Wholesale: Products & Services

Open Product/Process CR PC042108-02 Detail

Description Of Change

tw telecom (fka Time Warner Telecom) is requesting an additional option associated with a ToR change. The additional option, based on volume, would treat the ToR process request differently based on the magnitude of the ToR change which would be to handle it in a bulk manner at the circuit level. Time Warner Telecom is asking for all of a CLEC’s records with Qwest - including any collocations and/or UNE circuits under all billing systems – to be processed with this optional offering.

The benefit to the CLEC is in saving the cost and resources involved in issuing all of the ASRs and LSRs for this ToR change to occur. When issuing all of the change requests, there is also a potential risk that downtime could occur.

The benefit to Qwest is that the CLEC’s records will have the correct name on them which will allow Qwest to properly process requests and negotiate trouble tickets.

Previous Description

Time Warner Telecom is requesting an additional option associated with name changes which would allow a CLEC to not have to go through a TOR (transfer of responsibility) just to have Qwest records changed for a simple name change. We understand there is an existing Wholesale process to change the ACN/ACNA in IABS and TIRKS. Time Warner Telecom is asking for all of a CLEC’s records with Qwest - including any collocations and/or UNE circuits under CRIS billing – to work the same way.

The benefit to the customer is that we would be saving the cost and resources from issuing all of the ASRs and LSRs for this simple change to occur. When issueing all of the change requests, there is also a potential risk that downtime could occur.

The benefit to Qwest is that the customer’s records will have the correct name on them which will allow Qwest to properly process requests and negotiate trouble tickets

Project Meetings

10/15/08 Product/Process CMP Meeting

Mark Coyne – Qwest stated that the notice went out September 25th and will be effective on November 9th. Mark stated that Qwest received comments and will respond in the appropriate timeframe. Bonnie Johnson – Integra stated that she was not sure who submitted comments but Integra did and asked if Qwest anticipated any changes would be made due to Integra’s comments. Mark Coyne – Qwest stated that we need to review the comments and assess if any changes would be made.

9/17/08 Product/Process CMP Meeting Susan Lorence-Qwest stated that Bob Mohr is the owner of this request and will be providing status.

Bob Mohr-Qwest said that we have evaluated this CR and that the batch/bulk is something we can offer. He said that the concept is a batch size of 200 circuits or more per CLLI or ACTL and submitted on a unique spreadsheet per product. He said that the Unbundled loop would be on 1 spreadsheet and the individual UNEs would be on another spreadsheet instead of having to submit LSRs and ASRs. He said that all circuits would be dependent on the product type within the ACTL and would be considered towards meeting the 200 circuit limit. He said that there will be an amendment created for the batch ToR with the terms and conditions as well as the new rate. He said that the amendment would have to be signed to make this available. He said that we are looking at the PCAT and plan to announce by the end of this month with a targeted date of 9/25/09. The draft amendment would be available mid October with a targeted implementation date of early November depending on comment cycle etc.

Bonnie Johnson-Integra said that she was not going to comment on the amendment part but had questions on the process. She said that in the adhoc meeting, the determination was made that it does not make any difference on why you need the ToR and that the bulk process will be available for any ToR.

Bob Mohr-Qwest said that is correct under the current ToR guidelines, i.e when it is needed. He said that this is another method for submitting the ToR circuits with a batch method. We clarified in the adhoc meeting that this is not a new direction or setting new guidelines on whether the ToR is necessary or not.

Bonnie Johnson-Integra verified that Qwest said it is available only if there are 200 or more circuits per spreadsheet with the criteria set by product. Bonnie asked if, for example, DSO and DS1 UBL would be submitted on 2 different spreadsheets.

Bob Mohr-Qwest said that we separated it by the product family so UBL, UDIT, EEL and individual UNEs would have to be on a separate spreadsheet but all of those together spreadsheets combined towards the 200 total.

Crystal Soderlund-Qwest said that is correct.

Bonnie Johnson-Integra said that you could potentially have 4 different spreadsheets but as long the 4 total 200. She asked if the USOC defines the product.

Bob Mohr-Qwest said that the class of service defines the product and that he will clarify the product family in the PCAT. He said that it is not really a preference but is needed for the tool that will run this.

Bonnie Johnson-Integra verified that Qwest said you are not requesting separating spreadsheets by CLLI and ACTL and not by BAN.

Crystal Soderlund-Qwest said that is correct and said that it ends up being per BAN because each product is usually separated by BAN.

9/4/08 Adhoc Meeting CMP Adhoc Meeting –Transfer of Responsibility questions submitted by Integra Thursday, September 4, 2008

Attendees: Susie Franke-Time Warner Telecom, Kim Isaacs-Integra, Doug Denney-Integra, Bonnie Johnson-Integra, Tim Kagle-Comcast, Jim Hickle-Velocity, Cindy Buckmaster-Qwest, Bob Mohr – Qwest, Brett Bode-Qwest, Susan Williams-Qwest, Kathy Battles-Qwest, Crystal Soderlund-Qwest, Linda Miles-Qwest, Susan Lorence-Qwest, Lynn Stecklein-Qwest

Lynn Stecklein-Qwest stated that the purpose of this meeting is to address the questions submitted by Integra on August 11, 2008 associated with Transfer of Responsibility (ToR). She said that the questions could be found on the Wholesale Calendar. She said that Qwest will be providing a high level overview of the Time Warner CR in the September CMP Meeting

Question #1 - In an effort to ensure Integra understands how Qwest can maintain that their previous responses to Integra were consistent. Integra has enhanced Qwest’s original responses to Integra with the information gained on the 8/4/08 ad hoc call. On 7/14/08, Qwest stated: “With or without the ACNA change, a corporate name change requires a TOR”. It is Integra’s understanding that the complete answer should have been: With or without the ACNA change a corporate name change requires a ToR if and only if the CLEC would like to or is obligated to change the name on the collocation.

Cindy Buckmaster-Qwest said that changing the name of a corporation implies that the CLEC is going to be submitting orders and trouble tickets under a new name. If the intent is to submit orders and trouble tickets under a name that is not currently on the collo, ToR is required.

Bonnie Johnson-Integra said if you are going to be submitting the information to Qwest for orders and trouble tickets under the old name and there is no need or desire to change the name, can they assume that no ToR is required.

Cindy Buckmaster-Qwest said that is true. If you are going to maintain your collo under the name of Eschelon and continue to submit trouble tickets and services orders under the name Eschelon, there is no change from a ToR perspective.

Bonnie Johnson-Integra asked if that would be the case if you don’t have to change the ACNA or RSID.

Cindy Buckmaster-Qwest said that the tables tie the ACNA, RSID or ZSID to a customer name that guarantees integrity on your collo and the orders and trouble tickets associated with the collo. She said that anytime you change the RSID, ZSID, ACNA or the corporate name, that change has to go into our system and ToR applies.

Bonnie Johnson-Integra said that if the name or ACNA is not changed with Telecordia, the integrity should be intact and the previous response would apply if you change the name with Telcordia.

Cindy Buckmaster-Qwest said that her previous response was based on whether you submit trouble tickets and service orders under the old name or the new name.

Bonnie Johnson-Integra said that Qwest said since the ACNA and the RSID are tied to the corporate name and that for integrity a ToR would be required to change the name. She said that if you are not changing the name with Telecordia, it’s not going to change the name on the ACNA and RSID.

Cindy Buckmaster-Qwest agreed and reiterated that there is nothing that we are doing that is forcing you to do anything. The only way a ToR applies is when you take action. If you change your name, ACNA or RSID it is because it is required by law or because you just want to and you have a collo with or without subtending circuits at Qwest, you have to go through the ToR process. The current process is circuit by circuit.

Doug Denney-Integra said that the confusion is that you keep bringing up the corporate name in with the list of ACNA, RSID etc.

Cindy Buckmaster-Qwest said that they are tied because our system looks at the ACNA and corporate name. If you submit something as ABC for the ACNA and XYZ Telecom our system will reject because they don’t match. If you want to submit as ABC and XYZ Telecom you have to go through ToR process to tell us that you are changing it.

Doug Denney-Integra said that from the CLEC view we may have a corporate name change but we may not change the way we do our ordering. From Qwest’s view, we did not have a corporate name change and that is where there is confusion is. He said that they want clarification if the way they are placing their orders is not changing from the Qwest perspective there is no need for the ToR.

Cindy Buckmaster-Qwest said that is correct and that if you are going to leave your collo under the current name and you are going to place your trouble tickets and orders under the name that you currently have your collo in, there is no ToR.

Bonnie Johnson-Integra asked if it would be safe to say that if there were some kind of a name change and they submit orders under the collo name, Qwest will stay out of that as long as we submit them as ABC RSID with ABC company. She said that you will process the order and if they are doing something they shouldn’t be doing that is their problem.

Cindy Buckmaster-Qwest said if on Jan 1 you submitted to ABC company name and ABC RSID and something happens that requires you to do something different by July 1 and Aug 1 you are still submitting orders with ABC Telecom and RSID we don’t care. There is no legal impetus that causes us to change the name of your business.

Question #2 - 7/16/08, in the July CMP Meeting Qwest indicated if there is a corporate name change and the CLEC will continue to submit orders and repair tickets under the old corporate name, the Transfer of Responsibility process does not apply. It is Integra’s understanding that the complete answer should have been: If there is a corporate name change and the CLEC does not wish to or need to change the name on the collocation and the CLEC will continue to submit orders and repair tickets under the old corporate name, the Transfer of Responsibility process does not apply.

Lynn Stecklein-Qwest said that we already addressed this question and everyone agreed.

Question #3 - Does Qwest believe the ToR applies in the following scenarios? If so, please confirm our understanding on whether the various scenarios are addressed in Time Warner Telecom’s revised change request: When a CLEC chooses to transfer a collocation site from a vacating CLEC, which results in a change to the name and ACNA/ZCID of the collocation site and any subtending circuits. This scenario is not addressed in Time Warner Telecom’s request for a bulk ToR process.

Cindy Buckmaster-Qwest said we agree it is not addressed in Time Warner’s request.

Question #4 - A CLEC chooses to change only the name of a collocation site (and therefore the subtending circuits) without a change to the ACNA/ZCID of collocation. This scenario is addressed in Time Warner Telecom’s request for a bulk ToR process.

Cindy Buckmaster-Qwest said that Time Warner is only requesting a more efficient means of requesting a ToR on a volume of subtending circuits.

Susie Franke-Time Warner said that this specifically applies on the CRIS BILLING side of the house because there is not bulk process in place like there is on the IABS side. She said that an N and D Order would be required for every UNE circuit to change the name down to the circuit level and they are requesting a bulk process. She said that at no time was this CR addressing an ACNA change. She said that this is completely based on if a ToR is necessary.

Bonnie Johnson-Integra said that changing the name down to the circuit level is still considered a ToR and that Time Warner is looking for a more efficient way of doing it rather than submitting order by order.

Bob Mohr –Qwest said that he is evaluating the CR and is approaching it from that perspective. He said that it does not change when a ToR is or is not required but instead looking at a more efficient way for performing the ToR on the circuits.

Susie Franke-Time Warner said that was a good summary of what they are requesting.

Question #5 - A CLEC chooses to change the name and ACNA/ZCID of a collocation site (and subtending circuits). This scenario is not addressed in Time Warner Telecom’s request for a bulk ToR process.

Cindy Buckmaster-Qwest said that she agreed it is not addressed. It is already understood that this is part of the original ToR process and that Time Warner Telecom is only asking how they can do that original ToR process in bulk.

Bonnie Johnson-Integra said that whatever the situation is that causes a need for a ToR, Time Warner’s CR is not addressing when you need one or not. The CR is addressing a bulk process on the CRIS side when a ToR is requested. She asked if Time Warner’s CR would include all of these situations.

Cindy Buckmaster-Qwest said that they are not asking about the ToR process or criteria. She said that they are asking that consideration be given in the existing process and criteria for a bulk request.

Bonnie Johnson-Integra asked if once you develop a bulk process for a ToR wouldn’t that apply to any ToR regardless of the reason. Cindy Buckmaster-Qwest said that the ToR process and criteria stay in tact, the development underway is whether you follow the individual LSR process or whether you have the capability to follow a bulk process whether that is a spreadsheet, process etc.

Bonnie Johnson-Integra said that we are saying the same thing.

Kim Isaacs-Integra said that in the 1st bullet where you said it was not addressed in Time Warner’s request, the bulk process would be available if they were transferring a collo site from a vacating CLEC and they have active circuits. She said that if someone is vacating a collo and they have active circuits, you require the individual orders. In this case that portion of the ToR would be gone and we would be able to use the bulk process that is being developed.

Cindy Buckmaster-Qwest said that her intent was to say that isn’t about transferring a collo site from a vacating CLEC or resulting in a change to the name and ACNA. She said that you already have that process in place. We are looking at how to do it more efficiently for a large number of circuits.

Doug Denney-Integra asked for clarification on what already having the process in place means.

Cindy Buckmaster-Qwest said that the original intent of the ToR process was for CLECs that picked up a company going out of business etc. who wanted to take over the customers left on that collo. She said at that time there were very few customers to take over. The CLEC would submit individual LSRs to convert the few customers left on the collo. She said that process is defined. Time Warner is saying today they have a substantial amount of circuits to convert and would like a bulk process.

Doug Denney-Integra said that on a previous call there were restrictions re: this process and what Time Warner Telecom was requesting. He said that he thought that in Time Warner’s CR the only change was to the corporate name and not to the RSID, ACNA etc. He asked if that is part of Time Warner request.

Cindy Buckmaster-Qwest said it is not.

Kim Isaacs-Integra said that the Time Warner CR will cover any portion in the ToR process that requires LSRs to be sent individually.

Bob Mohr-Qwest agreed and with the parameters that we develop for that offering.

Bonnie Johnson-Integra asked if those parameters were going to be any different depending if you want to change the corporate name or if you want to change the name and ACNA.

Bob Mohr-Qwest said they would be the same.

Bonnie Johnson-Integra said that there was no need to address the last 2 questions below.

Question #6 - A CLEC acquires another CLEC and requests to change the name of the collocation but not the ACNA/ZCID of the collocation. There is one corporate name with 2 separate ACNAs/ZCID. This scenario is not addressed in Time Warner Telecom’s request for a bulk ToR process.

Question #7 - A CLEC has a corporate name change but does not choose to change the name on the collocation and the CLEC chooses to continue to submit orders and repair tickets under the old corporate name.

8/20/08 Product/Process CMP Meeting

Mark Coyne-Qwest stated that this CR was revised and will be presented today by Time Warner.

Susie Franke-Time Warner said that they are requesting an additional option associated with a ToR change. The additional option, based on volume, would treat the ToR process request differently based on the magnitude of the ToR change which would be to handle it in a bulk manner at the circuit level. Time Warner Telecom is asking for all of a CLECs records with Qwest - including any collocations and/or UNE circuits under all billing systems – to be processed with this optional offering. The benefit to the CLEC is in saving the cost and resources involved in issuing all of the ASRs and LSRs for this ToR change to occur. When issuing all of the change requests, there is also a potential risk that downtime could occur. The benefit to Qwest is that the CLECs records will have the correct name on them which will allow Qwest to properly process requests and negotiate trouble tickets. She said that Time Warner’s goal is to address the current process to avoid having to write N & D orders to make this change on 3500 UNE CKTs resulting in 7000 orders.

Bob Mohr-Qwest asked if Time Warner’s main focus is on the bulk process and not collocation.

Susie Franke-Time Warner said that special access is managed today by a special project and is handled on a spread sheet. She said that with this change they won’t have to write 7000 UNE orders.

Kim Isaacs-Integra said that Integra has sent a number of e-mails re: questions on ToR and asked why they aren’t posted in the CR.

Lynn Stecklein-Qwest said that they will be posted in the CR. She said that an adhoc meeting to address the last questions received from Integra has been scheduled for next week. The e-mails and responses will be posted in the CR after that meeting.

PC042108-02 CLEC Name Change – Same Customer Monday, August 4, 2008 12:00 PM – 1:00 PM Mountain Time

Attendees:

Susie Franke-Time Warner Telecom, Kim Isaacs-Integra, Doug Denney-Integra, Jeff Sonnier-Sprint, Loriann Burke-XO Communication, Brenda Bloemke-Comcast, Kasha Fauscett-Comcast, Cindy Buckmaster-Qwest, Susan Williams-Qwest, Kathy Battles-Qwest, Crystal Soderlund-Qwest, Bob Mohr-Qwest, Lynn Stecklein-Qwest

Lynn Stecklein-Qwest stated that the purpose of this meeting is to discuss the revised CR submitted by Time Warner on July 16, 2008. She reviewed the CR description: tw telecom (fka Time Warner Telecom) is requesting an additional option associated with a ToR change. The additional option, based on volume, would treat the ToR process request differently based on the magnitude of the ToR change which would be to handle it in a bulk manner at the circuit level. Time Warner Telecom is asking for all of a CLECs records with Qwest - including any collocations and/or UNE circuits under all billing systems – to be processed with this optional offering. The benefit to the CLEC is in saving the cost and resources involved in issuing all of the ASRs and LSRs for this ToR change to occur. When issuing all of the change requests, there is also a potential risk that downtime could occur. The benefit to Qwest is that the CLECs records will have the correct name on them which will allow Qwest to properly process requests and negotiate trouble tickets.

Susie Franke-Time Warner Telecom said that many Carriers are impacted by this same issue and companies are constantly acquiring other companies. She said that she handles other ILECs and Qwest is the only one that requires a name change down to the circuit level.

Kim Isaacs-Integra asked how Qwest is defining ‘bulk’ (i.e. spreadsheet or similar to the bulk disconnect process in the IMA GUI).

Susie Franke-Time Warner Telecom said that she did not think Qwest had defined that yet and is why they issued this revision.

Cindy Buckmaster-Qwest said that the request today was modified by Time Warner and we are having this meeting to determine if there are any questions on the modification. Cindy provided background as to when we reviewed this process in 1998. She said that the current ToR process was to allow companies to acquire other companies leaving the market. She said that we initially had these discussions when Rhythms/Jato were bought out and abandoned their customers. She said that we were trying to help transition those customers from the Rythyms and Jato collos to their new provider and that’s what ToR was about. Cindy said that if the company is agreeable to continue to do business under the name that they are currently doing business under by submitting trouble tickets and service orders under the circuits attached to the collo there isn’t any impact. She said that it’s only when the company requires thru their own initiatives to submit service orders and trouble tickets under a different name, then TOR comes into play. She said that we have to change the name on the account from end to end from the collo to the circuit level.

Kim Isaacs-Integra stated that if there is a corporate name change and you choose to continue submitting orders under the same name using the same RSID, then TOR doesn’t apply. She said that your corporate name is one thing and the way you submit orders is another but if you can manage that, then there is no need for ToR.

Cindy Buckmaster-Qwest said that is correct.

Susie Franke-Time Warner said that Time Warner Telecom is now tw telecom and under legal obligation they have to change the name.

Cindy Buckmaster-Qwest said that if we were to receive a trouble ticket or service order into our system with the name tw telecom we would not know what to do with it. The collo has to have the name tw telecom for the technician to understand where the circuits are going to and from. She said that in the Time Warner Telecom case, with the acquisition of the Xspedius account, is that you have this account but you can’t use our name. She said that it becomes an issue to submit the request under Time Warner or tw telecom and that we need to communicate thru all the channels and the only way to do that is with ToR.

Susie Franke-Time Warner Telecom said that with Xspedius there is a combination of potential of ACNA and OCN codes as a result of that acquisition. She said that they delayed the name change from Xspedius because the Time Warner name was changing too and they wanted to do everything at the same time. She said that special access is managed under the project arena. She said that It is primarily the 3500 UNE circuits requiring an N and D totaling 7000 orders and that they were hoping to avoid the additional work for both them and Qwest. She said that it sounds like if they are agreeable in keeping the Xspedius name under all the UNE circuits and we would agree to submit any change under the name of Xspedius Qwest would not require any of those circuits to be changed.

Cindy Buckmaster-Qwest said that if you have a license to use Xspedius and you leave the circuits terminated at the point they are currently in the CO and continue to submit trouble tickets and service orders under the name of Xspedius on those circuits, you don’t have to follow the ToR process. She said that you would be Time Warner doing business as Xspedius on those accounts. She said that on the Time Warner accounts you would be Time Warner doing business as tw telecom and in both cases you don’t have to follow the ToR process. She said when you are required to change the name of the provider at the collo then circuits that subtend that collo have to change.

Susie Franke-Time Warner Telecom said that the collo name would have to change to tw telecom and if the collo is under a different name than the circuit name, that is when the ToR comes into play.

Cindy Buckmaster-Qwest agreed and said that we can’t change the name of the collo without changing the name of all the subtending circuits.

Susie Franke-Time Warner Telecom asked if this would fall under any UNE that fall under specific collos. She said that the only thing that might help are the UNE circuits not under the name of Time Warner but under the name of Xspedius. She said that is they don’t have to change they would probably keep them under Xspedius.

Cindy Buckmaster-Qwest said that they can maintain them under how you are currently managing them or you can change from Xspedius to tw telecom. She said that in that case you would only have 1 transfer which would be more efficient for them and Qwest.

Susie Franke-Time Warner asked if Qwest would require the change down to the circuit level on the Xspedius UNE circuits that fell under the collo.

Cindy Buckmaster-Qwest said that if you have to change the name of the collo, you have to change down to the circuit level.

Susie Franke-Time Warner Telecom said that they issued the CR to avoid having to do 7000 orders. (N&D orders). She said that their service manager director gave her that information that there would be 2 separate orders and 2 separate costs based on what is in their ICA by state.

Cindy Buckmaster-Qwest said that you really only have to do a N/D order if you are re-terminating but if that is how you write your orders that might be what she is referring to.

Susie Franke-Time Warner Telecom said that nothing would change as far as the UNE circuit except the name.

Cindy Buckmaster-Qwest said that if you are going to leave them in the same location and continue doing business under the name they are currently under, you don’t have to go thru the ToR process. She said that if you are required to change the name and can’t continue to do business under the old name you have to go through the ToR for the collo and subtending circuits. She said that we want to look at a proposing a bulk process that would be more efficient in handling the mergers and acquisitions that are happening more frequently.

Susie Franke-Time Warner Telecom said that this will still impact them because they will have to change the name at the collo level and, therefore, all the circuits. She asked if Qwest would be willing to do this as a project like special access to avoid the work effort and the cost of doing 7000 orders.

Kim Isaacs-Integra said that the cost question keeps coming up and asked if the bulk process would have a cost associated with it. She said that current TOR rates are $20 to $30 a circuit.

Cindy Buckmaster-Qwest that we will be evaluating to determine what costs are involved and determine if there is a modification to the costs, a reduction to the cost or whether there is no cost at all.

Susie Franke-Time Warner Telecom said that cost is a concern but they are just as much as concerned with the work effort with N/D orders and the chance that a circuit could be taken down.

Doug Denney-Integra asked why the name of the collocation needed to change.

Susie Franke-Time Warner Telecom said that legally they can’t have the name as Time Warner Telecom anymore.

Doug Denney-Integra asked if that was an issue for Xspedius.

Susie Franke-Time Warner Telecom said that they would have to figure out what collos are under the Xspedius name.

Kim Isaacs-Integra said that this would be a decision made by Time Warner Telecom and is not that Qwest is telling you have to change the name.

Susie Franke-Time Warner Telecom said that this is internal we have to change the name (July 1st)

Cindy Buckmaster-Qwest said (8/8/08 Comments to minutes received from Integra) we will not tell you, you have to make a name change. The change is driven by the CLEC. If you don’t want to change the name on the collocation then you don’t need to do anything.

Susie Franke-Time Warner Telecom said that whatever name is at the collo level is what has to be at the circuit level as well. She said that they want to move forward with the request and she will check to see if they have the ability to keep the collo under the Xspedius name. She still wants to see that if they are required to change the collo level how can we make it easier at the circuit level.

Kim Isaacs-Integra said that there is still the open question on the definition of bulk.

Cindy Buckmaster-Qwest said that the definition of bulk is under evaluation. She said that to define bulk you would have a single collo that has x number of subtending circuits and x is yet to be determined. She said that x would be the efficiency point that is determined by the cost process and that cost process would determine the efficiency point at this level. She said that there would be less cost involved than at a level of that many single LSRs and that the X number overall is how that affects our business and how it affects you input mechanism.

Kim Isaacs-Integra said that decision needs to be made as to where this falls - per collo, per company or per state and that you still have to massage the numbers.

Doug Denney-Integra said that it should be clear in Time Warners request that this process would not require the placement of individual orders for each circuit.

Susan Williams-Qwest said that is correct and that there would not be any change to the ACNA or OCN or ZSID information and that this is a name change.

Cindy Buckmaster-Qwest said that we have a matching mechanism that takes your name and assigns it to an ACNA (assigned by telecordia). She said that if you change the name and we go into a table and see that the ACNA does not belong to this name anymore impact how orders flow and to be processed and the level of integrity on the circuity on your collo. She said that what we are looking at now is the name change piece.

Doug Denney-Integra asked the question if they had 2 entities in a state like Integra/Eschelon and went with the single name, they would still be placing orders separately because they would have different profiles due to different ACNAs on each collo (8/8/08 Comments to minutes received from Integra) and would not need a Transfer of Responsibility.

Cindy Buckmaster-Qwest said that you would still be placing orders and trouble tickets under separate profiles because you would have separate ACNAs (Integra and Eschelon). She said that when you get to the point that you don’t want to submit trouble tickets under the Eschelon name and now want to use Integra, we have to modify the tables to say that Integra is now under this ACNA and not Eschelon. She said that becomes an issue because we have to figure out the multiple ACNA issue for you. She said we are not addressing this scenario today.

Kim Isaacs-Integra confirmed that you (Qwest) are not currently addressing two separate ACNAs with the same name.

Doug Denney-Integra asked if the performance measures reports would still be reported separately by ACNA.

Cindy Buckmaster-Qwest said they would.

Susie Franke-Time Warner Telecom said that the ACNA and OCN are very closely related to a name change. She asked if Qwest could provide an estimate on timeframes for this request.

Lynn Stecklein-Qwest said that this CR will be presented in the August CMP meeting as a formality and that we need to regroup internally. She said that we should be able to provide a response in the September CMP Meeting.

Susie Franke-Time Warner Telecom said that they initiated this request in April and legally they should have changed the name on July 1st and asked if this request could be expedited.

Lynn Stecklein-Qwest said that Qwest would look into that.

8/11/08 E-mail received from Integra Hello Lynn,

Qwest indicated that its responses to Integra’s questions on when Transfer of Responsibility (ToR) process applies have been consistent. Qwest’s previous answers appeared to have been inconsistent but in fact Qwest’s responses may have been incomplete.

On the 8/4/08 ad hoc call to discuss tw telecom’s revised change request (PC042108-02), Qwest clarified that if the CLEC has a name change and is going to leave circuits in the same location and continue doing business under the old business name, then the CLEC does not have to go through the ToR process. Qwest indicated that if the CLEC was required to change the name or could not continue to do business under the old name the ToR for the collocation and subtending circuits applies. Qwest further clarified that Qwest would not drive the name change. A name change to the collocation is driven by the CLEC. If CLEC does not want to or need to change the name on the collocation then Qwest will not force a CLEC to complete a ToR.

In an effort to ensure Integra understands how Qwest can maintain that their previous responses to Integra were consistent. Integra has enhanced Qwest’s original responses to Integra with the information gained on the 8/4/08 ad hoc call.

7/14/08, Qwest stated: “With or without the ACNA change, a corporate name change requires a TOR”. It is Integra’s understanding that the complete answer should have been: With or without the ACNA change a corporate name change requires a ToR if and only if the CLEC would like to or is obligated to change the name on the collocation. 7/16/08, in the July CMP Meeting Qwest indicated if there is a corporate name change and the CLEC will continue to submit orders and repair tickets under the old corporate name, the Transfer of Responsibility process does not apply. It is Integra’s understanding that the complete answer should have been: If there is a corporate name change and the CLEC does not wish to or need to change the name on the collocation and the CLEC will continue to submit orders and repair tickets under the old corporate name, the Transfer of Responsibility process does not apply. Does Qwest believe the ToR applies in the following scenarios? If so, please confirm our understanding on whether the various scenarios are addressed in tw telecom’s revised change request:

When a CLEC chooses to transfer a collocation site from a vacating CLEC, which results in a change to the name and ACNA/ZCID of the collocation site and any subtending circuits. This scenario is not addressed in tw telecom’s request for a bulk ToR process. A CLEC chooses to change only the name of a collocation site (and therefore the subtending circuits) without a change to the ACNA/ZCID of collocation. This scenario is addressed in tw telecom’s request for a bulk ToR process. A CLEC chooses to change the name and ACNA/ZCID of a collocation site (and subtending circuits). This scenario is not addressed in tw telecom’s request for a bulk ToR process. A CLEC acquires another CLEC and requests to change the name of the collocation but not the ACNA/ZCID of the collocation. There is one corporate name with 2 separate ACNAs/ZCID. This scenario is not addressed in tw telecom’s request for a bulk ToR process. A CLEC has a corporate name change but does not choose to change the name on the collocation and the CLEC chooses to continue to submit orders and repair tickets under the old corporate name. Thank you.

Kim Isaacs | ILEC Relations Process Specialist

7/16/08 Product/Process CMP Meeting Mark Coyne-Qwest stated that this CR is being denied based on the fact that the option which Time Warner is requesting is already an element of the ToR process. There is no alternative to that process to change only BAN records, because the applications and repair tickets are edited to ensure only the customer of record places orders and repair tickets on the elements they own. Qwest is, however, open to working with Time Warner to revise their CR in order to address a process option that will allow for bulk processing based on the magnitude of the request.

Susie Franke-Time Warner asked who they should work with to revise their CR.

Mark Coyne-Qwest said that they should work with their Service Manager (Kathy Battles/Qwest).

Kathy Battles-Qwest said that she would work with Time Warner.

Susie Franke-Time Warner asked if Qwest would have a response to the revised CR in August.

Mark Coyne-Qwest said that we would get the team together once the revised CR is submitted.

Kim Isaacs-Integra said that there is CLEC industry wide interest and Integra would like to be involved in the development of the CR.

Mark Coyne-Qwest said that Qwest would schedule an adhoc meeting to give the CLECs an opportunity to provide input.

Doug Denney-Integra asked for clarification on the denial and when ToR charges don’t apply.

Cindy Buckmaster-Qwest said that if it is specific to collocation (7/24/08 Comments to minutes received from Integra) and you have subtending circuits with a name change, ToR applies. She said with other products (i.e. resale, UNE-P, tariff) are not under the ToR process). Other mechanisms and processes besides the ToR process are used.

Doug Denney-Integra cited (7/24/08 Comments to minutes received from Integra) an example using McLeod/Paytec merger assuming where McLeod changed their company name to Paetec.

Cindy Buckmaster-Qwest said you just can’t change the account at the BAN level on collocation. She said that on the collocation side you have to change to the circuit level.

Doug Denney-Integra said that in the Paetec situation they did not request a change at the circuit level (7/24/08 Comments to minutes received from Integra) there is no change to the ACNA.

Cindy Buckmaster-Qwest said that if orders and trouble tickets are to be submitted as Paetec the ToR process is required to change the name on the accounts all the way down to the circuit level. (7/24/08 Comments to minutes received from Integra) If submitting orders and trouble tickets under the old name the ToR process is not needed.

Susie Franke-Time Warner said that she would hold her comments until the CR is revised.

6/18/08 Product/Process CMP Meeting

Mark Coyne-Qwest stated that this CR is currently in an evaluation status. He said that the Qwest SMEs are meeting internally and hope to have a response in July.

E-mail sent to Time Warner 5/29/08

Hi Susie,

We are currently evaluating your request and will be providing a response in the June 18th Monthly CMP Meeting,

Thanks,

Lynn

--Original Message-- From: Franke, Susan [mailto:Susan.Franke@twtelecom.com] Sent: Thursday, May 29, 2008 1:02 PM To: Stecklein, Lynn Subject: RE: Action required: May CMP Meeting Minutes for your reviewandfeedback

Hi Lynn-

Just curious, how long does it normally take to get feedback from this?

Susie Franke Sr. Carrier Account Manager Time Warner Telecom Access Management 303-566-1782 (Office) 877-206-1646 (Pager) 8772061646@usamobility.net susie.franke@twtelecom.com

5/21/08 Product/Process CMP Meeting

Susie Franke-Time Warner said that they are requesting an option associated with a name change which would allow a CLEC to not have to go through a Transfer of Responsibility (TOR) to have the records changed for a simple name change. Susie said that with the Time Warner merger they would like the name change to the BAN level and that they don’t care about going down to the circuit level. She said that this option would apply to LSRs and ASRs. Mark Coyne-Qwest said that Qwest will assign an owner and if there were additional questions an adhoc meeting would be scheduled.

4/22/08 Acknowledgement sent to Time Warner:

Susie,

Qwest has received the Change Request form you submitted April 21, 2008. As a result of the request, PC042108-02 has been created as a Procuct/Process CMP CR. This change request will be presented in the May Monthly CMP Meeting to be held on May 21, 2008. If you do not agree with the classification of this CR as a Product/Process request, please advise ASAP. Attached for your reference is a current copy of your Change Request. Your change request will appear in the next scheduled update of the "CMP Change Requests - Product/Process Report" on the Qwest CMP web site. You may access the interactive report at http://wwwqwest.com/wholesale/cmp/changerequest.html. (Scheduled updates take place every Monday, Wednesday, and Friday, except for Qwest holidays.)

I am the Qwest CRPM (Change Request Project Manager) assigned to this CR. If you have any questions, please feel free to contact me at Lynn.Stecklein@qwest.com.

Thank you,

Lynn Stecklein Qwest Wholesale CMP

4/21/08 CR revised per Time Warner

CenturyLink Response

For Review by CLEC Community and Discussion at the July 16, 2008 CMP Meeting

Susie Franke Time Warner Telecom

SUBJECT: Qwest’s Change Request Response – PC042108-02 “CLEC Name Change – Same Customer”

This letter is in response to Time Warner Telecom Change Request (CR) PC042108-02. Time Warner Telecom is requesting an additional option associated with name changes which would allow a CLEC to avoid the Transfer of Responsibility (ToR) process to do a legal name change that does not include a transfer of responsibility between entities. Time Warner Telecom indicated they believe there is an existing Wholesale process to change the ACN/ACNA in IABS and TIRKS at the summary BAN level, and are requesting a similar process to be used to do a name change. The Time Warner Telecom CR is asking for all of a CLEC’s records with Qwest, including any collocations and/or UNE circuits under CRIS billing, to have a name change using a similar process.

Qwest understands that Time Warner Telecom is requesting a name change without a ToR between entities at the summary BAN level.. However, within Qwest, the activity referred to as a simple name change by Time Warner is in fact part of the TOR process. In regard to the point about requesting a similar process to IABS, it is important to note that other services that terminate in the Collocation may bill via various Qwest billing systems and must also follow this same TOR process. The Qwest ToR process was developed to accomplish all of the necessary changes attributed to any change of name, including but not limited to ensuring record ownership accuracy, insuring circuit ownership accuracy, placing current and future orders/repair tickets on those circuits, updating all Qwest internal systems that feed IMA for future use, and possible re-stenciling of the Central Office equipment to ensure connections go to the proper location.

Because of the need to ensure the integrity of our customers’ future activity with Qwest, it is not possible to separate the steps of the ToR process. Therefore, Qwest respectfully denies this request.

Sincerely,

Qwest Corporation