Wholesale: Products & Services

Open Product/Process CR 5608353 Detail

Description Of Change

Status History

Project Meetings

CenturyLink Response

This letter is in response to the following CLEC Change Request Forms #5263137, dated December 1, 2000 and #5608177 and #5608353, dated June 13, 2001. All of these Change Requests pertain to the CLEC to CLEC Migration process. The revised process was released via the Co-Provider Industry Change Management Process (CICMP) on May 25, 2001.

? Re-use of facilities for CLEC to CLEC carrier changes, improving the CLEC to CLEC reuse of facilities process and to ensure nondiscrimination.

? Response: The Qwest Release Notification Forms #5393537 (CLEC Unbundled Loop to CLEC Unbundled Loop), #5393543 (CLEC Unbundled Loop to CLEC Resale), and #5467108 (CLEC LNP with Unbundled Loop to CLEC Unbundled Loop) Revision B, released on May 25, 2001, noted changes in the Pre-Order section that the requirement to obtain the “Circuit Identification Number from the OLSP” is optional. Both Eschelon and Allegiance provided Qwest with examples of orders that were rejected by Qwest due to no Circuit Identification Number provided. After gap analysis, it was determined that additional training of Qwest Service Center personnel and updates to Service Delivery M&Ps were required. The following measures have been implemented:

? An updated Multi Channel Communicator (MCC) New or Changed Information Procedure was issued on July 9, 2001. ? Issued to target Qwest internal personnel in the Wholesale Customer Care, Customer Service, Error Group, Held Order/Escalation, Order Processing and Order Resolution organizations. ? Topic of the MCC: “CLEC to CLEC Migration of an Unbundled Loop and Unbundled Loop to other products.” ? CLEC to CLEC Migration is defined as; unbundled to unbundled, unbundled to resale, unbundled to Centrex resale. ? Emphasis placed on processing orders without circuit ids (ECCKT’s) on LSR requesting migration. ? States included in this communication are; AZ, CO, IA, ID-N, ID-S, MN, MT, ND, NE, NM, OR, Outside 14 State Region, SD, UT, WA and WY. ? All internal job aids and on-line support documentation have been updated. ? Qwest Service Center specific training sessions are currently in progress for both center coaches and center personnel. The training will be on going to ensure process compliance.

Sincerely

Nancy J. Hoag Qwest Wholesale Product Team

Open Product/Process CR PC073101-7 Detail

Description Of Change

Granted the process of the 48 pre-testing will catch most of these ahead of cut date, things happen on cut date that cannot be prevented. Allegiance wants the decision to bring the lines over or not to be the CLEC’s call.

Status History

Project Meetings

Action : Linda Hendricks will provide definition of Qwest 'flexibility' on cut date. Allegiance will submit a new CR to clarify the Qwest process when dial tone problems are on the Qwest side.

August 23rd, 2001 Clarification Meeting 1-866-289-7092 PC 741-1286 # PCCR073101-7

Terry Wicks/Allegiance Patrick Weston/Allegiance Doug Barman/Allegiance Linda Hendricks/Qwest Todd Mead/Qwest Introduction of Attendees Terry, Patrick, Doug, Linda and Todd Review Qwest Response Linda’s response to the original CR (PCCR073101-7) was discussed. Essentially Qwest will not hand over bad circuits to a CLEC. In mitigation, Qwest has implemented the 48/1 hour DT test on July 29, 2001 to resolve this issue. There is also the opportunity for the CLEC to split the order and have the bad circuits moved to another LSR. CLEC Response Allegiance accepted that when there is no DT on the Qwest side, Qwest should not hand over circuits until the problem has been resolved. Allegiance’s position is that they would still like to be able to take the circuit. If Qwest is consistently pre-testing on their side at least 48 hours prior to cut date, then the number of incidents of bad facilities on the Qwest side on cut date should be minimal. Allegiance will track and report accordingly. Allegiance will not pursue the issue at this point when the circuit is “bad” on the Qwest side. However, they will be pursuing to take the circuit when the problem is on Allegiance’s side. Allegiance agreed that the 48/1 hour DT test implemented on July 29 should substantially reduce the number of occurrences related to this issue on the Allegiance side. However, when the “no DT” is on the CLEC side, Allegiance wants to have the circuits passed over “as is”, and do not want to split the order. Allegiance has options to get the end user service on any “broken” line when the NDT is on their side. Once the TN is activated and Allegiance has the number in their switch, they can call forward the line to another line or to cell phones they supply to the end user. Allegiance has processes in place that they use daily with this type of situation when dealing with the other LECs. Allegiance would like to be able to use their processes in this situation with Qwest as well. Allegiance is prepared to escalate as needed if this cannot be resolved at this level. Confirm Right Personnel Involved Scott Simanson, VP and Fred Aesquivel Director (Qwest) need to be involved to make the final determination on Qwest’s position with respect to this issue. An internal meeting involving these people needs to take place. Todd will organize. Identify/Confirm CLEC’s Expectation Allegiance wants Qwest to hand over good circuits if the “no DT” is on the CLEC side. Allegiance stated every other ILEC they deal with (including PacBell, SW Bell, Bell North and South, Verizon and Ameritech) do this, as part of their normal business. Establish Action Plan (Resolution Time Frame) Review these minutes as an accurate account of this mornings discussion Set up a meeting with Scott, Fred and Linda to discuss Qwest’s position and draft a response. Set up a walk-through meeting with Allegiance to discuss the Qwest final response.

08/23/01 - Clarification Meeting Allegiance - Terry Wicks, Patrick Western, Doug Baram Qwest - Linda Hendricks, Todd Mead

Allegiance accepted that when there is no DT on the Qwest side, Qwest should not hand over circuits until the problem has been resolved. Allegiance agreed that the 48/1 hour DT test implemented on July 29 should substantially reduce the number of occurrences related to this issue. However, when the “no DT” is on the CLEC side, Allegiance wants to have the circuits passed over “as is”, and do not want to split the order.

08/09/01 - Alignment Meeting Terry Wicks/Allegiance Qwest - Scott Simanson, James Mackie,Dana Frenking, Linda Hendricks, John Moore, Cindy Buckmaster, Nancy Hoag, Lisa Schuzer

Turning up loops that do not meet Qwest test requirements or do not have CLEC DT on them. Their example was if they send in an LSR with 10 loops and 2 do not have CLEC DT on them or if Qwest has a facility problem, Qwest should allow Allegiance to make the decision to accept all of the orders even if problems exist. They want Qwest to close the order and open a repair ticket to provision the loops with the problems. No CLEC DT concern: Turning up loops that do not meet requirements will leave Qwest and the end user in a vulnerable position. If the CLEC decides they can't get DT working after we have closed the order and (if applicable had the translations ran), the end user customer could be out of service. Qwest wouldn't be able to work the order back, because it is closed. In order for the end user to get back to Qwest they would need to issue a WINBACK order and the CLEC would need to issue a disconnect order on the "BAD circuit/loop turned up". Qwest's facilities concern: If Qwest has the problem and our facilities are bad or maybe in some cases won't be built out at all, the following could occur if loop is turned up bad: mask facility issues on Qwest side (or perceive that is what we are doing) open the door for repair PID issues open our selves up to many issues from provisioning to repair PID measurement accuracy billing on a bad loop

CenturyLink Response

Wholesale Product Marketing

This letter is in response to the following CLEC Change Request Form PC073101-7 dated 07/30/2001. The Change Request related to Qwest’s current practice to not complete all circuits and/or orders on a given LSR, when there is known trouble either in the Qwest or CLEC network on one or more of the circuits being turned up.

In an effort to minimize the risk of the of an out of service condition during a migration, and to ensure the readiness of all parties to maximize success, Qwest has put the following process improvements in place:

48-Hour Dial Tone Check – Qwest Central Office Technician (COT) tests for Dial Tone at the CLEC CFA on the ICDF 48 hours prior to the scheduled cut. If Dial Tone is not present, the COT notifies the Qwest QCCC Coordinator, who in turn notifies the CLEC. This gives the CLEC 48 hours to correct the no dial tone condition.

1 Hour Dial Tone Check – Qwest COT tests for Dial Tone at the CLEC CFA on the ICDF 1 hour prior to the scheduled cut. If Dial Tone is not present, the COT notifies the Qwest QCCC Coordinator, who in turn notifies the CLEC. This second notification gives the CLEC an hour to correct the no dial tone condition.

Field Pre-Survey - Qwest Field Technicians Pre Survey outside plant facilities to identify any before due date. If Field Technicians determine that facilities are not available or acceptable for the service ordered, the Technician invokes an internal Qwest process to search for other facilities or place the order in a held status if suitable facilities are unavailable. The CLEC is then notified of the Held status.

Order Splitting – Qwest has offered to “split” orders on an LSR and “supp” the order with the circuit with the trouble condition at the time of the cut, allowing the CLEC the necessary time to correct the known condition.

After considerable deliberation and reconsideration, Qwest will continue to follow its practice to not turn over circuits that do not meet all defined standards at the time of the migration. CLEC’s retain the right to escalate and to petition through the Bona Fide Request (BFR) process.

Respectfully,

Frederick M Aesquivel III Director – Local Network Operations Support

CC: Scott Simanson Linda Hendricks Dana Filip

Open Product/Process CR PC092701-1 Detail

Description Of Change

These DID numbers were for the local police and fire station in this city. Due to the inaccurate CSR we left a two-way trunk with Qwest which disrupted the hunting (this line had a DPA on it that the customer wanted to keep). There were two sets of DIDs that were not addressed so when the TFD trunk they were riding on was ported the DIDs went down. The only way we were able to find the additional DIDs was by call Qwest for assistance.

Status History

Project Meetings

Name/Company: Terry Wicks, terry.wicks@algx.com, Allegiance Monica Manning, mxmanni@qwest.com, Qwest Susie Wells, sdwell2@qwest.com, Qwest Kate Spry, kspry@qwest.com, Qwest

Introduction of Attendees Terry, Monica, Susie, and Kate Review Requested (Description of) Change Develop a process for CLECs to get a “full” CSRs on DID numbers. Confirm Areas & Products Impacted Areas: Pre-Ordering / Ordering Products: Resale Confirm Right Personnel Involved Monica Manning is the ‘owner’ of this CR and will be the point of contact for future problems of this nature until the root cause is established and draft response issued. Susie would like to stay informed as to response and is available for questions pertaining to her area. Terry Wicks would like to stay informed as to response. Kate will coordinate all necessary clarification meetings, complete meeting minutes, and review, forward, and send information to Mike Keegan and Matt Rossi to store to database. Identify/Confirm CLEC’s Expectation Allegiance is requesting that a process be developed by Qwest to allow CLECs to be able to retrieve a full and complete CSR for all DID numbers for a specific End User at a specific location. Currently Allegiance is not confident that the information received through IMA is accurate. We have had several instances of End Users going down after conversion due to DIDs not being addressed. The reason for this is that not all DIDs are showing up on the CSRs. One example is for City of Tukwila BTN 206-433-1800. The CSR we pulled in IMA only shows the block 206-433-1844 to 1851 when in actuality the range goes to 1871. Qwest also advised us the DID 206-433-1856 did not exist. This meant that there was a break in the range of 206-433-1844 to 1855 then 206-433-1857 to 1871. DID range 206-433-7140 to 7199 is totally unaccounted for on the CSR.

These DID numbers were for the local police and fire station in this city. Due to the inaccurate CSR we left a two-way trunk with Qwest which disrupted the hunting (this line had a DPA on it that the customer wanted to keep). There were two sets of DIDs that were not addressed so when the TFD trunk they were riding on was ported the DIDs went down. The only way we were able to find the additional DIDs was by call Qwest for assistance. To clarify, two points are being addressed: ? When you pull a CSR and submit a request, the phone numbers aren’t on the CSR in the LSR. Is it then rejected? If so, why don’t they show up in the CSR if they are rejected? Terry gave the following examples: Here are the PONs where we ported these DID ranges: PON 699510-NP 206-431-3650 thru 3689 699510-NP1 206-431-3890 thru 3899 699510-NP2 206-433-1804 thru 1843

We have not completed the porting of these PONs: PON 860171-NP1 206-433-1844 thru 1855 PON 860171-NP2 206-433-1857 thru 1871 PON 860171-NP3 206-433-7140 thru 7199

The following TNs were on our CSR but we were told by Qwest there were additional TNs not showing up: 206-433-1844 thru 1851

The following TNs were not on our CSR we pulled from IMA for BTN 206-433-1800 206-433-1852 thru 1855 206-433-1857 thru 1871 206-433-7140 thru 7199

? Additional DIB ranges need to be addressed.

Identify any Dependent Systems Change Requests No related system CR’s were identified Establish Action Plan (Resolution Time Frame) Monica will clarify process via a written formal response draft. After clarification is received regarding possible system changes. She will forward this documentation to Kate by 10/18/01. Kate will review and forward the response draft to Mike Keegan and Matt Rossi to store in the CR database by 10/19/01 for CLEC review. The web location will be noted in Matt Rossi’s email regarding the response document by 10/22/01. This information can then be reviewed and discussed by the CLEC Community at the following CMP Meeting. Terry can view this information on the CR database and this CR can then be reviewed and discussed by the CLEC Community at the following CMP Meeting. Corrections/updates can then be made at that time.

CenturyLink Response

November 8, 2001

Terry Wicks LEC Manager Allegiance Telecom, Inc

This letter is being sent in response to CLEC Change Request Form # PC092701-1. PC092701-1 pertains to a request for a process to get a full CSR on DID numbers.

We have reviewed the list of LSRs and associated CSR you provided to QWEST for this Change Request. While it may have appeared that a Full CSR was provided to you by IMA, the Review Full CSR Response displayed a message indicating that only 52 of 61 pages were returned. This would explain why only a portion of the DID numbers for the account appeared.

The IMA User Guide provides instructions on how to retrieve additional CSR data, when the complete CSR is not displayed. This information can be found in Chapter 1 of the User Guide, under Reviewing Customer Service Records. As long as a Full CSR request does not exceed the page number limitation (300 pages in the IMA GUI, 450 pages in IMA EDI) and the CLEC is authorized, all of the CSR pages should be returned. If the instructions in the User Guide are followed, all of the CSR pages can be retrieved.

If you should encounter this trouble again while trying to retrieve a full CSR and have followed the steps outlined in the User Guide, please contact the Wholesale Systems Help Desk at (888) 796-9102 immediately. If we receive a trouble report regarding CSR retrieval "as it is occurring", we will be able to determine the root cause and correct the problem.

Sincerely,

Monica Manning IMA Process Specialist

Open Product/Process CR PC092701-2 Detail

Description Of Change

Status History

Project Meetings

CenturyLink Response

Terry Wicks LEC Manager Allegiance Telecom, Inc.

This letter is being issued to revise Qwest’s response dated November 8, 2001 to Change Request PC092701-2 requesting confirmation of all WTNs for a particular End User at a specific address for a Centrex Resale Customer. Qwest is prepared to implement the attached process to accommodate the CLECs request of confirming an End User WTNs.

Sincerely,

Susie Wells Sr. Process Analyst

(See Supplemental Information following detail report for Process)

December 4, 2001

Terry Wicks LEC Manager Allegiance Telecom, Inc. And, Kathy Stichter ILEC Relations Manager Eschelon Telecom, Inc.

This letter is in response to questions/concerns generated at the November CMP Meeting regarding Qwest’s response dated November 8, 2001 to Change Request PC092701-2.

Question: Is there a manual process available to Qwest retail that was not available to CLECs?

Answer: No. Qwest retail only retrieves CSRs for the WTNS provided by their customer .

Question: Does Qwest Retail have to get all WTN Numbers from new customers?

Answer: Yes. Qwest retail has to obtain all WTNs from their customer.

Sincerely,

Carolyn Brown Director Process Management

Cc: Monica Manning

--

DRAFT RESPONSE For Review By CLEC Community and Discussion at November CMP Meeting

Wholesale Product Marketing

November 8, 2001

Terry Wicks LEC Manager Allegiance Telecom, Inc

This letter is being sent in response to CLEC Change Request Form # PCR092701-2. PCR092701-2 pertains to a request for a process to get Full CSRs on Resale Centrex lines.

An IMA System Change would be required, in order to allow CLECs to request a Full CSR for all telephone numbers for a specific end user at a specific location. For the Resale Centrex account, DPA or DEPT and LOCN selection criteria might be added to the Review/Retrieve CSR functionality in IMA. However, a Systems Change Request would need to be created for these enhancements.

Until the IMA system changes can be deployed, you had requested that QWEST develop an interim process for obtaining end user specific Resale Centrex CSRs. Because a mechanized process does not exist, our service center personnel would have to gather this information manually. Unfortunately, QWEST does not have the resources to devote to these kinds of special requests. As long as a CLEC has the appropriate authorization, full CSRs can be retrieved through IMA. In lieu of the full CSR, partial CSRs by WTN can be retrieved. When a CLEC is unable to identify all WTNs associated with a request, the end user customer will have to be the provider of the information.

Sincerely,

Monica Manning IMA Process Specialist

Open Product/Process CR PC092701-3 Detail

Description Of Change

The most recent example happened today. PON 806241-HDSL1 – The FOC date to put in the circuit for this client is 09/25/01. Qwest was at the customer premises on 09/24/01 at 5:10 p.m. to do some work. The Qwest tech who went out was extremely rude to the customer. The Tech stated he has come several times, always after closing (5p.m.) and was not happy that he did not have access to the MPOE. The tech did not identify himself until the owner mentioned another company. The owner asked the tech if he worked for End 2 End Communications and the tech got upset and simply left. Several times the Qwest techs have told the customers that they would go down if they proceeded with converting to Allegiance.

Allegiance is requesting that an improved process be put in place that the CLECs can report these occurrences of anti-competitive behavior when they happen. This process should include a single point of contact , a thorough investigation with an appropriate response to the CLECs in a timely manner. The process should also include the proper training of Qwest personnel to prevent future occurrences

Status History

Project Meetings

Open Product/Process CR 5548229 Detail

Description Of Change

Status History

Project Meetings

Allegiance (Wicks) agreed this CR could be moved to “Completed” status. Allegiance did indicate they would like to see a higher level of compliance in this area. Currently they are still not receiving updated FOC’s 30% of the time.

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"'Russ Urveig'" cc: "'Kit Thomte'"

Subject: Allegiance - Same Day CFA Changes - No Updated FOCs Week of 7/15 - 7/19

Here is the last spreadsheet that I will send to you for updates. Beginning 7/22 we are using the new process to release busy CFAs should the situation arise.

There was only one PON that we did not get an updated FOC on last week. Please confirm the CFA change was corrected on you records for PON 1388133-LP and return the updated spreadsheet to me. Thanks.

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Terry Wicks LEC Account Manager allegiancetelecom, inc 469-259-4438 terry.wicks@algx.com

07/17/02 - July CMP Meeting Minutes: Qwest (Buck) provided the following status. Qwest had provided information back to Allegiance on the spreadsheet they have been tracking from. Allegiance agreed that they would begin using the escalation process on July 22. Qwest indicated that in the interim the escalation information has been provided to the CLECs to allow everyone to use the process. Worldcom inquired how someone that did not attend CMP could get the information. Qwest responded that the information was updated in the Qwest Raw Loop Data Qualification Tool Job Aid. This CR will remain in "CLEC Test" until the next CMP meeting to determine if the process is working properly and can be closed.

"Cheri Hurless" , "Wicks, Terry" cc: kthomte@qwest.com

Subject: Spreadsheets

Here is the completed spreadsheet for the CFA changes and no FOC sent, if you have any question please get with Cheri. There was only one request for CFA change where as the records were incorrect, I had a service order issue to correct the problem and it was due dated today. Just to clarify the spread sheet, in the column for NO FOC if the correct CFA was applied in TIRKS and the service order, I place an OK next you your N indicator. In the Comment section I just stated CFA verified. (See attached file: Same Day CFA Spreadsheet No FOC Master.xls)

I believe we have made great improvements on the FOC during the last several week and in all but 1 case the CFA had been correctly changed. I feel that this spread sheet should be discontinued and any concerns for CFA changes should move to the BUSY CFA activity, but only after the CFA query function had been performed on both the old CFA to make sure it is vacant and against the new CFA tom make sure it is busy. Any time we take activities out of the normal process flow and I an referring to requesting a CFA change without documentation there are extra steps we both must take to work together. Thanks for all your feed back on this matter Terry, and I look forward to closing this CR. Russ,

Here are my latest examples of not receiving updated FOCs on same day CFA changes.

5/20/02 thru 5/24/02

1268042-LP Received Updated FOC 1253525-LP Did Not receive updated FOC 1275739-LP Did Not receive updated FOC 1273724-LP Received Updated FOC 1272870-LP Received Updated FOC 1265872-LP Received Updated FOC 1277072-LP Received Updated FOC 1270017-LP Received Updated FOC 1276114-LP Received Updated FOC 1153382-LP Received Updated FOC

5/28/02 thru 5/31/02

1296008-LP 303-706-9024 Did Not receive updated FOC

1284062-L 480-237-0350 Did Not receive updated FOC 1308512-L1 480-966-8198 Did Not receive updated FOC 1295225-LP 303-781-8307 Received Updated FOC Received Updated FOC

1287395-L 303-771-0816 Received Updated FOC 1301207-LP Did Not receive updated FOC

1301991-LP Did Not receive updated FOC 303-762-9176 1278540-LP Received Updated FOC

1303185-L Received Updated FOC 1307043-L Did Not receive updated FOC 1303880-LP Received Updated FOC

1309037-LP Received Updated FOC 1309503-LP Did Not receive updated FOC 1292144-L Did Not receive updated FOC 1301212-LP Received Updated FOC

1285714-LP Received Updated FOC

Terry Wicks LEC Account Manager allegiancetelecom, inc 469-259-4438

Subject: CFA'S FOR 5/13/02 THRU 5/17/02

FOC 1242682-LP TN 720-932-8789 NEW 1263 OLD 1299

FOC 1257259-LP TN 303-755-3199 NEW 829 OLD 814

FOC 1284374-LP TN 206-323-1751 NEW 1279 OLD 1259 AND 1341 SHOWS WORKING IMA

NO FOC 1211795-LP2 TN 752-888-7554 NEW 247 OLD 276

FOC 1261532-LP TN 623-931-8086 NEW 808 OLD 768

FOC 1265023-L TN 303-991-0119 NEW 696 OLD 1183

FOC 1280325-MVL TN 763-576-6636-1 NEW 152 OLD 161

Thank you and have a good day,

Tasha Nichols/Supervisor Qwest/Verizon West 469-259-4823 fax 469-259-9051 tasha.nichols@algx.com

CenturyLink Response

Terry Wicks LEC Account Manager Allegiance Telecom

SUBJECT: Qwest’s Change Request Response - CR 5548229 Same Day Pair Change

This letter is in response to your recent request regarding the Escalation process associated with busy CFA. A subsequent request was made to include information to the CLECs regarding how they should initiate an escalation for busy CFA.

Below is the information that is necessary to initiate an Escalation for busy CFA.

Busy Connecting Facility Assignment (CFA) is defined as; When validating the CFA the slot shows that it is currently in use by a circuit in the Trunk Integrated Record Keeping System (TIRKS). The busy CFA can be the result of several different reasons: normal activity, pending service order activity, pending Inventory Availability Date (IAD) issues, and canceled service orders that have not cleared in TIRKS. Should you receive an indicator that the CFA is currently in use, however you records indicate the CFA is NOT in use, an Escalation ticket may be opened.

Information that is required for an Escalation ticket will be for BUSY CFA problems.

1. TERM Z TYPE LONG CLLI (ex.ALBONMNEHG1)

2. TERM A TYPE SHORT TYPE CLLI (e.g., ALBQNMNE)

3. CABLE TYPE (e.g., alt01)

4. UNIT NUMBER (e.g., 086)

5. Was there a disconnect request submitted to free CFA location. (EX. Yes, a disconnect request was submitted and an FOC was received. The PON number for the disconnect was AAA121211-MA)

6. Was the Slot changed during installation? If so what was the old slot and what should the current slot be? (EX. Yes, we changed the CFA during test and turn-up the previous CFA was ALT01 slot 89 TCANAZMAHG1 and slot changed to slot 91. The PON number associated to this change was AAA121211-MA)

7. Was there any migration activity on this CFA? (EX. Yes, we should that a migration to another Provider on 06/17/2002)

8. Want type of request were you attempting when you encounter the busy CFA problem? (EX. We were attempting to request a new loop and utilize this CFA, or we were attempting a change activity against circuit 99.LXFU.000111.nw.)

9. Were there any change activity against the circuit, if so PON number for activities. (EX. Our records show a change activity should have taken place on 06/17/2002 from PON AAA121211-MA to free this CFA. Or our records indicate a disconnect request on 06/17/2002 on PON AAA121211-MA which should have freed the CFA.)

If you have any questions regarding this information please feel free to contact me.

Sincerely,

Russ Urevig Senior Process Analyst

01/07/02 Response to Allegiance e-mail dated 12/28/01 January 7, 2002

Terry Wicks LEC Account Manager Allegiance Telecom

CC: Catherine Garcia

This letter is in response to your e-mail dated Friday, December 28th, 2001 – Allegiance – Same Day CFA Change – No Updated FOC Received.

Response: Since we have received examples of FOC’s not being sent to the CLEC’s when a CFA has been changed, new focus on this process has been brought forward. The QCCC have put the following procedures in place to insure that the CFA process is followed.

- All testers have been re-trained on the CFA Change Process.

- Four compliance reviews, for each tester, are completed every month focusing on compliance to the CFA Change Process.

- Performance managing is being done to insure the CFA Change Process is being complied with. If a tester fails their compliance review, there is documented discussion around the issue.

- Weekly Leadership meeting are held to discuss issues for the center. The CFA Change Process has been brought forward during these meetings to insure that the process is understood and followed.

Sincerely,

Deni Toye Network Unbundled Loop Process

October 10, 2001 Terry Wicks, Allegiance

This letter is in response to your CLEC Change Request Form CR5548229 dated August 30, 2001, Request:

Allegiance has sent Qwest examples of orders when Allegiance had problems on same day CFA changes. Allegiance was not receiving FOC’s back specifying that a CFA had been changed. Allegiance would like to know that there is a process for a CFA change on test and turn up for the same day.

Qwest Response: There was a process put into place to allow the CLEC to have a CFA change before or on the due date. On August 9, 2001 a process was put in place to allow this activity to happen. Terry Wicks sent some examples to show that the process is not working. After investigation of these orders, it was determined that a process is in place and does work, however, there are isolated cases of non-compliance issues. The orders that Terry sent to us did have the CFA changed the day of the due date, however, non-compliance to the process did not produce a call to the SDC, therefore, a FOC was not sent to the CLEC. These examples have been forwarded to the centers for process compliance verification.

Sincerely,

Deni Toye Network Unbundled Loop Process

Open Product/Process CR PC091201-1 Detail

Description Of Change

Also what is the process to negate the charges for these cuts and how is this tracked to insure the CLEC is not billed?

Status History

Project Meetings

Introduction of Attendees Terry Wicks, terry.wicks@algx.com, Allegiance Gary Stacy, gstacy@qwest.com, Qwest W. Rob Tomlinson, wtomlin@qwest.com, Qwest Linda Hendricks, lkhendr@qwest.com, Qwest Russ Urevig, rurevig@qwest.com, Qwest Joan Wells, jmwell2@qwest.com, Qwest Deni Toye, dtoye@qwest.com, Qwest Kate Spry, kspry@qwest.com, Qwest Ric Martin, rhmart2@qwest.com, Qwest

Terry, Gary, Rob, Linda, Russ, Joan, Deni, Kate, and Ric Review Requested (Description of) Change Clarify and document process for when orders are held on cut date, when Qwest has no facilities. Confirm Areas & Products Impacted Areas: Ordering and Day of Cut Products: UNE Confirm Right Personnel Involved Linda is the ‘owner’ of this CR and will be the point of contact for future problems of this nature until the root cause is established and draft response issued. Russ will forward necessary SCAT documentation to Kate. After the clarification meeting, it was determined that Gary, Rob, Joan, and Deni will not need to be involved in this CR. Kate will coordinate all necessary clarification meetings, complete meeting minutes, and review, forward, and store necessary documentation to database. Identify/Confirm CLEC’s Expectation Per Allegiance, “Allegiance wants clarification about the process when the problem is on Qwest’s side – Qwest should not have to SUP orders for no facilities on cut date. Allegiance provided an example of this happening (PON 824041-LP); Qwest should investigate this example and provide a documented process and reason why this happens on cut date. Also, what is the process to negate the charges for these cuts and how is this tracked to insure the CLEC is not billed?” Per Linda, there are no non-reoccurring charges. Identify any Dependent Systems Change Requests No related system CR’s were identified Establish Action Plan (Resolution Time Frame) Linda will clarify this process via a written formal response draft. She will forward this documentation to Kate by 9/27/01. Russ will forward the necessary SCAT documentation to Kate by 9/26/01. Kate will review and forward this information to Michael Belt and Matt Rossi to store in the CR database by 9/28/01 for CLEC review. The web location will be noted in Matt Rossi’s email regarding the response document on 9/28/01. This information can then be reviewed and discussed by the CLEC Community at the October CMP Meeting. Terry can view this information on the CR database and this CR can then be reviewed and discussed by the CLEC Community at the October CMP Meeting. Corrections/updates can then be made at that time.

CenturyLink Response

Terry Wicks LEC Manager, Allegiance Telcom Inc.

CC: Scott Simanson Fred Aesquivel

Re: DRAFT RESPONSE for PCCR 091201-1 For Review By CLEC Community and Discussion at October CMP Meeting" Topic: Provide the standard, documented process for when orders are held on cut date, when Qwest has no facilities Dated: 09/12/01

Dear Terry:

This letter is in response to the following CLEC Change Request Form PCCR 091201-1, dated 09-12-2001. The Change Request pertains to the Clarification and documented process for when orders are held on cut date, when Qwest has no facilities.

Qwest has a Pre Survey procedure in place to identify facility issues before due date. When it is discovered that facilities are not available or good an internal Qwest process looks for other facilities or place the order in a held status if no facilities can be located. The CLEC is then notified of the held status. The Cheyenne Held Order group notifies the CLEC after the order is placed in held. If the facility problem is found on test and turn up the CLEC is notified verbally at that time.

The orders that Allegiance inquired about on PON 824041-LP were held for facility problems on the due date, 8-29-01. The problem was discovered while trying to turn up the orders. The orders were all on Integrated Pair Gain and the process for handling Integrated Pair Gain orders was followed. A problem was discovered between the D4 channel and the SLC equipment in the Central Office. Qwest did not know of this problem until they tried to turn up the loops. The orders are being worked on to discover how to fix the problem and get the service provisioned. According to the WFA/C OSSLOG the CLEC has been advised of the progress.

Waiving the Non Recurring Charge does not apply to these orders because Qwest did meet the appointment time. The negating of Non Recurring Charge applies when Qwest does not meet the appointment time as specified on the CLEC’s LSR. MC The Missed Commitment should be applied only on Coordinated Orders (new and reuse) when Qwest misses the CLEC requested appointment time by 30 minutes or more. This MC=Y or MC causes a billing error to make the billing “fall-out” so the installation charges are dropped. This is placed on the OSSOI Cmnt/Rmk line in WFA/C. Systems captures and passes on to the billing CRIS system. When the billing error falls out, the SDC (service delivery coordinator) negates the nonrecurring charge on the customer's bill. This is how they receive their negated charges. The CLEC approved the start of the cut at 1007 on 8-29-01 by Scott at Allegiance.

Sincerely

Linda K. Hendricks Lead Project Analyst

Open Product/Process CR 5579296 Detail

Description Of Change

Status History

Project Meetings

Open Product/Process CR PC090401-1 Detail

Description Of Change

Request for Qwest to separate daily usage files by separating category 01 and 010 from category 011. Categories 01 and 010 separate daily usage records for end users while category 011 tracks billing for other carriers. AT&T separates billing entities by these functions. AT&T believes that other carriers utilize this same process. AT&T believes would be more efficient if the daily usage files were separate in this manner.

Status History

Project Meetings

Alan indicated that he was familiar with this subject. He believed it had been submitted once before but did not have the support of the other CLECs at that time. Alan indicated that he thought some of the CLECs might see the need for this now.

Alan stated the issue: In the current environment two usage files containing the same data are sent to two locations. ATT would like to have the file containing message types 01 and 10 split out on one file. The other file should contain message type 11, to be distributed separately.

Carla indicated she would take this CR to the next community meeting to propose this change to other CLECs.

CenturyLink Response

November 6, 2001

This letter is in response to the CLEC Change Request Form #PC090401-1. This Change Request requests that the Daily Usage Feed (DUF) be split into two pieces - with local usage (generally Category 1 & 10 EMI records) on one file, and access usage (Category 11 records) on a separate file.

Today, both local usage and access usage is sent on a single DUF file for each CLEC. It is fairly straight-forward to separate this usage into two files. To do so requires some small programming changes, as well as some JCL and NDM/Connect: Direct changes for every CLEC that chooses to have their DUF split into two pieces. This would be a medium-sized effort. This CR will be moved to the Systems CMP process in order to prioritize this system work.

Qwest would implement this CR in such a way that those CLECs that wish to continue to receive their DUF file as one file (like today) would be able to continue with that implementation. Those that wish to receive two separate files would be able to do so, having those two files sent to two different destinations (assuming connections exist) or to the same destination as the CLEC desires.

Any CLEC who would like to have their DUF split in two as this CR requests may send an e-mail to me at azimmer@qwest.com to be included in the deployment of this functionality. If you have any questions, feel free to e-mail me or call me at the number below.

Sincerely,

Alan Zimmerman (303)896-8346

Open Product/Process CR PC090401-2 Detail

Description Of Change

The process would include a minimum of the following steps:

- CLEC will provide prior notification of intent to convert via a list (spreadsheet?) identifying the LSO and number of TNs

- CLEC will provide ONE LSR PER CUSTOMER LOCATION for conversion.

- Qwest will provide a SPOC for each LSO conversion on the same due date.

- Qwest will perform a Loop Qualification for each LSR.

- Qwest will provide Loop Qualification results to CLEC.

- CLEC will have option to make supplemental changes or cancel LSRs per results of loop qualification.

- CLEC will schedule conversion to begin on Due Date no earlier than 4:00 PM. All conversions within the LSO will be completed by 12:00 Midnight.

Time Intervals for conversions shall be monitored and shall conform to the existing performance standards set in the current Qwest hot cut agreement.

Status History

Project Meetings

Qwest held a community meeting with AT&T regarding two questions that came up during the October CMP meeting. Other CLECs were invited and several participated.

Jonathan Spangler from AT&T had inquired if the orders would go through the QCCC. Russ Urevig stepped through the process. In the process he identified that in fact the QCCC will be the point of contact for the coordinated after hours cut. Jonathan indicated he had received some push back when trying to schedule other projects.

The second question was regarding charges associated with the after hours cut. Russ explained that the normal after hours charges would apply.

Jonathan brought up an additional issue. He wanted to know what the impacts would be to these projects when the 9.0 IMA Release goes in and the CLECs are required to use Appointment Scheduler. Russ indicated he was not sure that these types of cuts were included in the 9.0 release for Appointment Scheduler. Qwest to follow up with system SME’s regarding the System Change Request.

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09/17/01 - Introduction of Attendees Jonathan Spangler Carla Dickinson Pardee Russ Urevig Kit Thomte

Kit made introductions of people that were in attendance on the conference call Review Requested (Description of) Change {review long description from change request, confirm with all parties there is agreement on the change requested} AT&T would like Qwest to develop a process that would allow for the conversion of customers residing on UNE P to UNE L. CLECs will identify specific TN’s within the CO that need to be converted. This would occur initially via a spreadsheet with LSR’s to follow. The spreadsheet would be used by Qwest to determine if the line actually could be converted. Prior to this the CLECs will use the raw loop pre qualification tool to verify TN’s of end users being converted. The CLECs want to minimize the amount of down time for the customers so the cuts should be performed between 4 PM and 12:00 Midnight. The volumes anticipated are not very precise yet. AT&T will provide more information as it becomes available. Russ inquired how AT&T would like to handle a scenario where the end user has multiple lines and only a portion of the lines are being migrated. Would they set up separate accounts?? Jonathan said he would need to check that out. Confirm Areas & Products Impacted {read from change request, modify if needed} At this point only 1FR’s will be submitted, at some point this process might include DSL.

Confirm Right Personnel Involved {ensure the Qwest SME can fully answer the CLEC request. Confirm whether anyone else within Qwest has been involved with this issue, or whether we need to bring anyone else in} At this point Russ believes a person from network should be involved, this probably would be Deni Toye. A process person for UNE P should either be involved or review the process that is established. Eventually a SME from Retail should be aware of the process.

Identify/Confirm CLEC’s Expectation {Identify specific deliverables from CLEC – what does Qwest have to do in order to close this CR? (in measurable terms i.e. provide a documented process, change a process to include training etc)} Qwest needs to provide a process that will address this type of migration. This process needs to be put in place quickly with the worst case scenario being implementation in December of 2001.

Identify any Dependent Systems Change Requests {Note any connected CRs and the potential impacts} An existing CR would resolve the necessity of this CR. Russ Urevig agreed to identify this CR and let us know the status.

Establish Action Plan (Resolution Time Frame) {state action required, who will be responsible and by when) Russ will run this CR past his supervisor and the migration team that works on these issues. Russ should have a response by close of business on Monday Sept. 24th The detailed action plan will be provided after the session on the Sept. 24th.

09/12/01 - Susie Bliss is the Director 402-422-8006 Kit Thomte is the Project Mgr. 303 896-6776 Russ Urevig is the Owner 218 723-5800 Donna Osborne Miller gave me has provided the name of an individual to participate in a clarification meeting. Have not heard from the individual yet.

CenturyLink Response

Jonathan Spangler, LSAM Supervisor Donna Osborne-Miller, LSAM Manager AT&T Local Services

CC:Russ Urevig Susie Bliss Linda Miles Kit Thomte

This letter is in response to your CLEC Change Request Form PCCR090401-2 dated August 30, 2001.

Request:

AT&T would like to establish an efficient process with Qwest to convert AT&T customers residing on the Qwest UNE-P platform to the Qwest UNE-L platform on a Bulk LSO basis. The process would include a minimum of the following steps: CLEC will provide prior notification of intent to convert via a list (spreadsheet?) identifying the LSO and number of TNs CLEC will provide ONE LSR PER CUSTOMER LOCATION for conversion. Qwest will provide a SPOC for each LSO conversion on the same due date. Qwest will perform a Loop Qualification for each LSR. Qwest will provide Loop Qualification results to CLEC. CLEC will have option to make supplemental changes or cancel LSR's per results of loop qualification. CLEC will schedule conversion to begin on Due Date no earlier than 4:00 PM. All conversions within the LSO will be completed by 12:00 Midnight. Time Intervals for conversions shall be monitored and shall conform to the existing performance standards set in the current Qwest hot cut agreement

Qwest Response:

Conversion from UNE P to UNE L on a Bulk LSO basis can be handled as a project. The CLEC can contact their Account Service Manager to advise of the intent to Bulk convert on an LSO basis. By the conversion being handled as a project, the specifics such as due dates and individual tester, SPOC can be coordinated.

The CLEC can request raw loop data for an entire wire center. The RLD tool provides data in bulk format to the Co-Providers about loop make-up characteristics at the wire center level. The data includes CLLI code, load coil, bridged tap, wire gauge, cable and pair make-up, and similar information on a loop-by-loop basis.

There is a web-site maintained by Qwest where Co-Providers may access the RLD tool. To gain access to the web-site, Co-Providers must obtain a digital certificate from Qwest. The RLD tool is presented in an ASCII text file and can be downloaded to an Excel format or database built by the Co-Provider. The web-site address is http://ecom.uswest.com.

CLEC’s are encouraged to use the Pre-order function in IMA for Loop Qualifications. The results of the Loop Qualification are given to the CLEC. If an LSR is submitted and the loop does not qualify then the LSR would be rejected. A CLEC has the option to make supplemental changes or to cancel an LSR. For any due date requests outside the normal business hours appropriate charges would be billed.

Sincerely,

Russell Urevig Wholesale Service Delivery Process Team

Open Product/Process CR PC102601-1 Detail

Description Of Change

Status History

Project Meetings

CenturyLink Response

December 28, 2001

Carla Dickinson Pardee LSAM Manager AT&T

This letter is in response to the CLEC Change Request Form #PC102601-1 regarding RSID/ZCID Assignment for UNE-P. Qwest would like to close this Product/Process CR and open a new Systems CR to properly consider the best way of meeting this business need.

Today, the assignment of an RSID/ZCID value drives a lot of business processes in Qwest. USOC rates are maintained for each RSID/ZCID, Loss/Completion reports are generated for each RSID/ZCID, separate bills are generated, security and authorizations are specific per RSID/ZCID, etc. To assign multiple RSID/ZCID values per CLEC would create potential issues with contract updates, authorizations, etc. Qwest would prefer to create another mechanism for CLECs to tell Qwest how to segment customers for purposes of Loss/Completion reports, Daily Usage Feeds and any other system interfaces CLECs desire to have segmented.

This new separation mechanism would need to be accomodated on the LSR and IMA, as well as the other systems involved. A Systems CR would be required to accomplish this. Qwest will open the Systems CR on AT&T’s behalf.

If you have any questions, feel free to e-mail me or call me. Happy New Year!

Sincerely,

Alan Zimmerman (303)896-8346 azimmer@qwest.com

Open Product/Process CR PC110201-2 Detail

Description Of Change

Modification - 11/27-01:

The CR will focus on accepting partial LSRs that are related to multiple LSRs and will also evaluate any differences on managed cuts versus coordinated cuts.

Status History

Project Meetings

CenturyLink Response

December 27, 2001

Jonathon Spangler ILEC Relations Manager AT&T

This letter is being sent in response to CLEC Change Request Form # PC110201-2. PC110201-2 pertains to a request to change the due date on one or more LSRs that were previously submitted in a group of related PONs. This response addresses the current IMA process for changing the due date on one or more LSRs within a group of related PONs allowing the remaining PONs to be processed.

IMA Process:

A supplemental LSR should be issued for the PON requiring the due date change. The value entered in LSOG field 25 SUP should be “3” because there will be other changes on the LSR in addition to the due date change.

The value entered in LSOG field 51 RPON should be blank to indicate that this PON is no longer part of a related group.

The value of LSOG field 14 DDD should contain the new desired due date.

The value of LSOG field 10 PGofPageof should follow the LSOG business rules for the product specified on the LSR.

The LSOG business rules are documented on the Qwest website http://www.qwest.com/wholesale/clecs/lsog.html.

Sincerely, Deborah Osborne Process Specialist

Open Product/Process CR PC110201-1 Detail

Description Of Change

Status History

Project Meetings

Subject: RE: Clarification on Rate Maps/document to determine zones for lo op rates Date: Fri, 18 Jan 2002 17:13:09 -0600 From: "Clauson, Karen L." To: Todd Mead CC: Kathleen Stichter , "Morrisette, Garth M." , Susan Travis Todd: Garth has indicated that we also need the rate center maps as well. Please send copies to Kathy Stichter. Thanks.

01/18/02 Clarification e-mail from Eschelon

Subject: RE: Clarification on Rate Maps/document to determine zones for lo op rates Date: Fri, 18 Jan 2002 17:12:04 -0600 From: "Clauson, Karen L." To: Todd Mead CC: Kathleen Stichter , "Morrisette, Garth M." , Susan Travis I will be in Denver for the CMP Re-design meeting on Tuesday-Thursday. We can discuss on a break, if you would like. Otherwise, you can arrange a call with Kathy Stichter and Garth Morrisette while I am out, if Kathy can find a suitable time for you. Essentially, we are simply asking for the documentation that allows us to determine where our lines (and future lines) fall within the zones that have been established for geographically deaveraged loop rates. For example, a newspaper article in Denver said that Zone 1 (the most dense zone) covered most of the city of Denver. What are the boundaries of that Zone? Do you have a list of wire centers/CLLI code by zone (where the zone is defined by wire centers) or a map that shows these zones? We need this information for AZ and CO. I am copying Susan Travis of WCOM, because she had this same request, and she may have other states.

01/18/02 E-mail with AT&T mailing address

Subject: RE: Your Address Date: Fri, 18 Jan 2002 12:50:10 -0500 From: "Van Meter, Sharon K, NCAM" To: "Todd Mead" CC: "Saunders, Craig" Todd, Thanks for the reminder. 1875 Lawrence St. Room 8-15 Denver, CO 80205 Thanks for your help. Sharon Van Meter Western Region LSAM 303-298-6041 303-540-1637 (pager)

--Original Message-- From: Todd Mead [mailto:tmead@qwest.com] Sent: Friday, January 18, 2002 10:42 AM To: Van Meter, Sharon K, NCAM Cc: Saunders, Craig Subject: Your Address Sharon, Please send me you mailing address and we will send you a copy of the map you requested. Thanks Todd

01/09/02 E-mail from Qwest responding to Eschelon e-mail on Qwest response content

Subject: Re: Qwest Rate Center Maps Date: Wed, 09 Jan 2002 16:09:55 -0700 From: Todd Mead Organization: Qwest Communications International, Inc. To: "Clauson, Karen L." CC: "Van Meter, Sharon K, NCAM" , jmschu4@qwest.com, susan.a.travis@wcom.com, "Saunders, Craig" , "Stichter, Kathleen L." Karen, Yes! The Qwest response presented at next week's CMP meeting will encompass the information you refer to below. Thanks Todd

01/09/02 E-mail from Qwest asking for AT&T address to forward map example.

Subject: Re: Qwest Rate Center Maps Date: Wed, 09 Jan 2002 16:07:41 -0700 From: Todd Mead Organization: Qwest Communications International, Inc. To: "Van Meter, Sharon K, NCAM" CC: jmschu4@qwest.com, susan.a.travis@wcom.com, klclauson@eschelon.com, "Saunders, Craig" Sharon, The map the Qwest individual referred to in the CMP meeting is the same as the example Worldcom sent us. Sharon, if you can send me your address I will make sure a copy is sent to you for your review. Thanks Todd

01/04/02 E-mail from Eschelon requesting additional information on Qwest response content

Subject: RE: Qwest Rate Center Maps Date: Fri, 4 Jan 2002 11:26:00 -0600 From: "Clauson, Karen L." To: Todd Mead , "Van Meter, Sharon K, NCAM" CC: jmschu4@qwest.com, susan.a.travis@wcom.com, klclauson@eschelon.com, "Saunders, Craig" , "Stichter, Kathleen L." Todd: Thanks for the helpful response. Since Sharon asked specifically about the rate center maps, I wasn't sure that your response below deals with the Distribution Area (DA) maps requested by Eschelon. Will we be getting the DA maps at the January meeting? Also, at the meeting in December, we discussed whether the CLECs were actually requesting the correct items to meet their objectives (e.g., being able to identify customers in zones for geographically deaveraged rates). I believe this caem up because Qwest said that it didn't know if it had maps of the type requested. If not, then Qwest must look at something else to make these determinations. We asked that, if we had not requested the documentation used by Qwest for this purpose, that such documentation also be produced. Have you determined yet whether Qwest has different documents/maps and, if so, will that be provided at the January meeting? Thanks, Karen

01/04/02 E-mail response to AT&T

From: Todd Mead [SMTP:tmead@qwest.com] Sent: Friday, January 04, 2002 11:14 AM To: Van Meter, Sharon K, NCAM Cc: jmschu4@qwest.com; susan.a.travis@wcom.com; klclauson@eschelon.com; Saunders, Craig Subject: Re: Qwest Rate Center Maps Sharon, Thanks for your e-mail. At the December CMP meeting, we had a general clarification on this CR where you presented the business reasons for submitting this CR and then the Qwest SME's asked you several questions pertaining to the exact nature of information you were after with these rate center maps. The following are notes I documented from the December CMP clarification meeting: - What states you wanted maps for (Washington, Utah, Colorado, Oregon, Minnesota, Arizona & New Mexico) - What level of detail (you want to be able to see what rate center a specific address is located in) - What format you are after (CLECs prefer electronic, however hard copy would do) - Whether you wanted to only see major metro areas i.e.. Denver, Aurora, Smokey Hills etc. CLECs agreed to this - Eschelon wanted to know if these maps would show how each customer is being served i.e. RSU (Qwest responded they would not and Eschelon responded that they may submit a separate CR). - Worldcom wanted to know if the maps show the CILLI detail (they had some examples from previous USWest maps). We have since contacted LeiLani and she has forwarded a copy of these old maps to the Qwest SME to review to help their response preparation. - You also want the response to include the process for getting these maps updated At the January CMP meeting (01/16/02) Qwest will present their response to your CR. The Qwest team is currently working on this response and I will e-mail it to you (plus Eschelon and Worldcom) as soon as I receive it from the Qwest SME. The response will also be posted to the CMP database and published on the web no later than next Friday (01/11/02). If I have missed something here, I would be more than happy to discuss this with you. You can call me anytime today to discuss this. Regards Todd

01/04/02 E-mail from AT&T requesting map examples

Subject: Qwest Rate Center Maps Date: Fri, 4 Jan 2002 10:49:43 -0500 From: "Van Meter, Sharon K, NCAM" To: CC: , , Todd, I haven't heard anything about the deliver of the Rate Center Maps. It was my understanding that you would contact me and deliver some maps for my review. Please advise. Sharon Van Meter Western Region LSAM 303-298-6041 303-540-1637 (pager)

12/18/01 e-mail from Worldcom to Qwest

Todd, Sure, I will put one in the mail today. LeiLani Hines Worldcom Carrier Management

12/18/01 e-mail from Qwest to Worldcom

Leilani, The Qwest SME would like to see the copy of the map you have. Could you please send him one? Thanks, Todd

> From: Stichter, Kathleen L. > Sent: Friday, November 16, 2001 3:18 PM > To: 'mbelt@qwest.com' > Subject: PC110201-1 > > Mike, > Qwest has a web site http://www.qwest.com/iconn/ that a CLEC can go to and > click on Outside Plant Jobs Greater than $100K to get information on the > build jobs Qwest is planning. Once at this web page the details Qwest > gives are: > State, WireCenter, Job #, Fiber/Cooper, Quantity, Location i.e. DA/CLLI, > Ready for Service and Completion Date. The information populated in the > Location field is either CLLI or DA (Distribution Area). The DA data is a > number i.e. 310211. This number, for the distribution, means nothing to > Eschelon without a map detailing the bounderies down to street level > detail of the specific distribution area. > Thanks > > Kathy Stichter > ILEC Relations Manager > Eschelon Telecom Inc

3:00 p.m. (MDT) / Thursday 16th Nov 2001 Clarification Meeting Conference Call

Attendees: Sharon Van Meter / AT&T Matt Kruzic / Qwest Jacob Barlow / Qwest Jan Attebarry / Qwest Craig Saunders / Qwest Mary Anderson / Qwest Michael Belt / Qwest Kathy Stichter / Eschelon (called later) Tom Dixon / Worldcom (called later)

Review Requested (Description of) Change: AT&T – Qwest Rate Center maps to be public information to the CLEC Community Eschelon & Worldcom would like the DA and CLLI Maps also included with this CR.

Products Impacted - LNP

Identify/Confirm CLEC’s Expectation - Yes the expectations of the CR are understood, need to clarify the issue of Proprietry Qwest information.

CenturyLink Response

Sharon Van Meter Manager AT&T 1875 Lawrence St. Denver, CO 80205

SUBJECT: Qwest’s Change Request Response - CR # PC110201-1 Qwest Rate Center Maps

REQUEST: Qwest determines the Rate Centers. AT&T needs to mirror the Rate Center areas for residential LNP. What is the process for obtaining Rate Center Maps from Qwest?

Additional clarifications/requests: Requested maps at a street level detail. Requested maps for MSA’s in Arizona, Colorado, Washington, Utah, Oregon, Minnesota, & New Mexico Prefer electronic, however paper will do. Requested maps at a level to determine DA areas. Requested maps at a CLLI level detail. Requested a process to update maps.

RESPONSE: Qwest has provided, on the Qwest Wholesale web site, the same rate center maps that Qwest uses and updates on a quarterly basis. The URL is:

www.qwest.com/wholesale/network/ratecentermaps.html

Qwest does not solely rely upon rate center maps to determine number portability. Qwest, as well as other companies, relies upon the Local Exchange Routing Guide (LERG) as the official guide to determine the portability of a number. Qwest determines whether a number is available for porting by looking at the customers switch information, both from and to, which reflects the serving rate center. As determined by the FCC, Qwest does not permit the porting of the numbers between two different rate centers.

Currently the Rate Center maps used by Qwest and provided on the wholesale website do not have the capability to provide wire center street level detail. Maps of DA’s are available through the Qwest Wholesale web site by following the process outlined under the URL:

www.qwest.com/wholesale/pcat/remotecollocation.html

Requesting multiple DA’s in a particular wire center will enable CLEC’s to ascertain the description of the wire center boundary.

In regard to the request for maps where Qwest plans fiber and copper jobs greater than $100,000, Qwest has plot maps that are available for review as outlined in SGAT section 10.8.2.4. Qwest agrees to provide CLEC access to relevant plats upon receiving a bona fide request for such information as stated in the SGAT.

Sincerely,

Craig Saunders Staff Advocate Policy & Law Qwest

CC: Barry Orrel, Director Legal Issues, Qwest Jim Eitel, Director Legal Issues, Qwest Lydia Eiguren, Senior Director Business Development, Qwest John Hayat, Staff Advocate Policy & Law, Qwest Mary Retka, Director Legal Issues, Qwest

Open Product/Process CR PC090401-4 Detail

Description Of Change

Status History

Project Meetings

RE: CR Form #PCCR090401-4

The intent of this change request was to clarify Qwest’s LNP process and to address any discrepancies in the information provided by their Denver Interconnect Center on August 15th, August 17th, August 24th and August 31st to AT&T. Qwest’s Denver Interconnect Center stated on multiple conference calls (to AT&T Broadband and to LNS) that calendar days, instead of business days, would be counted in the LNP process. Discussions with Qwest at the October 17th Product and Process CMP meeting clarified that Qwest uses business days.

AT&T understands this to mean that if a port is scheduled on a Friday or Saturday, Qwest will not jeopardize the end customer by closing the LSR or removing the switch translation any earlier than the next business day. Next business day is defined as the following Monday at 11:59 p.m. AT&T wants to clarify that holidays do not constitute a Qwest business day. Therefore, Friday, Saturday or Sunday ports would not be disconnected out of the switch until the following Tuesday at 11:59 p.m. if Monday is a designated holiday.

Qwest states that their Interconnect Centers have been advised and are aware of this process. The process states that the ten (10) digit unconditional trigger and switch translations associated with the end user customer’s telephone number will not be removed, nor will Qwest disconnect the customer’s billing and account information, until 11:59p.m. (local time) of the next business day after the due date.

AT&T interprets this to mean Qwest has provided documentation and training to the typists at Sierra Vista, Phoenix, and Duluth Centers, both Interconnect Service Centers, the RCMAC center and any additional Qwest centers directly related to the LNP process. AT&T Broadband will reference Qwest’s letter dated October 29, 2001 to restore loss of dial tone when it is a direct result of non-adherence to Qwest’s LNP process by any Qwest employee of these centers. AT&T further expects the duty supervisors to be well versed in this process and provide consistent action and information based on this process.

Sincerely, Terry Bahner AT&T Local Services – LSAM Western Region

CC: Sharon Van Meter Tim Boykin Donna Osborne-Miller Mitch Menezes

Friday, September 21st, 2001 Alignment/Clarification Meeting

Donna Osborne-Miller, dosborne@att.com,AT&T Terry Bahner, tbahner@att.com, AT&T Kathleen Stichter, klstichter@eschelon.com, Eschelon Telecom Linda Miles, llmiles@qwest.com, Qwest Russ Urevig, rurevig@qwest.com, Qwest Joan Wells, jmwell2@qwest.com, Qwest Kate Spry, kspry@qwest.com, Qwest Ric Martin, rhmart2@qwest.com, Qwest

Introduction of Attendees Donna, Terry, Kathy, Linda, Russ, Joan, Kate, and Ric Review Requested (Description of) Change Clarify process to complete LSRS the day after due date. Confirm Areas & Products Impacted Areas: Ordering and Billing Products: LNP Confirm Right Personnel Involved Joan is the ‘owner’ of this CR and will be the point of contact for future problems of this nature until the root cause is established and draft response issued. After the clarification meeting, it was determined that Linda and Russ will not need to be involved in this CR. Kate will coordinate all necessary clarification meetings, complete meeting minutes, and review, forward, and store necessary documentation to database. Identify/Confirm CLEC’s Expectation AT&T has asked Qwest to clarify the process for completing LSRS the day after due date. Per AT&T, “Qwest notified the CLEC community LSRS would complete orders day after at 11:59 p.m. of install date to coincide with disconnect in switch. Qwest escalation center is stating that orders can start closing as early as 3 p.m. with the possibility of closing even sooner with disconnect to follow. Interconnect has stated that Qwest determines that there is a large volume of orders to close, they can decide a random time to start the process. AT&T would like to understand why this time frame fluctuates if the closing of these orders causes the disconnect in the switch to shift to an earlier time. AT&T is requesting a flow chart or documentation explaining and listing the backend systems for this process.” Identify any Dependent Systems Change Requests No related system CR’s were identified Establish Action Plan (Resolution Time Frame) Joan will clarify this process via a flowchart and written formal response draft. She will forward this documentation to Kate by the morning of 10/5/01. Kate will review and forward this information to Michael Belt to store in the CR database by 10/8/01 for CLEC review. This information can then be reviewed and discussed by the CLEC Community at the October CMP Meeting. Donna and Terry can view this information on the CR database and this CR can then be reviewed and discussed by the CLEC Community at the October CMP Meeting. Corrections/updates can then be made at that time.

CenturyLink Response

November 6, 2001

Ms. Terry Bahner Ms. Donna Osborne-Miller AT&T Communications

This letter is in response to CLEC Change Request PCR090401-4, dated September 4th, 2001, title of change: Clarify Qwest’s process on completing LSR’s day after due date. This Change Request pertains to the implementation of the new LNP process involving stand alone LNP port out service order requests.

Description of Change as noted in CR: QWEST notified CLEC community LSRS would complete orders day after at 11:59 pm of install date to coincide with disconnects in switch.. Qwest escalation center is stating that orders can start closing as early as 3pm with the possibility of closing even sooner with disconnect to follow. Interconnect has stated that if Qwest determines that there is a large volume of orders to close, they can decide a random time to start the process. AT&T would like to understand why this time frame fluctuates if the closing of these orders causes the disconnect in the switch to shift to an earlier time. AT& T is requesting a flow chart or documentation explaining and listing the backend systems for this process.

Implementation of this Qwest business process change was included in the IMA 8.0 release and was deployed effective August 20th, 2001.

The change is as stated: The ten (10) digit unconditional trigger and switch translations associated with the end user customer’s telephone number will not be removed, nor will Qwest disconnect the customer’s billing and account information, until 11:59p.m. (local time) of the next business day after the due date. Internal Qwest systems have been adjusted to accommodate this process change.

* Order completion and disconnect of translation’s will not occur prior to 11:59 p.m. the next business day following the due date.

* The subscription date to ASMS is sent to match the CLEC requested due date as available per the standard interval guide.

* The FOC is sent and matches the ASMS subscription date requested by the CLEC as available per the standard interval guide.

* An effective billing date to discontinue account billing is added to the order to match the actual port subscription date as requested by the CLEC and as available per the standard interval guide.

* Additional notification and a reminder of this current process was sent to the Interconnect Center’s through an internal communicator dated 10/29/01. The title was “Qwest response to CLEC questions concerning the current LNP Port Out process of holding switch translations and order completion until the next business day at 11:59pm.” * The process agreement is as stated: The ten (10) digit unconditional trigger and switch translations associated with the end user customer’s telephone number will not be removed, nor will Qwest disconnect the customer’s billing and account information, until 11:59p.m. (local time) of the next business day after the due date.

For due date changes or cancellation’s on existing LSR’s the following process should be followed:

Due Date Changes * You must notify Qwest via LSR supplement or notification to the ISC if you require a DD change for your port activity * Notifications of DD changes via a LSR supplement should be made as soon as possible on the DD and prior to 8:00 PM Mountain Time. * Late notification of DD changes will require that you call the ISC prior to 12:00 noon on the day after the DD (in the end-users' time zone) and issue a LSR supplement via IMA or IIS to confirm the request. If the port due date falls on a Saturday, the CLEC should notify the ISC no later than the following Monday by noon of the DD change. * Late DD change notifications after 12:00 noon the day after the DD, will require you to contact the Call Center Representative at 888-796-9087 to initiate an escalation ticket for these late changes. The CLEC should also issue a LSR supplement via IMA or IIS to confirm the request. The CLEC should also issue a LSR supplement via IMA or IIS to confirm the request.

Cancels * You must notify Qwest via LSR supplement or notification to the ISC if you require a cancel of the port activity. ? Notifications of DD cancels via a LSR supplement should be made as soon as possible on the DD and prior to 8:00 PM Mountain Time. * Late notification of DD cancels will require that you call the ISC prior to 12:00 noon on the day after the DD (in the end-users time zone) and issue a LSR supplement via IMA or IIS to confirm the request. . If the port due date falls on a Saturday, the CLEC should notify Qwest no later than the following Monday by noon of the cancellation. * Late cancel notifications after 12:00 noon the day after the DD will require you to contact the Call Center Representative at 888-796-9087 to initiate an escalation ticket for these late cancels. The CLEC should also issue a LSR supplement via IMA or IIS to confirm the request.

Qwest Interconnect Service Center hours of operation to support the functions described above are: 6 AM to 8 PM Mountain Time, Monday-Friday 7 AM to 5 PM Mountain Time on Saturday

With the implementation of this new process, the CLEC is still responsible for notifying Qwest if they are unable to meet their requested port due date. Service order completion and disconnect of switch translation’s are not scheduled to occur anytime prior to the 11:59 p.m. time frame the next business day following the due date. However, the port subscription message was sent for the initial CLEC desired due date and changes or cancellation’s must occur as outlined above or as noted in the supplement information listed in the Product catalog.

Sincerely,

Joan Wells Process Manager Local Number Portability

CC: Margaret Bumgarner Lorna Dubose Constance Overly Kate Spry

Open Product/Process CR PC120301-6 Detail

Description Of Change

Here is the industry documentation from the ASOG for two-six code assignment:

53 TSC - Two Six Code

Identifies a code assigned to a trunk group or a CCS link

Set.

NOTE 1: The code set is unique to each established

trunk group or CCS Link Set and is provided to the

customer on the Firm Order Confirmation or Design and

Order Confirmation. The TSC entry may then be

populated by the customer when ordering changes,

additions or deletions to an existing trunk group or CCS

Link Set.

Clearly Qwest is not in compliance with inventorying the two-six code, as the ASOG specifically states the two-six code is provided to the customer on the FOC. In the case where Qwest initiates ASRs, Qwest is the customer and AT&T is the supplier. Consequently, Qwest should be inventorying the two-six code provided by AT&T to Qwest on the FOC.

Expected Deliverables:

AT&T expects that Qwest will comply with industry guidelines and change process to begin to inventory the two-six code that AT&T assigns to Qwest-initiated ASRs.

Status History

Project Meetings

11/20/02 November CMP Meeting Qwest (Thomte) indicated that the trial orders that were established to convert the embedded base trunk groups in Wyoming were successful. The result is that both new trunks and embedded trunk groups appear to process through the systems using the AT&T Two Six code of CC. Qwest recommended that this CR move to CLEC Test and potentially be completed in December.

10/16/02 October CMP Meeting Qwest (Thomte) indicated that the trial was continuing and that two trial groups that are due to complete in early November. This CR to remain in “Develoment”.

08/21/02 - August CMP Meeting Qwest (Thomte) indicated progress had been made on this CR. Back end systems and reporting capability should be capable of accepting non Qwest two six code during September. Qwest and AT&T anticipate having a status meeting in late August. AT&T (Van Meter) concurred with the read out. This CR will remain in "Development" status

02/19/02 E-mail from AT&T with some questions about Qwest's response

Subject: RE: Qwest Response to Change Request PC120301-6 "Two-Six Code Inv entory for Local Interconnection Trunk Groups Ordered by Qwest" Date: Tue, 19 Feb 2002 17:20:24 -0600 From: "Stryczek, Kathleen K (Kathy), BNSVC" To: Michael Keegan CC: "Olsen, Linda Kae" , "Martin, Richard" , "Mead, Todd" , "Adkisson, Ann B, NCAM" , "Feinstein, Philip G (Phil), NNCER" , "Scherer, Esther A, NCAM" Michael, Thank you for your response to request PC120301-6 for Qwest to inventory the two-six code provided by AT&T on local interconnection trunk groups ordered by Qwest. If Qwest used the two-six code as the PON, would AT&T be able to report trouble tickets using the AT&T assigned two-six code? Also, would the Qwest maintenance group be able to locate a trunk group by searching for a PON which would have the two-six code embedded? If Qwest uses the AT&T two-six code only in the PON, but not in other systems, then I am concerned that Qwest may not be able to find the two-six code and associated trunk group when AT&T is reporting a trouble involving trunk groups ordered by Qwest. Kathy Stryczek AT&T 602-277-4527

Clarification Call, December 11, 2001, 11:00 am (MDT)

Attendees: Todd Mead, Qwest Linda Kae Olsen, Qwest Peggy Kilgus, Qwest Ann Adkinisson, AT&T Kathy Stryczek, AT&T Ester Shearer, AT&T

Reviewed description of Change Request.

Products impacted: Local Interconnection Service (LIS) Qwest need to have someone from the repair group who is involved in the management and use of the TIRKS system, involved in preparing the response to this CR. AT&T's expectation: AT&T would like Qwest to use the two-six code provided by AT&T when Qwest places an order for a local trunk group.

Action Plan: - Qwest will evaluate various options. This CR will be clarified with the CLEC Community at the January CMP Meeting. Qwest will provide a draft response for discussion at the February 2002 CMP meeting. - AT&T will provide Qwest with a contact in Ameritech to discuss ordering process and use of two-six codes. - Qwest to identify and involve the appropriate repair/TIRKS person to assist Linda in developing the draft response. An internal meeting will be held by next Wednesday (12/19/01)

CenturyLink Response

September 6, 2002

Kathy Stryczek AT&T

Subject: PC120301-6 Two-Six Code Inventory for Local Interconnection Trunk Groups Ordered By Qwest

This is a revised Qwest response to AT&T’s request, that Qwest comply with industry guidelines and change process to begin to inventory the two-six code that AT&T assigns to Qwest-initiated ASRs.

Qwest accepts AT&T’s request regarding complying with industry guidelines and inventory the two six code that is provided to Qwest on the FOC.

Qwest has worked in conjunction with AT&T to provide a trial request that will flow through the various systems and reporting processes. Qwest is currently making the appropriate modifications to support the request for AT&T.

Currently Qwest has one order that is in a trial process. AT&T has advised that they have additional orders expected in the near future. Qwest expects to address AT&T’s additional orders with the revised process.

Sincerely, Qwest

REVISED RESPONSE

September 6, 2002

Kathy Stryczek AT&T

Subject: PC120301-6 Two-Six Code Inventory for Local Interconnection Trunk Groups Ordered By Qwest

This is a revised Qwest response to AT&T’s request, that Qwest comply with industry guidelines and change process to begin to inventory the two-six code that AT&T assigns to Qwest-initiated ASRs.

Qwest accepts AT&T’s request regarding complying with industry guidelines and inventory the two six code that is provided to Qwest on the FOC.

Qwest has worked in conjunction with AT&T to provide a trial request that will flow through the various systems and reporting processes. Qwest is currently making the appropriate modifications to support the request for AT&T.

Currently Qwest has one order that is in a trial process. AT&T has advised that they have additional orders expected in the near future. Qwest expects to address AT&T’s additional orders with the revised process.

Sincerely, Qwest

REVISED RESPONSE

April 10, 2002

Ms. Kathy Stryczek Manager AT&T

SUBJECT: Qwest’s Change Request Response - CR # PC120301-6 Two-Six Code Inventory for Local Interconnection Trunk Groups Ordered by Qwest

This letter is a follow-up response to AT&T Change Request PC120301-6, requesting Qwest inventory the two-six code that AT&T assigns for Qwest initiated ASRs.

Qwest’s written response dated February 12, 2002 informed the CLEC community that Qwest was willing to perform a detailed economic and technical investigation to evaluate the feasibility of implementing the system changes required to meet the intent of this CR.

Qwest has completed its evaluation and has concluded the cost of changing the myriad of downstream-related systems needed to effect this change is prohibitive. Qwest suggests deferral of this CR until the 2003 fiscal year funding review, planned for later this year.

Therefore Qwest regretfully informs AT&T that this CR cannot be processed this year.

Sincerely,

Susan Bliss Director Process Management Qwest

FORMAL RESPONSE

February 12, 2002

AT&T Ms. Kathy Stryczek Manager

SUBJECT: Qwest’s Change Request Response - CR PC120301-6 Two-Six Code Inventory for Local Interconnection Trunk Groups Ordered by Qwest

This letter is in response to AT&T Change Request PC120301-6, Two-Six Code Inventory For Local Interconnection Trunk Groups Ordered By Qwest. AT&T has requested that Qwest inventory the two-six code that AT&T assigns for Qwest initiated ASRs.

During the CLEC Community clarification meeting held January 16, 2002, AT&T confirmed their desire for Qwest to inventory the TSC provided on the FOC for the order. AT&T agreed that this TSC, along with the TCICs and ACTL information provided today, could be provided during the up-front planning meeting for new markets. Qwest could then use this code as the PON number as well as possibly make program modifications that would allow it to be used as the TSC (TGAC) in the processing and inventory systems used by Qwest (EXACT, IABS, TIRKS, WFA, TRDB, etc.)

Qwest is willing to pursue internal system changes to evaluate the feasibility (technical and economical) of implementing such changes. Qwest can not determine all of the systems that would be impacted, nor what the downstream effects on the process would be until the systems evaluations are performed.

If this approach is acceptable to AT&T, Qwest will initiate the required internal system changes and provide a status update at the March CMP meeting.

Sincerely,

Linda Kae Olsen Process Specialist - LIS Qwest

Open Product/Process CR PC040501-1 Detail

Description Of Change

Status History

Project Meetings

Open Product/Process CR 5579794 Detail

Description Of Change

Status History

Project Meetings

Open Product/Process CR 5548341 Detail

Description Of Change

8-01 AT&T request add’l testing documents in regards to end to end testing.

Status History

Project Meetings

CenturyLink Response

Memorandum To: Central Office Directors

September 21, 2001

LX - - DVA (48 Hour) DIAL TONE TESTING REQUIREMENTS

There has been some confusion about the requirement, documented in the CO DVA PROCESS, for the CO to perform a Dial Tone test on DVA for Unbundled Dial Tone Capable Loops (NC Code LX - -). The requirements are:

1. ALL orders provisioning LX - - circuits MUST be checked for Dial Tone at the ICDF CFA. This includes both HOT CUT (Reuse of Facility) and Basic New (Vacant Facility) orders. 2. If the CO performs this test prior to the DVA and: A. Dial Tone is present the results must be logged in the order OSSLOG, using the OSSRMK screen in WFA-C. B. Dial Tone is NOT present the CO personnel MUST arrange to retest for Dial Tone on the DVA Critical Date by either: - Completing the DVA step partially and reloading the step to the DVA date. - Completing the DVA step and manually handling the order for retest (Manual holding bin) - Completing the DVA step and creating their own work request to retest on the DVA, loading this item to themselves or someone else. If someone else is loaded, the person loading the request must check to ensure that person is scheduled to work and that they know the item is loaded to them. 3. If the test is performed on the DVA and: A. Dial Tone is present the results must be logged in the order OSSLOG, using the OSSRMK screen in WFA-C. B. Dial Tone is NOT present, the testing CO personnel MUST contact the Implementer or Coordinator assigned to work the order (check the OSSOI screen in WFA-C). If none is assigned them must call the toll free number for the Design Service Center handling the order and give the trouble condition to the first implementer or coordinator they reach. Any Center personnel receiving this call SHOULD take the report and initiate Center activity for CLEC notification. This test failure MUST be logged in the OSSLOG. 4. If the time between DVA critical date and Due Date commitment time is greater that two (2) business days, the DSC/QCCC Implementer or Coordinator will determine this and hand off an SPL48 ticket requesting a Dial Tone retest two business day before commitment date. This should be the only time the CO would expect such a handoff.

The important points to remember are: - The CO is ultimately responsible for ensuring this Dial Tone test is peformed. - The CO must arrange their own retest if working DVA steps prior to DVA and NO DIAL TONE is found. - SPL48 tickets will only be generated by the DSC/QCCC under the situation stated in item (4.) above.

Please cascade this memo through your organizations. If you have any questions or comments, please contact me.

Cc: Central Office Senior Directors Deborah Heckart Fred Aesquivel

Open Product/Process CR 5582078 Detail

Description Of Change

Status History

Project Meetings

To discuss order processing or status, including Firm Order Confirmation (FOC) and Service Order Confirmation (SOC) Notice, or to send associated information to the appropriate Center for processing, contact our Customer Service Centers. Based on the location of your end-user and the type of service you requested, Local or Access Services, our Service Center numbers are:

LSRs for Interconnect Resale Services, Asynchronous Transfer Mode (ATM) Services, Resale Frame Relay, Complex Resale, Centrex, Local Number Portability (LNP), Interim Number Portability (INP), Unbundled Local Loops and Elements: Location Contact Fax Hours of Operation Interconnect Service Center (ISC) 888-796-9087 888-796-9089 - FAX Monday-Friday 6:00 AM - 10:00 PM Mountain Time Saturday 7:00 AM - 6:00 PM Mountain Time

Qwest's Service Center is available to assist with your needs and, if additional assistance is required you will be transferred to the Customer Service Inquiry and Education (CSIE) Center until 8:00 PM MTN Time Monday – Friday. If additional assistance is required after 8:00 PM or on Saturday, Qwest will coordinate a call back or provide additional assistance as needed.

November 6, 2001

Joan Wells Qwest LNP Process Manager

RE: CR Form #5582078

AT&T understands Qwest has denied its request to expand Qwest’s Interconnect Centers hours as stated at the October 17, 2001 monthly CMP meeting. Qwest has agreed to change the CR status to “deferred” until the May 2002 Product and Process CMP meeting. AT&T has three areas of concern with Qwest’s response:

AT&T recognizes NeuStar’s standard hours of operation do not include Saturday or Sunday; however, Qwest’s own action of providing support on Saturday acknowledges Saturday as an important port day for AT&T Broadband regardless of NeuStar’s hours of operation. Therefore, AT&T believes NeuStar’s standard hours of operation is not a determining factor for Qwest in regards to expanding its hours of support for Saturday or specifically, Sunday.

Although “port activity may currently be scheduled for any desired frame due time”, there are switches within Qwest’s network that cannot be set mechanically. Does Qwest have edits built into its systems to reject or defer LSRs in this scenario? How can these switches be identified?

The last concern centers on the 24-hour AMSC level of support that Qwest has offered. In the October 17 Product and Process CMP meeting, Qwest stated that the technicians at the AMSC center do not have access to Qwest’s provisioning systems for LNP. Offering this center as an alternative to expanding the Interconnect Centers hours only delays and provides a false expectation to CLECS trying to resolve outstanding porting issues. Therefore, AT&T does not believe this as an acceptable alternative to our change request.

AT&T believes continued discussions need to take place as AT&T’s business volumes continue to grow with Sunday porting activity.

Sincerely, Terry Bahner AT&T Local Services – LSAM Western Region

CC: Sharon Van Meter Tim Boykin Donna Osborne-Miller Mitch Menezes September 7, 2001 2:15 p.m.

Attendees:

Terry Bahner (AT&T), Donna Osborne-Miller (AT&T), Sharon Van Meter (AT&T), Lorna Dubose (Qwest), Joan Wells (Qwest), Michael Buck (Qwest), Todd Mead (Qwest)

Qwest clarified some information regarding the forecast information provided by AT&T on 9/5; the forecast information provided is a projection of daily volume in all markets within Qwest territory

Action Items: - Lorna Dubose (Qwest) to communicate forecast information to Ken Beck and Toni Dubuque (9/10) - Lorna Dubose (Qwest) to provide Qwest response (9/14/)

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Monday, August 27, 2001 1 p.m. Attendees: Terry Bahner (AT&T) Sharon Van Meter (AT&T), Lorna Dubose (Qwest), Michael Buck (Qwest), Todd Mead (Qwest) Terry explained that AT&T is interested in a window of Qwest support for LNP on Sundays after NPAC comes up. There is also a desire for Qwest support into the evening hours during the week. As an example, Terry cited the fact that AT&T gets orders until 10 p.m. (daylight time) in Salt Lake City. Lorna explained that Qwest center management could evaluate the possibility of expanded hours once the appropriate forecasting information is provided. The information to be included in the forecast: Expected volume by day and hour; any fluctuations expected (e.g. due to daylight savings time). Terry explained that she expected to be able to provide Qwest with forecast data by September 4. Lorna indicated that Qwest would attempt to examine forecast data prior to the September CMP meeting. Qwest will aim to provide a response prior to the September CMP meeting, but the formulation of a response might not be possible. Action Items: - Terry Bahner (AT&T) to provide Qwest with forecast volumes by 9/4/01 - Lorna Dubose (Qwest) to provide Qwest center management with forecast by 9/5/01 - Lorna Dubose (Qwest) to develop Qwest response by working with center management (tentative target: 9/7/01; with Michael Buck to organize walk-through meeting with AT&T during early week of 9/10/01)

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LNP Meeting Notes 8/13/01

Attendees: Lorna Dubose Matt Rossi Terry Bahner Donna Osborne-Miller CR #5582078 – Expand Qwest’s interconnect center’s hours - Lorna currently waiting on response from the Qwest Interconnect Hours - Terry to give estimate to Lorna on call volume to expect

CenturyLink Response

Ms.Terry Bahner, Ms. Donna Osborne-Miller, AT&T

This letter is in response to CLEC Change Request Form #5582078, dated June 6, 2001. This Change Request pertains to a request by AT&T to Expand Qwest’s Interconnect Center hours to include a window of 6am MST to 10pm MST, Sunday through Saturday.

At this time, Qwest has no plans to expand the Interconnect Center hours. The following are some of the reasons that Qwest has made this decision: Currently, Qwest’s published normal hours of work are Monday – Friday 7am MST to 7pm MST. These hours are in parity in both Qwest Wholesale and Qwest Retail. Qwest Interconnect Center’s hours have already been previously expanded to 6am MST to 8pm MST Monday-Friday and 7am – 5pm MST on Saturday’s. NeuStar’s standard hours of Operation for the NPAC are Monday – Friday 7am – 7pm CST/CDT. The Qwest Interconnect Center hours currently exceeds this standard. Economic conditions currently do not facilitate an increase in head count to support the proposed increase in order activity and expansion. Lack of support from downstream systems, currently operating under the standard business hours. System maintenance necessities (i.e. scheduled down time) do not support expansion. Access to automated systems for order input is already available. Port activity may currently be scheduled for any desired frame due time in those switches where the ten digit triggers are set mechanically. 24-hour support is currently available through the Account Maintenance Support Center (AMSC) in handling repair issues that are a result of number portability.

At this time, Qwest will not expand its Interconnect Center hours further. Qwest had originally proposed that we review the expansion request again in one year, but at Clec request, Qwest has agreed to review again in six months.

Sincerely, Joan Wells Qwest LNP Process Manager

September 20, 2001

DRAFT RESPONSE For Review By CLEC Community and Discussion at October CMP Meeting Wholesale Product/Process Ms.Terry Bahner, Ms. Donna Osborne-Miller, AT&T

This letter is in response to CLEC Change Request Form #5582078, dated June 6, 2001. This Change Request pertains to a request by AT&T to Expand Qwest’s Interconnect Center hours to include a window of 6am MST to 10pm MST, Sunday through Saturday. At this time, Qwest has no plans to expand the Interconnect Center hours. The following are some of the reasons that Qwest has made this decision: Currently, Qwest’s published normal hours of work are Monday – Friday 7am MST to 7pm MST. These hours are in parity in both Qwest Wholesale and Qwest Retail. Qwest Interconnect Center’s hours have already been previously expanded to 6am MST to 8pm MST Monday-Friday and 7am – 5pm MST on Saturday’s. NeuStar’s standard hours of Operation for the NPAC are Monday – Friday 7am – 7pm CST/CDT. The Qwest Interconnect Center hours currently exceeds this standard. Economic conditions currently do not facilitate an increase in head count to support the proposed increase in order activity and expansion. Lack of support from downstream systems, currently operating under the standard business hours. System maintenance necessities (i.e. scheduled down time) do not support expansion. Access to automated systems for order input is already available. Port activity may currently be scheduled for any desired frame due time in those switches where the ten digit triggers are set mechanically. 24-hour support is currently available through the Account Maintenance Support Center (AMSC). At this time, Qwest will not expand its Interconnect Center hours further. Qwest will review this expansion request again in one year.

Sincerely,

Joan Wells Qwest LNP Process Manager

CC: Lorna Dubose Judy Schultz Margaret Bumgarner Michael Buck Todd Mead

Open Product/Process CR 5582099 Detail

Description Of Change

Status History

Project Meetings

Cc: Tim Boykin Sharon Van Meter Donna Osborne-Miller

November 14 - CMP Meeting Callan-Qwest described the CR and the Qwest response. Bahner-AT&T stated that she did not want the CR to be closed as she had just received the response. She also noted that Qwest has not shared its PID data with AT&T. Clausen-Eschelon stated that this CR should not be in CLEC test. Bahner-AT&T stated that she was under the impression that Qwest was moving toward a solution to the CR, but that the recent response was a denial. Callan-Qwest stated that Qwest had evaluated the potential solution and was not prepared to accept the risk of changing a stable system platform, which would be the result of moving forward with a solution to the CR. Dixon-Worldcom asked if this measure was in the PAP. Callan-Qwest stated that it is a PID and it is also a PAP, except in Arizona. Dixon-Worldcom stated that this was inconsistent with his understanding of the Qwest agreements. He understood that Qwest would automatically incorporate all of the ROC measures into the Arizona filing. Callan-Qwest stated that it was her understanding that this had not been requested as a PAP in Arizona. Schultz-Qwest stated that Qwest would take an action item and report at the next meeting. She stated that the CR is denied and asked what status AT&T wanted to leave it in. Bahner-AT&T stated that she would like it left as Presented until next month.

November 6, 2001 AT&T Response to our final position on the CR. Lorna Dubose Qwest LNP Wholesale Product Manager

RE: CR Form #5582099 This letter is in response to the status you provided at the October 17, 2001 Product and Process CMP meeting. We look forward to Qwest implementing a system change that would disconnect the TN out of the switch immediately after AT&T Broadband activates the number. This change would eliminate unnecessary loss of dial tone between Qwest and AT&T Broadband, reduce the number of work backs and snap backs and in general, provide continuity to the LNP process. In the interim, AT&T Broadband will continue to operate under the process formally introduced on August 20th, 2001.

We look forward to the next status in November and a possible implementation date in 2002.

Sincerely, Terry Bahner AT&T Local Services – LSAM Western Region

CC: Sharon Van Meter Tim Boykin Donna Osborne-Miller Mitch Menezes

Internal Status Update Meeting (9/18/01 4:30 p.m.) Attendees: Michael Buck (Qwest), Lorna Dubose (Qwest) Internal cost analysis still on track for 9/28/01 completion. Lorna updated target date for formal AT&T response to 10/12/01.

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September 7, 2001 2:15 p.m.

Attendees:

Terry Bahner (AT&T), Donna Osborne-Miller (AT&T), Sharon Van Meter (AT&T), Lorna Dubose (Qwest), Joan Wells (Qwest), Michael Buck (Qwest), Todd Mead (Qwest)

Qwest provided a status update on this CR. Qwest has received time and cost estimates from 2 vendors to date. Qwest will be seeking a time and cost estimate from a third vendor. The addition of a third vendor is not expected to adjust the dates communicated in the August 27, 2001 Clarification Meeting. AT&T asked whether Qwest has yet committed to performing the change requested in this request. In response to a question from Sharon, Lorna indicated that Qwest has not yet committed to doing the work requested in this CR. The decision whether or not do the work is dependent upon the cost analysis scheduled for completion by 9/28/01.

Action Items:

- Lorna Dubose (Qwest) to create cost analysis based upon vendor time and costs by 9/28/01 - Lorna Dubose (Qwest) to develop Qwest response based upon cost analysis (tentative target: 10/5/01)

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Monday, August 27, 2001 1 p.m. Attendees: Terry Bahner (AT&T), Sharon Van Meter (AT&T), Lorna Dubose (Qwest), Michael Buck (Qwest), Todd Mead (Qwest) Terry confirmed that the goal of this CR is to have Qwest provide a response regarding AT&T’s desire that LNP disconnects not be released until a corresponding activate transaction is received from NPAC indicating that AT&T service is operational.

Terry indicated that previous action taken by Qwest (i.e. delayed posting of disconnects until due date plus 1 day) is helpful, but does not address the core of this request. Lorna reiterated that Qwest is still seeking vendor time and cost estimates to provide the functionality requested by AT&T.

Lorna expects to develop a cost analysis based upon vendor responses by the end of September. At that time Qwest will make a decision whether or not to pursue the vendor proposals.

Lorna does expect to be able to provide an interim status update at the September CMP meeting. As of August 29, 2001 time and cost bids have been received from both vendors involved in this CR.

Action Items: - Lorna Dubose (Qwest) to create cost analysis based upon vendor time and costs by 9/28/01 - Lorna Dubose (Qwest) to develop Qwest response based upon cost analysis (tentative target: 10/5/01)

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LNP Meeting Notes - 8/13/01

Attendees: Lorna Dubose Matt Rossi Terry Bahner Donna Osborne-Miller

- Qwest looking at long term solution - Price bid expected from Telcordia by 8/27 - Price bid expected from another vendor 08/30 - Cost analysis and internal analysis to be conducted by Qwest 09/28 - Estimated implementation date set for no earlier than Q1 2002

CenturyLink Response

Ms. Terry Bahner Ms. Donna Osborne-Miller

AT&T

This letter is in response to your CLEC Change Request Form, number 5582099 dated June 6, 2001 – LNP Switch Disconnect Timing.

Request: Change current switch disconnect process to where disconnect occurs immediately after AT&T Broadband activates the number.

Response: Qwest understands the goal is to eliminate disconnection of customers in error. Qwest has agreed to Performance Measurement OP-17 - Timeliness of Disconnects Associated with LNP Orders with a standard of 98.25%. Qwest is in full support of this measure and has committed to this standard.

In August, Qwest completed the mechanization of the solution to hold the switch translations and the service orders until 11:59 P.M. of the next business day after the port due date. Initial analysis of internal data from before and after the implementation indicates a 73% reduction in loss of dial tone and an 84% reduction in workbacks.

Qwest did evaluate several vendor proposals outlining a system solution to time the switch disconnect with the port activation. Qwest believes that our current process and recent system mechanization has provided a reliable and stable platform for the completion of port orders. As a result of the analysis of the vendor proposals, and the service improvements from our own internal system changes; we will not be pursuing any additional system enhancements. No further action is planned. Sincerely,

Maureen Callan Group Product Manager

Open Product/Process CR 5582212 Detail

Description Of Change

Status History

Project Meetings

Joan Wells Process Manager Local Number Portability

RE: CR Form #5582212 AT&T has submitted LSRs requesting the new 3-day service interval for Megabit service established after April 4th, 2001. At this point in time, only a small number of orders have been pushed out to the previous 5-day interval. AT&T considers this a coaching issue within Qwest and has socialized it with the typing centers and the Denver Interconnect center during our weekly conference calls. We will close this CR at the November 14th, 2001 Process and Product CMP meeting. Thank you for providing AT&T Broadband the tools to identify the appropriate USOCS. Sincerely, Terry Bahner AT&T Local Services – LSAM Western Region

CC: Sharon Van Meter Tim Boykin Donna Osborne-Miller Mitch Menezes

September 14, 2001

Lorna Dubose LNP Wholesale Product Manager Qwest Communications 1801 California Street Denver, Colorado 80202

RE: Your letter dated September 5, 2001 regarding change request 5582212 – 3-day interval Megabit Line

Dear Lorna:

AT&T believes Qwest has, in part, addressed CR 5582212. Going forward, any local service request to port an end-user’s telephone number that Qwest currently lists as a Megabit service qualifies for the 3-day interval if the Megabit service was installed with Qwest after April 4, 2001. AT&T would prefer this 3-day interval apply to all Megabit services regardless of the April 4th date.

Qwest has indicated AT&T Broadband can determine this date by reviewing the customer service record. AT&T Broadband has yet to determine if a Qwest install timestamp is present next to the USOC. AT&T would like Qwest to issue a unique USOC to help identify Megabit services installed after April 4th to assist in acquiring the 3-day interval. Your consideration to this request would be appreciated.

Sincerely,

Terry Bahner Supervisor Local Services Access Management Western Region

CC: Tim Boykin Sharon Van Meter Mitchell Menezes

###

September 7, 2001 2:15 p.m.

Attendees:

Terry Bahner (AT&T), Donna Osborne-Miller (AT&T), Sharon Van Meter (AT&T), Lorna Dubose (Qwest), Joan Wells (Qwest), Michael Buck (Qwest), Todd Mead (Qwest)

The Qwest response to this CR was presented; multiple clarification questions were asked and answered:

Q: Why is April 4, 2001 date important? A: This is the date when the process change for engineering megabit requests as non-design took place

Q: So the service offered did not change after April 4? A: Correct. Only an internal process was changed. The megabit service offered did not change.

Q: How should CLEC determine the customers’ install date? A: The necessary information should be available in the CSR (Customer Service Record). In Qwest internal systems both the USOC and the date are visible. Also, another option is to ask the customer when their service began.

Action Items:

- Terry Bahner (AT&T) to confirm that necessary information is available in the CSR visible to AT&T (9/13) - Terry Bahner (AT&T) to take Qwest response to AT&T stakeholders (9/13)

###

Monday, August 27, 2001 1 p.m. Attendees: Terry Bahner (AT&T), Sharon Van Meter(AT&T), Lorna Dubose (Qwest), Michael Buck (Qwest), Todd Mead (Qwest)

Terry clarified that the request for a reduced interval for LNP of megabit lines applies only to the ported number NOT the facilities. Terry indicated that AT&T had put in place procedures to inform customers of the impact to megabit facilities when AT&T ports only the number. Lorna indicated that she was working with appropriate product and process groups to address this request.

Action Items: - Lorna Dubose (Qwest) to formulate Qwest response by 9/5/01 - Michael Buck (Qwest) to organize a walk-through meeting with AT&T during late week of 9/3/01.

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LNP Meeting Notes – 8/13/01

Attendees: Lorna Dubose Matt Rossi Terry Bahner Donna Osborne-Miller

- Lorna scheduled meeting with Megabit Product Manager on 8/16 - Status update will be given to Terry Bahner after that meeting

CenturyLink Response

This letter is in response to CLEC Change Request Form, number 5582212 – 3 day LNP LSR interval for Megabit Line, dated June 6, 2001.

Request: Qwest considers a megabit line as a complex and requires a 5-day interval. Since LNP is porting a number only and does not need the special facilities, it should be treated as a ported number and have a 3 day interval.

Response: After meeting with the Megabit Product Manager and the Interconnect Service Centers, it has been determined that as of April 4, 2001, Qwest implemented a new process for engineering Megabit service and it is now considered a non-design/simple service. Therefore, end-user customers that ordered Megabit service after April 4, 2001 had their service installed as non-design/simple service. This type of Megabit service can have a 3-day interval, which is the same as simple LNP orders today. However, if the Megabit end-user service was installed prior to April 4, 2001, the service is still considered a design/complex service. This requires service interval timeframes that allow Qwest systems to accurately remove the switch translations and process the order completion. Appropriate intervals for the Complex Product type will continue to apply. These intervals are shown in the LNP Product Catalog under Standard Intervals for LNP or the Service Intervals for Interconnection & Resale located at Qwest.com.

New USOC’s were developed for this network platform change. Effective 04-04-01, the Basic and Pro Services using the HRL++ USOCs will be grandparented and may not be used for ordering new services. The new Qwest DSL basic line 1FB/1FR, AFK/AFH Usoc’s are GRL++ and will be used after the 04-01-01 date.

The Select Service using HRC++ USOCs also, are no longer available for use.

Grandparented USOC’s are as follows: HRCA1, HRCA3, HRCA5, HRCWM & HRL51, HRL53, HRL55, HRL5M, HRLA1, HRLA3, HRLA5, HRLAM, HRLB3, HRLB5, HRLBM, HRLC1, HRLC3, HRLC5, HRLCM, HRLD1, HRLD3, HRLD5, HRLDM, HRLE1, HRLE3, HRLE5, HRLEM, HRLF1, HRLF3, HRLF5, HRLFM, HRLG1, HRLG3, HRLG5, HRLGM, HRLW1, HRLW3, HRLW5, HRLWM

New USOC’s are as follows: GRLA1, GRLA3, GRLA5, GRLAM, GRLB1, GRLB3, GRLB5, GRLBM, GRLC1, GRLC3, GRLC5, GRLCM, GRLD1, GRLD3, GRLD5, GRLDM, GRLE1, GRLE3, GRLE5, GRLEM, GRLF1, GRLF3,GRLF5, GRLFM, GRLG1, GRLG3, GRLG5, GRLGM, GRLSM, GRLW1, GRLW3, GRLW5, GRLWM, GRLYM.

This list in not inclusive of all products provisioned with DSL. If further information is needed, please consult your Service Manager or a USOC guide.

In conclusion: In order to qualify for the 3-day interval, it will be necessary for the CLEC to know when Qwest installed the end-user’s Megabit service (before or after April 4, 2001) and whether the account meets the required criteria for requesting a 3-day interval. If the CLEC is unable to obtain the date of the installation information from the CSR or is unable to determine by the USOC, then additional consultation with the end user by the CLEC may be needed to find out when their Megabit service was installed, prior to or after the April 4th, 2001 date. Should the CLEC submit an LSR with a 3-day interval request and Qwest determines that the Megabit service does not qualify for the simple interval, then the FOC would be sent to the CLEC with the appropriate Design/Complex interval due date.

Discussion has occurred with the Interconnect Service Centers to reinforce this change that was previously documented, and sent out to the Centers, when the change occurred in April. Qwest will continue to follow the service interval guidelines for simple and complex services as outlined in the Product Catalog (PCAT).

Sincerely, Joan Wells Process Manager Local Number Portability

Open Product/Process CR 5582288 Detail

Description Of Change

Description changed resulting from 8/27/01 meeting.

The app date calculation for all LNP requests will reflect a 7 p.m. daily cut-off time rather than the 3 p.m. cut-off currently in place. Any LNP request received prior to 7 p.m. will receive an app date of the current date. Any LNP request received after 7 p.m. will receive an app date of the next business day.

Status History

Project Meetings

RE: CR Form #5582288 AT&T understands Qwest is denying our request to include Saturday as a business day in the SIG. In addition, Qwest is denying our request to manually change orders submitted prior to 7 p.m. MST on Wednesday to reflect a Saturday install date in lieu of a system change.

AT&T appreciates Qwest expanding the LSR submission deadline from 3 p.m. to 7 p.m. MST with the IMA 8.0 release. We are disappointed at the restriction placed on Saturday ports which Qwest had previously honored under the 3-day SIG (submissions of LSRs on Wednesday). Any additional action concerning this change request will be handled in a different venue when prudent. Sincerely, Terry Bahner AT&T Local Services – LSAM Western Region

CC: Sharon Van Meter Tim Boykin Donna Osborne-Miller Mitch Menezes

September 14, 2001

Lorna Dubose LNP Wholesale Product Manager Qwest Communications 1801 California Street Denver, Colorado 80202

RE: Your letter dated September 5, 2001 regarding change request 5582288 - Saturday as a business date

Dear Lorna:

It was not the intention of AT&T to worsen the service delivery to our customers by accepting the LNP Service Intervals in the State 271 Workshops. Section 10.2.5.2 LNP Standard Intervals has been reviewed and AT&T does not believe this section prevents Qwest from processing the change request to include Saturday as a business date for the LNP product. In fact, AT&T can find no dialogue from the 271 workshops which addressed omitting Saturday as a business day when determining LNP intervals.

Before the IMA 8.0 upgrade the weekend of August 18th, Qwest honored a 3-day interval for a Saturday install as long as AT&T Broadband submitted the LSR prior to 3 p.m. MST on Wednesday. Qwest’s typing center set expectations that AT&T passed on to its customers by providing a FOC with the 3-day interval.

Qwest has stated Saturday cannot be counted in the standard interval. Per Qwest, all local service requests must be submitted prior to 3pm MST on Tuesday to receive the Saturday install date. While AT&T understands Qwest has implemented and updated their systems to reflect its intervals, AT&T believes changes to the same system including Saturday as a business day can also be accomplished in an upcoming release. Though AT&T realizes Qwest is extending its business day from 3:00 p.m. to 7:00 p.m. MST, it does not satisfy the CR5582288 AT&T submitted. Saturday is a critical install day for AT&T Broadband. Qwest’s shift in process and the failure to inform AT&T of this change created an undue and sudden burden for AT&T Broadband’s customers.

Therefore, AT&T would like to partner with Qwest to implement a change as previously practiced by Qwest which includes Saturday. In the interim, AT&T is requesting Qwest to manually change orders submitted prior to 3:00 p.m. MST on Wednesday to reflect a Saturday install date. Thank you for your consideration.

Sincerely,

Terry Bahner Supervisor Local Services Access Management Western Region

CC: Tim Boykin Sharon Van Meter Mitchell Menezes

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September 7, 2001 2:15 p.m. Attendees:Terry Bahner (AT&T), Donna Osborne-Miller (AT&T), Sharon Van Meter (AT&T), Lorna Dubose (Qwest), Joan Wells (Qwest), Michael Buck (Qwest), Todd Mead (Qwest) The Qwest response to this CR was presented. AT&T reiterated concerns presented in an e-mail from August 30, 2001. The concerns centered on the fact that from June 1 until August 20 Qwest had used a process that allowed for a 3-day interval. After August 20 Qwest adjusted its process, requiring that requests be received by 3 p.m. Tuesday to qualify for a Saturday install. AT&T understands Qwest’s position that the process in place from June 1 through August 20 was incorrect. Furthermore, AT&T understands Qwest’s position that a reversion of process is necessary to remain compliant with guidelines decided in 271 Workshops. However, AT&T believes that Qwest should have been more effective in communicating the process change which resulted in an increase in the necessary interval to support a Saturday install. Qwest indicated that effective communication is a key element to implementing changes that affect CLECs.

Action Items: - Terry Bahner (AT&T) to provide confirmation of response acceptance (9/13)

### E-Mail from Terry Bahner (AT&T) to Qwest Thursday, August 30, 2001 12:15 p.m.

It's clear from the Qwest-Broadband call I facilitated this morning that Qwest has changed their process regarding the 3 day interval proces+U3when it pertains to a Saturday install date. From June 1st (PCNRN051601-1) to August 18, Qwest FOC'd a Saturday install date using the 3 day interval guide. As long as the LSR was sent prior to 3pm mst on Wednesday, Qwest gave the Saturday install date. On August 20th, Qwest changed its process. The LSR must be submitted on Tuesday before 3pm to have a Saturday install date. Qwest now states the due date interval guidelines do not include Saturday. Qwest has indicated the process was always in place and it was incorrectly interpreted by Qwest Escalations and typists and was therefore granted in error. AT&T reviewed the RN on multiple conference calls with Qwest and was told the requested Saturday date would be met. Further more AT&T was never informed the RN was a test/trial subject to change and/or interpretation by Qwest. AT&T considered the notification sent by Qwest on June 1st as a product and process change not a temporary fix as so indicated on this morning's call. While I welcome the extension of 3pm mst to the tentative 7pm mst, it no longer meets the intent of the CR. Therefore, please pursue with AT&T's request to include Saturday in Qwest's due date interval guidelines.

Thank you. Terry L. Bahner AT&T LSAM

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Monday, August 27, 2001 1 p.m. Attendees: Terry Bahner (AT&T), Sharon Van Meter (AT&T), Lorna Dubose (Qwest), Michael Buck (Qwest), Todd Mead (Qwest) Terry re-confirmed AT&T understands CR scope resulting from 8/14/01 meeting. To wit, the app date calculation for all LNP requests will reflect a 7 p.m. daily cut-off time rather than the 3 p.m. cut-off currently in place. Any LNP request received prior to 7 p.m. will receive an app date of the current date. Any LNP request received after 7 p.m. will receive an app date of the next business day.

In follow-up, Terry clarified: This is separate from agreeing to the current app date calculation Qwest has adopted August 20 (IMA 8.0 release) for LNP orders which now negatively impacts AT&T Broadband’s provisioning process and directly affects our market entry. AT&T will submit a separate change request to Qwest to resolve the additional day added to the LNP service interval if Qwest continues the new app date calculation process. This change request’s intent was to further extend the timeframe in submitting LSRs to facilitate a 3-day install; however, Qwest’s new app date calculation has negated this. Lorna indicated that a new Qwest User Request (UR # 2491) has been created to support the requested change. Work is underway to prioritize the request and determine when it will be implemented. This information will be provided in the Qwest response for this CR.

Lorna indicated that efforts had been underway to (piggyback) this CR on an existing user request in an attempt to complete the change sooner. However, that effort failed and new UR (2491) was issued.

Action Items: - Lorna Dubose (Qwest) to formulate Qwest response by 8/31/01 - Michael Buck (Qwest) to organize a walk-through meeting with AT&T during week of 9/3/01.

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LNP Meeting Notes 08/13/01 Attendees: Lorna Dubaose Matt Rossi Terry Bahner Donna Osborne-Miller

NPAC does not currently consider Saturday as a business day AT&T gave an example: if LSR submitted 3:01 pm on Friday - Monday is day 1, AT&T would like Saturday as day 1 Joan Wells mentioned at last CICMP that hours might be expanded to 7pm MST AT&T said that 7pm wold be sufficient and CR could be closed

CenturyLink Response

Wholesale Product Marketing Ms. Terry Bahner and Ms. Donna Osborne, AT&T

This letter is in response to your letter dated September 14, 2001, regarding Change Request 5582288 – Saturday as a business day.

Qwest acknowledges AT&T’s acceptance of the agreed upon 271 Workshop LNP Service Intervals.

As stated in your letter, before the IMA 8.0 release, Qwest would honor a three day interval for a Saturday install for LSR’s submitted prior to 3:00 p.m. Mountain Time on Wednesdays. However, after the IMA 8.0 release each CLEC, will need to submit its LSR for flow-through LNP orders on Tuesday by 7:00 p.m., Mountain Time, in order to have a Saturday due date.

Qwest identified the need to implement system logic to obtain parity between our manual and mechanized processes, company policies, as well as documentation. As a result, IMA was upgraded to support the company Service Interval Guide (SIG), which excludes the calculation of Saturdays, Sundays, and Holidays.

Qwest recognizes Saturday is a critical install day for AT&T Broadband and will continue to offer Saturdays, Sundays, and Holidays as due dates in our switches where the 10-digit unconditional LNP trigger can be set automatically. However, the CLEC will need to submit the LSR within the appropriate interval timeframe as far as business days.

At this time, Qwest appreciates AT&T offer to partner with us to include Saturday as a business day, however, Qwest declines, and will continue to support the agreed upon 271 Workshop intervals and existing company practice for the use of Business days. Thank you for your request.

Sincerely,

Lorna Dubose LNP Product Manager

Open Product/Process CR 5582295 Detail

Description Of Change

Status History

Project Meetings

Subject: CR # 5582295 Update Date: Thu, 11 Apr 2002 09:15:41 -0600 From: "Todd Mead" Organization: Qwest Communications International, Inc. To: Terry Bahner

Terry, Please see below in response to your question about PCAT update:

"The LEFV fid alone is not necessarily cause for the CLEC to be sent a jeopardy notification. Only if the FOC has been sent to the CLEC would we send a jeopardy notification. And the current process of jeopardy after FOC states that in all conditions where an FOC is sent and Qwest has found a problem with the request, we will follow the jeopardy after FOC process. No matter what, if it has been FOC'd and Qwest finds a problem with the LSR, we will follow the jeopardy after FOC process.

Thanks

Todd

03/06/02 Letter from AT&T offering a counter proposal to the matrix Qwest has presented for CR5582295

1875 Lawrence St. Denver, CO 80202-1847

March 6, 2002

Todd Mead CMP Manager Qwest Communications 1801 California Street Denver, Colorado 80202

RE: CR5582295, SCR092601, & Matrix

Dear Todd:

AT&T still has concerns surrounding the interim manual process of how and when Qwest issues a jeopardy after sending the CLEC a FOC for an LSR. We have two specific concerns. This first is the introduction of the Application Date (APP) as a tool to determine AT&T Broadband’s due date when orders are issued a jeopardy condition. And the second is the subjective use of the term "renegotiated".

AT&T believes Qwest could proactively minimize disruption to the customer if Qwest would maintain the CLEC ordered due date more frequently than is possible with the Qwest proposal.

AT&T proposes the following changes to achieve this objective:

1. Jeopardy Condition identified within 24 hours then original FOC’d due date will be maintained - Identified within 24 hours after LSR submission by CLEC - CLEC notified within 24 hours after LSR submission by CLEC - Jeopardy cleared within 4 business hours

Jeopardy Condition identified within 24 hours then original FOC’d due date will be renegotiated - Jeopardy not cleared within 4 business hours

2. Jeopardy Condition identified more than 24 hours then original FOC’d due date will be maintained - Identified more than 24 hours after LSR submission by CLEC but before the due date - CLEC notified more than 24 hours after LSR submission by CLEC but before the due date - Jeopardy condition is Qwest’s fault and CLEC clears the condition within 4 business hours

Jeopardy Condition identified more than 24 hours then original FOC’d due date will be renegotiated - Jeopardy condition is CLEC’s fault and CLEC clears the condition within 4 business hours - Jeopardy condition is not cleared within 4 business hours

3. Jeopardy condition identified on or after the due date - Qwest will immediately work with CLEC to resolve end user customer impact. No negotiated due date

AT&T would like written rules about the meaning of “renegotiated”. AT&T believes the renegotiated interval should have minimal customer impact and never exceed the standard service interval for LNP.

AT&T believes Qwest has reasonable time to identify all errors during the first 24 hours. If an error is discovered and the error is related to a Qwest CSR, a pending retail order or any error Qwest fails to identify, AT&T believes the FOC’d due date should be maintained. Our proposed changes define and clarify the process. We believe this will reduce misinterpretation of the process and provide a consistent response from Qwest during the escalation process.

AT&T appreciates Qwest extending the courtesy call to a third week. This allowed sufficient time for AT&T to verify the jeopardy was being received via EDI. It also provided sufficient time for AT&T to provide Qwest examples of when the process broke.

Sincerely,

Terry Bahner Supervisor AT&T Local Services Access Management Western Region 303-298-6149

Cc: Tim Boykin Sharon Van Meter Donna Osborne-Miller

02/22/02 Response e-mail from Qwest clarifying AT&T question on jeopardy and DD process for LNP

Subject: Re: CMP 2/20/2002: Action Item & Clarification Date: Fri, 22 Feb 2002 16:45:31 -0700 From: "Joan Wells" To: "Bahner, Teresa L (Terry), NCAM" CC: "Jill Martain" , Jill"

02:00 p.m. (MDT) / Friday 08 February 2002

Followup meeting to Investigate top reasons for error condition after FOC

Terry Bahner, AT&T Jonathan Spangler, AT&T Sharon Van Meter, AT&T Donna Osborne-Miller, AT&T Jill Martain, Qwest Joan Wells, Qwest Ric Martin, Qwest Michael Keegan, Qwest Christine Quinn-Struck, Qwest

Jill Martain presented the following historical values : Total LSRs submitted for AT&T in December for LNP was 15,121. Total Non-Fatal errors issued after FOC , 28. Of those 28, 13 were identified on the same day, 7 next day but within 24-hours, 8 after 24-hours.

Joan Wells discussed: The Service Interval Guide for Resale and Interconnection Services The Matrix for resolving Jeopardy Conditions and Effect on the DDD. The Qwest Ordering Screening Process The root cause for PON ZXDNV25275001 TN 303 463-0715 See attached PDF file "CR5582295 Interval Guide & jep matrix" which documents the above.

Joan Wells will revise the Qwest response to reference the discussion outlined in 2.2. The Qwest response will also indicate the desire by Qwest to work with AT&T to minimize changes to the AT&T FOC’d DD.

-

02:00 p.m. (MDT) / Thursday 31 January 2002

Investigate top reasons for error condition after FOC

Terry Bahner, AT&T Jonathan Spangler, AT&T Sharon Van Meter, AT&T Donna Osborne-Miller, AT&T Tim Boykin, AT&T Vernise York, AT&T Cynthia Linenberger, AT&T Ed Longstreet, AT&T Kerri Burke, AT&T Cheryl Moilanen, AT&T Scott Eicher, AT&T Jill Martain, Qwest Joan Wells, Qwest Ric Martin, Qwest Michael Keegan, Qwest Brandi Bentley, AT&T

Jill Martain provided a recap on the progress of CR 5582295 and Systems CR SCR 092601-1 stating we are still moving forward with a February 18 implementation. The process change will discontinue sending a non-fatal error notice after a FOC if an error condition is identified, and will send a jeopardy notice instead. If the error condition is identified within 24-hours, only a jeopardy notice will be sent. If it is after the 24th hour, a courtesy call (for LNP only) will also be made to notify the CLEC of the error condition. Clarification was made it is a courtesy call and the jeopardy notice is the official notification of the jeopardy condition. Jill further explained that if the jeopardy condition was responded to within 4-hours the orders would remain in the system and if no response was received the service orders would be canceled but the LSR would remain in a jeopardy condition for 30-business days. If at the end of 30-business days the LSR is still in a jeopardy status, the LSR would be rejected back to the CLEC..

Jill explained that the error report indentified several types of rejects. AT&T asked if Qwest had an idea of what the numbers were. Jill advised that she did not have time to review the details. AT&T asked for a listing of the areas of the error and the numbers. Jill explained that some problems came about when the order was pending disconnect then the Quality Checkers would notice a retail dissconnect that came through. She also indicated that some problems occur when there is a dfferent address then the one on the LSR.

AT&T asked if Qwest would honor the due date if AT&T issued their Sup. Qwest indicated that it was dependent on the time the Sup came in. Qwest clarified the process advising that when an error condition occurs after an FOC, Qwest will send a Jep notice, not a non-fatal error. The Jep would be sent back the same way the request was received (i.e. EDI, fax, etc.). Qwest explained that the LSR Order will stay in Jep status for 30 days. Qwest will only Jep the order in the first 24 hrs. On the 25th hour, Qwest will send the Jep and place a call. Qwest needs the Sup turnaround within 4 hrs and Qwest will respond in 24 hours after receipt of Sup. Qwest would issue an FOC, which would start the calculation over. AT&T advised that Qwest should still honor the due date if the Sup was issued within the time interval, especially if the Jep was due to a Qwest error. AT&T suggested that we have another meeting to address this question.

Joan Wells discussed the quality check process. A quality check typically takes place within the first day after the FOC. Qwest cannot commit to this timeframe due to potential volume and resource issues.

A question was raised on whether AT&T could have the Due Date. It was clarified that this would be only for LNP. Joan Wells indicated that she would have to go back to the team.

Qwest provided the root cause for the TN example that AT&T provided . The initial reject was due to a wrong address; however, that was corrected by AT&T Broadband. All following actions were the result of a Qwest agent mishandling this order after that FOC was sent. Joan Wells said this person was individually coached.

Action Plan Qwest will review the due date issue and revise its response to CR 5582295 as required. Qwest will pull historical data to identify the percentage of AT&T LSRs that are receiving an error condition after a FOC.. Qwest will set-up another meeting for Friday, February 8, 2002, from 2:00 PM to 4:00 PM. The manual process for all products associated with SCR 092601-1 is scheduled for implementation on 2/18

--

November 6, 2001 AT&T Reply to Final Response dated 10-24-01 Joan Wells Qwest LNP Process Manager

RE: CR Form #5582295

AT&T has stated in previous correspondence to Qwest and at the monthly CMP Product and Process forum the seriousness surrounding Qwest’s process to send a FOC then fatal reject it without notification to the CLECS. AT&T understands Qwest’s current process providing a 4-hour window for response to a non-fatal error notice. However, examples have been shared with Qwest on weekly calls where this process continues to fail. Therefore, AT&T expects Qwest to adhere to its commitment to allow a jeopardy notification after a FOC instead of a non-fatal error after a FOC as submitted under SCR092601-1. This was presented as a walk on at the October 18 Systems CMP meeting by Jill Martain as a candidate for the IMA 10.0 release scheduled for 2002. The CLEC community unanimously agreed to include the LNP product for this CR. Jill Martain concurred.

In regards to AT&T system changes, AT&T anticipated the need to update their IBICS system only after Qwest discounted the use of jeopardy codes on previous calls. When Qwest announced they would pursue using jeopardy codes (Loretta Huff calls August 31, 2001 and September 5th respectively) and informed AT&T that system changes were not required, AT&T did not pursue modifying IBICS since it is currently capable of handling jeopardy codes. AT&T OSS anticipates the upgrade to IMA 10.0 with SCR092601-1 to resolve this issue.

In the interim, AT&T expects Qwest to continue to follow its current 4-hour window process and make every effort to call AT&T Broadband before issuing a fatal reject. AT&T also expects Qwest to socialize this process with all centers directly involved with the LNP process with special emphasis on the Sierra Vista and Phoenix Centers and the duty supervisor in any Qwest Interconnect Center which provisions AT&T Broadband LSRs.

AT&T does not believe this CR has been fully addressed until SCR092601-1 can be implemented or Qwest discontinues its process of fatal rejecting an LSR without CLEC notification.

Sincerely, Terry Bahner AT&T Local Services – LSAM Western Region

CC: Sharon Van Meter Tim Boykin Donna Osborne-Miller Mitch Menezes

September 14, 2001

Lorna Dubose LNP Wholesale Product Manager Qwest Communications 1801 California Street Denver, Colorado 80202

RE: Your letter dated September 5, 2001 regarding change request 5582295 – Cancel after the FOC

Dear Lorna:

Qwest has forwarded two proposals to AT&T. The first was discussed with Loretta Huff from Qwest on Friday, August 31st. The second proposal, Qwest letter sent September 5th, was based on Qwest changing its process and AT&T making changes to IBICS. Ms. Huff, in a conference call, indicated to the CLEC community that Qwest would utilize jeopardy codes on local service requests to alert the CLEC community when an LSR is rejected.

Qwest has taken an action item to internally review which process will be the final resolution to CR 5582295. AT&T has stopped all plans to augment its EDI system based on Ms. Huff’s proposal. AT&T believes the CR has not been sufficiently addressed. Please let me know when Qwest would like to schedule a conference call to discuss the final resolution for CR 5582295.

Sincerely,

Terry Bahner Supervisor Local Services Access Management Western Region

CC: Tim Boykin Sharon Van Meter Mitchell Menezes

Internal Response Clarification Meeting (9/10/01 3:30 p.m.)

Attendees: Joan Wells, Mark Coyne, Jill Martain, Todd Mead, Michael Buck

Mark and Jill explained the context of the Loretta Huff process. Joan provided information regarding Qwest response provided to AT&T. It was determined that the already provided Qwest response was probably accurate and not affected by the Loretta Huff response. However, Joan took an action item to review the Loretta Huff process. Following the review, Joan will update the CR response as necessary.

Action Items:

- Jill Martain to provide Joan Wells with the Loretta Huff process given to the CLECs - Joan Wells to review process and update CR response as necessary (target due date: 9/26/01)

September 7, 2001 2:15 p.m. Attendees: Terry Bahner (AT&T), Donna Osborne-Miller (AT&T), Sharon Van Meter (AT&T), Lorna Dubose (Qwest), Joan Wells (Qwest), Michael Buck (Qwest), Todd Mead (Qwest) Before the Qwest response was presented AT&T indicated that the information contained in the response was contrary to information presented in another meeting held on September 6. Because of this inconsistency, AT&T requested that Qwest clarify the response before AT&T would accept it. Terry Bahner did confirm that the incidence of this situation (i.e. rejection of LSRs after FOC) had been much reduced since installation of IMA 8.0. However, Terry indicated that she was aware of a few situations where an LSR was rejected after FOC. Joan Wells and Lorna Dubose both reiterated that according to guidelines in the PCAT there were some situations in which rejects might occur after an FOC. To rule out system bugs or non-compliance with process Terry will provide examples to Lorna for investigation

Action Items: - Mike Buck (Qwest) to gather additional data from Judy Schultz (9/7) -- completed 9/7/01 - Mike Buck (Qwest) to schedule meeting with Loretta Huff (Qwest), Mark Coyne (Qwest), Joan Wells, and Lorna Dubose (9/10) -- completed 9/10/01 - Qwest to formalize single consistent response to this request (9/12) - Terry Bahner (Qwest) to provide Lorna Dubose (Qwest) examples of rejected requests after FOC (9/14)

Monday, August 27, 2001 1 p.m. Attendees: Terry Bahner (AT&T), Sharon Van Meter (AT&T), Lorna Dubose (Qwest), Michael Buck (Qwest), Todd Mead (Qwest) Terry confirmed that initial indications are that IMA 8.0 fix seems to be working; original problem has occurred only once since IMA 8.0 release. Further testing is still required, but Terry is please with the results. Terry will continue her efforts to confirm/test recent change and report to Lorna as necessary. Terry also provided further information on a second aspect for this CR. Concurrent with the change to IMA, another change was made to AT&T’s IBICS system. The IBICS system change required some coordination with Qwest systems that resulted in the involvement of Cim Chambers (among others). At this point, AT&T recognizes a system change is required in order to receive the final reject from Qwest. AT&T has asked its vendor to supply the patch. The estimated time the patch will be ready is within 30 days. No systems changes have been made at this point in time to recognize a final reject after a FOC. Evaluation will begin once the patch has been installed. Like the changes to IMA 8.0, AT&T needs to evaluate the fix for its efficacy. Terry does not anticipate any further action needed by Qwest to support either the Qwest IMA changes or the AT&T IBICS changes. But until AT&T installs patch and completes confirmation testing Terry would like this CR to remain open. The time frame for observation is dependent on the system patch and Qwest’s newly adopted process to consistently call the Broadband centers prior to the final reject. Allowing AT&T Broadband a four hour window to change or cancel the LSR. Terry also expressed concern that AT&T’s new system, Launch Now, might have the same limitation that resulted in the changes to IBICS. However, Terry agreed that should problems be identified with Launch Now, she would open a new CR to address any Qwest involvement that might be required to support AT&T’s modifications to their system. Action Items: - Terry Bahner (AT&T) to provide Michael Buck with e-mail of Qwest contacts involved with IBICS issue (completed 8/28/2001) - Michael Buck (Qwest) to contact Qwest contacts involved with IBICS issue to confirm no further Qwest involvement needed (completed 8/30/01) - Terry Bahner (AT&T) to provide Lorna with any additional feedback on the results of AT&T confirmation testing for recent IMA changes. Terry to provide confirmation testing results feedback based on when the patch has been installed by AT&T’s vendor. The estimate is 30 days. Terry will provide Qwest a tentative date no later than September 19th CMP if patch has not already been installed. If no issues are identified as part of AT&T confirmation testing, CR to be subsequently closed.

LNP Meeting Notes - 8/13/01

Attendees: Lorna Dubose Matt Rossi Terry Bahner Donna Osborne-Miller

- AT&T getting rejects after FOC - They are not seeing the cancel notification/no phone call – cannot act on 4 hr interval for action - AT&T report that they are still receiving rejects - Terry to get examples of rejected LSRs from the Denver Center (PON numbers) to Lorna and Joan

CenturyLink Response

October 24, 2001 Wholesale Product/Process Ms. Terry Bahner AT&T Communications

This letter is in response to CLEC Change Request Form #5582295, dated June 6, 2001, title of change: Qwest does not cancel LSR after confirming FOC via pending “C’ order. This Change Request pertains to CLEC receipt of an order request cancellation, after having already received a Firm Order Confirmation (FOC). One resolution of this Change Request is specific to LNP Port Out and involved an update to a Qwest internal system. Qwest business process in the IMA 8.0 release was deployed effective August 20th, 2001. A check for pending orders on LNP Port Out requests will now be made, before the FOC is issued. If a pending order exists, the order is placed for manual review.

Additionally, Qwest examined our exception handling processes, including the notifications issued by Qwest in exception situations. The analysis revealed that current Qwest processes sometimes resulted in a non-standard series of notifications, such as an FOC after a reject notice or an FOC after an LSR completion.

To address concerns about exception handling processes, a call was held with a small number of CLEC’s on 8/31/01 to solicit their input on Qwest’s current process. After considering the input that was provided, Qwest is taking the following current actions:

In those cases where an error is discovered after an FOC is sent, Qwest will continue to follow its current process of following the non-fatal reject process. This process was documented in a notice issued on 7/26/01. The process was also documented in IMA EDI 7.0 Disclosure, Addendum #6, released on 8/30/01 and in IMA EDI 8.0 Disclosure, Addendum #1, released on 9/04/01. The current versions of the disclosure documentation states that the CLEC has 2 hours to respond to the non-fatal error notice.

A documentation notice will be sent 9/24/01 indicating that in the situation where an FOC has been sent in error, a 4-hour window will be given for responding to the non-fatal error notice. The EDI Disclosure document will be updated following resolution of the Change Management Process (CMP) Change Request (CR) described below. (Product Specific to LNP, Qwest will allow a 4-hour window for response to a non-fatal error notice, whether or not the FOC has been previously sent.)

Due to CLEC input during the 8/31/01 call requesting a different process be followed, Qwest has opened a CR through the Change Management Process (CMP) for CLEC consideration. The purpose of SCR092601-1 will be to address the process of sending jeopardy notifications instead of following the non-fatal reject process, once the FOC has been sent to the CLEC.

Currently there are internal system limitation’s involving the inability to send jeopardy notification’s in association with Local Number Portability service order requests. This system change is being looked into with completion of the change request SCR092601-1. There is no time frame available for this system change at this time.

Local Number Portability Service Order requests will continue to follow the non-fatal reject process until such time that a system change can be implemented.

Related to this Change Request, AT&T had anticipated the need to update their IBICS system. In response to this perceived need Qwest previously provided systems expertise and answers to questions in support of AT&T planning efforts for intended modifications to their IBICS system. In a status update meeting held on August 27, 2001 AT&T indicated that no further Qwest support was likely to be needed in support of AT&T’s IBICS system modifications. Furthermore, in a letter dated September 14, 2001, AT&T has indicated that all plans to augment its EDI systems have been halted. Should AT&T elect to make IBICS system modifications, Qwest believes that the necessary information has already been provided. The change to Qwest process (via IMA) and the potential change to AT&T’s IBICS system will need to be evaluated to ensure their effectiveness. This confirmation testing effort is the responsibility of AT&T. Qwest understands that AT&T will notify Qwest of any issues that arise during testing of these changes, should they occur. However, it is noted that upon implementation of the new jeopardy process after FOC, that AT&T system changes may no longer be necessary.

It is anticipated that no further Qwest involvement is necessary with regard to this Change Request and that further involvement will center around SCR092601-1.

Sincerely,

Joan Wells Process Manager Local Number Portability

CC: Mark Coyne Loretta Huff Michael Belt Jill Martain Lorna Dubose Margaret Bumgarner Michael Buck Todd Mead

Open Product/Process CR 5582318 Detail

Description Of Change

·1: A certified letter - stating that either no customers were ever installed in the collo or if customers were installed, AT&T has notified them their service will be disconnected or moved - and a copy of the decommission application must to be sent to the Account Team Representative. Prior to this process change, AT&T was not required to do this. We have processed approximately 10 decommission applications so far this year and have not sent a certified letter for any of them.

Resolution: AT&T wants to send the application via email only as before.

2. The decommission process reads "The completion of a decommission request and 100% payment of any outstanding financial obligation, will terminate the billing of recurring charges for the site." What this means to AT&T is that we should be current on any bills for the collocation we are decommissioning. What this means to Qwest is that if there is any outstanding bills - either non recurring or recurring - due for any collocation in Qwest territory, they will NOT process the decommission application until all bills for all sites are paid. AT&T may incur additional monthly charges for the collocation being decommissioned since the application is on hold.

Resolution: It is AT&T’s request that only the non recurring and recurring bills for the collocation being decommissioned be subject to scrutiny.

3. Since Qwest charges AT&T a flat fee to decommission a site, AT&T has inquired about the possibility of conducting a site visit to ensure that Qwest has completed the decommissioning of the site. Qwest has denied AT&T this final site visit. Although Qwest may disconnect power cables, conduct a site visit and complete database work, they do not actually tear down the actual site. Qwest is hoping to lease the space to another CLEC and will not have to rebuild the space. Qwest assures AT&T that if the space is leased within a year of the decommissioning, AT&T will reimbursed some monies for the collo space.

Resolution: AT&T would like proof that the work has been completed.

Status History

Project Meetings

As a result of your feedback concerning Qwest’s recently issued Decommission procedures for existing Collocation sites, Qwest is adopting an interim plan for 90 days. During this interim 90-day period, Qwest will hold a series of meetings and conference calls with the industry to develop mutually acceptable procedures to follow concerning this issue. Please review the interim changes and the calendar of meetings below. We sincerely hope that you will participate.

Interim Changes Effective August 9, 2001 • Qwest will no longer issue a Quote of $3455 for each decommission before monthly recurring billing stops.

Qwest is waiving the Decommission Quote charges effective immediately with issuance of this announcement. Future pricing will be reviewed as part of the “Future Procedures Modifications Process” as described below.

• Qwest will credit past decommission quotes paid and any monthly charges paid past the date of acceptance of the valid application. CLECs can contact their Wholesale Project Manager regarding past decommissions processed or currently being processed.

• The vacating CLEC submitting the “Collocation Application for Cancel, Decommission, or Change of Responsibility” will no longer be required to be current on all billing for all collocation sites, including both monthly and non-recurring quotes before Qwest will process a decommission request.

• The interim requirement will state that a CLEC must be current on “all billing for the specific site for which the decommission application is submitted” for Qwest to decommission a site.

• Qwest will no longer require receipt of the quote charges to stop billing. Monthly billing will stop effective with the valid receipt of a decommission application.

• Applications will no longer need to be sent via certified mail for processing. “Electronic submission of requests to decommission a site can be sent to colo@qwest.com”

Future Procedures Modifications Process Qwest intends to issue future procedures that are acceptable to those parties concerned. For Qwest to implement satisfactory procedures, CLEC feedback is needed and valued. At the completion of this joint 90-day effort, the revised product procedures will be priced, and if appropriate, a template offered by Qwest for an amendment to the CLEC/Qwest

Interconnection Agreements. Please join Qwest in participating in the following calendar of meetings. These meetings will be chaired by Steve Nelson, Group Product Manager Collocation. He can be reached on 303-896-6357. Interested CLECs are encouraged to participate.

Kick-off meeting

August 9th, from 9am to 3pm, 1801 California, Executive Conference room, 23rd floor. Conference bridge: 877-542-1778, pass code 6904985.

1. Review existing product offerings and proposed changes, gather information on additional proposed changes, understand all concerns. Here is a brief outline of the discussion: 2. Agree to as many items as possible initially, table for future review those items requiring detailed response, and respond to disputed items by next meeting for resolution. 3. Capture voting record of participants on each issue, and dissenting opinion as agreed to by the team. 4. Prioritization of changes and timelines. 5. Review costing of current products. Items included in the costing model. 6. Discuss how other ILECs handle cancellation, decommission, change of responsibility or network transfer.

CenturyLink Response

October 31, 2001 Sharon Van Meter Manager, AT&T 1875 Lawrence St., 10th floor Denver, Colorado 80202

CC: William Campbell Steve Nelson Jane Lacy

This letter is in response to CLEC Change Request Form #5582318, dated June 25, 2001. This Change Request pertains to several issues regarding the Decommission product offering. On July 9th Qwest committed to partnering with the CLEC industry to resolve the issues identified in the Change Request Form specifically referring to decommission procedures. In addition, Qwest expanded this effort to review the product offerings for Cancellation, and Change of Responsibility. Throughout the month of August, September and October representatives from Qwest and the CLEC industry met to review the procedures for administering a Cancellation and Decommission request. The Qwest/CLEC Forum meetings will continue as we work together to revamp the Change of Responsibility product offering procedures. Successful resolution was achieved for those items addressed in the Decommission Change Request Form. Your efforts were instrumental in this partnership effort.

The following is a summary of the issues identified in the Decommission Change Request Form and the resolution for each: AT&T objected to process changes unilaterally without input from AT&T. Qwest committed to participate in a joint effort to review the Cancel, Decommission, and Change of Responsibility product offerings with CLEC industry and met that commitment. AT&T objected to the requirement to submit a certified letter stating that AT&T customers were notified of the disconnect or move. Qwest agreed to modify the process and allow both the application and confirmation notice to be sent electronically to the rfsmet@qwest.com mailbox. AT&T objected to the requirement that 100% payment of any outstanding financial obligation must be met in order to terminate billing of recurring charges. Qwest modified the procedures to state that financial obligations must be met with respect to the collocation site that is being decommissioned only. We further defined the financial obligations to include all non-recurring and monthly recurring charges must not be greater than thirty (30) days past due. AT&T objected to when the monthly recurring charges would cease. Qwest agreed that the billing end date will coincide with the date of a valid Decommission Application submit date. AT&T felt that they should be entitled to some monies for reimbursable elements at the Decommission site. Qwest agreed that a CLEC would be eligible for reimbursement on the re-usable elements for up to one (1) year from the Decommission Application submit date.

The following is the implementation schedule for the revised Cancellation and Decommission procedures: 11/15/01 - CMP Notification 12/01/01 - CLEC Review Period 12/15/01 - Revised Cancellation and Decommission procedures posted on the Collocation PCAT 01/01/02 - Effective date for the revised Cancellation and Decommission procedures

In summary, Qwest believes that we have satisfied your concerns regarding the Decommission and Cancellation procedures and therefore are considering this Change Request closed.

Sincerely,

Steve Nelson Group Collocation Product Manager

Open Product/Process CR 5608142 Detail

Description Of Change

Status History

Project Meetings

Attendees:

Jim Thiessen (Avista), Lorna Dubose (Qwest), Margaret Bumgarner (Qwest), Todd Mead (Qwest), Tom Davis (Qwest), Michael Buck (Qwest)

Qwest presented the draft response to the change request. Jim (Avista) indicated that the change request was intended to correct a problem that occurs once every three or four months. (The problem has not occurred since the CR was issued in early June.) The issue is that if there is problem at the time of the port, Avista would like to have it resolved in less than 24 hours to prevent or reduce the amount of time a customer is left without service. In the past, Avista had been instructed to call the LNP LAB for resolution. When this has happened resolution has taken up to 24 hours.

Margaret (Qwest) indicated that she believes that the repair escalation process has subsequently changed. She believes the process is for the CLEC to call the ISC for issues within 48 hours of the port and that the ISC would make the call to the LNP Lab. Margaret believed that the new process was covered in a notice issued in late May.

Jim (Avista) indicated that if the process Margaret described would satisfy his concern and his intent for writing the CR.

Lorna took a few action items to confirm the process for Avista in a revised response.

Action Items: - Lorna Dubose (Qwest) to confirm process for dealing with LNP Lab (due 9/26) - Lorna Dubose (Qwest) to write revised response (due 9/26)

CenturyLink Response

Mr. Jim Thiessen

Avista Communications

This letter is in response to your CLEC Change Request Form, number 5608142 dated June 13, 2001 – LNP Repair Interval.

Request: Currently, Qwest has a 24-hour commit time for all LNP trouble tickets that are opened. These tickets can be escalated every ½ hour, but all the escalation does is guarantee that the ticket will be worked within 24 hours. Would like to see this reduced to a more reasonable amount of time.

Response: Repair intervals were agreed to at the performance measurement workshops under the auspices of the Regional Oversight Committee (ROC) and the Arizona TAG. MR-11 LNP Trouble Reports cleared within 24 hours was established as a measure of the interval agreed upon. The standard is parity with MR-3C Results for Retail Residence. Qwest will continue to be consistent with these agreements.

Qwest Call Center Agents will review any pending order information for accuracy and establish contact with the appropriate repair center, if necessary. The ISC will issue a work queue ticket and agree to provide regular status to the CLEC at regular intervals until resolution.

Sincerely,

Maureen Callan Group Product Manager

Open Product/Process CR PC101201-2 Detail

Description Of Change

CLEC’s should not be required to place a (C) change order to add USOC’s to the circuit if the order is closed. A verbal authorization from the CLEC or a Qwest Technician should suffice.

This type of conditioning should be performed in a maximum of 3 to 5 business days. These circuits should be considered “Loops Out of Service” and should have the conditioning issues addressed in reduced intervals compared to the current 15 business day provisioning interval that is currently in place.

Conditioning:

- Load Coils

- Bridge Tap (Further definition is required here. Will Qwest remove all bridge tap or excessive bridge tap)

Status History

Project Meetings

2. CLEC’s should not be required to place a (C) change order to add USOC’s to the circuit if the order is closed. A verbal authorization from the CLEC or a Qwest Technician should suffice.

No change order for conditioning during the maintenance process

3. This type of conditioning should be performed in a maximum of 3 to 5 business days. These circuits should be considered “Loops Out of Service” and should have the conditioning issues addressed in reduced intervals compared to the current 15 business day provisioning interval that is currently in place.

Change interval from 15 to 5 days only on maintenance process

Conditioning: - Load Coils - Bridge Tap (Further definition is required here. Will Qwest remove all bridge tap or excessive bridge tap) Not All but maximum to 6kf Confirm Areas & Products Impacted Areas: Ordering, Repair Products: Unbundled Loop, UNE, Loop Confirm Right Personnel Involved Cliff Dinwiddie - Lead Brett Fesler - Assist Nancy Hoag/ Cindy Buckmaster - Assist Ann Danielsen - Assist (Repair) Michael Belt - Coordinate CR Cradle to Grave Identify/Confirm CLEC’s Expectation Expectations of the CR are understood. Identify any Dependent Systems Change Requests N/A Establish Action Plan (Resolution Time Frame) Majority of the request is within “Loop Conditioning Refund Draft” being reviewed by CLEC community. Nancy Hoag transferring to Training, Cindy Buckmaster to Facilitate

Cliff Dinwiddie to formulate DRAFT Qwest Response prior to dry-run meeting November 6, 2001 and present at CMP meeting November 14, 2001.

CenturyLink Response

John Moham TAC Manager, ILEC Repair Covad Communications

CC: Bill Campbell Debra Smith Dennis Pappas Bernadette Derlein Betty Heid

This letter is in response to your CLEC Change Request Form, number PCCR101201-2 dated October 11, 2001 – Maintenance Conditioning.

Qwest’s loop conditioning process is standard across both the unbundled loop family of interconnection products and the shared loop family of interconnection products.

Request:

1. Qwest should redefine and implement a process for conditioning when required by an ILEC Trouble Ticket in its maintenance processes or when a conditioning issue actually exists in the field but not in the Qwest LMU returns. (Accuracy of the Raw Loop Data Tool) i.e. - Loop qual, ADSL/RLD - check loop makeup = 10K no loads. Can’t get signal, have tech test for load and find that it is loaded. This adds 15 days to the interval at commitment date. This is on line sharing and IDSL (ISDN Capable Loop). Qwest Response:

CLECs can use the ADSL Loop Qualification and RLD tools, in addition to other IMA based loop qualification tools, to identify the existence of Load Coils and/or Excessive Bridged Tap prior to placing an order. Qwest will always attempt to assign facilities that do not require conditioning. However, there may be some situations where the only way to fulfill a request requires Qwest to condition the loop. Qwest will not condition a loop without CLEC approval.

To simplify the process, CLECs have the option to pre-approve conditioning by entering a ‘Y’ in the SCA field of the LSR. If this field carries the ‘Y’, all Load Coils and Bridged Tap will be removed, with the exception of stub cable. The pre-approval option provides the following benefit: - If conditioning is required, the LSR will flow through the provisioning process without delay, - If the pre-approval is not included on your LSR and conditioning is required, Qwest will reject your LSR and you will need to submit a new LSR.

Pre-Approval inclusion will not have any negative impacts on your order. Qwest will still attempt to locate facilities that do not require conditioning. CLECs can request the standard interval and if Qwest can assign the loop to facilities that do not require conditioning, the requested interval will be honored. Conditioning charges will only apply if conditioning actually occurs.

Therefore, assuming the CLEC is ordering a non-loaded loop (LX-N – 2/4 wire non-loaded, LXR- - ADSL Capable, AD-- - ISDN Capable, ADU- - xDSL-I Capable):

- If the LSR is submitted with a “Y” in the SCA field, Qwest will attempt to assign a facility free of Load Coils and Bridged Tap. If Load Coils and/or Bridged Tap is present on the facility assigned, Qwest will dispatch to ensure that the circuit will meet the parameters specified by the CLEC in the LSR. - If the LSR is submitted without Conditioning authorized (with an “N” in the SCA field or with the SCA field blank), Qwest will attempt to assign a facility free of Load Coils and excess Bridged Tap. If Load Coils and/or excess Bridged Tap is present on the facility assigned, Qwest will reject the LSR advising the CLEC that conditioning is required and the CLEC will return to the step above. - If the LSR is submitted without Conditioning authorized (with an “N” in the SCA field or with the SCA field blank), Qwest will attempt to assign a facility free of Load Coils and excessive Bridged Tap. If such a facility can be found, it will be assigned and the request will be processed. In this situation, the facility assigned can have Bridged Tap on it that does not exceed the limits identified by the NC/NCI Code specified by the CLEC in the LSR. - If the CLEC requires that additional Bridged Tap be removed (i.e. the CLEC now wants Qwest to condition the loop), that request will come through the Service Delivery Center. The CLEC will need to submit an LSR authorizing Bridged Tap Removal by entering a ‘Y’ in the SCA field. The standard 15 Business Day Conditioning Interval will apply. - If Load Coils and/or excessive Bridged Tap are not identified by Qwest as present on the facility assigned, and the proper NC/NCI code were used to indicate a Non-Loaded facility, Qwest should be able to identify their presence in Test & Turn-Up. If the Test doesn’t indicate the presence of Load Coils and/or excessive Bridged Tap, and the loop is subsequently turned over with Load Coils and/or excessive Bridged Tap on it, Qwest will handle the issue in the repair environment. This process will not require the CLEC to submit a supplemental LSR. This repair process will be completed within 5 Business Days. In this scenario: - If the CLEC originally entered a ‘Y’ in the SCA field of the LSR, Qwest will remove any Load Coils and all Bridged Tap (see question 3 below). - If the CLEC originally entered a ‘N’ in the SCA field of the LSR or left the SCA field blank, Qwest will remove only the Load Coils and excessive Bridged Tap. Bridged Tap that doesn’t interfere with the services specified in the NC/NCI Code combination will not be removed. - No charges will be assessed to the CLEC.

Request:

2. CLEC’s should not be required to place a (C) change order to add USOCs to the circuit if the order is closed. A verbal authorization from the CLEC or a Qwest Technician should suffice.

No change order for conditioning during the maintenance process

Qwest Response:

As stated above, CLECs will not be required to authorize the removal of Load Coils and/or excessive Bridged Tap inadvertently missed by Qwest. CLECs are still required to request conditioning if additional Bridged Tap removal is requested and can do so per the process previously defined.

Request:

3. This type of conditioning should be performed in a maximum of 3 to 5 business days. These circuits should be considered “Loops Out of Service” and should have the conditioning issues addressed in reduced intervals compared to the current 15 business day provisioning interval that is currently in place.

Change interval from 15 to 5 days only on maintenance process

Qwest Response:

As stated above, if the circuit was incorrectly conditioned by Qwest, it will be corrected within 5 business days. If the CLEC would like additional Bridged Tap removed, the standard 15 Business Day Conditioning Interval will apply.

Request:

4. Conditioning: - Load Coils - Bridge Tap (Further definition is required here. Will Qwest remove all bridge tap or excessive bridge tap)

Qwest Response:

If requested by the CLEC (with a ‘Y’ in the SCA field), Qwest will remove all Bridged Tap (except stub cable). If Conditioning was not requested, Qwest will ensure that the circuit meets the acceptable standards of the NC/NCI codes requested and will remove the amount of Bridged Tap necessary to meet those standards.

Request:

5. Additional questions were asked during the clarification session. These questions and answers are provided collectively in this section.

a. Where are the processes documented for the conditioning interval and the maintenance process? - The conditioning interval can be found in the Service Interval Guide. More information regarding the process associated with intervals as they apply to your request can be found in the Product Catalog (PCAT) at: http://www.qwest.com/wholesale/pcat/interconnection.html - Additional information regarding Maintenance processes can also be found in the PCAT at: http://www.qwest.com/wholesale/pcat/interconnection.html

b. How are identified data-base errors corrected? A ‘yellow’ response on the RLD or ADSL Loop Qual Tool does not prohibit the CLEC from ordering the service. Upon receipt of the request, Qwest will attempt to assign an adequate facility. If necessary, a Technician will be dispatched to resolve discrepancies in facility record. Once those discrepancies are resolved, the Qwest Technician is responsible for providing an update to the database. As those discrepancies are resolved, the CLEC request can be completed.

Two tools have been deployed to provide a vehicle for Qwest Technicians to get corrected information back to the data-base.

They are: 4.1 Internet A url has been deployed so that field forces can access the Qwest Web Site. This site is used to update facility data, based on actual measurements. This is an internal url and will be used by Qwest personnel only. 4.2 FAX A form has been developed that allows a technician to note the same information that is input into the Qwest Web Site. The form should be filled out as the readings are being taken. At the end of the day, hand the form(s) to your supervisor. The supervisor, or designee, will fax the forms daily.

This, too, is an internal process only. As the Qwest employee is the only person updating the database, documentation regarding the process is not publicly provided.

Sincerely,

Cindy Buckmaster Group Manager – UBL Product Management

Open Product/Process CR PC101201-1ES Detail

Description Of Change

These test results should be standardized utilizing the CEMR MLT test and 77S test unit utilized by Qwest Central Office Technicians.

These standards should also drive processes to repair existing loops or LST (Line and Station Transfer) working voice but not in service data loops to acceptable loops out of the end users serving terminal. They should also drive process implementation for Qwest Network or Complex Network Service technicians to be dispatched out to address the identified loop quality issues.

Loop Standards on:

Capacitance

Resistance

DC and AC signatures

Voltage

Status History

Project Meetings

CenturyLink Response

John Moham Covad Communications TAC Manager - ILEC Repair Denver COE Line Sharing Data Parameters

CC: Kathleen Lucero Steve Hilleary Deborah Heckart Brett Fesler Mike Lanoue

This letter supercedes Qwest Response dated 12/05/01 that responded to your CLEC Change Request PC101201-1 dated 10/12/01 Shared Loop Data Parameters.

This Change Request asks Qwest to engage in a collaborative effort with CLECs to establish testing provisioning and repair parameters for DSL on shared loops including: - a minimum set of standards; - standardized testing utilizing CEMR MLT and 77S test sets; - a loop repair process that requires a LST if the provisioned loop does not meet CLEC standards; and - a loop repair process that dispatches a Qwest technician if the loop has quality issues. Minimum Testing Parameters

Qwest is disinclined to develop a minimum set of provisioning and repair standards that would “qualify” a particular facility to carry Line Sharing for two reasons: - Difficulty in developing a “standard”. This is accentuated by the varied requirements of the multiple vendors, types of DSL, and quality of service deployed by CLECs. Developing the test parameters for an “acceptable” circuit for all CLECs would be a time and resource consuming activity for all parties and one not prudent to do in light of the following. - The minimum standards for provisioning and repair of a metallic loop are already being developed in an industry forum, American National Standards Institute (ANSI) T1E1.3. In order to prevent duplicative development and implementation efforts, Qwest believes the ANSI forum to be the most appropriate to address this issue. While Qwest denies this request to work independently with the CLECs on a set of minimum standards, Qwest is more than willing to work collaboratively with the CLECs and other industry participants to develop a set of national standards in the appropriate industry forum.

Additionally, Qwest Technical Publication 77406 Interconnection - Shared Loop outlines the minimum set of transmission standards that a facility can support. The transmission characteristics defined in the technical publication provide the CLEC with information regarding the minimum requirements that a facility must support to be delivered to a CLEC based on the Network Channel and Network Channel Interface (NC/NCI) codes that the CLEC includes on the Local Service Request (LSR). CEMR MLT and 77S Test Sets

In the clarification call for this Change Request, Covad indicated it would like to utilize Customer Electronic Maintenance and Repair (CEMR) Metallic Loop Test (MLT) for pre-provisioning xDSL loop qualification. Qwest has already addressed this issue in 271 workshops. CEMR MLT is a repair tool that provides CLEC testers in the repair process the capability to evaluate transmission characteristics of a metallic loop connected to a Qwest switch.

The reasons presented in the workshops for Qwest’s objection to using MLT in a provisioning process are twofold. First, MLT is an intrusive test that will disrupt voice services. While this is not a concern for repair scenarios, it is a real concern when MLT is being triggered electronically through CEMR. Secondly, to ensure the protection of Customer Proprietary Network Information (CPNI), MLT has a front end edit that limits access for a specific loop to the Local Exchange Carrier of record for that loop. In pre-order activity, MLT will not allow CLECs to access metallic loops it does not “own”.

However, in the Pre-Ordering process, Qwest can and does provide facility characteristic information to CLECs based on facility records via the Raw Loop Data Tool (RLDT). The data included in the RLDT is the same underlying data that Qwest utilizes to qualify loops for its retail xDSL product offerings. This data can be used, much the same way Qwest uses it, to qualify loops for CLEC xDSL services.

During the provisioning process to deliver shared loop products to CLECs, Qwest does use test sets, including the 77S, to identify load coils on a loop. Additionally, Qwest tests the electrical continuity of the data path for every shared loop provisioned for CLECs prior to circuit delivery.

Once the shared loop is provisioned for the CLEC, the CLEC can perform a MLT through CEMR.

Loop Repair LSTs

The Change Request indicates, "These standards should also drive processes to repair existing loops or Line and Station Transfer (LST) working voice but not in service data loops to acceptable loops out of the end users serving terminal." Qwest believes that existing repair processes sufficiently care for this concern. Again, Qwest delivers shared loop circuits according to the parameters outlined in Technical Publication 77406. Please review the response to Change Request PC101201-2 regarding loop conditioning during the repair process.

Loop Repair Dispatch

Qwest will dispatch a technician to a network DMARC at a customer premises only if trouble is isolated to the Outside Plant portion of the Qwest network. Qwest will not agree to dispatch its technicians unless the circumstances of a trouble ticket dictate such activity.

Sincerely,

Cliff Dinwiddie Senior Manager Global Wholesale Product Marketing

Open Product/Process CR PC102301-1 Detail

Description Of Change

Status History

Project Meetings

08/21/02 - August CMP Meeting Minutes Qwest (Gianes) indicated that a revised document had been provided, the document is being reviewed by the Network organization. A point of concern has been raised regarding the lack of information regarding the test parameters behind IVR. COVAD (Zulevic) inquired if the agreement was being expanded beyond provisioning? Gianes indicated that in the last session with COVAD (Mindy and John) agreed not to go beyond provisioning at this time. This CR will remain in “Development” status.

07/17/02 - July CMP Meeting Minutes: Qwest (Gianes) provided an update indicating that both COVAD and Qwest were happy with the results of the trial. Qwest would like to roll out the process within the fourteen states. Two regions have been trained so far, but actual implementation is pending legal approval. This process would be not be applicable to repair. This CR will continue with a status of "Development" Revised response will be provided prior to the next meeting.

To: "Berard, John" cc: "Zulevic, Michael" , "Cutcher, Minda" , "Linda Hendricks" , "Deni Toye" , "Mary Pat Cheshier" , "Alan D Braegger" , Michael Raleigh/Mass/USWEST/US@USWEST, "Kurtis L Preston" , "Rick Mabry" , "Diane L Diebel" , Kathleen Thomte/Mass/USWEST/US@USWEST

Subject: Re: IVR Trial with Covad

John, I still have not received the list of service orders from you that you had agreed to send for this trial. This list was to enable both company's to work from the same "database" for tracking purposes and determination of final results. I understand that the list may require updating on a weekly basis due to the service order intervals. That is not a problem. Would you also let me know what has happened regarding providing Qwest the On Time Performance (OTP) report we discussed. It was our impression that this was one of your critical measures of success in previous deployments of the IVR tool to other ILECs. Last week we decided to move forward without the service order list from Covad by asking Mike from the QCCC to pull a 30 day historical and future DD report. This will assist Kurt and Rick in determining which higher volume wire centers to focus on within the geography we discussed as we progress from the limited "dry run" with a few orders to the full scope of the trial. At this point we will use the future service order data we pulled as our baseline going forward to track and determine usage, IVR performance, etc. Also, Alan from the Qwest field staff, has developed a more refined flow chart which we have shared with the field director for use by the technicians. This provides an accurate and more straightforward chart of what the field technicians will experience when using the Covad IVR. I will be glad to share at our next joint status meeting. Please contact me regarding when you will be able to provide the future service order list and the OTP report at your earl

04/25/02 To: "Berard, John" cc: "Cutcher, Minda" , "'tgianes@qwest.com'" , "Zulevic, Michael" , "Deni Toye" , "Alan D Braegger" , lkhendr@qwest.com, Kathleen Thomte/Mass/USWEST/US@USWEST, "Rick Mabry" , "Kurtis L Preston" , "Mary Pat Cheshier" , Michael Raleigh/Mass/USWEST/US@USWEST, "Diane L Diebel"

Subject: Re: QWEST Trial of Covad IVR Loop Test Tool

Everyone, Here is a what I believe we agreed to on todays call: The trial will start Monday April 29th as scheduled. All parties agree that since Covad orders Coordinated Installation with Cooperative Test only, Qwest will utilize the IVR test during the Cooperative Testing portion of the test and turn up. As the field technicians become more comfortable with the IVR tool they have the option of utilizing the IVR at any point during their installation activity as long as it does not jeopardize Qwest meeting the Coordinated Install timeframe. Qwest will begin the trial by having a technician access sample Covad service orders and run through the IVR process. The technician will provide the Qwest team immediate feedback regarding their experience. John will send to Tim a list of pending Covad service orders so both Covad and Qwest will be working from the same list. This is critical in providing accurate results at the end of the trial. John is still pursuing providing an On Time Performance (OTP) report to Qwest since this is where Covad indicates there will be a significant benefit. John agrees a report of this type will be a valuable measure of success at the end of the trial. Minda confirmed that Qwest is the only ILEC with whom Covad orders Coordinated Installs. Based on the nature of Coordinated Install orders, Qwest performs extensive workstep completion confirmation prior to a field tech being dispatched to the premise. Minda agrees that because Qwest applies a very structured approach to Coordinated Installs this may minimize the extent of the benefit to Qwest that other ILECs have experienced with the IVR. Everyone also agrees that Qwest will continue to perform and document their required Core tests and follow established Coordinated testing agreements as they do today. Utilizing the IVR does not negate any current processes. Minda also agrees that if Qwest experiences a Fail situation via the IVR but successfully has passed standard Qwest core tests in the same area, Qwest will not default to the Covad test result but will contact Covad and work through the variance on a case by case basis as they do today. Tim will update the Trial Document to specify that Qwest will only enter the numeric portion of the PON number when accessing the IVR tool. Tim will schedule a follow up with the QCCC and the field to confirm the tracking spreadsheet detail Qwest will utilize to provide trial results on the orders submitted by Covad. Tim will schedule a joint meeting with Covad within the first 2 weeks of the trial to discuss progress and address concerns and opportunities.

I have tried to capture our conversation acccurately and completely and ask that you send me any corrections to what I have stated by end of day tomorrow. If there are no corrections or after making corrections I will ask that Kit Thomte incorporate these notes into our ongoing tracking of the original CR.

Tim Gianes 303 703-2199 03/22/02 - E-mail from Covad asking to begin trial without providing test parameters associated with IVR capability to Qwest

From: "Michael Zulevic" To: "Todd Meade" , "Michael Keegan" Cc: "Berard, John" Subject: IVR documentation Date: Fri, 22 Mar 2002 11:16:38 -0700

Todd,

Per our discussion yesterday, Covad does not see the need to provide our test perameters associated with our IVR capability to Qwest. Covad considers this to be proprietary information. As I stated yesterday, I would be willing to certify that our test perameters are within the technical specifications of your UNE loop offering. Once again, the IVR capability is in use in Verizon and the capability is now being deployed in SBC. BellSouth is also working with us to deploy the capability there as well. Covad has not been "required" to provide technical documentation to any of these ILECs as a condition of use. It must be understood that the IVR is a test capability, developed for use by Covad, that we are agreeing to allow Qwest and other ILECs to use, to assist them in their provisioning process. If, after a joint trial is completed, Qwest determines they have no need for this test capability, there is no obligation to continue with it's use. I would like to begin the trial as soon as possible, as trials with other ILECs have resulted in a significant improvement in the delivery of UNE loops. Please let me know if this informaion is sufficient to start the trial, and when we can get it started.

Thanks,

Michael Zulevic Director- External Affairs Office(520)575-2776 Cel(303)884-5657 Fax (520)575-2785

02/27/02 - Status report from Qwest posted in CMP database

Subject: Covad IVR Meeting 2/27/02 Date: Wed, 27 Feb 2002 16:12:46 -0700 From: "Tim Gianes" To: Todd Mead CC: "Frederick M Aesquivel Iii" Todd, I participated on a call today with Michael Zulevic and John Berard with Covad. John was involved in the deployment of the Covad IVR to Verizon. We discussed the 2 pending requests which were: - Utilization of the Covad circuit ID instead of the PON to activate the IVR - Full disclosure of specific tests activated (by circuit type) within the IVR and the related test parameters set for each Pass/Fail decision

John felt he could locate the IVR development document which should contain this information and send me a copy. Michael questioned the need for Qwest to have this data. I explained that this would allow us to insure that Covad & Qwest agree on the standard tests and test parameters utilized by the IVR before requiring field technicians to accept the Pass/Fail status from the IVR. It will be very beneficial to the field and center technicians to understand what the IVR is running, not just the net result, so they can better determine what action to take. Having the test detail will also promote buy-in from the field to actively use the IVR tool if they see the potential value of the test results.

I have agreed that Qwest will utilize the PON# which is present on the Worddoc. Micheal stated that the PON numbers were unique and would not cause Qwest to inadvertently intrude on another Covad circuit in error. Since Covad currently does not always provide their circuit ID on the LSR, requiring this would create an unnecessary step for Covad. Despite Qwest's preference to use the Covad circuit ID there is no compelling system or process related reason to not use the PON# as preferred by Covad. If using the PON becomes a problem, the process will have to be amended to revert to the circuit ID.

I am awaiting delivery of the detailed IVR document from Covad. Upon receipt, review, and agreement on tests & test parameters we will set a definite trial start date. Regarding the trial, I confirmed with Michael that Denver metro was the agreed location and 60 days the agreed trial duration. I also mentioned, and they concurred, that at the end of the trial we would gather performance results data as defined in my original response to the CR and determine future action.

Tim Gianes 303 703-2199

02/22/02 Return E-mail from Covad

Subject: RE: CR Interactive Report Date: Fri, 22 Feb 2002 20:02:53 -0700 From: "Michael Zulevic" To: "Todd Mead" CC: "Gianes, Timothy" Todd, I am looking for answers to your questions and sent an email to Tim earlier today asking about your availability for a clarification call this Weds. with one of our people who facilitated the implementation in Verizon. Hopefully, we can get this back on track real soon. Thanks, Michael Zulevic Director- External Affairs Office(520)575-2776 Cel(303)884-5657 Fax (520)575-2785

02/22/02 Information E-mail from Qwest to new Covad CR owner

From: Todd Mead [mailto:tmead@qwest.com] Sent: Friday, February 22, 2002 12:02 PM To: mzulevic@Covad.COM Cc: Gianes, Timothy Subject: CR Interactive Report Mike, As promised, here is the link to our interactive report where you can see the latest on your CR(s). This report is updated every 2 days. http://qwest.com/wholesale/cmp/changerequest.html (click on the Product/Process link) As regards to PC102301-1 IVR Testing Tool, there are two outstanding issues. Qwest is waiting for Covad to supply a response to these issues before we move on with the trial. The issues are: - Please provide the test detail behind each of the IVR options by product and respond in particular to the discrepancy on the loop length issue. - Would Covad be able to provide their circuit ID on every order so we could use that rather than the PON? You may already provide the circuit ID already but wanted verification it is standard procedure to include it on all ISRs. After your meeting with Mindy, please let me know if you want me to set something up with Qwest personnel. Thanks Todd

02/13/02 E-mail response, Qwest waiting for new Covad contact to move forward with trial.

From: Tim Gianes 02/13/2002 03:18 PM To: "Cutcher, Minda" Subject: RE: IVR Trial Status (Document link: Tim Gianes) Thanks for the heads up Mindy. I hope you are moving into something else you will be enjoying, Thanks for helping and providing the information you have. I will await the decision fom Covad on who our contact will be and will look for the requested data from that person going forward. Good luck! Tim Gianes 303 703-2199

02/13/02 E-mail from Covad advising change of personnel

From: "Cutcher, Minda" on 02/13/2002 12:52:26 PM To: Tim Gianes Subject: RE: IVR Trial Status Tim, As a result of some internal reorgs at Covad, someone else is going to be driving this forward with you. It will likely be Mike Zulevik, but I will keep you posted. It will take us a few weeks to transition. Mindy

02/07/02 Qwest response e-mail to Covad

Subject: RE: IVR Trial Status From: Tim Gianes 02/07/2002 09:16 AM To: "Cutcher, Minda" cc: Todd S Mead , Michael Keegan , Deni Toye , Terrance L Meehan , Linda Hendricks Subject: RE: IVR Trial Status (Document link: Todd S Mead) Mindy, I was expecting you to be able to provide the test detail behind each of the IVR options by product and respond in particular to the descrepancy on the loop length issue I mentioned. Also, would Covad be able to provide their circuit ID on every order so we could use that rather than the PON? You may already provide the circuit ID already but wanted verification it is standard procedure to include it on all ISRs. Thanks. Tim Gianes 303 703-2199

02/06/02 Reply e-mail from Covad

Subject: RE: IVR Trial Status From: Cutcher, Minda" on 02/06/2002 05:29:48 PM To: Tim Gianes , Todd S Mead , Michael Keegan cc: Deni Toye , Terrance L Meehan , Linda Hendricks Subject: RE: IVR Trial Status Tim, Help me out here. Are you looking for me to give you some more info or are you chasing the info? Mindy

01/29/02 E-mail from Qwest poviding update to Covad

Subject: IVR Trial Status Date:01/29/2002 04:02 PM From: tgianes@qwest.com To: mcutcher@covad.com, Todd S Mead/Mass/USWEST/US@USWEST, "Michael Keegan" cc: "Deni Toye" , "Terrance L Meehan" , Linda Hendricks/COMPLEX/USWEST/US@USWEST Mindy, Todd and Mike, Here is an update after the meeting I had with the Qwest Unbundled Services Process team. They expressed a couple of concerns that I believe can be resolved without much delay. As soon as we close on these issues we should be able to start a trial. First: They are strongly recommending that we use the Covad circuit ID instead of the PON number. We would have to insure that the circuit ID is posted to the LSR up front by Covad. This circuit number should appear on the Worddoc that the field techs work from. Second: They have requested a detailed description of the specific tests (with acceptance parameters) that are run at each option of the IVR and for each service type. I did receive a document titled Covad Loop Test Logic which seems to describe some of Covad's test acceptance parameters. Within that document for instance under Loop Length it shows that 15K is the acceptable parameter for ADSL. If this is built into the IVR parameters we would fail the test when in fact I don't believe these circuits have this requirement. For those that do have a length restriction it is 18K not 15K. We all agreed that long term there is the potential for incremental time savings, depending to a large degree on the detail provided by the IVR. Hence the desire to still pursue the trial. I will complete the trial document when I have these last 2 elements. The test parameters by option will be included in the trial documentation that I will distribute to the field. Please call with any questions/clarifications. It may be beneficial to have a quick call with the IVR SME to quickly work through the test options issue. Tim Gianes 303 703-2199

01/11/02 E-mail from Qwest responding to Covad

Subject: Re: Status at Last Date: Fri, 11 Jan 2002 09:02:58 -0700 From: "Tim Gianes" To: "Cutcher, Minda" CC: tmead@qwest.com, tgianes@qwest.com Mindy & Todd, My responses are in red after the question. "Cutcher, Minda" on 01/09/2002 08:44:26 PM To: tmead@qwest.com, tgianes@qwest.com Subject: Status at Last Todd and Tim, At last, here's my status on Action Items: 6.1 complete 6.2 the answer is yes to all (with the exception of the request on "fail to access") however, I think Covad could provide some generic data on system up time, which would drive to the same info (yes?). =Generic up time data would be helpful.= However, the catch is that to collect all this data requires a programming request, which could take between 2-4 weeks, depending on workload in our IT group. On the I-Report stuff, my understanding is that Covad will provide Qwest with a list of all orders that used IVR, then Qwest would run the I-Report analysis. Please confirm. =This is correct. Will need Qwest order numbers and related repair ticket numbers as well. Based on agreed definition of "I" report........submitting a repair ticket within 30 days of the service order DD.= 6.3 complete 6.6 sounds like Tim and I have more work to do on this. Let me know when would be a good time to discuss further. =Todd, could you schedule a 30 minute meeting? Looks like late (after 4 pm) on the 16th or 18th, or anytime on the 21st would be ok at this time.= If you have any questions, etc. let me know. Otherwise, let's talk about next steps to implementation. Mindy 253-323-2481 (efax) 781-649-0703 (p) 978-869-7376 (m)

01/10/02 E-mail update from Covad on Kick-off meeting actions

Subject: Status at Last Date: Wed, 9 Jan 2002 19:44:26 -0800 From: "Cutcher, Minda" To: tmead@qwest.com, tgianes@qwest.com Todd and Tim, At last, here's my status on Action Items: 6.1 complete 6.2 the answer is yes to all (with the exception of the request on "fail to access") however, I think Covad could provide some generic data on system up time, which would drive to the same info (yes?). However, the catch is that to collect all this data requires a programming request, which could take between 2-4 weeks, depending on workload in our IT group. On the I-Report stuff, my understanding is that Covad will provide Qwest with a list of all orders that used IVR, then Qwest would run the I-Report analysis. Please confirm. 6.3 complete 6.6 sounds like Tim and I have more work to do on this. Let me know when would be a good time to discuss further. If you have any questions, etc. let me know. Otherwise, let's talk about next steps to implementation. Mindy 253-323-2481 (efax) 781-649-0703 (p) 978-869-7376 (m)

01/04/02 Meeting minutes for Kick-off meeting

11:00 a.m. (MDT) / Thursday 3rd January 2002

Attendees: Todd Mead / Qwest Tim Gianes / Qwest Mindy Cutcher / Covad

Purpose of the meeting was to develop the framework for the IVR trial scheduled to begin on the 28th January 2002 and lasting for approximately 2 months.

Identify/Answer CLEC/Qwest Questions About Trial : Location of trial – Denver Metro area. Tim will verify with local field director Duration of trial will be approximately 2 months During the trial, all existing loop tests will continue as before. Qwest technicians will still provide continuity tests to Covad as requested and Qwest center technicians will continue to provide Covad required circuit turn-up test results.

Establish Action Plan (Resolution Time Frame): 6.1 Mindy will provide Tim a password for IVR by Monday (01/07/02) / Mindy 1/7/02 6.2 Mindy will provide details on reporting capability of IVR. Specifically: - Number of times Qwest accesses the Covad IVR - Number of times Qwest attempts to access IVR but fails (new request) - Number of circuits tested by Qwest via the IVR - Number of circuits that Passed the required IVR tests - Monthly summary of failed tests by state - Identify all circuits tested via the IVR by Qwest to run batch report for “I” Reports 6.3 Mindy needs to confirm what type of circuit the IVR testing tool should be used for. / Mindy 1/7/02 6.4 Todd to forward the ppt and pdf file attached to original CR onto Tim. / Todd 1/3/02 6.5 Tim will produce a trial document outlining the trial purpose, what will be measured during the trial and the expected outcomes. / Tim 1/14/02 6.6 Ideally, this trial should capture the number of times the IVR test generated a ‘pass’ but Covad found a problem with the circuit. Both Qwest and Covad will explore options for collecting this data. / Tim/Mindy 1/14/02

12/05/01 Answers to additional clarification questions, received from Covad:

Answers to the questions are embedded below. Keep in mind that we offer this to the ILECs as an additional testing tool for their use and have not had the opportunity to do any rigorous data gathering and analysis. That might be something we can build in to the trial if Qwest decides to go forward.

- What is the availability time of the IVR? I have assumed 24x7 but have there been unscheduled downtimes over the past 6 months and if so how many and for how long? The system is designed to be on 24X7. It is the same system Covad field techs and Agents use to test orders.

- What are the specific circuit types that are included in their process with Verizon? LX--? etc. It can be used to test any UNE loop... just not line share.

- Has COVAD tracked the success rate for accessing the IVR and completing the tests? If so what is the rate? No data on this.

- Is part of the agreement that if the tests come back positive, COVAD technicians will accept the test results without question and complete the order? No this is just to be used as a tool for the ILEC Tech at this time. It is not a replacement for test and accept.

- Has COVAD measured the actual usage of the IVR tool by Verizon.....what % of the orders that qualify are tested by Verizon utilizing the IVR? It has only been used as a interim test tool not for test and accept so no data on this.

- What % of the orders tested by the IVR and accepted by COVAD have had an "I" report (repair ticket within 30 days of turnup)? No data on this.

- What are the specific test parameters utilized by the IVR for each test run? It is the same parameters that are used by our agents when they test the loop for test and accept.

10:00 am (MDT) / Thursday, November 01, 2001

Clarification Meeting Conference Call 1-877-847-0338 PC7826706 # PC102301-1- IVR Testing

Minda Cutcher, mcutcher@covad.com , Covad Fred Aesquivel III, faesqui@qwest.com, Qwest Michael Belt, mbelt@qwest.com, Qwest

Introduction of Attendees Introduction, Fred, Mike, Minda / T. Meehan and T. Gianes left call per Fred’s request.

Review Requested (Description of) Change Implementation of Covad’s IVR Testing Tool by Qwest for use in the field provisioning and repair process. The Request was reviewed and fully understood.

Confirm Areas & Products Impacted Areas: Field Provisioning and Repair Products: Unbundled Loop/ Stand Alone Loops

Confirm Right Personnel Involved Fred Aesquivel will coordinate SME’s for review and response Michael Belt – Coordinate CR

Identify/Confirm CLEC’s Expectation Covad would like to implement IVR testing with Qwest. The Integrated Voice Response (IVR) unit is an automated, menu-driven tool allowing technicians to run loop tests, loop diagnostics, perform open, short, and quiet tests, and send a tone across the ILEC loop without calling for assistance. IVR is an automated voice response (dial-in) system by which Qwest technicians can perform a one way “pre-test” of a loop prior to formal cooperative (two way) acceptance testing with Covad. IVR takes the Qwest tech through the same process as the two-way test and will feed back results to the Qwest tech. If the loop tests "good", the Qwest tech would then perform the coop test and loop turnover with Covad. If a fault were discovered during the IVR test, the Qwest tech would then have the opportunity to correct the deficiency prior to turnover to Covad. This process has been implemented in another ILEC and Verizon specifically asked for its use to improve their provisioning efficiency as part of its recent recovery efforts in NYC. Eventually, the goal will be to eliminate the need for cooperative testing, saving both Covad and Qwest time and resources, improving operational efficiencies for both.

Identify any Dependent Systems Change Requests N/A

Establish Action Plan (Resolution Time Frame) Fred Aesquivel III to coordinate with Verizon on previous IVR testing from trial done in April/May in Massachusetts regarding loop turnover with Bell Atlantic.

CenturyLink Response

September 5, 2002

Michael Zulevic Covad

SUBJECT: Qwest’s Revised Change Request Response - CR #PC102301-1 Implementation of Covad’s IVR Testing Tool by Qwest

This is in response to Covad’s Change Request (CR) PC102301-1. This CR requests that Qwest implement Covad’s IVR Testing Tool for use in the field for Unbundled Loop provisioning and repair to warrant Qwest’s Technical Publications parameters. Qwest utilizes its own test tools for Unbundled Loop provisioning and repair. The use of Covad’s IVR tool requires adding an additional and redundant step to the Unbundled Loop provisioning process and Unbundled Loop repair process.

Utilization of Covad’s IVR tool obligates Qwest to stand ready to evaluate and accept any request from other CLECs to trial their respective test platforms into Qwest’s processes in a nondiscriminatory manner. Additionally regulatory requirements prohibit Qwest from providing different levels of service to CLECs. Utilization of a CLEC provided provisioning and repair tool or process may benefit some CLECs over others by creating disparate service levels.

Since acceptance of this request from Covad would open Qwest to accepting similar requests from all CLECs, Qwest has determined that utilization of the Covad IVR testing tool would be cost prohibitive to implement. Qwest would incur additional and unrecoverable costs related to turning up and completing service orders and/or repair tickets. * Cost estimates are based on order volumes (300,000) across the 14 states for a minimum of 300 existing CLECs who could each make similar requests of Qwest and which Qwest may have to honor for parity purposes. * Qwest would incur additional costs related to initial & required ongoing employee training for any testing tool that could be provided by the CLECs. Depending on the service types included, provisioning and/or repair application, and the complexity of the tool, employee-training costs or initial deployment could run $100,000 per request or potentially $30M if all CLECs made similar requests of Qwest. Considering the increasing complexity of providing comprehensive training to manage multiple CLEC test vehicles, ongoing and refresher training costs would be substantial. * Qwest already performs and documents internal tests based on ANSI standards. Utilizing test tools from CLECs would not only duplicate those tests but would require Qwest to spend a minimum of an additional 3-5 minutes per order at a cost of $690,000 - $1,150,000 per year based on regional order volumes. *Qwest would also incur additional costs related to required operational trials, process documentation and revisions, and the complexity of managing numerous process requirements for multiple tools. This is not measurable at this point due to the unknown nature of each potential request, but is recognized as a valid concern and real cost to Qwest.

The requested change does not result in a reasonably demonstrable business benefit to Qwest or Covad. In fact performance data during the trial does not support that service levels improved for Covad. Utilizing multiple test platforms requires Qwest to create multiple processes, requiring the Qwest Network Technician to determine which process/platform to use for which CLEC. This creates potential for human error, potentially degrading service quality and performance results.

As stated above, adapting the IVR tool into Qwest’s processes creates legal, economic and service quality performance liabilities for Qwest. Qwest respectfully declines to implement Covad’s IVR tool into its Network processes.

Sincerely,

Tim Gianes Senior Project Manager

cc: Paul Kirchhoffer, Diane Diebel, Mary Retka, Barry Orrel

12-03-2001

Minda Cutcher VP ILEC Relations Covad

CC: Fred Aesquivel Douglas Lange Todd Mead

This letter is in response to your CLEC Change Request Form, PC102301-1 dated 10/23/01 entitled “Implementation of Covad’s (IVR) Testing Tool”.

After having reviewed your request I was also able to interview John Reed with Verizon, a current user of the Covad IVR testing tool. Unfortunately John was unable to provide documented data regarding several critical measures. However, he was very positive in his feedback as a whole and felt that the tool has provided improved efficiencies when completing service orders with Covad.

Thank you for agreeing to respond to these and other questions I have recently submitted to you. The answers will greatly assist us as we move forward. - Percent of usage of the IVR tool for qualified orders? - Specific test parameters of the tool for each test? - Specific circuit types included in the process? - Have there been system access issues…..if so how often etc? - Rate of “I” reports (repair tickets within 30 Days) on IVR tested orders?

Based on some positive feedback from Verizon, the fact that there is no cost to Qwest, and the apparent benefit to all parties of utilizing the IVR tool, I am recommending that Qwest move forward by conducting a trial. The purpose of the trial would be to develop a documented process and to help Qwest & Covad establish data validating the usage and gained efficiencies of the IVR tool. The trial would be conducted in a metro area agreeable to both parties for a minimum period of 2 months beginning no later than January 28th, 2002. The results of the trial and answers to the above questions will determine further action regarding this initial Change Request. If Qwest ultimately decides to accept the new process, it will be with the understanding that Covad, and any other CLEC requesting this process, must provide the IVR, test vehicle, and process and usage documentation at no cost to Qwest.

Sincerely,

Timothy Gianes Senior Project Manager - Qwest Communications

Open Product/Process CR PC102901-1 Detail

Description Of Change

Status History

Project Meetings

Subject: Qwest Winbacks - Loss Report Date: Tue, 09 Apr 2002 15:09:36 -0600 From: "Todd Mead" Organization: Qwest Communications International, Inc. To: Bonnie Johnson CC: Kathleen Stichter

Bonnie, Thanks for the update on this issue. Qwest continues to monitor and investigate the daily spreadsheet you send to Dee. Thus far, Qwest has discovered two examples from your spreadsheets where the PON field was left blank on Qwest Winbacks. However, both of these orders were processed on 3/14 (the edit was implemented 3/16). If these early orders are not touched between the issue date and completion date and were submitted prior to the 3/16 edit, then the PON field will remain blank. However, for any orders submitted after 3/16 you should not see the PON field blank for Winbacks. Please continue to monitor and forward any examples to Qwest.

Thanks

Todd

04/01/02 - Reply e-mail from Eschelon - they continue to send daily reports to Qwest with missing PONs

Subject: RE: CR Update Date: Mon, 1 Apr 2002 10:20:31 -0600 From: "Johnson, Bonnie J." To: Todd Mead , "Stichter, Kathleen L."

Todd, See below!

--Original Message-- From: Todd Mead [SMTP:tmead@qwest.com] Sent: Monday, April 01, 2002 9:46 AM To: Stichter, Kathleen Cc: Johnson, Bonnie Subject: CR Update

Kathy, I am looking for some feedback on two of your CRs that are currently in CLEC Test:

PC102901-1 "Qwest to include PON on Qwest Winback Orders" Hopefully you are now seeing the Loss reports with the PON field populated for winback orders? Check with Dee Lucket at Qwest. We continue to send "missing PON's" to her on a daily basis. Dee would be able to give you the compliance rate as she identifies which "missing PON's" are Qwest winbacks.

02/21/02 Notification issued to CLECs with announcement of PON field enhancements on Loss & Completion report

Announcement Date: February 21, 2002 Effective Date: March 16, 2002 Document Number: SYST.02.21.02.F.02589.PONFldLs-CmplRpt Notification Category: System Target Audience: CLECs, Resellers Subject: PON Field for Loss & Completion Report (Winback and Record Orders)

This notification is to advise Loss & Completion report users that, effective March 16, 2002, two enhancements to the Loss & Completion reports will be implemented:

- For Qwest ‘Winback’ orders, the Loss and Completions report will display “000015137896” as the PON. - For Qwest ‘Record’ orders, the Completions report will display “RECCOR” as the PON.

If you have any questions, please feel free to contact me at 303-896-2680.

Curt Anderson 271 IT PMO

Wednesday, 5th December, 2001 / 12:00 p.m. (MST)

Second clarification call

Attendees: Kathy Stichter / Eschelon Bonnie Johnson / Eschelon Anne Robberson / Qwest Donna Svendgaard / Qwest Todd Mead / Qwest

Identify/Confirm CLEC’s Expectation - Eschelon do not want to see any orders on the completion report without an accompanying PON - Eschelon do not require the use of the word “Win Back” on the completion report if this creates parity issues with Qwest Retail. Who the customer goes to is not important to Eschelon, confirmation that Eschelon should stop billing the customer is the issue here. - With the implementation of a suitable process, Qwest and Eschelon can stop the current process of sending and investigating daily spreadsheets of completion orders with no PONs.

Establish Action Plan Anne will set up a meeting with Resale before next CMP meeting (12/12/01) Anne will report progress at December CMP meeting A draft response will be posted to the web and presented at January’s CMP meeting

Friday, 2nd November, 2001 Clarification Meeting Conference Call 1-877-847-0338 PC7826706 # PC102901-1 Qwest to include PON on Qwest winback orders.

Meeting Minutes of Eschelon Meeting 11/2/2001

Attendees: Kathy Stichter, Eschelon Bonnie Johnson, Eschelon Mark Routh, Qwest CMP Manager Peggy Esquibel-Reed, Qwest CMP Todd Mead, Qwest CMP Mike Belt, Qwest CMP Mark Coyne, Qwest Wholesale Process Anne Robberson, Qwest Wholesale Process Nancy Walker, Qwest Wholesale Systems Barbara Campbell, Qwest Wholesale Systems Curt Anderson, Qwest Wholesale Systems

The above attendees met on Friday, 11/2/2001 to review the research findings for the data issues that Eschelon had identified on their Loss and Completions reports. The research findings and resulting Qwest actions are documented in a document titled “Eschelon Research Summary”. The details of the data researched are documented in a document titled “Eschelon Research Details”. In addition to the Qwest actions identified in the “Eschelon Research Summary”, the following action items were identified in the meeting:

Anne will complete the Issue Reference column on the Eschelon Research Details document and return the document to Nancy. Nancy will forward it on to Peggy for distribution to Eschelon. Mark Coyne will define and implement a process for identifying the Qwest winback orders on the list of orders with missing PONs that Eschelon delivers to Qwest daily. Nancy will contact Alan Zimmerman to discuss Eschelon’s use of the Loss and Completions Report. It appears that Eschelon is using the report to identify when a line was lost for the purpose of discontinuing account billing. This may not be an appropriate use of this report. Anne will research the “C” orders with TIC charges that appear on one of Eschelon’s daily missing PONs list and will determine whether or not these orders were written correctly. Anne will research the orders that were identified as missing the TRAK DCR RS on the Eschelon Research Details document and will determine what process failures caused the omission. The following URs and CRs were discussed as a result of this research. Curt will track the processing of these requests to provide status updates to his management prior to the next CMP meeting. 1. Missing or Inaccurate PON on Completion Report:

The Missing PON spreadsheet sent on 10/2 had 248 detail lines which reflected 118 orders with missing or inaccurate PONS. For these orders, the Completion Report correctly included the service order information that was present in the SOP. The SOP either did not have PONs for these orders or had the inaccurate PONs at the time the orders completed. The causes for the missing or inaccurate PONs were traced to the following seven order writing scenarios:

Of the 118 orders: A. 58 are Qwest Retail “winback” orders. These orders were initiated by Qwest Retail and do not include PONs. These orders appear on the Loss and Completions Reports for the CLEC that is losing the service to notify them of the impact to their business. Qwest Actions: - Anne will talk with the retail service center that processes “winback” orders to gather information about their process and will determine if their process can be changed to require entry of a PON. Eschelon has submitted CR #PC102901-1 requesting this process change. - Anne will talk with the process specialist for Loss and Completions Reporting to request that existing procedures and CLEC training be updated to include information about Qwest Retail “winback” orders appearing with no PON on Loss and Completions Reports.

B. 14 are orders that were initiated by Qwest Wholesale to record Trouble Isolation Charges that resulted from a repair call that was placed by Eschelon or by their end-user. It is Qwest’s policy to bill a Trouble Isolation Charge when a Qwest technician finds the problem to be on the end-user’s premise. Qwest Wholesale initiates orders to record these charges and stores the Account Number in the PON field since the SOPs require PON and no PON is available. These orders appear on the Completions Reports for the CLEC that “owns” the service to notify them of the impact to their business. Qwest Actions: - Anne will talk with the process specialist for CLEC Trouble Reporting to gather information about their process for recording Trouble Isolation Charges and will determine if their process can be changed to enter “TIC” as the PON. If this change is feasible and if all CLECs agree to it, Anne will create a UR to initiate a system change in the system that generates these orders. - Anne will talk with the process specialist for CLEC Trouble Reporting to request that existing procedures and CLEC training be updated to include information about orders initiated by Qwest to record Trouble Isolation Charges. - Anne will talk with the process specialist for Loss and Completions Reporting to request that existing procedures and CLEC training be updated to include information about Qwest orders for Trouble Isolation Charges appearing with an Account Number as the PON on Completions Reports.

C. 3 are “F” orders without PONs. “F” orders are one component of a transfer order. Transfer orders are comprised of a “T” order (identifying the transfer to information) and an “F” order (identifying the transfer from information). These transfer orders were submitted by Eschelon and processed by the Flow through processor which stores the PON on the “T” order but not on the “F” order. Qwest Actions: - Anne wrote a UR to initiate a system change in the Flow through processor to record the PON on the “F” order.

D. 17 are orders that were submitted by Eschelon and manually entered without PONs into the Western region SOP by Qwest Service Delivery Coordinators. The SOPs in the Eastern and Central regions include an edit to require PON on wholesale orders (RCID or ZCID is present) with inward activity. The Western region SOP does not include this edit. Since the SOP did not require PON, Service Delivery Coordinators incorrectly omitted the PON when entering these orders into the SOP. Qwest Actions: - Anne wrote a UR to initiate a system change to include an edit to require PON on wholesale orders with inward activity in the Western region SOP.

E. 13 are orders that were submitted by Eschelon and manually entered with inaccurate PONs into the Eastern and Central region SOPs by Qwest Service Delivery Coordinators. The SOPs in the Eastern and Central regions include an edit to require PON on wholesale orders (RCID or ZCID is present) with inward activity. Service Delivery Coordinators incorrectly entered an inaccurate value for the PON when entering these orders into the SOP. Qwest Actions: -On 9/21/01 Qwest distributed internally an MCC to re-emphasize the importance of the PON entered on the service order matching the PON on the LSR. The topic heading of the MCC was “Order Writing” and the heading stated “It is extremely important that the PON information entered on the service order matches the PON on the LSR.” This action was taken as result of research performed by Qwest in response to a separate CLEC inquiry relating to inaccurate PONs on Loss and Completions Reports. -Anne will notify the team leaders in the wholesale service centers that there are occurrences of inaccurate PONs on service orders and will request that they ensure that their teams are entering PONs correctly.

F. 12 are record orders that were initiated by Qwest Wholesale and do not include PONs. Record orders may be initiated by a CLEC or by Qwest Wholesale to correct system records. The SOPs do not require PON on record orders. Qwest Actions: -Anne will talk with the process specialist for record orders to gather information about their process for generating record orders and will determine if their process can be changed to enter “RECCOR” as the PON. If this change is feasible and if all CLECs agree to it, Anne will issue an MCC internally to implement the process change. -Anne will talk with the process specialist for Loss and Completions Reporting to request that existing procedures and CLEC training be updated to include information about record orders appearing with no PON on Completions Reports.

G. 2 are disconnect orders submitted by Eschelon and do not include PONs. The SOPs do not require PON on disconnect orders. Qwest Actions: -Anne will write a UR to initiate a system change to include an edit to require PON on wholesale disconnect orders in all regional SOPs. -Anne will talk with the process specialist for Loss and Completions Reporting to request that existing procedures and CLEC training be updated to include information about disconnect orders appearing with no PON on Completions Reports.

Attachment: The spreadsheet titled “Qwest Research on Orders with Missing PONs” cross references the 118 orders included on Eschelon’s spreadsheet of orders with missing PONs to the order writing scenario detailed above that resulted in the missing or inaccurate PON data on the Loss and Completions Reports.

CenturyLink Response

Kathy Stichter ILEC Relations Manager Eschelon Telecom, Inc.

CC: Mark Coyne Sue Burson Carolyn Brown John Gallegos Connie Winston

This letter is in response to your CLEC Change Request Form, number PC102901-1 dated 10/29/01 Qwest to include PON on Qwest Winback Orders.

REQUEST: Currently, when Qwest wins-back a customer from Eschelon and an order is issued on an Eschelon account Qwest does not enter a PON. When Qwest does not enter a PON on an order then the Loss and Completion Report does not include a PON. Eschelon asks Qwest to develop, document, distribute and train an adhered to process to use a PON on all orders issued on Eschelon accounts.

RESPONSE: Qwest understands the difficulty the CLECs currently face when no PON is entered on the Loss & Completion Report for Qwest win-backs. To resolve this situation Qwest has initiated a systems related project that will ensure the PON field on the Loss & Completion Report is populated for Qwest win-backs.

Qwest has completed a systems change request on the behalf of Eschelon and resources have been assigned. The target implementation date for this project is in the second quarter, 2002. Qwest will provide a commitment date for implementation at the February CMP meeting.

Sincerely,

Anne Robberson Senior Process Analyst

Curt Anderson Project Manager

Open Product/Process CR 5579345 Detail

Description Of Change

Modifications

08/22/01 - Added Systems Action Item 314, Get a copy of the process in the AMSC

08/22/01 - Added Systems Action Item 315, Set up an internal meeting to discuss the AMSC process throughout Qwest

08/22/01 - Added Systems Action Item 271, Determine why the CLEC's call in a trouble ticket on the first TN and then have to fax in trouble tickets for any other

08/22/01- Added Systems Action Item 323, check into how the retail business handles trouble with more than three lines.

Status History

Project Meetings

Stichter, Kathleen L. on 09/05/2001 02:11:31 PM

To: lsteckl@qwest.com, mrossi@qwest.com cc: "Powers, F. Lynne" , "Clauson, Karen L." , "Walberg, Loren"

Subject: FW: CR#5579345 - Repair Process for multiple lines on single report

Lynn, The response is confusing. I need clarification. My major concern is design services which equates to unbundled loop for Eschelon. Does this response say: For Unbundled Loop Services, one trouble ticket will be issued for each separate case of trouble. Qwest inputs one case of trouble then gives that ticket number to the CLEC. The CLEC then faxes the additional cases of trouble to Qwest. The ticket number from the first case of trouble must be on the fax to be used as a cross-reference on all other cases of trouble. or For Non-Designed, Designed and Retail Services, multiple trouble reports will be accepted on a single repair ticket if all three (3) of the following criteria are met: 1. Same, exact trouble on each line, i.e. static on TN 333-333-3333, 333-333-3334 and 333-333-3335. 2. Same end user location 3. Same customer name for end user

There is a restriction on Designed Service trouble reports of five (5) cases of trouble per single repair ticket. No restrictions exist for Non-Designed Services. Please let me know. Either way the response does not meet our needs. What Eschelon is looking for is to report as many circuits (unbundled loops) for the same customer at the same address with one call. Qwest can issue as many tickets as it needs to issue but Eschelon should not have to fax additional circuits to Qwest when a customer has multiple circuits in trouble. I find it hard to believe that a Retail customer would need to fax information to Qwest on multiple circuits in trouble. Thanks

Kathy Stichter ILEC Relations Manager Eschelon Telecom Inc Voice 612 436-6022 E-Mail klstichter@eschelon.com

CenturyLink Response

November 7, 2001

Kathy Stichter ILEC Relations Manager Eschelon Telecom, Inc

CC: Matthew Rossi

RE: CR #5579345 – Repair process for multiple lines on single report.

This letter is in response to your CLEC Change Request Form #5579345 dated June 6, 2001. It includes the updates that were agreed to in a joint meeting held with Qwest and Eschelon on September 10, 2001.

Qwest is providing procedures detailed in this letter to address multiple circuits on a single trouble ticket. Credit for circuit outages are also addressed.

? Change Request: “Repair process for multiple lines on single report Develop a consistent repair process for receiving information about multiple lines for a single customer on a single report, without the use of facsimiles. In some instances, when Eschelon calls Qwest about a repair issue for a multiple-line account, Qwest will require Eschelon to call regarding the main line and then send information regarding the subsequent lines by facsimile. This is time consuming and inefficient for both parties. In other cases, the Qwest representative will take the information over the telephone for all of the lines. The latter approach is more efficient. In any case, a consistent approach is needed so that Eschelon may adequately train its employees in the proper procedure.”

Qwest Response:

Qwest has developed a process for handling multiple ticket requests which will provide an option to the CLECs to either fax multiple requests or remain on line with the Repair Employee while the tickets are submitted.

Related “Trouble”

For Wholesale, Non-Design and Design Services, including Unbundled Loops, multiple trouble reports will be accepted on a single repair ticket if all three (3) of the following criteria are met:

- Same, exact trouble on each line, i.e. static on TN 333-333-3333, 333-333-3334 and 333-333-3335. - Same end user location - Same customer name for end user

There is a restriction on Design Services, including Unbundled Loops; trouble reports of five (5) cases of trouble per single repair ticket. No restrictions exist for Non-Design Services.

Unrelated “Trouble”

If the CLEC answers “no” to any of these three questions, then individual trouble reports must be submitted.

One trouble ticket will be issued for each separate case of trouble. Qwest will offer the option to the CLEC to input one case of trouble and fax the additional cases of trouble to Qwest. The ticket number from the first case of trouble must be on the fax to be used as a cross-reference on all other cases of trouble. If the CLEC chooses not to fax additional cases of trouble, the CLEC may remain on the line with the Repair Employee to submit all trouble tickets.

The CLEC is responsible to isolate trouble to a specific line when multiple lines exist for a customer at one location. If the CLEC requests, Qwest will perform the trouble isolation and appropriate charges will apply.

Credits for Circuit Outages

Qwest currently uses the WFA (Work Force Administrator) system for all trouble reporting. It was designed to only handle a single circuit per trouble report. Consequently, credits for circuit outages are limited to a single circuit per trouble report. The CLEC may request individual tickets to ensure credit, as appropriate, for each affected circuit.

Qwest is willing to assist Eschelon or any other CLEC in the preparation of a system Change Request that would investigate options to modify WFA to correct current deficiencies in the system for providing credits for more than one circuit.

Sincerely, Cheryl McMahon Senior Process Analyst

October 31, 2001

Kathy Stichter ILEC Relations Manager Eschelon Telecom, Inc

CC: Matthew Rossi Chris Henderson

RE: CR #5579345 - Repair process for multiple lines on single report.

This letter is in response to your CLEC Change Request Form #5579345 dated June 6, 2001. It includes the updates that were agreed to in a joint meeting held with Qwest and Eschelon on September 10, 2001.

* Change Request: "Repair process for multiple lines on single report. Develop a consistent repair process for receiving information about multiple lines for a single customer on a single report, without the use of facsimiles. In some instances, when Eschelon calls Qwest about a repair issue for a multiple-line account, Qwest will require Eschelon to call regarding the main line and then send information regarding the subsequent lines by facsimile. This is time consuming and inefficient for both parties. In other cases, the Qwest representative will take the information over the telephone for all of the lines. The latter approach is more efficient. In any case, a consistent approach is needed so that Eschelon may adequately train its employees in the proper procedure."

Qwest Response:

Qwest currently uses the WFA (Work Force Administrator) system for all trouble reporting. This system is a Telecordia software system developed during the mid-1980’s time frame. It was designed to only handle a single circuit per trouble report. Any modifications to the software system for handling multiple circuits per trouble report would require a software modification by Telecordia. The cost for modification is roughly estimated in the hundreds of thousands of dollars. Currently, Qwest has no plans to modify WFA to accept multiple circuits per trouble report.

Qwest is providing procedures detailed in this letter to address multiple circuits on a single trouble ticket. Credit for circuit outages are also addressed.

Related "Trouble"

For Wholesale and Retail, Non-Designed and Designed Services, including Unbundled Loops, multiple trouble reports will be accepted on a single repair ticket if all three (3) of the following criteria are met:

- Same, exact trouble on each line, i.e. static on TN 333-333-3333, 333-333-3334 and 333-333-3335. - Same end user location - Same customer name for end user

There is a restriction on Designed Service, including Unbundled Loops; trouble reports of five (5) cases of trouble per single repair ticket. No restrictions exist for Non-Designed Services that meet the above criteria.

Unrelated "Trouble"

If the co-provider answers "no" to any of these three questions, then individual trouble reports must be submitted. If the co-provider has additional information that Qwest has no system access to, the information must be "faxed" to the appropriate repair center.

One trouble ticket will be issued for each separate case of trouble. Qwest inputs one case of trouble then gives that ticket number to the CLEC or Retail end user. The CLEC or Retail end user then faxes the additional cases of trouble to Qwest. The ticket number from the first case of trouble must be on the fax to be used as a cross-reference on all other cases of trouble.

The co-provider is responsible to isolate trouble to a specific line when multiple lines exist for a customer at one location. If the co-provider requests, Qwest will perform the trouble isolation and appropriate charges will apply.

Credits for Circuit Outages

Currently, only the circuit listed on the trouble ticket will receive credit. If multiple loops were put on one ticket, and multiple outages occurred, the CLEC would need to contact their Account Manager for additional credits.

To ensure process compliance by the Qwest Repair Center personnel, the center management has initiated a review of these Methods and Procedures.

Sincerely,

Chris Henderson Senior Process Analyst

Ann Danielsen Manager Process Management

-

September 14, 2001 Wholesale Product Marketing Kathy Stichter ILEC Relations Manager Eschelon Telecom, Inc

CC:Matthew Rossi Chris Henderson

RE: CR #5579345 Repair process for multiple lines on single report.

This letter is in response to your CLEC Change Request Form #5579345 dated June 6, 2001. It includes the updates that were agreed to in a joint meeting held with Qwest and Eschelon on September 10, 2001.

Change Request: Repair process for multiple lines on single report Develop a consistent repair process for receiving information about multiple lines for a single customer on a single report, without the use of facsimiles. In some instances, when Eschelon calls Qwest about a repair issue for a multiple-line account, Qwest will require Eschelon to call regarding the main line and then send information regarding the subsequent lines by facsimile. This is time consuming and inefficient for both parties. In other cases, the Qwest representative will take the information over the telephone for all of the lines. The latter approach is more efficient. In any case, a consistent approach is needed so that Eschelon may adequately train its employees in the proper procedure.

Qwest Response: For Wholesale and Retail, Non-Designed and Designed Services, including Unbundled Loops, multiple trouble reports will be accepted on a single repair ticket if all three (3) of the following criteria are met:

Same, exact trouble on each line, i.e. static on TN 333-333-3333, 333-333-3334 and 333-333-3335. Same end user location Same customer name for end user

There is a restriction on Designed Service, including Unbundled Loops, trouble reports of five (5) cases of trouble per single repair ticket. No restrictions exist for Non-Designed Services.

If the co-provider answers “no” to any of these three, then individual trouble reports must be submitted. If the co-provider has additional information that Qwest has no system access to, the information must be “faxed” to the appropriate repair center.

The co-provider is responsible to isolate trouble to a specific line when multiple lines exist for a customer at one location. If the co-provider requests, Qwest will perform the trouble isolation and appropriate charges will apply.

One trouble ticket will be issued for each separate case of trouble. Qwest inputs one case of trouble then gives that ticket number to the CLEC or Retail end user. The CLEC or Retail end user then faxes the additional cases of trouble to Qwest. The ticket number from the first case of trouble must be on the fax to be used as a cross-reference on all other cases of trouble.

To ensure process compliance by the Qwest Repair Center personnel, the center management has initiated a review of these Methods and Procedures.

Sincerely,

Nancy J. Hoag Wholesale Product Manager

July 13, 2001

Lynne Powers Vice President, Customer Operations Eschelon Telecom, Inc

CC:Matthew Rossi Chris Henderson

RE: CR #5579345 Repair process for multiple lines on single report.

This letter is in response to your CLEC Change Request Form #5579345 dated June 6, 2001. Change Request: Repair process for multiple lines on single report Develop a consistent repair process for receiving information about multiple lines for a single customer on a single report, without the use of facsimiles. In some instances, when Eschelon calls Qwest about a repair issue for a multiple-line account, Qwest will require Eschelon to call regarding the main line and then send information regarding the subsequent lines by facsimile. This is time consuming and inefficient for both parties. In other cases, the Qwest representative will take the information over the telephone for all of the lines. The latter approach is more efficient. In any case, a consistent approach is needed so that Eschelon may adequately train its employees in the proper procedure.

Qwest Response: For both Non-Designed and Designed Services, except for Unbundled Loops, multiple trouble reports will be accepted on a single repair ticket if all three (3) of the following criteria are met:

1. Same, exact trouble on each line, i.e. static on TN 333-333-3333, 333-333-3334 and 333-333-3335. 2. Same end user location 3. Same customer name for end user

There is a restriction on Designed Service trouble reports of five (5) cases of trouble per single repair ticket. No restrictions exist for Non-Designed Services. If the co-provider answers (no) to any of these three, then individual trouble reports must be submitted. If the co-provider has additional information that Qwest has no system access to, the information must be (faxed) to the appropriate repair center.

The co-provider is responsible to isolate trouble to a specific line when multiple lines exist for a customer at one location. If the co-provider requests, Qwest will perform the trouble isolation and appropriate charges will apply.

For Unbundled Loop Services, one trouble ticket will be issued for each separate case of trouble. Qwest inputs one case of trouble then gives that ticket number to the CLEC. The CLEC then faxes the additional cases of trouble to Qwest. The ticket number from the first case of trouble must be on the fax to be used as a cross-reference on all other cases of trouble.

To ensure process compliance by the Qwest Repair Center personnel, the center management will conduct a review of these Methods and Procedures. Sincerely,

Nancy J. Hoag Wholesale Product Manager

Open Product/Process CR PC091901-1 Detail

Description Of Change

CLEC on-net to resale reuse of facilities

CLEC on-net to resale new facilities

Resale CLEC to resale CLEC (same CLEC) move including port within

Change orders requesting a TN change reusing TNs from old location and changing them at the new location requiring port within.

The team to include Qwest SMEs from each of its’ functional areas:

Order distribution center

Service order processing

Assignments

Switch technicians (RCMAC)

Network dispatch in

Network dispatch out

LNP center

Eschelon has offered to serve as the prototype for this Quality Team which will benefit all CLECs. It is yet to be determined how these orders will be identified. Eschelon’s expectation is that the Quality Team at Qwest will watch the flow of each order and determine the process gaps that are causing CLEC customers a significant amount of service disruption and down time. In addition, the Quality Team should remain in place until process improvements are made and proven effective.

Status History

Project Meetings

Specifics: Purpose of Meeting: resolve Port In/Within order issues Meeting Dates: March 22,2002 Time: 1pm CST Meeting Chair: Toni Dubuque Next Meeting:Complete

Attendees: Toni Dubuque, Qwest Cust Svc Oprns Bonnie Johnson, Eschelon Joan Wells, Qwest Process Claudia Meredith-Trump, Qwest

Agenda: - Finalize flows - Finalize test process

- Port-in flows have been re-done on Power Point with specific language on process to be used in the 3 Port in scenarios and 8 Port within scenarios. These were reviewed by the team and are in an understandable format for training. - Training will be done by Qwest in the Mpls center CSIE team and documents shared with all other appropriate centers for review. - Joan will work with the product team to get specific scenarios updated in PCAT - Eschelon will do test order week of April 1st. Claudia will monitor flow and get specifics back to Bonnie for confirmation of order process.

The committee feels that they have completed the objective of improving the documented processes for unique situations involving Port In and Port within orders. This work will benefit all customers who order LNP. Order routing changes have eliminated the problems with moving orders from center to center within Qwest.

Purpose of Meeting: Resolve Port In/Within order issues Meeting Dates: January 23,002, Time: 1130am CST Call-in Bridge: 877-572-868, ID: 811-0227 Meeting Chair: Toni Dubuque Next Meeting:February 7,2002 3-4pm CST

Name/Presentation Toni Dubuque, Qwest Cust Svc Oprns/x/ Joan Wells, Qwest Process/x/ Bonnie Johnson, Eschelon/x/ Claudia Meredith-Trump, Qwest/x/ Chris Siewert,, Qwest Ctr Mgmt/x/ Barb Vigoren, Eschelon/ / Mary Madill, Qwest Ctr Mgr/ / Frank Lopez, Qwest Ctr Mgr/ /

Agenda: - Finalize flows - Finalize test process - Address Action Items - Determine next meeting

- Port-in flows are final and have been issued within Qwest; scenarios 1-3 are attached. - Port-within flows are work-in-progress to add all products - Test accounts have been set up and by 1-25 a test order will be submitted by Eschelon for monitoring and ensuring process for Scenario 3 is working; have already used process on live orders for Scenario 2. - During root cause process, we had identified a learning about procedures between RCMAC and Complex Translations (CT) that we wanted to investigate and tighten communications. On port-in C-orders, if the NPA-NXX of the end user has never been loaded into a DMS-10 or Ericsson Switch, Complex Translations must load before RCMAC does work. Communication is done by fax. We have added step in process for order writer to call CT to ensure load is complete prior to order flowing downstream. - Port-in coordination product is in detail design and pricing for both retail and wholesale. This will take care of end users who have special needs and cannot afford downtime. Joan is our representative and will keep us updated on progress. (CR open also) - Auto routing of port-in/within orders by MPI will be implemented 3-20-02. Good news – screening will be eliminated.

Action Items: Item/Assigned to/Status/Completion Date 1. Determine an interim process for cutting over end users who handle emergency call (doctors, hospitals) to eliminate inability to receive calls on due date (FDT 8am, work done anytime between 8-5pm)/Joan Wells/Same as #2/Work in progress 2. Communicate potential date of new coordination process/product for port in orders that will eliminate downtime (in definition stage)/Joan Wells/See above/Work in progress 3. Meet with Network process to investigate gaps in handling C action orders in complex translations/Joan/Chris/Completed / see notes above/1-23-02 Set up test accounts 612-302 and 612-721/Joan/Completed/1-23-02 Test Scenario 3/Joan/Bonnie// Finalize Port within flows/Joan/Should be done by 2-1/

Next meeting will be the last formal session. We will reconvene team to do live test when actual order is received by Eschelon.

CMP Quality Meeting Minutes 01-07-02

Specifics: Purpose of Meeting: resolve Port In/Within order issues Meeting Dates: December 18, 2001 Time: 2pm CST Call-in Bridge 877-572-868 811-0227 Meeting Chair: Toni Dubuque Next Meeting: January 9, 2002 @ 2pm CST

Attendees: Name Present Name Present Toni Dubuque, Qwest Cust Svc Oprns x Joan Wells, Qwest Process x Bonnie Johnson, Eschelon x Claudia Meredith-Trump, Qwest x Al Kiehn, Qwest Ctr Mgmt x Barb Vigoren, Eschelon x Mary Madill, Qwest Ctr Mgr Frank Lopez, Qwest Ctr Mgr

Agenda: - Review flows and clarify any questions - Set up process for live customer SPOC monitoring - Determine next meeting

Flows were presented by Joan Wells indicating the different scenarios regarding special circumstances for Port in, Port within orders.

- End user is with Q retail or current CLEC NSP/end user moving to new location requesting to move existing TN’s and change to a new reseller provider, new facilities/Q port in activity flow - Existing resale account, no service provider change to 2 current locations – original location with account history to be disconnected and TN’s moved to newest account locations where new TN’s exist that will be disconnected/Port within activity flow - Existing resale account port within/T &F dual service requested, number change at T location upon completion of F order activity flow - End user is with Q retail or current CLEC NSP/end user moving to new location already served by same reseller requesting Port, will be disconnecting existing TN’s and replacing with port in in TN’s, reuse existing facilities/Q port in activity flow

There were a number of questions and clarifications done on the flows. This used the majority of the time allotted for the meeting. Another meeting was set to regroup and finalize flows.

Quality Team - Qwest/Eschelon LNP Order Issues: Revision 5 Team Members: Sponsor - Toni Dubuque Q Team - Mark Coyne, Ray Burton, Mary Madill, Joan Wells, Russ Urvig E Team - Bonnie Johnson

Meetings: Sept 10, 2001 @ 10:30am CDT Sept 17, 2001 @ 2:00pm CDT (rev 2) Sept 26, 2001 @ 930am CDT (rev 3) Oct 5,2001 @ 930MDT/1030amCDT (rev 4) Oct 12, 2001 Oct 26, 2001 @ 230pmCDT (rev 5) NEXT MTG Nov 7, 2001 @ 900am CST Call-In Number: 877-847-3567 pc600-2974

ISSUE 1: Mis routing of orders causing missed commitments - CLOSED * Port within orders should go to Cheyenne for processing * Port in orders should go to Phoenix for processing * Screeners in Dallas must make determination based on remarks field * States manual handling * Move - port within or port between CLEC to CLEC ACTION ITEMS: * NPI field on LSR (determines port in or within) not used by Q. Eschelon has put in a CR for consideration. This field also then could be used to route LSR to right center without manual handling Owner: Mark and Joan * Retrain Dallas to handle current LSRs and screen to right center Owner: Ray * Identify unique req. type for these types of orders for ease in mechanized routing Owner: Joan Wells * With Virtual Center, should Duluth also be trained to handle the port in orders? The volume has been small so expertise has been centralized. Owner: Mary Status - Rev 1: This training took place the week of 9-3-01 with clarification on how to recognize the difference in order to route properly. The current process dictates that any misrouted order to be special handled and not go into regular flow (calls are placed between centers) Status - Rev 2: * An user request to use the NPI field in conjunction with the req. type will be filed by week ending 9-21 so that IMA can automatically route the orders to the proper center for processing. The NPI field is in use at Q on the Resale LSR form. 30-day notification will need to be made to all CLECs prior to implementation. No definite date yet but will target EOY. * The req. type change will not be required since routing will be accomplished through the NPI field. Req. type changes must go through OBF so the option selected for implementation should be more timely. * There were no failures in routing last week for Eschelon. Center managers are stressing the need to review the entire LSR before processing. Daily 3pm calls between centers are identifying each routing failure and preparing direct feedback to the SDC. * Volumes will dictate the move of port-in orders CLEC to CLEC to Duluth. * E is calling on any orders that do not carry telephone # and name of a Phoenix SDC. This is an indication to them that we potentially had a failure in routing. Status - Rev 3 * Routing problems significantly improved * CR for NPI field delayed due to further investigation; all problems resolved and will be issued on 10-8-01 by Joan Wells Status = Rev 5 * UR filed and kick-off meeting held with IT; projected implementation scheduled for late 1st qrt ’02 or early 2nd qrt * Decision made to implement as a going forward change ISSUE 2: Reuse of facilities on Port within orders - CLOSED

* Circuit ID given by E, if available * If reuse is not done, FOC must be noted in the remarks that new facilities are being used so that E can dispatch tech for cross-connect work. Failure to dispatch causes end-user out-of-service condition ACTION ITEMS: * Review process to verify what needs to take place within centers Owner: Mary/Joan/Russ Urvig * Look at Loop Reclamation policy and clarify obligation to reuse facilities Owner: Toni Status - Rev 2: * Clarification needed on product definition pertaining to Q discretion on reuse. Process/Product will get together to clarify and bring back to team concise definition. * Gap still exists when reuse not chosen as option. Order writers not aware of issue at time of FOC so do inform customer. Need to revise process to determine best method of notification. Status - Rev 3: * Policy is to reuse facilities whenever possible preventing dispatch for Q or for CLEC * When reuse is not the available option, our tech should be doing cross-connect work so no dispatch required by CLEC Status - Rev 5: * Process working and full understanding established

ISSUE 3: Trouble Shooting Port in/Port within orders

* When trying to back out orders that have gone bad, Q/E needs to understand internal flow to enhance trouble shooting skills ACTION ITEMS: * Review process and document key points for both Q CSIE team and E Owner: Joan Wells Status - Rev 2: * E indicated that there are numerous areas of failure for these types of work backs often causing outages of up to 3 days. They are recommending focal points within the center to deal with these orders so that expertise will be built and that data can be collected for root cause analysis. This suggestion will be looked at for feasibility and reported out at next meeting (Owner: Toni) Status - Rev 3: * Root cause will be done on all failures with gap analysis and recommended action. (Owner: Claudia Meredith-Trump) First read out on 10-5 * Focal points process to be discussed on 10-5

Status - Rev 5 * Root cause analysis done on 5 failures on 10-5 and 1 failure on 10-26 * Findings: * SO writing orders found for both sending and receiving parties; discussed process adherence and provided feedback to all employees touching orders * CLEC owning customers did not disconnect in switch on a timely basis; early detection of this in trouble shooting process can reduce impairment issues * CSIE personnel reviewed failure points and areas to intervene before additional complications add to length of impairment * Will continue process to look at every failure for additional learning

ISSUE 4: Problem for Port in – working in both switches * Calls going both ways in switch * E would like to coordinate the time between the techs for delivering new facilities ACTION ITEMS: * Review process to id gaps and areas for improvement Owner: Joan Wells Status - Rev 2: * Problem lies with FDT and when triggering takes place at both customer locations (giver/receiver). Joan has made one change to Q to default FDT from 5pm to noon. More investigation to follow on other issues and potential process improvements. Status - Rev 5 * Eschelon filed CR to request options; Joan Wells working on research for options

ISSUE 4: Identifying ways to minimize errors ACTION ITEMS: * Look at using NPI as first characters of PON to capture and track orders for trouble shooting Owner: Ray and Bonnie Status - Rev 2: * E will use effective 9-27 so that Q can capture orders and do root cause. Screening process will stay the same so that we ensure SDC still looks at entire LSR to determine correct routing. Status - Rev 5 * Continue to use field; screening failures minimal; feedback and process review continues with employees

ISSUE 5: Telephone number swap Added 9-17-01 * E will write up issue so right Q people on team to handle * Problem definition: Eschelon has a customer with a ported number (usually resale). They are going to move within the same CO so dual service is not an option. So they establish the customer at the new location with a new telephone number and leave the old number working. When the customer is moved and at the new premise, they need to disconnect the old ported number and reestablish it at the move location - also disconnecting the temporary telephone number. How can they do this?

Status - Rev 3: * Joan to read out on 10-5 Status - Rev 5 To clarify this answer, I checked with Retail on their processes for Port Within (T&F) and also Dual and Overlapping Service, which our Wholesale processes mirror. Retail does not allow dual service if you are porting your telephone number within. This means if the end user has a telephone number currently, that was either previously ported in or a native TN to the switch, and are now moving to a new switch and want to do a port within, they would not be able to have dual service, because of the LRN routing that is taking place through the NPAC. Incoming calls cannot be routed to more than one switch at a time, so this would cause problems with the end user receiving their incoming calls.

If the end user currently has a TN that was previously ported in and now wants to do a T&F to a new location within the same switch, this would not be considered a port within and the limitation involving the dual service would then be dependent upon the switch type, the product type, the line type (bridge taps etc.) and the region. There are methods in Infobuddy that outline the restrictions and rules for dual service, as well as facility check, which helps to determine if dual service is an option in these situations.

So, if dual service is desired, but not available, what the Reseller would have to do, is request a New connect at the new location with new TN's. Then, when they want the service at the old location disconnected, they would have to submit two related requests. One to do a number change at the new location as a port within, indicating the new numbers and another request to disconnect the number at the old location, using port out fids. Qwest would then process the disconnect, using the port out fids and the number change using the port in fids. These would be manual orders, with good remark entries needed from the Reseller as to what exactly is needed on the orders. Standard port due date intervals would apply.

* Process change to be made to allow move and port on one LSR; this will not change Dual service issue but will help with other order issues that cause CLEC to do two LSRs to accomplish task. Effective date yet to be determined. Will continue to monitor progress

Quality Team - Qwest/Eschelon LNP Order Issues: Revision 3 Team Members: Sponsor - Toni Dubuque Q Team - Mark Coyne, Ray Burton, Mary Madill, Joan Wells, Russ Urvig E Team - Bonnie Johnson

Meetings: Sept 10, 2001 @ 10:30am CDT Sept 17, 2001 @ 2:00pm CDT (rev 2) Sept 26, 2001 @ 930am CDT (rev 3) Oct 5,2001 @ 930MDT/1030amCDT (rev 4) Call-In Number: 877-847-3567 pc600-2974

ISSUE 1: Misrouting of orders causing missed commitments

* Port within orders should go to Cheyenne for processing * Port in orders should go to Phoenix for processing * Screeners in Dallas must make determination based on remarks field * States manual handling * Move - port within or port between CLEC to CLEC ACTION ITEMS: * NPI field on LSR (determines port in or within) not used by Q. Eschelon has put in a CR for consideration. This field also then could be used to route LSR to right center without manual handling Owner: Mark and Joan * Retrain Dallas to handle current LSRs and screen to right center Owner: Ray * Identify unique req type for these types of orders for ease in mechanized routing Owner: Joan Wells * With Virtual Center, should Duluth also be trained to handle the port in orders? The volume has been small so expertise has been centralized. Owner: Mary Status - Rev 1: This training took place the week of 9-3-01 with clarification on how to recognize the difference in order to route properly. The current process dictates that any misrouted order to be special handled and not go into regular flow (calls are placed between centers) Status - Rev 2: * An user request to use the NPI field in conjunction with the req type will be filed by week ending 9-21 so that IMA can automatically route the orders to the proper center for processing. The NPI field is in use at Q on the Resale LSR form. 30-day notification will need to be made to all CLECs prior to implementation. No definite date yet but will target EOY. * The req type change will not be required since routing will be accomplished through the NPI field. Req type changes must go through OBF so the option selected for implementation should be more timely. * There were no failures in routing last week for Eschelon. Center managers are stressing the need to review the entire LSR before processing. Daily 3pm calls between centers are identifying each routing failure and preparing direct feedback to the SDC. * Volumes will dictate the move of port-in orders CLEC to CLEC to Duluth. * E is calling on any orders that do not carry telephone # and name of a Phoenix SDC. This is an indication to them that we potentially had a failure in routing. Status - Rev 3 * Routing problems significantly improved * CR for NPI field delayed due to further investigation; all problems resolved and will be issued on 10-8-01 by Joan Wells ISSUE 2: Reuse of facilities on Port within orders

* Circuit ID given by E, if available * If reuse is not done, FOC must be noted in the remarks that new facilities are being used so that E can dispatch tech for cross-connect work. Failure to dispatch causes end-user out-of-service condition ACTION ITEMS: * Review process to verify what needs to take place within centers Owner: Mary/Joan/Russ Urvig * Look at Loop Reclamation policy and clarify obligation to reuse facilities Owner: Toni Status - Rev 2: * Clarification needed on product definition pertaining to Q discretion on reuse. Process/Product will get together to clarify and bring back to team concise definition. * Gap still exists when reuse not chosen as option. Order writers not aware of issue at time of FOC so do inform customer. Need to revise process to determine best method of notification. Status - Rev 3: * Policy is to reuse facilities whenever possible preventing dispatch for Q or for CLEC * When reuse is not the available option, our tech should be doing cross-connect work so no dispatch required by CLEC

ISSUE 3: Trouble Shooting Port in/Port within orders

* When trying to back out orders that have gone bad, Q/E needs to understand internal flow to enhance trouble shooting skills ACTION ITEMS: * Review process and document key points for both Q CSIE team and E Owner: Joan Wells Status - Rev 2: * E indicated that there are numerous areas of failure for these types of work backs often causing outages of up to 3 days. They are recommending focal points within the center to deal with these orders so that expertise will be built and that data can be collected for root cause analysis. This suggestion will be looked at for feasibility and reported out at next meeting (Owner: Toni) Status - Rev 3: * Root cause will be done on all failures with gap analysis and recommended action. (Owner: Claudia Meredith-Trump) First read out on 10-5 * Focal points process to be discussed on 10-5

ISSUE 4: Problem for Port in - working in both switches * Calls going both ways in switch * E would like to coordinate the time between the techs for delivering new facilities ACTION ITEMS: * Review process to id gaps and areas for improvement Owner: Joan Wells Status - Rev 2: * Problem lies with FDT and when triggering takes place at both customer locations (giver/receiver). Joan has made one change to Q to default FDT from 5pm to noon. More investigation to follow on other issues and potential process improvements.

ISSUE 4: Identifying ways to minimize errors ACTION ITEMS: * Look at using NPI as first characters of PON to capture and track orders for trouble shooting Owner: Ray and Bonnie

Status - Rev 2: * E will use effective 9-27 so that Q can capture orders and do root cause. Screening process will stay the same so that we ensure SDC still looks at entire LSR to determine correct routing.

ISSUE 5: Telephone number swap Added 9-17-01 * E will write up issue so right Q people on team to handle * Problem definition: Eschelon has a customer with a ported number (usually resale). They are going to move within the same CO so dual service is not an option. So they establish the customer at the new location with a new telephone number and leave the old number working. When the customer is moved and at the new premise, they need to disconnect the old ported number and reestablish it at the move location - also disconnecting the temporary telephone number. How can they do this?

Status - Rev 3: * Joan to read out on 10-5

Quality Team - Qwest/Eschelon LNP Order Issues: Revision 2 Team Members: Sponsor - Toni Dubuque Q Team - Mark Coyne, Ray Burton, Mary Madill, Joan Wells, Russ Urvig E Team - Bonnie Johnson

Meetings: Sept 10, 2001 @ 10:30am CDT Sept 17, 2001 @ 2:00pm CDT (rev 2) Sept 26, 2001 @ 930am CDT (rev 3) Call-In Number: 877-847-3567 pc600-2974

ISSUE 1: Misrouting of orders causing missed commitments

* Port within orders should go to Cheyenne for processing * Port in orders should go to Phoenix for processing * Screeners in Dallas must make determination based on remarks field * States manual handling * Move - port within or port between CLEC to CLEC ACTION ITEMS: * NPI field on LSR (determines port in or within) not used by Q. Eschelon has put in a CR for consideration. This field also then could be used to route LSR to right center without manual handling Owner: Mark and Joan * Retrain Dallas to handle current LSRs and screen to right center Owner: Ray * Identify unique req type for these types of orders for ease in mechanized routing Owner: Joan Wells * With Virtual Center, should Duluth also be trained to handle the port in orders? The volume has been small so expertise has been centralized. Owner: Mary Status - Rev 1: This training took place the week of 9-3-01 with clarification on how to recognize the difference in order to route properly. The current process dictates that any misrouted order to be special handled and not go into regular flow (calls are placed between centers) Status - Rev 2: * An user request to use the NPI field in conjunction with the req type will be filed by week ending 9-21 so that IMA can automatically route the orders to the proper center for processing. The NPI field is in use at Q on the Resale LSR form. 30-day notification will need to be made to all CLECs prior to implementation. No definite date yet but will target EOY.

* The req type change will not be required since routing will be accomplished through the NPI field. Req type changes must go through OBF so the option selected for implementation should be more timely.

* There were no failures in routing last week for Eschelon. Center managers are stressing the need to review the entire LSR before processing. Daily 3pm calls between centers are identifying each routing failure and preparing direct feedback to the SDC.

* Volumes will dictate the move of port-in orders CLEC to CLEC to Duluth. * E is calling on any orders that do not carry telephone # and name of a Phoenix SDC. This is an indication to them that we potentially had a failure in routing. ISSUE 2: Reuse of facilities on Port within orders

* Circuit ID given by E, if available * If reuse is not done, FOC must be noted in the remarks that new facilities are being used so that E can dispatch tech for cross-connect work. Failure to dispatch causes end-user out-of-service condition ACTION ITEMS: * Review process to verify what needs to take place within centers Owner: Mary/Joan/Russ Urvig * Look at Loop Reclamation policy and clarify obligation to reuse facilities Owner: Toni Status - Rev 2: * Clarification needed on product definition pertaining to Q discretion on reuse. Process/Product will get together to clarify and bring back to team concise definition. * Gap still exists when reuse not chosen as option. Order writers not aware of issue at time of FOC so do inform customer. Need to revise process to determine best method of notification.

ISSUE 3: Trouble Shooting Port in/Port within orders

* When trying to back out orders that have gone bad, Q/E needs to understand internal flow to enhance trouble shooting skills ACTION ITEMS: * Review process and document key points for both Q CSIE team and E Owner: Joan Wells Status - Rev 2: * E indicated that there are numerous areas of failure for these types of work backs often causing outages of up to 3 days. They are recommending focal points within the center to deal with these orders so that expertise will be built and that data can be collected for root cause analysis. This suggestion will be looked at for feasibility and reported out at next meeting (Owner: Toni)

ISSUE 4: Problem for Port in - working in both switches * Calls going both ways in switch * E would like to coordinate the time between the techs for delivering new facilities ACTION ITEMS: * Review process to id gaps and areas for improvement Owner: Joan Wells Status - Rev 2: * Problem lies with FDT and when triggering takes place at both customer locations (giver/receiver). Joan has made one change to Q to default FDT from 5pm to noon. More investigation to follow on other issues and potential process improvements.

ISSUE 4: Identifying ways to minimize errors ACTION ITEMS: * Look at using NPI as first characters of PON to capture and track orders for trouble shooting Owner: Ray and Bonnie

Status - Rev 2: * E will use effective 9-27 so that Q can capture orders and do root cause. Screening process will stay the same so that we ensure SDC still looks at entire LSR to determine correct routing.

ISSUE 5: Telephone number swap Added 9-17-01 * E will write up issue so right Q people on team to

-

Quality Team - Qwest/Eschelon LNP Order Issues: Revision 1 Team Members: Sponsor - Toni Dubuque Q Team - Mark Coyne, Ray Burton, Mary Madill, Joan Wells E Team - Bonnie Johnson

Meetings: Sept 10, 2001 @ 10:30am CDT Sept 17, 2001 @ 2:00pm CDT Call-In Number: 877-847-3567 pc600-2974

ISSUE 1: Misrouting of orders causing missed commitments

* Port within orders should go to Cheyenne for processing * Port in orders should go to Phoenix for processing * Screeners in Dallas must make determination based on remarks field * States manual handling * Move - port within or port between CLEC to CLEC ACTION ITEMS: * MPI field on LSR (determines port in or within) not used by Q. Eschelon has put in a CR for consideration. This field also then could be used to route LSR to right center without manual handling Owner: Mark and Joan * Retrain Dallas to handle current LSRs and screen to right center Owner: Ray Status: This training took place the week of 9-3-01 with clarification on how to recognize the difference in order to route properly. The current process dictates that any misrouted order to be special handled and not go into regular flow (calls are placed between centers) * Identify unique req type for these types of orders for ease in mechanized routing Owner: Joan Wells * With Virtual Center, should Duluth also be trained to handle the port in orders? The volume has been small so expertise has been centralized. Owner: Mary

ISSUE 2: Reuse of facilities on Port within orders

* Circuit ID given by E, if available * If reuse is not done, FOC must be noted in the remarks that new facilities are being used so that E can dispatch tech for cross-connect work. Failure to dispatch causes end-user out-of-service condition ACTION ITEMS: * Review process to verify what needs to take place within centers Owner: Mary * Look at Loop Reclamation policy and clarify obligation to reuse facilities Owner: Toni ISSUE 3: Problem understanding timing of translations

* When trying to back out orders that have gone bad, E needs to understand internal flow to enhance trouble shooting skills ACTION ITEMS: * Review process and document key points for both Q CSIE team and E Owner: Joan Wells

ISSUE 4: Problem for Port in - working in both switches * Calls going both ways in switch * E would like to coordinate the time between the techs for delivering new facilities ACTION ITEMS: * Review process to id gaps and areas for improvement Owner: Joan Wells

ISSUE 4: Identifying ways to minimize errors

ACTION ITEMS: * Look at using MPI as first characters of PON to capture and track orders for trouble shooting Owner: Ray and Bonnie

Open Product/Process CR PC101001-1 Detail

Description Of Change

Status History

Project Meetings

CenturyLink Response

Kathleen Stichter ILEC Relations Manager Eschelon

CC: Mark Coyne Ann Danielsen

This letter is in response to your CLEC Change Request Form, number PC 101001-1 dated 10/10/01 – Process for CLEC to get end user service corrected without an additional LSR when Qwest typed the original order incorrectly.

Request: Currently when Eschelon calls Qwest repair, if the customer service record (CSR) does not match what Eschelon ordered, Qwest repair refuses to open a ticket and instead tells Eschelon to issue an order to correct the problem. Eschelon will investigate and determine that what the LSR asked for is different than what Qwest typed. If an end user customer needs to wait for Eschelon to send through a LSR and Qwest to issue an order the end user would be without the service for several days. This is a hardship for the end user customer. Eschelon asks Qwest to develop, document, distribute and train an adhered to process for Eschelon repair to call Qwest repair and have the end user customer service fixed without Eschelon issuing another LSR. Eschelon asks that the process include Qwest repair transferring Eschelon to the appropriate person within Qwest who will issue an order with the same day DD to fix the problem that was caused by Qwest typing the original order incorrectly.

Qwest Response: Qwest Repair Process When a CLEC calls the Repair Center to report trouble on their end users service, the Repair Center will issue a repair ticket and forward the ticket to the appropriate screening group. If the screening group determines the problem needs to be resolved with a service order, the screener will refer the problem to the Interconnect Service Center (ISC). The ISC will initiate the subsequent order resulting from a Qwest error on the LSR or will contact the CLEC on errors resulting from a CLEC error on the LSR.

Interconnect Service Center Process CLEC reports of service problems or outages within 72 hours of order activity should be directed to the Interconnect Service Center (ISC) at 1-888-796-9087. The ISC agent will ascertain all pertinent information, create a database trouble ticket and attempt to warm transfer the CLEC to a Customer Service Inquiry and Education Service Delivery Consultant (CSIE SDC). If a CSIE SDC cannot be reached directly, the ISC agent will refer the trouble ticket to the CSIE SDC and advise the CLEC that they will receive a call back within 2 hours. The CSIE SDC will investigate the trouble ticket by reviewing the LSR and associated service order(s).

If a discrepancy is found on a completed service order (ordered product and/or services were not delivered), the CSIE SDC will issue a new service order to correct the problem. Every effort will be made to provide a same day Due Date for the new order. If no discrepancies are found on the completed service order, the CSIE SDC will either warm transfer the CLEC (if the CLEC is on the line) or refer the problem on behalf of the CLEC to the appropriate QWEST repair center. Resale POTS or PAL service trouble reports are handled by the Repair Call Handling Center (RCHC) at 1-800-573-1311 for residential service or 1-800-954-1211 for business service. Trouble reports for all other products are handled by the Account Maintenance Support Center (AMSC) at 1-800-223-7881.

Sincerely,

Cheryl McMahon Senior Process Analyst

Monica Manning IMA Process Specialist

Open Product/Process CR 5527214 Detail

Description Of Change

Eschelon asked that Qwest provide a process by which CLECs can order, pay for and use the stranded DS0 terminations that were delivered and terminated by Qwest but not ordered by the CLEC. Qwest (through Keith Rice) informed Eschelon that Qwest has no product offering to manage the process of filling in the DS0 termination holes and will not be developing one in the foreseeable future.

Qwest should provide CLECs with a process to use the unused but connected DS0 terminations to ensure efficient use of the network. The connections are wired and ready to go. Qwest should accept payment for each unutilized pair and activate each pair in TIRKS. This would provide Qwest with additional revenue and enable the efficient use of both Qwest and CLEC networks. Please modify Qwest’s processes to enable CLECs to purchase and use the unused DS0 terminations that resulted from Qwest’s decision to fill orders out of sequence when it changed its policy to require CLECs to purchase DS0 terminations in 100 block increments. Please identify any rate Qwest would propose to charge

Status History

Project Meetings

Open Product/Process CR 5527234 Detail

Description Of Change

This process creates customer-affecting problems. In many cases, the "hard hold" fails to work as intended, and the customer loses service completely. Because the service order has completed, it may be difficult to obtain the same facilities and OE to rebuild the customer in a timely manner. Even if the "hard hold" works as intended, the customer’s service can still be affected. For example, when a "hard hold" is used for an order for a customer with voice mail, the forwarding features are still functioning (because the "hard hold" holds the line translations from completing through RCMAC) but the mailbox portion of the customer’s voice mail is taken down (because the due date on the service order was not changed to reflect the hold). Qwest takes down the mailbox because, without a due date change, one group at Qwest does not know that the other has changed the date for completion of the order. The calls are forwarded, but there is no mailbox to receive them. This problem is not limited to voice mail and affects other areas, such as DSL. Qwest should stop using the "hard hold" and instead change the due date on the service order itself.

Status History

Project Meetings

Open Product/Process CR 5579338 Detail

Description Of Change

Status History

Project Meetings

Open Product/Process CR PC122701-1 Detail

Description Of Change

Status History

Project Meetings

Subject: CR PC122701-1 Resale DSL Conditioning Date: Mon, 28 Jan 2002 11:30:42 -0600 From: "Stichter, Kathleen L." To: tmead@qwest.com CC: "Johnson, Bonnie J." Todd, Here is an example of why Eschelon is requesting Conditioning on resale DSL. Eschelon sold a DSL to a customer. When we went to pre-qualify the results were, Loop does not qualify for Megabit Service: insertion loss is too high. The customer went to Qwest and ordered DSL through Qwest. When investigated we found that Qwest offered to provision a new line with DSL to see if the new line would qualify. The new line did qualify for DSL. Now the customer has 1 extra line that they do not need and will be removing. This could have been avoided if this CR were accepted. One of the existing lines could have been conditioned to handle the DSL. Please get this information to the Qwest SMEs assigned to this CR. Thanks

Clarification Meeting

2:00 p.m. (MST) / Wednesday 9th January 2002 PC 122701-1 Qwest to offer line conditioning to qualify a loop for Qwest resale DSL service

Attendees: Kathy Stichter / Eschelon Tina Shiller / Eschelon Todd Mead / Qwest Bob Shaheen / Qwest Nadine Jensen / Qwest

Review Requested (Description of) Change: - Kathy read out the description from the change request: "To provision DSL on a line, the line needs to meet certain qualifications. These qualifications include but are not limited to loop length, insertion loss, no bridge taps and no load coils. Currently a significant number of 1FB POTS lines ordered do not qualify for Qwest resale DSL. At this time Qwest does not offer line conditioning to qualify a line for Qwest resale DSL. Eschelon asks Qwest to offer line conditioning so more loops qualify for Qwest resale DSL." - Bob qualified that you can have bridge tap on a DSL line, it just causes a loss of signal strength - Kathy stated that if there is anything stopping DSL going on the line they want to be able to order line conditioning up front. - This request is for a product that currently does not exist. It is not just something not available for Resale.

Areas Impacted: Pre-Ordering, Provisioning

Products Impacted: Resale DSL

Confirm Right Personnel Involved: Freddi Pennington is the owner of this CR. Todd will inform Freddi.

Identify/Confirm CLEC’s Expectation: New process or product

Establish Action Plan: Eschelon may present this CR at the January CMP meeting (01/16/02). General Clarification by the entire CLEC community will take place at the February CMP meeting (02/20/02) and Qwest will provide a response at the March CMP meeting (03/20/02). Freddi 03/20/02

CenturyLink Response

February 25, 2002

Kathy Stichter ILEC Relations Manager Eschelon Telecom Inc. 720 2nd Avenue South, Suite 1200 Minneapolis, MN 55402

SUBJECT: Qwest’s Change Request Response - CR # PC122701-1 Resale DSL Conditioning

Eschelon requested that Qwest provide a DSL line conditioning service for resale.

Qwest DSL product management does not offer DSL line conditioning service and it is not available to retail end-user subscribers.

Qwest does not offer for resale a service that it does not provide its own retail end-user subscribers.

Sincerely,

Freddi Pennington Resale/PAL/UNE-P Group Manager Qwest

Cc: William Campbell, Director Structure & Loops, Qwest Jasmin Epsy, Senior Director Product Marketing, Qwest Teresa Taylor, Senior Vice President Product Management, Qwest

Open Product/Process CR PC122701-2 Detail

Description Of Change

Status History

Project Meetings

2:00 p.m. (MST) / Tuesday 8th January 2002 PC 122701-2 Qwest to allow 1FB POTS & DSL on one LSR

Attendees: Kathy Stichter / Eschelon Todd Mead / Qwest Jeff Cook / Qwest Brett Fesler / Qwest Nadine Jensen / Qwest Janean Van Dusen / Qwest

Review Requested (Description of) Change: Kathy read out the description from the change request: Currently to order a new line with Qwest resale DSL, Eschelon needs to submit 2 LSRs. One LSR for the POTS line and a subsequent LSR for the DSL. When 2 LSRs are issued Qwest does not know that the POTS line will eventually become DSL so facilities to provide a DSL capable loop are not taken into consideration. If Qwest allowed Eschelon to issue 1 LSR for the 1FB POTS line and the DSL then Qwest could provision the loop with DSL capable facilities, if available. Eschelon asks Qwest to allow 1FB POTS and DSL on 1 LSR. There were no questions from Qwest.

Areas Impacted: Ordering, Provisioning

Products Impacted: Resale, UNE-P, Other (DSL)

Nadine is the owner of this CR. Nadine agreed she is the right person to provide the response to this CR, with the assistance of the other Qwest people on the call.

Identify/Confirm CLEC’s Expectation: - Qwest to allow Eschelon to submit one LSR for both the 1FB POTS and the Qwest resale DSL. - If Qwest accepts this CR, then Eschelon expects to see the resulting process documented and the appropriate level of training given to Qwest personnel.

Establish Action Plan: Eschelon may present this CR at the January CMP meeting (01/16/02). General Clarification by the entire CLEC community will take place at the February CMP meeting (02/20/02) and Qwest will provide a response at the March CMP meeting (03/20/02).

CenturyLink Response

February 27, 2002

Kathy Stichter ILEC Relations Manager Eschelon Telecom Inc. 720 2nd Avenue South, Suite 1200 Minneapolis, MN 55402

SUBJECT: Qwest’s Change Request Response - CR # PC122701-2 Qwest to allow 1FB POTS and DSL on one LSR

The original request from Echelon is that Qwest accept a single LSR for both the local service line (POTS) and DSL service at the same time.

Upon clarification, Eschelon is now requesting that Qwest: - Manually analyze the available facilities at the location - Choose a facility that supports DSL (if available) - Deploy local service (POTS) on a line that will support DSL

Qwest does not offer this type of pre-analysis of a facilities to its retail end-user subscribers. Qwest currently uses a mechanized system that qualifies a facilities based on certain metrics and the facility must already be in place in order to see if it is engineered to support DSL service.

In order for Qwest to do the requested analysis upfront, Qwest would need to remove the order from the automatic facility assignment flow and manually assign facilities to the local service line (POTS). Qwest has made extensive investments in the loop qualification tool and process. Qwest has made the business decision not to manually assign POTS facilities in order to allow the addition of DSL for retail end-user subscribers. This service is not a retail service and is not available for resale.

Sincerely,

Freddi Pennington Resale/PAL/UNE-P Group Manager Qwest

Cc: William Campbell, Director Structure & Loops, Qwest Jasmin Epsy, Senior Director Product Marketing, Qwest Teresa Taylor, Senior Vice President Product Management, Qwest

Open Product/Process CR PC122801-1 Detail

Description Of Change

Eschelon asks Qwest to document, distribute and train an adhered to process to unlock numbers from the 911 data base so Intrado can apply the new records sent to them by Eschelon. If a current process exists, Eschelon asks to see the process and asks Qwest to improve the process or ensure adherence to the process.

Status History

Project Meetings

Date: January 9, 2002, 12:00 (MT) Place: Conference Call Location: 877-564-8688 Subject: PC122801-1, Qwest to document, distribute and train an adhered to process to unlock numbers for 911

Attendees: Ric Martin, Qwest Lorna Dubose, Qwest Joan Wells, Qwest Kathy Stichter, Eschelon Amanda Owens, Eschelon

Introduction of Attendees Introduction of the participants on the Conference Call were made and the purpose of the call discussed

Review Requested (Description of) Change Eschelon reviewed the requirements of their CR. Lorna asked if Eschelon had any performance measurements on the percentage of 755 Errors and 760 Cancellations they were getting. Eschelon advised that they didn’t have any measurements. Amanda indicated that they would only receive one 755 Error message and it would remain until the number was unlocked or it went to 760. They do not get continuous 755 Error messages for the same number. Amanda indicated that they started with many error messages from 2 years ago. They have reduced that number. She has been working with Qwest'’ 911 database manager and that has worked a little. She indicated that she had a recent e-mail from Intrado including a new 760 report. Amanda will send report to Lorna Dubose. The report indicated that there were other carriers on the report other than Qwest. The group was unsure who was responsible for the other carriers. Qwest will look into this. Joan indicated that Qwest had a recent clarification call on the process and indicated that it was working for the other CLECs. She explained that per commission ruling, Qwest is required to hold the order until 11:59 the next business day. Amanda indicated that they send their records to Intrado 2 days before the Due Date. This would explain why Eschelon would receive 755 Error notices, which would remain for 4 days. Eschelon stated that they understood that Intrado issued the database, but they thought Qwest owned the database. Qwest will advise if they own the 911 database and what the control is. Joan advised that there is a current 911 process on the PCAT. There is a 911 LNP link in the process. Amanda indicated that she had the process. Kathy will review the process and advise whether they understand the requirements. Qwest will look into their action items and check with their 911 database manager on the process of the 911 database management. Eschelon will review the process.

Confirm Areas & Products Impacted The products listed on the CR referenced 911. Qwest advised that this was primarily LNP. Qwest will update the CMP database. . Confirm Right Personnel Involved Qwest had the appropriate SMEs involved. It was confirmed that Lorna Dubose would be the owner with Joan’s support.

Identify/Confirm CLEC’s Expectation Qwest confirmed that there was a process. Eschelon is to review and comment Qwest and Eschelon are to collectively review why the 760 numbers are not getting unlocked.

Identify any Dependent Systems Change Requests There is no corresponding System CR

Establish Action Plan (Resolution Time Frame) Qwest and Eschelon to review their action items and get back to discuss findings.

CenturyLink Response

Eschelon Communications Kathleen Stichler ILEC Relations Manager

SUBJECT: Qwest’s Change Request Response - CR # PC122801-1 Qwest Process to Unlock E911 Records

This letter is in response to your Change Request PC122801-1 requesting that Qwest document, distribute and train an adhered to process to unlock numbers for E911.

Eschelon and Qwest conducted a clarification meeting to review Qwest’s current process for unlocking E911 records. During this meeting, Qwest shared with Eschelon that the migrate unlock record should be issued to Intrado, on the customer due date, once the migrate as been completed at NPAC. If the migrate record is issued prior to the customer due date, a 755 or 760 error will be generated.

In addition to Qwest’s existing process, effective, February 25, 2002, Qwest moved forward with implementing the new NENA recommendations. These recommendations require the old provider to unlock the E911 record once a validation has been completed with the NPAC. Therefore, when the CLEC sends the migration record to Intrado, on the customer due date, the NPAC activation should be complete also. Qwest will perform a validation to the NPAC and unlock the customer record once the CLEC migration record is received at Intrado. Intrado will distribute a report to the CLEC identifying any discrepancies.

The E911 Product Catalog has been updated to reflect this enhancement, as well as the appropriate personnel trained.

Again, thank you for partnering with Qwest.

Sincerely,

Lorna Dubose LNP Product Manager Qwest

Open Product/Process CR 5322587 Detail

Description Of Change

Status History

Project Meetings

Open Product/Process CR PC120301-2 Detail

Description Of Change

Status History

Project Meetings

Kathleen Stichter, Eschelon Renee Lernes, Eschelon Karen Kraas, Qwest Laurel Burke, Qwest Barry Orrel, Qwest Peter Wirth, Qwest

1.0 Introduction of Attendees Attendees introduced.

2.0 Review Requested (Description of) Change {review long description from change request, confirm with all parties there is agreement on the change requested} Eschelon presented the CR. Eschelon requested that Qwest provide final Alternate Point of Termination (APOT) 15 day prior to the collocation Ready for Service (RFS) date (additional detail in CR). This was requested in order to allow the CLEC to conduct provisioning on advance of the RFS date & provide customer service on the RFS date.

3.0 Confirm Areas & Products Impacted {read from change request, modify if needed} “Collocation” confirmed as appropriate. “Physical” & “ICDF Collocation” boxes under “Collocation” identified during conference call.

4.0 Confirm Right Personnel Involved {ensure the Qwest SME can fully answer the CLEC request. Confirm whether anyone else within Qwest has been involved with this issue, or whether we need to bring anyone else in} N/A Qwest & Eschelon confirmed appropriate personnel were in attendance.

5.0 Identify/Confirm CLEC’s Expectation {Identify specific deliverables from CLEC – what does Qwest have to do in order to close this CR? (in measureable terms ie provide a documented process, change a process to include training etc)} Qwest to evaluate CR. During the January 2002 Monthly P&P CMP Meeting, a CLEC community clarification session will be conducted with Qwest providing potential options for addressing the CR.

6.0 Identify any Dependent Systems Change Requests {Note any connected CRs and the potential impacts} N/A PC120301-3.

CenturyLink Response

Kathy Stichter ILEC Relations Manager Eschelon Telecom Inc

SUBJECT: Qwest Change Request Response - CR PC 120301-02 Develop, distribute and train and adhered to process to provide CLECs with final APOT information at least 15 days before RFS

This letter responds to your CLEC Change Request Form, number PC120301-2 dated November 30, 2001 - Develop, distribute and train an adhered to process to provide CLECs with final APOT information at least 15 days before RFS. Eschelon requested this change so that "CLECs can place orders in a timeframe that enables them to actually utilize their collocation space on the RFS date." The change request provided one example of final APOT information being made available by Qwest days after the payment.

Qwest distributes the preliminary Alternate Point of Termination (APOT) fifteen (15) days prior to the Ready for Service (RFS) date. Final APOT is provided to the CLEC customer on the RFS date, provided the final 50% payment is received in full. The CLEC may then use the preliminary APOT to place service orders. The ordering process does not differ for a preliminary or a final APOT.

[Note: The order may not be turned up prior to the collocation RFS date, and receipt of final payment for the collocation must be received. When the orders are placed within the provisioning timeframe for the service, such service may be utilized and available to the CLEC on the date of the collocation RFS.]

During on-site completion of actual install work there may be changes to the engineering design work package or actual cables and blocks. Therefore, Qwest needs to continue to provide preliminary APOT 15 days prior to RFS with final APOT delivered on RFS and receipt of full payment.

Eschelon’s example dealt with an Interconnection Distribution Frame (ICDF) collocation. They noted their final APOT was provided several weeks following the final payment. During the walk-through with the State Interconnect Manager, discrepancies were noted that required engineering changes. Those changes were implemented and a revised final APOT provided to the customer at that time. However, the final payment was received prior to this implementation. Since work on the discrepancies was progressing, the final APOT was held until that work completed.

Sample data supports the decision not provide a final APOT 15 days prior to RFS. Forty (40) jobs were completed in 2001 for Eschelon. Seven and a half percent (7.5%) of APOT data were changed between the time of issuance of the preliminary APOT and tender of the final APOT. Also, 55% of the 40 jobs completed significantly ahead of the RFS date such that only a final APOT was issued enabling Eschelon to order services and provide their customers with service on or before the scheduled RFS date.

Sincerely,

Robert Mohr Product Manager Qwest

Cc: William Campbell, Qwest

Open Product/Process CR PC120301-3 Detail

Description Of Change

Example #1 (Labeling of terminations in the CO(s) does not match the APOT information). A DS1 order could not be turned up due to incorrect labeling at the CLEC DS1 Spot Frame. APOT information indicated pairs 1-56 belonging to Eschelon, however, Qwest labeling at the Central Office indicated Pairs 1-28 + 33-60 belonging to Eschelon. Eschelon submitted the pending T1 order with APOT 29 and the order was accepted, indicating a labeling error at the Central Office. Errors such as this confuse the Eschelon Operations group and ultimately cause delays until the labeling issue is resolved/confirmed.

Example #2 (Information on Final APOT sheets sent to Eschelon does not match information loaded in TIRKS/IMA). Eschelon could not process DS0 orders due to incorrect information listed on the Final APOT sheet for a collocation. Eschelon submitted orders under one DS0 Cable name (as indicated on the Final APOT sheet). Qwest database was loaded with another DS0 Cable name. Consequently, Qwest was not recognizing orders issued with the DS0 Cable name identifier as the information did not exist in Qwest's systems. Eschelon helped to resolve the matter by sending its own technicians to the Central Office to verify the labeling of the DS0 Blocks. Eschelon discovered that Qwest labeled the APOT information on the Vertical Blocks differently then indicated on the APOT sheet. Qwest subsequently issued a corrected APOT sheet, two days after the problem was first discovered.

Example #3 (Information on Final APOT sheets sent to Eschelon does not match information loaded in TIRKS/IMA). Qwest rejected orders for an Eschelon Collocation due to what was perceived as an incorrect CLLI Code. Qwest informed the Eschelon Provisioning Group that the CLLI Code Eschelon used was incorrect. Qwest records indicated a different CLLI Code and would not process orders despite the fact that Eschelon used the CLLI Code identified on the Fianl APOT sheet on its orders. A service manager at Qwest helped resolve the issue and explained that the problem was due to internal miscommunication within Order Validation.

Status History

Project Meetings

Kathleen Stichter, Eschelon Renee Lernes, Eschelon Karen Kraas, Qwest Laurel Burke, Qwest Barry Orrel, Qwest Peter Wirth, Qwest

1.0 Introduction of Attendees Attendees introduced.

2.0 Review Requested (Description of) Change {review long description from change request, confirm with all parties there is agreement on the change requested} Eschelon presented the CR. Eschelon requested that Qwest provide accurate final Alternate Point of Termination (APOT) data to match TIRKS/IMA databases for correct provisioning of circuits (additional detail in CR). This was requested in order to allow the CLEC to conduct provisioning on advance of the RFS date & provide customer service on the RFS date.

3.0 Confirm Areas & Products Impacted {read from change request, modify if needed} “Collocation” confirmed as appropriate. “Physical” & “ICDF Collocation” boxes under “Collocation” identified during conference call.

4.0 Confirm Right Personnel Involved {ensure the Qwest SME can fully answer the CLEC request. Confirm whether anyone else within Qwest has been involved with this issue, or whether we need to bring anyone else in} Qwest & Eschelon confirmed appropriate personnel were in attendance.

5.0 Identify/Confirm CLEC’s Expectation {Identify specific deliverables from CLEC – what does Qwest have to do in order to close this CR? (in measureable terms ie provide a documented process, change a process to include training etc)} Qwest to evaluate CR. During the January 2002 Monthly P&P CMP Meeting, a CLEC community clarification session will be conducted with Qwest providing potential options for addressing the CR.

6.0 Identify any Dependent Systems Change Requests {Note any connected CRs and the potential impacts} N/A PC120301-2.

CenturyLink Response

Kathy Stichter ILEC Relations Manager Eschelon Telecom Inc

CC: Mary Retka, Qwest

This letter responds to your CLEC Change Request Form, number PC120301-3 dated November 30, 2001 – Implement an adhered to process to provde CLECs with accurate APOT information. Specifically, Eschelon asked Qwest to implement a process and procedure for accurate APOT numbering so that CLECs can be assured that they will be able to provide service without delay to their customers. The change request provided three examples of APOT information provided by Qwest and suggested that the process should include a requirement that Qwest personnel validate APOTs as they are entered into TIRKS.

Qwest previously committed and continues to commit to providing accurate Alternate Point of Termination (APOT) information. We also continue to commit to providing timely resolution of issues relating to information contained on the APOT. To this end, we revised and have implemented several internal processes to verify the accuracy of the APOT. Applicable process changes are addressed below in the context of the examples provided within the Change Request (CR).

- Example 1 describes a situation in which labeling of terminations in the Central Office did not match the APOT information. This job completed in April 2001 and the call to the APOT hotline occurred in November, seven months after the "Ready For Service" (RFS) date. Our investigation revealed that the State Interconnect Manager (SICM) and Eschelon representatives performed a walk through on this job; the APOT contained correct cable count pairs and matched the field cable count; the SICM identified where to connect their side of the terminations. The terminations were labeled correctly and TIRKS also reflects the correct cable count. However, the numbering associated with the jack locations did not match the locations identified on the APOT; for jobs other than ICDF collocations, the jack numbers do not appear on the APOT. Jack locations do not need to match the cable count numbers and in this case, the difference is apparently what caused confusion. This issue was resolved the business day after a call to the APOT hotline. In late June, early July 2001, CPMC personnel reevaluated their quality processes and implemented safeguards to ensure that correct information appears on the APOT; specifically, the state Project Manager is required to confirm that the APOT data matches TIRKS and that the DWP also matches the APOT. A process document (update issued 11/30/2001) reiterates that the Engineer must ensure that the actual installation is accurately reflected in both the APOT and the DWP. Additionally, Engineering revised its job aid on 8/28/2001 describing ICDF collocation engineering and its unique APOT in detail.

- Example 2 involved the inability of Eschelon to process DS0 orders based on incorrect TIRKS information. The APOT resulted from a job that completed in April but no call was made to the APOT hotline. There was a cable name error on the APOT; instead of an "s" the cable name contained a "d." The field and TIRKS correctly showed the "s," but there was a typographical error on the APOT. A revised final APOT was provided to Eschelon the morning of the second business day following the identification of the error to Collocation Project Management Center (CPMC) State Project Manager. Internal processes (updated 9/27/2001 and 11/30/2001) require the Engineer to verify the field installation information against the APOT, TIRKS, the design work package (DWP) as well as check any other affected engineering documents/systems for consistency. As changes are made and needs clarified (from sources such as the APOT hotline), engineering staff review and update the applicable job aids in addition to providing periodic training on issues, including APOT related ones, during monthly staff meetings. As indicated above, the CPMC State Project Manager is also required to manually check and validate that the APOT matches the parameters contained in the DWP. The CPMC audits compliance with this process on a monthly basis.

- Example 3 involved a rejection of orders because the CLLI code appeared to be incorrect on the final APOT. Upon notification of a building addition completion, Eschelon submitted an application for collocation space in the central office and was placed in the central office annex for which the addition had just been completed and for which a new CLLI had been assigned. The service center did not recognize the CLLI code associated with the collocation job (completed in April 2001) because it did not match the address or name of the central office on the order - a new name and physical address had been assigned to the building addition. However, the APOT, DWP and TIRKS were correct for the location of the collocation. The Account Service Manager was contacted and the situation explained sufficiently to allow the orders to process. Some unique situations will continue to arise and need to be addressed individually.

In summary, Qwest understands the concerns that result from order rejection, and has instituted the following measures to provide accurate APOT information:

- Internal process improvements (discussed above and) implemented by the Engineering, CPMC, and TIRKS organizations (effective July 2001);

- Qwest collocation engineering managers regularly provide training on and review of APOT job aids; and

- Continued operation of the "APOT Hotline" (refer to CR 5608156) to quickly and efficiently address any APOT discrepancies that may arise.

Qwest will continue to work with the CLEC community regarding APOT accuracy related issues.

Sincerely,

Laurel L. Burke Staff Advocate, Policy & Law Technical Regulatory Interconnection Planning

Open Product/Process CR PC120301-4 Detail

Description Of Change

Example #1 (Qwest needs to engineer the entire path (CLEC to CLEC) when the cross-connect is made through the Qwest ICDF). A CLEC to CLEC cross-connect was made with a third party in a Central Office. When the entire lineal footage of the DS3 Circuit was taken into consideration, the DS3 signal was not within ANSI loss level standards. Qwest contends that it will engineer the DS3 cable/signal from the Qwest ICDF to each separate Co-Provider but that it is not responsible for the complete circuit, although all elements involved. (i.e. BNC connectors, ICDF Cross-connect points, and DSX interfaces) contribute significantly to overall signal loss. Since Qwest provisions all three segments of the circuit, Qwest must provision the complete circuit in such a way that meets the ANSI standard.

Status History

Project Meetings

Kathleen Stichter, Eschelon Paul Hanser, Eschelon Michael Zulevic, Covad Bill Wycoff, Qwest Jeff Ferra, Qwest Laurel Burke, Qwest Peter Wirth, Qwest

1.0 Introduction of Attendees Attendees introduced.

2.0 Review Requested (Description of) Change {review long description from change request, confirm with all parties there is agreement on the change requested} Clarification was obtained from Eschelon & Covad for the subject CR. The following items were discussed: 1) Paul Hanser, Eschelon identified two (2) types of CLEC to CLEC connections in Qwest CO facilities: 1) direct connection (i.e., no routing through Qwest ICDF; and 2) connection through Qwest ICDF(s). Direct connections, in general, exhibit fewer problems and mainly concern cable lengths and re-generation concerns. Connections routed through a Qwest ICDF(s) usually involve larger Qwest CO facilities that may involve multiple floors and require more detailed assessments of circuit cable lengths, regeneration, ICDF connection losses, and other connector losses (i.e., BNC). Eschelon expressed concern that proper engineering and testing of the end to end portion of the Qwest furnished curcuit (i.e., cabling, regeneration (if required), all related connections) need to be conducted properly prior to "throwing the cables over the fence into the co-location areas." 2) Michael Zulevic, Covad concurred with Eschelon and also requested cable continuity testing and documentation for the Qwest provided portion of the circuit at the conclusion of the construction phase; along with possible collaborative testing during the test & turn-up phase. 3) William Wycoff, Qwest asked Eschelon what signal levels are being transmitted and received from their co-location areas. Paul Hanser, Eschelon indicated that maximum transmit and minimum receive are indicative of signal levels.

3.0 Confirm Areas & Products Impacted {read from change request, modify if needed} N/A. Discussed in previous clarification meeting.

4.0 Confirm Right Personnel Involved {ensure the Qwest SME can fully answer the CLEC request. Confirm whether anyone else within Qwest has been involved with this issue, or whether we need to bring anyone else in} N/A. Discussed in previous clarification meeting.

5.0 Identify/Confirm CLEC’s Expectation {Identify specific deliverables from CLEC – what does Qwest have to do in order to close this CR? (in measureable terms ie provide a documented process, change a process to include training etc)} Qwest to generate draft response for CMP Monthly Product & Process Meeting.

-

1:30 p.m. (MDT) / Friday 14th December 2001 Conference Call TEL: 877.564.8688 CODE: 6265401 PC120301-4 "Implement a process to insure Qwest adheres to ANSI Standard T1.102 and ANSI T1.104 for setting signal and loss level standards for DS3 cable length limitations" Clarification Meeting

Kathleen Stichter, Eschelon Renee Lernes, Eschelon Bill Kent, Eschelon Bill Wycoff, Qwest Jeff Ferra, Qwest Laurel Burke, Qwest Peter Wirth, Qwest

1.0 Introduction of Attendees Attendees introduced.

2.0 Review Requested (Description of) Change {review long description from change request, confirm with all parties there is agreement on the change requested} Eschelon presented the CR. Eschelon requested that the completed circuit provided by Qwest for CLEC to CLEC cross connect through a Qwest Interconnect Distribution Frame (ICDF) provide a signal level of no less than –4.7 dBm (additional detail in CR). Qwest is responsible for completing the cross connect circuit.

3.0 Confirm Areas & Products Impacted {read from change request, modify if needed} “Collocation” confirmed as appropriate. “Physical” & “ICDF Collocation” boxes under “Collocation” identified during conference call.

4.0 Confirm Right Personnel Involved {ensure the Qwest SME can fully answer the CLEC request. Confirm whether anyone else within Qwest has been involved with this issue, or whether we need to bring anyone else in} Qwest & Eschelon confirmed appropriate personnel were in attendance.

5.0 Identify/Confirm CLEC’s Expectation {Identify specific deliverables from CLEC – what does Qwest have to do in order to close this CR? (in measureable terms ie provide a documented process, change a process to include training etc)} Qwest to evaluate CR. During the January 2002 Monthly P&P CMP Meeting , a CLEC community clarification session will be conducted with Qwest providing potential options for addressing the CR.

6.0 Identify any Dependent Systems Change Requests {Note any connected CRs and the potential impacts} None.

CenturyLink Response

Kathy Stichter ILEC Relations Manager Eschelon Telecom Inc

SUBJECT: Qwest Change Request Response - Number PC120301-4 (December 3, 2001) – Implement a process to insure Qwest adheres to ANSI Standard T1.102 and ANSI T1.104 for setting signal and loss level standards for DS3 cable length limitations.

Qwest has responsibility to engineer network elements within its Central Offices (CO) in an efficient manner. Qwest has engineering criteria establishing DSX-N cross-connect fields that are in compliance with ANSI Standard T1.102 for setting signal and loss levels using cable length limitations, signal source level control, and signal regeneration. It is unclear how ANSI Standard T1.104 relates to the signal level question.

To minimize equipment, the ICDF is not engineered as a DSX-N level point. According to Technical Publication 77386 on Interconnection and Collocation, Chapters 5 and 15, the engineering requirement is to design through the ICDF to a DSX-N point when accessing unbundled offerings such as Unbundled Loops, Unbundled Dedicated Interoffice Transport, etc. This principle was established circa 1996 in FCC Docket 93-192.

The CLEC-to-CLEC Cross-Connection (COCC-X) offering is defined as the CLEC’s capability to order a cross-connection from its Collocation in a Qwest Premises to its non-ajacent Collocation space or to another CLEC’s Collocation within the same Qwest Premises at the Interconnection Distribution Frame (ICDF). This is accomplished by the use of the CLEC’s Connecting Facilty Assignment (CFA) terminations residing at the same ICDF and at the same service rate level.

Qwest is providing clarification for the following activities to address this request:

- CLEC ordering procedure for cross-connection; - Qwest engineering data exchange with the requesting CLEC(s) for the cross-connection; - CLEC to CLEC cross connection within the Qwest Central Office (CO); - ICDF connections, and regeneration installation; and - Verification testing.

CLEC Ordering Procedure

CLEC to CLEC cross-connections are ordered through the Qwest EXACT-PC system using the Access Service Request (ASR) form. This form is used for ordering Access and Local Network Interconnection Services. Qwest processes the ASR and determines a ready for service (RFS) date for the connection.

The requesting CLEC(s) is required to assess the need for signal regeneration prior to submittal of the completed ASR form. An engineering data exchange can be arranged through the Qwest Wholesale Collocation Project Manager (http://www.uswest.com/wholesale/clecs/escalations.html)

Qwest Engineering Data exchange with requesting CLEC(s)

The requesting CLEC(s) are required to know the cable types and lengths from their equipment to the ICDF(s) in order to assess the need for signal regeneration. The need for regeneration may arise when the distances between the CLEC’s collocation equipment exceeds twice the cable length limitation criteria (table) when connected through the ICDF. The total cable length limitation from signal source to sink, without a DSX-N point is nominally, two times the shown length.

Qwest will provide the requesting CLEC(s) the type and length of cable between their physical space and the ICDF. Each CLEC uses this information to design the span between their equipment. The design is done to determine any need for regeneration. Regeneration is typically at the ICDF.

[Table in Supplemental Information]

Given the probability of having cable lengths that total less than the maximums, it has been and is the CLEC’s responsibility to set any transmit attenuators in their equipment. Given the possibility that total cable lengths from the Collocation spaces through the ICDF are longer than the table allows, there is the opportunity for a CLEC to request regeneration by using a specific Network Channel Interface (NCI) code on their order. The NCI is chosen from Table 6-5 of Tech Pub 77386 using one that calls for regeneration. CLEC to CLEC cross connects occur between two CLECs within a Qwest CO and use jumper cables at the ICDF to complete the link. There is no assured DSX-N level point in the circuit.

Figure A below illustrates the situation where there is a single, ICDF cross-connect to complete a CLEC-to CLEC circuit that needs a regenerator. There is no DSX-N level point assured in this circuit.

[Figure A in Supplemental Information]

Figure A: Single ICDF Connection with Regeneration

ICDF connections and regeneration installation

Qwest, following receipt of the ASR will perform ICDF connections and regeneration functions. Equipment additions for regeneration (if no spares are available) will be initiated. Qwest completes these activities and conducts verification testing.

Verification testing

Verification testing of the cross-connection will be conducted to assure compliance with the ASR. Cooperative testing on circuits will be conducted with Qwest and requesting CLEC(s) technicians.

Qwest will coordinate with the requesting CLEC and schedule the testing of the completed cabling, ICDF connections and regeneration. CLEC(s) will be responsible to terminate cabling into their respective collocation equipment prior to the testing effort.

Although circuit testing is the responsibility of the CLECs, Qwest will provide technician support of CLEC to CLEC circuit testing efforts and provide trouble-shooting support, as necessary to successfully complete an ASR. Such testing shall confirm that ASR ordered circuits perform to service objectives in ANSI Standard T1.510, Network Performance Parameters for Dedicated Digital Services for Rates Up to and Including DS3. Clauses 8.2 and 8.3 describe DS1 and DS3 testing, respectively.

Sincerely,

William R. Wycoff Services Planning Qwest

CC: Bill Campbell, Qwest Barry Orrel, Qwest Gale Perko, Qwest Mary Retka, Qwest

Open Product/Process CR PC120301-5 Detail

Description Of Change

Status History

Project Meetings

Recent Service Request Activity If your service request was completed within the past 72 business hours contact Qwest's Interconnect Service Center (ISC) at 888-796-9087 for assistance. After researching the issue, the Customer Service Inquiry and Education Center (CSIE) will contact you regarding resolution of your issue.

3:30 p.m. (MDT) / Tuesday 18th December 2001 Conference Call TEL: 877.554.8688 CODE: 3269208 PC120301-5 “Process where once an escalation ticket is open and accepted that the issue stays with the CSIE group until the escalation is completed.” Name/Company:

Kathleen Stichter, Eschelon Bonnie Johnson, Eschelon Michelle Thacker, Qwest Peter Wirth, Qwest

1.0 Introduction of Attendees Attendees introduced.

2.0 Review Requested (Description of) Change {review long description from change request, confirm with all parties there is agreement on the change requested} Eschelon presented the CR. Eschelon requested that the process be confirmed as to handling of escalation tickets by CSIE. Eschelon expressed concern that once a trouble ticket is open, either the CSIE or repair group should handle through completion. Qwest confirmed with Eschelon that the ticket issue was a one-time occurrence.

3.0 Confirm Areas & Products Impacted {read from change request, modify if needed} Appropriate products & areas identified in CR.

4.0 Confirm Right Personnel Involved {ensure the Qwest SME can fully answer the CLEC request. Confirm whether anyone else within Qwest has been involved with this issue, or whether we need to bring anyone else in} Qwest & Eschelon confirmed appropriate personnel were in attendance.

5.0 Identify/Confirm CLEC’s Expectation {Identify specific deliverables from CLEC – what does Qwest have to do in order to close this CR? (in measureable terms ie provide a documented process, change a process to include training etc)} Qwest to evaluate CR. During the January 2002 Monthly P&P CMP Meeting, Qwest will provide an explanation of the escalation ticket occurrence; and provide clarification to the procedure to be followed by Qwest CSIE and Repair, as required.

CenturyLink Response

Kathy Stichter ILEC Relations Manager Eschelon Telecom Inc.

CC: Peter Wirth, Chris Siewert

This letter is in response to your CLEC Change Request Form, number PC120301-5 dated 11/30/01 - Process where once an escalation ticket is opened and accepted that the issue stays with the Customer Service Inquiry and Education (CSIE) group until the escalation is completed.

Qwest currently has a repair referral process in place, which provides for CSIE responsibility of a CLEC issue until resolution. The process provides procedures for handling an out of service condition when service order activity is involved. Your experience with the Qwest CSIE team was an isolated incident

The repair referral process addresses: review of the service order; matching service order entries against the CLEC issued LSR; issuing a service order to correct inaccurate entries on the service order if found; contacting internal departments for assistance; and follow up to ensure end user customer receives service, etc. The Qwest Service Delivery Coordinator (SDC) utilizes this process in processing escalation tickets.

I have confirmed with Chris Siewert - Team Leader Minneapolis CSIE, that process retraining occurred shortly after this incident for the entire CSIE team.

Sincerely,

Michelle Thacker Process Specialist

Open Product/Process CR 5608156 Detail

Description Of Change

Status History

Project Meetings

Kate, Here is Gerry's reply. Gerry is director of our switch operations. Please send this on to whoever needs to see it. Thanks Kathy Stichter ILEC Relations Manager Eschelon Telecom Inc Voice 612 436-6022 E-Mail klstichter@eschelon.com Kathy: When we assign a APOT/CFA we hard wire directly to the ICDF from our UE9000's. By having the APOT's in numerical sequence it allows for our LENS and the PM Terminal/Node Number(which is the APOT/CFA) to match up one to one. Example ...If I have an APOT of PST05 pair 12 for the Orchard CO it matches directly to LEN ORCH 0 00 1 12. By reusing the same numbering, i.e. ALT02 1-300 and PST05 1-300 the PM Terminal/Node Number will not match up with the LEN assignment. Thanks Gerry P.S. I can print out examples at a later date. Gerry

CenturyLink Response

Dear Ms. Powers:

I conducted a conference call with Eschelon on August 6th, 2001 at which time Qwest reviewed and responded to the letter written by myself, dated July 13, 2001. Eschelon clarified their request as, “Can they have sequential DS0 cable counts when they submit an augment for additional 100 DS0 cables.” They do not want 2 different naming conventions that have the same numbering system. Eschelon wants each new cable name to have its own associated cable counts.

According to Gerry Boeke from Eschelon, when they assign an APOT/CFA, they hard wire directly to the ICDF from their UE9000's. By having the APOT's in numerical sequence it allows for their LENS and the PM Terminal/Node Number, which is the APOT/CFA, to match up one to one (i.e...If you have an APOT of PST05 pair 12 for the Orchard CO it matches directly to LEN ORCH 0 00 1 12). By reusing the same numbering (i.e. ALT02 1-300 and PST05 1-300), the PM Terminal/Node Number will not match up with the LEN assignment.

Qwest does not believe it is a realistic expectation that cable counts always match exactly with LENS and Cable Counts. It will not and does not need to do so. Although administration would be easier for Eschelon, this is not practical on the part of Qwest. Existing working circuits are currently operating with different cable counts.

I have worked with John Waltrip, IOF EPOC methods manager, regarding this clarification. John’s response is as follows: “This issue is a scenario where a CLEC places an augment order to supplement facilities already in a given Central Office. The original facilities may have been built based on a cable naming convention that is now superseded (e.g. an original DS0 cable may have been called/counted as ALT02, 1-300); the new convention would carry a name like PDT05, 1-400 (for an additional 400 - or a total of 700). As a result, his response was that our practice is to not attempt a continuous count of old to new cable names for the same comparable circuit, (e.g. establishing the PDT05 with a count of 301-700) for the following reasons:

Our system has been in place for over a year and changes would mess-up live circuits. All CLECs are using this same system, so they rely on it as well. Other interfaces rely on this such as TIRKS, LFACS, etc. Sequence number is not critical when they place orders. The 1-300 gap in the PDT05 cable becomes an administrative fail point, not knowing that a PDT05, 1-300 count does not exist would cause the types of data base administration, as well as engineering and Service Delivery, problems that we have been cleaning up for the past 2 years. It is also possible that different types of DS0 cables go to different types of frame locations like line sharing. Different databases are also involved like LFACS for line sharing. If a customer has DS1 service it could be a UNE or Finished Service and can be configured with or without regeneration, all of these are now uniquely identified through our new naming convention. This in turn is desired to eliminate potential wiring errors and customer effecting trouble. Future mergers and acquisitions are causing conflicting databases also. The current new naming convention addresses and eliminates this problem. When two CLECs merge, each will have different cable counts. The TIRKS data base is universal in nature and tracks and monitors all circuits.

In summary, we acknowledge the needed additional work on behalf of individual CLECs to ensure accurate CFA is submitted on provisioning orders. We also acknowledge Qwest is committed to furnishing accurate information and timely resolution of issues as they occur in the provisioning and maintenance process relating to APOT information. For all the above mentioned reasons, we respectfully deny your request.

Sincerely

Stephen C. Nelson Collocation Group Product Manager

July 13, 2001

Ms. Lynne Powers Vice President, Eschelon Telecom

Dear Ms. Powers:

This letter is in response to your CLEC Change Request form number 5608156 dated June 13, 2001.

“Please provide a process and procedures for consistent APOT numbering. Qwest apparently uses different central offices (CO’s) for numbering APOT’s. This leads to problems when, for example, a typist at Qwest copies and pastes information for one CO and uses it for another. Also, there appears to be a discrepancy between physical number and the information reflected in TIRKS. To the extent that inconsistencies exist today, please develop and distribute a process for correcting those inconsistencies. The inconsistencies create serious problems for CLEC’s. For example: In one situation, the augment was labeled at the ICDF as starting with number1. But, the collocation term sheets and IMA (TIRKS) indicated that the augmented APOT starts at a higher number. Therefore, pending orders could not be completed to the APOT on which they were ordered.” Response: Our cable naming convention has undergone evolution over the last six years. When cable names were first assigned to the CLEC cables, the same cable names, e.g. ALT01, were often assigned to multiple CLEC’s. Despite that convention, their corresponding circuits could still be built and turned up since the unique cables were built in TIRKS with the CLEC’s unique CLLI code, e.g. HG5. CLLI codes are assigned by CLONES in order as CLEC’s come into an office, e.g. if a CLEC is the first physical in office A they would typically be assigned HG1, if they were the 8th CLEC they would be assigned HG8., etc. The current naming convention does assign unique cable names to CLEC cables in a given office. The unique name is established based on factors such as the type of collocation, type of circuit, and the 11 character of the unique CLLI codes assigned to the CLEC. (Attachment A is our current Cable Naming Convention) Cable names assigned using the old convention are not incorrect. They are simply not as descriptive as the current naming convention. Qwest explored the cost of converting the millions of cable names over to the new convention in place currently. The estimated cost was in the millions of dollars. Word documents would have to be cut along with new APOT’s etc. Therefore the decision was made to do several things on a going forward basis. One, through attrition the old cable names over time as changes occurred. Two, we would formalize our methods and train all personnel on the new cable naming configuration. Three, we would establish a “Hot Line” for CLEC’s to resolve immediate discrepancies through their Account Representative. Fourth, we would do a major data base reconciliation of all major cities. Fifth, each augment of a site would require a new APOT in its entirely including existing cable names. Qwest has a process for handling discrepancies in provisioning or repair traced to APOT forms. We have established an interval Hot Line to ensure items referred by CLEC customers to their Account Service Manager are responded to within 5 hours by an engineer for resolution. The engineer will identify and work to eliminate and resolve the issue. The engineer will report back to the account representative within 24 hours on the resolution or estimated resolution of the problem. All of these action items have associated methods and procedures which Qwest employees have been trained on. Attachment C and D of the Configuration Options Policy in the PCAT identifies our cable naming convention and samples of APOT’s by type of collocation. (I have attached sample copies of APOT’s )

In summary, although it is more difficult for Qwest and CLEC’s to administer cable names based on the different naming configurations, we do not plan to “convert” all past APOT’s. All existing APOT’s have correct information for submittal or provisioning and repair requests. The Hot Line will assist where discrepancies occur. Our methods have been standardized. We will work with any specific CLEC to resolve any items of concern regarding particular CLEC site APOT’s through your Service Manager.

Sincerely Stephen C. Nelson Collocation Group Product Manager

Open Product/Process CR 5608163 Detail

Description Of Change

Status History

Project Meetings

CenturyLink Response

Lynne Powers Vice President, Customer Operations Eschelon Telecom, Inc

CC: Mallory Paxton Matthew Rossi

This letter has been updated from the original July 13, 2001 written response to your CLEC Change Request Form #5608163 dated June 13, 2001.

Provide a process for resolving incorrect CSR information on either a Qwest or another co-provider’s CSR.

Response: Two options are available when the CSR is incorrect.

The CLEC can Check Manual Handling "Y" and explain in Remarks, for example, "Convert As Is. End User added fifth line 612-253-1234 6/29—CSR shows only four lines."

Open an escalation ticket with the Call Center. If this is the option selected, the CLEC should recognize that the ticket may still result in a manually-handled request, since Qwest may not be able to provide a current CSR in time to meet the CLEC’s needs.

These processes are in place today. They have been documented in the Internal Service Delivery M&Ps for the centers and have been communicated to all Qwest Center personnel. To ensure process compliance in all Qwest centers; a Multi-Channel Communicator (MCC) was released on July 13, 2001. The MCC reiterated the existing options as described above, to resolve incorrect CSR information. To further enforce this process, the MCC was redistributed to the Center Coaches on August 24, 2001

Sincerely,

Nancy J. Hoag Wholesale Product Manager

July 13, 2001

Lynne Powers Vice President, Customer Operations Eschelon Telecom, Inc

CC:Mallory Paxton Matthew Rossi

This letter is in response to your CLEC Change Request Form #5608163 dated June 13, 2001

Provide a process for resolving incorrect CSR information on either a Qwest or another co-provider’s CSR.

Response: Two options are available when the CSR is incorrect.

1. The CLEC can Check Manual Handling “Y” and explain in Remarks, for example, “Convert As Is. End User added fifth line 612-253-1234 6/29—CSR shows only four lines.”

2. Open an escalation ticket with the Call Center. If this is the option selected, the CLEC should recognize that the ticket may still result in a manually-handled request, since Qwest may not be able to provide a current CSR in time to meet the CLEC’s needs.

These processes are in place today, they have been documented in the Internal Service Delivery M&Ps for the centers, and have been communicated to all Qwest Center personnel.

Sincerely, Nancy J. Hoag Wholesale Product Manager

Open Product/Process CR 5608171 Detail

Description Of Change

8-29-01 Scope of request changed from UnBundled Loop to Resell (non design) features.

Status History

Project Meetings

Mallory talked with Coach at 1-800-223-7811. Not aware of problem Where Eschelon and Qwest resources not being able to view the same information.

Eschelon views IMA-GUI, Qwest views RCE-GUI (LMOS)

Agreement reached to have Eschelon provide trouble ticket data to Mallory when Eschelon/Qwest views are not the same. Problem is infrequent.

Monitor windows established to be August 31 to October 1st. If nothing is reported CR is subject to be closed.

Mallory to prepare Qwest response position paper to Matt Rossi target 8-31-01.

8-29-01 Conference call with Eschelon (Kathy Stichter); Qwest Unbundled Loop SME’s: Linda Hendricks, Catherine Garcia, Chris Henderson, Deni Toye, Russ Urevig Change Management: Richard Martin, Lyman McKee

Kathy Stichter reviewed CR request situation. Results: Determine CR was not addressing Unbundled Loop, Eschelon is satisfied with QCCC process. Problems are with Resale (Non –design) features. Request as written indicated problem was Un-bundled Loop. Kathy provided calls placed to 1-800-223-7811 option 1 are where the problem existed.

Identified Mallory Paxton and JoAnn Garromone as Qwest SME.

CenturyLink Response

Kathy Stichter Eschelon Telecom Inc CC : Matt Rossi This memo is a response to the CLEC Change Request CR 5608171 regarding discrepancies between the information available to Qwest repair personnel and that viewed by a CLEC in IMA. The CR was opened by Eschelon. In fact-finding sessions with Eschelon, it was determined that the problem is confined to calls to the AMSC at 1-800-223-7811, Option 1. The AMSC has reviewed the data visible to their repair personnel, who are looking at an RCE GUI which interfaces with LMOS (the Classic US West repair system). The information on the RCE GUI has been compared to the IMA information viewed by a CLEC calling the center and found to be the same, although the two systems are cosmetically different. Eschelon has no current examples of problems encountered when their employees called the AMSC and the AMSC could not see the same information as Eschelon was seeing. Eschelon has agreed to refer any such problems which occur in the next month to me so that I can research them with the AMSC and at the end of September to consider closing this CR if the problems are no longer occurring or have been resolved to their satisfaction.

Mallory Paxton Resale Process Specialist Email: mpaxton@qwest.com Phone: 206-345-3384

Open Product/Process CR 5608177 Detail

Description Of Change

Status History

Project Meetings

CenturyLink Response

This letter is in response to the following CLEC Change Request Forms #5263137, dated December 1, 2000 and #5608177 and #5608353, dated June 13, 2001. All of these Change Requests pertain to the CLEC to CLEC Migration process. The revised process was released via the Co-Provider Industry Change Management Process (CICMP) on May 25, 2001.

Re-use of facilities for CLEC to CLEC carrier changes, improving the CLEC to CLEC reuse of facilities process and to ensure nondiscrimination.

Response: The Qwest Release Notification Forms #5393537 (CLEC Unbundled Loop to CLEC Unbundled Loop), #5393543 (CLEC Unbundled Loop to CLEC Resale), and #5467108 (CLEC LNP with Unbundled Loop to CLEC Unbundled Loop) Revision B, released on May 25, 2001, noted changes in the Pre-Order section that the requirement to obtain the Circuit Identification Number from the OLSP” is optional. Both Eschelon and Allegiance provided Qwest with examples of orders that were rejected by Qwest due to no Circuit Identification Number provided. After gap analysis, it was determined that additional training of Qwest Service Center personnel and updates to Service Delivery M&Ps were required. The following measures have been implemented:

An updated Multi Channel Communicator (MCC) New or Changed Information Procedure was issued on July 9, 2001. Issued to target Qwest internal personnel in the Wholesale Customer Care, Customer Service, Error Group, Held Order/Escalation, Order Processing and Order Resolution organizations. Topic of the MCC: CLEC to CLEC Migration of an Unbundled Loop and Unbundled Loop to other products. CLEC to CLEC Migration is defined as; unbundled to unbundled, unbundled to resale, unbundled to Centrex resale. Emphasis placed on processing orders without circuit ids (ECCKT’s) on LSR requesting migration. States included in this communication are; AZ, CO, IA, ID-N, ID-S, MN, MT, ND, NE, NM, OR, Outside 14 State Region, SD, UT, WA and WY. All internal job aids and on-line support documentation have been updated. Qwest Service Center specific training sessions are currently in progress for both center coaches and center personnel. The training will be on going to ensure process compliance.

Sincerely

Nancy J. Hoag Qwest Wholesale Product Team

Open Product/Process CR 5371475 Detail

Description Of Change

For POTs resale and on the design side for DSOs, the due date can be changed in less than 5 days, provided that the change is not design-affecting. Qwest should change its process to similarly allow due date changes in less than 5 days (when not design-affecting) for unbundled loop orders.

Status History

Project Meetings

Introduction of participants on the Conference Call was made. The purpose of the call was to discuss Qwest’s draft response dated September 4, 2001 and Eschelon’s e-mail comments. Review of Response N Hoag reviewed the Change from 5 days to 3 days. B Johnson indicated that there would be a rare occasion where they might need less than 3 days. She provided the example of when a customer was moving lines and they couldn’t make Friday due to equipment, or other issues. She would like Qwest to work with them to improve the date from the improved 3 days. Bonnie indicated that a VP expedite could be difficult to obtain. N Hoag explained that the primary reason that Qwest could not commit to improve on the days was due to CO and Technician resource were typically committed between those days. C Siewert advised that, in these situations, Eschelon could look into switching out an existing order. If that can’t be done, then they would have to move to VP Escalation. Eschelon asked how DS0 orders were handled. C Siewert advised that they would call in for available time and if none were available, they would move to VP Escalation. B Johnson indicated that the VP Escalations have improved. They will play the new process by ear and attempt to get times improved as required. Eschelon asked if, on POP Orders, the customer was willing to pay for overtime, could Qwest accommodate the request. C Siewert advised that Saturday is a normal workday and didn’t believe OT could be accommodated. C Siewert asked B Johnson to provide the Order No. they were looking to have Monday and she will investigate. B Johnson advised that they will go through the escalation process and we could close this CR. K Stichter agreed. N Hoag will issue the draft response formally to M Rossi for issuance to Eschelon.

09/07/2001 08:56:12 AM Nancy Hoag on

To: klstichter@eschelon.com cc: lsteckl@qwest.com

Subject: CR 5371475

Kathy,

Please review the attached letter. Under the "Qwest Response" bullet, you will see that the processes for Retail and Complex Resale DSO's were included:

These are the same Methods & Procedures used by Qwest Service Delivery for all Designed Services, including Wholesale DSO. For due date changes on Qwest Wholesale POTS as well as Qwest Resale and Retail Non Designed Services, Appointment Scheduler is used to determine the next available appointment time.

As for the second issue, I plan on meeting with Steve Sheahan, Toni Dubuque and Bonnie Johnson to discuss how Qwest can best accommodate Eschelon's needs with respect to critical ICB escalations. I consider this issue as an action item, separate from the CR that was submitted. If you could provide me Bonnie's email address, I will forward the information once the meeting has been scheduled.

Nancy J. Hoag Wholesale Products/Unbundled Loop

-- 9/6 e-mail from K Stichter

Lynn, We understand the Response. What we are looking for are 2 items that Eschelon previously requested and we thought were agreed to by Nancy Hoag. They are: 1. Documentation stating the Retail DSO and Complex Resale DSO process for DD changes that do not affect the design. 2. Notice of communication with Toni Dubuque on how Eschelon would escalate any critical ICB issues. We look forward to seeing this documentation. Thanks.

Kathy Stichter ILEC Relations Manager Eschelon Telecom Inc Voice 612 436-6022 E-Mail klstichter@eschelon.com

From: Lynn Stecklein [SMTP:lsteckl@qwest.com] Sent: Tuesday, September 04, 2001 3:41 PM To: Stichter, Kathleen L. Cc: rhmart2@qwest.com; Jerri Brooks; Joann Garramone Subject: CR5371475 - Allow non design affecting due date changes for unbundled loop orders

Hello Kathy, Attached you will find the Qwest Response for the above Change Request. Please confirm via E-Mail if this response meets your needs or if we need to set up a walk through to discuss the issue further. Thanks, Lynn 303 294-1664

CenturyLink Response

CC: Russ Urevig Matthew Rossi

This letter is in response to your CLEC Change Request Form #5371475 dated February 1, 2001.

Change Request: Allow non design-affecting due date changes for unbundled loop orders. At present, for unbundled loop orders, Qwest imposes a 5-day interval for a supplemental order, even if the only change is to move out the due date. For example, a CLEC’s customer may have scheduled an appointment for a Friday. On Thursday, the end-user customer notifies the CLEC that Friday will no longer work, and the end-user customer asks to change the date to Monday instead. Under Qwest’s current policy, the CLEC must deny the customer’s request, because Qwest will impose a 5-day interval. With that interval, the earliest date available to the end-user customer will be the following Thursday. This is true even thought the change does not affect design, and the date is pushed out (not moved up). For POTs resale and on the design side for DSOs, the due date can be changed in less than 5 days, provided that the change is not design-affecting. Qwest should change its process to similarly allow due date changes in less than 5 days (when not design-affecting) for unbundled loop orders.

Qwest Response:

Per the Wholesale Unbundled Loop Methods & Procedures for Qwest Service Delivery, due date changes have a minimum 3-day interval. If a shorter than 3-day interval is required by a CLEC, they must follow the attached escalation guidelines as provided by your Service Manager.

This change was submitted via the Qwest Release Notification process, Log # PCRN061901-1, on June 19, 2001 by Russ Urevig

These are the same Methods & Procedures used by Qwest Service Delivery for all Designed Services, including Wholesale DSO. For due date changes on Qwest Wholesale POTS as well as Qwest Resale and Retail Non-Designed Services, Appointment Scheduler is used to determine the next available appointment time.

Qwest is unable to further reduce the due date change intervals for the Unbundled Loop Product, due to Central Office and Field Technician load and resource constraints on Designed Service orders.

Sincerely,

Nancy J. Hoag Wholesale Product Team

August 13, 2001

Wholesale Product Marketing

Lynne Powers Eschelon Telecom Vice President, Customer Operations

CC: Russ Urevig Matthew Rossi

This letter is in response to your CLEC Change Request Form #5371475 dated February 1, 2001.

Change Request: “Allow non design-affecting due date changes for unbundled loop orders. At present, for unbundled loop orders, Qwest imposes a 5-day interval for a supplemental order, even if the only change is to move out the due date. For example, a CLEC’s customer may have scheduled an appointment for a Friday. On Thursday, the end-user customer notifies the CLEC that Friday will no longer work, and the end-user customer asks to change the date to Monday instead. Under Qwest’s current policy, the CLEC must deny the customer’s request, because Qwest will impose a 5-day interval. With that interval, the earliest date available to the end-user customer will be the following Thursday. This is true even thought the change does not affect design, and the date is pushed out (not moved up). For POTs resale and on the design side for DSOs, the due date can be changed in less than 5 days, provided that the change is not design-affecting. Qwest should change its process to similarly allow due date changes in less than 5 days (when not design-affecting) for unbundled loop orders.”

Qwest Response:

Per the Wholesale Unbundled Loop Methods & Procedures for Qwest Service Delivery, due date changes have a minimum 3-day interval. If a shorter than 3 day interval is required by a CLEC, they must follow the escalation guidelines.

This change was submitted via the Qwest Release Notification process, Log # PCRN061901-1, on June 19, 2001 by Russ Urevig

These are the same Methods & Procedures used by Qwest Service Delivery for all Designed Services, including Wholesale DSO. For due date changes on Qwest Wholesale POTS as well as Qwest Resale and Retail Non-Designed Services, Appointment Scheduler is used to determine the next available appointment time.

Qwest is unable to further reduce the due date change intervals for the Unbundled Loop Product, due to Central Office and Field Technician load and resource constraints on Designed Service orders.

Sincerely,

Nancy J. Hoag Wholesale Product Team

Open Product/Process CR 5432820 Detail

Description Of Change

Status History

Project Meetings

Tuesday, August 28, 2001, Walk through Meeting Attendees: Michelle Spraque - McLeod, Peggy Esquibel-Reed, Todd Mead, and Irene Haskins/Qwest CLEC Expectations: McLeod would like Qwest to perform a mass update on the SAG files to correspond with the LEC records, or that the LEC records are revised to match the SAG address files. Mcleod agreed to close the CR and open another to address the following questions: During the address validation process via EDI, when performs an AVQ Hit, SAG address is returned. When performs a CSRQ Hit, the address from the CSR is returned. When the ISC gets an order from a CLEC, does the ISC use the address from the SAG or from the CSR? Which is the correct data source to use? Can the CLEC use just one of these data sources instead of both? Does the ISC use the SAG or the MSAG (911 address)? Which should be used?

Wednesday, August 15, 2001, CLEC CMP Meeting Product & Process. Lynne Powers questioned how SAG records get updated. Jeff Thompson advised that he wasn't sure how Telcordia issues updates, but Qwest can't get Telcordia to utilize Qwest's database. Jeff indicated that he would do some research on finding out how to get updates to Telcordia for their database. Mcleod provided Michelle Sprague as their contact at 319-790-7402.

CenturyLink Response

Michelle Sprague OSS Manager, McLeod USA

This letter is in response to the following CLEC Product & Process Change Request Form #5432820.

Request:

Not getting an appropriate match in SAG, during the address validation process. The LEC record address is being used in the attempt to validate against SAG, but the SAG records do not match the LEC records. Requesting that Qwest performs a mass update on the SAG files to correspond with the LEC records, or that the LEC records are revised to match the SAG address files.

Qwest agreed to investigate and report on what the process was for updating the SAG.

Qwest Response: * SAG is a Telecordia product. * Qwest is not able to modify the SAG and will not change the LEC. * The CLEC SAG book is a hybrid, it’s a Telecordia product and is an extract of the PREMIS database. It is created monthly. The CLEC SAG takes the QWEST SAG and additional information is extracted from the database and concatenates the two. Items not appropriate are not extracted and an item such as an NPA wire center that isn’t in the regular SAG book is added. * Qwest process for updating the SAG: - The Address Management Center’s are responsible for the data in PREMIS. Any service order fall-out or addresses that need to be updated, they are the group that does the work. - Should the CLEC find an address range that is incorrect, the CLEC calls interconnect and give’s them that information. - Interconnect contacts the AMC. - The AMC verifies with the appropriate county to make sure is valid and if it is, they update the database. - The following months extract will contain the new information. - Data is only extracted or updated once a month.

Jeffery L. Thompson Director, Information Technologies

Open Product/Process CR PC032801-2 Detail

Description Of Change

Status History

Project Meetings

CenturyLink Response

Lynne Powers Vice President, Customer Operations Eschelon Telecom, Inc

CC: Russ Urevig Matthew Rossi

This letter is in response to your CLEC Change Request Forms, numbers PCCR032801-2 and PCCR032801-3 dated March 26, 2001.

* "Advance notice of circuit identification changes. A problem arises when Qwest changes the circuit id after assigning it to a CLEC but without notification to the CLEC. Qwest should develop a process for notifying other carriers when circuit id information is changed. Inaccurate circuit information should not delay CLEC orders and cutovers."

* Response: The existing process used in centers today states: "Anytime a change is made to a CLEC request, including changing the circuit ID (identifier), SBN (subscriber billing number), due date or specified appointment time, and the changes are NOT requested by the CLEC, a "new" FOC must be issued and the changes identified in the remarks of the new FOC."

To ensure process compliance, a MCC (Multi Channel Communicator) was re-distributed on July 2, 2001, to all centers in AZ, CO, IA, ID-N, ID-S, MN, MT, ND, NM, OR, Outside 14 State Region, SD, UT, WA, and WY.

Sincerely,

Nancy J. Hoag Wholesale Product Manager

Open Product/Process CR PC032801-3 Detail

Description Of Change

Status History

Project Meetings

CenturyLink Response

Lynne Powers Vice President, Customer Operations Eschelon Telecom, Inc CC:Russ Urevig Matthew Rossi

This letter is in response to your CLEC Change Request Forms, numbers PCCR032801-2 and PCCR032801-3 dated March 26, 2001.

“Advance notice of circuit identification changes. A problem arises when Qwest changes the circuit id after assigning it to a CLEC but without notification to the CLEC. Qwest should develop a process for notifying other carriers when circuit id information is changed. Inaccurate circuit information should not delay CLEC orders and cutovers.”

Response: The existing process used in centers today states: “Anytime a change is made to a CLEC request, including changing the circuit ID (identifier), SBN (subscriber billing number), due date or specified appointment time, and the changes are NOT requested by the CLEC, a “new” FOC must be issued and the changes identified in the remarks of the new FOC.”

To ensure process compliance, a MCC (Multi Channel Communicator) was re-distributed on July 2, 2001, to all centers in AZ, CO, IA, ID-N, ID-S, MN, MT, ND, NM, OR, Outside 14 State Region, SD, UT, WA, and WY.

Sincerely, Nancy J. Hoag Wholesale Product Manager