter.  82 
 30.  Under  the  first  inquiry,  a  BOC  must  demonstrate  that  it  has  developed  sufficient  electronic  (for  functions  that  the  BOC  accesses  electronically)  and  manual  interfaces  to  allow 
 competing  carriers  equivalent  access  to  all  of  the  necessary  OSS  functions.  83  For  example,  a  BOC  must  provide  competing  carriers  with  the  specifications  necessary  for  carriers  to  design  or 
 modify  their  systems  in  a  manner  that  will  enable  them  to  communicate  with  the  BOCs  systems  and  any  relevant  interfaces.  84  In  addition,  a  BOC  must  disclose  to  competing  carriers  any 
 internal  business  rules  85  and  other  formatting  information  necessary  to  ensure  that  a  carriers  requests  and  orders  are  processed  efficiently.  86  Finally,  a  BOC  must  demonstrate  that  its  OSS  is 
 designed  to  accommodate  both  current  demand  and  projected  demand  for  competing  carriers  access  to  OSS  functions.  87  Although  not  a  prerequisite,  the  Commission  continues  to  encourage 
 the  use  of  industry  standards  as  an  appropriate  means  of  meeting  the  needs  of  a  competitive  local  exchange  market.  88 


 31.  Under  the  second  inquiry,  the  Commission  examines  performance  measurements  and  other  evidence  of  commercial  readiness  to  ascertain  whether  the  BOCs  OSS  is  handling 


 81  Id.  at  3992,  para.  87;  Ameritech  Michigan  Order,  12  FCC  Rcd  at  20616;  see  also  Second  BellSouth  Louisiana 
 Order,  13  FCC  Rcd  at  20654;  BellSouth  South  Carolina  Order,  13  FCC  Rcd  at  592-  93.  In  making  this  determination,  the  Commission  consider[  s]  all  of  the  automated  and  manual  processes  a  BOC  has  undertaken  to 


 provide  access  to  OSS  functions,  including  the  interface  (or  gateway)  that  connects  the  competing  carriers  own  operations  support  systems  to  the  BOC;  any  electronic  or  manual  processing  link  between  that  interface  and  the 
 BOCs  OSS  (including  all  necessary  back  office  systems  and  personnel);  and  all  of  the  OSS  that  a  BOC  uses  in  providing  network  elements  and  resale  services  to  a  competing  carrier.  Ameritech  Michigan  Order,  12  FCC  Rcd  at 
 20615;  see  also  Second  BellSouth  Louisiana  Order,  13  FCC  Rcd  at  20654  n.  241. 
 82  See  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  3992,  para.  88. 


 83  Id.  at  3992,  para.  87;  see  also  Ameritech  Michigan  Order,  12  FCC  Rcd  at  20616,  para.  136  (The  Commission 
 determines  whether  the  BOC  has  deployed  the  necessary  systems  and  personnel  to  provide  sufficient  access  to  each  of  the  necessary  OSS  functions  and  whether  the  BOC  is  adequately  assisting  competing  carriers  to  understand 


 how  to  implement  and  use  all  of  the  OSS  functions  available  to  them.).  For  example,  a  BOC  must  provide  competing  carriers  the  specifications  necessary  to  design  their  systems  interfaces  and  business  rules  necessary  to 
 format  orders,  and  demonstrate  that  systems  are  scalable  to  handle  current  and  projected  demand.  Id. 
 84  Id. 


 85  Business  rules  refer  to  the  protocols  that  a  BOC  uses  to  ensure  uniformity  in  the  format  of  orders  and  include 
 information  concerning  ordering  codes  such  as  universal  service  ordering  codes  (USOCs)  and  field  identifiers  (FIDs).  Id.;  see  also  Ameritech  Michigan  Order,  12  FCC  Rcd  at  20617  n.  335. 


 86  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  3992,  para.  88. 
 87  Id. 
 88  See  id. 
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 current  demand  and  will  be  able  to  handle  reasonably  foreseeable  future  volumes.  89  The  most  probative  evidence  that  OSS  functions  are  operationally  ready  is  actual  commercial  usage.  90 
 Absent  sufficient  and  reliable  data  on  commercial  usage,  the  Commission  will  consider  the  results  of  carrier-  to-  carrier  testing,  independent  third-  party  testing,  and  internal  testing  in 
 assessing  the  commercial  readiness  of  a  BOCs  OSS.  91  Although  the  Commission  does  not  require  OSS  testing,  a  persuasive  test  will  provide  us  with  an  objective  means  by  which  to 
 evaluate  a  BOCs  OSS  readiness  where  there  is  little  to  no  evidence  of  commercial  usage,  or  may  otherwise  strengthen  an  application  where  the  BOCs  evidence  of  actual  commercial  usage 
 is  weak  or  is  otherwise  challenged  by  competitors.  The  persuasiveness  of  a  third-  party  review,  however,  is  dependent  upon  the  qualifications,  experience  and  independence  of  the  third  party 
 and  the  conditions  and  scope  of  the  review  itself.  92  If  the  review  is  limited  in  scope  or  depth  or  is  not  independent  and  blind,  the  Commission  will  give  it  minimal  weight.  As  noted  above,  to  the 
 extent  the  Commission  reviews  performance  data,  it  looks  at  the  totality  of  the  circumstances  and  generally  does  not  view  individual  performance  disparities,  particularly  if  they  are  isolated  and 
 slight,  as  dispositive  of  whether  a  BOC  has  satisfied  its  checklist  obligations.  93  Individual  performance  disparities  may,  nevertheless,  result  in  a  finding  of  checklist  noncompliance, 
 particularly  if  the  disparity  is  substantial  or  has  endured  for  a  long  time,  or  if  it  is  accompanied  by  other  evidence  of  discriminatory  conduct  or  evidence  that  competing  carriers  have  been 
 denied  a  meaningful  opportunity  to  compete. 
 a.  Relevance  of  a  BOCs  Prior  Section  271  Orders 
 32.  The  SWBT  Kansas/  Oklahoma  Order  specifically  outlined  a  non-  exhaustive  evidentiary  showing  that  must  be  made  in  the  initial  application  when  a  BOC  seeks  to  rely  on 


 evidence  presented  in  another  application.  94  First,  a  BOCs  application  must  explain  the  extent  to  which  the  OSS  are  the  same    that  is,  whether  it  employs  the  shared  use  of  a  single  OSS,  or 
 the  use  of  systems  that  are  identical,  but  separate.  95  To  satisfy  this  inquiry,  the  Commission  looks  to  whether  the  relevant  states  utilize  a  common  set  of  processes,  business  rules,  interfaces, 


 89  Id.  at  3993,  para.  89. 
 90  Id. 
 91  Id. 
 92  See  id.;  Ameritech  Michigan  Order,  12  FCC  Rcd  at  20659  (emphasizing  that  a  third-  party  review  should 
 encompass  the  entire  obligation  of  the  incumbent  LEC  to  provide  nondiscriminatory  access,  and,  where  applicable,  should  consider  the  ability  of  actual  competing  carriers  in  the  market  to  operate  using  the  incumbents  OSS  access). 


 93  See  SWBT  Kansas/  Oklahoma  Order,  16  FCC  Rcd  at  6301-  02,  para.  138. 
 94  See  id.  at  6286-  91,  paras.  107-  18. 
 95  See  id.  at  6288,  para.  111. 
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 systems  and,  in  many  instances,  even  personnel.  96  The  Commission  will  also  carefully  examine  third  party  reports  that  demonstrate  that  the  BOCs  OSS  are  the  same  in  each  of  the  relevant 
 states.  97  Finally,  where  a  BOC  has  discernibly  separate  OSS,  it  must  demonstrate  that  its  OSS  reasonably  can  be  expected  to  behave  in  the  same  manner.  98  Second,  unless  an  applicant  seeks  to 
 establish  only  that  certain  discrete  components  of  its  OSS  are  the  same,  an  applicant  must  submit  evidence  relating  to  all  aspects  of  its  OSS,  including  those  OSS  functions  performed  by  BOC 
 personnel. 
 b.  Pre-  Ordering 
 33.  A  BOC  must  demonstrate  that:  (i)  it  offers  nondiscriminatory  access  to  OSS  pre-ordering  functions  associated  with  determining  whether  a  loop  is  capable  of  supporting  xDSL 


 advanced  technologies;  (ii)  competing  carriers  successfully  have  built  and  are  using  application-to-  application  interfaces  to  perform  pre-  ordering  functions  and  are  able  to  integrate  pre-  ordering 
 and  ordering  interfaces;  99  and  (iii)  its  pre-  ordering  systems  provide  reasonably  prompt  response  times  and  are  consistently  available  in  a  manner  that  affords  competitors  a  meaningful 
 opportunity  to  compete.  100 
 34.  The  pre-  ordering  phase  of  OSS  generally  includes  those  activities  that  a  carrier  undertakes  to  gather  and  verify  the  information  necessary  to  place  an  order.  101  Given  that  pre-ordering 


 represents  the  first  exposure  that  a  prospective  customer  has  to  a  competing  carrier,  it  is 
 96  The  Commission  has  consistently  held  that  a  BOCs  OSS  includes  both  mechanized  systems  and  manual 
 processes,  and  thus  the  OSS  functions  performed  by  BOC  personnel  have  been  part  of  the  FCCs  OSS  functionality  and  commercial  readiness  reviews. 


 97  See  SWBT  Kansas/  Oklahoma  Order,  id.  at  6287,  para.  108. 
 98  See  id.  at  6288,  para.  111. 
 99  In  prior  orders,  the  Commission  has  emphasized  that  providing  pre-  ordering  functionality  through  an 
 application-  to-  application  interface  is  essential  in  enabling  carriers  to  conduct  real-  time  processing  and  to  integrate  pre-  ordering  and  ordering  functions  in  the  same  manner  as  the  BOC.  SWBT  Texas  Order,  15  FCC  Rcd  at  18426, 


 para.  148. 
 100  The  Commission  has  held  previously  that  an  interface  that  provides  responses  in  a  prompt  timeframe  and  is 
 stable  and  reliable,  is  necessary  for  competing  carriers  to  market  their  services  and  serve  their  customers  as  efficiently  and  at  the  same  level  of  quality  as  a  BOC  serves  its  own  customers.  See  Bell  Atlantic  New  York  Order, 


 15  FCC  Rcd  at  4025  and  4029,  paras.  145  and  154. 
 101  See  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  4014,  para.  129;  see  also  Second  BellSouth  Louisiana  Order, 
 13  FCC  Rcd  at  20660,  para.  94  (referring  to  pre-  ordering  and  ordering  collectively  as  the  exchange  of  information  between  telecommunications  carriers  about  current  or  proposed  customer  products  and  services  or 


 unbundled  network  elements  or  some  combination  thereof).  In  prior  orders,  the  Commission  has  identified  the  following  five  pre-  order  functions:  (1)  customer  service  record  (CSR)  information;  (2)  address  validation; 
 (3)  telephone  number  information;  (4)  due  date  information;  (5)  services  and  feature  information.  See  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  4015,  para.  132;  Second  BellSouth  Louisiana  Order,  13  FCC  Rcd  at  20660,  para. 
 94;  BellSouth  South  Carolina  Order,  13  FCC  Rcd  at  619,  para.  147. 
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 critical  that  a  competing  carrier  is  able  to  accomplish  pre-  ordering  activities  in  a  manner  no  less  efficient  and  responsive  than  the  incumbent.  102  Most  of  the  pre-  ordering  activities  that  must  be 
 undertaken  by  a  competing  carrier  to  order  resale  services  and  UNEs  from  the  incumbent  are  analogous  to  the  activities  a  BOC  must  accomplish  to  furnish  service  to  its  own  customers.  For 
 these  pre-  ordering  functions,  a  BOC  must  demonstrate  that  it  provides  requesting  carriers  access  that  enables  them  to  perform  pre-  ordering  functions  in  substantially  the  same  time  and  manner  as 
 its  retail  operations.  103  For  those  pre-  ordering  functions  that  lack  a  retail  analogue,  a  BOC  must  provide  access  that  affords  an  efficient  competitor  a  meaningful  opportunity  to  compete.  104  In 
 prior  orders,  the  Commission  has  emphasized  that  providing  pre-  ordering  functionality  through  an  application-  to-  application  interface  is  essential  in  enabling  carriers  to  conduct  real-  time 
 processing  and  to  integrate  pre-  ordering  and  ordering  functions  in  the  same  manner  as  the  BOC.  105 


 (i)  Access  to  Loop  Qualification  Information 
 35.  In  accordance  with  the  UNE  Remand  Order,  106  the  Commission  requires  incumbent  carriers  to  provide  competitors  with  access  to  all  of  the  same  detailed  information 


 about  the  loop  that  is  available  to  the  incumbents,  107  and  in  the  same  time  frame,  so  that  a  competing  carrier  can  make  an  independent  judgment  at  the  pre-  ordering  stage  about  whether  an 
 end  user  loop  is  capable  of  supporting  the  advanced  services  equipment  the  competing  carrier  intends  to  install.  108  Under  the  UNE  Remand  Order,  the  relevant  inquiry  is  not  whether  a  BOCs 
 retail  arm  accesses  such  underlying  information  but  whether  such  information  exists  anywhere  in 


 102  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  4014,  para.  129. 
 103  Id.;  see  also  BellSouth  South  Carolina  Order,  13  FCC  Rcd  at  623-  29  (concluding  that  failure  to  deploy  an 
 application-  to-  application  interface  denies  competing  carriers  equivalent  access  to  pre-  ordering  OSS  functions). 
 104  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  4014,  para.  129. 


 105  See  id.  at  4014,  para.  130;  Second  BellSouth  Louisiana  Order,  13  FCC  Rcd  at  20661-  67,  para.  105. 
 106  UNE  Remand  Order,  15  FCC  Rcd  at  3885,  para.  426  (determining  that  the  pre-  ordering  function  includes 
 access  to  loop  qualification  information). 
 107  See  id.  At  a  minimum,  a  BOC  must  provide  (1)  the  composition  of  the  loop  material,  including  both  fiber  and 
 copper;  (2)  the  existence,  location  and  type  of  any  electronic  or  other  equipment  on  the  loop,  including  but  not  limited  to,  digital  loop  carrier  or  other  remote  concentration  devices,  feeder/  distribution  interfaces,  bridge  taps,  load 


 coils,  pair-  gain  devices,  disturbers  in  the  same  or  adjacent  binder  groups;  (3)  the  loop  length,  including  the  length  and  location  of  each  type  of  transmission  media;  (4)  the  wire  gauge(  s)  of  the  loop;  and  (5)  the  electrical  parameters 
 of  the  loop,  which  may  determine  the  suitability  of  the  loop  for  various  technologies.  Id. 
 108  As  the  Commission  has  explained  in  prior  proceedings,  because  characteristics  of  a  loop,  such  as  its  length  and 
 the  presence  of  various  impediments  to  digital  transmission,  can  hinder  certain  advanced  services  technologies,  carriers  often  seek  to  pre-  qualify  a  loop  by  accessing  basic  loop  makeup  information  that  will  assist  carriers  in 


 ascertaining  whether  the  loop,  either  with  or  without  the  removal  of  the  impediments,  can  support  a  particular  advanced  service.  See  id.,  15  FCC  Rcd  at  4021,  para.  140. 
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 a  BOCs  back  office  and  can  be  accessed  by  any  of  a  BOCs  personnel.  109  Moreover,  a  BOC  may  not  filter  or  digest  the  underlying  information  and  may  not  provide  only  information  that 
 is  useful  in  provisioning  of  a  particular  type  of  xDSL  that  a  BOC  offers.  110  A  BOC  must  also  provide  loop  qualification  information  based,  for  example,  on  an  individual  address  or  zip  code 
 of  the  end  users  in  a  particular  wire  center,  NXX  code  or  on  any  other  basis  that  the  BOC  provides  such  information  to  itself.  Moreover,  a  BOC  must  also  provide  access  for  competing 
 carriers  to  the  loop  qualifying  information  that  the  BOC  can  itself  access  manually  or  electronically.  Finally,  a  BOC  must  provide  access  to  loop  qualification  information  to 
 competitors  within  the  same  time  intervals  it  is  provided  to  the  BOCs  retail  operations  or  its  advanced  services  affiliate.  111  As  the  Commission  determined  in  the  UNE  Remand  Order, 
 however,  to  the  extent  such  information  is  not  normally  provided  to  the  incumbents  retail  personnel,  but  can  be  obtained  by  contacting  back  office  personnel,  it  must  be  provided  to 
 requesting  carriers  within  the  same  time  frame  that  any  incumbent  personnel  are  able  to  obtain  such  information.  112 


 c.  Ordering 
 36.  Consistent  with  section  271(  c)(  2)(  B)(  ii),  a  BOC  must  demonstrate  its  ability  to  provide  competing  carriers  with  access  to  the  OSS  functions  necessary  for  placing  wholesale 


 orders.  For  those  functions  of  the  ordering  systems  for  which  there  is  a  retail  analogue,  a  BOC  must  demonstrate,  with  performance  data  and  other  evidence,  that  it  provides  competing  carriers 
 with  access  to  its  OSS  in  substantially  the  same  time  and  manner  as  it  provides  to  its  retail  operations.  For  those  ordering  functions  that  lack  a  direct  retail  analogue,  a  BOC  must 
 demonstrate  that  its  systems  and  performance  allow  an  efficient  carrier  a  meaningful  opportunity  to  compete.  As  in  prior  section  271  orders,  the  Commission  looks  primarily  at  the  applicants 
 ability  to  return  order  confirmation  notices,  order  reject  notices,  order  completion  notices  and  jeopardies,  and  at  its  order  flow-  through  rate.  113 


 109  UNE  Remand  Order,  15  FCC  Rcd  at  3885-  3887,  paras.  427-  431  (noting  that  to  the  extent  such  information  is 
 not  normally  provided  to  the  incumbents  retail  personnel,  but  can  be  obtained  by  contacting  back  office  personnel,  it  must  be  provided  to  requesting  carriers  within  the  same  time  frame  that  any  incumbent  personnel  are  able  to 


 obtain  such  information.). 
 110  See  SWBT  Kansas  Oklahoma  Order,  16  FCC  Rcd  at  6292-  93,  para.  121. 


 111  Id. 
 112  UNE  Remand  Order,  15  FCC  Rcd  at  3885-  3887,  paras.  427-  31. 
 113  See  SWBT  Texas  Order,  15  FCC  Rcd  at  18438,  para.  170;  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  4035- 
 39,  paras.  163-  66.  The  Commission  examines  (i)  order  flow-  through  rates,  (ii)  jeopardy  notices  and  (iii)  order  completion  notices  using  the  same  time  and  manner  standard.  The  Commission  examines  order  confirmation 


 notices  and  order  rejection  notices  using  the  meaningful  opportunity  to  compete  standard. 
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 d.  Provisioning 
 37.  A  BOC  must  provision  competing  carriers  orders  for  resale  and  UNE-  P  services  in  substantially  the  same  time  and  manner  as  it  provisions  orders  for  its  own  retail  customers.  114 


 Consistent  with  the  approach  in  prior  section  271  orders,  the  Commission  examines  a  BOCs  provisioning  processes,  as  well  as  its  performance  with  respect  to  provisioning  timeliness  (i.  e., 
 missed  due  dates  and  average  installation  intervals)  and  provisioning  quality  (i.  e.,  service  problems  experienced  at  the  provisioning  stage).  115 


 e.  Maintenance  and  Repair 
 38.  A  competing  carrier  that  provides  service  through  resale  or  UNEs  remains  dependent  upon  the  incumbent  LEC  for  maintenance  and  repair.  Thus,  as  part  of  its  obligation  to 


 provide  nondiscriminatory  access  to  OSS  functions,  a  BOC  must  provide  requesting  carriers  with  nondiscriminatory  access  to  its  maintenance  and  repair  systems.  116  To  the  extent  a  BOC 
 performs  analogous  maintenance  and  repair  functions  for  its  retail  operations,  it  must  provide  competing  carriers  access  that  enables  them  to  perform  maintenance  and  repair  functions  in 
 substantially  the  same  time  and  manner  as  a  BOC  provides  its  retail  customers.  117  Equivalent  access  ensures  that  competing  carriers  can  assist  customers  experiencing  service  disruptions 
 using  the  same  network  information  and  diagnostic  tools  that  are  available  to  BOC  personnel.  118  Without  equivalent  access,  a  competing  carrier  would  be  placed  at  a  significant  competitive 
 disadvantage,  as  its  customer  would  perceive  a  problem  with  a  BOCs  network  as  a  problem  with  the  competing  carriers  own  network.  119 


 f.  Billing 
 39.  A  BOC  must  provide  nondiscriminatory  access  to  its  billing  functions,  which  is  necessary  to  enable  competing  carriers  to  provide  accurate  and  timely  bills  to  their  customers.  120 


 In  making  this  determination,  the  Commission  assesses  a  BOCs  billing  processes  and  systems, 
 114  See  Bell  Atlantic  New  York,  15  FCC  Rcd  at  4058,  para.  196.  For  provisioning  timeliness,  the  Commission 
 looks  to  missed  due  dates  and  average  installation  intervals;  for  provisioning  quality,  the  Commission  looks  to  service  problems  experienced  at  the  provisioning  stage. 


 115  Id. 
 116  Id.  at  4067,  para.  212;  Second  BellSouth  Louisiana  Order,  13  FCC  Rcd  at  20692;  Ameritech  Michigan  Order, 
 12  FCC  Rcd  at  20613,  20660-  61. 
 117  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  4058,  para.  196;  see  also  Second  BellSouth  Louisiana  Order,  13 
 FCC  Rcd  at  20692-  93. 
 118  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  4058,  para.  196. 


 119  Id. 
 120  See  SWBT  Texas  Order,  15  FCC  Rcd  at  18461,  para.  210. 
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 and  its  performance  data.  Consistent  with  prior  section  271  orders,  a  BOC  must  demonstrate  that  it  provides  competing  carriers  with  complete  and  accurate  reports  on  the  service  usage  of 
 competing  carriers  customers  in  substantially  the  same  time  and  manner  that  a  BOC  provides  such  information  to  itself,  and  with  wholesale  bills  in  a  manner  that  gives  competing  carriers  a 
 meaningful  opportunity  to  compete.  121 
 g.  Change  Management  Process 
 40.  Competing  carriers  need  information  about,  and  specifications  for,  an  incumbents  systems  and  interfaces  to  develop  and  modify  their  systems  and  procedures  to 


 access  the  incumbents  OSS  functions.  122  Thus,  in  order  to  demonstrate  that  it  is  providing  nondiscriminatory  access  to  its  OSS,  a  BOC  must  first  demonstrate  that  it  has  deployed  the 
 necessary  systems  and  personnel  to  provide  sufficient  access  to  each  of  the  necessary  OSS  functions  and  .  .  .  is  adequately  assisting  competing  carriers  to  understand  how  to  implement  and 
 use  all  of  the  OSS  functions  available  to  them.  123  By  showing  that  it  adequately  assists  competing  carriers  to  use  available  OSS  functions,  a  BOC  provides  evidence  that  it  offers  an 
 efficient  competitor  a  meaningful  opportunity  to  compete.  124  As  part  of  this  demonstration,  the  Commission  will  give  substantial  consideration  to  the  existence  of  an  adequate  change 
 management  process  and  evidence  that  the  BOC  has  adhered  to  this  process  over  time.  125 
 41.  The  change  management  process  refers  to  the  methods  and  procedures  that  the  BOC  employs  to  communicate  with  competing  carriers  regarding  the  performance  of,  and 


 changes  in,  the  BOCs  OSS.  126  Such  changes  may  include  updates  to  existing  functions  that  impact  competing  carrier  interface(  s)  upon  a  BOCs  release  of  new  interface  software; 
 technology  changes  that  require  competing  carriers  to  meet  new  technical  requirements  upon  a  BOCs  software  release  date;  additional  functionality  changes  that  may  be  used  at  the  competing 
 carriers  option,  on  or  after  a  BOCs  release  date  for  new  interface  software;  and  changes  that  may  be  mandated  by  regulatory  authorities.  127  Without  a  change  management  process  in  place,  a 
 BOC  can  impose  substantial  costs  on  competing  carriers  simply  by  making  changes  to  its  systems  and  interfaces  without  providing  adequate  testing  opportunities  and  accurate  and  timely 


 121  See  id.;  SWBT  Kansas/  Oklahoma  Order,  16  FCC  Rcd  at  6316-  17,  at  para.  163. 
 122  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  3999-  4000,  para.  102;  First  BellSouth  Louisiana  Order,  13  FCC 
 Rcd  at  6279  n.  197;  BellSouth  South  Carolina  Order,  13  FCC  Rcd  at  625  n.  467;  Ameritech  Michigan  Order,  12  FCC  Rcd  at  20617  n.  334;  Local  Competition  Second  Report  and  Order,  11  FCC  Rcd  at  19742. 


 123  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  3999,  para.  102. 
 124  Id.  at  3999-  4000,  para.  102 
 125  Id.  at  4000,  para.  102. 
 126  Id.  at  4000,  para.  103. 
 127  Id. 
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 notice  and  documentation  of  the  changes.  128  Change  management  problems  can  impair  a  competing  carriers  ability  to  obtain  nondiscriminatory  access  to  UNEs,  and  hence  a  BOCs 
 compliance  with  section  271(  2)(  B)(  ii).  129 
 42.  In  evaluating  whether  a  BOCs  change  management  plan  affords  an  efficient  competitor  a  meaningful  opportunity  to  compete,  the  Commission  first  assesses  whether  the  plan 


 is  adequate.  In  making  this  determination,  it  assesses  whether  the  evidence  demonstrates:  (1)  that  information  relating  to  the  change  management  process  is  clearly  organized  and  readily 
 accessible  to  competing  carriers;  130  (2)  that  competing  carriers  had  substantial  input  in  the  design  and  continued  operation  of  the  change  management  process;  131  (3)  that  the  change  management 
 plan  defines  a  procedure  for  the  timely  resolution  of  change  management  disputes;  132  (4)  the  availability  of  a  stable  testing  environment  that  mirrors  production;  133  and  (5)  the  efficacy  of  the 
 documentation  the  BOC  makes  available  for  the  purpose  of  building  an  electronic  gateway.  134  After  determining  whether  the  BOCs  change  management  plan  is  adequate,  the  Commission 
 evaluates  whether  the  BOC  has  demonstrated  a  pattern  of  compliance  with  this  plan.  135 
 2.  UNE  Combinations 
 43.  In  order  to  comply  with  the  requirements  of  checklist  item  2,  a  BOC  must  show  that  it  is  offering  [  n]  ondiscriminatory  access  to  network  elements  in  accordance  with  the 


 requirements  of  section  251(  c)(  3).  136  Section  251(  c)(  3)  requires  an  incumbent  LEC  to  provide,  to  any  requesting  telecommunications  carrier  .  .  .  nondiscriminatory  access  to  network  elements 
 on  an  unbundled  basis  at  any  technically  feasible  point  on  rates,  terms  and  conditions  that  are  just,  reasonable,  and  nondiscriminatory.  137  Section  251(  c)(  3)  of  the  Act  also  requires  incumbent 


 128  Id.  at  4000,  para.  103. 
 129  Id. 
 130  Id.  at  4002,  para.  107. 
 131  Id.  at  4000,  para.  104. 
 132  Id.  at  4002,  para.  108. 
 133  Id.  at  4002-  03,  paras.  109-  10. 
 134  Id.  at  4003-  04,  para.  110.  In  the  Bell  Atlantic  New  York  Order,  the  Commission  used  these  factors  in 
 determining  whether  Bell  Atlantic  had  an  adequate  change  management  process  in  place.  See  id.  at  4004,  para.  111.  The  Commission  left  open  the  possibility,  however,  that  a  change  management  plan  different  from  the  one 


 implemented  by  Bell  Atlantic  may  be  sufficient  to  demonstrate  compliance  with  the  requirements  of  section  271.  Id. 


 135  Id.  at  3999,  para.  101,  4004-  05,  para.  112. 
 136  47  U.  S.  C.    271(  c)(  2)(  B)(  ii). 
 137  Id.    251(  c)(  3). 
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 LECs  to  provide  UNEs  in  a  manner  that  allows  requesting  carriers  to  combine  such  elements  in  order  to  provide  a  telecommunications  service.  138 
 44.  In  the  Ameritech  Michigan  Order,  the  Commission  emphasized  that  the  ability  of  requesting  carriers  to  use  UNEs,  as  well  as  combinations  of  UNEs,  is  integral  to  achieving 
 Congress  objective  of  promoting  competition  in  local  telecommunications  markets.  139  Using  combinations  of  UNEs  provides  a  competitor  with  the  incentive  and  ability  to  package  and 
 market  services  in  ways  that  differ  from  the  BOCs  existing  service  offerings  in  order  to  compete  in  the  local  telecommunications  market.  140  Moreover,  combining  the  incumbents  UNEs  with 
 their  own  facilities  encourages  facilities-  based  competition  and  allows  competing  providers  to  provide  a  wide  array  of  competitive  choices.  141  Because  the  use  of  combinations  of  UNEs  is  an 
 important  strategy  for  entry  into  the  local  telecommunications  market,  as  well  as  an  obligation  under  the  requirements  of  section  271,  the  Commission  examines  section  271  applications  to 
 determine  whether  competitive  carriers  are  able  to  combine  network  elements  as  required  by  the  Act  and  the  Commissions  regulations.  142 


 3.  Pricing  of  Network  Elements 
 45.  Checklist  item  2  of  section  271  states  that  a  BOC  must  provide  nondiscriminatory  access  to  network  elements  in  accordance  with  sections  251(  c)(  3)  and 


 252(  d)(  1)  of  the  Act.  143  Section  251(  c)(  3)  requires  incumbent  LECs  to  provide  nondiscriminatory  access  to  network  elements  on  an  unbundled  basis  at  any  technically  feasible 
 point  on  rates,  terms,  and  conditions  that  are  just,  reasonable,  and  nondiscriminatory.  144  Section  252(  d)(  1)  requires  that  a  state  commissions  determination  of  the  just  and  reasonable  rates  for 
 network  elements  shall  be  based  on  the  cost  of  providing  the  network  elements,  shall  be 


 138  Id. 
 139  Ameritech  Michigan  Order,  12  FCC  Rcd  at  20718-  19;  BellSouth  South  Carolina  Order,  13  FCC  Rcd  at  646. 
 140  BellSouth  South  Carolina  Order,  13  FCC  Rcd  at  646;  see  also  Local  Competition  First  Report  and  Order,  11 
 FCC  Rcd  at  15666-  68. 
 141  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  4077-  78,  para.  230. 


 142  Id.  In  Iowa  Utilities  Board  v.  FCC,  219  F.  3d  744  (8th  Cir.  2000),  the  Eighth  Circuit  had  vacated  the 
 Commissions  additional  combinations  rules  (47  C.  F.  R.  Sections  51-  315(  c)-(  f)).  However,  on  May  13,  2002,  the  Supreme  Court  reversed  the  Eighth  Circuit  with  respect  to  those  rules  and  remanded  the  case  to  the  court  of  appeals 


 for  further  proceedings  consistent  with  this  opinion.  Verizon  Communications  Inc.  v.  FCC,  122  S.  Ct.  1646,  1687.  See  also  id.  at  1683-  87.  In  response,  the  Eighth  Circuit,  on  August  21,  2002,  vacated  its  prior  opinion  insofar  as  it 
 had  vacated  the  pertinent  combinations  rules  and  denied  the  petitions  for  review  with  respect  to  those  rules.  Iowa  Utilities  Board  v.  FCC,  8th  Circuit  Nos.  96-  3321,  et  al.,  Judgment,  filed  August  21,  2002.). 


 143  47  U.  S.  C.    271(  c)(  2)(  B)(  ii). 
 144  Id.    251(  c)(  3). 
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 nondiscriminatory,  and  may  include  a  reasonable  profit.  145  Pursuant  to  this  statutory  mandate,  the  Commission  has  determined  that  prices  for  UNEs  must  be  based  on  the  total  element  long 
 run  incremental  cost  (TELRIC)  of  providing  those  elements.  146  The  Commission  also  promulgated  rule  51.315(  b),  which  prohibits  incumbent  LECs  from  separating  already  combined 
 elements  before  providing  them  to  competing  carriers,  except  on  request.  147  The  Commission  has  previously  held  that  it  will  not  conduct  a  de  novo  review  of  a  states  pricing  determinations  and 
 will  reject  an  application  only  if  basic  TELRIC  principles  are  violated  or  the  state  commission  makes  clear  errors  in  factual  findings  on  matters  so  substantial  that  the  end  result  falls  outside  the 
 range  that  the  reasonable  application  of  TELRIC  principles  would  produce.  148 
 46.  Although  the  U.  S.  Court  of  Appeals  for  the  Eighth  Circuit  stayed  the  Commissions  pricing  rules  in  1996,  149  the  Supreme  Court  restored  the  Commissions  pricing 


 authority  on  January  25,  1999,  and  remanded  to  the  Eighth  Circuit  for  consideration  of  the  merits  of  the  challenged  rules.  150  On  remand  from  the  Supreme  Court,  the  Eighth  Circuit  concluded  that 
 while  TELRIC  is  an  acceptable  method  for  determining  costs,  certain  specific  requirements  contained  within  the  Commissions  pricing  rules  were  contrary  to  Congressional  intent.  151  The 
 Eighth  Circuit  stayed  the  issuance  of  its  mandate  pending  review  by  the  Supreme  Court.  152  The 


 145  47  U.  S.  C.    252(  d)(  1). 
 146  Local  Competition  First  Report  and  Order,  11  FCC  Rcd  at  15844-  46,  paras.  674-  79;  47  C.  F.  R.    51.501  et 
 seq.;  see  also  Deployment  of  Wireline  Services  Offering  Advanced  Telecommunications  Capability,  CC  Docket  No.  98-  147,  and  Implementation  of  the  Local  Competition  Provisions  of  the  Telecommunications  Act  of  1996,  CC 


 Docket  No.  96-  98,  Third  Report  and  Order  and  Fourth  Report  and  Order,  14  FCC  Rcd  20912,  20974,  para.  135  (Line  Sharing  Order)  (concluding  that  states  should  set  the  prices  for  line  sharing  as  a  new  network  element  in  the 
 same  manner  as  the  state  sets  prices  for  other  UNEs). 
 147  See  47  C.  F.  R.    51.315(  b). 


 148  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  4084,  para.  244;  SWBT  Kansas/  Oklahoma  Order,  16  FCC  Rcd  at 
 6266,  para.  59. 
 149  Iowa  Utils.  Bd.  v.  FCC,  120  F.  3d  753,  800,  804,  805-  06  (8  th  Cir.  1997). 


 150  AT&  T  Corp.  v.  Iowa  Utils.  Bd.,  525  U.  S.  366  (1999).  In  reaching  its  decision,  the  Court  acknowledged  that 
 section  201(  b)  explicitly  grants  the  FCC  jurisdiction  to  make  rules  governing  matters  to  which  the  1996  Act  applies.  Id.  at  380.  Furthermore,  the  Court  determined  that  section  251(  d)  also  provides  evidence  of  an  express 


 jurisdictional  grant  by  requiring  that  the  Commission  [shall]  complete  all  actions  necessary  to  establish  regulations  to  implement  the  requirements  of  this  section.  Id.  at  382.  The  Court  also  held  that  the  pricing  provisions 
 implemented  under  the  Commissions  rulemaking  authority  do  not  inhibit  the  establishment  of  rates  by  the  states.  The  Court  concluded  that  the  Commission  has  jurisdiction  to  design  a  pricing  methodology  to  facilitate  local 
 competition  under  the  1996  Act,  including  pricing  for  interconnection  and  unbundled  access,  as  it  is  the  States  that  will  apply  those  standards  and  implement  that  methodology,  determining  the  concrete  result.  Id. 


 151  Iowa  Utils.  Bd.  v.  FCC,  219  F.  3d  744  (8  th  Cir.  2000),  petition  for  cert.  granted  sub  nom.  Verizon 
 Communications  v.  FCC,  121  S.  Ct.  877  (2001). 
 152  Iowa  Utils.  Bd.  v.  FCC,  No.  96-  3321  et  al.  (8  th  Cir.  Sept.  25,  2000). 
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 Supreme  Court,  on  May  13,  2002,  upheld  the  Commissions  forward-  looking  pricing  methodology  in  determining  costs  of  UNEs  and  reverse[  d]  the  Eighth  Circuits  judgment 
 insofar  as  it  invalidated  TELRIC  as  a  method  for  setting  rates  under  the  Act.  153  Accordingly,  the  Commissions  pricing  rules  remain  in  effect. 


 C.  Checklist  Item  3    Poles,  Ducts,  Conduits  and  Rights  of  Way 
 47.  Section  271(  c)(  2)(  B)(  iii)  requires  BOCs  to  provide  [  n]  ondiscriminatory  access  to  the  poles,  ducts,  conduits,  and  rights-  of-  way  owned  or  controlled  by  the  [BOC]  at  just  and 


 reasonable  rates  in  accordance  with  the  requirements  of  section  224.  154  Section  224(  f)(  1)  states  that  [  a]  utility  shall  provide  a  cable  television  system  or  any  telecommunications  carrier  with 
 nondiscriminatory  access  to  any  pole,  duct,  conduit,  or  right-  of-  way  owned  or  controlled  by  it.  155  Notwithstanding  this  requirement,  section  224(  f)(  2)  permits  a  utility  providing  electric 
 service  to  deny  access  to  its  poles,  ducts,  conduits,  and  rights-  of-  way,  on  a  nondiscriminatory  basis,  where  there  is  insufficient  capacity  and  for  reasons  of  safety,  reliability  and  generally 
 applicable  engineering  purposes.  156  Section  224  also  contains  two  separate  provisions  governing  the  maximum  rates  that  a  utility  may  charge  for  pole  attachments.  157  Section 
 224(  b)(  1)  states  that  the  Commission  shall  regulate  the  rates,  terms,  and  conditions  governing  pole  attachments  to  ensure  that  they  are  just  and  reasonable.  158  Notwithstanding  this  general 
 grant  of  authority,  section  224(  c)(  1)  states  that  [  n]  othing  in  [section  224]  shall  be  construed  to 
 153  Verizon  v.  FCC,  122  S.  Ct.  at  1679.  On  August  21,  2002,  the  Eighth  Circuit  implemented  the  Supreme  Courts 
 mandate  with  respect  to  the  Commissions  TELRIC  pricing  rule  by  vacating  its  prior  opinion  insofar  as  it  had  invalidated  that  rule  and  by  denying  the  petitions  for  review  of  that  rule.  Iowa  Utilities  Board  v.  FCC,  8th  Circuit 


 Nos.  96-  3321,  et  al.,  Judgment,  filed  August  21,  2002. 
 154  47  U.  S.  C.    271(  c)(  2)(  B)(  iii).  As  originally  enacted,  section  224  was  intended  to  address  obstacles  that  cable 
 operators  encountered  in  obtaining  access  to  poles,  ducts,  conduits,  or  rights-  of-  way  owned  or  controlled  by  utilities.  The  1996  Act  amended  section  224  in  several  important  respects  to  ensure  that  telecommunications  carriers 


 as  well  as  cable  operators  have  access  to  poles,  ducts,  conduits,  or  rights-  of-  way  owned  or  controlled  by  utility  companies,  including  LECs.  Second  BellSouth  Louisiana  Order,  13  FCC  Rcd  at  20706,  n.  574. 


 155  47  U.  S.  C.    224(  f)(  1).  Section  224(  a)(  1)  defines  utility  to  include  any  entity,  including  a  LEC,  that  controls 
 poles,  ducts,  conduits,  or  rights-  of-  way  used,  in  whole  or  in  part,  for  any  wire  communications.  47  U.  S.  C.    224(  a)(  1). 


 156  47  U.  S.  C.    224(  f)(  2).  In  the  Local  Competition  First  Report  and  Order,  the  Commission  concluded  that, 
 although  the  statutory  exception  enunciated  in  section  224(  f)(  2)  appears  to  be  limited  to  utilities  providing  electrical  service,  LECs  should  also  be  permitted  to  deny  access  to  their  poles,  ducts,  conduits,  and  rights-  of-  way  because  of 


 insufficient  capacity  and  for  reasons  of  safety,  reliability  and  generally  applicable  engineering  purposes,  provided  the  assessment  of  such  factors  is  done  in  a  nondiscriminatory  manner.  Local  Competition  First  Report  and  Order, 
 11  FCC  Rcd  at  16080-  81,  paras.  1175-  77. 
 157  Section  224(  a)(  4)  defines  pole  attachment  as  any  attachment  by  a  cable  television  system  or  provider  of 
 telecommunications  service  to  a  pole,  duct,  conduit,  or  right-  of-  way  owned  or  controlled  by  a  utility.  47  U.  S.  C.    224(  a)(  4). 


 158  47  U.  S.  C.    224(  b)(  1). 
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 apply  to,  or  to  give  the  Commission  jurisdiction  with  respect  to  the  rates,  terms,  and  conditions,  or  access  to  poles,  ducts,  conduits  and  rights-  of-  way  as  provided  in  [section  224(  f)],  for  pole 
 attachments  in  any  case  where  such  matters  are  regulated  by  a  State.  159  As  of  1992,  nineteen  states,  including  Connecticut,  had  certified  to  the  Commission  that  they  regulated  the  rates, 
 terms,  and  conditions  for  pole  attachments.  160 
 D.  Checklist  Item  4    Unbundled  Local  Loops 
 48.  Section  271(  c)(  2)(  B)(  iv)  of  the  Act,  item  4  of  the  competitive  checklist,  requires  that  a  BOC  provide  [  l]  ocal  loop  transmission  from  the  central  office  to  the  customers  premises, 


 unbundled  from  local  switching  or  other  services.  161  The  Commission  has  defined  the  loop  as  a  transmission  facility  between  a  distribution  frame,  or  its  equivalent,  in  an  incumbent  LEC  central 
 office,  and  the  demarcation  point  at  the  customer  premises.  This  definition  includes  different  types  of  loops,  including  two-  wire  and  four-  wire  analog  voice-  grade  loops,  and  two-  wire  and 
 four-  wire  loops  that  are  conditioned  to  transmit  the  digital  signals  needed  to  provide  service  such  as  ISDN,  ADSL,  HDSL,  and  DS1-  level  signals.  162 


 49.  In  order  to  establish  that  it  is  providing  unbundled  local  loops  in  compliance  with  checklist  item  4,  a  BOC  must  demonstrate  that  it  has  a  concrete  and  specific  legal 
 obligation  to  furnish  loops  and  that  it  is  currently  doing  so  in  the  quantities  that  competitors  demand  and  at  an  acceptable  level  of  quality.  A  BOC  must  also  demonstrate  that  it  provides 
 nondiscriminatory  access  to  unbundled  loops.  163  Specifically,  the  BOC  must  provide  access  to  any  functionality  of  the  loop  requested  by  a  competing  carrier  unless  it  is  not  technically  feasible 
 to  condition  the  loop  facility  to  support  the  particular  functionality  requested.  In  order  to  provide  the  requested  loop  functionality,  such  as  the  ability  to  deliver  xDSL  services,  the  BOC 
 may  be  required  to  take  affirmative  steps  to  condition  existing  loop  facilities  to  enable  competing  carriers  to  provide  services  not  currently  provided  over  the  facilities.  The  BOC  must  provide 


 159  Id.    224(  c)(  1).  The  1996  Act  extended  the  Commissions  authority  to  include  not  just  rates,  terms,  and 
 conditions,  but  also  the  authority  to  regulate  nondiscriminatory  access  to  poles,  ducts,  conduits,  and  rights-  of-  way.  Local  Competition  First  Report  and  Order,  11  FCC  Rcd  at  16104,  para.  1232;  47  U.  S.  C.    224(  f).  Absent  state 


 regulation  of  terms  and  conditions  of  nondiscriminatory  attachment  access,  the  Commission  retains  jurisdiction.  Local  Competition  First  Report  and  Order,  11  FCC  Rcd  at  16104,  para.  1232;  47  U.  S.  C.    224(  c)(  1);  see  also  Bell 
 Atlantic  New  York  Order,  15  FCC  Rcd  at  4093,  para.  264. 
 160  See  States  That  Have  Certified  That  They  Regulate  Pole  Attachments,  Public  Notice,  7  FCC  Rcd  1498  (1992); 
 47  U.  S.  C.    224(  f). 
 161  47  U.  S.  C.    271(  c)(  2)(  B)(  iv). 


 162  Local  Competition  First  Report  and  Order,  11  FCC  Rcd  at  15691,  para.  380;  UNE  Remand  Order,  15  FCC  Rcd 
 at  3772-  73,  paras.  166-  67,  n.  301  (retaining  definition  of  the  local  loop  from  the  Local  Competition  First  Report  and  Order,  but  replacing  the  phrase  network  interconnection  device  with  demarcation  point,  and  making  explicit 


 that  dark  fiber  and  loop  conditioning  are  among  the  features,  functions  and  capabilities  of  the  loop). 
 163  SWBT  Texas  Order,  15  FCC  Rcd  at  18481-  81,  para.  248;  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  4095, 
 para.  269;  Second  BellSouth  Louisiana  Order,  13  FCC  Rcd  at  20637,  para.  185. 
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 competitors  with  access  to  unbundled  loops  regardless  of  whether  the  BOC  uses  digital  loop  carrier  (DLC)  technology  or  similar  remote  concentration  devices  for  the  particular  loops  sought 
 by  the  competitor. 
 50.  On  December  9,  1999,  the  Commission  released  the  Line  Sharing  Order,  which  introduced  new  rules  requiring  BOCs  to  offer  requesting  carriers  unbundled  access  to  the  high-frequency 


 portion  of  local  loops  (HFPL).  164  HFPL  is  defined  as  the  frequency  above  the  voiceband  on  a  copper  loop  facility  that  is  being  used  to  carry  traditional  POTS  analog  circuit-switched 
 voiceband  transmissions.  This  definition  applies  whether  a  BOCs  voice  customers  are  served  by  cooper  or  by  digital  loop  carrier  equipment.  Competing  carriers  should  have 
 access  to  the  HFPL  at  either  a  central  office  or  at  a  remote  terminal.  However,  the  HFPL  network  element  is  only  available  on  a  copper  loop  facility.  165 


 51.  To  determine  whether  a  BOC  makes  line  sharing  available  consistent  with  Commission  rules  set  out  in  the  Line  Sharing  Order,  the  Commission  examines  categories  of 
 performance  measurements  identified  in  the  Bell  Atlantic  New  York  and  SWBT  Texas  Orders.  Specifically,  a  successful  BOC  applicant  could  provide  evidence  of  BOC-  caused  missed 
 installation  due  dates,  average  installation  intervals,  trouble  reports  within  30  days  of  installation,  mean  time  to  repair,  trouble  report  rates,  and  repeat  trouble  report  rates.  In  addition, 
 a  successful  BOC  applicant  should  provide  evidence  that  its  central  offices  are  operationally  ready  to  handle  commercial  volumes  of  line  sharing  and  that  it  provides  competing  carriers  with 
 nondiscriminatory  access  to  the  pre-  ordering  and  ordering  OSS  functions  associated  with  the  provision  of  line  shared  loops,  including  access  to  loop  qualification  information  and  databases. 


 52.  Section  271(  c)(  2)(  B)(  iv)  also  requires  that  a  BOC  demonstrate  that  it  makes  line  splitting  available  to  competing  carriers  so  that  competing  carriers  may  provide  voice  and  data 
 service  over  a  single  loop.  166  In  addition,  a  BOC  must  demonstrate  that  a  competing  carrier,  either  alone  or  in  conjunction  with  another  carrier,  is  able  to  replace  an  existing  UNE-  P 
 configuration  used  to  provide  voice  service  with  an  arrangement  that  enables  it  to  provide  voice  and  data  service  to  a  customer.  To  make  such  a  showing,  a  BOC  must  show  that  it  has  a  legal 
 obligation  to  provide  line  splitting  through  rates,  terms,  and  conditions  in  interconnection  agreements  and  that  it  offers  competing  carriers  the  ability  to  order  an  unbundled  xDSL-  capable 


 164  See  Line  Sharing  Order,  14  FCC  Rcd  at  20924-  27,  paras.  20-  27;  see  also  n.  63  at  C-  12  supra. 
 165  See  Deployment  of  Wireline  Services  offering  Advanced  Telecommunications  Capability  and  Implementation  of 
 the  Local  Competition  Provisions  of  the  Telecommunications  Act  of  1996,  Third  Report  and  Order  on  Reconsideration  in  CC  Docket  No.  98-  147,  Fourth  Report  and  Order  on  Reconsideration  in  CC  Docket  No.  96-  98, 


 16  FCC  Rcd  2101,  2106-  07,  para.  10  (2001). 
 166  See  generally  SWBT  Texas  Order,  15  FCC  Rcd  at  18515-  17,  paras.  323-  329  (describing  line  splitting);  47 
 C.  F.  R.    51.703(  c)  (requiring  that  incumbent  LECs  provide  competing  carriers  with  access  to  unbundled  loops  in  a  manner  that  allows  competing  carriers  to  provide  any  telecommunications  service  that  can  be  offered  by  means  of 


 that  network  element). 
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 loop  terminated  to  a  collocated  splitter  and  DSLAM  equipment,  and  combine  it  with  unbundled  switching  and  shared  transport.  167 
 E.  Checklist  Item  5    Unbundled  Local  Transport 
 53.  Section  271(  c)(  2)(  B)(  v)  of  the  competitive  checklist  requires  a  BOC  to  provide  [  l]  ocal  transport  from  the  trunk  side  of  a  wireline  local  exchange  carrier  switch  unbundled  from 


 switching  or  other  services.  168  The  Commission  has  required  that  BOCs  provide  both  dedicated  and  shared  transport  to  requesting  carriers.  169  Dedicated  transport  consists  of  BOC  transmission 
 facilities  dedicated  to  a  particular  customer  or  carrier  that  provide  telecommunications  between  wire  centers  owned  by  BOCs  or  requesting  telecommunications  carriers,  or  between  switches 
 owned  by  BOCs  or  requesting  telecommunications  carriers.  170  Shared  transport  consists  of  transmission  facilities  shared  by  more  than  one  carrier,  including  the  BOC,  between  end  office 
 switches,  between  end  office  switches  and  tandem  switches,  and  between  tandem  switches,  in  the  BOCs  network.  171 


 F.  Checklist  Item  6    Unbundled  Local  Switching 
 54.  Section  271(  c)(  2)(  B)(  vi)  of  the  1996  Act  requires  a  BOC  to  provide  [  l]  ocal  switching  unbundled  from  transport,  local  loop  transmission,  or  other  services.  172  In  the  Second 


 167  See  SWBT  Kansas/  Oklahoma  Order,  16  FCC  Rcd  at  6348,  para.  220. 
 168  47  U.  S.  C.    271(  c)(  2)(  B)(  v). 
 169  Second  BellSouth  Louisiana  Order,  13  FCC  Rcd  at  20719,  para.  201. 
 170  Id.  A  BOC  has  the  following  obligations  with  respect  to  dedicated  transport:  (a)  provide  unbundled  access  to 
 dedicated  transmission  facilities  between  BOC  central  offices  or  between  such  offices  and  serving  wire  centers  (SWCs);  between  SWCs  and  interexchange  carriers  points  of  presence  (POPs);  between  tandem  switches  and 


 SWCs,  end  offices  or  tandems  of  the  BOC,  and  the  wire  centers  of  BOCs  and  requesting  carriers;  (b)  provide  all  technically  feasible  transmission  capabilities  such  as  DS1,  DS3,  and  Optical  Carrier  levels  that  the  competing  carrier 
 could  use  to  provide  telecommunications;  (c)  not  limit  the  facilities  to  which  dedicated  interoffice  transport  facilities  are  connected,  provided  such  interconnections  are  technically  feasible,  or  restrict  the  use  of  unbundled  transport 
 facilities;  and  (d)  to  the  extent  technically  feasible,  provide  requesting  carriers  with  access  to  digital  cross-  connect  system  functionality  in  the  same  manner  that  the  BOC  offers  such  capabilities  to  interexchange  carriers  that 
 purchase  transport  services.  Id.  at  20719. 
 171  Id.  at  20719,  n.  650.  The  Commission  also  found  that  a  BOC  has  the  following  obligations  with  respect  to 
 shared  transport:  (a)  provide  shared  transport  in  a  way  that  enables  the  traffic  of  requesting  carriers  to  be  carried  on  the  same  transport  facilities  that  a  BOC  uses  for  its  own  traffic;  (b)  provide  shared  transport  transmission  facilities 


 between  end  office  switches,  between  its  end  office  and  tandem  switches,  and  between  tandem  switches  in  its  network;  (c)  permit  requesting  carriers  that  purchase  unbundled  shared  transport  and  unbundled  switching  to  use  the 
 same  routing  table  that  is  resident  in  the  BOCs  switch;  and  (d)  permit  requesting  carriers  to  use  shared  (or  dedicated)  transport  as  an  unbundled  element  to  carry  originating  access  traffic  from,  and  terminating  traffic  to, 
 customers  to  whom  the  requesting  carrier  is  also  providing  local  exchange  service.  Id.  at  20720,  n.  652. 
 172  47  U.  S.  C.    271(  c)(  2)(  B)(  vi);  see  also  Second  BellSouth  Louisiana  Order,  13  FCC  Rcd  at  20722.  A  switch 
 connects  end  user  lines  to  other  end  user  lines,  and  connects  end  user  lines  to  trunks  used  for  transporting  a  call  to  (continued.) 
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 BellSouth  Louisiana  Order,  the  Commission  required  BellSouth  to  provide  unbundled  local  switching  that  included  line-  side  and  trunk-  side  facilities,  plus  the  features,  functions,  and 
 capabilities  of  the  switch.  173  The  features,  functions,  and  capabilities  of  the  switch  include  the  basic  switching  function  as  well  as  the  same  basic  capabilities  that  are  available  to  the  incumbent 
 LECs  customers.  174  Additionally,  local  switching  includes  all  vertical  features  that  the  switch  is  capable  of  providing,  as  well  as  any  technically  feasible  customized  routing  functions.  175 


 55.  Moreover,  in  the  Second  BellSouth  Louisiana  Order,  the  Commission  required  BellSouth  to  permit  competing  carriers  to  purchase  UNEs,  including  unbundled  switching,  in  a 
 manner  that  permits  a  competing  carrier  to  offer,  and  bill  for,  exchange  access  and  the  termination  of  local  traffic.  176  The  Commission  also  stated  that  measuring  daily  customer  usage 
 for  billing  purposes  requires  essentially  the  same  OSS  functions  for  both  competing  carriers  and  incumbent  LECs,  and  that  a  BOC  must  demonstrate  that  it  is  providing  equivalent  access  to 
 billing  information.  177  Therefore,  the  ability  of  a  BOC  to  provide  billing  information  necessary  for  a  competitive  LEC  to  bill  for  exchange  access  and  termination  of  local  traffic  is  an  aspect  of 
 unbundled  local  switching.  178  Thus,  there  is  an  overlap  between  the  provision  of  unbundled  local  switching  and  the  provision  of  the  OSS  billing  function.  179 


 56.  To  comply  with  the  requirements  of  unbundled  local  switching,  a  BOC  must  also  make  available  trunk  ports  on  a  shared  basis  and  routing  tables  resident  in  the  BOCs  switch,  as 
 necessary  to  provide  access  to  shared  transport  functionality.  180  In  addition,  a  BOC  may  not  limit  the  ability  of  competitors  to  use  unbundled  local  switching  to  provide  exchange  access  by 
 requiring  competing  carriers  to  purchase  a  dedicated  trunk  from  an  interexchange  carriers  point  of  presence  to  a  dedicated  trunk  port  on  the  local  switch.  181 


 (Continued  from  previous  page)  another  central  office  or  to  a  long-  distance  carrier.  Switches  can  also  provide  end  users  with  vertical  features  such 
 as  call  waiting,  call  forwarding,  and  caller  ID,  and  can  direct  a  call  to  a  specific  trunk,  such  as  to  a  competing  carriers  operator  services. 


 173  Second  BellSouth  Louisiana  Order,  13  FCC  Rcd  at  20722,  para.  207. 
 174  Id. 
 175  Id.  at  20722-  23,  para.  207. 
 176  Id.  at  20723,  para.  208. 
 177  Id.  at  20723,  para.  208  (citing  Ameritech  Michigan  Order,  12  FCC  Rcd  at  20619,  para.  140). 
 178  Id. 
 179  Id. 
 180  Id.  at  20723,  para.  209  (citing  the  Ameritech  Michigan  Order,  12  FCC  Rcd  at  20705,  para.  306). 
 181  Id.  (citing  the  Ameritech  Michigan  Order,  12  FCC  Rcd  at  20714-  15,  paras.  324-  25). 
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 G.  Checklist  Item  7    911/  E911  Access  and  Directory  Assistance/  Operator  Services 
 57.  Section  271(  c)(  2)(  B)(  vii)  of  the  Act  requires  a  BOC  to  provide  [  n]  ondiscriminatory  access  to    (I)  911  and  E911  services.  182  In  the  Ameritech  Michigan 
 Order,  the  Commission  found  that  section  271  requires  a  BOC  to  provide  competitors  access  to  its  911  and  E911  services  in  the  same  manner  that  a  BOC  obtains  such  access,  i.  e.,  at  parity.  183 
 Specifically,  the  Commission  found  that  a  BOC  must  maintain  the  911  database  entries  for  competing  LECs  with  the  same  accuracy  and  reliability  that  it  maintains  the  database  entries  for 
 its  own  customers.  184  For  facilities-  based  carriers,  the  BOC  must  provide  unbundled  access  to  [its]  911  database  and  911  interconnection,  including  the  provision  of  dedicated  trunks  from  the 
 requesting  carriers  switching  facilities  to  the  911  control  office  at  parity  with  what  [the  BOC]  provides  to  itself.  185  Section  271(  c)(  2)(  B)(  vii)(  II)  and  section  271(  c)(  2)(  B)(  vii)(  III)  require  a 
 BOC  to  provide  nondiscriminatory  access  to  directory  assistance  services  to  allow  the  other  carriers  customers  to  obtain  telephone  numbers  and  operator  call  completion  services, 
 respectively.  186  Section  251(  b)(  3)  of  the  Act  imposes  on  each  LEC  the  duty  to  permit  all  [competing  providers  of  telephone  exchange  service  and  telephone  toll  service]  to  have 
 nondiscriminatory  access  to  .  .  .  operator  services,  directory  assistance,  and  directory  listing,  with  no  unreasonable  dialing  delays.  187  The  Commission  concluded  in  the  Second  BellSouth 
 Louisiana  Order  that  a  BOC  must  be  in  compliance  with  the  regulations  implementing  section  251(  b)(  3)  to  satisfy  the  requirements  of  sections  271(  c)(  2)(  B)(  vii)(  II)  and 
 271(  c)(  2)(  B)(  vii)(  III).  188  In  the  Local  Competition  Second  Report  and  Order,  the  Commission 


 182  47  U.  S.  C.    271(  c)(  2)(  B)(  vii).  911  and  E911  services  transmit  calls  from  end  users  to  emergency  personnel.  It 
 is  critical  that  a  BOC  provide  competing  carriers  with  accurate  and  nondiscriminatory  access  to  911/  E911  services  so  that  these  carriers  customers  are  able  to  reach  emergency  assistance.  Customers  use  directory  assistance  and 


 operator  services  to  obtain  customer  listing  information  and  other  call  completion  services. 
 183  Ameritech  Michigan  Order,  12  FCC  Rcd  at  20679,  para.  256. 


 184  Id. 
 185  Id. 
 186  47  U.  S.  C.    271(  c)(  2)(  B)(  vii)(  II),  (III). 
 187  Id.    251(  b)(  3).  The  Commission  implemented  section  251(  b)(  3)  in  the  Local  Competition  Second  Report  and 
 Order.  47  C.  F.  R.    51.217;  Implementation  of  the  Local  Competition  Provisions  of  the  Telecommunications  Act  of  1996,  Second  Report  and  Order  and  Memorandum  Opinion  and  Order,  11  FCC  Rcd  19392  (1996)  (Local 


 Competition  Second  Report  and  Order)  vacated  in  part  sub  nom.  People  of  the  State  of  California  v.  FCC,  124  F.  3d  934  (8th  Cir.  1997),  overruled  in  part,  AT&  T  Corp.  v.  Iowa  Utils.  Bd.,  525  U.  S.  366  (1999);  see  also 
 Implementation  of  the  Telecommunications  Act  of  1996:  Provision  of  Directory  Listings  Information  under  the  Telecommunications  Act  of  1934,  Notice  of  Proposed  Rulemaking,  14  FCC  Rcd  15550  (1999)  (Directory  Listings 
 Information  NPRM). 
 188  While  both  sections  251(  b)(  3)  and  271(  c)(  2)(  B)(  vii)(  II)  refer  to  nondiscriminatory  access  to  directory 
 assistance,  section  251(  b)(  3)  refers  to  nondiscriminatory  access  to  operator  services,  while  section  271(  c)(  2)(  B)(  vii)(  III)  refers  to  nondiscriminatory  access  to  operator  call  completion  services.  47  U.  S.  C. 


 (continued.) 
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 held  that  the  phrase  nondiscriminatory  access  to  directory  assistance  and  directory  listings  means  that  the  customers  of  all  telecommunications  service  providers  should  be  able  to  access 
 each  LECs  directory  assistance  service  and  obtain  a  directory  listing  on  a  nondiscriminatory  basis,  notwithstanding:  (1)  the  identity  of  a  requesting  customers  local  telephone  service 
 provider;  or  (2)  the  identity  of  the  telephone  service  provider  for  a  customer  whose  directory  listing  is  requested.  189  The  Commission  concluded  that  nondiscriminatory  access  to  the  dialing 
 patterns  of  4-  1-  1  and  5-  5-  5-  1-  2-  1-  2  to  access  directory  assistance  were  technically  feasible,  and  would  continue.  190  The  Commission  specifically  held  that  the  phrase  nondiscriminatory  access 
 to  operator  services  means  that  a  telephone  service  customer,  regardless  of  the  identity  of  his  or  her  local  telephone  service  provider,  must  be  able  to  connect  to  a  local  operator  by  dialing  0,   
 or  0  plus  the  desired  telephone  number.  191 
 58.  Competing  carriers  may  provide  operator  services  and  directory  assistance  by  reselling  the  BOCs  services,  outsourcing  service  provision  to  a  third-  party  provider,  or  using 


 their  own  personnel  and  facilities.  The  Commissions  rules  require  BOCs  to  permit  competitive 
 (Continued  from  previous  page)    251(  b)(  3),  271(  c)(  2)(  B)(  vii)(  III).  The  term  operator  call  completion  services  is  not  defined  in  the  Act,  nor  has 


 the  Commission  previously  defined  the  term.  However,  for  section  251(  b)(  3)  purposes,  the  term  operator  services  was  defined  as  meaning  any  automatic  or  live  assistance  to  a  consumer  to  arrange  for  billing  or  completion,  or 
 both,  of  a  telephone  call.  Local  Competition  Second  Report  and  Order,  11  FCC  Rcd  at  19448,  para.  110.  In  the  same  order  the  Commission  concluded  that  busy  line  verification,  emergency  interrupt,  and  operator-  assisted 
 directory  assistance  are  forms  of  operator  services,  because  they  assist  customers  in  arranging  for  the  billing  or  completion  (or  both)  of  a  telephone  call.  Id.  at  19449,  para.  111.  All  of  these  services  may  be  needed  or  used  to 
 place  a  call.  For  example,  if  a  customer  tries  to  direct  dial  a  telephone  number  and  constantly  receives  a  busy  signal,  the  customer  may  contact  the  operator  to  attempt  to  complete  the  call.  Since  billing  is  a  necessary  part  of 
 call  completion,  and  busy  line  verification,  emergency  interrupt,  and  operator-  assisted  directory  assistance  can  all  be  used  when  an  operator  completes  a  call,  the  Commission  concluded  in  the  Second  BellSouth  Louisiana  Order  that 
 for  checklist  compliance  purposes,  operator  call  completion  services  is  a  subset  of  or  equivalent  to  operator  service.  Second  BellSouth  Louisiana  Order,  13  FCC  Rcd  at  20740,  n.  763.  As  a  result,  the  Commission  uses  the 
 nondiscriminatory  standards  established  for  operator  services  to  determine  whether  nondiscriminatory  access  is  provided. 


 189  47  C.  F.  R.    51.217(  c)(  3);  Local  Competition  Second  Report  and  Order,  11  FCC  Rcd  at  19456-  58,  paras.  130- 
 35.  The  Local  Competition  Second  Report  and  Orders  interpretation  of  section  251(  b)(  3)  is  limited  to  access  to  each  LECs  directory  assistance  service.  Id.  at  19456,  para.  135.  However,  section  271(  c)(  2)(  B)(  vii)  is  not  limited 


 to  the  LECs  systems  but  requires  nondiscriminatory  access  to  .  .  .  directory  assistance  to  allow  the  other  carriers  customers  to  obtain  telephone  numbers.  47  U.  S.  C.    271(  c)(  2)(  B)(  vii).  Combined  with  the  Commissions 
 conclusion  that  incumbent  LECs  must  unbundle  the  facilities  and  functionalities  providing  operator  services  and  directory  assistance  from  resold  services  and  other  unbundled  network  elements  to  the  extent  technically  feasible, 
 Local  Competition  First  Report  and  Order,  11  FCC  Rcd  at  15772-  73,  paras.  535-  37,  section  271(  c)(  2)(  B)(  vii)  s  requirement  should  be  understood  to  require  the  BOCs  to  provide  nondiscriminatory  access  to  the  directory 
 assistance  service  provider  selected  by  the  customers  local  service  provider,  regardless  of  whether  the  competitor;  provides  such  services  itself;  selects  the  BOC  to  provide  such  services;  or  chooses  a  third  party  to  provide  such 
 services.  See  Directory  Listings  Information  NPRM. 
 190  Local  Competition  Second  Report  and  Order,  11  FCC  Rcd  at  19464,  para.  151. 


 191  Id.  at  19464,  para.  151. 
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 LECs  wishing  to  resell  the  BOCs  operator  services  and  directory  assistance  to  request  the  BOC  to  brand  their  calls.  192  Competing  carriers  wishing  to  provide  operator  services  or  directory 
 assistance  using  their  own  or  a  third  party  providers  facilities  and  personnel  must  be  able  to  obtain  directory  listings  either  by  obtaining  directory  information  on  a  read  only  or  per  dip 
 basis  from  the  BOCs  directory  assistance  database,  or  by  creating  their  own  directory  assistance  database  by  obtaining  the  subscriber  listing  information  in  the  BOCs  database.  193  Although  the 
 Commission  originally  concluded  that  BOCs  must  provide  directory  assistance  and  operator  services  on  an  unbundled  basis  pursuant  to  sections  251  and  252,  the  Commission  removed 
 directory  assistance  and  operator  services  from  the  list  of  required  UNEs  in  the  UNE  Remand  Order.  194  Checklist  item  obligations  that  do  not  fall  within  a  BOCs  obligations  under  section 
 251(  c)(  3)  are  not  subject  to  the  requirements  of  sections  251  and  252  that  rates  be  based  on  forward-  looking  economic  costs.  195  Checklist  item  obligations  that  do  not  fall  within  a  BOCs 
 UNE  obligations,  however,  still  must  be  provided  in  accordance  with  sections  201(  b)  and  202(  a),  which  require  that  rates  and  conditions  be  just  and  reasonable,  and  not  unreasonably 
 discriminatory.  196 
 H.  Checklist  Item  8    White  Pages  Directory  Listings 
 59.  Section  271(  c)(  2)(  B)(  viii)  of  the  1996  Act  requires  a  BOC  to  provide  [  w]  hite  pages  directory  listings  for  customers  of  the  other  carriers  telephone  exchange  service.  197 


 Section  251(  b)(  3)  of  the  1996  Act  obligates  all  LECs  to  permit  competitive  providers  of 


 192  47  C.  F.  R.    51.217(  d);  Local  Competition  Second  Report  and  Order,  11  FCC  Rcd  at  19463,  para.  148.  For 
 example,  when  customers  call  the  operator  or  calls  for  directory  assistance,  they  typically  hear  a  message,  such  as  thank  you  for  using  XYZ  Telephone  Company.  Competing  carriers  may  use  the  BOCs  brand,  request  the  BOC 


 to  brand  the  call  with  the  competitive  carriers  name  or  request  that  the  BOC  not  brand  the  call  at  all.  47  C.  F.  R.    51.217(  d). 


 193  47  C.  F.  R.    51.217(  C)(  3)(  ii);  Local  Competition  Second  Report  and  Order,  11  FCC  Rcd  at  19460-  61,  paras. 
 141-  44;  Implementation  of  the  Telecommunications  Act  of  1996:  Telecommunications  Carriers  Use  of  Customer  Proprietary  Network  Information  and  Other  Customer  Information,  Implementation  of  the  Local  Competition 


 Provisions  of  the  Telecommunications  Act  of  1996,  Provision  of  Directory  Listing  Information  Under  the  Communications  Act  of  1934,  as  amended,  Third  Report  and  Order,  Second  Order  on  Reconsideration,  and  Notice 
 of  Proposed  Rulemaking,  14  FCC  Rcd  15550,  15630-  31,  paras.  152-  54  (1999);  Provision  of  Directory  Listing  Information  Under  the  Communications  Act  of  1934,  as  amended,  First  Report  and  Order,  16  FCC  Rcd  2736,  2743- 
 51  (2001). 
 194  UNE  Remand  Order,  15  FCC  Rcd  at  3891-  92,  paras.  441-  42. 


 195  UNE  Remand  Order,  15  FCC  Rcd  at  3905,  para.  470;  see  generally  47  U.  S.  C.    251-  52;  see  also  47  U.  S.  C.   
 252(  d)(  1)(  A)(  i)  (requiring  UNE  rates  to  be  based  on  the  cost  (determined  without  reference  to  a  rate-  of-  return  or  other  rate-  based  proceeding)  of  providing  the    network  element). 


 196  UNE  Remand  Order,  15  FCC  Rcd  at  3905-  06,  paras.  470-  73;  see  also  47  U.  S.  C.    201(  b),  202(  a). 
 197  47  U.  S.  C.    271(  c)(  2)(  B)(  viii). 
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 telephone  exchange  service  and  telephone  toll  service  to  have  nondiscriminatory  access  to  directory  listing.  198 
 60.  In  the  Second  BellSouth  Louisiana  Order,  the  Commission  concluded  that,  consistent  with  the  Commissions  interpretation  of  directory  listing  as  used  in  section 
 251(  b)(  3),  the  term  white  pages  in  section  271(  c)(  2)(  B)(  viii)  refers  to  the  local  alphabetical  directory  that  includes  the  residential  and  business  listings  of  the  customers  of  the  local 
 exchange  provider.  199  The  Commission  further  concluded,  the  term  directory  listing,    as  used  in  this  section,  includes,  at  a  minimum,  the  subscribers  name,  address,  telephone  number,  or  any 
 combination  thereof.  200  The  Commissions  Second  BellSouth  Louisiana  Order  also  held  that  a  BOC  satisfies  the  requirements  of  checklist  item  8  by  demonstrating  that  it:  (1)  provided 
 nondiscriminatory  appearance  and  integration  of  white  page  directory  listings  to  competitive  LECs  customers;  and  (2)  provided  white  page  listings  for  competitors  customers  with  the  same 
 accuracy  and  reliability  that  it  provides  its  own  customers.  201 
 I.  Checklist  Item  9    Numbering  Administration 
 61.  Section  271(  c)(  2)(  B)(  ix)  of  the  1996  Act  requires  a  BOC  to  provide  nondiscriminatory  access  to  telephone  numbers  for  assignment  to  the  other  carriers  telephone 


 exchange  service  customers,  until  the  date  by  which  telecommunications  numbering  administration,  guidelines,  plan,  or  rules  are  established.  202  The  checklist  mandates  compliance 
 with  such  guidelines,  plan,  or  rules  after  they  have  been  established.  203  A  BOC  must  demonstrate  that  it  adheres  to  industry  numbering  administration  guidelines  and  Commission 
 rules.  204 


 198  Id.    251(  b)(  3). 
 199  Second  BellSouth  Louisiana  Order,  13  FCC  Rcd  at  20748,  para.  255. 
 200  Id.  In  the  Second  BellSouth  Louisiana  Order,  the  Commission  stated  that  the  definition  of  directory  listing 
 was  synonymous  with  the  definition  of  subscriber  list  information.  Id.  at  20747  (citing  the  Local  Competition  Second  Report  and  Order,  11  FCC  Rcd  at  19458-  59).  However,  the  Commissions  decision  in  a  later  proceeding 


 obviates  this  comparison,  and  supports  the  definition  of  directory  listing  delineated  above.  See  Implementation  of  the  Telecommunications  Carriers  Use  of  Customer  Proprietary  Network  Information  and  Other  Customer 
 Information,  CC  Docket  No.  96-  115,  Third  Report  and  Order;  Implementation  of  the  Local  Competition  Provisions  of  the  Telecommunications  Act  of  1996,  CC  Docket  No.  96-  98,  Second  Order  on  Reconsideration;  Provision  of 
 Directory  Listing  Information  under  the  Telecommunications  Act  of  1934,  As  Amended,  CC  Docket  No.  99-  273,  FCC  99-  227,  Notice  of  Proposed  Rulemaking,  para.  160  (rel.  Sept.  9,  1999). 


 201  Id. 
 202  47  U.  S.  C.    271(  c)(  2)(  B)(  ix). 
 203  Id. 
 204  See  Second  Bell  South  Louisiana  Order,  13  FCC  Rcd  at  20752;  see  also  Numbering  Resource  Optimization, 
 Report  and  Order  and  Further  Notice  of  Proposed  Rulemaking,  15  FCC  Rcd  7574  (2000);  Numbering  Resource  (continued.) 
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 J.  Checklist  Item  10    Databases  and  Associated  Signaling 
 62.  Section  271(  c)(  2)(  B)(  x)  of  the  1996  Act  requires  a  BOC  to  provide  nondiscriminatory  access  to  databases  and  associated  signaling  necessary  for  call  routing  and 


 completion.  205  In  the  Second  BellSouth  Louisiana  Order,  the  Commission  required  BellSouth  to  demonstrate  that  it  provided  requesting  carriers  with  nondiscriminatory  access  to:  (  1)  signaling 
 networks,  including  signaling  links  and  signaling  transfer  points;  (2)  certain  call-  related  databases  necessary  for  call  routing  and  completion,  or  in  the  alternative,  a  means  of  physical 
 access  to  the  signaling  transfer  point  linked  to  the  unbundled  database;  and  (3)  Service  Management  Systems  (SMS).  206  The  Commission  also  required  BellSouth  to  design,  create, 
 test,  and  deploy  Advanced  Intelligent  Network  (AIN)  based  services  at  the  SMS  through  a  Service  Creation  Environment  (SCE).  207  In  the  Local  Competition  First  Report  and  Order,  the 
 Commission  defined  call-  related  databases  as  databases,  other  than  operations  support  systems,  that  are  used  in  signaling  networks  for  billing  and  collection  or  the  transmission,  routing,  or 
 other  provision  of  telecommunications  service.  208  At  that  time  the  Commission  required  incumbent  LECs  to  provide  unbundled  access  to  their  call-  related  databases,  including  but  not 
 limited  to:  the  Line  Information  Database  (LIDB),  the  Toll  Free  Calling  database,  the  Local  Number  Portability  database,  and  Advanced  Intelligent  Network  databases.  209  In  the  UNE 
 Remand  Order,  the  Commission  clarified  that  the  definition  of  call-  related  databases  includes,  but  is  not  limited  to,  the  calling  name  (CNAM)  database,  as  well  as  the  911  and  E911 
 databases.  210 
 K.  Checklist  Item  11    Number  Portability 
 63.  Section  271(  c)(  2)(  B)  of  the  1996  Act  requires  a  BOC  to  comply  with  the  number  portability  regulations  adopted  by  the  Commission  pursuant  to  section  251.  211  Section  251(  b)(  2) 


 requires  all  LECs  to  provide,  to  the  extent  technically  feasible,  number  portability  in 
 (Continued  from  previous  page)  Optimization,  Second  Report  and  Order,  Order  on  Reconsideration  in  CC  Docket  No.  99-  200  and  Second  Further 


 Notice  of  Proposed  Rulemaking  in  CC  Docket  No.  99-  200,  CC  Docket  Nos.  96-  98;  99-  200  (rel.  Dec.  29,  2000);  Numbering  Resource  Optimization,  Third  Report  and  Order  and  Second  Order  on  Reconsideration  in  CC  Docket 
 No.  96-  98  and  CC  Docket  No.  99-  200  (rel.  Dec.  28,  2001). 
 205  47  U.  S.  C.    271(  c)(  2)(  B)(  x). 


 206  Second  BellSouth  Louisiana  Order,  13  FCC  Rcd  at  20753,  para.  267. 
 207  Id.  at  20755-  56,  para.  272. 
 208  Local  Competition  First  Report  and  Order,  11  FCC  Rcd  at  15741,  n.  1126;  UNE  Remand  Order,  15  FCC  Rcd  at 
 3875,  para.  403. 
 209  Id.  at  15741-  42,  para.  484. 


 210  UNE  Remand  Order,  15  FCC  Rcd  at  3875,  para.  403. 
 211  47  U.  S.  C.    271(  c)(  2)(  B)(  xii). 
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 accordance  with  requirements  prescribed  by  the  Commission.  212  The  1996  Act  defines  number  portability  as  the  ability  of  users  of  telecommunications  services  to  retain,  at  the  same  location, 
 existing  telecommunications  numbers  without  impairment  of  quality,  reliability,  or  convenience  when  switching  from  one  telecommunications  carrier  to  another.  213  In  order  to  prevent  the  cost 
 of  number  portability  from  thwarting  local  competition,  Congress  enacted  section  251(  e)(  2),  which  requires  that  [  t]  he  cost  of  establishing  telecommunications  numbering  administration 
 arrangements  and  number  portability  shall  be  borne  by  all  telecommunications  carriers  on  a  competitively  neutral  basis  as  determined  by  the  Commission.  214  Pursuant  to  these  statutory 
 provisions,  the  Commission  requires  LECs  to  offer  interim  number  portability  to  the  extent  technically  feasible.  215  The  Commission  also  requires  LECs  to  gradually  replace  interim 
 number  portability  with  permanent  number  portability.  216  The  Commission  has  established  guidelines  for  states  to  follow  in  mandating  a  competitively  neutral  cost-  recovery  mechanism  for 
 interim  number  portability,  217  and  created  a  competitively  neural  cost-  recovery  mechanism  for  long-  term  number  portability.  218 


 L.  Checklist  Item  12    Local  Dialing  Parity 
 64.  Section  271(  c)(  2)(  B)(  xii)  requires  a  BOC  to  provide  [  n]  ondiscriminatory  access  to  such  services  or  information  as  are  necessary  to  allow  the  requesting  carrier  to  implement 


 local  dialing  parity  in  accordance  with  the  requirements  of  section  251(  b)(  3).  219  Section 
 212  Id.  at    251(  b)(  2). 
 213  Id.  at    153(  30). 
 214  Id.  at    251(  e)(  2);  see  also  Second  BellSouth  Louisiana  Order,  13  FCC  Rcd  at  20757,  para.  274;  In  the  Matter 
 of  Telephone  Number  Portability,  Third  Report  and  Order,  13  FCC  Rcd  11701,  11702-  04  (1998)  (Third  Number  Portability  Order);  In  the  Matter  of  Telephone  Number  Portability,  Fourth  Memorandum  Opinion  and  Order  on 


 Reconsideration,  15  FCC  Rcd  16459,  16460,  16462-  65,  paras.  1,  6-  9  (1999)  (Fourth  Number  Portability  Order). 
 215  Fourth  Number  Portability  Order,  15  FCC  Rcd  at  16465,  para.  10;  Telephone  Number  Portability,  First  Report 
 and  Order  and  Further  Notice  of  Proposed  Rulemaking,  11  FCC  Rcd  8352,  8409-  12,  paras.  110-  16  (1996)  (First  Number  Portability  Order);  see  also  47  U.  S.  C.    251(  b)(  2). 


 216  See  47  C.  F.  R.    52.3(  b)-(  f);  Second  BellSouth  Louisiana  Order,  13  FCC  Rcd  at  20758,  para.  275;  First 
 Number  Portability  Order,  11  FCC  Rcd  at  8355,  8399-  8404,  paras.  3,  91;  Third  Number  Portability  Order,  13  FCC  Rcd  at  11708-  12,  paras.  12-  16. 


 217  See  47  C.  F.  R.    52.29;  Second  BellSouth  Louisiana  Order,  13  FCC  Rcd  at  20758,  para.  275;  First  Number 
 Portability  Order,  11  FCC  Rcd  at  8417-  24,  paras.  127-  40. 
 218  See  47  C.  F.  R.    52.32,  52.33;  Second  BellSouth  Louisiana  Order,  13  FCC  Rcd  at  20758,  para.  275;  Third 
 Number  Portability  Order,  13  FCC  Rcd  at  11706-  07,  para.  8;  Fourth  Number  Portability  Order  at  16464-  65,  para.  9. 


 219  Based  on  the  Commissions  view  that  section  251(  b)(  3)  does  not  limit  the  duty  to  provide  dialing  parity  to  any 
 particular  form  of  dialing  parity  (i.  e.,  international,  interstate,  intrastate,  or  local),  the  Commission  adopted  rules  in  August  1996  to  implement  broad  guidelines  and  minimum  nationwide  standards  for  dialing  parity.  Local 


 Competition  Second  Report  and  Order,  11  FCC  Rcd  at  19407;  Interconnection  Between  Local  Exchange  Carriers  (continued.) 
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 251(  b)(  3)  imposes  upon  all  LECs  [  t]  he  duty  to  provide  dialing  parity  to  competing  providers  of  telephone  exchange  service  and  telephone  toll  service  with  no  unreasonable  dialing  delays.  220 
 Section  153(  15)  of  the  Act  defines  dialing  parity  as  follows: 
 [A]  person  that  is  not  an  affiliate  of  a  local  exchange  carrier  is  able  to  provide  telecommunications  services  in  such  a  manner  that 


 customers  have  the  ability  to  route  automatically,  without  the  use  of  any  access  code,  their  telecommunications  to  the 
 telecommunications  services  provider  of  the  customers  designation.  221 


 65.  The  rules  implementing  section  251(  b)(  3)  provide  that  customers  of  competing  carriers  must  be  able  to  dial  the  same  number  of  digits  the  BOCs  customers  dial  to  complete  a 
 local  telephone  call.  222  Moreover,  customers  of  competing  carriers  must  not  otherwise  suffer  inferior  quality  service,  such  as  unreasonable  dialing  delays,  compared  to  the  BOCs 
 customers.  223 
 M.  Checklist  Item  13    Reciprocal  Compensation 
 66.  Section  271(  c)(  2)(  B)(  xiii)  of  the  Act  requires  that  a  BOC  enter  into  [  r]  eciprocal  compensation  arrangements  in  accordance  with  the  requirements  of  section  252(  d)(  2).  224  In 


 turn,  pursuant  to  section  252(  d)(  2)(  A),  a  state  commission  shall  not  consider  the  terms  and  conditions  for  reciprocal  compensation  to  be  just  and  reasonable  unless  (i)  such  terms  and 
 conditions  provide  for  the  mutual  and  reciprocal  recovery  by  each  carrier  of  costs  associated  with  the  transport  and  termination  on  each  carriers  network  facilities  of  calls  that  originate  on 
 the  network  facilities  of  the  other  carrier;  and  (ii)  such  terms  and  conditions  determine  such  costs  on  the  basis  of  a  reasonable  approximation  of  the  additional  costs  of  terminating  such  calls.  225 


 (Continued  from  previous  page)  and  Commercial  Mobile  Radio  Service  Providers,  CC  Docket  No.  95-  185,  Further  Order  On  Reconsideration,  FCC 
 99-  170  (rel.  July  19,  1999). 
 220  47  U.  S.  C.    251(  b)(  3). 


 221  Id.    153(  15). 
 222  47  C.  F.  R    51.205,  51.207. 
 223  See  47  C.  F.  R.    51.207  (requiring  same  number  of  digits  to  be  dialed);  Local  Competition  Second  Report  and 
 Order,  11  FCC  Rcd  at  19400,  19403. 
 224  47  U.  S.  C.    271(  c)(  2)(  B)(  xiii). 


 225  Id.    252(  d)(  2)(  A). 
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 N.  Checklist  Item  14    Resale 
 67.  Section  271(  c)(  2)(  B)(  xiv)  of  the  Act  requires  a  BOC  to  make  telecommunications  services  .  .  .  available  for  resale  in  accordance  with  the  requirements  of 


 sections  251(  c)(  4)  and  252(  d)(  3).  226  Section  251(  c)(  4)(  A)  requires  incumbent  LECs  to  offer  for  resale  at  wholesale  rates  any  telecommunications  service  that  the  carrier  provides  at  retail  to 
 subscribers  who  are  not  telecommunications  carriers.  227  Section  252(  d)(  3)  requires  state  commissions  to  determine  wholesale  rates  on  the  basis  of  retail  rates  charged  to  subscribers  for 
 the  telecommunications  service  requested,  excluding  the  portion  thereof  attributable  to  any  marketing,  billing,  collection,  and  other  costs  that  will  be  avoided  by  the  local  exchange 
 carrier.  228  Section  251(  c)(  4)(  B)  prohibits  unreasonable  or  discriminatory  conditions  or  limitations  on  service  resold  under  section  251(  c)(  4)(  A).  229  Consequently,  the  Commission 
 concluded  in  the  Local  Competition  First  Report  and  Order  that  resale  restrictions  are  presumed  to  be  unreasonable  unless  the  LEC  proves  to  the  state  commission  that  the  restriction  is 
 reasonable  and  nondiscriminatory.  230  If  an  incumbent  LEC  makes  a  service  available  only  to  a  specific  category  of  retail  subscribers,  however,  a  state  commission  may  prohibit  a  carrier  that 
 obtains  the  service  pursuant  to  section  251(  c)(  4)(  A)  from  offering  the  service  to  a  different  category  of  subscribers.  231  If  a  state  creates  such  a  limitation,  it  must  do  so  consistent  with 
 requirements  established  by  the  Federal  Communications  Commission.  232  In  accordance  with  sections  271(  c)(  2)(  B)(  ii)  and  271(  c)(  2)(  B)(  xiv),  a  BOC  must  also  demonstrate  that  it  provides 
 nondiscriminatory  access  to  operations  support  systems  for  the  resale  of  its  retail 


 226  Id.    271(  c)(  2)(  B)(  xiv). 
 227  Id.    251(  c)(  4)(  A). 
 228  Id.    252(  d)(  3). 
 229  Id.    251(  c)(  4)(  B). 
 230  Local  Competition  First  Report  and  Order,  11  FCC  Rcd  at  15966,  para.  939;  47  C.  F.  R.    51.613(  b).  The 
 Eighth  Circuit  acknowledged  the  Commissions  authority  to  promulgate  such  rules,  and  specifically  upheld  the  sections  of  the  Commissions  rules  concerning  resale  of  promotions  and  discounts  in  Iowa  Utilities  Board.  Iowa 


 Utils.  Bd.  v.  FCC,  120  F.  3d  at  818-  19,  affd  in  part  and  remanded  on  other  grounds,  AT&  T  v.  Iowa  Utils.  Bd.,  525  U.  S.  366  (1999).  See  also  47  C.  F.  R.    51.613-  51.617. 


 231  47  U.  S.  C.    251(  c)(  4)(  B). 
 232  Id. 
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 telecommunications  services.  233  The  obligations  of  section  251(  c)(  4)  apply  to  the  retail  telecommunications  services  offered  by  a  BOCs  advanced  services  affiliate.  234 
 V.  COMPLIANCE  WITH  SEPARATE  AFFILIATE  REQUIREMENTS    SECTION  272 
 68.  Section  271(  d)(  3)(  B)  requires  that  the  Commission  shall  not  approve  a  BOCs  application  to  provide  interLATA  services  unless  the  BOC  demonstrates  that  the  requested 
 authorization  will  be  carried  out  in  accordance  with  the  requirements  of  section  272.  235  The  Commission  set  standards  for  compliance  with  section  272  in  the  Accounting  Safeguards  Order 
 and  the  Non-  Accounting  Safeguards  Order.  236  Together,  these  safeguards  discourage  and  facilitate  the  detection  of  improper  cost  allocation  and  cross-  subsidization  between  the  BOC  and 
 its  section  272  affiliate.  237  In  addition,  these  safeguards  ensure  that  BOCs  do  not  discriminate  in  favor  of  their  section  272  affiliates.  238 


 69.  As  the  Commission  stated  in  the  Ameritech  Michigan  Order,  compliance  with  section  272  is  of  crucial  importance  because  the  structural,  transactional,  and 
 nondiscrimination  safeguards  of  section  272  seek  to  ensure  that  BOCs  compete  on  a  level  playing  field.  239  The  Commissions  findings  regarding  section  272  compliance  constitute 


 233  See,  e.  g.,  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  4046-  48,  paras.  178-  81  (Bell  Atlantic  provides 
 nondiscriminatory  access  to  its  OSS  ordering  functions  for  resale  services  and  therefore  provides  efficient  competitors  a  meaningful  opportunity  to  compete). 


 234  See  Verizon  Connecticut  Order,  16  FCC  Rcd  14147,  14160-  63,  paras.  27-  33  (2001);  Association  of 
 Communications  Enterprises  v.  FCC,  235  F.  3d  662  (D.  C.  Cir.  2001). 
 235  47  U.  S.  C.    271(  d)(  3)(  B). 


 236  See  Implementation  of  the  Accounting  Safeguards  Under  the  Telecommunications  Act  of  1996,  CC  Docket  No. 
 96-  150,  Report  and  Order,  11  FCC  Rcd  17539  (1996)  (Accounting  Safeguards  Order),  Second  Order  On  Reconsideration,  FCC  00-  9  (rel.  Jan.  18,  2000);  Implementation  of  the  Non-  Accounting  Safeguards  of  Sections  271 


 and  272  of  the  Communications  Act  of  1934,  as  amended,  CC  Docket  No.  96-  149,  First  Report  and  Order  and  Further  Notice  of  Proposed  Rulemaking,  11  FCC  Rcd  21905  (1996)  (Non-  Accounting  Safeguards  Order),  petition 
 for  review  pending  sub  nom.  SBC  Communications  v.  FCC,  No.  97-  1118  (filed  D.  C.  Cir.  Mar.  6,  1997)  (held  in  abeyance  May  7,  1997),  First  Order  on  Reconsideration,  12  FCC  Rcd  2297  (1997)  (First  Order  on 
 Reconsideration),  Second  Order  on  Reconsideration,  12  FCC  Rcd  8653  (1997)  (Second  Order  on  Reconsideration),  affd  sub  nom.  Bell  Atlantic  Telephone  Companies  v.  FCC,  131  F.  3d  1044  (D.  C.  Cir.  1997),  Third  Order  on 
 Reconsideration,  FCC  99-  242  (rel.  Oct.  4,  1999)  (Third  Order  on  Reconsideration). 
 237  Non-  Accounting  Safeguards  Order,  11  FCC  Rcd  at  21914;  Accounting  Safeguards  Order,  11  FCC  Rcd  at 
 17550;  Ameritech  Michigan  Order,  12  FCC  Rcd  at  20725. 
 238  Non-  Accounting  Safeguards  Order,  11  FCC  Rcd  at  21914,  paras.  15-  16;  Ameritech  Michigan  Order,  12  FCC 
 Rcd  at  20725,  para.  346. 
 239  Ameritech  Michigan  Order,  12  FCC  Rcd  at  20725,  para.  346;  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at 
 4153,  para.  402. 
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 independent  grounds  for  denying  an  application.  240  Past  and  present  behavior  of  the  BOC  applicant  provides  the  best  indicator  of  whether  [the  applicant]  will  carry  out  the  requested 
 authorization  in  compliance  with  section  272.  241 
 VI.  COMPLIANCE  WITH  THE  PUBLIC  INTEREST    SECTION  271(  D)(  3)(  C) 
 70.  In  addition  to  determining  whether  a  BOC  satisfies  the  competitive  checklist  and  will  comply  with  section  272,  Congress  directed  the  Commission  to  assess  whether  the  requested 


 authorization  would  be  consistent  with  the  public  interest,  convenience,  and  necessity.  242  Compliance  with  the  competitive  checklist  is  itself  a  strong  indicator  that  long  distance  entry  is 
 consistent  with  the  public  interest.  This  approach  reflects  the  Commissions  many  years  of  experience  with  the  consumer  benefits  that  flow  from  competition  in  telecommunications 
 markets. 
 71.  Nonetheless,  the  public  interest  analysis  is  an  independent  element  of  the  statutory  checklist  and,  under  normal  canons  of  statutory  construction,  requires  an  independent 


 determination.  243  Thus,  the  Commission  views  the  public  interest  requirement  as  an  opportunity  to  review  the  circumstances  presented  by  the  application  to  ensure  that  no  other  relevant  factors 
 exist  that  would  frustrate  the  congressional  intent  that  markets  be  open,  as  required  by  the  competitive  checklist,  and  that  entry  will  therefore  serve  the  public  interest  as  Congress 
 expected.  Among  other  things,  the  Commission  may  review  the  local  and  long  distance  markets 
 240  Second  BellSouth  Louisiana  Order,  13  FCC  Rcd  at  20785-  86,  para.  322;  Bell  Atlantic  New  York  Order,  15  FCC 
 Rcd  at  4153,  para.  402. 
 241  Bell  Atlantic  New  York  Order,  15  FCC  Rcd  at  4153,  para.  402. 


 242  47  U.  S.  C.    271(  d)(  3)(  C). 
 243  In  addition,  Congress  specifically  rejected  an  amendment  that  would  have  stipulated  that  full  implementation  of 
 the  checklist  necessarily  satisfies  the  public  interest  criterion.  See  Ameritech  Michigan  Order,  12  FCC  Rcd  at  20747  at  para.  360-  66;  see  also  141  Cong.  Rec.  S7971,  S8043  (June.  8,  1995). 
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 to  ensure  that  there  are  not  unusual  circumstances  that  would  make  entry  contrary  to  the  public  interest  under  the  particular  circumstances  of  the  application  at  issue.  244  Another  factor  that 
 could  be  relevant  to  the  analysis  is  whether  the  Commission  has  sufficient  assurance  that  markets  will  remain  open  after  grant  of  the  application.  While  no  one  factor  is  dispositive  in  this  analysis, 
 the  overriding  goal  is  to  ensure  that  nothing  undermines  the  conclusion,  based  on  the  Commissions  analysis  of  checklist  compliance,  that  markets  are  open  to  competition. 


 244  See  Second  BellSouth  Louisiana  Order,  13  FCC  Rcd  at  20805-  06,  para.  360  (the  public  interest  analysis  may 
 include  consideration  of  whether  approval  .  .  .  will  foster  competition  in  all  relevant  telecommunications  markets). 
453
 Federal  Communications  Commission  FCC  02-  260 
 Separate  Statement  of 
 Commissioner  Michael  J.  Copps 


 Re:  Joint  Application  by  BellSouth  Corporation,  BellSouth  Telecommunications,  Inc.,  and  BellSouth  Long  Distance,  Inc.,  for  Provision  of  In-  Region,  InterLATA  Services  in 
 Alabama,  Kentucky,  Mississippi,  North  Carolina,  and  South  Carolina 
 BellSouth  has  done  a  great  deal  to  open  its  local  markets  to  competition  in  these  states.  Indeed,  its  performance  has  shown  improvement  in  certain  areas  that  were  at  issue  in  prior 
 applications.  I  also  commend  the  State  commissions  in  Alabama,  Kentucky,  Mississippi,  North  Carolina,  and  South  Carolina  for  their  efforts  to  promote  competition. 


 In  BellSouths  application  for  Georgia  and  Louisiana,  I  noted  that,  in  a  number  of  areas,  including  in  particular  the  operations  support  systems  and  the  process  for  modifying  those 
 systems,  BellSouth  only  minimally  passed  the  statutory  checklist.  The  record  in  this  proceeding  indicates  that  BellSouth  has  improved  its  performance  in  these  areas,  as  the  Department  of 
 Justice  and  other  parties  recognize,  but  that  there  are  additional  steps  that  BellSouth  should  take  to  further  improve  its  systems.  Our  expectation  is  that  BellSouths  performance  will  continue  to 
 improve  and  that  it  will  work  cooperatively  with  other  carriers  through  business-  to-  business  relationships  to  resolve  any  issues  that  develop. 


 To  the  extent  that  BellSouth  does  not  adequately  address  problems  that  occur,  the  Commission  and  the  state  commissions  have  a  statutory  obligation  to  enforce  the  market-opening 
 obligations  of  the  Act.  In  this  Order,  the  Commission  has  directed  its  271  Compliance  Team  to  examine  all  aspects  of  BellSouths  performance  to  guard  against  backsliding,  and  has 
 focused  its  attention  in  particular  on  OSS  and  change  control  issues.  We  must  be  proactive  and  vigilant  as  we  monitor  compliance  in  these  areas,  just  as  we  remain  vigilant  on  all  facets  of 
 section  271  compliance. 
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