Wholesale: Products & Services

Open Product/Process CR PC120213-1 Detail

Description Of Change

Integra requests the following changes to the Poles, Ducts and Right of Way process:

1. Automatic Refund of Excess Make Ready Charges; currently when CenturyLink’s actual Make Ready costs are less than the Make Ready charges paid by the CLEC, CenturyLink requires that the CLEC request a refund within 60 days. Integra requests a change in the existing process which would require that CenturyLink automatically refund (via check or credit) excess Make Ready charges paid by the CLEC.

Expected Deliverables/Proposed Implementation Date (if applicable):

Upon completion of this change request, Integra expects that;

1. CenturyLink with automatically refund (via check or credit) any excess Make Ready charges paid by the CLEC

[NOTE: After discussion in the January

2014 CMP meeting, CR PC120213-1 is being split into three related CRs to address each of the requested changes separately. Related CRs are PC120213-2 and PC120213-3]

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12-2-13 Original CR: Integra requests the following changes to the Poles, Ducts and Right of Way process:

1. Automatic Refund of Excess Make Ready Charges; currently when CenturyLink’s actual Make Ready costs are less than the Make Ready charges paid by the CLEC, CenturyLink requires that the CLEC request a refund within 60 days. Integra requests a change in the existing process which would require that CenturyLink automatically refund (via check or credit) excess Make Ready charges paid by the CLEC.

2. Extension of Inquiry Review Quote Acceptance Interval; Under the current process, a CenturyLink CenturyLink Inquiry Review quote is valid for only 30 days from the date the CLEC receives the quote. Integra requests that the quote acceptance interval be extended to a minimum of 90 days.

3. Monitoring of Approved CenturyLink Contractors during CLEC Field Verification; CLECs have the option of using a CenturyLink approved contractor when conducting Field Verifications for underground facilities. CenturyLink’s current practice is to have a CenturyLink employee monitor the contractor (already approved by CenturyLink) at the CLECs expense. Integra requests a change in the policy, if CenturyLink feels it is necessary to monitor contractors they have previously ”approved” then CenturyLink should not charge the CLEC for the monitoring.

Expected Deliverables/Proposed Implementation Date (if applicable):

Upon completion of this change request, Integra expects that;

1. CenturyLink with automatically refund (via check or credit) any excess Make Ready charges paid by the CLEC

2. CLECs will have a minimum of 90 days to accept an Inquiry Review quote.

3. When CLEC choses to use a CenturyLink approved contractor to complete a Field Verification for underground facilities, CenturyLink will not require the CLEC to pay for the monitoring of the approved contractor.

Project Meetings

3/19/14 Product/Process CMP Meeting Mark Coyne – CenturyLink said the CenturyLink SME team is still evaluating this CR and is considering the volume of this type of activity. We hope to send the draft response for the April meeting. Mark asked if there were any questions. There were none.

2/19/14 Product/Process CMP Meeting Mark Coyne – CenturyLink said this is the first of the three requested changes by Integra on the original CR. Mark said a draft response was sent on February 12 indicating this CR is still being evaluated and that we hope to have an answer by the March meeting. Mark asked if there were any questions. There were none.

1/15/14 Product/Process CMP Meeting Mark Coyne – CenturyLink relayed that the CR was presented last month by Kim Isaacs – Integra and that the CenturyLink SME team is still investigating each of the three proposed changes. Mark said that we would like to propose that we break the CR up into three separate but related CRs as we continue to move forward in our investigation.

Kim Isaacs - Integra said that was not a problem.

12/11/13 Product/Process CMP Meeting Kim Isaacs - Integra presented the new CR which requests three process changes associated with Poles, Ducts and Right of Way (PDR) as listed in the CR. Kim asked if there were any questions. There were none.

Mark Coyne – CenturyLink relayed that a clarification call had been held on December 9, 2013 and that the meeting minutes from the call would be posted soon. Mark said the CR would be moved to Presented status and the SME team would be evaluating the proposed changes.

12/9/13 Clarification Call Meeting Minutes Attendees: Kim Isaacs – Integra Laurie Roberson – Integra Susan Lorence-CenturyLink Mark Coyne-CenturyLink John Hansen-CenturyLink Steve Karpowich-CenturyLink Rita Urevig-CenturyLink Maggie Burgoyne-CenturyLink Cindy Schwartze-CenturyLink Tammy Meyer-CenturyLink

Susan Lorence – CenturyLink introduced the call and explained the purpose of the call. She asked Kim Isaacs from Integra to present the Change Request (CR). She suggested that they present the change and the deliverable at the same time for each of the three issues included in the CR.

Kim Isaacs-Integra presented the first issue which was the automatic refund of excess Make Ready costs.

Susan Lorence-CenturyLink asked for clarification as to where the current process was documented and wanted to confirm if it was in the Interconnection Agreement (ICA).

Kim Isaacs-Integra confirmed. She explained that all three of these issues were items that the CenturyLink ICA negotiators had asked Integra to bring through CMP.

Susan Lorence-CenturyLink asked for other questions; there were none. Susan clarified that the request is for customers to not have to initiate any excess amount of Make Ready charges and that CenturyLink would automatically issue the excess credit amount. She also clarified that it is unclear whether the current process was a check or a credit.

Kim Isaacs-Integra said that she thought the current process was only that a credit was available.

Susan Lorence-CenturyLink asked if Integra was insistent on receiving a check instead of a credit.

Kim Isaacs-Integra stated that she felt they would be willing to accept a credit if it was going to be automatic and a check would become an issue. She then presented the second item in the CR. She stated that they would like the quote to remain open until a resolution was reached, but that as a compromise, a minimum of 90 days would be sufficient.

Susan Lorence-CenturyLink reiterated that the current process only kept the quote open for 30 days and once that had elapsed; the process had to begin anew.

Kim Isaacs – Integra concurred.

Susan Lorence-CenturyLink asked if the CenturyLink SMEs had any questions. There were none.

Kim Isaacs – Integra presented the third and final issue in the CR.

Mark Coyne-CenturyLink asked how that was billed.

Kim Isaacs – Integra responded that it was billed Time and Materials. She stated that there was a CLEC Field Verification Option but that they had to use a CenturyLink-approved contractors and an employee to watch the contractor.

Susan Lorence-CenturyLink asked if it was in the ICA.

Kim Isaacs – Integra said that it was and that there was something in the PCAT, but nothing about the payment requirement.

Susan Lorence –CenturyLink stated that rates and charges were outside the scope of CMP, but that this had process change implications.

Kim Isaacs – Integra said the issue is really the need for monitoring.

Susan Lorence –CenturyLink asked if there were other questions from CenturyLink SMEs. There were none. She concluded the meeting by reminding Integra that they would present the CR at the next CMP meeting on Wednesday, December 11, 2013. She also asked if the CR could be split into three different CRs if necessary.

Kim Isaacs – Integra said that she felt initially that would not be an issue.

Susan Lorence-CenturyLink concluded the call at 9:16 AM MT.

CenturyLink Response

Kim Isaacs, Integra

SUBJECT: Integra CR PC120213-1, DRAFT RESPONSE for Review This letter is in response to CLEC Change Request PC120213-1, Updates to the Poles, Ducts and Right of Way Process -Automatic Refund of Excess Make Ready Charges

CR Description: Integra requested the following change to the Poles, Ducts and Right of Way (PDR) process: Automatic Refund of Excess Make Ready Charges. Currently, when CenturyLink’s actual Make Ready costs are less than the Make Ready charges paid by the CLEC, CenturyLink requires that the CLEC request a refund within 60 days. Integra requests a change in the existing process which would require that CenturyLink automatically refund (via check or credit) excess Make Ready charges paid by the CLEC. Upon completion of this change request, Integra expects that CenturyLink will automatically refund (via check or credit) any excess Make Ready charges paid by the CLEC.

NOTE: This specific change was originally one of three requested changes on Integra CR PC120213-1. After discussion in the January 2014 CMP meeting, CR PC120213-1 was split into three related CRs to address each of the requested changes separately. This CR now only addresses the first of the three requested changes related to the Make Ready Process.

History: A clarification meeting was held on December 9, 2013 with Integra and CenturyLink representatives in attendance. The CenturyLink SME team has completed an analysis of the requested change associated with the PDR Make Ready Process.

CenturyLink Response: After consideration of the requested PDR change, CenturyLink is denying this Integra Change Request to automatically refund (via check or credit) any excess Make Ready charges paid by the CLEC on the grounds that there is no reasonably demonstrable business benefit or significant customer improvement benefit. During the SME team investigation, they found the volume of this type of situation is relatively low. The SME team determined that rarely do the CenturyLink quotes come back under the Make Ready charges paid by the CLEC so there is typically nothing left to refund. In addition, the SME team found no instances of this Excess Make Ready Charge refund situation specific to Integra. If Integra can show some recent examples of this situation, the SME team will reconsider this change request further.

Sincerely, Susan Lorence CenturyLink Wholesale CMP Project Manager 402 422-4999

February 12, 2014 Kim Isaacs Integra

SUBJECT: Integra CR PC120213-1, DRAFT RESPONSE for Review

This letter is in response to CLEC Change Request PC120213-1, Updates to the Poles, Ducts and Right of Way Process - Automatic Refund of Excess Make Ready Charges

CR Description: Integra requested the following change to the Poles, Ducts and Right of Way (PDR) process: Automatic Refund of Excess Make Ready Charges. Currently when CenturyLink’s actual Make Ready costs are less than the Make Ready charges paid by the CLEC, CenturyLink requires that the CLEC request a refund within 60 days. Integra is requesting a change in the existing process which would require that CenturyLink automatically refund (via check or credit) excess Make Ready charges paid by the CLEC.

NOTE: This specific change was originally the first requested change included on Integra CR PC120213-1. After discussion in the January 2014 CMP meeting, CR PC120213-1 was split into three related CRs to address each of the requested changes separately.

Upon completion of this change request, Integra expects that CenturyLink with automatically refund (via check or credit) any excess Make Ready charges paid by the CLEC.

History: A clarification meeting was held on December 9, 2013 with Integra and CenturyLink representatives in attendance.

CenturyLink Response: The CenturyLink SME team is still completing an analysis of this requested change associated with the PDR Process. We hope to be able to share our response in the March CMP meeting.

Sincerely,

Susan Lorence CenturyLink CR Project Manager