Ehr Reply Affidavit Attachment C

Transcription

1 Ehr Reply Affidavit Attachment C

2 215 S. W ASHINGTON SQUARE, SUITE 200 L ANSING, M ICHIGAN T ELEPHONE: (517) FACSIMILE: (517) wright.com February 18, 2003 J OHN M. D EMPSEY jdempsey@dickinsonwright.com Via Hand Delivery Ms. Dorothy Wideman Executive Secretary Michigan Public Service Commission 6545 Mercantile Way Lansing, MI Re: Ameritech Michigan's submission on performance measurements, benchmarks, and reporting on compliance with the October 2, 1998 Order in MPSC Case No. U Case No. U Dear Ms. Wideman: Enclosed for filing regarding the above-captioned matter please find the original and 15 copies of the Amendment to Joint Motion and Proof of Service. I am authorized to represent that XO Michigan does not object to the relief requested. If you should have any questions, please contact me. Very truly yours, JMD/mds Enclosures John M. Dempsey LANSING v05 C o u n s e l l o r s A t L a w D ETROIT B LOOMFIELD H ILLS L ANSING G RAND R APIDS A NN A RBOR W ASHINGTON, D.C.

3 STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION Ameritech Michigan s submission on performance ) measurements, benchmarks, and reporting in ) compliance with the October 2, 1998 Order in ) Case No. U MPSC Case No. U ) ) AMENDMENT TO JOINT MOTION Michigan Bell Telephone Company d/b/a SBC Ameritech Michigan ( SBC ), the CLEC participants, 1 the Michigan Attorney General ( AG ), and the Michigan Public Service Commission Staff ( Staff ), (collectively, the Parties ) jointly submit this Amendment to their Joint Motion For Expedited Amendment of Prior Orders ("Joint Motion") filed in this docket on January 17, That Joint Motion asked the Michigan Public Service Commission ( MPSC ) to amend its Prior Orders issued 2 in this proceeding to reflect and implement the modifications, additions, and deletions regarding performance measurements and benchmarks agreed to by the Parties to the Joint Motion during the first six-month performance measurements review. The Parties have subsequently engaged in further collaborative discussions and have reached 1 2 The CLEC participants include the following: AT&T Communications, Inc., TCG Detroit, MCIMetro Access Transmission Services, Inc., MCI WorldCom Communications, Inc., and Brooks Fiber Communications of Michigan, Inc., and TDS Metrocom. On May 27, 1999 the Commission issued its initial Order in this case requiring Ameritech to implement performance measures and standards. Since that time the Commission has issued several orders amending the May 27, 1999 Order, including orders entered on September 3, 1999, July 17, 2000, February 22, 2001, April 17, 2001, July 11, 2001, July 25, 2001, December 20, 2001, and February 25, 2002 (the "Prior Orders").

4 agreement on matters as set forth in the amended Schedule 2, Agreed-To Measurement Changes 2002 Six-Month Review to this Amendment. The changes and updates include the following: The implementation dates for three Performance Measures ( PMs ) need to be delayed within the three-month schedule (PMs 1.2, 1.3 and 35.1) due to implementation complexities recently identified by the parties. A fourth PM (PM 56) was originally misidentified as a " Month" PM, and should be categorized as a " Month" PM. The issue requiring a " Month" implementation is the addition of EELs as a product disaggregation. All other UNE PMs with the EELs disaggregation added were correctly scheduled as " Month" implementations in the January 17, 2003 filing. The schedule for the remaining PMs remains unchanged, with the first changes being implemented with February 2003 results and reporting on March 20, WHEREFORE, the Parties respectfully request that the Commission act on this Amendment and the Joint Motion, on an expedited basis, to amend the performance measurements previously approved by the Commission's Prior Orders in this proceeding to reflect and implement the modifications, additions, and deletions regarding performance measurements and benchmarks agreed to by the parties as more fully detailed in this Amendment and the Joint Motion. 2

5 Dated this 18 th day of February Respectfully Submitted, AMERITECH MICHIGAN Craig Anderson (P28968) 444 Michigan Avenue, Room 1750 Detroit, MI (313) and DICKINSON WRIGHT PLLC By: John M. Dempsey (P30987) William J. Champion III (P31934) Attorneys for Ameritech Michigan 215 S. Washington Square, Suite 200 Lansing, MI (517) Concurred in by: MICHIGAN PUBLIC SERVICE COMMISSION STAFF AT&T COMMUNICATIONS, INC. TCG DETROIT MCIMETRO ACCESS TRANSMISSION SERVICES, INC., MCI WORLDCOM COMMUNICATIONS, INC. (F/K/A MFS INTELENET OF MICHIGAN, INC.) AND BROOKS FIBER COMMUNICATIONS OF MICHIGAN, INC. TDS METROCOM LANSING

6 AMENDED SCHEDULE 2 Agreed-To Measurement Changes 2002 Six-Month Review PM Number and Name Planned Implementation Date Is No Later Than X Results Month After Filing where X =, or 1.1 Average Response Time For Manual Loop Make-Up Information 1.2 Accuracy Of Actual Loop Makeup Information Provided For DSL Orders (Reporting of PM 1.2 Suspended Upon Implementation of PM 1.3) 1.3 Accuracy Of Actual Loop Makeup Information Provided For DSL Orders 2 Percent Responses Received Within X s OSS Interfaces 4 OSS Interface Availability 5 Percent Firm Order Confirmations (FOCs) Returned Within X Hours/Days 5.2 Percent Of Unsolicited FOCs By Reason Code 6 Average Time To Return FOC 7 Percent Mechanized Completions Returned Within One Hour Of Completion In Ordering Systems 7.1 Percent Mechanized Completions Returned Within One Day Of Work Completion 8 Average Time To Return Mechanized Completions 9 Percent Rejects 10 Percent Mechanized Rejects Returned Within One Hour Of Receipt Of Reject In MOR (Note - Measure Title Also Changes To Percent Rejects Returned Within X Hours ) 10.1 Percent Mechanized Rejects Returned Within One Hour Of Receipt Of Order (This Measure Deleted) 10.2 Percent Manual Rejects Received Electronically And Returned Within Five Hours (This Measure Deleted) 10.3 Percent Manual Rejects Received Manually And Returned Within Five Hours (This Measure Deleted) 10.4 Percentage Of Orders Given Jeopardy Notices 11 Mean Time To Return Mechanized Rejects(Also Measure Title Changes To Mean Time To Return Rejects ) 11.1 Mean Time To Return Manual Rejects That Are Received Via An Electronic Interface (This Measure Deleted) 11.2 Mean Time To Return Manual Rejects That Are Received Through The Manual Process (This Measure Deleted) 12 Mechanized Provisioning Accuracy 13 Order Process Percent Flow Through 13.1 Total Order Process Percent Flow Through 14 Billing Accuracy 15 Percent Of Accurate And Complete Formatted Mechanized Bills Via EDI And BDT 16 Percent Of Usage Records Transmitted Correctly SBC/Ameritech

7 Agreed-To Measurement Changes 2002 Six-Month Review PM Number and Name Planned Implementation Date Is No Later Than X Results Month After Filing where X =, or 17 Billing Completeness 18 Billing Timeliness (Wholesale Bill) 19 Daily Usage Feed Timeliness 20 Unbillable Usage 21.1 Average Time Placed On Hold At LSC 22 Local Service Center (LSC) Grade Of Service (GOS) 22.1 Mechanized Customer Production Support Center (MCPSC) Grade of Service (GOS) (New Measure) 24.1 Average Time Placed On Hold At LOC 25 Local Operations Center (LOC) Grade Of Service (GOS) 27 Mean Installation Interval 28 Percent POTS/UNE-P Installations Completed Within The Customer-Requested Due Date 29 Percent SBC/Ameritech-Caused Missed Due Dates 30 Percent SBC/Ameritech-Caused Missed Due Dates Due To Lack Of Facilities 31 Average Delay Days For SBC/Ameritech-Caused Missed Due Dates Due To Lack Of Facilities 32 Average Delay Days For SBC/Ameritech-Caused Missed Due Dates 33 Percent SBC/Ameritech-Caused Missed Due Dates > 30 Days 35 Percent Trouble Reports Within 30 Days (I-30) of Installation 35.1 Percent UNE-P Trouble Reports On The Completion Date (New Measure) 37 Trouble Report Rate 37.1 Trouble Report Rate Net of Installation and Repeat Reports 38 Percent Missed Repair Commitments 39 Receipt To Clear Duration 40 Percent Out Of Service (OOS) < 24 Hours 41 Percent Repeat Reports 42 Percent No Access (Percent Of Trouble Reports With No Access) 43 Average Installation Interval 44 Percent Specials Installations Completed Within Customer-Requested Due Date 45 Percent SBC/Ameritech-Caused Missed Due Dates 46 Percent Trouble Reports Within 30 Days (I-30) Of Installation 47 Percent SBC/Ameritech-Caused Missed Due Dates Due To Lack Of Facilities 48 Average Delay Days For SBC/Ameritech-Caused Missed Due Dates Due To Lack Of Facilities 49 Average Delay Days For SBC/Ameritech-Caused Missed Due Dates SBC/Ameritech

8 Agreed-To Measurement Changes 2002 Six-Month Review PM Number and Name Planned Implementation Date Is No Later Than X Results Month After Filing where X =, or 50 Percent SBC/Ameritech-Caused Missed Due Dates > 30 Days 52 Mean Time To Restore 53 Percent Repeat Reports 54 Failure Frequency 54.1 Trouble Report Rate Net Of Installation And Repeat Reports 55 Average Installation Interval 55.1 Average Installation Interval DSL (This Measure Deleted) 55.2 Average Installation Interval For Loop With LNP 55.3 Percent DSL-Capable Loop Orders Requiring The Removal Of Load Coils And/Or Repeaters 56 Percent Installations Completed Within Customer-Requested Due Date 56.1 Percent Installations Completed Within Customer-Requested Due Date For Loop With LNP 58 Percent SBC/Ameritech-Caused Missed Due Dates 59 Percent Trouble Reports Within 30 Days (I-30) of Installation 60 Percent SBC/Ameritech-Caused Missed Due Dates Due To Lack Of Facilities 61 Average Delay Days For SBC/Ameritech-Caused Missed Due Dates Due To Lack Of Facilities 62 Average Delay Days For SBC/Ameritech-Caused Missed Due Dates 63 Percent SBC/Ameritech-Caused Missed Due Dates > 30 Days 65 Trouble Report Rate 65.1 Trouble Report Rate Net Of Installation And Repeat Reports 66 Percent Missed Repair Commitments 67 Mean Time To Restore 68 Percent Out Of Service (OOS) > 24 Hours 69 Percent Repeat Reports 70 Percentage Of Trunk Blockage (Call Blockage) 70.1 Trunk Blockage Exclusions 70.2 Percentage Of Trunk Blockage (Trunk Groups) 71 Common Transport Trunk Group Blockage 73 Percentage Installations Completed Within Customer Requested Due Dates Interconnection Trunks 74 Average Delay Days For SBC/Ameritech-Caused Missed Due Dates Interconnection Trunks 75 Percentage SBC/Ameritech-Caused Missed Due Dates > 30 Days Interconnection Trunks 76 Average Trunk Restoration Interval Interconnection Trunks SBC/Ameritech

9 Agreed-To Measurement Changes 2002 Six-Month Review PM Number and Name Planned Implementation Date Is No Later Than X Results Month After Filing where X =, or 77 Average Trunk Restoration Interval For Service-Affecting Trunk Groups 78 Average Interconnection Trunk Installation Interval 79 Directory Assistance Grade Of Service 80 Directory Assistance Speed Of Answer 81 Operator Services Grade Of Service 82 Operator Services Speed Of Answer 83 Percentage Of Calls Abandoned 91 Percentage Of LNP Only Orders Within The Customer Requested Due Date 92 Percentage Of Time The Old Service Provider Releases The Subscription Prior To The Expiration Of The 9 Hour (T2) Timer 93 Percentage Of Customer Accounts Restructured By The LNP Only Completion Date 95 Average Response Time For Non-Mechanized Rejects Returned With Complete And Accurate Codes (This Measure Deleted) 96 Percentage Pre-Mature Disconnects For LNP Orders 97 Percentage Of Time SBC/Ameritech Applies The 10-digit Trigger Prior To The LNP Order Due Date 98 Percent LNP Trouble Reports Within 30 Days (I-30) of Installation 99 Average Delay Days for SBC/Ameritech-Caused Missed Due Dates (For Stand-Alone LNP Orders) 100 Average Time Of Out Of Service For LNP Conversions 101 Percent Out Of Service < 60 minutes 102 Average Time To Clear Errors (Facility-Based Providers) MI 6 Erred Customer Record Update Files Not Returned By Next Business Day (This Measure Deleted) 103 Percent Accuracy for 911 Database Updates (Facility-Based Providers) MI 7 Errors In Customer Record Update Files (This Measure Deleted) 104 Average Time Required To Update 911 Database (Facility-Based Providers) MI 8 Customer Record Update Files Not Updated By The Next Business Day (This Measure Deleted) The Average Time It Takes To Unlock The 911 Record 105 Percentage Of Requests Processed Within 35 Days 106 Average Days Required To Process A Request 107 Percentage SBC/Ameritech-Caused Missed Collocation Due Dates 108 Average Delay Days For SBC/Ameritech-Caused Missed Due Dates 109 Percent Of Requests Processed Within The Established Timelines 110 Percentage Of Updates Completed Into The DA Database Within 72 Hours For Facility- Based CLECs SBC/Ameritech

10 Agreed-To Measurement Changes 2002 Six-Month Review PM Number and Name Planned Implementation Date Is No Later Than X Results Month After Filing where X =, or 111 Average Update Interval For DA Database For Facility-Based CLECs 112 Percentage DA Database Accuracy For Manual Updates For Facility-Based CLECs 113 Percentage Of Electronic Updates That Flow-Through The Update Process Without Manual Intervention 114 Percentage Of Premature Disconnects (Coordinated Cutovers) CHC/FDT LNP With Loop Provisioning Interval 115 Percentage Of SBC/Ameritech-Caused Delayed Coordinated Cutovers Percent Provisioning Trouble Reports (PTR) Mean Time To Restore Provisioning Trouble Reports (PTR) 117 Percent NNXs Loaded And Tested Prior To The LERG Effective Date 118 Average Delay Days For NXX Loading And Testing 119 Mean Time To Repair 120 Percentage Of Requests Processed Within 30 Business Days 121 Percentage Of Quotes Provided For Authorized BFRs Within 45 Business Days 124 Timely Resolution Of Significant Software Failures Related With Releases (New Measure) Test Environment Availability (New Measure) MI 2 Percentage Of Orders Given Jeopardy Notices Within 24 Hours Of The Due Date MI 3 Coordinated Conversions Completed Within One Hour Of The Scheduled Time MI 4 Average Time To Provide A Collocation Arrangement MI 5 Structure Requests Completed Outside Of Interval MI 9 Percentage Missing FOCs MI 10 Percent Time-Out Transactions MI 11 Average Interface Outage Notification MI 12 Average Time To Clear Service Order Errors MI 13 Percent Mechanized Line Loss Notifications Returned Within One Day Of Work Completion MI 13.1 Average Delay Days For Mechanized Line Loss Notifications (New Measure) MI 14 Percent Completion Notifications Returned Within X Hours Of Completion Of Maintenance Trouble Ticket MI 15 Change Management MI 16 Percentage Rejected Query Notices WI 1 Percent No Access UNE Loops Provisioning WI 2 Percent No Access (Percent Of Trouble Reports With No Access) UNE Loops WI 9 Percent Facility Modification Orders CLEC WI 1 Average Delay In Original FOCs Due Dates Due To Delay Notices (Issue F) SBC/Ameritech

11 Agreed-To Measurement Changes 2002 Six-Month Review PM Number and Name CLEC WI 4 Accuracy Of Processing CLEC Corrections Based On Review Of Directory Information (Issue L) CLEC WI 5 Percentage of Protectors Not Moved After Technician Visit (Issue O) CLEC WI 6 FMOD Process: Percent Form A Received Within The Interval Ordered By The Commission CLEC WI 7 FMOD Process: Percent Forms B,CD Received Within 72 Hours Of Form A CLEC WI 8 FMOD Process - Form B: Percent Return FOC With New Due Date Within 24 Hours CLEC WI 9 FMOD Process - Form C: Percent Return Quote Within the Interval Ordered By The Commission CLEC WI 11 FMOD Process - Forms B,C,D: Percentage Of Due Dates Met IN 1 Percent Loop Acceptance Testing (LAT) Completed On Or Prior To The Completion Date Planned Implementation Date Is No Later Than X Results Month After Filing where X =, or SBC/Ameritech

12 STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION Ameritech Michigan s submission on performance ) measurements, benchmarks, and reporting in ) compliance with the October 2, 1998 Order in ) Case No. U MPSC Case No. U ) ) STATE OF MICHIGAN ) ) ss COUNTY OF INGHAM ) PROOF OF SERVICE Mindy Smith, being first duly sworn, deposes and says that she is employed at Dickinson Wright PLLC; and that on February 18, 2003 she served a copy of the Amendment to Joint Motion upon the attached service list via and fist class mail by placing the same in envelopes addressed as attached, with proper first-class postage affixed thereto, and by causing the same to be deposited in a mail receptacle maintained by the U.S. Government in Lansing, Michigan. Subscribed and sworn to before me, a Notary Public in and for said County, this 18 th day of February, Mindy Smith Alicia M. Ball, Notary Public Ingham County, Michigan My Commission Expires: 01/07/06 LANSING v02

13 SERVICE LIST U Michael A. Nickerson MPSC Staff 6545 Mercantile Way, Suite 15 Lansing, MI Orjiakor N. Isiogu Attorney General 6520 Mercantile Way, Suite 2 Lansing, MI William R. Ralls Leland R. Rosier CoreComm Michigan, Inc Woodlake Circle Okemos, MI William R. Ralls Leland R. Rosier McLeodUSA, Inc Woodlake Circle Okemos, MI Bradley R. Kruse Associate General Counsel McLeodUSA, Inc. G400 C Street, S.W. P.O. Box 3177 Cedar Rapids, IA Michael S. Ashton Z-Tel Communications 1000 Michigan National Tower Lansing, MI Claudia J. Earls Z-Tel Communications S. Harbour Island Blvd., Suite 220 Tampa, FL John J. Reidy, III Doug Trabaris AT&T Communications 222 W. Adams Street, Suite 1500 Chicago, IL Art LeVasseur AT&T Communications 3500 Guardian Building Detroit, MI Richard C. Gould Horizon Telecommunications, Inc S. Hagadorn Rd., Suite 320 East Lansing, MI Albert Ernst WorldCom Dykema Gossett PLLC 800 Michigan National Tower Lansing, Michigan James R. Denniston WorldCom 205 North Michigan Avenue, Suite 3700 Chicago, Illinois Howard Siegel IP Communications Corporation 9430 Research Blvd. Echelon II, Suite 120 Austin, Texas Michael S. Ashton XO Michigan, Inc Michigan National Tower Lansing, MI

14 SERVICE LIST U William R. Ralls Leland R. Rosier Rhythms Links, Inc Woodlake Circle Okemos, MI Lee T. Lauridsen Sprint Communications Company LP 8140 Ward Parkway, 5E Kansas City, Missouri Julie Kaminski Corsig CompTel Davis Wright & Tremaine LLP 1500 K Street, N.W., Suite 450 Washington, DC Michael S. Ashton KMC Telecom II, Inc./KMC Telecom III, Inc Michigan National Tower Lansing, MI Maureen K. Flood Rhythms Links, Inc Bishop Dr., Suite 124 San Ramon, CA William H. Keating GTE North/Verizon 100 Executive Drive Marion, OH Andrew O. Isar ASCENT 3220 Uddenberg Lane, Suite 4 Gig Harbor, WA Todd McNally MetroCom USA todd.mcnally@tdsmetro.com LANSING