Wholesale: Products & Services

Open Product/Process CR PC101802-3ES Detail

Description Of Change

Expected Deliverable

Reduction of interval from 3 to 2 days effective Dec. 1, 2002

Project Meetings

Buckmaster-Qwest presented the revised Qwest denial. Zulevic-Covad stated that he found the number of resources Qwest claimed it required to shorten the interval by one day to be mind-boggling. He asked if Qwest’s DSL was a flow-though process. Buckmaster-Qwest stated that she did not know if it was a flow through process. Zulevic-Covad stated that the Qwest DSL interval was a 5 day end-to-end interval. He stated that the intervals for Line Sharing, Line Splitting and Loop Splitting services were not end-to-end. Covad often took more than 2 days to finish their portion of the provisioning process. He stated that this was not parity. He stated that Qwest could continue with whatever recommendation it liked. White-Qwest stated that Qwest was denying the CR. Zulevic-Covad stated that he would escalate the CR.

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Ad Hoc Meeting 01-29-03

Attendees Matt White – Qwest Cindy Buckmaster – Qwest Deb Smith – Qwest Judy Schultz - Qwest Mike Zulevic – Covad Liz Balvin – WorldCom Sam Tenerelli – WorldCom Sharon Van Meter – AT&T

White-Qwest announced attendees and explained that the purpose of this meeting was to allow Qwest to clarify its reason for denying this CR and to answer and CLEC questions that were not addressed at the January CMP Meeting. He asked Buckmaster-Qwest to review the Qwest Response to the CR. Buckmaster-Qwest reviewed the response. She stated that Qwest was denying the CR for economic infeasibility because of resources impacts, including addition of resources, and volume of orders. She stated that the cost to Qwest when taken into consideration with the volume of Line Sharing orders compared to the volume of like orders resulted in the economic infeasibility conclusion.

Balvin-WorldCom stated that there was discussion at the Monthly Meeting around products with two-day intervals. Buckmaster-Qwest stated that the only Qwest products with two-day intervals involved record work. She explained that none of these products had any technician intervention.

Van Meter-AT&T stated that she would like to see more detail in the response. Schultz-Qwest stated that Qwest would revise the response.

Balvin-WorldCom stated that there was a Systems CR that involved flowthrough that might influence Qwest’s decision to deny this CR. Schultz-Qwest suggested that the Product/Process CR remain in Denied status and that Buckmaster-Qwest review the Systems CR to further analyze its relevance to the Product issues. Zulevic-Covad stated that it would be fine to leave the CR in Denied status but that he wanted Qwest to consider that there was another ILEC that had voluntarily changed their intervals. He also asked that Qwest reevaluate this request when the flowthrough CR was completed.

Balvin-WorldCom stated that she would like to see a more detailed discussion of the rationale for denying the CR for economic infeasibility. White-Qwest asked if there were any additional questions. There were none. Schultz-Qwest thanked the attendees.

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01/15/03 - CMP Meeting

Smith-Qwest presented the Qwest response. Zulevic-Covad stated that he had forwarded additional information to Qwest after Qwest had distributed the response. He asked if that information changed Qwest’s response to the CR. Smith-Qwest stated that it did not. Buckmaster-Qwest stated that the information had not changed Qwest’s response, that Qwest was exceeding their obligation of parity with retail, and that the request was economically infeasible. She continued that there was an agreement between Qwest and Covad in March 2002 when Qwest had voluntarily revised the interval from 5 to 3 days that Covad would not approach Qwest for another interval reduction. Balvin-Worldcom asked for clarification of the reason the CR was economically infeasible. Buckmaster-Qwest stated that the work to implement the CR was extremely manually intensive and costly, especially in light of the relatively low volume of orders. Balvin-Worldcom asked if there was a systems CR open that might help this process change be less expensive. Zulevic-Covad stated that there was a systems CR open for line sharing flow through. Buckmaster-Qwest stated that the change requested in PC101802-3 would not be facilitated by the systems CR. She stated that this change did not involve order fallouts. She continued that there were three manual changes Qwest would need to make to the IMA system, the FOC system and the Operations system to implement this change. Zulevic-Covad asked if the same cost would apply if the interval were reduced to 4 days. Buckmaster-Qwest stated that the same costs would still apply. She stated that in order for this interval to change in any way, Qwest would have to implement extensive manual handling of orders. She stated that the issue behind the denial of this CR was the amount of manual operations and the relatively low volume of orders. Zulevic-Covad stated that he did not recall any agreement that Covad would not request an additional reduction of this interval. Balvin-Worldcom recommended that the CR remain open for an additional month for Qwest to conduct additional research. Buckmaster-Qwest stated that additional would not change Qwest’s response. Zulevic-Covad recommended rewriting the response to more clearly emphasize the reasons that the CR was economically not feasible. Thomte-Qwest stated that Qwest would hold an ad hoc meeting before the next monthly meeting to discuss this CR. The CR remains in Evaluation.

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12/18/02 - CMP Monthly Product/Process Meeting

Smith-Qwest presented the Qwest response. The attendees agreed to move the CR into Evaluation status.

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11/20/02 - CMP Monthly Product/Process Meeting

Zulevic-Covad presented the CR. He stated that BellSouth already offered shorter intervals, and that Qwest should be able to as well. Burke-Qwest stated that she had no questions. The CR status was updated to Presented.

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CLEC Change Request – PC1018002-3 Clarification Meeting 10:30 AM (Mountain Time) / Wednesday, November 6, 2002

1-877-550-8686 2213337#

Attendees Matt White – CRPM Laurel Burke – Qwest Crystal Soderlund – Qwest Deb Smith – Qwest Mike Zulevic – Covad Make Lanoue - Qwest

Introduction of Attendees White-Qwest welcomed all attendees and reviewed the request.

Review Requested (Description of) Change Zulevic-Covad reviewed the CR. He stated that Covad would most prefer an interval of 1 day, but would be happy with a 2 day interval.

Confirm Areas and Products Impacted White-Qwest confirmed that the attendees were comfortable that the request appropriately identified all areas and products impacted.

Smith-Qwest stated that the current interval for line splitting and line sharing was 3 days, and the interval for loop splitting was 5 days.

Zulevic-Covad stated that loop splitting was not a product Covad currently used (although that may soon change) and that Covad was OK with an interval other than 2 days for Loop Splitting, but they want some reduction of the current interval. Confirm Right Personnel Involved White-Qwest confirmed with the attendees that the appropriate Qwest personnel were involved.

Identify/Confirm CLEC’s Expectation White-Qwest reviewed the request to confirm Covad’s expectation.

Identify and Dependant Systems Change Requests White-Qwest asked the attendees if they knew of any related change requests.

Burke-Qwest stated that the current Line Sharing CR may be related to this one.

Establish Action Plan White-Qwest asked attendees if there were any further questions. There were none. White-Qwest stated that the next step was for Covad to present the CR at the November Monthly Product/Process Meeting and thanked all attendees for attending the meeting.

CenturyLink Response

AMENDED RESPONSE For Review by CLEC Community and Discussion at the February 19, 2003, CMP Product/Process Meeting

Mike Zulevic Director - GEA Covad Communications

SUBJECT: Qwest’s Change Request Revised Response - CR #PC101802-3

This letter is in response to CLEC Change Request PC101802-03. This CR is a request by Covad to reduce the interval for Line Sharing, Line Splitting and Loop Splitting from 3 days to 2 days as Covad suggested that BellSouth had done.

This response confirms Qwest’s denial of this CR, for the reasons identified in the January 8, 2003, response, and clarifies the justification for the economically not feasible reason for denial. The following are the major reasons supporting Qwest’s decision to consider the CR economically not feasible:

Line Sharing Volumes: - Total In-Service Line Sharing Orders as of 12/31/02 – 26,083 (average 1,400 incremental lines per month). - Total In-Service UBL* Orders as of 12/31/02 – 483,308 (average 14,000 incremental lines per month). - Line Sharing represents just 5% of the total of these 2 product lines (10% of the average monthly volumes). - This is considered a Low Volume of requests.

Process Changes: - One additional Resource in the Service Center to move Orders more quickly. - A minimum of 60 to 90 additional Central Office Resources across Qwest’s 14 state region to move Orders more quickly. (Line Sharing is currently ordered in 12 of Qwest’s 14 in-region states)

The economic magnitude of adding the indicated resources is too large for the small number of orders. Therefore, Qwest has determined that reducing the interval on Line Sharing orders is economically not feasible. Qwest respectfully declines this change request.

The Line Sharing product is already provisioned in an interval that is shorter than the Retail interval. As the requirement is parity with retail, this requirement is more than met with the current interval.

Qwest continuously evaluates its ability to deliver products in a more timely fashion. If such an opportunity presents itself in the future, Qwest will implement and notify CLECs via the established processes.

Sincerely, Cindy Buckmaster Product Manager

*The comparison made to UBL is made solely on the basis of the functions required to install both services. These functions are comparable for both the Order Processing and Central Office provisioning.

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January 6, 2003

REVISED RESPONSE For Review by CLEC Community and Discussion at the January 15, 2002, CMP Product/Process Meeting

Mike Zulevic Director - GEA Covad Communications

SUBJECT: Qwest’s Change Request Revised Response Response - CR #PC101802-3

This letter is in response to CLEC Change Request PC101802-03. This CR is a request by Covad to reduce the interval for Line Sharing, Line Splitting and Loop Splitting from 3 days to 2 days as Covad suggested that BellSouth had done.

At this time, Qwest has no plans to reduce the interval for the Line Sharing, Line Splitting and Loop Splitting Products. Qwest is denying this request because it is economically not feasible. The following are the major reasons supporting Qwest’s decisions:

Installation intervals for these products were negotiated during the ROC TAG forums held in 2001 and 2002. SGAT Exhibit C Service Interval Tables provides the agreed upon intervals. Qwest will continue to be consistent with these agreements.

Qwest retail interval for the DSL product is 5 business days. As the wholesale interval is already less than retail, Qwest is not inclined to reduce the wholesale interval further. This is consistent with the discussions that took place with the CLECs earlier in 2002, when Qwest reduced the interval from 5 to 3 business days on Line Sharing and Line Splitting.

Both system and process changes would be required. System changes are required any time an interval is modified. These system changes are both manually intensive and time consuming, therefore costly. Due to low volumes of new Line Sharing and Line Splitting requests, and the lack of Loop Splitting requests, changes to the system for the small volume of Line Sharing products would be prohibitive. (The Line Sharing, Line Splitting and Loop Splitting products represent less than 5% of the total product volumes.) In addition, Qwest processes cannot guarantee a 2-business day interval causing potential problems with missed commitments for the end user customer.

Upon reviewing BellSouth’s service interval guide, Qwest has found that Qwest is already providing a comparable interval to BellSouth’s, if not superior in some cases. BellSouth applies their interval differently than Qwest. BellSouth applies their 2-business day interval after the request goes through their LSR processing interval. The LSR processing interval ranges from 10 business hours (or 1 business day) to 24 business hours (or 2 ½ business days). Total order completion interval for BellSouth is their service interval added to their LSR processing interval, which is 3 – 4 ½ business days. Qwest, on the other hand applies their 3 business day interval at the time the LSR is received (application date). Qwest includes the LSR processing time within their 3-business day interval; thus Qwest’s total order completion interval is 3 days.

In any case, it is Qwest’s understanding that BellSouth applies the interval that matches their retail offering. Qwest’s retail offering is currently 5 business days.

Therefore, Qwest respectfully declines this change request.

Sincerely, Debra Smith Product Manager

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December 6, 2002

DRAFT RESPONSE For Review by CLEC Community and Discussion at the December 18, 2002, CMP Product/Process Meeting

Mike Zulevic Director - GEA Covad Communications

SUBJECT: Qwest’s Change Request Response - CR #PC101802-3

This is a preliminary response regarding Covad CR PC101802-3.

Qwest has reviewed the current Line Sharing provisioning interval. There are a number of issues to be analyzed in answering this request. For this reason, Qwest would like to move this Change Request into the Evaluation Status to provide a complete answer to this request.

Qwest will provide a status update at the January CMP meeting and will outline their response at that time.

Sincerely,

Debra Smith Product Manager Qwest Corporation