Wholesale: Products & Services

Open Product/Process CR PC012703-3 Detail

Description Of Change

Expected Deliverable: Provide as soon as possible. Amend existing product to include this request.

Project Meetings

Nelson-Qwest presented the Qwest response. Zulevic-Covad stated that he had no questions but that Covad and Qwest differed in opinion in this issue. He stated the CR should be closed as denied because Covad’s description of change inferred that they wanted pricing similarities. Zulevic-Covad stated that he disagreed with Qwest’s assessment that this was a service that should be performed for a charge. The CR was moved to denied. Subsequent to the CMP Meeting, Zulevic-Covad contacted Nelson-Qwest by phone. Zulevic-Covad has stated that Qwest could close the CR as partially accepted because Covad can partially decommission a site, but not at the terms Covad requested. Zulevic-Covad asked that Qwest capture in the minutes Covad’s disappointment that Qwest was unwilling to perform this work without charge.

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03-19-03 - CMP Meeting

Nelson-Qwest presented the Qwest response. Zulevic-Covad stated that the current Qwest process the Nelson described meets Covad’s needs, but that Covad is also seeking a reimbursement similar to total decommissioning when another CLEC picks up unused collocation elements. Nelson-Qwest stated that this facet was not included in the description of change or mentioned on the clarification call. He stated that he would analyze that request. Zulevic-Covad stated that he was not satisfied with the high costs Qwest was charging. Nelson-Qwest stated that Qwest’s charges were approved by a commission or negotiated in Covad’s interconnection agreement, and were not part of CMP. The CR was moved to evaluation.

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02-19-03 - CMP Meeting

Zulevic-Covad presented the CR. Nelson-Qwest asked if Covad expected the partial decommissioning service to be performed at no charge. Zulevic-Covad stated that he expected it to be a small charge, because, in many cases, Qwest would only be updating its records. White-Qwest stated that the CR would be moved to Presented status.

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Clarification Meeting 1:00 PM (Mountain Time) / Monday, February 3, 2003

1-877-550-8686 2213337#

Attendees Matt White – CRPM Steve Nelson – Qwest John Waltrip – Qwest Jeff Cook – Qwest Lillian Robertson – 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. Waltrip-Qwest asked if the request was to give up space, power, etc on a partial basis. Berard-Covad responded that it was. Nelson-Qwest asked if the request was to the bay level or to the shelf level. Berard-Covad stated that he was primarily concerned with individual bays or terminals. Waltrip-Qwest asked if Berard was familiar with the Inverse Augment Product. Berard-Covad stated that he was not intimately familiar with it but would ask Neesen-Covad if that product addressed this request.

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

Mike Zulevic Director - GEA Covad Communications

SUBJECT: Qwest’s Revised Change Request Response - CR #PC012703-3

This memo is in response to Covad CR PC012703-3. This CR requests “…that Qwest provide a partial decommissioning product similar to the current decommissioning product that will include all collocation components to include but not be limited to space, termination, bays, and power.”

Qwest Response: Accepted

The request is accepted for the following reason: Qwest currently allows CLECs to reduce portions of an existing collocation site. To request this service a CLEC must complete the collocation application form “New/Change/Augment Application”. On this form, the CLEC must specify the work to be performed. In response to this form Qwest will issue a quote per the ICA or established timelines in the SGAT, as appropriate. Commissions, through cost docket hearings, arbitration, or through negotiations, approve the rates associated with this service.

Qwest also has an existing product that allows CLECs to power down DC power at a lesser cost, when an amendment is signed between Qwest and the individual CLEC.

Key work steps associated with reducing terminations, bays, or space is as follows: Receive application, validate, schedule, and distribute. (CPMC) Conduct 48 hour call where requested or needed. (Team of Network SMEs) Open a planning document and procure funding to process the job. Space planning and power engineering review to determine potential impacts. Determine feasibility. Begin IOF engineering job. Route to OSP if anything involving entrance facilities removal. Assign floor space changes, terminations, power changes. Monitor payment for timely acceptance. Request field visit to validate existing and changes (reductions or removals) Develop quote input. Enter job into COE-FM or OSP-FM. Schedule installation forces. Monitor payment and timely acceptance. Procure material as required. Track job progress and project manage all work steps, timelines, and resolve gaps or jeopardies. Complete field work and complete an Installation Completion Notification. Update applicable data bases such as TIRKs and SWITCH. Issue a revised APOT(s).

Qwest has a legitimate business reason to be compensated for these work functions and has no plans to reduce pricing which is based on cost models filed with the commissions or negotiated rates through Interconnect Agreements. This portion of the request (partial decommissions at no cost like full decommissions) which was identified during the clarification call on Feb. 3, 2003 is outside the CMP process since pricing is subject to commission ordered rate elements and or negotiations.

In the March 19, 2003 CMP Meeting, Covad asked whether any partial decommissioned infrastructure could be reused and, thus, be reimbursable. This request significantly changes the scope of this CR. By definition, Qwest’s decommission product and available inventory product descriptions require fully decommissioned sites for posting and reimbursement, if a subsequent CLEC requests the site. In situations where a CLEC occupies a cage, Qwest only posts vacated collocation space to the Web site if the CLEC completely vacates the space and the CLEC termination cable remaining in the cage meets applicable engineering standards. When a CLEC still occupies a portion of their cage space, any “partially decommissioned” site termination cable would be useless to other CLECs because the original CLEC is still occupying the site where the cable terminates. Qwest occasionally mines out partially decommissioned cable, but only in situations where it is necessary to relieve cable rack congestion. In a situation where a CLEC occupies cageless space, Qwest brings power and terminations to a cageless bay lineup and installs them to the equipment bay. This installation requires H-taps for power to be placed on each bay, and the cable and ground cable to be cut to length. Power cable running to a CLEC site is not CLEC cable nor is it reimbursable today under available inventory. Partially decommissioned power can not be reimbursed. Cageless bays are removed by the CLEC in most cases.

In summary, Qwest currently allows CLECs to reduce portions of an existing collocation site but has no plans to reimburse CLECs for a partial decommission.

Sincerely, Steve Nelson Qwest Product Manager

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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 #PC012703-3

This memo is in response to Covad CR PC012703-3. This CR requests “…that Qwest provide a partial decommissioning product similar to the current decommissioning product that will include all collocation components to include but not be limited to space, termination, bays, and power.”

Qwest Response: Accepted

The request is accepted for the following reason: Qwest currently allows CLECs to reduce portions of an existing collocation site. To request this service a CLEC must complete the collocation application form “New/Change/Augment Application”. On this form, the CLEC must specify the work to be performed. In response to this form Qwest will issue a quote per the ICA or established timelines in the SGAT, as appropriate. Commissions, through cost docket hearings, arbitration, or through negotiations, approve the rates associated with this service.

Qwest also has an existing product that allows CLECs to power down DC power at a lesser cost, when an amendment is signed between Qwest and the individual CLEC.

Key work steps associated with reducing terminations, bays, or space is as follows: Receive application, validate, schedule, and distribute. (CPMC) Conduct 48 hour call where requested or needed. (Team of Network SMEs) Open a planning document and procure funding to process the job. Space planning and power engineering review to determine potential impacts. Determine feasibility. Begin IOF engineering job. Route to OSP if anything involving entrance facilities removal. Assign floor space changes, terminations, power changes. Monitor payment for timely acceptance. Request field visit to validate existing and changes (reductions or removals) Develop quote input. Enter job into COE-FM or OSP-FM. Schedule installation forces. Monitor payment and timely acceptance. Procure material as required. Track job progress and project manage all work steps, timelines, and resolve gaps or jeopardies. Complete field work and complete an Installation Completion Notification. Update applicable data bases such as TIRKs and SWITCH. Issue a revised APOT(s).

Qwest has a legitimate business reason to be compensated for these work functions and has no plans to reduce pricing which is based on cost models filed with the commissions or negotiated rates through Interconnect Agreements. This portion of the request (partial decommissions at no cost like full decommissions) which was identified during the clarification call on Feb. 3, 2003 is outside the CMP process since pricing is subject to commission ordered rate elements and or negotiations.

Sincerely, Steve Nelson Qwest Product Manager