IV. SBC Hot Cut Processes (47 C.F.R. § 51.319(d)(2)(ii)(A)(2));-Overview

In addressing the four tasks assigned to the Commission by the TRO, we will begin with task 2, the adoption of a hot cut process, and subsequently address the size of the batch, the capacity of the process, and its price.

A. Position of SBC

SBC presented a proposal covering both one-at-a-time hot cuts for ongoing customer churn and a batch process for the cutover of the embedded base of existing UNE-P to UNE-L lines. SBC currently performs two types of hot cuts-Frame Due Time (FDT) and Coordinated Hot Cut (CHC). The FDT option describes a hot cut that is scheduled for a predetermined time with no CLEC coordination required. The "Local Operations Center" (LOC) technician travels to the central office (when necessary), runs the jumper from the "carrier's facility assignment"¹¹ to the end-use customer appearance on the frame, and then performs the "lift and lay," (i.e., the physical process to disconnect the customer loop from ILEC switching equipment and to reconnect it to the CLEC's switching equipment). Once this process is completed, the technician performs dial tone and phone number verification tests.

A CHC generally requires not only similar activities, but also coordination between the CLEC and workgroups within SBC on the day of the hot cut. In the case of an Integrated Digital Loop Carrier (IDLC) CHC, the field technician coordinates with the LOC.

SBC proposes three new hot cut options for one-at-a-time processing:

1. Enhanced Daily Process. This option is designed to support the CLECs' acquisition of new customers.

2. Defined Batch Process. This option is designed to allow CLECs to transition their embedded base of UNE-P customers to the CLEC's own switch. This offering may also be used for new acquisitions.

3. Bulk Project Process. This option provides CLECs with an additional manner for scheduling hot cuts. The Bulk Project offering may be used for both new acquisitions and embedded base customers and may be used in instances where the requesting CLEC wishes to arrange for hot cut options that are not available under either the Enhanced Daily Process or the Defined Batch Process.

SBC proposes three batch cut options that differ in the numbers of cut-overs to which they pertain and in the days and times of availability, as follows:

1. Daily Batch. With this option, each CLEC can request up to 50 mass market cut-overs per day in each of SBC's central offices. The due date intervals that currently apply to SBC's hot cut process (namely, three business days) is carried over to this process. Daily batch cuts are available Monday through Friday (excluding holidays), from 8:00 AM to 5:00 PM.

2. Defined Batch. This option permits up to 100 hot cuts per day per CLEC in each central office, scheduled at any hour of any day, except Sunday. (Database maintenance is done at the National Portability Administration Center (NPAC) on Sundays.) Defined Batch orders are to be received 13 business days before the date on which the cuts are to be made.

3. Bulk Project. The Bulk Project offering will be akin to today's negotiated "project," whereby SBC and the requesting carrier work together to plan the transition of a large, negotiated, number of loops to the requesting carrier's switch. This number may be much higher than the 100-loop maximum (per CLEC per central officer per day) under the Defined Batch offering. Even after the embedded base has been transitioned to CLEC switches, this option will remain available for carriers to transition large numbers of mass market customers from SBC's network to their own network.

B. Position of Other Parties

Three major CLEC parties sponsored testimony concerning SBC's batch cut processes, AT&T, MCI, and Covad. Generally, the CLECs claim that SBC's proposed hot cut processes do not meet the TRO requirement for a "seamless" process, and are deficient in that they:

· cannot handle the volumes needed to migrate customers between carriers if CLECs lose access to UNE switching;

· fail to address the migration of all customer services;

· create unacceptable delays on customer migrations;

· create unacceptable service disruptions; and

· fail to set forth an efficient end-to-end process (including database changes and porting of customer numbers) for migrating customers between carriers.

The specific problems with the hot cut processes claimed by the CLECs and proposed remedies are discussed below. The CLECs argue that a BHC process should not be approved until the deficiencies have been adequately addressed. The CLECs argue that although SBC provided assurances that its proposed systems are adequate, those assurances are not supported by the facts.

C. Discussion

We agree that the proposed SBC systems are not yet sufficiently developed to ensure a seamless transition from UNE-P to UNE-L in their present form. For that reason, we adopt the batch processes and volume limits proposed by SBC only on an interim basis. We set forth additional requirements that need to be met, as discussed below, in order for the proposed systems to provide a "seamless" and "efficient" process for the migration of customer loops from UNE-P to UNE-L.

¹¹ The Carrier Facilities Assignment is the point where the line to the CLEC collocation area appears on the frame.