Wholesale: Products & Services

Open Product/Process CR PC020210-1 Detail

Description Of Change

Project Meetings

7/17/13 Product/Process CMP Meeting Mark Coyne– CenturyLink said that CenturyLink sent the initial level 4 notice on June 10, 2013. No CLEC comments were received. The final notice was sent on July 10 with a planned effective date of July 25. The CR will then be moved to CLEC Test.

6/19/13 Product/Process CMP Meeting Mark Coyne– CenturyLink said there was a second ad hoc meeting on June 5 where CLEC questions from Integra and Windstream were reviewed. Mark relayed the CLEC questions and the minutes from the meeting are posted to the Wholesale calendar. CenturyLink had some additional updates from the June 5 meeting. On June 10, CenturyLink sent out a level 4 notice to provide a formal comment cycle. The planned effective date of the notice/TP 77385 update is July 25. Mark asked if there were any questions. There were none.

5/15/13 Product/Process CMP Meeting Susan Lorence– CenturyLink said this CR was moved out of Deferred status in April and relayed that an ad hoc call had occurred on May 1. Susan said the majority of the discussion was focused on the CLEC impacting changes. The meeting minutes are posted to the calendar as well as the Tech Pub updates that are as a result of the discussion in the meeting. During the call, it was determined that CLECs would have some time to review the changes with their engineers and submit questions in writing this week. Susan said there were CLECs requests to extend the review period so the next ad hoc call is now scheduled for June 5 from 9:30 to 10:30 AM MT. The revised documents are posted to the calendar with a 5-1-13 date. Susan asked if there were any questions.

Kim Isaacs – Integra expressed thanks for the additional review time.

5/1/13 Ad Hoc Meeting Attendees: Al Finnell – Windstream, Kim Isaacs – Integra, Curtis Ashton – CenturyLink, Rita Urevig – CenturyLink, Mark Coyne – CenturyLink, John Hansen – CenturyLink, Susan Lorence – CenturyLink

Susan Lorence - CenturyLink began the meeting by providing a brief history of this Change Request (CR). It was opened in February of 2010 and several ad hoc meetings were held in March and April. The meeting minutes from those meetings are included in the CR. Then the CR was placed in a Deferred status in April 2010. The CenturyLink SMEs subsequently worked on combining legacy CenturyLink power standards into the Tech Pub. Susan said we would like to approach this meeting by providing a high level review of the minor changes and then focus the call on reviewing the history log of the CLEC impacting changes.

Curtis Ashton - CenturyLink said the changes were driven by combining company standards across the various legacy companies. Curtis said the legacy CenturyLink did have standards but not actual Tech Pubs and that CenturyLink is looking at standardizing certain Tech Pubs across the company. The changes listed in the “minor change” history log for the Tech Pub 77385 were those that did not have anything to do with collocation or were minor updates associated with combining company standards. Curtis said the reason for this Tech Pub was to document CenturyLink standards for Power Equipment vendors and detailed power engineering vendors and some updates were to respond to requests for clarification in various sections of the document.

Kim Isaacs – Integra asked if there was a way to tell which entries in the history logs were associated with the Telcordia GR-513 update and which were related to combining companies.

Curtis Ashton - CenturyLink said he would point out which updates go with which change as he reviews the document. He said updates to the Telcordia GR-513 and, in turn, the Tech Pub was because power standards across the world are changing.

Kim Isaacs – Integra asked Curtis to point out differences as to how power is measured which will impact customer rates. Kim asked if Curtis had looked at the ICAs before making updates to the Tech Pub to insure the Tech Pub and ICA language matched. Kim used the example of AC Power and convenience outlets and the use of the term “may”.

Curtis Ashton - CenturyLink said those are good catches and to point those out during the review. He said there was no way he could review all of the ICAs as part of this Tech Pub standardization effort and that it was difficult to make the Tech Pub universal. He said he would make that update on the convenience outlets.

Kim Isaacs – Integra asked if the Tech Pub includes the statement that the “ICA rules”.

Al Finnell – Windstream agreed that would be good to add.

Curtis Ashton - CenturyLink said that was a good point and that he would include the “ICA rules” statement in Section 1.4 of the document. Curtis then began review of the history log of CLEC impacting changes which was in reverse order. He said the history log provided an overview of the specific wording in the Tech Pub.

Kim Isaacs – Integra said she was trying to cross reference Tech Pubs to insure things lined up and referred to Tech Pub 77351 Section 7.C.3 titled “Standalone rechargeable units”.

Susan Lorence - CenturyLink said before the group gets too far along in the review, she would like to confirm that for the meeting minutes for the call, the history logs would be used as reference and that she would capture questions and action items vs. the very detailed discussion.

Kim Isaacs – Integra said she understood though wished the detail was available.

Susan Lorence - CenturyLink said if there was something specific on the history log, we could capture it.

Kim Isaacs – Integra said she had Integra SMEs reviewing the document and that she may have more questions as the document is reviewed. Curtis Ashton - CenturyLink asked how CLEC feedback would be handled after the call.

Susan Lorence - CenturyLink said the plan was for Curtis to provide a high level review of the changes, allow for CLEC questions during the meeting and we would then determine if further Tech Pub updates were required. Susan said if there are CLEC questions prior to the next ad hoc meeting, those should be sent to the CMPCR mailbox.

Curtis Ashton - CenturyLink continued to review the changes associated with each line of the history log of CLEC impacting changes:

Section 1.5 – Related to Fuse coordination – Required for certain systems to minimize the impacts of an outage. CenturyLink requires this for our equipment but this is not required for collocators – See 7th paragraph in Section 1.5. This is more clear in Chapter 9, Section 9.6 where it identifies that feeds to CLECs are exempt from this requirement (just prior to Section 9.7). Section 1.6 – Updates made to make the document more generic and clarify NEBS spaces vs. non-NEBS spaces in CenturyLink network. For CLECs, requirements relate to their ICA. Kim Isaacs – Integra questioned whether the document identifies that the Tech Pub now applies to all CenturyLink states and would like that added.

Curtis Ashton - CenturyLink said he would put that information in Section 1.2.

Section 2.3 – Existing power standards policy is now stated in this Tech Pub. Section 2.4 – Changes were driven by Telcordia GR-513. Industry meetings took place over several years which is why there are multiple updates over a period of time. Curtis said that heat release requirements are a very important part of NEBS. Section 2.4.1 was updated to include equipment examples for both CenturyLink and vendors.

Al Finnell – Windstream questioned the 1st paragraph of Section 2.4 and how calculations occur.

Kim Isaacs – Integra said this has been an area of contention.

The Section 2.4 issue was summarized as follows: List 1 drains are not necessarily fully utilized based on anticipated growth. They can be calculated based on forecasted use vs. full population or usage.

Curtis Ashton - CenturyLink said Section 2.4 Bullet 1 includes some minor changes as to how things were sized but also includes a major change relating to cable voltage drop which in some cases is 125%.

Al Finnell – Windstream said he was going to refer this document to his engineers especially this section.

Curtis Ashton - CenturyLink asked if there were any other questions on List 1 and 2 drains since this has been a big issue in the past. There were none but Curtis said we can come back to this section if necessary.

Section 3.6 – Ni-Cd battery usage was added to make customers aware of how they are being used. Also removed references to polymer batteries since they have been removed from the CenturyLink network. Section 4 – Added information that collocators can place converters in CenturyLink network. Section 5 – Added information about inverters in the CenturyLink network. Section 6.3 – Clarified information about breaker coordination and added that in some instances EPO (emergency power off) switches may exist but not in a CO. Section 9.2 – Relates to voltage drop and rules. This is a carryover from previous ad hoc calls and relates to legal actions in some states. CenturyLink will use CLEC equipment order to size the cables. It also provides information on how CenturyLink is sizing batteries. Section 9.4 – Relates to standards for DC leads; the main reason this was added was for wireless backhaul. There is also information on red and black power wiring. Section 9.5 – Relates to Protectors and how they are sized. This section was part of the 2010 ad hoc meetings. The 200% language came out of AT&T. The rule does not apply inside the collocator cage. Section 9.6 – The List 1 drain estimating method was removed. Estimating now occurs in the CenturyLink lab.

Al Finnell – Windstream asked if this relates to the equipment that the CLEC installs and asked how CenturyLink would estimate that.

Curtis Ashton - CenturyLink said we don’t make any assumptions or estimates on the CLEC side. He said CenturyLink does not know what the CLEC will put in.

Al Finnell – Windstream said the best way to describe it in the history log would be to just say “Removed the use of a List 1 drain estimating method.”

Curtis Ashton - CenturyLink said he would update the history log entry.

Section 9.6 continued – The BDFB maximum was changed to 100 amps which used to be 70 amps. This does not apply to CLECs.

Al Finnell – Windstream questioned why it did not apply to CLECs.

Curtis Ashton - CenturyLink said the reason to include this is to relay that CLECs will not be fed from a BDFD if more than 100 amps are ordered.

Section 13.4 – The BDFB threshold and load was clarified regarding the A and B side due to lessons learned in the 90’s. An alarm will go off at 40% to allow time to react. Al Finnell – Windstream asked what happens to orders if the 40% alarm is reached.

Curtis Ashton - CenturyLink said that was an excellent point and said that orders will not be refused if the 40% alarm occurs. 50% is still the rule.

Section 17.1 – GR-513 was added as a reference.

Curtis Ashton - CenturyLink asked what the next steps would be for this CR.

Susan Lorence - CenturyLink said our proposal would be to give the CLECs some time to review the document with their engineers and then schedule another ad hoc call. Susan asked whether one or two weeks would be appropriate.

Al Finnell – Windstream said he would like two weeks to allow sufficient time for internal review and then have another ad hoc call.

Susan Lorence - CenturyLink said the plan for the next ad hoc meeting would be to review any specific CLEC questions vs. reviewing the whole document. Susan asked if CLEC questions could be submitted in two weeks and then an ad hoc call could be scheduled for the week of May 20.

Al Finnell – Windstream and Kim Isaacs – Integra agreed.

Susan Lorence - CenturyLink said assuming there is no need for an additional ad hoc call following the one later in May, the next step would be to submit the notice and Tech Pub updates for formal review which would include a 15 day formal CLEC comment cycle, 15 day CenturyLink response period and 15 day final notice prior to the effective date.

Curtis Ashton - CenturyLink said he had four action items and would get those completed in a day or so.

Susan Lorence - CenturyLink said the revised Tech Pub updates would be posted to the calendar for today’s meeting. Any CLEC questions and any additional Tech Pub updates would be posted to the subsequent ad hoc meeting. Susan said she would set up another ad hoc meeting for the week of May 20 and that she appreciated everyone staying on the call longer than planned to get through the material.

The meeting was adjourned at 11:45 AM MT.

4/17/13 Product/Process CMP Meeting Mark Coyne – CenturyLink said this CR was opened in February 2010. The CR originator, Curtis Ashton, placed the CR in Deferred status while he worked on combining legacy CenturyLink power standards into the document. Mark said the CR has moved out of Deferred and we will be scheduling ad hoc meetings to review the planned updates. The first ad hoc call is scheduled for May 1 from 9:30 to 10:30 AM MT. The meeting notice is planned for Friday, April 19, to relay details and provide redline documents.

Curtis Ashton – CenturyLink relayed that he has responsibility for four technical publications. The first one submitted last year was TP 77355, Grounding - Central Office and Remote Electronic Equipment Environments, which did not have any issues as it progressed through CMP. TP 77385 had been reviewed previously during ad hoc meetings and had CLEC comments. More changes are being made to combine Legacy CenturyLink into the document. Curtis said that we will cover all of the planned documentation updates on the May 1, 2013 call but focus will be on those areas the CLECs will likely be most interested in. More ad hoc calls can be scheduled as needed. Curtis asked if there were any questions. There were none.

8/15/12 Product/Process CMP Meeting Deferred CR list – Product Process Mark Coyne – CenturyLink relayed that in the July meeting, CenturyLink had asked the owner of each Deferred CR to determine if it should remain in Deferred status, is it should be Withdrawn, or whether it should be re- evaluated. Mark then reviewed the status of each CR as listed on the Attachment:

PC020210-1 - TP 77385 – Power standards updates – CenturyLink will retain this CR in Deferred status. CL SMEs are working on combining Legacy CTL power standards into this document. CR will then be reactivated.

5/19/10 Product/Process CMP Meeting Bonnie Johnson – Integra indicated that last month she had inquired about PC020210-1, TP77385 – Power standards updates and why the CR was placed in a Deferred status. Bonnie questioned whether Qwest had any more information on this.

Mark Coyne – Qwest relayed he did not have any more information on this and questioned Susan Lorence – Qwest if she had any more information.

Susan Lorence – Qwest indicated that she thought Curtis Ashton –Qwest had some other Tech Pub updates that were taking his time.

4/21/10 Product/Process CMP Meeting Mark Coyne – Qwest relayed that Curtis Ashton was not able to attend today’s meeting due to other meeting conflicts. Mark identified Qwest would move this CR into a deferred status.

Bonnie Johnson – Integra asked why is this in deferred status.

Mark Coyne – Qwest relayed he was not sure why but he assumed it was to do more evaluation.

04-01-10 Ad hoc meeting minutes APRIL 15, 2010 NOTE: THE REDLINED EDITS TO THE DRAFT MEETING MINUTES THAT WERE PROVIDED BY PAETEC HAVE BEEN INCLUDED IN CAPS/BOLD OR ARE IDENTIFIED WITH STRIKETHROUGH. SEE WHOLESALE CALENDAR FOR VERSION WITH STRIKETHROUGH.

Attendees: Julia Redman-Carter-PAETEC, Patrick Phipps – QSI Consulting, Inc. (on behalf of PAETEC), Diane Bowers – PAETEC, Al Finnell – PAETEC, Bryan Vanyo – PAETEC, Ross Nielsen – PAETEC, Robert Fuller – PAETEC, Bonnie Johnson - Integra, Kim Isaacs – Integra, Doug Denney – Integra, Mike McCarthy – Minnesota Dept. of Commerce, Curtis Ashton - Qwest, John Hansen - Qwest, Susan Lorence - Qwest

Susan Lorence – Qwest relayed that the last ad hoc call had been held on March 19, 2010. Following that call, Curtis Ashton – Qwest made some updates to the Tech Pub based on the discussion in the last call. Susan relayed a revised version of the Tech Pub was posted to the calendar. Susan relayed that she thought we left off on Section 9.2 and that we would begin there.

Curtis Ashton – Qwest said in Section 9.2, we would begin with the next paragraph that talks about other voltage after the formula discussion from the prior meeting. Curtis said he made some clarifications for 24 V and 130 V battery plants and converter plants that had not been covered before. He added voltage drop rules at the end of this paragraph and clarified the different voltages which apply.

Curtis Ashton – Qwest said in Section 9.4, an addition was made which applies to DC circuits from one cabinet or building to another. This is for when circuits are exposed to lightning because they are connected to DC plant. Some rules were built that apply to Qwest but do not really affect CLECs.

Curtis Ashton – Qwest said in Section 9.5, he added information about the maximum sizing rules (200%). Curtis said we always had the 125% minimum sizing rule and provided an example.. Ross Nielsen – PAETEC asked how that affected the CLEC: If they are only using 10 amps on A and 10 amps on B? Curtis Ashton – Qwest said if the order is for a 100 amp feed regardless of what it is drawing, they will be sized at 125% of the request. Curtis said from a Qwest perspective, it is not related to the draw either. Ross Nielsen – PAETEC asked if this is new regulation that is getting pushed down, will it come back up. Curtis Ashton – Qwest it is not a regulation issue. In many cases, when Qwest reused the feeder, or the feeder was decreased in size, the question was whether we can reuse the cable and the protector. This clarifies that we can reuse the protector if it is not more than 200% of the new request. Ross Nielsen – PAETEC said he wanted to insure that it was not an actual draw. Curtis Ashton – Qwest confirmed that was correct, it is based on the CLEC request. Patrick Phipps – QSI/PAETEC said the wording “ultimate expected” current is confusing or inaccurate. List 2 is the worst case scenario draw. Curtis Ashton – Qwest questioned if he took out “ultimate expected”, would that help? Curtis asked for alternate verbiage. Patrick Phipps – QSI/PAETEC said THE PROPOSED REFERENCE TO “CLEC REQUEST” IN SECTION 9.5 it does not seem to ADD do anything. Qwest equates a CLEC POWER feed ORDER to a List 2 DRAIN requirement. Curtis Ashton – Qwest said he will remove “peak current”. He said peak current meant “start up” current. Patrick Phipps – QSI/PAETEC said this is a situation where two reasonable people disagree. In the Iowa case, the court found that Qwest equates A CLEC POWER FEED the order to the list 2 drain. Doug Denney – Integra said he had a question on CLEC DC Power reduction, does Qwest change the fuses? Curtis Ashton – Qwest then said it was a good question and provided an example. If the CLEC originally ordered 90 amps, the fuse protector would be 125 amps. If the customer downsized to 65 amps, then 90 amps is the proper protector (closest to 125%) however Qwest only requires it to be less than 200%. In this case, the 125 amp protector is less than 200% of the 65 amp order so no change is required. There is a small window that does not have to be changed. Julia Redman-Carter - PAETEC ASKED THE PAETEC WHETHER said we need to be specific as to when the CLEC doES and does not need to make a change and questioned whether there was any need to clarify the language due to the discussion. Curtis Ashton – Qwest said this section applies to both equally – when downsizing or upsizing between 125 and 200%. Julia Redman-Carter - PAETEC questioned if that was the only time to change fuse and if that was what Doug was talking about. Ross Nielsen - PAETEC said this does not deal with plant but deals with cable. The 125 - 200% is clear. There is no need to deal with changing the language. He said that the one thing that is confusing is List 2 drain or CLEC request. Curtis Ashton – Qwest said it is List 2 drain for Qwest or the request for CLECs.

Ross Nielsen - PAETEC questioned even if the CLEC downsizes the order, the cable does not have to change?

Curtis Ashton – Qwest said that was a good question. Not every fuse position is capable of accepting the new fuse size. In a lot of situations, even when we do not have to run cable to a new power distribution board, we have to change the drop cable to reach the new fuse position. It is generally right that the main cable run does not change. Patrick Phipps – QSI/PAETEC said add clarifying language. T the trouble with the change is that BY REFERRING TO it is list 2 drain or CLEC request whichever is applicable, THE LANGUAGE. It is a problem to createS a distinction between Qwest’S EQUIPMENT and the CLEC equipment. Access should not be denied based on the owner of the equipment.

Curtis Ashton – Qwest said he would leave in whichever is “applicable”. He said he does want to make a change to be distinct. Curtis Ashton – Qwest next addressed the change that shows differences between local and national later in Section 9.5 where Qwest inserted “(or 1.88 for NNS sites)” which was added for National Network Sites.

At the end of Section 9.6, there was one other change to add the wording “for Qwest equipment” to clarify allowing estimation for a List 1 drain. 04-15-10 NOTE FROM QWEST IN REGARD TO THE REDLINED MEETING MINUTES: FOR READABILITY, THE FOLLOWING PARAGRAPH PROVIDES A STRIKETHROUGH VERSION OF THE MINUTES AS QWEST CAPTURED THEM. THE NEXT PARAGRAPH PROVIDES THE SAME PARAGRAPH AND THE ADDITIONS FROM PAETEC IN ALL CAPS.

STRIKE THROUGH PARAGRAPH Patrick Phipps – QSI/PAETEC then addressed his objection associated with the change toward the end of Section 9.6 which stems from the dispute related to estimating List 1 drains. Patrick then provided an explanation of the contention between Qwest and PAETEC. He relayed that problem is that some of Qwest technical document conflicts with other technical documents but these are filed as “confidential” in Iowa. He said there is nothing in the industry documents that justifies the difference. In Qwest’s previously filed testimony, it was ruled and upheld that estimation could be done for CLECs. He pointed to an AT&T document in another jurisdiction that allows estimating of CLEC List 1 drains. Patrick said Curtis said it could not be estimated, and now Qwest is trying to make the change to support a public policy position and codify language in the Tech Pub that supports treating CLECs differently. Patrick said he disagrees with Qwest’s later testimony that it should not be done.

Patrick Phipps – QSI/PAETEC then addressed his objection associated with the change toward the end of Section 9.6 WHERE QWEST PROPOSES CHANGES INDICATING THAT QWEST CAN ESTIMATE LIST 1 DRAIN ONLY FOR QWEST EQUIPMENT (PRESUMABLY EXCLUDING CLEC EQUIPMENT). Patrick then explained THAT THIS ISSUE IS IMPORTANT BECAUSE IT WAS ADDRESSED IN THE COMPLAINT PROCEEDINGS INVOLVING Qwest and PAETEC RELATED TO DC POWER. He DESCRIBED FOUR PRIMARY PROBLEMS WITH QWEST’S PROPOSED LANGUAGE REGARDING ESTIMATING LIST 1 DRAINS. FIRST, QWEST’S PROPOSED LANGUAGE THAT WOULD EXCLUDE CLEC EQUIPMENT FROM THIS ESTIMATION METHOD CONFLICTS WITH OTHER Qwest technical documentATION THAT QWEST filed as “confidential” in Iowa. SECOND, QWEST’S PROPOSED LANGUAGE HAS NO BASIS IN TELCORDIA GR-513, WHICH MAKES NO SUCH DISTINCTION BETWEEN QWEST EQUIPMENT AND CLEC EQUIPMENT. THIRD, QWEST’S PROPOSED LANGUAGE CONFLICTS WITH PRIOR QWEST TESTIMONY SUBMITTED IN IOWA WHICH INDICATED THAT LIST 1 DRAIN CAN BE ESTIMATED AND MADE NO DISTINCTION ABOUT EQUIPMENT OWNERSHIP. HE ADDED THAT it was ruled and upheld IN IOWA that estimation could be done for CLECs. FOURTH, QWEST’S PROPOSED LANGUAGE CONFLICTS WITH TECHNICAL PUBLICATIONS OF OTHER ILECS, SUCH AS AT&T. He pointed to an AT&T document in another jurisdiction that allows estimating of CLEC List 1 drains. Patrick said THAT AFTER MR. ASHTON TOOK OVER THE WITNESSING DUTIES ON THE DC POWER ISSUES IN THE COMPLAINT PROCEEDINGS BETWEEN QWEST AND MCLEODUSA, MR. ASHTON BEGAN CLAIMING THAT QWEST COULD ONLY ESTIMATE LIST 1 DRAIN FOR ITS OWN EQUIPMENT AND COULD NOT estimate LIST 1 DRAIN FOR CLEC EQUIPMENT. Patrick said he disagrees with Qwest’s later testimony that it should not be done. PATRICK ADDED THAT QWEST IS APPARENTLY ATTEMPTING TO MATCH UP ITS TECHNICAL PUBLICATIONS WITH THE ADVOCACY POSITION MR. ASHTON IS TAKING IN LITIGATED PROCEEDINGS, and codify language in the Tech Pub that ATTEMPTS TO JUSTIFY QWEST treating CLECs differently THAN ITSELF IN RELATION TO DC POWER. HE ADDED THAT THIS DIFFERENT TREATMENT WOULD RESULT IN HIGHER COSTS FOR CLECS, OR IN OTHER WORDS, THIS IS QWEST’S ATTEMPT TO JUSTIFY DISCRIMINATORY TREATMENT OF CLECS. Curtis Ashton – Qwest responded that he had eight separate legal cases in six states. He knows what Iowa found but it was found differently in different states. Curtis said WE COULD CHOOSE ONE OF TWO OPTIONS:the issue is either leave the language the way it is or remove the sentence around estimating entirely. He said GR-513 does not talk about estimates. Patrick Phipps – QSI/PAETEC said he does not want to risk sharing confidential information, SO HE COULD NOT DESCRIBE IN ANY LEVEL OF DETAIL THE DOCUMENT FROM IOWA THAT CONFLICTS WITH QWEST’S PROPOSED CHANGE TO SECTION 9.6. HOWEVER, HE EXPLAINED THAT Either Qwest can estimate List 1 drains or IT they cannot, AND SINCE ITS CURRENT LANGUAGE INDICATES THAT IT CAN ESTIMATE LIST 1 DRAINS, IT MAKES NO SENSE TO ENTIRELY DELETE That it cannot be both ways. Why take out the requirement. Curtis Ashton - Qwest explained when estimation is done which is almost never. He relayed Qwest sizes based on testing done in the lab. He said he was OK to take out the language since it is not necessary because Qwest is not going to estimate. He offered both options. Patrick Phipps – QSI/PAETEC said that is a false choice: I.E., WHETHER TO LEAVE IN QWEST’S PROPOSED LANGUAGE “FOR QWEST EQUIPMENT” OR DELETE THE SENTENCE ABOUT ESTIMATING LIST 1 DRAIN ALTOGETHER. Currently he had no position since both are equally problematic. Julia Redman-Carter - PAETEC described Patrick’s and Curtis’s points AND SUMMARIZED HER POSITION. IT APPEARS THAT CHANGES TO THE GR-513 NOR ANY OTHER INDUSTRY STANDARD PROVIDES AN OBJECTIVE BASIS FOR CHANGING THIS SENTENCE. AND TO MAKE EITHER OF CHANGES THAT QWEST IS PROPOSING WOULD BE BASED SOLELY ON QWEST’S ADVOCACY AND NOT ON ANY OBJECTIVE STANDARD. IF, INDEED, THE PRACTICE OF “ESTIMATING” HAS NOT BEEN DONE FOR A WHILE AND THE LANGUAGE HAS NOT IMPEDED QWEST’S ACTIONS; AND QWEST HAS NOT HAD A REASON PROPOSE A LANGUAGE CHANGE BEFORE NOW, THEN THERE SHOULD BE NO HARM IN LEAVING THE LANGUAGE AS IT IS. and said ACCORDINLY, PAETEC wants the language to stay as it is WITHOUT ANY REDLINED CHANGES. Curtis Ashton – Qwest said estimating is done sparingly or never and occurs. In the 1993-1996 timeframe, it may have been done but Qwest never estimates anymore because we now have labs to test for true list 1 drains so the sentence is obsolete. Patrick Phipps – QSI/PAETEC said QWEST’S OPINION THAT THIS LANGUAGE IS it only became obsolete due to CAME ONLY AFTER THE court cases and that DECISION IN IOWA; IF THE SENTENCE WAS ACTUALLY OBSOLETE, there has been ample time FOR QWEST to change it previously. It is now being changed to support Qwest advocacy. Julia Redman-Carter - PAETEC said for the record she wanted the language to remain as is. No redline changes for the reasons stated. Curtis Ashton – Qwest said that Qwest would decide what they wanted to do. He then addressed the remaining review of the changes to the Tech Pub. He questioned the process for CLEC final review. Susan Lorence – Qwest said the CLECs would have a chance to formally review the changes and comment during the CLEC comment cycle as part of the CMP notice or that we could have another ad hoc meting to review the additional changes. Julia Redman-Carter - PAETEC said she would like to see the changes before the formal comment cycle begins. Susan Lorence – Qwest said that is not following the CMP process to have an extended comment cycle. Julia Redman-Carter - PAETEC again said she wanted to see the language first AND THOUGHT but that we may not need another ad hoc meeting. BUT THAT COULD BE DETERMINED BETTER AT THE END OF THIS CALL. Curtis Ashton – Qwest then continued the review of the remaining changes starting at the last change in Section 9.6. Curtis said this change exempted CLECs from fuse coordination. Ross Nielsen - PAETEC asked for clarification that this is not just because Qwest can’t control CLEC fuse size. The previous discussion also relates to this. Curtis Ashton – Qwest said that is correct. That is also the reason for the change. Curtis Ashton –Qwest then reviewed the changes in Chapter 12.2 Curtis explained the difference between emergency and clarified that task lighting is only required in buildings larger than 500 square feet so the technician does not have to hold the flashlight in their teeth. Curtis Ashton –Qwest then reviewed the changes in Chapter 13 where he clarified the Title in the tables in Part 1A and 1B apply to lead acid batteries. Previously only the voltage range was provided. In Table Part 1B, clarification was also added that this applies to batteries at a normal temperature. When outside where the temperature varies a lot, this helps protect them from thermal runaway. These are temperature compensated. In regard to Table 1C, the word “Thresholds” was added to make it clearer. In the next paragraph where there were changes, Curtis said he clarified what constant current charging means. In Table 13-5, Part 1D, Curtis relayed Qwest is just starting to deploy lithium batteries and that we are learning as we go. These changes provide additional information. In Section 13-5, Part 2, new information was added for low gravity cells which have similar thresholds to the old 23 cell strings. A new paragraph was added here also to clarify how temperature compensation should be done. In Table 13-7, a standard message was added for surge arrestor. Qwest is just starting to deploy SNMP protocol in outside plant power equipment. This is not in COs yet but is also in the customer premises world. Curtis Ashton –Qwest then reviewed the changes in Chapter 16. This chapter covers the definitions and acronyms used in the document and Curtis said he added a couple acronyms that were added to the text in the last 10 years or so but not defined. Patrick Phipps – QSI/PAETEC questioned whether the ones added were the ones shown in red. Was just OSHA added? There were no definitions shown as redline. Curtis Ashton – Qwest said that was good point. Some of the changes were shown in redline but really were not added. When he was redoing this section and some of the tables, the pages were split and now show as redline but the updates are not really added. Curtis said the only one added was ONU – Optical Network Unit. Curtis Ashton – Qwest then went to Chapter 17 where he added GR-513. Patrick Phipps – QSI/PAETEC said he takes exception TO with this change as he did not see the basis for it. QWEST’S PROPOSED DEFINITIONS OF LIST 1 AND LIST 2 DRAIN, AS WELL AS QWEST’S PROPOSED CHANGES TO DISTINGUISH QWEST EQUIPMENT FROM CLEC EQUIPMENT HAVE NO BASIS IN TELCORDIA GR-513. Curtis Ashton – Qwest said he did not copy the document word for word. There documents are used as seed docs to build the Tech pubs. Julia Redman-Carter- PAETEC questioned the reason why the LSS GR section 13 was added. Curtis Ashton – Qwest said it was part of the actual title of the document and it is part of a bigger family of documents. Curtis Ashton – Qwest said he now wanted to go back to Section 2.4 where he used GR-513. He said that the language that Qwest used here in certain sections follows the spirit of the document but does not quote the document exactly. For example, AT&T added language to GR-513 about list 2x drains but Qwest does not use these so did not put them in.

04-15-10 NOTE FROM QWEST IN REGARD TO THE REDLINED MEETING MINUTES: FOR READABILITY, THE FOLLOWING PARAGRAPH PROVIDES A STRIKETHROUGH VERSION OF THE MINUTES AS QWEST CAPTURED THEM. THE NEXT PARAGRAPH PROVIDES THE SAME PARAGRAPH AND THE ADDITIONS FROM PAETEC IN ALL CAPS. SEE WHOLESALE CALENDAR FOR VERSION WITH STRIKETHROUGH.

STRIKETHROUGH PARAGRAPHPatrick Phipps – QSI/PAETEC said in Section 2.4, he would first like to explain his concerns. Patrick described the concerns that have been brought up previously in this meeting and other arenas in regard to how the Qwest changes in this Tech Pub are an attempt to justify discrimination against the CLEC community and define List 1 drains differently for Qwest vs. the CLECs. He went into his concerns of why this causes the CLECs to pay more than Qwest does. In Iowa, Patrick stated that PAETEC showed no basis for the differences yet Qwest proposed different language for drains. Patrick relayed that Qwest said it would insert verbatim the GR-513 language but did not. Patrick said the new/specific changes that Qwest provided are generally accurate but that he objected to the wording in the old third paragraph that allows Qwest to treat CLECs differently. He said he needed to think about what to do in that paragraph but that dropping it was a good thing. He said the second set of changes were more problematic than the first set. The second set said Qwest will size to CLEC equipment which is a big problem for PAETEC and so he disagrees with both changes to Section 2.4. Patrick stated that Qwest has an obligation to provide non-discriminatory access to power and per the ICA, Section 2.4 updates violate that. His final point was if Qwest insists on making the changes then he just wants language added that states that CLECs won’t pay higher costs for power than Qwest.

Patrick Phipps – QSI/PAETEC said in Section 2.4, he would first like to explain his concerns. Patrick STATED THAT QWEST’S PROPOSED LANGUAGE FOR SECTION 2.4 (BOTH SETS OF QWEST REVISIONS), LIKE QWEST’S PROPOSED LANGUAGE IN SECTION 9.6, IS an attempt BY QWEST to justify discrimination against the CLEC community. HE SAID THIS IS PLAIN TO SEE BECAUSE QWEST’S LANGUAGE ATTEMPTS TO DEFINE LIST 1 DRAIN DIFFERENTLY FOR QWEST’S EQUIPMENT THAN FOR CLEC EQUIPMENT. HE EXPLAINED THAT IN LITIGATED PROCEEDINGS, QWEST HAS ATTEMPTED TO JUSTIFY ITS APPLICATION OF DC POWER RATES TO AMPS OF ORDERED CABLE CAPACITY BY CLAIMING THAT QWEST SIZES POWER PLANT DIFFERENTLY FOR CLECS THAN IT DOES FOR QWEST’S OWN EQUIPMENT (I.E., QWEST CLAIMS IT SIZES POWER PLANT TO LIST 1 DRAIN FOR ITSELF AND TO ORDERED CABLE CAPACITY – REPRESENTING A HIGHER LIST 2 DRAIN – FOR CLECS). SINCE LIST 2 DRAIN IS SIGNIFICANTLY HIGHER THAN LIST 1 DRAIN, QWEST’S LOGIC RESULTS IN CLECS PAYING SIGNIFICANTLY more for DC power than Qwest PAYS. In Iowa, Patrick stated that PAETEC showed THAT QWEST DID NOT ACTUALLY SIZE POWER PLANT TO CLEC POWER CABLE ORDERS, AND AS SUCH, THERE IS no basis for TREATING CLECS differenTLY IN THIS REGARD OR FOR Qwest’’S proposed language THAT DEFINES LIST 1 DRAIN DIFFERENTLY DEPENDING ON THE OWNERSHIP OF EQUIPMENT. Patrick STATED THAT THERE IS NO BASIS FOR QWEST’S PROPOSED LANGUAGE IN EXISTING TECHNICAL PUBLICATIONS OR INDUSTRY STANDARDS, INCLUDING THE TELCORDIA GR-513, AND THE FACT THAT QWEST’S PROPOSED LANGUAGE IN SECTION 2.4 DIFFERS FROM THE DEFINITION IN TELCORDIA GR-513 SHOWS THAT QWEST’S PROPOSED CHANGES CONFLICT WITH THE MOST RECENT INDUSTRY STANDARDS. HE ADDED THAT AT THE PRIOR MEETING, Qwest said it would insert verbatim the GR-513 DEFINITION OF LIST 1 DRAIN but did not DO SO. Patrick said QWEST’S second set of changes TO THIS SECTION Are more problematic than QWEST’S first set OF CHANGES. WHEREAS IN QWEST’S FIRST SET OF REVISIONS, QWEST PROPOSED DEFINITIONS OF LIST 1 AND LIST 2 DRAIN THAT WERE generally accurate AND CONCENTRATED THE LANGUAGE MOST OBJECTIONABLE TO CLECS IN A SEPARATE third paragraph, QWEST’S SECOND SET OF REVISIONS RE-DEFINE LIST 1 DRAIN TO INCLUDE THE OBJECTIONABLE LANGUAGE IN THE DEFINITION ITSELF. AS SUCH, he disagrees with both SETS OF QWEST’S changes to Section 2.4. Patrick stated that Qwest has an obligation to provide non-discriminatory access to power UNDER THE ACT and per the ICA, WHICH REQUIRES QWEST TO PROVIDE DC POWER TO CLECS AT RATES, TERMS AND CONDITIONS THAT ARE EQUAL TO HOW QWEST PROVIDES DC POWER TO ITSELF; QWEST’S PROPOSED Section 2.4 updates violate that. His final point was if Qwest insists on making changes THAT COULD RESULT IN QWEST TREATING CLECS DIFFERENTLY THAN ITSELF FOR DC POWER, then QWEST SHOULD, AT A MINIMUM, ALSO ADD LANGUAGE INDICATING that CLECs won’t pay higher costs for power than Qwest. Curtis Ashton – Qwest said to start off with, PAETEC revised the minutes from the first meeting and added a lot of detail that Qwest did not capture word for word and that they must have a better memory then he had. Curtis said there is a continued reference to Iowa and he wanted to make something clear, he/Qwest has no intention of discriminating - and emphasized EVER – against the CLEC. He said Patrick was correct in what was relayed about Iowa but Curtis said Arizona found exactly the opposite. Curtis reiterated that Qwest would not discriminate against the CLECS and that Patrick relayed the Tech pub changes would allow Qwest to treat CLECs differently but he said the updates do not address CLECs at all. Curtis said he was leaving things positively open since every state has different rate cases and that Qwest has to follow each.of the 14 states. Patrick Phipps – QSI/PAETEC stated that QWEST’S SUGGESTION THAT ITS ENGINEERS USE A COST DOCKET ORDER FROM A STATE PUC TO SIZE POWER PLANT CAPACITY IN THE REAL WORLD IS FRANKLY HARD TO BELIEVE AND MAKES NO SENSE.never shared that the cost docket requires Qwest to size in a certain way. Qwest needs to charge in different ways. He said this is where two reasonable people disagree. Curtis Ashton – Qwest said he drastically changed the first paragraph and was there anything in the first paragraph that could stay. Patrick Phipps – QSI/PAETEC said he would have to look BECAUSE HE HAD NOT PERFORMED A LINE-BY-LINE COMPARISON OF QWEST’S SECOND SET OF REVISIONS TO THE TELCORDIA GR-513 DEFINITION – major concerns. Curtis Ashton – Qwest said he did not want to vary too far. Patrick Phipps – QSI/PAETEC said when you got past the first paragraph things looked very similar. Curtis Ashton – Qwest questioned whether it was OK to remove “serve Qwest equipment” and wondered if there was a need for another opportunity to do a stare and compare of the document updates. Patrick Phipps – QSI/PAETEC said that was fair. Curtis Ashton – Qwest questioned what to do about List 2 drains. Patrick Phipps – QSI/PAETEC said he had not had the time to review and was not prepared to comment. He said thereAT QWEST’S PROPOSED DEFINITION OF LIST 2 DRAIN APPEARS TO BE was lots of similarity to GR-513 but wanted to reserve comment. Curtis Ashton – Qwest suggested a short meeting in the future to review the updates. Patrick Phipps – QSI/PAETEC said he did have comments but they are not on list 2 drains. It was clear that Qwest would interpret A CLEC POWER CABLE ORDER as A list 2 DRAIN REQUIRMENT (or, AS MR. ASHTON HAS PUT IT, A proxy FOR LIST 2 DRAIN). Patrick then focused on List 1 drain. Julia Redman-Carter- PAETEC said she needed to look again at the updates. Curtis Ashton – Qwest said in Section 9.2 we needed to look at the formula. Curtis said Ross Nielsen – PAETEC said during the last meeting that the formula “I” needed to be broken out and listed as bullets. Curtis wondered if anyone had any comments on what had been done there. Julia Redman-Carter- PAETEC said she was not sure everyone saw the language. Ross Nielsen - PAETEC said he pulled the version off the calendar. Does the hour discharge rate apply only to battery cable sizing? Otherwise he had no problems with this. Curtis Ashton – Qwest said good point. Julia Redman-Carter- PAETEC questioned whether the bullets corresponded to the big paragraphs BELOW THE BULLETS and asked if they were in the same order. Curtis Ashton – Qwest said more detail is provided below but they were not in the same order. Julia Redman-Carter - PAETEC ASKED said on the paragraph below, FOR EXAMPLE, the second bullet, I cannot tell which drain PROXY is the applicable one AND I DON’T BELIEVE THAT THEY ARE INTERCHANGEABLE. WOULD ANY TECH They can BE ABLE TO derive THE CORRECT PROXY TO BE USED FROM the information BELOW?. Curtis Ashton – Qwest said he thought so. Curtis Ashton – Qwest said he could propose the review and finalization of the changes in two ways: 1) Submit the level 4 and allow the comment period, or 2) Schedule another short ad hoc call to review. Julia Redman-Carter- PAETEC said she preferred a short 30 minute call to review section 2.4 updates and the next set of changes. Susan Lorence – Qwest said she would like to get the remaining questions ahead of time to insure we specifically addressed them in the time period. Julia Redman-Carter- PAETEC said she was not sure that was possible but could identify the sections. Susan Lorence – Qwest said she rather then leaving it open, that we would like to have them in advance. Julia Redman-Carter- PAETEC said she THOUGHT WE MIGHT BE ABLE TO PROVIDE SOME QUESTIONS, AND Would like to see the final redlines of the Tech Pub. HOWEVER, OUR DECISION NOT TO PROVIDE QUESTIONS IS NOT TO LIMIT OUR DISCUSSION OR OUR ABILITY TO ADDRESS ANY OF THE LANGUAGE CHANGES PROPOSED IN THE NEXT AD HOC MEETING. Susan Lorence – Qwest said we would send those out with the meeting minutes and then schedule a short ad hoc call ABOUT five days later. Patrick Phipps – QSI/PAETEC said he had two ADDITIONAL issues as far as the final version of the Tech Pub: 1) Insure theAT ANY updates regarding “CLEC REQUEST” OR “CLEC ORDER” CLARIFY THAT IT IS cable sizing for CLECs always referRING to the “CLEC power feed order”, and 2) Suggest in the Notice section of the document, that the changes for 2010 are clearly delineated from what was there since 1996. He said there needed to be a history log of the changes made in 2010, ESPECIALLY FOR ANY CHANGES QWEST IMPLEMENTS REGARDING LIST 1/LIST 2 DRAINS. Curtis Ashton – Qwest said to look at Section 1.2, Reason for Reissue. He questioned whether that would be a better place to identify the changes than the Notice section. Patrick Phipps – QSI/PAETEC said it was a good suggestion and agreed TO CONSIDER HOW BEST TO INCORPORATE THIS LANGUAGE. Curtis Ashton – Qwest requested attendees to review the language of Section 1.2, Reason for Reissue, and propose what to put there.

03-19-10 Ad hoc meeting minutes APRIL 1, 2010 NOTE: THE REDLINED EDITS TO THE DRAFT MEETING MINUTES THAT WERE PROVIDED BY PAETEC HAVE BEEN INCLUDED IN CAPS/BOLD OR ARE IDENTIFIED WITH STRIKETHROUGH. SEE WHOLESALE CALENDAR FOR VERSION WITH STRIKETHROUGH.

Attendees: Julia Redman-Carter-PAETEC, Patrick Phipps – QSI Consulting, Inc. (on behalf of PAETEC), Diane Bowers – PAETEC, Al Finnell – PAETEC, Bryan Vanyo – PAETEC, Ross Nielsen – PAETEC, Bonnie Johnson - Integra, Kim Isaacs – Integra, Rebecca Beaton – Washington Commission, Eugene Evans - New Mexico Commission, Carolee Hall – Idaho Commission, Curtis Ashton - Qwest, John Hansen - Qwest, Susan Lorence - Qwest

Susan Lorence – Qwest relayed that the last ad hoc call had been held on March 8, 2010. During that call, we agreed that another ad hoc call was necessary to review the remainder of the document and any updates that Curtis Ashton – Qwest would make based on the discussion in the last call. Susan relayed a revised version of the Tech Pub was posted to the calendar.

Curtis Ashton – Qwest relayed that he had a discussion with legal and discussed the paragraph that was of most concern. He said he had removed some content from Section 2.4 and made changes to List 1 and 2 drains to follow the spirit of GR-513. Curtis said he would start where we left off and then go back to the changes that were made. Curtis Ashton – Qwest relayed in the section regarding sizing the rectifier plant, the acronym NNS was defined since it was the first time it occurred. NNS is the unregulated side of Qwest as opposed to the regulated side. Ross Nielsen – PAETEC asked about sizing the rectifier plant and whether it was based on the actual load. He questioned when sizing the rectifier, is Qwest going by the actual List 1 load. Julia Redman-Carter - PAETEC questioned if it is possible to make a clarification to the language ADDRESSING THIS. Curtis Ashton – Qwest identified it is as being the busy hour load. Ross Nielsen – PAETEC said he suspected it was based on battery busy hour load and that he was OK with that. Julia Redman-Carter PAETEC said if Ross Nielsen (PAETEC) was good WITH THE LANGUAGE, she was good. Curtis Ashton – Qwest said the next area of change is section 2.6 just below the bulleted items. The update is to clarify that there can be more than one power plant controller when adding newer switch mode rectifiers to a Ferro resonant plant. Curtis said rather than replace whole power plant, it was more economical to grow the plant with switch mode. Curtis said the switch mode required its own controller. There is still a master conventional controller for Ferro resonant rectifiers but there is now a separate sub-controller for the switch modes. He confirmed one master controller is common. Curtis said he can internally mix rectifier plants. Ross Nielsen - PAETEC questioned whether we were really talking separate power plants or parallel. Curtis Ashton – Qwest said in a way, two types of power plant are paralleled: One master and one sub controller. CURTIS ASHTON – QWEST SAID THAT Section 3.6 associated with Battery Types was discussed next – associated with Nickel Cadmium. Curtis Ashton-Qwest said Nickel Cadmium batteries used to be only deployed in engine start applications but are now placed in desert outdoor locations due to longer life. In regard to the section on Lithium, Curtis said he removed all references to Lithium metal polymer batteries since they are no longer commercially available. Curtis said that there was also a change to indicate that Li-ion batteries do not need to be cylindrically wound but can be rectangular as well. Next Curtis Ashton – Qwest NEXTsaid that he added a paragraph on Super Ultra Capacitors. He said they are not new and are generally used for short backup purposes.

Patrick Phipps – QSI/PAETEC questioned whether this was a paragraph that was moved from later pages and Curtis said yes.

Curtis Ashton – Qwest SAID YES. HE next addressed the change at the end of Section 3.9 where he deleted a paragraph. He said he removed it because there was no reason to include it since the information was already in Figure 3.2 and in Chapter 9. The change to Section 3.10 was to add the word “lead-acid” for clarification on end voltage because lithium and NiCd have different numbers. Julia Redman-Carter - PAETEC said she noticed the capitalization of the word ampacity was changed. Curtis ASHTON - QWEST provided some history on the term ampere and relayed that both capitalized and not capitalized usage is correct. Julia Redman-Carter- PAETEC questioned was there a definition ASSOCIATED WITH THE CAPITALIZATION OF THE TERM ‘AMPACITY’ that was deleted or adjusted. Curtis Ashton – Qwest relayed no and that ampacity refers to how much current cables or bus bars can carry before becoming too warm. Eugene Evans – New Mexico Commission questioned whether it was just an engineering correctionand Curtis said no, it was more a grammatical correction. Curtis Ashton – Qwest SAID NO, IT WAS MORE A GRAMMATICAL CORRECTION. HE said the next change is Section 6.3.to clarify that the fuse and breaker coordination is Qwest responsibility. Patrick Phipps – QSI/PAETEC agreed it was Qwest responsibility and questioned whether thE FUSE COORDINATION LANGUAGE is was associated with all fuses between collocation and power plant. HE INDICATED IT WAS HIS UNDERSTANDING THAT QWEST WOULD SIZE FUSES WITHIN ITS CONTROL AND A CLEC WOULD SIZE THE FUSE WITHIN ITS CONTROL. Curtis agreed that it is Qwest responsibility to coordinate all fuses within their control not the CLECs. Patrick Phipps – QSI/PAETEC said it is the CLEC responsibility to size the 1st fuse within their control. Curtis Ashton - Qwest said the NEC code requires fuse coordination for certain systems and but even where not required, it is a good practice. Patrick Phipps – QSI/PAETEC said GR-513 talks of fusing coordination but does not make a distinction between the CLEC and Qwest. Curtis Ashton – Qwest said there is no external legal requirement to coordinate; it is only a Qwest requirement. Qwest coordinates all Qwest owned fuses and breakers. Patrick Phipps – QSI/PAETEC identified the issue is the smallest fuse will blow first. Curtis Ashton – Qwest said that was correct and it is to minimize the impact of an outage. Curtis Ashton – Qwest then reviewed Section 8.2.1 which talks to the required points that will be monitored. Curtis said this only applies to new points; Qwest cannot retroactively fix old. When put in new, points are required to monitor alarms. There is one minor change associated with collocation circuits at power board; it used to say 75 which is not consistent. The current wording took 125% of 60 amps, which is not true. You really need to take 125% of 61 amps. Curtis said the language was contradictory and was a math error. Curtis Ashton – Qwest then discussed changes toward the end of Section 8.2.3. He said that the updates were made to provide additional clarification. In a Battery String Disconnect, you don’t have to monitor individual breakers, you can daisy chain them. You just need to know the breaker is tripped. Curtis also said two binary points were added for little Li-ion smart batteries. Lead acid is not smart. Two points were added for major and minor alarms. Curtis Ashton – Qwest said for changes in Section 8.5, Qwest does not generally allow power monitors to start and stop rectifiers because Qwest does not want two controllers fighting each other. There needs to be an exception for large sites. Curtis relayed for some sites that are co-owned with AT&T, they do have some sequence of rectifier start due to the size of engines. This rectifier sequencing is to allow power to come up slowly. The next section Curtis Ashton – Qwest SAID THE NEXT SECTION discussed was Section 8.6.3 where clarification was added associated with cell temperature. If the plant is already measuring, you don’t have to run more probes. Curtis also said that at the end of this section, a statement was repeated regarding the Disconnect breaker that they can be daisy chained. Curtis Ashton – Qwest then addressed the change in Section 9.2 where there was a clarification regarding the formula for calculating Voltage drop that is already covered in the next two pages. Curtis relayed “I” defines amperes and sometimes is the List 2 drain and sometimes not. For example, between the chandelier and the return bus, this size of the shunt is used. Curtis said this is obviously of most concern. To size the voltage drop for the CLEC order is based on the CLEC order. Patrick Phipps – QSI/PAETEC questioned the CLEC order, what order? Curtis Ashton – Qwest relayed that it was the CLEC power feed order and will clarify that. Patrick Phipps – QSI/PAETEC said the only observation is that Qwest interprets the power feed order as List 2. Curtis Ashton – Qwest said that is sort of true; it is a proxy for List 2. Patrick Phipps – QSI/PAETEC SAID that QWEST’S PROPOSED the language IN SECTION 9.2 SHOWS THAT QWEST said collocation is generally interpretedS A CLEC POWER FEED ORDER as a List 2 drain requirement. Curtis Ashton – Qwest said to be clear, will use the term proxy. He said the only information that Qwest has is what is on the order. Patrick Phipps – QSI/PAETEC said the CLEC order raises red flags. He said that it does represent List 2 drains. He questioned if it is necessary. If it is a proxy for List 2 drain, the original language should be sufficient. Curtis Ashton – Qwest said Qwest does not know if it is a List 2 drain for CLECs. This is not a universal statement so the ordered amount is used as a proxy. It may or may not be a List 2 drain. Patrick Phipps – QSI/PAETEC said it must be. Curtis Ashton – Qwest said when sizing cable to a List 2 drain, it is easy to do for individual shelf feeds. When feeding upstream aggregation devices, such as a BDFB from a PBD, we don’t know what is going in in the future so there is no way to calculate List 2 drain upfront. Qwest has to use a proxy for List 2 drain. For a BDFB fused at 600 amps, we never load one side greater than 300 amps so proxies are not just for CLECs. They are also feeding secondary protection. It might be List 2 or it might be proxy. Many CLECs don’t know what their List 1 and List 2 are. Patrick Phipps – QSI/PAETEC said he did not know whether the bottom line is that this current represents a List 2 drain requirement. Tthe language is not clear AND NOT NECESSARY BECAUSE MR. ASHTON PREVIOUSLY TESTIFIED THAT QWEST INTERPRETS A . The CLEC POWER FEED order AS language is List 2 drain. Curtis Ashton – Qwest said he testified it is a proxy for a List 2 requirement. It is not clear. There is disagreement about whether CLEC power feed order is List 2 and by inserting CLEC, it makes clear what order we are talking about. If language goes in, Curtis said it needs to be specific to say CLEC power feed order. Ross Nielsen - PAETEC questioned when doing battery cable sizing for capacity, do you use two hour discharge? Curtis Ashton – Qwest said we use four hour discharge. Ross Nielsen - PAETEC said when feeding CLEC from BDFB, are you using the full CLEC order for voltage drop calculations. Curtis said yes when feeding CLEC owned BDFB. CURTIS ASHTON – QWEST SAID YES WHEN FEEDING CLEC OWNED BDFB. Ross Nielsen - PAETEC questioned on the CLEC voltage drop, do you have to use breaker size? Curtis Ashton – Qwest said we do two calculations for breaker size. The cable has ampacity. If 100 ampere order, if size for voltage drop, will size cable based on circular mills. Curtis said there is a 2nd check to insure that the ampacity meets or exceeds 350kcmil. In our example 100 amp order, if the voltage drop calculation required a 350 kcmil cable, we would then check to insure it equals at least 125 amps. Ross Nielsen - PAETEC said the key was to break out the “I” values to make them more clear. Curtis Ashton – Qwest said he had summarized it in a parenthetical. He said a better way would be to put sub- bullets under “I”. Ross Nielsen - PAETEC said three things come into play. The main thing is to break down between the elements. Curtis Ashton – Qwest said he would rewrite the section and send it out again. Julia Redman-Carter- PAETEC had a suggestion to have ampere represent List 2 drain. Half protector size, battery discharge rate: all are proxy for List 2 drain. She had a question whether it is appropriate if you have the actual List 2, use it. If List 2 is not available, use a proxy. Julia said it should specify what should be used in which scenario. Specify which proxy in which scenario. Patrick Phipps – QSI/PAETEC said the fact that Qwest interprets Power feed as List 2 NECESSARILY MEANS THAT QWEST, why would NOT you also size the power plant to the same. If QWEST INTERPRETS A take CLEC power feed order as List 2 drain, Qwest should not use THAT ORDER same drain to size the power plant. POWER FEEDS AND POWER PLANT These are sized to TWO different standards in all publications. The group decided a 1 ½ to 2 hour meeting was needed to finish the review. Patrick Phipps – QSI/PAETEC said the couple sections that were of PARTICULAR concern TO HIM are 2.4 and 9.6 and that HIS we need to focus IS on policy ISSUES AND NOT vs. engineering ISSUES. Susan Lorence - Qwest questioned whether we need to continue to review change by change or just go over those sections where there were concerns. Eugene Evans – New Mexico Commission said he was interested in where others had questions and thought it was best to go through line by line. Julia Redman-Carter- PAETEC said she was not an engineer but would prefer to go through line by line. Patrick Phipps – QSI/PAETEC reiterated that if Qwest is going to use CLEC power feed order as proxy for List 2 drains, Qwest should not also use this order to also size power plant components.

3/19/10 Additional EMAIL RESPONSE to Qwest from Integra/PAETEC associated with redline updates to Ad Hoc Meeting minutes for 3/8/10

Susan,

Though Qwest may believe that the “meeting minutes that Qwest captured for the March 8 call were … an accurate yet concise summarization of the discussion in the ad hoc call,” the revisions by PAETEC indicate otherwise. PAETEC found that the meeting minutes did not capture most of the “key points” that we made during the discussion, and what was captured tended to dilute and/or misstate the point. PAETEC disagrees with Qwest’s suggestion that PAETEC expanded on what we said in the meeting notes. Obviously since the minutes are not verbatim, its not “exactly what was said”, but all of the points added in the minutes were stated on the call. Based on the CMP document, we don’t expect “a verbatim transcript,” but the minutes should be reflective of the discussion. Again, PAETEC did not “expand content” in our redlines of Qwest’s meeting minutes. Unlike Qwest that omitted key details, PAETEC did not change the discussion or the context of the statements.

In response to your comment about litigation, PAETEC is especially concerned that the meeting minutes accurately reflect the actual conversation. In the recent complaints concerning this very issue of collocation power, Qwest cited its November 2003 CMP meeting minutes to claim that McLeodUSA should have known that Qwest was agreeing to only bill DC power usage based on a measurement of the CLEC’s power usage. However, the CMP meeting minutes on this topic also noted that Qwest told the CLECs that it would not require an ICA amendment for a CLEC to have measured usage. Yet, Qwest later changed its mind and insisted that CLECs in fact had to execute such an amendment, without any modification to the CMP minutes. Had a CLEC relied on the CMP minutes that included that inaccurate statement regarding the necessity of an ICA amendment, the CLEC would have reasonably believed that they were entitled to measured power without an ICA amendment. Thus, the accuracy of CMP minutes is critical seeing as though Qwest itself has shown a propensity to use them as proof as to what exactly was the debate between the Qwest and CLEC position, and what was or was not agreed to.

Finally, PAETEC and Integra agree that there continues to be disagreement as what constitutes meeting minutes. In the 4/13/07 Qwest CMP Oversight Committee meeting referenced below, Qwest’s stated; “Susan said that the intent was to capture action items and the end result. She said that in the past there was a difference in the detail Qwest provided on product/process and system meeting minutes and in good faith started providing detail for both.” Becky Quintana from the Colorado PUC, who was a part of the CMP redesign team, responded “…that she disagreed with the last statement. Meeting minutes from redesign and CMP have always been very detailed and did include ‘he said, she said’.”

Julia

3/19/10 EMAIL RESPONSE from Qwest to Integra/PAETEC associated with redline updates to Ad Hoc Meeting minutes for 3/8/10 Bonnie and Julia,

Unfortunately, based on your email, there continues to be disagreement on what constitutes “meeting minutes” from a CMP perspective – especially when there is litigation involved.

Section 3.2 of the CMP document states: 3.2 Meeting Minutes for Change Management Process Meetings Qwest will record and distribute meeting minutes for all Change Management Process meetings, unless otherwise noted in this CMP.

Qwest will summarize discussions in meeting minutes and include any revised documents such as issues, action items and statuses….

The meeting minutes that Qwest captured for the March 8 call were provided in good faith as an accurate yet concise summarization of the discussion in the ad hoc call. To suggest otherwise is very inappropriate. As required by CMP, the Qwest meeting minutes focused on capturing the key points of the discussion and were not intended to be a verbatim transcript of the entire discussion. Qwest disagrees that the intent of the discussion was lost. Nor was there any omission of detail in the minutes that was material in nature as you suggest.

As has been the Qwest process, we will include these redline revisions to these minutes by documenting the Integra/PAETEC changes in all caps. Because Qwest does not tape record meetings, we do not have the ability to verify the significantly expanded content that has been redlined. No one from Qwest that attended the March 8 call recalls that your edits reflect exactly what was said. However, we do have concern that what was said on the call has been considerably expanded in the redlined changes. That particular issue of elaborating on content is significant and was addressed in the 4/13/2007 CMP Oversight meeting minutes that were referenced in your email. Specifically, as Integra stated in that meeting, changing the discussion or the context of the statements is not appropriate.

Finally, there was agreement in the 4/13/2007 meeting minutes that summarization was fine as long as it was complete and accurate. Qwest believes the summarization was complete and accurate in the minutes that were submitted for review.

Going forward, as we have in the past, Qwest will continue to capture in a concise, accurate manner a summary of the discussion that occurs in CMP meetings. Susan Lorence

3/17/10 EMAIL RESPONSE from Integra/PAETEC associated with redline updates to Ad Hoc Meeting minutes for 3/8/10

Susan/Qwest/CMP, I am attaching the joint redlined changes for PAETEC and Integra. As you can see from the attached document, the changes were significant. PAETEC and Integra were quite surprised that Qwest failed to capture all or portions of complete conversations, or what Qwest did provide did not reflect the entire conversation so in some cases the intent of the comments were lost.

The CMP Oversight Committee discussed the level of detail Qwest was required to provide for ad-hoc call meeting minutes in a CMP Oversight meeting regarding CMP meeting minutes. Becky Quintana from the Colorado PUC, who attended CMP Redesign, commented on the level of detail Qwest should provide. You can find that discussion in the April 13, 2007 CMP Oversight Committee meeting minutes located on Qwest’s website at http://www.qwest.com/wholesale/cmp/escdisp.html.

While we understand the conversation was of a very technical nature, the omissions were material in nature. PAETEC and Integra would appreciate any effort Qwest could make to provide more complete and accurate minutes for the ad-hoc call scheduled for this Friday. As CLECs have communicated in the past, when you are talking, it is difficult to take notes. Thanks, Bonnie and Julia

3/17/10 Product/Process CMP Meeting Susan Lorence-Qwest relayed that there had been an ad hoc meeting on March 8, 2010. The meeting minutes were out for review and will be posted by Friday. The next ad hoc meeting is scheduled for 3/19 at 10AM MT. Susan relayed that Curtis Ashton–Qwest had provided a revised Tech Pub 77385 due to some follow-up from the ad hoc call. That document is posted to the Wholesale calendar.

March 8, 2010 Ad hoc meeting minutes

MARCH 19, 2010 NOTE: THE REDLINED EDITS TO THE DRAFT MEETING MINUTES THAT WERE PROVIDED BY INTEGRA AND PAETEC HAVE BEEN INCLUDED IN CAPS/BOLD OR ARE IDENTIFIED WITH STRIKETHROUGH. SEE WHOLESALE CALENDAR FOR VERSION WITH STRIKETHROUGH.

Attendees: Julia Redman-Carter-PAETEC, Patrick Phipps – QSI CONSULTING, INC.(ON BEHALF OF PAETEC), Diane Bowers – PAETEC, Robert Fuller – PAETEC, Jim Gabberd – PAETEC, Al Finnell – PAETEC, Bryan Vanyo – PAETEC, Ross Nielsen – PAETEC, Bonnie Johnson-Integra, Doug Denney – Integra, Rod Cox – TDS Metrocom, Joe Eldrege – Cbeyond, Loriann Burke – XO Communication, Warren Wendling – Colorado PUC, Suzanne Smith – Oregon PUC, Mike Ripperger – New Mexico Commission, Eugene Evan - New Mexico Commission, Mike McCarthy – Minnesota Dept. of Commerce, Greg Doyle - Minnesota Dept. of Commerce, Curtis Ashton-Qwest, John Hansen-Qwest, Susan Lorence-Qwest

Susan Lorence - Qwest began the meeting by relaying that Curtis Ashton from Qwest presented the Qwest CR PC020210-1 in the February CMP monthly meeting. The ad hoc meeting is to review the planned updates to Technical Publication (Tech Pub) 77385 which is posted to the Wholesale calendar entry in addition to an excerpt from Telcordia GR-513.

Bonnie Johnson – Integra SAID QWEST SENT OUT EXCERPTS OF THE GR-513 CHANGES AND asked if this was the only change being made in GR-513.

Curtis Ashton - Qwest said the document had been significantly expanded. It used to be a 15 page document and now is over a 70 page document.

Bonnie Johnson – Integra asked whether QWEST WAS MAKING ALL OF THE GR-513 CHANGES IN THE there were any other Tech Pubs that are impacted.

Curtis Ashton - Qwest said no, THISother Tech Pubs WAS were not impacted by the multiple changes proposed. Curtis relayed GR-513 covered more areas of power and said that the updates were driven to reflect power standards in AT&T, Qwest and Verizon Tech Pubs, like the AT&T 767-200. It was updated to include a consensus of standards and rules that already existed.

Curtis Ashton - Qwest provided additional background on this Tech Pub update. Last year, updates to Tech Pub 77385 were submitted via a Level 2 notification. Due to CLEC comments, each individual change was reviewed during various ad hoc meetings and it was jointly decided what should be a level 2, level 3 and finally a level 4 change. The level 4 changes were removed from the update last year and have been incorporated in this CR.

Curtis Ashton - Qwest began reviewing the updates by relaying that the primary changes were associated with List 1 and 2 drains. He said he would come back to the Reason for Reissue and began by reviewing Table 1-2 which he said is the same table but now has a title. The next area of review was Section 1.5 on page 1-7 associated with fuse coordination. The document already had fuse coordination in it. This really only applies to Qwest. Curtis said last year Chapter 9 was fixed but now Chapter 1 is being fixed.

Julia Redman-Carter - PAETEC questioned the added phrase “feeding Qwest equipment” and the position that CLECs are not treated differently THAN QWEST TREATS THEMSELVES OR IS and that Qwest CLARIFYING THAT IT is not imposing a Qwest requirement on CLEC equipment.

Patrick Phipps – PAETEC QUESTIONED THE LOCATION OF THE FUSES/BREAKERS AND WHETHER THEY WERE FUSES THAT QWEST OR THE CLEC CONTROLS AND said CLECs don’t have control over Qwest fuse siZe.

Curtis Ashton - Qwest said this is at the shelf on circuits that Qwest controls. Curtis said at the end of Section 1.5 on page 1-9 that the changed wording applies only to Qwest. It is a clarification to what would be allowed for Qwest equipment.

Curtis Ashton - Qwest then pointed to Section 2.4 associated with List 1 and 2 drain changes that the coalition addressed in GR-513. Curtis said in Section 1.7 that there is a Note that is being removed. He said the reasoning for removing the Note is that it was adequately covered in the table which gives a good summary of NEBS. The Note was redundant and not necessary to state in text.

Curtis Ashton –Qwest began discussion of Section 2.4. He said the GR was last issued in 1995 and it did not address the primary equipment deployed today. The change was made to reflect more than just POTS and better defines the criteria for List 1 and 2 drains.

Patrick Phipps – PAETEC questioned how the definitions compared to the previous edits.

Curtis Ashton - Qwest relayed the edits are the same as last year.

Patrick Phipps – PAETEC questioned if the purpose was to synch up with GR-513. NOTED THAT QWEST’S CHANGE REQUEST INDICATED THAT THE PURPOSE OF THESE UPDATES IS TO AGREE WITH TELCORDIA GR-513, WHICH WAS ISSUED IN EARLY 2010. PAETEC QUESTIONED HOW THE PURPOSE OF THESE UPDATES COULD BE RELATED TO TELCORDIA GR-513 (ISSUED IN EARLY 2010) WHEN QWEST INITIALLY PROPOSED THE SAME EDITS IN EARLY 2009 (BEFORE THE MOST RECENT VERSION OF TELCORDIA 513 WAS ISSUED).

Curtis Ashton - Qwest said work started on GR-513 in January 2009 but the final published version of GR-513 was not until January 2010. Qwest first started proposing the update to Tech Pub 77385 last March. Curtis said they say the same thing but GR-513 now has more wording. Curtis said he was willing to copy what GR-513 said.

Patrick Phipps – PAETEC said it is the decision of the engineers. There is a dispute between Qwest and PAETEC. The definition in GR-513 is not in the Tech Pub. He said there is good information in GR-513 that is not in the Qwest document. PAETEC NOTED THAT THE UPDATED DEFINITIONS OF LIST 1 AND LIST 2 DRAIN PROPOSED BY QWEST WERE NOT THE SAME DEFINITIONS AS IN TELCORDIA GR-513. PAETEC QUESTIONED WHY QWEST’S DEFINITIONS WOULD BE DIFFERENT THAN THE DEFINITIONS IN TELCORDIA GR-513 IF THE PURPOSE OF THE UPDATES IS TO AGREE WITH GR-513. PAETEC NOTED THAT THE CONCEPTS OF LIST 1 DRAIN AND LIST 2 DRAIN ARE PART AND PARCEL OF LITIGATED PROCEEDINGS BETWEEN QWEST AND CLECS RELATED TO DIRECT CURRENT (“DC”) POWER RATES. PAETEC FURTHER NOTED THAT SOME OF THE LANGUAGE IN THE DEFINITION OF LIST 1 DRAIN FROM GR-513 (WHICH QWEST OMITTED FROM ITS UPDATES) APPEARS TO LEND A DEGREE OF REASONABLENESS TO THE CLECS’ POSITIONS IN THOSE LITIGATED PROCEEDINGS. PAETEC EXPRESSED CONCERN THAT QWEST’S UPDATES TO THE DEFINITIONS OF LIST 1 DRAIN AND LIST 2 DRAIN IN ITS TECHNICAL PUBLICATION 77385 WERE MADE TO SUPPORT QWEST’S ADVOCACY AND UNDERMINE THE CLECS’ ADVOCACY IN THE ONGOING DC POWER RATE PROCEEDINGS. IN RESPONSE TO MR. ASHTON’S SUGGESTION THAT THE DEFINITIONS OF LIST 1 DRAIN AND LIST 2 DRAIN FROM GR-513 BE COPIED VERBATIM INTO QWEST TECHNICAL PUBLICATION 77385, PAETEC INDICATED THAT THIS WAS A DECISION FOR THE ENGINEERS TO MAKE. PAETEC ADDED, HOWEVER, THAT, GIVEN QWEST’S STATED PURPOSE FOR THE CR, IT SEEMS LOGICAL THAT THE DEFINITIONS OF LIST 1 DRAIN AND LIST 2 DRAIN IN QWEST’S TECHNICAL PUBLICATION 77385 SHOULD “AGREE” WITH THOSE IN TELCORDIA GR-513, AND THAT UPDATES TO THESE DEFINITIONS SHOULD NOT BE SELECTIVELY CHOSEN BASED ON WHATEVER LANGUAGE MAY SUPPORT QWEST’S ADVOCACY IN THE ONGOING DC POWER RATE PROCEEDINGS.

Curtis Ashton - Qwest questioned how best to handle. He said he could rewrite Section 2.4. Curtis questioned the CMP process AND THOUGHT THAT THE CLECS COULD RESPOND IN THE FORMAL COMMENT PORTION OF THE CMP PROCESS.

Patrick Phipps – PAETEC said he did not see anything wrong with adding the wording. There would then be no reason to disagree if it was updated to be in agreement. He said lots do not have access to GR-513 REASON TO DISAGREE WITH QWEST’S PROPOSED UPDATES TO THE DEFINITIONS OF LIST 1 DRAIN AND LIST 2 DRAIN AND THAT THEY ARE CONSISTENT WITH HOW THESE TERMS HAVE BEEN TRADITIONALLY DEFINED; HOWEVER, THE POINT IS: QWEST’S UPDATED DEFINITIONS ARE DIFFERENT THAN WHAT IS IN TELCORDIA GR-513 AND DO NOT INCLUDE ALL INFORMATION IN THE TELCORDIA DEFINITIONS. HE STATED THAT THERE WOULD THEN BE NO REASON TO DISAGREE WITH THE DEFINITIONS OF LIST 1 DRAIN AND LIST 2 DRAIN IN QWEST’S TECHNICAL PUBLICATIONS IF THEY WERE UPDATED TO BE IN AGREEMENT WITH TELCORDIA GR-513, BUT HE DEFERRED TO THE ENGINEERS AS TO THE TECHNICAL MERITS OF MAKING QWEST’S DEFINITIONS IDENTICAL TO TELCORDIA’S. HE NOTED THAT THE MAJOR DISAGREEMENT PAETEC HAS WITH QWEST’S UPDATED DEFINITIONS PERTAINS TO THE LANGUAGE QWEST IS PROPOSING TO ADD ABOUT :COLLOCATOR LIST 1 AND 2 DC DRAINS…”, NOT SO MUCH QWEST’S PROPOSED UPDATES TO THE DEFINITIONS OF LIST 1 DRAIN AND LIST 2 DRAIN UNDER THE BULLETPOINTS IN SECTION 2.4. HE ADDED THAT, WHILE PAETEC HAS PURCHASED AND REVIEWED THE TELCORDIA GR-513, OTHERS DO NOT HAVE ACCESS TO GR-513. Susan Lorence - Qwest said it was OK to add the wording since the document had not been sent out for formal comment. She said we could either send the revised wording out for formal comment or have another ad hoc meeting.

Curtis Ashton - Qwest said he would add the GR-513 text and send out revised language.

Julia Redman-Carter - PAETEC said she would like another ad hoc meeting TO REVIEW AND DISCUSS THE NEW QWEST LANGUAGE PROPOSAL. THE LANGUAGE AND FORMAL COMMENT PERIOD CONTEMPLATES THAT THE CLEC CONCERNS AND FEEDBACK HAVE ALREADY BEEN INCORPORATED INTO THE LANGUAGE.

Curtis Ashton - Qwest said we will now get to the problem paragraph. Curtis said that “not generally known” was meant “to Qwest.” He questioned whether adding the words “to Qwest” would help. Curtis said it does not change that the Commission can order and that Qwest can choose to oversize.

Patrick Phipps – PAETEC said that with the phrase “and DC plant components” is the problem wording. If a person read GR-513 in detail, there are no distinguishing characteristics. ” WAS THE PRIMARY PROBLEM WITH THE ADDED LANGUAGE, AND THAT PAETEC CANNOT AGREE WITH THIS PARAGRAPH WITH THIS PHRASE INCLUDED. HE INDICATED THAT THIS ISSUE GOES TO THE HEART OF THE DISPUTE BETWEEN QWEST AND CLECS REGARDING DC POWER RATES. HE EXPLAINED THAT QWEST HAS CLAIMED IN THESE PROCEEDINGS THAT IT SIZES DC POWER PLANT COMPONENTS BASED ON THE CLEC ORDER FOR POWER FEEDS, AND ACCORDING TO QWEST, IT IS THEREFORE APPROPRIATE FOR QWEST TO CHARGE CLECS FOR DC POWER PLANT BASED ON THE SIZE OF THEIR POWER FEED. HE EXPLAINED THAT CLECS DISAGREE WITH QWEST ON THIS POINT AND HAVE SHOWN IN THESE PROCEEDINGS THAT QWEST’S CLAIM (ABOUT SIZING DC POWER PLANT TO CLEC CABLE FEEDS SIZE) IS NOT SUPPORTED BY ITS OWN TECHNICAL PUBLICATIONS, AND IN FACT, CONFLICTS WITH THOSE TECHNICAL PUBLICATIONS. HE EXPLAINED THAT THIS PROPOSED LANGUAGE IS AN APPARENT EFFORT TO BOLSTER QWEST’S ADVOCACY (AND UNDERCUT CLEC ADVOCACY) IN THE ONGOING DISPUTES WITH CLECS BY INSERTING LANGUAGE INTO ITS TECHNICAL PUBLICATIONS INDICATING THAT QWEST SIZES POWER PLANT AS IT CLAIMS IT DOES IN THOSE DISPUTES. IN OTHER WORDS, QWEST IS ATTEMPTING TO FILL THE HOLE IN ITS ADVOCACY EXPOSED BY THE CLECS IN THE ONGOING DISPUTES – I.E., THAT THERE IS NO QWEST TECHNICAL PUBLICATION THAT SUPPORTS THE WAY QWEST CLAIMS IT SIZES POWER PLANT IN THOSE ONGOING DISPUTES. PAETEC ALSO NOTED THAT IT HAD REVIEWED THE ENTIRE TELCORDIA GR-513 AND QWEST’S PROPOSED LANGUAGE HAS NO BASIS IN THAT DOCUMENT, NOR DOES TELCORDIA GR-513 DISTINGUISH BETWEEN CLEC EQUIPMENT AND ILEC EQUIPMENT WHEN DISCUSSING LIST 1 DRAIN AND LIST 2 DRAIN.

Curtis Ashton - Qwest said he is not claiming that we put the paragraph in due to GR-513 AND ACKNOWLEDGED THAT THIS PARAGRAPH REFLECTED QWEST’S ADVOCACY POSITIONS IN THE ONGOING DC POWER RATE PROCEEDINGS AND THAT HE WAS AWARE THAT CLECS DISAGREED WITH QWEST’S POSITION. He said that is how Qwest sizes.

Patrick Phipps – PAETEC said when we get into Cost Dockets, the state PUC looks at the ILEC engineering design standard. Patrick said one could make the case that Qwest has sized according to the standard. He has never seen it in AT&Ts. He said the state commission does not allow Qwest to recover oversizing. He said there is no basis for it and that he is saying sizing power plant and power raises problems. PAETEC RESPONDED TO MR. ASHTON’S STATEMENT THAT THIS LANGUAGE DOES NOT CHANGE WHAT A STATE COMMISSION COULD ORDER REGARDING A DC POWER RATE. PAETEC EXPLAINED THAT IN TELRIC PRICING PROCEEDINGS, COSTS ARE DEVELOPED BASED ON A MODELED NETWORK, AND TYPICALLY A STATE PUC LOOKS AT THE ILEC ENGINEERING DESIGN STANDARD TO EVALUATE THE REASONABLENESS OF THE MODELED NETWORK. HE EXPLAINED THAT WHEN MODELING A DC POWER PLANT FOR TELRIC COST STUDY PURPOSES, THE STATE PUC MAY LOOK AT THE LANGUAGE QWEST IS PROPOSING TO ADD, AND THAT LANGUAGE WOULD GIVE QWEST THE OPPORTUNITY TO MAKE THE CASE THAT QWEST HAS SIZED POWER PLANT ACCORDING TO ITS STANDARD – EVEN THOUGH QWEST’S LANGUAGE WOULD RESULT IN AN OVER-SIZED POWER PLANT. HE EXPLAINED THAT WHILE TELRIC DOES NOT PERMIT QWEST TO RECOVER COST OF AN OVER-SIZED POWER PLANT, THE CONCERN IS THAT ADDING THIS LANGUAGE TO THE TECHNICAL PUBLICATION WOULD GIVE QWEST THE OPPORTUNITY TO ARGUE THAT SIZING POWER PLANT TO CLEC ORDERS IS NOT OVER-SIZING. PAETEC ADDED THAT THIS LANGUAGE DOES NOT EXIST IN AT&T’S TECHNICAL PUBLICATIONS.

Curtis Ashton - Qwest said he wants what Qwest wants IS ADVOCATING which is to codify how Qwest sizes power plant.

Patrick Phipps – PAETEC said it gives Qwest a leg up on advocacy by codifying it in the Technical publication. HE ADDED THAT QWEST SHOULD NOT CODIFY ITS ADVOCACY POSITIONS IN ITS TECHNICAL PUBLICATIONS, PARTICULARLY WHEN there is no basis for it in standards.

Curtis Ashton - Qwest said that is the sticking point. He said he has not been through what Qwest can and cannot do. Qwest sets the rules on why things are sized the way they are.

Patrick Phipps – PAETEC said Qwest should not codify QWEST ADVOCACY it in the Tech Pub.

Curtis Ashton - Qwest said he is aware THAT THE LANGUAGE IN THE QWEST TECH PUB IS QWEST’S of the advocacy.

Patrick Phipps – PAETEC said this is Qwest choice ALSO TOOK ISSUE WITH OTHER LANGUAGE IN THIS PARAGRAPH: “COLLOCATOR LIST 1 AND 2 DC DRAINS ARE NOT GENERALLY KNOWN…” PAETEC EXPLAINED THAT IT DISAGREED WITH THIS LANGUAGE BECAUSE QWEST MAY, IN FACT, KNOW THE LIST 1 AND 2 DRAINS OF COLLOCATED EQUIPMENT. FURTHER, PAETEC EXPLAINED THAT IF QWEST DOES NOT KNOW COLLOCATOR LIST 1 AND 2 DRAINS, THEN THAT IS QWEST’S CHOICE BECAUSE QWEST COULD EASILY ASK FOR THIS INFORMATION ON THE COLLOCATION ORDER FORM OR PICK UP THE PHONE AND CALL THE COLLOCATOR AND REQUEST THAT INFORMATION. PAETEC ADDED THAT IF QWEST ACTUALLY NEEDED THIS INFORMATION IN ORDER TO SIZE POWER PLANT FOR CLECS THE SAME WAY QWEST DOES FOR ITSELF, IT SHOULD BE QWEST’S RESPONSIBILITY TO ACQUIRE THAT INFORMATION – QWEST SHOULD NOT WRITE AN EXCEPTION INTO ITS TECHNICAL PUBLICATION THAT APPLIES ONLY TO CLECS THAT RESULTS IN DIFFERENT TREATMENT AND HIGHER COSTS TO CLECS FOR DC POWER PLANT.

Curtis Ashton - Qwest said even if we ask, there is not enough experience COLLOCATORS FOR LIST 1 AND LIST 2 DRAIN INFORMATION, QWEST CANNOT BE SURE THAT THE INFORMATION CLECS WOULD PROVIDE COULD BE RELIED UPON BECAUSE QWEST DOES NOT HAVE ENOUGH EXPERIENCE WITH THAT EQUIPMENT. If Qwest chooses to oversize, it helps the CLEC.

Julia Redman-Carter - PAETEC questioned if Qwest oversizes, could it increase cost?

Curtis Ashton - Qwest said it depends.

Julia Redman-Carter - PAETEC said this TYPE OF Tech Pub update could increase cost on CLECs. She said if they agree to update the Tech pub, she does not see an update to the ICA. TO CLECS AND IT WOULD NOT BE REFLECTED AS A NEGOTIATED POINT IN THE ICA ITSELF BECAUSE THE ICAS INCORPORATE THE TECH PUBS. SO THE TECH PUB UPDATE CAUSES A COST INCREASE THAT IS NOT NEGOTIATED OR AGREED TO BY CLECS, AND, IS NOT REFLECTED SEPARATELY IN THE ICA.

Curtis Ashton - Qwest said it does not change the cost at all. The rates are already ordered.

Doug Denny - Integra said there is some disagreement REGARDING THE IMPACT OF THE TECH PUB ON RATES. and HE questioned whether QWEST’S STATEMENT ON COSTS that is factually true. SINCE Qwest will use the Tech Pub update for advocacy.

Curtis Ashton - Qwest said he has been involved in every one of the cost dockets. The rules are not in there and they cannot be used to advocate.

Doug Denny - Integra said it is the only reason QWEST WISHES to put THIS LANGUAGE it is in IS for advocacy.

Patrick Phipps – PAETEC said users should pay for it. The CLEC advocacy is that the rate should be billed and cost incurred based on power usage. He said we would argue about what Qwest charges. When Collo submits the request, Qwest will build to the Tech Pub and say there is no reason CLECs should not pay. It is inconsistent with sizing. If sizing power plant as required, no reason for this rule. EXPLAINED THAT THE WAY QWEST’S PROPOSED UPDATES COULD INCREASE CLECS COSTS IS THAT QWEST IS ATTEMPTING TO ADD LANGUAGE IN ITS TECHNICAL PUBLICATIONS TO COMBAT MEASURED-USAGE BASED DC POWER RATES. HE EXPLAINED THAT CLECS ARE ADVOCATING FOR MEASURED USAGE-BASED DC POWER RATES BECAUSE SUCH RATES RESULT IN EACH USER PAYING FOR ITS FAIR SHARE OF THE POWER PLANT, SIGNIFICANT COST SAVINGS FOR CLECS AND WOULD SOLVE THE CONCERN RAISED BY CLECS OF QWEST OVERCHARGING AND DISCRIMINATING AGAINST THEM BY APPLYING DC POWER RATES TO CABLE FEED SIZE. HE EXPLAINED THAT BY ADDING LANGUAGE THAT STATES THAT QWEST SIZES DC PLANT COMPONENTS TO A CLEC POWER FEED ORDER, QWEST IS ATTEMPTING TO JUSTIFY CHARGING CLECS FOR DC POWER BASED ON THE SIZE OF THEIR POWER CABLE FEEDS (AND AT THE SAME TIME, UNDERMINE MEASURED USAGE-BASED DC POWER RATES). IN OTHER WORDS, QWEST’S PROPOSED UPDATES COULD PROVIDE QWEST A LEG UP IN ARGUING FOR HIGHER DC POWER CHARGES FOR CLECS. PAETEC NOTED THAT QWEST’S LANGUAGE WAS INCONSISTENT WITH CURRENT STANDARDS ON POWER PLANT SIZING AND THAT THERE IS NO REASON FOR A NEW RULE GIVEN EXISTING DOCUMENTATION ABOUT SIZING POWER PLANT.

Curtis Ashton – Qwest said Qwest is not sizing that way. THAT QWEST’S PROPOSED LANGUAGE ABOUT SIZING DC POWER PLANT TO CLEC ORDERS REFLECTS THE WAY QWEST ACTUALLY SIZES POWER PLANT

Patrick Phipps – PAETEC said the Iowa Board disagrees and it creates disagreement on whether we size in a different way. PAETEC RESPONDED TO QWEST’S CLAIM THAT THIS LANGUAGE REFLECTS HOW QWEST ACTUALLY SIZES POWER PLANT. PAETEC EXPLAINED THAT THE IOWA UTILITIES BOARD (AND REVIEWING COURT) FOUND THAT QWEST DID NOT, IN FACT, SIZE POWER PLANT TO A CLEC ORDER FOR POWER FEEDS, AND AS SUCH, QWEST’S PROPOSED LANGUAGE CONFLICTS WITH THE FACTS.

Bonnie Johnson – Integra said she did not know a lot about List 1 and 2 drains but that CURTIS SAID QWEST it was putting advocacy in the Tech Pub. BONNIE SAID THIS IS IN CONFLICT THAT Qwest claims the Tech PubS ARE is in line with Industry StandardS of GR-513.

Curtis Ashton - Qwest said GR-513 does not address CLEC drains in it.

Julia Redman-Carter - PAETEC said THE INFORMATION IS NOT UNKNOWN TO QWEST AND THAT LANGUAGE IN THE GR-513 STATES THAT THE requirements are provided by equipment manufacturers. WHY IS THAT NOT INCLUDED IN THE TECH PUB?

Curtis Ashton – Qwest said Qwest does not take manufacturer’s word for it. He said he does not think GR-513 addresses the issue. Qwest measures the drain itself in our Labs. On List 2 drains, there is not an argument. List 1 drains vary and are much harder to figure out which becomes the big sticking point.

Patrick Phipps – PAETEC questioned is there a reason why Qwest does not reference List 2X drain IN ITS PROPOSED UPDATES?

Curtis Ashton - Qwest said this is an AT&T thing and that he had never heard of List 2X drains until AT&T brought it up. List 2X drain only has to do with A and B feeds and loss of one of those. Curtis said he will put it in the Tech Pub.

Patrick Phipps – PAETEC said List 2X is a new concept to Qwest. He questioned what is the difference between projected peak vs. total peak AND WHY QWEST’S TECHNICAL PUBLICATION USES “PROJECTED PEAK” WHEN TELCORDIA GR-513 USES “TOTAL PEAK”?

Curtis Ashton - Qwest said Qwest would use projected peak but agree total peak is better. He will work to make it agree with GR-513. From a legal perspective, there is disagreement about the 3rd paragraph. The question is whether Qwest can legally make the change. CLECs will have a comment period. Curtis said is it amenable to have the lawyers handle the question?

Julia Redman-Carter - PAETEC said let’s make language we can agree on. She said the first part of the phrase and the last part should be reviewed. Julia agreed this was not the place to have a legal argument. SHE SAID THAT PAETEC’S POSITION IS THAT THE FIRST PHRASE AND THE LAST PHRASEOF THE SENTENCE SHOULD BE REMOVED. THESE COMMENTS ARE NOT AN OBJECTIVE STANDARD AND THERE ARE ISSUES AS TO THE PROCESS, AND THIS IS OF PARTICULAR CONCERN IF QWEST BELIEVES THE DETERMINATION RESTS ON QWEST’S LEGAL REVIEW RATHER THAN ENGINEERING. JULIA AGREED THIS TECH PUB WAS NOT THE PROPER PLACE TO HAVE THIS LEGAL ARGUMENT, SO THOSE CHANGES SHOULD NOT BE INCORPORATED.

Ross Nielsen – PAETEC said when you are lumping in the DC plant component, Qwest is not actually going to size to that. AB is not clear . THE LAST PHRASE OF THE SENTENCE REGARDING LUMPING IN THE DC PLANT COMPONENTS WITH THE CLEC REQUEST SIZE IS INACCURATE. QWEST IS NOT GOING TO AUGMENT THEIR DC PLANT COMPONENTS TO THE FULL CAPACITY OF THE REQUESTED FEEDS SUMMED. FOR EXAMPLE, IF A CLEC ORDERS A 100 AMP A AND 100 AMP B FEED SET THE DC PLANT COMPONENTS WILL NOT BE EXPANDED TO PROVIDE 200 AMPS ASSUMING PROPER USAGE OF THE A AND B FEEDS.

Curtis Ashton - Qwest said when Qwest sizes the DC component, we size per List 1 for ourselves. The way we size for CLECs is based on the amount that is ordered. CLEC fuses are sized at 125%. We will clarify that point and discuss with legal on whether we remove the first and last part of the SENTENCE phrase. He said he will take that feedback and based on that, will rewrite section 2.4.

Julia Redman-Carter – PAETEC said this CHANGE is not due to GR-513 but is due to sizing.

Bonnie Johnson- Integra said THAT WITH the way CMP works, Qwest will implement anyway. BONNIE ASKED CURTIS IF HE WAS SAYING THAT EVEN IF CLECS OBJECTED THAT QWEST WILL PUBLISH THE CHANGES ANYWAY?

Curtis Ashton - Qwest said YES if we decide to leave it in. Every state is different especially MN and OR and possibly CO based on what is going on in the cost docket.

Julia Redman-Carter – PAETEC said she would like to see the proposed changes FOR THIS LANGUAGE before the next meeting SO THAT WE CAN DISCUSS THEM AT THE NEXT MEETING.

Curtis Ashton - Qwest said we would schedule another ad hoc meeting to review the rest of the changes which are not contentious, AND THEN COME BACK TO THIS SECTION. THIS WAY WE COULD GET THROUGHT THE REMAINDER OF THE DOCUMENT. ALSO and that he appreciated the calm discussion that had occurred.

Warren Wendling – CPUC said he wanted to make a suggestion. If the discussion hits upon a note where the language is inflexible, some measuring language should be included. He said that effort should be made to work hard at putting wording in where knowledge can be measured.

Susan Lorence – Qwest said she would set up another ad hoc meeting.

The meeting was adjourned.

2/17/10 Product/Process CMP Meeting Curtis Ashton-Qwest said this is the follow-up to the change to the Tech Pub 77385 that occurred last year. (2/25/10 Comments to minutes received from PAETEC in CAPS) PRIOR TO LAST YEAR, this Tech Pub had not been updated for six years. We initially proposed changes on a level 2 notice last year. After a detailed review of the changes, Qwest issued a level 3 notice and removed updates that were viewed as a level 4. As promised, these are the level 4 changes that include about 20 changes in the document. Curtis said he is happy to have an ad hoc meeting to review the changes. Curtis relayed that Telcordia GR-513 was re-issued in January and the TP update reflects those changes that are primarily to do with drain changes.

Julia Redman Carter-PAETEC said she would like an ad hoc meeting and wanted to know what issue of the Telcordia document. Curtis Ashton-Qwest said it is Issue 2 of Telcordia GR-513 that came out in January. Mark Coyne-Qwest said we would schedule an ad hoc meeting.