Wholesale: Products & Services

Open Product/Process CR PC020409-1EXES Detail

Description Of Change

This CR does not replace in any way Integra’s CR PC082808-1IGX (which is broader), and it should not delay the processing of that CR. Implementation of a USOC was not specifically mentioned in the description of change in that CR, whereas here Integra is specifically requesting USOC implementation for HDSL. Integra reserves its rights as to CR PC082808-1IGX. It appears from CMP discussions related to PC082808-1IGX that implementation of the USOC may be bogged down by other issues, so Integra has also submitted this CR to attempt to avoid delay in implementing the USOC. If implementation of the USOC assists in resolving some of the issues raised in CR PC082808-1IGX, as suggested by Qwest, then the companies may address that situation at the time.

CLECs communicate the type of service they intend to provide on 2/4 Wire Non-Loaded Loops by using the appropriate NCI/SECNCI codes on the Local Service Request (LSR). Qwest, however, told Integra personnel that Qwest provisions circuits to voice grade parameters, regardless of the NCI/SECNCI code requested on the LSR (e.g., even if the code indicates a digital capable service, rather than a voice grade service). Qwest has suggested that the resulting problems may be at least partially alleviated if Qwest implements this USOC because, once Qwest assigns the USOC to a service, doing so will allow it to flow through facility assignment to better identify a facility capable of supporting HDSL2 service. Although Qwest had said that work on USOC implementation is currently underway and scheduled to be implemented in mid April of 2009, Qwest has since suggested that it may stop work on the USOC if CLECs do not agree to an unrelated Qwest proposal. Qwest should not tie implementation of the USOC to other issues. Doing so will cause an unnecessary delay and may cause discriminatory conditions to continue.

Qwest’s ICA negotiations template Section 9.2.2.3 states:

Qwest will provision digital Loops in a non-discriminatory manner, using the same facilities assignment processes that Qwest uses for itself to provide the requisite service. (emphasis added)

A key problem that exists today, however, is that Qwest is not meeting this commitment. For CLECs, Qwest’s facilities assignment process does not select/assign the best (most qualified) loop available for the type of loop ordered by the CLEC (e.g., HDSL). Instead, it is just as likely, or more likely, to assign a voice grade loop to fill a CLEC request for a digital capable loop. In contrast, for Qwest retail, Qwest automatically assigns the best (most qualified) loop available for the type of loop ordered by Qwest retail. Every day that this situation continues is another day of discrimination, and so every effort should be made to accelerate resolution of this problem. As Qwest has suggested that implementation of this USOC will assist with this issue for HDSL, Qwest should promptly implement the USOC.

Expected Deliverables/Proposed Implementation Date (if applicable):

Qwest will implement the USOC no later than mid April of 2009.

Project Meetings

Mark Coyne-Qwest said that this exception CR was submitted by Integra. He said that a vote was conducted on 2/17/09 and the CR was denied. He said that a copy of the denial can be found on the Wholesale Calendar. Bonnie Johnson-Integra said Qwest traditionally sends a formal denial and asked when it would be sent. Lynn Stecklein-Qwest said that the denial was posted in the Qwest response section of the CR but that a formal denial letter would be sent. Bonnie Johnson-Integra said that she had additional questions on PC082808-1IGX. (Captured above)

Exception CR Vote Required Meeting Minutes – PC020409-1EX February 17, 2009 Attendees: Bonnie Johnson-Integra, Loriann Burke-XO, Julia Redman-Carter-McLeod, Mindy Chapman-Neustar, Bob Mohr-Qwest, Mark Nickell-Qwest, Jamal Boudhaouia, Mark Coyne-Qwest, Susan Lorence-Qwest Lynn Stecklein-Qwest stated that the purpose of this meeting is to review and conduct a vote on the Exception Request submitted by Integra to implement a USOC to correct the facility assignment for HDSL. She said that Integra and its entities (Integra) have submitted this change request to address a single issue - implementation of a Universal Service Ordering Code (USOC) for HDSL (2 and 4 wire non loaded loops) to correct assignment of facilities. Integra is seeking the following exceptions: • Implement the USOC no later than mid April of 2009 • This exception CR will not replace Integra s CR PC082808-1IGX and should not delay the processing of the CR. Lynn said that Quorum is eight and has been achieved. She reviewed the yes and no vote as follows: A vote of - Yes will indicate a preference to allow the implementation of the USOC to correct the facility assignment for HDSL no later than mid April 2009 and not delay the processing of PC082808-1IGX. A vote of - No will indicate a preference to NOT allow the implementation of the USOC to correct the facility assignment for HDSL and not delay the processing of PC082808-1IGX.

Bonnie Johnson-Integra said that she wanted to make sure that we were voting on whether this CR would be treated as an exception.

Lynn said that we were.

She said that Section 16.4 of the CMP Document states that - If the Exception Request is for a general change to the established CMP timelines for Product/Process changes, a two-thirds majority vote will be required unless Qwest or a CLEC demonstrates, with substantiating information, that one of the criteria for denial set forth in Section 5.3 is applicable. If one of the criteria for denial is applicable, the request will not be treated as an exception. E-mail votes with a vote of yes have been received from: Covad, Comcast Cable, Jaguar Communication, Live Wire Networks, Quantum Communications, Verizon Business During the call Integra, McLeod and XO voted yes. Lynn said that Qwest voted no. She said as stated earlier in section 16.4, this section allows for the CR to not be granted as an exception if one of the criteria for denial is applicable. She said that Bob Mohr (Qwest) will provide information on why the request will not be granted as an exception CR based on the standards set forth in Section 5.3. Bob Mohr-Qwest said this Exception Change Request requires a business discussion regarding the obligation to provide the HDSL Capable Loop USOC and the cost to do so. Absent the obligation to provide an HDSL Capable Loop, the decision to implement this Exception CR becomes a financial decision. Absent the CLEC community agreement to perform cooperative testing, this HDSL Capable Loop USOC implementation becomes a financial liability to Qwest. Qwest therefore respectfully denies this Exception CR to implement an HDSL Capable Loop USOC without including the cooperative test requirement as it is economically not feasible.

Bonnie Johnson-Integra said that Qwest is willing to do this for themselves but not for Wholesale.

Lynn Stecklein-Qwest said that this CR will be closed and the formal denial response will be sent to Integra and posted to the Wholesale Calendar.

CenturyLink Response

Qwest Response Exception Vote Required Meeting

Bonnie Johnson Integra

SUBJECT: CLEC Change Request Response - CR #PC020409-1EX

This CR submitted by Integra and its entities (“Integra”) is requesting to address a single issue – implementation of a Universal Service Ordering Code (“USOC”) for HDSL (2 and 4 wire non loaded loops) to correct assignment of facilities. Qwest has indicated that there is a USOC already recognized by Telcordia/industry standards that would help ensure that facilities assigned to CLECs meet the parameters and industry standards applicable to the specific HDSL product ordered by the CLEC. Qwest, however, has not yet implemented its use for CLECs. (Qwest has not yet indicated whether it uses this USOC for Qwest retail or, if not, how assignment of facilities is physically performed for Qwest retail. Qwest should provide this information.) Qwest should implement the USOC expeditiously.

This Exception Change Request requires a business discussion regarding the obligation to provide the HDSL Capable Loop USOC and the cost to do so. Absent the obligation to provide an HDSL Capable Loop, the decision to implement this Exception CR becomes a financial decision. Absent the CLEC community agreement to perform cooperative testing, this HDSL Capable Loop USOC implementation becomes a financial liability to Qwest. Qwest therefore respectfully denies this Exception CR to implement an HDSL Capable Loop USOC without including the cooperative test requirement as it is economically not feasible.

Sincerely,

Qwest Corporation