Wholesale: Products & Services

Open Product/Process CR PC102301-1 Detail

Description Of Change

Project Meetings

08/21/02 - August CMP Meeting Minutes Qwest (Gianes) indicated that a revised document had been provided, the document is being reviewed by the Network organization. A point of concern has been raised regarding the lack of information regarding the test parameters behind IVR. COVAD (Zulevic) inquired if the agreement was being expanded beyond provisioning? Gianes indicated that in the last session with COVAD (Mindy and John) agreed not to go beyond provisioning at this time. This CR will remain in “Development” status.

07/17/02 - July CMP Meeting Minutes: Qwest (Gianes) provided an update indicating that both COVAD and Qwest were happy with the results of the trial. Qwest would like to roll out the process within the fourteen states. Two regions have been trained so far, but actual implementation is pending legal approval. This process would be not be applicable to repair. This CR will continue with a status of "Development" Revised response will be provided prior to the next meeting.

To: "Berard, John" cc: "Zulevic, Michael" , "Cutcher, Minda" , "Linda Hendricks" , "Deni Toye" , "Mary Pat Cheshier" , "Alan D Braegger" , Michael Raleigh/Mass/USWEST/US@USWEST, "Kurtis L Preston" , "Rick Mabry" , "Diane L Diebel" , Kathleen Thomte/Mass/USWEST/US@USWEST

Subject: Re: IVR Trial with Covad

John, I still have not received the list of service orders from you that you had agreed to send for this trial. This list was to enable both company's to work from the same "database" for tracking purposes and determination of final results. I understand that the list may require updating on a weekly basis due to the service order intervals. That is not a problem. Would you also let me know what has happened regarding providing Qwest the On Time Performance (OTP) report we discussed. It was our impression that this was one of your critical measures of success in previous deployments of the IVR tool to other ILECs. Last week we decided to move forward without the service order list from Covad by asking Mike from the QCCC to pull a 30 day historical and future DD report. This will assist Kurt and Rick in determining which higher volume wire centers to focus on within the geography we discussed as we progress from the limited "dry run" with a few orders to the full scope of the trial. At this point we will use the future service order data we pulled as our baseline going forward to track and determine usage, IVR performance, etc. Also, Alan from the Qwest field staff, has developed a more refined flow chart which we have shared with the field director for use by the technicians. This provides an accurate and more straightforward chart of what the field technicians will experience when using the Covad IVR. I will be glad to share at our next joint status meeting. Please contact me regarding when you will be able to provide the future service order list and the OTP report at your earl

04/25/02 To: "Berard, John" cc: "Cutcher, Minda" , "'tgianes@qwest.com'" , "Zulevic, Michael" , "Deni Toye" , "Alan D Braegger" , lkhendr@qwest.com, Kathleen Thomte/Mass/USWEST/US@USWEST, "Rick Mabry" , "Kurtis L Preston" , "Mary Pat Cheshier" , Michael Raleigh/Mass/USWEST/US@USWEST, "Diane L Diebel"

Subject: Re: QWEST Trial of Covad IVR Loop Test Tool

Everyone, Here is a what I believe we agreed to on todays call: The trial will start Monday April 29th as scheduled. All parties agree that since Covad orders Coordinated Installation with Cooperative Test only, Qwest will utilize the IVR test during the Cooperative Testing portion of the test and turn up. As the field technicians become more comfortable with the IVR tool they have the option of utilizing the IVR at any point during their installation activity as long as it does not jeopardize Qwest meeting the Coordinated Install timeframe. Qwest will begin the trial by having a technician access sample Covad service orders and run through the IVR process. The technician will provide the Qwest team immediate feedback regarding their experience. John will send to Tim a list of pending Covad service orders so both Covad and Qwest will be working from the same list. This is critical in providing accurate results at the end of the trial. John is still pursuing providing an On Time Performance (OTP) report to Qwest since this is where Covad indicates there will be a significant benefit. John agrees a report of this type will be a valuable measure of success at the end of the trial. Minda confirmed that Qwest is the only ILEC with whom Covad orders Coordinated Installs. Based on the nature of Coordinated Install orders, Qwest performs extensive workstep completion confirmation prior to a field tech being dispatched to the premise. Minda agrees that because Qwest applies a very structured approach to Coordinated Installs this may minimize the extent of the benefit to Qwest that other ILECs have experienced with the IVR. Everyone also agrees that Qwest will continue to perform and document their required Core tests and follow established Coordinated testing agreements as they do today. Utilizing the IVR does not negate any current processes. Minda also agrees that if Qwest experiences a Fail situation via the IVR but successfully has passed standard Qwest core tests in the same area, Qwest will not default to the Covad test result but will contact Covad and work through the variance on a case by case basis as they do today. Tim will update the Trial Document to specify that Qwest will only enter the numeric portion of the PON number when accessing the IVR tool. Tim will schedule a follow up with the QCCC and the field to confirm the tracking spreadsheet detail Qwest will utilize to provide trial results on the orders submitted by Covad. Tim will schedule a joint meeting with Covad within the first 2 weeks of the trial to discuss progress and address concerns and opportunities.

I have tried to capture our conversation acccurately and completely and ask that you send me any corrections to what I have stated by end of day tomorrow. If there are no corrections or after making corrections I will ask that Kit Thomte incorporate these notes into our ongoing tracking of the original CR.

Tim Gianes 303 703-2199 03/22/02 - E-mail from Covad asking to begin trial without providing test parameters associated with IVR capability to Qwest

From: "Michael Zulevic" To: "Todd Meade" , "Michael Keegan" Cc: "Berard, John" Subject: IVR documentation Date: Fri, 22 Mar 2002 11:16:38 -0700

Todd,

Per our discussion yesterday, Covad does not see the need to provide our test perameters associated with our IVR capability to Qwest. Covad considers this to be proprietary information. As I stated yesterday, I would be willing to certify that our test perameters are within the technical specifications of your UNE loop offering. Once again, the IVR capability is in use in Verizon and the capability is now being deployed in SBC. BellSouth is also working with us to deploy the capability there as well. Covad has not been "required" to provide technical documentation to any of these ILECs as a condition of use. It must be understood that the IVR is a test capability, developed for use by Covad, that we are agreeing to allow Qwest and other ILECs to use, to assist them in their provisioning process. If, after a joint trial is completed, Qwest determines they have no need for this test capability, there is no obligation to continue with it's use. I would like to begin the trial as soon as possible, as trials with other ILECs have resulted in a significant improvement in the delivery of UNE loops. Please let me know if this informaion is sufficient to start the trial, and when we can get it started.

Thanks,

Michael Zulevic Director- External Affairs Office(520)575-2776 Cel(303)884-5657 Fax (520)575-2785

02/27/02 - Status report from Qwest posted in CMP database

Subject: Covad IVR Meeting 2/27/02 Date: Wed, 27 Feb 2002 16:12:46 -0700 From: "Tim Gianes" To: Todd Mead CC: "Frederick M Aesquivel Iii" Todd, I participated on a call today with Michael Zulevic and John Berard with Covad. John was involved in the deployment of the Covad IVR to Verizon. We discussed the 2 pending requests which were: - Utilization of the Covad circuit ID instead of the PON to activate the IVR - Full disclosure of specific tests activated (by circuit type) within the IVR and the related test parameters set for each Pass/Fail decision

John felt he could locate the IVR development document which should contain this information and send me a copy. Michael questioned the need for Qwest to have this data. I explained that this would allow us to insure that Covad & Qwest agree on the standard tests and test parameters utilized by the IVR before requiring field technicians to accept the Pass/Fail status from the IVR. It will be very beneficial to the field and center technicians to understand what the IVR is running, not just the net result, so they can better determine what action to take. Having the test detail will also promote buy-in from the field to actively use the IVR tool if they see the potential value of the test results.

I have agreed that Qwest will utilize the PON# which is present on the Worddoc. Micheal stated that the PON numbers were unique and would not cause Qwest to inadvertently intrude on another Covad circuit in error. Since Covad currently does not always provide their circuit ID on the LSR, requiring this would create an unnecessary step for Covad. Despite Qwest's preference to use the Covad circuit ID there is no compelling system or process related reason to not use the PON# as preferred by Covad. If using the PON becomes a problem, the process will have to be amended to revert to the circuit ID.

I am awaiting delivery of the detailed IVR document from Covad. Upon receipt, review, and agreement on tests & test parameters we will set a definite trial start date. Regarding the trial, I confirmed with Michael that Denver metro was the agreed location and 60 days the agreed trial duration. I also mentioned, and they concurred, that at the end of the trial we would gather performance results data as defined in my original response to the CR and determine future action.

Tim Gianes 303 703-2199

02/22/02 Return E-mail from Covad

Subject: RE: CR Interactive Report Date: Fri, 22 Feb 2002 20:02:53 -0700 From: "Michael Zulevic" To: "Todd Mead" CC: "Gianes, Timothy" Todd, I am looking for answers to your questions and sent an email to Tim earlier today asking about your availability for a clarification call this Weds. with one of our people who facilitated the implementation in Verizon. Hopefully, we can get this back on track real soon. Thanks, Michael Zulevic Director- External Affairs Office(520)575-2776 Cel(303)884-5657 Fax (520)575-2785

02/22/02 Information E-mail from Qwest to new Covad CR owner

From: Todd Mead [mailto:tmead@qwest.com] Sent: Friday, February 22, 2002 12:02 PM To: mzulevic@Covad.COM Cc: Gianes, Timothy Subject: CR Interactive Report Mike, As promised, here is the link to our interactive report where you can see the latest on your CR(s). This report is updated every 2 days. http://qwest.com/wholesale/cmp/changerequest.html (click on the Product/Process link) As regards to PC102301-1 IVR Testing Tool, there are two outstanding issues. Qwest is waiting for Covad to supply a response to these issues before we move on with the trial. The issues are: - Please provide the test detail behind each of the IVR options by product and respond in particular to the discrepancy on the loop length issue. - Would Covad be able to provide their circuit ID on every order so we could use that rather than the PON? You may already provide the circuit ID already but wanted verification it is standard procedure to include it on all ISRs. After your meeting with Mindy, please let me know if you want me to set something up with Qwest personnel. Thanks Todd

02/13/02 E-mail response, Qwest waiting for new Covad contact to move forward with trial.

From: Tim Gianes 02/13/2002 03:18 PM To: "Cutcher, Minda" Subject: RE: IVR Trial Status (Document link: Tim Gianes) Thanks for the heads up Mindy. I hope you are moving into something else you will be enjoying, Thanks for helping and providing the information you have. I will await the decision fom Covad on who our contact will be and will look for the requested data from that person going forward. Good luck! Tim Gianes 303 703-2199

02/13/02 E-mail from Covad advising change of personnel

From: "Cutcher, Minda" on 02/13/2002 12:52:26 PM To: Tim Gianes Subject: RE: IVR Trial Status Tim, As a result of some internal reorgs at Covad, someone else is going to be driving this forward with you. It will likely be Mike Zulevik, but I will keep you posted. It will take us a few weeks to transition. Mindy

02/07/02 Qwest response e-mail to Covad

Subject: RE: IVR Trial Status From: Tim Gianes 02/07/2002 09:16 AM To: "Cutcher, Minda" cc: Todd S Mead , Michael Keegan , Deni Toye , Terrance L Meehan , Linda Hendricks Subject: RE: IVR Trial Status (Document link: Todd S Mead) Mindy, I was expecting you to be able to provide the test detail behind each of the IVR options by product and respond in particular to the descrepancy on the loop length issue I mentioned. Also, would Covad be able to provide their circuit ID on every order so we could use that rather than the PON? You may already provide the circuit ID already but wanted verification it is standard procedure to include it on all ISRs. Thanks. Tim Gianes 303 703-2199

02/06/02 Reply e-mail from Covad

Subject: RE: IVR Trial Status From: Cutcher, Minda" on 02/06/2002 05:29:48 PM To: Tim Gianes , Todd S Mead , Michael Keegan cc: Deni Toye , Terrance L Meehan , Linda Hendricks Subject: RE: IVR Trial Status Tim, Help me out here. Are you looking for me to give you some more info or are you chasing the info? Mindy

01/29/02 E-mail from Qwest poviding update to Covad

Subject: IVR Trial Status Date:01/29/2002 04:02 PM From: tgianes@qwest.com To: mcutcher@covad.com, Todd S Mead/Mass/USWEST/US@USWEST, "Michael Keegan" cc: "Deni Toye" , "Terrance L Meehan" , Linda Hendricks/COMPLEX/USWEST/US@USWEST Mindy, Todd and Mike, Here is an update after the meeting I had with the Qwest Unbundled Services Process team. They expressed a couple of concerns that I believe can be resolved without much delay. As soon as we close on these issues we should be able to start a trial. First: They are strongly recommending that we use the Covad circuit ID instead of the PON number. We would have to insure that the circuit ID is posted to the LSR up front by Covad. This circuit number should appear on the Worddoc that the field techs work from. Second: They have requested a detailed description of the specific tests (with acceptance parameters) that are run at each option of the IVR and for each service type. I did receive a document titled Covad Loop Test Logic which seems to describe some of Covad's test acceptance parameters. Within that document for instance under Loop Length it shows that 15K is the acceptable parameter for ADSL. If this is built into the IVR parameters we would fail the test when in fact I don't believe these circuits have this requirement. For those that do have a length restriction it is 18K not 15K. We all agreed that long term there is the potential for incremental time savings, depending to a large degree on the detail provided by the IVR. Hence the desire to still pursue the trial. I will complete the trial document when I have these last 2 elements. The test parameters by option will be included in the trial documentation that I will distribute to the field. Please call with any questions/clarifications. It may be beneficial to have a quick call with the IVR SME to quickly work through the test options issue. Tim Gianes 303 703-2199

01/11/02 E-mail from Qwest responding to Covad

Subject: Re: Status at Last Date: Fri, 11 Jan 2002 09:02:58 -0700 From: "Tim Gianes" To: "Cutcher, Minda" CC: tmead@qwest.com, tgianes@qwest.com Mindy & Todd, My responses are in red after the question. "Cutcher, Minda" on 01/09/2002 08:44:26 PM To: tmead@qwest.com, tgianes@qwest.com Subject: Status at Last Todd and Tim, At last, here's my status on Action Items: 6.1 complete 6.2 the answer is yes to all (with the exception of the request on "fail to access") however, I think Covad could provide some generic data on system up time, which would drive to the same info (yes?). =Generic up time data would be helpful.= However, the catch is that to collect all this data requires a programming request, which could take between 2-4 weeks, depending on workload in our IT group. On the I-Report stuff, my understanding is that Covad will provide Qwest with a list of all orders that used IVR, then Qwest would run the I-Report analysis. Please confirm. =This is correct. Will need Qwest order numbers and related repair ticket numbers as well. Based on agreed definition of "I" report........submitting a repair ticket within 30 days of the service order DD.= 6.3 complete 6.6 sounds like Tim and I have more work to do on this. Let me know when would be a good time to discuss further. =Todd, could you schedule a 30 minute meeting? Looks like late (after 4 pm) on the 16th or 18th, or anytime on the 21st would be ok at this time.= If you have any questions, etc. let me know. Otherwise, let's talk about next steps to implementation. Mindy 253-323-2481 (efax) 781-649-0703 (p) 978-869-7376 (m)

01/10/02 E-mail update from Covad on Kick-off meeting actions

Subject: Status at Last Date: Wed, 9 Jan 2002 19:44:26 -0800 From: "Cutcher, Minda" To: tmead@qwest.com, tgianes@qwest.com Todd and Tim, At last, here's my status on Action Items: 6.1 complete 6.2 the answer is yes to all (with the exception of the request on "fail to access") however, I think Covad could provide some generic data on system up time, which would drive to the same info (yes?). However, the catch is that to collect all this data requires a programming request, which could take between 2-4 weeks, depending on workload in our IT group. On the I-Report stuff, my understanding is that Covad will provide Qwest with a list of all orders that used IVR, then Qwest would run the I-Report analysis. Please confirm. 6.3 complete 6.6 sounds like Tim and I have more work to do on this. Let me know when would be a good time to discuss further. If you have any questions, etc. let me know. Otherwise, let's talk about next steps to implementation. Mindy 253-323-2481 (efax) 781-649-0703 (p) 978-869-7376 (m)

01/04/02 Meeting minutes for Kick-off meeting

11:00 a.m. (MDT) / Thursday 3rd January 2002

Attendees: Todd Mead / Qwest Tim Gianes / Qwest Mindy Cutcher / Covad

Purpose of the meeting was to develop the framework for the IVR trial scheduled to begin on the 28th January 2002 and lasting for approximately 2 months.

Identify/Answer CLEC/Qwest Questions About Trial : Location of trial – Denver Metro area. Tim will verify with local field director Duration of trial will be approximately 2 months During the trial, all existing loop tests will continue as before. Qwest technicians will still provide continuity tests to Covad as requested and Qwest center technicians will continue to provide Covad required circuit turn-up test results.

Establish Action Plan (Resolution Time Frame): 6.1 Mindy will provide Tim a password for IVR by Monday (01/07/02) / Mindy 1/7/02 6.2 Mindy will provide details on reporting capability of IVR. Specifically: - Number of times Qwest accesses the Covad IVR - Number of times Qwest attempts to access IVR but fails (new request) - Number of circuits tested by Qwest via the IVR - Number of circuits that Passed the required IVR tests - Monthly summary of failed tests by state - Identify all circuits tested via the IVR by Qwest to run batch report for “I” Reports 6.3 Mindy needs to confirm what type of circuit the IVR testing tool should be used for. / Mindy 1/7/02 6.4 Todd to forward the ppt and pdf file attached to original CR onto Tim. / Todd 1/3/02 6.5 Tim will produce a trial document outlining the trial purpose, what will be measured during the trial and the expected outcomes. / Tim 1/14/02 6.6 Ideally, this trial should capture the number of times the IVR test generated a ‘pass’ but Covad found a problem with the circuit. Both Qwest and Covad will explore options for collecting this data. / Tim/Mindy 1/14/02

12/05/01 Answers to additional clarification questions, received from Covad:

Answers to the questions are embedded below. Keep in mind that we offer this to the ILECs as an additional testing tool for their use and have not had the opportunity to do any rigorous data gathering and analysis. That might be something we can build in to the trial if Qwest decides to go forward.

- What is the availability time of the IVR? I have assumed 24x7 but have there been unscheduled downtimes over the past 6 months and if so how many and for how long? The system is designed to be on 24X7. It is the same system Covad field techs and Agents use to test orders.

- What are the specific circuit types that are included in their process with Verizon? LX--? etc. It can be used to test any UNE loop... just not line share.

- Has COVAD tracked the success rate for accessing the IVR and completing the tests? If so what is the rate? No data on this.

- Is part of the agreement that if the tests come back positive, COVAD technicians will accept the test results without question and complete the order? No this is just to be used as a tool for the ILEC Tech at this time. It is not a replacement for test and accept.

- Has COVAD measured the actual usage of the IVR tool by Verizon.....what % of the orders that qualify are tested by Verizon utilizing the IVR? It has only been used as a interim test tool not for test and accept so no data on this.

- What % of the orders tested by the IVR and accepted by COVAD have had an "I" report (repair ticket within 30 days of turnup)? No data on this.

- What are the specific test parameters utilized by the IVR for each test run? It is the same parameters that are used by our agents when they test the loop for test and accept.

10:00 am (MDT) / Thursday, November 01, 2001

Clarification Meeting Conference Call 1-877-847-0338 PC7826706 # PC102301-1- IVR Testing

Minda Cutcher, mcutcher@covad.com , Covad Fred Aesquivel III, faesqui@qwest.com, Qwest Michael Belt, mbelt@qwest.com, Qwest

Introduction of Attendees Introduction, Fred, Mike, Minda / T. Meehan and T. Gianes left call per Fred’s request.

Review Requested (Description of) Change Implementation of Covad’s IVR Testing Tool by Qwest for use in the field provisioning and repair process. The Request was reviewed and fully understood.

Confirm Areas & Products Impacted Areas: Field Provisioning and Repair Products: Unbundled Loop/ Stand Alone Loops

Confirm Right Personnel Involved Fred Aesquivel will coordinate SME’s for review and response Michael Belt – Coordinate CR

Identify/Confirm CLEC’s Expectation Covad would like to implement IVR testing with Qwest. The Integrated Voice Response (IVR) unit is an automated, menu-driven tool allowing technicians to run loop tests, loop diagnostics, perform open, short, and quiet tests, and send a tone across the ILEC loop without calling for assistance. IVR is an automated voice response (dial-in) system by which Qwest technicians can perform a one way “pre-test” of a loop prior to formal cooperative (two way) acceptance testing with Covad. IVR takes the Qwest tech through the same process as the two-way test and will feed back results to the Qwest tech. If the loop tests "good", the Qwest tech would then perform the coop test and loop turnover with Covad. If a fault were discovered during the IVR test, the Qwest tech would then have the opportunity to correct the deficiency prior to turnover to Covad. This process has been implemented in another ILEC and Verizon specifically asked for its use to improve their provisioning efficiency as part of its recent recovery efforts in NYC. Eventually, the goal will be to eliminate the need for cooperative testing, saving both Covad and Qwest time and resources, improving operational efficiencies for both.

Identify any Dependent Systems Change Requests N/A

Establish Action Plan (Resolution Time Frame) Fred Aesquivel III to coordinate with Verizon on previous IVR testing from trial done in April/May in Massachusetts regarding loop turnover with Bell Atlantic.

CenturyLink Response

September 5, 2002

Michael Zulevic Covad

SUBJECT: Qwest’s Revised Change Request Response - CR #PC102301-1 Implementation of Covad’s IVR Testing Tool by Qwest

This is in response to Covad’s Change Request (CR) PC102301-1. 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.

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

12-03-2001

Minda Cutcher VP ILEC Relations Covad

CC: Fred Aesquivel Douglas Lange Todd Mead

This letter is in response to your CLEC Change Request Form, PC102301-1 dated 10/23/01 entitled “Implementation of Covad’s (IVR) Testing Tool”.

After having reviewed your request I was also able to interview John Reed with Verizon, a current user of the Covad IVR testing tool. Unfortunately John was unable to provide documented data regarding several critical measures. However, he was very positive in his feedback as a whole and felt that the tool has provided improved efficiencies when completing service orders with Covad.

Thank you for agreeing to respond to these and other questions I have recently submitted to you. The answers will greatly assist us as we move forward. - Percent of usage of the IVR tool for qualified orders? - Specific test parameters of the tool for each test? - Specific circuit types included in the process? - Have there been system access issues…..if so how often etc? - Rate of “I” reports (repair tickets within 30 Days) on IVR tested orders?

Based on some positive feedback from Verizon, the fact that there is no cost to Qwest, and the apparent benefit to all parties of utilizing the IVR tool, I am recommending that Qwest move forward by conducting a trial. The purpose of the trial would be to develop a documented process and to help Qwest & Covad establish data validating the usage and gained efficiencies of the IVR tool. The trial would be conducted in a metro area agreeable to both parties for a minimum period of 2 months beginning no later than January 28th, 2002. The results of the trial and answers to the above questions will determine further action regarding this initial Change Request. If Qwest ultimately decides to accept the new process, it will be with the understanding that Covad, and any other CLEC requesting this process, must provide the IVR, test vehicle, and process and usage documentation at no cost to Qwest.

Sincerely,

Timothy Gianes Senior Project Manager - Qwest Communications