Wholesale: Products & Services

Open Product/Process CR PC101201-1ES Detail

Description Of Change

These test results should be standardized utilizing the CEMR MLT test and 77S test unit utilized by Qwest Central Office Technicians.

These standards should also drive processes to repair existing loops or LST (Line and Station Transfer) working voice but not in service data loops to acceptable loops out of the end users serving terminal. They should also drive process implementation for Qwest Network or Complex Network Service technicians to be dispatched out to address the identified loop quality issues.

Loop Standards on:

Capacitance

Resistance

DC and AC signatures

Voltage

Project Meetings

CenturyLink Response

John Moham Covad Communications TAC Manager - ILEC Repair Denver COE Line Sharing Data Parameters

CC: Kathleen Lucero Steve Hilleary Deborah Heckart Brett Fesler Mike Lanoue

This letter supercedes Qwest Response dated 12/05/01 that responded to your CLEC Change Request PC101201-1 dated 10/12/01 Shared Loop Data Parameters.

This Change Request asks Qwest to engage in a collaborative effort with CLECs to establish testing provisioning and repair parameters for DSL on shared loops including: - a minimum set of standards; - standardized testing utilizing CEMR MLT and 77S test sets; - a loop repair process that requires a LST if the provisioned loop does not meet CLEC standards; and - a loop repair process that dispatches a Qwest technician if the loop has quality issues. Minimum Testing Parameters

Qwest is disinclined to develop a minimum set of provisioning and repair standards that would “qualify” a particular facility to carry Line Sharing for two reasons: - Difficulty in developing a “standard”. This is accentuated by the varied requirements of the multiple vendors, types of DSL, and quality of service deployed by CLECs. Developing the test parameters for an “acceptable” circuit for all CLECs would be a time and resource consuming activity for all parties and one not prudent to do in light of the following. - The minimum standards for provisioning and repair of a metallic loop are already being developed in an industry forum, American National Standards Institute (ANSI) T1E1.3. In order to prevent duplicative development and implementation efforts, Qwest believes the ANSI forum to be the most appropriate to address this issue. While Qwest denies this request to work independently with the CLECs on a set of minimum standards, Qwest is more than willing to work collaboratively with the CLECs and other industry participants to develop a set of national standards in the appropriate industry forum.

Additionally, Qwest Technical Publication 77406 Interconnection - Shared Loop outlines the minimum set of transmission standards that a facility can support. The transmission characteristics defined in the technical publication provide the CLEC with information regarding the minimum requirements that a facility must support to be delivered to a CLEC based on the Network Channel and Network Channel Interface (NC/NCI) codes that the CLEC includes on the Local Service Request (LSR). CEMR MLT and 77S Test Sets

In the clarification call for this Change Request, Covad indicated it would like to utilize Customer Electronic Maintenance and Repair (CEMR) Metallic Loop Test (MLT) for pre-provisioning xDSL loop qualification. Qwest has already addressed this issue in 271 workshops. CEMR MLT is a repair tool that provides CLEC testers in the repair process the capability to evaluate transmission characteristics of a metallic loop connected to a Qwest switch.

The reasons presented in the workshops for Qwest’s objection to using MLT in a provisioning process are twofold. First, MLT is an intrusive test that will disrupt voice services. While this is not a concern for repair scenarios, it is a real concern when MLT is being triggered electronically through CEMR. Secondly, to ensure the protection of Customer Proprietary Network Information (CPNI), MLT has a front end edit that limits access for a specific loop to the Local Exchange Carrier of record for that loop. In pre-order activity, MLT will not allow CLECs to access metallic loops it does not “own”.

However, in the Pre-Ordering process, Qwest can and does provide facility characteristic information to CLECs based on facility records via the Raw Loop Data Tool (RLDT). The data included in the RLDT is the same underlying data that Qwest utilizes to qualify loops for its retail xDSL product offerings. This data can be used, much the same way Qwest uses it, to qualify loops for CLEC xDSL services.

During the provisioning process to deliver shared loop products to CLECs, Qwest does use test sets, including the 77S, to identify load coils on a loop. Additionally, Qwest tests the electrical continuity of the data path for every shared loop provisioned for CLECs prior to circuit delivery.

Once the shared loop is provisioned for the CLEC, the CLEC can perform a MLT through CEMR.

Loop Repair LSTs

The Change Request indicates, "These standards should also drive processes to repair existing loops or Line and Station Transfer (LST) working voice but not in service data loops to acceptable loops out of the end users serving terminal." Qwest believes that existing repair processes sufficiently care for this concern. Again, Qwest delivers shared loop circuits according to the parameters outlined in Technical Publication 77406. Please review the response to Change Request PC101201-2 regarding loop conditioning during the repair process.

Loop Repair Dispatch

Qwest will dispatch a technician to a network DMARC at a customer premises only if trouble is isolated to the Outside Plant portion of the Qwest network. Qwest will not agree to dispatch its technicians unless the circumstances of a trouble ticket dictate such activity.

Sincerely,

Cliff Dinwiddie Senior Manager Global Wholesale Product Marketing