Wholesale: Products & Services

Open Product/Process CR PC011516-1 Detail

Description Of Change

CenturyLink is updating Technical Publication 77350, Telecommunications Equipment Installation Guidelines that includes a requirement for CLECs and all CenturyLink-approved Inside Plant (ISP) Service Suppliers to meet certain competency levels 1-4 for authorization to perform central office-based installation /removal services within CenturyLink Local Network Facilities. This new Business Procedure will specify the process and timeline for CLEC representatives to obtain a successful competency certification to the CenturyLink Central Office Engineering/Installation/Technical Standards Policy. Competency certification will be obtained for Service Suppliers by accessing the following link and determining individually which level of certification is needed based on Scope of Work and subcontracted necessity: http://www.centurylink-supplier-certification.com/.

Project Meetings

Kim Isaacs - Electric Lightwave said if CenturyLink moves the CR to a Completed status, it would be over their objections. Kim said Electric Lightwave has objected to the legal terms that CenturyLink has added to the Badge Access Request web site. Kim said they are continuing to ask CenturyLink to remove the terms or make a modification to them.

Mark Coyne – CenturyLink said that the CenturyLink has made note of the concerns that Electric Lightwave has expressed. Mark said he thinks we are at the point of agreeing to disagree.

Kim Isaacs - Electric Lightwave said her concern is that the legal language added to the Badge Access Request web site does not appear to provide any benefit to CenturyLink and the change in wording is requiring Electric Lightwave to change their process so that they have someone that can respond to the legal aspect of the badge process. Kim said with the ICAs and the Tech Pub, what benefit does this wording provide CenturyLink.

Mark Coyne – CenturyLink said we have captured the Electric Lightwave objections in the minutes. In checking with the CenturyLink legal team, not all of the ICAs have the specific wording to protect the shared facility space so this additional language is necessary. Mark said the terms protect not just CenturyLink but all customers. CenturyLink has always been in agreement that the terms of the ICA supercede the PCATs. Mark said we will capture this exchange in the minutes and move the CR to a Completed status.

Armando Fimbres – Oregon PUC asked what are the consequences of the additional language.

Mark Coyne – CenturyLink said if a dispute were to arise, CenturyLink would fall back on the terms of the agreement.

Kim Isaacs - Electric Lightwave said this change is being implemented over their objection and that they reserve the right to reopen this if the process becomes a problem. Kim said she is not sure how CenturyLink will implement this.

Mark Coyne – CenturyLink said we will leave it up to our Legal team.

7/20/16 Product/Process CMP Meeting PC042915-1 Technical Publication 77350, CenturyLink, Telecommunications Equipment Installation Guidelines PC011516-1 CLEC/CLEC Subcontractor Inside Plant (ISP) Competency Requirements and Testing on Technical Standards associated with CenturyLink Telecommunications Equipment Installation Guidelines (Tech Pub 77350) Mark Coyne – CenturyLink said he would provide an update on these two CRs at the same time. Both CRs are in CLEC Test as of July 1, 2016. Mark said a Level 3 notice was sent on July 6, 2016 to implement a further change to the CLEC Badge Access Request web site and the CLEC Badge Access Request Job Aid to include a wording update about the Badge acknowledgement process; the wording had originally been included as part of the final notice for these two CRs that was distributed on June 16, 2016. Mark said CenturyLink received a postponement request from Integra to delay implementation of the additional wording changes. Due to the postponement request, CenturyLink retracted that update and resent the redlined language as a Level 3 change on July 6, 2016 with an effective date of August 19, 2016. Mark said the specific information about the postponement request is available as Postponement #3 on the CMP Oversight Committee & Escalation/Dispute Information website at http://www.centurylink.com/wholesale/cmp/escdisp.html under Postponement Archive.

Kim Isaacs – Integra said she submitted comments on the Level 3 change that states Integra objects to the added language in the Badge Access tool. Kim said the process is covered by their ICA and has similar terms governing collocation access. (7-29-16 Updates received from Integra in CAPS) CENTURYLINK ALLOWS ONLY [delete WITH] one point of contact (POC) for each company [delete ALLOWED], that POC is an administrator and is not the right person to acknowledge the process for each badge holder or for their company.

Mark Coyne – CenturyLink said CenturyLink will review the Integra comments with our legal and SME team.

Kim Isaacs – Integra said her concern is that CenturyLink is (7-29-16 Updates received from Integra in CAPS) TRYING TO USE [delete USING] this same badge access site for CLECs and [delete THEIR SUB-CONTRACTORS] CENTURYLINK’S CONTRACTORS and those CenturyLink relationships are different. Kim said she thinks the badge acknowledgement language is redundant since the CLEC has an ICA but said she can understand the language being necessary when there is not an ICA.

Mark Coyne – CenturyLink said it might be that CenturyLink needs to include additional language like “unless otherwise specified within the ICA”.

Liz Tierney – Global Capacity said that she thinks adding requirements at the Collocation Access site is not needed. Liz said the ICA is explicit regarding access and that we need to remove barriers. Mark Coyne – CenturyLink said we will consider the comments and provide the CenturyLink response with the Final notice due August 4, 2016. Mark asked if there were questions. There were none.

6/15/16 Product/Process CMP Meeting Mark Coyne – CenturyLink said he would provide an update on this CR and CR PC011516-1at the same time since they are related. He said there were several notifications that were distributed associated with these changes: two level 4 notices and one Level 3. The initial notices were sent on May 25, 2016 that included a formal comment cycle that ended June 9. CenturyLink did receive customer comments. The final notices and response to comments are due on June 16, 2016. The changes will become effective on July 1, 2016. The CRs will then be moved to CLEC Test and will be reviewed in the July CMP meeting. Mark asked if there were questions. There were none.

5/18/16 Product/Process CMP Meeting Mark Coyne – CenturyLink reminded callers that this CR is tied to the Tech Pub 77350 CR and was also reviewed on the Ad Hoc call on May 2, 2016. Mark said Jeff Bostow – CR provided a high level review of the proposed Competency Test process which includes a new Business Procedure which was created by the SME team. This CR also requires additional revisions to the Collocation Badging Process to tie it to the Competency certification. On a side note, Mark relayed that the Collocation Badging Process rewrite of the website and the CenturyLink Premises Access Overview Business Procedure Version 8 became effective today, May 18, 2016. Mark said the planned timeline for the Competency Test is the same as the Tech Pub 77350 which has the July 1, 2016 effective date. Mark asked if there were any questions. There were none.

05/02/16 CMP Ad Hoc Meeting Attendees: Brendan Hamel – Granite Kim Isaacs – Integra Laurie Roberson – Integra Jeff Bostow – CenturyLink Rita Urevig – CenturyLink Mark Coyne – CenturyLink John Hansen – CenturyLink Susan Lorence – CenturyLink

Susan Lorence – CenturyLink went over an agenda for the meeting and then a brief history of the two CRs, PC042915-1 and PC011516-1. Susan said that during the meeting, she would like to take down specific Action Items that need to be resolved versus capturing detailed discussion of the examples that may be included in the Tech Pub.

CR PC042915-1 Technical Publication 77350 Jeff Bostow – CenturyLink then reviewed the CenturyLink proposed Tech Pub 77350 language dated April 28, 2016 that is posted to the CMP calendar entry for the meeting. The wording updates are associated with the CenturyLink response to questions posed during the CMP monthly meeting on April 20, 2016. Jeff spoke to Section 2.1.2 of the Tech Pub and said there are two types of Methods of Procedure (MOP) – General and specific. The MOP is required for CenturyLink and their subcontractors due to PUC requirements in case there is a service interruption; it shows the scope of the work and who is performing it. A MOP is not required if a CLEC is working solely within their space – caged or cageless. Jeff said the wording updates to Section 2.1.2 are to show a MOP is required if any work is performed in the shared space and has included examples in the Tech Pub wording to show when a MOP will be required. Jeff asked if the new language met what the group intended.

Kim Isaacs – Integra said she needed to run the newly proposed language passed her CO technicians. She said she did not think the CLEC could do any of the work listed.

Jeff Bostow – CenturyLink said that was correct but there have been some occasions where a CLEC has started performing some of this work themselves.

Kim Isaacs – Integra thanked Jeff for the examples and said she would review the new Tech Pub wording internally but that the proposed CenturyLink wording since mid April has been a good balance. Kim said she thought there would not likely be issues with these newly proposed updates. With the April 15, 2016 CenturyLink wording in Section 2, Integra believes they are protected for the day to day work they perform in their collocation space.

Jeff Bostow – CenturyLink said excellent. Susan Lorence – CenturyLink said the examples were added due to the Integra requests during the April monthly CMP call. She then referred call participants to Section 2.1.4.2 to review those wording changes. Susan said she thought Integra had reviewed the 04-15-16 wording and Jeff had made some updates to address the requests from the Monthly call.

Kim Isaacs – Integra said she liked Jeff’s 04-28-16 updates which make the responsibilities clearer.

Jeff Bostow – CenturyLink said the wording is intended to say a CLEC can perform their normal business routine in their collocation space but when work is required in the shared space, the Tech Pub wording applies.

Susan Lorence – CenturyLink asked if there were any other changes in Section 2 that had to be discussed. There were none. Susan then referred call participants to the Action Item list from September 2015 posted to the calendar to see if open items remain. She thought the open items were originally related to the Tech Pub wording changes that were just discussed and the Competency Test/badging wording which will be discussed next. Susan asked about the Action Item 16 related to Network Change Management System (NCMS) process.

Kim Isaacs – Integra said she was fine on that one.

Jeff Bostow – CenturyLink said the NCMS process now covers all of CenturyLink – Local and National.

Susan Lorence – CenturyLink said we will show Action Item 16 completed. She asked about Action Item 5 related to the badging process and whether she could refer that item to the Competency Test CR. No one disagreed. Susan said we will now show all of the Action Items Completed. Susan asked about discussion of a timeline.

Jeff Bostow – CenturyLink said Integra needed some time to review the wording.

Kim Isaacs – Integra said she could reply back by May 11, 2016 as to the whether Integra was OK with the most recently proposed Tech Pub 77350 wording changes.

Susan Lorence – CenturyLink asked Brendan Hamel – Granite if Granite could also meet a May 11, 2016 to provide any concerns.

Brendan Hamel – Granite said he could meet that date.

Susan Lorence – CenturyLink asked for any concerns to be sent to the CMPCOMM@centurylink.com mailbox by May 11, 2016.

PC011516-1 CLEC/CLEC Subcontractor Inside Plant (ISP) Competency Testing Susan Lorence – CenturyLink then pointed call attendees to the third document posted to the Wholesale calendar associated with the CLEC Competency Test CR. Susan said this draft document was created by John Hansen - CenturyLink in a Business Procedure format from the draft Competency Test Process Guide that Jeff had reviewed in the ad hoc meeting in January 2016.

Jeff Bostow – CenturyLink said this document has basically the same content as the CenturyLink internal document but has more of a CMP format. He said this document only applies to work outside of normal CLEC business activities. When a CLEC needs to expand their current model, an Inside Plant Central Office Installation Technician would be required which is an industry title that has been in existence for 30 years or so. Jeff said the Competency Test was developed after some problems in network installation attributed to human error. The Competency Test was aligned with the badging process depending on the work that is to be performed. Jeff said there are two types of testing that are aligned with Telcordia/Ericsson levels: Central Office Equipment (COE) Installer only (Level 1-3) and COE plus Power (Level 4). If the person taking the test successfully passes the Competency Test questions, their badge reflects certification to work in the CO to that level and it allows CenturyLink to be aware of subcontractor capabilities. Jeff said CenturyLink has been pleased with the result of the Competency Test process.

Kim Isaacs – Integra said she has reviewed the Business Procedure and asked how the Competency Test would appear.

Jeff Bostow – CenturyLink said a button would be added to the newly revised CenturyLink badging process to have a CLEC self identify up front to see if they are performing their normal work activities. That should allow no disruption to a CLECs current process. The Competency Test only is required if the CLEC indicates they are going to perform installation work. Jeff said he was not aware of when the newly revised badging website was to be reinstated.

Susan Lorence – CenturyLink said the newly revised badging website and Collocation – CenturyLink Premises Access Overview Business Procedure are to be effective May 18, 2016. CenturyLink is working on the response to CLEC comments that will be posted on May 3, 2016. Following the effective date of May 18, 2016, CenturyLink will work with the SME team to revise this Competency Test documentation and possibly the Collocation – CenturyLink Premises Access Overview Business Procedure to incorporate any changes in the process for CLEC testing.

John Hansen – CenturyLink said he wants to insure there is only one location to update associated with each of the processes.

Kim Isaacs – Integra said she wants to minimize confusion on these processes. Integra has a special point of contact (SPOC) for badging.

John Hansen – CenturyLink said the original information in the Competency Test documentation was not correct as it pointed to the old badging process and it will have to be updated. The first iteration of the badging tool does not have the Competency Test information included since the Tech Pub 77350 and Competency Test related issues were not yet resolved. CenturyLink wanted to get the revised badging website in production before making these Tech Pub related changes. John said there will be some radio buttons that ask what the CLEC scope of work will be. If it is the normal CLEC Collocation work, then the process will flow as today. If the work includes a broader scope, e.g., power work, it will stop the process and require the Competency Test. John asked if that made sense.

Kim Isaacs – Integra said yes.

Susan Lorence – CenturyLink said we will need to clarify in the documentation if a CLEC technician already has a badge and that needs to be expanded to include a further scope of work, e.g., COE or COE plus power, how does the process of competency testing and re-badging occur.

Kim Isaacs – Integra said she will have a chance to review the revised process when the CMP notice is sent. She is thinking if a MOP is required, it could be a trigger internally for Integra to determine if a Competency Test is required.

Jeff Bostow – CenturyLink said the process will apply to both the CLEC and their subcontractor. He said today a CLEC does not have to file a MOP if they are working in their space.

Kim Isaacs – Integra said if their project meets the requirements for a general or detail MOP, their internal process might be tied to the MOP to indicate the Competency Test may be required. Kim said Integra already uses the approved CenturyLink subcontractors for work and they probably have already been tested.

Susan Lorence – CenturyLink said it sounds like we can talk about a timeline for submitting the two Level 4 changes. With the May 11 date for CLEC responses for review of the most recent Tech Pub 77350 updates, the May 18 date for the effective date of the Badging website, Susan proposed that we notify with the two level 4 notifications as of May 19, 2016 with a 45 day timeline.

John Hansen – CenturyLink said he thought that would work from a documentation perspective.

Kim Isaacs – Integra agreed that the two processes for the Tech Pub and the Competency Test should be notified separately.

Brendan Hamel – Granite said he was OK with the May 19 date.

Susan Lorence – CenturyLink proposed that we may need to tweak the notification timelines somewhat but that we would work the various dates to make the changes become effective as of July 1, 2016.

Jeff Bostow – CenturyLink said that will be Issue O of Tech Pub 77350 that will become effective.

All agreed that it was very exciting to think that after the lengthy discussions, these Tech Pub and Competency Test changes will become effective as of July 1, 2016.

Susan Lorence – CenturyLink thanked everyone for their time and said CenturyLink will relay the timeline in the May CMP meeting.

The Ad hoc meeting was adjourned at 11:00 AM MT.

4/20/16 CMP ProdProc Meeting Mark Coyne – CenturyLink reminded callers that this CR is tied to the Tech Pub 77350 CR and is also related to an update to the Collocation Badging Process. Mark said a Level 3 Notice associated with the badging website rewrite is out for review with a comment cycle end date of April 27, 2016 and an effective date of May 18, 2016. There is a download associated with the Competency Test proposed Process that has been placed in the CMP template format that will be reviewed in the ad hoc call.

Kim Isaacs – Integra stated that they had intended to ask for clarifications during the Tech Pub Ad hoc call and now the comment cycle would end prior to the Ad hoc call.

Mark Coyne – CenturyLink asked if Integra could follow the CLEC comment protocol and submit comments to the CMP mailbox so that CenturyLink could try to be prepared to discuss during the Ad Hoc call.

Kim Isaacs – Integra said that would be acceptable but would include a statement that there may be more questions brought up in the Ad Hoc call.

Susan Lorence – CenturyLink advised callers that during the original discussion in January, 2016, Jeff Bostow had provided a draft procedure of the Competency Testing procedure. John Hansen – CenturyLink has placed the information in a CMP template form and that version has been attached to the ad hoc meeting calendar entry. Revisions will be necessary, but that draft is available for review prior to the Ad Hoc call.

3/16/16 CMP ProdProc Meeting Mark Coyne – CenturyLink said the CenturyLink SME team has been reviewing the Competency Test process and how it relates to the Collocation - Premises Access Overview Business Procedure. We had hoped the Tech Pub 77350 wording would help to clarify the process. Mark said we had planned to schedule a call at the end of March to review the redline business procedure and how it relates to the Competency Test screen shots but we will wait to determine when to schedule the next ad hoc call.

Kim Isaacs – Integra said she had previously asked to review the Competency Test questions to confirm they apply to the activities that a CLEC would perform in the CO shared space.

Mark Coyne – CenturyLink said he thought that might occur as part of the review in April.

Susan Lorence – CenturyLink said she was not sure if Jeff Bostow – CenturyLink wanted to share the actual Competency Test questions but we can see if anything has changed.

Kim Isaacs – Integra said that a CLEC would never touch a power plant so those questions on the Competency Test would not pertain to the work a CLEC would perform.

Liz Tierney – Global Capacity said she was not sure why Jeff would have concerns about sharing the questions and why they would be proprietary.

Mark Coyne – CenturyLink said we will take that Action Item back to Jeff. Mark asked if there were any other questions. There were none.

02/17/16 CMP ProdProc Meeting Mark Coyne – CenturyLink said this new CR was presented last month by Jeff Bostow – CenturyLink and there was lots of discussion about the CR associated with Competency Test requirements when a CLEC is performing installation or removal work in the common space. Jeff Bostow – CenturyLink said he has information on the Action Item on the current mode of access and the future mode. Kim Isaacs – Integra said the question [03/07/16 Updates received from Integra in CAPS] ASKED was WHETHER AND how the Competency Test would be tied to the access badge. There is also concern that the Competency Test will have questions that are not associated with work a CLEC would perform and that Integra would like to review the Competency Test questions.

Jeff Bostow – CenturyLink said the Competency Test content has not been divulged. He said there was an Action Item to see how access is provided today. Jeff said the current process identifies the use of the Collocation Web site however that site is being rewritten. Jeff then described the current manual process: The Wholesale CLEC application form is completed and then sent to a contact within CenturyLink depending on the CLEC location. The form is processed internally and once approved, the badge number is assigned and the badge is sent to the CLEC individual requesting the access. Jeff then described the planned process once the Collocation website is back in production which is to designate a point of contact. [NOTE: Any changes to the current process associated with the rewrite of the Collocation web tool will be notified via CMP.] Jeff said there will be two buttons that will be associated with different types of CLEC access to CenturyLink space. Depending on the button selected, the requestor will be routed appropriately. If the Competency Test is not required, Jeff said the assumption is that the CLEC will be working in their defined space.

Kim Isaacs – Integra said a CLEC may have an employee that does work in their defined space as well as performing installation or removal work in the shared space.

Jeff Bostow – CenturyLink said if there is specific power work, it would be covered in a MOP and CenturyLink has responsibility to do that power work so a Competency Test Level 4 is not required.

Susan Lorence – CenturyLink recapped that Jeff is currently working within the CenturyLink SME team to determine how the current process will be revised to accommodate the Competency Test.

Jeff Bostow – CenturyLink said that was correct and that he is working with the SME team to update the screen shots and will revise [03/07/16 Updates received from Integra in CAPS] [delete THE]what was previously shared.

Kim Isaacs – Integra said her understanding of the January 28, 2016 Ad Hoc Call was that a CLEC employee/subcontractor will need the Competency Test if they are building a new collocation (caged or cageless) or decommissioning a collocation.

Jeff Bostow – CenturyLink said if the CLEC is in their cage, they perform that work today with no restrictions.

Kim Isaacs – Integra asked how that works if the CLEC/subcontractor is bringing in equipment through the shared space. She said that is where the revised Tech Pub is unclear as to what will be required. It appears things are working fine currently and there are no issues with the competency of the CLEC employee/subcontractor. Kim said the Tech Pub says CenturyLink can ask a CLEC to leave if there is a concern and said the proposed process seems open to interpretation.

Jeff Bostow – CenturyLink said if a CLEC is moving in equipment and bumps into a power source, those accidents can occur and this is intended as protection of the CenturyLink network. Jeff said this requirement is a safeguard for CenturyLink to insure that any construction or removal of equipment – especially in an unstaffed office – is performed successfully. It is not intended to be restrictive. Jeff said if things are working fine and the CLEC is working just within their cage, that is not prohibited but asked what happens if there is an incident.

Kim Isaacs – Integra said she understands the need for protection and standards but [03/07/16 Updates received from Integra in CAPS] DOES not UNDERSTAND CENTURYLINK’S [delete THE] need to make a CLEC synonymous with a CenturyLink Service Supplier.

Jeff Bostow – CenturyLink said there was a situation with a collocator which did not go well which reaffirmed the need for more standards.

Susan Lorence – CenturyLink asked about the CLEC Action Item to propose clarifying language in Section 2. Then CenturyLink would take the proposed wording to the CenturyLink legal team.

Mark Coyne – CenturyLink said he thought CenturyLink was waiting to send out the formal 45 day notice until the various revisions could be fit together and reviewed with the CLEC community. Mark said we could review the changes on a CMP call.

Jeff Bostow – CenturyLink said yes, the process would be reviewed by Mark Rice – CenturyLink Physical Security. Jeff asked if it was typical to take a poll of call attendees to understand if others on the call had the same concerns as Integra.

Liz Tierney – Global Capacity said she is concerned if there is no documentation that defines the Competency Test. Liz said Global Capacity is nationwide in CenturyLink COs and have not had issues so far. Liz said she needs to understand how the current process might change.

Susan Lorence – CenturyLink asked if the CLECs could propose some language to Section 2 and that CenturyLink would then schedule a call at the end of the March CMP call to review the proposed process.

Kim Isaacs – Integra said the [03/07/16 Updates received from Integra in CAPS] CLEC PROPOSED language HAS BEEN [delete SHE HAS] drafted AND has been sent out for review which WILL also INCLUDE [delete INCLUDES] Integra legal review since the Tech Pub is part of their contractual requirements so she was not sure whether it would be available for review in the March meeting.

Mark Coyne – CenturyLink said we could wait until the April CMP meeting which may tie in with the Event Notice associated with the Collocation portal that has a planned effective date for end of 1st quarter.

Susan Lorence – CenturyLink said we may be in a chicken and egg situation if we have to agree on the Tech Pub language as part of the introduction of the updated Collocation portal and the CLEC review of the revised process of the Competency Test.

Kim Isaacs – Integra [03/07/16 Updates received from Integra in CAPS] AGREED WITH SUSAN AND ASKED CENTURYLINK TO CONFIRM WHETHER [delete SAID] these revisions are not due to a current problem with CLECs but are due to CenturyLink moving to a more contractual workforce.

Jeff Bostow – CenturyLink said CenturyLink has to trust that vendors know what they are doing and the only thing CenturyLink has is the Competency Test to provide an assessment of skill level before work begins in a shared space.

Mark Coyne – CenturyLink asked if there were any other questions. There were none.

01/28/16 CMP Ad Hoc Meeting Attendees: Liz Tierney – Global Capacity Kim Isaacs – Integra Valerie Starr – LS Networks Dave Rands – LS Networks Mark Anderson – LS Networks Scott Church – LS Networks Victor Gaither – TW Cable Frankie Nelson – Windstream Jeff Bostow – CenturyLink Carl Caughran – CenturyLink Mark Coyne – CenturyLink John Hansen – CenturyLink Susan Lorence – CenturyLink

Susan Lorence – CenturyLink provided a brief background of this Change Request (CR) that is related to CenturyLink CR PC042915-1, Technical Publication 77350, associated with Telecommunications Equipment Installation Guidelines. Susan said the most recent meeting for the Tech Pub77350 CR was held on January 7, 2016 and there were two Action Items that were the result. The first Action Item was specific to considering additional language in the Tech Pub. The second Action Item was to create a CR that would provide the process and parameters around the use of a Competency Test by the CLEC community.

Jeff Bostow – CenturyLink said the Inside Plant (ISP) Competency Test was originally developed due to some outages that were determined to be due to human error. With the merger of Legacy-Qwest and Legacy-CenturyLink, there was the need to insure that no matter which facility footprint was being accessed, the Central Office Equipment Installation Tech (COEIT) has the experience and knowledge required to perform the installation as required in Tech Pub 77350. The document provides the five steps to utilize the Competency Test tool. Jeff said the first step in the process is to route the person to the correct site, Inside Plant (ISP), Outside Plant (OSP), or National. If OSP is selected, then the ISP Competency Test is not required.

Kim Isaacs – Integra said this is the first time OSP has come up. Kim said if the CLEC is working in the CO common space – performing installation or removal work, they will require the Competency Test. If it is a day to day job, no Competency Test is required.

Jeff Bostow – CenturyLink said that was true.

Kim Isaacs – Integra asked if the test was required to run conduit.

Jeff Bostow – CenturyLink said that the OSP work did not apply since there was no bandwidth nor was there the knowledge to take the Competency Test. He said they still access the Competency Test, designate “OSP” via the radio button to signal to CenturyLink an acknowledgement of their need to get an access badge but will not be permitted in certain workspace.

Kim Isaacs – Integra asked if the test was tied to the badging process for CLEC access.

Jeff Bostow – CenturyLink said he did not think so since that is tied to the ICA. He said the Central Access Control Center has a process to differentiate OSP, ISP and CLEC access needs. If ISP, they will route the person to the Competency Test. Levels 1-3 are for basic entry level work and Level 4 is for critical work, e.g., working with power, work that might require back out, etc. Jeff said this is especially beneficial for everyone involved if the office is not staffed.

Scott Church – LS Networks asked about a CLEC caged Collo and a cageless Collo since that is open.

Jeff Bostow – CenturyLink relayed some different types of work to be completed but said the Competency Test does not apply to work being done in the CLEC specific space – caged or cageless – as long as the tech is not going outside of their space.

Scott Church – LS Networks asked about a third scenario of CLEC to CLEC cabling and gave the examples of a common room.

Jeff Bostow – CenturyLink said if the CLEC to CLEC is going through any shared space for any reason, then the Competency Test is necessary but if it CLEC to CLEC directly in a common room, then the Competency Test would not be required.

Scott Church – LS Networks said that makes sense.

Liz Tierney – Global Capacity said her understanding is if a tech is only in the CLEC space, no certification is required. If a CLEC hires their own contractor to work in common space, certification is required but it would not be required if they hire CenturyLink to do the work.

Jeff Bostow – CenturyLink said that was correct.

Scott Church – LS Networks said the Competency Test is required if it goes out of the Collo area but if it stays in their space or a segregated Collo space, it is not required.

Jeff Bostow – CenturyLink said that was correct.

Victor Gaither – TW Cable said based on the scenarios just discussed, he did not have an issue.

Kim Isaacs – Integra asked for an example of a Level 1 type job.

Jeff Bostow – CenturyLink said the main difference between Levels 1 through 3 is the experience. The tech performs the same functions. Jeff then provided a detailed example of the set up work in a new environment.

Kim Isaacs – Integra said those activities are required if a CLEC is building a new caged or cageless space and asked if there is another scenario once the space is established, e.g., adding a shelf to a bay.

Jeff Bostow – CenturyLink said if the CLEC is in their own space with no other interconnectivity, certification is not required for that.

Victor Gaither – TW Cable asked if CenturyLink provides a list of certified contractors.

Jeff Bostow – CenturyLink said CenturyLink has a list of suppliers that have passed the Competency Test. He said if a person has failed the Competency Test, they are allowed one additional attempt otherwise the person must wait one week to retest.

Victor Gaither – TW Cable said he was looking for a current list of CenturyLink certified contractors.

Jeff Bostow – CenturyLink said that information is proprietary and he could not provide it.

Kim Isaacs – Integra said per their ICA, that list was available.

Victor Gaither – TW Cable said their company has access to the approved contractor list and also has a list of approved equipment. Victor said that seems consistent with the industry.

Jeff Bostow – CenturyLink said once a contractor has demonstrated a specific competency level, a CLEC can subcontract to them and no additional Competency Test is required if another company works with that contractor.

Victor Gaither – TW Cable said a company can do the work for themselves or hire someone certified who can.

Jeff Bostow – CenturyLink said the Competency Test is mandatory within CenturyLink for all 38 states.

Liz Tierney – Global Capacity asked if those certified will have a different access card and whether those that currently have a badge are impacted.

Jeff Bostow – CenturyLink said he will need to investigate that. NOTE: 2/8/16 UPDATE from Jeff Bostow -- The badge is the access card; they are one and the same (unless a different arrangement was made for the CLECs via the ICA process). The only difference is the Competency Level designation (there is a “P” placed on the badge of those who certify to Competency Level 4). Investigation is continuing on this Action Item.

Victor Gaither – TW Cable said that is important to confirm the impact to the badging process. He said his understanding is that a CLEC can perform work in their environment but if they want to veer out, the Competency Test is required.

Jeff Bostow – CenturyLink said nothing changes in how a CLEC wants to do work in their space. If the CLEC does work outside their space, they must be certified. Jeff said the competency levels have been around at least 35 years since they were established he thought through BellCore which was changed to Telcordia and is now Ericsson. He said there is a National site like this local network site and the Competency Test is required to do work in each but there are certain differences between the two tests. Jeff provided some information specific to the National access process.

Susan Lorence – CenturyLink said we are here for the Local process and that we will take an Action Item to figure out how the badging process works with the Competency Test.

Liz Tierney – Global Capacity said she thought the current badging process does not provide access to inside plant and that there will be some differentiation between those certified and not to identify where they are allowed. Liz said she wants to confirm the badging process will not change.

Jeff Bostow – CenturyLink said he thinks once a customer has an access badge, they are allowed in the inside plant space. The intent is that a company stay in their own space. Today a customer can begin doing inside plant work with no certification but going forward, if they begin work outside their space, it will be determined if that person has the required certification.

Carl Caughran – CenturyLink said during the MOP process, it would be determined if certification was required.

Liz Tierney – Global Capacity said she did not want her techs to be caught with no access under their ICA.

Susan Lorence – CenturyLink said we have this as an Action Item.

Valerie Starr - LS Networks asked about the online badging process and said since last October, the Collocation access site has been down. Valerie said she was not notified the site of this and it is very frustrating to have to go through the old process filling out a form and then having to check multiple times for status.

Victor Gaither – TW Cable said if there was a significant business change, the process would be taken through CMP.

Susan Lorence – CenturyLink said yes but this problem was originally identified as a trouble ticket so an Event Notification was sent. The original thought was that it was a simple fix but then IT determined a larger problem existed and the tool is being rewritten. Susan said the Collocation site should be available end of 1st quarter and that CenturyLink would take an Action Item to follow-up on this and to send a broad notification when the site is to be back up. Mark Coyne - CenturyLink said there is a Trouble Ticket associated with this problem which is tracked each month in the Systems CMP package. Mark said there was now a dedicated person to work the requests until the site is back up and hoped it was working better.

Valerie Starr - LS Networks said no, it is not. She said the web site flowed smoothly but this manual process does not. Valerie said she has been cc’ing her Account manager on each request to get some help.

Susan Lorence – CenturyLink asked how the Collo access site fits into the Competency Test.

Jeff Bostow – CenturyLink said the Collo access site is for a CLEC or vendor and is used to gain access to outside plant or to the vault. Once there is an indication that the person is an ISP, they will be routed to the Competency Test for the appropriate testing level.

Kim Isaacs – Integra said she did not think her techs would identify as an ISP.

Jeff Bostow – CenturyLink said he agreed they would identify as a CLEC to get the badge and not have to go through the Competency Test.

Kim Isaacs – Integra asked if there would be a CLEC button.

Jeff Bostow – CenturyLink said no and that was the basis of the “Service Supplier” issue that is under discussion associated with the Tech Pub 77350 CR.

Scott Church - LS Networks asked if the CLEC tech was supposed to identify as a Service Supplier.

Jeff Bostow – CenturyLink said yes if they were going to work in the ISP space.

Susan Lorence – CenturyLink asked if there was a general understanding of the Competency Test process, who and when the test applied.

Victor Gaither – TW Cable said yes but would like it included in the meeting notes.

Kim Isaacs – Integra asked if their techs would be tested on work they would not perform.

Jeff Bostow – CenturyLink said the test is benign and that the test is aligned with the existing Tech Pubs. It is an open Tech Pub test that is assessing how successful previous training has been.

Susan Lorence – CenturyLink asked if Jeff could provide examples of some of the questions on the Competency Test.

Jeff Bostow – CenturyLink said no.

Frankie Nelson – Windstream asked if they were building racks within their cage, does the Competency Test apply.

Jeff Bostow – CenturyLink said the test does not apply. He said CenturyLink would not be involved in a CLEC space unless a blatant fire, life or safety issue was observed.

Scott Church - LS Networks asked about construction of bays in a caged and cageless space.

Jeff Bostow – CenturyLink said the Competency Test is required to install a bay in cageless space but thought CenturyLink did that work.

Kim Isaacs – Integra asked if a CLEC Tech could take Levels 1-3.

Jeff Bostow – CenturyLink said there is no charge when a CLEC Tech takes the test for the first time. For example, if they take the COE Only test (Level 1-3) and pass, everything is good. If the same CLEC Tech then wants to test for COE plus Power, they are required to pay a one-time charge for the second test and there is no history of the first test.

Susan Lorence – CenturyLink asked if the Action Items are resolved surrounding the Competency Test, can CenturyLink proceed with CMP notification without the Tech Pub issues being resolved.

Kim Isaacs – Integra said the timing is strange.

Jeff Bostow – CenturyLink said he thought the Tech Pub should be resolved first and then the Competency Test.

Susan Lorence – CenturyLink thanked everyone for the discussion. There are two Action Items and we will try to include the responses in the meeting minutes: 1) The question about how the Competency Test ties into the badging process; 2) The status of the Collo web site.

The Ad hoc meeting was adjourned at 3:00 PM MT.

01/20/16 CMP ProdProc Meeting Jeff Bostow – CenturyLink presented this new walk-on CR submitted by CenturyLink associated with the Tech Pub 77350 rewrite. Jeff said with the one company approach within CenturyLink, there is a desire to insure the Tech Pub 77350 is followed which includes an assessment of anyone who will attain an access badge for any CO work. The Competency Test is to insure that those requesting access have the wherewithal to perform the work. The CR is associated with capturing the web site and process to be used. Jeff said this Competency Test is not intended to train anyone but is to assess what should already be known. Kim Isaacs – Integra said she had been on the January 7, 2016 call and that she disagreed with Jeff’s statement that it was agreed the CR would be beneficial. Kim said Integra is not aware of any persistent problem with [1/29/16 Updates received from Integra in CAPS] [Delete INTEGRA] WITH THE CLEC’S employees skill level.

Jeff Bostow – CenturyLink said the Competency Testing is for anyone that would leave their dedicated CO space which includes CenturyLink employees, external contractors/suppliers, CLECs and CLEC subcontractors.

Kim Isaacs – Integra asked if a customer’s caged spaces are not subject to this Competency Testing but cageless spaces would require the Competency Testing. Kim said her understanding is that any job that requires a MOP will require a Competency level 4 lead resource to supervise the job. CenturyLink has not demonstrated that there is a persistent issue and thus this is adding an extra burden to CLECs. Kim said that she has not seen the test so she is not aware what it covers but wants to insure the test [1/29/16 Updates received from Integra in CAPS]WOULD ONLY [Delete COVERS] COVER the work activities that a CLEC [Delete WILL] WOULD perform IN A CO. Her concern is that a “one size fits all” Competency Testing might not fit since there are actions that a CLEC may never do in a CO. [1/29/16 Updates received from Integra in CAPS] BASED STATEMENTS CENTURYLINK MADE ON THE 1/28/16 AD HOC CALL – IT IS INTEGRA UNDERSTANDING THAT COMPETENCY TESTING IS ONLY REQUIRED FOR CLEC EMPLOYEES WHEN THE CLEC CHOOSES TO HAVE ITS EMPLOYEES INSTALL OR DECOMMISSION A COLLOCATION SPACE; OR WORK WITH POWER. ONCE THE CLEC COLLOCATION SPACE IS ESTABLISHED, DAY TO DAY OPERATIONS, EQUIPMENT OR CARD ADDITIONS DO NOT FALL UNDER THE COMPETENCY TESTING REQUIREMENTS.

Mark Coyne – CenturyLink said the purpose of the call today is to present the CR and that Kim is bringing up good questions. Mark said the next step is for CenturyLink to conduct an Ad Hoc call to review the CR and the Competency Testing process. He said CenturyLink would like to establish an Ad Hoc call to immediately follow the Tech Pub 77350 call on January 28 and that a separate meeting notice would be sent.

Kim Isaacs – Integra said she is concerned that the in depth calls related to a CR are not handled on the CMP monthly call. The CMP monthly calls are a standing two hour call and have been for over ten years and believes that time should be used to allow more people to participate and provide input. Kim said on the last Tech Pub 77350 Ad Hoc call, only Integra and Granite attended and that more CLEC participation is needed since these are impactful changes and having an Ad Hoc call is not working.

Mark Coyne – CenturyLink asked other customers on the call to weigh in and asked if they were supportive of extending the monthly call vs. holding a separate Ad Hoc call for those customers interested in a specific topic.

Victor Gaither – Time Warner Cable said he was flexible as to when CenturyLink would hold an Ad Hoc call but wanted more information on the scope of the new CR. Victor asked what type of work CenturyLink was talking about that would require the Competency Testing, for example, power work, fiber distribution panel, circuit work, etc. Victor said for work in a dedicated space, he did not think the Competency Testing is an issue for the CLEC employees/agents; the CLEC has the responsibility to insure their technicians are trained. Victor said he wants more information on the scope and when this might be implemented and that he also is concerned about his resources and that it seems like this is a big deal.

Jeff Bostow – CenturyLink said CenturyLink had a recent spate of installation related outages and found that some of the people erecting iron work, running cable, etc. did not have the proper training to do installation of inside plant. Jeff said he was talking about the technicians that build the network vs. those maintaining the network and used the example of the carpenter that builds a house vs. the owner of the house. Jeff said the installation job impacts the success of the next job and if someone does not know what they are doing and accidently causes an outage, CenturyLink is accountable to the PUC.

Kim Isaacs – Integra asked if the outages Jeff referred to were caused by a CLEC.

Jeff Bostow – CenturyLink said no, the outages were caused by human error. He said the Competency Testing is not fool proof but should help identify who knows how to perform the work and who does not.

Kim Isaacs – Integra said she does not have a problem with the Tech Pub 77350 standards but that a CLEC is contracted to CenturyLink to meet the standards and this Competency Testing seems like an extra step on who is allowed into a CO. Kim said the Competency Testing levels 1-4 may not be appropriate. In regard to how cageless space is handled, Integra has a workforce that is trained to work in that space and there has not been an issue the CenturyLink can point to. Kim said this is difficult to understand. Victor Gaither – Time Warner Cable asked if a cageless collocation is in scope.

Jeff Bostow – CenturyLink said yes it would be and gave examples of running cable or power or timing shelf synchronization.

Victor Gaither – Time Warner Cable asked if there was differentiation on the types of work to be done and the level of competency.

Jeff Bostow – CenturyLink said yes that the competency levels are taken from what was originally Telcordia (now Ericsson). Jeff said the four competency levels are industry standard and gave some examples of level 1-4 with the highest level requiring power certification. Jeff said when there is an outage, it has to be explained and how it was done incorrectly. The Competency Testing is to protect the network especially in a shared space.

Kim Isaacs – Integra said the Tech Pub 77350 now reads that if there is a MOP being worked by a level 1-3 technician, a level 4 lead is required to supervise the work.

Jeff Bostow – CenturyLink said that is correct.

Kim Isaacs – Integra said the Tech Pub 77350 requires CLECs/subcontractors to follow the same standards.

Victor Gaither – Time Warner Cable said if they have level 4 work, they resource that differently. Victor said he needs to read the Tech Pub and join the call next week.

Susan Lorence – CenturyLink asked if there was agreement to schedule a call for this CR following the Tech Pub call on January 28, 2016 since those resources may be the same.

Kim Isaacs – Integra said when contentious issues are pushed to an Ad Hoc call, attendance is lower.

Mark Coyne – CenturyLink said he will get with the CMP team to see if we can incorporate more discussion on the monthly CMP call. Depending on the topic, we will need to weigh what is most appropriate.

Armando Fimbres – Oregon PUC said he thought the recent discussion was good and wondered if the Ad Hoc calls can be added to the end of the CMP call.

Mark Coyne – CenturyLink said we have done that in the past but it also depends on the timing of when the CR is submitted. Mark asked if there were any more questions for Jeff. There were none.