3. Background and Purpose of OSS Test

In order to obtain approval to provide in-region long-distance service, Pacific must demonstrate that it provides non-discriminatory access to CLECs pursuant to a 14-point checklist enumerated in Section 271(c)(2)(C) of the Telecommunications Act of 1996. The FCC has stated that the most probative evidence of non-discriminatory access is actual performance data, including third-party testing.

In D.98-12-069, the Commission authorized Pacific to conduct third-party testing and directed the utility to file an OSS Master Test Plan (MTP) by January 11, 1999. Meanwhile, the Commission's Telecommunications Division retained Telcordia Technologies as a technical adviser in evaluating Pacific's MTP. On April 23, 1999, an Assigned Commissioner's Ruling directed Pacific and the CLECs to comment on several issues related to OSS testing and to Telcordia's reports on the MTP. In response, Pacific and interested CLECs asked the Assigned Commissioner to convene a collaborative workshop on the MTP.

The workshop was conducted between June 7 and June 15, 1999, and parties reviewed all aspects of the MTP. With the guidance of Telcordia and Commission staff, Pacific and the CLECs revised the MTP to include order and product types associated with various modes of CLEC entry, including Resale, local number portability (LNP), Loop with Port, Basic and Assured Loops, xDSL Loops, DS1 Capable Loops, and stand-alone directory listings. The functional areas of pre-ordering, order provisioning, billing, and maintenance and repair were included in the MTP. Testing would include both residence and business orders encompassing new, conversion "as specified," partial configurations, disconnects, cancellations, supplementals, and suspend and restore order types. From an ordering perspective, the testing was designed to generate acknowledgements, error rejections, firm order commitments, and service order completions. In addition, testing was to include a variety of feature combinations, directory listings, 900/976 blocking and toll restrictions.

During the workshop, parties designed the MTP around two types of testing: end-to-end functionality testing and capacity testing. The parties also decided that the Commission would be the test owner and project manager, assisted by Telcordia. To prevent any party from having advance knowledge of tests and ensure independence, Pacific and the CLECs agreed that the MTP would provide two additional expert roles: Test Generator and Test Administrator/Manager. The Test Administrator would oversee test execution and assess the processes and test results. The Test Generator would develop interfaces and install connectivity using the same set of requirements and documents available to the CLECs in pre-order/ordering system interfaces. The Test Generator also would be responsible for the creation and input of test orders and pre-ordering queries.

Pacific and the CLECs also agreed on the establishment of a Technical Advisory Board (TAB) comprised of representatives from Pacific, interested CLECs, the Commission, and third parties. The Test Administrator has convened regular meetings to keep TAB members apprised of test information and to obtain feedback, and has convened regular meetings with CLECs only to discuss CLEC-specific issues.

Following a Request for Proposal and a Bidders Conference to which all interested parties were invited, the Commission selected Cap Gemini, Ernst & Young, as the OSS Test Administrator and Technical Advisor. GE Information Services (now GE Global Exchange Services or "GXS) was engaged to act as the Test Generator.

The Assigned Commissioner's Ruling of June 29, 1999, found that the MTP provided for "a collaborative approach among the CLECs, the Commission, Pacific and the Third Parties as appropriate." Comments on the MTP were submitted by Pacific and the CLECs on July 12, 1999, and on August 20, 1999, the MTP was approved. Nearly all issues were closed by consensus prior to the August 20, 1999 ruling, and most open issues were resolved in the CLECs' favor by the Commissioner's ruling.