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Open Product/Process CR PC011502-1 Detail

Description Of Change

Additional Information: Covad has experienced a significant number of cable augments with electrical faults, requiring a technician dispatch to the central office.

Project Meetings

06/18/03 June CMP Meeting Minutes Steve Nelson – Qwest reported the Dry Creek test is still pending. Qwest and Covad completed the test in Washington. They tested 200 cables, all were good, and we found 2 splitter card problems that we resolved. The joint test took 1 hour to do the test, and 1-hour travel time each way. Qwest will reduce the interval to 1 hour. Mike Zulevic-Covad advised we need to work on sharing and recording test results. Covad requested to leave in CLEC Test one more month.

05/21/03 May CMP Meeting Minutes Steve Nelson – Qwest reported he is monitoring two RFS; one for Covad and one for Cyber Mesa. There is a call scheduled today which will set up the time for the Joint Test to occur. Steve and Mike will try to attend the Joint test. Steve will advise Cindy Macy when the joint test is scheduled and completed. This CR will remain in CLEC Test.

04/16/03 April CMP Meeting PC011502-1: Joint Testing of Qwest Installed Transmission Cables

Steve Nelson – Qwest reported a total of 13 joint test results have been submitted and are pending from 3 different CLECs. None are completed as of yet so we are unable to report on the test results until they go through that phase. These requests came in with Augment orders. Steve advised Qwest will be updating the document to include improvements on the process. Steve is working with the CPMC and will get the RFS dates and call Mike Zulevic. Mike advised he would like to keep this CR open until an order has gone through the entire process. This CR will remain in CLEC Test status.

03/19/03 March CMP Meeting Steve Nelson – Qwest reported Covad has issued orders and Qwest is waiting for Covad to accept the quote. After Covad accepts the quote Steve Nelson will monitor the process to make sure the joint test goes okay. Mike Zulevic agreed to check and see why Covad has not accepted the quote as of yet. Steve Nelson agreed to call Mike with BAN numbers.

02/19/03 Steve Nelson-Qwest and Mike Zulevic-Covad advised they have updated the Interconnection Agreement and Covad has placed augment orders. We are now waiting for the orders to go through the entire process which normally has a 45-60 day interval to complete. After the orders go through the entire process we will determine a close date.

01/15/03 January CMP Meeting

White-Qwest described the CR. Zulevic-Covad stated that Qwest and Covad were in the process of amending Covad’s interconnection agreement and that when that was complete Covad would begin placing orders. This CR remains in CLEC Test.

12/18/02 December CMP Monthly Meeting Minutes Qwest - Nelson advised the PCAT was published and no comments were received. Nelson reported he is working with Covad to clarify how to order the product. Section M of the Collocation Order Form and the Joint Testing at ICDF Form is used for ordering. Covad advised an amendment to their Interconnect Agreement will be issued to modify the increments. The team agreed another CR would need to be issued and handled as a Level 2. This CR will be left in CLEC Test until an order is placed for the product or until the team determines otherwise.

11/20/02 November CMP Monthly Meeting Minutes Qwest (Steve Nelson) reported the PCAT was updated and posted for review with the comment cycle ending 11-21. It was agred to move this CR to CLEC Test.

10/18/02 October CMP Monthly Meeting Minutes Qwest reported the process document for the Test Access Points is under review and anticipated to be available for review effective October 18, 2002. The Qwest documentation review team surfaced an issue after the CMP meeting that is currently under investigation. This issue will impact the October 18 availability date. The document will remain in review and this project will remain in Development status.

09/18/02 September CMP Monthly Meeting Minutes

Qwest advised that documentation on the Joint Test Process should be published by the end of next week. Comments from the last collaborative review meeting are being incorporated into the document and the Collo Application form is being updated. The CR will remain in Development

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08/21/02 August CMP Monthly Meeting Minutes

Qwest provided a status update on issuance of the Initial Notification. They indicated that the process with being revised to incorporate the CLECs request to have Qwest contact the CLEC to notify when they are ready and that there would be no additional QPF. Covad advised that they had a conversation with the Collocation Product Manager and he provided the same update.

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07/17/02 - July CMP Meeting Minutes: Qwest stated a meeting was held July 11, 2002 to discuss the proposed product offering. Qwest stated another meeting is planned for the first week of August with the CLECs to discuss proposed resolutions to the questions raised during the July 11 meeting. Qwest will issue a notice to the CLEC community containing proposed dates for the meeting.

CLEC conference call held to review the ICDF Joint Testing product offering and the Test Access Points document

10:00 a.m. (CST) / Thursday, July 11, 2002 Conference Call TEL: 877.521.8687 CODE: 5699655 PC011502-1 Joint testing of Qwest installed transmission cables

Attendees Brent Debrock Cbeyond Communications Al Villiam Allegiance Steve Marks Allegiance David Stauter Allegiance Mike Zoulvik Covad Beckey Neesen Covad Byron Dowing Alltel Laurel Burke Qwest Jerry Bocke Eschelon Lana Messenger FreeTel Communication Mike Keegan Qwest Benjamin Campbell Qwest Johnathan Spangler AT&T

Introduction of the participants on the Conference Call was made. Qwest explained that the purpose of the call was to review the IDCF Joint Testing product offering and the Test Access Points document.

Qwest discussed the new process offering of Joint Testing, and the Test Access Points Document. The CLEC community expressed that they want: 1) Qwest to take an active role in the test process during Joint Test 2) CLECs do not want to pay for the Joint Test if there are errors found in the Qwest installed Cable.

Qwest stated it would explore these two requests to see if they can be incorporated into the new product offering. Based upon this new feedback, Qwest will delay delivery of the Joint Test Process until resolution on these additions have been resolved. Qwest stated that it would set up another meeting to review the Joint Test Process once a decision is made on their request.

Qwest asked Eschelon if the Test Access Points Document provided the detail requested by Eschelon at the June 19, 2002 CMP meeting (reference Action Item AI041702-1 "Prepare high level documented process of what CLECs are allowed to do in Qwest Central Offices". Eschelon replied the document has not yet been reviewed.

CLEC Change Request Clarification Meeting

12:30 p.m. (MDT) / Wednesday 23 January 2002 Conference Call TEL: 877.554.8688 CODE: 3269208 PC011502-1 “Joint Testing of Qwest Installed Transmission Cables”

Attendees: Michael Zulevic, Covad Jeffery B. Cook, Qwest Richard Martin, Qwest Peter Wirth, Qwest

Introduction of Attendees Introduction of the participants on the Conference Call were made and the purpose of the call discussed

Review Requested (Description of) Change Mike indicated that he recognized that at the time the tie cables are placed, they do not do an actual test when the tie cables are terminated to the equipment. They were looking to be able to do continuity tests, etc before they terminated to the equipment and wanted a period of time for them to do their test and acceptance. Jeff asked why Covad wanted to test DS1 & 3 cables. Mike advised that they wanted to ensure that installation was correct. It was agreed that Covad didn’t want to limit the scope to the cables at the colo splitter arrangement and wanted to cover actual installation(s) at their colo location. Mike confirmed that they were looking for a formal test and turnover process and wanted an acceptance period after actual installation of the facility took place. This would be a joint testing process. Mike indicated that he would be willing to have discussion on the interval time of 60 days. Covad is limited to the number of techs that cover various states and a reasonable time would be required for their techs to get from place to place.

Confirm Areas & Products Impacted It was confirmed that Covad would like any products covered to be included in the process. . Confirm Right Personnel Involved Jeff indicated that Laurel Burke would probably take ownership of the CR and he would help facilitate.

Identify/Confirm CLEC’s Expectation It was confirmed that Covad is looking for a process for Test and Turnover of facility installations to their collocations.

Identify any Dependent Systems Change Requests There is no corresponding System CR

Establish Action Plan (Resolution Time Frame) Ric advised that the CR would be clarified with the CLEC Community at the next CMP Meeting and Qwest will verbally present potential solutions.

CenturyLink Response

Michael Zulevic Director Technical Regulatory Support Covad Communications

SUBJECT: Qwest’s Change Request Response - CR # PC011502-1 Joint Testing of Qwest Installed Transmission Cables

This letter is in response to your Change Request PC011502-1 requesting a formal test and turn up process and an acceptance period after the collocation installation work completes – after Ready For Service (RFS). Covad envisions this process as joint testing at no additional cost to take place within 60 days of the RFS that allows for scheduling of their technicians.

Qwest is committed to providing quality facilities installations by the RFS date and Qwest’s warranty obligations will be enforced. Qwest installation forces perform continuity testing where appropriate when the collocation is turned over to Covad for acceptance. We perform quality audits on a random basis to check the quality of our work on the collocation CLEC cable installations. Streaker tests are performed on Line Sharing installations.

Recent results of Qwest internal quality audits have identified the following as it relates to the line sharing installations performed as a project in the summer of 2000: ? Of 249 jobs checked, 25.7% had some percentage of defects. ? One way to describe it is in # of pairs provisioned - (1 pair/job w/problem) x (25.7% of jobs w/connection problems)/300 pairs/job = 0.086% of all terminations wired had problems open/cross/reversal problems. ? This type of error is not common, but not unheard of in Telecommunications Installation. ? 7 jobs (3%) had the cards not seated in the splitter. Normally, Central Office Equipment installation hands off cards to the CO Operations for final test/turn-up. Line Sharing differed from this ingrained work-norm, and thus resulted in 2% of those jobs exhibiting this problem. ? 3 (1%) of the jobs had items that were found to be attributed to CLEC-issues (e.g. telling Qwest to cannibalize circuits that already had jumpers run for CLEC-customers, and 1 item that was traced back to the Customer Premise - end user equipment). ? 5 jobs had a combination of the above issues.

Given the newness of the product and associated processes and technologies, this project proved more challenging than any standard collocation build. Thus, the quality of those standard builds are even better than the Line Sharing results.

After the facility installation has been turned-over and the CLEC has had the opportunity to terminate their bulk end of the cable, full testing of the terminations between their collocation space and the vertical side of the ICDF can be done by the CLEC. In the case that these CLEC test indicate Qwest-defects, Qwest is willing to revisit the site and resolve any such defects for no additional charge should they exceed a 2% threshold. The attached diagram captures the existing test points as they are defined today in the Unbundled Loop process and collocation test access.

The piece of cable between the CLEC’s collocation space and the vertical side of the ICDF (commonly referred to as CLEC cabling) is the responsibility of CLEC and is paid for by the CLEC, as part of the collocation build out. With that stated, the CLEC is responsible for the testing, maintenance and subsequent repair if they were to find trouble in this cable “piece” after any acceptance or continuity test on their part requiring Qwest installation revisit initially.

Qwest evaluated the possibility of having a coordinated Joint Test on a regularly scheduled basis, but determined quality results indicate it would not be productive to do so and would indeed be costly. Nevertheless, we are willing to Joint Test should a CLEC still feel the need for such a service and agree to do so under our Special Request process and price the service accordingly.

We are committed to define the Joint Test process over the next few months.

Sincerely,

Steve Nelson Group Product Manager-Collocation

Cc: Laurel Burke Mary Retka William Campbell

(See end of this CR Detail Report for Attachment)