Wholesale: Products & Services

Open Product/Process CR PC060909-1CM Detail

Description Of Change

Qwest is seeking to modify Section 2.6 of the CMP document to remove obsolete language that refers to the PID Administration Group which is no longer in existence. Revised wording is attached.

Project Meetings

9/16/09 Product/Process CMP Meeting

Mark Coyne-Qwest said Qwest proposed changes to Section 2.6 of the CMP Document. He said a vote was conducted in August with several no votes. He said the status of CR PC60909-1CM will be changed to a denied status. Mark said we will be sending out a final notice to close the Oversight issue with no further action and that we will agree to disagree.

8/19/09 Vote ProdProc CMP Meeting

Vote Required - Meeting Minutes August 19, 2009 Lynn Stecklein-Qwest said this CR is proposing updates to Section 2.6 of the CMP Document to remove obsolete language that refers to the PID Administration Group which is no longer in existence. The Redlined Document of the proposed changes can be found in the August Prod/Proc Distribution Package A vote of 'Yes' will indicate a preference that Section 2.6 of the CMP Document be updated to remove obsolete language that refers to the PID Administration Group which is no longer in existence. A vote of 'No' will indicate a preference that Section 2.6 of the CMP Document not be updated to remove obsolete language that refers to the PID Administration Group which is no longer in existence. Quorum is 8 and has been achieved 4 e-mail votes were received - Integra voted no, Velocity voted yes, Action Communications abstained and Qwest voted yes.

Lynn asked for other participants on the call to cast their vote.

Comcast - No Covad - Yes PAETEC - No TDS - Abstain tw telecom - No AT&T-No Sprint-Yes XO- No

Lynn said that Section 2.1 of the CMP Document states that incorporating a change into the Change Management Process requires unanimous agreement using the Voting Process, therefore, this request will not be granted.

7/15/09 ProdProc CMP Meeting

Mark Coyne-Qwest said a vote on this change will be conducted in the August CMP Meeting.

7/13/09 Adhoc Meeting Minutes Section 2.6 of the CMP Document July 13, 2009

Attendees: Doug Allen-Integra, Kim Isaacs-Integra, Bonnie Johnson-Integra, Brenda Bloemke-Comcast, Shelly Pedersen- tw telecom, Mindy Chapman-Neustar, Mike Williams-Qwest, Mark Coyne-Qwest, Susan Lorence-Qwest, Lynn Stecklein-Qwest

Susan Lorence-Qwest said the purpose of this meeting is to consider updates to Section 2.6 of the CMP Document. In March 2009, Integra submitted a request to Qwest to distribute a new PID request under Section 2.6. In April 2009, Qwest denied that request with the response that Section 2.6 was obsolete with the removal of the PID Administration Group. In May 2009, Integra submitted the issue to the CMP Oversight Committee for review. On 6/3/09, the Oversight Committee met and the decision was made that Qwest would distribute the request for a new PID via CMP and submit the CR to revise Section 2.6 and to move forward. She said this CR is to update Section 2.6 to make it work and not be obsolete based on the PID Administration Group being gone. Susan said the Oversight minutes are posted to the Wholesale website along with revisions to the proposed notice that went out. The proposed redline is also available on the website at: http://wholesalecalendar.qwestapps.com.

Mike Williams-Qwest said Qwest recognizes that we have underlying disagreement among parties about the PID Administration Group. Mike said Qwest claims that group doesn’t exist anymore and hasn’t for years and others don’t agree. He said when we looked at what we are everyone seemed to be trying to accomplish with Section 2.6 updates, we determined there was a PID related issue resulting from CMP, the desire was to have a notice distributed of a request for a PID change along with other communications about that subject among the parties. Mike said that we redlined Section 2.6 to remove the PID Administration Group and left Section 2.6 to address key functions. He said it now says when there are changes to a PID; Qwest would accommodate distribution of the notice. He said in the 1st and 2nd paragraphs, we deleted the PID Administration Group parenthetical. He said if there is an issue from CMP that relates to the PIDs, any party can bring that to Qwest and Qwest will distribute an e-mail notification to the CMP body. Mike said this is accomplishing what Qwest believes is desired without getting into agreeing or disagreeing on the PID Administration Group. Mike said the last paragraph recognizes the reverse can happen, where a PID discussion outside of CMP might have dimensions that should come back to CMP. He said in those cases, the CMP body may expect such issues to be brought to Qwest and the CMP body for resolution or recommendation such as a CR. Mike said if there is a PID issue, a party can seek a change and through this revised language, Qwest would agree to notify through the CMP procedures of that request and to share copies of correspondence relating to that request.

Susan Lorence-Qwest asked if there were any questions or comments. Susan said that Integra had expressed concerns about the notice and asked if we were ok to move forward with the CR.

Bonnie Johnson-Integra said there was lot of correspondence going back and forth and Integra doesn’t agree. She said while they agreed that a particular group of people that was once referred to as PID Administration Group, that group of people may no longer exist. She said they felt that the language cared for such successor groups. She said they don’t believe the language needs to be revised and the PID Administration group is the group to review any PID request that is submitted. She said she didn’t know what else to say that hasn’t already been said.

Susan Lorence-Qwest asked if tw telecom or Comcast had any feedback.

Brenda Bloemke-Comcast said she would like to review the comments that were submitted.

Susan Lorence-Qwest said the comments pertain to the notice not the redline. Susan asked if there were any other questions or concerns about the proposed redline. There were no other comments. Qwest will proceed with the CR.

6/17/09 ProdProc CMP Meeting

Mark Coyne-Qwest said that the Oversight Committee met on 6/3/09 and the minutes can be found on the Qwest Wholesale website. Mark said that as a result of that meeting it was agreed that a notice referencing Integra’s PID request would be sent out and that Qwest would issue a CR to update the language in section 2.6 and that further discussion would take place on the language. Mark said that the notification went out yesterday and the CR was submitted by Qwest to address the language in Section 2.6.

Bonnie Johnson-Integra said that she wanted to say that meeting minutes from that call and her comments support (6/24/09 Comments to minutes received from Integra in CAPS) THAT QWEST IS FREE TO SUBMIT ANY CR QWEST WISHES TO SUBMIT and that there was concurrence with that BUT NOT A RECOMMENDATION TO DO THAT. THE MEETING MINUTES IMPLIED THAT THE CLEC AGREED WITH QWEST’S POSITION THAT 2.6 NEED TO BE UPDATED, WHICH WAS NOT THE CASE. However, Bonnie said that Integra’s position is that they feel no change was needed to the document.

Mike Williams-Qwest said that Qwest’s position is that the PID Administration Group does not exist and has not existed for years. He said Qwest has no obligation left under Section 2.6 because there is no PID Administration Group. Mike said the Qwest CR simply removes the PID Administration Group language and replaces it with generic language. (6/24/09Comments to minutes received from Integra in CAPS) MIKE SAID HE UNDERSTANDS INTEGRA DISAGREES WITH QWEST’S INTERPRETATION. He said it represents the intent of parties, in considering Section 2.6, to facilitate communication if a PID question arises. He said the CMP process was not designed to handle PID issues but Qwest recognizes there may be items that spill back and forth to and from CMP. When that happens, notification will get distributed. No matter what you call it, the parties in CMP have access to communication. Making this change allows us agree to disagree on why we’re revising the language or on what happens in any given interaction while still facilitating the distribution of PID-related notices and communications as intended, overall, by Section 2.6.

Bonnie Johnson-Integra said they (6/24/09 Comments to minutes received from Integra in CAPS) ARE NOT REFUSING TO REVIEW THE CHANGES AND will look at the change and consider the change. She said they believe the CMP document anticipated a successor and Integra doesn’t believe the PID Administration Group is a defined group. She said that it could be any group of people REVIEWING A PID not A that particular group. She SAID WHILE A PARTICULAR GROUP OF PEOPLE NO LONGER EXIST SHE disagrees that the PID group is no longer operating. Bonnie asked if they should send comments back to CMP or Mark.

Susan Lorence-Qwest said that with a CR there is an option for a call. We could schedule an ad hoc call to review the language (6/24/09 Comments to minutes received from PAETEC in CAPS) IF THE GROUP FELT THERE WAS A NEED FOR THE AD HOC CALL. BUT IF ANYONE HAS COMMENTS OR any proposed changes TO THEIR REDLINE IT should be sent to Qwest.

Julia Redman-Carter-PAETEC said they would like an ad hoc call because there are fundamental issues (6/24/09 Comments to minutes received from PAETEC in CAPS) UNDERLYING THE PROPOSED LANGUAGE CHANGES that they need clarified before they can comment on the redline.

Mark Coyne-Qwest said that we will schedule an ad hoc meeting prior to any changes to the redline being submitted.

Julia Redman-Carter-PAETEC said she needs to understand how the process works and what the PID group looks like etc. to determine if she would agree to the language Qwest is proposing and that we need an adhoc meeting before the redline.

Mark Coyne-Qwest asked if there were any other questions or comments.

E-mail received from Integra 6/16/09 Bonnie Johnson-Integra said that Qwest SAID IT merely lifted the PID Administration group language but there are other changes besides than just deleting that language.

Mike Williams-Qwest said it was to make it more readable and to make it fit with the remaining language. It was our sincere intent not to create anything new and to determine how section 2.6 could go forward. Julia Redman-Carter-PAETEC asked that the State Commissions be invited to the ad hoc meeting.

Liz Balvin-Covad said that she agreed with having an ad hoc meeting. Liz said they have a fundamental concern when someone is not proactively looking at the documentation and that the PID administration group no longer exists. She said she thought that Qwest undertook some time ago and was surprised this wasn’t triggered at that time.

Mark Coyne-Qwest said that with the infrequency of using this section for changing PID etc and it hasn’t been looked. We knew it would be difficult to change that language and it hasn’t occurred until now.

Qwest, as you know from our earlier email, we disagree with several of your points. We ask that Qwest ensure that all of the email correspondence, including proposals, are posted as part of the record of this oversight escalation.

Bonnie

Bonnie J. Johnson | Director Carrier Relations bjjohnson@integratelecom.com

- From: Cmp, Escalation [mailto:cmpesc2@qwest.com] Sent: Tuesday, June 16, 2009 1:45 PM To: Johnson, Bonnie J.; 'allendm@att.com'; 'ebalvin@Covad.COM'; 'BrendaBloemke@cable.comcast.com'; 'Cox, Rod'; Coyne, Mark; 'Carolee Hall'; 'shelley.e.jones@state.or.us'; 'Quintana,Becky'; 'Redman-Carter, Julia' Cc: 'cmpesc@qwest.com'; Williams, Mike; Isaacs, Kimberly D.; Urevig, Rita; Denney, Douglas K.; 'charitypelak@cable.comcast.com' Subject: RE: Change Management Notice: GN: CMP - Oversight Review Submission

Bonnie,

In regard to the points made in each of your paragraphs below: 1) Qwest will utilize Julia Redman-Carter's version of the draft PID notice with the addition of the specific date of the CMP Oversight meeting as it was the most supported version of the notice among the responders. The PID notice will be distributed today, June 16, 2009. The final version is attached. 2) Qwest removed the CR reference from the notice. It was simply a way to tie the CMP Oversight meeting and the CR together. There was no attempt by Qwest to shift the focus from the issue Integra brought to the CMP Oversight Committee. The proposed CR is a way to move forward. Qwest disagrees that there was no recommendation made by the CMP Oversight Committee. After the discussion of the issue on the June 3 call, each Oversight member was specifically asked whether they agreed with Qwest sending out a PID notice and issuing a CR to change the CMP document. No one disagreed. Integra requested the ability to review the notice in advance which Qwest provided. In regard to your concern about referring recipients of the PID notice to the CNLA (this same concern was also expressed in an email today), the PID attachments will be specifically associated with the June 16, 2009 PID notice on the CNLA. The reference was specifically made to "...associated with this notification.." and was not intended to refer to the CMP Oversight notice distributed on May 7. When there are very large attachments associated with a notification, Qwest has previously used this approach of sending the notice and referring the mailout recipient to the CNLA to pick up the very large attachments. With two attachments associated with the PID notice each at approximately 1MB, Qwest will continue to make these documents available via the link to the CNLA. 3) The June 3 meeting minutes refer the reader to the specific CMP Oversight notice distributed in May which includes the the attachments that are available on the CNLA. Qwest did not intend on sending the PID notice until the final meeting minutes were posted to the Oversight URL which occurred on June 15. 4) The issuance of the Qwest CR is consistent with the way the CMP Oversight Committee expected this Oversight Issue to move forward. Qwest understands that Integra disagrees with Qwest's interpretation of CMP Section 2.6 and even our proposed solution. Nonetheless, Qwest's CR is simply a very straightforward attempt to solve the problem by removing references to the PID Administration Group that no longer exists while retaining the distribution of a notice by Qwest if a PID request is made.

Thank you, Susan Lorence Qwest CMP Manager

- From: Johnson, Bonnie J. [mailto:bjjohnson@integratelecom.com] Sent: Wednesday, June 10, 2009 12:12 PM To: Cmp, Escalation; 'allendm@att.com'; 'ebalvin@Covad.COM'; 'BrendaBloemke@cable.comcast.com'; 'Cox, Rod'; Coyne, Mark; 'Carolee Hall'; 'shelley.e.jones@state.or.us'; 'Quintana,Becky'; 'Redman-Carter, Julia' Cc: 'cmpesc@qwest.com'; Williams, Mike; Isaacs, Kimberly D.; 'charitypelack@cable.comcast.com'; Urevig, Rita; Johnson, Bonnie J.; Denney, Douglas K. Subject: RE: Change Management Notice: GN: CMP - Oversight Review Submission

Qwest,

Enclosed are Integra’s redlines of the draft notice and Qwest’s Change Request (CR). Regarding the CR, Integra has not redlined Qwest’s substantive request, though Integra disagrees with it, as Integra will comment at the appropriate time. The redline addresses the oversight committee language.

In the draft notice of Integra’s PID request, Qwest erroneously indicates that the notice is associated with Qwest’s CR. Although Qwest attempted in the Oversight Committee call to shift the focus from the issue Integra properly brought to the Oversight Committee to Qwest’s new request, they are separate issues. (See Integra’s enclosed Oversight review submission.) When Qwest announced on the call its intention to submit a CR, Integra recognized Qwest’s right to submit a CR but also indicated Integra’s disagreement with Qwest’s position. There was no vote or recommendation by the full Oversight Committee in favor of Qwest’s position. Neither of Qwest’s documents (the notice or the CR) should indicate or imply such a recommendation when there was none. If this issue is to be addressed at all, it should be done neutrally, recognizing the disagreement of the parties, as proposed in Integra’s redline. Qwest’s draft notice indicates that Integra’s PID request is available in Qwest’s customer notification archive, but that archive contains Qwest’s oversight committee meeting notice with attachments. Qwest gives insufficient information (e.g., the date and notice number) to find the notice. Making it difficult to locate and review the PID request is contrary to the purpose the notice is supposed to serve. Section 2.6 states Integra’s documentation should be DISTRIBUTED (not referenced) and, in any event, attaching the information better serves the purposes of giving notice.

In both Qwest’s draft notice and its draft CR, Qwest incorrectly states that “full discussion” is available at the Qwest escdisp URL. The only item available there is the meeting minutes (i.e., not Integra’s oversight committee submission), and Qwest does not even give sufficient information (e.g., the date) to locate the minutes. (The minutes are not yet posted. Any reference to the minutes should not be distributed to CLECs until the final minutes, including CLEC comment, are available.) As indicated above, Qwest inaccurately describes its position, with which Integra disagreed, as a recommendation of the Oversight Committee. There is no need to debate Qwest’s characterization of the results of that call, when the characterization can simply be deleted from the documents, and the minutes referenced.

Regarding Qwest’s proposed redlines to the CMP Document, they offer nothing by way of compromise or recognition of Integra’s position. Obviously, Integra will not vote for such one-sided Qwest changes and, as a unanimous vote is required per Section 17, the changes will not be made. Integra will comment on Qwest’s CR at the appropriate time. In the meantime, Integra reminds Qwest that the CMP Document, including Section 2.6 as written today, is a part of several Integra and Eschelon (as well as other CLEC) interconnection agreements, and Integra expects Qwest to comply with its contractual obligations.

Bonnie

Bonnie J. Johnson | Director Carrier Relations bjjohnson@integratelecom.com

- From: Cmp, Escalation [mailto:cmpesc2@qwest.com] Sent: Tuesday, June 09, 2009 6:12 PM To: 'allendm@att.com'; 'ebalvin@Covad.COM'; 'BrendaBloemke@cable.comcast.com'; 'Cox, Rod'; Coyne, Mark; 'Carolee Hall'; Johnson, Bonnie J.; 'shelley.e.jones@state.or.us'; 'Quintana,Becky'; 'Redman-Carter, Julia' Cc: 'cmpesc@qwest.com'; Williams, Mike; Isaacs, Kimberly D.; 'charitypelack@cable.comcast.com'; Urevig, Rita Subject: RE: Change Management Notice: GN: CMP - Oversight Review Submission

As discussed in our June 3 CMP Oversight Committee meeting, attached is the draft notification to the CLEC community for your review. Also attached is the CMP CR along with the redline version of Section 2.6 that was submitted to the CMP mailbox today. If you have any concern with the wording of the notification, please let me know by end of day on Thursday, June 11.

Thank you, Susan Lorence Qwest CMP Manager 402 422-4999

- From: Johnson, Bonnie J. [mailto:bjjohnson@integratelecom.com] Sent: Tuesday, June 09, 2009 2:10 PM To: Lorence, Susan; Urevig, Rita; 'allendm@att.com'; 'BrendaBloemke@cable.comcast.com'; 'ebalvin@Covad.COM'; 'Cox, Rod'; Coyne, Mark; 'Carolee Hall'; 'Quintana,Becky'; 'shelley.e.jones@state.or.us'; 'Redman-Carter, Julia'; Isaacs, Kimberly D.; 'charitypelack@cable.comcast.com' Cc: 'cmpesc@qwest.com'; Johnson, Bonnie J. Subject: RE: Change Management Notice: GN: CMP - Oversight Review Submission

Susan,

When will Qwest be sending the draft notice for the CMP Oversight Committee to review? Integra would like ample opportunity to review the notice and respond. I am off Thursday and Friday. Can Qwest send the draft before noon tomorrow? Thanks, Bonnie

Bonnie J. Johnson | Director Carrier Relations bjjohnson@integratelecom.com

- From: Lorence, Susan [mailto:Susan.Lorence@qwest.com] Sent: Wednesday, June 03, 2009 2:04 PM To: Johnson, Bonnie J.; Urevig, Rita; 'allendm@att.com'; 'BrendaBloemke@cable.comcast.com'; 'ebalvin@Covad.COM'; 'Cox, Rod'; Coyne, Mark; 'Carolee Hall'; 'Quintana,Becky'; 'shelley.e.jones@state.or.us'; 'Redman-Carter, Julia'; Isaacs, Kimberly D.; 'charitypelack@cable.comcast.com' Cc: 'cmpesc@qwest.com' Subject: FW: Change Management Notice: GN: CMP - Oversight Review Submission

- From: mailouts2@qwest.com [mailto:mailouts2@qwest.com] Sent: Thursday, May 07, 2009 4:33 PM To: sxloren@qwest.com Subject: Change Management Notice: GN: CMP - Oversight Review Submission