McLaughlin Aff by oUEnRF


									                               BEFORE THE
                           WASHINGTON, D.C. 20554

In the Matter of                                 )
Joint Application by SBC Communications Inc.,    )
Southwestern Bell Telephone Company, and         )
Southwestern Bell Communications Services,       )    CC Docket No. ________
Inc. d/b/a Southwestern Bell Long Distance for   )
Provision of In-Region, InterLATA Services in    )
Kansas and Oklahoma                              )


STATE OF TEXAS              )
COUNTY OF DALLAS            )

                                 TABLE OF CONTENTS
                                  BILLING AFFIDAVIT

SUBJECT                                                                  PARAGRAPH
PROFESSIONAL EXPERIENCE                                                       2
EXECUTIVE SUMMARY                                                             3
CRIS BILLING                                                                  5
CABS BILLING                                                                  8
USAGE EXTRACT                                                                11
BILLING RATE TABLES                                                          15
BILLING DATES                                                                18
OVERLAPPING BILLING                                                          21
BILLING CYCLES                                                               24
BILLING TIMELINESS                                                           30
CUSTOMER USAGE DATA                                                          34
BILLING PERFORMANCE MEASURES                                                 35
CONCLUSION                                                                   36

I, Weldon McLaughlin, being of lawful age and duly sworn upon my oath, do hereby depose and

state as follows:

1. My name is Weldon McLaughlin. I am Director-Billing Project Management for
    Southwestern Bell Corporation Services, Inc. (SBC Services). My business address is 211

    S. Akard, Two Bell Plaza, Room 1100.01, Dallas, Texas 75202. I am responsible for billing

    system development to support wholesale billing to Competitive Local Exchange Carriers

    (CLECs), as well as support for access service billing to InterExchange Carriers (IXCs) and

    retail billing for Southwestern Bell Telephone (SWBT) end-user customers.


2. I have twenty-six years experience with Southwestern Bell. I have focused on CLEC billing

    for the last two and one half years of my career.


3. The purpose of my affidavit is to show that SWBT is meeting its obligation and providing

    non-discriminatory access to billing in accordance with FCC requirements. SWBT continues

    to provide the same level of billing services, and has complemented those services with

    additional enhancements which I will explain in this affidavit. To meet its billing

    obligations under the Telecommunications Act of 1996 (Act), SWBT spent millions of

    dollars to modify and maintain its billing systems. These investments allow SWBT to

    deliver timely and accurate bills to CLECs. SWBT’s billing systems have been thoroughly

    tested under the supervision of the Texas Public Utility Commission (PUC).

4. In approving SWBT’s Texas 271 Application, the FCC found that SWBT provides non-

    discriminatory access to its billing functions in compliance with the Act.1 In particular, the

    FCC concluded that SWBT does not discriminate in its provision of wholesale bills or usage

    feeds to competing carriers. As set out below, the billing systems, processes and procedures

    evaluated by the FCC in connection with its approval of the Texas 271 application are the

 See Memorandum Opinion and Order, Application by SBC Communications, Inc., Southwestern Bell Telephone
Company, and Southwestern Bell Communications Services, Inc. d/b/a Southwestern Bell Long Distance Pursuant

    same billing systems, processes and procedures utilized by SWBT in Kansas, Oklahoma and

    throughout the five-state region. Accordingly, the FCC’s findings in Texas on billing apply

    equally to Kansas and Oklahoma. SWBT has met and continues to meet the billing-related

    271 requirements for CLECs operating in Texas while utilizing the exact same processes

    used in Kansas and Oklahoma.

                                CHECKLIST ITEM (II) – BILLING


5. SWBT uses the SWBT Customer Record Information System (CRIS) to bill its retail

    products to residential and business customers. CRIS is the same system used in Texas,

    Kansas, Oklahoma, and throughout SWBT’s five-state region. CRIS has proven to be a

    timely and accurate method of creating bills throughout its 20 years of commercial use. The

    system processes in excess of 3 billion usage records monthly and creates 12.7 million bills

    monthly that are issued to retail customers throughout SWBT’s five-state territory. The

    system has been developed to comply with all regulatory requirements and industry

    guidelines for retail billing.

6. In SWBT’s wholesale operations, CRIS is used to create timely and accurate bills for CLECs

    who are reselling SWBT products or services. CRIS is used to bill the same products and

    services to SWBT retail customers and CLECs. Resold services were first billed through

    CRIS in 1996, and CRIS has been in service for resale billing ever since. CRIS is also used

    to bill a few Unbundled Network Element (UNE)-related services, such as Interim Number

    Portability and operator-handled calls.

to Section 271 of the Telecommunications Act of 1996 to Provide In-Region, InterLATA Services in Texas, CC
Docket No. 00-65, FCC 00-238 (rel. June 30, 2000) ¶¶ 210-212 (“Texas Order”).

7. Bills issued to the CLECs from CRIS use the same processes as those used in SWBT retail

    billing. As such, CLEC billing benefits equally SWBT’s multi-million dollar investment to

    develop a highly controlled and efficient billing system. Because CRIS is the same system

    used for creating bills for SWBT retail customers, any degradation in the system for CLECs

    would be detrimental to SWBT as well.


8. SWBT uses the SWBT Customer Access Billing System (CABS) to issue bills for some

    products to business customers in its retail operations and for IXC customers in its access

    operations. CABS has been used to successfully create bills for access products and services

    in Texas, Kansas, Oklahoma and throughout SWBT’s five-state region for over 15 years.

9. In SWBT’s wholesale operations, CABS is used to create accurate and timely bills for UNEs,

    including loops, switch ports, and local transport. This would include billing monthly

    recurring charges, one-time charges, and usage-sensitive charges. CABS was modified in

    March 1999 to allow billing of usage-sensitive switch port charges in accordance with the

    FCC and Texas PUC rulings. These modifications allow SWBT to bill the CLEC properly

    for UNE switch port usage where an IXC participated in the call. This capability is in use

    today and was tested in the Texas PUC’s OSS test. See Telcordia Final Report, Section 2.2.2

10. Because CABS is the same system used for creating bills for SWBT retail business and IXC

    customers, any degradation in the system for CLECs would be detrimental to SWBT’s access

    operations as well. Therefore, SWBT has an additional incentive not to discriminate against

    a CLEC in SWBT’s provisioning of billing services.

 Telcordia Technologies, The Public Utility Commission of Texas Southwestern Bell OSS Readiness Report (Sept.
1999) (“Telcordia Final Report”); Ham Aff. Att. A (OCC filed June 9, 2000) (App. C-OK, Tab 69); Lawson Aff.
Att. A (KCC filed Mar. 16, 2000) (App. C-KS, Tab 183).


11. The Usage Extract process was developed specifically for SWBT’s CLEC customers. The

   process used in Kansas and Oklahoma is the same one used in Texas. See Texas Order

   ¶ 210. Usage Extract itemizes usage records for CLECs, which the CLEC can use to bill

   either its end-user customer or carrier customers. This process was developed to comply

   with industry guidelines, or where none exist, guidelines agreed upon by SWBT and the

   CLECs. The Usage Extract process has been in use since 1996, and over 1.89 billion CLEC

   records have been delivered successfully in that time. SWBT changes this process on an as-

   needed basis as industry guidelines are introduced or changed, or when new products or

   services are introduced in the marketplace. Usage from both CRIS and CABS is delivered to

   the CLEC via Usage Extract.

12. Usage Extract was supplemented in March 1999 to allow SWBT to provide access usage data

   to the CLEC for their billing of access charges on calls that terminate to a UNE switch port

   where an IXC participated in the call. The modifications also allow SWBT to provide the

   necessary records to the CLEC for their billing of access charges to an IXC on 800/888 calls

   that originate from a UNE switch port. This capability is in use today and was tested as part

   of the Texas carrier-to-carrier OSS test as validated by Telcordia. See the affidavit of

   Elizabeth Ham.

13. After full review of issues related to the timeliness and accuracy of SWBT’s usage data in the

   Texas 271 application, the FCC specifically found that, “the performance standards and

   measurements established by the Texas Commission and developed in conjunction with

   SWBT and competing carriers are appropriate measures of SWBT’s ability to provide

   competing carriers with usage data in substantially the same time and manner that SWBT

      provides such information to itself.”3 Based on its analysis of those measurements, the FCC

      went on to conclude that, “SWBT does not discriminate in the provision of usage feeds to

      competing carriers.”4 These findings remain true for Kansas and Oklahoma.

14. In fact, the parity standard set by the TPUC for PM 19 (requiring that 95% of usage records

      be sent within 6 work days) has been exceeded for all but one month of the current year, and

      SWBT’s results for PM 16 (requiring that 95% of usage records be transmitted correctly on

      the Daily Usage extract feed) for months of January through September 2000 have

      consistently been 100%. SWBT’s performance on these measures for Kansas and Oklahoma

      therefore meets or exceeds the performance evaluated by the FCC when it approved the

      Texas application.


15. SWBT assigns prices to products and services purchased by CLECs based on existing or new

      rating processes defined in SWBT’s interconnection agreements with CLECs. Rates

      themselves are maintained in billing rate tables which are all in the same location handled by

      the same personnel. There is no separation by state; i.e., the rate table used for Texas is the

      same one used for Kansas and Oklahoma with varying price entries according to state tariffs

      or contract specific rates. These tables contain a variety of CLEC-specific data that is

      necessary to accurately assign prices or discount percentages based on negotiated or

      arbitrated rates. When the necessary rating information is already within SWBT’s systems,

      such as when a CLEC orders service under an existing resale discount previously provided to

      another CLEC, the addition of another CLEC is routine business.

    Texas Order ¶ 211.

16. Modifications to existing rate levels or percentages are made within 30 days from the billing

   organization’s receipt of the change. In contrast, initial implementation of rates contained

   within an interconnection agreement, re-negotiation of rates in an existing agreement, or as a

   result of arbitration or regulatory rulings may require a longer period of time. This is

   because any alteration in rate structure must be accomplished through system changes that

   normally require a full development cycle of six months.

17. When SWBT is unable immediately to assign UNE prices in accordance with an

   interconnection agreement, SWBT uses existing rating routines that favor the CLEC by

   assigning prices at or below those defined in their agreement until such time as the system

   changes can be completed. When SWBT is unable to immediately assign resale prices in

   accordance with an interconnection agreement, retail rates are applied until such time as the

   correct rates or discounts are implemented. An automatic adjustment is then made to the

   CLEC resale bill to reconcile the past retail rates to those included in the interconnection

   agreement and an appropriate refund is made to the CLEC.


18. SWBT bills customers monthly for the products and services purchased. This billing

   includes monthly recurring charges, usage-sensitive charges, and one-time charges. SWBT

   divides its billing in CABS into three monthly bill dates. SWBT uses all three billing dates

   per month to bill CLECs for UNEs. This is the same number of bill dates used by SWBT for

   its retail and IXC billing through CABS.

19. SWBT has fifteen billing dates per month for resale customer accounts. This is the same

   number of bill dates SWBT uses for its retail customers billed through CRIS.

20. CLECs have a choice of bill dates in both the CRIS and CABS billing systems. SWBT

   allows the CLEC the opportunity to select bill dates based on the same rules that are used for

   other SWBT customers using the same billing systems. In the case of a conversion of an end

   user’s service from SWBT to a CLEC, the CLEC can keep the SWBT pre-conversion bill

   date if desired. The ability to maintain the bill date or choose any of the fifteen CRIS or

   three CABS bill dates provides both the resale and facility-based CLECs parity with SWBT’s

   billing to its retail and IXC customers because SWBT has offered every available bill date to

   the CLEC. CLECs have the same choice for bill dates across SWBT’s five-state region.


21. The issue of overlapping billing is always present whenever a customer changes its local

   service provider.

22. As is customary in the industry, customers of SWBT are billed in advance for monthly

   service, and are billed in arrears for usage-based services. When a customer changes local

   service providers, there is a need to reconcile the amounts previously billed and charges

   pending with payments and adjustments for the partial month of service. The only way

   overlap can be avoided is for customers to change providers only on their SWBT billing date.

   This is clearly not in the interests of the customer, CLECs, or SWBT.

23. SWBT has built the proper processes to mechanically handle the overlapping billing that

   occurs when customers change their local service provider. These processes include

   automatic credits to the customer and the issuance of revised bills that inform the customer of

   their exact account status with SWBT. These procedures, which were reviewed during the

   Texas PUC Carrier to Carrier test and found to work properly, and were examined by the

   FCC in connection with SWBT’s Texas 271 application, and found to comply with the

   requirements of the Act, are the same ones administered throughout SWBT’s entire five-state

   region to control overlapping billing. See Texas Order ¶¶ 191-192.


24. The bill cycle refers to the process of creating, auditing, and mailing a bill. The billing cycle

   starts on the billing date of each month. Customer account information that is effective as of

   the bill date and stored in the appropriate CRIS or CABS customer databases is used to

   process bills. The customer account information is established and changed through service

   order activity. By the fourth workday associated with the bill date, CRIS and CABS

   assemble all the billing records accumulated over the past month (since the last bill date) and

   create a data file with the usage, product, and service information needed to create a bill.

25. The data is then processed through a series of edits that verifies both the format and content

   of the data. Data that does not pass these program edits is distributed to error correction

   processes for investigation and correction. Corrected data is resubmitted to the system for

   processing. The billing data and account information that satisfies the program edits is used

   to create control totals and bills that can be reviewed for accuracy. The control totals are

   used for fluctuation analysis of revenues and bill volumes.

26. The bills are then audited for accuracy of both format and content. The audit of wholesale

   bills is conducted using the same process that SWBT uses on bills that it sends to its retail

   customers. The first step in that process is to develop a specific sample of actual bills that

   includes a cross-section of products, services, accounts, and geographic areas. Once

   established, the same sample is used each month with additions to the sample made as

   needed. Additional sample bills are added when a new product or service is available, or

   when some other unique condition is implemented. Second, SWBT checks the sample bills

   for format and completeness. Third, SWBT manually rates the products and services for the

   sampled accounts and then uses an independent program to mechanically validate the

   system-generated prices on a monthly basis. Once the audit is successfully completed, all

   bills for a given bill cycle are released for mailing to customers. This audit process is

   repeated throughout the month for each of the fifteen CRIS and three CABS monthly bill


27. Bills that will be printed on paper are produced in one of the SWBT Bill Print Centers.

   These centers use specialized hardware and software to print, assemble, and prepare the bills

   for mailing. These centers create and mail both the retail and wholesale bills using the same

   hardware, software, and personnel. Bills are ZIP-code sorted and then delivered to the U.S.

   Post Office for delivery to customers.

28. Bill data is handled differently if the CLEC chooses to use one of the electronic interfaces for

   obtaining billing data described in the affidavit of Elizabeth Ham.

29. For CLECs that choose to use Bill Data Tape, Usage Extract, or Electronic Data Interface

   (EDI), the billing data is formatted using the appropriate industry guidelines. For resale

   CLECs that choose to use Bill Plussm, the SWBT Data Center burns the bill data into a CD-

   ROM along with the software needed to analyze and view the data. This is the same system

   SWBT uses for its retail customers.


30. Whether through paper or electronic means, SWBT provides parity of billing timeliness.

   Bills are mailed or transmitted by the sixth workday associated with the bill date. This rule

   applies to both retail and CLEC accounts in all five SWBT states. SWBT has dedicated a

   team of personnel to track the release of each bill date and ensure the accuracy of bills

   rendered to all its customers.

31. The standard for measuring mechanized billing timeliness is contained in PM 18, and

   requires that 95 percent of such bills be released “on time,” defined as no later than midnight

   of the 6th workday. PM 18 currently covers wholesale bills processed through the CRIS

   system and supplied to competing carriers via EDI. Results on PM 18 for the months of

   January through September 2000 have consistently been at 100% in both Kansas and


32. In both the Kansas and Oklahoma state-level filings, AT&T is the only CLEC to raise the

   subject of SWBT’s billing timeliness. AT&T’s comments center on an AT&T space

   allocation issue related to its Texas bills that was ultimately resolved by a decision to receive

   their bills via tape as suggested months earlier by SWBT. This complaint is not a 271 issue

   at all, but rather, illustrates the results of SWBT’s efforts to go beyond requirements of the

   Act to accommodate AT&T’s preferences.

33. In the Texas Order, the FCC commented that “the record does not reflect that carriers,

   overall, are not receiving wholesale bills in a timely manner. We thus conclude that SWBT

   does not discriminate against competing carriers in the provision of wholesale bills.”5 Just as

   in Texas, CLECs operating in both Kansas and Oklahoma are receiving their SWBT bills in a

   timely and non-discriminatory fashion, in compliance with the requirements of the Act.


34. SWBT provides CLECs nondiscriminatory access to usage data by providing usage data on

   all the types of products and services for which SWBT provides usage data to itself (access

   usage records, intraLATA toll records, local usage records, billable messages recorded by

   other local companies). See Texas Order ¶ 211. SWBT’s current network does not have the

   capability to record usage data on resold flat rate lines and implementation is cost

   prohibitive. This capability does exist for resold lines that are purchased as measured

   service. To date, no CLEC has made a bona fide request for development of this capability

   for flat-rated resold lines. Should a CLEC make such a bona fide request in accordance with

    its contract, SWBT would provide the capability to the extent technically feasible, in

    compliance with the contractual bona fide request process and paragraph 160 of the FCC’s

    Second Louisiana Order.6


35. SWBT provides the following performance measures to demonstrate the accuracy,

    completeness, and timeliness of SWBT’s billing and Usage Extract.

   PM 14 – Billing Accuracy
   PM 15 – Percent of Accurate and Complete Formatted Mechanized Bills
   PM 16 – Percent of Usage Records Transmitted Correctly
   PM 17 – Billing Completeness
   PM 18 – Billing Timeliness (Wholesale Bill)
   PM 19 – Daily Usage Feed Timeliness
   PM 20 – Unbillable Usage

The affidavit of William R. Dysart describes the specific performance measures in detail.


36. SWBT recognizes the importance of billing in having met its obligation to open its local

    markets. SWBT has succeeded in its efforts to build a billing system that provides timely,

    accurate, complete, and nondiscriminatory billing information to CLECs, as the Texas PUC

    and Telcordia found. The billing processes in use in Texas are the same ones used in Kansas

    and Oklahoma. The wholesale billing processes and systems were built using the

    knowledge, experience, and pre-Act billing systems that SWBT has invested millions of

    dollars to develop. These systems are in use today processing billions of usage records and

    issuing millions of bills each month, on the same basis for wholesale as well as retail

 Id. ¶ 212.
 Memorandum Opinion and Order, Application of BellSouth Corporation, BellSouth Telecommunications, Inc., and
BellSouth Long Distance, Inc., for Provision of In-Region, InterLATA Services in Louisiana, 13 FCC Rcd, 20,599,
20,698-99, ¶ 160 (1998).

customers. SWBT has met its obligation of providing billing to CLECs on a non-

discriminatory basis.

This concludes my affidavit.

I declare under penalty of perjury that the foregoing is true and correct to the best of my

             Executed on ________________, 2000.

                                                  Weldon McLaughlin
                                                  Director-Billing Project Management


       Subscribed and sworn to before me
       this ______ day of _______________, 2000.

Notary Public

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