Wholesale: Products & Services

Open Product/Process CR PC072010-1ES Detail

Description Of Change

- defined parameters for assignment of copper pairs

- assignment of the pair with the least amount of loss in the cross box

- new levels of conditioning (near and far bridge tap and remove all options)

- enhanced tests for specific types of NCI codes.

092310 REQUEST FROM ORIGINATOR Please revise the Level 4 CR PC072010-1 to also include the state of Montana. Changes in this CR will apply to both Minnesota and Montana and be reflected accordingly in the PCAT documentation.

110910 REVISION CR to apply to Minnesota only. Remove the reference to Montana

12/21/10 REVISION Title change - previous title was

"110910 ADD’L REVISION Change in process in Minnesota for Non Loaded and ADSL Compatible Loops used to provide xDSL services. 092310 REVISED Change in process in Minnesota AND MONTANA for Non Loaded and ADSL Compatible Loops used to provide xDSL services"

Previous title 12/21/10 REVISED Change in process in Minnesota for xDSL Capable Loops, e.g., Non Loaded and ADSL Compatible Loops (aka xDSL services)

Expected Deliverables/Proposed Implementation Date is November 22, 2010

Project Meetings

Bonnie Johnson – Minnesota Department of Commerce said she wanted to thank Jamal and Mark.

Jamal Boudhaouia – CenturyLink responded with a Thank You as well.

7/16/14 Product/Process CMP Meeting Mark Coyne– CenturyLink said there was nothing new to report.

6/18/14 Product/Process CMP Meeting Mark Coyne– CenturyLink said there was nothing new to report.

5/21/14 Product/Process CMP Meeting Mark Coyne– CenturyLink said there was nothing new to report.

4/16/14 Product/Process CMP Meeting Mark Coyne– CenturyLink said there was nothing new to report.

3/19/14 Product/Process CMP Meeting Mark Coyne– CenturyLink said there was nothing new to report.

2/19/14 Product/Process CMP Meeting Mark Coyne– CenturyLink said there was nothing new to report.

1/15/14 Product/Process CMP Meeting Mark Coyne– CenturyLink said there was nothing new to report.

12/11/13 Product/Process CMP Meeting Mark Coyne– CenturyLink said there was nothing new to report.

11/20/13 Product/Process CMP Meeting Mark Coyne– CenturyLink said there was nothing new to report.

10/16/13 Product/Process CMP Meeting Mark Coyne– CenturyLink said there was nothing new to report.

9/18/13 Product/Process CMP Meeting Mark Coyne– CenturyLink said there was nothing new to report.

08/21/13 Product/Process CMP Meeting Mark Coyne– CenturyLink said there was nothing new to report.

07/17/13 Product/Process CMP Meeting Mark Coyne– CenturyLink said there was nothing new to report.

06/19/13 Product/Process CMP Meeting Mark Coyne– CenturyLink said there was nothing new to report.

05/15/13 Product/Process CMP Meeting Susan Lorence– CenturyLink said there was nothing new to report.

04/17/13 Product/Process CMP Meeting Mark Coyne – CenturyLink said there was nothing new to report. Mark reminded everyone that the full CR was posted to the calendar.

03/20/13 Product/Process CMP Meeting Mark Coyne – CenturyLink said there was nothing new to report. Mark reminded everyone that the full CR was posted to the calendar.

02/20/13 Product/Process CMP Meeting Mark Coyne – CenturyLink said there was nothing new to report. Mark reminded everyone that the full CR was posted to the calendar.

1/16/13 Product/Process CMP Meeting Mark Coyne – CenturyLink said there was nothing new to report. Mark reminded everyone that the full CR was posted to the calendar.

12/12/12 Product/Process CMP Meeting Mark Coyne – CenturyLink said there was nothing new to report.

11/14/12 Product/Process CMP Meeting Mark Coyne – CenturyLink said that there was nothing new to report. Mark reminded everyone that the CR detail was not included in the Distribution package but was attached to the calendar entry.

10/17/12 Product/Process CMP Meeting Mark Coyne – CenturyLink stated that there was nothing new to report. Mark reminded everyone that, as discussed last month, the CR had been removed from the Distribution package and was attached to the calendar entry. Mark said this was done to cut down on print pages and said he hoped that worked for everyone.

There were no comments.

09/19/12 Product/Process CMP Meeting Mark Coyne – CenturyLink stated that there was nothing new to report. Mark asked, because of the number of pages, if we could remove the detail for this CR from the Product Process package and place it on the calendar as a separate document where it would still be available. Mark said doing this would save time and paper. Mark asked if there were any objections to doing this.

Kim Isaacs – Integra said she had no objections.

Mark Coyne – CenturyLink said we would start doing this next month then.

08/15/12 Product/Process CMP Meeting Mark Coyne – CenturyLink stated that there was nothing new to report.

07/18/2012 Monthy CMP Prod/Proc Meeting Mark Coyne – CenturyLink stated that there was nothing new to report.

06/20/2012 Product Process Monthly Meeting Mark Coyne – CenturyLink stated that there was nothing new to report. Last month it was reported that a Level 2 final notice was sent and was effective on May 25, 2012.

Kim Isaacs – Integra stated that the notice was not related to the xDSL.

Mark Coyne – CenturyLink agreed that it was general cleanup that was not associated with the CR.

05/16/12 Product Process Monthly Meeting Mark Coyne – CenturyLink said in regard to the Tech Pub 77384, a level 2 notice was sent on Friday, May 4, associated with the clarification and documentation cleanup updates not related to the xDSL CR. Some CLEC comments were received which are generally requests for further clarification. Mark said the level 2 CMP Final notice and CenturyLink response to comments will be sent on 5/18/12 with an effective date of 5/25/12.

4/18/12 Product Process Monthly Meeting Mark Coyne – CenturyLink reminded everyone that the Technical Publication 77384 was reviewed at the end of the March monthly meeting and the revised chapters had been posted to the CMP calendar. Mark said CenturyLink had proposed we move forward with a notice on the changes that had been reviewed to date however, several CLECs indicated that they disagreed with that approach. Mark said CenturyLink is proposing that updates be made to the Technical Publication to make updates and corrections that are not associated with the xDSL CR in an effort to clean up the document, for example, removal of SONET, change from “metallic” to “copper”, etc. Mark said CenturyLink is planning to move forward with a Level 2 notification in the near future and will be specific regarding the changes that are being made to clean up the document. Bonnie Johnson – Integra stated that they would take a look at the changes and would comment if necessary. Bonnie asked if CenturyLink was going to address the follow-up items from March and whether CenturyLink planned to discuss the PCAT and the Conditioning download. Mark Coyne – CenturyLink read the following statement as a result of the March action item after discussion with the CenturyLink legal and SME team. It describes the company’s position on the status of the PCAT and Conditioning download: CenturyLink has checked with our SME and legal team and it is our position that the Unbundled General PCAT and the xDSL Conditioning Download that are currently operational do not have any content that conflicts with the processes required for customers who request xDSL conditioning, including those customers that have signed the xDSL Services Amendment. The current PCAT and download documents are compliant with the Amendment and support the processes that went into effect and have been in place since 1st quarter 2011. With respect to issues that are currently pending in the Minnesota docket which have also been raised as CMP issues, the pleadings and testimony of CenturyLink which are on file in that docket in Minnesota represent CenturyLink’s position on such issues. If parties to the Minnesota docket believe that such issues can be resolved for CMP purposes in a manner that is different from the pleadings and testimony in the Minnesota docket, then CenturyLink is willing to consider such ideas. Bonnie Johnson – Integra asked if the statement would be posted to the minutes. Mark Coyne – CenturyLink said the statement would be included in the meeting minutes. Bonnie Johnson – Integra asked if CenturyLink was stating that the current xDSL documentation is accurate and without errors. Mark Coyne – CenturyLink stated that CenturyLink believes itself to be compliant with the amendment and that it does support the processes that went into effect in January, 2011. Bonnie Johnson – Integra stated that Integra disagrees in some, but not all, respects. Al Finnell – Windstream said Windstream concurs with Integra’s position. CenturyLink™ Wholesale Change Management Process (CMP) Meeting Minutes 04/25/2012 Page 3 of 3 Mark Coyne – CenturyLink asked if there were any other CLECs that agreed or disagreed with the CenturyLink position. There were none. He stated that we would send the Tech Pub 77384 non-xDSL updates as Level 2 notice toward the end of the month and would address any CLEC comments.

3/21/12 Product Process Monthly Meeting Mark Coyne – CenturyLink stated that as discussed in the February meeting, CenturyLink sent out notification on 3-12-2012 with the CenturyLink updates to the Technical Publication. The plan is to complete the agendas for Product/Process and System meetings, take a short break, and then reconvene to discuss those updates.

Bonnie Johnson – Integra asked when CenturyLink plans to discuss the PCAT Conditioning download.

Mark Coyne – CenturyLink responded that it was not planned for today and that CenturyLink would check to see if it was something that could be put on the agenda for April.

Bonnie Johnson – Integra stated that it was provided in January.

Mark Coyne – CenturyLink said that CenturyLink SME team had spent their time working on the updates to the Technical Publication in preparation for review today. Mark said the documents for review are posted to the calendar for todays meeting.

(4/2/12 Updates received from Integra in CAPS) NOTE: CENTURYLINK NEEDS TO MOVE THE TECH PUB MEETING MINUTES THAT IT CURRENTLY HAS AFTER THE SYSTEM MEETING MINUTE DISCUSSION HERE SO IT REMAINS WITH THIS CR. I REMOVED THEM FROM THE SYSTEM MINUTES AND ADDED THEM HERE, THEN REDLINED THEM. ALTHOUGH THE DISCUSSION TOOK PLACE AFTER THE SYSTEMS MEETING, THE MINUTES SHOULD REMAIN WITH THE ASSOCIATED CR.

Following a short break (4/2/12 Updates received from Integra in CAPS) FOLLOWING THE CONCLUSION OF THE SYSTEMS PORTION OF THE MONTHLY CMP MEETING, the CMP monthly meeting reconvened for a review of the CenturyLink proposed updates to the Technical Publication 77384 and the associated Footnote matrix in response to the Integra updates sent January 24, 2012. The results of the review are included in the STATUS column of the CenturyLink Tech Pub 77384 Footnote matrix. The Tech Pub 77384 discussion is captured below with the specific rows identified if applicable.

NOTE: The resulting Tech Pub 77384 Chapter updates that were made as a result of the discussion are available on the Wholesale Calendar for the March meeting. The chapters are dated March 28, 2012 with the additional updates highlighted in yellow. Two new chapters are posted that include updates associated with an action item to review how the terms “channel” vs “loop” are used.

Mark Coyne – CenturyLink relayed he was going to turn the meeting over to Jeff Farra – CenturyLink to begin the review of the revisions to the Technical Publication 77384 Chapters, including the Tech Pub Footnote matrix.

Bonnie Johnson – Integra expressed concern (4/2/12 Updates received from Integra in CAPS) WHETHER [delete THAT] the CenturyLink Tech Pub Footnote matrix would work and that though it identified the changes that CenturyLink MADE AS A RESULT OF THE FOOTNOTES [delete HAD MADE], she SAID [delete FELT] there were also Tech Pub updates that CENTURYLINK [delete HAD BEEN] made that were not [delete DISCUSSED] DISCLOSED in the matrix and those need to be discussed as we review the changes.

Mark Coyne –CenturyLink relayed CenturyLink felt that the matrix was the most concise way to identify the CenturyLink changes. Mark said if it was viewed that CenturyLink had made other changes, those changes would also be discussed.

Susan Lorence – CenturyLink identified that the Tech Pub Chapters and related documents to be reviewed were available on the Wholesale Calendar and how CenturyLink planned to review them.

Mark Coyne – CenturyLink stated the focus of the call today was to review the Tech Pub changes that were not pending in the Minnesota Docket.

Doug Denney – Integra asked what the CenturyLink intent was with regard to the Minnesota Docket and will the Docket resolve the issues from a CMP view (4/2/12 Updates received from Integra in CAPS) AND IF WE WERE AT IMPASSE IN CMP.

Mark Coyne – CenturyLink said depending on the outcome of the Minnesota Docket, CenturyLink will then determine the next steps.

Doug Denney – Integra asked if it will apply across the region and asked whether open issues should be discussed for other than Minnesota.

Mark Coyne – CenturyLink said the Docket would apply to Minnesota only and that CenturyLink was not prepared to discuss the other states.

(4/2/12 Updates received from Integra in CAPS) DOUG DENNEY – INTEGRA STATED THEN SHOULDN’T WE BE TALKING ABOUT THESE ISSUES FOR OTHER STATES?

Al Finnell - Windstream asked for the purpose of the call today and said if the Docket only applies to Minnesota, then the discussion can address the issues for the other states.

Mark Coyne – CenturyLink said today’s call was to review the CenturyLink responses to Integra outside of those addressed by Minnesota. Mark said he will need to check with the CenturyLink legal team on the question regarding other states. He said the focus today would be to review the CenturyLink Tech Pub chapters which incorporate at least 90% of the newly requested CLEC changes and to get a clean document to move forward. Doug Denney – Integra asked for CenturyLink to (4/2/12 Updates received from Integra in CAPS) [delete HAVE A FOLLOW UP] TAKE BACK WHAT DOES DEFERRED TO THE MINNESOTA DOCKET MEAN [delete TO CONSIDER THE IMPACT OF THE MINNESOTA DOCKET].

Al Finnell - Windstream asked for subsequent discussion regarding the other states on issues not discussed in the meeting today.

Mark Coyne – CenturyLink said that CenturyLink will need to meet with legal on these questions.

Jeff Farra – CenturyLink began review of each row in the Footnote matrix and the CenturyLink response included there.

Bonnie Johnson – Integra said in Section 1.2, Reason for Reissue, CenturyLink has identified that the changes are due to the xDSL Services Amendment however some Tech Pub changes are outside the scope of the Amendment. Bonnie said that CenturyLink needs to be specific on each reason for change and either make the unrelated change at a different time or specifically identify those changes separately (4/2/12 Updates received from Integra in CAPS) IN THE REASON FOR REISSUE.

Jeff Farra – CenturyLink (4/2/12 Updates received from Integra in CAPS) AGREED AND said CenturyLink will address that when we reissue the Tech Pub.

Susan Lorence – CenturyLink said a column had been added to the Footnote matrix regarding “Status” and that as each Footnote/response is reviewed, unless there are questions, CenturyLink will add an A to indicate that change was accepted.

Doug Denney – Integra asked about how CenturyLink is using the terms “channel” vs. “loop” across the Tech Pub and referred to an email exchange between Integra and CenturyLink . Doug said it does not appear that CenturyLink is using the terms consistently within the Tech Pub. (4/2/12 Updates received from Integra in CAPS) DOUG SAID CENTURYLINK SAID AN UNBUNDLED LOOP WAS A COPPER LOOP. THIS IS NOT NECESSARILY SO IN ALL CASES FOR EXAMPLE HI-CAP LOOPS CAN BE PROVIDED ON HYBRID LOOPS. WHAT IS THE INTENT OF VOICEBAND CHANNEL VS. LOOP? IS LOOP ONLY COPPER?

Susan Lorence – CenturyLink said the email exchange is posted to the calendar which differentiates how CenturyLink used the various terms. Susan asked if Integra’s question was that loops are “not limited” to copper?

Bonnie Johnson – Integra said the definition of “channel” in the email is different than what is used in Tech Pub Chapter 8.

Kim Isaacs – Integra said the terms “channel” and “capable loop” not used consistently between Chapters 1 and 5 which is confusing.

Bonnie Johnson – Integra asked if “channel” and “capable loop” are different things (4/2/12 Updates received from Integra in CAPS) BECAUSE A LOOP IS A LOOP and asked if CenturyLink was trying to limit one thing over another. Bonnie suggested putting something up front to explain how the terms are used.

Jeff Farra – CenturyLink said we had tried to be distinct but would review again for consistency. Jeff said in a loop environment, the terms are somewhat interchangeable but we will clarify.

Jeff Farra – CenturyLink said there were a number of changes throughout the chapters that would be addressed under the Reason for Reissue: removal of the product SONET due to a TRO change, “Unbundled” would be retained, and the word “Interconnection” would be removed.

Bonnie Johnson – Integra asked how CenturyLink placed the definitions included in the Tech Pub. She said it seems that terms specific to the xDSL Services Amendment are in Section 1.6.1 and that general definitions are in Chapter 8.

Jeff Farra – CenturyLink agreed.

Bonnie Johnson – Integra said in regard to Chapter 1, Footnote 24, and the first paragraph following the heading in Section 1.6.1, CenturyLink had added the wording “executed by the parties” in that first paragraph associated with the Amendment. Integra asked about the intent and said they did not believe the wording was necessary or correct and instead proposed the wording “is an agreement available to all CLECs and is based on…” Another option suggested by Integra was that the wording inserted by CenturyLink should be removed. In that same paragraph, Integra questioned the words inserted by CenturyLink “contemplated by.” CenturyLink agreed to review each of the proposed phrases with the CenturyLink legal team.

Also in Section 1.6.1, Bonnie Johnson – Integra questioned how the terms “interconnection agreement” and “ICA” are used throughout the Tech Pub Chapters, how they are not consistently capitalized/not capitalized, and that the terms are not defined. CenturyLink agreed to search the Tech Pub, review the use of the terms for consistency, determine whether they should be capitalized or not, and make the appropriate updates.

Again in Section 1.6.1 related to Chapter 1, Footnote 21, Bonnie Johnson – Integra questioned the paragraph related to the terms NC and NCI and the insertion by CenturyLink of the sentence “The following information regarding NCI codes is specific to xDSL Capable Loops as they relate to the xDSL Services Amendment.” (4/2/12 Updates received from Integra in CAPS) BONNIE ASKED IF CL INTENDED THAT WHAT WAS FOLLOWING THAT SENTENCE WAS ONLY MEANT FOR THOSE THAT SIGNED THE AMENDMENT.

(4/2/12 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA CenturyLink SAID NO AND agreed to remove the sentence.

Bonnie Johnson – Integra said (4/2/12 Updates received from Integra in CAPS)THAT ALTHOUGH CL SAID IT WOULD NOT DISCUSS THE THINGS IT IDENTIFIED AS IN THE MN 1006 CASE, in regard to the Definitions included in Section 1.6.1 being specific to the xDSL Services Amendment, Integra does not understand why CenturyLink will not include the definition of “conditioning” from the Amendment.

Bonnie Johnson – Integra said in regard to Chapter 1, Footnote 10 and 11, Integra objects to the wording related to Spectrum Management being included in this section.

Jeff Farra – CenturyLink said that the Spectrum Management language was in the Tech Pub from before and was not part of the discussion.

Jeff Farra – CenturyLink said that Chapter 1, Footnote 12-15, relates to the term “copper” replacing the term “metallic” that occurred throughout all Tech Pub Chapters. Jeff said that CenturyLink was aligning with the Amendment which uses the term copper.

Bonnie Johnson – Integra asked if CenturyLink considers copper to be metallic.

Jamal Boudhaouia – CenturyLink said CenturyLink would again review the use of the terms metallic and copper and the loop vs. channel vs. line to insure the terms accurately represent loop makeup. Jamal said that copper is part of the metallic family and that from the loop perspective, there is only copper or fiber.

Jeff Farra – CenturyLink said where it used to be metallic there was no change of intent: metallic was not referring to fiber.

It was agreed in regard to the Reason for Reissue that once the Tech Pub changes are agreed to and finalized, then CenturyLink will go back and update the reason for the change. Back to Chapter 1, Footnote 21, there was again discussion around the second sentence added by CenturyLink.

Kim Isaacs – Integra identified that the wording associated with NC/NCI applies to everyone and questioned why the sentence was added.

Mike McCarthy – MN DOC stated that the added CenturyLink wording implies that the xDSL Services Amendment alters the application of NC/NCI codes.

Jamal Boudhaouia – CenturyLink (4/2/12 Updates received from Integra in CAPS) SAID YOU ARE RIGHT AND agreed it should not alter the definition. Jamal proposed that we take the paragraph out and only show the definitions in Chapter 8.

Bonnie Johnson – Integra said Integra would not agree to that since the definitions are different and the definition in 1.6.1 is from the Amendment. The Integra proposal is to remove the second sentence inserted by CenturyLink.

CenturyLink agreed to remove the sentence in question. Bonnie Johnson – Integra asked if CenturyLink assigned the best available loop even if a customer has not signed the Amendment.

Jamal Boudhaouia – CenturyLink said yes, there is an algorithm that applies the best available loop based on the NC/NCI code.

Bonnie Johnson – Integra (4/2/12 Updates received from Integra in CAPS) SAID SO [delete ASKED IF] CenturyLink had denied their CR but did it anyway.

Jamal Boudhaouia – CenturyLink said no comment.

Bonnie Johnson – Integra said that for Chapter 1, Footnote 30, the last sentence in the paragraph that CenturyLink added is already addressed. Bonnie said CenturyLink can either add the “including” back in or suggest other language.

Kim Isaacs – Integra identified that Chapter 6.1 already includes the language regarding additional (4/2/12 Updates received from Integra in CAPS) TESTING.

Bonnie Johnson – Integra suggested deleting the last sentence and adding “additional testing” following “Furthermore” in the prior sentence.

Jamal Boudhaouia – CenturyLink suggested adding wording from Chapter 6 on page 6-3 that includes the specific testing process that is in place instead of the last sentence to that paragraph.

Doug Denney – Integra identified that the approach may not make sense in Chapter 1.

Jamal Boudhaouia – CenturyLink said it is best not to have a variation in the tests that are performed but to have a uniform test process for the technicians; the tests are not limited to the CLECs that have signed the Amendment. Jamal described the process where the Service Manager tracks the additional tests that are performed and stated that if it is determined that the additional tests will benefit all customers then the tests will be added to the current process.

Bonnie Johnson – Integra (4/2/12 Updates received from Integra in CAPS) [delete QUESTIONED WHETHER OR NOT] ASKED IF the standard tests [delete WILL BE] WERE changed [delete AND] would the Tech Pub also be changed.

There were several suggestions as to how to address the additional tests however it was eventually agreed that CenturyLink would consider the language originally suggested by Integra which was to add “additional testing” following “Furthermore” in the prior sentence and that the last sentence in that paragraph be deleted.

Kim Isaacs – Integra suggested that following what was agreed to in Chapter 2, Footnote 21, that the words “but not limited to” be added to the paragraph in Section 2.3 that starts “Characteristics associated…” Kim said what is included is not consistent with the definitions.

Jamal Boudhaouia – CenturyLink suggested an alternative which is to end the sentence after the reference to Section 1.6.1.

It was agreed to go with that approach and also remove all of the bullets that follow.

Jeff Farra – CenturyLink relayed that in Chapter 3, following Footnote 7, that CenturyLink had replaced the reference to Telcordia with a reference to the ANSI standard since the Telcordia reference was no longer current.

Bonnie Johnson – Integra said Integra would look at the ANSI standard reference and identify any concerns.

Bonnie Johnson – Integra questioned why the words “entirety of the” had been added in the first paragraph following Section 3.1.1.

Jamal Boudhaouia – CenturyLink responded that CenturyLink wanted to be clear.

Mike McCarthy – MN DOC stated he was not opposed to the addition.

Bonnie Johnson – Integra suggested they were not opposed to CenturyLink stating that they would use the entire NC and NCI code and it was determined that CenturyLink would change it to “entirety of both the ..”

Mike McCarthy – MN DOC asked what “take into account” means.

Jamal Boudhaouia – CenturyLink responded that when assigning the loop characteristics, there are a number of different parameters that must be considered.

Mike McCarthy – MN DOC asked whether the phrase “apply to effect” could replace “take into account”.

Jamal Boudhaouia – CenturyLink said he was not sure of that meaning.

Mike McCarthy – MN DOC said in the last part of document but mainly in Chapter 6, the NC/NCI wording was struck and now refers to Section 3.1.1.

Jamal Boudhaouia – CenturyLink said CenturyLink is looking at the NC/NCI codes specifically from an engineering perspective in the Tech Pub.

Mike McCarthy - MN DOC said he will tentatively yield to this wording but may reopen it later based on (4/2/12 Updates received from Integra in CAPS) CONSEQUENCES OF THE Spectrum Management discussion.

Bonnie Johnson – Integra said in this same paragraph in 3.1.1, it needs to be tied to the Embedded base or it does not make sense. Bonnie agreed to send an email with language she would propose.

Bonnie Johnson – Integra said the wording in Section 3.4.3 under Table 3-4 needs correction from “NCIs” to “NCI codes”.

Jamal Boudhaouia – CenturyLink agreed.

Kim Isaacs – Integra identified that around Chapter 3, Row 28, CenturyLink begins to vary on the use of the term channel vs. loop.

Bonnie Johnson – Integra identified that in Chapter 5.3, that CenturyLink had appended the sentence “They terminate using digital interfaces.” to the prior paragraph and felt it was incorrect.

Jeff Farra – CenturyLink agreed.

Mike McCarthy - MN DOC questioned several lines being deleted at the end of page 6 -1 and also at the beginning of page 6-2.

Susan Lorence – CenturyLink said the wording beginning with “Qwest reserves the right…” was deleted back on 11-3-2011. The next paragraph was deleted on 10-28-11 with the December 2011 updates. Susan said the changes are referenced in the CenturyLink matrix dated 12-7-11.

Mike McCarthy - MN DOC asked if any CLEC recalled why this occurred.

Susan Lorence – CenturyLink referred Mike to the 12-7-11 CenturyLink Matrix, Row 20, Section 6.1 and said the deletion was at CLEC request and CenturyLink had agreed to it.

Kim Isaacs – Integra brought up a question regarding a cross reference to Section 1.6.1 and mentioned that some of the info is not there, e.g., load coils. Kim said with the conditioning paragraph mentioning load coils, she was ok with no update.

Bonnie Johnson – Integra said she did not have any updates to Chapter 8 under Definitions. She said she did not like the xDSL services listed alphabetically vs. grouping them together.

Susan Lorence – CenturyLink said they had been placed alphabetically at CLEC request. Other options were discussed but it was identified they are listed out on page 8.4.

Bonnie Johnson – Integra said she could live with the display.

Mark Coyne – CenturyLink said he wanted to acknowledge all of the work that had gone into reviewing the Tech Pub for updates. Mark said he is aware that there are still open points based on Minnesota but would like to suggest that CenturyLink move forward with the Level 3 notifications to get the changes that have been agreed upon to date implemented. This would allow a clean copy to move forward.

Bonnie Johnson – Integra said she has concerns about the Level 3 notice and that CenturyLink needed to respond to the follow-up points first. Bonnie said she then wanted another review to insure Integra agreed to them first.

Mark Coyne – CenturyLink said there were not many take backs and said he thought CenturyLink would agree to the changes that had been discussed today. Mark said that we could allow the review prior to issuing the level 3 notice.

Kim Isaacs – Integra asked what happens with Spectrum Management and the conditioning language.

Mark Coyne – CenturyLink said that language would stay as it is but that it was not in a final state.

Bonnie Johnson – Integra said there could be updates on either side from what occurs in Minnesota. She said if CenturyLink is (4/2/12 Updates received from Integra in CAPS) [delete HOLDING ON] PUNTING some of the updates pending the results in Minnesota, then CenturyLink will have to wait to finalize the Tech Pub. Bonnie said what is agreed to now may not be agreeable later. She said she is fine to identify where the document is to date but will not make them final until Spectrum Management and Conditioning are included.

Mike McCarthy - MN DOC said when the settlement occurred in 2010, the CLEC benefit was to get a fully applied NCI code and it would apply to Spectrum Management. CenturyLink would benefit from the “remove all” and an associated rate increase. Mike said we are left today with the two issues of Spectrum Management and conditioning which was the original purpose.

Mark Coyne – CenturyLink said he agrees there could be changes on both sides depending on the Minnesota outcome but does not want to rehash wording but wanted to work from a clean copy.

Bonnie Johnson – Integra said she is OK to (4/2/12 Updates received from Integra in CAPS) WORK COLLABORATIVELY TO DETERMINE WHERE WE ARE NOW [delete DO THAT] but not via a level 3 notice AND MAKE THE CHANGES FINAL. Bonnie said they are not willing to piecemeal it.

Mark Coyne – CenturyLink said CenturyLink needs to create a clean version and then determine next steps with the SME and legal.

Al Finnell - Windstream said he agreed with Integra.

Mark Coyne – CenturyLink asked if it was worthwhile to develop a clean copy.

Bonnie Johnson – Integra said that was fine but that the current updates and the Minnesota related updates needed to be made together.

Mark Coyne – CenturyLink said everyone understood there will be additional changes and the document would not be final.

Bonnie Johnson – Integra said she would not agree to any notification but will continue to work with CenturyLink.

Mark Coyne – CenturyLink said there are a number of groups that have input on the CenturyLink direction but that we will work toward creating clean documents and determining next steps.

Mike McCarthy - MN DOC said that it is CenturyLink that is deferring on these issues pending resolution in Minnesota and that these are not new issues but were initially discussed last April and May. Mike said there is apparently no rush within CenturyLink to move forward on these two issues that have been open 17 months.

Al Finnell - Windstream asked if the deferred issues only apply in Minnesota.

Mark Coyne – CenturyLink said that is true but that they could impact other states.

Al Finnell - Windstream asked what happens to other states.

Susan Lorence – CenturyLink said that is why we want to move forward. There have been no Tech Pub updates yet and we want something in production that reflects the Amendment.

Jamal Boudhaouia – CenturyLink said the majority of the Tech Pub updates have been in practice since January 15, 2011. Jamal said 99% of the processes are in place today to provision, maintain and operate the network. The issues that remain are the definition of Conditioning and Spectrum Management.

Bonnie Johnson – Integra said those two issues are a huge part of the Amendment.

Jamal Boudhaouia – CenturyLink said the Amendment has much more than that. Jamal said we deliver the best loop, maintain it and apply standards as required.

Bonnie Johnson – Integra said if that is the case, why not include the definitions.

Jamal Boudhaouia – CenturyLink said he is not a lawyer and cannot answer that.

Mark Coyne – CenturyLink asked whether having the definition would change the process.

Bonnie Johnson – Integra said that is the problem and that she will not agree to publish until Minnesota is resolved but will work with CenturyLink to get a clean copy.

Mark Coyne – CenturyLink said CenturyLink wants to get on record that we disagree on the impact of the open points.

Bonnie Johnson – Integra said that the impact is unknown.

Jamal Boudhaouia – CenturyLink said that we agree to disagree.

The (4/2/12 Updates received from Integra in CAPS) [delete MARCH 2012 CMP MEETING AND ]discussion of Technical Publication 77834 adjourned at 4:30 PM MT.

FROM SYSTEM MEETING MINUTES - after Attachment N The March CMP Systems Meeting was followed by a discussion of Technical Publication 77384.

CENTURYLINK NOTE: AT THE REQUEST OF INTEGRA, THE DISCUSSION OF THE TECH PUB 77384 WAS MOVED TO THE PRODUCT PROCESS MEETING MINUTES. THE DISCUSSION IS INCLUDED UNDER ATTACHMENT D OF THE PRODUCT PROCESS MEETING MINUTES ASSOCIATED WITH CR PC072010-1ES.

2/15/12 Product Process Monthly Meeting Mark Coyne – CenturyLink stated that in the January monthly meeting, CenturyLink said that a review of the Technical Publication matrix and chapters that had been distributed on 12-7-11 would be addressed in the February monthly meeting. Due to CLEC comments received on 01-24-2012, 01-30-2012 and 02-02-2012, CenturyLink needed additional time to address those issues and subsequently sent a notification on 2-8-12 stating that the issues would be addressed in the March face-to-face meeting. Mark said the CLEC comments had been posted to the calendar for March and stated that the updated CenturyLink matrix would be made available to the CLECs prior to the March meeting.

Bonnie Johnson – Integra asked if CenturyLink would respond to the matrix before the March meeting.

Mark Coyne – CenturyLink responded that the CenturyLink response would be included in the March package.

Bonnie Johnson – Integra asked if the response was available sooner, could it be distributed sooner to allow CLECs time to review. Bonnie said having the responses sooner would allow for all participants to have a more meaningful discussion in March.

Mark Coyne – CenturyLink stated that the SME team is currently reviewing the CLEC comments and if the response was available sooner, CenturyLink would distribute it. Mark said CenturyLink would try to distribute the CenturyLink response by 3-12-12.

Bonnie Johnson – Integra asked if CenturyLink would notify them when it was made available.

Susan Lorence – CenturyLink stated that a notice to the full CLEC community would be distributed so that everyone was aware of the availability of the CenturyLink response to the matrix. She also clarified that the March Face to Face meeting discussion would only be in regard to the Technical Publication 77384 matrix and chapters.

Mark Coyne – CenturyLink said the March review would be similar to what occurred in October for the PCAT.

Bonnie Johnson – Integra said that it was (02/22/12 Updates received from Integra in CAPS) REALLY important to get the CenturyLink updates sooner than later.

Al Finnell – Windstream stated that he echoed Integra’s request to receive the CenturyLink response as soon as possible and inquired how long the March Face to Face meeting would last.

Mark Coyne – CenturyLink stated that the Denver March meeting was scheduled until 5:00 PM MT and he suggested planning for at least until 4:00 PM MT.

1/18/12 Product Process Monthly Meeting Mark Coyne – CenturyLink recapped that a notice was distributed on December 7, 2011 that provided some additional updates to the Tech Pub chapters. Mark said that during recent meetings, it was to be determined when the Tech Pub matrix was to be reviewed. Mark asked if there was any objection to reviewing the Tech Pub matrix in February.

Kim Isaacs – Integra relayed that their intent was to provide an Integra response in January and that, barring any problems, the February meeting would be a good time to review the matrix.

Julia Redman-Carter – Windstream said her company was in a transition period but that she would shoot for February. If she was not able to be prepared for the February meeting, Julia said she would identify that in writing one week before the February meeting.

Mark Coyne – CenturyLink said at this point we would plan to review the Tech Pub matrix in the February meeting. Mark also relayed that on December 29, CenturyLink had sent a notice that included an update on the Conditioning matrix to provide an additional response to # 17 on modifying the PCAT definition of conditioning. The updated document is posted to the Customer Notice Letter Archive (CNLA). On January 6, Integra had provided a response associated with Item 8 on the PCAT matrix which was posted to the CMP calendar. Mark asked if there were any questions; there were none.

12/14/11 Product Process Monthly Meeting Mark Coyne – CenturyLink recapped the Change Request and said that after a discussion in the November meeting regarding the removal of instances of “Unbundled” and “Interconnection”, the matrix with updated comments and a redline of the Technical Publication went out with a notice on December 7, 2011. Mark said that a discussion was to be held in either January or February 2012 and asked if there was consensus as to when this could occur.

Bonnie Johnson – Integra stated that since the documents were just received, they did not know the scope of what their response (12/27/11 Updates received from Integra in CAPS) WOULD HAVE TO BE and with the holidays and the hearings in Colorado or Washington THE WEEK OF CMP, January does not work.

Mark Coyne – CenturyLink said we could target February and then revisit the issue in the January meeting.

Bonnie Johnson – Integra stated that (12/27/11 Updates received from Integra in CAPS) they [delete WOULD] SHOULD have an idea of the scope by then and said others may have questions today.

Mark Coyne – CenturyLink asked if there were other questions.

Julia Redman-Carter – Windstream stated she would need to at least February as well with their transitions and the holidays.

11/16/11 Product Process Monthly Meeting Mark Coyne – CenturyLink stated that the download matrix for the Technical Publication matrix was sent out on November 9th and that other related documents were also posted. He said in the October meeting, there was discussion on whether to discuss the Tech Pub matrix in January or February 2012. He asked if there were any preferences as to when to meet.

Bonnie Johnson – Integra stated that from what she could tell, she thought that there (11/28/11 Updates received from Integra in CAPS) WOULD be SOME movement on CenturyLink’s part, but it appears CenturyLink simply restated its position. She said she thought Integra would be responding sooner but due to the upcoming holidays, it was hard to say. She said January could be targeted, but that she could not commit to an absolute date.

Mark Coyne – CenturyLink asked what others thought, in particular, PAETEC.

Julia Redman-Carter – PAETEC agreed they would try for January meeting but could not promise.

Mark Coyne – CenturyLink offered to touch base in the December meeting to see if January or February would be best.

Bonnie Johnson – Integra said that would work but that there were unexplained changes made to the Technical Publication and had sent an email requesting information on that.

Mark Coyne – CenturyLink stated that CenturyLink had received an email from Integra that questioned why we had removed the terms “unbundled” and “interconnection” in the Technical Publication. Mark said the Integra email had been posted to the calendar for the CMP meeting and asked if Bonnie wanted to clarify the question. Bonnie Johnson – Integra stated that the email was fairly self-explanatory. She said nothing in the matrix explained the reason for the change.

Jamal Boudhaouia – CenturyLink asked Bonnie to restate the question again before he responded.

Bonnie Johnson – Integra stated CenturyLink had struck “unbundled” and “interconnection” in some places in the Tech Pub and it was unclear why.

Jamal Boudhaouia – CenturyLink responded that the Technical Publication encompasses multiple services and network elements and that when CenturyLink reviewed the document, some sections were defining a finished service (11/28/11 Updates received from Integra in CAPS) SUCH AS DS1 AND ISDN and some were defining a loop. Jamal said generally, a loop is not for interconnection which implies an exchange of traffic. Anywhere CenturyLink felt that the loop was not specific to interconnection or where it was defining a finished service, those words were removed. He also mentioned that some instances may have been missed AND HE DID NOT MAKE 100% OF THE CHANGES, but that was the concept behind the changes.

Bonnie Johnson – Integra asked if that explanation could be provided in an email

Mark Coyne –CenturyLink said yes but what about including it in the meeting minutes.

Bonnie Johnson – Integra said she preferred an email to get it sooner.

Mike McCarthy – MN Department of Commerce (11/28/11 Updates received from Integra in CAPS) SAID IT SOUNDS LIKE JAMAL IS THE RIGHT PERSON AND asked for clarification and referred to page 1-5 and brought up new edits to a previous edit in July. The Qwest responsibilities USED TO SAY BASED ON THE NC/NCI CODE [delete HAD INCLUDED REFERENCE TO THE NC/NCI CODES IN AN EARLIER UPDATE], but had been updated now to refer to Section 1.6.2 instead which included the “old fuzzy language” that stated that Qwest would “take this into account”. He asked if we had completed a cycle back to the spring of 2011 about the use of the NC/NCI codes WHICH SHOULD RELIABLY TRANSMIT A SIGNAL FOR XDSL SERVICE AND A PERSON MIGHT CONSTRUE THAT TO MEAN WE ARE WHERE WE WERE LAST SPRING.

Jamal Boudhaouia – CenturyLink said it did not make sense.

Mike McCarthy – MN Department of Commerce stated he wanted to understand if this was just an error in editing.

Jamal Boudhaouia – CenturyLink stated that it would be readdressed.

Julia Redman-Carter – PAETEC requested to be copied on the response and asked if they had questions, where should they be sent.

Mark Coyne – CenturyLink said to send them to the CMPCR mailbox.

Liz Tierney – Covad (now Megapath) asked that by removing the language, (11/28/11 Updates received from Integra in CAPS) IT WAS NOT MOVE RESTRICTIVE AND did the document cover more than just the unbundled product.

Jamal Boudhaouia – CenturyLink said yes the Tech Pub does not restrict the product at all.

Julia Redman-Carter – PAETEC asked that if it wasn’t restricting it, would customers have to go to a different Technical Publication for unbundled loops?

Jamal Boudhaouia – CenturyLink stated that unbundled loops would be sections of the Tech Pub and some sections would not be unbundled (11/28/11 Updates received from Integra in CAPS) LIKE DS1 AND ISDN.

Julia Redman-Carter – PAETEC asked for clarification with “interconnection”.

Jamal Boudhaouia – CenturyLink said interconnection is to connect two networks together. An unbundled loop is not used for interconnection. The term “interconnection” has the connotation that a loop would be used to exchange traffic with CenturyLink and in the loop environment, there’s no exchange of traffic. A loop is delivered in a collocation.

Julia Redman-Carter – PAETEC stated that she understood but was concerned about being able to have a product delivered over the loop. She didn’t want to limit a certain product from being sent through the network.

Jamal Boudhaouia – CenturyLink stated that under the context of 251, CenturyLink delivers the loop based on the NC/NCI codes and what the CLEC does with it is up to them, assuming that the signal is compliant. The CLEC is free to do what they wish with it once the circuit is delivered. CenturyLink does not see the signal and has no way to verify what is being transmitted (11/28/11 Updates received from Integra in CAPS) AND WE WOULD NOT KNOW WHAT THE IP PACKETS WERE.

Mike McCarthy – MN Department of Commerce asked if in terms of Spectrum Management, does that mean that CenturyLink will have (11/28/11 Updates received from Integra in CAPS) UNEXPECTED mysterious impacts on its system due to the traffic sent by CLECs.

(11/28/11 Updates received from Integra in CAPS) [delete JAMAL BOUDHAOUIA – CENTURYLINK STATED THAT WE WOULD NOT KNOW WHAT THE IP PACKETS WERE.]

Julia Redman-Carter – PAETEC stated her ICA allows for enough power to be able to send the signal to their customer and that she wanted to make sure that removing “interconnection” did not impact the Spectrum Management range for these products.

Jamal Boudhaouia – CenturyLink said we are talking about the context of 251. From a loop perspective, CenturyLink is not interconnecting with the CLEC. If there was interconnection with CenturyLink, we would have to agree on protocols to accept between the two networks.

Julia Redman-Carter asked that this be clarified in the response.

Bonnie Johnson – Integra said she knows her ICA and DS1 and ISDN services are unbundled and that Integra will object to the change. Whether or not CenturyLink considers it finished services, they are still unbundled loops in her ICA.

Julia Redman-Carter – PAETEC said she has the same concern but would wait to see it in writing.

Jamal Boudhaouia – CenturyLink clarified that he believed that Bonnie was talking about the definition of a loop.

Julia Redman-Carter – PAETEC stated that she understood the concept of the changes and that when she looks at the document, she understands it is from an engineering perspective. By leaving the terms in, it would help clarify points rather than pulling them out for an interpretation issue. Julia said it seems like CenturyLink is setting itself up for a legal argument based on interpretation. She would like to see the response in writing and how these changes do not impact Spectrum Management.

Jamal Boudhaouia – CenturyLink said based on what Julia said, regarding engineering terms and design, perhaps nothing should be included regarding interconnection, but rather pure network facility information. Engineering and technicians only deal with the network. Jamal said he was not advocating it, but if we were to go purely engineering terms then the network should only be defined as network, no interconnect or unbundled, just a facility.

Bonnie Johnson – Integra replied that whether or not Integra would agree to the changes, she has a real concern about Jamal stating that CenturyLink may not have captured all of the changes. She will look at the CenturyLink response but did not think Integra would be agreeable to removing any of them.

Jamal Boudhaouia – CenturyLink said he would like an explanation of why “interconnection” should be kept.

Mike McCarthy – MN Department of Commerce said there is an open docket in Minnesota about what is an unbundled element in regard to copper loops used for xDSL services. Mike said the watershed disagreement appears to be the (11/28/11 Updates received from Integra in CAPS) SHAPING UP ON THE difference between what is a finished service versus what is an unbundled copper loop. Mike said there is sensitivity on this and said it appears CenturyLink is redefining the product in the Tech Pub which is the [delete BASIS FOR THE CENTURYLINK AND CLEC DISAGREEMENT] LITERALLY THE NUB OF THAT DOCKET.

Jamal Boudhaouia – CenturyLink (11/28/11 Updates received from Integra in CAPS) SAID OH REALLY AND thanked Mike for his comments.

Kim Isaacs – Integra asked for clarification regarding reference to finished services. Kim said the changes made to the Tech Pub are not to DS1 and ISDN products, but rather to the xDSL loop and asked if it was the intent to change the definition of the xDSL product.

Jamal Boudhaouia – CenturyLink replied that unbundled xDSL is a dry copper wire.

Kim Isaacs – Integra replied that it was conditioned to provide the broadband services based on the NC/NCI codes.

Jamal Boudhaouia – CenturyLink confirmed that when conditioning was requested, CenturyLink would condition to transmit reliably the service ordered.

Kim Isaacs – Integra asked (11/28/11 Updates received from Integra in CAPS) FOR JAMAL TO TELL HER the difference between an unbundled xDSL Capable Loop and an xDSL Capable Loop.

Jamal Boudhaouia – CenturyLink stated that a loop was a loop; there was no difference from an engineering perspective. A dry copper loop is an unbundled loop.

Kim Isaacs – Integra asked why take out “unbundled”.

Jamal Boudhaouia – CenturyLink replied that he needed to look at what happened during the last weeks of revisions. In the multiple re-workings of the Tech Pub chapters, Jamal said there could have been instances where words were (11/28/11 Updates received from Integra in CAPS) INADVERTENTLY [delete INCORRECTLY] removed and he would clean it up.

Kim Isaacs – Integra stated that CenturyLink inserted “unbundled” in Chapter 5 and is taking it out in Chapter 3. Kim said it seems CenturyLink is trying to tell CLECs something.

Jamal Boudhaouia- CenturyLink said there was no intent but that we were trying to clean it up.

Mark Coyne – CenturyLink stated that we would respond to the email questions and that SMEs would make sure the documents were consistent.

Jamal Boudhaouia – CenturyLink stated that was correct.

Julia Redman-Carter asked that if corrections are made, to please send a notice since it would impact their response. Susan Lorence – CenturyLink said if changes are made, CenturyLink would send another Change Management notice with all of the documents.

Julia Redman-Carter said that was fine as long as the changes are specifically identified.

Mark Coyne – CenturyLink asked if there were any other comments. There were none. Mark said there was an action item from the October meeting regarding issuing a Change Request for conditioning during repair and an email exchange with Integra is posted to the CMP calendar. Mark said that CenturyLink has determined that there are some basic differences between the installation and repair processes and the efficiencies may not be that great on the CenturyLink side. Mark said the CLECs should issue the CR to express the benefit from their perspective.

Bonnie Johnson – Integra stated that Integra disagrees and that the Amendment is clear it should be done and that CenturyLink should be doing it. Bonnie said (11/28/11 Updates received from Integra in CAPS) IT IS NOT THEIR JOB TO CORRECT IT if a process was implemented that was contrary to the Amendment they should not have to submit a CR but will do so with their objection identified.

Mark Coyne – CenturyLink acknowledged their position.

Julia Redman-Carter – PAETEC stated that they were in agreement with Integra.

10/19/11 Product Process Monthly Meeting Mark Coyne – CenturyLink said he indicated in the last meeting that CenturyLink was working on the responses to CLEC concerns. The Conditioning matrix, PCAT and download are in the package with the CenturyLink response. Mark said CLECs had not had a lot of time to review the documents since last Friday; they were also sent out in Word the day before. Mark said he thought we have agreement on 90-95% of the matrix regarding language and that he would like to have Bob Mohr review the matrix and cover the issues that CenturyLink is in agreement with CLECs. He said there is still disagreement on a couple issues which will need discussion but due to sensitivity, those should be handled in writing vs. in the meeting. Mark proposed keeping the discussion to the first column and last two columns of the matrix.

Bob Mohr – CenturyLink addressed each issue in numerical order as included in the distribution package and CenturyLink’s actions in response to CLEC’s requests.

(10/28/11 Updates received from Integra in CAPS)BOB MOHR – CENTURY LINK STATED FOR ISSUE #1 CENTURYLINK ACCEPTED LANGUAGE AND PUT IT IN THE PCAT. ISSUE #2 CENTURYLINK ACCEPTED LANGUAGE AND ADDED AS RED-LINE TO THE CONDITIONING DOWNLOAD. ISSUE #3 CENTURYLINK UPDATED THE CONDITIONING DOWNLOAD ISSUE #4 CENTURYLINK CHANGED “WILL” TO “MAY” IN THE PCAT ISSUE #5 CENTURYLINK IMPLEMENTED SCA OPTION 3 (CONDITIONING AND/OR REMOVE ALL CONDITIONING) ON 10/17/11 IN IMA RELEASE 31.0 ISSUE #6 CENTURYLINK WILL MAKE THE CHANGES IN THE 10/31/11 ADDENDUM TO IMA RELEASE 31.0

Bonnie Johnson – Integra asked a question about line item #8 and CenturyLink’s determination that no changes were necessary in the process for requesting conditioning during repair. Bonnie asked if CenturyLink thinks this is something that CLECs can already do.

Bob Mohr –CenturyLink replied no, it is either or.

Bonnie Johnson – Integra stated that it doesn’t benefit either company or the end user to submit a repair ticket, dispatch the technician, determine that more conditioning is required, have the CLEC submit another ticket and dispatch the tech again. She said it is not logical and delays customer repair and asked how we get around this.

Bob Mohr – CenturyLink replied that he understood and that the issue had been discussed internally. Bob said if CenturyLink received a Change Request, it would be investigated.

Bonnie Johnson – Integra asked what that meant and said she felt that CenturyLink had already made a decision on this issue (10/28/11 Updates received from Integra in CAPS)AND WOULD DENY A CR.

Bob Mohr – CenturyLink replied that no decision had been made and that it would be investigated if a CR was received.

Bonnie Johnson – Integra stated that this is basically the same process as Installation and that the same technicians were doing the work. She stated that the Amendment allows CenturyLink to charge in the same manner.

Bob Mohr – CenturyLink asked if there was a concern issuing a CR? Bonnie Johnson – Integra stated that often they are told to submit a CR when it is not needed. She referred to the CMP document and a related document that describes the roles and responsibilities of the Service Manager. She said if there was an issue, the Service Manager was to submit a CR.

Liz Tierney – Covad asked if it was true CenturyLink would dispatch twice.

Mark Coyne – CenturyLink said yes and asked if Integra had taken this to their Service Manager.

Bonnie Johnson – Integra said they do not think a CR is required (10/28/11 Updates received from Integra in CAPS) AND THE AMENDMENT IS SUFFICIENT. If she agreed to submit a CR, they would want it expedited and that it would be submitted with objections.

Bob Mohr – CenturyLink stated that the process for repair is set up is an “either or” and that it would be a process change.

(10/28/11 Updates received from Integra in CAPS) MARK COYNE – CENTURYLINK STATED THIS IS FEASIBLE BUT YOU NEED A CHANGE REQUEST?

(10/28/11 Updates received from Integra in CAPS) BOB MOHR – CENTURYLINK SAID YES.

Julia Redman-Carter – PAETEC asked for clarification as to how CenturyLink handled its own customers. Does CenturyLink dispatch out twice and bill two dispatches.

Jamal Boudhaouia – CenturyLink said he does not believe CenturyLink does “remove all” for CenturyLink customers.

Bonnie Johnson – Integra said she knows it is feasible since it is done on installation (10/28/11 Updates received from Integra in CAPS) AND IN THE SPIRIT OF THE AMENDMENT THIS SHOULD APPLY TO REPAIR AS WELL.

Mark Coyne – CenturyLink said we would take this off line to work with Service Management to determine how a CR would be submitted and to decide if CenturyLink would need to come back to Integra to submit one.

Bob Mohr – CenturyLink continued reviewing the matrix (10/28/11 Updates received from Integra in CAPS) ISSUE #9 CENTURYLINK WILL USE THE “INF” CODE FOR TICKET CLOSURE. CENTURYLINK WILL BE EXPANDING THE INF DEFINITION TO INCLUDE CONDITIONING ON REPAIR UNDER THE XDSL AMENDMENT.

(10/28/11 Updates received from Integra in CAPS) SUSAN LORENCE – CENTURYLINK – STATED THE NOTICE WOULD BE SENT OUT AS A LEVEL 2 NOTICE

(10/28/11 Updates received from Integra in CAPS) BOB MOHR – CENTURYLINK INDICATED THAT THE NOTICE WOULD BE GOING OUT IN THE NEXT COUPLE OF DAYS. BOB MOHR CONTINUED TO REVIEW THE MATRIX. ISSUE #10 LANGUAGE HAS BEEN ADDED. ISSUE #11 LANGUAGE HAS BEEN INSERTED IN THE CONDITIONING DOWNLOAD PAGE 6, ISSUE #12 LANGUAGE HAS BEEN ADDED AS PROPOSED. ISSUE #13 DELETED LANGUAGE HAS BEEN REMOVED. ISSUE #14 FOR THE K JEP VERSUS C JEP ISSUE. CENTURYLINK IS PROPOSING TO IMPLEMENT A NEW JEP COD. IN THE INTERIM CENTURYLINK WILL IDENTIFY AN EXISTING CODES THAT DOES NOT ASSIGN THE JEP TO CLEC’S RESPONSIBILITY. ISSUE #15 INSERTED LANGUAGE ON PAGE 8. ISSUE #16 INSERTED LANGUAGE ON PAGE 8. In regard to line item 17, Bob stated that was being deferred.

(10/28/11 Updates received from Integra in CAPS) BONNIE JOHNSON – INTEGRA SAID ARE WE GOING TO ADDRESS THE ELEPHANT IN THE ROOM.

Mark Coyne – CenturyLink clarified that with line item 17 (definition of Conditioning), it is one of the sensitive issues that would have to be addressed by the stakeholders on the CenturyLink side.

(10/28/11 Updates received from Integra in CAPS) BONNIE JOHNSON – INTEGRA STATED WE HAVE MADE OUR POSITION CLEAR THERE IS AN FCC DEFINITION OF CONDITIONING AND THAT DEFINITION SHOULD BE USED.

(10/28/11 Updates received from Integra in CAPS) MARK COYNE – CENTURYLINK STATED THIS IS AN ISSUE THAT WILL NEED WRITTEN RESPONSES. MARK [delete HE]e stated that a lot of progress had been made and that much of the agreed upon language could move forward and be added to the documentation. He asked if there was an opinion as to how much time would be needed to review the matrix and respond if there were any other concerns.

Kim Isaacs – Integra questioned the matrix on Technical Publication 77384.

Mark Coyne – CenturyLink agreed that it was a separate matrix and that it was quite long and detailed and would be handled separately from the matrix which was just reviewed. Mark said we planned on sharing the approach for the Technical Publication matrix in the November meeting.

Mike McCarthy – Minnesota Department of Commerce said that since the matrix discussed today cross references Technical Publication 77384, would it be wise to review them side-by-side before they were wrapped up.

Mark Coyne – CenturyLink said he was premature in saying the PCAT updates could be sent out. He said we would wait to submit the changes just discussed until the Tech Pub matrix was reviewed. Bonnie Johnson – Integra stated that she thought Mike was indicating that the PCAT changes related to the Tech Pub and that the PCAT changes should wait until the Tech Pub matrix was reviewed.

Mike McCarthy – Minnesota Department of Commerce said he needed to digest the content that was just reviewed and that the deferred item #17 Conditioning was a cross-over and that it was not known the standard of conditioning that would be used.

(10/28/11 Updates received from Integra in CAPS) BOB MOHR – CENTURYLINK STATED THEY WERE MOVING FORWARD WITH PROCESS CHANGES

Julia Redman-Carter – PAETEC stated that she was not necessarily agreeing with everything that had been (10/28/11 Updates received from PAETEC in CAPS) REVIEWED [delete DISCUSSED] on the xDSL Conditioning Matrix JULIA STATED THAT SHE DID NOT WANT HER SILENCE TO CONSTRUED AS AGREEMENT until resolutions IS MET ON THE XDSL were agreed upon in regard to the Tech Pub matrix and reserved the right to re-address issues WITH XDSL MATRIX AND PCAT during AND delete [OR] after the Technical Publication issues were discussed.

(10/28/11 Updates received from Integra in CAPS) MARK COYNE – CENTURYLINK SAID YOU ALWAYS HAVE THAT RIGHT. (10/28/11 Updates received from PAETEC in CAPS) MARK COYNE – CENTURYLINK SAID THAT IS ALWAYS THE CASE.

(10/28/11 Updates received from Integra in CAPS) BONNIE JOHNSON – INTEGRA SAID QWEST HAS COME BACK BEFORE AND SAID WE DID NOT ADDRESS THAT AT THE TIME OF REVIEW AND WOULD NOT ACKNOWLEDGE THE CONCERN.

(10/28/11 Updates received from PAETEC in CAPS) BONNIE JOHNSON – INTEGRA STATED THAT HASN’T ALWAYS BEEN THE CASE. PREVIOUS SITUATIONS WHEN WE HAVE ASKED TO ADDRESS AN ISSUE CENTURYLINK HAS STATED THAT THERE WERE NO OBJECTIONS BY CLEC’S SO WE THOUGHT WE REACHED AGREEMENT AND IT WAS CLOSED.

(10/28/11 Updates received from Integra in CAPS) JULIA REDMAN-CARTER – PAETEC DISCUSSED RESERVATION OF RIGHTS AGAIN.

(10/28/11 Updates received from PAETEC in CAPS) JULIA REDMAN-CARTER – JULIA REDMAN CARTER SAID, FOR THE RECORD, PAETEC RESERVES OUR RIGHT TO COMMENT ON ANY ISSUES OR ADDRESS NEW ISSUES, INCLUDING THOSE THAT HAVE BEEN CLOSED PREVIOUSLY, RELATED TO THE XDSL MATRIX, PCAT, TECHNICAL PUBLICATIONS AND ANY OTHER DOCUMENTS RELATED TO XDSL UNTIL THE TECHINICAL PULICATION OR RELATED DOCUMENTS HAVE BEEN VETTED AND AGREED UPON.

Mark Coyne – CenturyLink agreed. He asked (10/28/11 Updates received from Integra in CAPS) IF THE DECEMBER CMP MEETING WAS APPROPRIATE FOR CLECS TO WEIGH IN ON EVERYTHING [delete FOR A REASONABLE TIME FRAME TO READDRESS THE MATRIX SINCE THE TECHNICAL PUBLICATION MATRIX WOULD HAVE TO BE CONSIDERED A PART OF THE REVIEW].

Bonnie Johnson – Integra stated that since(10/28/11 Updates received from Integra in CAPS) NOVEMBER AND December would be busy, perhaps the January 18 CMP meeting would be more logical.

Julia Redman-Carter – PAETEC stated that, provided they get the Technical Publication matrix by the first of November, they (10/28/11 Updates received from Integra in CAPS) VERY TENTATIVELY may be able to provide a response by the January meeting, but it might not be feasible due to the upcoming holidays.

Julia Redman-Carter – PAETEC stated that, provided they get the Technical Publication matrix by the first of November, (10/28/11 Updates received from PAETEC in CAPS) WE MAY TENTATIVELY [delete THEY MAY] be able to provide COMMENTS TO THE XDSL MATRIX [delete A RESPONSE] by the January meeting. PAETEC IS NOT ABLE TO COMMIT TO THAT DATE BECAUSE IT’S VERY DIFFICULT TO COORDINATE SME’S. IT MAY [delete BUT IT MIGHT] not be feasible due to the upcoming holidays.

Mark Coyne – CenturyLink asked to be able to consider the January meeting as a goal and to look at the PCAT and Tech Pub updates side by side and to provide written feedback. Mark said that he did not want to hold up the(10/28/11 Updates received from Integra in BOLD or CAPS) 95 % agreed upon updates to documentation due to [delete ONE OR TWO] A FEW issues that could not be easily agreed upon. He suggested that perhaps, if CLECs and CenturyLink could not agree upon a definition of Conditioning, perhaps it would not be included at this point in time as an interim resolution.

Bonnie Johnson – Integra stated that whether the definition of Conditioning was not included, it would still need to be addressed at some point and not ignored.

Mark Coyne – CenturyLink concurred and said not having the definition does not prevent CenturyLink providing service under the amendment.

Julia Redman-Carter – PAETEC stated that she can see moving forward with (10/28/11 Updates received from PAETEC in CAPS) SOME OF the agreed upon documentation updates but reserves the right to object or re-open ANY RELATED DOCUMENTATION if there is an issue that comes up later.

(10/28/11 Updates received from Integra in CAPS) MARK COYNE – CENTURYLINK ASKED MIKE IF THEY ADDRESSED HIS CONCERNS.

(10/28/11 Updates received from PAETEC in CAPS) MARK COYNE – CENTURYLINK ASKED MIKE MCCARTHY IF WE HAD SATISFIED HIS CONCERNS.

Mike McCarthy – Minnesota Department of Commerce said his issue had been acknowledged.

9/21/11 Product Process Monthly Meeting Mark Coyne – CenturyLink said based on email exchanges, CenturyLink had agreed to extend the review period to September 1, 2011 and that CenturyLink had received CLEC comments. Mark said those comments are currently being reviewed by SMEs to identify where CenturyLink agrees and doesn’t agree so that we can determine how to move forward.

Bonnie Johnson – Integra asked when CenturyLink expected to respond.

Mark Coyne – CenturyLink replied that without talking to the SME teams, he couldn’t provide a definite answer but thought it would be a few more weeks. He said he hoped there could be a discussion in the October meeting but couldn’t promise that.

Bonnie Johnson – Integra asked if it could be made a priority to talk about it in October.

Mark Coyne – CenturyLink said it could be put at the top of the list and hopefully the discussion can occur in October.

Julia Redman-Carter – PAETEC said if possible, she would like the information in writing before the meeting to allow time for review and discussion.

Mark Coyne – CenturyLink said (9/30/11 Updates received from PAETEC in CAPS) HE UNDERSTOOD OUR CONCERN AND THAT we would not want to provide it the day of the meeting.

8/17/11 Product Process Monthly Meeting Mark Coyne – CenturyLink said this is the CR associated with the change in process for xDSL capable loops, non-loaded and ADSL compatible loops, AKA xDSL services. As identified in the July meeting, a notification was sent on 7/22/2001 that provided the CLECs with draft documents and provided the date of 8/15/2011 for responding with comments. Mark said that based on some additional emails following the call last month regarding the 8/15 date, the date was extended to 9/1. A notification was sent on 8/15 informing all CLECs that the date had been pushed out until 9/1. Mark said once we receive those comments back on 9/1, we will work with the SME team to determine next steps. Mark also said an objection from Integra had been received which has been posted to the calendar for today’s meeting.

Bonnie Johnson – Integra said last month there was a “pat plan” to move forward but now you indicate that you will look at comments to determine next steps. Bonnie asked whether CenturyLink was now considering more calls to work collaboratively to resolve differences.

Mark Coyne – CenturyLink said that he could not commit until the SME team had time to review any comments that were received. Mark said in the July meeting, we said we (8/26/11 Updates received from Integra in CAPS) COMMITTED TO REVIEW THE CLEC COMMENT BEFORE WE would determine the next steps [delete BASED ON THE CLEC COMMENTS]. He said that the plans are to move forward with the Level 3 notice, but that we will review the comments before determining next steps.

Bonnie Johnson – Integra said thank you and that their request for a collaborative effort is an ongoing request.

Mark Coyne – CenturyLink said that we have that documented and asked if there was anything else on this CR. There was none.

7/20/11 Product Process Monthly Meeting Mark Coyne –CenturyLink (7/28/11 Updates received from Integra in CAPS) (7/29/11 Updates received from PAETEC in italicized CAPS) PROVIDED AN [Deleted RELAYED THE] update TO THE CHANGE REQUEST. [Deleted AS] CenturyLink held several ad hoc calls going through and reviewing the proposed documentation updates for this CR. Most of that time was spent reviewing TECH PUB (TP) 77384 revisions. As a result of those calls and email exchanges [Deleted CENTURYLINK HAS CAPTURED IN] two matrices WERE CREATED THAT CAPTURED [TO CAPTURE] the concerns and issues the CLECs brought forward for both the TECH PUB and the conditioning download. After further CENTURYLINK review and discussion BY CENTURYLINK about those concerns CenturyLink’s next steps WILL BE [Deleted ARE] to send a response with the two matrices detailing where CenturyLink has made the necessary revisions to address the CLECs concerns. Between the two matrices over 80% [Deleted 805] of the suggested updates by the CLECs will be included. Those responses along with the matrices will be going in the next few days. Following that CenturyLink will proceed forward with updating both the TECH PUB and the conditioning download and send out A level 3 notices. The CLECs under this approach will have two opportunities to comment on the revisions. One under the email response with the matrices and two under the formal level 3 comment cycle. We will be issuing a level 3 notice for the TP and also one for the conditioning download. We will also be issuing a level 1 notice for the process option associated with escalation #47 regarding conditioning during loop delivery and acceptance as was previously suggested by CenturyLink.

Bonnie Johnson – Integra, (7/28/11 Updates received from Integra in CAPS) (7/29/11 Updates received from PAETEC in italicized CAPS) STATED IT APPEARS CENTURYLINK IS [Deleted DEEP BREATH] sending OUT THEIR [Deleted OUT YOUR] position, CHANGING THE [Deleted CHANGE] PCAT, AND STATING THAT THE collaborative process ON THE TP, DOWNLOADS, AND PCATS THAT CENTURYLINK [DELETED IS OVER THAT YOU] committed to work through IS OVER [Deleted TP, DOWNLOAD AND PCAT} and CENTURYLINK IS [Deleted YOU’RE] going to make those changes THEY WANT whether it’s 20% or 75% over CLEC objection.

Mark Coyne – CenturyLink, (7/28/11 Updates received from Integra in CAPS) STATED THERE IS still opportunities for CLECs to submit comments.

Bonnie Johnson – Integra (7/28/11 Updates received from Integra in CAPS) STATED WE’VE BEEN THERE. THE COMMENTS ORIGINALLY went [Deleted THERE] back and forth and we asked for collaborative process where THE CLECS AND CENTURYLINK could sit down and talk about changes TO ENSURE that THE CHANGES ARE [Deleted WERE] consistent with the XDSL provisions in amendment. Integra DID [Deleted DOES] not agree with many of THE CHANGES CENTURYLINK PROPOSED.. BONNIE REITERATED THAT regardless [Deleted THOSE. REGARDLESS] of PCAT, ICA controls. CENTURYLINK INDICATED THAT YOUR [Deleted YOUR] goal was to include PROCESSES IN THE [Deleted PROCESS FOR] amendments in the PCATs. I AM[Deleted AND] really disappointed that Qwest has taken different turn and IS refusing to be collaborative on ad hoc basis or IN CMP MEETINGS [Deleted MEETING] to get language that ALL PARTIES can agree on. CENTURYLINK IS BACK [Deleted BACK] to THE approach of sending level 3 NOTICES [Deleted NOTICE] as long YOU [Deleted WE] wait appropriate time in CMP, THE changes will be made over CLEC objections.

Mark Coyne – CenturyLink, (7/28/11 Updates received from Integra in CAPS) STATED we have been collaborative in holding several ad hoc calls to discuss updates and revisions to XDSL.

Bonnie Johnson – Integra, (7/28/11 Updates received from Integra in CAPS) [Deleted DON’T] agree. WE [deleted , ] had calls and WERE half way through THE TP. WE [Deleted AND] haven’t talked about downloads or PCATs. WE ABSOLUTELY [Deleted ABSOLUTELY] don’t agree WITH CENTURYLINKS POSITION.

Mark Coyne –CenturyLink, (7/28/11 Updates received from Integra in CAPS) STATED I can note your comment. We believe we did get through TP and issues were identified. CENTURYLINK PLANS [Deleted PLAN] to send out RECOMMENDATIONS ON [Deleted RECOMMENDATION] the MATRIX, OUR response TO [Deleted WITH] all ISSUES AND RECOMMENDATIONS [Deleted RECOMMENDATION] from [Deleted CLEC FROM] the CLECS PRESENTED IN THE ad hoc meetings and what CENTURYLINK’s approach is going forward. WE WILL PROVIDE [Deleted PROVIDING] additional opportunities FOR THE CLECS to comment and we feel we have been collaborative.

Bonnie Johnson – Integra (7/28/11 Updates received from Integra in CAPS) STATED [Deleted IF] refusing to have ADDITIONAL meetings IS [Deleted YOU’RE] not being collaborative, you are unilaterally making changes that CLECs don’t agree with. We want collaborative meetings to get language we agree on in the PCATs.

Mark Coyne – CenturyLink (7/28/11 Updates received from Integra in CAPS) STATED OUR [Deleted OUR] effort has been anything but unilateral in this case. We have offered up ad hoc meetings, discussed, reviewed the changes we’ve listened to and documented CLEC concerns. We acted upon those issues and concerns and revised our documentation accordingly. I HAVE A HARD [Deleted HARD] time saying this is a unilateral change when we’ve collaborated with the CLECs.

Bonnie Johnson – Integra, (7/28/11 Updates received from Integra in CAPS) STATED THERE HAS not BEEN [Deleted HAD] one ad hoc call for download or PCATs. BACK [Deleted SENT BACK] in April, INTEGRA SENT a redline of THE download that Qwest has never responded to. WE HAVE [Deleted HAVE] asked on several occasions for response to that.

Mark Coyne – CenturyLink, (7/28/11 Updates received from Integra in CAPS) STATED yes, part of the response going out in next several days will include all those suggested changes by the CLEC on that download. It will be a matrix like the TP MATRIX. CENTURYLINK WILL [Deleted WILL] provide AN outline of changes agreed to by CenturyLink AND [Deleted TO] modify the language according to what CLECs have recommended.

Bonnie Johnson – Integra, (7/28/11 Updates received from Integra in CAPS) STATED our REQUESTS [Deleted REQUEST] for ad hoc calls and collaborative effort on the PCATs and download are ongoing.

Liz Tierney – Covad (7/28/11 Updates received from Integra in CAPS) (7/29/11 Updates received from PAETEC in italicized CAPS) STATED CenturyLink IS only agreeing to 80% of changes, so WE ARE not quite there.. THERE NEEDS TO BE [Deleted NEED] additional discussion to make sure 100% of language is concurrent or collaborative.

Mark Coyne – CenturyLink, (7/28/11 Updates received from Integra in CAPS) STATED the 80% is what we took from the CLECs,

Liz Tierney – Covad, (7/28/11 Updates received from Integra in CAPS) SAID sorry, THERE IS STILL 20% THAT IS OPEN SO [Deleted 20%] you’re not there.

Julia Redman-Carter – PAETEC, (7/28/11 Updates received from Integra in CAPS) (7/29/11 Updates received from PAETEC in italicized CAPS) STATED [SAID] THE MEETINGS WERE POSTPONED, WHILE WE WERE still working on TECH PUB AND STILL had several sections OF THAT to go through. PAETEC [Deleted WILL] temporarily AGREED [Delete AGREE] on couple of THE EARLIER points based on how LANGUAGE WAS TO BE INTEGRATED [Deleted INTEGRATE] into the LATER [Deleted DIFFERENT] sections. THE MEETINGS WERE [Deleted MEETINGS] put off and WE WERE waiting for other responses from CenturyLink before continuing calls. WE ARE CONCERNED THAT [Deleted CONCERNED] we did not get through entire piece. THIS CONCERNS [Deleted CONCERNS] me greatly because TP’s are AUTOMATICALLY INCORPORATED [Deleted INTEGRATED in our ICAs AND THIS CAN CAUSE ISSUES IF THE TECH PUB IS NOT CONSISTENT WITH THE ICA LANGUAGE. IT IS IMPORTANT [Deleted IMPORTANT] to go through ALL OF THE TECH PUB AND RELATED DOCUMENTS in an ad hoc meeting.

Mark Coyne – CenturyLink, (7/29/11 Updates received from PAETEC in italicized CAPS) SAID [Deleted STATED] we did get through TECH PUB. (7/28/11 Updates received from Integra in CAPS) THERE ARE STILL [Deleted STILL]some open items on the matrix and CENTURYLINK will be RESPONDING [Deleted RESPONDED] in the response that goes out IN THE next few days.

Susan Lorence – CenturyLink, (7/28/11 Updates received from Integra in CAPS) (7/29/11 Updates received from PAETEC in italicized CAPS) STATED THAT SHE CONFIRMED [Deleted CONFIRM] that we did get through all the items on the TECH PUB matrix.

Bonnie Johnson – Integra, (7/28/11 Updates received from Integra in CAPS) (7/29/11 Updates received from PAETEC in italicized CAPS) STATED [SAID] we reviewed THE ITEMS IN TP MATRIX but did not come to consensus. Now Qwest is saying it is not going to talk about it anymore. THE CHANGES [Deleted CHANGES] will be made whether CLECS [Deleted WE] agree or not. IT DOESN’T [Deleted DOESN’T] matter if WE’VE [CENTURYLINK AND THE CLECS HAVE] been meeting for a year if THE job isn’t FINISHED [COLLABORATIVELY], THERE HAS NOT BEEN [Deleted FINISHED. NOT], [THEN IT IS NOT] a collaborative approach.

Julia Redman-Carter – PAETEC, (7/28/11 Updates received from Integra in CAPS) (7/29/11 Updates received from PAETEC in italicized CAPS) [SAID] STATE I DON’T [Deleted DON’T] want to commit TO ANY CHANGES BEFORE I SEE THEM but I would like to see CENTURYLINK’S redline responses before WE MEET [Deleted MEETING] again. I AM WILLING [Deleted WILLING] to say THAT once we see what’s been incorporated and what hasn’t, WE then can narrow down THE issues AND HAVE ADDITIONAL [Deleted HAVE] ad hoc MEETINGS to address those issues. Hopefully, WE CAN focus on issues where THERE still is not CONSISTENCY [Deleted CONSISTENT].

Bonnie Johnson – Integra, (7/28/11 Updates received from Integra in CAPS) (7/29/11 Updates received from PAETEC in italicized CAPS) STATED WE WILL [SAID WE STILL] need to talk about the 20%.

Mark Coyne – CenturyLink, (7/28/11 Updates received from Integra in CAPS) STATED I hear you, AND THIS IS not a bad idea but I WILL need to confer with SME team. Let CLECs take a look at the matrices, see what points they feel are still outstanding that we cannot reach resolution on through this process then talk about next steps. I WILL DISCUSS THIS APPROACH WITH THE SME TEAM BUT I CANNOT [Deleted CANNONT] commit at this point.

Julia Redman-Carter – PAETEC, (7/28/11 Updates received from Integra in CAPS) (7/29/11 Updates received from PAETEC in italicized CAPS) STATED [SAID] I AM trying to get to next step. I DON’T [Deleted DON’T] want to agree that comments will be sufficient. I DON’T [Deleted DON’T] want to stop DISCUSSIONS [Deleted DISCUSSION] or come to halt. WE NEED TO [Deleted AS LONG CAN] get information and agree on next steps. We think is premature TO STOP [Deleted OF] the collaborative process.

Mark Coyne – CenturyLink, (7/28/11 Updates received from Integra in CAPS) (7/29/11 Updates received from PAETEC in italicized CAPS) STATED [SAID] I hear what you’re saying. WE PLAN [Deleted PLAN] on sending out responses and matrices in next few days.

Susan Lorence – CenturyLink, (7/28/11 Updates received from Integra in CAPS) (7/29/11 Updates received from PAETEC in italicized CAPS) STATED [SAID] WE ARE putting final changes on some documents and plan to send THEM IN THE next few days. RESPONSES TO EMAIL ARE [Deleted EMAIL RESPONSE] incorporated into THE documentation. AREAS [Deleted THAT PARTS] where CLECs had concerns were reviewed and some WERE accepted and ON some CENTURYLINK is not willing to move forward on and further discussion will not change that approach. Some of THE ISSUES [Deleted THOSE] are ongoing. One is the name of the amendment, WE WENT back and forth ON THE NAME OF THE AMENDMENT and CenturyLink is not willing to make that change [PAETEC deleted AT THIS TIME] at this time. We’ve talked about it and continuing TO TALK will not make a difference. THE CLECS SHOULD SEE [Deleted SEE] what THE CENTURYLINK responses are and see what CenturyLink is willing to change and what we aren’t and then WE WILL do a check. [Deleted POINT]

Julia Redman-Carter – PAETEC, (7/28/11 Updates received from Integra in CAPS) (7/29/11 Updates received from PAETEC in italicized CAPS) STATED [SAID] I AM willing to look at that. I WILL NEED AN [Deleted WOULD LIKE] explanation ON why CenturyLink IS not willing TO CONSIDER change on some of those points. AN DETAILED EXPLANATION [Deleted EXPLANATION] would help us to understand CENTURYLINK’S [Deleted THE] basis for not changing. THE EXPLANATION WILL PROVIDE [Deleted GET] a head start to keep THE PROCESS moving forward.

Susan Lorence – CenturyLink, (7/28/11 Updates received from Integra in CAPS) (7/29/11 Updates received from PAETEC in italicized CAPS) STATED [SAID] WE provided THE REASONS WHY CENTURYLINK IS [Deleted WHY] not willing to make name change to the amendment. CENTURYLINK WILL REVIEW [Deleted SEE] what CLECS [Deleted WE] send back before we decide THE next steps.

Bonnie Johnson – Integra, (7/28/11 Updates received from Integra in CAPS) (7/29/11 Updates received from PAETEC in italicized CAPS) STATED [ASKED] will Qwest agree not to send out level 3 notices .

Mark Coyne – CenturyLink, (7/28/11 Updates received from Integra in CAPS) ASKED until we hear back on the matrix?

Julia Redman-Carter – PAETEC, (7/28/11 Updates received from Integra in CAPS) (7/29/11 Updates received from PAETEC in italicized CAPS) STATED [SAID] until we have a chance to determine what the next step is. For both of us let’s get the feedback and see what next step SHOULD [Deleted WOULD] be. If CENTURYLINK SENDS A level 3 notices NOW [Deleted ARE ALREADY GOING OUT] with A comment period NOW, THEN we’re already at your NEXT step AND THE CLEC IS NOT. [Deleted NOT] able to come back and say WE WOULD LIKE AN ad hoc MEETING ON [Deleted OR] an issue. [PAETEC offered similar language in updates]

Mark Coyne – CenturyLink, (7/29/11 Updates received from PAETEC in italicized CAPS) SAID [Deleted STATED] CenturyLink is not intending to issue level 3 notices on the heels of sending out the responses and matrices. So as long as CLECs take THE opportunity to review and provide feedback in timely fashion, we’ll take a look at that.

Bonnie Johnson – Integra, (7/28/11 Updates received from Integra in CAPS) (7/29/11 Updates received from PAETEC in italicized CAPS) STATED THAT [SAID IT WOULD BE] most appropriate and helpful. BONNEI ASKED IF CENTURYLINK would be to send OUT the redline TECH PUB AND OTHER DOCUMENTS also. Sometimes what’s in matrix and what you do IN THE TP [IN THE ACTUAL DOCUMENTS] don’t coincide WITHOUT [Deleted .WITHOUT] [IT IS HARD TO TELL WITH JUST] a level 3 notice just attaching [ATTACHED] to the email.

Mark Coyne – CenturyLink, (7/28/11 Updates received from Integra in CAPS) SAID we can look at that and provide that.

Susan Lorence – CenturyLink, (7/28/11 Updates received from Integra in CAPS) (7/29/11 Updates received from PAETEC in italicized CAPS) STATED [SAID] that was the intent that the matrices would go OUT as well as the redlines.

Mark Coyne – CenturyLink, (7/28/11 Updates received from Integra in CAPS) (7/29/11 Updates received from PAETEC in italicized CAPS) STATED [SAID] I knew that FOR [Deleted ON] the TECH PUB. Are we also doing that on the conditioning download as well?

Susan Lorence –CenturyLink, (7/28/11 Updates received from Integra in CAPS) SAID yes

Mark Coyne – CenturyLink, (7/28/11 Updates received from Integra in CAPS) (7/29/11 Updates received from PAETEC in italicized CAPS) STATED [SAID] you will get the redline version of both of those documents with the matrices.

Bonnie Johnson – Integra, (7/28/11 Updates received from Integra in CAPS) (7/29/11 Updates received from PAETEC in italicized CAPS) ASKED what about the PCATs? There are 3 PCATs, the Unbundled Loop General , THE ADSL and the 2-Wire Non-Loaded [UNLOADED] Loop.

Mark Coyne – CenturyLink, (7/28/11 Updates received from Integra in CAPS) (7/29/11 Updates received from PAETEC in italicized CAPS) STATED [SAID] our CR is not calling for changes to those PCATs. WE ARE only CHANGING the conditioning download.

Bonnie Johnson – Integra, (7/28/11 Updates received from Integra in CAPS) (7/29/11 Updates received from PAETEC in italicized CAPS) STATED [SAID] we believe there are inaccuracies in the PCATs also. Is your intent to leave THE INNACURACIES IN those 3 PCATs [Deleted AS THEY ARE TODAY) ?

Susan Lorence – CenturyLink, (7/28/11 Updates received from Integra in CAPS) (7/29/11 Updates received from PAETEC in italicized CAPS) SAID those [3 PCATs] are not changing. It’s the JUST THE conditioning download and the TECH PUB THAT ARE CHANGING.

Mark Coyne – CenturyLink, (7/28/11 Updates received from Integra in CAPS) (7/29/11 Updates received from PAETEC in italicized CAPS) STATED [SAID] that’s true as of today.

Julia Redman-Carter – PAETEC, (7/29/11 Updates received from PAETEC in italicized CAPS) ASKED what’s a reasonable time to respond?

Susan Lorence – CenturyLink, (7/29/11 Updates received from PAETEC in italicized CAPS) ASKED what would think is reasonable?

Bonnie Johnson – Integra, (7/28/11 Updates received from Integra in CAPS) (7/29/11 Updates received from PAETEC in italicized CAPS) STATED THAT considering [SAID THE SAME] amount of time Qwest has taken to respond TO THE CONDITIONING DOWNLOAD WE SENT IN APRIL, BUT we don’t need that much time. BUT I AM [Deleted BUT I’M] on vacation for week and a half.

Julia Redman-Carter – PAETEC, (7/28/11 Updates received from Integra in CAPS) (7/29/11 Updates received from PAETEC in italicized CAPS) STATED I AM [SAID I HAVE][Deleted ON] on vacation as well. THIS IS SOMETHING [Deleted SOMETHING] that takes FOLKS a couple of WEEKS TO WORK ON, ADD [Deleted WEEKS. ADD] vacation TIME in and we’re looking at 3-4 weeks AT LEAST.

Bonnie Johnson – Integra, (7/28/11 Updates received from Integra in CAPS) (7/29/11 Updates received from PAETEC in italicized CAPS) STATED [SAID] that’s where I was going also.

Mark Coyne – CenturyLink, (7/28/11 Updates received from Integra in CAPS) ASKED is 3 weeks the right number? 21 calendar days?

Julia Redman-Carter – PAETEC, (7/28/11 Updates received from Integra in CAPS) ASKED so you’re looking at the 12th of August?

Bonnie Johnson – Integra, (7/28/11 Updates received from Integra in CAPS) (7/29/11 Updates received from PAETEC in italicized CAPS) RESPONDED IT IS [SAID] actually the 15th.

Julia Redman-Carter – PAETEC, (7/28/11 Updates received from Integra in CAPS) (7/29/11 Updates received from PAETEC in italicized CAPS) STATED [SAID] that WOULD [Deleted WILL] work BETTER SINCE it gives me the weekend.

Mark Coyne – CenturyLink, (7/28/11 Updates received from Integra in CAPS) (7/29/11 Updates received from PAETEC in italicized CAPS) STATED [SAID] based on responses we’ll determine next steps

Bonnie Johnson – Integra, (7/28/11 Updates received from Integra in CAPS) (7/29/11 Updates received from PAETEC in italicized CAPS) STATED SHE [SAID] HAD [A] ONE final point that regardless of what’s in the documentation if IT IS not consistent with amendment then THE amendment controls. If Qwest is training process off documentation THAT IS and not consistent WITH THE AMENDMENT, THEN OUR AMENDMENT CONTROLS.

Mark Coyne – CenturyLink, (7/28/11 Updates received from Integra in CAPS) (7/29/11 Updates received from PAETEC in italicized CAPS) STATED [SAID] THE amendment controls in that situation.

Julia Redman-Carter – PAETEC, (7/28/11 Updates received from Integra in CAPS) (7/29/11 Updates received from PAETEC in italicized CAPS) STATED [SAID] THE TP IS IN OUR ICAS AND THE concern is if TECH PUB IS not consistent with amendment, that’s where concern AND ISSUES comes in. TECH PUB is a big deal.

Mark Coyne – CenturyLink, (7/28/11 Updates received from Integra in CAPS) ASKED IF THERE WERE any final comments or questions on that CR?

No additional comments.

6/15/11 Product Process Monthly Meeting Mark Coyne – Qwest said that there had been a number of Ad hoc meetings and the next meeting is June 23. Mark said the documentation had been posted to the calendar and that the hope was to complete the review of the Tech Pub on June 23.

Karen Clauson – Integra questioned whether Qwest had completed their action items from the last call.

Susan Lorence – Qwest said yes, the SME team had completed a review of the Tech Pub updates and that the calendar included an agenda, the updated matrix and Tech Pub chapters.

Karen Clauson – Integra said there were action items that may not have been on the matrix and asked where that information was.

Susan Lorence – Qwest said that was included under Row 0 on the matrix.

Mark Coyne – Qwest asked if there were any more questions and there was none.

5/18/11 Product Process Monthly Meeting Mark Coyne – Qwest relayed there had been multiple ad hoc meetings on the Tech Pub updates and that the minutes from the last Ad hoc on May 11, 2011 were due today but that Qwest was requesting an extension to Monday 5/23 in exchange for allowing the CLECs extra time to comment.

Bonnie Johnson – Integra said she would be on vacation the next week. She said the problem is preparing for the Ad hoc and not have the meeting minutes from the last meeting. She asked when the documentation for the next meeting would be available.

It was determined that based on the upcoming holiday and various folks being on vacation and returning from vacation, the June 2 Tech Pub meeting would be moved to the first full week of June and that the related documentation would be out the week before to allow time for CLEC review. Qwest would send a notice to identify the change in the Ad hoc meeting date.

5/11/11 Ad hoc Meeting ORIGINAL ENTRY Pending updates of CLEC redlines in a format that is retainable in the CR database. In the interim, refer to Wholesale calendar at http://wholesalecalendar.qwestapps.com/detail/323/2011-05-11 for Qwest draft and CLEC combined redlined meeting minutes.

5/11/11 Ad hoc Meeting Attendees: Brandy Walton – RIO Networks, Julia Redman Carter- PAETEC, Mike McCarthy -Minnesota Department of Commerce, Bruce Linscheid - Minnesota Department of Commerce, Andy Bahn - Minnesota Department of Commerce, Greg Doyle -Minnesota Department of Commerce, Brenda Bloemke-Comcast, Bonnie Johnson-Integra, Doug Denney-Integra, Karen Clauson-Integra, Joyce Pederson - Integra, Kim Isaacs – Integra, Karrie Willis – POPP, Adam King – KTF Telecom, Carrie Lorenz – tw telecom; Evette Hendricks – cbeyond, Nicole Colvin – cbeyond, Mark Masi – cbeyond, Tony Insinga – cbeyond, Mitch Moore-Oregon PUC, Cindy Orenstein – Qwest, Jeff Farra – Qwest, Jamal Boudhaouia-Qwest, Rita Urevig – Qwest, Bob Mohr-Qwest, Linda Harmon-Qwest, Mark Coyne-Qwest, Mark Nickell – Qwest, John Hansen-Qwest, Carolyn Hammack-Qwest, Susan Lorence-Qwest

Susan Lorence - Qwest reviewed the agenda for the call; Spectrum Management would be the focus followed by a review of the document for consistency. She said due to the full agenda, the review of the Conditioning Download would be held for the Face to Face CMP meeting on May 18, 2011.

Bonnie Johnson - Integra questioned if the Qwest redline of the Integra proposed updates to the Conditioning Download would be received prior the meeting. Bonnie said the response is needed to allow time to review before any discussion occurs.

(6/2/12 Updates received from Integra in CAPS) SUSAN LORENCE – QWEST INDICATED THAT QWEST WILL REGROUP AND TRY TO HAVE THE RESPONSE BY THE END OF THE WEEK AND WILL CONFIRM VIA EMAIL.

(6/2/12 Updates received from Integra in CAPS) BONNIE JOHNSON – INTEGRA ASKED BY FRIDAY YOU WILL LET ME KNOW? SHE SAID WE WILL NEED THE RESPONSE PRIOR TO MEETING IF WE ARE GOING TO DISCUSS ON THE MAY 18TH CMP CALL.

(6/2/12 UPDATES RECEIVED FROM INTEGRA IN CAPS) SUSAN LORENCE – QWEST SAID YES.

(6/2/12 Updates received from Integra in CAPS) BONNIE JOHNSON – INTEGRA ASKED QWEST IF THE INTEGRA’S 5/11/11 MATRIX WAS POSTED.

(6/2/12 Updates received from Integra in CAPS) SUSAN LORENCE – QWEST SAID YES.

Jamal Boudhaouia-Qwest proposed the discussion continue by reviewing the matrix line by line.

Karen Clauson-Integra referred everyone to the posted matrix from Integra dated 5-11-11 (6/2/12 Updates received from Integra in CAPS) INDICATING THAT THE ROW NUMBERS WERE ADDED FOR EASE OF REFERENCE and said Spectrum Management was added as Row 0 in the matrix but it is also addressed in rows 14 and 33. Karen said Spectrum Management is addressed in Section 9.2.6.10 of the xDSL Services Amendment and IT STATES PARTIES AGREE TO FOLLOW THE ACT AND THE AMENDMENT, WHICH REQUIRES QWEST TO TAKE THE NCI CODE INTO ACCOUNT. KAREN said THAT, in the last meeting, Mike McCarthy of the Minnesota Department of Commerce (MN DOC) had referred to the T1 417 document in Section 3.1.45 to provide a definition OF SPECTRUM MANAGEMENT. Karen suggested the Spectrum Management definition be included in a new Section 1.8 and then it can be referred to in later sections of the Tech Pub. Karen said there are references to T1 417 in customers’ ICAs and it is referenced in 9.2.6.1 of the template and the Eschelon contract. Karen read the proposed Integra definition in the matrix and referred to the two sentences added by Integra and the related footnote. (See Integra 5-11-11 matrix Row 0 and footnote 3 for details of Integra proposed Section 1.8, Title, and Section references available at http://wholesalecalendar.qwestapps.com/detail/323/2011-05-11.)

Jamal Boudhaouia-Qwest proposed that the industry standard (6/2/12 Updates received from Integra in BOLD) T1 417 definition provided by Mike McCarthy-MN DOC be included in the General Section 1.7 as the guiding principal for other Tech Pub sections and said he thought that would be cleaner (6/2/12 Updates received from Integra in CAPS) AND SECTION 6 COULD BE MORE GRANULAR. JAMAL INDICATED QWEST WOULD LIKE TO LEAVE THE GENERAL SECTION DEFINITIONS AS THEY ARE.

(6/2/12 Updates received from Integra in CAPS) KAREN CLAUSON – INTEGRA SAID, UNDER THAT THOUGHT, WHERE WOULD THE REMAINDER OF INTEGRA’S PROPOSED LANGUAGE GO? ARE YOU SUGGESTING 6.1 GENERAL SECTION?

(6/2/12 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA – QWEST [delete JAMAL SUGGESTED] SAID YES, AFTER A SENTENCE IN SECTION 6.1, BUT the additional Integra [delete DEFINITIONS] DEFINITION WOULD be included in the Definition section of the General Section. Jamal suggested the second sentence of the Integra proposed language be included in Section 6.1 and would be updated to include the additional wording that Integra proposed.

Karen Clauson-Integra said (6/2/12 Updates received from Integra in CAPS) IT WAS INTERESTING THAT YOU WOULD POINT TO THAT SENTENCE BECAUSE, on Row 20 of the matrix, Qwest agreed on April 20, 2011 to delete two paragraphs that included the wording “QWEST RESERVES THE RIGHT TO MAKE SOME CABLES UNAVAILABLE …but remotely possible …NOTIFIED,” but they are still in the redlined document.

(6/2/12 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA-QWEST SAID ONE THING AT A TIME.

(6/2/12 Updates received from Integra in CAPS) KAREN CLAUSON-INTEGRA SAID QWEST AGREED TO REMOVE IT.

Jamal Boudhaouia-Qwest said if we agreed to remove it then we will remove it.

Karen Clauson-Integra confirmed the proposal: The heading and first sentence of (6/2/12 Updates received from Integra in CAPS) THE INDENTED LANGUAGE in Row 0 of the matrix would be placed in Section 1.7 of the Tech Pub. The next two sentences would move to Section 6.1 before the bullets. [delete KAREN SAID THE INTENT IS TO REFLECT THE AMENDMENT AND REFERRED TO OTHER SECTION HEADINGS.]

Jamal Boudhaouia-Qwest said (6/2/12 Updates received from Integra in CAPS) YES. JAMAL SAID he did not want to modify the T1 417 language but wanted to keep it exactly like the standard to say just “Spectrum Management”. Jamal said he was OK with modifying like Karen suggested but said it is not to the customers’ benefit to make it specific to “xDSL Capable Loop”. [delete JAMAL SAID IF HE HAD A T1 AMI SIGNAL, IT WOULD INTERFERE WITH OTHER BINDER GROUPS WHICH IS WHY HE IS SUGGESTING TO LEAVE IT AS IN THE STANDARD AS SPECTRUM MANAGEMENT. ]

(6/2/12 Updates received from Integra in CAPS) KAREN CLAUSON-INTEGRA SAID THE INTENT IS TO REFLECT THE AMENDMENT AND REFERRED TO OTHER SECTION HEADINGS. THIS WOULD BE IN 1.7, AND THERE IS A HEADING IN 3.1.45 AND THEN IT IS CONSISTENT WITH THE FORMAT OF THE DOCUMENT.

(6/2/12 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA – QWEST SAID THEN THERE IS AGREEMENT THE DEFINITION IS IN 1.7.

(6/2/12 Updates received from Integra in CAPS) KAREN CLAUSON – INTEGRA SAID YES LOOK AT 3.`1.45 AND IT SHOULD BE FORMATTED JUST LIKE THAT.

(6/2/12 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA – QWEST Jamal said if he had a T1 AMI signal, it would interfere with other binder groups, which is why he is suggesting to leave it as in the standard as Spectrum Management. Karen Clauson-Integra said that clarification was helpful and (6/2/12 Updates received from Integra in CAPS) [delete AGREED] SAID FOR THE HEADING to JUST SAY [delete LEAVE IT AS] 1.7 Spectrum Management, AND SHE ASKED IF THAT WOULD ADDRESS CONCERNS. Karen said Qwest relayed the purpose of the Tech pub changes was to reflect the contract.

Jamal Boudhaouia-Qwest said he wanted to leave the definition as it was in the standard so it covers all technology and that is as it is defined in T1 417. Jamal asked Mike McCarthy if that was the intent.

Mike McCarthy – MN DOC said yes.

Karen Clauson-Integra confirmed the proposal again on how to deal with (6/2/12 Updates received from Integra in CAPS) THE INDENTED LANGUAGE IN Row 0: The title would be Spectrum Management, and IT AND the first sentence would be placed in Section 1.7 of the Tech Pub. The next two sentences would move to Section 6.1 before the bullets. Karen said the group needed to talk about where the NC/NCI codes would go and asked what was the proposal for [delete THE] footnote 3 IN THE MATRIX.

Jamal Boudhaouia – Qwest (6/2/12 Updates received from Integra in CAPS) AGREED THAT [delete SAID] the NC/NCI information DESCRIBED IN FOOTNOTE 3 would go in the Tech Pub,[delete AND] BUT that he needed to find a place for them.

(6/2/12 Updates received from Integra in CAPS) KAREN CLAUSON-INTEGRA CONFIRMED IT IS AGREED TO INCLUDE THE INFORMATION BUT WE WILL NEED TO DECIDE ON PLACEMENT.

(6/2/12 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA – QWEST SAID ABSOLUTELY.

(6/2/12 Updates received from Integra in CAPS) There was agreement to place (6/2/12 Updates received from Integra in CAPS) THE PLACEMENT OF THE AMENDMENT LANGUAGE DESCRIBED IN [delete THE] footnote 3 [delete LANGUAGE] (SECTION 9.2.2.3.5.5 OF THE AMENDMENT) on HOLD until a place was found for it.

Karen Clauson-Integra said (6/2/12 Updates received from Integra in CAPS) THAT, on the last Ad hoc call, Mike McCarthy – MN DOC wanted to discuss the definition.

Mike McCarthy – MN DOC said (6/2/12 Updates received from Integra in CAPS) HE WANTED TO MAKE SURE THE PARTIES WERE USING THAT DEFINITION. HE SAID he thought the group was going where it needed to go and that the goal was for all parties to have their signal transmitted reliably and that there was reciprocity. HE SAID THAT SO FAR THE DEFINITION DOES THAT. Mike said NOW, AS WE MOVE FORWARD, the group needed to insure how Spectrum Management comported with Clause 5 of T1 417. HE SAID WE HAD TO BE SURE WE ARE USING SPECTRUM MANAGEMENT CLASSES AS THEY RELATE TO CLAUSE 5.

(6/2/12 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA-QWEST SAID HE AGREED.

(6/2/12 Updates received from Integra in CAPS) KAREN CLAUSON – INTEGRA ASKED JAMAL IF HE AGREED WITH MIKE’S DESCRIPTION OF THE DEFINITION.

(6/2/12 Updates received from Integra in CAPS) ) JAMAL BOUDHAOUIA -Qwest SAID YES, I AM TAKING IT WORD FOR WORD.

(6/2/12 Updates received from Integra in CAPS) KAREN CLAUSON–INTEGRA SAID MIKE STATED THAT SIGNALS TRANSMIT RELIABLY, DO YOU AGREE?

Jamal Boudhaouia-Qwest (6/2/12 Updates received from Integra in CAPS) AGREED AND asked MIKE what reciprocity meant.

Mike McCarthy – MN DOC said (6/2/12 Updates received from Integra in CAPS) THE INTENT OF THE DEFINITION, AS I UNDERSTAND IT, IS there are multiple wire pairs and multiple companies using them – QWEST AND OTHERS. THE INTENT OF THE DEFINITION OF Spectrum management means that, IF IT IS JUST THE TWO OF US AND 2 WIRE PAIRS, QWEST WILL MANAGE the signals [delete WOULD BE MANAGED] so MY SIGNAL WILL NOT MESS WITH YOURS AND YOUR SIGNAL WILL NOT MESS WITH MINE. [delete AS NOT TO MESS EACH OTHER’S SIGNALS UP] THERE IS AN INTENT THAT EVEYONE’S SIGNAL TRANSMITS [delete AND THAT ALL SIGNALS TRANSMITTED] reliably for both to have success.

Jamal Boudhaouia-Qwest said as long as the equipment hooked up to the wires from both sides meets the standards in T1 417, he had no issues.

Mike McCarthy - MN DOC said (6/2/12 Updates received from Integra in CAPS) THAT IS WHERE WE HOPE TO START, WITH AN UNDERSTANDING THAT ALL PARTIES HAVE RESPONSIBILITIES AND the goal is to insure all parties clearly understand their responsibilities.

Jamal Boudhaouia – Qwest said absolutely. (6/2/12 Updates received from Integra in CAPS) HE SAID, IF WE’RE IN AN OCEAN AND CAN’T SWIM, WE’LL ALL DROWN and that all parties need to adhere to certain processes. Jamal said he would put the definition in Section 1.7 to match T1 417. JAMAL ASKED KAREN IF WE HAVE AGREEMENT.

(6/2/12 Updates received from Integra in CAPS) KAREN CLAUSON – INTEGRA SAID THAT, IF THAT IS AS WE DISCUSSED IN 1.7, AND KAREN READ THE INTEGRA-PROPOSED DEFINITION, THEN YES.

(6/2/12 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA – QWEST SAID YES.

(6/2/12 Updates received from Integra in CAPS) KAREN CLAUSON – INTEGRA SAID WE HAVE MORE QUESTIONS, BUT IT HELPFUL TO START WITH THE DEFINITION.

Mike McCarthy - MN DOC (6/2/12 Updates received from Integra in CAPS) SAID THAT THE INTENT IS FOR THIS TO BE A STARTING POINT.[delete AND KAREN CLAUSON - INTEGRA BOTH AGREED.]

Julia Redman Carter- PAETEC said she agreed with the definition and proposal but wanted to (6/2/12 Updates received from PAETEC in CAPS) [delete CLARIFY] RESERVE THE POSSIBILITY that there may be a need to revisit it depending on the language AND WHERE IT WAS INSERTED in Section 6.1.

NOTE: DUPLICATE PARAGRAPH WITH 6/2/12 Updates received from Integra in CAPS) Julia Redman Carter- PAETEC said she agreed with the definition and proposal TO MOVE THE SECOND PART AND THE FOOTNOTE INFORMATION TO 6.1 AS AN EARLY AGREEMENT. SHE SAID SHE [delete BUT] wanted to clarify that there may be a need to revisit it depending on HOW the language in Section 6.1 LOOKS. JULIA SAID THAT SHE WANTED TO RESERVE HER RIGHT TO REVISIT THIS IN THE FUTURE.

Susan Lorence - Qwest said it sounded like there was agreement on wording in Section 1.7 and everyone was OK to move forward. (6/2/12 Updates received from Integra in CAPS) SUSAN ASKED WHAT OTHER QUESTIONS INTEGRA HAS.

Karen Clauson-Integra said (6/2/12 Updates received from Integra in CAPS) WE WILL START OFF, AND THE OTHER CLECS CAN JOIN IN THEY HAVE QUESTIONS. The Integra questions are addressed in Rows 0, 14 and 33. ONE OF OUR QUESTIONS IS THE BIG PICTURE QUESTION: WHERE IS QWEST GOING WITH THE LANGUAGE? On Row 33, IN SECTION 6.5, QWEST SAID: “QWEST CANNOT ENSURE THAT TYPICAL ADSL INTERFERING SIGNALS, E.G., T1 REPEATERED LINES OR BRI ISND LINES ARE NOT OR WILL NOT BE IN THE SAME OR ADJACENT CABLE BINDER GROUPS AS AN ADSL LOOP.” QWEST PROPOSED TO TAKE OUT “OR WILL NOT BE.” Karen asked ABOUT THE DIFFERENCE BETWEEN WHAT HAS BEEN IN THE PAST AND WHAT WILL BE GOING FORWARD . SHE ASKED that Jamal walk through the changes that will be different going forward with Spectrum Management. SHE SAID THERE SHOULD NOT BE [delete AND TO INSURE THERE IS NO] discrimination against any [delete ONE] carrier.

Jamal Boudhaouia-Qwest (6/2/12 Updates received from Integra in CAPS) SAID THAT, [delete REVIEWED WHAT HAS OCCURRED] in the past, [delete FOR] for any CLEC that had requested unbundled loop and Qwest correctly identified the NC/NCI, if there was interference, Qwest would always take care of any problems, including BINDER GROUP SEPARATION reinforcing a section of cable, or IN SOME CASES EVEN Putting new cable in the ground. HE SAID THAT QWEST DOES EVERYTHING POSSIBLE TO ENSURE CLEC SERVICES KEEP RUNNING IF THERE IS AN INTERFERENCE ISSUE. Jamal said THAT WHAT QWEST IS TRYING TO SAY HERE IS THAT, IF THERE ARE SERVICES RUNNING today, WHEN LFACS PICKS A LOOP BASED ON NC/NCI CODE, LFACs does not see in the binder group, and when the technicianS [delete GOES TO] GO IN the field, they may assign a different cable if they see there is interference DURING INSTALLATION. If there is interference AT A later DATE, LIKE T1’S RUNNING IN THE SAME BINDER GROUP AND, ESPECIALLY WHEN A REMOTE TERMINAL - DSLAM –IS DEPLOYED, QWEST WILL REINFORCE THE CABLE OR Qwest looks for a different pair IN A NEW BINDER GROUP. Jamal said the process has not changed since 2000 or before. When Qwest struck “or will not be..”, Qwest always took care of the problem. Going forward, the process of Spectrum Management will take into consideration that fact that Qwest has deployed remote DSLAM in the network, T1 AMI WILL NOT BE IN THE BINDER GROUP WITH XDSL CO BASED DSL CAN RUN IN THE SAME BINDER GROUP.

(6/2/12 Updates received from Integra in CAPS) KAREN CLAUSON-INTEGRA SAID THERE ARE QUESTIONS BUT NOT SURE IF THAT WAS DONE.

Julia Redman Carter- PAETEC questioned how is that different, and why (6/2/12 Updates received from Integra in CAPS) [delete IS] “or will not be” IS being deleted. WHAT IS DIFFERENT?

Jamal Boudhaouia-Qwest said there were not a lot of (6/2/12 Updates received from Integra in CAPS) REMOTE TERMINAL (RT) deployments previously but, as Qwest has deployed fiber to the node AND MORE REMOTE TERMINALS, there was more chance of spectrum management issues within the cross box. AS THERE IS MORE AND MORE RT-BASED DEPLOYMENT, WE ANTICIPATE MORE SPECTRUM MANAGEMENT ISSUES. IN ANTICIPATION OF THOSE ISSUES, Qwest [delete TRIED] TRIES to ACTIVELY segregate signals within one or two binder groups running from the CO. [delete JAMAL SAID THE DESCRIPTION WAS SENT IN CLAUSE 5 AND IT WAS IDENTIFIED AND WAS POSTED TO THE WHOLESALE CALENDAR FOR THE MEETING.]

(6/2/12 Updates received from Integra in CAPS) JULIA REDMAN CARTER – PAETEC SAID I UNDERSTAND THE DESCRIPTION.

(6/2/12 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA - QWEST SAID SUSAN SENT THE CLAUSE 5 DESCRIPTION REFERRED TO, AND IT WAS POSTED TO THE WHOLESALE CALENDAR FOR THE MEETING.

Julia Redman Carter- PAETEC said she (6/2/12 Updates received from PAETEC in CAPS) STILL did not understand HOW THE EXPLANATION APPLIES TO the PROPOSED deletion of “or will not be.” BUT THE CONVERSATION COULD MOVE ON AND SHE WOULD SEE IF IT MADE BETTER SENSE LATER.

Karen Clauson-Integra said (6/2/12 Updates received from Integra in CAPS) THAT, in earlier statements by Qwest, they were told BY QWEST REPEATEDLY that the NC/NCI codes were informational only and that Qwest did not load the NC/NCI CODES (AND SHE REFERRED TO FOOTNOTE 7 TO MATRIX ROW 14) but only looked at the NC code AND DID NOT LOOK AT WHAT THE CLEC DEPLOYED. Karen referred to Row 14 and said she understood that THE AMENDMENT SOLVED THAT AND, with the Amendment, [delete THAT] Qwest will use both the NC and NCI code to understand the protocol options and will look at the flavors of DSL. Karen said THAT, IN THE PAST, QWEST DID NOT USE THEM IN THE SAME MANNER AS IT WILL GOING FORWARD AND, SINCE QWEST DID NOT DO THAT, THERE MAY BE SOME CASES WHERE THE SERVICES ARE ARRANGED IN A DIFFERENT MANNER. [delete the] The difference is in the way they are looked at in the past vs. in the future, going from reactive to proactive SPECTRUM MANAGEMENT.

Jamal Boudhaouia-Qwest said he wanted to be clear and wanted to put it to rest that Qwest will take into account the NC/NCI in its entirety(6/2/12 Updates received from Integra in CAPS) INCLUDING THE PROTOCOL OPTIONS that is provided to Qwest in INSTALLING, provisioning, and managing spectrum management processes. Jamal said CLECS PROVIDED QWEST THE CODES THROUGH IMA OR OTHER MEANS, AND the information was retained IN THE SYSTEM in the past but not used FOR PROVISIONING downstream. In the future, Qwest will use THEM. IN ADDITION, FOR SPECTRUM MANAGEMENT, WE WILL USE IT IN ITS ENTIRETY TO FIGURE OUT WHAT PROTOCOLS – FLAVOR – OF SPECTRUM MANAGEMENT CLASS IS RUNNING ON THE COPPER PLANT. GOING FORWARD – “OR WILL NOT BE” – THE PROCESS WILL TAKE INTO ACCOUNT the entirety of the NC/NCI codes WHEN ASSIGNING LOOPS [delete TO DETERMINE WHAT IS RUNNING IN THAT COPPER PLANT].. Julia Redman Carter- PAETEC said she had a concern that it is not just (6/2/12 Updates received from PAETEC in CAPS) FOR provisioning and that it would also be used in [delete A] repair situationS for the embedded base CONSISTENT WITH THE XDSL AMENDMENT. [delete AND] SHE ALSO CLARIFIED that [delete IT HAD] THIS HAS been a problem since 2007.

NOTE: DUPLICATE PARAGRAPH WITH 6/2/12 Updates received from Integra in CAPS)Julia Redman Carter- PAETEC said THAT SOUNDS GREAT BUT YOU SAID WHEN WE PROVISION LOOPS. SHE ASKED, WHAT ABOUT REPAIR? [delete she]She EXPRESSED [delete HAD] a concern that it is not just provisioning and that it would also be used in a repair situation for the embedded base SO THEY ARE CORRECTED, and that THIS [delete IT] had been a problem THAT PAETEC HAS BEEN REPORTING TO QWEST since 2007.

Jamal Boudhaouia-Qwest said (6/2/12 Updates received from Integra in CAPS) THAT, FOR REPAIR AS WELL, QWEST WILL TAKE INTO ACCOUNT THE NC/NCI CODES. HE SAID THAT THERE MAY BE [delete IT IS ALSO REPAIR THAT IS] a spectrum management issue and that THE KEY IS TO [delete ALL WOULD] agree that it is the NC/NCI in its entirety OF THE SPECTRUM MANAGEMENT CLASS, FOR QWEST OR CLEC, FOR COPPER that is critical for provisioning, maintenance and repair.

(6/2/12 Updates received from Integra in CAPS) [delete KAREN CLAUSON-INTEGRA PROVIDED A REPAIR EXAMPLE THAT WAS PRIOR TO WHEN QWEST SAID IT WAS USING THE FULL NC/NCI CODE IN ITS ENTIRETY.]

(6/2/12 Updates received from Integra in CAPS) KAREN CLAUSON-INTEGRA ASKED ABOUT THE EXAMPLE INTEGRA PROVIDED ON PAGES 22-23 OF THE MATRIX ROW 33. SHE ASKED ABOUT A REPAIR EXAMPLE WHEN THERE IS INTERFERENCE ON A LOOP THAT WAS INSTALLED 2 YEARS AGO, BEFORE THE AMENDMENT, WHEN QWEST INDICATED THE NCI CODES WERE ONLY INFORMATIONAL. WILL THERE BE TIMES WHEN QWEST WILL INDICATE THAT THERE IS NO BINDER GROUP AVAILABLE FOR THE EMBEDDED BASE CIRCUITS?

Jamal Boudhaouia-Qwest said again, on the embedded base, in the past, issues have been taken care of to keep the customer going. If (6/2/12 Updates received from PAETEC in CAPS) [delete QWEST DETERMINES] there was an interference issue (6/2/12 Updates received from Integra in CAPS) BASED ON BINDER GROUP AND CABLE LOOP PLANT, then Qwest would look at the NC/NCI code in its entirety, even FOR THE EMBEDDED BASE AND EVEN when Qwest said in the past that it was informational only. JAMAL SAID QWEST WOULD LOOK AT IT; THE CODES ARE PROVIDED TO QWEST. Jamal said that is how they KNEW THE CODE WAS NOT THE RIGHT ONE AND identified problems in PAETEC.

Karen Clauson - Integra (6/2/12 Updates received from Integra in CAPS) ASKED WHETHER THE ANSWER TO HER QUESTION WAS NO (THERE WILL NOT BE TIMES WHEN QWEST WILL INDICATE THAT THERE IS NO BINDER GROUP AVAILABLE FOR THE EMBEDDED BASE). SHE requested confirmation that NC/NCI codes would not be TREATED AS informational ONLY going forward and that, for the embedded base, Qwest would make it work TO WHAT WAS DEPLOYED.

Jamal Boudhaouia-Qwest said yes, (6/2/12 Updates received from Integra in CAPS) IF IT HAS BEEN WORKING, WE WILL MAKE IT WORK GOING FORWARD. HE [delete BUT] said there may be the situation when the binder group separation was not working, that Qwest has fixed the problem in the past, AND THAT QWEST WILL REINFORCE CABLE OR PLOW THE GROUND AND PUT DOWN NEW CABLE.

Julia Redman Carter- PAETEC questioned what would happen if there is no binder group available and that reinforcing the ground cable would not fix it, what would happen (6/2/12 Updates received from Integra in CAPS) TO MY LINE.

Jamal Boudhaouia – Qwest said that, for the embedded base in the past, it would always be taken care of, including reinforcing the cable, and that is true going forward. Jamal said, for new installs, there may be instances (6/2/12 Updates received from Integra in CAPS) [delete WHERE THERE IS NO PLANT AVAILABLE] WHEN NO LOOPS MEET REQUIREMENTS. WHEN NO PLANT IS AVAILABLE, The customer has options – CRUNEC or cancel the order. QWEST WILL DO EVERYTHING IT CAN TO KEEP THE EMBEDDED BASE WORKING.

Julia Redman Carter- PAETEC (6/2/12 Updates received from Integra in CAPS) [delete CONFIRMED] ASKED, if there is no binder group available on an embedded base, Qwest will reinforce the cable AT QWEST’S COST but, on new customers, the option is to cancel the order or pay?

(6/2/12 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA – QWEST SAID YES.

(6/2/12 Updates received from Integra in CAPS) JULIA REDMAN CARTER- PAETEC ASKED - FOR NEW?

(6/2/12 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA – QWEST SAID IT IS THE EXISTING PROCESSES.

(6/2/12 Updates received from Integra in CAPS) Karen Clauson-Integra questioned what it means GOING FORWARD IF [delete WHEN] no binder group separation [delete WOULD BE] IS available?

(6/2/12 Updates received from Integra in CAPS) Jamal Boudhaouia-Qwest said what he meant was that, IF Qwest cannot find a pair THAT WOULD MEET NC/NCIS, EVEN IF QWEST MOVED OR REARRANGED TO GET A PAIR, THERE IS NO WAY OF PUTTING DIFFERENT SERVICES IN DIFFERENT BINDER GROUPS AND, based on binder group separation, QWEST [delete AND] would rearrange the cable if no pair was available.

(6/2/12 Updates received from Integra in CAPS) Karen Clauson-Integra referred to MATRIX Row 33 and the cited the Federal rule REGARDING KNOWN DISTURBERS and SAID THEY ARE TRYING TO FIGURE OUT HOW THIS FITS AND HOW QWEST COULD REARRANGE TO MAKE THE SERVICE AVAILABLE BECAUSE QWEST said that Qwest will look to make a loop available.

(6/2/12 Updates received from Integra in CAPS) Jamal Boudhaouia-Qwest said there is no reservation of ANY binder groups FOR ANY TYPE OF SERVICE IN FUTURE.[delete OR FACILITIES FOR ANYONE GOING FORWARD.]

(6/2/12 Updates received from Integra in CAPS) Karen Clauson-Integra REFERRED TO JAMAL’S REFERENCE TO LFACS AND said THAT, in the Facility Assignment process, the [delete CUSTOMER] CLEC does not know what binder group they are in, and SHE referenced the MATRIX Row 0 [delete FOOTER] FOOTNOTE 4. Karen said AT&T gives the information about [delete INTERFERENCE] INTERFERERS IN THE LOOP QUALIFICATION, and CLECs can see the information. [delete AND] She said Carriers would be better able to make decisions on what to do. SHE SAID THERE ARE FCC RULES REGARDING SHARING INFORMATION, AND THE ILEC MUST PROVIDE ON THE NUMBER OF LOOPS USING ADVANCED SERVICES WITHIN THE BINDER AND THE TYPE OF TECHNOLOGY DEPLOYED ON THOSE LOOPS. KAREN SAID IT DOES SEEM THAT, IF THAT INFORMATION WAS AVAILABLE, THAT QWEST COULD FIGURE OUT WHAT TO DO and [delete WONDERED] ASKED how Qwest [delete WOULD MAKE] MAKES that information available.

(6/2/12 Updates received from Integra in CAPS) Jamal Boudhaouia-Qwest said LFACs does not have the information available today via IMA or the download process. JAMAL SAID IT DOES TELL YOU IF THERE IS A DSLAM. IF THERE IS A SPECTRUM MANAGEMENT ISSUE, TO FIND OUT WHAT IS RUNNING, QWEST CAN CHECK TO ID THAT, IN MOST CASES, BECAUSE OF REMOTE DSL DEPLOYMENT, TELLS YOU THAT INFORMATION – ALL OF THE SERVICES RUNNING ON THE BINDER GROUP. Jamal said he would check to see how to make that information is made available to the CLECs to identify all of the advanced services that are running on a binder group.

(6/2/12 Updates received from Integra in CAPS) Karen Clauson-Integra said, IF YOU COULD TAKE THAT BACK, that would be good as [delete SHE THOUGHT THE] CLECs have a right to KNOW WHAT PROCESS TO USE TO ACCESS that information as to what is running on a particular binder group. She said she did not know if Qwest is investigating whether to put that information IN RAW LOOP DATA [delete ON LOOP MAKEUP] .

(6/2/12 Updates received from Integra in CAPS) Jamal Boudhaouia-Qwest said he would but that there may be an issue with CONFIDENTIAL INFORMATION, BUT COULD NOT THINK OF THE NAME (LATER SAID Carrier Identification information).

(6/2/12 Updates received from Integra in CAPS) Karen Clauson-Integra suggested JAMAL [delete IT] may be REFERRING TO [delete A] CPNI,[delete ISSUE] and that providing the information [delete WOULD] MAY have to occur in a method that could not be identified [delete TO THE] BY SPECIFIC CARRIER [delete CARRIERS].

(6/2/12 Updates received from Integra in CAPS) Kim Isaacs – Integra said that, since LFACs does not have the information about disturbers or interferers when assigning xDSL facilities, IS QWEST MAKING ASSUMPTIONS ABOUT THE NUMBER OF INTERFERORS OR DISTURBERS, SUCH AS IN EML, BECAUSE somewhere assumptions have to be made.

(6/2/12 Updates received from Integra in CAPS) Jamal Boudhaouia-Qwest said THAT, in the assignment process, Qwest does not make any assumptions - logically or physically – FOR QWEST OR CLECS. He SAID LFACS USES AN ALGORITHM DERIVED FROM THE NC/NCI CODES AND there are no assumptions during the assignment process either for the loop qual or LFACS.

(6/2/12 Updates received from Integra in CAPS) Mike McCarthy - MN DOC questioned whether the NC/NCI CODE COMBINATION [delete INFORMATION] INFORMATION ASSOCIATED WITH THE SPECTRUM MANAGEMENT CLASSES in the T1 417 document Clause 5 was the BUNDLE OF parameter information that Jamal was referring to?

(6/2/12 Updates received from Integra in CAPS) Jamal Boudhaouia-Qwest said it was that and that THE Spectrum Management CLASS DEFINES [delete CLASSES ARE DEFINED WITH] the technical parameters associated with A [delete THE] flavor of [delete DSL] xDSL.

(6/2/12 Updates received from Integra in CAPS) Kim Isaacs – Integra questioned whether Clause 5 addresses disturbers OR INTERFERORS. SHE ASKED, IF YOU ASSUME A CERTAIN AMOUNT OF [delete AND] interferers, DOES IT CHANGE [delete DO SPECTRUM MANAGEMENT PARAMETERS ADDRESS] the measurements?

(6/2/12 Updates received from Integra in CAPS) Jamal Boudhaouia-Qwest said no Clause 5 does not talk about interferers, it talks about the technical parameters OF EACH CLASS. [delete BASED ON THE] The NC/NCI codes [delete THAT] are applied by the industry for each class of spectrum management.

Greg Doyle – MN DOC questioned, when doing a new install and spectrum management as Qwest plans to do going forward, (6/2/12 Updates received from Integra in CAPS) [delete GREG SAID] can we assume that there will never be interference in the embedded base going forward.

Jamal Boudhaouia – Qwest said we can never say never but it would rarely happen.

Karen Clauson-Integra (6/2/12 Updates received from Integra in CAPS) SAID, [delete IDENTIFIED] if the embedded base at Qwest is in a different configuration, [delete THAN] when looking at the NC/NCI going forward, a new install in a binder group [delete WOULD] COULD result in a big clash between new installs and the embedded base, BECAUSE QWEST DID NOT LOOK AT THE NC/NCI CODES IN THE PAST. IF QWEST HAD BEEN PERFORMING SPECTRUM MANAGEMENT IN THE PAST, QWEST COULD INSTALL THE LOOP NOW. She said the purpose of the Amendment was to reduce problems and not to increase the number of rejections. It is to be proactively vs. retroactively managed [deleteSO THAT THERE IS NO LOOP AVAILABLE]. THE RESULT CANNOT BE THAT THERE IS NO LOOP AVAILABLE BECAUSE QWEST DID NOT MANAGE SPECTRUM IN THE PAST.

Jamal Boudhaouia-Qwest said he addressed the embedded base before. Going forward, he said they look (6/2/12 Updates received from Integra in CAPS) FOR INTERFERERS. HE SAID QWEST SCANS [delete AT] the entirety of the pairs available to find a copper pair that meets the technical parameters FOR THE NC/NCI CODE. THEY DON’T KNOW IF THERE ARE INTERFERORS. If there is a copper pair that can be assigned, it will be picked, THOUGH QWEST HAS NO IDEA WHAT IS RUNNING ON THAT CABLE. THE TECHNICIAN THEN GOES TO THE FIELD. If the TECHNICIAN IN THE FIELD SAYS IT DOES NOT MEET THE PARAMETERS OR THE CLEC says this pair does not meet the requirements, then Qwest will try to rearrange TO MAKE A LOOP AVAILABLE [delete BASED ON WHAT IS AVAILABLE BUT IT IS UNKNOWN IF THERE IS INTERFERENCE].

Karen Clauson-Integra said her question (6/2/12 Updates received from Integra in CAPS) IS CONSISTENT WITH GREG DOYLE’S QUESTION: [delete IS] when the technician goes to the field and there is an issue, will Qwest try to overcome THE [delete AN] issue by rearranging, AND NOT JUST [delete VS.] saying THERE IS no loop available?

(6/2/12 Updates received from Integra in CAPS) [delete JAMAL BOUDHAOUIA-QWEST SAID YES, THE TECHNICIAN WILL IDENTIFY IF THERE ARE ISSUES AND WILL REQUEST A DIFFERENT PAIR BE ASSIGNED BY REARRANGEMENT BUT JAMAL SAID HE CANNOT BE 100% SURE.]

(6/2/12 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA-QWEST SAID YES, THE TECHNICIAN WILL IDENTIFY IF THERE ARE ISSUES AND WILL REQUEST A DIFFERENT PAIR BE ASSIGNED BY REARRANGEMENT. JAMAL SAID THERE IS A LOT OF ACTIVITY IN THE FIELD, AND QWEST DOES EVERYTHING IT CAN. HE CANNOT SAY IT WILL NEVER HAPPEN THAT QWEST CAN’T BUT IT WOULD BE RARE.

Kim Isaacs – Integra said they have run into those situations and (6/2/12 Updates received from Integra in CAPS) PROVIDED EXAMPLES TO [delete WORKED WITH] QWEST Service Management OF SOMETHING SIMILAR but the problem is avoiding delay for the end user. If the tech knew more up front, it would avoid a dispatch to install a loop that does not meet the parameters and would avoid a C31 jep and escalation.

Jamal Boudhaouia-Qwest said he understood and it is frustrating for him also. He said if there are issues with the field technician, Qwest will take action but (6/2/12 Updates received from Integra in CAPS) THE WORLD IS NOT PERFECT [delete IT WILL NOT BE 100% PERFECT].

Karen Clauson-Integra said Integra is not asking for perfection but (6/2/12 Updates received from Integra in CAPS) IS [delete ARE] looking for things [delete THAT CAN BE DONE TO AVOID] TO REDUCE THE LIKELIHOOD OF errors. WHAT IS QWEST DOING UP FRONT TO MINIMIZE ERROR?

Jamal Boudhaouia-Qwest said the technicians are trained and retrained (6/2/12 Updates received from Integra in CAPS) ON A DAILY BASIS ON HOW TO READ THE ORDER AND to know what to look for.

(6/2/12 Updates received from Integra in CAPS) [delete JULIA REDMAN CARTER- PAETEC SAID SHE NEEDED TO UNDERSTAND ARE THE QWEST TECHNICIANS LOOKING AT POTENTIAL INTERFERERS OR ARE THEY LOOKING FOR THE PARAMETERS OF THE LOOP?]

(6/2/12 Updates received from Integra in CAPS) JULIA REDMAN CARTER- PAETEC SAID THAT YOU KEPT SAYING THE TECHNICIAN WILL CHECK PARAMETERS OF THE LOOP FOR NC/NCI CODES INCLUDING PROTOCOLS. WHAT I AM HEARING IN THE QUESTIONS BUT NOT HEARING YOU SAY IN THE ANSWER, IS ARE THEY IDENTIFYING THE POTENTIAL INTERFERERS OR ARE THEY LOOKING AT THE PARAMETERS OF THELOOP? THE POTENTIAL INTERFERORS FOR PROVIDING THE SERVICE.

Jamal Boudhaouia-Qwest said (6/2/12 Updates received from Integra in CAPS) THAT IS A GOOD QUESTION AND THAT INTERFERENCE IN spectrum management is tied to the NC/NCI code. When the technician goes out in the field, they are looking for two things: 1) to make sure that there are no T1 interferers WHICH GIVE THE MOST HEADACHES and 2) remote DSL deployment . JAMAL SAID THE TECHNICIAN HAS TEST GEAR TO TEST FOR THE PARAMETERS. Jamal said the most important part is to have the [delete CORRECT] NC/NCI codes that go with the class of service.

Mike McCarthy - MN DOC said he wanted to get back to fundamentals. He said he thought (6/2/12 Updates received from Integra in CAPS) HE HEARD Qwest SAY THAT QWEST was going to look TO SEE IF QWEST HAS INFORMATION ON WHAT services ARE running within a binder group. Mike said, from the T1 417 document, to proactively do spectrum management, YOU NEED TO KNOW WHAT services ARE running IN PROXIMITY. He said THAT frequency, signal strength and proximity are what causes CROSS TALK AND interference between signals. HE SAID that if we do not know WHAT SERVICES ARE RUNNING IN PROXIMITY, YOU DON’T KNOW THE PROSPECT FOR CROSS TALK, SO, YOU CANNOT manage THE spectrum.

Jamal Boudhaouia-Qwest said that was absolutely correct and that he will have to investigate. Jamal said he is sure Qwest has the information but that it is not in LFACs. (6/2/12 Updates received from Integra in CAPS) WITHOUT KNOWING WHAT IS RUNNING IN THE BINDER GROUP, WE CAN’T MANAGE SPECTRUM MANAGEMENT, ABSOLUTELY.

(6/2/12 UPDATES RECEIVED FROM INTEGRA IN CAPS) [delete MIKE MCCARTHY – MN DOC ASKED IF QWEST WAS COMMITTING TO BUILD A DATABASE IF THE INFORMATION IS NOT CURRENTLY AVAILABLE TO KNOW WHAT IS IN THE BINDER GROUP TO AVOID SPECTRUM MANAGEMENT PROBLEMS.]

(6/2/12 UPDATES RECEIVED FROM INTEGRA IN CAPS) MIKE MCCARTHY - MN DOC SAID WE ARE BACK TO WHERE WE STARTED. HE ASKED, IF QWEST DOES NOT HAVE THE INFORMATION CURRENTLY, DO I HEAR THAT A DATABASE WILL BE CREATED, SO WE WILL KNOW WHAT IS IN THE BINDER GROUP TO PROACTIVELY MANAGE SPECTRUM AND AVOID SPECTRUM MANAGEMENT PROBLEMS?

Jamal Boudhaouia-Qwest said he could not commit to that (6/2/12 Updates received from Integra in CAPS) NOW and [delete NEEDED] COMMITTED to do some research first.

Mike McCarthy - MN DOC asked if there was a way to do spectrum management without that (6/2/12 Updates received from Integra in CAPS) INFORMATION? [delete INFO.]

Jamal Boudhaouia-Qwest said no.

Mitch Moore-Oregon PUC asked if LFACs (6/2/12 Updates received from Integra in CAPS) [delete HAS] CONTAINS the information as to what services are running over the facility?

Jamal Boudhaouia-Qwest said again that he needed to do some research.

Mitch Moore-Oregon PUC asked if the (6/2/12 Updates received from Integra in CAPS) [delete INFO] INFORMATION delivered to CLECs was different than what Qwest gets.

Jamal Boudhaouia-Qwest said no.

(6/2/12 Updates received from Integra in CAPS) [delete JULIA REDMAN CARTER- PAETEC QUESTIONED WHETHER QWEST KNOWS OR DOES NOT KNOW WHAT IS IN THE EMBEDDED BASE.

(6/2/12 Updates received from Integra in CAPS) JULIA REDMAN CARTER- PAETEC REFERRED TO GREG DOYLE’S EARLIER QUESTION AND PROVIDED AN EXAMPLE. SHE SAID THAT, IN MY EMBEDDED BASE TO THIS POINT UNTIL VERY RECENTLY, QWEST HAS NOT USED NC/NCI CODES. QWEST SAID WE HAD THE “WRONG” CODES, SO THE “CORRECT” INFORMATION IS NOT IN THE BINDER GROUPS. SO, IF YOU BRING IN A NEW SERVICE, IS IT POSSIBLE THAT QWEST WOULD NOT KNOW WHAT IS IN THE EMBEDDED BASE?

Jamal Boudhaouia-Qwest said (6/2/12 Updates received from Integra in CAPS) [delete QWEST KNOWS] YOU AND I HAVE TALKED, AND WE KNOW what is in the embedded base but that he is not sure IN what database [delete IN QWEST] the information is in. [delete AND] HE SAID that is why WE AGREED THAT, IN THE PAST, the NC/NCI codes could be wrong.

Karen Clauson-Integra (6/2/12 Updates received from Integra in CAPS) SAID there are two different questions: 1) does Qwest know what CLECs have on the loop? and 2) does Qwest know and proactively deal with what is in the binder group and what is running in proximity to the CLECs? Jamal is researching what is running in proximity. The other issue is the embedded base issue which has been addressed. Julia Redman Carter- PAETEC said (6/2/12 Updates received from Integra in CAPS) THAT, IF A NEW ORDER COMES IN, AND A LOOP IS NOT AVAILABLE BECAUSE OF INTERFERENCE, HOW DO YOU KNOW WHAT IS ON THE LOOPS AND WHAT IS AVAILABLE? IF YOU DO NOT KNOW WHAT IS IN THE BINDER GROUP, HOW DO YOU KNOW THE NEW ONE WILL NOT INTERFERES? She [delete she] is trying figure out at what point do we know ON NEW when it is available and that it will not interfere with the embedded base.

Jamal Boudhaouia-Qwest said he is researching where the NC/NCI code is available during provisioning not whether the information is available. Jamal said the question is whether Qwest proactively performs spectrum management.

Karen Clauson-Integra questioned if Jamal was researching what codes are in proximity (6/2/12 Updates received from Integra in CAPS) [delete TO KNOW] AND HOW DOES QWEST KNOW what is there within the same binder group OR ADJACENT WITH THE BINDER GROUP.

(6/2/12 Updates received from Integra in CAPS) [delete JAMAL BOUDHAOUIA-QWEST WANTED TO CONFIRM WHETHER THEY ARE ADJACENT TO EACH OTHER WITHIN THE SAME BINDER GROUP.

(6/2/12 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA-QWEST ASKED WHAT YOU MEAN BY ADJACENT – ADJACENT WITHIN THE SAME BINDER GROUP?

Greg Doyle- MN DOC said you can still be in different binder groups but be adjacent to cause interference.

Jamal Boudhaouia-Qwest said (6/2/12 Updates received from Integra in CAPS) YES, CROSS TALK - in the cross box, interference could still appear in the crossbox.

Mike McCarthy - MN DOC asked if it was not just cross box but cables.

Jamal Boudhaouia-Qwest said cable could be made up of 900 pair, 200 pair or could multiple binder groups together.

Karen Clauson-Integra said, in any scenario, in order to add something to the binder group, you need to know what is in there (6/2/12 Updates received from Integra in CAPS) AND WHAT IS ADJACENT.

Jamal Boudhaouia-Qwest said that is correct.

(6/2/12 Updates received from Integra in CAPS) [delete MIKE MCCARTHY – MN DOC SAID TO DO SPECTRUM MANAGEMENT BY DEFINITION, PARTICIPANTS NEED TO READ THE FULL CLAUSE 5 OF T1 417. TO DO SPECTRUM MANAGEMENT MEANS MINIMIZING CROSS TALK BUT WITHOUT THE INFORMATION, SPECTRUM MANAGEMENT CANNOT BE PERFORMED. MIKE ASKED IF QWEST WAS COMMITTING TO DO THAT. QWEST HAS COMMITTED TO DO SPECTRUM MANAGEMENT AND THE INFORMATION IS NECESSARY TO DO THAT THEN QWEST IS GOING TO MAKE THE INFORMATION AVAILABLE AND USEFUL. MIKE ASKED IF IT IS CORRECT THAT QWEST IS COMMITTING TO DEVELOP THIS INFORMATION. ]

(6/2/12 Updates received from Integra in CAPS) MIKE MCCARTHY - MN DOC SAID THAT, WHAT I AM HEARING, IS THAT TO DO SPECTRUM MANAGEMENT, BY DEFINITION, PARTICIPANTS NEED TO READ THE FULL CLAUSE 5 OF T1 417. SPECTRUM MANAGEMENT APPLIED MEANS MINIMIZING CROSS TALK AND USING THE FREQUENCY SPECTRUM. WITHOUT THE REQUESTED INFORMATION, SPECTRUM MANAGEMENT CANNOT BE PERFORMED. MIKE INDICATED THE INFORMATION IS EITHER NOT CURRENTLY AVAILABLE OR THEY CANNOT GET IT. HE SAID QWEST HAS COMMITTED TO DO SPECTRUM MANAGEMENT, AND THE INFORMATION IS NECESSARY TO DO THAT, AND, IT FOLLOWS THAT QWEST IS GOING TO MAKE THE INFORMATION ACCESSIBLE AND USABLE. IS THERE A WAY THAT YOU CAN EXPLORE HOW THIS WILL GET DONE? MIKE ASKED IF IT IS CORRECT THAT QWEST IS COMMITTING TO DEVELOP THIS INFORMATION.

Jamal Boudhaouia-Qwest said (6/2/12 Updates received from Integra in CAPS) YES. HE SAID the INFORMATION [delete INFO] might be available but that he needs to find out. He said, from the Tech Pub perspective, Qwest can USE THE TECH PUB TO CREATE PROCESSES AND define how it is done.

Mike McCarthy - MN DOC said this is a natural jumping off point for the next conversation.

Susan Lorence - Qwest provided some logistical information in regard to the CMP monthly meeting on May 18 and agreed to send a notice out by the end of the week to identify when the next Tech Pub meeting would be and whether it would be in the Face to Face to cover Conditioning or another Ad hoc meeting.

5/2/11 Ad hoc Meeting Attendees: Julia Redman Carter- PAETEC, Brenda Bloemke-Comcast, Mindy Chapman - Neustar, Bonnie Johnson-Integra, Doug DennEy-Integra, Karen Clauson-Integra, Kim Wagner – Integra; Joyce Pederson - Integra, Kim Isaacs – Integra, Abbey Thyer-Ohly – Earthlink New Edge; Mike McCarthy-Minnesota Department of Commerce, Greg Doyle - Minnesota Department of Commerce, Linda Harmon-Qwest, Mark Coyne-Qwest, Carolyn Hammack-Qwest, Jeff Farra – Qwest; Bob Mohr-Qwest, Mark Nickell – Qwest, Jamal Boudhaouia-Qwest, Cindy Orenstein – Qwest, John Hansen-Qwest, Tobechi Agbim – Qwest, Susan Lorence-Qwest Mark Coyne – Qwest said the objective for the meeting was to complete the review of the Tech Pub 77384 matrix associated with the xDSL Amendment updates. He said during the last meeting, the review had completed about half of the document and that we would start with Row 16. Mark said a meeting for next week has been put on the calendar as a followup in case it is necessary. Karen Clauson –Integra suggested as part of Row 15 and the discussion associated with the definition of Conditioning, that Qwest had changed the proposal and suggested we discuss that before proceeding. Jamal Boudhaouia – Qwest asked if there were any issues with the proposed definition. (5/13/11 Updates received from Integra in CAPS) KAREN CLAUSON –INTEGRA ASKED JAMAL TO READ THE DEFINITION. (5/13/11 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA –QWEST SAID HE WAS NOT AT HIS DESK AND ASKED SUSAN FROM QWEST IF SHE HAD IT. JAMAL STATED HE THOUGHT HE ADDED A COUPLE OF WORDS WHEN IT IS PROVISIONED IT WILL BE FREE OF THOSE. Susan Lorence – Qwest read the definition that Qwest proposed in an email from the CMPCR mailbox on 4/28/11 to be included in Section 1.6 and 3.8.3 of the Tech Pub: At the time of Provisioning, these facilities shall be free of faults and of devices that could diminish the capability of the loop to provide the xDSL Service as indicated by the NC/NCI code combination. Qwest has responsibilities to provision the best available loop based on the NC/NCI code combination requested by the CLEC.

Karen Clauson – Integra said she would respond to the email. Qwest had added the wording “at time of provisioning” because of the embedded base and that she does not think that it does it. The definition is for all copper loops whether they ask for conditioning and repair. Jamal Boudhaouia – Qwest requested clarification. (5/13/11 Updates received from Integra in CAPS) He said the SENTENCE (remove FCC DEFINITION) does not address removal of conditioning or load coil and QWEST WILL DO THAT BASED ON YOUR INSTRUCTION. [remove THAT IS UP TO THE CUSTOMER. QWEST HAS NOT TAKEN THAT CAPABILITY AWAY TO REQUEST CONDITIONING]. Karen Clauson - Integra said (5/13/11 Updates received from Integra in CAPS) THAT SOME ARE MORE GENERAL BUT the definition is repeated in several places and that there should be one definition within the document. She said the FCC definition does not vary depending on when conditioning occurs and what varies is under the amendment and refers to the last piece that references the NC/NCI. If there is a definition of conditioning that reflects the FCC version and Qwest should not add “at time of provisioning.” Karen said in regard to the second sentence, that is separate and Qwest has the responsibility to assign facilities on the best available loop. Jamal Boudhaouia – Qwest said that is correct in provisioning terms and there is a link to specific product PCATs based on NC/NCI. Jamal said the Tech Pub is for additional technical parameters and that Qwest (5/13/11 Updates received from Integra in CAPS) NEEDS TO KNOW WHAT TO (remove WOULD NOT KNOW WHAT TO) condition TO [remove UNLESS THE NC/NCI IS AVAILABLE]. Karen Clauson - Integra said (5/13/11 Updates received from Integra in CAPS) SHE WAS GLAD TO HEAR THAT AND THAT IS WHAT WE HAVE BEEN SAYING FOR A LONG TIME. SHE SAID if new, there is no embedded base and Qwest would look at the NC/NCI on the order. If it is embedded based in a repair situation, Qwest would look at WHAT WAS [remove THE NC/NCI ON THE] deployed loop. Jamal Boudhaouia – Qwest agreed and that the NC/NCI controls the transactions. Karen Clauson - Integra said (5/13/11 Updates received from Integra in CAPS) YOU CANNOT LOOK AT IT IN A VACUUM AND she agreed with that at a high level. Karen said Qwest should look at what is deployed on the loop and whether it synchs up with what should be there per NC/NCI code. (5/13/11 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA – QWEST AGREED (5/13/11 Updates received from Integra in CAPS) Karen CLAUSON – INTEGRA said that there are lots of caveats and if looking at the Amendment, look at all factors. Karen asked, in regard to the embedded base, what was the decision on whether to include it in the Tech Pub. Jamal Boudhaouia – (5/13/11 Updates received from Integra in CAPS) Qwest SAID WE ALL AGREE [remove WANTED CONFIRMATION] that regardless of scenario – provisioning or repair or maintenance, that the correct NC/NCI controls – not what is in the system. Julia Redman-Carter - PAETEC requested clarification and said she thought the statement is correct as (5/13/11 Updates received from PAETEC and Integra in CAPS) TO IMPLEMENTATION [removed OUTLINED] in the Amendment. Jamal Boudhaouia – Qwest said (5/13/11 Updates received from Integra in CAPS) QWEST WILL ABIDE if conditioning – regardless of the perspective, the NC/NCI must be taken into consideration when provisioning or repair. HE SAID IF WE DON’T HAVE THAT AGREEMENT WE CANNOT OPERATE. Julia Redman-Carter - PAETEC said that she may not disagree (5/13/11 Updates received from PAETEC in CAPS) THAT THE NC/NCI MUST BE CONSIDERED, but that the definition LIMITED TO PROVISIONING is too narrow and too short. Julia said if JAMAL’S INTENT [delete IT] does NO [remove NOT] conflict with the Amendment LANGUAGE, then it appears WE SHOULD REACH AGREEMENT ON THE [remove THERE IS AGREEMENT] AMENDMENT LANGUAGE. Jamal Boudhaouia – Qwest said if there are caveats, Qwest cannot deliver and must have agreement that the NC/NCI controls. Jamal said based on engineering, provisioning and maintenance principles, regardless of what is in records, he has to have agreement that the NC/NCI codes control. Julia Redman-Carter - PAETEC said (5/13/11 Updates received from PAETEC in CAPS) IT [remove IF] feels like Qwest is trying to renegotiate THE AMENDMENT TERMS TO [remove HOW IT WILL] deal with it differently. Jamal Boudhaouia – Qwest said he is not renegotiating but talking the technical specifications and that processes are not in the Tech Pub. (5/13/11 Updates received from Integra in CAPS) JULIA REDMAN-CARTER – PAETEC ASKED SO WHAT ARE WE SAYING THAT IS CAUSING THIS PROBLEM? (5/13/11 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA – QWEST [delete HE] SAID THERE ARE CAVEATS IN THE PROCESSES AND THEY NEED TO BE REMOVED FROM THE TECH PUB based on engineering, provisioning and maintenance principles, regardless, when the embedded based is referred to from a Tech Pub perspective, the correct NC/NCI is the controlling parameter for Qwest to provide what is asked for. Julia Redman-Carter - PAETEC asked how “correct” is defined. Karen Clauson - Integra said (5/13/11 Updates received from Integra in CAPS) SHE AGREES there is no need to introduce ambiguity and that she disagreed AND IT WAS NOT [remove TALKING] only process. THE AMENDMENT LAYS IT OUT. Technical people must understand what to look at. She said for provisioning, the correct NC/NCI is on the order. For the embedded base, it was the NC/NCI deployed on the loop and that Qwest agreed to repair to what is on the loop. If that is not properly reflected in the Tech Pub, that causes confusion. Karen said now that Qwest moved from “unsuitable” to reflect the Federal rule, this part is not so difficult to separate out. If Qwest does not do that, there is big question ABOUT what JAMAL MEANS BY [remove IS] correct. Karen said THE FIRST CLAUSE IS ABOUT PROVISIONING it needs to be explained to the technician the difference on where to look for the NC/NCI code. Jamal Boudhaouia – Qwest suggested to split this in two places (5/13/11 Updates received from Integra in CAPS)THE NC/NCI CODE AS REQUESTED ON NEW ORDERS AND THE SERVICE DEPLOYED ON THE LOOP and would write out the definition. Karen Clauson - Integra said she sees where it is going and that it needs a little work on the language. (5/13/11 Updates received from Integra in CAPS) SHE SAID IT MAKES IT SEEM LIKE A CHOICE BUT IT IS ALREADY THERE. Karen questioned what the objective was to TRY TO FIGURE OUT AND USE A DEFINITION OF EMBEDDED BASE (remove DEFINE) it the way Qwest was. Jamal Boudhaouia – Qwest said (5/13/11 Updates received from Integra in CAPS) NO, NO OBJECTION we have to agree on the NC/NCI CODES AND use of the terms and that we need to find a common ground to move forward if one, deploy new and two, repair so there is no objection. Karen Clauson - Integra said the common ground is already laid out in Section 9.2.2.3.5.5 and that the language should mirror that. Karen said it was helpful to understand the Qwest position and that there is no objection to using the term embedded base. Karen said she will respond to the email and Qwest can then reply. Julia Redman-Carter - PAETEC said she agrees with Integra position (5/13/11 Updates received from PAETEC in CAPS) ESPOUSED THROUGHOUT THE MEETING unless otherwise SPECIFICALLY noted. Karen Clauson - Integra said in regard to Row 16, Qwest agreed there is a need for a consistency review. Jamal Boudhaouia – Qwest said he thought all references had been caught but please look also. NOTE: An updated matrix dated May 9, 2011 is an attachment along with these meeting minutes. The matrix has also been posted to the Wholesale calendar at http://wholesalecalendar.qwestapps.com/detail/323/2011-05-11. The matrix includes columns that show the March 14, 2011 CLEC Comments, the April 4, 2011 Qwest Response, both the April 11 and April 14, 2011 CLEC reply, an April 19, 2011 Qwest Response and a May 9, 2011 Qwest response. The updated matrix captures the key points of discussion in the April 13, 2011 and May 2, 2011 Ad hoc calls and also what Qwest has subsequently reviewed and responded to following the Ad hoc calls. The matrix is being used to capture discussion in conjunction with these meeting minutes. Karen Clauson - Integra said in regard to Row 17, Qwest agreed to do a synch up. For Row 18, Qwest agreed to insert the xDSL definition (5/13/11 Updates received from Integra in CAPS) IN 6.1 and that she thought Digital Subscriber Loop would also be added. Jamal Boudhaouia – Qwest said (5/13/11 Updates received from Integra in CAPS) HE ADDED IT TO THE END OF 6.1 AND would look at the Amendment and Tech Pub and that the DSL definition would be added in Section 1.1. Jamal confirmed if something was in Section 1.1, it applied everywhere. (5/13/11 Updates received from Integra in CAPS) KAREN CLAUSON - INTEGRA SAID SHE DID NOT SEE IT. (5/13/11 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA – QWEST SAID WE DID NOT TALK ABOUT ROW 18. Karen Clauson - Integra questioned (5/13/11 Updates received from Integra in CAPS) IF IT WAS ADDED TO Section 1.1 and THAT IT APPLIES THROUGHOUT THE AGREEMENT AND said that the list of RDSL, GHDSL, etc. are different in the Tech Pub and it is a partial list of what is in the Amendment and asked why. Jamal Boudhaouia – Qwest said (5/13/11 Updates received from Integra in CAPS) HE TRIED TO CAPTURE IT AND the list was not to be exhaustive to include every type of service AND THIS WAS THE INTRODUCTION SECTION but that it was intended to catch some within the technical parameters/standards so it would not have to be updated every time there was new technology. Karen Clauson - Integra said she agreed it was not exhaustive nor is the Amendment and recognizes the Amendment does not change with successive technologies. Karen said there are some that are missing (5/13/11 Updates received from Integra in CAPS) AND SECTION 1.1 COVERS WHAT WE ARE DEALING WITH TODAY. SINCE WE ARE REFLECTING THE AMENDMENT IT SHOULD HAVE GSDSL AND ASKED IF SHE MISSED IT. (5/13/11 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA – QWEST SAID NO. (5/13/11 Updates received from Integra in CAPS) KAREN CLAUSON – INTEGRA SAID WE MIGHT MISS IT IF IT IS NOT ADDED AND ASKED IF HE WANTED TO ADD IT. Jamal Boudhaouia – Qwest said (5/13/11 Updates received from Integra in CAPS) IF THAT IS A CONCERN he would add all definitions from the Amendment. Karen Clauson - Integra said (5/13/11 Updates received from Integra in CAPS) QWEST MODIFIED THE 4TH PARAGRAPH OF 6.1 AND IN THE APRIL 11TH COMMENTS for Row 19, she agrees with the deletion but all questions have not been answered and asked if it is dealt with separately if it does not apply. She said QWEST CHANGED THE PREAPPROVAL OF CONDITIONING the language has been in the Tech Pub for awhile and deals with if the loop is not available. Jamal Boudhaouia – Qwest said if there is no loop, it does not apply; that it applies to the physical loop. (5/13/11 Updates received from Integra in CAPS) KAREN CLAUSON – INTEGRA QUESTIONED IF THERE WAS NO PLACE IN THE TECH PUB THAT DEALS WITH WHEN NO LOOP IS AVAILABLE? (5/13/11 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA – QWEST SAID NOT IF THE LOOP DOES NOT EXIST. IF THE LOOP DOESN’T EXIST WE CAN’T APPLY THE PARAMETERS. (5/13/11 Updates received from Integra in CAPS) KAREN CLAUSON – INTEGRA ASKED IF IT WAS IN THE TECH PUB BEFORE AND WAS MOVED SOMEWHERE ELSE. (5/13/11 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA – QWESTSAID it was not moved to somewhere else and that current processes and language apply. Julia Redman-Carter - PAETEC requested clarification that the Tech Pub applies only if a loop is available. Jamal Boudhaouia – Qwest said if the loop is available, then Qwest will apply NC/NCI codes. If loop is already installed, Qwest will go back to correct NC/NCI codes to (5/13/11 Updates received from Integra and PAETEC in CAPS) SEE WHAT LEVEL TO TEST TO [remove REMOVE]. Julia Redman-Carter - PAETEC said that was the point; (5/13/11 Updates received from Integra and PAETEC in CAPS) AND WHAT SHE HEARD WAS THAT conditioning is not an issue if there never was a loop available. Julia suggested adding language “if applicable.” (5/13/11 Updates received from PAETEC and Integra in CAPS) JAMAL BOUDHAOUIA – QWEST SAID THAT IS RIGHT. (5/13/11 Updates received from Integra and PAETEC in CAPS) JULIA REDMAN-CARTER – PAETEC SAID WE MIGHT WANT TO CLARIFY AT THE BEGINNING OF THE TECH PUB IF NO LOOP IS AVAILABLE THIS DOES NOT APPLY. Jamal Boudhaouia – Qwest said (5/13/11 Updates received from Integra in CAPS) HE CANNOT WRAP HIS HEAD AROUND IT AND suggested Julia propose some language. Karen Clauson - Integra said Qwest can look at the proposed 4/11 language and read the wording in Section 9.2.2.3.5.1.4.1.1 related to manual steps if there are no loops that meet the criteria. (5/13/11 Updates received from Integra in CAPS) JAMAL WHAT YOU’RE SAYING IS YOU ARE NOT LOOKING TO THE TECH PUB TO VALIDATE? Jamal Boudhaouia – Qwest said that is correct. Kim Isaacs - Integra and Bonnie Johnson – Integra did not agree. Bonnie Johnson – Integra said the situation could be there was no loop because it did not meet the parameters. Jamal Boudhaouia – Qwest said to insure facilities are available, Qwest must look up 1) is loop available, 2) apply algorithm to meet parameters. Jamal said the Tech Pub is not invoked at this point. Bonnie Johnson – Integra said they have several where the Qwest records are wrong. (5/13/11 Updates received from Integra in CAPS) AND ONCE IT IS SENT TO THE TECHNICIAN THEY FIND OUT THERE IS NO LOOP. Jamal Boudhaouia – Qwest said that is correct, sometimes the Qwest records are wrong. LFACs says there are facilities but (5/13/11 Updates received from Integra in CAPS) THEN QWEST LOOKS AT THE XBOX AND TERMINAL AND there really are no facilities, Qwest CANNOT [remove WILL NOT] perform the test on a non-existent loop. Kim Isaacs – Integra said to provide the best available loop, (5/13/11 Updates received from Integra in CAPS) QWEST lookS at the NC/NCI to provision and that is what the NC/NCI is for. Karen Clauson - Integra said (5/13/11 Updates received from Integra in CAPS) LOOK AT THE DEFINITION IN 4.0 OF [remove IT IS] the best available pair with the least amount of conditioning. She said a statement should be added AND WOULD BE BETTER UP FRONT to say if no loop available, see CLEC ICA on what to do in that situation if [remove THE RECORDS ARE WRONG] NO FACILITIES ARE AVAILABLE. Julia Redman-Carter - PAETEC agreed (5/13/11 Updates received from PAETEC in CAPS) WITH INTEGRA’S PROPOSAL and said she will not send language BASED ON THE INTEGRA’S COUNTER PROPOSAL. (5/13/11 Updates received from Integra and PAETEC in CAPS) JAMAL BOUDHAOUIA – QWEST SAID YES SURE. Karen Clauson - Integra said for Row 20, (5/13/11 Updates received from Integra in CAPS) SORRY I THINK WE INADVERTENTLY MISSED THIS AND Qwest previously agreed to delete, RIGHT? (5/13/11 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA – QWEST SAID YES RIGHT. (5/13/11 Updates received from Integra in CAPS) KAREN CLAUSON -INTEGRA SAID FOR [remove For] Row 21 and the wording “diminished,” Integra will send an email with proposed wording SO THERE IS NO NEED TO GO OVER THIS NOW. For note in Section 6.1 and wording “2 wire or “, Karen questioned where in the Tech Pub it talks about this. (5/13/11 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA – QWEST SAID THE BULLETED ITEMS. Karen (5/13/11 Updates received from Integra in CAPS) CLAUSON- INTEGRA said in the proposal on 4/4, there was no Qwest change and section 6.1.3 was added to refer to what talking about. Jamal Boudhaouia – Qwest said for the last bullet before 6.2, he wanted to understand the reason for the change. (5/13/11 Updates received from Integra in CAPS) KAREN CLAUSON - INTEGRA SAID ARE YOU FOCUSING ON THE PAIRS MAKING UP THE FACILITY. IS THAT THE ISSUE? (5/13/11 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA – QWEST SAID HE WANTED TO KNOW THE PURPOSE OF THE CHANGE. Karen Clauson - Integra said there has been a long (5/13/11 Updates received from Integra in CAPS) HISTORY OF DISPUTES [remove FEUD] on 2W 4W, and at the time, there was no bullet. The question is whether need THE LAST BULLET [remove IT] at all. Jamal Boudhaouia – Qwest said it goes (5/13/11 Updates received from Integra in CAPS) THE HEART OF HOW [remove INTO DESIGN] of loop facility DESIGN. (5/13/11 Updates received from Integra in CAPS) KAREN CLAUSON – INTEGRA ASKED JAMAL TO EXPLAIN. (5/13/11 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA – QWEST SAID YOU EXPLAIN. Karen Clauson – Integra questioned why change the wording at all because there was agreement can have mixed gauges of cable; they may not be identical. Jamal Boudhaouia – Qwest said he has moved away from changing it (5/13/11 Updates received from Integra in CAPS) AND ASKED KAREN WHY SHE CHANGED THE LANGUAGE. (5/13/11 Updates received from Integra in CAPS) KAREN CLAUSON – INTEGRA SAID WHAT SHE SAID AND SHOULD SHE REPEAT IT AND SAID SHE WANTS QWEST’S. Jamal (5/13/11 Updates received from Integra in CAPS) BOUDHAOUIA - QWESTsaid YES AND the repeat column in the matrix was repeated in two other areas. Karen Clauson – Integra said the word “two” was missed inadvertently. Integra added, see previous bullet regarding loop lengths – all loops will have the same makeup including loop lengths. Jamal Boudhaouia – Qwest (5/13/11 Updates received from Integra in CAPS) SAID on the last bullet, is to insure design is loop plant go pair by pair AND THERE IS NO SEPARATION OF 2 WIRES COMPRISING PAIRS. Each two pair OF A 4 PAIR could have different loop makeup which is a basic design. Each two copper wires will always have the same makeup but may have different characteristics. Karen Clauson – Integra said it should say “makeup” instead of loop transmission. Jamal Boudhaouia – Qwest said 2 wire/one pair will have the same basic makeup. They will always be the same, they cannot be separated. No telecom provider separates them. (5/13/11 Updates received from Integra in CAPS) KAREN CLAUSON – INTEGRA ASKED THEY WILL NEVER BE SEPARATE? (5/13/11 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA – QWEST SAID NO THEY ARE TWISTED AND YOU CANNOT SEPARATE THEM. Julia Redman-Carter – PAETEC said when (5/13/11 Updates received from PAETEC in CAPS) lookING at the [remove VARIOUS BULLETS,] the second SENTENCE OF THE [remove AND] third bullet [remove S] from the bottom, IT IS [remove ARE] inconsistent with the last bullet. CMP NOTE REPEAT OF ABOVE ENTRY (5/13/11 Updates received from Integra in CAPS on Julia Redman-Carter statement above) Julia Redman-Carter – PAETEC said when look at the SECOND SENTENCE IT SEEMS [delete VARIOUS BULLETS, THE SECOND AND THIRD BULLETS FROM THE BOTTOM ARE] inconsistent with the last bullet. (5/13/11 Updates received from Integra in CAPS) KAREN CLAUSON – INTEGRA SAID WE ARE TRYING TO ADDRESS INCONSISTENCY; CAN YOU MAKE IT CONSISTENT? (5/13/11 Updates received from Integra in CAPS) JULIA REDMAN-CARTER – PAETEC READ FROM THE MATRIX AND SAID SHE DOES NOT UNDERSTAND WHY IT IS NOT CONSISTENT. Jamal Boudhaouia – Qwest said when Qwest tried to put in practical terms, we have two pairs. In theory, that is good but in practice it might not happen. (5/13/11 Updates received from Integra and PAETEC in CAPS) KAREN CLAUSON – INTEGRA SAID THEN IT IS CHANGING WHAT IS IN THE AMENDMENT. (5/13/11 Updates received from Integra in CAPS) Jamal BOUDHAOUIA – QWEST said he was not part of the amendment negotiationS AND EVEN THOUGH IT MAY HAVE BEEN GOOD INTENTIONS AND QWEST AGREED TO IT [delete BUT] he is trying to APPEAL TO CLECS PRACTICAL SENSE AND define IT in practical terms AND THERE MAY BE TIMES WHEN TWO LOOPS ARE NOT THE SAME. [delete JAMAL SAID SECTION 9.2.2.3.5.1.3.3.1 ADDRESSES THE SITUATION IF THE LOOPS ARE NOT IDENTICAL. CMP NOTE REPEAT OF ABOVE ENTRY (5/13/11 Updates received from PAETEC in CAPS) Jamal BOUDHAOUIA – QWEST said he was not part of the amendment negotiationS AND EVEN THOUGH IT MAY HAVE BEEN GOOD INTENTIONS AND QWEST AGREED TO IT but he is trying to define in practical terms AND THERE MAY BE TIMES WHEN TWO LOOPS ARE NOT THE SAME. Jamal said Section 9.2.2.3.5.1.3.3.1 addresses the situation if the loops are not identical. (5/13/11 Updates received from Integra in CAPS) Karen Clauson – Integra said Carolyn was involved in the Amendment negotiations (5/13/11 Updates received from Integra in CAPS) AND ASKED IF CAROLYN COULD RESPOND. (5/13/11 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA – QWEST SAID SECTION 9.2.2.3.5.1.3.3.1 ADDRESSES THE SITUATION IF THE LOOPS ARE NOT IDENTICAL. (5/13/11 Updates received from Integra in CAPS) KAREN CLAUSON – INTEGRA ASKED IF CAROLYN HANDED THAT TO JAMAL. (5/13/11 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA – QWEST SAID NO IT WAS BOB MOHR. (5/13/11 Updates received from Integra in CAPS) KAREN CLAUSON – INTEGRA SAID THANKS BOB AND JAMAL THAT WAS HELPFUL. (5/13/11 Updates received from Integra in CAPS) Karen CLAUSON – INTEGRA said the negotiation team put in a bullet related to main pair ends in Section 3.3.1 that is not there. To resolve concerns of inconsistency, what if added a bullet. Karen suggested that the last bullet in 6.1 be substituted with last bullet in Section 9.2.2.3.5.1.3.3.1 to care for concerns. (5/13/11 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA – QWEST SAID YES FROM A PRACTICAL STANDPOINT THAT IS WHAT HE WANTS. Julia Redman-Carter – PAETEC (5/13/11 Updates received from PAETEC in CAPS) [remove SAID] ASKED THAT when looking at Section 6.1, the second to last bullet shouldn’t that be deleted. (5/13/11 Updates received from Integra and PAETEC in CAPS) [delete JAMAL BOUDHAOUIA – QWEST SAID THE LAST TWO BULLETS WILL BE REMOVED AND REPLACED WITH THE SECTIONS THAT KAREN READ.] Karen Clauson – Integra said for Row 22, (5/13/11 Updates received from Integra in CAPS) INTEGRA MADE COMMENTS ON 4/11 FOR Section 6.2 associated with Qwest proposal to change the Title, TO ATTACHMENT 3. WE ARE TALKING ABOUT TWO DIFFERENT THINGS, the section goes beyond performance tests IN ATTACHMENT 3 WHICH IS NOT EXHAUSTIVE and it should not be limited to Attachment 3 which lists some of the tests. SO THIS IS WHAT THE PERFORMANCE PARAMETERS ARE AND THE TITLE SHOULD NOT BE THE SAME. Integra does not agree with the Title change; it makes it narrow. Jamal Boudhaouia – Qwest (5/13/11 Updates received from Integra in CAPS) SAID JUST TO BE CLEAR IT SHOULD JUST BE TRANSMISSION PERFORMANCE PARAMETERS? SURE, DONE [remove AGREED TO LEAVE AS TRANSMISSION PERFORMANCE PARAMETERS]. Karen Clauson – Integra said for Row 23, the change is made. Karen said for Row 24 (5/13/11 Updates received from Integra in CAPS) SECTION 6.1 WAS 3RD PARAGRAPH AND NOW IT IS THE 2ND PARAGRAPH, why reference the PCAT WHICH COULD BE CHANGED AND NOT THE AMENDMENT? [remove VS. THE ICA]. Jamal Boudhaouia – Qwest said it (5/13/11 Updates received from Integra and PAETEC in CAPS) [REMOVE IS NOT A PROCESS BUT DOES] not have problem taking it out. (5/13/11 Updates received from Integra in CAPS) KAREN CLAUSON – INTEGRA SAID SHE WANTED IT TO REFER TO THE ICA AND ASKED IF THAT WAS A PROBLEM NOW. (5/13/11 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA – QWEST SAID NO (5/13/11 Updates received from Integra in CAPS) JULIA REDMAN-CARTER – PAETEC ASKED IF THE WHOLE STATEMENT WAS COMING OUT (5/13/11 Updates received from Integra in CAPS) KAREN CLAUSON – INTEGRA READ THE TEXT AND SAID THAT WILL COME OUT RIGHT JAMAL? (5/13/11 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA – QWEST SAID YES. Karen Clauson – Integra said she missed one in Section 6.1 in Row 15 and 16 – April 11 comment, Qwest still using the term non-loaded (5/13/11 Updates received from Integra in CAPS) AND SINCE IT [remove WHICH] is NOT a term USED IN [remove NOT IN] the Amendment SHE ASKED WHAT QWEST PLANS WERE FOR THE USE OF THAT TERM and questioned why it is still used and it is causing concern BECAUSE IT LEADS TO CONFUSION. (5/13/11 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA – QWEST ASKED WHERE? (5/13/11 Updates received from Integra in CAPS) KAREN CLAUSON – INTEGRA SAID DO A SEARCH FOR NON-LOADED. Jamal Boudhaouia – Qwest said (5/13/11 Updates received from Integra in CAPS) THEY COULD SAY A loop facility with out load coils or free of loads, that is all Qwest is trying to convey. Karen Clauson – Integra said (5/13/11 Updates received from Integra in CAPS) THAT IS INTERESTING ANSWER AND she is not convinced that Qwest is NOT USING NON-LOADED TO REFER [remove REFERRING] to XDSL CAPABLE LOOPS [remove THE SAME THING]. Qwest should do search on term non-loaded AND MAKE SURE XDSL AND LOAD COIL ARE THE PROPER TERMINOLOGY [remove USE APPROPRIATE TERM]. She said the terminology is not in the current amendment. Most are in Chapter 3 or 6. CMP NOTE REPEAT OF ABOVE ENTRY Karen Clauson – Integra said (5/13/11 Updates received from PAETEC in CAPS) THAT IS INTERESTING ANSWER AND she is not convinced that Qwest is NOT USING NON-LOADED TO REFER [remove REFERRING] to XDSL CAPABLE LOOPS [remove THE SAME THING]. Qwest should do search on term non-loaded and use appropriate term. She said the terminology is not in the current amendment. Most OCCURENCES APPEAR [remove ARE] in Chapter 3 or 6. Jamal Boudhaouia – Qwest (5/13/11 Updates received from Integra and PAETEC in CAPS) SAID HE WILL CHECK AND MAKE SURE [remove AGREED TO REVIEW]. Karen Clauson – Integra said for Row 25, paragraph on loop length will be discussed at next meeting. (5/13/11 Updates received from Integra in CAPS) IT GOES BACK TO the question ABOVE WHICH is whether it will be applied to all or only to those that sign the amendment. Jamal Boudhaouia – Qwest said loop length is not n Table 6.1., it is gone. (5/13/11 Updates received from Integra in CAPS) KAREN CLAUSON – INTEGRA SAID THE COMMENT GOES TO A FORMER DRAFT SO MAYBE IT IS OUT. (5/13/11 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA – QWEST SAID THE LENGTHS REFERRED TO IN 6.1 ARE BRIDGED TAP AND NOT LOOP. Karen Clauson – Integra (5/13/11 Updates received from Integra in CAPS) SAID KIM ISAACS HAS A GOOD QUESTION [remove QUESTIONED] AND KIM ASKED whether AML and EML will apply to CLECs with no Amendment? Jamal Boudhaouia – Qwest said (5/13/11 Updates received from Integra in CAPS) NO it will not apply to them, only test parameters will be shown. Karen Clauson – Integra questioned if that was clear in the Tech Pub. Jamal Boudhaouia – Qwest questioned whether that needed to be in the Tech Pub. Karen Clauson – Integra said it (5/13/11 Updates received from Integra in CAPS) SEEMS TO ME THAT THESE WILL BE WHAT IS PERFORMED WITH THESE TERMS AND WILL DO TESTING AND IT SHOULD BE CLEAR [remove HAS TO BE TO CLARIFY] UP FRONT what will be done or not done if the Amendment is not signed. Jamal Boudhaouia – Qwest said he would propose language. (5/13/11 Updates received from Integra in CAPS) KAREN CLAUSON – INTEGRA SAID THANKS WE WILL LOOK AT THAT. (5/13/11 Updates received from Integra in CAPS) MARK COYNE QWEST SAID HE WAS DOING A QUICK CHECK ON TIME AND WE HAVE A ½ HOUR LEFT. Karen Clauson – Integra said Row 26 is a synch up; Row 27 will have language proposed, Row 28 will have the same issue, same changes related to non – loaded. (5/13/11 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA – QWEST SAID COULD DIMINISH YES. (5/13/11 Updates received from Integra in CAPS) KAREN CLAUSON – INTEGRA SAID for Row 29, Qwest is offering to change THE SECOND PARAGRAPH IN 6.4 IN THE TECH PUB, RIGHT? (5/13/11 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA – QWEST SAID YES. (5/13/11 Updates received from Integra in CAPS) KAREN CLAUSON – INTEGRA SAID [delete BUT] Integra does not agree with changes. In Section 6.4, the first sentence is related to discussion around “could diminish” wording. Karen said in regard to a process not being in a Tech Pub, this is legal wording that does not belong in the Tech Pub and both sentences should be stricken. Jamal Boudhaouia – Qwest agreed. Karen Clauson – Integra said for Row 30, there is agreement to synch up. Row 31, there (5/13/11 Updates received from Integra in CAPS) ARE TWO ISSUES. THE COULD DIMINISH AND THE [remove IS A QUESTION RE] bullets; Row 32 same issue/same change as Section 6.5. (5/13/11 Updates received from Integra in CAPS)JAMAL BOUDHAOUIA – QWEST SAID YES. (5/13/11 Updates received from Integra in CAPS)KAREN CLAUSON – INTEGRA SAID ROW 33 IS SPECTRUM MANAGEMENT. QWEST MODIFIED 6.5 AND I ASKED QWEST TO DELETE THE PARAGRAPH. Jamal Boudhaouia – Qwest said in regard to Row 33, the language going forward will be removed. Jamal said in the network, Qwest cannot guarantee that there will not be other services in the binder group or in cable. (5/13/11 Updates received from Integra in CAPS). THE CABLE PLANT IS WHAT IT IS IN THERE AND THERE ARE ALWAYS T1’S, THERE ARE MULTIPLE SERVICES RUNNING AND QWEST CANNOT GUARANTEE THERE WILL NOT BE OTHER SERVICES IN THE CABLE. Julia Redman-Carter – PAETEC questioned if Jamal was stating that if there is a service provisioned that is in a binder group that interferes, that Qwest won’t remove (5/13/11 Updates received from Integra and PAETEC in CAPS) OR ADJUST it? Jamal Boudhaouia – Qwest said he is not saying that but what is in loop plant (5/13/11 Updates received from Integra and PAETEC in CAPS) IS WHAT’S THERE AND could have interference. QWEST CANNOT GUARANTEE THERE IS NO INTERFERENCE UNTIL Qwest [remove WOULD HAVE TO] look[S] at cable plant. Karen Clauson – Integra said the big answer to be explained (5/13/11 Updates received from Integra in CAPS) BY A DELETION AND EITHER DELETE THE SENTENCE OR MODIFY TO EXPRESS CONTEXT. WHEN WE [remove IS TO] talk about Spectrum Management going forward and whether ADSL and xDSL be put in same OR ADJACENT binder group[S] going forward will interfere. Jamal Boudhaouia – Qwest said the discussion will take a long time. All (5/13/11 Updates received from Integra in CAPS) XDSL are powered from the CO and they are standard compliant for power interference and spectrum management. These will not have interference. YOU GET INTERFERENCE WHEN YOU HAVE THE SAME DSL SERVICE AND ONE IS RUNNING FORM THE CO AND THE OTHER FROM THE TERMINAL BECAUSE THEY ARE DIFFERENT POWER LEVELS. JAMAL SAID YOU GET THE SAME THING WHEN YOU PUT THE SAME POWER IT CREATES A WAVE AND IT WILL BE BIGGER FROM THE EDGE. Jamal said that is the physics of power.- WHEN IT TRAVELS it loses its strength. CMP NOTE REPEAT OF ABOVE ENTRY Jamal Boudhaouia – Qwest said the discussion will take a long time. All (5/13/11 Updates received from PAETEC in CAPS) XDSL are powered from the CO and they are standard compliant for power interference and spectrum management. These will not have interference. YOU GET INTERFERENCE WHEN YOU HAVE THE SAME DSL SERVICE AND ONE IS RUNNING FORM THE CO AND THE OTHER FROM THE TERMINAL BECAUSE THEY ARE DIFFERENT POWER LEVELS. JAMAL SAID YOU GET THE SAME THING WHEN YOU THROW A STONE IN A LAKE AND IT CREATES A WAVE THAT WILL BE BIGGER FROM THE EDGE. Jamal said that is the physics of power it loses its strength. Karen Clauson – Integra said she tends to disagree. Power will take longer to discuss. (5/13/11 Updates received from Integra in CAPS). POWER IS NOT THE ONLY THING YOU NEED TO CARE ABOUT. THAT IS FOR THE NEXT DISCUSSION. BACK TO WHERE WE LEFT OFF. IF THE PROTOCOL OPTIONS ARE REQUIRED THEN THAT RAISES QUESTIONS AND HOW WILL QWEST USE THEM. WE NEED A DISCUSSION REGARDING [remove THERE IS A NEED TO TAKE] proactive steps QWEST WILL TAKE to manage spectrum IN PARTICULAR HOW THINGS ARE DIFFERENT UNDER THE AMENDMENT [remove AND WHAT IS ADJUSTMENT IN THE BINDER GROUP]. BEFORE THE AMENDMENT NO NC/NCI CODES WERE TAKEN INTO ACCOUNT SINCE THE AMENDMENT THEY ARE TAKEN INTO ACCOUNT. WE WILL GO THROUGH AND FINISH THE REST MINUS 33. (5/13/11 Updates received from Integra in CAPS) MARK COYNE QWEST SAID OK. (5/13/11 Updates received from Integra in CAPS) KAREN CLAUSON – INTEGRA For Row 34, same changes DIMINISH AND BULLET POINTS AND WILL MAKE THAT CHANGE CORRECT? For Row 35, MODIFIED 6.6 will need to come back to as part of THE BIGGER DISCUSSION OF HOW THE AMENDMENT AFFECTS spectrum management. For Row 36, still talking. For Row 37, no TECH PUB language change is required. For Row 38, this is part of umbrella cleanup. Karen Clauson – Integra said we started with Row 15, we need to go back through 1 through 14 to address consistency, spectrum management, non-loaded loop, diminish capability which wording will be sent back by Karen. Mark Coyne – Qwest said the next call will be Wednesday, May 11 for a two hour slot. We will take a portion of the time for spectrum management and a portion for review of conditioning download. Mike McCarthy – Minnesota Dept of Commerce (5/13/11 Updates received from Integra in CAPS) SAID WHEN WE MEET AGAIN CAN WE START OFF WITH THE UNDERSTANDING THAT WE [remove SUGGESTED THE] use of the definition of spectrum management from the ANSI manual, Section 3.1.45, as used throughout Clause 5. (5/13/11 Updates received from Integra in CAPS) KAREN CLAUSON – INTEGRA ASKED IF JAMAL WOULD SEND THAT OUT. Jamal Boudhaouia – Qwest said he would distribute the ANSI definition to the team. [ Per request from Integra on 5-10-11, the following statement was deleted and the document was deleted which was attached. The ANSI definition is posted to the calendar as a separate document which is available at http://wholesalecalendar.qwestapps.com/detail/322/2011-05-02. delete NOTE: The ANSI definition from Jamal is attached.]

4/20/11 Product Process Monthly Meeting Mark Coyne – Qwest said the remaining states of Idaho and Washington went into effect on March 21, 2011. An escalation was received on April 7 associated with Process notice that was sent associated with the related system CR SCR083010-1 that was implemented in IMA during the last release. Mark said the Qwest binding response will be sent out on April 22, 2011. Mark said an ad hoc meeting was held on April 13 and another Ad hoc meeting is scheduled for May 2.

Bonnie Johnson – Integra questioned if Qwest was leaving the system CR open.

Mark Coyne – Qwest said yes.

Bonnie Johnson – Integra requested the review period for the April 13 Ad hoc meeting minutes be extended to the end of day Monday, April 25.

Mark Coyne – Qwest agreed and requested Qwest be given an extra day to send them out.

There were no objections and Mark said the April 13 Ad hoc meeting minutes would be sent out for review by end of day Thursday, April 21 with CLEC response due back at end of day April 25.

4/13/11 Ad hoc Meeting Attendees: Julia Redman Carter- PAETEC, Brenda Bloemke-Comcast, Mindy Chapman - Neustar, Bonnie Johnson-Integra, Doug Denney-Integra, Karen Clauson-Integra, Joyce Pederson - Integra, Kim Isaacs – Integra, Kim Wagner – Integra, Shawn -PAETEC, Chad Alberts - PAETEC, Mitch Moore-Oregon PUC, Kasha Fauscett -Comcast, Jim Hickle-Velocity, Mike McCarthy-Minnesota Department of Commerce, Linda Harmon-Qwest, Rita Urevig – Qwest, Mark Coyne-Qwest, Carolyn Hammack-Qwest, Bob Mohr-Qwest, Mark Nickell – Qwest, Jamal Boudhaouia-Qwest, Cindy Orenstein – Qwest, John Hansen-Qwest, Susan Lorence-Qwest Mark Coyne – Qwest reviewed where the documents for the call could be found and what documents were available. He stated the purpose of the call was not to renegotiate the xDSL Services Amendment but to resolve open points in the documents in relation to the Amendment. He also provided some meeting norms. Susan Lorence - Qwest provided a high level review of the revised Historical timeline that was posted to the CMP calendar. Susan pointed out an addition to the timeline for August 2010 which was the issuance of the Qwest system CR SCR083010-1, Expand the SCA field to allow optional conditioning to be requested, which would mechanize the process of requesting conditioning in IMA. As part of the timeline review, Susan stated that the basis for Qwest to send the Tech Pub updates as a level 2 notification was that there were no process changes with the Tech Pub update; the Tech Pub updates were synching up with the xDSL related documentation that were previously implemented via Level 4 CMP notifications. (4/26/11 Updates received from Integra in CAPS) QWEST SAID THAT IT RECEIVED COMMENTS FROM INTEGRA ON THE LEVEL 2 NOTICE REGARDING MECHANIZING THE SCA FIELD. SUSAN SAID THAT, WHEN QWEST RESPONDED, QWEST SAID THERE WAS AN OVERSIGHT IN DESIGN AND QWEST HAD LEFT OUT A THIRD LEVEL OF CONDITIONING. A SUBSEQUENT ESCALATION WAS RECEIVED FROM INTEGRA, AND FOUR CLECS JOINED – COVAD, CBEYOND, VELOCITY, AND PAETEC. SUSAN SAID QWEST IS IN THE PROCESS OF PUTTING TOGETHER A BINDING RESPONSE. Jamal Boudhaouia – Qwest then began review of the matrix and related Tech Pub updates. Starting with Section 1.1, Jamal said the information included here is general and not specific (4/26/11 Updates received from Integra in CAPS) ON PRODUCTS, AND HE SAID THAT QWEST ADDED THAT THESE ARE EXAMPLES. Jamal said Qwest would follow [ANSI] standards of the ANSI Committee or ANY OTHER other(remove S) STANDARDS COMMITTEES that have a stake in the transport layer. FOR SECTION 1.2, QWEST PROVIDED THE REASON FOR REVISIONS. For Section 1.6, the definition of xDSL Loops was added. Karen Clauson – Integra suggested a more efficient approach would be to respond to CLEC questions as each chapter is reviewed. Jamal Boudhaouia – Qwest agreed to that approach. Mark Coyne – Qwest suggested reviewing the sections where Qwest agreed to first. Karen Clauson - Integra said she would prefer to focus on the points where Qwest did not agree versus where Qwest did agree. She said it would be good to have dialogue but did not want to lose time and wanted to focus on what Jamal was prepared to discuss. Jamal Boudhaouia – Qwest said if there are questions not on the March 14 comments he would have to take that back. Jamal said in addition if there are questions on the 4/11/11 Matrix from Integra that we do not have answers to, he would also take those back. Karen Clauson - Integra then began to review the Integra xDSL Matrix Reply dated 04-11-11. She said she assumes updates in regard to row #1 are cleanup and will be done at the end. Row #2 deals with (4/26/11 Updates received from Integra in CAPS) [remove THOSE] CLECS that don’t have the Amendment. NOTE: An updated matrix dated April 19, 2011 follows these meeting minutes and will be posted to the Wholesale calendar at http://wholesalecalendar.qwestapps.com/detail/320/2011-04-13. The matrix includes columns that show the March 14, 2011 CLEC Comments, the April 4, 2011 Qwest Response, both the April 11 and April 14, 2011 CLEC reply, and an April(4/26/11 Updates received from Integra in CAPS) [remove 19, insert 21], 2011 Qwest Response. [insert footnote] The updated matrix captures the key (4/26/11 Updates received from Integra in CAPS) [remove POINTS OF DISCUSSION IN] ACTION ITEMS FROM the April 13, 2011 Ad hoc call in gray shading provided by Integra and also captures Qwest updates that were agreed to on the call in addition to items that Qwest has subsequently reviewed and responded to IN THE MATRIX following the Ad hoc call. The matrix is being used to capture [remove DISCUSSION] ACTION ITEMS in conjunction with these meeting minutes AND DOES NOT REPLACE MEETING MINUTES. Jamal Boudhaouia – Qwest said in regard to row #2, the only difference between those that sign the Amendment and those that don’t is the ability to see the test results. If a CLEC signs the agreement, they see the test results; those that don’t sign it, don’t see them (4/26/11 Updates received from Integra in CAPS) UNLESS THEY ORDERED COORDINATED INSTALL. Jamal said for efficiency, Qwest has to put a process in place for ALL technicians to be trained the same way. Jamal said Qwest will do 196 kHz testing for those CLECs that did not sign the agreement. If you have coordinated testing, you will see the test results. If you do not, you will not see the test results. See row #2. Also, if a CLEC signed the agreement, they will be able to request conditioning as defined in the agreement2/16/11 Product Process CMP Meeting Mark Coyne – Qwest relayed that the notification to implement the additional states was sent out on January 24, 2011. Qwest submitted its final notification and response to comments on February 11, 2011. On February 14, 2011,Qwest received an escalation from Integra on two issues. That escalation has been posted to the CMP external site and on February 15, a notification was sent out to the entire CLEC community to inform them of the escalation. At this point, Qwest is in the process of developing its response and will be sending it out according to the CMP document. Mark said the rollout of the remaining states related to this change will remain on schedule while we try to resolve these two issues. (4/26/11 Updates received from Integra in CAPS) BONNIE JOHNSONS - INTEGRA ASKED IF QWEST IS SAYING FOR THOSE THAT DO NOT SIGN THE AMENDMENT THEY WON’T SEE THE TEST RESULTS BUT QWEST WILL TEST OR IS QWEST SAYING THEY WILL COMPLETE THE TEST. JAMAL BOUDHAOUIA – JAMAL SAID WE TEST TO 196 KHZ, AND IF YOU SIGN THE AMENDMENT YOU RECEIVE THE TEST RESULTS; IF THE AMENDMENT IS NOT SIGNED, YOU WILL NOT GET THE TEST RESULTS. (4/26/11 Updates received from Integra in CAPS) BONNIE JOHNSON – INTEGRA said so Qwest will test and if the Amendment is signed, the test results are provided. If the Amendment is not signed, the test results are not provided BUT QWEST IS STILL DOING THE TESTING. Jamal Boudhaouia – Qwest said yes and that he was referring to testing not conditioning. Karen Clauson - Integra (4/26/11 Updates received from Integra in CAPS) ASKED WHAT ABOUT TESTING ON REPAIRS? SHE said the Tech Pub deals with both testing and conditioning and asked about other differences if a CLEC does not sign the Amendment. Jamal Boudhaouia – Qwest said the Tech Pub does (4/26/11 Updates received from Integra in CAPS) NOT HAVE DIFFERENCES FOR PROCESS. THOSE ARE IN THE PCAT AND DOWNLOAD; THEY DEFINE REQUIREMENTS. HE SAID THE TECH PUB ADDRESSES WHETHER CAN CARRY A SIGNAL BASED ON NC/NCI CODES AND [remove NOT ADDRESS THE PROCESS BUT] addresses technical capabilities or the physical layer of the loop to the CLEC. Jamal said process is addressed in the PCAT and the Conditioning download. (4/26/11 Updates received from Integra in CAPS) KAREN CLAUSON – INTEGRA ASKED WHETHER WE SHOULD BE EDITING THE TECH PUB AND TAKING OUT ALL PROCESSES. JAMAL BOUDHAOUIA – QWEST STATED THAT THE PHYSICAL PROCESS OF CONDITIONING IS IN THE TECH PUB, WHICH SHOULD MATCH THE ICA. THE PCAT TELLS WHETHER IT IS AVAILABLE.Karen Clauson - Integra asked whether the PCAT and the download (4/26/11 Updates received from Integra in CAPS) SHOULD also MATCH[ remove MEANT] the ICA. Jamal Boudhaouia – Qwest said yes, the PCAT should match the ICA. Karen Clauson - Integra then reviewed (4/26/11 Updates received from Integra in CAPS) MATRIX row #3 and reiterated the request to add more examples and the xDSL definition. Jamal Boudhaouia – Qwest explained that Section 1.1 was for General information only and is to give information of what the Tech Pub is and that this information would be addressed in the relevant Tables in a subsequent section. (4/26/11 Updates received from Integra in CAPS) JAMAL SAID THAT WHEN QWEST UPDATES WITH OTHER FLAVORS THAT ARE INVOLVED OR DEVELOPED, QWEST WILL ADD THEM IN THE RELEVANT TABLE TO INCLUDE THE NC/NCI CODE AND THAT SECTION 1.1 IS AN EXAMPLE ONLY. PARTICULAR TYPES ARE IN THE RELEVANT TABLES, AND THEN QWEST UPDATES THE RELEVANT SECTION. Karen Clauson - Integra said they had not seen the information anywhere else and that it would be important to include in Section 1.1 to cover the general principles and the successive technologies as well. (4/26/11 Updates received from Integra in CAPS) INTEGRA ASKED WHETHER QWEST WILL INCLUDE THE DEFINITION OF DIGITAL SUBSCRIBER LOOP FROM THE AMENDMENT. Jamal Boudhaouia – Qwest requested that Integra send him language and that he would look at it and that he would then look (4/26/11 Updates received from Integra in CAPS) AND, IF APPLICABLE, WILL INCLUDE IT. [remove AT INCLUDING THE DEFINITION IF IT WAS APPLICABLE.] Julia Redman-Carter - PAETEC (4/26/11 Updates received from Integra in CAPS) SAID THAT JAMAL SAID “IF APPLICABLE,” AND questioned [remove WHETHER THERE WAS] WHAT IS THE [remove A] standard for applicability. Jamal Boudhaouia – (4/26/11 Updates received from Integra in CAPS) QWEST SAID IT IS GENERAL, NOT SPECIFIC, SO QWEST NEEDS TO LOOK AT IT. Qwest said a Tech pub is based on national standards. Jamal said he will look at the definition to see if it aligns with a standard DSL definition and if it does, he will include it. Karen Clauson - Integra read the definition from the Amendment (4/26/11 Updates received from Integra in CAPS) [remove THAT WAS LATER EMAILED TO THE QWEST CMPCR MAILBOX]. She requested it be included in the General Section so it could be referred to in later sections AND WOULD NOT NEED TO BE REPEATED EACH TIME. (4/26/11 Updates received from Integra in CAPS) NOTE: INTEGRA SENT THE XDSL AMENDMENT TO THE QWEST CMPCR MAILBOX BY EMAIL DATED APRIL 13, 2011. INTEGRA INDICATED IN THE EMAIL THAT, IF JAMAL DESIRES A COPY OF THE ENTIRE MERGER AGREEMENT, QWEST CAN OBTAIN A COPY FROM CAROLYN HAMMACK AT QWEST, WHO WAS WITH JAMAL ON THE AD HOC CALL THAT DAY, AND WHO WAS PRESENT DURING THE QWEST-CENTURYLINK-INTEGRA NEGOTIATIONS OF THE XDSL AMENDMENT (ATTACHMENT A TO THE MERGER SETTLEMENT AGREEMENT). (4/26/11 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA - QWEST: STATED IT SOUNDS OK TO ME. KAREN CLAUSON – INTEGRA ASKED IF SECTION 1.6 IS PURSUANT TO THE CLEC ICA. JAMAL BOUDHAOUIA – QWEST ANSWERED YES.Karen Clauson - Integra reviewed (4/26/11 Updates received from Integra in CAPS) MATRIX row # 4 which Qwest agreed to update with the final review of the Tech Pub updates and MATRIX row #5 which Qwest agreed to change TO CLEC’S PROPOSED LANGUAGE. Karen then addressed MATRIX row #6. INTEGRA SAID THAT QWEST HAS INTRODUCED A NEW PHRASE -- “RENDER LOOPS UNSUITABLE” -- INSTEAD OF THE FCC DEFINITION LANGUAGE OF “COULD [remove AND] DIMINISH.” INTEGRA proposed Qwest use the FCC definition of conditioning in Chapter 1 which can then be referred to in later sections. Jamal Boudhaouia –(4/26/11 Updates received from Integra in CAPS) [remove QWEST PROVIDED AN EXPLANATION OF THE DIFFERENCE] JAMAL SAID THAT HE WAS PUTTING HIS ENGINEERING HAT ON. HE SAID "COULD DIMINISH" MEANS THE LOOP IS ALREADY INSTALLED AND REFERS TO THE CAPABILITY AS INSTALLED AND THAT THERE IS AN EXISTING CIRCUIT THAT COULD DIMINISH OVER TIME. HE SAID “COULD DIMINISH" DOESN'T ADDRESS WHAT HAPPENS AT INSTALLATION. QWEST SAID that the Tech Pub defines WHAT IS THE CAPABILITY OF THE LOOP FACILITY THAT WE PROVIDE YOU [remove THE PARAMETERS OF THE LOOP TO BE PROVIDED] versus the FCC definition which is the capability of the loop over time. Jamal said the Tech Pub was not intended to address the term “diminishing.” Karen Clauson - Integra said (4/26/11 Updates received from Integra in CAPS) [remove THE] A difference is that the Qwest IS FOCUSING [remove EMPHASIS IS] on the word “diminish” and the CLEC FOCUS [remove EMPHASIS] is on the word “could”. Jamal Boudhaouia – (4/26/11 Updates received from Integra in CAPS) QWEST SAID YOU SHOULD DO THAT BEFORE, IF YOU ORDER CONDITIONING, IF YOU WANT TO ADD REMOVE ALL, YOU CAN ADD REMOVE ALL CONDITIONING ON A LOOP. Qwest said the Tech Pub [remove FOCUSES ON WHAT THE CAPABILITIES ARE OF THE LOOP ORDERED AND PROVISIONED. ] PROVIDES THE DEFINITION OF TECHNICAL PARAMETERS BASED ON WHAT WAS ORDERED. He said he did not know the FCC’s intent; HE IS NOT A LAWYER. THE TECH PUB ADDRESSES ONLY THE CAPABILITIES OF THE COPPER LOOP, THE TECHNICAL PARAMETERS. Karen Clauson - Integra said the Amendment doesn’t define conditioning differently (4/26/11 Updates received from Integra in CAPS) [remove THEN] THAN the FCC. She said (4/26/11 Updates received from Integra in CAPS) THERE IS AN AGREEMENT TO PAY A DIFFERENT RATE [remove AMENDMENT PROVIDES THE NEGOTIATED RATE TO BE USED UNDER DIFFERENT CIRCUMSTANCES.] The Tech Pub and the Amendment both say here is what will occur when performing Conditioning and they need to synch up. Karen said the Qwest language “rendering unsuitable” is a problem and should have been part of negotiation which we are not here to redo. She said the language does not reflect the Amendment and that they cannot agree to it. Jamal Boudhaouia – Qwest said we are talking semantics. (4/26/11 Updates received from Integra in CAPS) QWEST SAID THAT THE PROCESS FOR CONDITIONING IS NOT IN THE TECH PUB. IT IS OUTSIDE THE TECH PUB, IF SIGNATORY TO THE AMENDMENT TO GET THE BENEFITS. FROM A TECH PUB PERSPECTIVE, WE DON’T USUALLY REFER TO A DEFINITION OUTSIDE THE TECHNICAL WORLD. LANGUAGE AS FAR AS ICAS WOULD RESIDE IN PROCESSES AND ICAS AND NOT BE PART OF THE TECH PUB, WHICH IS AS DEFINED IN THE ANSI STANDARDS. JAMAL [remove AND] he would review the ANSI standard language and propose something different. [remove SEE ROW #6.] The Tech Pub is intended to reflect the Amendment and not intended to be a PCAT. (4/26/11 Updates received from Integra in CAPS) KAREN CLAUSON – INTEGRA SAID SHE IS GLAD TO HEAR THAT. SHE SAID WE ARETALKING ABOUT THREE CRITICAL WORDS CHANGED FROM THE FCC DEFINITION. KAREN SAID, IF QWEST SENDS SOMETHING, WE WILL LOOK AT IT. KAREN SAID QWEST KNEW IT WAS TO REFLECT THE ICA AND, IF QWEST DOES SOMETHING ELSE, IT IS DIFFERENT FROM THE ICA. (4/26/11 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA – QWEST IS REFLECTING THE AMENDMENT, ABSOLUTELY. IT IS NOT WORD-FOR-WORD BUT HAVE DONE IT TO A LARGE EXTENT. THE DEFINITIONS MAY FALL UNDER DIFFERENT DOCUMENTS. TECH PUBS SHOULD REFLECT TECHNICAL CAPABILITIES. AS FAR AS PROCESSES AND PRODUCT DEFINITIONS, THE TECH PUB IS NOT A PRODUCT CATALOG. QWEST SAID AGAIN WE ARE TALKING SEMANTICS. WE NEED TO DISTINGUISH CAPABILITY. “DIMINISHES” IS OVER TIME; LOOK AT THE TIME OF TESTING. Karen Clauson - Integra said, if it is a matter of semantics, then . (4/26/11 Updates received from Integra in CAPS) AS A COURTESY use the CLEC language proposed. This particular language does not reflect the Amendment and if new language is proposed, it should reflect the Amendment and not be left to Qwest to interpret. The language is the same between the two except for the few words. Jamal Boudhaouia – Qwest said he is not ready to agree . (4/26/11 Updates received from Integra in CAPS) AND HE NEEDS TO TAKE THIS BACK. If he agrees to use “could diminish,” that impacts the industry Tech Pubs. . (4/26/11 Updates received from Integra in CAPS) JAMAL SAID THIS WOULD CHANGE EVERYTHING AND THAT HE WOULD NEED TO GO BACK TO BELLSOUTH AND AT&T AND REVISE IT, and HE SAID that he WOULD [delete COULD] NEED TO PUT IT IN THE [delete TAKE IT TO ] ANSI FORUM for review. Karen Clauson - Integra said . (4/26/11 Updates received from Integra in CAPS) WE NEED TO FOCUS ON the words “could diminish” WHICH are the issue and the FCC DEFINITION IN THE FEDERAL RULE, INCLUDING THE word “could,” has been around for years and is not inconsistent with other industry Tech Pubs. KAREN SAID, IF BRIDGE TAP COULD DIMINISH THE SERVICE, THEN IT COMES OFF TO PROVIDE THE SERVICE. Mark Coyne - Qwest suggested in the interest of making the best use of the remaining hour, the Qwest SMEs take some time to review the most recent proposed changes from Integra and that the meeting moves on to reviewing the Conditioning download and PCAT. Karen Clauson - Integra said she thought the discussion has been useful since it is the most important issue and it is beneficial for Qwest to have that background as further language changes are considered. Karen said she preferred to continue review of the Tech Pub matrix since that was the . (4/26/11 Updates received from Integra in CAPS) STATED intent of today’s meeting IN THE NOTICE, and since the Conditioning Download updates were just received AND, BECAUSE QWEST DID NOT SEND A NOTICE OF THE CHANGE, [delete THEY] WE NEEDED [delete NEED] time to review them. (4/26/11 Updates received from Integra in CAPS) MARK COYNE – QWEST SAID THERE WAS NOT ADDITIONAL NOTICE FOR THE CHANGES TO THE DOWNLOAD, AS PART OF THE LEVEL 3 NOTICE WAS PULLED BACK, SO THERE WAS NO ADDITIONAL COMMENT PERIOD. (4/26/11 Updates received from Integra in CAPS) KAREN CLAUSON – INTEGRA SAID SHE WAS NOT CRITICIZING; WE JUST NEED TIME TO LOOK AT THE NEW DOWNLOAD CHANGES AND THE MEETING WAS NOTICED TO DISCUSS THE TECH PUB. It was agreed to continue review of the Tech Pub matrix. Julia Redman-Carter - PAETEC said that PAETEC agrees 100% with the Integra position and wanted to provide that feedback and will continue as she has unless she has something else to add. Mark Coyne – Qwest agreed and also said if there are other call participants that disagree. (4/26/11 Updates received from Integra in CAPS) [delete WITH THE DISCUSION], they [delete WOULD MAKE THAT KNOWN] SHOULD SPEAK UP. Karen Clauson - Integra reviewed (4/26/11 Updates received from Integra in CAPS) MATRIX Row #7, Section 2.2.2, this is a cleanup issue and Qwest agreed. KAREN SAID WHERE ISDN-BRI IS USED IT NEEDS TO BE SPECIFIC AND CONSISTENT SO THE TECH PUB WILL BE CLEAR THAT THESE SECTIONS APPLY TO ISDN-BRI. (4/26/11 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA – QWEST SAID NO PROBLEM. Karen Clauson - Integra reviewed . (4/26/11 Updates received from Integra in CAPS) MATRIX Row #8 and said the issue is not placement as long as it is included and that this relates to Section 1.1 (Row #3) in providing more examples. Qwest agreed to look at it in both places. (4/26/11 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA – QWEST SAID HE WILL PUT IT IN SECTION 1. Karen Clauson - Integra reviewed (4/26/11 Updates received from Integra in CAPS) MATRIX Row #9, Section 3.1 where Qwest had already agreed and Qwest agreed to the proposed expanded update. KAREN SAID IT IS NOT LIMITED TO ASSIGNING FACILITIES, AND QWEST NEEDS TO EXPAND 3.1 INCLUDE PERFORMING REPAIRS AND SPECTRUM MANAGEMENT. (4/26/11 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA – QWEST SAID, NO PROBLEM, QWEST WILL ADD THAT. (4/26/11 Updates received from Integra in CAPS) KAREN CLAUSON - INTEGRA SAID ALSO [delete also] in regard to Row #9 and the embedded base and the NC/NCI code issue, Integra is requesting wording to be added so the Qwest technicians know what should happen if the codes are different than what is in the Amendment. KAREN SAID SHE UNDERSTANDS THIS IS THE TECH PUB BUT THERE NEEDS TO BE LANGUAGE ABOUT WHAT WILL HAPPEN EVEN IF IT IS TO RECOGNIZE THAT FOR THE EMBEDDED BASE YOU LOOK ELSEWHERE. (4/26/11 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA – QWEST SAID REPAIR ADDRESSES THE EMBEDDED BASE SO IT IS ALREADY INCLUDED. (4/26/11 Updates received from Integra in CAPS) KAREN CLAUSON - INTEGRA SAID GOING FORWARD IS TAKEN INTO ACCOUNT BUT THE EMBEDDED BASE HAS NOT BEEN TAKEN INTO ACCOUNT. IF IT IS A RECENT ORDER, THEN THE CLEC HAS TO SUBMIT AN ORDER AND CHANGE THE NC/NCI CODE. BUT, IF IT IS OLD, THEN IT IS A RECORDS UPDATE, AND THAT PROCESS IS IN THE AMENDMENT, SO THIS SHOULD BE A HEADS UP FOR TECHNICAL PEOPLE. WITHOUT THAT, THEY WILL DO SOMETHING ELSE. Jamal Boudhaouia – Qwest said the Qwest technicians don’t see the Tech Pub or the up front order processes. (4/26/11 Updates received from Integra in CAPS) HE SAID THE TECH PUB REALLY DOESN’T INFLUENCE WHAT THE TECHNICIAN SHOULD DO OR NOT DO. HE SAID, FOR THE EMBEDDED BASE, WHEN THEY SEE NEW OR CHANGE ORDERS TO NC/NCI CODES, QWEST SEES THE NEW CODES AND TESTS TO PARAMETERS. The technicians see the correct NC/NCI codes ON THE ORDER and perform testing based on whatever is defined for them as required. HE SAID THE TECH PUB DOES NOT CARE ABOUT RECORDS, AND THEY WILL DO WHATEVER IS ON THE ORDER. THEY DO NOT KNOW WHETHER THE RECORDS ARE WRONG OR NOT. HERE ARE THE TEST PARAMETERS AND IT SHOULD FALL WITHIN THIS LIMIT. It has nothing to do with the Tech Pub. Julia Redman-Carter - PAETEC said the embedded base is her biggest concern and how (4/26/11 Updates received from Integra in CAPS) THE repair will be handled if Qwest identifies IT AS THE WRONG [delete THAT THE] NCI CODE [delete WRONG]. She said her understanding is THAT QWEST WILL [delete THErepair TO [delete WOULD] WHAT IT SHOULD BE [delete OCCUR] AND then PAETEC would follow-up with an order. JULIA ASKED, UNDER THE TECH PUB, WHAT WILL GET REPAIRED? JULIA SAID SHE IS CONCERNED AS TO HOW THIS GETS REFLECTED. Julia questioned how does the correct work get done PER THE AMENDMENT. Jamal Boudhaouia – Qwest said the question is valid but is really a process and not a Tech Pub issue. (4/26/11 Updates received from Integra in CAPS) JAMAL SAID, IF THERE IS AN ADSL NC/NCI CODE TO RUN ADSL, THEN QWEST WILL TEST TO THE NC/NCI CODE. IT IS PUSHED DOWNSTREAM. Jamal said that the agreed to process would be that Qwest would send [delete A] AN SERVICE order with the correct NC/NCI to test but then request the customer send a records order to correct the Qwest records. QWEST WILL TEST TO THE QWEST SERVICE ORDER, USING THE CORRECT ONE. Karen Clauson - (4/26/11 Updates received from Integra in CAPS) INTEGRA SAID, FOR EMBEDDED BASE CUSTOMERS, THE SERVICE DEPLOYED ON THE LOOPS ASSUMES CERTAIN NC/NCI CODES AND THAT SCENARIO SHOULD BE CAPTURED IN THE TECH PUB. Integra said it does become a Tech Pub issue and is specific to the Amendment language IN 9.2.2.3.5.5, where the going forward process is described. Karen said they are looking for the one scenario where there is the potential for error. Karen said that the embedded base is a key area and one that causes a lot of problems and part of why this has become an issue. She said the Tech Pub is frequently quoted back TO THE CLEC and that the scenario needs to be addressed with [delete AN] THE exception. Karen said she thinks the fix is fairly simple if it isreferenced in this update. Jamal Boudhaouia – Qwest said he was concerned with having to reference all of the possible VARIATIONS [delete SCENARIOS] in the Tech Pub and that it is not designed for that. Jim Hickle – Velocity said (4/26/11 Updates received from Integra in CAPS) THAT IS NOT THE CASE. HE SAID [delete THE] Qwest SHOULD GET ITS techs [delete SHOULD] TO stop throwing THE TECH PUB [IT] back at the CLECs AND TELLING US TO FOLLOW THE TECH PUB. HE ASKED, IF THE TECH PUB IS NOT MEANT TO TELL TECHS TO DO THEIR JOB, WHY IS IT NEEDED AND WHY DO THE TECHS [delete THEN] SAY that [delete THEY] CLECS are not following the Tech Pub [delete .AND] Qwest should address that. Jamal Boudhaouia – Qwest said Qwest has tried to do that and that language was added to say NC/NCI codes are good to use no matter where they come from -- CLECs, Qwest or however they get into the system. Also, the Tech Pub language changed to take into account the NC/NCI codes when assigning facilities (4/26/11 Updates received from Integra in CAPS), PERFORMING REPAIRS, AND PERFORMING SPECTRUM MANAGEMENT. Julia Redman-Carter – (4/26/11 Updates received from Integra in CAPS) JULIA SAID QWEST HAS, IN OTHER PLACES, REFERENCED SOMETHING ELSE THAT CONTAINS THE PROCESS – NOT THAT QWEST GAVE THE PROCESS, BUT WHERE THE PROCESS IS. JULIA SAID THAT, FOR THE EMBEDDED BASE, PAETEC IS NOT ASKING THAT TO EXPLAIN THE PROCESS BUT TO NOTE THE EXCEPTION HERE. PAETEC suggested the exception needs to be noted in the process for the techs [delete AND THAT IT IS] OR THEY ARE still going to follow the NC/NCI codes. Karen Clauson – Integra provided an example of the repair situation using ADSL(4/26/11 Updates received from Integra in CAPS) ACTUALLY DEPLOYED ON THE LOOP and IDSL AS THE NC/NCI CODES IN THE RECORDS. KAREN SAID, IN [delete in] regard to the embedded base, Amendment section 9.2.2.3.5.5 SAYS THAT, [delete ]IN THIS example,[delete THAT] WHEN the records say IDSL, Qwest will repair to ADSL, and will allow the change TO THE PAPERWORK from IDSL to ADSL later. Karen said the key is to AT LEAST acknowledge the exception [delete AT LEAST] in the Tech Pub. The document needs to be clear on which NC/NCI to use in the repair situation since a lot of time and money has been spent to develop [delete IT] THESE TERMS. Jamal Boudhaouia - Qwest- said he liked Julia’s recommendation to see what processes are out there and point to it. Karen Clauson – Integra said she will only agree to that if the reference is to the ICA (4/26/11 Updates received from Integra in CAPS) FOR [delete AND] the embedded base. Jamal Boudhaouia – Qwest agreed that it will have the same reference to the download for the embedded base. Karen Clauson – Integra said that is the objection. (4/26/11 Updates received from Integra in CAPS) SHE SAID WE KNOW WHAT THE PCAT SAYS TODAY BUT WE DO NOT KNOW WHAT IT WILL SAY TOMORROW. The reference needs to ACKNOWLEDGE THIS SCENARIO AND include the ICA since the PCAT or download can be changed. Jamal Boudhaouia – Qwest said (4/26/11 Updates received from Integra in CAPS) HE AGREES absolutely, it should be the ICA but it might not be in this particular section since there could be a better place for it. Julia Redman-Carter – PAETEC said it may be in other sections but it really (4/26/11 Updates received from Integra in CAPS) ALSO needs to be in Section 3.1 because of the issues with the embedded base and NC/NCI codes. Karen Clauson – Integra said it sounds like we agree the wording can get into the Tech Pub someplace and that maybe Qwest wants to take it back to determine where. Jamal Boudhaouia – Qwest agreed to take it back. (4/26/11 Updates received from Integra in CAPS) KAREN CLAUSON – INTEGRA SAID IT’S A BIG ISSUE AND WE REALLY APPRECIATE IT. Karen Clauson – Integra said (4/26/11 Updates received from Integra in CAPS) MATRIS row #10 was agreed to by Qwest. MATRIX Row #11 was agreed to by Qwest. MATRIX Row #12 was agreed to by Qwest. For MATRIX row #13, since it is related to process for both Qwest and CLEC, the question is should the paragraph be removed. KAREN SAID QWEST LEFT IN THE CLEC RESPONSIBILITIES BUT NOT QWEST’S RESPONSIBILITIES. Jamal Boudhaouia – Qwest said it will all be removed. Karen Clauson – Integra said in regard to (4/26/11 Updates received from Integra in CAPS) MATRIX row #14, that no Qwest response had been provided to change the first three fields required to the first four fields that are required AND SHE ASKED IF THE OMISSION WAS INADVERTENT OR IF QWEST HAS A REASON FOR THAT. Jamal Boudhaouia – Qwest said (4/26/11 Updates received from Integra in CAPS) YES, QWEST HAD A REASON. HE SAID the protocol option defines the equipment capabilities to put on and what protocol is. HE SAID THAT, WHETHER IT IS ETHERNET, IP, OR WHATEVER YOU PUT ON IT, YOU DO NOT TEST TO THE PROTOCOL. He said Qwest does not test to protocol but to physical characteristics of the loop. Karen Clauson – Integra said Qwest previously argued in 271 cases that the NCI codes had to be available to do Spectrum management. Karen said now CLECs want (4/26/11 Updates received from Integra in CAPS) QWEST TO USE the NCI code and the question is why Qwest SAYS IT does not need the information. Jamal Boudhaouia – Qwest said (4/26/11 Updates received from Integra in CAPS) to LOOK AT THE FREQUENCY RANGE; SPECTRUM MANAGEMENT IS MORE ABOUT POWER AND NOT PAYLOAD. JAMAL SAID YOU LOOK AT THE POWER INFLUENCE BETWEEN DIFFERENT DSL SERVICES; YOU DO NOT LOOK AT PAYLOAD, EQUIPMENT ON THE LOOP. HE SAID the NC/NCI code without the forth character defines the POWER SPECTRUM OR frequency range IT SHOULD FALL WITHIN AND [delete THE DSL SERVICE IS RUNNING ON THE LOOP AND also defines the power limits. JAMAL SAID POWER SPECTRUM MANAGEMENT IS BASED ON FREQUENCY RANGES AND POWER CARRYING FROM YOUR EQUIPMENT. Jamal said Qwest does not and should not look at the payload [delete FOR THE INFORMATION] IN THAT FREQUENCY RANGE [ delete THAT IS BEING TRANSMITTED]. (4/26/11 Updates received from Integra in CAPS) KAREN CLAUSON – INTEGRA ASKED JAMAL TO SLOW DOWN. SHE SAID THAT HE IS GOING TOO FAST AND THAT IT IS DIFFICULT TO ABSORB BECAUSE HE IS TALKING TOO FAST. (4/26/11 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA – JAMAL SAID MAYBE HE SHOULD BE TALKING TO ENGINEERS INSTEAD. (4/26/11 Updates received from Integra in CAPS) KAREN CLAUSON – INTEGRA SAID THAT SHE BELIEVES SHE HAS SHOWN THAT SHE IS CAPABLE OF UNDERSTANDING THE INFORMATION AND COULD UNDERSTAND IT IF JAMAL TALKED SLOWER. KAREN SAID THAT SHE IS QUITE SURE AN ENGINEER WOULD HAVE TROUBLE KEEPING UP AS WELL BECAUSE JAMAL IS TALKING SO FAST. (4/26/11 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA – QWEST RESPONDED ABSOLUTELY AND APOLOGIZED. Julia Redman-Carter – PAETEC said she understood it made a difference for binder groups to be put together based on whether it was ADSL, SDSL, etc. (4/26/11 Updates received from Integra in CAPS)[delete AND ASKED IF THAT WAS TRUE. SHE SAID IT DOES MAKE A DIFFERENCE AND BASED ON THE ORDER WE WILL TELL WHAT FLAVOR BECAUSE THE NC/NCI CODES TELL QWEST THAT INFORMATION. JULIA ASKED IF QWEST AGREED. Jamal Boudhaouia – Qwest said the NC/NCI codes DO define (4/26/11 Updates received from Integra in CAPS) [delete THE] WHAT DSL IS RUNNING ON THE LOOP [delete TYPE], WHAT FLAVOR OF DSL IT IS USING. JAMAL SAID THE FOURTH CHARACTER DEFINES THE PROTOCOL, WHATEVER IS PUT ON IT. HE SAID HE NC/NCI CODES DEFINE THE FLAVOR. Kim Isaacs – Integra (4/26/11 Updates received from Integra in CAPS) ASKED, IF QWEST IS NOT LOOKING AT THE FOURTH FIELD IN THE NCI CODE, HOW CAN QWEST DETERMINE WHAT THE TYPE OF DSL. SHE ASKED ABOUT THE IMPEDENCE. SHE ASKED IF THE PROTOCOL OPTIONS ISN’T THE ONLY THING ALLOWING QWEST TO UNDERSTAND THE FREQUENCY. INTEGRA questioned what information provides Qwest everything that is necessary to know about spectrum management.. [delelte ?] (4/26/11 Updates received from Integra in CAPS) JAMAL BOUDHAOUIA – QWEST SAID THE PROTOCOL OPTIONS DEFINE THEPROTOCOL PUSHING DATA THROUGH AND TELLS WHICH DSL IS RUNNING ON THE LOOP. HE SAID, WITHOUT THAT OPTION, WE KNOW FROM THE PHYSICAL LAYER WHICH DSL IS RUNNING ON THE LOOP. (4/26/11 Updates received from Integra in CAPS) KIM ISAACS – INTEGRA ASKED HOW QWEST DOES THAT. INTEGRA SAID THE FIRST FIELD IS TOTAL CONDUCTORS AND THE SECOND FIELD IS CONNECTION AT THE CO AND THE THIRD FIELD IS THE IMPEDANCE AND NONE OF THESE TELL ME THAT THIS IS ADSL. SHE ASKED, SO HOW DOES THAT TELL QWEST WHAT YOU NEED TO KNOW. Jamal Boudhaouia – Qwest said (4/26/11 Updates received from Integra in CAPS) YES, FROM THE IMPEDENCE AND OHMS, QWEST CAN TELL THE FLAVOR. HE SAID, from the combination of the NC/NCI codes in the Tech Pub, Qwest knows which type of DSL flavor. Kim Isaacs – Integra referred to the Table 3-14 (4/26/11 Updates received from Integra in CAPS) AND POINTED OUT THAT, OF ALL THOSE WITH AN “NC” OF “LX-N,” MOST BEGIN WITH A CODE OF “02” FOLLOWED BY “QB” FOR THE MANUAL CROSS CONNECT. WHE SAID THAT, FOR IMPEDENCE, IT IS EITHER A “9” OR “5.” SHE CONCLUDED THAT THE DIFFERENCE BETWEEN THESE LOOPS, THEREFORE, IS IN THE PROTOCOL OPTIONS FIELD. SHE ASKED WHETHER THE PROTOCOL OPTIONS FIELD ISN’T THE INFORMATION THAT GETS TO THE MEAT OF WHAT IS RUNNING ON THE LOOP. KIM questioned whether it was the protocol options that provide the key of what is running and that makes the codes different. She said it appears the fourth field is required to understand the spectrum management class. Jamal Boudhaouia – Qwest said no, the NC/NCI codes in Table 3-14 defines the recognizable flavors of DSL. (4/26/11 Updates received from Integra in CAPS) KIM ISAACS – INTEGRA SAID THE FOURTH FIELD IS THE FIELD THAT GETS TO THE MEAT OF THE MATTER. IT IS WHAT MAKES EACH CODE DIFFERENT, AND IT IS REQUIRED TO UNDERSTAND SPECTRUM MANAGEMENT. KIM ASKED WHETHER QWEST AGREES THAT THE FOURTH FIELD GETS TO THE MEAT OF THE MATTER. KIM SAID THAT IT IS THE PROTOCOL OPTIONS THAT TELL WHETHER IT’S XDSL OR ADSL. KIM ASKED IF JAMAL SEEING WHERE WE’RE GOING WITH THE PROTOCOL OPTIONS – THAT THE FOURTH FIELD HAS TO BE REQUIRED? SHE SAID THAT QWEST NEEDS TO REQUIRE THE FOURTH FIELD. Bonnie Johnson – Integra (4/26/11 Updates received from Integra in CAPS) ASKED IF QWEST’S ANSWER IS THAT QWEST WILL PLACE ALL OF THESE DIFFERENT TYPES OF DSL [delete in the same binder group.[delete ?] Jamal Boudhaouia – Qwest said yes, (4/26/11 Updates received from Integra in CAPS) QWEST IS ALLOWED TO PUT THE TOGETHER IN THE SAME BINDER GROUP. HE SAID you can put different or multiple DSL signals in a single binder group without interference if they are within the spectrum management guidelines. Julia Redman-Carter – PAETEC said(4/26/11 Updates received from Integra in CAPS) that she is concerned based on history and that THIS is EXACTLY THE opposite of what she [delete HAS]heard [delete PREVIOUSLY] BEFORE. SHE SAID PAETEC’S [delete HER] experience with the embedded base indicates a problem putting ADSL and SDSL together in a binder group, and that it is a spectrum management issue. SHE SAID THAT THE FOURTH FIELD IS THE BASIS FOR SEPARATING THEM OUT. Jamal Boudhaouia – Qwest said (4/26/11 Updates received from Integra in CAPS) THAT THIS IS A GOOD QUESTION. HE SAID THAT spectrum management is the power influence on each other. HE SAID, WHEN DISCUSSING SPECTRUM MANAGEMENT, IF THERE IS A REMOTE DSL, ALL OF A SUDDEN THERE MAY BE A SUDDEN SHIFT IN THE POWER REFERENCE. HE SAID IF ADSL IS RUNNING FROM THE POWER REFERENCE IT WILL WORK TO HAVE TWO DIFFERENT TYPES OF DSL. HE SAID IF ADSL IS FROM THE CO AND ADSL IS FROM A REMOTE, OR TWO OF THE SAME SERVICES AT TWO DIFFERENT POINTS, THE POWER OF THE ADSL SIGNAL IS HIGHER THAN THE POWER OF THE ADSL SIGNAL THAT TRAVELS THROUGH THE CROSS BOX. ADSL AT REMOTE WILL INTERFERE. THAT IS WHY THE NC/NCI CODES FIGURE IN THE POWER ISSUE. [delete AND] HE provided an example of HDSL and ADSL services running from a central office will not interfere with each other. Spectrum Management issues arise when the same flavor of DSL is running from a different reference point. For example when you have ADSL running from the Central Office and another ADSL running from a remote DSLAM. Jamal said the NC/NCI codes help with figuring out any power issue at a reference point – most likely at a remote terminal. Mike McCarthy-Minnesota Department of Commerce - said it sounds like there is some agreement on the value of the protocol options. Mike said (4/26/11 Updates received from Integra in CAPS) QWEST SAID EARLY IN THE CALL THAT the INTENT OF THE call [delete BEGAN WITH THE INTENT TO RECONCILE] WAS TO RECONCILE the Tech Pub and the ICA. MIKE SAID THAT ATTACHMENT 2 TO THE AMENDMENT INCLUDES THE PROTOCOL OPTIONS. HE SAID THE [delete PROTOCOL OPTIONS ARE INCLUDED IN THE ICA AND IN] ANSI [delete STANDARDS] MANUAL ALSO INCLUDES THE PROTOCOL OPTIONS FIELD. HE SAID THEY [delete AND] are the definition of what drives spectrum management. Mike ASKED, SINCE ALL OF THIS IS CALLED OUT IN THE ICA, WHY WOULD QWEST IGNORE [delete QUESTIONED WHY ]that information [delete WOULD BE IGNORED] in [delete THE]directions to PEOPLE IN the field. Jamal Boudhaouia – Qwest said he would propose language to be added to the Tech Pub that allow the protocol options to be optional. Karen Clauson – Integra said the protocol options are already optional in the Tech Pub, (4/26/11 Updates received from Integra in CAPS) WHICH IS WHAT INTEGRA HAS PROPOSED TO CHANGE. [delete AND] SHE said Mike McCarthy described what is in the ICA. Karen used a pizza example and said they wanted the pizza that had been ordered and not just any pizza. Karen said the same is true for xDSL, they want the xDSL flavor specifically ordered which is why the protocol options are listed in the ICA and need to be listed in the Tech Pub and not be allowed to be optional. KAREN SAID THAT OUR REQUEST IS THAT QWEST RECOGNIZE AND TAKE INTO ACCOUNT THE NCI CODE AND GIVE US WHAT WE ORDERED. Jamal Boudhaouia – Qwest relayed the wording in Chapter 3 of the Tech Pub and said he was willing to AGREE TO TWO OF THE FIELDS [delete CONSIDER A CHANGE]. Karen Clauson – Integra said they had suggested updates on March 14 . See Row #14. Karen said you can review their proposed language. Jamal Boudhaouia – Qwest said he would come up with some words that specifically address the XDSL loop. Karen Clauson – Integra (4/26/11 Updates received from Integra in CAPS) ASKED IF WE UPDATED THE LANGUAGE TO INDICATE THAT XDSL PROTOCOL OPTIONS IS REQUIRED FOR XDSL LOOPS (SO IT DOES NOT SUGGEST THIS APPLIES TO OTHER LOOPS) WILL THAT TAKE CARE OF QWEST’S CONCERNS? KAREN provided some wording options for sub section 3.6.1. Jamal Boudhaouia – Qwest requested that Karen (4/26/11 Updates received from Integra in CAPS) [delete PROVIDE] SEND TO QWEST the PROPOSED sentence she is referring to IN WRITING. Karen Clauson – Integra agreed. (4/26/11 Updates received from Integra in CAPS) NOTE: INTEGRA PROVIDED THE SENTENCE TO QWEST BY EMAIL DATED APRIL 14, 2011, AS PART OF A MATRIX UPDATED AS TO ACTION ITEMS. Mark Coyne – Qwest said there is about 10 minutes left and he wanted to discuss the next steps. He said we have reviewed through (4/26/11 Updates received from Integra in CAPS) MATRIX Row # 14 [delete 14 WHICH] 14 WHICH is about half way through the matrix. Karen Clauson – Integra said she thought we should count (4/26/11 Updates received from Integra in CAPS) MATRIX Row #15 because that is the issue Qwest took back with respect to 1.1 and that we are actually further along since some of the same language repeats throughout the document so that will take care of some of those. Mark Coyne – Qwest said Qwest would review the matrix and recent Integra responses and provide that back. Mark said we will need another Ad hoc call. Susan Lorence –Qwest asked about several dates. Based on various conflicts, the group determined May 2nd was a workable date. Karen Clauson – Integra suggested if Qwest wanted to send the matrix back in between, they would review it. Mark Coyne – Qwest said we would do that and requested feedback on the Conditioning Download redline. Karen Clauson – Integra agreed. Susan Lorence –Qwest said Qwest will provide feedback on the matrix by 4/21 or 4/22 and then maybe in that same time period would receive feedback from the CLECs on the conditioning download and would plan to get back together May 2nd . Mark Coyne – Qwest said let’s go for that and then provided a recap of what had been accomplished according to the agenda: the historical background, review of Tech Pub Chapters 1, 2, and part of 3, impact of the CLEC’s who do not sign the XDSL amendment. Mark said that leaves us two and half chapters to go through as well as the download for the next meeting. Karen Clauson – Integra said they were looking at addressing some other issues relative to the escalations, terminology, and wanted to take an umbrella approach to see how it is all working together. Mark Coyne – (4/26/11 Updates received from Integra in CAPS) MARK SAID ALL RIGHT. Qwest asked if there were any additional comments or questions and there were none. 3/16/11 Product Process CMP Meeting Mark Coyne – Qwest said the rollout of the remaining states continues: Arizona, Oregon and Montana were implemented 3/14 and that Idaho and Washington will go into effect on 3/21. Mark said in regard to the escalation #46 that was identified last month, the Qwest binding response and the Integra binding response are posted to the CMP escalation site. Mark said there was also a Level 3 notice sent to implement an additional change in regard to the escalation on the Single Trouble Report Issue. Qwest submitted the final response to comments on the level 3 notice on 3/14/11 plus Qwest issued a level 2 Network notice on 3/7/11 on Tech Pub 77384 to synch up with the new process that had been implemented first in MN on 1/15/11. Mark said there were no new process changes with the Tech Pub update. Mark said we received a request from PAETEC to extend the comment cycle and a request from Integra to change the disposition to a level 4 notice. Mark said the plan is issue a new level 4 notice which will provide a 15 day extension to the comment cycle. Bonnie Johnson – Integra said piece-mealing the changes is not working and that Integra does not necessarily agree with the changes and that (3/25/11 Updates received from Integra in CAPS) QWEST MADE TO THE PCAT TO RESOLVE THE SINGLE TROUBLE REPORT TICKET ISSUE AND THAT they have been asking for a collaborative effort. Integra would like to COLLABORATIVELY review the changes including the lastest Tech Pub update which is why they asked for the change in disposition. Mark Coyne – Qwest said the timing of the changes could have been better. We can put together an ad hoc meeting to review the Tech Pub update. Jamal Boudhaouia - Qwest said in regard to the Tech pub update, the major changes are to Chapter 6 which are the performance test parameters. Jamal said the changes that have been copied word for word from the Amendment and settlement agreement. Jamal said the purpose of a Tech Pubs is not intended to be product description but it is intended to cover technical parameters. Bonnie Johnson – Integra thanked Jamal for the explanation but said Qwest has information in the Tech Pub that is in conflict. She said the information is not in line with the xDSL Amendment and that Integra provided some feedback and examples where the Tech Pub is in conflict. Bonnie said a collaborative meeting to review the whole Tech Pub is what was needed. She said it was not just the changes that were made but the changes that were not made. Jamal Boudhaouia - Qwest said he is not opposed to having an Ad hoc call but that he wants to insure that the expectations are clear. He said he did not want the Tech pub to be a futuristic document nor to be a Product Catalog. Mark Coyne – Qwest said we will set up an Ad hoc meeting to review the Tech Pub changes. Bonnie Johnson – Integra said the Ad hoc should not only be to review the Tech Pub but to review changes to other documents such as the Unbundled Loop PCAT or other relevant PCATs. She wants to work together to reflect the xDSL Amendment which is what governs. Bonnie said Qwest is rejecting some orders associated with conditioning and that the Amendment does not say exact verbiage has to be used and a Tech may forget to use specific words. Bonnie said she thought the problem was that Qwest was not training on the Amendment but (3/25/11 Updates received from Integra in CAPS) INSTEAD TRAINING on the PCAT. Mark Coyne – Qwest said we will schedule an Ad hoc and will get with Qwest SMEs to identify what pieces of the Tech Pub and documentation to discuss. Bonnie Johnson – Integra said that sounds fair and that Qwest should propose some dates/times to some of the main players for the Ad hoc. Mark Coyne – Qwest said we will propose some dates/times for the Ad hoc.

2/16/11 Product Process CMP Meeting Mark Coyne – Qwest relayed that the notification to implement the additional states was sent out on January 24, 2011. Qwest submitted its final notification and response to comments on February 11, 2011. On February 14, 2011,Qwest received an escalation from Integra on two issues. That escalation has been posted to the CMP external site and on February 15, a notification was sent out to the entire CLEC community to inform them of the escalation. At this point, Qwest is in the process of developing its response and will be sending it out according to the CMP document. Mark said the rollout of the remaining states related to this change will remain on schedule while we try to resolve these two issues.

1/19/11 Product Process CMP Meeting Mark Coyne – Qwest relayed an initial Level 4 notice went out on November 30, 2010, the comment cycle closed on December 15, 2010 and the final notice and response to comments went on December 23, 2010 with an effective date of January 15, 2010. This change did go into effect earlier this week and the CR has been moved to CLEC Test. Mark relayed a notification to implement the additional states will probably be sent before the end of this month. Bonnie Johnson – Integra asked if Qwest could relay what that would look like – the states and timeframe. Bob Mohr – Qwest indicated that we are finalizing the order and the implementation dates and that we do not have the complete schedule yet. Bob confirmed we are planning to put out something before the end of the month. Bonnie Johnson – Integra asked if Qwest can give her an idea if it is going to be all 14 states or the major metropolitan areas are going first and what are the dates. Mark Coyne – Qwest indicated the dates will be staggered. Bob Mohr – Qwest identified we do not have the firm dates yet. Susan Lorence – Qwest said we are thinking we will use a Level 4 notification again. When the dates are finalized, we will show the various states on the Level 4 notice and relay the various dates that they are going in. Susan said we are not going to send separate notices for each state and that we will notify in time for the first date, whatever it is. Bonnie Johnson – Integra said the plan was for the notice to go out before the end of this month and will contain the remaining 13 states and the associated dates. Mark Coyne – Qwest indicated that is correct. 12/15/10 Product Process CMP Meeting Mark Coyne – Qwest provided the following update: an ad hoc meeting was held on November 19, 2010 to discuss the revised documents associated with the CR. An initial Level 4 notice with those changes was sent November 30, 2010 with the comment cycle closing today, December 15, 2010. One comment was received today. Qwest is still planning on a final notice being sent on December 30, 2010 with an effective date of January 15, 2011. Mark asked if there were any questions. There were none. 11/19/10 Ad hoc Meeting Attendees: Loriann Burke – XO, Doug Denney – Integra, Steven Fisher – Integra, Kim Isaacs – Integra, Bonnie Johnson – Integra, Jamie Nelson – POPP, Julia Redman-Carter – PAETEC, Bob Mohr – Qwest, Jamal Boudhaouia – Qwest, Rita Urevig – Qwest, Linda Harmon – Qwest, JohnHansen – Qwest, Maryann Wiborg – Qwest, Rachel Ruiz – Qwest, Susan Lorence – Qwest Susan Lorence – Qwest began the meeting by providing a background on the CR that was originally introduced in the July CMP meeting. Two ad hoc calls were conducted on August 23 and September 13, 2010 to review the proposed change. On September 23, 2010, the CR was updated to include the state of Montana. The initial Level 4 notice was sent out on September 27, 2010 for Montana and Minnesota and a final notice was sent on October 22, 2010 with the effective date changed to November 22, 2010. On November 9, 2010, the CR was revised to remove the state of Montana with the indication of other revisions. On November 11, 2010, Qwest issued a notice to retract the initial level 4 change and also issued the notice to establish this ad hoc meeting to review the changes and relay a restart to the timeline. Bob Mohr – Qwest said he was going to review each of the PCATs and touch on the changes and then answer questions. Bob first reviewed the various changes to Unbundled Loop General Information V87. Bob relayed that information was added to better define references and that one of the big areas that changed was under Conditioning to be in sync with the latest agreements. Bob explained that the current definition of conditioning had been expanded to include Near and Far end bridge tap removal and then reviewed the two options for conditioning going forward. Bob added that there was a change related to testing that allows for the option for CLECs to escalate directly to their Service Manager. Jamal Boudhaouia – Qwest clarified that when Qwest completes testing, the results will be provided via CEMR. Jamal said the results would only be available to CEMR when and if the loop was provisioned. Kim Isaacs – Integra said she has found that the ADSL 196 test results are in CEMR when the loop is not completed but is placed in jeopardy status and that is what the ADSL PCAT says also. Kim said she has plenty of examples. Jamal Boudhaouia – Qwest said he would have to check that. Bob Mohr – Qwest reviewed the last UBL General PCAT updates associated with spectrum management. Bob asked if there were any questions before moving on and there were none. Bob Mohr – Qwest then reviewed the ADSL Compatible Loop PCAT updates which were similar to updates made to the UBL General. Bob asked if there were any questions and there were none. Bob Mohr – Qwest then reviewed the updates to 2W 4W Non-loaded Loop PCAT. Bob said Qwest was trying to put most of the detailed information into the downloads and referencing them from the PCATs. Bob asked if there were any questions. There were none. Bob Mohr – Qwest then reviewed the download Assignment of Facilities for xDSL Capable Loops and covered the additional updates to the previous version. Bob said a note was added that Qwest is going to try to apply the same processes to the sub loop offering but that the difference is the sub loop is a non-designed process and that many of the enhancements are not feasible from a non-design perspective. Bob said that Qwest is trying to determine how some of these things can be applied to the sub loop product and that Qwest will probably want input on how we can work together to meet some of the processes. Bob said it will likely have to be done manually and that it will not be the same as for Unbundled Loop. Bob said the other changes were in the facility length limit to go from 25,000 feet to 22,000 feet and the update to review what Qwest would do if there were changes in technology or industry standard associated with loop lengths. Bob said Qwest would be willing to modify those lengths to be consistent with those standards when requested. Bob asked if there were any questions on this download. There were none. Bob Mohr – Qwest said the Conditioning download had the most changes compared to the previous document and reviewed each of the revisions. Bob said we will start with a process where the customer will indicate the type of conditioning they want in the Remarks field but said that Qwest is working on a longer term solution to modify the SCA field which may be in place some time early next year. Bob said we added better defined guidelines around accepting or rejecting the quote on Remove All jobs greater than eight hours. Bob asked if there were any questions on the Conditioning download and there were none. Bob Mohr – Qwest then reviewed the last download which was Testing. Bob said some changes were made to the table but they were made to match up to the agreed upon tests and were not much different from what was reviewed previously. Jamal Boudhaouia – Qwest said in regard to 196 kHz insertion loss, it may not be met or within the parameters of 78 dB loss because of the limitation on the test equipment. Jamal said that the test equipment that is being widely deployed is not able to test to that level but may test to 70 dB plus or minus 2 dB. Of the Qwest test equipment in the field, some may go up to about 80 or so but few can measure to 78 dB so it will not be there at all times. Bob Mohr – Qwest indicated one of the biggest changes in the Testing download was the addition of the escalation to Service Management for additional testing. Bob said toward the end of the document, some additional definitions of optional testing were added and when charges apply or do not apply. And finally, information is included regarding the NC/NCI codes for the embedded base of circuits and what happens when they are different from what is on the loop. Bob said Qwest will proceed with the repair but we would like a correcting order to follow so we do not have that same discrepancy going forward. Bob asked if there were any questions. Kim Isaacs – Integra asked if there was a process developed for the NC/NCI code order and questioned if it was R or C order? Linda Harmon – Qwest indicated that we need to take that as a follow-up. Jamal Boudhaouia – Qwest provided a clarification on the D-Mark that it is not a core test. Bob Mohr – Qwest indicated that after these redlined documents were posted, a couple of typos were identified that do not change any parameters but reflect how the actual measurement occurs. Bob said we will be making those corrections. Susan Lorence – Qwest said that we are going to start the comment cycle again with a new Level 4 notice to go out on November 30, 2010 with the effective date of January 15, 2010. Bonnie Johnson – Integra said in the monthly CMP call on Wednesday, Qwest said the amendment would not be available until January 7, 2011 and that it was difficult to put things together with out the amendment. Bonnie questioned if it was the same amendment that Qwest and Integra filed in MN last week. Bob Mohr – Qwest indicated that was correct and that he did not know of any changes but if there were any, they would be minor. Qwest wassticking with what was filed. Julia Redman-Carter – PAETEC said she was not objecting to these changes but was concerned that the amendment would not be available. Bob Mohr – Qwest indicated that the actual amendment would come out a week before our final implementation date. Julia Redman-Carter – PAETEC said she was concerned with how to address incongruency if the amendment is not consistent with the documentation. Julia said she wanted to be sure the amendment reflects what she was interpreting and needed time if a clarification was required. Bonnie Johnson – Integra said if the idea is to leave the amendment as filed in MN, then it is done and it is feasible to provide it earlier. Susan Lorence – Qwest said we would note the desire to have the amendment available sooner and would take the concern back to our contract folks. Susan said again that Bob had identified there are some minor corrections to be made but that the plan is to send the initial Level 4 notice on November 30, 2010 for the state of MN. Julia Redman-Carter – PAETEC asked if there was any schedule or timeframes for other states. Bob Mohr – Qwest relayed not at this time but that Qwest is working to establish a schedule for the remaining states. Julia Redman-Carter – PAETEC requested clarification on binder groups and NCI codes in regard to repair. Jamal Boudhaouia – Qwest said that once we have the correct NC/NCI codes, that will be used for repair going forward. Bob Mohr – Qwest said if a customer was to give Qwest a repair ticket and we find the codes are different, Qwest will proceed with the repair as if the codes were correct but we would want an order to fix it later. Julia Redman-Carter – PAETEC said she understood that piece but that her question is whether Qwest will pull it out of the binder group for repair. Is it considered an issue in the Qwest network. Will the customer get charged for that repair? Jamal Boudhaouia – Qwest indicated if you have a repair ticket and there are HDSL NC/NCI codes on the loop but the loop is used for ADSL, the ADSL codes will be used to repair any issues within that loop and within the binder group. Jamal said depending whether the problem is found in the Qwest network or not, current processes will not change. He said Qwest will use the correct NC/NCI code for the maintenance and repair activity and the existing processes will be followed as far as whether to charge or not. Julia Redman-Carter – PAETEC provided a specific example: An ADSL customer has the wrong NC/NCI code compared to what Qwest has; Qwest identifies it as ADSL and does the repair but discovers it is in the wrong binder group. Qwest takes it out of the binder group and puts it in the correct binder group. An order is sent to change the NC/NCI codes to update records. The question is when Qwest removed the ADSL from the wrong binder group, is that considered an issue in the Qwest network. Julia questioned if she would be charged for it. Jamal Boudhaouia – Qwest repeated the situation: A repair ticket is placed and you had a HDSL NC/NCI code however you wanted ADSL. The ADSL within binder group 1 is interfered because of certain parameters. Qwest will change it to a different binder group where we believe there is no interference and the question is would you be charged for that maintenance activity. Julia Redman-Carter – PAETEC indicated yes, is the problem from Qwest network and therefore no charge or is that considered a charge? Jamal Boudhaouia – Qwest said he would have to investigate the maintenance process and would respond in writing. Julia Redman-Carter – PAETEC said that once an agreed upon answer is received, she wanted that clarified since this was a big deal with the NC/NCI codes and the changes. Jamal Boudhaouia – Qwest relayed that he will work with Bob to see if that is something to be documented and if so, where it should be documented - in a business procedure or PCAT. Julia Redman-Carter – PAETEC said ok but wanted to see it documented. Susan Lorence – Qwest asked if there are any other questions. Jamal Boudhaouia – Qwest asked if Kim Isaacs could send a few examples of the results of 196 kHz test that was jep’d and not provisioned. Susan Lorence – Qwest asked if Kim would send them to the CMPCR mailbox and we can forward it on. Kim Isaacs – Integra relayed that she would do that today. Susan Lorence – Qwest thanked everyone for joining the call. The meeting adjourned at 11:11 am MT. 11/17/10 Product Process CMP Meeting Mark Coyne – Qwest provided a background on this CR. The Level 4 notice originally went out on September 27, 2010 with an original effective date of November 8, 2010. However, on November 9, 2010 the CR was revised to remove the state of Montana. On November 11, 2010, Qwest sent a retraction notice in order to make some additional modifications associated with the CR. Those modifications have been posted to the Wholesale Calendar for an ad hoc call that is already established. The planned implementation date is January 15, 2011. Bob Mohr – Qwest indicated that we did retract the original proposed PCAT changes and have reposted those modifications. Bob said changes were made primarily to the Conditioning and the Testing download but other minor changes were made to the Facility Assignment download and the two PCATs and all documents have been reposted with the modifications in them. Bob said an implementation date of January 15, 2011 for Minnesota is proposed. Bonnie Johnson – Integra said with the ad hoc call on Friday, maybe her questions should be held for that. Bonnie questioned whether Qwest would review the changes to the originally proposed documents. She said the amendment was filed yesterday for the xDSL process in Minnesota with the implementation date of January 15, 2011 and asked if the change in the process will be in line with that amendment. Bob Mohr – Qwest said that the majority of these changes were due to recent agreements and that we also added some clarifying language due to feedback from the ad hoc meetings. Bob said we are syncing up the documents to agree with the agreements made. Bonnie Johnson – Integra indicated that the agreements are public. Bonnie said she had not seen an amendment for the process that was going to be implemented on November 22, 2010 and questioned whether the amendment and rate sheet that will be offered in Minnesota for a January 15, 2011 will be the amendment that Qwest and Integra filed with the Minnesota commission yesterday? Bob Mohr – Qwest indicated that yes, we will be creating a template and have a target of January 7, 2011 to have that posted externally. Bonnie Johnson – Integra asked if it was going to be the same amendment. Bob Mohr – Qwest said the template has not been finalized but he did not know of any changes. (11/29/10 Comments to minutes received from Integra in CAPS) Bob Mohr – Qwest said the template has not been finalized but he IS NOT AWARE of any changes BEING MADE. Mark Coyne – Qwest asked if there were any other questions for Bob. There were none. 10/20/10 Product Process CMP Meeting Mark Coyne – Qwest indicated that the initial Level 4 notice went out on September 27, 2010. The final notice is set to go out on October 22, 2010. The planned effective date is November 22, 2010. Kim Isaacs – Integra relayed that Integra has submitted objections and that any implementation of this will be over their objection. Mark Coyne – Qwest indicated that Qwest does have this noted. 09/15/10 Product Process CMP Meeting Mark Coyne – Qwest indicated that an ad hoc meeting was held on August 23, 2010 and another one was held on September 13, 2010. Qwest is following up on some questions that came out of the September 13, 2010 meeting and is planning to create a matrix of specific questions and Qwest responses to include with the meeting minutes. During the September 13, 2010 meeting, the CLECs were asked to review the comparison document/matrix that was included along with the redlined documents and downloads and to submit any questions to the CMPCR mailbox. Mark asked that the CLECS please submit any remaining questions to the CMPCR mailbox by Friday, September 17, 2010. For those CLECs that did not attend, the documents are out on the Wholesale Calendar for you to review. 09/13/10 Ad hoc Meeting Attendees: Brenda Bloemke – Comcast, Julia Redman-Carter – PAETEC, Bonnie Johnson – Integra, Kim Isaacs – Integra, Lynn Powers – Integra, Pat Phipps – QSI Consulting (on behalf of Integra), Doug Denney – Integra, Jim Hickle – Velocity, Jamie Nelson – POPP, Bob Mohr – Qwest, Jamal Boudhaouia – Qwest, Mark Nickell – Qwest, Linda Harmon – Qwest, John Hansen – Qwest, Rachel Ruiz – Qwest, Mark Coyne – Qwest, Susan Lorence – Qwest Bonnie Johnson – Integra asked if there were any changes to the documents posted on today’s calendar entry other than the ADSL comparison document. Susan Lorence – Qwest said all documents remain the same except the Comparison document which was revised and shows the 090810 date. Susan also said this morning she posted a question received from Integra on Friday and the Qwest response. Susan Lorence – Qwest began the meeting by relaying this is the second meeting on this CR. The first meeting was on August 23 where we progressed through a review of a number of the documents. Susan said we will begin today by reviewing the Testing download and will then review the revised xDSL compatible loop comparison document that includes a matrix added at the end to provide further information due to requests from both PAETEC and Integra. Susan also said there was the new question and Qwest response to review. Hopefully, there is enough time to get through all that today, decide our next steps and see if there are any questions. Bob Mohr – Qwest then reviewed the Testing - xDSL Capable Loops document. Bob said facility assignment is based on the estimated measured loss, EML; loop delivery and acceptance is based on actual measured loss, AML. AML insertion loss will be performed at 196 KHz except for the ISDN NCI codes which will be tested at 40 KHz. Bob said Qwest will conduct the core test (9/21/10 Comments in CAPS or strikethrough to minutes from Integra) AND at your request (deleted AND) will provide additional testing using the testing rates in your ICA. Upon completion of testing, Qwest will provide you with the test results before loop acceptance. Bob said that will apply to any xDSL order and that it will be done via a mutually agreed upon manner either electronically, by email or verbally. Bob said Qwest will provide a loop meeting the performance parameters for the service requested where facilities are available. The key objective of this enhancement is that we will use the specific NC/NCI requested and will test to those performance parameters to meet the service requested. Bob said if after testing, the loop does not meet the performance standards, we will attempt to bring the loop within parameters and locate a facility to meet those parameters. One or more of the conditioning options may be required to bring the facility into parameters and Bob said we need your acceptance of those charges before proceeding with conditioning. If after tests, we are still unable to identify a loop, Qwest will notify you that no compatible facilities exist and will advise you of next steps. Next steps could be supping the order to a different NC/NCI or cancelling the order. Bob said again the final objective is to provide a facility that meets the industry guidelines and the service you are requesting. During repair, Qwest will utilize the same performance tests as needed to fully resolve the trouble - taking into account the existing NC/NCI for the xDSL service. The AML insertion loss will be at 196KHz. Upon completion of the testing, we will provide you with the test results. Bob asked if there were any questions. Julia Redman-Carter – PAETEC asked what if we have a product that is there, her understanding is that if we put in NC/NCI codes, does that give Qwest permission to change the facilities. In a repair situation, is that going to give Qwest the ability to leave the binder group and force us into new facilities or will Qwest remove our service from the binder group? Jamal Boudhaouia – Qwest rephrased the question. If you have a repair ticket, you give Qwest the correct NC/NCI codes to change the order. If for some reason the repair indicates that it is not supporting the ADSL services, we will do whatever is necessary to make sure that the loop works. Jamal said that includes moving the service to a different binder group that will support the ADSL signal. Julia Redman-Carter – PAETEC said she appreciated that and asked where we know that they are in a binder group, will Qwest pursue that first? Julia said she does not want to lose the grandfathered product. If we know it is a binder group, is it going to be removed from the binder group first so we don’t interrupt the customer or lose the grandfathered product. Jamal Boudhaouia – Qwest said you won’t lose the product. Jamal said we want to make sure the loop works end to end and will support ADSL. Jamal said to not be concerned at what is going on in the network in the middle but look at the ends. Jamal said whether we change pairs should not matter; it is just the assignment process. Julia Redman-Carter – PAETEC said the concern is that the NC/NCI codes are changing and she does not want to change the facility the customer is getting; it has been fine for years. Jamal Boudhaouia – Qwest indicated if that is the case, the loop supports ADSL and we will repair the facilities and not pull out of the binder group. Jamal said we will look at what is not working. Julia Redman-Carter – PAETEC said if it is not working and the issue is in a binder group, are we going to repair it by pulling them out of the binder group first or are you going to test? Jamal Boudhaouia – Qwest indicated no we will do the 196KHz test first in addition to other tests to see if the loop has an opening in it and will fix that. But if we have a remote DSL that is in the same cross box, we may need to move to a different binder group to remove interference. Julia Redman-Carter – PAETEC said she wanted to clarify the 196KHz. Her engineers are not aware if the loop is in the wrong binder group and questioned whether they would be able to recognize that with 196KHz. Jamal Boudhaouia – Qwest said absolutely. The 196KHz alone does not tell me that there is an interference problem but the 196KHz will tell if that facility will support ADSL or not. Kim Isaacs – Integra (9/21/10 Comments in CAPS or deletions indicated to minutes from Integra) CONFIRMED THAT (deleted IF) the 196KHz will not tell you whether there is interference.(deleted ?) Jamal Boudhaouia – Qwest said that is correct. In addition to all the standard tests, we test the electrical characteristics. Then we do the196KHz to tell what kind of DSL it supports. Kim Isaacs – Integra asked why go with 196KHz to be the end all. Jamal Boudhaouia – Qwest said the 196KHz test is recognized as the Industry standard - in T1 417 in addition to 413 and 418 - as the broadband and wideband standard test to use for DSL. Kim Isaacs – Integra said (9/21/10 Comments in CAPS to minutes from Integra) SHE RECALLED it was not the only test recommended. Jamal Boudhaouia – Qwest indicated yes (9/21/10 Comments in CAPS to minutes from Integra) AND THAT THERE ARE OTHER TESTS. It is part of the battery of tests Qwest will provide. Kim Isaacs – Integra questioned whether we would pay for additional testing? Jamal Boudhaouia – Qwest said there is no charge for core tests which is to make sure the loop is electrically ok; then we do the broadband test which is the 196KHz testing. Jamal then provided a number of examples of the core tests that are performed at no extra charge. (9/21/10 Comments in CAPS to minutes from Integra) THERE IS NO CHARGE FOR THE CORE TEST AND 196 KHZ TEST. FOR ANY OTHER TESTS, WE WILL DO THE ADDITIONAL TEST AT AN ADDITIONAL CHARGE. Doug Denney – Integra asked when you refer to the additional testing rates on Exhibit A, is that referring to an existing rate or a new rate to be developed? Bob Mohr – Qwest said there is no new rate. It would be the rate that is in Section 9.20. Doug Denney – Integra indicated there is no rate called additional testing. Bob Mohr – Qwest indicated that it is additional cooperative testing. Doug Denney – Integra said additional cooperative testing applies during provisioning and installation and questioned whether there is an additional testing rate on repair? Bob Mohr – Qwest indicated that he would have to look at the full description since he was not familiar with all those descriptions. (MATRIX - QUESTION 1) Bob said it is not a new charge; we would charge from section 9.20 for testing for repair. Doug Denney – Integra asked if the facility fails the 196 KHz test during repair, is Qwest going to code that for performance measures as trouble on the Qwest network? Jamal Boudhaouia – Qwest asked if the correct NC/NCI codes are already on the loop? Doug Denney – Integra said let’s take each scenario. Jamal Boudhaouia – Qwest indicated if the correct NC/NCI codes are on the loop and the customer was working and now is not, if we performed the 196 KHz as well as other battery of tests that were mentioned, it would not be coded against the CLEC but would be a facility repair ticket on the Qwest network. Bob Mohr – Qwest indicated that if the circuit was in place today, it would not have been tested for 196KHz. If it then gets tested on repair and does not pass, the service can be reassigned to a compatible facility or you have the right to keep that service. Bob said if you keep the facility,we will want that documented since accepting it as is, there is little Qwest can do to better qualify that loop. One thing might be to do conditioning but if you want to go that way, we cannot improve on that insertion loss achieved by conditioning. Doug Denney – Integra questioned if that is on an embedded base circuit regardless if it has the correct NC/NCI codes? Bob Mohr – Qwest said if we find an incorrect NC/NCI code that does not match how the circuit is used, Qwest will test and repair at the level of service you tell us it is working at, but you are required to follow up with an order so there is no future disagreements. Doug Denney – Integra said in this embedded base scenario of using ADSL with the correct NC/NCI code on the loop, how will this get coded if it fails the 196KHz test? (MATRIX - QUESTION 2) Jamal Boudhaouia – Qwest indicated if for some reason this facility fails the 196 KHz test, we will look for a facility that will pass the test. Jamal said he has to assume that the service was working before and for some reason it is not working anymore. We will figure out the problem first and then determine steps to correct the problem which might include moving to a different binder group. You are not going to lose the service. Kim Isaacs – Integra asked if that is coded to a Qwest facility issue then. Jamal Boudhaouia – Qwest indicated right. Julia Redman-Carter – PAETEC repeated the scenario of an embedded base customer that has the correct NC/NCI code and trouble is reported. Qwest will go in and take care of it. Julia questioned if there is a charge for the repair for the 196KHz? Jamal Boudhaouia – Qwest indicated that he was not sure and would followup. (MATRIX - QUESTION 3) Julia Redman-Carter – PAETEC said the other scenario is an embedded base that has an improper NC/NCI code, is Qwest going to do the repair and then if necessary, I would need to follow up with an order to change NC/NCI code. Are those repairs charged? This would be outside of any conditioning. Bob Mohr – Qwest indicated he will have to check but that he thought the same answer will apply to both these scenarios. Julia Redman-Carter – PAETEC indicated so what I am hearing is if I have to pay for repairs and I have an embedded base where Qwest believes the NC/NCI code is improper that I may have to pay for repairs just to get the right service. Bob Mohr – Qwest indicated that he does not think we said we would or would not. We are looking into it. (MATRIX - QUESTION 4) Julia Redman-Carter – PAETEC questioned another scenario of the wrong NC/NCI code per Qwest. Will Qwest attempt to repair to the ADSL standard? What happens if Qwest does whatever repairs but the problem still exists. I change the NC/NCI code to ADSL. Will Qwest try to correct it then? What is the recourse? Jamal Boudhaouia – Qwest verified the scenario: CLEC told Qwest they have ADSL. The assumption is the loop has incorrect NC/NCI codes. We tried to fix it but it does not get fixed for some reason. You put in an order and then the circuit is not working anymore. Julia Redman-Carter – PAETEC said the order is to the wrong NC/NCI code but you are able to repair it. Julia verified if it was correct she had to follow-up with an order to change the NC/NCI code. Julia wanted to know if the order for the NC/NCI code would cause Qwest to change facilities or do something else other than changing paperwork. She wanted confirmation that it was not a new repair or a repeat ticket and that it did not change any facilities. Jamal Boudhaouia – Qwest indicated yes, that is a record change only. There would not be any change in facility. Julia Redman-Carter – PAETEC asked if she then has a problem on that repair ticket, she would use the new NC/NCI codes. Julia questioned if this is considered a new repair or a repeat ticket? Jamal Boudhaouia – Qwest said he was not familiar with that process. (MATRIX - QUESTION 5) Susan Lorence – Qwest said we would take that as an issue and include the answer in the meeting minutes. Kim Isaacs – Integra asked if the circuit ID was going to change if there was a change to the NC/NCI code? Jamal Boudhaouia – Qwest said the circuit ID will be the same and not change. Kim Isaacs – Integra (9/21/10 Comments in CAPS or deletions indicated to minutes from Integra) (deletes SAID) CONFIRMED QWEST (deleted YOU) will change the DLR and CSR to change NC/NCI codes but the circuit ID remains the same. Linda Harmon – Qwest said she would double check to make sure after Jamal said yes. (MATRIX - QUESTION 6) Bonnie Johnson – Integra said she wanted clarification following the discussion of what Qwest was not charging for. She requested confirmation of the charges recovered in non-recurring rates. Susan Lorence – Qwest said her question was to capture the tests for the notes rather than get into the specifics of how the charges would occur. Bonnie Johnson – Integra questioned that Qwest is not charging an additional charge but has said the tests are not free. (MATRIX - QUESTION 7) Bob Mohr – Qwest said that is right, we are not doing them for free but he did not know if they were recovered in MRC or NRC without knowing the studies. Jamal Boudhaouia – Qwest said he was not sure of the cost docket and how it applies to MRC or NRC but that we don’t charge separately today and we won’t charge separately going forward.

Susan Lorence – Qwest indicated that charges are outside the scope of CMP and that her question was to clarify the tests already there and which ones were part of this change. Bonnie Johnson – Integra said we have been talking about costs for half an hour. Susan Lorence – Qwest indicated not specific costs and what is included in them. Susan said we can clarify that as a separate issue and asked if Bob had finished review of the testing download. Bob Mohr – Qwest said yes and that the tests and their parameters are listed in the download. Julia Redman-Carter – PAETEC questioned if she has a customer that is on the grandfathered product and puts in an order to change them to ADSL, what happens. Julia wants to be sure it is still covered under their grandfathered product. Bob Mohr – Qwest asked if you are signing into the new enhancement or the current product? Julia Redman-Carter – PAETEC said if she has an embedded base customer on the ADSL compatible product that Qwest makes a repair on, she sends an order with the corrected NC/NCI. Her question is which NC/NCI to use, the one she has today that was wrong or the NC/NCI code with the ADSL compatible loop code. Bob Mohr – Qwest indicated that NC/NCI codes do not change regardless of whether it is the existing or enhanced product. The LXR- is the same and referred everyone to the Comparison matrix. Bob then discussed the matrix saying additional information was added to clarify some items. The Comparison matrix addresses pre-grandfathered, post-grandfathered, and then the enhanced offer. Julia Redman-Carter – PAETEC asked if there will be a distinction to identify the grandfathered customers. Bob Mohr – Qwest indicated that if you sign the amendment (9/21/10 Comments in CAPS to minutes from Integra) FOR THE ENHANCEMENT, Qwest will “un-grandfather” that product so you can order it. Bob said technically, it won’t be grandfathered in MN with the enhanced offer. Kim Isaacs – Integra said when a product is grandparented, she understood that they could get the product as it is in the ICA but during the next ICA negotiation, the product becomes unavailable and there is no way to move new customers to the product. When Qwest grandparented the ADSL loop, did it eliminate it? Bob Mohr – Qwest indicated that was correct; he had misspoke. When ADSL was grandfathered, if it was in your ICA, you could continue to order it. If it was not in your ICA then it was not available for new agreements. Julia Redman-Carter – PAETEC said if she has it in her current agreements and asked why she would need to sign the amendment? Is this just so Qwest can fix it when you wouldn’t before? Bob Mohr – Qwest said we would fix it before. The amendment defines certain parameters for the ADSL loop and referenced an example of the EML limits on page 2. Bob said there is a better definition of industry standards and provided some examples from the Comparison matrix. Kim Isaacs – Integra (9/21/10 Comments in CAPS or strikethrough to minutes from Integra) SAID (deleted ASKED IF) my ICA says I get ADSL compatible loops at industry standards, why sign the agreement. Jamal Boudhaouia – Qwest said you have it in your ICA and your agreement references the industry standards specifically to the 196 KHz. (9/21/10 Comments in CAPS or deletions indicated to minutes from Integra) (deleted THE AMENDEMT OFFERS) BOB IS OFFERING ENHANCEMENTS (deleted ADDITIONAL FEATURES) to the current product that enhances it in a number of ways - specifically conditioning which is offered as two tiers vs. one. Jamal said from a legal perspective, he cannot answer that but what you have in the agreement is what you have. Qwest is offering an amendment with enhancements. Kim Isaacs – Integra said (9/21/10 Comments in CAPS or deletions indicated to minutes from Integra) (deleted IF) what is in my agreement is what you call the enhancements, there is a difference in opinion. Susan Lorence – Qwest said we would take an action item on clarifying the legal definition of grandfathering. (MATRIX - QUESTION 8) Susan said we have talked grandfathering in CMP and she thought it was that you just couldn’t order it new but you could keep what you have in existence. Julia Redman-Carter – PAETEC said she is not disagreeing. Julia questioned what she is getting with this enhancement that she is not getting now. Her agreement says she can get services so that her customers can get the services they ordered and they have been getting it for years. Julia said she was going to send in a repair ticket and that she couldn’t get it fixed before but she is assuming that now this is available. She said it seems the general terms of my agreement are not enough and that specific language is needed and requested that be clarified. Jamal Boudhaouia – Qwest indicated that we will take that back. (MATRIX - QUESTION 9) Susan Lorence – Qwest asked whether we should go through the Comparison document any further or whether it was clear enough. Julia Redman-Carter – PAETEC indicated she would like to go through it to understand the differences and where she is now and where to focus. Susan Lorence – Qwest asked if there was something specific or should we start at the top. Julia Redman-Carter – PAETEC said let’s take Ordering; she then reviewed each column. For post-grandfathered, you wanted LXR- but she said many of theirs were ordered LX-N. Julia said she would be trying to get repair; the difference is that on the enhanced offer you have to enter the Remarks on the LSR. She doesn’t know it is an enhanced offer. Some things included are clarifications that are very specific vs. general differences. Julia said she is trying to understand what is the enhancement vs. what is a more detailed process not stated before. Bob Mohr – Qwest said the manual handling information in the Remarks section is related to the new tiers of conditioning. Before, you needed a Y in the SCA field for conditioning. With the enhanced offer, we need to know the type of conditioning you want so we can properly route the request. Or for a trouble ticket, so we can send it to the correct technician.

Julia Redman-Carter – PAETEC said in this one for ordering, it is for after the fact. Julia questioned if she needed to put the order in again (9/21/10 Comments in CAPS to minutes from Integra) SHE IS BACK IN A CIRCLE; she is not changing anything. Bob Mohr – Qwest indicated if this is a trouble ticket, we want the trouble report to include the type of conditioning so we can route it to the correct technician. Qwest has added scripting in the PCAT. Julia Redman-Carter – PAETEC said yes and submit an order after the fact. Bob Mohr – Qwest said if you only want conditioning and want Remove all conditioning, issue a trouble ticket for Remove all. No follow-up order is necessary. Bob said that assumes the NC/NCI codes are correct with how the circuit is used. Julia Redman-Carter – PAETEC said in a case of repair with the wrong code, an order is sent to change the NC/NCI code; is the order in the beginning? Bob Mohr – Qwest said that is a Record order after repair to change the NC/NCI code so there are no discrepancies going forward. Bob said that is no change from today - no other info is required. Kim Isaacs – Integra asked if manual handling is required on every order or just where they are unable to make the determination via Loop qual, etc. Can an order be sent in with LXR- and not drop to manual handling? (MATRIX - QUESTION 10) Linda Harmon – Qwest questioned if you are not asking for conditioning on the initial request? Kim Isaacs – Integra said yes. They do the pre-order steps and feel comfortable no conditioning is needed. (9/21/10 Comments in CAPS to minutes from Integra) INTEGRA SUBMITS THE ORDER BASED ON THE PRE-ORDER INOFRMATION THAT NO CONDITIONING IS REQUIRED. Linda Harmon – Qwest said to submit as usual; Qwest will still respond (9/21/10 Comments in CAPS or deletions indicated to minutes from Integra) (deleted SIMILAR TO TODAY) WITH A JEP if we find conditioning is needed. Kim Isaacs – Integra said today Qwest (9/21/10 Comments in CAPS to minutes from Integra) DOES NOT RESPOND WITH A JEP AS LINDA THOUGHT BUT QWEST is delivering it with all OF THAT on it. Linda Harmon – Qwest said she would verify what happens if you don’t ask for conditioning on an LXR-. (MATRIX - QUESTION 11) Susan Lorence – Qwest indicated that the time is almost up and there are a number of action items. Susan said she will create a matrix and also identify them in the meeting minutes. Susan requested attendees to review the Comparison matrix over the next couple days to determine if there are still questions; if so, send them to the CMPCR mailbox so we don’t delay in getting a response back. Bonnie Johnson – Integra said they can do that and was interested in next steps. Bonnie said she wanted to again say that Integra is requesting the CR be withdrawn until the MN proceeding has been decided and then a regulatory CR could be submitted. Bonnie said she knows Qwest plans to implement (9/21/10 Comments in CAPS to minutes from Integra) THE CR anyway. Susan Lorence – Qwest said our approach is to see if there are additional questions and to determine then if another ad hoc is required or if the questions can be answered by a response as part of the meeting minutes. Then, if there are no outstanding points, Susan said we would like to proceed with a Level 4 notification for Minnesota as Mark Nickell had originally identified. Mark Nickell – Qwest confirmed that is the strategy at this point. Susan Lorence – Qwest said we will note Integra’s request to withdraw this CR and wait until the MN proceeding. Julia Redman-Carter – PAETEC questioned if we feel there is a need for an ad hoc, should that be sent in with our questions. Susan Lorence – Qwest said yes. Julia Redman-Carter – PAETEC indicated that she would like another ad hoc call to understand the testing differences better. Susan Lorence – Qwest said after reviewing the matrix, the discussion from the call, and the documentation that is posted, if you believe another ad hoc call is necessary then please let us know. Jim Hickle – Velocity said he wanted to echo Integra to remove the CR until the MN proceedings are done. Jim said we are re-doing things over and over again and wasting time with this. He said he appreciated all the great conversation on the call especially the work that PAETEC and Integra had done. Jim said from the beginning, he wanted the CR withdrawn immediately and stands by that. Susan Lorence – Qwest indicated that we will note that as well. Julia Redman-Carter – PAETEC said for the record PAETEC feels the same and echo Integra’s position because she feels she is doing this multiple times. Susan Lorence – Qwest thanked everyone for participating and requested participants review the documentation and matrix and send in any additional questions. Susan said we will work on the questions from today and then determine next steps. Susan said our intent is to move forward with this unless there are additional questions. Meeting adjourned at 1:01 pm MT. 9/10/10 Email sent to PAETEC and Integra Attached is a revised document that provides the before/after comparison information requested by both PAETEC and Integra. The document was also posted to the Wholesale calendar entry in preparation for the ad hoc meeting on September 13, 2010. [Comparison document that was attached can be viewed on Wholesale calendar entry http://wholesalecalendar.qwestapps.com/ on 9/13/10.] 8/24/10 Email received from Integra Integra agrees with PAETEC and joinsIntegra agrees with PAETEC and joins in the request. This is not the first time that Integra has requested this information. In my 7/26/10 email to Qwest, I said: “Mark Nickell, who presented Qwest’s short paragraph at the monthly CMP meeting, was also present during negotiations with Integra. In addition, please provide in advance of the call the side-by-side comparison of each aspect of the process previously used for ADSL (including facilities assignment, the algorithm used for facilities assignment, tests conducted for provisioning and repair, NC and NCI codes used, etc.) before and after Qwest grandparented ADSL over CLEC objection, as requested by PAETEC on the CMP call and previously by Integra.” Integra previously requested this information at a meeting in May attended by Mr. Nickell. Please provide the requested information in sufficient time for the CLECs to review the information before the next scheduled ad-hoc call. 8/24/10 Email received from PAETEC Qwest indicated on the CMP Ad Hoc call that it provided the document titled “CR PC072010-1 Change in process in Minnesota for Non Loaded and ADSL Compatible Loops used to provide xDSL services” in response to PAETEC’s earlier request in CMP. That document, however, does not provide the requested information. PAETEC asked for a before/after comparison from before Qwest grandparented ADSL compatible loops with after Qwest would implement its proposed change request. To clarify, PAETEC asked for, in addition to a detailed comparison of the Qwest grandparented ADSL compatible loops with the Qwest proposed change request, the associated details of the differences regarding ordering, repair, standards, intervals, conditioning, processes, etc in a side-by-side, point-by-point comparison. Qwest’s document does not contain most of the “before” information. Under key differences, only the first bullet point gives before and after information (“The reintroduced ADSL Compatible Loop (LXR-) Maximum AML db loss: =78.dB @196khz, whereas the standard in the grandfathered product is = 41db @ 196 khz.”). The other bullets appear give the “after” (i.e., after implementation of the CR). In contrast, for example, the next bullet point, says that, after implementation, ADSL loops will be assigned based on a formula and loop make-up records. It does not address before ADSL was grandparented. Therefore, there is no comparison. Before Qwest grandparented ADSL, ADSL loops were assigned based on a formula and loop make-up records. Therefore, any before/after difference is not apparent. Why is this information identified as a key difference, and what is the difference? Qwest is in the process of scheduling another ad hoc call regarding this CR where the comparison document would be reviewed. Before the next call, please provide an updated document that gives the before, as well as the after, information for each bullet in the document titled “CR PC072010-1 Change in process in Minnesota for Non Loaded and ADSL Compatible Loops used to provide xDSL services” and all the points addressed in the grandparented ADSL product. Also, please include before/after differences, if any, in NC or NCI codes and USOCs as well. 8/23/10 Ad hoc Meeting Attendees: Kasha Fauscett – Comcast, Brenda Bloemke – Comcast, Doug Denney – Integra, Bonnie Johnson – Integra, Kim Isaacs – Integra, Laurie Roberson – Integra, Karen Clausen - Integra, Mike Starkey – QSI Consulting (on behalf of Integra), Julia Redman-Carter - PAETEC, Bill Haas – PAETEC, Anna Bell – Enventis/Hickory Tech, Bob Mohr – Qwest, Mark Nickell – Qwest, Jamal Boudhaouia – Qwest, Linda Harmon – Qwest, John Hansen – Qwest, Rachel Ruiz - Qwest, Susan Lorence - Qwest Susan Lorence – Qwest began the meeting by relaying that Mark Nickell from Qwest presented this Qwest CR PC072010-1 in the July CMP monthly meeting. The ad hoc meeting is to review the revised PCAT and downloadable documents, and review the comparison document requested by PAETEC of how the ADSL LXR- product differs from the grandfathered ADSL product. We will take questions after each section rather than all at the end. We will then discuss next steps. Mark Nickell – Qwest (9/1/10 - Comments in CAPS to minutes received from Integra) SAID IT SHOULD BE AN INTERESTING CALL AND provided an overview of the CR indicating Qwest will be making a change specific to Minnesota to add information regarding new optional processes for Facility Assignment, Conditioning, and Performance Testing of the Unbundled Local Loop - 2-Wire or 4-Wire Non-Loaded Loop and Asymmetric Digital Subscriber Line (ADSL) Compatible Loop. Discussion will be led by Bob Mohr and Jamal Boudhaouia, Qwest SMEs. Bob Mohr – Qwest relayed that there are 3 key areas that include proposed changes. First is conditioning, second is facility assignment and third is testing. There are some changes to the Unbundled Local Loop General Information PCAT but the changes are minimal. Bob indicated that unless there are specific comments to the product PCATs, he would like to move on to the downloads. Bonnie Johnson – Integra said the ADSL PCAT updates went from Version 23 to Version 25 and said that there are questions outstanding on Version 24. Bonnie relayed that this causes confusion and Qwest had previously agreed to not make overlapping updates. These proposed changes do not reflect Version 24. Jamal Boudhaouia – Qwest indicated that these were 2 different areas. The ADSL Version 24 update relates to testing if it is in your ICA. These updates to Version 25 ADSL updates are associated with general 2 or 4 Wire Non-loaded Loop that is xDSL capable associated with an amendment to the ICA.

Susan Lorence – Qwest indicated that we did receive comments on the Version 24 ADSL Level 3 notice and are currently working on setting up an ad hoc call to go over those changes. Susan said we would like to hold off on Version 24 questions until the ad hoc call.

Bonnie Johnson – Integra indicated that this should be retracted until Version 24 is resolved.

Susan Lorence – Qwest said that there is nothing in formal review so there is nothing to retract. Bonnie Johnson – Integra indicated that they disagree. Bonnie questioned the changes in the 2nd paragraph on Unbundled Local Loop 2 & 4 Wire Non loaded Loop. She said that the NC/NCI change that is being removed is not specific to Minnesota and questioned why it is being removed. Bob Mohr – Qwest indicated that the reason it is being removed is that currently the NC/NCI is informative and not dependent on the Minnesota change but was meant globally. Bonnie Johnson – Integra said shouldn’t this change be a Level 2 for document changes. Susan Lorence – Qwest relayed that per the CMP document, Qwest can include related Level 2 changes in a Level 3 notice but it was noted by Integra that this is a Level 4 change and Susan replied she thought the same language applied. Bonnie Johnson – Integra said this change should not be included in the CR that is for MN only. Brenda Bloemke – Comcast concurred. Julia Redman-Carter – PAETEC agrees since it affects the 14 state. Susan Lorence – Qwest relayed that we will take this as a point to consider as its own Level 2 update. Bonnie Johnson – Integra requested information on what the determination is. She then asked for an explanation why this is in MN only. Mark Nickell – Qwest indicated that as we moved towards implementation, Qwest ran into a variety of operational challenges and decided on a one state deployment initially to make sure that everything was going to work. Mark said (9/1/10 - Comments in CAPS to minutes received from Integra) BECAUSE OF ISSUES IN Minnesota IT was the best choice due to service concerns there but that Qwest fully intends to expand at a later date. Bonnie Johnson – Integra asked what are the challenges. Mark Nickell – Qwest indicated that there were issues with USOCs, (9/1/10 - Comments in CAPS to minutes received from Integra) LOOP BACK DEVICES, testing and training to obtain better efficiencies. He said there was more work and a whole host of issues that raised the question of going global or implement at a state level AND BE LESS THAN SATISFACTORY initially. MARK SAID QWEST WAS DOING TESTING FOR IMPLEMENTATION IN MN. Karen Clausen - Integra referred to the variety of stages of a CR and wanted to know if Qwest implemented before the CR was presented and what Qwest was implementing. Mark Nickell – Qwest indicated that no this was not implemented; the analysis all hinged around the operational process which included equipping the wire centers, installing the Loop back devices to do the testing, training technicians, etc. associated with initial preparation to have the field force ready to go. Susan Lorence – Qwest relayed there was no official implementation. Karen Clausen – Integra asked what is the difference between preparation and official implementation. Mark Nickell – Qwest reiterated nothing has started. He indicated that the technicians are now being trained and ready to deploy. Technicians are doing testing for operational efficiencies so that when we are ready to begin, there will be as few issues as possible. (9/1/10 - Comments in CAPS to minutes received from Integra) Mark Nickell – Qwest reiterated nothing has started. He indicated that the technicians are now being trained and ready to deploy. Technicians are doing testing for operational efficiencies so that when we are ready to PULL THE TRIGGER, there will be as few issues as possible. Susan Lorence – Qwest relayed that Bob Mohr will go through the first download of process. Bob Mohr – Qwest indicated that for xDSL capable loops, we will be adding in 3 new options to condition circuits: 1) LXR- Conditioning, 2) LX-N Conditioning and 3) Remove All Conditioning. These will be available on provisioning as well as repair and can be requested via a repair ticket. Bob then reviewed the content included in the Conditioning download. Bob said Qwest is not required to remove Stub Cable and for the Remove All option, Qwest would remove everything from the Loop with the exception of anything that is inaccessible due to safety concerns or buried plant. Bob asked if there were any questions. Bonnie Johnson – Integra asked why are these downloads? We asked for an amendment. Bob Mohr – Qwest indicated that at this phase, there is a redlined PCAT. The downloads are not in place of the amendment. Bonnie Johnson – Integra asked when will the amendment be available. Bob Mohr – Qwest indicated after the PCAT updates. Then will provide rates. Bonnie Johnson – Integra indicated that in the monthly CMP meeting it was relayed that the amendment will have more detail. Mark Nickell – Qwest relayed that was correct. Bonnie Johnson – Integra asked how levels 1 and 2 of conditioning are different than today. Bob Mohr – Qwest said that there is no 3rd option of Remove All. Bonnie Johnson – Integra said that the difference between level 1 and 2 is that you do this today and level 3 is new. (9/1/10 - Comments in CAPS to minutes received from Integra) Bonnie Johnson – Integra ASKED IF that the difference between level 1 and 2 is that you do this today and level 3 is new (9/1/10 - Comments inCAPS to minutes received from Integra) BOB MOHR – QWEST STATED 2 IS WHAT WE DO TODAY, 1 IS ADDING REMOVAL OF NEAR AND FAR END BRIDGE TAP AND OPTION 3 IS NEW. Julia Redman-Carter – PAETEC questioned if LXR- and LX-N conditioning only apply to products with matched NC/NCI codes. Bob Mohr – Qwest indicated yes, that was correct. The only way to know is NC/NCI. Julia Redman-Carter – PAETEC asked if you are addressing old NC/NCI codes that do not match the product. Bob Mohr – Qwest indicated that this will be covered as part of the assignment of facilities. If NC/NCI code is different, during repair if you advise Qwest, we will repair the service to the new NC/NCI code combination but we will expect an order from the CLEC to correct records. (9/1/10 - Comments in CAPS to minutes received from Integra) BOB SAID QWEST WILL NOT REFUSE TO RESTORE THE CIRCUIT BECAUSE OF THE NCI CODE. Julia Redman-Carter – PAETEC confirmed Qwest would not refuse to repair. Jamal Boudhaouia – Qwest indicated that as long as we have agreement from the CLEC s to send an order to correct the records. Susan Lorence – Qwest asked for clarification on whether Qwest would or would not refuse to repair service. Jamal Boudhaouia – Qwest indicated that Qwest will not refuse a repair ticket. (9/1/10 - Comments in CAPS to minutes received from Integra) Jamal Boudhaouia – Qwest indicated that Qwest will not refuse TO REPAIR. Julia Redman-Carter – PAETEC asked if there was a guarantee for no change to facility or disruption. Jamal Boudhaouia – Qwest said Qwest can not guarantee no change to facility. In a repair situation, the existing facility may be defective and as such a new facility may be required. Also, if the existing facility does not meet the NC/NCI code loss parameters, Qwest will strive to find the best facilities that would meet these parameters. Bonnie Johnson – Integra requested the definition of inaccessible bridge tap. Bob Mohr – Qwest provided some examples, e.g., if it is buried, Qwest will not dig up buried plant, OSHA standards due to safety restrictions. Bob also said Qwest will not remove stub cable. Mike Starkey – QSI requested to go through LXR- and LX-N 2 or 4 Wire Non Loaded loop terminology. Bob Mohr – Qwest indicated that LXR- is ADSL Compatible. Bob said to request conditioning, a CLEC may indicate in the Remarks section the type of conditioning they are requesting. The request will drop for manual handling. Bob indicated there was a long-term goal to update the IMA SCA field. Bob said the change could not get into the fall release but possibly the spring release. Bob relayed that Qwest would ask for pre-approval before starting the work by having the customer place a Y in the SCA field to indicate pre-approval. He said that would be a benefit to both parties; there would be no disputed charges. Bob said there was an exception; if first approved for LX-N or LXR- conditioning and then Qwest needed to Remove All bridge tap to meet parameters. (9/1/10 - Comments in CAPS to minutes received from Integra) Bob Mohr – Qwest indicated that LXR- is ADSL Compatible. Bob said to request conditioning, a CLEC MUST PUT A Y IN THE SCA FIELD. The CLEC MUST DROP THE request for manual handling. Bob indicated there was a long-term goal to update the IMA SCA field. Bob said the change could not get into the fall release but possibly the spring release. Bob relayed that Qwest would ask for pre-approval before starting the work by having the customer place a Y in the SCA field to indicate pre-approval. He said that would be a benefit to both parties; there would be no disputed charges. Bob said there was an exception; if first approved for LX-N or LXR- conditioning and then Qwest needed to Remove All bridge tap to meet parameters. Bonnie Johnson – Integra asked if Qwest is charging for both? Bob Mohr – Qwest indicated that if we charge, it would only be a charge to Remove All. (9/1/10 - Comments in CAPS to minutes received from Integra) Bob Mohr – Qwest indicated that if the THE LXR- OR LX-N CONDITIONING DID NOT BRING THE CIRCUIT IN LIMITS, it would only be a charge to Remove All. THERE WOULD BE BOTH CHARGES IF A SECOND TECHNICIAN HAD TO BE DISPATCHED TO DO THE REMOVE ALL BUT QWEST WOULD NOT CHARGE BOTH CHARGES IF IT DID NOT REQUIRE AN ADDITIONAL DISPATCH. Doug Denny – Integra said that there is only one rate in MN and asked if Qwest knew what the rates are. Bob Mohr – Qwest indicated there will be three new rate elements planned Susan Lorence – Qwest said charges were outside of the CMP discussion. Mark Nickell – Qwest clarified that two new rates are planned and we are still working on rates. Doug Denny – Integra indicted that this is important for the CLECs to have rates. Bob Mohr – Qwest relayed that the rates have to go through the normal avenue for approval. Doug Denny – Integra indicated that CLECs must authorize conditioning. If it is not requested, do you do it? Bob Mohr – Qwest indicated that we will only bill and perform it (9/1/10 - Comments in CAPS to minutes received from Integra) ONLY if is necessary for the service. Bob said he does not believe we would automatically Remove All. If the customer authorizes Remove All and it is necessary to achieve parameters, Qwest will perform it. Julia Redman-Carter – PAETEC asked if that was stated in the document and that clarification would be helpful. Bob Mohr – Qwest indicated that it is not clearly stated. Doug Denny – Integra asked if request “Remove All,” you will only do if requested? (9/1/10 - Comments in CAPS to minutes received from Integra) Doug Denny – Integra asked if request “Remove All,” you will only do if REQUIRED? Bob Mohr – Qwest said yes. Bonnie Johnson – Integra said rates have to be approved by the Commission and that was a commitment due to the Expedite CR. (9/1/10 - Comments in CAPS to minutes received from Integra) Bonnie Johnson – Integra said rates have to be approved by the Commission and that was a commitment QWEST MADE FOR the Expedite CR AND DIDN’T DO IT. Bob Mohr – Qwest stated that we would ultimately seek Commission approval. Karen Clausen – Integra asked what the pre-approval rate process is and what process will Qwest follow in MN for unapproved rates. (9/1/10 - Comments in CAPS to minutes received from Integra) KAREN ASKED IF QWEST WILL IMPLEMENT THIS BEFORE RATES ARE APPROVED. Mark Nickell – Qwest indicated that Bob and Mark are Product but that we would be adhering to whatever legal guidelines apply. Bob Mohr – Qwest indicated that in regard to Repair for all options, Qwest is looking for CLEC help in scripting the TR (trouble report). If they are not electronically bonded tickets, Qwest will enter the scripting as we need to insure what is being requested and what we are going to bill for is clear. Bob Mohr – Qwest said for a conditioning request to Remove All, Qwest will provide a quote back and will not do anything until we get a response back. Bob referred to Section 9.20 of the ICA in regard to rates for quoted charges. Bob said for jobs greater than 8 hours, there is a quote prior to removing conditioning. Doug Denny – Integra what happens if there is additional time over 8 hours. (9/1/10 - Comments in CAPS to minutes received from Integra)DOUG ASKED IF QWEST WILL CHARGE THE REMOVE ALL PLUS ANY TIME OVER 8 HOURS. Bob Mohr – Qwest indicated that we bill additional time and said there are two rate elements and provided a description of the two rate elements. Bob said the quote will only include the time over the 8 hours. A customer does not have to request the first level of conditioning in order to request Remove All. The “Remove All” can be requested up front. Bob said no rates will be applied more than once for the life of the circuit. Mike Starkey – QSI said he heard there are 2 rate elements and asked if the current one was being replaced or are they in addition. Bob Mohr – Qwest indicated that the new rates will take the place of the current one and that an amendment will replace the current rates. Bob indicated that you currently get BT and LC removal per CSA guidelines. 9/1/10 - Comments in CAPS to minutes received from Integra) Bob Mohr – Qwest indicated that the new rates will take the place of the current one and that an amendment will replace the current rates. KIM ISAACS – INTEGRA ASKED WHAT YOU GET FOR THE CURRENT RATE. Bob MOHR - QWEST indicated that you currently get BT and LC removal per CSA guidelines. Karen Clausen – Integra asked if this was per CSA guidelines. Bob Mohr – Qwest provided a response that covered the lengths as included in the Conditioning download. Doug Denny – Integra questioned is that the LX-N conditioning today and was the rate replaced? 9/1/10 - Comments in CAPS to minutes received from Integra) Doug Denny – Integra IF THE NEGOTIATED RATE WILL BE REPLACED BECAUSE IT WAS NEGOTIATED IN A COST CASE ALONG WITH MANY OTHER RATES? Bob Mohr – Qwest indicated that was correct and it will replace what is in the ICA. Bob said that covers conditioning and he would move to assignment of facility where he reviewed the information included in the Facility download and provided examples. 9/1/10 - Commentsin CAPS to minutes received from Integra) BOB MOHR – QWEST SAID QWEST WILL USE THE NC/NCI CODES TO ASSIGN TO INDUSTRY STANDARDS TODAY QWEST IS NOT USING NC/NCI CODES FOR ASSIGNMENT AND QWEST WILL ASSIGN TO EML. Kim Isaacs – Integra asked what Qwest is doing today of these steps. Jamal Boudhaouia – Qwest responded that today we do not take NC/NCI codes into the equation. Going forward, Qwest will take them into consideration and 9/1/10 - Comments in CAPS to minutes received from Integra) WILL USE ANSI STANDARDS AND TEST AT 196 AND will calculate insertion loss. Jamal then described some industry limits based on NC/NCI codes that are included in the download. For instance, limits on the ADSL loops are 18 kfeet in length where as SHDSL and/or MVL could work on loops that are 25 kfeet or longer. Kim Isaacs – Integra relayed that after reading the Tech Pub, she thought that NC/NCI codes are informational and that the LXR- is not considered during provisioning. Jamal Boudhaouia – Qwest indicated that the NC code is taken into consideration 9/1/10 - Comments in CAPS to minutes received from Integra) FOR LXR- AND LX-N WHICH ARE A WHOLE HOST OF SERVICES. It is correct that in the Tech Pub, NCI code is for information only. JAMAL SAID THE COMBINATION OF THE NC AND NCI CODES IS INFORMATIONAL ONLY. In IMA, NC code drives the product USOC to the downstream systems such as LFACs. Jamal indicated that the NC code is considered part of non-loaded. To pre-qualify a loop for a particular service such as ADSL, the CLEC should go through IMA Loop qual tools. Kim Isaacs – Integra indicated that she was aware of the pre-qualification in IMA but you cannot reserve the loop if you see availability. Kim said on an LXR- order, Qwest doesn’t look at it when the order is sent 9/1/10 - Comments in CAPS to minutes received from Integra) BECAUSE QWEST SAID THE NCI CODE IS INFORMATIONAL ONLY. Jamal Boudhaouia – Qwest said we do not put a limit on the loop and agreed that you cannot reserve facilities as a matter of process. Qwest can not reserve facilities for itself or any other customer without an order. Kim Isaacs – Integra said we run loop qualification, send the order for ADSL, it goes into the Qwest system and Qwest ignores LXR-. Jamal Boudhaouia – Qwest said that we don’t ignore the LXR-. Kim Isaacs – Integra indicated she is trying to determine the difference between what is done currently today and the change. Bob Mohr – Qwest indicated that today we have a USOC or 9/1/10 - Comments in CAPS to minutes received from Integra) ADSL AND WE USE THE NC/NCI for determining what product you want. Today, we don’t restrict it on length or NC code. Jamal Boudhaouia – Qwest stated the enhancement is that we will adhere to standards based on EML. Currently, we don’t restrict loop length or loss to assign LXR-. The proposal is to provision loop that meet Loss requirements that are compliant to ANSI standards. Bob Mohr – Qwest indicated that there are loss limits for those products. Bonnie Johnson – Integra said she was confused on ADSL and questioned when Qwest grandfathered this product over objections, you said you were putting on limitations. How did you come up with 196 kHz? Bob Mohr – Qwest relayed that limits were set up in the past and that he was not familiar with the history. Jamal Boudhaouia – Qwest said the 196 kHz test is a technical question based on T1 417. Jamal addressed the hypothetical calculation for wide band DSL testing. Karen Clausen – Integra asked 9/1/10 - Comments in CAPS to minutes received from Integra) HOW QWEST WAS PICKING THE TESTS AND if this was for wide band testing only and was that the industry standard. Jamal Boudhaouia – Qwest indicated that the question is for 196 kHz testing and that 196 kHz is 9/1/10 - Comments in CAPS to minutes received from Integra) AT THE MFF IS ACCEPTABLE AND IS wide band testing. Jamal raised the question of impulse noise and whether it was important and which standard it applied to. Karen Clausen – Integra said she is trying to find out about the proposed change and questioned whether impulse noise testing is part of the CR and if not part of the proposal, would Qwest consider it. Jamal Boudhaouia – Qwest 9/1/10 - Commentsin CAPS to minutes received from Integra) ASKED WHY IT WAS IMPORTANT. Jamal relayed that we have not looked at it but will consider it and would talk to the techs to understand. Karen Clausen – Integra 9/1/10 - Comments in CAPS to minutes received from Integra) SAID THERE ARE MANY QUESTIONS AND asked what standards were considered. Jamal Boudhaouia – Qwest indicated ANSI T1- 417, 413 and 418. 9/1/10 - Comments in CAPS to minutes received from Integra) JAMAL BOUDHAOUIA - QWEST SAID THAT IT WAS A 5 POINT STANDARD AND RELAYED THAT WE HAVE NOT LOOKED AT IT BUT WILL CONSIDER IT AND WOULD TALK TO THE TECHS TO UNDERSTAND. QWEST INDICATED ANSI T1- 417, 413 AND 418. Bob Mohr – Qwest indicated that Testing standards are documented in the next download. Susan Lorence – Qwest indicated that we were out of time and she will schedule another ad hoc meeting. Karen Clausen – Integra said that Integra continues to object 9/1/10 - Comments in CAPS to minutes received from Integra) BECAUSE THERE IS A MN PROCEEDING GOING ON and requests that Qwest retract this Minnesota only CR until the legal issues are resolved. She said that at that point, a Regulatory CR should be issued. Karen said however, if Qwest schedules further ad hoc calls, Integra would attend. Julia Redman-Carter – PAETEC indicated she did not fully understand the objections but that she wanted to make note that PAETEC 9/1/10 - Comments in CAPS to minutes received from Integra) HAS A GENERAL OBJECTION AND has not agreed to anything until she is sure she understands the issues. Meeting adjourned at 11:07 am MT. 08/18/10 Product Process CMP Meeting Mark Coyne – Qwest indicated that this CR was presented last month. He indicated that Qwest had scheduled an ad hoc meeting on August 12 but it has since been rescheduled to August 23, 2010. The red lined documents have been posted to the Wholesale Calendar. PAETEC requested a comparison of products in last month’s meeting. This comparison document has also been posted to the Wholesale Calendar. Brenda Bloemke – Comcast asked if he said the documents were on the calendar for next Monday. Mark Coyne – Qwest indicated that the meeting is on August 23 and the documents can be pulled from the calendar. Bonnie Johnson – Integra wanted it noted that as stated in her email, Integra objects to Qwest moving forward and Qwest is moving forward anyway. Mark Coyne – Qwest said the objection was so noted. 8/6/10 Email Response received from Integra When rescheduling, Integra is not available August 17th, 18th and 19th so please avoid those dates. 8/6/10 Email Response received from Velocity Due to a previous commitment, I cannot attend this Ad Hoc meeting and due to its importance to Velocity, I respectfully request that it be rescheduled for the following week. 7/27/10 Email Response received from PAETEC Thank you for the heads-up. PAETEC wants to participate on that call. Unfortunately, I have a conflict from 10:00am to 12:30pm CT (Tuesdays and Thursdays) on August 12 that I can not change. I would appreciate it if you would arrange the meeting around that time frame on August 12. 7/26/10 Email Response received from Integra Integra re-iterates its earlier comments, which Qwest has failed to address or satisfy. Although Qwest acknowledges that rates are outside the scope of CMP, Qwest is nonetheless implementing a new process in CMP that it admitted during the monthly CMP meeting will result in new charges. This is the same approach used by Qwest and rejected by the Arizona commission previously, when the Arizona Commission said, in Arizona Decision No. 70557 (p. 32 line 26 – p. 33 line 1), Docket No. T-03406A-06-0257: “We concur with Staff, and caution Qwest to review its procedures so that the CMP is not utilized to change Commission-approved rates.” The fact that Qwest will implement new rates, but refuses to discuss them, highlights the objectionable nature of Qwest’s unilateral action. The federal Act and rules require Qwest to negotiate with CLECs in good faith. It is not good faith to implement a process via CMP that requires an ICA amendment while not providing the ICA amendment to CLECs for review. Regardless of whether Qwest provides its proposed amendment in CMP or separately, please provide Qwest’s proposed amendment (before any ad hoc call or other CMP activity). Please indicate whether Qwest’s proposed amendment (which was referenced by Qwest in CMP) is the same as the proposed amendments that Integra and PAETEC have already rejected in negotiations and, if not, please identify any differences. CLECs cannot meaningfully review proposed changes without knowing what rates would be associated with those changes. As previously indicated, If Qwest does change its PCAT and procedures in this regard, Qwest will have to provide the changed process at existing Commission approved rates, unless and until Qwest obtains approval of different rates from the state commissions. Enclosed is a matrix of Commission-approved line conditioning rates. Please confirm whether Qwest intends to provide any changes to its line conditioning practices at Commission-approved rates. Qwest has not obtained agreement on an input approach as required by CMP Document Section 5.4.5.1 and should not be proceeding without that agreement. If Qwest nonetheless proceeds with its unilateral ad hoc call, please ensure that any Qwest representatives on the call are familiar with all of the written materials and discussions that have occurred to date in both of the previous CRs and associated escalations (see CR #PC082808-1IGX; CR #PC020409) and that they are familiar with the Qwest-Integra negotiations, including the written matrices and explanatory comments provided to Qwest by Integra. Mark Nickell, who presented Qwest’s short paragraph at the monthly CMP meeting, was also present during negotiations with Integra. In addition, please provide in advance of the call the side-by-side comparison of each aspect of the process previously used for ADSL (including facilities assignment, the algorithm used for facilities assignment, tests conducted for provisioning and repair, NC and NCI codes used, etc.) before and after Qwest grandparented ADSL over CLEC objection, as requested by PAETEC on the CMP call and previously by Integra. Even with this information, Qwest’s proposed approach is wholly inadequate to provide input and certainly to reach any kind of business resolution, particularly in this context, when years of raising operational issues, business and CMP escalations, and multi-state negotiations, in addition to MN Commission-ordered settlement negotiations, have not resulted in resolution. As indicated below, timing of events, combined with the fact that Qwest’s Change Request is for Minnesota only, shows that the real driver of Qwest’s sudden and surprise decision to walk-on a short, vague Minnesota-only Change Request about this important, long-disputed CLEC-affecting issue is Qwest litigation tactics directed at Minnesota docket number P-6312, 421/C-08-1381 (the MN UNE Provisioning Docket). ATTACHMENT INCLUDED WITH EMAIL - 1Cable Unloading (100809) 7/26/10 Email Response received from Velocity I still request that this CR request, CR PC072010-1, be removed by Qwest pending the settlement of the 1066 docket in Minnesota. 7/26/10 Email Response sent from Qwest Qwest is planning to hold an ad hoc meeting(s) to gain CLEC input on the proposed optional product offering associated with PC072010-1. We are currently looking at the date of August 12 with meeting notification provided by August 5. At that time, the redlined PCAT documents will be made available on the Wholesale calendar entry along with an agenda. Qwest will not be providing rate or amendment documents as they are outside of the scope of CMP. With that in mind, a discussion of rates and/or amendments will not be a part of the CMP ad hoc meeting. 7/23/10 Email Response received from PAETEC PAETEC agrees with Integra as stated below in the email from Bonnie Johnson. 7/23/10 Email Response received from Integra In response to your email yesterday, Integra and its entities (Integra) disagree with Qwest. Qwest cannot excuse a clear violation of the terms of the CMP Document by claiming it is ok because Qwest always violates it. The CMP Document states in Section 5.4.5.1 on page 45: Qwest will present the Change Request at the Monthly CMP Product/Process Meeting. The purpose of the presentation will be to: · Clarify the proposal with the CLECs · Confirm the disposition level of the Change (see below). · Propose suggested input approach (e.g., a 2 hour meeting, 4 meetings over a two week period, etc.), and obtain agreement for input approach · Confirm deadline, if change is mandated · Provide proposed implementation date, if applicable See http://www.qwest.com/wholesale/cmp/ (emphasis added). This shows that it is Qwest’s obligation to propose a suggested input approach. Qwest failed to do so, and clearly Qwest failed to obtain agreement. Qwest is also in violation of CMP because Qwest said at the CMP meeting that there would be rates associated with Qwest’s changes, but rates and the application of rates are outside the scope of CMP and cannot be implemented via CMP. For example, in Arizona Decision No. 70557 (p. 32 line 26 – p. 33 line 1) , Docket No. T-03406A-06-0257, the Commission said: “We concur with Staff, and caution Qwest to review its procedures so that the CMP is not utilized to change Commission-approved rates.” If Qwest does change its PCAT and procedures in this regard, Qwest will have to provide the changed process at existing Commission approved rates, unless and until Qwest obtains approval of different rates from the state commissions. Regarding the point raised by Jim Hickle of Velocity as to improper notice, there is support in the CMP Document for the notion that CLECs may raise issues by walk-on whereas Qwest cannot (for the simple reason that Qwest can control the timing of implementation of CLEC requests, while the reverse is not true and CLECs cannot control the timing of Qwest changes). The CMP Document refers to walk-on items as being originated by CLECs: “CRs that are not submitted fourteen (14) calendar days prior to the Monthly CMP Systems Meeting may be introduced at that Monthly CMP Systems Meeting as walk-on items. The Originating CLEC will present the CR . . .” Section 5.1.4, p. 30 (emphasis added). Even assuming walk-ons are available to Qwest, Qwest should use judgment in, and have defensible reasons for, presenting issues as walk-ons. This is not an issue that arose suddenly so as to prevent Qwest from providing 14 calendar days notice. In fact, this issue has been through CMP twice before, and on both occasions Qwest denied CLECs’ requested resolution of the issues. (See CR #PC082808-1IGX; CR #PC020409 and, e.g., the enclosed documents.) Also enclosed are two chronologies that shed further light on events related to this issue over a number of years. The change is a Level 4 Change Request (CR). The CMP Document states in Section 5.4.5 on page 45: “Level 4 changes are defined as changes that have a major effect on existing CLEC operating procedures or that require the development of new procedures. Level 4 changes will be originated using the CMP CR process and provide CLECs an opportunity to have input into the development of the change prior to implementation” (emphasis added). Yet, Qwest’s Change Request (enclosed) is all of one paragraph long, and it simply lists topics with no information whatsoever about how Qwest’s handling of these major issues will change. Qwest also provided no adequate, legitimate business reason why its Change Request is limited to Minnesota only, when Qwest’s problem processes exist throughout its 14-state territory. It is impossible to provide input on something so short and ill defined. Timing of events shows that the real driver of Qwest’s sudden and surprise decision to walk-on a short, vague Minnesota-only Change Request about this important, long-disputed CLEC-affecting issue is Qwest litigation tactics directed at Minnesota docket number P-6312, 421/C-08-1381 (the MN UNE Provisioning Docket). A Change Request properly submitted fourteen calendar days before the July 21, 2010 monthly CMP meeting would have been submitted on July 7, 2010. The day after, on July 8, 2010, Integra filed with the MN PUC, in the MN UNE Provisioning Docket, a Motion for Prehearing Conference in which Integra requested specifically that the first deadline to be scheduled should be for Qwest’s overdue response to the Joint CLEC’s 11/24/09 comments. (The MN ALJ then scheduled a prehearing conference for July 27, 2010.) The timing, combined with the fact that the Qwest CR is limited to MN-only, shows that Qwest simply threw together a wholly inadequate paragraph and walked it on during the CMP meeting to enable Qwest to argue for more delay in the docket because, according to Qwest, the issues are now being addressed in CMP. Jim Hickle of Velocity has already expressed, in his email below, his view of such tactics. We disagree the issues are being addressed in any meaningful or proper way in CMP. As the ALJ found in the MN Qwest-Eschelon ICA Arbitration: “Eschelon has provided convincing evidence that the CMP process does not always provide CLECs with adequate protection from Qwest making important unilateral changes in the terms and conditions of interconnection.” (MPUC P-5340,421/IC-06-768, Arbitrators’ Report, ¶ 22). CLECs have already used CMP twice for these issues, and Qwest’s Change Request serves no purpose but for Qwest to act unilaterally and cause further delay. It is no response to this to say that Qwest is claiming the changes are allegedly “optional,” when the alternative is the current Qwest process which is already in violation of ICAs and federal law, as explained in detail in Joint CLECs’ 11/24/09 MN comments and attachments. Even assuming the issues go forward in CMP in this manner, Qwest has not provided any workable approach to proceeding in CMP for process and procedures that need changing throughout its territory. To the extent Qwest proposes an input approach at all in its email below (which does not meet the CMP Document requirement of presenting the proposal at a CMP Meeting), Qwest said that it is willing only to schedule “an ad hoc meeting prior to the notification and redlined documents being distributed” (emphasis added). Based on past experience, Qwest’s reference to “redlined documents” refer to redlines to its own online Product Catalog (PCAT). Integra made a specific request to see Qwest’s full proposals, including Qwest’s proposed amendment, which Qwest ignores. At this point, CLECs have no idea if Qwest’s proposed amendment referenced in by Qwest in CMP looks anything like the proposed amendments that CLECs in MN have already rejected in negotiations. CLECs cannot assess a proposal without knowing the associated proposed rates, which based on previous experience, Qwest provides not in the PCAT but in the amendment. Qwest’s email suggestion is not an “input approach,” because CLECs can hardly provide input on proposed changes they have never seen. An ad hoc call, even assuming it occurs after Qwest’s provides its proposed documentation, amendment, and rates, is also wholly inadequate to provide input and certainly to reach any kind of business resolution, particularly in this context, when years of raising operational issues, business and CMP escalations, and multi-state negotiations, in addition to MN Commission-ordered settlement negotiations, have not resulted in resolution. ATTACHMENTS INCLUDED WITH EMAIL - 1 RE: Qwest Binding Response to Integra and affiliates ("Integra") Escalation PC082808-1IGX Denied; 2 Integra position response - Integra and affiliates ("Integra") Escalation PC020409-1EX Denied; 3AttachmentK.xDSL Summary of Key Events; 4ATTACHMENT R.xDSL SUMMARY - PAETEC; 5PC072010-1 7/23/10 Email Response received from Velocity Thanks for the politically correct Qwest response, but I object to this type of “negotiation” tactic by Qwest. The introduction of this CR may be by the rules, but it does not pass the smell test in my mind and I believe it is not ethical and with ulterior motives. If Qwest is going to have some implementation challenges and that is why they chose to implement it in only one state on a trial basis that they choose another state because of the 1066 Docket and Investigation. This issue is important to us and I object to the way it was introduced. I feel like it was introduced under the radar without proper notification to all interested parties especially in light of the 1066 Investigation. I formally request that this CR request, CR PC072010-1, be removed by Qwest pending the settlement of the 1066 docket in Minnesota. 7/22/10 Email Response sent from Qwest Qwest followed the same approach as it has for other CRs. Once the originator has presented the CR, the originator asks if there are any questions. If there are none, Qwest typically relays the notice will be distributed with the proposed documentation updates. In this instance, Mark Nickell presented the CR, took questions from the CLEC community, and relayed the redlined documents would be available soon. Mark Nickell responded to several CLEC questions in regard to the CR however no CLEC requested an ad hoc meeting to discuss this change in more detail. When Mark Coyne relayed the redlined documents would be made available via the notification, there was no disagreement on this proposal during the meeting. Qwest assumed this approach for gaining input to the change request was satisfactory. Typically, if an ad hoc meeting is required, it is requested by the CLEC community. Qwest assumed agreement on this approach to gain input. If members of the CLEC community would prefer to have an ad hoc meeting prior to the notification and redlined documents being distributed, Qwest is certainly willing to schedule one.

7/21/10 Email Response received from Integra On today’s CMP call, Qwest presented a Change Request (CR) that was not provided at least 14 calendar days before the meeting per CMP Document. Instead, Qwest presented the CR as a walk-on agenda item today. Per Section 5.4.5.1 of the CMP Document, when presenting any CR, Qwest must: “Propose suggested input approach (e.g., a 2 hour meeting, 4 meetings over a two week period, etc.) and obtain agreement for input approach” (emphasis added). Qwest did not propose an approach or obtain agreement. The meetings or collaborative to provide input to Qwest’s proposal will naturally be unproductive if CLECs do not have the terms upon which CLECs are to provide input. As I stated on the CMP call today, Integra will review Qwest’s proposal and respond. We need to understand the proposal to provide meaningful input. Integra and its entities (Integra) request that Qwest provide its proposed input approach to CLECs as required by Section 5.4.5.1, as well as Qwest’s full proposal and proposed amendment, for CR # CR PC072010-1.

07/21/10 Product Process CMP Meeting Mark Nickell – Qwest presented this CR. Mark indicated Qwest will be making a change specific to Minnesota to add information regarding new optional processes for Facility Assignment, Conditioning, and Performance Testing of the following services: Unbundled Local Loop - 2-Wire or 4-Wire Non-Loaded Loop and Asymmetric Digital Subscriber Line (ADSL) Compatible Loop. The enhanced optional processes will include: defined parameters for assignment of copper pairs, assignment of the pair with the least amount of loss in the cross box, new levels of conditioning (near and far bridge tap and remove all options), enhanced tests for specific types of NCI codes. Mark identified that the expected deliverable date is September. Next steps are to provide redlined PCATS regarding proposed changes. Mark relayed this is an optional offering and that the initial target state is Minnesota.

Bonnie Johnson – Integra asked why this is Minnesota specific.

Mark Nickell – Qwest relayed that when we got to looking at the implementation, we ran into operational challenges and decided on a one state deployment initially to make sure that everything was going to work according to plan. Mark said Minnesota was the most likely choice due to service concerns there.

Bonnie Johnson – Integra said she was not sure that made sense. Bonnie asked if there are associated charges.

Mark Nickell – Qwest indicated that there would be additional charges. Mark relayed the product would be offered under an amendment which would include more specificity.

Mark Nickell – Qwest [7/29/10 - Comments to minutes received from Integra] said that there would be charges and it will require an amendment which will include more detail than usual.

Julia Redman-Carter – PAETEC asked how this ADSL product compared to the one that was grandfathered in 2007.

Mark Nickell – Qwest indicated that it is very close.

Julia Redman-Carter – PAETEC indicated that she would like to see (7/23/10 - Comments to minutes received from PAETEC) the details of how this ADSL product differs from the old grandfathered ADSL product. 7/27/10 NOTE: The grandfathered product is associated with CR PC121106-1 available on the CMP website at url http://www.qwest.com/wholesale/cmp/archive/CRPC121106-1.html. The grandfathered PCAT is available at http://www.qwest.com/wholesale/pcat/unloopadslcompatloop.html. (7/23/10 - Comments to minutes received from PAETEC) Mark Nickell – Qwest committed to provide a comparison noting the differences between this ADSL product and the grandfathered ADSL product.

Bonnie Johnson – Integra indicated that they would take this back for internal review.

Mark Coyne – Qwest relayed that if we get this information, we will include it in the minutes for this meeting. If is not available by then, we will send out a notice. SEE 7/27/10 NOTE ABOVE.