2. Summary of Request

The petition was filed on July 26, 2000, by AT&T Communications, Inc.; Covad Communications Co.; Electric Lightwave, Inc.; ICG Access Services, Inc.; Nextlink California, Inc.; Sprint Communications, Inc.; and WorldCom, Inc. (Collectively, the Joint Petitioners.) The Joint Petitioners seek to extend the time for testing and substitute a concept of "openness" for the concept of "independence and blindness" that has governed the third-party testing of OSS. The Joint Petitioners explain:

"In the context of third-party testing, openness can be defined broadly as enabling all interested parties to examine and comment upon, on a real-time basis, the assumptions, methodology, practices, and observations of the test administrator and test generator. The relatively high-level and generalized nature of the [Master Test Plan]'s definition of test processes and the test administrator's bias against communications with CLECs has resulted in a California OSS test that cannot fairly and accurately document whether Pacific is providing CLECs with a meaningful opportunity to compete in the marketplace." (Joint Petition, at 2.)

The Joint Petitioners ask that D.98-12-069 be modified to provide the following forms of relief:

1. Additional access to test results and data on a real-time basis, prior to the issuance of the final test report;

2. Adoption of a document that the CLECs describe as a "Blueprint for Openness";

3. Expanded testing of DS1 loops; and

4. Issuance of a timetable and plan for Pacific to demonstrate compliance with the UNE Remand Order recently issued by the Federal Communications Commission (FCC).

The Joint Petitioners assert that their inability to obtain real-time information about testing methodologies and observations inhibits their ability to ensure that the test processes are thorough and relevant to the CLECs' experience. They state that their expertise can ensure that the procedures for testing are sufficiently detailed to capture potential variations in outcome that could affect the quality of service that will be offered by Pacific to CLECs.

Pacific's response to the petition was filed on August 25, 2000. By Administrative Law Judge ruling, the Joint Petitioners were granted the right to reply to Pacific's response, and they did so on September 11, 2000.