Wholesale: Products & Services

Archived System CR SCR060407-01ES Detail

1. Per Qwest, Qwest does not allow CLECs to obtain an electronic CSR in IMA. Instead Qwest’s requires the CLEC to submit a manual fax CSR request. (In rare and isolated cases, Eschelon has been able to obtain an electronic CSR in IMA, so Eschelon knows this is feasible.)

2. Per Qwest, Qwest requires CLECs submit LSRs via a manual fax submission. Qwest does not allow CLECs to submit an electronic LSR via IMA GUI or Application to Application. (In rare and isolated cases, Eschelon has been able to submit an electronic LSR in IMA, so Eschelon knows this is feasible.)

3. Per Qwest, the Qwest service orders do not flow to its VoIP switch so the Qwest initiated service order will not remove the customers telephone numbers from Qwest’s switch after the customer converts to the new local service provider from the Qwest VoIP platform. Qwest also told Eschelon that Eschelon can not contact Qwest Wholesale to ask to have the numbers removed from the Qwest switch. Qwest told Eschelon that the Eschelon’s end user customer has to contact the Qwest retail business office to request a disconnect of their VoIP services and ask to have the number removed from the Qwest switch. This not only prevents a seamless transition but it also creates the potential for inappropriate Qwest customer retention activity.

The end user customer should not be penalized because the end user customer is converting from a particular Qwest product. These delays and impacting issues are affecting the end users ability to seamlessly change to the local service provider of their choice. On March 1 2007, the FCC granted a Petition for Declaratory Ruling filed by Time Warner Cable (TWC), Memorandum Opinion and Order, TWC Request for Declaratory Ruling that Competitive Local Exchange Carriers May Obtain Interconnection under Section 251 of the Communications Act of 1934, as Amended, to Provide Wholesale Telecommunications Services to VoIP Providers, WC Docket No. 06-55, DA 07-709 (Mar. 1, 2007) (“Order”). The order clarifies that CLECs serving interconnected VoIP providers must provide number portability pursuant to section 52.23 of the FCC’s rules when a VoIP provider’s customer changes carriers. Eschelon requests that Qwest implement system and process changes to support the migrations of end users with Qwest VoIP products with the same system (IMA) functionality as migrations from any other Qwest product.

Expected Deliverable:

Eschelon asks Qwest to implement a seamless migration process for conversions/migrations from the Qwest VoIP product to a different local service provider (such as a CLEC providing service using unbundled loops and/or Local Number Portability per its ICA). For example, Eschelon asks for the following:

-- Immediately change the Qwest requirement that the CLEC end user customer contact the Qwest retail business office to have the TNs removed from the Qwest VoIP Platform after the number port has been completed. If necessary to achieve an immediate change, implement a interim process under which the CLEC contacts Qwest Wholesale until a systems solution is in place.

-- Electronic CSR via IMA for End Users on the Qwest VoIP product

-- The ability to submit migration requests via IMA GUI or App to App for CLEC end users migrating from a Qwest VoIP product

Status History

Project Meetings

November 19, 2008 Product/Process CMP Meeting

Mark Coyne-Qwest said that a notification was sent on 10/31/08 and that we would like to close this issue. Bonnie Johnson-Integra said that she was fine with closing this issue but that the system CR associated with this issue still needs to be worked. Mark Coyne-Qwest said that the CR is packaged in IMA 25.0.

October 15, 2008 Product/Process CMP Meeting

Mark Coyne – Qwest stated that the status of the outstanding issue of the relationship between QC and QCC numbering partner is that testing has been completed on the internal process. He said that when this QC/QCC process is implemented, Qwest Wholesale will no longer provide the detailed instructions to a CLEC to tell their end user to contact QCC since there will no longer be any need for the end user to go to QCC. Mark noted that since what is documented as part of the Wholesale Port process does not go into the detail of referencing the CLEC to tell their end user to contact QCC the current external documentation does not need to be updated. He said that Qwest does not believe a notification is necessary. He said that Qwest would be willing to send a notice only (no documentation update) to relay this information. Mark stated that the Oversight Issue will be closed. Bonnie Johnson – Integra stated that the existing CR contains that piece of the process, to make the End User call. Bonnie asked if the notification could be sent and related to that CR. Mark Coyne – Qwest said that we can do that and relate the CRs Bonnie Johnson – Integra asked that the CR could be updated with the notification so that it will be in one place.

September 17, 2008 Product/Process CMP Meeting

Susan Lorence-Qwest said that Qwest stated last month that we were looking to implement some process improvements on the numbering partner issues by the end of the 3rd quarter. She said that it does not look like this will take place by the end of September and will probably occur in the October time frame. We hope to be able to provide a status in the October CMP Meeting that those changes have been implemented and that we will be communicating with the Oversight Committee to close this issue.

August 20, 2008 Product/Process CMP Meeting

Mark Coyne-Qwest stated that the QC and QCC staff has developed internal process improvements to resolve the numbering partner issue. Job aids and training are under development with a target date for implementation by the end of the third quarter. He said that volumes continue to be very low and that through July for the year, there have only been 10 requests. Mark said that Qwest does not believe any further meeting of the CMP Oversight Committee is required. Qwest is proposing that a final status be provided to this Committee once the internal QC and QCC process improvements targeted for third quarter have been implemented. Mark said that Qwest believes this Oversight issue can then be closed. However, if there is a desire to meet and discuss the above information further, please contact Qwest who will then work to coordinate the next meeting.

July 16, 2008 Product/Process CMP Meeting

Mark Coyne-Qwest stated that there was nothing new to report and said that the most current information is on the website. Mark said that we will post any new information in these minutes or on the website.

June 18, 2008 Product/Process CMP Meeting

Mark Coyne-Qwest stated that Qwest sent an update yesterday to the Oversight Committee. He said that there is 1 outstanding issue associated to QC and QCC numbering partners. He said that we will continue to work with the Oversight team to determine if we can close or if we need to reconvene.

May 21, 2008 Product/Process CMP Meeting

Mark Coyne-Qwest stated that there are still outstanding issues and that Qwest sent out an updated response yesterday. Mark said that we would also be presenting a system CR later relating to this issue

April 16, 2008 Product/Process CMP Meeting

Status of Request for CMP Oversight Review - SCR060407-01ES Develop and Implement the Needed Systems Changes and/or Process Changes to Avoid Delay and/or Customer Impact When a Customer is Converting to a Different Local Service Provider From One of Qwest’s VOIP (OneFlex) Products. Mark Coyne-Qwest stated that Qwest sent out the proposed resolution and will continue to work with the Oversight team. He said that Qwest will be submitting a CR as part of the resolution. He said that there will not be a meeting but that we will be providing e-mail updates to the Oversight Committee.

March 19, 2008 Product/Process CMP Meeting

Mark Coyne-Qwest stated that we do have a Request for CMP Oversight Review – SCR060407-01ES Develop and Implement the Needed Systems Changes and/or Process Changes to Avoid Delay and/or Customer Impact When a Customer is Converting to a Different Local Service Provider From One of Qwest’s VOIP (OneFlex) Products. Mark said that an Oversight meeting was held on February 21, 2008 and the minutes are posted on the CMP website. He also said that another Oversight meeting would be held later today.

February 20, 2008 Product/Process CMP Meeting

Mark Coyne-Qwest stated that we do have a Request for CMP Oversight Review – SCR060407-01ES Develop and Implement the Needed Systems Changes and/or Process Changes to Avoid Delay and/or Customer Impact When a Customer is Converting to a Different Local Service Provider From One of Qwest’s VOIP (OneFlex) Products. Mark said that this issue will be addressed in the Oversight meeting that is scheduled on February 21, 2008.

September 19, 2007 Systems CMP Meeting Discussion: Mark Coyne-Qwest stated that this is a carry over from last month and noted that Qwest addressed the denial last month and that Eschelon had additional concerns so it was agreed that this CR would be discussed at the September CMP Meeting. Mark stated that Qwest received an email stating that Eschelon could not find specific examples but did want further discussion. Mark then asked Eschelon to start the discussion. [Comment received from Eschelon: Bonnie Johnson-Eschelon asked what examples Qwest was looking for.] Kim Isaacs-Eschelon stated that Qwest had asked for examples of where Qwest called the losing provider to have a TN removed from their switch. Kim stated that this has happened but could not find examples. [Comment received from Eschelon: Kim Isaacs-Eschelon stated that Qwest had asked for examples of where the customer had to call Qwest to have a TN removed from their switch. Kim stated that this has happened but could not find examples.] Bonnie Johnson-Eschelon stated that that is the process so it should be 100% of the time. [Comment received from Eschelon: Bonnie Johnson-Eschelon stated that Qwest said that is the process so it should be 100% of the time.] Bonnie stated that the process is that the customer calls the VOIP part of the service in order to have that TN removed from the switch. Bonnie asked why examples would be necessary. Mark Coyne-Qwest stated that the VOIP provider is Qwest Retail, not Wholesale. Bonnie Johnson-Eschelon stated that Qwest has told the CLECs that has to happen so the number is removed from the VOIP switch. Bonnie stated that this is not a non compliance issue. Bonnie stated that Eschelon knows and understands that this has to happen or the number would work in both places. [Comment received from Eschelon: Bonnie stated that Eschelon Qwest said that this has to happen or the number would work in both switches.] Bonnie questioned the value of examples. Mark Coyne-Qwest stated that in the CMP Meeting last month, Eschelon stated that they had contacted the CSIE in order to have them help to get a number disconnected from a VOIP switch. Mark stated that it is not Qwest’s practice or policy to do that so we asked for examples of when that occurred so we could research them and address it with the CSIE. Bonnie Johnson-Eschelon stated that is a different example and Eschelon had indicated that the customer should not take any part in disconnecting of the number. Bonnie then stated that Eschelon would be escalating this CR. Bonnie stated that Qwest wants Eschelon to tell Qwest that the CSIE has acted as they should have, because Eschelon doesn’t believe that the customer should have to call. Bonnie stated that the examples do not have any bearing on the denial. Mark Coyne-Qwest stated that they do, due to VOIP being an enhanced service and is not within the CMP Guidelines. Bonnie Johnson-Eschelon stated that the services that the customer is moving to are. Mark Coyne-Qwest said yes, but for the enhanced service piece, the customer needs to contact the VOIP provider. Mark stated that it is not the responsibility of the CSIE to do that. Mark stated that this is Qwest’s position and his understanding of why the CR was denied. Mark then noted that he did hear that Eschelon would escalate this CR. Bonnie Johnson-Eschelon said yes, will most likely escalate and can have further discussions then. Bonnie stated that it is possible to do this and she wants to immediately allow the CSIE to do that extra step. Bonnie stated that the examples would only prove that it can be done.

-- August 22, 2007 Email Received from Eschelon: Hello Peggy, My internal teams are having difficulty finding specific escalation tickets numbers that demonstrate that the CSIE/Qwest porting team will work with the Old Service Provider to ensure that TNs are removed from the old provider’s switch. However, they are in agreement that Qwest has assisted us with this type of request in the past. To further support this point and to support my statement that removing the TNs from the old providers switch is an expectation of the porting process, I would like to point out Qwest’s “expectations” listed in the Port In PCAT: http://www.qwest.com/wholesale/clecs/portin.html . “Expects that the OLSP will remove the TN(s) from their switch by 5PM MTN time on the DDD or according to their current port process” Please note that Qwest’s expectation does not have a qualifier stating unless the OLSP is a VoIP provider. Kim Isaacs Eschelon Telecom, Inc. ILEC Relations Process Specialist

August 17, 2007 Email Sent to Eschelon: Thanks KIm, I will look for them then. Have a great weekend. Peggy E-R

August 17, 2007 Email Received from Eschelon: Hello Peggy, I have not had the opportunity to complete a review escalation ticket history, I anticipate responding to you mid next week. Thanks. Kim Isaacs Eschelon Telecom, Inc.

- August 17, 2007 Email Sent to Eschelon: Hi Kim, I am just checking on the status of the examples that Qwest requested during the August 15th CMP Meeting denial discussion for your CMP CR SCR060407-01 Develop and Implement the Needed Systems Changes and/or Process Changes to Avoid Delay and/or Customer Impact When a Customer is Converting to a Difference Local Service Provider From One of Qwest’s VoIP (OneFlex) Products. The examples will be appreciated and will assist us in our research of your concern regarding a disconnect from a VOIP Platform. Thank you, Peggy Esquibel-Reed Qwest Wholesale CMP

August 15, 2007 Systems CMP Meeting Discussion: Note: 8/23/07 Bold indicates comments to minutes received from Eschelon Mark Coyne-Qwest stated that this CR is being denied and will be addressed by Kathy Rein (Qwest) Kathy Rein-Qwest stated that Qwest has completed an analysis and has determined that the current processes for obtaining a CSR and submitting an LSR allow a CLEC to port or convert any number currently within the Qwest network. Consequently, Qwest is denying your request due to no demonstrable business benefit. Kathy then stated that the Qwest OneFlex product (VOIP) is an enhanced service and is denied because it is outside the scope of the Change Management Process. Kim Isaacs-Eschelon stated that she objects to the denial and would like to leave it as action item while they consider their next step. Kim stated that the request was for an efficient mechanized process. Qwest does have a manual LSR / CSR process but that Eschelon does consider faxing an acceptable process due to trouble with faxing and tracking. Kim then stated that the manual process is not efficient. Kim then stated that this is not outside the scope of CMP because the product that it is moving to is CMP governed. Kim stated that porting does fall under CMP. Mark Coyne-Qwest asked for further understanding and stated that VOIP does not fall under CMP. Kim Isaacs-Eschelon stated that LNP and porting fall under CMP. Mark Coyne-Qwest stated that the mention of VOIP takes this out of CMP. Kim Isaacs-Eschelon stated that porting includes a disconnect of a number in the Qwest switch. Kathy Rein-Qwest stated that Qwest does do that today, in a Qwest switch. Kim Isaacs-Eschelon stated Qwest does not take the TN off of the Qwest VOIP Platform. Kathy Rein-Qwest stated that the VOIP Platform is outside the scope of CMP. Kim Isaacs-Eschelon stated that the disconnection of the TN from the losing carrier’s switch is part of the port process and Qwest would not have finished the port if the TN remains in the switch. This causes service affecting issues for the end user customers. Kathy Rein-Qwest stated that the only service impacted is in VOIP. Kim Isaacs-Eschelon said calls from VOIP users can’t get through to the end user. Kim stated that the numbers are on the VOIP Platform and the CLEC switch at the same time. When numbers do not get disconnected from the losing carrier’s switch this causes problems. Kathy Rein-Qwest stated that the number has been disconnected from the Qwest switch and is all that Qwest has control over. Kathy stated that there is no way and Qwest cannot control a disconnect out of a VOIP switch; for Qwest or for any voice provider. Kim Isaacs-Eschelon stated that she did not believe that and stated that if we are requesting that Qwest port from another CLEC to a Qwest switch based product like QPP or Resale. Kim stated that Qwest coordinates with the losing CLEC to ensure the TN is removed from the losing carriers switch. Kathy Rein-Qwest stated that there is coordination in the switch, but if the CLEC provided an enhanced service, we could not guarantee that it is disconnected from another voice provider switch. Kim Isaacs-Eschelon stated that if they call in a ticket, the CSIE works with them and the old provider to see the number is removed from the other providers switch. Kim stated that they have ported from other CLECs and Qwest has made sure that the number is pulled out of the carriers switch. Kim stated that the disconnect from the old provider’s switch is part of the port process. Kathy Rein-Qwest stated that we can only control what is on the Qwest switch and Qwest does not have visibility or control over enhanced processes. Mark Coyne-Qwest asked Kim (Isaacs-Eschelon) to provide examples of when the CSIE has done that and stated that we would look at them. Kim Isaacs-Eschelon stated that she would look for them, but it is part of the porting process and that is where the argument is. Kim stated that Qwest is porting the number and is the LNP provider. Mark Coyne-Qwest stated that Qwest has done as much as we can and have done our part. Mark stated that Qwest cannot control what is not in the Qwest switch. Kathy Rein-Qwest stated that we can only go back to the VOIP provider and ask that they take the number out of the platform and it is then up to them. Kathy stated that is what is outside of CMP. Kim Isaacs-Eschelon stated that she disagrees and wants further discussion next month. Mark Coyne-Qwest stated that we would take an action item and would note Eschelon’s objection. Mark then stated that Qwest is standing by the denial and asked Kim (Isaacs-Eschelon) to please send in those requested examples so we could look at them. This CR remains in Denied Status and remains active.

- July 18, 2007 Systems CMP Meeting Discussion: Mark Coyne-Qwest stated that Qwest is still evaluating this request in order to discuss the different pieces of the request and will be scheduling an ad hoc call with Eschelon. Bonnie Johnson-Eschelon asked if the call could be open to other CLECs. Mark Coyne-Qwest said yes. Bonnie Johnson-Eschelon said thank you.

- June 20, 2007 Systems CMP Meeting Discussion: Kim Isaacs-Eschelon stated that Eschelon is requesting a mechanized process to efficiently convert customers from VOIP to LNP, QLSP, QPP, or Resale. Kim stated that Eschelon’s first focus is for Qwest to develop a process for customers to not have to call Qwest to have a number removed. Kim stated that the current process for submitting an LSR is manual and stated that they are looking for a mechanized process to convert the customers. Mark Coyne-Qwest asked if there were any questions for Kim. There were none. Mark then noted that the Clarification Call had been held and that Qwest is currently evaluating the request and the benefits. Mark stated that there would be an update in July.

- June 18, 2007 Clarification Call: Attendees: Kim Isaacs-Eschelon, Peggy Esquibel Reed-Qwest, Kathy Rein-Qwest, Denise Martinez-Qwest, Chuck Anderson-Qwest, Carol McKenzie-Qwest Peggy Esquibel Reed-Qwest introduced the call and asked Kim Isaacs (Eschelon) to provide a description of her Change Request. Kim Isaacs-Eschelon noted that Kathy Rein (Qwest) has been on a call with Eschelon and Eschelon’s Service Manager, so she is aware of the issues. Kim stated that Eschelon is having difficulty converting from Qwest OneFlex products. Kim stated that the CSR is similar to the Centrex CSR but it is difficult to get a CSR record. Kim noted that it is also difficult to issue LSRs. Kim stated that Eschelon has had limited success if the TN is within the first half of the very large CSR. Kim stated that she knows that it is possible to use electronic interfaces, and when it does not work, they have to submit faxes to the Centers. Kim stated that this has resulted in a number of rejects, even with the manual requests, due to the product being a new product. Kim stated that the Qwest disconnect order does not flow through to the Qwest VOIP Platform in order to be removed from that platform; the number remains there on either the Eschelon switch or the Qwest switch. Kim stated that this causes problems for the end user customer. Kim stated that Eschelon was told that the customer has to call Qwest in order to get the TN removed from the switch. Kim stated that Eschelon was told that Qwest could not help Eschelon, and that the end user customer had to call Qwest. Kim stated that Eschelon is requesting an electronic means to efficiently and completely remove the customer from VOIP. They want to eliminate the customer having to call Qwest in order to remove the TN. Kim then stated that Eschelon is okay with a manual process before the electronic means can be done. Kim then stated that this request is really comprised of three components: 1) Pre-order piece in order to get the CSR 2) The electronic LSR component 3) For the D order to flow through VOIP Kim stated that Eschelon is requesting a manual workaround until the electronic means can be implemented. Kim stated that this is a very important piece. Peggy Esquibel Reed-Qwest asked if there were any questions or comments for Eschelon. There were no comments or questions. Kim Isaacs-Eschelon stated that Qwest could look at using something similar to Centron/Centrex Plus, and how that conversion process works as to how to address this request. Peggy Esquibel Reed-Qwest stated that this CR is on the agenda for Eschelon to present at the June 20th CMP Meeting. Peggy then noted that the Qwest Response is due prior to the July CMP Meeting. The call was concluded.

CenturyLink Response

December 4, 2007

Bonnie Johnson Eschelon Telecom

Subject: Escalation on Eschelon Telecom CR#SCR060407-01ES Denied

This letter is Qwest’s binding response to your November 26, 2007 escalation regarding SCR060407-01ES, “Develop and Implement the Needed Systems Changes and/or Process Changes to Avoid Delay and/or Customer Impact When a Customer is Converting to a Difference Local Service Provider From One of Qwest’s VoIP (OneFlex) Products.

Qwest has reviewed the formal escalation and Qwest maintains our position as identified in the CR denial associated with SCR 060407-01ES. The OneFlex product (VOIP) is an enhanced service offered by Qwest Communications Corporation (QCC). As such, this retail offering by QCC does not fall within the purview of the Qwest Corporation (QC) Change Management Process (CMP). The portion of the Change Request SCR060407-01ES which addresses the OneFlex product continues to be denied because it is outside the scope of the QC CMP. Even assuming for the sake of argument that this was an issue that could be addressed by the QC CMP, the action that Eschelon seeks is not something within the control of QC. As Eschelon notes in its escalation “Qwest's process requires the customer to contact Qwest to have the number removed from the Qwest switch.” QC does remove the number from the QC network switch. QC, however, is not enabled nor empowered to remove the end user number from the QCC VOIP platform -- nor would it be able to do so in regard to any other VOIP service provider platform. In regard to the references in the Escalation and Change Request associated with the porting or the conversion process which do fall under the scope of CMP, Qwest continues to believe that the current processes for obtaining a CSR and submitting an LSR allow a CLEC to port or convert any number currently within the Qwest network. Consequently, Qwest also maintains this portion of the CR denial for SCR060407-01ES due to no demonstrable business benefit based on the current volume of such services.

Dildine Lybarger Qwest Wholesale Director Program/Project Mgmt

August 9, 2007 Revised Qwest Response To: Kim Isaacs This letter is in response to CLEC Change Request number SCR060407-01, dated 06/4/07, and titled: Develop and Implement the Needed Systems Changes and/or Process Changes to Avoid Delay and/or Customer Impact When a Customer is Converting to a Difference Local Service Provider From One of Qwest’s VoIP (OneFlex) Products.

CR Description: Eschelon is requesting that Qwest develop and implement the necessary system and/or process changes to support seamless migrations to local service providers when end user customers are migrating from Qwest VoIP (OneFlex) products. Eschelon’s end users have experienced a number of delays and customer impacting problems when changing their local service provider when the customer is moving from one of Qwest’s VoIP products. Eschelon presented this issue to its Qwest service manager. Qwest’s service manager arranged for a call with a Qwest process representative. Even though Eschelon is submitting an LSR to Qwest, Qwest told Eschelon on that call that migrations from the Qwest VoIP product are subject to a number of system and process exceptions that do not occur when a customer is converting from non Qwest VoIP products. These exceptions are: 1. Per Qwest, Qwest does not allow CLECs to obtain an electronic CSR in IMA. Instead Qwest’s requires the CLEC to submit a manual fax CSR request. (In rare and isolated cases, Eschelon has been able to obtain an electronic CSR in IMA, so Eschelon knows this is feasible.) 2. Per Qwest, Qwest requires CLECs submit LSRs via a manual fax submission. Qwest does not allow CLECs to submit an electronic LSR via IMA GUI or Application to Application. (In rare and isolated cases, Eschelon has been able to submit an electronic LSR in IMA, so Eschelon knows this is feasible.) 3. Per Qwest, the Qwest service orders do not flow to its VoIP switch so the Qwest initiated service order will not remove the customers telephone numbers from Qwest’s switch after the customer converts to the new local service provider from the Qwest VoIP platform. Qwest also told Eschelon that Eschelon can not contact Qwest Wholesale to ask to have the numbers removed from the Qwest switch. Qwest told Eschelon that the Eschelon’s end user customer has to contact the Qwest retail business office to request a disconnect of their VoIP services and ask to have the number removed from the Qwest switch. This not only prevents a seamless transition but it also creates the potential for inappropriate Qwest customer retention activity.

The end user customer should not be penalized because the end user customer is converting from a particular Qwest product. These delays and impacting issues are affecting the end users ability to seamlessly change to the local service provider of their choice. On March 1 2007, the FCC granted a Petition for Declaratory Ruling filed by Time Warner Cable (TWC), Memorandum Opinion and Order, TWC Request for Declaratory Ruling that Competitive Local Exchange Carriers May Obtain Interconnection under Section 251 of the Communications Act of 1934, as Amended, to Provide Wholesale Telecommunications Services to VoIP Providers, WC Docket No. 06-55, DA 07-709 (Mar. 1, 2007) (“Order”). The order clarifies that CLECs serving interconnected VoIP providers must provide number portability pursuant to section 52.23 of the FCC’s rules when a VoIP provider’s customer changes carriers. Eschelon requests that Qwest implement system and process changes to support the migrations of end users with Qwest VoIP products with the same system (IMA) functionality as migrations from any other Qwest product.

Expected Deliverables/Proposed Implementation Date (if applicable): Eschelon asks Qwest to implement a seamless migration process for conversions/migrations from the Qwest VoIP product to a different service provider (such as a CLEC providing service using unbundled loops and/or Local Number Portability per its ICA). For example, asks for the following: -- Immediately change the Qwest requirement that the CLEC end user customer contact the Qwest retail business office to have the from the Qwest VoIP Platform after the number port has been completed. If necessary to achieve an immediate change, implement process under which the CLEC contacts Qwest Wholesale until a systems solution is in place. -- Electronic CSR via IMA for End Users on the Qwest VoIP product -- The ability to submit migration requests via IMA GUI or App to App for CLEC end users migrating from a Qwest VoIP product

History: The CR was submitted on 06/4/07 and a clarification meeting was held on June 18, 2007 with Eschelon and Qwest representation.

Qwest Response: Qwest has completed an analysis for SCR060407-01 and has determined that the current processes for obtaining a CSR and submitting an LSR allow a CLEC to port or convert any number currently within the Qwest network. Consequently, Qwest is denying your request for SCR060407-01 due to no demonstrable business benefit.

The Qwest OneFlex product (VOIP) is an enhanced service and is denied because it is outside the scope of the Change Management Process.

Sincerely, Qwest Corporation

DRAFT RESPONSE

July 9, 2007

RE: SCR060407-01 Develop and Implement the Needed Systems Changes and/or Process Changes to Avoid Delay and/or Customer Impact When a Customer is Converting to a Difference Local Service Provider From One of Qwest’s VoIP (OneFlex) Products

Qwest has reviewed the information submitted as part of Change Request SCR060407-01. Qwest is still examining the issue. Qwest will continue to research the problem and provide an updated response at the August Systems CMP Meeting.

Sincerely, Qwest Corporation