7. Customer List and Customer Service Records (CSR)

At least 60 days prior to the projected cutover date, the exiting CLEC must submit its customer list to the Commission. Carriers' submission of customer lists and staff use of or disclosure of customer list information are subject to applicable laws and regulations relating to public disclosure of records, confidential trade secret status, and privacy protections. Applicant's customer list totals more than 240,000 entries. Therefore, Applicant first made the list available to the CD in early fall 2007 and has made the list routinely available for updated review. As a result, we find that Applicant has provided the necessary information with sufficient lead time to allow staff to assess the nature of the customers being transferred, to track the progress of the migration, and to facilitate the customer migration process.

Exiting CLECs must also have available the CSR data elements specified in the Guidelines that are needed to enable any carrier to migrate the exiting CLEC's customers seamlessly. CSRs are classified as customer proprietary network information. Applicant represented that its CSRs are being kept and maintained in computerized, data-storage inventory systems accessible and managed with adherence to strict password-protected login policies and procedures.

After the customers' cut-off date has passed for selecting an alternate carrier, Applicant stated that it would develop a list containing CSR information and provide it to AT&T California via electronic file transfer. This list will contain and identify Applicant's customers who have not actively made a selection of a local exchange carrier and will be used by AT&T California as the trigger to commence the mass migrations from Applicant's local service platform to AT&T California's local service platform. Thus, Applicant has satisfied our requirement to have available the CSR data elements needed to enable any carrier to migrate Applicant's customers seamlessly.