Liam S. Coonan, Esq.
Senior Vice President and
Assistant General Counsel
SBC Communications, Inc.
175 E. Houston Street
San Antonio, Texas 78205
Re: SBC Performance Measures
Dear Mr. Coonan:
As part of the Department's commitment to work with all Bell companies on
relevant issues in advance of their section 271 applications, the Department of
Justice and SBC Communications, Inc. ("SBC") have, as you know, been spending
considerable time discussing issues relating to wholesale support processes and
performance measures. In that regard, you have provided us with a draft list of
proposed performance measures, a list that you have supplemented as our
discussions have progressed.
Attachment A is a comprehensive list of performance measures. With the
qualifications set forth below, we are satisfied that the performance measures listed
in Attachment A, to which SBC has agreed,(1) would be sufficient, if properly
implemented, to satisfy the Department's need for performance measures for
evaluating a Section 271 application filed in the not-too-distant future.
We appreciate SBC's engagement with the Department on satisfying our
competitive assessment in advance of a filing and look forward to working with you
on additional related issues. One such issue is whether the performance measures
in Attachment A have been "properly implemented," since the majority of our
discussions have dealt with the performance measures themselves and since it is
upon the actual measures that this letter focuses. As you can appreciate, there
are important repercussions that may arise from how the measures are
implemented. For example, definitional issues and other details connected with
the measures themselves (such as the basis upon which due dates and start and
stop times are set in particular measures) could significantly affect the meaning of
the data. Thus, because we have not yet reached agreement on issues such as
data retention, presentation, and reporting (e.g., disaggregation, reporting
intervals and formats), and analysis, we expect that Department staff and SBC will
continue to work towards resolution of these issues. We also expect that
Department staff and SBC will discuss performance standards and benchmarking,
other important aspects of the Department's performance analysis.
Moreover, while we are satisfied at the present time that the measures set
out in Attachment A would, if properly implemented, suffice for present purposes,
performance measurement is a dynamic area and future developments could
necessitate changes in our views of appropriate performance measures. For
example, while the measures listed in Attachment A are structured to cover the
provision of unbundled network elements, once it becomes clear how unbundled
network elements will be provided so as to allow requesting carriers to combine
such elements in order to provide a telecommunications service, we may find that
other measures are necessary to assess performance in this situation. In addition,
the development of new services or new methods of providing existing services
could necessitate additional performance measures. Alternatively, through
ongoing regulatory proceedings, our own investigation, or otherwise, we might
learn of additional risks, and even occurrences, of discrimination of which we were
not previously aware. Accordingly, we would expect SBC to implement additional
measures or modifications to existing measures should it become apparent to the
Department that they are necessary. On the other hand, developments might
reveal that certain measures were no longer necessary and could be eliminated.
Our satisfaction with the performance measures set out in Attachment A must
be placed in its proper context. First, it is limited to the Department's application
of its competitive standard. Under section 271, the Department is to evaluate
applications for Bell entry using "any standard" the Department believes is
appropriate, and the FCC is required to give "substantial weight" to that
evaluation. As we have explained, our standard, in addition to the specific
statutory prerequisites, requires a demonstration that local markets in a state have
been "fully and irreversibly opened to competition," and appropriate performance
measures, standards, and benchmarks are important to the Department's
application of our competitive standard.
Second, our conclusions relate only to the Department's evaluation of
section 271 applications and should not be construed as an expression of the
Department's views concerning the appropriate resolution of any federal or state
regulatory proceeding relating to performance measures. The FCC and some
state commissions have ongoing proceedings considering both performance
measures and performance standards, including company-specific and state-specific issues. These proceedings may produce performance measures different
from, or in addition to, those described in Attachment A.
I am hopeful that we can resolve the remaining issues expeditiously through
our ongoing discussions. I appreciate your cooperation in addressing these issues
and look forward to our continuing mutual efforts. If you have any questions or
suggestions regarding these issues, please call.
Donald J. Russell
Telecommunications task Force
- Pre-order OSS Availability: Measures both the hours and days the BOC's
pre-order OSSs are available to CLECs and non-scheduled downtime.
- Pre-order System Response Times: Measures, in seconds, the speed with
which the CLEC Service Representatives receive information (including
rejection and error messages) for processes described below with a
customer on the line. These cycle-time measures assume the CLEC has
mechanical access to the BOC databases and should be measured in a
manner that allows appropriate comparisons to like cycle times
experienced by BOC retail service representatives. Times are provided
separately for the following functions:
- Address verification
- Request for telephone number
- Request for customer service record (CSR)
- Service and product availability
- Appointment scheduling
- Firm Order Commitment (FOC) Cycle Time: Measures the average time
from CLEC service order submission to BOC response, confirming receipt
of a properly formatted and appointed order and committing to
complete the order by a specified date. In addition, may be presented
as the percentage returned within an agreed upon interval.
- Rejected Order Cycle Time: Measures the average time, from CLEC
service order submission to BOC response, for rejecting an incomplete
service order or one containing errors. Each submission of an order, up to
and including the FOC, requires a response cycle-time result.
- Ordering Quality: The following performance measures are important
determinants of service order processing parity or adequacy. Each is
important in its own right and provides insights into different aspects of
order quality. While the entire set would not be required, Percent Flow
Through and either Percent Rejected Orders or Order Submissions per
Order are necessary.
- Percent Rejected Orders: Measured at the BOC gateway, it is the
result of dividing rejected orders by total orders submitted, manually
or mechanically. It is an adequacy measure because there are no
equivalent BOC analogs. BOC orders are "rejected" via automatic
edits before the order leaves the service representative position.
- Order Submissions per Order: Measured at the BOC gateway, it is
determined by dividing total order submissions by the number of
orders receiving a firm order commitment.
- Percent Flow Through: Measures the percentage of orders that flow
from the BOC gateway to acceptance by the BOC service order
processor without manual intervention. Orders rejected at the
gateway are excluded.
- Ordering OSS Availability: Measures both the hours and days the BOC's
ordering OSSs are available to CLECs and non-scheduled downtime.
- Ordering Center Availability: Reports both the hours and days of
operation of the BOC ordering center.
- Speed of AnswerOrdering Center: Measures the average time to reach
a BOC service representative.
- Service Provisioning Interval: Measures the time from customer request for
service to completion when the appointment is offered by the BOC, either
from a common appointment database, generally used in a resale
environment, or by agreed-to appointment intervals, more commonly used in
a UNE environment. Service Provisioning Interval should be measured both as
a mean, or average interval, and as a percent over a standard interval. Next
available appointments offered from the work schedule OSS and expedited
requests should be included for measurement; customer-requested due dates
longer than the offered appointment should be excluded.
- Average Service Provisioning Interval: Measured in days from end-user
request to order completion and counted separately for dispatched and
- Percent Service Provisioned Out of Interval: Measures the percentage of
service orders completed in more than an agreed upon number of days.
Ideally, measured incrementally by day. For example, orders completed
in more than 3 days, 4 days, 5 days, and 6 days. This performance
measure depicts the tail of the interval curve. Combined with the
Average Installation Interval, portrays a robust picture of provisioning
- Other Provisioning Measures
- Percent Interconnection Facilities Provisioned Out of Interval: Measures
the percentage of interconnection facilities (switched trunks and
dedicated circuits) provisioned in more than an agreed upon number of
- Percent Missed AppointmentsCompany Reasons: Order completion is
measured against the original CLEC-requested due date. No due date
changes may be made unless explicitly specified by the end user or
explicitly agreed to by the CLEC and the BOC. Orders missed for
company reasonsload, facilities, or otherare included. Orders missed
due to customer reasons are not counted as a miss for purposes of this
- Percent New Service Failures: Measures the number of trouble reports on
newly provisioned service within an agreed number of days of the original
trouble. Studies have shown high correlation between provisioning errors
and trouble reports occurring within 10 days and lower correlations
beyond 10 days.
- Completed Service Order Accuracy: Measures the extent to which
orders are completed by the BOC as ordered by the CLEC.
- Orders Held for Facilities: Measures service orders not completed by the
original due date because of a lack of network facilities (including loops
and central office equipment) in terms of (a) the average time between
the original due date and the final completion date, and (b) the number
of pending orders, as of the report date, held beyond a specified period
(usually 30 days) following the original due date.
- Average Completion Notice Interval: Measures the average time from
order completion to notification of the CLEC for orders submitted on a
- Trouble Reporting & Clearance
- Trouble Report Rate: Measured as the number of trouble reports per
customer or access line per month.
- Percent Repeat Reports: Measured as the percentage of end-user
troubles on the same access line within an agreed number of days of the
original trouble. Studies have shown high correlation between repair
errors and repeat reports occurring within 10 days and lower correlations
beyond 10 days.
- Percent Out of Service Over 24 Hours: Measured as a percentage of out-of-service troubles cleared within 24 hours.
- Percent Missed Appointments: Measures the percentage of trouble
reports cleared after the promised appointment. Requires that
appointment times, once set, cannot be changed except by the end
- Mean Time to Repair: Measured as the average interval from trouble
report to clearance.
- Interconnection Facilities Restored Out of Interval: Measures the
percentage of interconnection facilities (switched trunks and dedicated
circuits) reported out of service and restored after an agreed-to interval.
May also be measured and reported as an average interval.
- Maintenance OSS Availability: Measures both the hours and days the
BOC's maintenance OSSs are available to CLECs and non-scheduled
- Maintenance Center Speed of Answer: Measures the average time to
reach a BOC repair service representative.
- Network Quality
- Percent Blocked Calls: Measures trunking grade (quality) of service.
Should be provided separately for the following types of trunks:
- ILEC End Office to CLEC End Office Trunk Groups
- ILEC Tandem to CLEC End Office Trunk Groups
- ILEC Tandem to and from ILEC End Office Trunk Groups
- Bill Timeliness: Measures the percentage of billing records delivered
within an agreed-to interval. Should be provided for the following billing
information provided to CLECs:
- Daily Usage File (DUF): Measures, from message creation to the
availability of the usage information to the CLEC, the percentage of
DUF's provided within the interval.
- Wholesale Bill: Measures the percentage of wholesale bills issued
within an agreed-to number of days following the end of the billing
- Bill Completeness: Measures the percentage of complete billing records
for usage charges, recurring charges, and non-recurring charges
provided to CLECs. Should be measured after bills are released. Under
approved conditions, sufficiently robust pre-release test and audit
procedures could substitute for a post-release audit.
- Usage: Measures unbillable usage and usage from the current bill
cycle not included on the current wholesale bill.
- Recurring Charges: Measures current bill cycle recurring charges not
included on the current wholesale bill.
- Non-Recurring Charges: Measures non-recurring charges completed
in the current bill period not included on the current wholesale bill.
- Bill Accuracy: Measures the percentage of accurate billing records for
usage charges, recurring charges, and non-recurring charges provided to
CLECs. Should be measured after bills are released. Under approved
conditions, sufficiently robust pre-release test and audit procedures could
substitute for a post-release audit.
- Operator Services Toll Speed of Answer: Measures raw interval in seconds
or as a percentage under a set objective. Should be provided
separately for unbranded and branded service.
- Directory Assistance Speed of Answer: Measures raw interval in seconds
or as a percentage under a set objective. Should be provided
separately for unbranded and branded service.
- 911 Database Update Timeliness and Accuracy: Measures the
percentage of missed due dates of 911 database updates and the
percentage of accurate updates.
1. As we have discussed with you, the Department has agreed to narrow variances
from Attachment A in light of certain SBC processes and procedures. Specifically, we
have agreed that SBC need not provide separate operator services and directory
assistance speed-of-answer measurements for branded and unbranded calls and that
SBC can limit its 911 measurements to an error-clearing interval measure that is presently