Wholesale: Products & Services

Open Product/Process CR PC082808-1IGXES Detail

Description Of Change

Integra communicates the type of service it intends to provide on 2/4 Wire Non-Loaded Loops by using the appropriate NCI/SECNCI codes on the Local Service Request (LSR). However, Qwest has indicated that it now designs, provisions and repairs the circuits to voice grade parameters measured at 1004 Hz, regardless of the NCI/SECNCI code requested on the LSR. The Network Code NC: LX-N indicates that a CLEC is ordering within the Non-Loaded Loop family. As discussed below, it supports a number of digital services depending upon the NCI/SECNCI codes provided on the LSR (e,g., Digital DS0 Level, Advanced Digital Transport, ADSL, Basic Rate ISDN, HDSL2 …). Therefore, an order of LX-N with the NCI code of 02QB9.00H and a secondary NCI code (“SEC”) of NCI 02DU9.00H tells Qwest that it needs to provision, test, and repair for HDSL2 capable service. For example, Qwest needs to ensure that the loop meets the appropriate performance parameters. Each digital service has its own parameters, such as:

• Voice grade analog circuit with Loss at 0 to -8.5 dB at 1004 Hz

• ISDN service Loss at less than 40 dB at 40 kHz

• ADSL service Loss at less than 41 dB at 196 kHz

• HDSL2 service Loss at less than 28 dB at 196 kHz.

When Integra raised the issue of Qwest limiting digital services to voice grade parameters with its Qwest Service Management team, Qwest responded by indicating that “Qwest does not provision requests to meet a specific facility or technology, but rather provisions a class of service, based on the NC codes the CLEC orders.” Integra continues to believe that its current Interconnection Agreements (“ICAs”) require Qwest to provide unbundled loops that transmit digital signals in addition to voice-grade service, etc. Integra reserves its rights under its ICAs. At the same time, in an effort to resolve this issue and at the request of Qwest, Integra is requesting in CMP that Qwest develop and maintain the process and procedures needed to design, provision, test and repair Unbundled Loops so that the circuit will conform to the requirements requested by CLEC, including compliance with the industry standards for the NCI/SECNCI code provided on the LSR. On 7/23/08, Qwest proposed that Integra submit a change request in CMP, including asking Qwest to design, provision, test and repair services in way that takes into account NCI/SECNCI codes standards instead of just the NC codes. Integra includes that request in this CR.

Qwest’s Technical Publication 77384 indicates that a number of advanced digital services are provisioned on Non-Loaded Loops (NC: LX-N), using a variety of NCI/SECNCI codes (for example: Advanced Digital Transport in a variety of spectrum classes, Basic ISDN – NCI: 02QC5.OOS, HDSL - NCI: 02QB9.00H). Qwest’s Technical Publications indicate that the NCI/SECNCI codes conform to the various ANSI standards for the specific digital service. However, as noted earlier, the Qwest service management team confirmed that it is Qwest’s current practice to design, provision, test and repair these digital services delivered on Unbundled Loops based on the NC code which delivers voice grade parameters measured at 1004Hz, even though each digital service has its own parameters for optimum performance. Integra is requesting that Qwest use the industry standards for NCI/SECNCI codes provided on the LSR when designing, provisioning, testing and repairing Unbundled Loops. For example, an Unbundled Loop ordered on the LSR with the Basic ISDN NCI: 02QC5.OOS should be designed, provisioned, tested and repaired per industry standards using a loss based on 40 kHz, not the voice grade 1004 Hz. Additionally, an Unbundled Loop ordered on an LSR with HDSL NCI 02QB9.00H should be provisioned using loss based on 196 kHz. When Qwest grandparented the ADSL compatible loop (only for CLECs without any ADSL compatible loop terms in their ICAs), Qwest pointed to the 2 Wire Non-Loaded Loop as an alternative to the ADSL compatible loop. However, per Qwest’s current stated position regarding designing, provisioning, testing and repairing to the NC code only, the 2 Wire Non-Loaded Loop would not be a reliable or serviceable alternative to an ADSL compatible loop. For a 2 Wire Non-Loaded loop to be a viable alternative to an ADSL compatible loop, Qwest should design, provision, test and repair digital capable Non-Loaded loops (such as HDSL capable or ADSL compatible loops) based on the NCI code as well.

While Qwest has said that it does not provision requests to meet a specific facility or technology, it should provision requests in compliance with industry standards and as ordered by CLEC, including providing working digital capability/compatibility when that capability is ordered. The SGATs, like the recent Qwest-Eschelon Minnesota and Arizona ICAs (§9.2.2.3), define 2/4 wire non-loaded loops as “digital capable” loops. The SGATs and the recent Qwest-Eschelon ICAs (§9.2.2.1.1 & 9.2.2.1.2) provide that use of the words “capable” and “compatible” to describe Loops means that Qwest assures that the Loop meets the technical standards associated with the specified Network Channel/Network Channel Interface codes, as contained in the relevant technical publications and industry standards. Qwest’s stated position that its current process recognizes only the “Network Channel” code but not the “Network Channel Interface” is inconsistent with this long-established principle. Similarly, the Qwest-Integra Oregon ICA has been in place since 2000 (for Integra as well as other CLECs, as it is based on the Qwest-AT&T ICA). That ICA (Att. 3, §2.1 and subparts) defines an unbundled loop to include loops that transmit digital signals and provides that CLEC may order special copper loops unfettered by any intervening equipment and which do not contain any bridged taps, so that CLEC may use the loops for a variety of services by attaching appropriate equipment. For example, when a CLEC orders an HDSL2 capable loop (identified on the LSR by using the NC code of LX-N with the NCI code of 02QB9.00H and a SEC code of NCI 02DU9.00H), the CLEC should receive a loop unfettered by intervening equipment so that CLEC may provide working HDSL2 service over the HDSL2 capable loop by attaching appropriate equipment. Regarding repair after a Qwest maintenance or modernization event, the SGATs and recent Qwest-Eschelon ICAs (§9.1.9) provide that network maintenance and modernization activities will result in UNE transmission parameters that are within transmission limits of the UNE ordered by CLEC. If CLEC orders a 2/4 wire non-loaded loop that is digital capable (such as ADSL compatible or HDSL2 capable), then the loop must be restored to the appropriate digital capable level after a Qwest maintenance or modernization event. In short, if a loop qualifies for a digital service, the circuit should work (and continue working) for that digital service.

Qwest will design, provision, test and repair Unbundled Loops to the requirements ordered by CLEC, including industry standards for the NCI/SECNCI codes provided on the LSR. Qwest should take into account NCI/SECNCI code standards, and not just the NC codes. When a CLEC orders a 2/4 wire non-loaded loop for providing a digital service (e.g., as identified using the applicable NCI/SECNCI code on the LSR), Qwest will not limit the design, provisioning or repair of 2/4 wire non-loaded loops to voice grade parameters (e.g., measured at 1004 Hz). After repairs and Qwest network maintenance and modernization changes, the end user customer’s service should work for the service ordered by CLEC.

Project Meetings

3/18/09 Prod/Proc CMP Meeting Bob Mohr-Qwest reviewed the denial response that can be located in the CR description as follows: The Unbundled Non Loaded Loop product was developed to interface with various applications contained in Technical Publication 77384. For Unbundled Loop LX-N Network Channel (NC) codes, the NCI codes are informational only, as stated in the above mentioned Technical Publication and do not affect transport designs or performance. The associated NC code requires that the service use non-loaded, metallic facilities free of faults (grounds, shorts, noise, or foreign voltage). The CLEC has responsibility to inspect the character of the facilities, e.g. gauge, length, etc and determine that the facility is appropriate for their specific application. Because Qwest is under no obligation to provide the product in the manner requested by CLEC, and Qwest is only obligated to provide a Non Loaded Loop to the broader standards listed in Technical Publication 77384, this Change Request to Design, Provision, Test and Repair Unbundled Loops to the requirements of the NCI code required a business discussion regarding the benefit to providing Non Loaded Loops in this manner vs. the cost to do so. That is, because there is no obligation to provide Non-Loaded Loops in this manner, the decision to implement this CR becomes one of economics. Absent the CLEC community agreement to negotiate in good faith to perform cooperative testing, this request becomes economically not feasible for Qwest. Therefore, Qwest respectfully denies this request. Bonnie Johnson-Integra commented that from Integra’s perspective hearing that NC/NCI codes are informational only is a surprise and they don’t agree.(3/27/09 Comments to minutes received from Integra) Bonnie said Qwest can name a product whatever it wants, but it doesn’t change Qwest’s obligations. Bonnie said that they are escalating this and the other denied CR. She said that Integra has provided detailed information .(3/27/09 Comments to minutes received from Integra) in its CRs and in the response about testing and Qwest hasn’t responded .(3/27/09 Comments to minutes received from Integra) to any detail. Bonnie said that .(3/27/09 Comments to minutes received from Integra) you do not negotiate in CMP. You negotiate ICAs they don’t agree that Qwest doesn’t have an obligation to what has been negotiated in the ICAs and have a right to this type of loop and Qwest can’t continue negotiate. She said that they want a revised response for both CRs .(3/27/09 Comments to minutes received from Integra) the respond to the cites and detail Integra provided. Liz Balvin-Covad said that Qwest is provisioning a product they can’t test and turn up in a mechanized way. Bob Mohr-Qwest said that Qwest is provisioning a non loaded loop product with an HDSL interface. Liz Balvin-Covad asked if this was being done manually. Bob Mohr-Qwest said it uses the standard provisioning Unbundled Loop provisioning process. Kim Isaacs-Integra asked Qwest to explain an HDSL interface. Jamal Boudhaouia-Qwest said that we provide a 2-4 wire non loaded loop with the capability to transport multiple protocols. Jamal said we give access to the Raw Loop data through IMA and we don’t restrict the use of the loop. He said that we let the CLEC determine what protocol they want to support. Kim Isaacs-Integra said if they find the loop there is no way to reserve the most compatible loop. Jamal Boudhaouia-Qwest said that it is the same for Qwest with no reservation and it is first in first out. Kim Isaacs-Integra said that Qwest .(3/27/09 Comments to minutes received from Integra) has already said it does this for itself. Qwest service runs through the CSA guidelines. Jamal Boudhaouia-Qwest said that is a finished service and (3/27/09 Comments to minutes received from Integra) and has a USOC associated with an NC/NCI code. He referred to tech pub 77384. The CLEC community has the opportunity to order the DS-1 capable loop that is the same as the retail offering that Qwest offers its end users. Kim Isaacs-Integra said they provide the NC/NCI code. Jamal Boudhaouia-Qwest said that the NC/NCI codes are for information only as documented in tech pub 77384. Bonnie Johnson-Integra said that the industry drives the NC/NCI codes and Qwest tech pubs are intended to be based on the industry standard. She asked if Qwest was insinuating that they develop a product and pick the NC/NCI codes out of a hat. Liz Balvin-Covad said the loop is provisioned to the specified NC/NCI codes but you don’t provision to the HDSL functionality. Jamal Boudhaouia-Qwest said that you could qualify a loop for HDSL and that the NC code determines the type of loop being requested. Kim Isaacs-Integra said that in reality you order HDSL or ADSL using LX-N and the appropriate NC/NCI codes. Kim said that pre-qual, in the past, has delivered a loop that does not support the functionality. She said that when a bridge tap issue is identified, Qwest says they only need to provide to voice grade standards and still does not understand why NC/NCI codes are informational only. Jamal Boudhaouia-Qwest said that the NCI codes are used for spectrum management purposes within copper.(3/27/09 Comments to minutes received from Integra) but not for provisioning or testing. The language in the ICAs and the negotiation template provides the reasons for the CLECs to provide Qwest with the correct NC/NCI code combinations. Liz Balvin-Covad asked why Qwest only provisions to voice grade. Jamal Boudhaouia-Qwest said that network was built and managed to voice grade. However, we provision the non-loaded loop to a higher grade than voice grade. As most every one here knows, voice grade can run on loaded loops. So Qwest provisions the non-loaded loops to a higher grade than voice grade. Liz Balvin-Covad asked what happens when it is non loaded and when you test and run into the situation that it has to be conditioned. Kim Isaacs-Integra said that the argument with Qwest is the definition of excessive bridge tap and the amount of bridge interference. Kim said that there are issues with the digital and voice grade parameters. Jamal Boudhaouia-Qwest said that digital data services, by definition, encompass any digital bits ranging from 9.6KB up to 20 Megs and digital data service could be supported on bridge tap. Jamal said that he wanted to get back to Covad’s question of manual vs. mechanized. Liz Balvin-Covad asked when they order 2/4 wire that is in their contracts, does Qwest have the ability to assign the loop electronically. Jamal Boudhaouia-Qwest said it is assigned electronically and that the order will flow through IMA. Liz Balvin-Covad asked if the USOC was available. Jamal Boudhaouia-Qwest said the USOC is not available for the HDSL capable loop. Liz Balvin-Covad-asked if HDSL is a Qwest supported functionality. Jamal Boudhaouia-Qwest said HDSL is a protocol to provide DS1 which could be provided using multiple technologies HDSL, AMI, SONET etc. He said that HDSL is just one of the protocols. Jamal said that using the 2/4 wire non loaded loop, the mux will generate the HDSL signal to transport DS1. Liz Balvin-Covad asked what excessive bridge tap is and will Qwest remove. Kim Isaacs-Integra said that is where they run into trouble. Jamal Boudhaouia-Qwest said that there are different requirements for different protocols and technologies. Liz Balvin-Covad-asked why this CR was being denied for economically not feasible reasons. Bob Mohr-Qwest said that the CR is being denied because of the cost of the equipment to perform the testing and the training required for the technicians to perform HDSL testing. Jamal Boudhaouia-Qwest said that we don’t do manual testing from the Central Office for Qwest today. Jamal said that after provisioning the testing is done through the centers. He said that we have asked the CLEC community to negotiate a testing process for HDSL similar to what tests Qwest performs for itself. Also, Qwest would be able to negotiate the technical parameters to test to with the CLEC community. He said that to make sure that the facility meets the requirements of the services to be provisioned on the loop, we need to consider the added length at the Central Office and the Customer Premises. He said that a 2000 feet copper segment could be added to the loop length and testing end-to-end becomes critical in the delivery of the service to the end user. Kim Isaacs-Integra said that (3/27/09 Comments to minutes received from Integra) Qwest she was assuming that the CLEC was making no consideration for the length in office and the end user location. Kim said that they make the calculation and place their order and Qwest auto assigns the loop with no load coil. She said that some will work and asked if Qwest was refusing to determine the location of the bridge tap. Bonnie Johnson-Integra said that Qwest (3/27/09 Comments to minutes received from Integra) said that they don’t do this testing for themselves and that they assign the facility following the CSA guidelines. She said that Qwest is expecting them to do testing that they don’t do for themselves and that they want parity that is currently in their contract. Jamal Boudhaouia-Qwest said that he respectfully disagreed. He said that he is asking for cooperative testing to mirror what Qwest does for itself. He said that the CLEC would be to interject a signal from their center and Qwest technicians in the field would receive the signal. Liz Balvin-Covad asked if there was a cost associated with cooperative testing. Bob Mohr-Qwest said that we have not looked at that. Liz Balvin-Covad asked what Qwest will do if they do the cooperative testing and determine excessive bridge tap. Bob Mohr-Qwest said that if cooperative testing is done and excessive bridge tap is causing impediments and the CLEC authorizes conditioning, Qwest will remove excessive bridge tap as is our process today. Julia Redman-Carter-PAETEC asked if Qwest would waive it. Bonnie Johnson-Integra said that (3/27/09 Comments to minutes received from Integra) Qwest said the test in not done in the CO because Qwest said they are not equipped to do that. Jamal Boudhaouia-Qwest said that we don’t have testing equipment in the CO and is very inefficient to do the testing in the CO. Jamal said that to do HDSL signal testing it would be done in the centers and that the CLECs can do this. Liz Balvin-Covad asked if the CLEC can launch that test. Jamal Boudhaouia-Qwest said yes, they can interject the signal. Bonnie Johnson-Integra asked what Centers Qwest was referring to. Jamal Boudhaouia-Qwest said that he was referring to the provisioning, maintenance and alarm centers. Jamal said that he did not know how the CLECs operate their business but that most telecom companies have some type of network operation center that is used to monitor the health on the network. Bonnie Johnson-Integra asked for more information on the repair aspect and that she did not understand how Qwest can deny. Bonnie said that the FCC requires that Qwest (3/27/09 Comments to minutes received from Integra) not limit testing to test to Voice Grade parameters. Jamal Boudhaouia-Qwest said since Integra is referencing the FCC requirements, the question becomes one of a legal nature. Bonnie Johnson-Integra said that they asked this question in the escalation and want a complete response. Mark Coyne-Qwest said that this question has been addressed in previous meetings and we believe that it has been answered. Julia Redman-Carter-PAETEC asked that Qwest provide the legal response. Mark Coyne-Qwest said that we will take this into consideration. Bonnie Johnson-Integra said that this before this CR was originated, they tried to resolve with their Service Manager and were told that they need to take the issue to CMP. Bonnie said that when they presented this CR they did not feel that they needed to bring this to CMP. She said that Qwest should respond to all citations in the escalation and respond to the (3/27/09 Comments to minutes received from Integra) to the Integra’s response to testing. Liz Balvin-Covad asked if the limits to test only to voice grade is limited to 2 wire non loaded. Jamal Boudhaouia-Qwest said that it is called out in the tech pub and does specify 2 and 4 wire. Jamal said that he will send to Mark and will be provided in the notes. Kim Isaacs-Integra said that the tech pub says 2 or 4 wire is tested to voice grade parameters.

2/18/09 Prod/Proc CMP Meeting Mark Coyne-Qwest said that this CR is currently in a development status and will remain as is based on the discussions regarding cooperative testing. (2/26/09 Comments to minutes received from Integra) Bonnie Johnson-Integra asked if we were going to discuss this CR on the call today. Mark Coyne-Qwest said that the last CMP Meeting Integra took an action to provide a response to Qwest regarding the cooperative testing. Bonnie Johnson-Integra said that Integra provided Qwest a formal response on 2/4/09 and has not received anything back and needs to decide on next steps. She said that she wanted the 2/4/09 response included in the body of the CR. (3/2/09 Comments to minutes received from Integra) Mark Coyne – Qwest stated Qwest has Integra’s response Bonnie Johnson – Integra indicated that Integra provided Qwest with Integra’s response on 2/4/09 and asked if there was confusion at Qwest. Bonnie asked if Qwest has taken any action on Integra’s response. Mark Coyne – Qwest stated actions have been taken but the SME team is not prepared to discuss them at this time. Lynn Stecklein-Qwest said that she would get the response posted. Mark Coyne-Qwest said if Integra’s position is to not test, Qwest will look at a response. Liz Balvin-Covad asked why Qwest required testing on the HDSL product when it is not required on the 2 – 4 wire that has 6 installation options available. Bob Mohr-Qwest said that we have had lengthy discussions on why we need this for HDSL. Bonnie Johnson-Integra said that in the Denial on implementing the USOC the issue was a financial liability. Bonnie said that they would like Qwest to implement a manual process and add a remark to assign the appropriate loop when submitting orders. Mark Coyne-Qwest said that Jamal has addressed the manual process. Jamal Boudhaouia-Qwest said that even with the manual process, cooperative testing is still a required. He said that Qwest has stated their position in the past and has been document in previous meeting minutes. 2/26/09 Comments to minutes received from Integra) Doug Denney-Integra asked Qwest to clarify that it’s position is that even though Qwest is unable to test the loop, CLECs should be able to test. Jamal Boudhaouia-Qwest said that Qwest’s position has previously been documented. Bonnie Johnson-Integra asked why Qwest was reluctant to speak to the process for those who have not been in those meetings. She asked what Qwest was going to do about repair if the HDSL loop is working and then needs repair. Bob Mohr-Qwest said that we need cooperative testing on a repair basis. Liz Balvin-Covad asked if there was a charge for the cooperative testing because Qwest is saying they can’t do without both parties. Bob Mohr-Qwest said that has not been identified. Doug Denney-Integra asked in a repair situation for HDSL, is Qwest going to undertake what Qwest does for themselves, i.e. checking for bridge tap and load coil. Jamal Boudhaouia-Qwest said the (3/2/09 Comments to minutes received from Integra) electrical testing is done as stated previously the tests have been described. Bonnie Johnson-Integra asked if Qwest’s process going forward is to continue to test to voice grade level and not to the HDSL standard. Bob Mohr-Qwest said this (2/26/09 Comments to minutes received from Integra) has not been decided the CR is requesting to test to those limits. Bonnie Johnson-Integra asked if we do nothing with the CR, will Qwest continue test to voice grade level and would it be status quo for voice grade only. Bonnie said that (2/26/09 Comments to minutes received from Integra) Jamal said in a previous meeting he was unaware that was taking place and she never received a response to that question. Jamal Boudhaouia-Qwest said that we did talk to this in previous meetings and that he will review the minutes. Doug Denney-Integra said that Qwest’s denial on the exception CR states that there is a financial risk and asked what Qwest was referring to. Bob Mohr-Qwest said that the financial liability is associated with the cost of equipping and training the technicians to perform the test at this level. Doug Denney-Integra said that the other CR doesn’t ask Qwest to do this and that they only want the USOC implemented. He said he was not sure how that fits into the rejection of the CR. Bob Mohr-Qwest said that the CR would be a half solution without testing and would shift additional liability to the repair process and Qwest is not willing to implement a partial solution. Doug Denney-Integra said that Integra is (3/2/09 Comments to minutes received from Integra) still reviewing Qwest’s denial of the other CR and may have more questions.

2/4/09 Integra Response On the January 21, 2009 CMP call, Integra agreed to consider the comments that Qwest had made on that call and respond in writing. Integra provides this response to Qwest. Please ensure that this response in included in the detail for CR PC082808-1IGX.

The Issue

Integra believes that Qwest has not appropriately framed the issue. Qwest focuses on one issue (Qwest’s view of testing) to the exclusion of the larger issues outlined in Integra’s change request (CR). Qwest’s approach suggests that Qwest may stop all progress on all aspects of the CR if one issue that it claims is “critical” is not handled in the manner proposed by Qwest. Integra disagrees with that approach.

In the January 21st CMP meeting, Qwest (Jamal) erroneously said that Integra’s “original CR calls for a test process” (see footnote 1) and that this is a “new process.” (see footnote 2) That is simply not the case, as is clear from reading the entire CR. It is also apparent from the CR’s title, which does not request a “test process” but asks Qwest to “Design, Provision, Test, and Repair Unbundled Loops to the requirements requested by CLEC, including NCI/SECNCI Code Industry Standards.” In other words, even when using existing processes (including existing testing), Qwest needs to apply the applicable NCI/SECNCI codes. The example provided by Integra in the first paragraph of the CR makes this even more clear:

For example, in May of 2008, Integra provided an example to its Qwest service management team in which HDSL2 service was working fine for Integra’s end user customer; Qwest made a Qwest-initiated change to its network which disrupted the customer’s HDSL2 service; Integra opened a trouble ticket to restore service; and Qwest repair told Integra that Qwest would test and repair only to voice grade parameters, which meant that the end user customer’s HDSL2 service no longer worked (i.e., was permanently disrupted).

In this example, Qwest already has a process for testing as part of a repair. The issue is that Qwest personnel, when using that process, should not take the position that Qwest will test “only to voice grade parameters” but instead should test to the standard applicable for the requested service (e.g., a loop capable of carrying data). As pointed out in the CR, it has long been established (e.g., in the SGATs and in ICAs, such as those cited in the CR going back to 2000) that use of the words “capable” and “compatible” to describe Loops means that Qwest assures that the Loop meets the technical standards associated with the specified Network Channel/Network Channel Interface codes, as contained in the relevant technical publications and industry standards. Therefore, this is a process that had long been in place (until recently, when Qwest starting telling Integra that it would test only to voice grade parameters). Qwest needs to restore compliance with the ICA terms requiring testing to the appropriate levels.

The above example involved a repair. The same is true for loop installations. During the CMP clarification call, Qwest (Jamal) asked Integra how Qwest would provide the test results to Integra. Integra responded:

“Doug Denney-Integra said that there are different installation options that exist today and some of those require different degrees of test results being provided by Qwest. He said that those are described in the Carrier’s contracts and when we set up the cost for those options. He said they are not attempting to (9/12/08 Comments to minutes from Integra) change the process of providing test results with regard to provisioning loops.” (see footnote 3) (Emphasis added) Integra asked Qwest in its CR to perform the tests Qwest is currently obligated to perform per the ICAs for the installation option ordered. As noted above, Qwest should be testing to the levels appropriate for the type of circuit ordered.

Installation

Qwest provides CLEC with multiple types of loops and, for each, various installation options. Types of Unbundled Loops and Assignment of Those Loops Qwest provides multiple types of loops to Integra and other CLECs. For example, Qwest’s ICA negotiations template in Section 9.2.2.2 addresses “Analog (Voice Grade) Unbundled Loops” and in Section 9.2.23 addresses “Digital Capable Loops – DS1 and DS3 Capable Loops, Basic Rate (BRI) ISDN Capable Loops, 2/4 Wire Non-Loaded Loops and xDSL-I Capable Loops.” Section 9.2.2.3 provides that digital capable loops, including “2/4 Wire Non-Loaded Loops,” are “capable of carrying specifically formatted and line coded digital signals.” That means that, when Qwest delivers the loop, it must deliver a loop capable of providing data to the CLEC to have met its obligation to provide the digital capable loop ordered by the CLEC. There is no exception in 9.2.2.3 for providing a loop that is not digital capable and then later, after imposing extra work and delays upon CLEC, providing a different loop that is digital capable. Qwest’s ICA negotiations template Section 9.2.2.3 also states: Qwest will provision digital Loops in a non-discriminatory manner, using the same facilities assignment processes that Qwest uses for itself to provide the requisite service. (emphasis added) A key problem that exists today, however, is that Qwest is not meeting this commitment. For CLECs, Qwest’s facilities assignment process does not select/assign the best (most qualified loop available for the type of loop ordered by the CLEC. Instead, it is just as likely, or more likely, to assign a voice grade (see footnote 4) loop to fill a CLEC request for a digital capable loop. In contrast, for Qwest retail, Qwest automatically assigns the best (most qualified) loop available for the type of loop ordered by Qwest retail.(see footnote 5) Every day that this situation continues is another day of discrimination, and so Qwest should make every effort to accelerate resolution of this problem. Existing Loop Installation Options

Qwest also offers multiple loop installation options (basic, coordinated, cooperative testing, etc.). Qwest lists its installation option offerings in its ICA negotiations template Section 9.2.2.9, which provides that the options are available for all types of loops, though the price may vary by option. Section 9.2.2.9.1 provides that “Basic Installation” is available for all “new or existing Unbundled Loops,” which includes for example 2/4 Wire Non-Loaded Loops. For a basic installation of a loop, Section 9.2.2.9.1 provides that Qwest completes its work and Qwest calls the CLEC, and for new service Qwest conducts performance testing but does not provide the test results to CLEC. As indicated above (and reflected in the 9/9/08 CMP Clarification Call minutes), Integra is not attempting to change this option (which in most, if not all, Qwest states is available to CLECs at a commission-approved rate).

As Integra understands Qwest’s current proposal, however, Qwest is seeking to alter this option – by removing the basic option altogether for HDSL (2 and 4 wire non loaded loops) and insisting instead on not only a more expensive installation option (cooperative testing) but also requiring time consuming and costly joint meets in circumstances when they are unnecessary and not required for Qwest retail. For Qwest retail, however, Qwest assigns a loop following CSA guidelines and, if it does not work, will perform the repair. (see footnote 6) To be nondiscriminatory, a basic installation option must remain available to CLECs for digital capable loops.

Specifically, Qwest admitted that for comparable types of service, Qwest does not perform or require its staff to perform the work it seeks to require CLECs to perform. Qwest said:

Jamal Boudhaouia - He said that we will check to see if the bridge tap is interfering with it. He said that Qwest does not do HDLS [sic] test in the CO because we are not equipped to do that and the equipment is very expensive. (12/30/08 Comments to minutes received from Integra) When we hook to the HDSL mux we test remotely - it works or doesn't work - we don't have the ability to test the raw loop, we look for open shorts, bridge tap, or Load Coils that we missed. (see footnote 7) (Emphasis added)

In other words, Qwest “does not do HDSL2 tests in the CO” for every installation for itself, but Qwest is attempting to force HDSL2 tests in the CO upon CLECs by requiring joint cooperative testing in the case of every loop installation. This is inefficient and creates unnecessary work, delay, and expense for CLECs. For example, if a CLEC that has 50 collocations throughout a city has ordered loops with the same due date for 3 installations in 3 unmanned collocations spread far apart in that city, Qwest would require CLEC to dispatch technicians all over town that day to jointly test for problems, even though the loops may in fact work when delivered (and should work, if proper facilities are assigned). For CLECs, Qwest proposes to require joint testing 100% of the time.

In contrast, Integra’s position is much more efficient, because it isolates joint testing to those limited circumstances when joint testing is truly required. Per Integra’s position, when Qwest assigns a loop capable of carrying data consistent with industry guidelines, in most cases the loop should work as intended. Therefore, no joint testing is required. Even assuming the loop does not work upon delivery, CLEC will be able to perform tests once it hooks up its equipment. Qwest’s existing processes require CLEC to perform trouble isolation before reporting trouble to Qwest and to submit its test results with its trouble report. (See Qwest’s ICA negotiations template Sections 12.3.3.5 & 12.3.4.) As with any other basic loop installation after which the loop does not work, the companies may agree on the cause of the problem and the solution. If the CLEC reports that its tests indicate, for example, that excessive bridged taps are interfering with its HDSL2 service and Qwest agrees, no joint meet its required. (see footnote 8) Only in the sub-set of installations for which the loop does not work and the companies do not agree on trouble isolation may joint testing be required. (see footnote 9) This is a far more efficient than Qwest’s proposal to require joint testing for 100% of installations.

As discussed above, a key problem that Integra’s CR is attempting to address is that, when Qwest provides a digital loop with a basic installation to CLECs, the facilities assignment process should take care of as many problems in advance of loop delivery as the facilities assignment process for Qwest retail. For example, if a Qwest retail customer that orders a digital service is unlikely to be assigned an analog facility with excessive bridged taps, a CLEC that orders a digital service should also be just as unlikely to be assigned an analog facility with excessive bridged taps. Once Qwest’s facilities assignment process is nondiscriminatory, the need for CLECs to request repairs after a basic installation should be reduced accordingly. In other words, repairs following installations that are caused by Qwest delivering a voice grade loop when in fact a digital loop was ordered should be substantially reduced, if not eliminated.

Qwest is legally and contractually obligated to deliver the loop a CLEC orders within the industry standard parameters for that loop. Qwest appears to have taken the position, however, that if CLECs will not agree to order and pay for cooperative testing (despite the availability in its ICAs of basic installation at Commission-approved rates), Qwest will not implement the USOC for CLECs that will allow Qwest’s systems to assign a loop for CLECs that will support the type of service the CLEC ordered. Qwest refers to this as “Gate one.” (see footnote 10) Qwest is basically saying it will not do one without the other. (see footnote 11) As Qwest knows from previous communications, Integra does not agree. There is no legitimate reason to link the two. Qwest needs to bring its facilities assignment process into compliance and make it nondiscriminatory. If implementing the USOC for CLECs is the means by which Qwest may do that (at least for one of the products, HDSL), Qwest should have done it by now given its obligations but certainly should not delay it any longer by attaching inappropriate pre-conditions to implementing the USOC. (see footnote 12) Integra will comply with the installation option provisions in its ICAs, including basic installation. Qwest needs to ensure that, before delivering a loop, Qwest is first assigning a loop that meets the industry standards for that type of loop. Qwest cannot cure its failure to appropriately assign a loop on a nondiscriminatory basis by shifting the burden to CLECs to perform work that would not be necessary if the assignment process worked as it should. Once it works as it should, there may be little or no need for joint testing or repair, because the delivered loop will work as intended for the service ordered.

To be nondiscriminatory, a proper facilities assignment process should be automated for CLECs, just as it is for Qwest retail. Qwest should ensure the process is automated, including implementation of a USOC(s) if that serves this purpose. With respect to the USOC for HDSL, Integra has submitted a separate CR for Implementation of USOC to Correct Facilities Assignment for HDSL” to attempt to ensure that the USOC is implemented without delay.

Until the facilities assignment process is automated for all affected products, and without waiving any rights, Integra asks Qwest as an interim measure to train its personnel to use the existing manual process (by which remarks in an order cause an order to fall out for manual handling) so that, when a remark indicates that the facility being ordered is a digital capable service (e.g., HDSL2), Qwest personnel will assign the type of facility needed for the digital capable loops (including compliance with industry standards). CLECs preferring automatic facilities assignment will be able to avoid this manual process by not using remarks. Footnotes: Qwest should deliver a loop capable of supporting the type of service ordered by the CLEC, which will reduce problems at installation and reduce the number of needed repairs to make the service work as intended.

Repair, including repairs following Qwest maintenance and modernization activities

The example that was included in the first paragraph of Integra’s CR (copied in part above) involved a repair not associated with an installation. A Qwest process already exists that enables CLECs to make comments when submitting trouble reports. When a CLEC, as part of those comments, identifies the facility to be repaired as a digital capable facility (e.g., HDSL2), Qwest needs to treat that facility accordingly. For example, Qwest personnel cannot (as they did in the example) tell the CLEC that Qwest will test and repair only to voice grade parameters, even though the facility is supposed to be capable of carrying data. (see footnote 13)

To the extent that problems, such as the one in the example, occur because of inadequate training, Qwest should promptly train its personnel as to the appropriate parameters for services capable of carrying data. Once a facility is identified (by CLEC or Qwest) as a digital capable service (e.g., HDSL2), there should be no more instances when Qwest personnel as a matter of policy refuse to test to the industry standards/parameters for that service.

To the extent that problems, such as the one in the example, occur because Qwest repair personnel are relying on circuit ID or other indicators suggesting that a loop is an analog loop when in fact it is a digital capable loop, Qwest should promptly train its personnel to accept input from CLECs as to the type of service. For example, if a CLEC tells Qwest in written remarks or on a telephone call (consistent with applicable Qwest process) that a facility was ordered as HDSL2, the Qwest repair personnel should not take the position that Qwest will not treat it for testing and repair purposes as HDSL2 because the circuit ID or other indicator suggests otherwise. Qwest should test and repair it per the applicable industry standards for the digital capable service identified by CLEC.

There is no reason to wait for implementation of a USOC to ensure that repairs are performed in a manner appropriate for the service ordered by the CLEC. Even after a USOC(s) is implemented for new ordering, digital capable loops (including HDSL2 circuits) will exist in the embedded base. If Qwest does not identify these facilities itself, Qwest will have to rely on information provided by CLEC as to the type of facility ordered when facilities in the embedded base need repair. Qwest should be relying on that CLEC-provided information now.

Qwest has identified no systems change or other change that is needed before implementing the requested training. Certainly, there is no legitimate reason to tie Qwest’s position on testing at installation to testing for these repairs.

Footnote 1 - See http://wholesalecalendar.qwestapps.com/detail/10/2009-01-21 and link to minutes from 1/21/09 CMP Product/Process meeting. Footnote 2 - See http://wholesalecalendar.qwestapps.com/detail/10/2009-01-21 and link to minutes from 1/21/09 CMP Product/Process meeting. Footnote 3 - See http://www.qwest.com/wholesale/cmp/cr/CRPC082808-1IGX.html minutes from 9/9/08 clarification meeting. Footnote 4 - Because Qwest used the term “voice grade” to describe the type of loop it was then testing to (see above example from the first paragraph of the CR), Integra uses that term in this response for ease of reference. Footnote 5 - See, e.g., http://www.qwest.com/wholesale/cmp/cr/CRPC082808-1IGX.html minutes from 12/17/08 CMP meeting (Jamal Boudhaouia-Qwest - “The Qwest HDSL2 goes through the CSA guidelines and Qwest will do remote testing from the center.”; “Qwest said that we have to take the necessary steps for the centers and LFACs to make sure the facility is qualified. He said that we have 2 extra steps - the technician needs to be equipped and that we have the insertion for the CSA guidelines.”); see also See http://wholesalecalendar.qwestapps.com/detail/10/2009-01-21 and link to minutes from 1/21/09 CMP Product/Process meeting. (Jamal Boudhaouia-Qwest – “Qwest retail does not use a manual process.”) Footnote 6 - See http://www.qwest.com/wholesale/cmp/cr/CRPC082808-1IGX.html minutes from 12/17/08 CMP meeting (quoted below). Footnote 7 - See http://www.qwest.com/wholesale/cmp/cr/CRPC082808-1IGX.html minutes from 12/17/08 CMP meeting. Footnote 8 - This assumes that Qwest is not enforcing a policy of testing only to voice grade parameters even when the CLEC informs Qwest that its service is supposed to be capable of carrying data, as discussed below regarding repairs. Ensuring Qwest’s personnel are properly trained in this regard is one of the purposes of Integra’s CR. Footnote 9 - When a joint meet is required, the Qwest-Eschelon approved ICAs in MN, OR, and UT provide for joint repair appointments. See 9.2.5.2.1. Footnote 10 - See http://www.qwest.com/wholesale/cmp/cr/CRPC082808-1IGX.html minutes from 11/12/08 CMP meeting. Footnote 11 - See http://wholesalecalendar.qwestapps.com/detail/10/2009-01-21 and link to minutes from 1/21/09 CMP Product/Process meeting. Jamal at Qwest said if CLECs can not complete co-op testing we need to re-analyze the CR. Footnote 12 - See http://wholesalecalendar.qwestapps.com/detail/10/2009-01-21 and link to minutes from 1/21/09 CMP Product/Process meeting. “Doug Denney-Integra (1/30/09 Comments to Minutes received from Integra) said while we would all like 100% perfection there is the opportunity for and improvement along the way. He asked why we want to delay the USOC and manual process because of the testing issue when by using the USOC we could get to 80% improvement today. Footnote 13 - See, e.g., Qwest-Eschelon OR ICA: “9.1.9 In order to maintain and modernize the network properly, Qwest may make necessary modifications and changes to the UNEs in its network on an as needed basis. Such changes may result in minor changes to transmission parameters. If such changes result in the CLEC’s End User Customer experiencing a degradation in the transmission quality of voice or data, such that CLEC’s End User Customer loses functionality or suffers material impairment, Qwest will assist the CLEC in determining the source and will take the necessary corrective action to restore the transmission quality to an acceptable level if it was caused by the network changes. . . .” (emphasis added).

1/21/09 Product/Process CMP Meeting

Bob Mohr-Qwest said that Qwest met with the Database administrator to develop the timeline and systems requirements for the implementation of the USOC. Bob said that the table changes will be worked with the system release in (1/30/09 Comments to Minutes received from Integra) mid April. He said that joint cooperative testing is a critical component for the success of this effort. Bob said that between now and April we will make necessary changes to the PCAT, Tech Pubs, Contract Language, and Internal documentation. This will include changes for ISDN BRI and ADSL Non Loaded ordering as well. Bob said that Cooperative testing must be included in that solution.

Bonnie Johnson-Integra said Integra proposed, until the USOC can be put in place, implementation (1/30/09 Comments to Minutes received from Integra) of a manual work around to bring relief. The work around is to drop to manual handling and the type of loop would be identified in the Remarks. Bonnie said that Qwest responded that they were not implementing manual process. Why can’t Qwest implement Integra’s proposal

Jamal Boudhaouia- Qwest said that LFACs will look for a HDSL qualified Facility when the new USOC is present. He said that based on the NC codes the USOC will be assigned. He said that if the USOC is not there LFACs doesn’t know what to assign and that the remarks is informational only. He said that IMA will drive LFACs to assign the correct facility.

Bonnie Johnson-Integra said that (1/30/09 Comments to Minutes received from Integra) for a period of time in the past, Qwest used this process for ADSL. Today there is a process where if the order does not flow through, it will drop to manual assignments and are there are codes associated with the process. Bonnie asked if the concern was that the Qwest resources would not know what kind of loop to assign and couldn’t Qwest train their people on this process.

Jamal Boudhaouia-Qwest said that to drop every loop to manual handling is economically not feasible and there will be delays during provisioning and additional hold time.

Bonnie Johnson-Integra said that it didn’t sound like this is a system or training issue (1/30/09 Comments to Minutes received from Integra) but that Qwest was concerned about the volume of orders and that Integra is only proposing that HDSL2 loops be dropped to manual handling, not all loops.

Jamal Boudhaouia-Qwest said that another concern is what triggers would have to be put in place for LFACs and IMA.

Bonnie Johnson-Integra said that Integra is only proposing that HDSL2 loops be dropped to manual handling not all loops. She said that they would identify for Qwest that this is HDLS2. She said they are not asking Qwest to make the decision on their own. She said that they will indicate in Remarks and should not require more work on the Qwest side.

Jamal Boudhaouia-Qwest said that the manual process will cause issues down the line due to human error etc. He said that this process would impact all CLECs and not just Integra. (1/30/09 Comments to Minutes received from Integra) Qwest has not thought about a manual process. Qwest hasn’t discussed what changes in systems would be required.

Liz Balvin-Covad asked for clarification on the issue. (1/30/09 Comments to Minutes received from Integra) You (Integra) have the right to order this type of loop?

Bonnie Johnson-Integra said that (1/30/09 Comments to Minutes received from Integra) Qwest is provisioning and repairing to a voice grade level.

(1/30/09 Comments to Minutes received from Integra) Liz Balvin-Covad said because there is no USOC?

Jamal Boudhaouia-Qwest said it is provisioned as a 2 wire loaded loop. (1/30/09 Comments to Minutes received from Integra) The product developed doesn’t provision HDSL. The NCI/SECNCI codes were used for information only.

Bonnie Johnson-Integra said (1/30/09 Comments to Minutes received from Integra) Qwest should install based on the NC/NCI codes.

Jamal Boudhaouia-Qwest said that we have never offered the product to HDSL parameters. He said that Integra wants a process to ensure HDLS2 Unbundled loops are provisioned correctly.

Liz Balvin-Covad asked why the NC/NCI codes aren’t driving this.

Jamal Boudhaouia-Qwest said that the NC/NCI codes never drove this and we want to assign a USOC and drive to all downstream. He said that Qwest wants a robust process to make sure we have codes and logic in place.

Bonnie Johnson-Integra said (1/30/09 Comments to Minutes received from Integra) based on the Industry Standards for the NC/SECNCI they should be HDSL2 capable. Bonnie said that Integra did not feel they should have to submit a CR but that is what Qwest told us to do so here we are.

Liz Balvin-Covad asked why Qwest could not support a manual process. (1/30/09 Comments to Minutes received from Integra). Liz stated she was surprised, shocked to hear that Qwest is not using the NCI/SECNCI codes. This is industry standard. Covad relies heavily on xDSL Loops. I am just shocked. I am not saying you are lying, Jamal, I am just shocked.

Bonnie Johnson – Integra indicated that this is our position as well.

Liz Balvin – Covad stated this appears to be a defect in the downstream systems.

Jamal Boudhaouia – Qwest stated Qwest is trying to implement a robust process. We are where we are.

Liz Balvin – Covad requested manual support.

Jamal Boudhaouia-Qwest said that we don’t believe manual handling is the right way to do this and that cooperative testing is critical to the process.

Doug Denney-Integra asked why the joint testing is critical to the process. (1/30/09 Comments to Minutes received from Integra) In past calls Qwest indicated that it doesn’t test for themselves.)

Jamal Boudhaoia-Qwest said each equipment manufacturer has specific standards. He said that we have proposed critical joint testing for the complete provisioning and acceptance. He said that we test remotely without a technician and Qwest can’t do this on their own to insure we have delivered a quality loop. Bonnie Johnson-Integra said they will take this back internally and that they wanted to make sure they were on the same page. Kim Isaacs-Integra said that currently when you have a repair situation, all Qwest will do is test to analog VG. She said that ticket will say maintain to the appropriate level. (1/30/09 Comments to Minutes received from Integra) Kim asked why Qwest could not implement the repair process. Jamal Boudhaouia-Qwest said that the repair scenario is different than provisioning because it is not driven by input/output. Dan Wiger-Integra asked what a cooperative test would look like (1/30/09 Comments to Minutes received from Integra) on the installation process what does Qwest do for itself and what is expected. The testing parameters are still an open issue. He asked if Qwest is suggesting some type of test if , for example, our equipment is hooked up and the circuit won’t pass, would they be asked to do something or will Qwest initiate a process and fix the problem. Qwest implied that coop testing is needed on repairs. Jamal Boudhaouia-Qwest said (1/30/09 Comments to Minutes received from Integra) testing parameter would apply to provisioning and repair and that we would have to agree on the parameters. Dan Wiger-Integra said that they would know as the customer to repair back to the HDSL. He said that cooperative testing for repair would be a challenge. He asked if it was open/out would Qwest fix to the standard. Jamal Boudhaouia-Qwest said that the loop is hooked up to the Mux and HDSL has different parameters different than Nortel, for example. He said that we would fix it so that it is easier for you to interject a signal. Dan Wiger-Integra said (1/30/09 Comments to Minutes received from Integra) Qwest can fix metallic trouble but the challenges would be more on HDSL. Basic faults are easier to diagnose but that Multi band Mux remote capabilities would be a problem. We would ask Qwest to repair to parameters. Jamal Boudhaouia-Qwest said that we will agree to the concept of the proprietary process, the test parameters depend on what they want to see and on your testing capabilities. He said that Qwest will negotiate and agree on parameters. Dan Wiger-Integra asked is (1/30/09 Comments to Minutes received from Integra) Qwest positioning that it does not have the resources, trained or personnel in the CO to test with the Field and the CLEC will the CO resource. Jamal Boudhaouia-Qwest said that we would not be in parity with retail. (1/30/09 Comments to Minutes received from Integra) If CLEC can not complete co-op testing we need to re-analyze the CR. He said that it is much more than training and resources but do they have the equipment to do the testing. Dan Wiger-Integra asked if the pair was not working, would Qwest (1/30/09 Comments to Minutes received from Integra) Retail would test through the vendor equipment and do further testing on the frame to the technician in the field – Qwest in Wholesale – CLEC CO Test. Jamal Boudhaouia-Qwest said that HDSL parameters don’t have the capability nor have the technician in the CO to test to HDSL parameters. Dan Wiger-Integra said (1/30/09 Comments to Minutes received from Integra) stated that Qwest retail would seek another pair and that they would have to take this back. Doug Denney-Integra said that said that Integra wanted to get the manual process going so that they could work on how to handle testing going forward. Jamal Boudhaouia-Qwest said that Integra’s CR requested Design, Provision, Test and Repair Unbundled Loops to the requirements requested by the CLEC. He said that with this new process, Qwest expects provisioning will be better than before for HDSL requirements. He said that the original CR calls for a test process. Doug Denney-Integra (1/30/09 Comments to Minutes received from Integra) said while we would all like 100% perfection there is the opportunity for and improvement along the way. He asked why we want to delay the USOC and manual process because of the testing issue when by using the USOC we could get to 80% improvement today. Jamal Boudhaouia-Qwest said (1/30/09 Comments to Minutes received from Integra) to propose a new process if this will not work. He did not understand the objections to cooperative testing. He said that everyone needs to be comfortable with the testing and we want to meet the CLECs needs so that we don’t have issues going forward. He said that he would be open to another discussion. Bonnie Johnson-Integra said that when a CR requires system work in the past a workaround has been implemented. She said that Integra believes that Qwest can assign a loop without cooperative testing as it does for itself. (1/30/09 Comments to Minutes received from Integra) Jamal Boudhaouia-Qwest said that Qwest Retail does not use a manual process. (1/30/09 Comments to Minutes received from Integra) Bonnie Johnson-Integra said she was not stating that Qwest does this using a manual process and that Qwest retail could have a USOC they use. Dan Wiger-Integra said that Qwest has identified 3 steps in the process from this discussion: 1. Implement a new process/manual process, 2. implementing the USOC with cooperative testing will provide a quality loop and 3.final details on testing and how it will work. Bonnie Johnson-Integra said that it appears that Qwest is unwilling to move forward without implementing the USOC and won’t do one without the other. Jamal Boudhaouia-Qwest said that Qwest is not unwilling to discuss a manual process and Integra’s CR is requesting a testing process. Bob Mohr-Qwest said that Qwest wants assurance that with cooperative testing, we meet the HDSL test standard. Mark Coyne-Qwest summarized that based on Qwest’s response we will go back and look at the manual process, move forward with implementing the USOC and work together on joint testing. Mark Nickell-Qwest asked when Integra would respond to the question on joint testing. Bonnie Johnson-Integra said that they would review internally and provide a timeframe for a response to the CMP CR mailbox.

12/17/08 Product/Process CMP Meeting Bob Mohr-Qwest said that we wanted to provide an update from the last call. He said that we have held meetings with our sub teams to address the support of the (12/30/08 - Comments to minutes received from Integra) HDSL USOC and provisioning guidelines. The team has completed the analysis and determined that LFACs will look for a HDSL qualified Facility when the new USOC is present. He said that the team will meet on January 8th to work through the implementation steps and establish timelines associated with the implementation of the USOC. The team will also address non loaded BRI and ADSL loops. He said the 2nd sub team is working on the testing criteria and several outstanding issues from last month’s CMP meeting were discussed. He said that the implementation plan depends on the CLECs testing to 196 KHz and is critical to the implementation team. Jamal Boudhaouia-Qwest said that conditioning on the bridge tap and load coil will be performed (12/30/08 - Comments to minutes received from Integra) when we detect excessive bridge tap and have as we do today and that we will get authorization to remove it. Kim Isaacs-Integra asked if it would be done on the near and far end on the bridge tap and interference bridge tap too. Jamal Boudhaouia-Qwest said that far and near is part of the CSA guidelines and is very clear. He said that we will consider from a process perspective the automatic authorization to remove the bridge tap to make it compatible. Kim Isaacs-Integra said that they can populate the SCA field on the 1st order to approve authorization. Jamal Boudhaouia-Qwest said that we assume authorization because of ease and efficiency. He said you can choose to follow the same process. Kim Isaacs-Integra said that it should be based on if the field is populated and that the existing process says that we communicate to Qwest whether we approve the condition. Jamal Boudhaouia-Qwest said that he could go either way. He provided examples of how Qwest performs testing. (12/30/08 Comments to minutes received from Integra) Kim Isaacs – Integra indicated that Integra would prefer to use the existing process to approve conditioning. Jamal Boudhaouia-Qwest provided examples of how Qwest performs testing. DS1 service (12/30/08 Comments to minutes received from Integra) using HDSL2 – Qwest owns both ends, MUX on CO end of loop to customer prem. The Qwest HDSL2 goes through the CSA guidelines and Qwest will do remote testing from the center. HDSL is not a complete standard more focused to loop make up but each equipment manufacturer has specific standards. BRI – Testing is done remotely. UBL – Test is done on frame on most loops and the technicians are equipped with that ability. HDSL – CSA guidelines are used and hook up to the (12/30/08 Comments to minutes received from Integra) HDSL equipment and do remote. The HDSL is how loop should be done and have different parameters on how they test depending upon the manufacturer’s specifications. It is different for Lucent or any other manufacturer. We do the testing remotely and the tester reads the performance. Jamal asked that the CLECs test remotely or coordinate with the Qwest tester to cooperatively test with Qwest. He said that we don’t know how you test to 196 KHz and it depends on your Mux. Dan – Integra said that Qwest has various vendor technicians and has various test standards for HDSL. He said that if they are expected to do (12/30/08 Comments to minutes received from Integra) continuity testing how do they logistically accomplish this with HDSL and what is the next step. He said that Qwest can have the CO tech put the test devise on the loop asked why Qwest is not able to do this on HDSL. Jamal Boudhaouia-Qwest said that we don’t do 196 KHz on our own and that we do performance but they are driven by the vendor equipment. Our Technician is not equipped and the tools are very expensive to do 196 KHz. He said the equipment itself has certain parameters between the NIU or the technician would have a laptop to do remotely. Dan-Integra asked if the CLEC orders (12/30/08 Comments to minutes received from Integra) HDSL it is the industry standard to run multi-band test and Qwest does not run an insertion loss for high frequency. He asked how Qwest would know if the HDSL is a qualified loop. Jamal Boudhaouia-Qwest said that is the question associated to the CR. He said that today Qwest doesn’t perform or guarantee tests. Dan-Integra asked Qwest to confirm that Qwest itself does not perform test. Jamal Boudhaouia-Qwest said that on raw copper loop the tech on the other end doesn’t interject test parameters (12/30/08 Comments to minutes received from Integra) Qwest connects the loop to the HDSL equipment and tests remotely. Dan-Integra asked if Qwest would perform the test for HDSL signaling for themselves if the circuit doesn’t work. Jamal Boudhaouia-Qwest said no and that typically (12/30/08 Comments to minutes received from Integra) Qwest looks for overlooked bridge tap or load coil and removes these if found – the practice of testing the loop don’t do is driven by CO Mux. Qwest tests remotely. Dan-Integra said that with the Mux you don’t have the technician. He said that you order the facility and hook up to the vendor equipment and it doesn’t work. He said that a loop issue is found. He asked how they could cooperatively test by sending the tone for every ADSL and hand off a qualified loop. (12/30/08 Comments to minutes received from Integra) Dan stated it sounds as though Qwest is just using vendor testing. Jamal Boudhaouia-Qwest said that we don’t have the equipment or technicians trained for HDSL signaling. He said Qwest does not have the capability to test raw loops. He said that we will check to see if the bridge tap is interfering with it. He said that Qwest does not do HDLS test in the CO because we are not equipped to do that and the equipment is very expensive. (12/30/08 Comments to minutes received from Integra) When we hook to the HDSL mux we test remotely - it works or doesn't work - we don't have the ability to test the raw loop, we look for open shorts, bridge tap, or Load Coils that we missed. Most of the time we don't test using test equipment in the CO. Qwest is not equipped to do the testing in every central office. Dan-Integra asked if Qwest’s position was that when the CLEC orders an HDSL Loop Qwest wants the CLEC to be part of the Loop Qual testing. Jamal Boudhaouia-Qwest said (12/30/08 Comments to minutes received from Integra) LFAC will do the Loop Qualification. We don’t know the capability of the CLEC. He said that we are asking for cooperative testing and what other parameters beside 196 KHz to test to because 196 KHz may not interject the signal. Dan-Integra said that they would review the recommendation internally. He asked if they agree to cooperative testing would the standard be jointly defined. Jamal Boudhaouia-Qwest said (12/30/08 Comments to minutes received from Integra) yes we are willing to jointly define compliance standards that some CLECs can’t test remotely with 196 KHz. Doug Denney-Integra (12/30/08 Comments to minutes received from Integra) said that Qwest indicated some COs are equipped with test with this 196 KHz testing standard and asked if Qwest’s position is the same, regarding testing of the loop, even in offices where the capability to test the loop exists. Jamal Boudhaouia-Qwest said that is correct from a process perspective. He said that in these offices the process we are introducing with this CR would be across the board. Bonnie Johnson-Integra asked when Qwest includes new technology or service is the criteria included in the binder group. Jamal Boudhaouia-Qwest assuming that Qwest knows the NC/NCI codes in the binder group are running each pair is assigned the correct codes in the cable. He said that he tried to make manage spectrum management process – DS1 on it if the separate CO based HDSL and ADSL interfere with the CO based – interference will appear after a certain amount of time and that is how the spectrum if we know the codes in binder group. Kim Isaacs-Integra asked how Qwest gets the NC/NCI information to manage spectrum etc. Jamal Boudhaouia-Qwest said that it is driven by the service order and that is how they get assigned to the cable. Kim Isaacs-Integra said that (12/30/08 Comments to minutes received from Integra) service modifier LFXU is for 2 Wire Analog and Non Loaded Loops and they all carry the same service modifier code and asked how Qwest could manage spectrum correctly/interference on the loop. Jamal Boudhaouia-Qwest said that (12/30/08 Comments to minutes received from Integra) historically the NC/NCI codes were not loaded. He said that when we have a UBL the NC/NCI codes need to be correct on the loop and that is what we are trying to do going forward in order to manage spectrum.. Kim Isaacs-Integra asked how Qwest determines the NC/NCI codes on LXFU. Jamal Boudhaouia-Qwest said that if we have LXFU would be able to manage with NC/NCI codes and we are looking at the total technical parameters with the NCI/SECNCI going forward. Kim Isaacs-Integra said when assigning HDSL, LFACs will find the loop upfront and asked if the NC codes will be tied to the circuit so when you manage spectrum you aren’t going to have interference. Jamal Boudhaouia-Qwest said that when the USOC is input, IMA will drive the correct NCI codes. Bonnie Johnson-Integra said that the reason they are asking is because they have had an ongoing issue for 2 years. She said that Qwest network personnel told them that the repair commit time for LXFU 2-4 wire Non-Loaded Loop is 24 hours when the SIG indicates it is 4 hours. She said that Qwest said they determine repair commit time by the service code modifier and not the NC/NCI code and that they can’t differentiate between 2 & 4 wire analog and a 2/4 Wire Non-Loaded Loop. She said that they are concerned with the challenge in repair when there are 600 pairs on the binder group and is Qwest looking at 600 orders. She said that going forward there will be a different USOC but will still have the service code modifier. She said that we may need to take a closer look at this with HDSL & being included and LXFU modifier. Jamal Boudhaouia-Qwest said that we are not looking at 600 pairs. He said that there are 25 pair cables and if the services apart in each binder group there won’t be an interference issue. He said that he was not aware of the repair time and will take as an action item. He said that what he envisions going forward is that the new USOC will drive NC/NCI codes and HDSL will be assigned. Bonnie Johnson-Integra asked if we could do research on how they can differentiate between a VG loop and an HDSL loop. Jamal Boudhaouia-Qwest said that we can research.

11/19/08 Product/Process CMP Meeting

Bob Mohr-Qwest said that we had questions from the adhoc meeting held 11/12 and would like to provide an update. Bob said that the 1st question is associated with the embedded base of circuits. He said the question was will Qwest update the circuit with the USOC as needed when the CLEC opens repair tickets and indicates this is a 2 wire non-loaded loop with HDSL NC/NCI codes. Bob said that if the circuit is identified and qualifies as HDSL, Qwest will change to the new USOC. He said that if the circuit does not meet the guidelines we will ask that it be moved to a service that qualifies. Bonnie Johnson-Integra said that when we are talking about repair we are talking about 2 buckets. She said that the 1st bucket is when a circuit is working and Qwest does a network modification resulting in the circuit not working. She said that there should never be a case when the circuit worked and now doesn’t qualify because of the network modification (11/26/08 Comments to minutes received from Integra) because per Jamal on the ad hoc call, an address qualifies or it does not. Jamal Boudhaouia-Qwest said that is correct. (11/26/08 Comments to minutes received from Integra) we will look at this situation on an individual case basis. Bonnie Johnson-Integra said that going forward they should not have to open up a ticket in this situation (11/26/08 Comments to minutes received from Integra) because Qwest will not install the circuit if it does not qualify. Jamal Boudhaouia-Qwest there should be no repair issue and that the circuit should work and continue to work going forward. Bonnie Johnson-Integra said that if the circuit does not qualify and you request that the circuit be moved to another facility should only apply to circuits prior to this process. She said that the circuits Bob is referring to are those that don’t meet the guidelines. Bob Mohr-Qwest said he was referring to the embedded base. Bonnie Johnson-Integra asked if these would be circuits that never worked. Jamal Boudhaouia-Qwest said that if there have been 4 or 5 repair tickets on a circuit there may be a problem. He said that if the circuit has always worked properly, it should work going forward. Julia Carter-Redman-McLeodUSA said that their concern is that they have a circuit that has worked properly for years (11/26/08 Comments to minutes received from Integra) a change occurs in Qwest’s network and now the circuit doesn’t work. Qwest’s response is that the circuit meets the standar for test per NCI code and CLEC now has to re-order because it has the wrong NCI codes. Jamal Boudhaouia-Qwest said that the issue is to provide correct NCI codes. Julia Redman-Carter-McLeodUSA said that the (11/26/08 Comments to minutes received from Integra) circuit has been working for years and the codes in the beginning worked and now there is a repair issue. Qwest is now claiming it doesn’t work because the NCI codes are wrong.and we have to reorder with the now correct NCI codes. Jamal Boudhaouia-Qwest said that we are talking about 2 different issues. Mark Coyne-Qwest said that McLeodUSA’s issue doesn’t fall into the description of the CR and that we have captured their concern. Bonnie Johnson-Integra said that their CR is asking for Qwest to install and provision circuits based on the NCI/SECNCI codes. She said that Qwest was only installing to voice and their CR addresses ADSL. Jamal Boudhaouia-Qwest said that we are trying to make sure that the NC/NCI codes expected on the request are to provision UBL. He said that our expectation is that the NCI codes in the PCAT and ICA are correct going forward. Julia Redman-Carter-McLeodUSA confirmed that this (11/26/08 Comments to minutes received from Integra) addresses only installation and provisioning on a going forward basis. Jamal Boudhaouia-Qwest said yes. Julia Redman-Carter-McLeodUSA said that they don’t want (11/26/08 Comments to minutes received from Integra) to have to reorder something that has been working and now stops working. PAETEC want the service repaired based on the standard for the service we originally ordered and received.

Kim Isaacs-Integra said that the NCI & SECNCI codes used for the service should work to those standards. She said that if the NCI code is different than what you wanted, the circuit won’t work per the standard. Julia Redman-Carter-McLeodUSA said that she still has a problem with a circuit working for years (11/26/08 Comments to minutes received from Integra) though it may have the ‘wrong’ codes – and now Qwest won’t repair and PAETEC may need to re-order again because of Qwest changes. Kim Isaacs-Integra said if you have an embedded circuit with a 2 wire non loaded loop NCI and it is working as ASDL and then it stops working, Qwest will repair to NCI code standards based on ADSL. Jamal Boudhaouia-Qwest said that we could talk further about this is an adhoc meeting. Jamal said that we test and manage to current NCI codes. Bonnie Johnson-Integra said if the current codes are HDSL capable and the circuit was working and then it doesn’t, Qwest is going to have to remove the bridge taps. Mark Coyne-Qwest said that these were good discussion points for an adhoc meeting. Bonnie Johnson-Integra asked why these discussions have to take place outside of a CMP Meeting. (11/26/08 Comments to minutes received from Integra) Bonnie said we have the participants on the call now and Qwest seems to always be trying to get things outside of CMP. Mark Coyne-Qwest said that he was not sure we had all the right SMEs on the call. (11/26/08 Comments to minutes received from Integra) Bonnie Johnson-Integra asked Jamal and Bob it that was true. Jamal Boudhaouia-Qwest said that McLeod’s issue is outside of the CR and said that he was not prepared to discuss this concern. Julia Redman-Carter-McLeodUSA said that she was not able to join the adhoc meeting. Bonnie Johnson-Integra confirmed that Qwest will change the circuit if it qualifies and if a circuit has worked for a year it should still work. Jamal Boudhaouia-Qwest agreed that circuit should qualify and that if the circuit does not work, Qwest will take a look at it and place it on a facility that works. Julia Redman-Carter-McLeod said that they should not have to make changes to make it work. Bonnie Johnson-Integra asked if the confusion is that in the past McLeodUSA was using NCI codes not associated with HDSL and that is the difference from the CR. Julia Redman-Carter-McLeodUSA said (11/26/08 Comments to minutes received from Integra) that per the NCI/SECNCI codes the testing standard applied should be to HDSL codes per PCAT. She asked that if the circuit was working previous years and meets the designated standard per the NCI code but not the ADSL standard so that the circuit is working as it has been for the previous years, then does CLEC have to re-order with the now correct codes. Jamal Boudhaouia-Qwest said that we are not asking the CLEC to re-order but if the circuit never worked we are asking that it be moved to a different service. He said that if the circuit qualifies and has the correct codes Qwest will apply the USOC. Laurie Roberson-Integra said that if the circuit has been working for a year and quits and it qualifies, Qwest will restore it. She said if there is a Qwest network change and it doesn’t qualify per the rules Qwest will not restore. Jamal Boudhaouia-Qwest said that based on tests and if the circuit worked intermittently and doesn’t meet standards, Qwest will ask the CLEC to change it. Laurie Roberson-Integra asked if the circuit worked before and now it doesn’t will Qwest try and fix the issue. Jamal Boudhaouia-Qwest said that he wanted to emphasize the standard test of 96HZ and if the circuit falls outside of the standard, Qwest will ask the CLEC to change it. Bonnie Johnson-Integra said that it is a case-by-case basis and that McLeodUSA’s issue is a different issue and not related to this CR. Jamal Boudhaouia-Integra agreed and said it is a totally different spectrum issue (HDSL with ADSL) and that the remote D-Slam has no affect on ADSL. Kim Isaacs-Integra asked how Qwest will address bridge tap removal (near and far end) during the design and provisioning phase and what will Qwest do if it interferes with the service. Jamal Boudhaouia-Qwest said that would fall under the conditioning process and said he was not familiar with the current practice. Kim Isaacs-Integra asked if Qwest could provide a response. Mark Coyne-Qwest said that we will provide a response in the meeting minutes. Jamal Boudhaouia-Qwest addressed the question regarding what additional work and HDSL2 testing requirements need to be added to this process. He said that the technicians need to be equipped with HDSL tier testing and be able to read and understand DB levels. They will need to check for load coils going forward and test to the correct range. Bonnie Johnson-Integra asked if this additional work (11/26/08 Comments to minutes received from Integra) because the circuit will now be designed is related to Qwest wanting to increase from 3 to 5 day intervals. Jamal Boudhaouia-Qwest said that we have to take the necessary steps for the centers and LFACs to make sure the facility is qualified. He said that we have 2 extra steps - the technician needs to be equipped and that we have the insertion for the CSA guidelines. Bonnie Johnson-Integra asked when Qwest adds the USOC could she assume that it goes through LFACs to find the facility or does it fall out for manual handling. She said that she knew some will flow through. Jamal Boudhaouia-Qwest said that they would go through LFACs. Kim Isaacs-Integra asked if they would be auto assigned. Jamal Boudhaouia-Qwest said that he did not have the details but that the center will have to look for the correct facility. He said that extra time is needed in trying to mirror the design process and it is not an automatic process. He said all DS1s go through the design process. Jamal Boudhaouia-Qwest addressed whether coordinated/cooperative testing will be required, and if so, does that mean basic install will not be available for these loops. He said that cooperative testing will have basic install testing with coordinated cooperative testing or have CLEC requested timeframes. Bonnie Johnson-Integra asked Qwest to confirm that plain basic installation was not available and has to be basic with cooperative test. Jamal Boudhaouia-Qwest said that was correct. Kim Isaacs-Integra said that on a basic install with DS1 or analog, Qwest is doing some test with a verbal response and asked if there was anything additional that needs to be done with HDSL. Bob Mohr-Qwest asked if they were referring to a finished DS1. Kim Isaacs-Integra said that with any loop order they can request basic install and Qwest will test to standard with a run test and asked what additional activity they need to do with cooperative testing. Bob Mohr-Qwest said that performance testing may be required and was not certain if there was a different test. He said that with the basic option, test results are not provided. Jamal Boudhaouia-Qwest said that we need to look at DS1 capable loops. He said that we will look at DS1 testing requirements to see what the CLEC has to do. Jamal said that he envisioned that the testing could be done remotely by the Qwest technician and CLEC with the same test results. Kim Isaacs-Integra (11/26/08 Comments to minutes received from Integra) asked if Qwest wanted us to send the 196 kHz down the loop and it will loop back. Bonnie Johnson-Integra said that with cooperative test you need the CLEC for something vs. just testing to the parameters and calling us. Bonnie said that they may have additional questions. Mark Coyne-Qwest said that if there are any other questions to send to cmpcr@qwest.com.

November 12, 2008 adhoc meeting Attendees: Bob Mohr–Qwest, Jamal Boudhaouia-Qwest, Doug Allen-AT&T, Kim Isaacs-Integra, Bonnie Johnson-Integra, Loriann Burke-XO Communications, Joyce Bilow–Paetec, Laurie Roberson-Integra, Doug Denney-Integra, Jo Wees-Qwest, Susan Lorence-Qwest

Susan Lorence-Qwest stated the purpose of the call is to discuss CR PC082808-01IG, Design, Provision, Test and Repair Unbundled Loops to the requirements requested by CLEC, including NCI/SECNCI Code Industry Standards, and for Qwest SMEs to provide a high level concept of the proposed solution. Bob Mohr-Qwest relayed that since the last ad hoc call, there have been several meetings to evaluate what would be required to provision specific interfaces for the Non Loaded loops to industry guidelines. The key is for downstream groups to be able to identify the unique interface. Bob relayed we would like to share the concept of a 2 gate approach to qualifying and provisioning the HDSL loop interface. Bob Mohr-Qwest said the team had researched how the NC/NCI codes are processed today for the specific interfaces and found that the majority of downstream systems rely on a unique USOC along with NC/NCI combination. Qwest found an existing USOC (U2UXX) that is defined today as a HDSL Unbundled Loop. The USOC is not used for any other application and LFACS can assign a Qual Code to validate availability of a facility that meets the HDSL guidelines. Bob relayed that if a facility exists then LFACS assigns facility and the order has made it through gate 1 otherwise the order is rejected. Jamal Boudhaouia - Qwest relayed that the determination in Gate 1 is if there is any capable facility available. (11/21/08 - Comments to minutes received from Integra) HDSL CSA Guidelines T1.418 recommendation would be used to determine capability. He relayed he wanted to be sure everyone was clear on the guidelines.

Bonnie Johnson-Integra asked Qwest to confirm that with the USOC, Qwest would be able to identify in LFACS whether or not there was a facility and that this was the current process that any order takes through Gate 1 11/21/08 – Comments to minutes received from Integra) and not a new process. Bonnie raised the question on what would occur if there was no facility. She indicated she disagreed that if there was no facility, Qwest would reject rather than treat as a delayed order.

Bob Mohr-Qwest said (11/21/08 – Comments to minutes received from Integra) rejected might be the wrong word and he said he would take that issue back to his SME team.

Bonnie Johnson-Integra (11/21/08 – Comments to minutes received from Integra) said that Qwest was focused on the HDSL and said the change was broader than HDSL and questioned whether Qwest was looking for other unique USOCs.

Bob Mohr-Qwest (11/21/08 Comments to minutes received from Integra) recommendation with respect to digital products other than HDSL2 to order the corresponding digital compatible or capable loops. at the same price as non-loaded loops but there was not that latitude with HDSL.

Bonnie Johnson-Integra asked if new USOCs will also be obtained for the other Non-Loaded Loop Interfaces such as ISDN BRI and xDSL-I.

Qwest relayed the concept for other interfaces such as BRI ISDN, and xdsl-I should be ordered using the existing NC code for that UBL (xDSL-I and BRI ISDN Capable UBLproducts). This will ensure that these services are provisioned using industry guidelines and testing. ADSL interfaces should be ordered using the NC code of LXR- and this will drive the specific ADSL tests and parameters.

Kim Isaac-Integra (11/21/08 Comments to minutes received from Integra) said that it appears Qwest was stepping away from the ADSL loop through grandfathering the product. This ADSL loop may disappear in the next round of ICAs.

Bob Mohr–Qwest said there is no plan to grandfather ISDN BRI Capable and xDSL-I Capable Loop, but that Qwest was looking into the issue related to grandfathering of the product ADSL (11/21/08 Comments to minutes received from Integra) and possibly un-grandparenting the ADSL capable loop product.

Bonnie Johnson-Integra asked about the timeframe for that and Bob Mohr-Qwest relayed that he did not have that information at this point.

Bob Mohr-Qwest said at this point in the process, Gate 1 had been passed and that Gate 2 involved the actual provisioning and testing of the order. Bob relayed that with the additional testing and coordination, a change to the interval from 3 to 5 days is required. There was also the need to explore whether a cooperative test was required and whether that was operationally feasible. Bob relayed that the call was needed to explore those two areas: the interval change from 3 to 5 days and cooperative testing.

There was discussion on why there was a need for the increased interval. (11/21/08 Comments to minutes received from Integra) Jamal Boudhaouia - Qwest relayed that the 2 wire non loaded loop is a 3 day interval because it is not designed. The increased interval was due to the additional testing time that was required to test the 196khz frequency And because the circuit would now be a designed service and different test sets and technicians trained for this testing are needed on each end of the circuit.

Bonnie Johnson-Integra questioned what the expectation was around cooperative testing vs. a coordinated testing.

Discussion occurred the around the types of testing, various cost issues and how often these type of circuits would be ordered vs. the required test equipment.

(11/21/08 Comments to minutes received from Integra) Bonnie Johnson – Integra asked if Qwest was going to require coordinated/cooperative testing.

(11/21/08 Comments to minutes received from Integra) Bob Mohr – Qwest said that from a product perspective Qwest needs to determine the cost vs. the return.

(11/21/08 Comments to minutes received from Integra) Bonnie Johnson – Integra indicated she would take this back internally. She asked Qwest if they are currently doing any testing for 2-wire loops.

Jamal Boudhaouia - Qwest relayed that today there is no requirement to perform (11/21/08 Comments to minutes received from Integra) HDSL tests. He said Qwest tests for load coils only.

Jamal Boudhaouia – Qwest (11/21/08 Comments to minutes received from Integra) said the qual code for the 1st gate will be the CSA Guidelines. The specific guidelines indicate that if there are no facilities, the order would be rejected.

(11/21/08 Comments to minutes received from Integra) Susan Lorence – Qwest indicated that there was an earlier question regarding the difference between rejected and delayed orders.

(11/21/08 Comments to minutes received from Integra) Jamal Boudhaouia – Qwest said for HDSL, there is no recommendation on a standard. ANSI T1.418 is the standard that references HDSL2 on the other hand if certain guidelines are not met, the address does not qualify which would be a reject vs. following the delayed order process. Jamal referenced that the CSA guidelines must be met.

(11/21/08 Comments to minutes received from Integra) Kim Isaacs - Integra questioned whether qualifications were based on gauge or distance only because we can request conditioning to remove load coils and interfering bridge tap

Jamal Boudhaouia - Qwest relayed it was based on gauge and distance and that it was a mathematical calculation.

Jamal Boudhaouia–Qwest relayed he would provide the specific guidelines. NOTE: The T1E1 Technical Report #28 is the guideline that Jamal Boudhaouia cited, specifically Section 3.1 depicts the CSA Guidelines that are Industry Standard.

Bonnie Johnson-Integra relayed that if the parameters are considered during loop qualification, the order should not get rejected.

Jamal Boudhaouia–Qwest indicated that if a customer uses the Raw Loop data tool, that chances are good that if it qualifies, the facility will still be available however there is no guarantee that some other provider did not order those facilities. The Raw Loop data tool does not reserve facilities.

Bonnie Johnson-Integra stated again there is a difference between an address that does not qualify and (11/21/08 Comments to minutes received from Integra) address that does qualify but no facilities which is the difference between a reject and a delayed order.

Jamal Boudhaouia–Qwest relayed (11/21/08 Comments to minutes received from Integra) that is a good point and Qwest would take that into consideration.

Bob Mohr-Qwest said he would take an action item: what to do with ADSL.

Bonnie Johnson - Integra questioned whether Qwest was looking for concurrence before the CR moves forward on the two areas of extending the interval from 3 to 5 days and the question of testing.

Bob Mohr-Qwest said the idea was to share the concept while Qwest continues to investigate the testing and other issues. He questioned whether Qwest was on track and moving in the right direction.

Bonnie Johnson-Integra (11/21/08 Comments to minutes received from Integra) said that provisioning and repairing the loops to the NC/NCI code is where we need to be. We will not discuss whether we believe Qwest should have been doing this all along under our ICA on this call. Integra cannot dictate how to get to the solution but knows where we need to end up and wants to get there.

Jamal Boudhaouia–Qwest said Qwest wants to get there as well with a process that will work.

Susan Lorence-Qwest confirmed that Qwest would provide the Carrier Service Area (CSA) guidelines and asked for questions. Qwest relayed information had been provided on the direction and status of the CR and Qwest has additional items to think about.

10/15/08 Prod/Proc CMP Meeting Mark Coyne-Qwest stated that Bob Mohr-Qwest will provide an update. Bob stated that the team reviewed the change and stated that no IMA (10/22/08 Comments to minutes received from Integra - in bold) or system changes are necessary, so this CR will cross over to Product/Process. Bob stated that they looked at one change and solution and the concept failed. Bob stated that Qwest has other solutions but those were more complex and the team is evaluating the changes that need to be made. Bob stated that we would like to schedule an adhoc meeting in about two weeks to review the status and potential new solutions. Bonnie Johnson-Integra asked if the adhoc meeting will be to update the CLECs or to present a solution for the CR. Bob Mohr – Qwest stated that is what Qwest hopes but he did not want to set any misconceptions but the existing solutions are more complex. Bob stated that in the next 2 weeks our objective is to research, test, and look at financials. Mark Coyne – Qwest thanked Bob for the update.

9/17/08 Systems CMP Meeting Susan Lorence-Qwest said that this request was submitted as a Product/Process CR. This CR is in the Systems Package because an industry guideline CR has to be submitted as a system CR per the CMP Document. If determination is made that there are no system changes the CR will be crossed over to a Product/Process CR. Bonnie Johnson-Integra said (9/25/08 Comments to minutes from Integra in bold) she will not read the entire CR request but that there have been a number of discussions with Qwest on these types of circuits and there is a lot of background and history. At a high level, Qwest advised Integra that regardless of the NCI code on requests for 2w/4w non loaded loops, Qwest installs, provisions and repairs to a voice grade level. She said that they are asking Qwest to provision and repair circuits based on the industry standards for the NCI/SECNCI Code instead of just the NC code. Susan Lorence-Qwest said that we held a clarification meeting on September 9th. She said that Bonnie provided ANSI T1.418 as the Industry Guideline. Bonnie Johnson-Integra said that was provided as an example and may not cover all of them. Qwest has a lot of codes already referenced in the tech pubs. We talked in the clarification call about the industry guideline CR having to be submitted as a system CR. She said that if there if no system work, the CR would be crossed over to a Product/Process CR. She said that they have been trying to address this issue for quite some time and have a concern about any delay. She said that there have been so many people engaged up to the VP level and they would like Qwest to respond ASAP on how soon this can be done. Susan Lorence-Qwest said that the SME team is already looking at the CR and that we will have a response by the next CMP meeting. She said that we hope to provide a response on whether we are accepting the change and whether there is system work involved. She said that once we determine if there is no system work involved, the CR will be crossed over to Product/Process. Bonnie Johnson-Integra said that they don’t believe they should have had to issue this CR but Qwest recommended that they do. She said that there are industry guidelines that Qwest should be repairing and provisioning their circuits to. She said that they have been trying to get this resolved for over a year and they don’t want to wait month after month for a response and will not be very patient. She said that anything Qwest can do to expedite the process would be appreciated.

CenturyLink Response

For Review by CLEC Community at the March 18, 2009 CMP Product/Process Meeting

Bonnie Johnson Integra

Subject: Integra Change Request - CR #PC082808-1IGX

This CR is requesting to Design, Provision, Test and Repair Unbundled Loops to the Requirements requested by CLEC, including NCI/SECNCI Code Industry Standards.

Additional detail for this change request can be found at: http://www.qwest.com/wholesale/cmp/changerequest.html

Qwest Response:

The Unbundled Non Loaded Loop product was developed to interface with various applications contained in Technical Publication 77384. For Unbundled Loop LX-N Network Channel (NC) codes, the NCI codes are informational only, as stated in the above mentioned Technical Publication and do not affect transport designs or performance. The associated NC code requires that the service use non-loaded, metallic facilities free of faults (grounds, shorts, noise, or foreign voltage). The CLEC has responsibility to inspect the character of the facilities, e.g. gauge, length, etc and determine that the facility is appropriate for their specific application.

Because Qwest is under no obligation to provide the product in the manner requested by CLEC, and Qwest is only obligated to provide a Non Loaded Loop to the broader standards listed in Technical Publication 77384, this Change Request to Design, Provision, Test and Repair Unbundled Loops to the requirements of the NCI code required a business discussion regarding the benefit to providing Non Loaded Loops in this manner vs. the cost to do so. That is, because there is no obligation to provide Non-Loaded Loops in this manner, the decision to implement this CR becomes one of economics. Absent the CLEC community agreement to negotiate in good faith to perform cooperative testing, this request becomes economically not feasible for Qwest. Therefore, Qwest respectfully denies this request.

Sincerely

Qwest Corporation