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Handbook for California and Nevada

Bonafide Request Process (BFR/INER)

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Bona Fide Request Process (BFR/INER)

Bona Fide Request Process (BFR/INER)
Standard Forms
Notification to CLECs
Generic Appendices
Request Process
Description of BFR Costs
BFR Escalation Process

Bona Fide Request Process (BFR/INER)
A Bona Fide Request (BFR), previously referred to as the INER process, is a process that a CLEC utilizes to request Unbundled Network Elements (UNE), Interconnection Arrangements or Other Arrangements which do not currently exist in the CLEC’s Interconnection Agreement or have not been previously defined in the generic appendices (Appendix UNE, Appendix NIM or other appropriate appendix).

The BFR process should not be utilized where a process already exists. Examples of existing processes where the BFR is not applicable are, but not limited to:

  • Collocation
  • OSS activity (including requests for changes in the fields on OSS forms)
  • Resale Services

Standard Forms
The BFR process utilizes standard forms to ensure the consistency of communication between Pacific Bell and the CLEC. The following standard forms can be found in the Forms, BFR/INER Application Forms section.
    For copies of the BFR forms, please see the Bonafide Request Process (BFR) Forms section.

    Notification to CLECs
    The Accessible Letter will be used to communicate with the CLECs. Accessible Letters will provide the CLEC with a 30 day prior notification of any changes to the process. Accessible Letters will be issued to announce new products as they become available.

    Generic Appendices
    Generic appendices include a description of the UNEs, Interconnection Arrangements and other arrangements that Pacific Bell offers. If a requested BFR is accepted by the CLEC and Pacific decides that it has general applicability, it will be added to the appropriate generic appendix. Additionally, new products are added to the generic appendices through normal product development based on market demand. The available rates for the products are found in the pricing appendix. CLECs do not have to file a BFR application for items found in these appendices. However, for a CLEC to obtain an item found in the generic appendix, the appropriate generic appendix, or individual UNE contract amendment, will need to be negotiated into the existing interconnection agreement.

    The generic appendices will continually be updated as new UNEs, interconnection arrangements or other arrangements become generally available. Contact your Account Manager for additional information on the Generic Appendices and Pricing Appendix.

    Request Process
    The request for an unbundled element, interconnection arrangement or other arrangement that is not defined in the CLEC's Interconnection Agreement, or Generic Appendices, must be made in writing using the BFR Application to the CLEC's Account Manager.

    To request a copy of the BFR application, refer to the Bonafide Request Process (BFR) Forms section

    The letter must provide the following information:

      • Technical description of each requested Network Element or Interconnection arrangement.
      • Where the interconnection is to take place (street address or end office CLLI [Common Language Location Identification])
      • A statement that the Interconnection for telephone exchange service and exchange access or Network Element will be utilized to provide a telecommunications service
      • Date when the interconnection is requested
      • A description of how the requested item will be utilized
      • Projected quantity of interconnection points with a demand forecast
      • Desired Interconnection/UNE specifications

    A request to construct facilities must be made in writing to the CLEC's Account Manager including the following information:

      • Address where the construction of facilities is required (street address and end office CLLI)
      • Date when the service is requested
      • Whether or not expedite charges are authorized
      • Demand forecast if available

    PB promptly considers and analyzes each new BFR request it receives from a CLEC. Within ten (10) business days of its receipt , PB acknowledges receipt of the BFR and in such acknowledgment, advises the CLEC of any missing information needed to process the request Thereafter, PB promptly advises the CLEC of the need for any additional information that will facilitate the analysis of the BFR. Timeline intervals begin once PB is certain that it has a BFR application with sufficient information to allow it to make a determination regarding feasibility.

      BFR Denial ('no' response)
      Within fifteen (15) calendar days of PB receipt of the complete and accurate BFR, PB will notify the CLEC if the request is denied. The reason for denial will accompany the notification. Reasons for denial could include, but not limited to: BFR is not technically feasible, BFR is the inappropriate process for the request and there is a referral to the appropriate process, or that the BFR does not qualify as an Unbundled Network Element or Interconnection Arrangement that is required by law.

      PB may refer the CLEC to an alternate process if it is determined that the BFR is not the correct process. If a referral is made PB will provide the details on the provision of the alternate process within the same 15 calendar days as the original BFR request. The details may include an application form for the alternate process, the interval to process the request and other documentation that may be required to submit the application for the alternate process.

      Acceptance of the BFR ('yes' response)
      If PB determines to proceed with the BFR (also known as a 'yes' response), PB will notify the CLEC in writing within thirty (30) calendar days of receipt of the request. The 'yes' response will include a Preliminary Analysis. (an estimate of the final charges) The Preliminary Analysis will include cost categories (material, labor, and other) and high level costs for new UNEs, interconnection arrangements, and other arrangements not previously defined. If Pacific is able to provide a 'yes' response in a shorter time frame it will do so. However, an early 'yes' response will not include costs. Costs will be sent by the 30th calendar day (or 24 days after the 30th day if Wholesale Construction is required).

      A Preliminary Analysis provides an estimate of the high level cost categories and costs to be used by a CLEC for determining whether to proceed with detailed product development. PB will continue with the BFR Final Quote development upon written notification from the CLEC. The BFR Final Quote is the actual costs that require no additional review or development by PB. If a Preliminary Analysis is provided the Final BFR quote will be provided as soon as reasonably possible (but no more than 90 calendar days after written authorization from the CLEC to proceed with the BFR Final Quote).

      A Preliminary Analysis includes the following:

        • An estimate of costs in High-Level cost categories.
        • An estimate of cost to develop the BFR Final Quote (for Type 1 Cost)
        • An estimate of the interval to provide service.
        • An estimate of the Terms and Conditions that will surround the BFR Final Quote.

      The BFR Final Quote includes the following:

        • BFR Final Quote of costs in high-level cost categories.
        • BFR Final Quote of cost to develop the BFR Final Quote (for Type 1 Cost)
        • The interval to provide service.
        • The Terms and Conditions surrounding the BFR.

      If Wholesale Construction is required, high-level cost support will be provided in an additional 24 calendar days after the 'yes' response. Wholesale Construction is a process that is utilized if construction of facilities is required.

    Description of BFR Costs
    The following sections describe different kinds of costs for BFR.

    Brief Description of Type 1 and Type 2 Costs
    There are two kinds of costs:

      • Type 1 Costs include BFR development costs, recurring costs, and nonrecurring costs. Costs of this type are used predominately when demand does not cover the development costs.
      • Type 2 Costs include recurring costs and nonrecurring costs of the BFR.

    The choice between applying Type 1 Costs or Type 2 Costs is made at the sole discretion of PB.

      Type 1 BFR Costs
      If PB used Type 1 Costs in its Final BFR Quote, the CLEC must do one of the following:

        • Agree to pay the development costs of the Interconnection Arrangement, Other Arrangement or Unbundled Network Element , or
        • Cancel its BFR

      If PB used Type 1 Costs in its Final BFR Quote and the CLEC agrees to pay the development costs and requests PB to proceed:

        • PB additionally charges those development costs on a prorated basis to the next nine parties who place an initial order..
        • As each additional party places its initial order for the BFR, PB refunds the appropriate prorated portion of the development costs to parties who have previously paid development costs.

      The charges and refunds are made using the proration chart set forth in the 'Proration Chart For Type 1 BFR Project Costs' below except that the period of proration for charges and refunds shall be 36 months from when PB first makes the BFR available.

      Proration Chart for Type 1 BFR Project Costs
      RequesterDevelopment CostsCumulative RefundRefunded to
      2nd50%50%1st Part
      3rd33.33%16.67%1st & 2nd parties
      4th25.00%8.33%1st - 3rd parties
      5th20.00%5.00%1st - 4th parties
      6th16.67%3.33%1st - 5th parties
      7th14.29%2.38%1st - 6th parties
      8th12.50%1.79%1st -7th parties
      9th11.11%1.39%1st - 8th parties
      10th10.00%1.11%1st - 9th parties
      11th and beyond00.0%

      Type 2 BFR Costs
      If SWBT/PB/NB used Type 2 costs in its BFR Quote, the CLEC must do one of the following:

        • Indicate its nonbinding interest in purchasing the INER at the stated quantities and rates,
        • Cancel its BFR
        • Unless otherwise stated, all dates in the BFR process and BFR Escalation Process are calendar days.

    BFR Escalation Process
    The purpose of the BFR Escalation Process is to provide our customers with clear and concise information regarding a process for escalations within the BFR interval.

    To initiate the process the customer should contact their Account Manager. The Account Manager is responsible for investigating the request by contacting key personnel and setting up a meeting, if required. The Account Manager will provide the customer with periodic status reports at time frames specified by the customer.

    The BFR Escalation Process provides specific time intervals for escalating to the next higher level of management if the request has not been resolved to the customer’s satisfaction.

    The following provides the flow of events for the Escalation Process with defined days to escalate to the next level:

    The customer initiates the BFR Escalation Process by contacting the Account Manager.

    The Account Manager investigates the request by contacting key personnel and/or setting up a meeting, if required.

    The Account Manager escalates to the Director if not resolved.

    The Director escalates to the Executive Director if not resolved.

    The Executive Director escalates to the Vice President if not resolved.

    If the request is not resolved PB or the customer may initiate Dispute Resolution Process.