Billing World OSS News Unbundling ILEC OSS

The task of unbundling ILEC OSS functions has been a challenging one, and the deadline of Jan. 1, 1997, hasn't made it any easier.

The FCC stated that by Jan. 1, all the ILECs were to provide "non-discriminatory access to operations support system functions' to any requesting, certified telecommunications carrier. OSS functions have been deemed, by the FCC, as "critical to affording new entrants a meaningful opportunity to compete with incumbent LECs." The interconnection order was passed on Aug. 8, 1996, giving the ILECs less than five months to integrate their legacy OSSs into a more accessible environment and develop the interfaces and security systems necessary to provide and monitor remote access to their back-office databases. The data format and interface standards for OSS access have not yet been established, and some ILECs are questioning the timing of the deadline.

A Difficult Task

Garner Cheney, assistant vice president of information technology at BellSouth, says, "Some of the complexities involved were not appreciated by all parties." This may be true. Integrating multiple legacy systems into a single environment is not simple. The ILECs have had to take stand-alone mainframe systems from several manufacturers and fit them into a uniform, client-server environment that can allow access from a single point of support. Granted, this was essential for the ILECs that needed to cut costs and improve customer service, but it's a difficult job. Interfaces also had to be developed independently that can allow wholesale customers remote access to this integrated OSS environment. BellSouth's initial discussions on access, according to Cheney, "were not as detailed as the FCC order." As a result, he says, BellSouth has had to readdress how they are going to provide access to "more finite elements." Remote access is an extremely sensitive issue and the new gateways into the ILEC back office need to be carefully monitored for two major reasons.

Security issues. First are serious security issues. Ed Pinnes, director of element management systems architecture at Bellcore, points out, "We've all heard stories of telephone company databases being hacked for illegal purposes, anything from terrorism to thwarting FBI investigations, to use data to stalk people. It certainly wasn't the intent of the FCC to make that easier to do." But making telephone company data more accessible does increase the chance of illegal usage. Security systems must be designed to ensure that legitimate users can only see what they are supposed to see, and that outsiders, or hackers, cannot break in. Pinnes adds, "The OSSs are often not designed to have multiple companies accessing them; very often there is not a partitioning scheme, so in general we are looking for the gateways to provide the necessary security and filtering." There must be barriers that separate proprietary data between different companies. Cheney notes that security systems must, for example, "protect an AT&T so that AT&T's data is not accessible by MCI. "As competition grows, the rate of data exchange will grow significantly, and thus the chance for illegal or improper usage to go undetected will grow as well.

Monitoring usage. Second, but equally important to the ILECs, OSS access is considered an unbundled element, one for which the ILECs may charge. To charge, usage needs to be carefully monitored. Again, it is the job of the gateway to keep track of who is on the system and exactly what OSS functions they use. As usage grows, the complexity of billing for OSS services will increase. Add to that mix the future possibilities of a convergence environment, and the billing systems clearly must be "flexible enough to handle new unbundled network elements" such as cellular and television services, according to John Bush, communications services division director at Trecom Business Systems. New billing systems must be developed that can track these types of services, which have never before been provided.

This is merely the surface of the issue. Negotiations are ongoing, state-by-state and company-by-company, regarding what types of interfaces should be provided, what information is necessary to allow true competition and what the charges should be for access. In some cases, as for BellSouth in Georgia, the Jan. 1 deadline has been pushed back two or more months by the state PUCs. Some ILECs, including Nynex and Bell Atlantic, have met the challenge head-on and have solved most of the problems involved with unbundling their OSSs.

Others, such as Southwestern Bell, have seemingly operated in secrecy and are unwilling to reveal their integration and access plans. In fairness to the ILECs, there are no standards or precedents for this type of system re-engineering. It would seem, however, that those who have been most successful will provide a model for the rest of the industry.

Nynex Leads the Way

The New York State Public Service Commission ordered Nynex to be ready for resale throughout the state by Oct. 8, 1996. As a result, Nynex was first in line to open its OSS functions to wholesale customers. Nynex currently provides three different methods for access.

• Wholesale customers can choose to design their own application based on an EDI standard that can send and receive requests to and from Nynex's data center.

• They can choose to build their own application based on what NYNEX calls an EIF, or electronic interface format. EIF is a Nynex proprietary protocol that can be used similarly to EDI.

• The most popular option, according to Nynex, involves a GUI (graphical user interface) designed in-house by Nynex that operates via the Internet and can be accessed by a PC running any standard Web browser, such as Netscape or Microsoft Explorer.

For any of these options, the wholesale customer can either employ dial-up access with a standard modem over a regular phone line or can arrange for a direct link, such as a T-1 circuit, to Nynex's data center. According to Sean Sullivan, director of resale services at Nynex, users of the unbundled OSS system will have much the same capabilities as do their retail service reps in their business offices. "You're talking response times measured in seconds," says Sullivan. "If they want to take a look at a product or service availability for a particular central office, you're talking like 15 seconds. It's all fully automated, no manual intervention."

Nynex offers five pre-sale functions:
• Wholesale customers can pull customer service records to see a list of a customer's products, services, features, etc.
• They can access due date availability for, for example, installation of a new line.
• New phone numbers can be assigned remotely and directly.
• Customer premises can be validated for repair assignments.
• Wholesale customers can verify custom service offerings.

"Let's say a customer calls up and asks if custom calling features are available in the area," suggests Sullivan. "They [the wholesale customer] can type in the area code and the exchange of the customer, and bang, 15 seconds later they have a list of what's available." Nynex also offers ordering, maintenance and provisioning features. Resellers can create and send service orders that can convert an account from Nynex retail to their own service, add or remove specific features, suspend service, or change the customer's PIC. Users can issue trouble tickets and receive a committed date and time for repairs and also a ticket number for tracking purposes. The wholesale customer can reschedule these dates remotely. Users can also do remote line tests without issuing a trouble ticket. Sullivan says, "They have full service order capability."

But What About Security?

It would seem that having customer information anywhere near the Internet would be begging for trouble. Nynex has designed a security system it believes is virtually unhackable. The customer service Web site is not a part of the public Internet; it is actually located on Nynex's secure intranet, so that anyone surfing the Web can't just happen on it. The only way to get access to this site, via the Internet, is to be authorized by Nynex as a certified reseller.

Nynex uses two security checkpoints. The user is issued an ID card, about the size of a credit card, with a liquid crystal display that displays an alphanumeric pass code that changes every 60 seconds. Nynex's security monitoring software is programmed to recognize and verify each new code as it changes, thus providing an encryption system similar in concept to the frequency jumping technology used in advanced military radios. Once past this point, the user is prompted to provide another ID and password, provided by Nynex. Thus, all access and usage can be monitored and tracked. If someone does break through, any unusual usage can be instantly identified and Nynex can freeze any usage instantaneously. Sullivan claims, "We know everything about anybody who comes in."

What Are the Usage Charges?

Nynex does not charge for use of its GUI, private Web site or other forms of access, but it does charge for certain functions. Access to customer service records (CSRs) is charged on a pay-per-CSR basis of about 39 cents per record pulled. There is no charge for issuing trouble tickets or for premise/address validation, but there are charges for issuing service orders.

There is also a charge of about $5 for changing a customer's PIC, according to Bill Meehan, Nynex's staff director of resale product development. Charges are billed monthly and bills are available in three formats: magnetic tape, network data mover or CD-ROM. All billing information is exchanged in Bellcore standard BDT (Bill Data Tape) format.

Nynex is clearly ahead of the game regarding access, security and billing for unbundled OSS. Though there is debate in other states between CLECs and ILECs regarding how much access should be provided, it would seem that the precedent set by Nynex could become an unofficial standard. The initial argument over nondiscriminatory access was whether it meant equal access to the databases the ILECs use, or some sort of mirror or indirect access to more selective information.

Nynex has provided what amounts to real-time, complete access, and thus provided a model that competitive providers can refer to in their own negotiations. Trecom's Bush, a former Nynex executive, says, "The direction that the leading incumbent LECs go will set the standard. If you're a national reseller and you're getting something from Nynex and something from Bell Atlantic and you're not getting it somewhere else, you can scream." BellSouth, according to Cheney, is providing "not exactly the specifications that they [CLECs] wanted, but a suitable substitute." Cheney does admit, however, that "suitable is not always complete agreement."

Another Possible Model: Bell Atlantic

Bell Atlantic has stepped up to meet the challenge of the order, and is providing two distinct access methods. AT&T and MCI already have Open Systems Interconnection (OSI) based Electronic Bonding gateway for trouble ticket administration, and have requested an extension of those gateways' capabilities to support their local operations. Sprint is also building such a gateway.

This standardized technology is extremely expensive, however, and is not an option for most local competitors. For those who do not have EB capability, Bell Atlantic provides a system called ECG (Electronic Communications Gateway). ECG was designed in-house by Bell Atlantic and is a screen emulation, IBM 3270 mainframe-based system. Users gain access with a PC, either through a dial-up connection or a private line to Bell Atlantic's data center. The application uses menu presentation and can reach a variety of back-end functions for read-only access.

For service ordering, Bell Atlantic converts an EDI standard into an LSR (local service request) format for electronic entry into its business office service order system. ECG is only an interim solution, according to Hugh Loder, Bell Atlantic director of re-engineering and electronic bonding for carrier services.

"ECG is not full stack-to-stack, gateway-to-gateway, but it allows the user, if they choose, to build some sort of application on their end to port across this path to our menu," Loder says. "Then they can get access to customer service records, address information, phone number reservations, and a host of other capabilities. I like to refer to it as a quasi-EB." The ECG system can process simple requests, such as straight service transfers, relatively easily.

More complex services, such as Centrex or ISDN, require some manual intervention. Loder notes that because the standards for ordering, pre-ordering, and so on have not been established, there was no possibility of having OSI type interfaces in place by the Jan. 1 deadline. "There are efforts under way right now for electronic access ordering that are being worked before the OBF and ECIC," he says. "If the industry moves toward OSI or CORBA, we will certainly be part of that." Interim solutions must suffice until the standards have been defined. "What we're trying to do is build the maximum amount of electronic capability to facilitate the opportunity for resellers to get into business with a minimal amount of manual intervention on their end or our end," he says.

As far as security, Bell Atlantic has built local service provider IDs into its gateway and assigned individual user IDs to track who is on the gateway and what they are doing. There is no direct access to actual OSS databases, and because the system is not part of the Web, there is less of a threat of outsiders breaking in. The ID system can track usage but, at press time, Bell Atlantic had not decided how they would charge for OSS services. Loder says, "We think we've built a pretty safe process here where they [unauthorized users] can't damage, distort, or in any way impact our internal operating databases."

What About the Standards?

The fact is that there are no official standards yet. The Jan. 1 deadline was set well before standards were seriously discussed. Several interface options must be developed by each ILEC, and standards for formatting data must be defined. With the current state-by-state, company-by-company system, a variety of methods will arise. Even if, for example, Nynex's service is used as a model, it is unlikely that others will use the same formats or processes. Between the time competition was opened and when the standards are defined, myriad interim networks will be developed to provide OSS access for a rapidly growing number of local market entrants. National CLECs will have to conform to many access networks depending upon the state and/or ILEC they are dealing with.

These access networks will be as critical to the CLECs' businesses as the legacy OSSs are to the function of the actual carrier networks. Legacy systems cannot be rapidly replaced because of their importance to the network and the expense associated with such a task. Similarly, once the CLECs have established, for example, customer service processes, a switch to some new system may not be so easy. While the standards should, in theory, help provide CLECs the necessary access which they may not be getting from interim arrangements, implementation is bound to be difficult and costly because of the process and network re-engineering involved.