ALJ/KAJ/jva DRAFT Agenda ID #5314

Ratesetting

Decision DRAFT DECISION OF ALJ JONES (Mailed 1/27/2006)

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Petition of Verizon California Inc. (U 1002 C) for Arbitration of an Amendment to Interconnection Agreements with Competitive Local Exchange Carriers and Commercial Mobile Radio Service Providers in California Pursuant to Section 252 of the Communications Act of 1934, as Amended, and the Triennial Review Order.

Application 04-03-014
(Filed March 10, 2004)

DECISION ADOPTING AMENDMENT

TO EXISTING INTERCONNECTION AGREEMENTS

Table of Contents

Title Page

DECISION ADOPTING AMENDMENT TO EXISTING INTERCONNECTION AGREEMENTS 2 2

I. Summary 2 2

II. Background 2 2

III. Disputed Issues 4 4

1. Issue 1: Sections 1, 2.2, 2.4, 2.6, 3.1.1, 3.1.2, 3.2.1, 3.2.2, 3.2.3, 3.2.4, 3.3.10, 3.9.3, 3.11.1, 3.11.2, 3.11.2.5 - Should the Amendment refer to Verizon's tariff? 5 5

2. Issue 2: Scope of Amendment 7 7

(a.) Sections 2.1, 2.2, 2.3, 2.7, 3.1.2, 3.2.2, 3.2.3, 3.3.10, 3.6.1.1, 3.6.2.1,
3.12.1, 4.7.1, 4.7.21 - Are Verizon's obligations under the Amendment
limited to "Federal Unbundling Rules" as Verizon contends; or should the Amendment include rates, terms and conditions that do not arise from federal unbundling regulations pursuant to 47 U.S.C. sections 251 and 252, including issues asserted to arise under "Applicable Law" as CLECs
contend? Should the Amendment include a definition for Federal Unbundling Rules? If so, what is the definition? Should the
Amendment include a definition for Applicable Law? If so, what is the definition? 7 7

(b.) Section 4.4 (and the references to § 4.4 in Sections 2.4, 3.1.1, 3.1.2,
3.2.1, 3.2.2, 3.2.3, 3.2.4, 3.3.10, 3.6.2.3) - Should the CLECs' proposed
language be added to this section to state that the Amendment does not
alter or modify "any rights and obligations under Applicable Law contained in the Agreement, other than those Section 251 rights and obligations specifically addressed in the amendment"? Should the Commission
approve the CLECs' additional language stating that "execution of this Amendment shall not be construed as a waiver with respect to whether Verizon, prior to the Amendment Effective Date, was obligated under the Agreement to perform certain functions required by the TRO"? 9 9

(c.) Section 2.7 - Should the Amendment state that replacement arrangements
for elements the FCC has de-listed are not subject to the requirements of
47 U.S.C. § 252? 11 11

(d.) Section 2.5, 2.5.1 - How should the Amendment address Verizon's pre-existing discontinuance rights, if any? 12 12

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3. Issue 3: Sections 2.4, 2.5, 2.7, 3.6.3.1, 3.9.1, 3.9.2, 3.9.2.1, 4.7.11 -
Should the Amendment use Verizon's term "Discontinued Facility"
or the CLECs' term "Declassified Network Element" to refer to elements
that Verizon is no longer required to provide under Section 251 (c)(3)
or 47 C.F.R. Part 51? What is the appropriate definition for the term to be used in the Amendment? Should the Amendment reference or address commercial agreements that may be negotiated for services or facilities to which Verizon is not required to provide access as a UNE? 12 12

4. Issue 4: General Terms with Respect to Notice and Discontinuation of
De-listed Items: 15 15

(a.) Section 2.4, 2.4.2, 2.5, 2.5.1, 3.4.1.2.5, 3.4.2.2.5, 3.4.3.2.5, 3.5.1.2.5, 3.5.2.2.5, 3.5.3.2.5 - How should the Amendment address notice of discontinuation
of a de-listed item? 15 15

(b.) Section 2.4.1 and 2.4.2 - Should the Amendment permit Verizon to disconnect, convert, and/or reprice de-listed elements for which the CLEC has not requested disconnection or obtained alternative arrangements? 17 17

5. Issue 5: Section 2.6 - Should the Amendment address packet switching?
If so, how? 17 17

6. Issue 6: FTTH and FTTC Loops 18 18

(a.) Section 3.1.1 - What, if any, are Verizon's obligations to provide
unbundled access to newly built FTTH and FTTC loops? 18 18

(b.) Section 3.1.2 - What, if any, are Verizon's obligations to provide
unbundled access to overbuilt FTTH and FTTC loops? Is Verizon
required to provide up to 24 such voice grade transmission paths when it retires a DS-1 copper loop? 19 19

(c.) Section 3.1.2.1 - Should the Amendment impose new terms, conditions, notice and/or CLEC approval requirements on Verizon's ability to retire copper loops? 20 20

(d.) Sections 3.2, 4.7.2.4, 4.7.2.5, 4.7.2.7, 4.7.34 - (a) Should the Amendment distinguish between "mass market" customers and other types of
customers for purposes of applying the FCC's FTTH and FTTC unbundling rules? (b) If so, then how should the Amendment define "mass market" for these purposes? 21 21

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7. Issue 7: Hybrid Loops: 25 25

(a.) Section 3.2.1 - For packet switched features, functions and capabilities of Hybrid Loops, should the Amendment read that "Verizon shall not be required to provide [such access] to any Hybrid Loops" or "CLECs shall not be entitled to obtain [such access] to its Hybrid Loops"? 25 25

(b.) Sections 3.2.4, 3.2.4.1 - How should the Amendment reflect Verizon's obligation to fulfill a CLEC's request for access to a loop to a customer premises that Verizon serves with an IDLC Hybrid Loop? Under what conditions can Verizon impose non-recurring charges other than standard loop order charges? 25 25

(c.) Section 3.2.4.2 - Where neither a copper Loop nor a Loop served by
UDLC is available, how should the Amendment reflect Verizon's
obligation to provide a technically feasible method of access? Under what circumstances is CLEC responsible for new construction charges? 27 27

8. Issue 8: Section 3.2.5 - Should the Amendment specify that when a CLEC requests access to a Loop, Network Interface Device functionality shall be provided at no additional charge? Section 3.2.6 - Should the Amendment require Verizon to provide physical loop test access points to CLEC for testing, maintaining, and repairing copper loops and subloops? If so, should the Amendment specify the physical points? 27 27

9. Issue 9: Sections 3.3 through 3.3.10 - What terms for CLEC access to subloops should be included in the Amendment? 29 29

10. Issue 10: Loops and Transport: 32 32

(a.) Sections 3.4.1.1.2, 3.4.2.1.2, 3.5.1.1.2, 3.5.2.1.2 - How should the Amendment treat a CLEC's affiliate(s) for purposes of applying the FCC's caps on availability of unbundled DS1 and DS3 UNE Loops and Transport? 32 32

(b.) Section 3.5.1.1.2 - Does the FCC's cap of 10 UNE DS-1 dedicated transport circuits apply only on routes where UNE DS3 dedicated transport is unavailable? 33 33

(c.) Sections 3.4.1, 3.4.3.1, 3.5.1, 3.5.2, 3.5.3 - Should "Section 251(c)(3)"
be included as a qualifier for DS1, DS3 and Dark Fiber Loops and
Transport? 35 35

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(d.) How should the Amendment address the transition away from DS1 loops and transport, DS3 loops and transport, and dark fiber loops and transport that Verizon is no longer required to unbundle? In particular, 35 35

(1) Sections 3.4.1.2.1, 3.4.2.2.1, 3.4.3.2.1, 3.5.1.2.1, 3.5.2.2.1, 3.5.3.2.1 -
Should the embedded base be defined to include orders submitted,
but not yet provisioned as of March 11, 2005? 35 35

(2) Sections 3.4.1.2.2, 3.4.2.2.2, 3.4.3.2.2, 3.5.1.2.2, 3.5.2.2.2, 3.5.3.2.2 -
Should the Commission approve the CLECs' proposed language addressing CLEC options for conversion from de-listed loops and transport? 36 36

(3) Sections 3.4.1.2.1, 3.4.2.2.1, 3.4.3.2.1, 3.5.1.2.1, 3.5.2.2.1, 3.5.3.2.1,
3.4.1.2.2, 3.4.2.2.2, 3.4.3.2.2, 3.5.1.2.2, 3.5.2.2.2, 3.5.3.2.2 - Should the TRRO's transition rates for de-listed loops and transport apply
for the entire transition period if conversion to alternative
arrangements occurs before the end of the period? 37 37

(4) Sections 3.4.1.2.3, 3.4.2.2.3, 3.4.3.2.3, 3.5.1.2.3, 3.5.2.2.3, 3.5.3.2.3 -
Should the Commission approve the CLECs' provisions addressing replacement of de-listed loops and transport with self-provisioned facilities or facilities or services of third parties? 38 38

(5) Sections 3.4.1.2.4, 3.4.2.2.4, 3.4.3.2.4, 3.5.1.2.4, 3.5.2.2.4, 3.5.3.2.4, 3.8 - Should the Amendment states that any discontinuance or conversions
of de-listed items "shall take place in a seamless manner that does not affect the customer's perception of service quality"? 38 38

(6) Sections 3.4.1.2.5, 3.4.2.2.5, 3.4.3.2.5, 3.5.1.2.5, 3.5.2.2.5, 3.5.3.2.5 -
Should the Commission approve the CLECs' proposed provisions requiring Verizon to convert de-listed loops or transport facilities to
"an analogous special access arrangement at month-to-month pricing,"
in the event a CLEC does not request disconnection of, or obtain replacement arrangements for, such de-listed facilities? 40 40

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11. Issue 11: Certification and Provisioning: 41 41

(a.) Section 3.6.1.1, 3.6.1.2, 3.6.1.3 - How should the Amendment reflect the TRRO's certification process for ordering high-capacity loops and transport? How should the Amendment address back-up data supporting Verizon's designation of non-impaired wire centers? How should the Amendment
state Verizon's obligation to process a request for unbundled access to a TRRO Certification Element? 41 41

(b.) Sections 3.6.2.2, 3.6.2.2.1 - What are Verizon's obligations when disputing CLECs' certification? For example, should the Amendment establish a
30-day time period for Verizon to dispute a CLEC's certification? If
Verizon prevails on such a dispute, how should the facility be re-priced? 47 47

(c.) Sections 3.6.2.3, 3.6.3.6 - Under what circumstances may Verizon reject a CLEC certification without first seeking dispute resolution? 48 48

(d.) Section 3.6.3.1 - If Verizon adds wire centers to its "no-impairment" list
that do not appear on the list when the Amendment takes effect, what is
the appropriate transition period for elements/facilities provided out of
those wire centers? 49 49

(e.) Section 3.6.3.2 - Should Verizon be required, on a quarterly basis, to post on its website information advising when it believes a wire center has reached 90% of the number of business lines needed for the wire center to be
classified as a Tier 1 or a Tier 2 wire center, and to specify which wire
centers it considers to have 2 or 3 fiber collocators? 51 51

(f.) Section 3.6.3.3 - (i) Should the Amendment limit the application of termination liabilities or penalties when the CLEC disconnects tariffed transport or collocation facilities if a wire center is determined to be non-impaired? (ii) If so, how should such termination liabilities or penalties be calculated? 52 52

(g.) Sections 3.6.3.4, 3.6.3.4.1 - Should the Amendment include the CLECs' provision stating that, with respect to seeking new UNEs from newly designated wire center(s), CLECs may provide a self-certification more
than 60 days after Verizon's designation? If so, should the Amendment
also state that Verizon is required to provision new UNEs during the
dispute resolution process? Should the Commission approve the CLECs' proposal for 12- and 18-month transition periods, with no rate increases,
for UNEs that become de-listed when wire centers are added to the list of non-impaired wire centers? 53 53

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(h.) Section 3.6.3.5 - Should the Amendment include a provision that allows
for the reversion of non-impaired wire centers to impaired wire centers?
If so, what credits, if any, and procedures should apply in connection with the reversion? 55 55

(i.) Section 3.6.3.7 - Should the Commission approve the CLECs' proposed Section 3.6.3.7, which states that nothing in Section 3.6.3 "shall in any way limit any right [CLEC] may have to challenge Verizon's reversion of its
Wire Center Lists"? 56 56

12. Issue 12: Charges: 57 57

(a.) Sections 3.4.1.2.4, 3.4.2.2.4, 3.4.3.2.4, 3.5.1.2.4, 3.5.2.2.4, 3.5.3.2.4, 3.8, 3.9.3 - How should the Amendment address non-recurring charges related to the transition away from de-listed UNEs? 57 57

13. Issue 13: Mass Market Switching and Related Elements: 61 61

What obligations, if any, with respect to unbundled access to local circuit switching, including mass market and enterprise switching, should be
included in the Amendment? 61 61

(a.) Sections 3.7.1, 4.7.34 - Should this provision be limited to the provisions
of Section 251(c)(3)? How should "Mass Market Switching" be defined
for purposes of the Amendment? 61 61

(b.) Section 3.7.2 - Should the Amendment address modifications to the
TRRO transition rules by the California Commission? 63 63

(c.) Section 3.7.2 - Should the Commission approve the CLECs' § 3.7.2
language stating that CLECs can order new Mass Market Switching arrangements for their embedded base until May 1, 2005? 63 63

(d.) Sections 3.7.2, 3.7.3.1 - Should the Amendment state under what circumstances Verizon is obligated to continue to service CLEC UNE-P Embedded Base Customers? How should the embedded base of
end user customers be defined? 64 64

(e.) Section 3.7.2 - Should the Commission approve the CLECs' proposed language regarding conversion of UNE-P to a UNE line splitting arrangement? 65 65

(f.) Section 3.7.2 - Should the Amendment provide that parties agree to use
the TRRO transition period to accomplish an orderly transition? 66 66

(g.) Section 3.7.2 - Should the Commission approve the CLECs' language in
§ 3.7.2 addressing the transition period for UNE loop switching and
UNE-P? 66 66

(h.) Section 3.7.2 - Should the Commission approve the CLECs' proposed language for § 3.7.2 with respect to minimizing customer disruptions
and coordinating conversions? 68 68

(i.) Section 3.7.4 - What is the scope of Verizon's obligation to provide access
to signaling, call-related databases and shared transport facilities to the
extent that Mass Market Switching is required to be made available
under § 3.7 of the Amendment? Should the Amendment reference
47 C.F.R. Part 51? 69 69

(j.) Sections 3.8, 3.8.2.3 - How should the Amendment address payment of transition charges, including both prospective and retrospective transition charges? 69 69

(k.) Section 3.8.2.3 - Should the Amendment specify the information Verizon must provide in bills for any transition or true-up charges? 70 70

14. Issue 13 Part II: Discontinuance of TRRO Embedded Base at the End of the Transition Period 70 70

(a.) Sections 3.9.1, 3.9.1.1, 3.9.2 - What effective date and other restrictions are appropriate for CLEC transition orders to an alternative service? 70 70

(b.) Section 3.9.1.1 - How should the Amendment address re-pricing of
de-listed items in the event that Verizon cannot complete a CLEC's conversion or migration order by the end of the relevant TRRO transition period? 71 71

(c.) Sections 3.9.2, 3.9.2.1 - What notice requirements, if any, must Verizon
follow if a CLEC fails to order disconnection or obtain replacement
services for its embedded base of de-listed facilities? How should the Amendment address re-pricing such facilities if Verizon is unable to
complete the migration or conversion by March 11, 2006? 72 72

15. Issue 14: Form of Conversion Requests 73 73

(a.) Sections 3.4.1.2.2, 3.4.2.2.2, 3.4.3.2.2, 3.5.1.2.2, 3.5.2.2.2, 3.5.3.2.2, 3.7.2 -
Should CLECs be permitted to submit conversion requests for de-listed services and facilities on a manual basis? 73 73

16. Issue 15: Section 3.9.4 - Should the Amendment address terms to be applied
if Verizon denies a CLEC request for access to conduit space? 74 74

17. Issue 16: Section 3.10 - What terms and conditions should the Amendment include to address Line Sharing? 74 74

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18. Issue 17: Commingling & Combinations 75 75

(a.) Sections 3.11.1, 3.11.1.1, 3.11.1.3.2 - What is the scope of Verizon's
obligations to provide commingling and combinations? 75 75

(b.) Section 3.11.1.1 - Should the Amendment provide that Verizon CA will
make certain Commingled Arrangements available in California if Verizon makes them available in any of its other state territories, whether voluntarily or pursuant to a state commission order? 76 76

(c.) Sections 3.11.1.1, 3.11.1.3 - Should the Amendment list those commingling arrangements that Verizon must provide? If so, what Commingling Arrangements should Verizon be required to offer CLECs in this Amendment? What commingling restrictions, if any, should apply to
de-listed facilities/elements? 77 77

(d.) Section 3.11.1.1 - What ordering processes should apply to commingling arrangements? To future arrangements? 78 78

(e.) Section 3.11.1.1 - Should the Amendment require Verizon to connect
loops leased or owned by CLEC to a third-party's collocation arrangement,
or to connect an EEL leased by CLEC to a third-party's collocation or vice versa? 79 79

(f.) Section 3.11.1.1 - Should the Amendment address non-recurring charges
for performing commingling? If so, how? 81 81

(g.) Section 3.11.1.1 - Should the Commission approve the CLECs' language imposing notice, grandfathering, and other requirements upon Verizon
in the event that Verizon "changes its Access tariffs, or adds new Access tariff(s), that would restrict or impact the availability or provisioning of Commingled Arrangements"? 83 83

(h.) Sections 3.11.1.1, 3.11.1.2 - How should commingled arrangements be
priced? How should the FCC's restrictions on "ratcheting" be worded? 85 85

19. Issue 18: Section 3.11.1.4 - Should the Commission approve the CLECs' proposed language for conversion of wholesale services to UNEs
and vice versa? 86 86

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20. Issue 19: Performance Measures: 88 88

(a.) Sections 3.2.4.3, 3.11.1.2, Former 3.11.2.6, 3.12.2, 3.14.3 - If an effective
order of the Commission or the FCC does not expressly require standard provisioning intervals and performance measures and remedies in connection with Verizon's provision of the following items, may Verizon exclude its performance from standard provisioning intervals and performance measures and remedies in connection with its provision of: 88 88

21. Issue 20: Interconnection, Signaling 90 90

(a.) Sections 3.5, 3.5.4, 3.5.4.1, 3.13, 3.13.1 - What obligations, if any, with
respect to interconnection facilities under section 251(c )(2) should be included in the Amendment to the parties' interconnection agreements? 90 90

22. Issue 21: EELs 93 93

Sections 3.11.2, 3.11.2.1 - What obligations with respect to the conversion
of wholesale services (e.g., special access circuits) to UNEs or UNE
combinations (e.g., EELs) should be included in the Amendment to the
parties' interconnection agreements? In particular: 93 93

(a.) Sections 3.11.2.1.5, Former 3.11.2.3 - What information should a CLEC
be required to provide to Verizon (and in what form) as certification to
satisfy the FCC's service eligibility criteria to convert existing circuits/services to EELs or order new EELs? 94 94

(1) Sections Former 3.11.2.2, 3.11.3 (Former Section 3.11.2.2) - What type
of charges, if any, and what conditions, if any, can Verizon impose for Conversions from wholesale services to UNEs? 96 96

(2) Section 3.11.4.3 (Former 3.11.2.6) - For conversion requests submitted by a CLEC prior to the effective date of the amendment, should CLECs be entitled to EELs/UNE pricing effective as of the date the CLEC submitted the request (but not earlier than October 2, 2003)? 97 97

(3) Sections 3.11.4.3 (Former 3.11.2.6), 3.11.4.4 (Former 3.11.2.7) - When should a Conversion be deemed completed for purposes of billing? 98 98

(b.) Section 3.11.4.1 (Former 3.11.2.4) - When Verizon performs a conversion
for the CLEC, should the Amendment prohibit Verizon from disconnecting
or altering any facilities, and should the amendment allow CLECs to order any alteration as part of the conversion (as opposed to before or after the conversion)? 98 98

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(c.) Section 3.11.2.2 (Former 3.11.2.9) -- How should the Amendment
address audits of CLEC compliance with the FCC's service eligibility
criteria? 99 99

(d.) Section 3.11.2.7 (Former 3.11.2.8) -- Should the Amendment provide that
all ASR conversions will result in a change in the circuit ID? 102 102

23. Issue 22: Routine Network Modifications 103 103

(a.) Sections 3.12.1, 3.12.1.1 - How should the Amendment reflect Verizon's obligation to perform routine network modifications necessary to permit access to loops, dedicated transport, or dark fiber transport facilities? 103 103

(b.) Section 3.12.1.1 - What Routine Network Modifications should Verizon be required to undertake for UNE local loops, UNE dedicated transport, and dark fiber? 105 105

(c.) Section 3.12.1.2 - For each such required routine Network Modification,
do the current Commission-approved nonrecurring and monthly recurring rates for the UNE local loop, UNE dedicated transport, or dark fiber
recover the TELRIC cost of the Routine Network Modification? If not, should Verizon be allowed to impose any additional nonrecurring and/or
monthly recurring charges, and if so, under what conditions and in what amounts? 107 107

(d.) Section 3.12.1.3 - Should the Commission approve the CLECs' proposal to give the CLEC a credit when Verizon doesn't provision a CLEC's DS1
UNE loop order within 14 days due to the need to perform routine network modifications? 109 109

(e.) Sections 3.12.1.4, 3.12.15-Should the Commission approve these
provisions imposing certain requirements upon Verizon when it rejects a
DS1 UNE loop order with a jeopardy code indicating that facilities are unavailable and/or cable placement is required? What modifications,
if any, to Verizon's current preordering, ordering, and provisioning systems and practices, including standard provisioning intervals, are required with respect to Routine Network Modifications if the commission adopts the CLECs' proposed language? 111 111

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24. Issue 24: Should the following definitions be included in the Amendment?
If so, what are the appropriate definitions for each: 112 112

(a.) Section 4.7.2 - Business Line 112 112

(b.) Section 4.7.3 - Building 113 113

(c.) Section 4.7.5 - Combination 114 114

(d.) Section 4.7.6 - Commingling 114 114

(e.) Section 4.7.7 - Cross Connection 115 115

(f.) Section 4.7.8 - Dark Fiber Loop 115 115

(g.) Section 4.7.9 - Dark Fiber Transport 116 116

(h.) Section 4.7.10 - Dedicated Transport 116 116

(i.) Section 4.7.12 - Distribution Sub-Loop Facility 117 117

(j.) Section 4.7.13 - DS0 117 117

(k.) Section 4.7.18 - Enhanced Extended Link (EEL) Combination 118 118

(l.) Section 4.7.19 - Entrance Facility 118 118

(m.) Section 4.7.22 - Fiber-Based Collocator 119 119

(n.) Hot cuts (this issue has been deferred) 119 119

(o.) Section 4.7.27 - Hybrid Loop 119 119

(p.) Section 4.7.28 - Inside Wire Subloop 120 120

(q.) Section 4.7.30 - Line Conditioning 120 120

(r.) Section 4.7.32 - Loop or Local Loop 121 121

(s.) Section 4.7.33 - Loop Distribution 121 121

(t.) Section 4.7.36 - Packet Switching 121 121

(u.) Section 4.7.38 - Routine Network Modifications 121 121

(v.) Section 4.7.39- Signaling (Signaling System 7) 122 122

(w.) Section 4.7.40 - Single Point of Interconnection (SPOI) 122 122

(x.) Section 4.7.41 -- Sub-Loop for Multiunit Premises Access 123 123

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25. Issue 25: Pricing Attachment: 124 124

(a.) Section 1.2 - When applying any applicable rates what documents should control? Specifically, should the Pricing Attachment reference the Agreement, the Amended Agreement, Exhibit A, and/or Verizon's federal
or state tariff? 124 124

(b.) Section 1.3 - Should the Pricing Attachment provide that any charges approved or allowed by the Commission or FCC should apply without further amendment to the ICA? 126 126

(c.) Section 1.4 - Should the Pricing Attachment provide that charges covered
by Sections 1.2 and 1.3 are applicable whether or not so stated in the text
of the Amendment? 126 126

Comments on Draft Decision 126 126

Assignment of Proceeding 127 127

Findings of Fact 127 127

Conclusions of Law 130 130

ORDER 131 131

DECISION ADOPTING AMENDMENT
TO EXISTING INTERCONNECTION AGREEMENTS

I. Summary

In this decision, we adopt an amendment to the existing interconnection agreements (ICAs) that various Competitive Local Exchange Carriers (CLECs) and Commercial Mobile Radio Service Providers have with Verizon California Inc. (Verizon). This change-of-law proceeding results from changes in federal unbundling obligations of Incumbent Local Exchange Carriers (ILECs). The parties have attempted to negotiate amendments to their ICAs in order to implement the changes in unbundling rules. The purpose of this consolidated proceeding is for the Commission to resolve those issues on which parties were unable to come to agreement.