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Open Product/Process CR 5608156 Detail

Description Of Change

Project Meetings

Kate, Here is Gerry's reply. Gerry is director of our switch operations. Please send this on to whoever needs to see it. Thanks Kathy Stichter ILEC Relations Manager Eschelon Telecom Inc Voice 612 436-6022 E-Mail klstichter@eschelon.com Kathy: When we assign a APOT/CFA we hard wire directly to the ICDF from our UE9000's. By having the APOT's in numerical sequence it allows for our LENS and the PM Terminal/Node Number(which is the APOT/CFA) to match up one to one. Example ...If I have an APOT of PST05 pair 12 for the Orchard CO it matches directly to LEN ORCH 0 00 1 12. By reusing the same numbering, i.e. ALT02 1-300 and PST05 1-300 the PM Terminal/Node Number will not match up with the LEN assignment. Thanks Gerry P.S. I can print out examples at a later date. Gerry

CenturyLink Response

Dear Ms. Powers:

I conducted a conference call with Eschelon on August 6th, 2001 at which time Qwest reviewed and responded to the letter written by myself, dated July 13, 2001. Eschelon clarified their request as, “Can they have sequential DS0 cable counts when they submit an augment for additional 100 DS0 cables.” They do not want 2 different naming conventions that have the same numbering system. Eschelon wants each new cable name to have its own associated cable counts.

According to Gerry Boeke from Eschelon, when they assign an APOT/CFA, they hard wire directly to the ICDF from their UE9000's. By having the APOT's in numerical sequence it allows for their LENS and the PM Terminal/Node Number, which is the APOT/CFA, to match up one to one (i.e...If you have an APOT of PST05 pair 12 for the Orchard CO it matches directly to LEN ORCH 0 00 1 12). By reusing the same numbering (i.e. ALT02 1-300 and PST05 1-300), the PM Terminal/Node Number will not match up with the LEN assignment.

Qwest does not believe it is a realistic expectation that cable counts always match exactly with LENS and Cable Counts. It will not and does not need to do so. Although administration would be easier for Eschelon, this is not practical on the part of Qwest. Existing working circuits are currently operating with different cable counts.

I have worked with John Waltrip, IOF EPOC methods manager, regarding this clarification. John’s response is as follows: “This issue is a scenario where a CLEC places an augment order to supplement facilities already in a given Central Office. The original facilities may have been built based on a cable naming convention that is now superseded (e.g. an original DS0 cable may have been called/counted as ALT02, 1-300); the new convention would carry a name like PDT05, 1-400 (for an additional 400 - or a total of 700). As a result, his response was that our practice is to not attempt a continuous count of old to new cable names for the same comparable circuit, (e.g. establishing the PDT05 with a count of 301-700) for the following reasons:

Our system has been in place for over a year and changes would mess-up live circuits. All CLECs are using this same system, so they rely on it as well. Other interfaces rely on this such as TIRKS, LFACS, etc. Sequence number is not critical when they place orders. The 1-300 gap in the PDT05 cable becomes an administrative fail point, not knowing that a PDT05, 1-300 count does not exist would cause the types of data base administration, as well as engineering and Service Delivery, problems that we have been cleaning up for the past 2 years. It is also possible that different types of DS0 cables go to different types of frame locations like line sharing. Different databases are also involved like LFACS for line sharing. If a customer has DS1 service it could be a UNE or Finished Service and can be configured with or without regeneration, all of these are now uniquely identified through our new naming convention. This in turn is desired to eliminate potential wiring errors and customer effecting trouble. Future mergers and acquisitions are causing conflicting databases also. The current new naming convention addresses and eliminates this problem. When two CLECs merge, each will have different cable counts. The TIRKS data base is universal in nature and tracks and monitors all circuits.

In summary, we acknowledge the needed additional work on behalf of individual CLECs to ensure accurate CFA is submitted on provisioning orders. We also acknowledge Qwest is committed to furnishing accurate information and timely resolution of issues as they occur in the provisioning and maintenance process relating to APOT information. For all the above mentioned reasons, we respectfully deny your request.

Sincerely

Stephen C. Nelson Collocation Group Product Manager

July 13, 2001

Ms. Lynne Powers Vice President, Eschelon Telecom

Dear Ms. Powers:

This letter is in response to your CLEC Change Request form number 5608156 dated June 13, 2001.

“Please provide a process and procedures for consistent APOT numbering. Qwest apparently uses different central offices (CO’s) for numbering APOT’s. This leads to problems when, for example, a typist at Qwest copies and pastes information for one CO and uses it for another. Also, there appears to be a discrepancy between physical number and the information reflected in TIRKS. To the extent that inconsistencies exist today, please develop and distribute a process for correcting those inconsistencies. The inconsistencies create serious problems for CLEC’s. For example: In one situation, the augment was labeled at the ICDF as starting with number1. But, the collocation term sheets and IMA (TIRKS) indicated that the augmented APOT starts at a higher number. Therefore, pending orders could not be completed to the APOT on which they were ordered.” Response: Our cable naming convention has undergone evolution over the last six years. When cable names were first assigned to the CLEC cables, the same cable names, e.g. ALT01, were often assigned to multiple CLEC’s. Despite that convention, their corresponding circuits could still be built and turned up since the unique cables were built in TIRKS with the CLEC’s unique CLLI code, e.g. HG5. CLLI codes are assigned by CLONES in order as CLEC’s come into an office, e.g. if a CLEC is the first physical in office A they would typically be assigned HG1, if they were the 8th CLEC they would be assigned HG8., etc. The current naming convention does assign unique cable names to CLEC cables in a given office. The unique name is established based on factors such as the type of collocation, type of circuit, and the 11 character of the unique CLLI codes assigned to the CLEC. (Attachment A is our current Cable Naming Convention) Cable names assigned using the old convention are not incorrect. They are simply not as descriptive as the current naming convention. Qwest explored the cost of converting the millions of cable names over to the new convention in place currently. The estimated cost was in the millions of dollars. Word documents would have to be cut along with new APOT’s etc. Therefore the decision was made to do several things on a going forward basis. One, through attrition the old cable names over time as changes occurred. Two, we would formalize our methods and train all personnel on the new cable naming configuration. Three, we would establish a “Hot Line” for CLEC’s to resolve immediate discrepancies through their Account Representative. Fourth, we would do a major data base reconciliation of all major cities. Fifth, each augment of a site would require a new APOT in its entirely including existing cable names. Qwest has a process for handling discrepancies in provisioning or repair traced to APOT forms. We have established an interval Hot Line to ensure items referred by CLEC customers to their Account Service Manager are responded to within 5 hours by an engineer for resolution. The engineer will identify and work to eliminate and resolve the issue. The engineer will report back to the account representative within 24 hours on the resolution or estimated resolution of the problem. All of these action items have associated methods and procedures which Qwest employees have been trained on. Attachment C and D of the Configuration Options Policy in the PCAT identifies our cable naming convention and samples of APOT’s by type of collocation. (I have attached sample copies of APOT’s )

In summary, although it is more difficult for Qwest and CLEC’s to administer cable names based on the different naming configurations, we do not plan to “convert” all past APOT’s. All existing APOT’s have correct information for submittal or provisioning and repair requests. The Hot Line will assist where discrepancies occur. Our methods have been standardized. We will work with any specific CLEC to resolve any items of concern regarding particular CLEC site APOT’s through your Service Manager.

Sincerely Stephen C. Nelson Collocation Group Product Manager