Wholesale: Products & Services

Open Product/Process CR PC032504-1 Detail

Description Of Change

Expected Deliverables: As soon as possible.

Project Meetings

9/15/04 CMP Meeting Minutes Cindy Buckmaster – Qwest advised that we performed a test review on 19 order examples to make sure circuits were correctly tagged. The test was successful. This week Covad sent examples that Qwest will also review to make sure circuits are correctly tagged. Qwest will provide status at the next monthly CMP meeting. This CR will remain in CLEC Test Status.

8/16/04 CMP Meeting Mintues Cindy Buckmaster – Qwest advised this process was implemented and effective August 3. John Berard – Covad asked how will Covad know this process is in place. John requested a review by Qwest of a set number of examples. Cindy agreed to propose the review suggestion to Network. If agreed, Qwest will select a few Central Offices and have the Supervisor check to make sure the circuits were tagged. John Berard – Covad will send the order information that will be verified to Cindy Macy for 6 orders installed after August 3, 2004 (two in each region). If an audit is agreed to, Qwest will add additional circuits to the list to create a statistically valid sample. This CR will move to CLEC Test Status.

July 21, 2004 CMP Meeting notes: Cindy Buckmaster – Qwest recapped the request. Cindy advised that Qwest currently marks anything above a DS0 circuit (not analog circuits), and with this CR Qwest has expanded the process to include DSL circuits (not including POTs process requests for Line Sharing and Line Splitting). In order to make the information available to the technicians we have updated the tech books. Tech book updates occur every 12 – 18 months. We have to train the technicians and we anticipate this to be completed the middle of August. Qwest will issue a Level 1 notification when this becomes effective. This CR will remain in Development status.

June 16, 2004 CMP Meeting notes: Cindy Macy – Qwest advised this CR is in progress. The technician books need to be updated. Training the technicians will occur after the books are updated. Qwest anticipates implementing this towards the end of July. This CR will remain in Development Status.

May 19, 2004 CMP Meeting notes: Cindy Buckmaster – Qwest reviewed the response and advised that Qwest will support this CR. Cindy recapped the intent of the CR, reviewed Wholesale’s current process, explained the parity of the process with Retail for analogous circuits and potential impacts of additions beyond what Qwest has agreed to in this response. Cindy advised that Qwest will support this process on additional products identified in the response. This CR will move to Development status.

April 21, 2004 CMP Meeting notes: Mike Zulevic – Covad presented this CR. Mike explained that Covad would like for Qwest to provide SSP on certain UNE Loop type services. This would provide the ability to specify on a loop by loop basis when the order is placed that protectors are needed on the frame. Today most are black, except the SSP ones have red protectors. This tells the technician that the circuit should not be opened unless they get an okay from the customer. This is done on cross connects also, and on outside plant. These circuits are not to be moved without the proper release from the customer. This has been in place for 40 – 50 years on SSP. We need it now on additional data circuits. Bonnie Johnson – Eschelon asked what would the customer use the circuit for? Mike advised burglar alarms, data, FAA, control and monitor traffic lights, fire department and some are POTS lines. In the future VOIP lines will need this. Cindy Buckmaster – Qwest asked if Mike was aware of Qwest’s Telecommunications Service Priority (TSP). This allows the customer to identify critical and expedited circuits. Cindy Buckmaster also clarified that the type of circuits are data, not POTS circuits. Mike advised some are ordered as 2Wire loop non loaded, but they are data capable loops. Cindy verified they are not 2Wire analog loops? Mike agreed Covad’s loops are not analog, but other CLECs may have 2W analog loops. Cindy advised we will look into this CR. This CR will move to Presented Status.

Clarification Meeting April 9, 2004 1-877-552-8688 7146042# PC032504-1 Special Service Protection for UNE Loops

Attendees John Berard – Covad Cindy Buckmaster - Qwest Denny Graham – Qwest Cindy Macy – Qwest

Meeting Agenda: Action 1.0 Introduction of Attendees Attendees introduced

2.0 Review Requested (Description of) Change John Berard – Covad reviewed the change request. John explained that this service is already offered on other products, such as Switch net 56 and DDS. Cross connection equipment is red flagged which alerts technicians to take special steps before working on the facility. John advised Covad would like to be able to request this service on specific accounts provided via UNE Loop also. Covad is launching a new product and some of those customers will be consider their service critical and may want the protection service available to them. Cindy Buckmaster verified the product lines that John is requesting this service to be available include Analog, digital capable loops including non-loaded, XDSL-I, ADSL, ISDN and DS1 and DS3. John agreed. Denny Graham advised that Qwest marks the facilities in the central office by placing red heat coils and jumpers or red caps and in the field by placing red jumpers or red caps. Denny advised that process changes would be required. Cindy Buckmaster advised we would have to look at the service order process and determine the impacts. Additionally we need to look at the practice on a geographic basis to ensure we incorporate the correct process and color used. Qwest will evaluate the viability of the service requested. Cindy Buckmaster asked John what their interval was for deploying their new product that would benefit from this service. John advised in the next month.

3.0 Confirm Areas & Products Impacted Cindy Buckmaster verified the product lines that John is requesting this service to be available include Analog, digital capable loops including non-loaded, XDSL-I, ADSL, ISDN and DS1and DS3 .

4.0 Confirm Right Personnel Involved Team agreed that Lori Langston needed to be involved.

5.0 Identify/Confirm CLEC’s Expectation Provide SSP on identified products. 6.0 Identify any Dependent Systems Change Requests none

7.0 Establish Action Plan (Resolution Time Frame) Covad will present the CR at the April CMP Meeting Qwest will provide our Response at the May CMP Meeting

CenturyLink Response

For Review by the CLEC Community and Discussion at the May 19, 2003 CMP Meeting

John Berard Covad

SUBJECT: Qwest’s Change Request Response - PC032504-1 “Special Service Protection (SSP) for UNE Loops ”

‘Covad proposes that a product be developed which can be ordered with a UNE Loop that will provide Special Service Protection at all cross-connects points in the Qwest network. This protection has been provided by Qwest for critical customer circuits (i.e.; alarm circuits, high capacity data circuits, emergency services circuits, etc.) for many years and Covad would like the option of ordering this for certain UNE Loops. These cross connect points, as well as the protector frame “heat coils” are either red, or have red devices attached that alert the technician to take special steps prior to initiating invasive actions for testing or maintenance. These cross connect points are “protected” at all possible points both in the central office, as well at field connection points.’

Qwest concurs with Covad’s request, currently performs this function for many circuits and will further expand that process as identified below.

In the evaluation of this request Qwest considered a number of factors: 1) Intent of the CR, 2) Current Wholesale process, 3) parity of that process with Retail process for analogous circuits, 4) Potential Impacts of Additions Beyond that Agreed to Here-in.

Each of these steps is addressed in this response. 1) Intent of the CR – based on the conversation in both the clarification meeting and in the subsequent CMP meeting it is Qwest’s interpretation that the CLECs want to ensure data integrity and avoid unnecessary down time. It is anticipated that by identifying certain ‘services’ by ‘color-coding’ the jumpers and other equipment could draw the attention of technicians causing them to exercise additional caution in their presence. Based on that assumption, it may help to re-iterate Qwest’s current practice of ‘marking’ circuits for Special Service Protection.

2) Current Wholesale Process – as mentioned at CMP and in other CRs currently under review, Qwest does mark some circuits to draw a technician’s attention to the need to operate carefully when in their presence. Those circuits currently include a) All Telecommunication Service Priority (TSP) Circuits – as mentioned before, that application is made to the Government, Qwest manages those circuits as identified by the applicable contacts at the City, State and Federal level, b) All Designed Data Services – including High Capacity Services (DS1 and above), all ISDN Circuits, and all Designed Data Capable Circuits. Each of those circuits are currently ‘marked’ according to a standard practice. The Central Office equipment is marked with Red Heat Coils and Jumpers and field terminations and cross connects are ‘marked’ with red cross jumpers, tags and/or termination caps. At present, Qwest is already marking the dispatched UBLs ordered as ISDN Capable, xDSL-I Capable, ADSL Compatible or DS1/DS3 at parity with Retail.

3) Parity of that Process with Retail Process for analogous circuits – This is at parity with what Qwest currently provides in its Retail environment. As DSL is provisioned via the Plain Old Telephone Service (POTS) flow for Retail, none of the Retail DSL capable circuits are specially marked. In the past, Qwest did not assume that all LX-N circuits were data, however, as the CLEC Unbundled Requests (for Unbundled Network Elements) flows via the Designed Service Flow, Qwest is prepared to offer to mark (in the manner defined above) all dispatched Data Capable UBL circuits including the 2/4 wire Non-Loaded Loop (where the NC Code = LX-N). Effective with this notice, Qwest will mark these circuits (by class only – Data Capable) similar to the marking already provided for ISDN/xDSL-I and DS1/DS3. This (List Document Name) attachment 2 offer is for DSL only and not for DSL/Analog or split services (i.e. Line Sharing, Line Splitting, Loop Splitting or the Shared Distribution Loop). Additionally, this offer is for circuits on a going forward basis and not for the embedded base of UBL circuits.

4) Potential Impacts of Additions Beyond that Agreed to Here-in - an effort to mark any other circuits (i.e., Sharing, Line Splitting, Loop Splitting, Shared Distribution Loop or the Analog UBL), not in parity with those done in current practice, will be denied for two reasons, Economic In-feasibility and No Measurable Benefit to both Qwest and the CLEC. The first reason would be due to the fact that Qwest would need to equip and re-train all technicians who currently work on POTS circuits to mark specified voice grade CLEC circuits. With 2,000 POTS Technicians currently doing this work that cost is expected to be in excess of $200K. Additional changes to the systems would be required to allow a method for CLECs to identify which circuits they would like to ‘mark’. Although the information could be added in Remarks up-front, for no or little additional cost, down-stream systems would need to carry this information to the field and would require mechanization. The second reason, No Measurable Benefit to both Qwest and the CLEC, would be based on the outcome that all CLEC circuits would be marked as un-interruptible and would disrupt the efficient use of the current network design and quickly dissipate use of any plant that would allow the provision of services requiring special plant configurations (i.e., having a Voice Grade circuit on a non-loaded loop with no option to move that non-loaded configuration for Data use). This provides no benefit to the network and would further cost Qwest the economic imbalance of providing a service to the CLECs that it isn’t equipped to provide for its own end-users.

In summary, Qwest will mark all Data Capable CLEC circuits per their local practice to draw technicians’ attention to the fact that the circuit carries un-interruptible traffic.

Sincerely, Cindy Buckmaster Manager Product Management