Mpsc E Dockets

[Nella Mcnairy]

Whatdoes this mean for net metering and other proven retail solar compensation programs? It might suggest opportunities for evolution towards more sophisticated programs that capture DER value. But designing new policies for DER compensation will require states to carefully balance the need to (1) encourage deployment in ways that leverage the range of benefits that DERs can provide to the gird and society, while (2) preserving a stable and financeable policy environment to support rapid market growth.

These dockets and others like them, will determine whether Midwest customers enjoy full, fair, and robust compensation for DERs to maximize deployment and value to the utility, its customers, and society.

In this Appendix, we examine Ameritech's wholesale support processeshe automated and manual processes required to make resale services and unbundled elements, among other items, meaningfully available to competitors nd performance measures under the criteria outlined in the Department's Evaluation regarding SBC's Section 271 Oklahoma application, filed on May 16, 1997. 1

In evaluating BOC applications under Section 271, the Department considers whether a BOC has made resale services and unbundled elements practicably available by providing them via wholesale support processes, including the critical access to OSS functions required by the Commission's rules, that: (1) provide needed functionality; and (2) are demonstrated to operate in a reliable, nondiscriminatory manner at reasonably foreseeable volumes, providing entrants with a meaningful opportunity to compete. 2 Ameritech echos this standard in its application, and in particular with reference to OSS access: "Ameritech should be required to show that its OSS interfaces are operational, i.e., that they have undergone sufficient testing or use to provide reasonable assurance that competitors can obtain, upon request, access to the OSS functions they need to enter the marketplace and serve customers successfully at reasonably foreseeable demand levels." Affidavit of Joseph A. Rogers 15 ("Rogers Aff."), attached to Ameritech Brief, Volume 2.13.

Depending on the volume of orders expected, BOCs will have to automate in two areas to make resale services and unbundled elements meaningfully available at reasonably foreseeable volumes. First, BOCs will have to automate many of the interfaces between a BOC and its competitors through which information is exchanged regarding such services and elements. Application-to-application interfaces in particular allow competing carriers to build their own software for processing transactions with a BOC. In some instances, though, such application-to- application interfaces might be too expensive for smaller carriers who cannot afford such customized software development. In those instances, terminal emulation or graphical user interfaces (GUIs) may be appropriate. SBC, for example, is developing multiple interfaces, for small and large carriers, to support almost every automated wholesale support function. 3

Second, BOCs will need to automate, to varying degrees, the interaction of these interfaces with their internal OSSs. Such automation often will be critical to the meaningful availability of resale services and unbundled elements. The Commission's nondiscrimination requirement obligates BOCs to provide automated interaction between interfaces and OSSs where such access is automated analogously for the BOCs' retail operations, or where the lack of such automation would cause significant barriers to entry, denying competitors a meaningful opportunity to compete. Thus, while we generally concur with Ameritech's "cost-benefit" approach to determining when to mechanize order processing, as the MPSC correctly pointed out, 4 we disagree with Ameritech's position that "manual processing of certain orders, after they are received through the appropriate electronic interface, has absolutely no bearing on compliance with the checklist and the Commission's [rules]." Rogers Aff. 42. Manual processing that results in the practicable unavailability of services or elements at foreseeable demand levels can impede the development of competition, and thus obviously has a direct bearing on compliance with the competitive checklist and the Commission's rules.

In addition to automation in general, adherence to industry standards for interfaces between carriers in particular will generate further economic benefits both for CLECs and incumbents. Committees of the Alliance for Telecommunications Industry Solutions (ATIS) recently finalized standards for ordering resale services and some unbundled elements via electronic data interchange (EDI), and the Department will ordinarily expect BOCs to adhere to such standards following a reasonable period of development in cooperation with competing carriers wishing to use the standardized interface. 5

Finally, proper performance measures with which to compare BOC retail and wholesale performance, and to measure exclusively wholesale performance, are a necessary prerequisite to demonstrating compliance with the Commission's "nondiscrimination" and "meaningful opportunity to compete standards." Moreover, without a track record of performance described by comprehensive measures, it will be difficult -- if not impossible -- for competitors and regulators to detect backsliding of performance after in-region interLATA entry is authorized.

Ameritech has made significant progress in improving the functionality and operability of its wholesale support processes, both manual and automated. Ameritech has generally been forthcoming about early problems with its processes, and has made good faith efforts at finding solutions to many such problems. In addition, Ameritech has attempted to place in this and in state records detailed internal testing results, carrier-to-carrier testing results, commercial performance statistics (including error rates), and, in most cases, internal retail performance results, thereby allowing competitors and regulators to examine and comment on such evidence and compare retail and wholesale performance.

Detailed comments regarding each wholesale support process Ameritech claims to provide are provided below. In each instance, we review the functions Ameritech purports to provide and the testing and operational evidence supporting such functionality. Because Ameritech's processes are generally operated on a regional, rather than state-wide basis, our analysis is not limited to Michigan activities unless there is evidence of state-specific operating problems. Similarly, if a problem exists with Ameritech's processes in another state, we assume that the problem exists in Michigan unless shown otherwise.

Ameritech provides CLECs with manual and automated processes for obtaining preordering information. The latter is provided primarily through an EDI interface, and thus Ameritech has generally anticipated the direction ATIS committees have taken in this regard. 6 Ameritech provides five primary preordering functions: customer service record retrieval; telephone number selection and reservation; due date selection and reservation; address validation; and feature availability. These functions appear to provide CLECs with at least the basic functionality required to provide competitive POTS services to end users. The first three functions are provided in near-real-time over the EDI interface, while the last two are provided as file downloads and are updated nightly. There is little or no evidence in the record to indicate that this division of functions between real-time and file transfer is competitively unreasonable, particularly in light of the relatively static nature of the address and feature availability data.

Ameritech's EDI preordering interface has undergone significant internal testing, and some, albeit insufficient, carrier-to-carrier testing and commercial use. First, Ameritech asserts that internal testing of the interface by Ameritech alone was completed in November and December 1996, and that the interface has been available since then. Rogers Aff. 25. Ameritech also presents the details of internal testing at the direction of Andersen Consulting personnel. By analyzing both previous Ameritech testing and current projections of preordering transactions, personnel from Andersen Consulting and Further Inspection, an information technology firm, created a set of benchmark transactions that represented the expected "mix" of preordering transactions. Affidavit of Robert H. Meixner 25-27 ("Meixner Aff."), attached to Ameritech Brief, Volume 2.9. Using these benchmark transactions, Ameritech and Further Inspection personnel then ran tests on the preordering system involving 906 transactions and six simultaneous users. The results are reported in Schedules 9 and 10 of Meixner's affidavit. The reported results claim a capacity of 945 preorder transactions per hour, or 307,000 per month, well above Ameritech's projected volumes for 1997.

The results also claim an average response time for these transactions of approximately 8.2 seconds, roughly corroborated by 9.5 second response times in tests using USN's interface for retrieving CSRs. Ameritech also corroborates these results through submission of a study by Further Inspection comparing Ameritech's retail and wholesale preorder response times further broken out by state. 7 It is unclear whether the data depicted is a breakout of the tests described above or separate tests. Meixner Aff. 25-31. The Further Inspection bar graphs indicate that, for Michigan and most other states, wholesale preorder response times are approximately 10 seconds or less and retail response times are approximately 2-4 seconds. While there is limited evidence in the record indicating that such a difference in response time is competitively significant, 8 Ameritech does not reveal the source of the retail performance data, the conditions under which it was obtained, or the basis for its goal of providing wholesale access in 10 seconds. 9

3a8082e126