Wholesale: Products & Services

Archived System CR SCR070103-01ES Detail

Financial suspend orders in WA, OR and ID-N currently require manual handling. MCI seeks automation of financial suspend orders in the Western Region. In addition, two-way suspensions are not consistent across Qwest 14 state footprint. MCI seeks to have two-way suspensions processed in one of the two methods consistently:

1) Automatic two way suspension

or

2) Make use of the suspend type field across all states to specify if the suspension should be one-way or two-way

Expected Deliverables/Proposed Implementation Date (if applicable):

That financial suspend orders flow through for Western Region and two-way suspensions are consistently process throughout Qwest 14 state footprint.

Status History

Project Meetings

- April 20, 2005 Systems CMP Meeting Discussion: Jill Martain-Qwest stated that 17.0 was deployed on 4/11/05 and that this CR will remain in CLEC Test.

March 16, 2005 Systems CMP Meeting Discussion: Jill Martain-Qwest stated that this CR is scheduled to be implemented on April 11, 2005, with the IMA 17.0 Release.

-- November 17, 2004 Systems CMP Meeting Discussion: Jill Martain/Qwest stated that the IMA 17.0 Packaging Status is located in Attachment M. Jill also said that the Release date for 17.0 was changed from April 25, 2005 to April 11, 2005. Liz Balvin/Covad stated that the LOE was reduced for this release and asked if Qwest would provide capacity in December of 2004. Jill Martain/Qwest stated that Qwest would provide the capacity for 2005 in December of 2004. Liz Balvin/Covad asked if the 1400 to 1600 hours for SCR121003-01EX Mechanization for SUPP Type 3 Activity scheduled in December were available. Liz said the hours should be available for 17.0 Susie Bliss/Qwest stated that we were utilizing those hours this year. Bonnie Johnson/Eschelon said that here understanding was that the hours were available for 17.0. Susie Bliss/Qwest said that we don’t know what the hours are for 2005 yet. Bonnie Johnson/Eschelon asked if the available resources stayed at 20,000 hours for the year. Susie Bliss/Qwest stated that the 20,000 hours is an estimate for 17.0. Bonnie Johnson/Eschelon said that Qwest used to package to mid-range and that for 17.0 Qwest packaged at the high range. Susie Bliss/Qwest said that this is due to the uncertainty. Comment received from Eschelon 11/29/04 – and Qwest does not know the hours for 2005 right now. Liz Balvin/Covad asked why the IMA 17.0 production date was moved. John Gallegos/Qwest said that Qwest needed to sync up with other systems and for other technical reasons. John Berard/Covad asked if the date was moved because of the hours. John Gallegos/Qwest said no, it was not because of the hours.

July 22, 2004 Systems CMP Meeting Discussion: Jill Martain/Qwest stated that Qwest would distribute the ballot on July 27th, it is due back to Qwest on July 30th, and Qwest would email the initial prioritization list to the CLECs on August 3rd. There were no questions. Liz Balvin/MCI stated that this is a high priority for MCI.

March 18, 2004 Systems CMP Meeting Discussion: Connie Winston/Qwest stated that the LOE for this CR is 2350 to 2650 IMA hours and noted that this CR is available for the next vote. Connie stated that there would be an IMA edit that will allow IMA to know what the switch level is. There were no comments or questions. The Action Item was Closed.

- March 11, 2004 Email Sent to Liz Balvin-MCI: Good Morning Liz, I have attached a current copy of your SCR070103-01ES Allow financial suspend orders to flow through for WA, OR, and ID-N. In addition, process two-way suspensions consistenty across Qwest 14 state footprint. This copy indicates: - Level of Effort of 2350 to 2650 hours - Impacted Interface of IMA Common. Thru the analysis of what it would take to mechanize this function, it was determined that there is in fact, an impact to IMA as well as other systems. - Status Changed to Pending Prioritization - Action Item Created for a read-out of the LOE at the March Systems CMP Meeting.

Thank you, Peggy Esquibel-Reed Qwest CMP CRPM -- Systems Peggy.Esquibel-Reed@qwest.com

- February 19, 2004 Systems CMP Meeting Discussion: Michelle Thacker/Qwest stated that the status of this CR was changed from Denied to Presented. Michelle stated that Qwest would allow 2-way suspensions in OR, WA, and N. ID for UNE-P. Michelle stated that 1-way suspensions would be allowed for non DMS Switches, for Resale. Connie Winston/Qwest stated that Qwest is determining the LOE. There were no questions or comments. The action item was closed.

Judy Schultz/Qwest stated that she wanted to provide an update to the funding approval process that was discussed in the January CMP Systems Meeting. Judy referred everyone to Attachment J in the Distribution Package. She stated that all CRs are being re-evaluated and must be approved. Judy said that CRs could not be scheduled without approval. Judy noted that the status of this CR is: There is no new Status for this CR.

January Systems CMP Meeting Discussion: Liz Balvin/MCI stated that MCI escalated this denial and needs to understand the escalation response. Jim Maher/Qwest stated that MCI needs to respond to the escalation in writing. Judy Schultz/Qwest stated that Qwest could call MCI to answer her questions. Liz Balvin/MCI stated that she would send a written response. Judy Schultz/Qwest stated that the process is that MCI submits their response in writing and that Qwest post’s it to the web. Liz Balvin/MCI stated that she needs to understand DMS100 & DMS10 switches. Jim Maher/Qwest stated that 2-way suspensions in Oregon & Washington are due to the technical limitation of not being able to do a 1-way suspend in DMS100 & DMS10 switches. Liz Balvin/MCI stated that she would like this CR modified to accommodate processing of two-way suspension orders for the DMS100 & DMS10 switches in these states, eliminating the manual process. Jim Maher/Qwest stated that there would be a clarification call scheduled to discuss the changes to the CR, and to clarify MCI’s request. Liz Balvin/MCI agreed to the meeting being scheduled.

January 19, 2004 Qwest Response to Escalation SCR070103-01-E20: Liz, Attached is the Qwest response to your escalation # SCR070103-01-E20. Please let me know if you have any questions. Thanks, Jim:

Escalation # SCR070103-01-E20 January 19, 2004

Liz Balvin MCI

Dear Ms. Balvin:

This letter is in response to MCI Escalation # SCR070103-01-E20 regarding the MCI position that Qwest inappropriately denied to allow financial suspend orders to flow through for WA, OR, and ID-N, and that Qwest process two-way suspensions consistently across Qwest 14 state footprint. The MCI issues, in blue font, raised in this escalation and the associated Qwest responses are as follow:

MCI Issue: Qwest documented procedures URL: http://www.qwest.com/wholesale/pcat/tdnpr.html states "State: Arizona, Colorado, Southern Idaho, Iowa, Minnesota, Montana, Nebraska, New Mexico, North Dakota, South Dakota, Utah, or Wyoming Switch Type: All Types Type of Restriction: Outgoing and incoming calls State: Northern Idaho, Washington or Oregon Switch Type: All Types except DMS Type of Restriction: Outgoing Only NOTE: For two-way temporary disconnects, you must issue your request manually and note in REMARKS "two-way denial". State: Northern Idaho, Washington or Oregon Switch Type: DMS Type of Restriction: Outgoing and incoming calls". NOTE: Qwest provides ability to order two-way suspensions in the Western Region on a manual basis.

Qwest Response: Qwest agrees that the information in the Temporary Disconnection for Non-payment/Restore PCAT is not clear and (for WA and OR) is incorrect (see #2 below). To clarify, in states other than WA and OR, where two-way suspensions are allowed and provided, the process for requesting two-way suspensions is as described in the PCAT. Qwest will update the PCAT to both clarify the process and application for two-way suspensions and correct the PCAT relative to the regulatory restrictions for WA and OR, (see the next Qwest Response below).

MCI Issue: Upon receipt of MCI's change request to systematically allow the ordering of two-way suspensions, Qwest not only denied the CR based on retail tariff language but is expected to update the above documentation such that CLECs cannot order entirely. Qwest stated "This compliance entails revisions of the PCAT language as well as revision to methods regarding the manual process for 2-way suspensions. The revision to methods has been completed and the revision to the PCAT is in progress" (email from Qwest 11/18/03).

Qwest Response: As indicated by Michelle Thacker on December 17, 2003, and subsequently provided via email on December 18, 2003 and documented in the CMP CR, the PCAT document located on URL: http://www.qwest.com/wholesale/pcat/tdnpr.html, is incorrect and will be revised to reflect the OR and WA state regulatory requirements of only allowing one-way suspensions of service except in DMS10 and DMS 100 switches where only two-way suspensions are technically feasible.

MCI Issue: MCI Interconnect Agreements (ICA's) state "Access to Unbundled Local Switching encompasses line-side and trunk-side facilities, plus the features, functions, and capabilities of the Switch. The features, functions, and capabilities of the Switch include the basic switching function, as well as the same basic capabilities that are available to Qwest's End User Customers. Unbundled Local Switching also includes access to all vertical features that the Switch is capable of providing, as well as any technically-feasible customized routing functions" (SGAT section 9.11.1.1)" Thus, when ordering UNE-P POTS, MCI's ICA's apply, not Qwest retail tariff.

Qwest Response: The switch capability associated with two-way suspensions is not currently listed/identified as a UNE in either existing Interconnection Agreements or Qwest’s SGAT. In addition, based on WA and OR state regulatory rules, Qwest is prohibited from providing two-way suspensions to customers in the states of WA and OR except in DMS10 and DMS100 switches which are technically limited to a two-way suspension switch functionality.

MCI Issue: In addition to MCI's ICA's, the FCC regulations require Qwest to provide MCI all the features and functions of the switch when we buy switching unbundled network elements (UNEs) (47 CFR Section 51.319(c)(1). Qwest denial states "Although the switch may have capability of two-way denial, the State Commission does not allow for this practice." (12/30/03 Email from Qwest) Please note, this restriction applies to Qwest retail ONLY, not wholesale whereby contract language supercedes.

Qwest Response: Qwest continues to recommend that MCI pursue two-way suspensions in OR and WA by way of the Special Request Process (SRP). A SRP request would determine if two-way suspensions are technically feasible in the switches in OR and WA, and would result in an ICA amendment that would go before the OR and WA state commissions for review/approval. This would bring the issue of OR and WA’s current position on two-way suspensions to those state commissions for either approval for MCI and Qwest to move forward in establishing this capability or would result in a continued denial of MCI’s request (assumedly for the same reasons those state commissions do not allow Qwest to do two-way suspensions in those states).

MCI Issue: Qwest inappropriately denied MCI's change request SCR070103-01. Not only is Qwest denying the systematic means to order two-way suspension but intends to eliminate the ability to order on a manual basis, restricting CLECs all together.

Qwest Response: Qwest does not agree that the denial of MCI’s change request SCR070103-01 is inappropriate. In addition, Qwest is not "eliminating the ability to order on a manual basis"; Qwest is correcting information in the PCAT that is currently incorrect. The ability to order two-way suspensions on a manual basis will remain intact and the PCAT will be corrected to reflect the exceptions for OR and WA (non-DMS10 and DMS100 switches) where this capability is not available.

MCI Issue: MCI contracts and FCC regulations require that Qwest provide all features available with a particular switch. What this means is that MCI is not limited to what Qwest provides its retail customers. MCI must be provided access to existing features to be able to innovate and provide competition to our customers. Thus, Qwest cannot restrict two-way suspensions.

Qwest Response: Qwest does not agree that we are arbitrarily restricting two-way suspensions or otherwise not providing MCI with access to features in a particular switch. To summarize Qwest’s position: ? Two-Way Suspensions are not currently identified as a UNE in either the ICA or SGAT. ? Due to regulatory constraints in OR and WA, Qwest is prohibited from providing two-way suspensions in those states, with the specific exception of DMS10 and DMS100 switches. ? MCI has the opportunity to pursue this switch capability through the SRP, obtain this function as a UNE, if approved, and bring to closure the issues associated with the OR and WA regulatory limitations.

In conclusion, the request to allow financial suspend orders to flow through for WA, OR, and ID-N, and that Qwest process two-way suspensions consistently across Qwest’s 14 state footprint will remain in deny status.

Please contact me by telephone at (303) 965-3709, or by e-mail at Loretta.A.Huff@qwest.com if you have any additional questions.

Sincerely, Loretta Huff Senior Director/Wholesale Service Delivery Qwest

January 9, 2004 Escalation Received from Liz Balvin, MCI: Description: Inappropriate denial from Qwest to allow financial suspend orders to flow through for WA, OR, and ID-N. In addition, process two-way suspensions consistently across Qwest 14 state footprint. History: Qwest documented procedures... URL: http://www.qwest.com/wholesale/pcat/tdnpr.html ...states "State: Arizona, Colorado, Southern Idaho, Iowa, Minnesota, Montana, Nebraska, New Mexico, North Dakota, South Dakota, Utah, or Wyoming Switch Type: All Types Type of Restriction: Outgoing and incoming calls State: Northern Idaho, Washington or Oregon Switch Type: All Types except DMS Type of Restriction: Outgoing Only NOTE: For two-way temporary disconnects, you must issue your request manually and note in REMARKS "two-way denial". State: Northern Idaho, Washington or Oregon Switch Type: DMS Type of Restriction: Outgoing and incoming calls"

NOTE: Qwest provides ability to order two-way suspensions in the Western Region on a manual basis.

Upon receipt of MCI's change request to systematically allow the ordering of two-way suspensions, Qwest not only denied the CR based on retail tariff language but is expected to update the above documentation such that CLECs cannot order entirely. Qwest stated "This compliance entails revisions of the PCAT language as well as revision to methods regarding the manual process for 2-way suspensions. The revision to methods has been completed and the revision to the PCAT is in progress" (email from Qwest 11/18/03).

MCI Interconnect Agreements (ICA's) state "Access to Unbundled Local Switching encompasses line-side and trunk-side facilities, plus the features, functions, and capabilities of the Switch. The features, functions, and capabilities of the Switch include the basic switching function, as well as the same basic capabilities that are available to Qwest's End User Customers. Unbundled Local Switching also includes access to all vertical features that the Switch is capable of providing, as well as any technically-feasible customized routing functions" (SGAT section 9.11.1.1)" Thus, when ordering UNE-P POTS, MCI's ICA's apply, not Qwest retail tariff.

In addition to MCI's ICA's, the FCC regulations require Qwest to provide MCI all the features and functions of the switch when we buy switching unbundled network elements (UNEs) (47 CFR Section 51.319(c)(1). Qwest denial states "Although the switch may have capability of two-way denial, the State Commission does not allow for this practice." (12/30/03 Email from Qwest) Please note, this restriction applies to Qwest retail ONLY, not wholesale whereby contract language supercedes.

Reason for Escalation: Qwest inappropriately denied MCI's change request SCR070103-01. Not only is Qwest denying the systematic means to order two-way suspension but intends to eliminate the ability to order on a manual basis, restricting CLECs all together.

Business need and impact: MCI contracts and FCC regulations require that Qwest provide all features available with a particular switch. What this means is that MCI is not limited to what Qwest provides its retail customers. MCI must be provided access to existing features to be able to innovate and provide competition to our customers. Thus, Qwest cannot restrict two-way suspensions.

Desired CLEC resolution: That Qwest continue to support the manual means and allow the systematic means to order two-way suspensions in the Western Region for UNE-P POTS. Given this CR was initiated by MCI July 1, 2003 (over 6 months ago), MCI recommends this CR become eligible for 16.0 prioritization.

CLEC contact information: Name: Liz Balvin Title: Sr. Carrier Management Project Manager Phone #: 303-217-7305 Email: Liz.Balvin@mci.com

Qwest binding response due 7 calendar days after sending acknowledgement e-mail, expected no later than 1/19/04.

Liz Balvin MCI Carrier Management - Qwest Region

- January 8, 2004 Email Sent to Liz Balvin/MCI: Hi Liz, I can see where this might be confusing. Although the switch has the capability for a 2-way suspension, the state commission does not allow for a 2-way denial. The tariff exception is there for specifically DMS-100 and DMS-10 central offices, due to their inability to provision a 1-way denial. The difference is in the fact that the DMS-10 and DMS100’s technically cannot provision a 1-way denial. I am attaching a current copy of your CR. It contains the response to the action item that came out of the December CMP Meeting. This CR will be included in the January CMP Distribution Package, for the discussion of the action item (Attachment I). Does that help? Peggy Esquibel-Reed Qwest CMP CRPM -- Systems

- January 7, 2004 Email Received From Liz Balvin/MCI: Peggy, Qwest response to this CR (email from you dated 11/18/03) stated: "Based upon further investigation, resulting from our November 3, 2003 conference call, this CR will remain in Denied status. Qwest has reviewed tariffs for all 14 states and will be in compliance with the tariff's. Due to Tariff regulations in OR & WA, only 1-Way deny orders are permissible. A 1-Way deny order to block outgoing local calls will be provisioned. THE ONLY EXCEPTION TO THE TARIFF REGULATION IS IN DMS-100 AND DMS-10 CENTRAL OFFICES WHEN THERE IS NOT THE ABILITY TO PROVISION A 1-WAY DENIAL."

Qwest below response states: "This CR will continue to remain in a denied status. ALTHOUGH THE SWITCH MAY HAVE CAPABILITY OF A TW-WAY DENIAL, THE STATE COMMISSION DOES NOT ALLOW FOR THIS PRACTICE. Qwest's Consumer division has confirmed we do not provide a two-way suspension to our end users in the states of Washington or Oregon complying with the requirements of those states."

These statements IN CAPS are in direct conflict with each other, please advise. Thanks, Liz Balvin MCI Carrier Management - Qwest Region

December 30, 2003 Email Sent to Liz Balvin, MCI: Liz, This email is to provide you with the current written response to your CMP CR, SCR070103-01 (Allow financial suspend orders to flow through for WA, OR, and ID-N. In addition, process two-way suspensions consistenty across Qwest 14 state footprint). This is the response that was provided at the December Systems CMP Meeting, by Michelle Thacker in the Qwest Process Organization: "Additional research was conducted by Qwest regarding SCR070103-01. This CR will continue to remain in a denied status. Although the switch may have capability of a two-way denial, the state commission does not allow for this practice. Qwest’s Consumer division has confirmed we do not provide a two-way suspension to our end users in the states of Washington or Oregon complying with the requirements of those states. Michelle stated that current PCAT documentation indicating a manual process for two-way denial would be revised to reflect the position of the tariff. Michelle noted that should MCI wish to pursue two-way denial functionality in Washington and Oregon the SRP (Special Request Process) should be used and noted that details regarding the SRP process can be found in exhibit F of the state SGAT." This information will also be in the meeting minutes from the December Systems CMP Meeting, which you have already seen, and will also be added to the CR. Peggy Esquibel-Reed Qwest CMP CRPM -- Systems

-- December 17, 2003 Systems CMP Meeting Discussion of Action Item: Peggy Esquibel-Reed/Qwest stated that Liz has sent an email requesting additional information and that Michelle Thacker (Qwest) is on the bridge to respond. Michelle Thacker/Qwest stated that following each of the emails and conference calls over the last months, additional research was conducted by Qwest regarding SCR070103-01. This CR will continue to remain in a denied status. Although the switch may have capability of a two-way denial, the state commission does not allow for this practice. Qwest’s Consumer division has confirmed we do not provide a two-way suspension to our end users in the states of Washington or Oregon complying with the requirements of those states. Michelle stated that current PCAT documentation indicating a manual process for two-way denial would be revised to reflect the position of the tariff. Michelle noted that should MCI wish to pursue two-way denial functionality in Washington and Oregon the SRP (Special Request Process) should be used and noted that details regarding the SRP process can be found in exhibit F of the state SGAT. Liz Balvin/MCI asked for that response in writing. Peggy Esquibel-Reed/Qwest stated that she would send it to Liz. Liz Balvin/MCI asked if the PCAT was wrong in the statement regarding manual 2-way suspends. Michelle Thacker/Qwest responded yes and stated that the PCAT was being revised. Liz Balvin/MCI asked if Qwest performs 2-way suspends in DMS100 and DMS 10 switches? Michelle Thacker/Qwest stated that she would need to investigate that further in regard to the tariff language. Steve Kast/Qwest stated that Peggy Esquibel-Reed (Qwest) responded in an email dated November 18, 2003, to MCI, that "Based upon further investigation, resulting from our November 3, 2003 conference call, this CR will remain in Denied status. Qwest has reviewed tariffs for all 14 states and will be in compliance with the tariff's. Due to Tariff regulations in OR & WA, only 1-Way deny orders are permissible. A 1-Way deny order to block outgoing local calls will be provisioned. The only exception to the tariff regulation is in DMS-100 and DMS-10 central offices when there is not the ability to provision a 1-Way denial. In addition, Qwest has reviewed the Interconnection Agreement and found no reference to 2-way suspensions that would supercede the tariffs. This compliance entails revisions of the PCAT language as well as revision to methods regarding the manual process for 2-way suspensions. The revision to methods has been completed and the revision to the PCAT is in progress." Liz Balvin/MCI asked if that meant that 2-way is allowed in DMS100 and DMS10’s. Michelle Thacker/Qwest stated that she would look into the clarification of that question.

-- December 3, 2003 Email Received from MCI/Liz Balvin: Peggy, MCI ICA's provide the following language (example: Idaho SGAT section 9.11.1.1): "Access to Unbundled Local Switching encompasses line-side and trunk-side facilities, plus the features, functions, and capabilities of the Switch. The features, functions, and capabilities of the Switch include the basic switching function, as well as the same basic capabilities that are available to Qwest’s End User Customers. Unbundled Local Switching also includes access to all vertical features that the Switch is capable of providing, as well as any technically-feasible customized routing functions." Thus, MCI continues to object to the denial provided by Qwest that is defaulting to Tariff Language when our ICA's should apply. Please advise. Thanks, Liz Balvin MCI Carrier Management - Qwest Region

-- November 20, 2003 Systems CMP Meeting Discussion: Barb Carlson/Qwest stated that this CR remains in Denied Status. Barb stated that Qwest has reviewed tariffs for all 14-states and will be in compliance with those tariffs. Due to Tariff regulations in OR & WA, only 1-way deny orders are permissible. A 1-way deny order to block outgoing local calls will be provisioned. Barb further stated that the only exception to the tariff regulation is in DMS-100 and DMS-10 Central Offices when there is not the ability to provision a 1-way denial. Barb stated that in addition, Qwest has reviewed the Interconnection Agreement and found no reference to 2-way suspensions that would supercede the tariffs. Barb stated that this compliance entails revisions of the PCAT language as well as revisions to methods regarding the manual process for 2-way suspensions. The revision to methods has been completed and the revision to the PCAT is in progress. Liz Balvin/MCI stated that she is still not 100% clear why the Interconnection Agreement is not used and why Qwest is stating that suspensions are not in the Interconnection Agreement. Liz stated that she would like to discuss this with her legal team and requested that this matter remain open.

- November 18, 2003 Email sent to Liz Balvin/MCI: Liz, Based upon further investigation, resulting from our November 3, 2003 conference call, this CR will remain in Denied status. Qwest has reviewed tariffs for all 14 states and will be in compliance with the tariff's. Due to Tariff regulations in OR & WA, only 1-Way deny orders are permissible. A 1-Way deny order to block outgoing local calls will be provisioned. The only exception to the tariff regulation is in DMS-100 and DMS-10 central offices when there is not the ability to provision a 1-Way denial. In addition, Qwest has reviewed the Interconnection Agreement and found no reference to 2-way suspensions that would supercede the tariff's. This compliance entails revisions of the PCAT language as well as revision to methods regarding the manual process for 2-way suspensions. The revision to ethods has been completed and the revision to the PCAT is in progress. Barb Carlson will attend the Systems CMP Meeting on November 20th to share this same information with the CLEC Community and to answer your questions. Thank you, Peggy Esquibel-Reed Qwest CMP CRPM -- Systems

November 3, 2003 Conference Call Attendees: Liz Balvin/MCI, Michelle Singer-Nelson/MCI, T.D./MCI, Peggy Esquibel-Reed/Qwest, Lesley Wood/Qwest, Barb Carlson/Qwest, Kit Thomte/Qwest Peggy Esquibel-Reed/Qwest stated that the purpose of the call was to advise MCI that this CR, SCR070103-01, remains in Denied Status. Peggy stated that analysis was performed on the tariffs, across the 14-state region and the result of the analysis is that the CR is to remain Denied based on regulatory ruling/legal implications. Liz Balvin/MCI stated that she is questioning the denial due to the Qwest web site stating that the Western region allows 2-way suspensions, manually. Liz stated that she does not understand why the Interconnection Agreement would not apply here, and why Qwest is applying the denial based on tariffs. Liz stated that she believes that this request should be granted due to the Interconnection agreement. Liz stated that she questiones the denial for 2-reasons. The first reason is because Qwest currently allows on a manual basis, and secondly because the Interconnection Agreement should apply, not the tariff, because this is a UNE-P request and UNE-P is driven out of the Interconnection Agreement. Lesley Wood/Qwest stated that the Interconnection Agreement is a good point and stated that she is not entirely convinced that this is considered a UNE-P feature. Liz Balvin/MCI stated that it is a feature of the switch and that the Interconnection Agreement provides for switch features. Lesley Wood/Qwest stated that Qwest will need to take this back and review the Interconnection Agreement. Michelle Singer-Nelson/MCI stated that she is the regulatory representative and stated that prior to the next call, if Qwest's position remains the same, that more thorough information, in writing, is needed. Michelle stated that MCI is hoping that after Qwest looks into the Interconnection Agreements, that the denial will be reversed. Liz Balvin/MCI stated that she would like information ASAP and does not want this CR to miss being included in another IMA Prioritization. Peggy Esquibel-Reed/Qwest stated that Qwest will continue to research and schedule the next meeting as soon as the Interconnection Agreement research has been done. Peggy stated that the next IMA Prioritization is currently scheduled to take place after the November Systems CMP Meeting. The call was concluded.

-- October 30, 2003 Email Sent to Liz Balvin/MCI: Good Morning Liz -- I have scheduled the meeting to discuss SCR070103-01 as follows: DATE: Monday, November 3, 2003 TIME: 10:30 a.m. MT CALL IN: 1-877-564-8688 CONFERENCE ID: 8571927 Thanks, Peggy Esquibel-Reed Qwest CMP CRPM -- Systems

October 29, 2003 Email Received from Liz Balvin/MCI: Peggy, This Friday 10:30 or 11:00am or 2:30pm would work. Otherwise, Monday between 10:30 or 11:00 would also work. Thanks, Liz Balvin MCI Carrier Management - Qwest Region

October 29, 2003 Email Sent to Liz Balvin/MCI: Liz -- In response to your email....yes, you are correct in your statement below. Let me know when you are available to discuss this on a conference call. If you can give me several dates/times, that would be great. Thanks, Peggy Esquibel-Reed Qwest CMP CRPM -- Systems 303.382.5761

-- October 28, 2003 Email Received from Liz Balvin/MCI: Peggy, Please make sure I'm clear, that Qwest believes the following Tariff applies to wholesale orders: "Oregon - Exchange & Network Tariff, General Regulations -Conditions of Offering Service 2.2.9 (E) 1 & 2 Termination of Service - Company Initiated and Washington- Exchange and Network Services Tariff, General Regulations - Conditions of Offering Service, 2.3.6 Billing (G)1 - Temporary Disconnect Due to Nonpayment." Thanks, Liz Balvin MCI Carrier Management - Qwest Region

October 28, 2003 Email Sent to Liz Balvin/MCI: Hello Liz -- The response is that the CR will remain in Denied status. Qwest has reviewed tariffs for all 14 states and will be complying with the tariff verbiage. This compliance will entail revisions of the PCAT language as well as revision to methods regarding the manual process for 2-way suspensions. Peggy Esquibel-Reed Qwest CMP CRPM -- Systems

October 28, 2003 Email Received from Liz Balvin/MCI: Peggy, Then I would like the responses in writing prior to the call. Until I receive the answers I cannot schedule a call because I may need to coordinate with internal SME's. Thanks, Liz Balvin MCI Carrier Management - Qwest Region

- October 28, 2003 Email Sent to Liz Balvin/MCI: Liz, The CR will remain in Denied status and we would like to schedule a conference call with you in order to answer your questions in regard to the denial. Are you available Wednesday, October 29th at 2:00 MT? If you are not available at that time, please let me know what your availability is and I will schedule the call. Thank you, Peggy Esquibel-Reed Qwest CMP CRPM -- Systems

- October 28, 2003 Email Received from Liz Balvin/MCI: Peggy, I would appreciate the response in writing from Qwest prior to a scheduled call so that I can best prepare myself and if need be request MCI SME's. Thanks, Liz Balvin MCI Carrier Management - Qwest Region

October 28, 2003 Email sent to Liz Balvin/MCI: Hi Liz, I would like to schedule the meeting with you to discuss the denial of your submitted CMP CR, SCR070103-01 Allow financial suspend orders to flow through for WA, OR, and ID-N. In addition, process two-way suspensions consistenty across Qwest 14 state footprint. Please provide several dates/times, I will schedule the call, and send you the call-in information. Thanks, Peggy Esquibel-Reed Qwest CMP CRPM -- Systems 303.382.5761

- October 16, 2003 Systems CMP Meeting Discussion: Phyllis Sunins/Qwest stated that the investigation is continuing. Liz Balvin/MCI stated that this CR was denied over a month ago and asked why it is taking so long to figure this out. Phyllis Sunins/Qwest stated that Qwest wants to make sure that the right decision was made and that accurate information will be provided as the investigation results. Liz Balvin/MCI stated that this CR was postponed from the 15.0 vote and does not want to wait until November CMP for the answer. Peggy Esquibel-Reed/Qwest stated that a meeting will be scheduled with MCI as soon as the investigation has been completed. There were no additional questions or comments.

October 8, 2003 Email to Liz Balvin - MCI: Hello Liz, RE: Allow financial suspend orders to flow through for WA, OR, and ID-N. In addition, process two-way suspensions consistently across Qwest 14 state footprint. I just wanted to send you an email to let you know that I have not forgotten about you or your CR. We are still doing some analysis and will schedule the meeting with you as soon as the analysis is complete. This should only take a few more weeks. Thank you so much for your patience. The action items associated to the CR will be in the October Systems Distribution Package for next week's CMP Meeting. The update will be that we are continuing to research the issue. Thanks, Peggy Esquibel-Reed Qwest CMP CRPM -- Systems

-- September 18, 2003 Systems CMP Meeting Discussion: Peggy Esquibel-Reed/Qwest stated that a meeting has been held with Qwest and MCI and noted that a follow-up meeting will be scheduled to communicate the results of the continued investigation. Liz Balvin/MCI asked what Qwest was investigating. Peggy Esquibel-Reed/Qwest stated that Qwest is analyzing the denial and looking into tariff interpretations. Stephanie Prull/McLeod asked that the information that is to be shared with MCI be shared with the CLEC Community. Liz Balvin/MCI stated that 2-way suspensions could be done manually and noted that the denial was based on the tariff language. Peggy Esquibel-Reed/Qwest stated that a follow-up call would be scheduled with MCI and that an action item would be created to share the information with the CLEC Community at a CMP Meeting. This Action Item remains open.

- September 5, 2003 Email Sent to Liz Balvin/MCI: Hi Liz -- I have scheduled the follow-up meeting to discuss 2-way suspensions. Meeting details are: DATE: Friday, September 12, 2003 TIME: 9:00 a.m. CALL-IN#: 1-877-564-8688 CONFERENCE ID: 8571927 Thanks, Peggy Esquibel-Reed Qwest CRPM -- System

September 5, 2003 Conference Call: ATTENDEES: Liz Balvin/MCI, Barb Carlson/Qwest, and Peggy Esquibel Reed/Qwest DISCUSSION: Peggy Esquibel Reed/Qwest stated that the purpose of the call was to discuss the Denial of MCI’s request, SCR070103-1 Allow financial suspend orders to flow through for WA, OR, and ID-N. In addition, process two-way suspensions consistently across Qwest 14 state footprint. Peggy Esquibel Reed (Qwest) stated that the Qwest has reviewed the denial and that the denial would stand based on the tariff references provided to MCI. Peggy asked Liz (MCI) if she had the opportunity to read the tariffs referenced. Liz Balvin/MCI stated that she had not, but that she had talked with her tariff folks about the denial. Liz stated that MCI’s request is for mechanization of 2-way suspensions. Liz stated that Qwest does this manually today and does not understand why it cannot be mechanized. Peggy Esquibel Reed/Qwest stated that it is not a question of whether it can be mechanized, the denial is based on the language in the tariffs. Peggy read the excerpt from the tariffs: Oregon - Exchange & Network Tariff, General Regulations -Conditions of Offering Service 2.2.9 (E) 1 states "Temporary disconnect means the service will be restricted to either incoming or outgoing service." The Washington- Exchange and Network Services Tariff, General Regulations - Conditions of Offering Service, 2.3.6 Billing (G) 1 states "Temporary disconnection means the service will be restricted to either incoming or outgoing service." Liz Balvin/MCI stated that the PCAT states that for two-way temporary disconnects, you must issue your request manually and note in REMARKS "two-way denial". Liz asked that if Qwest is currently doing manually, why would Qwest not mechanize it and asked that if it is the tariff for 1-way only, why is Qwest doing it manually. Barb Carlson/Qwest stated that she would take an action item to check into why 2-way suspends are occurring manually. Liz Balvin/MCI stated that the CR also requested that suspends flow through and stated that the denial did not address that piece. Barb Carlson/Qwest stated that suspends do currently flow through for a 1-way suspend. Liz Balvin/MCI stated that they are receiving rejects. Barb Carlson/Qwest stated that the 1-way suspends are flowing through and asked Liz for examples of the rejects so she can check into them. Barb noted that not every switch allows it to flow through, such as a DMS restriction. Liz Balvin/MCI stated that she understood that and stated that she believes that MCI is getting rejects. Liz agreed to provide examples of 1-way suspends not flowing through. Peggy Esquibel-Reed/Qwest stated that another call would be scheduled to discuss the action items and asked Liz for her availability. Liz Balvin/MCI stated that next Thursday or Friday would work. Peggy Esquibel-Reed/Qwest concluded the call and stated that the follow-up call details would be emailed today.

- September 4, 2003 Email Sent to Liz Balvin/MCI: Hi Liz, I am now the CRPM for your submitted CMP CR, SCR070103-01 Allow financial suspend orders to flow through for WA, OR, and ID-N. In addition, process two-way suspensions consistenty across Qwest 14 state footprint. I have scheduled a conference call to discuss the Qwest Response to this request. Call details are: DATE: Friday, September 5, 2003 TIME: 9:00 a.m. CALL IN #: 1-877-564-8688 CONFERENCE ID: 8571927 Thank you, Peggy Esquibel-Reed Qwest CRPM -- Systems

- September 2, 2003 Email from Liz Balvin/MCI: Laurel, Please verify I understand what we are attempting to accomplish: The CR states "allow financial suspend orders to flow through for WA, OR, and ID-N. In addition, process two-way suspensions consistently across Qwest 14 state footprint." Qwest response states "regulation prohibits Qwest from offering automatic two-way suspensions in Washington, Oregon, and Northern Idaho. The tariff information can be found the in following sections: Oregon - Exchange & Network Tariff, General Regulations -Conditions of Offering Service 2.2.9 (E) 1 & 2 Termination of Service - Company Initiated and Washington- Exchange and Network Services Tariff, General Regulations - Conditions of Offering Service, 2.3.6 Billing (G)1 - Temporary Disconnect Due to Nonpayment."

MCI questioned the denial based on the following: 1) The Part I of the CR requested financial suspends to flow through in the Western Region. The Qwest response did not address this portion of the request. 2) Part II of the CR requested that two-way suspensions be processed consistently across Qwest 14 state footprint. Per Qwest documentation, two-way suspensions can be ordered in the Western Region but only on a manual basis (see following): URL: http://www.qwest.com/wholesale/pcat/tdnpr.html State: Arizona, Colorado, Southern Idaho, Iowa, Minnesota, Montana, Nebraska, New Mexico, North Dakota, South Dakota, Utah, or Wyoming Switch Type: All Types Type of Restriction: Outgoing and incoming calls State: Northern Idaho, Washington or Oregon Switch Type: All Types except DMS Type of Restriction: Outgoing Only NOTE: For two-way temporary disconnects, you must issue your request manually and note in REMARKS "two-way denial".

State: Northern Idaho, Washington or Oregon Switch Type: DMS Type of Restriction: Outgoing and incoming calls

Thus, MCI questioned why two-way suspensions could be handled manually and yet restricted systematically. I am available Thursday or Friday during the following times: Thursday all but between 10 - 11 am. Friday all but between 2 - 3 pm. Thanks, Liz Balvin MCI Carrier Management - Qwest

- August 21, 2003 Systems CMP Meeting Discussion: Laurel Nolan/Qwest reviewed the denial and stated that Qwest was unable to fulfill this request because of the tariffs in WA, OR and ID-N. Liz Balvin/MCI stated that she had checked with her legal team and that they could not find any language stating that the two-way denials could not flow through. She stated that they wanted the ability to have two-way suspensions performed. She continued that she didn’t understand why the request was denied for two-way because currently Qwest can complete this function manually. Liz then stated that she still wants the ability for two-way suspension. Laurel Nolan/Qwest stated that she would schedule a call between MCI and Qwest SMEs to discuss further. Liz Balvin/MCI agreed.

- Email from Laurel Nolan to Liz Balvin August 14, 2003 Liz, Per our conversation, Qwest is unable to provide flow through of 2-way denials in Northern Idaho, Washington, and Oregon due to the tariff. Through our research it was determined that 1-way denials do flow through in these areas and that 2-way denials do flow through in the other states. If you believe that the system is not working according to the above statement it would be wonderful if you could provide examples. I would also be happy to host a call between Qwest SMEs and MCI if you believe it would be helpful. Thanks, Laurel CMP

--Original Message-- From: Elizabeth Balvin [mailto:liz.balvin@mci.com] Sent: Thursday, August 14, 2003 9:02 AM To: 'Nolan, Laurel' Subject: RE: SCR070103-01, Allow financial suspend orders to flow through for WA, OR, and ID-N. In addition, process two-way suspensions consistently across Qwest's 14 state footprint.

Laurel, Is Qwest denying the request to allow financial suspend order to flow-through as well? Thanks, Liz Balvin MCI Carrier Management - Qwest Internal Line - V625-7305 External Line - 303-217-7305 Pager (888) 900-7221

--Original Message-- From: Nolan, Laurel [mailto:Laurel.Nolan@qwest.com] Sent: Wednesday, August 13, 2003 4:21 PM To: Liz Balvin (E-mail) Cc: Nolan, Laurel Subject: SCR070103-01, Allow financial suspend orders to flow through for WA, OR, and ID-N. In addition, process two-way suspensions consistently across Qwest's 14 state footprint.

Liz, Attached is the response to SCR070103-01, Allow financial suspend orders to flow through for WA, OR, and ID-N. In addition, process two-way suspensions consistently across Qwest's 14 state footprint. This CR will also be discussed in next week's CMP Meeting. Thanks, Laurel Nolan Qwest Communications CMP-Systems 303.965.3715 laurel.nolan@qwest.com

Clarification Meeting July 10, 2003

Meeting attendees: Liz Balvin-MCI, Mary Hunt-MCI, Qiana Davis-Qwest, John Ebert-Qwest, Suzy Enney-Qwest, Laurel Nolan-CRPM Qwest Review of request and confirm expected deliverables: Nolan-Qwest reviewed the written request and expected deliverable. She asked MCI if there were any additions. None. She then asked Qwest if there were any questions. Davis-Qwest asked if MCI was viewing financial suspends the same as vacation suspends. Hunt-MCI stated no, that she was talking about denies and that she was refering to the PCAT for Temporary Disconnects for Non-Payment. Ebert-Qwest stated that there were particial and full denies. Davis-Qwest discussed inbound vs. outbound. Hunt-MCI stated that there was no consitency between Northern Idaho, WA, and OR except for DMS switches. She stated that they have to put the information in the remarks field and that they didn't want to have to do that. Balvin-MCI stated that they wanted it automated. Hunt-MCI stated that either solution would work. Ebert-Qwest stated that MCI was requesting for one automated process across all states. Confirm interfaces and products impacted: Nolan-Qwest stated that she believed that this request should be IMA Common. Balvin-MCI agreed. Nolan-Qwest stated that she would change the CR. Action plan: Nolan-Qwest stated that this CR would be presented by Balvin-MCI in the August meeting and that Qwest would work to provide a response prior to the meeting. She asked if there were any other questions or concerns. None. Meeting adjourned.

CenturyLink Response

Liz Balvin MCI

Dear Ms. Balvin:

This letter is concerning the Escalation Response Qwest submitted to you on January 19, 2004. Qwest continued to review this escalation response, based on MCI’s request, and has determined that the CMP Change Request (CR) will be changed from a 'Denied' to an 'Active' status. Qwest, through the Wholesale Change Management Process (CMP), will work with MCI and the CLEC community in determining the necessary systems/operations changes and timelines required for this CR.

In CMP CR SCR070103-01-E20, MCI requested two way suspensions for UNE-P and Resale. Qwest will be working to implement this request for UNE-P, however Qwest will continue to offer the same suspension services on resold accounts that it offers Qwest retail customers. At this time, Qwest offers two way suspension orders to Qwest retail customers in Washington, Oregon, and Northern Idaho when those customers are served from Nortel DMS-10 and DMS-100 central offices. In all other cases, Qwest offers one way suspension services to Qwest retail customers in these states. The one-way suspension allows Qwest retail customers to receive incoming calls.

Please contact me by telephone at (303) 965-3709, or by e-mail at Loretta.A.Huff@qwest.com if you have any additional questions.

Sincerely, Loretta Huff Senior Director/Wholesale Service Delivery Qwest

-- January 19, 2004 Qwest Response to Escalation SCR070103-01-E20: Liz, Attached is the Qwest response to your escalation # SCR070103-01-E20. Please let me know if you have any questions. Thanks, Jim:

Escalation # SCR070103-01-E20 January 19, 2004

Liz Balvin MCI

Dear Ms. Balvin:

This letter is in response to MCI Escalation # SCR070103-01-E20 regarding the MCI position that Qwest inappropriately denied to allow financial suspend orders to flow through for WA, OR, and ID-N, and that Qwest process two-way suspensions consistently across Qwest 14 state footprint. The MCI issues, in blue font, raised in this escalation and the associated Qwest responses are as follow:

MCI Issue: Qwest documented procedures URL: http://www.qwest.com/wholesale/pcat/tdnpr.html states "State: Arizona, Colorado, Southern Idaho, Iowa, Minnesota, Montana, Nebraska, New Mexico, North Dakota, South Dakota, Utah, or Wyoming Switch Type: All Types Type of Restriction: Outgoing and incoming calls State: Northern Idaho, Washington or Oregon Switch Type: All Types except DMS Type of Restriction: Outgoing Only NOTE: For two-way temporary disconnects, you must issue your request manually and note in REMARKS "two-way denial". State: Northern Idaho, Washington or Oregon Switch Type: DMS Type of Restriction: Outgoing and incoming calls". NOTE: Qwest provides ability to order two-way suspensions in the Western Region on a manual basis.

Qwest Response: Qwest agrees that the information in the Temporary Disconnection for Non-payment/Restore PCAT is not clear and (for WA and OR) is incorrect (see #2 below). To clarify, in states other than WA and OR, where two-way suspensions are allowed and provided, the process for requesting two-way suspensions is as described in the PCAT. Qwest will update the PCAT to both clarify the process and application for two-way suspensions and correct the PCAT relative to the regulatory restrictions for WA and OR, (see the next Qwest Response below).

MCI Issue: Upon receipt of MCI's change request to systematically allow the ordering of two-way suspensions, Qwest not only denied the CR based on retail tariff language but is expected to update the above documentation such that CLECs cannot order entirely. Qwest stated "This compliance entails revisions of the PCAT language as well as revision to methods regarding the manual process for 2-way suspensions. The revision to methods has been completed and the revision to the PCAT is in progress" (email from Qwest 11/18/03).

Qwest Response: As indicated by Michelle Thacker on December 17, 2003, and subsequently provided via email on December 18, 2003 and documented in the CMP CR, the PCAT document located on URL: http://www.qwest.com/wholesale/pcat/tdnpr.html, is incorrect and will be revised to reflect the OR and WA state regulatory requirements of only allowing one-way suspensions of service except in DMS10 and DMS 100 switches where only two-way suspensions are technically feasible.

MCI Issue: MCI Interconnect Agreements (ICA's) state "Access to Unbundled Local Switching encompasses line-side and trunk-side facilities, plus the features, functions, and capabilities of the Switch. The features, functions, and capabilities of the Switch include the basic switching function, as well as the same basic capabilities that are available to Qwest's End User Customers. Unbundled Local Switching also includes access to all vertical features that the Switch is capable of providing, as well as any technically-feasible customized routing functions" (SGAT section 9.11.1.1)" Thus, when ordering UNE-P POTS, MCI's ICA's apply, not Qwest retail tariff.

Qwest Response: The switch capability associated with two-way suspensions is not currently listed/identified as a UNE in either existing Interconnection Agreements or Qwest’s SGAT. In addition, based on WA and OR state regulatory rules, Qwest is prohibited from providing two-way suspensions to customers in the states of WA and OR except in DMS10 and DMS100 switches which are technically limited to a two-way suspension switch functionality.

MCI Issue: In addition to MCI's ICA's, the FCC regulations require Qwest to provide MCI all the features and functions of the switch when we buy switching unbundled network elements (UNEs) (47 CFR Section 51.319(c)(1). Qwest denial states "Although the switch may have capability of two-way denial, the State Commission does not allow for this practice." (12/30/03 Email from Qwest) Please note, this restriction applies to Qwest retail ONLY, not wholesale whereby contract language supercedes.

Qwest Response: Qwest continues to recommend that MCI pursue two-way suspensions in OR and WA by way of the Special Request Process (SRP). A SRP request would determine if two-way suspensions are technically feasible in the switches in OR and WA, and would result in an ICA amendment that would go before the OR and WA state commissions for review/approval. This would bring the issue of OR and WA’s current position on two-way suspensions to those state commissions for either approval for MCI and Qwest to move forward in establishing this capability or would result in a continued denial of MCI’s request (assumedly for the same reasons those state commissions do not allow Qwest to do two-way suspensions in those states).

MCI Issue: Qwest inappropriately denied MCI's change request SCR070103-01. Not only is Qwest denying the systematic means to order two-way suspension but intends to eliminate the ability to order on a manual basis, restricting CLECs all together.

Qwest Response: Qwest does not agree that the denial of MCI’s change request SCR070103-01 is inappropriate. In addition, Qwest is not "eliminating the ability to order on a manual basis"; Qwest is correcting information in the PCAT that is currently incorrect. The ability to order two-way suspensions on a manual basis will remain intact and the PCAT will be corrected to reflect the exceptions for OR and WA (non-DMS10 and DMS100 switches) where this capability is not available.

MCI Issue: MCI contracts and FCC regulations require that Qwest provide all features available with a particular switch. What this means is that MCI is not limited to what Qwest provides its retail customers. MCI must be provided access to existing features to be able to innovate and provide competition to our customers. Thus, Qwest cannot restrict two-way suspensions.

Qwest Response: Qwest does not agree that we are arbitrarily restricting two-way suspensions or otherwise not providing MCI with access to features in a particular switch. To summarize Qwest’s position: ? Two-Way Suspensions are not currently identified as a UNE in either the ICA or SGAT. ? Due to regulatory constraints in OR and WA, Qwest is prohibited from providing two-way suspensions in those states, with the specific exception of DMS10 and DMS100 switches. ? MCI has the opportunity to pursue this switch capability through the SRP, obtain this function as a UNE, if approved, and bring to closure the issues associated with the OR and WA regulatory limitations.

In conclusion, the request to allow financial suspend orders to flow through for WA, OR, and ID-N, and that Qwest process two-way suspensions consistently across Qwest’s 14 state footprint will remain in deny status.

Please contact me by telephone at (303) 965-3709, or by e-mail at Loretta.A.Huff@qwest.com if you have any additional questions.

Sincerely, Loretta Huff Senior Director/Wholesale Service Delivery Qwest

-- REVISED RESPONSE August 13, 2003

Liz Balvin MCI

CC: Lynn Notarianni Connie Winston Beth Foster Kit Thomte

This letter is in response to CLEC Change Request number SCR070103-01, dated 07/01/03, titled: Allow financial suspend orders to flow through for WA, OR, and ID-N. In addition, process two-way suspensions consistently across Qwest’s 14 state footprint.

CR Description: “Financial suspend orders in WA, OR and ID-N currently require manual handling. MCI seeks automation of financial suspend orders in the Western Region. In addition, two-way suspensions are not consistent across Qwest 14 state footprint. MCI seeks to have two-way suspensions processed in one of the two methods consistently: 1) Automatic two way suspension or 2) Make use of the suspend type field across all states to specify if the suspension should be one-way or two-way”

Expected Deliverable: “That financial suspend orders flow through for Western Region and two-way suspensions are consistently processed throughout Qwest’s 14 state footprint.”

History: A clarification meeting was held on July 10, 2003 with MCI and Qwest representation.

Qwest Response: Qwest has completed an analysis for CR SCR070103-01, dated 07/01/03, titled: Allow financial suspend orders to flow through for WA, OR, and ID-N. Through Qwest’s analysis it was determined that regulation prohibits Qwest from offering automatic two-way suspensions in Washington, Oregon, and Northern Idaho. The tariff information can be found the in following sections: Oregon - Exchange & Network Tariff, General Regulations -Conditions of Offering Service 2.2.9 (E) 1 & 2 Termination of Service - Company Initiated and Washington- Exchange and Network Services Tariff, General Regulations – Conditions of Offering Service, 2.3.6 Billing (G)1 - Temporary Disconnect Due to Nonpayment.

Qwest is denying your request for CR SCR070103-01, dated 07/01/03, titled: Allow financial suspend orders to flow through for WA, OR, and ID-N based on regulatory ruling/legal implications.

Sincerely,

Qwest