Wholesale: Products & Services

Open Product/Process CR PC012703-1 Detail

Description Of Change

Expected Deliverable

Covad requests that Qwest reduce its current provisioning interval for Loop Conditioning to a standard of 5 days

Project Meetings

Moreland-Qwest presented the Qwest denial response. Berard-Covad stated that Covad was evaluating whether to escalate this issue. The CR was moved to denied status.

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03-19-03 - CMP Meeting

Smith-Qwest stated that Qwest would like to continue to evaluate this CR. CR moved to evaluation status.

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02-19-03 - CMP Meeting

Zulevic-Covad presented the CR. He stated that Qwest is currently processing orders in less than the 15 day interval; in many cases in fewer than 5 days. He stated that this caused both Qwest and Covad excess work. He stated that if Qwest established a 5 day interval, Covad understood that there would be instances when Qwest could not meet the interval. White-Qwest stated the CR would move to Presented status.

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Clarification Meeting 3:00 PM (Mountain Time) / Monday, February 3, 2003

1-877-550-8686 2213337#

Attendees Matt White – CRPM Deb Smith – Qwest Bob Mohr – Qwest Neil Houston – Qwest John Berard – Covad

Introduction of Attendees White-Qwest welcomed all attendees and reviewed the request.

Review Requested (Description of) Change Berard-Covad reviewed the CR. Smith-Qwest asked which products this CR was for. Berard-Covad stated that it was for the products that Covad ordered: UNE unbundled loops and line sharing. White-Qwest asked which ILECs Covad was referring to in its description. Berard-Covad stated that SBC and Bell South had 5-10 day intervals and that Qwest had the longest interval at 15 days.

Confirm Areas and Products Impacted White-Qwest confirmed that the attendees were comfortable that the request appropriately identified all areas and products impacted. Confirm Right Personnel Involved White-Qwest confirmed with the attendees that the appropriate Qwest personnel were involved.

Identify/Confirm CLEC’s Expectation White-Qwest reviewed the request to confirm Covad’s expectation.

Identify and Dependant Systems Change Requests White-Qwest asked the attendees if they knew of any related change requests.

Establish Action Plan White-Qwest asked attendees if there were any further questions. There were none. White-Qwest stated that the next step was for Covad to present the CR at the February Monthly Product/Process Meeting and thanked all attendees for attending the meeting.

CenturyLink Response

REVISED RESPONSE For Review by CLEC Community and Discussion at the April 16, 2003, CMP Product/Process Meeting

03/28/03

Mike Zulevic Director – GEA Covad Communications

SUBJECT: Qwest’s Change Request – CR PC012703-1

This letter is in response to CLEC Change Request PC012703-1. This CR is a request by Covad for Qwest to reduce its current provisioning interval for Loop Conditioning to a standard of 5 days.

Qwest is denying this request because it is economically not feasible. The following supports this decision:

Covad has stated that the current interval causes excess work for both Qwest and Covad. Contrary to that assumption, Qwest finds that the opposite is true for Qwest work. After an analysis of the impact to Qwest workforces, Qwest has determined an additional 150-185 resources would be required to respond to a 5 day interval. This would include: - 25-30 Engineering resources to issue jobs more quickly - 5 resources in the Construction Management Centers to process the jobs through on an escalated basis - A minimum of 120–150 Field resources across the 14 state region to complete the conditioning work

Economic conditions currently do not facilitate an increase in head count to support the proposed interval reduction.

Qwest has voluntarily initiated the use of Line Moves and Removal of UDCs in order to provision Line Sharing, ADSL-capable Unbundled Loops and Qwest retail DSL products (see CR #PC022403-5, PC022403-6, PC022403-7 and PC022403-8). Qwest feels that this initiative will reduce the need for line conditioning for many orders as well as reduce the provisioning interval for those orders utilizing a Line Move.

Qwest has also initiated a new Bulk Deload project, which will be to both the CLECs and Qwest’s advantage in responding to their customers’ service requests by eliminating the need to require line conditioning for many orders. Qwest has notified the CLEC community of this project through the Joint Planning Process.

Covad has stated that SBC and Bellsouth line conditioning intervals are at 5-10 days. Qwest respectfully disagrees. Qwest research of similarly situated ILECs indicate: - SBC has a 10 business day interval - Bellsouth has an 11-12 business day interval: the standard interval of 11 business days and the LSR processing interval of 3-24 hours equals the total service interval - Verizon has a 15 business day interval

Qwest finds the Qwest current line conditioning interval of 15 business days to be within the nationwide standard.

Sincerely, Heidi Moreland Staff Advocate Policy and Law

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March 12, 2003

DRAFT RESPONSE For Review by CLEC Community and Discussion at the March 19, 2003, CMP Product/Process Meeting

Mike Zulevic Director - GEA Covad Communications

SUBJECT: Qwest’s Change Request Response - CR #PC012703-1

This is a preliminary response regarding Covad CR PC012703-1.

Qwest has reviewed the current Loop Conditioning interval. There are a number of issues Qwest must analyze before answering this request. For this reason, Qwest proposes moving this Change Request into Evaluation Status while Qwest prepares a complete answer to this request.

Qwest will provide a status update at the April CMP meeting.

Sincerely,

Debra Smith Product Manager Qwest Corporation