Wholesale: Products & Services

Archived System CR SCR082808-01IGX Detail

Integra communicates the type of service it intends to provide on 2/4 Wire Non-Loaded Loops by using the appropriate NCI/SECNCI codes on the Local Service Request (LSR). However, Qwest has indicated that it now designs, provisions and repairs the circuits to voice grade parameters measured at 1004 Hz, regardless of the NCI/SECNCI code requested on the LSR. The Network Code NC: LX-N indicates that a CLEC is ordering within the Non-Loaded Loop family. As discussed below, it supports a number of digital services depending upon the NCI/SECNCI codes provided on the LSR (e,g., Digital DS0 Level, Advanced Digital Transport, ADSL, Basic Rate ISDN, HDSL2 …). Therefore, an order of LX-N with the NCI code of 02QB9.00H and a secondary NCI code (“SEC”) of NCI 02DU9.00H tells Qwest that it needs to provision, test, and repair for HDSL2 capable service. For example, Qwest needs to ensure that the loop meets the appropriate performance parameters. Each digital service has its own parameters, such as:

• Voice grade analog circuit with Loss at 0 to -8.5 dB at 1004 Hz

• ISDN service Loss at less than 40 dB at 40 kHz

• ADSL service Loss at less than 41 dB at 196 kHz

• HDSL2 service Loss at less than 28 dB at 196 kHz.

When Integra raised the issue of Qwest limiting digital services to voice grade parameters with its Qwest Service Management team, Qwest responded by indicating that “Qwest does not provision requests to meet a specific facility or technology, but rather provisions a class of service, based on the NC codes the CLEC orders.” Integra continues to believe that its current Interconnection Agreements (“ICAs”) require Qwest to provide unbundled loops that transmit digital signals in addition to voice-grade service, etc. Integra reserves its rights under its ICAs. At the same time, in an effort to resolve this issue and at the request of Qwest, Integra is requesting in CMP that Qwest develop and maintain the process and procedures needed to design, provision, test and repair Unbundled Loops so that the circuit will conform to the requirements requested by CLEC, including compliance with the industry standards for the NCI/SECNCI code provided on the LSR. On 7/23/08, Qwest proposed that Integra submit a change request in CMP, including asking Qwest to design, provision, test and repair services in way that takes into account NCI/SECNCI codes standards instead of just the NC codes. Integra includes that request in this CR.

Qwest’s Technical Publication 77384 indicates that a number of advanced digital services are provisioned on Non-Loaded Loops (NC: LX-N), using a variety of NCI/SECNCI codes (for example: Advanced Digital Transport in a variety of spectrum classes, Basic ISDN – NCI: 02QC5.OOS, HDSL - NCI: 02QB9.00H). Qwest’s Technical Publications indicate that the NCI/SECNCI codes conform to the various ANSI standards for the specific digital service. However, as noted earlier, the Qwest service management team confirmed that it is Qwest’s current practice to design, provision, test and repair these digital services delivered on Unbundled Loops based on the NC code which delivers voice grade parameters measured at 1004Hz, even though each digital service has its own parameters for optimum performance. Integra is requesting that Qwest use the industry standards for NCI/SECNCI codes provided on the LSR when designing, provisioning, testing and repairing Unbundled Loops. For example, an Unbundled Loop ordered on the LSR with the Basic ISDN NCI: 02QC5.OOS should be designed, provisioned, tested and repaired per industry standards using a loss based on 40 kHz, not the voice grade 1004 Hz. Additionally, an Unbundled Loop ordered on an LSR with HDSL NCI 02QB9.00H should be provisioned using loss based on 196 kHz. When Qwest grandparented the ADSL compatible loop (only for CLECs without any ADSL compatible loop terms in their ICAs), Qwest pointed to the 2 Wire Non-Loaded Loop as an alternative to the ADSL compatible loop. However, per Qwest’s current stated position regarding designing, provisioning, testing and repairing to the NC code only, the 2 Wire Non-Loaded Loop would not be a reliable or serviceable alternative to an ADSL compatible loop. For a 2 Wire Non-Loaded loop to be a viable alternative to an ADSL compatible loop, Qwest should design, provision, test and repair digital capable Non-Loaded loops (such as HDSL capable or ADSL compatible loops) based on the NCI code as well.

While Qwest has said that it does not provision requests to meet a specific facility or technology, it should provision requests in compliance with industry standards and as ordered by CLEC, including providing working digital capability/compatibility when that capability is ordered. The SGATs, like the recent Qwest-Eschelon Minnesota and Arizona ICAs (§9.2.2.3), define 2/4 wire non-loaded loops as “digital capable” loops. The SGATs and the recent Qwest-Eschelon ICAs (§9.2.2.1.1 & 9.2.2.1.2) provide that use of the words “capable” and “compatible” to describe Loops means that Qwest assures that the Loop meets the technical standards associated with the specified Network Channel/Network Channel Interface codes, as contained in the relevant technical publications and industry standards. Qwest’s stated position that its current process recognizes only the “Network Channel” code but not the “Network Channel Interface” is inconsistent with this long-established principle. Similarly, the Qwest-Integra Oregon ICA has been in place since 2000 (for Integra as well as other CLECs, as it is based on the Qwest-AT&T ICA). That ICA (Att. 3, §2.1 and subparts) defines an unbundled loop to include loops that transmit digital signals and provides that CLEC may order special copper loops unfettered by any intervening equipment and which do not contain any bridged taps, so that CLEC may use the loops for a variety of services by attaching appropriate equipment. For example, when a CLEC orders an HDSL2 capable loop (identified on the LSR by using the NC code of LX-N with the NCI code of 02QB9.00H and a SEC code of NCI 02DU9.00H), the CLEC should receive a loop unfettered by intervening equipment so that CLEC may provide working HDSL2 service over the HDSL2 capable loop by attaching appropriate equipment. Regarding repair after a Qwest maintenance or modernization event, the SGATs and recent Qwest-Eschelon ICAs (§9.1.9) provide that network maintenance and modernization activities will result in UNE transmission parameters that are within transmission limits of the UNE ordered by CLEC. If CLEC orders a 2/4 wire non-loaded loop that is digital capable (such as ADSL compatible or HDSL2 capable), then the loop must be restored to the appropriate digital capable level after a Qwest maintenance or modernization event. In short, if a loop qualifies for a digital service, the circuit should work (and continue working) for that digital service.

Qwest will design, provision, test and repair Unbundled Loops to the requirements ordered by CLEC, including industry standards for the NCI/SECNCI codes provided on the LSR. Qwest should take into account NCI/SECNCI code standards, and not just the NC codes. When a CLEC orders a 2/4 wire non-loaded loop for providing a digital service (e.g., as identified using the applicable NCI/SECNCI code on the LSR), Qwest will not limit the design, provisioning or repair of 2/4 wire non-loaded loops to voice grade parameters (e.g., measured at 1004 Hz). After repairs and Qwest network maintenance and modernization changes, the end user customer’s service should work for the service ordered by CLEC.

Status History

Project Meetings

Mark Coyne – Qwest stated that this is the cross over CR that was discussed in the Product Process package.

10/1/08 E-mail sent to Integra

Hi Bonnie,

Qwest is still evaluating system impacts and will provide a readout in the October 15th CMP meeting.

Thanks,

Lynn Stecklein Qwest Wholesale CMP

10/01/08 E-mail from Integra

Hi Lynn, Would you please provide us with an update on this CR? Has Qwest determined if systems changes are needed? As I mentioned in my email and in CMP, this request/issue is not new to Qwest so the expectation is that we can determine systems needs quickly.

Thanks Lynn!!

Bonnie

9/17/08 Systems CMP Meeting

Susan Lorence-Qwest said that this request was submitted as a Product/Process CR. This CR is in the Systems Package because an industry guideline CR has to be submitted as a system CR per the CMP Document. If determination is made that there are no system changes the CR will be crossed over to a Product/Process CR. Bonnie Johnson-Integra said (9/25/08 Comments to minutes from Integra in bold) she will not read the entire CR request but that there have been a number of discussions with Qwest on these types of circuits and there is a lot of background and history. At a high level, Qwest advised Integra that regardless of the NCI code on requests for 2w/4w non loaded loops, Qwest installs, provisions and repairs to a voice grade level. She said that they are asking Qwest to provision and repair circuits based on the industry standards for the NCI/SECNCI Code instead of just the NC code. Susan Lorence-Qwest said that we held a clarification meeting on September 9th. She said that Bonnie provided ANSI T1.418 as the Industry Guideline. Bonnie Johnson-Integra said that was provided as an example and may not cover all of them. Qwest has a lot of codes already referenced in the tech pubs. We talked in the clarification call about the industry guideline CR having to be submitted as a system CR. She said that if there if no system work, the CR would be crossed over to a Product/Process CR. She said that they have been trying to address this issue for quite some time and have a concern about any delay. She said that there have been so many people engaged up to the VP level and they would like Qwest to respond ASAP on how soon this can be done. Susan Lorence-Qwest said that the SME team is already looking at the CR and that we will have a response by the next CMP meeting. She said that we hope to provide a response on whether we are accepting the change and whether there is system work involved. She said that once we determine if there is no system work involved, the CR will be crossed over to Product/Process. Bonnie Johnson-Integra said that they don’t believe they should have had to issue this CR but Qwest recommended that they do. She said that there are industry guidelines that Qwest should be repairing and provisioning their circuits to. She said that they have been trying to get this resolved for over a year and they don’t want to wait month after month for a response and will not be very patient. She said that anything Qwest can do to expedite the process would be appreciated.

E-mail Sent to Ingegra 9/9/08

Hi Bonnie,

The timeline for Product/Process and Sytems CR,as you know, are different. At this time it is unclear whether or not system work is involved. I am hoping that we can make that determination quickly to prevent any delay.

Thanks,

Lynn

--Original Message-- From: Johnson, Bonnie J. [mailto:bjjohnson@integratelecom.com] Sent: Tuesday, September 09, 2008 2:44 PM To: Stecklein, Lynn Subject: RE: PC082808-01IG

That is OK Lynn. We have been dealing with this for so long that Integra really does not want any delay. Would to time line be the same??

Bonnie J. Johnson| Director Carrier Relations direct 612.436.6218 | fax 612.436.6318 730 Second Avenue S | Suite 900 Minneapolis, MN 55402 bjjohnson@integratelecom.com

--Original Message-- From: Stecklein, Lynn [mailto:Lynn.Stecklein@qwest.com] Sent: Tuesday, September 09, 2008 3:38 PM To: Johnson, Bonnie J. Subject: RE: PC082808-01IG

Hi Bonnie,

I was going to change the CR number from PC082808-01IG to SCR082808-01IG and include it in the September Systems CMP Distribution Package. If we determine that no system work is needed then I will cross it over to a Product Process CR. What do you think?

Thanks!

Lynn Stecklein Qwest Wholesale CMP

--Original Message-- From: Johnson, Bonnie J. [mailto:bjjohnson@integratelecom.com] Sent: Tuesday, September 09, 2008 2:33 PM To: Stecklein, Lynn Subject: RE: PC082808-01IG

Hi Lynn! I dropped off before I heard your answer about the IG for process. Are we just going to leave it and acknowledge we missed a step??

Bonnie J. Johnson| Director Carrier Relations direct 612.436.6218 | fax 612.436.6318 730 Second Avenue S | Suite 900 Minneapolis, MN 55402 bjjohnson@integratelecom.com

--Original Message-- From: Stecklein, Lynn [mailto:Lynn.Stecklein@qwest.com] Sent: Tuesday, September 09, 2008 1:27 PM To: Johnson, Bonnie J. Subject: RE: PC082808-01IG

No problem Bonnie! I think we were done unless you had more to say. We thought you were there and didn't want to say goodbye! How funny.

Thanks,

Lynn

--Original Message-- From: Johnson, Bonnie J. [mailto:bjjohnson@integratelecom.com] Sent: Tuesday, September 09, 2008 12:25 PM To: Stecklein, Lynn Subject: RE: PC082808-01IG

Hi Lynn! I am sorry we got cut off. I pressed a wrong button and when we called back in you were not there. Why don't you call me!

Bonnie J. Johnson| Director Carrier Relations direct 612.436.6218 | fax 612.436.6318 730 Second Avenue S | Suite 900 Minneapolis, MN 55402 bjjohnson@integratelecom.com

--Original Message-- From: Stecklein, Lynn [mailto:Lynn.Stecklein@qwest.com] Sent: Tuesday, September 09, 2008 9:48 AM To: Johnson, Bonnie J. Cc: Isaacs, Kimberly D. Subject: RE: PC082808-01IG

Hi Bonnie,

We are having the clarification meeting as required per the CMP document. If at all possible, I would recommend that you bring the Integra SMEs that have been involved in these discussions.

Thanks!

Lynn Stecklein Qwest Wholesale CMP

--Original Message-- From: Johnson, Bonnie J. [mailto:bjjohnson@integratelecom.com] Sent: Tuesday, September 09, 2008 8:26 AM To: Stecklein, Lynn Cc: Isaacs, Kimberly D. Subject: RE: PC082808-01IG

Hi Lynn, When I submitted the CR, I stated because of the discussion and work between Qwest and Integra, I did not anticipate any questions during the clarification call. I was not planning on bringing any technical SMEs to the call as a result.

If I have a misunderstanding regarding Qwest's need for clarification, please let me know.

Maybe you could check with Bob and ask if he will have questions, and if so, on which subject so I know who to bring!!

Thanks Lynn!

Bonnie J. Johnson| Director Carrier Relations direct 612.436.6218 | fax 612.436.6318 730 Second Avenue S | Suite 900 Minneapolis, MN 55402 bjjohnson@integratelecom.com

--Original Message-- From: Stecklein, Lynn [mailto:Lynn.Stecklein@qwest.com] Sent: Tuesday, September 02, 2008 2:28 PM To: Johnson, Bonnie J. Subject: PC082808-01IG

Hi Bonnie!

Qwest has received the Change Request form you submitted August 28, 2008.

As a result of the request, PC082808-01IG has been created as a Product/Process CMP CR. This change request will be presented in the September Monthly CMP Meeting to be held on September 17, 2008. If you do not agree with the classification of this CR as a Product/Process request, please advise ASAP.

NOTE: The Qwest SMEs are not available this week for the clarification meeting. They are available on Tuesday, September 9th at 12:00 pm MT or Wednesday, September 10th at 9:00 am MT. Would either of these times work for you? If you can let me know, I will schedule the call and post it to the Wholesale Calendar

Attached for your reference is a current copy of your Change Request.

Your change request will appear in the next scheduled update of the "CMP Change Requests - Product/Process Report" on the Qwest CMP web site. You may access the interactive report at http://wwwqwest.com/wholesale/cmp/changerequest.html. (Scheduled updates take place every Monday, Wednesday, and Friday, except for Qwest holidays.)

If you have any questions, please feel free to contact me at Lynn.Stecklein@qwest.com.

Thank you,

Lynn Stecklein Qwest Wholesale CMP

9/9/08 Clarification Meeting for SCR082808-01IG (Previously assigned as PC082808-01IG)

Attendees: Bonnie Johnson-Integra, Doug Denney-Integra, Jamal Boudhaouia-Qwest, Bob Mohr-Qwest, Mary Dobesh-Qwest, Susan Lorence-Qwest, Lynn Stecklein-Qwest

Lynn Stecklein-Qwest said that the purpose of this meeting was to clarify the CR submitted by Integra. She said that the title of the CR is: Design, Provision, Test, and Repair Unbundled Loops to the requirements requested by CLEC, including NCI/SECNCI Code Industry Standards. She said that discussions have taken place between Integra and Qwest and that we understand what the CR is requesting but have additional questions. Lynn said that we also need to talk about the Industry Guideline classification later on in the call.

Jamal Boudhaouia-Qwest said that in the CR Integra references various ANSI standards and asked if they could direct him to what specific ANSI standards for which product they were looking for in terms of testing parameters. He said that his 2nd question had to do with what their expectation were in terms of the process in delivering to Integra from the Qwest perspective.

Bonnie Johnson-Integra asked for clarification on the 2nd question.

Jamal Boudhaouia-Qwest said that when our test centers perform to certain ANSI standards with the expectation that you want the test results sent back to you. Do you have any idea what the process would be for the centers to show you the results of that loop during provisioning and install. He said that when do the test on the loop at 196KHz, for example, and we know the db loss at that time is the expectation that Qwest deliver those tests to Integra.

Bonnie Johnson-Integra said that when you deliver test results now it is done verbally and sometimes via e-mail. This is refining a process.

Doug Denney-Integra asked if (9/12/08 - Comments to minutestfrom Integra) Qwest's position regarding test results was for results provided during the provisioning process.

Jamal Boudhaouia-Qwest said yes

Doug Denney-Integra said that there are different installation options that exist today and some of those require different degrees of test results being provided by Qwest. He said that those are described in the Carrier’s contracts and when we set up the cost for those options. He said they are not attempting to (9/12/08 Comments to minutes from Integra) change the process of providing test results with regard to provisioning loops.

Bonnie Johnson-Integra asked if ANSI T1.418 would answer Jamal’s question.

Jamal Boudhaouia-Qwest said he would have to look into it.

Bob Mohr-Qwest asked if on a basic install option Integra would not be looking for any test results on that type of installation option but for installations options where we provide them today and that is where the request is looking for additional test results.

Bonnie Johnson-Integra said that is correct and as long as it is provisioned and repaired to those results we don’t necessarily need to have the results as long as the practice is taking place.

Bob Mohr-Qwest said that Integra mentioned repair to those parameters. He asked if the expectation that once the circuit is turned up to those test parameters that there would be some certain guarantee above the non loaded loop.

Bonnie Johnson-Integra said that the reason they outlined this in the CR is because one of the things that brought this issue to light was a repair technician said that all he had to do was to repair to a voice grade level. She said if Qwest does some type of network modification and it changes the parameters and we open up a trouble ticket, the expectation is that Qwest would repair to those specifications.

Bob Mohr-Qwest asked if it would be to the specifications of the NC/NCI combination.

Bonnie Johnson-Integra said that was correct.

Lynn Stecklein-Qwest said that she reviewed the CMP Document (Section 5.1.3) and found that an Industry Guideline CR should be submitted as a System CR. If we find that there is no system work involved, the CR is then crossed over to a product/process CR.

Bonnie Johnson-Integra said that we forgot a step.

Lynn Stecklein-Qwest said that we did and that the CR should be changed to SCR082808-01IG and be included in the September Systems Distribution Package.

Lynn Stecklein-Qwest asked if Jamal had enough information on the ANSI standard.

Jamal Boudhaouia-Qwest said that he will have to research.

This CR will be presented in the September Systems CMP Meeting.

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