Wholesale: Products & Services

Open Product/Process CR PC112807-2 Detail

Description Of Change

This proposed change in process was originally submitted on November 5, 2007 as a Level 3 notification PROS.11.05.07.F.05018.Location_Routing_Number. A customer comment was received to change the disposition of this notice to a level 4. Per CMP requirements, this change to disposition request was discussed at the November 2007 CMP monthly meeting and a subsequent ad hoc meeting on November 27, 2007. It was agreed in the subsequent ad hoc meeting that Qwest would retract the level 3 notice and reissue this change in process as a level 4.

Project Meetings

March 19, 2008 Product/Process CMP Meeting Mark Coyne-Qwest stated that the effective date of this request was 2/28/08. He said that this CR will remain in CLEC Test for another month. Bonnie Johnson-Integra stated that she was not sure if this was CMP related or not but they have had discussions with their Service Manager about the change from 7 to 10 digits that was part of this request. She said that (Comments to minutes received from Integra 3/27/08) Integra’s SLC SWITCH was isolated for 4 ½ hours. She said that Service Manager’s root cause analysis found that the problem was due to this project. Bonnie said that Qwest said these type of outages have to be reported to the FCC. She said that the Service Manager assured them that controls were in place to prevent this from happening again. Bonnie said that Qwest implemented this request over Integra and McLeod’s objection and that this change had significant impacts to them. Mark Coyne-Qwest said that Integra’s concern will be noted and that we will follow up with the service manager regarding the root cause analysis.

February 20, 2008 Product/Process CMP Meeting Mark Coyne-Qwest stated that the Final notification was sent on 2/13/08 with an effective date of 2/28/08.

January 16, 2008 Product/Process CMP Meeting Mark Coyne-Qwest stated that the Level 4 notification went out on 1/14/08 with an effective date of 2/28/08.

January 7, 2008 Ad Hoc Meeting -- CR PC112807-2 Change from Single Location Routing Number Process to Location Routing Process

Attendees: Susan Lorence-Qwest, Lynn Stecklein-Qwest,Vicki Dryden-Qwest, Sandy Stulen-Qwest, Todd Rodgers-Qwest, Jeff Sonnier-Sprint, Susie Wells-Qwest, Georganne Weidenbach-Qwest, Connee Moffatt-Qwest, Karen Ferguson-Qwest, Mike Whaley-Qwest, Mark Coyne-Qwest, Wandy Kinney-Qwest, Scott Thorne-Sprint, Craig Stone-Sprint, , Bonnie Johnson-Integra, Kim Isaacs- Integra, Chris Gilbert-Integra, Marcelle-Integra, Roger Maxwell-Integra, Roxanne Hoover-McLeod, Sherry Krewett-McLeod,, Julia Redman-Carter-McLeod, Sue Wright-XO Communications, Laurie Roberson-Integra, Mark Miller, Robb Garth

Lynn Stecklein-Qwest stated that the PCAT and Ordering documents that would be discussed in this meeting could be found at: http://www.qwest.com/wholesale/cmp/teammeetings.html. Connee Moffatt-Qwest asked if there were any questions on the redline PCAT.

McLeod and Integra stated that they did not have an opportunity to review the PCAT.

Bonnie Johnson-Integra said not to assume silence means that they have no questions. She said that the “change in response to customer feedback…” in the first paragraph sounds like that this change is based on all customer’s requests (Comment to minutes received from Integra 1/15/08) said it is apparent from previous calls that there are CLECs that did not ask for this change and asked how this could be revised.

Julia Redman-Carter-McLeod asked if the call on the 1st diagram was a local call.

Todd Rodgers-Qwest said it is a local call. Julia Redman-Carter-McLeod asked why there were 9 diagrams originally and now there are only 3.

Todd Rodgers-Qwest said that on a previous call everyone wanted to know what existed today and what ARLRN would look like. He said that we only included ARLRN diagrams in the PCAT.

Julia Redman-Carter-McLeod asked where the diagram for LRN was.

Todd Rodgers-Qwest said the last diagram is the default LRN 6 digit routing.

Julia Redman-Carter-McLeod asked if any of these differ from what we do today.

Roxanne Hoover-McLeod stated that SRLN could still exist today and they want to see that diagram.

Julia Redman-Carter-McLeod said that the SRLN diagram should be placed in the SRLN section and since LRN is crossed out they can’t tell what the difference is.

Karen Ferguson-Qwest explained that when we tried to decide on which diagrams to include, Qwest did not feel the previous process should be included. New requests would follow the ARLRN process.

Julia Redman-Carter-McLeod said that on the last ad hoc call a customer does not use ARLRN, it would go to the default which is the industry standard. She also stated that they would like to see how the traffic will continue to flow for SLRN if no changes are made. .

Todd Rodgers-Qwest relayed that the last diagram is the industry standard. The first two diagrams are the ARLRN process. The Business Procedure applies to ARLRN and that their Service Managers would be happy to outline what exists today if requested. He said that to McLeod’s point, including nine diagrams would lose the essence of ARLRN.

Julia Redman-Carter-McLeod agreed that was the issue and that there are so many options not captured in the diagrams. She referenced Diagram 2 and had a concern about toll calls and local calls. If Qwest is routing traffic through the default, what happens to all other traffic.

Todd Rodgers-Qwest said that if you had the NPANXX in the local calling area,it would ride the DEOT. If ARLRN is not requested, you would follow Diagram 3.

Julia Redman-Carter-McLeod asked how much of this is 5123 traffic.

Todd Rodgers-Qwest stated that this traffic is minimal and that Qwest had offered to conduct a study.

Julia Redman-Carter-McLeod said that this type of traffic may be minimal but would like Qwest to conduct a study.

Karen Ferguson-Qwest said that this change involves a large territory and there is no way to globally study this type of traffic. She said that the CLECs need to choose the LRN and DEOT. Qwest does not know the CLECs network and that a customer needs to provide something to study.

Chris Gilbert-Integra asked why Qwest was making this change if they can’t measure it.

Todd Rodgers-Qwest stated that this change is in reaction to customers requests. He said the feedback received is that SLRN is not customer friendly and that ARLRN is more customer focused.

Scott Thorne-Sprint stated that they were in favor of what Qwest is doing and feel that the traffic is minimal. He said that they could provide an example and do a quick study to determine percent of change of utilization. Scott asked if 3-5 examples would be an accurate representation,

Todd Rodgers-Qwest stated that Sprint could provide the LRN where the NPA of the end office has DEOT trunking. He said that 3 examples in 3 different states would be fine and could send in the next day or two and would be done in five business days from receipt. Qwest stated that it would be easier to conduct the study at the same time so that the trace only had to be done once.

McLeod asked if the Sprint study would be shared with everyone or would this information be proprietary.

Scott Thorne-Sprint stated that from their perspective they are willing to share the number of trunks and the percent of change. Jeff Sonnier – Sprint said this information is beneficial and could be shared with everyone.

Bonnie Johnson-Integra stated that they would discuss internally to determine if they want a study done.

Roxanne Hoover-McLeod stated that she totally agreed that the traffic is minimal and does not want to bother with a study. Roxanne said that this does not stop Qwest from growing this traffic in the future and adding new customers to the QC PIC and that they would not know that the traffic will go up. She also said that the problem of this being in violation of the ICA has not been addressed.

Sandy Stulen-Qwest stated that she would follow up today and would provide a response to the ICA language Roxanne sent through the service team.

Roxanne Hoover-McLeod reiterated that they want something in writing and that this could have a huge impact to their business.

Karen Ferguson-Qwest stated that Qwest is not planning on growing the 5123 type of traffic and that is not one of Qwest’s objectives. This is not why we are implementing ARLRN. She reiterated that the CLECs don’t have to request ARLRN.

Bonnie Johnson-Integra stated that they have the same concern and that corporate direction has changed in the past.

Comment to minutes received from Integra 1/15/08 Qwest (unknown though I believe it was Karen) stated that she is not in a position to make a commitment about Qwest Corporate strategy in CMP or to commit that Qwest will not start assigning the 5123 PIC in the future.

Susan Lorence-Qwest stated that this discussion about corporate strategy is not appropriate to CMP. She said that the purpose of this discussion today is specific to the ARLRN CR and asked if there were any question associated with the change in process.

Roxanne Hoover-McLeod stated that they have expressed their concerns and would like to see the SLRN process in a separate diagram.

Susan Lorence-Qwest stated that Qwest would take that as a follow up item. She asked if there were any questions on the ordering form.

Julia Redman-Carter –McLeod stated that on the ordering the ‘R’ is missing from ARLRN. McLeod asked if there was a change in the last bullet re: the 30 day due date.

Connee Moffatt-Qwest stated that there was no change and that the changes are noted in blue.

Susan Lorence-Qwest stated that Qwest will proceed in sending the notice and document out for formal comment and we will follow up with Sprint to determine how the results of the study will be shared.

Julia Redman-Carter-McLeod expressed concern regarding billing and costs to them associated with putting in new trunks and especially if there is an increase in traffic and requires putting in new trunks.

Sandy Stulen-Qwest said that trunking is part of their ICA and that it depends on their relative use factor.

Karen Ferguson-Qwest stated that the decision of who pays for what is very customer specific to their relative use factor and that the they should discuss that process with their access manager. This is dealt with in a different PCAT and is ICA specific.

McLeod stated that diagram 2 could potentially have an impact on routing and want that issue addressed.

Susan Lorence-Qwest stated that we would take this back to the SME team to determine if referencing another PCAT is appropriate. She said that the next step is to sending out the documentation for comment and to conduct the study. Susan also asked if there were any more questions on the CORR form.

Bonnie Johnson-Integra stated they have not had the opportunity to review the form.

Julia Redman-Carter-McLeod stated that they want the answers in writing to Roxanne’s (Mcleod) questions before they will consider this request.

Susan Lorence-Qwest stated that any questions associated to their ICA are outside of CMP and should be worked with their Service Managers. Qwest will provide the response to ICA questions back to McLeod and if McLeod so chooses, they can share the information with other CLECs.

The meeting was adjourned.

December 17, 2007 Adhoc Meeting -- CR PC112807-2 Change from Single Location Routing Number Process to Location Routing Process

Note: Unless otherwise noted, comments in bold are feedback and input received from Qwest

Attendees: Susan Lorence-Qwest, Lynn Stecklein-Qwest,Vicki Dryden-Qwest, Sandy Stulen-Qwest, Todd Rodgers-Qwest, Jeff Sonnier-Sprint, Susie Wells-Qwest, Georganne Weidenbach-Qwest, Connee Moffatt-Qwest, Karen Ferguson-Qwest, Ralph Smith-Sprint, Craig Stone-Sprint, Scott-Sprint, Bonnie Johnson-Eschelon, Kim Isaacs-Eschelon, Marcelle-Integra, Roger Maxwell-Integra, Roxanne Hoover-McLeod, Sherry Krewett-McLeod, Mike Whaley-Qwest, Julia Redman-Carter-McLeod, Ron-XO Communications, Sue Wright-XO Communications, Gary-XO Communications, John-XO Communications, Kathi Lee-AT&T, Nancy Sanders-Comcast, Jason-AT&T, Laurie Roberson-Integra, Nancy Sanders-Comcast

Susan Lorence-Qwest provided a background on this CR. The process change was originally submitted on November 5, 2007 as a Level 3 notification PROS.11.05.07.F.05018.LocationRoutingNumber. She said that a customer comment was received to change the disposition of this notice to a level 4. The comment was discussed at the November 2007 CMP monthly meeting and on November 27 where a decision was made to retract the Level 3 notice and issue a CR. Susan said that both those meeting minutes have been posted to this CR. She said that this CR was presented in the December CMP Meeting by Karen Ferguson (Qwest). She said that the purpose of this meeting is to further discuss this change. She said that the LRN diagram document that will be discussed in the meeting can be found at: http://www.qwest.com/wholesale/cmp/teammeetings.html Connee Moffatt-Qwest stated that this CR was issued to change the SRLN routing number process to ARLRN. She said that SRLN will no longer be offered and that existing SRLN will be left in place. She said that during the last ad hoc meeting, the CLECs asked Qwest to provide diagrams to explain SRLN and how we want to change from 10digit routing to 6-digit routing.

Todd Rodgers-Qwest reviewed slide 1 of the LRN Diagrams – Typical End Office LRN Routing (LRN outside of local calling area). NOTE: The slides are included at the end of these meeting minutes.

Julia Redman-Carter-McLeod asked what kind of trunks were associated with step 4 on slide 1 and whether they were IntraLATA or local traffic.

Todd Rodgers-Qwest stated that this is LIS trunking and that the trunks were primarily for IntraLATA traffic. He said that this call is a local call to your next door neighbor over a toll trunk group. He said that this occurs today and everywhere not just in Qwest territory.

Julia Redman-Carter-McLeod stated that it is a local call coming from Qwest, ported number which is why we did the dip and also is a transit call.

Todd Rodgers-Qwest said it would be a transit call.

Connee Moffatt-Qwest said it could be non-Qwest also.

Todd Rodgers-Qwest stated that this would be the transit scenario.

Julia Redman-Carter-McLeod said that the call is coming back to the end office where we did the dip and it’s going across the IntraLATA trunk not necessarily access. This is a call from the tandem going out through an IntraLATA trunk group to the CLEC end office.

Bonnie Johnson-Eschelon asked if this scenario was the default scenario described in an earlier call.

Todd Rodgers-Qwest said that it is.

Julia Redman-Carter-McLeod asked for clarification whether this is typical end office LRN routing.

Todd Rodgers-Qwest said that it is typical LRN routing and happens all day everyday.

Todd Rodgers-Qwest reviewed Slide 2 of the LRN Diagram.

The question was asked what kind of trunks. NOTE: This question was asked multiple times throughout the call and the response was that the trunks are LIS trunks for IntraLATA or local traffic. The slides will be updated accordingly.

Todd Rodgers-Qwest reviewed Slide 3. He stated that the trunks in steps 5 are Qwest infrastructure trunking.

Jason-AT&T said that instead of your local tandem being isolated, they are actually going to have links to access tandems.

Todd Rodgers-Qwest said that these are one way links specifically for this type of traffic.

Jason-AT&T asked if this was based on the provider or if everybody’s traffic will be pointed to the same trunks groups.

Todd Rodgers-Qwest responded that everybody’s traffic would be combined and further said that this is non-Qwest, non-dipped traffic delivered to the local tandem. Todd Rodgers-Qwest said that this would be primarily for those ILECs who are incapable of doing the LNP dip and that that number is diminishing. He said that if a call comes into Qwest un-queried for whatever reason, we are the query of last resort on the default routing query at the local tandem. He said that this is diminishing also.

Jeff Sonnier-Sprint asked what percentage of ILECs are doing dips.

Todd Rodgers-Qwest said that it is increasing every day. If he had to guess based on his experience in the routing group, it is probably approaching 90%.

Jason-AT&T asked if the CLECs have to establish an ARLRN group or will it just be one giant group that this traffic will terminate over.

Todd Rodgers-Qwest stated that (Number 6 on slide 3) the trunk group will have already been established by a CLEC.

Jason-AT&T said that they don’t have to do anything for line 5 that is strictly Qwest building that infrastructure.

Integra asked if slide 3 is applicable for CLECs who don’t have trunks to the local tandem.

Todd Rodgers-Qwest stated that slide 2 is what exists today with SRLN and slide 4 describes when you want to put in trunks to implement ARLRN.

Sandy Stulen-Qwest stated that SPOP (step 6) could be combined IntraLATA/local and that is how you would have ordered it.

Integra asked if a customer already has trunks to the local tandem would they have to go to slide 3 and build trunks to the access tandem and remove the local tandem trunks.

Todd Rodgers-Qwest said you can and it is an option. He said that SRLN can remain in place and you don’t have to change anything. He said that if you choose, you can remove those trunk groups from the local tandem.

Julia Redman-Carter-McLeod asked if the documentation has been updated with the current process or are you just describing the process based on the diagrams. She said that the current process does not describe that SRLN is an option and asked if that meant they could keep doing it.

Todd Rodgers-Qwest stated that you can continue SRLN as you have it today but you can’t add in new areas.

Qwest stated that the (PCATs) are being updated.

Todd Rodgers-Qwest reviewed Slide 4 and said that this is similar to slide 2 but only translating to 6 digits. He indicated that this is transit traffic and is a non- Qwest service provider.

AT&T said that this would be going from multiple trunks to single trunk and from 10 digits to 6 digits on LRN.

Todd Rodgers-Qwest stated that Qwest is responding to feedback from our customers. He said that many times we have heard that Qwest should not route on 10 digits because the LNPA working group describes that we should use 6. He said that many times customers have said we shouldn’t require multiple trunk groups vs. one.

Sandy Stulen-Qwest said that this change will not happen overnight. She said that if you already have multiple trunks groups with LRN, the embedded base stays as it is. She that if a customer wants to make a change, they would have to work with their service manager.

Sherry Krewitt-McLeod said that Qwest said ARLRN is an option but is that the case for new trunks groups.

Further discussion indicated that changes from SRLN to ARLRN would be on a project basis, 1st come 1st served and that each customer should work with their service manager if they wanted to change.

Todd Rodgers-Qwest stated that one could have a local tandem and follow slide 3. If you choose to put in direct trunking to a local tandem that is where ARLRN would come in. He said that you could have direct trunking to a local tandem and only have NPA NXX routing. This could be a mix of slide 3 and 4 and your LRN could follow slide 3 and your local NXX could follow slide 4.

Jeff Sonnier-Sprint said one of the advantages of going to 4 would be to combine trunk groups rather than SLRN multiple trunks on slide 3.

Todd Rodgers-Qwest stated that slide 3 is if you are homing off the Qwest access tandem, that trunk group is out of the access tandem.

Karen Ferguson-Qwest asked if Sprint was referring to slide 2.

Jeff Sonnier-Sprint said that slide 2 and slide 4 is where the difference is.

Integra said that so far we have only talked about local calls.

Todd Rodgers-Qwest agreed and said that we would talk about toll in slides 7, 8 9.

Todd Rodgers-Qwest explained the difference between slide 2 and 4. He said that slide 2 is the SLRN process where Qwest translates down to a 10-digit LRN and does that once per trunk group.

McLeod said that really the SRLN or the ARLRN process is that the traffic is going the same way when routed. She said that the difference between SRLN and traffic routed on ARLRN is the same.

Todd Rodgers-Qwest stated that the difference is the translation on ARLRN will translate on 6 digits and SRLN will translate on 10 digits. SRLN is one LRN per trunk group and multiple ARLRN allows for multiple trunk groups within the same NPA NXX.

A question was asked if the result will be the same for transit traffic.

Todd Rodgers-Qwest said yes and this is a large change for Qwest.

Todd Rodgers-Qwest reviewed Slide 5and Slide 6. He said slides 1-6 are all local and slides 7-9 are toll.

Todd Rodgers-Qwest reviewed Slide 7 and relayed that # 4 is a JPSA/toll LIS trunk. Todd mentioned that on SPOP, you could combine local or toll.

Todd Rodgers-Qwest reviewed Slide 8 and 9.

There was discussion about other NPA NXXs ported to LRN and Todd said only traffic to the NPA NXX of the LRN would be affected and said Qwest would not do the look up of any other NXX at that end office.

Todd Rodgers-Qwest provided an NPA NXX example: the LRN is xxx xxx 1234 and my Qwest customer is calling xxx xxx 1235. That call would route the same way of the local call using the 1234 LRN, if the Qwest customer was LPIC’d to 5123. This is a specific, small set.

There was discussion about how toll and local traffic is tracked, whether it is different, if toll how much, when etc.

Karen Ferguson-Qwest stated the call referred to on slide 9 is not a transit call. The way a customer knows whether a call is toll or local depends on how the CLEC does recording and billing. She said that for bill validation, Qwest only looks at the originating and terminating number to determine jurisdiction. No record is sent by Qwest to the CLEC on this kind of call. Qwest pays based on the bill sent to us and every CLEC is different and how they create the bill is not clear to Qwest. She said that Qwest doesn’t provide a record to you but that you make some kind of recording in your company to identify the call as local or toll. In regard to meet point billing, Karen stated only would apply to slide 7 where there is an IXC call involved. These types of records are MPB/JPSA and transit for a LIS service - Not for a Qwest originated toll call. She referred the CLECs to their access managers to discuss specific questions/concerns about Qwest payment of their bills.

Todd Rodgers-Qwest provided clarification on what occurs when a number that is part of LRN is ported out. If ARLRN is requested, it would be a triggered in the end office. He said if a number was ported away, the Qwest end office would do a look up, receive the LRN and route based on whatever is in place for the owner of the new LRN For ARLRN routing on a specific NPA NXX, the CLEC calls ported away from them will not be delivered. If a call is ported away, Qwest will do the look up and deliver to the appropriate party. On local calls ported to you via ARLRN, only local calls ported will be delivered using your specific NPA NXX. For LRN or toll calls to that NPA NXX, if the Qwest customer is LPICd to 5123 and that customer makes a toll outside of the calling, Qwest will not give you other ported calls from that DEOT trunk group.

McLeod stated that per their ICA, their position is that they don’t want IntraLATA toll traffic over their local trunks and wanted to make sure that would not happen.

Sandy-Stulen-Qwest stated that this is a matter for legal and Qwest is not coming up with the same answer as McLeod. Sandy said we received McLeod’s email and that something will be sent back via the service manager.

Bonnie Johnson-Eschelon stated that they have the same concern and are in agreement with McLeod.

Sandy Stulen-Qwest stated that she would prefer that Eschelon send their own e-mail either via their service manager or directly to her regarding their concern.

McLeod continued to express their concern about this change and how it would impact them and whether they could continue with the SLRN process. There is a concern that this change in process will require more of their resources and their routing staff has more to do.

Todd Rodgers-Qwest stated that this is a change in process and if a CLEC does not request anything different, Qwest will keep what is there in place. Todd reiterated slide 3 illustrates what happens if you do request ARLRN routing and slide 1 is what happens if you don’t request ARLRN routing. The call works and gets delivered to you.

An example was given if the Qwest customer is making an IntraLATA call that is PIC’d to 5123to a McLeod customer using the same NPA NXX as McLeod’s LRN. That call will travel over the local trunk group only if ARLRN routing is requested and if you don’t will follow slide 8 which is what it is doing today.

There was a question on whether there would be a tandem or local charge like in slide 3 however it was stated that you don’t pay tandem when you are receiving a call.

Bonnie Johnson-Eschelon asked if this impacts the relative usage.

Karen Ferguson-Qwest stated that this is very customer specific and each customer needs to talk with their access manager about the specific location you are concerned about. This is a small amount of traffic and it is unclear how it would impact the transport for the relative use factor.

It was again stated that Qwest should label the diagrams to insure it was clear what kind of trunks are being referenced. Qwest said that these are all LIS trunks. It was stated that LIS is a Qwest term and based on different ICAs, there is a question as whether toll group or IntraLATA traffic. Qwest stated that it all depends on how each company’s network is set up. Each CLEC may do this differently however it is all basically LIS trunks.

McLeod again stated their concern that SRLN routing will no longer be available and questioned where the ARLRN scenario is. Qwest reiterated that SLRN remains available where already in place. McLeod asked if ARLRN routing is requested, what happens to the flow when a toll call is made. Todd Rodgers-Qwest said you would follow slide 9. If you put in DEOT and don’t implement, then you would follow slide 8.

McLeod brought up the 512 CCS report and asked whether it will be changed to reflect CLEC routing. They indicated that every month they get a report that tells them where Qwest believes end office trunks should be installed. McLeod indicated they have had a lot of problems with this report. They relayed the reports would have to more sophisticated or are going to be worthless.

Todd Rodgers-Qwest stated that he has not been very involved with the 512 report and that with porting and pooling, it is difficult for Qwest to understand how an LRN might be used outside of the area. He said that ARLRN gives you more control over the 512 report. Joint planning of your network, would help to determine if a customer would need ARLRN routing rather than relying solely on Qwest. McLeod again stated their concern with the 512 report and its accuracy. They believe the report needs to be adjusted.

Todd Rodgers-Qwest asked if they were solely designing their network based on a report provided by Qwest. McLeod responded that they were forced to per their ICA but questioned if they can change it.

Susan Lorence-Qwest stated that the meeting was only scheduled 1 hour for this meeting and that it would be more logical to handle some of these questions offline. She questioned if this call had made the process more clear or whether there were major outstanding questions.

Jeff Sonnier-Sprint stated that Todd (Qwest) has done an excellent job and should be commended on the diagrams and explaining the differences on the SRLN, ARLRN and default routing. He said that the billing concerns and routing concerns etc. by the other CLECs should have more discussion. He said that overall this has been a great job.

Susan Lorence-Qwest said thank you and has been a big effort to pull together.

Julia-McLeod stated that they do appreciate the help and that the diagrams have been helpful but that they need more clarity and information. She said that she is not prepared to go further without a process outline. Once the document is updated, then more discussion should occur. She asked if the diagrams would be included in the document.

Susan Lorence-Qwest said that she was not sure if they would be included.

Bonnie Johnson-Eschelon said that she would like to see the diagrams included and some definitions would be helpful.

Susan Lorence-Qwest stated that we would take that back.

Julia-McLeod asked what they need to do if there are other questions especially if they are related to their ICA and requested the name of the Qwest attorney.

Susan Lorence-Qwest stated that the ICA is outside of CMP and those issues should be worked with their service managers or to send those questions to Sandy Stulen (Qwest).

Susan Lorence-Qwest stated that we need to regroup internally and then decide how to proceed and whether another adhoc meeting would be worthwhile. She said that the process will be sent out for formal review. She proposed using the formal level 4 notification process and cycle which allows a 15 day CLEC comment period.

Julia-McLeod stated that this is not acceptable and that she did not feel comfortable about the process.

Bonnie Johnson-Eschelon stated that we have had ad hoc meetings in the past for further discussion and there needs to be a commitment from Qwest to update the documentation.

Susan Lorence-Qwest stated that we would have another ad hoc meeting after the 1st of the year due to the holidays and SME availability. Qwest will regroup internally to discuss the documentation concerns. She said that if there are ICA concerns that they need to work with their service manager.

Julia-McLeod stated that we need to address the issues on billing, what trunks need to be adjusted, respond on how Qwest proposes to address the costs and to redline the process document. She asked what other CLECs could do if there were additional questions.

Susan Lorence-Qwest stated that questions could be sent to the CMPCR@qwest.com mailbox.

The meeting was adjourned.

December 12, 2007 Product/Process CMP Meeting Susan Lorence-Qwest stated that this CR is a result of a Level 3 change to disposition that was discussed in an adhoc meeting on November 27th. She said that subsequent to that meeting, Qwest agreed to retract the level 3 notice and issue a level 4. Karen Ferguson-Qwest stated that Qwest has reviewed its current Single Location Routing Number (SLRN) process, and proposes to change the SLRN process to be more closely aligned with industry guidelines. Qwest proposes modifications to the SLRN process to reflect a modified Location Routing Number (LRN) process to improve routing and trunking. Qwest proposes to simplify the process for customers to route based on the first 6 digits of the LRN as if it were a dialed number rather than using the full 10 digit LRN. Karen stated that an adhoc meeting is scheduled to discuss the details of this change on Monday, December 17th. Kim Isaacs-Eschelon asked if the meeting minutes from prior meetings would be posted to this change request. Susan Lorence-Qwest stated that they would be.

November 27, 2007 Adhoc Meeting Integra/Eschelon Objection to a Leve 3 Process Notice – Comment received 11/12/07 in CMP CR and CMP COMM mailboxes

Attendees: Susan Lorence-Qwest, Vicki Dryden-Qwest, Mark Coyne-Qwest, Sandy Stulen-Qwest, Todd Rodgers-Qwest, Jan Wittnebel-Qwest, Mike Hammer-Sprint, Jeff Sonnier-Sprint, Susie Wells-Qwest, Neil Houston-Qwest, Georganne Weidenbach-Qwest, Ralph Smith-Sprint, Connee Moffatt-Qwest, Karen Ferguson-Qwest, Craig Stone-Sprint, Bonnie Johnson-Eschelon, Kim Isaacs-Eschelon, Mike Hammer-Eschelon, Doug-Eschelon, Marcelle-Eschelon, Lee-Integra, Dennis-Integra, Roger-Integra, Roxanne Hoover-McLeodUSA, Sherry Krewett-McLeodUSA

Susan Lorence-Qwest stated that the purpose of this call is to discuss a proposed change in process that was originally submitted on November 5, 2007 as a Level 3 notification PROS.11.05.07.F.05018.LocationRoutingNumber. She said that a customer comment was received to change the disposition of this notice to a level 4. Susan said that per CMP requirements, this change to disposition request was discussed at the November 2007 CMP monthly meeting and the decision was made to schedule this adhoc meeting to further discuss this change in process. Susan stated that the minutes from the November 14th meeting were posted to the Wholesale Calendar. She said that she would like Sandy Stulen (Qwest) and Todd Rodgers (Qwest) to provide an overview of this change in process and then would open the discussion to questions and/or comments.

Sandy Stulen-Qwest stated that Qwest reviewed its LRN processes and in response to customer feedback made the decision to change the SRLN process to be more closely aligned with industry guidelines. She said that those customers who currently have SLRN routing in place are not required to make any changes in their embedded network. Sandy said that all new requests will follow the LRN process. Sandy said that there are benefits for both the CLECs and Qwest. She said that one of the benefits is that it will reduce the number of trunks between Qwest and the CLEC. She said that the SLRN process required a trunk group per LRN and that this change in process allows multiple LRNs on a trunk group. Sandy said that when Qwest implements a new local tandem, this change in process eliminates the necessity for a CLEC who is porting and pooling in the local tandem area to order trunking for LRN routing. She said that this change in process allows the CLEC to be in charge of managing their porting and pooling network.

Todd Rodgers-Qwest stated that prior to this change in process, Qwest looked at the full 10 digit LRN and routing required additional customer trunking for each LRN. Todd said that as a result of customer feedback this change in process will allow the traffic to be delivered to the access tandem and will reduce the CLECs trunking needs. He said that we will route based on the first 6 digits of the LRN and this is transparent to the CLEC and Qwest.

Susan Lorence-Qwest asked if there were any general questions.

Dennis-Integra stated that (12/6/07 Comment Submitted by Eschelon) one LRN per switch per LATA has been the industry standard for years and asked if this change was for porting and pooling providers only.

Todd Rodgers-Qwest stated that this change in process was not directed at any one customer. He said that with SRLN routing it is per switch per LATA and you don’t own a NPA-NXX within the local calling area.

Dennis-Integra stated that toll LRN identifies the switch location based on the (12/6/07 Comment submitted by Eschelon) NPA-NXX of the originating and terminating number. He said that DEOT under version 3 vs. version 2 says you route direct to a tandem owner of LRN.

Todd Rodgers-Qwest stated that LRN has no jurisdiction and said it is more like an IP address or mailing address.

Todd Rodgers-Qwest stated that about 10 years ago one LRN per rate center was required and when the Industry changed the requirement to one LRN per switch per LATA Qwest created the SRLN process for the separation of local from toll because of internet traffic. Qwest wanted the dial up local internet traffic off of the access network.

Dennis-Integra asked if he meant in this part of the country.

Dennis-Integra said that if they don’t request any changes then there will be no change to what happens today.

Todd Rodgers-Qwest agreed. Kim Isaacs-Eschelon asked if this was for any augment.

Todd Rodgers-Qwest said this change does not apply to augments on current trunks and with a new trunk groups this change in process will apply. He said that it is your choice and if LRN is not implemented the calls will route.

Dennis-Integra said that nothing works without LRN routing.

Todd Rodgers-Qwest stated that when a Qwest customer calls there will be a LNP look up and if the LRN returned is outside of the local calling area the call will be routed to the access tandem. Todd said that there will be no change to the lookup with this proposed change. He said that Qwest will route the LRN to the access tandem as if dialed by an end user. Todd said that Qwest will route the NPA NXX on the trunk group you request. He said that if an unqueried call routed to the local tandem prior to the change, there was no way to route the traffic and it would not complete. Qwest has added LRN infrastructure between the local and access tandem. He said that non-Qwest companies complete 90% or better LNP local queries and that the LRN outside of the local calling is minimal. Todd said there is less intervention and that the inter-tandem routing is the major change here.

Dennis-Integra asked if the traffic would be routed the way they wanted.

Todd Rodgers-Qwest said yes.

Marcelle-Integra cited an example of a customer in Fort Collins with a ported number – Qwest to Integra and asked how the call would be routed. Todd Rodgers-Qwest stated that the routing would stay in place and if you choose to implement LRN routing we can divert the NPA-NXX away from the access tandem to a specific trunk group. Dennis-Integra asked if this was regardless of the type of call.

Todd Rodgers-Qwest stated that due to switch limitations, if a customer is LPIC’d to 5123 – INTRALATA CIC and they make a call to the NPA NXX of the LRN that traffic would route over the designated trunk group. Marcelle-Integra said that it does not say whether customer is PIC’d to Qwest.

Todd Rodgers-Qwest said that it would be the trunk you designate.

Roger-Integra said that if it is PIC’d to Qwest our CIC then it would route to the access tandem.

Roger-Integra asked about the blockage of trunks.

Todd Rodgers-Qwest said that would be minimal. (12/6/07 Comment submitted by Eschelon) – is a legitimate concern).

Dennis-Integra said that some time ago Qwest has 50% of LPICs.

Todd Rodgers-Qwest stated that when a customer made changes to a calling plan they are normally moved to QCC CIC 432 or 236 – another branch of Qwest.

Dennis-Integra asked if Qwest could provide traffic studies.

Todd Rodgers-Qwest said that he would have to defer to determine scope.

Dennis-Integra asked if they would run out of trunks because toll traffic is routed over the trunks.

Todd Rodgers-Qwest stated that not all Qwest toll traffic would be routed over these groups– just from the end office of the DEOT to the specific NPA-NXX of the LRN.

Roxanne Hoover-McLeod said that you have your own code.

Bonnie Johnson-Eschelon asked if this change applied to new requests and only if you request the change.

Todd Rodgers-Qwest stated that if it was new and you don’t request a change it will route to the tandem and that there is no change to the existing process unless you ask for it.

Todd Rogers-Qwest stated that we would route toll over local only if you requested LRN routing.

Roxanne Hoover-McLeod stated that Qwest has taken on an industry term and used it differently. (Comment from McLeodUSA 12/5/07) – Qwest either needs to pick a different name for their new product or figure out a way to identify it separately from the industry standard meaning.

Dennis-Integra stated that there is LRN routing all over the country, He said that he needed further explanation associated with the LRN to trunk group routing.

Dennis-Integra stated that the balance of traffic we receive reciprocal compensation (12/6/07 Comment submitted by Eschelon) and reciprocal compensation rates are based on the balance of traffic. He said now with this swing of toll traffic and more Qwest originated traffic and they will receive a lower compensation rate.

Todd Rodgers-Qwest stated that he was not familiar with reciprocal compensation.

Sandy Stulen-Qwest asked if these were transport costs.

Dennis-Integra stated that it was 3-1 balance ISP Compensation at a lower rating.

Dennis-Integra stated that with ELI/Integra stated that they look at the trunk group for the 3-1 balance on the originating /terminating. He said not knowing what kind of traffic we are talking about today and with the new process could skew this balance.

Sandy Stulen-Qwest stated that we would have to take a look at the 3-1 balance.

Marcelle-Integra stated that this could be issues for anyone in all six Regions. He said that it could be VNXX trap with the originating/terminating balance.

Karen Ferguson-Qwest stated that VNXX has no bearing on the change and that this will not change the local originating/terminating balance.

Dennis-Integra stated that it was not clear in the VNXX proceedings.

Karen Ferguson-Qwest stated that we have been clear and that it starts with a call that looks like a local call and has no bearing on this.

Susan Lorence-Qwest asked if anyone else on the call had any input.

Integra- stated that Qwest mentioned that they wanted to simplify routing and said if Qwest was going to require LRN routing from Integra, will Qwest (12/6/07 Comment submitted by Eschelon) allow Integra to route toll traffic on the same trunk group.

Todd Rodgers-Qwest stated that he could not speak to toll on direct trunk groups.

Integra- stated that it was the same thing but a different way of routing.

Todd Rodgers-Qwest stated that with porting and pooling and there is a new local tandem conversion. He said that we look at all traffic and identify pooling and porting providers and we require a trunk group to the local tandem. He said that with porting and pooling we needed a way to deliver the traffic. He said that with this change in process if you own a NPA NXX and you are in control and it is your choice with routing.

Integra-stated that it is not pure toll.

Todd Rodgers-Qwest said only Qwest originated 5123 LPIC to NPA NXX of LRN traffic will be directed to the DEOT group.

Bonnie Johnson-Eschelon asked if it was fair to say that this change in process would be an advantage for a specific type of business - porting and pooling. Todd Rodgers-Qwest said that this only applies to customers with pooling and porting and it only happens with LRN routing. He said that you can allow routing to happen as it happens today and that if you implement LRN routing the existing traffic will be overridden with the 6 digits rather than 10 digits.

Bonnie Johnson-Eschelon said that now it is SLRN and asked if going forward and you don’t implement LRN, can you keep SRLN.

Todd Rodgers-Qwest stated that in the normal course the LRN is routed as if dialed by the originator. He said that with this change in process you can if you choose to override that routing. Dennis-Integra stated that in the Seattle area that most customers started as Qwest customer and a large number were ported numbers to other carriers. He said that all calls will come back as LRN for all LPIC’d to Qwest. He said that if you have a Qwest customer dialing the LRN of switch there will be more traffic.

Integra- said not toll - only dip if local. – LPIC to Qwest Intrastate/Intralata – Toll was the exception.

Todd Rodgers-Qwest stated that if you request us to implement this process change and if you see LRN put on Trunk group A we will only do the LNP dip on local. He said that the basis of exception or the thing we want you to be aware of is a Qwest customer LPICd to 5123, a diminishing base, makes a 1+ call to NPA-NXX of the LRN it will also follow the same 6 digit routing.

Dennis-Integra stated that dialed digits not returning LRN that you have to do a query.

Todd Rodgers-Qwest said we don’t query on toll.

Marcelle-Integra 1+ Time Warner you are assuming we own LNP process Qwest- last resort – default by accident.

Dennis-Integra stated that you are the IXC and asked if something is PIC’d to you who does the query.

Roxanne Hoover-McLeod stated that the process needs to be documented.

Susan Lorence-Qwest stated that McLeod made the comment that they were not enthused with the way the document was worded and that we would like to focus on the process. (12/6/07 - Comment submitted by Eschelon) She said Qwest took the documentation back internally and Qwest did not think any changes needed to be made and the documentation was correct.

Roxanne Hoover-McLeod stated that the document needs to reflect the process and the document is not correct.

(12/6/07 Comment submitted by Eschelon) Susan Lorence-Qwest statedt hat there is a process to request documentation updates.

Todd Rodgers-Qwest asked if the document before this change tells you how to remove the SRLN.

Roxanne Hoover-McLeodUSA said that she never read the document but that they were forced to fill out forms. She said that the prior process did not tell them how to remove the SRLN. (12/5/07 - Comment from McLeodUSA ) because we were never allowed to remove SLRN routing.

Todd Rodgers-Qwest stated that SRLN and LRN routing are options.

Roxanne Hoover-McLeod stated that they were forced to fill out a form and that she would like to see a process to make suggestions and to request changes. She said that she does not want to rewrite Qwest’s document and all Qwest did in the documentation was to take out the “S”.

Bonnie Johnson-Eschelon stated that she agrees that the process is not clear based on the questions from this call. She said that she wants the process documented to determine the impacts to the process. She said that she did not think that this call would get us there. Bonnie said that she needs to understand what happens today vs. tomorrow and that the CLECs should not have to request that the process be documented. (12/6/07- Comment submitted by Eschelon) Bonnie said for purposes of this discussion Qwest should make diagrams of routing the way it is today and how it will be for the new process.

Susan Lorence-Qwest stated that she agreed that clarification was needed in some areas of the document. She said that Qwest will regroup to determine if diagrams would be helpful.

Roxanne Hoover-McLeod stated that they need this process in writing and that Qwest has explained 3 or 4 times and still no one understands the process (12/5/07 - Comment from McLeodUSA) because the document does not reflect the same answers Qwest is giving on the calls. She said that sending INTRALATA TOLL over local trunk groups is a violation of the ICA in all 14 states.

Sandy Stulen-Qwest stated that the Qwest attorneys did not see where we were in violation of the contract. She said that if there were specific areas of concern they need to get with their Service Managers.

Roxanne Hoover-McLeod stated that she could pull examples in a couple of different states.

Bonnie Johnson-Eschelon asked if Qwest considered 5123 only as resold toll.

Todd Rodgers-Qwest said no.

Bonnie Johnson-Eschelon asked if Qwest was going to get volumes on that PIC to see how many 5123 PICs there are, how many minutes are we going to see, per trunk group and per end office.

Todd Rodgers-Qwest stated that if the CLECs could provide an example of an end office and NXX, he would see what he could do.

Integra- stated that they did not care about the number of customers and that Qwest is the only one that has the customer PIC of 5123. He said that he wanted to know how many are calling his customer (12/6/07 Comment submitted by Eschelon) and where the calls will be routed.

Todd Rodgers-Qwest stated that this would only happen in a dedicated end office and that if they could tell him what their LRN is he could tell how many toll calls were made to that NXX.

Dennis-Integra stated that if Qwest would query they would have the LRN.

Todd Rodgers-Qwest stated that he would check to see what could be done.

Integra-asked if they choose this option what will happen to the existing trunk.

Todd Rodgers-Qwest stated that there is no change if you don’t request this change in process.

Kim Isaacs-Eschelon requested that the Level 3 be retracted and that a Level 4 be submitted to make this change clear. She said that collaborative sessions could be held and if applicable raise any red flags at that time.

Susan Lorence-Qwest asked if there were any other comments from anyone on the bridge.

Jeff Sonnier-Sprint stated that they had no problems with the Level 3.

Susan Lorence-Qwest stated that Sprint was comfortable with the Level 3 and said that an official vote would require a majority vote. She said that Qwest would retract the Level 3, work on the document as discussed and reissue a Level 4 CR.

Jeff Sonnier-Sprint asked how long it would take to issue the Level 4.

Susan Lorence-Qwest stated that the Level 4 would be presented in the December 12th CMP meeting. Susan said that another adhoc meeting would be held and we would renotify from that point. She said that the 80 day time period could be reduced by shortening the Qwest response time.

Jeff Sonnier-Sprint asked if something could be done in parallel. He said that they do agree with the need for diagrams and the work on presentations.

Susan Lorence-Qwest stated that the current process vs. the LRN process.

Bonnie Johnson-Eschelon asked if Qwest could include in the future what happens with new trunk group and that you don’t have to ask for LRN on the new trunk group.

Integra-stated that they also need a diagram to know how routing works and what the definition of the new scenario is if they don’t request LRN routing.

Susan Lorence-Qwest said that we would consider that request.

Integra- said that they were confused about what the LRN alternative is and need to understand the default.

Jeff Sonnier-Sprint stated that he could not find version 3 on the website.

Susan Lorence-Qwest stated that version 2 is only compared to version 3 and that the current version on the web is version 2. Susan said that we would proceed with the Level 3 retraction, issue a level 4 CR and provide clarification.

November 14, 2007 Product/Process CMP Meeting

Integra/Eschelon Objection to a Level 3 Process Notice - Comment received 11/12/07 in CMPCR and CMPCOMM mailboxes Integra/Eschelon objects to level 3 CMP notice: PROS.11.05.07.F.05018.LocationRoutingNumber. Integra/Eschelon has a number of concerns regarding Qwest’s proposal to remove the SLRN practice. The Qwest proposed changes appear to limit the availability and applicability or functionality of an existing product. CLECs should have the opportunity to discuss the scope and possible negative impacts of the proposed changes in a collaborative forum. Therefore, Integra/Eschelon is requesting the Qwest retract notice: PROS.11.05.07.F.05018.LocationRoutingNumber and open a level 4 change request to present the proposed changes to the CLEC community. Thank you. Here is a list of Integra/Eschelon’s preliminary concerns regarding Qwest’s proposal to remove the SLRN practice: o This is a significant change in network routing, not a change in process. We need time and a proper forum to discuss ramifications. o LIS trunking is priced based on balance of traffic o Balance of traffic can trigger $0.0007 ISP rate o Will this result in hidden Qwest traffic that should be charged access? o Will this generate billing records that aren't needed today? o When Qwest makes this routing change, they will be routing toll calls on existing Local trunks. ? We may experience blockage due to increase traffic on Local trunk. ? Will Qwest implement alternate routing for all Local calling via IntraLATA toll trunks? ? Will there be reservations set on the existing local trunks. If not we will be blocking outbound without alternate routing via IntraLATA Toll trunks. ? Is Integra expected to Alternate route existing local traffic to IntraLATA Toll trunks. ? Due to Qwest changes to routing, will we have a period of time to augment existing Local trunks without occurring NRC? ? Will Integra be able to route IntraLATA toll calls on same trunks to forgo cost of Tandem Transit/Switching cost?

Susan Lorence-Qwest stated that on 11/5/07 Qwest submitted PROS.11.05.07.F.05018.LocationRoutingNumber to change the existing process. She said that the document is available for review on the CMP Document Review website. Susan said that Eschelon submitted a change to disposition on 11/12/07. Susan provided the background as to why this change to disposition needed to be addressed in this meeting. She referred to Section 5.4.4.1 in the CMP Document that states ‘...CLECs and Qwest will discuss requests to change the disposition level of notified changes at the next Monthly CMP Product/Process Meeting. In the event that timing doesn’t allow for discussion at the upcoming Monthly CMP Product/Process Meeting, Qwest will call a special ad hoc meeting to address the request…’. Susan relayed that if we cannot reach agreement on how we should proceed on this change to disposition, that the requirement is to take a vote in accordance which must follow Section 17.0. The result then is determined by the majority. Susan Lorence-Qwest stated that before the Qwest SMEs address the specific questions that Eschelon has identified that she wanted to address Eschelon’s first general comment that this change appears to limit the availability and applicability of an existing product. Susan said that Single Local Routing is not a product, it is a process and that in the further discussion, Qwest would be able to make that clear. Sandy Stulen-Qwest stated that Qwest has reviewed its LRN processes and in response to customer feedback made the decision to change the SLRN process to be more closely aligned with industry guidelines. She said that those customers who currently have SLRN routing in place are NOT required to make any changes in their embedded network and that all new requests will follow the LRN process.

Todd Rodgers-Qwest stated that previously with the SLRN, Qwest looked at the full 10 digit LRN and routing required additional customer trunking for each 10 digit LRN. He stated that Qwest has simplified the process for customers and will route based on the first 6 digits of the LRN as if it were a dialed number and that this may, as a result, reduce the trunking needs.

Kim Isaacs-Eschelon stated that she was not qualified to address this subject and that her SMEs were not on this call.

Roxanne Hoover-McLeod stated that she shares some of the same concerns as Eschelon/Integra. She said that Qwest said that they are trying to mirror the industry standard but that other companies route with the 10 digit LRN and do not route toll on local trunks.

Jeff Sonnier-Sprint stated that a 6 digit LRN works for them and that they were using 6 digits with other providers also.

Todd Rodgers-Qwest stated that the LRN should be routed on 6 digits and that the last 4 digits should be placeholders per industry guidelines.

Roxanne Hoover-McLeod asked if the existing routing would continue to work unless the customer requests a change.

Todd Rodgers-Qwest agreed.

Luke Mestas-Comcast said that Qwest alluded to the fact that this would require less trunking and asked how this would work.

Todd Rodgers-Qwest said with the SRLN process, we require a trunk group at the local tandem. He said that with the change to the LRN process, using LRN outside of the Local Calling Area, it would be routed as dialed through the access tandem. Qwest has added infrastructure to the local tandem that allows for routing of toll LRNs on a 1 way basis to the access tandem.

Luke Mestas-Comcast said that there will be less traffic to the tandem.

Todd Rodgers-Qwest said that in an end office today, when you have the LRN outside the local calling area, Qwest will route the LRN to the access tandem as if dialed by an end user. He said that if you don’t require different trunking, then set the trunking up to the tandem and it is delivered to you. He said that with the change in process, all LRN routing will be based on NPA NXX rather than the full 10 digits.

Luke Mestas-Comcast asked if the 1 LRN per trunk group rule applies to the changed process. Todd Rodgers-Qwest stated No.

Luke Mestas-Comcast said that worked for them and asked how they know what is SRLN routed currently.

Todd Rodgers-Qwest stated that it is best that they work with their Service Manager to determine how the LRN is being routed. He said that if the customer wants to change we can accommodate.

Susan Lorence-Qwest asked if there were any other questions or comments about this change to the process.

Roxanne Hoover-McLeod stated that some of Eschelon/Integra’s concerns made sense and others did not. She said that in the document, it doesn’t describe how this will work. She said that the process states that Qwest will route toll on Local Trunk groups. Roxanne asked if they could route toll traffic to Qwest the same way.

Todd Rodgers-Qwest said in answer to the last question, the answer is no. He said that the change to the LRN process delivers all calls to the service provider and translates on six digits. He said that because of that, Qwest end user’s LPIC’ed to 5123 would follow the same pattern and, therefore, only those toll calls would be delivered over local trunk groups with the caveat that the existing base is diminishing. Todd said that with 271/272 relief, QCC CIC 432 is used for toll traffic and is treated as Feature D traffic.

Roxanne Hoover-McLeod agreed that it is limited. She said it would only be on the NPA NXX of the LRN for a number ported away. Roxanne asked how they get away from the fact that the trunk type is local only. (11/26/07 - Comment submitted by Eschelon) She said that this violates McLeod’s ICA.

Todd Rodgers-Qwest stated that we wanted to be as upfront as possible and describe what “could” happen if a customer requests LRN routing.

Bonnie Johnson-Eschelon stated that unfortunately she did not know that this discussion would require SME attendance. She said that she (11/26/07 - Comment submitted by Eschelon) has an issue with Qwest implementing a Product/Process change (11/26/07 - Comment submitted by Eschelon) that knowingly violates an ICA agreement. She said that Roxanne (McLeod) has the technical expertise and in light of the fact the Eschelon SMEs weren’t on the call, she would depend on the meeting minutes from this call (11/26/07 - Comment submitted by Eschelon) and hope they will be accurate. Bonnie said that this change in process going forward would have a major impact to any CLEC with the 10 digit routing and that there may be major internal changes required to what a CLEC is currently doing. She said that this change should be a Level 4 CR and that they wanted their technical SMEs on a call to understand current routing requirements and any further impacts.

Roxanne Hoover-McLeod stated that she had billing system concerns and that the LRN document does not help. She said that the document is poorly written and confusing and asked Qwest to review and correct the document. Roxanne stated that this will always look like toll in the billing system and could Qwest use class of service screening to separate the traffic. (11/26/07 Comment submitted by Eschelon) She said she knows now what Qwest is doing and doesn’t like it.

Kim Isaacs-Eschelon stated that they have additional questions. Kim stated that this process change should be collaborative and should be discussed in some type of forum – especially if there is to be toll on local trunks.

Todd Rodgers-Qwest stated that the only time there would be toll on local is if the CLEC requests the LRN process. He said that the customer’s LRN will work with little intervention from the customer. He said that the calls will remain as they are today unless the customer requests a change.

Kim Isaacs-Eschelon asked when this change would be required.

Todd Rodgers-Qwest stated that there are no plans on making this a required change.

Bonnie Johnson-Eschelon said that she understood this change would be a requirement on a going forward basis. She said that if they open up collocation in a certain state, what LRN they give.

Todd Rodgers-Qwest said that if you read the LRN document and insert the word “process” after LRN, it makes more sense.

Bonnie Johnson-Eschelon said that she was glad to hear that Mcleod has some of the same concerns with this change.

Susan Lorence-Qwest said that we could have a separate adhoc meeting to continue discussion on these issues and to fully review this change. She said that the comment cycle for this change closes on November 20th. Susan said that we need to decide whether to retract this notice and issue a level 4 or reissue as a level 3.

Bonnie Johnson-Eschelon said that she agreed with McLeod’s recommendation to update the document first. She said that it may lead to different questions and that it is a critical first step in understanding the change taking place.

Susan Lorence-Qwest asked if anyone else on the call besides Eschelon and McLeod had any comments.

Bonnie Johnson-Eschelon said that she would like (11/26/07 - Comment submitted by Eschelon) Qwest to revise the documentation first, and then we may need an adhoc meeting to determine billing impacts and the scope of all impacts to determine if this change warrants a level 4 CR. Bonnie said that she is taking McLeod’s lead regarding the other questions as to their validity or not and that they may come to the same conclusion.

Susan Lorence-Qwest stated that we will take as feedback and regroup internally at Qwest and follow-up with an adhoc meeting to determine how we proceed and determine next steps.