Wholesale: Products & Services

Open Product/Process CR PC081705-1 Detail

Description Of Change

Project Meetings

Cindy Buckmaster-Qwest stated that the denial response is located in the March Distribution Package. Cindy said that Covad is requesting the right to maintain the DSL on an existing circuit in the event the telephone number is ported off Qwest’s switch. She said that CMP is a process for is a warehousing effort for all CLECs and would not be fair to Qwest as information related to ports away from other providers will not be available and could not be pro-actively noticed. She said that this would be a CPNI violation to other providers and that we can’t accept this request via CMP. Lynn Hankins-Covad stated that she would have to get back to Qwest. Lynn asked if the reason for the denial is that divulging Qwest information is confidential. Cindy Buckmaster-Qwest said that we can divulge Qwest information as a CLEC but cannot divulge any other CLECs information. She said that this makes it unfair to Qwest as a CLEC. Lynn Hankins-Covad stated that she would get back to Qwest and that she may request an adhoc meeting.

2/15/06 Product/Process CMP Meeting

Cindy Buckmaster-Qwest stated that another clarification meeting was held with Covad because of the changes in personnel on this request. She said that Qwest fully understands the request and that a response will be provided in the March CMP Meeting. Lynn Hankins-Covad asked if Qwest received the 2 e-mails she sent to Lynn Stecklein (Qwest). Lynn Stecklein-Qwest stated that the 2 e-mails were received and that Qwest is currently reviewing. Lynn asked if there was a specific question Covad wanted to address now.

Lynn Hankins-Covad said no, that she was confirming that the e-mails were received.

Jill Martain-Qwest said that this CR will remain in Evaluation and a response will be provided in the March Meeting.

1/31/06 Adhoc Meeting with Covad

Attendees: Lynn Hankins - Covad, Cindy Buckmaster - Qwest, Paul Schlater - Qwest, Alan Braegger - Qwest, Shirley Tallman - Qwest, Jamal Boudhaouia - Qwest, Lori Burchett - Qwest, Lynn Stecklein - Qwest

Lynn Stecklein - Qwest stated that Qwest requested an additional clarification meeting with Covad in the January CMP Meeting to further discuss this CR.

Cindy Buckmaster - Qwest stated that several of the SMEs working on this CR were no longer with Qwest and that we wanted to get a clear understanding of what Covad was requesting on this CR.

Lynn Hankins - Covad said that they were Covad is looking to maintain DSL on existing circuits in the event the telephone number is ported off Qwest’s switch. She also said that they would like to know 1st if the line is taken down and would like to keep with no downtime to the customer.

Cindy Buckmaster - Qwest said that Covad would not be the Voice Provider and that Covad's principal product is the DSL. She said that the voice provider is the controller of the circuit.

Lynn Hankins - Covad said that they would notification whether or not Qwest or the CLEC is the owner of the line.

Cindy Buckmaster - Qwest asked if Lynn Hankins (Covad) was aware of any other CR submitted in the past requesting the same thing as this CR.

Lynn Hankins - Covad stated that she was not aware of any.

Cindy Buckmaster - Qwest stated that this CR will remain in Evaluation and that Qwest will provide a response if the March Product/Process CMP Meeting.

1/18/06 Product/Process CMP Meeting

Cindy Buckmaster - Qwest said that several SMEs are no longer with Qwest and that we would like to have a meeting with Covad to discuss this CR. Lynn Hankins - Covad stated that she was fine with having another adhoc meeting. Jill Martain - Qwest said that Lynn Stecklein (Qwest) will contact Lynn Hankins (Covad) to schedule a meeting.

12/14/05 Product/Process CMP Meeting

Jill Martain/Qwest stated that we are still evaluating all options and feasibility on this CR. She said that this CR will remain in evaluation and that we will provide a status in the January CMP Meeting.

11/16/05 Product/Process CMP Meeting

Lynn Stecklein/Qwest stated that this request was placed in evaluation last month. She said that internal discussions are still underway to ensure all potential solutions are reviewed and analyzed. She stated that an updated response will be provided in the December CMP Meeting

10/19/05 Product/Process CMP Meeting

Anthony Washington/Qwest said that we would like to place this CR in evaluation status in order to continue with analysis of the existing process and look at potential solutions for this change request. He said that Qwest will provide an updated response at the November CMP meeting. Jill Martain/Qwest stated that this CR will move to Evaluation status.

9/21/05 Product/Process CMP Meeting

Liz Balvin/Covad stated that they are seeking the right to maintain DSL on existing circuit in the event the telephone number is ported off Qwest’s switch. Bonnie Johnson/Eschelon asked if this is just for line sharing. Liz Balvin/Covad stated it would apply to Line Splitting and Line Sharing when the number is ported out. Jill Martain/Qwest stated that this CR will move to presented.

E-mail send to Covad

Hi Liz,

In the Line Sharing environment, the orders are issued directly by the DLEC.

In the case of Line Splitting, Qwest understands that DLECs can issue orders under the 'owning' carriers (Customer of Record) log in as per arrangement between the CLEC and DLEC. LSOG 6-LSR field 7b is listed as DLEC CCNA - CCNA (Customer Carrier Name) for DLEC (Data Local Exchange Carrier) The Customer of record is required to populate this field for Line Splitting, which is how Qwest identifies the DLEC.

Let me know if you have additional questions.

Thanks,

Lynn Stecklein Qwest Wholesale CRPM 303 382-5770

8/31/05 E-mail from Covad

Lynn,

Thanks, I do have an additional question. In the Line Sharing environment, while the orders are issued by DLECs under owning carriers company code information, how does Qwest identify the DLEC?

Thanks,

Liz

--Original Message-- From: Stecklein, Lynn [mailto:Lynn.Stecklein@qwest.com] Sent: Wednesday, August 31, 2005 8:20 AM To: Balvin, Elizabeth Subject: Re: PC081705-01 First Right of Refusal Procedures

Hi Liz,

This is in response to your question regarding how Qwest identifies the line is shared. Qwest floats FIDS after the Line Assignable USOC that is shared and that is how we recognize it. The Line Splitting product mirrors the Line Share product in this way. Let me know if you have further questions.

Thanks,

Lynn Stecklein

Qwest Wholesale CRPM

303 382-5770

--Original Message-- From: Balvin, Elizabeth [mailto:ebalvin@covad.com] Sent: Monday, August 29, 2005 1:37 PM To: Stecklein, Lynn Subject: RE: PC081705-1 First Right of Refusal Procedures

Lynn,

To follow-up on when the line that exists is line splitting (UNE-P plus DSL):

Covad would like to understand how Qwest identifies the line is shared?

Thanks,

Liz

--Original Message-- From: Stecklein, Lynn [mailto:Lynn.Stecklein@qwest.com] Sent: Tuesday, August 23, 2005 9:22 AM To: Balvin, Elizabeth

8/25/05 Clarification Meeting

Attendees: Liz Balvin - Covad, Crystal Soderlund - Qwest, Heidi Moreland - Qwest, Ellen McArthur - Qwest, Anthony Washington - Qwest, Lynn Stecklein - Qwest

Review Description of Change Lynn Stecklein - Qwest reviewed the CR description. Covad stated that Qwest currently lacks procedures surrounding existing shared lines whereby the TN is ported and the circuit remains available for use. Covad seeks the right to maintain DSL on existing circuit in the event the telephone number is ported off Qwest’s switch. Scenarios include (but may not be limited to): Existing services = 1) line splitting 2) line sharing and an LNP order is received to port number to 1) cable 2) VoIP or 3) wireless. Procedures to consider surround notification allowing first right of refusal and billing changes.

Discussion: Crystal Soderlund - Qwest asked if the customer was currently with Covad or would this apply to any owner of shared service and if this was Line Splitting would Covad be the owner. Liz Balvin - Covad said no. Liz asked asked how they maintain a number porting on a standalone disconnect of voice. Liz said that she would like a process implemented to notify Covad and asked how Qwest maintains the DSL on the loop. Crystal Soderlund - Qwest said that we don't because we lose it. Liz Balvin - Covad stated that Verizon has a manual workaround today where they provide a spreadsheet for losses. Crystal Soderlund - Qwest stated that Qwest has a process to notify the voice provider via the loss and completion report. Heidi Moreland - Qwest asked if Covad wanted wanted this information before the disconnect was completed. Liz Balvin - Covad said that they would prefer the information prior to the disconnect completion and that this would prevent customer downtime. Crystal Soderlund - Qwest said that with line splitting, the loss is not to the voice provider. Crystal said that line splitting should be removed from this CR. She said that Qwest would not know because we only have 1 customer of record. Liz Balvin - Covad stated that she needed to check internally on the line splitting portion of the CR

Confirm Areas and Products Impacted Line Split/Shared

Establish Action Plan Liz Balvin - Covad will present this CR in the September 21st Product/Process CMP Meeting

CenturyLink Response

For Review by CLEC Community and Discussion at the March 2006 CMP Meeting

Lynn Hankins Covad Communications

SUBJECT: Change Request Response - PC081705-1 First Right of Refusal

This letter is in response to Covad’s Change Request (CR) PC081705-1. Covad is requesting the right to maintain the DSL on an existing circuit in the event the telephone number is ported off Qwest’s switch. The CR includes scenarios for Line Splitting and Line Sharing where an LNP order is received to port a number to a cable, VOIP or Wireless provider.

Qwest has evaluated this CR and finds that implementing Covad’s request would require proactive notification. Additionally, it would only be technically feasible to perform this function in circumstances where the voice circuit belongs to Qwest.

ILECs such as Qwest are obligated to treat all service providers in a similar fashion. Since Qwest is only aware of the request in those instances where the porting or disconnection of a Qwest voice circuit is required, Qwest cannot provide proactive notification in 100 percent of the cases where porting or disconnecting a voice circuit will also affect a corresponding DSL service. This would create an uneven playing field, and would pose serious legal problems concerning the entire porting process.

For the reasons cited above, Qwest respectfully denies the request.

Sincerely,

Qwest Corporation

10/11/05 Draft Response

For Review by the CLEC Community and Discussion at the October 17th CMP Meeting

October 11, 2005

Covad Liz Balvin

SUBJECT: CR # PC081705-1 First Right of Refusal Procedures

This letter is in response to Covad's Change Request (CR) PC081705-1 First Right of Refusal Procedures. This CR requests that Qwest Covad seeks the right to maintain DSL on existing circuit in the event the telephone number is ported off Qwest’s switch. Scenarios include (but may not be limited to): Existing services = 1) line splitting 2) line sharing and an LNP order is received to port number to 1) cable 2) VoIP or 3) wireless. Procedures to consider surround notification allowing first right of refusal and billing changes.

Qwest would like to place this CR in evaluation status in order to continue with analysis of the existing process and look at potential solutions for this change request. Qwest will provide an updated response at the November CMP meeting. Qwest will move this CR to Evaluation status.

Sincerely,

Qwest