Wholesale: Products & Services

Open Product/Process CR PC050812-1X Detail

Description Of Change

The most recent example of a failed process involved copper retirement which was announced in CenturyLink’s Network Disclosure Announcement #751 and impacted a senior living facility in Minnesota (“Customer”) which was served via copper loop facilities. Disclosure #751 established the planned retirement date of July 13, 2011 for copper facilities which were subsequently used by CenturyLink to provision service to the Customer. After receipt of Disclosure #751 and prior to the announced retirement date, XO found alternative service arrangements for several customers then served by the copper facilities subject to the planned retirement.

With respect to the Customer, the copper loop facilities needed to provide service weren’t placed into service by CenturyLink until November 3, 2011 – nearly 4 months after the planned copper retirement date about which CenturyLink had notified XO via notice #751. XO received no notice from CenturyLink that such retirement had been substantially delayed. Based on the above, XO had reasonably concluded that the facilities subject to notice #751 had been retired in July as CenturyLink’s notice indicated. The fact that CenturyLink provisioned the copper facilities to Customer in November clearly demonstrates that CenturyLink’s systems showed copper facilities were available to Customer’s premises when ordered and that even CenturyLink personnel weren’t aware that the facilities were about to be disconnected.

On January 25, 2012, XO was notified by CenturyLink that the copper facilities serving the Customer were about to be removed by construction crews. CenturyLink and XO had to take extraordinary measures in a short period of time and incur significant costs in order to delay removal of the copper and prevent a service disruption to the Customer while an alternative means of service provision was identified and put in place.

The recent experience described above makes abundantly clear that CenturyLink needs to expeditiously update its pre ordering and ordering systems to accurately show copper facilities noticed for retirement , thus avoiding threats to customer service and the imposition of significant costs. XO sought to participate in a cooperative evaluation and modification of CenturyLink’s systems, which CenturyLink refused to do. Instead, CenturyLink invited XO to request a process change by following the CMP process located at: http://www.centurylink.com/wholesale/cmp/

Project Meetings

Kim Isaacs – Integra asked when the ad hoc calls were anticipated.

Mark Coyne – CenturyLink stated that no date has been set and when they are scheduled, an announcement would be made. Mark asked if John had any other comments. John Ivanuska – XO Communications said he was fine with the approach and looked forward to the ad hoc calls.

5/16/2012 CMP CR Clarification call Attendees: John Ivanuska – XO Communications, Liz Tierney – Megapath, Kim Isaacs – Integra, Cindy Buckmaster – CenturyLink, Jeff Ruckel – CenturyLink, Shon Higer – CenturyLink, Lori Burchett – CenturyLink, Jamal Boudhaouia – CenturyLink , Denise Martinez – CenturyLink, Clinton Maurice – CenturyLink, Michelle Faamausili - CenturyLink, Rita Urevig – CenturyLink, Mark Coyne -CenturyLink, John Hansen - CenturyLink, Susan Lorence - CenturyLink

Susan Lorence – CenturyLink took attendance and asked John Ivanuska - XO Communications to give an overview of his Change Request (CR). She recapped the reason for the CMP clarification call.

John Ivanuska – XO Communications relayed the contents of his CR. The CR as currently written states the orders placed on a route to be decommissioned would be rejected. He said it would be possible to expand the discussion but he wanted to know the construction timeline. John said he thought that currently there was no designation in CenturyLink systems that would stop an order placed on a decommissioned route.

Susan Lorence – CenturyLink then asked Kim Isaacs - Integra to explain the modification that she had asked for in the earlier CMP monthly call.

Kim Isaacs – Integra stated that the reject is fine but that her modification would allow the ability to override a reject if necessary on the short term. For example, if a customer was ordering a service that was delayed and needed a copper facility for the short term until the requested service was available and before the decommissioning of the copper.

Jamal Boudhaouia – CenturyLink stated that John Ivanuska had mentioned that he didn’t have visibility to the CenturyLink systems and asked him to elaborate.

John Ivanuska – XO Communications clarified that he did have access to IMA but didn’t know which CenturyLink systems would need to be updated since he thought there was no designation to support this CR.

Jamal Boudhaouia – CenturyLink said that is correct, it is not in IMA or the Raw Loop Data tool.

Liz Tierney – Megapath asked for clarification as to the level of the rejection and whether it would be at the Serving Wire Center (SWC) level. Liz said she could provide examples of where there was a retirement and not all end users were impacted.

Jamal Boudhaouia – CenturyLink replied that the decommissioning would be down to the crossbox level and not the SWC level.

Kim Isaacs – Integra asked for confirmation that the rejects would happen on services that were dependent on the copper loop to be decommissioned.

Jamal Boudhaouia – CenturyLink replied that any service that required a copper loop would be rejected.

Kim Isaacs – Integra asked if a voice grade circuit riding on copper would be impacted by a copper retirement.

Jamal Boudhaouia – CenturyLink replied that CenturyLink just changed the technology so it would not be impacted.

Kim Isaacs – Integra asked if her order would be rejected if she orders a voice grade loop in an area pending copper retirement, since CenturyLink can change the technology.

Jamal Boudhaouia – CenturyLink said he would have to check with developers but thought that would be part of the requirement.

Kim Isaacs – Integra asked if there was agreement from those on the call that CenturyLink would not reject any order that was not impacted by the copper retirement.

John Ivanuska – XO Communications agreed.

Susan Lorence – CenturyLink summarized by stating that the orders to receive a reject were the orders directly impacted by the copper retirement.

Kim Isaacs – Integra confirmed that it was the orders that would have to be disconnected when the copper was decommissioned.

Jamal Boudhaouia – CenturyLink said CenturyLink would not want to restrict a CLECs opportunity to order a loop that was not impacted.

Liz Tierney – Megapath asked if pre-qualification would be enhanced with this CR so the customer would not get to provisioning or would the CR need to be expanded?

Susan Lorence – CenturyLink stated that currently the CR was a Product/Process CR and that it might need to cross over to a Systems CR depending on what CenturyLink SMEs are thinking.

Cindy Buckmaster – CenturyLink stated we needed to talk internally. She said CenturyLink may be doing something wrong as decommissioning should not impact end users and maybe we can just get that fixed. She said if CenturyLink had offered loops in the facility, the CLEC would still have the loops.

Kim Isaacs – Integra said no, xDSL wouldn’t work if the copper is pulled.

Cindy Buckmaster – CenturyLink replied that she wasn’t involved in xDSL issues but that we needed to work internally to see what gaps exist before we decide to crossover the CR to systems.

Susan Lorence – CenturyLink stated that she agreed that we need to evaluate the CR to determine impacts. If there are system changes required, we would cross it over to a Systems CR but that will be a longer timeline than a product/process change.

Liz Tierney – Megapath asked if she needed to submit a System CR to get the information at the pre-qualification level.

Susan Lorence – CenturyLink stated that she felt that would be true if this CR remains a Product/Process change with no impact to systems. If that was the case, a System CR would be required to make a pre-qual change.

Liz Tierney – Megapath said OK.

John Ivanuska – XO Communications indicated that he was in agreement.

Susan Lorence – CenturyLink asked if there were any other questions for John Ivanuska regarding his Change Request. There were none.

John Ivanuska – XO Communications asked what the timeline on the response would be.

Susan Lorence – CenturyLink stated that CenturyLink had a couple of weeks to get the response together and that it should be before the next CMP Meeting.

There was further discussion in regard to whether the examples that Liz Tierney – Megapath was going to send were needed. It was determined they were not.

The call was concluded at 11:22AM MT.

05/16/2012 CMP Prod Proc Meeting John Ivanuska - XO Communications presented the proposed change as included in the CR.

Liz Tierney – MegaPath said she supported this CR and has had similar issues which is not a good place to be in with the end user.

Kim Isaacs – Integra said she supported the concept of this CR but asked if XO Communications would be open to a modification (5/25/12 Updates received from Integra in CAPS) IF THE ORDER WAS ON A COPPER FACILITY. Kim asked if the order reject could be over ridden depending if the request was for a short or longer term facility.

John Ivanuska - XO Communications said there would not be a problem for a modification but he wanted the order reject made clear up front if the route was going to be decommissioned. He said if there was a need on the short term for the facility, he was OK with that flexibility.

Bonnie Johnson – Minnesota Department of Commerce said she supported the CR and agreed with the caveat Integra presented. If there was a job a year down the road, there was a need to allow the CLEC to override the reject for a short term.

Susan Lorence - CenturyLink said there is a clarification call with CenturyLink SMEs scheduled for Wednesday, May 16, 2012 at 11 AM to review the CR.

Jamal Boudhaouia - CenturyLink said CenturyLink would determine the feasibility of the CR and that on face value it is doable. Jamal said there needed to be a common understanding on what the CR is asking for and there may be a need for another CR depending on what is being asked for and the type of facility.

Kim Isaacs - Integra asked if the reject would include voice grade loops that may not be impacted by a copper retirement.

Jamal Boudhaouia - CenturyLink said the impact is to the copper loop CO to the end user premise.

Liz Tierney – MegaPath said the copper retirement is at the distribution level and asked if Jamal was saying that CenturyLink could not implement a process at that level.

Jamal Boudhaouia - CenturyLink said he has not seen examples that say that the F1 facilities are going away but there could be examples of that.

Liz Tierney – MegaPath said she has examples where the retirement is not at the CLLI level and will try to send them before the clarification call.

Mark Coyne – CenturyLink said to send them to the CMPCR mailbox and said that this is the kind of discussion that will be included in the CR clarification call.

Kim Isaacs - Integra asked why the CR was a Product Process CR vs. a system CR and whether the rejects will be manual.

Mark Coyne – CenturyLink said that will be addressed on the clarification call.

CenturyLink Response

June 13, 2012

John Ivanuska, XO Communications

SUBJECT: CR # PC050812-1 CenturyLink’s recognition of to be decommissioned copper routes

This letter is in response to XO’s Change Request (CR) PC050812-1,CenturyLink’s recognition of to be decommissioned copper routes. This CR requests that CenturyLink reject orders that are placed on a route that is to be decommissioned.

During the Clarification call held on May 16, 2012, there was some discussion that there could be a CenturyLink process issue that was causing this to be a problem. After further investigation, that is not the case. CenturyLink processes and systems associated with tracking copper retirement are working as designed. Furthermore, during the Clarification call, Integra proposed a revision to the CR that an order could be placed on an exception basis if a CLEC has a need for an unbundled copper loop on a temporary basis.

The SME team has been reviewing potential solutions and believes that the most efficient approach for a solution to this CR will require a system change since orders are placed through IMA. Thus, CenturyLink proposes that this CR cross over to a system CR during the June CMP meeting. As such, this CR PC050812-1 will be closed and CenturyLink will open CR SCR050812-1X on XO’s behalf with a reference to the original product process CR.

CenturyLink is continuing to evaluate the possible options for a system solution and hopes to schedule an ad hoc call in the near future to present the proposed solution.

Sincerely, Susan Lorence CenturyLink CR Project Manager