Wholesale: Products & Services

Open Product/Process CR PC021502-1 Detail

Description Of Change

January 2002/Qwest’s Minneapolis Orchard Central Office: Qwest's Orchard Central Office is currently under construction for a new addition. That addition includes modification to the existing mechanical system, as well as additional floor space. Eschelon leases space, from Qwest, for a collocation in the Orchard Central Office. During a dispatch, in January 2002, Eschelon's technician discovered dirt, dust and metal shavings on its collocation equipment. Photographs showing the extent of the problem are attached. Qwest would not expose its own equipment to these conditions. Qwest had not notified Eschelon of this construction or the potential impact on Eschelon’s collocation space. When Eschelon discovered the problem, Eschelon immediately contacted Qwest to report the problem, request resolution, and obtain assurances that this serious problem would not be repeated. During later visits to this collocation site, Eschelon discovered excessive temperature levels that could also damage its equipment. Cleaning the equipment required 'powering down' the equipment, resulting in customer outages. Qwest removed all essential cooling to the area and replaced it with a fan, an inadequate solution. Qwest would not find that a fan would be adequate to cool its own equipment. The problem also required one of Eschelon's technicians to be available for the time period while a vendor was completing the clean up. This tied up a technician who should have been doing other work. This incident caused down time for our customers and forced Eschelon to incur unnecessary time and expense and could have caused major damage to our equipment. Eschelon believes that at least two other CLEC collocation spaces were adversely affected by the same construction. Qwest has an obligation to protect the CLEC collocation equipment with at least as much care, as it would use to protect its own equipment. Eschelon asks Qwest for an improved process to ensure that our collocations are protected during construction in any Qwest building that houses one of our collocations.

March 2001/Denver Main Central Office: On March 15, 2001, Eschelon conducted a site survey of its physical collocation located at the Denver Main Central Office. The conditions discovered at the site indicated a deliberate breach in security and potential damage to our equipment. Qwest had not notified Eschelon of this construction or the potential impact on Eschelon’s collocation space. When Eschelon discovered the problem, Eschelon contacted Qwest immediately asking for resolution of the following issues:

1. Eschelon's cage was accessed without Eschelon authorization or knowledge. A Qwest approved contractor removed the pins securing Eschelon's collocation cage to gain access and Qwest security failed to notify Eschelon of the intrusion. Eschelon pays security charges on a monthly basis and expects Qwest to provide and maintain a secure environment. Eschelon told Qwest that this matter is of utmost importance as the integrity of Eschelon's collocation equipment was jeopardized.

2. A 1 inch copper pipe running across the span of Eschelon's cage was installed. The location and height of the pipe severely restricted Eschelon's ability to expand the existing cable ladder racking for future growth. Additionally, the pipe was believed to be a water pipe, which if ruptured, had significant potential for causing damage to personnel and property.

3. There was a significant amount of dust within the cage and on the collocation equipment. This presented an operational issue with Eschelon's hardware and its ability to operate properly. Eschelon asked Qwest to thoroughly clean Eschelon's collocation cage and the surrounding area.

4. There were two additional 1/2 inch copper pipes running across the cage at ceiling height. These pipes also posed a significant problem, as they appeared to be water pipes serving the cooling unit adjacent to Eschelon's cage. The same potential for damage to personnel and property existed.

Both of these examples involved serious problems concerning the integrity of Eschelon's collocation cage. Eschelon had to escalate the issues within Qwest in an attempt to resolve them. An after-the-fact clean up, however, is not a satisfactory remedy. The breaches to security and integrity to the collocation cannot be undone. Eschelon also had to incur unnecessary time and expenses, in addition to its customers experiencing unjustified downtime.

Qwest would not expose its own equipment to such conditions or allow CLECs to treat Qwest’s space and equipment in this same manner. One can only imagine how Qwest would react if a CLEC removed the pins to a Qwest door to get around a lock securing access to the Qwest area of a building. On a much smaller scale, recently, a Vice President of Qwest in charge of Qwest’s network directly contacted Eschelon’s Executive Vice President of Operations and Engineering to allege that Eschelon’s equipment was causing a Qwest fire alarm near Eschelon’s cage to go off. Eschelon was able to show that was not the case. Nothing in Eschelon’s cage had caused the alarm to sound. Eschelon believes that the Qwest fire protection system in that building has had false alarms before, for reasons unrelated to collocation. The mere proximity of a CLEC collocation to a fire protection device that sounded a false alarm was sufficient to draw an immediate call from Qwest’s top management.

In contrast, Eschelon has had difficulty in getting appropriate attention to the very serious issues that have occurred with respect to violations of its collocation space. Eschelon had to expend substantial resources escalating these issues to obtain after-the-fact resolutions. Even after the first situation was resolved, and assurances were received that the problem would not occur again, serious problems occurred again, this time in the Orchard Central Office. In response to its escalation of the most recent situation (Orchard Central Office), Qwest provided Eschelon with a written response that said: “Throughout the life of this construction project, Qwest has insured that all methods of procedures (MOP’s) were followed and that dust protection was appropriate and in place.” Please review the enclosed photographs in light of this statement. Obviously, if following the current procedures at Qwest produces this result, the current procedures are inadequate.

Qwest needs to promptly establish an improved process. Eschelon requests that a solution be developed and implemented quickly to avoid further serious breaches.

The law and interconnection agreements provide support for Eschelon’s request. Examples include:

47 U.S.C. § 551(c)(6): Incumbent local exchange carrier has -- “The duty to provide, on rates, terms, and conditions that are just, reasonable, and nondiscriminatory, for physical collocation of equipment necessary for interconnection or access to unbundled network elements at the premises of the local exchange carrier, except that the carrier may provide for virtual collocation if the local exchange carrier demonstrates to the State commission that physical collocation is not practical for technical reasons or because of space limitations” (emphasis added).

Minnesota Qwest-Eschelon interconnection agreement, Second Amendment: “USW shall provide Collocation in a nondiscriminatory manner on rates, terms and conditions that are just, reasonable and nondiscriminatory.” § 2.1; see also Part A, § 4.

Project Meetings

February 26, 2002, 12:00 (MT) Conference Call

877-564-8688 PC021502-1, Collocation: Construction Process (in, near or affecting CLEC collocation space)

Attendees: Ric Martin, Qwest Clyde Just, Qwest Laurel Burke, Qwest Chuck Frauenfeld, Qwest Paul Williams, Qwest Deb Heckart, Qwest Steve Sheahan, Qwest Kay Daugaard, Qwest Kathy Stichter, Eschelon Paul Hanser, Eschelon Bonnie Johnson, Eschelon

Introduction of Attendees Introduction of the participants on the Conference Call were made and the purpose of the call discussed Ric advised that there were two issues surrounding the Change Request. The first deals with the issues at the Orchard Central Office and the second deals with the process change requested in the Change Request. Ric advised that it would be best to discuss the first issue in a separate meeting and focus on the process in this meeting. Steve Sheahan would facilitate the meeting with Eschelon personnel with Kathy Stichter. Eschelon agreed with this path forward.

Review Requested (Description of) Change Kathy reviewed the requirements of their CR and their expected deliverable. Bonnie advised that Eschelon was aware that there is a documented process, but the concern is that it is not being followed 100%. Paul Hanser indicated that Eschelon would like to be involved in the planning process and be made aware of the construction activity. They want to know how the equipment is going to be protected and that it is kept cool and clean. Paul indicated that Eschelon would like to be involved in the project planning phase. Paul Williams asked if Eschelon would like to be notified on all construction activity. Paul Hanser indicated that they were more interested in the building construction activity rather than equipment installations. It was confirmed that Eschelon would prefer to be notified when there is facility construction as opposed to equipment installations. Paul clarified that some equipment installations could create a fair amount of dust (i.e. drilling through thick concrete) and they would want to be made aware of this type of installation. Ric confirmed that the process followed for construction activity is Technical Publication 77350. Clyde asked what name would Eschelon want Qwest to contact. Paul Hanser indicated that they would like the name on the emergency list provided to each Central Office, or the 800 number on their Collo cages contacted. This allows the call to go to operations that coordinate Eschelon’s activities. Clyde expressed concern that not all CLECs operate in the same manner. The only consistency is the name on the application. Paul Hanser advised that the person on the application and the associated number may change, but the posted 800 number remains the same. Qwest advised that this could be difficult to get a consistent approach from all CLECs. Ric asked Eschelon if discriminatory meant the same process for all parties involved. Kathy added that all equipment is treated the same for Qwest and CLECs.

Confirm Areas & Products Impacted It was confirmed that the CR addressed Collocation equipment. . Confirm Right Personnel Involved Ric advised that there are several SMEs that will be working on the CR. Laurel Burke will be the Owner identified on Qwest’s reports, but the other SMEs are Howard Cooper, Real Estate, Jerry Jenson, C.O. Staff, and Jeff Bostow, Technical Publications.

Identify/Confirm CLEC’s Expectation Eschelon confirmed that their expectation is their written statement under Expected Deliverable in the Change Request.

Identify any Dependent Systems Change Requests There is no corresponding System CR

Establish Action Plan (Resolution Time Frame) Qwest will facilitate a separate meeting to review the Orchard Construction activity. Ric advised that the CR will have the Community CLEC clarification and Qwest will present potential options at the March 20th CMP meeting.

CenturyLink Response

Kathy Stichter ILEC Relations Manager Eschelon Telecom, Inc.

SUBJECT: Qwest Change Request Response - CR PC021502-1 Collocation: Construction Process (in, near or affecting CLEC collocation space)

This letter responds to Change Request PC021502-1 requesting that Qwest develop a written, trained and adhered to nondiscriminatory process that addresses proper procedures when Qwest and/or its vendors perform construction activities in buildings that house CLEC collocations. Additionally, the two (2) examples described in your Change Request will be addressed in Attachment 1 to this letter.

Eschelon suggested that the process include the following:

1. Improved Qwest process for building construction activity in Central Offices that house CLEC collocations.

Qwest’s process for building construction utilizes a project management approach. Due to the nature of individual building construction activity, project design drawings and specifications documents embody the performance expectations associated with each construction project. The very specific nature of such projects and the quantity of detailed information associated with these projects prohibit Qwest from providing a detailed building construction process in this response. However, Qwest provides below a description of activities common across building construction projects.

Qwest Building Construction Project Management

When a project is initiated, Local Design Construction teams, coordinated by Real Estate Project Managers, develop project plans and specifications in conjunction with Registered Professional Consulting Architects/Engineers and selected Qwest General Contractors. Prior to entering into a contract with Qwest (Real Estate), these consultants and contractors must have a demonstrated track record of proficiency while working with electronic equipment environments. Methods used to demonstrate this include checking work references from other clients and reviewing the contractors project portfolio. Local teams may then choose projects small in scope to evaluate the contractor for larger projects such as Central Office building additions.

The Local Design Construction team assembles the project work scope and customizes it according to the specific project at hand. The documentation and scope of the project work utilizes engineering and operational elements from Qwest policy documents, engineering and operational standards, as well as engineering guideline documentation specifically applicable to Central Office projects. Building environment specifications, or operational standards, commonly contain aspects of several Qwest and industry standards. Examples of these standards include:

? Class 100,000 clean room requirements for airborne particulate control (reference Qwest Regional Policy REGN 000-010-019RG); ? Temperature control requirements meeting industry standards (reference Bellcore (Telcordia) Network Equipment Building Systems (NEBS) document NEBS GR-63-CORE, and REGN 000-010-019RG); ? Technical Publication 77350 for equipment isolation and protection; ? National Electrical Code (NEC) specifications; and ? Project specific Methods of Procedure ("MOP").

Real Estate Consultants and Contractors use Qwest policies and standards in project documents and are held accountable for performing and utilizing these policies and standards. Local Design Construction teams are reminded on each project about the consequences of not following and/or failing to perform to these policies and standards, including the potential for contract termination or probation. In fact, during 2001, Qwest terminated contracts with three (3) real estate contractors and placed two (2) others on probation for failing to adhere to documented policies and standards.

Additionally, before construction begins, an approved MOP document must be posted. The construction contractor must describe all tasks associated with a project that may represent a direct threat to service such as AC Power work affecting DC power and work generating airborne debris open to working equipment, in order to describe the method for protecting the equipment from the threat. The Local Network Central Office Manager and/or Supervisor reviews the MOP and approves the equipment protection strategies - validating that those strategies are present and to be utilized during the construction activity.

Finally, Qwest provides contractors with explicit expectations regarding adherence to standards and an audit mechanism for ensuring compliance. The Introduction to Qwest Technical Publication 77350 provides "the material and workmanship requirements for personnel working in Qwest Central Offices and provide the basis for audit and evaluation of a job." Contractors are individually responsible for adhering to Qwest standards as well as applicable law and industry standards. When work operations jeopardize the network or fail to comply with safety standards, Qwest employees may expel contractors from the facility. Qwest employees are encouraged to stop construction work in progress to question a threat to personnel safety or risk to working equipment. Also, when problems are identified with a specific Real Estate contractor, a thorough root cause analysis is completed and appropriate action taken up to and including termination of a contractor.

2. Provide Advance Notification to and coordination with affected CLECs of construction occurring in Qwest Central Offices containing CLEC collocations. The General Mailout notification process would not be adequate.

Qwest agrees to provide CLECs with an Advance Notification process providing notice of building construction in Qwest Central Offices containing CLEC collocations. Advance Notification will provide targeted email to CLECs collocated in the affected Central Office at the time the project is funded by Qwest. The email, provided by the Collocation Project Management Center ("CPMC") will include the Central Office affected, description of the construction activity, date construction is planned to begin, date construction is planned to complete, and a Qwest contact name and number for the project. The Qwest contact can be used by CLECs to identify environmental issues or concerns during the project. Qwest will also provide status updates in the event the project changes significantly, i.e. the start date is moved forward or the scope of the activity increases. This process will be implemented effective May 2002 or as soon thereafter as possible in compliance with the agreed upon notification schedule. The following real estate work will be the subject of CLEC notifications: ? Building Additions ? HVAC Infrastructure Modifications ? Electrical Infrastructure Modifications ? Building Work for Space Rearrangements or Compartmentation ? Roof Replacement ? Other Building work that could affect the equipment environment

3. Ensure measures are in place to protect the collocation equipment environment including but not limited to protection from:

? Dust ? Dirt ? Metal Shavings ? Adverse Temperature conditions

Qwest contractors performing building construction work within Qwest Central Offices are required to apply appropriate industry standards in an effort to limit and control dust, dirt, metal shavings and temperature variations. As stated earlier, prior to starting any work activity the work steps for protecting working equipment must be documented in a MOP, Method of Procedure. After construction starts and during Real Estate building construction activities, the real estate contractors apply specific environmental requirements as described in the project design and specifications documents.

Qwest requires its contractors to adhere to specific aspects of American Society of Heating, Refrigerating and Airconditioning Engineers (ASHRAE) industry standards as it relates to Class 100,000 clean room requirements (described in Qwest Regional Policy REGN 000-010-019RG). These requirements provide specific airborne particulate standards that in turn are used for isolating working equipment from construction zones. Typically project specifications state that all construction work shall comply with Class 100,000 clean room requirements and must maintain a Class 100,000 environment in the Central Office environment regardless of any activity construction or otherwise. This means that airborne particulates of 0.5 micron and larger cannot exceed a count of 100,000 in one cubic foot of air.

Qwest requires its contractors to meet ASHRAE Class 100,000 requirement by specifying two methods in its project specifications:

? Isolation/Vacuum: Isolate working equipment form the construction zone, pressurize and seal for migration of airborne construction debris; o If isolation is not possible, then directly extract dust dirt and debris by using a HEPA vacuum with the operation of cutting and drilling tools. ? Filtration: If filtration of airborne particulates is questionable then particulate monitoring with instrumentation is used. Particulate counting monitors the environment only at one point in the room environment and is not necessary if the construction zone is isolated.

In addition to ASHRAE requirements, Qwest contractors must adhere to Section 2 of Tech Pub 77350 that specifically addresses Qwest’s expectations of personnel including employees, contractors and suppliers, while performing construction activities within Central Office buildings:

2.3.6 The cutting, filing, drilling, and milling or painting of the Qwest approved auxilliary framing, cable rack, etc., shall be done outside of the equipment area. When drilling of equipment or structures, that can not be removed from the facility, proper protection, and the use of HEPA vacuum shall be required. 2.3.7 General cleaning of the equipment facility or storage area in which work is being done shall be performed by the Service Supplier during the entire installation or removal process. Care shall be taken to generate a minimal amount of airborne dust. 2.3.8 The Service Supplier shall use only a High Efficiency Particulate Arrestor (HEPA) vacuum, capable of filtering particles larger than .3 microns in size, and equipped with a static dissipative hose in QWEST facilities to capture dust and chips from the drilling of floors, walls, ceiling, ironwork, and equipment during the uncrating process, and while cleaning cable racks and equipment. 2.3.9 The Service Supplier shall be aware of conditions that may result in equipment thermal shock (failure or degraded service brought on by a rapid change in temperature) and take steps to prevent its occurrence.

4. Prohibit unauthorized entry into CLEC space and ensure that CLEC security is not breached.

Qwest has documented procedures regarding physical security associated with CLEC collocations. Refer to Qwest’s PCAT under heading Central Office Security.

Additionally, in order to provide more direction to Qwest suppliers performing duties in Central Offices with CLEC collocations, pursuant to the agreed upon notification process, Qwest proposes replacement of Section 16.1.6 of Tech Pub 77350 to read as:

Qwest requires emergency access to all cages for safety purposes. Combination locks (or combination lock-boxes, with a key inside to unlock a keyed padlock) must be provided by the CLEC and attached to each cage. This will provide the Qwest representative with emergency access into the cage when needed. Qwest also requires that the CLEC forward the combination code to its cage lock to the appropriate personnel, e.g., State Interconnect Collocation Manager (SICM). The CLEC’s representative (emergency contact phone number located on the CLEC cage placard) must also retain the combination.

Qwest reserves the right to access CLEC enclosure when work is required in the Qwest-owned space above the cage (this includes access to the overhead ironwork, cable racking, electrical conduit, etc.). CLEC enclosure space will not be entered by anyone, for any reason, without first contacting the CLEC representative and the Qwest State Interconnect Collocation Manager and obtaining the required approval(s).

Qwest is committed to protecting CLEC equipment collocated in Qwest premises when performing activities within a Qwest Central Office that may reasonably be foreseen or predicted to harm such equipment. While Qwest strives to provide an environment for equipment to operate throughout its expected life cycle, it is reasonable to expect that some failures from environmental support equipment or personnel cannot always be avoided. Qwest does require its suppliers (including Qwest personnel) to comply with all published Qwest standards, applicable laws as well as industry standards and disciplines noncompliance. However, since Qwest can not provide a 100% event free environment for its network facilities and equipment, it in turn cannot provide this to CLECs. Nonetheless, Qwest remains committed to protecting and responding to the needs of the CLEC equipment environment with timely responses to correct adverse environmental events.

In response to the two (2) incidents identified by Eschelon in the Change Request, Attachment 1 provides Qwest’s evaluation of the incidents and the corrective action initiated by Qwest.

Sincerely,

Laurel L. Burke Staff Advocate, Policy & Law Technical Regulatory Interconnection Planning Local Networks, Qwest Corporation

cc: Mary Retka, Director, Legal Issues Barry Orrel, Director, 271 Technical Regulatory Paul Williams, Jr, Manager, Real Estate Wolfgang Wiewel, Director, Real Estate

Attachment 1

Eschelon described two locations, Minneapolis Orchard and Denver Main, where they believe Qwest’s current procedures failed to protect Eschelon's equipment effectively resulting in discrimination. Qwest’s evaluation and response to the issues are set forth below.

January-February 2002/Qwest’s Minneapolis Orchard Central Office

? Eschelon’s technician discovered dirt, dust and metal shaving on its collocation equipment ? Qwest had not notified Eschelon of this construction or its potential impact on Eschelon’s collocation space. ? During later visits to the site, Eschelon discovered excessive temperature levels that could also damage its equipment ? Cleaning the equipment required “powering down” the equipment which in turn resulted in customer outages ? Qwest removed all essential cooling to the area and replaced it with a fan ? Eschelon provided a technician to be available for the time period while a vendor was completing the clean-up ? Eschelon believes that at least two other CLEC collocations spaces were adversely affected by the same construction ? Qwest has an obligation to protect the CLEC collocation equipment with at least as much care as it would use to protect its own equipment ? Dust problem continued after the professional cleaning of the equipment. ? The lack of environmental control at this Qwest C.O. disturbs Eschelon. Eschelon does not believe Qwest equipment is subjected to similar environmental conditions. ? Eschelon requires that Qwest take immediate action to have their equipment cleaned again by a professional service. ? Eschelon will be submit their internal cost to Qwest for our clean-up effort ? Dust was also observed on other CLEC’s equipment.

Qwest Response:

Qwest Real Estate completed a root cause investigation of the Orchard environmental event and discovered the following:

? Project documentation for the construction related activity conveyed the proper information about Class 100,000 clean room requirements and the proper environmental temperature control requirements to the supplier. ? An approved MOP was in place identifying the required protection for working equipment ? Contractor provided protection in the form of dust partition walls separating the construction zone from working equipment. ? Contractor provided supplemental cooling equipment with the proper high efficiency filtration for temperature and airborne particulate control. ? Contractor failed to achieve proper room pressurization to prevent particulate migration from the construction zone to working equipment. ? Contractor failed to recognize the lack of room pressurization after the first event and a repeat of the migration occurred within days after the first event. ? The lack of proper pressurization was caused by incorrect placement of temporary floor fans and created improper air-flow and pressurization in the working equipment area. Incorrect fan placement provided a recirculating air-flow which allowed transport of airborne and non-airborne construction debris to the working equipment area.

Qwest Real Estate completed a root cause investigation of the Orchard environmental event and concluded the following:

? Qwest Real Estate concluded the root cause was contractor error, meaning the contractor was provided with appropriate environment specifications to protect equipment but did not perform to those specifications. ? Qwest confirmed that air filtration and temperature control was adequately provided in all areas of the Central Office and that the same high efficiency filtration was provided to the CLEC area during construction activity. ? It was observed that Qwest equipment was also soiled due to particulate migration from construction activities. ? The contractor did provide proper pressurization and sealing procedures in the MOP but failed in the attempt to properly pressurize and seal the working equipment area from the construction zone. ? While it was observed that measures were in place and seemed to be properly applied, the contractor failed to identify the recirculating air flow/ negative pressurization that resulted in subsequent environmental problems a few days later.

Qwest action taken:

? Contractor has been placed on probation. ? Lack of information to the contractor was not an issue, but Qwest will verify going forward that all construction documents contain the Class 100,000 clean room requirement with improved awareness. ? Temporary air flow, pressurization and sealing of construction zones will be added as specific MOP check list items to address and will be standard for all projects requiring construction zone isolation. ? Placement of floor fans and other temporary cooling equipment will be secured to prevent tampering. ? Contractors will be reminded that they are responsible for placement and operation of all temporary air movement as well as pressurization equipment to achieve and maintain environmental conditions. ? The MOP will require contractors to observe particulate accumulation and soiling of equipment surfaces before and periodically during construction activity and will address reporting this information to the Central Office Manager and the Real Estate Project Manager. ? Advance Notification process will identify people to contact for concerns about construction debris, temperature control and other environmental issues. ? To prevent the potential for pressurization and/or construction zone seal failure, only Real Estate contractors/agents will be permitted to provide fans and/or other means of cooling during construction periods.

March 2001/Denver Main Central Office

? Eschelon’s collocation cage was accessed without Eschelon's authorization or knowledge. A Qwest approved contractor removed the pins securing Eschelon’s collocation cage to gain access and Qwest security failed to notify Eschelon of the intrusion. ? A 1-inch copper pipe running across the span of Eschelon’s cage was installed. The location and height of the pipe restricted Eschelon’s ability to expand the existing cable ladder racking for future growth. Additionally, the pipe was believed to be a water pipe, which, if ruptured, had significant potential for causing damage to personnel and property. ? There were two (2) additional ½-inch copper pipes running across the cage at ceiling height. These pipes appeared to be water pipes serving the cooling unit adjacent to Eschelon’s cage. ? There was a significant amount of dust within the cage and on the collocation equipment. Eschelon asked Qwest to thoroughly clean Eschelon’s collocation cage and the surrounding area.

Qwest response:

The Qwest State Interconnect Manager ("SICM") for Colorado arranged a meeting between himself, Eschelon representatives shortly after Eschelon notified Qwest of the problems in March 2001, the Qwest Real Estate Manager and the contractor performing work in the Qwest Central Office at the time Eschelon voiced their concern. The contractor was remodeling space in the west half of the 7th floor of Denver Main to support future equipment placement in that area.

? The meeting was held at Denver Main and the investigation resulted in the contractor being directed to perform several additional tasks: ? Remove copper pipes placed at the 8' level above the Eschelon cage; ? Place piping pans under the existing water pipes to ensure that no dripping water would fall into Eschelon's cage; ? Have Eschelon's space and equipment cleaned; ? Make arrangements with Eschelon PRIOR to entering their space to correct the pipe related issues; ? Take steps to ensure no further unauthorized entry would occur by adhering to the access guidelines and permissions required. ? The Central Office Supervisor indicated that he had not been contacted by the contractor for permission to enter the collocation cage; he also indicated that he had no way to access the cage as he did not have a combination or the key. Qwest action taken:

? The SICM and the Real Estate Manager reiterated to the contractor that they must have specific permission to enter CLEC space using first the number located on the cage. Product Catalog ("PCAT") language has been provided since this occurrence that clarifies Qwest personnel and vendor roles while working in CLEC physical collocations. Additionally, Qwest proposes to add additional clarity in its Technical Publication 77350 regarding contractor requirements relating to CLEC security while working in Qwest buildings. ? The SICM reviewed collocation access requirements with the Central Office supervisor. ? Qwest employees are now encouraged and expected to question any activity that does not comply with security guidelines. ? Eschelon provided the appropriate access information to the Central Office supervisor. ? Following the submittal of this change request, a Design Construction Director and Project Manager physically confirmed that leak protection had been installed and conforms to that for other equipment in Denver Main. ? The temporary applications of filters for all new ductwork grilles, registers and diffusers will be a MOP checklist item. o Qwest will reconfirm the application of temporary filtration on all new ductwork outlets is contained in construction documents.

Finally, upon acceptance of this response by the CLEC community, Qwest Real Estate will issue a document to alert Qwest Real Estate Design Construction Field Directors of all actions contained in this Change Request response. This alert will require confirmation that all construction documents contain the items specified herein.