Wholesale: Products & Services

Open Product/Process CR PC110209-1 Detail

Description Of Change

The USOCs associated with these interfaces are:

CPSHP & FGOHP (ESCON - 200 Mbps – Protected)

CPSHW & FGOHW (ESCON - 200 Mbps -Unprotected)

CPSKW & FGOKW (ETR - 16 Mbps - Unprotected)

CPSDP & FGODP (FDDI - 125 Mbps – Protected)

CPSDW & FGODW (FDDI - 125 Mbps - Unprotected)

CPSJP & FGOJP (ISC - 1.06 Gbps - Protected)

CPSJW & FGOJW ( ISC - 1.06 Gbps - Unprotected)

CPSMP & FGOMP (Fibre Channel - 266 Mbps - Protected)

CPSMW & FGOMW (Fibre Channel - 266 Mbps - Unprotected)

CPSBP & FGOBP ( Fibre Channel - 133 Mbps - Protected),

CPSBW & FGOBW ( Fibre Channel – 133 Mbps – Unprotected)

CPSNP & FGONP (Fibre Channel – 531 Mbps – Protected)

CPSNW & FGONW (Fibre Channel – 531 Mbps – Unprotected)

CPSQP & FGOQP (D1 Video - 270 Mbps - Protected )

DM2XS &DM2XW (Shelf)

CPSQW & FGOQW (D1 Video - 270 Mbps - Unprotected)

There are currently no wholesale customers with these USOCs.

Expected Deliverables/Proposed Implementation Date (if applicable):

The proposed implementation date is 12/16 /09

Project Meetings

12/16/09 Product/Process CMP Meeting Mark Coyne-Qwest said the level 2 final notice announced on 12/9/09 and will become effective on 12/16/09.

11/18/09 Product/Process CMP Meeting Cindy Schwartze-Qwest said Qwest plans to restructure GeoMax service. As part of the restructure, Qwest will no longer offer the following interfaces: ESCON, ETR, FDDI, and ISC, Fibre Channel – 133, 266, 531 Mbps, D1 Video and the Additional Shelf element.

The USOCs associated with these interfaces can be located in the CR description at: http://www.qwest.com/wholesale/cmp/cr/CLECQwestCMPProductProcessInteractiveReport.html

There are currently no wholesale/resale customers with these USOCs and the proposed implementation date is 12/16 /09.

Julia Redman-Carter-PAETEC asked if this is the GeoMax product that is part of the broadband forbearance.

Cindy Schwartze-Qwest said it is.

Julia Redman-Carter-PAETEC asked that (11/30/09 – Comments to minutes received from PAETEC in BOLD) NOTING the products listed in Attachment A of QWEST’S the petition that existed at that time if the changes TO THE GEOMAX are significantly restructured, is it still Qwest’s position that this GEOMAX PRODUCT is STILL a part of forbearance even with the changes.

Cindy Schwartze-Qwest said that we would take an action item to work with the Product Manager to answer that question.

Bonnie Johnson-Integra asked if any of these products were in the ICA.

Cindy Schwartze-Qwest said GeoMax is a resold product and is under Section 6.0 of the ICA. She said the interface will be replaced with another interface.

Bonnie Johnson-Integra said if it is part of the ICA, a change in law is required.

Cindy Schwartze-Qwest said it’s not specific to GeoMax in the ICA and would go under all other services and falls under the PLT category.

Julia Redman-Carter-PAETEC said (11/30/09 – Comments to minutes received from PAETEC in BOLD) SHE THOUGHT the template mentioned GeoMax and references the terms of the exiting activity under forbearance. Julia said if GEOMAX is no longer COVERED under forbearance, it would need to go through a different process. Cindy Schwartze-Qwest said she will review the template and provide a response in the minutes.

Susan Lorence-Qwest said that once the questions are answered Qwest would like to propose a level 2 notification because there are no Wholesale customers and asked if everyone was agreeable.

Julia Redman-Carter-PAETEC said she needs to understand if this product (11/30/09 – Comments to minutes received from PAETEC in BOLD) WITH THE CHANGES, still falls under forbearance.

Bonnie Johnson-Integra said Integra won’t agree until she gets an answer to their question regarding ICAs.

Barb Fanning-Qwest joined the call.

Julia Redman-Carter-PAETEC said GeoMax is part of forbearance and with these changes that appear to be significant, is wondering if they are significant enough and at what point do they no longer qualify as the products that were granted with the broadband forbearance.

Barb Fanning-Qwest said GeoMax is a product that you can order the interface, i.e. Sonnet, and there are options for the customer. She said we are removing those with no demand and in some cases with the shelf we are using a different technology and helping the customer. Barb said this is for large bandwidth and for large customers that order, for example, OC192.

Julia Redman-Carter-PAETEC said she needs to understand the (11/30/09 – Comments to minutes received from PAETEC in BOLD) CHANGES IN access where they are coming in and who they go to.

Julia Redman-Carter-PAETEC asked for clarification that with the changes Qwest is making, they are not changing the product.

Barb Fanning-Qwest said we are not changing the product, only the interfaces.

Julia Redman-Carter-PAETEC said Attachment A (11/30/09 – Comments to minutes received from PAETEC in BOLD) OF QWEST’S PETITION is very specific. Julia said the commission said that only those services outlined that existED AS OF QWEST’S PETITION would qualifY FOR FORBEARANCE. I AM TRYING TO UNDERSTAND IF GEOMAX with these changes change the parameters OF GEO MAX from which the forbearance has been granted.

Barb Fanning-Qwest said the changes don’t change parameters granted on forbearance.

Bonnie Johnson-Integra said their concern is that if any of the services are offered in the ICA, Qwest can’t remove without a change in law.

Cindy Schwartze-Qwest said that she checked in the ICA, Exhibit A, and they do not reside there. She said the only place we would have identified GeoMax is under PLT and it’s not spelled out. She said we would consider it an intrastate resold GeoMax and these USOCs/ interface are not in the ICA.

Bonnie Johnson-Integra said that Integra and Qwest don’t always agree on what’s in the ICA. She said if this is the case Integra would object and disagree on what’s in the ICA and if Qwest is removing something there needs to be a change in law.

Cindy Schwartze-Qwest said there are no wholesale/resale customers with GeoMax. Cindy said this is in the RSS 1 and AZ, MN and NE State tariffs. She said this is only sold under section 6 of the ICA and we don’t get that specific because everything is out of the tariff.

Bonnie Johnson-Integra said it is retail product.

Cindy Schwartze-Qwest said we come to CMP when retail chooses to grandfather or remove a product or service.

(11/30/09 - Comments to minutes received from Integra in BOLD) BONNIE JOHNSON-INTEGRA SAID YES AND THERE IS NOT A CHANGE TO WHERE THE PRODUCT IS LOCATED.

Julia Redman-Carter-PAETEC asked if GeoMax is under the detariffed tariff.

Julia Redman-Carter-PAETEC asked if (11/30/09 – Comments to minutes received from PAETEC in BOLD) THE CHANGES TO GEOMAX would be consistent in all detariffed tariffs APPLICABLE TO ALL STATES.. Julia said that all states defineD AND APPLIED forbearance ORDER and she thought QWEST was being removING GEOMAX from AZ, MN NE state tariffs and changing the product itself.

Barb Fanning-Qwest said GeoMax exists today in the interstate AZ, MN, NE and we aren’t changing the GeoMax product. We are only changing the interface. i.e. the shelf is new technology and not changing the service.

Susan Lorence-Qwest said that Qwest is only grandfathering by eliminating and syncing up with the tariff. Susan said in order to match the tariff dates and since there are no customers, Qwest would like to submit a level 2 notice. Susan said we are eliminating those interfaces no longer available and not ordered by Wholesale customers

Julia Redman-Carter-PAETEC said as (11/30/09 – Comments to minutes received from PAETEC in BOLD) long as QWEST IS only grandfathering, i.e. the shelf for new technology, AND THERE ARE NO CUSTOMERS CURRENTLY USING THE GRANDFATHERED SHELF, PAETEC doesn’t have a problem with the change.THIS MEANS THAT THE GRANDFATHERED CHANGES DON’T CHANGE THE PRODUCT IN LIGHT OF QWEST’S PETITION ATTACHMENT A TO WHICH THE QWEST FORBEARANCE ORDER APPLIES. Julia said if the change is doing more than that, (i.e. changing the product) she would have a problem with this change AND PAETEC WOULD OBJECT..

Barb Fanning-Qwest said that all we are doing is going with a new technology and THIS is why are getting rid of the shelf.

Susan Lorence-Qwest asked if everyone was comfortable with the level 2 notice

Bonnie Johnson-Integra said she would like to review internally and will send a response back to Qwest.

Mark Coyne-Qwest said that the sooner we receive Integra’s response the better to meet the implementation date. Mark said based on Integra’s response, we can agree on the level 2 notice.

Bonnie Johnson-Integra said that would be her hope.

11/19/09 Response received from Bonnie Johnson/Integra: I checked a couple of ICAs and was not able to find the term GeoMax in the few ICAs I checked. However, as is often the case, Qwest’s product name is not mentioned but there may be provisions in the ICA described as something else or a change could impact a different provision that may connect to GeoMax. Qwest said they checked ICAs and this change does not impact any ICA, however, Qwest has said that before (expedites for example) and we don’t agree with Qwest.

I know Qwest wants to move forward with this change and I do not have the bandwidth right now to dig deeper. Integra does not object to Qwest implementing this as a level two changed, based on Qwest’s comments that no CLECs ICA is impacted with this change and, there are no customers with these USOCs. If in the future Integra determines that is not the case, Integra will take the appropriate action. .