Wholesale: Products & Services

Open Product/Process CR PC070103-3 Detail

Description Of Change

An end user customer should be able to obtain one due date for installation/functioning of both voice and data. Carriers should be able to place a single LSR to convert physical DSL service (regardless of the identity of the ISP) to any provider without undue service interruption. Regardless of the ISP (or of the sharing scenario, if any), customer switches that involve both voice and data should be performed with (1) one LSR, and (2) no extended service disruption. With this request, we seek, for example, to: (1) ensure that the use/presence of a DSL Volume provider does not adversely impact conversions/conversion intervals when switching providers. (If a conversion would not result in an extended outage or longer intervals if a non-volume DSL provider is involved, then the same conversion should not result in an extended outage or longer intervals if a volume DSL provider is involved); and (2) to convert (using a single LSR) a customer’s existing DSL service regardless of how service is provided [including various sharing scenarios (e.g., line sharing/splitting; loop sharing/splitting)] without extended service interruption to data or voice providers.

#1

There should be no exception to the process for volume providers. Currently, when a customer switches from Qwest Retail DSL and Qwest ISP service to a CLEC, Qwest processes allow a CLEC/DLEC, using one LSR, to (a) convert the DSL and change the ISP (for resale/UNE-P), or (b) perform a partial conversion (such as leaving the line and DSL with Qwest Retail for one line and converting the remaining lines in the account to CLEC) – both without disconnecting the DSL. In contrast, when the customer has DSL service from a volume provider, Qwest will disconnect the DSL in both of these scenarios. The disconnect is not momentary. It results in a DSL outage for the customer for the length of the entire interval required to add the DSL again (5 days or more). Such outages are harmful to competition, because customers are reluctant to switch carriers when faced with such an extended DSL outage. The presence or absence of a volume provider should not affect the result. In any case, such an extended DSL outage should not occur. CLECs should be able to request these conversions using one LSR.

#2

The current process that does not require DSL disconnects (see #1a and #1b) should be expanded to include the types of conversions that currently result in DSL disconnects/outages, cannot be ordered using one LSR, or both. When switching carriers, an end user customer should be able to obtain one due date for installation/functioning of both voice and data and should not experience extended DSL outages. This result should not depend on the product that the customer currently uses or to which it is switching. Currently, the result does vary by product. For example, if a customer is on line sharing (with Qwest Retail voice and Covad data) and wants to switch to a UNE-P line splitting product (with CLEC voice and Covad data), Qwest will disconnect the DSL. Again, the disconnect is not momentary and results in an extended DSL outage. Even though the data is staying with Covad in this example, Qwest requires disconnection of the line sharing product and re-establishment of the UNE-P line splitting product as a physical matter. In reality, however, this should just be a pure records change for data and should not affect the customer’s service. CLECs should be able to request these conversions using one LSR.

Expected Deliverable:

Qwest will develop, document and train a process(es) that meets the needs described in the above Description of Change. The process will expand the current one to avoid DSL disconnects/outages in situations that currently result in disconnects/outages; it will allow use of a single LSR for ordering these conversions; and it will not include any exception for volume providers. If different parts of this CR can be done earlier than others, please describe the options to CLECs. Also, if different methods would be used to provide these conversions (such as a coordinated hot cut type elective option), please describe. Eschelon and Covad bring these issues together in one CR so that portions of the request do not fall between the cracks.

Text of e-mail message from Bonnie Johnson:

“Scenario #1

Qwest Retail customer is converting to Eschelon (Resale or UNE-P) and hasQwest DSL with the DVDP FID. Eschelon sends conversion request and retains Qwest DSL but changes the ISP host (we do these today when the customer does not have volume provider arrangement).

Scenario #2

Qwest Retail customer is converting to Eschelon (Resale or UNE-P) and has Qwest DSL with the DVDP FID. Eschelon sends conversion request and requests the line with Qwest DSL with volume provider stay with Qwest and Eschelon converts all or a part of the remaining account (we do these today when the customer does not have volume provider arrangement).

Scenario #3

Qwest Retail customer is converting to Eschelon (Facility based) and has Qwest DSL with or without a volume provider. Eschelon converts the line with DSL to a DSL (XDSL-I) capable loop.”

Project Meetings

Jill Martain/Qwest stated that this CR was closed in the February CMP Meeting.

2/16/05 Product Process CMP Meeting

Jill Martain - Qwest stated that this CR was effective 12/4/04 and that we addressed the global concern Eschelon raised last month regarding notifications. Jill said that notifications should now include the CR number in the title and the notes.

Bonnie Johnson - Eschelon said that she was ok to close this CR. She said that the problem is with DSL and typing errors on the DD and it is hard to determine if the problem is due to the global concern she raised last month. Bonnie thanked Qwest for the additional information on the notifications.

1/19/05 CMP Meeting

Lynn Stecklein/Qwest stated that this CR was effective December 4, 2004 and should be ready to close. Bonnie Johnson/Eschelon said that she has a global concern associated with notifications. Bonnie said that the notification for this CR did not include the CR number that the notice was associated to and asked if Qwest could include the CR number on the notices. She stated that she would like to keep this CR open another month. Jill Martain/Qwest stated that we will take an action item to review the notification issue. Jill Martain/Qwest stated the CR would remain in CLEC test.

December CMP Meeting Minutes Cindy Macy – Qwest advised this CR was effective December 4. This CR will move to CLEC Test Status.

11/17/04 November meeting minutes Cindy Macy – Qwest advised this CR is still on track for December 2004 due date. This CR will remain in Development Status.

10/20/04 CMP Meeting Minutes Cindy Macy – Qwest advised this CR is still on track for December 2004 due date. This CR will remain in Development Status.

9/15/04 CMP Meeting Minutes Cindy Macy – Qwest advised this CR is still on track for target deployment in December 2004. This CR will remain in Development Status.

8/16/04 CMP Meeting Mintues Cindy Macy – Qwest advised that the target implementation date is December 2004. There is system work that needs to occur that is in progress. This CR will remain in Development Status.

07/21/04 July CMP Meeting: Cindy Macy – Qwest advised that this CR is effective October 18. The PCAT is currently being updated. This CR will remain in Development status until the CR is implemented in October.

06/16/04 June CMP Meeting Linda Sanchez-Steinke with Qwest said there is no new information since April’s update and implementation is tentatively scheduled for 10/16/04. This CR will remain in Development status.

-- 05/19/04 May CMP Meeting Linda Sanchez-Steinke with Qwest said last month’s update was that implementation is tentatively scheduled for 10/16/04. This CR will remain in Development status.

04/21/04 April CMP Meeting Anthony Washington with Qwest gave an update that the implementation date is tentatively scheduled for 10/16/04. We are currently finalizing the requirements. Bonnie Johnson with Eschelon asked if there were systems impacted. Anthony said FTS and Integrator are impacted. This CR will remain in Development status.

03/17/04 March CMP Meeting Linda Sanchez-Steinke with Qwest gave an update that funding approval has been received and we are waiting for an implementation date and will give an update on the implementation date at the April meeting or before if available. John Berard asked if all requirements for development were complete and which systems were being changed. Linda said the systems were not CLEC facing and could not answer if development was completed. This CR will remain in Development status.

- 02/18/04 February CMP Meeting Anthony Washington with Qwest provided an update that we have received funding approval and are waiting for an implementation date. This CR will remain in Development status.

01/21/04 January CMP Meeting Russ Urevig with Qwest gave an update that the Migration/Conversion PCAT will contain a link for unbundled loop scenarios and will explain if a single or a combination of LSRs is required. The documentation will be available in the late January timeframe and will be located at the end of the ordering section in the Migration/Conversion PCAT. This CR will remain in Development status.

12/17/03 December CMP Meeting Russ Urevig with Qwest said that there were questions submitting orders and the scenarios for migrations and conversions. Bonnie Johnson with Eschelon added they need to know how to submit the LSRs. Russ asked if the CR should be left open for this documentation change. Linda Sanchez-Steinke with Qwest said that the CR should remain open due to systems changes needed. This CR will remain in Development status.

11/19/03 November CMP Meeting Anthony Washington with Qwest gave an update on Scenario #1 and said that Qwest accepts this CR and the process changes will be initiated. Updates will be provided as the project moves forward. Jamal Boudhaouia with Qwest added that the CLECs should understand that the CLEC should provide the end user a modem and a profile should be ready and built in the new ISP to additionally minimize downtime. Bonnie Johnson with Eschelon said she did understand. Bonnie added that Qwest had announced PCAT changes associated with scenario #3 and needs to provide additional information on how to submit an LSR when ordering four voice retail lines to convert to an unbundled loop and one data line is converting to an unbundled loop with DSL service. Russ Urevig said that he is doing research and will determine if a PCAT update is needed. This CR will move to Development status.

10/15/03 October CMP Meeting Deb Smith with Qwest gave an update on Scenario #3 and #4. Updates have been made to PCATS for Line Sharing, Loop Splitting, Line Splitting, Unbundled Loops and Migrations and Procedures. The procedure identifies if 1 or more LSRs are needed and explains that downtime will not exceed 45 minutes. Kim Isaacs with Eschelon asked if the DSL notices were in the UNE loop PCAT. Deb Smith said the unbundled loop PCAT went out as a level 2 on 10/1/03. Kim said that she will review the changes and added that she didn’t know that the CR was associated with the PCAT.

Anthony Washington with Qwest gave an update on Scenario #1. Qwest SME’s held a meeting with Bonnie Johnson to discuss looking at separate service orders to resolve the CR. Qwest is re-evaluating and will have an update at the November meeting. This CR will remain in Evaluation status.

Meeting Minutes PC070103-3 September 30, 2003 1-877-572-8687, Conference ID 3393947# 1:00 p.m. - 1:45 p.m. Mountain Time

List of Attendees: Bonnie Johnson - Eschelon Janean Van Dusen - Qwest Cindy Schwartze - Qwest Anthony Washington - Qwest Michael Whitt - Qwest Linda Sanchez-Steinke - Qwest

The meeting began with Qwest making introductions and welcoming all attendees. Linda Sanchez-Steinke with Qwest explained that the purpose of the meeting was to discuss CR PC070103-3 and Bonnie’s request at the September CMP meeting to review whether the process could be accomplished by Qwest initiating two service orders.

Bonnie said at the September CMP meeting, Qwest denied this CR because it was economically unfeasible due to changes to systems that would have to be done. Eschelon would like to convert customers with no downtime on DSL when a customer has a volume service provider. From a process perspective, issue an order to disconnect DSL volume service provider and ISP then consecutively issue an order to install Qwest DSL ISP of choice. This process would re-install the service order so the customer is not without DSL service.

Cindy Schwartze asked if Eschelon wants Qwest to take the LSR and if it has VISP remove that and keep the same speed, change the host and there will no outage of DSL. Bonnie agreed.

Bonnie said the response at September CMP didn’t make sense because systems would not need to be changed to accomplish, when it can be done by changing a process. An order could be issued with Qwest DSL staying or changing and another order, with one due date, the date of conversion, getting rid of the host and getting a new one. The request is not to have any downtime.

Anthony Washington asked how much downtime, Bonnie said that we have discussed this and Linda said that 45 minutes downtime had been identified as acceptable in the change request.

Janean Van Dusen said that we have legal and contractual obligations with the volume ISP.

Bonnie said that when the LSR is sent in, Qwest allows the disconnect of the volume ISP. Bonnie suggested that if we look at this as a process solution, we could use 2 service orders to accomplish the same thing, the volume ISP would go away, and the customer would not have the 5 day lag time without DSL. It is not logical that system changes would be required to accomplish the change request.

Cindy asked if this example would be accurate: Eschelon wants to issue 1 LSR to convert the account, remove the VISP, add or change what is existing for Qwest DSL with the same due date. Cindy further explained that today Eschelon issues 1 LSR to convert and remove the VISP and 1 LSR to add Qwest DSL and host. Bonnie said that the second LSR can’t be submitted until the VISP order is completed.

Michael Whitt asked if Eschelon would be willing to send more than 1 LSR. Bonnie said it is not Eschelon’s preference and it would leave more room for gaps and rejects in error. Bonnie asked if they would get IMA up front errors.

Cindy asked if there was a question about different modems for the end user and new I-host. Anthony said he did not believe that has anything to do with Qwest.

Cindy asked if the VCI/VPI would be an issue. Bonnie said that Qwest resale or Qwest retail change, VCI/VPI, on Qwest Q host on the same day.

Cindy said the CLEC gets the VCI/VPI within 1 hour and Integrator does translations.

Bonnie said that Eschelon is currently using this process with customers on Qwest retail DSL with Qwest ISP. Volume ISP is a contractual agreement. If it is not a Volume ISP and the costs are $1 M, what systems need to be changed and why does the process work currently when there is not a volume ISP.

Cindy Schwartze said that the VISP isn’t a resale-able product. Originally we rejected LSR’s because it wasn’t a resale-able product. Cindy said that Qwest needs to get everyone together for an estimate of what it would take.

Michael Whitt said that we can’t promise that the response will be different and said that we have been working on a way to provide the change requested. Bonnie said that the CMP process states that if the CR is denied that Qwest should provide details.

Linda asked if there were any additional questions. No questions were asked and Linda said that we would discuss this CR at the October CMP meeting.

09/17/03 September CMP Meeting Deb Smith with Qwest explained this CR was submitted jointly by Eschelon and Covad and was divided into Scenarios 1 through 4.

Deb read the draft response for Scenario 3, a Qwest Retail customer is converting to Eschelon (Facility based) and has Qwest DSL with or without a volume provider. Eschelon converts the line with DSL to a DSL (xDSL-I) Capable Loop. Qwest and Eschelon agreed that downtime will not exceed 45 minutes on these type of requests and will update the Unbundled Loop PCAT with this information.

Deb read the draft response for Scenario 4, Line Sharing, Line Splitting and Loop Splitting, has been addressed in a CR PC012703-2 and Qwest has updated the Migration and Conversion PCAT addressing the need for more than 1 LSR for each migration or conversion possible. The PCAT will be updated to reflect the 45 minute timeframe and will get the information to the documentation team by Friday. Notification of updated PCAT will be provided to the CLEC Community.

Anthony Washington read the draft response for Scenario #1. Liz Balvin with MCI said that the CMP document says that if a CR is denied as economically not feasible, then Qwest should provide some details around the costs in excess of one million dollars. Bonnie Johnson with Eschelon stated she wants Qwest to go back to the drawing board and determine if this can be done by issuing separate service orders. Eschelon wants to have Qwest DSL that same day and not 5 days later. A separate call will be held to discuss alternate process solutions to implement this scenario.

Anthony read the response for Scenario #2, Qwest is currently providing this capability. This CR will remain in Evaluation status.

CMP Meeting 08-20-03

Smith-Qwest presented the response; Qwest is still evaluating the request. The request was moved to Evaluation status.

===========================================

Sent: Fri 8/8/03 5:48 AM From: Bonnie Johnson To: Linda Sanchez-Steinke RE: Question Scenario #3 PC070103-3 Hi Linda, The customer in this scenario would be converting both voice and data to the CLEC. No services would be left with Qwest.

Let me know if this helps!

Have a good day!

Bonnie Johnson Sr. Manager ILEC Relations Eschelon Telecom, Inc. Phone 612 436-6218 Fax 612 436-6318 Cell 612 743-6724

Sent: Wed 8/6/03 1:31 PM To: Bonnie Johnson From: Linda Sanchez-Steinke Subject: Question Scenario #3 PC070103-3

Bonnie - Below is a question from Deb Smith, on CR PC070103-3. Would you respond back to me and I'll e-mail on to Deb.

Thank you Linda Sanchez-Steinke CRPM Qwest 303-965-0972

Scenario #3 Qwest Retail customer is converting to Eschelon (Facility based) and has Qwest DSL with or without a volume provider. Eschelon converts the line with DSL to a DSL (XDSL-I) capable loop.

Bonnie,

We need a bit more clarification on scenario #3. Our understanding of scenario #3 is that a Qwest Retail customer is converting both voice and data to Eschelon. Is that correct? If so, this would be a conversion to an Unbundled Loop xDSL-I reusing existing facilities (if facilities qualify). If the voice portion is remaining with Qwest, this is not a conversion and would require a new Unbundled Loop to the premise.

Any additional clarification would be greatly appreciated.

Thank you, Deb Smith

Mon 8/4/03 11:48 A From: Bonnie Johnson To: Linda Sanchez-Steinke RE: PC070103-3 Scenario #2

Linda, I clarified all of this on the clarification call, however, if Qwest needs further information then we need a call. Yes Qwest currently offers partial conversions but the DSL is disconnected at the time of conversion when they have a volume provider. Bonnie Johnson Sr. Manager ILEC Relations Eschelon Telecom, Inc. Phone 612 436-6218 Fax 612 436-6318 Cell 612 743-6724

From: Linda Sanchez-Steinke To: Bonnie Johnson Sent 8/4/03 8:36 Bonnie -

I am backfilling for Matt White and Anthony Washington had a question about PC070103-3, scenario #2.

The following is Anthony's question: Scenario #2 appears to be a partial conversion, which Qwest already makes available to CLECs. Therefore, explain how the scenario differs from a partial conversion, and or, revise the scenario in a manner that differs from scenario #1 and #3.

Bonnie, I've attached the scenarios and would you e-mail me back, if needed we can get Anthony on a conference call.

Thank you

Linda Sanchez-Steinke CRPM Qwest 303-965-0972

Clarification Meeting - 07-21-03

Attendees Matt White Deb Smith Crystal Soderlund Cindy Schwartze Janean Van Dusen Karen McClemic Bonnie Johnson John Berard

(NOTE: Prior to this meeting, Johnson-Eschelon forwarded three scenarios that involved the change requested in this CR. The text of this e-mail is included at the end of these minutes.)

White-Qwest described the purpose of the meeting and asked the Qwest attendees if they could articulate their questions to Bonnie.

Smith-Qwest thanked Johnson for the scenarios she provided by e-mail. She stated that there is mention in the CR of line splitting and line sharing. Johnson-Eschelon stated that Berard should send Qwest examples of these scenarios. Berard-Covad stated that he would send those examples. He stated that what he wanted to address is the down time that is involved with a conversion. Smith-Qwest asked if Covad was seeking to issue only one LSR. Berard-Covad stated that he was interested in only one LSR and the issue of the 5 days of down time.

Johnson-Eschelon stated that whatever process Qwest develops, even if it involves that CLECs need to send a separate LSR that piggybacks on the first one one, the due dates should match. Soderlund-Qwest asked what product Johnson was referring to. Johnson-Eschelon stated that she was interested in Resale, UNP-P, UNE loop, line sharing and line splitting. Soderlund-Qwest asked what the conversion would be from. Johnson-Eschelon stated that this was a very large CR that may have to be done in pieces. She emphasized that she wanted to ensure that no piece slipped through the cracks.

Schwartze-Qwest stated that she had reviewed the scenarios Johnson had send and that she wanted to better understand scenario 1. She explained that the CR included information about converting to resale or UNE. She asked if Johnson understood, that with 13.0, Qwest would remove the DVDP FID and then the CLECs would need to submit another LSR. She stated that he understanding was the Eschelon did not want to submit the additional LSR or be subjected to the 5-day due date. Johnson-Eschelon stated that all the work happens on the due date. Schwartze-Qwest asked if Eschelon wanted to be able to provide the new I-host to Qwest rather than disconnecting the DSL and having to order the feature on the line.

Van Dusen-Qwest asked what the difference was between scenarios 1 and 2. Johnson-Eschelon stated that scenario 2 is where the customer wants to keep DSL with MSN and Eschelon wants to opportunity to leave it behind. She stated that was doing a partial conversion where Eschelon leaves the line and DSL as they are. She explained that she was asking for a partial conversion but that she wanted the line and DSL to stay as a Qwest retail account. She stated that this would occur if a customer has 5 lines wherein one is 1FB with Qwest DSL with MSN and Eschelon wants to convert the other 4 lines. Smith-Qwest asked of the 3rd scenario referred only to unbundled capable XDSL-I. She confirmed that Eschelon wanted Qwest only to be validating that the line was DSL capable, not validating the dial tone. Johnson-Eschelon stated that Eschelon wants to reuse the facilities and turn it into a DSL capable loop.

Berard–Covad stated that he could prioritize the scenarios that have already been identified. He stated that Covad could not live with a 5-day disconnect. He explained that Covad wanted voice and DSL to have same due date. Soderlund-Qwest asked Berard and Johnson could provide Qwest with a prioritized list of all the examples that fell under this change. Johnson-Eschelon stated that she had provided her examples and that numbers 1 and 2 were her top priority. She explained that every example left the customer without service. She stated that she did not want Qwest to work these examples in series. She stated that she expected to work on these examples in parallel. Soderlund-Qwest stated that she wanted to ensure that Eschelon and Covad were on the same page when it came to the examples. She explained that Qwest needed to be sure that Eschelon’s and Covad’s priorities are the same. Berard-Covad stated that he would take Johnson’s examples and add any additional ones that he felt were appropriate. Johnson-Eschelon stated that Eschelon and Covad were jointly submitting the CR and that the big scope of the CR is that we don’t want our customers to be without DSL service. She stated that the intent of the CR is to have Qwest develop a process to avoid a situation where customers are making decisions to change to Eschelon or Covad and then changing their minds because they will be without service for 5 days. She explained that she want processes to stop this impact on the customers and that she did not want to have to prioritize her examples. She stated that Eschelon wanted them all to have top priority. She explained that she understood that each product might have a different timeframe depending on the scope of the change, but that she did not want to send a prioritized list because the CR is asking for Qwest to develop processes. Soderlund-Qwest thanked he for her input.

White-Qwest asked if there were any additional examples needed. Smith-Qwest asked if Covad was going to provide more examples. Berard-Covad stated that he would go through existing documentation and send any additional examples to White-Qwest. Berard-Covad asked if there were any instances when the DSL does not go down. Schwartze-Qwest stated that with the DVDP arrangement, DSL goes down on all sides. She stated that she was concerned about line sharing/splitting and loop sharing and asked if Berard could send outage examples for these products. Berard-Covad stated that the big examples for Covad are line sharing and line spliting. Johnson-Eschelon stated that she understand that there would be some outage time on the dure date because work must occur. Smith-Qwest stated that Berard had said that 45 minutes would be an acceptable amount of down time. Berard-Covad stated that he was fine with that. He understood that Qwest needed time to move and test the cross connects.

Johnson-Eschelon stated that she agreed. She also stated that her biggest challenge is getting the DVPIVCI info off Q-host. Schwartze-Qwest stated that she had been told that the integrator refreshes every hour. Johnson-Eschelon stated that her problem was with it getting translated.

White-Qwest confirmed that there were no more questions. Johnson-Eschelon asked that if Qwest had any questions that they contact her for an impromptu meeting or call.

Text of e-mail message from Bonnie Johnson:

Scenario #1 Qwest Retail customer is converting to Eschelon (Resale or UNE-P) and hasQwest DSL with the DVDP FID. Eschelon sends conversion request and retains Qwest DSL but changes the ISP host (we do these today when the customer does not have volume provider arrangement).

Scenario #2 Qwest Retail customer is converting to Eschelon (Resale or UNE-P) and has Qwest DSL with the DVDP FID. Eschelon sends conversion request and requests the line with Qwest DSL with volume provider stay with Qwest and Eschelon converts all or a part of the remaining account (we do these today when the customer does not have volume provider arrangement).

Scenario #3 Qwest Retail customer is converting to Eschelon (Facility based) and has Qwest DSL with or without a volume provider. Eschelon converts the line with DSL to a DSL (XDSL-I) capable loop.

07-17-03 Clarification Meeting

Attendees Matt White - Qwest Deb Smith – Qwest Heidi Moreland - Qwest Crystal Soderlund - Qwest Monica Manning - Qwest Karen McClimek - Qwest Janean Van Dusen - Qwest Cindy Schwartze - Qwest Terry Kilker - Qwest Anthony Washington - Qwest John Berard - Covad

White-Qwest welcomed the attendees and explained the purpose of the call. He asked Berard-Covad to review the change. Berard-Covad reviewed the change. On any data migration CLECs should submit a single LSR for both voice and data. Similarly, the migration should get one due date for voice and data and there should be no more than 30-45 minutes of down time instead of five days. Soderlund-Qwest asked if Berard was talking about all of the shared products for this CR. Berard-Covad stated that he was. Smith-Qwest what UNE-P products the CR was referring to. Berard-Covad stated that the CR sought that the existing UNE P migration process now be linked to the data product. He stated that it encompasses many different scenarios and that Covad was looking for no down time for customers who ask for no down time. There was further discussion of different scenarios that this CR may apply to. Various Qwest SME’s asked that Berard and Johnson create a list of all possible scenarios that this CR would apply to so they could more appropriately respond to the request. Berard-Covad stated that he would like to have another clarification call with Johnson-Eschelon on the line. He stated that Covad and Eschelon would produce a list of all possible scenarios. White-Qwest stated that he would schedule another clarification call. He thanked the attendees and adjourned the meeting.

============================================ CMP Meeting 07-16-03

White-Qwest stated that this CR will have the clarification meeting on 7/17. Johnson-Eschelon presented the CR. CR to Presented status.

CenturyLink Response

November 11, 2003

For Review by the CLEC Community and Discussion at the November 19, 2003 CMP Meeting

Bonnie Johnson Director Eschelon Telecom Inc. 720 2nd Avenue South, Suite 1200 Minneapolis, MN 55402

SUBJECT:Qwest’s Change Request Revised Response PC070103-3 DSL Volume provider and data migration process to prevent extended DSL outage

This letter is in response to CLEC Change Request PC070103-3, scenario number one, re-evaluation. This CR is a request by Eschelon for Qwest to reduce its current provisioning interval for VISP conversions from the standard 5 days to a much more reasonable timeframe.

Qwest will accept this request. The following provides details surrounding this decision.

Qwest will allow CLECs to submit one LSR to convert VISP end users. The conversion process involves changing the host through a C & T action on the service order; therefore, Qwest will remove the VISP arrangement while not taking down the DSL service. This will alleviate the need for CLECs to submit two LSRs, one to remove the VISP and another to add the DSL service five days later.

The conversion process will maintain the DSL service but the host change will require the standard five day interval.

The new conversion process will impact several systems. After an analysis of the impact, Qwest has determined that more then 350 hours is required to complete systems changes, and develop and document the new process. Therefore, Qwest will schedule and complete the system changes, and develop the new process as soon as possible, and will provide updates as they become available.

Sincerely,

Anthony Washington Product Management Qwest

September 30, 2003

REVISED DRAFT RESPONSE For Review by CLEC Community and Discussion at the October 2003 CMP Meeting

Bonnie Johnson Eschelon

John Berard Covad

SUBJECT: Qwest’s Change Request Response - PC070103-3

Scenario #1 "Qwest Retail customer is converting to Eschelon (Resale or UNE-P) and has Qwest DSL with the DVDP FID. Eschelon sends conversion request and retains Qwest DSL but changes the ISP host."

During the September 17th CMP meeting Qwest denied Scenario #1 of CR PC070103-3 based on it being economically unfeasible. At that time, we were asked if it would be possible to accept the CR if Qwest Wholesale changed the process to allow one LSR and two services orders.

Currently we are re-evaluating this process change and identifying all the of the necessary process and systems changes that would be impacted. Therefore, we require more time to verify if it is possible to provide a minimal outage situation when a CLEC wishes to change the ISP host.

Sincerely,

Anthony Washington Product Manager

September 9, 2003

REVISED RESPONSE For Review by CLEC Community and Discussion at the September 17, 2003 CMP Meeting

Bonnie Johnson Eschelon

Mike Zulevic Covad

SUBJECT: Qwest’s Change Request Response - PC070103-3

This letter is in response to CLEC CR PC070103-3. This CR is a joint request from Covad and Eschelon to request that migrations (voice, data or voice/data) are obtained with a single LSR and minimal interruption of service. Clarification calls were held on July 17 and 21 to further identify the migration scenarios. Eschelon provided Qwest four scenarios. In this response, Qwest will provide responses to each of the scenarios separately.

Scenario #1 "Qwest Retail customer is converting to Eschelon (Resale or UNE-P) and has Qwest DSL with the DVDP FID. Eschelon sends conversion request and retains Qwest DSL but changes the ISP host."

Qwest response: The proposed change to the existing retail DSL product and processes would require resource allocation and expenditures associated with legacy systems and software specifications in excess of one million dollars. Information Technology redesigns would include systems changes to the electronic business to business system for each VISP provider, which would require considerable funding and a redirection of scarce technology resources. This would also include, to a significant extent, additional expense for producing and implementing changes to system performance and functionality of the Qwest VISP Graphical User Interface (GUI) and XML Interface, as well as require manual interaction to allow for communications with respect to Qwest retail customer changes and current status. Additional changes likely include significant modifications to existing ordering and processing systems and functionality, which would be a considerable burden at a great expense to Qwest.

Qwest respectfully denies Scenario #1 of this CR based on economic unfeasibility.

Scenario #2 "Qwest Retail customer is converting to Eschelon (Resale or UNE-P) and has Qwest DSL with the DVDP FID. Eschelon sends conversion requests and requests the line with Qwest DSL with volume provider stay with Qwest and Eschelon converts all or a part of the remaining account."

Qwest response: Qwest allows partial conversions of existing Qwest retail end user accounts to UNE-P or Resale services. In the instance where an existing retail end user account has more than one (1) line and one (1) or more of those lines has Qwest DSL Host Volume Discount Program arrangements (indicated by the presence of a DSL USOC followed by a ‘DVDP’ FID), CLEC may convert the entire account or specify certain lines for conversion.

If CLEC chooses to convert lines with DSL Host Volume Discount Program arrangements, as noted in the UNE-P with Qwest DSL PCAT, the (http://www.qwest.com/wholesale/pcat/unepqdsl.html) and similarly in the Resale DSL PCAT (http://www.qwest.com/wholesale/pcat/resaledsl.html), "Qwest will remove the DSL USOC and the DVDP FID from the account. This activity will remove end-user DSL functionality".

If CLEC chooses to convert only lines without DSL Host Volume Discount Program arrangements, the remaining retail lines with the DSL Host Volume Discount Program arrangements will remain in service.

Because Qwest currently offers this capability, Qwest accepts this Scenario of the CR.

Scenario #3 "Qwest Retail customer is converting to Eschelon (Facility based) and has Qwest DSL with or without a volume provider. Eschelon converts the line with DSL to a DSL (xDSL-I) Capable Loop."

Qwest response: Unbundled Loop Scenario #3 is a conversion of Qwest Retail customer’s service to the CLEC requested xDSL-I Unbundled Loop. The CLEC would submit 1 LSR to convert the Qwest Retail customer to the requested xDSL-I Unbundled Loop service with or without number portability. A disconnect will be performed on the end customer’s Qwest Retail service at the time of the migration activities.

During the PC070103-3 clarification meeting held on July 21, 2003, Covad, Eschelon and Qwest agreed that their request required that the activities of the migration not exceed 45 minutes. The migration activities would include the termination at the ICDF and any associated tests. For the Unbundled Loop services the migration work activities won’t exceed the 45-minute time frame.

Qwest accepts Scenario #3 of this CR. Qwest will update the Unbundled Loop General PCAT to reflect the migration activities will not exceed 45 minutes.

Scenario #4 Line Sharing, Line Splitting and Loop Splitting

Qwest response: In accordance with the Qwest response to PC012703-2, Data Migrations, the Migrations and Conversions Procedural PCAT (http://www.qwest.com/wholesale/clecs/migrateconvert.html) has been updated (in accordance with CMP timelines) with CLEC input on identification of the Data Migration scenarios for Line Sharing, Line Splitting and Loop Splitting. In that documentation, Qwest identifies, by scenario, whether a specific migration would require 1 LSR or multiple LSR’s. If the migration request currently requires more that 1 LSR, Qwest has provided the IMA (15.0) release that effects the change to 1 LSR.

During the PC070103-3 clarification meeting held on July 21, 2003, Covad, Eschelon and Qwest agreed that the activities of the migration will not exceed 45 minutes. The migration activities would include the ‘lift and lay’ of the cross connects and any associated tests. For the Line Sharing, Line Splitting, and Loop Splitting services the migration work activities won’t exceed the 45-minute time frame.

Qwest accepts Scenario #4 of this CR. We have responded, identified and documented the Line Sharing, Line Splitting and Loop scenarios as a result of PC012703-2, Data Migrations. Qwest will update the Data Migration scenarios for Line Sharing, Line Splitting and Loop Splitting (downloadable links) to reflect the 1 LSR vs. multiple and the IMA (15.0) release that effects the change to 1 LSR. Qwest will update the Line Sharing, Line Splitting, and Loop Splitting PCATs to reflect the migration activities will not exceed 45 minutes.

Sincerely,

Deb Smith Product Manager

Anthony Washington Product Manager

August 12, 2003

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

Bonnie Johnson Eschelon

Mike Zulevic Covad

SUBJECT: Qwest’s Change Request Response - PC070103-3

This is a preliminary response regarding the Eschelon/Covad CR PC070103-3. This CR requests a DSL Volume provider and data migration process to prevent extended DSL outage.

Qwest is currently evaluating this request. Because this request involves the creation of a complex and wide-reaching process, there are a large number of issues Qwest must analyze. Qwest proposes moving this Change Request into Evaluation Status and while we continue to investigate and provide an updated response.

Qwest will provide a status update at the September CMP meeting.

Sincerely,

Deb Smith Product Manager