ALJ/GEW,JAR/tcg DRAFT 1

11/21/00

Decision DRAFT DECISION OF ALJ REED (Mailed 10/18/2000)

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Rulemaking on the Commission's Own Motion to Govern Open Access to Bottleneck Services and Establish a Framework for Network Architecture Development of Dominant Carrier Networks.	Rulemaking 93-04-003
Investigation on the Commission's Own Motion Into Open Access and Network Architecture Development of Dominant Carrier Networks.	Investigation 93-04-002
Order Instituting Rulemaking on the Commission's Own Motion Into Competition for Local Exchange Service.	Rulemaking 95-04-043
Order Instituting Investigation on the Commission's Own Motion Into Competition for Local Exchange Service.	Investigation 95-04-044

OPINION

1. Summary

Seven competitive local exchange carriers (CLECs) have filed a Petition for Modification of Decision (D.) 98-12-069, in which the Commission chartered the testing of the Operation Support Systems (OSS) of Pacific Bell (Pacific) prior to Pacific's entry into the long distance market as a result of the anticipated emergence of robust competition in the local exchange market. In essence, the Petition for Modification seeks additional access and control of the testing process and contemplates an extension of time for completion of the OSS tests. While the petition raises numerous concerns of these seven carriers, it is filed belatedly on the eve of the competition of the testing process and seeks substantial revisions in a process carefully crafted by all parties to these proceedings under the direction of the Commission and its consultants. For the reasons set forth below, the Petition for Modification is denied.