Wholesale: Products & Services

Archived System CR SCR052604-01 Detail

Status History

Project Meetings

Jeff Sonnier/Sprint thanked Qwest for contacting Sprint prior to this meeting with the updated response. Jeff stated that he was okay with the response but has not experienced frustration or used the Shared Collocation. Jeff asked if any other CLEC used Shared Collocation yet and is the process working. Liz Balvin/MCI stated that MCI has multiple entities and does place orders on behalf of and uses the LOA. Liz said that the order is sent in with a remark ‘this is a Brooks Facility’ even though is MCI. Cindy Buckmaster/Qwest stated that example would be on the ASR side and that we did not block on the Wholesale side. Liz Balvin/MCI asked if it could be done on loops or local. Jeff Sonnier/Sprint said that the order is rejected. Cindy Buckmaster/Qwest said that the CLECs should work a business agreement between them without involving Qwest to gain that authorization. Liz Balvin/MCI agreed that the LOA is for EDI. Liz asked if the edit can be re-done on the Wholesale side. Cindy Buckmaster/Qwest said that we looked at that option and that it can’t cost effectively be done. Cindy said that Qwest needs to prevent CLECs from inadvertently connecting to the wrong CFA. Cindy said Qwest’s involvement would be manual and that it would be very expensive and would not flow through. Cindy Buckmaster/Qwest stated that Sprint could contact Steve Nelson/Qwest if they had questions on the Shared Collocation option. This CR will be closed.

6/17/04 Systems CMP Meeting

Jeff Sonnier/Sprint reviewed the description of this CR. Jeff stated that Sprint is requesting that Qwest’s system be changed to allow a CLEC to order UNE based services (DS0, DS1, DS3) into a 3rd party ACTL (CLEC Co-location). Jeff stated that their orders are getting rejected because the ACNA does not match the ACTL. Liz Balvin/MCI stated that she thought that they should have the ability to do this today. Liz said that MCI has partners with an LOA stating that other Companies can use MCI’s ACNA. Jeff Sonnier/Sprint said that is not what Sprint is looking for with this request. Jeff stated that Sprint wants to use the Sprint ACNA and the 3rd party ACTL. Jeff said that the coordinating company uses their own ACNA because that is where the bill goes. Jeff said that he can’t use a dummy ACTL for the cage. Susie Bliss/Qwest stated that Qwest needs to research this request further. This CR will move to Pending Prioritization.

6/9/04 Clarification Meeting

Attendees: Jeff Sonnier - Sprint, John Gallegos - Qwest, Lori Langston - Qwest, Sami Hooper - Qwest, Conrad Evans - Qwest, Joy McConnell - Qwest, Robyn Libidia - Qwest, Steve Nelson - Qwest, Lillian Robertson - Qwest, Lynn Stecklein - Qwest, Peggy Esquibel-Reed - Qwest

Review Description of Change Jeff Sonnier - Sprint reviewed the description of the CR. Sprint is requesting that Qwest’s system be changed to allow a CLEC to order UNE based services (DS0, DS1, DS3) into a 3rd party ACTL (CLEC Co-location). Today, Sprint has authorization to order special access circuits via the ASR and UNE based services via the LSR into a 3rd party CLEC Co-location ACTL. Unfortunately, the Qwest LSR systems and process do not allow this type of order. Sprint requests the same type of process for UNE based services via the LSR. In discussions with Qwest, this cannot occur today because the Qwest system checks to ensure that the ACNA (UTC/Sprint) matches the 3rd Party CLLI in the ACTL field. Since these two fields do not match, the order is rejected. It is therefore requested that Qwest systems be changed to allow UNE based services to be processed via the LSR using a 3rd party ACTL.

Jeff Sonnier - Sprint stated that this is available on Access and would like to have on UNE.

Steve Nelson - Qwest asked if any other ILECs offer unbundled elements from another collocation site.

Jeff Sonnier - Sprint stated that SBC allows in the SW Bell area. Pac Bell allows. Verizon West allows and Verizon East is in re-looking at the process

Steve Nelson - Qwest asked how the CLECs know that they have an agreement with COs.

Jeff Sonnier - Sprint stated that they have a blanket LOA with Sprint and 3rd party Carrier with a list of Cos where there are cages.

Steve Nelson - Qwest asked how billing was handled and asked if other CLECs bill the submitter of the LSR or the 3rd party CLEC.

Jeff Sonnier - Sprint stated that he was not sure but if Sprint submits the order, Sprint is billed.

John Gallegos/Qwest stated that it is billed to the ACNA Company and asked if Sprint wanted the capability to go under a different ACNA.

Jeff Sonnier - Sprint said that they want to order service under UTC with the ACTL of the 3rd party provider.

Lillian Robertson - Qwest asked if UTC will find a CLEC with a cage and the End User will terminate in a 3rd party cage.

Jeff Sonnier/Sprint said yes and that the order is rejected due to an edit (ACNA not matching collocation

Discussion

Confirm Areas and Products Impacted Jeff Sonnier - Sprint stated that the interface impacted is IMA Common and for the UNE product.

Establish Action Plan Lynn Stecklein/Qwest stated that this change request will be presented by Sprint in the June 17, 2004 Systems CMP Meeting.

CenturyLink Response

DRAFT RESPONSE For Review by the CLEC Community and Discussion at the July 2004 CMP Meeting

Jeff Sonnier Sprint

SUBJECT: Qwest’s Change Request Revised Response SCR052604-01 Ordering UNE based Services via 3rd Party CLEC Co-location ACTL

In this request, the CLECs are requesting to be able to place an order for UNEs using another CLEC’s CFA.

This request is respectfully denied due to No Measurable Benefit to both Qwest and the CLEC.

Qwest currently offers CLECs the option of obtaining their own unique terminations for ordering UNEs utilizing a shared configuration with another CLEC via the Shared Collocation product. This product provides the CLEC with the ability to share anew or existing collocation cage with another CLEC. The shared collocation arrangement is established in a manner that allows Qwest to identify a portion of the terminations as belonging to the ordering CLEC. Through this arrangement, a CLEC would be able to order unbundled network elements from another CLECs collocation cage.

Additionally, Qwest currently offers all forms of collocation that are required by the Communications Act of 1934, as amended in 1996, (Act) and the FCC’s rules. Qwest is not required to modify or upgrade their processes and systems in order to allow a CLEC to order UNEs and other services from the collocation arrangement of another CLEC outside of Qwest’s shared collocation policies. Qwest allows CLECs to obtain unbundled network elements through each of the types of physical and virtual collocation required by Section 251(c)(6) and Section 51.323 of the FCC’s rules. Among those methods of collocation is the sharing of caged collocation space by two or more CLECs pursuant to terms and conditions agreed to by the CLECs. Under such arrangements, CLECs can purchase shared collocation space in increments small enough to collocate a single rack, or bay, of equipment. The request to order UNEs from another CLECs unshared collocation arrangement goes beyond the requirements of the Act and the FCC’s rules

The fact that Qwest may allow carriers to order special access services from another CLECs collocation arrangement does not mean that Qwest is required to allow the same for UNEs. As noted, Qwest complies with each of the collocation provisions of the Act and the FCC’s rules. Those provisions do not obligate Qwest to adopt the same processes for ordering UNEs and non-UNE wholesale services. In implementing the nondiscriminatory access" requirement of Section 251(c)(3), the FCC has found that an ILEC satisfies this requirement if (i) the quality of a UNE, as well as the access provided to that UNE, are equal between all carriers requesting access to that UNE; and (ii) where technically feasible, the access and UNE provided by an ILEC are at least equal-in-quality to that which the ILEC provides to itself. 47 C.F.R. § 51.311. See also, In the Matter of Implementation of the Local Competition Provisions in the Telecommunications Act of 1996, First Report and Order, 11 FCC Rcd 15499 312 (1996). This standard does not compare the terms and conditions on which an ILEC offers tariffed services, such as special access, to the ILECs UNE offerings.

As this option is not required, Qwest already has an alternative product that allows this capability for the CLECs, and there is no demonstrable gain over the options already offered to the CLEC, this request is respectfully denied. It is recommended that the CLECs either arrange with other CLECs to share collocation cages (as defined above), that the CLEC owning the collocation could submit the LSR, and/or establish cross billing capabilities between the CLECs that wish to provide a portion of their collocation to another CLEC.

Sincerely,

Qwest