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Open Product/Process CR PC061002-1 Detail

Description Of Change

Expected Deliverable:

Qwest to change this process ASAP, give the CLEC a reasonable amount of time (90 minutes) to correct a no dial tone situation on a reuse of existing facilities and give loops to the CLEC if there is continuity to the spot pair on new facilities

Project Meetings

- 10/16/02 October CMP Meeting Michael Buck with Qwest said that final notification PROD.10.11.02F.00839.Final24WireLoop was sent on 10/11/02 and the implementation date is 10/27/02. The CR is currently in Development Status and Qwest would like to move it to CLEC Test on the deployment date later this month. Byron Dowding with Alltel said that it was appropriate to move to CLEC test and discuss again at the November CMP meeting.

09/18/02 September CMP meeting Minutes Qwest discussed the revised draft response and provided an update that Qwest would no longer require dial tone on new unbundled loops effective mid-October. Conversion orders will continue to require dial tone. Qwest explained that the effective date is following the PCAT update for 2-wire 4-wire, Version 11, which is effective October 21, 2002. Allegiance and Eschelon appreciate Qwest changing to the no dial tone requirement on new unbundled loops. Allegiance also noted a clarification from the August Meeting minutes regarding the conversation on this CR. At the August meeting Lyndall Nipps – Allegiance asked why doesn't Qwest check for continuity on DS0 loops like you do for DS1 and above loops by plant test date. Qwest responded that it was not in the infrastructure to test for continuity on DS0 loops. A pre-survey is done for all UBL except for LX - -. LX - - is worked on the due date. This CR was moved to Development status.

9/12/02 2:29 p.m. To: cc:

Subject: RE: Updated Draft Response to CR PC061002-1

Byron -

The following is in response to Alltel's questions in your e-mail dated 8/27/02:

1. CHC means Coordinated Hot Cut (Y or N). You can have a Hot Cut with the Basic Option. Hot Cut means we go from one service provider to another on an existing service, this option can be ordered Coordinated or Basic.

2. Qwest is preparing to only require dial tone on reuse LX-- in mid-October.

3. The polarity of the Qwest wiring and facilities, from the CFA to the NI at the end user locations, can be checked using normal Qwest test systems and sets. The polarity of the supplied CLEC service can not be tested without the CFA operationally in service. If the CLEC provides service on the CFA with reversed polarity, Qwest will not reverse their wiring or facilities to correct, as this would impair Qwest’s ability to properly maintain the circuit in service. The polarity of a loop start line is of significant importance when the facility provided is anything but a plain copper loop. Pair Gain facilities require correct polarity of supplied service to operate correctly.

4. Qwest is preparing to only require dial tone on reuse LX-- in mid-October.

Please call me if you have any questions.

Thank you

Linda Sanchez-Steinke Change Request Project Manager Qwest

-- From: Byron.Dowding@alltel.com on 08/27/2002 08:03:51 a.m. To:

Subject: RE: Updated Draft Response to CR PC061002-1 Linda This is ALLTEL's response to the Qwest response I don't have any feedback yet to verify Qwest allowing more than 30 mintutes to provide dial tone on a loop. Byron

SUBJECT: ALLTEL response to Qwest response regarding change request PC061002-1 dated 08/19/2002

ALLTEL would like to make the following points.

1. The first statement in Qwest’s response states that this CR is about Qwest’s Hot Cut process. CR PC061002-1 has nothing to do with Hot Cuts. This CR is about ordering an unbundled loop with the Basic option and no testing (CHC is N). The service being ordered is 2/4 wire analog with the NC code of LX--. Due date on the loop being turned over to the CLEC and actual customer in service date don’t have a direct relationship. 2. The CLECs have stated several times that ordering a new loop and reuse should be handled as 2 different issues. We are willing to provide dial tone in a reasonable time when we are reusing a facility. When ordering a new loop no dial tone should be provided. 3. Our techs check for polarity when shooting trouble and can reverse the jumper/drop to correct the problem. Polarity should never be an issue with loop start dial tone. I would like to know how Qwest could check for polarity on loop start dial tone when dial tone is provided. 4. For the most part providing dial tone requires CLECs to program dummy numbers in their switch and then reprogramming when the service is actually turned up. This places a costly and unneeded burden on the CLECs.

ALLTEL is planning to charge Qwest for providing joint test capabilities when ordering unbundled loops that Qwest requires dial tone on. ALLTEL is also going to work with the regulatory agencies to significantly reduce the one-time charges associated with provisioning these types of loops.

-- 08/21/02 - August CMP Meeting Minutes: Qwest provided an updated draft response dated August 19, 2002 because information was missing in the August 13, 2002 draft response. The updated draft response is available on line and was handed out to participants in the meeting. Allegiance expressed concern that the 2-wire 4 wire PCAT updated language does not distinguish between new loops and conversions and that Allegiance and other CLECS are trying to find out the technical reasons why Qwest requires dial tone on new loops when there are other ways to check for continuity. Allegiance asked if Qwest checks for continuity from demarc to the central office before plant test date. Eschelon also asked for Allegiance’s question to be answered; does Qwest dispatch for continuity. Qwest stated (Hilleary) that we are pushing for dial tone on due date and dial tone 48 hours before due date is not a requirement. Allegiance disagreed. Qwest stated (Hendricks) that dispatch for continuity is not done, and the pre-survey is done to make sure there are facilities. Qwest stated (Braegger) that on services provided on UDC there is no way to verify correct service operation without Dial Tone on the circuit. Covad said that on digital loop carrier card verified set options correctly if have dial tone. Qwest (Braegger) stated that if Dial Tone is coming in reversed to the card, the card will not operate correctly and won’t operate unless there is battery to it.

Covad asked what would prevent Qwest technician from putting dial tone on temporarily from ICDF at cosmic frame. Qwest (Retka) asked that Covad send in procedure on a CR for Qwest to use spare dial tone temporarily from the ICDF.

Allegiance indicated that Qwest was the only ILEC requiring dial tone on new loops and is a burden on all CLECs when changing from T1 to UNE loop because translations are required for two different numbers and when Qwest checks for ANI the line is not the right number. Eschelon said there is effort that they must go through internally assigning dummy numbers to CFA to provide dial tone for Qwest.

Allegiance asked how Qwest identifies a fault and what does it mean in PCAT wording, pages 5-6 under the ordering section, asked if the purpose of notification is relationship managing. Eschelon asked if they should receive a jeopardy rather than a call if there was a short. Qwest (Boudhaouia) stated Qwest will re-write the PCAT. Allegiance said that the language creates concern over PIDS managing to process and Allegiance does not want the PCAT updated on 8/26/02. Qwest (Maher) stated that for Qwest and the CLECs to follow the CMP, the PCAT would be updated on 8/26/02 because there were comments from the CLEC community on the PCAT change, and Qwest had followed CMP and responded to those comments. Qwest (Schultz) clarified that the PCAT update included documentation of processes that were currently in effect. Allegiance objected to the PCAT update on 8/26/02.

Alltel asked for status of CR. Qwest (Graham) reviewed draft response part 1 reviewing why tests are done and the technical reasons for dial tone requirement.

Qwest (Hendricks) reviewed draft response part 2 reviewing the procedure for the basic option. When the CLEC selects the basic option and is not ready on due date, the technicians go on to their other work. If the CLEC calls back later in the day, then Qwest will try to get technicians back out. Alltel (Dowding) will check with Alltel people that asked for CR because they had said at 31 minutes the order has to be supplemented. Qwest explained that the 31 minutes would be applicable on the appointment time option but is not applicable on the basic option.

Due to another scheduled meeting, which many CMP participants wished to attend, the meeting was adjourned before discussion on the final disposition of the CR was concluded. Qwest will work offline with Alltel regarding the status of the CR and bring the CR back up for discussion at the September CMP meeting.

CLEC – Qwest Change Management Process Monday, August 12, 2002 Ad-Hoc meeting to discuss CLEC comments and CR Conference Bridge: 877.521.8688, passcode 7901848#

NOTE: These DRAFT meeting minutes were developed August 19, 2002 by Qwest following a meeting on the 2Wire 4Wire CLEC Dial Tone Requirement

MEETING MINUTES

The meeting was initiated by Qwest via Change Management notice CMPR.08.06.02.F.01307.CMPMtgFinalized that was distributed to the CLECs on August 6, 2002. Qwest scheduled the meeting to discuss the following two items with members of the CLEC community:

1) CLEC comments received for Notice PROD.07.12.02.F.00784.AnalogLoop24Wire 2) CMP Change Request PC061002-1 titled, “LSR put in Jeopardy when no dial tone present when Qwest installs Unbundled Loop” from Alltel.

The meeting began with Qwest reviewing the Qwest response to CLEC comments from Allegiance, Alltel, and Eschelon on the Level 3 notification sent out by Qwest on July 12th, 2002, PROD.07.12.02.F.00784.AnalogLoop24Wire. Several CLECs asked when the comments response had been distributed and Qwest responded that the notification had gone out the evening of August 9th, 2002, via notice PROD.08.09.02.F.00807.AnalogLoop24Wire and that the Qwest response to the comments had been posted under the Qwest CMP Product/Process Archive Document Review site under PROD.07.12.02.F.00784.AnalogLoop24Wire. Qwest then reviewed the response to comments with the attendees on the call. Allegiance stated that the Qwest posted comments referred to both conversion of analog loops as well as new installations, and that Allegiance did agree that CLEC dial tone should be required on conversion orders but not on new orders. Eschelon asked why the PCAT was being updated associated with PROD.07.12.02.F.00784.AnalogLoop24Wire. Qwest responded that the PCAT was being updated to reflect the requirement that Qwest currently has in place for these types of orders, and that the requirement was for CLEC dial tone prior to order completion. Eschelon, Allegiance, and ATT requested that the PCAT update be delayed until there was final resolution of the Alltel CR. Qwest responded that this request was out of process because the PCAT update needed to take place August 26th based on the final notice PROD.08.09.02.F.00807.AnalogLoop24Wire, but Qwest would take the request to delay the PCAT update back for final determination. Eschelon stated that there was no reason for CLEC comments if Qwest did nothing with them. Qwest responded that Qwest does take CLEC comments under consideration, but there is no CMP requirement to revise product/process changes based upon CLEC comments. Allegiance then stated that Qwest was the only ILEC requiring CLEC dial tone prior to order completion on NEW orders, and that Qwest needed to reevaluate the requirement. Covad stated that the issue could be resolved by Qwest providing Qwest dial tone to test the circuits, or that there were other test alternatives Qwest could implement. Qwest responded that the requirement for CLEC dial tone was still in effect due to technical requirements outlined in the response to CLEC comments, and that Qwest would provide a response to the Alltel CR at the August 21st CMP Monthly Product/Process meeting. The CLECs requested that a specific block of time be set aside at the CMP Monthly Product Process meeting to discuss this issue so they could have their technical subject matter experts on the call. Qwest agreed to set aside a specific time on August 21, 2002 to further discuss this. The time will be 1PM MT. The call-in number is 877 572-8687 passcode 3393947. The meeting then adjourned.

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07/17/02 - July CMP Meeting Minutes: Alltel introduced their Change Request. Alltel requested the wording in the meeting minutes for the clarification meeting held on June 18, 2002 be changed from “48 hours before the Due Date” to “48 hours after application date”. Allegiance stated that Qwest is the only ILEC requiring dial tone testing for testing continuity. Covad stated it should be the CLECs responsibility for providing dial tone. Eschelon stated all CLECs are interested in this Change Request. CR status is presented.

Clarification Call Time/Date: 11:00 qa.m. (MDT) / Tuesday, June 18, 2002 Place: Conference Call Conference: TEL: 877.521.8688 Call-In No: CODE: 7901848 CR No: PC061002-1 "LSR put in Jeopardy when no dial tone present when Qwests installs Unbundled Loop"

Attendees: Byron Dowding, Alltel Neil Houston, Qwest Linda Hendricks, Qwest Steve Hilleary, Qwest Michael Keegan, Qwest

1.0 Attendees introduced. 2.0 Description: The following is extracted from the CR submitted by Alltel: When ALLTEL orders an unbundled loop with a NC Code of LX--and the CHC marked N, Qwest checks for dial tone at the end user (new loops) or at the spot pair (reuse facilities). If there is no dial tone present, Qwest contacts the CLEC gives them 30 minutes to get dial tone on the loop or the LSR is put in Jeopardy and a new LSR has to be written with a new due date. If the order contains multiple loops and one of the loops does not have dial tone, all of the loops are placed in Jeopardy. Qwest has responded to our concerns saying that this has always been their procedure but it was not being followed. Because these orders are not coordinated hot cuts, Qwest can make their cut anytime during the day. It could even happen over a lunch hour. We have also had situations where Qwest has put a loop on the wrong spot pair, had no dial tone at the customer’s premise and placed the order in Jeopardy.

Clarification Call Discussion: Alltel indicated that this problem started recently (60 – 90 days ago) and has occurred at both Omaha and Grand Island, Nebraska

Alltel said the problem is they get a call from Qwest on the due date when no dial tone is present and the order is placed in jeopardy if the problem is not corrected in 30 minutes.

Qwest does a Dial Tone check on both Basic and Coordinated LX - - (2W/4W Analog)type orders on DVA (Design Verify Assign) which is approximately 48 hours after application Date. If there is no Dial Tone at that time Qwest contacts the CLEC to let them know there is no dial tone at this time. The notification is approximately 24-36 hours before the Due Date. I have verified a couple of orders and we have called Alltel after the Dial Tone Check to notify them that there was No Dial Tone at DVA. On Due Date Qwest does another Dial Tone check before they do the install or hot cut before Qwest starts to do the work. If Dial Tone is not present, the COT calls the QCCC (Qwest CLEC Coordination Center) Coordinator. The QCCC Coordinator calls the CLEC and lets them know that Dial Tone is not present at their CFA (Connecting Facility Assignment). The CLEC is given 30 minutes to correct the Dial Tone situation. If the CLEC is not ready in 30 mintues they are requested to send a supplement to their LSR for a new Due Date. If the LX- - has a Reverse Battery or No Signal NCI (Network Channel Interface) Qwest does not require Dial Tone to be present at the CLEC’s CFA. If the order has multiple loops the CLEC may split out the LSR and accept those that do have Dial Tone. The order without Dial Tone may be put on a separate LSR. The Coordinated Appointment Time Option allows the CLEC to choose exactly when they want the installation or hot cut to be performed. The Basic Option allows Qwest to start the installation or hot cut any time between 8AM and 5PM regional time. The COT should be doing the ANI test on the loop before and after they perform the lift and lay. The correct number should be identified. This is the process in place and should be followed to insure the accuracy of the request.

Linda Hendricks will prepare the Qwest response.

3.0 Confirmed that UNE Loop is the product impacted.

4.0 Qwest confirmed the correct personnel were on the call.

5.0 CLEC expects Qwest to change this process ASAP, give the CLEC a reasonable amount of time (90 minutes) to correct a no dial tone situation on a reuse of existing facilities and give loops to the CLEC if there is continuity to the spot pair on new facilities

6.0 No Dependent Systems Change Requests were identified,.

7.0 Action Items Alltel can present this Change Request to the CLEC community at the July Product/Process CMP meeting scheduled for July 17 Qwest will issue draft response to this Change Request by Aug 14 (one week prior to the Aug 21 CMP meeting). Qwest will discuss the draft response at the Aug 21 CMP meeting.

CenturyLink Response

Byron Dowding OSS Coordinator Alltel

SUBJECT: Qwest’s Change Request Revised Response - CR #PC061002-1 LSR put in jeopardy when no dial tone present when Qwest installs unbundled loop Alltel is requesting that Qwest change its Hot Cut process to allow for 90 minutes when no Dial Tone is present at the CFA and not to reject orders with multiple service requests when one of the requests must be rescheduled. (Part 1, No Dial Tone) Dial tone is required to provide a quality installation of the service ordered. To ensure adequate circuit level performance, installation and operational tests are performed. Dial tone must be present to perform these tests across the entire circuit: - To verify the assurance of the assignment and translation of the CFA. - To confirm the Competitive Local Exchange Carrier (CLEC) Connecting Facility Assignment (CFA) is operational and test hard wiring from the Qwest Interconnection Distribution Frame (ICDF) to the CLEC CFA. - To perform a polarity test at the termination of the Network Interface Device (NID) and to perform an overall end to end operational circuit test to ensure reliability and functionality. - When provisioning over Digital Loop Carrier (DLC), to perform ground start, loop start and polarity check tests to assure the electronic card in the DLC is operational and optioned correctly. These operational tests require dial tone to minimize trouble reports immediately following test and turn up. If the NC/NCI codes are such that the circuits do not require Dial Tone, Qwest does not require Dial Tone to be present at the CLEC’s CFA.

Qwest is preparing to no longer require the CLEC to provide Dial Tone on new Unbundled Loops (LSR ACT = N) in mid-October and will follow all appropriate CMP timelines. Prior to new Unbundled Loop Basic or Coordinated Hot Cuts, the Qwest Technician will conduct performance testing to assure the new Unbundled Loop complies with its respective NC/NCI standards.

(Part 2, 90 minutes) Perhaps the CLEC request reflects a misunderstanding. Qwest believes that the process in place more than meets the needs of the CLECs. The Basic Option allows Qwest to start the installation or hot cut any time between 8AM and 5PM regional time. Qwest actually allows more than 90 minutes when a Basic Installation is ordered.

Here is the procedure when the Basic Installation Option is ordered:

On Due Date when Qwest is finished doing the installation and core tests, we call to notify the CLEC that we are done and that the test has been completed. If the CLEC wants to do more testing on their own or they can't get something working on their end, Qwest waits 30 minutes, then calls the CLEC again. If the CLEC still isn’t ready Qwest lets the field tech and the Central Office Technician (COT) go to their next jobs.

Qwest will hold the order open and if we do not have a CLEC resolution by the end of day we will have the COT disable the circuit. If the CLEC calls back on the same day and is ready, we will try to get a tech back out (if applicable) and the COT back in the central office. If it is too late in the day, or the resources are not available, Qwest will jeopardize the order and the CLEC must supplement the LSR with a new desired due date.

If the order has multiple loops the CLEC should accept the loops that have Dial Tone and supplement the LSR to remove the loop that does not have Dial Tone. The loop without Dial Tone should be put on a separate LSR with a new desired due date.

In mid-October, on a New order the Outside Technician (OST) will check for dial tone. If the OST does not have dial tone they will: - Call the Central Office and have the COT check for dial tone. If dial tone exists, the OST needs to check the facilities and resolve. - If no dial tone exists, the COT needs to check for dial tone at the Connecting Facility Assignment (CFA). If dial tone exists at the CFA, the COT needs to check the wiring in the CO and resolve. - If dial tone does not exist, the COT will notify the OST and the COT will wire in temporary Qwest dial tone for the OST to perform core tests to complete the order. The QCCC Coordinator / Implementor will not need to notify the CLEC.

Sincerely,

Linda Hendricks Lead Project Analyst Qwest

Cc: Mary Retka, Mary Pat Cheshier, Diane Diebel