Wholesale: Products & Services

Open Product/Process CR PC120301-3 Detail

Description Of Change

Example #1 (Labeling of terminations in the CO(s) does not match the APOT information). A DS1 order could not be turned up due to incorrect labeling at the CLEC DS1 Spot Frame. APOT information indicated pairs 1-56 belonging to Eschelon, however, Qwest labeling at the Central Office indicated Pairs 1-28 + 33-60 belonging to Eschelon. Eschelon submitted the pending T1 order with APOT 29 and the order was accepted, indicating a labeling error at the Central Office. Errors such as this confuse the Eschelon Operations group and ultimately cause delays until the labeling issue is resolved/confirmed.

Example #2 (Information on Final APOT sheets sent to Eschelon does not match information loaded in TIRKS/IMA). Eschelon could not process DS0 orders due to incorrect information listed on the Final APOT sheet for a collocation. Eschelon submitted orders under one DS0 Cable name (as indicated on the Final APOT sheet). Qwest database was loaded with another DS0 Cable name. Consequently, Qwest was not recognizing orders issued with the DS0 Cable name identifier as the information did not exist in Qwest's systems. Eschelon helped to resolve the matter by sending its own technicians to the Central Office to verify the labeling of the DS0 Blocks. Eschelon discovered that Qwest labeled the APOT information on the Vertical Blocks differently then indicated on the APOT sheet. Qwest subsequently issued a corrected APOT sheet, two days after the problem was first discovered.

Example #3 (Information on Final APOT sheets sent to Eschelon does not match information loaded in TIRKS/IMA). Qwest rejected orders for an Eschelon Collocation due to what was perceived as an incorrect CLLI Code. Qwest informed the Eschelon Provisioning Group that the CLLI Code Eschelon used was incorrect. Qwest records indicated a different CLLI Code and would not process orders despite the fact that Eschelon used the CLLI Code identified on the Fianl APOT sheet on its orders. A service manager at Qwest helped resolve the issue and explained that the problem was due to internal miscommunication within Order Validation.

Project Meetings

Kathleen Stichter, Eschelon Renee Lernes, Eschelon Karen Kraas, Qwest Laurel Burke, Qwest Barry Orrel, Qwest Peter Wirth, Qwest

1.0 Introduction of Attendees Attendees introduced.

2.0 Review Requested (Description of) Change {review long description from change request, confirm with all parties there is agreement on the change requested} Eschelon presented the CR. Eschelon requested that Qwest provide accurate final Alternate Point of Termination (APOT) data to match TIRKS/IMA databases for correct provisioning of circuits (additional detail in CR). This was requested in order to allow the CLEC to conduct provisioning on advance of the RFS date & provide customer service on the RFS date.

3.0 Confirm Areas & Products Impacted {read from change request, modify if needed} “Collocation” confirmed as appropriate. “Physical” & “ICDF Collocation” boxes under “Collocation” identified during conference call.

4.0 Confirm Right Personnel Involved {ensure the Qwest SME can fully answer the CLEC request. Confirm whether anyone else within Qwest has been involved with this issue, or whether we need to bring anyone else in} Qwest & Eschelon confirmed appropriate personnel were in attendance.

5.0 Identify/Confirm CLEC’s Expectation {Identify specific deliverables from CLEC – what does Qwest have to do in order to close this CR? (in measureable terms ie provide a documented process, change a process to include training etc)} Qwest to evaluate CR. During the January 2002 Monthly P&P CMP Meeting, a CLEC community clarification session will be conducted with Qwest providing potential options for addressing the CR.

6.0 Identify any Dependent Systems Change Requests {Note any connected CRs and the potential impacts} N/A PC120301-2.

CenturyLink Response

Kathy Stichter ILEC Relations Manager Eschelon Telecom Inc

CC: Mary Retka, Qwest

This letter responds to your CLEC Change Request Form, number PC120301-3 dated November 30, 2001 – Implement an adhered to process to provde CLECs with accurate APOT information. Specifically, Eschelon asked Qwest to implement a process and procedure for accurate APOT numbering so that CLECs can be assured that they will be able to provide service without delay to their customers. The change request provided three examples of APOT information provided by Qwest and suggested that the process should include a requirement that Qwest personnel validate APOTs as they are entered into TIRKS.

Qwest previously committed and continues to commit to providing accurate Alternate Point of Termination (APOT) information. We also continue to commit to providing timely resolution of issues relating to information contained on the APOT. To this end, we revised and have implemented several internal processes to verify the accuracy of the APOT. Applicable process changes are addressed below in the context of the examples provided within the Change Request (CR).

- Example 1 describes a situation in which labeling of terminations in the Central Office did not match the APOT information. This job completed in April 2001 and the call to the APOT hotline occurred in November, seven months after the "Ready For Service" (RFS) date. Our investigation revealed that the State Interconnect Manager (SICM) and Eschelon representatives performed a walk through on this job; the APOT contained correct cable count pairs and matched the field cable count; the SICM identified where to connect their side of the terminations. The terminations were labeled correctly and TIRKS also reflects the correct cable count. However, the numbering associated with the jack locations did not match the locations identified on the APOT; for jobs other than ICDF collocations, the jack numbers do not appear on the APOT. Jack locations do not need to match the cable count numbers and in this case, the difference is apparently what caused confusion. This issue was resolved the business day after a call to the APOT hotline. In late June, early July 2001, CPMC personnel reevaluated their quality processes and implemented safeguards to ensure that correct information appears on the APOT; specifically, the state Project Manager is required to confirm that the APOT data matches TIRKS and that the DWP also matches the APOT. A process document (update issued 11/30/2001) reiterates that the Engineer must ensure that the actual installation is accurately reflected in both the APOT and the DWP. Additionally, Engineering revised its job aid on 8/28/2001 describing ICDF collocation engineering and its unique APOT in detail.

- Example 2 involved the inability of Eschelon to process DS0 orders based on incorrect TIRKS information. The APOT resulted from a job that completed in April but no call was made to the APOT hotline. There was a cable name error on the APOT; instead of an "s" the cable name contained a "d." The field and TIRKS correctly showed the "s," but there was a typographical error on the APOT. A revised final APOT was provided to Eschelon the morning of the second business day following the identification of the error to Collocation Project Management Center (CPMC) State Project Manager. Internal processes (updated 9/27/2001 and 11/30/2001) require the Engineer to verify the field installation information against the APOT, TIRKS, the design work package (DWP) as well as check any other affected engineering documents/systems for consistency. As changes are made and needs clarified (from sources such as the APOT hotline), engineering staff review and update the applicable job aids in addition to providing periodic training on issues, including APOT related ones, during monthly staff meetings. As indicated above, the CPMC State Project Manager is also required to manually check and validate that the APOT matches the parameters contained in the DWP. The CPMC audits compliance with this process on a monthly basis.

- Example 3 involved a rejection of orders because the CLLI code appeared to be incorrect on the final APOT. Upon notification of a building addition completion, Eschelon submitted an application for collocation space in the central office and was placed in the central office annex for which the addition had just been completed and for which a new CLLI had been assigned. The service center did not recognize the CLLI code associated with the collocation job (completed in April 2001) because it did not match the address or name of the central office on the order - a new name and physical address had been assigned to the building addition. However, the APOT, DWP and TIRKS were correct for the location of the collocation. The Account Service Manager was contacted and the situation explained sufficiently to allow the orders to process. Some unique situations will continue to arise and need to be addressed individually.

In summary, Qwest understands the concerns that result from order rejection, and has instituted the following measures to provide accurate APOT information:

- Internal process improvements (discussed above and) implemented by the Engineering, CPMC, and TIRKS organizations (effective July 2001);

- Qwest collocation engineering managers regularly provide training on and review of APOT job aids; and

- Continued operation of the "APOT Hotline" (refer to CR 5608156) to quickly and efficiently address any APOT discrepancies that may arise.

Qwest will continue to work with the CLEC community regarding APOT accuracy related issues.

Sincerely,

Laurel L. Burke Staff Advocate, Policy & Law Technical Regulatory Interconnection Planning