Wholesale: Products & Services

Open Product/Process CR PC060111-4 Detail

Description Of Change

Project Meetings

Bonnie Johnson- Integra said she was fine with that.

6/15/11 Product Process Monthly CMP Meeting Bonnie Johnson- Integra said the CR was to request a process associated with the Net Neutrality order that has no known date right now. She said during the Clarification call, it was identified that the order only impacts HSI resale products that Qwest said are under commercial agreements and not part of CMP. Qwest is going to deny the CR (6/23/11 Updates received from Integra in CAPS) WITH A NOTE THAT [delete AND] will state that when the order is received, Qwest will review and provide information to the commercial agreements notification group.

Mark Coyne – Qwest clarified those services are outside of the scope of CMP and that Qwest was preparing the denial response.

Bonnie Johnson- Integra said though Qwest is denying the CR, there was agreement on the process that will be used to communicate. Once the order comes out, Qwest will determine the disclosure and send a notice to Commercial agreement carriers.

Mark Coyne – Qwest said yes. There were no other questions.

6/13/11 Clarification Meeting Attendees: Bonnie Johnson-Integra, Kim Isaacs – Integra, Mark Coyne-CenturyLink, Jamal Boudhaouia -CenturyLink, Bill Campbell -CenturyLink, Susan Lorence-CenturyLink

Bonnie Johnson-Integra said the net neutrality order is to go into effect around August 1, 2011 and for the products Integra resells, they require net neutrality disclosure and their requirements should be same as Qwest and they do not want to forward customers to the Qwest website.

Jamal Boudhaouia -CenturyLink asked which products she was referring to and said it was a proposed order from the FCC.

Bonnie Johnson - Integra said she is not an expert on net neutrality and was maybe making an assumption that Qwest was developing disclosure on impacted products and that it would impacts products that resellers resell.

Jamal Boudhaouia -CenturyLink said based on his analysis, the proposed order impacts the products that are internet access offered to mass markets and small business customers and the only customers impacted are HSI.

Bonnie Johnson-Integra said OK and asked if they have commercial agreements on those.

Bill Campbell -CenturyLink said yes.

Bonnie Johnson-Integra said if Qwest believes those are the products requiring disclosure, then Integra should mirror it.

Jamal Boudhaouia -CenturyLink said by definition, it only impacts products associated with internet access and the only product that is offered for resale is QWB via commercial agreement.

Bill Campbell -CenturyLink said QVR is also offered.

Bonnie Johnson-Integra said she is not debating which products Qwest believes require disclosure but that for those products that do, Qwest and Integra should work together.

Jamal Boudhaouia -CenturyLink said the order was FCC 10-201 adopted December 21, 2010 and released December 23, 2010.

Bonnie Johnson-Integra said it appears the effective date is August 1.

Jamal Boudhaouia -CenturyLink said he respectfully disagreed based on where the order was in the FCC order process.

Bonnie Johnson-Integra said it may not be August 1 but whatever date, she would like to get it done.

Jamal Boudhaouia -CenturyLink said he did not disagree but based on the FCC process, he thought the earliest date would be October 15, 2011.

Bill Campbell -CenturyLink questioned whether a declarative statement had to be issued.

Jamal Boudhaouia -CenturyLink said no but it was open for debate the type of required disclosure within the industry. He said once the order was effective, resale disclosure requirements would be determined.

Bill Campbell -CenturyLink said when the general business changes are determined, retail would make some decisions, and he would send a non-CMP notice to HSI wholesale customers.

Bonnie Johnson-Integra said she thought the CR would remain on HOLD until decisions are made but wanted a plan of action.

Susan Lorence-CenturyLink said she understood the products are related to internet access (HSI, QVR, QWB) that are outside of the scope of CMP and she did not want to keep the CR open.

Bonnie Johnson-Integra said to respond to the CR as suggested and close the CR.

Bill Campbell -CenturyLink and Jamal Boudhaouia -CenturyLink agreed that that plan would work

Bill Campbell -CenturyLink said upon Qwest/CTL review of the final order, it will be determined what changes and notifications are required to the Qwest customer. Qwest will also then notify their wholesale customers via a non-CMP notice.

Susan Lorence-CenturyLink said the SME team would confirm this approach and asked if there were any other questions and there were none.

CenturyLink Response

CC: Kim Isaacs – Integra, Mark Coyne - Qwest, Jamal Boudhaouia – Qwest, Bill Campbell - Qwest, Susan Lorence-Qwest

This letter is in response to CLEC Change Request PC060111-4, Need for a Process/Policy on what net neutrality information a reseller should disclose, and the manner in which the Qwest reseller should disclose that information to its customers

CR Description: The FCC issued its order on Net Neutrality (FCC 10-201; 25 FCC Rcd 17905; GN Docket No 09-191 and WC Docket No. 07-52). The order will be effective around August 1, 2011. Resellers of Qwest internet access products will need to provide Net Neutrality disclosure language for those Qwest internet access products. Confusion may result if the disclosures are different. Please provide Qwest’s disclosure language and if needed, a process for carriers to obtain and use that language.

Expected Deliverable: Qwest will work with Resellers of Qwest’s internet access products to develop a process so Resellers can obtain the net neutrality disclosure language and use that language for Qwest resale products impacted by the FCC net neutrality order.

History: The CR was submitted on June 1, 2011 and a clarification meeting was held on June 13, 2011 with Integra and Qwest representation. The CR was presented in the June CMP monthly meeting.

Qwest Response: As part of the discussion in the Clarification call on June 13, 2011, it was determined that the products associated with the Net Neutrality order are related to internet access (HSI, QVR, QWB). Because these internet access products are outside of the scope of CMP, Qwest is denying this CR for that reason. However, during the clarification call, it was agreed that upon Qwest's review of the final order, it will be determined what changes and notifications are required to the Qwest customer. Qwest will also then notify their wholesale customers via a non-CMP notice.

Sincerely, Qwest Corporation