Wholesale: Products & Services

Open Product/Process CR PC031103-1 Detail

Description Of Change

To facilitate the CLEC’s option to perform maintenance, Covad requests the following changes.

1. Qwest allow the CLEC to access the front of the splitter shelf for testing thereby permitting test of a splitter card by the CLEC (Diagram A).

2. Qwest will allow the CLEC to perform maintenance on the splitter cards including replacement as necessary.

3. Qwest will continue to provision the CAS and will control the engineering configuration database for CAS. For new circuits, Qwest will install and provision the new splitter cards as necessary.

4. Qwest will continue to maintain the splitter shelves and Common Area Splitter bays.

5. CLEC’s will have the option to perform maintenance on the splitter cards or continue to have Qwest control all maintenance.

6. If the CLEC impairs a Qwest voice customer during the maintenance of the splitter cards Qwest may temporarily remove the data portion of the circuit.

7. The monthly recurring fees will be adjusted to remove the maintenance cost for those CLECs electing to perform the CAS splitter card maintenance.

8. The CAS shelves will be clearly designated to identify those shelves maintained by Qwest or the CLEC.

Original Description of Change (03-11-03):

Covad requests to be allowed to convert any or all existing Common Area Splitter Collocation arrangements to Cageless Shelf at a time Collocation. The current arrangement, being a type of Virtual Collocation, requires Qwest technicians to perform all maintenance associated with the splitters and splitter cards. While this process has worked in some central offices, Covad continues to experience problems related to improperly performed maintenance including splitter cards removed in error, splitter cards not installed properly, splitter cards replaced unnecessarily and cards removed as defective which cannot be located. Further, Covad and Qwest have not been able to jointly develop and document a workable process for the replacement of defective splitter cards. Covad has been trying to resolve these problems for over three years but continues to have the same experiences. These problems, coupled with the high non-recurring costs, have caused Covad to begin placing splitters in its own collocation arrangements, as additional capacity is required. It is Covad’s hope that by converting the existing splitter capacity from Common Area Splitter Collocation to some form of Cageless Shelf at a time Collocation, most of the maintenance problems will be resolved. This proposal would remove the splitter maintenance responsibility from Qwest and place it with Covad. This conversion may also require adjustments to existing monthly recurring charges applicable to the current product.

Expected Deliverable:

As Soon As Possible

Project Meetings

- 03/17/04 March CMP Meeting Steve Nelson with Qwest gave the update that the PCAT changes were effective on 2/26/04 and the contract amendment is available. This CR will move to CLEC Test status.

-- 02/18/04 February CMP Meeting Dave Williams with Qwest said that the PCAT changes will be effective on 2/26/04 and a contract amendment will be available at the same time. This CR will remain in Development status.

1/21/04 January CMP Meeting Dave Williams with Qwest provided an update to this CR and said changes for the PCAT were released 1/12/04 and the proposed effective date is 2/26/04. Mike Zulevic asked if the change would be available across the board on 2/26/04. Dave said yes. This CR will remain in Development status.

12/17/03 December CMP Meeting Dave Williams with Qwest provided an update to this CR which allow the CLEC to maintain POTS splitter cards. Dave said changes for the PCAT should be out soon. This CR will remain in Development status.

11/19/03 November CMP Meeting Dave Williams with Qwest provided an update to this CR and said we will be submitting level 3 changes for the PCAT and plan to have available in the December timeframe. Dave will send a copy to Mike Zulevic and John Berard for comments. This CR will remain in Development status.

10/15/03 October CMP Meeting Dave Williams with Qwest provided an update to this CR which provides CLECs the option to do maintenance or have Qwest do the maintenance on splitter cards. There will be changes made to the PCAT in November. This CR will remain in Development status.

09/17/03 September CMP Meeting Dave Williams provided an update to this CR and said that we have moved forward with a trial beginning 8/25 in Seattle areas and the trial has been well received by both Qwest and Covad. There will be a process change written in the next few weeks. This CR will remain in Development status.

CMP Meeting 08-13-03

White-Qwest presented the Qwest acceptance of the revised Covad Description of Change. Zulevic-Covad stated that Qwest and Covad were testing the process in 15 Central Offices in Washington state. He stated that it looked as if the process was progressing very well.

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CMP Meeting 07-16-03

White-Qwest presented the status and stated that Covad had submitted a revised description of change that Qwest was working on. Williams-Qwest stated that Qwest would probably start a trial with Covad on August 1. Berard-Covad stated that this was good progress. CR remains in Development. ============================================== CMP Meeting 06-18-03

Williams-Qwest presented the Qwest response. Zulevic-Covad stated that he had reviewed the response and that the Qwest recommended solution addressed a majority of his concerns. He asked how to proceed. White-Qwest recommended that Covad revise their description of change to align with the Qwest recommendation. He stated that he could forward a suggestion to Zulevic for approval. Zulevic-Covad agreed. White-Qwest stated that the change request would move into Development.

========================================================== CMP Meeting 05-21-03

White-Qwest presented the Qwest response and suggested the CR be moved to Evaluation status. ==========================================

04-16-03 - CMP Meeting

Zulevic-Covad presented the CR. Williams-Qwest stated that another option would be to move the splitters to the cageless lineup. Zulevic-Covad stated that this was to difficult logistically. Williams-Qwest asked if Covad expected Qwest to develop a per shelf collocation cost. Zulevic-Covad stated that he expected a monthly recurring rental rate. Williams-Qwest asked if Covad had discussed this issue with any other CLECs. Zulevic-Covad stated that he had not and that this would probably create a bifurcated process for Qwest. Williams-Qwest stated that he would query other DLECs for interest. Van Meter-AT&T stated that AT&T would like to be involved in any development calls for this CR.

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Clarification Meeting Wednesday, March 26, 2003

1-877-550-8686 2213337#

Attendees Matt White – CRPM Dave Williams – Qwest Jeff Cook – Qwest Mike Zulevic – Covad John Berard – Covad Becky Neesen - Covad

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

Review Requested (Description of) Change Berard-Covad reviewed the CR. Zulevic-Covad this has been a tough issue for both companies and that Covad was just looking for a possible solution.

Williams-Qwest asked if Covad was intending to physically move splitters. Zulevic-Covad stated that there was no move necessary; Covad would just take over maintenance of splitters. Williams-Qwest stated that the issue was that when Covad provisions loops Qwest sometimes makes mistakes.

Cook and Williams had no further questions.

Confirm Areas and Products Impacted White-Qwest confirmed that the attendees were comfortable that the request appropriately identified all areas and products impacted.

Confirm Right Personnel Involved White-Qwest confirmed with the attendees that the appropriate Qwest personnel were involved. He stated that Lillian Robertson would also be involved in analyzing this CR. Williams-Qwest stated that he would work with Robertson on this CR.

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

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

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

CenturyLink Response

August 12, 2003

REVISED RESPONSE For Review by CLEC Community and Discussion at the August 20, 2003, CMP Product/Process Meeting

John Berard Covad Communications

SUBJECT: Qwest’s Change Request Response - CR #PC031103-1

Qwest accepts this revised CR and proposes offering an optional maintenance program for Common Area Splitter configurations.

Diagram A, attached, depicts a typical configuration for a CAS

In this configuration Qwest maintains the common area splitter configuration and all provisioning of loops. Presently Qwest also performs all maintenance on the splitter shelf including splitter card installation and replacement. Qwest also keeps records of CAS in the administrative/engineering system SWITCH/FOMS.

The current DMARC separating the CLEC controlled cabling from the Qwest network is the rear of the splitter shelf as shown in Diagram A. The CLEC also has access to the ICDF frame and specifically the voice block for testing purposes (Diagram A).

Under this revised plan, the CLEC would have the option to have Qwest perform the maintenance, as is currently the practice, or the CLEC could perform the splitter card maintenance.

To facilitate the CLEC’s option to perform maintenance, Qwest proposes the following changes.

1. Qwest will allow the CLEC to access the front of the splitter shelf for testing thereby permitting test of a splitter card by the CLEC (Diagram A). 2. Qwest will allow the CLEC to perform maintenance on the splitter cards including replacement as necessary. 3. Qwest will continue to provision the CAS and will control the engineering configuration database for CAS. For new circuits, Qwest will install and provision the new splitter cards as necessary. 4. Qwest will continue to maintain the splitter shelves and Common Area Splitter bays. 5. CLEC’s will have the option to perform maintenance on the splitter cards or continue to have Qwest control all maintenance. 6. If the CLEC impairs a Qwest voice customer during the maintenance of the splitter cards Qwest may temporarily remove the data portion of the circuit. 7. The monthly recurring fees will be adjusted to remove the maintenance cost for those CLECs electing to perform the CAS splitter card maintenance. 8. The CAS shelves will be clearly designated to identify those shelves maintained by Qwest or the CLEC.

This solution addresses Covad’s primary concern of maintenance of the CAS and enables Covad and other CLECs to dispatch their technicians to correct a defective splitter card without having to generate a trouble/maintenance ticket through Qwest.

For Qwest, the proposed solution will require training and process updates but will not require the introduction of an entirely new product that would be cost prohibitive.

The CLECs also have the option to place the splitters in their collocation site eliminating any maintenance issues.

Sincerely,

David Williams Qwest Wholesale Product Manager 303-896-8166

================================================ June 11, 2003

REVISED RESPONSE For Review by CLEC Community and Discussion at the June 18, 2003, CMP Product/Process Meeting

John Berard Covad Communications

SUBJECT: Qwest’s Change Request Response - CR #PC031103-1

Covad has requested a change to the common area splitter product as follows: “Covad requests to be allowed to convert any or all existing Common Area Splitter Collocation arrangements to Cageless Shelf at a time Collocation.” In response to this CR Qwest provides the following response.

1. Issue 1. Covad requested to convert all existing Common Area Splitter Collocation arrangements to Cageless Shelf at a time Collocation. In order to change what now is a virtual collocation product to a cageless product, Qwest would require the development of a brand new product. Qwest's cageless collocation process is based on a per bay basis so this would not follow as a simple variation to the existing cageless collocation process. The Common Area Splitters are currently provisioned and maintained by Qwest. In a proposed conversion to a cageless product, a new provisioning process would be required in addition to a reconfiguration of the network to redefine the DEMARC. Qwest billing software changes would also be required. All of these changes would require significant funding from Qwest and none are practical when Common Area Splitter collocation is an optional process and experiences low ordering volumes. The CLEC always has the option to locate the splitters into their collocation space. The chart below summarizes the required effort to implement a new common area splitter (CAS) proposed by Covad.

Task Person Months Define New Product 4 Create M&P 1 Define Provisioning Process 4 Create M&P 1 Implement software changes for billing system 3 Update PCAT and documentation 2 Create Amendment Language 2 Total 17

Qwest rejects this portion of the request because it is not economically feasible.

2. From Qwest’s further evaluation of this change request, it appears that Covad’s primary issue is maintenance of the splitter and, specifically, the splitter cards. While there was no documentation provided with this CR to indicate that any maintenance issues exist, Qwest proposes offering an optional maintenance program for Common Area Splitter configurations to address Covad's apparent concern.

Diagram A, attached, depicts a typical configuration for a CAS

In this configuration Qwest maintains the common area splitter configuration and all provisioning of loops. Presently Qwest also performs all maintenance on the splitter shelf including splitter card installation and replacement. Qwest also keeps records of CAS in the administrative/engineering system SWITCH/FOMS.

The current DMARC separating the CLEC controlled cabling from the Qwest network is the rear of the splitter shelf as shown in Diagram A. The CLEC also has access to the ICDF frame and specifically the voice block for testing purposes (Diagram A).

Under this revised plan, the CLEC would have the option to have Qwest perform the maintenance, as is currently the practice, or the CLEC could perform the splitter card maintenance.

To facilitate the CLEC’s option to perform maintenance, Qwest proposes the following changes.

1. Qwest will change the DMARC for CAS and allow the CLEC to access the front of the splitter shelf for testing thereby permitting test of a splitter card by the CLEC (Diagram A). 2. Qwest will allow the CLEC to perform maintenance on the splitter cards including replacement as necessary. 3. Qwest will continue to provision the CAS and will control the engineering configuration database for CAS. For new circuits, Qwest will install and provision the new splitter cards as necessary. 4. Qwest will continue to maintain the splitter shelves and Common Area Splitter bays. 5. CLEC’s will have the option to perform maintenance on the splitter cards or continue to have Qwest control all maintenance. 6. If the CLEC impairs a Qwest voice customer during the maintenance of the splitter cards Qwest may temporarily remove the data portion of the circuit. 7. The monthly recurring fees will be adjusted to remove the maintenance cost for those CLECs electing to perform the CAS splitter card maintenance. 8. The CAS shelves will be clearly designated to identify those shelves maintained by Qwest or the CLEC.

This solution addresses Covad’s primary concern of maintenance of the CAS and enables Covad and other CLECs to dispatch their technicians to correct a defective splitter card without having to generate a trouble/maintenance ticket through Qwest.

For Qwest, the proposed solution will require training and process updates but will not require the introduction of an entirely new product that would be cost prohibitive.

The CLECs also have the option to place the splitters in their collocation site eliminating any maintenance issues.

Sincerely,

David Williams Qwest Wholesale Product Manager 303-896-8166

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May 14, 2003

DRAFT RESPONSE For Review by CLEC Community and Discussion at the May 21, 2003, CMP Product/Process Meeting

John Berard Covad Communications

SUBJECT: Qwest’s Change Request Response - CR #PC031103-1

This is a preliminary response regarding Covad CR PC031103-1. This CR requests that CLECs be allowed to convert any or all existing Common Area Splitter Collocation arrangements to Cageless Shelf at a time collocation.

Qwest is currently working internally to identify a solution to this request. Because there are a large number of issues Qwest must analyze, Qwest proposes moving this Change Request into Evaluation Status while Qwest prepares a complete answer to this request.

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

Sincerely,

Dave Williams Product Manager Qwest Corporation