Open Product/Process CR PC071403-1 Detail |
| Title: Good Faith Estimate of Construction Charges | ||||||
| CR Number |
Current Status Date |
Area Impacted | Products Impacted | |||
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| PC071403-1 |
Denied 11/19/2003 |
Pre-ordering, Ordering, Billing | UNE, DS1, DS0 | |||
| Originator: Berard, John |
| Originator Company Name: Covad |
| Owner: Boudhaouia, Jamal |
| Director: |
| CR PM: Sanchez-Steinke, Linda |
Description Of Change |
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Covad requests that Qwest provide a good faith estimate of construction charges (at no cost) for wholesale customers. Qwests current process requires that the requesting CLEC provide a non-refundable fee up front in order for Qwest to determine an estimate of the construction costs. In many cases it might cost upwards of $1000 to provide an estimate of these costs to our end users. With non-refundable charges of this magnitude it makes it impossible for us to use the current process which causes us to cancel the order rather than potentially moving ahead with the order. It must also be noted that Qwest currently provides this estimate to it’s retail customers at no charge.
Expected Deliverable: Qwest revises their current process to provide free of charge a good faith estimate of construction charges. Covad is looking for this process change as soon as possible.
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| Date | Action | Description |
| 7/14/2003 | CR Submitted | |
| 7/15/2003 | CR Acknowledged | |
| 7/16/2003 | July CMP Meeting - Meeting minutes will be posted to this CR's Project Meetings section. | |
| 8/20/2003 | August CMP Meeting - Meeting minutes will be posted to this CR's Project Meetings section. | |
| 9/17/2003 | September CMP Meeting - Meeting minutes will be posted to this CR's Project Meetings section. | |
| 10/15/2003 | October CMP Meeting - Meeting minutes will be posted to this CR's Project Meetings section. | |
| 11/19/2003 | November CMP Meeting - Meeting minutes will be posted to this CR's Project Meetings section. |
Project Meetings |
| 11/19/03 November CMP Meeting Jamal Boudhaouia with Qwest reviewed the draft response. John Berard with Covad said parity with retail was not addressed in the denial response and would like it addressed in the denial letter. Jamal said that Qwest is looking at modifying the retail tariffs. Bonnie Johnson with Eschelon said that Qwest has addressed recovery of costs in the denial response. Jamal responded that it is in the fourth paragraph of the denial response. John asked if Qwest is looking at the retail tariffs in order to bring to parity. Jamal said in the response the CLECs agreed to what is currently in the SGAT and Qwest will look at the tariffs to see what can be done and come back to SGAT and TRO Compliance. Kit Thomte with Qwest asked if we could open an Action Item to track the retail tariffs. John agreed that an Action Item should be opened. John asked about the parity issue. Jamal said Qwest is still looking at modifying the Retail tariffs. John said that the way he understands the Qwest engineer job, that for $1500 the job is fully engineered. When you have someone provide an estimate for work on your house, it is not fully engineered and materials are not purchased. There should be the ability for the engineer to tell in one hour what size cable would be needed how much and then just provide an estimate. If additional information was included in the jeopardy notice; there is no F1 cable CLECs can probably estimate that themselves or there is no F2 distribution. Jamal said that Qwest has not looked at providing that detail of information in a jeopardy notice. Jamal added that the engineers can look at LFACS and could look at the kind of cable required for a job but wouldn’t know if it should be aerial, buried, or if there is a need to bore. In addition, the field engineer needs to survey in order to see any obstacles. John said that the engineer could look at the cable plat. Jamal said that engineering would need to additionally look at burying the cable or bore etc. Jamal added that the process and proposed changes will be introduced in the SGAT and will be TRO compliant. Liz Balvin with MCI asked if the QPF is designed. Jamal said that the CR requested a good faith estimate at no cost. Construction will be re-evaluating and will bring in line with the TRO. John said that he would like the parity issue and how it will be resolved addressed in the denial letter and an Action Item opened to review the retail tariffs. Judy Schultz suggested that Covad send in a new CR regarding the jeopardy process. John asked Qwest to update the denial letter to address the parity concern noted in the CR. This CR will be moved to Denied status. Eschelon Comments on Meeting Minutes - I made several statements regarding this issue and none are noted. Since it is difficult to talk and write I don’t have my comments noted. If you cannot update the minutes with my comments, I can ask if other CLECs noted them. If not then I would like the minutes to reflect my concern that my comments were not noted. 10/15/03 October CMP Meeting Jamal Boudhaouia with Qwest reviewed the revised draft response. Jamal said that the QPF is closely related to the Crunec process which is not in place. Qwest is evaluating this CR and will provide an updated response at the November CMP Meeting. John Berard asked if Qwest has reviewed the retail process where currently the retail estimate is provided at no charge. Jamal said we are evaluating the retail process. Bonnie Johnson said she disagrees that QPF is related to the Crunec process. This CR will remain in Evaluation status. 09/17/03 September CMP Meeting Denny Graham with Qwest said that Qwest is evaluating this response and will provide an updated response at the October CMP Meeting. This CR will move to Evaluation status. 08/20/03 - August CMP Meeting Mike Zulevic with Covad presented this CR. Mike said that Covad would like to receive an estimate of construction changes up front at no charge. Quote Preparation Fees are between $1100-$1500 for a quote to provide facilities and Covad would like to see the costs up front, without having to spend $1100-$1500 on a non-refundable quote, similar to the Colorado Private Line Tariff. This CR will be moved to Presented status. CLEC Change Request Clarification Meeting 9:00 a.m. (MDT) / July 23, 2003 1-877-572-8687 3393947# PC071403-1 Good Faith Estimate of Construction Charges Attendees Name/Company: John Berard, Covad Denny Graham, Qwest Cindy Buckmaster, 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 Linda read the description of change from Covad’s CR as follows: Covad requests that Qwest provide a good faith estimate of construction charges (at no cost) for wholesale customers. Qwest’s current process requires that the requesting CLEC provide a non-refundable fee up front in order for Qwest to determine an estimate of the construction costs. In many cases it might cost upwards of $1000 to provide an estimate of these costs to our end users. With non-refundable charges of this magnitude it makes it impossible for us to use the current process which causes us to cancel the order rather than potentially moving ahead with the order. It must also be noted that Qwest currently provides this estimate to it’s retail customers at no charge. The meeting was opened for questions; Cindy Buckmaster explained that Qwest has a Quote Preparation Fee (QPF) for up front engineering preparation for the quote. Cindy asked John if Covad would like to be billed for the full amount rather than receiving a bill for the quote prep fee and then a bill for construction. John said that Covad would rather receive an estimate within + - 20% and the estimate not be fully engineered. Cindy explained that if Qwest has DS0 plant to make a DS1 the quote prep fee is $300 as long as Qwest doesn’t have to place plant. There are additional charges for construction and the QPF for this type of charge is not $1500. If Qwest has to construct plant, the QPF is $1500 and again there are additional charges for construction. Conditioning as defined by the FCC is removal of load coil and bridge tap. Removal of those elements doesn’t change the DS0 into DS1 it is just an unloaded DS0. The function Qwest performs to change DS0 plant into DS1 capable goes beyond conditioning and is considered construction. John said that with a retail estimate there is no up front construction charge and is a parity issue. Confirm Areas & Products Impacted Products impacted are DS1 & DS0 UNE Loops. Confirm Right Personnel Involved Qwest confirmed the correct personnel were on the call to resolve the CR. Identify/Confirm CLEC’s Expectation Provide a construction estimate free of charge on DS1 & DS0 UNE Loops Identify any Dependent Systems Change Requests No systems change requests. Establish Action Plan (Resolution Time Frame) Covad will present this CR at the August CMP meeting. 07/16/03 July CMP John Berard with Covad reviewed the walk on CR PC071403-1. There will be a clarification call on this change request.
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CenturyLink Response |
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November 11, 2003 For Review by the CLEC Community and Discussion at the November 19, 2003 CMP Meeting John Berard Director - Operations Support Covad Communications SUBJECT: Qwest Change Request Response CR # PC071403-1 Good Faith Estimate of Construction Charges This letter is in response to Covad Communications Change Request (CR) PC071403-1. This CR requests that Qwest provide a good faith estimate of construction charges (at no cost) for wholesale customers. It is appropriate to evaluate construction charges on an Individual Case Basis (ICB). Few construction projects are the same in terms of scope and nature thus, requiring separate evaluation by Qwest Engineers to determine what elements may need to be constructed. For example, construction costs vary depending on the size and type of cable being placed and the method used to place the cable, as well as the environment where the placing is being done. There currently are no standard placing costs that apply universally. This is why Qwest developed the Quote Preparation Fee (QPF) charge based on Qwest cost studies of the operations required providing the cost of UNE construction. QPF’s allow Qwest to recover the cost of the Engineering work required to complete this evaluation. This element is in-place and approved across jurisdictions for other Wholesale products as well. Before Qwest begins the evaluation process and expends any resources, the QPF must be submitted. Upon acceptance, this QPF is subtracted from the total cost of the job and the balance is submitted to the CLEC for payment. Upon payment by the CLEC of the identified construction costs, the construction will begin. The Good Faith Estimate referenced in this CR applies to developing an estimate of construction charges for UNEs that do not exist in the Qwest Network and therefore need to be built. Qwest and the CLEC community have agreed that Qwest can implement a Quote Preparation Fee (QPF) for the work that Qwest Engineers and planners perform to develop such an estimate. This is documented in Section 19.3 of the SGAT, which states: A quote for CLEC’s portion of a specific job will be provided to CLEC. QPF is provided in writing and is binding for ninety (90) business days after the issue date. When accepted, the CLEC is be billed the quoted price and construction commences after receipt of payment. If CLEC chooses not to have Qwest construct the facilities, Qwest reserves the right to bill CLEC for expenses incurred for producing the engineered job design. To assure an accurate price quote, Qwest engineering must provide diligence to the quote preparation. There is a substantial cost to investigate and prepare an accurate quote. In accordance with the SGAT, Qwest is entitled to recover these costs through the QPF. Therefore, Qwest respectfully denies the request because it is economically not feasible due to the burden of the cost to provide the construction quote being borne solely by Qwest. Although Qwest is declining this request, Qwest acknowledges that the definition of construction is changing in light of the TRO and recognizes that it may have an affect on the QPF and the constructions charges. Sincerely, Jamal Boudhaouia Staff Advocate cc:Mary Retka, Barry Orrel, Ev Montez
-- October 1, 2003 REVISED DRAFT RESPONSE For Review by the CLEC Community and Discussion at the October 15, 2003 CMP Meeting John Berard Director - Operations Support Covad Communications SUBJECT: Qwest Change Request Response - CR # PC071403-1 Good Faith Estimate of Construction Charges This letter is in response to Covad Communications Change Request (CR) PC071403-1. This CR requests that Qwest provide a good faith estimate of construction charges (at no cost) for wholesale customers. Qwest views this request as related to the recent changes to the DS1 construction policy. The latest CMP notice PROS.09.18.03.01198 DS1CapableLoopProc posted on September 18, 2003 was open for comments until September 30, 2003. Qwest is currently evaluating the QPF (Quote Prep Fee) and the CRUNEC process and would like to request that this CR be kept in an Evaluation Status. Qwest will provide an update at the November Meeting. Sincerely, Denny Graham Staff Advocate Policy and Law September 9, 2003
DRAFT RESPONSE For Review by CLEC Community and Discussion at the September 2003 CMP Meeting
John Berard Covad
SUBJECT: Qwest’s Change Request Response - PC071403-1 "Good Faith Estimate of Construction Charges" This letter is in response to Covad Communications Change Request (CR) PC071403-1. This CR requests that Qwest provide a good faith estimate of construction charges (at no cost) for wholesale customers. Qwest is currently evaluating this request and proposes moving this Change Request into Evaluation Status while we continue to investigate. Qwest will provide an updated response at the October CMP meeting. Sincerely, Denny Graham Staff Advocate Policy and Law
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Information Current as of 1/11/2021