Wholesale: Products & Services

Open Product/Process CR PC120301-4 Detail

Description Of Change

Example #1 (Qwest needs to engineer the entire path (CLEC to CLEC) when the cross-connect is made through the Qwest ICDF). A CLEC to CLEC cross-connect was made with a third party in a Central Office. When the entire lineal footage of the DS3 Circuit was taken into consideration, the DS3 signal was not within ANSI loss level standards. Qwest contends that it will engineer the DS3 cable/signal from the Qwest ICDF to each separate Co-Provider but that it is not responsible for the complete circuit, although all elements involved. (i.e. BNC connectors, ICDF Cross-connect points, and DSX interfaces) contribute significantly to overall signal loss. Since Qwest provisions all three segments of the circuit, Qwest must provision the complete circuit in such a way that meets the ANSI standard.

Project Meetings

Kathleen Stichter, Eschelon Paul Hanser, Eschelon Michael Zulevic, Covad Bill Wycoff, Qwest Jeff Ferra, Qwest Laurel Burke, 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} Clarification was obtained from Eschelon & Covad for the subject CR. The following items were discussed: 1) Paul Hanser, Eschelon identified two (2) types of CLEC to CLEC connections in Qwest CO facilities: 1) direct connection (i.e., no routing through Qwest ICDF; and 2) connection through Qwest ICDF(s). Direct connections, in general, exhibit fewer problems and mainly concern cable lengths and re-generation concerns. Connections routed through a Qwest ICDF(s) usually involve larger Qwest CO facilities that may involve multiple floors and require more detailed assessments of circuit cable lengths, regeneration, ICDF connection losses, and other connector losses (i.e., BNC). Eschelon expressed concern that proper engineering and testing of the end to end portion of the Qwest furnished curcuit (i.e., cabling, regeneration (if required), all related connections) need to be conducted properly prior to "throwing the cables over the fence into the co-location areas." 2) Michael Zulevic, Covad concurred with Eschelon and also requested cable continuity testing and documentation for the Qwest provided portion of the circuit at the conclusion of the construction phase; along with possible collaborative testing during the test & turn-up phase. 3) William Wycoff, Qwest asked Eschelon what signal levels are being transmitted and received from their co-location areas. Paul Hanser, Eschelon indicated that maximum transmit and minimum receive are indicative of signal levels.

3.0 Confirm Areas & Products Impacted {read from change request, modify if needed} N/A. Discussed in previous clarification meeting.

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} N/A. Discussed in previous clarification meeting.

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 generate draft response for CMP Monthly Product & Process Meeting.

-

1:30 p.m. (MDT) / Friday 14th December 2001 Conference Call TEL: 877.564.8688 CODE: 6265401 PC120301-4 "Implement a process to insure Qwest adheres to ANSI Standard T1.102 and ANSI T1.104 for setting signal and loss level standards for DS3 cable length limitations" Clarification Meeting

Kathleen Stichter, Eschelon Renee Lernes, Eschelon Bill Kent, Eschelon Bill Wycoff, Qwest Jeff Ferra, Qwest Laurel Burke, 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 the completed circuit provided by Qwest for CLEC to CLEC cross connect through a Qwest Interconnect Distribution Frame (ICDF) provide a signal level of no less than –4.7 dBm (additional detail in CR). Qwest is responsible for completing the cross connect circuit.

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} None.

CenturyLink Response

Kathy Stichter ILEC Relations Manager Eschelon Telecom Inc

SUBJECT: Qwest Change Request Response - Number PC120301-4 (December 3, 2001) – Implement a process to insure Qwest adheres to ANSI Standard T1.102 and ANSI T1.104 for setting signal and loss level standards for DS3 cable length limitations.

Qwest has responsibility to engineer network elements within its Central Offices (CO) in an efficient manner. Qwest has engineering criteria establishing DSX-N cross-connect fields that are in compliance with ANSI Standard T1.102 for setting signal and loss levels using cable length limitations, signal source level control, and signal regeneration. It is unclear how ANSI Standard T1.104 relates to the signal level question.

To minimize equipment, the ICDF is not engineered as a DSX-N level point. According to Technical Publication 77386 on Interconnection and Collocation, Chapters 5 and 15, the engineering requirement is to design through the ICDF to a DSX-N point when accessing unbundled offerings such as Unbundled Loops, Unbundled Dedicated Interoffice Transport, etc. This principle was established circa 1996 in FCC Docket 93-192.

The CLEC-to-CLEC Cross-Connection (COCC-X) offering is defined as the CLEC’s capability to order a cross-connection from its Collocation in a Qwest Premises to its non-ajacent Collocation space or to another CLEC’s Collocation within the same Qwest Premises at the Interconnection Distribution Frame (ICDF). This is accomplished by the use of the CLEC’s Connecting Facilty Assignment (CFA) terminations residing at the same ICDF and at the same service rate level.

Qwest is providing clarification for the following activities to address this request:

- CLEC ordering procedure for cross-connection; - Qwest engineering data exchange with the requesting CLEC(s) for the cross-connection; - CLEC to CLEC cross connection within the Qwest Central Office (CO); - ICDF connections, and regeneration installation; and - Verification testing.

CLEC Ordering Procedure

CLEC to CLEC cross-connections are ordered through the Qwest EXACT-PC system using the Access Service Request (ASR) form. This form is used for ordering Access and Local Network Interconnection Services. Qwest processes the ASR and determines a ready for service (RFS) date for the connection.

The requesting CLEC(s) is required to assess the need for signal regeneration prior to submittal of the completed ASR form. An engineering data exchange can be arranged through the Qwest Wholesale Collocation Project Manager (http://www.uswest.com/wholesale/clecs/escalations.html)

Qwest Engineering Data exchange with requesting CLEC(s)

The requesting CLEC(s) are required to know the cable types and lengths from their equipment to the ICDF(s) in order to assess the need for signal regeneration. The need for regeneration may arise when the distances between the CLEC’s collocation equipment exceeds twice the cable length limitation criteria (table) when connected through the ICDF. The total cable length limitation from signal source to sink, without a DSX-N point is nominally, two times the shown length.

Qwest will provide the requesting CLEC(s) the type and length of cable between their physical space and the ICDF. Each CLEC uses this information to design the span between their equipment. The design is done to determine any need for regeneration. Regeneration is typically at the ICDF.

[Table in Supplemental Information]

Given the probability of having cable lengths that total less than the maximums, it has been and is the CLEC’s responsibility to set any transmit attenuators in their equipment. Given the possibility that total cable lengths from the Collocation spaces through the ICDF are longer than the table allows, there is the opportunity for a CLEC to request regeneration by using a specific Network Channel Interface (NCI) code on their order. The NCI is chosen from Table 6-5 of Tech Pub 77386 using one that calls for regeneration. CLEC to CLEC cross connects occur between two CLECs within a Qwest CO and use jumper cables at the ICDF to complete the link. There is no assured DSX-N level point in the circuit.

Figure A below illustrates the situation where there is a single, ICDF cross-connect to complete a CLEC-to CLEC circuit that needs a regenerator. There is no DSX-N level point assured in this circuit.

[Figure A in Supplemental Information]

Figure A: Single ICDF Connection with Regeneration

ICDF connections and regeneration installation

Qwest, following receipt of the ASR will perform ICDF connections and regeneration functions. Equipment additions for regeneration (if no spares are available) will be initiated. Qwest completes these activities and conducts verification testing.

Verification testing

Verification testing of the cross-connection will be conducted to assure compliance with the ASR. Cooperative testing on circuits will be conducted with Qwest and requesting CLEC(s) technicians.

Qwest will coordinate with the requesting CLEC and schedule the testing of the completed cabling, ICDF connections and regeneration. CLEC(s) will be responsible to terminate cabling into their respective collocation equipment prior to the testing effort.

Although circuit testing is the responsibility of the CLECs, Qwest will provide technician support of CLEC to CLEC circuit testing efforts and provide trouble-shooting support, as necessary to successfully complete an ASR. Such testing shall confirm that ASR ordered circuits perform to service objectives in ANSI Standard T1.510, Network Performance Parameters for Dedicated Digital Services for Rates Up to and Including DS3. Clauses 8.2 and 8.3 describe DS1 and DS3 testing, respectively.

Sincerely,

William R. Wycoff Services Planning Qwest

CC: Bill Campbell, Qwest Barry Orrel, Qwest Gale Perko, Qwest Mary Retka, Qwest