Wholesale: Products & Services

Open Product/Process CR PC051216-1 Detail

Description Of Change

The FCC has relieved LECs of the requirement to provide a voice channel in the event the LEC retires its copper network IN A FIBER TO THE CURB (FTTC) AND FIBER TO THE HOME/PREMISE (FTTH, FTTP) AREAS. The CenturyLink Product team has determined it will no longer provide a 64Kbps voice channel in areas where it has undertaken such a fiber overbuild and copper retirement.

In its Memorandum Opinion and Order (FCC 15-166), issued December 28, 2015, the Federal Communications Commission relieved LECs of the obligation to provide a 64Kbps voice channel on fiber when the LEC overbuilds its copper network with fiber and retires its copper plant in a service area.

CENTURYLINK WILL CONTINUE TO OFFER THE CLEC COMMUNITY A 64 KBPS CHANNEL AS A REPLACEMENT OF AN ANALOG VOICE GRADE COPPER LOOP IN AREAS WHERE CENTURYLINK IS REPLACING THE FEEDER PORTION OF THE LOOP WITH FIBER.

CenturyLink will continue to make Voice Resale available in areas affected by copper retirements. CenturyLink will also work with any impacted customers to review its service offerings and to suggest any potential alternatives.

Proposed Implementation Date:7/1/16

Project Meetings

7/20/16 Product/Process CMP Meeting Mark Coyne – CenturyLink said this CR was presented in May. Following an Ad Hoc call on June 7, 2016, the CR was revised and the updates were reviewed in the June CMP monthly meeting. A level 4 notice was distributed on June 22, 2016 and the associated final notice was sent on July 15, 2016 with an effective date of August 1, 2016. We will review the CR in the August CMP meeting. Mark asked if there were questions. There were none.

6/15/16 Product/Process CMP Meeting Mark Coyne – CenturyLink said this CR was a Walk-on that was presented in May. An Ad Hoc call was held on June 7, 2016 that included considerable discussion regarding how a hybrid loop is defined in relation to this CR. Mark said the draft meeting minutes were sent for review June 14, 2016 along with a revision to the CR that was submitted by the originator. A revised copy of the CR has since been posted to the CMP calendar which Mark then reviewed. With the revisions that had been made, CenturyLink would like to send the Level 4 notice after June 22, 2016. Mark said there were no documentation updates to be made associated with this CR so it would be a notification only.

Kim Isaacs – Integra said the updates look OK but that her assumption about the revised CR wording is that it means (6-24-16 Updates received from Integra in CAPS) THAT THE 64 K CHANNEL IS NOT AVAILABLE ONLY when CenturyLink retires its copper network and replaces it with fiber to the curb and fiber to the premise. She asked if that was correct.

Jamal Boudhaouia – CenturyLink said that was correct.

Susan Lorence – CenturyLink said it sounded like a CR revision was not required and that the meeting minutes were sufficient to capture the clarification.

Kim Isaacs – Integra said that was fine and she could not think of any documentation that needed to be updated.

06-07-16 FINAL meeting minutes from Ad hoc call Attendees: Bonnie Johnson – MN DOC Bruce Linseheid– MN DOC Diane Dietz – MN DOC Linda Jensen – MN DOC Greg Doyle – MN DOC Armando Fimbres – Oregon PUC Susan Travis – CO PUC Teresa Ferguson – CO PUC Lynn Notarianni – CO PUC Kim Isaacs – Integra Doug Denney – Integra Laurie Roberson – Integra Jamal Boudhaouia – CenturyLink Steve Karpowich– CenturyLink John Hansen – CenturyLink Susan Lorence – CenturyLink

Susan Lorence – CenturyLink went over the agenda for the meeting and then a brief history of the CR. Susan said Jamal Boudhaouia – CenturyLink had provided a copy of the FCC order, FCC-15-166A1, which was posted to the calendar.

Steve Karpowich– CenturyLink provided an overview of the CR and said the order FCC-15-166A1 came out last year and that CenturyLink had issued the CR to notify through CMP that CenturyLink would not provide 64Kbps voice channel when switching from copper to fiber.

Jamal Boudhaouia – CenturyLink referred call participants to paragraphs 55 to 66 of the FCC order which provides the specific requirements for the CenturyLink CR. Jamal said there is a new requirement to provide notification of copper retirement with 180 day lead time which used to be 95 days. He said he has provided some notifications to some call participants of some upcoming copper retirements for the 180 day lead time.

Kim Isaacs – Integra said the Copper retirement order is different than the 64Kbps Forbearance order.

Jamal Boudhaouia – CenturyLink said he agreed they are different orders. Jamal said the first FCC order is associated with when CenturyLink is putting fiber to the premise, to the DLC or to the curb and the requirement is now to issue the Network Disclosure at least 180 days prior to the planned cutover date. Jamal said the CenturyLink notification goes to the FCC and all customers. For those customers specifically impacted by the copper retirement, he provides the list of those impacted circuits that have to be moved to a different product. Jamal said the Forbearance order identifies if ILECs are retiring copper in an area and installing fiber to the home or curb, CenturyLink no longer is required to provide a 64Kbps channel. Jamal said the CLECs will no longer be able to order the 64Kbps loop in this situation.

Kim Isaacs – Integra said the FCC Forbearance order did not change the requirement for ILECs to provide the hybrid loops.

Jamal Boudhaouia – CenturyLink said it did. Jamal asked what is a hybrid loop channel.

Kim Isaacs – Integra said then read the following information from C.F.R 47 §51.319 that had been included in an email Kim sent on 5-18-16 following the CMP monthly call:

(iii) Narrowband services. When a requesting telecommunications carrier seeks access to a hybrid loop for the provision of narrowband services, the incumbent LEC may either: (A) Provide nondiscriminatory access, on an unbundled basis, to an entire hybrid loop capable of voice-grade service (i.e., equivalent to DS0 capacity), using time division multiplexing technology; or (B) Provide nondiscriminatory access to a spare home-run copper loop serving that customer on an unbundled basis.

Kim Isaacs – Integra said forbearance was not provided for these services.

Jamal Boudhaouia – CenturyLink said he needed to take this back to CenturyLink legal for review.

Doug Denney – Integra said CenturyLink needed to look at the hybrid loop definition and this would be more clear.

Teresa Ferguson – CO PUC asked for clarification of the footnote.

Jamal Boudhaouia – CenturyLink said the wording Kim referenced is in Footnote 172 of FCC-15-166A1.

Kim Isaacs – Integra said USTelecom did not ask for forbearance from this rule. Forbearance was specific to the 64Kbps rule.

Armando Fimbres – Oregon PUC asked if CenturyLink legal had provided their final review of this order.

Jamal Boudhaouia – CenturyLink said yes, for fiber to the home and fiber to the curb.

Kim Isaacs – Integra said this was the discussion during the CMP monthly meeting which was why the reference was sent after the meeting and questioned why there was no final response.

Jamal Boudhaouia – CenturyLink said that was not his understanding of the discussion. Jamal said now there are two architectures under discussion: fiber to the DLC and fiber to the curb and we need to get a good definition of a hybrid loop. He said the order under consideration has fiber and copper.

Kim Isaacs – Integra said the FCC defines a hybrid loop is a loop with both fiber optic cable and copper.

Doug Denney – Integra said in this case, Footnote 172 calls the hybrid loop a fiber loop and that CenturyLink needs to look at C.F.R 47 §51.319.

Jamal Boudhaouia – CenturyLink said he thinks so but needs to have further internal review.

Susan Lorence – CenturyLink said that the question of the definition of a hybrid loop is an open point. The next agenda item was grandfathered loops.

Jamal Boudhaouia – CenturyLink said once we agree on the definition, the existing 64Kbps loops would be grandfathered and would not be required to be disconnected. If the loop is copper, if a customer does not want them converted to fiber based, they must be removed according to FCC rules. Jamal said he would continue to issue the copper retirement notifications to all customers but now under the new timeline. The individual reports will go to the appropriate customers and will include the impacted circuits along with the timing of when a decision must be made.

Kim Isaacs – Integra said Copper retirement and the 64Kbps are two separate FCC orders. She asked if CenturyLink will use the copper retirement process for customers not getting a 64Kbps channel.

Jamal Boudhaouia – CenturyLink said yes, the two orders are separate. He said the copper retirement notices will continue to go to all customers as well as an FCC submittal. He said once forbearance is in effect, individual customers will follow the forbearance rules if there are LX- - loops that are impacted.

Bonnie Johnson – MN DOC said CenturyLink currently provides a report to each customer when copper loops are eliminated and asked if CenturyLink will do this for the 64Kbps.

Jamal Boudhaouia – CenturyLink said yes for those customers that are impacted.

Lynn Notarianni – CO PUC said there is a statement in Para 66 of FCC-15-166A1 that says: “…Meanwhile, a competitive LEC that has already requested and obtained access to an unbundled 64 kbps channel will have reasonably incurred costs in putting the channel to use, such as connecting the channel to a self-provisioned switch. Relieving an incumbent of its unbundling obligation in these circumstances would risk stranding the competitor’s investment with no clear offsetting benefit to the incumbent. Accordingly, we find it is appropriate to require incumbents to maintain access to channels made available under the 64 kbps unbundling requirement that are in use as of the adopted date of this order. “ Lynn asked how that paragraph is reconciled between the Copper retirement and Forbearance orders.

Jamal Boudhaouia – CenturyLink if there is an existing 64Kbps channel, those will stay in place. But once forbearance is in place, the 64 Kbps unbundling is not an option.

Lynn Notarianni – CO PUC said Paragraph 66 then only applies if the loop is already built out.

Jamal Boudhaouia – CenturyLink said yes, those loops are grandfathered so there is no stranded investment in place. Jamal asked if that answered the question.

Lynn Notarianni – CO PUC said that clarifies the CenturyLink interpretation.

Susan Lorence – CenturyLink asked if there were more questions about the reports.

Bonnie Johnson – MN DOC said no.

Kim Isaacs – Integra asked if the order impacts hicap circuits.

Jamal Boudhaouia – CenturyLink said no; these are not impacted.

Susan Lorence – CenturyLink said if CenturyLink can resolve the hybrid loop question, then CenturyLink will include the response in the meeting minutes. If there is an issue with the interpretation, Jamal will request another ad hoc call. When the meeting minutes are sent out for review, participants can then also identify if another ad hoc call is required.

Kim Isaacs – Integra asked if the CR would be revised.

Jamal Boudhaouia – CenturyLink said it would be. [NOTE: As of 6-14-16, Steve Karpowich – CenturyLink, CR originator, modified the CR to address the hybrid loop question. The revised CR is attached to the email associated with these meeting minutes.] Susan Lorence – CenturyLink asked if everyone is in agreement with the updates to the CR, CenturyLink would like to send the level 4 notification on June 21, 2016. She said that will provide a week after the meeting minutes are distributed to identify any issues.

Kim Isaacs – Integra and Jamal said that would be fine if there are no issues with the updated CR.

Armando Fimbres – Oregon PUC asked what CLECs are on the call.

Susan Lorence – CenturyLink said only Integra was on the call to represent the CLEC community. She said it was disappointing that there were not more CLECs that joined the call. She said the draft meeting minutes and updated CR would be available for the CMP meeting and the proposed timeline would be reviewed there.

The Ad hoc meeting was adjourned at 3:10 PM MT.

05-18-16 Content of EMAIL received from Kim Isaacs - Integra following CMP monthly meeting NOTE: Content in all caps was highlighted in email.

Clarification Needed on Change Request PC051216-1

I am hoping we will find that we are all the same page and I just misunderstood CenturyLink’s intent. As discussed on today’s CMP call, Integra believes that Change Request PC051216-1 Discontinuation of 64K voice grade requirements on fiber when copper network is retire needs to be modified to clarify that the discontinuation of the 64K voice grade channel apply only in cases where CenturyLink has deployed fiber to the premise (FTTP, FTTH). The forbearance the FCC granted in its Memorandum Opinion and Order (FCC 15-166) was “very limited” answering “USTelecom requests forbearance on a nationwide basis for all incumbent LECs from application of section 51.319(a)(3)(iii)(C) of the Commission’s rules, which requires unbundling of a 64 kbps voice-grade channel to provide narrowband services over fiber WHERE AN INCUMBENT LEC RETIRES A COPPER LOOP IT HAS OVERBUILT WITH A FIBER-TO-THE-HOME OR FIBER-TO-THE-CURB LOOP.” (¶ 55).

Rule: 51.319(a)(3)(iii)(C) says: (C) An incumbent LEC that retires the copper loop pursuant to paragraph (a)(3)(iv) of this section shall provide nondiscriminatory access to a 64 kilobits per second transmission path capable of voice grade service over the fiber-to-the-home loop or fiber-to-the-curb loop on an unbundled basis.

In the case where CenturyLink is retiring cooper but not deploying FTTH or FTTC, the FCC did not grant ILECs forbearance from C.F.R 47 §51.319 (a)(2) (iii)(A) Hybrid Loops for Narrowband services. (2) Hybrid loops. A hybrid loop is a local loop composed of both fiber optic cable, usually in the feeder plant, and copper wire or cable, usually in the distribution plant. (i) Packet switching facilities, features, functions, and capabilities. An incumbent LEC is not required to provide unbundled access to the packet switched features, functions and capabilities of its hybrid loops. Packet switching capability is the routing or forwarding of packets, frames, cells, or other data units based on address or other routing information contained in the packets, frames, cells or other data units, and the functions that are performed by the digital subscriber line access multiplexers, including but not limited to the ability to terminate an end-user customer's copper loop (which includes both a low-band voice channel and a high-band data channel, or solely a data channel); the ability to forward the voice channels, if present, to a circuit switch or multiple circuit switches; the ability to extract data units from the data channels on the loops; and the ability to combine data units from multiple loops onto one or more trunks connecting to a packet switch or packet switches. (ii) Broadband services. When a requesting telecommunications carrier seeks access to a hybrid loop for the provision of broadband services, an incumbent LEC shall provide the requesting telecommunications carrier with nondiscriminatory access to the time division multiplexing features, functions, and capabilities of that hybrid loop, including DS1 or DS3 capacity (where impairment has been found to exist), on an unbundled basis to establish a complete transmission path between the incumbent LEC's central office and an end user's customer premises. This access shall include access to all features, functions, and capabilities of the hybrid loop that are not used to transmit packetized information. (III) NARROWBAND SERVICES. WHEN A REQUESTING TELECOMMUNICATIONS CARRIER SEEKS ACCESS TO A HYBRID LOOP FOR THE PROVISION OF NARROWBAND SERVICES, THE INCUMBENT LEC MAY EITHER: (A) PROVIDE NONDISCRIMINATORY ACCESS, ON AN UNBUNDLED BASIS, TO AN ENTIRE HYBRID LOOP CAPABLE OF VOICE-GRADE SERVICE (I.E., EQUIVALENT TO DS0 CAPACITY), USING TIME DIVISION MULTIPLEXING TECHNOLOGY; OR (B) PROVIDE NONDISCRIMINATORY ACCESS TO A SPARE HOME-RUN COPPER LOOP SERVING THAT CUSTOMER ON AN UNBUNDLED BASIS.

I don’t see the need for an ad hoc call, if CenturyLink updates the PC051216-1 to say something similar to the following:

The FCC has relieved LECs of the requirement to provide a voice channel in cases where the LEC retires its copper network and has overbuilt with a fiber-to-the-home (FTTH) or fiber-to the-curb (FTTC) loop. The CenturyLink Product team has determined it will no longer provide new** 64Kbps channel in areas where it has retired a copper and overbuilt with a FTTH or FTTC. In its Memorandum Opinion and Order (FCC 15-166), issued December 28, 2015, the Federal Communications Commission relieved LECs of the obligation to provide a 64Kbps voice channel on fiber when the LEC retires copper loops it has overbuilt with FTTH and FTTP

CenturyLink will continue to make Voice Resale available in areas affected by copper retirements when it has overbuilt with FTTH or FTTC.

Proposed Implementation Date: 7/1/16 **Note** The FCC “grandparented” rule 51.319(a)(3)(iii)(C) so there will not be an impact to any embedded base of 64K channels being provided in service areas where copper has been retired and CenturyLink has overbuilt with FTTH and FTTC.

The above addresses only the clarity needed for change request PC051216-1. I haven’t had the opportunity to discuss the need for an amendment internally yet. Thank you. ** 5/18/16 Product/Process CMP Meeting Steve Karpowich – CenturyLink presented this Walk on CR. Steve said the FCC relieved LECs of the requirement to provide a voice channel (64 kb/s) when the copper network is retired. Steve said CenturyLink is planning to go that direction and is providing notice. He said we will work with customers to consider possible alternatives.

Kim Isaacs – Integra (5-27-16 Updates received from Integra in CAPS) STATED (delete ASKED IF) this ONLY APPLIES TO (delete IS) copper (delete ONLY) retired WHEN CENTURYLINK DEPLOYS FIBER to the premise.

Steve Karpowich – CenturyLink said he thought that was true but will investigate further. He thought we are getting rid of unbundled copper loop if we retire copper.

Bonnie Johnson - Minnesota Dept of Commerce said when there is a copper retirement, CenturyLink provides a spreadsheet 90 days ahead of time and asked if the report will include all loops in the future.

Steve Karpowich – CenturyLink said that was correct.

Jamal Boudhaouia – CenturyLink said we provide that list today and not just xDSL loops.

Kim Isaacs – Integra said (5-27-16 Updates received from Integra in CAPS) VOICE SERVICE IS ONLY IMPACTED if the copper is retired to the premise. (delete ,) WHEN COPPER IS RETIRED IN THE FEEDER, DISTRIBUTION, OR WHEN A FIBER BASED DLC IS DEPLOYED only xDSL loops are impacted. Voice (ANALOG DS0 UNE LOOPS) and DS1 LOOPS are not impacted.

Jamal Boudhaouia – CenturyLink said the Forebearance rule does not specify. When replacing copper with fiber, the 64Kbps channel will not be available which is the change of law.

Kim Isaacs – Integra said that she disagreed with that interpretation.

Jamal Boudhaouia – CenturyLink said if we disagree, we may need more discussion. Jamal said we will look at the rule again but DS1 was not impacted. Currently, Jamal said he sends all the copper loops and then the CLEC determines which ones can be transferred to 64K.

Kim Isaacs – Integra said (5-27-16 Updates received from Integra in CAPS) (delete THERE) are many EXISTING VOICE/ANALOG loops that are impacted and asked if all of those had to be changed to resale voice. [NOTE: THE FCC FORBEARANCE ORDER “GRANDPARENTED” THE 64K CHANNEL WHEN AN ILEC DEPLOYED FIBER TO THE HOME/PREMISE SO THE FORBEARANCE WILL NOT IMPACT EXISTING SERVICES PROVIDED ON 64K CHANNELS]

Jamal Boudhaouia – CenturyLink said if it is a DS0 channel and the copper is not retired, those are not impacted. If everything is moved to fiber to the premise, those are impacted. Jamal said for direct copper fed homes with no cross box that is being entirely replaced, or it is split, then copper is no longer available to premise. He will now send the retirement disclosure and ask customers to make a change based on this new rule.

Kim Isaacs – Integra said that the Order says the LEC is required to serve the CLEC with (5-27-16 Updates received from Integra in CAPS) VOICE GRADE DS0 LOOPS WHEN THERE IS A FIBER FED DCL AND THE PREMISE IS SERVED BY COPPER (delete A FIBER FED LOOP).

Jamal Boudhaouia – CenturyLink said that is not what the order says.

Kim Isaacs – Integra gave the example of new Greenfield fiber and said they don’t have access today. Kim said if it is fiber to the premise with a straight fiber circuit, there is no access to 64K.

Jamal Boudhaouia – CenturyLink said he did not think they would solve this and would need to review the language and suggested an Ad Hoc call to discuss.

Kim Isaacs – Integra agreed that an Ad Hoc is required.

Bonnie Johnson - Minnesota Dept of Commerce said her question is outstanding. When CenturyLink retires copper and notifies CLECs of the impacted xDSL loops, the voice grade loops swing to the fiber fed. Bonnie said it sounds like that will no longer occur and asked if the voice grade loops will now appear on the CenturyLink spreadsheets that are sent.

Jamal Boudhaouia – CenturyLink said if the loops are straight copper, they are all included today on the list that is sent. Jamal said if it is an F1 change, he asks for everything on the report not just xDSL.

Kim Isaacs – Integra said she disagrees; she only sees xDSL and some DS0 but does not see all loops. Kim said her ICA says DS0 are provided on hybrid loops.

Jamal Boudhaouia – CenturyLink said that is the change of law that allows CenturyLink to present this CR.

Bonnie Johnson - Minnesota Dept of Commerce asked if there will need to do an amendment before this process is changed.

Jamal Boudhaouia – CenturyLink said he needed to investigate that.

Mark Coyne – CenturyLink said Jamal will provide the language in the order for the minutes and we will set up an Ad Hoc call.

Susan Lorence – CenturyLink asked if some examples from Kim would be helpful before having a call.

Kim Isaacs – Integra said she could provide an example where all circuits are not provided. (5-27-16 Updates received from Integra in CAPS) [NOTE: EXAMPLE FROM CENTURYLINK’S FCC COPPER RETIREMENT FILING 5/4/2016 NETWORK DISCLOSURE 788 – INDICATES NON-LOADED LOOPS ARE IMPACTED (VOICE GRADE DS0 LOOPS ARE NOT CONSIDERED “NON-LOADED COPPER LOOPS”) ALL OTHER LOOP TYPES REMAIN AVAILABLE.

INTEGRA INSERTED TABLE BELOW (For a better view of this table, refer to the meeting minutes posted to the Wholesale calendar at http://wholesalecalendar.centurylinkapps.com/cal/2016/5)

STATE WIRE CENTER PLANNED COMPLETION OR RETIREMENT DATE DA (s) Job # Replacing AZ McClintock TEMPAZMC 07-15-2016 N/A N.067002 Growth in distribution area requires CenturyLink to cut facilities to fiber fed digital loop carrier system (DLC). After the cut to DLC, copper reliant services, such as non-loaded copper loops will not be supported. All other types of unbundled loops will still be available.] END TABLE

Liz Tierney – Global Capacity said she was trying to distinguish between xDSL and voice grade and what the difference was for conversion. Liz asked how the xDSL would be impacted.

Jamal Boudhaouia – CenturyLink said the LX-- for voice grade will move to a new NC/NCI combination and there are other loops impacted. Jamal said xDSL is impacted since it has to be copper all of the way.

Mark Coyne – CenturyLink asked if there were any other questions prior to the Ad hoc call. There were none.