STATE FILING

21 June 1999 Mr. Jack Rose, Executive Secretary Arizona Corporation Commission 1200 West Washington Street Phoenix, AZ 85007 Re: US West Communications, Inc.’s Compliance with Section 271 of the Telecommunications Act of 1996, Docket No. U-0000-97-238, T00000A-97-0238 Dear Mr. Rose: The Telecommunications Resellers Association (“TRA”), on behalf of its members, and pursuant to the Arizona Corporation Commission’s June 8, 1999 Procedural Order in the above referenced matter, submits this letter in lieu of formal comment. TRA commends the Commission for its consideration of appropriate Operations Support Systems (“OSS”) standards to be used in evaluating US West Communications, Inc.’s (“US West”) compliance with §271 of the Telecommunications Act of 1996 (the “Act”) for in- region interLATA market entry. Establishment of OSS standards, with the input of competitive local exchange carriers (“CLECs”) who rely upon, and are most affected by, US West’s OSS, is imperative toward reaching a determination of whether US West has satisfied its Section 271 requirements, including whether US West provides nondiscriminatory OSS access to competitors. TRA agrees that a collaborative process is particularly beneficial in that regard. The Commission’s Procedural Order poses a series of questions regarding OSS standards. In response, TRA submits a recent White Paper, Evaluating OSS Availability: A Blueprint for Third Party Testing, prepared by the Competitive Telecommunications Association/ACTA (“CompTel”). CompTel’s Paper proposes an effective framework for OSS standards and evaluation development, based in part on the practical experience gained from third party testing plans in California and New York. CompTel proposes adoption of guiding principals to be considered in the development of any OSS standards and evaluation. They include: 1. Agreement the incumbent’s OSS obligations 2. Evaluation of the practical ability of OSS to process and support commercial volumes of competitively-provided local services 3. Evaluation of the entire OSS process beginning at the point where competitors design systems interfaces 4. Evaluation across a full range of entry options which recognizes the diversity between competitive local exchange carriers and their capabilities 5. Evaluation of OSS capabilities to test incorrect orders 6. Evaluation of the ability to test data service as well as voice service orders 7. Evaluation of OSS effectiveness over a reasonable period of time TRA urges the Commission to adopt OSS standards and evaluation metrics, consistent with the considerations proposed by CompTel, to ensure a complete and accurate determination of US West’s compliance with the Act. Sincerely, Telecommunications Resellers Association Andrew O. Isar