At least 60 days prior to the projected cut-off 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. On February 25, 2008, Applicant submitted its customer list to CD. Applicant submitted its customer list 50 days prior to the projected cut-off date, less than the required 60 days. However, Applicant provided the necessary information with sufficient lead time to allow staff to assess the nature of the customers being transferred, track the progress of the migration, and 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. Applicant states that its CSRs14 are being kept and maintained in computerized, data-storage inventory systems. After the customers' cut off date has passed for selecting an alternate carrier, Applicant advises that it will develop a list containing the noted CSR information and provide it to alternate carrier(s) 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 the alternate carrier(s) as the trigger to commence mass migrations from Applicant's local service platform to the local service platform of the alternate carrier(s). Then, Applicant will supply the CSR information to those alternate carriers taking customers in accordance with the existing interconnection agreements. Accordingly, Applicant has satisfied our requirement to have available the CSR data elements needed to enable any carrier to migrate Applicant's customers seamlessly.
14 There are eight data elements associated with the CSRs: billing account number, working telephone number(s), customer billing name, customer billing address (same as Service Address), Service Type (e.g., Local Wholesale Complete or Telephone Service Request), Telephone Number Service Codes, Class of Service (residential only), and Customer directory listings.