VI. Verizon's Proposed Hot Cut Processes (47 C.F.R. § 51.319(d)(2)(ii)(A)(2)) and Volume Limitations (47 C.F.R. § 51.319(d)(2)(ii)(A)(1))

A. Position of Verizon

Verizon proposes covering both ongoing hot cuts and cutover of the embedded base of existing UNE-P to UNE-L lines through a batch cut process. Verizon currently employs two types of coordinated hot cuts: (1) a "coordinated conversion" and (2) a "hot cut coordinated conversion." The only difference in the latter type involves a live continuous conference call during the entire hot cut process whereas in the former type, the CLEC is contacted only before and after the process is completed by Verizon.⁵⁵

Verizon's BHC proposal is designed to enable a CLEC to earmark specified hot cut orders for batch processing. In each central office, orders submitted for batch processing would be held until a "critical mass" is reached, based on the volume of cuts and optimum level of frame staffing in each office. The minimum holding period would be 10 business days with a maximum of 35 business days. The CLEC would be notified of the actual cutover date no later than six days beforehand. If a CLEC wants a shorter, specific interval, Verizon offers the CLEC the option of using its current Basic or Large Job hot cut option. The BHC cutover process differs in one significant way from the Large Job process in that CLECs would be required to authorize Verizon, instead of the CLEC, to submit the final number port activation order to Number Portability Administration Center (NPAC). Doing so will virtually eliminate the need for coordination with the CLEC at the time of the cutover.

Verizon argues that, because of the reduced coordination requirements, CLECs would not need to know the precise order in which the lines will be cut, and the cutover schedule will not need to be rigidly tied to the order in which "local service requests" are received. Once the cut and number port are complete, the process will be identical to the "Basic" and "Project" hot cut processes. Upon completion of the cut, Verizon will notify the CLEC through its Wholesale Provisioning Tracking System (WPTS).

Verizon places the following additional restrictions on the use of its proposed BHC process. The process would not apply to IDLC lines and to certain other loop types. The use of WPTS would be mandatory. One the BHC is submitted, no changes to the interim UNE-P account could be made without canceling and resubmitting the hot cut order. The process would not be offered for UNE-L to UNE-L migrations, nor would it be available for line splitting or line sharing orders.

B. Position of Other Parties

As discussed for SBC, parties raise similar concerns with respect to the hot cut processes proposed by Verizon. We incorporate by reference that discussion above. As with SBC, parties argue that Verizon's hot cut processes should not be approved without first addressing the deficiencies identified by the CLEC parties. The claimed deficiencies are discussed in further detail below.

C. Discussion

We find that the proposed Verizon systems are not yet sufficiently developed to ensure a seamless transition from UNE-P to UNE-L in their present form. For that reason, we adopt the batch processes and volume limits proposed by Verizon only on an interim basis. Verizon's proposed volume limits are not set at a specific number, but are based upon achieving a "critical mass" of orders. We set forth additional requirements to be met, as discussed below, in order for Verizon's systems to provide a "seamless" and "efficient" process for the migration of customer loops from UNE-P to UNE-L.

⁵⁵ A diagram of the basic hot cut process is in Appendix II-A to Exhibit 24 (Verizon BHC Panel Testimony).