With a modified list of unbundled network elements from the FCC, Bell Atlantic strains to accommodate the recent changes and present up-to-date billing systems and operational support systems.
Regulatory shifts keep incumbent LECs and competitive LECs in constant respond-and-recover mode. During the last three years, Bell Atlantic has been standardizing its offerings for the unbundled network elements (UNEs) initially identified in the Telecommunications Act of 1996, but recent changes have caused the carrier to revise and adjust its UNE services.
These changes result from the Sept. 15 ruling by the FCC clarifying incumbents’ unbundling obligations. Every three years, the FCC is charged with reexamining the existing policies and regulations regarding the Telecommunications Act of 1996. Last September, the FCC revisited its list of UNEs and clarified seven items. Only one month later, the UNE profile expanded again as the FCC strengthened the restrictions of enhanced extended loops (EELs) and also directed carriers to offer line sharing. (For further details on the FCC’s UNE decisions, see January “UNE Audits: World of Missed Revenue”)
As of December 1999, Bell Atlantic had covered its bases with multiple offerings of UNEs initially identified by the FCC. But Bell Atlantic is still developing its inventory of UNEs outlined in the Sept. 15 ruling and subsequent decisions. Currently, its available UNEs include unbundled operations support systems (OSS); signaling links and signaling transfer points in conjunction with unbundled switching and on a standalone basis; access to circuit switching; unbundled access to network interface devices; and unbundled access loops. Bell Atlantic’s UNEs now in development include unbundled access to subloops, line sharing and EELs.
One area that the commission modified—and Bell Atlantic is responding to—is subloops. The commission required incumbents to provide unbundled access to subloops, or portions of loops, and dark fiber optic loops and transport. At this point, subloops are available throughout Bell Atlantic’s territory, although the company does not have a standardized ordering process for the UNE.
If a CLEC wants unbundled access to a subloop, it must go through Bell Atlantic’s bona fide request process. With this procedure, the CLEC supplies Bell Atlantic with the specifics of what it wants, and Bell Atlantic will then research the request, and provide a price and deployment time. To date, Bell Atlantic has sold only a small number of subloops.
To smooth purchasing, Bell Atlantic is developing a standardized ordering process for subloops, but hasn’t set a firm availability date. “We try to meet every date that is required by the governing bodies,” says Amy Stern, director of wholesale products for Bell Atlantic. “We work first on providing products with more demand. For those that we don’t expect to see a large demand, we save for last.”
Another missing UNE in the Bell Atlantic portfolio is access to dark fiber. The FCC required ILECs to provide dedicated interoffice transmission facilities, or transport, including dark fiber. At this point, Bell Atlantic offers dark fiber only in Massachusetts and a couple of the smaller New England states.
Bell Atlantic also has geographically limited UNE platform (UNE-P) and EEL offerings. In New York and Massachusetts platforms are available, and the company has filed for compliance for platforms in New Jersey and Pennsylvania. EEL services are available in New York, Massachusetts, Pennsylvania and New Jersey.
In regard to the more recent FCC change—line sharing—Bell Atlantic began field tests in New York in late December 1999. U S West has already announced line sharing in Minnesota, but Bell Atlantic is waiting until its field tests are finalized. The company is participating in an industry collaboration in New York that will gather information during this testing and development phase that will be used to roll out line sharing throughout its territory. Created by the New York Public Service Commission, the collaborative group includes NorthPoint Communications, Rhythms NetConnection, Covad Communications, Sprint, AT&T and MCIWorldcom. Together they have established several committees to define administrative, network, technical and OSS issues for line sharing.
Beginning in January 2000, each committee will meet once a week for half-day sessions to ensure that line sharing will be available within the next six months. During this testing phase, Bell Atlantic is doing trials in several central offices (COs) that represent the different types of COs in its territory. Bell Atlantic and the other members in the collaboration are testing about 100 lines in COs located in Manhattan, as well as some suburban COs in the outer boroughs of New York City.
Bell Atlantic is currently noncommittal regarding the availability dates of the various UNEs. Stern says the OSS and billing systems are being changed now to accommodate these new services, and “tariffs are being negotiated.” But she is unwilling to specify a firm date for any of the services. Her standard answer is, “We will comply with the UNE remand order.” Using that statement as a gauge, CLECs can look for a full set of standardized offerings for the Sept. 15 list of UNEs by March, and EELs and line sharing by April.
UNE Kinks and Tangles
CLEC customers ordering UNEs from Bell Atlantic have experienced difficulties in various steps of the process. Complaints include problems gaining access to Bell Atlantic’s preordering information, lost activation notices and billing difficulties.
MCIWorldcom, one of Bell Atlantic’s largest customers for UNE-Ps, places thousands of orders each day with Bell Atlantic. One of MCIWorldcom’s biggest concerns has been the responsiveness of Bell Atlantic’s Web-based graphical user interface for preordering UNEs. “The preorder system has been very unstable,” says Sherry Lichtenberg, senior manager OSS and facilities development for MCIWorldcom. “We are experiencing a lot of response time errors and time out errors.”
Sean Sullivan, director of wholesale systems and infrastructure at Bell Atlantic, acknowledges the system’s early bugs. In response to the problems, Bell Atlantic has increased its hardware and made some software changes to increase speed and improve capacity.
Another problem experienced by data CLECs is access to critical preordering information, specifically for xDSL-capable loops. “Bell Atlantic is putting in a loop prequalification database,” says Glenn Harris, assistant general counsel for NorthPoint. “While the database information is helpful on a percentage of our loops, it does not contain all the information that we need to properly inform potential customers.”
Covad has experienced similar problems. “Our biggest problem is loop qualification. We can provide address validation, but not the loop distance or if the loop qualifies for a particular type of DSL,” says Umesh Bellur, senior engineering manager for Covad.
The CLECs want access to loop data available in two systems: the loop facility assignment and control system, which inventories, maintains, and assigns outside plant local facilities; and the trunk record-keeping system, which inventories, maintains and assigns facilities for interoffice transmissions, trunking and special services. Bell Atlantic, however, maintains that CLEC customers have access to the same data that its representatives use, which includes references, phone number assignments, customer records, due dates, and loop qualification for ISDN and DSL.
MetTel, a CLEC concentrated in the Bell Atlantic territory, has experienced more difficulties in provisioning UNEs from the RBOC. “We don’t have problems ordering or billing for any particular UNE, but we have had problems on the provisioning side,” says Andoni Economou, executive vice president at MetTel. “Often Bell Atlantic will claim an order is complete, but later we discover that the customer isn’t getting usage. In turn, we’ve generated invoices for customers that don’t have service.”
Disparity Among the UNE Offerings
Parallel with ramping up its UNE ordering and billing systems, Bell Atlantic also bolstered its Web site resources. A three-volume CLEC handbook at www.bell-atl.com/tis offers reams of pertinent information, including explanations of the different types of UNEs, the preorder and ordering requirements, and the various OSS and billing systems.
Bell Atlantic also offers three-day UNE training sessions in each of its territories. These classes provide an overview of the available UNEs, give direct access to Bell Atlantic’s OSS and allow attendees to practice inputting orders. If a CLEC cannot travel to Bell Atlantic’s campus, the ILEC will send representatives to the CLEC’s sites and provide customized training.
Bell Atlantic encourages CLECs to take advantage of the training sessions because of the myriad differences in ordering specific UNEs. When ordering UNE-Ps, for example, there are some subtle differences from ordering non-platform UNEs. The same system is used to place the orders, but CLECs must use different forms and different fields for each service. Ordering a UNE-P requires four forms: LSR Administration, End User Information, Port Services, and DL Service. For an unbundled basic loop, CLECs are only required to fill out three forms: LSR Administration, End User Information and Loop Services.
Another difference is in the assignment of account numbers. In almost every UNE order, Bell Atlantic requires CLECs to have a Special Billing Number (SBN). Basic and premium UNE loops that are not part of a platform require SBNs, but loops used in conjunction with platforms, and those ordered via an access service request (ASR), are billed on a Billing Account Number (BAN), and do not require an SBN.
More extensive differences exist within Bell Atlantic’s billing systems. In its southern territory, Bell Atlantic is using a Customer Record Information System (CRIS) and Carrier Access Billing System (CABS). In its northern territory, Bell Atlantic uses CABS exclusively. CABS processes service orders for CLECs and IXCs, prices services, renders bills and other billing media, posts payments and adjustments, and updates the Customer Service Record (CSRs). It also provides internal and external reports. CRIS processes service order information and cash transactions, updates the CSR base, calculates billing and provides internal reports. CRIS acts as the master record base for customer record information.
In Bell Atlantic South, ASRs for interoffice facilities and transport are processed through CABS. Local service requests (LSRs) for loops, ports and interim number portability go through CRIS. In Bell Atlantic North, ASRs and LSRs and handled by CABS.
For people accustomed to Bell Atlantic’s UNE billing formats, the process seems simple. “Billing for UNEs is pretty straightforward,” says Richard Sampson, director of wholesale billing and collections at Bell Atlantic. “You put in the number of orders and the tariff, and that’s about all there is to it.”
Those on the receiving end of the bills, however, have raised concerns about CRIS. “Bell Atlantic’s process is not optimal,” says Robert McCausland, vice president of regulatory and interconnection at Allegiance Telecom. “It creates difficulties and challenges in terms of managing the number and types of bills and validating the information. The CRIS statements are not rendered just once a month; they are fragmented. We receive bills almost every day.”
Allegiance prefers receiving bills from ILECs that use CABS because it provides a single bill in the geographic area each month. “The CABS layout allows us to efficiently validate the information within the bill,” adds McCausland. “Moving to a more carrier- oriented approach for UNE payment would help Bell Atlantic. It would save them time and trouble if it had a more efficient billing process.”
Already aware of these problems, Bell Atlantic is in the midst of providing bills from another in-house system, expressTRAK. During the next six months, CLECs in Maryland, Virginia, West Virginia and the Washington, D.C., area will receive bills from expressTRAK. The other states will also move to expressTRAK, but no firm cutover dates have been set.
The expressTRAK system offers an improved format for viewing bills. CLECs will be able to get a consolidated invoice, customized delivery dates, more analysis and reporting tools, and clearer language than the current cumbersome codes used in CRIS.
As Bell Atlantic considered its move from CRIS to expressTRAK, it did explore off-the-shelf products. “Ultimately, we chose to stick with in-house, proprietary systems, and I don’t expect we’ll move from that decision any time soon,” says Sampson.
Retrieval and Access
Bell Atlantic sends CLECs multiple bills depending upon how they set up their accounts. The bills can be separated by states, or CLECs can receive bills from each CO. At this point, there is no plan to provide aggregated billing for CLECs.
The bills generated by CABS are in Bill Data Tape (BDT) format, as defined by the Order and Billing Forum (OBF) and standardized by Telcordia Technology’s Technical Review Group. CLEC bills are provided in Billing Output Specification format. CLECs can choose to have the bills delivered in a variety of different formats: electronic transfer via Connect:Direct, magnetic tape, CD-ROM or printed hard copies. Bills are resent for a charge, but are only available in the original format requested by the CLEC. CLECs can also receive a copy of the monthly SBN UNE bill via electronic data interchange (EDI), magnetic tape, CD-ROM or printed hard copies.
MetTel receives its UNE bills via CD-ROM. Its usage accounts number between 8,000 and 9,000 pages, and its monthly customer service, access, and services range between 15,000 and 18,000 pages. MetTel has considered changing to an electronic transfer for its bills. “The CD-ROM format has proven to be unwieldy in some instances, but it’s not a priority,” says Economou.
FORWARD THINKING
Bell Atlantic’s UNE challenges reflect the ongoing upheavals faced by all players maneuvering under the FCC’s continuous modifications to the Telecommunications Act of 1996. Looking ahead, carriers can count on more adjustments and alterations to UNEs, but for the short term, carriers can take advantage of the new UNEs to readjust their business plans and renegotiate their interconnection agreements.
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