Wholesale: Products & Services

Open Product/Process CR PC112003-1 Detail

Description Of Change

Project Meetings

Date: 6/1/04 7:55 a.m. To: 'tom.hyde@cbeyond.net', 'stephan.calhoun@cbeyond.net' From: Sanchez Steinke, Linda Subject: FW: CMP CR PC112003-1

Tom & Stephan -

As a follow up to the e-mail message attached, I will be closing change request PC112003-1 on Thurdsay 6/3/04. If you have any questions, please respond back to me before 6/3/04.

Thank you

Linda Sanchez-Steinke CRPM Qwest 303-382-5768

--Original Message-- From: Sanchez Steinke, Linda Sent: Thursday, May 20, 2004 8:03 AM To: 'Stephan.Calhoun@cbeyond.net'; 'tom.hyde@cbeyond.net' Subject: CMP CR PC112003-1

Stephan & Tom -

As a follow up to yesterday's CMP meeting, we discussed closing this CR. The CLEC community suggested that I e-mail and find out if Cbeyond agrees to close. Please let me know.

Thank you

Linda Sanchez-Steinke CRPM Qwest 303-382-5768

Date: 5/20/04 8:03 a.m. From; Sanchez Steinke, Linda To; 'Stephan.Calhoun@cbeyond.net'; 'tom.hyde@cbeyond.net' Subject: CMP CR PC112003-1

Stephan & Tom -

As a follow up to yesterday's CMP meeting, we discussed closing this CR. The CLEC community suggested that I e-mail and find out if Cbeyond agrees to close. Please let me know.

Thank you

Linda Sanchez-Steinke CRPM Qwest 303-382-5768

05/19/04 May CMP Meeting Pat Finley with Qwest reported during the April meeting Stephan Calhoun with Cbeyond said that a USOC appeared on EEL and LMC bills that had a UNE-P definition. This USOC is shared between UNE-P, EEL and LMC. Service Delivery has requested that this description be corrected. Pat said that the USOC will have a new description. Liz Balvin with MCI asked if notification would be provided. Susan Lorence with Qwest said there usually is no notification. Bonnie Johnson with Eschelon said the billing folks would need to know. Susan said if there is a product change or product name change, then there could be PCAT changes. Liz asked if the USOC would continue to say NRC for UNE-C. Pat said that the USOC will remain the same, but the description will be more generic. Susie Bliss with Qwest asked Liz if her question was, is something going to look different on the bill. Liz agreed. Bonnie said that people who are processing bills will see one thing one month and another the next. Susie asked Sami Hooper if the bill phrase is going to change. Sami Hooper with Qwest said that the USOC FID finder is generic and that the central CRIS bill singled out UNE-P. Bonnie and Liz both said that Qwest may receive questions for that change in the definition of the USOC and would be good to get a notice. Susan Lorence asked if Bonnie and Liz were concerned the billing reps would need to be provided information so they know that this is the reason for the change. (Bonnie’s comment insert here) Susie Bliss said that Qwest billing SDCs could notify the CLECs of changes of this nature. Do we have an action item open for this issue? (end Bonnie’s comment) Linda Sanchez-Steinke with Qwest will e-mail Cbeyond for approval to close this CR.

04/21/04 April CMP Meeting Pat Finley with Qwest said that during last month’s meeting some items discussed need to be corrected. Qwest has developed the TRAK FID, which uniquely identifies EEL & LMC. PCAT changes identify the USOCs used for LMC and EEL. Last month Liz Balvin with MCI had asked if monthly training could be provided to the center. In speaking with the process specialist, training is provided on an as needed basis when we identify a problem, and won’t be done on a monthly basis. Also last month, Bonnie Johnson with Eschelon had asked if a review was done on all customer’s bills, and that was not the case. Specific questions Cbeyond had on their billing, when their circuits were converted to EEL and LMC were researched.

Bonnie Johnson with Eschelon asked why, if there is a known problem, and if there was not a review of all CLEC accounts, that the expectation is the CLECs prove there is a problem. Pat Finley responded there is not a widespread problem and Cbeyond had given specific instances where EEL and LMC conversion orders were issued. Bonnie asked if service management could notify their customers, that Qwest should do notification. Bonnie asked if other customers had these conversions done. Pat said that if any company has problems they could contact their service manager for resolution. Bonnie said that since a problem has been uncovered that you may want to get with service managers, who could contact their customers. Kit Thomte with Qwest said that Linda Sanchez-Steinke will contact the directors over the service management team to make them aware.

Stephan Calhoun with Cbeyond joined the call and said that as Cbeyond was investigating, they found that circuit IDs with inconsistencies. They found circuit IDs that have no relationship to what Qwest provisioned and the circuit ID has been changed to fit with EEL or LMC. Further, Cbeyond is concerned that the circuit ID has no connection to what is in the provisioning system and asked how do Eschelon or other CLECs know that their circuit IDs are correct. Pat Finley said that the Cbeyond issue was corrected. Stephan said he is suspicious and concerned that this could happen elsewhere and the circuit ID has been altered and is out of sync with billing and provisioning. Stephen added he is unsure how to protect Cbeyond. Pat said that she did not know of other instances where this was occurring and that the problem was isolated to one or two individuals in the center who were then covered on the correct procedures.

Stephan said reconciling the invoice, knowing that potential is there not to reflect the correct circuit IDs, and there is not a dedicated rep for the Cbeyond orders. Pat said there is not a way to compare the provisioning system against the billing system because they are separate operating systems and would be glad to work on specific examples. Stephan said that the examples of the circuit ID not matching the FOC and SOC were given to their Service Manager.

Stephen asked if the TRAK FID was as far as Qwest would go to resolve this CR. Pat answered that separate classes of service would not be provided and the PCAT changes identifying the USOCs used for LMC and EEL and the TRAK FID were done to address the CR.

Stephan asked if certain USOCs descriptions would be included in the billing because they are seeing inconsistencies. On EEL orders they see UNE-P USOCs. Pat said that some USOCs used may be private line and borrow many USOCs. Stephan said he sent the examples but these may have gone only to the service manager. Kit said we would get with the service manager to investigate.

Jen Arnold with U S Link said the man number on the circuit ID changes and they are finding, particularly in a re-use situations, the man number may be the same for more than one circuit ID. This was brought to service management and has not been answered yet. Kit said there was no one on the call to answer the question and said they should wait to hear from service management.

Bonnie Johnson said she is generally frustrated whenever there is an issue or problem that the CLEC must submit a CR, ask for documentation, etc. and would like to see Qwest take a more active role is resolving issues. Qwest has an obligation to let CLECs know when something has been found through the discovery process, or through researching a CR, and should get the problem fixed for all CLECs. Donna Osborne-Miller said this seems to be a reasonable request and Qwest should notify the CLECs. Bonnie said we can discuss off line where to go to get Qwest to take a more active approach. This CR will move to CLEC Test status.

03/17/04 March CMP Meeting Pat Finley with Qwest said that an ad hoc meeting was held on 3/5/04 to address concerns raised by Stephan Calhoun with Cbeyond. Tom Hyde with Cbeyond attended the call for Stephan. Pat reviewed that the CR was submitted asking for separate classes of service for EELs and LMCs. Pat explained that the TRAK FID uniquely identifies EEL & LMC. Cbeyond had 14 instances where the conversion of circuits from private line was done incorrectly and orders were issued to correct the circuit IDs. Pat said Interstate classes of service are not being assigned on new installations of service and the interstate classes of service were used for the conversion of private line. Qwest has no plans to charge higher rates for interstate vs. intrastate and UNE’s are billed at TELRIC rates. PCAT changes were issued in February to provide a download to map USOCs and class of service. During the ad hoc meeting, Tom said he had not reviewed the changes. Liz Balvin with MCI asked if training would be reinforced to eliminate errors from occurring. Pat said that training has been provided to the center to make sure the correct processes are followed. Liz added that monthly training might be helpful because of turnover in representatives inputting the orders. Pat said that she would suggest monthly training to the process person. Bonnie Johnson with Eschelon said that if Cbeyond had problems with inaccuracies in circuit IDs that there may have been other CLECs with the same problem and asked if a review was done. Pat said that a report was pulled for all customers. Bonnie asked if corrections and credits had been done. Pat said corrections and credits were given if appropriate. This CR will move to Development status.

- Ad Hoc Meeting Minutes PC112003-1 March 5, 2004 1-877-572-8687, Conference ID 3393947# 9:00 a.m. - 10:00 a.m. Mountain Time

List of Attendees: Tom Hyde - Cbeyond Kathy Stichter - Eschelon Kim Isaacs - Eschelon Rodney Johnson - SBC Pat Finley - Qwest Robyn Libadia - Qwest Gayla Samarripa - Qwest Sami Hooper - Qwest Jennifer Fisher - Qwest Susie Johnson - Qwest Sue Kriebel - Qwest Peggy Esquibel-Reed - Qwest Lynn Stecklein - Qwest Linda Sanchez-Steinke - Qwest

The meeting began with Qwest making introductions and welcoming all attendees. Linda Sanchez-Steinke with Qwest explained that the purpose of the meeting was to discuss CR PC112003-1 agenda topics: - Qwest will not establish separate Class of Service for EEL & LMC - Qwest assigning interstate Classes of Service on new EEL/LMC requests - Determine if EEL/LMC services established as new connect or conversion - Jurisdiction of EEL/LMC - EEL/LMC XUMAX Interstate, UBNWN Intrastate Rates - PCAT updates

The following is the write-up of the discussions and action items from the working session.

- Qwest will not establish separate Class of Service for EEL & LMC. Pat Finley with Qwest explained that separate classes of service will not be provided for EEL and LMC. Qwest has developed the TRAK FID on the CSR which identifies EELs and LMC circuits. Pat added that Qwest will not count LMCs in the calculation of LIS trunking to EEL ratio.

- Qwest assigning interstate Classes of Service on new EEL/LMC requests. Pat Finley said that Qwest did have a deviation from the process and orders for the conversion were issued with Interstate classes of service. Additional training has been provided to the center and the center is in the process or writing orders to correct. Tom Hyde with Cbeyond said that he is concerned that UNE billing deviates from Telcordia standards with respect to USOCs. Pat said the EEL and LMC PCATs have been updated to include a download of USOCs for interstate and intrastate. Tom said that he has not reviewed the PCAT. Sami Hooper with Qwest said that the Chan Term is the same as special access but has a unique class of service and ZCID. Tom Hyde said that the rate is driven by the ZCID. Sami said that the rate is driven by class of service, USOC and the company code or ZSID makes the rate unique. Tom said he is concerned that class of service is irrelevant to billing of basic Chan Term which is a finished service. Pat said that the company code makes rating unique and several UNEs borrow retail USOCs. The interconnection agreement provides rates. Tom said he was concerned that the PCAT will be ambiguous, an audit of billing will provide different information and the only method to audit is a manual method. The interoffice mileage and fixed charges are charged incorrectly. Pat said the USOC definitions will be the same and this is not unique to LMC and EEL. The rating is done per the interconnection agreement. Susie Johnson said that Gia is correcting the incorrectly billed multiple fixed mileage charges.

- Determine if EEL/LMC services established as new connect or conversion. Tom said that Qwest has asked him to identify which were new connect circuits and which were converted circuits and that everything was being assigned Interstate. Pat said that Qwest knows how the services were established, either new connect or conversion.

- Jurisdiction of EEL/LMC. Pat Finley said that 14 circuits have the incorrect circuit ID and are being corrected via record orders.

- EEL/LMC XUMAX Interstate, UBNWN Intrastate Rates. Pat Finley said that Qwest has no plans to charge a higher rate for interstate vs. intrastate and UNE’s are billed at TELRIC. Tom Hyde said he doesn’t care for CRIS billing for UNE-P, that it was probably ok a couple years ago and is causing grief because of the lack of consistency and manual work involved to audit bills. CRIS billing is not part of CMP CR PC112003-1 and was not discussed further.

- PCAT updates. Pat Finley said the PCAT was updated and provides a download to map USOCs and class of service. Tom said he has not reviewed the changes made to the PCAT. Pat said that the combination of USOCs are unique. Sami said that is correct and the PCAT identifies the nonrecurring USOCs and the FID identifies if EEL or LMC. LMC has no mileage. Tom said that the bill will subtract LMC mileage and it was billed in error, identified in manual audit. Pat said that if orders are issued correctly the ZCID, etc. drives billing. Pat explained that establishing a new unique classes of service for LMC is cost prohibitive due to the conversion required to the embedded base. Tom said that a new USOC can’t be cost prohibitive. Tom added that the circuit ID is being corrected and has helped.

There were no additional questions and Linda said that meeting minutes would be provided in the body of the change request.

02/18/04 February CMP Meeting Pat Finley with Qwest said the examples Cbeyond provided following the January meeting were examples of circuits with jurisdiction based on the class of service. There were hundreds of circuits converted correctly via record orders and the 10 circuits provided as examples were issued incorrectly, and required record orders to fix. Pat explained that the PCATs for EEL and LMC were updated and now contains a downloadable list of USOCs for interstate and intrastate. The USOC list, combined with the TRAK FID on the CSR differentiates LMC and EEL and there is no need to establish separate classes of service. The work associated with establishing separate classes of service is prohibitive because of the conversion to the embedded base.

Pat said that the e-mail received from Stephan Calhoun on 1/22/04, confuses the request with other CRs requesting billing changes and believe that this CR can be closed.

Stephan Calhoun with Cbeyond said the PCAT updates are appreciated and that he was only able to review the Qwest response on this CR yesterday. Stephan said he has concerns with the 2/3/04 Qwest response and asked that Pat read through the response.

Pat read the draft response. Stephan said that his understanding is that usually classes of service define the product but not the jurisdiction. Pat disagreed saying that the jurisdiction of many Qwest products is identified by class of service.

Stephan also said that interstate class of service was assigned to conversion orders that were issued last year, are also being assigned on new requests for EEL and LMCE. Pat said that the interstate EEL and LMC classes of service are only used to convert to Special Access circuits.

Stephan said that he doesn’t understand the reason UMX was changed to new EEL and LMC. Cbeyond has not made any changes in the way the services were ordered. Pat Finley said that interstate was only used for conversion orders only.

Stephan said that Cbeyond is concerned that billing doesn’t support the Qwest response. The billing department was not able to identify what was converted and what was a new order. There seems to be a disconnect with the policy and what is actually done. Pat explained that the Billing Center is able to access history information on the services, and to tell what is new and what was converted. Stephen said that the billing manager, service manager and process manager were unable to determine and planned to contact the product manager. Stephan has provided examples to their service manager.

Stephan is also concerned that the recurring interstate and intrastate EEL do not bill the same as UNE. Pat said that PLT has different rates and is a finished service. Interstate and intrastate EEL and LMC are billed the same recurring rates. Stephan said LMC jurisdiction is based on FCC definition and doesn’t seem to fit. Stephan said the concern is not the rate itself, but the rate elements, and asked what would keep Qwest from applying different rates to interstate and intrastate. Pat asked if the concern is that Qwest may raise UNE rates that are interstate. Pat explained that Qwest is obligated to make these UNEs available to CLECs at TELRIC rates.

Judy Schultz with Qwest said there are many concerns with this CR and suggested that an ad hoc meeting be scheduled to discuss. This CR will remain in Evaluation status.

Thu 1/22/04 3:41 PM From; Stephan Calhoun [Stephan.Calhoun@cbeyond.net] To: Sanchez Steinke, Linda, Finley, Pat J cc; Morgan Halliday, Tom Hyde Subject; RE: Qwest Draft Response PC112003-1 (Differentiate LMC from EEL) - Cbeyond Response Linda/Pat,

I apologize for not getting this to you prior to yesterday's call. I got wrapped up in some other Qwest CRs that we received responses to at the same time. It appears that Qwest has addressed the regulatory concerns raised by the TRO in its response to this CR. Unfortunately, the billing implications on this CR appear to have been forgotten. Cbeyond has 3 specific concerns to Qwest's response:

1. Providing fields on the CSR for services that are billed in CRIS is not the same as for services billed in IABS. In the CRIS system, the CSR is not part of the bill. The CSR is provided as a separate file that is not in the same format as the invoice and is also not an OBF/industry standard format. Even this is a bit of a misnomer, the CSR is actually a collection of files per subaccount on an invoice. If an invoice has 2,000, the CSR is actually comprised of 2,000+ files. This is a partial explanation of why Cbeyond considers the delivery of information on the CSR as insufficient in addressing the billing concern of this CR.

2. Qwest has demonstrated through reports from the billing group (because Qwest doesn't actually put the class of service on the bill), that it uses or appears to use 2 different classes of service and thus 2 different sets of USOCs for the same bandwidth level, product, and jurisdiction as it applies to EELs and LMCs. Please find the attached examples.

3. An even broader concern, and perhaps the subject of another CR, is that Qwest has failed to map the USOCs & Classes of Service that it bills for LMCs & EELs to a product. Conversely, the PCATs for LMCs and EELs do not define the classes of service or USOCs to be applied to the elements that define each product. Obviously, Qwest has this defined somewhere in their system, but has failed to publish it to the CLEC community.

Again, I apologize if my comments caught you off guard as that was truly not my intent. I only saw the Qwest response the morning of the call and grew very concerned about what the response did not address.

Sincerely, Stephan

01/21/04 January CMP Meeting Pat Finley with Qwest said that Qwest held the Clarification meeting on 12/4/03 and that Qwest had sent an e-mail to Morgan Halliday stating that Qwest does not count EELs in the LMC ratio to LIS trunking. Pat reviewed the Qwest response and said that we will not establish unique classes of service for EELs and LMCs and that Qwest has created a way to distinguish EEL and LMC for the TRO by using TRAK FID. The TRAK FID information is available for CLECs on the CSR. Pat said that Qwest needed to distinguish between EELs and LMCs and has no intention of counting LMCs in the LIS trunking ratio.

Stephen Calhoun with Cbeyond said he is confused by the response because in December he received one answer and then in January received another answer. The CSR is not part of the bill and is not populating the difference between EEL and LMC on the bill. It is a different process to view the CSR as opposed to looking at the bill. The Cbeyond concern is based on reports received from the billing team where LMCs and EELs have different classes of service and USOCs. LMCS or EELs could be either class of service. Stephen will provide examples.

Pat Finley said there are 12 classes of service and they vary according to whether service is intrastate or interstate and the bandwidth requested. Stephen said these are brand new DS1 level, local installs and they have different classes of service assigned. In addition, when reviewing the PCAT there is a lack of documentation because LMC and EEL have no USOC mapping available to see the classes of service. Bonnie Johnson said that in reconciling bills, Qwest provides data is in so many different places, and there is a general concern that bills don’t provide enough detail to reconcile. (Begin comment from Bonnie Johnson – Eschelon) Bonnie said all of her personnel vendor bills contain the detail you need to know what you are paying for. (end comment). Carla Pardee with AT&T and Liz Balvin with MCI said they agree with Bonnie’s comments. This CR will move to Evaluation status.

Mon 1/5/04 1:12 PM From; Linda Sanchez-Steinke To; 'tom.hyde@cbeyond.net' cc: Pat Finley Subject; Change Request PC112003-1

Tom -

The attached e-mail was sent to Morgan Halliday a couple of weeks ago regarding change request PC112003-1, titled "Differentiate between Loop-MUX combos and EELs due to different FCC treatment (TRO Order)". I realize that with the holidays Cbeyond may not have had an opportunity to respond.

Would you please let me know if Pat Finley's attached e-mail provides the information needed to resolve the change request or if the change request is still needed.

Thank you

Linda Sanchez-Steinke Change Request Project Manager Qwest 303-382-5768

--Original Message-- From: Finley, Pat J Sent: Tuesday, December 16, 2003 4:43 PM To: 'morgan.halliday@cbeyond.net' Cc: Sanchez Steinke, Linda; Libadia, Robyn; Romano, Anthony Subject: Qwest's response to PC112003

Mr. Halliday, I wanted to provide you a formal response to the primary concerns you raised on the clarification call we had on December 4, 2003, for the Change Request titled "Differentiate between Loop-MUX combos and EELs due to different FCC treatment (TRO Order)." You asked that Qwest provide you in writing, assurances that we will not count Loop-MUX combinations (LMCs) in the calculation of LIS trunking to EEL ratio, to determine service eligibility. Please consider this written confirmation, that Qwest has no intention of counting LMCs in the calculation of the LIS trunking to EEL ratio as specified in the service eligibility criteria of the Triennial Review Order. We hope this satisfies your request. Please contact me at 303 896-8466, if you have any questions.

12/17/03 December CMP Meeting Cbeyond presented this CR and said Cbeyond would like to be able to differentiate LMX and EELs class of service on billing invoices. Liz Balvin with MCI asked how they come on the bills today. Stephen Calhoun said that Qwest provides Cbeyond additional information on a spreadsheet to help differentiate, and Qwest does not have the ability to separate LMX and EEL class of service. Jamal Boudhaouia with Qwest asked if Cbeyond orders LMX by itself, or if it is part of the whole circuit being provisioned. Stephen Calhoun said there are definite differences and if look at two DS1’s there is no differentiation between LMX and EEL and there are many implications, TRO order, Performance Management Plan, Regulatory side and billing. Jamal asked if the CR is based on the TRO order and if Cbeyond is asking for differentiation between the classes of service because of TRO implications. Judy Schultz with Qwest said that we may need another clarification meeting to get clear what the CR is requesting. Bonnie Johnson with Eschelon said that she was at the clarification meeting and felt that the CR request was clear. Kit Thomte said that Pat Finley the SME was not on the call and Kit felt that the discussion wasn’t helpful if she was not involved in the discussion. This CR will move to Presented status.

Tue 12/16/03 4:43 PM From; Pat Finley To; 'morgan.halliday@cbeyond.net' cc: Sanchez Steinke, Linda; Libadia, Robyn; Romano, Anthony Subject; Qwest's response to PC112003 Mr. Halliday, I wanted to provide you a formal response to the primary concerns you raised on the clarification call we had on December 4, 2003, for the Change Request titled "Differentiate between Loop-MUX combos and EELs due to different FCC treatment (TRO Order)." You asked that Qwest provide you in writing, assurances that we will not count Loop-MUX combinations (LMCs) in the calculation of LIS trunking to EEL ratio, to determine service eligibility. Please consider this written confirmation, that Qwest has no intention of counting LMCs in the calculation of the LIS trunking to EEL ratio as specified in the service eligibility criteria of the Triennial Review Order. We hope this satisfies your request. Please contact me at 303 896-8466, if you have any questions.

CLEC Change Request Clarification Meeting

2:00 p.m. (MDT) / Thursday December 4, 2003

1-877-572-8687 3393947# PC112003-1 Differentiate between Loop-MUX combos and EELs due to different FCC treatment (TRO Order)

Name/Company: Morgan Halliday, Cbeyond Tom Hyde, Cbeyond Stephen Calhoun, Cbeyond Kim Isaccs, Eschelon Bonnie Johnson, Eschelon Pat Finley, Qwest Carl Sear, Qwest Tony Romano, Qwest Paul Johnson, Qwest

Introduction of Attendees Qwest welcomed all attendees to the meeting.

Review Requested (Description of) Change Linda Sanchez-Steinke with Qwest read the description of change from the submitted change request; Seperately identify LMCs and EELs on bills. Tom Hyde with Cbeyond said that the primary part of the TRO is the ratio of, or test for EELs (high cap) to LIS trunking with the new service eligibility criteria. Since Qwest uses the same classes of services and USOCs for EELs and LMCs as are used for PLTS. Pat Finley with Qwest clarified that the TRO ratio is the number of interconnection trunks to EELs, however LMCs (Loop Mux Combinations) are excluded from the ratio requirement. Tom answered that Cbeyond would be satisfied if Qwest will acknowledge in writing that LMC is to be excluded from the service eligibility criteria (safe harbor), and therefore would be excluded from the LIS trunking to EEL ratio, that would satisfy Cbeyond’s concern.

In the CPAP Qwest is lumping EELs and LMCs together. Tom said that Qwest is the only ILEC that has EELs and LMCs under the same class of service.

Confirm Areas & Products Impacted Loop Mux Combo and EEL billing

Confirm Right Personnel Involved Correct Qwest personnel were involved in the clarification meeting

Identify/Confirm CLEC’s Expectation Extablish different class of service for LMCs and EELs

Identify any Dependent Systems Change Requests None identified.

Establish Action Plan (Resolution Time Frame) Cbeyond will present this CR at the December CMP meeting. Qwest will provide a response in January 2004.

CenturyLink Response

DRAFT RESPONSE For Review by the CLEC Community and Discussion at the February 2004 CMP Meeting

Morgan Halliday Cbeyond Communications, LLC

SUBJECT: Qwest’s Change Request Draft Response - PC112003-1 "Differentiate between Loop-MUX combos and EELs due to different FCC treatment (TRO Order)"

This letter is in response to the CLEC Change Request PC112003-1, that requests LMC (Loop Mux Combination) be assigned a unique class of service, to separately identify LMC from EEL (Enhanced Extended Loop) due to requirements in the Triennial Review Order (the Order). Qwest will not establish a separate class of service for LMC. Qwest will provide a link to a downloadable document in both the EEL and LMC PCATs that will identify USOCs that are utilized with XUMAX and UBNWN classes of service. This action will enable our customers to map EEL/LMC classes of service to USOCs for billing. The estimated costs to establish a separate class of service for LMC and convert the embedded base are considerable. Establishing a separate LMC class of service will not solve all of the billing issues Cbeyond has raised in subsequent meetings on this Change Request.

In the email Mr. Calhoun sent to Qwest dated 1-22-2004, he listed examples of EEL and LMC circuits that have two different classes of service (interstate and intrastate) with two different sets of USOCs for the same bandwidth, product and jurisdiction. When Cbeyond’s PLT (Private Line Transport) circuits were converted to either EEL or LMC, the jurisdiction, circuit id, and billing USOCs remained the same as when billed and provisioned as PLT circuits. To prevent service interruptions during the conversion, the class of service on the PLT record is converted to the EEL/LMC equivalent. There is no difference in recurring billing between the inter- and intrastate EEL/LMC classes of service and USOCs. The use of both retail and EEL/LMC product specific USOCs is explained in detail in the LMC and EEL PCATs.

In addition to the downloadable spreadsheet we will make available in the PCATs, we have established the TRAK FID and datasets that allow you and Qwest to differentiate between LMC and EEL. With this differentiation, Qwest will not include LMC circuits in your LIS to EEL ratio requirements per the Order service eligibility requirements. We believe these actions will address your specific concerns with billing associated with EEL and LMC. Your other pending change requests will help resolve the other issues you have raised with Qwest’s bills.

Sincerely,

Pat Finley Product Manager

January 13, 2004

DRAFT RESPONSE For Review by the CLEC Community and Discussion at the January 2004 CMP Meeting

Morgan Halliday Cbeyond Communications, LLC

SUBJECT: Qwest’s Change Request Response - PC112003-1 "Differentiate between Loop-MUX combos and EELs due to different FCC treatment (TRO Order)"

This letter is in response to the CLEC Change Request PC 112003-1, that requests EELs (Enhanced Extended Loops) and LMCs (Loop Mux Combinations) be assigned unique classes of service, to separately identify the services due to requirements of the Triennial Review Order (the Order). Qwest has researched this issue, and we will not be establishing separate classes of service and USOCs (Universal Service Order Codes) for EELs and LMCs. We have however, provided a method for you to validate, or identify EEL from LMC circuits, by using a FID (Field Identifier) called TRAK, which is a tracking code. If the circuit is an EEL, the dataset, or entry following TRAK FID on the CSR (Customer Service Record) will be IEEL. This entry will be shown following the class of service on the CSR. LMC circuits will be identified by the dataset ILMC after the TRAK FID. This information has been added to all EEL and LMC accounts in our embedded base, and it is a required service order entry on new EEL and LMC requests. We are able to produce reports that display the information, and we are working on producing reports from our order processing system to ensure the entries are appropriately made, when required. We are confident that this will allow us to validate the 24-to-1 EEL to interconnection trunk ratio specified in the Order (paragraph 608). Please recall that the Order provides for tests based on the service eligibility criteria conducted by an independent auditor to insure that high capacity combinations such as DS1 and DS3 EELs are used for local voice service. As noted in the Order, if Qwest requests an audit, the independent auditor will evaluate compliance with the service eligibility criteria. The compliance testing will be designed by the independent auditor, and Qwest will provide all documentation requested to satisfy standard auditing principles. The independent auditor will perform an "examination engagement", and issue an opinion regarding Qwest’s and the CLECs compliance with the service eligibility criteria (paragraph 626).

Sincerely,

Patricia J. Finley Product Manager Qwest Communications, Inc.