286 1 STATE OF MICHIGAN 2 BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION 3 4 In the matter, on the Commission's on motion, to consider AMERITECH 5 MICHIGAN'S compliance with the Case No. U-12320 competitive checklist in Section 271 6 of the federal Telecommunications Act of 1996. 7 ______________________________________/ 8 Proceedings had in the above-entitled 9 matter at the Michigan Public Service Commission, 6545 10 Mercantile Way, Lansing, Michigan. 11 SESSION OF THURSDAY, MARCH 30, 2000 12 VOLUME 4 13 - - - 14 BEFORE: THOMAS LONERGAN, Director MPSC Communications Staff 15 RODNEY GREGG, Facilitator 16 17 PARTICIPANTS ____________ 18 MPSC ____ 19 STEVEN D. HUGHEY, Legal ANN SCHNEIDEWIND, MPSC Communications Staff 20 ROBIN ANCONA, MPSC Communications Staff 21 AMERITECH_MICHIGAN _________ ________ 22 CRAIG ANDERSON, Legal SUSAN FRENTZ, Director - Regulatory 23 KELLY FENNELL, Director YVETTE PUGH 24 ERIN GRAVELYN, Legal DONALD V. CALAMIA, Manager, Regulatory 25 TERICE LASSWELL

287 1 AMERITECH_MICHIGAN (Continued) _________ ________ 2 JERRY L. HAMPTON, Director 3 SCOTT J. ALEXANDER, Director JEFF HUTCHINSON, Director 4 5 AT&T_COMMUNICATIONS ____ ______________ 6 JAY REIDY, Legal BRUCE C. BENNETT, Director 7 FRANCES BROWN 8 BULLSEYE_TELECOM ________ _______ 9 BILL DeFRANCE 10 HORIZON_TELECOMMUNICATIONS,_INC. _______ ___________________ ____ 11 RICK GOULD, Regulatory 12 13 MCI_WORLDCOM ___ ________ 14 JAMES R. DENNISTON, Legal SHERRY LICHTENBERG, via telephone 15 JOAN CAMPION, via telephone EVELYN RUFFIN, via telephone 16 JOANN RAINEY, via telephone 17 NEXTLINK ________ 18 THERESA POWELL, via telephone 19 RHYTHMS_NETCONNECTIONS _______ ______________ 20 CLEC_ASSOCIATION_OF_MICHIGAN ____ ___________ __ ________ McLEODUSA _________ 21 BILL RALLS, Legal 22 23 SPRINT_COMMUNICATIONS_COMPANY ______ ______________ _______ 24 RACHEL REIBER JIM SEVERANCE 25

288 1 Lansing, Michigan 2 Thursday, March 30, 2000 3 10:00 A.M. 4 - - - 5 (The proceedings were resumed pursuant to 6 the adjournment.) 7 MR. GREGG: Rod Gregg from the MPSC. 8 MR. LONERGAN: I'm Tom Lonergan with the 9 MPSC. 10 MR. ALEXANDER: Scott Alexander with 11 Ameritech. 12 MR. HAMPTON: I'm Jerry Hampton with 13 Ameritech, Chicago. 14 MR. HUTCHINSON: Jeff Hutchinson, 15 Ameritech. 16 MR. ANDERSON: Craig Anderson, Ameritech. 17 MS. FENNELL: Kelly Fennell, Ameritech. 18 MS. LASSWELL: Terice Lasswell, 19 Ameritech. 20 MR. RALLS: I'm Bill Ralls, representing 21 the CLEC Association of Michigan, McLeodUSA and Rhythms. 22 MR. DENNISTON: Jim Denniston, MCI 23 WorldCom. 24 MR. REIDY: Jay Reidy, AT&T. 25 MR. BENNETT: Bruce Bennett, AT&T.

289 1 MS. REIBER: Rachel Reiber, Sprint. 2 MR. SEVERANCE: Jim Severance, Sprint. 3 MS. SCHNEIDEWIND: Ann Schneidewind, 4 Commission staff. 5 MS. LICHTENBERG: This is Sherry 6 Lichtenberg on the bridge. We can't hear you. 7 MS. ANCONA: Robin E. Ancona, staff. 8 MS. FRENTZ: Susan Frentz from Ameritech 9 Michigan - Regulatory. 10 MS. GRAVELYN: Erin Gravelyn from 11 Ameritech. 12 MS. PUGH: Yvette Pugh from Ameritech 13 Michigan. 14 MR. CALAMIA: John Calamia, Ameritech 15 Michigan. 16 MS. BROWN: Francie Brown, AT&T. 17 MR. DeFRANCE: Bill DeFrance, BullsEye 18 Telecom. 19 MR. GREGG: Okay. And then we have the 20 people on the bridge. Do you want to introduce 21 yourselves? 22 MS. LICHTENBERG: Sherry Lichtenberg, MCI 23 WorldCom. 24 MS. POWELL: Teresa Powell, Nextlink. 25 MR. LONERGAN: Anybody else?

290 1 MR. GREGG: Well, welcome to the tariff 2 collaborative. 3 We have an agenda set out. So we may as 4 well start on it. 5 MS. LICHTENBERG: Excuse me, Tom. We 6 can't hear you. You need to be closer to the mike or 7 speak up. 8 MR. LONERGAN: We'll try. 9 MS. LICHTENBERG: That's much better. 10 MR. GREGG: This is Rod Gregg. We're 11 going to start now. First we're going to start with 12 Ameritech summarizing their tariff filing. 13 Do we have someone from Ameritech who is 14 going to do that for us? 15 MR. ANDERSON: Just before we start I 16 want to make a comment. 17 I wanted to thank everybody, the 18 industry, for giving us the list of the issues. I think 19 it was helpful in defining what issues we need to address. 20 And we have tried to have the right people here to address 21 those issues to the extent we can. 22 There may be some issues that come up 23 that we don't -- 24 MS. LICHTENBERG: I'm not hearing 25 anything.

291 1 (A recess was taken.) 2 - - - 3 MR. ANDERSON: As I was saying, based on 4 the issues that have been identified in the filings made 5 earlier this week, we have attempted to have all the right 6 people here to answer the questions. 7 There may be some issues however that 8 come up that were not identified or that some of the 9 people were not available for this meeting. As to those, 10 we'll take those back and get answers back. 11 We have attempted to summarize the issues 12 as identified in the filings and categorize them for 13 discussion purposes. 14 I did want to say that I think obviously 15 the purpose of the collaborative is to resolve issues 16 where possible, and where we can't reach resolution to 17 hopefully narrow the issues. 18 And I recognize that there are some 19 issues here that are probably going to be thorny issues 20 and involve fundamental disagreements, perhaps on policy 21 issues. And candidly, I think one of those is the 22 connected-through issue, currently connected issue, that 23 was identified, I think, in almost all the filings. 24 Rather than spend a lot of time with me 25 laying forth Ameritech's legal position and Jay or Jim

292 1 laying forth the positions that have already been argued 2 ad nauseum in various forums, I would suggest as to those 3 issues we certainly identify them and set out our position 4 and to the extent that we can reach resolution. 5 But I would like, to the extent we can 6 avoid focusing on the legal arguments here and address -- 7 I think there are many of the issues that have been 8 identified that relate to operational and factual issues. 9 And to the extent we can resolve those, address them and 10 identify them or narrow the other issues that are really 11 legal policies. So just as an opening comment. 12 MS. FRENTZ: And this is Susan Frentz 13 from Ameritech. 14 Yvette Pugh put together that 15 categorization that Craig just referred to. Yvette has 16 them, if you haven't picked them up, on the back table. 17 MS. LICHTENBERG: I really would like to 18 hear this. And I'm physically unable to travel today. 19 Can you all get closer to the microphone or do anything? 20 MR. LONERGAN: There's a couple more 21 chairs. For those of you who are going to be speaking 22 frequently, you might as well come to the front table. 23 MS. FRENTZ: I'll try to restate it. 24 MS. LICHTENBERG: We would particularly 25 like to be able to hear Ameritech.

293 1 MR. ANDERSON: And we like to hear you, 2 Sherry. 3 MS. FRENTZ: Thank you, Sherry, and those 4 on the phone. 5 This is Susan Frentz from Ameritech. Can 6 you hear me? 7 MS. LICHTENBERG: Great. 8 MS. FRENTZ: Great. 9 The first group of items that we put 10 together relate to issues that will be coming up and we 11 will be tariffing them per the FCC orders. And they are 12 in the UNE remand order and also in the line-sharing 13 order. And they will be effective on May 17th in the case 14 of subloop and dark fiber. And in the case of line 15 sharing, they become effective June 5th. 16 So we just wanted to let you know, thanks 17 for all the comments: Hey, where is your line sharing? 18 We didn't see subloop or dark fiber. But you will. It's 19 just not effective yet and we do not have to file those 20 tariffs yet. 21 So that's the first small group of items. 22 MS. LICHTENBERG: This is Sherry 23 Lichtenberg. 24 Will you be able to provide us with any 25 discussion today on what those, what that information will

294 1 be? Or will we not see that tariff or any data until May 2 17th? 3 MS. FRENTZ: You will not see that data 4 today. 5 MS. LICHTENBERG: Thank you. 6 MS. FRENTZ: The next group -- Kelly, I 7 think they will be able to hear you from there. 8 MS. FENNELL: The next group we sort 9 of -- 10 MS. LICHTENBERG: Would you ask Kelly or 11 whoever is speaking to get to the microphone. 12 MS. FENNELL: How is that, Sherry? 13 MS. LICHTENBERG: I'm really interested 14 in what you have to say. So if you could go directly to 15 it, it would help a lot. I apologize. 16 MS. FENNELL: I'm right in front of it. 17 MS. LICHTENBERG: Okay. That's better. 18 MS. FENNELL: The second group we labeled 19 a provisioning group of items. And in that there were 20 some references in the various comments about using CABS 21 as the billing system, including information on 22 maintenance and repair and then a reference to the 23 customer-friendly manual. 24 And we see those issues more as 25 provisioning type issues rather than tariff issues. We

295 1 usually don't put in our tariffs what billing system we 2 are using for billing. 3 Maintenance and repair, that is addressed 4 real -- I guess, broadly, I would put it. There's a 5 general thing about that we, Ameritech, maintain our 6 equipment at our expense. And that's in the general reg 7 section in part 2, section 2. 8 Is that correct, Yvette? 9 MS. PUGH: Yes. 10 MS. FENNELL: Yes. And then the 11 reference to the customer-friendly manual. I know that's 12 an issue that needs to be addressed. And it's in the 13 Commission order established in this case. But I think 14 that one will be covered as part of our comprehensive OSS 15 test. 16 In there there will be a review of all of 17 our documentation. And I think that issue will be 18 addressed there rather than a tariff issue. So that to me 19 is an OSS test issue. 20 MR. GREGG: This is Rod Gregg, alias John 21 Kern. 22 Just a comment on the new issues. You 23 say that those things will not be available until -- they 24 don't need to be tariffed until May 17th and June 5th. 25 I noticed in the tariffs that you filed

296 1 recently, these things are not -- at least there are some 2 rates that are not effective until April 30th. 3 Can't you put these tariffs in effect and 4 make them effective as of these May 17th, June 5th dates? 5 MS. FENNELL: We don't have anything -- 6 we're still in the process of developing those products. 7 Because they are not required until May per the UNE remand 8 order and then early June for line sharing. 9 Those products are still in development. 10 I think that's a little different than -- it's a different 11 situation for us than updating rates. 12 MR. GREGG: Okay. 13 MR. REIDY: Before we move on, Jay Reidy 14 from AT&T. 15 And in particular, what you just said, 16 Kelly, with regard to provisioning, I want to just 17 understand the structure and format of our discussion 18 today. 19 We might disagree with you, for example, 20 that the provisioning issues that we raised may have some 21 importance to this tariff collaborative. Should we raise 22 those now? Should we wait and see? Are you giving us a 23 layout for the day or is this the time that I start 24 pounding the table, I guess? 25 MR. LONERGAN: I guess I would

297 1 recommend -- I think we're on item 1 which is the 2 Ameritech summary and then item 2 is CLECs' responses. 3 So I guess I would let them kind of go 4 through these and explain what their notion is and then 5 we'll open it up for debate and discussion and critique. 6 I guess I'm trying to be John Kern today 7 and keep this thing moving. So let's let Ameritech kind 8 of run down their exhibit here, kind of give you the 9 overview of what they think that these are and then we'll 10 come back and give you the chance. 11 MR. REIDY: That's fine with us. 12 MR. ANDERSON: Tom, I think Kelly and I 13 were just looking at it. I think maybe the document 14 itself could serve as our summary. And if we want to get 15 right into discussion on, say, new items and see if 16 there's issues, then maybe we can just kind of identify if 17 there's issues and come back to that. 18 MR. LONERGAN: So you are essentially 19 waiving your oral presentation? 20 MR. ANDERSON: Well, I think I would 21 suggest that this document serve as our summary of what 22 the issues are. 23 MR. LONERGAN: So you're saying take each 24 category and talk about them. That's fine with me if 25 that's what you --

298 1 MR. ANDERSON: If that's okay with -- 2 MR. REIDY: So you don't have any overall 3 presentation on the tariff to give? 4 MR. ANDERSON: No, not really. I think 5 our focus was on -- really, we looked at the issues that 6 you all or all y'all sent us and identified and tried to 7 categorize them in this fashion. 8 And I think that was our intent, that 9 this would serve as a format for discussion. 10 MR. LONERGAN: That being the case, why 11 don't we back up to the new items and see if there's any 12 further discussion or comment about those. 13 MR. DENNISTON: I just want to make sure. 14 Sherry, are you still there? 15 MS. LICHTENBERG: I am here, but I can 16 barely hear anyone. 17 MR. DENNISTON: The last couple times I 18 noticed that the green lights on top were on on top of 19 that unit and now they are off. Would that be 20 affecting -- 21 MR. GREGG: They are still on. 22 MR. LONERGAN: We may just not have a 23 very good line here. 24 MR. REIDY: Well, the other thing is 25 usually there's extensions from that type of a telephone

299 1 conference unit that can be placed around. 2 MS. LICHTENBERG: I can hear you but 3 you're clipping. And when the gentlemen who is 4 facilitating speaks, we can hear him very well. 5 MR. GREGG: We're sitting right next to 6 it. 7 MS. LICHTENBERG: It may have something 8 to do with the mikes or cross-talk of some sort. 9 MR. LONERGAN: I can move that mike over 10 there and they can -- 11 (There was a discussion off the record.) 12 - - - 13 MR. GREGG: So do we want to make 14 comments on the new items? 15 MR. DENNISTON: Well, right now we're 16 kind of in the dark on the new items. We haven't seen 17 what they are going to propose with subloop, dark fiber or 18 line sharing. 19 So our comments are, we would like to see 20 it as soon as possible. My understanding is that it's not 21 ready to be seen yet. So I don't know where we go with 22 this other than, I think we should put this in a parking 23 lot until we see the tariff or a draft of the tariff. I 24 don't know how else to do it. 25 MS. FENNELL: And I guess we had

300 1 anticipated that once those were out, that we would have 2 more meetings to discuss it. So -- 3 MR. ALEXANDER: Well, on line sharing 4 there's an ongoing trial of line sharing. And I know AT&T 5 has attended some of those meetings; that SBC is having a 6 regional test of line sharing. And I know that there is 7 not a test office for line sharing in Michigan, but 8 there's one in Illinois. 9 And the offices that were selected were 10 selected on a collaborative basis across the entire SBC 11 territory and the CLECs, the data selected the office they 12 wanted the trial in. It happened to be in Chicago. 13 There was no request by the CLECs at 14 SBC's collaborative meetings to get a line sharing office 15 in Michigan. So if there had been a demand for that, it 16 probably would have accommodated. But to my knowledge 17 there was not a request to trial line sharing in Michigan. 18 But there is ongoing trials with a number 19 of CLECs in a number of cities with line sharing. So 20 information is being shared through those channels of 21 people participating in those various committees on line 22 sharing. 23 MR. GREGG: Again, could you make sure to 24 you tell your name before you speak. 25 MR. ALEXANDER: Sure.

301 1 MR. BENNETT: This is Bruce Bennett from 2 AT&T. Just a point of clarification on that. 3 In those trials, it's my understanding 4 that Ameritech is not supporting line sharing in 5 conjunction with UNE-P. 6 Do you intend to do that with the tariff 7 that you're going to offer? 8 MR. ANDERSON: Bruce, I think our 9 position on that is and will be, that under the FCC's 10 order on line sharing, paragraph 72, they clearly state 11 that the only situation where there is an obligation to 12 provide line sharing is where the ILEC has the voice 13 service on the line. And that obviously is not the case 14 with UNE-P. 15 I think the FCC was just explicit. I can 16 read you the language -- I have it right here -- in which 17 they address it. But I think you know that's been our 18 position and will be our position. We can discuss it, but 19 I think the FCC has clearly addressed it. 20 But fundamentally the point is that where 21 the ILEC has the underlying loop, it has the obligation to 22 share the higher band. But the FCC has said where the 23 ILEC does not provide the voice service over that loop, 24 that the CLEC can purchase that loop itself and if it 25 wants to share or split the service, it can do it itself.

302 1 But the ILEC doesn't have the obligation 2 in the case of the UNE-P to offer line sharing. 3 MR. BENNETT: The short answer is no? 4 MR. ANDERSON: Consistent with the FCC, 5 no. Yes. 6 MR. BENNETT: I'm not going to retort to 7 that. But obviously we have a fundamental disagreement 8 about what the FCC order says. But I just wanted to 9 clarify that. That won't be part of this offering. 10 MR. ANDERSON: When either in the UNE-P 11 or when the line sharing comes out, it will not apply on 12 the UNE-P. 13 Is that right, Scott? 14 MR. ALEXANDER: That's right. 15 MR. BENNETT: Thank you. 16 MR. DENNISTON: A follow-up on that 17 comment, Craig. 18 Is Ameritech going to be offering line 19 sharing underneath an EEL's situation. 20 MR. ALEXANDER: I guess I don't 21 understand that request in terms of what are you 22 describing as an EEL in that. 23 MR. DENNISTON: A loop of transport 24 combination. 25 MR. ALEXANDER: I think Craig just

303 1 answered that. Under a UNE-P, which is a loop and a 2 transport, two loops switching transport combination, it 3 doesn't apply. 4 So if the ILEC is not providing the 5 voice, then the line sharing order doesn't require that. 6 MR. ANDERSON: Which would be the case in 7 an EEL situation. It would be the CLEC has purchased the 8 loop itself and the ILEC doesn't have the underlying 9 voice. 10 MR. LONERGAN: Anything else on new 11 items? 12 MR. DENNISTON: Well, how do we follow up 13 with that then? 14 MR. LONERGAN: I guess I assume that 15 Ameritech will subsequently file two more tariffs, 16 correct? 17 MS. FRENTZ: That's correct. 18 MR. LONERGAN: One that's due May 17th. 19 So if we file sometime prior to May 17th -- and the second 20 one on line sharing is due June 5th. So that would be 21 submitted sometime prior to June 5th. 22 I guess I would see the Commission order 23 that calls for a collaborative discussion of that still 24 applying to those tariffs as well as the one we have in 25 front of us today.

304 1 So your comment about putting it in a 2 parking lot, I guess, is appropriate. We will set it 3 aside, but we will come back to it. 4 I would just encourage Ameritech, as soon 5 as it can, to file those tariffs. Not necessarily wait 6 till the day before the deadline. 7 But I guess we will come back to those 8 and attempt to deal with them here. I trust this 9 proceeding will still be going on. If not, the option 10 still exists for anybody, any party that wishes to take it 11 in a different direction through a complaint or 12 application, they can get into a different proceeding. 13 And that may or may not happen, depending on what's 14 happening elsewhere in terms of the testing and so on. 15 So since it's not in front of us, I don't 16 know that there's anything that we can really deal with 17 today. But I would agree to convening a further 18 collaborative at such time as we can do that. 19 MR. ANDERSON: And I would add, I think, 20 maybe this is one of those issues where there may be a 21 fundamental difference. 22 Bruce, as you pointed out, AT&T disagrees 23 with what we believe the FCC order says. And we can talk 24 about that. But I think that may fall in the category and 25 I don't want to subject everybody at this table to hearing

305 1 the lawyers argue. 2 I would like to maybe set that issue 3 aside, at least for now, and try to focus on some of the 4 operational issues that we can hopefully address and reach 5 resolution on. 6 MR. BENNETT: I agree. 7 MR. GREGG: Would it be better to deal 8 with that issue like now or wait until the tariffs are 9 filed and then try to deal with that issue? I mean, not 10 in this collaborative, but at this time. 11 MR. BENNETT: I think it would be better 12 to see the tariffs, personally, and then deal with the 13 issues once we see the tariffs. 14 MR. ANDERSON: And, Tom, I will say on 15 the tariffs, keep in mind -- and I appreciate the desire 16 to get the tariffs as early as possible -- but this is a 17 huge product development undertaking on the part of 18 Ameritech as a result of the UNE remand order and having 19 to do the line sharing and thing. And also the people 20 that are doing this, are in part sitting here at the table 21 today instead of back working on the product. 22 So we are going to do it as quickly as we 23 can, but I don't want to lead anybody to believe that we 24 can do it any faster than the FCC has given us the time to 25 do it in.

306 1 Is that a fair statement? 2 MR. ALEXANDER: Yes. 3 MR. GREGG: Okay. Anything else on any 4 of the new issues? 5 Do we want to discuss the provisioning? 6 MR. REIDY: Was Kelly done with the 7 provisioning? 8 MS. FENNELL: I guess I gave our basic 9 position that we feel that these issues really aren't 10 tariff issues ready for or maybe appropriate -- I'm 11 probably not using a correct word here -- for discussion 12 at this collaborative. They will probably be appropriate 13 for discussion at different collaboratives. 14 Provisioning issues could be raised when 15 we do the checklist compliance collaborative. And the 16 customer-friendly manual, as I said earlier, would be 17 part -- the review of that would be part of the OSS test. 18 So it seems to me redundant to do it here 19 and there. 20 MR. DENNISTON: I guess my comment on the 21 billing systems or CABS, my understanding was the present 22 tariff you have, the way I read it, does not allow for 23 CABS. 24 And so if we were to say, well, let's 25 wait for some other aspect of this proceeding, at that

307 1 point someone might say, well, it should have been raised 2 in the tariff proceeding because the tariff specifically 3 addressed billing. 4 MS. FENNELL: Can you point us to what 5 you're looking at, Jim? 6 MR. DENNISTON: Sure. I'll try to find 7 it. 8 MR. ANDERSON: Jim, looking at the 9 summary, paragraph 6, page 4, bottom of the page, you 10 refer to sheet 11. Does that help? 11 MR. DENNISTON: Okay. Yes. On sheet 11 12 it references the daily usage file. And then at the 13 bottom of that paragraph it says: "No other detailed 14 billing will be provided." 15 And to us that would preclude the use of 16 CABS at the billing. At least, that's how we would read 17 that or possibly read that. 18 MR. HAMPTON: There was no attempt at 19 that. The statement here is just basically that the 20 detail, the call detail being provided on the daily usage 21 file is the call detail that we have. 22 Our bill display would, of course, follow 23 the industry standards as those are developed for these 24 particular products. But there was no intent here to 25 state what billing -- this is not a statement of what

308 1 billing system. This has to do with what detail is 2 available as far as the call details. 3 MR. DENNISTON: Are you saying, I guess, 4 just trying to -- are you saying that CABS is available or 5 CABS is not available? 6 MR. HAMPTON: For the ULS-IST product, 7 the billing system that is in place to handle this billing 8 is not CABS. 9 MR. BENNETT: Is that the RBS system? 10 MR. HAMPTON: Yes. It would be the 11 billing for the ULS-IST usage. And the access credit 12 would be out the RBS system. 13 But this tariff does not speak to the 14 billing system or intent of the billing system. 15 The billing system that was chosen has to 16 do with the usage that we have and the utility to create a 17 bill in the time frame committed to for providing this 18 particular service. 19 MR. BENNETT: Maybe it would help if you 20 could clarify whether it's your intent to ultimately move 21 to CABS and bill the whole product off CABS. Or whether 22 it's your intent to continue to send multiple bills for 23 the same product. 24 MR. HAMPTON: For the ULS-IST product, 25 there is no intent to move that to CABS.

309 1 You have to remember that as far as the 2 ULS product is concerned, the life of this product is 3 through October of this year. So for the interim shared 4 transport product, there is no plan to move it to any 5 other billing system. 6 MR. DENNISTON: Do you have a plan then 7 for a tariff to replace the ULS-IST tariff with perhaps a 8 UNE-P tariff? 9 MR. HAMPTON: There is a commitment that 10 we made when we agreed to provide this tariff, that within 11 a year's period of time we would create a long-term shared 12 transport product -- that's different than UNE-P -- a 13 long-term shared transport product that would be in 14 essence similar to the AIN-based shared transport product 15 that Texas provides. 16 MR. DENNISTON: Would it be possible to 17 just have a pure UNE-P tariff without regard to how it's 18 actually provisioned, how Ameritech technically provisions 19 it? You know, use it, create the tariff from the CLEC 20 perspective. 21 The CLEC wants to order UNE-P. Here's 22 what you have to order by, however Ameritech goes about 23 doing it. You know, it's not tariffed. 24 What is tariff though? It's just a UNE-P 25 tariff, without getting involved in the technical details.

310 1 MR. HAMPTON: I guess I'm not sure I 2 understand your question. 3 MR. DENNISTON: I guess -- 4 MS. LICHTENBERG: I'd like to hear this 5 discussion. Can you guys all get closer to the mike? 6 MR. DENNISTON: Sure. I guess my 7 understanding was that the Commission ordered a UNE-P 8 tariff. And what Ameritech produced was a one-page 9 amendment incorporating the ULS-IST tariff. And we're 10 told now, and part of the merger conditions were that the 11 ULS-IST tariff goes away in October. 12 What we're looking for is the 13 unrestricted UNE-P tariff that the Commission has ordered. 14 And can we have such a thing without being geared to 15 ULS-IST and without being geared to your long-term shared 16 transport product that you talked about? Can we just have 17 a pure UNE-P tariff? 18 MR. ANDERSON: If I may, for a moment. 19 And, Jim, I think frankly that's what there is. I mean, 20 UNE platform today offers what is there to be combined and 21 that is loop. 22 MS. LICHTENBERG: Excuse me. Please get 23 close to the mike. I need to hear this. This is Sherry 24 Lichtenberg. 25 MR. ANDERSON: And the UNE-P tariff I

311 1 believe that we have out there does comply with what the 2 Commission required and is simply our offering of the UNE 3 platform. And that is a combination of the loop and 4 ULS-IST, unbundled local switching interim shared 5 transport, as it's required today. 6 Eventually, as you point out, the ULS-IST 7 will transition to what I think Jerry called the long-term 8 unbundled local switching, which addresses some of the 9 issues that have been raised about the interim offering. 10 But fundamentally, our tariffs are 11 intended to simply describe the service offering vis-a-vis 12 the customer. You're right. The tariffs do not go into a 13 lot of the ways we provision the services behind the 14 scenes, such as billing systems. 15 MR. REIDY: Maybe we can ask this a 16 different way. 17 We have an arbitration -- we have an 18 interconnection agreement that was arbitrated, which I 19 don't believe mentions anywhere ULS-IST. Indeed, it 20 mentions a combination of common transport and ULS and 21 loop in a platform in a number of different scenarios. 22 Is this tariff that was filed, is this 23 the realization of that interconnection agreement? Or are 24 we speaking of two different things here? 25 MR. ANDERSON: Number one, tariffs are

312 1 not realizations of interconnection agreements. And I, as 2 you, disagree with the contention that your 3 interconnection agreement provides for the platform. But 4 that's a dispute we have briefed incessantly. 5 But this UNE-P platform that we filed is 6 intended to be consistent with and in accordance with the 7 FCC requirement in the UNE remand order, the merger 8 conditions and this Commission's requirements for the 9 platform. 10 MR. GREGG: Are you saying that your 11 tariff allows the UNE-P for any -- for not just 12 residential services? 13 MR. ANDERSON: The tariff addresses UNE-P 14 for both business and residents. 15 MR. GREGG: Does it allow for both? I 16 don't care if it addresses it. Does it allow for both? 17 MR. ANDERSON: Yes. 18 MR. GREGG: There are no restrictions 19 then? 20 MR. ANDERSON: Well, subject to the "any 21 currently combined issue" which I identified at the 22 outset. 23 MS. LICHTENBERG: This is Sherry 24 Lichtenberg. 25 Am I hearing that there are no

313 1 restrictions on business UNE-P in this tariff? 2 MR. HAMPTON: Other than the currently 3 combined. 4 MS. LICHTENBERG: So I can serve a 5 100-user premise with a UNE-P circuit you all are making 6 available as part of this tariff? 7 MR. ANDERSON: To the currently combined 8 issue. 9 MS. LICHTENBERG: So I can migrate -- 10 we'll talk about the "not yet combined" -- I can migrate 11 any size business to UNE platform under this tariff? 12 MR. ANDERSON: No. There are no volume 13 constraints. 14 MR. HAMPTON: I mean, it's a 15 line-for-line product. 16 MS. LICHTENBERG: That's terrific. I 17 like that. 18 MR. ANDERSON: And I think that goes to 19 the point that was raised in MCI's comments, the reference 20 of the thought that what was intended in our tariff filing 21 was the limited -- I think it was characterized as a 22 promotional offering in the merger conditions -- this is 23 not the case. The restrictions are not from the merger 24 conditions. The limited "promotional" platform is not 25 what's being offered here.

314 1 MR. REIDY: I'm a little confused 2 because, as you might expect I would be, I heard that this 3 platform, whatever we're calling it, this combination of 4 elements is only going to be available until October and 5 will be replaced by what we are all anticipating here 6 which is what is available in Texas, the AIN-based 7 combination of elements. 8 MR. ANDERSON: Right. 9 MR. REIDY: So I'm confused as to what -- 10 your term, this isn't a promotion. It may not be, given 11 your clarification now, what is in the FCC merger 12 conditions, but it is a service that has limited life. 13 MR. ANDERSON: Well, it has limited life 14 because we have committed to changing the existing ULS, 15 unbundled local switching offering, interim shared 16 transport offer in the October time frame. 17 And the only thing that will happen at 18 that point is UNE-P tariff would change in its reference. 19 Where it references today ULS-IST, it will reference the 20 new ULS offering, whatever that's called. 21 MR. DENNISTON: Is that the long-term 22 shared -- 23 MR. ANDERSON: Right. 24 MR. HUTCHINSON: The process of being 25 able to get a combination of loop, switching and transport

315 1 is available now. It will be available then. 2 What we're talking about is changing the 3 ability to do recordings for the long-term solution. It 4 will change some of the rate elements. But the underlying 5 process of having that combination and having customers 6 served by that combination is not going to change. 7 MR. ANDERSON: Does that clarify it, Jay? 8 MR. REIDY: We'll see. 9 MR. DENNISTON: When do you expect to 10 have the long-term shared transport product tariff, at 11 least in draft form, available for us to look at? 12 MR. HAMPTON: It's my understanding that 13 commitment is by October the 8th. So it would be shortly 14 before that. I mean, it's in development right now. 15 MR. DENNISTON: Are you essentially going 16 to take the Texas terms and conditions and tariff them in 17 Michigan and work on the rate elements and make them 18 Michigan-specific? 19 MR. ANDERSON: We're working on the May 20 17th filings. That is aways out. If Jerry can answer. 21 But, I mean, that is a significant -- 22 MR. HAMPTON: I'm not that involved with 23 that offering. Someone else is doing it. 24 MR. BENNETT: Could somebody clarify for 25 me -- this is Bruce Bennett from AT&T -- could you clarify

316 1 for me -- obviously a tariff never has all the detail that 2 a CLEC is interested in when they want to purchase a 3 product from Ameritech. 4 And we utilize your unbundled order guide 5 that's available on TCNet, as well as a lot of other 6 documentation in order to go out and provision a platform 7 for our customers. 8 Could you clarify for me, is the 9 unbundled ordering guide that's on TCNet today updated to 10 reflect this tariff? Is that information correct 11 information to support this tariff? 12 MR. HAMPTON: Yes, it is. 13 MR. BENNETT: Thank you. 14 MR. HAMPTON: It was placed in there at 15 the same time that we put the tariff out there. 16 MR. BENNETT: So what the unbundled 17 ordering guide says is that you will support -- going back 18 to billing which is, I think, where we started this 19 discussion -- the unbundled ordering guide says that 20 you're going to send a carrier two separate bills. 21 And the fundamental problem I have from a 22 carrier perspective is that you are sending us two bills 23 for one service. And I'm just wondering if that gets 24 corrected -- when we move to the long-term platform that 25 you're talking about, will you be supporting the UNE-P

317 1 platform with a single bill off of CABS or is that not 2 your intent? 3 MR. HAMPTON: Well, I guess I would have 4 to challenge the first part of it in that it's not one 5 service. You're getting a combination of two unbundled 6 elements. We still have to bill those two unbundled 7 elements. So we follow the billing procedures for those 8 two unbundled elements. 9 MS. LICHTENBERG: This is Sherry 10 Lichtenberg. 11 I am now very confused because you're 12 telling us that these are elements that are already in 13 combination. Therefore, how come you're billing us 14 separately? 15 MR. HAMPTON: The elements may be in 16 combination, but there's still two separate unbundled 17 elements. And the billing structure, by the Commission 18 and other places, is that we still must continue billing 19 for the loop and we need to bill for the unbundled port 20 and the shared transport. 21 So actually there's three different 22 things that you're being billed for. You're being billed 23 for the loop. You're being billed for the unbundled local 24 switching and you're being billed for the shared 25 transport.

318 1 It happens that the unbundled local 2 switching and shared transport have to both be billed out 3 of the same billing system so they can be placed on the 4 same bill. 5 The loops is not billed out of the RBS 6 system. It's billed out of CABS. And so therefore it's a 7 separate bill. But the rate elements, the rate 8 structures, all of those things, just because they are a 9 combination of elements, doesn't change our requirement to 10 bill for those separate elements. Okay. 11 So you're still billing for separate 12 elements, even though what you have is a combination of 13 those elements. 14 MS. LICHTENBERG: Some of those must come 15 out of CABS and some out of CRIS? 16 Could we take a break while we get the 17 new mikes set up? 18 (A recess was taken.) 19 - - - 20 MR. LONERGAN: Let me just encourage, 21 since we have made no improvements, encourage you to use 22 the microphones that are on the tables as much as 23 possible. That will help a little bit. 24 There is no place to plug it in. It's a 25 model A.

319 1 MR. DENNISTON: I think Sherry was 2 talking last. Sherry, you mentioned something about CRIS. 3 Are you there? 4 MS. LICHTENBERG: About this multiple 5 billing, is this billing coming to us from two or more 6 systems? Is there a CABS bill and also a CRIS bill 7 to cover the loop, the switching and the transport? 8 MR. HAMPTON: You would receive a bill 9 out of the CABS billing system for a loop. And you would 10 receive a bill out of CRIS actually through our RBS leg of 11 CRIS that would provide you a bill for the unbundled local 12 switching and the interim shared transport. 13 MS. LICHTENBERG: And when do you plan to 14 switch to the OBF guidelines, which I believe call for all 15 of this to come from CABS? 16 MR. HAMPTON: I guess I'm a little 17 surprised. Normally OBF doesn't determine what billing 18 system. It gives the billing structure of the output. 19 MS. LICHTENBERG: I believe that they 20 have specified CABS billing. I could be wrong. I know 21 that in other companies we do receive CABS billing for 22 each of these elements. 23 MR. HAMPTON: I understand. I personally 24 don't know of any plans right now to move anything. 25 Definitely not for the ULS-IST product. It's such a

320 1 short-term product that by the time you would even get it 2 scheduled into a schedule, it wouldn't happen. 3 I don't know what the plans are for the 4 long-term. I'm not currently involved with that 5 particular effort. So I don't know for sure where they 6 are going with that. 7 I know there's, as a result of the 8 merger, there's a lot of work going on to merge system and 9 get everything in the same billing system. I don't know 10 how that is being discussed regarding platform and its 11 billing structure or the billing of the elements that 12 constitute the platform. 13 So I can't tell you that I know of any 14 plans to merge them together. I can tell you I do know 15 that even for Texas, their platform product is billed out 16 of two different systems. 17 MS. LICHTENBERG: I believe that we 18 receive in Texas only CABS' bills for the wholesale 19 portion. We also receive a daily usage fee for customer 20 usage. 21 I will check on that with my folks, but I 22 have never heard that we are receiving CRIS billing for 23 switching and transport. 24 MR. HAMPTON: No. It's not for the 25 switching and transport. But it's my understanding, and I

321 1 don't know all of the details, but in the conversations 2 that I was involved with early on with the merger efforts, 3 there are some things like directly listings, those type 4 of things, that wind up getting billed out of their CRIS 5 system as well. 6 MS. LICHTENBERG: That's a very different 7 animal than switching and transport. 8 But rather than belabor this point, let 9 me ask one more question. And perhaps it was asked during 10 a point when I couldn't hear, so I apologize in advance. 11 We are looking here at a tariff for a 12 product that will be subjected to third-party testing but 13 will disappear from the world in October, if not sooner. 14 Is there any way that we can avoid 15 spending resources for a product that is not going to 16 exist, and I assume, will not even be the subject of any 17 going-forward work by Ameritech? 18 MR. HAMPTON: I guess from my perspective 19 the decision whether to spend resources to purchase this 20 product or not is really your decision. 21 MS. LICHTENBERG: I'm actually speaking 22 more towards third-party testing which will test something 23 it appears that will cease to exist almost immediately. 24 And perhaps we'll take that up in the third-party testing 25 venue.

322 1 I would assume though that you if you are 2 bringing in a new product, you would be able to tell us 3 almost immediately what that new product is going to look 4 like. 5 MR. ANDERSON: Sherry, I agree with you 6 that I think that issue comes up -- this is Craig 7 Anderson. I'm sorry -- comes up in the context of OSS 8 testing. 9 And let me just reiterate what Joe Rogers 10 mentioned at the very first meeting, is that there are 11 developments coming down the road, not only this one but 12 others. And if indeed the suggestion is being made that 13 we shouldn't even begin testing until all these 14 developments are in place, this whole process is not going 15 anywhere because all these changes aren't going to be in 16 place until, I think, Joe said 2003. 17 I mean, there are planned changes going 18 forward all the time. And our position is that we don't 19 need to, nor should we delay testing, if we can begin 20 testing now and test the changed management process. 21 But I agree -- 22 MS. LICHTENBERG: I don't disagree with 23 that. On the other hand, and again, we'll take this up, I 24 think, in the third-party testing, this is the crux of the 25 entire issue because this is the product that CLECs will

323 1 offer and it's going to cease to exist. 2 But we'll take that up in the proper 3 venue. 4 MR. BENNETT: Could I just -- following 5 up on Sherry's questioning -- could I just ask that 6 perhaps, Craig, if Ameritech could review for us what the 7 plans are with regard to implementing billing for the 8 permanent platform, as you described it, and let us know 9 if there's going to be a single CABS' bill or if you 10 intend to continue providing two separate bills once the 11 interim platform is done away with. 12 MR. ANDERSON: We'll track that down. 13 MR. BENNETT: Thank you. 14 MR. DENNISTON: I guess I have a question 15 about the transition from the ULS-IST product to the 16 permanent shared transport product. 17 As I understand Ameritech's position, and 18 correct me if I'm wrong, the present ULS-IST tariff 19 changes that are made as a result of the collaborative 20 process will remain in place until October when Ameritech 21 will then say it's going to be replaced with another 22 tariff. 23 If CLECs have a problem with this 24 brand-new tariff, we'll have to go through an extended 25 process under which we are buying from the tariff before

324 1 we get needed changes made. 2 Can we set a process to have us take a 3 look at the tariff, resolve all concerns about the tariff, 4 have the Commission rule on these concerns, so that come 5 October 1 or whatever there is a firmness and a permanency 6 to the tariff that's in place on that date. So that CLECs 7 are not disadvantaged and everyone has a better idea as to 8 what things to look forward to in the long term, without 9 having an interim period where we would be stuck with a 10 product that might have serious flaws. 11 MR. ANDERSON: This is Craig Anderson. 12 Number one, I think that by October I 13 would hope that this proceeding has been concluded. Maybe 14 I'm overly optimistic. 15 But the process in Michigan for tariff 16 filing and implementation is what it is. And it is 17 fundamentally a file and use process. 18 And there are certainly processes by 19 which parties can address issues with tariffs after the 20 fact. But we have to file this tariff in October. 21 And I guess you're saying, well, can you 22 give us a preliminary tariff? And as I indicated, I don't 23 think we're going to be able to do that as a practical 24 matter. We will work, to the extent we can, 25 collaboratively going forward with regard to these issues.

325 1 But I don't think we can commit to say 2 we're going to agree to a fundamental change in process 3 that this Commission uses or law that says that all 4 tariffs have to not only be preapproved by the Commission, 5 but be negotiated in advance with everybody who might be 6 interested. That's not how tariffs work, Jim. 7 MR. DENNISTON: If we're serving 8 customers off of this ULS-IST tariff or the UNE platform, 9 we're serving them in the few months from now. And we 10 have so many thousand customers. Come October 1 you're 11 saying that all of the terms and conditions underneath 12 which we are obtaining service to provision to these 13 customers is all going to change. And we have no insight 14 ahead of time as to what those changes are going to be. 15 MR. ANDERSON: Number one, I don't think 16 it's a fair statement to say all those terms and 17 conditions are going to change. Fundamentally, what is 18 changing is they're adding a billing capability to the 19 service. 20 Maybe I'm oversimplifying it and I don't 21 understand all the details. But it's not a complete 22 change and it's not a completely different product. It's 23 still unbundled local switching. But it has the recording 24 capabilities to allow you to record access. 25 MR. DENNISTON: Is there a way of having

326 1 an umbrella type of tariff that would cover both 2 circumstances, you know, the present ULS-IST and whatever 3 it is you plan on having in October, so that we can just 4 order UNE-P underneath that one tariff and it would be 5 covered by whatever system changes you had in place 6 between now and then? 7 MR. ANDERSON: I think that's what the 8 tariff will do. 9 The only change that I would anticipate 10 in the UNE-P part of the tariff is instead of referencing 11 the ULS-IST tariff, it will reference the new long-term 12 tariff. 13 MR. BENNETT: What's your intent with 14 regard to allowing -- just following up on that -- what's 15 your intent with regard to allowing CLECs to be an access 16 provider when they're using the platform in the long-term 17 offering? 18 I mean, when you say nothing is going to 19 change, I assume that in the new tariff that comes out in 20 October, I assume, you know, based on the fact that you 21 put in AIN that you network and that you can now record 22 usage, that you are going to let CLECs be the access 23 provider when they use the platform. 24 MR. ANDERSON: And that's true today. 25 MR. BENNETT: That's true today under

327 1 this tariff? 2 MR. ANDERSON: Right. It's just that 3 we -- 4 MR. BENNETT: No. Today you give it to 5 CLECs as a credit under this tariff, right? You credit 6 access. Well, I should stop and ask you how you deal with 7 that in today's tariff. But it's my understanding that 8 what you are doing is you're giving an access credit in 9 the bill. 10 MR. HAMPTON: Right. But as far as your 11 concern when you order that port, you select what the 12 carrier is. When we get down into really discussing this 13 ULS-IST, one of the fundamental problems we had with 14 providing shared transport was the fact that there are no 15 recordings that we have that exist in the network today 16 that we can identify that that usage originated from a ULS 17 port. 18 So in order to deal with that problem in 19 the network -- in order to provide a shared transport 20 product, the customer still picks who the carrier they 21 want it to go to. 22 We can't provide you a record so that you 23 can bill the carrier. So we provide an average usage on a 24 line port and give you that money back. 25 MR. BENNETT: But I was simply getting to

328 1 Craig's point that nothing is going to change on October 2 1st. Obviously, there are going to have to be tariff 3 changes made to reference the fact that now you're going 4 to allow us to bill the access to the end user. 5 What you have in there today is a rate 6 that is an offset rate giving us an access credit. And 7 when it goes forward, it's going to be something different 8 than that. 9 And I can probably come up with five or 10 six other examples of kinds of changes like that that 11 would have to go into effect in the long-term tariff. 12 I think Mr. Denniston's point simply was 13 that we would like to get an understanding of what that 14 long-term platform looks like come October 1st, rather 15 than speculate what that might look like, to understand 16 whether CLECs have to change their systems, change the way 17 they bill things, change the way they provision things 18 come October 1st. 19 MS. LICHTENBERG: This is Sherry 20 Lichtenberg. 21 I would echo that. Just from listening 22 to this discussion, it appears to me that we would have to 23 make massive changes to our billing systems based on these 24 changes and fees. 25 And again, I would suggest that you all

329 1 must already be in the planning stage for this because 2 there will be big changes to your systems. And it's 3 already almost April. 4 MR. HAMPTON: We are in the product 5 development cycle, that is correct, determining what the 6 product will be. 7 MS. LICHTENBERG: When will you have your 8 requirements written? What does your cycle look like? 9 MR. HAMPTON: I don't know that. I'm not 10 involved with that cycle. 11 MS. LICHTENBERG: If I could ask that 12 that question be put on the table here. I know, at least 13 from MCI WorldCom, we write our requirements at least six 14 months in advance. So I would assume you all do something 15 similar. And if we saw those requirements, it would help 16 us quite a bit. 17 MR. HAMPTON: I guess the other part 18 though is, I guess it was my understanding from my 19 perspective, our commitment is that basically the product 20 that we will do will be substantially similar to that in 21 Texas. 22 So in essence what you're going to see is 23 the billing elements providing you a record for access. 24 Those types of things are all in line with that commitment 25 to have the product that is similar to the product that

330 1 exists in Texas. 2 MS. LICHTENBERG: So help me understand 3 that. You will be adopting the complete Texas UNE 4 platform or you will be adopting some pieces of the Texas 5 UNE platform? 6 MR. HAMPTON: Our discussion really isn't 7 platform. Our discussion really is shared transport which 8 is a piece of the platform. Our commitment was that the 9 shared transport that we would provide as part of the ULS 10 product would be substantially similar to the shared 11 transport provided in Texas which is also a component. 12 MS. LICHTENBERG: And again, I apologize. 13 I was an English major. What does "substantially similar" 14 mean. 15 MR. HAMPTON: I'm not developing the 16 product. So I wasn't the person who made the commitment 17 either. 18 MR. HUTCHINSON: I think it's safe -- 19 this is Jeff Hutchinson -- I think there's some rough 20 things that it's safe to say from a network provisioning 21 standpoint those customers that are out there, nothing is 22 going to happen. 23 MS. LICHTENBERG: I'm sorry. This sounds 24 important. Could you get closer to the microphone. 25 MR. HUTCHINGSON: How is this? Can you

331 1 hear me? 2 MS. LICHTENBERG: That's excellent. 3 Thank you. 4 MR. HUTCHINSON: Good. 5 I hear a lot of concerns. I'm not quite 6 sure what they are founded in. But the customers that 7 have this service, their service is not going to be 8 interrupted in any way when all of a sudden the long-term 9 solution for the shared transport portion of the platform 10 goes into effect. 11 I think you guys know that you're going 12 to get the ability to bill the access. Yeah, there are 13 going to be billing changes. Yeah, you do this process 14 already in Texas. Yeah, there will be a lot of details 15 that will need to be worked out. But the platform is 16 going to remain out there. There will be probably some 17 changes in the ordering process. And we're developing 18 that now. 19 But there seems to be -- I mean, the 20 astuteness of your questions indicates that you understand 21 the process. We're developing it and it sounds like you 22 would like to be part of the development process. 23 MS. LICHTENBERG: This is Sherry 24 Lichtenberg. 25 I think the biggest question that I have

332 1 in my mind -- and I understand there is a development 2 process and yes, we would like to be part of it -- is will 3 I in November when the interim shared transport goes away 4 and the real shared transport appears, will I have some 5 customers being billed one way and other customers being 6 billed another way? 7 It's going to be very hard to manage a 8 customer set with two different sets of billing. And what 9 I haven't heard, and perhaps this is a subject for a later 10 discussion, is the way in which the issues like that will 11 be dealt with. 12 MR. HUTCHINSTON: And that's quite a 13 reasonable question. I mean, you don't want to have half 14 your customers being billed to the old ULS-IST process and 15 half of them being billed under a new process. 16 And I guess your last statement that it 17 might be better for a later discussion, I think is a good 18 one because we don't have the gentleman here that is 19 heading up that development process for the new product, 20 which is why we don't have a lot of those transition 21 questions, the answers to those questions for you today. 22 MS. LICHTENBERG: Would you be amenable 23 to noting in this tariff that a real product is coming and 24 its due on X date? So that we understand and have some 25 sort of a hook to live with?

333 1 MR. ANDERSON: Sherry, this is Craig 2 Anderson. 3 I think you have the hook in the merger 4 conditions. I mean, we're obligated to do it. And I 5 don't think putting anticipated changes or some reference 6 to anticipated changes is the kind of thing that normally 7 goes in any tariff. 8 MS. LICHTENBERG: The major reason I ask 9 is that I also had a hook in Bell Atlantic for uniform 10 interfaces and we had to litigate it two years after it 11 happened. 12 MR. ANDERSON: I can't defend Bell 13 Atlantic. I'm sorry. Or I won't. 14 MR. BENNETT: Sherry, there is Bruce 15 Bennett. 16 I bet you have a lot of other questions 17 that you would like to get answered about the product, and 18 I certainly do. But perhaps it would behoove us to sort 19 of move on and get through the rest of the series of 20 questions besides billing that we have. 21 MS. LICHTENBERG: I agree and I'm sure 22 you guys are really sorry that I can now hear. 23 MR. HUTCHINSON: Essentially, we're 24 looking at a tariff package that is the interim solution. 25 And if we can deal with the problems that you see with

334 1 that product, that would be good. 2 MR. GREGG: This is Rod Gregg. I have 3 one more question that I have to go back to kind of. 4 On your package on part 19, section 15, 5 the original sheet 1, on the second paragraph there you 6 talk about that all the terms, conditions, regulations and 7 application of rates/charges as well as the rates and 8 charges themselves contained in sections 2 and 14 of this 9 part apply to this section, unless expressly provided to 10 the contrary as specified below. 11 That concerns me because in section 14 on 12 the original sheet 1 it says that -- it has that these 13 UNE-Ps are as of the FCC and then also of the SBC merger 14 conditions. 15 Well, it's my understanding that the SBC 16 merger conditions limit it to just residential customers. 17 Is that true? Or do we need to fix this tariff to take 18 that exception out? 19 MS. LICHTENBERG: This was the reason for 20 my question about the number of lines that UNE-P was 21 allowed to. 22 Am I correct in understanding that 23 Ameritech is offering UNE-P to a wider spectrum than the 24 319 remand decision has? 25 MR. GREGG: They seem to have answered it

335 1 that they are. So we need to change this tariff to 2 reflect that? 3 MR. HUTCHINSON: I understand the 4 confusion. The confusion is when you look at this 5 language you say, well, gee, doesn't this mean that this 6 is the merger offering and don't all the conditions 7 associated with the merger offering therefore flow with 8 this? 9 And we would be glad to clean up this 10 tariff language to clear up any confusion on that. 11 Because the ULS-IST offering or CPO offering or the 12 combined platform offering, that is offered through the 13 merger conditions with all the limitations that are 14 associated with that. 15 MR. BENNETT: Can I just revisit one of 16 my earlier questions then? 17 On your TCNet board, the unbundled 18 ordering guide, you have a lot of reference to CPO. And I 19 asked a question earlier about whether or not the 20 unbundled ordering guide which was on TCNet was a 21 description of the support for this product and this 22 tariff. And I think you told me yes. 23 MR. HUTCHINSON: Right. 24 MR. BENNETT: So throughout that ordering 25 guide, the restrictions that we have been talking about

336 1 today are included in that ordering guide? 2 MR. HUTCHINSON: Right. 3 MR. BENNETT: So would it be your intent 4 to take those restrictions out and so to clarify for CLECs 5 that those restrictions don't apply to this product? 6 MR. HUTCHINSON: I think you are just 7 looking in the wrong place on TCNet. The CPO that is on 8 TCNet is the merger offering. And the ULS-IST portion of 9 the unbundled ordering guide is where you need to go. 10 MR. BENNETT: Somebody else can ask a 11 question. 12 MR. HUTCHINSON: Because it's very clear 13 in the CPO offering, the residential restrictions are very 14 clearly outlined in that. But as I said, that offering is 15 the merger offering that you're looking at. 16 MR. BENNETT: So what's the product 17 offering that is supported by the staff? Where do I find 18 that in the unbundled ordering guide? 19 MR. HAMPTON: In the ULS-IST section. 20 MR. BENNETT: In the ULS-IST section? 21 MR. HAMPTON: Right. 22 MR. GREGG: Can we move on to, I believe, 23 other issues now? 24 MR. REIDY: Let me just -- the lawyers 25 have to weigh in just a little bit here.

337 1 You know, we have had a long discussion 2 about this and it's all tracing back to federal law and to 3 the FCC orders. 4 I don't want my silence to indicate here 5 that, you know, there's a much larger issue of state law 6 authority here that is not, as far as I can tell, even 7 referred to in the Ameritech tariff. 8 But I think that's one of those issues, 9 Craig, that you indicated we probably don't need to talk 10 about today. 11 MR. ANDERSON: I think it's a legal 12 issue. Certainly and typically, our tariffs don't refer 13 specifically to state law versus federal law. 14 MR. REIDY: Then I guess what I need an 15 explanation on -- and we can table this -- but I would go 16 to sheet number 2 of section 14. And in that first 17 paragraph at the top of the page it says: "ULS-IST 18 described herein shall be automatically without notice 19 suspended as of the date of such termination or order or 20 finding and shall not apply to any product or service 21 subscribed to." 22 And I think the order being referred to 23 there is in some manner -- if the federal requirements for 24 whatever you make of them for ULS-IST are in some way 25 either diminished or eliminated, then Ameritech is

338 1 reserving the right to eliminate this product ordering 2 kind of unilaterally and without notice. 3 I don't know how that jives with the 4 Commission's order in 12143 and 12320. And I'll track 5 back all the way to arbitrations, saying you've got to 6 give us a platform. 7 So we're back to this problem, even if 8 you are going to replace ULS-IST with another product 9 offering in October, that doesn't solve my problem on a 10 legal basis with. You don't appear in my mind to be 11 tariffing the product that the Commission has ordered you 12 to do. 13 I understand this is a matter in the 14 appellate courts and we don't discuss it now. But that 15 issue is still there. 16 MR. LONERGAN: Let me just maybe address 17 on behalf of the Commission. 18 I think the Commission's order setting 19 this proceeding up pretty clearly said you must satisfy 20 our requirements, not only FCC requirements, in order to 21 get an affirmative recommendation on 271. 22 So whatever that means in specifics in 23 terms of the language of the tariff, I'm not sure. But 24 I'm just saying that's my perception of what the 25 Commission said.

339 1 MR. ANDERSON: And we recognize that 2 absolutely. 3 But keep in mind, the interim shared 4 transport offering when it was initially filed, was filed 5 pursuant to the merger conditions and it was recognition 6 that our network at the time did not allow for the access 7 billing situation that Jerry described. And we committed 8 in the interim to offer the interim shared transport and 9 by October of this year to offer the long-term shared 10 transport, and offered it. 11 Now, this says -- the language you 12 specifically referenced said that if the merger conditions 13 were not approved. And that was the intent of that 14 language. 15 Keep in mind that this was filed, I 16 believe, before the merger, September 30th, last year. 17 That condition, if you will, is passed. 18 MR. DENNISTON: Would it be okay then to 19 just delete that paragraph? 20 MR. ANDERSON: I think we can clean it 21 up. I don't know about -- 22 MR. REIDY: I think it needs to be 23 cleaned up. You know, practically looking at it, this 24 tariff has been on file since September of 1999. MCI 25 would have dismissed its complaint in 12143 if it thought

340 1 that the platform that was required under Commission's 2 orders. So -- 3 MR. ANDERSON: Well, the UNE remand order 4 came out after that too. 5 MR. REIDY: I think we can table the 6 conversation. I'm willing to debate it all day obviously. 7 But I don't think you guys want to listen to us. 8 But the point here is that, don't let my 9 silence -- it's not silence anymore -- but I'm not sure I 10 agree with your analysis. I don't think that we're as far 11 along as we need to be yet. 12 Limiting that paragraph might be some 13 help. 14 MR. LONERGAN: I think we're here today 15 hopefully with the end result that portions of this tariff 16 that are not where they need to be, from the point of view 17 of us collectively or from the Commission or whatever, 18 that there will be changes made. 19 So presumably what we need to do when the 20 day is over is to have identified those areas where 21 collectively you are asking for changes. And then 22 Ameritech presumably will go back and try to satisfy those 23 if they can. 24 MR. REIDY: And I suppose, to end on that 25 point, it would be helpful if we're going to schedule

341 1 another meeting of this collaborative, that if the 2 decision is made to modify the tariff, obviously in light 3 of some of the concerns that we have expressed, that we 4 try and get that done before the next meeting so that we 5 can have a fruitful discussion next time around. 6 MR. LONERGAN: I would think that would 7 make sense. 8 MR. GREGG: All right. I think, or at 9 least I had planned to have Ameritech do any revisions 10 they are willing to do by a certain date. And then if 11 they are willing to do that, we meet -- I think our next 12 scheduled meeting is the 13th. So if they are willing to 13 do some revisions, we'll meet then. If they aren't, we 14 won't be meeting then. 15 MS. FRENTZ: And did you let us know a 16 date when you were looking at, or are you just making this 17 up now? 18 MR. GREGG: We're thinking about in a 19 week. But we'll have to schedule a date at the end of 20 this. 21 MS. FRENTZ: All right. 22 MR. GREGG: Shall we go on to the other 23 issues now? 24 MS. FENNELL: The next group was sort of 25 a miscellaneous category.

342 1 MR. GREGG: Kelly, can you use the mike. 2 MS. FENNELL: I'm sorry. Now I'm really 3 loud. 4 The other issues, categories were sort of 5 a miscellaneous where we didn't have any other category to 6 put them in. 7 The first one was EELS. I believe there 8 was a couple of parties who requested that EELS be 9 reflected in the tariff. And our position on EELS is 10 based on the UNE remand. 11 The UNE remand said that EELS were only 12 required to be offered where we were not offering 13 unbundled local switching. And since we're offering local 14 unbundled switching everywhere, there is no requirement 15 for EELS. So that is why you don't see EELS in our 16 tariff. 17 MS. LICHTENBERG: That was not my reading 18 of the UNE remand. This is Sherry Lichtenberg. 19 Does everyone else read it that way? 20 MR. DENNISTON: Sherry, I'll agree with 21 whatever you say. But I don't have the order in front of 22 me. But we absolutely reserve our right to dispute 23 Ameritech on this position. 24 MR. HUTCHINSON: This is Jeff Hutchinson. 25 I think very clearly in the UNE remand

343 1 order they said that they decline at this time to 2 specifically identify the EEL as an unbundled network 3 element. And I think that's almost verbatim. 4 MR. ANDERSON: Paragraph 478. 5 MR. HUTCHINSON: Yes, it was. And if you 6 like, I can read it. It says: "We decline to define the 7 EEL as a separate network element in this Order." 8 And in terms of when we are required to 9 provide it, I think they were just as succinct about that 10 also. And that has to do with when we do not offer 11 unbundled local switching within the top 50 MSAs for 12 customers with four or more lines. 13 MS. FENNELL: There's one more, but I 14 can't remember. 15 MR. HUTCHINSON: Off the top of my head, 16 I'm sure you guys know. 17 MR. BENNETT: I forgot to ask one of my 18 questions under provisioning. 19 Are you supporting MLT testing under your 20 current offer and the long-term offer in your platform? 21 MR. ALEXANDER: If in our plan of record 22 document which was filed -- maybe you are familiar with 23 that document -- 24 MR. ANDERSON: Scott, I don't think 25 everybody is necessarily -- so if you could share for the

344 1 group what the plan of record is. 2 MR. ALEXANDER: As part of the merger, 3 most of the commitments -- there was a document prepared 4 and made available called the OSS plan of record. And 5 that document is rather comprehensive and has a lot of 6 information about current method of operation and future 7 method of operation. 8 But to your point, in the current method 9 in the Ameritech states, MLT is not available on the loop 10 or combination, but it's part of the future method of 11 operation, which according to the plan of record is 12 supposed to be available in the first part of April. 13 So we have checked back with some folks. 14 And as far as we know, that's still on track. So that 15 within a couple weeks here, there should be MLT available, 16 based on the plan of record commitments. 17 By the time we come back to the mid-April 18 collaborative, we can provide a report, status report, to 19 ensure that that implementation is occurring according to 20 that schedule. 21 MR. BENNETT: I can't recall, is that 22 commitment included in your tariff today, that by such and 23 such a date you will support MLT testing for maintenance 24 purposes? 25 MR. ALEXANDER: I don't believe that's in

345 1 the tariff. That's in the plan of record. 2 MR. BENNETT: I assume you would be 3 willing to enhance the tariff to include something like 4 that then? 5 MR. ALEXANDER: Well, the issue there is 6 a lot of times tariffs typically don't talk about what 7 maintenance and provisioning and testing capabilities are 8 available with a particular product. 9 MS. LICHTENBERG: This is Sherry 10 Lichtenberg. 11 I think we need to consider the absolute 12 criticality of this capability. In New York where we are 13 in business, we are doing thousands of MLTs a day to 14 handle customer troubles. 15 So I would suggest that this might -- 16 that this promise, if you will, should be in this tariff. 17 MR. ANDERSON: Well -- this is Craig 18 Anderson. 19 I guess, elaborating on Scott's point, I 20 think typically tariffs don't address that. There are 21 processes. The plan of record is one of them that is 22 addressing specifically how we'll address that. 23 If you're suggesting that that is not a 24 sufficient commitment, I mean, we are stating the 25 commitment here. It will be included in a lot of details

346 1 and provisioning issues that we have to address in the 2 checklist filing. 3 MR. BENNETT: Will you be providing that 4 to us for free then, I take it? 5 MR. REIDY: MLT testing. 6 MR. ALEXANDER: I'm not sure of any terms 7 and conditions on the provision of MLT. So that's -- I 8 know there's other collaboratives and discussions. I know 9 that it's asked. I don't know if it has come up there. 10 MR. ANDERSON: And I would say, Bruce, 11 typically if it is a service that is being offered and 12 there's a price for it, that is the kind of thing that is 13 in tariffs. 14 MR. DENNISTON: From WorldCom, I would 15 also think it should be tariffed for the simple reason 16 that if we have a problem with how it's performed, that a 17 remedy if it's a tariff would be before the MPSC, as 18 opposed to relying on the FCC plan of record. We don't 19 have to go to the FCC to resolve a Michigan-specific 20 dispute. 21 MR. ANDERSON: And there are your 22 interconnection agreements which obviously go into much 23 greater detail than anything in the tariff. 24 MR. REIDY: Of course, we cannot order 25 the platform while for interconnection agreements. At

347 1 least that's what I'm hearing Ameritech's position is 2 today. 3 MR. ANDERSON: Today? That's been our 4 position. That's been going on for three years. 5 MR. REIDY: I was hoping for a change. 6 MR. BENNETT: Actually, that's a 7 reasonable question, I think. The business that Ameritech 8 and AT&T do today is typically done under the 9 interconnection arrangements we have. And a lot of the 10 other support to run a product like this is detailed in 11 those interconnection agreements. 12 And that's why the founders of the act 13 decided to use interconnection agreements instead of 14 tariffs, in my opinion. 15 So is it Ameritech's position that you 16 would be willing to allow us to take this tariff offering 17 that's here in Michigan and incorporate it in our 18 agreement if we wanted to have that? 19 MR. ANDERSON: We're in the process now, 20 our two companies, of negotiating, as I understand. And I 21 would anticipate, yes, would include the platform. 22 MR. BENNETT: We have an agreement today, 23 an effective agreement today. And if I wanted to get an 24 amendment to that agreement, would you be willing to put 25 it in that agreement?

348 1 MR. HAMPTON: The amendments are drafted 2 when we draft agreements for both ULS-IST and platform. 3 MR. BENNETT: And specifically to this 4 Michigan platform is what I'm asking. 5 There's many differences between the two 6 amendments that you have drafted for CPO and ULS-IST and 7 what you're offering out of this tariff. So I'm just 8 clarifying, would you be willing to roll the terms and 9 conditions of this tariff into my interconnection? 10 MR. HAMPTON: The USL-IST -- there is an 11 amendment that's available to you for ULS-IST. 12 MR. BENNETT: I'm familiar with that 13 amendment. 14 MR. HAMPTON: And it's basically 15 identical to this language and this contract. 16 MR. BENNETT: So the answer is yes? 17 MR. ANDERSON: You're in the midst of 18 negotiations. And I know you and Robin Charleston are 19 talking to counterparts that aren't here at the table, 20 Kathy Polter and Jerry Hoskins. 21 I don't want to affect negotiations. 22 MR. BENNETT: I'm not talking about those 23 negotiations at all, Craig. I'm simply talking about the 24 ULS-IST amendment that is out there today and it's 25 different in respects, you know, subject to check if

349 1 you'll take my word on it, its different in respects than 2 what is offered under this tariff. 3 And I'm sure as you enhance this tariff 4 through this process, there's going to be other 5 differences that occur too. And I'm just trying to 6 understand if you would be willing to roll that into my 7 interconnection agreement as it stands today? 8 MR. ANDERSON: I don't see why not. But 9 I just want to check with those folks that are doing the 10 negotiation. It makes sense. If we're willing to offer 11 the ULS-IST, why wouldn't we do it. 12 MR. DENNISTON: This topic kind of blends 13 into another topic we have briefly addressed on and that 14 was Craig's concern that tariffs are not that detailed 15 because usually the details are found inside the 16 interconnection agreements. 17 My concern is that in Michigan the 18 Commission has been clear that you can have 19 interconnection by tariff or by interconnection, or in the 20 case -- I think it's 12035 -- even if you have an 21 interconnection, you can still order out of the tariff. 22 Therefore, in talking about this product, 23 I think it would be important to add the necessary details 24 set forth in the tariff since we truly are allowed to 25 interconnect by tariff, whether or not we have an

350 1 interconnection agreement. 2 And, Bruce, that would alleviate your 3 concern about rolling in the tariff into your interconnect 4 agreement under Michigan law. It's already available. 5 I'll leave that up to your attorney to discuss with you. 6 MR. BENNETT: I think I got my answer 7 from Craig. He said that it's a reasonable thing and he 8 would be willing to do it, subject to check. 9 Just moving on -- 10 MR. ANDERSON: I have gone out on a limb 11 now, Bruce. 12 MR. BENNETT: Thank you. 13 Maybe somebody could clarify this. Maybe 14 I'm looking on the wrong part of TCNet. But on TCNet, as 15 they talk about supporting this product, there's a 16 provision included in there that basically says that you 17 preserve your right to charge for additional things, 18 including engineering, administration, training, 19 publishing, documentation, developing of MYPs, maintenance 20 associated with combining elements. 21 I'm just wondering if those limitations 22 or those preservations of rights under the product guide 23 that's on TCNet, if there's, if that same preservation of 24 rights comes under this tariff that you're offering today. 25 Is it contemplated that you'll charge us

351 1 for those kinds of things under some sort of special 2 to-be-determined rate? 3 The essence of my question is, are all 4 the rates in the tariff war or are you going to charge me 5 other things too? 6 MR. HAMPTON: All the rates are in the 7 tariff that we plan on charging at this point in time. 8 The preservation of rights, when we began 9 development of the long-term product, was basically to say 10 as we went through that product, we determined there were 11 other costs because we didn't -- when we get down into 12 this later on, when we talk about how the rates were 13 created, we took existing rates and used those to create 14 these. 15 The intent was to preserve our right as 16 we developed a long-term product and went through the cost 17 process for that; to not limit our ability to collect our 18 actual costs in providing that service. 19 There is no intent at this point in time 20 to alter this product. What you see is the rates that 21 we're going to charge. 22 MR. BENNETT: So if you were going to 23 charge for those kinds of things in the future, I assume 24 you would go through some kind of TELRIC proceeding to 25 develop the rates for that before you begin charging us a

352 1 CLEC for that stuff? 2 MR. HAMPTON: And there would be a tariff 3 filing to incorporate those into the tariffs. 4 MR. BENNETT: Thank you. 5 MR. HAMPTON. That's correct. 6 MR. ANDERSON: Bruce, to clarify, I don't 7 know that typically the process in Michigan is not 8 necessarily to file ahead of time in a separate 9 proceeding; rather file and use and support what the cost 10 study is for new products and services. 11 MR. BENNETT: And again, the essence of 12 my question was, I'm not just going to see those charges 13 appear on my bill even though that you have preserved your 14 rights to put it on the bill, unbundled ordering guide. 15 Thank you. 16 MS. FENNELL: I'll see if I can talk 17 really loud. 18 Sherry, can you hear me? 19 MS. LICHTENBERG: No. If you could get a 20 little closer. 21 MS. FENNELL: I was trying not to play 22 ping-pong here. 23 MS. LICHTENBERG: Just get right up there 24 to the mike. 25 MS. FENNELL: Under other issues, I think

353 1 we're on billing remedies. And I don't recall who had it 2 in their list, but it was, what do we do, what remedies 3 are there if there are inaccurate bills? 4 And our response back, our reaction to 5 that is the tariff and general regs does have a process, a 6 time limit in there -- and Yvette has it here -- for the 7 records, I know it's in part 2 -- that lays out what you 8 do or how long do you have to identify an inaccurate 9 billing back to us. 10 MS. LICHTENBERG: Could you help me out? 11 And I haven't read those regs. 12 My question is, if you do not provide us 13 the bill in a timely fashion, does this time limit start 14 before when the charge is generated or when we receive the 15 bill? 16 MS. FENNELL: I'll have to take a look at 17 the language to answer that specifically. And then, of 18 course, as to billing timeliness, we do have performance 19 measures on that as well. 20 MS. LICHTENBERG: Yes. And I know that 21 you're trying to -- that we're looking at the Texas 22 remedies, which to us are not acceptable. 23 MS. FENNELL: And we haven't addressed 24 what we call the performance assurance plan yet here in 25 Michigan. So that hasn't -- we haven't really addressed

354 1 that here yet in Michigan on the remedy side. 2 We can get you that tariff reference, 3 Sherry. Yvette is pulling it now. 4 MS. LICHTENBERG: That would be my 5 concern. 6 And I'm sure in the third-party testing 7 we'll learn how one deals with billing inaccuracies. That 8 is, where you send them, etc. 9 MS. FENNELL: Now I've got two copies of 10 it. 11 MR. DENNISTON: Can you tell me the 12 section and sheet number you're on? 13 MS. FENNELL: It's part 2, section 2, 14 sheet 15. 15 MS. LICHTENBERG: 2, 2, 15. 16 MS. FENNELL: "Within two years after the 17 date when the bill that the customer seeks to adjust was 18 rendered." 19 MS. LICHTENBERG: So it's from the date 20 on which you provided it to us? 21 MS. FENNELL: Right. 22 MS. LICHTENBERG: Thank you. 23 MR. ANDERSON: Sherry, this is Craig 24 Anderson. 25 That's not to say that that issue will

355 1 not be addressed further in the performance assurance 2 plan. 3 MS. LICHTENBERG: I'm sure it will be, 4 and in the third-party testing. 5 MS. FENNELL: Yep. We'll see it over and 6 over again, I'm sure. 7 The next issue on the list -- we're going 8 to send the microphone down the table here -- was the 9 training question. 10 MR. ALEXANDER: Scott Alexander 11 responding to this one. 12 I don't recall who raised the issue. It 13 was in one of the written responses that we received from 14 the other parties about training workshops that Ameritech 15 conducts. 16 And I believe the response was directed 17 to the tariff which made a reference of initial training 18 that Ameritech would provide for two personnel. And at 19 the time of the tariff provided that was the policy, that 20 a carrier could send two personnel to a training class 21 free of charge. 22 I believe recently there has been updated 23 training information that would apply more generically on 24 the TCNetwork that discusses the types of training 25 available. It talks about up to six CLEC employees can

356 1 attend workshops. 2 So that's on TCNet. And it's more 3 detailed than here and also broader information. The 4 information that -- TCNet provides training information 5 about a number of training opportunities in addition to 6 this very specific one here. 7 MS. LICHTENBERG: This was my question. 8 You have not answered it. 9 My specific question is as follows, and 10 now that you have told me that there's something on TCNet 11 that changes what you have written in the tariff, I'm more 12 confused. 13 Is this X number of people at no charge 14 to each training class? Or is it a total number of people 15 spread across all training classes? 16 MR. ALEXANDER: My reading of that -- and 17 I'm seeking some clarification from the people that 18 publish that information -- is that the workshops are 19 fairly diverse. 20 So the TCNet information doesn't change 21 what's written in the tariff. I think it supplements. So 22 if we are providing the training and you are coming to us 23 per se, I don't think anybody will disagree that there's 24 six people versus two, based on the information that's in 25 TCNet.

357 1 So if this is something that we need to 2 change, I think we can do that. 3 MS. LICHTENBERG: So I assume that you 4 will be updating the tariff to reflect what your real 5 policy is? 6 MR. ALEXANDER: We can't take that back. 7 MS. LICHTENBERG: My understanding of 8 tariffs is that they generally reflect reality. 9 My question is, is the tariff going to be 10 amended, this draft, to reflect the reality of whatever 11 your training policy is? 12 MR. ALEXANDER: Well, the tariff, the 13 only place that I saw training addressed in the tariff was 14 actually in the existing September of '99 ULS-IST tariff. 15 We're talking original sheet 48, part 19, section 14 which 16 talked about two personnel. 17 MS. LICHTENBERG: Right. Which now 18 apparently is no longer true. 19 So I'm interested in how we're going to 20 get the real numbers reflected in your tariff. Or are you 21 not going to reflect the real numbers in the tariff? 22 MR. ALEXANDER: We can take that back and 23 we will reflect the appropriate number in the tariff. 24 MS. LICHTENBERG: Thank you. 25 MR. ALEXANDER: Since we're going down

358 1 the list of other issues, the next issue on the list were 2 technical references. 3 One party raised a couple of technical 4 references that were referred to in the tariff. And I 5 believe the question was, how could you obtain these? 6 I believe a telephone number is listed in 7 the tariff that refers you to an office in Hoffman 8 Estates. And any customer that wishes those publications 9 or any member of really the general public could obtain 10 those documents by calling that phone number. 11 If someone is particularly interested in 12 those, I would assume that we could bring copies back to 13 the next workshop if that would be helpful for some 14 reason. 15 But in general, the general offering of 16 that type of technical documentation is made through the 17 telephone number listed in the tariff. 18 MS. FRENTZ: MCI brought up that issue, 19 number 13. 20 MR. DENNISTON: Yes. I was just hoping 21 to get a copy of them. 22 MR. ALEXANDER: We can bring that. 23 MR. DENNISTON: Great. 24 MR. ANDERSON: Shall we move on to 25 general or UNE-P issues? Hot cuts?

359 1 MR. GREGG: Sounds good. 2 MS. FENNELL: Just a quick preamble on 3 the category. 4 We wrote "general" or "UNE-P" because of 5 where they were positioned. We didn't know for these 6 three topics whether it was a UNE-P-specific question or a 7 broader question. So we are looking for some feedback 8 from you too as we respond. 9 So with that, because it's hot cuts, it's 10 going back down to Scott. 11 MR. ALEXANDER: Again, I don't have a 12 notation of which party raised the hot cuts issue, but it 13 showed up more than once. 14 But my understanding of hot cuts has 15 always been that a hot cut involves an unbundled loop 16 conversion where the current customer is working without 17 home service and the CLEC wants to convert to an unbundled 18 loop with numbered portability. 19 So I don't think we were sure how that 20 involves a conversion of elements that are currently 21 combined. So that if the party that raised the issue on 22 hot cuts wants to embellish the question a little bit, we 23 might be able to talk about that a little more. 24 But I myself did not know how hot cuts 25 applied to UNE-P per se.

360 1 MR. REIDY: AT&T is one of the parties 2 that raised this. Actually, your answer is informative to 3 me. 4 Is it your understanding that this 5 collaborative is only on combinations? 6 MR. ALEXANDER: I wasn't clear on the 7 question, is what I'm saying. 8 MR. REIDY: I would agree with your 9 general premise that hot cuts are related to provisioning, 10 a manner of provisioning loops on an unbundled basis. 11 And so the question is, is it Ameritech's 12 intent, as part of its tariff procedures for provisioning 13 unbundled loops, to incorporate any more details regarding 14 how, with regard to hot cuts or coordinated cut-over, that 15 type of thing? 16 MR. ALEXANDER: Okay, on unbundled loops 17 specifically, you said tariff provisioning. Generally, 18 provisioning procedures are going to be either in the 19 schedule of an interconnect agreement or, for instance, in 20 the TCNet materials. So typically you wouldn't find that 21 level of operational detail in the tariff. 22 So sitting here right now today, we do 23 hot cuts today and I know there's discussions around what 24 performance measures should be provided relative to hot 25 cuts. But that level of detail is not in the tariff.

361 1 MR. REIDY: There isn't even a reference 2 in the tariff, I guess, is the question. 3 MR. ALEXANDER: One issue on that, and 4 we're really talking now of very specific operational 5 provisioning about how to order it, what fields to fill 6 out, how to request it, how to coordinate with the network 7 element control center, the local operations control 8 center. 9 Now we're talking real operational 10 issues, which I wouldn't really think would be involved in 11 tariff language. It's not the product per se. Those are 12 the procedures on how to order the product and how the 13 product is provisioned. 14 MR. REIDY: And you're saying that's in 15 the ordering guide right now? 16 MR. ALEXANDER: There would be 17 information about how to provide information about 18 coordinated related orders. For instance, if the provider 19 wanted to reuse the unbundled loop, that information 20 should be on TCNet to tell them how to order that as a 21 coordinated related order. 22 MR. BENNETT: Well, we could sit and 23 debate the difference between fail-safe hot cut cut-overs, 24 so the customers are converted in a fail-safe manner in 25 the coordinated conversion process that you have on TCNet

362 1 today. 2 But what I'm really interested in is, in 3 this collaborative are we talking about the combination of 4 the platform here or are we talking more generally talking 5 about all aspects of unbundled network elements? 6 Because I think he is right. If we're 7 only talking about the platform, then the discussion of 8 hot cuts is not an appropriate discussion to have here. 9 If we're talking more generally about all 10 unbundled network elements, then I'd like to continue this 11 discussion because I think you could simply put something 12 in the tariff to reference a hot cut procedure without 13 getting into operational detail. And I think tariffs are 14 full of that stuff. 15 MR. ANDERSON: Bruce, my understanding, 16 and our approach, I guess, in addressing this re the 17 Commission order, was that the purpose of this 18 collaborative in particular was to address the tariffs 19 that we were required to file on March 10th, which were, 20 as you know, the UNE-P and the unbundled loop, the xDSL 21 conditioning and there was a mid condition. 22 But we're glad to talk about the issue 23 and answer the question. But I guess I would -- and I 24 look to staff for suggestions -- I wouldn't want to expand 25 this to cover all of our tariffs.

363 1 And these are, as you know, discussions 2 we're having in our negotiations. 3 MR. BENNETT: I'm not looking to expand 4 the discussion here either. And I don't think it would be 5 terribly fruitful. I just, you know, want to understand 6 that that wasn't the intent of this because I didn't know 7 that. 8 MR. GREGG: I kind of am getting my 9 direction from page 3 of the 12323 order which states that 10 "Ameritech Michigan shall file tariffs that demonstrate 11 its full compliance with state and federal statutes, rules 12 and previous Commission orders on unbundled network 13 element (UNE) offerings, including Commission orders 14 addressing the availability of the UNE platform discussed 15 in the February 9, 2000 order in Cases Nos. U-11104 and 16 U-12143." 17 MR. REIDY: And my response is, you know, 18 I agree there's a line to be walked here. But it is not 19 as narrow, I think, Craig, as what you're drawing it. It 20 may not include a robust discussion of the operational 21 methodology for hot cuts. 22 But to be in compliance with state and 23 federal law and the rules and rulings of the Commission 24 may require more than simply -- may require a tariff that 25 references more explicitly the types of hot cut procedures

364 1 that -- what we're talking about here. 2 So we may not have to get into the 3 operational details of it. It's the fact that to be in 4 compliance with what the Commission required in that 5 order, we might have to get into those discussions. 6 MR. ANDERSON: We'll take that back, Jay, 7 and look at it and whether we can put something. But I 8 take it that would be in the unbundled loop tariff is 9 where that would go from Bruce's comments? 10 MR. BENNETT: I would think it would. I 11 also, you know, in the interest of full disclosure, I know 12 that I have heard in other collaboratives and other forums 13 that it's your intent to discuss the hot cut procedure as 14 part of OSS. And at other times I have heard that it's 15 your intent to discuss that as part of performance. 16 I don't care where we discuss it. It 17 needs to be discussed by every RBOC in the country. If 18 Ameritech offers a fail-proof hot cut procedure today in 19 one form or another and they are in different advanced 20 stages, but you don't even offer a fail-safe hot cut 21 procedure today. So we need to talk about it someplace. 22 And wherever you want to talk about it is great with me. 23 MR. ALEXANDER: It's my understanding 24 that was also being discussed in the contract negotiations 25 in terms of a specific procedure.

365 1 And I'm also aware that through merger 2 best practice discussions, Ameritech SBC Pacific, are 3 looking at procedures that could be rolled out near term 4 and field-tested sometime in the early second quarter, to 5 look at, not doing hot cuts one way here in Michigan and 6 another way in Illinois and in 14 or 15 different ways. 7 So there are activities under way with 8 that. And I think we can provide information on that as 9 it becomes available. 10 And particularly with hot cuts and 11 tariffs, if there were specific activities that were 12 performed that were more of a service-related thing -- 13 some type of enhanced coordination activity or testing -- 14 and there were charges for that, then logically that could 15 wind up in a tariff because there would be functions 16 identified that you could electively perform as part of 17 the service of purchasing that unbundled loop. 18 MR. ANDERSON: And, Bruce, just to 19 process the question and maybe this goes to Rod's point, 20 and I read in the language you have quoted, it was our 21 belief on March 10th that we had to file the tariffs that 22 were necessary to fill any gaps in our existing tariff to 23 fulfill our obligations under state and federal. And we 24 did that. 25 And as we indicated, there are some

366 1 additional obligations that are arising and tariffs will 2 be filed for them coming up, line sharing and dark fiber 3 and subloop. 4 And we will be addressing the whole array 5 of all the existing services when we file our specific 6 filing demonstrating how we comply with a particular 7 checklist item, i.e., loops. And we'll file that in the 8 order separately in a separate paragraph and address it as 9 a collaborative process to discuss it. 10 So at least there and as you point out in 11 OSS testing and performance measurements, these are all 12 subjects. 13 But really our focus and our thought was 14 to focus on those tariffs that we had to file by March 15 10th in this process initially. 16 If we want to broaden it, we certainly 17 can. But I'm just pointing out there will be these other 18 discussions and filings to address. 19 Scott, is that fair? 20 MR. ALEXANDER: Yes. 21 MR. GREGG: I think what we want to 22 discuss in here is that if parties believe that you did 23 not file all the tariffs that you needed to, to meet the 24 requirements of the Commission order. 25 MR. ANDERSON: Okay.

367 1 MR. REIDY: One comment though, Craig. 2 In the checklist process you mention a 3 collaborative. And again, that's not the way I read the 4 order. We don't get to collaborate after. Or do we? I 5 don't know. 6 MR. GREGG: What were you referring to? 7 MR. REIDY: Paragraph 14 is what I'm 8 looking at. 9 MR. GREGG: I thought you were talking 10 about if the parties reach an impasse during the 11 collaborative process. 12 Well, the sentence before that says: "If 13 any party believes that Ameritech Michigan's tariff 14 filings are insufficient or inconsistent with the 15 Commission's prior orders regarding the UNE platform, 16 questions regarding the sufficiency of the tariff should 17 be first addressed in the collaborative process 18 established by the order." 19 "If the parties reach an impasse during 20 the collaborative process, any party having a disagreement 21 with Ameritech Michigan's tariff filings may file an 22 application and complaint pursuant to..." Legal stuff. 23 MR. REIDY: I absolutely agree with that. 24 That's what we're here doing today. And I want to 25 understand your reference to the checklist filings.

368 1 MR. ANDERSON: Jay. Paragraph 4, I 2 think, is the general process. And as I think I 3 outlined -- we outlined in our very first submission or 4 the first collaborative -- although we were there together 5 for OSS at that time -- it's our intent to file as we 6 believe we meet each checklist item the documentation 7 showing that we filed it and that we would have a 8 collaborative on that subject. 9 MR. REIDY: Okay. But we have 15 days to 10 file a response under the Commission's order to your 11 checklist filing. 12 I just want to make sure I understand the 13 process. And I apologize for slowing this down. But you 14 were going to collaborate after we file our comments? 15 MR. ANDERSON: We'll need to talk about 16 that. 17 MR. REIDY: Okay. I think it's a good 18 thing. 19 MR. LONERGAN: I don't think we really 20 addressed the procedures of paragraph 4 and 14 together. 21 They do seem to suggest a collaborative, perhaps followed 22 by the opportunity to make a filing as well. 23 MR. REIDY: I agree. 24 MR. LONERGAN: That's kind of how I'm 25 reading it today. I just want to make a couple of

369 1 comments on hot cuts and some of these other items. 2 We undoubtedly will address these matters 3 in the test plan in terms of identifying testing and that 4 sort of thing. 5 And I know in New York this was a pretty 6 hot issue which in their case resulted in significant 7 changes to the way things were done. Which suggests that 8 a tariff today may not have a great deal of meaning, even 9 if there was a need for one. 10 But this is something to look at down the 11 road perhaps, whether there is a need -- some of these 12 services are billed for or charged for. I guess they 13 belong to tariff. But I don't know that that will or is 14 the case now or will be the case. 15 So I'm not saying we should ignore it. 16 I'm just saying I think it will be looked at very 17 carefully. 18 MR. ANDERSON: Why don't we go to the 19 next mechanized MLT. 20 MR. DENNISTON: I thought we discussed 21 that. 22 MS. FENNELL: We did MLT. Was there 23 anything more on MLT? 24 MR. BENNETT: No. And I just wanted to 25 clarify that. The MLT I was talking about was in

370 1 conjunction with the platform. So I assume your answer 2 still is yes, you can't? 3 MR. ALEXANDER: The answer is still the 4 same. 5 MS. FENNELL: The next issue is regarding 6 LEC protection. And Jeff. 7 MR. HUTCHINSON: And I think we had a 8 little bit of confusion here also as to whether or not 9 this was LEC protection for the platform or in general. 10 MR. BENNETT: From AT&T's perspective the 11 question comes from how the PIC freeze program that you're 12 putting in will relate for local, will relate to the 13 platform. And whether or not the same provisions that 14 you're applying for resale today are going to be the same 15 kind of provisions that would be supported for the 16 platform product. 17 MR. DENNISTON: And from MCI's 18 perspective, it's a matter of being able to identify, if a 19 customer calls us and says, yes, I want MCI for local, how 20 do we find out whether or not they have LEC protection? 21 And if so, what are the processes available to us to lift 22 it or suspend it so as to enable the customer to come to 23 MCI for local. 24 MR. HUTCHINSON: And I think those are 25 both excellent questions.

371 1 We have had a long hard process of 2 getting our resale LEC protection up to, I think, where it 3 meets all the requirements of U-11900. 4 And we are also in the process of 5 developing that for facilities-based. We currently do not 6 have any orders from any carrier to provide them unbundled 7 local switching, where we would have the obligation as the 8 executing carrier to offer LEC protection. 9 So do we currently have a commercial 10 offering that is being used for LEC protection? The 11 answer is no, because we do not have the customers that 12 currently purchase the use of our switch. 13 We are in the process of developing it. 14 I don't have a whole lot of details for you today. We 15 will be getting in more details on that too. 16 My presumption is that the program will 17 track very closely with what we have done for resale. 18 MR. DENNISTON: Part of the LEC 19 protection information that I think we would require would 20 be in the parsed CSR sent to us. That that information 21 would contain information that would allow us to determine 22 whether or not the customer has LEC protection. And 23 that's something that we're looking for. 24 And also, we would have the availability 25 or ability to use a three-way call.

372 1 MR. HUTCHINSON: I think the order very 2 clearly lays that out for the lifting of LEC protection or 3 suspension of LEC protection, that the two options are 4 letter authorization that's written or three-way calling. 5 I think we're very clear on what the 6 order says. 7 MR. DENNISTON: I'm not quite sure TCNet 8 is consistent with that. 9 MS. LICHTENBERG: Jim, I'm not sure I 10 heard that answer. 11 MR. DENNISTON: I'll let Jeff explain his 12 answer. 13 MR. HUTCHINSON: Was she asking for my 14 answer or yours? 15 MS. LICHTENBERG: I was actually -- I 16 think I heard, Jeff, you talking about your understanding 17 of how you will be dealing with LEC protection. 18 MR. HUTCHINSON: Yes. 19 MS. LICHTENBERG: That's what I didn't 20 hear. 21 MR. HUTCHINSON: And I really did not 22 provide any detail because at this point I don't have the 23 detail for the facility-based LEC protection program. 24 MS. LICHTENBERG: So would that be added 25 to the tariff when you have such detail?

373 1 MR. HUTCHINSON: I don't believe so. To 2 the extent that the detail that you may be looking for -- 3 I mean, it's very clearly laid out on our TCNet and gets 4 more to the level of the methods and procedures and 5 processes that need to be utilized to implement LEC 6 protection. 7 MR. DENNISTON: Jeff, my problem is that 8 TCNet -- in my opinion the procedure set up there 9 contradicts the procedures available to us under 11900. 10 MR. ANDERSON: We recognize that TCNet 11 needs to be updated in that regard. We're in the process. 12 MR. HUTCHINSON: And, Sherry, for your 13 benefit, the answer was that we are updating TCNet to 14 reflect the LEC protection process at this point. 15 MS. LICHTENBERG: So let me understand 16 that today when I read TCNet, it doesn't necessarily tell 17 me reality either? 18 MR. ANDERSON: We haven't caught up with 19 the revisions to TCNet that have been required by the 20 latest Commission orders. We are in the process of doing 21 that. 22 MR. HUTCHINSON: They don't fully reflect 23 what's required in 11900. They are being updated. 24 MS. LICHTENBERG: Thank you. 25 MS. SCHNEIDEWIND: And I would also note

374 1 that the one merger amendment that we have received at the 2 Commission for the UNE platform, it was rejected by the 3 Commission in particular because of the PIC change 4 language. And we are still negotiating an acceptable 5 language in your interconnection agreements to properly 6 incorporate the rules that the Commission adopted in 7 11900. 8 MR. ANDERSON: Right. I understand 9 that's ongoing and I think there were conversations as 10 recently as yesterday. 11 MS. SCHNEIDEWIND: This morning. 12 MR. ANDERSON: Better yet. 13 MR. REIDY: Can I ask then, are the 14 changes that are going to be made to TCNet, first of all, 15 will they allow the use of a third-party verifier that is 16 not Ameritech's contracted third-party verifier? 17 MR. HUTCHINSON: Which aspect of the 18 program are you asking about? 19 MR. REIDY: The lift or suspend 20 operation. 21 MR. HUTCHINSON: Lift or suspend, if you 22 look in 11900, has two options. It has a written LOA or 23 it has a three-way call. 24 MR. REIDY: I understand that. And on 25 the three-call where there is a third-party verifier --

375 1 MR. HUTCHINSON: It's a different option. 2 MR. REIDY: All right. Then I'll stop. 3 (At 12:05 P.M., a recess was taken until 4 1:05 P.M. of the same day.) 5 - - - 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

376 1 Lansing, Michigan 2 Thursday, March 30, 2000 3 1:05 P.M. 4 - - - 5 (The hearing was resumed pursuant to the 6 noon adjournment.) 7 MR. GREGG: Are we ready to begin? 8 I think you had something, Jim. 9 MR. DENNISTON: Yes. Just following up 10 from where we were when we left off. 11 It would be our position that the 12 language accurately identifying the practices of Ameritech 13 regarding LEC protection be part of the tariff. And 14 that's the way we would like to see things. 15 I understand Ameritech disagrees with 16 that. But I just want to be sure that we're clear on 17 where we're coming from. 18 MR. ANDERSON: Jim, in that regard, when 19 you say LEC protection, is it in the context of LEC 20 protection for end users who are served via the UNE 21 platform or are you talking now about transitioning 22 customers? 23 MR. DENNISTON: You really can't have one 24 without the other. But the primary purpose is to show 25 what the rules are, what the methods are whereby CLECs can

377 1 deal with LEC protection. 2 For example, a new customer wants a CLEC 3 for local service, but has LEC protection. We want to 4 make sure that the notification that the customer has LEC 5 protection is part of the parsed CSR. And we specifically 6 want the tariff to provide that the methods of lifting or 7 suspending that are all the methods as set forth in 11900, 8 including three-way telephone call and/or an LOA at the 9 option of the CLEC and/or customer. 10 MR. HUTCHINSON: And I think both of 11 those options are pretty clearly specified in 11900. In 12 order to lift LEC protection, we have got to be able to 13 offer the written LOA or the three-way call. 14 As to the parsed CSR, I think that's an 15 issue that is better dealt with in a different forum, the 16 OSS forum, I believe. 17 MS. LICHTENBERG: This is Sherry 18 Lichtenberg. 19 A question is, how will we know a 20 customer has LEC protection if you do not provide it with 21 the CSR that is parsed and shows all of this information? 22 MR. HUTCHINSON: Sherry, my level of 23 detailed understanding isn't real great, but my 24 understanding is if an order is submitted for a customer 25 that does have LEC protection on it, that that order will

378 1 not be processed and that notification will be given. 2 MS. LICHTENBERG: So rather than telling 3 us whether a customer has LEC protection, you would rather 4 increase the reject rate and the rework rate and all of 5 the activities that both our companies have to undertake? 6 MR. HUTCHINSON: As I said, I don't think 7 my level of understanding of the exact process is clear 8 enough to really give you the detail of it. 9 We do have updated language that we're 10 going to be putting on the TCNet that will give a more 11 accurate representation of the processes. It's currently 12 being deployed for resale. And my assumption is that the 13 facilities-based procedures are going to very closely 14 follow that. 15 MS. LICHTENBERG: And again, I believe we 16 need to see those procedures. And I would hope that at 17 our next meeting, in a forum where we should be discussing 18 these items potentially, the third-party testing forum or 19 other OSS collaboratives, that you all would bring the 20 relevant experts who could answer these questions. 21 MR. HUTCHINSON: Agreed. 22 MR. GREGG: And are you saying that not 23 in the tariffing forum, but in the OSS forum? 24 MR. HUTCHINSON: I think that we have got 25 a disagreement in terms of the level of detail and where

379 1 it should appear, whether or not it's in the tariff or 2 whether or not it's in methods or practices which are 3 communicated via a website. 4 And as far as the procedures for LEC 5 protection, and not only LEC protection but selection and 6 protection and suspension of protection, all of those 7 different processes, they are outlined in the Commission's 8 slamming order. 9 I don't think that there's agreement as 10 to whether that level of detail is needed within the 11 tariff. And I think there is complete agreement that that 12 level of detail needs to be communicated. 13 MR. LONERGAN: I just bring this up just 14 to comment on it. 15 There is a requirement in the Commission 16 order that a "user friendly procedures manual or manual be 17 developed." And it seems to me what I'm hearing here is 18 presumably in order to determine that something is user 19 friendly, the users have to be consulted. 20 So I think when we get to that point, 21 some of these issues of communication, which is what this 22 sounds like it's about, will, I think, from the staff 23 point of view at least, have to be addressed. 24 MR. REIDY: Picking up on that point, 25 Tom, and I guess this question is for Ameritech, have you

380 1 developed a position as to whether or not the ordering 2 guides that are currently on TCNet will be those 3 user-friendly order guide that are referenced in the 4 Commission's order? Or are we going to see a separate 5 document prepared in reaction to the Commission's order in 6 12320? 7 MR. ANDERSON: My understanding is it 8 will be TCNet. That's the vehicle for that. 9 MR. LONERGAN: I'm not sure we -- I don't 10 think we oppose that necessarily. But I think what it 11 suggests is that TCNet has to be sort of opened up for a 12 discussion about, is it serving that purpose in a 13 user-friendly manner. 14 MR. REIDY: I think that's right. 15 MR. DENNISTON: Can we talk about TCNet 16 in general right now? 17 Tom, does staff have access to TCNet? 18 MR. LONERGAN: Yes, we do. 19 MR. DENNISTON: Okay. My understanding 20 is also that in everything that TCNet is pretty much 21 confidential and proprietary. And is there a way of 22 opening up that to some extent? 23 I think a lot of pages there are stamped 24 confidential or proprietary, even if it has to do with 25 some rather common day practices that all CLECs are

381 1 familiar with. 2 Is there a way of having a portion of 3 TCNet opened up? 4 MR. ANDERSON: I think -- let me take a 5 stab at that. 6 I think the reason why it is treated as 7 proprietary is that it is details of how we run our 8 business. And in terms of our wholesale business, 9 processes we have developed that we would not want to give 10 away to Bell Atlantic should they decide to be as customer 11 friendly at we are. 12 MS. LICHTENBERG: I'm really sorry. But 13 somebody is muted. 14 MS. FRENTZ: Or they are on their 15 cellular phone maybe. 16 MR. ANDERSON: So, it is proprietary in 17 that sense. I don't think it is proprietary vis-a-vis -- 18 and I think in all the interconnection agreements we have 19 with our customers there is a provision that says to the 20 extent you use the data basis of TCNet and that kind of 21 thing, that it is treated with some level of 22 confidentiality. But I don't think it is the same kind of 23 confidentiality issue that there is with the cost study, 24 for example. 25 I mean, this is out there with all our

382 1 customers. All our customers have access. But when we 2 give a customer access to TCNet, it is given via a pass 3 code and a number. It's not open generally to the public. 4 So it is proprietary in that sense. In 5 the same sense, I assume, MCI's customer guides with their 6 customers are proprietary. 7 MS. LICHTENBERG: Actually, when we are 8 in the Bell Atlantic region, for instance, there is no 9 necessity for any sort of pass code, dial-in, etc. 10 Originally, for the ordering GUI and the preorder GUI, 11 there is, but not for the CLEC handbook site. 12 I would suggest that everyone, whether 13 they are already a CLEC or not, would need access to that 14 handbook site, as opposed to the ordering or preorder 15 sites. 16 MR. ANDERSON: Well, I'm not sure I 17 understand what the problem is. 18 MS. LICHTENBERG: It makes it difficult. 19 For instance, I have a significant number of users. And 20 to go in and every single time I want to get somebody 21 accessed to take a look at your TCNet information, I have 22 to go through my carrier management folks and get a log-in 23 I.D. It seems to just create more work for the CLECs. 24 MR. DENNISTON: And also, another -- to 25 put my lawyer hat on -- another angle I was looking at is

383 1 you don't want to put a lot of stuff in the tariffs 2 because you say a lot of these procedures are worked out 3 inside TCNet. That's where the procedures are laid out. 4 And so if we have a problem with whether 5 or not you are actually following the procedures that have 6 been agreed to here or have been worked out, we would have 7 to file a complaint. And it seems as though our complaint 8 is you violated your confidential TCNet policies and 9 procedures. 10 It's really -- we are filing -- almost 11 our entire testimony then would be confidential. And I 12 think it's a preference to have testimony filed in a 13 public version. And it makes it, I guess, you know, we 14 would argue for a violation of your internal policies and 15 procedures as opposed to a violation of a tariff. 16 And I think if it's tariff, it would give 17 it more force and effect and would give CLECs more or 18 better grounds to stand upon and certainly any violations 19 of what's being worked out here. 20 MR. ANDERSON: Well, there are procedures 21 in place to address confidentiality of documents and we 22 use them all the time in Commission cases. 23 I guess I don't know. I think in part 24 we're getting beyond the subject matter of what we're 25 focusing on here. Certainly this is something that can

384 1 come up and we'll address in the context of the 2 customer-friendly user guide. 3 I do have some concerns about what you're 4 saying, Jim. I mean, we develop detailed methods and 5 procedures and to a certain extent those are put on the 6 interface and that is proprietary to us. I mean, it's not 7 something we want somebody else to just take and use out 8 there. 9 It's not confidential in the sense of 10 trade secret. Well, I guess it is trade secret 11 information. That's exactly the issue. 12 MS. FRENTZ: Actually, as an Ameritech 13 employee, any one of us, we have to go through the same 14 process that Sherry mentioned in order to look at it. And 15 we don't want Bell Atlantic or anyone else to do that. 16 MR. ALEXANDER: I wanted to respond to 17 that a little bit also. 18 Another purpose of having the pass word 19 or user I.D. on TCNet was also to track usage and 20 usefulness, so that the people that are building the 21 website kind of know if we need to go back and find out, 22 well, are people really using this and who is really using 23 it and where are the hits coming from. That there's some 24 value to that information in making the website more 25 usable if you know more about the usage and who the users

385 1 are. So I think there's some reasons for the pass code 2 with regard to that. 3 I have also noticed that recently if you 4 walk on to TCNet on the original front screen, there is a 5 nonpass word protected area with some information in it. 6 And I'm not sure all the information is in there. But I 7 think we have some customers that were customers of AIS in 8 Ameritech that were not necessarily CLECs, but were other 9 types of whole sale customers that could get information 10 that was not UNEs and that kind of thing from that. 11 So I think there's certain types of 12 information which may not require that, but there are 13 other types of information that do require it. 14 MS. RUFFIN: Excuse me. This is Evelyn 15 Ruffin from MCI WorldCom. 16 I was thinking that you could agree that 17 we could develop that side of the website that is 18 unprotected. You could read those through those documents 19 that offer a CLEC use and then we wouldn't have to go 20 through that bridge. 21 MR. ALEXANDER: Well, actually -- Scott 22 Alexander speaking from Ameritech. 23 And actually what I stated was there is a 24 nonpass word protected piece of TCNet out there now. I'm 25 not sure exactly of all the information that's in that

386 1 section of TCNet. I believe it was intended for the 2 nonCLEC type of customers that Ameritech had that used 3 other types of products and services, not necessarily UNEs 4 or interconnection services. 5 MS. RUFFIN: I'm agreeing with you. But 6 I think it's very limited in its use. And there are 7 certain documents maybe that you could look at that are in 8 the protected area that could be moved over. 9 MR. ALEXANDER: That's possible. 10 MR. LONERGAN: Let me just close this 11 out. I think it would be unwieldy from what I have seen 12 in TCNet to try and tariff all that stuff. But it's 13 possible that in the future that if some of those things 14 begin to have prices associated with them or whatever, 15 that it would be appropriate. 16 As far as what's in the protected or 17 nonprotected, perhaps you folks can advance your 18 suggestions and Ameritech can take those into 19 consideration. And we'll be looking at that later on in 20 terms of the, does TCNet meet our definition of a 21 user-friendly manual for purposes of, at least in this 22 case, for purposes of purchasing and provisioning UNE-Ps 23 and some of the other things. So we could come back to 24 that. 25 I'm not sure strictly speaking that it's

387 1 a UNE-P tariff matter. But some of the suggestions are 2 good ones, I think. 3 Do we want to move into the cost sector? 4 MS. LASSWELL: Hi. This is Terice 5 Lasswell, for the people who are on the bridge, and I'm 6 with Ameritech. And I wanted to address the two issues 7 that are shown as being cost-related issues. 8 There is one for cancellation and change 9 service charges and also service coordination fee. 10 I'll start on it by talking about the service coordination 11 fee. 12 And the issue, I think, was raised by 13 Horizon. And they wondered why we had a separate 14 coordination fee and why that wasn't rolled into the 15 TSLRIC cost study. I'm assuming they mean for the loop. 16 And I just wanted to point out that we 17 have always had a separate rate element for service 18 coordination fee. That goes back to when we first filed 19 our tariffs around U-11290. 20 MS. LICHTENBERG: What is a service 21 coordination fee? 22 MS. LASSWELL: It's a charge that we 23 assess per carrier per switch for doing billing. 24 MS. LICHTENBERG: And what is the actual 25 work that you're doing to generate that?

388 1 MS. LASSWELL: Well, there is a piece of 2 it associated with actually rendering the bill. There are 3 pieces associated with customer contact and coordination. 4 I don't have the study with me. But it's 5 really all the aspects of actually sending out the bill to 6 the customer. 7 MS. LICHTENBERG: To the CLEC, correct? 8 MS. LASSWELL: To the CLEC, right. This 9 goes to the CLEC. 10 MS. CAMPION: This is Joan Campion. I 11 have a question. 12 Is this that really substantial charge 13 that's in the tariff? Just so I know what we're talking 14 about. 15 MS. LASSWELL: No, it's not. I believe 16 the rate that we charge is -- hold on a second. 17 MR. BENNETT: 84 cents it says 18 MS. CAMPION: Okay. I had that confused 19 with the -- 20 MR. DENNISTON: The $800,000 number? 21 MS. CAMPION: Yes. Sorry. 22 MS. LASSWELL: And actually, the rate 23 that we have in the tariff today is what we were ordered 24 to use out of our U-11831 cost docket order. And we were 25 told that we needed to maintain the rate that had been

389 1 established from the U-11280 docket. 2 MR. ANDERSON: Any discussion on that? 3 Rick, I know you have addressed that. 4 MR. GOULD: I guess basically I'll need 5 to take a look at these other cases that you made 6 reference to and see its impact on them. 7 I guess basically it seems to me that as 8 far as part of the bill, for the billing services that 9 should be incorporated within your other charges. But 10 I'll take a look at these other two cases and see how that 11 fits in. 12 MR. ANDERSON: That was the biannual cost 13 docket we had just concluded and that issue was in both 14 that docket and the earlier cost docket. 15 MS. LASSWELL: The next cost-related 16 issue -- and this was also brought up by Horizon, but I 17 think a couple of the other parties commented on this 18 also -- had to do with the cancellation and change service 19 charges which we have in our tariff. And I think Horizon 20 specifically referenced the unbundled loop. 21 Those charges, as they exist in the 22 tariff, are based on requirements of the U-11831 order. 23 Again, those elements were addressed in the biannual 24 filing which we just -- well, we got a final order in 25 anyway in Michigan.

390 1 And out of that order, we were told that 2 we needed to adopt the adjustments that were recommended 3 by the MCI nonincurring cost model. And in fact, for the 4 rate elements in question here, we had to actually close 5 to the results of the model that came out of the, 6 actually, Turner model. 7 So basically we're complying with the 8 order. We're using the MCI adjustments that we were 9 ordered to use. And again, these were part of the case 10 that we just received a final order on and concluded our 11 compliance filings on. 12 MR. ANDERSON: Terice, you mentioned the 13 term "model." Was that -- the Turner was the collocation 14 model. 15 MS. LASSWELL: I'm sorry. That was the 16 Jenkins model, not the Turner model. 17 MR. SEVERANCE: Just for clarification, 18 can we do an example here? 19 Jim Severance from Sprint. 20 If we order a loop and you tell us that 21 we will get that loop next Wednesday, and then for 22 whatever reason, on Tuesday you call up and say it's not 23 going to be available until Friday. And then just to 24 carry this example one step further, you say again you 25 delay it again until it's due next Tuesday. And we say

391 1 just forget about it. 2 Would we be charged the $123? 3 MR. ANDERSON: I'm not sure of the 4 answer, Jim. And I think we need to check. We tried in 5 the short time we had to do a little further checking on 6 this. 7 Just a couple of comments. Number one, 8 the idea is to cover the costs of cancellation. And 9 originally when we did our cost studies, we had included 10 the cost of cancellation overall in the study and several 11 of the parties had said no, take that out; charge it only 12 to the cost causer, i.e., the one that cancels the order. 13 Part of the concern is that the 14 billing -- I'm sorry, the performance assurance plan or 15 remedies that ultimately will be put in place, we believe 16 will address to a significant degree the extent to which a 17 carrier sustains injury as a result of our not meeting the 18 performance measurements. 19 And in a sense there would perhaps be 20 duplicative recovery. So if the charge does apply in that 21 instance, that in essence the carriers gets it back 22 through the performance assurance plan. 23 The problem with just saying in the 24 tariff that, well, this charge doesn't apply if it's 25 Ameritech's fault, quite frankly is, every cancellation

392 1 would be Ameritech's fault. Then you get into endless 2 billing disputes about this. 3 And part of the thing is maybe -- and I'm 4 not sure we need to look at this a little further -- maybe 5 the answer is that when these issues arise, the charge 6 applies on its face. But if there is a dispute whether it 7 should properly be applied in that instance, that is 8 something to be addressed pursuant to the specified 9 billing dispute procedures. 10 I think all of the contracts with the 11 carriers have specific and separate procedures for 12 addressing these billing disputes. So it doesn't turn 13 into a he said, she said debate every time on every order. 14 MR. SEVERANCE: And I don't have a 15 quarrel if those cancellation charges are something that 16 need to be recovered. 17 But somehow we need a comfort level, that 18 when it's because of Ameritech -- and I don't agree that 19 every time that this comes up that we would automatically 20 accuse Ameritech of being the reason that we cancelled the 21 order. 22 MR. ANDERSON: I didn't mean to suggest 23 any one carrier would do that. But there's the potential 24 for that. 25 MR. SEVERANCE: If you could look at that

393 1 situation and see if there's some way that we could attack 2 this in this proceeding. 3 MR. GOULD: I have a question. 4 Rick Gould from Horizon. 5 In looking at your cancellation charges 6 here, essentially it's revised sheet 9, under 19, section 7 2. I'm trying to read these and understand them. 8 It appears to me that essentially the 9 cheapest route for the CLEC is essentially is, have the 10 loop installed and then cancel it. Because the charges 11 that you have here -- and that's what I guess I'm trying 12 to get a handle on here -- design layout reports 403, 13 records issue dates 1790, design verified and assigned 14 date is 3578. 15 Are all of these charges, if I cancelled 16 them prior to installation, going to be charged to me as a 17 CLEC? 18 MS. LASSWELL: It really depends at what 19 point in the provisioning process the order gets 20 cancelled. So I would assume on one cancellation, only 21 one of these charges would apply. 22 MR. HAMPTON: It's not a sum. 23 MS. LASSWELL: It's not cumulative. 24 MS. LICHTENBERG: This is Sherry 25 Lichtenberg. Let me add to that question, if I could.

394 1 Are we talking at all about orders that 2 are cancelled by Ameritech because the CLEC made an error, 3 the order was rejected and there was some length of time 4 before an appropriate correction went in and Ameritech 5 cancelled it? Is that cancellation charge according to 6 that? 7 MS. LASSWELL: Sherry, according to the 8 tariff language, the charge only applies when the 9 telecommunications carrier cancels the order. 10 MS. LICHTENBERG: And does that apply if 11 a telecommunications carrier had an order, for instance, 12 rejected five or six times and Ameritech says, you really 13 need to do it a different way. Cancel it? 14 MR. HAMPTON: No. It's after. 15 MS. LICHTENBERG: And the CLEC chooses to 16 make the cancellation at Ameritech's request? 17 MR. HAMPTON: No. Because the ordering 18 charges don't apply until we have got a good order to 19 begin with. 20 MS. LICHTENBERG: Thank you. 21 MR. HAMPTON: Okay. So the cancellation 22 charges, when we have got an order, it's good. We started 23 processing it. And at some point in time you said, nope, 24 I don't want this anymore. Okay. 25 And the rate table that you see is

395 1 saying, what is the, as we call it, the critical date? 2 Where are we in the process of provisioning that order, 3 because of those dates we have incurred X amount of costs. 4 So if you're at X date, the cost is this. 5 If you're at this date, the cost is this. So you don't 6 add them up. It's this rate at this point. 7 Okay. Does that make sense? 8 MS. LICHTENBERG: That makes sense. And 9 I assume there are cost studies that justify these 10 charges? 11 MS. LASSWELL: Yes. 12 MR. HAMPTON: Yes. 13 MR. GREGG: Speaking of the cost studies 14 that justify these charges, are the people that are in 15 this, the parties that are a part of this collaboration, 16 do they all have this, the cost support, that was filed 17 with these tariff sheets? 18 MS. LASSWELL: No. I believe AT&T and 19 MCI would have access to the cost data. I don't believe 20 Nextel or Sprint or Horizon. 21 MS. FENNELL: Sprint signed a proprietary 22 agreement. 23 MS. FRENTZ: We can check the list, Rod, 24 to see. There's a different list for who got proprietary 25 information.

396 1 MR. ANDERSON: Basically, it was 2 distributed to the people who were on the confidential 3 distribution list in the cost docket and chose to 4 participate and then signed the confidentiality agreement. 5 MS. FRENTZ: So, Rick Gould, I don't 6 remember if you were on that list or not. 7 MR. GOULD: I don't remember either. 8 MS. FRENTZ: You would have a stack as 9 high as the ceiling. 10 MR. ANDERSON: You wouldn't have missed 11 this stuff. 12 MR. GOULD: But you guys do everything 13 that way though. 14 MR. ANDERSON: And we'd be glad to, if 15 someone is interested, here's the lady who has to 16 reproduce that stack. 17 Let me put it another way. There have 18 been participants who came into the docket and sought that 19 information, I guess. 20 MR. GOULD: I'll think about it and give 21 you a call. 22 MR. ANDERSON: You might check. Mr. 23 Ralls might have a copy laying around his office. 24 MR. RALLS: I don't know if I can show it 25 to you though, Rick.

397 1 MR. DENNISTON: Terice, the two items you 2 have on this handout you gave us today on cost-related 3 issues, I don't see in there the items MCI raised on page 4 5, paragraph 9, asking for cost support for the interim 5 share of transport charge. 6 MS. LASSWELL: We have that under interim 7 shared transport pricing. 8 MR. DENNISTON: I see. 9 MS. LASSWELL: It's the first item. 10 MR. DENNISTON: Okay. And the access 11 settlement charge? 12 MS. FENNELL: Jim, both of those are 13 under the ULS with interim shared transport. We were 14 trying to keep all those issues grouped together. 15 MS. PUGH: Any more questions for Terice? 16 I'm Yvette Pugh, Ameritech Michigan. And 17 I'm covering the next item, the xDSL loop conditioning 18 charges. 19 And there were concerns or comments 20 regarding our charges, specifically, the nonrecurring 21 charges for removal of bridge tap, our load coils and 22 voice grade repeaters. 23 And the comments were that the charges 24 were excessive and not cost-based. And I think this is a 25 very easy one.

398 1 At the time that we filed the tariff, we 2 also did file cost work supporting our costs. And those 3 are available to all of you subject to a proprietary 4 agreement. And I think once you review that information, 5 you'll see that our rates are justifiable and cost-based. 6 MS. CAMPION: Just like all the others 7 have been. 8 MR. REIDY: I'll just go right on a limb 9 here. AT&T requests copies of those cost materials. 10 MR. ANDERSON: And we have not had a 11 proprietary agreement thus far for a confidentiality order 12 in this case. And I think we indicated at one of the 13 earlier meetings we thought we could work one out. We 14 have done it certainly enough times. Can we just use 15 something -- 16 MR. REIDY: Were the cost-based filed in 17 the 11831 docket as well? 18 MR. ANDERSON: Not these, no. These were 19 new studies for the new services. 20 MR. GREGG: These need to be consistent 21 with 11831. 22 MR. ANDERSON: Oh, absolutely. 23 MR. GREGG: They should be the same 24 costs. 25 MS. PUGH: And they were.

399 1 MR. ANDERSON: I mean, they are 2 consistent with -- 3 MR. GREGG: What is different? 4 MR. ANDERSON: They are consistent with 5 the methodologies. It's just how the studies get put 6 together. 7 MR. GREGG: What's different? 8 MS. LASSWELL: It's a new service. We 9 did not have xDSL loop conditioning in the biannual 10 filing. But it does use all the same factors, methodology 11 that was ordered in 11831 in the cost docket. 12 MR. DENNISTON: On what page of the 13 tariff are these charges set forth? It's in section 2. 14 MR. GOULD: 811. 15 MS. PUGH: Part 19, section 2, 8.1. 16 MR. REIDY: I guess my -- I'm proceeding 17 from memory here, but in the BRE case I thought the 18 Commission's order was if Ameritech intended to tariff any 19 type of special construction charges, that they would do 20 so in the 11831 docket. 21 MS. CAMPION: That's my recollection as 22 well. 23 This is Joan Campion. 24 MR. ANDERSON: Well, first of all, in the 25 BRE 2 special construction guides, 11735, the issue of

400 1 xDSL loops was not at issue. There were no xDSL loops at 2 issue in any of the orders in that case. And the 3 Commission order did specifically limit itself to the 4 orders that were at issue in that case. 5 Expressly, the only conditioning charges 6 at issue in that case were, I believe, a 56k loop, but 7 none of the DSL loops. 8 MS. FENNELL: DS1 and 64k were the only 9 digital loops. The rest were POTS. 10 MR. ANDERSON: And since that time the 11 FCC's UNE remand order came out, addressed the requirement 12 for the xDSL loop conditioning and clearly stated that the 13 loop conditioning costs had to be filed, filing the loop 14 conditioning costs consistent with the FCC order. 15 MS. REIBER: This is Rachel Reiber from 16 Sprint. 17 So how do we go about getting the cost 18 studies that led to these prices? 19 MR. ANDERSON: We can -- AT&T has 20 requested, and I will circulate amongst counsel a copy of 21 the proposed protective agreement if we don't want to go 22 to an order. 23 Tom, is that process okay with staff? 24 MR. LONERGAN: Let's ask Steve. Steve 25 Hughey is here, our counsel.

401 1 MR. HUGHEY: I don't think there's a 2 problem as long as we keep it limited to what the 3 information that we're dealing with here in the cost 4 information. 5 You probably know, Craig, staff has a 6 difference of opinion with Ameritech on some of the market 7 stuff. So what we do want to avoid certainly at this 8 point is having some kind of a global protective agreement 9 that you or anyone else would argue, well, that covers 10 everything that's at issue. 11 So if we can craft some kind of agreement 12 that's limited to this cost piece of it, I don't think 13 that's a problem. 14 MR. ANDERSON: I will be glad to do that 15 and circulate that soon, within -- I'll have one out to 16 everybody by Monday. 17 MS. FRENTZ: To the attorneys, Craig or 18 through John Kern? 19 MR. ANDERSON: I can send it to John. I 20 don't have a problem with sending it to everybody on the 21 list, if everybody wants it. 22 MR. SEVERANCE: So where do we go from 23 here? We look at that cost study and based on one week 24 review or whatever we have before the next collaborative 25 meeting, should we be prepared to bring our cost folks

402 1 with us? Or what happens after we look at it and we say 2 we don't agree with it? 3 MR. LONERGAN: Well, I don't think we 4 intend this collaborative to be a cost docket. So if you 5 disagree and you think that that's going to amount to 6 impasse, then I think we go to the next stage, which is we 7 take this aside and we say, let's go with a complaint or a 8 docket. 9 If your disagreements are minor enough 10 that maybe a meeting of this group can resolve those, that 11 may be a different story. But I don't intend taking 12 testimony from cost experts and all that sort of thing in 13 this sort of a forum. I just don't think that would work. 14 So I guess it's the extent of your 15 disagreement. If it's something that can be worked out 16 around this table, okay. But if it's going to -- if we're 17 going to have a battle of experts, I don't think this is 18 the place for that. 19 MR. GREGG: Seems to me there's a 20 difference between what rates we're going to put in there 21 versus what text we're going to put in there. 22 If we can at least agree here with what 23 kind of text needs to be in there, I think that would go a 24 long way to getting something. And then if we disagree 25 with the rates, that would have to go to a contested case

403 1 probably. 2 MR. LONERGAN: Part of the reason for 3 this is to make sure we have all of the appropriate 4 services that are then going to go into the test plan. 5 The rate is something we could probably deal with, as Rod 6 says, separately, if there's a big disagreement over 7 rates. 8 But the key to me is to have all the 9 services identified that ought to be in the tariff and 10 therefore available and therefore tested. 11 MR. REIDY: And I think that's right. 12 Except that if one believes that there is no cost basis 13 for the rates that have been listed in the tariff -- I 14 could tell you that the costs that are listed there could 15 be competitively prohibitive to somebody who wants to 16 provision xDSL. 17 When we go to design a test, the question 18 becomes, how many people are going to order xDSL from 19 Ameritech if they are going to be paying 534 bucks to 20 remove a load coil every time they have to do it? 21 And if your position is that those costs 22 are already recovered in the recurring rates, I don't want 23 to bring any cost experts either. But if we're going to 24 design a test that actually tests a product that's 25 commercially viable, we may have to enter into some of

404 1 these issues. 2 MR. LONERGAN: I'm not disagreeing with 3 that. We have sort of different time frames associated 4 with them. 5 MR. ANDERSON: And just to address, Jim, 6 in part your concern about timing, we can endeavor, I 7 think we can get that proposed agreement out faster, in 8 the next day or two, because I think it is pretty standard 9 what we have done before and I'll expedite that in a day 10 or two. 11 MR. LONERGAN: Before we adjourn here, 12 we'll talk about next steps and scheduling and how much 13 time you need to look at that and where do we go from 14 here. 15 I want to make sure that about 2:30 we do 16 that because I understand some of you have planes to catch 17 planes in the neighborhood of around 4:00 o'clock. Even 18 if we're not all the way down the list, we need to talk 19 about next steps. 20 MR. GREGG: Okay. Next up is -- 21 MS. FENNELL: OSS. It's listed as OSS 22 for UNE-P -- 23 MS. LICHTENBERG: Could you guys get 24 closer to the microphone, please. 25 MS. FENNELL: I'm sorry, Sherry. I was

405 1 reading from my note -- this is Kelly -- and I turned my 2 head. So let me move my note. 3 OSS for UNE-P and ULS with IST, I think 4 this was an MCI comment. And that was to not only to have 5 an EDI ordering interface available, but also a GUI. 6 MS. LICHTENBERG: We are unclear as to 7 why you do not have a GUI available for smaller CLECs or 8 for the times when an EDI link is down or some other point 9 in time. 10 We know that one exists at SBC, your 11 parent company, and pretty much every other ILEC. 12 MS. FENNELL: In the plan of record, and 13 Scott talked about that earlier when we were talking about 14 the MLT, the mechanized loop testing, that is in the plan 15 of record for a GUI interface for ordering, for 16 implementation, and it looks like, according to the plan 17 of record, in March of 2001. 18 So we're looking at one of the 19 enhancements coming down the road from the merger. 20 MS. LICHTENBERG: So again, this is 21 another one of these promises sometime in the future. 22 MS. FENNELL: It's something planned for 23 the future, yes. 24 MS. LICHTENBERG: I think you know in MCI 25 Worldcom's opinion this is an absolutely critical piece of

406 1 the equation. And we would want to see this much earlier 2 than that. 3 MS. FENNELL: And I can't address, 4 Sherry, as to the scheduling of that. That's really more 5 for our OSS experts who aren't here today. But I know 6 that we're working hard and furious to make all of these 7 great system changes and they do take time. And I'm sure 8 that's an aggressive schedule. 9 The other thing -- I'll just throw this 10 out just so we have our point sort of on the record -- 11 that the FCC in our first order, our 1997 order where our 12 271 was rejected, the FCC did note that the "incumbent LEC 13 does not have an affirmative obligation to provide 14 multiple interfaces to competing carriers if it is able to 15 demonstrate that its interface is economically efficient 16 to use by both larger and smaller entrants." 17 And that's FCC 97-298, paragraph 220. 18 And my understanding and, again, I'm not 19 the OSS expert, is that a number of carriers, both small 20 and large, are using the EDI interface. And we don't have 21 this affirmative obligation to provide multiple 22 interfaces. 23 So we are working toward it, but it's not 24 an obligation on our part at this time. 25 MR. DENNISTON: Is the basis that it's

407 1 not an obligation, is that the basis for the March 1 early 2 roll-out? 3 MS. FENNELL: I don't know the basis of 4 the roll-out. I'm not involved, Jim, in how the schedule 5 was set. As I said, we're working fast and furious to 6 make a number of enhancements and changes to our OSS. 7 And many of you are aware of it, being 8 involved in the plan of record work and other 9 collaborative work across the region. So I can't answer a 10 more detailed question. 11 MR. DENNISTON: I don't have the New York 12 order memorized and I don't have it in front of me either. 13 But my recollection is the order referenced the fact that 14 out of the hundred or some CLECs in New York, I think 15 three or four were using EDI, the rest were using GUI. 16 MS. FENNELL: I'm not familiar with that 17 part of the New York order. I know we have a number of 18 CLECs using EDI. It's more than three or four. 19 MS. LICHTENBERG: And will you be 20 providing that data on the number of CLECs that are 21 actually using your full EDI implementation that developed 22 to it for UNE platform or UNE ULS-IST, or whatever we're 23 calling it here? 24 I am a little surprised that you have 25 that many ordering UNE platform via EDI.

408 1 MS. FENNELL: Sherry, as we indicated 2 earlier, no one has ordered UNE-P or ULS with interim 3 shared transport yet at all. 4 MS. LICHTENBERG: So, again, relying on 5 EDI probably doesn't work or the most -- the method by 6 which most real residential competition will take place. 7 MS. FENNELL: Well, I think we have got a 8 chicken and egg thing. No one is ordering it yet. They 9 are ordering other services and are up and functioning on 10 the EDI interface. 11 MR. DENNISTON: Is the GUI available for 12 the other services? 13 MS. FENNELL: I don't know what's 14 available for what, Jim. 15 MR. ALEXANDER: That's explained in the 16 plan of record in pretty gruesome detail in terms of the 17 current state of the OSS and then the future state of the 18 OSS on a timetable. 19 And the GUI that Kelly was describing was 20 going to be a uniform GUI application, which I'm assuming 21 to be across at least the Ameritech states and probably 22 across a broader region than that. 23 So I believe that played into dictating 24 the time frames was that the commitment was to implement a 25 uniform GUI platform.

409 1 MR. DENNISTON: Is there a GUI platform 2 currently in Texas? 3 MS. LICHTENBERG: Yes, there is and it's 4 called Verigate. It's part of a system -- there's a 5 preorder and order system under Verigate and Toolbar with 6 a system called LEX for GUI-based ordering of UNE platform 7 and EASE for ordering of resale. 8 MR. DENNISTON: I take it then the 9 Ameritech folks here do not know whether come March 1 10 we're using the Texas GUI or a brand new GUI? 11 MS. FENNELL: I don't know. I think 12 that's better posed for our OSS folks like Joe Rogers or 13 Joe Magiera who were here at the OSS collaboratives. 14 Those folks are the experts. 15 MR. DENNISTON: Another question on this. 16 You mentioned that the GUI for ordering would be available 17 March 2001. Did you also mean to include preordering, 18 maintenance repair? 19 MS. FENNELL: It has preordering GUI. 20 I'm looking at the plan of record, the FCC FMO time line 21 release schedule which is on page 54 of the FCC plan of 22 record. It has preordering and ordering on that. 23 And then under repair and maintenance -- 24 and Sherry probably knows more about this than I do -- the 25 MLT EBTA and GUI are in April, as Scott indicated earlier.

410 1 And then there's another TRF-D3 and history window GUI 2 update, looks like scheduled for June of 2000. Now, what 3 that interface does, I couldn't tell you. 4 MS. LICHTENBERG: Actually, I am totally 5 confused by all of your GUIs. 6 We do believe however that this is a 7 critical piece, particularly to smaller CLECs. 8 MS. FRENTZ: Sherry, what was the term 9 you mentioned that Texas may have? 10 MS. LICHTENBERG: Texas has a system 11 called Verigate. And it's an overall GUI type 12 implementation. It's also referred to as a Toolbar. It 13 has various halves, they call it. LEX is for ordering. 14 Verigate is preorder information. It is a down-loadable 15 software package. It's also used in Pacific Bell. It's 16 used throughout the entire SBC footprint, except the 17 Ameritech states. 18 MR. RALLS: This is Bill Ralls. 19 One of our clients is the CLEC 20 Association of Michigan and we have a number of very small 21 CLECs in Michigan. 22 This potentially would be critical to 23 sell them. I appreciate what you have said about the 24 limits of your knowledge. But it would be very helpful to 25 have someone here at the next collaborative address

411 1 specifically these issues. 2 MR. ANDERSON: Well, let me just add, I 3 think those people are at the OSS collaboratives. Those 4 are the people who are the experts in the OSS system. As 5 Kelly said, Joe Rogers, Rick Dishman, Joe Magiera, who can 6 address these issues. They have been here for all the OSS 7 groups. 8 MS. FENNELL: And they will be back here 9 on April 11th. 10 MS. LICHTENBERG: Again, I think it would 11 be really -- maybe we should make this whole list of what 12 we need for that April 11th meeting and the following to 13 make sure that all the right experts are available. 14 MR. BENNETT: Just on this same point -- 15 this is Bruce Bennett from AT&T. 16 On this same point, you do identify later 17 on in your tariff -- I believe it's page 35 -- you outline 18 a little bit what the electronics systems are going to be. 19 I'd like to see an expansion of that to 20 include whatever you are really going to do. Because what 21 it says in here is that you are going to have an 22 electronic bonding interface. Personally, I think of 23 electronic bonding as maintenance. And that's the way you 24 describe your ordering interface. 25 So I think it needs to be reviewed and

412 1 more specificity put behind what you are actually going to 2 use in the way of interfaces and GUIs. 3 MR. ANDERSON: Well, Bruce, I just 4 expressed the same concern. We have stated several times 5 that it may get to a level of detail that we don't believe 6 is appropriate for tariff. 7 MR. BENNETT: I'm just talking about 8 three sentences here, Craig. 9 MS. LICHTENBERG: Electronic bonding is 10 an absolute misnomer in terms of EBI ordering, if that's 11 what you are proposing. 12 MR. BENNETT: I mean, electronic bonding, 13 an electronic bonding interface, EBI is the maintenance 14 interface, correct? 15 MS. LICHTENBERG: That is correct. It is 16 not used for ordering. 17 MR. BENNETT: So we at least have a 18 reference to the right interface in there. And I would 19 also think we would want to expand this to better describe 20 what those interfaces are and include GUIs too if you are 21 going to support it with a GUI. 22 MR. REIDY: And to answer, that, Craig, I 23 think that's in line with what we have said in the OSS 24 collaboratives. I mean, although I don't agree with 25 Ameritech's position, your position, as I understand it,

413 1 is we're going to test what's in place now. 2 I think it's important that as a matter 3 of your tariff that we know essentially what Ameritech 4 thinks is in place right now. 5 You know I'm going to argue that that's 6 the wrong way to go. But if that's the way we end up 7 going, I think it's important that the tariffs reflect 8 that. 9 So I don't think this is a level of 10 detail that is onerous in any way. 11 MR. GREGG: Is there a definition in the 12 tariff of what electronic bonding interface is? 13 MS. REIBER: EBR or EBI? 14 MR. BENNETT: E-B, B as in boy. 15 MS. REIBER: That's maintenance repair. 16 MR. HAMPTON: Let me talk about those 17 words a little bit that everybody is pulling apart here 18 because I was involved in creating those words. 19 We consciously chose electronic bonding 20 instead of speaking to specific EDI or whatever, because 21 of the discussions going on as to the fact that those 22 electronic interfaces are changing and they do change over 23 time. And we are specifically not specific into the 24 tariff as to what they were, so that we did not have 25 long-term tariff maintenance as we agreed on different

414 1 interfaces, to have to come back in and change the 2 language of the tariff. 3 Now, maybe electronic bonding was a bad 4 choice of words. But the intention was to indicate that 5 there were going to be electronic interfaces for the 6 ordering, provisioning and preordering processes of the 7 services. And that's what those words are representing. 8 They are talking about EBTA. They are 9 not talking about data. They are talking about whatever 10 we wind up agreeing as the correct electronic interfaces 11 and the ones once that we put out there was to be a 12 generic term addressing the electronic interfaces for 13 ordering and provisioning of these services. 14 There was no intent in creating those 15 words for it to be pointing to the EBTA. It was 16 intentionally pointing to leave the specific interfaces 17 being addressed in our TCNet material or electronic 18 ordering guide or unbundled product guide. Because those 19 change over time. 20 I mean, we have been through iterations 21 in the last six years that we have been having these 22 products out here, just exactly what those electronic 23 interfaces are. So the intention was to try to use the 24 generic term to talk about the electronic interfaces and 25 that the interfaces would be electronic.

415 1 So, I mean, that was the choice of words. 2 And if we need to change them to something different 3 that's even more generic than that, that's fine. But the 4 intent was to be a generic term that has those interfaces 5 changed over time to different things, that we didn't have 6 to go back and make tariff updates. 7 Sort of like a billing system. What 8 billing system did you use? What electronic interface did 9 you use? The point was to state that they were 10 electronic. So that the orders were received 11 electronically. You had access to the information you 12 needed to prepare the orders electronically. Billing 13 media was electronic. Maintenance processes were 14 electronic. That was the intent of the language, for what 15 it's worth. 16 MR. GREGG: Would it provide more comfort 17 if they put in some kind of definition that said this is a 18 generic? 19 MS. RAINEY: This is JoAnn Rainey with 20 MCI WorldCom. 21 I think it would be helpful to clarify 22 that because from an industry perspective electronic 23 bonding has certain implications with regard to trouble 24 administration. It's a different protocol using CMIS 25 protocol, some of the EDI CORBA development.

416 1 So I think it would help to clarify this 2 electronic interface or E-commerce or something like that. 3 MR. REIDY: And my response is, in other 4 parts of the tariff we have technical references listed, 5 we have other reference material available or at least a 6 reference to determine what the actual specifics of the 7 tariff offering is. 8 So I'm still not clear why in this aspect 9 there's a reluctance to make that type of information 10 available. I'm looking at section 2, sheet number 5, 11 where if you order a loop, you know what you're going to 12 get because you are going to order it pursuant to the 13 technical reference, Ameritech unbundled analog loops. 14 MR. HAMPTON: But section 2 applies as 15 well. 16 MR. REIDY: I understand. But I'm 17 saying, why not provide the type of specificity for 18 ordering that you are providing for technical details on 19 the loop design. 20 MR. ANDERSON: Well, because you're not 21 ordering the ordering system when you order, Jay, you are 22 ordering the product. And the technical references 23 related to the product, they describe the service. 24 The tariff fundamentally contains the 25 service description and the price for the service and the

417 1 fundamental terms and conditions of the service. 2 And we can keep going back to this 3 debate. I don't think the ordering system -- we don't 4 want to have to change the tariff every time some detail 5 in the ordering system is changed. That's what the change 6 management process is for. And nothing you pointed to 7 relates to the ordering system. And I don't think it 8 should. 9 MR. REIDY: I disagree. 10 MR. ANDERSON: And it's not the first 11 time. 12 But we'll take it back and see what we 13 can do with language to address the concern. 14 MR. GREGG: Shall we move on? 15 MR. HAMPTON: We're up to -- I'm Jerry 16 Hampton with Ameritech. 17 We're up to the discussion relative to 18 unbundled local switching with interim shared transport. 19 There are several issues here that were requested to be 20 addressed. 21 The first one was essentially, where did 22 the rates come from for ULS, the usage charge, the ULS-IST 23 usage charge? 24 The second one was, where did the rates 25 come from for the access credit charge?

418 1 Questions relative to the line 2 information database 911, DA-Data, are those going to be 3 maintained for a ULS-IST customer? 4 Questions relative to the OS/DA branding. 5 That's pretty much it. The others -- there was a question 6 about call routing for toll calls. I think that will be 7 addressed as we talk about the actual pricing of grading 8 structure for free ULS. 9 I tried to get what I think is the easy 10 off the board here first and that is relative to the -- is 11 the information ULS-IST customer going to be maintained 12 and would be. And as the call is processed, will we 13 utilize that LIDB information? The answer to that 14 question is yes. 15 Information that's relative to the 16 account will continue to be maintained in the LIDB 17 database as a result of the ULS port service. 18 911 access to that database and the data 19 in the database relative to this telephone number will be 20 maintained. That's part of the ULS product. 21 MR. HAMPTON: The DA data. If you look 22 at the tariff, it specifically states that with the ULS 23 product and with ULS-IST, which is just an addition to 24 that ULS product, that it does include the white page 25 listing. So that white page listing will be maintained as

419 1 well. 2 Unless someone has another question -- 3 MR. REIDY: Well, I understand the 4 reference to DA. But as to the LIDB and the 911, are 5 there tariff references you can point me to where it's 6 stated that Ameritech will maintain it? 7 MR. HAMPTON: The LIDB information there 8 is not a specific tariff reference, other than it talks 9 about office features, functions of the switch, okay. 10 And that's in the -- 11 MR. REIDY: I understand that you are 12 offering all features and functions of the switch. 13 MR. HAMPTON: LIDB is a feature function 14 of the switch. 15 MS. LICHTENBERG: This is Sherry 16 Lichtenberg. I have a very specific question on that 17 LIDB. In your current owner's company in Texas, they do 18 not update the LIDB data for the customer. And they force 19 the CLEC to do it. That was the subject of litigation in 20 the Texas public utility commission and they have not 21 changed their system to meet all requirements yet. 22 Will an order from a CLEC update the 23 customers' LIDB listing or will you dismantle that 24 listing? 25 MR. HAMPTON: Tell me some more. What

420 1 specifics are you talking about? I need specific 2 information. 3 MS. LICHTENBERG: I am specifically 4 saying that if I switch a customer from Ameritech to MCI 5 WorldCom, and I decide that I want him to block the 6 ability to accept collect calls, will Ameritech make that 7 change or will Ameritech force CLECs to go through some 8 other system to do that when we are selling UNE platform, 9 or whatever you call it? 10 MR. HAMPTON: If they had call blocking 11 on that service before it was changed to UNE platform, it 12 would continue to carry that unless you asked us to remove 13 it. Or you may send a subsequent order to add blocking to 14 the account. 15 MS. LICHTENBERG: I'm talking LIDB. I'm 16 talking the inbound blocking option. So you do not use a 17 system equivalent to the LVAC system in SBC? 18 MR. HAMPTON: I'm not familiar with that 19 system in SBC. 20 MS. LICHTENBERG: Will you specify in 21 this tariff that LIDB options and 911 options will be 22 handled as part of the ordering? 23 MR. HAMPTON: We can take this back. I 24 guess what I'm saying is that anything would have been in 25 LIDB relative to the account that we would have maintained

421 1 in LIDB before, would still be maintained there. We're 2 not going to change our processes for how we do certain 3 features and functions. 4 MS. LICHTENBERG: You will not be 5 adopting the Southwestern Bell processes? 6 MR. HAMPTON: Not for ULS-IST. 7 MS. LICHTENBERG: But presumably in your 8 next tariff? 9 MR. HAMPTON: I can't speak to what's 10 happening with long-term shared transport. I'm not 11 creating that product. I'm not involved with its 12 creation. 13 MR. HAMPTON: There was another question. 14 MR. BENNETT: I just didn't get 15 resolution to that. Were you going to add a sentence that 16 says you'll maintain the existing LIDB 911? 17 MR. HAMPTON: We can take that back and 18 look at that. 19 MR. BENNETT: Thank you. 20 MR. HAMPTON: My view is that it's 21 basically already there. But I don't think there's a 22 problem to take it back and look at that. 23 MR. BENNETT: It's the subject of a lot 24 of litigation. That's why we're interested. 25 MR. HAMPTON: And there was another.

422 1 What was the other one? 2 MR. REIDY: That was my question. My 3 question essentially, you're going to add it to the tariff 4 because we don't see it there yet. And that's what I hear 5 you saying, that you'll take it back. 6 MR. HAMPTON: I'll take it back and look 7 at it. 8 Okay. Let's talk now -- there were 9 questions relative to the way that the rates were created 10 for ULS-IST. 11 At the time that we filed the ULS-IST 12 tariff in September, along with that we included 13 worksheets that described the calculation. Okay. 14 Let's go ahead. I brought along copies 15 of -- when the rates were updated with the cost docket 16 biannual filing, okay, we reran those calculations using 17 the rates that were the new TELRIC rates. 18 So what they are passing out right now, 19 because in order to walk through this rate process, I'm 20 passing out a copy of that material. But it's based upon 21 the rates and supports the rates that are in the current 22 version of the tariff. 23 The process is the same. The way we 24 created the rates is the same. It's just that we plugged 25 the new rates in from the biannual.

423 1 Just a little explanation as to how these 2 rates were created. The rates were created by -- let's 3 step back. The ULS-IST, when we agreed to provide this 4 interim solution, we have long at Ameritech argued 5 relative to the shared transport order that there was 6 basically four problems with the order in implementing it 7 the way it was written. 8 So in order to solve those problems, we 9 had a problem that the original FCC order required 10 dedicated links and customer routing if you are going to 11 get to any switch that was not an Ameritech switch. So we 12 had to deal with that problem. 13 The second problem that we had was it 14 required us to measure terminating calls, both for local 15 and access. The switches are not capable of measuring the 16 terminating call. There is no terminating call record on 17 the local call. 18 MR. BENNETT: Just for clarification, 19 Ameritech switches aren't capable of doing that? 20 MR. HAMPTON: Ameritech switches are not 21 capable of doing that. I don't know of anyone else's 22 switches that are capable of doing that either. 23 MS. LICHTENBERG: Help me out here. 24 You're saying that your switches are not capable of 25 tracking access? Is that what you're telling me?

424 1 MR. HAMPTON: No. 2 MS. LICHTENBERG: Can you restate it? I 3 didn't hear you very clearly. 4 MR. HAMPTON: My statement was that on a 5 local call, Ameritech switches -- and to my knowledge, I 6 don't know of anyone's switches that on a local call have 7 a record, other than there are ways that has been worked 8 around that -- Texas has solved it by using AIN triggers 9 and using an AIN record, but the switches themselves 10 aren't capable of recording the call, at Ameritech. 11 MS. LICHTENBERG: So the ANA (sic) record 12 that I get in Bell Atlantic territory from their class 5 13 switches, their DMS 100 and their 5 ESSs, would show me 14 the exact dial digits and give me this information. 15 Your equivalent switch cannot generate 16 that record. Is that what you're saying? 17 MR. HAMPTON: They cannot. They cannot, 18 not on a terminating call. 19 MS. LICHTENBERG: So on your class 5, for 20 instance, on your class 5 fees, what generic are you 21 asked? 22 MR. HAMPTON: I'm sorry. 23 MS. LICHTENBERG: On your class 5 ESS 24 switches, what release are you asked? 25 MR. HAMPTON: I'm sorry. I don't have

425 1 that technical knowledge. 2 MS. LICHTENBERG: I believe I heard you 3 say that the switches are not technically capable of doing 4 that. Everyplace else they are. So I am very confused as 5 to where you got that statement, where your technical 6 people pointed you for that statement. 7 MR. HAMPTON: Okay. And I believe 8 that -- I have been in talk with, pretty much as a result 9 of these conversations, I pretty much have talked with 10 every company. And to my knowledge, no one has the 11 ability to record terminating usage on a local call. 12 All of them have created a work-around 13 for that in some way, shape or form. My understanding, 14 Bell Atlantic uses an originating record to create a 15 terminating record from. SBC is using an AIN trigger to 16 create a record. 17 MS. LICHTENBERG: So you're talking about 18 the terminating record? 19 MR. HAMPTON: I'm talking the terminating 20 record. There is no recording made on a local call at the 21 terminating port. 22 MR. ANDERSON: So your point is that 23 Ameritech hasn't done their work-around yet? 24 MR. HAMPTON: We have to figure a way to 25 work around that problem.

426 1 MS. CAMPION: This is Joan Campion from 2 MCI WorldCom. 3 I don't think it's limited to local. 4 Doesn't it also include access, and that's why you have 5 this access settlement charge? 6 MR. HAMPTON: No. The access settlement 7 charge is different. I haven't got to that bullet point 8 yet. 9 We do have a record of originating and 10 terminating access. The access problem is that in looking 11 at an access record, there is no indicator in that record 12 that you can look at that tells you did it originate or 13 terminate to a ULS port. 14 So we had no way of pulling that record 15 out of the access billing process. 16 MS. LICHTENBERG: Wouldn't you have a 17 line class code that would show what port you were coming 18 from? 19 MR. HAMPTON: No. 20 MS. LICHTENBERG: Or a PN that would show 21 who owned that record? 22 MR. HAMPTON: Not in the records that are 23 passed through our system. 24 MS. LICHTENBERG: Not on the originating 25 record, it doesn't show the station number that originated

427 1 the call? 2 MS. CAMPION: On terminating -- 3 MS. LICHTENBERG: I thought I heard 4 originating. 5 MR. HAMPTON: Originating does not have 6 an indicator in that record that can tell us it started 7 from a ULS port. 8 MS. LICHTENBERG: Although it does have a 9 station indicator, correct? 10 MR. HAMPTON: The billing system never 11 sees anything other than the NPA-NXX. 12 MS. LICHTENBERG: Does it see the 13 originating phone number of the call? 14 MR. HAMPTON: No. 15 MS. LICHTENBERG: Only the terminating 16 phone call number? 17 MR. HAMPTON: No. 18 MS. LICHTENBERG: And therefore, if you 19 don't know who originated the call, how are you sending me 20 a usage fee for the call? 21 MR. HAMPTON: I can't on an access call. 22 That's the problem. 23 MS. LICHTENBERG: Okay. 24 MR. HAMPTON: Okay. I'm describing the 25 problems that we had to create a solution for and then I'm

428 1 going to explain to you the solution that we created in 2 order to create this IST product. 3 MS. LICHTENBERG: Okay. I wish I had a 4 picture. I apologize. 5 MR. HAMPTON: Okay. So let's go back a 6 minute. 7 We have a problem with getting a call off 8 the network, okay. Because it required a dedicated link 9 between any office that wasn't on our network. You 10 couldn't do that because if you were using our routing 11 tables, which is a requirement of IS shared transport, we 12 haven't any way to point to a dedicated trunk if we're 13 using our routing tables. 14 You have the problem of you have no 15 terminating call record on a local call. You have the 16 problem on access calls, either originating or 17 terminating, you can't tell that it originated or 18 terminated to a ULS port. 19 And the fourth one was, we were actually 20 supposed to provide transport separate from switching. 21 And we could not figure out a technical way to do that. 22 Okay. 23 So when we agreed to provide the interim 24 shared transport product, we created solutions that would 25 resolve each of those problems. The dedicated link,

429 1 customer rod requirement, what we said was, we'll allow it 2 to transit the network, to go to anyone's switch using our 3 network that we have in place and using the routing tables 4 that we have in place. 5 This means that when it's going to a CLEC 6 or a wireless provider, an ICO or another third party, 7 that we're going to be charged -- us, Ameritech -- because 8 they will have no way of identifying that it didn't come 9 from Ameritech, we're going to be charged some type of 10 charges for that call. 11 We will allow those calls to go across 12 and we bill those charges that were going to be charged 13 into the ULS-IST rate. Okay. 14 The second problem relative to measuring 15 terminating call detail. The way we worked around that 16 problem is that we won't charge on the terminating side. 17 The originating parties, because we do have an originating 18 call record on the calls, we will bill the originating 19 party for the call, because we know who that is and we 20 have a way that we can apply that ULS charge to that and 21 the originating party to the call. 22 The access side of the house, we have no 23 way of pulling those records out of our access billing 24 process because we have no way to identify them. So what 25 we did was we said, okay, a ULS port -- we know that in

430 1 our network, and we did it by state, we know that X port 2 generates X amount of access usage, both originating and 3 terminating -- we calculated those separately -- and we 4 know that there is an average rate per access that we bill 5 for. 6 So we created the access credit which is 7 essentially an average amount per port that we will give 8 you back for those access -- since we can't give you a 9 record that you can bill, we created the credit so that we 10 will give you the amount that we billed. 11 So that's an average because we don't 12 have a way to uniquely identify it by the port. Access 13 billing is done at the office level. There is no way to 14 look at that record and tell whose it was. 15 MS. LICHTENBERG: This is what we used to 16 call rough justice. 17 MR. HAMPTON: This is rough justice. 18 That's exactly it. 19 And then on the originating side of it, I 20 already talked about that, about the originating party 21 pays. 22 So that's the principles that we went in 23 with solving those problems. 24 So what we did is we then looked at the 25 call and said, okay, what do we need to recover for?

431 1 Starting on the calling switch, you have a line port and 2 you have local switching. That's recovered for by your 3 ULS local switching. That will continue to be billed. 4 The line ports are recurring monthly rate in the State of 5 Michigan and the ULS charge is a permanent abuse charge. 6 From the trunk port all the way through, 7 up through and including the termination on the far 8 switch, whatever, whoever, wherever that is, that is 9 what's going to be recovered by the ULS-IST charge. Okay. 10 So what we needed to do was look at the 11 calls and say, okay, there's basically four types calls. 12 If I can find my notes, I can state them, I think. 13 There are calls that are direct routed to 14 an Ameritech end office. There are calls that originate 15 from a ULS port and are through a tandem routed to an 16 Ameritech end office. There are direct routed calls 17 terminating to a nonAmeritech end office. And there are 18 tandem route calls that terminate to a nonAmeritech end 19 office. All right. 20 So we needed to account for all of those 21 situations in this one rate. Okay. 22 I want to start by looking at this 23 assumptions page and go through the assumptions that we 24 used in creating the rate and explain where we took the 25 information from to create that rate.

432 1 The first thing we did was -- 2 MR. DENNISTON: And, Jerry, just to make 3 sure, with people on the phone here -- so that if you can 4 verbally explain what's on the sheet as you get to it. 5 MR. HAMPTON: Fine. I'll do it that way. 6 The first thing we did was we said, okay, 7 we need a usage-based TELRIC rate to represent the 8 portions of the network that are being utilized for this 9 rate. We want it to be a TELRIC base, because that's a 10 requirement of UNEs; and b, we wanted to use rates that 11 were already usage-based and already were supported by 12 cost studies. 13 So all the rates used, other than the 14 access, were TELRIC rates based on -- TELRIC rates that 15 were already filed, already approved and have been updated 16 in the biannual filings. So the rate we created is a 17 composite rate by applying factors to existing cost-based 18 rates, TELRIC rates. Okay. And I'll explain which ones 19 we used for what portions of the network that we were 20 recovering for. 21 MR. REIDY: I don't mean to interrupt. 22 But with regard to the interim shared transport usage 23 charge, is that a composite rate, as you describe it? 24 MR. HAMPTON: Yes. That's the rate I'm 25 describing right at this point.

433 1 MR. REIDY: Okay. 2 MR. HAMPTON: Okay. All of the rates 3 were created specifically using the Michigan TELRICs and 4 were all based on Michigan numbers except in a few cases. 5 And we'll talk about those as we go on. So all of the 6 data that we used was based on Michigan data. 7 The ULS-IST rate is in addition to the 8 existing ULS charges. So it's a usage charge, but it's in 9 addition to, since it recovers for the rest of the network 10 that's not already recovered for in the ULS charges. It's 11 covering from the trunk port through the rest and up to 12 the termination of the call. 13 It's going to apply on all calls. There 14 wasn't a way to identify which kind of call was which type 15 of call, so the rate is averaged in such a manner that 16 it's applied and is going to be applied on every minute of 17 use that starts from a ULS port. 18 Given the structure of the way other 19 folks terminate to our office, we assumed that all traffic 20 going off the Ameritech network -- so it's going to a 21 wireless provider, it's going to an ICO, it's going to a 22 third party CLEC, it's going to you, it's going to an ICO, 23 all of those we assumed were going to be tandem routed 24 type calls. 25 All right. The next thing we had to do

434 1 in order to create this rate was determine average mileage 2 because traffic is mileage sensitive. All right. So we 3 created average mileages. 4 The first one we needed to create was, 5 what is the average distance from an Ameritech end office 6 to a tandem. That value was calculated using switched 7 access data. AIT end office to AIT end office was based 8 upon the ULT circuits that were in place as of July 1999 9 in Michigan. 10 The AIT end office to non-AIT end office 11 was based on several different pieces of information. 12 Basically, a UNE fact report -- there's a list here -- the 13 UNE fact report comments. I would have to actually -- I 14 don't have exactly which cases that these were all in. 15 But these are all public documents in various cases 16 throughout the region and at the FCC relative to -- most 17 of them are information, I believe, relative to how far 18 people think the distance should be. 19 I don't have copies of these with me. 20 But we can produce copies of the documents from which we 21 pulled these distances from. 22 And then the tandem to nonAmeritech end 23 office, we used the same percentage difference as what we 24 would have calculated between an Ameritech end office to 25 an Ameritech end office calculation, or an Ameritech end

435 1 office to an Ameritech tandem. 2 In Michigan that average comes out to be 3 11 miles from an Ameritech end office to an Ameritech end 4 office, 21 miles from an American end office to an 5 Ameritech tandem, 20 miles between an Ameritech end office 6 to a nonAmeritech end office, and then 38 miles from a 7 tandem to a nonAmeritech end office. 8 We assumed that 20 percent of the traffic 9 is tandem routed and 80 percent of the traffic is direct 10 routed. And that information comes from several different 11 ex partes filed by various companies with the FCC at 12 various points in time. 13 Generally, there hasn't been too much of 14 an argument. That is a regional number. It's not a 15 Michigan-specific number. The only documentation that we 16 could find to substantiate that is these ex partes and a 17 filing in an Illinois cost docket and a response to an 18 Illinois cost docket. 19 So that is a regional averaged amount of 20 20 percent tandem, 80 percent direct. 21 The next that we needed an average of was 22 the percentage of calls that are intraswitch. Because if 23 a call is intraswitch, you don't want to apply the IST 24 charge to it because there was no IST involved. 25 There is a report that's created -- I

436 1 believe it's annually. I had the July 1999 or was given a 2 copy for the July 1999 -- it's actually 1998 data, that 3 shows in Michigan 25 percent of traffic is intraswitch. 4 We then had to also calculate how the 5 interswitch traffic, how much terminates to an Ameritech 6 switch and how much terminates to a nonAmeritech switch. 7 You find that 80 percent in Michigan terminates to an 8 Ameritech switch and 20 percent terminates to a 9 nonAmeritech switch. 10 Then the last item was averaging the 11 access minutes and the average access rate. We looked at 12 year-to-date information for our switched access data. 13 You find 175 minutes of originating usage, 152 minutes of 14 terminating usage. And the average rate per minute of use 15 is .011497. 16 Those are all of the assumptions that 17 were used and the averages that were used in creating this 18 rate. 19 Have I lost you yet? 20 MR. GREGG: We're going to have to stop 21 there to make sure that we get the schedule covered. We 22 said we would stop at 2:30 and we are about as far behind 23 as we were for lunch. 24 MR. LONERGAN: Let's take a couple 25 minutes and talk about next steps. And then if there's

437 1 time we go on. And if not, we'll have other days. 2 I'm sure I digested all of that that he 3 just said. 4 Go ahead, Rod. 5 Well, maybe I can just summarize what I 6 thought I heard already, just the next steps. 7 You're going to go ahead and draft a 8 protective agreement of some sort and circulate that next 9 week? 10 MR. ANDERSON: Correct. 11 MR. LONERGAN: To allow parties to look 12 at all the cost data? 13 MR. ANDERSON: Right. And this is the 14 xDSL cost support. 15 MR. DENNISTON: Could we also have 16 whatever supporting documents you have for the IST 17 document that we have? Can we have that produced also so 18 we don't have to go out digging out through the various 19 other -- 20 MR. ANDERSON: Sure, but -- 21 MR. DENNISTON: You referred to some type 22 of internal reports and things like that. 23 MR. ANDERSON: I just don't want to go 24 through the path of getting this in a cost docket, a 25 discovery cost docket.

438 1 MR. REIDY: We're there, Craig. We are 2 already there. We have very basic fundamental challenges 3 to what Jerry just read to us. It might help you to 4 spruce up those documents because this is in the 5 Commission order, in 11831. 6 MR. BENNETT: Just as a practical matter, 7 each of the four things that you identified were 8 originally identified by the FCC when they rejected your 9 271 application back in 1997. 10 None of them have been worked on 11 apparently. Other RBOCs have implemented solutions for 12 every one of those things. And all the gyrations that 13 you're going through to develop this huge blended rate 14 could have been worked around, if you had just worked on 15 the systems so that you could record the usage correctly. 16 True? 17 MR. ANDERSON: No. 18 MR. LONERGAN: I would suggest that the 19 attorneys need to decide what's in and what's out of this 20 agreement. But, again, it's not I don't think the intent 21 to use this docket as a costing, a new TSLRIC case. If 22 that's needed, we needed to take that and put it into its 23 own docket and begin working on it. 24 I see Steve is shaking his head. Of 25 course he is going to be in Bermuda next week.

439 1 MR. ANDERSON: Can we ship cost documents 2 to you, Steve? 3 MS. SCHNEIDEWIND: We're going to bring 4 them personally. 5 MR. LONERGAN: In any event, I assume 6 whatever cost information becomes available, you're going 7 to need some time to look at that before we want to get 8 back together again. 9 MR. BENNETT: Could I just ask one point 10 of clarification on that? 11 Does all this go away when the AIN 12 solution is put into place in October? Will there be an 13 actual measurement that you will be doing at that point? 14 MR. HAMPTON: For the most part, yes. 15 The one thing that I know doesn't go away 16 with the AIN solution, because SBC still has the problem, 17 and that is direct versus tandem routed. You still have 18 to blend direct versus tandem routed. 19 But the problem of an access record goes 20 away. The problem of us being billed when you all should 21 be billed for the recip. comp. goes away. Being able to 22 give you a record goes away. Us billing on the 23 terminating side of the call goes away. 24 I mean, the majority of all of these go 25 away. AIN is the proposed solution to resolve those.

440 1 MR. REIDY: This is my last, very simple 2 question. I asked it at the beginning of your 3 presentation. I want to make sure that I understand what 4 you just identified as the cost support for the rate. 5 Again, we're talking only -- you did 6 not -- what you just talked about in terms of supporting a 7 rate was not for the access charge settlement charge, but 8 for the interim shared transport usage charge alone, 9 correct? 10 MR. HAMPTON: Right. The access credit 11 is just a matter of taking average minutes of use at the 12 access rate and subtracting out what the ULS charges for 13 those same minutes of use would be. 14 MR. REIDY: I just wanted to make sure I 15 still disagree with you. 16 MR. ANDERSON: I think we can take that 17 as a gift. 18 MR. LONERGAN: Let me suggest that the 19 protective agreement needs to be executed. The cost data 20 needs to be distributed. 21 I would suggest CLECs that have specific 22 language changes to the tariff, you might want to make 23 those or send those ideas to Ameritech people. They have 24 already agreed to take certain things back and look at 25 them and rehash them.

441 1 I would presume you would benefit from 2 getting specific suggestions from these people if they 3 have items that they want you to look at. 4 MR. REIDY: Will you want us to make 5 changes to the tariff? 6 MR. LONERGAN: I'm saying, if you have -- 7 I'm opening that possibility up. 8 MR. REIDY: I was going to request a word 9 version of the tariff, if I may, as a means of presenting 10 some of my -- 11 MR. DENNISTON: Redline comments to it. 12 MR. REIDY: Yes. I mean, currently I 13 think it's an Adobe document. 14 MR. ANDERSON: We'll look at it. 15 MS. FRENTZ: We have a genius who can do 16 it. 17 MR. REIDY: I'm sure you had it 18 originally in words. And then they can explain it to me. 19 MR. DENNISTON: And the sooner you can 20 get that to us, the better it is, the more time we'll have 21 in which to have redline comments back to us folks. 22 MR. GREGG: What dates are we talking 23 here? We have our next tariff collaborative scheduled for 24 the 13th. 25 MR. REIDY: Well, there's some dispute.

442 1 Is it the 13th or the 14th? 2 MS. FRENTZ: It's the 13th. 3 MR. LONERGAN: Tentatively we had said 4 the 13th. 5 MS. FENNELL: And there are still some 6 unfinished issues from this list too. 7 MR. LONERGAN: Yes, there are. Do you 8 want to go ahead with that date? 9 MS. LICHTENBERG: I'm sorry. I didn't 10 hear. What dates are we proposing for what? 11 MR. LONERGAN: April 13th to continue 12 this discussion regarding the tariff. 13 MS. LICHTENBERG: If I remember, there's 14 an April 11th meeting for third-party testing and then an 15 April 12th for the market conditions. 16 Would it be possible to switch this 17 meeting on the 13th for the meeting on the 12th? That is, 18 continue the tariff on the 12th, do the third-party 19 testing meeting on the 11th and then have market 20 conditions on the 13th? 21 MR. ANDERSON: I don't think we can have 22 the people here you need. 23 MR. RALLS: No, no. This is Bill Ralls. 24 It's important that we have someone here 25 for the market conditions and we're not going to be

443 1 available on the 13th. 2 So we're not opposing not going forward 3 with the tariff collaborative on the 13th. But I would be 4 opposed to switching. 5 MS. FRENTZ: And we would too from 6 scheduling. 7 MS. LICHTENBERG: I guess my concern is I 8 do want to be out there for this, but I don't really need 9 to be there for three days. And I need to be there on the 10 11th and the 13th obviously. 11 MR. DENNISTON: Sherry, this is Jim. And 12 this is a question to everyone. 13 Is the 13th too aggressive of a date if 14 we're going to get redline comments back on the tariff? 15 MR. ANDERSON: I suggest that we're going 16 to get everything we can to you, get the cost studies. 17 But we still have a number of items on the list and I 18 think we can get as much done as we can done. 19 I prefer not to give up a date that we 20 have scheduled. We still have a lot of issues. And I 21 think some of them are the beefiest issues that we have. 22 MR. REIDY: Well, to be quite frank, I 23 wouldn't feel comfortable, I suppose, giving a redline on 24 the tariff until after we have gone through the issues 25 listed at least one time.

444 1 But I don't know how that fits with your 2 schedule, Jim. I mean, we have three collaborative 3 meetings in one week. That's strenuous by anybody's 4 measure. 5 MR. ANDERSON: If you give us some of the 6 tariff changes you do have done on sections that we 7 discussed, with the recognition that we have more to talk 8 about. 9 If you've get some -- if you don't have 10 them yet, we can do more later. 11 MR. REIDY: What I plan on doing is 12 giving you as much notice of what our concerns are. If we 13 have questions out of what came today, I'm going to try to 14 put those in writing and submit those to you. 15 If we agree to do that by a date, that's 16 fine. But my intent is to try and give you as much notice 17 as I can of what our concerns are. So if that's by giving 18 you a redline or giving you another list of questions, 19 then we'll do it. 20 Obviously, I'm not going to sit here and 21 try and bury you in questions because eventually we want 22 to get to filing a complaint. 23 MR. DENNISTON: It seems as though a lot 24 of these issues are interrelated. And we would kind of 25 like go in on a treadmill if we would start doing redline

445 1 comments before we heard the comments we have on the early 2 revisions in the tariff. 3 So I think before we can even get to 4 redline, that we probably have to go through the other 5 issues. 6 I mean, internally we can get started on 7 the process. But we really don't have a document. 8 MR. ANDERSON: Well, from everything I'm 9 hearing, it suggests that we need to go forward on the 10 13th. 11 MR. LONERGAN: Is that what I'm hearing? 12 We would continue this discussion on the 13th with 13 whatever additional information you have accumulated in 14 the meantime. 15 And if you can submit back any 16 information, questions or suggested language to Ameritech, 17 not giving up your right to do another version later, I 18 would encourage you to do that. And staff will be 19 attempting to do the same thing. 20 MR. GREGG: And also Ameritech will come 21 in with whatever changes they have decided they can make. 22 MS. FENNELL: Should we schedule a -- I 23 hate to even say this -- another, a third tariff 24 collaborative meeting. Knowing that we are going to need 25 it, it might be easier to put it on the schedule now.

446 1 MR. LONERGAN: Like a couple weeks past 2 the 13th? 3 MS. FENNELL: Yes. Two weeks past that. 4 MR. LONERGAN: I guess we can try to do 5 that as long as we are all here today. 6 I think I would suggest that that second 7 meeting be kind of our deadline meeting. If we're going 8 to be looking at something in late April or early May, 9 that that would be our goal, to either reach some sort of 10 consensus or not, and decide we don't have that and we're 11 not going to get it. 12 I'm not saying we would rule out further 13 work. But I think we need at some point to decide whether 14 or not we're going to be able to collaborate this thing to 15 conclusion or not. And so, I'm kind of thinking in terms 16 of the second meeting as being that time. 17 Do you have something in mind, Kelly? 18 MS. FENNELL: Two weeks after the 13th is 19 the 27th. That's Easter week. 20 MR. REIDY: That's a difficult week 21 unfortunately. 22 MS. REIBER: Isn't Easter on -- 23 MR. REIDY: It's the week after Easter, 24 the 23rd. 25 MS. FENNELL: 13th, 14th, and then 27th.

447 1 MS. REIBER: But what's the big deal? 2 It's after Easter. 3 MS. FENNELL: Well, a lot of folks are on 4 vacation. 5 MS. FRENTZ: Some folks get Easter week 6 off. That's all. 7 MS. FENNELL: I was trying. I tried. 8 (There was a discussion off the record.). 9 - - - 10 MR. LONERGAN: We're agreeing that the 11 this group, the tariff collaborative, will reconvene first 12 on Thursday, April 13th at 10:00 A.M. 13 And we're also assuming that we will need 14 a second meeting on Friday, May 5th, also at 10:00 A.M. 15 I guess if that's agreed to, if we want 16 to take a few more minutes and go back and talk about what 17 we were talking about -- and I guess we can do that as 18 long as you want to, although I know some of you have 19 flights to catch. 20 MS. LICHTENBERG: I apologize, but I have 21 to drop off. I know you guys are too happy about that. 22 MR. DENNISTON: Sherry, this is Jim. 23 Talk to you tomorrow. 24 MR. LONERGAN: We might as well call this 25 a day unless there's some final comments that anyone wants

448 1 to make. 2 MR. REIDY: We have lots of questions. 3 MR. LONERGAN: But nothing that can be 4 done in five minutes, right? 5 MR. REIDY: We can probably list the 6 questions. 7 The real question is, did you use the 8 AT&T common transport study as ordered in 11831? 9 MR. HAMPTON: This isn't common 10 transport. It's shared transport. 11 MR. REIDY: You answered my question. 12 Thanks. 13 MR. LONERGAN: Why don't we go off the 14 record. We'll conclude the meeting. And if you folks 15 want to ask some questions off the record, go right ahead. 16 (At 3:00 P.M., the hearing was adjourned 17 to 10:00 A.M., Thursday, April 13, 2000.) 18 - - - 19 20 21 22 23 24 25

449 1 2 3 4 5 C E R T I F I C A T E _ _ _ _ _ _ _ _ _ _ _ 6 7 8 I, Donna-Christine Sell, do hereby 9 certify that I reported stenographically the foregoing 10 proceedings had in the within-entitled matter, being Case 11 No. U-12302, at the Mercantile Building, Lansing, 12 Michigan, on Thursday, March 30, 2000; and that the 13 foregoing transcript constitutes a true and 14 correct transcript of my said stenographic notes. 15 16 17 18 ___________________________________ 19 20 21 22 23 Dated: March 31, 2000 24 25