Wholesale: Products & Services

Open Product/Process CR PC050905-1 Detail

Description Of Change

Covad seeks reduction of the following intervals applied by Qwest:

1) DSL line shared/split disconnect orders reduced to 24 hours.

2) CFA only supplemental orders (post FOC, pre completion) reduced to 24 hour interval for line shared/split and 2/4 wire non-loaded loops

Expected Deliverable:

1) That Qwest will perform DSL line shared/split disconnect orders within 24 hours (current interval 3 days).

2) That Qwest will process CFA only supplemental orders within 24 hour interval (currently 72 hours) for line shared/split and 2/4 wire non-loaded loops. For example, if the CFA change request is made before the due date has passed than the due date remains the same or if the CFA change request is made on the due date or after the due date has passed, Covad requests the 24 hour interval instead of the current 3 day interval.

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Original Description:

Covad seeks reduction of the following intervals applied by Qwest:

1 Stand alone DSL line shared/split disconnect orders reduced to 1 day.

2) CFA only supplemental orders (post FOC, pre completion) reduced to 24 hour interval for line shared/split and xDSL qualified loops.

Expected Deliverable:

That Qwest will perform stand alone DSL line shared/split disconnect orders within 24 hours (current interval 3 days). In addition, that Qwest will process CFA only supplemental orders within 24 hour interval (currently 72 hours) line shared/split and xDSL qualified loops.

Orig Products: UBL xDSL, Line Split/Shared

Project Meetings

-- April 7, 2006 Email Received From Covad: Peggy, I haven’t heard back yet. It’s on my list and I will let you know as soon as I hear back from our Ops. Thanks, Lynn

- April 7, 2006 Email Sent to Covad: Good Morning Lynn - This email is a follow-up to the emails below. Is Covad ready for closure of the Reduce Intervals CR? Thank you, Peggy Esquibel-Reed Qwest Wholesale CMP

March 31, 2006 Email Received From Covad: Hi Peggy, I have requested information from our Ops department on this CR - I will inquire again on Monday to see if there are any issues that would prevent closure, based on the testing. Thanks, and have a nice weekend. Lynn

- March 31, 2006 Email Sent to Covad: Hello Lynn, This email is just a follow-up to see if you have had the opportunity to validate the changes made as a result of Covad's Product Process CMP CR PC050905-1 Reduce Intervals. The effort was implemented on January 30th. Please let me know if you are ready to close the CR or if you did find an issue with the implementation, please let me know what the issue is and I can assist in getting the issue resolved. Thank you, Peggy Esquibel-Reed Qwest Wholesale CMP

March 15, 2006 Monthly Product Process CMP Meeting Discussion: Jill Martain-Qwest stated that this effort deployed on January 30th and asked if the CR was ready to be closed. Lynn Hankins-Covad asked that the CR remain open another month, as she has not been able to check. Jill Martain-Qwest advised Covad that if they determine that the CR could be closed before the next CMP meeting that they could send an email to close during the month. Lynn Hankins-Covad advised she would check, and if possible, she will let Qwest know off-line. This CR remains in CLEC Test.

-- February 15, 2006 Monthly Product Process CMP Meeting Discussion: Jill Martain-Qwest stated that this CR deployed on January 30th and asked for closure. Lynn Hankins-Covad asked that the CR remain open another month. This CR remains in CLEC Test.

January 18, 2006 Monthly Product Process CMP Meeting Discussion: Jill Martain-Qwest stated that the Level 2 Notice was sent on January 19th with a targeted implementation date of January 30th. Jill stated that this CR would move to CLEC Test on January 30, 2006.

- December 14, 2005 Monthly Product Process CMP Meeting Discussion: Jill Martain/Qwest stated that this is still on target for a January 28, 2005 deployment. This CR remains in Development status.

-- November 16, 2005 Monthly Product Process CMP Meeting Discussion: Jill Martain/Qwest stated that this effort was targeted for January 28, 2006 and noted that the notice would be sent in early December. This CR remains in Development status.

-- October 19, 2005 Monthly Product Process CMP Meeting Discussion: Anthony Washington/Qwest stated that Qwest is accepting the remaining portion of this request and is tentatively looking at implementation in February, due to changes needed in back-end systems. Jill Martain/Qwest stated that the implementation date is not yet finalized and that the February date is very tentative. Jill stated that this CR moves to Development Status. Jill noted that the CFA portion was already solved. Liz Balvin/Covad agreed.

-- September 21, 2005 Monthly Product Process CMP Meeting Discussion: Peggy Esquibel-Reed/Qwest stated that Qwest is continuing to work internally on this request and is currently looking at the costs for changes to back-end system changes that may be able to meet this need. Peggy stated that Qwest would like to leave this CR in Evaluation status and that a status would be provided in the October CMP Meeting.

August 17, 2005 Monthly Product Process CMP Meeting discussion: Peggy Esquibel Reed-Qwest stated that Qwest is still evaluating this request and noted that Qwest has met internally at least once per week in order to discuss this CR. Peggy stated that this CR remains in Evaluation and that a status would be provided in September. [Comment received from Eschelon: Liz Balvin-Covad asked Qwest if we need an ad-hoc meeting. Liz said she does not want the CR to be denied. Liz said Qwest was looking at systems solutions and asked if that was still Qwest’s path. Qwest said they will keep an ad-hoc meeting in mind.]

- July 20, 2005 Monthly Product Process CMP Meeting discussion: Anthony Washington-Qwest said that this CR is for Line Sharing and Line Splitting. He said that the Line Sharing portion of this CR is still in evaluation. Anthony said that we have to figure out how we can determine the 1 day’s intervals versus a standard interval and then be able to prioritize the orders. Liz Balvin-Covad clarified that the disconnect interval reduction from 3 to 1 days, and the CFA change on Due Date for Line Sharing and Line Splitting is in Evaluation. Anthony Washington-Qwest advised yes. Deb Smith-Qwest added that UBL 2/4 wire non loaded was addressed post FOC and pre completion via CR5548229 (the verbal sup process). Liz Balvin-Covad said that she thought they could not do the CFA change. Liz said that the documentation was not very clear and that she will check on this. Liz advised that they still want the Line Splitting/Line Sharing. Jill Martain-Qwest stated that this CR will remain in Evaluation Status.

June 15, 2005 Monthly Product Process CMP Meeting discussion: Jill Martain-Qwest stated that Qwest is internally evaluating this request and that a status would be provided at the July CMP Meeting. This CR is in Evaluation status.

- May 18, 2005 Clarification Meeting Attendees: Liz Balvin-Covad, Nicole-Covad, Kim Isaacs-Eschelon, Bonnie Johnson-Eschelon, Peggy Esquibel Reed-Qwest, Heidi Moreland-Qwest, Crystal Soderlund-Qwest, Jo Wees--Qwest, Deb Smith-Qwest, Shirley Tallman-Qwest, Anne Robberson-Qwest, Paul Schlacter-Qwest, Anthony Washington-Qwest

Review Requested (Description of) Change: Peggy Esquibel Reed-Qwest reviewed the CR Title and Description and stated that the products indicated on the CR are UBL, DSL, Line Splitting, and Line Sharing. Peggy also noted that this CR is requesting a process change for Provisioning. Peggy then asked Covad if they had additional information to provide to Qwest. Nicole-Covad stated that currently for line shared and line split and when the voice is disconnected, the DSL is automatically disconnected within 24-hours. Nicole stated that the first item in the CR is requesting that stand alone DSL be in synch. Nicole stated that the second item in the CR is if it is identified that the CFA needed to be changed that they get a 3-day interval. Crystal Soderlund-Qwest asked Covad to further explain what Covad means by stand alone DSL. Liz Balvin-Covad stated that when they have a shared service, they are requesting a disconnect of the DSL only. Crystal Soderlund-Qwest asked if when requesting a disconnect of a line split or a shared line. Nicole-Covad stated is for the DSL portion of shared service. Crystal Soderlund-Qwest asked if this was for the data portion. Liz Balvin-Covad stated that the line in question is already split, voice and data, and if the provider disconnects the voice, the data portion is also to be automatically disconnected. Liz stated that if they disconnect the DSL only, it is a 3-day interval. Crystal Soderlund-Qwest stated that line sharing and Qwest DSL are 2 different products. Liz Balvin-Covad stated yes and that the DSL would be Covad provided DSL. Deb Smith-Qwest asked if this was just for shared services or if there is an impact to unbundled loops. Crystal Soderlund-Qwest asked if xDSL was qualified loops. Liz Balvin-Covad stated that it would be a stand alone DSL and noted that this CR has 2 different scenarios. Nicole-Covad stated that the first scenario applies to shared lines with the disconnect interval reduced to 1-day. The second scenario is when there is a CFA change, the interval is reduced to for stand alone DSL, the UNE line/UBL) and for line share. Anthony Washington-Qwest asked if this was for loop splitting. Nicole-Covad stated that this CR has 2 requests. UBL and shared loop. Nicole stated that if a CFA change is needed, they want a 24-hour interval instead of 3 days for shared lines and 5 days for UBL. Liz Balvin-Covad stated that the DSL product is a 2/4 wire non-loaded loop. Crystal Soderlund-Qwest asked if these were T1’s. Liz Balvin-Covad stated is 2/4 wire non-loaded loops, sDSR, not T1 or higher. Liz stated this would be for a DS0. Liz then noted that Covad does not purchase Qwest ADSL qualified loops. Crystal Soderlund-Qwest asked to confirm that item 1 in the CR should state that line sharing and line splitting need to be reduced to a 1-day interval and item 2 should state CFA changes for line shared/line splitting and 2 & 4 wire non splitting loaded loops. Liz Balvin-Covad said yes and stated that she would send in a revised CR. Crystal Soderlund-Qwest asked for example, a line shared request for slot 26 to be used; Qwest sends an FOC but is prior to completion. The request comes in today, May 18th, so May 23rd would be the due date on a 3-day interval. On May 19th, is post completion and Covad then wants a splitter change to slot 40. Crystal asked if Covad then wanted a May 20th due date. Nicole-Covad stated that normally, the only CFA change is when Qwest notifies them of a synchronization problem. Nicole stated that id Covad confirms that there is a problem with the CFA, they resubmit with a new assignment. Nicole stated that this is when they want a 1-day interval from when they submit the order. Nicole stated that if they receive a jeopardy on the CFA and Covad confirms the problem, they would resubmit on May 19th and would want the CFA completed on May 20th, not May 23rd. Kim Isaacs-Eschelon asked if there was a repair process for a CFA change. Nicole-Covad stated that this is for when the order is not yet completed, so they cannot go through repair. Kim Isaacs-Eschelon asked if this was for when the CFA was busy. Nicole-Covad said yes. Crystal Soderlund-Qwest asked that if the order is jeop’d on day 1, and there is a request to change the CFA, Covad wants a 1-day interval. Nicole-Covad said yes, with the impression that all the other work has been done, such as cross connects. Nicole stated that Covad does not want to affect the customer’s voice. This is for when no additional work is needed; they just need to switch to another card; and for UBL, if the pair is bad and the fieldwork has already been done. This would just be a pair change in the C.O. Deb Smith-Qwest asked to confirm that this would already be down to the due date since all the work has been done. Nicole-Covad said yes and noted that it could be on the FOC date or on the day before. Deb Smith-Qwest stated that on UBL 2/4 wire non-loaded loop; they should get the FOC long before the due date and is a 5-day interval. Deb stated that fieldwork may be done on the PTD but is close to the due date. Nicole-Covad stated that the C.O. work would be done and is done on the FOC date. Nicole stated that the fieldwork is done and the line is complete and Qwest tests or does co-operative testing. Then there could be a problem with the CFA assignment. If Covad reassigns the CFA, they currently wait 5-days, when the work is already done. Nicole stated that Covad does not know that there is a problem until the FOC date. Nicole stated this is where they want the 1-day interval. Crystal Soderlund-Qwest asked to confirm that a 1-day interval is requested if is on or after the original due date, or anytime during the process. Nicole-Covad stated anytime during the process. Crystal Soderlund-Qwest asked to confirm that if there is a CFA issue for a slot or splitter, the order is due today and there is a bad pair or splitter, Covad is asking for a 1-day interval. Crystal stated this would be a total 4 to 6-day interval. Kim Isaacs-Eschelon stated that this request sounds familiar and stated that there is a CR regarding a same day pair change the day of the cut, submitted by Allegiance. Kim stated that the CR number is 5548229 and noted that it was completed. Peggy Esquibel Reed-Qwest stated that Qwest would look at that CR. Liz Balvin-Covad asked what the escalation process was. Nicole-Covad stated that when the order is jeop’d for failure of a synch test, Covad disputes. If agreement is reached and a new CFA is sent, they want a sooner due date. Liz Balvin-Covad stated that of the Allegiance CR was completed; there should be a process in place. Peggy Esquibel Reed-Qwest stated that Qwest would look into the Allegiance CR. Liz Balvin-Covad stated that the Allegiance CR was for a post completion maintenance problem. Kim Isaacs-Eschelon stated that Allegiance asked for on the due date. Liz Balvin-Covad asked if Qwest understood what Covad was requesting. Deb Smith-Qwest stated that Covad is requesting a reduction to 1-day if it comes in today and that the 1-day would be at the end of business tomorrow. Liz Balvin-Covad said yes. Deb Smith-Qwest asked what if the due date was today and the CFA change was tomorrow. Nicole-Covad stated that if the due date were today and they were told today that there was a CFA problem, they are asking for a new due date of tomorrow. Deb Smith-Qwest asked if Covad only wants the 1-day interval for CFA’s on the due date and for the day before the original due date, the interval is not to be reduced. Nicole-Covad stated that if is jeop’d the day before or 2-days before the due date. Nicole stated that the expectation is to avoid pushing out the due date. Nicole stated that if the due date has passed, they want the interval to be 1-day. Crystal Soderlund-Qwest asked if that could also be clarified on the revision to the CR. Deb Smith-Qwest asked to confirm that the requested outcome is to not push out the due date when the CFA issue is identified prior to the due date. Nicole-Covad said yes and will clarify that on the revision being sent. Crystal Soderlund-Qwest stated that a 24-hour interval could be different than a 1-day interval, depending on the time that the request comes into Qwest. Liz Balvin-Covad said yes and would also clarify that on the CR revision. Peggy Esquibel Reed-Qwest asked if there were any additional questions or comments. There were none brought forward. Peggy then stated that this CR is scheduled for presentation at the June CMP Meeting and that Qwest would internally review the request.

-- May 18, 2005 Monthly Product Process CMP Meeting discussion: Liz Balvin-Covad stated that this CR had 2 pieces and stated that the first piece is that Covad would like a reduction that when Covad processes a line split, they would like the interval reduced to 1-day. Liz stated if it is a DSL disconnect, it is a 3-day interval. [Comment from Covad: Liz Balvin-Covad stated that this CR had 2 part 1) that the a DSL only disconnect be processed within 1 day Liz stated that currently if the voice is disconnected, the DSL automatically is brought down and done so within a day but if the DSL requires disconnection, Qwest imposes a 3-day interval.] Liz then stated that the second piece is for the ability to change the CFA on a supplemental order, post FOC and pre completion. Liz stated that the clock starts again if they need to change the CFA. Liz noted that the Clarification Call is scheduled for this afternoon. This CR moved to Presented status.

May 16, 2005 Email Received from Covad: Peggy, My internal contact was out of the office last week. I have a note out and should have back to by COB today with clarification call options. Thanks, Liz Balvin Covad Communications

-- May 16, 2005 Email Sent to Covad: Hi Liz, This email is just to follow-up on the item below. Will you send me several dates & times for the call? I will then get it scheduled and send you the call-in information. Thanks much, Peggy Esquibel-Reed Qwest Wholesale CMP

May 10, 2005 Email Sent to Covad: Hello Liz, Will you please advise me of your availability for the Clarification Call to discuss your request to Reduce Intervals? Several options would be greatly appreciated. Thanks much, Peggy Esquibel-Reed Qwest CMP

CenturyLink Response

Revised Response for Review by the CLEC Community and Discussion at the October 19, 2005 Product Process CMP Meeting

TO: Liz Balvin, Covad

SUBJECT: Qwest’s Revised Response for PC050905-1 Reduce Intervals

Description of Change: Covad seeks reduction of the following intervals applied by Qwest: - DSL line shared/split disconnect orders reduced to 24 hours. - CFA only supplemental orders (post FOC, pre completion) reduced to 24 hour interval for line shared/split and 2/4 wire non-loaded loops

This Covad Change Request, PC050905-1, is asking Qwest to perform DSL line shared/split disconnect orders within 24 hours (current interval 3 days) and that Qwest will process CFA only supplemental orders within 24 hour interval (currently 72 hours) for line shared/split and 2/4 wire non-loaded loops. For example, if the CFA change request is made before the due date has passed than the due date remains the same or if the CFA change request is made on the due date or after the due date has passed, Covad requests the 24 hour interval instead of the current 3 day interval.

Revised Qwest Response: Qwest provided a response for the CFA portion of the request which stated that with the CFA verbal supplement process that is currently in place; Qwest believes that the CFA issue has been resolved for Unbundled Loops. Please see the July 12, 2005 Qwest Response for details.

Qwest is accepting the remaining portion of this request, which is the DSL line shared/split disconnect orders reduction to 24 hours. Implementing this change will involve changes to back-end systems and Qwest is currently assessing when those changes can be implemented. When the implementation date is determined, Qwest will follow the appropriate notification timelines and will communicate the implementation date at a monthly CMP Meeting. Qwest would like to move this Change Request to Development Status.

Sincerely, Qwest

-- July 12, 2005

DRAFT RESPONSE For Review by the CLEC Community and Discussion at the July 20, 2005 CMP Meeting

TO: Liz Balvin, Covad

SUBJECT: Qwest’s Change Request Response - PC050905-1 Reduce Intervals

Description of Change: Covad seeks reduction of the following intervals applied by Qwest: - DSL line shared/split disconnect orders reduced to 24 hours. - CFA only supplemental orders (post FOC, pre completion) reduced to 24 hour interval for line shared/split and 2/4 wire non-loaded loops

Qwest Response: This Covad Change Request, PC050905-1, is asking Qwest to perform DSL line shared/split disconnect orders within 24 hours (current interval 3 days) and that Qwest will process CFA only supplemental orders within 24 hour interval (currently 72 hours) for line shared/split and 2/4 wire non-loaded loops. For example, if the CFA change request is made before the due date has passed than the due date remains the same or if the CFA change request is made on the due date or after the due date has passed, Covad requests the 24 hour interval instead of the current 3 day interval.

As it relates to the Shared Service products Qwest is evaluating what all of the changes and resources that are needed would entail for this effort. We are determining how we can identify a 1 day interval vs. a standard interval and once identified, if we can ensure that we can comply with completing a 1 day interval, or a CFA post FOC, pre-completion by the requested time frame. Qwest would like to leave this portion of PC050905-1 in Evaluation status.

In regard to the 2/4 wire Non Loaded Unbundled Loop, as a result of an Allegiance Change Request (5548229 Same Day Pair Change During Test and Turn-up (day of cut)) completed 8/21/2002), Qwest implemented a process to allow CLECs to have a CFA change before or on the due date for Unbundled Loop services, including the 2/4 wire Non Loaded. These processes allow this activity to happen via Verbal Supplements.

Information is located in the Ordering Overview Business Procedure at http://www.qwest.com/wholesale/clecs/ordering.html section Verbal Supplements on LSRs: "Changes to an existing service request must be made via a supplement as described above. Qwest will only accept a verbal supplement change request for one of the following reasons: - CFA or slot change on the due date - etc.

Note: For Unbundled Loop, verbal CFA or slot changes may be made up to three days prior to the due date".

Therefore, if the CLEC determines that their CFA is defective after FOC, but pre completion, the CLEC will contact the QCCC with the new CFA and provide their representative’s name and phone number. The QCCC will initiate the work activities within Qwest to perform the CFA change. A new FOC will be sent to the CLEC following the standard FOC guidelines. It is not necessary for the CLEC to issue a supplement to their LSR for these types of CFA changes.

With the CFA verbal supplement process that is in place, Qwest believes the CFA issue has been resolved for Unbundled Loops.

Sincerely, Qwest