Wholesale: Products & Services

Archived System CR SCR030117-1 Detail

• Custom Business Rules were part of the EASE Technical Specifications.

• Normally an update to a Release tech spec requires a CMP CR to be issued and a 73 day system release notice to be sent.

• With a Custom Business Rule update, a customer must either fix the request or the customer is prohibited from populating a field a certain way.

• Since the implementation of EASE ASR in Legacy CenturyLink and Legacy Embarq, a Business Rule update has typically been communicated via a 30 day system notice to customers.

• During the months leading up to the ASR Consolidation project, CenturyLink sent periodic updates (approximately monthly) to Business rules as Revised Tech Specs.

• CenturyLink would like to establish a timeline and notification process to update Business Rules on a 30 day window on an ongoing basis. This will be more in line with other industry providers.

Expected Deliverables/Proposed Implementation Date (if applicable): 6/1/17

Status History

Project Meetings

7/19/17 System CMP Meeting FROM DISCUSSION UNDER ATTACHMENT I Mark Coyne – CenturyLink said that CenturyLink does have an EASE Custom Business Rule update to be implemented in the Point release 2.3 scheduled for August 14, 2017. The initial notification was issued July 14, 2017 and is included in the package. The comment cycle closes on July 24, 2017. If required, the final notification will be issued on July 28, 2017. Mark said as we had discussed, we are using the Event Notification process for EASE ASR Trouble Tickets when error conditions are found. He said we will revisit this CR for moving to a Completed status in the August CMP meeting. Mark asked if there were any questions. There were none.

FROM DISCUSSION UNDER ATTACHMENT L Mark Coyne – CenturyLink said there is one Event notification 9573979 that remains open associated with Customers encountering the EASE edit EQW55. The date for resolution has not yet been determined.

6/21/17 System CMP Meeting FROM DISCUSSION UNDER ATTACHMENT I Mark Coyne – CenturyLink stated that CenturyLink does have an EASE Custom Business Rule update to be implemented in the Point release 2.2 scheduled for July 17, 2017. The initial notification was issued June 16, 2017 and is included in the package on Page 23. The final notification is to be issued on July 3, 2017, if required. Mark recommended that next steps would be to get through one more point release scheduled for July 17 and readdress in the July meeting and consider the CR for closure.

Kim Isaacs – Allstream asked if the dates were different on the Legacy CenturyLink/Embarq notification.

Mark Coyne – CenturyLink stated that he would check and that we were working to ensure notifications from both sides of the business were synced going forward. He said that the date on both notices should have reflected July 17, 2017.

FROM DISCUSSION UNDER ATTACHMENT N Kim Isaacs – Allstream stated that she had checked on the dates for SCR030117-1 and that the date was indeed July 17, 2017.

5/17/17 System CMP Meeting Mark Coyne – CenturyLink said an Ad Hoc meeting was held following the April CMP monthly meeting. He provided an overview of how the meeting had proceeded which included the SME team reviewing some EASE Business Rule examples. There was also a review of multiple notification options available under CMP. Mark said the discussion ended with agreement that the planned approach would be to utilize a Point Release notification for Custom Business Rule updates.

Susan Lorence – CenturyLink then reviewed a document included in the CMP package (on page 32) that had a synopsis of the various CMP notification options for changes to Custom Business Rule as discussed in the Ad hoc meeting. The options reviewed were: an Event notification, an Addendum, a Point Release, and a combined Point Release/Product Process notice. Susan said the Point release notification had been determined as the best fit for a Custom Business Rule update if CenturyLink believes that a business rule is not CLEC code impacting. The Point release could impact CLEC operating procedures. The notice would have a 30 day timeline that includes a 10 day CLEC comment period. If a CLEC identifies during the comment window that a proposed Business Rule change has an impact on their code, CenturyLink will pull the Business Rule from the Point release and include it in the next Major release. Susan said that last month we had discussed sending a trial Point Release system notification that would go out with a shorter timeline with an effective date of May 12, 2017. (See notification number SYST.EASE.04.20.17.F.15529.EASER2.1CustomBusRules included in the package on page 30.) Susan relayed that in the flurry of the responsibilities for the Point release, CenturyLink had missed sending the final notification that was due May 1, 2017 for EASE Release 2.1. She asked if it might be appropriate to eliminate that final notice going forward as long as there were no CLEC comments. With the number of notifications sent by CenturyLink, Susan asked if the final reminder notification was meaningful to customers as a reminder of the upcoming Business Rule effective date.

Kim Isaacs – Electric Lightwave asked if the CMP doc would require a change if no final notification was sent.

Susan Lorence – CenturyLink said no since the Point Release is not well defined in the CMP document and that when we had looked at the timeline used for prior system Point releases, a 30 day timeline had been used. She said the definition of a Point release is only included in the Definition of Terms section of the CMP document.

Kim Isaacs – Electric Lightwave proposed that a reference be included in the initial Point release notice to say that a Final notice would be sent if there were CLEC comments.

There was agreement of the CLECs on the call that we will try this approach for now and revisit if necessary.

Susan Lorence – CenturyLink then relayed the rationale about sending both a Product Process notice and a Point release notice if a Business Rule update impacted CenturyLink external documentation. For consistency, CenturyLink believed it is best to send both notices and make the effective dates the same. There were no concerns expressed with this approach. Since there were no updates required to the CMP document, the CR/meeting minutes would capture this agreed upon approach. Susan asked if there were any other questions. There were none.

4/19/17 Ad Hoc Meeting Minutes FINAL (following the monthly CMP call)

Attendees: Frank Behnke – AT&T Andrea Smith – Comcast Kasha Fauscett – Comcast Jay Bodapati – Custom Call Carl Williamson – Custom Call Kim Isaacs – Electric Lightwave Nancy Taylor – Electric Lightwave Liz Tierney – Global Capacity Joyce Oliveira – Granite Jonathan Kronewitter – Granite Larry Stevens – Iowa Utilities Board Bonnie Johnson – Minnesota Department of Commerce Jeff Sonnier – Neustar Rebecca Byland - POPP Michelle Li – CenturyLink BL Marcom – CenturyLink Nicole James – CenturyLink Tracy Strombotne – CenturyLink Renee Albersheim – CenturyLink Alan Bratetic – CenturyLink George Allen – CenturyLink Letty Walker – CenturyLink Mark Coyne – CenturyLink John Hansen – CenturyLink Susan Lorence – CenturyLink

Susan Lorence – CenturyLink went over the agenda for the meeting and asked if there were any questions. There were none. Susan said we will refer to the various documents that are posted to the calendar as we proceed with the call.

Mark Coyne – CenturyLink then provided a review of what is included in the Description of the Change Request (CR). Mark said the CenturyLink proposal for how to notify of a Custom Business Rule (CBR) change would be to send a system notice and to post the proposed changes to the CMP Document Review site. The notice would include a 10 day window for customer comment. Any CLEC could then identity if any proposed business rule update posed any CLEC coding impacts. The rule would then be discussed/moved to a Major release.

Kim Isaacs – Electric Lightwave asked what the following two points had to do with the CR: 1) the CBR being part of the Technical specifications, and, 2) that CBR updates were sent approximately every 30 days in preparation for the Access Consolidation. Kim said she was clear that during the Access Consolidation project, there were special circumstances and she did not think the two points made any difference to this CR.

Mark Coyne – CenturyLink said he agreed the Access Consolidation project did have special circumstances but that CenturyLink thought the two points had worked well and that we could possibly consider them to see how we could move forward.

Kim Isaacs – Electric Lightwave said she did not agree and that there were so many problems with the CBR, there was no other option. Kim said CenturyLink releases need to be correct during the time leading up to the release and that customer impacts needed to be minimized between releases. With the use of a 30 day system notice, there is no incentive for CenturyLink to get it right the first time.

Mark Coyne – CenturyLink said the CenturyLink desire is to always get the release correct the first time. The 30 day notice would not be a detriment.

Kim Isaacs – Electric Lightwave asked how often CORA or IMA had Point releases or Addendums. Kim said we are talking about systems that are “like for like” including release quality.

Mark Coyne – CenturyLink said he was OK taking the points out. The intent of the CR is to send CBR updates that will improve processing for both CenturyLink and the customer.

Kim Isaacs – Electric Lightwave asked why the CBR updates could not be part of the major release unless they are associated with coding or documentation problems. She said it is very disruptive to have customers have to review changes between releases. Kim said the expectation is that there should be very few changes between EASE releases and that EASE needs to use the options provided for in CMP and not be treated differently.

Susan Lorence – CenturyLink said that the first statement that Kim was questioning regarding CBRs being part of the technical specifications was included because the updates were posted with the XML technical specifications. Susan said the other point was included as part of historical reference.

Kim Isaacs – Electric Lightwave said she felt the second point was included to skew the discussion.

Susan Lorence – CenturyLink said we could take the second point out but the first point was to capture that the CBR are not part of the Product Process documentation but part of the EASE technical specifications.

Kim Isaacs – Electric Lightwave said maybe CBR updates should be considered like the ASOG.

Mark Coyne – CenturyLink said the intent is not to send CBR updates every 30 days and maybe we should look at some examples.

Kim Isaacs – Electric Lightwave said she understands the content of the CBRs and that is not the issue. The issue is EASE needs to follow CMP and there are ways to do that and fix any errors. Kim said she would not agree to a system courtesy notice.

Mark Coyne – CenturyLink said in the March CMP meeting, that point was made to use what exists in CMP but before going through that information, we should take some time to review some CBR examples for the benefit of all those on the call.

Susan Lorence – CenturyLink asked call participants to open the third document posted to the Wholesale calendar which were examples of the types of CBR updates to be sent on a 30 day notice. Susan asked Letty Walker - CenturyLink to include in the discussion what would happen before the EASE rule was included and after it was included.

Letty Walker - CenturyLink said the CBRs that she would discuss were related to ASOG not LSOG changes. She then reviewed the HBAN example and said this rule was to be added to perform an upfront edit. Letty said if this HBAN rule was not there, a problem would be caused at the point of FOC. The customer would receive a CNR which would require an order to be supp’d and the provisioning process would have to be restarted. By adding the HBAN CBR, the provisioning process would not be delayed.

Kim Isaacs – Electric Lightwave asked why this was not an existing edit.

Letty Walker - CenturyLink said this was not an ASOG edit. Letty said she understood why Kim was requesting to stick with two releases a year but in this case, waiting for the next release could impact a lot of customers/ASRs.

Kim Isaacs – Electric Lightwave said she wanted to talk about how this was handled in CORA and said she thought this type of CBR would have been added as part of the normal 73 day CORA release notice.

Michelle Li - CenturyLink said she could speak to the release process for both CORA and EASE. Michelle said with EASE, the IT team also does the upfront analysis to add new CBRs with the ASOG release. With CORA, there were also some last minute business rule changes for a release. When that occurred, a point release would be used.

Kim Isaacs – Electric Lightwave said that is how she would like EASE to be handled. She said she understands there can be mistakes but the request is not to disrupt users with interim changes.

Susan Lorence – CenturyLink asked if this type of HBAN CBR change would disrupt ELI today if they already had an edit that required the correct number of HBAN characters. Susan asked if it would require code to be changed.

Kim Isaacs – Electric Lightwave said no.

Susan Lorence – CenturyLink said the reason that CenturyLink wanted to put this rule in is to assist other customers with fewer errors. Susan said by the time we converted from CORA to EASE, CORA was a mature system with lots of up front edits established. EASE is new and we are still adding some of those edits.

Mark Coyne – CenturyLink asked if the issue is really that Electric Lightwave does not want to establish a new 30 day notification process vs. making these changes to EASE.

Kim Isaacs – Electric Lightwave said yes that is true. Kim said she wants to use the existing CMP. When a change comes in mid release, the change has to be communicated internally and typically that would have to happen via email. Kim said why not handle these changes like a Product Process change similar to the LSOG.

Mark Coyne – CenturyLink said it is important to keep in mind that there will be these types of changes mid release.

Letty Walker - CenturyLink then reviewed the next CBR example for EVCSP which was a similar circumstance to the HBAN edit. The CBR is being added for those customers that do not have robust edits up front; with this rule added, the provisioning process is not stopped. Letty then reviewed the next two rules which were not candidates for a CBR update but would instead require a major release and coding changes. Letty then reviewed the CBR rule for the LV3 field to not exceed 12 characters. She said a customer was having problems; this custom rule was added to prevent orders from being submitted incorrectly.

Susan Lorence – CenturyLink said these are examples of existing rules but asked if anyone had any questions about how these would have been handled. There were none. Susan then asked those on the call to open the fifth document posted to the calendar to review the additional two rules that were added in red.

Alan Bratetic – CenturyLink then reviewed the CTLV0204 rule having to do with Supps. Alan said this rule mirrors an existing rule in CORA to prevent someone from supping an ASR with a very extended date.

Kim Isaacs – Electric Lightwave asked why this CBR was not included with the Consolidation release.

Alan Bratetic – CenturyLink said he did not know how it was missed as part of the Consolidation.

Kim Isaacs – Electric Lightwave said this is an interesting CBR. Kim said there was a Product Process notice to implement this change and the notice could have indicated that a new CBR would also be added. Kim said the existing CMP could be used to handle this vs. a 30 day system EASE notice.

Alan Bratetic – CenturyLink then reviewed the next CBR example for CTLV0204 having to do with Supps and the VER field.

Kim Isaacs – Electric Lightwave said she did not understand why this was not an existing rule in EASE and said an Addendum could have been used to update the CBR or it could have been sent as a Level 2 Product Process change.

George Allen – CenturyLink then reviewed the following CBR change: Only allow capital letters for the following fields: ACTL, FACTL, SECLOC, CFA, SCFA, ECCKT, RECCKT, and occurrences of these fields on ACI forms. If any of these fields are populated without upper case letters EASE will reject back with: Error code=EQ289; Error message=UPPERCASE CHARACTERS REQUIRED. George said this rule will prevent a time delay on an order and a CNR back to the customer due an error in TIRKS.

Kim Isaacs – Electric Lightwave said this CBR was asked for during the transition and said she did not understand why it was not already included.

Susan Lorence – CenturyLink said George can look into why it had not been included with the Consolidation release. Susan then referred those on the call to the fourth document posted to the calendar that identified two notices sent in by Kim that were not sent by Legacy CenturyLink with a 30 day lead time.

Mark Coyne – CenturyLink said the first example is a CBR associated with an edit that was already occurring in Legacy Qwest. Since this was a benefit to customers, Legacy CenturyLink wanted to let customers know that the supp logic was available.

Kim Isaacs – Electric Lightwave said the reason that these examples were sent to CenturyLink was due to the March meeting where someone said that Legacy CenturyLink followed a 30 day timeline.

Mark Coyne – CenturyLink said that is correct and that no process is perfect. Mark then reviewed the next Electric Lightwave example. This notice was truly a “miss” on the part of the SME team but though they missed the 30 day notification window, since the change was not a big change nor a significant product, the Legacy CenturyLink team decided to let the release go as scheduled.

Susan Lorence – CenturyLink then referred those on the call back to page two of the first document from the calendar entry. She said she had reviewed the CMP document looking for existing System processes that could be used for the CBR update. Though Kim had mentioned using a Product Process notification for some of the rules changes, Susan said she specifically did not consider a CBR update as a Product Process level 1, 2 or 3 notice type since the SME team considers the CBR updates as part of the EASE technical specifications.

Kim Isaacs – Electric Lightwave said with IMA on the LSOG side, the notification is sent as a Product Process change but the LSOG rules appear as part of the technical specifications. She said she did not understand the difference in handling and thought it would provide more flexibility with anywhere from a one day to 45 day timeline.

Mark Coyne – CenturyLink said we would look into that.

Susan Lorence – CenturyLink then reviewed the system notification options available under CMP starting with Section 8 - Change to an Existing OSS Interface and using the approach of a Point release. Susan reviewed the wording under the Definition of Terms which indicates that a Point Release “may not be CLEC code impacting, but may affect CLEC operating procedures. The Point Release is used to fix bugs introduced in previous Releases…” Susan referred to some examples of some Point releases that have occurred previously that had used a 30 day notice timeline. A Point release is typically included on the OSS Interface calendar and Susan questioned if we went with this approach, would we be adding to the OSS calendar each month.

Kim Isaacs – Electric Lightwave said that she thought this is a viable approach without treating EASE differently.

Susan Lorence – CenturyLink said we thought that to be true also. Susan then reviewed the option of considering the CBR update as an addendum update under Section 8.1.7 Release Documentation Addenda of CMP. She said this did not seem like a good fit since the first addendum is typically sent two weeks after the release is installed and is effective immediately which does not provide customers any time to react.

Kim Isaacs – Electric Lightwave said an addendum is typically for something found during the CLEC comment cycle or during testing.

Susan Lorence – CenturyLink said the addendum is normally associated with a problem with documentation and that we did not feel this was a good fit either.

Kim Isaacs – Electric Lightwave said it is good for the EASE representatives to understand the Addendum option is available for a documentation correction.

Susan Lorence – CenturyLink then reviewed an option associated with handling a CBR update as a trouble ticket under Section 12.0 - Production Support in the CMP document. She said an Event notification is for “trouble found”. An Event notification can be opened and closed on the same day or it can be effectively immediately when the SME team determines the fix. Susan said there is also a problem with the distribution list for an Event notification since only a relatively small percentage of customers have signed up to receive them and the recipients on an Event notification are generally technical. The CenturyLink distribution list for “Mailout” notifications is more robust. CenturyLink did not think this was a good fit either.

Kim Isaacs – Electric Lightwave said she understood.

Susan Lorence – CenturyLink then reviewed the second attachment on the Wholesale calendar of system Point release notifications from 2002, 2008 and 2009. She asked if there are any questions about these options or examples of notifications. There were none. Susan asked if there were any options within CMP that anyone thought should be considered, such as the Product Process change.

Kim Isaacs – Electric Lightwave said the Point Release notification seems doable.

Mark Coyne – CenturyLink asked about the Point release and the Definition of Terms which includes the following wording: The Point Release is used … to make changes to the GUI, and/or deliver enhancements to IMA disclosed in a Major Release that could not be delivered in the timeframe of the Major Release. Mark said he wanted to make sure that with the “and/or” wording associated with disclosure with a major release, he did not think that always had to apply.

Kim Isaacs – Electric Lightwave said she agreed.

Mark Coyne – CenturyLink said we have some CMP work to compile an approach that considers the Point release and a possible combination with a Product Process change similar to how we handle LSOG changes.

Susan Lorence – CenturyLink asked if she was the only one questioning whether it was good to have a mixed approach between a Product Process and a system notification. She said the CBR updates are considered to be part of the technical specifications.

Kim Isaacs – Electric Lightwave said it would be easier if there was consistency.

Mark Coyne – CenturyLink said he wanted to keep all the options open especially when considering a time when IMA will be part of EASE.

Susan Lorence – CenturyLink said it sounds like if the CBRs follow the approach laid out under the Point release, we would typically follow that. But if there was a significant process or documentation change associated with a CBR update, at that point we could send a Product Process notice. It would not likely be a Level 1 change (effective immediately); more likely, the change would be a Level 2 notice (21 day timeline) or a level 3 notice (anywhere from 31 to 45 day timeline).

Kim Isaacs – Electric Lightwave brought up the example of the Product Process change associated with the 30 day change having to do with Supps and said the process change was the driver behind the CBR updates. Kim said there were significant documentation updates.

Susan Lorence – CenturyLink asked those on the call if there were any other options within CMP that had not been discussed. There were none. She said we would try to capture the distinctions in the meeting minutes between when a Point Release vs. a Product Process notice would be used. She then relayed that we had hoped to send a trial notification with a 30 day timeline for the CBR updates that Alan Bratetic and George Allen from CenturyLink had reviewed. That effective date would have been May 12, 2017. When we moved the Ad Hoc meeting to today, we no longer have 30 days and asked if those on the call would still allow that shorter effective date.

Kim Isaacs – Electric Lightwave said she was OK with the shorter timeline for these rules.

Susan Lorence – CenturyLink said we will then go with a trial Point release system notification putting the CBR on the Document review site.

Kim Isaacs – Electric Lightwave said this is a good solution.

Susan Lorence – CenturyLink asked if there were any comments from customers or commission representatives.

Liz Tierney - Global Capacity said that Kim had spoken well for the group.

Bonnie Johnson – MN DOC said she is comfortable as long as the CLECs are.

Susan Lorence – CenturyLink thanked everyone for the great discussion and coming to agreement on a planned approach.

The Ad hoc meeting was adjourned at 10:30 AM MT.

4/19/17 System CMP Meeting Mark Coyne – CenturyLink said this CR was presented in the March meeting and there had been lots of discussion. An Ad Hoc meeting is scheduled to immediately follow this monthly Systems CMP meeting. The Wholesale calendar has the information associated with the Ad hoc call.

3/15/17 System CMP Meeting Mark Coyne – CenturyLink presented this new CenturyLink CR associated with proposing that EASE Business Rules be updated with a 30 day system Courtesy notice outside of the major release schedule. These types of business rule updates would be non ASOG related. He said Legacy CenturyLink and Legacy Embarq typically communicate these types of business rule updates via a 30 day notice. Mark said prior to the ASR Consolidation, CenturyLink was sending updates to Business rules approximately every 30 days. The predominant types of update to Business Rules in this scenario would be to allow a cleaner order to come in thus eliminating errors up front and downstream. Mark said CenturyLink would like to establish agreement on a timeline and process to allow updates to Business Rules with a 30 day notification cycle.

Kim Isaacs – Electric Lightwave asked if these business rule updates would require a coding update on the customer side.

Mark Coyne – CenturyLink said the intent is that the BR update would not require customer coding however he said CenturyLink does not always know that. With that in mind, Mark said CenturyLink is proposing a 10 day “safety net” up front for customers to identify if they have concerns with a specific BR change. If there was a customer concern, we would revert to a 73 day timeline for those situations.

Kim Isaacs – Electric Lightwave asked how CORA handled this type of change.

Mark Coyne – CenturyLink said these types of changes were included in a major release.

Kim Isaacs – Electric Lightwave asked if such a change as this would require the CMP document to be updated.

Mark Coyne – CenturyLink said possibly. He said we could consider adding a NOTE to call this out as an exception to the 73 day notification timeline.

Susan Lorence – CenturyLink said we did not want to call out a specific application in the CMP document since we would eventually like to handle the EASE LSR business rules changes in a similar fashion. Susan said we thought presenting the change as a CR and tracking it would capture whatever approach that is agreed upon.

Kim Isaacs – Electric Lightwave said she has some reservations with this. Kim said the previous CORA notification process eliminated a lot of unintended consequences. The CenturyLink CMP process works the best as compared to other companies she deals with. Kim said there may be ways to consider this type of customer communication under the current CMP document.

Mark Coyne – CenturyLink said he understands her concerns but was hoping for consideration of a fresh approach similar to the Legacy CenturyLink approach which seems to be working fine.

Kim Isaacs – Electric Lightwave said it is does not work as well on the EASE L-CenturyLink side.

Mark Coyne – CenturyLink asked if you have provided any feedback to Legacy CenturyLink.

Kim Isaacs – Electric Lightwave said there is no (3-24-17- Updates received from Electric Lightwave in CAPS) LEGACY CENTURYLINK CMP to provide feedback. Kim said the Legacy CenturyLink notification cycle is all over the map varying in the number of days lead time for a change. INSTEAD OF ADOPTING THE LEGACY CENTURYLINK NOTIFICATION PROCESS EASE ASR, she said a better approach is to improve the Legacy CenturyLink process.

Letty Walker – CenturyLink asked Kim for an example of an ASR notification that was less than 30 days.

Kim Isaacs – Electric Lightwave said she could not readily do that but would provide some examples. (3-24-17- Updates received from Electric Lightwave in CAPS) NOTE 3/24/17 – KIM ISAACS/ELECTRIC LIGHTWAVE EMAILED CENTURYLINK TWO RECENT EXAMPLES OF ASR NOTIFICATION SENT WITH LESS THAN 30 DAYS.

Letty Walker – CenturyLink said an example would be helpful since she was not aware of any notifications less than 30 days. Letty said if there is a problem with a BR, CenturyLink is stuck with a 73 day cycle now.

Kim Isaacs – Electric Lightwave said under CMP, if there is a problem there are other options and that it could be considered a defect.

Letty Walker – CenturyLink suggested this discussion be taken offline.

Kim Isaacs – Electric Lightwave said the CMP meeting is the correct forum to discuss any changes since it impacts all customers.

Mark Coyne – CenturyLink said it is best that CenturyLink schedule an Ad Hoc call to discuss this. It would allow both CenturyLink and CLECs to gather some examples of this type of change in the past and scenarios going forward. Mark said we can consider an Event notice or an addendum but the main consideration is to get non-code impacting changes in more quickly which would benefit both CenturyLink and customers.

Kim Isaacs – Electric Lightwave said it will be difficult to vote to change the CMP document that has worked well for many years. Kim said it could be considered a loss of functionality. She said it needs to be evaluated and voted on by all customers.

Mark Coyne – CenturyLink said we really want to hear from other customers also – either on the call today or by sending in their views to CMPCOMM@centurylink.com. Mark said we will set up an ad hoc call to discuss this further.

Susan Lorence – CenturyLink said the key to understanding this proposed change might be to consider examples of the types of changes CenturyLink is proposing with a 30 day notification timeline.

Kim Isaacs – Electric Lightwave said she believes there are options in the CMP document that should be considered, e.g., addendums and event notifications (3-24-17- Updates received from Electric Lightwave in CAPS) WHICH WOULD ALLOW CENTURYLINK TO MAKE EASE ASR BUSINESS RULE UPDATES WITH LESS THAN THE 73 DAY CYCLE. IN THE MERGER CONDITIONS CENTURYLINK AGREED TO USE THE QWEST CMP PROCESS GOING FORWARD, JUST BECAUSE CORA WAS TRANSITION TO EASE A LEGACY CENTURYLINK SYSTEM DOES NOT MEAN CENTURYLINK CAN CHANGE THE CMP PROCESS.

CenturyLink Response