Wholesale: Products & Services

Open Product/Process CR PC072604-1 Detail

Description Of Change

Expected Deliverable: As soon as possible

Project Meetings

8/18/04 CMP Meeting John Berard presented the CR saying that Covad is looking for a one day interval on line share orders. He had seen some notices with one day intervals from Qwest and is looking for the same thing in Wholesale. The CR will move to Presented status.

-- Clarification Meeting

1:00 p.m. (MDT) / Thursday August 5, 2004

1-877-521-8688 1456160# PC072604-1 Line Sharing Provisioning Interval Attendees

John Berard, Covad Doug Andreen, Qwest Heidi Moreland, Qwest Crystal Soderlund, Qwest Bob Mohr, Qwest

Meeting Agenda: Action 1.0 Introduction of Attendees Introduction of participants on the conference call was made and the purpose of the call discussed. 2.0Review Requested (Description of) Change Doug Andreen, Qwest read and reviewed the CR. The CR is titled Line Sharing Provisioning Interval and the description reads Covad proposes that a one day interval be provided for all Line Sharing Family of products that do not require a field dispatch. Qwest has shown that this is possible as outlined in the attached two accessible letters. Doug ask John Berard, Covad if he had anything to add to the description and he said not really that it was pretty self explanatory Heidi Moreland, Qwest asked if the request was for Line Sharing only or did it include Line Splitting or all the shared loop products. John answered that Line Sharing as the primary product with Line splitting being nice to have. John also added that the CR just includes those orders that involve CO work only. There were no further questions and the meeting was concluded. 3.0 Confirm Areas & Products Impacted Line Sharing and Line Splitting 4.0 Confirm Right Personnel Involved Correct personnel were involved in the meeting.

5.0 Identify/Confirm CLEC’s Expectation To be done as soon as possible. 6.0 Identify any Dependent Systems Change Requests TBD 7.0 Establish Action Plan (Resolution Time Frame) John Berard, Covad will present the CR at the August CMP meeting. Qwest will respond at the September meeting.

CenturyLink Response

October 12, 2004

For Review by the CLEC Community and Discussion at the October 20, 2004 CMP Meeting

TO: John Berard Director Operations Support COVAD Communications

SUBJECT: CLEC CR - PC072604-1 Line Sharing Provisioning Interval

Covad proposes that a one day interval be provided for all Line Sharing Family of products that do not require a field dispatch and states “Qwest has shown that this is possible as outlined in the attached two accessible letters”. (See Supplemental Information)

This request is respectfully denied due to No Measurable Benefit to both Qwest and the CLEC.

The intervals offered in the documentation attached to the CR were short in duration and limited in scope – thus promotional. Promotional offerings by Qwest are not mechanized and therefore limited in order to provide a service for customers that would otherwise either not be accommodated or that would take time and costly system changes to effect. These promotional offerings were noticed to the CLEC community so that they too could take advantage of this interval during this time frame in this market. They are neither, by virtue of their short term nature, permanent nor extendable outside of the designated market.

Permanent interval changes, as mentioned above, affect both the systems and the work force. CLEC intervals are set to ensure parity and/or to provide a competitor a meaningful opportunity to compete. Qwest’s intervals were evaluated during Third Party testing, in some cases specific product intervals were ruled upon by state commissions and Qwest’s actual commercial performance (which is driven by existing intervals) was repeatedly found acceptable by the FCC in its evaluation of Qwest’s 271 applications. Additional changes are accommodated as process changes are made that can reduce the interval or where retail intervals are likewise reduced (where there is a comparable retail equivalent product).

COVAD has also entered a Commercial Agreement with Qwest that went into effect on October 2, 2004. That document states that the Line Sharing interval shall be Three (3) Business Days. While a CMP change in interval could be negotiated between the parties prior to October 2, such a change would be in effect at most 10 days in duration when that CMP negotiation would be superceded by the stated interval in your Commercial Agreement.

Because of their intensive nature, interval changes are costly and difficult to price. As Qwest is not required to undertake the substantial, costly modifications and upgrades to its systems and processes to allow a CLEC to order UNEs and other services at an interval different than the standard interval for the product and there is negative measurable benefit to Qwest and no demonstrable gain over the options already offered to the CLEC, this request is respectfully denied.

Sincerely,

Qwest

- September 8, 2004

DRAFT RESPONSE For Review by CLEC Community and Discussion at the September 2004 CMP Meeting

John Berard Director Operations Support Covad

SUBJECT: Qwest’s Change Request Response PC072604-1 Line Sharing Provisioning Interval

This letter is in response to Covad’s Change Request (CR) PC072604-1. This CR requests that Qwest provide a one day interval for all Line Sharing Family of products that do not require a field dispatch.

Qwest is currently evaluating this request and proposes moving this Change Request into Evaluation Status while we continue to investigate. Qwest will provide an updated response at the October 2004 CMP meeting.

Sincerely,

Cindy Buckmaster Product Manager - Qwest