Wholesale: Products & Services

Open Product/Process CR PC062603-1 Detail

Description Of Change

Other CLECs have no plans to discontinue this facility. In fact many are making enhancements with parameters, making this a viable facility for AT&T needs.

AT&T request that this facility be metallic only, unloaded and have a maximum distance of 12,000 feet using 24 gauge copper, or 9,000 feet using 26 gauge equivalent copper. In addition, it is requested that this facility have a maximum total bridge tap of no more than 2,500 feet, with no single bridge tap being longer than 2,000 feet.

Expected Deliverable:

Qwest to retain and enhance this facility

Project Meetings

07/16/03 July CMP Meeting Donna Osborne-Miller with AT&T presented this CR. AT&T would like Qwest to maintain the NCI code for this facility. Kate Pedersen with AT&T said that in a conversation with Bill Wycoff with Qwest he had stated the facility offering would be eliminated. Cindy Buckmaster with Qwest said that her understanding was that in the migration to Industry Spectrum Management Standards, those services would not be eliminated but would be merged into a specific spectrum class. Kate indicated that analysis matched her understanding.

CLEC Change Request Clarification Meeting

10:00 a.m. (MDT) / Friday, July 11, 2003

1-877-562-8687 3393947# PC062603-1 Industry Compliance Request LX-N 02QB9.00H Loop

Name/Company: Donna Osborne-Miller, AT&T Sharon Van Meter, AT&T Kate Pedersen, AT&T Lydia Braze, AT&T Phil Law, AT&T Jen Arnold, U S Link Cindy Buckmaster, Qwest Denny Graham, Qwest Bill Wycoff, Qwest Linda Sanchez-Steinke, Qwest

Introduction of Attendees Introduction of participants on the conference call was made and the purpose of the call discussed.

Review Requested (Description of) Change AT&T’s CR requests that Qwest not eliminate the LX-N 02QB9.00H loop. Many other ILECs offer this loop as an option and this option works well for AT&T. AT&T had heard that Qwest may be eliminating the option and would like to have the option continued.

Cindy Buckmaster with Qwest said that the designation of the HDSL facility (provided by the NCI code) defines the capability of a non-loaded loop, and further clarified that an HDSL capable loop is not a product offering. This is important to understand in determining if AT&T would like a new product announced or the maintenance going forward of the availability of the specified HDSL facility. AT&T said that they are fine with the continuation of the availability of the facility offering with the changes that would contain the following loop limiting parameters; 12,000 ft. maximum loop length for 24 gauge cable that includes Bridged Tap (BT), 9,000 ft. maximum length for 26 gauge cable that also includes BT. BT would be limited to 2,000 ft. maximum length for an individual BT, and a total bridge tap limit of 2,500 ft.

Cindy Buckmaster further explained that the NCI code identifies the facility and the NC is the classification of the product. The designation of LX-N tells Qwest that the customer wants a non-loaded loop. Prior to widespread availability of HDSL, Qwest selected the facility for the CLEC, and now, the CLEC has the ability to choose the facility by specifying the 02QB9.00H NCI code. Neither of these parameters limits the loop length or amount of bridged tap.

Phil Law with AT&T asked Bill Wycoff with Qwest if the .00H designator means that Qwest applies spectrum for HDSL so they know how to manage. Bill Wycoff said the LX-N triggers the facility and the .00H is the electrical interface. The interface code is informational to Qwest for possible spectrum management purposes and does not affect loop design or performance.

Bill Wycoff with Qwest asked Phil if AT&T orders a facility to a premises and there are no loops that meet the limitations set by AT&T above, if they want to receive a reject. Phil answered yes, AT&T would prefer a reject rather than get a loop with 5,000 feet of bridged tap.

Confirm Areas & Products Impacted The area of this Change Request impacts Unbundled loop, and UNE

Confirm Right Personnel Involved Qwest confirmed the correct personnel were on the call to resolve the CR.

Identify/Confirm CLEC’s Expectation AT&T’s expectation is that Qwest keep and enhance the LX-N 02QB9.00H facility.

Identify any Dependent Systems Change Requests No systems change requests.

Establish Action Plan (Resolution Time Frame) AT&T will present this CR at the July CMP meeting.

CenturyLink Response

DRAFT RESPONSE For Review by the CLEC Community and Discussion at the August 20, 2003 CMP Meeting

Donna Osborne-Miller AT&T

SUBJECT: Qwest’s Change Request Response - PC062603-1 "Industry Compliance Request LX-N 02QB9.00H Loop"

This CR requests that Qwest retain and enhance the LX-N 02QB9.00H unbundled loop facility.

In the interpretation of NC/NCI (Network Channel/Network Channel Interface) codes as provided by AT&T (LX-N 02QB9.00H), CLECs must refer to the UBL Technical Publication 77384. As indicated in Section 3 of this publication, the primary point of reference is the NC Code, which tells Qwest what facility type the CLEC is requesting. In the case of an NC Code equal to LX-N, the CLEC is requesting a metallic facility free of Load Coils. Where that facility is available in the Qwest inventory, or where incremental facility work can be accomplished to create such a facility, the non-loaded loop will be provisioned for the CLEC.

The secondary point of reference is the NCI Code, which provides operational information ONLY regarding the number of conductors the CLEC will be connecting at the interface (ICDF). Contrary to the proposal of AT&T, Qwest does not assign the facility for the NCI Code specified based on Loop Length or Bridged Tap. Rather, the loss parameter, of the facility requested, is measured at the interface and can be influenced by a number of elements, including Loop length and Bridged Tap length. Qwest processes are in place to ensure that the loss limits of the facility requested are in compliance with the specifications of the Technical Publication.

The Protocol Option part of the NCI, i.e., 00H, is informative to Qwest of the CLEC applied, electrical signal. This is used for spectrum management information.

None of these elements provide the limitations defined by AT&T (loop length, segment gauge, bridged tap limits). Therefore, these NC/NCI codes alone will not provide AT&T the specific facility they desire.

Qwest reviewed current assignment and inventory systems to determine if the necessary information can be gleaned and aggregated to accommodate this request. As Qwest systems currently consider only segment information and can’t aggregate the segments, this is not a viable option. Qwest would require System modifications that are expected to cost in excess of $1M to accommodate this request. Once the capability was installed, the system would logically need to be enhanced to accommodate specifications of each CLEC as their equipment may have facility needs different than the HDSL equipment in focus.

Qwest reviewed the manual process required to fill in where the system modification would be too costly. This manual process is likely to include expenses associated with: - Development of a means to identify a CLECs technical specifications - Additional assignment personnel to research potential facilities matching restrictions identified by the CLEC - Engineering time to review unqualified loops and create jobs to qualify the loops - Construction jobs may be required involving more construction personnel. - Additional network involvement to condition the loop (remove Load Coils and Bridged Taps) where applicable - A process to identify the required work on the customer’s records (perhaps on the CLECs bill)

A conservative estimate of the annual cost of providing this loop would be in excess of $250,000. Again, the identification of unique technical specifications, due to CLEC specific equipment and services requested, would only exaggerate this cost as well.

It is recommended instead that CLECs can use the Raw Loop Data Tool to provide the visibility to the likelihood that facilities are available to meet their request.

Although the CLEC can continue to order the LX-N Unbundled Loop, the technical specifications indicated by the CLEC, (maximum distance of 12,000 feet using 24 gauge copper or 9,000 feet using 26 gauge copper and a maximum total bridged tap of no more than 2,500 feet, with no single bridged tap being longer than 2,000 feet), cannot be guaranteed by Qwest. Therefore, Qwest respectfully denies the request because it is economically not feasible due to the cost to implement the request as identified above.

Sincerely,

Cindy Buckmaster Manager Product Management