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Open Product/Process CR PC093003-1 Detail

Description Of Change

Attachments: Overview of Loop Test IVR process and enhancements, Detailed M & P for Covad’s Loop Test IVR

Covad would also like to make this tool available for Qwest Maintenance and Repair Tech’s when trouble shooting a Covad loop.

Project Meetings

John Berard with Covad said he would respond formally to the denial response. John added that the IVR testing tool would reduce time in the call, and reduces, rather than increases, the testing time. John said he did not understand the $30M figure provided in the denial response because the same system is used today by Qwest to send tone and test a line and it is the same system POTS test use for the retail side. The tool is more efficient and the electronic delivery of demarc information on another CR under development will not have the advantage of the IVR Tool. In addition, the IVR testing could be done 24 x 7. John also said there was no CLEC opposition to the IVR tool when he discussed at the CLEC only call and no CLECs were concerned that Qwest would be doing something special for Covad over other CLECs. Testing the loop with the tool is like getting your balance on a credit card.

Tim Gianes explained that the $30M training issue is related to performing a different test for each CLEC customer across the 14 states. Carla Pardee with AT&T asked if the test is available in other ILEC locations. John answered yes, that Qwest is the only ILEC that has denied. Liz Balvin with MCI asked if Qwest is concerned that if this CR is accepted, then other CLECs may ask that their testing capability be implemented.

Judy Schultz with Qwest said that what Qwest does for Covad would have to be done for other customers and the training for specific customer testing tools is the concern. Tim Gianes said that Qwest doesn’t use the IVR to do testing and Qwest uses standard tests.

John Berard said that the tool adds option 4 for the loop test, which can be done remotely, and the call goes into the same exact IVR. John added that Qwest wasn’t willing to trial the test in one garage. In contrast, SBC has been asking if they can offer this testing to other CLECs. Tim Gianes responded that Qwest did perform a trial and technicians did use the tool. It wasn’t that the tool was not useable, but Qwest did not want to be in a position where other CLECs that had testing tools would request implementation of their testing tool. John said that Qwest should be open to other tools.

Liz Balvin said that the tool may cut down on jeopardies caused by not being able to contact CLECs. Tim Gianes said that Qwest would not gain efficiency when dealing with multiple tools for multiple customers and from a Qwest perspective technicians would have to be trained on multiple customer tools. The reason for the denial was not due to the quality of the tool. This CR will be moved to Denied status. Covad will send a formal response.

10/15/03 October CMP Meeting John Berard with Covad presented this new CR. John said the IVR loop test application. When a Qwest tech is in the field and finished installing a loop at the NID can perform continuity testing on UNE using this front end system. The system asks the tech to input the PONE number and verifies at the right central office and correct loop. The test includes putting a short on the loop and taking the short off, then pressing “0” and getting a Covad agent to get the demar information. Qwest requested that Covad submit this CR because this is a process change and can be used for products. Jim Recker asked if worked for DLC. John said yes. Kit Thomte asked how this CR is different from the CR denied last September. John said the difference is that the previous CR was a tool that required the Qwest tech to be on the line with the Covad agent when the continuity testing was done. The new CR allows the Covad agent to see the test. Jamal Boudhaouia asked if Covad would share the technical parameters, noise level and threshold. John said he will take that question back to Covad. This CR will be moved to Presented status.

CLEC Change Request Clarification Meeting

3:00 p.m. (MDT) / Wednesday October 7, 2003

1-877-572-8687 3393947# PC093003-1 Loop Test IVR application from Covad

Name/Company: John Berard, Covad Denny Graham, Qwest Craig Suellentrop Qwest Linda Sanchez-Steinke, Qwest

Introduction of Attendees Introduction of participants on the conference call was made and the purpose of the call discussed.

Review Requested (Description of) Change Linda Sanchez-Steinke read the Description of Change from the CR; Covad is requesting that Qwest allow it’s field Technicians to use Covad’s Loop Test IVR application when contacting Covad to perform Test and Acceptance on a loop. Currently Qwest Technicians use option number 1 when contacting Covad for loop acceptance, Covad is requesting that the Qwest Technicians now use Option number 4 to contact Covad and perform the loop acceptance testing via the Loop Test IVR application. Once the test has been completed the Qwest Tech will hit Option 0 to be connected to a Covad Agent to provide demarc information and receive a confirmation number. Covad would also like to make this tool available for Qwest Maintenance and Repair Tech’s when trouble shooting a Covad loop. Linda said there was also an Overview of the Loop Test IVR process Power Point presentation and M&P for Covad’s Loop Test IVR attached to the CR.

Linda mentioned there had been a similar CR submitted by Covad last year. John Berard said that this tool will give extra features. This tool will work similarly to credit card companies when calling into customer service, this will enable the ability to get information about the account.

When Qwest wants to do test and acceptance, input the PON number via the IVR, hit 0 to be directed to the agent. The Covad system has captured information and is already pulling up the account. There are seven other features when installing POTS, technicians call into the switch to test on the loop. The features allow testing that can be done without the assistance of a Central Office Technician. Craig asked if Covad requests to have the tool used with unbundled loop with cooperative testing. John said yes and added that other ILECS like it. John said he had gone over the details of the tool with Denny & Craig in a previous meeting.

Confirm Areas & Products Impacted Maintenance / Repair Provisioning

Confirm Right Personnel Involved Correct personnel were involved in the meeting.

Identify/Confirm CLEC’s Expectation Covad is requesting that the Qwest Technicians now use Option number 4 to contact Covad and perform the loop acceptance testing via the Loop Test IVR application. Covad would also like to make this tool available for Qwest Maintenance and Repair Tech’s when trouble shooting a Covad loop.

Identify any Dependent Systems Change Requests No systems change requests.

Establish Action Plan (Resolution Time Frame) John will present this CR at the October CMP Meeting. Qwest will provide a response at the November CMP meeting.

CenturyLink Response

November 11, 2003

For Review by the CLEC Community and Discussion at the November 19, 2003 CMP Meeting

Name:John Berard Title:Operations Support Company: Covad

SUBJECT:Qwest’s Change Request Response PC 093003-1 Covad IVR Testing Tool

This letter is in response to CLEC Change Request (CR) PC093003-1. This CR requests that Qwest implement Covad’s IVR Testing Tool for use in the field for Unbundled Loop provisioning and repair to warrant Qwest’s Technical Publications parameters. Qwest utilizes its own test tools for Unbundled Loop provisioning and repair. The use of Covad’s IVR tool requires adding an additional and redundant step to the Unbundled Loop provisioning process and Unbundled Loop repair process. Although it appears that the Covad Testing Tool & utilization process has been modified, the fundamental reasons for this rejection are the same as the reasons for the earlier rejection of PC102301-1 submitted in early 2002.

Utilization of Covad’s IVR tool obligates Qwest to stand ready to evaluate and accept any request from other CLECs to trial their respective test platforms into Qwest’s processes in a nondiscriminatory manner. Additionally regulatory requirements prohibit Qwest from providing different levels of service to CLECs. Utilization of a CLEC provided provisioning and repair tool or process may benefit some CLECs over others by creating disparate service levels.

Since acceptance of this request from Covad would open Qwest to accepting similar requests from all CLECs, Qwest has determined that utilization of the Covad IVR testing tool would be cost prohibitive to implement. Qwest would incur additional and unrecoverable costs related to turning up and completing service orders and/or repair tickets. Cost estimates are based on order volumes (300,000) across the 14 states for a minimum of 300 existing CLECs who could each make similar requests of Qwest and which Qwest may have to honor for parity purposes. Qwest would incur additional costs related to initial & required ongoing employee training for any testing tool that could be provided by the CLECs. Depending on the service types included, provisioning and/or repair application, and the complexity of the tool, employee-training costs or initial deployment could run $100,000 per request or potentially $30M if all CLECs made similar requests of Qwest. Considering the increasing complexity of providing comprehensive training to manage multiple CLEC test vehicles, ongoing and refresher training costs would be substantial. Qwest already performs and documents internal tests based on ANSI standards. Utilizing test tools from CLECs would not only duplicate those tests but would require Qwest to spend a minimum of an additional 3-5 minutes per order at a cost of $690,000 - $1,150,000 per year based on regional order volumes. Qwest would also incur additional costs related to required operational trials, process documentation and revisions, and the complexity of managing numerous process requirements for multiple tools. This is not measurable at this point due to the unknown nature of each potential request, but is recognized as a valid concern and real cost to Qwest.

The requested change does not result in a reasonably demonstrable business benefit to Qwest or Covad. In fact performance data during the trial does not support that service levels improved for Covad. Utilizing multiple test platforms requires Qwest to create multiple processes, requiring the Qwest Network Technician to determine which process/platform to use for which CLEC. This creates potential for human error, potentially degrading service quality and performance results.

As stated above, adapting the IVR tool into Qwest’s processes creates legal, economic and service quality performance liabilities for Qwest. Qwest respectfully declines to implement Covad’s IVR tool into its Network processes.

Sincerely,

Tim Gianes Senior Project Manager

cc: Paul Kirchhoffer, Diane Diebel, Mary Retka, Barry Orrel