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Open Product/Process CR 5263671 Detail

Description Of Change

Unbundled Loops can only be established on copper or Universal Digital Loop Carrier (UDLC). Integrated Digital Loop Carrier (IDLC) cannot be used for an Unbundled Loop service at this time. Qwest has chosen not to unbundle IDLC because of the expense of providing equipment to "groom" the DS0 lines. During the Unbundled Loop facility assignment, an attempt will be made to Line and Station Transfer (LST) the IDLC loop to UDLC or copper. If there are no facilities available to complete the LST, the Co-Provider will be notified that the order has been placed into a held status. (Emphasis added.)

The FCC has said that "[t]he BOC must provide competitors with access to unbundled loops regardless of whether the BOC uses [IDLC] technology . . ." (BellSouth Second Louisiana 271 Order, 187 and SBC Texas 271 Order, 248.) The processes outlined in Qwest’s IRRG are not consistent with this requirement. In some cases, Qwest does not identify that IDLC is being used until the day of cut. When the discovery is made, Qwest may not dispatch a technician. Instead, Qwest delays the order or places it in held status. Qwest does so for all lines, even though facilities may be available for some of the lines. Please modify Qwest’s processes to be consistent with the FCC’s order. Also, please modify Qwest’s processes to identify earlier (before the day of cut) that IDLC is being used. If use of IDLC is not identified until the day of cut, ensure that a technician is available to resolve the issue that day (rather than delaying the order). If Qwest indicates that it does not have facilities for all lines, change Qwest’s processes so that the lines for which facilities are available may be installed (when the line configuration supports

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